ML18159A034
| ML18159A034 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/04/2018 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 18-199 | |
| Download: ML18159A034 (19) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINlA 23261 June 4, 2018 10 CFR 50.55a U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 Serial No.
SPS-LIC/CGL Docket No.
License No.
ASME SECTION XI INSERVICE INSPECTION PROGRAM RELIEF REQUESTS FOR LIMITED COVERAGE EXAMINATIONS PERFORMED IN THE FIRST PERIOD OF THE FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL 18-199 RO 50-281 DPR-37 Virginia Electric and Power Company (Dominion Energy Virginia) performed inservice inspection (ISi) examinations at Surry Power Station Unit 2 for the first period of the fifth 10-year ISi interval, which began on May 10, 2014 and will end on May 9, 2024.
Examinations of certain components conducted during the first period of the fifth interval received less than the required examination coverage.
Pursuant to 10 CFR 50.55a(g)(5)(iii), Dominion Energy Virginia requests relief for limited examinations on the basis that the required examination coverage was impractical due to physical obstructions and limitations imposed by design and geometry of the subject components. Attachments 1 and 2 contain the specific relief requests and the basis for each request. These relief requests have been reviewed and approved by the station's Facility Safety Review Committee.
If you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.
Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Commitments made in this letter: None
Attachments:
Serial No.18-199 Docket No. 50-281 Relief Requests for 1st Period of 5 th Interval Limited Coverage Examinations Page 2 of 2
- 1. Relief Request S2-15-LMT-C01, Examination Category B-D, Pressurizer Nozzle Inner Radius Sections
- 2. Relief Request S2-15-LMT-P01, Examination Category R-A, Preservice Weld Examinations cc: U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station Ms. K. R. Cotton-Gross NRC Project Manager - Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, Maryland 20852 Mr. J. R. Hall NRC Senior Project Manager - North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B-1 A 11555 Rockville Pike Rockville, Maryland 20852 Mr. R. A. Smith Authorized Nuclear Inspector Surry Power Station Serial No. 18-1 99 Docket No. 50-281 Relief Request S2-15-LMT-C01, Examination Category 8-0, Pressurizer Nozzle Inner Radius Sections Virginia Electric and Power Company (Dominion Energy Virginia)
Surry Power Station Unit 2
Dominion Energy Virginia Surry Power Station Unit 2 5th 10-Year Interval May 10, 2014-May 9, 2024 Pressurizer Nozzle Inner Radius Sections Relief Request S2-15-LMT-C01 In Accordance with 10 CFR 50.55a(g)(5)(iii)
Drawing:
ASME Class:
10NIR, 11NIR 11548-WMKS-RC-E-2 1
83.120 Serial No.18-199 Docket No. 50-281
==
Description:==
Pressurizer Nozzle Inner Radius Sections Material: SA-216 Grade wee Cast Carbon Steel Operating Pressure: 2235 psig Operating Temperature: 650 °F
2. Applicable Code Edition and Addenda
2004 Edition of ASME Section XI
3. Applicable Code Requirement
The 2004 Edition of ASME Section XI does not require examination of Class 1 Nozzle Inner Radius (NIR) Sections.
The Code of Federal Regulations Part 50.55a(2)(xxi) conditions the requirements of ASME Section XI Table IWB-2500-1, Examination Category B-D.
The condition mandates that the 1998 Edition of Section XI be used which requires Page 1 of 6
Serial No.18-199 Docket No. 50-281 examination of the Class 1 NIRs by Items B3.120 and B3.140.
Either an ultrasonic or enhanced visual examination from the inner diameter (ID) shall be performed.
4. Impracticality of Compliance
The pressurizer is covered with an insulation support structure (Figure 1 ). As can be seen, the support frame interferes with completion of a full volumetric examination around the circumference of the 10NIR and the 11 NIR nozzles to pressurizer safety valves. The examinations were further limited by the rough exterior surface on the nozzles which restricted adequate UT probe contact in several areas. Figures 2 and 3 illustrate the areas of limitation.
5. Burden Caused by Compliance
Total removal of the support structure at the mechanical connections is considered impractical due to the high dose rates in the pressurizer area.
Furthermore, this is not a viable effort when considering consequential disturbance of interconnected cross supports and the welded connections to safety and power operation relief valve supports. Any removal of the mechanical connections or forced spreading apart of components would create the risk of structural misalignment and distortion. Cutting the support could be necessary for removal; thus, destroying the support structure.
