ML20082P088
| ML20082P088 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/30/1991 |
| From: | Joshua Wilson TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9109100193 | |
| Download: ML20082P088 (17) | |
Text
'
S.
b i
i i
d i
.e i
i Jxk t W j
cs-r, August 30, 1991
(
t i
t I
I U.S. Nuclear Regulatory Commission ATINt Document Control Desk Washington, D.C.
20555 l
Gentlement I
In the Matter of
)
Docket Nos. 50-327 i
Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN) - REQUEST FOR RELIEF FROM THE AMERICAN SOCIETY CF MECHANICAL ENGINEERS (ASME) SECTION XI. HYDROSTATIC PRESSURE TEST REQUIREMENTS i
Reference:
Letter f rom NRC to 1TA dated January 17. 1991. " Inservice Pressure Test Program (TAC Nos. 72017/72018) - Sequoyah l
Kuclear Plant. Units 1 and '"
Enclosed are seven relief requests from the ASME Code.Section XI.
- .ydrostatic test requirements involving snwil sections of ASME Code l
Class 2 piping.
TVA's proposed relief requests are being submitted to l
l support SQN's pressure test schedule for the Cycle 6 refueling outages on
[
both units.
Each request for relief-is_ identical in that it involves small portions of ASM6 Code Claes 2 piping that penetrates prinary containment.
The safety function for each of the applicable sections of Class 2 piping is to provide a containment boundary postaccident.
TVA has determined that l
since this piping is leak tested at the containment design pressure j
(12 pounds per square inch gauge (psig]) in accordance with 10 CFR 50 Appendix J, performance of an ASME code hydrostatic pressure test woulo i
nat provide significant additional assurance of piping ability to perf orm
(-
the containment boundary function.
TVA has determined that conformance with ASME coce would result in unwarranted hardship without a j
compensating increase in the level of quality and safety.
TVA's proposed i
l_
alternative testing (i.e., performance of an Apper. dix J 1eak test at the containnent vessel design pressure of 12 psig) is considered to be an l
E adequate demonstration of leak tightress for these snull sections of ASME l
Class 2 piping.
Accordingly, the praposed relief requests are being
}
submitted pursuant to 10 CFR 50.55a(4)(3) and 10 CFR 55a(g)(5)(iiii.
j 00(
t 9109100193 910930 i
PDR ADOCK 05000327 L \\\\
P Ptet I
. -. - -. - ~ - - - - _. -...---.- -
2 U.S. Nuclear Regulatory Commission August 30, 1991 The enclocure contains seven individual relief requests entitled Inservice Pressure Test (ISPT)-2 through ISPT-3 (ISPT-1 was previously accepted by the reference letter).
These relief requests are being submitted at this time to support the Cycle 5 outage schedule. Unit 1 is the lead unit with the Cycle 6 refueling outage projected to begin March 13, 1993. The Unit 2 Cycle 6 outage is projected to begin September 1, 1993.
TVA requests that NRC response be provided before June 1.
1992, to allow for adequate planning of work activities in the Cycle $ outages.
Please direct questions concerning'this issue to D. V. Goodin at (615) 843-7734 Very truly yours.
-TENNESSEE VALLEY AUTHORITY
") &G
'J
- u. Wilson Enclosures cc (Enclosures)
Mr. D. E. LaBat ge, Project Manager U.S. Nucicar Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission L
Region II 101 Marietta Street, NW, Suite 2900 I
Atlanta. Ceorgia 30323 l
, -,,,,. ~
-,, ~,, -,,+
n
,,--,--n.
4 l
bhubbbb S'VES ASME SECTION XI RELIEF kEQUtSTS FOR SQN
~
UNITS 1 AND 2
e R(QUEST _FOR RELIEF ISPT-2 Components: Kaste disposal and auxiliary boration system piping between containment isolation valves FCV-77-9 FCV-77-10, and VLV-84-511.
Class: American Society of Mechanical Engineers (ASME) cede Class 2 (equivalent)
Tunction: The subject Class 2 piping, which penetrates primary containment, is a small section of plant process piping between inboard and outboard containment isolation valves.
This piping provides a flow path through primary containment from the
-reactor coolant drain tank pumps to the_ waste disposal system and the flood mode boration system. This function is not needed to bring the reactor to the safe shutdown condition or to mitigate the consequences of an accident.
