ML073230126

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10 CFR 50.55a Alternative Requests from ASME Section XI, IWA-5244, Buried Piping
ML073230126
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 11/09/2007
From: Gerald Bichof
Dominion Nuclear Connecticut
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
07-0338, IWA-5244
Download: ML073230126 (21)
v • d • e


Text

Dominion Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, Virginia 23060 Dominio Web Address: www.dom.com November 9, 2007 U. S. Nuclear Regulatory Commission Serial No. 07-0338 Attention: Document Control Desk NSS&L/DF R2 One White Flint North Docket Nos. 50-336 11555 Rockville Pike 50-423 Rockville, MD 20852-2738 License Nos. DPR-65 NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 AND 3 10 CFR 50.55a ALTERNATIVE REQUESTS FROM ASME SECTION XI, IWA-5244, BURIED PIPING Pursuant to 10 CFR 50.55a(a)(3)(ii), Dominion Nuclear Connecticut, Inc. (DNC) hereby submits requests for relief from the requirements of ASME Code,Section XI, 1989 Edition, IWA-5244, "Buried Piping," at Millstone Power Station Units 2 and 3 (MPS2 and MPS3). Specifically, relief is requested to perform an alternative to the pressure test requirements of IWA-5244(a) and IWA-5244(b) for certain portions of buried piping.

DNC has determined the proposed alternatives provide for an acceptable level of quality and safety, consistent with 10 CFR 50.55a(a)(3)(ii). MPS2 is in its third inservice inspection (ISI) interval and MPS3 is in its second ISI interval.

The proposed alternatives to the Code are contained in attachments to this letter as follows: - Proposed Alternative From Pressure Test Requirements of ASME Section XI, IWA-5244 Buried Piping in Accordance with 10 CFR 50.55a(a)(3)(ii), MPS3 Class 2 Piping (IR-2-40) - Proposed Alternative From Pressure Test Requirements of ASME Section XI, IWA-5244 Buried Piping in Accordance with 10 CFR 50.55a(a)(3)(ii), MPS2 and MPS3 Class 3 Piping (RR-89-57 and IR-2-41)

DNC requests NRC review and approval of these requests by November 15, 2008.

If you should have any questions regarding this submittal, please contact Margaret Earle at (804) 273-2768.

Very truly yours, Gerald T. Bischof Vice President - Nuclear Engineering

Serial No. 07-0338 Docket Nos. 50-336 50-423 Page 2 of 2 Attachments Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 Ms. C. J. Sanders Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 0-8 B3 Rockville, MD 20852-2738 Mr. S. W. Shaffer NRC Senior Resident Inspector Millstone Power Station

Serial No. 07-0338 Docket No. 50-423 ATTACHMENT I PROPOSED ALTERNATIVE FROM PRESSURE TEST REQUIREMENTS OF ASME SECTION XI, IWA-5244 BURIED PIPING IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(ii)

MPS3 CLASS 2 PIPING (IR-2-40)

DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No. 07-0338 Docket Nos. 50-423 Attachment 1, Page 1 of 8 PROPOSED ALTERNATIVE FROM PRESSURE TEST REQUIREMENTS. OF.ASME SECTION X1I IWA-5244 BURIED PIPING IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(ii)

MPS3 CLASS 2 PIPING (IR-2-40)

- Hardship or Unusual Difficulty Without CompensatingIncrease in Level of Quality or Safety -

1.0 Reason for Request An alternative is requested from performing the pressure testing using the pressure loss or change in flow methods described in IWA-5244(a) and IWA-5244(b) for the buried piping segments of the Class 2 Quench Spray (QSS), Safety Injection (SI) and Auxiliary Feedwater (AFW) Systems. The alternative is requested on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The buried piping segments of the Class 2 QSS, SI, and AFW Systems are provided with a single, normally locked-open valve at their respective storage tanks. These are butterfly type valves for the QSS and SI piping from the Refueling Water Storage Tank (RWST) and gate type valves for the AFW piping segments from the Demineralized Water Storage Tank (DWST). These tanks are of such a large capacity that a small increase in level due to leakage through the tank boundary valve could not be detected.

A pressure decay test on these buried piping segments, that do not have double isolation valves with a drain test connection to quantify internal valve seat leakage, could not differentiate between boundary valve internal seat leakage and external pressure boundary leakage from the buried piping segment. To perform an accurate pressure drop test, extensive maintenance or system modification would be required.

For example the -storage tanks would need to be drained and additional valves installed, or the valves would need to be removed from the system and blind flanges installed.

The configuration of the piping segments do not provide for a sufficient straight length of pipe to properly install a flowmeter for accurate flow measurement at the storage tank ends of the buried pipe segments. Therefore, it is not possible to compare a change in flow between the ends of the buried components. There is no annulus provided in which the areas at the ends of the buried components could be visually examined and there is no access to the buried sections without excavation.

