ML060130194

Inservice Test Pressure (Ispt) Program Update and Associated Relief Requests for Third Ten-Year Interval

ML060130194
Person / Time
Site:	Sequoyah
Issue date:	01/09/2006
From:	Pace P Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML060130194 (39)

Text

Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37384-2000 10 CFR 50.55a January 9, 2006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - INSERVICE TEST PRESSURE (ISPT)

PROGRAM UPDATE AND ASSOCIATED RELIEF REQUESTS FOR THIRD TEN-YEAR INTERVAL

Reference:

NRC letter to TVA dated April 27, 1998, "Evaluation of the Second 10-Year Interval Inspection Program Plan and Associated Requests for Relief for Sequoyah Nuclear Plant, Units 1 and 2 (TAC NOS. M94115 and M94116)"

The purpose of this letter is to provide for your review SQN's updated ISPT program and the associated request for relief (ISPT-01) for SQN's third 10-year inspection interval.

The request for relief is being submitted for staff review and approval in accordance with 10 CFR 50.55a(a)(3)(ii).

The ISPT program has been developed to the 2001 Edition through the 2003 Addenda of the American Society of Mechanical Engineers (ASME) Code,Section XI.

By the reference letter, NRC issued the Safety Evaluation Report for SQN's second 10-year inspection interval. The enclosed relief request for SQN's third 10-year interval is identical to the relief request (ISPT-03) previously approved for SQN's second interval.

AFa47 Printed on recycled paper

U.S. Nuclear Regulatory Commission Page 2 January 9, 2006 SQN's third 10-year inspection interval begins June 1, 2006.

TVA requests NRC review and approval of the enclosed relief request to support the June 1, 2006 start date.

Please direct questions concerning this issue to me at (423) 843-7170 or J. D. Smith at (423) 843-6672.

Sincerely, P. L. Pace Manager, Site Licensing and Industry Affairs Enclosure cc (Enclosure):

Mr. Douglas V. Pickett, Senior Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08G-9a One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739

ENCLOSURE TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 AND 2 INSERVICE PRESSURE TEST (ISPT) PROGRAM WITH ASSOCIATED RELIEF REQUEST (ISPT-01)

THIRD 10-YEAR INTERVAL

TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT TECHNICAL INSTRUCTION 0-TI-SPT-000-201.0 ASME SECTION Xi PRESSURE TESTING PROGRAM BASIS DOCUMENT Revision 0 QUALITY RELATED PREPARED BY: K. R. Wilson RESPONSIBLE ORGANIZATION: Component Enoineering APPROVED BY: G. S. Haliburton EFFECTIVE DATE: XXX VALIDATION DATE: XXX LEVEL OF USE: REFERENCE USE

REVISION, DESCRIPTION: NEW PROCEDURE

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 2 of 36 TABLE OF CONTENTS Section Title Page Table of Contents 2

1.0 INTRODUCTION

3 1.1 Purpose 3 1.2 Scope 3

2.0 REFERENCES

3.0 PRECAUTIONS AND LIMITATIONS 5 4.0 PREREQUISTE ACTIONS 5 5.0 ACCEPTANCE CRITERIA 6.0 PERFORMANCE 5 6.1 Definitions 5 6.2 Program Scope and Plan 6 6.3 Regulatory Requirements 7 6.4 Description 7 6.5 Pressure Test Requirements 7 6.6 Corrective Action 13 6.7 Instrument Requirements 14 6.8 Repair/Replacements 15 7.0 POST PERFORMANCE ACTIVITIES 16 8.0 RECORDS 16 APPENDIXES AND ATTACHMENTS APPENDIX A - REQUEST FOR RELIEF 17 APPENDIX B - PRESSURE TEST SCHEDULE 20

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING - Revision 0 PROGRAM BASIS DOCUMENT Page 3 of 36

1.0 INTRODUCTION

1.1 Purpose The rules for the inservice pressure testing for Nuclear Power Plant Components are contained in the ASME Boiler and Pressure Vessel Code, Section Xl, Division 1. Title 10 Part 50 paragraph 50.55a of the Code of Federal Regulations (10CFR50.55a) and Sequoyah technical specifications require that ASME Section XI be met throughout the service life of the nuclear power plant and updated at the beginning of each 10 year interval. This procedure provides the technical requirements for implementing the inservice pressure- testing program-for Sequoyah -

Nuclear Plant (SQN).

1.2 Scope The scope of this instruction applies to the ASME Section Xl Class 1, 2 and 3 boundaries as defined by the ASME Section Xl Color Coded Boundary Drawings.

2.0 REFERENCES

2.1 Performance References None 2.2 Developmental References A. 10CFR50.55a B. ASME Boiler and Pressure Vessel Code, Section Xl, Division 1, 2001 Edition and the 2003 Addenda C. Sequoyah Nuclear Plant Technical Specifications D. SQN UFSAR E. ANSI/ASME N45.2.6-1978, Qualification of Inspection Examination and Testing Personnel for Nuclear Power Plants.

