View source for PY-CEI-NRR-2177, Forwards Response to 970515 RAI Re Request for Relief from ASME Code,Section XI & Inservice Exam Program.Two Relief Requests Have Been Revised to Incorporate Conditions

{{Adams
| number = ML20148S807
| issue date = 07/02/1997
| title = Forwards Response to 970515 RAI Re Request for Relief from ASME Code,Section XI & Inservice Exam Program.Two Relief Requests Have Been Revised to Incorporate Conditions
| author name = Myers L
| author affiliation = CENTERIOR ENERGY
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000440
| license number = 
| contact person = 
| document report number = PY-CEI-NRR-2177, TAC-M97694, NUDOCS 9707080319
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 9
| project = TAC:M97694
| stage = Request
}}

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CENTEREOR ENERGY                                                                                                              r Power Generation Group Perry Nuclear Power Plant      Mail Address:                       216-280-5915                   Lew W. Myers to Center Road                 P.O. Box 97                         FAX: 216-280-8029              Vice President           i Perry, Ohio 44081              Perry. OH 44081                                                                             '
July 2,1997                                                                                                         j PY-CEI/NRR-2177L                                                                                                   j l
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United States Nuclear Regulatory Commission                                                                         !
Document Control Desk                                                                                              <
Washington, D.C. 20555                                                                                              l Perry Nuclear Power Plant                                                                                          l Docket No. 50-440 Response to Request for Additional Information - Inservice Examination Program, Perry Nuclear Power Plant, Unit No.1 (TAC No. M97694)
Ladies and Gentlemen:
Requests for relief from requirements of the American Society of Mechanical Engineers (ASME)
Code, Section XI were submitted to the Nuclear Regulatory Commission (NRC) for the Perry Nuclear Power Piant, Unit 1, inservice Examination Program, in a {{letter dated|date=January 7, 1997|text=letter dated January 7,1997}} (PY-CEl/NRR-2125L), and supplemented by a {{letter dated|date=February 12, 1997|text=letter dated February 12,1997}} (PY-CEl/NRR-2136L). In a request for additional information dated May 15,1997, the NRC staff indicated that an initial review of the submittal had been performed, and additional information was needed to complete the review. Specifically, the NRC found the request to knplement Code Cases N-522 and N-546 acceptable provided the conditions stated in the initial review were followed, and                  ,
requested that infonnation reflecting incorporation of the conditions be submitted.                                 !
The two relief requests have been revised to incorporate the conditions. A description of the NRC                  ]
requests and responses to the conditions are provided in Attachment 1, and the revised relief requests are provided in Attachments 2 and 3. In addition, Relief Request PT-005 (Attachment 2) has been revised to reflect the addition of three penetrations to the Identification of Components table. The revised sections are designated by revision bars in the right margin.
If you have questions or require additional information, please contact Mr. Henry L. Hegrat, Manager - Regulatory Affairs, at (216) 280-5606.
Very truly yours, NY               y                                                                                          '
i 9707000319 970702*
KMN:sc                   PDR         ADOCK 05000440                                                         C   :I P                         Pm                                                    hO Attachments cc:       NRC Project Manager NRC Resident inspector NRC Region 111                                                                           -
Michael T. Anderson, INEL Research Center
(,'"' SOC      9'            Authorized Nuclear Inservice Inspector
     '     "'~
Ohio Department of Commerce

