ML17164A670
| ML17164A670 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/23/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17164A669 | List: |
| References | |
| NUDOCS 9707150076 | |
| Download: ML17164A670 (20) | |
Text
~R RE0II
~o Cy Cl UNITED STATES NUCLEAR REGULATORY COMMISSION I
WASHINGTON, D.C. 205554001 0
r+
0 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE RECONCILIATION OF THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION ISI PROGRAM PLAN FOR PENNSYLVANIA POWER 5 LIGHT COMPANY SUS UEHANNA STEAM ELECTRIC STATION UNITS 1
AND 2 DOCKET NOS.
50-387 AND 50-388
- 1. 0 INTRODUCTION The Technical Specifications for Susquehanna Steam Electric Station, Units 1
and 2, state that the inservice inspection of the American Society of Mechanical Engineers (ASHE) Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASHE Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(g),
except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).
It is stated in 10 CFR 50.55a(a)(3) that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of
.quality and safety.
Pursuant to 10 CFR 50.55a(g)(4),
ASHE Code Class 1,
2, and 3 components (including supports) shall meet the 'requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASHE
- Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components,"
to the extent practical within the limitations of design,
- geometry, and materials of construction of the components.
The regulations require that inservice examination of components and system pressure tests conducted during the, first 10-year interval and subsequent intervals comply.
with the requirements in the latest edition and addenda of Section XI of the ASHE Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.
The applicable edition of Section XI of the ASHE Code for Susquehanna, Unit 1 first 10-year inservice inspection (ISI) interval is the 1980 Edition through the Winter 1980 Addenda (80W80),
and 1980 Edition through Winter 1981 Addenda (80W81) for Susquehanna Unit 2.
Pursuant t'o 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASHE Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASHE Code requirement.
After evaluation'f the determination, pursuant to 10 CFR 50.55a(g)(6)(i),
the Commission may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due'onsideration to the burden upon the licensee tIIat could result if the requirements were imposed.
h 9707i 50076 970b2S PDR ADQCK'05000387 PDR Enclosure
In a letter dated June 1,
- 1995, Pennsylvania Power 3 Light Company submitted to the NRC Revision 3 (Unit 1) and Revision 2 (Unit 2) to its first 10-year ISI program.
The program revisions included two new (one per unit) and eight revised (four per unit) requests for relief from the requirements of ASHE
- Code,Section XI.
In addition, six requests for relief (three per unit) were withdrawn.
In a conference call dated November 30, 1995 the NRC staff requested additional information concerning the first 10-year ISI program plan interval.
The licensee provided the requested additional information in a letter dated January 9,
1996'his submittal withdrew one request for relief and included two requests for relief pertaining to the augmented reactor pressure vessel examination required under 10 CFR 50 '5a(g)(6)(ii)(A) that was performed during the first 10-year intervaled 2.0 EVALUATION AND CONCLUSIONS The staff, with technical assistance from its contractor, the Idaho National Engineering Laboratory (INEL), has evaluated the information provided by the licensee in support of its reconciliation of the First.10-Year ISI Program Plan for Susquehanna Units 1 and 2.
Based on the information submitted, the staff adopts the contractor's 'conclusions and recommendations presented in the Technical Letter Report attached Relief is granted or should remain granted, pursuant to 10 CFR 50.55a(g)(6)(i), for Requests for Relief 1RR-12, 1RR-15, 1RR-17, 1RR-23 2RR-13, 2RR-14, 2RR-15, and 2RR-20; Such relief is authorized by law and will not endanger life, property, or the common defense and security, and is otherwise in the public interest.
The relief has been granted giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility For Requests for Relief 1RR-19 and 2RR-16, relief from the augmented examination requirements of Susquehanna's FSAR, Section 6.6.8 is approved as requested.
Requests for Relief 1RR-24 and 2RR-21 were not evaluated in this report.
