RNP-RA/02-0065, Relief Request Number RR-12 for the Fourth Ten-Year Interval Inservice Inspection Program
| ML021360017 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 05/14/2002 |
| From: | Fletcher B Carolina Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RNP-RA/02-0065 | |
| Download: ML021360017 (12) | |
Text
10 CFR 50.55a S2CP&L A Progress Energy Company Serial: RNP-RA/02-0065 MAY 1 4 200Z United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 RELIEF REQUEST NUMBER RR-12 FOR THE FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM Ladies and Gentlemen:
The Fourth Ten-Year Interval Inservice Inspection (ISI) program and associated plan for H. B.
Robinson Steam Electric Plant (HBRSEP), Unit No. 2, was submitted to the NRC by letter dated August 17, 2001. Additional information was submitted by HBRSEP, Unit No. 2, in a letter dated April 5, 2002. A revised version of Relief Request Number RR-12 was included in that submittal.
In a conference call on April 23, 2002, with the NRC contract reviewer for this ISI program relief request, it was determined that Relief Request Number RR-12 would be improved by including information similar to that contained in the Relief Request Number RR-25 from the previous ISI interval. Therefore, Relief Request Number RR-12 is provided as an attachment to this letter. This version of Relief Request Number RR-12 includes the requested additional information and other minor clarifications, including the consistent use of "system leakage test" and minor corrections to Table 1. This version of Relief Request Number RR-12 supersedes the previous versions of this relief request.
The Fourth Ten-Year ISI Interval for HBRSEP, Unit No. 2, started on February 19, 2002. Therefore, approval this relief request is requested as soon as practicable to allow efficient implementation of ISI program requirements.
If you have any questions regarding this matter, please contact Mr. C. T. Baucom.
Sincerely, B. L. Fletcher III Manager - Regulatory Affairs Robinson Nuclear Plant 3581 West Entrance Road Hartsville, SC 29550
United States Nuclear Regulatory Commission Serial: RNP-RA/02-0065 Page 2 of 2 CAC/cac Attachment c: Mr. L. A. Reyes, NRC, Region II Mr. R. Subbaratnam, NRC, NRR NRC Resident Inspector, HBRSEP
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/02-0065 Page 1 of 10 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST NUMBER RR-12
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/02-0065 Page 2 of 10 Relief Request Number RR-12 Component(s) for Which Relief is Requested The components applicable to this relief request are the HBRSEP, Unit No. 2, Class 1 pressure test boundaries subject to system leakage testing in accordance with IWB-5222, "Boundaries," subsection (b).
Code Examination Requirements The ASME B&PV Code,Section XI, 1995 Edition with 1996 Addenda, IWB-5222(b),
requires that the pressure retaining boundary during the system leakage test conducted at or near the end of each inspection interval be extended to all Class 1 pressure retaining components within the system boundary.
Requested Relief HBRSEP, Unit No. 2, requests relief from the ASME B&PV Code,Section XI, 1995 Edition with 1996 Addenda, IWB-5222(b), regarding extension of the pressure retaining boundary during system leakage tests conducted at or near the end of the inspection interval to Class 1 pressure retaining components within the system boundary.
Basis for Relief HBRSEP, Unit No. 2, requests relief in accordance with 10 CFR 50.55a(a)(3)(ii) on the basis that hardship and unusual difficulty exists, without a compensating increase in the level of quality and safety, regarding extension of the pressure retaining boundary during system leakage tests to all Class 1 pressure retaining components within the system boundary.
Table 1 identifies the Class 1 pressure retaining components that are associated with the requested relief.
The HBRSEP, Unit No. 2, design of Class 1 vents and drains typically consists of a single isolation valve with a capped end that constitutes the Class 1 system boundary. Many of these valves are not readily accessible due to their physical locations and radiation/contamination levels in the area. System leakage testing is performed in Mode 3 and would involve opening these single isolation valves to pressurize to the extended Class 1 system boundary. After performance of the required VT-2 visual examination, these single isolation valves would be closed, isolating a high temperature, pressurized volume of water between the isolation valve and the capped end. This results in an undesirable configuration that would be conducive to pressure lock or the initiation of system leakage from valve packing or capped ends.
