ML19345C302
| ML19345C302 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 11/14/1980 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19345C299 | List: |
| References | |
| NUDOCS 8012040364 | |
| Download: ML19345C302 (21) | |
Text
.
qL/ < /p uaw-UNITED STATES.
- l 7 J c '{ g NUCLEAR REGULATORY COMMISSION
_jj WASHINGTON, D. C. 20555
%; y ]
SAFETY' EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION j
RELATED TO AMENDMENT NO. 43 TO FACILITY OPERATIflG LICENSE N0. DPR-42 AND AllENDMENT N0. 37 TO FACILITY OPERATING LICENSE NO. OPR
- i NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENEPATING PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-282 AND 50-306 By appiitation transmitted by letter dated October 15, 1976 for Unit 1 and October 12, 1977 for Unit 2, the Northern States Power Company (the licensee) requested changes to the Technical Specifications (TS) appended to Facility Operating License Nos. OPR-42 and DPR-60 for the Prairie Island Nuclear Generating Plant Unit Nos. I and 2, respectively. The proposed change would remove the specific inservice inspection requirements from the TS 4
and replace.~ them with the Prairie Island Nuclear Generating Plant Inservice Inspection Program.
As required by 10 CFR 50.55a(g), the Northern States Power Company has updated the Inservice Inspectio:t Program for the P*airie Island Nuclear Generating Plant Unit-Nos. I and 2 facility to the requirements of the 1974 Edition through Summer 1975 Addenda of Section XI ASME Boiler and Presst.re Vessel Code. Based on information submitted by letters dated February 1, 1978, September 15,:1978, June 8, 1979, September 19, 1979, April-17, 1980 and -September 3,1980, it has been determined that certain requirements of the Code cannot be implemented at the facility because of component or system design, geometry, or materials of construction. Requested relief from those requirements has been evaluated and our determinations to grant or deny the requests are documented below.
5 INSERVICE INSPECTION f
I.
CLASS I' COMPONENTS t
A. --Units 1 and 2 j
1.
Request relief from having a calibration standard of the correct length j.
when examining reactor vessel closure head studs.
Code Requirement
-The length of the ultrasonic calibration standard shall be as described in i-Article 5 of Section V.
l--
l Licensee's Basis for Peouesting Relief I
The present calibration standard was used'to perform the preservice examination
~
of the reactor vessel-closure head studs.
801200 36T
2-Evaluation -
The calibration standard which the licensee is using contains the correct size reference hole (3/8" dia.) and would give an accurate reflection at that depth for calibration in accordance with the code. However, attenua-tion of the sound with increased metal path would be a factor and must be determined. The ifcensee has proposed a multiple back reflection to determine and correct for attenuation. The staff finds that the licensee's calibration standard is acceptable provided equivalent sensitivity is proven by actual demonstration to the satisfaction of the region I&E inspector and if requested, by the Authorized InspeQ or.
2.
Request relief from performing the volumetric examination at the required frequency for each weld on the regenerative heat exchanger.
The percentage of examination completed by tne end of each inspection period will not comply with lWB-2all.
Code Recuirement Five percent of each of the three shell's tube sheet-to-head welds are to be examined by the end of the inspection interval with credit for no more than 33-1/3 percent of the welds required to be examined by the expiration of each inspection period.
Licensee's Basis for Requesting Relief The regenerative heat exchanger consists of three identical cylindrical exchanger shells (approximately 7" 0.0.), which are vertically stacked and are connected in series by short lengths of 2" nominal diameter pipe. The'high radiation levels involved in parforming the inspection,
' hich includes removal and replacement of insulation, makes it impractical to perform inspections of each tube sheet-to-head weld during each inspection period. The radiation levels were measured during the March 1977 refueling outage to be 2.5 R/hr. on contact.
Evaluation The licensee has proposed an alternate inspection to perform a 100 percent examination on one tube sheet-to-head weld during each consecutive inspection period.
This will result in a total examination of linear inches which exceeds the minimum examination requirement of the code.
It also reduces the man-rem exposure by approximately 53 percent. The staff finds tnat the procosed alternate examination is acceptable and therefore the requested relief is granted.
3.
Request to use the ultrasonic inspection procedure for pipe welds instead of the examination procedure for neavy wall vessels for thin wall vessels.
