ML20072Q197
| ML20072Q197 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/29/1994 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20072P977 | List: |
| References | |
| PROC-940829, NUDOCS 9409090181 | |
| Download: ML20072Q197 (33) | |
Text
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1 ATTACHMENT 2 PROPOSED CHANGES TO SECTION 7 OF THE BYRON UNIT 1 AND UNIT 2 INSERVICE INSPECTION PLAN MARKED-UP PAGES i
l 9409090181 940829 PDR ADOCK 05000454 P PDR
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ENCLOSURE 2 SECTION 7.0 INSERVICE INSPECTION PROGRAM PLAN FOR PRESSURE TESTING
Rsvision 0 OL l
Section Descriotion Page 7.1 Introduction and Plan Description 4 7.2 ISI Classification Boundary Drawings 4
-RelleLJtaqueste 'L I% E I V <.5 5 7.3 4 7.4 Technical Approach and Positions 5 7.5 ISI Plan Summary 5 7.6 Augmented Inservice Inspection Requirements 6 7.7 References 7 l
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Rovision OA BYRON UNIT 1 AND UNIT 2 INSERVICE PRESSURE TEST PLAN 7.
1.0 INTRODUCTION
AND PLAN DESCRIPTION This Inservice Inspection Plan for visual examination of ASME Class 1, 2 and 3 components and systems at nominal operating pressure and hydrostatic
- pressure was developed in accordance with the inservice inspection requirements in ASME Section XI, S ubs ections IWA, IWB, IWC and IWD. All references to the " Code" in this plan are taken from the ASME Boiler and Pressure Vessel Code,Section XI, Division I, " Rules for Inservice
. Inspection of Nuclear Power Plant Components", the 1983 Edition through j j and including the Summer 1983 Addenda. j 1
This Inservice Inspection Plan will be effective for Unit 1 from September 16, 1985 through and including September 16, 1995 and from August 21, 1987 through and including August 21, 1997 for Unit 2. -
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2 7.1.1 Inservice Pressure Testing h %CuW 1 The key features of this Plan are; the Relief Requests, the explanation of technical approach and positions, and the definition of scope for the Inservice Pressure Test Program. The details of the Inservice Pressure ;
Test Program are addressed in other documents that are available at Byron. Marked up system boundary drawings, administrative procedures, NDE procedures and other records required to define and execute the Inservice Pressure Test Plan are all retained at Eyron.
7.2.0 ISI PRESSURE TEST BOUNDARY DRAWINGS The Byron Unit 1 and Unit 2 ISI Classification Boundary Drawings (ISI CBDs) clearly define the scope of the ISI Class 1, 2 and 3 Inservice Inspection Program. Systems or portions of systems subject to the requirements of ASME Section XI have been identified on the ISI-CBDs. One set of ISI-CBDs have been included with this Inservice Inspection plan.
The Legend and Symbols drawing provided with tha ISI-CBDs explains how Code Exemptions have been applied to the Byron Unit 1 and Unit 2 Inservice Inspection Program. Lists of ISI-CBDs for Byron Unit 1 and Unit 2 have been included in Table 7.2.0-1 and Table 7.2.0-3 (sorted by unit and System name) and Table 7. 2.0-2 and Table 7. 2. 0-4 (sorted by unit and ISI-CBD number).
The system Inservice Inspection classification, developed specifically to define the extent to which Section XI requirements will be applied, may differ from the design classification (ASME Section III). These differences exist because the design of certain rfstem or portions of l systems was optionally upgraded or modified by the Owner. The ISI-CBDs are limited to safety related systems which contain steam or radioactive materials in accordance with Regulatory Guide 1.26.
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Revision OA The ISI-CBDs submitted with this Inservice Inspection Plan are for Reference Only. A controlled set of ISI-CBDs will be maintained at Byron. The controlled set of ISI-CBDs will be based on as-built P& ids to ensure that all system modifications are properly addressed by the ISI Program. The controlled set of ISI-CBDs indicate the system pressure test boundaries as well as the individual test boundaries.
7 3. G AIte.rrwk C,w(. G ks
,%+ r0- Relief Reouests
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Pursuant to 10CTR50.55a (g) (5) (iv). Relief Requests have been included when specific requirements in the Code are considered impractical. The enclosed Relief Requests are subject to change throughout the inspection )
interval. If testing requirements are determined to be impractical during the course of the interval, additional or modified Relief Requests will be submitted in accordance with 10CTR50.55a (g) (5) (iv).
A summary of Relief Requests is provided in Table 7.3.0-1
'9A][nSert /\
7.4.0 Tech ical Accreach and Positions When the requirements of the Code are not easily interpreted, Dyron Station has reviewed general licensing / regulatory requirements and industry practice to determine a practical method of implementing each code requirement. The Technical Approach and Position documents in this section of the Plan have been provided to clarify Byron's implementation of the Code.
i A summary of Technical Approach and Positions is provided in Table 7.4.0-1.
7.5.0 ISI Plan Summary Table 7. 5. 0-1, "ISI Plan Summary includes the following information:
Examination Category and Examination Category Description The Examination Category and its description as defined in ASME Section XI Tables IWB-2 500-1. IWC-2500-1, and IWD-2500-1 are listed.
Item Number and Item Number Description The Item Number and its description as described in ASME Section XI Table s IWB-2500-1, IWC-2500-1, and IWD-2500-1 are listed.
