ML18065A574
| ML18065A574 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/11/1996 |
| From: | Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.147, RTR-REGGD-1.147 NUDOCS 9603200017 | |
| Download: ML18065A574 (10) | |
Text
consumers Power*
POWE RI Nii MICHlliAN"S PROliREll Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 March 11, 1996
- u S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT INSERVICE INSPECTION PRESSURE TEST PROGRAM - REQUESTS FOR RELIEF Two relief requests are attached (Attachment 1) which require NRC approval prior to use. These relief requests propose alternative testing per 10 CFR Part 50.55a(a)(3) within the Palisades lnservice Inspection Pressure Test Program.
Relief Request PR-02 requests that alternative testing be allowed for components under the reactor vessel. Current Code requirements (ASME Section XI, IWA and IWB) specify that these pressure retaining components shall be subject to visual examinations during system pressure tests. The area under the reactor vessel is extremely b?zardous during the hot shutdown conditicms when pressure testing is performed. The hazardous conditions include not only high radiation fields but also confined spaces and heat stress conditions. The alternative testing proposed is to conduct the test in accordance with ASME Section XI, IWA-5244, "Buried Components" with a leakage calculation performed to determine the total PCS leak rate.
Relief Request PR-04 requests that the ASME Nuclear Code Case N-522, "Pressure
- Testing of Containment Penetration Piping," be approved for use prior to its inclusion in Regulatory Guide 1.147. Code Case N-522 (Attachment 2) accepts the test requirements of 1 O CFR Part 50, Appendix J as an alternative to the test requirements of ASME Section XI, Table IWC-2500-1, Category C-H. This would significantly reduce the redundant testing required by the imposition of both ASME Section XI and 10 CFR Part 50, Appendix J.
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2 In accordance with 10 CFR Part 50.55a(a)(3), approval of Relief Requests numbers PR-02 and PR-04 is requested as alternatives to the requirements of ASME Section Xl-1989.
. I
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
Richard W Smedley Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades 2 Attachments
ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 INSERVICE INSPECTION PRESSURE TEST PROGRAM - REQUESTS FOR RELIEF RELIEF REQUESTS PR-02 AND PR-04
RELIEF REQUEST NUMBER: PR-02 COMPONENT IDENTIFICATION Code Class:
References:
1 IWA-5211 Table IWA-5210~1 IW8-5210 Table IW8-2500-1 Examination Category: 8-P
==
Description:==
Alternative Testing for the Reactor Vessel Within the Reactor Cavity CODE REQUIREMENT IWA-5211 states that the pressure retaining components within each system boundary shall be subject to system pressure tests as specified in Table IWA-5210-1 under which conditions VT-2 Visual Examinations are performed.
Table IWA-5210-1 requires a system leakage test and a system hydrostatic test be performed in accordance with Table IW8-2500-1, Category 8-P.
IW8-521 0 states that the pressure retaining components shall be tested at the frequency given and visually examined by the method specified in Table IWB-2500-1, Examination Category 8-P.
Table IWB-2500-1, Examination Category 8-P requires a system leakage test be performed each refueling outage on the pressure retaining boundary associated with normal reactor start-up and a system hydrostatic test be performed each inspection interval on the pressure retaining boundary of all Class 1 components.
BASIS FOR RELIEF Pursuant to 1 OCFR50.55a(a)(3)(ii), an alternative to the visual VT-2 examination specified by the requirements is requested on the basis that they would result in hardship and unusual difficulty without a compensating increase in the level of quality and safety. Also, per 1 OCFR50.55a(a)(3)(i), the proposed alternate examination will provide an acceptable level of quality and safety.
The area under the reacfor vessel is extremely hazardous when the Plant is at Hot Shutdown Conditions for system leakage testing. Radiation levels are expected to be 2.5 rem/hr (on contact), which is the maximum measured during cold shutdown. General dose is 1.5 to 2 rem/hr in the area. Assuming 2 persons in this area at one-half. hour per person, a total of 1.5 to 2 rem of dose would be received.
