ML20245J983
| ML20245J983 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/07/1989 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20245J987 | List: |
| References | |
| NUDOCS 8908180254 | |
| Download: ML20245J983 (5) | |
Text
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TOLEDO EDISON 4 can, e-w com.=
DONALD C. SHELTON Vee Presdent-Nuclear (419)D49-2300 Docket Number 50-346~
License Number NPF-3 Serial Number 1686 August 7, 1989' United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555
Subject:
Proposed Alternative to ASME.Section XI Requirements for End of Interval Hydrostatic Test of the Steam Generators and Auxiliary Feedvater Valve Replacement Gentlemen:
ASME Boiler and Pressure Vessel Code,Section XI requires that the Class.2 portion of the steam generators, associated auxiliary feedvater, main feedvater, and main steam piping ~be hydrostatically tested at or near the end of each 10-year inservice inspection (ISI) interval. The Code requires that-the test be perfornied at 1313 psig and at 130'F to 200*F vith a 4-hour hold:
time. The purpose of this letter is to propose an alternative test to the.End of Interval Class 2 Steam Generator Hydrostatic Test and for the replacement of auxiliary feedwater (AFV) valves FV599 and FV608-(AFV to steam' generator I
stop valves) at the' Davis-Besse Nuclear Pow 2r Station (DBNPS).
The detailed description and justification for the proposed, alternative to:the.
ASME Code requirement is provided in. Attachment 1.
.An information only copy Fw+
of DBNPS drawings M-007A and M-007B, " Steam Generator Secondary System", is provided'in Attachment 2.
On the basis of radiological considerations and resource requirements, Toledo Edison proposes to perform a' hydrostatic test similar to the requirements for Class 1 piping. The proposed alternative test N Z vould be a 4-hour pressure test at 957 psi (10% above normal operating g'
pressure) and normal system operating temperature followed by a VT-2 visual inspection of the entire test boundary.
pc This proposal is submitted pursuant to 10CFR 50.55a, Paragraphs (a)(3) and
~
- rg (g)(5)(iii). Toledo Edison was granted a similar relief request for testing' h
following the auxiliary feedvater header replacement.during the steam Ja generator repair program in July, 1982 [ Reference Toledo Edison Serial Number har 830, dated June 22, 1982, and NRC response dated July Q
Log Number 1044)].
' 29, 1982 (Toledo Edison' i
. - l OWg # ;
THE TOLEDO EDISON COMPANY EDISON PLAZA
' 300 MADISON AVENUE TOLEDO, OHIO 43652
.. AFg
i Docket Number 50-346
- License Numbar NPF-3 Serial Number 1686 Page 2 Toledo Edison requests NRC approval of this preposed alternative by October 31, 1989, in order to facilitate scheduling of testing during the sixth refueling outage.
Should further information be required, please contact Mr. R. V. Schrauder, Nuclear Licensing Manager, at (419) 249-2366.
Very truly yours, w
hj-GBK/dlm j
Attachments cc:
P. Byron, DB-1 Senior Resident Inspector A. B. Davis, Regional Administrator, NRC Region III T. V. Vambach, NRC/NRR DB-1 Senior Project Manager l
State of Ohio l
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_.___.______._________a
Docket' Number 50-346 4
License Number NPF-3 Serial Number 1686 -
- Page 1 Proposed Alternative to ASME Code Required Testing Components: Steam Generators E-24-1 and E-24-2 and associated auxiliary feedvater, main feedvater, blowdown and main steam piping.
Function: To remove heat'from reactor coolant system.
ASME Class: 2 Testing Requirements: VT-2 visual examination during a secondary system hydrostatic test at a pressure of 1313 psig, temperature of 130' to 200'F vith a 4-hour hold time.
Reference:
ASME Code Section XI, 1977 Edition through the Summer 1978 l
Addenda.
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l Basis for Proposed Alternative l
1.
Code Test Requirements for Class 2 Piping:
A.
Table IWC-2500-1, Examination Category C-H, Code Item Numbers C7.11 and C7.21 requires a test per IWC-5222 each inspection interval. Note 5 of the table permits the hydrostatic test to be performed at or near the end of the inspection interval or during the same inspection period of each inspection interval of Inspection Program B.
B.
IVA-4000 requires a system pressure test be performed after repairs are made by velding. The replacement of FV599 and FV608 requires a system pressure test to be performed in accordance with IUC-5222.
(-
C.
IVA-5211 " Test Description" requires a system pressure test be performed in conjunction with:
"(d) A system hydrostatic test conducted during a plant shutdown at a pressure above nominal ~ operating pressure or system pressure.for j
vhich overpressure protection is provided."