NOTE: Some Examination Categories and Item Numbers are not applicable to Byron Unit 1 and Unit 2. Table 7.5.0-1, "ISI Plan Summary" lists all Examination Categories and Item Numbers in the referenced Code. The Remarks column at the f ar right of the table explains when an Examination l Category and Item Nitmber is not a.pplicable because Byron )
Unit 1 and Unit 2 do not have any components that would be assigned the subject Examination Category and Item Number.
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j 7.3.0.2 ASME Code Cases i
Pursuant to Footnote 6 of 10CFR50.55a, alternate rules in the form of ASME Code Cases may be used at the discretion of Byron Station if the Code Cases are j determined to be suitable for use and listed in Regulatory Guide 1.147, " Inservice 4
Inspection Code Case Acceptability - ASME Section XI, Division 1". The rules of the Code Case and any other limitations on its use as specified in Regulatory Guide 1.147 shall be satisfied when implementing the Code Case. The use of other Code
> Cases not endorsed by Regulatory Guide 1.147 may be authorized by the Director of the Office of Nuclear Reactor Regulation upon request in accordance with 10CFR50.55a(a)(3). Acceptable Code Cases for use at Byron Station are listed in l Technical Approach and Position SP-06. Superceded or annulled Code Cases may j continue to be used provided that the Code Cases were identified in the ISI Program 4 Plan prior to being superceded or annulled.
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, Revision 04
- and volume Control, Residual Heat Removal, Fuel Pool Cooling and Clean-up, Radioactive Waste Gas, Offgas/ Hydrogen Recombiner, and Process Sampling.
The visual examinations are conducted at nomimal operating pressure at
- intervals of once per refueling cycle.
The Byron Unit 1 and Unit 2 ISI Classification Drawings (ISI-CBDs) define l the scope of the NUREG 0737 III.D.1.1 inspection program. ASME Class 2 l and 3 systems within the scope of the Inservice Pressure Test Plan that are located outside containment are'also included in the scope of the
, Augmented Inspection program and are tested at intervals of once per refueling cycle, i
One set of ISI-CBDs have been included with this Inservice Inspection plan. These drawings are_for reference only and a controlled set of ISI-CBDs will be maintained at Byron Station. -The controlled set of ISI-CBDs will be based on as-built P& ids to ensure that all system modifications are properly addressed by the ISI program.
7.
7.0 REFERENCES
The reference used to develop this Inservice Inspection Program Plan include:
- a. Code of Federal Regulations, Title 10, Part 50, Paragraph 50.55a,
" Codes and Standards".
- b. ASME Boiler and Pressure Vessel Code,Section XI, Division I,
" Inservice Inspection of Nuclear Power Plant Components", 1983 Edition through Summer 1983 Addenda.
- c. Regulatory Guide 1.26, Revision 3, " Quality Group Classifications and Standards for Water , S te am , and Radioactive Waste- Containing Components of Nuclear Power Plants".
- d. Code of Federal Regulations, Title 10, Part 50, Paragraph 2,
" Definitions", the definition of " Reactor Coolant Pressure Boundary".
- e. NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants". LWR Edition, Section 3.2.2, Revision 1, " System Quality Group Classifications".
- f. Updated Final Ayalysis Report, Byron Station Unit 1 and Unit 2.
- g. Technical Specifications, Amendment 35, Byron Station Unit 1 and Unit 2.
- h. NUREG 0737 III.D.l.1, " Integrity of Systems Outside Containment Likely to Contain Radioactive Material for Pressurized-Water Reactors and Boiling-Water Reactors".
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l BYRON STATION UNIT 1 AND UNIT 2 INSERVICE INSPECTION PLAN Table 7.3.0-1 RELIEr REQUEST SUMMARIES RELIEF l
REQUEST NUMBER GENERAL DESCRIPTICRI I
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l Rev.O RELIEF REQUEST NUMBER: IIR-1 l
COAIPONENT IDENTIFICATION ,
Code Classes: 1, 2, and 3
References:
IWA-4400 IWA-4600 IWA-5000 Examination Categories: B-P C-II D-A, D-B, D-C Item Numbers: B15.10 through B15.71 C7.10 through C7.80 DI.10, D2.10, and D3.10
Description:
Alternate Ilydrostatic Pressure Test Requirements for ASME Class 1, 2 and 3 Repaired / Replaced Components Component Numbers: All ASME Class 1,2, and 3 pressure retaining components subject to Ilydrostatic Pressure Tests per IWA-4400 and IWA-4600.
CODE REOUIREMENT IWA-4400(a) and IWA-4600 requires an elevated pressure hydrostatic test to be perfonned in accordance with IWA-5000 after repairs by welding or the attachment of replacement items by welding on the pressure retaining boundary of ASME Class 1,2, or 3 components, except those exempted by IWA-4400(b) or IWA-7400.
BASIS FOR RELIEF Elevated pressure hydrostatic tests are difficult to perform and often represent a true hardship. Some of the difficulties associated with hydrostatic testing include:
- Complicated or abnormal valve line-ups to provide system draining, filling, venting, and system / component isolation.
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Rev.0 1
- Relief valves with setpoints lower than the hydrostatic test pressure must be blocked closed, or removed and blank flanged. This process requires draining, refilling of the system prior to the test and draining, valve restoration, and refilling once more for system restoration. Improper blocking or gagging can result in damage to the relief valve.
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- Valves that are not normally used for isolation are often required to provide pressure i isolation for a hydrostatic test. In order to provide tight isolation, time consuming valve maintenance would be required prior to a hydrostatic test.
- The radiation exposure required to setup and perform a hydrostatic test is quite high in comparison to an operational pressure test due to time required for valve manipulation, filling and venting, valve maintenance, etc).