F. TVA Calculation SQN-SQTP-001, ASME Section Xl Inservice Code Class Boundaries for the Second 10 Year Interval.

G. SPP-9.1, ASME Section Xl H. SPP-9.7, Corrosion Control Program

SQN ASME SECTION Xi Q-TI-SPT-000-201.0 UNIT 0, 1,2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 4 of 36

2.0 REFERENCES

(CONTINUED)

I. Sequoyah Nuclear Plant Design Criteria and Design Guides:

1. SQ-DC-V-3.0 Classification of Piping, Pumps, Valves and Vessels

2. SQ-DC-V-2.16 Single Failure Criteria

3. SQ-DC-V-3.2 Classification of HVAC Systems J. Regulatory Guide 1.147 K. TVA submittals to the NRC

-He.tSecond-Ten Year Program Update submitted 11/21/95-Rims S64951121800

2. RAI response submitted 5/9/96 RIMS S64960509800

3. RAI response submitted 3/4/97 RIMS S64970305800

3. RAI response submitted 8/28/97 RIMS S64970829801 M. NRC SER dated 4/27/1998, TAC No.'s M94115 and M94116 N. ASME Section Xl, 1998 Edition

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 5 of 36 3.0 PRECAUATIONS AND LIMITATIONS NONE 4.0 PREREQUISTE ACTIONS NONE 5.0 ACCEPTANCE CRITERIA

- ,-This procedure provides no-specific -acceptance-criteria§--The-procedures which implement system pressure tests will provide all acceptance criteria.

6.0 PERFORMANCE 6.1 Definitions A. Inspection Interval - Nominally 10 years of plant operation. The length of the inspection interval can be adjusted in accordance with paragraphs 2430(d), 2430(e), and IWA-2432.

B. Inspection Period - Approximately 1/3 of an inspection interval (nominally 3 to 4 years of plant operation).

C. Design Temperature and Pressure - The specified design temperature and pressure of a specific system, piping segment, or component.

Design temperature and pressure is specified on the corresponding system flow diagram.

D. Nominal Operating Temperature and Pressure - The pressure and temperature to which systems or component are exposed during normal plant operation. For standby systems nominal operating pressure and temperature are those conditions achieved during required performance testing of the system or component.

E. Buried Components - For the purpose of system pressure testing, a component is one buried beneath the ground or encased in concrete and, therefore, inaccessible for visual examination. Piping which penetrates a concrete wall through an annulus is considered inaccessible for direct visual examination per IWA-5244 and only the ends of the annulus need be examined for evidence of leakage.

F. Open Ended - Piping that permits free fluid discharge to the atmosphere, either inside or outside of the plant containment.

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0,1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 6 of 36 6.0 PERFORMANCE (CONTINUED) 6.2 Program Scope and Plan SCOPE The ASME Section Xl, IWX-2500-1 tables identify the components and test frequency requirements for periodic pressure testing. The applicable tables and examination categories in relation to code class are as follows:

-Class4 ..-T-ab~leWB-.20Q1  ;.........-CategorylB P--

Class 2 ... Table IWC-2500-1 . Category C-B, C-H Class 3... Table IWD-2500-1 . Category D-B Additionally, where applicable, pressure retaining components which have been repaired or replaced in accordance with the requirements of ASME Section Xl shall be pressure tested prior to resumption of service as required by IWA-4000.

Appendix B provides a pressure test schedule for the systems included within the ASME Section Xi boundaries. This schedule gives general information of the systems, the boundaries, and the tests required by inspection periods for the second interval. This schedule may be amended as needed as long as compliance with all the Code requirements for system pressure testing is obtained.

PLAN A. The ASME Section XI pressure test procedures and results shall be reviewed and approved by the Program Test Engineer.

B. The ASME Section XI pressure test records shall be maintained in accordance with Subsections IWA-1 400 and IWA-5300 and Article IWA-6000 of the 2001 Edition through the 2003 Addenda of ASME Section Xl.

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 7 of 36 6.0 PERFORMANCE (CONTINUED) 6.3 Regulatory Requirements 10CFR50.55a(g) requires the inservice inspection and pressure testing of ASME Code Class 1,2, and 3 components per the 2001 Edition through the 2003 Addenda of ASME Section Xl. ASME Section Xl Subsections IWA, IWB, IWC, and IWD identify those components and/or systems which shall be tested in accordance with Article IWA-5000.

Under the provisions of 10 CFR 50.55a, pressure testing will be performed in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable addenda. As required by 10 CFR 50.55a (b), the effective edition of Section Xl for the third ten year interval is the 2001 Edition through the 2003 Addenda of ASME Section XI, Division 1.

The pressure test program shall be conducted in accordance with Article IWX-5000 (where IWX refers to IWB, IWC, and IWD) of Section Xl of the ASME Boiler and Pressure Vessel Code (applicable edition and addenda) except when relief has been granted under the provisions of 10 CFR 50.55a and approved alternatives contained in code cases listed in the test program.

6.5 Pressure Test Requirements 6.5.1 Test Description The pressure retaining components within each system boundary shall be subject to system pressure tests, when required. While system conditions are stable and following the completion of any required hold times a visual examination, VT-2, shall be performed to detect any evidence of leakage.

