ML20235U881

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Safety Evaluation Supporting Request for Relief from Certain Exam & Hydrostatic Test Requirements of ASME Code
ML20235U881
Person / Time
Site: North Anna Dominion icon.png
Issue date: 07/13/1987
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20235U849 List:
References
NUDOCS 8707220623
Download: ML20235U881 (30)
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ENCLOSURE -l SAFETY EVALUATION REPORT ON REQUESTS FOR RLLIEF FROM SECTION XI j EXAMINATION AND HYDROSTATIC TEST REQUIREMENTS l

VIRGINIA ELECTRIC AND POWER COMPANY l NORTH ANNA POWER STATION UNIT 1 DOCKET NO. 50-338

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. I. BACKGROUND INFORMATION Technical Specification 4.0.5 for North Anna Power Station Unit I states that inservice examinations and tests of ASME Code Class 1, 2, and 3 components shall be performed in accordance with the requirements of Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50.55a(g) except where specific written relief has been granted by the Commission. 10 CFR 50.55a(g) requires inservice inspection and testing programs to be updated to later editions and addenda of Section XI at the beginning of each ten year interval of plant operating life. However, certain requirements of later editions and addenda of Section XI are impractical to perform an older plants because of the plant's desi0n, component geometry, and materials of construction. Thus, 10 CFR 50.55a(g)(6)(1) authorizes the Commission to grant relief from those requirements upon making the necessary findings.

By letter dated February 6, 1987, Virginia Electric and Power Company (VEPCO)

(the licensee) submitted requests for relief from certain examination and testing requirements of Section XI for North Anna Power Station Unit 1. These requests for relief pertain to the requirements of the 1974 Edition including the Summer 1975 Addenda of Section XI for component examinations and the 1977 l Edition including the Summer 1979 Addenda of Section XI for hydrostatic '

testing requirements. Use of the later Code edition and' addenda for the hydrostatic testing requirements is allowed by the regulation and was approved by the NRC for North Anna Power Station Unit 1 as documented in a letter dated June 7, 1982. As a result of discussions via telepbone on March 24 and Aprii 29 j 1987, between the staff and Virginia Electric and Power Company personnel, the submittal was revised and transmitted by letter dated May.22, 1987. In the i revised submittal, three relief requests concerning bolting examinations werm withdrawn. The requests, suppo~ r ting information, and the findings made by the staff are presented in this report.  ;

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I II. REQUESTS, SUPPORTING INFORMATION, AND EVALUATIONS OF IMPRACTICAL EXAMINATION REQUIREMENTS A. RELIEF REQUE$T FROM CLASS 1 PUMP CASING' EXAMINATION

1. ASME Section XI Examination Requirement - 1974 Edition through Summer 1975 Addenda
a. Item No. B5.6, Category B-L-1: The examinations performed 1 .I during each insoection interval shall include 100% of the pressure-retaining welds in et least one pump in each group .

of pumps performing similar functions in system (e.g.,

recirculating coolant pumps). Tho examination method shall be volumetric.

b. ' tem No. 85.7, Category B-L-2. One pump in each of the group c: pumps performing similar functions in the sytem shall be .{

examined during each inspection interval. This examination may be performed on the same pump se'sected for the Category B-L-1 examination. The examination method shall be visual..

P. Alternate Examination Prfposed by Licensee for Item Not B5.6 and B5.7 VEPC0 proposed the following alternative:

In lieu of Volumetric Examinations, Virgirila Electric and Power Company proposed to perform:

1) 100% visual examination of the external surfaces only of one pump's casing welds to the extent and frequency of Examination Category B-L-2.
2) Surface examination to the extent practical of the exterral casing weld (s) of one pump only, to the I conditions and frequency of Examination Category B-L-2.
3. Licensee's Reason for Relief Request VEPCO's basis for the relief request is as follows:

The North Anna Power Station Unit I reactor coolant pumps are Westinghouse Model 93 contrciled leakage pumps.

The Model 93 pump casing is fabricated by welding four stainless steel castings together. Thus, there are three circumferential pressure boundary welds in the pumps that are to be examined in accordance with Category B-L-1 and B- L- 2.

l Since the installation of these pumps, it lias been recognized that a volumetric examination of the casing welds is not practical with today's ultrasonic techniques.

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The physical properties of tae stainless steel casing and weld material preclude a meaningful ultrasonic examination.

Thus, the capability to examine these pump casing welds in the field did not exist until recently. In the spring of 1981 an examination was performed on one of the reactor l

coolant pumps at the R. E. Ginna plant using the miniature linear accelerator (MINAC), which was built under an EPRI-sponsored program. This equipment has been made available for the volumetric examination of reactor coolant pump casing walds.

The volumetric examination method is radiographic and is perforn.ed by placing the MINAC inside the pump casing and placing film on the outside of the pump. To perform the examination, the pump must be completely dis &ssembled,

- including removal of the diffuser adapter and casing adapter.

This amount of disassembly is far beyond the amount of disassembly performed for normal maintenance. Insulation must also be removed from the exterior of the pump casing.

The examination has been performed at four different sites, all of which have the Westinghouse Model 93 pump. The MINAC examination was performed at Ginna in the spring of 1981, at Point Beach Unit 1 in the fall of 1981, at Turkey Point Unit 3 early in 1982, and at H. B. Robinson Unit 2 later )

in 1982. No problems with the welds were found at any of the sites. A review of the original radiographs of the Point Beach Unit 1 pump was performed prior to the MINAC examination, I and all the landmarks found were identifed during the field examination with no apparent change.  ;

The successful performance of this volumetric examination, using the MINAC at four different sites demonstrates that the method is capable of satisfying ASME Section XI examination requirements; however, the performance of the examination has shown that there is a relatively high .

radiation exposure associated with it. The total exposure I associated with insulation removal, disassembly, examination, and reassembly of the pump has averaged about 40 man-rem.

There have been no defects identified by the four er.amina-tions performed on these pumps to date. A volumetric examination was attempted at North Anna in 1982. A radio-i active source was placed within the pump casing and film around the outside. The developed film did net meet the density requirement for an acceptable examination. This examination was attempted twice at Surry. Both examinations yielded similar results.

The pumpi cesing examination.s are also not justified from a cost /t hefit perspective, The pump disassembly, examination and ressaembly is estimated to cost 5750,000.

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4. Staff Evaluation and Conclusion The reactor coolant pumps at North Anna Unit 1 are fabricated  !

i from thick-wall, cast stainless steel material. 'The pump's' l l

casing design and material of construction make the Code required volumetric and visual examination:t impractical to  ;

l perform. Although radiographic examinations.have pern performed.

on similar design pump casings, the man-rem exposure and burden .l Placed on the licensee by imposing the requirements exceed;the j l gain in plant safety when the licensee's proposed alternative l l examination, data obtained from other examinations indicating i no failures or reportable service-induced flaws in the pumps'. l casings, and the materials' fracture toughness properties are considered. Based on this, the staff' concludes that relief from the pump casing examinations may be granted ss requested. 1 B.

RELIEFREQUESTFROMCLASS1VALVEBO_DYVISUALEXAMINATION

1. AjHE Section XI Examination Requirement - 1974 Edition through Summer 1975 Addenda l I

Item No. B6.7, Category B-M-2: Visual examination of the j internal pressuie boundary surfaces, on valves exceeding 4 in. '

nominal pipe size. One valve in each group of valves of the same constructional design, e.g., globe, gate, or check valve, manufacturing method and manufacturer that perform similar  ;

functions in the system shall be examined during each inspection interval.

