ML20010E273
| ML20010E273 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/01/1981 |
| From: | MISSISSIPPI POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20010E271 | List: |
| References | |
| PROC-810901, NUDOCS 8109030258 | |
| Download: ML20010E273 (100) | |
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f MISSISSIPPI POWER AND LIGHT COMPANY PRESERVICE INSPECTION PROGRAM GRAND GULF NUCLEAR STATION UNIT 1 l
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REQUEST FOR RELIEF 00002 IfiSERVICE IfiSPECT10fi I
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Component:
Peripheral Control Rod Drive Housings welds (Tube to Tube, Tube I
to Flange) and bolting located on CRD Housings and in-Core Hous-ings.
I Code:
These portions of the CRD and In-Core Housings were designed and fabricated to the ASME Section Ill, class I requirements.
Applica-1 ble Pre / Inservice Inspections to be performed in accordance with the ASME Section XI, 1977 Edition through and including summer 1978 i
- addenda, j
Code Requirement 1.
Peripheral control Rod Prive Housings welds are required to be j
Surface Examined (Dye Penetrant) once as a Preservice.
Welds located in 10% of the Peripheral CRD Housings require Surface Examination (P.T.) during each ten (10) year Inservice Inspec-tion Interval in accordance with ASME Section XI, IWB-2500-1, examination category B-0.
2.
Pressure retaining bolting for the Flange to Flange joints, located on the CRD and Incore Housings, are required to be visually examined (VT-1) once as a Preservice and once every ten (10) year Inspection Interval in accordance with ASME Sec-tion XI, IWB-2500-1, examination category B-G-2.
O information to The we,d erees end be, ting ere not eccessible for inspect 4on uniess support the the Control Rod Drive (CRD) Support Structure is removed.
A total o
determination that 360 Surface Examination cannot be accurately accomplished from the the code require-outside, due to interference from adjacent CRD Housings.
Inspection i
l ment is impractical of the weld from the inside of the CRD Housing would require that j
the Control Rod Drive mechanism be removed, which could result in damage to the Drive.
With renoval of the Drive, a small amount of Reactor water would escape to the CRD cavity area, possibly causing P
contamination of personnel and equipment.
The time frame associated with the CRD Support Structure removal and CRD mechanism would be approximately six (6) man hours (per drive).
Dosage received by personnel in this interval cannot justify the inspection process to possibly find a fault which would be discovered by excessive leakage in the Drywell Sump (monitored with technical specification limits in effect).
Reasons why relief Request for exemption from Inservice Inspection of the Peripheral should be granted CRD Housing welds (Tube to Tube, Tube to Flange), Eight (8) bolts associated with each Flange of 193 CRD Housings and four (4) bolts I
associated with each Flange of 58 Incore Housings, be granted for l
the following reasons:
1.
The Peripheral CRD Housing welds have been Volumetrically examined by Radiography and Liquid Penetrant methods, and have been Hydrostatic tested in acccedance with ASME Section O
III code requirements.
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2.
All Incore and CRD Housing bolting has been examined in l
accordance w th the requirements of Aide Section III.
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The welds and bolting will be subject to Hydrostatic Testing l
upon completion of each Jutage, per the requirements of l
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4.
If the welds and/or bolts fail while in operation, the maxi-i mum leakage rate, by calculation, will occur at the Peripheral CRD Housing tube to Flange weld. This leak rate will correspond to 681 GPM.
By criteria established in IWB-1200, " exemptions by make up capacity", the normal makeup for GGNS is 878 GPM, l
which is in excess of the calculated maximum leakage.
l 5.
Leak detection is provided with the Leakage Detection System, l
with continuous monitoring in the Control Room.
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REQUEST FOR RELIEF 00003 PRE / INSERVICE INSPECTION O-Component:
Pump casing welds inaccessible, due to concrete encasement for the following pumps:
PUMP PUMP NO.
Low Pressure Core Spray lE21 C001 High Pressure Core Spray lE22 C001 RHR "B" 1E12 C002B Code:
LPCS, HPCS and the RHR "B" pumps were designed and fabricated to the ASME Section III, class 2 requirements.
