ML033230347
| ML033230347 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/06/2003 |
| From: | Salas P Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MB9085, TAC MB9086 | |
| Download: ML033230347 (21) | |
Text
-
Tennessee Valley Authorty. Post Office Box 2000, Soddy-Daisy, Tennessee 37384-2000 November 6, 2003 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING ASME SECTION XI INSERVICE INSPECTION (ISI) PROGRAM RELIEF REQUESTS 1-ISI-23, 1/2-ISI-24, AND 1/2-ISI-25 (TAC NOS. MB9085 AND MB9086)
Reference:
TVA letter to NRC dated May 13, 2003, "Sequoyah Nuclear Plant (SQN) - American Society of Mechanical Engineers (ASME)Section XI Inservice Inspection (ISI) Program - Relief Requests" The purpose of this letter is to provide additional information requested during an October 14, 2003 teleconference between your staff and TVA ISI personnel.
Enclosure 1 contains additional information requested to support ongoing review of ASME code relief requests for SQN as contained in TVA' s referenced letter. The additional information is associated specifically with relief requests 1-ISI-23, 1/2-ISI-24, and 1/2-ISI-25.
In addition, please note that relief request 1/2-ISI-25 has been revised to correct two discrepancies discovered during preparation of the enclosed additional information. The discrepancies are described as follows:
- 1) Examination coverage for 1-ISI-25 and 2-ISI-25 was recalculated and found to be 67 percent rather than 75 percent.
,4DSeo1`
Red ma recyW pare
U.S. Nuclear Regulatory Commission Page 2 November 6, 2003
- 2) The number of integral attachment lugs is 17 for the Unit 1 relief request 1-ISI-25 and 16 for the Unit 2 relief request 2-ISI-25, rather than 16 for both units.
The above discrepancies have been documented in TVA's corrective action program and revised relief requests 1/2-ISI-25 with their associated inspection reports are being resubmitted in Enclosures 2 and 3, respectively. The revised relief requests supersede the original relief requests from TVA's referenced letter.
No commitments are made in this response. Please direct questions concerning this issue to me at (423) 843-7170 or J. D. Smith at (423) 843-6672.
Licen g and Industry Affairs Manager Enclosures cc (Enclosures):
Mr. Michael L. Marshall, Jr., Senior Project Manager U.S. Nuclear Regulatory Commission Mail Stop O-8G9A One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739
ENCLOSURE 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING ASME CODE INSERVICE INSPECTION (ISI)
RELIEF REQUESTS FOR 1-ISI-23, 1/2-ISI-24, AND 1/2-ISI-25 The following is a restatement of NRC's request for information, followed by the TVA response.
- 1. NRC Request (1-ISI-23)
"Has the licensee considered inspecting similar components with no access restrictions for the Code required examination. Specifically, components with comparable Risk Informed ISI implications? If not, please explain why this was not considered."
TVA response:
Piping weld RHRF-107 is subject to a postulated failure mechanism of stress corrosion cracking. Based on this postulated failure mechanism and the fact that the segment which includes this weld is a high-safety significant segment, this portion of the piping segment is placed in Sub-Region 1A in accordance with the Risk-Informed Topical Report WCAP-14572, Revision 1. Sub-Region 1A welds are required to be examined and are not subject to a selection process. No other welds in this piping segment are placed in Sub-Region 1A.
- 2. NRC Request (1-ISI-24 & 2-ISI-24)
"The Summary on P. E2-2 discussed impracticality while Justification on P. E2-4 talked about hardships. Please clarify if the examination can be performed given the hardships."
TVA Response A best-effort examination of the pressurizer support skirt welds could possibly be performed if the immersion heaters and wiring and insulation were removed. Radiological dose that would be received performing these tasks must also be considered. The information on page E2-4 was included to identify why it is impractical to perform the surface examination between the pressurizer bottom head and the EI-1
inside of the support skirt in the examination area C-D.
Due to the configuration of the pressurizer bottom head to support skirt weld, the hardships in providing access and the radiological dose that would be received, it is impractical to perform the surface examination of examination area C-D. In addition, the supplemental Ultrasonic Examination (UT) performed provides an acceptable alternative without the health consequence of the .higher radiation dose. The UT examination performed provides assurance that no cracking exists in the pressurizer bottom head to support skirt weld.