The examination may be performed at or near the end of the inspection interval.

2. Alternate Examination Proposed bv Licensee VEPC0 proposed the following alternative:

In lieu of examination of each similar valve's interior on lines 4 inch nominal pipe size and larger during the interval, Virginia Electric and Power Company proposes to examine only those valves in this category which are j disassembled during the remainder of the first interval 1 for maintenance purposes.

3. Licensee's Raason for Relief Request VEPCO's basis for the relief request is as follows:

Disassembly of a valve which has been functioning within acceptable parameters for the sole purpose of examination is contrary to good maintenance practices since the likelihood of failure may be increased. These components are subjected to an alternate form of performance and/or leakage I

monitoring, such as inservice valve testing, Appendix J leak rate testing, or primary coolant system leak detection.

Valves in this category are constructed of cast austenitic stainless or carbon steels, which have been identified as unlikely to experience f ailure by cracking. Finally, l considering the uncertain benefit involved, it is difficult l te justify the additional radiation exposure which would be incurred in the valve disassembly, examination, and valve

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reassembly.

We, therefore, believe that performing a visual examination of the interior of one valve in a group of similar valves I within the Class I pressure boundary at North Anna Power Station Unit I during the first ten year inservice inspection inte vtl does not provide an increase in safety above that

_ providea by routine inservice valve testing and pressure testing requireo by ASME Section XI. Therefore, the costs and radiation exposure associated with this examination are not justifiable.

Based on the preceding factors, we request relief from performing a visual examination of the interior surface of one valve in a group of similar valves on piping 4 inch nominal pipe size and larger at North Anna Power Staiion Unit I during the first ten year inservice inspection interval, unless the valve is disassembled for maintenance I

between now and the end of the interval.

4. Staff Evaluation and Conclusion Disassembly of Class 1 valves subject to interncl visual examination j by Section XI, in the absence of other required maintenance, repre-sents an undue burden and hardship on the licensee without a compen-I sating increase in plant safety. The required preparation, visual examination, and reassembly of the valves would cause excessive exposute to radiation of personnel without a significant gain in assurance of the valves' structural integrity over that obtained by l the licensee's proposed alternative and other examinations and tests  !

to which the valves are subjected. The staff therefore concludes that the requested relief from the visual examination requirement may be granted pursuant to 10 CFR 50.55a(a)(3)(ii).

C. RELIEF REQUEST FROM VISUAL EXAMINATION OF CLASS 1 INTERIOR CLAD I SURFACES OF VESSELS OTHER THAN REACTOR VESSELS

3. ASME Section XI Examination Requirement - 1974 Edition through l .

Summer 1975 Addenda Item No. B2.9, Category B-I-2 Pressurizer Cladding and Item No. B3.8, Category B-I-2, Heat Exchanger and Steam Generator i

Cladding: "The examinations performed during each inspection I

interval shall cover 100% of the patch areas." The exam method shall be visual.

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2. Alternate Examination Proposed by L,1censee for Item Nos. B2.9 and B3.8 i

VEPC0 stated the following:

Virginia Electric and Power Company proposed no sdditional examinations in these catagories since later editions and addenda of ASME Section XI approved by the NRC and incorporated into 10 CFR 50.55a no longer require cladding examinations.

3. Licensee's Reason for Relief Request VEPCO's basis for the relief request is as follows:

The Edition of the ASME Code,Section XI in effect q l for the first ten year inservice inspection interval I

} at North Anna Power Station is the 1974 Edition with l Addenda through Summer 1975. This edition of the Code requires ieactor vessel, pressurizer and steam generater 4 l

cladding examinations. Subsequent editions and addenda I to the Code which have been approved by the NRC for incorporation into 10 CFR 50.55a have deleted the cladding inspection.

Recognizing this deletion and the intent of the ASME Section XI examination to provide monitoring of conponent j degradation over the plant's service interval, it is our i position that the radiation exposure and cost associated '

with the cledding examinations are not commensurate with the ivrease in safety realized. The clad examination rer & ; obtained during the first inspection interval will i j

no. Fe dicactly comparable to examination results in later intervals.

Table 1 below presents a summary of the cladding examinations required by the first ten year inservice inspection plan and the results of those examinations performed to date.

TABLE 1 - CLADDING EXA3 )

Pressurizer - Isometric Number - VRA-1-2100 Component Number Exam Date Results CPO-1 Scheduled for REF 87*

i Steam Generator - Isometric Number - VRA-1-3100 CP01 A REF 85 No Reportable Indications CP02 A REF 85 No Reportable 3ndications q CPC3 B Scheduled for REF 87* i CPO4 B Scheduled for l REF 87*

CP05 C REF 85 No Reportable Indications CP06 C REF 85 No Reportable Indications j i

  • Relief Proposed REF 85 - Refueling Outage 1985 l

Based or the preceding f6ctors, we request relief from the remaining {

Pressurizer and Steam Generator clcdding examinations at North Anna j Power Statior. Unit I during the first ter, year inservice inspection i interval.

4. Staff Evaluation and Conclusion l

The steam generator and pressurizer cladding examinations are  !

impractical to perform w'1en the radiation exposure to personnel I versus the gain in safety provided is considered. The later editions of the Code deleted this requirement. The licensee has performed some examinations without reportable indications. The j ten-year scheduled vessel examination covers a considerable amount l of cladding in areas susceptible to cracking, thereby providing  ;

surveillance that is more meaningful than the Category B-I-2 re- I qui rement . Based on the above, the staff concludes that relief from performing the remaining examinations may be granted as requested.

D. RELIEF REQUEST FROM VISUAL EXAMINATION OF CLASS 1, 2, AND 3 HYDRAULIC SHOCK SUPPRESSORS

1. ASME Sectiun XI Examination Requirements - 1974 Edition through Summer 1975 Addenda

, a. Item Nos. B4.10, B5.5, and B6.5 Examination Category B-K-2 l Support romponents and Item Nos. C2.6, C3.4, and C4.4 l

Examination Category C-E-2, Support Components: The crea

shall include the support compo1ents that extend from the l piping, valve and pump attachment to and including the

! attachment to the supporting structure. The examination j performed during each inspection interval shall cover all j support components.

l l The support settings of constant and variable spring type hangers, snubbers , and shock absorbers shall be verified.

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b. Category IWD-2600(c) Support Components

" Support (restraints), and hangers for components exceeding four-inch ncminal pipe size whose structural integrity is relied upon to withstand design loads when the system function l is required shall be visually examined co detect any. loss of support capability and evidence of inadequate restraint.

2. Alternate Examination Proposed by Licensee for Item Nos. B4.10, B5.5, B6.5, C2.6, C3.4, C4.4 ,and 1 Category IWD-2600(c)

VEPCO proposed the following alternative:

Virginia Electric and Power 'omoany C requests permission to examine the hydraulic shock-suppressors on Class 1, 2, and 3 systems according to the requirements of-the facility Technical Specifications in lieu of the Section XI requirements listed above.

