ML042730338

Third Ten Year Inservice Inspection Interval Request for Relief No. 04-ON-006

ML042730338
Person / Time
Site:	Oconee, Susquehanna
Issue date:	09/20/2004
From:	Rosalyn Jones Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
04-ON-006
Download: ML042730338 (13)

Text

. Duke RON A. JONES uJPowere Vice President A Duke Energy Company Oconee Nuclear Site Duke Power ONOI VP / 7800 Rochester Highway Seneca, SC 29672 864 885 3158 864 885 3564 fax September 20, 2004 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

Duke Energy Oconee Nuclear Station, Unit 1, 2, and 3 Docket No. 50-269,-270,-387 Third Ten Year Inservice Inspection Interval Request for Relief No. 04-ON-006 Pursuant to 10 CFR 50.55a(g)(5)(ii), attached is a Request for Relief from the requirement to examine 100% of the volume .specified by the ASME Boiler and Pressure Vessel Code,Section XI, 1989 Edition with no Addenda (as modified by Code Case N-491). This request is to allow Duke Energy to take credit for one (1) limited visual (VT-3) examination per unit on a Letdown Filter Housing support described in the attached request. During examination of the subject Unit 1 support, the VT-3 examination coverage did not meet the 100% examination requirements. The obtainable coverage for the examination is indicated on the attached request. As discussed in the attached request, achievement of greater examination coverage for these welds constitutes a hardship without a compensating increase in quality or safety due to radiation and contamination concerns aggravated by the existence of insulation on the support and asbestos abatement concerns.

This examination has been performed on Unit 1, but similar conditions exist on Units 2 and 3 such that relief is also requested for the equivalent components on those units.

Therefore, Duke Energy requests that the NRC grant relief as authorized under 10 CFR 50.55a(a)(3)(ii).

If there are any questions or further information is needed you may contact R. P. Todd at (864) 885-3418.

www.dukepower.comr

U. S. Nuclear Regulatory Commission September 20, 2004 Page 2 Ver yours, R. ones, Site Vice President, Oconee Nuclear Station Attachment xc w/att: Mr. William D. Travers Administrator, U.S. Nuclear Regulatory Commission, Region II Atlanta Federal Center 61 Forsyth St., SWW, Suite 23T85 Atlanta, GA 30303 L. N. Olshan, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 xc(w/o attch):

M. C. Shannon Senior NRC Resident Inspector Oconee Nuclear Station Mr. Henry Porter Division of Radioactive Waste Management Bureau of Land and Waste Management SC Dept. of Health & Environmental Control 2600 Bull St.

Columbia, SC 29201

Relief Request 04-ON-006 Page lof4 Proposed Relief in Accordance with 10 CFR 50.55a (a)(3)(ii)

Inservice Inspection Hardship Duke Energy Corporation Oconee Nuclear Station - Unit 1 (EOC-21) Interval Start Date= 7-15-1993 Interval End Date=1-1-2004 Unit 2 (EOC-20) Interval Start Date= 12-16-1994 Interval End Date=9-9-2004 Unit 3 (EOC-21) Interval Start Date= 12-16-1994 Interval End Date=12-16-2004 Third 10-Year Interval - Inservice Inspection Plan ASME Section XI Code - 1989 Edition with No Addenda I. I. & Ill. IV. V. VI. VIl.

Limited System l Code Requirement from Which Basis for Relief Alternate Justification Implementation Area/hVeld Component for Which Relief is Requested: Examinations or for Granting Schedule I.D. Relief is Requested: 100% Exam Volume Coverage Testing Relief Number Area or Weld to be Exam Category Examined Item No.

Fig. No.

Limitation Percentage I-LDFTR-IA High Pressure Injection (Code Case N-491) See Paragraph See Paragraph See Paragraph See Paragraph System Exam Category F-A "A" "B""C" Component Support for Item No. F01.040.035 Letdown Filter IA Fig. IWF-1300-1(a)

Limited Coverage of the IWF-Support Examination Boundary-C 2-LDFTR-2A High Pressure Injection (Code Case N-491)

System Exam Category F-A Component Support for Item No. F01.040.028 Letdown Filter 2A To be examined during EOC 20 in May of 2004 3-LDFTR-3A High Pressure Injection (Code Case N-491)

System Exam Category F-A Component Support for Item No. F01.040.038 Letdown Filter 3A To be examined during EOC 21

. in October of 2004 Sec Attachment A for a drawing on F01040 support area/weld locations.

See Attachment B for inspection data on the Unit I item listed in the above table for this Relief Request.

Note: Item for.Unit 1 in this relief request was inspected during October of 2003.