Applicable Pre /
Inservice Inspection to be performed in accordance with the ASME Section XI,1977 edition through and including summer 1978 l
addenda.
Code Requirement:
The pressure retaining welds located on the LPCS, HPCS and RHR (ASME SECTION XI)
"B" pumps are requirei to be Pre / Inservice surface examined (ragnetic particle) once as a Preservice and once every ten years in accordance with the ASME Section XI, IWC-2500-1 cate-gory C-G.
Information to Inaccessible pump casing welds are located where the concrete suppert the pump support encasement only allows a 3" clearance between the determination that pump casing and the concrete encasement wall (see attach drawing (qJ the code require-for details of the design).
Due to this limited accessibility, ment is impractical:
it is impractical to surface examine those portions of welds located within the surroundings of the concrete pump support encasement.
Reasons why relief Request for an exemption from Pre / Inservice Inspection of in-should be granted:
accessible portions of pump casing welds on HPCS, LPCS, RHR "B" pumps located inside of concretc pump support encasements.
Ex-amination of the accessible pump casing welds will be performed.
1.
These welds have been volumetrically examined by radiography, passed in accordance with the ASME Section III, class 2 require-ments.
2.
The accessible length of each applicable weld will be surface examined (magnetic particle method) in accordance with ASME Section XI, etc.
3.
The failure of these welds, thus leading to failure of the pump, would have no adverse affect on plant safety as redundant ECCS systems are provided.
4.
Annunciators (i.e. low suction pressure, discharge pressure abnormal, etc.) are provided in the Control Room along with other system indicators to alert the operators to abnormal operating O
coodition.
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5.
The systems, including the pumps, are tested at least once f
per 31 days, per Technical Specifications requirements, to i
i ensura operabili ty.
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Pumps will be subject to a system pressure test in accordance I
with ASME Section XI, class 2 requirements.
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E12 - F,HR PUMP CASING WELDS SURFACE TESTED DH-1 Dl:-4 DH-7 DH-25 SB-5 DH-2 DH-5 DH-ll SB-3 SB-6 DH-3 DH-6 DH-12 SB-4 SC-7 RELIEF REQUESTED l
WELDS PARTIALLY C0"PLETED WELDS NOT SURFACE TESTED l
DUE TO ACCESS DUE TO ACCESS SB-2 (18" Done, 54" Not Done)
SB-1 E21 - LPCS PUMP CASING t
WELD 3 SURFACE TESTED l
DH-1 DH-4 DH-7 DH-27 SB-5 DH-2 DH-5 DH-ll SB-3 SB-6 DH-3 DH-6 DH-12 SB-4 SB-7 RELIEF REQUESTED t
O WELDS PAP,TIALLY COMPLETE WELDS NOT SURFACE TESTED DUE TO ACCESS DUE TO ACCESS SB-2 (3" Done, 69" Not Done)
SB-1 E22 - HPCS PUMP CASING WELDS SURFACE TESTED DH-1 DH-4 DH-7 DH-19 SB-6 DH-2 DH-5 DH-19 DH-28 SB-7 DH-3 DH-6 DH-28 SB-5 RELIEr REQUESTED WELDS PARTIALLY COMPLETE WELDS NOT SURFACE TESTED DUE TO ACCESS DUE TO ACCESS SB-4 (68" Done, 4" Not Done)
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t REQUEST FOR RELIEF 00004 PRESERVICE IfiSPECTI0ti 3
Component:
Residual Heat Rerwal Heat Exchanger #1E12B001 A Pressure Retaining fiozzle Welds (f43 & N4)
Code:
The RHR Htat Exchanger fiozzle Welds (fi3 & fi4) were fabricated in accordance with ASME Section III, class 2 requirements.
Preservice Inspection to be perfomed in accordance with ASME Section XI, 1977 edition, through and including, summer ~978 addenda.
