ML13350A109
| ML13350A109 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/09/2013 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML13350A109 (12) | |
Text
10 CFR 50.55a VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 December 9, 2013 United States Nuclear Regulatory Commission Serial No.13-639 Attention: Document Control Desk SPS-LIC/CGL R1 Washington, D. C. 20555 Docket Nos.
50-280 50-281 License Nos.
DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 ASME SECTION XI FOURTH INTERVAL INSERVICE INSPECTION (ISI) PROGRAM REVISED RELIEF REQUESTS SPT-003 AND SPT-002 ALTERNATIVE TESTING REQUIREMENTS FOR SMALL DIAMETER REACTOR COOLANT SYSTEM PRESSURE BOUNDARY CONNECTIONS Pursuant to 10 CFR 50.55a(a)(3)(i), Virginia Electric and Power Company (Dominion) submits revised Relief Requests SPT-003 and SPT-002 for Surry Units 1 and 2, respectively.
These relief requests permit visual examination as an alternative to pressure testing of one inch and less diameter Class 1 Reactor Coolant System (RCS) pressure boundary vent, drain, sample, and instrumentation connections. These relief requests were previously approved by the NRC for Units 1 and 2 Fourth ISI Intervals by letters dated August 11, 2004 (TAC Nos. MB7762, MB7763, and MB9528) and September 9, 2004 (TAC Nos. MB7762, MB7763, and MB9528), respectively.
Since the approval of the original relief requests, Code Case N-798, "Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Vent, Drain, and Test Isolation Devices," was approved by the ASME Committee on December 20, 2010. This code case allows the use of IWB-5222(a) for defining the pressure retaining boundary as an acceptable alternative to the extended pressure test boundaries of IWB-5222(b).
The revision to Relief Requests SPT-003 and SPT-002 adds the Units 1 and 2 Reactor Vessel Head Vent lines. The requisite information and justification contained in the approved relief requests also apply to the Reactor Vessel Head Vent lines.
The revised Relief Requests SPT-003 and SPT-002 have been reviewed and approved by the station's Facility Safety Review Committee.
Dominion requests review and approval of the attached requests for the use of alternative testing requirements by June 30, 2014.
Serial No.13-639 Docket Nos. 50-280/50-281 Revised Relief Requests SPT-003 and SPT-002 Page 2 of 2 If you have any questions or require additional information, please contact Mr. Gary D.
Miller at (804) 273-2771.
Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Development Commitments made in this letter: None Attachments:
- 1. Revised Relief Request SPT-003 - Surry Unit 1
- 2. Revised Relief Request SPT-002 - Surry Unit 2 cc:
U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station Ms. K. R. Cotton-Gross, NRC Project Manager - Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852 Dr. V. Sreenivas, NRC Project Manager - North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852 Mr. R. A. Smith Authorized Nuclear Inspector Surry Power Station
Serial No.13-639 Docket Nos. 50-280/50-281 Attachment I Alternative Requirements to ASME Code Requirements for Small Diameter Reactor Coolant System Pressure Boundary Connections -
Revised Relief Request SPT-003 Virginia Electric and Power Company (Dominion)
Surry Power Station Unit I
Serial No.13-639 Docket Nos. 50-280/50-281 Page 1 of 4 RELIEF REQUEST SPT-003, Rev. I IDENTIFICATION OF COMPONENTS Approximately 20, small diameter (_<1 inch), Class 1, reactor coolant system (RCS) pressure boundary vent, drain, sample, and instrumentation connections.
IMPRACTICAL CODE REQUIREMENTS Section XI 1998 Edition with addenda up to and including the 2000 Addenda, Examination Category B-P, Items B15.50 and B15.70 require system leakage testing and associated VT-2 visual examination of all Class 1 pressure retaining piping and valves.
IWB-5222(b) requires that "The pressure retaining boundary during the system leakage test conducted at or near the end of each inservice inspection interval shall extend to all Class 1 pressure retaining components within the system boundary."
II1.
BASIS OF REQUEST FOR RELIEF These piping segments are equipped with either two valves or a valve and end cap that provide for double isolation of the reactor coolant system (RCS) pressure boundary. For each pipe segment, the inboard (i.e., closer to the primary loop piping) or first isolation valve is maintained closed during normal operation; thus, the piping outboard of the first isolation valve is not normally pressurized.
