ML19320B324

Forwards Addl Info Requested by NRC Re Preservice Insp Program

ML19320B324
Person / Time
Site:	Farley
Issue date:	07/03/1980
From:	Clayton F ALABAMA POWER CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
References
NUDOCS 8007100177
Download: ML19320B324 (25)

Text

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Alabama Power Company 600 North 18th Street Post Offica Box 2641 Birmingh;m. Alcbam:3 35291 Telephone 205 323-5341 k

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(;,bfie'?,";it Alabama Power the southem e'ectrc system July 3, 1980 Docket No. 50-364 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washin3 ton, D. C.

20555 Attentior:

Mr. A. Schwencer Gentlemen:

JOSEPH M. FARLLT NUCLEAR PLANT - UNIT 2 PRESERVICE INSPECTION PROGRAM Your letter of June 17, 1980 requested additional information on the subject issue. This information is provided in the enclosure.

Should you have any questions, please advise.

Yours very truly, d i).;24hM- {

2-n K. L. Clayton, Jr.

3 Lf4 F

RWS:de Enclosure cc:

Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. L. L. Kintner Mr. W. H. Bradford

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8 o 07seo/77 4

ENCLOSURE Response to NRC Request for Additional Information J

Reccest:

1 21. 2 Your response to Question 121.1 does not provide sufficient information to complete our evaluation regarding your preservice inspection program.

For each component which cannot be completely examined in accordance with ASME Code Section XI requirements, submit a relief request in accordance with the guidelines in Appendix A of Question 121.1 Specific information should include the extent of the Section XI requirements that were performed, alternative nondestructive examin clons, and description of the measures required to perform the required examinations.

In the case where relief is requested for piping sy: tem welds, provide a list of the welds that cannot be completely examined to Section XI requirements.

Res conse:

Relief requests are attached for each component (s) which cannot be completely examined during the preservice inspection in accordance with the requirements of the ASME Code Section XI,1974 Edition with Addenda through Summer 1975.

During the performance of the preservice i

inspection, it was determined that the Reactor Vessel lowerrhead-to-shell circumferential weld is accessible and will receive a full Section XI examination. Consequently, the existing Note 1 in FSAR Table 5.2-33 will be deleted in the next amendment.

Recuest:

Where construction code examinations are substituted for preservice examination requirements, in accordance with IWB-2100b and IWC-2100b in Section XI, identify the specific construction code NDE method.

Resconse:

The components and the specific construction code NDE method are identified below:

Component Const. Code NDE Method RCP Seal Housing Bolts Surface (MT) and Visual RCP Main-Flange Bolts Surface (MT), Visual, UT Charging Pump Casing Radiograph Pressure Retaining Welds Pressurizer Safety Line Radiography and Surface Welds (PT)

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Request:

Identify the specific parts of the ECCS and RHR5 where IWC-1220(a) and (c) exerotions are used and a preservice examination was not performed.

Resoonse:

We have applied IWC-1220(a) to the following ccmponents:

1) the Refueling Water Storage Tank (RWST),

2) suction piping from the RWST to the HHSI pumps,

3) suction piping from the RWST to the RHR/LHSI pumps,

4) suction piping from the RWST to the CTMT Spray pumps.

In all cases the design temperatures are less than 2000F and design pressures are less than 275 psig.

We have applied IWC-1220(c) to the following components:

1) the safety injectionaccumulators and associated Class 2 piping and

2) the boron injection tank and associated Class 2 piping exceeding 4 inches in diameter.

The accumulators are sampled for boron concentration at least once per 31 days in accordance with the plant technic.al specification 4.5.l(b). The boron injection tank is sampled for baron concentration at least once per 7 days in accordance with plant technical specification 4.5.4.1(b).

Reouest:

1 21. 3 For the preservice inspection program the following information is necessary to clarify specific aspects of the FSAR and additional infomation supplied in your letter of April 21, 1980:

(1) A list of all welds, the percentage of volume which can be examinad, and alternate examinations to be performed for which Notes 9 and 10 in Table 5.2-33 and Notes 5 and 6 in Table 5.2-34 apply.

Resoonse:

This information is provided in the attached Relief Requests (D),

(J), and (K).

