ML020990092
| ML020990092 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/03/2002 |
| From: | Kansler M Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| IPN-02-024 INT-1-1300, Rev 4 | |
| Download: ML020990092 (32) | |
Text
Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
440 Hamilton Avenue Entergy White Plains, NY 10601 Tel 914 272 3200 Fax 914 272 3205 Michael R. Kansler Senior Vice President &
Chief Operating Otficer April 3, 2002 IPN-02-024 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001
SUBJECT:
Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 Revised Relief Request Nos. 3-12, 3-14, 3-16, and 3-17 Third 10-Year Inservice Inspection Interval Program Plan
Reference:
- 1. NYPA letter IPN-00-055 to NRC, "Third Ten Year Inservice Inspection Interval," dated July 18, 2000
- 2. NRC letter, "Request for Additional Information Regarding Third 10-Year Inservice Inspection Program (TAC No. MA9757)," dated February 13, 2001
- 3. Entergy letter IPN-01 -024 to NRC, "Request for Additional Information Regarding Third Ten Year Inservice Inspection Interval Program Plan," dated March 20, 2001
Dear Sir:
This letter transmits the revised Request for Reliefs (RRs) for the Indian Point Nuclear Generating Unit No. 3 (1P3), RR 3-12, RR 3-14, RR 3-16 and RR 3-17. These RRs were initially submitted with the IP3 Third 10-Year Inservice Inspection Program Plan (Reference 1).
In response to the letter of request for additional information (RAI) from the NRC (Reference 2),
these RRs were withdrawn (Reference 3) for administrative reasons. contains the revised relief requests which incorporated supplemental information, drawings/sketches, and/or previous inspection data from the 2 nd Interval to address the specific issues identified in the RAI (Reference 2) letter for the subject RRs.
Approval is requested by December 16, 2002 to support implementation for the upcoming R12 refueling outage.
There are no new commitments made in this letter. If you have any questions, please contact Ms. Charlene Faison at 914-272-3378.
Senior Vice President and Chief Operating Officer Attachments: As stated cc:
Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511 Mr. Patrick Milano, Project Manager Project Directorate I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555
ATTACHMENT I TO IPN-02-024 INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 THIRD TEN-YEAR INSERVICE INSPECTION INTERVAL PROGRAM PLAN REVISED RELIEF REQUESTS Relief 3-12, Revision 1 Relief 3-14, Revision 1 Relief 3-16, Revision 1 Relief 3-17, Revision 2 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286 DPR-64
Indian Point 3 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER 3-12, Rev. 1 (Page 1 of 2)
A. COMPONENT IDENTIFICATION Code Class: 1
References:
Table IWB-2500-1, Category B-A; Figure IWB-2500-3 Examination Category: B-A Item Numbers: B1.21, B1.22
==
Description:==
Reactor Vessel Closure Head and Bottom Head Circumferential and Meridional Welds B. CODE REQUIREMENT 10 CFR 50.55a(xv) requires the use of Appendix VIII of Section Xl, 1995 Edition with the 1996 Addenda for the qualification process.
C. RELIEF REQUESTED:
Indian Point 3 requests relief to utilize the Performance Demonstration Initiative (PDI) procedure (PDI-UT-6) for Reactor Vessel welds for thicknesses greater than the currently qualified procedure thickness.
D. BASIS FOR RELIEF Pursuant to 10 CFR 50.55a(3)(i), relief is requested on the basis that the proposed alternatives would provide an acceptable level of quality and safety. The PDI procedure is qualified for thicknesses up to 7.64". As can be seen from the enclosed "Profile of the Reactor Vessel Closure Head" sketch, portions of the meridional and circumferential head welds may exceed this thickness. Based on input from EPRI-PDI group, the search units specified in PDI-UT-6 have a large depth of field and are capable, though not currently qualified, for thicknesses up to 11". This capability is well above the maximum weld thickness shown on the attached profile of the Indian Point Unit 3 Reactor Vessel Closure Head sketch (Attachment 1).
While not a part of this relief, Entergy plans to perform the inspection of the Head-to Flange Weld (B1.40, Weld #1 on INT-1-1300) using the PDI method in lieu of the Section XI examination as well. The PDI method will be used in accordance with Section IWA-2240 of Section Xl for alternative examination methods. The PDI procedure is qualified in accordance with Appendix VIII and will be used in lieu of the prescriptive requirements of Article 4,Section V of the ASME B&PV Code. The procedure and personnel qualified to the procedure are currently the state of the art
Indian Point 3 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER 3-12, Rev. 1 (Page 2 of 2) and exceeds the requirements of Section XI and Section V. In using the PDI procedure, only the 60°RL transducer will be used from the outside of the vessel.
E. PROPOSED ALTERNATE EXAMINATION PDI procedure PDI-UT-6 will be used for reactor head inspections as allowed by and in accordance with ASME, B&PVC,Section XI, 1989 Addition, No Addenda, IWA-2240, "Alternative Examinations", but in some areas the actual thickness may be beyond the qualified thickness indicated in the procedure.
F. JUSTIFICATION FOR RELIEF The use of the PDI procedure beyond its qualified thickness will still result in accurate data. Based on input from EPRI, the search units specified in PDI-UT-6 have a large depth of field and are capable, although not currently qualified, for thicknesses up to 11".