6. Proposed Alternative and Basis for Use
Components 1 ONIR and 11 NIR were ultrasonically examined using an NOE procedure that incorporates EPRI modeling report IR-2012-485 specific to the Surry Unit 2 pressurizer safety/relief nozzles. This modeling report details the required ultrasonic scan parameters which should be applied to achieve full coverage of the examination volume. Modeling report IR-2012-485 requires a combination of ultrasonic scanning both from the nozzle blend region and the pressurizer vessel head.
Different transducer angles, skews and wedge contours were used for the required scans. The prior ultrasonic examinations performed during the fourth ISi interval consisted of only scanning from the nozzle blend region; scanning was not required from the vessel head. The majority of the documented limitations occurred in the region on the vessel head which did not require scanning during previous intervals.
No alternative ultrasonic examination techniques would provide meaningful additional data on this cladded material for the examination volume not attained.
The pressurizer receives a visual (VT-2) examination every refueling outage as Page 2 of 6
Serial No. 18-1 99 Docket No. 50-281 required by Section XI, Table IWB-2500-1, Category 8-P, for Class 1 components performed at normal operating pressure and temperature.
Any effort to achieve greater coverage would be impractical creating risk of component damage or destruction and excessive personnel dose exposure.
The nozzle inner radius sections are not welds but actually cast material components. There have been no known through wall flaws in Class 1 nozzle inner radius section components.
It is proposed that the scanning percentage coverages obtained, as summarized for each NIR in Table 1, with no recordable indications be considered as meeting the Code requirements.
Table 1 - NIR Coverage Summary Component Scanning Coverage Obtained 10NIR 77.61%
11NIR 84.83%
7. Duration of Proposed Alternative
This proposed alternative is requested to meet the requirements for the fifth ten-year inspection interval for Surry Power Station Unit 2, which began May 10, 2014 and will end May 9, 2024.
Page 3 of 6
Serial No.18-199 Docket No. 50-281 Insulation Support Frame Safety/Relief Valve Supports Pressurizer Figure 1 - Pressurizer Insulation Support Structure Page 4 of 6 Insulation Support Rings
2-RC-lONIR Limitation Sketch and Coverage of Scan Surface Serial No.18-199 Docket No. 50-281 Report No: UT-17-018 Summary No: S2.B3.120.001 Pg. 2 of 2 Date: 5/ 11/ 2017
...s-nc1 Scan surt-Araa
- 39 m.*
V Scan Surface AfWa 54() 5 n
- an irfaec l.11n1tabo Totil Area 129 91 ui ln-...:ulallurt ~.!J lfl a Ar a-7 97 The scan surfaces (vessel) for 2-RC-1 0 IR were obstructed by the PZR Insulation Support Frame.
The total area of scanning surface 1s 580.32 sq in.
Th total r a of l1m1 ed scanning is 129.91 sq in Total percentage limited= (129 91/580 32) x 100 = 22 39%
Percentage of scan area scanned = 100%. 22 39% = 77 61 %
Figure 2 - 1 ONIR Page 5 of 6
2-RC-1 1NIR urfi *c In nt 1100
- 4.
loc ai*
Report No: UT 01 9 Summary No: S2.B3.120 002 Pg. 2of 2 Date: 5/ 112011 Limitation S etch and Cove e of Scan Surface o*
- e nd Sean Surface Are**
82,n *
~
es Scan Surf Area
- 540.5 In.*
Scan Surface um* at,on otat Area
- 88 02,n
- In h Serial No.18-199 Docket No. 50-281 The scan surfaces {blend and vessel) for 2-RC-11 NI R were obstructed by the PZR Insulation Support rame and also limited by a surface indentation which did not allow for adequate probe contact.
The total area of scanning surface is 580.32 sq in.
TIit: tu tc1I cti t:ct ur li1 11ilt:d :s1..c11111i11y i:s 88.02 :s4 i11.
Total percentage limit d = (88.02/580.32) x 100 = 15.17%
Percentage of scanned area scanned= 100% - 15.17% = 84.83%
Figure 3 - 11 NIR Page 6 of 6 Serial No.18-199 Docket No. 50-281 Relief Request S2-15-LMT-P01, Examination Category R-A, Preservice Weld Examinations Virginia Electric and Power Company (Dominion Energy Virginia)
Surry Power Station Unit 2
Dominion Energy Virginia Surry Power Station Unit 2 5th 10-Year Interval May 10, 2014-May 9, 2024 ASME XI Preservice Pipe Welds Relief Request S2-15-LMT-P01 Repetitive/Duplicate Relief Requests In Accordance with 10 CFR 50.SSa(g)(S)(iii)
Code Class 1 Serial No.18-199 Docket No. 50-281 Examination Category:
R-A, Risk Informed Piping Examinations Stainless Steel Piping Item Numbers:
Component Identification:
Material:
R 1.20, High Safety Significant not subject to a Degradation Mechanism Refer to Specific Table Refer to Specific Table
2. Applicable Code Edition and Addenda
2004 Edition of ASME Section XI
3. Applicable Code Requirement
Required Method: Surface and Volumetric for Preservice Requirements The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory Guide 1.147, Revision 17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.