The only safety function provided by this section of piping is to maintain a containment boundary following an accident.
Inspection-Requirement : ASME Section XI, paragraph IWC-5210(a)(1), requires that all
. code Class 2 systems or portions of systems that operate during normal reactor operation or are not required to undergo-periodic functional tests to meet owners' requirements must-be hydrostatically tested once each inspection interval.
Basis for Relief: The subject piping section is classified ASME code Class 2 because it performs the safety function of providing primary containment isolation. This piping performs no safety function in bringing the reactor to the safe shutdown condition or in mitigating the consequences of an accident.
During accident conditions, this line will be isolated by its containment isolation valves.
As part of the containment isolation system, this piping la tested in accordance with-Appendix J of 10 CFR 50.
Appendix J requires that each containment isolation valve be leak tested each. refueling outage and that the entire. primary containment be tested three times in every 10-year period.
The test pressure for these leakage tests-is based on the. design accident pressure for the containment system.
Durin6 the leakage test of each outboard containment isolation valve, the code Class 2_ piping between the isolation __ valves is subjected to a _ leakage test.
The presence of any leakage from the test volume greater than that allowed for the isolation valve requires evaluation and corrective action.
The 1eakage test pressure of 12. pounds per square inch gauge (psig) is equal to the design accident pressure _for the containment vessel. This test-pressure is much less than the Section X1 hydrostatic test pressure of 1.1 times the system piping design pressure of 150 psig. However, the containment accident pressure is the pressure at which this piping is required to perform its safety function.
o s.
2 REFEST FOR REl.!EF ISI'T-2 The purpose of the ASME Section XI hydrostatic pressure test is to verify the structural integrity of the pressure-retaining corrponents to ensure tacir ability to perform their safety function.
The safety function of this piping in to provide primary containment integrity.
The Appendix J testing program is specifically designed to demonstrate the ability of a component or structure-to perform this function.
A significant number of man-hours are required in the development and performance of the ASME Section XI hydrostatic pressure test for this piping.
The estimated cost to TVA for procedure development and test performance is approximately
$6.000 per unit. This hydrostatic pressure test requires several entries into radiation areas to conduct test equipment setup, valve-alignments, visual inspections, and equipment removal.--These-activities result in significant personnel exposure.
Based on prevlous similar tests, the estimated radiation exposure for this hydrostatic test la 800 millirem per unit.
In consideration of the safety function of the subject piping, the Appendix J-testing performed on this piping, and the man-hours and radiation expos tre required to perform the Section XI hydrostatic-test, it is concluded that compliance with the specified requirements would result in an unnecessary hardship
-without a compensating increase in the level of quality and safety.
Alternate Testing:
The structural integrity.of the subject piping will.be verified during testing performed under 10 CFR 50 Appendix J.
This includes a leakage test performed each refueling outage.
,..-....= -. - -.- -.:
= - - -. = u.
- =a = -
- - -
= = - -
s.
req QST FOR R1L RF ISPT-3 Components:
Pt imary water system piping between containment isolation valves
-FCV-B1-12. CKV-81-502, and VLV-81-529.
Class: ASME code Class 2 (equivalent)
Function:
The subject Class 2 piping, which penetrates primary containment, is a small section of plant process piping between inboard and outboard containment isolation valves.
This piping provides a flow path through primary containment for the primary water supp'y used to flush the reactor coolant pump No. 3 seal standpipe.
This. function is not needed to bring the reactor to the safe shutdown condition or to mitigate the consequences of an accident.
The only safety function providid by this section of piping is to maintain a containment boundary following an accident.
Inspection Requirement ASME Section XI, paragraph IWC-5210(a)(1), requires that all code Class 2 systems or portions of systems that operate during normal reactor operation or are nat required to undergo periodic functional tests to meet owners' requirements must be hydrostatically tested once each inspection interval.
Basis for
-Relief: The subject piping section is classified ASME code Clasn 2 because it performs the safety function of providing primary containment isolation.
This piping performs no safety function in bringing the reactor to the safe shutdown condition or in mitigating the consequences of an accident. During accident conditions, this line will be isolated by its containment isolation valves.
As part of the containment isolation system, this piping is tested in accordance with Appendix J of 10 CFR 50.
Appendix J requires:that each containment isolation valve be leak tested each refueling outage and that the entire primar containment be-tested three times in every 10-year period. The test pressure for these--leakage tests is based on--the design accident-ptesaure for the containment system.
