ML20211A588

Safety Evaluation Supporting Evaluation of First 10-yr Interval ISI Program Plan Requests for Relief PT-004,PT-005 & PT-006 for Plant,Unit 1

ML20211A588
Person / Time
Site:	Perry
Issue date:	09/11/1997
From:	NRC (Affiliation Not Assigned)
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ML20211A562	List: ML20211A558 ML20211A588
References
NUDOCS 9709240308
Download: ML20211A588 (18)

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g* og\ UNITED STATES P

NUCLEAR REGULATORY COMMIS810N g, j* WASHINGTON D.C. 300eH001 SAFETY EVALUATION BY THE OFFICE Of NUCLEAR REACTOR REGULATJQN OF THE FIRST 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN REQUESTS FOR RELIEF PT-004. PT-005. AND PT-006 EDB THE CLEVELAND ELECTRIC ILLUMlNA2' uOMPANY ET AL. ,

PERRY NUCLEAR POWER PLANT. ' NIT NO.1 DOCKET NO. 50-440 1.0 INTh0 DUCTION The Technical Specifications for Perry Nuclear Power Plant (PNPP), Unit No.1, states that the inservice inspection of the American Society of Mechanical Engineers (ASME) Code Class 1,2, and 3 components shall be performed in accordance with Section XI of the ASME So#er endpressure Vesse/ Code (tha Code) and applicable addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(l). Section 50.55a(a)(3) of Title 10 of the Code o/Federe/ Aeputations states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (1) the proposed alternatives would provide an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, " Rules for Inservice inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10 year interval and subsegurnt intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by refe ence in 10 CFR 50.55alb),12 months prior to the start of the 120-mor.th interval, subject to the limitations and modifications listed therein. The applicable edition of Section XI of the ASME Code for PNPP, Unit No.1, first 10 year Inservice Inspection (ISI) interval is the 1983 edition through the summer 1983 addenda.

ENCLOSURE D 0

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2 Pursuant to 10 CFR 50.55alg)(5), if the licensee determines that confoimance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement. After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed. .

In a letter dated January 7,1997, Centerior Energy (licensee), submitted to the NRC its First 10 Year Inservice inspection interval Program Plan Requests for Relief PT 004, PT 005, and PT 006 for Perry Nuclear Power Plant, Unit No.1. The licensee also provided additional information in its letter dated July 7,1997.

2.0 EVALUATION The staff, with technical assistance from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL), has evaluated the information provided by the licenseo in support of its First 10 Year Inservice inspection Interval Program Plan Requests for Relief PT-004, PT 005, and PT 006 for Perry Nuclear Power Plant, Unit No.1. The licensee also provided edditional information in its letter dated July 7,1997. Based on the information submitted, the staff adopts the contractor's conclusions and recommendations presented in the attached Technical Letter Report (TLR).

Request for R', lief PT 004: The 10 Year Hydrostatic Test Requirements for Code Class 1, 2, as s Syst1ms are contained in Table IWB 2500-1, Category B E, Items B4.11,84,12, an1 B l.13, r id Category B P, items B15.11, B15.51, B15.61, and B15.71 (for Class 1 syst' ms); T able IWC 25001, Category C H, items C7.20, C7.40, C7.60, and C7.80 (for Class 2 sy.,tems); and Table IWD 25001, Categories D A, D B, and D-C, items D1.10, D2.10, and D3.10 (for Class 3 systems). The Code requires system hydrostatic testing onco per 10-year interval at or near the end of the interval.

Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed an alternative to perform the alternative examination delineated in Code Case N 4981 as an option to performing the Code required hydrostatic tests. Code Case N 4981 expands the scope of N 498 to include Class 3 systems. For Class 3 systems, in lieu of the 10-year system hydrostatic test required by ASME,Section XI (Division 1), Table IWD 25001.