The ultrasonic inspection of the thin wall vessel snell welds will not be cerformed in accordance with Accendix I of Section XI nor Article 5 of Section V. W
Code Recuirement Vessels 2-1/2 inches thick and over shall be examined in accordance with Appendix I.
Where Appendix I is not applicable, the provisions of Article 5 of Section V shall apply.
Licensee's Basis for Recuesting Relief The design service requirements for the regenerative heat excnanger and i
excess letdown heat exchangers resulted in the relatively small and thin wall vessels which permitted them to be fabricated from piping components.
Therefore, ultrasonic inspection procedures for pipe welds would be more applicaole than procedures for examination of heavy wall vessels.
Evaluation The licensee has proposed an alternate examination which is to ultrasoni-cally examine the aoove listed components in accordance with Appendix III cf.he 1975 Winter and 1976 Summer Addenda of Section XI.
The evaluation of indications shall comply with Article 5 of Section V of the 1974 Code, Summer 75 Addenda.
The staff finds that this is a more appropriate test on thin wall vessels and therefore the requested relief is granted.
4.
Request to delay the volumetric examination of the reactor coolant pumo integrally welded supoorts until the end of the inspectior.
interval.
Code Recuirement The examinations performed during each inspection interval snall cover 25 percent of the integrally welded suoports with credit for no more than 33-1/3 percent by the exoiratica of each inspection period.
Licensee's Basis for Recuesting Relief Because of the weld joint geometry, heavy wall, and austenitic stainless steel cast structure of the pump body, present volumetric NDE metnods would be ineffective.
In addition, insulation removal and reolacement is a formidaole task, requiring a consideraole amount of manpower. The insulation is cesigned to be removed in large panels and because of a lack in lay cown space, it would have to be removed to another area.
Not considering any unforeseen proolems in the removal and replacement of insulation, the task for one pumo would be a very time consuming joo, and a nign accumulative radiation exposure o cersonnel would be anticicated.
\\
-l Evaluation The staff does not find licensee's justification adequate to warrant granting the requested relief. Neither manpower expenditure nor insulation removal and replacement effort can constitute a sufficient valid basis to request for relief. The staff concludes the inspections be performed at the intervals required by Section XI IWB-2411.
In the event the volumetric examinations cannot be performed because of the weld joint geometry, heavy wall, and the austenitic steel structure, a surface examination (liquid penetrant) should be used as a substitute for the volumetric examination.
If high radiation levels are experienced, a request for relief together with the anticipated total time of the inspection and man-rem doses should be submitted to the NRC at that time.
5.
Request to delete the requirement for the surface examination of the reactor vessel closure head cladding and steam generator channel head cladding.
Code Recuirement Surface and visual or volumetric examinations on the closure head clacding.
Visual examination on the steam generator cladding.
Licensee's Basis for Recuesting Relief Visual examination will be performed on the reactor vessel closure head cladding and all clad surfaces must be free of cracks.
Volumetric examination is required for the meridional and circumferential welds in the vessel head and the head to tube sheet circumferential weld in the steam generators. These examinations'will cover a sufficient area of c's/-case metal interface to give an indication of the general condition u. the cladding and clad interface.
Radiation levels were calculated at 5 R/hr contact reading and 2 R/hr general area reading for the reactor vessel closure head and aporoximately 5 R/hr in the steam generator channel head.
Evaluation We agree with the licensee's basis for relief reauest and conclude that the proposed changes as described above are acceptacle and therefore the requested relief is granted.
6.
Request to delay the volumetric examination of the reactor vessel support lugs until the end of the inspection interval.
4
9
~
Code Reouirement The examinations performed during each inspection interval shall cover 100 percent of the support lugs with credit for no mobs than 33-1/3 percent by the expiration of each inspection period.
Licensee's Basis for Requesting Relief As a result of the reactor vessel cavity design, the two integrally welded supports are not accessible from the 0.0. of the vessel. Ul tra-sonic examination through the vessel wall from the I.D. surface appears to be the only means of examination.
This examination would require the core barrel to be removed to gain access to the vessel's I.D. surface.
When the core barrel is removed from the reactor vessel, at or near the end of the inspection interval, the supports will be volumetrically inspected 100 percent.
Evaluation The staff concurs with the licensee's basis for relief request and finds the alternative inspection schedule proposed acceptacle.
7.
