ML20072P972
| ML20072P972 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/29/1994 |
| From: | Bauer J COMMONWEALTH EDISON CO. |
| To: | Russell W NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20072P977 | List: |
| References | |
| NUDOCS 9409090039 | |
| Download: ML20072P972 (6) | |
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Downers Grove. Ilknois 60515 August 29,1994 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Attention:
Mr. William T. Russell
Subject:
Byron Station Inservice inspection Plan Section 7.0,
" Inservice Inspection Plan for Pressure Testing", Relief Request Cost Beneficial Licensing Action (CBLA)
Byron Station Units 1 and 2 (NPF-37/66; NRC Docket Nos. 50-454/455)
Refererices: 1. T. K. Schuster letter to R. E. Murley, dated December 4,1990
- 2. R. J. Barrett letter to T. J. Kovach, dated December 6,1991
Dear Mr. Russell:
In a December 4,1990 letter from T. K. Schuster to T. E. Murley, Commonwealth Edison Company (Comed) submitted the most recent revision of the Byron Station Inservice Inspection Plan, Section 7.0, " Inservice inspection Plan for Pressure sting" This revision was subsequently approved in the NRC Safety Evaluation aport issued on December 6,1991.
Revision Request Pursuant to 10 CFR 50.55a(g)(5)(iii), Comed is requesting to modify the inservice inspection requirements. The proposed revision incorporates Relief Request, HR-1,
" Alternate Hydrostatic Pressure Test Requirements for ASME Class 1,2 and 3 Repaired or Replaced Components", Relief Request HR-2, " Alternate Rules for 10 Year Hydrostatic Pressure for Class 3 Systems", and Technical Approach and Position, SP-06, " Adoption of Regulatory Guide 1.147 Approved Code Cases". The relief requests are consistent with ASME Code Case N-416-1 and N-498-1 which have been approved by the Board of Nuclear Codes and Standards (BNCS). Additional NDE requirements for Class 3 welds have also been incorporated into the Relief Request HR-1. Technical Approach and Position, SP-06, adopts NRC accepted ASME Code Cases that are listed in NRC Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability ASME Section XI, Division 1" kinlaibyrorrast416.wpf g
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l Mr. W. T. Russell August 29,1994 Cost Beneficial Licensing Action Commonwealth Edison respectfully requests that the subject relief request be prioritized as a Cost deneficial Licensing Action. The proposed relief request modifies a requirement that provides little or no safety benefit, yet will require significant resources to implement.
l The number of over-pressure hydrostatic tests for due to repairs varies with each outage. The cost of performing such tests also varies greatly depending upon the extent of the repairs and the ease / difficulty of isolating the repaired area. Typically, Byron performs four tests per refueling outage at an average cost of $10,000 per test.
Collectively, the two units at Byron undergo a refueling outage at a rate of three every two years. This equates to a savings of $60,000 per year for the site. Considering that the remaining life of the station is approximately 30 years, the total savings related l
to HR-1 alone would be roughly $2 million.
i in addition, Byron budgets approximately $50,000 per unit per year for scheduled j
system hydros. Again, considering the remaining 30 year life of the station, the total savings related to HR-2 and Technical Approach and Position SP-06 will be approximately $3 million (for Class 1,2 and 3 hydros).
l The resource savings due to these relief requasts, therefore, satisfies the NRC CBLA Task Force's threshold of $100,000.
Schedule l
Byron Station anticipates installing the Essential Service Water (SX) Cooling Tower l
Pipe Replacement Modification in April,1995. This modification will require relief from the ASME Code as addressed in Relief Request HR-1. Hot tapping and installation of line stops in the 24" ASME Class 3 underground SX supply piping will result in penetration of the pipe pressure boundary. These activities normally require a hydrostatic test prior to restoring the system to service, however, the SX Cooling Towers' supply lines cannot be isolated for a hydrostatic test without both units being shutdown and defueled. Commonwealth Edison, therefore, respectfully requests that the NRC Staff review and approve the requested revisions to the ISI program by March 15,1995.
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Mr. W. T. Russell August 29,1994 To the best of my knowledge and belief, the statements contained in this document are true and correct. In some respects these statements are not based on my personal knowledge, but on information furnished by other Comed employees, contractor employees, and/or consultants. Such information has been reviewed in accordance with company practice, and I believo it to be reliable.
Please address any comments or questions regarding this matter to this office.
Respectfully, royl k.