Serial No. 07-0338 Docket Nos. 50-423 Attachment 1, Page 2 of 8

2.0 ASME Code Components Affected

This requestapplies to the Class 2 buried segments of piping from the MPS3 Refueling Water Storage Tank (RWST) to the QSS and SI Systems, and from the Demineralized Water Storage Tank (DWST) to the AFW System.

Code Class: 2 Code

Reference:

ASME Section Xl, IWA-5244 Examination Category: C-H Item Number: C7.30 The applicable piping line numbers are identified as follows:

" Line 3SIL-024-152 One 24" (common train) suction line of the low pressure safety injection (SIL) / residual heat removal (RHS) pumps from the RWST that also provides suction to the high pressure safety injection (SIH) and charging (CHS) pumps. (Reference FSAR Figure 6.2-37. Excerpts of FSAR drawings are provided at the end of this Attachment for information only.)

All of the subject buried segments are constructed of corrosion resistant Type 304 stainless steel. During original installation additional preventative measures were taken to mitigate corrosion and protect the external piping surfaces with the application of two coats of a silicone protective coating.

3.0 Applicable Code Edition and Addenda

The applicable Code for MPS3 is the American Society of Mechanical Engineers (ASME) Code, Section Xl, 1989 Edition, No Addenda.

4.0 Applicable Code Requirement

The 1989 Edition of ASME Section Xl requires that for "Buried Components" the pressure test requirements of IWA- 5244 will be applied as follows:

IWA-5244(a) - In nonredundant systems where buried components are isolable by means of valves, the visual examination VT-2 shall consist of a leakage test that.determines the rate of pressure loss. Alternatively, the test may determine

Serial No. 07-0338 Docket Nos. 50-423 Attachment 1, Page 3 of 8 the change in flow between the ends of the buried components. The acceptable rate of pressure loss shall be established by the owner.

IWA-5244(b) - In redundant systems where the buried components are nonisolable, the visual examination VT-2 shall consist of a test that determines the change in flow between the ends of the buried components. In cases where an annulus surrounds the buried components, the areas at each end of the buried components shall be visually examined for evidence of leakage in lieu of a flow test.

IWA-5244(c) - In nonredundant systems where the buried components are nonisolable, such as return lines to the heat sink, the visual examination VT-2 shall consist only of a verification that flow during operation is not impaired.

5.0 Proposed Alternative and Basis for Use 5.1 Proposed Alternative DNC proposes to use, as an alternative to the requirements of IWA-5244(a) or IWA-5244(b), a verification of unimpaired flow in accordance with IWA-5244(c) to provide an acceptable level of quality and safety. For each segment of the subject buried pipe, periodic flow testing will be performed in accordance with Inservice Test (IST) Program surveillance procedures. These surveillance procedures require flow to be measured, recorded and compared to established acceptance criteria to provide the assurance that flow is not impaired during operation. During each flow test, the pump draws suction from the storage tank through the associated buried sections of piping.

5.2 Basis for Use Flow testing of the two QSS pumps is performed quarterly and will use the established minimum flow rate specified in the IST procedures as the acceptance criteria for the pressure testing of the associated 14" QSS buried pipe segments.

The flow rate is currently specified as 3,950 gallons per minute (gpm).

Flow testing of the two RHS pumps is performed during each cold shutdown and will use the established minimum flow rate specified in the IST procedures as the acceptance criteria for the associated single 24" SIL buried pipe segment. The flow rate is currently specified as 4,000 gpm.

Flow testing of the three AFW pumps is performed each refueling outage and will use the established minimum flow rates specified in the IST procedures as the acceptance criteria for the associated 8" and 10" AFW buried pipe segments. The flow rate of the two motor driven pumps will be used as the acceptance criteria for the 8" segments and the flow rate of the turbine driven pump will be used as the

Serial No. 07-0338 Docket Nos. 50-423 Attachment 1, Page 4 of 8 acceptance criteria for the 10" segment. These flow rates are currently specified as 490 gpm for each of the two motor driven pumps and 750 gpm for the turbine driven pump.

If during the IST surveillances the minimum flows cannot be achieved, the pump(s) would be declared inoperable and a condition report initiated in accordance with the Millstone Corrective Action Program with further corrective actions as required to restore the pump(s) and/or system to an operable status.

Additionally, the level in the RWST and DWST are monitored periodically to satisfy Technical Specification requirements. In the case of the DWST, monitoring is performed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in the case of the RWST, monitoring is performed once every seven days. The RWST and DWST also have a low level alarm in the control room.

