ML20012A104

Inservice Insp Hydrostatic Test Program for Class 2 & 3 Sys Conducted During First 10-Yr Inservice Insp Interval.

ML20012A104
Person / Time
Site:	FitzPatrick
Issue date:	03/01/1990
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20012A103	List: ML20012A102 ML20012A104
References
NUDOCS 9003080281
Download: ML20012A104 (19)

Text

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NEW YORK POWER AUTHORITY p

", JAMES A. FITZPATRICK NUCLEAR POWER PLANT r

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' INSERVICE INSPECTION llVDROSTATIC TEST PROGRAM FOR CLASS 2 AND 3 SYSTEMS CONDUCTED DURING Tile F1RST 10 YEAR INSPECTION INTERVAL ,

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NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 l

l 9003000281 900301 PDR ADOCK OS000333; 1 PNU ' '

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' INSERYlCE INSPECTION llYDROSTATIC TEST PROGIIAM y..e ,

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TABLE OF CONTENTS

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SECTION' PAGE L INTRODUCTION 3-

2. ' SCOPE OF TESTING 3-

- 3.

SUMMARY

OF TEST METilODS 3 4c TEST RESULTS . 3

5. REQUESTS FOR RELIEF FROM CODE REQUIRED EXAMINATIONS

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4 TABLES 1-1

SUMMARY

OF HYDROSTATIC TESTS PERFORMED DURING Tile - 5 FIRST 10-YEAR INSPECTION INTERVAL

~ 21 ' SYSTEMS CONTAINING ISI CLASS 2 COMPONENTS 7

- ATTACHMENTS

1. IlYDROSTATIC RELIEF REQUESTS 8

- II. JUSTIFICATION FOR DELETION OF CLASS Il AUGMENTED 18 AIR / NITROGEN SYSTEMS FROM Ti!E ISI PROGRAM b

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1.- INTRODUCTION To meet the requirements of the ash 1E Boiler and Pressure Vessel Code,Section XI,1974 Edition -; '

through the Summer 1975 Addenda, the Authority performed hydrostatic tests for the first 10-year inspection interval on ISI Class 2 and 3 systems at the James A. FitzPatrick Nuclear Power Plant.

Relief is requested for those cases in which AShiE Section XI,1974 Edition through Summer 1975 Addenda requirements are impractical. In some cases, reliefis requested to allow use of the requirements of the 1980 Edition through Winter 1981 Addenda of the cot'a, Visual examLiations (VT-2) were performed to verify the integrity of the piping systems by personnel e qualified / certified to ANSI N45.2.6. These inspections were performed in accordance with New York j

3 P Power Authority Ouality Assurance (QA) approwd non destructive examination procedures. Table 1 1 identifies the hydrostatic tests that were performed during the first 10-year inspection interval.  :

2. SCOPE OF TESTING - -.

The systems subject to testing include all components identified as ISI Class 2 and the Reactor Core '

lsolation Cooling System (ISI Class 3). The system test beundaries and ISI classification utilized were I__ based on the FitzPatrick Plant ISI Program plan boundary diagrams for the second inspection interval.

The boundary diagrams for the second 10-year interval were used as they were revised to reflect the as built conditions of the plant. The systems containing Class 2 components are listed in Table 2-1.

3. SUhthiARY OF TEST htETHODS ash 1E Section XI requires the system testing pressure to be equal to or greater than 1.25 times the system design pressure. The FitzPatrick plant's origiaal construction code (ANSI B31.1,1%7 Section i 137.4.1) states, *The test pressure for the piping shall not exceed the maximum test pressure of any vessels or components in the piping system." Therefore, all system test pressures were based upon the lesser of the limiting component pressure limit or the ash 1E Section XI test pressure.

Systems designed to use a gas as the process medium were tested using air as n pressurizing medium and a liquid bubble solution (SNOOP) for leakage detection.

In accordance with AShiE Section XI,1974 Edition through the Summer 1975 Addenda, Subsection IWC 5220(d), open-ended portions of non. closed systems extending to the first shutoff valve are exempt from the testing req'lirements of AShtE Section XI 1974 Edition through the Summer 1975 Addenda Subsection IWC-2510.

