ML20217K906

Safety Evaluation Accepting Plant First 10-yr Interval ISI Program Plan Relief Request PT-007

ML20217K906
Person / Time
Site:	Perry
Issue date:	08/12/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20217K903	List: ML20217K900 ML20217K906
References
NUDOCS 9708180253
Download: ML20217K906 (3)

Text

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN REOUEST FOR RELIEF PT-007 THE CLEVELAND ELECTRIC ILLUMINATING CO.

PERRY NUCLEAR POWER PLANT. UNIT NO. 1 DOCKET NO. 50 440

1.0 INTRODUCTION

The Technical Specifications for Perry Nuclear Power Plant (PNPP). Unit No. 1 state that the inservice inspection of the American Society of Hechanical Engineers (ASME) Code Class 1. 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50.55a(g), except where s)ecific R

written relief has been 50.55a(g)(6)(1), granted Section 50.55a(a by)the (3) Commission of 10 CFR Part pursuant 50 states to 10 thatC alternctives to the requirements of paragraph (g) may be used, when authorized by the NRC if (1) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4). ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the )reservice examination requirements. set forth in the ASME Code.Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components." to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsecuent intervals comply with the requirements in the latest edition and addenca of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b).12 months prior to the start of the 120 month interval, subject to the limitations and modifications listed therein. The applicable ASME Code.Section XI. for PNPP's first 10-year inservice inspection (ISI) interval is the 1983 edition through summer 1983 addenda. The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.5;a(b) subject to the limitations and modifications listed therein and subject to Commission approval.

ENCLOSURE 9708100253 970812 DR ADOcK0500g0

-24 Pursuant to 10 CFR 50.55a(g)(5) if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the Code requirement. After evaluation of the determination. pursuant to 10 CFR 50.55a(g)(6)(1), the Commission may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger '

life, property, or the common defense and security and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed.

In a letter dated June 12. 1997. The Cleveland Electric Illuminating Company (CEI), the licensee, submitted to the NRC its request for relief from performing the Code-required pneumatic test during the current inspection interval and proposed an alternative pressure test of the Class 3 safety or relief valve discharge piping into the containment pressure suppression pool.

The NRC staff has reviewed and evaluated the licensee's request for relief and the proposed alternative, pursuant to 10 CFR 50.55a(a)(3)(ii) for PNPP.

2.0 DISCUSSION COMPONENT:

Class 3 safety or relief valve piping which discharges into the containment pressure suppression pool.

EXAMINATION REQUIREMENT:

The ASME Code.Section XI, 1983 edition through summer 1983 addenda. Seti. ion IWD-5223(f) states that for safety or relief valve piping which discharges into the containment pressure suppression pool.-a-pneumatic test (at a pressure of 90% of the pipe submergence head of water) that demonstrates leakage integrity shall be performed in lieu of the system hydrostatic-test.

LICENSEE'S REQUEST FOR RELIEF: (As stated)

" Pursuant to 10 CFR 50.55a(a)(3)(ii) relief is requested from performing the Code required hydrostatic tests. An alternative pressure test is proposed."

LICENSEE'S BASIS FOR RELIEF:

The safety / relief valve discharge lines are basically open-ended piping that function to direct steam flow to the quencher in the containment pressure suppression pool and are not a leaktight pressure retaining boundary. The system pressure test at the end of the 10-year inservice insSection interval for the oiping requires pressurization to only 5.4 psig whic1 does not ensure leak tigit integrity but merely enhances detection of the location of through-wall flaws. In order to perform the Code-required 3ressure test, special test equipment to blank off the open-ended piping, attac1 ment of test connections and erecting scaffolding for application of soap solution for VT-2 visual

_ _ _ = _

o O examination, will be required involving considerable time, manpower, and radiation dose without a compensating increase in the level of quality and safety.

LICENSEE'S PROPOSED ALTERNATIVE: (As stated)

"As an alternative to the hydrostatic / ressure test requirement of IWD-5223(f), CEI proposes to perform the h drostatic/ pressure test requirements of section IWD-5223(d). Confirmation of dequate flow in accordance with section IWD-5223(d) will satisfy the inspection re examination (pressure retaining material),quirements the examination of the extent method (visual,of VT-2), and the frequency of examination (each inspection interval)."

3.0 EVALUATION The NRC staff has reviewed the licensee's request for relief from performing the required pneumatic test at 5.4 psig and to substitute an alternate test to confirm adequate flow through the open-ended safety / relief valve discharge piping to the suppression pool. The ASME Code,Section XI, 1983 edition through summer 1983 addenda also allows a test to confirm adequate flow as an

. alternative to the system hydrostatic test for open-ended portions of discharge lines beyond the last shutoff valve. The staff considered the mitigating factors such as man-rem and outage time expended in performing a pneumatic test of the open-ended discharge piping and determined that comaliance to the requirement of the Code would result in unusual difficulty wit 1out a compensating increase in the level of quality and safety. The staff further believes that the required pressure test at a pressure of 5.4 asig may not discover inservice leaks as a result of driving an existing throug1-wall flaw. On the contrary, the proposed flow test would ensure that the piping downstream of the safety / relief valve is capable of discharging inventory to the suppression pool unimpeded for which it is designed and, therefore, would provide reasonable assurance of operational readiness.

4.0 CONCLUSION

The licensee proposes to perform a flow test in accordance with Section IWD 5223(d) in lieu of the pneumatic test of the safety / relief valve discharge piping as required per Section IWD-5223(f) of the applicable ASME Code.

Section XI. The staff finds that the 3roposed testing provides reasonable assurance of operational readiness. T1e staff has determined that compliance to the Code requirement would result in unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the licensee's Relief Request No. PT-007 is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for Perry Nuclear Power Plant, Unit No. 1 for the first inspection interval.

Principal Contributor: P. Patnaik Date: August 12, 1997