The existing tank isolation valves are administratively locked open during all modes of operation, thus the buried sections of piping are continuously exposed to the static head pressure of their respective storage tanks. Tank level losses due to leakage from buried piping would be promptly identified.

5.3 Discussion on Acceptable Level of Quality or Safety or Hardship Without A Compensating Increase in the Level of Quality or Safety Based on the hardship described above and the use of inservice flow testing to verify that flow through the buried piping is unimpaired, and in conjunction with the periodic storage tank level monitoring, it is DNC's determination that this alternative provides an acceptable level of quality and safety.

The hardship is considered by DNC to be without a compensating increase in the level of quality or safety for the following reasons:

  • These surveillance procedures require flow to be measured, recorded and compared to established acceptance criteria to provide the assurance that flow is not impaired during operation.

" During each flow test, the pump draws suction from the storage tank through the associated buried sections of piping.

" The verification of unimpaired flow in accordance with IWA-5244(c) provides an acceptable level of quality and safety considering the proposed alternative and its basis for use.

Serial No. 07-0338 Docket Nos. 50-423 Attachment 1, Page 5 of 8 6.0 Duration of Proposed Alternative The proposed alternative to the Code is applicable for the remainder of the second 10-year inservice inspection (ISI) interval at MPS3, which began April 23, 1999.

7.0 Precedents A similar request for relief of buried Service Water piping was previously approved for Byron Station, Units 1 and 2 (Relief 13R-07) and Braidwood Station Units 1 and 2 (Relief 12R-46) by letter dated January. 16, 2007. (Reference TAC NOS. MD1757, MD1758, MD1759 and MD1760)

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Serial No. 07-0338 Docket Nos. 50-336 50-423 ATTACHMENT 2 PROPOSED ALTERNATIVE FROM PRESSURE TEST REQUIREMENTS OF ASME SECTION XI, IWA-5244, BURIED PIPING IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(ii)

MPS2 AND MPS3 CLASS 3 PIPING (RR-89-57 and, IR-2-41)

DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 AND 3

Serial No. 07-0338 Docket Nos. 50-336 50-423 Attachment 2, Page 1 of 9 PROPOSED ALTERNATIVE FROM PRESSURE TEST REQUIREMENTS OF ASME SECTION XI, IWA-5244 BURIED PIPING IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(ii)

MPS2 AND MPS3 CLASS 3 PIPING (RR-89-57 for MPS2, IR-2-41 for MPS3)

- Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety -

1.0 Reason for Request An alternative is requested from performing the pressure testing using the pressure loss or change in flow methods described in IWA-5244(a) and IWA-5244(b) for the buried piping segments of the MPS2 and MPS3 Class 3 Service Water System (SWS) on the basis. that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The buried piping segments of the MPS2 and MPS3 Class 3 SWS piping are bounded by butterfly valves that are not designed or expected to provide an adequate leak tight boundary that is necessary for an accurate pressure decay test, and extensive maintenance or system modification would be required to conduct this test. For example, the valves would need to be replaced with valves that have better leakage control characteristics, or the valves would need to be removed from the system and blind flanges installed.

The configuration of the piping segments do not provide for a sufficient straight length of pipe to properly install a flowmeter for accurate flow measurement at the ends of the buried pipe segments. Therefore, it is not possible to compare a change in flow between the ends of the buried components.

There is no annulus provided in which the areas' at the ends of the buried components could be visually examined and there is no access to the buried sections without excavation.

2.0 ASME Code Components Affected

This request applies to the MPS2 and MPS3 Class 3 buried portions of the SWS supply piping.

A

Serial No. 07-0338 Docket Nos. 50-336 50-423 Attachment 2, Page 2 of 9 Code Class: 3 Code

Reference:

ASME Section Xl, IWA-5244 Examination Category: D-B Item Number: D2.10 MPS2 buried piping segments consist of two trains of buried 24" SWS supply piping from the intake structure to the turbine building. This piping is cement lined, cast ductile-iron material with an additional epoxy lining applied utilizing an in-situ form process to enhance long-term life.

The applicable piping line number is identified as follows: 24"-KE-1 (Reference MPS2 FSAR Figure 9.7-1. Excerpts of FSAR drawings are provided at the end of this Attachment for information only.)

MPS3 buried piping segments consist of two trains of buried 30" SWS supply piping from the intake structure to the auxiliary building including branch lines to loads in the emergency diesel generator, control, and emergency safeguards buildings. This piping is carbon steel material clad with copper nickel and encased in concrete.