Code Requirement:
The RHR Heat Etchanger fiozzle Welds (N3 & N4) are required to (ASME Section XI) be Surface (Magnetic Particle) and Volumetric (Ultrasonics) examined, once as a Preservice and once every 10 year Inservice Inspection interval, in accordance with ASME Section XI, IWC-2500-1, examination category C-A, Item no. C2-20.
Information to Approximately 1160 man nours would be required to remove and support the replace, already installea, insulation on the RHR Heat Ex-determination that changer fiozzles to perform the Surface Examination.
With the code require-already acceptable, more strigent radiography and ultrasonics ment is impractical t>eing performed per ASME Section III and General Electric Com-for Preservice pany specifications on these Nozzles, it is expected that the Inspection:
non-performance of the required Surface Examination will have no adverse effect on plant safety.
Therefore, the expenditure t
of 1160 man hours to remove and replace insulation to perform a Surface Examination is felt to be impractical and will not enhance overall plant safety.
Reasons why relief:
Request for an exemption from Preservice Surface Examinations f
should be granted of RHR Heat Exchanger fiozzle welds N3 & N4.
Required Surface Examinations will be performed during the first 10 year Inspec-tion interval.
1.
fiozzle welds (N3 & N4) have been Volumetrically examined by Radiography and Ultrasonics, passed in accordance with the ASME Section III, Class 2 requirements.
2.
Nozzle welds (N3 & N4) were subject to, and passed, a de-
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sign Hydrostatic Pressure Test during fabrication, in accordance with ASME Section III, class 2 requirements.
3.
The RHR Heat Exchangers will be subject to a system Pressure Test, in accordance with ASME Section XI, class 2 requirements.
4 All modes of RHR, that require the use of the RHR Heat Ex-changers, functicn as two (2) sePerate streams (twe (2)
Heat Exchangers in series per stream).
While there are no provisions for the is11ation of any one (1) Heat Exchanger, O
either one of the two streams can be isolated. The RHR system design criteria allows for the isolation of either v
stream without adversely affecting plant safety or the a-bility of the system to perform its intended function.
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REQUEST FOR RELIEF 00005 PRE / INSERVICE INSPECTION Component:
Thermal Tee Sleeve welds D011A (weld 54) 0011B (weld 58) located on the RHR Return from RWCU Line (G.E. Isometrics RH-8-1 and RH-8-3).
Code:
Pressure Retaining Thennal Tee Sleeve welds (D011A & D011B) were fabricated in accordance with ASME Section III, class 2 requirements.
Pre / Inservice inspections are to be performed in accordance with ASME Section XI, 1977 edition through and including Sumer 1978 addenda.
Code Requirement Thermal Tee Sleeve welds are required to be Surface (magnetic ASME SECTION XI:
particle) and Volumetric (Ultrasonics) inspected once as a Preservice and once evsry ten (10) year Inservice Inspection interval in accordance with ASME Section XI, IWB-2500-1, ex-amination category CF, Item #C5.21.
Information to Due to the design of the Thennal Tee Sleeve welds D0llA support the deter-(weld 54) and D0llB (weld 58), there is not sufficient area mination that the to perfonn a meaningful Ultrasonic examination. Also, the code requirement position of the Thermal Sleeve, as well as lack of internal is impractical:
access, precludes the use of radiography.
Reason why relief Request for exemption from Pre / Inservice Volumetric should be granted:
(Ultrasonics and Radiography) inspections of Thermal Tee welds D0llA (weld 54) and D0llB (weld 58) on the RHR Return to RWCU Line.
- 1) The Thermal Tee welds have been Volumetrically examined by Radiography, found acceptable in accordance with ASME Section III, class 2 requirements.
- 2) The Thermal Tee welds have been Surface examined by Magnetic Particle, found acceptable in accordance with ASME Section XI, class 2 requirements.
- 3) The Thennal Tee welds will be Magnetic Particle inspected every ten (10) year interval in accordance with ASME Section XI, class 2 requirements.
- 4) Thermal Tee welds will be subject to a System Pressure Test in accordance with ASME Section XI, class 2 requirements.
