ML19354D704
| ML19354D704 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/31/1989 |
| From: | Beth Brown, Mudlin J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML19354D702 | List: |
| References | |
| CON-FIN-D-6022 EGG-ESM-7923, NUDOCS 8912290133 | |
| Download: ML19354D704 (46) | |
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TECHNICAL EVALVATION REPORT ON THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION RELIEF REQUESTS:
NEW YORK POWER AUTHORITY, JAMES A. FITZPATRICK NUCLEAR POWER PLANT, .
DOCKET NUMBER 50-333 B. W. Brown J. D. Mudlin Published August 1989 Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for:
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 under DOE Contract No. DE-AC07-761001570 FIN No. D6022 (Project 5) 8912290133 891226 DR ADOCK 0500 : 3
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' . ABSTRACT i: .
This report presents the results of the evaluation of the James A. .
FitzPatrick Nuclear Power Plant inservice inspection (ISI) requests for relief.from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI-requirements which the Licensee has determined to be impractical for the first 10 year inspection interval.
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L This work was funded under:
U.S. Nuclear Regulatory Commission FIN No. D6022, Project 5 l Operating Reactor Licensing Issues Program, Review of ISI for ASME Code Class 1, 2, and 3 Components l
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SUMMARY
On August 6, 1987, the Licensee, New York Power Authority, submitted requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical for the first 10-year inspection interval. The available information in this submittal was reviewed. As a result of the review, a request for additional information (RAI) was prepared describing the information and/or clarifications required from the Licensee in order to complete the review. The requested information was provided by the Licensee in a letter dated September 20, 1988.
Based on the review of the Licensee's relief requests, it is concluded that the Licensee has demonstrated that specific Section XI requirements are impractical in all cases except Requests for Relief la, 5, 7, 9, ll, and 12.
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CONTENTS ABSTRACT ................................................................ ii
SUMMARY
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- 1. INTRODUCTION ........................................................ 1
- 2. EVALVATION OF INSERVICE INSPECTION PROGRAM PLAN ..................... 3
- 3. EVALUATION OF RELIEF REQUESTS ....................................... 4 3.1 Class 1 Components ............................................... 4 3.1.1 Reactor Pressure Vessel ...................................... 4 3.1.1.1 Request for Relief No, la, Examination Category B-B, item Bl.2, Reactor Pressure Vessel Tcp Closure Head Me ri d i on al Wel d s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.1.1.2 Request for Relief No. Ib, Examination Category B-B, Item Bl.2, Reactor Pressure Vessel Bottom Closure Head Me r i d i o n a l We l d s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.1,1.3 Request for Relief No. 2a, Examination Category B-D, Item Bl.4, Reactor Pressure Vessel Nozzle-to-Vessel Welds and Nozz'i e Inner Radii . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 3.1.1.4 Request for Relief No. 2b, Examination Category B-D, Item Bl.4, Reactor Pressure Vessel Nozzle-to-Vessel Welds and Nozzle Inner Radii ............................. 9 3.1.1.5 Request for Relief No. 6, Examination Category B-G-2, Item Bl.ll, Reactor Vessel Pressure Retaining Bolting ... 12 3.1.2 Pressurizer (Does not apply to BWRs) 3.1.3 Heat Exchangers and Steam Generators (No relief requests) 3.1.4 Piping Pressure Boundary .................................... 14 3.1.4.1 Request for Relief No. 3, Examination Category B-F, item Bl.6, Nozzle-to-Safe End Welds, ard Examination Category B-J, Item B4.6, Branch Pipe Connection Welds ... 14 3.1.4.2 Request for Relief No. 4, Examination Category B-F, item B4.1, Pressure Retaining Dissimilar Metal Welds . . . . 16 3.1.4.3 Request for Relief No. 5, Examination Category B-G-2, Item B4.12, Class 1 Piping Pressure Retaining Bolting . .. 18 3.1.5 Pump Pressure Boundary (No relief requests) iv
3.1.6 Valve Pressure Boundary ..................................... 20 3.1.6.1 Request for Relief No. 7, Examination Category B G 2,
- Item B6.9, Valve Pressure Retaining Bolting . . . . . . . . . . . . . 20 3.1.6.2 Request for Relief No. 10, Examination Category B M 2, g
item B6.7, Valve Internal Pressure Boundary Surfaces .... 22 3.1.7 General ..................................................... 24 3,1.7.1 Request for Relief No. 8, Examination Category B K 1, items B4.9, 35.4, and B6.4, Integrally Welded Supports M for Pi pi ng , Pump s , and Val ves . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 L
3.1.7.2 Request for Relief No. 9 Examination Category B K 2, Items B4.10. B5.5, and B6.5, Component Supports for Cl ass 1 Piping, Pumps, and Valves . . . . . . . . . . . . . . . . . . . . . . . 29 3.2 Class 2 Components .............................................. 32 L 3.2.1 Pressure Vessels (No relief requests) 3.2.2 Piping ...................................................... 32 3.2.2.1 Request for Relief No. 12. Examination Category C G, items C2.1, C2.2, and C2.3, Pressure Retaining Welds in Class 2 Piping ....................................... 32 3.2.3 Pumps (No relief requests) 3.2.4 Valves (Noreliefrequests) 3.2.5 General ..................................................... 34
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3.2.5.1 Request for Relief No. II, Examination Category C E-1, Items C2.5 C3.3, and C4.3, Integrally Welded Supports for Cla',s 2 Piping, Pumps, and Valves ................... 34 3.3 Class 3 Comporents (No relief requests) 3.4 Pressure Tests (No relief requests) 3.5 General (No relief requests) r 4. C0i4CLUSION ......................................................... 38
- 5. REFERENCES ......................................................... 40 v i
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- i. , TECHNICAL EVALUATION REPORT ON THE FIRST 10 YEAR INTERVAL INSERVICE INSPECTION RELIEF REQUESTS:
NEW YORK POWER AUTHORITY, JAMES A. FITZPATRICK NUCLEAR POWER PLANT, DOCKET NUMBER 50 333
- 1. INTRODUCTION The James A. FitzPatrick Nuclear Power Plant First 10 Year Interval Intervice Inspection (ISl) Program Plan vtas previously evaluated in the Nuclear Regulatory Commission's (NRC) Safety Evaluation Report (SER) dated January 31, 1984 (Reference 1), and was determined to be acceptable for implementation during the first inspection interval. This SER also granted, conditionally granted, or denied requests for relief.
The first 10 year inspection interval ended July 28, 1985. The Licensee, New York Power Authority, subsequently submitted additional requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI (Reference 2) requirements which the Licensee determined to be impractical for the first inspection interval.
These additional relief requests for the first inspection interval were included in Attachment 1 of the August 6, 1987 (Reference 3) submittal of the " Summary Report of the First 10-Year Interval."
As required by 10 CFR 50.55a(g)(5) (Reference 4), if the licensee determines that certain Code examination requirements are impractical and requests relief from them, the licensee shall submit information and justifications l to the NRC to support that determination.
l Pursuant to 10 CFR 50.55a(g)(6), the NRC will evaluate the licensee's l determinations under 10 CFR 50.55a(g)(5) that Code requirements are impractical. The NRC may grant relief and may impose alternative l l requirements that are determined to be authorized by law, will not endanger l
life or property or the common defense and security, and are otherwise in l the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
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The available information in the Au9ust 6, 1987 submittal tas reviewed, in a letter dated August 15, 1988 (Reference 5), the NRC requested additional [
information that was required in order to complete the review of these relief requests. The requested information was provided by the Licensee in i a letter dated September 20, 1988 (Reference 6). [
The additional requests for relief for the first inspection interval are i evaluated in Section 3 of this report. Unless otherwise stated, references i to the Code refer to the ASME Code,Section XI,1974 Edition including '
Addenda thrcugh Summer 1975 (74575).
