ML20206R504

Revises 870120 Request for Relief from ASME Code Section XI Requirements Re Inservice Insp & Testing Program

ML20206R504
Person / Time
Site:	Prairie Island
Issue date:	04/14/1987
From:	Musolf D NORTHERN STATES POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8704220176
Download: ML20206R504 (17)

Text

'd, A Nortnem States Power Company 414 Nicollet Mall Minneapohs unnesota 55401 Telephone (612) 330-5500 April 14, 1987 10 CFR Part 50 Section 50.55(g)(6)(1)

U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Information Required for NRC Review of Revision No. 2 to Requests for Relief from ASME Code Section XI Requirements The purpose of this submittal is to revise our January 20, 1987 submittal entitled "Information Required for NRC Review of Inservice Inspection and Testing Program and Requests for Relief from ASME Code Section XI Requirements". Request for Relief No. 18, 27, 39, 57a, 57b, 57c, 59, 69 for Unit 1 and 18, 27, 39, 57a, 57b, 57c, 59, 69 for Unit 2 of the original submittal have been revised per discussions with Mr. Dominic DiIanni, Senior Project Manager, Office of NRR. The revised Requests for Relief are included as Attachment A.

Payment of an application fee is not required since this is a revision to an earlier submittal for which an application fee was included.

Summary of Reauest for Relief Revisions

1. Reauest for Relief No. 18 (Units 1 & 2)

Request for Relief No. 18 has been deleted from the Prairie Island Inservice Inspection and Testing Program. This Request for Relief dealt with corrective actions in cases where valve stroke timing was found to be outside acceptable bounds. Per ASME code IWV-3417, measured valve stroke timing is to be compared to the last stroke timing performed on the valve as the basis for determining the allowable 25% and 50% stroke time increase. Request for Relief No.

18 proposed comparing stroke timing tests to a time established by;

1) original preoperational testing, 2) post maintenance testing or 3) the first running of the test. This is a more conservative method than is outlined by the ASME code. Based on this fact and discussions with Mr. DiIanni, the Request for Relief was 8704220176 870414 2 b

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Director of NRR h States Pm Company April 14, 1987 Page 2 deemed unnecessary and is being removed from the program. We will continue to stroke time test the valves included in the Inservice

' Inspection and Testing program in the manner outlined above.

2. Reauest for Relief No. 27 (Units 1 & 2)

Valves VC-8-2, VC-17-1 (Unit 1) and'2VC-8-2, 2VC-17-1 (Unit 2) have been deleted from Request for Relief No. 27. These valves will now be tested at each cold Shutdown as required by IWV-3522.

3. Reauest for Relief No. 39 (Units 1 & 2)

Request for Relief No. 39 is being withdrawn. Valves previously referenced in Request for Relief No. 39 will now be tested at each Cold Shutdown.

4. Reauest for Relief No. 57a (Units 1 & 2)

Request for Relief No. 57a was revised in our submittal dated January 20, 1987 as a result of NRC Inspection Nos. 50-282/85012 and 50-306/85009. A statement has been added to the basis section of Request for Relief No. 57a to document the revision.

5. Reauest for Relief No. 57b (Units 1 & 2)

Based on discussions with Mr. DiIanni, most of the valves have been deleted from Request for Relief No. 57b. The valves that have been deleted from the Request for Relief could potentially cause various operational problems. These valves will be tested at each cold shutdown.

6. Reauest for Relief No. 57c (Units 1 & 2)

Request for Relief No. 57c has been withdrawn. See the above Discussion related to Request for Relief No. 57b for the basis for withdrawing this Request for Relief.

7. Reauest for Relief No. 59 (Units 1 & 2)

Point number 1 in the Basis section of Revision 1 to Request for Relief No. 59 has been deleted. This section of the basis was originally included to justify alternate testing to that required by IWV-3426. Mr. Dilanni pointed out that IWV-3426 allows the licensee to define the method for performing such tests. This makes this section of the basis unnecessary.

Director of NRR Northem States Power Company April 14,-1987 Page 3

9. Reauest for Relief No. 69 (Units 1 & 2)

Request for Relief no. 69 contains one administrative change. In the submittal dated January 20, 1987, the revision number on Request for Relief No. 69 was incorrect. It has been corrected to "Rev. 2 4/14/87" from "Rev. 0 12/12/86". This is the only change to this Request for Relief.