- 5) Leak detection is provided for the Main Stream tunnel, via the leak detection system in the Control Room which would de-tect a leak in the Thermal Sleeve weld.
- 6) The system design would allow for isolation of the Thermal O
Sleeve without adversely affecting plant safety.
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REQUEST FOR RELIEF 00006 INSERVICE INSPECTION Component:
Reactor Recirculation Pumps C001A-N and C001B-N (pump casing).
Code:
Reactor Recirculation pump casings were designed and fabricated to the ASME Section III, Class 1 requirements.
Applicable Pre / Inservice Inspections to be performed in accordance with the ASME Section XI,1977 Edition through, and including, Suniner 1978 Addenda.
Coda Requirement:
The Recirculation pump casing internals are required to be Pre / Inservice Visually Examined (VT-1), once as a Preservice and once every ten (10) year Inservice In-spection interval, in accordance with ASME Section XI, IWB-2500-1, Examination Category B-M-2, Item 12.20.
Infonnation to Visual Examination (VT-1) of the Internals, of subject support the purp, would require disarsembly of the pumps.
This detennination would cause undue high raiiation exposures to plant per-that Code Require-sonnel, which is totally i gainst the concept of the "ALARA"-
ment is impractical:
Program to keep radiation exposures to personnel to a minimum.
The disassembly of these pumps would also impose an undue burden on the r.lant, due to extended outages that l
would be required, and may increase the probability of pump failure.
Reasons why relief Request for exemption from Inservice Visual Examination shoud be granted:
(VT-1) of pump casing internals of Reactor Recirculation pumps C001A-N and C001B-N. Should the pumps be required to be disassembled for other plant reasons, the required Inservice Visual Examinations will be considered.
- 1) The subject pump casings have been Volumetrically examined by Radiography and have been Hydrostatically tested in accordance with ASME Section III requirements.
- 2) Pumps are subject to a System Leakage Test after each refueling outage, and System Hydro-Test during each ten (10) year inspection interval, in accordance with ASME Section XI, Class ~1 requirements.
3)
Vibration monitoring, with indicators provided in the Control Room, are provided on the Recirc. pumps which would detect possible adverse conditions and prevent damage to the pumps.
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- 4) Leak Detection is providad by way of the Leakage Detection System, with continuous monitoring in the Control Room.
- 5) Low and High temperature alarms are provided for each pump with continuous monitoring in the Control Room.
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.m Sheet lm 2 TABLE OF ASME SECTION XI CODE EXEMPTION APPLICATION CODE APPLIED A PPLICATION EDITION PARACRAPH - DESCRII'fl0N YES NO Class 1 1978 IWB-1220 (a) Components connected to and part of the reactor X
Code Exemp-coolant pressure boundary, but exempted from Class 1 requirements tions by regulations of the regulatory authority having jurisdiction at the plant site.
IWB-1220(b) Component connections, piping and associated va12es X
of 1 inch nominal pipe size and smaller, eveept for steam generator tubing.
IWB-1220(c)
Reactor vessel head connections and associated piping X
2 inches nominal pipe size and smaller, made inaccessible by control rod drive penetrations.
Class 2 1978 IWC-1220 (a)
Components of systems or portions of systems that X
Code Exemp-during normal plant operating conditions are not required to operate tions (not or perform a system function but remain flooded under static con-RHR or ECCS) ditions at a pressure of at least 80% of the pressure that the component or system will be subjected to when required to operate; or IWC-1220 (b)
Components of systems or portions of systems, other than X
Residual Heat Removal Systems and Emergency Core Cooling Systems, chat are not required to operate above a pressure of 275 psig (1900 kPa) or above a temperature of 200 (93 C) F1 or IWC-1220(c)
Component connections (including nozzles in vessels X
and pumps), piping and associated valves and vessels (and their supports) that are 4 ir.. nominal pipe size and smaller.
