ML18052A149

Requests Relief from Main Steam & Feedwater Sys Pressure Test & IWA 5214 Which Requires Hydrostatic Test Following Repair or Replacement.Refueling Outage Preparation & Completion Make Test Impractical to Complete.Fee Paid

ML18052A149
Person / Time
Site:	Palisades
Issue date:	11/01/1985
From:	Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8511050178
Download: ML18052A149 (6)

Text

consumers Power company General Offices: 1945 West Parnell Road, *Jackson, Ml 49201 *.{517) 7S8-0550 November 1, 1985

Director, Nuclear Reac*tor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

INSERVICE INSPECTION - HYDROSTATIC TESTS OF CLASS 2 SYSTEMS INCLUDING REQUEST FOR RELIEF*

Section XI of the ASME B&PV Code, as referenced in the Palisades Technical Specifications 4.3.b, requires periodic system pressure tests for ASME Class 1, 2, and 3 systems/components. The current edition of the ASME B&PV Code IWC-2500, Category C-H, specifically requires a hydrostatic test at or near the end of each ten-year inspection interval for Class 2 systems.

Furthermore, IWA 5214 requires the hydrostatic test following repairs and replacements.

Our previous interpretation of the Code was that the ten-year hydrostatic test interval requirements began on the date the requirement came into existence.

The initial interval date for Palisades was therefore assumed to start approximately May of 1977, which was concurrent with our updating to the 1974S75 Edition and addenda of Section XI. This interpretation would require the subject testing to be completed by 1987. However subsequent review has established that the code actually requires the ten-year inspection interval to begin the date of commercial operation and end ten years later plus allowable extensions. The first inservice inspection interval ended for Palisades in November 1983 at which time all required hydrostatic tests should have been completed.

Due to the previous incorrect interpretation of the "Code" intent, the required ten-year hydrostatic test required by Section XI, ASME B&PV, was not performed on the main steam and feedwater systems at Palisades.

A comprehensive review was conducted of the system pressure test program which identified no other areas of noncompliance. Based on past inspection history,

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which includes a;; inservice leak test in 1980 and again in 198v}3, ~ .

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Director, Nuclear Reactor Regulation Palisades Plant Inservice Insp~ction November 1, 1985

• 2 nondestructive examination required by plant Tech Specs, and routine inservice inspection activities conducted throughout the first interval, continued operation of the main steam and feedwater systems does not constitute a compromise in safety. Based on the examinations and tests performed to date, plus the fact that *systems and equipment are in place to detect system degra-dation such as leakage, it is felt that a reasonable level of quality and safety is provided which is equal to or greater than that of a ten-year hydrostatic test. The Plant Review Committee has concurred with the conclu-sions of the review.

The request also incorporates a request for relief from IWA 5214 which requires a hydrostatic test following repair or replacement. The requirement will apply if any repairs are performed during our refueling outage to portions of the main steam and feedwater systems which are unisolable from the secondary side of the steam generator up to and including the containment isolation valves. However it should be noted that no such repairs are currently planned.

Circumstances created by the refueling outage preparation and completion, and the difficulty of the required test, make it impractical to complete the test this refueling outage. It is with these considerations in mind that the attached request for relief is submitted. In the relief request, Consumers Power Company proposes to conduct system leak tests during the upcoming refueling outage (to begin 11/30/85) in lieu of the ten-year hydrostatic test.

A hydrostatic test will be scheduled to be conducted during the next refueling outage (presently forecasted to begin in August 1987), or adequate technical justification for relief and alternate examination will be submitted prior to that outage, in sufficient time for NRC review.

A check in the amount of $150.00 is enclosed pursuant to 10CFR170.21.

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l/.Tames L Kuemin Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC1085-0018-NL02

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ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 MAIN STEAM AND FEEDWATER SYSTEM PRESSURE TEST REQUEST FOR RELIEF November 1, 1985 3 Pages IC1085-0018-NL02

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Main Steam and Feedwater System Pressure Test Request for Relief Component Identification

a. Main steam and feedwater systems (includes secondary side of steam generators)

b. The main steam and feedwater systems are classified as ASME Class 2 in accordance with Reg Guide 1.26

c.Section XI, Item No. - C7.ll, C7.21, C7.41 Category - C-H

• Requirement Section XI of the ASME B&PV Code, 77S78 addenda, requires periodic system pressure tests for ASME Class 1, 2 and 3 systems and components.

