ML17353A400
| ML17353A400 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/10/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17353A399 | List: |
| References | |
| NUDOCS 9510160131 | |
| Download: ML17353A400 (30) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&0001 ENCLOSURE 1
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE SECOND TEN YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN RE UESTS FOR RELIEF FOR FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNITS 3 AND 4 DOCKET NUMBERS:
50-250 AND 251
1.0 INTRODUCTION
The Technical Specifications for Turkey Point, Units 3 and 4 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).
10 CFR 50.55a(a)(3) states that alternatives (g) may be used, when authorized by the
- NRC, would provide an acceptable level of quality with the specified requirements would result difficulties without a compensating increase safety.
to the requirements of paragraph if (i) the proposed alternatives and safety or (ii) compliance in hardship or unusual in the level. of quality and Pursuant to 10 CFR 50.55a(g)(4),
ASME 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 ten-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 ASME Code for the Turkey Point, Units 3 and 4 second 10-year inservice inspection (ISI) interval is the 1980 Edition through Winter 1981 Addenda.
The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASHE Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Commission approval.
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Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME 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 of 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 consideration to the burden upon the licensee that could result if the requirements were imposed.
In letters dated February 20, 1995 and April 6, 1995, Florida Power and Light Company submitted to the NRC its second ten-year interval inservice inspection program plan, requests for relief for the Turkey Point, Units 3 and 4.
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 second ten-year interval inservice inspection program plan, requests for relief for the Turkey Point, Units 3 and 4.
Based on the information submitted, the staff adopts the contractor's conclusions and recommendations presented in the Technical Letter Report attached.
The staff concludes that for the licensee's Part "A" requests for relief the Code requirements are impractical.
Therefore, considering the burden on the licensee that would result if the'requirements were
- imposed, relief is granted for the Part "A" requests for relief pursuant to 10 CFR 50.55a(g)(6)(i).
The staff concludes that the alternative contained in Part "B" provides an acceptable level of quality and safety and, therefore, the licensee's proposed alternative to the selection of high stress Class 1 piping welds is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
TECHNICAL LETTER REPORT ON THE SECOND 10-YEAR INSERVICE INSPECTION INTERVAL END 0 INTERVAL RE UESTS FOR RELIEF FOR TURKEY POINT UNITS 3 AND 4 FLORIDA POWER AND LIGHT CONPANY DOCKET NUMBERS:
50-250 AND 50-251 ENCLOSURE 2
- 1. 0 INTRODUCTION By letters dated February 20, 1995 and April 6, 1995, Florida Power and Light Company submitted requests for relief for Turkey Point, Units 3 and 4.
The requests for relief address examination areas where the Code-required coverage was not obtained for the second 10-year interval.
In addition, the licensee submitted a request for relief regarding selection of Class 1 high stress piping welds required by Examination Category B-J, Note 1(b).
The Idaho National Engineering Laboratory (INEL) staff has evaluated the subject requests for relief in the following section.
- 2. 0 EVALUATION The Code of record for the Turkey Point, Units 3 and 4, second 10-year inservice inspection interval, which began February 22, 1984 and ended February 21, 1994, for Unit 3 and began April 15,
- 1984, and ended April 14, 1994, for Unit 4, is the 1980 Edition through the Winter 1981 Addenda of the American Society of Hechanical Engineers (ASHE) Boiler and Pressure Vessel Code, Section Xl..The information provided by the licensee in support of the requests for relief from Code requirements has been evaluated and the bases for disposition are documented below.
The licensee submitted requests for relief for Turkey Point, Units 3 and Unit 4, for instances where Code examination coverage requirements were not satisfied by inservice inspections performed during the second 10-year interval.
These submittals include requests for relief from examination requirements of the ASHE Code,Section XI, for Class 1 and 2
component and pipe examination areas.
The relief requests address
Examination Categories B-D, B-F, B-J, C-A, C-C, and C-F.
A common "Basis for Relief" and "Alternative Examination" was developed by the licens'ee for all examination areas that are part of these relief requests.
- However, these requests were evaluated by Examination Category.
Al.
Unit 3 Re uest for Relief Examination Cate or 8-D Items B3. 120 and B3. 140 Pressurizer and Steam Generator Nozzle Inner Radius Sections Code Re uirement:
Table IWB-2500-1, Examination Category B-D, Items B3. 120 and B3. 140 require 100X volumetric examination of Class 1 pressurizer and steam generator nozzle inner radius sections as defined by Figure IWB-2500-7 (a) through (d),
as applicable.
Licensee's Code Relief Re uest:
The licensee requested relief from the Code-required 100X volumetric examination coverage for the nozzle inner radius sections listed below.