The difGculties encountered in performing a hydrostatic pressure test are prohibitive when weighed against the beneSts. Industry experience, which is supported by Byron Station experience, shows that most through wall leakage is detected during system operation as opposed to during the elevated pressure tests associated with the ten-year hydrostatic test.
i Little benefit is gained from the added challenge to the piping system provided by an elevated pressure hydrostatic test when compared to an operational test. The piping stress experienced by a hydrostatic test does not include the significant stresses associated with the thermal growth and dynamic loading during operation or a design basis event. Therefore, the system is more likely to leak at operating conditions, due to operational dynamic and i thermal loading, than during the careful, slow pressurization associated with a hydrostatic I test. I l
The acceptability of performing nominal operating pressure tests in lieu of hydrostatic tests is l also supported by the recent approval by the Board of Nuclear Codes and Standards of ASME Code Case N-416-1, " Alternate Pressure Test Requirement for Welded Repairs or j j Installation of Replacement Items by Welding for Class 1,2, and 3 Systems,Section XI, l Division 1" This Code Case allows a system leakage test at nominal operating pressure and temperature, in accordance with IWA-5000 of the 1992 Edition of Section XI, to be performed in lieu of a hydrostatic test, provided that Non Destructive Examination (NDE) of the weld (s) is performed in acccordance with the methods and acceptance criteria of the applicable subsection of the 1992 Edition of Section III.
Based on the above, Byron Station requests relief from the ASME Section XI Class 1,2 and 3 repair /replacemnent elevated pressure hydrostatic testing requirements.
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Rev.O PROPOSED ALTERNATE PROVISIONS As an alternate to the existing ASME Section XI requirements, Byron Station will adopt the provisions of Code Case N-416-1, as approved by the Board of Nuclear Codes and Standards, with additional NDE requirements. Listed below are th: proposed alternate provisions to be performed, which is a summary of Code Case N-1-416-1 requirements with additional NDE requirements imposed by Byron Station.
- A VT-2 visual examination will 1,e performed at nominal operating pressure and temperature in conjunction with a system leakage test in accordance with IWA-5000 of the 1992 Edition of Section XI. The examination will be performed prior to or immediately upon return of the component to service.
l l - Non-Destructive Examination will be performed on the repair / replacement welds or i welded areas with the methods and acceptance criteria of the applicable Subsection of ,
the 1992 Edition of Section Ill. In addition, when NDE is required by ND-5222 for Class 3 components, an additional surface examination will be performed on the root l (pass) layer. A surface examination will also be performed on Class 3 socket / fillet welds.
- The use of this relief request shall be documented on the applicable NIS-2 Form.
- If the previous version of Code Case N-416 were used to defer a Class 2 hydrostatic test, the deferred test may be eliminated when the requirements of this relief request are ;
met. In addition, the NDE methods and acceptance criteria of the Code Edition and addenda used for the repair must be reconciled to those of the 1992 Edition of Section III.
APPLICABLE TIME PERIOD Relief is requested for the first ten-year inspection interval of the inservice Inspection Program for Byron Unit I and Unit 2.
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t Rev.O RELIEF REQUEST NUMBER: IIR-2 CONIPONENT IDENTIFICATION Code Classes: 3
References:
IWD-5210 IWD-5223 Examination Categories: D-A D-B D-C Item Numbers: D1.10 D2.10 D3.10
Description:
Alternate Rule,s for 10 Year Hydrostatic Pressure Testing for Class 3 Systems I
l Component Numbers: All Class 3 Systems subject to Hydrostatic l
Testing per IWD-2500.
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! CODE REOUIRENIENT IWD-2500 requires elevated pressure hydrostatic tests (VT-2) to be performed each 10 year inspection interval on ASME Class 3 pressure retaining components in accordance with IWD-5223.
BASIS FOR RELIEF Elevated pressure hydrostatic tests are difficult to perform and often represent a true hardship without benefits gained. Some of the difficulties associated with 10 year system hydrostatic testing include:
- Complicated or abnormal valve line-ups to provide system draining, filling, venting, and system isolation.
l
- Relief valves with setpoints lower than the hydrostatic test pressure must be blocked Page 1 of 3
Rev.O closed, removed and blank flanged. This process requires draining, refilling of the system prior to the test and draining, valve restoration, and refilling once more for system restoration. Improper blocking or gaging can result in damage to the relief valve.
- Valves that are not normally used for isolation are often required to provide pressure isolation for a hydrostatic test. In order to provide tight isolation, time consuming valve maintenance would be required prior to a hydrostatic test.
- The radiation exposure required to perform hydrstatic testing is quite high in comparison to operational pressure testing due to time required for valve manipulation, Olling and venting, valve maintenance, etc.
At hydrostatic test pressures required by ASME Section XI,10% and 25% over the piping design pressure, a hydrostatic test does not induce significantly more stresses in the system than in a system operational test. Also, the system stresses associated with the hydrostatic l test do not compare to the stress associated with thermal growth and dynamic loading during design basis events. Therefore, little benefit is gained from the hydrostatic test over the oeprational pressure test.
Industry experience, which Byron Station experience supports, indicates that most through i wall leakage is detected during system operation as opposed to hydrostatic testing at elevated pressures. ,
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These arguments are also supported by ASME Code Case N-498-1, " Alternate Rules for 10 Year Ilydrostatic Pressure Testing for Class 1, 2 and 3 Systems,Section XI, Division 1" and ASME Code Case N-498, " Alternate Rules for 10 Year Hydrostatic Pressure Testing for Class I and 2 Systems,Section XI, Division 1" Code Case N-498-1 has been reviewed and approved by the Board of Nuclear Codes and Standards (BNCS). Code Case N-498 for Class 1 and 2 systems had previously been approved and accepted for industry use in Regulatory Guide 1.147, Revision 10.