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/02-0065 Page 3 of 10 The IHBRSEP, Unit No. 2, design also requires substantial effort to extend the Class 1 system boundary where check valves or non-redundant components serve as the first system isolation from the reactor coolant system. Such configurations may require check valve disassembly or other temporary configurations to achieve test pressures at upstream piping and valves. Since the Class 1 system leakage testing is performed in Mode 3, these temporary configurations could conflict with Technical Specification requirements.
Establishing and restoring such temporary configurations could also result in an unwarranted increase in worker radiation exposures.
Based on the above, extension of the pressure-retaining boundary during system leakage tests to Class 1 pressure retaining components within the system boundary represents a hardship and unusual difficulty that does not provide a compensating increase in the level of quality and safety.
(The following is specific information pertaining to the various pipe segments for which relief has been requested).
Small Size Class I Vent, Drain, Test, and Fill Lines Relief is requested from fully pressurizing piping between the first and second isolation device on small size vent, drain, test, and fill lines. There are twenty-six vent, drain, test and fill lines in the Reactor Coolant System (RCS) ranging in size from 0.75 inch to two inches. The configurations are either two small isolation valves in series, a valve and blind flange, or a valve and cap. In some configurations, the piping between the two vent and drains will tee to a third valve that is also the second isolation boundary. The piping segments provide the design-required double isolation barrier for the reactor coolant pressure boundary. The Code-required leakage test would be performed in MODE 3 at the normal operating pressure of 2235 psig and at a nominal temperature of about 547 'F.
Leakage testing of these piping segments at nominal operating pressure in MODE 3 would require the opening of the inboard isolation valve at the normal operating RCS temperature and pressure conditions. In so doing, the design requirement for two primary coolant pressure boundary isolation devices would be violated. Additionally, opening of these valves introduces the potential risk for spills and personnel contamination. For configurations where blind flanges or caps are installed as the isolation device, opening of the inboard valve introduces the possibility of a personnel safety hazard if a flange or cap fails in the presence of inspection personnel.
These piping segments are VT-2 inspected through the entire length as part of the Class 1 system inspection at the conclusion of each refueling outage. The leakage test will not specifically pressurize past the first isolation valve for this inspection. No external or visible leakage will be allowed for a test to be successful. Since this type of test will assure that the combined first and second isolation devices are effective in maintaining
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/02-0065 Page 4 of 10 the reactor coolant pressure boundary at normal operating temperature and pressure, the increase in safety achieved from the Code-required leakage test is not commensurate with the hardship of performing such testing.
Larger Size Class 1 Piping Segments 14 Inch Residual Heat Removal Motor Operated Valves This piping segment consists of 42 feet of 10 inch piping between Residual Heat Removal (RHR) inlet valves RHR-750 and RHR-751. These valves are interlocked at a required setpoint of *__474 psig to avoid over-pressurization of the RHR system. The interlock prevents manual opening of the valves from the Control Room with RCS pressure above the setpoint. There are no test connection points in this segment of the line. This segment was last tested during the Second Ten-Year Inservice Inspection interval, with the vessel defueled, as part of the RCS hydrostatic test.
The piping segment is VT-2 inspected through the entire length as part of the Class 1 system inspection at the conclusion of each refueling outage. The proposed system pressure test will not specifically pressurize past the first isolation valve for this inspection. It is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. No external or visible leakage will be allowed for the test to be successful. This test will provide assurance that the combined first and second isolation valves are effective in maintaining the reactor coolant pressure boundary at normal operating temperature and pressure.
Safety Injection Loops Low Head Check Valves SI-875A, B, and C, and Upstream Piping These three piping segments consist of a 3 foot 8 inch piping span connected by a tee to a 10-inch piping span along with a short 0.75 inch connection. These lines are for injecting low head Emergency Core Cooling System (ECCS) water from the accumulators and the low head safety injection system (i.e., RHR system in ECCS configuration). The primary isolation and secondary isolation devices for the 8 inch and 10 inch lines are check valves oriented to flow into the RCS. The piping segments provide the design-required double isolation barrier for the reactor coolant pressure boundary.
Leakage testing in MODE 3 would require a pressure source be connected at each segment location. In so doing, the design requirement for two primary coolant pressure boundary isolation devices would be violated. For test locations located overhead and away from normal personnel access areas, ladders or scaffolding would have to be installed to provide access to the piping segment and to open the valve. This process would add to the occupational dose associated with leakage testing these lines.
These lines are located in areas involving occupational radiation exposure, and leakage testing of these lines would increase occupational radiation dose.