Com onent ID Percentage of Code Covera e Obtained Examination Coverage Limited 8 3-SGB-I-IRS 3-SGB IRS 70X 70X Welded-on pads,
- support, and configuration Welded-on
- pads, support, and configuration 3-SRGN IR 3-SGA-I-IRS 3-SGA IRS SP-03-I-IR 70X 55X Heater penetrations 70X Welded-on pads,
- support, and configuration Welded-on
- pads, support, and configuration 70X from 2 directions, Configuration of Spray 15X from one direction Nozzle Inner Radius RV-03-551C-IR RN-03-1-IR 40X 40X Interference from insulation ring Interference from insulation ring
Com onent ID Percentage of Code Examination Coverage Covera e Obtained Limited B
3-SGC-I-IRS 3-SGC-0-IRS 70X 70X Welded-on
- pads, support, and configuration Welded-on
- pads, support, and configuration Licensee's Basis for Re uestin Relief (as stated):
"Several welds examined during the second ISI interval did not receive the required volumetric and/or surface examinations due to one or more factors:
1.
Portions of the required volumetric and surface area obstr uctions.
2.
Some welds could be examined from only one side due to the configuration of the. component, high attenuation of the ultrasonic
- sound, or other technical reasons.
"FPL performed the examinations to the extent possible.
The surfac'e and volumetric examinations along with the required system pressure tests provide assurance of an acceptable level of quality and safety.
The attached table summarizes the percent of coverage achieved and references specific figures that show the extent of the limitations."
Licensee's Pro osed Alternative Examination (as stated):
"l.
Volumetric and surface examinations were performed to the extent possible.
2.
System pressure tests as required by the Turkey Point Inservice Pressure Test Program were performed.
3.
As part of the development of the system engineer program during the second interval, monthly walkdowns were initiated on Class 2 systems to check for leakage or other problems.
During
- outages, system engineers walk down Class I and Class 2 systems inside containment.
4.
During the third interval, FPL will consider substituting other welds in order to further reduce the number of components with limitations.
Substitutions will generally be in the immediate vicinity and of the same configuration, to the extent practical.
The examination volume achieved by surface and/or ultrasonic examination, combined with the system pressure tests and system
engineer walkdowns, provide an acceptable level of quality and safety.
If permanent obstructions are removed for other
- reasons, FPL will examine those areas that become accessible to the extent possible."
Evaluation:
The Code requires that 100X of the subject nozzle inner radius sections be volumetrically examined during the inspection interval.
Based on a review of the sketches'nd information provided, it has been determined that complete Code examination coverage of the subject examination areas is impractical due to the location of permanent insulation tabs, nozzle outside surface configuration, raised letters, heater penetrations,
- geometry, and supports.
To obtain complete volumetric coverage, design modifications would be required resulting in a considerable burden on the licensee.
The licensee performed the examinations to the extent practical, resulting in coverages of the subject inner radius sections from 40X to 70X.
Based on the percentage of coverage obtained, it can be concluded that significant degradation, if present, would have been detected.
As a result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
A2.
Unit 3 Re uest for Relief Examination Cate or B-F Items B5. 10 B5.30 and B5.70 Reactor Pressure Vessel Nozzle-to-Safe End Welds and Steam Generator Nozzle-to-Safe End Welds Code Re uirement:
Table IWB-2500-1, Examination Category B-F, Items B5. 10, B5.30, and B5.70 require 100X volumetric and surface examination of nozzle-to-safe end welds as defined by Figure IWB-2500-1.
'Sketches provided by the licensee are not included with this evaluation.
Licensee's Code Relief Re uest:
Relief is requested from the Code-required 100X volumetric examination of the following Class 1 nozzle-to-safe end welds:
Component ID
& Descri tio Percent of Code Coverage Obtained Examination Covera e Limited B
29"-RCS-1305-4 Nozzle-to-elbow 31"-RCS-1301-5 Nozzle-to-elbow 31"-RCS-1302-5 Nozzle-to-elbow 29"-RCS-1304-4 Elbow-to-nozzle 4"-RC-1301-1A Nozzle-to-safe-end 43X from elbow side, 2X from nozzle side 75X from elbow side, OX from nozzle side 75X from elbow side, OX from nozzle side 100X from elbow side, OX from nozzle side 50X 4"-RC-1306-1A 50X Nozzle-to-safe-end:
31"-RCS-1303-5 Nozzle-to-elbow 75X from elbow side, OX from nozzle side 29"-RCS-1308-4 100X from elbow side, Elbow-to-nozzle OX from nozzle side Weld crown and joint configuration Weld crown and joint configuration Weld crown and. joint configuration Weld crown and joint configuration Weld crown from adjacent weld and joint configuration Weld crown from adjacent weld and joint configuration Joint configuration and weld crown Joint configuration and weld crown Licensee's Basis for Re uestin Relief:
(See Part Al above.)
Licensee's Pro osed Alternative Examination:
(See Part Al above.)
Evaluation:
The Code requires that the subject nozzle-to-safe end welds receive 100X volumetric and surface examinations.
