ML090900514

Proposed Relief Request No. 09-MN-001 for the Third Ten-Year Inservice Inspection Interval

ML090900514
Person / Time
Site:	Mcguire
Issue date:	03/23/2009
From:	Brandi Hamilton Duke Energy Carolinas, Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RR 09-MN-001
Download: ML090900514 (12)

Text

Duke BRUCEH HAMILTON Vice President McGuire Nuclear Station Duke Energy Corporation MG01 VP / 12700 Hagers Ferry Road Huntersville, NC 28078 704-875-5333 704-875-4809 fax bhhamilton@duke-energy.com March 23, 2009 U.S. Nuclear Regulatory Commission Washington', DC 20555-0001 ATTENTION: Document Control Desk Duke Energy Carolinas, LLC (Duke)

McGuire Nuclear Station Unit 2 Docket No. 50-370

SUBJECT:

Proposed Relief Request No. 09-MN-001 for the Third Ten-Year Inservice Inspection Interval

REFERENCE:

Letter from Duke to NRC dated July 9, 2008 Pursuant to 10 CFR 50.55a(g)(5)(iii), Duke Energy Carolinas, LLC (Duke) hereby requests NRC approval of a proposed relief request for the Third Ten-Year Inservice Inspection Interval at the McGuire Nuclear Station. The third interval began on March 1, 2004. This submittal, applicable to a Unit 2 reciprocating charging pump to flange weld, requests relief from inservice examination requirements that have been determined to be impractical. The details of the request are included in the enclosure.

In the Inservice Inspection Report for the end of cycle 18 (referenced letter), Duke notified the NRC of the intent to submit this request.

This submittal document contains no additional regulatory commitments.

If there are any questions or if additional information is needed, please contact M. K. Leisure at (704) 875-5171.

Sincerely, Bruce H. Hamilton 40L47-T Enclosure www. duke-energy.com

U.S. Nuclear Regulatory Commission March 23, 2009 Page 2 xc with enclosure:

L.A. Reyes Administrator, Region II U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, Suite 23T85 Atlanta, GA 30303 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station J. H. Thompson (addressee only)

NRC Project Manager (MNS)

U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001

ENCLOSURE REQUEST NO. 09-MN-001

Relief Request 09-MN-001 McGuire, Unit 2 Page I of 4 Relief Request 09-MN-001 Proposed Relief in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality Duke Energy Corporation McGuire Nuclear Station - Unit 2 (EOC-18)

Third 10-Year Interval - Inservice Inspection Plan Interval Start Date = 3-1-2004 Interval End Date = 3-1-2014 This Relief Request has 1 weld for which relief is being sought.

The ID, Item/Summary Number for the weld is:

Weld ID Item/Summary Number 2RCHP-IN M2.R1.11.0279 The Item in this relief request was examined during March, repaired, and re-examined in April of 2008.

Relief Request 09-MN-001 McGuire, Unit 2 Page 2 of 4

1. ASME Code Component Affected Chemical and Volume Control System Reciprocating Charging Pump Inlet to Flange Weld ASME Code Class 2 Weld ID = 2RCHP-IN Item Number/Summary Number = M2.R1.11.0279 II. Applicable Code Edition and Addenda ASME Boiler and Pressure Vessel Code,Section XI - 1998 Edition thru the 2000 Addenda III. Applicable Code Requirement The examination requirements for Class 1 and 2 piping welds are governed by the Risk-Informed Inservice Inspection program which is based on WCAP-14572, Revision 1-NP-A. The WCAP Table 4.1-1, Examination Category R-A, Risk-Informed Piping Examinations, requires 100% of the exam location to be examined per Figure IWC-2500-7(a) for Item Number R1.11. Code Case N-460 is applicable.

IV. Impracticality of Compliance The material is stainless steel. This weld has a wall thickness of 0.237 inches and a nominal diameter of 4.0 inches.

During the radiographic examination of this weld, only 78.0 % coverage of the required examination volume was obtained due to the geometry of the Pipe Flange-to-Pump Inlet weld. 100% of the weld volume and the required base metal on the flange side were examined. The exam limitation was restricted to the base metal on the pump housing side of the weld. In order to provide more coverage, the weld would have to be re-designed. This is impractical.

Rejectable fabrication flaws were detected in the weld metal during the exam.

The weld was repaired by welding and then reexamined by the radiographic method and was found to be acceptable. During the subsequent examination following the repair, the same examination limitation of 78.0 % was encountered.

