ML18065A802

Rev 2 to EM-09-13, ISI Pressure Testing Program.

ML18065A802
Person / Time
Site:	Palisades
Issue date:	02/21/1996
From:	Fouty T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18065A800	List: ML18065A799 ML18065A802
References
EM-09-13, EM-9-13, NUDOCS 9607020194
Download: ML18065A802 (57)

Text

Procedure No EM 13 Revision 2 Issued Date 2/23/96

• PALISADES NUCLEAR PLANT ENGINEERING MANUAL PROCEDURE TITLE: INSERVICE *INSPECTION PRESSURE TESTING PROGRAM k f~

Procedure Sponsor I 2.fz1/q/_

Date THFouty I 1/11/QS Technical Reviewer Date

• User Reviewer Date Rev#

I .

9607020194 960624 :

PDR ADOCK 050002551 Q . _ ____ _____ .. __ t='DR

PALISADES NUCLEAR PLANT Proc No EM-09-1 3 ENGINEERING MANUAL PROCEPURE Revision 2 Page i

• TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM Table of Contents 1 .0 PURPOSE ........................................... 1 2.0 SCOPE ......... ~ ................ *........ ~ ..... *..... 1

3.0 REFERENCES

............... *.* . . . . . . . . . . . . . . . . . . . . . . . . 1 3.1 SOURCE DOCUMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

3. 2 REFERENCE DOCUMENTS ........ : . . . . . . . . . . . . . . . . 2 4.0 DEFINITIONS AND RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . 4

4. 1 DEFINITIONS : . . . . . . . . . . . . . . . . . . . . . *.......... *.. 4

4. 2 RESPONS.IBILITIES . . . . . . . . . . . . . . . . ; . . . . . . . . . . . . . 6 5.0 PROCEPURE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

5. 1 FREQUENCY AND SCHEDULING OF TESTS .............* 8 5.2 GENERAL REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . 10

. 5.2._1

• Test Description ; . . . . : .. *: .. . . .* : . . . . . . . . *. . .

• 10 .

5.2.2 Test Pres*surization Boundaries OWA-5220) * .. ~ . . 14 5.2.3 Visual Exaqiinatjoo OWA-5240) . . .. . . . . . ... . . 15 5.2.4 lnstryments for Pressure Tests OWA-52601 . .. . . . 18 5.3 REQUIREMENTS FOR CLASS 1 PRESSURE TESTING (IWB-5000) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 5.3.1 UWB-5210) . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 5.3.2 Pressyre UWB-5220) . . . . . . . . . . . . . . . . . . . . . 21 5.3.3 Temperature UWB-5230> ................... 22 5.3.4 Reactor Vessel Examinations . . . . . . . . . . . . . . . 23

. 5.4 REQUIREMENTS FOR CLASS 2 PRESSURE TESTING (IWC-5000) . . . . . . . . . . . . . . . . . . . . . . . . . .. . .. . . . . . . 23 5.4.1 Test UWC-5210> . . . . . . . . . . . . . . . . . . . . . . . . 23 5.4.2 Pressure UWC-5220) . . . . . . . . . . . . . . . . . . . . . 25 5.4.3 Temperature UWC-5230> ................... 26

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page ii TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

• Table of Contents

5. 5 REQUIREMENTS FOR CLASS 3 PRESSURE TESTING (IWD-5000) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 7 5.5.1 Test UWD-5210) . . . . . . . . . . . . . . . . . . . . . . . . 27

5. 5. 2 Pressure UWP-5220) . . . . . . . . . . . . . . . . . . . . . 28

5. 5. 3 Temperature UWP-52301 . . . . . . . . . . . . . . . . . . 2 9

5. 6 REQUIREMENTS FOR NON ASME PRESSURE TESTING : ... 30 5.6.1 Technical Specification 6.15 . . . . . . . . . . . . . . . . 30 5.6.2 *Technical Specification 4.5.3 . . . . . . . . . . . . . . . 30

5. 7 NONCONFORMANCES . . . . . . . . . . . . . . . . : ......... 31

• 5.8 5.7.5 Corrective Measures UWA-5250)

ADMINISTRATIVE REQUIREMENTS 5.8.1

. . . . . . . . . . . . 31

. . . . . . . . . . . . . . . . . 32 Procedure Development and Periodic Review . . . . 3 2

. 5.8.2

• Outage Preparation . . . . . . . . . . . . . .. . . . . .. . . . 3.2

• 5.8.3 Outage Performance . . . . . . *. . . . . . . . . . . . . . . 34

5. 9 POST OUTAGE DOCUMENTATION . . . . . . . . . . . . . . . . . . 36

5. 9. 1 Test Records UWA-5300) . . . . . . . . . . . . . : .- . . 36 5.9.2 ISi Summarv Report . . . . . . . . . . . . . . . . . . . . . 36 6.0 ATTACHMENTS ANP RECORPS ...... *. . . . . . . . . . . . . . . . . . . . 37 6.1 ATTACHMENTS . : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 6.2 RECORDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 ATTACHMENTS Attachment 1, "2nd Interval Pressure Test Record" Attachment 2, "lnservice/Functional Tests, 3rd Interval"

• Attachment Attachment Attachment 3,

4, 5,

"Pressure Test Flow Chart" "System Pressure Testing Relief Requests" "Revision Summary"

PALISADES NUCLEAR PLANT Proc No EM 13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 1 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM USER ALERT REFERENCE USE PROCEDURE Refer to the procedt:1re periodically to confirm that all procedure segments of an activity will be or are being performed. Where required, sign appropriate sign-off blanks to certify that all segments are complete.

1.0 PURPOSE This procedure provides general requirements for the performance of the ASME Section XI and Technical Specifications, Pressure Testing Program.

2.0 SCOPE

• 2.1 2.2 This procedure complies with all requirements of ASME Section XI, 1989 Edition, no Addenda.

This procedure complies with all requirements of Technical Sp~cif~catio_n 4.0.5a.

2.3 This procedure complies with the requirements of Technical Specifications 6.15"and 4.5.3. These requirements are in addition to ASME and Technical Specification 4.0.5a.

2.4 The Palisades Plant lnservice ln'spection Pressure Testing Program Plan will be in effect through the second third 1 20-month interval (August 1995 through August 2005) and will be updated in accordance with 10CFR50.55a(g).

3.0 REFERENCES

3.1 SOURCE DOCUMENTS 3.1.1 ASME Boiler and Pressure Vessel Code,Section XI, 1989 Edition, no Addenda

• 3.1.2 3.1 .3 Code of Federal Regulations 10CFR50.55a Technical Specification Chapter 6 - 6.15

PALISAPES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 2 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM 3.1.4 Technical_Specification Chapter 4 - 4.0. 5 and 4. 5. 3 3.1.5 Technical Specification Chapter 3 - 3.1 3.1.6 Final Safety Analysis Report (FSAR) - 6.9 and Table 6-13 3.1.7 Palisades ISi Color Coded Boundary Drawings 3.2 REFERENCE DOCUMENTS 3.2.1 Palisad~s Administrative Procedure 9.20, "Technical Specification Surveillance and Special Test Program

3.2.2 Palisades Administrative Procedure 9.06, "Code Requirements for Plant Maintenance and Modifications" 3.2.3 Palisades Administrative Procedure 10.41, "Procedure Initiation and Revision" 3.2.4 Palisades Administrative Procedure 10.42, "Procedure/Document Matrix" 3.2.5 _ Palisades Administrative Pr_ocedur.e 10.51, "~rite.r's Guide_line for Procedures ...

3.2.6 Palisades Administrative Procedure 10.53, "Use and Adherence of Procedures and Other Forms of Written Instructions" 3.2. 7 Engineering Manual Procedure EM-09-14, "VT-2 Examinations" 3.2.8 Engineering Manual Procedure EM-26, "Boric Acid Leak Inspection" 3.2.9 Palisades Administrative Procedure 5.04, "Control of Installed Plant Instrumentation (IPI)"

3.2.10 Palisades Administrative Procedure 5.07, "Control of Measuring and Test Equipment" 3.2.11 Technical Specification Surveillance Procedure RT-71 A, "Primary Coolant System, Class 1 Hydrostatic System Leakage Test" 3.2.12 Technical Specification Surveillance Procedure RT-71 B, "HPSI Train 1 and 2 and SIT System, Class 2 System Functional/lnservice Test"

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 3 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM 3.2.13 Technical Specification Surveillance Procedure RT-71 C, "Chemical and Volume Control System, Class 2 and 3 lriservice/Functional Tests"

3. 2.14 Technical Specification Surveillance Procedure RT-71 E, "Main Steam, Feed water, and Auxiliary Feedwater Systems, Class 2 System lnservice Test" 3.2.15 Technical Specification Surveillance Procedure RT-71 F, "Component Cooling System Class 2 and 3 lnservice Test" 3.2.16 Technical Specification Surveillance Procedure RT-71G, "Service Water System Class 2 and 3 lnservice Test"

3. 2. 1 7 Technical Specification Surveillance Procedure RT- 71 H, "Spent Fu~I Pool System Class 3 lnservice Test" 3.2.18 Technical Specification Surveillance Procedure RT-711, "Auxiliary Feedwater Class 2 and 3 System Functional/lriservice Test" 3.2.19 Technical Specification Surveillance Procedure RT-71 J, "ESS Pump Suction From Containment Sump, Class 2 System Functional Test" 3-.7.20 Technical Specificati-on- Surveillance Procedu're RT:71 K, "Class 2 System Functional Test for Shutdown Cooling System"

3. 2. 21 Technical Specification Surveillance Procedure RT- 71 L, "I echnical Specification 4.5.3 Pressure Test of ESS Pump Suction Piping" 3.2.22 Technical Specification Surveillance Procedure RT-71 M, "Class _2 System lnservice Test for Safety_lnjection and Refueling Water Tank and Chemical Addition System" 3.2.23 Technical Specification Surveillance Procedure RT-71 N, "Leak Test of PCS Sampling System"

3. 2. 24 Technical Specification Surveillance Procedure RT-71 0, "Pressure Test of Containment Air Sampling System Outside of Penetrations MZ-21 and -

MZ-21A"

• 3.2.25 Technical Specification Surveillance Procedure RT-71 P, "Pressure Test for Containment Air Sampling System Outside of Penetration MZ-40A and MZ-408"

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 4 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM 3.2.26 Regulatory Guide 1.26, "Quality Group Classifications and Standards for Water, Steam, and Radioactive Waste Containing Components of Nuclear Power Plants"

3. 2. 2 7 Regulatory Guide 1 . 14 7, Revision 11, "In service Inspection Code Case Acceptability, ASME.Section XI, Division I" 3.2.28 Licensing Correspondence 510150, "Approval of Code Case N-416-1" el I (TAC NO M91764) (FIL-G2740493) 3.2.29 Licensing Correspondence 510116, "Approval of Code Case N-498-1 el (TAC NO M91410) (FIL-G22511799)

~OIE: Code Case N-522 allows for 10CFR50, Appendix J testing to take credit for Section XI, Table WC-2500-1, Category C-H pressure testing of Class. 2 containment penetration piping and valves where the balance _of the piping system is outside the scope of Section XI.