- However, based on a review of the sketches provided, it has been determined that complete volumetric Code coverage is impractical due to the nozzle-to-safe end configuration.
To obtain complete volumetric coverage, design modifications or replacement of the nozzle-to-safe end with one of a design Sketches provided by the licensee are not included with this evaluation.
providing for complete coverage would be required.
The licensee performed the volumetric examinations to the extent practical.
Based on the percent of volumetric coverage
- obtained, in combination with the Code-required surface examinations, it can be concluded that significant degradation, if present, would have been detected.
As a result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
A3.
Unit 3 Re uest for Relief Examination Cate or B-J Item B9. 11 Circumferential Pi e Welds Code Re uirement:
Table IWB-2500-1, Examination Category B-J, Item B9. 11 requires 100X volumetric and surface examination of Class 1 pressure-retaining piping circumferential welds as defined by Figure IWB-2500-8.
Licensee's Code Relief Re uest:
Relief is volumetric or surface examination, as appli Class 1 examination areas:
requested from 100X cable, for the following Component ID 8 Descri tion 31"-RCS-1302-8 Pipe-to-elbow 29"-RCS-1305-3 Pipe-to-elbow 2"-SI-1305-4 27.5"-RCS-1307-11 Pump casing-to-pipe 27.5"-RCS-1306-11 Pump casing to pipe Percent of Code Covera e Obtained 100X from pipe side, 82X from elbow side 93X from pipe side, 69X from elbow side 87X Surface 55X from pipe side, OX from pump side 100X from pipe side, OX from pump side Examination Covera e Limited B
Volumetric coverage limited by elbow configuration Volumetric coverage limited by branch connection and elbow configuration Surface coverage limited by component support Volumetric coverage limited by joint configuration and weld crown Volumetric coverage limited by joint configuration and weld crown
Component ID 8 Descri tion 12"-RC-1301-1 Branch connection-to-pipe 14 "-RHR-1301-6 Pipe-to-valve 8"-RHR-1301-3 Elbow-to-valve 10"-SI-1302-1 Elbow-to-branch connection Percent of Code Covera e Obtained 100X from pipe side, OX from nozzle side 100X from pipe side, OX from valve side 100X from elbow side, OX from valve side 100X from elbow side, OX from branch side Examination Covera e Limited B
Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration 8"-RHR-1302-1 Valve-to-pipe 10"-SI-1303-11 Elbow-to-valve 31"-RCS-1301-10 Elbow-to-pump 31"-RCS-1302-10 Elbow-to-pump 4"-RC-1304-18 Elbow-to-tee 100X from pipe side, OX from valve side 100X from elbow side, OX from valve side 75X from elbow side, OX from pump side 75X from elbow side, OX from pump side 70X Volumetric coverage joint configuration Volumetric coverage joint configuration Volumetric coverage joint configuration Volumetric coverage joint configuration Volumetric coverage elbow configuration radius area limited by limited by l,imited by limited by limited by and tee inner 4"-RC-1305-19 Pipe-to-tee 4"-RC-1306-7 Tee-to-reducer 8"-RHR-1301-1 Tee-to-elbow 10"-SI-1302-4 Elbow-to-valve 100X from pipe side, 60X from tee side 100X from reducer
- side, 65X from tee 100X from elbow side, 31X from tee side 85X from elbow side, 25X from valve side Volumetric coverage limited by tee inner radius Volumetric coverage limited by branch tee interference Volumetric coverage limited by tee inner radius Volumetric coverage limited by joint configuration Licensee's Basis for Re uestin Relief:
(See Part Al above.)
Licensee's Pro osed Alternative Examination:
(See Part Al above.)
Evaluation:
The Code requires that the subject Class 1 piping welds receive 100X volumetric and surface examination.
Based
on a review of the sketches provided depicting typical examination area configurations, it has been determined that complete Code coverage is impractical due to joint configurations, weld crowns, and interferences.
To obtain complete Code-required
- coverage, design modifications and/or replacement of components would be required, resulting in a
considerable burden on the licensee.
The licensee performed the volumetric and surface examinations to the extent practical.
Based on the percent of coverage obtained, it can be concluded that significant degradation, if present, would have been detected.
As a result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
A4.
Unit 3 Re uest for elief xamination Cate or C-A Item C1.10 Head-to-Shell Weld and Item C1.20 Flan e-to-Shell Weld Residual Heat Removal Heat Exchan er Code Re uirement:
Table IWC-2500-1, Examination Category C-A, Item Cl. 10 requires 100X volumetric examination of Class 2
vessel shell circumferential welds as defined by Figure IWC-2500-1.
Item Cl.20 requires 100X volumetric examination of each head circumferential weld as defined by Figure IWC-2500-1.
Licensee's Code Relief Re uest:
The licensee requested relief from the Code-required examination area coverage of Residual Heat Removal Heat Exchanger shell-to-flange Weld 3-RHE-A2 and shell-to-head Weld 3-RHE-A1.