,Recuest:

A

.(2) The type and extent of examination of the nozzle inner radii region of the reactor vessel, steam generator, and pressurizer, and the nozzle to safe end welds in the steam generator.

Resconse:

The ncz:le inner radii on the reaecor vessel will be ultrasonically exarf r.ed in sc:ordan:e with the requirements of Section XI. The steam genera:c s are integrally east with the head and do not contain any welds. Therefore, tse inner radii of the steam generators are not required to ':e ins:e:ted. The information regarding the nozzle, inner radii re;i:n of the steam generator nozzle-to-safe-end welds and the pressu-i:er no:zle-to-vessel welds are provided in Relief Requests (0) and (3) res;ectively.

Recuest:

(3) A list cf all welds in branch pipe connections exceeding 6 inches in diame:er for which relief is requested. A detailed description or draaf1g depicting inaccessibility and estimates of the extent of exa.mina:ian as a percentage of total weld volume are required.

Resoonse:

This infomation is provided in Relief Request (F).

Isometric drawings sheding these welds were included in our letter dated April 21,1930.

e Recuest:

(4) Exclusic1 si:es in the piping pressure boundary you have used based on Ik'B-122]b of Se: tion XI.

Support these sizes with docu.entation if they are not otherwise exempted.

Resconse:

Components, ta'.vas, and ?iping (and their supports) one-inch nominal pipe si:e and 3: taller hate been exempted under IWB-1220(b)(3). No other exclusio s bar:d on IW3-1220b have been taken.

Recuest:

(5) A list cf all Class 2 welds which cannot be examined volumetrically due tc tain aa:1 thickness.

Res::cese:

This infocati:n is provided in Relief Request (I).

Recuest:

(6) A relief re:;est for the charging pump casing welds.

Response

Shop data, in the fen: of radiography, will be utilized for the preservice inspe:tien as allowed by IWC-2100(b). No relief request is r.eeded.

Request:

(7) A discussior, cf the impact on plant safety of the omission of NOE or. r.3:zle te vessel welds of the residual heat exchanger, as referen:ed in Note 3, Table 5.2-34 of the FSAR, and of pressurizer safety weids 7, 9,.10, and 11 in additional information of your April 21,1930 letter.

Response

The RER heat exchangers are identical.

In a letter dated December 7,1979, frta the NRC to Alabana Power Company, the NRC stated, "Evaluaticn: The design of the residual heat exchangers is such that it is not p:ssible to perform the required volumetric examination.

However, we have dstentined that the other (head to shell and shell to tubesheet}-weld exacination should provide some indication of the integri:y of the nozzle to vessel welds".

In addi:icn, the welds will be visually inspected for evidence of i-leakage as stated in Relief Request (H).

The pressurizer safety welds have been renumbered as shown in Figure 1.

The ir.a:cessible welds are 29, 31, and 32.

Field data in the form of radiography and dye penetrant will be utilized for the preservice inspection as allowed by IWC-2100(b).

Recuest:

(8) The percentage of weld volumes in the regenerative heat exchanger which can be examined volumetrically.

l Resconse:

1 This information is provided in Relief Request (L).

J N

RELIEF REQUEST (A)

(Revised Note 1, FSAR Table 5.2-33)

CC"FT;ENT:

Pressuri:er and primary portions of the CODE CLASS; 1 Steac Generators.

EXAMINATION REQUIREMEhT:

Requirement #1:

The 1974 Edition of Section XI, I-3121 states, " Material from which the block is fabricated shall be from the component, frca either a nozzle dropout or a prolcngation."

Requirement #2:

The Sammer 1975 Addenda of Section XI, I-3121 states "Paterial from which the block is fabricated shall be from one of the following:

(I) the component ncz:le dropout; (2) the component prolongation; or (3) when it is not possible to fabricate the block from material taken from the component, it may be fabricated frca a material of a specificationincluded in the applicable examination volcmes of the component. The acoustic velocity and attenuation of such a block shall be demonstrated to fall within the range of straight beam longitudinal wave velccity and attenuation found in the unclad component."