During the leakage test of each cutboard containment isolation valve. the code Class 2 piping f;
between the isolation valves i t, subjected to a leakage test.
-The presence of any leakage from the-test volume greater than that allowed for the isolation valve requires evaluation and I
corrective action.
The leakage test pressure of 12 psig is equal to the design accident pressure for the containment vessel. This test pressure is much less than the Section XI hydrostatic-test pressure of 1.1 times the design pressure of 100 psig.. However, the containment accident pressure is the pressure at which this piping is required to perform its safety function.
l.
.,s 5.
2 RJE.ql'EST FOR RELIFF 1SPT-3 The purpose of the ASME Section XI hydrostatic pressure test is to verify the structural integrity of the pressure-retaining f
components to ensure their ability to perform their safety function.. The safety function of this piping is to provide l
primary containment integrity. The Appendix J testing program l
1s specifically designed to demonstrate the ability of a j
component or structure to perform this function.
[
t A significant number of man-hours are required in the development and performance of the ASME Section XI bydrostatic
{
_ pressure test for this piping.
The estimated cost to TVA for i
procedure development and test performance is approxinately
$6,000 per unit.
This hydrostatic pressure test 5* quires
-several entries into radiation areas to conduct test equipment setup, valve alignments, visual inspections, and equipment removal. These activities result in significant personnel exposure - Based on previous similar tests, the estimated radiation exposure for this hydrostatic test is 800 millirem per f
unit.
In consideration of the safety function of the subject j
piping, the Appendix J testing performed on this piping, and the j
man-hours and radiation exposure required to perform the Section r
XI hydrostatic test, it is concluded that compliance with the
{
specified requirements would result in an unnecessary hardship j
without a compensating increase in the level of quality and
- safety, 1
Alternate Testing: The structural integrity of the subject piping vill be verified during testing performed under 10 CFR 50 Appendix J.
This j
includes a leakage test performed each 'efueling outage.
Il r
f f
I i
i l
(
E a
v l
i l
I k
I r
L
_____ c1. _, _ _. _ _ _,.-
.. _. _.c. _ _.. _ _ _.,
_-...,..,_,...,n
- f
I u
e a
R_E_Qt'F.ST FOR _ RELIEF ISPT-4 Components:
Fire protection system piping between containment isolation
[
valves FCV-26-240. CKV-26-1260, and VLV-26-1258 and between FCV-26-243, CKV-26-1296 and VLV-26-1293.
Class: ASME code Class 2 (equivalent)
Function The subject Class 2 piping, which penetrate primary containment, is a small sections of plant fire protection piping between inboard and outboard containment isolation valves.
This piping provides a flow path through primary containment from the fire protection header to the spray heads and standpipes inside 4
conta itunent.
This function is not needed.to bring _the reactor to the safe shutdown condition or to mitigate the consequences of an accident.
The only safety function provided by this section of piping'is to maintain a containment boundary I
following an accident.
Inspection Requirement: ASME Section XI, paragraph IWC-5210(a)(1) requires that all' code Class 2 systems or portions of systems that operate during i
normal reactor operation or are not required to undergo periodic functional tests to meet owners' requirements must be-hydrostatically tested once each inspection interval'.
i Basis for f
-Reliefi The subject piping section is classifled ASME code Class 2 i
because it performs-the safety function of providing primary l
containment isolation.. This piping performs no safety function l
in bringing the reactor to the safe shutdown condition or in
,f mitigating the consequences of..an accident.
During accident conditions, this line will be isolated by its containment isolation valves.
i As part of the containment isolation system, this piping is
[
-tested in accordance with Appendix J of 10 CFR 50.
Appendix J requires that each containment isolation valve be leak tested f
each refueling outage sad that the entire primary containment be tested three times in every 10-year period. The test. pressure for these lea'kage tests is based"on the design accident pressure-for the containment system. During the leukage test of each i
-outboard contairment-isolation valve, the code Class 2 piping
[
between the isolation valves is subjected to a leakage-test.-
The presence of any leakage from the test volume greater than.
)
that allowed for the isolation valve requires evaluation and corrective action.
The leakage test pressure of 12 psig is equal to the design accident. pressure for the containment vessel.