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/02-0065 Page 5 of 10 The leakage test will not specifically pressurize past the first isolation valve for this inspection. It is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. Otherwise, the pressure in the segment will be at least at the operating pressure of the ECCS accumulators, which are pressurized to between 600 and 660 psig. No external or visible leakage will be allowed for the test to be successful.
Since this test will assure that the combined first and second isolation devices are effective in maintaining the reactor coolant pressure boundary at normal operating temperature and pressure, the increase in safety achieved from the Code-required leakage test is not commensurate with the hardship of performing such testing.
Safety Injection Loop "B" and "C" High Head Check Valves SI-874A and B, and UpstreamPiping These two piping segments consist of a 2-inch piping span between two check valves oriented toward the RCS. These lines are for injecting high head ECCS water into the hot legs after an accident. The primary and secondary isolation devices are an inboard check valve oriented to flow into the RCS and an outboard motor-operated valve. The piping segments provide the design-required double isolation barrier for the reactor coolant pressure boundary. Leakage testing of these piping segments at nominal operating pressure in MODE 3 would require a modification to allow pressurizing to the normal operating RCS temperature and pressure conditions.
The leakage test will not specifically pressurize past the first isolation valve for this inspection. It is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. No external or visible leakage will be allowed for the test to be successful. This test will assure that the combined first and second isolation valves are effective in maintaining the reactor coolant pressure boundary at normal operating temperature and pressure.
Proposed Alternative Examinations The Class 1 system boundary during leakage tests will be maintained in a normal, operational alignment with items identified within Table 1 constituting exceptions to the Code-required boundary. The VT-2 visual examination will extend to the Class 1 boundary.
Items within Table 1 will be visually examined for evidence of leakage during system leakage testing without being pressurized.
Implementation Schedule This relief is requested for and will be implemented in the HBRSEP, Unit No. 2, Fourth Ten-Year ISI Interval, which began on February 19, 2002.
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/02-0065 Page 6 of 10 Table 1 Relief Request Number RR-12 Affected Class 1 Pressure Retaining Components Affected Line or Component Code Pipe Pipe Sch. Approx. Examination Drawing Boundary Exception(s)
Class Dia. Length Category No.
Drain line below PZR safety A376 TP316 5379-1971, Valve RC-545 remains closed to avoid valve RC-551A (pipe piece 1 0.75 in. < 1 ft. B-P pressurizing downstream Class 1 pipe between RC-545 and RC-545A) SMLSpiece and valve RC-545A Drain line below PZR safety A376 TP316 5379-1971, Valve RC-546 remains closed to avoid valve RC-551B (pipe piece 1 0.75 in. < 1 ft. B-P pressurizing downstream Class 1 pipe between RC-546 and RC-546A) SMLSpiece and valve RC-546A Drain line below PRZ safety A376 TP316 5379-1971, Valve RC-547 remains closed to avoid valve RC-551C (pipe piece 1 0.75 in. A376 TP3 16 <1 ft. B-P 57-91 pressurizing downstream Class 1 pipe between RC-547and RC-547A) SMLSpiece and valve RC-547A Vent valve and blind flange on A376 TP316 5379-1971 Valve RC-527C remains closed to avoid Ven vpaylveandblind1f 0.75 in. 160 < 1 ft. B-P Sheet pressurizing downstream Class 1 pipe PZR spray line Spiece and blind flange RCS loop intermediate loop "A" A376 TP316 5379-1971, Valve RC-505A remains closed to avoid drain valve and liquid waste 1 2 in. 1 ft. B-P pressurizing downstream Class 1 piping disposal piping SMLS Sch. 160 Sheet I and valve RC-505B A376 TP316 RCS loop intermediate loop "B" 2 in. SMLS Sch. 160 7 in. Valve RC-508A remains closed to avoid drain valve and liquid waste B-P 537e191 pressurizing downstream Class 1 piping disposal piping 0.75 in. A376 TP316 iSheet 1 and valves RC-508B and RC-542 SMLS Sch. 160 A376 TP316 RCS loop intermediate loop "C" 2 in. SMLS Sch. 160 8 in. Valve RC-515A remains closed to avoid drain valve and liquid waste 1 B-P Sheet 1 pressurizing downstream Class 1 piping disposal piping 0.75 in. A376 TP316 1 ft. and valves RC-515B and RC-601 SMLS Sch. 160
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/02-0065 Page 7 of 10 Table 1 (Continued)
Relief Request Number RR-12 Affected Class 1 Pressure Retaining Components Affected Line or Component Code Pipe Pipe Sch. Approx. Examination Drawing Boundary Exception(s)
Class Dia. Length Category No.
