ML17354A359
| ML17354A359 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/04/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17354A357 | List: |
| References | |
| NUDOCS 9612090290 | |
| Download: ML17354A359 (25) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-0001 SA TY EVALUA ION BY THE OFFICE OF UC EAR REACTOR REGULATION E ATED I
D 0-Y R INT RV L EV SIO I INSE VICE TESTING ROGRA FLORIDA POWER AND LIGHT COMPANY TURKEY POINT NUCLEAR POWER PLANT UNITS 3 AND 4 DOCKET NUHBERS 50-250 AND 50-251
1.0 INTRODUCTION
The Technical Specifications for Turkey Point, Units 3 and 4 states that the inservice inspection of the American Society of Hechanical 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 been been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).
The 10 CFR 50.55a(a)(3) states 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 difficulties 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 pre-service 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) 12 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 the Turkey Point, Units 3 and 4 third 10-year inservice inspection (ISI) interval is the 1989 edition.
The Turkey Point, Unit 3, third 10-year interval began on February 23,
- 1994, and Turkey Point, Unit 4, third 10-year interval began on April 15, 1994.
96l2090290 96i204 PDR ADQCK 05000250 P
PDR ENCLOSURE 1
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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 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 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 a letter dated December 14, 1995, Florida Power and Light Company (licensee),
submitted to the NRC its Third 10-year Inservice Inspection Interval Requests for Relief Nos. 6, 14, 15, and 17 for Turkey Point, Units 3 and 4.
The licensee provided additional information in its letter dated August 8, 1996.
- 2. 0 EVALUATION 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 Third 10-year Inservice Inspection Interval Requests for Relief Nos.
6, 14, 15, and 17 for 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 (TLR) attached with the following exceptions.
Relief Request No.
6 was withdrawn by the licensee by letter dated November 13,
- 1996, and is therefore not authorized.
The staff has reviewed the licensee's Requests for Relief Nos.
14 and 15 from the third 10-year interval Code examination requirements for Turkey Point, Units 3 and 4 and determined that the Code examination requirements are impractical for the subject welds.
To perform the Code-required examinations, design modifications or component replacement with ones of a design that provides for complete volumetric examination would be required.
The examination coverage of the subject welds provides reasonable assurance of structural integrity of the welds.
Therefore, relief is granted, pursuant to 10 CFR 50.55a(g)(6)(i).
The staff has determined that for Request for Relief No.
17 the minimal burden associated with the examinations is insufficient to justify not examining the subject welds on the "A" Steam Generator and the licensee's proposed alternative contained in its relief is denied.
3.
CONCLUSIONS The staff concludes that, for the welds contained in Requests for Relief Nos
~
14 and 15, the Code examination requirements are impractical.
Based on the weld coverage obtainable, the surface examination of the subject welds, and the examination of similar welds, reasonable assurance of structural integrity is provided.
Therefore, relief is authorized pursuant to 10 CFR 50.55a(g)(6)(i) for Requests for Relief Nos.
14 and 15.
The Commission may grant such relief and may impose such requirements as it determines is authorized by law and will not endanger life or property or the common defense
l
and security, and is otherwise in the public interest.
In making its determination, the staff gave due consideration to the burden upon the licensee and facility that could result if the Code requirements were imposed on the facility.
For Request for Relief No.
17 the staff has concluded that the minimal burden associated with the examinations is insufficient to justify not examining the subject welds on the A" Steam Generator.
Therefore, the licensee's proposed alternative contained in its relief is denied.
Principal Contributor:
Tom McLellan ECGB/NRR Date:
I
CHNIC L L ER E 0 T ON THE THIRD 10-YEAR INSERVICE INSPECTION INTERVAL E UESTS FOR RELIEF 6 14 15 AND 17 TURKEY POINT UNITS 3 AND 4 FLORIDA POWER AND LIGHT COMPANY OC ET NUMBERS:
50-250 AND 50-251 1.0 0UC 0
By letter dated December 14, 1995, Florida Power and Light Company submitted Requests for Relief 6, 14, 15, and 17.