Request relief from performing acoustic velocity and attenuation measurements to determine acoustic similarity of the ultrasonic calibra-tion block to the reactor vessel, pressurizer and steam generator.
Code Reouirement The acoustic velocity and attenuation of ultrasonic calibration blocks shall be demonstrated to fall within the range of straight team longitudinal wave velocity and attenuation found in the unciad component.
Licensee's Basis for Recuesting Relief Because all the components involved are clad on the inner surface, it would be impossible to obtain a comparison of sound beam velocities and attenuation in the unclad component.
Evaluation The requirement to examine the block and component with a longitudinal wave to determine acoustic velocity and attenuation only apolies to those items which can be checked before the component is clad.
As stated by the licensee, all comoonents involved are clad on the inner
- surface and therefore this requirement would not apply.
The requested relief is granted based on the licensee's commitment to fabricate the calibration blocks in the following manner:
5-
" calibration blocks required for the examination of welds. in ferritic vessels 21/2 inch thick and over will be fabricated from material of the same specification, product form, and heat treatment as one of the saterials being joined as allowed by Article T-434.1 in the Winter 1976 Adcenda of Section V of the ASME Boiler and Pressure Vessel Code."
8.
Request relief from performing a system leakage test on the section of piping between motor-operated valve #31329 and Check valve pVC-8-3 at the frequency required by the Code.
C::e Recuirement The piping shall be subjected to a system leakage test prior to startup fo' lowing each reactor outage.
Licensee's Basis for Recuesting Relief Tnis section of piping is not isolatable from the RCS. Performing a leakage
- est at functional pressure causes pressurizer spray which causes a reduction in RCS pressure. Spraying water into the pressurizer from the auxiliary saray line is an abnormal operation. The spray line is designated for 10 sJch inadvertent operations.
Evaluation Eacause of the design of the Auxiliary Spray System, piping between the ra:ar-operated valve #31329 and check valve #VC-8-3 cannot be pressurized
- 3 the proper test pressure without bypassing the check valve or opening
- ne motor-operated valve.
It is impractical to pressurize this portion cf the piping system at the frequency required by the Code because of the ris< associated with the inadvertent operation of the pressurizer sprays.
Tne licensee will perform a system leakage test on this section of piping e/ery ten years and visually inspect tha piping for leakage during the c /erall reactor coolant system leakage test prior to startup following eacn refueling outage. This section of piping is also examined in accord-ance with the rules of IWB-2000. The staff finds that the examinations wnich will be performed by the licensee on this section of piping will
- rcvide adequate assurance of its structural integrity and therefore the requested relief from the testing frequency as required by the Code is granted.
D )))
ng, a
s u
.s.
t II.
CJASS 2 COMP 0NEES A.
Units 1 and 2 1.
Request relief from performing the system pressure test at the frequency required by IWC-2412.
Licensee's Basis for Recuesting Relief Scheduling system pressure tests in this manner is not practical as mechanisms are not available for isolation of tne piping systems at the various boundaries created by the NDE exemption criteria. Consequently numerous redundant pressure tests will be performed which is not warranted considering the operational problems (system valve lineups, leak off or overpressure protection, radiation exposure, generation of waste, etc.)
involved. Additionally, the majority of these systems are either normally pressurized or pressurized during the performance of a pump or valve functional test.
Evaluation The licensee has proposed that all comoonents be pressure tested at or near the end of each inspection interval (10 years) instead of pressure testing some of the exemoted components during the inscection interval.
The staff has evaluated the licensee's basis for requesting relief and concluded that this recuest shculd not be granted.
However, the staff concludes that the following examinations may be conducted. A system functional test may serve as a system cressure test anc at least one visual examination shall be conducted at or near the end of each inspection period coinciding with a system functional test.
In addition a system hydrostatic test snall be conducted at or near the end of each inspection interval.
These recuirements are consistent with the Winter 77 Section XI requirements for all Class 2 components and are necessary to maintain an acceptacle level of quality curing the 10 year interval.
2.
Recuest relief from performing the system pressure test at the pressures reouired for Class 2 systems on the systems listed elow.
o Safety injection piping nonisolacle from Class 1 ciping, o
Reactor coolant system piping 3/a" and smaller that is nonisolacie from Class 1 piping.
i o
Residual heat removal system piping nonisolable from Class 1 piping.
o RCP seal injec-ion piping 3/4" and smaller that is nonisolable from Class 1 piping.
o RCP seal return piping nonisolable from Class 1.
o Charging line piping nonisolable from Class 1.
o Sample system piping nonisolable from Class 1.