The licensee's proposed alternative to the augmented reactor vessel examination specified in 10 CFR 50.55a(g)(6)(ii)(A) will be evaluated in a subsequent report.'equests for Relief 1RR-3, 1RR-10, 1RR-21, 1RR-18, 2RR-3, 2RR-8, and 2RR-18 have been withdrawn by the licensee in its June 1,
- 1995, submittal'ttachment:
Technical Letter Report Principal Contributor:
T. HcLellan Date:
June 23, 1997
0 TECHNICAL LETTER REPORT ON THE RECONCILIATION OF THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN FOR PENNSYLVANIA POWER
- 5. LIGHT CONPANY SUSQUEHANNA STEAN ELECTRIC STATION, UNITS 1
AND 2 DOCKET NUMBERS: 50-387 AND 50-388 T.N
~INTR I I
N By letter dated June 1,
1995, the licensee, Pennsylvania Power 8 Light
- Company, submitted the Susquehanna Steam Electric Station Reconciliation of the First 10-Year Interval Inservice Inspection (ISI) Program Plan For Susquehanna SES Units I and 2, containing Revision 3 (Unit 1) and Revision 2
(Unit 2) of the first 10-year interval ISI Program Plan.
The program revisions included two new (one per unit) and eight revised (four per unit) requests for relief from the requirements of the American Society of
'echanical Engineers (ASNE) Boiler and Pressure Vessel Code Section XI.
In addition, six requests for relief (three per unit) were withdrawn in the June 1,
1995, submittal.
In a letter dated January 9,
1996, the licensee provided additional information regarding the first 10-year interval as a
result of a November 30,
- 1995, conference call.
This submittal withdrew one request for relief and included two requests for relief pertaining to the augmented reactor pressure vessel examination of 10 CFR 50.55a(g)(6)(ii)(A) that was performed during the first 10-year interval.
The Idaho National Engineering Laboratory (INEL) staff has evaluated the information provided by the licensee regarding the Program Plan revisions in the following section.
2.0 EVALUATION The Code of record for the Susquehanna Steam Electric Station first 10-year ISI interval is the 1980 Edition, Winter 1980 Addenda (SOWSO) for Unit 1, and the 1980 Edition through Winter 1981 Addenda (SOW81) for Unit 2.
The information provided by the licensee in support of the reconciled Program Plans has been evaluated and documented below.
A.
The licensee determined that seven requests for relief were no longer required and removed them from the first 10-year ISI Program Plan.
The withdrawn relief requests and corresponding submittal dates are listed in the table below.
'ithdraw'n'..
.Requests-
.'for".Relief 1RR-3 1RR-10 1RR-21 2RR-3 2RR-8 2RR-18 1RR-18 Unit Submittal:.Date June 1,
1995 January 9,
1996 Attachment B.
Re uest for Relief No.
1RR-12 Rev.
3 Examination Cate or B-A Items 1.22 and B1.40 eactor Pressure Vessel RPV Meridional Head and Head-to-n e
e ds pote:
As the result of a Nuclear Regulatory Commission (NRC) Safety Evaluation (SE) dated January 9,
1995, the licensee deleted RPV longitudinal Weld BF from Request for Relief 1RR-12 in Revision 3 of the Program Plan.
Since.this change does not affect the technical content of the request, relief should remain granted, pursuant to 10 CFR 50.55a(g)(6)(i),
as concluded in the January 9,
- 1995, SE.
C.
Re uest fo elief Nos.
1 R-15 Rev.
3 and 2RR-13 Rev.
2 E aminatio Cate or B-F Items B5.50 B5.51 and B5. 130 Pressure Retainin issimila Metal Welds and Examination Cate or B-J Items B9. 11 B9. 12 and B9.31 Class 1 'n Welds Code Re uirement:
Table IWB-2500-1, Examination Categories B-F and B-J, Items B5.50, B5. 130, B9. 11, and B9. 12 require volumetric and surface examinations as defined by Figure IWB-2500-8 for all RPV dissimilar metal safe end welds and selected circumferential pipe welds greater than or equal to 4-inch nominal pipe size (NPS).
Examination Category B-F, Item B5.51 requires a surface examination as defined by Figure IWB-2500-8 for dissimilar metal welds less than 4-inch NPS.