Sketches provided by the licensee are not included with this evaluation.
Licensee's 8 sis for Re uestin Relief:
(See Part Al above.)
Licensee's Pro osed Alternative Examination:
(See Part Al above.)
Evaluation:
The Code requires that 100X of each circumferential shell weld be volumetrically examined.
Based on a review of the sketches provided depicting the typical weld and flange configuration, it has been determined that complete volumetric coverage is impractical due to the joint configuration.
To obtain complete volumetric coverage, design modifications or replacement of the component with a design providing for complete coverage would be required.
Imposition of this requirement would cause a considerable burden on the licensee.
The licensee performed the volumetric examinations to the extent practical.
Greater than 50X volumetric coverage of the head-to-shell weld and 40X volumetric coverage of the shell-to-flange weld was obtained.
Based on the percent of coverage obtained, it can be concluded that significant degradation,. if present, would have been detected.
As a result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
A5.
Unit 3 Re uest for Relief Examination Cate or C-C It m C3. 10 Inte rail Welded Attachments to the Residual Heat Removal Heat xchan er Code Re uirement:
Table IWC-2500-1, Examination Category C-C, Item C3. 10 requires 100X surface examination of all integrally welded attachments on one of multiple vessels as defined by Figure IWC-2500-5.
Sketches provided by the licensee are not included with this evaluation.
10 Licensee's Code Relief Re uest:
The licensee requested relief from the Code-required surface examination area coverage of Residual Heat Removal Heat Exchanger integrally welded attachment Welds 3-RHE-SPA-1 and 3-RHE-SPA-2.
Licensee's Basis for Re uestin Relief:
(See Part Al above.)
Licensee's Pro osed Alternative Examination:
(See Part Al above.)
Evaluation:
The Code requires 100X surface examination of the subject Residual Heat Removal Heat Exchanger integrally welded attachment welds.
- However, due to permanent support structure interference, no examination can be performed on the bottom side of the integral attachments.
To perform a complete surface examination, design modifications would be required.
Imposition of this requirement would cause a considerable burden on the licensee.
It appears that the licensee obtained greater than 50X coverage of the examination area.
Based on the percent of coverage obtained, it can be concluded that significant degradation, if present, would have been detected.
As a result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
A6.
Unit 3 Re uest for Relief Examination Cate or C-F Item C5.21 Class 2 Pi in Welds Code Re uirement:
Table IWC-2500-1, Examination Category C-F, Items C5.11 and C5.21 require 100X volumetric and surface examination of Class 2 circumferential butt welds as defined by Figure IWC-2500-7.
Licensee's Code Relief Re uest:
The licensee requested relief from the Code-required 100X volumetric and surface examination, as applicable, for the following Class 2 pipe welds:
11 Component ID 8 Descri tion Percent of Code Covera e Obtained Examination Covera e Limited B
26"-MSB-2305-15 85X surface 6"-BDA-2301-2 Pipe-to-valve 6"-BDA-2301-8 Tee-to-pipe 100X from pipe side, 50X from valve side 100X from pipe side, 50X from tee side 10"-SI-2304-3 Valve-to-pipe 8"-SI-2310-24 Pipe-to-valve 10"-SI-2302-5 Valve-to-pipe 10"-SI-2302-6 Pipe-to-valve 10"-SI-2305-3 Valve-to-pipe 10"-SI-2305-8 Elbow-to-valve 10"-SI-2304-2 Elbow-to-valve 10"-SI-2304-3 Valve-to-pipe 8"-SI-2303-1 Reducer-to-pipe 6"-BDB-2302-1 Reducer-to-valve 100X from pipe side, OX from valve side 100X from pipe side, 50X from valve side 100X from pipe, OX from valve side 100X from pipe, OX from valve 100X from pipe, OX from valve 100X from elbow side, OX from valve side 100X from elbow side, OX from valve side 100X from pipe side, OX from valve side 100X form pipe side, OX from reducer side 75X from reducer side, 70X from valve side 6"-BDA-2304-26 74X surface Surface coverage limited due to weld proximity to floor Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Surface coverage limited due to weld proximity to floor Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration 6"-FWB-2302-3 Valve-to-pipe 6"-BDC-2303-1 Reducer-to-valve 6"-BDC-2303-5 Reducer-to-valve 50X surface coverage in one direction only parallel to weld for axial flaws only 85X from reducer side, 72X from valve side 72X from reducer side, 66X from valve side Surface coverage limited by a double acting restraint Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration
12 Licensee's Basis for Re uestin Relief:
(See Part Al above.)
Licensee's Pro osed Alternative Examination:
(See Part Al above.)
Evaluation:
The Code requires that the subject piping welds receive 100X volumetric and surface examination.
