View source for NOC-AE-08002308, Request for Relief from ASME Code Case N-498-4, Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2 and 3 Systems, Section XI, Division 1 (RR-ENG-2-51)

{{Adams
| number = ML081620109
| issue date = 06/02/2008
| title = Request for Relief from ASME Code Case N-498-4, Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2 and 3 Systems, Section XI, Division 1 (RR-ENG-2-51)
| author name = Jenewein B
| author affiliation = South Texas Project Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000498, 05000499
| license number = 
| contact person = 
| case reference number = NOC-AE-08002308, RG-1.147
| document type = Letter type:NOC
| page count = 6
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Nuclear Operating Company South Texas Proec Electric Genemtmn$ Station P0. Box 28,9 wdsworth, Teixas77483                           ,%AAA-June 2, 2008 NOC-AE-08002308 File No.: G25 10CFR50.55a U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2746 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, 50-499 Request for Relief from ASME Code Case N-498-4, "Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1,2 and 3 Systems, Section XI, Division 1" (RR-ENG-2-51).
In accordance with the provisions of 10 CFR 50.55a(a)(3)(ii), STP Nuclear Operating Company (STPNOC) submits this request for relief from the requirements of ASME Section XI Code Case N-498-4. ASME Code Case N-498-4 is listed in Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability ASME Section XI Division 1 ," Revision 15, as approved for use. This code case requires that the boundary .subject to test pressurization during system pressure testing extend to all Class 1 pressure-retaining components within the system boundary. However, compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Approval of this relief request will exempt Class 1 components from being tested at full Reactor Coolant System pressure if they are normally isolated from full Reactor Coolant System pressure.
STPNOC requests permission to implement the system leakage test modified as described above during the current 10-year inservice inspection interval for Unit 1 and Unit 2. The interval ends September 25, 2010, for Unit 1, and October 19, 2010, for Unit 2. Approval is requested by December 31, 2008, to support completion of the inspection prior to the end of the interval.
There are no commitments included with this request.
If there are any questions, please contact either Mr. P. L. Walker at (512) 972-8392 or me at (512) 972-7431.
adnJenewein d~ana ler, st* g/Programs .Engineering PLW

==Attachment:==
Request for Relief from ASME Code Case N-498-4, "Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2 and 3 Systems, Section XI, Division 1" (RR-ENG-2-51)
A04 7 STI: 32316810

NOC-AE-08002308 Page 2 of 2 cc:
(paper copy)                              (electronic copy)
Regional Administrator, Region IV         Thad Hill U. S. Nuclear Regulatory Commission       Catherine Callaway 611 East Lamar Blvd, Suite 400            Jim von Suskil Arlington, Texas 76011-4125               NRG South Texas LP Mohan C. Thadani                          A. H. Gutterman, Esquire Senior Project Manager                    Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission One White Flint North (MS 7 D1)           Mohan C. Thadani 11555 Rockville Pike                      U. S. Nuclear Regulatory Commission Rockville, MD 20852 Richard A. Ratliff                        J. J. Nesrsta Bureau of Radiation Control               R. K. Temple Texas Department of State Health Services K. M. Polio 1100 West 49th Street-                    E. Alarcon Austin, TX 78756-3189                     City Public Service C. M. Canady                              C. Kirksey City of Austin                            City of Austin Electric Utility Department 721 Barton Springs Road                   Jon C. Wood Austin, TX 78704                          Matthews & Branscomb Senior Resident Inspector.
U. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483

Attachment NOC-AE-08002308 Page 1 of 2 SOUTH TEXAS PROJECT UNITS 1 AND 2 Request for Relief from ASME Code Case N-498-4, "Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2 and 3 Systems, Section XI, Division 1" (RR-ENG-2-51)
: 1. ASME Code Components Affected The ASME Class 1 components (ASME Section Xl Table IWB-2500-1, Examination Category B-P) included in this request are listed in the addendum.