3.2.30 Code Case N-522, "Pressure Testing of Containment Penetration Piping" 3.2.31 Health Physics Procedure HP 2.2, "Determining Concentrations of Radioactivity In-Air" 3.2.32 System Operating Procedure SOP 1, "Primary Coolant System" 3.2.33 Technical. Specification Surveillance Procedure FT-3, "Containment

. Spray Nozzle Test" 3.2.34 Palisades Administrative Procedure 10.44, "Engineering Records Center Distribution and Control Qf Design Documents" 4.0 PEEINIIIONS ANP RESPONSIBILl!IES

4. 1 DEFINITIONS 4.1.1 Access Engineering - The review of applicable inspection areas described by ASME B&PV Code,Section XI, for the purpose of determining

. inspectability, inspection environment, and establishing basis for

• necessary relief requests.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 5 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM 4.1.2 Authorized Inspection Agency - An Authorized Inspection Agency is one designatea by, or acceptable to, the appropriate legal authority of one of the cities or states of the United States of America, or province of Canada, that has adopted Section XI of the ASME Boiler and Pressure Vessel Code. Such agencies shall meet the criteria of Section XI of the ASME Code and of the National Board of Boiler and Pressure Vessel Inspectors.

4.1.3 Authorized Nuclear lnservice Inspector (ANll) - An Inspector employed by an authorized inspection agency.

4.1.4 Code Cases - A statement by B&PV Committee establishing additions or revisions to the Code or clarifying the intent of existing requirements for provide rules for materials or construction not covered by the Code.

Those cases which have* been adopted will appear in the ASME B&PV Code Case books. The NRC documents endorsement of Code Cases in Regulatory Guide 1 . 14 7, Revision 11 dated October .1 994 is the current revision of Regulatory Guide 1 . 14 7.

4.1.5 Enforcement Authority - The State of Michigan, Department of Labor, Boiler Division.

4.1.6 Examination - The performance of nondestructive~'testing sue~ as.-:

radiography, ultrasonic, liquid penetrant, magnetic- particle methods, and :.-

visual examinations.

4.1.7 Examination Agency - Any contractor or Consumers Power Company organization approved by Consumers Power Company to perform lnservice Inspection Examination (see definition 4.1.6).

4.1.8 lnservice Inspection - An inspection performed in accordance with the rules of the ASME B&PV Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," and the Plant Technical Specifications.

4.1.9 lnservice Inspection (ISi) Coordinator - That individual assigned by the Engineering Programs Manager to oversee performance of the testing program, evaluate data, and identify the need for corrective action to the appropriate System Engineer .

PALISADES NUCLEAR PLANT Proc No EM 13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 6 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

4. 1. 10. Records -_Information showing the history, including surveillance test results and significant maintenance actions. At Palisades, the record includes the Uniform Filing Index (UFI) (test results), the maintenance order files contained on AMMS (maintenance documentation), the applicable surveillance procedure basis document (discussion of test limits and basis), and the ISi Outage Plan and ISi Ou~age Record.

4. 1 . 11 Relief Request - Specific documents requesting exemption from code testing requirements, submitted to the US Nuclear Regulatory Commission (NRC). Upon identification of need, the initial request shall be submitted to the Nuclear Licensing Department who shall review the requests, ask appropriate questions, and prepare the request for relief for submittal to

• the NRC.

4.1 .12 System Engineer - Service manager for the subject system.

4.1 .13 System Pressure Test - One of several tests, leakage, functional, inservice, hydrostatic, pneumatic, open flow, or tank full, conducted in accordance with ASME B&PV Code,Section XI, to verify a system's, or portion of a system's, pressure boundary integrity.

4.1.14 Technical _Specification Sur:veillance Program Administrato.r (JSS~PA) -

The individual responsible for the administration of the Technical Specification Surveillance Program.

4.1.15 VT-2 Visual Examination - A visual examination conducted in accordance with Section XI, paragraph IWA-5240 to locate evidence of leakage from pressure retaining components during the conduct of a system pressure test.

4.2 RESPONSIBILITIES The Engineering Program Department is assigned overall responsibilities for the administration of the Palisades Nuclear Plant *ISi Program.

Responsibilities for major portions of the program are as follows:

4.2.1 Pressure Testing Program Development and Maintenance - Palisades ISi provides the necessary access engineering and code interpretation to

• • generate pressure testing procedures for all Class 1 , 2, and 3 components and piping.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 7 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

a. Hydrostatic and Leak Test - Palisades ISi is responsible for procedure development and revision for the hydrostatic and leak tests. Palisades ISi shall determine required test pressures, examination boundaries, hold times, and overall compliance with Section XI.

b. Code Case N-498-1 Tests - Palisades ISi is responsible for procedure development and revision to ensure the requirements of Code Case N-498-1 are incorporated into .the third 10-year interval Pressure Testing Plan for all ISi Classed components and piping.

Palisades ISi shall determine the required surveillance procedures, test pressures, examination boundaries, hold times, test instrumentation, and overall compliance with the code case. Test Boundaries shall be inclusive of all ISi Class 1, 2 and 3 components and piping, and Test Hold Times shall be in accordance with ASME Section XI, paragraph IWA-521 3(d).

NOTE:* Code Case N-498-1 revises Code Case N-498 to allow for system inservice/functional tests in lieu of 10-year hydrostatic tests for Class 3 components and piping. This test methodology was previously granted for Class 1 and 2 systems under Code Case N~498. The NRC has approved the use of this code case as documented in Reference 3.2.29. 1e.

4.2.2 Relief Requests - Palisades ISi shall request relief from the provisions of

' - *~

Section XI as necessary by generating detailed ISi exemption, impracticability, hardship, _alternative examination, and safety analyses.

Palisades ISi shall prepare the appropriate Technical Specifications and Relief Request bases for submittal to the NRC via the Palisades Licensing Department.

4.2.3 Updates - Palisades ISi shall prepare and summit details of the pressure J testing program in conjunction with the 40 year ISi Master Plan updates as required. The updates address changes in ASME Boiler and Pressure Vessel Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," and Palisades Plant Technical Specifications, Sections 4.0, 4.5, and 6~ 15.

4.2.4 Revision - Palisades ISi shall mai'ntain the Pressure Testing Program by periodic review and correction of this procedure, review of Plant modifications and addressing required program updates, and by checks on examination schedule and frequency requirements for compliance following each inspection.

PALISADt;S NUCLEAR PLANT Proc No EM 1 3

./. ENGINEERING MANUAL PROCEPURE TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM Revision 2 Page 8 of 37 4.2.5 Engineerir:ig - Palisades ISi shall provid~ en_gineering expertise on code interpretations and technology application. Palisades ISi shall be responsible for access engineering, Technical Specifications, and relief request submittals. Palisades ISi shall obtain information which establishes access requirements for components to be inspected such as scaffolding, insulation, or other maintenance activities.

4.2.6 Test Team - Palisades ISi shall coordinate station groups required to conduct each pressure test, including but not limited to, Operations, Work Planning, Mechanical Maintenance, Instrument Maintenance VT-2 Examiners, Station laborers, and Radiation Protection.

4.2.7 Performance - Palisades ISi shall schedule, or verify scheduled, and oversee the various activities required by the Test T earn for pre-test preparation, test performance, and post~test system restoration.

5.0 PROCEPURE USER.ALERT REFERENCE USE PROCEDURE Refer to the procedure periodically to conf.irm

• that all procedure segments of an activity will be or are being performed. Where required, sign appropriate sign-off blanks to certify that all segments are complete.

5.1. FREQUENCY AND SCHEDULING OF TESTS

5. 1. 1 ASME Class 1, 2, and 3 components as determined by 1 OCFR50 and 1 OCFR50'.55a shall receive a hydrostatic test once each inspection interval of 10 years and a system leakage test at nominal operating pre.ssure and temperature each refueling outage, prior to Plant start-up.

Per Code Case N-498-1, a System Leakage Test may be conducted as an alternative to the 10-year hydrostatic test provided that the boundary subject to test pressurization and VT-2 examinat_ion during the leakage

• test extends to all Class 1 pressure retaining components and. that the pressurization hold time be at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components and 10 minutes for noninsulated components.

PALISADES NUCLEAR PLANT

• Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 9 of 37

• TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM NOTE: Code Case N-498-1 revises Code Case N-498 to allow for system inservice/functional tests in lieu of 10-year hydrostatic tests for Class 3 components and piping. This test methodology was previously granted for Class 1 and 2 systems under Code Case N-498. The NRC has approved the use of this code case at Palisades as documented in Reference 3.2.29.

5.1.2 ASME Class 2 and 3 components as determined by 10CFR50.55a and Regulatory Guide 1 .26 shall receive a hydrostatic test once per 10-year inspection interval and a system inservice/functional test at normal operating pressure and temperature once per 3-113 year inspection period.

Per Code Case N-498-1, a System lnservice/Functional Test may be conducted as an alternative to the 10-year hydrostatic test provided that the boundary subject to test pressurization and VT-2 examination extends to all Class 2 and 3 components required to operate qr support system safety function up to and including the first normally closed valve, or valve capable of automatic closure, and that the pressurization hold time be at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components and 1 0 minutes for noninsulated components .

.NOTE:

• Code Case N-498-1 revises Code Case N-498 to allow for system inservice/functional test i.n lieu of--10-year hydrostatic tests for Class 3 components and piping. This test methodology was previously granted for Class 1 and 2 systems under Code Case N-498. The NRC has approved the use of this Code Case at Palisades as documented in Reference 3.2.29.

• 5.1.3 Pressure testing required by Technical Specifications 4.5.3 and 6.15 are described in Section 5.6.

5.1.4 See Attachment 2, "lnservice/Functional/Leakage Tests" for the third 10-year inspection interval system pressure testing schedule .

• PALISADES NUCLEAR PLANT Proc No EM 1 3 ENGINEERING MANUAL PROCEDURE Revision 2 Page 10 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM 5.2 GENERAL REQUIREMENTS 5.2.1 Test Description

a. 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 accordance with Section 5.2.3 to detect leakages. The required system pressure tests and examinations, as referenced in Table IWA-5210-1, may be conducted in conjunction with one or more of the following system tests or operations:

1. A system leakage test conducted following opening and reclosing of a component in the system after pressurization to nominal operating pressure. This test applies to ISi Class 1 components.

