ML18152B163
| ML18152B163 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/23/1988 |
| From: | Chandu Patel Office of Nuclear Reactor Regulation |
| To: | Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| TAC-65557, TAC-65558, NUDOCS 8806030199 | |
| Download: ML18152B163 (16) | |
Text
Docket Nos. 50-280 and 50-281 Mr. D.S. Cruden e
May 2 3, 1 988 Vice President-Nuclear Virginia Electric and Power Company P.O. Box 26666 Richmond, Virginia 23261
Dear Mr. Cruden:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - SECOND 10-YEAR INSERVICE INSPECTION PROGRAM FOR SURRY UNITS 1 AND 2 (TAC NOS. 65557 AND 65558)
In conducting our review of your April 16, 1987 submittal relating to the above subject at the Surry Units 1 and 2, we have determined that we will need addi-tional information identified in the enclosures (Enclosure 1 for Unit 1 and for Unit 2) to continue our review.
In order for us to maintain our review schedule, your response is requested within 45 days of the date of this letter. If you cannot provide a full response within the requested time, please provide your full response schedule within 30 days of the date of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than 10 respondents; therefore, 0MB clearance is not required under P.L.96-511.
Enclosures:
As stated cc w/enclosures:
See next page L~
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PDR DISTRIBUTION Docket File NRC PDR Loca 1 PDR PD22 Rag SVarga GLainas DMiller ~.sit M C~ng 5lz,o/88 Sincerely, Chandu P. Patel, Project Manager Project Directorate 11-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation CPate'l EJordan JPartlQW ACRS (10)
OGC Gray_ File MHum D.)
~~~?w 57'J')/88
Mr. D. s*. Cruden Virginia Electric and Power Company cc:
Mr. Michael W. Maupin Hunton and Williams Post Office Box 1535 Richmond, Virginia 23212 Mr. David L. Benson, Manager Surry Power Station Post Office Box 315 Surry, Virginia 23883 Resident Inspector Surry Power Station U.S. Nuclear Regulatory Cor.1mission Post Office Box 166, Route 1 Surry, Virginia 23883 Mr. Sherlock Holmes, Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 W. T. Lough Virginia Corporation Commission Division of Energy Regulation Post Offic~ Box 1197 Richmond, Virginia 23209 Regional Administrator, Region II U.S. Nuclear Regulatory Corrmission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323 James B. Kenley, M.D., ColTUllissioner Department of Health 109 Governor Street Richmond, Virginia 23219 Surry Power Station Attorney General Supreme Court Building 101 North 8th Street Richmond, Virginia 23219
e ENCLOSURE 1 e
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNIT 1, DOCKET NUMBER 50-280 MATERIALS ENGINEERING BRANCH DIVISION OF ENGINEERING AND SYSTEMS TECHNOLOGY Request for Additional Information - Second IO-Year Interval Inservice Inspection Program Plan*
I. Scope/Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code.Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in the ASME 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. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during the second 120-month inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.SSa(b) on the date 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by
. reference in 10 CFR 50.SSa(b) subject to the limitations and modifications listed therein. Based on the starting date of December 22, 1982 for the second IO-year interval, the Inservice Inspection (ISI) Program Plan has been prepared to meet the requirements of the 1980 Edition, Winter 1980 Addenda (80W80) of the ASME Code Section XI except that the extent of examination for Code Class 1 and 2 piping welds has been determined by the 1974 Edition through Summer 1975 Addenda (74S75).
1
e e
As required by 10 CFR 50.SSa(g)(S), if the licensee determines that certain Code examination requirements are impractical and relief is requested, the licensee shall submit information to the Nuclear Regulatory Commission (NRC) to support that determination.
The staff has reviewed the available information in the Surry Power Station, Unit I, Second IO-Year Interval ISi Program Plan, Revision 3, submitted April 16, 1987 and the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical.
- 2.
Additional Information/Clarification Required Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the ISi Program Plan:
A.
Provide isometric and/or component drawings showing the welds, components, and supports which Section XI of the ASME Code requires be examined.
- 8.
Provide the staff with an itemized listing of the welds/components subject to examination during the second IO-year interval. The*
requested listing, along with the isometric drawings, will permit the staff to determine if the extent of ISi examinations meets the applicable Code requirements.
