ML18053A483
| ML18053A483 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/10/1988 |
| From: | Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8808150419 | |
| Download: ML18053A483 (12) | |
Text
consumers Power POW ERi Nii lfllCHlliAN'S PROliRESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 August 10, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
INSTRUMENTED INSPECTION TECHNIQUE (IIT)
The purpose of this letter is to notify the Nuclear Regulatory Commission of our intention to use an alternative inspection technique, at the Palisades Plant, to satisfy the Inservice Pressure Testing requirements of ASME Code,Section XI IWA, IWB, IWC, and IWD, as permitted by 10CFR50.55a(a)(3).
The details of this alternative Instrumented Inspection Technique (IIT), are the subject of RAFA International, Inc. Topical Report RAFA 135 (P)(A).
This topical report was approved by NRC for licensing reference on November 7, 1985.
The Palisades Plant systems identified below have been evaluated by RAFA International, Inc. in accordance with Section IV of the topical report and this evaluation is available at the Palisades site.
Based on these evaluations, it has been determined that IIT can be implemented on the appropriate portions of the following systems:
- 1.
Main Steam System (Including Steam Generators)
- 2.
Auxiliary Feedwater System (Water and Steam)
- 3.
Service Water System It is Consumers Power Company's intention to use IIT for post repair and replacement testing in lieu of hydrostatic testing (see Reference 5).
A ten minute holding time in lieu of a two hour hold time prior to performing the visual inspection (VT-2) will be implemented when using IIT (See Reference 1).
It is also our intention to file for an amendment to the plant Technical Specifications Table 4.2.2 in early 1989.
The change will affect the Critical Headers Service Water System testing method and frequency.
Discussion and methodology on each of the above topics are in Attachment A to this letter.
Since IIT has been accepted for licensing (reference RAFA Topical Report RAFA 135 (P-A)), Consumers Power Company intends to implement OC0888-;.0091-NL02
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Nuclear Regulatory Commission Palisades Nuclear Plant Instrumented Inspection Technique Draft this technique on portions of the above mentioned systems during the current outage at the Palisades Nuclear Plant.
It should be noted that Consumers Power Company recognizes the capability of the !IT methodology to determine intersystem leakage and may opt to take credit for !IT to satisfy the Inservice Testing Program and Technical Specifications requirement where appropriate.
Justification for not performing the conventional hydrostatic tests on the systems listed in this letter are in Attachment B and in HAFA Topical Report HAFA 135 (P-A).
A set of color coded P&ID's are included in.this attachment.
Cu~
Staff Licensing Engineer*
CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachments:
A Discussion and Methodology B Conventional Hydrostatic Constraints With P&ID's
References:
- 1. Letter dated February 29, 1988 from P S Tam, NRC to JD Sieber, Duquesne Light Company.
- 2.
Excerpt from Topical Report HAFA 135 (P-A), page v.
- 3.
Meeting minutes of September 30, 1987 dated October 7, 1987 from H Askwith, HAFA to G Johnson, NRC.
- 4.
Meeting minutes of November 5, 1987 dated November 12, 1987 from H Askwith, HAFA to D Weakland, Duquesne Light Company.
- 5.
Meeting minutes of February 4, 1986 dated February 6, 1986 from J Hallen, HAFA to J Lingenfelter, Toledo Edison Company.
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l.l OC0888-0091-NL02 ATTACHMENT A Consumers Power Company Palisades Plant Docket 50-255 DISCUSSION AND METHODOLOGY August 10, 1988 2 Pages
u ATTACHMENT A DISCUSSION AND METHODOLOGY As stated in the NRC Safety Evaluation Report dated November 7, 1985, page v (Reference 1):
The information and data contained in the topical report were presented to demonstrate that the Instrumented Inspection Technique is capable of detecting and locating external system leakage, inter-system valve leakage, reducing personnel exposure to radiation, detecting small leaks, eliminating overpressurization of lower pressure rated piping and components, and is therefore a suitable alternative to Section XI requirements for hydrostatic tests.
