ML20086M388
| ML20086M388 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/06/1991 |
| From: | Devine J GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 5000-91-2084, C321-91-2280, NUDOCS 9112170388 | |
| Download: ML20086M388 (7) | |
Text
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MNuclear GPU Nuclear Corporation
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Parsippany, New Jersey 07054 201 316 7000 TRIX 130 492 Wrwa Direct Dial Nurnter C321 91-2200 5000-91-2084 December 6, 1991 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555 b
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50 219 Request to invoke ASME Code Case N 498
References:
1)
Letter No. 5000 90 1996 dated December 7, 1990 GPUN to USNRC 2)
Letter dated March 26, 1991, USNRC to GPUN By Reference 1 noted above, GPU Nuclear requested relief from the ASME 10 year hydrostatic testing requirements contained in IWB-5222 for Class 1 systems and IWC-5222 for Class 2 systems.
In that letter, GPUN provided a basis for relief by proposing the application of an ASME code case which was in final review. Appropriate alternate test requirements were specified within the limits of the pending code case.
By Reference Y noted above, the USNRC denied the GPUN request citing:
"It is the NRC's position to not grant relief to a specific nuclear power plant based upon a possible change to the code....'
On May 13, 1991, ASME approved Code Case N 498, (Attachment 1).
In accordance with Attachment I and the approved Code Case, GPU Ni' lear requests relief from: 1) IWB-5222 as described in Attachment II; and ) IWC-5222 as described in Attachment III.
Code Case N-498 will be used to conduct the remainder of the pressure testing during plant operation. These pressure tests are the only remaining items to be performed to close out the current inspection interval.
Therefore, we request an expeditious review of this relief request.
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5000-91-2034 C321-91-2280 Page 2 If any further information is required, please contact !!r. John Rogers at 609-971-4893.
Very truly yours, c
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7 J.C. DeVine, Jr.
' lice President & Director Technical functions JCD\\JJR:jc cc:
Administrator, Region 1 Senior NRC Resident Inspector Oyster Creek NRC Project Manager i
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l A1TACPMENT 1 CASE N 498 CME 3 0F A8ML 10!LI.R AND PRE 3aVa5W13Lt.CDU&
Approval Detet May is, itst See Numerreal anges (or saevsten one any renMWmseen aassa.
Cass N.4ts (d) Tut temperaturss and pressures sasu not Alternative Reiss for 10. Year Hydrestatte Prussars eresed limiting conditions for byerestatic test curve Tutlas for Class 1 and 2 Systems as contained irr the pisnt Techaksi spessosations.
Sectlen XI. Divisten 1 (3) The VT.2 visual satminadan shall include all components Whtn the boundary id4Ati6sd in (2)
- above,
/nquhy: What afternattvs ruiss may be ussd in llau (b) !!is also the opinion of the Camertets:that, u of thws recivired by 1setion XI. Division 1. Table er alismative to the 10 year hyerostatte pressurs test IWD.15001, Category B.P. and Tabis IWC.2.5001.
resultad by Table IWC.23001, Catspry C41, the Category C.H. for the 10 year hydrostatic prusure fotoming rules shall be ussd.
test?
(1) A system pressurs test shall be conductea at er naar the sad of each inspectton tmerral or during the aaras inspsocon period of sash ig+2+i inter.
val of Inspection Program 2.
prpty fs) It is the opinion of the Ccmmittee that as an (2) The boundary sub)ses to test pressatuation altername to the 10.vsar hydrostatic pressurs teu during % ryness pressure test shau smead to all Clus 2 a:ponsats inodudsd in those postions of sys-required by Tabla 1WS.25001. Category 8.P. the followmg r.dse shall be used.
tems requirwd to operate or support tbs saisty pretsm (1) A systeen leaka$s test (!WB.3221) shall be function up to and including the Srst eersnaNy closed condusted at or near the and of each inspection in.
vaM (includists a safety or tensivalve) or ufre ca.
isrval, prior to reactor startup, pable of.utomatic clorun esa the seAsty funetfoa (2) Th* boundary subjset to tut prenvrization is required.
during the system Isakap tut shall extend to s.tl (J) Prior to performing Vid visual examins.