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- 2. EVALVATION OF INSERVICE INSPECTION PROGRAM PLAN
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The James A. FitzPatrick Nuclear Power Plant First 10 Year Interval ISI Program Plan was previously evaluated in the NRC's SER, dated January 31, 1984, and was determined to be acceptable for implementation l during the first inspection interval. This SER also granted, conditionally granted, or denied requests for relief.
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- 3. EVALUATION OF RELIEF REQUESTS Additional requests for relief from the ASME Code requirements which the L
Licensee has determined to be impractical for the first 10 year inspection interval are evaluated in the following sections.
3.] Class 1 Components 3.1.1 Reactor Pressure Vessel 3.1.1.1 Recuest for Relief No. la. Examination Cateoory B-B. Item Bl.2.
Reactor Pressure Vessel Too Closure Head Meridional Welds Code Reouirement: Section XI, Tables IWB 2500 and IWB 2600, r Examination Category B-8, Item Bl.2 requires a volumetric examination of at least 10% of the length of each reactor pressure vessel (RPV) meridional head weld. The examination may be performed at or near the end of each inspection interval.
Licensee's Code Relief Reouest: Relief is requested from examining the full Code required volume of all the meridional welds in the vessel top closure head:
VV-TH 1A VV TH lE VV-TH 1B VV-TH lF VV TH-lc VV-TH lG VV-TH 10 VV-TH lH Licensee's Procosed Alternative Examination: The Licensee states that 9.6% of each weld was actually examined during the first 10 year inspection interval but that the full Code-required examination will be performed during subsequent inspection intervals.
l Licensee's Basis for Recuestina Relief: The Licensee states that, due to an administrative error, only 9.6% of each weld 4
tras actually examined (i.e., 8 inches /83 inches total length of f; -
each weld). This error was discovered after the 1985 refueling outage was completed and the plant restarted. The Code-required extent of examination will be performed in the future. The Licensee also states that, since no indication was found in the lengths examined and since the unexamined length is so small, this minor discrepancy will not affect the safety of the plant.
Evaluation: The regulations allow for granting relief on the basis of inaccessibility or impracticability. However, the Licensee has not demonstrated that the Code required examination of these welds was impractical to perform or that the welds were inaccessible during the first 10 year interval.
Relief requested solely because an inspection was missed should normally not be considered.
Because no indications were found, we concur that this minor discrepancy should not affect the safety of the plant.
However, it is our position that the Code requirement is a minimum and that the Licensee should not have hesitated to exceed the minimum examination requirements, in order to be in compliance with the " minimum" Code requirement, at least 107,of each of the RPV meridional head welds should have received a volumetric examination. By being more diligent in documenting examinations and examination results, the Licensee could have corrected this mistake during the first 10 year inspection interval.
Conclusions:
Based on the above evaluation, it is concluded that, at this time, requiring the Licensee to examine the small percentage (0.4?.') of the weld volume that was missed (0.3 inch of each weld) would result in an undue burden without a compensating increase in weld integrity verification or plant safety. Therefore, it is recommended that relief be granted as 5
l requested. However, the Licensee should be reminded to be more diligent in the documentation of examination results and confirmation that "at least" the minimum Code requirements have been met prior to completion of the Code required examinations.
3.1.1.2 Reauest for Relief No. Ib. Examination Cateaory B B. Item Bl.2.
Reactor Pressure Vessel Bottom Closure Head Meridignal Welds (2de Reauirement: Section XI, Tables IWB 2500 and IWB-2600, Examination Category B B, Item Bl.2 requires a volumetric examination of at least 10% of the length of each RPV meridional head weld. The examination may be performed at or near the end of each inspection interval.
Licensee's Code Relief Reo;ill: Relief is requested from performing the Code required volumetric examination of the following meridional welds in the vessel bottom closure head:
VV BH-2B VV BH 2E VV BH 2C VV-BH 2F Relief is also requested from examining the full Code required volume of bottom closure head meridional welds VV-BH 2A and VV-BH 2D.
Licensee's Procosed Alternative Examination: The Licensee states that 5% of each of welds VV BH-2A and VV-BH-2D was examined during the first 10 year inspection interval. None of the other subject welds were examined during the first 10 year inspection interval.
Licensee's Basis for Reauestina Relief: The Licensee states that inspection of the Code-required 10% of the length of each of these welds is not possible due to restricted accessibility. Access is limited to four 18 inch diameter i
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i manways 90 degrees apart in the vessel support skirt. In !
- - addition, the control rod drives and twelve core instrument l
penetrations provide extensive interference. Five percent of each of welds VV BH 2A and VV BH 2D was inspected during the first 10 year inspection interval. Since inspection of the other welds is not possible, relief is requested from 100". of the Code required extent of examination of all the subject welds except VV BH 2A and VV-BH 20. Relief from 50% of the '
Code required extent of examination is requested for welds -
VV BH 2A and VV-BH 2D. The Licensee also states that, as no indications have been discovered in welds VV-BH 2A and VV BH-20, nor in the welds of the top head, this relief will not affect the safety of the plant. '
Evaluation: The volumetric examination of the RPV bottom head meridional welds is impractical to perform to the extent required by the Code because the design of the RPV bottom head assembly does not permit access for examination. Drawings detailing the interferences from the control rod drive and instrument penetrations and the limited access were included as Enclosure 5 of Attachment IV of the Licensee's August 27, 1986 submittal (Reference 7).
Conclusions:
Based on the above evaluation, it is concluded that the Code requirement for these RPV bottom head meridional welds is impractical for the first 10 year interval.
Therefore, it is recommended that relief be granted as requested.
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3.1.1.3 Recuest for Relief No. 2a. Examination Cateaory B D. Item B1.4. !
Reactor Pressure Vessel Nozzle-to-Vessel Welds and Nozzle Inner F_itdii Code Recuirement: Section XI, Tables IWB 2500 and IWB 2600, t Examination Category B-D, Item Bl.4 requires a 100% volumetric .
examination of the RPV nozzle-to-vessel welds and nozzle inside [
radius sections as shown in Figure IWB 25000. All nozzles shall be examined during each inspection interval.
Licensee's Code Relief Recuest: Relief is requested from performing the full Code required volumetric examination of the nozzle to vessel welds and inner blend radii of the following RPV nozzles:
N0ZZLE NAME/ FUNCTION N 2A Recirculation System Inlet N 2E Recirculation System Inlet N 2H Recirculation System Inlet .
N-2J Recirculation System Inlet N 3C Main Steam Outlet N-8B Jet Pump Instrumentation Licensee's Procosed Alternative Examination: The Licensee states that a limited Section XI volumetric examination was l
performed on the RPV nozzle-to-vessel welds and nozzle inside l radius sections. Although the extent of examination performed was not recorded, the Licensee estimates that the examination coverage is similar to that reported in Request for Relief 2b (70 to 93%).
Licensee's Basis for Reauestino Relief: The Licensee states that the examinations that were performed were restricted by interference from permanent structures such as nonremovable vessel insulation, instrumentation lines / penetrations, and other nozzles. Because detailed measurements of these interferences were not taken at the time of some of these examinations, the extent of examination actually performed is 8
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not recorded. Although it is likely that the extent of l
- examination completed is similar to that detailed in Relief Request No. 2b (70 to 93%), relief is requested from examination of the nozzle-to vessel welds and inner blend radii I of the subject nozzles due to inaccessibility. ,
Evaluation: The Licensee states that the extent of examination i
actually performed was not recorded and estimates that the welds and nozzle inner radius sections received 70 to 93% of the Code required axial scan examination during the first 10-year inspection interval. The volumetric examination of the subject nozzle-to vessel welds and nozzle inner radius sections is impractical to perform to the extent required by the Code because of the permanently installed insulation and/or permanently installed instrumentation / drain piping. Access to ,
the nozzle-to vessel welds and nozzle inner radius sections would entail modifications to the permanently installed insulation and/or instrumentation / drain piping in order to complete the remainder. However, the Licensee should be more diligent in documenting examinations and examination results in subsequent inspection intervals.