===2. Applicable Code Edition and Addenda===
The South Texas Project Inservice Inspection program for the second ten-year interval complies with the requirements of ASME Section XI, 1989 Edition.
: 3. Applicable Code Requirements ASME Code Case N-498-4, "Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2 and 3 Systems, Section XI, Division 1," allows use of a system leakage test (IWB-5221) in lieu of the hydrostatic test required by Table IWB-2500-1, Examination Category B-P. To apply the system pressure test, N-498-4 requires that the test extend to all Class 1 pressure-retaining components within the system boundary.
: 4. Basis for Relief from Code Requirements Pursuant to 10 CFR '50.55a(3)(ii), STP Nuclear Operating Company (STPNOC) requests relief from applying a system leakage test to Class 1 components at full Reactor Coolant System pressure for those components normally isolated from Reactor Coolant System (RCS) pressure.
STPNOC has concluded that compliance with Code requirements to apply RCS pressure to test components beyond the first isolation valve under normal operating conditions imposes significant hardships without a compensating increase in the level of quality and safety.
Hardships associated with testing performed in accordance with the referenced Code requirements are as follows:
* Special valve lineups required for these tests add unnecessary challenges to the system configuration. There are no test connections between isolation valves.
Consequently, a system pressure test would require opening the first manual isolation valve to test the second isolation valve.
   "   The affected components are located inside containment. Tests performed inside the radiologically restricted area increase the total exposure to plant personnel while modifying and restoring system lineups, as well as contamination of test equipment.
* Use of single valve isolation from systems with lower design pressures could result in over-pressurization of these systems and damage to permanent plant equipment.
* Use of single valve isolation is a significant personnel safety hazard.
* There are no test connections for testing the piping between check valves in the Residual Heat Removal system.

NOC-AE-08002308 Page 2 of 2
* Leakage past isolation valves to the RCS during special tests could affect the RCS boron concentration and complicate the task of maintaining homogeneous boron concentrations.
: 5. Justification for Granting Relief Pressurization of components above their normal operating temperature and pressure in order to detect leakage during the VT-2 visual examination is not necessary. Piping with two isolation valves is designed to operate with the first isolation valve closed and the second isolation valve utilized only for draining or venting. Piping between two isolation valves during normal operating pressure and temperature is normally pressurized, but at a lower pressure.
The temperatures and pressures present in Class 1 components during 100% reactor power are sufficient to qualify as a System Pressure Test alternative to the '&#xfd;10-year Hydrostatic Test to satisfy Code Case N-498-4. Normal operating temperature and pressure are used to detect leaks under the Alternative Rules for 10-year Hydrostatic, Pressure Testing. Code Case N-498-4 requires that the VT-2 visual examination extend to include the second isolation valve at the Class 1 boundary extremity. The pressure boundary integrity of these components is validated and documented using identical VT-2 visual examination requirements each refueling outage. The requested relief will apply VT-2 inspections of the Class 1 boundary beyond the first isolation valves at a stabilized pressure achieved based on seat leakage from the first isolation valve.
STPNOC performs other surveillance procedures (i.e., Local Leakage Rate Tests, Contaminated Leakage Rate Tests, Isolation Check Valve Leak Tests, and Inservice Leak Rate Tests) to monitor these components for leakage. Leakage is identified using normal operating temperature and pressure conditions. In addition to leakage testing, boric acid inspections performed during refueling outages will also identify leakage from these components. The system leakage, test as an alternative to the hydrostatic test of the components identified by this request is in addition to these surveillances.
Under this relief, the pressure-retaining boundary during the 10-year hydrostatic test shall correspond to the reactor coolant system boundary, with all valves in the normal
   *position required for' normal reactor startup.
: 6. Duration of Proposed Alternative STPNOC requests permission, to implement the system leakage test modified as described above for the tests to be performed in the current 10-year inservice inspection interval for Unit 1 and Unit 2. The interval ends September 25, 2010, for Unit 1, and October 19, 2010, for Unit 2.
: 7. Implementation Approval is requested by December 31, 2008, to support completion of the inspection in the current inspection interval.
                                                                                               /'