1. Class 1 Systems - A System Leakage Test shall be conducted in accordance with IWB-5221. The system leakage test shall be conducted at a pressure not less than the pressure corresponding to 100% rated reactor power. The system test pressure and temperature shall be attained at a rate in accordance with the heat-up limitations specified for the system.

SQN ASME SECTION Xi Q-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 8 of 36 6.0 PERFORMANCE (CONTINUED)

2. Class 2 Systems - A System Leakage Test shall be conducted in accordance with IWC-5221. The system leakage test shall be conducted at the system pressure obtained while the system, or portion of the system, is in service performing its normal operating function or at the system pressure developed during a test conducted to verify system operability (e.g., to demonstrate system safety function or satisfy technical specification surveillance requirements).

3.- Class 3 Systems -A-System-Leakage-Test shall be conductedirrn-accordance with IWD-5220. The system leakage test shall be conducted at the system pressure obtained while the system, or portion of the system, is in service performing its normal operating function or, for standby systems, at the system pressure developed during a test conducted to verify system operability (e.g., to demonstrate system safety function or satisfy technical specification surveillance requirements).

6.5.2 Pressure and Temperature

1. System leakage tests and system hydrostatic tests shall be conducted at the pressure and temperature specified in IWB-5000, IWC-5000, and IWD-5000. The system hydrostatic test pressure shall not exceed the maximum allowable test pressure of any component within the system pressure test boundary.

2. When conducting a system leakage test described in IWA-5211 (a),

system pressure shall be verified by normal system instrumentation, test instrumentation, or through performance of the system operating or surveillance procedure.

3. The system test conditions shall be maintained essentially constant during the course of the visual examination, except as provided in IWA-5245.

4. When conducting system hydrostatic or pneumatic pressure tests described in IWA-5211 (b) and (c), the test instrumentation requirements of IWA-5260 shall be met.

5. When portions of a system are subject to system pressure tests associated with two different system functions, the visual examination need only be performed during the test conducted at the higher of the test pressures of the respective system function, except as permitted in IWA-5222.

SQN ASME SECTION Xi O-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 9 of 36 6.0 PERFORMANCE (CONTINUED)

6. A system hydrostatic test [IWA-5211 (b)] is acceptable in lieu of the system leakage test [IWA-5211 (a)].

7: The system test pressure and temperature. may be obtained by using any means that comply with the plant Technical Specifications.

6.5.3 Test Condition Holding Time

- - The hotding-timeafterpressurizatiorTtotest-onditions,<-before-thevisual examination commence, shall be as follows.

1. For a Class 1 system leakage test, no holding time is required after attaining test pressure.

2. For a Class 2 and Class 3 system leakage test for systems which are not required to operate during normal plant operation, a 10 minute holding time is required after obtaining test pressure.

3. For a Class 2 and Class 3 system leakage test for systems which operate during normal plant operation, the system shall have been in operation for at least four hours for insulated components or ten minutes for noninsulated components.

4. For system pressure tests required by IWA-4540, a ten minute holding time for noninsulated components or four hour holding time for insulated components is required after obtaining test pressure.

5. For system pneumatic tests, a ten minute holding time is required after obtaining test pressure.

SQN ASME SECTION XI O-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 10 of 36 6.0 PERFORMANCE (CONTINUED) 6.5.4 Test Pressurization Boundaries The following test pressurization and examination boundaries are applicable when performing those periodic tests identified in Table IWX-2500-1. The boundary limits are generally defined by the location of the safety class interface valves within the system.

1. Class I - The pressure retaining boundary during the Class I system

---.------- leakagItest-rshalt-rrespondo-to the reactor-coolant pressure boundary (RCPB), with all valves in the position required for normal reactor operation startup. The visual examination shall, however, extend to the entire RCPB and include all Class 1 pressure retaining components . The test boundary subject to pressurization during the system leakage test conducted at or near the end of each inspection interval shall extend to all Class 1 pressure retaining components within the Class 1 boundary.

2. Class 2 - The pressure retaining boundary includes only those portions of the system required to operate or support the safety function up to and including the first normally closed valve (including a safety or relief valve) or valve capable of automatic closure when the safety function is required. Components outside these boundaries (specified in IWC-5222(a)), and open ended discharge piping, are excluded from the pressure test requirements.

3. Class 3 - The pressure retaining boundary includes only those portions of the system required to operate or support the safety function up to and including the first normally closed valve (including a safety or relief valve) or valve capable of automatic closure when the safety function is required. Components outside these boundaries (specified in IWC-52221WD-5240(a) and open ended discharge piping, are excluded from the pressure test requirements.

The ASME Section Xl Class 1, 2, & 3 boundaries are defined by the Color Coded ISI drawings and calculation SQN-SQTP-001. Control of these drawings and this calculation is the responsibility of SQN Mechanical Engineering Design.

l

SQN ASME SECTION Xl 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 11 of 36 6.0 PERFORMANCE (CONTINUED) 6.5.5 Visual Examination

1. The VT-2 visual examination shall be conducted by examining the accessible external exposed surfaces of pressure retaining components for evidence of leakage.