The proposed alternative provides an acceptable level of safety and quality based on the following:
- 1) ASME Section XI Code, 1998 Edition with addenda up to and including the 2000 Addenda, paragraph IWA-4540, provides the requirements for hydrostatic pressure testing of piping and components after repairs by welding to the pressure boundary.
IWA-4540(b)(6) excludes component connections, piping, and associated valves that are 1 inch nominal pipe size and smaller from the hydrostatic test. Visual examination of these <1 inch diameter RCS vent/drain/sampling connections once each 10-year interval is unwarranted considering that a repair weld on the same connections is exempted by the ASME Xl Code.
- 2) The non-isolable portion of the RCS vent and drain connections will be pressurized and visually examined as required. Only the isolable portion of these small diameter vent and drain connections will not be pressurized.
- 3) These piping connections are typically socket welds that received a surface examination after installation.
- 4) The piping and valves are nominally heavy wall. These piping components and associated piping are towards the free end of a cantilever configuration (stub end isolated by either a valve or a flange). There is no brace or support for this portion of the pipe. Consequently, this portion does not experience any thermal loading.
Serial No.13-639 Docket Nos. 50-280/50-281 Page 2 of 4
- 5) This portion of the line is isolated during normal operation and does not experience pressure loading unless there is a leak at the first isolation valve.
- 6) The valves do not have an extension operator, so the rotational accelerations at the valve do not produce significant stress.
- 7) The stresses towards the free end of the cantilever due to other types of loading are only a small fraction of the applicable Code allowable.
The Technical Specifications (TS) require RCS leakage monitoring during normal operation. Should any of the TS leakage limits be exceeded, then SPS 1 is required to identify the source of the leakage and restore the RCS boundary.
During the 1998 North Anna Unit 1 refueling outage, similar piping segments were pressurized by the connection of a test rig. The dose associated with this testing was 1.5 man-rem. It is expected that conditions at SPS Unit 1 would yield comparable exposure results if the testing were performed.
Since the original relief request SPT-003 approval by NRC SER letter dated August 11, 2004, Code Case N-798, "Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Vent, Drain, and Test Isolation Devices," was approved by the ASME Committee on December 20, 2010. This code case allows the use of IWB-5222(a) for defining the pressure retaining boundary as an acceptable alternative to the extended pressure test boundaries of IWB-5222(b).
IV.
ALTERNATE PROVISIONS As an alternative to the Section Xl requirement that once per interval a system leakage test be performed of the normally isolated portions of the subject Class 1 RCS pressure boundary vent, drain, sample, and instrumentation connections, the following is proposed:
- 1) The RCS vent, drain, instrumentation, and sample connections will be visually examined for leakage and any evidence of past leakage, with the isolation valves in the normally closed position each refueling outage during the ASME Section Xl Class 1 System Leakage Test (IWB-5220).
- 2) During operation the RCS will be monitored for leakage and radiation levels in accordance with the requirements of the applicable Technical Specifications.
- 3) These alternative provisions will only be applied to the inservice testing performed to meet the requirements of Category B-P.
The proposed alternative examination requirements will ensure that the overall level of plant quality and safety will not be compromised. Therefore, approval to use the stated alternative examination requirements is requested under the provisions of 10 CFR 50.55a(a)(3)(i).
