ML17332A608
| 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
PRIORITY (ACCELERATED RIDS PROCESSING 1
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)
ACCESSXON NBR:9503080325 DOC.DATE: 95/02/27 NOTARIZED: NO DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH. NAME AUTHOR AFFILIATION FITZPATRICK,E. Indiana Michigan Power Co. (formerly Xndiana & Michigan Ele P 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 C
DISTRXBUTXON CODE A047D COPXES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: Inservice/Testing/Relief from ASM Code GL-89-04 NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 1 PD3-1 PD 1 1 HICKMAN,J 1 1 INTERNAL: AEOD/SPD/RAB 1 1 E-CENTER= 1 1 NRR/DE/EMCB 1 1 NRR/DE/EMEB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 RES/DSIR/EIB 1 1 EXTERNAL: LXTCO BROWN, B 1 1 LITCO RANSOME i C 1 1 NOAC 1 1 NRC PDR 1 1 D
0 C
u N
NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE iVASTE! CONTACTTHE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 504-2083 ) TO ELI XIINATE YOUR NAME FROif DISTRIBUTION LISTS FOR DOCUMENTS YOU DON "I'L'ED!
TOTAL NUMBER OF COPXES REQUIRED: LTTR 14 ENCL 13
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 will retain 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 PDR
U. S. Nuclear Regulatory Commission AEP:NRC'0969AE Page 2 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.
Essential service water Two tests; ten hours per test
- 2. 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
CASE N-498-'1 CASES OFAShfE BOILER AND PRESSURE VESSEL CODE Approval Date: May 11, 1994 See Numerical Index for expiration and any reaffirmation dates.
Case N-498-1 (2) The boundary subject to test pressurization Alternative Rules for IOrYear System Hydrostatic during the system pressure test shall extend to aH Testing for Class I, 2, and 3 Systems Class 2 components included in those portions of sys-Section XI, Division I tems required to operate or support the safety system function up to and including the first normally closed Inquiryl What alternative rules may be used in lieu valve, including a safety or relief valve, or valve ca-of those required by Section XI, Division 1, Table pable of automatic closure when the safety function IWB-2500-1, Category B-P, Table IWC-2500-1, Cat- is required.
egory C-H, and Table IWD-2500-1, Categories D-A, (3) Prior to performing the VT-2 visual exami-D-B, and D-C, as applicable, for the 10-year system nation, the system shall be pressurized to nominal hydrostatic test? 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 Reply: visual exammation.
(a) It is the opinion of the Conunittee that as an (4) The VT-2 visual examination shall include alternative to the 10-year system hydrostatic test re- aH components within the boundary identified in quired by Table IWB-2500-1, Category B-P, the fol- (b)(2) above.
lowing rules shall be used. (5) Test instrumentation requirements of IWA-(I) A system leakage test (IWB-5221) shall be 5260 are not applicable.
conducted at or near the end of each inspection in- (c) It is the opinion of the Committee that, as an terval, prior to reactor startup. alternative to the 10-year system hydrostatic test re-(2) The boundary subject to test pressurization quired by Table IWD-2500-1, Categories D-A, D-B, during the system leakage test shall extend to aH or D-C (D-B for the 1989 Edition with the 1991 and Class 1 pressure retaining components within the sys- subsequent Addenda), as applicable, the following tem boundary. rules shaH be used.
(3) Prior to performing the VT-2 visual exami- (I) A system pressure test shall be conducted at nation, the system shall bc pressurized to nominal or near the end of each inspection interval or during 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 the same inspection period of each inspection inter-systems and 10 minutes for noninsulated systems. val of Inspection Program B.
The system shall be maintained at nominal operating (2) Thc boundary subject to test pressurization pressure during performance of the VT-2 visual ex- during the system pressure test shall extend to all amination. Class 3 components included in those portions of sys-(4) Test temperatures and pressures shall not tems required to operate or support thc safety system exceed limiting conditions for the hydrostatic test function up to and including the first normally closed curve as contained in the plant Tcchnical Specifica- valve, including a safety or relief valve, or valve ca-tions. pable of automatic closure when the safety function (5) The VT-2 visual examination shall include is required.
atl components within thc boundary identified in (3) Prior to performing the VT-2 visual exami-(a)(2) above. nation, the system shall be pressurized to nominal (6) Test instrumentation requirements of IWA- 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 5260 arc not applicable. systems and 10 minutes for noninsulated systems.
(b) It is the opinion of the Committee that, as an The system shall be maintained at nominal operating alternative to the 10-year system hydrostatic test re- pressure during pcrformancc of thc VT-2 visual ex-quired by Table IWC-2500-1, Category C-H, the fol- amination.
lowing rules shall be used. (4) The VT-2 visual examination shall include (I) A system pressure test shall be conducted at aH components within thc boundary identified in or near the end of each inspection interval or during (c)(2) above.
the same inspection period of each inspection inter- (5) Test instrumentation requirements of IWA-val of Inspection Program B. 5260 arc not applicable.
SUPP. 9 NC
g lt h' ~