L-14-105, Notification of Impracticality for the Third 10-Year Inservice Inspection Interval

Notification of Impracticality for the Third 10-Year Inservice Inspection Interval

ML14069A424
Person / Time
Site:	Perry
Issue date:	03/07/2014
From:	Harkness E FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-14-105
Download: ML14069A424 (9)

Text

FENOC Perry Nuclear Power Plant P.O. Box 97 10 Center Road Perry, Ohio 44081 FirstEnergy Nuclear Operating Company Ernest J. Harkness 440-280-5382 Vice President Fax: 440-280-8029 March 7, 2014 L-14-105 10 CFR 50.55a ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Notification of Impracticalitv for the Third 10-Year Inservice Inspection Interval In accordance with 10 CFR 50.55a, FirstEnergy Nuclear Operating Company (FENOC) is submitting to the Nuclear Regulatory Commission (NRC) a notification of impracticality related to an inservice inspection where the required visual examination coverage of 100 percent was not achieved.

The notification of impracticality is enclosed and supports the third 10-year inservice inspection interval, which commenced on May 18, 2009 and is currently scheduled to expire on May 17, 2019.

The original cover letter for this notification was incorrectly dated for 2013. To avoid any potential confusion, FENOC is resubmitting the notification.

There are no regulatory commitments contained in this submittal. If there are any questions or additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 315-6810.

Sincerely, Ernest J. Harkness

Enclosure:

Perry Nuclear Power Plant, 10 CFR 50.55a Request IR-058 cc: NRC Region III Administrator NRC Resident Inspector NRC Project Manager

Perry Nuclear Power Plant 10 CFR 50.55a Request IR-058 Page 1of4 Notification of Impracticality in Accordance with 10CFR 50.55a(g)(5)(iii)

-lnservice Inspection Impracticality--

1. American Society of Mechanical Engineers IASME> Code Components Affected Reactor Pressure Vessel Support Skirt (1B13-00001-SP)

ASME Code Class 1

2. Applicable Code Edition and Addenda

ASME Boiler and Pressure Vessel Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," 2001 Edition through 2003 Addenda.

3. Applicable Code Requirement

Table IWF-2500-1, Examination Category F-A, Item F1 .40 requires a visual examination (VT-3) of 100 percent of the reactor pressure vessel (RPV) support skirt [both interior and exterior surfaces of the skirt], as defined by ASME Figure IWF-1300-1.

4. Impracticality of Compliance Examining 100 percent of the RPV support skirt, as* required by the ASME Code, is impractical. Examination limitations exist due to the configuration of the RPV support skirt and its thermal insulation package, which is permanently attached to the skirt's interior surface and not designed for disassembly or removal. Examination limitations also exist due to undervessel interferences. These limitations are inherent to the General Electric boiling water reactor design.

5. Burden Caused by Compliance The RPV support skirt and thermal insulation package were designed and fabricated such that the insulation, which is permanently attached to the interior surface of the RPV support skirt, obstructs the skirt's interior surface and prevents visual examinations.

Removing the obstructions to perform the examination would require the permanent thermal insulation to be redesigned and replaced, which is impractical.

Although theoretically feasible, It is estimated that removing the permanent thermal insulation from the interior surface of the RPV support skirt and replacing it with removable insulation would require several hundred man-hours to stage and erect scaffolding, remove RPV support skirt insulation, perform the required visual examinations, install removable insulation, and remove the scaffolding. Based on radiological survey results from a March 2009 outage, this work would occur directly below the RPV within radiation fields of 560 milli-Rem (mR) to 1300 mR per hour at head level and 450 mR to 1000 mR per hour at chest level, resulting in a significant increase in cumulative occupational radiation exposure [dose] to personnel without a compensating increase in quality and safety. Due to the existing undervessel interferences and limited accessibility, the use of temporary shielding to reduce this dose is also impractical.

Request IR-058 Page 2of4

6. Proposed Alternative* and Basis for Use Alternative Examination: _

Accessible areas of the RPV support skirt have been visually examined. For the exterior of the skirt, 100 percent of the skirt's surface and 60 skirt mounting bolts have been examined. The exterior VT-3 examination was performed from within the RPV's biological shield wall. For the interior ()f the skirt, approximately 10 percent of the skirt's surface and 12 of 60 skirt mounting bolts have been examined. The interior VT-3 visual examination, which was limited due to existing undervessel interferences and permanently installed thermal insulation, was performed from below the RPV using a remote portable camera. This results in an aggregate examination coverage of approximately 55 percent.

Basis for Use:

Figure 1 depicts the RPV bottom head, RPV support skirt, permanent insulation, and the area viewed using the portable remote camera.

