ML051580203

Request for Relief from System Hydrostatic Test Requirements for Small Bore (5 1 Inch), ASME Code Class 1 Reactor Coolant Pressure Boundary (RCPB) Vent, Drain, and Branch (Vtdb) Lines and Connections

ML051580203
Person / Time
Site:	FitzPatrick
Issue date:	05/26/2005
From:	Ted Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-05-008 1, RR-36, TAC MC1472
Download: ML051580203 (4)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

.A . James A. Fitzpatrick NPP P.O. Box 110 E nter tC1Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 T.A. Sullivan May 26, 2005 Site Vice President - JAF JAFP-05-008 1 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Relief Request No. RR-36 Request for Relief from System Hydrostatic Test Requirements for Small Bore (5 1 inch), ASME Code Class 1 Reactor Coolant Pressure Boundary (RCPB) Vent, Drain, and Branch (VTDB) Lines and Connections

References:

1. USNRC letter from D.J. Roberts to M. Kansler, dated January 6, 2005 regarding Pilgrim Nuclear Power Station Relief Request No. PRR-29, Relief from System Hydrostatic Test Requirements for Small Bore (< 1-inch), ASME BPV Code Class I RCPB Vent, Drain and Branch Lines and Connections (TAC No. MC 1472)

Dear Sir or Madam:

The purpose of this letter is to request NRC approval of the attached James A. FitzPatrick (JAF) Relief Request No. RR-36 (Enclosure 1) which proposes: (1) a system leakage test in lieu of a full hydrostatic test; and (2) testing to the normal operating pressure boundary on small bore (< 1 inch) ASME Code Class 1 Reactor Coolant Pressure Boundary (RCPB) vent, drain, and branch (VTDB) lines and connections in lieu of the full Class I pressure boundary.

RR-36 requests relief from the Inservice Inspection Program requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 1989 Edition. The request applies to the system hydrostatic test requirements for small bore (< 1 inch), ASME Code Class I Reactor Coolant Pressure Boundary (RCPB) vent, drain, and branch lines and connections. Entergy has concluded that this proposed alternative provides an acceptable level of quality and safety, and that compliance with the specified Code requirements would result in unnecessary hardship without a compensating increase in the level of quality and safety. The relief is requested under the provisions of 10 CFR 50.55a(a)(3)(ii).

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A similar relief request was approved for the Pilgrim Nuclear Power Station (Reference 1).

Entergy requests approval of the relief request by May 2006, to support JAF Refueling Outage (RFO) - 17.

Should you have any questions concerning this letter, please contact Mr. Richard Plasse, Regulatory Compliance Manager at (315) 349-6793.

There are no new commitments made in this letter.

Very truly yours,

- -a _ v A_ -~ - a_ ; __ -~ A s

• T.A. SULLIVAN TAS:GB:dr : Relief Request Number RR-36 cc:

Regional Administrator, Region 1 Mr. Paul Eddy U.S. Nuclear Regulatory Commission New York State Department 475 Allendale Road of Public Service King of Prussia, PA 19406-1415 3 Empire State Plaza, 10'h Floor Albany, NY 12223 Office of the Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Mr. P. Milano, Sr. Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop MS-8-C2 Washington, DC 20555-0001 Mr. Peter R. Smith, President NYSERDA 17 Columbia Circle Albany, NY 12203-6399

- Attachment I to JAFP-05-0000 RELIEF REQUEST NO. RR-036 James A. FitzPatrick Nuclear Power Plant Third Inservice Inspection Interval Inservice Inspection Program Relief from System Hydrostatic Test Requirements for Small Bore (s 1 inch)

ASME Pressure Vessel Code Class 1 Reactor Coolant Pressure Boundary Vent, Drain and branch lines and Connections ASME CODE COMPONENT(S) FOR WHICH RELIEF IS REQUESTED Code Class: 1

References:

IWB-2500, Table IWB-2500-1 Examination Category: B-P Item Numbers: B15.51 and B15.71 Parts Examined: Piping and Valves

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Description:==

Class 1 components within the Reactor Coolant System Component Number: Reactor Coolant Pressure Boundary (RCPB) vent, drain and branch (VTDB) lines and connections, Small bore (<

1 inch)

APPLICABLE CODE EDITION AND ADDENDA The Code of Record for JAFNPP's Third Inservice Inspection Interval is ASME Section Xi Code, 1989 Edition, No Addenda.

RELIEF REQUEST JAFNPP requests relief from ASME Section Xi Code, 1989 Edition, Subsection IWB-2500 Examination and Pressure Test requirements (Class 1), Table IWB-2500-1, Examination Category B-P (All Pressure Retaining Components), Items No. B15.51 (Piping) and B15.71 (Valves). Note 2 of Table IWB-2500-1 states that 'The pressure retaining boundary during system hydrostatic test shall include all Class 1 components within the system boundary."

This would require the normally closed vent, drain and branch lines and connections to be opened and/or pressurized. Specifically, JAFNPP proposes to perform an ASME Code Class 1 System Leakage Test in accordance with the requirements of ASME Code 2001 Edition, 2003 Addenda, Subsection IWB-2500, Table 2500-1 for Class 1 system components; with the reactor coolant pressure boundary (RCPB) vent, drain, and branch (VTDB) lines and connections in the normally closed position.

BASIS FOR REQUEST The 2001 Edition, including up to 2003 Addenda of the ASME Section Xl Code has been incorporated into 10 CFR 50.55a(b) by reference (10 CFR 50.55a(b), 69 FR 58819, dated October 1, 2004.) Table IWB-2500-1 of the 2003 Addenda requires a system leakage test at the end of each refueling outage (including the last one at or near the end of the interval) in accordance with requirements of IWB-5220. Subsection IWB-5220, Subparagraph IWB-1

Attachment I to JAFP-05-0000 RELIEF REQUEST NO. RR-036 ALTERNATE EXAMINATIONS A system leakage test of the Class 1 systems and components will be performed prior to plant startup following each refueling outage, in accordance with ASME Section Xl Code, 2001 Edition, 2003 Addenda, Table IWB-2500-1 and IWB-5220 requirements, with the exception that the RCPB VTDB lines and connections will be visually examined for leakage and any evidence of past leakage, with the isolation valves in the normally closed position.

The RCPB VTDB lines and connections will be visually examined with the isolation valves in the normally closed position during the 10-year Inservice Inspection System Leakage Test.

This examination will be performed at nominal operating pressure associated with 100%

reactor power after satisfying the required 4-hour hold time.

The above proposed alternative provides an acceptable level of quality and safety.

IMPLEMENTATION SCHEDULE This request is applicable for the remaining Third 10-Year Interval duration, which currently ends on December 31, 2006.

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