ML20076M513
| ML20076M513 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/25/1994 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9411070397 | |
| Download: ML20076M513 (19) | |
Text
{{#Wiki_filter:St; tion Euppttt Dep rtmInt 10CFR50.55a(g)(5)(ii!) a PECO ENERGY " = ~ c=" - Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne, PA 19087-5691 October 25,1994 Docket No. 50-353 Ucense No. NPF-85 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Limerick Generating Station, Unit 2 Request Relief for First Ten-Year Interval inservice inspection Program Regarding System Pressure Testing Gentlemen: Attached for review and approval is Revision 1 to Relief Request No. RR-13 for the Limerick Generating Station (LGS), Unit 2, First Ten-Year Interval inservice inspection (ISI) Program. Revision 1 to Relief Request No. RR-13 requests relief from the requirements of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, 1986 Edition, regarding system pressure tests for various Class 2 and 3 pressure retalning components, which includes piping, pumps, and valves. This Relief Request was originally submitted (i.e., Revision 0) for NRC review and approval by letter dated March 12,1993. By letter dated March 1,1994, the NRC issued 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 for Unit 1, since we failed to adequately justify that meeting the ASME Code requirements was impractical and that it created a hardship or burden. Therefore, the Unit 1 relief request was subsequently revised to provide additional justification to support the relief request, and was resubmitted to the NRC for review and approval by letter dated October 4,1994. Since this Unit 2 Relief Request is essentially identical to the RR-13 for Unit 1, we are revising RR-13 for Unit 2 to provide the necessary justification in support of this Relief Request, and to be consistent with the Unit I relief request recently submitted. Revision 1 to Relief Request No. RR-13 for Unit 2 supersedes in entirety Revision 0 previously submitted by letter dated March 12, 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 1, and request that the NRC grant relief from performing the ASME Code required pressure tests for Class 2 and 3 pressure retaining components by July 31,1995. 070084 9411070397 941025 PDR ADOCK 05000353 Ij f PDR
October 25,1994 I If you have any questions or require additional information, please do not hesitate to contact us. Very truly yours, h /? b lRA 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) 1 i e
t' .l t i Limerick Generating Station, Unit 2 First Ten-Year interval inservice inspection Program RELIEF REQUEST NO. RR-13 Revision 1 t l t i I d r +~c-m
Docket No. 50-353 Page 1 of 14 Limerick Generating Station, Unit 2 RELIEF REQUEST NO. RR-13 Revision 1 1. IDENTIFICATION OF COMPONENTS Class 2 (exempt and non-exempt) pressure retalning components within the pressure retaining 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 retaining components within the pressure retalning 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. 11. CODE REQUIREMENTS FROM WHICH REUEF IS REQUESTED ASME Code, Section XI,1986 Edition, Examination Category C-H requires the pressure retalning 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 Tables RR-13-1.1 through RR-13-1.11 due to redundant testing. Individual test requirements requiring relief are as detailed in the Tables. Ill. BASIS FOR REllEF 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 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 are as proposed in Table (s) RR-13-1.1 through RR-13-1.11. l
....- - =.. ~ ii Docket No. 50 353 Page 2 of 14 Limerick Generating Station, Unit 2 REUEF REQUEST NO. RR-13 Revision 1 (Continued) Table RR-13-1.1 (Withdrawn) l 1 i P i i i l t d -.r.. n, e,, ---,r
Docket No. 50-353 Page 3 of 14 Limerick Generating Station, Unit 2 RELIEF REQUEST NO. RR-13 Revision 1 (Continued) Table RR-13-1.2 Revision 1 1. -Identification of Comoonents Class 3 Nut, lear Soller Vessel instrumentation tubing to drywell pressure instrumentation l outboard of HV-42-247A, B, C, and D. (Ref P&lD: ISI-M-42, Sht 3, ISI-M-57, Sht 4, ISI-M-59, Sht 3) 11. Code Reauirement From Which Relief is Reauested IWD-5221, System Inservice Test and IWD-5223, System Hydrostatic Test III. Basis For Relief Normal Drywel' pressure is less than 1 psig. The pressurtzing fluid is n!trogen gas. A VT-2 inspect!on loo <ing for a nitrogen gas leak with less than 1 psig drMng pressure would be inconclusive. LGS Technical Specifications require channel checks every 12 hours 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-42-247A, B, C, and D shall remain "Open" during the performance of the Appendix "J" ILRT. 4 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. i