C.
Provide a list of the ultrasonic calibration standards being used during the second IO-year inspection interval. This list should include calibration standard identifications, material specifications, and sizes.
D.
Provide a list of the nondestructive examination procedures that are being used during the second inspection interval.
2
e e
E.
In Section 3 of Revision 3 of the ISi Program Plan, the Licensee added a new program for component and piping support inspection.
The Licensee proposes to follow the Code requirements with the following exemptions:
(1)
"Component supports that are outside the scope of the Show Cause Order regarding the I&E Bulletin 79-14 are exempt from the preservice and inservice requirements of this support program."
(2)
"Component and piping supports which are buried, encased in concrete, or that portion of the supports which are made inaccessible by the normal component or piping insulation are exempt from the preservice and inservice requirements of this support program."
With regard to the first proposed exemption, I&E Bulletin 79-14, entitled "Seismic Analyses for As-Built Safety-Related Piping Systems," requires a licensee to verify that seismic analyses were performed based on the as-built piping system configuration. This Bulletin is not intended as a guide for support inspections. Thus, the staff considers it to be inappropriate to use the scope of I&E Bulletin 79-14 in the selection of supports for examination.
The proposed program would exclude from examination supports for Class 1, 2, and 3 piping 2 inch nominal pipe size and smaller. This is not consistent with Code requirements which exclude supports for Class 1 piping 1 inch nominal pipe size and smaller, and for Class 2 and 3 piping 4 inch pipe size and smaller.
The Licensee would inspect fewer Class 1 component and piping supports and more Class 2 and 3 component and piping supports in the proposed program than the Code requires.
Furthermore, most of the supports in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) Systems would be excluded from the proposed program due to the size exemption.
However, pursuant to 10 CFR 50.55a(b)(2)(iv)(A), the RHR, ECC, and CHR systems must be inspected because of their importance in a safe plant shutdown.
Thus, the staff considers the proposed adherence to the scope of 3
e e
l&E Bulletin 79-14 in the selection of supports for inspection not acceptable. The Licensee should follow IWF-2510 in the Code for the selection of supports for examination.
With regard to the second proposed exemption, component and piping supports that are made inaccessible by insulation cannot be excluded from the support inspection program without consideration of the supports.
Such supports should be treated on an individual basis.
Paragraph IWF-1300(e) of Section XI of the ASME Code states:
"Where the mechanical connection of a nonintegral support is buried within the component insulation, the support boundary may extend from the surface of the component insulation provided the support either carries the weight of the component or serves as a structural restraint in compression." According to the reply to Question (5) of ASME Code Section XI Interpretation: XI-1-86-11 (Interpretations Vol. 18), IWF-2510 and IWF-1300(e) require the removal of that insulation necessary to perform inspection of all component supports that cannot be shown to carry the weight of the component or serve as a structural restraint in compression.
Pursuant to 10 CFR 50.55a(g)(5)(iii), the Licensee should submit a relief request for staff evaluation for a support whose examination is determined to be impractical to perform.
This provides a consistent inspection procedure for both the component and the support. Thus, the staff considers the proposed exemption of inaccessible supports for examination not acceptable.
The Licensee should revise Section 3 of the ISi Program Plan to delete these two unacceptable exemptions from the support inspection program and establish an acceptable examination sample as stated above.
(For additional information on the evaluation of the above exemptions, see NRC Memorandum, R.L. Ballard to C. Patel, dated July 25, 1986.)
F.
Request for Relief SR-005 was previously denied because inadequate information was submitted. This relief request has been resubmitted in Revision 3 of the ISi Program Plan and includes drawings that 4
- show the obstructions that preclude volumetric examination of portions of pressurizer welds 7 and 15.
From review of these drawings, it appears that these welds are totally inaccessible from one side and only partially obstructed from the other side and that a significant percentage of the volumetric examination can be performed from the partially obstructed side of the welds.
Estimate the percentage of the Code-required examination that can be performed for each of these welds.
G.
Request for Relief SR-008: This relief request has not been supported by adequate descriptive and detailed technical information.
