TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR …Pressure Test Program and all applicable plant...

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TENNESSEE VALLEY AUTHORITY

WATTS BAR NUCLEAR PLANT

ASME SYSTEM PRESSURE TESTING

PROGRAM BASIS DOCUMENT

This document is to be used for the initial ten year inspection interval

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I TENNESSEE VALLEY AUTHORITY WATT'S BAR NUCLEAR PLANT PAGE 2I ~ASME SYSTEM PRESSURE TESTING PROGRAM BASIS DOCUMENT

REVISION LOG

FREVISION DESCRIPTION

OF REVISION DATE

0 Initial Issue April 24, 1996

TENNESSEE VALLEY AUTHORITY WATT"S BAR NUCLEAR PLANT PAGE 3

ASME SYSTEM PRESSURE TESTING PROGRAM BASIS DOCUMENT IREV 0

TABLE OF CONTENTS

PAGE

I. CHARTER - MISSION - OBJECTIVES 4

II. PURPOSE - BASES 5

III. REFERENCES 6

IV. DEFINITIONS 7

V. PROGRAM SCOPE AND PLAN 8

VI. REGULATORY REQUIREMENTS 9

VII. DESCRIPTION 10

VIII. PRESSURE TEST REQUIREMENTS 11

IX. RESPONSIBILITIES 16

X. KNOWLEDGE AND:TRAINING REQUIREMENTS 17

APPENDICES. APPENDIX A: REQUESTS FOR RELIEF

APPENDIX B: INITIAL PRESSURE TEST SCHEDULE

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ASME SYSTEM PRESSURE TESTING PROGRAM BASIS DOCUMENTREV 0

I. CHARTER

This document has, been prepared for the initial Ten Year ASME Section XIInspection Interval.

A. MISSION STATEMENT

The ASME Section XI Inservice Pressure Test Program shall incorporate TVApolicies and standards to support safe and reliable operation of Watts BarNuclear Plant through the following:

1. Establish and maintain the ASME Section XI Pressure Test Program toensure the requirements of 10CFR50.55a and WBN Technical Requirementsare met.

2. For all cases where ASME Section XI pressure test requirements are not met,or alternatives to Code requirements are proposed, provide a documentedrelief request for NRC approval.

3. Development of implementing procedures to satisfy programmatic requirements.

The Pressure Test Program Engineer shall hold responsibility, accountability, andauthority for accomplishing this mission and maintaining the program.

The WBN site supervisor assigned responsibility for the ASME Section XIInservice Pressure Test Program shall designate the Pressure Test ProgramEngineer and provide the resources necessary to accomplish this mission.

B. OBJECTIVES

The Objectives of the ASME Section XI Pressure Test Program areas follows:

1. Perform system pressure testing in accordance with ASME Section XI,1989 Edition and applicable Code Cases unless relief is requestedfor alternative testing.

2. Maintain system pressure boundary integrity by satisfying TechnicalSurveillance Requirement 3.4.5.2.

3. Maintain clearly defined responsibilities of organizations involvedwith pressure testing.

4. Maintain applicable procedures, test equipment, and methods tocurrent industry standards or better.

5. No NRC violations due to the ASME Inservice Pressure Test Program.

I TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT PAGE 5


II. PURPOSE - BASES

The rules for inservice pressure testing for nuclear power plant components arecontained in the ASME Boiler and Pressure Vessel Code, Section XI, Division 1.Title 10, Part 50, Article 50.55a of the Code of Federal Regulations and WattsBar's Technical Requirements state that ASME Section XI shall be met throughoutthe service life of the nuclear power plant and updated at each 10 year interval.

Under the provisions of 10CFR50.55a, inservice pressure tests of safety relatedpiping systems will be performed in accordance with a specific edition andaddenda of Section XI of the ASME Boiler and Pressure Vessel Code. The initial10 year inspection interval will begin at commercial operation of Watts Bar Unit1. The applicable edition and addenda of ASME Section XI for the initial 10 yearinspection interval is the 1989 Edition. In addition, the following ASME CodeCases will be applicable during the initial inspection interval:

1. ASME Code Case N-416-1, Alternative Pressure Test Requirement for WeldedRepairs or Installation of Replacement Items by Welding, Class 1, 2 and 3Section XI, Division 1. (See ISPT-02)

2. ASME Code Case N-498, Alternative Requirements for 10-Year SystemHydrostatic Testing for Class 1 and 2 Systems, Section XI, Division 1.

3. ASME Code Case N-498-1, Alternative Rules for 10-Year System HydrostaticTesting for Class 1, 2 and 3 Systems, Section XI, Division 1. (See ISPT-01)

4. ASME Code Case N-522, Pressure Testing of Containment Penetration Piping(See ISPT-04)

5. ASME Code Case N-533, Alternative Requirements for VT-2 Visual Examinationof Class 1 Insulated Pressure-Retaining Bolted Connections, Section XI,Division 1 (See ISPT-06)

6. ASME Code Case N-546, Alternative Requirements for Qualification ofVT-2 Examination Personnel, Section XI, Division 1 (See ISPT-07)

III. REFERENCES

1. 10CFR50.55a

2. ASME Boiler and Pressure Vessel Code, Section XI, Division 1, 1989 Edition.

3. ANSI/ASME N45.2.6-1978, Qualification of Inspection Examination and TestingPersonnel for Nuclear Power Plants.

4. Watts Bar Nuclear Plant Technical Requirements

5. STD - 6.9, Repair/Replacement of ASME Section XI Components

6. STD - 8.5, ASME Section XI System Pressure Test Program

7. WBN Final Safety Analysis Report (FSAR)

8. Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASMESection XI-Division 1

9. ASME Code Case N-416-1, Alternative Pressure Test Requirement for WeldedRepairs or Installation of Replacement Items by Welding, Class 1, 2 and 3Section XI, Division 1.

10. ASME Code Case N-498, Alternative Requirements for 10-Year System HydrostaticTesting for Class 1 and 2 Systems, Section XI, Division 1.

11. ASME Code Case N-498-1, Alternative Rules for 10-Year System HydrostaticTesting for Class 1, 2 and 3 Systems, Section XI, Division 1.

12. ASME Code Case N-522, Pressure Testing of Containment Penetration Piping

13. ASME Code Case N-533, Alternative Requirements for VT-2 Visual Examinationof Class 1 Insulated Pressure-Retaining Bolted Connections, Section XI,Division 1

14. ASME Code Case N-546, Alternative Requirements for Qualification of VT-2Examination Personnel, Section XI, Division 1

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IV. DEFINITIONS

1. Inspection Interval - The time interval during which this inservicepressure ýtest program shall be in effect and equal to 120 monthscommencing at unit commercial operation, except as modified in accordancewith paragraphs IWA-2430 (d) and (e).