On March 10,
- 1996, a
conference call was held and additional information requested.
The licensee revised Requests for Relief 14 and 15, and provided the requested information in a letter dated August 8, 1996.
The Idaho National Engineering Laboratory (INEL) staff has evaluated the subject requests for relief in the following section.
2.0
~EV UATI N
The Code of record for the Turkey Point Units 3 and 4 third 10-year inservice inspection interval, which began February 23, 1994, for Unit 3 and April 15, 1994, for Unit 4, is the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel
- Code,Section XI, 1989 Edition.
The information provided by the licensee in support of the requests for relief has been evaluated and the bases for disposition are documented below.
A.
Re uests for Relief 6 Units 3
& 4 Authorization to Use Code Case'32 te ative Re u 'rements to e
l ceme t ocument ti u's and se v'ce Summar Re ort Pre aration and Subm'ssio as e uired b NA-4000 and NA-6000 Code Re irement:
IWA-6220 requires that the licensee prepare reports using NIS-1, Ow'ner's Report for Inservice Inspections, and NIS-2, oner's Report for Repair or Replacements; IWA-6230 requires that these reports be filed with the enforcement and regulatory authorities having ENCLOSURE 2
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4
(
jurisdiction at the plant site within 90 days of the completion of the inservice inspection conducted during each refueling outage.
icen ee's Cod Re Re est:
The licensee requested re1ief from Code-required repair and replacement and inservice summary report documentation and submission requirements.
c for e t Re ef (as stated):
"Code Case N-532, 'Alternative Requirements to Repair and Replacement Documentation Requirements and Inser vice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000,Section XI, Division I,'as approved for use by ASIDE on December 12, 1994.
This code case addresses alternative methods of documenting repairs, replacements, and inservice inspections.
"The alternative methods proposed by the code case include a revised version of the current NIS-I and NIS-2 form.
The new single page form serves as a certification record which documents conformance to Section XI requirements.
"The revised Form NIS-2A eliminates the need to list each individual item used in a replacement.
Instead, this information is to be documented within a separate Repair/Replacement Plan.
Upon completion of all required replacement activities, the Repair/Replacement Certification
- Records, Form NIS-2A, is presented to the Authorized Nuclear Inservice Inspector for acceptance.
Both the Plan and Form NIS-2A are maintained on file by the Owner.
An index or abstract used to track completed repair or replacement activities is later submitted as an attachment to the Owner's Activity Report, Form OAR-I.
"In addition to the revised NIS-2 Form, Code Case N-532 provides alternatives to the preparation and submittal of the inservice inspection summary report and Form NIS-I, currently prepared in accordance with the requirements of IWA-6220 and IWA-6310.
"These changes eliminate the need to document information on more than one record and the submittal of numerous NIS-2 reports."
icensee's Pro osed Alternative Examination (as stated):
r "As an alternative to the present requirements of IWA-6220 and IWA-6230, FPL proposes to follow the guidelines of Code Case N-532 as follows:
"I.
A Repair/Replacement Plan will be prepared prior to the start of repair or replacement activities.
Each Plan will describe the conditions and elements required by IWA-4130 and IWA-7130.
Each Plan shall be identified and tracked by a unique
N2 identification number, which could be a Plant Work Order (PWO)
- number, Construction Work Order (CWO) number, or other unique tracking number designated by the plant.
Upon completion of the repair or replacement activity, FPL will prepare a Repair/Replacement Certification Record, Form NIS-2A.
The form will be presented to the inspector for acceptance and be maintained on file.
II3 I14 After each refueling outage, FPL shall prepare an Owner's Activity Report
- Form, OAR-1, which lists applicable tests and examinations.
Test and Exam information will be maintained in an abstract. (or index) similar to Table 1.
The OAR-I will identify items with flaws or relevant conditions and a summary of the applicable evaluation.
This information shall be maintained in an abstract (or index) similar to Table 2.