2. For components who external surfaces are inaccessible for direct VT-2 visual examination, only the examination of the surrounding area (including-the-floor areas-orequipment-surfaces-tocated undemeath-'- --

the components) for evidence of leakage shall be required.

3. Components within rooms, vaults, etc., where access cannot be obtained, may be examined using remote visual equipment or installed leakage detections systems.

4. Essentially vertical surfaces need only be examined at the lowest elevation where leakage may be detected.

5. Discoloration or residue on surfaces shall be examined for evidence of boric acid accumulations from borated reactor coolant leakage.

6. The VT-2 visual examination shall be conducted in accordance with NDE instruction N-VT-4.

6.5.6 Insulated Components

1. For insulated components in systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolted connections for VT-2 visual examination. Insulation removal and VT-2 visual examination of insulated bolted connections may be deferred until the system is depressurized. When corrosion-resistant bolting material with a chromium content of at least 10%,

such as SA-564 Grade 630 H1 100, SA-453 Grade 660, SB-637 Type 718 or SB-637 Type 750, is used, it is permissible to perform the VT-2 visual examination without insulation removal. Insulation must be removed from 17-4 PH or 410 stainless steel studs or bolts aged at a temperature below 11000 F or having a Rockwell Method C hardness value above 30, and from A-286 stainless steel studs or bolts preloaded to 100,000 pounds per square inch or higher.

2. Essentially horizontal surfaces of insulation shall be examined at each insulation joint if accessible for direct VT-2 visual examination.

SQN ASME SECTION Xl I 0-TI-SPT-000-201.0 UNIT 0, 1, 2 . PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 12 of 36 6.0 PERFORMANCE (CONTINUED)

3. When examining insulated components, the examination of the surrounding area (including floor areas or equipment surfaces located underneath the components) for evidence of leakage, or other areas to which such leakage may be channeled, shall be required.

6.5.7 Components with Leakage Collection Systems

1. Where leakages from components are normally expected and

-- collected-tsuctrasvalve-stems-;pump-sealsorvessel-flangegaskets) the VT-2 visual examination shall be conducted by verifying that the leakage collection system is operative.

6.5.8 Buried Components

1. For buried components surrounded by an annulus, the VT-2 visual examination shall consist of an examination for evidence of leakage at each end of the annulus and at low point drains.

2. For buried components where a VT-2 visual examination cannot be performed, the examination requirement is satisified by the following.

The system pressure test for buried components that are isolable by means of valves shall consists 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 system engineer. The system pressure test for nonisolable buried components shall consist of a test to confirm that flow during operation is not impaired. Test personnel need not be qualified for VT-2 visual examination.

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 13 of 36 6.0 PERFORMANCE (CONTINUED) 6.6 Corrective Action The source of leakages detected during the performance of system pressure tests shall be determined, and evaluated by the Program Engineer for corrective action as follows:

1. Buried components with leakage losses in excess of limits acceptable for continued service shall be repaired or replaced.

2. If leakage occurs at a bolted connection, corrective action shall be initiated in accordance with the requirements of Relief Request ISPT-01.

3. Corrective measures shall be performed where the relevant condition can be corrected without a repair/replacement activity.

4. Repair/replacement of components required to correct relevant conditions shall be performed in accordance with IWA-4000.

5. When boric acid residue is detected on components, the leakage source and the areas of general corrosion shall be located.

Components with local areas of general corrosion that reduce the wall thickness by more than 10% shall be evaluated to determine whether the component may be acceptable for continued service, or whether repair/replacement is required. Additionally, all areas of boric acid residue shall also be documented per the plant boric acid control program.

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 14 of 36 6.0 PERFORMANCE (CONTINUED) 6.7 Instrument Requirements NOTE: The following instrument requirements are applicable ONLY when performing system hydrostatic tests.

Any pressure measuring instrument or sensor, analog or digital, including the pressure measuring instrument of the normal operating system instrumentation may be-used provided-the followingTequirementsaremet

1. Accuracy The pressure measuring instrument or sensor used shall provide results accurate to within 0.5% of full scale for analog gages and 0.5%

over the calibrated range for digital instruments.

2. Calibration All pressure measuring instruments shall be calibrated against a standard deadweight tester or calibrated master gage. The gages shall be calibrated before each test or.series of tests. A series of tests is a group of tests that use the same pressure measuring instruments and that are conducted within a period not exceeding 2 weeks.

3. Ranges Analog pressure gages shall have a graduated range of at least 1.5 times, but not more than 4 times the intended maximum test pressures. Digital pressure instruments shall be selected such that the intended maximum test pressure shall not exceed 70% of the calibrated range of the instrument.

4. Location The pressure measuring instrument or sensor shall be connected close to the component when testing an isolated component. When testing a group of components or a multi-component system the instrument or sensor shall be connected to any point in the pressure boundary such that the imposed pressure on any component, including static head, will not exceed 106% of the specified test pressure for the system even thought the specified test pressure may not be achieved at the highest elevations in the system.