Based on a
review of sketches provided depicting-typical examination area joint configurations and interferences, it has been determined that complete volumetric Code coverage is impractical due to the subject examination area joint configurations and interferences.
To obtain complete coverage, design modifications and/or replacement of the component with one of a design providing for complete coverage would be required.
Imposition of this requirement would cause a
considerable burden on the licensee.
The licensee performed the volumetric and surface examinations to the extent practical.
Based on the percent of coverage obtained, it can be concluded that significant degradation, if present, would have been detected.
As a result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
A7.
Unit 4 Re uest for Relief Examination Cate or B-D Items B3. 120 and B3. 140 Pressurizer and Steam Generator Nozzle Inner Radius Sections Code Re uirement:
Table IWB-2500-1, Examination Category B-D, Items B3.120 and B3.140 require 100X volumetric examination of Class 1 pressurizer and steam generator nozzle inner radius sections as defined by Figure IWB-2500-7 (a) through (d) as applicable.
'Sketches provided by the licensee are not included with this evaluation.
13 Licensee's Code Relief Re uest:
The licensee requested relief from the Code-required 100X volumetric examination coverage for the subject nozzle inner radius sections listed below.
Component ID L Descri tion 4-SGA-I-IRS, Steam Generator Nozzle Inner Radius Section 4-SGA-O-IRS, Steam Generator, Nozzle Inner Radius Section Percentage of Code Coverage Obtained 70X 70X Examination Covera e Limited B
Vessel
- support, insulation
- tabs, outside configuration Vessel
- support, insulation
- tabs, outside configuration SP-04-I-IR, 70X in 2 Raised letters, nozzle Pressurizer Nozzle directions, 15X configuration, spray nozzle Inner Radius Section from 1 direction inner radius RV-4-551-A-IR, Pressurizer Nozzle Inner Radius Section V-4-5551-C-IR, Pressurizer Nozzle Inner Radius Section 4-SRGN IR, Pressurizer Nozzle Inner Radius Section 4-SGB-I-IR, Steam Generator Nozzle Inner Radius Section 4-SGB-O-IR, Steam Generator Nozzle Inner Radius Section 4-SGC-I-IRS, Steam Generator Nozzle Inner Radius Section 4-SGC-O-IRS, Steam Generator Nozzle Inner Radius Section 85X 85X 55X 70X 70X 70X 70X Insulation on bottom Insulation on bottom Heater penetrations Welded pads, supports Welded pads, supports Vessel
- support, insulation
- tabs, outside configuration Vessel
- support, insulation
- tabs, outside configuration Licensee's Basis for Re uestin Relief:
(See Part Al above.)
Licensee's Pro osed Alternative Examination:
(See Part Al above.)
14 Evaluation:
The Code requires that the subject Class 1 nozzle inner radius sections be 100X volumetrically examined during the inspection interval.
Based on a review of the sketches and supporting information pr'ovided, it has been determined that complete coverage of the subject examination areas is impractical due to the location of permanent insulation tabs, nozzle outside surface configuration, raised letters, heater penetrations,
- geometry, and supports.
To obtain complete volumetric coverage, modification of the permanent insulation support design would be required, resulting in a considerable burden on the licensee.
The licensee performed the examinations to the extent practical, resulting in coverages from 55 to 85X.
Based on the percentage of coverage obtained, it can be concluded that significant degradation; if present, would have been detected.
As a result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
A8.
Unit 4 Re uest for Relief Examination Cate or B-F Items 85. 10 B5.30 and 85.70 Reactor Pressure Vessel Nozzle-to-Safe Ends and Steam Generator Nozzle-to-Safe Ends Code Re uirement:
Table IWB-2500-1, Examination Category B-F, Item B5. 10, B5.30, and 85.70 require a
100X volumetric and surface examination of nozzle-to-safe end welds as defined by Figure IWB-2500-1.
Licensee's Code Relief Re uest:
Relief is requested from performing the complete Code-required 100X volumetric examination of the following Class 1 nozzle-to-safe end welds:
Sketches provided by the licensee are not included with this evaluation.
15 Component 10
& Descri tion Percent of Code Covera e Obtained Examination Covera e Limited B
31"-RCS-1401-5 OX from nozzle side, Joint Configuration Nozzle-to-elbow 75X from elbow side 4"-RC-1404-31 50X from nozzle side, Joint configuration and Safe end-to-nozzle 50X from safe-end side adjacent weld crown 29"-RCS-1404-4 Elbow-to-nozzle 31"-RCS-1402-5 Nozzle-to-elbow 29"-RCS-1405-4 Elbow-to-elbo'w 31"-RCS-1403-5 Nozzle-to-elbow 29"-RCS-1408-4 Elbow-to-nozzle 100X from elbow side, OX from nozzle side 75X from elbow side, OX from nozzle side 100X from elbow side, OX from nozzle side 75X from elbow side, OX from nozzle side 94X from elbow side, OX from nozzle side Joint configuration Joint configuration Joint configuration Joint configuration Joint configuration Licensee's Basis for Re uestin Relief'.