Code Recuirement The pressure retaining components shall be subjected to a hydrostatic test at 1.25 times the system design pressure at a temperature not less than 100* F at least once toward the end of each inspection interval.
Licensee's Basis for Recuesting Relief The piping is not isolable from the Class 1 piping.
Evaluation The licensee has proposed an alternate inspection plan which is to perform a hydrostatic test to the requirements for Class I systems near-the end of each inspection interval. The staff finds this acceptable providing the licensee performs a visual examination for evidence of leakage on those portions of the above systems at the system nominal operating pressure in accordance with the requirements of IWB-5221.
This examination shall be performed prior to startup following each reactor refueling outage.
B.
Unit 2 1.
Request relief from volumetric examination of inaccessible welds which are identified below:
SYSTEM ITEM IDENTIFICATION CODE MAIN STEAM SYSTEM PIPING WELDS (ENCAPSULATED AT GUARD PIPE) CLASS 31-2MS-1 WELDS MS-19,MS-20 2
WELD MS-19 TO MS-20 2
MS-1858,MS-1850 2
6-2MS-1 WELD MS-33 2
31-2MS-2 WELOS MS-166,-92,-93,-94,-95,-96,-97,
-98,-99,-117,-170 WELDS MS-165 TO -166,MS-95 TO -92 2
MS-97 TO -98, MS-99 TO -117 WELD MS-988 2
8
1 i
30-2M5-2 MS-88,-89,-90,-91,-165,-100 2
WELD MS-89 TO -90 2
WELDS MS-183C, MS-183A 2
6-2MS-2 WELD MS-lli 2
FEEDWATER SYSTEM PIPIf4G WELDS (ENCAPSULATED BY GUARD PIPE) 16-2FW-16 WELDS FW-119,-120,-121,-122,-123,124,
-125,-126,-127,-185,-128,-129,
-130W, -131,-132 2
CONTAINMENT SUMP A&B DISCHARGE PIPING WELDS (IMBEDDED IN CONCRETE) 14-2SI-338 WELDS 1,2,3,207 2
12-251-348 WELD 4
2 14-2SI-33A WELDS 13,14,15 2
12-2SI-34A WELD 16 2
CONTAINMENT SUMP A&B DISCHARGE SUPPORTS (IMBEDDED IN CCNCRETE) 14-2SI-338 SUPPORTS A,8,C 2
14-2SI-33A SUPPORTS A,B,C 2
Code Raouirement Class 2, Category C-E-1, requires 100 aercent of the supports be surface examined each inspection interval.
Class 2, Category C-G, requires volumetric examination of 100 percent of the weld on 50 percent of tne total welds over a 40 year period.
Licensee's Basis for Reouestino Relief Items are not accessible for examination because of eitner being encao-sulated by guard pipe or imbedded in concrete.
Evaluation Access to volumetrically and/or surfa'ce examine these welds is restricted by not having access to the outside surface due to the interference from steel plate or concrete. All welds identified above as being inaccessible snall be v'
' ly inspected for leakage by observing the general area after a 4-hold at the pressure test requirements as stated in IWC-5000.
examination, and other volumetric inspections required by Section XI of similar systems whien can be performed, will provice assurance that no degradation has occurred and the ciping pressure boundary will remain struccurally acceotaole during the insoection interval.
9-1 c-
---,g a
w gc m
~.r.
I I
1 1
l
-This relief does not apply in the event paragraph IWC-2430 of Section XI is applicable.
III. CLASS 3 COMPONENTS A.
Units 1 and 2 1.
Request relief from performing a pressure test by tne expiration of each inspection interval on the Cooling Water Supoly and Return Headers.
Code Recuirement 100 percent of the components shall nave been pressure tested and examined by the expiration of each inspection interval.
Licensee's Basis for Recues_ ting Relief The Cooling Water System design is such that Unit 1 and Unit 2 safeguards equipment is supplied from both sides of the cooling water system header.
Consequently, the entire supply and return header must be in operation at all times to meet operating license requirements.
Evaluation The licensee has proposed the following alternate inspection of the Cooling Water Supply and Return Headers whien the staff fincs acceptable.