3. Lirensee's Reason for Raljet' Reauest VEPCO's basis for the relief request is as follows:

The hydraulic shock suppressors on Class 1, 2, and 3 systems are currently subjected to an ongoing Examination and testing program detailed in the Jechnical Specifications which exceeds the requirements of ASME Section XI. The requirements of the Technical Specifications specify examinations to be performed at a minimum frequency of 18 months. The examination frequency is increased for test  !

failures. 7his program is designed to demonstrate continued operational readiness and structural . integrity of shock suppressors. The visual examination boundary required by Technical Specifications covers the came areas as the ASME Section XI examination boundary.

Additional visual examinations are performed beyond the ,

ASME Section XI requirements to determine operability and freedom of movement The Technical Specifications require-nients for snobber examinations meet and exceed the ASME  ;

Section XI visual examination requirements.for component '

supports.

4. Staff Evaluation and Conclusion The Technical Specifications for visual examination of support components at North Anna Unit 1 exceed the requirements of the 1974 Edition of Section XI. By performing the Technical Specifications requirements, compliance with the Code is being met by the licensee.

Relief, therefore, from the Code requirements is not necessary in this case.

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l l E. RELIEF REQUEST FROM 100% NONDESTRUCTIVE EXAMINATION OF CLASS 1 PRESSURE RETAINING BOLTS AND STUDS TWO-INCH AND LARGER IN DIAMETER i DN PUMPS AND VALVES l

1. ASME Section XI Examination Requirements - 1974 Edition through Summer 1975 Addende Examination Category B-G-1, Pressure Retaining Bolting 2 inches and Larger in Diameter Item Nos. B5.1, B5.3, B6.1, B6.2, and B6.3: The areas shall include bolts, studs, nuts, bushings, washers, and threads in base material and flange ligaments between threaded stud holes.

The examinations performed during each inspection interval shall cover 100% of the bolts, studs, nuts, bushings, and threads in base ,

material and flanges ligaments between threaded stud holdes.

Bushings, threads, and ligaments in base material of flanges are required to be examined only when the connection is disassembled.

Bolting may be examined either in place under tension, when the i

connection is disassembled, or when the bolting is removed.

The examination shall be volumetric for Items Nos. B5.1 and B6.1.

Volumetric and surface examinations are required for Items Nos.

B5.2 and B6.2. A visual examination shall be performed on Item Nos.

B5.3 and B6.3.

2. Alternate Examination Propcsed by Licensee for Item Nos. B5.2, B5.3, B6.1, B6.2, and B6.3 VEPC0 proposed the following alternative:

Virginia Electric and Pcwer Company proposes to )

examine bolting of Category B-G-1 of pumps and )j valves, which have been selected for examination, '

under Examination Categories of B-L-2 and B-M-2 in lieu of 100% of the bolting.

3. Licensee's Reasons for Relief Request VEPCO's basis for the relief requtst is as follows:

i Subsequent editions and addenda of the Code which have been i approved by the NRC for incorporation into 10 CFR 50.55a l have defined the scope of Examination Category for B-G-1 to i be only that bo? ting which is part of components selected for B-L-1, and B-M-1 examinations, (pump casing and valve l bodies welds). It war the intent of ASME that bolting be examined only on components selected for B-L-2 (pump casings) and B-N-2 examinations; see inquiry BC84-390. Categories B-L-2 I

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J 'A and B-M-2. require examination of components which perform a similar function within a system. Examining bolting in the same proportion as pump casings and valve bodies provides reasonable assurance of the' component pressure boundaPy.

Bolting is an element of the pump or valve. The increase in safety by exanining a larger proportion of bolting than the components is not commensurate with the associated radiation exposure required to perform the examination.

4. Staff Evaluation and Conclusions This requsst was withdrawn by letter dated May 22, 1987, in which the licensee stated:

" Impracticality for performing the required examinations of

- the components in this category cannot be shown at this time.

Virginia Electric and Power Company, therefore, withdraws this request."

F. RELIEF REQUEST FROM 100% NONDESTRUCTIVE EXAMINATION OF CLASS 1 PRESSURE RETAINING BOLTING LESS THAN TWO-INCH DIAMETER

1. ASME Section XI Examination Requirements - 1974 Editien through Summer 1975 Addenda Examination Category B-G-2 Pressure Retainirg Bolting, Less Than Two-Inch Diameter Item No. B4.12 Piping Pressure Boundary and Item No. B6.9 Valve Pressure Boundary: "The area shall include bolts, studs and nuts.

The examinations performed during ecch inspection interval shall cover 300% of the bolts, studs, and nuts. Bolting may be examined in place under tension, when the connection is disassembled, or when the bolting is removed. The examination shall be visual."

2. Alternate Examination Proposed by Licensee for Item Nos. B4.12 l and B6.9 VEPCO proposed the following alternative:

Virginia Electric and Power Company proposes to examine  ;

bolting of Category B-G-2 of piping and valves which have i been selected for examination under Examination Category of B-J and B-M-2.

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3. Staff Evaluation and Conclusion i

This relief request was withdrawn by letter dated May 22, 1987, )

in which the licencee stated:

" Impracticality for performin'g a visual examinstior of  ;

the remaining 10 valves in the category cannot be shown.  !

Virginia Electric and Power Company, therefore, withdraws _

this relief request."

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l G. RELIEF REQUEST FROM ULTRASONIC EXAMINATION OC CLASS 2 N0ZZLE-TO-VESSEL WELDS ON RHR HEAT EXCHANGERS

1. ASME Section XI Examination Requiremen - 1974 Edition through Summer 1975 Addenda Item No. C1.2, Category C-B: The examination shall include 100% of the nozzle to vessel attachment welds. The examination method shall be volumetric.
2. Alternate Examination Proposed by Licensee VEPC0 propose;j thc following alternative:

Due to the configuration of the RHR heat exchanger nozzle (reinforcing plate), Virgina Electric and Power Company proposes to perform:

e. ' 100% vitual examinations of the external surfaces of the weld and reinforcing plate during hydrostatic pressure test. j l

b) Insulation will be removed to allow for inspection of the tell-tale hole for leakage during hydrostatic testing. i

3. Licer.see's Reason for Relief Request l

VEPCO's basis for the relief request is as follows:

The nozzle-to-vessel welds of the RHR. heat ex_ hangers are completely covered by a reinforcing plate and are not accessible for examination as required by IWC-2500. The reinforcing plate covering the RHR heat exchanger nozzle-to-vessel welds contains j tell-tale holes such that visual examinations I can be performed for evidence of leakage.

a. STAFF nVALUATION AND CONCLUSION The nozzle-to-vessel welds of the RHR heat exchanger are completely covered by reinforcing plates required in the design of large openings ,

in the component shells and thereby inaccessible for performance of l volumetric or surface examination. Failure of the nozzle-to-vessel I weld can be detected by leakage through the tell-tale holes provided l for this reason. The licensee's proposed alternative is acceptable and will provide assurance of the contint.ed structural integrity cf the weld or early detection of throughwall cracks. The staff there-fore concludes that relief fr0.n the requirement may be granted.

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H. RELIEF REQUEST FROM NONDESTRUCTIVE EXAMINATION OF CLASS ? BOLTING, I

,LESS THAN TWO-INCH DIAMETER l 1

1. ASME Section XI Examination Requirement - 1974 Editinn through 1975 Addenda ,

item No. C1.4, Category C-D: " Visual examinations performed during i each inspection interval shall cover 100% of the bolts,. studs, nuts, i bushings, washers and threads in base materini and flange ligaments j between threaded studs holes. l Nondestructive examination shall be performed on 10% of the bolting ~;

in each joint , but not less than two bolts or studs' per jnint, j Bushings, threads, and ligaments in base material of flanges are required to be examined only when the connection is disassembled.

