ML20076F185
| ML20076F185 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/04/1994 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9410130225 | |
| Download: ML20076F185 (17) | |
Text
Station Supptrt Diptrtmsnt 10CFR50.55a(g)(5)(lii) 2
%r PECO ENERGY Eo ~ c-
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Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne, PA 190676631 October 4,1994 Docket No. 50-352 License No. NPF-39 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 St.bject: Limerick Generating Station, Urdt 1 Request Relief for First Ten-Year Interval inservice Lepection Program Regarding System Pressure Testing Gentlemen:
Attached for review and approval is Revision 2 to Relief Request No. RR-13 for the Limerick Generating Station (LGS), Unit 1, First Ten Year Interval inservice Inspection (ISI) Program.
Revision 2 to Rollef Request No. RR-13 requests relief from the requirements of Section XI of the American Society of Mechanical Engineers (ASME) Boller and Pressure Vessel (B&PV) Code, 1986 Edition, regarding system pressure tests for various Class 2 and 3 pressure retaining components, which includes piping, pumps, and valves. This Rollef Request was originally submitted (i.e., Revision 0) for NRC review and approval by letter dated January 24,1992, and was subsequently revised and superseded by Revision 1. Revision 1 to Relief Roquest No.
RR-13 was submitted by letter dated May 18,1993, to provide additional information to address NRC questions concerning this Relief Request.
By letter dated March 1,1994, the NRC lssued its Safety Evaluation Report (SER) and supporting Technical Evaluation Report (TER) for the LGS, Unit 1, First Ten-Year Interval ISI Program. As documented in the March 1,1994 NRC letter, and supporting SER and TER, relief was denied for some aspects of Relief Request No. RR-13, Revision 1, since we failed to 1
adequately justify that meeting the ASME Code requirements was impractical and that it created a hardship or burden.
Therefore, we are submitting Revision 2 to Rollef Roquest No. RR 13 to provide additional justification based on information provided in the NRC's SER to support approval of this Relief Request. Revision 2 to Relief Request No. RR 13 supersedes Revision 1 previously submitted by letter dated May 18,1993.
The details and justification for relief are explained further in the attached Relief Request. We would appreciate your cooperation in reviewing Relief Request No. RR-13, Revision 2, and request that the NRC grant relief from performing the ASME Code required pressure tests for Class 2 and 3 pressure retaining components by June 30,1995.
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9410130225 941004 PDR ADOCK 05000352 fi l
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October 4,1994 Page 2 If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, A.
G. A. Hunger, Jr.
Director - Licensing Attachment cc:
T. T. Martin, Administrator, USNRC, Region I (w/ attachment)
N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachment)
Umerick Generating Station, Unit 1 First Ten-Year interval inservice inspection Program RELIEF REQUEST NO. RR-13 Revision 2 i
Docket No. 50-352 Page 1 of 14 Limerick Generating Station, Unit 1 RELIEF REQUEST NO. RR-13 Revision 2 1.
IDENTIFICATION OF COMPONENTS Class 2 (exempt and non-exempt) pressure rataining components within the pressure retalning boundary of pressure vessels, piping, pumps, and valves, Examination Category C-H, item Numbers C7.10 through C7.80 inclusive.
Class 3 (exempt and non-exempt) pressure retalning components within the pressure retaining boundary, Examination Categories D-A, D-B, and D-C, item Number D1.10, D2.10, and D3.10, respectively.
The specific Class 2 and 3 components covered by this relief request are detailed in Table (s)
RR-13-1.1 through RR-13-1.11.
II.
CODE REQUIREMENTS FROM WHICH RELIEF IS REQUESTED ASME Code,Section XI,1986 Edition, Examination Category C-H requires the pressure retaining components within each system boundary be subject to the system pressure tests of IWC-5000 and visually (VT-2) examined.
ASME Code,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 Interval in accordance with Table IWC-2500-1 or Table IWD-2500-1, as appilcable Relief is requested from meeting the subject pressure test requirements for the specific components listed in Table RR-13-1.1 through RR-13-1.11 due to hardship imposed by plant design and/or redundant testing. Individual test requirements requiring relief are as detailed in the Tables.
Ill.
BASIS FOR RELIEF Pressure testing in accordance with some or all of the requirements of IWC-5000 or IWD-5000, as applicable, for the affected components is impractical due to plant / system design and/or redundant test requirements as detailed in Table (s) RR-13-1.1 through RR-13-1.11.
In all cases, alternate testing provides adequate assurance of pressure boundary integrity.
IV.
ALTERNATE PROVISIONS Any alternate test provisions, where pradcal, are as proposed in Table (s) RR-13-1.1 through RR 13-1.11.