Please contact Ron Meyer at (612).337-2035 if you have any questions regarding this submittal. The above described changes will be distributed as Revision No. 2 to all holders of the Prairie Island Section XI Inservice Inspection and Testing Program,

v. ,

David Musolf Manager - Nuclear Support Services DMM/RJM/rjm c: Regional Administrator-III, NRC NRR Project Manager, NRC (3 copies)

Resident Inspector, NRC H Barion, State of Minnesota S Tack, Hartford Steam Boiler G Charnoff 1

Attachments

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SECTION-1.5 REQUESTS FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS DETERMINED TO BE IMPRACTICAL UNIT NO. 1 AND COMMON COMPONENTS This section contains a tabulation of all of the requirements contained in Section XI of the ASME Code that we have determined are impractical on Unit I and common components.

The Requests for Relief are numbered sequentially with the following exceptions:

Request for Relief No. Remarks 6 Withdrawn 10 Withdrawn 15 Withdrawn 17 Withdrawn 18 - 20 Withdrawn l 22 Withdrawn 32 Withdrawn 34 Withdrawn 36 - 39 Withdrawn l 41 - 44 Withdrawn 46 - 47 Withdrawn 49 Withdrawn 51 Withdrawn 53 Withdrawn 55 Withdrawn 57c Withdrawn l

58 Withdrawn 62 Withdrawn 64 - 65 Withdrawn PI ISI/IST Section 1.5-1 2nd 10-YR PROGRAM Rev. 2 4/14/87

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27. REQUEST FOR RELIEF ASME COMPONENT FUNCTION Code Viv Class Cat AF-14-1 11 Aux Fd Pump Suct Check Close to isolate condensate supply to Aux Fd Pop 3 C AF-14-3 12 Aux Fd Pump Suct Check Close to isolate condensate supply to Aux Fd Pop 3 C CC-3-3 Return Line to 11 Comp Cool Pump Check Close to isolate non-safeguards equipment 3 C CC-3-4 Return Line to 12 Comp Cool Pump Check Close to isolate non-safeguards equipment 3 C F-8-1 FW to 11 Steam Generator Check To close on feed line break 2 C l-F-8-2 FW to 12 Steam Generator Check To close on feed line break 2 C CL-42-1 Loop A Cig Hdr Turb Bldg Check Valve Close to isolate non-safeguards equipment 3 C 2CL-42-1 Loop B Cig Hdr Turb Bldg Check Valve Close to isolate non-safeguards equipment 3 C CODE REQUIREMENT The valves will not be exercised as required by IWV-3522.

, BASIS System design does not permit the performance of a meaningful exercise test to verify the valve prevents reverse flow without excessive manipulation of components and systems involved. These operations are not warranted for the extent of testing to be accomplished. Specifically:

Ar-14-1. 3 These are normally open check valves. Verification of valve closure requires taking one of the opposite units aux i

feedwater pumps out-of-service and draining approximately 200 feet of 8 inch pipe. Taking one of the otiier units aux feedwater pumps out-of-service requires repositioning of valves, which if not performed properly, could result in a

, violation of the plant's operating license.

CC-3-3. 4 These are normally open check valves. Verification of valve closure requires isolation of the following equipment and draining of long sections of piping.

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PI ISI/IST Section 1.5-29 2nd 10-YR PROGRAM Rev. 2 4/14/87

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i 57a CODE FOR REQUEST -(cont'd)

BASIS These valves are . required by 10 CFR 50 Appendix J (Prima ry Reactor Containment Leakage Testing for Water Cooled Power Reactors) to have a minimum leakage and are therefore category A valves. Since the va lves a re requi red by Appendix J .

they will be leak rate tested, in accordance with Appendix J. This includes the method, measurements, medium, analysis, and corrective actions. This is consistant with Section Xi's philosophy on containments; Table IWE-2500-1 and IWE-5220 state pressure retalning boundaries of containments will be tested in accordance with 10 CFR 50 Appendix J. This request for relief was submitted in accordance with NRC inspection Report Nos. 50-282/85012 and 50-306/85009 transmitted by letter dated July 3, 1985. ,

ALTERNATE INSPECTION iTESTINC)

The valves will be tested in accordance with 10 CFR 50 Appendix J.