Examination Category B-J, Item B9.31 requires 100X surface and volumetric examination, as defined by
=Figures IWB-2500-9, -10, and -11, for branch connection welds greater than or equal to 4-inch NPS.
Licensee's Code Relief Re uest:
The licensee has'equested relief from performing the surface and/or volumetric examinations, to the extent required by the Code, for the welds listed in Tables 1RR-15 and 2RR-13 below.
These welds have been added to Requests for Relief 1RR-15 and 2RR-13, respectively',
which were previously evaluated in NRC SEs dated January 9,
- 1995, and April 13, 1995.
" lv '+"""-':~ -'"'""':-"'~":"""" <-"'-'"~ "-~ "."'"<'"""TABLE"-1RR-'l5'@'-".--"'-"<':""~""-'~~'"~'"'::-""""'-@"<>"'-"'"""':-"~~
- Cat'."
- /:Ite'm'.;;.:
B-J B9.31 B-J/B9.12 B-J/B9.12 B-F/B5.50 B-F/B5.51
- ~ Wel d: Numb'e'r,'-'):.'-:,':;;
VRRB312-3-B VRRB312-2-V VRRB312-2-U VRRB312-10-V VRRB312-10-U DCA1031-F W-16 DCA1031-FW-57
'0X Volumetric 87.5X Volumetric 87.5X Volumetric OX Surface OX Volumetric 36X Surface
- l-imi,tinge,
- Conditi'on(-:.(F:.:-;.::,.:-',.'.':;::$.
Com onent confi uration Component configuration Component configuration Whip restraint directly over weld Adjacent whip restraint
iCat":/Item':,"~.
B-J/B9.11
- '..Mel'd.':;:Number'..'.j4,,:::
VNBB214-FW-B-4
- C'ove'rage~<-.'."<6";:;":.',",~':.':.".::::L'xiii)ting ',Con'dition'j~;:".-'.~~."::-':".".'<j~
85.4X Volumetric Adjacent pipe whip 86X Surface restraint B-J/B9.12 B-J/B9.11 VRR313-10-R VNBB213-FW-04 46X Volumetric 46X Surface 86X Volumetric 86X Surface Pipe support clamp Whip.restraint weld B-F/B5. 130 B-J/B9.31 DCA2301-F W-2 VRRB314-3-B OX Volumetric OX Surface Support directly over weld 50X Volumetric Component configuration Licensee's Basis for Re uestin Relief (as stated):
"Each individual weld requiring relief is listed in Table 1RR-15-1
[and Table 2RR-13-1, both paraphrased above].
Each weld is detailed as to plant system, pertinent Code information, limiting condition(s),
estimate of examination
- coverage, and basis for relief."
Licensee's Pro osed Alternative Examination:
No alternatives to the Code requirements were proposed.
The Code-required surface and/or volumetric examinations were performed to the extent practical.
In addition, Examination Category B-F and B-J welds are subject to VT-2 visual examination during system pressure testing following each refueling outage and during the system hydrostatic test once during the interval.
Evaluatio The~Code requirements for the subject Class 1 piping welds include volumetric and/or surface examinations.
- However, access is limited by component configuration, supports covering the welds, or adjacent obstructions.
Therefore, it is impractical to meet the examination coverage requirements of the Code for these welds.
To perform the examinations to the extent required by the Code, design modifications would be necessary to provide sufficient access for examination.
Imposition of this requirement would cause a considerable burden on the licensee.
The licensee has performed the required examinations to the extent practical and has examined a substantial portion (at least 50X) of the Code-required examinations for a majority of the subject welds.
Consequently, any significant patterns of degradation existing in these
~
welds would have been detected, and reasonable assurance of the structural integrity has been provided.
For the remaining welds, examinations were limited to less than 50X (in two cases OX), and the detection of patterns of degradation is less certain.
For the two dissimilar metal welds, the Code-required examinations were completely obstructed, but the welds could
not be replaced by other welds since all Examination Category B-F welds are already included in the ISI program.
- However, these welds are part of a larger group of Class 1 piping welds that did receive complete examination, and the overall reduction in examination coverage is small compared to the weld metal that was examined.