2. Period - The three time periods into which the inspection interval isdivided of approximately 3 years, 4 years and 3 years (per Tables IWB-2412-1, IWC-2412-1 and IWD-2412-l), except as modified in accordance withparagraphs IWA-2430 (d) and (e).

4. Nominal Temperature and Pressure - The pressure and temperature conditionsto which the system or component is exposed when aligned for normal plantoperation. For standby systems, the pressure and temperature conditionsachieved during component/system functional testing.

5. Buried Component - A component that is buried, or encased in concrete,underground. This does not include piping which penetrates a concretewall, or passes through an enclosed penetration. Such piping is consideredinaccessible per IWA-5240.

6. Open Ended - Piping that permits free discharge of fluid to openatmosphere or containment atmosphere.

V. PROGRAM SCOPE & PLAN

SCOPE

ASME Section XI, Tables IWB-2500-1, IWC-2500-1 and IWD-2500-1 identify thosecomponents and test frequency applicable to the inservice pressure testrequirements of IWA-5000 for periodic testing. The applicable tables andexamination categories in relation to code class are as follows:

Class 1 ...... Table IWB-2500-1 ........ Category B-P, B-EClass 2....... Table IWC-2500-1 ........ Category C-H, C-BClass 3 ...... Table IWD-2500-1 ........ Category D-A, D-B, and D-C

Additionally, repair/replacement activities performed in accordance with therequirements of ASME XI shall be pressure tested prior to, or immediately uponreturn to service if required by IWA-4000 or IWA-7000. Alternatively, therequirements of Relief Request ISPT-2 may be used to satisfy the pressure testrequirement in lieu of Code required hydrostatic testing.

Appendix B provides a initial inservice pressure test schedule for the systemsincluded within the ASME Section XI boundaries. This schedule gives generalinformation of the systems, boundaries, and the tests required by periods forthe initial inspection interval. This schedule may be amended as needed aslong as compliance with all the Code requirements for system pressure testingiis maintained.

PLAN

A. The ASME pressure test instructions shall be developed, reviewed,approved and conducted in accordance with the ASME Section XI InservicePressure Test Program and all applicable plant procedures.

B. ASME Section XI pressure test will be conducted in, accordance withapproved written instructions and witnessed/verified by the AuthorizedNuclear Inservice Inspector (ANII).

C. The ASME pressure test records shall be reviewed by the Pressure TestProgram Engineer and maintained in accordance with Subsections IWA-1400,IWA-5300 and IWA-6000 of the 1989 Edition of ASME Section XI.

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VI. REGULATORY REQUIREMENTS

10CFR50.55a (g) requires the inservice inspection and pressure testing of CodeClass 1, 2, and 3 components per an NRC approved edition and addenda of ASMESection XI, "Inservice Inspection of Nuclear Power Plants" of the ASME Boilerand Pressure Vessel Code. ASME Section XI Subsections IWB, IWC and IWDidentify those components which shall be tested per the requirements of IWA-5000. Portions of later editions and addenda pursuant to paragraph50.55a(g) (4) (iv), requests for relief from Code requirements pursuant toparagraph 10CFR50.55a(g) (5) (iii) and alternatives pursuant to10CFR50.55a(a) (3), and ASME Code Cases pursuant to footnote 6 to 10CFR50.55aalso apply.

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PAGE 101

VII. DESCRIPTION

Under the provisions of 10CFR50.55a, pressure testing will be performed inaccordance with Section XI of the ASME Boiler and Pressure Vessel Code andapplicable Addenda. As required by 10CFR50.55a (b), the effective edition ofSection XI with regard to the initial ten year interval is the 1989 Edition,Division 1. Pressure testing shall comply with the requirements of ASMESection XI (applicable Edition and Addenda) and approved test alternativescontained in code cases listed in the test program, except where relief isrequested under the provisions 6f 10CFR50.55a.

m

VIII. PRESSURE TEST REQUIREMENTS

A. Test Description

The pressure retaining components within each system boundary shall be subjectto system pressure tests. When test conditions are stable and any requiredhold times are satisfied a visual examination VT-2 shall be performed todetect any leakage. The required system pressure tests may be conducted inconjunction with one or more of the following system tests:

1. A System Leakage Test conducted at nominal operating pressure on a Class1 system prior to plant startup following each reactor refueling outageor after reassembly of mechanical joints following a Section XI repairor replacement. No holding time is required after attaining testpressure and temperature conditions.

When a system leakage test is performed in lieu of a 10-year hydrostatictest, per Code Case N-498-1, the system shall be pressurized to nominaloperating pressure for at least 4 hours for insulated components and 10minutes for noninsulated components. When testing to satisfy N-498-1lthe boundary subject to test pressurization and VT-2 examination shallextend to all Class 1 pressure retaining components within the systemboundary.

12. A System Functional Pressure Test conducted during a componentfunctional test for systems not required to operate during normal plantoperation while under system operating pressure. When a systemfunctional pressure test is performed-to satisfy the periodic testrequirements, a 10 minute holding time is required after attainingsystem operating pressure.

When a system functional pressure test is performed to satisfy N-498-1requirements in lieu of a 10-year hydrostatic test, the system shall bepressurized to nominal operating pressure for a minimum of 4 hours forinsulated systems and 10 minutes for noninsulated systems. The systemshall be maintained at nominal operating pressure during the performanceof the VT-2 visual examination. The boundary subject to testpressurization and examination shall extend to all Code Class componentsincluded in those portions of systems required to operate or support thesafety system function up to and including the first normally closedvalve (including a safety or relief valve) or valve capable of automaticclosure when the safety function is required. Components outside theboundary pressurized under a periodic system/component functional testmay be tested separately.

................................. ~.

3. A System Inservice Pressure Test conducted while the system is inservice under operating pressure. The system inservice test is normallyapplied to those safety systems which are required to operate during thecourse of normal plant operation. When an inservice test is performed tosatisfy the periodic test requirements, no holding time is requiredprovided the system has been in operation for at least 4 hours.

When a system inservice pressure test is performed to satisfy N-498-1requirements in lieu of a 10-year hydrostatic test, the system shall bepressurized to nominal operating pressure for a minimum of 4 hours forinsulated systems and 10 minutes for noninsulated systems. The systemshall be maintained at nominal operating pressure during the performanceof the VT-2 visual examination. The boundary subject to testpressurization and examination shall extend to all components includedin those portions of systems required to operate or support the safetysystem function up to and including the first normally closed valve(including a safety or relief valve) or valve capable of automaticclosure when the safety function is required.