Provide, as a minimum, the following additional information:
(1)
Provide drawings/sketches showing the dimensions of the nozzle-to-safe end weld and the pipe-to-safe end weld with respect to each other; (2)
Discuss what examination can be performed from the safe end side of the welds; (3) State whether the Code-required surface examination will be performed on both welds; and (4)
Estimate the percentage of the Code-required volumetric examination that can be performed for each of the welds for which relief is requested.
H.
Request for Relief SR-009:
Discuss the possibility of using the improved miniature linear accelerator (Minac-6), which is reported to be almost 10 times more powerful than the original EPRI Minac, for volumetric examination of the Class 1 longitudinal electroslag piping welds in the cast austenitic elbows on the crossover leg of the reactor coolant system.
5 J
e e
I. Requests for Relief SR-010 and SR-013:
These are generic relief requests without a list of specific welds for which relief is requested.
The regulations do not provide for granting generic relief requests. Therefore, the staff requests the following information with regard to Requests for Relief SR-010 and SR-013:
(1)
List the specific welds for which relief is requested, (2)
For each of the welds listed, provide a detailed description of the obstructions or limitations which will be encountered during the course of the examination(s), and (3)
Provide an estimate of the percentage of the Code-required examination(s) that can be performed for each of the welds listed.
J. Request for Relief SR-011:
Relief is requested from performing the Code-required volumetric examination of the bolting used in the reactor coolant loop stop valves. It is stated that, due to the material characteristics of both the bolting and the valve body, removal of the bolting may cause significant damage to the studs and the valve body.
The bolting is ASTM A193 grade B-8M with a hex head and a 3/4-inch hole drilled completely through the stud.
An ultrasonic examination could be conducted from the center-drilled hole of the Class 1 bolts while in place under tension. Also, ASME Code Case N-307-1 (listed in Regulatory Guide 1.147 as an NRC-approved Code Case) allows for a revised ultrasonic examination volume when the examinations are conducted from the center~drilled hole.
The Licensee should either withdraw Request for Relief SR-011 and use ASME Code Case N-307-1, or provide further technical justification for requesting relief from the Code requirement.
6
e K.. Request for Relief No. 22:
The section entitled "Section XI Code Requirements For Which Relief is Requested" lists the following:
Class I System Hydrostatic Test, IWB-5222; Class I System Leakage Test, IWB-5221; and Visual Examination, IWA-5240.
Verify that relief is being requested for the visual examination only.
Also, provide a brief description of the proposed alternative examination method utilizing leakage identification in lieu of the Code-required visual examinations.
L.
Request for Relief No. 23:
It is stated that the valve design of HCV-13IOA prevents pressurization of the subject piping and valves when conducting the system hydrostatic pressure test per IWC-5222.
The valve is required to be closed for the system hydrostatic pressure test but when the required test pressure (3419 psig) is applied, the valve lifts off its seat. It is also stated that, in previous tests, a mechanical jack has been installed to prevent the valve seat from lifting. The hydrostatic test would be completed but valve damage was incurred (bending stem, disc, seat, etc.).
Has the damaged valve been replaced and, if so, will the replacement valve withstand the Code-required test pressure? What is the maximum test pressure that a hydrostatic test could be performed at without damaging the valve?
The schedule for timely completion of this review requires that the Licensee provide, by the requested date, the above requested information and/or clarifications with regard to the Surry Power Station, Unit I, Second IO-Year Interval ISI Program Plan, Revision 3.
7
ENCLOSURE 2 e
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNIT 2, DOCKET NUMBER 50-281 MATERIALS ENGINEERING BRANCH DIVISION OF ENGINEERING AND SYSTEMS TECHNOLOGY Request for Additional Information - Second IO-Year Interval Inservice Inspection Program Plan I. Scope/Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and 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. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during the second 120-month inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.SSa(b) on the date 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.SSa(b) subject to the limitations and modifications listed therein. Based on the starting date of May 1, 1983 for the second IO-year interval, the Inservice Inspection (ISI) Program Plan has been prepared to meet the requirements of the 1980 Edition, Winter 1980 Addenda (SOWSO) of the ASME Code Section XI except that the extent of examination for Code Class 1 and 2 piping welds has been determined by the 1974 Edition through Su11111er 1975 Addenda (74S75).