II5 II6 II7 An Abstract (or index) similar to Table 3, which lists each Repair and Replacement Plan by its identification number, shall be maintained.
The index shall also indicate the inspection interval and period when the repair or replacement was completed.
At the end of each inspection period, a copy of the OAR-I and applicable attachments will be filed with the enforcement and regulatory authorities who have jurisdiction at the plant site, following the end of the inspection period.
Repair/Replacement Plans describing the repair or replacement activity and containing the essential information as described by IWA-4000 and IWA-7000, will be available for inspection at any time."
In the licensee' August 8,
- 1996, response the following information was provided:
'Recently FPL received approval to use Code Case N-416-1.
This Code Case requires that it be documented on NIS-2 forms when it is used.
FPL will instead document this Code Case within the Repair/Replacement plan."
Evalu t'on:
The Code requires the use of Form NIS-I, Owner's Report For Inservice Inspections, and Form NIS-2, Owner's Report for Repairs or Replacements, and submittal of the 90-day Summary Reports.
Alternatives contained in Code Case N-532 allow the licensee to submit these records in an abstract format on Form NIS-2A, Repair/Replacement Certification
- Record, and Form OAR-1, Owner's Activity Report, following the completion of an inspection period.
The requirements associated with documentation of inser vice examinations and repairs/replacements and the subsequent submittal of Forms NIS-1 and NIS-2 within 90 days allowing a refueling outage are administrative only. It is noted that repair and replacement documentation reviews and approvals by the Authorized Nuclear Inspector continue to be required by this Code Case and that the licensee is required to establish a Repair/Replacement Plan in accordance with IWA-6340 of the 1992 Edition of Section XI.
The licensee has implemented Inspection Program B of the Code.
Under this program, examination schedules are satisfied on a "per period" basis.
Considering the milestones associated with Inspection Program B,
submittal of the results of examinations and an abstract of repairs/replacements on a periodic basis is a reasonable alternative.
In addition, the INEL staff believes that the forms contained in Code Case N-532, which provide a summary of the status of repairs/replacements and a more detailed status of examinations by period and interval, are an improvement over report forms currently required by the Code.
For
- example, OAR-1 includes the status of examinations credited for the period'and percent credited to date for the interval, by Examination Category.
This type of information provides the regulatory authorities a
more comprehensive report on the status of the inservice inspection program.
Considering that the Code recording and reporting criteria are simply administrative requirements, the INEL staff believes that use of the alternatives to Code requirements contained in Code Case N-532 will continue to provide an acceptable level of quality and safety.
Therefore, it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
The use of alternatives contained in Code Case N-532 should be authorized for the current interval until such time as the Code Case is published in a future revision of Regulatory Guide 1. 147.
At that time, if the licensee intends to continue to implement the alternatives of this Code Case, the
licensee is to follow all provisions in Code Case N-532 with limitations issued in Regulatory Guide 1. 147, if any.
B.
Re est f Relief 14 U it 3 ables I B-2500-d WC-2500-1 Ex m nat o
Cate pries B-D B-F B-J C-F-1 and C-F-2 Items B3. 140 5
0 C5, nd C5.51 Cl s
and 2
ss e Ret in'imilar and issimil r Metal elds in Vesse s and Pi in Code Re ui ement:
Tables IWB-2500-1 and IWC-2500-1, Examination Categories B-D, B-F, B-J, C-F-1, and C-F-2, Items B3. 140, 85.70, B9. 11, C5. 11, and C5.51 require surface and/or volumetric examination of 100X of the required examination volume.
Licensee's Code Relief Re uest:
The licensee requested relief from performing volumetric examination of essentially 100X of the required examination volume for the welds listed in Table l.
