ML20044E729

Forwards Rev 1 to Relief Request RR-13 for Unit 1,First Ten Yr Interval ISI Program.Rev 1 Requests Relief from ASME B&PV Code Section 11 Re Steam Pressure Tests for Class 2 & 3 Pressure Retaining Components

ML20044E729
Person / Time
Site:	Limerick
Issue date:	05/18/1993
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9305250366
Download: ML20044E729 (29)

Text

{{#Wiki_filter:E .u-Y' _10CFR50.55a(g)(5)(iii)- PHILADELPHIA ELECTRIC COMPANY - W NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD. 1 WAYNE, PA 19087-5691 f C15) 6404000 i STATION SUPPORT DEPARTMENT { May 18, 1993 Docket No. 50-352 License No. NPF-39 t U.S. Nuclear Regulatory Commission Attn: Document Control Desk i Washington, DC 20555

Subject:

Limerick Generating Station, Unit 1 Revision to Relief Request for First Ten Year i Interval Inservice Inspection Program for i Performance of System Pressure Tests-l l Gentlemen: t i Attached for your review and aparoval is Revision 1 to Relief Request No. RR-13 for the Limerick Generating Station (LGS), Unit 1, First Ten Year Interval Inservice Inspection (ISI) Program. Revision 1 to_ Relief Request RR-13 requests relief from the American Society of Mechanical Engineers- (ASME) Boiler and. Pressure Vessel (B&PV) Code Section XI,1986 Edition, requirements regarding system pressure tests for various Class 2 and Class 3 pressure retaining components, which includes piping, pumps, and valves. Revision 0 of this relief request was submitted for NRC review and approval by letter dated January 24, 1992. Revision 1 of this relief request supersedes the January 24, 1992 i submittal of RR-13. i The details and justification for relief for the various Class 2 and Class 3 components are explained in further detail in the attached relief request. In addition, this revised request is similar to the LGS, Unit 2, relief request (i.e., RR-13) submitted by letter dated March 12, 1993, concerning the_ same topic. i If you have any questions or require additional information, please do not hesitate to contact me. R40038 1 I f 9305250366 930518 gi ADDCK0500g2-g DR

Jt f - U.S. Nuclear. R:gulatory Ccamission _ May 18,'1993 i Document Control Desk. Page 2 Very truly yours, . Q./4,, A G. A. Hunger, p < Jr. l Director ' Licensing Section. Attachment cc: T. T. Martin, Administrator, USNRC, Region 1 (w/ attachment) l N. S. Perry, USNRC Senior Resident Inspector, LGS (w/ attachment) I i P ) h I i ~ ) i t i i

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Specification l

NE-42, l- ~ LGS-1 ~! ~ ^ ISI Program Appendix A-13 l Page 1 of 27 l I RELililt REQUEST NO. RR-13 Revision 1 I. 1DENTIFICATION OF COMPONENTS N Class 2 (exempt and non-exempt) pressure retaining components within the pressure L retaining boundary of pressure vessels, piping, pumps, and valves, Examination Category-' C-II, Item Numbers C7.10 through C7.80 inclushc. i Class 3 (exempt and non-exempt) pressure retaining components within the pressure retaining boundary, Examination Categories D-A, D-11, and D-C, item Number DI.10, D2.10, and D3.10, respectively. i The specific Class 2 and 3 components covered by this relief request are detailed in Table (s) RR 131.1 through RR-13-1.13. l i II. CODE REQUIREMENTS FROM WillCil REllEF IS REOUESTED. i .i ASME Section XI 1986 Edition, Examination Category C-Il requires the pressure retaining components within each system boundary be subject to the system pressure tests _ of' f 4 IWC-5000 and visually (VT-2) examined. I ASME Section XI 1986 Edition, Examination Categories D-A, D-B, and D-C require the pressure retaining components within each system boundary be subject to the system pressure tests of IWD-5000 and visually (VT-2) examined. The required system pressure tests shall be performed during the first inservice inspection t interval in accordance with Table IWC-2500-1 or Table IWD-2500-1, as applicable. 2 Relief is requested frorn meeting the subject pressure test requirements for the specific components listed in Table RR-13-1.1 through RR-13-1.13 due' to hardship imposed by l { plant design and/or redundant testing. Individual test requirements requiring relief are'as detailed in the Tables. l l i s.-..