1
e As required by 10 CFR 50.SSa(g)(S), if the licensee determines that certain Code examination requirements are impractical and relief is requested, the licensee shall submit information to the Nuclear Regulatory Co1T111ission (NRC) to support that determination.
The staff has reviewed the available information in the Surry Power Station, Unit 2, Second IO-Year Interval ISi Program Plan, Revision 1, submitted April 16, 1987 and the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical.
- 2.
Additional Information/Clarification Required Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the ISi Program Plan:
A.
Provide isometric and/or component drawings showing the welds, components, and supports which Section XI of the ASHE Code requires be examined.
B.
Provide the staff with an itemized listing of the welds/components subject to examination during the second IO-year interval. The requested listing, along with the isometric drawings, will permit the staff to determine if the extent of ISi examinations meets the applicable Code requirements.
C.
Provide a list of the ultrasonic calibration standards being used during the second IO-year inspection interval. This list should include calibration standard identifications, material specifications, and sizes.
O.
Provide a list of the nondestructive examination procedures that are being used during the second inspection interval.
2
e e
E:
In Section 3 of Revision 1 of the ISI Program Plan, the Licensee added a new program for component and piping support inspection.
The Licensee proposes to follow the Code requirements with the following exemptions:
(1)
"Component supports that are outside the scope of the Show Cause Order, 79-14, are exempt from the preservice and inservice requirements of this support program."
(2)
"Component and piping supports which are buried, encased in concrete, or that portion of the supports which are made inaccessible by the normal component or piping insulation are exempt from the preservice and inservice requirements of this support program."
With regard to the first proposed exemption, I&E Bulletin 79-14, entitled "Seismic Analyses for As-Built Safety-Related Piping Systems," requires a licensee to verify that seismic analyses were performed based on the as-built piping system configuration. This*
Bulletin is not intended as a guide for support inspections. Thus, the staff considers it to be inappropriate to use the scope of I&E Bulletin 79-14 in the selection of supports for examination.
The proposed program would exclude from examination supports for Class 1, 2, and 3 piping 2 inch nominal pipe size and smaller. This is not consistent with Code requirements which exclude supports for Class 1 piping 1 inch nominal pipe size and smaller, and for Class 2 and 3 piping 4 inch pipe size and smaller. The Licensee would inspect fewer Class 1 component and piping supports and more Class 2 and 3 component and piping supports in the proposed program than the Code requires. Furthermore, most of the supports in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) Systems would be excluded from the proposed program due to the size exemption.
However, pursuant to 10 CFR 50.55a(b)(2)(iv)(A), the RHR, ECC, and CHR systems must be inspected because of their importance in a safe plant shutdown.
Thus, the staff considers the proposed adherence to the scope of 3
I&E Bulletin 79-14 in the selection of supports for inspection not acceptable.
The Licensee should follow IWF-2510 in the Code for the selection of supports for examination.
With regard to the second proposed exemption, component and p1p1ng supports that are made inaccessible by insulation cannot be excluded from the support inspection program without consideration of the supports. Such supports should be treated on an individual basis.
Paragraph IWF-1300(e) of Section XI of the ASHE Code states:
"Where the mechanical connection of a nonintegral support is buried within the component insulation, the support boundary may extend from the surface of the component insulation provided the support either carries the weight of the component or serves as a structural restraint in compression." According to the reply to Question (5) of ASHE Code Section XI Interpretation: Xl-1-86-11 (Interpretations Vol. 18), IWF-2510 and IWF-1300(e) require the removal of that insulation necessary to perform inspection of all component supports that cannot be shown to carry the weight of the component or serve as a structural restraint in compression.
Pursuant to 10 CFR 50.SSa(g)(S)(iii), the Licensee should submit a relief request for staff evaluation for a support whose examination is determined to be impractical to perform. This provides a consistent inspection procedure for both the component and the support. Thus, the staff considers the proposed exemption of inaccessible supports for examination not acceptable.
The Licensee should revise Section 3 of the ISi Program Plan to delete these two unacceptable exemptions from the support inspection program and establish an acceptable examination sample as stated above.