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 15 of 36 6.0 PERFORMANCE (CONTINUED) 6.8 Repairs/Replacements

1. Unless exempted, repair/replacement activities performed by welding or brazing on a pressure-retaining boundary shall include a hydrostatic or system leakage test in accordance with IWA-5000, prior to, or as a part of, returning to the component to service. Only brazed joints and weld made in the course of a repair/replacement activity require pressurization and VT-2 visual examination during the test.

2. The following are exempt from any pressure test.

a. Cladding

b. Heat exchanger tube plugging and sleeving

c. Piping, pump, and valve welding or brazing that does not penetrate through the pressure boundary

d. Flange flange seating surface when less than half the flange axial thickness is removed and replaced

e. pressure vessel welding when the remaining wall thickness, after metal removal, is at least 90 percent of the minimum design wall thickness

f. components and connections one inch nominal pipe size and smaller

g. tube-to-tubesheet welds when such welds are made on the cladding

h. seal welds

i. welded or brazed joints between nonpressure-retaining items and the pressure-retaining portion of the components

j. valve discs or seats

3. Replacement components and appurtanances shall be pressure tested in accordance with the Construction Code selected for use with IWA-4221. Replacement component installed by mechanical joints shall also receive a system leakage test.

4. Brazed joints and welds in replacement parts and pipng subassemblies, fabricated by the Repair/Replaoement Oraniza r fabricated in accordance with the Construction Code wiihbut in hydrostatic pressure test, shall be tested as requied by lV'A4540(a).

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 16 of 36 7.0 POST PERFORMANCE ACTIONS NONE 8.0 RECORDS NONE

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0, 1,2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 17 of 36 APPENDIX A REQUEST FOR RELIEF In the event specific test requirements of 10CFR50.55a or ASME Section XI are impractical or present a hardship without a commensurate increase in plant safety, relief may be granted by the NRC. Additionally, requests for relief are included where, in the opinion of TVA, a proposed alternative test provides adequate assurance of pressure boundary integrity.

SQN ASME SECTION Xi O-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 18 of 36 REQUEST FOR RELIEF: ISPT-01

Subject:

Alternative Rules for Corrective Actions for Leakage Discovered at Bolted Connections Components: All pressure retaining bolting in Class 1, 2, and 3 pressure retaining bolted connections.

Code Requirements: If leakage occurs at a bolted connection, one of the bolts

-shall-- be -removed, VT-3 examined, and -evaluated-nn accordance with IWA-3100. The bolt selected shall be the one closest to the source of leakage. IWA-5250(a)(2), 2001 Edition through the 2003 Addenda of ASME Section Xl.

Basis for Relief: ASME Section Xl inservice pressure tests are, as a rule, performed with the system inservice. In particular, the Code Class 1 leakage tests are performed as the unit is returning to service following each refueling outage. The requirement to immediately remove bolting from a mechanical connection when evidence of leakage is detected can create a significant hardship on the plant which is not commensurate with the increase in the level of quality and safety that is provided. For systems that are aligned to normal plant operating configuration during testing, paragraph IWA-5250(a)(2) may require the system to be taken out of service and depressurized to permit removal of one of the bolts prior to any type of engineering analysis of the connection. An engineering evaluation of the leak and the affected mechanical connection may be able to determine that sufficient structural integrity exists in the connection and that removal of bolting for visual examination in compliance with paragraph IWA-5250(a)(2) can be deferred to the next unit outage without a reduction in component safety margin.

Therefore, pursuant to 10CFR50.55a(a)(3)(ii), it is recommended that relief be granted.

This request for relief is similar to relief approved for the second interval.

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 19 of 36 Alternative Test: When evidence of leakage is discovered at a bolted connection during a Section XI inservice pressure test, the connection will be evaluated for structural integrity using the following factors:

1. Size of the leak.

2. Duration of the leak.

3. Bolting and flange materials.

4. Visual evidence of corrosion with the connection

-- assembled. -- - -

5. Corrosiveness of the process fluid.

6. Experience with similar bolting material in similar environments.

7. Degradation of other components in the vicinity of the leakage.

When the engineering evaluation determines that the bolted connection possesses sufficient structural integrity for continued operation, removal of the bolt may be deferred to the next unit outage of sufficient duration to allow the system to be removed from service and depressurized. Should the engineering evaluation determined that sufficient structural integrity does not exist at the connection, provisions will be made to remove one bolt for visual examination (VT-1) in compliance with IWA-5250(a)(2).

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0,1,2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 20 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS .

FIRST SECOND THIRD PERIOD PERIOD PERIOD 1 47W801 -1 2 Main Steam system piping and components Leakage Leakage Leakage 47W803-2 described below (excluding S/Gs):

• From Steam Generator 1 to FCV-1-15, FCV-1-4 and FCV-1-147.

• From Steam Generator 2 to FCV-1 -11 and FCV-1-148.

• From Steam Generator 3 to FCV-1 -22 and FCV-1-149.

• From Steam Generator 4 to FCV-1-16, FCV 29 and FCV-1 -150.

