ML030990350
| ML030990350 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 04/01/2003 |
| From: | Wanczyk R Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY 03-28 | |
| Download: ML030990350 (180) | |
Text
APPENDIX D Calibration Block Index Appendix D PP 7015 Rev. 3 Page 1 of 6
Appendix D (Continued)
Calibration Block Index IdSetifidartd Schedule Diameter/Size Thickness Material RPB-4 N/A 2.50" x 14.00" N/A A193 GRB7 RV-1 N/A 16.00" x 6.00" 5.62" A533-65 GRB RV-2 N/A 9.00" x 6.00" 3.00" A533-65 GRB RV-3 N/A 35.00 x 6.00" 5.625" A533-65 GRB RV-4 N/A 15.50" OD x 5.1325" A508 CL II 34.625" VY-1 80 2.50" 0.276 A312-304 VY-10 120 14.00" 1.093" A106 GR C VY-11 80 18.00" 0.937" A106 GR C VY-12 N/A 6" x 4" x 1.44" 1.44" A312 Type 304 VY-13 N/A 6" x 4" x 1.44" 1.44" A515- 72 VY-14 N/A 10.00" 0.500" B168 Inconel VY-16 30 16.00" 0.375" A106 GR B VY-17 80 4.00" 0.337" A451 Type CPF8M VY-18 80 4.00" 0.337" A451 Type CPF8M VY-19 80 8.00" 0.500" A106 GR B VY-2 160 2.50" 0.375 A106 GR C VY-20 100 8.00" 0.594" A312 Type 316L VY-21 80 2.50" 0.276" A376 Type 304 Appendix D PP 7015 Rev. 3 Page 2 of 6
Appendix D (Continued)
Calibration Block Index Standard Identification Schedule Diameter/Size Thickness Material VY-22 80 4.00" 0.337" A376 Type 304 VY-23 120 10.00", 0.844" A106 GR B VY-24 80 16.00" 0.844" A106 GR B VY-25 120 16.00" 1.219" A106 GR B VY-26 80 18.00" 0.938" A106 GR B VY-27 80 20.00" 1.031" A106 GR B VY-28 80 24.00" 1.219" A106 GR B VY-29 80 10.00" 0.594" A106 GR B VY-3 80 3.00" 0.300" A312-304 VY-30 N/A 15.406" OD 0.875" A336 CI F8 VY-31 N/A 12.84" 0.667" A336 CI F8 VY-32 N/A 20.00" 1.095" A358 Type 304 VY-33 80 22.00" 1.125 " A358 Type 304 VY-34 N/A 24.00" 1.312" A358 Type 304 VY-35 N/A 25.87" ID 1.138" A358 Type 304 VY-36 N/A 28.00" 2.00" A358 Type 304 VY-37 120 4.00" 0.437" A376 Type 304 VY-38 160 6.00" 0.718" A106 GR B Appendix D PP 7015 Rev. 3 Page 3 of 6
Appendix D (Continued)
Calibration Block Index Standard Identification Schedule Diameter/Size Thickness Material VY-39 80 8.00" 0.500" A376 Type 304 VY-4 160 3.00" 0.438" A106 GR C VY-40 80 8.00" 0.719" A106 GR B VY-5 80 4.00" 0.337" A312-304 VY-50 80 6.00" 0.432" A106 GR B VY-51 STD/40 8.00" 0.332" A106 GR B VY-52 STD/40 10.00" 0.365" A106 GR B VY-53 100 10.00" 0.719" A106 GR B VY-54 STD 12.00" 0.375" A106 GR B VY-55 40 12.00" 0.406" A106 GR B VY-56 80 12.00" 0.688" A106 GR B VY-57 STD 14.00" 0.375" A106 GR B VY-58 80 14.00" 0.750" A106 GR B VY-59 160 14.00" 1.406" A106 GR C VY-6 80 4.00" 0.337" A106 GR B VY-60 STD 18.00" 0.375" A106 GR B VY-61 STD 20.00" 0.375" A106 GR B VY-62 30 20.00" 0.500" A106 GR B Appendix D PP 7015 Rev. 3 Page 4 of 6
Appendix D (Continued)