Class 2 1975 IWC-12 20 (a ) Components in systems where both the design pressure X
Code Exemp-and temperature are equal to or less than 275 psig and 200 F, tions (RHR respectively.
or ECCS)
IWC-1220 (b)
Components in systems or portions of systems, other that N/A N/A emergency core cooling systems, which do not function during aormal reactor operation.
Sheet T of 2 TABLE OF ASME SECTION XI CODE EXEMPTION APPLICATION APPLIED CODE APPLICATION EDITION PARAGRAPil - DESCRIPTION YES NO Class 2 1975 IWC-1220 (c)
Components which perforia an emergency core cooling X
Code Exemp-function, provided the control of the chemistry of the contained tic.s (RIIR fluid is verified by periodic sampling and test.
or ECCS)
X l
IWC-1220 (d ) Component connections, piping, and associated valves, and vessels (and their supports), that are 4 in. nominal pipe size and smaller, l
1 l
APPLICATION OF EXEMPTION CRITERIA
SUMMARY
A) CLASS 1 1)
IWB-1220(b) of Summer 1978 Addenda was applied to all welds one (1) inch NPS and smaller.
Due to the large number of lines in ti.ic category, no numerical count was performed.
IWB-1220(c) of Summer 1978 Addenda will be applied to a total of 22 welds for Inservice Inspection.
These welds wera axamined for the Preservice program.
)
1074 B) CLASS 2 (RHR & ECCS ONLY) 1)
Due to the large number of lines smaller than 3" NPS, the weld totals do not include welds on these lines.
No numerical count was performed.
IWC-1220(a) of Summer 1975 Addenda was applied to a total of 201 welds.
4)
IWC-1220(d) of Summer 1975 Addenda was applied to a total of 326 welds.
5)
Total number of welds subject to the 10% salcction criteria 574
- 6) Total number of welds examined 121 O
v
APPLICATION OF EXEMPTION CRITERIA (continued)
C)
CLASS 2 (NON-RHR & ECCS)
- 1) Due to the large number of lines smaller than 3" NPS, the weld totals do not include welds on these lines.
No numerical count was performed.
IWC-1220(b) of Summer 1978 Addenda was applied to a total of 342 welds.
4)
IWC-1220(c) of Suniner 1978 Addenda was applied to a total of 154 welds.
- 5) Total number of welds subject to the 25% selection criteria
( 50% for steam lines )
253 p
- 6) Total number of welds examined
^'
222 GENERAL NOTE:
The required percentages of welds to be examined is ex-ceeded in some systems due to Augmented Inspection requi rements.
Welds Exempt Non-Exempt Examined Per Cent CLASS 1 1074 1074 1074 100%
CLASS 2 1850 1023 827 343 41%
TOTAL 2924 1023 1901 1417 75%
O v
MAKE-UP WATER TREATMENT SYSTEM P&ID M-0033B 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system - 2**
A.
IWC-1220(c) has been applied to:
LINE NUMBER NO. OF WELDS 4-HBB-155 2
B.
Total number of welds subject to selection criteria - 0 C.
Total number of examinations - 0 0
O
AV I
STANDBY SERVICE WATER SYSTEM P&ID M-1061B,D 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system - 19**
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 18-GBB-17 15 B.
IWC-1220(c) has been applied to:
LINE liUMBER NO. OF WELDS 3-HBB-142 2
3-HBB-143 2
C.
Total number of welds subject to selection criteria - 15 D.
Total number of examinations - 4 (Welds are scheduled for Preservice Inspection)
~
[
AU COMP 0NENT COOLING WATER SYSTEM P&ID M-1063B (P42) 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system - 18**
A.
IWC-1220 (b) will be applied to:
LINE NUMBER NO. OF WELDS i
10-HBB-35 4
8-HBB-36 4
8-HBB-37 7
'~~)
10-HBB-38 3
J B.
Total welds subject to selection criteria - 0 C.
Total number of examinations - 0 l
1
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CONDENSATE & REFUELING WATER STORAGE & TRANSFER SYSTEM P&ID M-1065 (Pll) 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system - 49**
A.