For Class 1,2, and 3 pressure-retaining systems, the Code requires a system hydrostatic test to be perfoimed once per interval in accordance with IWA 5000. In lieu of the Code, the licensee proposes to implement Code Case N-4981, Altemative Rules for 10-Year System Hydrostatic Testing for Class 1,2, and 3 Systems, dated May 11,1994.

The system hydrostatic test stipulated in Section XIis not a test of the structuralintegrity of the system, but rather an enhanced leakage test. Hydrostatic testing only subjects the

3-piping components to a smallincrease in pressure, over the design pressure. Therefore, piping dead weight, thermal expansion, and seismic loads present far greater challenges to the structuralintegrity of the system. Consequently, the Section XI hydrostatic pressure test is primarily regarded as a means to enhance leak detection during the examination of components under pressure, rather than as a method to determine the structuralintegrity of the components. In addition, industry experience indicates that leaks are not being discovered as a result of hydrostatic test pressures causing a preexisting flaw to propagate through the wall. In most cases, leaks are being found when the system is at normal operating pressure. .

In lieu of 10 year hydrostatic pressure testing at or near the end of the 10 year interval, Code Case N-4981 requires a VT 2 visual examination at nominal operating pressure and temperature in conjunction with a system leakage test performed in accordance with paragraph IWA 5000 of the 1992 edition of Section XI. The requirements of Code Case N 4981 for Class 1 and 2 systems are the same as those of Code Case N 498, Alternative Rules for 10-Year System Hydrostatic Testing for Class 1 and 2 Systems, which was previously approved for general use on Class 1 and 2 systems in Regulatory Guide 1.147, Rev. 9. For Class 3 systems, N 4981 specifies requirements identical to those for Class 2 components.

Class 3 systems do not normally receive the amount and/or type of nondestructive examinations that Class 1 and 2 systems receive. While Class 1 and 2 system failures are relatively uncommon, Class 3 leaks occur more frequently and are caused by different failure mechanisms. Based on a review of Class 3 system failures requiring repair during the last 5 years', the most common causes of failures are erosion corrosion (EC),

microbiologically induced corrosion (MIC), and general corrosion. In general, licensees have implemented programs for the prevention, detection, and evaluation of EC and MIC.

Therefore, Class 3 systems receive inspections commensurate with their functions and expected failure mechanisms.

System hydrostatic testing entails considerable time, radiation dose, and dollar resources.

The safety assurance provided by the enhanced leakage detection gained from a slight increase in system pressure during a hydrostatic test may be offset or negated by the necessity to gag or remove Code safety and/or relief valves (placing the system, and thus the plant, in an off normal state), erect temporary supports in steam lines, and expend resources to set up testing with special equipment and gages. Therefore, performance of system hydrostatic testing represents a considerable burden. Giving consideration to the minimal amount of increased assurance provided by the increased pressure associated with a hydrostatic test versus the pressure for the systr.m leakage test, and the hardship associated with performing the hydrostatic test, the staff finds that compliance with the Section XI hydrostatic testing requirements results in burdship and/or unusual difficulty without a compensating increase in the level of quality and safety. Furthermore, Documented in Licensee Event Reports ano .no Nuclear Plant Reliability Data System databases.

4 performing the pressure tests in accordance with Code Case N 4981 will provide reasonable assurance of operational readiness. Therefore, the licensee's proposed alternative, to implement the pressure test requirements of Code Case N-4981 for Code Class 1,2, and 3, is authorized for PNPP, Unit No.1, pursuant to 10 CFR 50.55ala)(3)(li).

This alternative is authorized for the current interval or until such time as the code case is published in a future tevision of Regulatory Guide 1.147. At that time,if the licensee intends to continue to implement this code case, the licensee must follow all provisions in Code Case N 4981, including any limitations identified in Regulatory Guide 1.147.

Request for Relief PT 005: Table IWC 25001, Examination C6tegory C H, items C7.10, C7.30, C7.50, and C7.70, Pressure Retaining Components require a VT 2 visual examination during System Functional and System inservice Pressure Tests.

Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposes to use the alternatives contained in ASME Code Case N 622, Pressure Testing of Containment Penetration Piping, for the VT 2 visual examination during System Functional and System inservice Pressure Tests of the portions of the subject containment penetration pipe classified as Code Class 2. Code Case N 522 allows 10 CFR Part 50, Appenoix J tests, to be used as an alternative to the rules in Table IWC 25001, 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 plant is outside of the scope.

The Appendix J pressure testing provides periodic verification of the leak tight integrity of the primary reactor containment, and systems and components that penetrate containment. The Appendix J tests' frequency provides assurances that the containment pressure boundary is being maintained at an acceptable level while monitoring for deterioration of seals, valves, and piping. Appendix J requires that three Type A tests be performed at approximately equalintervals during the 10 year ISIinterval, with the third test done while shutdown for the 10 year plant ISI. Appendix J also requires Type B and C tests be performed during each refueling outage, but in no case at intervals greater than 2 years.

The attaching sections of these lines are outside the scope of Section XI. The following are the safety Class 2 containment penetrations for the subject relief:

P204 P201 P317 P109 P119 P120 P317 P319 P424 P420 P417 P418 V313 V314 P114 P208 P428 P436 P108 P111 P309 P310/P311 P404/P405 P308 P305/P306 P312 P406 P210 P117 P413 The licensee states that:

'In lieu of the requirements specified in IWA 5211 and lWC 5210, Perry will follow the guidance of Code Case N 672 for pressure testing of safety class 2 containment penetrations associated with non safety class systems, i

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5-Testing required by 10 CFR 50, Appendix J may be used as an alternative to the rules in Table IWC 25001, 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."

These segments of lines are safety related only because they function as part of the containment pressure boundary and are relied on for containment integrity. Therefore, it is logical to test the penritration piping portion of the associated systems to the containment test criteria found in 10 CFR 50.55a, Appendix J.

Appendix J pressure tests are local leak rate and integrated leak rate tests that verify the leak tight integrity of the primary reactor containment and of systems and components that penetrate containment. In addition, Appendix J test frequencies provide assurance that the containment pressure boundary is being maintained at en acceptable level while monitoring for deterioration of seats, valves, and piping.

The Class 2 containment isolation valves (CIVs) and connecting pipe segments must withstand the peak calculated containment internal pressure related to the maximum design containment pressure. The staff finda that the pressure-retalning integrity of the CIVs and connecting piping and their associated safety functions may be verified with an Appendix J, Type C test when it is conducted at the peak calculated containment pressure.

The seat between the connecting pipe segment and containment may be verified using an Appendix J, Type B test. Therefore, when the connecting pipe segment is subjected to either a Type B or C test, its safety function is verified by the Appendix J test.

The staff has reviewed the licensee's basis and alternatives. Considering that the licensee's Appendix J test procedures require that these leak tests be performed at the peak calculated containment design pressure and that they contain acceptance criteria for detection and location of through wall leakages in the pipe segments that are being tested, the staff concludes that the licensee's proposed alternative provides an acceptable level of quality and safety. Therefore, the licensee's proposed alternative to the Code-required pressure tests is authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use of alternatives contained in Code Case N 522 are authorized for the current interval or until such time as the code case is published in a future revision of Regulatory Guide 1.147. At that time,if the licensee intends to continue to implement this code case, the licensee must follow all the provisions in Code Case N 522, including any limitations identified in Regulatory Guide 1.147.

6-Request for Relief PT 006: Pursuant to 10 CFR 50.55ala)(3lp), the licensee proposed to use Code Case N 546 in lieu of the requirements of IWA 2300 for VT 2 visual examination personnel. The Code,Section XI, lWA 2300, requires that personnel performing VT 2 and VT 3 visual examinations be qualified in accordance whh comparable levels of competency as defined in ANSI N45.2.6. Examination personnel shall have natural or corrected near distance vision aculty, in at least one eye, equivalent to a Snellen fraction of 20/20. For f ar vision, personnel shall have natural or corrected f ar distance visual acuity of 20/30 or equivalent.