Based on the above, Byron Station requests relief from the ASME Section XI Class 310 Year System Ilydrostatic Pressure Testing requirements.
PROPOSED ALTERNATE PROVISIONS A system pressure test with a VT-2 visual examination will be perfonned with the Class 3 system pressurized to a test pressure equal to nominal operating pressure. The visual examination will be conducted after the system has been pressurized to test pressure for a minimum of 10 minutes for noninsulated components or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components prior to examination. The system will be maintained at test pressure for the duration of the Page 2 of 3
Rev.0 VT-2 visual examination. IIydrostatic test instrumentation requirements of IWA-5260 are not applicable as test parameter recording is performed by normal operating system instrumentation or equivalent.
The system pressure test will be conducted at or near the end of the inspection interval or during the same inspection period of each inspection interval.
The boundary subject to test pressurization and VT-2 visual examination during the system pressure test shall extend to all Class 3 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 safety or relief valve) or valve capable of automatic closure when the safety function is required.
APPLICABLE TIME PERIOD Relief is requested for the first ten-year inspection interval of the Inservice Inspection Program for Byron Unit I and Unit 2 which ends on 9/16/95 and 8/21/97, respectively, i
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7 Rsvision 0 BYRGI STATION UNIT 1 AND UNIT 2 INSERVICE INSPECTION PLAN Table 7.4.0-1 TECIDTIf'it APPROACM AND POSITION SUMMARIES TECHNICAL APPROACH AND POSITION NUMBER faZliKRAL DESCRIPTION SP-01 System Pressure Psv determination when a safety or relief valve pressure setting is greater than the system design pressure. i SP-02 ASME Class 2 and 3 pressure retaining system boundary..
SP-03 Exemption of Class 2 and 3 penetrations and associated piping. ,
SP-04 Exemption of various TW, SD and SI components.
SP-05 Exemption of Class 2 and 3 CV components.
SP-ob Adophoo .c f Re30 k+ey 6'dJc l./97 ApervWA Cocle cmea I
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l BYRON STATION UNITS 1 AND 2 l ISI/IST TECIINICAL APPROACH AND POSITION: SP-06 COMPONENT IDENTIFICATION Code Class: 1, 2, and 3
Reference:
U.S. NRC Regulatory Guide 1.147 l l
10CFR 50.55a Footnote 6 l
Examination Category: Various Item Numbers: Various
Description:
Adoption of Regulatory Guide 1.147 Approved Code Cases
- CODE REOUIREMENT l
Proposed alternatives to the provisions of the ASME Code may be used when authorized by i l
the Director of the Office of Nuclear Reactor Regulation, as specified in paragraph (a)(3) of 1' l 10CFR50.55a. Footnote 6 of 10CFR50.55a specifically addresses the use of ASME Code
! Cases that are determined suitable by the Commission and listed in Regulatory Guide 1.147.
POSITION This Technical Approach and Position identifies those ASME Section XI, Division 1, Code !
Cases that may be used for preservice/ inservice inspection or used for a repair / replacement l during the first 10 year Interval for Byron Station Units 1 and 2. These Code Cases have I been accepted by the NRC Staff for application and are listed in Regulatory Guide 1.147, j l Inservice Inspection Code Case Acceptability ASME Section XI Division 1. Any of the Code Cases listed in Table SP-06-1, Acceptable Code Cases for Byron Station Implementation, may be used at any time given at the discretion of Byron Station. Use of a Code Case does not indicate a commitment to use the Code Case for the remainder of the Interval. Code Cases shall be used as conditions warrant. However, whenever a Code Case is used, adherence to any limitations on its use as specified in Regulatory Guide 1.147, I
appropriate revision, is required . Table SP-06-1 will be revised periodically to incorporate l Code Cases endorsed by later revisions of Regulatory Guide 1.147. Superceded or annulled Code Cases that were identified in the ISI Program Plan when the Code Cases were :
endorsed, may continue to be used.
Page 1 of 2
BYRON STATION UNITS 1 AND 2 ISI/IST TECIINICAL APPROACII AND POSITION: SP-06 TABLE SP-06-1 ACCEPTABLE CODE CASE FOR BYRON STATION IMPLEMENTATION si l Code Case ASME R.G. 1.147 Code Case ASME R.G.1.147 l Approval / Revision !
Approval / Revision Reaffirmation Reaffirmation i 1705-1 12-03-90 10 N-435-1 07-30-89 10 I N-98 N-113-1 12-03-90 10 N-437 07-30-89 10 ,
N-211 04-30-90 10 N-448 04-30-90 10 N-235 12-03-90 10 N-449 04-30-90 10 N-278 02-19-89 10 N-457 12-03-90 10 N-307-1 12-03-90 10 N-458 08-14-90 10 N-311 04-30-90 10 N-460 05-13-91 10 C
N-335-1 05-13-91 10 N-461 08-14-91 10 N-355 12-03-90 10 N-463-1 03-05-90 10 N-356 10-23-88 10 N-465 08-14-91 10 N-389 05-14-89 10 N-471 04-30-90 10 N-401-1 05-13-91 10 N-472 03-08-89 10 l N-402-1 03-14-91 10 N-481 03-05-90 10 N-408-2 07-24-89 10 N-485-1 08-14-91 10
]
l N-409-2 05-13-91 10 N-489 08-14-90 10 N-415 08-14-91 10 N-490-1 05-13-91 10 N-416 12-03-90 10 N-491 03-14-91 10 N-419 05-13-91 10 N-494 12-03-90 10 N-426 05-13-91 10 N-495 12-03-90 10 N-427 12-05-88 10 N-496 03-14-91 10 N-429-1 03-05-90 10 N-498 05-13-91 10 N-432 02-20-89 10 Page 2 of 2
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ATTACHMENT 3 .