Subsequent to the issuance of the Topical Report, RAFA has performed over 200 tests utilizing IIT.
IIT has demonstrated the capability of detecting intersystem leakage and external leakages (that were not found by conventional pressure testing) on systems and components in the Safety Injection System, Auxiliary Feedwater System, Component Cooling Water System, Safety Injection Tanks, Residual Heat Removal System, etc.
- 1.
REPAIR AND REPLACEMENT IIT will be utilized for testing systems and components that have been modified due to repairs or replacements.
Using IIT for this application has been previously approved by NRC staff members (see References 1 and 5).
Auxiliary feedwater pump steam supply valves CV-0521 and CV-0522B are planned for rep~acement during the upcoming outage and will be tested using the IIT methodology for repairs and replacements.
The justification for utilizing IIT in lieu of conventional hydrostatic testing is identified in RAFA Topical Report 135 P-A under main steam system testing.
It should be noted that any applicable valve repair or component replace-ment will be inspected by conventional NDE methods as required by the construction code of the respective plant.
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- 2.
TEN MINUTE HOLD TIME IN LIEU OF TWO HOUR HOLD TIME As accepted by Mr G Johnson's (NRC) review and documented in Mr P S Tam's
.<NRC) letter of February 29, 1988 (Reference 1), a ten minute hold time will be implemented in lieu of a two hour hold time for insulated piping.
This item was discussed with NRC staff on September 30, 1987 and October 7, 1987.
Based upon these discussions, the NRC staff agreed that when using IIT as a test method, a two hour hold time is not warranted since data will be taken during the entire test which exceeds the two hour time limit.
When the system under test achieves normal operating pressure, we will hold for ten minutes and a visual examination (VT-2) will be performed.
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OC0888-0091-NL02 ATTACHMENT B Consumers Power Company Palisades Plant Docket 50-255 CONVENTIONAL HYDROSTATIC TESTING CONSTRAINTS August 10, 1988 6 Pages
ATTACHMENT B CONVENTIONAL HYDROSTATIC TESTING CONSTRAINTS
- 1.
Main Steam System (as shown on P&ID's M-205, Sh 1 and 2; M-207, Sh 1 and lA; and M-226, Sh 1).
- a.
Conventional hydrostatic testing of the main steam system including steam generators, steam generator blowdown system, main feedwater system and auxiliary feedater system would impose the following requirements:
Blanking of 12 code safety relief valves in each of two main steam system loops and 1 additional relief valve:
RV-0521 RV-0701 RV-0702 RV-0703 RV-0704 RV-0705 RV-0706 RV-0707 RV-0708 RV-0709 RV-0710 RV-0711 RV-0712 RV-0713 RV-07'14 RV-0715 RV-0716 RV-0717 RV-0718 RV-0719 RV-0720 RV-0721 RV-0722 RV-0723 RV-0724 OC0888-0091-NL02
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- 1.
- b.
Removal of bonnets and possible removal of internals from check valves.
After reassembly of t~ese check valves a VT-2 leak test would be required.
CK-0482 CK-0701 CK-0702
- c.
Routing of temporary piping and connections between the hydrostatic test pump and several locations in the system through controlled areas.
- d.
Pinning of spring hangers.
- e.
A hydrostatic test of this system would also impose the following hardships:
- 1.
Palisades Technical Specification (TS) 3.l.l.e(6) requires that the steam generator secondary side pressure never be greater than 350 psi above primary coolant system pressure.
This requires the primary coolant ~ystem to be heated and pressurized to at least 950 psia.
requires testing of one steam generator and associated piping at a time with the other generator remaining operabie for heat removal.
Upon completion of testing the first steam generator and associated piping the primary coolant system would have to be placed in cold shutdown to reinstall relief valves on the first system that was tested and remove and blank flange the relief valves for the second system to be tested.
