ML20247G069
| ML20247G069 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/31/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8904040114 | |
| Download: ML20247G069 (6) | |
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David W. Cockfield Vice President, Nuclear March 31, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington DC 20555
Dear Sirs:
Inservice Inspection Relief Requests First Ten-Year Interval Under the provisions of Title 10, Chaptor I of the Code of Federal Regulations, Part 50, Section 55a, Paragraph g [10 CFR 50.55a(g)],
exceptions to examination and test requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code may be taken when the examination or test requirements are determined to be impractical. Several necessary exceptions to ASME Section XI (1974 Edition and Addenda through Summer 1975) requirements for hydrostatic testing were identified near the end of our first ten-year inservice inspection (ISI) interval, but relief requests were not submitted prior to the end of the interval. Due to a misinterpretation of 10 CFR 50.55a(g)(5)(iv), we believed an additional 12 months was provided in which we could submit the requests. Prior to submitting them, yet aircady past the first ten-year interval, it was recognized that 10 CFR 50.55a(g)(5)(iv) applies to the succeeding vice preceding inspection interval.
Copies of the relief requests that were not submitted are attached, showing the bases for our determination that the alternative examinations which were performed provide adequate, practical assurance of the integrity of the affected components.
Furthermore, the correct Aw1 1
8904040114 890331 k
PDR ADOCK 05000344 i
Q PDC G SW SJmon SPeet Portand OrNon 97204
Portlarici Genetal Elechic Coi s pEmTy i
Document Control Desk l
March 31, 1989 Par,e 2 interpretation of 10 CFR 50.55a(g)(5)(iv) will be specifically addransed in the upcoming Revision 1 of Topical Report PGE-1049, " Inservice Inspection Program Second Ten-Year Interval."
Should you have any questions, please contact Scott Bauer at (503)A64-8311.
Sincerely, lA Attachment c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant
.g Trojan Nuclear Plant Documsnt Control Dask Docket 50-344 March 31, 1989 License NPF-1 Page 1 of 1 CLASS 1 TO CLASS 2 BOUNDARY RELIEF REQUEST Line
Description:
)
(1) Safety Injection System - [ Piping and Instrument Diagram (P&lD) M-206)
)
(a) Boron injection tank T-207, discharge piping to the Reactor Coolant System (RCS) loops cold-legs (3-inch SI-2501R-3), and the test connection piping (3/4-inch SI-2501R-23 and 1-inch SI-2501R-3) from motor-operated valves MO-8801A and MO-8801B, and air-operated valve CV-8843 and manual valve 8925 to check valve 8815.
(b) Safety injection pumps (SIP), P-203A and P-203B, discharge to the RCS loops hot-legs (2-inch and 4-inch SI-2501R-1), and the test connection piping (3/4-inch SI-2501R-22 and 1-inch SI-2501R-23) from motor-operated valves MO-8802A and MO-8802B to check valves 8905A, 8905B, 8905C, 8905D, and air-operated valves CV-8824 and CV-8881.
(c) SIP discharge to.the RCS loops cold-legs (2-inch and 4-inch SI-2501R-1), and the test connection piping (3/4-inch SI-2501R-1) from motor-operated valve MO-8835 to check valves 8819A, 8819B, 8819C, 8819D and test connection valve CV-8823.
ASME Code Class:
All affected piping is ASME Section XI, Class 2.
ASME XI Examination Requirements:
Article IWC-5000 requires that the system hydrostatic test pressure shall be 1.25 times the system design pressure.
The test pressure may be reduced where the testing must be conducted at temperatures above 100*F.
The test pressure requirement for the system is 1.25 times the design pressure of the Class 2 portions of the Safety Injection System adjacent to the RCS (3107 psig).
Basis for Relief:
Pressurizing these lines to the hydrostatic test pressure required by IWC-5000 would require pressurizing the RCS in excess of that required by IWB-5000 due to the flow direction of the check valve from the Class 2 system to the Class 1 system. Pressurizing the RCS to the Class 2 pressure requirements is I
undesirable because of the limitations on the hydrostatic test pressure and l
the number of hydrostatic test cycles incorporated into the design of the l
system components.
1 Alternative Examination:
These lines were pressurized and visually examined during the adjacent Class 1 RCS hydrostatic test which was conducted at 2280 psig pressure and greater than 500*F temperature il.02 times the system nominal operating pressure).