Specification l y. NE-42, LGS-1 ISI Program Appendix A Page 2 of 27 RlillEF REQUEST NO. RR-13 (CONTD.) Revision 1 + l III. BASIS FOR RELIEF i Pressure testing in accordance with some or all of the requirements of IWC-5000 or IWD-5000, as applicable, for the afTected components is impractical due to plant / system l design and/or redundant test requirements as detailed in Table (s) RR-13-1.1 through l l l R R 1.13. In all cases, plant modification to facilitate the required testing represents undue hardship and/or alternate testing provides adequate assurance of pressun: boundary integrity. IV. ALTERNATE PROVISIONS Any alternate test provisions, where practical, are as proposed in Table (s) RR-13-1.1 through RR-l' '.13 j i' i k f l f I r I l t i I'i i r

-( Specification NE-42, . L.GS-1 l ISI Program l Appendix A-13 i Page 3 of 27 j RELIEF REQUEST NO. RR-13 (CONTD.) l Revision 1 e Table RR-13-1.1 -t l. Identification of Components l Class 2 Service Air piping,11BB-166 between and including valves 15-1139 and 15-1140. l (Ref. P & ID: ISI.N1-15, Sht 15) r 11. Code Requirement From Which Relief is Requested d IWC-5221, System pressure test during system functional / inservice tests and, { IWL 222, System hydrostatic test [ 111. Basis For Relief l 10CFR50 Appendix J local Icak Rate Testing (LLRT) meets the intent of the ASME j requirement. l During normal plant operation, Senice Air licader pressum is approximately 100-110 psig. i 118B-166 is isolated from the Senice Air header by normally-closed valves 15-1138 and - l 15-1139 outside containment and 15-1140 and 15-1212 inside containment. j I f I .Although Leical Irak Rate tests use a lower pressure (44 psig) than nonnal Service Air. pressure, they offer the following advantages over system pressure tests: i 1) LLRTs are performed more frequently than periodic system functional tests and the i ten year hydrostatic test. 2) LLRTs have the ability to quantify leakage which is not feasible with VT-2 inspections on air systems. i 3) LLRTs conservatively test some unclassified piping and includes through valve j leakage which would not be identified in a VT-2 inspection. I i f I

Specification .,~ NE-42, l l l - LGS-1 ISI Program l Appendix A-13 l Page 4 of 27 ? RELIEF REQUEST NO. RR-13 (CONTD.) _i Revision 1 i IWC-5210(b) allows for air tests which permit location and detection of through-wall .f leakages. In the event the LLRT fails to meet its acceptance criteria, further testing would-be performed to determine the location of the Icaks, appropriate corrective maintenance j would be performed, and an appropriate retest would be performed. i IV. ALTERNATE PROVISIONS 10CFR50 Appendix.I local Irak Rate Testing (1.1.RT) will be utilized to meet the ASME f -i Section XI IWC-5000 pressure testing requirements. .j t i 'h r .' ii _i .l { i:j w r I i i l l t I k I l 1 1 t