! SCHEDULE FOR IMPLEMENTATION Presently being done, i

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s PI ISI/IST Section 1.5-47 2nd 10-YR PROCRAM Rev. 2 4/14/87 m _ _ _ _ _ _+a

57b. REQUEST FOR RELIEF AS4E COMPONENT FUNCTION Code . Viv Class Cat isolate Containment MC A CV-31740 1 Cntat inst Air isol Valve A 1solate Containment MC A CV-31741 1 Cntet inst Air isol Valve B CODE REQUIREMENTS The valves will not be exercised at Cold Shutdown as required by IWV-3410.

BASIS Exercising these valves at Cold Shutdown would create extensive operational p rob l ems, spectrically:

CV-31740. CV-31741 Cycling of these valves will isolate instrument air in containment. This will cause all of the air operated control valves to go to their railed position. ..

ALTERNATE INSPECTION (TESTING)

The valves will be exercised at refueling and arter maintenance when they are leak tested.

SCHEDULE FOR IMPLEMENTATION Presently being done.

PI ISI/IST Section 1.5-48 2nd 10-YR PROGRAM Rev. 2 4/14/87

59. REQUEST FOR RELIEF (cont'd)

BASIS Because of piping configurations multiple valves will be tested at the same time. IWV-3424(b) will be followed in that the total leaked of the multiple valves will be required to be less than the seat leakage for any one valve.

ALTERNATE INSPECTION fTESTING)

SI-6-1 and SI-6-3 Leakage will be measured per'lWV-3424(a) except that accumulator volume change instead of telltale drainage will be used. This is done to minimize change of contamination and for ALARA.

SI-9-3. St-9-4. S1-16-4. SI-16-5. SI-16-6. SI-16-7. CV-31447 and CV-31449 Leakage will be measured per IWV-3424(a) except that multiple valves will be tested at the same time. Total l ea kage will be assigned to each individual valve. This is done for ALARA.

i SI-9-1. SI-9-2. SI-9-5. and SI-9-6 Leakage will be measured per IWV-3424(a) except that multiple valves will be tested at the same time. Total leakage will be assigned to each individual valve. This is done for ALARA.

MV-32066 Leakage will be measured per IWV-3424(b) except that the change in pressure will be used to determine apparent lea kage instead of maintaining a constant pressure. For significant changes in pressure the correction of IWV-3423(e) will be used.

MV-32165 and MV-32211 Leakage will be measured per IWV-3424(b), however, because of piping configuration the leakage of MV-32164 and MV-32230 will be added to the leakage of MV-32165 and MV-32231 to determine leakage. MV-32165 and 32231 will be tested at reduced dp per IWV-3423(e). This is done to minimize the change of contamination and for ALARA.

1 MV-32164 and MV-32230 Leakage will be measured per IWV-3424(a) except that pressure change of a test volume will be used. lWV-3423(e) will be used for correction of leakage rate. This is done to minimize the chance of contamination.

Additionally all valves are tested at Hot Shutdown Condition so that leakage is representive of at Power 6nd Hot Shutdown valves.

SCHEDULE FOR IMPLEMENTATION Presently being done PI ISI/IST Section 1.5-50 2nd 10-YR PROCRAM Rev. 2 4/14/87

59. REQUEST FOR RELIEF ASME FUNCTION Code Viv COMPONENT Class Cat Allows Leakage Testing of First 1 A CV-31447 Acc After Ok Test Viv Accumulator Check Valve Allows Leakage Testing of First 1 A CV-31449 Acc After Ck Test Viv Accumulator Check Va lve 4

CODE REQUIREMENT Valves will not be exercised as required by IWV-3412.

BASIS Valves are only in the system to allow testing of leakage of 'the first set of accumulator check valves. Because of'the location of these valves they form the second isolation valve fromHowever the Reactor Coolant System and are therefore Code since the valves are only for testing they can Class 1 valves. These valves are leakage tested per IWV-3420.

be exempted f rom exercise testing per IWV-1200.

ALTERNATE INSPECTION (TESTINC)

Valves will be leakage tested per IWV-3420.

SCHEDULE FOR IMPLEMENTATION Presently being done.

PI ISI/IST Section 1.5-57 2nd 10-YR PROCRAM Rev. 2 4/14/87

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SECTION 2.5 REQUESTS FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS DETERMINED TO BE IMPRACTICAL UNIT NO. 2 This section contains a tabulation of all of the requirements contained in Section XI of the ASME Code that we have determined are impractical on Unit 2 components.