1 47W803-2 2 and 3 Main Steam supply to Turbine Driven Auxiliary Feed Leakage Leakage Leakage 47W803-3 Water Pump terry turbine as described below:

• From FCV-1 -15 and FCV-1 -16 through TDAFW Pump A-S terry turbine to roof exhaust and steam traps at drain tank. ,

SQN ASME SECTION XI 0>,TI-SPT-000-201.0 UNIT 0, 1,2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 21 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD PERIOD PERIOD PERIOD 1 47W801-2 2 Steam Generator Blowdown system piping and Leakage Leakage Leakage 47W862-1 components described below:

• From Steam Generator 1to FCV-1-7 (including sample line).

• From Steam Generator 2 to FCV-1-14.

• From Steam Generator 3 to FCV-1 -25.

• From Steam Generator 4 to FCV-1 -32. .

3 47W803-1 2 Main Feed Water system piping and components Leakage Leakage Leakage 47W803-2 described below (boundary extends to non-isolated portions of Auxiliary Feedwater system):

• From Steam Generator 1 (including S/G shell) to 3-832,3-873 and FCV-3-33.

• From Steam Generator 2 (including S/G shell)to 3-922 and FCV-1 -14.

• From Steam Generator 3 (including S/G shell) to 3-921 and FCV-1-25.

• From Steam Generator 4 (including S/G shell) to FCV-1-32. -

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0, 1,2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 22 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS ,

FIRST SECOND THIRD

_ _ PERIOD PERIOD PERIOD 3 47W803-2 2 Auxiliary Feed Water system piping and Leakage Leakage Leakage components as described below:

• Normally isolated Class 2 portion of AFW to Steam Generator 2. From 3-831 and 3-872 to 3-922.

• Normally isolated Class 2 portion of AFW to Steam Generator 3. From 3-830 and 3-871 to l___

_ 3-921. __

3 47W803-2 3 Auxiliary Feed Water system piping and Leakage Leakage Leakage components as described below:

• From 3-805 through MDAFW Pump A-A to 3-831 and 3-832.

• From 3-806 through MDAFW Pump B-B to 3-830 and 3-833.

• From 3-810 through TDAFW Pump A-S to 3-871, 3-872, 3-873 and 3-874 .

SQN ASME SECTION XI 0-TI-SPT-000-201 .0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT -Page 23 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS  :::

FIRST SECOND THIRD PERIOD PERIOD PERIOD 26 47W850-10 2 Fire Protection system piping and components Exempt- Exempt- Exempt-as described below: IWA- IWA- IWA-

• Portion of system penetrating containment 511 0(c) 5110(c) 5110(c) from FCV-26-243 to 26-1296 and from FCV-26-240 to 26-1260 .

31 47W865-5 2 Reactor Building Instrument Room Chilled Exempt- Exempt- Exempt-Water system piping and components as IWA- IWA- IWA-described below: 5110(c) 5110(c) 5110(c)

• Portion of system penetrating containment from FCV-31 C-224 to FCV-31 C-225 and 31 C-734.

• Portion of system penetrating containment from FCV-31 C-222 to FCV-31 C-223 and 31C-752.

• Portion of system penetrating containment from FCV-31 C-231 to FCV-31 C-232 and 31 C-697.

• Portion of system penetrating containment from FCV-31 C-229 to FCV-31 C-230 and

_ _ _ _ __ __ __ _ _ _ _ __ _ 3 1 C-7 15 ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 24 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS ,

FIRST SECOND I THIRD PERIOD PERIOD PERIOD 31 47W865-8 3 Shutdown Board Rooms Chilled Water system Leakage Leakage Leakage piping and components as described below: is

• From Compression Tank and Air Separator through CW Pump A-A, Water Chiller Package A-A and Air Handling Units 1A-A and 2A-A to pump suction.

• From Compression Tank and Air Separator through CW Pump B-B, Water Chiller Package B-B and Air Handling Units 1B-B and 2B-B to pump suction. .

Demineralized Water system piping and Exem pt- Exempt- Exempt-components as described below: IWA- IWA- IWA-

• Portion of system penetrating containment 511 0(c) 511 0(c) 511 0(c) from 59-522 to 59-633. A .1. I

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 25 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD

.. PERIOD PERIOD PERIOD 61 47W814-2 2 Ice Condenser system piping and components Exempt- Exempt- Exempt-as described below: IWA-! IWA-51I 10(c) IWA-

• Portion of system penetrating containment 5110(c) 51 10(c) from FCV-61-191 to FCV-61-192 and 61-533.

• Portion of system penetrating containment from FCV-61-193 to FCV-61-194 and 61-680.

I; ii, i.

SQN ASME SECTION Xl 0-TI-SPT-000-201.0 UNIT 0,1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 26 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD

__-_PERIOD PERIOD PERIOD 62 47W809-1 2 Chemical and Volume Control system piping and Leakage Leakage Leakage 47W809-2 components as described below:

47W81 1-1

• Letdown line from FCV-62-70 through Regenerative Hx, Letdown Hx (TCV-61-79 and LCV-62-118 aligned to VCT) and VCT to charging pump suction header.