The actual thicknesses encountered for part of the weld length will be slightly greater than the qualified maximum, but are within the qualified range for most of the weld length. The procedure uses the latest in technology for ultrasonic inspection as compared to the requirements of Section Xl and Section V.
G. PERIOD FOR WHICH RELIEF IS REQUESTED Relief is requested for the third inspection interval, July 21, 2000 through July 20, 2009.
H. ATTACHMENTS TO RELIEF
- Sketch INT-1-1300, Rev.4
- Profile of the Reactor Vessel Closure Head
got VIEW 041 / 5b270 170 640 320110 8( )120390 Q67 400 le0 30 4Q1J90 043 1042 0' .5g 2b 70I1 9v2 m 611 - 600 39QI1<) 20 5Qcr Q44 630310100o 6( )1303 35
- 42 0068 74 o5tob"o 4 21 290 O'656 I(CLOSURIE HEAD 460300 22(
TO FL ANGE) 700 0°o3p]
2gb 06906 620 CONTROL ROD DRIVE MECHANISM WITH CONOSEAL BOLTINO 2 -}
71a2 I:;'
(REF.VIEW B) 770' CONTROL ROD IflIVE MECHAN ISM 0
CONOSEAL BOLTING N VIEW B REACTOR VESSEL CLOSURE HEAD, DIAMETER 167.431" CIRCUMFERENCEi525.75" 0 CLOSURE HEAD TO FLANGE WELD It 8.O"T A5OB-64 CARBON STEEL MERIODIONAL WELDS 2 THRU 71 0.O"T SA302 GRADE B CARBON STEEL FLANGE N CONTOL ROD DRIVE MECHANISMS I THRU 78s 0.625"T SB-167 INCONNEL -tz TO 304 STAINLESS STEEL UPPER POSITIONER CONTROL ROD'DRIVE MECHANISMS VIEW C S--UPPER AND LOWER
- CLAMP (I EACH)
NEW YORK POWER AUTHORITY INDIAN POINT UNIT NO.3 REACTOR VESSEL CLOSURE HEAD SB-167 INCONNEL 304 STAINLESS STEEL INT- 1-1300 I1 I
WESTINGHOUSE NUCLEAR SERVICE DIVISION INSPECTION SERVICES PROFILE OF THE RECTOR VESSEL CLOSURE HEAD UNIT 3 SKETCH INT-1-1300, REV. 4 PLANT INDIAN POINT SYST./COMP. 16A,-,7 o, V's-.*4-'. ;o*Mwe ,*' / DATE 03"- 0,.__-_,__/
EXAMINER 4,, n4. IDENTIFICATION WELDS 1, 3, 5 AND 7 f/ . j" V &-
00 WeLD d]
7,
Indian Point 3 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER 3-14, Rev. 1 (Page 1 of 3)
A. COMPONENT IDENTIFICATION Code Class: 1
References:
Table IWB-2500-1, Category B-B, Figure IWB-2500-1 and 2 Examination Category: B-B Item Number: B2.11, B2.12
==
Description:==
Inspection of Pressurizer Shell-To-Head Circumferential and Longitudinal Welds B. CODE REQUIREMENT Table IWB-2500-1, Category B-B, Items B2.11 and B2.12 require volumetric examination of the Pressurizer Circumferential and the adjoining foot of the longitudinal shell-to-head welds as defined by Figures IWB-2500-1 and -2.
C. RELIEF REQUESTED Indian Point 3 requests relief from performing the code required volumetric examination of the pressurizer upper head circumferential weld # 17 on sketch INT-1 -2100 (attached) and from examining the intersecting one foot of the longitudinal shell-to-head welds (#s 2 and 16). In addition, relief is requested from examining 100% of the lower circumferential weld # 1.
D. BASIS FOR RELIEF Pursuant to 10CFR50.55a(a)(3)(ii), relief is requested on the basis that compliance with the specified Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The pressurizer was designed and fabricated to Codes in effect during the late 1960's. The Codes used did not provide for full access for inservice inspection as required by later Codes. The upper circumferential and longitudinal welds are enclosed in a biological and missile shield (see attached drawings 9321 -F-25453 and 9321 -F-25463). Insulation details can be seen on attached drawing 9321-LL-53253. The insulation in this area and the fact that the vessel is surrounded by a support structure indicates that these welds are completely inaccessible for volumetric examination.
Indian Point 3 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER 3-14 (I), Rev. 1 (Page 2 of 3)
Welds 1 and 2 for the lower head have been examined in the past but complete coverage was not possible. For the longitudinal weld (# 2), the first 15" of the adjoining section of the weld is covered by permanent insulation. One foot of the accessible portion of the weld was scanned in the last interval, but the insulation near the weld limits the 45 and 60 degree scans as indicated in the attached "Limitation to Examination" sheets. The circumferential weld (# 1) is accessible for the entire length, but with limitations as shown on the attached "Limitation to Examination" sheets for the previous interval.
E. PROPOSED ALTERNATE EXAMINTION Visual examination (VT-2) will be performed of the upper head welds (#s 16 and 17) for evidence of leakage during system pressure tests in accordance with IWB-2500, Category B-P, and Code Case N-498-1. It is expected that any through wall defects would be detected by this examination prior to the failure of the pressurizer based on the expectation that the component will experience leakage before a catastrophic failure
("leak before break"). A similar request for relief was approved and performed in the second interval (Reference SER dated November 7,1991, TAC NO. 72247).