The Cooling Water System will be visually examined by every 1/3 of eacn inspection interval for conditions adverse to system cperation. Additionally, the system is in constant operation and any leaks wcaid be immediately known.
Portions that are isolable from the main headers will be pressure tested in accordance with the apolicable recuirements.
S.
Unit 1 1.
Request relief from performing a visual examination or pressure test on the following Class 3 pioing.
o Wasta Gas Vent Header and Associated Liquid Drains to tne HUTS o
121 Catalytic Hycrogen Recomciner o
122 Catalytic Hydrogen Recombiner o
Waste Gas Hign Level Loco o
Waste Gas low Level Loop Code Recuirement 100 percent of the Class 3 pioing snall hcve been tested anc examinec cy the expiration of each inspection interval. 1
J e
Licensee's Basis for Requestico Relief Numerous operational problems will be created in trying to perform the required tests.
Isolation of the Wasta Gas System for pressure testing would require shifting of waste gas inventories to allow isolation of components, generation of additional waste gas required for purging operations and possible radioactive gas releases.
Filling the systems with water 'to perform the tasts would generate additional problems with system corrosion and instrumentation fouling.
Evaluation The licensee has numerous methods to detect leakage of the above listed components. Local pressure indication provides indication to operators of any malfunctions and daily gas cecay tank inventories will also indicate any leakage. Local radiation monitors will detect any gaseous or particulate releases.
The staff finds the pressure test requirement to be impractical to perform and grants the requested relief based on the licensee's present leak detection capacilities.
2.
Request "elief from performing a visual examination or pressure test on the following Class 3 tanks and piping, o
Diesel Generator and Diesel Cooling Water Pump 011 Storage Tanks, Fuel Oil Transfer Piping to the Diesel Generator and Diesel Cooling Water Pump Day Tanks Code Recuirement 100 percent of the Class 3 piping and comoonents snall have been tested and examined by the expiration of each inspection interval.
Licensee's Basis for Recuesting Relief The tanks and most of the pioing are underground anc not accessible for testing and inspection. Any leakage from the fuel oil storage tanks will be detected during daily checks of the storage tank levels.
- Also, annually each tank is tested for moisture content.. Monthly checks af the diesel generator and diesel cooling water day tank levels and alarms, will incicata any problems in the fuel oil transfer piping system.
Ivaluation The staff finds that the suoject examination or testing recuirement is impractical based on the component and system design. The staff also finds that the licensee's inspection and sampling program is acceptable for those systems which are underground and cannot otherwise be inspected.
Therefore the requested relief is granted.
3.
Request relief from performing a pressure test on the following Class 3 piping systems.
1 o
Starting Air, Air Intake, and Cooling Water Piping associated with 11 and 12 Diesel Generator.
Code Reauirement 100 percent of the Class 3 piping and components shall have been tested and examined by the expiration of each inspection interval.
Licensee's Basis for Recuesting Relief The systems are in constant operation and the piping is not isolable from the Diesel Generators.
Evaluation The licensee has proposed to visually examine tne piping every 1/3 of each inspection interval for conditions adverse to system operation.
Additionally, the systems are in constant operation and any leaks would be Known.
Portions that are isolable from the Diesel Generators will be pressure tested in accordance with the applicable requirements.
The staff finds this acceptable and therefore the requested relief is granted.
C.
Unit 2 1.
Request relief from performing a visual examination or pressure test on the Waste Gas Low Level Loop.
Code Reauirement 100 percent of the Class 3 piping shall have been tested and examined oy the expiration of each inspection interval.
Licensee's Basis for Recuesting Relief Numerous operational croblems will be created in trying to perform the required tests.
Isolation of the Wasta Gas System for pressure testing would require shifting of waste gas inventories to allow isolation of comoonents, generation of additional waste gas required for curging operations and possible radioactive gas releases.
Filling the systems with water to perform the tests would generate additional problems with system corrosion and instrumentation fouling.
Evaluation The licensee has numerous methods to detect leakage of the acove iirted components.
Local pressure indication provices indication to coerators of any malfunctions and -daily gas decay tank inventories will also indicate any leakage.
Local radiation monitors will detect any gaseous or particulate releases.
The staff finds the pressure test requirement
~
to be impractical to perform and grants the requested relief based on the licensee's present leak detection capabilities.