2563W.0389
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" Trojan; Nuclear Plant
. Document Control Dask DocketE50-344' March 31,.1989 License.NPF-1 Page 1 of 2 CLASS 2 TO 3 OR NON-ASME SECTION'XI BOUNDARY RELIEF REQUEST
- Line
Description:
(1) E hemical and Volume Control System - [ Piping and Instrument Diagram (P&ID)
C M-20?]1 (a) 2-inch CS-151R-7 between check valve 8445 and manual valve 8441.
(b) 2-inch CS-151R-7 between check valve 8442 and motor-operated valve
'MO-8104.
(c) 'l-inch CS-151R-5 between check valve 8436 and manual valve 8435.
(d) 8-inch CS-151R-5 between check valve 8546, and motor operated valves MO-112D and MO-112E.
(e). 1-inch CS-25C1R-25 between check valve 8411, and manual valves 8410 and 8376.
(2) Containment Spray System - (P&ID M-207)
(a) 14-inch HCB-14 between motor-operated valves MO-2050A and MO-2050B, and check valves CS2001 and CS2002.
(3) Main Steam System - (P&ID M-208)
(a) '28-inch EBB-1 from air-operated check valve CV-2216 to check valve MS2001, and manual valves MS197 and MS158.
(b) 28-inch EBB-1 from air-operated check valve CV-2236 to check valve MS2002, and manual valves MS198 and'MS160.
(c) 28-inch EBB-1 from air-operated check valve CV-2256 to check valve MS2003, and manual valves MS199 and MS162.
(d) 28-inch EBB-1 from air-operated check valve CV-2276 to check valve MS2004, and manual valves MS200 and MS164.
ASME Code Class:
_All affected piping is ASME Section XI, Class 2.
ASME XI Examination Requirements:
Article IWC-5000 requires that the system hydrostatic test pressure shall be at least 1.25 times the system design pressure.
The test pressure may be reduced where testing must be conducted at temperatures above 100*F.
Basis for Relief:
Check valves are oriented to flow into or from adjacent Class 2 systems, Class 3 systems or non~ASME Section XI piping. This prevents the isolation of the applicable sections of the Class 2 lines from the adjacent lines.
l.
. Trojan Nuclear Plant Document Control Dask Docket 50-344 March 31,-1989 License NPF-1 Page 2 of 2 Alternative Examination:
The entire class boundary was visually examined during the hydrostatic test of the class 2 piping, even though the areas of requested relief were not pressurized.
I l
2563W
is, i
Trojan Nuclear Plant Document Control Dnsk Docket 50-344 March 31, 1989 License NPF-1 Pago 1 of 1 CLASS 3 TO NON-ASME SECTION KI BOUNDARY RELIEF REQUEST Line
Description:
(1) Chemical and Volume Control System - [ Piping and Instrument Diagram (P&ID)
M-202]
(a) 1-inch HCC-62 betweer manual valve CK009 and check valve CH2006.
(b) 1-inch HCC-62 between manual valve CM010 and check valve CM2007.
(2) Chemical and Volume Control System - [ Piping and Instrument Diagram (P&II )
M-204]
(a) 2-inch CS-151R-15 between check valve 8348 and manual valve 8328.
(3) Main Steam System - (l'&ID M-208)
(a) 3-inch and 3/4-inch EBD-7 piping between air-operated valve CV-1451, check valve MS2006 and manual valve MS165.
(b) 3-inch and 3/4-inch EBD-7 piping between air-operated valve CV-1452, check valve MS2007 and manual valve MS167.
(c) 3-inch arid 3/4-inch EBD-7 piping between air-operated valve CV-1453, check valve MS2008 and manual valve MS169.
(d) 3-inch and 3/4-inch EBD-7 piping between air-operated valvo CV-1454, check valve MS2009 and manual valve MS171.
(4) Radioactive Gaseous Waste System - (P&ID M-222)
(a) 1-inch HCC-65 between check valve GR2023 and air-operated valve CV-4336.
(b) 1-inch HCC-65 between check valve GR2024 ano air-operated valve CV-4353.
(c) 1-inch HCC-65 between check valve CR2025 and air-operated valve CV-4342.
(d) 1-lneh HCC-65 between check valve GR2026 and air-operated valve CV-4360.
ASME Code Class:
All affected piping is ASME Section XI, Class 3.
ASME XI Examination Requirements:
Article IWD-5000 requires that the system hydrostatic test pressure shall be at least 1.10 times the systen design pressure.
Basis for Relief:
Check valves are oriented to flow into a class 3 system from a non-ASME Section XI system.
During the Class 3 hydrostatic tests, portions of the non-ASME Section XI system could be overpressurized.
Alternative Examination:
The entire c)c:ss boundary was visually examined daring the hydrostatic test of the class 3 system, even though the areas of requested relief were not pressurized.
2563W
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