EXN CATEGORY Table 1
ITEN 0 ITEN DESCRIPTION L IMITATION COVERAGE B-D B3.140 3-SGB-I-IRS 3-SGB-0-IRS Welded on pads,
- support, and IRS confi uration 70X two directions B-D B-F B-J 8-J B3. 120 3-SRGN IR B5.70 31"-RCS-1302-5 B9. 11 31 "-RCS-1302-10 B9. 11 29"-RCS-1305-3 Heater penetrations Steam generator nozzle configuration and elbow material is hi hl attenuative Pump casing configuration and elbow & pump material is hi hl attenuative Branch connection to pipe configuration, elbow configuration, and elbow material is hi hly attenuative 55X two directions 75X from elbow side 75X from elbow side 93X from pipe side, 69X from elbow side
EXAN ITEN 0 ITEII DESCRIPTION CATEGORY LINITATION COVERAGE B-F B-J B-J B-J B-J C-F-1 C-F-1 C-F-2 B5.70 29"-RCS-1305-4 B9.11 27.5"-RCS-1306-11 B9.11 12"-RC-1301-1 B9.11 10"-SI-1302-1 B9.11 10"-SI-1302-4 C5.11 8"-SI-2309-22 C5.11 8"-SI-2309-24 C5.51 6"-BDA-2301-8 Nozzle and elbow configuration and elbow material is hi hl attenuative Pump casing to pipe configuration and pump casing material is hi hl attenuative Branch connection to pipe configuration Valve to elbow configuration Valve to elbow configuration Pipe to Tee configuration Valve surface in as-cast condition.
Tee geometry and a
rough weld crown 43X from elbow side, 2X from nozzle side 100X from pipe side 100X from pipe side, 67X from branch connection side 100X from elbow side, 85X from valve side 85X from elbow side, 25X from valve side 100X from pipe side, 47X from tee side 100X from i
e side 100X from pipe side, 50X from tee side
Licensee's Basis for Re uestin Relief (as stated):
"Several welds examined during the 1994 outage did not receive the required volumetric examinations due to one or more factors:
"1.
Portions of the required volumetric area are inaccessible due to permanent physical obstructions.
"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 reason].
"3.
High attenuation of the ultrasonic sound.
"The UT techniques for each weld were reviewed to determine if additional coverage could have been achieved.
FPLs procedures require the examiner to consider whether additional coverage is necessary and practical.
Those alternate techniques were investigated at the time of discovery.
The alternate techniques considered were extending the calibration distance and using additional beam angles and/or modes.
This has often provided the additional coverage needed to avoid relief.
After considering the alternate UT techniques, it was determined they would have provided little or no additional coverage.
The coverage obtained were the maximum practical by UT techniques.
"If practical, physical obstructions were removed.
In most cases, it was not possible to remove the obstruction without significant work, radiation exposure, and/or damage to the plant (I. e. pressurizer heaters at the surge line inside radius section.)
"Additional weld preparation by welding or metal removal is a
modification of the examination area requiring significant engineering and construction personnel support.
High radiation exposure and costs would be incurred in order to perform these types of modifications.
Radiography is impractical due to the amount of work being performed in the area on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis.
This would result in numerous work related stoppages and increased exposure due to the shutdown and startup of other work in the area.
Removal of water from the associated piping is not always possible, and when performed, increases the radiation dose rates in the area.
It would be a significant hardship to perform weld or area modifications or radiography in order to increase examination coverage.
"FPL has made reasonable efforts to meet Code requirements.
Limitations were derived by graphically plotting the angles on replicas of the as welded surfaces (when possible) and looking at actual and theoretical coverage that could be obtained with additional angles.
In each
- case, the coverages obtained were considered the maximum practical.
The alternate techniques would not have enhanced the coverage, nor added to the quality of the examination or safety of the system.
"FPL performed the examinations to the extent possible.
The surface and volumetric examinations performed 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...[ASME Section XI].
"3.
Monthly walkdowns by system engineers are performed on Class 2
systems outside containment to check for leakage, piping configuration, and/or damage.
During outages, system engineers walkdown Class I and Class 2 systems inside containment.
This walkdown is performed to look for system anomalies which could affect plant performance.
"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 practical."
Evaluation:
The Code requires volumetric and/or surface examinations of the subject welds.
However, portions of the required examination volumes are inaccessible due to permanent physical obstructions.