During the current 10-year inservice inspection interval, 100 percent of the skirt's exterior surface and 60 skirt mounting bolts were VT-3 visually examined during a 2012 outage. Approximately 10 percent of the skirt's interior surface and 12 of 60 skirt mounting bolts were VT-3 visually examined during the spring 2013 refueling outage.

Due to the permanently installed thermal insulation and interferences from existing undervessel components, which include 177 control rod drive hydraulic lines and structural support steel, further VT-3 visual examinations of the skirt's interior surface or skirt mounting bolts was not possible using the remote portable camera. This results in*

an aggregate VT-3 visual examination coverage of approximately 55 percent. Areas visually examined were found to be acceptable with no age related degradation or fabrication flaws identified and no indications that exceed the acceptance criteria of ASME Section XI. These examinations provide reasonable assurance of the RPV support skirt's structural integrity. The two visual examination reports for the support skirt are provided as attachments to this request.

Due to existing undervessel interferences and configuration of the RPV support skirt with its permanently installed thermal insulation, the examination requirements of ASME Section XI, 2001 Edition through 2003 Addenda, are impractical.

7. Duration of Proposed Alternative The proposed notification supports the third 10-year inservice inspection interval, which commenced on May 18, 2009.

Request IR-058 Page 3of4

8. Precedent The Nuclear Regulatory Commission (NRC) approved similar requests for the River Bend Station and Grand Gulf Nuclear Station:

NRC letter tQ Entergy Operations, Inc.,

Subject:

"River Bend Station, Unit 1, Request for Relief From ASME Code,Section XI, Requirements for Reactor Pressure Vessel Support Skirt for the Second 10-Year lnservlce Inspection Interval *

(TAC No. ME9654)," September 24, 2013. [Accession No. ivlL13261A379]

NRC letter to Entergy Operations, Inc.,

Subject:

"Grand GulfNuclearStation, Unit 1, Relief Requests GG-ISl-005 Through GG-ISl-012 for Second 10-Year lnservice Inspection Interval (TAC Nos. ME1376, ME1377, ME1378, ME1379, ME1380, ME1381, ME1382, and ME1383)," May 25, 2010. [Accession*No. ML101410002]

9. Attachments

1. Visual Examination of Pipe Hanger, Support or Restraint (VT-3),

Report No. 1042-13-094, December4, 2013. *

[Interior of RPV Support Skirt]

2. Visual Examination, Report No. 1Q800-13-047, June 25, 2012.

[Exterior of RPV Support Skirt]

Request IR-058 Page4of4

.** . ~:. ....._* -~, . .'J*,* *** ..'. *. *, , . *t .* *. ' .*

RPVSUPPORT

- - - = : ! : . -*.* ..... .

NON-REMOVABLE I . ..

. *. SKIRT (TYP.)

. *-~*. ,

PERMANENT INSULATION, EXCEPT AT SMALL ACCESS PANELS (4 LOCATIONS) r ..

\ . ...

RPVSUPPORT *. * . CENTERLINE OF SKIRT (TYP.) CONTROL ROD PERMANENT (TYP. 177 TOTAL) AREA VIEWED USING INSULATION REMOTE PORTABLE

< ELEVATION VIEW> CAMERA (SUPPORT SKIRT MOUNTING BOLTS ARE NOT DEPICTED)

FIGURE 1 - RPV Bottom Head. RPV Support Skirt and Permanent Insulation

Attachment 1 .

FENOC Visual Examination of Pipe Hanger, Support or Restraint (VT-3)

Request IR-0.58 Page 1of2

• Site/Unit: Perry I 1 Procedure: NQl-1042(3) Outage No.: RF014 Summary No.: 002825 Procedure Rev.: ----------------- 16 Report No.: 1042-13.094; Workscope: ISi Work Order No.: ----------------- Page: 1 of 2 Code: ASME Sec XI 2001E/2003A Cat./ltem: F-AIF1.40 . Location: RB-DW Drawing No.:

• 305-006-104

Description:

RPV SUPPORT SKIRT (WA)

System ID: 1813 Component ID: ------------------------------------------------------------------------

1813-00001-SP Limitations: Undervessel lnsulatlon Package Light Meter Mfg.: NIA Serial No.: ______....;;..N=/A....;;..______ lllumlnatlon: - - - - - - - - - - - -

Light Verification Times: Cal In O NIA NIA Cal Out 0 - - - - - -

Temp. Tool Mfg.: NIA

---

Serial No.: N/A NIA Surface Temp. ______ °F Resolution: Visual Acuity Card 0.105" Characters System Condition: Cold Visual Equipment/Aids: Remote Camera System with battery operated llghUng, Visual Acculty card Varlable Spring SupportO Constant Support@ Restraint 0 Other 0 Visual Examination: Remote SAT UNSAT N/A See Comments

