HNP-96-106, Requests Approval for Plant to Use Alternative to ASME Boiler & Pressure Vessel Code Requirements for Performing Certain Pressure Testing on Containment Penetration Piping
| ML18012A355 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/09/1996 |
| From: | Robinson W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| HNP-96-106, NUDOCS 9609170583 | |
| Download: ML18012A355 (7) | |
Text
CATEGORY 1 REGUDA'IY INFORMATION DISTRIBUTIOOSYSTEM (RIDE) 4 ACCESSION NBR:9609170583 DOC.DATE: 96/09/09 NOTARIZED; NO FACIAL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AU+H.NME AUTHOR AFFILTATION ROBINSON,N.R.
Carolina Power 8 Light Co.
?ECIP.NAME RECIPIENT AFFIIIATION Document Control Branch (Document Control Desk)
DOCKET I 05000400
SUBJECT:
Requests approval for plant to use alternative to ASME Boiler 6 Pressure Vessel Code requirements for perfor'ming certain pressure testing on containment penetration pip1ng.
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TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code GL-89-04 NOTES:Application for permit renewal filed.
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Carolina Power & Light Company PO Box 165 New Hill NC 27562 William R. Robinson Vice President Harris Nuclear Plant SEP 9 1996 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SERIAL: HNP-96-106 SHEARON HARRIS NUCLEARPOWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 ASME BOILER AND PRESSURE VESSEL CODE, SECTION XI REQUEST FOR APPROVALTO USE CODE CASE N-522
Dear Sir or Madam:
In accordance with 10 CFR 50.55a(a)(3), Carolina Power &Light (CP&L) Company requests approval for the Harris Nuclear Plant (HNP) to use an alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requirements for performing certain pressure testing on containment penetration piping. The requested alternative, ASME Code Case N-522, "Pressure Testing of Containment Penetration Piping,Section XI, Division 1,"
was approved by the ASME on December 9, 1993. This code case has not been incorporated into Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability ASME Section XI Division 1."
The bases for the request are provided in the Enclosure.
HNP is currently in the third period of its first ten year ISI interval and is to complete remaining inspections in the next refueling outage, currently scheduled to begin in March 1997. NRC approval is requested by December 31, 1996 to support the planning required for the outage.
Questions regarding this matter may be referred to Mr. T. D. Walt at (919) 362-2711.
'P609i70583 960909 PDR ADQCK 05000400 6
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LSR/lsr,"'incerely, c:
Mr. J. B. Brady, NRC Resident Inspector Mr. S. D. Ebneter, NRC Regional Administrator Mr. N. B. Le, NRC Project Manager State Road1134 NewHill NC Tel 919362-2502 Fax 919362-2095
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Enclosure to Serial: HNP-96-106 RE UEST FOR RELIEF FROM INSERVICE INSPECTION RE UIREMENTS ASME CODE CASE N-522 Code Re uirement for Which Relief is Re uested System pressure tests per ASME Code,Section XI, Table IWC-2500-1, Category C-H.
A licable Construction Code and Class for Harris Nuclear Plant ASME Section III, 1974 through Winter 1976 Addendum ASME Section XI, 1983 through Summer 1983 Addendum Reference Code Case Code Case N-522, "Pressure Testing ofContainment Penetration Piping,Section XI, Division 1."
Com onents for Which Exem tion is Re uested This request is for ISI Class 2 system pressure tests to be performed during each remaining ISI inspection interval for piping that penetrates the containment, when the piping and isolation valves that are part ofthe containment system are Class 2, but the balance of the piping system is outside the scope of Section XI. At Harris Nuclear Plant these penetrations specifically include the following: Service Water (M-91, M-92);
Sampling (M-88, M-33); Reactor Makeup Water (M-40); Demineralized Water (M-90);
Leak Rate Testing (M-62, M-34, M-96); Containment Hydrogen Purge Makeup (M-61);
Safety Injection (M-76A, M76B, M-77A); Spent Fuel Pool Cooling and Cleanup (M-44, M-65, M-45); Miscellaneous Drains (M-74); Fire Protection (M-79, M-105); Instrument Air(M-80); Service Air(M-41); Waste Gas (M-77C); Penetration Pressurization (RHR Valve Chambers, Containment Spray Valve Chambers, Emergency AirLock, Breech Type Personnel AirLock, and Equipment Hatch).
Basis for Re uestin Relief The piping segment from a non-code class system that penetrates containment is designed and examined as Class 2 piping in order to protect the integrity ofcontainment. The hydrostatic pressure test required in Table IWC-2500-1, Category C-H, provides periodic verification ofthe leak-tight integrity of Class 2 piping systems or segments at least once during every 10-year ISI interval.
The 10 CFR 50, Appendix J pressure testing provides periodic verification of the leak-tight integrity of the reactor containment, and systems and components that penetrate containment.
The Appendix J test frequency provides assurance ofcontainment pressure boundary integrity by monitoring the deterioration ofseals, valves, and piping. Appendix J requires Type B and C tests to be performed during each refueling outage, but in no case
Enclosure to Serial: HNP-96-106 at intervals greater than 2 years.
The purposes of the periodic surveillances required by Appendix J are to assure that proper maintenance and repairs are made during the service life ofthe containment, and systems and components penetrating containment.
ASME Code Case N-522 was approved December 9, 1993 by the ASME Boiler and Pressure Vessel Code Committee and the Board ofNuclear Codes and Standards as an acceptable alternative to the requirements ofthe ASME Code,Section XI. Consistent with ASME Code Case N-522, this request is based on performing testing in accordance with 10 CFR 50, Appendix J, Option A in lieu of the interval Class 2 system pressure tests for piping that penetrates a containment vessel, when the piping and isolation valves that are part ofthe containment system are Class 2, but the balance ofthe piping system is outside the scope ofSection XI. A review ofthe ASME pressure tests performed at Harris Nuclear Plant for the first two inspection periods has determined that no through wall leaks have been identified during these tests.
The burdens imposed by pressure testing of the above referenced Class 2 penetrations are as follows:
The performance of the pressure testing required by the ASME Code,Section XI, would require an additional VT-2 examination to be performed during the 10 CFR 50, Appendix J testing or system operation at nominal pressure.
The extra examination willincrease dose by an estimated 0.1 person-rem and willrequire an estimated 10 additional person-weeks ofoutage resources during each inspection period (every 3 and 1/3 years).
6.
In lieu ofperforming interval pressure testing, Harris Nuclear Plant willperform 10 CFR 50, Appendix J testing in accordance with ASME Code Case N-522.
7.
Conclusion The ASME Code, Section XIpressure testing does not provide an increase in the level of quality or safety because integrity willbe demonstrated by the 10 CFR 50, Appendix J testing in lieu ofthe Section XItesting.
The Harris Nuclear Plant is currently in the third period ofits first ten-year ISI interval and is to complete remaining inspections during the next refueling outage, currently scheduled to begin in March 1997. NRC approval is requested by December 31, 1996 to support the planning required for a 10-year ISI outage.
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