The licensee proposes to implement the alternatives contained in Code Case N 546 which requires that VT 2 visual examiners meet the following requirements:

a. Personnel must have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant walkdown experience, such as that gained by licensed and nonlicensed operators, localleak rate personnel, systern engineers, and inspection and nondestructive examination personnel;

b. Personnel must receive at least 4 Fours of training on Section XI requirements and plant specific procedures for VT 2 visual examiration; and

c. Personnel must meet the vision test requirements of IWA 2321,1995 edition.

The qualification requirements in Code Case N 546 are not significantly different fiom the qualifications required for VT 2 visual examiner certification. Licensed and nonficensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel typically have a sound working knowledge of plant components and piping layouts. This knowledge makes them acceptable candidates for performing VT 2 visual examinations. Because of the varied experience levels and potentially different interpretations of leakage, in the submittal dated July 2,1997, the licensee made the following commitments regarding Relief Request PT 006:

"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 en independent review and evaluation of the VT-2 visual examination results be performed and documented on the examination records."

Based on review of Code Case N 546 and the licensee's submittal, the staff concludes that the licensee's proposed alternative provides an acceptable level of quality and safety. The alternative involves implementation of formal procedures to obtain consistent VT 2 vess31 examination results even with varied experience levels and will document the qualifications, training, and visual acuity of persons selected to perform VT 2 visual l

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7 examinations. Therefore, the licensee's request to implement Code Case N 546 is authorized pursuant to 10 CFR 50.55ata)(3)(i). Use of Code Case N 546 is authorized for  ;

the first interval or until such time as the code case is published in a future revision of Regulatory Guide 1.147. From that time, if the licensee intends to continue to implement this code case, the licensee must follow all provisions in Code Case N 546, including any limitations identified in Regulatory Guide 1.147.

3.0 CONCLUSION

S The staff has completed its review of the information provided by the licensee and concluded that for Request for Relief PT 004, imposing the Code requirements on the licensee would result in a burden without a compensating increase in quality and safety.

Therefore, pursuant to 10 CFR 50.55alall3)(ii), the alternative contained in R34uest for Relief PT 004 is authorized.

For Relief Requests PT 005 and PT 006, the staff concluded that the licensee's proposed alternatives provide an acceptable level of quality and safety. Therefore, the licensee's proposed alternatives contained in Requests for Relief PT 005 and PT-006 are authorized pursuant to 10 CFR 50.55a(a)(3)(i).

Palnciple Contributor: Thomas McLellan Date: September 11,1997

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TECHNICAL LETTER REPORT ON THE FIRST 10 YEAR INsERYJCE INSPECTION INTERVAL REQUESTS FOR RELIEF PT 004, PT 005 AND PT 006 EQB CENTERIOR ENERGY PERRY. NUCLEAR POWER PLANT, UNIT 1 DOCKET NUMBER:. 50-440

1.0 INTRODUCTION

By letter dated January 7,1997, Centerior Energy, submitted Relief Requests PT 004, PT 005, and PT 006 for Perry Nuclear Power Plant (PNPP), Unit 1. In a letter dated February 12,1997, the licensee submitted revisions to PT 004 and PT 006. Following the review of these documents, additional information regarding PT 005 and PT 006 was requested by the Nuclear Regulatory Commission (NRC)in a letter dated May 15,1997. The licensee responded to the NRC request for additional information in a letter dated July 2,1997. The Idano National Engineering and Environtri ntal Laboratory (INEEL) staff has evaluated the licensee's submittals in the following section.

2.0 EVALUATION The first 10 year inservice inspection (ISI) interval for PNPP, Unit 1, began November 13,1987, and ends November 13,1997. The Code of record for the first 10 year intervalis the 1983 Edition through the Summer 1983 Addenda of Section XI of the American Society of Mechanical Engineers (ASME) Boller and Pressure Vessel Code. The information provided by the licensee in support of the requests for relief has been evaluated and the bases for disposition are documented below.