Dockd No. 50-352 Page 2 of 14 Umarick Generating Station, Unit 1 i
REUEF REQUEST NO. RR-13 Revision 2 J
(Continued) l Table RR-13-1.1 (Withdrawn) l
)
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I
Docket No. 50-353 Page 3 of 14 Umerick Generating Station, Unit 1 RELIEF REQUEST NO. RR-13 Revision 2 (Continued)
Table RR-13-1.2 Revision 2 This Table approved in NRC SER dated 3/1/94 1.
.[dentification of Comoonents Class 3 Nuclear Boiler Vessel instrumentation tubing to drywell pressure instrumentation outboard of HV-42-147A, B, C, and D. (Ref P&lD: ISI-M-42, Sht 1, ISI-M-57, Sht 1, ISI-M-59, Sht 1) 11.
Code Readirement From Which Rollef is Reauested IWD-5221, System Inservice Test and IWD-5223, System Hydrostatic Test 111.
Basis For Relief Normal Drywell pressure is less than 1 psig. The pressurizing fluid is nitrogen gas. A VT-2 inspection looking for a nitrogen gas leak with less than 1 psig driving pressure would be inconclusive.
LGS Technical Specifications require channel checks every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to verify drywell pressure instrumentation operability. This is performed by verifying proper pressure readings. A significant tubing leak will cause an improper reading, and will be corrected and retested. The tubing and components are also included in the integrated Leak Rate Test (ILRT) boundary.
Note: valves HV-42-147A, B, C, and D shall remain "Open" during the performance of the Appendix "J" ILRT.
IV.
ALTERNATE PROVISIONS LGS Technical Specification operability checks and the Integrated Leak Rate Test (ILRT) provide assurance of component integrity and will be utilized to satisfy ASME Section XI requirements.
j Docket No. 50-352 Page 4 of 14 Limerick Generating Station, Unit 1 RELIEF REQUEST NO. RR-13 Revision 2 (Continued)
Table RR-131.3 Revision 2 1.
Identification of Comoonents Class 2 RCIC Turbine Exhaust Vacuum Breaker line HBB-145 between and including valves HV-49-1F084, HV-49-1F081, and 1019.
(Ref. P&lD: ISI-M-49, Sht 1) 11.
Code Reauirement From Which Rollef is Reauested IWC-5221, System pressure test during system functional / inservice tests and, IWC-5222. System hydrostatic test lli.
Basis For Relie?
Normal Drywell pressure is less than 1 psig. The pressurizing fluid is nitrogen gas. A VT-2 inspection looking for a nitrogen gas leak with less than 1 psig driving pressure would be inconclusive, 10CFR50 Appendix J Local Leak Rate Testing is performed once per Refuel Outage.
During LLRTs, the subject piping is pressurized to 44 psig, a substantially higher pressure than that developed during a periodic system functional test. As such, the LLRT offers the following advantages over system pressure tests:
1)
LLRTs are performed more frequently than periodic system functional tests and the ten year hydrostatic test.
2)
LLRTs have the ability to quantify leakage which is not feasible with VT-2 inspections on this essentially gas-filled piping.
3)
LLRTs conservatively include through valve leakage which would not be identified in a VT-2 inspection.
IV.
ALTERNATE PROVISIONS 10CFR50 Appendix J Local Leak Rate Testing (LLRT) provides assurance of component integrity.
Docket No. 50-352 Page 5 of 14 Umerick Generating Station, Unit 1 REUEF REQUEST NO. RR-13 Revision 2 (Continued)
Table RR-13-1.4 Revision 2 1.
Identification of Comoonents Class 2 HPCI Turbine Exhaust Vacuum Breaker line HBB-144 between and including valves HV-55-1F095, HV-55-1F094, and 55-1026. (Ref P&lD: ISI-M-55, Sht 1) 11.
Code Reautrement From Which Relief is Reauested IWC-5221, System pressure test during system function / inservice tests and, IWC-5222, System hydrostatic test.
Ill.
Basis For Relief Normal Drywell pressure is less than 1 psig. The pressurizing fluid is nitrogen gas. A VT-2 inspection looking for a nitrogen gas leak with less than 1 psig driving pressure would be inconclusive.
Appendix J LLRTs are performed once per Refuel Outage. During LLRTs, the subject piping is pressurized to 44 psig, a substantially higher pressure than that developed during a system functional test. As such, the LLRT offers the following advantages over system pressure tests:
1)
LLRTs are performed more frequently than periodic system functional tests or the ten year hydrostatic test.
2)
LLRTs have the ability to quantify leakage which is not feasible with VT-2 inspection on this essentially gas-filled piping.
3)
LLRTs conservatively include through valve leakage which would not be identified in a VT-2 inspection.
IV.