The numbering system used parallels Section 1.5 of this report (Unit No. 1 Requests for Relief) with the following exceptions:

Request for Relief No. Remarks 4 Not used 6 Withdrawn 10 Not used 15 Not used 17 Withdrawn 18 - 20 Withdrawn 22 Withdrawn l 23 Not used 24 Withdrawn 25 - 26 Not used 30 - 31 Not used 32 Withdrawn 34 Not used 35 Withdrawn 36 - 37 Not used 38 - 39 Withdrawn l

40 - 41 Not used 8 42 - 44 Withdrawn 46 - 47 Withdrawn 49 Not used 51 Withdrawn 53~ Withdrawn 55 Withdrawn 57c Withdrawn 58 Withdrawn 61 Not used 62 Withdrawn 64 - 65 Withdrawn PI ISI/IST 2.5-1 2nd 10-YR PROGRAM Rev. 2 4/14/87

27. REQUEST FOR RELIEF ASME COMPONENT FUNCTION Code. Viv Class Cal __

AF-14-7 22 Aux Fd Pump Suct Check Close to isolate condensate supply to Aux Fd Pop 3 6 AF-14-5 21 Aux Fd Pump Suct Check Close to isolate condensate supply to Aux Fd Pop 3 C 200-3-3 Return Line to 21 Comp Cool Pump Check Close to isolate non-safeguards equipment 3 C 2CC-3-4 Return Line to 22 Comp Cool Pump Check- Close to isolate non-safegua,rds equipment 3 C 2FW-8-1 FW to 21 Steam Generator Check To close on feed line break 2 C 2FW-8-2 FW to 22 Steam Generator Check To closn on feed l i ne b rea k 2 .C CODE REQUIREMENT The valves will not be exercised as required by IWV-3522.

BASIS System design does not permit the performance of a mear.Ingful exercise test to verify the valve prevents reverse flow without excessive manipulation of components and systems involved. These operations are not warranted for the extent of testing to be accomplished. Specifically:

AF-14-5. 7 These are normally open check valves. Verification or valve closure requires taking one of the opposite units aux feedwater pumps out-of-service and draining approximately 200 feet of 8 inch pipe. Taking one of the other units aux feedwater pumps out-of-service requires repositioning of valves, which if not performed property, could result in a violation of the plants operating license.

2CC-3-3. 4 These are normally open check valves. Verification of valve closure requires isolation of the following equipment and draining of long sections of piping.

1. Boric Acid Evaporator 4. Letdown Heat Exchanger

2. Seconda ry Sampling System 5. Reactor Coolant Pumps

3. Seal Water lleat Exchanger 6. Excess Letdown Heat Exchanger The water in the system is chromated and its disposal presents an occupational and environmental haza rd.

Pl ISI/IST 2.5-20 2nd 10-YR PROGRAM Rev. 2 4/14/87

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'27. REQUEST FOR RELIEF (cont'd) 2FW-8-1 2FW-8-2 .

Stroking these valves requires operation or the' aux feedwater pumps and .the draining of a long section of 16- inch pipe.

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Such an errort is not warranted to verify that the check valves close.

s ALTERNATE INSPECTION fTESTINGl J

See Individual Bases..

SCHEDULE FOR IMPLEMENTATION Six months from the submittal date or October 14, 1983.

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PI ISI/IST 2.5-21 2nd 10-YR PROGRAM Rev. 2 4/14/87

57s. REQUEST FOR RELIEF fcont'd)

CODE REQUIREMENTS The valves will not be leak rate tested in the manner required by IWV-3420.

BASIS i

These valves are required by 10CFR 50, Appendix J (Primary Reactor Containment Leakage Testing for Watercooled Power Reactors) to have a minimum leakage, and are therefore Category A valves. Since the valves are required by Appendix J they will be leakrate tested, in accordance with Appendix J. This includes the method, measurements, medium, analysis, and corrective actions. This is consistent with Section XI philosophy on containment Table IWE 2500-1 and IWE 5220 state i

pressure retalning boundaries or containment will be tested in accordance with -10CFR 50, Appendix J. This request fo r relier was submitted in accordance with NRC Inspection Report Nos. 50-282/85012 and 50-306/85009 transmitted by letter dated July 3, 1985.

l ALTERNATE INSPECTION (TESTIN0)

The valves will be tested in accordance with 10CFR 50, Appendix J.