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l l-     .                                                                                                        j l    ,                                                                                 Attachment 1             j l                                                                                      PY-CEl/NRR-2177L         :
l PageIof3                 l i
1 BACKGROUND l        Requests for relief from requirements of the American Society of Mechanical Engineers (ASME)
Code, Section XI were submitted to the Nuclear Regulatory Commission (NRC) for the Perry Nuclear       l Power Plant (PNPP), Unit 1, inservice Examination Program (ISEP), in a {{letter dated|date=January 7, 1997|text=letter dated January 7,1997}} (PY-CEl/NRR-2125L), and supplemented by a {{letter dated|date=February 12, 1997|text=letter dated February 12,1997}} (PY-CEl/NRR-2136L).            l In a request for additional hformation dated May 15,1997, the NRC staffindicated that an initial       !
review of the submittal had been performed, and additional information was needed to complete the      ,
review. Specifically, the NRC has requested commitments to several specific conditions associated      I with Code Cases N-522 and N-546. A description of the NRC requests and responses to the conditions are provided below.
i RELIEF REOUEST PT-005                                                                                  j NRC Conditions for Relief Reauest PT-005 "In ReliefRequest PT-005, CEIrequested to implement the alternative to Code requirements contained in Code Case N-522, " Pressure Testing ofContainment Penetration Piping." The NRCfinds this alternative to Code regairements acceptable for use with thefollowing conditions (1) the test is conducted at thepeak calculated containmentpressure: and (2) the testprocedure provides criteriafor the detection andlocation ofthrough-wall leakages in CIVs andpipe segments between the CIVs. "
i Resnonse to NRC Conditions (n and (2)
These conditions have been incorporated into Relief Request PT-005, as described below. Appropriate procedures will be revised to incorporate these conditions.
In accordance with 10 CFR 50, Appendix J, Local Leak Rate Tests (LLRTs) of the               ,
penetrations identified in Relief Request PT-005 are conducted at a pressure of P., where P, is the peak calculated containment internal pressure.
For LLRT of the penetrations identified in Relief Request PT-005, whenever the testmg        ;
results indicate leakage, the test procedure will provide criteria for identification of the l source of the leakage, including provisions for detection and location of through-wall leakage in the containment isolation valves and pipe segments in between.
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Attach;nent 1 l                                                                                PY-CEl/NRR-2177L Page 2 of 3 RELIEF REOUEST PT-006 l               NRC Conditions for Relief Request PT-006 I
                "In ReliefRequest PT-006, CEIproposed to implement the alternatives to Code l
requirements contained in Code Case N-546, " Alternative Requirementsfor                !
Qualification of VT-2 VisualExamination Personnel." The NRC stafffinds this Code case acceptablefor use with thefollowing conditions:                                    \
(1) developproceduralguidelinesfor obtaining consistent, quality VT-2 visual examinations; I
(2) document and maintain records to verW the quahfication ofpersons selected to l
perform VT-2 visual examinations; and                                               l (3) implement independent review and evaluation ofleakage bypersons other than those thatperformedthe VT-2 visualexaminations."
PNPP Resnonse to Conditions (11 (21 and (3)
These conditions have been incorporated into Relief Request PT-006, as described below. Appropriate procedures will be revised to incorporate these conditions.
VT-2 examination personnel qualified in accordance with Code Case N-546 will perform examinations using procedures that provide for consistent, quality VT-2 examinations.
Training and qualification of VT-2 personnel will be documented and the records will be maintained for the life of the plant.
Procedures for the performance of VT-2 visual examinations will require that an independent review and evaluation of the VT-2 visual examination results be performed and documented on the examination records.

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I   ',                                                                                  Attachment 1 PY-CEI/NRR-2177L Page 3 of 3 i        .
t COMMITMENTS The following table identifies those actions which are considered to be regulatory commitments.
Any other actions discussed in this document represent intended or planned actions, are l          described for the NRC's information, and are not regulatory commitments. Please notify the l          Manager - Regulatory Affairs at the Perry Nuclear Power Plant of any questions regarding this i          document or any associated regulatory commitments.
Commitments                                              I These conditions have been incorporated into Relief Request PT-005, as described below.
Appropriate procedures will be revised to incorporate these conditions.
In accordance with 10 CFR 50, Appendix J, Local Leak Rate Tests (LLRTs) of the penetrations identified in Relief Request PT-005 are conducted at a pressure of Pa, where Pa is the peak calculated containment internal pressure.
For LLRT of the penetrations identified in Relief Request PT-005, whenever the testing         ;
results indicate leakage, the test procedure will provide criteria for identification of the   i source of the leakage, including provisions for detection and location of through-wall         i leakage in the containment isolation valves and pipe segments in between.                      ;
These conditions have been incorporated into Relief Request PT-006, as described below.
Appropriate procedures will be revised to incorporate these conditions.
VT-2 examination personnel qualified in accordance with Code Case N-546 will perform examinations using procedures that provide for consistent, quality VT-2 examinations.
Training and qualification of VT-2 personnel will be documented and the records will be maintained for the life of the plant.
Procedures for the performance of VT-2 visual examinations will require that an independent review and evaluation of the VT-2 visual examination results be performed and documented on the examination records.