10 CFR 50.55a(b )(2)(xv)(A) requires the following examination coverage criteria when applying Supplement 2 to Appendix VIII of ASME Section XI :
Page 1 of 9
Serial No.18-199 Docket No. 50-281 (1)
Piping must be examined in two axial directions, and when examination in the circumferential direction is required, the circumferential examination must be performed in two directions provided access is available.
(2)
Where examination from both sides is not possible on austenitic welds or dissimilar metal welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld.
10 CFR 50.55a(b)(2)(xvi)(B) requires that examinations performed from one side of a stainless steel pipe weld must be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single-side examinations.
To demonstrate equivalency to two-sided examinations, the demonstration must be performed in accordance with the requirements of Appendix VIII as conditioned by 10 CFR 50.55a(b)(2)(xvi)(B) and 10 CFR 50.55a(b)(2)(xv)(A).
4. Impracticality of Compliance
Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the volumetric examination coverage requirements for the subject welds due to the geometric configuration which limits the volumetric coverage that can be obtained.
For the austenitic weld, when the examination area is limited to one side of an austenitic weld, examination coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A),
proficiency demonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B), and full coverage credit may not be claimed. There are currently no Performance Demonstration Initiative (POI) qualified single-side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to U.S. nuclear applications. However, POI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single-side examination is performed on a best-effort basis.
The best-effort qualification is provided in place of a complete single-side qualification to demonstrate that the examiner's qualification and the subsequent weld examination are based on application of the best available technology.
The subject welds were examined with a manual ultrasonic (UT) technique using pulse echo UT instruments and search units to achieve the maximum examination coverage practical. Examinations were performed using personnel, equipment and procedures qualified in accordance with ASME Section XI, Appendix VIII, as implemented by the POI. No alternative welds were considered Page 2 of 9
Serial No.18-199 Docket No. 50-281 since these are preservice examinations for each specific weld that was reconstructed.
Specific examination coverage and component details are provided in Table P01.
Weld 1-20A Summary# S2.R1.20.125 This is a stainless steel ASME XI, Category R-A weld, Item R1.20, High Safety Significant not subject to a degradation mechanism. The weld configuration is stainless steel (ASTM 376 Type 316) pipe to a stainless steel (ASTM 351) valve.
This new weld also received volumetric examination by radiography and a liquid penetrant surface examination for preservice with no unacceptable flaws or indications detected.
When the system reached operating pressure and temperature, the weld was further inspected visually (VT-2) for through-wall leaks with none detected.
Weld 1-21A Summary# S2.R1.20.126 This is a stainless steel ASME XI, Category R-A weld, Item R1.20, High Safety Significant not subject to a degradation mechanism. The weld configuration is a stainless steel (ASTM 351) valve to stainless steel (ASTM 376 Type 316) pipe.
This new weld also received volumetric examination by radiography and a liquid penetrant surface examination for preservice with no unacceptable flaws or indications detected.
When the system reached operating pressure and temperature, the weld was further inspected visually (VT-2) for through-wall leaks with none detected.
Weld 2-24A Summary# S2.R1.20.132 This is a stainless steel ASME XI, Category R-A weld, Item R1.20, High Safety Significant not subject to a degradation mechanism. The weld configuration is stainless steel (ASTM 376 Type 316) pipe to a stainless steel (ASTM 351) valve.
This new weld also received volumetric examination by radiography and a liquid penetrant surface examination for preservice with no unacceptable flaws or indications detected.
When the system reached operating pressure and temperature, the weld was further inspected visually (VT-2) for through-wall leaks with none detected.
Weld 2-25A Summary# S2.R1.20.129 This is a stainless steel ASME XI, Category R-A weld, Item R1.20, High Safety Significant not subject to a degradation mechanism. The weld configuration is a Page 3 of 9
Serial No.18-199 Docket No. 50-281 stainless steel (ASTM 351) valve to stainless steel (ASTM 376 Type 316) pipe.
This new weld also received volumetric examination by radiography and a liquid penetrant surface examination for preservice with no unacceptable flaws or indications detected.