- 3. NRC Request (1-ISI-24 & 2-ISI-24)
"Alternative Examination on P. E2-3, '... a 100% surface examination on surface A-B as illustrated.in Figure IWB-2500-13 and... .was performed on both welds.' Please clarify why surface C-D is not accessible as the drawing does not indicate as such."
TVA response The drawing was provided to identify the welds subject to examination. The drawing shows the pressurizer bottom head to skirt weld but does not show the attached 78 immersion heaters and wiring or the space limitations and insulation between the pressurizer shirt weld and the bottom head. The 78 immersion heaters and attached wiring are located on the bottom head between the surge nozzle and the pressurizer skirt. This restriction does not allow direct access to the inside of the pressurizer skirt weld examination area C-D. In addition, insulation removal would require disconnecting the immersion heater wiring.
The following is background information on the examinations that were performed during the first inspection ISI interval. The ASME code of record for the first inspection interval was the 1977 Edition with the Summer 1978 Addenda.
The code examination category B-H, item number B8.20, figure IWB-2500-13 requirement for the pressurizer support skirt integral attachment weld was to examine area A-B only using a surface examination method. TVA used the magnetic particle method for this examination. The first inspection interval code of record did not have a requirement to examine area C-D.
- 4. NRC Request (1-ISI-25 & 2-ISI-25)
"In Justification on P. E2-9, 'The design configuration of the subject weld (partial penetration), Item No.5 (base plate) to Item No.1 (strainer) precludes visual examination El-2
of essentially 100% of the required examination area. In order to visually examine the weld in accordance with the code requirement, the ERCW strainer would require extensive disassembly in order to access the inside surface of the strainer. In order to dissemble the subject strainer, a temporary monorail is required to be installed due to limited overhead clearance,' the paragraph indicated it is accessible. So this is actually a hardship instead of impracticality. The Executive Summary says 'impractical'.
From the drawing provided, it does not appear that the locations are inaccessible. Please clarify."
TVA response TVA's selection of impractical versus hardship is based on the significant extent of plant disassembly required for examination. The subject weld is located on the underside of the strainer base flange which is bolted flush with plates that are also bolted to the floor. This makes the weld inaccessible. Examination of this weld requires disassembly of the strainer as shown in detail A on the drawing provided. Access to the underside surface of the base flange would require disconnecting the 24-inch diameter piping, unbolting the strainer from the floor base plates, and raising the strainer. TVA' s evaluation of these constraints concludes that the weld on the inside surface area is inaccessible for either full or partial examination. Accordingly, TVA considers examination to be impractical.
The structural integrity of the support is maintained by the accessible integral attachment welds on top of the base plate. This includes the fillet weld 360 degrees around the strainer at the base plate and the fillet welds on both sides on each of the attachment lugs to the strainer.
During performance of the examination, the examiner is to be within 2 feet of the examination surface for the VT-i examination instead of 4 feet as required for VT-3 examination. This closer distance required by the VT-i examination would enable the examiner to detect discontinuities and imperfections on the surface instead of examining for general mechanical and structural conditions as required by VT-3. The inaccessible integral attachment weld on the bottom of the base plate is not necessary for the integral attachment to perform its intended function of providing support for the ERCW strainer.
- 5. NRC Request (1-ISI-25 & 2-ISI-25)
"Page E2-9, Justification. VT-3 looks for different thing as compared to VT-1. Please explain why using VT-1 is E1-3
better than VT-3. How is a VT-1 more detailed than a VT-3, and why it is appropriate in this case?"
TVA response In accordance with ASME Section XI, the VT-i examinations are conducted to detect discontinuities and imperfections on the surfaces of components such as cracks, wear, corrosion, or erosion. The VT-3 examinations are conducted to determine the general mechanical and structural condition of the component or component support. The VT-i examination has more stringent distance requirements than the VT-3 examination. The VT-i examination performed on these welded attachments was a more detailed visual examination and would fulfill the requirements for the VT-3 examination. The VT-i examination method was selected because Code Case N-509 requires a VT-i examination. A VT-3 examination was also performed on these supports when the VT-i examination was performed on the attachment welds..
The following is background information on the examinations that were performed during the first ISI inspection interval. The ASME code of record for the first inspection interval was the 1977 Edition with the Summer 1978 Addenda.
The code examination category D-A, item number D.1.2 requirement was to examine component supports on components greater that 4 inches in diameter using the VT-3 examination method to determine the general mechanical and structural conditions of the support. This code of record for the first inspection interval did not have a separate requirement for Class 3 integrally-welded attachments.