This test i
pressure is much leds,than the Section XI hydrostatic test
. lioweve r,
{
pressure of 1.'1 times the design' pressure of 150-psig.
the containment accident pressure is the pressure at which this piping is required to perform its safety function.
It should be noted.that this piping is not pressurized during unit operation.
l t
I l;
.u-
. 1
$5
,s.
I I
REQUEST FOR REllEF ISPT-4 l
The purpose of the ASME Section Xi hydrostatic pressure test is to verify the structural integrity of the pressure-retaining components to ensure their ability to perform their safety j
function.
The safety function of this piping is to provide l
prinary containment integrity.
The Appendix J testing program j
is specifically designed _to_ demonstrate the ability of a component to perform this function.
{
t A significant number of man-hours are required in the development and performance of the ASME Section XI hydrostatic pressure test for this piping.
The estimated cost to TVA for procedure development and test performance is-approxinately
$10,000 per unit. This hydrostatic pressure test requires several entries into radiation areas to conduct test equipment
-setup, valve alignments, visual inspections, and equipment removal. 'These activities result in significant personnel exposure.
Based on previous similar tests, the estimated
{
radiation exposure for this hydrostatic test is 1600 millirem
}
per unit.
In consideration of the safety function of the subject piping. the Appendix J testing performed on this piping.
~!
and the man-hours and radiation exposure required to perform the
'{
Section XI bydroststic test, it is concluded that compliance
}
"with the specified requirements would result in an unnecessary-.
hardship without a compensating increase in the level of quality and' safety.
. Alternate Testing: The structural integrity of the subject piping will be verified
[
during testing. performed under 10 CFR 50 Appendix J.
This
[
includes a leakage test performed each refueling outage.
f I
i-f
-t i
i
-f j
t I
r i
i I
1
[
i-I r
h l
I u..
-,_..,.__,__L._.___.
4
n
+
s.
I t
REpUEST FOR RE!.!EF IGPT-5 i
i Components:
Floor and equipment drain system piping between containment j
isolation valves FCV-77-127 and FCV-77-128.
l Class ASME code Class 2 (equivalent) l Tunction: The subject Class 2 piping. which penetrates primary l
containment. is a small section of plant process piping between inboard and outboard containment isolation valves.
This piping provides a flow path through primary containment from the reactor building floor and equipment drain sump to the tritiated drain collector tank.
This piping performs no safety function j
in bringing the reactor to the cold shutdown condition.
This j
function is not needed to bring the reactor to the safe shutdown i
l condition or to mitigate.the consequences of an accident.
The only safety function provided by this section of piping is to maintain a containment-boundary following an accident.
1 Inspection-Requirement: ASME Section XI, paragraph IWC-5210(a)(1), requires that all code Class 2 systems or portions of systems that operate during f
normal reactor operation or are not required to undergo periouic
.f functional tests to moet owners' requirementa must be t
hydrostatically tested once each inspection interval.
liasis for Reliefi The subject piping section is classified ASME code Clars 2 l
because it performs the safety functJcn of providing pritrary
[
containment isolation.
This piping performs no safety function
-in bringing the reactor to the safe shetdown condition or irr mitigating the consequences of an accident.
During accident
[
conditions, this ifno will be isolated by its containment isolation valves.
t As part of the containment isola'tlon systetr. this piping is f
tested in accedance with Appendix J of.10 f.,Fk 50.
Appendix J j
requires that each containment isolation valve he leak tested each refbeling outage and'that the entire primary containment-be I
{
tested three times in every 10-year period.
The test oressure for these leakage tests is based on the design accident pressure for the: containment-system.
During the leakage test of-eaca-t I
outboard containment isolation valve, the code Class 2 piping between the isolation valves is-subjected to a leakage test.
[
-Tho presence of any leakage from the test volume greater than
{
that allowed for the irolation valve requires evaluation and corrective action.
{
The leakage test pressure of 12 psig is equal to the design accident pressure for the containment veusel.
This test pressure is much less than the Section XI hydrostatic test i
pressure of 1.1 times the design pressure of 150 psig.
!! owe ve r,
{
the containment accident pressure is the pressure at which this piping is required to perform its safety function.
[
t i
,.-_.'.,..__.,.__..,.-..,_.._......___._..___.._...m....__,__=_,,__
,_,___,.O
V
.REQl'FST_FOR ret.1 EF ISpT-5 The purpose of the ASME 3ection XI hydrostatic pressure test is to verify the structural integrity of the pressure-retaining components to ensure their ability to perform their safety function. The safety. function of this piping is to provido primary containment integrity.