When the system reached operating pressure and temperature, the weld was further inspected visually (VT-2) for through-wall leaks with none detected.
Table P01 - Preservice Examinations Drawing / Line# / ID Weld Pipe Op. Pressure Pipe Coverage Limitation System / Class Material
/Op.
Dia.
Thickness/
Achieved
/ Results Fig.
ASME Category Temperature Material 11548-WMKS-Stainless 0.44" 50%
Single-0125A1 /4-RC-314/
Steel Stainless sided, Pipe 1-20A ASTM 2235 psi 4"
Steel 14.8%
to Valve, Reactor CoolanU1/
376 543 °F Type 316 Best Effort NRI*
R-A Type 316 11548-WMKS-Stainless 0.44" Single-0125A1 / 4-RC-314 /
Steel 50%
1-21A ASTM 4"
Stainless
- sided, Reactor Coolant/1/
376 2235 psi Steel 14.8%
Valve to R-A Type 316 543 °F Type 316 Best Effort Pipe, NRI*
11548-WMKS-Stainless 0125A1 / 4-RC-315 /
Steel 0.44" 50%
Single-2-24A ASTM 2235 psi 4"
Stainless sided, Pipe Reactor Coolant/ 1 /
376 543 °F Steel 14.8%
to Valve, R-A Type 316 Type 316 Best Effort NRI*
11548-WMKS-Stainless 0.44" Single-0125A1 / 4-RC-315 /
Steel 2235 psi Stainless 50%
- sided, 2-25A ASTM 543 °F 4"
Steel Valve to Reactor Coolant/1 /
376 Type 316 14.8%
Pipe, NRI*
R-A Type 316 Best Effort
- No Recordable Indications
5. Burden Caused by Compliance
Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow full examination from both sides of the weld.
This option to rebuild components is considered impractical and would cause unnecessary radiation exposure.
Furthermore, plant equipment could be impacted in a detrimental manner.
Page 4 of 9 1
2 3
4
6. Proposed Alternative and Basis for Use
Serial No.18-199 Docket No. 50-281 Attach ment 2 The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques. With the incorporation of the POI for Supplement 2, demonstration of best effort coverage was made for single-sided examination from the accessible side of the austenitic steel welds. The best-effort coverage achieved is provided in Table P01. No indications were noted for any of the areas volumetrically examined. The four welds were surface examined with a liquid penetrant test achieving 100% coverage of the welds with no indications. The welds were volumetrically examined by radiography with no unacceptable flaws detected. Upon return to service the welds received a visual examination (VT-2) with no through-wall leakage detected.
The components are monitored for through-wall leakage as part of the ASME XI System Pressure Test Program and receive a visual (VT-2) examination every refueling outage as requ ired by Section XI, IWB-2500-1, Category B-P, for Class 1 components.
None of the pipe or weld material is constructed with Alloy 600/82/182 materials; therefore, there are no primary water stress corrosion cracking (PWSCC) concerns.
Based on the volumetric coverage obtained by ultrasonic examination, the visual (VT-2) examinations performed upon return to service, the surface examinations (liquid penetrant) and ful l volumetric examination (radiography), all with acceptable results, it is reasonable to conclude that no unacceptable flaws exist in the new welds. These proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.
Therefore, Dominion Energy Virginia requests relief in accordance with 10 CFR 50.55a(g)(5)(iii).
7. Duration of Proposed Alternative
This proposed alternative is requested to meet requirements for the fifth ten-year inspection interval for Surry Power Station Unit 2, which began May 10, 2014 and ends May 9, 2024.
Page 5 of 9
Supplemental Report Summary No.: S2.R1.20.125 Serial No.18-199 Docket No. 50-281 Report No.: _ _;u...;r_.1...;s_.1...;4..;.6_
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Summary No.: S2.R1.20.126 Supplemental Report Serial No.18-199 Docket No. 50-281 Report No.:
UT-15-148 Page:
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Sketch or Pholo:
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14.IM Figure 2 - Weld 1-21A Page 7 of 9
~Dominion Supplemental Report Summary No.: S2.R1.20.132 Serial No.18-199 Docket No. 50-281 Report No.:
UT-15-141 Page:
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IU" Figure 3 - Weld 2-24A Page 8 of 9
~
ill'Dominion Supplemental Report Summary No.: S2.R1.20.129 Serial No.18-199 Docket No. 50-281 Report No.:
UT-15-144 Page:
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Sketch or Photo:
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14.8" Figure 4 - Weld 2-25A Page 9 of 9