ML080710257

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Request for Additional Information - Weld Overlay of the Decay Heat Drop Line Relief Request #08-001-RR, Revision 0
ML080710257
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/11/2008
From: Stewart Bailey
NRC/NRR/ADRO/DORL/LPLII-2
To: Boyce T
NRC/NRR/ADRO/DORL/LPLII-2
Bailey S , NRR/DORL,415-1321
References
TAC MD8237
Download: ML080710257 (5)


Text

March 11, 2008 MEMORANDUM TO: Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing FROM: Stewart N. Bailey, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - WELD OVERLAY OF THE DECAY HEAT DROP LINE RELIEF REQUEST #08-001-RR, REVISION 0 (TAC NO. MD8237)

On March 7, 2008, the licensee submitted a relief request to support weld overlay repairs on the decay heat drop line at Crystal River Unit 3. The Nuclear Regulatory Commission (NRC) staff sent the licensee the enclosed draft request for additional information (RAI) March 10, 2008, in order to facilitate the review of the relief request. The RAI questions were discussed via conference call on March 10, 2008. The majority of the questions turned out to be editorial in nature, as they ask for clarifications of portions of draft Code Case N-740-2 that the licensee does not plan to use. The licensee is incorporating the responses to the RAI questions and developing Revision 1 to the relief request. This memorandum and the enclosure do not constitute a formal RAI or present an NRC staff position.

Docket No. 50-302

Enclosure:

As stated.

DRAFT REQEUST FOR ADDITIONAL INFORMATION WELD OVERLAY OF THE DECAY HEAT DROP LINE RELIEF REQUEST #08-001-RR, REVISION 0 CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 By letter dated March 7, 2008, Florida Power Corporation submitted Relief Request #08-001-RR to support the application of a structural weld overlay to the decay heat drop line at Crystal River Unit 3. The relief request was submitted as an alternative to the requirements of the ASME Code,Section XI, IWA-4000. In order to complete its review, the NRC staff requests for the following additional information.

1. Please provide nominal outside diameter and wall thickness of the decay heat line in the ASME Code Component Affected section of the relief request.
2. On Page 2 of the relief request, in the Applicable Code Requirement section, the licensee listed draft Code Case N-740-2 as an applicable code requirement. ASME Code Cases cannot be used or represented as the ASME Code requirements because they are alternatives to the ASME Code requirements.
3. Licensees who have previously submitted weld overlay relief requests have committed to provide the following reports within fourteen days from completing the final ultrasonic examinations of the completed weld overlays:

(1) Weld overlay examination results including a listing of indications detected. The recording criteria of the ultrasonic examination procedure to be used for the examination of the overlays requires that all indications, regardless of amplitude, be investigated to the extent necessary to provide accurate characterization, identity, and location. Additionally, the procedure requires that all indications, regardless of amplitude, that cannot be clearly attributed to the geometry of the overlay configuration be considered flaw indications.

(2) Disposition of indications using the standards of ASME Section XI, IWB-3514-2 and/or IWB-3514-3 criteria and, if possible, the type and nature of the indications. The ultrasonic examination procedure requires that all suspected flaw indications are to be plotted on a cross-sectional drawing of the weld and that the plots should accurately identify the specific origin of the reflector.

(3) A discussion of any repairs to the weld overlay material and/or base metal and the reason for the repairs.

(4) A stress analysis summary demonstrating that the subject piping will perform its intended design functions after the weld overlay installation. The stress analysis report will include results showing that the requirements of NB-3200 and NB-3600 of the ASME Code,Section III, are satisfied. The stress analysis will also include results showing that the requirements of IWB-3000 of the ASME Code,Section XI, are satisfied. The results will show that the postulated crack including its growth in the nozzles will not adversely affect the integrity of the overlaid welds. This information will be submitted to the NRC prior to entry into Mode 4 start-up.

Discuss whether the above reports will be submitted to the NRC within 14 days from completing the final ultrasonic examinations of the completed weld overlays.

ENCLOSURE

4. The licensee referenced Code Case N-504-2 in various sections of the relief request (e.g.,

page 2). The NRC has approved Code Case N-504-3, which is a newer version of N-504-2, in Regulatory Guide 1.147, Revision 15. Discuss whether the subject relief request is consistent with Code Case N-504-3.