- 6. NRC Request (ISI-24 & ISI-25)
"The staff believes that RRs ISI-24 & ISI-25 are alternatives, which requires prior NRC approval. Please explain why these relief requests were not submitted for approval prior to the implementation."
TVA response The examinations of these welded attachments are required to be performed in accordance with ASME Section XI. The limitations were identified at the time of examination.
The pressurizer support-skirt attachment weld surface examination was supplemented with a UT examination at the time of the examination to support request for relief ISI-
- 24. Performance of the UT examination on the inaccessible area C-D from the accessible surfaces provides assurance of the structural integrity of the weld.
E14
The visual examination for the raw-cooling water (ERCW) system strainer support attachment weld was performed using the VT-I method. The VT-i examination is a more stringent visual examination than the required VT-3 examination and was performed for Code Case N-509. Performing the VT-1 examination on the accessible area provided more assurance of the structural integrity of the weld.
El-5
ENCLOSURE 2 REVISED INSERVICE INSPECTION (ISI) RELIEF REQUESTS 1-ISI-25 and 2-ISI-25 Request for Relief 1-ISI-25 and 2-ISI-25 Note: Bolded text reflects revisions.
Executive Summary:
TVA is requesting relief from the ASME code to address the Unit 1 and Unit 2 essential raw cooling water (ERCW) system strainer support AlA-A Unit 1 and A2A-A Unit 2 integral attachment. The design configuration of the ERCW strainer to support interval attachment weld precludes a 100% visual VT-3 examination of the required area. These physical examination limitations occur when the 1989 Code examination requirements are applied in areas of components constructed and fabricated to early plant physical designs. Based on the date of Sequoyah Nuclear Plant's (SQN) construction permit (May 27, 1970), SQN is exempt from the code requirements for providing original design and examination access as allowed in 10 CFR 50.55a(g)(4).
An inservice visual examination was performed on accessible areas to the maximum extent practical, given the physical limitations of the subject welds. The design configuration limits visual examination to approximately 67% on both welds. Performance of a visual examination of essentially 100% of the subject integral attachment welds would be impractical. The maximum extent practical visual examination of the subject welds provides reasonable assurance of an acceptable level of quality and safety because the information and data obtained from the area examined provides sufficient information to judge the overall integrity of the welds.
Therefore, pursuant to 10 CFR 50.55a(g)(5)(iii), it is requested that relief be granted, for the second inspection interval.
Unit: 1 and 2 System: ERCW System (System 67)
Components: ERCW Strainer Support Integral Attachment Weld ASME Code Class: ASME Code Class 3 (Equivalent)
E2-1
Request for Relief 1-ISI-25 and 2-ISI-25 (continued)
Section XI Edition: 1989 Edition Code Table: IWD-2500-1 Examination Category: D-A, Systems in Support of Reactor Shutdown Function (ASME Code Case N-509 Integral Attachments for Class 3 Vessels, Piping, Pumps and Valves)
Examination Item No.: ASME Section XI Item Number D1.20, Integral Attachment - Component Supports and Restraints (ASME Code Case N-509, Item No. D1.10)
Code Requirement: ASME Section XI, Table IWD-2500-1, Examination Category D-A, Item Number D1.20, Requires VT-3 Examination (ASME Section XI Code Case N-509 Item No. D1.10 Requires VT-1 Examination)
Code Requirement From Which Relief Is Requested: Visual VT-3 Examination Coverage of Essentially 100% of the ERCW Strainer Support Integral Attachment Weld List of Items Associated With the Relief Request: ERCWSH-05-IA, Integral Attachment Weld (Unit 1)
ERCWSH-11-IA, Integral Attachment Weld (Unit 2)
Basis for Relief:
The design configuration of the ERCW strainer support precludes a complete visual VT-3 examination of the required area for the integral attachment weld ERCWSH-05-IA (Unit 1) and ERCWSH-11-IA (Unit 2). These areas are not accessible for visual examination due to the location and configuration between the strainer and the concrete floor. The design configuration and location limits visual examination to approximately 67% of weld ERCWSH-05-IA for Unit 1 and 67% of weld ERCWSH-11-IA for Unit 2 of the required E2-2
Request for Relief 1-ISI-25 and 2-ISI-25 (continued) examination areas as calculated in accordance with TVA Procedure N-GP-28.