Volumetric examination of the lower head welds (#s 1 and 2) will be performed, but only to the extent practical as described above in this relief request. In lieu of the adjoining one foot of weld #2, an accessible foot of the weld will be examined to the extent practical.
F. JUSTIFICATION FOR RELIEF Based on the reliable operating history of this and similar vessels at other plants and the performance of VT-2 examinations for leakage, granting of this relief request will not decrease the overall level of quality and safety of this component.
Indian Point 3 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER 3-14, Rev. 1 (Page 3 of 3)
G. PERIOD FOR WHICH RELIEF IS REQUESTED Relief is requested for the third inspection interval, July 21, 2000 through July 20, 2009.
H. ATTACHMENT TO RELIEF
- Sketch INT-1 -2100, Rev.8
- Dwg. 9321-LL-53253, Rev.2
- Dwg. 9321-F-25453, Rev.20
- Dwg. 9321-F-25463, Rev.12
"* "Limitation of Examination" Sheets (3 pages) for Welds (# 1 and 2) for the 2 nd Interval
PRESSUR I ZER VIEW A VIEW A 6" SAFETY (REr.l-4502) 6" SAFETY (REF.1-4501) 4" SPRAY (REF, -4504) 21-IR 50.5"R 5 1. 25" - 1 / 0 TC.
E-uO
"" 6" SAFETY REF. I-4503) 51.25,"- 00000 4"iriELIEF(RE-° 1-4505) z* L"ELr{E -0) 52.5" - to
- 50. -7 WELDS I THRU 17tSNELL.t4.75"T SA 302 GRADE 13 CARBON STEEL UPPER &'LOWER HEADa4,75"T SA216 GRADE WCC
/O CARBON STEEL NV I AMETEREs92 375" I CRCUMFERENCE 1290.05" NOZZLE TO NOZZLE VESSEL INSIDE WELDS iNOT APPLICABLE RADIUS SECTIONo 20IR THRU 2SIR INTEGRALLY WELDED ATTACHMENT SUPPORT SI<!RT WELD) 18.
I.S"'r CARBON STEEL PLATE TO SA516 GRADE 70 CARBON STEEL MANWAY BOLTINGO 16-1.88" DIAMETER 4 SUPPORTStREF. INT-1-21OOA
- 90. 25"
/ F3 NOTEiSAFETY NOZZLE LOCATIONS PER CON.ED. DRAWING A2D21O AND LINE NUMBER STAMPED ON INTEGRALLY WELDED ATTACHMENTS RC-H-342,RC-H-343 AND RC-H-344.
. 2 NOTEIWELD 2-0" TO 15" (ADJACENT WELD I) INACCESSIBLE 8B.5" _
DUE TO PERMANENT INSULATION.
'IWELD 19 LOCATED 25" CCW FROM WELD 2.
- 34. 25" ENTERGY NUCLEAR NORTHEAST
-INDIAN POINT UNIT NO.3 26.75"-
PRESSURIZER
"-25117 14" SURGE (REF.1-4500) RCPCPRI
-SUPPORTS (IEF. -2100Ai) INT- 1 -2 100
THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:
DWG. NO. 9321-LL-53253-2 "CONTAINMENT BUILDING PRESSURIZER - INSULATION SECTIONS.& DETAILS" q ""
WITHIN THIS PACKAGE...OR, BY SEARCHING USING THE DOCUMENT/REPORT DWG. NO. 9321-LL-53253-2 NOTE: Because of this page's large file size, it may be more convenient to copy the file to a local drive and use the Imaging (Wang) viewer, which can be accessed from the Programs/Accessories menu.
D-1
THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:
DWG. NO. 9321-F-25453-20 "CONTAINMENT BUILDING PRIMARY COOLANT PRESSURIZER SAFETY RELIEF VALVE PIPING - SHEET NO. 1" WITHIN THIS PACKAGE...OR, BY SEARCHING USING THE DOCUMENT/REPORT DWG. NO. 9321-F-25453-20 NOTE: Because of this page's large file size, it may be more convenient to copy the file to a local drive and use the Imaging (Wang) viewer, which can be accessed from the Programs/Accessories menu.
D-2
THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:
DWG. NO. 9321-F-2545463-12 "CONTAINMENT BUILDING PRIMARY COOLANT PRESSURIZER SAFETY RELIEF VALVE PIPING - SHEET NO. 2" WITHIN THIS PACKAGE...OR, BY SEARCHING USING THE DOCUMENT/REPORT DWG. NO. 9321-F-254563-12 NOTE: Because of this page's large file size, it may be more convenient to copy the file to a local drive and use the Imaging (Wang) viewer, which can be accessed from the Programs/Accessories menu.
D-3
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PROVIDE GENERAL INFORMATION TO DESCRIBE APPROXIMATE SIZE, LOCATION AND TYPE OF LIMITATION.
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INSULATION SUPPORT RING WELD CENTERLINE El 0 0 36.50CW 83.5'rCW
.0" REFERENCE INSULATION SUPPORT RING 5.6" FROM WELD TOE ON 5 SIDE LIMITS 60°, 5 SCAN 2 INSTRUMENTATION NOZZLES, 2 SIDE, 4" FROM WELD TOE LIMITS , LIMITS 45- & 60- SCAN FOR 4" 1 2"X2" WELDED PAD, 2 SIDE, 1.5" FROM TOE OF WELD, LIMITS ALL SCANS FOR 2" 9% EXAM REQUIRED VOLUME NOT COVERED.