2. A system functional test conducted to verify operability in systems (or components) not required to operate during normal Plant operation while under system operating pressure. The High and low Pressure Safety Injection Sys_t~ms are an.example of syst_en:is whi~h WO!.Jld _receive a system functional test. -

3. A system inservice test conducted to perform visual examination VT-2 while the system is in service under operating pressure. The Service Water System is an example of a system which would receive a system inservice test.

4. A system hydrostatic test conducted during a Plant

• shutdown at a pressure above nominal operating pressure or system pressure .for which overpressure protection is provided.

5. A system pneumatic test conducted in lieu of a hydrostatic pressure test for components within the scope of IWC a_nd IWD. (Class 2 and 3 systems)

PALISAPES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEPURE Revision 2 Page 11 of 37

• TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

b. Pressure and Temperature (IWA-5212)

1. System leakage tests and system hydrostatic tests shall be conducted at the test conditions of pressure and temperature specified in Sections 5.3, 5.4, and 5.5.

2. For the purpose of the test, the level of system pressure and temperature indicated or recorded by normal operating system instrumentation, or alternatively by test instrumentation, is acceptable.

3. Per IWA-5212(c), test conditions should be maintained essentially constant over the course of the visual examination.

a) If the pressure is lost during the hold time, the test shall be placed on hold, the .effect of loss on insulation soak shall be evaluated; and the test conditions restored. It is not necessary to restart the hold time at the beginning if the evaluation indicates no substantial effect on insulation soak.

b) Should test conditions be-lost*during the VT-2 examination, the test shall be* placed on hold until test conditions can be restored. It is not necessary to repeat examinations completed prior to the loss of test conditions.

4. > When conducting system tests described in Steps 5.2.1 a.4 and 5.2.1a.5, the requirements of Section 5.2.4 shall be met.

c. Test Condition Holding Time ~IWA-5213)

The holding time after pressurization to test conditions, before the visual examinations commence, shall be as follows:

1. System leakage tests - no holding time required after attaining test pressure and temperature conditions .

2. System functional tests - 1 0-minute holding time required after attaining the system operating pressure.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 12 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

3. System inservice tests - no holding time required, provided the system has been in operation for at least four hours.

4. System hydrostatic tests - four-hour holding time required after attaining the test pressure and temperature conditions for insulated systems, and 10 minutes for noninsulated systems or components.

5. System pneumatic tests minute holding time required after attaining the test pressure.

d. Repairs and Replacements (IWA-5214)

1. A component repair or replacement shall be pressure tested prior to resumption of service if required by IWA-4 700 or this procedure. All pressure tests shall be documented on a VT-2 Checklist as contained in Engineering Manual Procedure EM-09-14, "VT-2 Examinations."

2. The test pressure and temperature for a system hydrostatic test, subsequent to the component repair or replacement, shall comply with the system test pressure and temperature

~p'ecified in- Sections 5.3;* S.4, .and 5.5, as a*pplicaole to the system which contains the repaired or replaced* component.

3. Where repaired or replaced components are isolatable within a portion of the system, only that portion need be pressure tested. * -

4. Where the system hydrostatic test of Step 5.2.1 d.2, above, imposes system conditions which conflict with limitations included in the Plant Technical Specifications, a system inservice test [IWA-5211 (c)] at nominal operating temperature shall be acceptable in lieu of the system hydrostatic test.

5. If only disassembly and reassembly of mechanical joints of a component are involved (eg, bolted flange connection), a system pressure test of Steps 5.2.1 a.1, 2, or 3 shall be performed if disassembly and reassembly involves a Section XI repair or replacement.

PALISAPES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2

• Page 13 of 37

• TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

6. In accordance with IVVB-1220, IWC-1221, certain safety I Class 1 and 2 components may be exempted from I volumetric and surface, including VT-2 examination IE..

requirements based on size. I

7. Per Code Case N-41 6-1 , a system leakage test may be used in lieu of the hydrostatic pressure test required by IWA-4000 for welded repairs or installation of replacement items by I

welding, provided the following requirements are met:

• a) NOE shall be performed in accordance with the methods and acceptance criteria of the applicable Subsection of 1992 Edition of Section Ill.

b) Prior to, or immediately upon return to' service, a VT-2 visual examination shall be performed in conjunction with a system leakage test, using the 1992 Edition of Section XI, in accordance with IWA-5000, at nominal

• operating pressure and temperature.

c) *Use of this alternative shall be documented on a NIS-2 Form and identified as use of Code Case NA 16-l. ' -** ** * ,, --

• d) When (Surface* examination methods) NOE i's to be conducted per Subsection ND-5222 on a Code Class 3 componen.ts, an additional surface examination shall be performed on the root (pass) layer.

e) When Code Class 3 repair or replacement activities involve socket/fillet welds, a surface examination shall be performed on the subject socket/fillet welds.

If the original Code Case N-41 6 was used to defer a Class 2 hydrostatic test, the deferred test may be eliminated when the requirements of Code Case N-*4 1 6- 1 have been met.

Use of N-41 6- l shall be invoked by a controlling document, such as, a Facility Change, Specification Change, Work Order, etc.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 14 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM NOTE: Code Ca~e N-A 1 6-1 supersedes Code Case N-41 6 to allow for a system leakage test in lieu of the hydrostatic test for post repair/replacement purposes. The NRC has approved the use of this code case at Palisades as documented in Reference 3.2.28.

5.2.2 Test Pressurization Boundaries UWA-5220)

The boundary limits are generally defined by the location of the safety class interface valves within the system.

a. System Leakage Test Boundary (IWA-5221)

The boundary subject to test pressurization during a system.

leakage test (Step 5.2.1 a.1) shall extend to the pressure retaining components within the system boundary containing pressurized reactor coolant under the Plant mode of normal reactor startup.

b. System Functional Test Boundary (IWA-5222)

The boundary subject to test pressurization during a system functional test (Step 5.2.1 a.2) shall include only those pressure retaining ,componenis ..within the _system bo1.m,dary pr~ss.uriz~d.

under the test mode -required during: ttie, performanGe of a *p~riodic system (or component) functional test. *

c. System lnservice Test Boundary (IWA-5223)

The boundary subject to test pressurization during a system inservice test (Step 5.2.1 a.3) shall extend to those pressure retaining components under operating pressures during normal system service.

d. System Hydrostatic Test Boundary (IWA-5224)

1. The boundary subject to test pressurization during a system hydrostatic test (Step 5*:2.1 a.4) shall be defined by the system boundary (or each portion of the boundary) within which the components have the same minimum required classification and are designed to the same primary pressure rating as governed by the system function and the internal fluid operating conditions, respectively.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 15 of 37

• TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

2. Systems which share safety functions for different modes of Plant operation and within which the component classifications differ shall be subject' to separate system pressure tests of each portion of the system boundary having the same minimum required component classifications.

3. Systems designed to operate at different pressures under several modes of Plant operation or post accident conditions shall be subject to a system pressure test within the test boundary defined by the operating mode with the higher pressure.

4. Where the respective system primary pressure ratings on the suction and discharge sides of system pumps differ, the system test boundary shall be divided into two separate boundaries (such as suction side and discharge side test boundaries). In the case of positive displacement pumps, the boundary interface shall be considered as the pump. In the case of centrifugal pumps, the boundary interface shall be the first shutoff valve on the discharge side of the pump.

e. Color Coded P&IDs The inservice inspection color coded P&IDs provide the boundaries

• for Palisades Class 1, 2, and 3 systems. These drawings are maintained in Document Control and provide a basis for the test boundaries contained in Plant pressure testing procedures.

5.2.3 Visual Examjoatjoo UWA-52401

a. Noninsulated Components (IWA-5241)

1. The visual examination VT-2 shall be conducted in accordance with Engineering Manual Procedure EM-09-14, "VT-2 Examinations," by examining the accessible external exposed surfaces of pressure retaining components for evidence of leakage.

PALISAPES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEPURE Revision 2 Page 16 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

2. For components whose external su"rfaces are inaccessible for direct visual examination VT-2, only the examination of surrounding area (including floor areas or equipment surfaces located underneath the comp*onents) for evidence of leakage shall be required.

b. Insulated Components (IWA-5242)

1. For systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolted connections for visual examination VT-2. For other components, visual examination VT-2 r:nay be conducted without the removal of insulation by examining the 1 accessible and exposed surfaces and joints of the insulation ..

Essentially vertical surfaces of insulation need only be examined *at the lowest elevation where leakage may be

• 2.

detectable. Essentially horizontal surfaces of insulation shall be examined at each insulation joint.

When examining insulated components, the examination of surrounding area (including floor areas or equipment surfaces located underneath the, components) for evidence of leakage, or other areas to which such reakage -may be channeled, shall be required.

3. Discoloration or residue on surfaces examined shall be given particular attention to detect evidence of boric acid accumulations from borated reactor coolant leakage.

c. Components With .Leakage Collection Systems (IWA-5243)

Where leakages from components are normally expected and collected (such as valve stems, pump seals, or vessel flange gaskets), the visual examination VT-2 shall be conducted by verifying that the leakage collection system is operative .

PALISAPES NUCLEAR PLANT Proc No EM 1 3 ENGINEERING MANUAL PROCEDURE Revision 2 Page 17 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

d. Measuring Leak Rates Leakage should be measured in one-minute increments for two minutes or more, unless the leakage exists in an area where the radiation exposure to the Examiner would be excessive. It is left to the Examiner's judgement whether or not to measure the leakage in radiation areas to obtain representative leak rates. The measurements should be averaged to give leak rate per minute.

e. Buried Components (IWA-5244)

1. In nonredundant systems where the buried components are insolable by means of valves, the visual examination VT-2 shall consist of a leakage test that determines the rate of pressure loss. Alternatively, the test may determine the change in flow, between the ends of the buried components.

The acceptable rate of pressure loss or flow shall be established by the Owner.

2. In redundant systems where the buried components are noninsolable, the visual examination VT-2 shall consist of a test that determines the change in flow between the ends of the buried- components. In cases where an annulus surrounds the buried components, the areas at each end of the buried components shall be visually examined for evidence of leakage iri lieu of a flow test.

3. In nonredundant systems where the buried components are nonisolable, such as return lines to the heat sink, the visual examination. VT-2 shall consist only of a verification that the flow during operation is not impaired.

f. Elevated Temperature Tests (IWA-5245)

The visual examination of system components requiring a test temperature above 200°F during the system pressure test may be conducted after the pressure holding period of Step 5.2.1 c is satisfied, and the pressure is lowered to the level corresponding with a temperature of 200°F, in accordance with allowable cooldown rates established by fracture prevention criteria.

PALISAPf;S NUCLEAR PLANT Proc No EM 1 3 ENGINEERING MANUAL PROCEDURE Revision 2 Page 18 of 37 TITLE: INSERVICE- INSPECTION PRESSURE TESTING PROGRAM

g. Repaired or Replaced Components and Alteration of a System (IWA-5246).