\\ Docket No. 50-353 Page 4 of 14 Limerick Generating Station, Unit 2 RELIEF REQUEST NO. RR-13 Revision 1 (Continued) Table RR-13-1.3 Revision 1 1. Identification of Comoonents l Class 2 RCIC Turbine Exhaust Vacuum Breaker line HBB-245 between and including valves i HV-49-2F084, and HV-49-2F081 & 2018. (Ref. PalD: ISI-M-49, Sht 2) II. Code Reaulrement 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 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 pressuro 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. 1
Docket No. 50453 Page 5 of 14 Limerick Generating Station, Unit 2 RELIEF REQUEST NO. RR-13. Revision 1 (Continued) Table RR-13-1.4 Revision 1 1. Identification of Comoonents Class 2 HPCI Turbine Exhaust Vacuum Breaker line HBB-244 between and including valves HV-55-2F095, and HV-55-2F094 & 2026. (Ref P&lD: ISI-M-55, Sht 2) - il. Code Reauirement From Which Relief is Reauested i IWC-5221, System pressure test during system function / inservice tests and, IWC-5222, System hydrostatic test. 111. Basis For Relief Normal Drywell pressure is less than 1 psig. The pressurlzing 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 ~! 4 . 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.
Docket No. 50-353 Page 6 of 14 Limerick Generating Station, Unit 2 RELIEF REQUEST NO. RR-13 Revision 1 (Continued) Table RR-13-1.5 Revision 1 1. Identification of Comoonents Class 3 Containment Atmospheric Control tubing to seppression pool pressure and level instrumentation outboard of SV-57-201. (Ref P&lD: ISI-M-57, Sht 4, ISI-M-52, Sht 3) II. Code Reauirement From Which Relief is Reauested IWD-5221, System inservice Test and IWD-5223, System Hydrostatic Test. Ill. Basis For Relief Normal supprculon pool pressure is less than 1 psig. The pressurizing fluid is nitrogen gas. A VT-2 inspecticu 'ooking for a nitrogen gas leak with less than 1 psig driving pressure would be inconclusive. LGS Techaical 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 pool level indicators. This is performed by verifying proper level readings. A significant tubing leak will give an improper reading, and will be corrected and retested. Also, the tubing and components are included in the Integrated Leak Rate Test (ILRT) boundary. Note: Valve SV-57-201 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. i 1 i l l a
Docket No. 50-353 Page 7 of 14 Limerick Generating Station, Unit 2 RELIEF REQUEST NO. RR-13 Revision 1 (Continued) Table RR-13-1.6 Revision 1 1. identification of Comoonents Class 2 Post-LOCA Recombiner piping HBB-228 and HBB-227 between and including "A" Recombiner and valves HV-57-261 and HV-57-262; and, HBB-226 and HBB-224 between and including *B* recombiner and valves HV-57-263 and HV-57-264. (Ref P&lD: ISI-M-57, Shts 4, & 5) Cless 2 hydrogen / oxygen sampling lines HCB-216 and HCB-217, between connections on the Combustible Gas Analyzer Package 20S205, and valves SV-57-259, SV-57-241, SV-57-242 and SV-57-2478, SV-57-243, SV-57-244 and SV-57-246B, and SV-57-245 (HCa %). HCB-216 and HCB-217, between connections on the Combustible Gas Analyzer package 20S206, and valves SV-57-284 and SV-57-246A, SV-57-286 and SV-57-247A, SV-57-295, SV-57-290 and 57-2090, and SV-57-285 (HCB-217). (Ref. P&lD: ISI-M-57, Sheets 4,5,6). II. Code Reaulrement From Which Relief is Reauested IWC-5221, System pressure test during system functional / inservice tests and, IWC-5222 System hydrostatic test lli. Basis For Relief During normal plant operation, this piping is either isolated or less than 1 psig (normal containment pressure). The pressurlzing 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. CPls 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) CPls are performed more frequently than periodic system functional tests and the ten year hydrostatic tests. 2) CPls have the ability to quantify leakage which is not feasible with a VT-2 insprtion on this air filled 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. 50-353 Page 8 of 14 i Umarick Generating Station, Unit 2 REUEF REQUEST NO, RR-13 Revision 1 - l (Continued) l 1 Table RR-13-1.7 Revision 1 I 1. Identification of Comoonents j Class 2 Containment Atraospheric Control piping as illustrated in figures RR-13-1.7a & b. IL Code Reautrement From Which Relief is Reauested IWC-5221, System pressure test during system functional / inservice tests and, i IWC-5222, System hydrostatic test. 111. Basis For Relief During normal plant operation, this piping is either isolated or less than 1 psig (normal l containment pressure). The pressurizing fluid is essentially nitrogen gas. A VT-2 inspection i 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. i Appendix J LLRTs are performed once per Refuel Outage. During LLRTs, the subject piping is l 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. 2) LLRTs have the ability to quantify leakage which is not feasible with VT-2 inspection on this essentially gas-filled piping. l 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. ~,..., -.