Bolting may be examined either in piece under . tension, when the connection is disassembled or when the bolting is removed, j The examination shall be visual and either surface or volumetric."

2. Alternate Examination Proposed by Licensee .i i

VEPCO's proposed no alterr.ative examination. .

3. Licensee's Reasons for Relief Request' 1

i VEPCO's basis for the relief request is as follows:

The edition of the ASME Code Section XI in effect for the first ten year inservice inspection interval at North Anna Power Station is the 1974 Edition with Addenda through Summer 1975.

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This Edition of the Code requires pressure vessel pressure retaining bolting exceeding 1-inch in diameter be examined.

Subsequent editions and addenda to the Code which have been approved by the NRC for incorporation into 10 CFR 50.55a have increased the size requirement for examination from 1-inch to 2-inches.

Recognizing this change and the intent of ASME Section XI examination to provide monitoring of component degradation over the plant's service interval, it is our position thet the radiation exposure ard cost associated with the bolting examinations are not commensurate with the increase in safety realized.

The examination results which would be obtained by performing these exams would not be used for comparing to later examinations.

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Based on the preceding factors we request relief from the remaining examinations on Class 2 bolts, studs, nuts, bushing, and threads in base material and flange ligaments between threaded stud holes for bolts 2 inches and less at North Anna Power Station Unit I during the first, ten year inservice inspection interval. t

4. Staff Evaluation and Conclusion '

This relief request was withdrawn by letter dated May 22, 1987, in which the licensee stated: "The original intent of this relief l request was to take advantage of later editions of the code. I Impracticality of examination for the remaining 4 valves in this  !

category cannot be shown. Virginia Electric al.d Power Company l withdraws this relief request." )

III. REQUESTS, SUPPORTING INFORMATION, AND EVALUATIONS OF IMPRACTICAL

( HYDROSTATIC TESTING REQUIREMENTS OF THE 1977 EDITION THROUGH j i SUMMER 1979 ADDENDA 0F SECTION XI j l

A. RELIEF REQUEST 1 - REQUEST TO TEST Al LOWER PRESSURE

1. System - Chemical and Volume Control )

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2. Components - Piping on" drawing 11715-FM-95C between the pumps and first flange from pumps.

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Pumps Line }

1-RC-P-1A 2"-CH-14-1502 1-RC-P-1B 2"-CH-15-1502 }

1-RC-P-1C 2"-CH-16-1502 i

3. Code Requirements - System Hydrostatic Test per IWB-5222, 1977 l Edition through Summer 1979 Addenda of Section XI, 1.10 times j systen nominal operating pressure. 3 i

, Licensee's Proposed Alternative Examination j l '

I VEPC0 proposed the following alternative:

l The normal system leakage test after each refueling is an adequate examination.

5. Licensee's Reason for Relief i l

VEPCO's basis for the relief request is as follows- i t

Pressurizing the piping listed above will also I pressurize the number one seal of the reactor i coolant pumps. This could potentially damage the number one seal. Relief was granted to Surry Power Station Unit 2 per Safety Evaluation Report dated January 24, 1986 for the samo situation as described cbove.

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6. Staff Evaluation and Conclusion '

The design of the reactor coolant pump seal injection system does not allow isolation of the pump shaft seals from the small section of piping required to be tested To impose the Code requirements could result in damage to the reactor coolant pump shaf t seal. The alternative test proposed by the licensee is an acceptable test for determining the continued structural integrity of the piping. The '

staff concludes that relief from the Code requirement may be granted as requested.

B. RELIEF REQUEST 2 - RE00EST TO TEST AT LOWER PRESSURE

1. System - Chemical and Volume Control Components - Piping located on drawing 11715-FM-95C between the

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2. i valves listed below:

Valves Line HVC-1311 and 1-CH-328 2"-CH-68-1502 ,

1-CH-325 and 1-CH-496 3"-CH-1-1502

3. Code Requirements - Class 1 System Hydrostatic Test per IWB-5222.

Po=2500 psig, To=496 F, Test Pressure is 2550 psig per IWB-5222.

4. Licensee's Alternative Examination VEPC0 proposed the following alternative:

As an alternative, the Reactor Coolant System will be pressurized to a pressure as close as practical to 2335 i

psig but not less than 2300 psig while the reactor is in a shutoewn condition to create a pressure boundary at Check Valves 1-CH-328 and 1-CH-325. The components listed abovo will then be tested to a pressure (2300 psig < test pressure < 2335 psig) as close as practical to the Reactor Coolant System pressure using a charging pump.

5. Licensee's Reason for Relief VEPCO's basis for the relief request is as follows:

Check valves 1-CH-328 and 1-CH-325 prevent the components listed above from being pressurized without pressurizing the Reactor Coolant System. The Code required test pressure of 2550 psig will overpressurize the Reactor Coolant System.

Also, the power operated relief valves (PCV-1456 and PCV-1455C) of the Reactnr Coolant System are designed to limit the pressurizer pressure to a value below the fixed high pressure rear *or trip setpoint (2385 psig). The relief valve setpoints are 2335 psig. It is not desirable to take the Reactor Coolant System above the power operated relief valve setpoint.

Similar relief was granted to Surry Power Station Unit 2 per Snety Evalustion Re;,ori. dated 01/24/86 (Docket 50-281) for components wit- ,he same design configuration.

6. Staff Evaluation and Conclusion It is impractical to test the sections of piping between the valves listed to the Code required test pressuro without applying the same pressure to the reactor coolant system because (,f the check valve arrangement in the auxiliary spray and charging lines. The licensee has proposed to test the sections of piping to a pressure between 2300 psig and 2335 psig. The staff finds the alternative test 1 pressure acceptable considering the system design and the impracticality of achieving the Code required test pressure. This system is subjected to other NDE in assessing its continued structural integrity. The staff has determined that the alternative hydrostatic test and the other examinations are adequate bases for concluding that relief may be granted as requested.

C. RELIEF REQUEST 3 - REQUEST TO TEST AT LOWER PRESSURE l

1. System - Chemical and Volume Control i
2. Components - Piping between the valves listed below located on drawings 11715-FM-95C and 11715-FM-958.

Valves Line 1-CH-496, 1-CH-HCV-1311, & 1-MOV-1289A 3/4"-CH-240-1502 2"-CH-68-1502 3"-CH-1-1502 3"-CH-79-1502

3. Code Requirement - Class 2 System Hydrostatic Test per IWC-5222.

Since there are no relief valves for the above components, test )

pressure per IWC-5222 is 3419 psig.

4. Licensee's Proposed Alternative Test VEPCO proposed the following alternative:

As an alternative, the Reactor Coolant System will be l 4

pressurized to a pressure as close as practical to 2335 psig  !

but not less than 2300 psig while the reactor is in a shutdown  !

condition to create a pressure boundary at Check Valves l 1-CH-328 and 1-CH-496. The components listed above will then j be tested to a pressure (2300 psig < test pressure < 2335 psig) j as close as practical to the Rou ter Coolant System pressure 1 using a charging pump.

