ML18093B319

Forwards Attachment Inadvertently Omitted from Util 880606 Request for Relief from Requirements Re 10-yr Hydrostatic Testing of Buried Piping in Unit Auxiliary Feedwater Sys

ML18093B319
Person / Time
Site:	Salem
Issue date:	11/28/1988
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLR-N88190, NUDOCS 8812010338
Download: ML18093B319 (4)

Text

Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer November 28, 1988 NLR-N88190 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESUBMITTAL OF INSERVICE INSPECTION PROGRAM RELIEF REQUEST SALEM GENERATING STATION UNIT NO. 1 DOCKET NO. 50-272 On June 6, 1988, Public Service Electric and Gas Company (PSE&G) submitted a request for relief from the requirements of ASME Section XI regarding the 10-year hydrostatic testing of buried piping in the Salem Unit 1 Auxiliary Feedwater System. In an effort to begin NRC staff review of this relief request, Mr. J. Stone, the NRR Project Manager for Salem Generating Station, informed us that a page from the Attachment to the June 6, 1988 letter was not received by the NRC Docket Room. We apologize for any inconvenience this may have caused. Another copy of the attachment is enclosed with this letter.

A check in the amount of $150.00 was submitted with the June 6, 1988 letter in accordance with the requirements of 10CFR170.21.

If you have any questions with regard to this relief request, please do not hesitate to contact us.

Sincerely, Attachment Ao41 8812010338 881128 r~ '\1 PDR ADOCK 05000272 Q PDC

Document Control Desk 2 11-28-88 c Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson, Acting Senior Resident Inspector Mr. W. T. Russell, Administrator Region I Ms. J. Moon, Interim Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

I I

ATTACHMENT ASME SECTION XI RELIEF REQUEST FROM 10 YEAR HYDROSTATIC TEST REQUIREMENTS FOR BURIED PIPING IN THE AUXILIARY FEEDWATER SYSTEM ASME SECTION XI EXAMINATION REQUIREMENT - 1974 Edition through Summer 1975 Addenda.

Article IWD - 2600(b) - In the case of buried components (e.g.,

underground piping), valves shall be provided to permit isolation of the buried portions of piping for the purpose of conducting a system pressure test in lieu of the visual examination. A loss of system pressure during the test shall constitute evidence of component leakage.

ALTERNATE EXAMINATION PROPOSAL - PSE&G conducted a pressure test of buried piping between valves 12AF23, 12AF21 and 12AF86 for Steam Generator #12 and 14AF23, 14AF21 and 14AF86 for Steam Generators #14 (see attached sketch) using the following alternate test method. The header was pressurized to the required hydrostatic test pressure and header pressure was maintained with the hydrostatic test pump. While the pressure was maintained, and for the duration of the test, both the volume of water used by the pump and that collected downstream of the leaking test boundary valves 12AF23 and 14AF23 were measured.

The two measured volumes were then compared to provide assurance that the inaccessible portion of the pipe had no identified leakage. The buried pipe in each case was approximately 190 feet in length.

REASON FOR RELIEF REQUEST

1. The buried piping was initially tested by a pressure drop test using boundary valves as prescribed in the Code. The pressure drop test failed because of excessive leakage through the test boundary. The leakage was suspected to be past the 12AF23 and 14AF23 valves. In order to substantiate this suspected leakage path, the alternate test method described above was used. Relief is being requested as the Code does not provide for an alternate method of testing inaccessible pipe.

2. This matter was considered unresolved (Unresolved Item 272/87-32-01) in the routine Resident Safety Inspection performed between November 3, 1987 to November 30, 1987 (NRC Combined Inspection Report 50-272/87-32 and 50-311/87-33).

The inspector found the alternate test method to be a reasonable alternative to the pressure drop test since the boundary valves could not be made leak tight. The inspector also requested that a relief request be submitted to acquire a formal approval for the use of the alternate test method.

12(14}AF21

~N SALEM UNIT 1 I CONTAINMENT I

I LEAKAGE UNIT 1 FHB I COLLECTION I POINT I 12(14)BF57 I 12(14)BF58 I

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' ' .... ..... NOTES ~

1. EACH BURIED PIPE RUN IS APPROXIMATELY 190 Ff.

BURIED OUTER MECHANICAL PENE'JRATJON

2. PIPE CONFIGURATION IS THE SAME FOR PIPES BOTH 12 AND 14 12(14}AF23 AF LINES