Therefore, any significant patterns of degradation, if present, would have been detected by the examinations that were performed.
These examinations, combined with the Code-required pressure
- tests, provide reasonable assurance of the structural integrity of the subject piping systems.
'ased on the impracticality of meeting the Code coverage requirements and the examinations that were performed on these and similar welds, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
For welds included in previous submittals and addressed in the January 9,
- 1995, and April 13, 1995 evaluations, relief should remain granted pursuant to 10 CFR 50.55a(g)(6)(i).
D.
e uest for Relief Nos.
2 Examination Cate or C-C Item C3.40 C3.20 Inte rail Welded Attachments to Class 2
Note: Integrally welded attachments to Class 2 piping were changed from Item C3.40 in the 80W80 Code to Item C3.20 in the 80W81 Code.
Therefore, the Unit 1 components are categorized as Item C3.40, and Unit 2 components are Item C3.20.
The examination requirements are identical for both items.
Code Re uirement:
Table IWC-2500-1, Examination Category C-C, Item C3.40 (C3.20) requires a surface examination, as defined by IWC-2500-5, for integrally welded attachments to piping whose base material design thickness is 0.7P inches or greater.
Examination is limited to those components required to be examined under Examination Categories C-F and C-G.
Lice see's Code Relief Re vest:
The licensee has requested relief from performing the surface and/or volumetric examinations, to the extent required by the Code, for the welds listed in Tables 1RR-17 and 2RR-15 below.
These welds have been added to Requests for Relief 1RR-17 and 2RR-15, respectively, which were previously evaluated in NRC SEs dated January 9,
- 1995, and April 13, 1995.
J
',"-.,':.'Coiiiponent.::f,l'::::
'.""-'.:::":..'Sy'tem:"'".)~;-.:::Coverage'-,.'.:
GBB1011-HW-2A GBB1011-HW-2B GBB1011-HW-2C GBB1011-HM-2D DBB1212-HW-3A DBB1212-HM-3B DBB1212-HW-3C DBB1212-HW-3D GBB1014-HW-1A GBB1014-HW-1B GBB1014-HM-1C G8 81014-HM-1D GBB1014-HW-18A Pipe lugs/
CS Pipe lugs/
RCIC Pipe lugs/
CS Pipe-plate/
CS 89X 88X 89X 39X Access limited due to hanger clamp Exams completed to extent practical.
Access limited due to hanger clamp Exams completed to extent practical.
Access limited due to hanger clamp Exams completed to extent practical.
Access limited due to adjacent welded pipe support - Exams completed on remaining three integral attachment welds (18 B,
C,
& D)
.':."';Corn'oneiiti.:::i,:.";": ".:Confi '.System":-,
Cov'e'i a'"..
- -":.l'~:.::-',:::;.'-.',:L'imitin:::Conditi on:::."':-:,".::::.;.'BB2012-HW-3A HBB2012-HW-3B HBB2012-HW-3C HBB2012-HW-3D HBB2091-HW-3A HBB2091-HW-3B HBB2091-HW-3C HBB2091-HW-3D DBB2141-HW-Bi DBB2041-HM-6A DB82041-HW-6A DBB2041-HM-6A Pipe-to-lug wel ds/RC IC Pipe-to-lug welds/HPCI Pipe-to-plate/HPCI Pipe-to-plate/HS 88X 80X 67X 81.5X Clamp arrangement on pipe support limits access to one side of lug.- Exams completed to extent ractical.
Clamp arrangement on pipe support limits access to one side of lug Exams completed to extent ractical.
Penetration seal remaining welds (Ag, 8C, and 8D) corn letel examined.
Whip restraint - Exams completed to extent practical.
Licensee's Basis or Re uestin Relief (as stated):
"Table 1RR-17-1
[and Table 2RR-15-1, both paraphrased above] list[s] each individual integrally welded attachment requiring relief from Code examination requirements.
In addition, each attachment weld is detailed as to physical plant information, limiting condition, percent of examination
- coverage, and basis for relief."