Serial No.13-639 Docket Nos. 50-280/50-281 Page 3 of 4 Approval Provisions:
The following is the list provided to the NRC in Dominion Letter # 02-642A which details the exact pipe segments where this relief will apply:
Drawing/Coordinates Line Number Bounded By Function 1
11448-CBM-083B-3-3/E-7 3/4-RC-165-1502 Flange to #5 Vent 2
11448-CBM-083B-3-3/E-7 3/4-RC-172-1502 Flange to #6 Vent 3
11448-CBM-083B-3-3/E-7 3/4-RC-163-1502 Flange to #8 Vent 4
11448-CBM-086A-3-1/D-4 3/4-RC 1-RC-154 to flange Drain 5
11448-CBM-086A-3-1/F-5 3/4-RC-165-1502 1-RC-9 to #1 Vent 6
11 44S-CBM-086A-3-2/F-5 3/4-RC-172-1502 1 -RC-48 to #2 Vent 7
1144S-CBM-086A-3-2/D-4 3/4-RC 1-RC-84 to flange Drain 8
1144S-CBM-086A-3-3/F-6 3/4-RC-163-1502 1-RC-80 to #3 Vent 9
11448-CBM-086A-3-3/D-7 3/4-RC 1-RC-156 to flange Drain 10 1144S-CBM-OS6A-3-3/C-4 3/4-RC-161-1502 1 -RC-1 03 to flange Drain 11 11448-CBM-088C-3-1/E-7 3/4-CH 1-CH -366 to flange Drain 12 11448-CBM-088C-3-2/C-S 3/4-CH 1-CH-325 to flange Drain 13 1144S-CBM-088C-3-2/C-7 3/4-CH 1 -CH-335 to flange Drain 14 1144S-CBM-088C-3-2/C-6 3/4-CH 1-CH-351 to flange Drain 15 11448-CBM-089B-3-4/F-8 3/4-SI-401-ICN9 1-SI-421 to 1-SI-422 Test Connection 16 1144S-CBM-089B-3-4/E-8 3/4-SI-403-ICN9 1-SI-424 to 1-SI-425 Test Connection 17 11448-CBM-089B-3-4/D-S 3/4-SI-405-ICN9 1-SI-427 to 1-SI-428 Test Connection The following lines are being added in Rev. 1 of relief request SPT-003 for the remainder of the Unit 1 fourth inservice inspection interval:
Drawing/Coordinates Line Number Bounded By Function 1-RC-SOV-100A1 to 1
11 448-CBM-086A-4-3/A-5 1 -RC-233-1502 1 -RC-SOV-1000A2 Vent 1-RC-SOV-100B1 t 2
11 448-CBM-086A-4-3/A-5 1 -RC-234-1502 1-RC-SOV-100B1 to Vent
_____~~~~~~~~~~
I-RC-SOV-1 00B2
Serial No.13-639 Docket Nos. 50-280/50-281 Page 4 of 4 V.
DURATION OF PROPOSED ALTERNATIVE The proposed alternative is requested for the fourth inservice inspection interval which began October 14, 2003, is being extended one year as allowed by ASME Section XI, Inspection Intervals IWA-2430(d), and will end October 13, 2014.
VI.
PRECEDENTS The NRC approved relief requests similar to the original relief request SPT-002 for Edwin I.
Hatch Plant, Units 1 and 2 under TAC Nos. MA2118 and MA2119, respectively. Also, the NRC approved a similar relief request for North Anna Power Station, Unit 1, third inservice inspection interval, under TAC No. MA5750. Similar requests were approved for North Anna Power Station Unit 2, third inservice inspection interval, under TAC NO. MB2280; and Surry Power Station Units 1 and 2, third inservice inspection intervals, under TAC Nos. MA4979 and MA4980, respectively.
Relief requests similar to relief request SPT-003, Rev. 1, have been approved by the NRC for the following:
South Texas Project, Units 1 and 2. Relief Request NumberRR-ENG-3-06, approved by NRC letter dated August 28, 2012; Accession Number ML12235A347 Catawba Nuclear Station, Units 1 and 2. Relief Request Number 11-CN-002, approved by NRC letter dated August 14, 2012: Accession Number ML12223A197 Davis-Besse Nuclear Power Station, Unit 1. Relief Request Number RR-A35, approved by NRC letter dated April 29, 2012; Accession Number ML120750481 Millstone Power Station, Unit 2. Relief Request Number RR-04-04, approved by NRC letter dated July 27, 2011; Accession Number ML111881029 McGuire Nuclear Station, Units 1 and 2. Relief Request Number 09-MN-005, approved by NRC letter dated June 14, 2010; Accession Number ML101580422
Serial No.13-639 Docket Nos. 50-280/50-281 Alternative Requirements to ASME Code Requirements for Small Diameter Reactor Coolant System Pressure Boundary Connections -
Revised Relief Request SPT-002 Virginia Electric and Power Company (Dominion)
Surry Power Station Unit 2
Serial No.13-639 Docket Nos. 50-280/50-281 Page 1 of 4 RELIEF REQUEST SPT-002, Rev. I I. IDENTIFICATION OF COMPONENTS Approximately 20, small diameter L<1 inch), Class 1, reactor coolant system (RCS) pressure boundary vent, drain, sample, and instrumentation connections.