2.1 Reauest for Relief PT 004,10 Year Hydrostatic Test Reauirements for Code Class 1, 2. and 3 Systems Attachment 2

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2 Code Reauirement: The requirements for system hydrostatic testing are contained in Table IWB 2500-1, Category B-E, items B4.11, B4.12, and B4.13, and Category B-P, items B15.11, B15.51, B15.61, and B15.71 (for Class 1 systems); Table IWC-7.5001, Category C H, items C7.20, C7.40, C).60, and C7.80 (for Class 2 systemr); and Table IWD 2500-s, Categories D A, D-8, and D-C, items D1.10, D2.10, and D3.10 (for Class 3 t4ystems). The Code requires system hydrostatic testina once per 10-year interval at or near the end of the interval.

Licensee's Proposed Alternative: (as stated)

" Pursuant to 10 CFR 50.55a(a)(3)(ii), relief is requ,:sted from performing the Code required hydrostatic tests. . . .

"CEl proposes to perform the alternative examination delineated in Code Case N 4981 at an option to performing the Code required hydrostatic tests. Code Case N 4% 1 expands the scope of N-498 to include Class 3 systems. For Class 3 systems, in lieu of the 10-year system hydrostatic test required by ASME Section XI (Division 1) Table IWD 25001, Code Case N 4981 allows the alternative requirements summarized as follows:

"1. A system pressure test shall be conducted at or near the end of each inspection interval.

"2. The test boundary shall extend to all Class 3 components included in those portions of systems required to operate or support the safety function up to and including the first normally closed isolation valve (including a safety or relief valve) or valve capable of automatic closure when the safety function is required.

"3. A VT-2 visual examination shall be performed with the system maintained at nominal operating pressure. The system shall be pressurized 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, prior to pcrforming the VT 2 visual examination.

~4. The VT 2 visual examination shr.ilinclude all components within the boundary identified in (2) above.

• 5. The test instrument requirements of IWA-5260 are not applicable."

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3-Licensee's Basis for the Prooosed Alternative (as stated):

"ASME Section XI requires hydrostatic testing of Class,1,2, and 3 systems to be performed at the end of each 10 year inservice inspection interval. The use of Code Case N 498, ' Alternative Rules for 10-Year System Hydrostatic Testing for Class 1 and 2 Systems', was previously approved by the NRC in Regulatory Guide 1.147, Revision 11. The N 4981 alternative requirements for Code Class 1 and 2 are unchanged from N-498; Code Case N-4981 expands the scope of Code Case N 498 to include Class 3 systems.

"The Cleveland Electric illuminating Company (CEI) has determined that ,

hydrostatic tests represent a hardship with little benefit. Hardships are generally encountered with the performance of hydrostatic testing in accordance with the Code. Because hydrostatic test pressure is higher than the nominal operating pressure, hydrostatic pressure testing frequently reqtires significant effort to set up and perform. The preparation for the performance of the 10-year system hydrostatic tests involves co1siderable time and radiation dose with little or no compensating increase in the level of quality and safaty.

"The ASME Subcommittee Working Group on Pressure Testing concluded that no additional benefit is gained by conducting the existing system hydrostatic tests in place of the alternate requirements which require a system leakage test at the nominal operating pressure. The conclusion of the group was that Section X; hydrostatic testing rhes not verify integrity and could result in extended outages and increased costs.

" Industry experience has demonstrated that in-service leaks are not discovered as a result of hydrostatic pressures propagating an existing flaw throughwall. The experience indicates'that, in most cases, leaks are being found when the system is at normal operating pressure."

. Evaluation: For Class 1,2, and 3 pressure retaining systems, the Code requires a system hydrostatic test to be performed once per interval in accordance with IWA 5000, in lieu of the Code, the licensee proposes to implement Code Case N-4981, Altemative Rules for 10-Year System Hydrostatic Testing for Class 1, 2, and 3 Systems, dated May 11,1994.