(For additional information on the evaluation of t_he above exemptions for Unit 1, see NRC Memorandum, R.L. Ballard to C. Patel, dated July 25, 1986.)
F.
Request for Relief SR-005 was previously denied because inadequate information was submitted. This relief request has been resubmitted in Revision 1 of the ISI Program Plan and includes drawings that 4
e show the obstructions that preclude volumetric examination of portions of pressurizer welds 7 and 2.
From review of these drawings, it appears that these welds are totally inaccessible from one side and only partially obstructed from the other side and that a significant percentage of the volumetric examination can be performed from the partially obstructed side of the welds.
Estimate the percentage of the Code-required examination that can be performed for each of these welds.
G.
Request for Relief SR-008: This relief request has not been supported by adequate descriptive and detailed technical information. Provide, as a minimum, the following additional
. information:
(1)
Provide drawings/sketches showing the dimensions of the nozzle-to-safe end weld and the pipe-to-safe end weld with*
respect to each other; (2) Discuss what examination can be performed from the safe end side of the welds; (3) State whether the Code-required surface examination will be performed on both welds; and (4)
Estimate the percentage of the Code-required volumetric examination that can be performed for each of the welds for which relief is requested.
H.
Request for Relief SR-009: Discuss the possibility of using the improved miniature linear accelerator (Minac-6), which is re_ported to be almost 10 times more powerful than the original EPRI Min,c, for volumetric examination of the Class 1 longitudinal electroslag piping welds in the cast austenitic elbows on the crossover leg of the reactor coolant system.
5
e e
I. Requests for Relief SR-010 and SR-013: These are generic relief requests without a list of specific welds for which relief is requested.
The regulations do not provide for granting generic relief requests. Therefore, the staff requests the following information with regard to Requests for Relief SR-010 and SR-013:
(1)
List the specific welds for which relief is requested, (2)
For each of the welds listed, provide a detailed description of the obstructions or limitations which will be encountered during the course of the examination(s), and (3)
Provide an estimate of the percentage of the Code-required examination(s) that can be performed for each of the welds listed.
J. Request for Relief SR-011:
Relief is requested from performing the Code-required volumetric examination of the bolting used in the reactor coolant loop stop valves. It is stated that, due to the material characteristics of both the bolting and the valve body, removal of the bolting may cause significant damage to the studs and the valve body.
The bolting is ASTM Al93 grade 8-SM with a hex head and a 3/4-inch hole drilled completely through the stud.
An ultrasonic examination could be conducted from the center-drilled hole of the Class 1 bolts while in place under tension. Also, ASME Code Case N-307-1 (listed in Regulatory Guide 1.147 as an NRC-approved Code Case) allows for a revised ultrasonic examination volume when the examinations are conducted from the center-drilled hole.
The Licensee should either withdraw Request for Relief SR-011 and use ASHE Code Case N-307-1, or provide further technica~
justification for requesting relief from the Code requirement.
6
K.
Request for Relief No. 21:
The section entitled "Section XI Code Requirements For Which Relief is Requested" lists the following:
Class 1 System Hydrostatic Test, IWB-5222; Class 1 System Leakage Test, IWB-5221; and Visual Examination, IWA-5240.
Verify that relief is being requested for the visual examination only.
Also, provide a brief description of the proposed alternative examination method utilizing leakage identification in lieu of the Code-required visual examinations.
L.
Request for Relief No. 22:
It is stated that the valve design of HCV-2310A prevents pressurization of the subject piping and valves_
when conducting the system hydrostatic pressure test per IWC-5222.
The valve is required to be closed for the system hydrostatic pressure test but when the required test pressure (3419 psig) is applied, the valve lifts off its seat.
In previous tests, a mechanical jack has been installed to prevent the valve seat from lifting. The hydrostatic test would be completed but valve damage was incurred (bending stem, disc, seat, etc.).
Has the damaged valve been replaced and, if so, will the replacement valve withstand the Code-required test pressure? What is the maximum test pressure that a hydrostatic test could be performed at without damaging the valve?
The schedule for timely completion of this review requires that the Licensee provide, by the requested date, the above requested information and/or clarifications with regard to the Surry Power Station, Unit 2, Second IO-Year Interval ISI Program Plan, Revision 1.
7