HNP-05-130, Relief Requests No 2R1-016 Request for Relief from Inservice Inspection Requirements for Pressure Retaining Dissimilar Metal Welds and No 2R1-017 Request for Relief from Inservice Inspection Program Requirements for Reactor Vessel..
| ML053290159 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/16/2005 |
| From: | Kamilaris C Progress Energy Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| HNP-05-130 | |
| Download: ML053290159 (11) | |
Text
Progress Energy Serial: HNP-05-130 NOV 1 6 2005 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUESTS NO 2R1 -016 REQUEST FOR RELIEF FROM INSERVICE INSPECTION REQUIREMENTS FOR PRESSURE RETAINING DISSIMILAR METAL WELDS AND NO 2R1 -017 REQUEST FOR RELIEF FROM INSERVICE INSPECTION PROGRAM REQUIREMENTS FOR REACTOR VESSEL SHELL TO FLANGE WELD.
Ladies and Gentlemen:
In accordance with the Code of Federal Regulations, Title 10, Part 50.55a, "Codes and Standards," paragraph (a)(3)(i), the Harris Nuclear Plant (HNP) of Carolina Power and Light Company (CP&L) doing business as Progress Energy Carolinas, Inc., requests relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, 'Rules for Inservice Inspection of Nuclear Power Plant Components," requirements for the examination of the reactor pressure vessel (RPV) and connecting loop piping welds for the second 10-year interval of HNP's Inservice Inspection (ISI) Program. provides 10 CFR 50.55a Relief Request 2R1-016 to the HNP Second Interval ISI Program. It requests an alternative to the qualification requirements of ASME Section Xl Appendix VIII, Supplement 10 for supporting examination of dissimilar metal piping welds. provides 10 CFR 50.55a Relief Request 2R1 -017 to the HNP Second Interval ISI Program. It would allow the use of a Performance Demonstration Initiative (PDI-qualified procedure to complete the ultrasonic examination of the RPV shell-to-flange weld from the vessel inside diameter surface in accordance with Appendix Vil, Supplements 4 and 6 in lieu of ASME Section V, Article 4 (as directed by ASME Section Xl, 1989 Edition, Subsection IWA-2232 and Appendix I, Subparagraph 1-2100).
Attachments 1 and 2 provide detailed descriptions of these proposed alternatives including bases for relief. HNP has concluded that the proposed alternatives provide an acceptable level of quality and safety, and that compliance with the specified Code requirements would result in unnecessary hardship without a compensating increase in the level of quality and safety. HNP requests approval of these relief requests, pursuant to 10 CFR 50.55a(a)(3).
Progress Energy Carolinas, Inc.
Harris Nuclear Plant P.0. Box 165 New Hill, NC 27562
HNP-05-1 30 Page 2 HNP requests approval of these relief requests by March 8, 2006 to support planning activities associated with Refueling Outage (RFO) 13 scheduled for the spring of 2006.
This document contains no new Regulatory Commitments.
Please refer any questions regarding this submittal to Mr. Dave Corlett at (919) 362-3137.
Sincerely, C S. oa-L k-C.S. Kamilaris Manager, Site Support Services CSK/khv c:
Mr. R.A. Musser, NRC Sr. Resident Inspector Mr. C. P.Patel, NRC Project Manager Dr. W. D.Travers, NRC Regional Administrator
Attachment 1 to HNP Serial No. HNP-05-130 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST NO 2R11-016 REQUEST FOR RELIEF FROM INSERVICE INSPECTION REQUIREMENTS FOR PRESSURE RETAINING DISSIMILAR METAL WELDS SYSTEMICOMPONENT (S) FOR WHICH ALTERNATIVE IS REQUESTED ASME Category B-F Pressure Retaining Dissimilar Metal Welds, Item No. B5.10 Nozzle-to-Safe End Butt Welds.