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      ,                                                                          Attachment 2 PY-CEI/NRR-2177L Page1of3 Perry Nuclear Power Plant Unit 1 RELIEF REQUEST No. PT-005 l
t Code Case N-522
: 1. Identification of Comoonents Penetration No. Drawing No.        Associated ISI Pressure Test Instruction P204           D-302-871                    ISI-C11-T1201-2 P201           D-806-004                    1SI-D17-Tl 100-2 l
P317           D-806-007                    ISI-D17-T1101-2 P109           D-302-811                    ISI-E61-Tl 100-2 Pl19           D-302-811                    ISI-E61-Tl 101-2 P120           D-302-811                    ISI-E61-Tl 102-2                              ,
P317           D-302-811                    ISI-E61-Tl 103-2 P319           D-302-811                    ISI-E61-T1104-2 P424           D-302-672                    ISI-G33-Tl 100-2 P420           D-302-737                    ISI-G50-Tl 100-2 P417           D-302-739                    1SI-G61-T1100-2 P418           D-302-740                    ISI-G61-T1101-2 V313           D-912-604                    ISI-M14-T1100-2 V314           D-912-604                    ISI-M 14-Tl 101-2 P114           D-912-606                    ISI-M 17-Tl 100-2                             !
P208           D-912-606                    ISl-M 17-Tl 101-2 P428           D-912-606                    ISI-M17-Tl102 2 P436           D-912-606                    ISI-M 17-Tl 103-2 P108          D-302-102                    ISI-P11-Tl100-2 Pl11           D-302-102                    ISI-P11-Tl101-2 P309           D-302-713                    ISI-P22-Tl100-2 P310/P311          D-302-613                    ISI-P43-T1200-2                _
P404/P405          D-913 008                    ISI-P50-T1200-2                  _
P308          D-302-242                    1SI P51-T1200-2 P305/P306          D-302-244                    ISI-P52-T1200-2 P312          D-302-243                    ISI-P52-T1200-2 P406          D-914-003                    ISI-P54-Tl100-2 P210          D-914-005                    ISI-P54-T1101-2 l
P117          D-302-950                    ISI-P86-Tl100-2 P413          D-302-431                    ISI-P87-Tl 100-2
: 11. ASME Boiler & Pressure Vessel Code Section XI Reauirements The following requirements of the 1983 Edition through Summer 1983 Addenda of 1
Section XI apply:

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Attachment 2            '
PY-CEl/NRR-2177L        l Page 2 of 3             l
: l. IWA-5211, states "The pressure retaining components within each system boundary shall be subject to system pressure tests under which conditions visual examination VT-2 is performed in accordance with IWA-5240 to detect leakages."
: 2. IWC-5210(a) states, "The pressure retaining components within each system boundary shall be subjected to a system pressure test conducted during a system functional test, system inservice test, or a hydrostatic test, and visually examined by the method specified in bble IWC-2500-1, Examination Category C-H."
: 3. Table IWC-2500-1, Examination Category C-H, specifies a VT-2 examination once per inspection period for inservice or functional testing and once per inspection interval for hydrostatic testing.
III. ReliefRequested Code Case N-522 accepts the test requirements of 10 CFR 50, Appendix J as an alternative to the testing requirements of ASME Section XI, Table IWC-2500-1, Category C-H, for pressure testing piping that penetrates a containment vessel when the piping and isolation valves that are part of the containment system are Class 2 but the       ,
balance of the piping system is outside the scope of Section XI.                              !
IV. Basis for Relief Pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative provides an acceptable level of quality and safety.                                                                        l The proposed alternative reduces the amount of redundant testing required on the same systems by the imposition of both ASME Section XI and 10 CFR 50, Appendix J.
Cunently, imposition of the IWC-2500-1 test requirements results in additional testing as follows:
: 1. Water systems are flooded and pressurized through the associated penetration test tap and a VT-2 visual examination performed during the pressurization period.
: 2. Air and gas systems are tested in an identical manner to the 10 CFR 50, Appendix J method and a VT-2 visual examination is performed during the pressurization period.
For the penetrations listed in Section I above,10 CFR 50, Appendix J testing is performed by draining the test volume and pressurizing the test volume with air to a pressure of P , where P, is the peak calculated containment internal pressure. The rate of makeup flow is determined and compared to acceptance criteria based on allowable containment leak rates.
Thus, by being able to take credit for the ASME Section XI testing by using the 10 CFR 50, Appendix J testing, elimination of the redundant testing reduces the number of tests required on the same system.