The McGuire 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 criteria of this Code Case.

Relief Request 09-MN-001 McGuire, Unit 2 Page 3 of 4 V. Burden Caused by Compliance See section IV, second paragraph.

VI. Proposed Alternative and Basis for Use Due to the material and configuration, there is no viable alternative examination and ultrasonic examination would not provide additional examination coverage.

There are only two welds in this segment. The only other weld in this segment was examined by UT this outage once it was discovered that 2RCHP-IN had a relevant condition exceeding acceptance standards and was limited. The UT was "clear" with greater than 90 % coverage.-

VII. Duration of Proposed Alternative This request is for the duration of the third inservice inspection interval, currently scheduled to end on March 1, 2014.

VIII. Justification for Granting Relief Radiographic examination of the weld for item number M2.R1.11.0279 was conducted using personnel qualified in accordance with ASME Section XI of the 1998 Edition with the 2000 Addenda. Radiographic procedures complied with the requirements of ASME Section V, Article 2 of the 1998 Edition with the 2000 Addenda.

System Leakage Tests and VT-2 visual examinations performed each refueling outage provide adequate assurance of pressure boundary integrity.

In addition to the above Code required examinations (volumetric and pressure test), there are other activities which provide confidence that, in the event that leakage did occur through this weld, it would be detected and proper action taken. Specifically, visual observations performed during operator rounds provide additional assurance that any leakage would be detected prior to gross failure of the component. This weld is also inspected during the leak rate test for the NV system as required by Technical Specifications 5.5.3, "Primary Coolant Sources Outside Containment", on a refueling frequency.

The component weld was not examined by volumetric NDE methods during construction.

Based on the coverage and results of the volumetric and the pressure testing VT-2 examinations performed and the clear volumetric examination of the other

Relief Request 09-MN-001 McGuire, Unit 2 Page 4 of 4 weld in this segment, it is Duke's position that a reasonable assurance of component integrity exists.

IX. Precedents None.

This weld did not require a radiographic examination during construction, therefore the examination results of this Inservice Inspection exam could not be compared to previous data.

X. Attachments Attachments (2) contain the examination data for the two examinations of this weld.

FORM NDE-RTI REVISION 7 DUKE POWER COMPANY RADIOGRAPHIC EXAMINATION REPORT / TECHNIQUE Weld / Component ID: 2RCHP-IN Project: McGnire Unit 2 Procedure No./Rev: NDE 12 / 12 Acceptance/Reporting Standards:

Rardi phe."

r:,- Level: Date:

J.D. Shepard ---- 7 ".' -- I 03-14-08 Code

Reference:

ASME Sec. XI Material: CS: 0 SS: 0 E] Diameter: 4" Thickness: .237" Source: Ir-192 Size: .148" Curies: 77.1 Estimated Weld Build-Up: .062" SFD: 4.625" IQI: Film Side 0 Source Side 0I 5 Size(s) IQI Design: Standard Hole-Type Film View: Single 0 Composite [] Number of Film Per Cassette: 2 Film Stand Off NA Film Brand/Type: Front Fuji 50 Center NA Back Fuji 50 Shim Size(s): NA Screen Thickness: Front .010" Center NA Back .010" (Ug = Ft/D) Actual Ug: .008 Exposure Time: Hrs. Min. Sec. Thicker member used as shim: T Exposure: El Single Wall [] -DoubleWall Image View: N Single Wall Ii Double Wall TECHNIQUE SET UP

• A [C LIE LUG LIIH LI I Other 7

Draw Sketch

/

/ __ . ...

O1B ............... .. ........7 ....**

LD

/.--

I% jffjw Offset Offset Superimposed Single Wall Single Wall Double Wall Double Wall Exposure, Film EL Sketch View View View Inside Pipe Attached

__FILM REVIEW Intervai Date Indication Length/Size/Comment Reviewer Level Date 0-1 03-14-08 17 3/4" (0.750") _ nI 03-14-08 F. El 01 1-2 03-14-08 14 1/8" Il 03-14-08 I 2-3 03-14-08 14 1/8" 1II 03-14-08 NJ [] I 3-4 03-14-08 17 3/8" (0.400") III 03-14-08 L] U1 I El 4-5 n3-14-08 14 1/16" / 111 03-14-08 Ml El 01 5-0 03-14-08 17,14 (0.200) 3/16", 1/16" 1I 1 03-14-08 l I I t[l Ell U Indication and Flow types: 5. Crack 8. Porosity 11. Concavity 14. Rounded i.Incomp. Fusion 3. E*cessive Pen. 6. Slag 9. Tunen 12. Inclusion 15. Surface