• Exces letdown from transition piece and RCP seal return line from RCP seals through Seal Water Hx to connection to charging pump suction header.

• Charging pump suction header to the first normally closed valve.

• From charging pumps suction header through Centrifugal Charging Pumps A-A and B-B (including miniflow line) to seal injection check valves62-560, 561, 562 and 563, charging check valves62-716 and 717, pressurizer spray isolation valve 62-84 and high head safety injection valves FCV-63-39 and FCV-63-40.

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 27 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD PERIOD PERIOD PERIOD 62 47W809-2 3 Chemical and Volume Control system piping and Leakage Leakage Leakage 47W809-5 components as described below:

• Boric Acid Tanks A, B and C through Boric Acid Transfer Pumps and Boric Acid Blender to FCV-62-138,62-929,62-935, 62-936 and FCV 144.

62 47W809-1 3 Chemical and Volume Control system piping and Leakage Leakage Leakage 47W809-2 components as described below:

47W809-3

• From TCV-62-79 through Mixed Bed 47W809-4 Demineralizers A and B and Cation Bed 47W81 1-1 Demineralizer to 62-1075 (in return line to 47W819-1 Reactor Coolant Filter).

• From LCV-62-118 (and various other inputs) through Holdup Tanks A and B, Holdup tank Recirculation Pump and Gas Stripper Pumps A, B and C to 62-926A.

I, i

i i,

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 28 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD PERIOD PERIOD PERIOD 63 47W81 1-1 2 Safety Injection system piping and components as Leakage Leakage Leakage described below:

• High head saftey injection line from FCV-63-39 and FCV-63-40 to RCS Class 1/2 boundary valve 62-581.

• From FCV-63-5, FCV-63-6 and FCV-63-7 and FCV-63-11 through Safety Injection Pumps A-A and B-B (including miniflow to FCV-63-3) to RCS Class 1/2 boundary valves63-543, 63-545,63-547, 63-549,63-553 and 63-555.

• Cold Leg Accumulators 1 through 4 to RCS Class 1/2 boundary valves63-622, 62-623,63-624 and 63-625.

• Low head safety injection lines (RHR) INSIDE containment including containment sump and RHR return lines.

63 47W81 1-1 2 Safety Injection system piping and components as Leakage Leakage Leakage 47W812-1 described below:

47W830-1

• Refueling Water Storage Tank and piping to first 47W855-1 normally closed valve (i.e., HCV-74-34) and CVCS, SIS, RHR, and CS pump suction isolation valves LCV-62-135, FCV-62-136, FCV-63-5, FCV-63-1, FCV-72-21 and FCV-72-22. _

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0,1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 29 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS .

FIRST SECOND THIRD

_ PERIOD PERIOD PERIOD 67 47W832-3 2 and 3 Essential Raw Cooling Water system piping and Leakage Leakage Leakage 47W845-1 components as described below (Class 2 only at 47W845-2 containment penetrations):

47W845-3

• ERCW Screen Wash Pumps A-A, B-B, C-B(

47W845-4 and D-A to associated traveling screens.

47W845-5

• ERCW Pumps J-A, K-A, Q-A and R-A through Train A supply header, associated heat 47W860-1 exchangers (except Containment Spray Hx),

coolers, Train A discharge header to FCV 364.

• ERCW Pumps L-B, M-B, N-B and P-B through Train B supply header, associated heat exchangers (except Containment Spray Hx),

coolers, Train B discharge header to FCV 365.

67 47W845-2 3 Essential Raw Cooling Water system piping and Leakage Leakage Leakage components as described below:

• Containment Spray Heat Exhangers A and B.

• Normally closed ERCW supply to MDAFW Pumps A-A (FCV-3-116A to FCV-3-116B) and B-B (FCV-3-126A to FCV-3-126B).,

• Normally closed ERCW supply to TDAFW Pump A-S (FCV-3-136A to FCV-3-136B and FCV-3-179A to FCV-3-179B).

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0,1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 30 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD PERIOD PERIOD PERIOD 68 47W813-1 1 Reactor Coolant system piping and Leakage: Leakage Leakage every 47W809-1 components as described below: every RFO every RFO and 47W810-1

• All Class 1 piping and components. RFO IWB-522(b) in 47W81 1-1 last RFO

. 47W859-2 .

70 47W859-4 2 Component Cooling system piping and Leakage. Leakage Leakage components as described below):

• From FCV-70-143 through Excess Letdown

__ _Hx to FCV-70-85.  :

SQN ASME SECTION Xi 0-TI-SPT-000-201.0 UNIT 0,1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 31 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD PERIOD PERIOD PERIOD 70 47W859-1 2 and 3 Component Cooling system piping and Leakage Leakage Leakage 47W859-2 components as described below (Class 2 only at 47W859-3 containment penetrations):

47W859-4

• CCS Pumps A-A and B-B through Train A supply header, associated heat exchangers (except Excess Letdown Hx), coolers, Surge Tannk, Thermal Barrier Booster Pumps and Train A return header to CCS pumps.