Relief Request 04-ON-006 Page 2 of 4 IV. Basis for Relief Paragraph A: (The support leg brackets are SA 476 Type 304 material, the threaded half couplings are SA 182 F 304 material, and the support legs are SA 106 Gr. B material.

During the remote visual examination of the Letdown Filter Housing support (Item F01.040.035), the examination was limited because portions of the support were covered by insulation and the inspection was performed using a camera mounted to an extendable boom which limited viewing portions of the inspection area. The room could not be entered into by personnel to inspect or remove the insulation due to it being in a highly contaminated area and it is also an area that may have asbestos concerns. RP states that the most recent encounter with insulation in this area resulted in airborne activity measuring 19.6 DAC (beta /gamma) and 130 DAC (alpha). It would take considerable effort of changing the installed filters and decon efforts to get the whole body exposure rates to a manageable range (100 mr/hr general area).

The following is an estimate that shows 1.050 rem for the total dose that would be received to perform an examination that allows you to inspect 100% of the required examination area:

Clean room and establish asbestos abatement controls 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> X 50 mr/hr = 500 mrem Install Shielding I hour X 200 mr/hr = 200 mrem Strip Insulation .5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> X 100 mr/hr = 50 mrem, Perform inspection .5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> X 100 mr/hr = 50 merm Remove shielding .5 hr X 100 mr/hr = 50 mrem Install insulation 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> X 100 mr/hr = 100 mrem Clear area 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> X 50 mr/hr = 100 mrem The 1.050 rem would be the dose received to inspect the support for 1 unit. To inspect a support for each unit, it would take a total of 3.150 rem.

The dose received to perform the remote inspection that was performed by QC and civil engineering was 0 mrem.

The dose (1.050 rem) that would be received to prepare the Letdown Filter Housing support so that 100% of the support could be examined would be a hardship for Duke Energy. There were no indications found that would cause the support to be inoperable, on the areas of the support that were examined.

For supports listed in the table above, all configurations, including interference, are the same for Units 1, 2, and 3.

Therefore, all three units are being documented in this Relief Request as described in NRC Inspection Report No.

50-269/95-05, 50-270/95-05, 50-287/95-05 dated May 5, 1995. While only the Unit 1 examination has been completed at this time, approximately the same configuration and examination coverage is expected; therefore, relief is also being sought for the same supports in Units 2 and 3.

V. Alternate Examinations or Testing Paragraph B:

The scheduled 10-year code examination was performed on the referenced area/support and it resulted in the noted limited coverage of the required VT-3 examination surface. No additional examinations are planned for the area/support during the current inspection interval.

Relief Request 04-ON-006 Page 3 of 4 NI. Justification for Granting Relief Paragraph C:

Visual (VT-3) examination of the Letdown Filter IA Housing support for the item number F01.040 was conducted using personnel, qualified in accordance with paragraph IWA-2300 of the 1989 Edition with no addenda, ASME Section XI Code. The examination procedure was demonstrated using the remote camera equipment and the 1/32 inch black line on an 18% neutral gray card. Although 100% of the required examination surfaces could not be examined, the amount of surface that was examined and the Engineering Evaluation (Attachment B, Page 6 of 6) of the visual examination results provides an acceptable level of quality and integrity.

In addition to the FO1.040 support that relief is being requested for required due to examination surfaces that could not be inspected, there was a remote visual examination of accessible surfaces on the Letdown FilteriB housing support. The examinations performed by civil engineering and QC didn't identify any indications that would raise concern about the structural integrity of the support. The inspection on the IB letdown Filter housing was not a required exam (Note 3 of Table -2500-1 in Code Case N491 states that in cases where there are multiple components within a system of similar design, function and service, the support of only one of the multiple components are required to be examined.) but was performed to see if the lB support would be more accessible. The examination coverage is about the same for Letdown Filter IA Housing support as it is for the IB Letdown Filter housing support.

The letdown filter housings are located in a room that is normally inaccessible and are not routinely visually inspected. There is a floor drain in the room where the letdown filter housings are located as well as in the adjacent room where the letdown storage tank is located. (Note the letdown filter room and letdown storage tank room are interconnected by pipe sleeves that pass through the wall between the two rooms.) Any water that goes into these floor drains ends up in the low activity waste tank. The low activity waste tank is pumped to a waste tank in rad waste and the level in these tanks is monitored to identify when there appears to be excessive waste. Through this monitoring, leaks from the letdown filter housing and associated pipe would be identified.