Conclusions:
Based on the above evaluation, it is concluded .
that the volumetric examination of these nozzles is impractical to perform to the extent required by the Code and that the l
limited volumetric examination provides reasonable assurance of l the continued inservice structural integrity. Therefore, it is recommended that relief be granted as requested, i
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3.1.1.4 Reauest for Relief No. 2b. Examination Cateaory B-D. Item Bl.4.
- j. Reactor Pressure Vessel Nozzle-to Vessel Welds and Nozzle Inner
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Code Reauirement: Section XI, Tables IWB-2500 and IWB-2600, l
i Examination Category B-D, item Bl.4 requires a 100% volumetric l
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f exa2ination of the RPV nozzle to vessel welds and nozzle inside radius sections as shown in Figure IWB-25000. All nozzles shall be examined during each inspection interval.
Licensee's Code Relief Reauest: Relief is requested from performing the full Code-required volumetric examination of the '
nozzle-to vessel welds and inner blend radii of the following RPV nozzles:
EXTENT l N0ZZLE/NAME EXAMINED LIMITATION N-1A/ Recirculation 87% Permanent Vessel Suction Insulation N 1B/ Recirculation 93% Permanent Vessel Suction Insulation N-28/Recircul ation 93% Permanent Vessel Inlet Insulation N-2C/ Recirculation 93% Permanent Vessel Inlet Insulation N 2D/ Recirculation 93% Permanent Vessel Inlet Insulation N 2F/ Recirculation 93% Permanent Vessel Inlet Insulation N-2G/ Recirculation 93% Permanent Vessel inlet Insulation N-2K/ Recirculation 93% Permanent Vessel Inlet Insulation '
N 4A/Feedwater 70% 1" Centerline 2" away; Nozzle and surface curvature of blend area causing transducer to lift off N-4C/Feedwater 70% 1" Centerline 2" away; Nozzle and surface curvature of blend area causing transducer to lift off N-5B/ Core Spray 86% Thermocouple connections at permanent insulation structure Licensee's Proposed Alternative Examination: The RPV nozzle-to vessel welds and nozzle inside radius sections received volumetric examination to the maximum extent practical (as listed above).
Licensee's Basis for Reauestina Relief: The Licensee states that examination of the reactor vessel nozzle to vessel welds 1
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and nozzle inner blend radii in the areas listed above is
- . restricted by access limitations. Accessibility is limited by permanent insulation and/or permanently installed instrumentation / drain piping. Detailed measurements were taken of these areas, and relief from the full Code-required examination is requested. These restrictions apply only to the axial scans of the volume in question, both for the nozzles listed above and in Relief Request 2a. The Code-required volume was inspected completely by circumferential scans. The limitations listed reflect the variation in the available distance from the nozzle for performance of the axial scan around the nozzle circumference. The Licensee also states, since the bulk of the nozzle weld areas was inspected, these relief requests (both 2a. and 2b.) will not affect the safety of the plant.
Evaluation: The volumetric examination of the subject nozzle-to-vessel welds and nozzle inner radius sections is impractical to perform to the extent required by the Code because of the permanently installed insulation and/or permanently installed instrumentation / drain piping. Access to the subject nozzle to vessel welds and nozzle inner radius sections would entail modifications to permanently installed insulation and/or instrumentation / drain piping in order to complete the remainder. A significant percentage (70 to 93%)
of the Code-required axial scan examination was performed on the subject nozzle to-vessel welds and nozzle inner radius sections. Also, the examination volumes were completely inspected by circumferential scans.
Conclusions:
Based on the above evaluation, it is concluded that the volumetric examination of these nozzles is impractical to perform to the extent required by the Code and that the limited volumetric examination provides reasonable assurance of the continued inservice structural integrity. Therefore, it is recommended that relief be granted as requested.
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1 3.1.1.5 Recuest for Relief No. 6. Examination Catecorv B G-2. Item Bl.ll. Reactor Vessel Pressure Retainino Boltino Code Recuirement: Section XI, Tables IW8 2500 and IWB 2600, Examination Category B G 2, Item Bl.11 requires a 100% visual examination of the reactor vessel pressure retaining bolting less than 2 inches in diameter. The areas shall include bolts, studs, and nuts. The examinations performed during each inspection interval shall cover 100% of the bolts, studs, and nuts. Bolting may be examined either in place under tension, when the connection is disassembled, or when the bolting is removed.
Licensee's Code Relief Recuest: Relief is requested from performing the Code required visual examination of certain reactor vessel pressure retaining bolting of the 137 Control Rod Drives (CRDs) and of the 43 Incore Instrumentation Penetrations.
Licensee's Prooosed Alternative Examination: None. The Licensee states that 57% of the CRDs' bolting was inspected and 16% of the incore instrumentation bolting was inspected during the first 10-year inspection interval. Remote inspection for leakage was also performed on each component during the Class I hydrostatic test at the end of the interval.
Licensee's Basis for Recuestino Relief: The Licensee states that this bolting is inaccessible in place due to the control rod drives and incore instrument penetrations and was inspected only during disassembly for component maintenance / replacement.
During the first 10 year interval, 79 components or 57% of the CRDs' bolting was inspected, and 7 components or 16% of the incore instrumentation bolting was inspected. Relief is requested from the Code-required extent of examination (100%)
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for the first 10 year interval with the above percentages
. inspected instead.
The Licensee also states that, since most bolting failure commonly occurs during loosening and retightening, this relief request will not affect plant safety.
Evaluation: As permitted by the Code, the Licensee has the option to visually examine the bolting in place under tension, when the connection is disassembled, or when the bolting is removed. The subject bolting is inaccessible for the Code required visual examination while in place due to the control rod drives and incore instrument penetrations. The Licensee has performed the Code required visual examination of 57% of the CRD bolting and 16% of the incore instrumentation bolting which were made accessible during disassembly for component maintenance / replacement. The disassembly of these components for the sole purpose of inspection is a major effort and, in addition to the possibility of additional wear or damage to the surfaces of the bolting / components, could result in personnel receiving excessive radiation exposure. The limited Section XI visual examination of the subject bolting, along with the remote inspection for leakage during the Class I hydrostatic test, provides reasonable assurance of the integrity of the bolting.
Conclusions:
Based on the above evaluation, it is concluded that compliance with the specific requirements of Section XI is impractical for the subject bolting. Therefore, it is recommended that relief be granted as requested.
3.1.2 Pressurizer (Does not apply to BWRs) 3.1.3 Heat Exchanaers and Steam Generators (No relief requests) 13
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3.1.4 Pioina Pressure Boundary 3,1.4.1 Recuest for Relief No. 3. Examination Cateaory B F. Item Bl.6.
Nozzle to Safe End Welds. and Examination Cateaory B-J. Item - !