1) Component Support Identified ...Ji._

2) Deformation or Structural Degradation -Ji._

3) Support Structure/Concrete/Embedments -Ji._

4) Support Items/Attachments/Connections -Ji._

5) Cracks In Welds

6) Anchors/Fasteners/Integral Attachments ~

7) Thread Engagement ~

8) Loose/Missing/Detached Items ~

9) Cotter Pins/Locknuts (Broken/Missing/Loose)

10) Hanger/Rod/Movement Obstructions

11) Mlsallgnment/Clearances/Blndlng

12) Loose Position/Load Indicator/Settings

13) Pivot Wear/Close Tolerance Surfaces

14) Corrosion/Foreign Material/Coating

15) Travel Stops/Locking Devices

16) Other (Describe)

Cold Load Setting: N/A Position Indicator Reading: N/A Hot Load Setting: N/A Pin to Pin Setting:

NIA Comments:

Examined the Inside of RPV skirt support from the El 583 CRD undervessel area. See supplemental sheet for details.

Original exam date 4119/2013 Results: SAT~ UNSAT 0 EVAL D Revised 11/25/2013 per CR-2013-18628 Percent Of Coverage Obtained > 90%: see comments Reviewed Previous Data: NIA E)C8mlner Level Ill Date Reviewer Signature .Date Wirtz, Charles J "-"~~---1PJ013 NIA Examiner Level Date Site Review Date N/A Fuller Jr, Richard 11/25/2013 Other Level NIA Signature Date ANll Review NIA Laps, Thomas

Attachment 1 FENOC Supplemental Report Request IR-058 Page2of2*

• Report No.: 1042-13-094 Page: 2 of 2 Summary No.: 002625 ~

Examiner: WlrtZ, Cha~ Level: _11_1_ Reviewer: _N_IA_________--"._ Date:

Examiner: NIA Level: . N/A Site Review: Fuller Jr, Richard Date: 11/25/2013 Other: N/A Level: N/A __________

ANH Review: Laps, Thomas ......_~,,_;;;...

Date: ~~~:-'""'£..,

....,....+,...,...,.,_

Comments:

The exterior of the RPV skirt support was examined during a forced outage on 8/15/12, refer to report 1QB00-13-047. This exam was a best effort attempt to examine the Interior of the RPV skirt. The portions of the Interior of the RPV skirt support that are directly under the reactor vessel and accessible via the bloshleld and through the skirt hatch at Odegrees, Is not vlslble because of the permanent sheetmetal insulation package that Is under the reactor vessel, which fonns a floor right at the hatch level (hiding the Inside bolts of the skirt support) and llnes the Interior walls of the skirt.

This exam was performed from 583' CRD undervessel area. A portable remote camera that booms out to 20 feet was used from the undervessel carousel platfonn to boom up to below the undervessel Insulation package and look at a right angle at the Inside part of the skirt that is below the undervessel lnsulatlon package/floor. Access was only afforded In a couple areas of the annulus area between the CRD shoot out steel and the Inside of the RPV pedestal. *I was assisted by Sean Franklin. We were only able to boom up to the necessary elevation from a couple places right Inside the undervessel keyway (at approx 190 degrees) and at approximately 270.degrees. In other areas, the CRD Insert and withdraw lines or structural steel precluded access. There are 60 bolts outside the skirt and 60 Inside the skirt. From the 3 locatatlons where we able to boom up, we were able to see 22 of the 60 bolts, with only about 12 of those at VT-3 distances and resolution. All of the bolUng appeared to be tight and Intact. The bolting did appear to be covered with fight surface rust, but nothing so heavy as to obscure the threads. In total It Is estimated that this exam looked at about 10% of the skirt Interior, but that Included 20% of the Interior bolting at VT-3 resolution and 36.7% with best effort looks.

Resolution checks were perfonned*prlor to and after the exams.

Total composite coverage at VT-3 examination distances and acuity Is 55% (100% of the exterior and approximately 10% of the Interior).

Attachment 2 Request IR-058 FENOC Vlsual Examination Page 1of2

.r

~---~

Site/Unit: Peny I 1 Procedur&l _ _ _ Na_f..1_0_42(...,S..._)_ _ Outage No.:

.Rf014 Summary No.: 002625 Ptocedure Rev.:

---

18 :Report No.: 1QBOIM3-047 a

Worbc;ope: 181 Work Older No.:

---

200412044 Page: 1 of Code; Drawing No.:

ASME Sec XI 2001E/2003A Cal.ntern:

F-A/F1,40 Location:

Description:

.RPV SUPPORT SKIRT (WA)

~--------~

System ID: 1813

---

~

ComponentlD: 1813-00001-SP Comments:

See supplemental page for datasheet and required slgnaturee.