5. Licentee's Reason for Relief VEPCO's basis for the relief request is as follows:

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'l Check valves 1-CH-328, 1-CH-325 and 1-CH-496 prevent the components listed above from being pressurized without l pressurizing the Reactor Coolant System. The Code required test pressure of 3419 psig will overpressurize the Reactor Coolant System.

Also, tne power operated relief valves (PCV-1456 and PCV-1455C) of the Reactor Coolant System are designed to licit the pressuri-zer pressure to a value below the fixed high pressure reactor trip setpoint (2385 psig). The relief valve setpoints are l 2335 psig. It is not desirable to take the Reactor Coolant  !

System above the power operated relief valve setpoint. .j

6. Staff Evaluation and Conclusior) l It is impractical to test the sections of piping between the valves 1 -

listed to the Code required test pressure without overpressurizing the primary system piping and components due to the arrangement of check valves. The licensee has proposed testing the piping to a i pressure between 2300 psig and 2335 psig. The staff finds the  !

alternative test pressure acceptable considering the system design and limitations encountered in attempting to comply with the Code requirements. Since the system is subjected to other NDE, the staff has determined that the alternative test proposed by the licensee l will provide an adequate part of the overall assessment of the I system's continued structural integrity. We therefore conclude that i relief may be granted as requested. I I

D. RELIEF REQUES1 4 - REQUEST TO TEST IN ACCORDANCE WITH WESTINGHOUSE I TECHNICAL MANUAL )

1. System - Feedwater
2. Components - Piping between the valves listed below located on drawing 11715-FM-74A.

Valve Connection Line Valve j i

1-FW-62 3"-WAPD-10-601 to 1-FW-68 I 3"-WAPD-9-601 j 1-FW-64 3"-WAPD-9-601 1-FW-68 1-FW-93 3-WAPD-12-601 to 1-FW-100 3"-WAPD-11-601 i 1-FW-96 3"-WAPD-11-601 1-FW-100 1-FW-126 3"-WAPD-14-601 to 1-FW-132 .j 3"-Wt.PD-13-601 1-FW-128 3"-WAPD-13-601 1-FW-132 1-FW-278 4"-WAPD-39-601 to 1-FW-68 3"-WAPD-10-601

I

- .]

i

3. Code Requirements - Class'2 System Hydrostatic Test per IWC-5222 and IWA 5213(d). P =1400 psig, T 200*F, Test Pressure is 1540 psig per d o ,

IWC-5222.

1

4. Licensee's Proposed Alternative Test l VEPC0 proposed the following alternative:

1 Since the component:, listed .above cannot be pressurized I without pressurizing the steam generator, they must be .j tested per the ' Squired manufacturer's hydrost6 tic test j method for the steam generators. Therefore, the proposed alternative examination is the examination described in the Westinghouse Technical Manual for the secondary side-of the steam genertMr. The test is to pressurize the-secondary side of tne'ste n generator to 1356 psig,. hold for 30 minutes, and then reduce to the design pressure  !

(1085 psig) for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. A VT-2 examination will then be performed.

i

5. Licensee's Reason for Reli_ef ;j VEPCO's basis for the reIief request'is as follows:

Due to check valves 1-FW-132, 1-FW-100, and 1-FW-68 the piping listed above cannot be pressurized without pressurizing the steam generators. The code required test pressure of 1540 psig would overpressurize the steam generators.

6. Staff Evaluation and Conclusion J

It is impractical to hydrostatically test the valves and piping j bounded by the valves listed to Code requirements without subjecting i the steam generators to conditions adverse to those specified in the Westinghouse Technical Manual. Therefore, the hydrostatic test j pressure for these sections of piping is limited by the test J pressure to which the steam generators are recommended being  ;

< subjected. The Code required test pressure for these sections of feedwater piping is 1540 psig and the pressure limited by the steam generators is 1356 psig. The testing procedure recommended by ,

Westinghouse is to subject the steam generators (and thus the 'l piping) to 1356 psig for 30 minutes.and then reduce the pressure j to 1085 psig. The test pressure proposed by the licensee is sufficiently higner than normal operating to adequately test the.

piping pressure boundary for its continued structural ir.tegrity.

~

Since the section of piping will be held at the Code requiced' test pressure for the steam generators for.30 minutes and then lowered .

to the design pressure and held for 3 1/2 hours prior to the VT-2 I

t

_ gg -

examination, any leakagd will W.ost likely appear at the surfaces of insulation and be detected during the examination. The staff finds the licensee's proposed alternative test as recommended by Westingnause to be acceptable. We therefore conclude that relief I from the higher pressure may be granted as requested.

E. RELIEF REQUEST 5 - REQUEST TO TEST AT LOWER PRESSORE

1. System - Feedwater, Chemical and Volume Control and Safety Injection
2. Components - Centrifugal pumps and discharge piping to first isola-tion valve on drawings 11715-FM-74A, 11715-FM-958., 11715-FM-96A.

Pumps 1-rW-P-2, 1-FW-P-3A, 1-FW-P-3B

- 1-CH-P-1A, 1-CH-P-10, 1-CH-P-1C 1-SI-P-1A, 1-5I-P-1B l 3. Code Requirements - System Hydrostatic Tests per IWC-5222 and IWD-5223.

4. Licensee's Proposed Alternative Examination l

l VEPCO proposed the following alternative:

As an alternative, the test pressure for the pump  !

I discharge and associated piping extending to the first shutoff valve on the discharge side of the pump shall be the same as that required for the i I

piping and components on the suction side of the pump. In sepport of this alternative, the 1980 l Edition, Winter of 1981 Addenda of ASME Section XI I (approved by the NRC) paragraph IWA-5224(d) allows the system test bnundary interface to be the first shutoff valve on the discharge side of the centrifugal i l pump when the primary system pressure ratings on the '

suction and dischage sides differ.

5. Licensee's Reason for Relief VEPCO's basis for the relief request is as follows:

l Centrifugal pumps and the portions nf the pump discharge lines up to the first itulation valve cannot be isolated from the pump suction.

If the discharge piping were pressurized to the required test pressure, then the suction piping and/or pcmp would be subjected to a pressure far in excess of its design with the potential for permanent damage to piping and components.

l l

l l

4

)

1 1

6. Staff Evaluation and Conclusion j The design of the centrifugal pumps and portions of the associated piping systems makes compliance with the Code hydrostatic test pressure requiremer.ts impractical due to possible damage to the pumps. This impractical requirement has been recognized and reflected in later editions of Section XI by changing the system test ooundaries to the first shutoff valve on the disc hrte side of

~

the pump. The staff concludes that relief from the requirement may be gra<ted as requested.

F. RELIEF REQUEST 6 - REQUEST NOT TO PERFORM VISUAL EXAMINATION i 1. System - Reactor Coolant

2. o C_cmnonents - Bottom of retctor vessel.
3. Code Requirements - Visual Examination per IWA-5240 during Systen Hydrostatic Test.
4. Licensee's Proposed Alternative Examination VEPC0 proposed the following alternative:

The proposed alternative examination is to examine the i bottom of the reactor vessel for evidence of leakage -

during the 10 year vessel inspection. -

5. Licensee's Reason fer Relief VEPCO's basis for the relief request is as follows:

I The systen, hydrostatic test for tha Reactor Coolant System is performed at Hot Standby MODE 3.