Specifically, IWC-2500, Category C-H, requires a hydrostatic test of Class 2 systems in accordance with IWA-5000, IWC-5000 and IWC-5222. This test is to be performed at or near the end of each inspection interval or during the same period of each interval. Per IWC-5222a, the required test pressure would be 1.25 times the system Psv, which for Palisades would be a minimum of 1231

• psig. Consistent with this requirement, IWA 5214 requires a similar hydrostatic test to be performed following repairs or replacement.

Basis for Relief It has been discovered that, due to an apparent difference in code interpreta-tion, no hydrostatic test was performed on the main steam and feedwater systems during the first inspection interval which ended in 1983. A system leak test was performed at a pressure conservative to tnat which would be required by Section XI. The required test pressure for a leak test in accordance with the "Code" is nominal operating pressure, or approximately 700 psig for Palisades. The leak test that was performed at Palisades was done with the main steam isolation valves closed and the plant in hot standby, which equates to a pressure of approximately 860 psig.

Since the code noncompliance was only recently discovered, and in view of the ensuing refueling outage scheduled for November 30, 1985 and related prepara-tions, it is considered highly impractical to perform the required test this outage. In addition, the following items are submitted regarding the imprac-ticality of performing the test this outage:

1. Currently, no procedure exists to perform the test.* This would have to be drafted, reviewed and approved for use.

2. Main steam system hangers must be pinned and blocked to allow the piping system to be water s.olid*. As part of this effort, .hanger settings must IC1085-0701A-TC01-NL04

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2 be recorded to allow return to normal after testing. Procedure must be drafted, reviewed and approved to accomplish this work.

3. Scaffolding would have to be erected to pin hangers and record settings.

Preplanning for materials or budget must be developed for. this activity.

4. Overpressure protection must be properly addressed. Relief valves must be calibrated and installed.

5. Proper valve lineups and routing of discharge and drain piping must be addressed (see #1).

6. Test would require approximately 50,000 gallons of condensate quality water.

7. Main steam relief valves must be removed or gagged. CPCo currently owns only one gag and a total of 24 are required. Removing and reinstallation of valves would require approximately 100 man-hours per valve.

8. Repair work on main steam isolation valves (MSIV) will not be complete until mid January. Hydro cannot take place prior to MSIV completion.

9. Integrated leak rate testing (ILRT) is scheduled at the end of the outage. No work will be allowed in containment during that time. This wilJ be impacted by the hydro i f performed.

10. Maintenance work may have unisolable portions of system open. Detailed review of maintenance work is required.

11. System instrumentation must be evaluated regarding capability to withstand hydro pres.sure and isolated or removed as applicable.

12. Based on above considerations, sufficient time does not exist to evaluate all facets of performing the required test.

13. Budget does not exist to support required action items and manpower requirements to perform the test this outage.

Alternate Examination Based on the above information, Consumers Power Company will perform a system leak test during the 1985-86 refueling outage at the increased pressure as previously performed (plant in hot standby with systems pressurized to con-tainment isolation valves). The alternate examination coupled with previous augmented nondestructive examinations (100% volumetric examination of all welds in main steam and feedwater penetration rooms each 3 1/3 year period and weekly visual inspection) plus routine inservice inspection examinations, con-ducted over the first inspection interval, provide a reasonable level of quality and safety equal to or greater than that of the ten year hydrostatic test.

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.* 3 Implementation The alternate*examination will be performed during the 1985-86 refueling outage at Palisades in lieu of the ten year hydrostatic test.

In addition, the hydrostatic test required by ~SME Section XI will be performed during the next refueling outage or adequate technical justification for relief and alternate examination will be submitted prior to that outage for NRC consideration. This request for relief also includes the hydrostatic test required following repair or replacement this outage to portions of the main steam and feedwater systems which are unisolable from the secondary side at the steam generator up to and including the containment .isolation valves.

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