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l l                                                                                   Attachment 2                            4 PY-CEI/NRR-2177L                        l l                                                                                   Page 3 of 3 Leakage from water systems would be indicated during the 10 CFR 50, Appendix J test more readily than the IWC-2500-1 test due to the lower density of the air test medium.
Based on this fact, use of the Appendix J test program for water systems is conservative                     ,
when compared to the ASME Section XI program.                                                                1 1
Leakage from air and other gas systems would be indicced by 10 CFR 50, Appendix J testing in a similar manner to an IWC-2500-1 test. Based on this fact, the two programs are essentially equivalent.                                                                                  j i
The frequency of testing will be in accordance with 10 CFR 50, Appendix J. The                               l 10 CFR 50, Appendix J testing is performed by a staffof Perry employees supplemented                        )
by contract personnel. All personnel involved in local leak rate testing (LLRT) at Perry                     ;
are qualified in accordance with the current Perry-specific LLRT training program.                           ;
Therefore, Appendix J testing is performed by personnel trained to recognize                                 i l
unacceptable leakage from a pressure boundary.
V. Alternate Examination In lieu of the requirements specified in IWA 5211 and IWC-5210, Perry will follow the                        ,
guidance of Code Case N-522 for pressure testing of safety class 2 containment                               i penetrations associated with non-safety class systems.
Testing required by 10 CFR 50, Appendix J may be used as an alternative to the rules in Table IWC-2500-1, Category C-H, for pressure testing piping that penetrates a containment vessel, when the piping and isolation valves that are part of the containment system are Class 2 but the balance of the piping system is outside the scope of                              ;
Section XI.                                                                                                  !
The testing will be conducted at a pressure of P., where P is the peak calculated containment internal pressure. Whenever the testing results indicate leakage, the test procedure will provide criteria for identification of the source of the leakage, including provisions for detection and location of through-wall leakage in the containment isolation valves and pipe segments in between.
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        ^                                                                                  Attachment 3 PY-CEl/F RR-2177L Page 1 of 2
                                                                                                              \
l Perry Nuclear Power Plant Unit 1
'                                             RELIEF REQUEST No. PT-006 Code Case N-546                                       l I. Identification of Components i
Class 1,2, and 3 systems subject to pressure testing.
II. ASME Boiler & Pressure Vessel Code Section XI Requirements l
Tables IWB-2500-1,IWC-2500-1 and IWD-2500-1 of the 1983 Edition through Summer             I 1983 Addenda of Section XI require the VT-2 examination method for pressure testing. l IWA-2300(c) requires that personnel performing the VT-2 visual examinations be             l qualified by the Owner or the Owner's agent in accordance with the comparable levels l
of competency as defined in ANSI N45.2.6-1973. Perry further utilizes Code Case            l N-448, " Qualification of VT-2 and VT-3 Visual Examination Personnel, Section XI, Division 1," which reflects later editions oflWA-2300 that require personnel perfonning visual examination to be qualified and certified to comparable levels of qualification as defined in SNT-TC-1 A and the Employers written practice.                                  j Ill. ReHef Reauested Pursuant to 10 CFR 50.55a(a)(3)(i), reliefis requested from requiring that the personnel performing the VT-2 examinations be aualified and certified to comparable levels of        j qualification as defined in SNT-TC-1 A.                                                    l I
IV. Basis for Relief The use of Code Case N-546 will eliminate the need to treat VT-2 examination               j personnel as NDE personnel. The Abstract of SNT-TC-1 A states, "This standard applies to personnel whose specific tasks orjobs require appropriate knowledge of the technical principals underlying nondestructive testing (NDT) methods for which they have responsibilities within the scope of VT-1 and VT-3 examination methods." VT-2 requires no special knowledge of technical principals underlying its performance. It is simply the straight forward examination for leakage. No special skills or technical training are required in order to observe water dripping from a component or bubbles       i forming on ajoint wetted with leak detection solution. As such, qualification in accordance with the provisions of the Code Case does not present any reduction in quality or safety. Ir fact, it will facilitate the qualification of those personnel most familiar with the walkdown of plant systems.
Additionally, there is a cost benefit of approximately $12,000 per operating cycle realized by eliminating the formal certification of Perry and contracted VT-2 examination personnel.

             .                                                                              Attachment 3 PY-CEI/NRR-2177L Page 2 0f 2 4
In summary, approval of this request would be in accordance with 10 CFR 50.55a(a)(3)(i), as compliance with Code Case N-546 will provide an essentially equivalent alternative to the IWA-2300 requirements. It would also provide relief from l
                                                                                                                 ~
the administrative and financial burdens of certification, which do not provide any compensating increase in the level of quality or safety.
V. Alternate Examination CEI proposes to perform VT-2 examinations utilizing personnel qualified in accordance    {
with the provisions of Code Case N-546 in lieu of personnel who are qualified and
,                       certified to comparable levels of qualification as defined in SNT-TC-1 A. The qualification provisions specified in Code Case N-546 are as follows:                    '
(1) Personnel must have at least 40 hours of plant walkdown experience, such as that gained by licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel.
(2) Personnel must receive at least 4 hours of training on Section XI requirements and   i plant specific procedures for VT-2 examination.
i (3) Personnel must meet the vision test requirements ofIWA-2321,1995 Edition.
Training and qualification of VT-2 personnel will be documented and the records will be maintained.
Additionally, to provide for consistent, quality VT-2 visual examinations, the examinations will be performed using standard procedures. An independent review and evaluation of the VT-2 visual examination results will be performed and documented on the examination records.
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