B12647, Forwards Relief Request 3.0 Requesting Relief from Performing Sys Hydrostatic Test of Svc Water Sys at Pressure in Conformance W/Requirements of IWA-5265(b).Fee Paid

Forwards Relief Request 3.0 Requesting Relief from Performing Sys Hydrostatic Test of Svc Water Sys at Pressure in Conformance W/Requirements of IWA-5265(b).Fee Paid

ML20238A632
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	08/25/1987
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
B12647, NUDOCS 8708310151
Download: ML20238A632 (4)

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l g CONNECTICUT YANKEE ATOMIC POWER COMPANY ]

B E R L I N, CONNECTICUT P.O. box 270

• HARTFORD, CONNECTICUT 06141-0270 I

l TELEPHONE

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l Docket No. 50-213 B12647 Re: 10CFR50.55a(g) I U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

l Haddam Neck Plant Inservice Inspection Relief Request for the Performance of Hydrostatic Testing of the Service Water System Attached is " Relief Request 3.0" requesting relief from performing a system hydrostatic test of the Service Water System at a test pressure in conformance with the requirements of IWA-5265(b). This relief request is being submitted pursuant to 10CFR50.55a(g)5(iii).

Connec ticut Yankee Atomic Power Company (CYAPCO) believes that the proposed alternative test is adequate in demonstrating system integrity and, based on the physical configuration of the involved systems, is the most practical ,

means of performing the test without incurring significant expenses needed to l install additionalisolation valves, j

In order to support outage activities, CYAPCO requests approval of the above i relief request on an expedited basis. Also, should you need additional j information to support this relief request, please contact our licensing  !

representative directly.

I Pursuant to the requirements of 10CFR170.12(c), enclosed with this relief request is an application fee of $150.00.

Very truly yours, i

CONNECTICUT YANKEE ATOMIC POWER COMPANY t W/

E. J.<Mroczka //

Senior Vice President

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l cc: W. T. Russell, Region I Administrator F. M. Akstulewicz, NRC Project Manager, Haddam Neck Plant q I l

3. T. Shediosky, Resident Inspector, Haddam Neck Plant

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Docket No. 50-213 B12647 Attachment Relief Request 3.0 I

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i August,1987 1

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Attachment B12647/Page1

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Relief Request 3.0 i I

l Code Class. 3 Examination Category: D-B Item Number: B2.10 .!

System  ;

Service Water System Components Piping and components included in the system hydrostatic test boundary.

Code Requirement l-Per Section XI'of the ASME B&PV code,1980 Edition with Addenda through I Winter 1980, subarticle IWA-5265(b) "...the imposed pressure on any component, including static head, will not exceed 106% of the specified test pressure for the system." l Code Relief Request  !

Pursuant to 10CFR50.55a(g)5(iii), relief is requested from performing the system hydrostatic test at the required test pressures for all elevations within the system.

I Reason for Relief Unisolable portions of the above system within the system hydrostatic test boundary exist such that there are variations in elevation within the boundaries that would result in imposed pressures in excess of 6% of the specified test pressure. From the lowest portion of the system (floor level where the RHR heat exchangers are located, elevation - 19') to the highest portion of the system (the Primary Auxiliary Building (PAB) Service Water Header, elevation 50' 6") -;

represents an elevation difference of 69' 6' and corresponds to a static head of j approximately 30 psi. This differential is greater than the allowed range of test pressures for the Service Water System. The minimum a!! owed test pressure for the Haddam Neck Plant Service Water System is 121 psig while the maximum allowed test pressure is 106% of this or 128 psig. This allows only a 7 psi range and, therefore, unless the system can be isolated to limit the effects of a static head to less than 7 psi (which it cannot be) the Code requirements cannot be met. Therefore, it is Connecticut Yankee Atomic 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 I static head, portions of the piping at higher elevations will be subjected to a test pressure lower than that specified. There is no practical method for isolating 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) '

7 dated March 31, 1986, relief was granted from IWA-5265(b) for situations as described above.

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, i Attachment B12647/Page 2 Proposed Alternative Examination i

Hydrostatic testing of the Service Water System that cannot be isolated to meet the system test pressure at the test boundary high point and the 106% system test pressure maximum at the test boundary low point shall be conducted by

- pressurizing to 106% of the system test pressure at the low point in the test boundary. Instrumentation will be set up at the RHR heat exchangers to indicate when 128 psig is attained. Pressure indication at the upper level of the PAB will .

also be noted and is expected to be at approximately 98 psig. l Note: Normal operating system pressure is approximately 65 psig.

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