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NE42, l

LGS-1 "l ISI Program _i Appendix A j Page 5 of 27 ~l RELil!F RiiQUliST NO. RR-13 (CONTD.) Revision 1 i j Table RR 13-1.2 1 1. Identification of Components } r Class 3 Nuclear Boiler Vessel instrumentation tubing to drywell pressure instrumentation outboard of IIV-42-147A, II, C, and D. (Ref P & ID: IS'-t.t-42, Sht I, ISI-M-57, Sht 1, j ISI-M-59, Sht 1) t i i II. Code Requimment From Which Relief is Requested j IWD-5221 System Inse:Tice Test and IWD-5223, System Ilydrostatic Test i t i !!I. Basis For Relief j l Normal Drywell pressure is less than 1 psig. The pressurizing fluid is nitrogen gas. A VT-2 l inspection looking for a nitrogen gas leak with less than I psig driving pressure would be inconclusive. J 1 LGS Technical Specifications require channel checks every 12 hours to verify drywell f pressure instrumentation operability. This is performed by verifying proper pressure f I readings. A significant tubing leak will cause an improper reading, and will be corrected and mtested. The tubing and components am also included in the Integrated leak Rate Test i t (ILRT) boundary. l i IV, ALTERNATE PROVISIONS f LGS Technical Specification operability checks and Integrated leak Rate Testing provide. l [ assurance of component integrity and will be utilized to satisfy ASME Section XI requirements. i l i .] I

- ~, -.. - ~ ~ Specification ' i NE-42, i LGS-1 ISI Program Appendix A-13 Page 6 of 27 i RELIEF RiiQUEST NO, RR-13 (CONTD.) Revision 1 Table RR-13-1.3 - \\ 'i I. Identification of Components j q Class 2 RCIC Turbine Exhaust Vacuum Breaker lines llDB-101 and IIBB-145 between and -l including valves IIV-49-IF084, !!V-49 IF080, llV-49-IF060 and 49-lF001. j (Ref. P & ID: ISI-M-49, Sht 1) { Class 2 RCIC Vacuum Pump Exhaust to Suppression Pool, IIBB-150 between 49-lF028 ] and IIV-49-1F002,49-1038 and 49-1F055. (P & ID: ISI-M-49, Sht 1) i II. Code Requirement From Which Relief 1s Recues_ted i j fWC-5221, System pressure tr~ % ring system functional /inservim tect= and, IWC-5222, System hydrostatic test j l 111. Basis For Relief t i 10CFR50 Appendix J Iocal Irak Rate Testing (LLRT) meets the intent of the ASME i t requirement. ) l During LLRTs, the subject piping is pressurized to 44 psig, a substantially higher pressure i r than that developed during a periodic system functional test. As such, the LLRT offers the g-1 following advantages over system pressure tests: i i 1) LLRTs are performed more frequently than periodic system functional tests and the ten year hydrostatic test. 1 2) LLRTs have the ability to quantify lear, age which is not feasible with VT-2 inspections on this essentially Fas-filled piping.. j I i l I

Specification NE-42, LGS-1 i ISI Program Appendix A-13 Page 7 of 27 l ii RELIEF REQUliST NO. RR-13 (CONTD.) Revision 1 i 3) LLRTs conservatively include through valve Icakage which would not be identified in - r a VT-2 inspection. l IWC-5210(b) allows for air tests which permit location and detection of through-wall { leakages. In the event the LLRT fails to meet its acceptance criteria, further testing would j be performed to deterrnine the location of the leaks, appropriate corrective maintenance, and l t an appropriate retest would be performed. I IV. ALTERNATE PROVISIONS 10CFR50 Appendix J local 1.cak Rate Testing (LLRT) will be utilized to rnect the ASME - Section XI IWC-5000 pressure testing requirements. i I i l t i ~ l - i w -,-~,

.A Specification . NE-42, LGS-1.' ISI Program Appendix A-13 Page 8 of 27 l RELIEF REQUEST NO. RR-13 (CONTD.) Revision 1 i I Table RR 13-1.4 1. Identification of Components l Class 2 IIPCI Turbine Exhaust Vacuum Breaker lines IIBB-108 and IIBB-144 between and - l

f including valves llV-55-IF095, llV-55-lF093, IIV-55-lF072, and 55-IF021. (Ref P & ID:

l ISI-M-55, Sht 1) i i 1 II. Code Requirement From Which Relief is Requested j i i IWC-5221, System pressure test during system function / inservice tests and, IWC-5222, System hydrostatic test. q i I" Basis For Relief I I 10CFR50 Appendix J local Icak Rate Testing (LLRT) meets the intent of the ASME 1 requirement. j l During LLRTs, the subject piping is pressurized to 44 psig, t substantially higher pressure j than that developed during a system functional test. As such, the LLRT offers the .f following advantages over system pressure tests: 1) LLRTs are performed more frequently than periodic system functional tests or the ten year hydrostatic test. a r 2) LLRTs have the ability to quantify leakage which is not feasible with VT-2 inspection on this essentially gas-filled piping. t 3) LLRTs conservatively include through valve leakage which would not be identified in a VT-2 inspection. .l