ALTERNATE PROVISIONS 10CFR50 Appendix J Local Leak Rate Testing (LLRT) provides assurance of component integrity.
1 l
1
l Docket No. 50-352 Page 6 of 14 j
Limerick Generating Station, Unit 1 RELIEF REQUEST NO. RR-13 Revision 2 (Continued)
Table RR-13-1.5 Revision 2 This Table approved in NRC SER dated 3/1/94.
l.
Identification of Comoonents Class 3 Containment Atmospheric Control tubing to suppression pool pressure and level instrumentation outboard of SV-57-101. (Ref P&lD: ISI-M-57, Sht1, ISI-M-52, Sht 1)
II.
Code Reauirement From Which Relief is Reauested IWD-5221, System inservice Test and IWD-5223, System Hydrostatic Test.
111.
Basis For Relief Normal suppression pool pressure is less than 1 psig. The pressurizing fluid is nitrogen gas. A VT-2 inspection looking for a nitrogen gas leak with less than 1 psig driving pressure would be inconclusive.
LGS Technical Specifications require monitoring suppression pool pressure every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to verify proper pressure. Additionally, Technical Specircations require channel checks every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify operability of the suppression pool level indicators. This is performed by verifying a proper level readings. A significant tubing leak will ghte an improper reading, and will be corrected and rotested. Also, the tubing and components are included in the integrated Leak Rate Test (ILRT) boundary. Note: Valve SV-57-101 shall remain "Open* during the performance of the Appendix "J" ILRT.
IV.
ALTERNATE PROVISIONS LGS Technical Specification suppression pool instrumentation operability checks and the Integrated Leak Rate Test (ILRT) provide assurance of component integrity and will be utilized to satisfy ASME Section XI requirements.
Docket No. 50-352 -
Page 7 of 14 Limerick Generating Station, Unit 1 RELIEF REQUEST NO. RR-13 Revision 2 (Continued)
Table RR-13-1.6 Revision 2 i
1.
Identification of Comoonents Class 2 Post-LOCA Recombiner piping HBB-128 and HBP-127 between and including 'A' Recombiner and valves HV-57161 and HV-57162, and HBB-126 and HBB-124 between and including "Bi recombiner and valves HV-57-163 and HV-57-164. (Ref P & ID: ISI M-57, Sht 1 & 2)
Class 2 hydrogen / oxygen sampling lines HCB-116 and HCB-117, between connections on the Combustible Gas Analyzer Package 10S205, and valves SV-57-159, SV-57-141, SV-57-142 and SV-57-1478, SV-57-143, SV-157-144 and SV-57-1468, and SV-57-145 (HCB-117). HCB 116 and HCB-117, between connections on the Combustible Gas Analyzer package 10S206, and valves SV-57184 and SV-57-146A, SV-57-186 and SV-57-147A, SV-57-195, SV-57-190 and 57-1090, and SV-57-185 (HCB-117), (Ref. P&lD: ISI-M-57, Sheets 1,2,3).
II.
Code Reauirement From Which Relief is Reauested IWC-5221, System pressure test during system functional / inservice tests and, IWC-5222, System hydrostatic test Ill.
Basis For Relief During normal plant operation, this piping is either isolated or less than 1 psig (normal containment pressure). The pressurizing fluid is essentially nitrogen gas. A VT-2 inspection looking for a nitrogen gas leak with less than 1 psig driving pressure would be inconclusive.
System Contaminated Pipe inspection (CPI) is performed once per refuel on post-LOCA recombiner piping. During CPI testing associated with the Leak Reduction Program (UFSAR 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 following advantages over system pressure tests:
1)
CPIs are performed more frequently than periodic system functional tests and the ten year hydrostatic tests.
2)
CPIs have the abuity to quantify leakage which is not feasible with a VT 2 Inspection on this air fHied piping.
3)
CPIs conservatively include through valve leakage which would not be Identified in a VT-2 inspection.
The combustible gas analyzer continuously samples containment. A tubing leak will cause improper (high) readings which would be corrected and retested.
IV.
ALTERNATE PROVISIONS System Contaminated Pipe inspection (CPI) and monitoring of the combustible gas analyzers provides assurance of component integrity.
Docket No. 50-352 Page 8 of 14 Limerick Generating Station, Unit 1 RELIEF REQUEST NO. RR 13 Revision 2 (Continued)
Table RR-13-1.7 Revision 2 1.
Identification of Comoonents Class 2 Containment Atmospheric Control piping as illustrated in figures RR-13-1.7a & b.
fl.
Code Recuirement From Which Relief is Recuested IWC-5221, System pressure test during system functional / inservice tests and, IWC-5222, System hydrostatic test.
111.