A376 TP316 Valves RC-567 and RC-568 remain closed 0.75 in. SMLS Sch. 160 53 to avoid pressurizing downstream Class 1 RPV head vent valves and piping and valves RC-569, RC-570, B-P Sheet 1 piping A376 TP316 ft. RC-571, RC-572, RC-573, RC-574, and SMLS Sch. 160 RC-575 RCP "A" seal injection drain A376 TP316 5379-685, Valve CVC-300A remains closed to avoid valP "a" sl injetindai 1 0.75 in. A376 TP3 16 <1 ft. B-P 5396t pressurizing downstream pipe piece and valve and blind flange SMLS Sch. 160 Sheet 1 flange RCP "A" seal leakoff vent valve A376 TP316 5379-685, Valve CVC-300C remains closed to avoid RCP sel a "A" flange o ne 1 0.75 in. A376 Sch. 160 SMLS < 1 ft. B-P Sh965 Sheet 1 pressurizing downstream pipe piece and and blind flange RCP "A" seal water byp~ass 1 0.75 in. A376 TP3 16 <1lft. B-P 5379-685, pressurizing Valve CVC-307D remainspipe downstream pieceto and closed avoid SMLS Sch. 160 Sheet 1 drain valve and cap cap iA376 TP316 Valve CVC-300D remains closed to avoid RCP "B" seal injection drain1 0.75 in. A376 16 <lft.
13 B-P 5379-685, pressurizing downstream pipe piece and valve and blind flange SMLS Sch. 160 Sheet 1 fag flange RCP "B" seal leakoff vent valve A376 TP316 5379-685, Valve CVC-300F remains closed to avoid RCP b" sla o ne 1 0.75 in. A37< TP316 1 ft. B-P 53e6t pressurizing downstream pipe piece and and blind flange SMLS Sch. 160 Sheet 1 flange RCP "B" seal water bypass 0A376 TP316 5379-685, Valve CVC-307E remains closed to avoid drCP "B"vsale water bapas 1 0.75 in. A7 10 < 1 ft. B-P 539e5 pressurizing downstream pipe piece and drain valve and cap SMLS Sch. 160 Sheet 1 cap
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/02-0065 Page 8 of 10 Table 1 (Continued)
Relief Request Number RR-12 Affected Class 1 Pressure Retaining Components Affected Line or Component Code Pipe Pipe Sch. Approx. Examination Drawing Boundary Exception(s)
Class Dia. Length Category No.
RCP "B" seal water bypass 1 0.75 in. A376 TP316 < 1 ft. B-P 5379-685, Valve CVC-307F remains closed to avoid drain valve and cap SMLS Sch. 160 Sheet 1 pressurizing downstream pipe piece and cap RCP "C" seal injection drain 1 0.75 in. A376 TP316 < 1 ft. B-P 5379-685, Valve CVC-300G remains closed to avoid valve and blind flange SMLS Sch. 160 Sheet 1 pressurizing downstream pipe piece and flange RCP "C" seal leakoff vent valve 1 0.75 in. A376 TP316 _ 1 ft. B-P 5379-685, Valve CVC-300J remains closed to avoid and blind flange SMLS Sch. 160 Sheet 1 pressurizing downstream pipe piece and flange RCP "C" seal water bypass 1 0.75 in. A376 TP316 1 ft. B-P 5379-685, Valve CVC-307C remains closed to avoid drain valve and cap SMLS Sch. 160 Sheet 1 pressurizing downstream pipe piece and cap Auxiliary spray valve and 1 2 in. A376 TP316 500 ft. B-P 5379-685, Valve CVC-311 remains closed to avoid downstream piping SMLS Sch. 160 Sheet 1 pressurizing downstream piping to check valve CVC-313 CVCS letdown drain valve and 1 0.75 in. A376 TP316 < 1 ft. B-P 5379-685, Valve CVC-460H remains closed to avoid downstream cap SMLS Sch. 160 Sheet 1 pressurizing downstream pipe piece and cap CVCS letdown vent valve and 1 0.75 in. A376 TP316 < 1 ft. B-P 5379-685, Valve CVC-460G remains closed to avoid downstream cap SMLS Sch. 160 Sheet 1 pressurizing downstream pipe piece and cap CVCS letdown drain valve and 1 0.75 in. A376 TP316 < 1 ft. B-P 5379-685, Valve CVC-475 remains closed to avoid downstream cap SMLS Sch. 160 Sheet 1 pressurizing downstream pipe piece and cap Safety injection loop "1" cold 1 0.75 in. A376 TP316 _ 1 ft. B-P 5379-1082, Valve SI-875N remains closed to avoid leg injection vent valve and cap SMLS Sch. 160 Sheet 4 pressurizing downstream pipe piece and cap
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/02-0065 Page 9 of 10 Table 1 (Continued)
Relief Request Number RR-12 Affected Class 1 Pressure Retaining Components Affected Line or Component Code Pipe Pipe Sch. Approx. Examination Drawing Boundary Exception(s)
Class Dia. Length Category No.