The Appendix J testing program is specifically designed to demonstrate the ability of a component to peraorm this function.
A significant number of men-hours are required in the development and perfnrmance of.the ASME Section XI hydrostatic pressure test for this piping. The estimated cost to ITA for-procedure development and test perf ornance is approxinately
$6,000 per unit. This hydrostatic pressure test-requires several entries into radiation areas t.o conduct test equipment setup, valve alignments, visual inspections, and equipment removal.
These activillen result in significant personnel-exposure.
Based on previous similar tests, the estimated radiation exposure for this hydrostatic test la 800 millirem por unit. -In consideration of the safety function of the subject piping, the Appendix J hating perf ormed on this piping, and the
-man-hours and radiation-exposure required to perform the Section XI hydrostatic test, it is concluded that compliance with the specified requirements would result in an unnecessary hardship without a compensating increase in the level of quality and safety..
Alternate Testing: The structural lategrity of the subject piping will be verified during testing perforrned under 10 CFR 50 Appendix J.
This-includes a leakage test performad each refueling outage.
i t.
l
g.
REgt!EST__FOR REllEF_ISPT-6
-f i
Components:
Fuel pool cooling and cleaning system piping between containment I
isolation valves VLV-78-5!7. VLV-78-226A. and VLV-78-558 and VLV-78-563. VLV-78-22SA. and VLV-78-561.
Classt ASME code Class 2 (equivalent) i Function: The subject Class 2 piping, which penetrates primary i
containment, is a small section of plant process piping between inboard and outboard containment isolation valves.
This piping i
provides a flow path through primary containment between the f
reactor refueling cavity and refueling water purification pumps.
This piping performs no safety function in bringing the
{
reactor to the cold shutdown condition. This function _is not i
needed to bring the reactor to the safe shutdom condition or to mitigate the consequences of an accident.
The only safaty j
function provided by this section of piping is to maintain a containment boundary following an accident.
Inspection
{
Requirementt ASME Section X1, paragraph IWC-$210(a)(1) requires that all j
code Class 2 systems or portions of systems that operate during normal reactor operation or are not required to undergo periodic functional tests to meet owners' requirements must be hydrostatically tested once each Inspection interval.
Basis for Relieft lThe subject piping section is classified ASME code Class 2
-f because it performs the safety function of'providing primary containment isolation.
This piping performs no safety function in bringing the reactor to the safe shutdown condition or in
- s mitigating the consequences of an accident.
During accident i
conditions. this line will be isolated by its containment l
isolation valves.-
i As part of the containment isolation system, this piping is tested in accordance with Appendix J of 10 CFR 50. ' Appendix J requires that each containment _ isolation valve be leak tested each refueling cutage and that_'the entire primary containment be
[
tested three times in every 10-ycar period. The test pressure
[
for theso leakage tests is-based on the design accident pressure i
l for the containment system.
During the leakage test of each
-[
l-outboard containment isolation valve, the code Class 2 piping between-the isolation valves is subjected to a leakage test.
[
The presence of any leakage from the test volume greater than
~
that allowed for the isolation valve requires evaluation and i
corrective action.
l i
The leakage test-pressure on 12 psig is equal to the design i
accident pressure for the containment vessel.
This test pressure-is much less than the Section XI hydrostatic test pressure of 1.1 times the design pressure of 150 psig, floweve r.
I the containment accident pressure is the pressure at which this l
piping is required to perform-its safety function.
l t
{
l I
u
{
f t*-
t
,.4*
I r
RRt'EST FOR __REl.lEF _lSP.T-6 The purpose of the ASME Section Xi hydrostatic pressure test is to verif y the structural integrity of the pressure-retaining components to ensure their ability to perform their safety function.
The safety function of this piping la to provide i
primary :ontainment integrity.
The Appendix J testing program l
la specifically designed to demonstrate the ability of a component to perform this function.
A significant number of man-hours _are required in the development and performance of the ASME Section XI hydrostatic pressure-test for this piping.
The estimated cost to TVA for
- procedure development'and test performance is approximately.
$10,000 per unit.
This hydrostatic pressure test requires i
several: entries into radiation areas to conduct test equipment setup, valve alignments, visual inspections, and equipment removal. These activitles_ result in significant personnel i
exposure. -Based on previous similar tests, the estimated
-l radiation exposure for.this hydrostatic test is 1600 milltrem l
per unit.