Basis For Relief During normal plant operation, this piping is either isolated or less than 1 psig (normal containment pressure). The pressurizing fluid is essentially nitrogen gas. A VT-2 inspection looking for a nitrogen gas leak with less than 1 psig driving pressure would be inconclusive.
10CFR50 Appendix J Local Leak Rate Testing (LLRT) is performed once per Refuel Outage.
During LLRTs, the subject piping is pressurized to 44 psig, a substantially higher pressure than that developed during a periodic system functional test. As such, the LLRT offers the following advantages over system pressure tests:
1)
LLRTs are performed more frequently than periodic system functional tests.
2)
LLRTs have the ability to quantify leakage which is not feasible with VT-2 inspection on this essentially gas-filled piping.
3)
LLRTs conservatively include through valve leakage which would not be identified in a VT-2 inspection.
IV.
ALTERNATE PROVISIONS 10CFR50 Appendix J Local Leak Rate Testing (LLRT) provides assurance of component integrity.
Docket No. 50-352 Page 9 of 14 Umerick Generating Station, Unit 1 RELIEF REQUEST NO. RR-13 Revision 2 (Continued)
Figure RR-13-1.7a (Ref. P&lD: ISI M-57, Sht 2)
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Docket No. 50-352 Page 10 of 14 Umerick Generating Station, Unit 1 REUEF REQUEST NO. RR-13 Revision 2 (Continued)
Figure RR-13-1.7b (Ref. P&lD: ISI-M-57, Sht 1) 6 J:
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Docket No. 50452 Page 11 of 14 Umorick Generating Station, Unit 1 -
REUEF REQUEST NO. RR-13 Revision 2 (Continued)
Table RR-13-1.8 (Withdrawn)
Docket No. 50452 Page 12 of 14 Limerick Generating Station, Unit 1 i
REUEF REQUEST NO. RR-13 Revision 2 (Continued)
Table RR-13-1.9 (Withdrawn) l
Docket No. 50-352 Page 13 of 14 Limerick Generating Station, Unit 1 RELIEF REQUEST NO. RR-13 Revision 2 (Cortinued)
Table RR-13-1.10 Revision 2 1.
Identification of Comoonents Class 2 Plant Process Radiation Monitoring System piping HCB-128, between and including valves 26-1009,26-1011, SV-26-190A & B, and 26-1010,26-1012, SV-26-190C & D. (Ref. P&lD:
ISI-M-26, Shts 1 & 2)
II.
Code Reauirement From Which Relief is Reauested IWC-5221, System pressure test during system functional / inservice tests and, IWC-5222, System hydrostatic test 111.
Basis For Relief During normal plant operation, this piping is exposed to containment pressure. The pressurizing fluid is essentially nitrogen gas. A VT-2 inspection looking for a nitrogen gas leak with less than 1 psig drMng pressure would be inconclusive.10CFR50 Appendix J Local Leak Rate Testing (LLRT) is performed once per Refuel Outage for leakage.
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 offers the following advantages over system pressure tests:
1)
LLRTs are performed more frequently than periodi;c system pressure tests and the ten year hydrostatic test.
2)
LLRTs have the ability to quantify leakage which is not feasible with VT-2 lospections on air systems 3)
LLRTs conarvatively include through valve leakage which would not be identified in a VT-2 inspection.
IV.
ALTERNATE PROVISIONS 10CFR50 Appendix J Local Leak Rate Testing (LLRT) provides assurance of component integrity, f
l
Docket No. 50-352 Page 14 of 14 Limerick Generating Station, Unit 1 RELIEF REQUEST NO. RR-13 Revision 2 (Continued)
Table RR-13-1.11 Revision 2 1.
Identification of Comoonents Class 2 Primary Containment instrument Gas System piping, as follows:
HCB-109 piping and components at penetration X-40F, between and including valves HV-59-102 and HV-59-101.
Tubing and components from and including valvas XV-59-141 A, B, C, D, E, to penetration X350, D, E, F, and G respectively.
(Ref. P&lD: ISI-M-59, Sht 1).
11.
Code Reouirement From Which Relief is Reouested IWC-5221. System pressure test during system functional / inservice tests and, IWC-5222, System hydrostatic test lil.
Basis For Relief During normal plant operation, this piping is exposed to containment pressure. The pressurizing fluid is essentially nitrogen gas. A VT-2 inspection looking for a nitrogen gas leak with less than 1 psig driving pressure would be inconclusive.10CFR50 Appendix J Local Leak Rate Testing (LLRT) is periormed once per Refuel Outage for leakage. The Local Leak Rate tests 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.
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 Vf-2 inspection.
4)
LLRTs are at higher pressure (44 psig) than normal operation.
IV.
ALTERNATE PROVISIONS 10CFR50 Appendix J Local Leak Rate Testing (LLRT) provides assurance of component integrity.
l