In addition to radiation concerns, access to the area under the vessel poses* various industrial hazards. Of primary concern is confined spaces and heat stress.
Ambient air temperatures with the Primary Coolant System at full pressure and temperature are expected to be approximately 300 degrees. Access under these conditions would require significant ventilation for cooling. The access tube to this area is only 30 inches in diameter. This size limits the amount of ventilation possible while allowing personnel access.
PROPOSED ALTERNATE EXAMINATION Palisades Nuclear Plant shall determine leakage from piping and components in the area under the reactor vessel in accordance with paragraph IWA-5244 "Buried Components" of ASME Section XI, 1989 Edition, no Addenda. This requirement will be satisfied by conducting Palisades' System Operating Procedure SOP 1, "Primary Coolant System (PCS)," which completes the PCS leak rate calculation.
Plant Technical Specification ~.1.5 states, "If the primary coolant system leakage exceeds 1 gpm and the source of the leakage is not identified, reduce unidentified primary coolant system leakage to less than 1 gpm within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or place the reactor in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown condition within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." Technical Specification 3.1.5d invokes a more restrictive leakage limit of 0.6 gpm during startups. Technical Specification Table 4.2.2, Item 7 requires this leak rate determination on a daily basis. These limits are approved as documented in Palisades Facility Operating License DPR-20, through Amendment No 1 61 and are applicable at all times when the Primary Coolant System is greater than cold shutdown conditions.
- APPLICABLE TIME PERIOD This alternative is requested for the third ten-year interval of the lnservice Inspection Program for Palisades, which concludes in August of 2005.
2
RELIEF REQUEST NUMBER PR-04 COMPONENT IDENTIFICATION Code Class:
2
References:
IWA-5211 IWA-5240 Table IWC-2500-1 IWC-521 O(a)
Examination Category: C-H
==
Description:==
Alternative Pressure Testing of Containment Penetration Piping Containment Isolation System (CIS)
MZ-1a MZ-1b MZ-1c MZ-10 MZ-10a MZ-11 MZ-17 MZ-18 MZ-18a MZ-19 MZ-21 MZ-21a MZ-25 MZ-26
- MZ-27 MZ-28 MZ-33 MZ-37 MZ-38 MZ-39 MZ-40a MZ-40b MZ-41 MZ-42 MZ-44 MZ-46 MZ-47 MZ-48 MZ-49 MZ-50 MZ-51 MZ-52a MZ-52b MZ-64 MZ-65 MZ-66 MZ-67 MZ-68 MZ-69 MZ-72 Purge Air Exhaust Purge Air Exhaust Bypass Purge Air Exhaust Service Air Service Air Condensate to Shield Cooling Surge Tank Containment Pressure Instrument Line Transfer Winch Cable Fuel Transfer Tube Personnel Air Lock Hydrogen Monitoring Return Line Hydrogen Monitoring Supply Line Clean Waste Receiver Tank Vent Nitrogen to Quench Tank ILRT Fill Line Containment Air Sample Line Safety Injection Tank Drain Primary System Drain Tank Recirculation Containment Building Heating Steam Return Containment Building Heating Steam Supply Hydrogen Monitoring Return Line Hydrogen Monitoring Supply Line Degasifier Pump Discharge Demin Water to Quench Tank Primary Coolant Pump Controlled Bleed Off Containment Vent Header Primary System Drain Tank Pump Suction Containment Pressure Instrument Lines Clean Waste Receiver Tank Circulation Lirie Emergency Access Equipment Hatch Containment Sump Level Instrument Containment Sump Level Instrument Reactor Cavity Fill and Recycle Instrument Air ILRT Instrument Line Clean Waste Receiver Tank Pump Discharge Air Supply to Air Room Clean Waste Receiver Tank Pump Suction Reactor Cavity Drain and Recycle
2 CODE REQUIREMENT IWA-5211 states, "The pressure retaining components within each system boundary shall be subject to system pressure tests under which conditions visual examination VT-2 is performed in acco.rdance with IWA-5240 to detect leakages."