NOTE: The preceding system pressure tests may be used in lieu of a 10-year hydrostatic test for Class 1, 2 and 3 safety systemsproviding the criteria specified in Relief Request ISPT-l (CodeCase N-498-1) is satisfied during test performance.

4. A System Hydrostatic Test conducted during plant shutdown at a pressureabove nominal operating pressure or system pressure for whichoverpressure protection is provided. When performing a systemhydrostatic test, a 4 hour holding time is required after attaining thetest pressure and temperature conditions for insulated systems and 10minutes for noninsulated systems or components. System hydrostatic testsshall be conducted at the test conditions of pressure and temperaturespecified in IWB-5000, IWC-5000, and IWD-5000.

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B. Test Pressurization Boundaries

The following test pressurization and examination boundaries are applicablewhen performing those periodic tests identified in Tables IWB-2500-1, IWC-2500-1 and IWD-2500-1. The boundary limits, as discussed in the following, aregenerally defined by the location of the design safety class interface valveswithin the system as shown on plant system flow diagrams.

1. System Leakage Test Boundary - The boundary subject to testpressurization and VT-2 visual examination shall extend to the pressureretaining components within the system boundary containing pressurizedreactor coolant under the plant mode of normal reactor startup (Mode 3).

2. System Functional Test Boundary - The boundary subject to testpressurization and VT-2 visual examination shall include only thosepressure retaining components within the system boundary pressurizedunder the test mode required during the performance of a periodicsystem/component functional test.

3. System Inservice Test Boundary - The boundary subject to testpressurization and VT-2 visual examination shall extend to thosepressure retaining components under operating pressures during normalsystem service.

4. System Hydrostatic Test Boundary - The boundary subject to testpressurization and VT-2 visual examination shall include only thoseportions of systems that were not exposed to nominal operating pressurewhen tested pursuant to Code Case N-498 or Relief Request ISPT-l.

The ASME Section XI Code class 1, 2, & 3 boundaries are defined as:

ASME Code Class 1 is equivalent to TVA Class AASME Code Class 2 is equivalent to TVA Class BASME Code Class 3 is equivalent to TVA Class C and D

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C. Corrective Action

The source of leakages detected during the performance of system pressuretests shall be evaluated for corrective measures as follows:

1. Buried components with leakage losses in excess of limits acceptable forcontinued service shall be repaired or replaced.

2. If leakage occurs at a bolted connection, corrective action shall beinitiated in accordance with the requirements of Relief Request ISPT-03.

3. Repairs or replacement of components shall be performed in accordancewith IWA-4000 or IWA-7000, respectively.

4. When leakage or boric acid residue is detected on components, theleakage source and/or areas of general corrosion shall be located.Components with local areas of general corrosion which reduce the wallthickness by more than 10% shall be evaluated to determine whether thecomponent may be acceptable for continued service, or whether repair orreplacement is required.

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D. Instrument Requirements

NOTE: The following instrument requirements are applicable ONLY when

performing system hydrostatic tests.

Any pressure measuring instrument or sensor, analog or digital, including thenormal operating system instrumentation may be used provided the followingrequirements are met.

1. Accuracy

The pressure measuring instrument or sensor used shall provide resultsaccurate to within 0.5% of full scale for analog gages and 0.5% over thecalibrated range for digital instruments.

2. Calibration

All pressure measuring instruments shall be calibrated against astandard deadweight tester or calibrated master gage. The gages shall becalibrated before each test or series of tests. A series of tests is agroup of tests that use the same pressure measuring instruments and thatare conducted within a period not exceeding 2 weeks.,

,3. Ranges

Analog gages shall have a graduated range of at least 1.5 times, but notmore than 4 times the intended maximum test pressures. Digital pressureinstruments shall be selected such that the intended maximum testpressure shall not exceed 70% of the calibrated range of the instrument.

4. Location

The pressure measuring instrument shall be connected close to thecomponent when testing an isolated component. When testing a group ofcomponents or system the instrument shall be connected to any point inthe boundary such that the imposed pressure on any component, includingstatic head, will not exceed 106% of the specified test pressure for thesystem.

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TX. RESPONSIBILITIES

1. Program Engineera. overall program ownershipb. Ensure program compliance with existing regulations and standardsC. Ownership of Site Standard Practice 8.05 "Pressure Test Program"d. Site contact for all system pressure testinge. Review and approve test resultsf. Ensure periodic tests are performed on scheduleg. Maintain a tracking system to ensure periodic system pressure tests

are scheduled and performed to meet periodic and interval systempressure testing requirements

2. Systema.b.c.

EngineersMaintain pres'sure test proceduresCoordinate test schedule with Operations and Outage Scheduling StaffProcure support and equipment needed to perform the pressure tests

3. Corporatea. Preparation and Maintenance of corporate standards.b. Interpretation of ASME Code requirements.C. Review requests for relief and program submittal.d. Perform periodic assessments of site code programs.

4. OthersPlant Operations - Perform valve and equipment alignments for tests.Instrument Maintenance - Perform calibration of test instrumentation.Mechanical Maintenance - Perform corrective repairs/replacement and

provide test support, as necessary.

0

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X. KNOWLEDGE AND TRAINING REQUIREMENTS

1. Program Engineera. Understanding of 10CFR50.55ac. Knowledge of ASME Section XI Code and related Code Casesc. Knowledge of ASME Section XI Code Inquiriesb. Knowledge of test instrumentation used to perform pressure testsc. Knowledge of industry standards and NRC positions

2. Test Performersa. Understanding of pressure test instructionsb. Knowledge of test instrumentation used to performc. Knowledge of ASME Section XI as it applies to the

of testing

pressure testsperformance

3. Inspection Personnela. VT-2 qualifications, orb. Code Case N-546 qualifications:

i) Minimum of 40 hours of plant walkdown experience,ii) Minimum of 4 hours of plant specific VT-2 visual examination

instruction, andiii) Visual test requirements of IWA-2321 (1995 Edition of

Section XI)



APPENDIX A

REQUESTS FOR RELIEF

Pursuant to 10CFR50.55a relief from the requirements of Section XI of the ASMEBoiler and Pressure Vessel Code may be granted by the regulatory authority. TVAwill request relief from the requirements of ASME Section XI for the following:

1. To propose alternatives to the code requirements which TVA hasdetermined results in unusual difficulty or hardship without acompensating increase in the level of quality or safety, inaccordance with paragraph 10CFR50.55a(a) (3) (ii),

2. When TVA has determined that a requirement of the Code isimpractical for Watts Bar Nuclear Plant Unit 1, in accordance withparagraph 10CFR50.55a(g) (4) (iv).