The system hydrostatic test stipulated in Section XIis not a test of the structural l

Integrity of the system but rather an enhanced leakage test. Hydrostatic testing l only subjects the piping components to a smallincrease in pressure over the design pressure. Therefore, piping dead weight, thermal expansion, and seismic l loads present far greater challenges to the structural integrity of the system.

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4 Consequently, the Section XI hydrostatic pressure test is primarily regarded as a means to enhance leak detection during the examination of components under pressure, rather than as a method to determine the structuralintegrity of the components, in addition, industry experience Indicates that leaks are not being discovered as a result of hydrostatic test pressures causing a preexisting flaw to propagate through the wall, in most cases leaks are being found when the system is at normal operating pressure.

In lieu of 10 year hydrostatic pressuiu testing at or near the end of the 10 year interval, Code Case N-498-1 requires a VT-2 visual examination at nominal operating pressure and temperature in conjunction with a system leakage test performed in accordance with paragraph IWA 5000 of the 1992 Edition of Section XI. The requirements of Code Case N 4981 for Class 1 and 2 systems are the same as those of Code Case N 498, Attemative Rules for 10 Year System Hydrostatic Testing for Class 1 and 2 Systems, which was previousiy approved for general use on Class 1 and 2 systems in Regulatory Guide 1.147, Rev. 9. For Class 3 t ystems, N-4981 specifies requirements identical to those for Class 2 compone1ts.

Class 3 systems do not normally receive the amount and/or type of nondestructive examinations that Class 1 and 2 systems receive. While Class 1 and 2 system failures are relatively uncommon, Class 3 leaks occur more frequently and are caused by different failure mechanisms. Based on a review of Class 3 system f ailures requiring repair during the last 5 years', the most common causes of failures are erosion-corrosion (EC), microbiological!y-induced corrosion (MIC), and general corrosion, in general, licensees have implemented programs for the prevention, detection, and evaluation of EC and MIC; therefore, Class 3 systems receive inspections commensurate with their functions and expected failure mechanisms.

1 Documented in Licensee Event Reports and the Nuclear Plant Reliability Data System databases.

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- System hydrostatic test!ng entails considerable time, radiation dose, and dollar resources. The safety assurance provided by the enhanced leakage detection gained from a slight increase in system pressure during a hydrostatic test may be offset or negated by the necessity to gag or remove Code safety and/or relief

. valves (placing the system, and thus the plant, in an off normal state), erect '

temporary supports in steam lines, and expend resources to set up testing with.

t special equipment and gages. Therefore, performance of system hydrostatic -

testing represents a considerable burden. Giving consideration to the minimal amount of increased assurance provided by the increased pressure associated 5 with a hydrostatic test versus the pressure for the system leakage test, and the  ;

hardship associated with performing the hydrostatic test, the INEEL staff finds that compliance with the Section XI hydrostatic testing requirements results in hardship and/or unusual difficulty without a compensating increase in the level of quality and safety. Furthermore, performing the pressure tests in accordance with Code Case N 4981 will provide reasonable assurance of operational readiness. Therefore, it is recommended that the licensee's proposed alternative, k to implement the pressure test requirements of Code Case N 498-1 for Code Class 1,2, and 3, be authorized for Perry Nuclear Power Plant, Unit 1, pursuant

, to 10 CFR 50.55a(a)(3)(ii). This alternative should be authorized for the current interval or until such time as the Code Case is published in a future revisicn of Regulatory Guide 1.147. At that time, if the licensee intends to continue to implement this code case, the licensee must follow all provisions in Code Case N-4981, including any limitations identified in Regulatory Guide 1.147.

l 2.2 Reauest for Relief PT-OOS. Table IWC 2500-1. E'x amination Cateoorv C-H,

. Items C7.10. C7.30 C7.50,' and C7?/0,- Pressure-Retainino Comoonents Code Reauirement: Section XI, Table IWC 2500-1, Examination Category C-H,-

4 ltems C7.10, C7.30, C7.50, and C7.70 require a VT-2 visual examination during System Functional and System inservice Pressure Tests.