In consideration at the safety function nf the-subject. piping, the Appendix J testing perfornied on this piping, I
and the man-hours and radiation exposure required to perform the l
Section X1 hydrostatic. test, i t is concluded that compliance with the specifled requirements would result in an unnecessary hardship without a compensating increase in the icvel of quality
{
and safety.-
[
Alternate i
Testing: The structural integrity of the subject piping will be verified
[
during-testing performed under 10 CFR 50 Appendix J.
This t
. includes a leakage test performed each refueling outage.
I I
I
?
l i
l l[
(J j
1 i
'I i
i' f
lL h
W-'
W 4--W'N
'W7w-ws're trw e D-4PMN-edew---9WT*MTi'er SwdMeee-'-
T'itm er' M MP' WkNS 'M WW F '4"4 t-rwcws-s-Fe---*wde*pWN9+W-*>'T**"tN-K"P1'--y e fw n-W -'r r 7T'
***cFW
-"t'-'*s*'rtt--85vha"NYT
g.
klqUFST FOR kEL!fF ISPT-7 Components:
Demineralized water system piping between conteinment isolation valves VLV-59-522. VLV-59-651. CEV-59-533, and VLV-$9-704 Class! A5ME code class 2 (equivalent) l Funct.on:
The subject Class 2 piping, which penetrates primary 8
containment. is a small section of plant process piping between inboard and outloard containment isolation valves.
This piping provides a flow path through primary containment between the deminerallred water supply header to the reactor building headers.
This piping performs no safety function in bringing the reactor to the cold shutdown condition.
This function is not needed to bring the reactor to 'he safe shutdown condition or to mitigate the consequences of an accident. The only safety function provided by this section of piping is to maintain a containment boundary following an accident.
Inspection Requirement:
ASME Section XI, paragraph I WC-5 210 ( a )( 1 ). requires that all code Clasa ; systems or portions of systems that operate during normal reactor operation or are not required to undergo periodic functional tests to meet owners' requirements must be hydrostatiently tested once each inspection interval.
Basis for t
Relief:
The subject piping section is classif ied ASML (ode Class 2 because it performs the safety function of providing primary containment isolation.
This pipin,; performs no safety function in bringing the reactor to the safe shutdown condition or in mitigating the consequences of an accident.
During accident conditions, this line will be isolated by its containment isolation valves.
Aspartofthecontain.hnt isolation system, this piping is tested in accordance wt.h Appendix J of 10 CFR 50.
Appendix J requires that each conta' ment isolation valve he leak tested eachrefuelingoutageanisthat the entire primary containment be tested three times in e /ery 10-year period. The test pressure for these leakage tests is based on the design accident pressure for the containment system.
During the leakage test at each
(
outboard containment isolation valve, the code Class 2 piping between the isolation valves is subjected to a leakage test.
The presence of any leakage from the test volume greater than that allowed for the isolation valve requires evaluation and corrective action.
The leakage test pressure of 12 psig is equal to the design accident pressure for the containment vessel.
This test pressure is much less than the Section XI hydrostatic test pressure of 1.1 times the design pressure of 100 psig.
- However, the containtrent accident pressure is the pressure at which this piping is required to perform its satety function.
l l
t i
1 l
REqyEST_ TOR RE1,lEF ISPT-!
[
The purpose of the ASME Section XI hydrostatic pressure test is f
to verif y the structural integrity of the pressure-retaining components to ensure their ability to perform their safety function. The safety function of this piping is to provide prinary containment integrity.
The Appendix J testing program la specifically designed to demonstrate the ability of a
}
component to perform this function.
A significant number of man-hours are required in the
[
development and performance of the ASME Section XI hydrostatic pressure test for this piping.- The estinated cost to TVA for i
-procedure development and test p6rformance is approximately
$6,000 per unit. This hydrostatic pressure test requires i
several entries into radiation areas to conduct test equipment I
setup, valve alignments, visual inspections, and equipment removal.- These activities result in significant personnel exposure.
Based on previous similar tests, the estimated-
{
radiation exposure for thi. hydrostatic test is 800 millirem per
[
unit.