J 4. TEST RESULTS The leak test acceptance criterion, as specified in the individual leak test procedure is,"there shall be no leakage from welded joints.' In addition, leakage from mechanicaljoints shall be recorded and

! repaired,if required.

All detected leakage was reviewed in accordance with the FitzPatrick Plant GA Program. A

'( Deficiency and Corrective Action Report (DCAR) was generated for all cases requiring additional review or corrective action. A record of all DCARs is maintained by the OA/QC department.

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INSERVICE INSPECTION IfYDROSTATIC TEST PROGRAM -

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Several types of acceptable leakage were noted during the ISI inspection such as bolted flange leaks, .

valve packing leaks and other mechanicaljoint'fcaks. These items were reviewed and if required, non.

conformance and corrective action reports were generated to resolve these deficiencies.

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' REOUESTS FOR RELIEF FROM CODE REOUIRED EXAMINATIONS

• First 10-year interval Relief is requested for those cases in which ASME Section XI,1974 Edition through Summer 1975 Addenda requirements are impractical. In some cases, reliefis requested to allow use of the requirements of the 1980 Edition through Winter 1981 Addenda of the code. Attachment I identifies 7 and provides justification for exception to the code testing requirements as allowed in 10 CFR . ')

50.55a(g)(5)(iii).

Second 10-year interval +

The code of record for the second 10-year inspection intervalis ASME Section XI,1980 Edition through Winter 1981 Addenda. As allowed by 10 CFR 50.55a(g)(5)(iii) the Authority also requests relief for the hydrostatic tests to be conducted during the second 10-year interval (see flydrostatic Relief Requests 4,5,6,7, and 8 contained in Attachment I). The Authority has determined that in' '

these cases, ASME Section XI,1980 Edition through Winter 1981 Addenda requirements are also impractical.

Ilydmstatic Relief Request 8 has been approved previously by the NRC for the first and second 10-

. year interval but is included in this report for historical reference.

Each hydrostatic relief request identifies the affected System (s), Component (s), Code Class, Code Test ,

Requirements, Basis for Relief and Testing to be Performed in Lieu of the Code Requirements. ,

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- i TABLE 11

SUMMARY

OF llYDROSTATIC TESTS PERFORMED DURING H

THE FIRST 10-YEAR INSPECPlON INTERVAL l

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- Procedure No. Title Remarks

10/45477/3 B' RHR Discharge Remainder 10/45477/6- RHR Shut down Cooling Piping

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10/45477/7 'A' RiiR Suction 10/45477/8: 'A' RHR Discharge licat Exchanger Section RHR Crosstle and Fuel Pool Cooling 10/45477/9-Assist Line i(. '16d/51424/1 Drywell Torus dp 1ndication 16 1/51424/2 Drywell Torus dp Indication 23/53364/8- Torus LevelInstrumentation X-206 A&B i

'23/53364/9 Torus LevelInstrumentation X 206 C&D CRD-Scram Discharge System Post ModTesting 03/20109/1-Modification-East CRD Scram Discharge System Post Mod Testing -

03/20109/2 Modification West ,

10/45477/1, 'B' RilR Suction 10/45477/2' *B' RHR Discharge Heat Exchanger Suction

, '10/45477/4 'B' RHR Drywell Spray

.'10/45477/5 "B" RHR llead Spray \

ATTS Mod Penetration X-40Ee Post Mod Testmg 10/21993/C ATTS Mod Penetration X-40Ed Post Mod Testing 10/21193/7 A7TS Mod Penetration X 55a Post-Mod Testing -

10/21193/8 ATTS Mod Penetration X 55c Post Mod Testing 10/21193/9 11/045747/1 SLC Suction Piping ,

11/(M5747/2 . SLC Discharge Piping 11/045747/3. SLC Pump 11P-2A FunctionalTest f _11/045747/4: SLC Pump 11P-2B - Functional Test Page 5 of 19