2. Incomp. Pen. 4. UnconsumedInsert 7. Undercut 10. Convexity 13. Elongated 16. Film Artifact Exam Limitations: Yes: 78 % Examined I No: (100% Examined) 17. Linear Comments: See attached sheet for limitation calculations.

o(

Second Review: Level: III Date: 03-14-08 I~

ANI/ANII Review: Date: - , -o IS[ Item: M2.RI. 11.0279 IJ/

V

/ 'C-'

IDDEAL Limitation Record swoffare s-Lt re Site/Unit MNS 12 Procedure: NDE-12 Outage No: 2EOC18 Summary No: M2.RI.11.0279 Procedure Rev: 12 Report No:

Workscope: RT ISI Exam Work Order No: 01748135-09 Page: 2 of 2 237' T Description of Umitation: 4" x .37" NPS welded pipe flange to pump housing weld ISI ID# 2RCHP-IN.

Required exam area includes the 0.625" weld width and 0.250" on both sides of the weld.

The Pipe Flange-to-Pump Inlet configuration does not allow for RT film placement to capture the radiographic image of the 0.250" of base metal on the pump side of the exam area. See sketch of the limitation below.

Calculations:

Required weld/exam area length (L): 16.250" L (measurement taken from the RT film intervals)

Required exam area width (W): 0.625" + .250" + .250" = 1.125" W Required exam area in sq inches: 16.250" L x 1.125" W = 18.281" Actual area examined in sq inches: 16.250" L x 0.875" W = 14.218" Percent of coverage: 14.218" / 18.218" - 100 = 78% coverage Sketch of Umitation:

Pump Housing 1 4" NPS Welded Flange Weld: 2RCHP-IN Exam Area = 0.625" Weld + .250" each side Limitations removal requirements: N/A Radiation field: N/A Examiner Level Signat"fe Date R in Date 2z 03-14-2008_ 03-14-2008 Examiner Level Signature Date Site Review k9Signature Date Other Level Signature Date ANII Review JjCopSignature Date

I Form OA-516A (Front) I Revision 5 Rejectable Indication Evaluation Report STATION UNIT ISI PLAN rIEM NUMBER I1I PLAN ID NUMBER MNS 2 M2.Rl.11.0279 2RCHP-IN NDE METHOD NDE PROCEDURE USED INDICATION SERIAL NUMBER RT NDE-12 Rev 12 RT Intervals 0-1, 3-4 and 5-0 DESCRIPTION OF ITEM CONTAINNO INDICATION DATE INSPECTED EVALUATION NEEDED BY DATE 4" welded pipe flange to pump housing 03-14-2008 03-14-2008 A

COMMENTS RT Interval 0-1 contains a 0.750" linear indication RT Interval 3-4 contains a 0.400" linear indication RT Interval 5-0 contains a 0.200" linear indication ORIGINATED BY IDATE 03-14-2008 T L Tucker - NDE Level I[-RT ACCEPTANCE STANDARD: Examination procedure; NDE-12 Appendix A and ASME Section XIn 1998/2000, IWC-3514 / IWB-3514 and Table IWB-3514-4 CALCULATIONS/COMMENTS: The lengths of the linear indications in intervals 0-1, 3-4 and 5-0 exceeds the allowable limits of the above acceptance standards.

B Indications are Rejectable.

Evaluated By DATE:

(NDE LEVEL III) 03-14-2008 PIP SERIAL NO. /) q&' -0 O/7O ISI COORDINATOR DATE -5' /'-,--o ADDITIONAL EXAMINATIONS []NOT REQUIRED 0] REQUIRED: ISI PLAN ADDENDA S/N:

D SUCCESSIVE EXAMINATIONS []NOT REQUIRED 0 REQUIRED: ISI PLAN ADDENDA S/N:

ISI PLAN MANAGER DATE DISPOSITION [I ACCEPTABLE IN ACCORDANCE WITH IWB-3600 (FMA)