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.e.

Licensee's Proposed Alternative: Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposes to use the alternatives contained in ASME Code Case N 522 for the VT 2 visual examination during System Functional and System inservice Pressure Tests of the portions of the subject containment penetration pipe classified as Code Class 2. The attcching sections of these lines are outside the scope of Section XI. The following are the safety class 2 containment penetrations for the subject relief:

P204 P201 P317 P109 P119 P120 -

P317 P319 P424 P420 P417 P418 V313 V314 P114 P208 P428 P436 P108 P111 P309 P310/P311 P404/P405 P308 P305/P306 P312 P400 P210 P117 P413.

The licensee states that:

"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 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 25001, 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 coriducted at a pressure of P , where P, .s 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."

Licensee's Basis for the Procosed Alternative (as stated):

" Pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative provides an acceptable level of quality and safety. .

"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. Currently, imposition of the IWC-25001 test requirements results in additional testing as follows:

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"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.

" 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 AS:ME Section XI program.

" Leakage from air and other gas systems would be indicated 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.

"The frequency of testing will be in accordance with 10 CFR 50, Appendix J.

The 10 CFR 50, Appendix J testing is performed by a staff of Perry employees supplemented by contract personnel. All personnel involved in local leak rate testing (LLRT) at Perry are qualified in accordance with current Perry-specific LLRT training program. Therefore, Appendix J testing is performed by personnel trained to recognize unacceptable leakage from a pressure boundary."

Evaluation: The licensee proposes to implement the alternatives contained in Code Case N-522, Pressure Testing of Containment Penetration Piping, in lieu of the Code-required pressure tests for portions of the subject lines that are Class 2 at the containment penetration. These segments of lines are safety-related only because they function as part of the containment pressure boundary and are relied on for containment integrity. Therefore, it is logical to test the penetration l

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,4 m e - LL -

.v .

. 8-piping portion of the associated systems to the containment test criteria found in 10 CFR 50.55a, Appendix J.

Appendix J pressure tests are local leak rate and integrated laak rate tests that verify the leak tight integrity of the primary reactor contcinment and of systems and components that penetrate containment. In addition, Appendix J test frequencies provide assurance that the containment pressure boundary is being maintained at an acceptable level while monitoring for deterioration of seals, valves, and piping.

The Class 2 containment isolation valves (CIVs) and connecting pipe segments must withstand the peak calculated containment internal pressure related to the maximum design containment pressure. The INEEL finds that the pressure-retaining integrity of the CIVs and connecting piping and their associated safety functions may be verified with an Appendix J, Type C test when it is conducted at the peak calculated containment pressure. The seal between the connecting pipe segment and containment may be verified using an Appendix J, Type B test.

Therefore, when the connecting pipe segment is subjected to either a Type B or C test, its safety function is verified by the Appendix J test.

The INEEL staff has reviewed the licensee's basis and alternatives. Considering that the licensee's Appendix J test procedures require that these leak tests be performed at the peak calculated containment design pressure and that they contain acceptance criteria for detection and location of through-wall leakages in the pipe segments that are being tested, the INEEL staff believes that an acceptable level of quality and safety is provided. Therefore, it is recommended that the licensee's proposed alternative to the Code-required pressure tests be authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use of alternatives contained in Code Case N 522 should be authorized for the current interval or until such time as the Code Case is published in a future revision of Regulatory Guide 1.147. At that time, if the licensee intends to continue to implement this n- -

7- ,

Code Case, the licensee must follow all the provisions in Code Case N-522 ,

including any limitations identified in Regulatory Guide 1.147.

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- 2.3 Raouest for Relief PT-006. Use of Code Case N 546. Alternative

' Beaultements for Qualification of VT 2 Examination Personnel Section XI.

