ML17312A734
| ML17312A734 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/22/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17312A732 | List: |
| References | |
| NUDOCS 9605010260 | |
| Download: ML17312A734 (12) | |
Text
<PS RE00
+4 0
P Op 0O IVl O
+O gO
++*++
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 GU T
S C
OG VSO SS ON PU UCL AR GENE NG S
0 UN S
AN 3
CK T NOS. STN-50-528 ST 529 AND STN-50-530 1.0 IHTT0.
IIN The technical specifications for Palo Verde Nuclear Generating Station, Units 1, 2, and 3, state that the inservice inspection of the American Society of Hechanical Engineers (ASHE) Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASHE Boiler and Pressure Vessel Code and applicable Addenda as required by the Code of Federal Regulations, 10 CFR 50.55a(g),
except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).
Section 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4),
ASHE Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASHE Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design,
- geometry, and materials of construction of the components.
The regulations require that inservice examination of components and system pressure tests conducted during the first ten-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASHE Code as incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.
For Palo Verde, Units 1, 2, and 3, the applicable edition of Section XI of the ASHE Code for the first 10-year inservice inspection (ISI) interval is the 1980 Edition through the Minter 1981 Addenda with the exception of Code Class 2 examination for components in the residual heat removal, safety injection, and containment heat removal
- systems, where ASHE Section XI, 1974 Edition through the Summer 1975 addenda is applicable as required by 10 CFR 50.55a.
96050i02b0 960422 PDR ADGCK 05000528 P
Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASHE Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request for relief from the ASIDE Code requirement.
After evaluation of the licensee determination, pursuant to 10 CFR 50.55a(g)(6)(i),
the Comaission may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life, property, or the comnon defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed.
In a letter dated Harch 12, 1993, Arizona Public Service Company submitted Revision 1 to the First Ten-Year Interval Inservice Inspection Program Plan.
In Revision 1, the licensee withdrew requests for relief 2 and 5 for Units 1, 2,
and 3.
In addition, the licensee submitted requests for relief 6, 7, and 8.
By letter dated December 20, 1995, the licensee withdrew request for relief 8 and by letter dated Harch 5, 1996, the licensee withdrew request for relief 6.
- 2. 0
+~)ATDA The staff, with technical assistance from its contractor, the Idaho National Engineering Laboratory (INEL), has evaluated the information provided by the licensee in support of Revision 1 to the First Ten-Year Interval Inservice Inspection Program and request for relief 7 and proposed alternative examination for Palo Verde Units 1, 2, and 3.
Based on the information submitted, the staff adopts the contractor's conclusions and recommendations presented in the attached Technical Letter Report.
The staff concludes that Revision 1 to the First Ten-Year Interval Inservice Inspection Program, for Palo Verde Units 1, 2, and 3 is acceptable, because no deviations from regulatory requirements or commitments were identified in Revision 1.
3.0 CONC US 0 Based on the infovaation provided by the licensee, the staff has determined that, with respect to request for relief 7, the proposed alternative, when performed at the peak calculated containment pressure using test procedures that will detect a through-wall leakage in the pipe segments being tested, will provide an acceptable level of quality and safety.
Therefore, the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
Attachment:
Technical Letter Report Principal Contributor:
G. Georgiev Date:
April 22, f996
t
Attachment T CHNICA R
P T
ON THE FIRST 10-YEAR INSERVIC INSPECTION INTERVAL REVISION 1
A 0 V R
NUC EAR GEN RAT NG TAT ON UN TS 1
AND 3 RIZONA PUBLI S RVICE COHPAN DOCKET NOS.
50-528 50-529 AND 50-530
- 1. 0 INTRODUCTION By letter dated Harch 12, 1993, Arizona Public Service Company submitted Revision 1 to the First IO-Year Inservice inspection Program Plan for the Palo Verde Nuclear Generating Station, Units I, 2, and 3.
In a letter dated December 20, 1995, the licensee provided additional information to the Nuclear Regulatory Commission (NRC).
The first 10-year inservice inspection (ISI) interval will end on July 17, 1998, for Unit 1; Harch 17, 1997, for Unit 2;
and January 10, 1998, for Unit 3.
The Idaho National Engineering Laboratory (INEL) staff has evaluated Revision 1 to the program plan in the following section.
2.0
~VALUAT ON The Code of record for Palo Verde Nuclear Generating Station, Units 1, 2, and 3, first 10-year interval, is the American Society of Hechanical Engineers (ASHE) Boiler and Pressure Vessel
- Code,Section XI, 1980 Edition through the Minter 1981 Addenda with the following exception.
As required by 10 CFR 50.55a, the extent of Class 2 examinations for components in the Residual Heat Removal, Emergency Core Cooling, and Containment Heat Removal
- systems, was determined by ASHE Code,Section XI, 1974 Edition with addenda through the Summer 1975 addenda.
The INEL staff reviewed Revision 1 to the Inservice Inspection Program.
The revision includes: I) non-technical editorial changes,
- 2) additions or modifications to existing commitments that have already received NRC approval, and 3) three new requests for relief.
Based on this review, no deviations from regulatory requirements or commitments were identified.
Evaluations of additions and modifications to the ISI program plan are provided below.
A.
To establish a common start date of Harch 18, 1987 for the 10-year ISI interval, the licensee used the average 100X commercial power license date for the three units.
It is noted however, that the Code of record, is based on an average 5X power operation date and that establishes a start date of September 1985.
In addition, it is noted that the current end of interval dates for the three units are different due to differences in the duration of plant outages.
J 'I
Based on this evaluation, the INEL staff believes that the licensee's common interval start date is acceptable.
B.
Piping isometric zone drawings have been added to the program; these drawings identify the examination areas specific to segments of systems.
