ML17332A608

Requests Approval to Use ASME Code Case N-498-1, Alternate Rules for 10-Yr Sys Hydrostatic Testing for Class 1,2 & 3 Sys

ML17332A608
Person / Time
Site:	Cook
Issue date:	02/27/1995
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:0969AE, AEP:NRC:969AE, NUDOCS 9503080325
Download: ML17332A608 (9)

Text

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(ACCELERATED RIDS PROCESSING REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)

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ACCESSXON NBR:9503080325 DOC.DATE: 95/02/27 NOTARIZED:

NO FACIL:50-315 Donald C.

Cook Nuclear Power Plant, Unit 1, Indiana M

50-316 Donald C.

Cook Nuclear Power Plant, Unit 2, Indiana M

AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.

Indiana Michigan Power Co.

(formerly Xndiana

& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Requests approval to use ASME Code Case N-498-1, "Alternate Rules for 10-Yr Sys Hydrostatic Testing for Class 1,2 3

Sys II DISTRXBUTXON CODE A047D COPXES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: Inservice/Testing/Relief from ASM Code GL-89-04 NOTES:

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indiana Michigan Power Company P.O. Box 16633 Columbus, OH 43216 FI February 27, 1995 AEP:NRC'0969AE Docket Nos.:

50-315 50-316 U. S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.

C.

20555 Gentlemen:

Donald C.

Cook Nuclear Plant Units 1 and 2

Request for Use of Code Case N-498-1

Reference:

Letter, T. R.

Quay (NRC) to N.

S.

Cams (Wolf Creek),

"Request for Approval of Code Case N-498-1 as an Alternative to the Required Hydrostatic Pressure

Test, Wolf Creek Nuclear Operating Corporation, Wolf Creek Generating Station (TAC NO.

M90051),"

dated February 3,

1995 Pursuant to the requirements of 10CFR50.55a(a)(3)(i),

we request approval to use ASME Section XI Code Case N-498-1, "Alternative Rules for 10-Year System Hydrostatic Testing for Class 1, 2, and 3

Systems" for both Unit 1

and Unit 2.

The rationale of and justification for this request are identical to those contained in a similar request approved for the Wolf Creek Nuclear Plant (see reference).

This is a cost beneficial licensing action which is estimated to represent a potential cost savings of $ 1 million per outage, as detailed in attachment l.

Code Case N-498-1 provides for an alternative to hydrostatic testing which willretain an acceptable level of quality and safety for Class 1, 2, and 3 systems.

Specifically, it allows the use of a system leakage test in lieu of a hydrostatic test.

This code case was approved by the ASME Boiler and Pressure Vessel Code Committee on May 11, 1994, but is not included in the most recent listing of NRC approved code cases in Revision 11 of Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability--ASME Section XI Division l."

9503080325'50227 PDR ADOCK 05000315 P

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U. S. Nuclear Regulatory Commission Page 2

AEP:NRC'0969AE The system hydrostatic test is not a test of the structural integrity of the system.

Rather, it is an enhanced leakage detection test.

Leakage from Class 3

systems is normally the result of erosion/corrosion or joint seal/sealant age deterioration and is readily apparent to inspectors during a

system pressure test.

Industry experience indicates that, in most cases, leaks are found when the system is at normal operating pressure.

Thus, we consider that the alternate requirements proposed in Code Case N-498-1 constitute a reasonable, safe alternative to the existing hydrostatic testing requirements.

A copy of the approved code case is attachment 2.

The second ten-year ISI interval for both units will end on July 1, 1996, and Unit 1

systems are currently scheduled for hydrostatic testing of Class 3

systems during the upcoming refueling outage which begins in September 1995.

The use of this code case is estimated to reduce the outage critical path time by 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> by eliminating hydrostatic tests for the essential service water

system, the steam generators, and the diesel generators (starting air and cooling jacket water).

Thus, we request that approval of this request be granted prior to July 1, 1995, in order to apply the code case provisions during planning for the upcoming Unit 1 outage.

Sincerely, E,

E. Fitzpatrick Vice President eh Attachments CC:

A. A. Blind G. Charnoff J.

B. Martin NFEM Section Chief NRC Resident Inspector

- Bridgman J.

R. Padgett

ATTACHMENT 1 TO AEP:NRC:0969AE COST BENEFICIAL LICENSING ACTION USE OF CODE CASE N-498-1

ATTACHMENT 1 TO AEP:NRC:0969AE Page 1

Re lato Re uirement Unit 1

and Unit 2 Technical Specification 4.0.5 requires that inservice inspection of ASME Code Class 1, 2, and 3 components be conducted in accordance with Section XI of the ASME Code.

The code requires hydrostatic testing of Class 1,

2, and 3

components.

However, Code Case N-498, which has been incorporated into Regulatory Guide 1.147, allows the use of a system pressure test in lieu of a hydrostatic test for Class 1

and Class 2

components.