Alternative Examination:
In lieu of the code required 100% VT-3 visual examination, a VT-i visual examination of the ERCW strainer integral attachment weld was performed on accessible areas to the maximum extent practical given the physical limitations. Refer to attached examination reports.
Justification for the Granting Of Relief:
The design configuration of the subject weld (partial penetration) Item No. 5 (base plate) to Item No. 1 (strainer) precludes visual examination of essentially 100%
of the required examination area. In order to visually examine the weld in accordance with the code requirement, the .ERCW strainer would require extensive disassembly in order to access the inside surface of the strainer. In order to dissemble the subject strainer, a temporary monorail is required to be installed due to limited overhead clearance.
The physical arrangement of the ERCW strainer is composed of 17 integral lugs for Unit 1 and 16 integral lugs for Unit 2 (Item No. 30) attachments that support the strainer body No. 1 to a base plate connection (Item No. 5). As part of the integral attachment, the base plate assembly (Item No.
- 5) is attached to the strainer body (Item No. 1) by a partial penetration weld from the inside surface for 360 degrees and a fillet weld 360 degrees around the outer circumference for 360 degrees. Each of the attachment lugs and outer base plate to strainer body welds are accessible from the outside surface. The inside surface partial penetration weld does not allow access for visual examination. The amount of examination coverage, when considered in total weld length examined, was determined to be approximately 67%.
Radiographic examination from the outside surface as an alternate volumetric examination method was determined to be impractical due to the support attachments affecting radiographic quality. Performing radiographic examination from the inside surface of the ERCW strainer would require placing a radiographic source near the center of the E2-3
Request for Relief 1-ISI-25 and 2-ISI-25 (continued) component. The ERCW strainer would require complete extensive disassembly and taken out of service for an extended period of time. Radiographic quality would be compromised due to the support attachments and the subject contrast effects from conditions associated with a partial penetration weld (i.e., butt joint match lines would mask indication due to the partial penetration condition). Thus, additional radiography from the inner surface, to gain any additional coverage, are also impractical.
Performance of an ultrasonic volumetric examination to supplement the required coverage was also deemed to be impractical. The design configuration of the partial penetration weld is not amenable for the detection of circumferential flaws due to the partial penetration condition (i.e., discrimination of weld flaws is masked due to the partial penetration weld geometry). In addition, the fillet weld impedes the search unit position from the outside surface such that the ultrasonic beam cannot be oriented for detection of radial oriented flaws. The support attachments are 1-inch thick welded lugs equally stationed at 17 positions for Unit 1 and 16 positions for Unit 2 around the strainer. The lug attachments, along with baseplate boltings/holes, would in addition interfere with the sound beam from being directed to the inner-weld region.
Performing a surface examination from the inside was determined to be impractical due to the same reasons as the visual examination.
The more detailed VT-1 visual examination was performed in lieu of the VT-3 examination.
The high percentage (67%) of the VT-l visual examination of the subject weld areas and adjacent base metal was obtained.
This examination coverage provides reasonable assurance of an acceptable level of quality and safety. The weld areas examined provide sufficient information to judge the overall integrity of the weld. Significant degradation, if present, would be detected during the VT-1 visual examination of the subject weld.
As a result, assurance of structural integrity for these welds is provided by the examinations that were performed.
E2-4
Request for Relief 1-ISI-25 and 2-ISI-25 (continued)
Therefore, pursuant to 10 CFR 50.55a(g)(5)(iii), it is requested that relief be granted for the second inspection interval.
Implementation Schedule:
This request for relief'is applicable to the second 10-year ISI interval for SQN Unit 1 and Unit 2. Weld ERCWSH-05-IA for Unit 1 and ERCWSH-11-IA for Unit 2 were examined in the first period.
References:
- Revised Examination Data Reports:
R7152 Unit 1, Ri R5762 Unit 2, Ri * - ISI Program Drawing:
ISI-0285-C-01 (Unit 1)
ISI-0268-C-01 (Unit 2) * - Examination Limitation Drawing Typical of Unit 1 and Unit 2 * - Nondestructive Examination Procedure N-GP-28, "Calculation of ASME Code Coverage for Section XI NDE Examinations"
- Enclosures 4, 5, and 7 remain unchanged from the original enclosures provided by TVA letter dated May 13, 2003.
