ML19332F124

Forwards Response to NRC 890803 Request for Addl Info Re Review of Second 10-yr Inservice Insp Program,Per 891005 Ltr

ML19332F124
Person / Time
Site:	Farley
Issue date:	12/07/1989
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8912130436
Download: ML19332F124 (8)

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1' 4 ~ Alabama Powe' r Companyi ,

40 inverness C,nter Parkway - '

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Post Office Box 1295 - j

, . Birmingham, Alabama 35201.

Telephone 205 868 5581 - -1 W. G.' Hairston, Ill -

< Senior Vice Presldent nueear Operaan. - Nabama Power-

'1 December 7, 1989 tte southem elecmc system L ,

1CCFR50.55a(g) g e 3 V "

Docket No.:50-348:

U.lS.1 Nuclear Regulatory Commission f  : Attentions'? Document Control Desk Vashington, D. C. 20555 .

1 Gentlemen f: , Joseph H. Farley Nuclear-Plant - Unit 1 m

" Response.to the NRC Request for Additional.Information  ;

for-the Inservice Inspection Program

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.By letter. dated August 3, 1989, the NRC requested Alabama Power Company to provide additional information pertaining-to the reviev of the Unit 1-Second Ten-Year Inservice Inspection (ISI) Program. Revision 0 of this, u l

program was submitted to the NRC by letter dated-November 23, 1987. The NRC granted interim-approval of the reliefs requested'in Revision 0 by letter dated December 10, 1987. Revisions 1 and-2 of-the program including

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two additional: relief requests were submitted ~by letter dated

~ September 9, 1988.

Alabama Power Company responded to the NRC's Request for Additional Information, Enclosure 1 (for Unit 1) by~1etter dated October 5, 1989. In 0 two instances, one involving the acceptability of the existing ultrasonic

' , Jealibration blocks for performing 1983 Code examinations and the'other

.regarding hydrostatic testing of portions of the service water, component cooling water, chemical and volume control, spent fuel pool cooling and-

. reactor makeup systems, a substantial review effort was necessary to provide a suitable response. Enclosed for your review is Alabama Power

= Company's final response which summarizes the results of these additional

-reviews.

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Page 2 14[h;[, :y:s. -U.'S.: Nuclear Regulatory Commission c p 37, ),,

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> c If.there are any-questions or if additional informatior,is needed, please.

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advise.

i Respectfully submitted, ALABAMA POWER COMPANY.

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,L V. G. Hairston, III.

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. j ENCLOSURE Joseph M. Farley Nuclear Plant - Unit 1 Response to the NRC's Request for Additional ,

Information for the Inservice Inspection Program Alabama Power Company's initial response to the NRC's Request for Additional Information (RAI) was provided on October 5, 1989. Additional information is i herevith submitted which completes all items requested by the RAI. The following items correspond to Enclosure 1. Item 2 of the NRC's RAI J. RC.ief Requests RR-5 and RR-6 Provide the following information with regard to ISI calibration standards:

NRC Request:

For each of the subject relief requests, provide technical justification as to why obtaining the appropriate calibration block is impractical.

APCo Reply: ,

Relief Request RR-5 pertains to calibration block dimensions for piping and thin-valled vessel examinations. In general, dimensional design for these calibration blocks was based on the existing codes and standards in use at  :

the time of fabrication. The existing calibration blocks were fabricated '

from materials representative of the specifications in use at that time.

These blocks were utilized for preservice and inservice examination and provide an important reference from which to evaluate future examination ,

results. Further review has indicated that while under the present Code, dimensional deviations exist between the component and calibration block, these differences are inconsequential to the examination results and would in most cases result in conservative examination results. Fabrication of l

new calibration blocks, solely for the purpose of achieving dimensional congruity vitt the component vill no: in Alabama Power Company's judgment improve examination quality. The consistent use of calibration standards l

between the preservice and inservita examinations performed to date and ,

future examinations vo dd be lost if new calibration blocks were utilized.