In the case at Davis-Besse Unit 1, the lovest overpressure protection device is 1050 psig.
In accordance with IVA 5213(d) the required test hold time vould be 4-hours.
D.
IVC-5222 " System Hydrostatic Test" requires:
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"(a) The system hydrostatic test pressure shall be at least 1.10 times the system pressure P for systems with design temperature of j
200'F.(93'C) or less,yyand at least 1.25 times the system pressure l
P f r systems with design temperature above 200'F (93'C)..The i
sv the number of saf! shall be the lowest pressure. setting among system pressure P }y or relief valves provided for overpressure protection within the boundary of the system to be tested."
In the case of Davis-Besse Unit 1, the test pressure would be 1050 x 1.25 - 1313 psig.
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1 Docket Number 50-346 License Number NPF-3 Serial Number 1686 -
- I Page 2 1
E.
IVC-5230 " Temperature" states:
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"(a) The system test temperature during a system hydrostatic test in system containing ferritic steel components shall meet the requirements specified by fracture prevention criteria."
"(b) In systems containing ferritic steel components for which fracture toughness requirements were neither specified nor
- required in the construction of the components, the system test temperature shall be determined by the Owner."
The hydrostatic test temperature would have to be a minimum of NDTT + 60 F, which would be 130'F.
F.
In summation, the Code hydrostatic test parameters for these systems
{
vould be 1313 psig at a minimum of 130'F vith a 4-hour hold time.
I 2.
Code Test Requirements for Class 1 Piping:
A.
IVB-5222 (a), " System hydrostatic test shall be conducted at a test pressure of 1.10 times the system nominal operating pressure, P, that corresponds with 100% rated power except where the test is cond8cted at temperatures above 100*F (38'C) to meet the requirements of IVB-5230."
B.
IVB-5222 (b), "The system hydrostatic test may be conducted at the reduced test pressure of Table IVB-5220-1 to meet the requirements of IVB-5230."
C.
Table IVB-5220-1, " Test Pressure", requires a test pressure of 1.10 P for tests conducted at 100'F.
In the case of Davis-Besse Unit 1, if this system was designated as Class 1, the hydrostatic test vould be conducted at 870 (P ) x 1.10 -
957 psig, compared to 1313 psig for the Class 2 hydrostatic test.
Toledo Edison considers that the Class 1 requirement more realistically considers the pressure-temperature relationship of the system or portions of the system to be hydrostatically tested.
3.
Ramifications of Code Testing of Class 2 Performance of the hydrostatic test specified by the Code for Class 2 l
vould require the following:
A.
Blanking of 9 Code safety and 2 atmospheric vent valves per system.
B.
Pin blocking all spring hangers on the main steam, auxiliary feedvater, main feedvater and blowdown systems.
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4 Docket l Number 50-346 License Number NPF-3 Serial Number-1686 -
Page 3 C.
. Temporary piping and connections between the hydrostatic test pump and several locations in the system routed through radioactive control areas requiring:
(1) Decontamination of temporary piping before and after test (2) ALARA considerations:
estimated penalty of 50' millirems per man.
D.
An estimated total of 2287 additional man-hours.
E.
Approximately 4.5 days delay in reactor startup.
4.
Alternative Examination Allowed by Code:
A.
IWC-2500, " Examination and Pressure Test Requirements" states:
" Components shall be examined and pressure tested e.s specified in Table IUC-2500-1. The method of examination for the components and parts of the pressure retaining boundaries shall comply vith those tabulated in Table IWC-2500-1 except where alternate examination methods are used that meet the requirements of IVA-2240."
B.
IVA-2240, " Alternate Examinations" states:
" Alternative examination methods, a combination of methods, or newly developed techniques may be substituted for the methods specified in this Division, provided the Inspector is satisfied that the results are demonstrated to be equivalent or superior to those of the specified method."
Alternative Examination Proposed:
l Alternative examinations in lieu of the hydrostatic test requirements of ASME Section XI, IVA-3211(d) and 5214(b) and IWC-5222(a).
A.
Based'on the above technical and radiological considerations, additional outage time and cost with no noted safety benefits, Toledo Edison requests permission to perform in lieu of the secondary hydrostatic test described in paragraph lE, a System Reduced Pressurc Hydrostatic. test (at 957 psig and operating temperature with a 4-hour hold time in Mode 3) followed by a VT-2 visual inspection of the entire test boundary. This test approximates the Class 1 requirements and offers a more meaningful evaluation of the system.
The 48 manhours (with no downtime) required to conduct this test are-insignificant when compared to the 2287 manhours (with a 4.45' day startup delay) required for the Class 2 hydrostatic test.
Other i
benefits include the elimination of those items described in ubove L
Section 3.
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