IV. CLASS 1 AND 2 COMPONENTS A.
Units 1 and 2 1.
Request to use Appendix III, including Supplement 7, of the 1975 Winter and 1976 Summer Addenda of Section XI in lieu of Article 5 of Section V.
Code Recuirement Ultrasonic examination shall be conducted in accordance with the provi-sions of Appendix I.
Where Appendix ! is not applicable, the provisions of Article 5 of Section V shall apply.
Licensee's Basis for Recuestino Relief The use of side drilled holes to establish a distance amplitude correction curve for pipe weld. inspections, as required by Appendix ! of Section XI and Article 5 of Section V, results in an excessive instrument gain setting which greatly impairs the inspector's ability to detect and interpret indications by producing a lower signal-to-noise ratio and cecreases the usable range of the "0AC.
Evaluation The rules of Appendix III, including Supplement 7, thru Summer 1976 Accenda to Section XI are acceptacle.
The evaluation of indications shall comply with the rules of Section XI 1974 Edition including Summer 75 Accenca. However, all indications at or aoove 50 cercent DAC shall be recorced and indications 20 percent DAC or greater wnich are interpretec to be a crack must be identified and evaluated to the rules of Section XI Coce.
2.
Request to use a flat calibration block on pipes greater than a 20-incn diameter.
Ioce Recuirement The basic calibration blocks shall be mace from material of tne same nominal diameter when using tne rules of Accendix III Summer 76 Accenca of Section XI...
Licensee's Basis for Recuesting Relief Any difference in accuracy and sensitivity for ultrasonic examination of welds with surface curvatures greater than a 20-inch diameter, when using a flat basic calibration block versus a curved basic calibration block, would be within the accuracy of the test.
Evaluation For surface curvature, the rules of Article 5 cf section V, paragraph T-533-1, 1974 Edition shall apply for pipe w2id inspection.
3.
Request relief from having a calibration standard when calibrating the ultrasonic test equipment for examination of reactor coolant pumps flange studs and seal house bolting.
Code Reouirement
~
ASME Section V, Article 5, requires a calibration standard with reference holes to establish a calibrated distance amplitude correction for examining bolt material.
Licensee's Basis for Recuesting Relief The variation in ultrasonic attenuation between bolts of the same type, diminishes the usefulness of generating a distance amolituce curve (DAC) from a test bar and using it as the recorting and evaluation criteria.
In addition, this technique was not used for the baseline inspection, nor is it as sensitive to detect service-induced defects as other presently available techniques.
Evaluation The licensee has proposed an alternate calibration technique for ultra-sonically examining bolts. This tecnnioue utili:es the response from the back reflection of the bolt or stud being examined to establish instrument sensitivity.Section V, Article 5 is the current requirement.
The Alternative examination technique to be used by the licensee has been demonstrated to be superior to that required and is therefore acceptable.
Therefore the requeste relief is granted.
d
~
4.
Request relief from filing with the regulatory authority of the inservice inspection reports for Class 1 and 2 components.
Code Recuirement The Owner's inservice inspection reports shall be filed within ninety (90) days after completion of the inservice insoection with the enforce-ment and regulatory authorities having juri< diction at the plant site.
Licensee's Basis for Raouesting Relief Submittal of the inservice inspection reports would be an addition to the already heavy reporting burden and would require positive reporting of successful coraletion of the hundreds of tests'and examinations that are required every year on a nuclear plant.
All inspection and test recoros are available at the facility for inspection by the Inspection and Enforcement regional inspectors.
Evaluation The intent of tne 90-day reporting requirement is to provide the NRC and the Authori:ed Inspection Ageny a summary of examinations performed, conditions observed, corrective measures recommended and taken.
If a more detailed review of the inspection activity is deemed necessary, the I&E regional inspector would perform an incepth audit at the facility.
It is the staff's position that the 90-day report is necessary and does not create an undue hardship upon the licensee to comply with the code requirement.
i We therefore recommend that the code requirement be met by submitting six(6) copies of the inservice inspection report. Two copies should be submitted to Region III and four (4) copies to the Director, NRR.
3.
Unit 1 1.