DISSIMILAR WELDS CODE CATEGORY B-F Inside Minimum Description Weld No. Diameter Thickness Base Material Weld Safe-end to Loop A II-RV-OOlRVNOZAI-N- 29" 2.33" SA508/SA376 82/182 RPV Inlet Nozzle OISE Safe-end to Loop A ll-RV-OO1RVNOZAO- 27.5" 2.21" SA508/SA351 82/182 RPV Outlet Nozzle N-06SE Safe-end to Loop B ll-RV-OOlRVNOZBI-N- 29" 2.33" SA508/SA376 82/182 RPV Inlet Nozzle 03SE Safe-end to Loop B II-RV-OO1RVNOZAO- 27.5" 2.21" SA508/SA351 82/182 RPV Outlet Nozzle N-02SE Safe-end to Loop C II-RV-OOIRVNOZCI-N- 29" 2.33" SA508/SA376 82/182 RPV Inlet Nozzle 05SE Safe-end to Loop C H-RV-OOIRVNOZAO- 27.5" 2.21" SA508/SA351 82/182 RPV Outlet Nozzle N-04SE APPLICABLE CODE EDITION AND ADDENDA.
The applicable Codes are as follows:
Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition, No Addenda, Examination Category B-F, Pressure Retaining Dissimilar Metal Welds. Code Item B5.10, Figures IWB-2500-8.
10 CFR 50.55a(g)(6)(ii)(C) requires implementation of the ASME Code,Section XI, 1995 Edition, 1996 Addenda, with an expedited implementation for Appendix VIII ultrasonic examinations.
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Attachment 1 to HNP Serial No. HNP-05-130 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST NO 2R1-016 REQUEST FOR RELIEF FROM INSERVICE INSPECTION REQUIREMENTS FOR PRESSURE RETAINING DISSIMILAR METAL WELDS APPLICABLE CODE REQUIREMENT ASME Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10, para. 3.2(b) states that the examination procedures, equipment and personnel are qualified for depth sizing when the root mean square (RMS) error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125-inch.
REASON FOR REQUEST This relief is requested to allow the use of an alternative RMS value when depth sizing flaws that may be found during examination of the reactor vessel nozzle to pipe welds from the inside surface. Paragraph 3.2(b) of Supplement 10 requires that the examination procedures, equipment, and personnel are qualified for depth sizing when the root mean square (RMS) error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125-inch.
Currently there are no procedures, equipment or personnel qualified for depth sizing with an RMS less than or equal to 0.125-inch.
HNP would apply this alternative to Supplement 10 in conjunction with HNP's previously approved request for relief, Requests for Relief from ASME Code,Section XI, Appendix VIII, Supplement 10, "Qualification Requirements for Dissimilar Metal Piping Welds" dated December 5, 2003. Also refer to Safety Evaluation for Shearon Harris Nuclear Power Plant, Unit 1, (HNP) Relief Request - ASME Code Section XI, Appendix VIII, Supplement 10 (TAC No.
MC1638) dated May 3, 2004.
PROPOSED ALTERNATIVE AND BASIS FOR USE In accordance with 10 CFR 50.55a(a)(3)(i), in lieu of the requirements of the ASME Code,Section XI, 1995 Edition with 1996 Addenda, Appendix VII, Supplement 10, Paragraph 3.2(b) the proposed alternative discussed below shall be used. Compliance with the proposed alternative will provide an adequate level of quality and safety for examination of the affected welds.
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Attachment 1 to HNP Serial No. HNP-05-130 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST NO 2R1-016 REQUEST FOR RELIEF FROM INSERVICE INSPECTION REQUIREMENTS FOR PRESSURE RETAINING DISSIMILAR METAL WELDS The proposed alternative for depth sizing of flaws that may be found during examination is to add to the measured flaw size the difference between the achieved sizing error and the 0.125-inch RMS acceptance tolerance. Westinghouse Procedure, PDI-ISI-254-SE; Revision I Remote Inservice Examination of Reactor Vessel Nozzle to Safe End, Nozzle to Pipe and Safe End to Pipe Welds, has a demonstrated RMS depth sizing error of 0.189-inch. Any flaws that may be found during the examination will be evaluated by adding the difference between the 0.189-inch and the 0.125-inch to the measured flaw size.
For demonstrations performed from the inside surface personnel have been unsuccessful at achieving the 0.125-inch RMS depth sizing criterion. At this time achieving the 0.125-inch RMS appears to be impractical. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Additionally HNP proposes to use Eddy Current examination (ET) techniques to provide examination coverage in areas of complex geometry where UT may be limited. An enhanced visual examination will also be performed in conjunction with the ET to help discriminate between relevant indications and non-relevant indications.