PAGE 19 1

REOUEST FOR RELIEF ISPT - 01

Subject:

Components:

CodeRequirement:

Basis forRelief:

AlternateTesting:

10-Year hydrostatic pressure test requirements for Class 1,2and 3 systems.

All Class 1, 2 and 3 piping systems which are applicable tothe hydrostatic pressure test requirements of ASME SectionXI.

A system hydrostatic pressure test (IWA-5211(d)) andaccompanying VT-2 examination is required at least once eachinspection interval (Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, Categories B-P, C-H, D-A, D-B, and D-C).

The performance'of a hydrostatic pressure test requires theremoval of large portions of the system from service, theover-torquing or blocking of boundary valves, the removal,or gagging, of system relief valves, the installation oftest pressure relief valves, and the purchase of specialhydrostatic pressure pumps and test gauges. A Section XIhydrostatic pressure test is conducted at 110 or 125% ofdesign pressure. This test pressure is only 25 to 40% abovenormal operating pressure for most code class class systems.Past experience in ASME Section XI system pressure tests atTVA's other two nuclear plants (Browns Ferry units 1, 2 and3 and Sequoyah units 1 and 2) has shown that this smallincrease in pressure has not enabled the detection of systemleakage that would not have been detected during a systeminservice or functional pressure test.

Significant effort and expense are incurred in theperformance of hydrostatic pressure tests in comparison tothe information obtaining during the test. The increase inthe level of quality and safety achieved in the performanceof these tests is not commensurate with the hardship to theplant.

The requirements of ASME Code Case N-498-1 will be followedin lieu of the requirement to perform periodic systemhydrostatic pressure tests on Code Class 1, 2 and 3 systems.

I ~~ASME SYSTEM PRESSURE TESTING PROGRAM BASIS DOCUMENT PG 0

REQUEST FOR RELIEF ISPT - 02

Subj ect:

Components:

CodeRequirements:

Basis forRelief:

AlternativeTesting:

Pressure test requirements for welded repairs or installationof replacement items by welding.

All Class 1, 2, and 3 components which receive welded repairsor are installed by welding as replacements.

After repairs by welding on the pressure retaining boundary,a system hydrostatic test shall be performed in accordancewith IWA-5000.

Class 1, 2, and 3 pressure boundary replacements requiringinstallation by welding are normally constructed and suppliedin accordance with the requirements of ASME Section III whichprovides for hydrostatic testing at the manufacturers.Subsequent to installation hydrostatic pressure testing is ameans of proving weld integrity. Performing NDE and invokingacceptance criteria in accordance with current ASME IIIrequirements in addition to a system leakage test providesreasonable assurance that weld integrity is maintained at anacceptable level of quality. It is WBN's position that theperformance of hydrostatic pressure tests subsequent to weldrepairs and the installation of welded replacements could notonly expose components to unnecessary stress levels, but is ahardship which provides little or no increase in the level ofquality or safety.

The alternative requirements of ASME Code Case N-416-1 shallbe used.




Subject: Bolting examination (VT-3) subsequentoccurring during a system pressure test.

Components:

CodeRequirements:

Basis forRelief:

to flange leakage

All bolting associated with Class 1, 2, and 3 boltedconnections which receive a visual examination (VT-2) duringthe performance of system pressure testing.

If leakage occurs at a bolted connection, the bolting shallbe removed, VT-3 visually examined for corrosion, andevaluated in accordance with IWA-3100. (IWA-5250(a) (2))

The 1989 Edition of Section XI requires that all bolting mustbe removed in the event of a bolted connection leak for thepurpose of VT-3 examination and evaluation. The 1990 Addendato the 1989 Edition of Section XI and later editions recognizethat the removal of all the bolting in the connection isunnecessary, if the bolt most affected by the leakage isexamined and found to be acceptable by the VT-3 examination.The requirement in the 1989 Edition could require placing theassociated component or portion of piping out of servicepossibly resulting in plant shutdown, delaying plant startup,or placing the plant in an unsafe condition for continuedoperation. Additionally, the removal of all bolting isunnecessary if the bolting material is of a specificationwhich is not susceptible to corrosion when in contact with theleaking fluid.

ASME Section XI inservice pressure tests are, as a rule,performed with the system inservice. In particular, the CodeClass 1 leakage test is performed as the unit is returning toservice following each refueling outage. For systems that areinservice in support of normal plant operation during testing,paragraph IWA-5250(a) (2) may require the system be taken outof service and depressurized to permit removal of one of thebolts for visual examination. For certain systems this couldrequire the unit to be removed from production dependent uponthe existing plant and equipment status.

Although removal and inspection of a fastener is necessary todetermine the full extent of corrosion, this may not benecessary to evaluate the structural integrity of theconnection. The structural integrity of the leakingconnection is dependent upon several factors including theamount of leakage and its duration, the corrosiveness of thefluid, the bolting and flange materials, the number of boltsand the number of these exposed to the fluid, and a visualevaluation of the connection for corrosion and material loss.

An engineering evaluation of the leak and affected mechanicalconnection can determine whether sufficient structuralintegrity exists in the connection and whether removal ofbolting for visual examination in compliance with paragraphIWA-5250(a) (2) can be deferred to the next system outagewithout a reduction in component safety margin.

REQUEST FOR RELIEF ISPT - 03 (continued)

The experience at other TVA nuclear plants, which have acombined total of over 40 years of nuclear unit operation,indicates that, although leaks and subsequent corrosion offasteners do occur at bolted connections, no failures offasteners has occurred prior to the detection of the leakageand its repair. This experience demonstrates that theconnections have been designed with sufficient safety marginto prevent the failure of bolted connections prior todetection of leakage. In addition to the Section XI inservicepressure test program, WBN utilizes a Borated Water CorrosionProgram and plant housekeeping procedures to identify systemleaks.

The requirement to immediately remove bolting from amechanical connection when evidence of leakage is detected cancreate a hardship on the plant by requiring system and evenplant shutdown. In view of past experience at TVA nuclearplants, the hardship invoked by this requirement is notcommensurate with the increase in the level of quality orsafety that is provided.

It is the position of WEN that the requirement of the 1989Edition of ASME Section XI to immediately remove bolting froma mechanical connection presents a hardship to the plantwithout providing a commensurate increase in the level ofsafety of quality.