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TABLE 1 1 (Cont'd)

SUhihiARY OF IIYDROSTATIC TESTS PERFORhiED DURING

, Tile FIRST 10-YEAR INSPECTION INTERVAL -q Procedure No - Title Remarks 3

13/52475/1 RCIC Pump Suction and Torus f Suction  ;

13/53357/2 Ilydrostatic Test for Post Mod Testing -

13RCIC 752 Replacement RCIC Pump Discharge

{ 13/52475/4

. 13/52475/7 RCIC Tbrbine Steam Supply 14/51422/1. 'A' Core Spray Suction 14/51422/2 *B' Core Spray Suction 14/51422/5 *B' Core Spray Discharge 14/51422/6 . A" Core Spray Discharge 15/20249/1 Penetrations X-24, X-64: 'B' Post Mod Testing Drywell Cooling Assembly RBC Supply / Return 15/20249/2 Penettations X 67, X-68: *B' Pcst Mod Testing Recirculation Pump and '

Motor Coolers Supply / Return 15/20249/3 Penetrations X 63,X 64:"A" Post Mod Testing Recirculation Pump and Motor Coolers Supply / Return 15/20249/4 Penetrations X-23, X-65, Post-Mod Testing X 66:"A" Drywell Cooling and .,

Equipment Sump Cooler Supply / Return 16-1/52052/2 Mensor Mod Torus dp ' Post-Mod Testing Indication 20/51421/1 Radwaste Penetration X-18 20/51421/2 Radwaste Penetration X-19 23/53364/1- HPCI Pump Suction

.23/53364/2 HPCI Torus Suction g 23/53364/4 IIPCi Pump Discharge 23/53364/5 HPCI Steam Supply Page 6 of 19 i

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L . fit INSERVICE INSPECTION llYDROSTATIC TEST PROGRAM ig Table 21

[ SYSTEMS CONTAINING ISI CLASS 2 COM PONENTS -

The following systems contain Class 2 components:

't System No, System Remarks F

01 125 , Standby Gas Treatment See Note 1 -

03 Control Rod Drive Post Modification Testing 07 Tip Neutron Monitor Exempt per Subsection IWC 5220(d) 10 Residuallleat Removal llydrostatic Relief Requests 1,2,3 11 Standby Liquid Control flydrostatic Relief Requests 1,2,4,5 0

13 Reactor Core Isolation Cooling flydrostatic Relief Requests 1,2,3,8

> See Note 2 14 Core Spray ' ilydrostatic Relief Request 3

' 15 - Reactor 13uilding Closed Loop liydrostatic Relief Request 7 )

Cooling Water i 1

16 Drywell/ Torus Leak Rate Analyzer Ilydrostatic Relief Requests 1,2 19 ' Fuel Pool Cooling and Cleanup Examination performed under the scope ofIlcat Removal System testing '

-20 Radwaste Ilydrostatic Relief Requests 1,2 23 Iligh Pressure Coolant Injection flydrostatic Relief Requests 1,2,3,8 27 Containment Air Dilution See Note 1  !

33 ~ Condensate Exempt per Subsection IWC-5220(d) 39 Ilreathing, Instrument and See Note 1 {

Service Air i t

46 Senice Water 1-lydrostatic Relief Request 6  ;

NOTES:

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1. This system has been removed from the scope of the inservice inspection program, See Attachment II.

2.' The Reactor Core Isolation Cooling System, although classified ISI Class 3, has been hydrostatically tested to the more conservative requirements of ASME Class 2.

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A1TACilMENT I IlYDROSTATIC RELIEF REQUESTS 1

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NEW YORK POWER AUTIIORITY JAMES A FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 Page 8 of 19

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' ilYDROSTATIC RELIEF REQUEST 1 e -

Systems: . All Class 11/111 ,

Components: Various Code Class: 2 Code Test ' Ist Intesval Requirements: ASME Section XI 1974 Edition through Summer 1975

.- Addenda, Subsection IWC 5220 states:

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The system hydrostatic test pressure shall be at least 1.25 times the system design pressure (PD) and conducted at a test temperature not less than 100*F except as f may be required to meet the test temperature requirements ofIWA 5230."

