ML18064A589
| ML18064A589 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/24/1995 |
| From: | Haas K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9502010055 | |
| Download: ML18064A589 (6) | |
Text
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consumers Power l'OWERINli MICHlliAN-S l'ROlillESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 January 24, 1995 Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT KurtM.Haas Plant *Safety and Licensing Director CODE CASE N-498-1 USAGE APPROVAL FOR 10 YEAR HYDROSTATIC PRESSURE TESTS FOR CLASS 1, 2, AND 3 SYSTEMS The AMSE Code Case N-498 allows Class 1 and 2 systems to be hydrostatically tested at a reduced pressure equal to the system nominal operating pressure.
Code Case N-498 has been endorsed by the NRC in Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI Division l".
The ASME has recently expanded the scope of the Code Case when it approved Code Case N-498-1.
Code Case N-498-1 repeats the requirements for hydrostatically testing Class 1 and 2 systems and extends the allowed nominal opefating pressure testing to Class 3 systems.
Code Case N-498-1 also allows the use of installed plant instrumentation in place of the requirements for special test gauging of IWA-5260 when performing these nominal operating pressure tests.
Due to its recent approval, Code Case N-498-1 has not yet been approved for use in Regulatory Guide 1.147.
However, in accordance with footnote 6 to 10 CFR 50.55a, we request approval for use of Code Case N-498-1 for Inservice Testing during the 1995 refueling outage which is presently scheduled to begin in May of this year.
Pursuant to 10 CFR 50.55a(a)(3) and the justification provided in Attachmen~ 1 to this letter, we believe that Code Case N-498-1 provides an acceptable alternative to the presently NRC endorsed requirements.
9502010055,950i24
- PDR ADOCK 05000255
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A CMS' ENERGY COMPANY
SUMMARY
OF COMMITMENTS This letter contains no new commitments.
I Kurt M Haas Plant Safety and Licensing Director CC Administrator, Region Ill, USNRC NRC Resident Inspector - Palisades Attachment 2
ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 CODE CASE N-498-1 USAGE APPROVAL FOR 10 YEAR HYDROSTATIC PRESSURE TESTS FOR CLASS 1, 2, AND 3 SYSTEMS JUSTIFICATION FOR CODE CASE APPROVAL 3 Pages
Code Class:
Subject:
JUSTIFICATION fOR USE OF CODE CASE N-498-1 1, 2 and 3 10-Year hydrostatic pressure test requirements for Class 1, 2 and 3 systems.
1 Components:
All Class 1, 2 and 3 piping systems which are subject to the pressure test requirements of ASME Section XI.
Code Requirements Reference ASME Section XI 1983 Edition, Summer 1983 Addenda.
A system hydrostatic pressure t~st (IWA-52lld) and accompanying VT-2 is required at least once.each inspection interval(nominally 10 years).
Reference Table IWA-5210-1, Categories B-P (Class 1), C-H (Class 2), 0-A, 0-B and 0-C (Class 3).
Basis for Justification Performance of system hydrostatic pressure tests imposes an undue hardship without a compensating increase in nuclear safety.
The amount of effort expended in repairing system boundary valves, which are not designed for leak tight shutoff, in order to successfully complete testing is not compensated for by an increase in safety. Additionally, removing systems from service to complete hydrostatic testing poses a risk to safety by isolating cooling water from important plant loads, such as, spent fuel pool cooling and shutdown cooling.
Code Case N-498, currently endorsed by the NRC in Regulatory Guide 1.147, allows Class 1 and 2 System Hydrostatic testing at a reduced pressure equal to system nominal operating pressure.
The recent ASME approved Code Case N-498-1, while repeating these requirements for Class 1 and 2, also clarifies the intent of using installed plant instrumentation without the need for test gauging or their imposed requirements of IWA-5260 when performing these nominal operating pressure tests.
It is Palisades' position that performing system pressure tests on Class 1 and 2 systems consistent with the requirements of N-498-1, together with the applicable volumetric examinations in accordance with the ISi Program, provides a level of quality and safety equivalent to, or greater than, that provided by the Code hydrostatic test pressure and instrumentation requirements.
Code-Case N-498-1 also permits the reduced pressure testing-in lieu of Hydrostatic Tests for Class 3 systems.
Palisades Class 3 systems include portions of Chemical and Volume Control, Component Cooling, Service Water, Auxiliary Feedwater and Spent Fuel Pool Cooling Systems.
Each of these systems is designed, fabricated, constructed and tested in a manner which assures pressure boundary integrity. Additionally, each system receives chemical treatment and/or monitoring to assure continued pressure boundary integrity.
2 The Auxiliary Feedwater System receives water from the Condensate Storage Tank T-2.
The water contained in T-2 is filtered and demineralized to reduce corrosion of system components.
In the Component Cooling System, nitrite concentration is maintained to provide corrosion protection.
The nitrate inhibitor acts to create and maintain a passive oxide layer on the internals of the Component Cooling System.
Sampling and analysis of system chemistry is performed at a frequency adequate to maintain proper corrosion inhibiting conditions.
For the Service Water System, Palisades employs a program designed to ensure corrosion, erosion, silting, biofouling and protective coating degradation are controlled so that safety-related components are not at risk. This program includes chlorination, zebra mussel chlorination treatment, inspections and coupon analysis. This program is also designed to control Microbiologically Influenced Corrosion (MIC).
The portion of Chemical and Volume Control between the Class 1 portion of letdown and the containment penetration has been designated as Class 3 in accordance with Regulatory Guide 1.26.
The CVCS is d~signed to maintain Primary Coolant System chemistry, therefore appropriate conditions are maintained through the use of filtration and addition of Boron, Hydrogen.,
Nitrogen and other chemicals.
Spent Fuel Pool chemistry is maintained through the use of Primary Make-up water and Boron.
System design makes extensive use of stainless steel to reduce corrosion concerns.
Chemistry contaminant limits are consistent with that of the Primary Coolant System, because Spent Fuel Pool water may enter the PCS when refueling is in process.
System chemistry for all Palisades safety systems is maintained by approved plant procedures.
The purpose of chemistry control is to assure operational readiness by inhibiting degradation mechanisms which may compromise pressure boundary integrity.
Palisades maintains Visual Examination VT-2 certifications for all Auxiliary Operators and other selected individuals, who meet the educational, experience and physical requirements of ANSI N45.2.6.
The VT-2 program provides training to assist operators in determining the pressure boundary integrity of all plant systems during daily rounds.
Operators are trained to recognize evidence of leakage, as well as, actual system leakage.
Operator use of VT-2 Examination training provides additional assurance of pressure boundary integrity for all class systems.
It fs Palisades' position that performing system pressure tests on Class 3 systems consistent with the requirements of N-498-1, together with the implementation of chemical control and VT-2 examination programs, provides a level of quality and safety equivalent to, or greater than, that provided by the Code hydrostatic test pressure and instrumentation requirements.
Proposed Alternative 3
As a supplement to existing Section XI requirements, Palisades will adopt the provisions of Code Case N-498-1, as approved by the Board of Nuclear Codes and Standards (BNCS}.
In lieu of performing a hydrostatic pressure test at a pressure above nomi~al operating pressure or system pressure for which overpressure protection is provided, as required by Table IWA-5210-1, Examination Categories B-P, C-H, D-A, 0-B and 0-C, a system pressure test at nominal operating pressure and temperature shall be performed.
In lieu of instrumentation requirements specified in IWA-5260, existing plant instrumentation will be used per IWA-5212(b}.
Where gauging may be required and does not exist, the rules of IWA-5260 shall be used.