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Specification J,. NE-42, liiS-1 ISI Program Appendix A-13 Page 9 of 27 RELIEF REQUEST NO. RR-13 (CONTD.) Revision 1 IWC-5210(b) allows for air tests which permit location and detection of tiuough-wall leakages. In the event the LLRT fails to meet its acceptance criteria, further testing would be performed to determine the location of the leaks, appropriate corrective maintenance, and an appropriate retest would be performed. IV. ALTERNATE PROVISIONS 10CFil50 Appendix J local I cak Rate Testing (LI.RT) will be utilized to meet the ASME Section XI IWC-5000 pressure testing requirements. e i I i s ? I i f

9 Specification - z. NE-42, ~ LGS-1 ISI Program l Appendix A-13 l Page 10 of 27 l l RI!LIliF REQUliST NO. RR-13 (CONTD.) i Revision I r Table RR-13-1.5 I 1. Identification of Components Class 3 Containment Atmospherie Control tubing to suppression pool pressure and level instmmentation outboard of SV-57-101. (Ref P & ID: ISI-M-57, Shti, ISI-M-52, Sht 1) f i 11. Code Requirement From Which Relief is Requested t IWD-5221, System Inservice Test and l IWD-5223, System 11ydrostatic Test. i III. Basis For Relief -l i Normal suppression pool pressure is less than 1 psig. 'Re pressurizing fluid is nitrogen gas. A VT-2 inspection looking for a nitrogen gas leak with less than I psig driving pressure - [ would be inconclusive. i LGS Technical Specifications require monitoring suppression pool pressure every 12 hours. to verify proper pressure. Additionally, Technical Specifications require channel checks every ) 24 hours to verify operability of the suppression poollevel indicators. This is performed by l verifying a proper level readings. A significant tubing leak will give an improper reading, i and will be corrected and retested. Also, the tubing and components are included in the l l Integrated Leak Rate Test (ILRT) boundary. ) IV. ALTERNATE PROVISIONS ? LGS Technical Specification suppression pool instrumentation operability checks and [ Integrated Irak Rate Testing provide assurance of component integrity and will be_ utilized l ~ to satisfy ASME Section XI rrquirements. -l i i i I i

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Specification NE-42, LGS-1

~ ISI Program ) Appendix A-13 l Page 11 of 27 l RELIEF REQUEST NO. RR-13 (CONTD.) .i Revision 1 - ] Table RR-13-1.6 i 1. Identification of Comr>onents Class 2 Post-LOCA Recombiner piping IIBB-128 and ilBB 127 between and including "A" Recombiner and valves IIV-57-161 and IIV-57-162, and IIBB-126 and IIBB-124 between j and including "B' recombiner and valves IIV-57-163 and IIV-57-164. (Ref P & ID: ISI M-57, Sht I & 2) Class 2 hydrogen / oxygen sampling lines IICB-Il6 & IICB-117, between connections on the-f Combustible Gas Analyzer Package lOS205, and valves SV-57-159, SV-57-141, SV-57-142 1 f & SV-57-147B, SV-57-143, SV-57-144 & SV-57-146B, and SV-57-145(IICB-ll7). IICB-116 & IICB-ll7, between connections on the Combustible Gas Analyzer Package IOS206, and valves FV-57-lR4 & SV "m6A, SV-57-186 & SV-57-14R SV-57-195, SV-57-190 & 57-1090, and SV-57-185(llCB-117). (Ref. P & ID: ISI-M-57, Shts 1,2,3). i II. Code Requirement From Wluch Relief is Requested IWC-5221, System pressure test during system functional / inservice tests and, i i IWC-5222, System hydrostatic test '. i I III. Basis For Relief System Contaminated Pipe Inspection (CPI) meets the intent of the ASME requirement. .j During nonnal plant operation, this piping is either isolated or exposed to less than 1 psig i (normal containment pressure). During CPI testing associated with the leak Reduction Program (FSAR 6.2.8), this piping is pressurized to 44 psig. CPIs for this system are performed similar to 10CFR50 Appendix J Local Leak Rate Testing and, as such, offer the i following advantages over system pressure tests: i 3 i i