The bottom of the reactor vessel is inaccessible 1 due to temperature and radiological concerns. I

~

6. Staff Evaluation and Conclusion The Code requiremer,t to visually examine the bottom of the reactor I vessel is impractical to perform when the test is performed during j Hot Standby due to the high temperature and radiation levels. How- I

' ever, surveillance of the lower reactor vessel head is an essential i I part of the hydrcistatic test. The staff recommended and the licensee agreed by letter dated May 22, 'l987 to visually ins,pect the lower head during the time of examination of the reactor vessel. The staff finds that the visual inspection will provide assurance that flaws are not present and that the lower head remains structurally sound.

We therefore conclude that relief may be granted as requested provided the licensee performs a visual inspection of the lower head.

I

_.A

4 4 G. RELIEF. REQUEST 7 - REQUEST TO TEST AT LOWER PRESSURE

1. System - Residual Heat Removal
2. Comporients - Piping located on drawing 11715-FM-94A between valves. ']

listea below. 1 l

Valves Line MOV-1701 and MOV-1700 14"-RH-1-1502 L 3. Code Requirements - Class 1 System Hydrostatic Test IWB-5222. I l Po=2235 psig, Td =650 degrees F, Test pressure per IWB-5222 is l P280 psig.

4. Licensee's Proposed Alternative Test VEPC0 proposed the following alternative:

As an alternative, the components listed above will be tested in accordance with IWC-5222. ~The test pressure will be 584 psig as determineu by the setpoint of relief valves RV-1721A and RV-17218 (467 psig). This alternative is considered sufficient since the relief valves are set at 467 psig. As a result, line 14-RH-1-1502-Q1 should not see a pressure significantly higher than 467 psig. In addition, MOV-1700 and MOV-1701 will not open if the Reactor Coolant oressure is >660 psig.

5. Licensee's Reason for Relief VEPCO's basis for the relief request is as follows:

During the system hydrostatic test of the primary system, MOV-1700 is closed in addition to MOV-1701 )

in order to prevent possible overpresstrization of the Residual Heat Removal System.

Thus, the portion of the RHR system identified above I cannot be pressurized with the primary system and due l to design, it cannot be pressurized'without opening l one of the MOV's. I

6. Staff Evaluation and Conclusion j It is impractical to pressurize the pipi n between MOV-1700 and MOV-1701 because of the probability of failure of the single Class 1/2 boundary and subsequent overpressurization of Class 2 l piping in the RHR system. The licensee has proposed testing this section of piping to the requirements for Class 2 hydrostatic tests.

The staff finds the preposed test pressure acceptable. 'The visual ,

examination and the other nondestructive examinations performed on  !

I

the RHR piping will provide assurance of the continued structural integrity of the piping. The staff therefore concludes that relief may be granted.

H. RELIEF REQUEST 8 - REQUEST TO TEST AT LOWER PRESSURE

1. System - Safety Injection
2. Cumponents - Piping between the following sets of valves located on statirn print 11715-Fm-96B.

Valves Lines 1-51-83, 1-SI-190, and 1-51-195 6"-51-131-1502 1-51-86, 1-51-192, and 1 197 6"-51-133-1502 1-51-89, 1-51-194, and 1-51-199 6"-51-132-1502 1-51-95, 1-SI-211, and 1-51-204 6"-51-19-1502 2"-SI-59-1502 1-5I-99, 1-51-209, and 1-51-203 6"-51-21-1502 2"-51-61-1502 1-51-103, 1-51-213, and 1-51-205 6"-51-16-1502 2"-51-63-1502 i

3. Code Requirements - Class 1 System Hydrostatic Test per IWB-5222.

Po=2235 psig, To=160 F, Test Prese. ire per IWB-5222 is 2432 psig. l

4. Licensee's Proposed Alternative Test VEPC0 proposed the following alternative:

As an alternative, the Recctor Coolant System will be pressurized to a pressure as close as i practical to 2335 psig but not less than 2300 psig I while the reactor is in a shutdown condition to l create a pressure boundary at the first valve of  ;

each set listed above. These components will then l be tested to a pressure (2300 psig < test prassure i

< 2335 psig) as close as practical to the Reactor '~,,

Coclant System pressure using a charging pump. The Reactor Coolant System will be borated equal to or greater than cold shutdown boron concentration.

w____________-_-______--___________-______. __ .- __. _. _. -___-___ __ - _ _ _ _ _ - _ _ _

i i

5. Licensee's Reason for Relief VEPCO's basis for the relief request is as follows:

The first valve listed in each set prevents the components listed above from being pressurized-without pressurizing the Reactor Coolant System. 2 The power operated relief valves (PCV-1456 and PCV-1455C) of the Reactor Coolant System are designed to limit the pressurizer pressure to f a value below the fixed high pressure rear, tor trip setpoint (2385 psig). The relief vrtive setpoints are 2335 psig which is below the test i pressure of 2432 psig. It is not desirabl9 to take the Reactor Coolant System above the power operated relief valve setpoint.

Similar relief was granted to Surry Power Station Unit 2 per Safety Evaluation Report dated 01/24/80  ;

(Docket 50-281) for components with the same design configuration.

6. Staff Evaluation .end Conclusion It is impractical to test the section of piping between the valves listed to the C<:de required test pressure without applying _the same pressure to the reactor coolant system. The staff finds the alternative test pressure acceptable considering the system design and limitations encountered in attempting to' comply with the Code requirements. Since the system is subjected to the NDE, the staff has determined that the alternative test proposed by the licensee  ;

will provide an adequate part of the overall assessment of the  !

system's continued structural integrity. We therefore conclude that >

l relief mey be granted as requested.  ;

1 I. RELIEF REQUEST 9 - REQL'c;T TO TEST AT LOWER PRESSURE 1

1. System - Safety Injection l 2. Components - Piping and valves listed below and located on drawings 1

11715-FM-96A and 11715-FM-96B.

Valve Connecting Line Valve MOV-1890C and MOV-1890D 10"SI-18-1502/10"-SI-238-1502 1-S1-197 to 6"-S1-133-1502 1-SI-199 to 6"-51-132-1502 1-51-195 '

to 6"-51-131-1502 i

i

Valve Connecting Line Valve MOV-1890A 10"-51-15-1502 1-51-213 to 6"-SI-16-1502 1-SI-211 to 6"-51-130-1502 to 6"-SI-19-1502 MOV-1890B 10"-51-140-1502 to 6"-SI-21-1502 1-51-209 1-51-193 2"-51-55-1502 1-51-194 1-51-191 2"-51-53-1502 1-51-192 1-51-188 2"-SI-51-1502 1-51-190

3. Code Requirements - Class 2 System Hydrostatic Test per IWC-5222.

P = 2485 psig, Design Temperature is less than 200 F, Test pressure iN2733.5psig.

4. Licensee's Proposed Alternative Examination YEPC0 proposed the following alternative:

As an alternative, the Reactor l ,olant System will be pressurized to a pressure as close as practical to 2335 psig but not less than 2300 psig while the reactor is in a shutdown condition to create a pressure boundary at Chect Valves 1-51-83, 1-SI-86, 1-51-89, 1-51-95, 1-SI-99 and 1-51-103. These components will then be tested to a pressure (2300 psig < test pressure < 2335 psig) as close as practical to the Reactor Coolant System pressure using a test pump.