450 99% EXAMINED 600 91% EXAMINED 00 99% EXAMINED J
Indian Point 3 3 rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER 3-16, Rev. 1 (Page 1 of 3)
A. COMPONENT INDENTIFICATION Code Class: 1
References:
Table IWB-2500- 1, Figure IWB-2500-7 Examination Category: B-D Item Number: B3.120
==
Description:==
Inspection of Pressurizer Nozzle Inside Radius Sections B. CODE REQUIREMENT Table IWB-2500-1, Category B-D, requires a volumetric examination of the pressurizer nozzle inside radius section.
C. RELIEF REQUESTED Indian Point 3 requests relief from the performing the code required volumetric examination of the pressurizer nozzle inside radius section.
D. BASIS FOR RELIEF Pursuant to 10 CFR 50.55a(3)(i), relief is requested on the basis that the proposed alternatives provide an acceptable level of quality and safety. The pressurizer was designed and fabricated to Codes in effect during the late 1960s. The Codes used did not provide for full access for inservice inspection, nor did they require a surface finish in the nozzle area suitable for UT examination. The design of the nozzles, utilizing a gradual inside radius section, is specifically intended to reduce stress in this area and minimize the conditions that might lead to cracking.
The nozzles on the pressurizer are cast with the vessel heads. The identification numbers for these nozzles are 201R, 211R, 221R, 231R, 241R, and 251R as shown on sketch INT-1 2100. The as-cast surface of the heads, combined with the geometry of this area, makes ultrasonic examination of the nozzle inner radii impractical (see drawing 681J281). The geometry and size of the nozzles are such that a radiographic examination is not feasible.
Specifically, the radiographic test film cannot be situated properly from the I.D. due to a lack of interior structure. Placement of the source will not allow proper film to source distance, resulting in greatly reduced sharpness. Surface and visual examinations would be restricted by anticipated high radiation levels and the as-clad surface.
Indian Point 3 3 rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER 3-16, Rev. 1 (Page 2 of 3)
A similar relief to perform only the visual, VT-2 examination was initially requested for the 2 n ISI Interval, but was granted with an additional condition to perform a remote video examination of the pressurizer nozzle inside radius sections, with the exception of the pressurizer surge nozzle (251R) which has a retaining basket covering the outlet to preclude remote visual examination (Reference SER dated December 21, 1994, TAC NO. M8269 for Relief Request No. 9). These pressurizer nozzle inside radius sections were remote visually inspected during the Second ISI Interval (Refueling Outage 10 in 1999). No evidence of cracking was found.
E. PROPOSED ALTERNATE EXAMINATION In lieu of the code-required volumetric examination all nozzles (with the exception of Pressurizer Surge Nozzle 251R) will be examined visually (VT-3) using a remote color video camera. This visual (VT-3) examination for all the accessible nozzles will be performed at the same time during an outage when the Pressurizer manway cover is removed for maintenance activities; or by the end of the 10-Year interval for ISI inspection. In addition, all nozzles will be visually examined (VT-2) at each refueling outage during system pressure tests in accordance with IWB-2500, Category B-P, and Code Case N-498-1. It is expected that any through wall defects would be detected by the proposed alternate examinations prior to failure of the component. This is based on the expectation that the component will experience leakage before a catastrophic failure ("leak before break")
F. JUSTIFICATION FOR RELIEF The type and frequency of examinations proposed for the nozzles are the same as previously approved for the 2 nd inspection interval. Based on the reliable operating history of this and similar vessel nozzles at other plants, and the satisfactory remote visual examination results from the inspection performed in 1999, the granting of this relief to perform the remote visual VT-3 and the VT-2 examination of the pressurizer nozzles during system pressure test will not decrease the overall level of quality and safety. The remote visual examination will be the alternate examination for the 3 rd Interval.
Since access to perform the VT-3 visual examination is through the pressurizer manway, it will be performed during the interval when the pressurizer manway is scheduled for removal due to maintenance purposes. Otherwise, the VT-3 examination will be performed at the end of the interval when the manway will be removed for the proposed alternate ISI examination. All the accessible nozzles will be examined at the same time to minimize impact on outage schedules, radwaste generation and radiation exposures. During the 2 n Interval, a total of 150 mRem was recorded for the performance of this remote visual (VT-3) examination.
Indian Point 3 3 rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER 3-16, Rev. 1 (Page 3 of 3)
G. PERIOD FOR WHICH RELIEF IS REQUESTED Relief is requested for the third inspection interval, July 21, 2000 through July 20, 2009.