B4.6. Branch Pice Connection Welds Code Reauirement: Section XI Tables IWB-2500 and IWB 2600, Examination Category B F, item Bl.6 requires both 100% ,
volumetric and surface examinations of the pressure retaining dissimilar metal nozzle to-safe end welds. The areas shall include dissimilar metal welds between combinations of carbon, low alloy, or high tensile steels and stainless steels, nickel chromium iron alloys, and nickel-copper alloys. This ;
shall include the base material for at least one wall thickness beyond the edge of weld. j Examination Category B J, item B4.6 requires a 100% volumetric examination of 25% of the branch pipe connection welds exceeding 6 inches in diameter. The areas shall include the weld metal, the base metal for one pipe wall thickness beyond the edge of the weld on the main pipe run, and at least 2 inches of the base metal along the branch run, licensee's Code Relief Reauest: Relief is requested from performing the Code required surface and volumetric examinations of Jet Pump Instrumentation Nozzle safe-end weld N88 SE and from performing the Code-required surface examination of Jet Pump Instrumentation Nozzle safe-end weld NBA-SE. Relief is also requested from performing the Code required volumetric examination of the following penetration seal welds (Examination Category B-J):
"A" Jet Pumo Assembiv "B" Jet Pomo Assembiv N8A-SE 1 N8B SE-1 NBA SE-2 N8B-SE-2 NBA-SE 3 N8B-SE-3 4-117 4-118 14
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- . Licensee's Pronosed Alternative Examination
- The Licensee !
reports that both volumetric examination and visual examination (VT-2) were performed on weld N8A SE in lieu of the Code required surface examination due to excessively high radiation levels of approximately 40 rem /hr on contact. Attachment 3 of >
the August 6,1987 submittal details the radiation survey :
performed at that time.
Licensee's Basis for Recuestino Relief: The Licensee states !
that volumetric and surface examinations of the Jet Pump Instrumentation Nozzle safe end and penetration seal welds l could not be performed due to extremely high radiation fields.
Attachment 3 of the August 6,1987 submittal is a radiation survey taken during inspection attempts in the 1985 refueling outage. Even after flushing, the shielded dose exceeds 5 rem /hr. Significantly, the lead shielding is directly over the areas to be inspected and would require removal before inspection. Visual examinations ware performed, including one '
during the vessel hydrostatic test to detect evidence of leakage. The Licensee also states that, due to the alternative examinations performed, this relief request will not affect the safety of the plant.
Evaluation: The Code required volumetric and/or surface examinations of the subject welds are impractical to perform for the first 10 year inspection interval because of the ALARA concerns. However, the Licensee either has examined these welds or has committed to examine these welds during the second 10 year inspection interval.
As stated in the Licensee's September 20, 1988 submittal, the .
Licensee inspected weld N8B SE (volume and surface) during the 1987 refueling outage after decontamination by flushing as part of the IGSCC program for the second interval. The Licensee has scheduled decontamination of the Jet Pump Instrumentation 15
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Nozzle assemblies for the 1988 refueling outoge. Accordingly, I nozzle to-safe end weld NBA SE is scheduled for inspection as required by NUREG 0313, Revision 2.
With regard to the Jet Pump Instrumentation Nozzle penetration i seal welds, the Licensee performed volumetric and surface i examinations on "B" Jet Pump assembly welds during the 1987 refueling outage. This was the first outage of the second I- 10-year interval. These inspections reflected the requirements i of the second 10-year interval ISI, the draft of NUREG 0313, Revision 2, and Generic Letter 84-11. The "A" Jet Pump assembly welds were inspected during the 1988 outage in accordance with NUREG-0313, Revision 2.
Because these welds are being examined during the second 10 year interval, the continued inservice structural integrity will be verified.
Conclusions:
Based on the above evaluation, it is concluded that, for these welds, compliance with the specific '
requirements of Section XI is impractical for the first 10 year inspection interval. Therefore, it is recommended that relief be granted as requested.
3.1.4.2 Reauest for Relief No. 4. Examination Cateaory B-F. Item B4.1.
Pressure Retainina Dissimilar Metal Welds Code Reauirement: Section XI, Tables IWB-2500 and IWB 2600, Examination Category B F, Item Bl.6 requires both 100".
volumetric and surface examinations of the pressure retaining dissimilar metal welds. The areas shall include dissimilar metal welds between combinations of carbon, low alloy, or high tensile steels and stainless steels, nickel-chromium iron alloys, and nickel-copper alloys. This shall include the base material for at least one wall thickness beyond the edge of the weld.
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. Licensee's falg, Relief Recuest: Relief is requested from examining 100% of the Code required volume of the following 24-inch diameter bimetallic welds in the Residual Heat Removal System:
Weld Number Confiouration Weld Number Confiouration 24 10 142 pipe to valve 24-10-130 pipe to valve 24-10 143 valve to-valve 24 10-131 valve to-valve 24 10 144 valve to elbow 24 10-132 valve to-elbow Licensee's Procosed Alternative Examination: The Licensee states that a limited ultrasonic examination was performed on the subject welds. The coverage needed for angle beam insoection could not be obtained. A straight beam ultrasonic examination was used as a "best effort" examination. Also, the required visual and surface examinations were performed.
Licensee's Basis for Recuestino Relief: The Licensee states that the geometry of these welds (i.e., valve-to valve, pipe to valve, elbow-to valve) prevents examination by ultrasonic shear wave techniques. The wall thickness of over 2 inches prevents meaningful radiographic inspection without system draindown and component disassembly. Development of unique calibration blocks is currently under way. Because an adequate, practical examination methodology was not developed, visual, surface, and limited ultrasonic examinations were performed in lieu of volumetric inspection.
Evaluation: The volumetric examination of the subject valve to-valve, pipe-to valve, and valve-to elbow welds is impractical to perform to the extent required by the Code for the first 10-year inspection interval because an examination methodology was not developed for examination of this component / weld geometry during the first 10-year inspection interval. However, the Licensee has committed (in the ISI program plan for the second 10 year inspection interval (Reference 8)) to perform the full Code-required volumetric and 17 i
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[. i L. i surface ext inations of these welds during the second 10 year
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- inspection interval. Therefore, the inservice structural
! integrity of these welds will be verified during the second 10 year inspection interval. The alternative examinations performed provide reasonable assurance of the continued inservice structural integrity.
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Conclusions:
Based on the above evaluation, it is concluded l that, for the subject welds, compliance with the specific l requirements of Section XI is impractical for the first 10-year inspection interval. Therefore, it is recommended that relief be granted as requested.
3.1.4.3 Recuest for Relief No. 5. Examination Cateoorv B G-2. Item B4.12. Class 1 Pioino Pressure Retainino Boltino Code Recuirement: Section XI, Tables IWB 2500 and IWB 2600, Examination Category B G 2, Item B4.12 requires a 100% visual examination of the Class 1 piping pressure retaining bolting less than 2 inches in diameter. The areas shall include bolts, stuas, and nuts. The examinations performed during each inspection interval shall cover 100% of the bolts, studs, and nuts. Bolting may be examined either in place under tension, when the connection is disassembled,' or when the bolting is removed.
Licensee's Code Relief Reauest: Relief is requested from performing the Code required visual examination of the pressure l retaining bolting associated with Flanges A, B, C, and D in the RHR System head spray line.
Licensee's Proposed Alternative Examination: None.
Licensee's Basis for Recuestino Relief: The Licensee states I that, as indicated in previous submittals, this bolting was 18
scheduled for inspection only when these components were ,
disassembled for other maintenance. The Licensee tiso states that, since most bolting failure occurs during loosening and retightening, and since drywell leakage limits would serve as a !
warning of a failed bolt, this relief request will not affect plant safety.
Evaluation: As permitted by the Code, the Licensee has the option to visually examine the bolting in place under tension, when the connection is disassembled, or when the bolting is removed. If the connection is not disassembled for maintenance and the Licensee chooses not to remove the bolting for the sole purpose of inspection, then the bolting should be visually examined while in place under tension. Although the Licensee may not have confidence in this method of examination for determining the condition of the subject bolting, justification has not been supplied to establish that the Code-required visual examination is impractical. Lack of confidence in examination results is not justifiation for relief from the Code requirements. Therefore, there is no reason for this
- bolting to be excluded from the Code-required examination during the first 10-year inspection interval. It should be noted that this relief request was previously denied in the NRC's SER dated January 31, 1984 f or lack of justification.