SCHEDULE FOR IMPLEMENTATION Presently being done.

PI ISI/IST 2.5-35 2nd 10-YR PROGRAM Rev. 2 4/14/87

57b. REQUEST FOR REllEF AS1E COMPONENT FUNCTION Code Viv Class Cat CV-31742 2 Cntet inst Air isol Valve A isolates Containment MC A CV-31743 2 Cntet inst Air Isol Valve B isolates Containment MC. A CODE REQUIREMENTS These valves will not be exercised at cold shutdown as required by IWV-3410.

I BASIS Exercising these valves at cold shutdown would create extensive operativnc! problems spect rically:

CV-31742. CV-31743 Cycling of these valves will isolate instrument air in containment. This would cause all the air operated control valves to go to their failed position. ,

ALTERNATE INSPECTION (TESTING)

The valves will be exercised at refueling and after maintenance when they are leak tested.

SCHEDULE FOR IMPLEMENTATION Presently being done.

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i PI ISI/IST 2.5-36.

2nd 10-YR PROCRAM Rev. 2 4/14/87 i

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59. REQUEST FOR REllEF fcont'd)

PASIS Because or piping configurations, multiple valves will be tested at the same. time. Condition IW-3424(b) will be followed, in that the total leakage of the multiple valves will be required to be less than the seat leakage for any one valve.

ALTERNATE lHSPECTION f TESTING) l RSI-6-1 and 2SI-6-3 ..

Leakage will be measured per IW-3424(a) except that accumulator volume change Instead or telltale dralnage, will be used. This is done to minimize chance of contamination and for ALARA.

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2 S I-9-3 dS I fq_211_16-4. 2SI-16-5. 2SI-16-6. 2SI-16-7 W-118.tS9 and CV-31861 1 Leakage will be measured per IWV-3424(a) except that multiple valves will be tested at the same time. Total leakage will be assigned to each Individual valvo. This Is done for ALARA.

ESI-9-1. 211-9-2. 2SI-9-5. and 2St-9-6 Leakage will be measured per IWV-3424(a) except that multiple valves will be tested at the same time. Total leakage will be assigned to each Individual valve. This Is done for ALARA.

tiV-32162 Leakage will be measured per IWV-3424(b) except that the change in pressure will be used to determine apparent leakage,

+ instead of maintaining a constant pressure. For significant changes in pressure the correction or IWV-3423(e) will be used.

tiY-32123_.a nd .11Y-32231 Leakage will be measured per IWV-3424(b), however,. because of piping configuration the leakage of MV-32192 and MV-32232 will be -

added to the leakage of MV-32193 and MV-32233 to determine the leakage. MV-32193 and MV-32233 will be tested at reduced load per chance of contamination and for ALARA.

(N-32192 and My-32232 Leakage will be measured per IWV-3424(a) except that pressure change or a test volume will be used. IWV-3423(e) will be used for l correction or leakage rate. This is done to alnialZe the chance or contamination.

j Addit,lonally all valves are tested at flot Shutdown condition so that leakage is representative or at power and Hot Shutdown j valvss.

0 scEpyl..E FOR_lMPt EMENTATIM Presently being done.

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P1 ISI/IST 2.5-38 2nd 10-YR PROGRAM Rev. 2 '4/14/87

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69. REQUEST FOR RELIEF AS1E COMPONENT TUNCTION Code Viv l Class Cat t

Allows leakage testing of first accumulator 1 A CV-31459 Acc Af ter Check Test Valve check valve Acc Af ter Check Test Va lve Allows leakage testing of first accumulator 1 A CV-31461 check valve l

l CODE REQUIREMENT Valves will not be exercised as required by IWV-3412.

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l BASIS Valves are only in the system to allow leak testing of the first set of accumulator check. valves. These valves a re the second isolation valve from the Reactor Coolant System and are therefore Code Class 1 valves. These valves a re leakage tested per IWV-3420. However since the valves are only for testing they can be exempted from exercise testing per IWV-1200.

ALTERNATE INSPECTION iTESTING)

Valves will be leakage tested per IWV-3420.

SCHEDULE FOR IMPLEMENTATION Presently being done.

PI ISI/IST 2.5-44 2nd 10-YR PROCRAM Rev. 2 .4/14/87

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