ML073231205

Third Ten Year Inservice Inspection Interval Request for Relief No.02-001, Revision 1

ML073231205
Person / Time
Site:	Oconee
Issue date:	11/15/2007
From:	Brandi Hamilton Duke Energy Carolinas, Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML073231205 (17)

Text

BRUCE H HAMILTON Vice President wEnergy Oconee Nuclear Station Duke Energy Corporation ONO1VP / 7800 Rochester Highway Seneca, SC 29672 864 885 3487 864 885 4208 fax bhhamilton@duke-energy. corn November 15, 2007 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke)

Oconee Nuclear Station, Unit 3 Docket Nos. 50--287 Third Ten Year Inservice Inspection Interval Request for Relief No.02-001, Revision 1 Pursuant to 10 CFR 50.55a(g)(5)(iii), 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-460). This request is to allow Duke to take credit for limited ultrasonic examinations on a specific Reactor Building penetration pipe to valve weld described in the attached request. During examination of the subject Unit 3 weld, the ultrasonic examination coverage did not meet the 90% examination requirements of Code Case N-460. Achievement of greater than 75%

examination coverage for this weld is impractical due to piping/valve geometry, interferences, and existing examination technology. Therefore, Duke requests that the NRC grant relief as authorized under 10 CFR 50.55a(g)(6)(i).

This relief was initially submitted by letter dated March 11, 2002 (ADAMS Accession Number ML020840509). However, the cover letter contained typographical errors and apparently the letter was not entered into the NRC review process pending submittal of a corrected version. The third Inservice Inspection Interval for Oconee Unit 3 terminated January 2, 2005. Despite the elapsed time, Duke is resubmitting the request for NRC review and approval in order to close out the third interval documentation. The attached request was revised during preparation and review for re-submittal and is considered Revision

1. This revision replaces and supersedes the original request.

www. duke-energy. com

U. S. Nuclear Regulatory Commission November 15, 2007 Page 2 If there are any questions or further information is needed you may contact R. P.

Todd at (864) 885-3418.

Very truly yours, B. H. Hamilton Site Vice President Enclosure xc w/att:

Dr. W. D. Travers Administrator, Region II U.S. Nuclear Regulatory Commission 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 artch):

D. W. Rich Senior NRC Resident Inspector Oconee Nuclear Station S. E. Jenkins, Section Manager Bureau of Land and Waste Management SC Dept. of Health & Environmental Control 2600 Bull St.

Columbia, SC 29201

U. S. Nuclear Regulatory Commission November 15, 2007 Page 3 bxc w/att:

R. L. Gill, Jr.

T. J. Coleman P. A. Wells V. B. Dixon B. W. Carney, Jr.

R. P. Todd L. C. Keith G. L.' Brouette (ANII)

J. J. Mc Ardle III J. E. Smith ISI Relief Request File NRIA File/ELL EC050 Document Control

Duke Energy Carolinas Oconee Nuclear Station Unit 3 THIRD 10-YEAR INTERVAL REQUEST FOR RELIEF NO.02-001 Rev. 1 Duke has determined that conformance with certain ASME Section XI Code requirements is impractical. Therefore, pursuant to 10CFR50.55a(g)(5)(iii), Duke requests relief from applicable portions of the code.

Included in this request is a single Examination Category C-F-2 weld.

The Oconee Unit-3 Inservice Inspection Plan was written to the requirements of the 1989 Edition of ASME Section Xl, no addenda.

The exam in this Request for Relief was performed during EOC-19, the last outage in the second period of the third ten-year interval.

Code Case N-460 applies to the examination performed during this outage.

1.

System/Component(s) for Which Relief is Requested:

A.

Pipe to Valve 3PR-2:

ID Number Item Number 3-20B-21-18-18 C05.051.046 Reference Attachment "A" for a weld iso drawing of the pipe to valve 3PR-2 weld.

Reference Attachment B for a copy of the examination records for the weld addressed in this request.

This weld is part of the Reactor Building Purge System Penetration Piping.

II.

Applicable Code Edition and Addenda

ASME Section XI Code - 1989 Edition, with no addenda Page 1 of 3

III.

Code Requirement IWC-2500, Table IWC-2500-1, Examination Category C-F-2, Item Number C5.51, Figure IWC-2500-7 (a), Volume Coverage of Examination Volume C-D-E-F.

IV.

Impracticality of Compliance Pipe to Valve 3PR-2 weld 3-20B-21-18-18 (Item C05.051.046) is limited to 75.00% coverage of the required volume due to the proximity of a penetration. The percentage of coverage represents the aggregate coverage from all scans performed on the weld and adjacent base material. The coverage from each scan was as follows: 450 shear wave circumferential scans, both clockwise and counter-clockwise covered 56.25% of the weld and base material; 600 shear wave scan perpendicular to the weld (toward the penetration) covered 87.5% for the first leg which included 100% of the inside surface within the area of interest and 100%

for the second leg of the weld and base metal in the axial direction. In order to achieve more coverage, the penetration would have to be removed or re-designed to allow scanning from both sides of the weld.

That would be impractical. There was one recordable indication found that was determined to be a geometric reflector during the inspection of this weld.

The Oconee Inservice Inspection Plan allows the use of Code Case N-460, which requires greater than 90% volumetric coverage of examination volume C-D-E-F. Therefore, the available coverage will not meet the acceptance criteria of this Code Case.

V.

-Alternate Examinations or Testing The use of radiography as an alternate volumetric examination of the weld/component referenced in this request is not a viable option.

Restrictions to performing radiography are primarily due to limited access for placement of film due to the proximity of the penetration. No additional examinations are planned during the current interval for weld 3-20B 18-18.

VI.

Implementation Schedule This request is for the duration of the third inservice inspection interval, which ended on January 2, 2005.

Page 2 of 3

VII.

Justification for the Granting of Relief The subject weld was examined to the maximum extent practical using ultrasonic techniques qualified in accordance with the requirements of ASME Section XI, Appendix VIII, Supplements 2 and 3 of the 1995 Edition with the 1996 Addenda as administered by the PDI. An ID connected circumferential flaw within the required examination volume would have been detected.

In addition to the volumetric examination with limited coverage, Duke performed a surface examination (code required) on this C5.51 item and achieved 100% coverage. The result from the surface examination was acceptable.

In addition to the C5.51 welds of this relief request, there were five additional C5.51 welds that surface and volumetric examinations were performed on during the outage. All of the surface and volumetric examinations except for one surface examination were acceptable. A surface examination on weld 3MS-20B-B found a reportable indication which was removed by grinding and reexamined and found to be acceptable. Additional surface exams were performed as required by code. 100% coverage was obtained on all five additional C5.51 surface and volumetric examinations. Three of the five additional welds were from the Low Pressure Service Water System, one of the additional welds was from the Feedwater System, and one of the additional welds was from the Main Steam System.

IWC-2500, Table IWC-2500-1, Examination Category C-H System Leakage Tests and VT-2 visual examinations performed once each period provide adequate assurance of pressure boundary integrity.

In addition to the above Code required examinations (volumetric, surface, and pressure test), there are other activities which provide a high level of confidence that, in the unlikely event that leakage did.occur through this weld it would be detected and proper action taken. Specifically, Appendix J penetration leak rate testing performed during refueling outages provides additional assurance that any leakage would be detected prior to gross failure of the component.

The component weld was inspected by visual examination during construction and verified to be free from unacceptable surface fabrication defects. Based on the coverage and results of the volumetric, surface, and the pressure testing VT-2 examinations performed, it is Duke's position that this combination of examinations provides a reasonable assurance of quality and safety.

Page 3 of 3

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