Results: SAT lltJ UNSAT 0 EVAL 0 Urnlt.ad Exam (60%) Sat.

Percent Of Ccwerege Obtained > 90%: No Reviewed Previous Data: NIA Examiner Level Signature Date Reviewer. Signature Date NIA. See attached 8115120i2 NIA 1;:.xamlner Level NIA Signature Date Site Review s19nature Date

.f/A Funer Jr, Richard 8/1112012 Other Level NIA Signature Date ANll Review Signature Date NIA Lape, Thomae 8J28/2012 a*93.l - e1 s a 67

Attachment 2 Request IR-058 FENOC Supplemental Report Page2of2

• Reporj No.: 1Q8Q0.13-G47 Page: 2 of 2

""°'1rrtary No.: 00282&

FENOC Visual Examination of Component Support& and Snubber& fVT-3)

~; ___ ..,...<<>>-....11M 2__ 0ula98 Nii.: NIA Pnlc:edur9 Rev.: - - - " ' - ' ' 6 ' " - - - RelJOI\ No.: 1042-12EMJff W0111 OnW Na.: 1ooonoae Page: _!_. ol _1_

Code: _ _ _....;SOct;.;;..;.;;....;XJ;...._ _ Ca1Jltem: F-A I Ft.AO Location: _ _ _ _ _0,.,..;;.;1.,;_ ~"-----

OmM9 No~ HS406-104 Desalptiin: ;;.;RPV;...;...;5'111='--------~------

Sy11em ID: 1813 Comi>oTienI 10: ~-----~-----~-------------~--

1813-00001-81>

Llmitatkllu; EJtArlol' *Ul'l'Ues only lfaht M~efll.fg.; HJA Serial No.: --~Nl;.;.;Ac..___ Uhmllnatlon: .Adi!qualll i.lg!lt Velif.alton Times: Ce! In 0 NIA NIA IUA Ccl Ou1 0 NIA TD111p. TDOI 1.!tiJ.: NIA Selfal No.: . NIA Slllfi1CO Temp.: NIA 'F R~~: o. tOS" Charactar Card Surface Common: As.found Visual EQU!pmrntlA!d): F1111hllghL O.tOS" vl!nral acul!y card (CRC 10.tlA)

Viou-Ol &amlnnt'..1111: Dlrocl Seo Soo All Com~ BAT UN!IAf NIA Com:ncnla Spttng Supports SAT UNSAT NIA c-

1) ~emol Obstndon _L

--* , 9) Off Stale High _ _L

2) CrocQ or uncar 11111.

3) Loasa Pml!I

_L

..L.

- 20) Oii Scale L-

21) Loctl"i} Davia! In Plam

--L-

4) ~Parta _:!__ U)~ Oeoraded

6) Olls!r. To~ PMS_:!__ - ..!!!._

23) Givsa M1sa1i9'1ment _ _L

6) Wear ..J!_

MochanlQd Sm.dllltta

7) Ccinr.lslonlCoa~ ..L.

,, _ _t_,

8) CcinlamJuinta 24) Swing Clearance

9) ll!IPIVflef Weld Relnfar. " 25) Bent Exlamlon Rod --L

10) Physical DQ!ormalloll ...L. 26) Hclu$illg Oamag&

11) MistJ3o _..!!_ tlylhullo~

12) Slipped ClamPI 27) ~esamlr l.ewl _ _L,

_-l!-,

13) OUwlr (DosCribe) 28)Lmage_

29) Pl51Dn FU!y Elll!lndcd

14) Conod Sellfngs Ye$ No NIA -~

1S) Ac:lllal Sflllln9 NIA

"' 30) PlslDn Fl9/ Rlllnldad _ ..:t_

18) Serial No. NIA 31)R~ONOir lrweitod c-t.111 Load8u-'8 32) Pil!an Damage .

-~

17) Tlll\let~inPlal:e

- ..J!_

1s1 Housing oamaoo _ --.

Com1118111&:

UmltcKt OQllltndonperformod. Ellta!lo1CO Ulewael, lnlltRel only,~ llllBl'lllnBllon c:owo111911.

SAT iJ UHSAT 0 EVAL 0 No NIA Exilmtner 1.11ve1 n Dal&

Fnanldln, 8aan M. llH/2012

'- -