Safety injection loop "2" cold 1 0.75 in. A376 TP316 < 1 ft. B-P 5379-1082, Valve SI-875P remains closed to avoid leg injection vent valve and cap SMLS Sch. 160 Sheet 4 pressurizing downstream pipe piece and cap Safety injection loop "3" cold 1 0.75 in. A376 TP316 < 1 ft. B-P 5379-1082, Valve SI-875T remains closed to avoid leg injection vent valve and cap SMLS Sch. 160 Sheet 4 pressurizing downstream pipe piece and cap Safety injection loop "1" cold 1 0.75 in. A376 TP316 _<1 ft. B-P 5379-1082, Check valve to remain closed to avoid leg injection check valve SMLS Sch. 160 Sheet 4 disassembly or other temporary configurations SI-875A and upstream piping required to achieve test pressures at upstream 8 in. A376 TP316 3 ft. piping and valves SI-873F, SI-850B, SI-876A, SMLS Sch. 120 SI-875H, SI-875D, and SI-875M l0in. A376 TP316 62 ft.
SMLS Sch. 140 Safety injection loop "2" cold 1 0.75 in. A376 TP316 < 1 ft. B-P 5379-1082, Check valve to remain closed to avoid leg injection check valve SMLS Sch. 160 Sheet 4 disassembly or other temporary configurations SI-875B and upstream piping required to achieve test pressures at upstream 8 in. A376 TP316 5 ft. piping and valves SI-875S, SI-873E, SI-876E, SMLS Sch. 120 SI-876B, SI-875J, SI-850D, and SI-875E 10 in. A376 TP316 52ft.
SMLS Sch. 140 Safety injection loop "3" cold 1 0.75 in. A376 TP316 _ 1 ft. B-P 5379-1082, Check valve to remain closed to avoid leg injection check valve SMLS Sch. 160 Sheet 4 disassembly or other temporary configurations SI-875C and upstream piping required to achieve test pressures at upstream 8 in. A376 TP316 8 ft. piping and valves SI-875R, SI-873D, SI-875L, SMLS Sch. 120 SI-850F, SI-876C, and SI-875F 10 in. A376 TP316 63 ft.
SMLS Sch. 140
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/02-0065 Page 10 of 10 Table 1 (Continued)
Relief Request Number RR-12 Affected Class 1 Pressure Retaining Components Affected Line or Component Code Pipe Pipe Sch. Approx. Examination Drawing Boundary Exception(s)
Class Dia. Length Category No.
Safety injection loop "2" hot leg 1 2 in. A376 TP316 92 ft. B-P 5379-1082, Check valve to remain closed to avoid injection check valve SI-874B SMLS Sch. 160 Sheet 4 disassembly or other temporary configurations and upstream piping required to achieve test pressures at upstream piping and valves SI-874C and SI-866B Safety injection loop "3" hot leg 1 2 in. A376 TP316 44 ft. B-P 5379-1082, Check valve to remain closed to avoid injection check valve SI-874A SMLS Sch. 160 Sheet 4 disassembly or other temporary configurations and upstream piping required to achieve test pressures at upstream piping and valves SI-874D and SI-866A Residual heat removal motor- 1 14 in. A376 TP316 42 ft. B-P 5379-1484, Valve RHR-750 to remain closed to avoid operated valve RHR-750 and SMLS Sch. 140 Sheet 1 pressuring downstream piping and valve RHR common suction piping 751, which would result in single valve isolation between hydrostatic test boundary and decay heat removal system