PROPOSED CHANGES TO SECTION 7 OF THE BYRON UNIT 1 AND UNIT 2 INSERVICE INSPECTION PLAN TYPED PAGES i
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i j ENCLOSURE 2 i
SECTION 7.0 g INSERVICE INSPECTION PROGRAM PLAN FOR I
PRESSURE TESTING I 1
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. 4 Revision Oa Section Descrintion Page 7.1 Introduction and Plan Description 4 7.2 ISI Classification Boundary Drawings 4 7.3 Alternate Code Rules 5 7.4 Technical Approach and Positions 5 7.5 ISI Plan Summary 5 7.6 Augmented Inservice Inspection Requirements 6 7.7 References 7 I
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l BYRON UNIT 1 AND UNIT 2 INSERVICE PRESSURE TEST PLAN i l
7.
1.0 INTRODUCTION
AND PLAN DESCRIPTION This Inservice Inspection Plan for visual examination of ASME Class 1, 2 and 3 components and systems at nominal operating pressure and hydrostatic pressure was developed in accordance with the inservice inspection '
i requirements in ASME Section XI, Subsections IWA, IWB, IWC and IND. All references to the " Code" in this plan are taken from the ASME Boiler and Pressure Vessel Code,Section XI, Division I, " Rules for Inservice Inspection l, of Nuclear Power Plant Components", the 1983 Edition through and including the Summer 1983 Addenda.
This Inservice Inspection Plan will be effective for Unit 1 from September 16, 1985 through and including September 16, 1995 and from August 21, 1987 through and including August 21, 1997 for Unit 2. j 7.1.1 Inservice Pressure Testing l The key 1satures of this Plan are; the Relief Requests, the applicable ASME j code cases. the explanation of technical approach and positions, and the l definition of scope for the Inservice Pressure Test Program. The details of the Inse rvice Pressure Test Program are addressed in other documents that
. are available at Byron. Marked up system boundary drawings, administrative
( procedures, NDE procedures and other records required to define and execute the Inservice Pressure Test Plan are all retained at Byron.
7.2.0 ISI PRESSURE TEST BOUNDARY DRAWINGS The Byron Unit 1 and Unit 2 ISI Classification Boundary Drawings (ISI_CBDs) clearly define the scope of the ISI Class 1, 2 and 3 Inservice Inspection Program. Systems or portions of systems subject to the requirements of ASME Section XI have been identified on the ISI-CBDs. One set of ISI-CBDs have been included with this Inservice Inspection plan.
The Legend and Symbols drawing provided with the ISI-CBDs explains how Code Exemptions have been applied to the Byron Unit 1 and Unit 2 Inservice Inspection Program. Lists of ISI-CBDs for Byron Unit 1 and Unit 2 have been included in Table 7.2.0-1 and Table 7.2.0-3 (sorted by unit and System name) and Table 7.2.0-2 and Table 7.2.0-4 (sorted by unit and ISI-CBD number) .
The system Inservice Inspection classification, developed specifically to define the extent to which Section XI requirements will be applied, may dif fer f rom the design classification . (ASME Section III) . These differences exist because the design of certain system or portions of systems was optionally upgraded or modified by the Owner. The ISI-CBDs are limited to safety related systems which contain steam or radioactive materials in accordance with Regulatory Guide 1.26.
7.0 2479z/0048z/040390
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Revision Oa The ISI-CBDs submitted with this Inservice Inspection Plan are For Reference Only. A controlled set of ISI-CBDs will be maintained at Byron. The !
controlled set of ISI-CBDs will be based on as-built P& ids to ensure that all system modifications are properly addressed by the ISI Program. The controlled set of ISI-CBDs indicate the system pressure test boundaries as well as the individual test boundaries. j 7.3.0 Alternate Code Rules 7.3 0.1 Felief Reauests Pursuant to 10CFR50.55a (g) (5) (iv), Relief Requests have been included when specific requirements in the Code are considered impractical. The enclosed Relief Requests are subject to change throughout the inspection interval. If testing requirements are determined to be impractical. .
during the course of the interval, additional or modified Relief Requests will be submitted in accordance with ~100FR50.55a (g) (5) (iv).
A summary of Relief Requests is provided in Table 7,3.0-1 7.3.0.2 ASME Code Cases Pursuant to Footnote 6 of 10CFR50.55a, alternate rules in the form of ASME Code Cases may be used at the discretion of Byron Station if the Code Cases are determined to be suitable for use and listed in Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability -
ASME Section XI, Division 1". The rules of the Code Case and any other
! limitations on its use as specified in Regulatory Guide 1.147 shall be l satisfied when implementing the Code Case. The use of other Code Cases l not endorsed by Regulatory Guide 1.147 may be authorized by the Director
( of the Office of Nuclear Reactor Regulation upon request in accordance with 10CFR50.55a (a) (3) . Acceptable Code Cases for use at Byron Station are listed in Technical Approach and Position SP-06. Superceded or l annulled Code Cases may continue to be used provided that the Code Cases l were identified in the ISI Program Plan prior to being superceded or l annulled.