H. ATTACHMENTS
"* Sketch INT-1-2100
"* Drawing 681J281, Rev.4
PRESSUR IZER VIEW A VIEW A 6" SAFETY (REP. 1-4502) 6" SAFETY (REF. 1-4501) 1t7 4" SPRAY (REF.1-4504) 50.5" ' 24 R 231R 5 1.25" 6" SAFETY (nEr.1-45o3) 000 4"'RELIEF(REF. 1-4505) 51 .25" 52.5" a 7 WELDS I THRU 17-SHELLi4.75"T SA 302 GRADE B CARBON STEEL UPPER &' LOWER HEAD14.75"T SA216 GRADE WCC
- -CARBON DIAMETERSTEEL
,92. 375" iC IRCUMFERENCE '290.05" 79.0"- NOZZLE TO VESSEL WELDSiNOT APPLICABLE
--5 NOZZLE INSIDE RADIUS SECTIONi 201R THRU 25IR INTEGRALLY WELDED ATTACHMENT SUPPORT SI(IRT WELD 18.
i.S','r CARBON STEEL PLATE TO SA516 GRADE 70 CARBON STEEL MANWAY 0OLTINGs16-I.e8" DIAMETER 4 SUPPORTStREF. INT-I-2100A
- :3 NOTEsSAFETY NOZZLE LOCATIONS PER CON.ED. DRAWING A20210B AND LINE NUMBER STAMPED ON INTEGRALLY WELDED ATTACHMENTS 2 RC-Hi-342 1 RC-H-343 AND RC-H-344.
NOTEtWELD 2-0" TO 15" (ADJACENT WELD I) INACCESSIBLE 68.5, DUE TO PERMANENT INSULATION.
WELD 19 LOCATED 25" CCW FROM WELD 2.
34 .25" -- / -1
- 34. 58ENTERGY NUCLEAR NORTHEAST INDIAN POINT UNIT NO.3 20.75" -
PRESSUR IZER
"-I4" SURGE (REF.I-4500) RCPCPRI
-SUPPORTS(IIEF.1I-2IOOA) 8N--2o
THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:
DWG. NO. 681J281 "GENERAL ASSEMBLY &
FINAL MACHINING" WITHIN THIS PACKAGE...OR, BY SEARCHING USING THE DOCUMENT/REPORT DWG. NO.68IJ281 NOTE: Because of this page's large file size, it may be more convenient to copy the file to a local drive and use the Imaging (Wang) viewer, which can be accessed from the Programs/Accessories menu.
D-4
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Attachment to IPN-02-024 RR 3-16, rev. 1 Section blowup of Dwg. 681J281 Bill of Material is PH SILL OF MATERIAL.
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INDIAN POINT UNIT NO. 3 THIRD INSPECTION INTERVAL RELIEF REQUEST NO. RR 3-17, Rev. 2 A. COMPONENT INDENTIFICATION IWA-4000/AII ISI Class 3 moderate energy service water piping.
B. CODE REQUIREMENTS ASME Code, Section Xl, IWA-431 0 requires that the defect be removed or reduced in size in accordance with Article IWA.
C. RELIEF REQUESTED:
Relief is requested from removing defects and repairing in accordance with the design specification or the original construction code for internal wall thinning or pitting resulting from conditions such as, but not limited to, microbiological corrosion; cavitations induced pitting; erosion/corrosion and/or localized pitting corrosion.
The ASME Section XI Code Committee recognized that an alternative repair approach existed for internal wall thinning of Class 3 piping systems which have experienced degradation mechanisms, such as flow-assisted corrosion and/or microbiological corrosion that would provide an acceptable repair configuration. This alternative repair technique as described in Code Case N-562-1 involves the application of additional weld metal on the exterior of the piping system, which restores the wall thickness requirement. Code Case N-562-1 was approved by the ASME Section XI Code Committee on July 30,1998. However, it has not been incorporated into NRC Regulatory Guide 1.147 and thus is not available for application at nuclear power plants.
Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety. This relief request applies to all ASME Class 3 moderate energy (i.e., less than or equal to 200OF and/or less than or equal to 275 psig maximum operating conditions) carbon steel plant service water piping systems.
Entergy Nuclear Operations, Inc. (ENO) also proposes to use the following welding processes for the weld overlay: Shielded Metal Arc Welding (SMAW); Gas Tungsten Arc Welding (GTAW) -manual and/or automated); Gas Metal Arc Welding (GMAW) and Flux Cored Arc Welding (FCAW). The overlays may be installed on water backed piping or piping that is empty.
D. BASIS FOR RELIEF Code Case N-562-1 provides alternative requirements to those of IWA-4000 and for the repair of internal piping system defects or degradation. The ASME Xl Code Committee determined that the weld overlay would ensure that an adequate level of quality and safety was being maintained. Therefore, the proposed alternative is justified per 10CFR50.55a(a)(3)(i) as the proposed repair will provide an acceptable level of quality and safety. The primary purpose for implementing this repair method is to allow adequate time for additional examination of adjacent piping so that pipe replacement 1
INDIAN POINT UNIT NO. 3 THIRD INSPECTION INTERVAL RELIEF REQUEST NO. RR 3-17, Rev. 2 can be planned to reduce impact on system availability including Maintenance Rule applicability, availability of replacement materials and cost. In addition, use of Code Case N-562-1 may reduce outage schedules, as installation of a weld overlay would avoid the need for a pipe replacement and corresponding system line-ups and drain downs during scheduled refueling outages.
A similar relief request was approved at Southern Nuclear Operation Company's Hatch Plant, Units 1 and 2 (Reference SER dated May 31, 2000, TAC Nos. MA 6123 and MA 6124).