.- O, Specification NE-42, - LGS-1 ISI Program l Appendix A-13 Page 12 of 27 RELIEF REQUEST NO. RR-13 (CONTD.) 'l Revision I 1) CPIs are perfonned more frequently than periodic system functional tests and the ten year hydrostatic tests. '{ t 2) CPIs have the ability to quantify leakage which is not feasible with a VT-2 inspection on this air filled piping. l 3) CPIs conservatively include through valve leakage which would not be identified in a VT-2 inspection. f IWC-5120(b)' allows for air tests which permit location and detection of through-wall leakages. In the event the CPI fails to meet its acceptance criteria, further testing would be perfonned to determine the location of the leaks, appropriate corrective maintenance, and an appropriate retest would be performed. IV. ALTERNATE PROVISIONS f I System Contaminated Pipe Inspection (CPI) will be utilized to meet the ASME Section XI IWC-5000 pressure testing requirements. -l s t 7 'I I I 1 l .l l i \\ l a 1

~. =6 ' Specificatbn ' NE-42, LGS ; ISI Program i Appendix A-13 l Page 13 of 27 { RELIEF REQUF50 NO. RR-13 (CONTD.) - Resision 1 Table RR-13-1.7 j L Identification of Components I' Class 2 Containment Atmospherie Control piping as illustrated in figures RR-13-1.7a & b. l r l 11. Code Requirement From Which Relief is Requested .j l i IWC-5221 System pressure test during system functional / inservice tests and, i 1WC-5222, System hydrostatic test. l 111. Ilasis For Relief i 10CFR50 Appendix J Local leak Rate Testing (LLRT) meets the intent of the ASME ' .i requ;rement 'Re LLRT offers the following advantages over system pressure tests: 1) LLRTs are performed more frequently than periodic system functional tests. j l 2) LLRTs have the ability to quantify leakage which is not feasible with VT-2 j inspection on this essentially gas-filled piping. { i 3) LLRTs conservatively include through valve leakage which would not be identified in a VT-2 inspection. ( i, .i IWC-5210(b) allows for air tests which permh location and detection of through-wall { . Icakages. In the event the LLRT fails to meets its acceptance criteria, further testing would. f be performed to determine the location of the leaks, appropriate corrective ma'mtenance and an appropriate retest would be performed. I ,i i i I

- _ _ _.. ~.... -... _,.. _ _. -.. - -. _.. _.. _._ O. Specification j NE-42, i LGS-1 l ISI Program l Appendix A-13 } Page 14 of 27 . } l RELIEF REQUEST NO. RR-13 (CONTD.) l Revision 1 ) i IV. AIXFRNNFE PROVISIONS l r 10CFR50 Appendix 3 Local leak Rate Testing (LI.RT) will be utilized to meet the ASME i a Section XI IWC-5000 pressure testing requirements. L i a i Y l 6 h i i I ? i f I i l I t s i e ~ - i i i - t -f 7 ) i l i - t l s J.,n. ..-s.. a y

D Specification ~ NE-42, LGS-1 ISI Program Appendix A-13 Page 15 of 27 RELIEF REQUEST NO. RR-13 (CONTD.) Revision 1 Figure RR-13-1.7a (Ref P & ID: ISI-M-57, Sht 2) 7 L h i' t., t t'fy. k b1 i i g il',e ki' {@ Y" 4 J e. F W

