ML14043A108

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Notification of Impracticality for the Third 10-Year Lnservice Inspection Interval
ML14043A108
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 02/12/2014
From: Harkness E J
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-14-031
Download: ML14043A108 (9)
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Text

FE NOCŽ RrstEnergy Nuclear Operating Company Ernest J. Harknsss Vice President February 12; 2013 L-14-031 ATTN: Document Control Desf{ U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant P.O. Box97 10 Center Road Perry, Ohio 44081 10 CFR 50.55a 440-280-5382 Fax: 440-280-8029 Notification of Impracticality for the Third 10-Year lnservice Inspection Interval In accordance with 10 CFR 50.55a, FirstEnergy Nuclear Operating Company (FENOC) is submitting to the Nuclear Regulatory Commission (NRC) a *notification of impracticality related to an inservice inspection where the required visual examination coverage of 100 percent was not achieved.

The notification of impracticality is enclosed and supports the third 10-year inservice inspection interval, which commenced on May 18, 2009 and is currently

__ scheduled to expire on May 17, 2019. There are no regulatory commitments contained in this submittal.

If there are any questions or additional information is required, please contact Mr. Thomas A. Lentz, Manager -Fleet Licensing, at (330) 315-6810.*

Ernest J. Harkness

Enclosure:

Perry Nuclear Power Plant, 10 CFR 50.55a Request IR-058 cc: NRC Region Ill Administrator NRC Resident Inspector NRC Project Manager Perry Nuclear Power Plant 10 CFR 50.55a Request IR-058 Page 1of4 Notification of Impracticality in Accordance with 1 O CFR 50.55a(g)(5)(iii) -lnservice Inspection Impracticality--

1. American Society of Mechanical Engineers IASME> Code Components Affected Reactor Pressure Vessel Support Skirt ( 1 B 13-00001-SP)

ASME Code Class 1 2. Applicable Code Edition and Addenda ASME Boiler and Pressure Vessel Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," 2001 Edition through 2003 Addenda. 3. Applicable Code Requirement Table IWF-2500-1, Examination Category F-A, Item F1 .40 requires a visual examination (VT-3) of 100 percent of the reactor pressure vessel (RPV) support skirt [both interior and exterior surfaces of the skirt], as defined by ASME Figure IWF-1300-1.

4. Impracticality of Compliance Examining 100 percent of the RPV support skirt, as* required by the ASME Code, is impractical.

Examination limitations exist due to the configuration of the RPV support skirt and its thermal insulation package, which is permanently attached to the skirt's interior surface and not designed for disassembly or removal. Examination limitations also exist due to undervessel interferences.

These limitations are inherent to the General Electric boiling water reactor design. 5. Burden Caused by Compliance The RPV support skirt and thermal insulation package were designed and fabricated such that the insulation, which is permanently attached to the interior surface of the RPV support skirt, obstructs the skirt's interior surface and prevents visual examinations.

Removing the obstructions to perform the examination would require the permanent thermal insulation to be redesigned and replaced, which is impractical.

Although theoretically feasible, It is estimated that removing the permanent thermal insulation from the interior surface of the RPV support skirt and replacing it with removable insulation would require several hundred man-hours to stage and erect scaffolding, remove RPV support skirt insulation, perform the required visual examinations, install removable insulation, and remove the scaffolding.

Based on radiological survey results from a March 2009 outage, this work would occur directly below the RPV within radiation fields of 560 milli-Rem (mR) to 1300 mR per hour at head level and 450 mR to 1000 mR per hour at chest level, resulting in a significant increase in cumulative occupational radiation exposure [dose] to personnel without a compensating increase in quality and safety. Due to the existing undervessel interferences and limited accessibility, the use of temporary shielding to reduce this dose is also impractical.

Request IR-058 Page 2of4 6. Proposed Alternative*

and Basis for Use Alternative Examination:

_ Accessible areas of the RPV support skirt have been visually examined.

For the exterior of the skirt, 100 percent of the skirt's surface and 60 skirt mounting bolts have been examined.

The exterior VT-3 examination was performed from within the RPV's biological shield wall. For the interior ()f the skirt, approximately 10 percent of the skirt's surface and 12 of 60 skirt mounting bolts have been examined.