Calibration Block Index Standard Identification Schedule Diameter/Size Thickness Material VY-63 STD 24.00" 0.375" A106 GR B VY-64 30 24.00" 0.562" A106 GR B VY-65 STD 26.00" 0.375" A106 GR B VY-66 N/A 6.25" x 6.25" 0.690" A515 GR 70 VY-68 N/A 28.00" 1.235" A376 Type 316 VY-69 N/A 28.00" 1.140" A376 Type 316 VY-70 N/A 24.00" 1.140" A376 Type 316 VY-71 N/A 22.00" 0.990" A376 Type 316 VY-72 N/A 20.00" 0.985" A376 Type 316 VY-73 N/A 12.00" 0.690" A376 Type 316 VY-75 120 4.00" 0.438" A106 GR B VY-78 N/A 8.00" 0.975" A 167-82 A480-83 Clad VY-79 N/A 8.00" 1.50" A240-884A A262-81 VY-8 160 10.00" 1.125" A106 GR B VY-81A/B N/A 3.00" x 9.00" 1.125" A240-82C VY-85 40 6.00" .280" A106 GRB VY-86 40 16.00" .500" A106 GRB Appendix D PP 7015 Rev. 3 Page 5 of 6
Appendix D (Continued)
Calibration Block Index Standard Schedule Diameter/Size Thickness Material Identification ..
VY-87 30 18.00" .438" A106 GRB VY-88 20 20.00" .375" A106 GRB VY-89 80 4.00" .337" A312 GRB VY-9 80 12.00" 0.687" A312-304 VY-90 120 14.00" 1.094" A106 GRB VY-N3-lR N/A 10.75" x 6.125" 2.3125" A508 CL II VY-N4-LR N/A 10.75" x 6.125" 2.3125" A508 CL II Appendix D PP7015 Rev. 3 Page 6 of 6
Docket No. 50-271 BVY 03-28 Attachment 3 Vermont Yankee Nuclear Power Station Fourth-Interval Inservice Inspection Program Plan, Fourth-Interval Inservice Inspection Pressure Test Program and Request for Approval of ISI Relief Requests ISI Pressure Test Program
VERMONT YANKEE NUCLEAR POWER STATION PROGRAM PROCEDUREy
- PP 7034 Revision 1 INSERVICE INSPECTION PRESSURE TEST PROGRAM USE CLASSIFICATION: INFORMATION LPC Effective Affected Pages No. Date 4 4 I Implementation Statement: N/A I Issue Date:_
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TABLE OF CONTENTS 1.0 PURPOSE, SCOPE AND DISCUSSION ................................ 3 2.0 DEFINITIONS ... 4...................
3.0 PRIMARY RESPONSIBILITIES ................................ 6 4.0 PROCEDURE ... 7...................
5.0 REFERENCES
AND COMMITMENTS ............................... 10 6.0 FINAL CONDITIONS ............................... 11 7.0 ATTACHMENTS ............................... 12 PP 7034 Rev I Page 2 of II
1.0 PURPOSE, SCOPE, AND DISCUSSION 1.1 Purpose The Fourth Ten-Year Interval Inservice Inspection Pressure Testing Program (Program) implements the requirements of Title 10 Code of Federal Regulations, Part 50, Section 50.55a, Codes and Standards (IOCFR50.55a) dated September 26, 2002, pertaining to pressure testing and VT-2 visual examination of systems or portion of systems for the three periods of the Interval.
1.2 Scope The scope of this procedure is to identify the systems, based on the ASME group classification criteria, for pressure testing, to provide a scheduling guideline for the performance of periodic pressure testing, and to direct the required pressure testing in support of the AP 0070, ASME Section XI Repair and Replacement Procedure.
