ML20138B159

Requests Approval for Use of ASME Section Xi,Paragraph IWA-5244 Buried Components in 1995 Edition w/1995 Addenda, for Second 10-yr ISI Interval

ML20138B159
Person / Time
Site:	Wolf Creek
Issue date:	04/24/1997
From:	Muench R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ET-97-0040, ET-97-40, NUDOCS 9704290090
Download: ML20138B159 (4)

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l W4pLF CREEK NUCLEAR OPERATING CORPORATION i

} Richard A. Muench Vice President Engineering

April 24, 1997 4 ET 97-0040 J

j U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 1 Mail Station P1-137 j Washington, D. C. 20555 i

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Subject:

Docket No. 50-482: Request for Use of ASME Section XI IWA-5244 in the 1995 Edition with the 1995 Addenda i

l Ga*.lemen:

Pursuant to the provisions of 10 CFR 50.55a (a) (3) (i) , Wolf Creek Nuclear Operating Corporation (WCNOC) requests approval for use of ASME Section XI paragraph "IWA-5244 Buried components" in the 1995 Edition with 1995 Addenda.

i The attached relief request, I2R-22, provides the justification for the use of i the provisions of a later ASME Code edition and addenda than the ASME Code j edition and addenda currently approved in 10 CFR 50.55a(b). In addicion, the j attached relief request includes a determination that use of IWA-5244 in the i 1995 Addenda provides an acceptable level of quality and safety. Approval for

use of this relief request is requested by July 16, 1997, to support WCNOC's

preparation for the next refueling outage scheduled to begin September 20, i

1997. A copy of IWA-5244 from the 1995 Addenda is enclosed for your 3

convenience.

If you should have any questions regarding this request, please contact me at

(316) 364-8831, extension 4034, or Mr. Richard D. Flannigan at extension 4500.

i Very truly yours, D

Richard A. Muench i

I RAM /jad l

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Attachment:

Relief Request I2R-22

Enclosure:

IWA 5244, 1995 Addenda ]I j i cc: E. W. Merschoff(NRC), w/a l W. D. Johnson (NRC), w/a

_ J. F. Ringwald (NRC), w/a j J. C. Stone (NRC), w/a 1

9704290090 970424 l PDR ADOCK 05000482

. , .h v PDR P.O. Box 411/ Burlington. KS 66839 / Phone' (316; 364-8831

An Equal Opportunity Employer M F HCVET . = * * * *

.-I Attachment to ET 97-0040 Page 1 of 2 a[-

RELIEF REQUEST I2R-22 Page 1 of 2 Component Identification:

Buried Class 3 Piping Category:

ASME Section XI 1989 Edition, Table IWD-2500-1, Examination Categories D-A, D-B, and D-C, Item Numbers D1.10, D2.10 and D3.10 Examination Requirements:

The pressure retaining components within the boundary of each system shall be pressure tested and VT-2 examined each inspection period and hydrostatically tested and VT-2 examined each inspection interval. VT-2 examination of buried components is performed in accordance with IWA-5244.

Relief Requested:

Pursuant to 10 CFR 50.55a (a) (3) (i), relief is requested for the Second 10-Year Inspection Interval. Relief is requested to use an alternative to the provisions currently approved for use in 10 CFR 50.55a(b). The requested alternative is to use the provisions of IWA-5244 from the 1995 Edition with 1995 Addenda of ASME Section XI in lieu of the provisions of IWA-5244 from the 1989 Edition for performing pressure tests of buried components at Wolf Creek Generatirg Station. All other provisions of the 1989 Edition would continue to be met, except as specifically approved for other relief requests.

Basis For Relief:

The following examples demonstrate the need and the acceptability of using IWA-5244 from the 1995 Edition with 1995 Addenda:

1) The 1989 Edition of ASME Section XI, as approved by 10 CFR 50.55a, does not provide provisions for testing buried systems that are, " redundant,"

and, " isolable," such as the case for the WCNOC Essential Service Water (ESW) System. Use of the 1995 Addenda of Section XI categorizes requirements based on isolability alone and is independent of whether the system is considered " redundant". Use of the 1995 Addenda would allow WCNOC to perform, where applicable, a Code prescribed " rate of pressure loss" test, measuring mass going into the isolated ESW buried pressure boundary which would account for leakage, if present, through the buried portions of the system and the boundary valves.

2) IWA-5244(b) of the 1989 Edition addresses systems that are, " redundant,"

and, "nonisolable." The only method in the 1989 Edition for testing this ccafiguration is to compare the flow at one end of the buried components with the flow at the other end of the buried components.