ALTERNATE EXAMINATIONS The automated weld examinations from the nozzle inside diameter shall be performed using a qualified procedure in accordance with ASME Code,Section XI, Div. 1, 1995 Edition with 1996 Addenda, Appendix VIII, Supplement 10 as amended by the Federal Register Notice 64FR 51370 through 51400, dated September 22, 1999. All other ASME Section XI Code requirements for which relief is not specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
The Appendix VIII criteria were developed to ensure the effectiveness of UT examinations within the nuclear industry by means of a rigorous, item-specific performance demonstration. The performance demonstration was conducted on mockups containing flaws of various sizes and locations. The demonstration established the capability of equipment, procedures, and personnel to find flaws that could be detrimental to the integrity of the weld. The performance demonstration showed that the proposed UT technique is equal to or surpasses the requirements of the Code. Therefore, there is reasonable assurance that the proposed alternative provides an acceptable level of quality and safety.
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Attachment 1 to HNP Serial No. HNP-05-130 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST NO 2R1-016 REQUEST FOR RELIEF FROM INSERVICE INSPECTION REQUIREMENTS FOR PRESSURE RETAINING DISSIMILAR METAL WELDS DURATION OF PROPOSED ALTERNATIVE:
The proposed alternative is requested for the duration of the second inservice inspection interval.
PRECEDENTS The NRC has granted similar relief to the Virgil C. Summer Nuclear Station.
Reference:
SCE&G Letter to NRC (Document Control Desk), RC-03-0199, dated September 17, 2003, Resubmittal of Request to Use Alternatives to ASME Boiler and Pressure Vessel Code,Section XI. (0-C-03-0262) RR-11-20 and RR-II-21 and the associated NRC Safety Evaluation, letter from John A. Nakoski to Mr. Stephen A. Byrne (South Carolina Electric & Gas Company) dated February 3, 2004;
Subject:
Virgil C. Summer Nuclear Station - Second 10-Year Inservice Inspection, Request for Relief RR-II-20, RR-11-20 Addenda and RR-II-21 (TAC NO. MC0108)
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Attachment 2 to HNP Serial No. HNP-05-130 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST NO 2R1 -017 REQUEST FOR RELIEF FROM INSERVICE INSPECTION PROGRAM REQUIREMENTS FOR REACTOR VESSEL SHELL TO FLANGE WELD SYSTEM/COMPONENT (S) FOR WHICH ALTERNATIVE IS REQUESTED ASME Category B-A Pressure Retaining Welds in Reactor Vessel, Item No. B 1.30 Shell to Flange weld.
WeldNo.: II-RV-OOlFTSW-RV-OlFA,B,C APPLICABLE CODE EDITION AND ADDENDA.
The applicable requirements are as follows:
Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition, No Addenda, Examination Category B-A, Pressure Retaining Welds in Reactor Pressure Vessel.
Code Item B1.30, Figures IWB-2500-4.
10 CFR 50.55a(g)(6)(ii)(C) requires implementation of the ASME Code,Section XI, 1995, Edition, 1996 Addenda, with an expedited implementation for Appendix VIII ultrasonic examinations.
APPLICABLE CODE REQUIREMENT ASME Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, No Addenda, Subsection IWA-2232 and Appendix I, Subparagraph 1-2100, requires ultrasonic testing (UT) examination of the RPV shell-to-flange weld to be in accordance with ASME Code,Section V,Article 4. In addition, HNP has committed to follow Regulatory Guide 1.150, "Ultrasonic Testing of Reactor Vessel Welds during Preservice and Inservice Examinations," which augments the UT examination of the RPV welds.
REASON FOR REQUEST ASME Section XI Article 1 requires that HNP performs inservice examination of the RPV shell-to-flange weld in accordance the requirements of ASME Section V Article 4.
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Attachment 2 to HNP Seral No. HNP-05-130 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST NO 2R1-017 REQUEST FOR RELIEF FROM INSERVICE INSPECTION PROGRAM REQUIREMENTS FOR REACTOR VESSEL SHELL TO FLANGE WELD 10 CFR 50.55 a(g)(6)(ii)(C) Codes and Standards requires that ASME Section XI, Appendix VIII, Supplement 4, "Qualification Requirements for the Clad/Base Metal Interface of Reactor Vessel," and Supplement 6, "Qualification Requirements for Reactor Vessel Welds Other Than Clad/Base Metal Interface," be implemented for most RPV welds by November 22, 2000. The RPV shell-to-flange and closure head-to-flange are not required to be conducted in accordance with Appendix VIII.