(_ Dock:t No. 50-353 Page 9 of 14 Limerick Generating Station, Unit 2 RELIEF REQUEST NO. RR-13 Revision 1 (Continued) Figure RR-13-1.7a (Ref P&lD: ISI-M-57, Sht 4) E3 a: _ _ _ _ = = _ q DDif ,=. ,l -w-- ,,i w.-- [ m. .r_kI[ww=__ _ __ i ew 4 m, W w 1. g y 3' U 6 K ;:: ,, w a,, a s l l,',il u,, I'l ,ML p,. l . E!3E, iq
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Dock t No. 50-353 Page 10 of 14 Limerick Generating Station, Unit 2 REUEF REQUEST NO. RR-13 Revision 1 (Continued) Figure RR-13-1.7b (Ref P&lD: ISi-M-57, Sht 5) hj o lW- ,c tP- . 2 CW h O w J b ip-g j; t-p-q i, 4 . dD_ 5, _ lej+ - g.- p ss._ ~ b f:, Wi c7 7 l k l,, h i. 0:9.9 l@ l@ E.-@ .: c. on. l
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Docket No. 50-353 Page 11 of 14 Limerick Generating Station, Unit 2 REUEF REQUEST NO. RR-13 Revision 1 (Continued) Table RR-13-1.8 [Vithdrawn)
Docket No. 50-353 Page 12 of 14 Limerick Generating Station, Unit 2 RELIEF REQUEST NO. Ph13 Revision 1 (Continued) Teble RR-13-1.9 Revision 1 1. Identification of Comoonents Class 2 Plant Process Radiation Monitoring System piping HCB-228, between and including valves 26-2009,26-2011, SV-26-290A & B, and 26-2010,26-2012, SV-26-290C & D. (Ref. P&lD: ISI M-26, Shts 7 & 8) 11. Code Reaulrement From Which Relief is Reauested IWC-5221, System pressure test during system functional / inservice tests and, lWC-5222, System hydrostatic test lit. 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 performed once per Refuel Outage for leakage. During LLRTs, the subject piping is pressurized to 44 psig, a substantia!!y 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 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 include through valve leakage which would not be identified in a VT-2 inspection. IV. ALTERNATE r>ROVISIONS 10CFR50 Appendix J Local Leak Rate Testing (LLRT) provides assurance of component integrity.
Docket No. 50-353 Page 13 of 14 Limerick Generating Station, Unit 2 RELIEF REQUEST NO. RR-13 Revision 1 (Continued) Table RR-13-1.10 Revision 1 1. Identification of Comoonents Class 2 Primary Containment Instrument Gas System piping, as follows: HCB-209 piping and components at penetration X-40F, between and including valves HV 59-202 and HV-59-201. Tubing and components from and including valves XV-59-241 A, B, C, D, E, to penetration X35C, 0, E, F, and G respectively. (Ref. P&lD: ISI-M-59, Sht 3). II. Code Recuirement 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 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 performed 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 VT-2 inspection. 4) LLRTs are at higher pressure (44 psig) than normal operation. IV. A. TERNATE PROVISIONS 10CFR50 Appendix J Local Leak Rate Testing (LLRT) provides assurance of component integrity.
1 l Docket No. 50 353 Page 14 of 14 Umerick Generating Station, Unit 2 REUEF REQUEST NO. RR-13 Revision 1 (Continued) Table RR-13-1.11 (Withdrawn) l l}}