Basis for Rehef: Reliefis requested from the referenced temperature requirement.

The minimum 100*F temperature requirement presents considerable hardship and excessive cost to the testing program, since there is no direct means of heating the large volume of water required for performing the hydrostatic testing.

.AfME Section XI 1980 Edition through Winter 1981 Addenda, Subsection IWC-5230 does not specify a minimum test temperature for Class 2 systems composed entirely of austenitic material. For those composed all, or in part, of ferritic steel, '

test temperatures are required to meet requirements specified by fracture toughness criteria.  !

Based on the above justification, the Authority concludes that the proposed alternate testing would not result in a decrease in safety.

Alternate Testing: Perform hydrostatic testing of system containing ferritic steel components at a test temperature which meets the requirements for fracture prevention criteria, if fracture prevention criteria were neither specille nor required in component -

construction, the Authority determined the minimum test temperature. No limit on test temperature is specified for systems comprised of components constructed entirely of austenitic steel or other non-ferritic materials.

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.. q. INSERVICE INSPECTION llYDROSTATIC TEST PROGRAM 3

IIYDR0 STATIC RELIEF REQUEST 2 h ,

Systems: All Class 11/111 ' ,

- Compoacnts: Various ~-

TCode Class: 2- -'

Code Test 1st Interval: ,

, Requirements: ASME Section XI 1974 Edition though Summer 1975 Addenda, Subsection IWA.

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$210(a) requires the following:

. 'The pressure retaining components shall be visually examined while the system is under the hydrostatic test pressure and temperature. The test pressure and temperature shall be maintained for at least four hours prior to the performance of

, the examinations?

, Basis for Relief: Reliefis proposed from the minimum hold time of four hours for visualinspection of noninsulated systems and components.

i -- The intent of the code is to hold the test pressure for four hours prior to the -

inspection of insulated components. This will allow sufficient time for the insulation j l to soak through. There is no practical purpose for holding the test pressure for four ,

hours prior to the inspection of noninsulated components, ASME Section XI 1980 Edition through Winter 1981 Addenda, Subsection IWA.

52t3(d) recognizes this and requires a four hour holding time after attaining the test ,

pressure and temperature condition for insulated systems, and ten minutes for -

noninsulated systems or components.

Based on the abovejustification, the Authority concludes that the proposed alternate testing would not result in a decrease in safety.

Alternate

< Testing: For insulated systems or components, the test pressure and temperature shall be maintained for a minimum of four hours prior to examination. For noninsulated

- systems or components, the test pressure and temperature will be maintained for a minimum of ten minutes prior to examination.

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u IIYDROSTATIC RELIEF REQUEST 3 Systems

Residual llcat Removal (RHR), Core Spray (CS), liigh Pressure Coolant Injection

' (IIPCI) and Reactor Core Isolation Cooling (RCIC) -

Components: RilR System pumps and discharge piping to the first isolation valve Core Spray System pumps and discharge piping to the first isolation valve IIPCI System pump and discharge piping to the first isolation valve g RCIC System pump and discharge piping to the first isolation valve Code Class: 2 The RCIC System piping and components, although classified as ISI Class 3, have been tested hydrostatically to the more conservative requirements of AShiE Class 2.

Code Test 1st Interval Requirements: ash 1E Section XI 1974 Edition though Summer 1975 Addenda, Subsection -

IWC-5220(a) states:

"The system hydrostatic test pressure shall be at least 1.25 times the system design pressure (PD) and conducted at a test temperature not less than 100*F except as '.

may be required to meet the test temperature requirements of IWA-5230?

Basis for Relief: Relief from the referenced test pressure requirement for centrifugal pump discharge piping is requested.

The discharge piping from the pump up to the first discharge valve on a centrifugal [

pump cannot be isolated from the pump suction if the piping between the pump and first discharge vahr were pressurized to the required test pressure, the pump suction piping would be subjected to pressures which exceed its design and potentially cause permanent damage to the piping and system components.

