NRC-2006-0078, 10 CFR 50.55a Request, Resubmittal of Relief Request 15, Fourth Ten-Year Interval Inservice Inspection (ISI) Program

10 CFR 50.55a Request, Resubmittal of Relief Request 15, Fourth Ten-Year Interval Inservice Inspection (ISI) Program

ML063320377
Person / Time
Site:	Point Beach
Issue date:	11/20/2006
From:	Koehl D Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-2006-0078
Download: ML063320377 (6)

Text

Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC November 20,2006 NRC 2006-0078 10 CFR 50.55a U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 10 CFR 50.55a Request Resubmittal of Relief Request 15 Fourth Ten-Year Interval Inservice Inspection (ISI) Program

References:

1. Letter from Nuclear Management Company, LLC to NRC Document Control Desk, "Relief Request from the Provisions of ASME Section XI, IWA-5244, 'Buried Components,' Relief Request 15," dated January 21,2005, ADAMS Accession Number ML050250178.

2. Letter from Nuclear Regulatory Commission to Nuclear Management Company, LLC, "Point Beach Nuclear Plant, Units 1 and 2 - Request for Additional Information Re: Relief Request from the Provisions of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI (TAC Nos. MC7770 and MC7771)," dated August 12,2005, ADAMS Accession Number ML052210268.

3. Letter from Nuclear Management Company to NRC Document Control Desk, "Response to Request for Additional Information: Relief Request from the Provisions of ASME Section XI, IWA-5244, 'Buried Components,' Relief Request 15 (TAC Nos. MC7770 and MC7771),"

dated August 26,2005, ADAMS Accession Number ML052500533.

4. Letter from Nuclear Management Company to NRC Document Control Desk, "Request for Withdrawal: Relief Request from the Provisions of ASME Section XI, IWA-5244, 'Buried Components,' Relief Request 15 (TAC Nos. MC7770 and MC7771)," dated October 14,2005, ADAMS Accession Number ML053040428.

6610 Nuclear Road Two Rivers, Wisconsin 54241-9516 Telephone: 920.755.2321

Document Control Desk Page 2

5. Letter from Nuclear Regulatory Commission to Nuclear Management Company, LLC, "Point Beach Nuclear Plant, Units 1 and 2 -Withdrawal of Relief Request 15 from the Provisions of ASME Code,Section XI, IWA-5244, 'Buried Components' (TAC Nos. MC7770 and MC7771),"

dated December 14,2005, ADAMS Accession Number ML053130082.

6. Letter from Nuclear Regulatory Commission to Nebraska Public Power District, "Cooper Nuclear Station RE: Fourth 10-Year Interval Inservice Inspection Request for Relief No. PR-06 (TAC No. MD0286)," dated October 2,2006, ADAMS Accession Number ML062260217.

This letter requests that the Nuclear Regulatory Commission (NRC) grant the Nuclear Management Company, LLC (NMC) relief from and authorize alternatives to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (Code),Section XI, IWA-5244, "Buried Components," for the fourth ten-year interval inservice inspection program for Point Beach Nuclear Plant (PBNP) pursuant to 10 CFR 50.55a(a)(3)(ii). The basis for the request is that compliance with the specified requirements for pressure testing buried piping would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The details of the relief request are contained in Enclosure 1.

This relief request was previously submitted (reference I ) , supplemented (reference 2 and 3), and subsequently withdrawn (reference 4 and 5). However, subsequent to the withdrawal, NMC concluded that relief from the requirements of IWA-5244 is appropriate.

Accordingly, this relief request is being resubmitted for the fourth ten-year interval, which ends June 30, 2012. Additionally, Cooper Nuclear Station recently received a similar relief from the requirements of IWA-5244 (reference 6).

NMC requests approval of the relief request by November 30, 2007.

Summary of Commitments This letter contains no ne ommitments and no revisions to existing commitments.

~49 Dennis L. Koehl Site Vice-president

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Enclosure cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Mr. Mike Verhagan, Department of Commerce, State of Wisconsin

ENCLOSURE 1 Proposed Alternative In Accordance with 10 CFR 50.55a (a)(3)(ii)

Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality of Safety 1.0 ASME CODE COMPONENTS AFFECTED Approximately 90 feet of Class 3, 30-inch diameter carbon steel service water (SW) piping for each unit is buried between the Circulating Water Pump House and the Turbine Building. These sections of piping are not accessible for pressure testing.

2.0 APPLICABLE CODE EDITION AND ADDENDA:

The inservice inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 1998 Edition with 2000 Addenda.

3.0 CODE REQUIREMENT Examination Category D-B, Item No. D2.10 requires a system leak test and visual examination of the service water piping. For buried components where a VT-2 visual examination cannot be performed, the examination is satisfied by IWA-5244(b).

IWA-5244, Buried Components:

(b) For buried components where a VT-2 visual examination cannot be performed, the examination requirement is satisfied by the following:

1) The system pressure test for buried components that are isolable by means of valves shall consist of a test that determines the rate of pressure loss. Alternatively, the test may determine the change in flow between the ends of the buried components. The acceptable rate of pressure loss or flow shall be established by the Owner.

2) The system pressure test for non-isolable buried components shall consist of a test to confirm that flow during operation is not impaired.

