ML18052A172

Revises 840514 Request for Relief from Hydrostatic Test Pressure Requirements of ASME Code,Including Relief for Repair of Four Atmospheric Steam Dump Valves.Approval for Use of Code Case N-416 Also Requested.Fee Paid

ML18052A172
Person / Time
Site:	Palisades
Issue date:	11/26/1985
From:	JOHNSON B D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8512030238
Download: ML18052A172 (4)

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• consumers Power company General Offices: 1945 West Parnell Road, Jackson, Ml 49201 *.1517} 788-0550 November 26, 1985 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 ,,.

DOCKET 50-255 -LICENSE DPR-20 -.PALISADES PLANT -AMENDMENT TO MAY 14, 1984 HYDROTEST RELIEF REQUEST Consumers Power Company letter dated May 14, 1984, requested relief from the hydrostatic test pressure requirements of the ASME B&PV Code 1977 Edition through Summer 1978 .Addenda in accordance with Palisades Technical tion 4.3.6. This request was for the modification and repair of the auxiliary feedwater and main feedwater lines. When those repairs were being performed, four atmospheric dump valves were also removed, reworked and subsequently replaced.

The referenced request did not include the request for relief for the hydrostatic test pressure requirements for the repair of the four (4) . atmospheric steam dump valves. Consumers Power Company requests that the May 14, 1984 relief request be amended per Attachment I to include the four atmospheric dump valves. These atmospheric dump valves are not isolable from the secondary side of the steam generator for hydrostatic testing without system modifications.

Palisades Technical Specifications allow a total of eight hydrostatic tests to the secondary side of the steam generators in the projected 40-year life. As in the case of the auxiliary feedwater modification, it is requested that remaining hydrostatic tests be withheld for other contingencies and that the hydrostatic pressure test requirement for the full penetration welds be deferred until the next scheduled ten-year ISI hydrostatic pressure test. In lieu of a hydrostatic test, Code Case N-416 was followed which stipulates performing surf ace and volumetric examinations on the welds in question as well as an inservice leak test. In light of the frequent necessity for such relief requests, it is further requested that Code Case N-416, Attachment II, be approved for use at Palisades.

This Code Case is not currently contained in Regulatory Guide 1.147, Revision 3, titled Inservice Inspection Code Case Acceptability ASME Section XI, Division I. The use of this Code Case would preclude the need for specific requests of this nature in the future, while providing adequate alternate testing and a reasonable level of qualilty and OC1185-0009-NL02

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Nuclear Reactor Regulation Palisa,,des Plant Hydrotest Relief Request November 26, 1985 2 Since our records do not indicate that a fee was submitted with the May 14, 1984 request, a check in the amount of $150 is enclosed pursuant to 10CFR170.21.

Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector

-Palisades OC1185-0009-NL02

• ATTACHMENT I CONSUMERS POWER COMPANY PALISADES NUCLEAR PLANT SYSTEM PRESSURE TEST RELIEF REQUEST AMENDMENT TO THE MAY 14, 1984 RELIEF SUBMITTAL System Main Steam Atmospheric_Dump System Code Class 2 Requirement During the 1983/84 refueling outage the four eight-inch atmospheric dump valves were removed, reworked and subsequently replaced.

The replacement procedure consisted of full penetration welds. ASME B&PV Code Section XI, 77S78, IWA-5214 and IWC-5210(a)(2) notes that a hydrostatic pressure test is required, and IWC-522Z(a) indicates that pressure is 1.25 P SV Basis for Relief For the Palisades atmospheric steam dump valves, the welds are not isolable from the secondary side of the steam generators.

Palisades Technical fications permit eight (8) hydrostatic pressure tests at 1.25 P , or 1,250 psia, over the life of the steam generators.

One test was performed for the construction acceptance test and one is to be scheduled every ten years for the projected 40-year life. As in the case of the iary feedwater modification, it is requested that the remaining hydrostatic test requirement for the full penetration welds be deferred until the next scheduled ten-year ISI hydrostatic pressure test. Alternate Examinations Based upon the aforementioned considerations, CPCo has performed both surface and volumetric weld examinations and an inservice leak test in lieu of a hydrostatic leak test. Implementation The alternate examinations were performed in accordance with approved written procedures using qualified personnel.

IC1185-0009A-NL02

• ATTACHMENT I I . CASI N-416 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approw1I D1t1: D-ber 6, 11MW SH Numeric Index forexpi,.tion t1nd t1ny ret1ffirmt1tion dt1r.1. CueN-416 Alternative Rules for Hydrostatic Tnting of Repair or Replacement of Cius 2 Piping Section XI, Division 1 Inquiry: For Section XI, Division 1, repair or ment of Oass 2 piping that cannot be isolated by ing valves or that requires securing safety or relief valves from isolation, may the system hydrostatic test required by IW A-4400 (IWA-4210 in earlier Code editions) be ferred until the next regularly scheduled system static test (IWC-5000) for that system? Reply: It is the opinion of the Committee that the system . hydrostatic test required by IW A-4400 (IW A-4210 in earlier Code editions) for repair or replacement 821 of Class 2 p1pmg that cannot be isolated by existing valves or that requires securing safety or relief valves from isolation may be deferred until the next regularly scheduled system hydrostatic tests (IWC-5000), pro* vided both of the following conditions are met. (a) Prior to or immediately upon return to service, a visual examination (VT-2) for leakage shall be con* ducted during a system functional test or during a sys-. tern inservice test in the repaired or replaced portion of the piping system. ( b) The repair or replacement welds shall be amined in accordance with IW A-4000 and IW A-7000 using volumetric examination methods (IWA-2230) for full penetration welds or surface examination methods (IW A-2220) for partial penetration welds. SUPP. 7 AND B -NC