• CCS Pump C-S through Train B supply header, associated heat exchangers, coolers, Surge Tannk and Train B return header to CCS pumps.

70 47W859-1 3 Component Cooling system piping and Leakage Leakage Leakage components as described below:

• Piping between normally closed valve pairs on the CCS pump discharge header and CCS heat exchanger discharge header. __

SQN ASME SECTION Xl 0-TI-SPT-000-201.0 UNIT 0, 1,2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 32 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD PERIOD PERIOD PERIOD 72 47W812-1 2 Containment Spray system piping and Exempt - Exempt - Exempt -

components as described below: IWC-5222(b) IWC- IWC-

• Containment Spray ring headers from FCV- 5222(b) 5222(b) 72-39 and FCV-72-2 to spray nozzles and RHR Spray ring headers from FCV-72-41 and FCV-72-40 to spray nozzles.

72 47W812-1 2 Containment Spray system piping and Leakage Leakage Leakage components as described below:

• From FCV-72-22 and FCV-72-23 through CS Pump A-A and CS Heat Exchanger A-A l to FCV-72-39 and 72-502.

• From FCV-72-20 and FCV-72-21 through CS Pump B-B and CS Heat Exchanger B-B

. . to FCV-72-2 and 72-504. i 74 47W810-1 2 Residual Heat Removal system piping and Exempt Exempt - Exempt -

47W81 1-1 components as described below: IWC-5220 IWC-5220 IWC-5220

• Containment sump including piping and

-components to first isolation valve FCV i_ _72 and FCV-63-73.  ;

iI I

I i

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 33 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD L _ PERIOD PERIOD PERIOD 74 47W810-1 2 Residual Heat Removal system piping and Leakage Leakage Leakage 47W81 1-1 components as described below:

47W812-1

• From PCV-63-1, FCV-63-72, FCV-63-73, FCV-72-20, FCV-72-23 and FCV-74-21 through RHR Pump A-A and RHR Heat Exchanger A-A to HCV-74-34, FCV-74-28, FCV-72-40, FCV-63-8 hot leg injection line containment penetration and cold leg injection lines containment penetrations.

• From FCV-74-24 through RHR Pump B-B and RHR Heat Exchanger B-B to FCV-74-28, FCV-72-41 and FCV-63-1 1.

• Normally isolated piping in the heat exchanger bypass line from HCV-74-34 to HCV-74-36 and HCV-74-37.

• Normally isolated piping in the RHR letdown line from 74-530 and 74-531 to FCV-62-83.

SQN ASME SECTION Xl 0-,TI-SPT-000-201.0 UNIT 0, 1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 34 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD

PERIOD PERIOD PERIOD 77 47W809-7 2 Waste Disposal system piping and Exempt- Exempt- Exempt-47W830-1 components as described below

IWA-51 10(c) IWA-51 10(c) IWA-

• Portion of system penetrating 5110(c) containment from FCV-77-9 to FCV 10 and 84-512. .

77 47W851 -1 2 Floor and Equipment Drains system piping Exempt- Exempt- Exempt-and components as described below: IWA-51 10(c) IWA-51 10(c) IWA-

• Portion of system penetrating 5110(c) containment from FCV-77-127 to FCV-77-128.  ;

77 47W851-1 3 Floor and Equipment Drains system piping Unimpaired Unimpaired Unimpaired and components as described below: Flow Test Flow Test Flow Test

• From Elevation 693' drain through the

-Crane Wall.

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0,1, 2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 35 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS FIRST SECOND THIRD PERIOD PERIOD PERIOD 78 47W855-1 3 Spent Fuel Pool Cooling system piping and Leakage Leakage Leakage components as described below:

• From Spent Fuel Pool suction strainers through Spent Fuel Pit Pumps, Spent Fuel Pit Heat Exchangers and Demineralizer to Spent Fuel Pit discharge diffuser. .

78 47W855-1 2 Spent Fuel Pool Cooling system piping and Exempt- Exempt- Exempt-components as described below: IWA- IWA- IWA-

• Portion of system penetrating containment 5110(c) 5110(c) 5110(c) from 78-557 to 78-558.

• Portion of system penetrating containment

.__ _from 78-560 to 78-561. .

SQN ASME SECTION XI 0-TI-SPT-000-201.0 UNIT 0, 1,2 PRESSURE TESTING Revision 0 PROGRAM BASIS DOCUMENT Page 36 of 36 APPENDIX B PRESSURE TEST SCHEDULE SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TEST TEM CLASS .:

FIRST SECOND THIRD

. PERIOD PERIOD PERIOD 81 47W819-1 2 Primary Water system piping and components Exempt- Exempt- Exempt-as described below: IWA- IWA-51 10(c) IWA-

• Portion of system penetrating containment 511 0(c) 511 0(c) from FCV-81-12 to 81-502.

43 47W881-5 2 Containment Penetrations X-93 and X-103. Exempt- Exempt- Exempt-47W881-6 IWA- IWA-51 10(c) IWA-511 0(c) 511 0(c)