AShlE Section XI 1980 Edition though Winter 1981 Addenda, Subsection IWA-5224(d) identifies specific testing requirements for this condition as follows: I "Where the respective system primary pressure rating on tbc suction and dischzra l side 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."

Based on the above justification, the Authority concludes that the proposed alternate testirg would not result in a decrease in safety.

Alternate i Testing: The test pressure for the subject pumps, from the pump discharge to the first isolation valve on the discharge side of the pump, shall be the same pressure '

required for the piping and components on the suction side of the pump.

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-- IIYDROSTATIC RELIEF REQUEST 4 Systems- Standby Liquid Control (SLC)

- Components: SLC System pumps and discharge piping up to the pump discharge check valves

- Code Class: 2 .f Code Test 1st Interval

"' ASME Section XI 1974 Edition through Summer 1975 Addenda, Subsection Requirements:

IWC-5220(a) states:

'The system hydrostatic test pressure shall be at least 1.25 times the system design pressure (Pn) and conducted at a test temperature not less than 100*F cxcept as 0 ~ may be required to meet the test temperature requirements of IWA-5230."

2nd Interval

-: ASME Section XI 1980 Edition through Winter 1981 Addenda, Subsection IWC 5220(a) states:

"The System hydrostatic test pressure shall be at least 1.10 times the system pressure Psv for systems with a Design Temperature of 200*F or less, and at least 1.25 times the system pressure Psv for systems with Design Temperature above t 200*F.*

Basis for Relief: Relief from the referenced test pressure is requested, The SLC pumps are positive displacement pumps with discharge check valves located immediately downstream of the pumps. There is no way to test the piping between the pump and discharge check valve without removing the check valve

' internals.

- Based on the abovejustification, the Authority concludes that the proposed

- alternate testing would not result in a decrease in safety.

Alternate Testing: Perform a system functional test at nominal operating pressure, holding pressure for more than ten minutes prior to inspection of the uninsulated piping.

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t IIYDROSTATIC RELIEF REQUEST 5

- Systems: . Standby Liquid Control (SLC) - ,

- Components:' Standby Liquid Control Storage Tank '

Code Class: 2'

- Code Test 1st interval O Requirements: ASME Section XI 1974 Edition through Summer 1975 Addenda, Subsection IWC-5220(c) states:

'In the case of storage tanks, the nominal hydrostatic pressure developed with the tank filled to its design capacity shall be acceptable as the system test pressure."

• 2nd Interval ASME Section XI 1980 Edition through Winter 1981 Addenda, Subsection IWC 5222(b) states:

"In the case of atmospheric storage tanks, the nominal hydrostatic pressure -i developed with the tank filled to its design capacity shall be acceptable as the system test pressure. For 0-15 psi (0-103 kPa) storage tanks, the test pressure shall bc ,

1.1Po Design Pressure of vapor or gas space above liquid level for which i overpressure protection is provided by relief valves,"

Basis for Relief; Relief from the referenced test pt:ssure is requested. .

The Standby Liquid Control tank is an atmospheric tank with a volume of 5000 gallons. The Technical Specifications require this tank to be maintained at a minimum volume of 2200 gallons and a maximum volume of 4780 gallons. Standard plant practice is to maintain the tank level between 87% and 90% of capacity or between 4350 and 4500 gallons Filling this tank to its design capacity would exceed the plant Technical Specification limit for tank volume and may affect the sodium pentaborate solution concentration adversely, Based on the above justification, the Authority concludes that the proposed alternate testing would not result in a decrease in safety, i

- Alternate

. Testing: As required by the plant Technical Specifications, the solutica volume is checked at -

least once per day. This provides reasonable assurance that any leakage would be detected.

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E  : HYDRCSTATIC RELIEP REQUEST 6 l

Systems: Senice Water Components: Piping at penetration X-20 from check valve inside the drywell, through  !

- containment wall to welded cap.

