05000255/FIN-2014008-11
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Finding | |
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| Title | Classification of CCW Piping and Components Inside the Reactor Containment Building |
| Description | The inspectors identified an unresolved issue (URI) regarding the Inservice Inspection (ISI) classification of component cooling water (CCW) piping and components inside the reactor containment building. This piping is currently classified as non-safety related. Resolution of this issue will be based on clarification of Palisades licensing basis by NRC staff. The inspectors reviewed SEP-ISI-PLP-002, ASME Code Boundaries for ASME Section XI Inservice Inspection Program, Revision 1. The purpose of this document was to establish classifications to ensure the proper scope of ASME Section XI system pressure tests, ASME Section V nondestructive examinations, ASME Section XI inspection of component supports, and ASME Section XI repairs, replacements and modifications. This program document stated that guidance for Class 2, 3, and nonsafety- related components is found in Regulatory Guide 1.26. The program referred to a set of color-coded P&IDs. The inspectors noted the CCW piping and components inside the reactor containment building were identified as non-safety-related on the color-coded P&IDs. The team also observed that Attachment 1 of SEP-ISI-PLP-002 (page 45 of 75) identified the piping from the containment penetrations to the single containment isolation valve outside containment as class 2 (check valve CK-CC910 for penetration MZ-14, air-operated valve CV-0911 for penetration MZ-15). This attachment referred to note H, which stated, in part: All containment penetration assemblies in Class 2, Class 3, and non-class piping will be considered ASME Class 2 out to the second isolation valve where applicable. In some cases, there is single isolation (e.g., MSS, FWS)... Where a Class 3 system penetrates containment, that portion will be considered Class 2 and treated as such (ie, ASME Section XI Interpretation BC84-603). The basis for classification of containment penetrations is contained in EGAD-EP-12, Mechanical Containment Penetrations Basis Program. The current Mechanical Containment Penetrations Basis document was SEP-APJ-PLP- 101, Revision 0. This document included a similar description for CCW penetrations MZ-14 and MZ-15. It stated that FSAR Table 5.8-4 classifies these penetrations as class C1. The FSAR table also identified these penetrations as Class C1 and indicated that they are not subject to 10 CFR Part 50, Appendix J testing requirements. The FSAR Section 6.7 included a description of Class C1 penetrations, it stated, in part: Penetrations in this class include those systems that are not connected to either the containment atmosphere or to the Primary Coolant System and are normally open or may be opened during power operation. These lines are protected from missiles originating inside the containment and the lines themselves form the boundary of the containment. One remote manually operated valve, locked closed manual valve or automatic isolation valve is provided in each line. Check valves are considered automatic. In SEP-APJ-PLP-101 also stated, that both Penetrations MZ-14 and MZ-15 were originally classified as C2 (closed system outside containment per FSAR Section 6.7), until FSAR Revision 22. These were reclassified by SDR-99-0884, dated July 22, 1999. The basis for these changes included an evaluation that determined CCW piping inside containment would not be damaged by internal missiles (as addressed by NRCs evaluation of SEP Topic III-4,c, dated September 21, 1981), and the classification of CCW as a closed system inside containment. The associated 10 CFR 50.59 evaluation determined that NRC approval was not required for these changes. The inspection team raised questions regarding the licensing basis classification of the CCW system inside containment: 1. FSAR Section 6.9 stated that Regulatory Guide 1.26 was used to select ASME Classes 2 and 3 systems and components for coverage by the inspection plan. Regulatory Guide 1.26, stated in part: The Quality Group C standards given in Table 1 of this guide should be applied to water-, steam-, and radioactive-waste-containing pressure vessels; heat exchangers (other than turbines and condensers); storage tanks; piping; pumps; and valves that are not part of the reactor coolant pressure boundary or included in Quality Group B but part of the following: ...(b) cooling water and seal water systems or portions of those systems important to safety that are designed for the functioning of components and systems important to safety, such as reactor coolant pumps, diesels, and the control room... The classification of the CCW system inside containment did not appear to be consistent with the guidance of Regulatory Guide 1.26. In addition, industry guidance provided by ANSI/ANS 51.1 1983 indicated that closed systems inside containment (with single active isolation valves) should be class 2 or class 3. 2. FSAR Section 6.7 addressed class C1 containment penetrations stating, These lines are protected from missiles originating inside the containment and the lines themselves form the boundary of the containment. The inspectors questioned whether it was appropriate to classify a portion of the containment boundary as nonsafety- related for the purpose of inspection, testing, and repairs. The licensee has stated that the CCW system classification is in accordance with their current licensing basis. This position is primarily based on the NRCs evaluation of SEP Topic III-4,c, dated September 21, 1981, the CCW system being protected from internal missiles, and seismic events not being postulated to occur coincidently with a LOCA. Resolution of this issue will be based on clarification of Palisades licensing basis. Pending resolution, this item will be tracked as an URI. |
| Site: | Palisades  |
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| Report | IR 05000255/2014008 Section 1R21 |
| Date counted | Dec 31, 2014 (2014Q4) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | A Stone C Baron C Brown C Zoia H Leake J Corujo-Sandin L Rodriguez S Sheldona Armstronga Nguyen C Hunt G Hansen G O'Dwyer J Boettcher J Cassidy J Coroju-Sandin J Jandovitz J Lennartz J Rutkowski L Rodriguez M Domke M Holmberg M Keefe T Taylor V Myers |
| INPO aspect | |
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Finding - Palisades - IR 05000255/2014008 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2014Q4
Self-Identified List (Palisades)
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