Cus 1 p wis rutaming components within the sys.
tion, the systsm shall be prsarernsd to reminal op.
tem boundary, ersting prsssure for a mmimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insu-(J) Prior to parforming YT.2 visual examina.
lated systems and 10 minutas for nonmsulated tion. the systam shall be prenurtaed to nominal op.
rystems. De syr;sm shall be maintained at nominal ersung pressurt for at laut 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated opersung pressure during the perimmanos of the rystems and to minutu for noninsulated rystems.
VT.2 visual exammation.
The system shall be masatsmad at nominal operating (4) The V't.2 visual saarmosoon shall incl de prsuurs c.tring the performance of ths VT.2 virual all components within the bouncary ider.tified in (2) ersmmanon-ebove.
1 611AW!iERLJ1 MLESRE RET AININGl0MPONENTS ELaliS.1 CAliCORY B E
[QQf E 0VIREMENT Section XI c7 the ASHE Code, 1980 Edition through the Winter 1981 Addenda, Tabic IWB 25001 Examination Category B P requires a System Hydrostatic Pressure Test (IWB-5222) be performed on all Class 1 pressure retaining components (e.g. reactor vessel, piping, pumps and valves) once every 10-year interval. Class 1 Ly_ i m lly11rgitatic Pressure Testi are conducted at reduced test pressures (Table IWB 5220 1) to meet the requirements of fracture prevention criteria arolicable to ferritic materials of system components.
For Oyster Creek Nucle v Generating Station, the test pressure is 1135 psig at a tem 3erature greater tha. 220' F.
The hydrostatic test pressure is held for four 1ours prior to, and during, the VI-2 visual examination.
Category B P also requires a System Leakage Test (IWB 5221) to be conducted prior to plant startup following each reactor refueling outage.
The pressure retaining boundary during the system leakage test shall correspond to the reactor coolant system boundary including the pressure retaining components within the system boundary which contain pressurized reactor coolant during normal reactor startup. Lyittm Leakagg h 111 are conducted at test pressures not less than the nominal crerating pressure associated with 100% rated reactor power.
For Oyster Creek Nuclear Generating Station, the nominal test pressure is 1040 psig at a_ test temperature _ greater than 215'F.
No holding time is required prior to performing the visual examination.
[0DE RELIEF RE0 VESTED Relief is requested from performing a category B-P System Hydrostatic Pressure Test (1WD-0222), on Class 1 pressure retaining components once every 10-year interval.
DallS FOR RELIE[
As an alternative to performing a System Hydrostatic Pressure Test once per inspection interval, JPUN is proposing to perform a System Leakage Test once per inspection interval at nominal operating pressure with an additional test requirement to hold the test pressure for four hours prior to, and-during, the l
H-2 visual examination.
The basis for this relief is supported b) ASME Code Case N 498.
Hydrostatic Pressure Tests above nominal operating or design pressure are a standard prerequisite for verifying the integrity of the design, material e
l selection, component fabrication and system installation for preservice acceptance. Many of the in-servve related indications develop gradually and l
are detected by surveillance and inspection programs.
The Section XI Hydrostatic Pressure Test offers-very little increase in the confidence level for the integrity and reliability of systems already included in a regular surveillance and inspection program.
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2 The requirements for performing the Section XI Hydrostatic Pressure Test
-significantly burdens Oyster Creek with unnecessary radiation exposure and dedication of manpower resources.
Special valve line ups, relief valve gagging and by pass jumpers are needed in order to perforn, a higher than nominal operating pressure test. A System Leakage Test pressurized to nominal operating pressure with a four hour hold time shall allow sufficient time for leakage to permeate through insulated components.
The proposed alternate test requirements to perform a VT 2 visual examination during a four hour System Leakage Test provides an acceptable level of assurance that the leak tightness of Class 1 pressure retaining components is maintained.
ER0 POSED ALTfRNATIVE TESTUM lt is requested that ASME Code Case N 498, response "a", be invoked to allow the following test be performed as an alternative to the Class 1 10 year Hydrostatic pressure Test (lWB 5222 as specified in Table IWB 2500 1 Category B P)i l.
The System Leakage Test will be performed once each inspection interval, prior to reactor startup without use of nuclear heat.
2.
The boundary subject to test pressurization during a System Leakage Test will extend to the pressure retaining components within the system boundary containing pressurized reactor coolant during hot standby in the start up mode.
3.
The system will be held at nominal operating pressure (1040 psig) for a minimum of four hours prior to the start of the leakage test and during performance of the VT-2 visual examination.
