ML20215L142
| ML20215L142 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 10/20/1986 |
| From: | Papanic G YANKEE ATOMIC ELECTRIC CO. |
| To: | Mckenna E Office of Nuclear Reactor Regulation |
| References | |
| DCC-86-137, FYR-86-087, FYR-86-87, NUDOCS 8610280493 | |
| Download: ML20215L142 (5) | |
Text
YANKEE ATOMIC ELECTRIC COMPANY Tc'epho"e(6 ")a' **'00 TWX 710-380-7619
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r 1671 Worcester Road, Framingham, Massachusetts 01701 g _.C
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DCC 86-137 0.1 J l '. E E 2.C2.1 October 20, 1986 FYR 86-087 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Eileen M. McKenna, Project Manager Project Direcorate #1 Division of PWR Licensing - A
References:
(a) License No. DPR-3 (Docket No. 50-29)
(b) Letter J.A. Kay to D.M. Crutchfield, USNRC, dated 10/2/81, " Revised Inservice Inspection Program".
(c) ASME Code Section XI 1977 Edition Summer 1978 Addendum.
Subject:
Inservice Inspection Program Changes
Dear Ms. McKenna:
Yankee Atomic Electric Company submitted their Inservice Inspection Program (ISI) plan (Reference b) in accordance with the requirements of the Code of Federal Regulations, Title 10 Part 50 55.a.
A comprehensive engineering review of this document based on system design changes, revised plant drawings and operating procedures, has identified a number of component examinations that are either impossible or impractical to perform without placing undue burden upon the plant. Additionally, some component examinations were in excess of ASME Section XI requirements.
Therefore, in accordance with 10CFR 50 55 (g) (5) (iv), Yankee Atomic Electric Company submits the enclosed changes to the ISI program including additional relief requests from ASME Section XI Code requirements as identified in.
FEE An application fee of $150.00 is enclosed in accordance with 10CFR 170.21.
We trust you will find this submittal satisfactory however, if you have any questions or require additional information, please contact us.
I Very truly yours, i'
N l
60 YANKEE ATOMIC ELECTRIC COMPANY g'
d fk Vern Georg apanic[/Jr.
Senior Project Engineer - Licensing
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g Enclosure 8610280493 861020 PDR ADOCK 05000029 G
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Relief Requests 1.
Charging and Volume Control System Code Category C-H ASME XI 1977 Edition Sumer 1978 Addendum.
Code Requirement:
IWC-5222 (a): The system hydrostatic test pressure shall be at lgast 1.10 times the system pressure Psv with design temperature of 200 F or less, and at least 1.25 timeg the system pressure Pav for systems with design temperature above 200 F.
Code Relief Request:
Class 2 portions of the charging system (from CH-MOV-522/523 to CH-V-611/
CH/V-617 cannot be hydrostatically tested at the Class 2 required pressure.
This would result in overpressurization of the unisolatable Class 1 piping.
Yankee requests relief from this Code requirement.
Proposed Alternative Examination:
This section of piping will be subjected to a hydrostatic test at the Class 1 required pressure which provides assurance of pressure boundary integrity.
2.
Safety Injection Nitrogen System Code Category C-H ASME XI 1977 Edition Sumer 1978 Addendum.
Code Requirement:
IWC-5222 (a): The system hydrostatic test pressure shall be at 1gast 1.10 times the system pressure Psv with design temperature of 200 F or less, and at least 1.25 timeg the system pressure Psv for systems with design temperature above 200 F.
Code Relief Request:
Yankee requests relief from subjecting the Safety Injection Nitrogen System to a hydrostatic test at 1540 Psi. This system is comprised of carbon steel storage tanks and piping, and residual moisture remaining in this system following hydrostatic testing may result in degradation or total inoperability of the system.
Proposed Alternativo Examination:
As requircd by technical specifications, this system is charged continuously to 1294 psi.
As an alternative, Yankee will continue with an Ongoing Pressure Monitoring System which provides assurance of the pressure boundary integrity.
L
. s 3.
Inservice Testing of Valves in Nuclear Power Plants, IWV, Safety Valve and Relief Valve Tests, ASME XI 1977 Edition Summer 1978 Addendum.
Code Requirement:
IWV-3512 Test Procedure: Safety Valve and Relief Valve setpoints shall be tested in accordance with ASME PTC 25.3 1976.
PTC 25.3, 1976 Section 3.0.2:
A person who supervises the test shall have a formal education in thermo-dynamics and fluid mechanics.