E. ALTERNATIVE REPAIR TECHNIQUE:
ENO will implement the requirements of Code Case N-562-1 in its entirety with the additional restrictions and exceptions as described below, for Class 3 moderate energy (i.e., _ 200OF and/or _275 psig maximum operating pressure) piping system repairs resulting from phenomenon such as flow-assisted corrosion and/or microbiological corrosion. These types of defect are typically identified by small leaks in the piping system or by pre-emptive non-code and code-required examinations performed by the licensee to monitor the degradation mechanisms. The repair technique described in Code Case N-562-1 will be utilized whenever engineering evaluation determines that such a repair is suitable for the particular defect or degradation being resolved.
Provisions for use of this Code Case will be addressed in the repair and replacement program procedure. These provisions will require that adjacent areas be examined to verify that the repair will encompass the entire flawed area and that there are no other unacceptable degraded locations within a representative area dependent on the degradation mechanism present. An evaluation of the degradation mechanism will be performed to determine the re-examination schedule to be performed over the life of the repair. The repair will be considered to have a maximum service life of two operating cycles at which time an ASME Section Xl code repair (typically a pipe replacement) will replace the weld overlay unless specific approval is requested and received from the NRC to make it permanent.
The NRC had previously approved Indian Point Unit 3 relief request No. 3-7 (Reference SER dated May 17, 2001, TAC NO. MA9757) to utilize ASME Section XI Code Case N 532. Code Case N-532 provides alternatives for the documentation requirements for repair and replacement activities. Code Case N-532 allows use of Form NIS-2A in lieu of Form NIS-2 as required by Code Case N-562-1, paragraph 7.0. Therefore, Entergy will document the use of Code Case N-562-1 on Form NIS-2A in lieu of Form NIS-2.
F. IMPLEMENTATION SCHEDULE The relief request is applicable for the Third 10-Year Interval and will be utilized upon receipt of NRC approval.
G. ATTACHMENTS TO THE RELIEF REQUEST:
2
Mk *-/oze-a CASE Rk. 3- /"7, v,2_
N-562-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: July 30, 1998 See Numeric Index for expiration and any reaffirmation dates.
Case N-562-1 Case shall not apply. In addition, the total thickness Alternative Requirements for Wall Thickness -of filler metal applied over multiple repairs shall not Restoration of Class 3 Moderate Energy Carbon exceed the original nominal thickness of the piping.
Steel Piping Section XI, Division 1 Inquiry: As an alternative to replacement or internal 2.0 INITIAL EVALUATION weld repair, what requirements may be applied for The material beneath the surface to which the weld wall thickness restoration of Class 3 moderate-energy overlay is to be applied shall be evaluated to establish carbon steel piping systems that have experienced in ternal wall thinning or pitting from conditions such the existing average wall thickness and the extent and as, but not limited to, flow-assisted corrosion and mi configuration of degradation to be reinforced by the weld overlay. Consideration shall be given to the cause crobiological corrosion?
of degradation. The extent of degradation in the piping, Reply: It is the opinion of the Committee that areas and the effect of the repair on the piping, 3 shall be of Class 3 moderate energy (i.e., less than or equal evaluated in accordance with IWA-4160.
to 200*F or and less than or equal to 275 psig maxi mum operating conditions) carbon steel piping experi encing internal thinning or pitting may have the wall 3.0 DESIGN thickness restored externally by means of a weld deposited carbon or low-alloy steel reinforcement on 3.1 General Design Requirements the outside surface of the piping in accordance with (a) Unless otherwise established by theoretical or the following requirements. Excluded from these pro experimental analysis, or by proof testing as provided visions are conditions involving corrosion-assisted for in para. 3.3 or para. 3.4, the full thickness of the cracking or any other form of cracking.
weld overlay shall extend a distance of at least s in each direction beyond the area predicted, over the design life of the restoration to infringe upon the required thickness.4 1.0 GENERAL REQUIREMENTS where (a) The wall thickness restoration shall be performed in accordance with a Repair/Replacement Plan satisfying S= >:%N[R-J' m the requirements of IWA-4150) R = outer radius of the component (b) The wall thickness restoration shall meet the tnom = nominal wall thickness of the component requirements of IWA-4000, 2 except as stated in this Case. Edges of the weld overlay shall be tapered to the (c) If the minimum required thickness of deposited existing piping surface at a maximum angle ("a" in weld metal necessary to satisfy the requirements of Fig. 1) of 45 deg. Final configuration of the reinforce para. 3.0 is greater than the nominal thickness for the ment shall permit the examinations and evaluations size and schedule of the piping, the provisions of this required herein, including any required preservice or
.. nserace-_examinations of- -encompassecd -or-- adjacent__
'IWA-4140 in the 1989 Edition with the 1991 Addenda through 1995 Edition. IWA-4130 (Repair Progam) in the 1989 Edition with 3
the 1990 Addenda and earlier Editions and Addenda. IWA-4150 in the 1989 Edition with the 1991 Addenda 2 through IWA-4000/7000 and IWC/IWD-4000/7000, as applicable, in the 1995 Edition. IWA-4130 (Repair Program) in the 1989 Edition with 1989 Edition with the 1990 Addenda and earlier Editions and the 1990 Addenda and earlier Editions and Addenda.
