ML050630348

Third Ten Year Inservice Inspection Interval Requests for Relief No. 04-ON-013, Revision 1

ML050630348
Person / Time
Site:	Oconee
Issue date:	02/17/2005
From:	Rosalyn Jones Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
04-ON-013, Rev 1
Download: ML050630348 (10)

Text

Duke RON A. JONES MhfPowere Vice President Oconee Nuclear Site A Duke Energy Company Duke Power ONO1 VP / 7800 Rochester Highway Seneca, SC 29672 864 885 3158 864 885 3564 fax February 17, 2005 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

Duke Energy Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269,-270, -287 Third Ten Year Inservice Inspection Interval Requests for Relief No. 04-ON-013, Revision 1 By letter dated December 21, 2004, Duke Energy (DUKE) submitted Request for Relief No. 04-ON-013 pursuant to 10 CFR 50.55a(a)(3)(i). That request addressed four specific sections of pipe in equivalent locations on both Unit 1 and Unit 2 which were inadvertently omitted from testing during the Class 1 tests during the third ten year interval. That interval has ended on all three units.

The equivalent sections of pipe on Unit 3 were not addressed in the relief due to Duke's intention to perform this testing during the 3EOC21 refueling outage, which is now complete. The testing was completed satisfactorily on three of the four sections of pipe. However, during that testing, valve 3HP-0492, associated with one of these sections, could not be opened. As a result, the associated section of pipe could not be exposed to system pressure as planned. Therefore, Duke hereby submits Request for Relief No. 04-ON-013, Revision 1, attached, which has been modified to include this one section of Unit 3 pipe in addition to the Unit 1 and 2 sections which were previously addressed.

Request for Relief 04-ON-013 will allow Duke Energy to credit testing to be performed on these sections during the fourth ten year interval in lieu of the required third interval tests. In this case, the tests on these piping 414 www. dukepower. corn

U. S. Nuclear Regulatory Commission February 17, 2005 Page 2 sections would be performed in the first refueling outage in the fourth interval as follows:

Unit 1 - 1EOC22, Scheduled to begin 04/09/05 Unit 2 - 2EOC21, Scheduled to begin 10/22/05.

Unit 3 - 3EOC22, Scheduled to begin 04/29/06.

Therefore, Duke Energy requests that the NRC grant relief as authorized under 10 CFR 50.55a(a)(3)(i).

If there are any questions or further information is needed you may -ontact R. P. Todd at (864) 885-3418.

Very u yours, R. A J es Site Vice President Attachment

U. S. Nuclear Regulatory Commission February 17, 2005 Page 3 xc w/att: Mr. William D. Travers Administrator, Region II U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St., SWW, Suite 23T85 Atlanta, GA 30303 L. N. Olshan, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 xc(w/o attch):

M. C. Shannon Senior NRC Resident Inspector Oconee Nuclear Station Mr. Henry Porter Division of Radioactive Waste Management Bureau of Land and Waste Management SC Dept. of Health & Environmental Control 2600 Bull St.

Columbia, SC 29201

Duke Energy Corporation Oconee Nuclear Station Units 1 & 2 Request for Relief No. 04-ON-01 Rev 1 1.0 System / Component for Which Relief is Requested:

Relief is requested for 1 inch Nominal Pipe Size (NPS) portions of ASME Code Class 1 piping and components connected to the Reactor Coolant System (RCS) that are normally isolated from direct RCS pressure during normal operation. These areas are isolated from the RCS by their configuration between two normally closed valves that remain closed when the unit is in Modes 3, 2, or 1.

This relief is requested for the third 10-year interval, which is now complete on all three units.

2.0 Applicable Code Edition and Addenda

ASME Boiler & Pressure Vessel Code,Section XI, 1989 Edition with no addenda.

3.0 Applicable Code Requirement

Section XI, Table IWB-2500-1 Examination Category B-P, Pressure Retaining Components, System Hydrostatic Test, all Class 1 components within the system boundary.

This test is to be conducted once during the 10 year interval, either at or near the end of the interval.

Code Case N498-1: Alternative Rules for 10-year system hydrostatic testing for Class 1, 2, and 3 systems,Section XI, Division 1.

a. It is the opinion of the committee that as an alternative to the 10 year system Hydrostatic test required by Table IWB-2500-1 Category B-P, the following rules shall be used:

(1) A system leakage test (IWB-5221) shall be conducted at or near the end of each inspection interval, prior to reactor startup.

(2) The boundary subject to test pressurization during the system leakage test shall extend to all Class 1 pressure retaining components within the system boundary.

(3) Prior to performing the VT-2 visual examination, the system shall be pressurized to nominal operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for non-insulated systems. The system shall be maintained at nominal operating pressure during the performance of the VT-2 visual examination.

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Duke Energy Corporation Oconee Nuclear Station Units 1 & 2 Request for Relief No. 04-ON-01 Rev I (4) The test temperatures and pressures shall not exceed limiting conditions for the hydrostatic test curve as contained in the plant Technical Specifications.