In addition, he shall have at least two years practical experience in fluid flow measurement and have had experience in test supervision.
Code Relief Request:
Yankee requests relief from this code requirement. ASME Section XI Safety Valve tests include setpoint check only. Since no fluid flow measurements or tests are performed, these requirements are unrealistic.
Proposed Alternctive Examination:
As an alternative, at a minimum the person supervising the test shall have two years practical experience in safety valve setpoint testing and be certified at least a level II per ANSI N45.2.6 1976 in accordance with the Yankee Atomic Electric Company Quality Assurance Manual.
4.
IWV - Inservice Testing of Valves in Nuclear Power Plants, ASME XI 1977 Edition Sumer 1978 Addendum.
System / Component:
CH-V-773, Charging and Volume Control / Seismic SAFE Shutdown System, Code Class 2/ Safety Position: Open.
Code Requirement:
INV-3412: Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation.
If only limited operation is practical during plant operation, the valve shall be part stroked exercised during plant operation and full stroke exercised during cold shutdown.
Code Relief Request:
Yankee requests relief from this Code requirement since cycling CH-V-773 to the safety position of Open would introduce radioactive water into a normally non-radioactive system. This is an unacceptable consequence for testing this valve.
Proposed Alternative Examination No".e.
I t
_ ~
5.
IWV - Inservice Testing of valves in Nuclear Power Plants, ASME Section XI 1977 Edition Sumer 1978 Addendum.
System / Component:
VD-V-ll57 Emergency Feedwater Blowdown System, Seismic SAFE Shutdown System, Code Class 2/ Safety Position: Open.
Code Requirement:
I IWV-3412: Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation.
If only limited operation is practical during plant operation, the valve shall be part stroked exercised during plant operation and full stroke exercised during cold shutdown.
f Code Relief Request:
Yankee requests relief from this code requirement since cycling VD-V-1157 to the safety position of Open will introduce untreated water into the STEAM Generator Feedwater System.
This is an unacceptable consequence for testing this valve.
Proposed Alternative Examination:
l None.
I 6.
(39) Class 2, Shutdown Cooling System Pipe Welds, Code Category C-F, ASME XI 1974 Edition Sumer 1975 Addendum.
Code Requirement:
IWC-2411(b): The examinations required by IWC-2520 shall be examined such that 100% of the required examinations of the components will be completed over the systems' service lifetime.
IWC-2411(c): The required examinations assigned to the components in each stream of the system shall be completed by the end of the service lifetime, but divided among the number of inspection intervals (e.g.
four intervals for 40 year design service lifetime).
Code Relief Request:
Yankee requests relief from the requirement that 100% of the required examinations be completed over the service lifetime of the plant, and I
proposes prorating the number of welds (39) required to be examined during the first interval.
When Yankee completed its 1st inspection interval in 1974, examination of Safety Class 2 pipe welds were not required by Section XI keeping with the intent of Section XI, (to examine a percentage of welds over time to identify any system degradation). Yankee does not believe any 4
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benefit is obtained by backfitting the number of welds required to be inspected for the 1st interval.
In addition, these examinations would result in unnecessary radiation exposure as well rs additional time and manpower considerations.
Proposed Alternative Examination:
I Yankee will examine the remaining 116 welds (or 75%) over the service lifetime of the plant.
7.
(33) Class 2 Safety Injection Pipe Welds, Code Class C-F, ASME XI 1974 i
Edition Suamer 1975 Addendum.
Code Requirement:
IWC-2411(b): The examinations required by IWC-2520 shall be examined such that 100% of the required examinations of the components will be i
completed over the system's service lifetime.
IWC-2411(e): The required examinations assigned to the components in each stream of the system shall be completed by the end of the service life time, but divided among the number of inspection intervals (e.g.
four intervals for 40 year design service lifetime).
Code Relief Request:
Yankee requests relief from the requirement that 100% of the required examinations be completed over the service lifetime of the plant, and proposes prorating the number of velds (33) required to be examined during the first interval.
1 When Yankee completed it 1st inspection interval in 1974, examination of Safety Class 2 pipe welds were not required by Section XI.
Keeping with the intent of Section XI, (to examine a percentage of welds over time to identify any system degradation), Yankee does not believe any benefit is obtained by backfitting the number of welds required to be inspected for the 1st interval.
Proposed Alternative Examinations:
Yankee will examine the remaining 103 volds (or 75%) over the service lifetime of the plant.
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