Calibration block ALA/APR-33 is used for the examination of cast austenitic stainless steel reactor coolant loop piping materials in the hot, cold and

• the crossovet legs which have different diameters and thicknesses. The calibration block is the same nominal diameter as the hot leg, but is of smaller diameter than the crossover leg piping and larger diameter than the cold leg piping. Use of the calibration block for examination of the larger crossover leg piping is conservative since calibrating on a smaller diameter calibration block and examining a larger diameter component would tend to decrease ultrasonic attenuation. The calibration block thickness differs from that of all three legs: however, it is considered representative since its thickness is close to the average thickness for all three legs. Code Case N-461 allows the use of calibration blocks which are within plus or minus 25% of the pipe vall thickness which vould i envelope the loop piping thickness differences. The ASME has approved this Code Case ^and the NRC is considering incorporation of N-461 into a future revision of Regulatory Guide 1.147. Regardless of the differences in diameter and thickness, the NRC has reviewed and accepted the special

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- Enclosure - Unit 1  ;

Page 2 i

examination techniques which Alabama Power Company utilizes for reactor l coolant loop examination as permitted by Section XI, Paragraph IVA-2240. t This reviev included an attenuation comparison of the calibration block and the coolant loop piping. It was concluded that the calibration block vas representative of the installed piping and would therefore provide a conservative examination. l Calibration block ALA-24 has a nominal thickn2ss greater than the examined  ;

piping. Use of a thicker calibration block is conservative since examination of a thinner component vould tend to decrease ultrasonic ,

attenuation. As discussed above, NRC approval of Code Case N-461 vill permit the use of this calibration block since the calibration block ,

thickness is within plus or minus 25% of the component thickness.

Calibration block ALA-25 differs in both thickness and diameter from the 16 -

inch diameter reducer which connects the 14 inch diameter feedvater piping to the steam generator nozzle. The reducer is schedule 100 with a nominal thickness of 1.031 inchest however, in the area of interest it is machined to a nominal thickness of 0.758 inch to match the steam generator nozzle thickness. Therefore, use of the .750 inch thick calibration block vill provide a representative examination of the nozzle to reducer veld.

Again, application of Code Case N-461, once NRC approval is obtained, would permit the use of this calibration block. The calibration block is 14 inches in diameter and is used for examining the 16 inch diameter reducer to steam generator nozzle veld. As discussed above, use of-this >

calibration block is considered conservative since calibration on a smaller diameter calibration block and examination of a larger diameter component l vould tend to reduce ultrasonic attenuation.

Calibration block ALA-5 vas fabricated from 8 inch diameter stainless steel pipe and is utilized for examination of a 9.5 inch diameter component.

Calibration on a smaller diameter calibration block for examination of a larger diameter component is considered conservative since it would tend to decrease ultrasonic attenuation. Regardless, APCo utilizes enhanced ultrasonic examination techniques on all stainless steel components. This 1 technique includes requirements that the refracted angle be recorded for ,

each examined component. In addition to the required 45' examination, a 60' examination is also utilized and both are performed at increased sensitivity by adjusting the gain to an average noise level of 10 percent >

of full screen height. This enhanced examination technique more than adequately compensates for any mismatch between the calibration block and the examined component.

Calibration blocks ALA-31 and ALA-32 are fabricated from stainless steel plate and are used to examine thin-valled vessels ranging from 22 to 84 inches in nominal diameter. Use of the flat calibration block is considered acceptable based on guidance from the ASME Code,Section V, Articles 4 and 5, which state that for diameters greater than 20 inches, a block of essentially the same curvature or alternately a flat basic calibration block shall be used. Given the large diameter of the components being examined, the flat calibration block is considered to be accepteMo. As discussed above, use of the enhanced ultrasonic examination technique more than aiequately compensates for any mismatch between the calibration block and the curvature of the examined component.

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. o Enclosure - Unit 1 Page 3 Calibration block ALA-23 is fabricated from carbon steel plate and it is >

used to examine 34.5 inch diameter piping. Given the guidance from Section V for the use of flat basic calibration blocks where the component diameter exceeds 20 inches, the flat calibration block is considered acceptable. '

Relief Request RR-6 pertains to calibration block materials for piping and thin-valled vessel examinations. After a substantial comparison of the ,

calibration block and component materials and a review of the examination requirements of Section XII Appendix III, Paragraph III-3411 as clarified by ASME Code Interpretation XI-1-86-61, it was found that all calibration block materials are in compliance, therefore, relief request RR-6 it not required and vill be deleted from the ISI Program with the next revision.

NRC Request Relief Request RR-5: Identify the calibration blocks for which relief is requested and provide information with regard to the actual vall thickness ,

and curvature differences between the calibration blocks and the components to be examined. 6 APCo Reply: '

Attachment 1 is a list of the calibration blocks for which relief from thickness and/or curvature requirements is requested. This list includes the calibration block thickness or diameter, as appropriate., the examined component thickness or diameter and the material.  :

NRC Request Relief Request RR-6: Identify the calibration blocks for which relief is requested and provide additional information with regard to the materials of fabrication and acoustic compatibility with the component to be examined.