There was adequate time between the January 31, 1984 SER and ,
the end of the inspection interval (July 28,1985) for the Licensee to perform the Code required examination and, furthermore, this request for relief was resubmitted two years after the end of the first 10 year inspection interval.
It should also be noted that the Licensee submitted a generic request for relief from the Code required visual examination of l pressure retaining bolting 2 inches and less in diameter for the second 10 year inspection interval. This request for relief was denied by the NRC in the SER dated October 27, 1987 (Reference 9) for the same reasons as stated above.
19
r j
, 4
Conclusions:
Based on the above evaluation, it is concluded that the Licensee has not justified the determination of impracticality for the visual examination of the pressure retaining bolting and that the Licensee should be required to j comply with the Code requirements. Therefore, it is recommended that relief be denied.
l 3.1.5 Pumo Pressure Boundary 3.1.6 Valve Pressure Boundary 3.1.6.1 Reauest for Relief No. 7. Examination Catecory B G-2. Item _
B6.9. Valve Pressure Retainino Boltina Code Reouirement: Section XI, Tables IWB-2500 and IWB 2600, Examination Category B G 2, Item B6.9 requires a 100% visual examination of the valve pressure retaining bolting less than 2 inches in diameter. The areas shall include bolts, studs, and nuts. The examinations performed during each inspection interval shall cover 100% of the bolts, studs, and nuts.
Bolting may be examined either in place under tension, when the connection is disassembled, or when the bolting is removed.
Licensee's Code Relief Reauest: Relief is requested from performing the Code required visual examination of the pressure retaining bolting of the following valves:
System Valve Numbers Reactor Water Recirculation 02 MOV 43A 02 M0V 53B 02 MOV 43B 02 MOV 54A 02 MOV 53A 02-MOV 54B Residual Heat Removal RHR 29 10 A0V-25A l RHR B1A 10-A0V-25B L RHR 81B 10 A0V 32 l RHR-88 10 A0V-33 20 l
l
J (continued)
System Valve Numbers Reactor Water Cleanup 12 MOV 15 RWC 62 12 MOV-18 RWC 68 RWC 46 12 MOV 68 Reactor Core Isolation Cooling 13 MOV 15 13 MOV 16 13 MOV-21 13 MOV 22 Core Spray 14 MOV 12A 14 MOV 12B High Pressure Coolant injection 23 MOV 15 23 MOV 16 23 MOV 18 23 MOV 19 Main Steam 29 RV-71A 29 A0V 80A Feedwater 34 NRV lllA FWS 29B FWS 29A Licensee's ProDosed Alternative Examination: None.
Licensee's Basis for Recuestina Relief: The Licensee states that this bolting was scheduled for inspection only when these components were disassembled for other maintenance. The Licensee also states that, since most bolting failure occurs during loosening and retightening and since FitzPatrick has drywell leakage limits, this relief request will not affect plant safety.
Evaluation: As permitted by the Code, the Licensee has the option to visually examine the bolting in place under tension, when the connection is disassembled, or when the bolting is removed, if the connection is not disassembled for maintenance and the Licensee chooses not to remove the bolting for the sole purpose of inspection, then the bolting should be visually examined while in place under tension. Although the Licensee may not have confidence in this method of examination for determining the condition of the subject bolting, justification has not been supplied to establish that the Code-required visual examination is impractical. Lack of confidence in examination results is not justification for relief from the Code requirements. Therefore, there is no reason for this 21
bolting to be excluded from the Code required examination
! during the first 10 year inspection interval. it should be noted that this relief request was previously denied in the NRC's SER dated January 31, 1984 for lack of justification.
There was adequate time between the January 31, 1984 SER and the end of the inspection interval (July 28,1985) for the Licensee to perform the Code required examination and, furthermore, this request for relief was resubmitted two years after the end of the first 10 year inspection interval.
It should also be noted that the Licensee submitted a generic request for ~ relief from the Code required visual examination of pressure retaining bolting 2 inches and less in diameter for the second 10 year inspection interval. This request for relief was denied by the NRC in the SER dated October 27, 1987 for the same reasons as stated above.
Conclusions:
Based on the above evaluation, it is concluded that the Licensee has not justified the determination of impracticality for the visual examination of the pressure retaining bolting and that the Licensee should be required to comply with the Code requirements. Therefore, it is recommended that relief be denied.
l L 3.1.6.2 Reauest for Relief No.10. Examination Cateaory B-M 2. Item l B6.7. Valve Internal Pressure Boundary Surfaces Code Reauirement: Section XI, Tables IWB 2500 and IWB-2600, Examination Category B-M 2, Item B6.7 requires a 1007. visual examination of the internal pressure boundary surfaces on valves exceeding 4 inch nominal pipe size.
One valve in each group of valves of the same constructional design (e.g., globe, gate, or check valve), manufacturing method, and manufacturer that performs similar functions in the 22
system shall be examined during each inspection interval. This examination may be performed on the same valve selected for the Category B M 1 examination. The examinations may be performed I at or near the end of the inspection interval.
Licensee's Code Relief Recuest: Relief is requested from performing the Code required visual examination of the internal surfaces of the following valves:
! SYSTEM VALVE NUMBERS Reactor Water Recirculation 02 MOV-43A 02 MOV-53B 02 MOV-43B 02 MOV-54A 02 MOV-53A 02 MOV 54B Residual Heat Removal RHR 29 10 A0V-25A RHR-81A 10 A0V-25B RHR 88 10 A0V-32 10-A0V 33 Reactor Water Cleanup 12 MOV-15 RWC 46 12 MOV-18 RWC 62 12 MOV-68 RWC-63 Reactor Core Isolation Cooling 13 MOV 15 :3 MOV 16 13 M0V-21 IS-MOV 22 Core Spray 14 MOV-12A CSP-14A 14 MOV-12B CSP 14B High Pressure Coolant Injection 23-MOV-15 23 MOV 16 23 MOV-18 23 MOV-19 Main Steam 29-RV-71A 29-RV-71G 29-RV-71B 29 RV-71K 29 RV-71C 29 RV 71L 29-RV 710 29 RV 71J 29 RV-71E 29 A0V 80A 29 RV-71F 29 A0V 86A Feedwater 34 NRV-Illa FWS 29A FWS-28A FWS-29B FWS 28B Licensee's Proposed Alternative Examination: None.
l Licensee's Basis for Recuestino Relief: The Licensee states l that these components were scheduled for inspection only when
! disassembled for other maintenance. The Licensee also states ,
l l
i 23 1
1 l.
i that, based on the visual inspections performed, combined with )
the drywell leakage monitoring, this relief request will not affect the safety of the plant. l l
Evaluation: The visual examination is performed to determine 1 whether unanticipated severe degradation of the valve body is occurring due to phenomena such as erosion, corrosion, or i cracking. However, previous experience during examination of ,
similar valves at other plants has not shown any significant ,
degradation of valve bodies. The concept of visual exemination [
if the valve is disassembled for maintenance is acceptable.
The disassembly of the valves for the sole purpose of .
inspection is a major effort and, in addition to the possibility of damage to the internal surfaces of the valves, could result in personnel receiving excessive radiation exposure.
Conclusions:
Based on the above evaluation, it is concluded that, for the subject valves, compliance with the specific requirements of Section XI is impractical for the first 10-year interval. Therefore, it is recommended that relief be granted as requested.