The applicable piping line numbers are identified as follows (Reference MPS3 FSAR Figure 9.2-1, Sheets 2 and 4.):

3SWP-030-191-3 / 3SWP-030-190-3 (sheets 2 and 4) 3SWP-026-65-3 / 3SWP-026-57-3 (sheets 2 and 4) 3SWP-012-24-3 / 3SWP-012-13-3 (sheet 4) 3SWP-010-25-3 / 3SWP-010-40-3 (sheet 4) 3SWP-006-31-3 / 3SWP-006-226-3 (sheet 4)

3.0 Applicable Code Edition and Addenda

The applicable Code for MPS2 and MPS3 is the American Society of Mechanical Engineers (ASME) Code,Section XI, 1989 Edition, No Addenda.

4.0 Applicable Code Requirement

The 1989 Edition of ASME Section Xl requires that for "Buried Components" the pressure test requirements of IWA- 5244 will be applied as follows.

IWA-5244(a) - In nonredundant systems where buried components are isolable by means of valves, the visual examination VT-2 shall consist of a leakage test that determines the rate of pressure loss. Alternatively, the test may determine the change in flow between the ends of the buried components. The acceptable rate of pressure loss shall be established by the owner.

Serial No. 07-0338 Docket Nos. 50-336 50-423 Attachment 2, Page 3 of 9 IWA-5244(b) - In redundant systems where the buried components are nonisolable, the visual examination VT-2 shall consist of a test that determines the change in flow between the ends of the buried components. In cases where an annulus surrounds the buried components, the areas at each end of the buried components shall be visually examined for evidence of leakage in lieu of a flow test.

IWA-5244(c) - In nonredundant systems where the buried components are nonisolable, such as return lines to the heat sink, the visual examination VT-2 shall consist only of a verification that flow during operation is not impaired.

5.0 Proposed Alternative and Basis for Use 5.1 Proposed Alternative DNC proposes to use, as an alternative to the requirements of IWA-5244(a) or IWA-5244(b), a verification of unimpaired flow in accordance with IWA-5244(c) to provide an acceptable level of quality and safety. For each segment of the subject buried pipe, periodic flow testing will be performed in accordance with Inservice Test (IST) Program surveillance procedures. These surveillance procedures require flow to be measured, recorded and compared to established acceptance criteria to provide the assurance that flow is not impaired during operation.

5.2 Basis for Use Flow testing of the three MPS2 SW pumps is performed quarterly and will use the established minimum flow rate specified in the IST procedures. The current flow rate is 10300 gpm and will be used as the acceptance criteria for the SWS buried pipe segments.

Flow testing of the four MPS3 SW pumps is performed quarterly and will use the established minimum flow rate specified in the IST procedures. The current flow rate is 8820 gallons per minute (gpm) and will be used as the acceptance criteria for the SWS buried pipe segments.

If during the IST surveillances the minimum flows cannot be achieved, the pump(s) would be declared inoperable and a condition report initiated in accordance with the Millstone Corrective Action Program with further corrective actions as required to restore the pump(s) and/or system to an operable status.

Additionally, internal visual inspection is performed of the buried pipe segments periodically during plant refueling outages to ensure the piping, coating, or lining is not experiencing unacceptable degradation. For MPS2 this visual inspection is performed on alternating trains each refueling outage. For MPS3 this visual

Serial No. 07-0338 Docket Nos. 50-336 50-423 Attachment 2, Page 4 of 9 inspection is performed on the accessible piping that is 18 inches in diameter and greater on alternating trains each refueling outage.

5.3 Discussion on Acceptable Level of Quality or Safety or Hardship Without A Compensating Increase in the Level of Quality or Safety Based on the hardship described above and the use of inservice flow testing to verify that flow, through the buried piping is unimpaired, and in conjunction with the periodic internal visual inspections, it is DNC's determination that this alternative provides an acceptable level of quality and safety.

The hardship is considered by DNC to be without a compensating increase in the level of quality or safety for the following reasons:

  • These surveillance procedures require flow to be measured, recorded and compared to established acceptance criteria to provide the assurance that flow is not impaired during operation.
  • Internal visual inspections ensure the piping, coating, or lining is not experiencing unacceptable degradation.
  • The verification of unimpaired flow in accordance with IWA-5244(c) provides an acceptable level of quality and safety considering the proposed alternatives and their basis for use.

6.0 Duration of Proposed Alternative The proposed alternative to the Code is applicable for the remainder of the third 10-year inservice inspection (ISI) interval at MPS2 that began April 1, 1999 and for the remainder of the second ISI interval at MPS3 that began April 23, 1999.

7.0 Precedents A similar request for relief of buried Service Water piping was previously approved for Byron Station, Units 1 and 2 (Relief 13R-07) and Braidwood Station Units 1 and 2 (Relief ,12R-46) by letter dated January 16, 2007. (Reference TAC NOS. MD1757, MD1758, MD1759 and MD1760)

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