! 7. Technical Accroach and Positions I
When the requirements of the Code are not easily interpreted, Byron Station has reviewed general licensing / regulatory requirements and industry practice to determine a practical method of implementing each code requirement. The Technicr.1 Approach and Position documents in this section of the Plan have been provided to clarify Byron's implementation of the Code.
A summary of Technical Approach and Positions is provided in Table 7.4'.0-1.
7.0 5-l
! 24792/0048z/040390 1
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7.~
Revision Oa and Volume control, Residual Heat Removal, Fuel Pool Cooling and Clean-up, Radioactive Waste Gas, Offgas/ Hydrogen Recombiner, and Process Sampling. The visual examinations are conducted at nomimal operating pressure at intervals ;
of once per refueling cycle. l l
The Byron Unit 1 and Unit 2 ISI Classification Drawings (ISI-CBDs) define the l scope of the NUREG 0737 III.D.1.1 inspection program. ASME Class 2 and 3 ;
cystems within the scope of the Inservice Pressure Test Plan that are located i outside containment are also included in the scope of the Augmented l Inspection program and are tested at intervals of once per refueling cycle. I l
One set of ISI-CBDs have been included with this Inservice Inspection plan. ]
These drawings are for reference only and a controlled set of ISI-CBDs will be maintained at Byron Station. The controlled set of ISI-CBDs will be based on as-built P& ids to ensure that all system modifications are properly addressed by the ISI program.
7.
7.0 REFERENCES
The reference used to develop this Inservice Inspection Program Plan include:
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- a. Code of Federal Regulations, Title 10, Part 50, Paragraph 50.55a, " Codes and Standards". ,
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- b. ASME Boiler and Pressure Vessel Code,Section XI, Division I, " Inservice Inspection of Nuclear Power Plant Components", 1983 Edition through l Summer 1983 Addenda. j I
- c. Regulatory Guide 1.26, Revision 3, " Quality Group Classifications and i Standards for Water , Steam , and Radioactive WasteContaining Components I of Nuclear Power Plants".
- d. Code of Federal Regulations, Title 10, Part 50, Paragraph 2,
" Definitions", the definition of " Reactor Coolant Pressure Boundary". ,
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- e. NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants". LWR Edition, Section 3.2.2, Revision 1, " System Quality Group Classifications".
- f. Updated Final Ayalysis Report, Byron Station Unit 1 and Unit 2.
- g. Technical Specifications, Amendment 35, Byron Station Unit 1 and Unit 2.
- h. NUREG 0737 III.D.1.1, " Integrity of Systems outside Containment Likely to Contain Radioactive Material for Pressurized-Water Reactors and Boiling-Water Reactors",
- i. Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability,Section XI, Division 1."
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Revision Oa BYRON STATION UNIT 1 AND UNIT 2 INSERVICE INSPECTION PLAN Table 7.3.0-1 RELIEF REOUEST SUMMARIES RELIEF i REQUEST NUMBER GENERAL DESCRIPTION HR-1 Alternate Hydrostatic Pressure Test Requirements for ASME Class 1, 2 and 3 Repaired or Replaced Components.
HR-2 Alternate Rules for 10 year Hydrostatic Pressure Testing for Class 3 Systems.
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I Revision 0 l RELIEF REQUEST MUMBER: HR-1 COMPONENT IDENTIFICATION Code Classes: 1, 2, and 3
References:
IWA-4400 l IWA-4600 IWA-5000 l
Examination Categories: B-P C-H D-A, D-B, D-C Item Numbers: B15.10 through B15.71 C7.10 through C7.80 D1.10, D2.10, and D3.10 '
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Description:
Alternate Hydrostatic Pressure Test !
Requirements for ASME Class 1, 2 and 3 '
Repaired / Replaced Components j Component Numbers: All ASME Class 1, 2, and 3 pressure retaining components subject to Hydrostatic Pressure Tests per IWA-4400 and IWA-4600.
CODE REQUIREMENT IWA-44 0 0 (a) and IWA-4600 requires an elevated pressure hydrostatic test to be performed in accordance with IWA-5000 after repairs by welding or the attachment of replacement items by welding on the pressure retaining boundary of ASME Class 1, 2, or 3 components, except those exempted by IWA-4400(b) or IWA-7400.
BASIS FOR RELIEF Elevated pressure hydrostatic tests are difficult to perform and often i represent a true hardship. Some of the difficulties associated with hydrostatic testing include:
- Complicated or abnormal valve line-ups to provide system draining, filling, venting, and system / component isolation.
! - Relief valves with setpoints lower than the hydrostatic test pressure must be blocked closed, or removed and blank flanged. This process requires draining, refilling of the system prior to the test and draining, valve restoration, and refilling once more for system restoration. Improper blocking or gagging can result in damage to the relief valve.
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- Valves that are not normally used for isolation are often required to provide pressure isolation for a hydrostatic test. In order to provide tight isolation, time consuming valve maintenance would be required prior to a hydrostatic test.
- The radiation exposure required to setup and perform a hydrostatic test is quite high in comparison to an operational pressure test due to time ;
required for valve manipulation, filling and venting, valve maintenance, etc). ;
The difficulties encountered in performing a hydrostatic pressure test are ,
prohibitive when weighed against the benefits. Industry experience, which is '
supported by Byron Station experience, shows that most through wall leakage is detected during system operation as opposed to during the elevated pressure tests associated with the ten-year hydrostatic test.