The visual examination VT-2 following a repair or replacement of a component or the alteration of a system may be limited to the repaired qr replaced components or the altered portion of the system, but shall include any connection made to the existing system.

h. Visual Examination Program req1,Jirements are outlined in Engineering Manual Procedure EM-09-14, "VT..:2 Examinations."

i. The Authorized Nuclear lnservice Inspector (ANll) shall be notified immediately prior to performance of VT-2 Examinations associated with Technical Specification Surveillance or SpeCial Test Procedures.

5.2.4 Instruments for Pressure Tests CIWA-5260)

The requirements of this section shall be met for hydrostatic testing (5.2.1 a4)) and pneumatic testing (5.2.1 a5) except when performing a system leakage, fu11ctional or inservice test in lieu_ of. the 1__Q~y"~~r system _

_ hydrostatic- test per--Code Case N-498~ 1. The 'requirements of thls section are optional for periodic system leakage (5.2.1 a1), functional (5.2.1 a2) or inservice tests (5.2.1 a3).

a. Type (IWA-5261)

Any pressure measuring instrument or sensor, analog or dtgital, including the pressure measuring instrument of the normal operating system instrumentation (such as Control Room instruments), may be used provided the requirements of this section are met.

b. Accuracy (IWA.;5262)

The pressure measuring instrument or sensor used in pressure testing shall provide results accurate to within 0.5% of full scale for analog gauges and 0.5% over the calibrated range for digital instruments.

PALISAPES NUCLEAR PLANT Proc No EM-09-13

. ENGINEERING MANUAL PROCEDURE Revision 2 Page 19 of 37

• TITLE: INSERVICE INSPECTION PRESSURE_ TESTING PROGRAM

c. Calibration (IWA-5263)

All pressure measuring instruments shall be calibrated in accordance with Palisades Administrative Procedures 5.04, "Control of Installed Plant Instrumentation," and 5.07, "Control of Measuring and Test Equipment," against a standard dead weight tester or a calibrated master gauge. The test gauges shall be calibrated before eaqh test or series of tests. A series of tests is a

• group of tests that use the same pressure measuring instruments or

• gauges and that are conducted within a period not exceeding two weeks. *

d. Ranges {IWA-5264)

1. Analog pressure gauges used in testing shall have dials graduated over a range of at least 1 .5 ti.mes, but not more than 4* times the intended maximum test pressures.

2. Digital pressure measuring instruments used in testing shall be selected such that the intended maximum test* pressure shall not exceed 70% of. the calibrated range of the instrument.

e. Location {IWA-5265)

1. When testing an isolated component, the pressure measuring in~trument or sensor shall be con11ected close, to the component.

2. When testing a group of components or a multicomponent system, the pressure measuring instrument or sensor shall be connected to any point within the pressure boundary of the components or system such that the imposed pressure on any component, including static head, will not exceed 106%

of the specified test pressure for the system,

f. The test instrumentation requirements of Section 5.2.4 {IWA-5260) are not applicable when performing a system leakage, functional, or inservice test in lieu of the 10-year system hydrostatic test per Code Case N-498-1 .

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 20 of 37 TITLE: INSERVICE* INSPECTION PRESSURE TESTING PROGRAM NOTE: Code Case N-498-1 revised Code Case N-498 to allow for system inservice/functional tests in lieu of 10-year hydrostatic tests for Class 3 components and piping. This test methodology was previously granted for Class 1 and 2 systems under Code Case N-498. The NRC has approved the use of this code case at Palisades as documented in Reference 3.2.29.

5.3 REQUIREMENTS FOR CLASS 1 PRESSURE TESTING (IWB-5000) 5.3.1

• UWB-5210)

a. The pressure retaining components shall be tested at the frequency stated and visually examined by the method specified in Table IWB-2500-1, Examination Category 8-P:

1. System leakage test, Step 5.2.1 a.1

2. System hydrostatic test, Step 5.2.1 a.4

b. The system pressure tests and visual examination shall be conducted in accordance with Sections 5.2 and 5.3. Reactor

. coolant shall be us.ed as. the_ pressurizing me,dium.

11

c. Code Case N-498-1 , Alternate Rules for 10 Year Hydrostatic 11 Testing for Class* 1 and 2 Systems

1. In accordance with ASME Section XI, a system leakage test per Step 5.2.*1 a.1 is a suitable alternate to the ten-year hydrostatic test when the following occurs:

a) The system leakage test shall be conducted at or near the end of each inspection interval, prior to reactor startup.

b) The boundary subject to test pressurization during the system leakage test shall extend to all Class 1 pressure retaining components within the system boundary.

PALISADES NUCLEAR PLANT Proc No EM 1 3 ENGINEERING MANUAL PROCEDURE Revision 2 Page 21 of 37

• TITLE:

• INSERVICE INSPECTION PRESSURE TESTING PROGRAM .

c) Prior to performing VT-2 visual examination .. the system shall be pressurized to nominal operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for noninsulated systems. The system shall be maintained at nominal operating pressure during the performance of the VT-2 visual examination.

d) Test temperatures and pressures shall not exceed limiting conditions for hydrostatic test curve as contained in Technical Specification 3.1.

e) The visual examination shall include all components within the boundary identified in (b) above.

f) Test instrumentation requirements of Section 5.2.4 are Il.Q1 applicable.

5.3.2 Pressure UWB-5220)

a. System Leakage Test (IWB-5221)

l.

• The system leakage* test shall be conductea at a test

. pressure not less than the nominal operating pressure associated with 100% rated reactor power.

2. The system test pressure and temperature shall be attained at a rate in accordance with the heat-up limitations specified for the system.

b. System Hydrostatic Test (IWB-5222)

1. The system hydrostatic test may be conducted at any test pressure specified in Table IWB-5222-1 (below) corresponding to the selected test temperature, provided the requirements of Section 5.3.3 are met for all ferritic steel components within the boundary of the system (or portion of system) subject to the test pressure (see Step 5.2.3e) .

PALISADES NUCLEAR PLANt Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 22 of 37 TITLE: INSERVICE INSPECTION PRESSURE . TESTING PROGRAM

2. -.yYhenever a system hydrostatic test is conducted in. which the reactor vessel contains nuclear fuel and the vessel is within the system test boundary, the test pressure shall not exceed the limiting conditions specified in the Plant Technical Specifications.

3. The pressure measuring instrument used for measuring system hydrostatic or pneumatic test pressure shall meet the requirements of Section 5.2.4.

TABLE IWB-5222-1 TEST PRESSURE TEST TEMPERATURE, °F TEST PRESSURE 100 or less l.10 Po 200 1.08 Po 300 1.06 Po 400 1.04 Po 500 or greater 1.02 Po NOJES: 1. P0 :*is the nominal operating pressure correspondingc with

. 1 00 % rat'ed reactor power.

2. Linear interpolation at intermediate test temperatures is permissible.

5.3.3 Temperature UWB-5230>

a.

• The minimu'11 test temperature for either the system l~akage or system hydrostatic test shall not be lower than the minimum temperature for the associated pressure specified in the Plant Technical Specifications.

b. The system test temperature shall be modified, as required, by the results obtained from each set of material surveillance specimens withdrawn from the reactor vessel during the service lifetime .

PALISADES NUCLEAR PLANT Proc No EM-09-1 3 ENGINEERING MANUAL PROCEDURE Revision 2 Page 23 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

c. For tests of. systems or portions of systems constructed entirely of austenitic steel, test temperature limitations are not required to meet fracture prevention criteria. In cases where the components of the system are constructed of ferritic and austenitic steels that are nonsolable from each other during a system leakage or system hydrostatic test, the test temperature shall be in accordance with Step 5.3.3a above.

5.3.4 Reactor Vessel Examinations The area under the reactor vessel is extremely hazardous when the Primary Coolant System is at full temperature and pressure. Personnel are not required to access this area for the purposes of pressure testing leak examinations. Leakage from this area shall be determined in accordance with Step 5.2.3e.1 by performance of a PCS leak rate calculation in accordance with System Operating Procedure SOP 1, "Primary Coolant System." (Reference System Pressure Testing Relief Request PR-02 in Attachment 4.)

5.4 REQUIREMENTS FOR CLASS 2 PRESSURE TESTING (IWC-5000).

5.4.1 Test UWC-521 Ol

a. The pressure retaining components within each system boundary shall be _subjected to the following system pressure tests and visually examined by the method specified in Table IWC-2500-1, Examination Category C-H:

1. A system pressure test conducted during a syste~ functional test of Step 5.2.1 a.2 systems (or components) not required to operate during normal Plant operation, but for which periodic system (or component) functional tests are performed to meet the Owner's requirements.

2. A system pressure test conducted during a system inservice test; Step 5.2.1 a.3, for those systems required to operate during normal Plant operation.

3. A system hydrostatic pressure test, Step 5.2.1 a.4, for each system or portions of systems, and for repaired or replaced components or altered portions of systems.

PALISAPES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 24 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

b. Th~ system pressure tests and visual examinations shall be conducted in accordance with Section 5.2 and 5.4. Normal system fluid shall be used as the pressurizing medium, except in steam systems, where either water, steam or air may be used. When air is used, the test procedures shall permit for the detection and location of through-wall leakage in the components being tested.

c. Code Case N-498, "Alternate Rules for 10 Year Hydrostatic Testing for Class 1 and 2 Systems"

1. In accordance with ASME Section XI, a system functional/inservice tests per Step 5.2.1 a.2 or 5.2.1 a.3 are suitable alternatives to the ten-year hydrostatic test when the following occurs:

a) The system pressure test shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection interval of Inspection Program B (IWA-2432).

b) The boundary subject to test pressurization during the systeni pressure test shall extend to all Cl~ss 2 co'mpc>nents -included in those- portions of systems required to operate or support .the safety system function up to and _including the first normally closed valve (including a safety or relief valve) or valve capable of automatic closure when the safety function is required.

c) Prior to performing VT-2 visual examination, the system shall be pressurized to nominal operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for noninsulated systems. The system shall be maintained at nominal operating pressure during the performance of the VT-2 visual examination.

d) The visual examination shall include all components within the boundary identified in (b) above.

e) Test instrumentation requirements of Section 5.2.4 are ru21 applicable.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 25 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

d. Code Case N-522, "Pressure Testing of Containment Penetration Piping."

For pressure testing piping that penetrates a containment vessel, when 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; 1 OCFR50, Appendix J Leakage Testing shall be used as an alternative to the system functional, inservice, and hydrostatic tests required by Table IWC-2500-1, Category C-H.

NOTE: Code Case N-522 allows for 10CFR50, Appendix J testing to take credit for Section XI, Table IWC-2500-1, Category C-H pressure testing of Class 2 containment penetration piping and valves where the balance of the piping syste'm is outside the scope of Section XI.