4 Addenda. Design thickness as prescribed by the Construction Code.
919 SUPP. 2 - NC
CASE (continued)
N-562-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE (b) The thickness shall be sufficient to maintain (1) the base metal is of the same P-No. and Group required thickness for the predicted life of the repair, Number when impact properties are applicable, as the and, except for the tapered edges, the overlay shall base metal tested; have a uniform thickness. (2) the specified minimum tensile strength of the (c) The tensile strength of the weld filler metal for item does not exceed that specified for the base metal the reinforcement shall be at least that specified for tested; the base metal to which it is applied. (3) the average thickness of the overlay areas is (d) The predicted maximum degradation of the over at least the thickness of the mockup plug, u; laid piping and the overlay over the design life of (4) the overlap on the full thickness of base metal, the restoration shall be considered in the design. The s, is at least that of the mockup; predicted degradation of the piping shall be based upon (5) the transition angle at the outer edges of the in-situ inspection and established data for similar base overlay, a, is not greater than that of the mockup; metals. If the weld overlay is predicted to become (6) the overlay surface finish is similar to or exposed to the corroding medium, the predicted degrada smoother than that tested; tion of the overlay shall be based upon established data (7) the maximum proportionate axial dimension, for base metals or weld metals with similar chemical LID, is not more than that tested; composition to that of the filler metal used for the (8) the maximum proportionate circumferential di weld overlay. mension, CID, is not more than that tested; (e) The effect of weld overlay application on interior (9) the nominal diameter is not less than one-half coating shall be addressed in the Repair/Replacement nor more than two times the diameter tested; Plan [Repair Program]. (10) the nominal thickness/diameter ratio, tMD, is not less than one-half nor more than three times the 3.2 Design tMD, ratio tested.
(b) The mockup base shall consist of new base The design of weld overlays not prequalified by material of similar configuration, or type of item, as paras. 3.3, 3.4, or 3.5 shall be in accordance with the the item to be overlaid. A rounded-corner segment of applicable requirements of the Construction Code or the base material shall be removed to represent the ND-3100 and ND-3600 (including Appendix II), and maximum proportionate size (axial dimension of L and shall consider the weld overlay as an integral portion circumferential dimension of C) and location of thinning of the piping or component upon which it is applied or pitting to be compensated for by the weld overlay.
(not as a weld). The allowable stress values of the A plug of the same base metal and of uniform thickness base metal shall apply to the design of the deposited u, which shall not exceed the smallest average thickness weld metal. The following factors shall be considered, on which the overlays will be permanently applied, as applicable, in the design and application of the shall be full-penetration welded around the opening reinforcement: and flush with the outside surface of the piping. Alterna (a) The shrinkage effects, if any, on the piping. tively, an equivalent volume of base metal may be (b) Stress concentrations caused by application of removed from the inside surface of the mockup by the overlay or resulting from existing and predicted machining or grinding, without need for welding in a piping internal surface configuration. closure plug.
(c) The mockup weld overlay shall be applied in 3.3 Proof Test Qualification as a Piping Product accordance with the design or specified configuration using the specified weld filler metal. Maximum section As an alternative to design, the configuration of weld thickness at the overlaid opening (weld metal plus base overlays may be qualified by performance of proof metal plug, u + w) shall not exceed 871/2% of the testing of a mockup in accordancewith- -the following -nominal -thickness of the -piping.
requirements: (d) Straight pipe equivalent to a minimum of one (a) A satisfactory mockup burst test shall qualify pipe diameter, or one-half diameter for piping over the design or configuration for application in the same NPS 14, shall be provided (butt-welded to the mockup, orientation on the same type of item, and the same if necessary) beyond both ends of the overlay. The location on fittings, when the following conditions are piping shall be capped and the completed mockup satisfied (see Fig. 1): assembly shall be thoroughly vented and hydrostatically SUPP. 2 - NC 920
CASE (continued)
N-562-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE pressure tested to bursting. To qualify the design for provided all of the following conditions are satisfied general application within the limits of para. 3.3(a), in Fig. 1:
burst pressure shall not be less than: (a) All of the requirements of para. 3.1 apply.
(b) The provisions of para..3.3(e) shall be met.
p = 2tSact (c) The full thickness of weld overlay shall not D, exceed a maximum axial length of the greater of six in. or the outside diameter of the piping.
where (d) The finished overlay shall be circular, oval, full P = minimum acceptable burst pressure, psi circumferential, or rectangular in shape.
t = minimum specified thickne ss (excluding manu (1) For each repair, the maximum dimension com facturing tolerance) of the base metal being pensated by a circular overlay shall not exceed 2/3 the tested, in. nominal outside diameter of the piping.
Sa. = reported actual tensile strength of the base metal (2) Rectangular overlays shall be aligned parallel being tested, psi with or perpendicular to the axis of the piping, and D, = outside diameter of the pipe, in. comers shall be rounded with radii not less than the overlay thickness.
(e) If flexibility analysis was required by the original (3) For oval overlays, the end radii shall not be Construction Code, the effect of the weld overlay shall less than 3/4ivRZ-n, and the axis of the overlay shall be reconciled with the original analysis. In this case, be aligned parallel with or perpendicular to the axis for rectangular-shaped overlays on piping designed to of the piping.