E2-5
ENCLOSURE 3 REVISED EXAMINATION DATA REPORTS R7152 Unit 1 R5762 Unit 2 E3-1
V TENNESSEE VALLEY AUTHOR Y RECORD OF VISUAL EXAMINATION
'AM DATE:L-Z 5 f' PROCEDURF N-VT-1, REV-it TC: 97--Z5 RERT NUTfBE R -
LANT: 56A0P UNIT: CYCLE: f5 INSERVICE PRESERVICE COMPONENT ID: Eeeto511 /,I MODIED PORION ONLY: YES El NO a DRAWINGNO: '5/- oZ8s- d - of SYSTEM: -Ields CODECATEGORY: b-A COMPONENT TYPE: SUPPORT [ BOLTING El PUIMPALJVE Cl DMTGRAL ATTACH (A) 0 TYPE OFVISUALEXM: VT-1i VT-3 E DIRECT19 REMOTE El VISUAL AID(S):fLeLiflkde4 ATTRIBUTE ACCEPT REJECT NIA SUPPORT TYPE:
DEFORPUNED OR SHEARED El RIGO SUPPORT O CONSTANT FORC BOLTIS{TUDS SEADS (VT-I) El 1 EVARIABLE SPRING [I S1UBMER /
CORROSION (VT-) 1 0 E ° DUALSPRINGISNUBBER LOOSEBOLONG (Vt-I) E El YES O NO TrHREAD ENGAGE11ENT (Vl-l) 1 ] CI.X COOLANT LEAKAGE (Vl-l) EE]
O Type:
CRACKS/FRACTURRES (VT-1,3) ____* El El Model:
SIRUCTURAL DISTORTIONI Size:
DEGRADATION (VT-I1 0 .__Ol Range: (1)
PHYS. DAMAGE/ Set!g (1) VA DISPLACEMENT (VT-1.3) !El RPng: (2)
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P.E.R resolution of exam coverage estimation Date: 10/16/2003 To: Goulart, Jeffery C.
Cc: Wade, Gary L.
From: Robert E. Hardaway RE: P.E.R. 03-014859-000 This memo is notification to update report R7152 to reflect the correct amount of coverage for the Usual examinations of integral attachment, and the weldment that wmas inaccessible for examination dutoihe component design. The coverage previously reported as approximately 75% is closer to 67/o Rje-measurement of weldment and outside diameter of component minus insulation thickness
~esul~e ~n amore accurate deduction of coverage.
Re measurement 161" plus (17 IA@10") =33 1" plus 161" inaccessible =492" 331/492 = 67.3%
E Rt;;WYSH;05:1A REH 1
1011612003 l 10/16/2003
10/16/2003 P.E.R. RESOLUTION OF EXAM COVERAGE ESTIMATION:
P.E.R. 03-014859-000 161" plus (17 IA@10") =331" plus 161" inaccessible =492" 33 1/492 = 67.3%
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RECORD OF VT-1 EXAMINATION DATE PROCEDURE N-VT-1. REV. REPO2T NO.
S I>252-7 .2& 19- 576.2 AWING NO' DIRECT REMOTE Q COMPONENT IDENTIFICATION: SYSTEM:
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0 SQN UNIT 2 0 INSERVICE O WBN 0 UNIT 3 0 PRESERVICE O BLN EXAMINATION RESULTS l_____ /@ lfB<W2J__ B-M-2/1-N-2 ATTRIBUTE l ACC. REJ. ATTRIBUTE ACC. l REJ.
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- 1 /g 5X62 POER resolution of exam coverage estimation Date: 10/16/2003 To: Goulart, Jeffery C.
Cc: Wade, Gary L.
From: Robert E. Hardaway RE: P.E.R. 03.014859-000 or, nThis memo is notification to update report R 5762 to reflect the correct amount of coverage for the
.isxual examinations of integral attachment, and the weldment that was inaccessible for examination the component design. The coverage previously reported as approximately 75% is closer to Udiu:o
- .R6e'-measurement of weldment and outside diameter of component minus insulation thickness resulte~d ina more accurate deduction of coverage.
emeasurement 161" plus (16 IA@10") =321" plus 161" inaccessible =482" 321/482= 66.6%
,ERCWIV SH I1-IA REH REH 40/03 I
10/16/2003
-30F
I 10/1612003 P.E.R. RESOLUTION OF EXAM COVERAGE ESTIMATION:
P.E.R. 03-014859-000 R S76p 161" plus (16 IA@10") =321" plus 161" inaccessible =482" 321/482 = 66.6%
IA Inaccessible for VT v -y 05ze /0/;,:w9
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4ifoP 10/16/2003 2