El REPAIRED 0 REPLACED-E COMMENTS DISPOSITIONED BY (ISI Plan Manager)_ DATE

IFORM NDE-RT1I REVI1SION 7 DUKE POWER COMPANY RADIOGRAPHIC EXAMINATION REPORT / TECHNIQUE ID: REVISION 7 Weld // Component Weld FORM NDEoRT1 Component ID: 2RC-P-IN Project: McGuire Unit 2 Procedure NoRevr. NDE 10/23, 12(12 Acceptance/Reporting Standards: 10-A and 12-A Level: Date:

J.D. Shepar dFj4V C II 04-13-08 r ,

Code

Reference:

ASME rI-NC & XI Material: CS: 0 SS: _ _ [1 Diameter: 4" Thickness: .237" Source: Ir-192 Size: .148" Curies: 57.7 Estimated Weld Build-Up: .062" SFD: 4.625" IQI: Film Side N Source Side 1] 7 & 12 Size(s) IQI Design: Standard Hole-Type Film View: Single Composite 5 Number of Film Per Cassette: 2 Film Stand Off NA Film Brandflype: Front Fuji 50 Center NA Back Fuji 50 Shim Size(s): NA Screen Thickness: Front .010" Center NA Back .010" (Ug Ft/D) Actual Ug: .008 Exposure Time: Hrs. Min. Sec. 20 Thicker member used as shimS"" [*

Exposure: [I Single Wall -DoubleWall Image View: 21 Single Wall [I Double Wall TECHNIQUE SET UP OE [F L/ G 1 I Other Draw Sketch

/ i

.......... T........

F."

1.......

Fg.m Offset Offset Superimposed Single Wall Double Wall Double Wall E] Sketch I View View View Attached

• .- S - *- *

[ -II I FILM REVIEW I I T I:

Level Date U Interval Date Indication LengthlSize/Connuent Reviewer 4, 0-1 04-13-08 10,14,16 .0625" III 04-13-08 NJ 01 1 1-2 04-13-08 14,16 .0938" 7 HI 04-13-08 MI --

2-3 04-13-08 16 [I1 04-13-08 01 El IE 3-4 04-13-08 16 'ALe - II 04-13-08 01 [] IL 4-5 04-13-08 14 _ _ _ .0625"

_ _ _ _ 111 04-13-08 NJ El [*] b 5-0 04-13-08 14 .0625" 111-_III04-13-08 NJ U 01 [

01 Q] IL BOIOL Indication and Flawty : 5. Crack 8. Porosity 11. Concavity 14. Rounded

1. Incormn. Fusion 3. Excessive Pen. 6. Slag 9. Tungsten 12. Inclusion 15. Surface

2. Incomp. Pen. 4. UnconsumedInsert 7. Undercut 10. Convexity 13. Elongated 16. Film Artifact Exam Limitations: 1 Yes: *78 %Examined No: (100% Examined) 17. Linear Comments: *See attached sheet for ASME XI limitation calculations. Weld metal and base material on the flange side of the weld was examined. Base material on the pump side of the weld was not examined. 12-2T or 74T equivalent sensitivity. ID hand written on 4-5 interval with a permanent marker.

Second Review: Level: MI Date: 04-13-08 ANIANII Review: , Date:

,,i)

I ISI Item: M2.'kl.f1.0279 .lt~

IDDEAL Limitation Record software suite Site/Unit ...MNS 12 Procedure: NDE-12 Outage No: 2EOC18 Summary No: M2.R11.11.0279 Procedure Rev. 12 Report No:

Workscope: RT PSI Exam R1 Work Order No: 01802766 Page: 2 of 2 Description of Umitation: 4" x .237" NPS welded pipe flange to pump housing weld ISI ID # 2RCHP-IN.

Required exam area includes the 0.625" weld width and 0.250" on both sides of the weld.

The Pipe Flange-to-Pump Inlet configuration does not allow for RT film placement to capture the radiographic image of the 0.250" of base metal on the pump side of the exam area. See sketch of the limitation below.

Calculations:

Required weld/exam area length (L): 16.250" L (measurement taken from the RT film intervals)

Required exam area width WN): 0.625" + .250" + .250" = 1.125" W Required exam area in sq inches: 16.250" Lx 1.125" W = 18.281" Actual area examined in sq inches: 16.250" L x 0.875" W = 14.218" Percent of coverage: 14.218"/ 18.218"- 100 = 78% coverage Sketch of Limitation:

Limitations removal requirements: N/A Radiation field: N/A J~xaminer Ie Signature Date Reviewer A Signature Date E ami 04-13-2008 04-13-2008 0

ier Level Signature Date Site Review Signature Date Other Level Signature Date ANII Review Signature Date