3 ASIS FOR RELIEF:

Requirement il car.not be ret. At the time the components were built, no excess

..i material was saved for fabrication of calibration blocks.

e-Requirement #2 canact be cet because tne Code assumes an "unciad ccmponent" when in fact all the components are clad on the inner surfaces.

ALTERNATIVE EXAMINATICN:

Calibration blocks recuired for the examination of welds in these vessels will be fabricaced frca material of the same specification, product form, and heat treatment as or.e of the materials being joined as allowed by Article T-434.1.1 in the Kir.ter 1976 Addenda of Section V of the ASME Soiler and Pressure Vessel Code which states, " The material from which the block is fabricated shall be from one of the folicwin - (1) nozzle drop out from the component; (2) a component prolor.gaticr; or 3) material of the same material specification, product form, and reat creatr.ent as one of the materials being joined.

o RELIEF REQUEST (3)

(tiote 5. FSAR Table 5.2-33)

COM30f EfiT:

Pressuri:er CODE CLASS: 1 EXAMIf ATI0ft REQL'IREv.E',T:

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Tables IW3-2500 Categ:ry E-C and IWB-2600 Item B2.2 require volumetric examination of the no:zle-to-vessel welds and adjacent base metal for one wall thickness on l

each side of the weld.

j-BASIS FOR RELIEF:

i The geometric configurationof the nozzle prevents ultrasonic examinations from being performed froc. :he nozzle side of the weld to the extent required by IWB-2600. Exar.inaticn will be performed from both the weld and shell surfaces.

The nozzle configuratfor. is shown in Figure B2.2 ALTEPf:ATIVE ETAMIf;ATICri:

One hundred percart of the weld, the heat affected zone, and the required amount of base metal on the shell side of the weld will be examined. Base metal on the nozzle side of the weld will be examined to the extent practical,~which is 5'

approximately 2E percent.

In addition, the weld will receive surface examination (MT) on those areas not scanned by UT.

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RELIEF REQUEST (C)

(Note 6, FSAR Table 5.E-33)

COMPONENT: Steam Generators (3)

CODE CLASS: 1 EXAMINATIC.1 REQL'IREFEhT:

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Tables IW3-2503 Cate; cry 2-F and IWB-2600 Item B3.3 require surface and volumetric examinatf or.s of the nozzel-to-safe-end welds and the adjacent base metal for one wall thickness on either side of the welds.

d.tSIS FOR RELIEF:

Examination of the steam ganerator primary nozzle safe-end-tc-pipe welds is limited by the nczzle geometry and surface condition, and by the limited surface creparatien on the pipe side of the weld. The surface on the pipe side o'.he weld, which is a cast elbow, is machined for a distance of appr.oximately Sk inchas fr:m the edge of the weld.

Ultrasonic examination is limited to this dis:ance from the edge of the weld.

Examinations can be performed on the surfa:e of the weld but are severely limited from the nozzle side by the configuratan of weld build up and weld overlay. Weld configuration is shown in Figure E3.3 k'

ALTERNATIVE EXAMINATIC'i:

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Ultrasonic examinatiers will be performed from both the pipe and weld surface.'

as allowed by T-5?? of Sec-ion V. All of the weld metal, including the weld root will be inspecied.

Since no UT can be performed on the nozzle side of the weld, the extent cf examination is limited to approximately 90 percent of the code-required a ea. Surface examinations will be performed on essentially 100 percent of the recaired area.

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• RELIEF REQUEST (D)

(Notes 9 & 10, FIAR Table 5.2-33)

C0t PONENT:

Pipir.g Pressure Boundary CODE CLASS: 1 EXA!!INATION REOL*IEEME!iT:

Tables IWB-2500 Categcry B-J and IWB-2500 Item B4.5 require volumetric examination of circumferer.tial bat welds plus the adjacent base material for a distance of one wall thickr.ess on eitner side of the weld.

BASIS FOR RELIEF:

Instances occur w'.ere pipe welds are between fittings, such as elbow-to-valve r

or flange-to-elbow welds. In such instances access may be severely limited and ultrasenic examination cannot be performed on 100 percent of the volume of the weld and tr.e heat affected zone.

ALTERNATIVE EXAMIMTIC1:

Ultrasonic examinatf or.s will be performed to the extent practical and will be supplemented by surface examination.