Little benefit is gained from the added challenge to the piping system provided by an elevated pressure hydrostatic test when compared to an j operational test. The piping stress experienced by a hydrostatic test does not include the significant stresses associated with the thermal growth and dynamic loading during operation or a design basis event. Therefore, the system is more likely to leak at operating conditions, due to operational dynamic and thermal loading, than during the careful, slow pressurization associated with a hydrostatic test.
The acceptability of performing nominal operating pressure tests in lieu of ,
hydrostatic tests is also supported by the recent approval by the Board of Nuclear Codes and Standards of ASME Code Case N-416-1, " Alternate pressure Test Requirement for Welded Repairs or Installation of Replacement Items by Welding for Class 1, 2, and 3 Systems,Section XI, Division 1". This Code t Case allows a system leakage test at nominal operating pressure and temperature, in accordance with IWA-5000 of the 1992 Edition of Section XI, to be performed in lieu of a hydrostatic test, provided that Non Destructive Examination (NDE) of the weld (s) is performed in acccordance with the methods and acceptance criteria of the applicable subsection of the 1992 Edition of Section III.
Based on the above, Byron Station requests relief from the ASME Section XI Class 1, 2 and 3 repair /replacemnent elevated pressure hydrostatic testing requirements. ;
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PROPOSED ALTERNATE PROVISIONS As an alternate to the existing ASME Section XI requirements, Byron Station will adopt the provisions of Code Case N-416-1, as approved by the Board of Nuclear Codes and Standards, with additional NDE requirements. Listed below are the proposed alternate provisions to be performed, which is a summary of Code Case N-1-416-3 requirements with additional NDE requirements imposed by Byron Station.
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- A VT-2 visual examination will be performed at nominal operating pressure and temperature in conjunction with a system leakage test in accordance with IWA-5000 of the 1992 Edition of Section XI4 The examination will be performed prior to or immediately upon return of the component to service.
- Non-Destructive Examination will be performed on the repair / replacement welds or welded areas with the methods and acceptance criteria of the applicable Subsection of the 1992 Edition of Section III. In addition, when NDE is required by ND-5222 for Class 3 components, an additional surface examination will be performed on the root (pass) layer. A surface examination will also be performed on Class 3 socket / fillet welds.
- The use of this relief request shall be documented on the applicable NIS-2 Form.
- If the previous version of code Case N-416 were used to defer a Class 2 hydrostatic test, the deferred test may be eliminated when the requirements !
l of this relief request are met. In addition, the NDE methods and acceptance criteria of the Code Edition and addenda used for the repair j must be reconciled to those of the 1992 Edition of Section III. l APPLICABLE TIME PERIOD Relief is requested for the first ten-year inspection interval of the Inservice Inspection Program for Byron Unit 1 and Unit 2.
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Revision 0 RELIEF REQUEST NUMBER: HR-2 COMPONENT IDENTIFICATION Code Classes: 3
References:
IWD-5210 IWD-5223 Examination Categories: D-A D-B D-C Item Numbers: D1.10 D2.10 D3.10 1 1
Description:
Alternate Rules for 10 Year Hydrostatic Pressure Testing for Class 3 Systems j Component Numbers: All Class 3 Systems subject to Hydrostatic Testing per IWD-2500. l i
CODE REQUIREMENT I IWD-2500 requires elevated pressure hydrostatic tests (VT-2) to be performed each 10 year inspection interval on ASME Class 3 pressure retaining components in accordance with IWD-5223.
BA_ SIS FOR RELIEF Elevated pressure hydrostatic tests are difficult to perform and often represent a true hardship without benefits gained. Some of the difficulties associated with 10 year system hydrostatic testing include:
- Complicated or abnormal valve line-ups to provide system draining, filling, venting, and system isolation.
- Relief valves with setpoints lower than the hydrostatic test pressure must be blocked closed, removed and blank flanged. This process requires draining, refilling of the system prior to the test and draining, valve restoration, and refilling once more for system restoration. Improper blocking or gaging can result in damage to the relief valve.
- Valves that are not normally used for isolation are often required to l
provide pressure isolation for a hydrostatic test. In order to provide tight isolation, time consuming valve maintenance would be required prior to a hydrostatic test.
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l f - The radiation exposure required to perform hydrstatic testing is quite high j in comparison to operational pressure testing due to time required for valve manipulation, filling and venting, valve maintenance, etc.
At hydrostatic test pressures required by ASME Section XI, 10% and 25% over the piping design pressure, a hydrostatic test does not induce significantly more stresses in the system than in a system operational test. Also, the system stresses associated with the hydrostatic test do not compare to the stress associated with thermal growth and dynamic loading during design basis events. Therefore, little benefit is gained from the hydrostatic test over the oeprational pressure test.
Industry experience, which Byron Station experience supports, indicates that most through wall leakage is detected during system operation as opposed to hydrostatic testing at elevated pressures. ,
These arguments are also supported by ASME Code Case N-498-1, " Alternate Rules ,
for 10 Year Hydrostatic Pressure Testing for Class 1, 2 and 3 Systems, Section ,
XI, Division 1" and ASME Code Case N-498, " Alternate Rules for 10 Year l Hydrostatic Pressure Testing for Class 1 and 2 Systems,Section XI, Division 1". Code Case N-498-1 has been reviewed and approved by the Board of Nuclear Codes and Standards (BNCS). Code Case N-498 for Class 1 and 2 systems had previously been approved and accepted for industry use in Regulatory Guide 1.147, Revision 10.
Based on the above., Byron Station requests relief from the ASME Section XI j Class 3 10 Year System Hydrostatic Pressure Testing requirements.