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s..... t O ' Specification l NE-42, LGS-1 \\ ISI Program j Appendix A 13 Page 16 of 27-RELIEF REQUEST NO. RR-13 (CONTD.) r Revision 1 i i t Figure RR-13-l.7b 7 (Ref P & ID: ISI-M-57, Sht 1) -{ A I ? M O ~ e_ m___ _ = *_ _ w e

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V Specification NE42 I GS-1 ISI Program Appendix A-13 Page 17 of 27 REl.IEF REQUEST NO. RR-13 (CONTD.) Revision 1 Table RR-13-1.8 (Deleted) s l

Specification v NE-42, LGS-1 ISI Program Appendix A-13 Page 18 of 27 RELIEF REQUFSF NO. RR-13 (CONTD.) Revision 1 i Table RR-13-1.9 1. Identification of Comr>onents j r Class 2, Primary Containment leak Testing lines llCB-122 between and including valves 60-1050, 60-1057, and 60-1058; llCB-122 between and including valves 60-1051, 60-1070, and 60-1071; and llCB-122 between and including valves 60-1052, 60-1073, and 60-1074. (Ref P & ID: ISI-M-60, Sht 1) II. Code Requirement From Which Reliefis Requested IWC-5221, System pressure test during system functional / inservice tests and, IWC-5222, System hydrostatic test. III. BaA For Relief 10CI:R50 Appendix.1 Local Irak Rate Testing (LLRT) meets the intent of the ASME requirement. i During normal plant operation, this piping is not pressurized and is isolated by locked valves. During the ILRT the piping is pressurized to 44 psig. Tids piping is also pressurized dudng LLRTs. LLRTs offer the following advantages over system pressure tests: 1) L1 RTs are performed more frequently than pedodic system functional tests. t 2) LLRTs have the ability to quantify leakage which is not feasible with a VT-2 inspection on this air filled piping. l 3) LLRTs conservatively include through valve leakage which would not be identified in I a VT-2 inspection. i i l

O Specification o NE-42, LGS-1 ISI Program Appendix A-13 Page 19 of 27 RELIEF REQUEST NO. RR-13 (CONTD.) Revision I IWC-5210(b) allows for air tests which permit location and detection of through-wall Icakages. - In the event the 11RT fails to meet its acceptance criteria, further testing would be performed to determine the location of the leaks, appropriate corrective maintenance, and an appropriate retest would be performed. IV. Al TERNATE PROVISIONS 10CFR50 Appendix J Local 1.cak Rate Testing (LLRT) and Integrated leak Rate Test (ILRT) will be utilized to meet the ASME Section XI IWC-5000 pressure testing requirements. s e a s 9 f 6 i

.M.. ' Specification NE-42, LGS-1 ISI Program Appendix A-13 .Page 20 of 27 RELilIF REQUEST NO. RR-13 (CObTrD.) Resision 1 Table RR-13-1.10 L Identification of Comr>onents Class 2 Plant Process Radiation Monitoring System piping IICIl-128,' between and including valves 26-1009, 26-1011, SV-26-190A & B, and 26-1010, 26-1012, SV-26-190C &- D. (Ref. P & ID: ISI-M-26, Shts 1 & 2) II. Code Requirement From Which Relief is Requested IWC-5221, System pressure test during system functional /insersice tests and, IWC-5222, System hydrostatic test 111. Basis For Relief 10CFR50 Appendix J local Leak Rate Testing (LLRT) meets the intent of the ASME requirement. During LLRTs, the subject piping is pressurized to 44 psig, a substantially higher pressure than that developed during a system pressure test. As :;uch, the LLRT offers the following j advantages over system pressure tests: '-] i 1) LLRTs are performed more frequently than penodic system pressure tests and the ten j year hydrostatic test. ~

1 2)

LLRTs have 'the ability to quantify leakage which is not feasible with VT-2 inspections on air systems. 3) LLRTs. conservatively test some unclassified piping and includes through valve leakage which would not be identified in a VT-2 inspection. ~ .e