(See Part Al above.)
Licensee's Pro osed Alternative Examination:
(See Part Al above.)
Evaluation:
The Code requires that the subject nozzle-to-safe end welds receive 100X volumetric and surface examination.
Based on a review of the sketches depicting the typical examination area, it has been determined that complete volumetric Code coverage is impractical'ue to joint configurations and interfering adjacent welds.
To obtain complete volumetric coverage, design modifications or replacement of the nozzle-to-safe ends with ones of a design providing for complete coverage would be required.
The licensee performed the volumetric examinations to the extent practical.
Based on the percent of volumetric coverage, in combination with the Code-required surface examinations, it can be concluded that significant degradation, if present, would have been
16 detected.
As a result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
A9.
Unit 4 Re uest for Relief Examination Cate or B-J Item B9. 11 Circumferential Pi e Welds Code Re uirement:
Table IWB-2500-1, Examination Category B-J, Item B9. 11 requires 100X volumetric and surface examination. of Class 1 pressure-retaining piping circumferential welds as defined by Figure IWB-2500-8.
Licensee's Code Relief Re uest:
Relief is requested from 100X volumetric and surface examination, as applicable, for the following examination areas:
Component ID
& Descri tion 27.5"-RCS-1409-11 Reactor coolant pump casing-to-pipe 12"-RC-1401-4 Pipe-to-pipe 4"-RC-1401-9 Pipe-to-flange 14"-RHR-1401-5 Pipe-to-valve 8"-RHR-1401-6 Valve-to-elbow 8"-RHR-1402-7 Tee-to-Reducing Tee 10"-SI-1402-1 Valve-to-elbow Percent of Code Covera e Obtained 100X from pipe side, OX from pump side 88X surface 100X from pipe side, 50X from flange side 100X from pipe side, OX from valve side 100X from elbow side, 50X from valve side 70X from tee side, 31X from reducing tee side 100X from elbow side, OX from valve side Examination Covera e Limited B
Volumetric coverage limited by joint configuration Surface coverage limited by support interference Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration
17 Component ID
& Descri tion 10"-SI-1403-14 Valve-to-elbow 31"-RCS-1402-10 Elbow-to-reactor coolant pump casing 4"-RC-1406-8 Tee-to-pipe 14"-RHR-1401-6 Valve-to-pipe 14"-RHR-1401-16 Pipe-to-valve 10"-SI-14-1401-14 pipe-to-valve 10"-SI-1402-13 Valve-to-pipe 10"-SI-1403-1 Valve-to-tee Percent of Code Covera e Obtained 100X from elbow side, OX from valve side 75X from elbow side, OX from pump side 79X 100X from pipe side, OX from valve side 100X from pipe side, OX from valve side 100X from pipe side, OX from valve side 100X from elbow side, OX from valve side 75X from tee side, OX from valve side Examination Covera e Limited B
Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetri c coverage limited due to-tee inner radius area Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited due to tee radius area Licensee's Basis for Re uestin Relief:
(See Part Al above.)
Licensee's Pro osed Alternative Examination:
(See Part Al above.)
Evaluation:
The Code requires that the subject Class 1 piping welds receive 100X volumetric and surface examination.
Based on a review of sketches provided depicting typical examination area configurations, it has been determined that the component configurations or interferences preclude complete "Sketches provided by the licensee are not included with the evaluation.
18 examination.
To perform the complete Code-required examination, designs providing for complete coverage would be required.
Imposition of this requirement would cause a
considerable burden on the licensee.
The licensee performed the volumetric and surface examinations, as applicable, to the extent practical.
Based on the percent of coverage obtained, it can be concluded that significant degradation, if present, would have been detected.
As a result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
A10. Unit 4 Re uest for Relief Examination Cate or C-A Item Cl. 10 Residual Heat Removal Heat Exchan er Head-to-Shell Weld Code Re uirement:
Table IWC-2500-1, Examination Category C-A, Item Cl. 10 requires 100X volumetric examination of each Class 2
circumferential head weld as defined by Figure IWC-2500-1.
Licensee's Code Relief Re uest:
The licensee requested relief from the Code-required coverage of the Residual Heat Removal Heat Exchanger head-to-shell Weld 4-RHE-A1.
Licensee's Basis for Re uestin Relief:
(See Part Al above.)
Licensee's Pro osed Alternative Examination:
(See Part Al above.)
Evaluation:
The Code requires that 100X of each circumferential shell weld be volumetrically examined.
19
- However, based on a review of sketches provided, it has been determined that complete volumetric coverage is impractical due to the head and shell configuration.
To obtain complete volumetric coverage, design modifications or replacement of the components with those of a design providing for complete coverage would be required.