Request relief from volumetric examination of inaccessible welcs which are identifiac celow:
i SYSTEM ITEM IDENTI ICATION CODE MAIN STEAM SYSTEM PIPING WELDS (ENCAPSULA7ED A7 GUARD PIPE) CLASS 31-MS-2 WELOS MS-150, -71, -72, -73, -74, -75 2
-76, -77, -78, -79 WELDS MS-74 to -75, MS-7, 2
MS-73 to -79 l l l
e
~
n
,a m
i 30-MS-2 WELDS MS-68, -70, -159,~-108 2
WELD MS-159 to -160 2
6-MS-2 WELDS MS-108A, -134 2
31-MS-1 WELDS MS-14 to -15 2
30-MS-1 WELDS MS-51, -52W 2
WELD MS-182 to -183 2
6-MS-1 WELDS MS-51C, -62 2
FEEDWATER SYSTEM PIPING WELDS (ENCAPSULATED BY GUARD PIPE) 16-FW-16 WELDS FW-202, -203, -204, -225, -205, 2
-206, -207, -208, -209, -210,
-211, -212, -219, -213, -214, 2
CONTAINMENT SUMP B OISCHARGE PIPING WELDS (IMBEDDED IN CONCRETE) 14-SI-33A WELDS SI-ll, -217, -12, -13 2
14-SI-34A WELD SI-14 2
14-SI-33B WELDS SI-1, -217, -12, -13 2
14-SI-348 WELD SI-4 2
CONTAINMENT SUMP B DISCHARGE SUPPORTS (!MBEDOED IN CONCRETE) 14-SI-33A SUPPORTS A,B,C, 2
14-SI-338 SUPPORTS A,B,C 2
SAFETY INJECTION LOW HEAD A PIPING WELDS (IMBEDDED IN CONCRETE) 4-RC-14A WELD 3
1 Code Recuirement Class I welds - volumetric examination of 25 percent of the welds during.
each inspection interval.
Class 2, Category C-E 100 percent of the suoports to be surface examined during each inspection interval.
Class 2, Category C-G - 100 percent of the weld to be inspected on 50 pe-cent of the total welds by volumetric examination over a 40 year period.
Licensee's Basis for Reouestino Relief Items are not tecessible for examination because of either being encap-sulated by guard pipe or imoecced in concrete..
~
E Evaluation Access to volumetrically and/or surface examine these welds is restricted by not having access to the outside surface due to the interference from steel plate or concrete. All welds identified above as being inaccessible shall be visually inspected for leakage by observing the general area after a 4-hour hold at the pressure test requirements as stated in IWB-5000 and IWC-5000. This examination, and other volumetric inspections required by Section XI of similar systems which can be performed, will provide assurance that no degradation has occurred and the piping pressure boundary will remain structurally acceptable during the inspection interval.
This relief does not apply in the event paragraph IWC-2430 of Section XI is applicable.
V.
CLASS 2 AND 3 COMPONENTS A.
Units 1 and 2 1.
Request relief from removing insu ation from nonwelded piping and valve supports.
Code Recuirement The examination performed during each inspection interval shall' cover all support components and shall include the support C0mponents wnich extend from the piping, valve, and pump attachment, and including the attachment to the supporting structure.
Licensee's Basis for Recuestino Relief Any loss of suoport capability or inadequate restraints can usually be detected througn tne inspection of the uninsulated portion of the suoport and the surrounding insulation.
The governing Codes and Regulations used in the design and construction of those systems that are now classified as Class 2 and 3 did not require provisions for inspection access for these systems.
Thus it would be an undue burden without compensating increase in safety to require insulation removal for support inscection.
The insulation will be removed from a supported comoonent for further inspections whenever an abnormality is detected tnat may have oeen a result of a loss of supoort capability or inadequate restraint.
o,
1 Evaluation The staff grants the requested relief with the following restrictions.
The insulation must be removed sufficient to allow inspection of all mechanical connections such as, eyelets, bolts, adjustments, locking devices, etc. Any welds which might be on the scoport also require insulation removal to allow direct visual inspection of the weld.
VI. CLASS 1. 2, 3 COMPONENTS A.
Units 1 and 2 1.
During the system pressure test, request relief from the 4-hour hold re uirement when the areas are exposed for a visual examination.
Code Recuirement The test pressure and temperature shall be maintained for at least 4-hours prior to the performance of a visual examination.
Licensee's Basis for Reouesting Relief This requirement is not practical nor meaningful when performing pressure tests of areas that are exposed for visual examination. The A-nour hold requirement is based on detection of leakage from insulated areas.