1.3 Discussion The Code of Record (Code) for the Program is the American Society for Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components" (ASME Section XI - 1998 Edition through the 2000 Addenda).
The Program incorporates the alternative requirements for pressure testing and VT-2 visual examination as outlined in Regulatory Guide 1.147, as needed. Presently, the following Code Cases are being implemented:
None The Program additionally incorporates the alternative requirements for pressure testing, VT-2 visual examination, or corrective measures as outlined in relief requests. Presently, the following relief requests are being implemented:
PT-1: For use of a system leakage test in lieu of the Class 3 "Interval" hydrostatic test The Program was developed by updating the Third Ten-Year Interval Inservice Inspection Pressure Testing Program to the requirements of 10CFR50.55a and the Code. The Program scope was adjusted as required. A continuity of periodicity and frequency was maintained.
The Program determined system ASME Classifications are based on Regulatory Guide 1.26 and ANS-22, Draft 4, Rev I guidelines that are applicable to water-, steam-, and radioactive-waste-containing components important to the safety of water-cooled nuclear power plants. Systems such as instrument and service air, diesel engine and its auxiliary support systems, etc., that are not within the guideline's scope are not required to be classified and included in the Program.
System or portions of systems included in the Program conform to Quality Group A, B, or C criteria and corresponding ASME construction codes. The Program's ASME Class pressure boundaries, using the above guidelines and additional guidelines provided by IOCFR50.2, may PP 7034 Rev I Page 3 of II
not correspond to the system Safety Classifications (i.e., SCx) per AP 6006 (e.g., nonisolatable SC 2 portions of the Reactor Coolant Pressure Boundary are classified as ASME Class I by the Program for pressure testing and VT-2 visual examination purposes, etc.).
The Pressure Test Table (Table I) contains the Program determined system AMSE Class, Status (Operating or Non-operating during normal operating conditions), and Category. It also includes systems or portions of systems that are considered optionally upgraded as annotated in the Comments/Remarks. Optionally upgraded systems are provided with a Class and Status.
The Program schedules and frequencies are based on IWA-2432 of the Code, "Inspection Program B," consisting of four ten-year intervals with three periods per interval. The relative interval and period starting and ending dates are outlined in the following matrix:
Period I I Period 2 l Period 3 Interval 1 On-line Dec. 1, 1972 l to April 30. 1983 2 May 1, 1983 Scpt. I, 1986 Sept 1, 1990 Interval 2 to To to Aug. 31, 1986 3 Aug 31. 1990 Aug. 31, 1993 Sept. 1, 1993 Sept. I, 1996 Sept 1, 2000 Interval 3 to to to Aug. 31, 1996 Aug 31,2000 Aug. 31, 2003 Sept. 1,2003 Sept. 1, 2006 Sept 1, 2010 Inevl4to to to 4 Interval4 Aug.31,2006 Aug 31,2010 Aug.31,2013 4
[RIRO 24 & 25] [RFO 26, 27, & 28] [RFO 29 & 30]
The First Interval was five years long, due to the delay inthe development and implementation of ASME Section Xl 2 The end date of the First Interval was extended by five months, in accordance with IWA-2430(c), to permit inspections concurrent with a plant refueling outage. Consequently, all subsequent intervals were adjusted forward five months In the Second Interval, the end date of Period I was extended by four months to reflect the 1985-86 pipe replacement/refucling outage (9months duration) in accordance with IWA-2430(c). Consequently, all subsequent intervals were adjusted forward four months Vermont Yankee's onerating license exnires March 21.2012 Table 1 contains the Fourth Interval (i.e., I", 2 nd, & 3 rd Periods) forecasts of the expected refueling cycle frequencies for the Pressure Tests. The AP 4000, Surveillance Program database provides the scheduling for pressure testing and VT-2 visual examination.
Pressure testing and the VT-2 visual examination to support AP 0070, "ASME Section XI Repair and Replacement Procedure" is an unscheduled activity, being conducted on an as needed basis.