5. Licensee's Reason for Relief VEPCO's basis for the relief request is as fo110ws:

Check Velves 1-51-83, 1-SI-86, 1-51-89, 1-51-95, 1-51-99 and 1-51-103 prevent the components listed above from being pressurized without pressurizing the Reactor Coolant System.

The Code required test pressure of 2733.5 psig will overpressurize the Reactor Coolant System.

The power operated relief valves (PCV-1456 and l PCV-1455C) of the Reactor Coolant System are designed to limit the pressurizer pressure to a value below the fixed high pressure reactor trip l l

setpoint (2385 psig). The relief valve setpoints are 2335 psig which is below the test pressure of 2733.5 psig. It is not desirable to take the Reactor Collant System above the power operated relief valve setpoint.

1

Similar relief was granted to Surry Power Station Unit 2 per Safety Evaluation Report dated 01/24/86 (Docket 50-281) for components with the same design configuration.

6. Staff Evaluation and Conclusion It is impractical to test the sections of piping between the valves listed to the Code required test pressure without applying the same pressure to the reactor coolant system. The staff finds the alternative test pressure acceptable considering the system design and limitaticos encountered in attempting to comply with the Code requirements. Since the system is subjected to other NDE, the staff has determined that the alternative test proposed by the licensee will provide an adequate part of the overall assessment of the 1 -

system's continued structural integrity. We therefore conclude that 3 relief may be granted as requested.

J. RELIEF REQUEST 10 - REQUEST TO TEST AT LOWER PRESSURE

1. System - Safety Injection
2. Components - Piping between the sets of valves listed below located on drawing 11715-FM-96B.

Valves Line MOV-1865A and 1-SI-125 12"-51-123-1502 1-51-123 and 1-SI-125 3/4"-SI-78-1502 MOV-1865B and 1-51-142 12"-SI-124-1502 1-51-140 and 1-51-142 3/4"-51-84-1502 MOV-1865C and 1-51-159 12"-51-125-1502 1-SI-157 and 1-51-159 3/4"-51-80-1502

3. Code Requirements - Class 2 System Hydrostatic Test per IWC-5222.

Pd =2485 psig, Tg <200 F, Test pressure per code is 2733.5 psig since there is no evef pressure protection for the above components.

4. Licensee's Proposed Alternative Examination VEPCO proposed the following alternative:

As an alternative it is requested that the Class 2 components listed above be tested per IWB-5222. The l nominal operating pressure is 660 psig and temperature l 1s 120"F. Thus, testing per IWB-5222 would require a test pressure of 724 psig. This should be adequate considering the nominal operating conditions.

4

5. Licensee's Reason _,for Relief VEPCO's basis for the relief request is as.follows:

l' Check valves 1-SI-125' 1-51-142, and 1-51-159 at-1.- the Class 1 and 2 system boundaries. prevent the pressurization of the above components without pressurizing the primary system. The required test pressure is 2733.5 psig as stated above, which.would over pressurize the primary system.

6. Staff Evaluation and Conclusing It is impractical to test to the code requirement. A review of the piping for which relief from the tes*:ioressure requirement has been requested and the Code requirements indicates that the test pressure

- should be lower than that stated by the licensee. The Code requires the sections of piping to be tested at 1.1 times.the set pressure of the relief valves on the accumulators. The set pressures'of the relief valves are normally 700 psig,-thereby requiring the test pres-sure to be 770 psig. The licensee has proposed to test the sections of piping at 724 psig, the pressure required under IWB-5222. The staff finds that the test pressure proposed by the licensee is accep-table giving consideration to the design, normal operating pressure, and other NDE to which the piping'is subjected. We therefore conclude that relief may be granted as requested.

K. RELIEF REQUEST 11 - REQUEST TO TEST IN ACCORDANCE WITH WESTINGHOUSE TECHNICAL MANUAL

1. Systems - Main 5 team (Steam) Decay Heat Release Feedwater Chemical Feed Blowdown
2. Components - Steam Generator and piping located on drawings 11715-FM-70B, 11715-FM-74A, 11715-FM-890. 11715-FM-98A, and 11715-FM-102A.

Component Connected Piping Component 1-RC-E-1A 32"-SHP-1-601 SV-MS-101A L to 32"-SHP-22-601 SV-MS-102A SV-MS-103A  ;

SV-MS-104A SV-MS-105A to 6"-SHP-37-601/1"-SHP-84-601 PCV-MS-101A 1 to 3"-SHP-64-601 1-MS-327 1 1-MS-18 i to 1 1/2"-SHPD-6-601 1-MS-22  ;

to 1/2"-SHPD-71-601- 1-MS-26.

'l I

1

I 1 . .

Component Connected Piping Component l 1-RC-E-1A 32"-SHP-1-601 1-MS-35 NRV-MS-101A 3"-SHP-60-601 1-MS-344 1-RC-E-1A 32"-SHP-1-601 to 3"-SHP-45-601 1-MS-344 j to 3"-SHP-531-601 NRV-MS-103A to 1"-SHP-518-601 1-MS-346 1-MS-348 1-RC-E-1A 2"-55-302-601 1-55-576 l 1

1-RC-E-1A 32"-SHP-1-601 l to 32"-SHP-22-601 1

~

to 3"-SDHV-1-601 j to 4"-SDHV-4-601 HCV-MS-104 '

1-RC-E-1A 16"-WFPD-24-601 1-FW-68 l 1-FW-47 to 3/4"-CFPD-1-1CN9 1-WT-39 1-RC-E-1A 2"-WGCB-4-601 1-BD-1 2"-WGCB-5-601 1-BD-4 1"-WGCB-6-601 1-BD-2 j J

1-9C-E-1B 32"-SHP-2-601 SV-MS-101B to 32"-SHP-23-601 SV-MS-102B SV-MS-103B SV-MS-104B SV-MS-105B to 6"-SHP-38-601/1"-SHP-85-601 PCV-MS-101B to 3"-SHP-65-601 1-MS-325 1-MS-57 to 1 1/2"-SHPD-8-601 1-MS-60 to 1/2"-SHPD-73-601 1-MS-64 l

l 1- R C- E- 1B 32"-SHP-2-601 1-MS-74 NRV-MS-101B 3"-SHP-61-601 1-MS-353 1-RC-E-1B 32"-SHP-2-601 to 3"-SHP-61-601 to 3"-SHP-46-601 1-MS-353 to 3"-SHP-533-601 NRV-MS-103B to 1"-SHP-520-601 1-MS-356 1-MS-357 1-RC-E-1B 2"-55-225-601 1-55-218 l

i 40>$+#

l MAGE EVALUATION ////p

<[fI$lg, x

////f0\ Y *(-tigf// TEST TARGET (MT-3) d*@

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1 1.0 l;mm

} lll l\llM l,l llllM

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l.8 1.25 1.6 j' l.4 1

4 150mm >

l< 6" >

$ ? + ///

  • >ev,v gr/

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__________a____--_-___ _

99?9 o q.

