L-2003-122, NRC Order EA-03-009 - Reactor Pressure Vessel Head & Vessel Head Penetration Nozzle Inspection Results

NRC Order EA-03-009 - Reactor Pressure Vessel Head & Vessel Head Penetration Nozzle Inspection Results

ML031550062
Person / Time
Site:	Turkey Point
Issue date:	05/27/2003
From:	Jones T Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-03-009, L-2003-122
Download: ML031550062 (5)

Text

FPL MAY 2 7 2DO3 L-2003-122 10 CFR 50.4 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D. C. 20555 Re: Turkey Point Unit 3 Docket No. 50-250 NRC Order EA-03-009 - Reactor Pressure Vessel Head And Vessel Head Penetration Nozzle Inspection Results NRC Order EA-03-009, issued on Februay 11, 2003 established interim inspection requirements for reactor pressure vessel heads of pressurized water reactors.Section IV. E. of the NRC Order requires that the results of the inspection be provided within 60 days of the plant being returned to operation. In accordance with section IV. E. of the NRC Order, the attachment to this letter submits the Florida Power and Light Company (FPL) inspection results for Turkey Point Unit 3 for the March 2003 refueling outage.

Based on the results of the reactor pressure vessel head visual examination, reactor pressure vessel head penetration nozzles ultrasonic examinations and leak path assessments (including liquid penetrant of the vent), FPL concludes that the alloy 600 reactor pressure vessel head penetration nozzles are not degraded, and no wastage has occurred of the reactor pressure vessel head.

Should there be any questions on this letter, please contact Walter Parker at (305) 246-6632.

Very truly yours, Terry 0. Jones Vice President Turkey Point Plant OH Attachment cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point an FPL Group company

Attachment to L-2003-122 Page 1 of 4 NRC ORDER EA-03-009 60 DAY REPORT: REACTOR PRESSURE VESSEL HEAD AND VESSEL HEAD PENETRATION NOZZLE POST OUTAGE INSPECTION RESULTS FOR TURKEY POINT UNIT 3 The NRC issued an Order' on Februay 11, 2003 establishing interim inspection requirements for reactor pressure vessel heads of pressurized water reactors. In section IV.E. of the NRC Order, the NRC required that the results of the inspection be provided within 60 days of the plant being returned to operation. Florida Power and Light Company (FPL) hereby submits the inspection results for Turkey Point Unit 3 for the March 2003 refueling outage.

Turkey Point Unit 3 March 2003 Post Outage Inspection Results:

1. Plant Susceptibility Category: The Turkey Point Unit 3 reactor pressure vessel (RPV) closure head had approximately 18.3 effective degradation years at the start of the March 2003 refueling outage, as identified in the FPL response to NRC Bulletin 2002-022. The inspection category identified in the Order is High. The corresponding inspection method specified in Section IV.C.(1). is as follows:

IV.C.(1) For those plants in the High category, RPV head and headpenetration nozzle inspections shall be performed using the following techniques every refueling outage.

(a) Bare metal visual examination of 100% of the RPV head surface (including 3600 around each RPV head penetration nozzle), AND (b) Either:

(i) Ultrasonic testing of each RPV head penetration nozzle (i.e., nozzle base material) from two (2) inches above the J-groove weld to the bottom of the nozzle and an assessment to determine if leakage has occurred into the interference fit zone, OR (ii) Eddy current testing or dye penetrant testing of the wetted surface of each J-Groove weld and RPV head penetration nozzle base material to at least two (2) inches above the J-groove weld.

2. Inspection Scone and Method:

2.a. RPV Bare Metal Head Surface Visual: A bare metal visual inspection of 100% of the RPV head top surface, including 3600 around each RPV head penetration nozzle, was performed as identified in section IV.C.(1)(a) of the NRC Order. The VT was performed with the head shroud raised and all of the RPV head insulation removed, providing unrestricted visual access using both direct and remote visual examination techniques.

The scope of the inspection did not include the inside surface of the 58 RPV stud holes as clarified in the summary of the February 24, 2003 NRC meeting 3 conducted to discuss the NRC Order.

A limitation was noted where the /2"thick shroud support ring comes in close contact with the sloping RPV head outside of the RVHP nozzles. The square cut edge of the shroud support ring comes in close contact with the sloping RPV head for approximately half of the

Attachment to L-2003-122 Page 2 of 4 circumference of this 120" diameter ring. The adjacent areas uphill and downhill of the shroud ring and the areas under the shroud ring where a gap existed were visually examined. These areas were found to be free of any boric acid accumulation or staining.

The shroud ring metal edge to vessel contact, and lack of staining indicated that no wastage could have occurred. The limited area under the shroud ring was not considered relevant because there was no source of external boric acid leakage at or under the shroud ring that could result in wastage (Reference 3, NRC response to NEI question # 2). The limited area under the shroud ring is less than 0.3% of the vessel surface (<100 in2 / 31,700 in2), since only the edge of the shroud ring was in contact with the RPV head instead of the entire 1/2" thickness.

2.b. RPV Head Penetration Inspection: The ultrasonic (UT) examination technique option, identified in section IV.C.(1 )(b)(i) of the NRC Order, was performed of all of the 66 reactor vessel head penetration (RVHP) nozzles, including the vent line. The inspection included the nozzle base material 2" above the J-groove weld, down to the bottom end of all of the penetrations, with minor limitations for nine penetrations. These nine penetrations were inspected from 2" above the J-groove weld, down to a minimum of 1" below the weld.

This limitation was the subject of a relaxation request 4 5that was approved by the NRC 6.