PROPOSED ALTERNATE PROVISIONS A system pressure test with a VT-2 visual examination will be performed with the class 3 system pressurized to a test pressure equal to nominal operating pressure. The visual examination will be conducted after the system has been pressurized to test pressure for a minimum of 10 minutes for noninsulated components or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components prior to examination. The system will be maintained at test pressure for the duration of the VT-2 visual examination. Hydrostatic test instrumentation requirements of IWA-5260 are not applicable as test parameter recording is performed by normal operating system instrumentation or equivalent.
The system pressure test will be conducted at or near the end of the inspection interval or during the same inspection period of each inspection interval-.
The boundary subject to test pressurization and VT-2 visual examination during the system pressure test shall extend to all Class 3 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 safety or relief valve) or valve capable of automatic closure when the safety function is required.
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Revision 0 APPLICABLE TIME PERIOD Relief is requested for the first ten-year inspection interval of the Inservice Inspection Program for Byron Unit 1 and Unit 2 which ends on 9/16/95 and 8/21/97, respectively.
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i BYRON STATION UNIT 1 AND UNIT 2 INSERVICE INSPECTION PLAN i
Table 7.4.0-1 TECHNICAL APPROACH AND POSITION SUMMARIES ;
l TECHNICAL l APPROACH AND POSITION NUMBER GENERAL DESCRIPTION ,
SP-01 System Pressure Psv determination when a safety or relief valve ;
pressure setting is greater than the system design pressure.
SP-02 ASME Class 2 and 3 pressure retaining system boundary.
SP-03 Exemption of Class 2 and 3 penetrations and associated piping. l SP-04 Exemption of various FW, SD and SI components. I SP-05 Exemption of Class 2 and 3 CV components.
l l SP-06 Adoption of Regulatory Guide 1.147 Approved Code Cases t i
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Revision 0 BYRON STATION UNITS 1 AND 2 ISI/IST TECHNICAL APPROACH AND POSITION: SP-06 l
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COMPONENT IDENTIFICATION Code Class: 1, 2, and 3
Reference:
U.S. NRC Regulatory Guide 1.147 10CFR50. 55a (a) (3 ) j 10CFR 50.55a Footnote 6 Examination Category: Various ;
Item Numbers: Various
Description:
Adoption of Regulatory Guide 1.147 Approved Code Cases CODE REOUIREMENT Proposed alternatives to the provisions of the ASME Code may be used when authorized by the Director of the Office of Nuclear Reactor Regulation, as specified in paragraph (a) (3) of 10CFR50.55a. Footnote 6 of 10CFR50.55a l specifically addresses the use of ASME Code Cases that are determined suitable by the Commission and listed in Regulatory Guide 1.147.
POSITION i This Technical Approach and Position identifies those ASME Section XI, Division 1, Code Cases that may be used for preservice/ inservice inspection or used for a repair / replacement during the first 10 year Interval for Byron Station Units 1 and 2. These Code Cases have been accepted by the NRC Staff for application and are listed in Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability ASME Section XI Division 1. Any of the Code Cases l listed in Table SP-06-1, Acceptable Code Cases for Byron Station !
Implementation, may be used at any time given at the discretion of Byron !
Station. Use of a Code Case does not indicate a commitment to use the Code Case for the remainder of the Interval. Code Cases shall be used as conditions warrant. However, whenever a Code Case is used, adherence to any limitations on its use as specified in Regulatory Guide 1.147, appropriate revision, is required . Table SP-06-1 will be revised periodically to incorporate Code Cases endorsed by later revisions of Regulatory Guide 1.147.
Superceded or annulled Code Cases that were identified in the ISI Program Plan when the Code Cases were endorsed, may continue to be used.
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! Revision 0 l BYRON STATION UNITS 1 AND 2 ISI/IST TECHNICAL APPROACH AND POSITION: SP-06 i TABLE SP-06-1 i
ACCEPTABLE CODE CASE FOR BYRON STATION IMPLEMENTATION Code Case ASME R.G. Code Case ASME R G.1.147 Approval / 1.147 Approval / Revision Reaffirmati Revision Reaffirmati on on 1705-1 12-03-90 10 N-435-1 07-30-89 10 N-98 N-113-1 12-03-90 10 N-437 07-30-89 10 N-211 04-30-90 10 N-448 04-30-90 10 l N-235 12-03-90 10 N-449 04-30-90 10 N-278 02-19-89 10 N-457 12-03-90 10 ,
N-307-1 12-03-90 10 N-458 08-14-90 10 N-311 04-30-90 10 N-460 05-13-91 10 t
N-335-1 05-13-91 10 N-461 08-14-91 10 N-355 12-03-90 10 N-463-1 03-05-90 10 ,
N-356 10-23-88 10 N-465 08-14-91 10 N-389 05-14-89 10 N-471 04-30-90 10 i
N-401-1 05-13-91 10 N-472 03-08-89 10 N-402-1 03-14-91 10 N-481 03-05-90 10 i l
N-408-2 07-24-89 10 N-485-1 08-14-91 10-N-409-2 05-13-91 10 N-489 08-14-30 10 N-415 08-14-91 10 N-490-1 05-13-91 10-N-416 12-03-90 10 N-491 03-14-91 10 N-419 05-13-91 10 N-494 12-03-90 10 1
i 10 N-426 05-13-91 N-495 12-03-90 10 N-427 12-05-88 10 N-496 03-14-91 10 N-429-1 03-05-90 10 N-498 05-13-91 10 N-432 02-20-89 10 i Page 2 of 2 l
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