Code Case N-498-1, which has not yet been incorporated into Regulatory Guide 1.147, allows the use of a system pressure test in lieu of a hydrostatic test for Class 3 components.

Thus, periodic hydrostatic tests of Class 3

components are

required, unless NRC approval is obtained to adopt and apply code case N-498-1 conclusions'ffect of Re uirement The effect of the requirement is to require testing of the applicable system to pressures exceeding their design values in order to detect leaks.

ationa e

o Re ulator Chan e

Code Case N-498 was endorsed for use by the NRC and has been incorporated into Regulatory Guide 1.147.

Code Case N-498-1 extends the scope to ASME Class 3 components.

The code committee concluded that no additional benefit would be gained by conducting the existing Class 3 system hydrostatic tests versus performing leak tests at nominal operating pressure.

roximate Cost of Re uirement The present testing requirement requires the following hydrostatic tests.

Times cited are "time at pressure" and do not include system preparation or restoration times.

2.

Essential service water Two tests; ten hours per test Steam generators Four tests; ten hours per test

ATTACHMENT 1 TO AEP:NRC:0969AE Page 2

3.

Diesel generators (starting air and cooling water jackets)

Twelve tests; two hours per test (some tests can be conducted in parallel)

The effort is estimated to represent 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of outage critical time, which equates to approximately

$ 1 million avoidable cost per outage.

ATTACHMENT 2 TO AEP:NRC:0969AE CODE CASE N-498-1

CASES OFAShfE BOILERAND PRESSURE VESSEL CODE Approval Date: May 11, 1994 See Numerical Index for expiration and any reaffirmation dates.

CASE N-498-'1 Case N-498-1 Alternative Rules for IOrYear System Hydrostatic Testing for Class I, 2, and 3 SystemsSection XI, Division I Inquiryl What alternative rules may be used in lieu of those required by Section XI, Division 1, Table IWB-2500-1, Category B-P, Table IWC-2500-1, Cat-egory C-H, and Table IWD-2500-1, Categories D-A, D-B, and D-C, as applicable, for the 10-year system hydrostatic test?

Reply:

(a) It is the opinion of the Conunittee that as an alternative to the 10-year system hydrostatic test re-quired by Table IWB-2500-1, Category B-P, the fol-lowing rules shall be used.

(I) A system leakage test (IWB-5221) shall be conducted at or near the end of each inspection in-terval, prior to reactor startup.

(2) The boundary subject to test pressurization during the system leakage test shall extend to aH Class 1 pressure retaining components within the sys-tem boundary.

(3) Prior to performing the VT-2 visual exami-nation, the system shall bc pressurized to nominal operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for noninsulated systems.

The system shall be maintained at nominal operating pressure during performance of the VT-2 visual ex-amination.

(4) Test temperatures and pressures shall not exceed limiting conditions for the hydrostatic test curve as contained in the plant Tcchnical Specifica-tions.

(5) The VT-2 visual examination shall include atl components within thc boundary identified in (a)(2) above.

(6) Test instrumentation requirements ofIWA-5260 arc not applicable.

(b) It is the opinion of the Committee that, as an alternative to the 10-year system hydrostatic test re-quired by Table IWC-2500-1, Category C-H, the fol-lowing rules shall be used.

(I) A system pressure test shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection inter-val of Inspection Program B.

(2) The boundary subject to test pressurization during the system pressure test shall extend to aH Class 2 components included in those portions ofsys-tems required to operate or support the safety system function up to and including the first normally closed valve, including a safety or relief valve, or valve ca-pable of automatic closure when the safety function is required.

(3) Prior to performing the VT-2 visual exami-nation, the system shall be pressurized to nominal operating pressure for a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for in-sulated systems and 10 minutes for noninsulatcd sys-tems. The system shall be maintained at nominal op-crating pressure during performance of thc VT-2 visual exammation.

(4) The VT-2 visual examination shall include aH components within the boundary identified in (b)(2) above.

(5) Test instrumentation requirements of IWA-5260 are not applicable.

(c) It is the opinion of the Committee that, as an alternative to the 10-year system hydrostatic test re-quired by Table IWD-2500-1, Categories D-A, D-B, or D-C (D-B for the 1989 Edition with the 1991 and subsequent Addenda),

as applicable, the following rules shaH be used.

(I) Asystem pressure test shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection inter-val of Inspection Program B.

(2) Thc boundary subject to test pressurization during the system pressure test shall extend to all Class 3 components included in those portions ofsys-tems required to operate or support thc safety system function up to and including the first normally closed valve, including a safety or relief valve, or valve ca-pable of automatic closure when the safety function is required.

(3) Prior to performing the VT-2 visual exami-nation, the system shall be pressurized to nominal operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for noninsulated systems.

The system shall be maintained at nominal operating pressure during pcrformancc of thc VT-2 visual ex-amination.

(4) The VT-2 visual examination shall include aH components within thc boundary identified in (c)(2) above.

(5) Test instrumentation requirements of IWA-5260 arc not applicable.

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