Divlslon 1 Code Raouirement: Section XI, IWA-2300, requires thct personnel perform'w VT 2 and VT-3 visual examinations be qualified in accordance with comparable levels of competency as defined in ANSI N45.2.6. Examination personnel shall i have natural or corrected near distance vision acuity, in at least one eye, equivalent to a Snellen fraction of 20/20. For for vision, personnel shall have

- na'tural or corrected far distance visual acuity of 20/30 or equivalent.  ;

Licensee's Proposed Alternative: Purst. ant to 10 CFR 50.55ala)(3)(i), the licensee proposed to use Code Case N 546 in lieu of the requirements of IWA-2300 for VT 2 visual examination personnel.

Licensee's Basis for the Proposed Alternative (as stated):

"The use of Code Case N 546 will eliminate the need to treat VT-2 examination 4 personnel as NDE personnel. The Abstract of SNT-TC-1 A states, 'This standard

- applies to personnel whose specific tasks or jobs require appropriate knowledge of the technical principals underlying nondestructive testing (NDT) methods for which they have responsibilities within the scope of VT-1 nd 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 forming on a joint 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, in fact, it will facilitate

. the qualification of those personnel most familiar with the walkdown of plant systems.

" Additionally, there is a cost be'nefit of approximately $12,000 per operating cycle realized by eliminating the formal certification of Perry and contracted VT-2 examination personnel.

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4 "In summary, approval of this request would be in accordance 10 CFR 50.55ala)(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 the administrative and financial burdens of certification, which do not provide any compensating increase in the level of quality and safety."

Evaluation: The Code requires that VT-2 visual examination personnel be qualified to comparable levels of competency as defined in ANSI N45.2.6. The Code also requires that the examination personnel be qualified for near and far ,

distance vision acuity. The licensee proposes to implement the alternatives contained in Code Case N 546 which requires that VT-2 visual examiners meet the following requirements:

Personnel must have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant walkdown experience, such as that gained by licensed and nonlicensed operators, localleak rate personnel, system engineers, and inspection and nondestructive examination personnel.

Personnel must receive at least four hours of training on Section XI requirements and plant specific procedures for VT-2 visual examination.

Personnel must meet the vision test requirements of IWA-2321,1995 Edition.

The qualification requirements in Code Case N 546 are not significantly different from the qualifications required for VT-2 visual examiner certification. Licensed and nonlicensed operators, localleak rate personnel, system engineers, and inspection and nondestructive examination personnel typically have a sound working knowledge of plant components and piping layouts. This knowledge makes them acceptable candidates for performing VT-2 visual examinations.

Because of the varied experience levels and potentially different interpretations of leakage, in the submittat dated July 2,1997, the licensee made the following commitments regarding Relief Request PT-OO6:

i 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 l records will be maintained for the life of the plant.

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I 11 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 documentwd on the examination records.

Based on review of Code Case N 546 and the licensee's submittal, the INEEL -

staff believes that the licensee's proposed alternative will provide an acceptable level of quality and safety. Therefore, it is recommended that the licensee's request to implement Code Case N 546 be authorized pursuant to 10 CFR 50.55a(s)(3)(l). Use of Code Case N 546 should be authorized until such *l time as the Code Case is published in a future revision of Regulatory Guide 1.147. From that time, if the licensee intends to continue to implement this Code Case, the licensee'must follow all provisions in Code Case N 546 including any limitations identified in Regulatory Guide 1.147.

3.0 CONCLUSION

9 The INEEL staff has completed review of the information provided by the licensee and l concluded that for PT-004, imposing the Code requirements on the licensee would result in a burden without a compensating increase in quality and safety . Therefore, the INEEL staff recommends that, for PT-004, the licensee's proposed alternative be authorized pursuant to 10 CFR 50.55ala)(3)(ii).

For Relief Requests PT-005 and PT-006, it is concluded tiet the licensee's proposed

- alternatives provide an acceptable level of quality and safety. Therefore, the INEEL

staff recommends that, for PT-005 and PT-006, the licensee's proposed alternatives be authorized pursuant to 10 CFR 50.55a(a)(3)(i).

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