._~._ _ ._ ~ Specification i e 9 NE-42,- LGS-1 i I ISI Program Appendix A'-13 .i i Page 21 of 27 RELIEF RiiQUEST NO. RR-13 (CONTD.) Revision 1 i IWC-5210(b) allows for air tests which permit location and detection of through-wall leakages. In the event the LLRT fails to meet its acceptance criteria, further testing would i be performed to determine the location of the leaks, appropnate corrective maintenance would be perfonned, and an appropriate retest would be performed. i IV. Al TERNATE PROVISIONS j 10CFR50 Appendix J local Leak Rate Testing (LLRT) will be utilized to meet the ASME i t Section XI IWC-5000 pressure testing requirements. l -l t C L t i ~; I t i ~ ' t ? t P l 4 4 x .a j i J

4.. Specification NE-42, LGS-1 'i 'ISI Program l Appendix A-13 .j Page 22 of 27 i ? RELIEF REQUEST NO. RR-13 (CONTD.) f Revision 1 l i Table RR-13-1.11 -l .i f i I. Identification of Components t Class 2 Primary Containment Instrument Gas System piping, as follows: IICB-124 piping and components at penetration X-3D, between and including valves. ] IIV-59-151B and 59-1111. f IlCB-124 piping and components at penetration X-27A, between and including valves j llV-59-151A and 59-1129. { IICB-110 piping and components at penetration X-3B, between and including valves IIV-59-129B and 59-1005B. IICB-110 piping and components at penetration X-40ll, between and including valves { IIV-f" 129A and 59-1005A. s Tubing and c-ynents from and including vz'ves XV-59141 A. B, C, D, A "; to -l i penetrations X-35C, D, E, F, & G respectively. IICB-110 piping and components at penetration X-35B, between and including valves IIV-59-131 and 59-1056. l 11CB 109 piping and components at penetration X-40F, between and including valves 'f t i IIV-59-102 and 1IV-59-101. j llCB-110 piping and components at penetration X-218, between and including valves IIV-59-135 and 59-1001. (Ref. P & ID: ISI-M-59, Sht 1). j 11. Code Requirement From Which Relief is Requested i e IWC-5221, System pressure test during system functional / inservice tests and, l IWC-5222, System hydrostatic test .j I III. Basis For Relief -l 10CFR50 Appendix I Local I.cak Rate Testing (LLRT) meets the intent of the ASME i requirement. .) 6 i 1y

A'. Specification NE-42, LGS-1 ISI Program Appendix A-13 Page 23 of 27 f RELIEF REQUFSF NO. RR-13 (CONTD.) Revision 1 -l t t Ahhough local I cak Rate tests use a lower pressure (44 psig) than normal Containment Instrument Gas pressure, they offer the following advantages over system pressure tests: 1) LLRTs are performed more frequently than periodic system pressure tests and the ten year hydrostatic test. I I 2) LLRTs have the ability to quantify leakage which is not feasible with VT-2 j inspections on air systems. 3) LLRTs conservatively test some unclassified piping and includes through valve leakage which would not be identified in a VT-2 inspection. t l IWC-5210(b'i allows for - tests which pennit location -nd detection of throuch-wall q Icakages. In the event the LLRT fails to meet its acceptance criteria, further testing would -j be performed to determine the location of the leaks, appropriate corrective maintenance would be performed, and an appropnate retest would be performed. t IV. ALTERNATE PROVISIONS f 10CFR50 Appendix J local leak Rate Testing (LLRT) will be utili7ed to meet the ASME Section XI IWC-5000 pressure testing requirements. j i i It l I f i l l c LJ