In consideration er the salety. function of the subject piping, the Appendiv f.esting performed on this piping, and the
~
man-hours and r,oiation exposure required to perform-the Section t
-XI_ hydrostatic test, it is concluded that compilance with the
[
specified requirements would result in an unnecessary hardship l
without a compensating increase in the level of quality and safety.
[
Alternate Testing:
The structural integrity of the subject piping will be verified during. testing performed under 10 CFR 50 Appendix J.
This i
. includes a leakage test performed each refueling outage.
[
t Ii I
t i
t I
r 1
ir
.t F
i v
r
.t i
I
._._i..a.,._.-,.~
-._,.-__,,,-.,-....-,._._,,.;.-..-,.-.,_,.-.-.-,...E
8 REQUEf7 FOR RELIEF ISPT-9 Componentst Air conditioning chilled water system piping between containment isolation valves'FCV-31C-222 FCV-31C-223, and VLV-31C-752 FCV-31C-224, FCV-31C-225, and VLV-31C-7341 FCV-31C-229, FCV-310-230, and VLV-31C-7151 and FCV-31C-231, FCV-31C-232, and VLV 31C-697.
4 Clacs: ASME code class 2 (equivalent)
Function: The subject Class 2 piping, which penetrates primary containment, is a small section of plant process piping between inboard and outboard-con; air. ment isolation valves. This piping provides a-flow path through primary containment between the reactor building instrument-room water chiller unit and the instrument room air handling unit. This function is not needed
-to bring the reactor to the-safe shutdown condition or to mitigate _the consequences of an accident. The only safety function-pr ided by this section of piping is to maintain a containment boundary following an accident, inspection-Requirement: ASME Section X1. paragraph !WC-5210(a)(1), requires that all code Class 2 systems or portions of systems that operate daring normal reactor operation or are not required to undergo periodic functional tests to meet owners' requirements must be hydrostatically tested ~once each inspection interval.
Basis for-Relieft The subject piping section-is classified ASME code Class 2 because it performs the safety function of providing primary containment isolation.
This piping performs no safety function
-in bringing the reactor to the safe shutdown condition or in mitigating the consequences of an accident.
During accident conditions, this line will be isolated by its containment isolation valves.
l' As part of the containment isolation system, this piping is tested in accordance with Appendix J of 10 CFR 50.
Appendix J requires that each containment isolation valve be leak tested each refueling outage and that the entire primary containment be tested three tiines -in every 10-year period.
The test pressure for these leakage tests is based on t'.ie design accident pressure-for'the containment system.- During the leakage test of each outboard containment isolation valve,-the code Class 2 piping between the isolation valves is subjected to a. leakage test.
The presence of any leakage from the test volume greater than that allowed for the isolation valve requires evaluation and corrective action.
4 u
2 4
RFQp,EST FOR RELIEF ISPT-8 The leakage test pressure of 12 psig is equal to the design accident pressure f or the containn.ent vessel.
This test pressure is much less than the Section XI hydroatatic test pressure of 1.1 times the design pressure of 65 psig.
- However, the containment accident pressure is the pressure at which this piping is required to perform its safety f unction.
It should be noted that this piping has a relief valve to protect it from over pressurization.
The purpose of the ASME 6ection XI hydrostatic pressure test is to verify the structural integrity of the pressure-retaining components to ensure their ability to perform their safety function.
The safety function of this piping is to provide primary containment integrity.
The Appendix J testing program is specifically designed to demonstrate the ability of a component to perf orm this function.
A significant number of man-hours are required in the development and performance of the ASME Section XI hydrostatic n
pressure test for this piping. The ertinated cos t to TVA for procedure development and test perf on tance is approximately
$10,000 per unit. This hydrostatic pressure test requires f
6everal entries into radiation areas to conduct t e s t e qui p..te n t setup, valvo alignments, visual inspections, and equi nent t
removal.
These activities result in significant personnel exposure.
Based on previous similar tests, the estimated radiation exposure for this hydrostatic test is 800 millirem per unit.
In consideration of the safety function of the subject piping, the Appendix J testing performed on this piping, and the nan-hours and radiation exposure required to perform the Section XI hydrostatic test, it is concluded thst compliance with the specified requfrements would result in an unnecessary hardship without a compensating increase in the level of quality and safety.
Alternate Testing:
The structural integrity of the subject piping will be verified during tasting performed under 10 CFR 50 Appendix J.
This includes a leakage test performed each refueling outage.
. _ _. -