3) Test personnel need not be qualified for VT-2 visual examination.

4.0 REASON FOR REQUEST Pursuant to 10 CFR 50.55a, Codes and Standards, Paragraph(a)(3)(ii), relief is requested from the requirements of ASME Code Section XI, IWA-5244(b)(1), on the bases that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Page 1 of 4 Relief Request 15 The buried piping consists of about 90 feet of 30-inch diameter carbon steel piping located between the circulating water pumphouse and the turbine building.

The piping sections are buried approximately seven feet underground with a road built over the piping. There is no access to this buried piping other than by excavation. No annulus was provided during original construction that would allow for testing or examination of these buried sections of piping. Therefore, it is not possible to perform a direct VT-2 examination when performing a system leakage test.

For a pressure loss test, it would be necessary to close six large butterfly valves to isolate the buried piping, three per piping section. These valves are not expected to provide an adequate pressure test boundary. System modification or extensive valve seat maintenance on the six butterfly valves would be required to perform an adequate pressure loss test.

The PBNP service water system for both units is configured with a ring header such that both sides (e.g, north and south headers) of the system are supplying both units. Isolation for a pressure decay test of the buried piping would isolate one service water header. This action requires entry into dual unit Technical Specification Action Condition (TSAC) TS 3.7.8. PBNP TS 3.7.8 requires, "SW ring header continuous flow path not interrupted, for SW system operability. If the SW ring header continuous flow path is interrupted, the ability of the system to provide required cooling water flow to required equipment must be verified within one hour in accordance with TSAC 3.7.8.C, Required Action C.1 and the SW ring header continuous flow path must be restored within seven days in accordance with TSAC 3.7.8.C, Required Action C.2. Technical Specification Action Condition entries are minimized to ensure full capability of the system if ever challenged by a design basis event.

IWA-5244(b)(1) also allows determining the change in flow between the ends of the buried components. Flow instrumentation is installed on the downstream side of the buried piping, however, no flow instrumentation is installed on the upstream side of the buried piping. There is not a sufficient run of straight pipe upstream of the buried piping, therefore, accurate flow measurements using temporary ultrasonic flow meters are not possible. The installation of permanent flow instruments would require system modification.

Performing the specified examinations or testing would require either excavating the buried piping, entering multiple Technical Specification Action Statements, or performing major modifications to system piping. Therefore, compliance with the specified requirements is a hardship without a compensating increase in the level of quality and safety.

Page 2 of 4 Relief Request 15 5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE In lieu of performing a test in accordance with the requirements specified in IWA-5244(b)(1), NMC proposes to use the requirements of IWA-5244(b)(2).

IWA-5244, Buried Components:

(b)(2) The system pressure test for nonisolable buried components shall consist of a test to confirm that flow during operation is not impaired.

The integrity of the buried piping will be verified during quarterly service water pump testing. Trending of the pressure drop across each pump will indicate leakage through the buried piping assuming no degradation of the pump. Should the pump test results fall in the required action range of the Code, additional testing and evaluations will be performed to determine whether the unsatisfactory test results are due to degraded pump performance, pump test valve leakage, or through-wall leakage. If pump acceptance criteria is not met, the affected pump(s) will be declared inoperable, the appropriate TSAC will be entered, and an action request will be written for the affected equipment. An engineering evaluation will be performed to assess the change in the performance of the pump, including the potential for piping leakage.

NMC requests approval of the proposed alternative to test the buried portion of SW piping in conjunction with the quarterly testing of the SW pumps as it will detect significant through-wall leakage if present and would provide reasonable assurance of operational readiness.

6.0 DURATION OF PROPOSED ALTERNATIVE The duration of the proposed alternative is for the fourth inservice interval, which began on July 1, 2002, and is scheduled to end on June 30, 2012.

7.0 PRECEDENTS By letter dated February 23, 2006, Nebraska Public Power District (NPPD) submitted relief request No. PR-06, related to the fourth 10-year interval inservice inspection program for the Cooper Nuclear Station (reference 4). In Relief Request PR-06, the licensee requested relief from performing the ASME Code required pressure test of the buried portion of service water piping by measuring rate of pressure loss or change in flow between the ends of the buried components. Alternatively, the licensee proposed a test that will confirm that flow during operation is not impaired. By letter dated October 2, 2006, the NRC approved the relief request for the Cooper Nuclear Station (reference 3).

Similar to NPPD, NMC is also requesting relief from the ASME Code required pressure test of the buried service water piping and proposing an alternative that will confirm that flow during operation is not impaired.

Page 3 of 4 Relief Request 15

8.0 REFERENCES

1. ASME Section XI, 1998 Edition with Addenda through 2000

2. PBNP Technical Specification 3.7.8, Service Water (SW) System

3. Letter from NRC to Nebraska Public Power District, Cooper Nuclear Station Re: Fourth 10-Year Interval Inservice Inspection Request for Relief PR-06, dated October 2, 2006, ADAMS Accession Number ML062260217.

4. Letter from Nebraska Public Power District to NRC Document Control Desk, 10 CFR 50.55a Requests for Fourth Ten-Year Inservice Inspection Interval Cooper Nuclear Station, Docket No. 50.298, DPR-46, dated February 23, 2006, ADAMS Accession Number ML060590300.

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