%+P. #;f; IMAGE EVALUATION fe(y O %, v j ////g, , '

/// \'{ %f/ TEST TARGET (MT-3) s[b /g f > #4,ppp /

ppp l.0 E 2 LB y [@ El I,l [ ' L& B

- 1.8 l

1.25 1.4 I.6 4 150mm >

4 6" >

k,,,~ .

m h_m _ _ _ . _ _ _ _ . . _ _ _ . _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _

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.#._.m_ . _ _ _ - . _ . _ _ _ _ _ _ . - _ _ . _ _ _ _ _

$$' $f' IO IMAGE EVALUATION d

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/o j/ *% + Y# # TEST TARGET (MT-3) / dg/g, 1.0 gm m

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ll z.6 =

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.. j Component Connected Piping Component 1-RC-E-1B 32"-SHP-2-601 3

to 32"-SHP-23-601 to 3"-SDHV-2-601 to 4"-SDHV-4-601 HCV-MS-104 1-RC-E-1B 16"-WFPD-23-601 1-FW-79 i

1-FW-100 to 3/4"-CFPD-2-1CN9 1-WT-51

[

1 1-RC-E-1B 2"-WGCB-7-601 1-BD-10 2"-WGCB-8-601 1-BD-13 1"-WGCB-9-601. 1-BD-11 l

i 1-RC-E-IC 32"-SHP-3-601 to 32"-SHP-24-601 SV-MS-101C SV-MS-102C SV-MS-103C SV-MS-104C SV-MS-105C l to 6"-SHP-39-601/1"-SHP-86-601 PVC-MS-101C i to 3"-SHP-66-601 1-MS-95 1-MS-323 to 1 1/2"-SHPD-7-601 1-MS-98 to 1/2"-SHPD-75-601 1-MS-412 1-RC-E-1C 32"-SHP-3-601 1-MS-112 NRV-MS-101C 3"-SHP-62-601 1-MS-362 1-RC-E-1C 32"-SHP-3-601 to 3"-SHP-62-601

' to 3"-SHP-47-601 1-MS-362 to 3"-SHP-532-601 NRV-MS-103C to 1"-SHP-519-601 1-hS-365 1-MS-336  ;

1-RC-E-IC 2"-55-227-601 1-5S-217 1-RC-E-1C 32"-SHP-3-601 to 32"-SHP-24-601 ,

to 3"-SDHV-3-601 l to 4"-SDHV-4-601 HCV-MS-104 l

1-RC-E-1C 16"-WFPL-22-601 1-FW-111  !

1-FW-132 l to 3/4" -CPFD-3-1CN9 1-WT-67 I 1-RC-E-1C 2"-WGCB-10-601 1-BD-19 l l 2"-WGCB-11-601 1-BD-22 )

1"-WGCB-12-601 1-BD-20 l

- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _-__________-__A

3. Code Requirement - Class 2 System Hydrostatic Test per IWC-5222 and IWA-5213(d). For Feedwater components P = 1100 psig, T pressure per IWC-5222 would be 1375 psigY For the ChemYe>200al Feed F, test Components P =1775 psig, Td <200'F, test pressure per IWC-5222 wouldbe195!.5psig. The remaining components'have P d = 1085 psig, Td >200*F, test pressure per IWC-5222 would be 1356 psig.
4. Licensee's Proposed Alternative Examination VEPCO proposed the following alternative:

The Westinghouse Technical Manual for the Steam Generator requires the secondary side to be pressurized to 1356 psig, held for 30 minutes and then reduced to the design pressure (1085 psig) for a sufficient time to permit proper examination of welds, closures and surfaces for leakage or weeping.

The secondary side will be held at 13b5 psig for 30 minutes and then at 1085 psig for a minimum of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> in accordance with the Code. A VT-2 examination will then be performed.

5. Licensee's Reason for Relief VEPCO's basis for the relief request is as fo11cws:

Westinghouse, the manufacturer of the steam generators, gives specific testing requirements for the steam generator which must also be applied to the components listed above because components cannot be isolated from the steam generators.

6. Staff Evaluation and Conclusion It is impractical to hydrostatically test the valves and piping bounded by the valves listed to Code requirements without subjecting the steam generators to conditions adverse to those specified in the Westinghouse Technical Manual. Therefore, the hydrostatic test pressure for these sections of piping is limited by the test pressure to which the steam generators are recommended being subjected. The Code required test pressure for these sections of feedwater piping is 1540 psig and the pressure limited by the steam generators is 1356 psig. The testing procedure recommended by Westinghouse is to subject the steam generators (and thus the piping) to 1356 psig for 30 minutes and then reduce the pressure ,

to 1085 psig. The test pressure proposed by the licensee is sufficiently higher than normal operating to adequately test the piping pressure boundary for its continued structural integrity.

i l

l Since the section of. piping will be held at the Code required test pressure for the steam generators for 30 minutes and then lowered to the design pressure and held for 3 1/2 hours prior to the VT-2 examination, any leakage will most likely appear at the surfaces of insulation and be detected during the examination. The staff finds the licensee's proposed alternative test as recommended by Westinghouse to be acceptable. We therefore conclude that relief ,

from the higher pressure may be granted as requested.

L. RELIEF REQUEST 12 - REQUEST TO TEST AT LOWER PRESSURE

1. Systems - Component Cooling, Chemical and Volume Control, Fuel Pit Cooling Safety Injection, Quench Spray, Recirc. Spray, Service 1 Water and Sampling. ,

l Components - Piping and components included in the system hydrostatic 2.

~

test boundary.

3. Code Requirement - Per IWA-5265(b). .."the impose.1 pressure on any component, including static head, will not exceed 106% of the specified test pressure for the system." '
4. Licensee's Proposed Alternative Examination VEPC0 proposed the following alternative:

Hydrostatic testing of systems that cannot be isolated to meet the system test pressure at the test boundary high point and the 106% system test pressure maximum at f the test boundary low point shall be conducted by pressurizing to the system test pressure at the 70w point in the test boundary.

5. Licensee's Reason For Relief VEPCO's basis for the relief request is as follows: I Unisolable portions of the above systems within the system hydrostatic test boundary are located throughout the plant such that there are variations in elevation i within the boundaries that would result in imposed 1 pressures in excess of six percent of the specified test pressure. It is Virginia Electric and Power Company's desire to limit the test pressure imposed on system components to 106% of the specified test pressure (as required by paragraph IWA-5265(b)). Thus, due to the

, effects of static head, portions of the piping at higher 1

i

L. .

elevations will be subjected to a test pressure lower than  ;

that specified. There is no practical method for isolating j the piping segments to achieve the required test pressure  !

at all elevations. In a safety Evaluation Report on Duane Arnold Energy Center (Docket No. 50-331) dated 03/31/86, relief was granted from IWA-5265(b) for situations as  !

described above.

6. Staff Evaluation and Conclusion The Code requirement is impractical to achieve in situations cited by the licensee without system modifications. The relatively small pressure differentials existing between the systems high and low points during the hydrostatic test do not warrant such modifications nor will they significantly change the results if the requirements were imposed. The licensee's proposed alternative test pressures will provide the assurance necessary to assess the systems continued l structural integrity. The staff therefore concludes that relief f from the Code requirement may be granted as requested.

I III. CONCLUSION The staff has reviewed the relief requests discussed abnve and has determined, pursuant to 10 CFR 50.55a(a)(3), that the alternatives proposed would provide an acceptable level of quality and safety, that compliance with the code re-quirements would result in hardship or unusual difficulties without a compen-sating increase in the level of quality and safety. The staff has also deter-mined that the requirements of the code are impractical and pursuant to 10 CFR 50.55a(g)(6)(i), the requested relief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

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