It has been determined that the subject drawings support the licensee in the programmatic implementation of the inservice examination program.
C.
In Revision 1, the licensee withdrew Requests for Relief 2 and 5 for Units 1, 2, and 3.
In addition, the licensee submitted Requests for Relief 6, 7, and 8.
By letter dated December 20, 1995, the licensee withdrew Request for Relief 8 and by letter dated March 5, 1996, the licensee withdrew Request for Relief 6.
Provided below is the evaluation for Request for Relief 7.
e uest for Relief Units 1
2 and 3
Table IWC-2500-1 Examination Cate or C-H tems C7. 10 C7.30 C7.50 and C7.70 ressure-Retainin Com onents Code Re uirement:
Section XI, Table IWC-2500-1, Examination Category C-H, Items C7. 10, C7.30, C7.50, and C7.70 require a VT-2 visual examination during System Functional and System Inservice pressure tests.
Licensee's Code Relief Re uest:
Relief is requested from performing the Code-required VT-2 visual examination during System Functional and System Inservice pressure tests for the portions of the subject piping penetrating containment, classified as Code Class 2.
The attaching segments of line inside and outside of containment are nonclass.
CH-275 CH-283 DW-055 FP-096 GA-002 GA-009 GR-001 IA-069 IA-080 NC-135 NC-137 PC-072 PC-073 RD-259 WC-039 WC-042 1-1/2" 3N 2 II 6N 1 II IN 1"
2N 3N 10" 10" g>>
3N 10" 10" 13-M-CHS-003 13-M-CHS-003 13-M-DWS-002 13-M-FPS-006 13-M-GAS-001 13-M-GAS-001 13-M-GRS-001 13-M-IAS-003 13-M-IAS-002 13-M-NCS-003 13-M-NCS-003 13-M-PCS-001 13-M-PCS-001 13-M-RDS-001 13-M-WCS-001 13-M-WCS-001
I
icensee's Basis for Re uestin Relief (as stated):
"This is applicable only to portions of piping systems that are classified ASHE due to penetration of containment building liner plate.
For the applicable class 2 systems the piping upstream and downstream of containment isolation is classified non-ASHE."
icensee's ro osed Alternative xamination (as stated):
"The applicable containment piping penetrations are routinely subjected to 10CFR50, Appendix J testing.
This testing is more conservative than the VT-2 examination required by code.
Local Leak Rate Testing is significantly more sensitive than a visual examination for leakage.
Reference Code Case N-522 for the ASHE Code interpretation."
~valuation:
The Code requires that a VT-2 visual examination be performed during System Functional and System Inservice pressure tests.
As an alter native, the licensee proposes to implement the requirements of 10 CFR 50, Appendix J, as applicable for the subject piping.
In accordance with alternatives to Code requirements contained in Code Case N-522, Pressure Testing of Containment Penetration
- PiPing, 10 CFR 50, Appendix J, may be used as an alternative to rules in Table IWC-2500-1, Category C-H, for pressure testing piping that penetrates a containment vessel, when the piping and isolation valves that are part of the containment system are Class 2, but the balance of the piping system is outside the scope of Section XI.
The containment isolation valves and connecting pipe segment must withstand the peak calculated containment internal pressure related to the maximum design containment pressure during Appendix J tests..
Appendix J pressure tests verify the leak-tight integrity of the primary reactor containment and of systems and components that penetrate containment by local leak rate and integrated leak rate tests.
In addition, Appendix J test frequencies provide assurance that the containment pressure boundary is being maintained at an acceptable level while monitoring for deterioration of seals,
- valves, and piping.
The Class 2 containment isolation valves (CIVs) and connecting pipe segment must withstand the peak calculated containment internal pressure related to the maximum design containment pressure.
The containment penetration piping is classified as Class 2 because of its function as part of the containment pressure
- boundary, and because containment integrity is the only safety-related function performed by this penetration piping.
Therefore, it is logical to test the penetration piping portion of the associated system to the Apendix J criteria.
The INEL finds that the pressure retaining
integrity of the CIVs and connecting piping and their associated safety functions may be verified with an Appendix J, Type C test if conducted at the peak calculated containment pressure.
The seal between the connecting pipe segment and containment may be verified using an Appendix J, Type B test.
Therefore, when the connecting pipe segment is subjected to either a Type B or C test, its safety function is verified and Code Case N-522 may be used.
For Class 2
pipe segment between the CIVs that are not subjected to either a
Type B or C test, the safety function is not'verified and Code Case N-522 may not be used.
Section XI, IWC-5210(b) requires that where air or gas is used as a
testing medium, the test procedures shall include methods for detection and location of through-wall leakage in components of the system tested.
Because an Appendix J, Type C test most likely uses air as a testing medium, the licensee's test procedure should meet the above requirement for the CIVs and pipe segments between the CIVs.
The INEL staff believes that an acceptable level of quality and safety will be provided by Appendix J tests, provided that the licensee performs the leak test at the peak calculated containment design pressure and that a test procedure is implemented that provides for detection and location of through-wall leakages in the pipe segments that are being tested.
Therefore, it is recommended that the licensee's proposed alternative pressure test be authorized pursuant to 10 CFR 50.55a(a)(3)(i),
provided that the licensee performs the leak test at the peak calculated containment pressure and uses a test procedure that provides for detection and location of through-wall leakages in the pipe segments being tested.
- 3. 0 CONCLUSION The INEL staff has reviewed Revision 1 to the First IO-Year Inservice InsPection Program Plan for the Palo Verde Nuclear Generating Station, Units I, 2, and 3.
Based on this review, no deviations from regulatory requirements or commitments were identified.
For Request for Relief 7, it is recommended that the proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i),
with the condition stated in the evaluation.
e
~~
/
4