3.1.7 General l
3.1.7.1 Recuest for Relief No. 8. Examination Cateaory B-K-1. Items B4.9. 85.4. and B6.4 Intearally Welded Succorts for Pioina.
I Pomos. and Valves 1
Code Recuirement: Section XI (74S75), Tables IWB-2500 and l
IWB 2600, Examination Category B K-1, Items B4.9, B5.4, and l B6.4 require a 100Y. volumetric examination of the integrally welded supports for Class 1 piping, pumps, and valves. The I volumetric examination performed during each inspection interval shall cover 25Y. of the integrally welded supports.
l The areas shall include the integrally welded external support 24 l
r ;
i*
attachments. This includes the welds to the pressure retaining )
- - boundary and the base metal beneath the weld zone and along the !
support attachment member for a distance of two support thicknesses.
1 Licensee's Code Relief Recuest: Relief is requested from
)
performing the Code required surface examination of the j following integrally welded supports (5/8 inch or greater l
! attachment base metal thickness) which were not examined during the first 10 year inspection interval:
SYSTEM B-K-1 COMPONENTS l Reactor Water Recirculation 22 02 2-22A 28 02 2 89A l 22-02-2-22B 28 02 2 89B 28:02-2-31B 28-02 2 890 28 02 2 31D 28 02-2 110F 28 02-2 150 28 02 2 143 28-02-2-158 28-02-2-145 22-02 2-86A 28-02 2 151 22-02-2-87A 28 02 2 156 22-02 2-87B 28 02 2 146B Residual Heat Removal 24-10-132A 24-10 992 24 10-132B 24-10 993 24-10 989 High Pressure Coolant Injection 10-23 668A 14 23 428A Main Steam 24-29-519A 24-29 593 24-29 522A 24-29-542C 24 29 607C 24 29 626A 24-29 543C 24-29-543D 24-29-550A 24 29 574C 24-29-557A 24 29 574D 24-29 5698 37-29-573C Feedwater 12 34 401A 18-34 937A 12-34 944 Licensee's Procosed Alternative Examination: None.
Licensee's Basis for Recuestina Relief: The Licensee has determined that a surface examination is a more meaningful examination than the volumetric examination for these components, as indicated in the later Code Editions, and has 25
performed such inspections during the first 10 year inspection interval without discrimination based on attachment plate thickness. During this interval, up tt April 1985, the extent of examination complied with the James A. FitzPatrick ISI Program's base Code, 74575, which requeed examination of 25%
of all components.
The Licensee states that their understanding of the NRC's position, as detailed in the NRC's April 18, 1986 SER (Reference 10), is that surface examination of these components is acceptable providing the extent of examination follows that of the later Code Editions (i.e., 1977 Edition, Summer 1978 Addenda (77578), or later). This would require examination of 100% of all components whose attachment base metal is 5/8 inch or greater in thickness.
The first ISI interval for James A. FitzPatrick has 'ueen completed without resolution of this issue. This issue does not affect the ISI Program Plan for the second 10 year inspection interval, which is based on the 1980 Code, Winter 1981 Addenda (80W81).
However, fewer than 100% of these components with a 5/8 inch or greater attachment base metal thickness were inspected during the first 10 year inspection interval, as required by 77S78, and some support attachment plates less than 5/8 inch in thickness were examined.
The first 10 year inspection interval for the FitzPatrick plant was effectively completed at the end of the Spring 1985 outage; thus, it was impossible to complete these inspections during the first interval. Subsequent inspections have been conducted in accordance with the ISI program submitted in September 1985. The Licensee summarized the inspections performed during the first interval in the August 6,1987 submittal. This letter also requested relief from, and proposed earlier 26
h scheduling during the second interval of, inspections of the integrally welded support welds (Category B K 1). Therefore, the impracticality of performing inspections is due to the completion of the first interval before final determination of l the required frequency. The requirement of 100% inspection was not definitively expressed until Code Interpretation XI-186 04 was published in 1986, which was subsequent to the completion of the first 10 year interval.
The Licensee states that 52.5% of all support welds were examined, including those with thickness less than 5/8 inch (82 out of 156 total support welds). This total includes 44 support welds of 5/8 inch thickness or greater, out of a total populativn of 86, which represents inspection of approximately 50.0% of these welds. Thus, a total of 42 B K-1 welds require relief from examination during the first 10 year interval.
These 42 B K-1 welds will be inspected early in the second interval as part of the current ISI program.
The Licensee also states that the examination extent originally proposed in the James A. FitzPatrick First 10 Year Interval ISI Program Plan (25%) has been met in all cases. Moreover, since 100% of all required support welds will be inspected during the next interval, performance of " additional" inspections at the start of this next interval is not meaningful. However.
l inspection of these components will be scheduled at the start of the next interval as far as practical. It is the Licensee's position that this relief request will not affect plant safety, as no evidence of service induced failure has been discovered l to date and future inspections will be in accordance with later l Code requirements.
l l Evaluation: The Licensee previously requested relief from the volumetric examination (74S75 Code) of all Class 1 integrally welded external support attachments for piping, pumps, and l valves on the basis that the physical design of integrally l 27 l
l
1,.
.' welded supports (fillets or partial penetration welds) does not Y
permit meaningful volumetric examination. This fact has been recognized by Section XI of the ASME Code and the requirement for volumetric examination of integrally welded supports has been deleted from later editions and addenda of the Code (e.g.,
77S78).
- Pursuant to 10 CFR 50.55a(g)(4)(iv), the Licensee elected to use 77578 of Section XI for the examination method for l' Examination Category B-K-1 welds. This edition and addenda of the Code requires that a surface examination be performed on support attachments for which the support base material design thickness'is 5/8 inch and greater, and which conform to the configuration of integral attachments referenced in Figures IWB-2500-13, 14, and -15. Accordingly, the Licensee proposed to inspect those supports for which relief is requesteo by surface examination.
The above regulation accepting the use of an alternative ASME Coce, such as 77578, also states that all relevant requirements of the more recent edition must be met. Accordingly, the Licensee must increase the frequency of examination of the subject welds from once per plant lifetime to once per inspection interval as required by 77S78.
However, there was confusion on the part of the Licensee as to the 77578 Code-required frequency of examination of B-K-1 welds. The extent of examination was clarified in Code Interpretation XI-1-86-04, which states that 100% of the support members required to be examined shall be examined each inspection interval, This interpretation was issued on October 8,1985 and published July 1986, which was subsequent to the completion of the first 10-year inspection interval.
It was previously concluded in the NRC's April 18, 1986 SER that the Licensee's proposed surface examinations of the 28
subject welds conform to the regulations and provide reasonable
' assurance of the inservice structural integrity of these welds. Relief was granted with the provision that examination of the subject welds be conducted once per inspection interval. This SER was also issued after the end of the first 10 year inspection interval.
Based on the fact that the extent of examination of the B-K 1
- welds was not established until after the end of the first 10-year inspection interval, it is impractical for the Licensee
-to comply with the provisions of the April 18, 1986 SER for these welds. The Licensee has committed to comply with the Code requirements for these welds during the second 10-year inspection interval; thus, the inservice structural integrity will be verified.
Conclusions:
Based on the above evaluation, it is concluded that, for these B-K-1 welds, compliance with the specific Section XI requirements and the provisions of the April 18, 1986 SER for the first 10-year inspection interval is impractical. Therefore, it is recommended that relief be granted as requested.
3.1.7.2 Reauest for Relief No. 9. Examination Cateaory B-K-2. Items 84.10. B5.5 and B6.5. Component Suocorts for Class 1 Pioino.
