ML20055F853
| ML20055F853 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/17/1990 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20055F854 | List: |
| References | |
| 1829, NUDOCS 9007190297 | |
| Download: ML20055F853 (6) | |
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. tw e m Docket Number 50-346 DONALD C SHEL10N.
License Nur.oer NPF-3
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s$ sana Serial Ntmber 1829 July _it. 1990 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555
Subject:
Request for Relief from ASME Code Section X1 Hydrostatic Test Pressure and Hold Time Requirements
_The purpose of this letter is to request NRC approval pursuant to 10CFR50.55a(a)(3) of relief from the minimum hydrostatic test pressure and hold tjme requirements of Section XI of the American Society of Mechanical Engineers I
L (ASME) Boiler and Pressure Vessel Code for systems where the Inst:umented Inspection; Technique (IIT) was used as an approved alternative during the first ten-year in-service inspection interval.
The ASHE Code Sections IWA-5212 specifies minimum hydrostatic test pressures which are greater than normal system operating pressure.
Section IWA-5213 requires'that the specified test i
l pressure be maintained for a minimum hold time of four hours for insulated systems, and ten minutes for uninsulated systems, prior to the ASME Code required visual examination (VT-2) of the system..
Performance of hydrostatic tests often involves plant evolutions and abnormal-i valve line-ups which are unique to hydrostatic tests, and generally cannot be conducted during plant operation. Hydrostatic tests have also involved i
l.
significant personnel radiation exposure which may not be in keeping with ALARA l
principles when the merits of hydrostatic tests for verifying the structural integrity of systems are considered in view of design conservatism included in the ASME Code.
The Instrumented Inspection Technique (IIT) was developed as an alternative to alleviate the problems and burden associated with conventional hydrostatic testing.
In April 1985, HAFA International requested NRC approval of IIT as an alternative to conventional hydrostatic testing.
IIT involves the use of Leakage Monitoring Devices (LHD's) and Acoustic Emission (AE) sensors to augment visual examination (VT-2) in the location of leakage in systems pressurized to normal operating pressure.
In December 1985, the NRC approved IIT as described in HAFA International Topical Report 135 (P-A), a. an acceptable alternative to the ASME Code hydrostatic test requirementi..
The principal differences between the ASME Code hydrostatic test requirements and IIT are that IIT can be used at normal operating pressure instead of the ASME Code specified elevated hydrostatic test pressure, and the hold time prior to 9007190297 900717
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PDR ADOCK 05000346
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' l THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLED OHIO 43652
Dock;t Number 50-346 Lic:nse Number NPF-3
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Serial. Number 1829 i
Page 2 i
l-(VT-2) visual examination may be reduced from four hours to two hours for
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insulated systems.
I Toledo Edison's letters to the NRC dated October 18, 1985 (Serial Number 1199),
April 11, 1988 (Serial Number 1486), and September 8, 1908 (Serial Number 1582) requested NRC approval to use IIT at Davis-Besse Nuclear Power Station (DBNPS) as an alternative to ASME Code hydrostatic tests.
The NRC granted approval of these requests by letters dated November 13, 1985 (Log Number 1861) and
. September 28, 1988 (Log Number 2715). A total of 31 IIT tests were conducted under these approvals.
i Recently, by letter dated June 4, 1990 to HAFA International, the NRC rescinded p
approval of the HAFA Topical Report and reaffirmed its position that testing l
done in accordance with this method was invalid.
In response to'the recent NRC concerns regarding IIT, conventional hydrostatic tests which satisfy the first ten year ISI program requirements have been completed covering 12 of the 31 IIT 3"
tests.
The sixth refueling outage was the last scheduled outage for the remainder of the first ten-year interval which will end on September 21, 1990.
Consequently It is impractical to complete any additional hydrostatic tests during the remainder of the first ten-year interval.
Because it is impractical to complete conventional hydrostatic tests during the remainder of the first ten-year ISI interval Toledo Edison requests relief from the ASME Code Section XI. Articles IWW-5212 and IWA-5213 for the affected systems for the first ten-year ISI interval.
Details of the requested relief are provide in.
As stated in Toledo Edison's letter to the NRC dated July 17, 1990 (Serial Number 1823), Talede ffeon is adjusting the schedule for second ten-year interval conventional hydtestatic tests of systems where only IIT was used in the first ten-year ISI inttrval.
Conventional hydrostatic tests covering the j
majority of the remaining IYT tests will be scheduled for completion during the first period of the second ten-year interval with any that remain being scheduled for completion by the end of the first refueling outage in the second period of the second ten-year interval.
The second ten-year ISI interval will begin on September 21, 1990, with the first period ending on September 21, 1993.
Toledo Edison previously concluded that all of the systems on which IIT was used are operable and fully capable of performing their intended safety functions.
This conclusion was previously stated in Toledo Edison's February 6, 1990 letter to the NRC (Serial Number 1763).
The bases for this conclusion are documented in Potential Condition Adverse to Quality Report (PCAQR) Number 89-0558.
PCAQR 89-0558 was initiated to resolve system operability concerns conservatively assuming that the IIT tests would be determined to be invali.