AlternativeTesting: when evidence of leakage is discovered at a bolted connection

during a Section XI inservice pressure test, the connectionwill be evaluated for structural integrity using the followingfactors:

1. Size of leak2. Duration of leak3. Bolting and flange material4. visual evidence of corrosion with the connection

assembled5. Corrosive properties of the fluid6. Experience with similar bolting material in similar

environments7. Degradation of other components in the vicinity of the

leakage

When the engineering evaluation determines that the boltedconnection possesses sufficient structural integrity forcontinued operation, removal of the bolt may be deferred tothe next system outage of sufficient duration to allow thesystem to be removed from service and depressurized. Shouldthe engineering evaluation determine that sufficient integritydoes not exist in the connection for continued operation, thenthe bolt most affected by the leakage will be removed and VT-3examination.

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Subject:

Components:

CodeRequirement:

Basis forRelief:

AlternativeTesting:

Pressure testing of non-safety system process piping in acontainment penetration.

All Class 2 penetration piping where the inboard and outboardpiping outside the containment isolation valves is classifiedas non-safety related.

Pressure retaining components, piping and valves require asystem pressure test, inservice or functional (IWC-5221)and/or a system hydrostatic test (IWC-5222) in conjunctionwith a VT-2 visual examination (Table IWC-2500-l, Category C-H).

The portion of piping that penetrates containment and theassociated inboard and outboard containment isolation valvesare required to be constructed in accordance with Class 1 or2 design requirements. For non-safety systems the solefunction of the penetration and the associated isolationvalves are to provide containment isolation capability for theprotection of containment integrity during the event of a lossof the attached non-safety piping. In all cases the isolationvalves associated with these penetrations are maintainedduring normal operation in the locked closed position, orclose upon receipt of a containment isolation signal. Thesafety function of these penetrations is verified by 10CFR50Appendix J leakrate testing performed on all containmentisolation valves and penetrations at each refueling outage.

The performance of pressure testing, as required by Table IWC2500-1, Category C-H, is considered unnecessary in the sensethat there is minimal enhancement to quality or safetyresulting from the additional testing, and results inadditional personnel radiation exposure and outage costs. Itis the position of WEN that pressure testing of thesecontainment penetrations presents a hardship *to the plantwithout providing a commensurate increase in the level ofsafety of quality. The testing pursuant to 10CFR50 AppendixJ requirements provides an acceptable level of quality andsafety.

The alternative test requirements of ASME Code Case N-522shall be used.




Pressure testing of Class 1 components.

Components:

CodeRequirement:

Basis forRelief:

ASME Code Class 1 vents, drains, test and fill piping whichrange in diameter from 3/4 inch to 2 inches.

ASME Section XI, Subsection IWB-2500, Table IWB-2500-1,Category B-P, Footnote 2 states that "The pressure retainingboundary during the system hydrostatic test shall includeall Class 1 components within the system boundary."

Various piping segments are located in open-end tailpipesthat serve as vent, drain, test, or fill lines. ManualValves and flanges bound these piping segments to providethe design-required double isolation at the reactor coolantpressure boundary. These piping segments are not normallypressurized. Pressure testing of these piping segments atnominal operating pressure in Mode 3 would require that theinboard isolation valve be opened when the reactor coolantsystem (RCS) is at full temperature and pressure. Theaction would violate the design requirement for doubleisolation valve protection. The potential for spills whenopening the system presents a significant risk of personnelcontamination. Pressure testing in Mode 6 would requirethat a hydrostatic pump be connected at each segmentlocation. However, for some segments there is no connectionavailable and would require a modification for installationof a pump connection. These piping segments are located inhigh-radiation areas and testing would result in highpersonnel radiation exposure. A breakdown of the doseestimates for each radiation area in the plant is providedbelow:

1. RCS Loop Drains6 items at 10 person-hours per item at 300 mR/hour

2. Reactor2 items2 items

Vessel Head Ventsat 10 person-hours per item at 150 mR/hour andat 8 person-hours per item at 20 mR/hour.

3. Pressurizer Spray Vents2 items at 10 person-hours per item at 200 mR/hour.

4. Excess Letdown Drain1 item at 8 person-hour per item at 50 mR/hour.

5. RCS Seal Drains and Vents4 items at 8 person-hours per item at 20 mR/hour and4 items at 8 person-hour per item at 50 mR/hour

Subj ect:

TENNESSEE VALLEY AUTHORITY WATTIS BAR NUCLEAR PLANT PAGE 25

RSEVSYTE PRESSURE TESTING PROGRAM BASIS DOCUMENTI

REQUEST FOR RELIEF ISPT -05 (continued)

This results in a total of approximately 28 Rem of doseaccumulated in performing these tests. This data is basedon estimated durations and actual survey data from refuelingoutage 5 for units 1 and 2 at TVA's Sequoyah Nuclear Plantwhich is very similar in design to WBN. These radiationexposure estimates are based on the removal of blindflanges, the installation of test flanges and the connectionof a hydrostatic pump. Personnel would remain in the areato perform the test, disconnect the test equipment, andreinstall the blind flange.

These piping segments are visually inspected each refuelingoutage as the unit returns to operation. These segments arenot specifically pressurized past the first isolation valvefor this inspection. It is possible that the piping ispressurized because of leakage at the first isolation valve.With these inspection being performed approximately sixtimes in each inspection interval, the increase in safetyachieved from the required nominal operating pressure testis not commensurate with the hardship of performing suchtesting.

!AlternateTesting: These piping segments will continue to be visually inspected

following each refueling outage for leakage and evidence ofpast leakage during the RCS leakage test. This test isconducted with the RCS at full operating temperature andpressure.

TENNESSEE VALLEY AUTHORITY WATT~S BAR NUCLEAR PLANT PAGE 26I ~ASEESYSTEM PRESSURE TESTING PROGRAM BASIS DOCUMENTI

Subject:

Components:

CodeRequirement:

Basis forRelief:

AlternativeTesting:


Removal of Code Class 1 Bolted Connection Insulation for VT-2Examinations

All insulated pressure retaining bolted connections in CodeClass 1 systems which are borated for reactivity control.

For systems borated for the purpose of controlling reactivity,insulation shall be removed from the pressure retaining boltedconnections for visual examination VT-2. (IWA-5242(a), 1989Edition ASME Section XI)

The leakage test of Code Class 1 components is performed atthe completion of each refueling outage with the unit in hotstandby and the reactor coolant system at full temperature andpressure. The Section XI Code Class 1 leakage test isgenerally the final activity prior to unit restart followingthe refueling outage. Compliance with the Code requirementswould involve holding the unit in the hot standby mode aftercompletion of the VT-2 examination to allow replacement of thethermal insulation and removal of scaffolding. This situationplaces a hardship on the plant for the following reasons:

1. Entering containment to replace thermal insulation andto remove scaffolding when the unit is at fulltemperature, jeopardizes the safety of personnel due toheat stress and the potential for burns resulting fromcontact with hot components.