Pumos. and Valves Code Reauirement: Section XI, Tables IWB-2500 and IWB-2600, Examination Category B-K-2, Items B4.10, B5.5, and B6.5 require a 1007. visual examination of all component supports for Class 1 piping, pumps, and valves during each inspection interval. The support settings of constant and variable spring type hangers, snubbers, and shock absorbers shall be verified. The areas subject to examination shall include the component supports that extend from the piping, valve, and pump attachment to and including the attachment to the supporting structure.
29
y
-.-- Licensee's Code Relief Reauest: Relief is requested from performing the Code required visual examination of the following component supports which were not examined during the first 10-year inspection interval:
PERCENTAGE EXAMINED (NUMBER EXAMINED / SUPPORTS SYSTEM TOTAL POPULATION) NOT EXAMINED Recirculation 94% (49/52) 02-2-18-S-15 02-2-2B-S-4 02-2-9B AN-10*
Residual Heat 86% (32/37) 10 2C-AN-205 Removal 10-43-AS-236 10-14A-NS-240B 10-43 AN-230 10-43-AN-229 Reactor Water 95% (23/24) 12-14-NS-12 Cleanup Reactor Core 95% (19/20) 13-4A-NS-1A Isolation Cooling Main Steam 94% (55/58) 29-lC AN 23B 29-lC-AN-28 29-lD-AN-40A
- This support will be eliminated during the 1987 refueling outage as part of the by-pass line removal, licensee's Proposed Alternative Examination: None.
Licensee's Basis for Reauestina Relief: The Licensee states that relief is requested from examination of the supports listed above since, for some systems, fewer than 100% were inspected. These supports will be scheduled for inspection during the first half of the next 10-year interval. The Licensee also states that this relief request will not affect the safety of the plant, as the vast majority of these supports were inspected with little or no evidence of service induced failure.
30
d* Evaluation: The regulations allow for granting relief on the basis of inaccessibility or impracticability. The Licensee has not demonstrated that the Code-required visual examination of these component supports was impractical to perform or that the component supports were inaccessible during the first 10 year inspection interval. Relief that is requested solely because an inspection was missed should normally not be considered.
However, it is noted that 93% of the Code-required visual examinations of component supports were completed during the first 10-year inspection interval, and that these visual examinations of similar component supports showed little or no evidence of service induced degradation. Since the uninspected supports will see the same operating and environmental conditions as many of the inspected supports, a reasonable assurance of the structural integrity of the supports for which relief is requested has been attained.
Conclusions:
Based on the above evaluation and the fact that the Licensee has committed to perform the missed visual examinations during the first half of the second 10-year interval, it is concluded that requiring the Licensee to examine, at tnis time, the small percentage of the supports that were missed would result in an undue burden without a compensating increase in plant safety. Therefore, it is recommended that relief be granted as requested. However, the Licensee should be reminded to be more diligent in the documentation of examinations such that all of the Code required examinations will have been completed prior to the end of the applicable inspection interval.
1 31
a:
", 3.2 Class 2 Comoonents 3.2.1 Pressure Vessels (No relief requests) 3.2.2 Pioina 3.2.2.1 Recuest for Relief No. 12. Examination Cateaory C-G. Items C2.1. C2.2, and C2.3. pressure Retainina Welds in Class 2 Pioina Code Reauirement: Section XI, Tables IWC 2520 and IWC-2600, Examination Category C-G, items C2.1, C2.2, and C2.3 require a 100% volumetric examination of the circumferential butt welds, longitudinal weld joints in fittings, and branch pipe-to-pipe weld joints in Class 2 piping.
Licensee's Code Relief Reauest: Relief is requested from performing the Code-required volumetric examination of two, Examination Category C-G, Class 2 piping welds.
Licensee's Procosed Alternative Examination: The Licensee states that inspection of two additional Examination Category C-G welds, in the Containment Air Dilution System (an air system receiving non-Code-required, augmented inspections),
will'be performed during the first half of the next interval to meet the program requirements.
Licensee's Basis for Recuestina Relief: The Licensee < 1tes that the NRC's April 18, 1986 SER approved combining Class 1, 2, and 3 components into one inspection program with a common inspection interval. To do this, the Licensee proposed completion of 50% of the Code requirements for Class 2 and 3 components during the February 1985 outage. Inspection of two additional Examination Category C-G welds, in the Containment Air Dilution System (an air system receiving non-Code-required, 32 ,
l
augmented inspections), will be performed during the first half of the next interval to meet the program requirements. The Code-required inspection percentages, as modified in the April 18, 1986 SER, have been met otherwise. It is the Licensee's position that this relief request will not affect plant safety, as no evidence of service induced failure has been discovered. Future inspections will be in accordance with later Code requirements.
Evaluation: The Licensee had previously committed to complete 50% of the required inspections of Class 2 and 3 components during the Reload 6/ Cycle 7 refueling outage. The Reload 6/ Cycle 7 refueling outage ended in May 1985 and the Licensee failed to examine two of the required Class 2 piping welds.
The regulations allow for granting relief on the basis of inaccessibility or impracticability. The Licersee has not demonstrated that the Code-required examination of these welds was impractical to perform or that the welds were inaccessible during the first 10-year inspection interval. Relief that is requested solely because an inspection was missed should normally not be considered.
However, as the Licensee has reported, examinations of the welds that were examined during the February 1985 outage revealed no evidence of service induced indications. Since the two uninspected welds have seen the same operating and environmental conditions as many of the inspected welds, a reasonable assurance of the structural integrity of the welds for which relief is requested has been attained.
Conclusions:
Based on the above evaluation and the fact that the Licensee has committed to perform the examination of the missed two welds during the first half of the second 10-year interval, it is concluded that requiring the Licensee to 33 1
examine, at this. time, the two welds that were missed would
- ' ' result in an undue burden without a compensating increase in weld integrity verification or plant safety. Therefore, it is recommended that relief be granted as requested. However, the Licensee should be reminded to be more diligent in the documentation of examinations such that all of the Code required examinations will have been completed prior to the end of the applicable inspection interval.
3.2.3 Py.m.g1 (No relief requests) 3.2.4 Valves (No relief requests) 3.2.5 General 3.2.5.1 Reauest for Relief No. 11. Examination Cateaory C-E-1. Items C2.5. C3.3. and C4.3. Intearally Welded Succorts for Class 2 Pioina. Pumos. and Valves Code Reauirement: Section XI, Tables IWC-2520 and IWC-2600, Examination Category C-E-1, Items C2.5, C3.3, and C4.3 require a 100% surface examination of the integrally welded supports for Class 2 piping, pumps, and valves. The examinations performed during each inspnction interval shall cover 100% of the major load bearing elements of the support structure and hanger. The areas subject to examination shall include the external support attachments. This includes the welds to the pressure retaining boundary and the base metal beneath the weld zone and along the support attachment member for a distance of two support thicknesses.
Licensee's Code Relief Reauest: Relief is requested from performing the Code-required surface examination of the C-E-1 welds that were not examined during the first 10-year inspection interval.
34
- Licensee's Proposed Alternative Examination: The Licensee
' states that examinations necessary to meet 50% of the total will be performed during the first half of the second 10-year inspection interval.
Licensee's Basis for Recuestina Relief: The Licensee states that the NRC's April 18, 1986 SER approved combining Class 1, 2, and.3 components into one inspection program with a common inspection interval. To do this, the Licensee proposed completion of 50% of the Code requirements for Class 2 and 3 components during the February 1985 outage. However, for Code Category C-E-1, fewer than 50% of the specific Code requirements were completed by the end of the first 10-year interval. Examinations necessary to_ meet 50% of the total will be performed during the- first half of the next interval.