Addendum NOC-AE-08002308 Page 1 Of 2 SCOPE OF RELIEF REQUEST APPLICABILITY Piping and Associated Check Valves
* 2"CV1 (2)1211BB1 between CV0009 and LV3119                (RCS Auxiliary Spray)
* 4"CV1(2)118BB1 between XCV0001 and XCV0002                (RCS Normal Charging)
* 4"CV1 (2)1201BB1 between XCV0004 and XCV0005              (RCS Alternate Charging)
* 6"SI1(2)111BB1 between XSI0007A and 10"RH1(2)108BB1       (High Head SI)
* 6"SI1(2)211BB1 between XSI0007B and 10"RH1(2)208BB1       (High Head SI)
* 6"Sl1(2)308BB1 between XSI0007C and 10"RH1(2)308BB1       (High Head SI)
* 6"/8"SI1(2)108BB1 between XSI0009A and XSI001OA           (High Head SI)
* 6"/8"SI1(2)208BB1 between XSI0009B and XSI0010B           (High Head SI)
* 6"/8"Sl1(2)327BB1 between XSI0009C and XSI00100C           High Head SI)
* 12"SI1(2)125BB1 between XS10038A and XS10046A            (RCS Cold Leg Loop 1)
* 12"SI1(2)218BB1 between XS10038B and XS10046B            (RCS Cold Leg Loop 2)
* 12"SI1(2)315BB1 between XS10038C and XS10046C            (RCS Cold Leg Loop 3)
* 8"RH1(2)112BB1 between XRH0020A and 8"SI1(2)108BB1        (Residual Heat Removal)
* 8"RH1(2)212BB1 between XRH0020B and 8"Sl1(2)208BB1        (Residual Heat Removal)
* 8"RH1(2)315BB1 between XRHO02OC and 8"Sl1(2)327BB1        (Residual Heat Removal) 0  8"/10"RH1(2)108BB1 between XRH0032A and 12"SI1(2)125BB1   (Residual Heat Removal)
* 8"I10"RH1(2)208BB1 between XRH0032B and 12"SI1(2)218BB1   (Residual Heat Removal)
'    8"/10"RH1(2)308BB1 between XRH0032C and 12"SI1(2)315BB1 (Residual Heat Removal)
Piping and Associated Isolation Valves
* 1 "RC1 (2)048BB1 associated with HV3657A and HV3658A     (Head Vent)
* 1 "RC1 (2)049BB1 associated with HV3657B and HV3658B     (Head Vent)
* 1 "RC1 (2)048BB1 associated with (downstream of) RC01 32 (Head Vent)
  " 2"CV1 (2)1411BB1 associated with CV0083 and CV0082         (RCS Excess Letdown)
* 12"RH1 (2)1,01BB1, associated with XRH060A and XRH061 A  (RCS Hot Leg Loop 1)
* 12"RH1(2)201BB1 associated with XRH060B and XRH061B      (RCS Hot Leg Loop 2)
* 12"RH1(2)301BB1 associated with XRH060C and XRH061C      (RCS Hot Leg Loop 3)

NOC-AE-08002308 Page 2 of 2 Piping and Associated Manual Vent/Drain Valves 0  3/4"(1 ")CV1 (2)122BB1 associated with CV038A and CV0595A   (RCP Seal Injection)
* 3/4"(1 ")CV1 (2)124BB1 associated with CV038B and CV0595B   (RCP Seal Injection)
* 3/4"(1 ")CV1 (2)126BB1 associated with CV038C and CV0595C   (RCP Seal Injection)
* 3/4"(1 ")CV1 (2)128BB1 associated with CV038D and CV0595D   (RCP Seal Injection)
* 3/4"(1 ")RC1 (2)013BB1 associated with RC064A and RCO1 64   (RCS Loop 1)
* 3/4"(1 ")RC1 (2)01 OBB1 associated with RC064B and RC01 67, (RCS 'Loop 2)
* 3/4"(1")RC1 (2)006BB1 associated with RC064C and RC01 62   (RCS Loop 3).
* 3/4"(1 ")RC1 (2)214BB1 associated with RCO0123 and RCO0152 (RCS Loop 2)
* 3/4"(11')RC1(2)126BB1 associated with RC0128 and RC0146     (RCS Loop 1)
* 3/4"(1")RC1(2)114BB1 associated with RC0129 and RC0142      (RCS Loop 1) 9  3/4"(1 ")RC1 (2)122BB1 associated with RC0200               (RCS Loop 1)
* 1 "RC1 (2)326BB1 associated with SI01 68 and S10203        (RCS Hot Leg Loop 3)
* 1"RC1(2)327BB1 associated with S10170 and S10202           (RCS Hot Leg Loop 3)
* 1 "RC1 (2)003BB1 associated with RC01 03 and RC01 63       (RCS Loop 4)
* 2"RC1 (2)1211BB1 associated with RC057A and RC058A          (RCS Loop 1)
* 2"RC1 (2)220BB1 associated with RC057B and.RC058B           (RCS Loop 2)
* 2"RC1 (2)3211BB1 associated with RC057C and RC058C          (RCS Loop 3)
* 2"RC1 (2)418BB1 associated with RC057D and RC058D           (RCS Loop .4)
* 2-1/2"RC1 (2)003BB1 associated with RC0502 and RC0503       (RCS Loop 4)}}