5.4.2 Pressure UWC-5220)

• a. System Functional Test (IWC-5221 a)_

The nominal operating pressure of the system functional test shall be acceptable as the system test pressure.

b. System lnservice Tes_~ OW.C-522-1 b) ,

The nominal operating pressure during system operation shall be

'acceptable as the test pressure for the system inservice test.

c. System Hydrostatic Test (IWC-5222)

1. The system _hydrostatic test pressure shall be at least 1 . 10 times the system pressure for systems with design temperature of 200°F or less, and at least 1.2.5 times the system pressure for systems with design temperature above 200°F. The system pressure shall be the lowest pressure setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested. For systems (or portions of systems) not provided with safety or relief valves, the system design pressure shall be substituted for safety or relief valve set pressure.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 26 of 37 TITLE: INSERVICE INSPECTION -PRESSURE TESTING PROGRAM

2. In the case of atmospheric storage tanks, the hydrostatic head, developed with the tank filled to its design capacity, shall be acceptable as the test pressure. For 0 - 15 psi storage tanks, the test pressure shall be 1 . 1 PG design pressure of vapor or gas space above liquid level for which overpressure protection is provided by relief valve.

3. For the purpose of the test, open-ended portions of suction or drain lines from a storage tank extending to the first shutoff valve shall be considered as an extension of the storage tank.

4. For open-ended portions of discharge lines beyond the last shutoff valve in nonclosed systems (eg, containment spray header), demonstration of an open flow path* shall be acceptable in lieu of system hydrostatic test .

• 5.4 ..3

5. The pressure measuring instrument used for measuring system hydrostatic or pneumatic test pressure shall meet the requirements of Section 5.2.4.

Temperature UWC-5230}

a. The system test temperature during a system hydrostatic test in systems containing ferritic steel components shall meet the requirements specified by fracture prevention criteria.

b. In systems containing ferritic steel components for which fracture toughness requirements were neither specified nor required in the construction of the components, the system test temperature shall be determined by the Owner.

c. No limit on system test temperature is required for systems comprised of components constructed entirely of austenitic steel materials .

PALISADES NUCLEAR PLANT Proc No EM 13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 27 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM 5.5 REQUIREMENTS FOR CLASS 3 PRESSURE TESTING (IWD-5000) 5.5.1 Test CIWD-52101

a. The pressure retaining components within the boundary of each system specified in the examination categories of Table IWD-2500-1 shall be pressure tested and examined in accordance with Table IWD-2500-1 during the following tests:

1. System inservice test, Step 5.2.1 a.3

2. System functional test, Step 5.2.1 a.2

3. System hydrostatic test, Step 5.2.1 a.4

b. The system hydrostatic test shall be conducted in accordance with Section 5.2, as applicable. The contained .fluid in the system shall serve as the pressurizing medium.

c. Code Case N-498-1, "Alternate Rules for 10 Year Hydrostatic Testing for Class 1, 2, and 3 Systems."

1.. In accordance with ASME Section XI, system functional/inservice tests per Step 5.2.1 a.2 or 5.2.1 a.3 are suitable alternatives to the ten-year hydrostatic test when the following occur:

a) The system pressure test shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection interval of Inspection Program B (IWA-2432).

b) T.he boundary subject to test pressurization during the system pressure test shall extend to all Class 2 components included in those portions of systems required to operate or support the safety system function up to and including the first normally closed valve (including a safety or relief valve) or valve capable of automatic closure when the safety function is required.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEPURE Revision 2 Page 28 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM -

c) Prior to performing VT~2 visual examination, the system shall be pressurized to nominal operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems a*nd 10 minutes for noninsulated systems. The system shall be maintained at nominal operating pressure during the performance of the VT-2 visual examination.

d) The visual examination shall include all components within the boundary identified in b) above.

e) Test instrumentation requirements of Section 5.2.4 are Il.Q1 applicable.

5.5.2 Pressure UWP-52201

a. System lnservice Test (IWD-5221)

The inservice operating pressure during system operation shall be acceptable as the system test pressure.

b. System Functional Test (IWD-5222)

The nominal operating pressure of the system functional test shall be acceptable as the system test pressure.

c. System Hydrostatic Test (IWD-5223)

1. The system hydrostatic test pressure shall be at least 1 . 1 0 times the system pressure for systems with design temperature of 200°F or less, and at least 1 .25 times the system pressure for systems with design temperature above 200°F. The system pressure shall be the lowest pressure setting among the number of safety or relief valves provided for overpressure *protection within the boundary of the system to be tested. For systems (or portions of systems) .

not provided with safety or relief valves, the system design pressure shall be substituted for safety or relief valve set pressure.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEPURE Revision 2 Page 29 of 37

• TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

2. In the case of atmospheric storage tanks, the hydrostatic head developed with the tank filled to its design capacity, shall be acceptable as the test pressure. For 0 - 1 5 psi storage tanks, the test pre~sure shall be 1 .1 PG design pressure of vapor or gas space above liquid level for which overpressure protection is provided by relief valve.

3. For the purpose of the test, open-ended portions of suction or drain lines from a storage tank extending to the first shutoff valve shall be considered as an extension of the storage tank. Discharge lines to structural compartments (eg, service water pump intake structures), collection tanks, sumps, and basins that are open (or may become open) to the atmosphere are considered open-ended.

4. For open-e_nded portions of discharge lines beyond the last shutoff valve in nonclosed systems (eg, service water systems) confirmation of adequate flow during system operation shall be acceptable in lieu of system hydrostatic test.

5. Open-ended vent and drain lines from components ext~nding b!=!vond _the last shutoff valve and open ended $_afety*'ot relief.

valve discharge lines shall be* exempt from hydrostatic test.

6. The pressure measuring instrument used for measuring system hydrostatiG or pneumatic test pressure shall meet the requirements of Section 5.2.4.

5.5.3 Temperature UWP-52301

a. The system test temperature during a system hydrostatic test in systems constructed of ferritic steel components shall satisfy either the requirements of fracture prevention criteria, as applicable, or the test temperature determined by the Owner.

b. For tests of systems or portions of systems constructed entirely of austenitic steel, test temperature limitations are not required to meet fracture prevention criteria .

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 30 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM 5.5.4 Due to Pl~nt configuration, it is not possible to inspect the external portions of Spent Fuel Pool welds. Therefore, in accordance with Step 5. 2. 3c, examinations for the Spent Fuel Pool shall be completed by observing Pool Leak Detection Isolation Valve MV-SFP501 located in the Fuel Pool Heat Exchanger Room.

5.6 REQUIREMENTS FOR NON ASME PRESSURE TESTING 5:6.1 Technical Specjfjcation 6. 1 5 "The licensee shall implement a program to reduce leakage from systems outside containment that would or could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. This program shall include the following:

a. Provisions establishing preventive maintenance and periodic visual inspection requirements.

b. Integrated leak test requirements for each system at a frequency not to exceed refueling cycle intervals.

Technical Specification Surveillance Procedures RT-7_1 B, RT-71 J, RT-7.1 _K, RT-7 H:, RT-7 lN, RT.~ 71 o,* and RT71 P serve to fulfill -

. Technical Specification 6.15 requirements for periodic leak testing and visual inspection.

5.6.2 Techojcal Specjfjcatjoo 4.5.3

a. The portion of the Shutdown Cooling System that is outside the Containment shall .be tested either by use in normal operation or hydrostatically tested at 255 psig at the interval specified in Technical Specification 6.15. Technical Specification Surveillance Procedures RT- 71 K and RT-7 lL serve to fulfill Technical Specification 4.5.3a.1 ).

b. Piping from valves CV-3029 and CV-3030 to the discharge of the safety injection pumps and containment spray pumps shall be hydrostatically tested at no less than 1 00 psig at the interval specified in Technical Specifications 6.15. Technical Specification Surveillance Procedure RT- 71 L serves to fulfill Technical Specifications 4.5.3a.2).

PALISADES NUCLEAR PLANT Proc No EM 1 3 ENGINEERING MANUAL PROCEDURE Revision 2 Page 31 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

5. 7 NONCONFORMANCES

5. 7. 1 If any through-wall leakage is identified from cracks or weld defects, the ISi Coordinator shall take the following action:

a. Declare inoperable the system or that portion of the system that contains the defect.

b. . Initiate a Condition Report.

c. The NRC has taken the position that as soon as it is known an acceptance criteria has not been met, the system component shall be declared inoperable and the Technical Specification action time started.

5.7.2 Any defects shall be retested after repair in accordance with ASME B&PV Code Section XI, 1 989 Edition, no addenda. Retests need not include the entire system originally tested, only the component which contained the defect.

5.7.3 Leakage that is not a through-wall recordable indication (ie, valve packing, pump seal, flange gasket, etc) shall be noted "For Information" and turned over* to_ the sy~tem engineer or_9peratipns to~ corrective actions .

. 5.7.4 For recirculation heat removal systems outside of containment, the total system leak rate shall be 0.2 gpm (756 ml/min), or less from components.

that are normally inspected for leaks such as seats, seals, valve stems, pump seals, vessel flange gaskets, and other mechanical joints.

This applies to Technical. Specification Surveillance Procedures RT- 71 8, RT-71 J, RT-71 K, and RT-71 L.

5. 7. 5 Corrective Measures UWA-52501

a. The source of leakages detected during the conduct of a system

. pressure test shall be located and evaluated by the Owner for corrective measures as follows:

1. Buried components with leakage losses in excess of limits acceptable for continued service shall be repaired or replaced.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 32 of 37

• TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

2. If leakage occurs at a bolted connection, the bolting shall be removed, VT-3 visually examined for corrosion, and evaluated in accordance with IWA-3100.

3. Repairs or replacements of components shall be performed in accordance with IWA-4000 or IWA- 7000 respectively and the Palisades Repair and Replacement Program (Palisades Administrative Procedure 9.06, "Code Requirements for Plant Maintenance and Modifications").

b. The detection of boric aci.d residues on ferritic steel components shall result in the following: *

1. The location and extent of leakage shall be d~termined.

2. A Boric Acid Inspection Checklist may be completed as required by Engineering Manual Procedure. EM-26, "Boric Acid Leak Inspection."

3. A work request shall be initiated for repair.

5. 8 ADMINISTRATIVE REQUIREMENTS

5. 8. 1 Procedure Development and Periodic Review

• All Technical Specification Surveillance Procedures associated with the Palisades Pressure Testing Program shall be developed in accordance with Palisades Administrative Procedures 9.20, "Technical Specification Surveillance and Special Test Program"; 10.51, "Writers Guideline for Procedures"; and 10.53, ... Use and Adherence of Procedures and Other Forms of Written Instructions."

5.8.2 Outage Preparation

a. Surveillance procedure scheduling and issue are, controlled by Palisades Administrative Procedure 9.20, "Technical Specification Surveillance and Special Test Program."