Imposition of this requirement would cause a considerable burden on the licensee.
The licensee performed the volumetric examinations to the extent practical, obtaining approximately 50X coverage of the Code-required examination volume.
Based on the percent of coverage obtained, it can be concluded that significant degradation, if present, would have been detected.
As a result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
All. Unit 4 Re uest for Relief Examinatio Cate or C-F Item 5.21 Class 2 Circumferential Pi in Welds Code Re uirement:
Table IWC-2500-1, Examination Category C-F, Item C5.21 requires 100X volumetric and surface examination of Class 2 circumferential butt welds as defined by Figure IWC-2500-7.
Licensee's Code Relief Re uest:
The licensee requested relief from the Code-required 100X volumetric and surface examination, as applicable, for the following Class 2 pipe welds:
Sketches provided by the licensee are not included with the evaluation.
20 Component ID 8 Descri tion Percent of Code Covera e Obtained Examination Covera e Limited B
6"-BDA-2401-6 Reducer-to-valve 85X from reducer side, 70X from valve side 14"-RHR-2406-10 68X surface Elbow-to-pipe Volumetric coverage limited by joint configuration Surface coverage limited by 4 welded pads close to the weld 10"-SI-2401-lA Nozzle-to-pipe.
10"-SI-2401-6 Pipe-to-valve 10"-SI-2403-1A Nozzle-to-pipe 10"-SI-2403-4 Elbow-to-valve 10"-SI-2407-4 Pipe-to-valve 10"-SI-2407-5 Valve-to-elbow 8"-SI-2402-18 Pipe to valve 8"-SI-2407-8 Tee-to-pipe 8"-SI-2407-22 Pipe-to-valve 12"-HSA-2401-2 Tee-to-flange 12"-HSB-2403-4 Tee-to-flange 6"-BDB-2402-1 Reducer-to-valve 100X from pipe side, OX from nozzle side 100X from pipe side, OX from valve side 100X from pipe side, OX from nozzle side 85X from elbow side, OX from valve side 100X from pipe side, OX from valve side'00X from elbow side, OX from valve side 100X from pipe side, 50X from valve side 100X from pipe side, 50X from tee side 100X from pipe side, 50X from valve side 85X surface coverage 78X surface coverage 76X from reducer side 69X from valve side Volumetr ic coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by branch connection interference Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited due to tee radius area Volumetric coverage limited by joint configuration Surface coverage limited by flange nuts Surface coverage limited by flange nut and restraint Volumetric coverage limited by joint configuration
21 Component ID 8 Descri tio 6"-BDA-2404-45 Valve-to-pipe 6"-BDB-2405-42B Valve-to-pipe 10"-SI-2402-1A Nozzle-to-pipe 8"-SI-2403-1 Tee-to-pipe 8"-SI-2403-17 Pipe-to-valve 8"-SI-2408-16 Valve-to-elbow Percent of Code Covera e Obtained 100X from pipe side, 50X from valve side 100X from pipe side, 50X from valve side 72X from pipe side, OX from nozzle side 58X from pipe side, ON from tee side 58X from pipe side, OX from valve side 40X from elbow side, OX from valve side Examination Covera e Limited B
Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Volumetric coverage limited by joint configuration Licensee's Basis for Re uestin Relief:
(See Part Al above.)
Licensee's Pro osed Alternative Examination:
(See Part Al above.)
Evaluation:
The Code requires that the subject piping welds receive 100X volumetric and surface examination.
Based on a
review of the sketches provided depicting typical joint configurations, it has been determined that complete examination is impractical because of the joint configurations or interferences.
To obtain complete coverage, design modifications and/or replacement of the component with one of a design providing for. complete examination would be required.
Imposition of this requirement would cause a considerable burden on the licensee.
Sketches provided by the licensee are not included with this evaluation.
22 The licensee has performed the examinations to the extent practical.
Based on the percent of coverage obtained, it can be concluded that significant degradation, if present, would have been detected.
As a
- result, reasonable assurance of structural integrity has been provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
B.
Clarification on the Selection of Class 1 Piping Welds for Examination, Turkey Point Units 3 and 4
Code Re uirement:
Table IWB-2500-1, Examination Category B-J, Note (1)(b) for weld selection states:
"All terminal ends in each pipe or branch run connected to other components where the stress levels exceed either of the following limits under load associated with specific seismic events and operational conditions:
(1) primary plus secondary stress intensity range of 2.4S, for ferritic steel and austenitic steel (2) cumulative usage factor U of 0.4."
Licensee's Code Relief Re uest:
Relief is requested from the selection criteria of Category B-J, Note (1)(b).
Licensee's Basis for Re uestin Relief as stated "The ASHE Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1980 Edition with Addenda through Winter
- 1981, Inservice Inspection Program for the Second Ten-Year Interval, and the 1989 Edition for the third ten year interval, require examination of "high stress" welds in Class 1 piping as described in a footnote to Table IWB-2500-1, examination category B-J.