The information contained in Table I is also used to determine the requisite applicability for pressure testing, as modified by IWA-4540(b) of the Code. Requisite Hold(ing) time, prior to examination, is also determined from the Table I and conditions specified by the Program.
2.0 DEFINITIONS 2.1 Asset - A component as described in EMPAC 2.2 Automatic closure - An action of a valve to close in response to a protection or system isolation signal (e.g., MOV, AOV, etc) or to a system condition (i.e., check valve) when the safety function is required.
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2.3 Component - An item in a nuclear power plant such as a vessel, pump, valve, piping system, or component support.
2.4 Examination - An IWA-2212 of the Code VT-2 visual examination conducted in accordance with NE 8046, "Visual Examination Procedure for VT-2" by examiners qualified in accordance with NE 8043, "Training, Qualification and Certification of NDE Personnel" or other Vermont Yankee approved procedures.
2.5 Hold(ing) Time - The minimum period after attaining test conditions (e.g., system or elevated pressure), prior to the commencement of the VT-2 visual examination.
2.6 Normal Operating Conditions - The operating conditions during reactor startup, operation at power, hot standby, and reactor cooldown to cold shutdown. Test conditions are excluded.
2.7 Normal Plant Operation - The conditions of startup, hot standby, operation within the normal power range, and cooldown and shutdown of the plant.
2.8 Optionally Upgraded - Describes systems or portions of systems (components) that are classified as ASME Class 2 or 3 at the owner's discretion. ENVY regards these systems or portions of systems as ASME Class, as appropriate for their importance to safety, but reserves the right to restrict the application of the Code requirements per IWA-1320. These systems or portions of systems are tested and visually examined to the principles of the Code; however, the optionally upgraded systems are not subject to the Code.
2.9 Period - A fixed portion (nominally 36-48 months) of the ten-year time span (interval) used for the scheduling of required testing and examination.
2.10 Pressure Test - A generic term ascribed to a series of test types, which, under the test conditions, a VT-2 visual examination is performed in accordance the Code to detect leakage.
2.11 Program - A "Program" is a set of activities that benefit from the existence of a formal, high level "Program Document." Such documents are meant to provide for a common understanding of Program depth, breadth, and technical bases as well as the responsibilities of the Program owner and those helping to implement the Program. "Program Documents" are typically created to ensure regulatory requirements are satisfied. They can also be used to layout the technical bases and personnel responsibilities related to complex, multi-departmental processes.
2.12 Program Owner - The individual responsible for maintaining the Program, Program documents, and assuring proper execution of the Program requirements. Each Program shall have an individual assigned as the Program owner. The appropriate job title is determined by the responsible Department Manager. A summary of expectations for the Program owner are contained in Appendix A of AP 0098 and shall be referenced in all Program Procedures.
2.13 Reactor Coolant Pressure Boundary - Per I OCFR50.2, all those pressure-containing components of boiling and pressurized water-cooled nuclear power reactors, such as pressure vessels, piping, pumps, and valves, which are:
(1) Part of the reactor coolant system, or (2) Connected to the reactor coolant system, up to and including any and all of the following:
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(i) The outermost containment isolation valve in system piping which penetrates primary reactor containment, (ii) The second of two valves normally closed during normal reactor operation in system piping which does not penetrate primary reactor containment, (iii) The reactor coolant system safety and relief valves.
For nuclear power reactors of the direct cycle boiling water type, the reactor coolant system extends to and includes the outermost containment isolation valve in the main steam and feedwater piping.
3.0 PRIMARY RESPONSIBILITIES 3.1 Manager, System Engineering, is responsible to ensure:
3.1.1 Implementation of AP 0098, Appendix A, for the Program.
3.1.2 The Program is defined and maintained per the requirements of IOCFR50.55(a), in accordance with ASME Section XI - 1998 Edition through the 2000 Addenda, in compliance with Regulatory Guide 1.147 and approved relief requests.