PALISADES NUCLEAR PLANT Pree No EM-09-13

• ENGINEERING MANUAL PROCEDURE Revision 2 Page 33 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

b. Per Technical Specifications 4.0.2, unless otherwise specified, each inservice pressure test surveillance requirement shall be performed within the specified time interval with:

1. A maximum allowable extension not to exceed 25% of the surveillance interval.

2. A total maximum combined interval time for any three consecutive surveillance intervals not to exceed 3.25 times the specified surveillance interval.

c. If a scheduled surveillance is not performed, the TSSPA shall complete a "Surveillance Not Done Justification" describing or justifying why the procedure was not performed. The reasons for

. the nonperformance should be determined by the Surveillance Scheduler, Program Coordinator, or group performing the surveillance. The Program Coordinator shall review the justification. This form is filed in lieu of a completed surveillance procedure.

d. Palisades ISi shall initiate planning for a given inservice inspection by:

1; Development and implementation of a preoutage schedule.

2. Component or piping changes documented in Facility Change files.

3. ASME B&PV Code,Section XI - This review also i!1cludes the Pressure Testing records from the previous outages to identify items which should be scheduled for subsequent outages. In addition, a review of examination versus ISi period requirements is*performed and documented in the ISi Master Plan.

4. Review of Relief Requests for application to the subject inspection or scheduling for subsequent outages. (See Attachment 4)

• 5. Review of Code Cases for application to the subject inspection and scheduling of any unique activities required.

PALISAPES NUCLEAR PLANT Proc No EM 1 3 ENGINEERING MANUAL PROCEPUBE Revision 2 Page 34 of 37 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

6. Identification and scheduling of Test Team groups required to prepare, conduct, and complete the inspection activities.

{See Sections 4.2.6 and 4.2. 7 .)

e. Preinspection Activities - Onsite activities are initiated by Palisades ISi review of. the work areas to determine preparation requirements.*

Examination crews are directed to appropriate Plant personnel for any required Plant indoctrination {Security, Radiation Protection, Confined Spare Training, VT-2). Palisades ISi shall conduct a review of personnel, equipment, and material certifications provided

• by the Examination Agencies. Palisades ISi provides coordination for any maintenance, radiation protection, or PRC support of onsite activities. Palisades Operations Dept VT-2 certifications are maintained per Engineering Manual Procedure EM-09-14, "VT-2 Examinations."

f. Notification - Palisades ISi shall notify the Enforcement Authority

{Michigan Department of Labor - Boiler Division) and the Authorized Inspection Agency of the scheduled Pressure Testing start dates.

The Authorized Nuclear lnservice Inspector {ANll) shall be notified reasonably in ad'Jance of the scheduled test to prepare to witness the inspection or review the test package and waive his attendance of the test.

5.8.3 Outage Performance

a. Technical Specification Surveillance Procedures shall be performed in accordance with Palisades Administrative Procedure 9.20, "Technical Specification Surveillance and Special Test Program."

. b. System inservice leak tests and hydrostatic tests shall be performed, as applicable, prior to startup following each reactor refueling outage.

c. Palisades ISi reviews and supports any Preservice Inspection Programs conducted by the various Plant or designated Engineering Department(s). Support is confined to review and comment on any proposed programs submitted. Involvements other than this shall

• be with the approval of the Engineering Programs Manager.

PALISADES NUCLEAR PLANT Proc No EM-09-1 3 ENGINEERING MANUAL PROCEDURE Revision 2 Page 35 of 37

• TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

d. Palisades ISi shall generate color coded P&IDs which identify the inspection boundaries for ASME Class 1, 2, and 3 systems. The ISi Boundary P&IDs are reviewed periodically for revision due to Plant modifications, redline changes, etc .. The ISi Boundary P&IDs are a controlled document subject to the applicable portions of Palisades Administrative Procedure 10.44, "Design Document Control and* Distribution."

Only redline changes to piping, pumps, valves, or other mechanical components in general must be reviewed for possible classification and subsequent color coding according to the steps below.

Editorial revision, electrical systems, and instruments in general are not applicable to this section and do not require completion .of the steps below:

1. ISi shall review redline revisions of Palisades Plant P&IDs to determine if the changes affect current ASME Class 1, 2, or 3 systems, or if complete system additions have been made.

2. If current ASME Class 1, 2, or 3 boundaries are affected or complete systems are added, the requirerpents of 1 OCFR50.55, Paragraph A, "Codes and Standards,"

.. Regt,1lat.ory Guide 1.26, Qu~lity Group* Classification arid .

. Standards for Water, Steam and Radioactive - Waste Containing Components of Nuclear Power Plants," are applied and the system is classified and color coded accordingly. If adequate boundary valves do not exist, classification boundaries must be justified with regard to capability to handle volume loss and/or water in the area of a postulated line break.

Upon receipt of Palisades P&ID revisions and completion of the ISi Review, one set shall be placed in DCC.

e. Palisades ISi shall administer the Pressure Test Program and coordinate Examination Agency(ies), Authorized Nuclear lnservice Inspector, State, and NRC activities. As work progresses, Palisades ISi compiles test results. Palisades ISi initiates changes in the procedures to facilitate performing additional testing or retesting, if necessary, due to reports or test failure.

PALISADES NUCLEAR PLANT Proc No EM-09-13 ENGINEERING MANUAL PROCEDURE Revision 2 Page 36 of 37

• TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM

f. After pressure testing has begun, the progress is monitored and res.ults reviewed to ensure al.I scheduled items are properly tested

• and inspected according to approved procedures. Palisades ISi keeps the Plant Planning and Scheduling Administrator appraised of testing and inspection progress and problems as they occur, as well as the status of evaluations and corrective actions whic,h must be completed prior to returning the Plant to service.

g. Any audit observations/findings conducted by the Authorized Nuclear lnservice Inspector, NRC, NPAD, or any designated audit group shall be dispositioned in accordance with the Plant's corrective action system.

5. 9 POST OUT AGE DOCUMENT A !ION

5. 9. 1 Test Records UWA-R300l The record of the visual examination conducted during system pressure tests shall include the procedure documenting the system test condition and system pressure boundary. Any source of leakage or evidence of structural distress shall be itemized and the location and corrective action documented .

. 5.9.2 - ISi Summarj Report -

a. Palisades ISi shall provide pressure testing examination results for inclusion in the ISi Report. These results shall be submitted in a timely fashion in order to support the 90-day deadline for submittal of the ISi Report. (Referei:ice IWA-6200)

b. The completed ISi Outage Plan, including all appendices, constitutes the completed ISi Record for the lnservice Inspection.

The ISi Record, which includes the ISi Summary Report, shall be entered into the Plant Document Control Center and the Uniform File Index within approximately 1 20 days of completion of the last

. onsite examination/test. The pressure testing results are part of this record. (Reference IWA-6300) c.. All pressure testing documentation concerning lnservice Inspection, not included in a or b above, is indexed and shall be entered into the Uniform File Index as 22*22*03/LP.

PALISADES NUCLEAR PLANT Proc No EM 1 3 ENGINEERING MANUAL PROCEDURE Revision 2 Page 37 of 37

• 6.0 TITLE: INSERVICE INSPECTION PRESSURE TESTING PROGRAM ATTACHMENTS ANP RECORDS 6.1 ATTACHMENTS 6.1.1 Attachment 1, "2nd Interval Pressure Test Record" 6.1.2 Attachment 2, "lnservice/Functional Tests, 3rd Interval" 6.1.3 Attachment 3, "Pressure Test Flow Chart" 6.1.4 Attachment 4, "System Pressure Testing Relief Requests" 6.1.5 Attachment 5, "Revision Summary" 6.2 RECORDS None

Proc No E -13 Attachment 1 2nd lr,JTERVAL PRESSURE TEST RECORD Revision 2 Page 1 of 2 PROCEDURE CLASS 1ST PERIOD 2ND PERIOD 3RD PERIOD TEST INTERVAL 11/10/83 - 09/10/88 09/11 /88 - 01 /11 /92 01 /12/92 - 05/11 /95 PRIMARY COOLANT SYSTEM '

COMPLETED COMPLETED COMPLETED 92 REFOUT RT-71A REFUELING 1 83 & 85 REFOUTS 88 & 90 REFOUTS COMPLETED 93 REFOUT also reference RT- 70F and RO- 70F HYDRO IN 95 REFOUT HIGH PRESSURE SAFETY INJECTION COMPLETED COMPLETED COMPLETED 92 REFOUT RT-718 REFUELING 1 & 2 83 & 85 REFOUTS 88 & 90 REFOUTS COMPLETED 93 REFOUT also reference RT-74 and R0-74 HYDRO IN 95 REFOUT CHEMICAL AND VOLUME CONTROL SYSTEM HYDRO IN 83 REFOUT COMPLETED 88 REFOUT COMPLETED 92 REFOUT RT-71C PERIOD 2 HYDRO IN 95 REFOUT

. also reference RO- 71 C MAIN STEAM AND FEEDWATER SYSTEM COMPLETED COMPLETED 88 REFOUT HYDRO IN 95 REFOUT RT-71E PERIOD 2 83 & 85 REFOUTS HYDRO IN 90 REFOUT also reference RO- 71 E COMPONENT COOLING WATER SYSTEM HYDRO IN 83 REFOUT COMPLETED 88 REFOUT COMPLETED 92 REFOUT RT-71F PERIOD 2&3 HYDRO IN 95 REFOUT also reference RO-71 L SERVICE WATER SYSTEM HYDRO IN 83 REFOUT COMPLETED 88 REFOUT COMPLETED 92 REFOUT RT-71G PERIOD 2&3 HYDRO IN 95 REFOUT also reference RO- 71 G-1 and RO- 71 G-2 SPENT FUEL POOL SYSTEM COMPLETED 83 REFOUT COMPLETED 88 REFOUT COMPLETED 92 REFOUT RT-71 H PERIOD 2&3 HYDRO IN 95 REFOUT also reference RO- 71 H-1 and RO- 71 H-2

• All Hydros were completed using Nuclear Code Case N-498-1 as an alternative.*

• 2nd INTERVAL PRESSURE TEST RECORD Proc No E Attachment 1 Revision 2 Page 2 of 2 PROCEDURE CLASS 1ST.PERIOD 2ND PERIOD 3RD PERIOD TEST INTERVAL 11/10/83 - 09/10/88 09/11 /88 - 01 /11 /92 01 /12/92 - 05/11 /95 AUXILIARY FEEDWATER SYSTEM

.COMPLETED 83 REFOUT COMPLETED 88 REFOUT COMPLETED 92 REFOUT RT-711 PERIOD 3 HY*DRO IN 95 REFOUT also reference RO- 711 CONTAINMENT SUMP