(5) The VT-2 visual examination shall include all components within the boundary identified in (a)(2) above.

(6) Test instrumentation requirements of IWA-5260 are not applicable.

IWB-5221 System Leakage Test (a) The system leakage test shall be conducted at a test pressure not less than the nominal operating pressure associated with 100% rated reactor power.

(b) The system test pressure and temperature shall be attained at a rate in accordance with the heat-up limitations specified for the system.

The application of the above ASME Code requirements along with those of Code Case N-498-1 would require all Class 1 pressure retaining components within the system boundary to be pressurized and VT-2 visually examined.

Relief is requested to defer the 10-year interval pressure test on the four identified areas in Units 1 and 2 and from the one identified area in Unit 3 from the end of the third interval to the first refueling outage in the fourth interval.

In accordance with the requirements of 10 CFR 50.55a(a)(3)(i), relief is requested from the requirements of the 1989 ASME B&PV Code,Section XI, Category B-P, Table IWB-2500-1, footnote (6). This footnote mandates performance of the 10-year pressure test to be conducted at or near the end of each inspection interval.

4.0 Reason for Request

Four areas in Unit I and four identical areas in Unit 2 were inadvertently not pressure tested during the performance of the Class 1 10-year pressure test. One area in Unit 3 could not be pressurized because valve 3HP-492 malfunctioned and could not be safely opened during the Class 1 test. These sections of pipe are identical configurations in each unit and are as follows:

Section 1: 1" pipe between isolation valves HP-490 and HP-497 (Units 1 & 2)

Section 2: 1" pipe between isolation valves HP-491 and HP-498 (Units 1 & 2)

Section 3: 1" pipe between isolation valves HP-492 and HP-499 (Units 1, 2 & 3)

Section 4: 1" pipe between isolation valves HP-493 and HP-500 (Units 1 & 2)

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Duke Energy Corporation Oconee Nuclear Station Units I & 2 Request for Relief No. 04-ON-01 Rev 1 5.0 Proposed Alternative and Basis for Use:

The four identified areas in Unit 1 and Unit 2 were inadvertently omitted from the Class 1, 10-year pressure test, performed in the third interval. The one identified*

area in Unit 3 could not be pressurized because valve 3HP-492 could not be safely opened due to a malfunction. A task to repair or replace 3HP-492 is being added to the schedule for the next Unit 3 outage, 3EOC22.

Per the requirements of the 1989 ASME B&PV Code,Section XI, Category B-P, Table IWB-2500-1, footnote (1), the identified areas have received a VT-2 visual exam each refueling outage without being pressurized and have had no evidence of leakage. The next opportunity to pressurize these areas and perform a VT-2 visual exam will be during the next refueling outage, which will be during the fourth interval. Therefore, the proposed alternative is that all these areas will be 10-year pressure tested during the next refueling outage on the respective units.

If a leak were to develop in any of these areas, it could be detected by various means available to the operators. Area monitors will alarm when the radiation levels of the reactor building atmosphere reach set limits.

Additionally, plant Technical Specification 3.4.13 requires that at least once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, when above Mode 5, the Reactor Coolant System (RCS) water inventory balance be performed. This Technical Specification limits the amount of unknown leakage to I gpm. If this limit is exceeded, then the source must be identified or the reactor must be placed in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Besides the area radiation monitors and the RCS inventory monitoring, other leakage detection methods available include periodic pumping the reactor building normal sump.

Starting at Mode 3, during reactor shutdown for refueling outages, numerous inspections are made in the reactor building looking for indications of leakage. Each leak is evaluated and repaired.

6.0 Implementation Schedule:

Relief is requested to defer the 10-year interval pressure test on the four identified areas in Units 1, and 2 and the one area on Unit 3 from the end of the third interval to the first refueling outage in the fourth interval. The third interval end date for each unit is as follows:

Unit 1 January 1, 2004 Unit 2 September 9, 2004 Unit 3 January 2, 2005 Page 3 of 7

Duke Energy Corporation Oconee Nuclear Station Units 1 & 2 Request for Relief No. 04-ON-01 Rev I I The current schedule for the first refueling outage in the fourth interval for each unit is:

Unit 1 - 1EOC22, scheduled for 04/09/05 Unit 2 - 2EOC21, scheduled for 10/22/05 Unit 3 - 3EOC22, scheduled for 04/29/06 1.0 Other Information:

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Duke Energy Corporation Oconee Nuclear Station Units 1 & 2 Request for Relief No. 04-ON-01 Rev 1 I Page 5 of 7

Duke Energy Corporation Oconee Nuclear Station Units 1 & 2 Request for Relief No. 04-ON-01 Rev 1 l Page 6 of 7

- s Duke Energy Corporation Oconee Nuclear Station Units 1 & 2 Request for Relief No. 04-ON-01 Rev 1 I Valves HP-493 through HP-500 Flow Diagram

OFD-1OlA-1.4 (Unit I Shown - Unit 2 Is lE D

C Valve HP-500 on top

& HP-493 t f.IA e'

on bottom ,-1 Page 7 of 7