However, . inspection of these components will comply with the Code currently in effect and, therefore, will include only those components whose attachment plate is greater than 3/4 inch thick. The following table shows the number of welds in one equivalent stream of those systems that did not receive inspection'of 50% or greater of its C-E-1 components and indicates the total number of welds examined:
50% EQUIVALENT NUMBER SYSTEM STREAM EXAMINED Residual Heat 43 29 Removal Reactor Core 5 2 Isolation Cooling Core Spray 6 2 Containment Air 6 5 Dilution (CAD)
It is the Licensee's position that this relief request will not affect plant safety, as no evidence of service induced failure has been discovered. Future inspections will comply with current Code requirements.
35
e
- 1. .
l' di Evaluation: In the Licensee's September 20, 1988 response to the NRC request for additional information, the Licensee states the following:
"The Authority implemented the ISI program based on the 1974 Edition, Summer 1975 Addenda of Section XI of the ASME Boiler Pressure Vessel Code during the Spring / Summer 1980 refueling outage. Prior to that time, inservice inspections at the FitzPatrick plant were performed in accordance with the 1970 Edition of Section XI. This mid-interval Code update resulted in a significant expansion of ISI requirements. The 1970 Edition had required inspection of only those components which are now considered Class 1, while the newer Code expanded-the scope of inspection to
. include Class 2 and Class 3 components. Therefore, while the initial FitzPatrick plant ten-year interval for Class 1 components ended July 28, 1985, the actual interval for the Class 2 and 3 components was at its midpoint. The Authority, in a letter dated March 4, 1985, committed to meet 50% of the Code requirements for inspections of the Class 2 components in order to consolidate the inspection intervals. . . . for Code Category C-E-1, the 1974 Edition, Summer 1975 Addenda, required 100%
inspection of non-exempt welds for one equivalent piping stream. This corresponds to 50% of an equivalent stream for each system containing Code Category C-E-1 components. . . . not all systems received inspection of 50% or greater of its C-E-1 components. . . .
The 22 welds needed to achieve 50% inspection exist in a population of hundreds. For example in the RHR system, there are 133 C-E-1 welds. Out of these 133, 14 must be inspected to achieve 50% of one equivalent stream. The welds are not uninspectable due to physical inaccessibility. The necessary weld examinations will be performed during the second interval. The relief requested is based on the fact that the first interval is over, some components were not inspected during the interval, and these will be inspected during the second interval. . . ."
The regulations allow for granting relief on the basis of inaccessibility or impracticability. The Licensee has not demonstrated that the Code-required examination of these welds was impractical to perform or that the welds were 36 1
i iei
, .- inaccessible. Relief that is requested solely because an lo -* ' inspection was missed should normally not be considered.
However, as the Licensee has reported, examinations of the integrally welded supports that were examined during the February 1985 outage revealed no evidence of service induced indications. Since many of the uninspected supports have seen the same operating and environmental conditions as the inspected supports, a reasonable assurance of the structural integrity of the welds for which relief is requested has been attained.
Conclusions:
Based on the above evaluation and the fact that the Licensee has committed to perform the examinations of the missed integrally welded supports during the first half of the second 10-year interval, it is concluded that requiring the Licensee to examine, at this time, the integrally welded supports that were missed would result in an undue burden without a compensating increase in weld integrity verification or plant safety. Therefore, it is recommended that relief be granted as requested. However, the Licensee should be reminded to be more diligent in the documentation of examinations such that all of the Code required examinations will have been completed prior to the end of the applicable inspection interval.
3.3 Class 3 Comoonents (No relief requests) 3.4 Pressure Tests (No relief requests) 3.5 General (No relief requests) 37 i
n +
, ~.
3 .
- 4. CONCLUSION tv-Pursuant to 10 CFR 50.55a(g)(6), it has been determined that certain Section XI required inservice examinations are impractical to perform. In all cases except Requests for Relief la, 5, 7, 9,11, and 12, the Licensee has demonstrated that specific Section XI requirements are impractical. The regulations allow for granting relief on the basis of inaccessibility or impracticability.
Requests for Relief 5 and 7 have not been granted as the Licensee has not demonstrated that the Code-required examination of the subject welds / components is impractical to perform or that the welds / components are inaccessible, Relief that is requested solely because an inspection was missed should normally not be considered. However, Requests for Relief la, 9,11, and 12 have been granted because either the Licensee has met the intent of the Code or has made the commitment to complete the missed examinations during the first part of the second inspection interval. Denying relief at this time for Requests for Relief la, 9,11, and 12 would result in an undue burden on the Licensee without a compensating increase in the level of plant quality and safety. By being more diligent in documenting examinations and examination results, the Licensee could have eliminated the need for these four requests for relief for the first 10 year inspection interval.
This technical evaluation report has not identified any practical method by which the Licensee can meet all the specific inservice inspection requirements of Section XI of the ASME Code for the existing James A. FitzPatrick Nuclear Power Plant facility. Requiring compliance with all the exact Section XI required inspections would entail redesign of a significant number of plant systems, acquisition of sufficient replacement components, installation of the new components, and a baseline examination of these components. Even after the redesign efforts, complete compliance with the Section XI examination requirements probably could not be achieved. Therefore, it is concluded that the public interest is not served 38
J ,
, by imposing certain provisions of Section XI of the ASME Code that have been
- ' determined to be impractical. Pursuant to 10 CFR 50.55a(g)(6), relief is allowed from these requirements which are impractical to implement if granting the relief will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
39
l s ,
fx 5. REFERENCES 3 -; o l .- Letter, dated January 31, 1984, D. B. Vassallo (NRC) to J. P. Bayne '
[New York Power Authority;(NYPA)), " Safety Evaluation Report Related to
. Requests for Relief from Inservice Inspection Requirements" for the James A. FitzPatrick Nuclear Power Plant First- 10-Year Interval.
- 2. American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Division 1:
1974 Edition through Summer 1975 Addenda 1977 Edition through Summer.1978 Addends
- 3. Letter, dated August 6, 1987, J. C. Brons (NYPA) to NRC, submittal of the " Summary Report of the First 10-Year Interval."
- 4. Code of Federal Regulations, Volume 10, Part 50.
- 5. Letter, dated August 15, 1988, H. I. Abelson (NRC) to J. C. Brons (NYPA), request for additional information with regard to the first 10-year inspection interval relief requests.
- 6. Letter, dated September 20, 1988, J. C. Brons (NYPA) to NRC, " Response to Requests for Additional Information."
- 7. Letter, August 27, 1986, J. C. Brons (NYPA) to D. R. Muller (NRC),
response to request for additional information on the James A.
FitzPatrick ISI Program Plan for the Second 10-Year Interval.
- 8. Letter, dated September 30, 1985, J. C. Brons (NYPA) to D. B. Vassallo (NRC), " James A. FitzPatrick Nuclear Power Plant Second 10-Year Interval Inservice Inspection Program Plan, Revision 0."
- 9. Letter, dated October 27, 1987, R. A. Capra (NRC) to J. C. Brons (NYPA), " Safety Evaluation Report on the Second Ten-Year Inservice Inspection Program for James A. FitzPatrick Nuclear Power Plant."
- 10. Letter, dated April 18, 1986, D. R. Muller (NRC) to J. C. Brons (NYPA),-
" Safety Evaluation Related to Request for Reevaluation of Request for Relief From First 10-Year Inservice Inspection Requirements."
40
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New York Power Authority, e- -
James A. FitzPatrick Nuclear Power Plant, August : 198h.*
Docket Number 50-333 4 5 N oa caANr w vein FIN-D6022 (Proj. 5) !
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'n ' report presents the rusults of the evaluation of the James A. FitzPatrick Nucwar Power Plant inservice inspection (ISI) risquests for relief fram the American
! Society of Mechanical Dyineers (ASME) Boiler ard Pressure Vessel Code Section XI h requirements which the Licensee has detennined to be impractical for the first l --
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