4.
The-VT-2 visual examination will extend t all components within the safety class boundary as identified in (2) above, i
AllAtlMENT 111 ERES1URE REiAUtilfLCORQtiDils G AS5 2 - CAM GORY C H
@DE RE0VIREMENT Section XI of the ASME Code, 1980 Edition through the Winter 1981 Addenda, i
Table IWC 2500-1 Examination Category C H requires System Hydrostatic Pressure Test (lWC 5222) be performed on r11 Class 2 pressure retaining components (e.g. pru sure vessels, piping, pumps and valves) once every 10 year interval.
The System Hydrostatic lest pressure shall be at least 1.10 times the system pretsure (Pav) for systems with design temperatures of 200'F or less, and at least 1.25 times the system pressure (Pav) for systems with design 1
temperatures above 200*F. The system pressure (Pav) shall be the lowest pressure setting among the number of safety or relief valves provided for overpressure protection within the boundary of the systems tested.
For systems not provided with safety or re,'ef valves, the system design pressure (Pd) shall be substituted for Pov.
A four hour holding time is required af ter attaining the test pressure and temperature conditions for insulated systems, and ten minutes for non insulated systems or components.
Category C H also requires a System Leakage Test once each inspection period i
conducted during a " System functional Test" of those systems or portions of systems not required to operato during normal reactor operation.
A ten minute holding time is required after attaining the system operating pressure.
Category C-H does not require a leakage test on Class 2 t,ystems that are normally in service during reactor power operation.
G DE REllEF RE0 VESTED Relief is requested from performing a Category C-H System Hydrostatic Pressure Test (lWC-5222) on Class 2 pressure retaining components once every ten year interval.. ASIS FOR REllEE As an alternative to performing a Hydrostatic Pressure Test once per inspection. interval, GPUN is-proposing to perform a System Leakage Test once per inspection interval at nominal operating pressures on all Class 2 systems. To ensure that small leaks will propagate through pipe insulation to become i visible, the systems will be held at nominal operating pressure for four hours for insulated systems, and for ten minutes for non-insulated systems prior to the start of the visual inspection. The system will be maintained at nominal operating pressure during performance of the VT-2 visual examination. The basis for this alternative is supported by ASME Code Case N 498. l Hydrostatic Pressure Tests above nominal operating or design pressure are a standard prerequisite for verifying the integrity of the design, material selection, component fabricating, and system installation for preservice l acceptance. l l l
i Attachment !!! 2-Many of the inservice related indications develop gradually and are detected by surveillances and inspection programs. The Section XI Hydrostatic Pressure Test offers very little increase in the confidence level for the integrity and reliability of systems already included in a regular surveillance and inspection progr.m. Performance of the Hydrostatic Pressure Test for Class 2 Pressure Retaining comr vents has a signific W impact of unnecessary radiation exposure and manpower researces. The % t u ted craft expenditures, nrt including corrective maintenance, woule te an additional 3 REM exposure and approximately 5,000 craftman hours. Each system boundary is defined by the components which have the same minimum required classification and are designed to the same primary pressure rating as governed by the system function and internal fluid operating conditions. Pump and valve packing require more corrective maintenance as the components are challenged by the test pressure exceeding the normal operating parameters. Building and removing staging platforms for valve wrk activities increases. Radwaste expenditures are increased when draining systems for valve work activities. A more effective and efficient 3ressure test progiam would be the performance of a System Leakage Test pressurized to nominal operating pressure on all Class 2 systems once each inspection interval, rather than the present combination of 10-year Hydrostatic and ten minute " Functional" Pressure Tests every inspection period. PR0p0 SED AL1ERNATIVE TESTING lt is requested that ASME Code Case N-498, response "b", be invcked to allow the follow!ng test be performed as an alternative to the Class 2 ten year Hydrostatic Pressure Test (IWC-5222 as specified in Table IWC-2500-1 Category C-H): 1. The System Leakage Test will be performed once per inspection interval on all Class 2 systems. 2. The boundary subject to test pressurization will extend to those pressure retaining components under nominal operating pressure during normal system service. 3. The system will be at nominal operating pressure for a minimum of four hours for insulated systems, and for at least ten minutes for noninsulated systems prior to the start of the leakage test. 4. The VT-2 visual examination will extend to all components within the safety class boundary. (Rogers /C321 91-2280) __}}