In addition to the monitoring of the waste tank level, there are local radiation monitors which would detect Xenon gas from a leak at the letdown filters. Also since the letdown filters are directly connected to the reactor coolant system (RCS), leakage at the filter housings would be seen as RCS leakage during the RCS leakage calculation, which is run once each shift. In the control room there is a continuous indication of the level of the letdown storage tank; a decreasing level in this tank would be an indicator of a RCS leak, the source of which would have to be identified.

The combination of these leakage detection systems would provide adequate assurance that if a leak was to develop it would be detected in a timely manner.

Duke Energy has examined the support referenced in this request to the maximum extent possible utilizing the latest in examination techniques and equipment. The Letdown Filter Housing and support identified in this request was built and inspected in accordance to the 1968 ASME Section III Construction Code and verified to be free from unacceptable fabrication defects. Based on the inspections during construction and the coverage and results of the required visual VT-3 exams this outage, it is Duke's belief that this examination provides a reasonable assurance of component integrity.

VII. Implementation Schedule Paragraph D The scheduled third 10-year interval plan code examination for Unit I was performed on the referenced area/support resulting in limited inspection of the required surfaces of the support being examined. The Unit 2 and Unit 3 supports are scheduled to be examined during the spring and fall outages of 2004. No additional examinations are planned for the supports during the current inspection interval. The same area/support may be examined again as part of the next (fourth) 10-year interval plan, depending on the applicable code year edition and addenda requirements adopted in the future.

Relief Request 04-ON-006 Page 4 of 4 VIII. Other Information The following individuals contributed to the development of this relief request:

James J. McArdle (NDE Level III Examiner) provided Sections II through V and part of Section VI.

B. W. Carney, Jr. (Oconee Engineering) provided part of Section VI.

Larry C. Keith (Oconee ISI Plan Manager) compiled the remaining sections.

Sponsored By: &Dzy= C %7 Date q17 ,3 C)

Approved By: l rI v Date .417 r/- g -

- t I Attacljiiicxt B P'agc / of 6 QAL-14 Form QAL-14A Revision 14 PAGE 1 OF A DUKE POWER COMPANY PROJECT Oconee 5 PSI ISI ISI VISUAL EXAMINATION VT-3 HANGERS UNIT 1 W.O. #/NSM 9g57 98;3 PROCEDUREQAL-14 REV.

INSPECTOR LEVEl DATE VISUAL METHOD: ';gDiRECT E[fREMOTE VISUAL AIDS

/0 - 315 IM&TE SN: Ac/167E7Itf7~

SYSTEM STATUS: 5 HOT EKOLD [ OTHEP

._ (EXPLAIN (N COMMENTS SIR NUMBER REV. I.D. NUMBER ACTUAL SYSTEM TEMPERATUR

/ A /e72O&W AyL?2* r 1-LDFTR-1A I RESULTS: 5 ACCEPTABLE [ UNACCEPTABLE, (REQUIRES NDE, EVALUATION OR REPAIR)

• BIOPTIONAL) SEE ENGINEERING JUSTIFICATION ATTACHED IND. INDICATION NO. TYPE LENGTH WIDTH REMARKS

._ _ PA.6t Z OF Z MECHANICAL SHOCK SUPPRESSOR A B UMIT STOP A B HOT SEtlING WA WA ACTUALTRAVEL(COMPIrENSION)IA NA

[

COLD SEtTING WA WA HYDRAUUC SHOCK SUPPRESSOR A B ACTUAL PISTON SETTING NWA /A, _ ___RFLUq_L1EVEL WA -NA VARIABLE SPRING SUPPORTS A B HOTSETTING N/A WA HOT LOAD WA A COLD SETTING NIA WA COLD LOAD WA WA ACTUAL PISTON SETTING NWA WA LOAD IND. READING NA NA COMMENTS/DISPOSITION (OPTIONAL) SKETCWtDRAWING ATTACHED~j}/g CONSTANT SUPPORT A B Letdown Filter IA ';'-~ -5 HOT LOAD WA WA Class B.

COLD LOAD N/A WA POSITION IND. READING WA WA TOTAL NO. OF DIV. SCALE WA WA PIP: [] YES Q4o10 ISERIAL NO. Vg A FINAL REVIEW DATE ANII REVIEW DATE 7Xv w /~2-/M- 7 ,'

4V Z Z, ITEM NUMBER F01.040.035

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I Attachmnent B Page: 1 Document Name: untitled Pagc g Of 4 TIMM121 TASK COMPLETION COMMENTS 02/09/04 10:35 Help Data Print Roadmap Exit W/O Task : 98579823 01 Task Status: COMPLETE Status Date  : 10/21/03 Title PERFORM VT-3 EXAM ON ITEM F01.040.035__ Resp. Facility: ON Facility : ON Unit: 1_ UTC  :