Licensee's Pro osed Alternative Examination:
No alternative to the Code requirements has been proposed.
The Code-required surface examinations were performed to the extent practical.
valuat o
The Code requires a
100X surface examination for the subject integral attachment welds.
- However, access to the examination areas is restricted by physical obstructions that preclude a
100X surface examination.
Therefore, the Code requirements are impractical for these integrally welded attachments.
To perform the examination to the extent required by the Code, design modifications would be necessary to allow access for examination.
Imposition of this requirement would create a
considerable burden on the licensee.
In most cases, a significant portion (at least 80X) of each weld was examined.
For two of the attachment
- welds, coverage was limited to less than 80X on one of multiple attachments at a single location.
In these
- cases, the remaining welds (i.e., three out of four) at that location did receive complete examination.
Since, the condition of the associated attachment welds should be representative of those for the partially examined welds, any existing patterns of degradation would have been detected.
Therefore, adequate assurance of the structural integrity of the subject components has been maintained.
Based on the impracticality of meeting the Code coverage requirements for the subject welds and the portion of the examinations that were completed, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
For welds included in previous submittals 'and addressed in the January 9,
- 1995, and April 13, 1995, safety evaluations, relief should remain granted pursuant to 10 CFR 50.55a(g)(6)(i).
E.
Re uest for Relief No.
2RR-14 Rev.
2 Examination Cate or B-K-1 Item B10. 10 Cla s
1 Inte rail Welded Attachments to Pi in Code Re uirement:
Table IWB-2500-1, Examination Category B-K-l, Item B10. 10 requires a surface or volumetric examination as defined by Figure IWB-2500-13, -14, or -15.
Licensee's Code Relief Re uest:
The licensee requested relief from performing the surface examinations, to the extent required by the
- Code, for the integrally welded attachments in Table 2RR-14 below.
These welds have been added to Request for Relief 2RR-14, which was previously evaluated in an NRC SE dated April 13, 1995.-
,..';:C'om> "o<n'en't'k.-":;,. <<>pj's,<<<<>,c<<<<?'<<.
<<<><< <<<><;><><<<<.,'>.,<y>>">'~<'~j>< ><<<<,<> <<,:<<<: ><<;<>><<>>'<p<<~<<'j><,",><
::;:;:;:;::.'-';:.';Sy'tem:"'-'->>:,'-:!"::;~'i.i'~':::::,'.: ~b.< ':::.'Basi iP~"',i':::":,<"i:"-""'-",'.".";i,
<<<>> <P: '":3."<<@<:<':S.;.,
5Cov>e<r'a"e':':
RWS200-HW-10AA RWS200-HW-10AB RWS200-HW-10AC RWS200-HW-10AD RWS200-HW-2A RWS200-HW-2B RWS200-HW-2C'WS200-HW-2D RWS200-HW-2E RWS200-HW-2F RWS200-HW-2G RWS200-HW-2H Four pipe-to-lug welds/
Reactor Recirculation Height pipe-to-lug welds/
Reactor Recirculation Hanger clamp restricts access; clamp impractical to remove due to lack of adequate deadweight supports'.
Exams corn'pleted on three of four sides of each lu Hanger clamp restricts access; support necessary to maintain proper alignment of'system, clamp impractical to remove.
88X 88X Licensee's Basis for Re uestin Relief (as stated):
"Table 2RR-14-1
[paraphrased above] lists each individual integrally welded attachment requiring relief from Code examination requirements.'n
- addition, each attachment weld is detailed as to physical plant information limiting condition, percent of examination
- coverage, and basis for relief."
Licensee's Pro osed Alternative Examination:
No alternatives to the Code requirements have been proposed.
The Code-required examinations were performed to thy extent practical.
Evaluation:
The Code requires surface examination of the subject integrally welded attachments.
However, physical obstructions limit access to the examination area.
The hanger clamps are impractical to
- remove, and design modifications would be required to perform the examinations with them in place.
Therefore, the surface examinations are impractical to perform to the extent required by the Code.
To meet the Code requirement, the subject attachment welds and/or adjacent hangers would have to be redesigned and replaced to allow access for examination.