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Welds which will recuire s; poler. ental surface examination, along with,,the estimated extent cf vclume:ric examination are as follows:

Loop 1 RTC retarn, weld #15 - 40%

Loop 1 Cold Leg SIS, weld #8 - 60%

Pressuri:er Spray, welds #42 - 70% and #43 - 70%

Loop 3 RTC Return, weld #8 - 60%

Pressurizer Relief, weld #14 - 50%

Pressurizer Safety, welds #2 - 70%

1. 5 - 80%

1. 12 - 70%

e16 - 80%

1. 20 - 80%

1. 24 - 70%

1. 27 - 80%

Pressurizer Safety welds #29, 31, and 32 are inaccessible. However, field data in the fonn of raciegraphy and dye penetrant will be utilized for the preservice inspection as allcwed by IWC-2103(b).

RELIEF REQUEST (E)

(t;ote 11, FSAR Table E.2-33)

COM.p0NENT:

Integrally-Welded Supports CODE CLASS: 1 EXAMINATION REQUIF.EMENTS:

Tables IWB-2500 Categ:ry 2-K-1 and 38-2600 Item B4.9 require volumetric examination of the weld, the base' metal beneath the weld and base metal along the support attachment rc. amber for integrally-welded supports.

BASIS FOR RELIEF:

The piping systems' ir.tegrally-welded supports are attached to the pipes by fillet welds. The cor. figurations of these welds are such that examinations cannot be performed to the extent required by IWB-2600. Only the base material of the pipe wall and de base metal of the support attachment can be volumetrically examined.

ALTERfMTIVE EXAMINATICN:

Surface examinatien will be perfor.ned on the integrally-welded attachments to supplement the volumetric examination.

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RELIEF REQUEST (F)

(Note 12, FSAR Table 5.2-23)

COMPONENT:

Piping Pressure 3our.dary CODE CLASS: 1 EXAMINATION REGUIEEME!T:

Tables IWB-2500 Categ:ry E-J and IWB-2603 f tem 84.6 require volumetric examination

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of br:nch pipe connec-icn welds of branch connecticns exceeding 6-inch diameter.

BASIS FOR RELIEF:

The geometric configuratica of the welds as shown in Figure 84.6 prevents ultrasonic examinatior.s from. being perforced from the weld surfaces.

ALTERNATIVE EXAMINATIC.'l:

Volumetric exacicatiens will be performed to the extent practical from the pipe and nozzle surfaces acjacent to the weld. Surface examination of the welds will be perfonned to supplement the volumetric examination.

The welds to which this relief request applies, along with the estimated extent of volumetric examination, are as follows:

N Reactor Coclant Loop #1, weld #16BC - 80%

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Reactor Coolant Loop #1, weld #21BC - 80%

Reactor Coelant Loop 32, weld pl6BC - 80%

Reactor Coolant Loop 42, weld 721BC - 80%

Reactor Coclant Loop #3, weld #16BC - 80%

Reactor Coclant Loop #3, weld #21BC - 80%

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REACTOR COOLANT PIPE (CAST AUSTENITIC STAINLESS STEEL)

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RELIEF REQUEST (G)

(tiew fiote 13, FSAR Tatie E.2-33)

COMP 0 fief!T: Pressurizer and Primary Portions of the CODE CLASS: 1 Steam Generator EXAf!ItiATIOfi RE0CIF.Ev.E!T:

I-3122 requires that if the component is clad, then the calibration block shall be clad.

BASIS FOR RELIEF:

The calibration blocks for the ultrasonic examinations of the referenced components are not clad. However, thela:s of cladding does not affect the ca.ibration of the ultrasonic equipment. Caly the top (0.D.) portions of the blocks are actually used in the calibraticas. Soe:ifically, three side-drilled holes, at depths of k T, 4 T, and 3/4 T are utilized.

The I.D. of the blocks do contain a 2% T notch. However, it is only used for reference. The acplitude response from the notch is not required to be above a certain minimum.

In fact, the amplitude is not even recorded.

Cladding the blocks could cause the amplitude response to either increase or decrease.

In cither case, the calibration would not be affected.