APCo Reply:

For the reasons cited above, Relief Request RR-6 vill be deleted from the ,

ISI Program with the next revision.

l V. Relief Request RR-33 NRC Request:

l Provide detailed technical justifications demonstrating impracticality and I

discuss the following concerns with regard to most of the systems involved (i.e., service water, component cooling water, chemical and volume control, reactor makeup): Are these systems required by the Technical Specification ,

l to be operable in all modes (e.g., during vessel examinations when fuel is removed from the reactor)? Do any of these systems have multiple trains of which one could receive the Code-required examination? Do these systems l have portions which can be " valved out" to accommodate the Code-required i hydrostatic test?

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, .o Enclosure - Unit 1 i Page 4 e

APCo Reply:

l Those portions of the service vater, component cooling water, chemical and volume control and spent fuel pool cooling systems which can be isolated without loss of redundant trains within the system vill be hydrostatically L

tested to the extent practical as required by the Code. A detailed reviev l vas conducted to identify those portions of these systems which cannot be 4 hydrostatically tested as required by the Code. A listing of these is provided in Attachment 2. The piping and components listed either lie beyond the Code boundary valve used to isolate the system for performance of the hydrostatic test or interconnect the redundant system trains such that removal from service for testing would render the entire system >

inoperable. RR-33 vill be revised accordingly to incorporate this table and the revised relief request vill be resubmitted with the next ISI ,

Program revision.

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4 ATTACHMENT 1

SUMMARY

OF CALIBRATION BLOCK DIMENSIONAL

-DIFFERENCES UNDER THE S83 CODE REQUIREMENTS (RELIEF REQUEST RR-5)

VALL THICKNESS DEVIATIONS Calibration Calibration Pipe Pipe Pipe Vall Material Block No. Block Th.(in.1 Dia.(in.) Schedule Thicknes (in.)

ALA/APR-33 2.487 27.5 Special 2.30 Cast SS ALA/APR-33 2.487 29.0 Special 2.42 Cast SS ALA/APR-33 2.487 31.0 Special 2.59 Cast SS ALA-24 1.200 32.0 Special 1.033 Carbon ALA-25 0.750 16.0 100 1.031 Carbon CURVATURE DEVIATIONS Calibration Calibration Component Component Material Block No. Block Dia.(in.) Description Diameter (in.)

ALA/APR-33 29 Pipe 27.5 Cast SS ALA/APR-33 29 Pipe 31.0 Cast SS ALA-5 8 Thin-Valled Vessel 9.5 Stainless ALA-32 Flat Thin-Valled Vessel 39.75 Stainless ALA-31 Flat Thin-Valled Vessel 21.78 Stainless ALA-31 Flat Thin-Valled Vessel 84.00 Stainless ALA-23 Flat Pipe S4.55 Carbon ALA-25 14 Reducer 16x14 Carbon cht-nrc.8.3

p ATTACHMENT 2 Listing of Portions of Service Water, Component Cooling Vater, Chemical and Volume control and Spent Puel Pool Cooling Systems Which Cannot Be Hydrostatically Tested i

i Service Vater (1)

1. Portion of Piping upstream of valves 01P16V540 and 01P16V541.

2. Portion of Piping downstream of valves 01P16V516 and 02P16V517.

y Spent Puel Pool Cooling (2)

1. Portion of Piping dovnstream of valves 01G31V003A and 01G31V003B.

2. Portion of Piping downstream of valve 01GS1V005.

3. Portion of Piping upstream of valves 01G31V001A and 01G31V001B.

Component Cooling Vater (2)

1. Component Cooling Vater Surge Tank. l'

2. Portion of Piping from CCV surge tank to valves 01P17V117A, 01P17V1178, 01P17V121A, 01P17V121B, 01P17V110A, 01P17V110B, 01P17V110E, 01P17V110F, {

01P17V109A, 01P17V109C, 01P17V278A, 01P17V278B, 01P17V278C, 01P17V144A, l 01P17V144C, 01P17V017A, 01P17V017B I

i Chemical and Volume Control (2)

1. Portion of Piping from valve 01E21V019 to discharge of Boron Injection Recirculation Pumps - valves 01E21V006A and 01E21V006B.

l Notes (1) These portions of Class 3 piping are unisolable from non-safety related 1

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piping providing service water supply to and from the turbine building.

(2) These portions of Class 3 piping and components cannot be isolated for hydrostatic test s'ince removal from service for testing would render the entire system inoperable.

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