3.1.3 The assignment of the Pressure Testing Coordinator, the Program owner.
3.1.4 Approval of changes to the Program (i.e., PP 7034 and implementing procedures).
3.2 Manager, Design Engineering, is responsible to ensure:
3.2.1 Control of the Design Basis documentation that affects the Program.
3.2.2 Design compliance with the requirements of the Program.
3.3 Superintendent, Technical Support Services, is responsible to ensure:
Control of the AP-4000 Surveillance Testing Program as it affects the Program.
3.4 Manager, Planning and Scheduling Outage, is responsible to ensure:
3.4.1 Work Order planning complies with the requirements of the Program.
3.4.2 Outage planning complies with the requirements of the Program.
3.5 Inservice Inspection (ISI) Coordinator is responsible:
Assimilate pressure testing and VT-2 visual examination results for inclusion, as needed, in the NIS-1 Summary Reports.
3.6 ASME Section XI Repair and Replacement Program (RRP) Coordinator is responsible:
Assimilate pressure testing and VT-2 visual examination results for inclusion, as needed, in the NIS-2 Summary Reports.
3.7 Pressure Testing Program (PT) Coordinator is responsible to ensure:
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3.7.1 Implementation and administration of the Program.
3.7.2 Development of test configurations for pressure tests required by ASME Section XI.
3.7.3 Coordination of the periodic and interval required pressure tests and VT-2 visual examination.
3.7.4 Maintenance and revision of "Inservice Inspection Pressure Test Program," PP 7034 and of the "Visual Examination Procedure for VT-2," NE 8046 3.7.5 Initiation of VYNEF 8046.01.
3.7.6 Notification of the ANII when pressure tests are to be performed.
3.7.7 Review of completed VYNEF 8046.01 and 8046.02.
3.7.8 Assignment of an Evaluator of Leakage for leakage identified on completed VYNEF 8046.01 and 8046.02.
3.7.9 Evaluations, as required, by the Program.
3.7.10 Provide pressure testing and VT-2 visual examination results input to the ISI and RRP Coordinators for the development of the NIS-I and NIS-2 Summary Reports.
3.7.11 Assignment of certified examiners for conducting VT-2 visual examinations. (Examiners are certified in accordance with NE 8043, "Training, Qualification and Certification of NDE Personnel" or other ENVY approved procedures.)
4.0 PROCEDURE 4.1 Administration The Program provides for two processes: the first is for the performance of Code required periodic and interval pressure testing and VT-2 visual examination; the second is for pressure testing and VT-2 visual examination to support AP 0070, ASME Section XI Repair and Replacement Procedure.
4.1.1 Program Procedure a) The Program text contains general information common to the functions.
b) Appendix A - Inservice Inspection Pressure Test Relief Requests c) Table 1 - Pressure Test Tables 4.1.2 Implementing Procedures a) NE 8046, "Visual Examination Procedure for VT-2" is an implementing procedure of the Program used to execute the examination process. (Examiners are certified in accordance with NE 8043, "Training, Qualification and Certification of NDE Personnel" or other ENVY approved procedures.)
b) OP 4101, "RPV Operational System Leakage Test" is an implementing procedure used to execute the Class 1 System Leakage Test and the VT-2 visual examination.
c) Various operating and surveillance procedures are utilized to provide consistent pressure testing conditions prior to the VT-2 visual examination.
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d) AP 6001 (Installation and Test) and AP 0020 (Installation Requirements) text may be utilized to establish pressure testing conditions prior to the VT-2 visual examination during modification acceptance testing.
4.1.3 Records The Program administrative and implementing procedures, analyses, evaluations, calculations, VT-2 visual examination results, and other records required to define and execute the Program are retained per AP 6806 and AP 6807. Copies of selected records shall be retained in the Pressure Testing Coordinator files.