2. Insulation replacement activities require holding theunit in hot standby mode until all work is completed andall personnel have exited containment. These activitieswill delay the return of the unit to production forseveral hours.

The purpose of removing insulation from pressure retainingbolting for visual examination is to inspect for borated waterleakage that could cause corrosion of the bolting. Due to thedeposits of boron crystals that remain where borated waterleakage occurs, it is not necessary to actually see the fluidleakage in order to determine where leakage has occurred.Therefore, borated water leakage inspections can beeffectively performed when the system is depressurized. Forthis reason thd hardships resulting from Code compliance arenot commensurate with the increase in safety, or qualityachieved.

The alternative test requirements of ASME Code Case N-533 willbe performed. The insulation on code class 1 boltedconnections will be removed for VT-2 examinations at eachrefueling outage.


Subject:

Components:

CodeRequirement:

Basis forRelief:

AlternativeTesting:

Alternative Requirements for Qualification of VT-2 ExaminationPersonnel

All pressure retaining Code Class 1, 2 and 3 componentssubject to inservice pressure tests

Personnel performing nondestructive examination (NDE) shall bequalified and certified using a written practice prepared inaccordance with SNT-TC-IA and the additional requirements ofthis Division. (IWA-2310, 1989 Edition ASME Section XI)

The VT-2 examination performed in conjunction with a SectionXI pressure test consists of a visual inspection of componentsand surrounding surfaces for leakage and evidence of leakagefrom the pressure retaining components per IWA-2212. Themethods to be used in the performance of the inspection arefound in IWA-5240. To adequately perform these visualinspections, personnel must possess the following:

1) Knowledge and understanding of the methods of inspectionto be used for Section XI visual inspections as definedin IWA-5240.

2) Knowledge of plant systems and familiarization withsystem walkdown procedures.

3) Good visual perception.

Personnel possessing this knowledge, experience and visualacuity will be fully able to perform the VT-2 examinationsduring system pressure test conditions. These attributes areeasily attained by plant system engineers and operationpersonnel who perform daily and weekly walkdowns of plantsystems as part of their normal responsibilities. Theadditional requirements for the qualification andcertification of personnel to SNT-TC-lA are not necessary toperform these VT-2 examinations.

It is WBN's position that the additional cost of qualificationand certification of personnel to SNT-TC-lA is a hardship tothe plant which does not provide a commensurate increase inquality or safety.

The alternative qualification requirements of ASME Code CaseN-546 shall be used.

TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT PAGE 22I ASMESYSTEM PRESSURE TESTING PROGRAM BASIS DOCUMENTI

APPENDIX B

INITIAL PRESSURE TEST SCHEDULE

INITIAL PRESSURE TEST SCHEDULE

BOUNDARY TYPE OF PRESSURE TEST

1 st 2nd 3rdPERIOD PERIOD PERIOD

1 47W801-1 2 Main Steam system piping and Code Case Inservice Inservice47W803-2 components described below (excluding N-498

S/Gs): hydro test* From Steam Gen. 1 to FCV-1-4, 15, alternative

147, PCV-1-5, 1-522, 523, 524, 525,526, 537, 542.

* 'From Steam Gen. 2 to FCV-1 -11,148PCV-1 -12, and 1-517, 518, 519, 520,521, 535, 541.

* From Steam Gen. 3 to FCV-1 -22,149, PCV-1-23, and 1-512, 513, 514,515, 516, 532, 540.

* From Steam Gen. 4 to FCV-1 -16,FCV-1 -29, PCV-1 -30 and 1-527, 528,529, 530, 531,539, 543.

47W803-2 2 and 3 Main Steam supply to Turbine Driven Inservice Inservice Code Case47W803-3 Auxiliary Feed Water Pump terry turbine N-498

as described below: (Class 2)* From FCV-1-15 and FCV-1-16 or N-498-1

through TDAFW Pump A-S terry (Class 3)turbine to roof exhaust and steam hydro testtraps at drain tank. alternative

47W801-2 2 Steam Generator Blowdown system Code Case Inservice Inservicepiping and components described below: N-498* From Steam Gen. 1 (including hydro test

sample line) to FCV-1-7 alternative* From Steam Gen. 2 to FCV-1 -14* From Steam Gen. 3 to FCV-1 -25* From Steam Gen. 4 to FCV-1 -32

3 47W803-1 2 Main Feed Water system piping and Code Case Inservice Inservice47W803-2 components described below (including N-498

S/G shell and bypass piping): hydro test* From Steam Gen. 1 to Turbine Bldg alternative

flued head and 3-832, 873.* From Steam Gen. 2 to Turbine Bldg

flued head and 3-922.* From Steam Gen. 3 to Turbine Bldg

flued head and 3-921.* From Steam Gen. 4 to Turbine Bldg

flued head and 3-833, 874.

SYSTEM

DRAWING ASMECLASS


BOUNDAHY TYPE OF PRESSURE TEST

1st 2nd 3rdPERIOD PERIOD PERIOD

3 47W803-2 2 Auxiliary Feed Water system piping and Code Case Functional Functionalcomponents as described below: N-498* Normally isolated Class 2 portion of hydro test

AFW to Steam Generator 2. From 3- alternative831 and 3-872 to 3-922.

* Normally isolated Class 2 portion ofAFW to Steam Generator 3. From 3-830 and 3-871 to 3-921.

3 47W803-2 3 Auxiliary Feed Water system piping and Functional Functional Code Casecomponents as described below: N-498-1* From 3-805 through MDAFW Pump hydro test

A-A to 3-831 and 3-832. alternative* From 3-806 through MDAFW Pump

B-B to 3-830 and 3-833.* From 3-810 through TDAFW Pump A-

S to 3-871, 3-872, 3-873 and 3-87426 47W850-9 2 and 3 Fire Protection system piping and Code Case Code Case Code Case

47W850-13 components as described below: N-522 N-522 N-522* Portion of system penetrating App. J test App. J test App. J test

containment from FCV-26-240 to 26- alternaltiye alternative alternative1260, FCV-26-243 to 26-1296.

26 47W850-13 3 Fire Protection system piping and No- I Notcomponents as described below: Required1 Required1 Required1

* Header piping that serves as AFWsupply during flood mode.