L 4 Specification . NE-42, LGS-1 ISI Program Appendix A-13 Page 24 of 27 RELIEF REQUINT NO. RR-13 (CONTD.) Revision 1 Table RR-13-1.12 1. Identification of Comr>onents Class 3 Primary Containment Instrument Gas System, IICC-134 piping and components: between and including valves 59-1111, 59-ll31E & 59-ll31K, and PSV-41-lF013E, & -K; between and including valves 59-1129, 59-113111, 59-1131h1, 59-1131S, and PSV IF01311, -M, -S. (Ref P & ID: ISI-M-59, Sht 1; ISI-M-41, Sht 2). i 11. Code Requirement From Which Relief Is Requested I IWD-5221, System pressure test during system inservice tests and, IWD-5223, System hydrostatic test 111. Ba-For Relief f Testing similar to 10CFR50 Appendix 3 Local leak Rate Testing (LLRT) meets the intent of the ASME requirement. I During each refueling outage, Containment leakage Check examinations are performed on this piping at operating pressure. Additionally, during surveillance testing of the ADS accumulator system, conducted each refueling outage in accordance with UFSAR, para. l 5.2.2.10, the portion of piping and components between and including valves 59-1023E, -11, i -K, -M, & -S; 59-1131E, -11, -K, -M, & -S; and PSV-41 IF013E, -11. -K, -M, & -S are tested in a manner similar to 10CFR50 Appendix J Local Irak Rate Testing. 'lhese tests offer the following advantages over system pressure tests: i i 1) Testing is performed more frequently than periodic system pressure tests and the ten l year hydrostatic tests. 2) The tests have the ability to quantify leakage which is not feasible with a VT-2 inspection on this air filled piping. l t l m.

.4 Specification ~ ^ NE-42, j ^ IJ3S-1 ISI Program Appendix A-13 Page 25 of 27 REl,IliF REQUEST NO. RR-13 (CONTD.) Revision 1 3) The tests conservatively include through valve Icakage which would not be identified in a VT-2 inspection. l In the event the above testing fails to meet its acceptance criteda, further testing would be. i performed to determine the location of the leaks, appropriate corrective maintenance, and an l appropriate retest would be performed. r IV. ALTERNATE PROVISIONS i local lxak Rate Testing and Containment leak Check examinations will be utilized to meet the ASME Section XI IWD-5000 pressure testing requirements. l i r ? l t I b I h h i i ~

6 Specification o ~ NE-42, LGS-1 ISI Program Appendix A-13 Page 26 of 27 RELIEF REQUEST NO. RR-13 (CONTD.) Revision 1 Table RR-13-1.13 1. Identification of Components Class 2 Liquid Radwaste Collection System. Drywell Floor Drain Sump piping and components llCB-106 and llBB-164 at penetration X-231 A, between and including valves 61-1025 and ilV-61-111. Drywell Equipment Drain Tank piping and components llCB-107 and IIBB-165, at penetration X-231B, between and including valves 61-1024 and IIV 131. (Ref. P & ID: ISI-M.61, Sht 1). II. Code Requirement From Which Reliefis Requested IWC-5221, System pressure test daring system ftmetionallinservice tests and, IWC-522 :*m hydrost, tic test I III. Basis For Relief 10CFR50 Appendix J Incal Irak Rate Testing (LLRT) meets the intent of the ASME requirement. During LLRTs, the subject piping is pressurized to 44 psig, a substantially higher pressure than that developed during a system pressure test. As such, the LLRT ofTers the following advantages over system pressure tests: 1) LLRTs are performed more frequently than periodie system pressure tests and the ten year hydrostatic test. 2) LLRTs conservatively test some unclassified piping and includes through valve - leakage which would not be identified in a VT-2 inspection. f IWC-5210(b) allows for air tests which permit location and detection of through-wall leakages. In the event the LLRT fails to meet its acceptance criteria, further testing would

4 Specification NE-42, ~ LGS-1 151 Program Appendix A-13 Page 27 of 27 RELIEF REQUEST NO. RR-13 (CONTD.) Revision I be performed to determine the location of the leaks, appropriate corrective maintenance I would be performed, and an appropriate retest would be performed. IV. ALTERNATE PROVISIONS 10CFR50 Appendix.I local I cak Rate Testing (1.lET) will be utilized to meet the ASME Section XI IWC-5000 pressure testing requirements. t I L l l i}}