ND-3650 and aligned parallel or perpendicular to the (e) The distance between toes of adjacent overlays axis of the piping, unless a lower stress intensification shall not be less than t.or..
factor (SIF or i) is established, an SIP (i) of 2.1 shall be applied for overlays on straight pipe and adjacent welds; a stress multiplier of 1.7 shall be applied to 4.0 Water-backed Applications the SIF (i) for standard elbows; and an SIF (i) of 2.1 (a) Manual application of overlays on water-backed shall be applied for tees and branch connections when piping shall be restricted to P-No. 1 base materials.
the toe of the overlay is not less than 2'/24i ..from Welding of such overlays shall use the SMAW process any branch reinforcement in Fig. 1. and low-hydrogen electrodes. In addition, the surface 3.4 Proof Test Qualification for Specific examination required in para. 6.0 shall be performed Applications no sooner than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after completion of welding.
For such overlays consideration should be given to As an alternative to design by. analysis or proof using a temper bead technique similar to that described test qualification as a piping product, the design or in IWA-4650.'
configuration of weld overlays may be qualified for (b) Piping with wall thickness less than the diameter limited service conditions using the provisions of of the electrode shall be depressurized before welding.
ND-6900. "Proof Tests to Establish Design Pressure,"
except that component hydrostatic testing is not required (other than as required by IWA-4000 2 ). The mockups 5.0 INSTALLATION shall be fabricated and tested in accordance with the (a) The entire surface area to which the weld overlay provisions of para. 3.3(b), (c), and (d), and shall be is to be applied shall be examined using the liquid applied in accordance with the provisions and conditions penetrant or magnetic particle method, with acceptance of para. 3.3(a). The provisions of para. 3.3(e) shall criteria in accordance with ND-2500/5300 for the prod be met. uct form (base metal or weld) involved. -Prequalifled -Design. __.(b) _If through-_wall-repairs-are required to satisfy- the acceptance criteria, or result from application of the Application of weld overlays on straight pipe, portions of tees not less than 21/2,4R-t' from any branch 5 IWA-4540 in the 1989 Edition with the 1991 Addenda through reinforcement in Fig. 1 standard elbows, and associated the 1995 Edition. IWE-4200 in the 1986 Edition with the 1988 welds to correct limited degradation shall be exempt Addenda through the 1989 Edition with the 1990 Addenda. IWE-4320 in the 1986 Edition with the 1987 Addenda and earlier Editions and from the requirements of para. 3.2 through para. 3.4, Addenda.
921 SUPP. 2 - NC
CASE (continued)
N-562-1 CASES OF ASMEBOILERAND PRESSURE VESSEL CODE weld overlay, they shall be accomplished by sealing (c) Weld overlays shall be volumetrically examined with weld metal using a qualified weld procedure as base metal repairs when required by the Construction suitable for open-root welding. This weld shall be Code, except as follows:
examined in accordance with para. 5.0(a). In addition, (1) Weld overlays not exceeding 10 in. 2 surface the first layer of overlay over the repaired area shall area are exempt from volumetric examination.
be examined in accordance with para. 5.0(a). (2) Other weld overlays shall be exempt from S(c) Overlay weld metal shall be deposited using a volumetric examination when the finished applied thick grove-welding procedure qualified in accordance with ness (w in Fig. 1) does not exceed.
Section IX and the Construction Code,Section X and (a) il3t for t < 3/4 in.
Section III, or IWA-4610 and either lWA-4620 or (b) 1/4 in. for 34 in. < t _<21/2 in.
IWA-4650. 6 The qualified minimum thickness specified (c) The lesser of 3 in. or 10% of t for t >
in the weld procedure does not apply to the weld 2'!2 in.
overlay or associated base metal repairs.7 where (d) The surface of the weld overlay shall be prepared t= finished fall-section thickness of compensated by machining or grinding, as necessary, to permit area (e.g., w + u, in Fig. 1) performance of surface and volumetric examinations required by para. 6.0. For ultrasonic examination, a When volumetric examination is required, the full surface finish of 250 RMS or better is required. volume of the finished overlay, excluding the tapered edges, but including the volume of base metal required for the design life of the overlay, shall be examined using either the ultrasonic or radiographic method, and shall, to the depth at the surface of the existing piping, 6.0 EXAMINATION satisfy the acceptance criteria for weldments of the Construction Code or ND-5300. The volume of the (a) The completed weld overlay shall be examined existing piping, beneath the weld overlay, taken credit using the liquid penetrant or magnetic particle method for in the design, shall satisfy the volumetric acceptance and shall satisfy the surface examination acceptance criteria of ND-2500/5300 for the product form, or criteria for welds of the Construction Code or ND-5300. IWA-3000. 8 (b) The weld overlay, including the existing piping (d) Follow-up inspection shall be scheduled as neces upon which it is applied, shall be examined to verify sary to confirm any design assumptions relative to rate acceptable wall thickness. or extent of future degradation.
7.0 DOCUMENTATION 6
1WA-4500 and either IWA-4510 or IWA-4540 in the 1989 Edition with the 1991 Addenda through 1995 Edition. IWA-4510 or IWE-4200 Use of this Case shall be documented on an NIS-2 in the 1986 Edition with the 1988 Addenda through 1989 Edition Form.
with the 1990 Addenda. IWB-4320 or IWE-4320 in the 1986 Edition with the 1987 Addenda or earlier Editions and Addenda.
7 Exception to IWA.4000. "8IWA-3000 and IWB-3514 in the 1989 Edition with the 1990 Addenda and earlier Editions and Addenda.
SUPP. 2 - NC 922
CASE (continued)
N-562-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE X -Lmit of branch reinforcement FIG. 1 922.1 SUPP. 2 - NC