31 47W865-5 2 Reactor Building Instrument Room Chilled Code Case Code Case Code CaseWater system piping and components as N-522 N-522 N-522described below: App. J test App. J test App. J test* Portion of system penetrating alternative alternative alternative

containment from FCV-31-305 toFCV-31-306 and 31-3421.

* Portion of system penetratingcontainment from FCV-31-308 toFCV-31-309 and 31-3407.



'These components are not included in Examination Categories D-A, D-B or D-C.

StSYSTEM

UHAWINU

PAGE3 1

AWMLCLASS



VQ I rl AAIIkIA1 'K A IT -Jf% IIllr A A I IVIir ',M0IVIr

CLASS'UU EJIi1 l I TE • r PRESSURE TEST


31 47W865-3 3 Main Control Room Chilled Water system Inservice Code Case nsriepiping and components as described N-498-1below: hydro test* From Pump A-A, Water Chiller alternative

Package A-A and Air Handling Units1A-A and 2A-A to pump suction.

* From CW Pump B-B, Water ChillerPackage B-B and Air Handling Units1 B-B and 2B-B to pump suction.

31 47W865-8 3 Shutdown Board Rooms Chilled'Water Inservice Inservice Code Casesystem piping and components as N-498-1described below: hydro test* From CW Pump A-A, Water Chiller alternative

Package A-A and Air Handling Unit topump suction.

* From CW Pump B-B, Water ChillerPackage B-B and Air Handling Unit topump suction.

31 47W865-7 3 Electric Board Room Chilled Water Code Case Inservice Inservicesystem piping and components as N-498-1described below: hydro test* From CW Pump A-A, Water Chiller alternative

Package A-A and Air Handling Unit topump suction.

* From CW Pump B-B, Water ChillerPackage B-B and Air Handling Unit topump suction.

43 47W625-7 2 Containment Penetrations X-23, 28, 85A, C Code Case Code Case47W625-11 86A, 86B, 86C, 92A, 92B, 99, 100 and N-522 N-522 N-52247W625-15 105. App. J test App. J test App. J test

alternative alternative alternative59 47W856-1 2 Demineralized Water system piping and Code Case Code Case Code Case

components as described below: N-522 N-522 N-522* Portion of system penetrating App. J test App. J test App. J test

containment from 59-522 to 59-698. alternative alternative alternative

ITETEM

Ui'•/'• VV I I•1 •1

TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT PAGE 321ASME SYSTEM PRESSURE TESTING PROGRAM BASIS DOCUMENTREV 0

SYS DRAWING ASME BOUNDARY TYPE OF PRESSURE TESTTEM CLASS


61 47W814-2 Ice Condenser system piping and C Code Case Code Casecomponents as described below: N-522 N-522 N-522* Portion of system penetrating App. J test App. J test App. J test

containment from FCV-61-191 to alternative alternative alternativeFCV-61-192 and 61-532, 533.

* Portion of system penetratingcontainment from FCV-61-193 toFCV-61-194 and 61-680, 681.

* Portion of system penetratingcontainment from FCV-61-96 to FCV-61-97 and 61-691, 692.

* Portion of system penetratingcontainment from FCV-61 -110 toFCV-61-122 and 61-745, 746.

62 47W809-1 2 Chemical and Volume Control system Code Inservice Inservice47W81 1-1 piping and components as described Case N-47W813-1 below: 498

* Letdown line from FCV-62-70 through hydro testRegenerative Hx, Letdown Hx (TCV- alternative62-79 and LCV-62-118 aligned toVCT) and VCT to charging pumpsuction header.

* Excess letdown from Loop 3 andRCP seal return line from RCP sealsthrough Seal Water Hx to connectionto charging pump suction header.

* Charging pump suction header.* From charging pumps suction header

through Centrifugal Charging PumpsA-A and B-B and PositiveDisplacement Pump C (includingminiflow line) to seal injection checkvalves 62-560, 561, 562 and 563,charging check valves 62-659 and660, pressurizer spray isolation valve62-84 and high head safety injectionvalves FCV-63-39 and FCV-63-40.

62 47W809-2 3 Chemical and Volume Control system Inservice Code Case Inservice47W809-5 piping and components as follows: N-498-1

* Boric Acid Tanks A, B and C through hydro testBoric Acid Transfer Pumps and Boric alternativeAcid Blender to FCV-62-138, 62-929,62-935, 62-936 and FCV-62-144.



~. ... rOUUNUAKY IYr U F PRESSURE TEST


62 47W809-1 3 Chemical and Volume Control system Not Not Nt47W809-2 piping and components as described Required' Required' Required'47W809-3 below:47W809-5 * From TCV-62-79 through Mixed Bed47W809-7 Demineralizers A and B and Cation47W811-1 Bed Demineralizer to 62-1075 (in

return line to Reactor Coolant Filter).* From LCV-62-118 (and various other

inputs) through Holdup Tanks A andB, Holdup tank Recirculation Pumpand Gas Stripper Pumps A, B and C.

• Flood mode boration.

Safety Injection system piping andcomponents as described below:* High head safety injection line from

FCV-63-39 and FCV-63-40 to RCSClass 1/2 boundary valve 63-581.

* From FCV-63-5, FCV-63-6 and FCV-63-7 and FCV-63-11 through SafetyInjection Pumps A-A and B-B(including miniflow to FCV-63-3) toRCS Class 1/2 boundary valves 63-543, 63-545, 63-546, 63-548, 63-553and 63-555.

* Cold Leg Accumulators 1 through 4 toRCS Class 1/2 boundary valves 63-622, 63-623, 63-624 and 63-625.

* Low head safety injection lines (RHR)INSIDE containment.

-unctional I Functional Lode UaseN-498

hydro testalternative

1These components are not included in Examination Categories D-A, D-B or D-C.

TYMTEM

UKAWIINU AbIL

CLASS

47W81 1-1

I' 7 I If I ta.. rT W T -p.. .DUUNUAMY TYPE OF PRESSURE TEST


63 47W81 1-1 2 Safety Injection system piping and Inservice Inservice Code Case47W812-1 components as described below: N-49847W830-1 * Refueling Water Storage Tank and hydro test47W809-1 piping to first normally closed valve alternative

(i.e., HCV-74-34) and CVCS, SIS,RHR, and CS pump suction isolationvalves LCV-62-135, 136, FCV-63-1,5, FCV-72-21, 22, FCV-74-3, 21.