Toledo Edison considers that completion of conventional hydrostatic tests of the affected systems prior to September 21, 1990, the end of the first ten-year ISI interval, would result in hardship or unusual difficulties without a i
compensating increase in the level of quality and safety.
Toledo Edison, therefore, concludes that the requested relief from the ASME Code requirements is warranted as provided by 10CFR50.55a(a)(3).
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$hould you have.any questions concerning this matter, please contact Mr.
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'R.'W. Schrauder. ManagerL. Nuclear Licensing, at-(419) 249-2366..
VEry truly yours..
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Ittachment
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cci P. M. Byron. DB-1 NRC Senior Resident Inspector p'
-A.' B. Davis,' Regional Administrator,!NRC Region.III:
T. V. Wa:$ach. DB-1._ NRC-Senior Project Manager 9;
. State of Ohio (2)
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Relief Request Component Description I
Systems and components for which relief is requested are identified by Table 1 i
and on the attached Piping and Instrumentation Drawings (P& ids).
I ASME Code Class ASHE Class 2 and 3 as identified on the attached drawings.
ASME Section XI In-Service Inspection Requirements q
IWA-5212 Pressure and Temperature L
'a) System leakage tests and system hydrostatic tests shall be conducted at l
the test conditions of pressure and temperature specified in IWB-5000, IWC-5000, and IWD-5000.'
Specific ASME, Code minimum hydrostatic test pressures required in accordance with this article for each of the systems for which relief is requested are identified in Table 1.
IWA-5213 Test Holding Time
'The holding time after pressurization to test conditions, before the visual
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examinations commence, shall be as fol10was....
I (d) system hydrostatic tests - 4 hr. holding required after attaining the test pressure and temperature conditions for insulated systems, and 10 mins for noninsulated systems or components:...."
Basis for Requested Relief Relief is requested from the minimum hydrostatic test pressure requirements of IWA-5212 and the four hour hold time requirements of IWA-5213 for the first ten-year in-service inspection interval which ends on September 21, 1990 for the systems identified in Table 1.
During the first ten-year interval the Instrumented Inspection Technique (IIT) described in HAFA Topical Report 135 (P-A) was used as an NRC approved i
alternative to the hydrostatic test requirements of IWA-5000.
This method
-included a VT-2 examination but at lower pressures and shorter hold times.
By letter to' HAFA International dated June 4, 1990, the NRC staff rescinded approval of the IIT Topical Report and reaffirmed its position that testing done in accordance with this method was invalid.
Conventional hydrostatic tests cannot be completed on the systems identified on Table 1 where IIT was used prior to the September 21, 1990 end of the first ten-year ISI interval, s
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- Lic:ces Number NPF-3 i
Seri:1 Number 1829 l
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-Attachment 1 Page 2 The. principal differences' between ASHE Code hydrostatic test requirements and
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IIT are that IIT'can be used at normal operating pressure instead of elevated-j hydrostatic test pressures, and-hold times prior to VT-2 visual examination may j
"be reduced from four hours to two hours for insulated systems. -Table I l
identifies the Code required hydrostatic test pressure and the actual pressure used for the IIT tests.
Table I also identifies the test duration at the IIT i
. test pressure...However, this is not to be construed to be the hold time prior to the VT-2 visual examination which may have occurred any time after two hours for insulated systems. 'For uninsulated. systems the IIT hold time is the same as.
-l the-ASHE Code 10 minute hold time and relief from this requirement is not needed;
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W Even though'IIT tests did not. fully meet ASHE Code requirements it provides confidence in the structural integrity of_the affected systems. 'All other ASHE J
Code non. destructive: examinations and tests required by the in-service inspection program have been successfully completed for the affected systems.-
l The structaral integrity of the affected systems is therefore not compromised by
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the requested relief.
Alternative Examination 7
Conventional hydrostatic tests will be conducted on the affected systems.during the second and subsequent ten-year in-service inspection intervals in'accordance with the~ effective-ASHE Code editions and any relief requests in force at the' time.
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ASME Code
' IIT Actual Hydrostatic-Test System Train P&ID~
Test Pressure Pressure Test Duration Decay Heat 1-1
. M-033BL 363 377 2 hrs.',45 mins.-
Decay Heat.
RCS to DH M-033B 400 232
' 3 hrs. 35 mins (
-Suction M-033C Decay Heat 1-2 M-033B 563 385-390
- 2 hrsJ.15 mins.
~ M-033C-Service Water 1
M-041A.
162
'115 3 hrs.~22 mins.
. M-041B M-041C M-006D 4
Service Water 2&3
-162 112 5 hrs. 10 mins.-
Service Water Return Header' 162 116 4 hrs. 20 mins.-
Auxiliary 1-1 M-006D 1688
'1150 3 hrs. 5 mins.
- M-007B 1-2 i
Component 1
ti-0.'6A 188 100 4 hrs.
Cooling M-03cB-Vater 2
M-036A
- 188, 100 5 hrs. 17 mins.
M-036F M-036C 3
M-036A 2188
-100' 4 hrs.
1 HPI System 1-1 Suction M-033A-563
214 15 mins.
M-033B-1-2 Suction M-033A c563~
209-I hr 20 mins.
M-033B-
.1-2. Discharge M-033A~.
2813-
-2250 -
49 mins.
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