5. On page 1 of Attachment 1, the mitigative weld overlay is defined. The proposed weld overlay is a repair weld overlay, not a mitigative weld overlay, because of the degraded weld.

Therefore, the definition for the mitigative weld overlay should be removed from the proposed relief request.

6. (a) On pages 1 and 2 of Attachment 1, the NRC staff has generic concerns regarding the application of Sections A1.1(b)(1), A1.1(b)(1)(a), and A1.1(b)(1)(b) to the weld overlay installation because the NRC staff has technical issues that have not been resolved with the ASME Code committees. Justify how these requirements are applicable to the subject weld overlay at Crystal River. (b) Section A1.1(b)(2) states that If ambient temperature temper bead welding is used, Attachment 2 shall be used. In light of staffs concern regarding on the above three A1.1(b) sections, ambient temperature temper bead welding must be used, not if used on the carbon steel nozzle. Explain.
7. Section A.1.1(c)(3) of Attachment 1 states that a layer of austenitic stainless steel filler material may be apply to the austenitic stainless base (pipe) metal. Section A.1.1(c)(3) also requires that the wire used meet the minimum requirements for delta ferrite. (a) Provide the material specification of the austenitic stainless filler metal, (b) Confirm that the Certified Material Test Report (CMTR) for the austenitic stainless steel filler wire shows a minimum delta ferrite of a specified amount. Provide the maximum and minimum delta ferrite number of the austenitic stainless steel weld wire based on CMTR.
8. Please justify the requirements of Sections A1.2(2), A1.2(3), and A1.2(4) of Attachment 1 because they are not applicable to the weld overlay of the subject weld.
9. The second sentence in Section A1.3(c)(2) of Attachment 1 provides inservice examination for the mitigative weld overlay. The proposed weld overlay is not a mitigative weld overlay.

Justify the applicability of the second sentence in Section A1.3(c)(2) to the weld overlay of the subject weld.

10. Section A1.3 of Attachment 1 provides examination requirements for the cast austenitic stainless steel component. The subject weld and associated nozzle and pipe are not made of cast austenitic stainless steel. Confirm that examination requirements for cast austenitic stainless steel are not applicable to the weld overlay of the subject weld.
11. Section A1.3(c)(4) requires that If a planar flaw is detected in the outer 25% of the base material thickness, it shall be included in the design analysis required by 2. The licensee needs to clarify what is meant by 2 in the statement. Is the above paragraph meant to read If a planar flaw is detected in the outer 25% of the base material thickness, it shall be included in the design analysis required by Section A1.2?

March 11. 2008 MEMORANDUM TO: Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing FROM: Stewart N. Bailey, Senior Project Manager Plant Licensing Branch II-2 /RA/

Division of Operating Reactor Licensing

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - WELD OVERLAY OF THE DECAY HEAT DROP LINE RELIEF REQUEST #08-001-RR, REVISION 0 (TAC NO. MD8237)

On March 7, 2008, the licensee submitted a relief request to support weld overlay repairs on the decay heat drop line at Crystal River Unit 3. The Nuclear Regulatory Commission (NRC) staff sent the licensee the enclosed draft request for additional information (RAI) March 10, 2008, in order to facilitate the review of the relief request. The RAI questions were discussed via conference call on March 10, 2008. The majority of the questions turned out to be editorial in nature, as they ask for clarifications of portions of draft Code Case N-740-2 that the licensee does not plan to use. The licensee is incorporating the responses to the RAI questions and developing Revision 1 to the relief request. This memorandum and the enclosure do not constitute a formal RAI or present an NRC staff position.

Docket No. 50-302

Enclosure:

As stated.

DISTRIBUTION:

Public RidsNrrDorlLpl2-2 RidsNrrLABClayton LPL2-2 R/F RidsNrrPMSBailey ADAMS ACCESSION NO.: ML080710257 OFFICE LPL2-2/PM LPL2-2/LA LPL2-2/BC NAME SBailey BClayton TBoyce DATE 3/11/08 3/11/08 3/11/08

OFFICIAL RECORD COPY