Imposition of the requirement would cause a considerable burden on the licensee.
In all cases, a significant portion (88X) of the Code-required surface examinations were performed.
Therefore, existing patterns of degradation would have been detected, and reasonable assurance of the structural integrity of these attachment welds has been provided.
Considering the examinations that were performed and the impracticality of meeting the Code requirements, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
For welds included in previous submittals and addressed in the April 13, 1995 safety evaluation, relief should remain granted pursuant to 10 CFR 50.55a(g)(6)(i).
F.
Re uest o
e ef No.
1RR-19 Rev.3 Au mented Examinatio s of Hi h
Ener Pi in er FSAR Section 6.6.8 and Austenitic Stainless Steel i
NUREG-0313 u mented Exami ation:
Susquehanna Steam Electric Station, Unit 1
- FSAR, Section 6.6.8 specifies a 100X volumetric.examination of all Class 1 and 2
circumferential welds in piping between containment isolation valves for which no breaks are postulated.
NUREG-0313, Technical Report on Haterial Selection and Processing Guidelines for BUR Coolant Pressure Boundary Piping, specifies ultrasonic examination of piping that is prone to intergranular stress, corrosion
'cracking (IGSCC).
Selection of welds and inspection scheduling requirements are based on material type, cracking history, and preventive and repair measures taken (e.g.,
stress improvement and weld overlay).
Licensee's Relief Re uest:
The licensee has requested relief from performing the augmented volumetric examinations to the extent specified by FSAR 6.6.8 and NUREG-0313 for the'welds listed in Table 1RR-19 below.
These welds have been added to Request for Relief 1RR-19, which was previously evaluated in,an NRC SE dated January 9,
1995.
'.>",-'Augmented";
.'.':<,::,':Com 'onent..'"0,,".:,'":.Conf) 'ur'ation'.
- ".
- :::'";;,;'L'iiiii'ti'ng.".;'-';.>'~".
..'Condi ti'o'n" Bas i'
.".!Co'ver",a "e"':.
FSAR6.6.8 NUREG-0313 DBB1181-1-A VRRB311-FM-A20 VRR8311-I-A VRRB311-2-B VRRB312-FW-B20 VRRB312-10-B VRRB312-12-A VRRB312-3-A VRRB312-3-B DBB1181-1-A Pipe-Sweepolet/
Feedwater Weldolet-Pipe/
Reactor Recirculation Component configuration Component (Weldolet) configuration 50X 50X Licensee's Basis for Re uestin Relief (as. stated):
'"Individual components requiring relief are listed in Table 1RR-19-1
[paraphrased above].
Each component is detailed as to augmented examination source/requirement; limiting condition, estimate of examination
- coverage, and basis for relief."
Lice see's Pro osed Alternative E amination:
No alternative to the augmented examination requirements has been proposed.
The augmented examinations were performed to the extent practical.
Th
- b" t 1d i
IDOY 1
h i ti p
t of the augmented inspection program at Susquehanna Steam Electric Station Unit 1.
- However, component configuration makes the augmented examinations impractical to perform.
As stated by the licensee, a substantial portion (50X) of each weld was examined.
In addition, the NUREG-0313 welds are part of a much larger examination sample of welds that are being completely examined.
Further assurance of the structural integrity is provided by the fact that as part of the feedwater and reactor recirculation systems, these welds receive the Code-required pressure tests with the remainder of the Class 1, 2, and 3 pressure retaining piping.
Therefore; reasonable assurance of structural integrity has been provided, and it is recommended that this request be approved.
The examinations performed on the subject welds, along with the Code-required pressure examinations and the complete examination of other, similar welds, provide adequate assurance of continued structural integrity.
For welds included in previous submittals and addressed in the January 9,
1995 safety evaluation, relief should remain approved.
G.
e uest for Re ief No.
2RR-16 Rev.
2 Au mented Examinations of Hi h Ener Pi in er FSAR Section 6.6.8 and Austenitic Stainless Steel i 'n e
NUR G-0313 u mented Examination:
Susquehanna Steam Electric Station Unit 2 FSAR, Section 6.6.8 specifies a
100X volumetric examination of all Class 1 and 2
circumferential welds in piping between containment isolation valves for which no breaks are postulated.