Equipment: _ __ Mfr. Code :_

Component: _- Model No. :

Work Item: MSC ISIINSPECTIONS__ Serial No.:

Plan Dur. Change: N_ Delays/Barriers: N_ Plan Improvement: N_ PJA Comments -

Last Update By: PSE1290_ Last Update Date: 02/09/04 09/25/03 11:33:14: H. MORGAN GRANTED CLEARANCE TO BEGIN WORK. HWM7312_

10/15/3 VT-3 PERFORMED -- ACCESS IS LIMITED AS IS VISIBILITY. CAMERA_ PSE1290_

WAS USED WITH ONBOARD LIGHTING AND ZOOM. FILTER IS INSULATED. LOWER_ PSE1290_

PART OF LEGS, BASEPLATES AND ANCHORS WERE VISIBLE. NO DETRIMENTAL_ PSE1290_

INDICATIONS WERE NOTED. THIS WAS A LIMITED INSPECTION PERFORMED WITH_ PSE1290_

CIVIL ENGINEERING PRESENT AND LOOKING AT COLOR MONITOR. PSE1290/TAH66 PSE1290_

95 CREW 261 PSE1290_

18% NEUTRAL GREY CARD TESTED WITH CAMERA LIGHT IN RP OFFICE WITH_ _ PSE1290_

REDUCED OFFICE LIGHTING TO SIMULATE ACTUAL CONDITIONS AT THE PSE1290_

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RECORD COMPLETION COMMENTS, F9 TO STEP THROUGH TASK COMPLETION PANELS F1=Help F4=Prompt F6=Refresh F7=Bkwd F8=Fwd F10=Perform Msg F12=Cancel 4-0 1 Sess-3 162.113.67.5 NTCPNBJE 2/2 Dato- ng/nq/nd 9,ime

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Page: 1 Document Name: untitled iAttachment B t Page 3 of C TIMM121 TASK COMPLETION COMMENTS 02/09/04 10:35

__ Help Data Print Roadmap Exit W/O Task : 98579823 01 Task Status: COMPLETE Status Date  : 10/21/03 Title  : PERFORM VT-3 EXAM ON ITEM F01.040.035_- Resp. Facility: ON Facility : ON Unit: 1_ UTC  :

Equipment: _ _ Mfr. Code :

Component: ___ Model No. :

Work Item: MSC ISIINSPECTIONS__ Serial No.:

Plan Dur. Change: NL Delays/Barriers: N_ Plan Improvement: N_ PJA Comments -

Last Update By: PSE1290_ Last Update Date: .02/09/04 FILTER PSE1290 CREW 261 PSE1290_

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RECORD COMPLETION COMMENTS, F9 TO STEP THROUGH TASK COMPLETION PANELS F1=Help F4=Prompt F6=Refresh F7=Bkwd F8=Fwd F10=Perform Msg F12=Cancel 4-o 1 Sess-3 162.113.67.5 NTCPNBJE 2/2 Da tp: 02/0q'/04 Tim-: 10O*V-AO

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Attachment B Page 6 of 6 Attachment to Form OAL-14A Support No. I-LDFLTR.IA-HOUSING SUPPORT QA Item No. FO1.040.035 Civil EndR22ns Comments/Disposifian-,

Civil Engineering evaluated the support posts and their anchorage for IA & lB Letdown Filter Housing for the reported discrepancies per acceptance requirements of Code Case N-491, section 3122.3. The conclusions and recommendations are as follows:

Indication #1:

"Using a RP camera mounted on an extendable boom, VT-3 of the support posts and their anchorage for lA & lB Letdown Filter Housing was performed. The filter housing is insulated, covering parts of the legs under the housing. With lighting on the camera, QC was able to see a portion of the legs and the base plates/ancbors There has been some leakage in the past during filter changes. This has caused some surface rust but not bad enough to have bucded paint. This is a limited inspection. However, QC feels that the overall condition of the support is good."

Civil engineering also observed/inspected the support posts and their anchorage for IA & lB Letdown Filter Housing along with the QC inspectors in aux. bldg. unit-i. Since the filter housing is insulated covering parts of the legs under the housing, some visibility of the support legs and the anchorage is restricted due to limited access. Based on what was seen during insction using the RP camera with lighting mounted on an extendable boom, the support legs, base plates and anchor bolts do not appear to have any degradation or damage that copld raise a concern about its structural integrity besides some minor surface rust as reportd. However, a Requcst For Relief for IA &i B Letdown Fiter Housing

' > needs to be processed since the complete inspection can not be performed.

OrWitedBy: D B. PatelI Date. lo> 1l -3 Checked By: _ Date:

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