.r-ALTERflATIVE EXAMItiATIC'l:

The existing unclad calibration blocks, mquired for tt,a examination of welds in these vessels, will be utilized for the calibration of ultrasonic equipment.

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RELIEF REQUEST (H)

(fiote 3 FSAR Table 5.2-34)

COMP 0fiENT:

Residual Feat P.ecoval (RHR)

C9DE CLASS: 2 Heat Exchangers (2)

EXAMINATION REQUIREMEhT:

Tables IWC-2520, Categvj C-3 and IWC-2600, Item C1.2 require volumetric examination of the no:21e-to-vessel welds.

BASIS FOR RELIEF:

The RHR Heat Exchanger noz:le-to-vessel welds are covered by reinforcement rings and are not accessible for examination. The configuration is shown in Figure C1.2.

ALT $RfiATIVE EXAMI?MTICN:

The nozzles will be subject to visual inspection for evidence of leakage.

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NOZZLE TO VESSEL WELD

.75" THICK BY 3" WIDE REIN FORCEMENT PAD

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.75" THICK SHELL AND HEAD Note: A!! materials and welds are r: sinless steel.

RES; DUAL HEAT REMOVAL HEAT EXCHAi:GER NOZZLE TO VESSEL CONFIGURATION Figure - C1.2 2S34 c

RELIEF REQUEST (I)

(Note 4, FSAR Table 5.2-34)

COMPONENT: Seal Water Heat Exchanger CODE CLASS: 2 Letdown Re7 eat Heat Ex: hanger Reacter Co31 ant.:llter Seal kater Return Filter EXAMIfMTION REQUIREEhT:

Tables IWC-2520 Categcry C-A and IilC-2500 Item C1.1 require that twenty percent of the total length of tne vessel head-to-shell and flange-to-shell welds be volu.etrically examined.

BASIS FOR RELIEF:

The thickness of the raterials utilized for the construction of these components (0.165 to 0.188 ir.:hes) is such thatmeanincN1 results could not be expected with ultrasonic examiration.

ALTERNATIVE EXAMINATIC'l:

The required twenty percent of these welds will be examined by surface and 5

visual methods.

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RELIEF REQUEST (J)

(Notes 5 & 6, FSAR Tatie 5.2-34)

CODE CLASS: 2 COMPONENT:

Piping pressure Boundary EXAMINATION REQUIF.EME!J:

Tables IWC-2520, Category C-3 and IWC-2600, Item 2.1 require volumetric examination of circumferential bu:t welds plus the adjacent base material for a distance l

of one wall thickr.ess on either side of the weld.

BASIS FOR RELIE. :

The arrangement and details of the Class 2 piping system and components were designed and fabricated before the examination requirements of Section XI of the Code were fornali:ed and some examinations are limited or not practical due to gecmetric configuratior, or accessibility. Generally these limitations exist at all fitting-to-fit-tr.g welds such as elbow-to-tee, elbow-to-valve, reducer-to-valve, etc. where geonetry conditions preclude ultrasonic coupling or access for i

the required scan length.

t ALTERNATIVE EXAMINATICN:

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Ultrasonic examinations will be performed to the extent practical from the pipe and weld surfaces and be supplemented by surface examinations on those welds where 100 percer.t of the weld and heat affected zone have not been volumetrically examined. Welds requiring supplemental examination, along with the estimated extent cf vclumetric examination, are as follows:

RMR, wel ds #31 - 50%

1. 32 - 50%

1. 14 - 90%

1. 11 - 30%

1. 20 - 30%

pl8 - 50%

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RELIEFREQUEST(X)

(fiote 5, FSAR Table 5.2-34)

COMPONENT: Piping Fressure Boundary CODE CLASS: 2 EXAMINATION REQUIF.E!'E!.T:

Tables IWC-2520, Categories C-F and C-G, and IWC-2600, Item C2.3 require volumetric examinatf or. cf bran:h connection weld joints when the branch connection exceeds 4-inch diameter.

BASIS FOR RELIEF:

The geometric configuratic, of the welds prevents ultrasonic examinations from being performed from the wsld surfaces.