• COMPLETED 85 REFOUT COMPLETED COMPLETED 92 REFOUT RT-71J REFUELING 2 88 & 90 REFOUTS COMPLETED 93 REFOUT also reference RT-88 and R0-88 HYDRO IN *95 RE FOUT SHUTDOWN COOLING SYSTEM ':

COMPLETED 85 REFOUT COMPLETED COMPLETED 92 REFOUT RT-71 K REFUELING 2 88 & 90 REFOUTS COMPLETED.93 REFOUT also reference RT-88 and R0-88 HYDRO IN 95 REFOUT LEFT AND RIGHT CHANNEL ESS PUMP SUCTION

.COMPLETED 85 REFOUT COMPLETED COMPLETED 92 REFOUT RT-71L *REFUELING 2 88 & 90 REFOUTS COMPLETED 93 REFOUT also reference RT-88 and R0-88 HYDRO IN 95 REFOUT SIRW TANK AND CHEMICAL ADDITION COMPLETED 85 REFOUT COMPLETED COMPLETED 92 REFOUT RT-71M PERIOD 2 88 & 90 REFOUTS HYDRO IN 95 REFOUT also reference RT-88 and R0-88 PASM AND PCS SAMPLING COMPLETED COMPLETED COMPLETED 92 REFOUT RT-71N REFUELING N/A 83 & 85 REFOUTS 88 & 90 REFOUTS COMPLETED 93 REFOUT also reference RT- 78 and RC-78 I SCHEDULED 95 REFOUT CONTAINMENT AIR SAMPLING SYSTEM COMPLETED COMPLETED COMPLETED 92 REFOUT RT-710 REFUELING N/A

• 8.3 & 85 REFOUTS 88 & 90 REFOUTS COMPLETED 93 REFOUT also reference RT-798 and RO- 798 SCHEDULED 95 REFOUT RT-71P REFUELING N/A also reference RT- 79C and RO- 79C Hydros were completed using Nuclear Code Case N-498-1 a~ . ilternative.

Proc No E*-13 Attachment 2 INSEBVICE/FUNCTIONAL TESTS. 3BP INTERVAL Revision 2 Page 1 of 2 PROCEDURE CLASS 1ST PERIOD 2ND PERIOD 3RD PERIOD TEST INTERVAL 05/12/95 - 09/11/98 09/12/98 - 01 /11 /02 OJ/12/02 - 05/11/05 PRIMARY COOLANT SYSTEM SCHEDULE FOR 06, 07 RT-71A REFUELING *1 96,98 99,00,02 HYDRO IN 2007 HIGH PRESSURE SAFETY INJECTION SCHEDULED FOR 06, 07 RT-718 REFUELING 1 & 2 96,98 99,00,02 HYDR0 IN 2007 CHEMICAL AND VOLUME CONTROL SYSTEM RT-71 C PERIOD 2 *-:*

98 2002 HYDRO IN 2007 MAIN STEAM AND FEEDWATER SYSTEM RT-71 E PERIOD 2 98 2002 HYDRO IN 2007 COMPONENT COOLING WATER SYSTEM t RT-71 F PERIOD 2&3 . 98 2002 HYDRO. IN 2007 SERVICE WATER SYSTEM '

RT-71G PERIOD 2&3 98 2002 HYDRO IN 2007 SPENT FUEL POOL AND REACTOR CAVITY SYSTEM 98 2002 HYDRO IN 2007 RT-71H PERIOD 2&3 AUXILIARY FEEDWATER SYSTEM RT-711 PERIOD 3 98 2002 HYDRO IN 2007

INSERVICE/FUNCTIONAL TESTS. 380 INTERVAL Proc No E.13 Attachment 2 Revision 2 Page 2 of 2 PROCEDURE CLASS 1ST PERIOD 2ND PERIOD 3RD PERIOD TEST INTERVAL 05/12/95 - 09/11 /98 09/12/98 - 01 /11 /02 01 /12/02 - 05/11 /05 CONTAINMENT SUMP SCHEDULED FOR 06,07 RT-71J REFUELING 2 9~,98 99,00,02 HYDRO IN 2007 SHUTDOWN COOLING SYSTEM SCHEDULED FOR 06 RT-71 K REFUELING 2 ,. 96,98 99,00,02 HYDRO IN 07 LEFT AND RIGHT CHANNEL ESS PUMP SUCTION SCHEDULED FOR 06 RT-71 L REFUELING 2 96,98 99,00,02 HYDRO IN 07 SIRW TANK AND CHEMICAL ADDITION RT-71M PERIOD 2 98 2002 HYDRO IN 07 PASM AND PCS SAMPLING RT-71N REFUELING N/A 96,98 99,00,02 SCHEDULE FOR 06 & 07 CONTAINMENT AIR SAMPLING SYSTEM SCHEDULE FOR 06 & 07 RT-710 R.EFUELING N/A 96,98 99,00,02 SCHEDULE FOR 06 & 07 RT-71P REFUELING N/A 96,98 99,00,02

• Proc No E Attachment 3 Revision 2 Page 1 of 1

-13

• ,*PRESSURE TEST FLOW CHART THE ITEM IS CLASSIFIED AS CLASS 1, 2, OR 3 PER COLOR CODED P&ID1 NO PRESSURE TEST INTERVAL t:EST PERFORM LEAKAGE TEST PER N-498 NO PRESS TEST ITEM DURIHG IHTERVAL FOR REFUEL OUTAGE HYDRO TEST PER PERFORM SYSTEM 5.3, 5.4, OR 5.5, LEAKAGE TEST AS APPLICABLE PER 5.3.

PERFORM SYSTEM LEAKAGE TEST 5.2.1d.5 INTERVAL TEST PERFORM LEAKAGE JEST PER N-498 PERFORM SYSTEM YES PERIOD TEST PRESSURE TEST PERFORM SYSTEM PER N-418-1 LEAKAGE TEST PER 5.4 INTERVAL TEST

. PERFORM LEAKAGE YES TEST PER 5.5 PERIOD TEST PERFORM SYSTEM LEAKAGE TEST PER 5.5 TECH SPEC YES INTERVAL TEST 4.5.3 OR PERFORM LEAKAGE TEST PER 5.4 8.15 OR 5.6 PERFORM HYDROSTATIC TEST ON ISOLABLE PORTION OR SYSTEM CONTAINING THE ITEM 5.2.3g

Proc No EM 1 3 Attachment 4 Revision 2

• SYSTEM PRESSURE TESTING RELIEF REQUESTS Page 1 of 9 RELIEF REQUEST

SUMMARY

TABLE Relief I Request I . Page(s) I Summary I PR-01 2 thru 4 Alternate Testing for Class 1, Class 2, and Class 3 Welded Repaired/Replaced Components PR-02 5 thru 6 Alternate Testing for Components Under the Reactor Vessel PR-03 7 thru 9 10-Year Hydrostatic Pressure Test Requirements of Class 1 , 2, and 3 Systems

- I

Proc No EM-09-13 Attachment 4 Revision 2 Page 2 of 9 RELIEF REQUEST NUMBER: PR-01 (Page 1 of 3)

COMPONENT IDENTIFICATION Code Classes: 1, 2, and 3

References:

_IWA-4700(a), IWA-4700(b), IWA-5214 IWB-5222, IWC-5222, IWD-5223

Description:

Alternate Testing for Class 1, Class 2, and Class 3 Welded Repaired/Replaced Components.

Component Numbers: All Class 1, Class 2, and Class 3 pressure retaining components subject to Hydrostatic Testing per IWA-4700.

COPE REQUIREMENT The 1989 Edition of ASME Section XI, IWA-4700(a) requires a hydrostatic test to be performed per IWA-5000 after welded repair/replacement of classed components, except those exempted by IWA-4700(b).

A-5214 requires a pressure test per IWB-5222, IWC-5222, or IWD-5223, as applicable to the system ich contains the repaired or replaced component.

IWB-5222, IWC-5222, and IWD-5223, System Hydrostatic Test, require a Test Pressure of 1 ..02 to 1.10 times P0 for Code Class 1 components, 1.10 or 1.25 times Psv (or Pd or Pg) for Code Class 2 components, and 1.10 or 1.25 times Psv (or Pd or Pgl for Code Class 3 components, where P0 is the nominal operating pressure corresponding with 100.% rated reactor power,-Psv is the-lowest 'pre-ssi.ire

.. setting among *the safety or relief valves provided for overpressure protection within the boundary of the system:to be tested, Pd is the system design pressure, and Pg is design pressure of vapor or gas space above *liquid level within an atmospheric storage tank for which overpressure protection is provided by relief valves. '

• BASIS FOR RELIEF Pursuant to 10CFR50.55a(a)(3)(i), relief is requested on the basis that the proposed alternatives provide an acceptable level of quality and safety.

Due to the additional preparation required to safely accomplish the required System Hydrostatic Tests (at pressures above normal operating levels) after welded repairs and replacements on Code Class 1, 2, and 3 components, these tests present unusual difficulties and often hardship situations for Palisades Nuclear Plant.

Some of the specific problem~ typically encountered when preparing and performing these tests include:

• - Complicatetl or abnormal valve line-ups in order to properly vent, fill, and isolate the component requiring testing.

Proc No EM 1 3 Attachment 4 Revision 2 Page 3 of 9 RELIEF REQUEST N.UMBER: PR~Ot (Page 2 of 3)

BASIS FOR RELIEF (Cont'd)

- Relief valves with setpoints lower than the hydrostatic test pressure must be gagged or removed .

and blind flanged. This process requires the draining and refilling of the system both prior to the test and prior to system restoration.

- Valves that are not normally used for isolation (eg, normally open pump discharge valves) are often required to provide pressure isolation for an elevated pressure hydrostatic test. These valves frequently require time consuming seat maintenance in order to obtain a leak tight pressure boundary.

- The radiation exposure to Plant. personnel

. involved in hydrostatic tests is high in comparison to operational pressure testing due to the large amount of time required to prepare the volume for testing (ie, installing relief valve gags, performing appropriate valve line-ups, completing valve maintenance, filling and venting, etc).

The difficulties encountered in performing a hydrostatic pressure test are prohibitive when weighed against the benefits. Industry experience; which is supported by Palisades' experience, shows that most ,.

rough wall l~akage is detected during system operation as opposed to during elevated pressure tests

• uch as ten-year or post-maintenance system hydrostatic tests.

• No leakage detection benefit is gained, from the added challenge to the piping system provided by an elevated pressure hydrostatic test as compared to a system operational test. The stresses experienced during a hydrostatic test do not include the significant stresses associated with the thermal growth and dynamic loading seen during a system operational test. Thus, the ~yst~m.is more .likely to experience any

• througb_'Jli'all leakage,.at operating conditions due to the combination of dynamic/thermal loading and the normal op-erating pressure parameters than during the careful, slow pressurization of a hydrostatic .test.