The interior VT-3 visual examination, which was limited due to existing undervessel interferences and permanently installed thermal insulation, was performed from below the RPV using a remote portable camera. This results in an aggregate examination coverage of approximately 55 percent. Basis for Use: Figure 1 depicts the RPV bottom head, RPV support skirt, permanent insulation, and the area viewed using the portable remote camera. During the current 10-year inservice inspection interval, 100 percent of the skirt's exterior surface and 60 skirt mounting bolts were VT-3 visually examined during a 2012 outage. Approximately 10 percent of the skirt's interior surface and 12 of 60 skirt mounting bolts were VT-3 visually examined during the spring 2013 refueling outage. Due to the permanently installed thermal insulation and interferences from existing undervessel components, which include 177 control rod drive hydraulic lines and structural support steel, further VT-3 visual examinations of the skirt's interior surface or skirt mounting bolts was not possible using the remote portable camera. This results in* an aggregate VT-3 visual examination coverage of approximately 55 percent. Areas visually examined were found to be acceptable with no age related degradation or fabrication flaws identified and no indications that exceed the acceptance criteria of ASME Section XI. These examinations provide reasonable assurance of the RPV support skirt's structural integrity.

The two visual examination reports for the support skirt are provided as attachments to this request. Due to existing undervessel interferences and configuration of the RPV support skirt with its permanently installed thermal insulation, the examination requirements of ASME Section XI, 2001 Edition through 2003 Addenda, are impractical.

7. Duration of Proposed Alternative The proposed notification supports the third 10-year inservice inspection interval, which commenced on May 18, 2009.

Request IR-058 Page 3of4 8. Precedent The Nuclear Regulatory Commission (NRC) approved similar requests for the River Bend Station and Grand Gulf Nuclear Station: NRC letter tQ Entergy Operations, Inc.,

Subject:

"River Bend Station, Unit 1, Request for Relief From ASME Code,Section XI, Requirements for Reactor Pressure Vessel Support Skirt for the Second 10-Year lnservlce Inspection Interval * (TAC No. ME9654)," September 24, 2013. [Accession No. ivlL13261A379]

NRC letter to Entergy Operations, Inc.,

Subject:

"Grand GulfNuclearStation, Unit 1, Relief Requests GG-ISl-005 Through GG-ISl-012 for Second 10-Year lnservice Inspection Interval (TAC Nos. ME1376, ME1377, ME1378, ME1379, ME1380, ME1381, ME1382, and ME1383)," May 25, 2010. [Accession*No.

ML101410002]

9. Attachments
1. Visual Examination of Pipe Hanger, Support or Restraint (VT-3), Report No. 1042-13-094, December4, 2013. * [Interior of RPV Support Skirt] 2. Visual Examination, Report No. 1Q800-13-047, June 25, 2012. [Exterior of RPV Support Skirt]

Request IR-058 Page4of4 .** . ..... _* . .'J*,* *** . .' .. *. *,, ,, .

  • t .** *. ' .* r \ . RPVSUPPORT SKIRT (TYP.) ---=:!: .. -*.* ..... RPVSUPPORT . *. SKIRT (TYP.) NON-REMOVABLE PERMANENT INSULATION, EXCEPT AT SMALL ACCESS PANELS (4 LOCATIONS)

I . .. . . , *. * . CENTERLINE OF CONTROL ROD (TYP. 177 TOTAL) PERMANENT INSULATION

< ELEVATION VIEW> . . ... AREA VIEWED USING REMOTE PORTABLE CAMERA (SUPPORT SKIRT MOUNTING BOLTS ARE NOT DEPICTED)

FIGURE 1 -RPV Bottom Head. RPV Support Skirt and Permanent Insulation

    • .*

FE NOC Visual Examination of Pipe Hanger, Support or Restraint (VT-3) Attachment 1 . Request IR-0.58 Page 1of2

  • Site/Unit:

Perry I 1 Procedure:

NQl-1042(3)

Outage No.: RF014 Summary No.: 002825 Procedure Rev.: 16 Report No.: 1042-13.094;

Workscope:

ISi Work Order No.: Page: 1 of 2 Code: ASME Sec XI 2001E/2003A Cat./ltem:

F-AIF1.40 . Location:

RB-DW ------------------------...,----

Drawing No.:

  • 305-006-104

==

Description:==

RPV SUPPORT SKIRT (WA) System ID: 1813 ------------------------------------------------------------------------

Component ID: 1813-00001-SP Limitations:

Undervessel lnsulatlon Package Light Meter Mfg.: NIA Serial No.: ______ ....;;..N=/A....;;.._

____ _ lllumlnatlon:

Light Verification Times: Cal In O ------------

NIA NIA NIA Cal Out 0 ------Temp. Tool Mfg.: NIA Serial No.: N/A Surface Temp. ______ °F Resolution:

Visual Acuity Card 0.105" Characters System Condition:

Cold Visual Equipment/Aids:

Remote Camera System with battery operated llghUng, Visual Acculty card Varlable Spring SupportO Constant Support@ Restraint 0 Other 0 Visual Examination:

Remote 1) Component Support Identified

2) Deformation or Structural Degradation
3) Support Structure/Concrete/Embedments
4) Support Items/Attachments/Connections
5) Cracks In Welds 6) Anchors/Fasteners/Integral Attachments
7) Thread Engagement
8) Loose/Missing/Detached Items 9) Cotter Pins/Locknuts (Broken/Missing/Loose)
10) Hanger/Rod/Movement Obstructions
11) Mlsallgnment/Clearances/Blndlng
12) Loose Position/Load Indicator/Settings
13) Pivot Wear/Close Tolerance Surfaces 14) Corrosion/Foreign Material/Coating
15) Travel Stops/Locking Devices 16) Other (Describe)

Cold Load Setting: N/A Hot Load Setting: N/A Comments:

SAT -Ji._ -Ji._ -Ji._ UNSAT --* N/A See Comments ...Ji._ Position Indicator Reading: N/A --------------

Pin to Pin Setting: NIA --------------

Examined the Inside of RPV skirt support from the El 583 CRD undervessel area. See supplemental sheet for details. Original exam date 4119/2013 Results:

UNSAT 0 EVAL D Revised 11/25/2013 per CR-2013-18628 Percent Of Coverage Obtained > 90%: see comments Reviewed Previous Data: NIA E)C8mlner Level Ill Wirtz, Charles J Examiner N/A Other NIA Level Level NIA Date Reviewer NIA Signature Date Site Review Fuller Jr, Richard Date ANll Review Laps, Thomas Signature .Date Date 11/25/2013 FE NOC Supplemental Report Attachment 1 Request IR-058 Page2of2*

  • Report No.: 1042-13-094 Page: 2 of 2 Summary No.: 002625 Examiner:
WlrtZ, Level: _11_1 _ Reviewer:

_N_IA _________

--"._ Date: Examiner:

NIA Level: . N/A Site Review: Fuller Jr, Richard Other: N/A Level: N/A ANH Review: Laps, Thomas __________

Comments:

Date: 11/25/2013 Date:

....,....+,...,...,., _ The exterior of the RPV skirt support was examined during a forced outage on 8/15/12, refer to report 1QB00-13-047.

This exam was a best effort attempt to examine the Interior of the RPV skirt. The portions of the Interior of the RPV skirt support that are directly under the reactor vessel and accessible via the bloshleld and through the skirt hatch at O degrees, Is not vlslble because of the permanent sheetmetal insulation package that Is under the reactor vessel, which fonns a floor right at the hatch level (hiding the Inside bolts of the skirt support) and llnes the Interior walls of the skirt. This exam was performed from 583' CRD undervessel area. A portable remote camera that booms out to 20 feet was used from the undervessel carousel platfonn to boom up to below the undervessel Insulation package and look at a right angle at the Inside part of the skirt that is below the undervessel lnsulatlon package/floor.

Access was only afforded In a couple areas of the annulus area between the CRD shoot out steel and the Inside of the RPV pedestal.

  • I was assisted by Sean Franklin.

We were only able to boom up to the necessary elevation from a couple places right Inside the undervessel keyway (at approx 190 degrees) and at approximately 270.degrees.

In other areas, the CRD Insert and withdraw lines or structural steel precluded access. There are 60 bolts outside the skirt and 60 Inside the skirt. From the 3 locatatlons where we able to boom up, we were able to see 22 of the 60 bolts, with only about 12 of those at VT-3 distances and resolution.

All of the bolUng appeared to be tight and Intact. The bolting did appear to be covered with fight surface rust, but nothing so heavy as to obscure the threads. In total It Is estimated that this exam looked at about 10% of the skirt Interior, but that Included 20% of the Interior bolting at VT-3 resolution and 36. 7% with best effort looks. Resolution checks were perfonned*prlor to and after the exams. Total composite coverage at VT-3 examination distances and acuity Is 55% (100% of the exterior and approximately 10% of the Interior).