NUREG-0313, Technical Report on Haterial Selection and Processing Guidelines for BUR Coolant Pressure Boundary Piping, specifies ultrasonic examination of /ping that is prone to inter-granular stress corrosion cracking (IGSCC).
Selection of welds and inspection scheduling requirements are based on material type, cracking history, and preventive and repair measures taken (e.g.,
stress improvement and weld overlay).
icensee's Relief Re uest:
The licensee requested relief from performing the augmented volumetric examinations to the extent specified by FSAR Section 6.6.8 and NUREG-0313 for the welds listed in Table 2RR-16 below.
These welds have been added to Request for Relief 2RR-16, which was previously evaluated in the NRC SE dated April 13, 1995.
5<>:<,;::,",@P>kjÃP'.".,s..". >A'<::.;~:>'<'":;;:~8;~'R:;>j~;A:,c~'5,"iTABLE)2RR 16..;,.g.>~":>)Vqj.;.",$g.~c~R~4'8'<+>P,';>'.':>x), x, j"
>~'Augiiiented::
>'=:,.::;;~~~,'.::;;.::<'. j'j::j~~;:
'-'.::::;.Con'fi " Sy'tem.
,":," "..-':j~,.L'imi,t,iiig',.,:~',:,'.',':,';".',>,.:':.:.":>kg','~:.,",,',:.,:,:,'~";:,,:;:.',',
3'-.',;:Coiidition'as i s':: ",:::;,'Cover'a" e.
FSAR 6.6.8
.DLA2011-FW-6 DBB2181-1-A Pipe-valve/
Feedwater Sweepolet-to-i e
RWCU Access restricted due to adjacent whi 'estraint Component confi uration 83X 50X NUREG-0313 VRRB313-FW-A20 VRRB314-FW-B20 VRRB313-14-A VRRB313-1-A VRRB314-3-A VRRB314-3-B Sweepolet-to.-
ieRR Pipe-to-sweepolet/RR Component confi uration Component configuration 50X 50X Licensee's Basis or e uest'n Re ief (as stated):
"Individual components requiring relief are listed in Table 2RR-16-1
[paraphrased above].
Each component is detailed as to augmented examination source/requirement, limiting condition, estimate of examination
- coverage, and basis for relief."
Licensee's Pro osed Alternative Examination:
No alternative to the augmented examination requirements has been proposed.
The augmented examinations were performed to the extent practical.
E 1
':T> >>" t id
>I 1>N 1 ti i
i
> t of the augmented inspection program at Susquehanna Steam Electric Station Unit 2.
- However, component configuration makes the augmented examinations impractical to perform.
As stated by the licensee, a substantial portion (50X) of each weld was examined.
In addition, the NUREG-0313 welds are part of a much larger examination sample.of welds that are being completely examined.
Further assurance of the structural integrity is provided by 'the fact that as part of the feedwater and reactor recirculation systems, these welds receive the Code-required pressure tests with the remainder of the Class 1, 2, and 3.pressure-retaining piping.
Therefore, reasonable assurance of structural integrity has been provided, and it is recommended that this request be approved.
The examinations performed on the subject welds, along with the Code-required pressure examinations and the complete examination of other, similar welds, provide adequate assurance of continued structural integrity.
For welds included in previous submittals and addressed in the April 13, 1995 safety evaluation, relief should remains approved.
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Re uest for Relief Nos.
1 R-23 Unit 1
and 2RR-20 Unit 2 Examination Cate or 8-0 Item B14. 10 Control Rod Drive CRD Housin Welds Code Re ui ement:
Table IWB-2500-1, Examination Category 8-0, Item 814. 10 requires a surface or volumetric examination as defined by Figure IWB-2500-18 for welds in 10X of the peripheral CRD housings.