4.1.4 Reports Reports will be generated as required per the Code. A copy of the report shall be retained in the Pressure Testing Coordinator files.
4.1.5 Reportability Pressure testing conditions adverse to Technical Specifications must be assessed for Emergency Notification System reporting under IOCFR50.72(b)(1)(ii) and (b)(2)(i), and for a Licensee Event Report under 10CFR50.73(a)(2)(ii).
4.1.6 Training and Qualification An approved, position specific training program is in place and functional for the Pressure Testing (Program) Coordinator.
4.1.7 Evaluations The Program requires evaluations for various reasons (e.g., for the requisite Post Modification and Maintenance Testing requirements, etc.). These evaluations shall be documented and a copy retained in the Pressure Testing Coordinator files.
4.1.8 Instrumentation Evaluations When a test instrument used for pressure testing during the instrument's last calibration cycle is determined to be Out of Calibration/Tolerance/Specification, an instrument evaluation shall be documented and a copy retained in the Pressure Testing Coordinator files. The instrument performance will be evaluated against the Code instrument allowable tolerances, unless the event causing the Out of Calibration/Tolerance/Specification condition is known (e.g., pressure gauge was dropped). When the instrument's performance has been determined to exceed the Code allowable tolerance, the affected pressure test and VT-2 visual examination results will be assessed for potential impact.
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4.2 Pressure Tests 4.2.1 System Leakage Tests are conducted while the system is in operation, during a system operability test, or while the system is at rest conditions using an external pressure source.
(a) Class I Systems -- a test of reactor coolant pressure boundary systems or portions of systems at a pressure not less than the pressure corresponding to 100% rated reactor power (-1010 psig) at a temperature permitted by Technical Specifications.
The test is performed once prior to plant startup, following each refueling outage as required by Table IWB-2500-1 of the Code.
- A test is performed following an applicable Section XI Repair/Replacement activity on a system or portion of a system as required by IWA-4500 of the Code.
The test boundary shall correspond to the reactor coolant boundary, with all valves in the position for normal reactor operation startup. During the test conducted at or near the end of each inspection interval (e.g.,
RFO 29), the test boundary shall be extended to all Class 1 pressure retaining components within the system boundary.
The VT-2 visual examination shall extend to the second closed valve at the test boundary extremity.
Prior to the VT-2 visual examination, With NO applicable Section XI Repair/Replacement activity - No holding time is required after attaining system pressure; or With an applicable Section XI Repair/Replacement activity - A holding time of at least 10 minutes is required for noninsulated systems or components; or of at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is required for insulated systems or components on a system or portion of a system as required by IWA-4500 of the Code.
(b) Class 2 & 3 Systems -- a test for systems or portions of systems at the system pressure obtained while the system is performing its normal operating function or during a test conducted to verify operability.
- The test is performed once each Period as required by Tables IWC-2500-1 or IWD-2500-1 of the Code.
- A test is performed following an applicable Section XI Repair/Replacement activity on a system or portion of a system as required by IWA-4500 of the Code.
- The test boundary shall extend to only those portions of systems required to operate or support the safety system function up to and including the first normally closed valve, including a safety or relief valve, or valve capable of automatic closure when the safety function is required.
Prior to the VT-2 visual examination a holding time of:
For Systems In Service During Normal Operating Conditions - at least 10 minutes is required for noninsulated components or at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is PP 7034 Rev 1 Page 9 of I I
required for insulated components after attaining system pressure, unless system has been in service for the minimum required holding time; or For Systems Not In Use DuringNormal OperatingConditions - at least 10 minutes is required after attaining system pressure.
4.2.2 System Hydrostatic Test -- A test for systems or portions of systems during a plant shutdown as specified in IWB-5230, IWC-5230, or IWD-5230 of the Code.
4.2.3 System Pneumatic Test -- A test performed in lieu of a system leakage test or a system hydrostatic test for an ASME Class 2 or 3 systems as permitted by IWC-5222 or IWD-5222 of the Code.