II. IMPRACTICAL CODE REQUIREMENTS Section Xl 1998 Edition with addenda up to and including the 2000 Addenda, Examination Category B-P, Items B15.50 and B15.70 require system leakage testing and associated VT-2 visual examination of all Class 1 pressure retaining piping and valves.
IWB-5222(b) requires that "The pressure retaining boundary during the system leakage test conducted at or near the end of each inservice inspection interval shall extend to all Class 1 pressure retaining components within the system boundary."
Ill. BASIS OF REQUEST FOR RELIEF These piping segments are equipped with either two valves or a valve and end cap that provide for double isolation of the RCS pressure boundary. For each pipe segment, the inboard (i.e. closer to the primary loop piping) or first isolation valve is maintained closed during normal operation; thus, the piping outboard of the first isolation valve is not normally pressurized.
The proposed alternative provides an acceptable level of safety and quality based on the following:
- 1) ASME Section XI Code, 1998 Edition with addenda up to and including the 2000 Addenda, paragraph IWA-4540, provides the requirements for hydrostatic pressure testing of piping and components after repairs by welding to the pressure boundary.
IWA-4540(b)(6) excludes component connections, piping, and associated valves that are 1 inch nominal pipe size and smaller from the hydrostatic test. Visual examination of these < 1-inch diameter RCS vent/drain/sampling connections once each 10-year interval is unwarranted considering that a repair weld on the same connections is exempted by the ASME Xl Code.
- 2) The non-isolable portion of the RCS vent and drain connections will be pressurized and visually examined as required. Only the isolable portion of these small diameter vent and drain connections will not be pressurized.
- 3) These piping connections are typically socket welds that received a surface examination after installation.
- 4) The piping and valves are nominally heavy wall. These piping components and associated piping are near the free end of a cantilever configuration (stub end isolated by either a valve or a flange). There is no brace or support for this portion of the pipe.
Consequently, this portion does not experience any thermal loading.
Serial No.13-639 Docket Nos. 50-280/50-281 Page 2 of 4
- 5) This portion of the line is isolated during normal operation and does not experience pressure loading unless there is a leak at the first isolation valve.
- 6) The valves do not have an extension operator, so the rotational accelerations at the valve do not produce significant stress.
- 7) The stresses toward the free end of the cantilever due to other types of loading are only a small fraction of the applicable Code allowable.
The Technical Specifications (TS) require RCS leakage monitoring during normal operation. Should any of the TS leakage limits be exceeded, then SPS 2 is required to identify the source of the leakage and restore the RCS boundary.
During the 1998 North Anna Unit 1 refueling outage, similar piping segments were pressurized by the connection of a test rig. The dose associated with this testing was 1.5 man-rem. It is expected that conditions at SPS Unit 2 would yield comparable exposure results if the testing were performed.
Since the original relief request SPT-002 approval by NRC SER letter dated September 9, 2004, Code Case N-798, "Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Vent, Drain, and Test Isolation Devices," was approved by the ASME Committee on December 20, 2010. This code case allows the use of IWB-5222(a) for defining the pressure retaining boundary as an acceptable alternative to the extended pressure test boundaries of IWB-5222(b).
IV. ALTERNATE PROVISIONS As an alternative to the Section XI requirement that once per interval a system leakage test be performed on the normally isolated portions of the subject Class 1 RCS pressure boundary vent, drain, sample, and instrumentation connections, the following is proposed:
- 1) The RCS vent, drain, instrumentation, and sample connections will be visually examined for leakage and any evidence of past leakage, with the isolation valves in the normally closed position each refueling outage during the ASME Section X1 Class 1 System Leakage Test (IWB-5220).