Compliance with this requirement is not always possible. Such is the case for the WCNOC Emergency Fuel Oil Transfer System because one end of the buried pipe is the transfer pump which is submerged within an I

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Attachment to ET 97-0040 4 '

Page 2 of 2 REI,IEF REQUEST I2R-22 Page 2 of 2 underground storage tank. Therefore, it is not possible to measure the flow leaving the pump. The function of this system is to transfer fuel oil to the day tank which is the suction source for the emergency diesel generator fuel injectors. Excess inventory is then gravity drained back to the storage tank. Use of the 1995 Addenda would allow the use of measuring an adequate flow rate which is performed on a quarterly basis through implementation of the Inservice Pump Testing requirements.

The Code revision to IWA-5244 was based on recognition that the requirements do not address industry conditions, such as " redundant / isolable" conditions and inability to measure flow at both ends of buried components. The revision broadens the requirements for isolable systems by regniring the same provisions for all isolable buried components, whether they are redundant or nonredundant systems. The revision also changes the test for nonisolable systems to require a verification that flow during operation is not impaired since determining the change in flow between ends of nonisolable buried components for redundant systems, as required by the 1989 Edition, is not always possible. This Code revision published in the 1995 Addenda was approved by the Code consensus process. Approval by the Code consensus process and the above discussion demonstrates an acceptable level of quality and safety. Therefore, the use of the 1995 Addenda is an acceptable alternative to the 1989 Edition.

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.q IWA 5222 ' GENERAL REQUIREMENTS IWA-5245  ;

IWA 5222 System Hydrostatic Test Boundary where leakage may be detectable. Essentially horizontal ,

surfaces of insulation shall be examined at exh insula-(a) The boundary subject to test pressurization during tion joint.  ;

a system hydrostatic test [lWA-5211(b)] shall be defmed '

(b) When exanu,n,mg insulated components, the exam-by the system boundary (or each portion of the bound.

ination of the surrounding area (including floor areas ,

ary) within which the components have the same mini-f e4u ipment surfaces located underneath the compo- I mum required classirication and are designed to the nents) for evidence of leakage, or other areas to which  ;

same pressure rating as governed by the systera function such leakage may be channeled, shall be required. '

and the internal fluid operating conditions, respectively.

(c) Discoloration or residue on surfaces examined (b) Systems which share safety functions for different shall be given particular attention to detect evidence modes of plant operation, and within which the compo-f boric acid accumulations from borated reactor coolant nent classifications differ, shall be subject to separate

" "E' system hydrostatic tests of each portion of the system boundary having the same minimum required design pressure ratings. IWA 5243 Components With Leakage Collection (c) Systems designed to operate at different pressures Systeras under several modes of plant operation or post-accident hem leakages fmm components are nonnaHy ex-conditions shall be subject to a system hydrostatic test Pected and collected (such as valve stems, pump seals, I within the test boundary defined by the operating mode r vessel flange gaskers) the VT-2 visual examination with the higher pressure.

shall be conducted by verifying that the leakagt collec-(d) Where the respective system design pressure rat-tion system is operative.

ings on the suction and discharge sides of system pumps differ, the system hydrostatic test boundary shall <

be divided into two separate boundaries (such as suction IWA 5244 Buried Components APS l side and discharge side test boundaries). In the case  !

(a) For buried components surrounded by an annulus, '

of positive displacement pumps, the boundary interface the VT-2 visual examination shall consist of an examina-  !

shall be considered as the pump. In the case of centrifu.

tion for evidence of leakage at each end of the annulus j gal pumps, the boundary interface shall be the first ""

shutoff valve on the discharge side of the pump.

b) For b rie co nents where a VT-2 visual examination cannot be performed, the examination re-quirement is satisfied by the following:

IWA 5240 VISUAL EXAMINATION (1) The system pressure test for buried components IWA 5241 Noninsulatect Components that are isolable by means of valves shall consist of a test that determines the rate of pressure loss. Alterna-(a) The VT-2 visual exammmiva shall be conducted tively, the test may determine the change in flow by examining the accessible external exposed surfaces of between the ends of the buried components. The accept-pressure retaining components for evidence of leakage. able rate of pressure loss or flow shall be established (b) For components whose extemal surfaces are inac' by the Owner, cessible for direct VT-2 visual examination, only the (2) Tha system pressure test for nonisolable buried examination of the surrounding area (including floor components shall consist of a test to confirm that flow areas or equipment surfaces located underneath the during operation is not impaired.

components) for evidence of leakage shall be required. (3) Test personnel need not be qualified for VT-2 visual examination.

IWA 5242 Insulated Components A ate emPerature Tests (a) For systems borated for the pugose of controlling reactivity, insulation shall be removed from pressure The visual examination of system components requir-retaining bolted connections for VT-2 visual examina- ing a test temperature above 200*F during the system tion. For other components, a VT-2 visual examination pressure test may be conducted after the pressure holding may be conducted without the removal of insulation period of IWA-5213 is satisfied, and the pressure is by examining the accessible and exposed surfaces and lowered to the level corresponding with a temperature joints of the insulation. Essentially vertical surfaces of of 200'F, in accordance with allowable cooldown rates insulation need only be examined at the lowest elevation established by fracture prevention criteria.

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