4.2.4 Pressure Decay, Flow Comparison, and Flow Verification Tests -- Special pressure tests per IWA-5244 of the Code for buried components. The Pressure Testing Coordinator shall specify the test method and provide the acceptance criteria for each required examination on a case by case basis.
4.3 Program Positions 4.3.1 Skid mounted EDG components have been excluded. The EDG Skid originates and terminates at the EDG manufacturer's supplied components to ENVY system interface.
EDG Skid components (coolers) directly connected to the service water system, and the EDG Starting Air (DGSA) and Fuel Oil (FO) systems are considered optionally upgraded.
4.3.2 Skid mounted HPCI & RCIC turbines and turbine auxiliaries components are considered optionally upgraded.
4.3.3 Systems or portions of systems that penetrate the Primary Containment have been excluded from the periodic pressure testing program when the piping and isolation valves perform a containment function and the balance of the piping system is outside the scope of the Code (e.g., IA, N2 , RW, etc.) including systems or portions of systems that originate and terminate within the Primary Containment (e.g., H2-0 2 Monitoring, HPCI
& RCIC vacuum breakers, etc.). Systems or portions of systems that have been excluded from the periodic pressure testing program may be subject to the Code for other activities.
4.3.4 The (ADS) Post Seismic Depressurization subsystem (X-51E) of the Instrument Air System is considered optionally upgraded.
4.3.5 Effluent lines originating in or influent lines terminating in the Primary Containment free volume are considered as open ended lines extending to the first shutoff valve (i.e., inside the First Barrier, normally, as designated in PP 7006).
5.0 REFERENCES
AND COMMITMENTS 5.1 Technical Specifications and Site Documents PP 7034 Rev 1 Page 10 of 11
5.1.1 Technical Specification Section 3.6.E/4.6.E 5.1.2 Vermont Yankee Operational Quality Assurance Manual (VOQAM)
I.C ORGANIZATION - Organizational Relationships III.C DESIGN CONTROL - Implementation X.C INSPECTIONS - Implementation XI.C TEST CONTROL - Implementation XV.C NON-CONFORMING MATERIALS, PARTS AND COMPONENTS -
Implementation XVI.C CORRECTIVE ACTIONS CONTROL - Implementation XVII.C QUALITY ASSURANCE RECORDS - Implementation APPENDIX D.III ADMINISTRATIVE CONTROLS - Plant Operating Records 5.2 Administrative Limits None 5.3 Codes, Standards, and Regulations 5.3.1 ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition through 2000 Addenda 5.3.2 Code of Federal Regulations, IOCFR50.2 Definitions 5.3.3 Code of Federal Regulations, I OCFR50.55a dated September 26, 2002 5.3.4 Code of Federal Regulations, 10CFR50 Appendix J 5.3.5 Regulatory Guide 1.147, Rev 12, Inservice Inspection Code Case Applicability 5.3.5 Regulatory Guide 1.26, Rev 3, Quality Group Classifications and Standards for Water-,
Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants 5.3.6 ANS-22, Draft 4, Rev 1, Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants 5.4 Commitments None 5.5 Supplemental References 5.5.1 AP 0009, Event Reports 5.5.2 AP 0095, Plant Procedures 5.5.3 AP 0098, Procedure Writer's Guide 5.5.4 OP 4101, RPV Operational System Leakage Test 5.5.5 AP 6006, Safety Classification of Structures, Systems, Components and Parts 5.5.6 AP 6806, Transfer of Quality Assurance Records to RIMS 5.5.7 AP 6807, Collection, Temporary Storage and Retrieval of Quality Assurance Records 5.5.8 PP 7006, Primary Containment Leak Rate Testing Program 5.5.9 PP 7801, Quality Assurance Records Program 5.5.10 NE 8046, Visual Examination Procedure for VT-2 6.0 FINAL CONDITIONS 6.1 The Program Owner shall ensure that the required information from the Inservice Inspection Pressure Testing Program is included in the NIS-l Report.