IWC-521 O(a) states, "The pressure retaining components within each system boundary shall be subjected to a system pressure test conducted during a system functional test, a system pressure test conducted during a system inservice test, or a hydrostatic test, and visually examined by the method specified in Table IWC-2500-1, Examination Category C-H."
Table IWC~2500-1, Examination Category C-H, specifies a frequency of examination of once per inspection period for inservice or functional testing and once per inspection interval for hydrostatic testing.
BASIS FOR RELIEF Pursuant to 1 OCFR50.55a(a)(3)(i), the proposed alternative provides an acceptable level of quality and safety.
The proposed alternative will reduce the level of redundant testing. Imposition of the IWC-2500-1 test requirements would result in additional testing as follows:
- 1.
. 2.
Water systems would be flooded and pressurized through the associated penetration test tap and a VT-2 visual examination performed during the pressurization period.
Air and gas systems would be tested in an identical fashion to 1 OCFR50, Appendix J test method and a VT-2 visual examination would be performed during the pressurization period.
For the penetrations listed, 10CFR50, Appendix J testing is performed by draining the test volume, if required, venting downstream of the test volume and pressurizing the test volume to 55 psig. The rate of pressure decay is determined and compared to acceptance criteria based on allowable containment leak rate.
Leakage from water systems would be indicated during the 1 OCFR50, Appendix J test more readily than the IWC-2500-1 test due to the lower density of the air test medium.
Based on this fact, the use of the Appendix J test program is conservative when
- compared to the ASME Section XI program.
3 Leakage from air and other gas systems would be indicated by 1 OCFR50, Appendix J testing in a similar manner to an IWC-2500-1 test. Based on this fact, the two programs are essentially equivalent.
The specified frequency of testing for the 1 OCFR50, Appendix J test program is once per refueling cycle, which is approximately 18 months. The IWC-2500-1 specified test frequency is once per inspection period which is approximately 3-1/3 years. A comparison of the specified test frequencies indicates the 1 OCFR50, Appendix J test program is conservative when compared to the ASME Section XI test program.
Palisades 1 OCFR50, Appendix J testing is performed by plant auxiliary operators (AO's). Palisades certifies the AO's as VT.;2 Level II examiners in accordance with Section XI. Therefore, Appendix J testing is performed by personnel trained to recognize unacceptable leakage from a pressure boundary.
PROPOSED ALTERNATIVE In lieu of the requirements specified in IWA-5211 and IWC-5210, Palisades will follow the guidance of Code Case N-522 for pressure testing of safety class 2 containment penetrations associated with non-safety class systems.
Testing required by 1 OCFR50.55, Appendix J may be used as an alternative to the rules in Table IWC-2500-1, Category C-H, for pressure testing piping that penetrates a containment vessel, when:
- 1.
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.
APPLICABLE TIME PERIOD The proposed alternative is requested for the third ten-year interval of the lnservice Inspection Program for Palisades, which concludes in August of 2005.
ATTACHMENT 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 INSERVICE INSPECTION PRESSURE TEST PROGRAM - REQUESTS FOR RELIEF ASME CODE CASE N-522 1 Page
CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: December 9, 1993 See Numerical Index for expiration and any reaffirmation dates.
Case N-522 Pressure Testing of Containment Penetration Piping Section XI, Division 1 Inquiry: What altem.ative to the niles of Table IWC-2500-1, Category C-H may be used for pressure testing piping that penetrates a containment vessel, when the piping and isolation valves that are part of the contain-ment system are Class 2 but the balance of the piping system is outside the scope of Section XI?
Reply: It is the opinion of the Committee that 10 CFR 50, Appendix J, may be* used as an alternative to the 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 con-tainment system are Class 2 but the balance of the pip-ing system is outside the scope of Section XI?
1029 CASE N-522