Upon completion of this work the primary coolant system would need to be heated and pressurized to complete testing of the second system.
After com-pletion of testing the second system the primary coolant system again would be returned to cold shutdown to reinstall relief valves, remove hydrostatic test equipment and unpin all previously pinned spring can hangers.
The work identified above is expected to take a minimum of 15 days of critical path time.
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- 1.
- b.
- 2.
Test pressure required by Section XI, IWC-5222 would be 1246 psia.
Palisades TS 3.l.1.e(4) states that the maximum secondary hydro-static test pressure shall not exceed 1250 psia.
Controlling test pressure within this range would be extremely difficult if not impossible.
Based on cycling of the hydrostatic pump and heat input from the primary coolant system into the water solid steam generator.
- 3.
Relief valve protection for this hydrostatic test would require a relief valve that must be accurate to within.3% so that it would be able to relieve before 1250 psia was reached.
Relief valves that pass the necessary flow are not accurate within this range
(.3%).
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4
- 2.
Auxiliary Feedwater System (as shown on P&ID's M-207, Sh 2 and M-220, Sh 1 and 2).
- a.
Discharge Lines
- 1)
Conventional hydrostatic testing would require pinning or removal of the following check valves since the check valves would be sub-jected to hydrostatic pressure in the reverse flow direction.
CK-FW728 CK-FW729 CK-FW703 CK-FW704
- 2)
Relief valve RV-0783 would have to be gagged or removed to perform a conventional hydrostatic test.
- b.
Suction Lines Conventional hydrostatic testing is unable to quantify leakage in buried pipe sections from the condensate storage tank isolation valve to pump discharge isolation valve.
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5
- 3.
Service Water System (as shown on P&ID's M-207, Sh 2; M-208, Sh lA and lB; M-209, Sh 2; M-213 and M-218, Sh 7).
- a.
Conventional hydrostatic testing would pressurize the component cool-ing water heat exchangers to 150 psig.
Design pressure of the heat exchangers is 125 psig and normal operating pressure is 65 psig.
Con-ventional hydrostatic testing of these heat exchangers could cause tube damage within these units.
- b.
Conventional hydrostatic testing would pressurize this piping system to 150 psig.
Service water system piping design pressure is 100 psig and normal operating pressure is 65 psig.
Testing this sytem to 150 psig (2.3 times greater than normal ope~ating pressure) could cause damage to this piping.
Conclusion Based on the conventional hydrostatic testing constraints listed for the main steam system, auxiliary f eedwater system and the service water system, it has been determined that conventional testing is impractical.
Therefore, IIT will be implemented for testing these systems in lieu of hydrostatic testing as allowed by 10CFR50.55a(a)(3) and RAFA International, Inc Topical Report 135 (P)(A).
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6 Associated P&ID's:
I. Main Steam, Main and Auxiliary Turbine Systems, M-205 Sh I, Rev 43
- 2.
Main Steam and Auxiliary Turbine Systems, M-205 Sh 2, Rev 2I
- 3.
Feedwater and Condensate System, M-207 Sh I, Rev 56
- 4.
Feedwater and Condensate System, M-207 Sh IA, Rev I4
- 5.
Auxiliary Feedwater System, M-207 Sh 2, Rev 8
- 6.
Service Water System, M-208 Sh IA, Rev IO
- 7.
Service Water System, M-208 Sh IB, Rev 8
- 8.
Component Cooling System, M-209 Sh 2, Rev IO
- 9.
Service Water, Screen Structure and Chlorinator, M-2I3, Rev 38 IO.
Heating, Ventilation and Air Conditioning Control Room, M-2I8 Sh 7, Rev 3 II. Makeup, Domestic Water and Chemical Injection Systems, M-220 Sh I, Rev 4I I2.
Makeup, Domestic Water and Chemical Injection Systems, M-220 Sh 2, Rev 5 I3.
Steam Generator Blowdown Modification, M-226 Sh I, Rev 33 OC0888-009I-NL02