Where areas of examination are not exposed, the test pressure and temoera-ture will se maintained for a minimum of four hours.
Evaluation The staff grants the requested relief with the following conditions.
o When performing a system pressure test the entire system must be directly visible. This incluces the welds and all base materials.
o Following a repair the repaired area must be accessible for a direct visual examination.
o When the areas are exoosed, the pressure and temoerature snall be maintained for a minimum time of 10 minutes and for such additional time as may be necessary to conduct the examinations.
1 1
l '
This relief is consistent with the rules of Section XI Winter 75 Addenda, which the staff finds acceptable.
VII. AUGMENTED INSPECTION FOR UNITS 1 AND 2 Pursuant to 10 CFR 50.55a(g)(6)(ii) the Commission may require the licenses to follow an augmented inservice inspection program.
Accordingly, the staff requires an augmented inservice inspection on the following Class 2 systems which perform an " Emergency Core Cooling" function and which are presently exempt from examination as provided in ASME Section XI, paragraph IWC-1220(c) and of the 1974 Edition and Summer 1975 Addenda. The licensee has been con-sulted on these inspections and has agreed to incorporate them in forthcoming revisions to the inservice inspection program.
A.
Unit 1 Residual Heat Removal System Line Total Welcs M.5.
12-RH-5A 10 Welds 12-RH-5B 10 Welds 8-RH-7A 12 Welds S-RH-78 13 Welcs 8-RH-9A 14 Welds 8-RH-9B 13 Welds S.S.
10-RH-ll 9 Welds Safety Injection System Line Total Welds M.5.
6-SI-10A 10 Welds 12-RH-6A 5 Welds 12-RH-6B 5 Welds 5.5.
8-SI-18 39 Welds M.S.
6-SI-13A S Welds 5-SI-13B 3 Welds S.S.
12-SI-il 9 Welds la-SI-l 8 Weids 3.
Uni: 2 Residual Heat Re oval Svs em Line Total Welds M.5.
12-2RH-5A 9 Welcs 4,.
4 12-2RH-58 9 Welds 8-2RH-7A 12 Melds 8-2RH-7B 12 Welds 8-2RH-9A 10 Welds 8-2RH-98 11 Welds S.S.
6-2SI-108 10 Welds M.S.
12-2RH-6A 7 Welds 12-2RH-6B 6 Welds S.S.
8-2SI-18 55 Welds M.S.
6-2SI-13A 7 Welds 6-2SI-138 7 Welds S.S.
12-25I-11 9 Welds 14-2SI-ll 8 Welds The examination requirements of IWC shall apply on the above systems, including their supports, in accordance with the following:
The number of Class 2 pipe welds to be examined snall be 10 percent of the total number of welds in each individual system.
The welds to be examined shall be distributed approximately equally among runs (or portions of runs) that are essentially similar in design, size, system function, and service conditions.
The welds to be examined shall be 100 percent of the terminal ends of pipe at vessel nozzles with the remaining additional weld of the 10 percent selected proportionally from the following categories:
(1) dissimilar-metal welds, (2) welds at structural discontinuity, (3) welos that cannot be pressure tested in accordance with IWC-5000.
This augmented inspection is in accordance with the rules of 10 CFR part 50-55a.(g)(6)(ii).
Bases for the Augmented Insoection o
The systems are necessary for safe shutdown in the event of an
- accident, o
The licensee has been unable to provide a technical justification for not inspecting the welds, o
The exemption was deleted and inspection requirements such as those described above were imposed in later editions of the ASME B&PV codes.
Environmental Consideration We have determined that these amendments do not authorize a change in. effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Hav-ing made this determination, we have further concluded that the amendments involve an action which is insignificant from the stand-point of environmental impact and, pursuant to 10 CFR 551.5(d)(4),-
that an environmental impact statement, or negative declaration and environmental impact appraisal need not be preparea in connection with the issuance of the amendments.
Conclusion We have concluded, based on the considerations discussed above, that:
(1) because the amendments do not involve a significant increase in the probability or consequences of accidents previously considered and do not involve a significant decrease in a safety margin, the amendments do not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of,
the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliante with the Commission's regulations and the issuance of these amend-ments will not be inimical to the common defense and security or to the health and safety of the public.
Cated: November 14, 1980 1 '
_