.r FE NOC Vlsual Examination Site/Unit:

Peny I 1 Procedur&l

___ Na_f..1_0_42(...,S..._)

__ Summary No.: 002625 Ptocedure Rev.: 18 --------Worbc;ope:

181 Work Older No.: 200412044

Code; ASME Sec XI 2001E/2003A Cal.ntern:

F-A/F1,40 Location:

Drawing No.:

==

Description:==

.RPV SUPPORT SKIRT (WA) System ID: 1813 Attachment 2 Request IR-058 Page 1of2 Outage No.: .Rf014 -----:Report No.: 1QBOIM3-047 Page: 1 of a ComponentlD:

1813-00001-SP Comments:

See supplemental page for datasheet and required slgnaturee.

Results: SAT lltJ UNSAT 0 Percent Of Ccwerege Obtained > 90%: Examiner Level Signature NIA. See attached 1;:.xamlner Level NIA Signature .f/A Other Level NIA Signature NIA EVAL 0 No Date 8115120i2 Date Date Urnlt.ad Exam (60%) Sat. Reviewed Previous Data: Reviewer.

NIA Site Review Funer Jr, Richard ANll Review Lape, Thomae NIA Signature Date s19nature Date 8/1112012 Signature Date 8J28/2012 a*93.l -e1 s a 67 FE NOC Supplemental Report Attachment 2 Request IR-058 Page2of2

  • Reporj No.: 1Q8Q0.13-G47 Page: 2 of 2 ""°'1rrtary No.: 00282& '--FE NOC Visual Examination of Component Support& and Snubber& fVT-3) ___ .. ,...<<>>-.... 11M ........ 2 __ 0ula98 Nii.: NIA Pnlc:edur9 Rev.: ---"'-6'"---

W0111 OnW Na.: 1ooonoae RelJOI\ No.: 1042-12EMJff Page: _!_. ol _1 _ Code: ___ ....;SOct;.;;..;.;;....;XJ;....

__ Ca1Jltem:

F-A I Ft.AO Location:

_____ 0,.,..;;.;1.,;_

OmM9 HS406-104 Desalptiin:

Sy11em ID: 1813 Comi>oTien I 10: 1813-00001-81>

Llmitatkllu; EJtArlol'

  • Ul'l'Ues only lfaht HJA Serial No.:

Uhmllnatlon: .Adi!qualll i.lg!lt Velif.alton Times: Ce! In 0 NIA NIA IUA Ccl Ou1 0 NIA TD111p. TDOI 1.!tiJ.: NIA Selfal No.: . NIA Slllfi1CO Temp.: NIA 'F

o. tOS" Charactar Card Surface Common: As.found Visual EQU!pmrntlA!d):

F1111hllghL O.tOS" vl!nral acul!y card (CRC 10.tlA) Viou-Ol &amlnnt'..1111:

Dlrocl Seo All BAT UN!IAf NIA Com:ncnla Spttng Supports SAT UNSAT NIA 1)

Obstndon _L --* , 9) Off Stale High _ _L 2) CrocQ or uncar 11111. _L --20) Oii Scale L---L-3) Loasa Pml!I ..L. --21) Loctl"i} Davia! In Plam -..!!!._ 4)

_:!__ Oeoraded -..!!!._ 6) Olls!r. PMS_:!__ 23) Givsa M1sa1i9'1ment

_ _L 6) Wear ..J!_ 7)

..L. MochanlQd Sm.dllltta

8) CcinlamJuinta

,, 24) Swing Clearance

_ _t_, 9) ll!IPIVflef Weld Relnfar. " 25) Bent Exlamlon Rod --L 10) Physical DQ!ormalloll

...L. 26) Hclu$illg Oamag& ---11) MistJ3o _..!!_

12) Slipped ClamPI _-l!-, 27) l.ewl _ _L, 13) OUwlr (DosCribe)

-...!'--28)Lmage_

-_:!__ 14) Conod Sellfngs Ye$ No "' NIA 29) Pl51Dn FU!y Elll!lndcd 1 S) Ac:lllal Sflllln9 NIA 30) PlslDn Fl9/ Rlllnldad

_ ..:t_ 18) Serial No. NIA lrweitod -..!!!._ c-t.111 Load8u-'8

32) Pil!an Damage . 17)

-..J!_ 1s1 Housing oamaoo _ --. Com1118111&:

UmltcKt OQllltndonperformod.

Ellta!lo1CO Ulewael, lnlltRel llllBl'lllnBllon c:owo111911.

SAT iJ UHSAT 0 EVAL 0 No NIA Exilmtner 1.11ve1 n Fnanldln, 8aan M. Soo c--Dal& llH/2012

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