67 47W845-1 2 and 3 Essential Raw Cooling Water system Inservice Inservice Code Case47W845-2 piping and components as described N-49847W845-3 below (Class 2 only at containment (Class 2)47W845-4 penetrations): or N-498-147W845-5 * ERCW Screen Wash Pumps 1A-A, (Class 3)47W845-6 1 B-B, 2B-B and 2A-A to associated hydro test

traveling screens. alternative• ERCW Pumps A-A, B-A, C-A and D-A

through Train A supply header,associated heat exchangers (exceptContainment Spray Hx), coolers, andTrain A discharge header.

* ERCW Pumps E-B, F-B, G-B and H-Bthrough Train B supply header,associated heat exchangers (exceptContainment Spray Hx), coolers, andTrain B discharge header.

67 47W845-2 3 Essential Raw Cooling Water system Functional Functional e Casepiping and components as described N-498-1below: hydro test* Containment Spray Heat Exhangers A alternative

and B.* Normally closed ERCW supply to

MDAFW Pumps A-A (FCV-3-116A toFCV-3-116B) and B-B (FCV-3-126Ato FCV-3-126B).

* Normally closed ERCW supply toTDAFW Pump A-S (FCV-3-136A toFCV-3-136B and FCV-3-179A toFCV-3-179B).

TEMU iM YV I NU U AM"li

CLASS

I

7---



IiUUNUAHY TYPE OF PRESSURE TEST


68 47W813-1 1 Reactor Coolant system piping and Leakage Leakage ge47W809-1 components as described below: every RFO every RFO every RFO47W810-1 * All Class 1 piping and components. and47W811-1 Code Case

N-498hydro testalternative

70 47W859-2 2 Component Cooling system piping and Inservice Inservice Code Casecomponents as described below): N-498* From FCV-70-143 through Excess hydro test

Letdown Hx to FCV-70-85. alternative70 47W859-1 2 and 3 Component Cooling system piping and Inservice Code Case Inservice

47W859-2 components as described below (Class 2 N-49847W859-3 only at containment penetrations): (Class 2)47W859-4 * CCS Pumps A-A and B-B through or N-498-1

Train A supply header, associated (Class 3)heat exchangers (except Excess hydro testLetdown Hx), coolers, Surge Tank, alternativeThermal Barrier Booster Pumps andTrain A return header to CCS pumps.

CCS Pump C-S through Train B

supply header, associated heatexchangers, coolers, Surge Tank andTrain B return header to CCS pumps.

70 47W859-1 3 Component Cooling system piping and Functional Code Case Functionalcomponents as described below: N-498-1* Piping between normally closed valve hydro test

pairs on the CCS pump discharge alternativeheader and CCS heat exchangerdischarge header.

72 47W812-1 2 Containment Spray system piping and Not Not Hydrostaticcomponents as described below: Required2 Required2 (unimpaired• Containment Spray ring headers from flow

FCV-72-39 and FCV-72-2 to spray method)nozzles and RHR Spray ring headersfrom FCV-72-41 and FCV-72-40 tospray nozzles.

2Exempted by Footnote 1 to Table IWC-2500-1, Examination Category C-H.

TEMUHAWINU ASMh

CLASS



72 47W812-1 2 Containment Spray system piping and Code Case Functional Functionalcomponents as described below: N-498* From FCV-72-22 and FCV-72-44 hydro test

through CS Pump A-A and CS Heat alternativeExchanger A-A to FCV-72-39.

* From FCV-72-45 and FCV-72-21through CS Pump B-B and CS HeatExchanger B-B to FCV-72-2.

74 47W810-1 2 Residual Heat Removal system piping Not Not I F~ Hydrostatic47W81 1-1 and components as described below: Required2 Required 2 (visual

* Containment sump including piping unimpairedand components to first isolation flowvalve FCV-63-72 and FCV-63-73. method)

74 47W809-1 2 Residual Heat Removal system piping Code Case Functional Functional47W810-1 and components as described below: N-49847W81 1-1 * From FCV-63-1, FCV-63-72, FCV-63- hydro test47W812-1 73, FCV-72-45, FCV-72-44 and FCV- alternative

74-21 through RHR Pump A-A andRHR Heat Exchanger A-A to HCV-74-34, FCV-74-28, FCV-72-40, FCV-63-8, FCV-63-11 hot leg injection linecontainment penetration and cold leginjection lines containmentpenetrations.

* From FCV-74-24 through RHR PumpB-B and RHR Heat Exchanger B-B toFCV-74-28, FCV-72-41 and FCV-63-11.

* Normally isolated piping in the heatexchanger bypass line from HCV-74-32 to HCV-74-36 and HCV-74-37.

* Normally isolated piping in the RHRcleanup line from 74-530 and 74-531to FCV-62-83.

77 47W809-7 2 Waste Disposal system piping and Code Case Code Case Code Case47W830-1 components as described below: N-522 N-522 N-522

* Portion of system penetrating App. J test App. J test App. J testcontainment from FCV-77-9 to FCV- alternative alternative alternative77-10 and 84-530.

2Exempted by Footnote 1 to Table IWC-2500-1, Examination Category C-H.

SYSTEM

DKAWINU ASMECLASS



77 47W851-1 2 Floor and Equipment Drains system Code Case Code Casepiping and components as described N-522 N-522 N-522below: App. J test App. J test App. J test* Portion of system penetrating alternative alternative alternative

containment from FCV-77-127 toFCV-77-128.

77 47W851-1 3 Floor and Equipment Drains system Unimpaired Unimpaired Unimpairedpiping and components as described Flow Test Flow Test Flow Testbelow:* From Elevation 716' drain through

the Crane Wall.78 47W855-1 3 Spent Fuel Pool Cooling system piping Inservice Inservice Code Case

and components as described below: N-498-1* From Spent Fuel Pool suction hydro test

strainers through Spent Fuel Pit alternativePumps, Spent Fuel Pit HeatExchangers and Demineralize toSpent Fuel Pit discharge diffuser.

78 47W855-1 2 Spent Fuel Pool Cooling system piping Code Case Code Case Code Caseand components as described below: N-522 N-522 N-522* Portion of system penetrating App. J test App. J test App. J test

containment from 78-557 to 78-558. alternative alternative alternative* Portion of system penetrating

containment from 78-560 to 78-561.81 47W819-1 2 Primary Water system piping and Code Case Code Case Code Case

components as described below: N-522 N-522 N-522* Portion of system penetrating App. J test App. J test App. J test

containment from FCV-81-12 to 81- alternative alternative alternative502.

SYSTEM

DRAWING ASMECLASS

Enclosure 3STEAM GENERATOR PROGRAM

TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR …Pressure Test Program and all applicable plant...

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