This relief is requested to allow the use of a Performance Demonstration Initiative (PDI) qualified procedure to complete the UT examination of the RPV shell-to-flange weld from the vessel ID surface of the weld in accordance with ASME Section XI, Div. 1, 1995 Edition through the 1996 Addenda, Appendix VIII Supplements 4 and 6 as amended by 10 CFR 50.55a in lieu of ASME Section V,Article 4.
PROPOSED ALTERNATIVE AND BASIS FOR USE During the upcoming ten (10) year RPV weld examinations, HNP will be employing personnel, procedures and equipment that are demonstrated and qualified by a PDI and in accordance with ASME Section XI, Div. 1, 1995 Edition with 1996 Addenda, Appendix VIII, Supplements 4 and 6 as amended by the Federal Register Notice 64 FR 51370 through 51400, dated September 22, 1999 for applicable RPV welds.
The remote examinations will be performed using the Westinghouse UT data acquisition system in accordance with a PDI qualified procedure. The Westinghouse procedure PDI-ISI-254, "Remote Inservice Examination of Reactor Vessel Shell Welds," in accordance with ASME Section XI, Appendix VIII, Supplements 4 and 6, was demonstrated at the PDI qualification session in 2001 (Performance Demonstration Qualification Sheet (PDQS) No. 407). The procedure complies with ASME Section XI, Appendix VIII, 1995 Edition with 1996 Addenda as modified by the final rule.
Appendix VIII was developed to ensure the effectiveness of UT examinations within the nuclear industry by means of a rigorous, item-specific performance demonstration. The performance demonstration was conducted on a RPV mockup containing flaws of various sizes and locations.
The demonstration established the capability of equipment, procedures, and personnel to find flaws that could be detrimental to the integrity of the RPV.
Although Appendix VIII is not a requirement for this weld, the qualification process to Appendix VIII criteria demonstrates that the examination and evaluation techniques are equal to or surpass the requirements of paragraph IWA-2232 and Appendix I subparagraph 1-2100 of Section XI of the ASME Code and the guidance in RG 1.150.
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Attachment 2 to HNP Seral No. HNP-05-130 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST NO 2R1-017 REQUEST FOR RELIEF FROM INSERVICE INSPECTION PROGRAM REQUIREMENTS FOR REACTOR VESSEL SHELL TO FLANGE WELD A comparison between the ASME Code,Section V,Article 4 based UT methods and the procedures developed to satisfy the PDI/Appendix VIII can be best described as a comparison between a compliance-based procedure (ASME Code,Section V,Article 4) and a results-based procedure (PDl Appendix VIII). ASME Code,Section V procedures use an amplitude-based technique and a known reflector. The proposed alternate UT method was established independently from the acceptance standards for flaw size found in ASME Code,Section XI.
The PDI qualified sizing method is considered more accurate than the method used in ASME Code,Section V,Article 4. The proposed alternate UT examination technique provides an acceptable level of quality and examination repeatability as compared to the Article 4 requirements.
The PDI Program's PDQS No. 407 attests that Westinghouse procedure PDI-ISI-254 is in compliance with the detection and sizing tolerance requirements of Appendix VIII. The PDI qualification method is based on a group of samples, which validate the acceptable flaw sizes in ASME Section XI. The sensitivity to detect these flaws is considered to be equal to or greater than the sensitivity obtained through ASME Section V Article 4 because the Westinghouse procedure PDI-ISI-254 relies on a smaller scan index and a higher scan sensitivity for the detection of the UT signals.
The examination and sizing procedure uses echo-dynamic motion and tip diffraction characteristics of the flaw instead of the amplitude characteristics required byASME Code,Section V, Article 4. The search units interrogate the same examination volume as depicted by ASME Code,Section XI, Figure IWB 2500-4, "Shell-to-Flange Weld Joint."
The use of procedures for satisfying the requirements of ASME Code,Section V, Article 4 for the UT examination of the RPV-to-flange weld from the vessel shell has not received the same qualifications as a PDI qualified procedure.