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6.2 QA records shall be collected, stored and processed in accordance with PP 7801, "Quality Assurance Records Program," requirements for QA record handling and storage.
7.0 ATTACHMENTS 7.1 Appendix A - Inservice Inspection Program Pressure Test Relief Requests 7.2 Pressure Test Table - Table 1 PP 7034 Rev I Page 12 of Il
APPENDIX A 10 CFR 50.55a Request Number: PT-1 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
- 1. ASME Code Component(s) Affected All ASME Code Components within the scope of 10 CFR 50.55a(g) in the following Systems:
Service Water Fuel Pool Cooling Alternate Cooling Subsystem of Reactor Building Closed Loop Cooling Water
2. Applicable Code Edition and Addenda
ASME Section XI - 1998 Edition through the 2000 Addenda
3. Applicable Code Requirement
Table IWD-2500-1, Category D-B, Item D2.20
- 4. Reason For Request ENVY has concluded that Code Case N-498-1 is not applicable to the 1998 Edition through the 2000 Addenda and therefore requests an alternative to the code requirements on the basis that the proposed alternative would provide an acceptable level of quality and safety.
- 5. Proposed Alternative and Basis for Use ProposedAlternative:
(1) A system leakage test, in accordance with IWA-521 1(a), shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection interval at the system nominal operating pressure.
(2) The boundary subject to test pressurization during the test shall extend to all Class 3 components included in those portions of systems required to operate or support the safety system function up to and including the first normally closed valve, including a safety or relief valve, or valve capable of automatic closure when the safety function is required.
(3) Prior to the VT-2 visual examination a holding time of:
For Systems In Service During Normal Operating Conditions - at least 10 minutes is required for noninsulated components or at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is required for insulated components after attaining system pressure, unless the system has been in service for the minimum required holding time; or For Systems Not In Use During Normal Operating Conditions - at least 10 minutes is required after attaining system pressure.
(4) The system shall be maintained at the nominal operating pressure during performance of the VT-2 visual examination of all components identified in (2) above.
(5) Test instrumentation requirements of IWA-5260 are not applicable.
Appendix A PP 7034 Rev I Page I of 2
APPENDIX A (Continued)
Basis:
ASME Section XI 1998 Edition through the 2000 Addenda requires only a System Leakage Test to fulfill all inspection period and interval pressure test conditions prior to a VT-2 visual examination for Class I and 2 pressure retaining components.
For the Class 3 systems in service during normal operating conditions, Auxiliary Operators certified as VT-2 visual examiners, perform tours three times a day in accessible areas during normal plant operations. For all systems, control room operators can observe system pressure anomalies or an increase in sump pump operation. It is for more likely that a pressurized component will leak under extended operation, than during a static test at a higher pressure that is only observed for a brief time.
The normally, Class 3 systems not in use during normal operating conditions, are operated to demonstrate safety system functionality or to satisfy technical specification surveillance requirements quarterly and are therefore, similarly monitored operationally 4 times per year or 40 times per inspection interval. Additionally, the proposed alternative holding time is the same as per 10CFR50.55a(b)(2)(xx) for the system leakage test requirements performed once each inspection period for Class 2 and 3 systems not in use during normal operations. The minimum 10-minute holding time prior to the VT-2 visual inspection will provide adequate assurance of the leak-tight integrity of all components.
As evidenced by the acceptability of Section XI ASME Code Case N-498-1, the hydrostatic testing requirement does not provide a compensating increase in the level of quality or safety.
- 6. Duration of Proposed Alternative Fourth Ten-Year Inservice Inspection Interval
- 7. Precedents Requested alternative is similar to that provided in the approved Section XI ASME Code Case N-498-1 found acceptable in Regulatory Guide 1.147 Revision 12 and ENVY's Third Inservice Inspection Interval approved relief request P-3.
Appendix A PP 7034 Rev I Page 2 of 2