In addition, some welds could be examined from only one side due to the configuration of the component and the highly attenuative properties of the base metal.
The specific limitation for each of the subject welds is contained in Table I above.
To obtain complete volumetric coverage, modification or replacement of the subject 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 proposed to examine the subject welds to the extent possible.
Extended beam paths were considered and found to be impractical due to the metallurgical properties of the centrifugally cast stainless steel base material.
- However, based on the volume that will be
- examined, the surface examination of the subject welds, and the examination of other similar welds, it is reasonable to conclude that degradation, if present, will be detected.
Therefore, reasonable assurance of continued structural integrity will be provided.
The restrictions noted in Table 1 above make the Code-required volumetric examinations impractical.
Based on the weld coverage obtainable, the surface examination of the subject welds, and the examination of similar
- welds, reasonable assurance of structural integrity will be provided.
Therefore, it is recommended that relief be granted, pursuant to 10 CFR 50.55a(g)(6)(i).
C.
e es e 'e 5
U t ab WB-500-1 am nation Cate or es B-D B-F nd 8-J Items B3. 140 B5.70 a d B9 ll Class 1 Pressure Retainin Similar and Dissimilar Metal Welds in Vessels and Pi in Code Re uirement:
Table IWB-2500-1, Examination Categories B-D, B-F, and B-J, Items B3. 140, B5.70, and B9. 11, require surface and/or volumetric examination of 100X of the required examination volume.
Licensee's Code Relief Re uest:
The licensee requested relief from performing volumetric examination of essentially 100X of the required examination volume for the welds listed in Table l.
Table 1
EXAN ITEN ¹ ITEN DESCRIPTION CATEGORY LINITATIOH COVERAGE B-D B3.140 4-SGA-I-IRS, 4-SGA-0-IRS Welded on pads,
- support, and IRS confi uration 70X two directions B-F B-J B-J B5. 70 31"-RCS-1401-5 B9. 11 31"-RCS-1401-8 B9.11 31"-RCS-1401-10 Steam generator nozzle confi uration Elbow and weld geometry Pump casing configuration and elbow eometry 75X from elbow side 88X from elbow side, 64X from i
e side 57X from elbow side
I
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10 EXAN CATEGORY ITEN f ITEN DESCRIPTION LINITATION COVERAGE 8-F 8-F 8-J 8-J 8-J 8-J 8-J 8-J 8-J 8-J 8-J 8-J 8-J 85.70 29"-RCS-1404-4 85.70 29"-RCS-1305-4
- 89. 11 29"-RCS-1404-18 89.11 27.5"-RCS-1407-11 89.11 27.5"-RCS-1407-20 89.11 29"-RCS-1405-21 89.11 27.5"-RCS-1406-18 89.11 27.5"-RC-1409-16
- 89. 11
- 27. 5"-RC-1409-17
- 89. 11 14"-RHR-1401-1
- 89. 11 14"-RHR-1401-5 89.11 14"-RHR-1401-6
- 89. 11 14"-RHR-1401-9 Nozzle-to-elbow confi uration Nozzle and elbow configuration Meld configuration Pump casing to pipe configuration Branch connection to i e confi uration Branch connection to pipe configuration Branch connection to i
e confi uration Branch connection to i
e confi uration Branch connection to i e confi uration Branch connection to elbow configuration Pipe to valve confi uration Valve to pipe confi uration Elbow to pipe configuration 74X from elbow side 43X from elbow side, 2X from nozzle side 100X from branch connection side 41X from pipe side, 18X from um side 92X from nozzle side 75X from branch connection side 100X from nozzle side 100X from nozzle side 100X from nozzle side 70X from elbow side, 35X from branch connection side 100X from i e side 100X from i e side 53X from pipe side, 54X from elbow side
11 EXAN ITEN f ITEN DESCRIPTION CATEGORY LINITATION COVERAGE B-J B-J B9.11 10"-SI-1401-14 B9.11 10"-SI-1401-18 Valve to pipe configuration Branch connection to pipe configuration 100X from pipe side, 26X from valve side 100X from pipe side, 18X from branch connection side Licensee's Basis for Re uestin Relief (as stated):
"Several welds examined during the 1994 outage did not receive the required volumetric examinations due to one or more factors:
"1.