- 2) During operation the RCS will be monitored for leakage and radiation levels in accordance with the requirements of the applicable Technical Specifications.
- 3) These alternative provisions will only be applied to the inservice testing performed to meet the requirements of Category B-P.
The proposed alternative examination requirements will ensure that the overall level of plant quality and safety will not be compromised. Therefore, approval to use the stated alternative examination requirements is requested under the provisions of 10 CFR 50.55a(a)(3)(i).
Serial No.13-639 Docket Nos. 50-280/50-281 Page 3 of 4 Approval Provisions:
The following is the list provided to the NRC in Dominion Letter #03-428A which details the exact pipe segments where this relief will apply:
1st Valve Normally Seg Mark Number/Description Closed Function 1
2-RC-154 on 3/4" line Yes Vent 2
2-RC-48 on 3/4" line to blank flange Yes High Point Vent 3
2-RC-80 on 3/4" line to blank flange Yes High Point Vent 4
2-RC-156 on 3/4" line Yes Stand Pipe Vent 5
3/4" line between 2-RC-104 and 2-RC-173 Yes Stand Pipe 6
1" line between 2-RC-36, 2-RC-1 86 and 2-RC-FNG-Yes Reactor Vessel 545A Vent 7
Yes Vessel Level 3/4" line between 2-RC-105, 2-RC-106 and 2-RC-157 Stn Pipe Stand Pipe 8
3/4" line downstream of 2-RC-106 Yes Test Connection 9
3/4" line downstream of 2-RC-103 Yes Test Connection 10 3/4" line between 2-RC-1 70 and 2-RC-1 38 Yes Stand Pipe Vent to Pressurizer 11 3/4" line between 2-SI-411 and 2-SI-412 Yes Test Connection 12 3/4" line between 2-SI-414 and 2-SI-415 Yes Test Connection 13 3/4" line between 2-SI-417 and 2-SI-418 Yes Test Connection The following lines are being added in Rev. 1 of relief request SPT-002 for the remainder of the Unit 2 fourth inservice inspection interval:
1st Valve Normally Seg Mark Number/Description Closed Function 1
1" line between 2-RC-SOV-200A-1 and 2-RC-SOV-Yes Vent 200A-2 2
1" line between 2-RC-SOV-200B-1 and 2-RC-SOV-Yes Vent 2___
200B-2 YesVent V.
DURATION OF PROPOSED ALTERNATIVE The proposed alternative is requested for the fourth inservice inspection interval which began May 10, 2004, is being extended one year as allowed by ASME Section Xl, Inspection Intervals IWA-2430(d), and will end May 9, 2015.
Serial No.13-639 Docket Nos. 50-280/50-281 Page 4 of 4 VI.
PRECEDENTS The NRC approved relief requests similar to the original relief request SPT-002 for Edwin I.
Hatch Plant, Units 1 and 2 under TAC Nos. MA2118 and MA2119, respectively. Also, the NRC approved a similar relief request for North Anna Power Station, Unit 1, third inservice inspection interval, under TAC No. MA5750. Similar requests were approved for North Anna Power Station Unit 2, third inservice inspection interval, under TAC NO. MB2280; and Surry Power Station Units 1 and 2, third inservice inspection intervals, under TAC Nos. MA4979 and MA4980, respectively.
Relief requests similar to relief request SPT-002, Rev. 1, have been approved by the NRC for the following:
South Texas Project, Units 1 and 2. Relief Request NumberRR-ENG-3-06, approved by NRC letter dated August 28, 2012; Accession Number ML12235A347 Catawba Nuclear Station, Units 1 and 2. Relief Request Number 11-CN-002, approved by NRC letter dated August 14, 2012: Accession Number ML12223A197 Davis-Besse Nuclear Power Station, Unit 1. Relief Request Number RR-A35, approved by NRC letter dated April 29, 2012; Accession Number ML120750481 Millstone Power Station, Unit 2. Relief Request Number RR-04-04, approved by NRC letter dated July 27, 2011; Accession Number ML111881029 McGuire Nuclear Station, Units 1 and 2. Relief Request Number 09-MN-005, approved by NRC letter dated June 14, 2010; Accession Number ML101580422