The PDI qualification specimens are curved vessel shell plate sections and do not have taper transition geometry. However, the procedure is used to examine reactor vessel shell welds, which have taper transitions at weld joints of dissimilar thickness. The PDI qualification for Supplements 4 and 6 allows for examination of material thickness up to 12.3 inches or a metal path distance of 17.5 inches in the case of the 45 degree transducer. This qualified test range bounds a significant percentage of the flange-to-shell weld examination volume even in the thicker portion above the weld centerline.
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Attachment 2 to HNP Serial No. HNP-05-130 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST NO 2R1-017 REQUEST FOR RELIEF FROM INSERVICE INSPECTION PROGRAM REQUIREMENTS FOR REACTOR VESSEL SHELL TO FLANGE WELD HNP's RPV flange-to-shell weld was examined during pre-service by remote automated inspection in accordance with Section XI. The pre-service examination was performed from the vessel ID surface, using Section XI techniques of 0 degree longitudinal and 45 and 60 degree shear beam angles. Examination from the flange surface was performed using 0, 8, and 19 degree longitudinal beam angles. For inservice examinations, during the first interval the weld examination from flange surface was performed in accordance with Section XI using 0, 8, and 19 degree longitudinal beam angles. The weld ID surface examination was performed using 0 degree, SLIC 40 and 55 degree transducers by remote automated inspection in accordance with Section XI and Regulatory Guide (RG) 1.150 Revision 1. No matters of concern were identified during the aforementioned examinations.
The use of Appendix VIII Supplements 4 and 6 for the completion of the RPV vessel-to-flange weld from the shell side (which PDI has qualified) is expected to reduce examination time, which translates to reduced personnel radiation exposure.
Additionally, this relief would allow a smooth transition to the welds adjacent to the RPV circumferential and longitudinal welds which do require an examination in accordance with Appendix VIII, Supplements 4 and 6. This would eliminate the need to switch to the different calibrations, procedure, and technique required by ASME Code,Section V,Article 4 and Regulatory Guide 1.150, Rev 1. This would result in a reduction in transition time to the different calibration, procedure, and technique required which translates to reduced personnel radiation exposure and is more cost effective.
For ultrasonic examination of the reactor vessel shell-to-flange weld conducted from the face of the flange, the examination procedure shall continue to meet the requirements of the 1989 Edition of ASME Section XI, Category B-A and ASME Section V, Article 4 as augmented by RG 1.150 Rev. 1.
ALTERNATE EXAMINATIONS The automated shell-to-flange weld examinations from the shell inside diameter shall be performed using a qualified procedure in accordance with ASME Code,Section XI, Div. 1, 1995 Edition with 1996 Addenda, Appendix VIII, Supplements 4 and 6 as amended by the Federal Register Notice 64FR 51370 through 51400, dated September 22, 1999. All other ASME Section XI Code requirements for which relief is not specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
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Attachment 2 to HNP Serial No. HNP-05-130 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RELIEF REQUEST NO 2R1 -017 REQUEST FOR RELIEF FROM INSERVICE INSPECTION PROGRAM REQUIREMENTS FOR REACTOR VESSEL SHELL TO FLANGE WELD The Appendix VIII criteria were developed to ensure the effectiveness of UT examinations within the nuclear industry by means of a rigorous, item-specific performance demonstration. The performance demonstration was conducted on RPV mockups containing flaws of various sizes and locations. The demonstration established the capability of equipment, procedures, and personnel to find flaws that could be detrimental to the integrity of the RPV. The performance demonstration showed that the proposed UT technique is equal to or surpasses the requirements of the Code and the recommendations of RG 1.150. Therefore, there is reasonable assurance that the proposed alternative provides an acceptable level of quality and safety.
DURATION OF PROPOSED ALTERNATIVE:
The proposed alternative is requested for the duration of the second inservice inspection interval.
PRECEDENTS The NRC has granted similar relief to Callaway Plant. Reference AmerenUE Callaway Plant letter, dated August 14, 2003, Docket No. 50-483, "Requests for Relief Regarding Implementation of ASME Section XI Appendix VIII Requirements", and the associated NRC Safety Evaluation, letter from Stephen Dembek to Garry Randolph (Union Electric Company) dated April 7, 2004;
Subject:
Callaway Plant Unit I - Relief Request ISI-27 through ISI-31 Pertaining to Implementation of ASME Section XI Appendix VIII Requirements (TAC Nos.
MC04478 through MC04482, respectively).
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