Portions of the required volumetric area are inaccessible due to permanent physical obstructions.
"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 reason.
"The UT techniques for each weld were reviewed to determine if additional coverage could have been achieved.
FPLs procedures require the examiner to consider whether additional coverage is necessary and practical.
Those alternate techniques were investigated at the time of discovery.
The alternate techniques considered were extending the calibration distance and using additional beam angles and/or modes.
This has often provided the additional coverage needed to avoid relief.
After considering the alternate UT techniques, it was determined they would have provided little or no additional coverage.
The coverages obtained were the maximum practical by UT techniques.
"If practical, physical obstructions were removed.
In most cases, it was not possible to remove 'the obstruction without significant work, radiation exposure, and/or damage to the plant (i. e. pressurizer heaters at the surge line inside radius section.)
"Additional weld preparation by welding or metal removal is a
modification of the examination area requiring significant engineering and construction personnel support.
High radiation exposure and costs would be incurred in order to perform these types of modifications.
Radiography is impractical due to the amount of work being performed in the area on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis.
This would result in numerous work related stoppages and increased exposure due to the shutdown and startup of other work in the area.
Removal of water from the associated piping is not
12 always possible, and when performed, increases the radiation dose rates in the area.
It would be a significant hardship to perform weld or area modifications or radiography in order to increase examination coverage.
" FPL has made reasonable efforts to meet Code requirements.
Limitations were derived by graphically plotting the angles on replicas of the as welded surfaces (when possible) and looking at actual and theoretical coverage that could be obtained with additional angles.
In each
- case, the coverage obtained were considered the maximum practical.
The alternate techniques would not have enhanced the coverage, nor added to the quality of the examination or safety of the system.
"FPL performed the examinations to the extent possible.
The surface and volumetric examinations performed 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
[ASIDE Section XI] were performed.
"3.
monthly walkdowns by system engineers are performed on Class 2
systems outside containment to check for leakage, piping configuration, and/or damage.
During outages, system engineers walkdown Class I and Class 2 systems inside containment.
This walkdown is performed to look for system anomalies which could affect plant performance.
"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 practical."
~Eva ati:
The Code requires volumetric and/or surface examinations of the subject welds.
However, portions of the required examination volumes are inaccessible due to permanent physical obstructions.
In addition, some welds could be examined from only one side due to the configuration of the component and the highly attenuative properties of the base metal.
The specific limitation for each of the subject welds is contained in Table I above.
To obtain complete volumetric coverage, modification or replacement of the subject components with those of a design providing
1
)
> ~
)
V
13 for complete coverage would be required.
Imposition of this requirement would cause a considerable burden on the licensee.
The licensee proposed to examine the subject welds to the extent possible.
Extended beam paths were considered and found to be impractical due to the metallurgical properties of the centrifugally cast stainless steel base material.
- However, based on the volume that will be
- examined, the surface examination of the subject welds, and the examination of other similar welds, it is reasonable to conclude that degradation, if present, will be detected.
Therefore, reasonable assurance of continued structural integrity will be provided.
The restrictions noted in Table I above make the Code-required volumetric examinations impractical.
Based on the weld coverage obtainable, the surface examination of the subject welds, and the examination of similar
- welds, reasonable assurance of structural integrity will be provided.
Therefore, it is recommended that relief be granted, pursuant to 10 CFR 50.55a(g)(6)(i).
D.
Re est for Relief 17 Unit 4 IWB-2420 a Successive Ins ections of E amination Cate or C-B Items C2.21 and C2.22 Steam Generator Nozzle-to-Shell Weld and Inner Radius Sect'ons Code Re uirement:
IWB-2420(a) requires the sequence of component examinations established during the first inspection interval to be repeated during each successive inspection interval.