. Code Class: '2 Code Test 1st Intenal Requirements: ASME Section XI 1974 Edition through Summary 1975 Addenda, paragraph IWC-5220 states:

• The system hydrostatic test pressure shall be at least 1.25 times the system design pressure (Po ) and conducted at a test temperature not less than 100*F except as -

may be required to meet the test temperature requirements of IWA 5230?

2nd Intenal ASME Section XI 1980 Edition through Winter 1981 Addenda, Paragraph IWC-5222(a) states:

• The system hydrostatic test pressure shall be at least 1.10 times the system pressure Psv for systems with Design Temperature of 200*F (93*C) or less, and at least 1.25 times the system pressure Psv for systems with Design Temperature above 200"F ',

(93*C). The system pressure Psv shall be the lowest pressure setting among the

. amnber 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 vakes, the system design pressure Pp shallbe substituted for Psv.'

Basis for

' Relief: Relief from the performance of hydrostatic testing is requested.

This is a deactivated portion of piping. Penetration X-20 has been identified as a ,

spare penetration since before 1974 (prior to Preoperational Containment Leak Rate Testing). The ISI Boundary Diagram shall be revised to delete this piping from the ISI scope.

' Alternate Testing: No alternate testing is required.

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INSERVICE INSPECTION llYDROSTATIC TEST PROGRAM V

1 HYDROSTATIC RELIEF REQUEST 7 I

Systems: Reactor Building Closed Loop Cooling Water Coreponents: Primary containment penetrations for the Reactor Building Closed Loop Cooling Water System Code Class: 2 Code Test 1st Interval Requirements: ASME Section XI 1974 Edition through Summer 1975 Addenda, Subsection IWC-5220(a) states,'that the system test pressure shall be 1.25 times the system design pressure."

2nd Interval ASME Section XI 1980 Edition through Winter 1981 Addenda, Paragraph ,

, IWC-5222(a) states: I

• The system hydrostatic test pressure shall be at least 1.10 times the system pressure ,

Psv for systems with Design Temperature of 200*F (93*C) or less, and at least 1.25 l times the system pressure Psv for systems with Design Temperature above 200*F -

(93*C). The system pressure Psv 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 I provided with safety or relief vakes, the system design pressure Pp shall be substituted for Psv.*

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Basis forj Relief: Relief from the performance of hydrostatic testing is requested.

!. These penetrations are tested as part of the system In Senice test performed on the  :)

- Reactor Building Closed Loop Cooling Water, Emergency Service Water and l Senice Water Systems. This In-Senice test meets the requirements of IWA-5211(c)

. of ASME Section XI 1980 Edition through the Winter 1981 Addenda. The Authority requests a system inservice test be performed in lieu of hydrostatic testing.

These penetrations are used to supply cooling water to the Drywell Cooling .

l Assemblies, Recirculation Pump Motor Coolers, and the Drywell Equipment Sump 1 Cooler. As containment penetrations, the piping components between the containment isolation valves are subject to testing requirements of 10 CFR 50,  ;

Appendix J,'Iype C testing. This is a pneumatic test at 45 psig which is a very  ;

sensitive measure of component leakage. -

Based on the above justification, the Authority concludes that the proposed 1 alternate testing would not result in a decrease in safety. l l

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(-T I HYDROSTATIC RELIEF REQUEST 7 (Cont'd)-

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' Alternate i F " Testing: In accordance with IWA 5211(c), an In-Service test at nominal operatmg pressure is - ,

. performed for these containment penetrations. During normal operation these .

lines are pressurized and in use with RBCLC water at a pressure of about 125 psig. l This is close to the design pressure of 150 psig. In addition, the piping components between containment isolation valves are subject to Local Leak Rate Testing  ;

_(LLRT) in accordance with the 'Iype C testing requirements of 10 CFR 50, Appendix J, t-

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. IIYDROSTATIC RELIEF REQUEST 8 Systems: 11PCI and RCIC Components: The turbine steam exhaust lines from each turbine to.the pressure suppression chamber (Torus)

Code Class: 2 I Code Test 1st Intersal ~'

l U Requirements: ASME Section XI 1974 Edition through Summer 1975 Addenda, Subsection IWC.