ALTERNATIVE EXAMIMTIC 1:

Volumetric examinatf ors will be performed to the extent practical from the pipe surfaces adjacent to the welds.

Surface examinations of the welds will be per-formed to supplement the limited volumetric examinations. The welds to which this relief request applies, alang with the estimated extent of examination, are as follows:

,e Main Steam, welds #4 80%

1. 4 80%

1. 1 80%

1. 1 80%

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1. 1 80%

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1. 1 80%

1. 1 80%

1. 1 80%

1. 1 80%

1. 1 80%

1. 2 80%

1. 2 80%

1. 2 80%

1. 2 80%

1. 2 80%

1. 2 80%

1. 2 80%

1. 2 80%

1. 3 80%

1. 3 80%

1. 3 80%

1. 3 80%

1. 3 80%

1. 3 80%

1. 3 80%

1. 3 80%

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RELIEF REQUEST (L)

(Note 7, Table 5.2-34; CODE CLASS: 2 COMPONENT:

Regenerative Heat Exchanger EXAMINATION REOUIF.EME'iT:

Tables IWC-2520 Categ:ry C-A and IWC-2600 Item C1.1 require volumetric examination

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of 20% of the heat ex: hanger head-to-shell and chell-to-tubesheet welds.

BASIS FOR RELIEF:

The regenerative heat exchanger shell is fabricated from centrifugally-cast austenitic steel caterial which limits ultrasonic examination as required by IWC-2500 to the half-node tectniques. The geometric configuration of the weld surface and the location cf adjacent nozzles and supports provide limitations to the extent of the exar.ina-icns coverage.

ALTERNATIVE EXAMINATION:

The code-required 20% of each circumferential weld will be inspected using the hal f-node technique. The spacing of the inspection areas will be as stated in Relief Request (N).

Surface examinations will be performed to supplement the volumetric examinatio.s.

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RELIEF REQUEST (M)

(t;ew Note 10, FSAR Table 5.2-M)

COMP 0NENT: ChargingPumps(3)

CODE CLASS: 2 EXAMINATION R QUIREMENT:

E Tabl es IWC-2520, Category C-E-1 and IWC-2600, Item C3.3 re:;uire surface examina-tions of 100 percent of the major load bearing elements of the integrally-welded supports.

BASIS FOR RELIEF:

D':: to component and support designs, approximately 20 percent of each integrally-welded support is inaccessible for examination.

5 ALTERNATIVE EXAMItiATICN:

The accessible portior.of each support will receive visual and surface examinations.

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RELIEF REQUEST (N)

(fiew tiote ll, FSAR Table 5.2-34)

COMP 0fiENT:

Regenerative Heat Exchanger CODE CLASS: 2 Excess Letdown Heat Exchanger Letdown Reheat Heat Exchanger

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EXA'tIrlATION REQUIREMENT:

Tables IWC-2520, Category C-A and IWC-2600, Item C1.1 require volumetric examinations

" uniformly distributed among three areas around the vessel circumference".

BASIS FOR RELIEF:

The location of nozzles and supports provides limitations to the extent of examination coverage.

Consequently, the requirement for three uniformly distributed areas cannot be met.

ALTERNATIVE EXAf11 NATION:

One or two areas will be inspected, as accessibility permits, instead of the required three areas. The required 20 percent of each circumferential weld will be volumetri-F cally examined except where material thickness precludes ultrasonic testing as stated in Relief Request (I).

RELIEF REQUEST (0)

(New Note 12, FSAR Table 5.2-34)

COMPONENT: Secondary portions of the Steam Generators (3)

CODE CLASS: 2 EXAMINATION REQUIREMENT:

The 1974 Edition of Section XI, I-3121 states, " Material from which the block is fabricated shall be from the component, from either a no:zle dropout or a prolonga tion."

BASIS FOR RELIEF:

At the time the components were built, no excess material was saved for the fabrication of calibration blocks.

ALTERNATIVE EyAMINATION:

Calibration blocks required for the examination of welds in these vessels will be fabricated from material of the same specification, product form, and heat -

treatment as one of the materials being joined as allowed by Article T-434.1.1 in the Winter 1976 Addenda of Section V of the ASME Soiler and Pressure Vessel Code.

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