Li ensee'ode Relief Re uest:
The licensee requested relief from following the sequence of examinations set during the first and second intervals for the steam generator nozzle-to-shell weld and inner radius sections.
icensee's Basis for Re uestin Relief (as stated):
"On Steam Generator , the Upper Shell to Head weld is scheduled for examination during the third period.
Steam Generator ain Steam Nozzle is scheduled for examination during the first period.
These welds
)
14 and inner radius sections are required to be volumetrically examined once each interval.
This schedule is consistent with the previous interval, and Note (4) of Category C-A and Note (3) of Category C-B.
By scheduling the welds and inner radius section on the same steam generator, FPL will reduce radiation exposure and costs.
"In order to examine the head to shell weld, scaffold must be built around the steam generator and insulation removed.
This process is repeated for the steam nozzle examinations.
Holding to the same schedule as previous intervals would require this work to be performed 2 times.
Scheduling the examinations together on the same steam generator would save the radiation exposure and costs required for the majority of one of these examinations.
"A review if 1995 Edition of Section XI shows that the Code Committee has recognized that Owners may not always be able to adhere to the strict scheduling requirements of the earlier Codes.
The words 'o the extent practical'ere added to each Note.
This would enable Owners to change to different Steam Generators if unanticipated problems were to occur or if significant reduction in costs and radiation exposure could be realized.
"The proposed schedule for the examination of substitute nozzle to shell weld and the associated inside radius section complies with FPL's Turkey Point Relief No. 9, Alternative Scheduling of Examinations."
In the licensee' August 8,
- 1996, response the following information was provided:
"FPL is requesting to change the examination schedule to reduce exposure and costs.
This relief is requesting to substitute the examination of the team generator main steam nozzle weld in place of the same weld on the team generator.
This weld has not been previously examined.
The Turkey Point ISI Program did not address examining welds which had not previously been examined except when the originally scheduled weld was not accessible or if radiation exposure could be significantly reduced.
This change would minimally reduce
- exposure, so the dose criteria in FPL Relief Request No.
9 was not being met.
The purpose of requesting this change is to reduce the amount of time and work involved in removing insulation and to build scaffold on one steam generator instead of two.
During the 1995 Unit 3 outage, it was discovered to be more efficient to examine the main steam nozzle to shell weld and the upper head to shell weld together rather than at different times.
The requirements were the same.
Examining the two areas at the same time was cost effective and reduced some future radiation exposure."
Licensee's Pro osed Alternative Examination (as stated):
"FPL will substitute the same Main Steam nozzle to shell weld and inner radius section on a different Steam Generator.
The proposed schedule
15 will be to examine the Nozzle to Shell weld and its inside Radius Section on Steam Generator
, The examination will be scheduled in accordance with the attached tables'."
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examinations established during the first inspection interval be repeated during each successive inspection interval.
The licensee has proposed rescheduling examination areas for the third interval under a zone concept.
Specifically, by changin'g two Examination Category C-B welds from Steam Generator "A" to Steam Generator "C".
However, the minimal burden associated with the examinations is insufficient to justify not examining the subject welds on the "A" Steam Generator.
Therefore, it is recommended that the licensee' alternative be denied.
3.0 CONCLUSION
The INEL staff has reviewed the licensee's submittal and concludes that, for Request for Relief 6, the use of the alternatives to Code requirements contained in Code Case N-532 will continue to provide an acceptable level of quality and safety.
Therefore, it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
The INEL staff has reviewed the information provided by the licensee and concludes that the Code examination requirements are impractical for the welds contained in Requests for Relief 14 and 15.
Based on the weld coverage obtainable, the surface examination of the subject welds, and the examination of similar welds, reasonable assurance of structural integrity is provided.
Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
The INEL staff has evaluated Request for Relief 17.
The minimal burden associated with the examinations is insufficient to justify not examining the subject welds on the "A" Steam Generator.
Therefore, it is recommended that the licensee' alternative be denied.
"Not included in this technical letter report.
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