MU Joseph A. Bauer Nuclear Licensing Administrator :
Detailed Description of Proposed Change :
Section 7 Marked-up Pages :
Section 7 Typed Pages cc:
George F. Dick, Byron Project Manager - NRR R. P. Zimmerman, CBLA Programs - NRR H. Peterson, SRI - Byron B. Clayton, Branch Chief - Region 111 l
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ATTACHMENT 1 Detailed Description of Propose.d CF.snge Summary of Change The proposed change involves e revision to Section 7 of the Byron Unit 1 and Unit 2 Inservice Inspection (ISI) Plan, " Inservice Inspection Program Plan for Pressure Testing" The proposed revision incorporates Relief Request, HR-1, " Alternate Hydrostatic Pressure Test Requirements for ASME Class 1,2 and 3 Repaired or Replaced Components", Relief Request HR-2, " Alternate Rules for 10 Year Hydrostatic Pressure for Class 3 Systems", and Technical Approach and Position, SP-06, " Adoption of Regulatory Guide 1.147 Approved Code Cases" The relief requests are consistent with ASME Code Case N-416-1 and N-498-1 which have been approved by the Board of Nuclear Codes and Standards (BNCS). Additional NDE requirements for Class 3 welds have been incorporated into the Relief Request HR-1.
Technical Approach and Position, SP-06, adopts NRC accepted ASME Code Cases that are listed in NRC Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability ASME Section XI, Division 1" l
l Please note that Byron Station has incorporated Code Case N-498 for Class 1 and 2 systems. This Code Case has been previously approved for industry use by Regulatory Guide 1.147, as noted in the attached Technical Approach and Position, l
l l
Affected Sections of the ISI Plan - S_ection 7 Page Section Descriotion 2
Index Index 4
7.1.1 Inservice Pressure Testing 5
7.3.0 Alternate Code Rules (Title Change) 5 7.3.0.1 Relief Requests (Section Number Change) 5 7.3.0.2 ASME Code Cases (New) 7 7.7.0 References 16 Table 7.3.0-1 Relief Request Summaries New Relief Request HR-1 (New)
New Relief Request HR-2 (New) 17 Table 7.4.0-1 Technical Approach and Position Summaries New Technical Approach and Position SP-06 (New)
Page 1 of 3 i
4 Detailed Descfip_tLon of Revisions Page 2. Index Change title of Section 7.3 from " Relief Requests" to " Alternate Code Rules" Page 4. Section 7.1.1. Inservice Pressure Testing Add reference of applicable ASME Code Cases to the first sentence. Change first sentence to read as follows:
"The key features of this Plan are: the Relief Requests, the applicable ASME Code Cases, the explanation of technical approach and positions..
Page 5. Section 7.3.0. Relief Reauests Change section title from " Relief Requests" to " Alternate Code Rules" Page 5. Section 7.3.0.1. Relief B_eauests (New Section)
Move text in its entirety from the former Section 7.3.0 to the new section 7.3.1.
Page 5. Section 7.3.0.2. ASME Code Cases (New Section)
Insert A of Attachment 2 adds a new section that describes the use of ASME Code Cases.
Page 7. References Add Reference to Regulatory Guide 1.147, " Inservice inspection Code Case Acceptability ASME Section XI, Division 1" Page 16. Table 7.3.0-1. Relief Reauest Summaries Add Relief Request HR-1," Alternate Hydrostatic Pressure Test Requirements for ASME Class 1,2 and 3 Repaired or Replaced Components" Add Relief Request HR-2, Alternate Rules for 10 Year Hydrostatic Pressure Testing for Class 3 Systems.
Table 7.3.0-1 Attachments I
Attach Relief Request HR-1 to Table 7.3.0-1.
Attach Relief Request HR-2 to Table 7.3.0-1.
Page 2 of 3
Page 17. Table'7.4.0-1. Technical Accroach and Position Summaries Add Technical Approach and Position SP-06, " Adoption of Regulatory Guide 1,147 Approved Code Cases" Table 7.4.0-1 Attachments
. Attach Technical Approach and Position SP-06 to Table 7.4.0-1.
Schedule Re_quirements Byron Station anticipates installing the Essential Service Water (SX) Cooling Tower l
Pipe Replacement Modification in April,1995. This modification wiU require relief from the ASME Code as addressed in Relief Request HR-1. Hot tapping and installation of line stops in the 24" ASME Class 3 underground SX supply piping will result in penetration of the pipe pressure boundary. These activities normally require a hydrostatic test prior to restoring the system to service, however, the SX Cooling Towers' supply lines cannot be isolated for a hydrostatic test without both units being shutdown and defueled. Commonwealth Edison, therefore, respectfully requests that the NRC Staff review and approve the requested revisions to the ISI program by March 15,1995.
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