Licensee's Code Relief Re uest:
Relief is requested from performing the Code-required examination of the CRD housing-to-flange welds due to plant design access restrictions.
icensee's Basis for Re uestin Relief (as stated):
"Relief is requested from examination (surface or volumetric) of the CRD housing-to-flange welds due to numerous plant design obstructions.
The CRD position indicator probes, CRD shoot out steel, and CRD flange shields severely limit access to the housing-to-flange welds.
In addition, high radiation doses in this area make it impractical to attempt to perform limited examinations in the face of these obstacles.
The remaining housing weld is without obstruction and can be completely examined.
Examination of the unobstructed housing welds (tube A-to-tube B) provides reasonable assurance of the structural integrity of the CRD housing welds.
"The CRD housing welds are within the system pressure retaining boundary of Examination Category B-P.
As such, reasonable assurance of the pressure retaining integrity of the flange-to-housing welds is gained through periodic VT-2 visual examination during Class 1 system pressure testing."
Licensee's Pro osed Alte native Examination (as stated):
"No alternate provisions are proposed for the subject examinations."
Evaluation:
The CRD housings at Susquehanna Units 1 and 2 each have.two pressure-retaining welds:
the housing-to-flange weld and the housing-tube-A-to-housing-tube-B weld.
The Code requires a surface or volumetric examination of the pressure-retaining welds in 10X of the peripheral CRD housings.
However, the licensee contends that examination of the housing-to-flange weld is impractical due to numerous physical obstructions that limit access and to high radiation doses associated with this area.
The INEL staff has reviewed the licensee's drawings and supporting information, and concurs with the licensee's determination that the Code-required examinations are impractical for the subject welds.
The lower housing-to-flange welds are located well below the tube-A-to-tube-B weld in an area with little access.
To gain access for examination, the CRD housings and surrounding obstructions would require design modifications.
Imposition of the Code requirements would cause a considerable burden on the licensee.
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-.12 The licensee has performed the Code-required examinations on the upper welds of the housing.
In addition, the CRD housings received periodic leakage tests with the balance of the Class 1, systems.
Therefore, any significant patterns of degradation should have been detected, and reasonable assurance of the operational'readiness has been provided.
Based on the impracticality of performing the Code-required examinations on the subject CRD welds, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
The examinations that were performed provide reasonable assurance of the structural integrity of the CRD housing welds.
I.
e uest for Re ief os.
1RR-2 Unit 1
and 2RR-21 Unit 2 Examination Cate or B-A tems
- 1. 11 and Bl. 12 Au mented Reactor Pressure Vessel RPV Examination emote:
Requests for Relief 1RR-24 (Unit 1) and 2RR-21 (Unit 2) were submitted in the January 9,
1996, letter as a result of the November 30,
- 1995, conference call. 'However, the NRC staff has determined that the licensee's proposed alternative to the augmented volumetric examination specified in 10 CFR 50.55a(g)(6)(ii)(A) should be addressed as a stand alone issue.
Therefore, Requests for Relief Nos.
1RR-24 and 2RR-21 will be evaluated in a subsequent report.
3.
~NL t
The INEL staff has reviewed the licensee's submittal and concludes that the requirements of the Code are impractical and that relief should be granted or should remain granted, pursuant to 10 CFR 50.55a(g)(6)(i), for Requests for Relief 1RR-12, 1RR-15, 1RR-17, 1RR-23, 2RR-13, 2RR-14, 2RR-15, and 2RR-20.
Such relief is authorized by law and will not endanger life, property, or the common defense and Ncurity, and is otherwise in the public interest.
The relief has been granted giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
For Requests for Relief 1RR-19 and 2RR-16, it is recommended that relief 'from the subject augmented requirements be approved.
Requests for Relief 1RR-24 and 2RR-21 were not evaluated in this report.
The licensee's'roposed alternative to the augmented reactor vessel examination specified in 10 CFR 50.55a(g)(6)(ii)(A) will be evaluated in a subsequent report.
Requests for Relief 1RR-3, 1RR-10, 1RR-21, 1RR-18, 2RR-3, 2RR-8, and 2RR-18 have been withdrawn in a letter dated June 1,
- 1995, as a result of the November 30,
- 1995, conference call.
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