As part of the UT examinations, the 65 RVHPs with interference fits were assessed to determine if leakage had occurred into the interference fit zone (annulus between the RPV head and the penetration above the pressure boundary weld). This assessment used the Framatome-ANP proprietary "leak path" technique, which was described in the post outage inspection report for the previous FPL St. Lucie Unit 1 RPV head inspection 7 The UT examinations of the 65 RVHPs (excluding the vent), were performed utilizing a circumferential "blade probe" consisting of two elements in a pitch/catch configuration in accordance with Framatome-ANP procedure 54-ISI-100-09. The vent inspection was performed using a rotating transducer in accordance with Framatome-ANP procedure 54-lSI-1 37-01.

The UT procedures utilized for the examination of the vent and the 65 RVHPs have been previously submitted to the NRC by the inspection vendore 9. Since the submittal to the NRC, the UT procedure used for the vent line was revised to include the change authorizations identified in Reference 9 from the Fall 2002 inspections. After the issuance of the NRC Order, one non technical change authorization for each procedure, FRA-03-004 Rev. 1 and FRA-03-005 Rev. 1, was also processed for the UT procedures to match the examination area wording with the area defined in the NRC Order. The inspection essential variables, procedure demonstrations, and personnel qualifications that were described in Reference 7 remain unchanged.

3. Inspection Results Summary:

3.a. RPV Head Visual Results: The overall condition of the Turkey Point Unit 3 RPV head was clean with no evidence of leakage from the 66 RVHPs or wastage of the RPV head surface.

3.b. RPV Head Penetration Inspection Results: In accordance with UT procedures 54-ISI-100-09 and 54-ISI-137-01 (vent line), there were no indications identified in any of the 66 RVHPs in the Turkey Point Unit 3 RPV head. There was also no evidence of a "leak path" signature for any of the 65 interference fit RVHPs (excluding the vent) examined,

Attachment to L-2003-122 Page 3 of 4 which is the Framatome-ANP assessment to determine if leakage has occurred into the interference fit zone.

Since the vent line is a clearance fit nozzle, a clean visual inspection provides a direct determination that no leakage has occurred into the annulus. In addition, the flush pressure boundary surface inside of the RPV head associated with the vent line (the head vent line, alloy 600 attachment weld, and a portion of the adjacent stainless steel clad weld) was examined using the liquid penetrant (PT) examination method. The acceptance criteria utilized for the PT examination was "PT white." There were no PT indications identified in the inspected area associated with the head vent line, which provides additional confirmation for the assessment that the vent line has no leakage into the annulus.

4.

Conclusion:

FPL has complied with the requirements of the NRC Order (EA-03-009) for the Turkey Point Unit 3 Cycle 20 refueling outage, based upon the performance of the RPV head inspection and the NRC conditional approval of the relaxation request for the non-pressure boundary portion of nine RVHPs 6, Based on the results of the visual examinations, UT examinations, and leak path assessments (including PT of the vent), FPL concludes that the alloy 600 RVHP nozzles are not degraded, and no wastage has occurred of the RPV head.

'US NRC Letter EA-03-009, Issuance of Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors," from Samuel J. Collins (NRC) to all Pressurized Water Reactor Licensees, February 11, 2003.

2 FPL letter L-2002-185, St. Lucie Units 1 and 2, Docket Nos. 50-335, 50-389, Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-251, Response to NRC Bulletin 2002-02, Reactor Pressure Vessel Head Penetration Nozzle Inspection Programs " R. S. Kundalkar to NRC, September 11, 2002.

3 US NRC Letter (ADAMS Accession No. ML030780413), Summary of Meeting Held on February 24, 2003, with Nuclear Energy Institute and EPRI MRP to Discuss the Order Issued on Reactor Vessel Head Inspections," S.D. Bloom to A.J. Mendiola, March 21, 2003.

4 FPL letter L-2003-067, 'Turkey Point Units 3, Docket No. 50-250, Order (EA-03-009) Relaxation Request, Examination Coverage of Reactor Pressure Vessel Head Penetration Nozzles," W.

Jefferson to NRC, March 11, 2003.

5 FPL letter L-2003-068, 'Turkey Point Units 3, Docket No. 50-250, Order (EA-03-009) Relaxation Request, Examination Coverage of Reactor Pressure Vessel Head Penetration Nozzles -

Supplemental Data," W. Jefferson to NRC, March 14, 2003.

6 US NRC Memo (ADAMS Accession No. ML030790501), Turkey Point Unit 3 - Relaxation of the Requirements of Order (EA-03-009) Regarding Reactor Pressure Vessel Head Inspections (TAC No.

MB7990) and attached Safety Evaluation by the Office of Nuclear Reactor Regulation' S.W. Moore to J.A. Stall, March 20, 2003.

Attachment to L-2003-122 Page 4 of 4 7 FPL letter L-2002-233, St. Lucie Units 1 and 2, Docket Nos. 50-335, 50-389, Reactor Pressure Vessel Head (RPVH) Inspection, NRC Bulletin 2002-02 Supplemental Response, D. E. Jemigan to NRC, November 21, 2002.

8 Framatome ANP Letter NRC:02:056, "Procedures for the Conduct of Ultrasonic Examinations of Reactor Vessel Head Penetrations," James F. Mallay (FRA-ANP) to NRC Document Control Desk, November 11, 2002.

9 Framatome ANP Letter NRC:02:057, Change Authorizations to Procedures for the Conduct of Ultrasonic Examinations of Reactor Vessel Head Penetrations," James F. Mallay (FRA-ANP) to NRC Document Control Desk, November 15, 2002.