N 5220 discusses the requirements for the Class 2 piping pressure tests. Included in  !

this is the system hydrostatic test of 1.25 times the system design pressure (Pn ).

2nd Interval ASME Section XI 1980 Edition through Winter 1981 Addenda, Paragraph IWC 5222(a) states:

'The system hydrostatic test pressure shall be at least 1.10 times the system pressure Psv for systems with Design Temperature of 200*F (93*C) or less, and at least 1.25 times the system pressure Psv for systems with Design Temperature above 200*F (93*C). The system pressure Psy 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 Pos hall be substituted for Psv."

Basis for Relief: These exhaust lines were not designed for hydrostatic testing. This is evidenced by the design pressure of the turbine seals (30 psig) and the interferences with other .

systems which would be encountered by attempting to install temporary closures on the turbine exhaust flanges. Relief was granted on November 10,1988. See NRC letter, R. Capra to J. C. Brons ([[::JAF-88-341|JAF-88-341]]).

Alternate 1 Testing: A system In-Service test is performed in lieu of the hydrostatic test. This test was performed in accordance with IWA 5211 of Section XI of the ASME Code (1980 i Edition).

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ATTACilMENT II JUSTIFICATION FOR DELETION OF CLASS II AIR / NITROGEN SYSTEMS FROM Tile ISI PROGRAM l

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i h NEW YORK POWER AUTHORITY JAMES A FITZPATRICK NUCLEAR POWER PLANT DOCKET NO,50-333 Page 18 of19

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, , INSERVICE INSPEC110N HYDROSTATIC TEST F)MRAM a  !

I ATTACilMENT 11 l

• JUST!FICATION FOR DELETION OF CLASS Il AUGMENTED

[ AIR / NITROGEN SYSTEMS FROM ISI PROGRAM  !

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Systems: . Drywell inerting, CAD and Purge System l Containment Differential Picssurization System

. Breathing, Instrumer4t and Senice Air g Containment 11ydrogen Monitoring System F . Standby Gas Treatment System Justification: When the scope of the Inservice Inspection (ISI) program was developed, the above listed air / nitrogen systems were included. Upon further review, the Authority determined these systems did not fallinto the scope of the ISI program. This determination was made as follows:

- 10 CFR 50.55a (g) (4),'Insenice Inspection Requirements,' states,

• Throughout the service life of a boiling or prer,surized water cooled nuclear power facility, components (including supports) which are classified as ASME Code Class 1, Class 2 and Class 3 shall meet the requirements except design and access provisions and preservice examination requirements, set ,

forth in Section XI of editions of the ASME Boiler and Pressure Yessel Code and Addenda ... to the extent practical within the limitations of design, i' geometry and materials of construction of the components.*

. The footnotes to 10 CFR 50.55a states,' Guidance for quality group classifications of components ... may be found in Regulatory Guide 1.26...'

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- Regulatory Guide 1.26,'Ouality Group Classifications and Standards for Water., steam , and Radiological-waste.containing Components of Nuclear Power Plants,' applies, as indicated by its title, only to those systems which contain water, steam, and radioactive materials.  ;

1 In addition, Regulatory Guide 1.26 stmes,'Other systems not covered by this guide, such as instrument and service air, dicsci engine and its generators and auxiliary support systems, dicsci fuel, emergency and normal ventilation, fuel handling and radioactive waste management systems, should be designed, fabricated, crected, and tested to quality standards commensurate with the t.afety function to be performed.*

Based upon the above information, the air / nitrogen systems listed above clearly do not fall under the guidance of Regulatory Guide 1.26 or in the scope of the ISI program. Portions of the above systems which are safety related are tested commensurate with their safety function. The FSAR and/or Technical Specifications require surveillance testing combined with the testing required by 10 l

CFR 50 Appendix J for portions of these systems which comprise the containment boundary.

Based upon the above, these systems are considered Safety Related Non ASME Section XI and are not included in the FitzPatrick Inservice Inspection Program Plan.

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