These arguments are also supported by Code Case N-498, "Alternative Rules for 10-Year Hydrostatic Pressure Testing for Class 1 and 2 Systems,Section XI, Division 1." This relief request is a logical extension of that Code Case. Code Case N-498 is approved for use in Regulatory Guide 1.147, Revision 11. In addition, the ASME Board of Nuclear Codes and Standards has approved Code Case N-416-1, "Alternative Pressure Test Requirements for Welded Repairs or Installation of Replacement Items by Welding, Class 1, 2, and 3 Systems,Section XI, Division 1," which incorporates the logic and Alternative Examinations contained within this relief request.

Based on the above, Palisades Nuclear Plant requests relief from the ASME Section XI requirements for performing elevated pressure hydrostatic tests on Class 1, Class 2, and Class 3 repaired/replaced components .

Proc No EM-09-13 Attachment 4 Revision 2 Page 4 of 9 REl.IEF REQUEST NUMBER: PR-01 (Page 3 of 3)

PROPOSED AL TERN ATE PROVISIONS After welded repairs or installation of replacement items by welding, the following alternative requirements will be met in lieu of performing the hydrostati_c pressure test required per paragraph IWA-4000:

(a) NOE shall be performed in accordance with the methods and acceptance criteria of the applicable Subsection of the 1992 Edition of Section Ill.

(b) Prior to or immediately upon return to service, a visual examination (VT-2) shall be performed in conjunction with a system leakage test, using the 1992 Edition of Section XI, in accordance with paragraph IWA-5000, at nominal operating pressure and temperature.

(c) . Use of this Relief Request shall be documented on an NIS-2 Form.

(d) When NOE is to be conducted per .Subsection N0-5222 on a Code Class 3 component, an additional surface examination shall be performed on the root (pass) layer.

(e) When Code Class 3 repair or replacement activities involve socket/fillet welds, a surf ace examination shall be performed on the subject socket/fillet welds.

These methodologies are specified in Code Case N-416-1 as approved by the Board of Nuclear Codes and Standards, with the additional NOE of (d) and (e) above.

APPLICABLE TIME PERIOD Reliel is requested for the third ten-year interval of the lnservice Inspection Program for Palisades, which

~

I concludes in August 2005. Use of this Code Case has been approved by the NRC (TAC NO M91764)

I until Code Case N-416-1 is included in Regulatory Guide 1 .14 7 .

Proc No EM-09-13 Attachment 4 Revision 2 Page 5 of 9 RELIEF REQUEST NUMBER: PR-02 .

(Page 1 of 2)

COMPONENT .IDENTIFICATIQN Code Class: 1

References:

IWA-5211 Table IWA-5210-1 IW8-5210

. Table IW8-2500-1 Examination Category: 8-P

==

Description:==

Alternative Testing for Compone.nts Under the Reactor Vessel 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 ~est be performed in ccordance with Table IW8-2500-1, Category 8-P.

8-5210 states that the pressure retaining components shall be tested at the frequency given and

• visually examined by the method specified in Table IV\18-2500-1, Examination Category 8-P.

Table IW8-2500-1, Examination Category 8-P requires a system leakage test be performed each refueling outage on the pressure retaining boundary associated with normal rea.ctor start-up and a system hydrostatic test be performed each inspection interv~l-on the pre~sure ret~\nin_g boundary of all Class 1 component~-*

BASIS FOR RELIEF Pursuant to 10CFR50.55a(a)(3)(ii), relief is requested on the basis that the specified requirements above would result in hardship and unusual difficulty without a compensating increase i.n 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 reactor vessel is extremely hazardous when the Plant is at Hot Shutdown Conditions for system leakage testing. Radiation levels are expected to be greater than 5-10 rem/hr (on contact),

which is the maximum measured during cold shutdown. Assuming 2 persons at one hour per person in this area a total of 10 to 20 rem of dose would be received.

In addition to radiation concerns, access to the area under the vessel posses 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 nder these conditions would require significant ventilation for cooling. The access tube to this area is nly 30 inches in diameter. This size limits the amount of ventilation possible while allowing personnel access.

Proc No EM 13 Attachment 4 Revision 2 Page 6 of 9 RELIEF REQUEST NUMBER: PR-02 (Page 2 of 2)

PROPOSED AL TERNA TE 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 the conducting of Palisades' System Operating Procedure SOP 1, "Primary Coolant System (PCS)," which completes the PCS leak rate calculation. Plant Technical Specification 3.1.5 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 place 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 161 and are applicable at all times when the Primary Coolant System is greater than cold shutdown conditions.

APPLICABLE TIME PERIOD elief is requested for the third ten-year interval of the lnservice Inspection Program for Palisades, which ncludes in August of 2005.

Proc No EM-09-13 Attachment 4 Revision 2 Page 7 of 9 RELIEF REQUEST NUMBER PR-03 (Page 1 of 3)

Code Class: 1, 2, and 3

Subject:

10-Year hydrqstatic pressure test requirements for Class. 1, 2 and 3 systems.

• 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 1989 Edition A system hydrostatic pressure test (IWA-5211 d) 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), D-A, D-B, and*o-c (Cfass 3).

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 comple~e_ hydrostatic testing poses a risk to safeJy by isolating cooling-water from important Plant loads, such as, Spent Fuel Pool cooling anci"shutd9wn 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,

Proc No EM 1 3 Attachment 4 Revision 2 Page 8 of 9*

RELIEF REQUEST NUMBER PR-03 (Page 2 of 3)

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.

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 inhit:>itor 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).

he portion of Chemical .~nd Volume Control between the Clas-s 1 portion of letdown and the containment penetration has been designated as Class 3 in accordance with Regulatory Guide 1. ?6. The CVCS is designed 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 st~inless steeJ tp reduce corrosion con_cerns_; Chemistry* co'iitaminant lir.:nits are c_onsisteht witti that of the Primary Coolant System, bec*ause 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 operationaf 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 ANSl-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.

• Proc No EM-09-13 Attachment 4 Revision 2 Page 9 of 9 RELIEF REQUEST NUMBER PR-03 (Page 3 of 3)

It is 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 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 nominal operating pressure or system pressure for which overpressure protection is provided, as required by Table IWA-5210-1, Examination Categor.ies 8-P, C-H, D-A, D-8, 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 r IWA-521 ~(b). Where gauging niay be required and does not exist, the rules of IWA-5260 shall be ed.

Palisades shall continue to implement chemical control programs for safety systems. These programs shall be designed to assure system pressure boundary integrity by inhibiting erosion, corrosion, biofouling, MIC, and other identified degradation mechanis'ms.

• Palisades shall continue to maintain a Visual . Examination VT-2 :Program.

APPLICABLE TIME PERIOD Relief is requested for the third ten-year interval of the lnservice Inspection Program for Palisades, which concludes in August of 2005. Use of this Code Case has been approved by the NRC (TAC NO M91410) until the Code Case N-498-1 is included in Regulatory Guide 1 . 147.

• Proc No EM-09-13 Attachment 5 Revision 2 Page 1 of 3 REVISION

SUMMARY

Revision 0 - Initial Issue MRN-E-92-009

1. Reference to Technical Specification 3. 1 added in Step 3. 1 . 5.

2. References to Code Cases N-437 and N-498 added in Steps 3.2.29 and 3.2.30.

3. Added reference to Engineering Manual Procedure EM-09-14, "VT-2 Examinations," for description of VT-2 Program in Steps 5.2.3a.1 and 5.2.3g.

I

4. Add description of Code Case N-498 to Steps 5.3.1 band 5.4.1 b.

MRN-E-92-010

1. Added reference 3.2.29 to Regulatory Guide 1.147, Revision 9, "lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1."

2. Revise Step 4.1.13, "Code Cases" to reference Regulatory Guide 1.147.

3. Step 5.2.1 d.5 was revised to outline requirements for pressure testing when bolted connections are disassembled/reassembled, 'but no repairs or replacements were performed. *

4. Add Step 5.2.3h to provide* i.nstructions for performing notification points. Instructions were previously contained in Palisades Administrative Procedure 10.41, "Procedure Initiation and Revision," Attachment 5.

. 5. Added new Step 5.4.1 c to describe test program for Class 2 penetrations associated with nonclass systems.

6. Added Step 5.5.1 c to describe test program for Class 2 penetrations associated with Class. 3 systems.

7. Deleted previous Attachment 1 and replaced it with new Attachments 1 and 2. These attachments describe the pressure testing program schedule through the third inspection

• interval.

J Attachment 3, "Revision Summary," is new.

Proc No EM-09-13 Attachment 5 Revision 2 Page 2 ~f 3 REVISION

SUMMARY

Revision 1 -* Perioqic Review

1. Relief Request Basis, Attachment 4 has been drafted as required by D-PAL-93-246.

2. Section 5.1 is revised to direct readers to Section 5.6 for further tech spec required examinations.

3. Step 5.2.4e is added to describe color coded P&IDs as source of test boundaries.

4. Step 5.2.d is added to provide method for leak rate determination.

5. Revised Step 5.2.3h which still conforms to VP requirements.

6. Section 5.3.4 is added to address reactor vessel examination requirements.

More detail has been added to Step 5.6.1 regarding Tech Spec 6.15 program.

Reference to Boric Acid Leakage Program is added.

9. Attachments 1 and 2 are revised based on latest outage schedules.

10. Added Step 5.5.4 to describe method for examining Spent Fuel Pool.

Revision '2 - 3rd Interval ISi Program Update

1. Updated the Pressure Testing Program from the 1983 Edition, summer 1983 addendum,*

of ASME B&PV Code,Section XI, to the 1989 Edition, no addendum.

2. Incorporated the requirements *of Code Case N-416-1 for conducting post repair/replacement pressure tests.

• 3. Incorporated the requirements of Code Case N-498-1 for conducting 10-year interval pressure tests.

4. Incorporated the requirements of Code Case N-522 for conducting containment penetration pressure tests.

5. . Updated references to Revision 1 0 of Regulatory Guide 1 . 14 7 to Revision 11 .

6. Added "System Pressure Test" and "VT-2 Visual Examination" definitions.

Proc No EM 13 Attachment 5 Revision 2 Page 3 of 3

• REVISION

SUMMARY

7. Added the overview of the Test Team and Test Performance to the Palisades PTS responsibilities .

. 8. Restructured Section 5.1 to coincide with the *code Classification testing requirements.

9. Clarified the testing requirements within Section 5.2.1 d.5.

10. Updated Section 5.2.4 instrumentation requirements to the 1989 Edition of ASME B&PV Code,Section XI.

11 . Clarified the procedures meeting the requirements for Technical Specification testing in Section 5.6.

12. Added Section 5. 7. 3 to include provisions for reporting For Information Only indications.

13. Re-wrote Attachment 4 to define the 3rd 10-year Interval System Pressure Testing Relief Requests.