This examination selection criteria requires stress intensities and cumulative usage factors from an ASME Section III Class 1 type analysis.
"FPL's second ten year ISI Program submittal stated that an engineering evaluation had been initiated to determine which welds, if any, may be subject to examination due to the high stress criteria.
If any welds are identified, they would be incorporated into the plan.
The third ten year ISI Program submittal references the 1989 Edition of Section XI which still includes this selection criteria.
23 "Category B-J Note (l)(b) All terminal ends and joints in each pipe or branch run connected to other components where the stress levels exceed the following limits under loads associated with specific seismic events and operational conditions:
(1) primary plus secondary stress intensity range of 2.4Sm for ferritic and austenitic steel; (2) cumulative usage factor U of 0.4 "Because of the vintage of Turkey Point, ASME Section III Class 1
type analyses were not required nor performed for Class 1 systems.
Turkey Point was designed and analyzed in accordance with the rules of the 1955 Edition of Power Piping ASA B31.1.
The selection criteria specified in Table IWB-2500-1 for Category B-J cannot be used because the stress criteria specified in ASA B31. 1 is not compatible with ASME Section III, Class 1 analyses.
" In order to comply with the intent of ASHE Section XI for identification of "high stress"
- welds, FPL used the criteria specified in ASHE Section XI, 1980 addenda through Winter 1981, Table IWC-2500-1, Category C-F, note(1)(a).
These criteria were used because it is based on ASHE Section III Class 2 design rules which closely resemble ASA B31.1.
"This note states:
Welds at locations where the stresses under the loadings resulting from Normal and Upset plant conditions as calculated by the sum of Equations (9) and (10) in NC-3652 exceed 0.8(1.2sh
+ SA).
"The exception to this is the pressurizer surge line which was reanalyzed in accordance with ASHE Section III rules in response to NRC Bulletin No. 88-08 (Zones 3-016 and 4-016).
This criteria was used for the second ten year interval and will be used for the third.
"10CFR50.55a(g)(4) states "Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components (including supports) which are classified as ASME Code Class 1, 2, and 3 must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of editions of the ASHE Boiler and Pressure Vessel Code and Addenda that become effective subsequent to editions specified in paragraphs (g)(2) and (g)(3) of this section and that are incorporated by reference in paragraph (b) of this section, to the extent practical within the limitations of design, geometry and materials of construction of the components."
"Based on the difference in design philosophies of ASHE Section III Class 1 and ASA B31. 1, the required stress intensities and usage factors cannot be calculated unless a complete system reanalysis to an upgraded code is performed.
This cannot be reasonably done'
because current versions of ASHE Section III Class 1 would require additional design requirements associated with loading, load combinations, cycle counting, etc.
The substantial reanalysis/redesign effort required to perform Class 1 analyses would not be consistent with 10CFR50.55a(g)(4).
"Since there was no design requirement at the time of construction to perform Class 1 analyses, they are not available nor required.
Title 10 CFR 50.55a(g)(4) does not require FPL to perform these calculations for the sole purpose of identifying those Class 1 welds that would exceed the Category B-J stress criteria.
"FPL has examined the Class 1 welds on the pressurizer surge line (which were reanalyzed to the Class 1 criteria),
and Class 1 and 2
welds that exceeded the Class 2 criteria.
The Class 1 welds are scheduled for examination during the third interval."
Licensee's Pro osed Alternative Examination:
The licensee proposes to select pipe welds based on engineering judgement.
Welds selected will include all terminal ends of branch runs connected to vessels; and other components.
Additional welds will be selected based upon the established criteria in the 1989 Edition.
Evaluation:
Selection criteria of Note l(b) in Examination Category B-J require evaluation of primary plus secondary stress C
intensities and cumulative usage factors.
Turkey Point Units 3 and 4 were designed principally to the requirements of ASA B31. 1.0-1955, Power Piping, so the stress information is not available for weld selection.
The licensee's proposed alternative is to include all terminal ends of branch runs connected to vessels and other components.
Additional welds will be selected based upon the established criteria in the 1989 Edition.
This alternative is a conservative approach for the selection of welds potentially subjected to high stress levels.
Because the licensee's proposed alternative is a sound engineering approach to Class 1 weld selection that concentrates the examinations on those welds with potentially higher stress
- levels,
25 an acceptable level of quality and safety will be maintained.
Therefore, it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
- 3. 0 CONCLUSION The INEL staff has evaluated the requests for relief submitted at the end of the second interval for Turkey Point, Units 3 and 4.
Based on these evaluations, it is recommended that relief be granted pursuant to.
10 CFR 50.55a(g)(6)(i) for limited examinations addressed in evaluations Al through All.
For Part B, it is recommended that the licensee's proposed alternative to the selection of high stress Class 1 piping welds be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
S. t'