IWC-1220(b) was applied to:
LINE NUMBER N0. OF WELDS 12-HBB-30 13 6-HBB-34 3
()
20-HCB-9 12 18-HCB-1 18 6-HCB-8 3
B.
Total number of welds subject to selection criteria - 0 C.
Total number of examinations - 0 i
O
O INSTRUMENT AIR SYSTEM P&ID M-1067A (P53) 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system -
2**
A.
IL.'C-1220(c) was applied to:
LI'E NUMBER NO Of WELDS 3-HBB-45 2
B.
Total number of welds subject to selection criteria - 0 0
C.
Totel number of exemimations - 0 i
l
O 1
O SERVICE AIR SYSTEM P&ID M-1068A (P52) 1.
Number of Class 1 welds in system - 0*
2.
Number of Class 2 welds in system - 0**
(All Class 2 lines on this system are 4 inches NPS and less, therefore, all Class 2 lines are exempt per IWC-1220(c) ).
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PLANT SERVICE WATER SYSTEM P&ID M-1072B (P44) 1.
Number of Class I welds in piping system - 0*
2.
Number of Class 2 welds in piping system - 25**
A.
IWC-1220(b) was applied to:
LINE NUMBER NO. OF WELDS 5-HBB-40 2
4-HBB-40 4
4-HBB-42 5
~
(
)
5-HBB-42 2
4-HBB-39 4
5-HBB-39 2
4-HBB-41 4
5-HBB-41 2
B.
Total number of welds subject to selection criteria - 0 C.
Total number of examinations - 0
b)
s/
O NUCLEAR BOILER SYSTEM P&ID M-1077A,B,c (B21) 1.
Number of Class 1 piping welds in system - 346*
A.
Non-exemp'c welds:
LINE NUMBER NO. OF WELDS 24-DBA-13 14 24-DBA-17 3
15-DBA-25 40 lb-DBA-69 4
lb-DBA-87 8
2-DBA-19 23 2-DBA-21 7
2-DBA-25 12 2-DBA-22 22 3-DBA-23 19 10-DBA-24 2
12-DBA-17 44 18-DBA-13 8
lb-DCA-3 14 28-Class 1 106 8-Class 1 20 B.
Total number of welds subject to selection criteria - 346 C.
Total number of examinations - 346
('N
NUCLEAR BOILER SYSTEM (continued)
P&ID M-1077A,B,C (B21)
( )
2.
Number of Class 2 piping welds in system - 59**
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 24-DBB-141 4
24-DBB-73 29 28-DBB-23 12 28-DBB-143 14 B.
Total number of welds subject to selection criteria - 59 C.
Total number of examinations - 67 (8 of these welds are also in NBZ) 3.
Number of welds examined per NBZ examination criteria and not other-wise examined. (ref. FSAR 3.6A.2.1 (G) )
LINE NUMBER NO. OF WELDS
\\'~ '/
3-DBD-31 6
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O REACTOR RECIRCULATION SYSTEM P&ID M-1078A,B (B33) 1.
Number of Class 1 piping welds in system - 299*
A.
Non-exempt welds:
LINE NUMBER N0. OF WELDS lk" Class 1 8
4" Class 1 14 12" Class 1 96 16" Class 1 26 24" Class 1 82 4-DBA-ll 18 4-DCA-1 12 4-DBA-9 1
2-DC/i-24 18 2-DBA-41 9
2-DBA-40 6
2-DBA-42 5
20-DCA-25 2
20-DBA-64 2
B.
Total number of welds subject to selection criteria - 299 C.
Total number of welds examined - 299 r\\
V
O REACTOR RECIRCULATION SYSTEM (continued',
P&ID M-1078A,B (B33) 2.
Number of Class 2 piping welds in system - 12**
A.
Non-exempt welds - 0 B.
IWC-1220(b) was applied to:
LINE NUMBER NO OF WELDS 5-HBB-lll 2
C.
IWC-1220(c) was applied to:
LINE NUMBER N0. OF WELDS 4-HBB-111 10 D.
Total number of welds subject to selection criteria - 0 E.
Total number of welds examined - 0 0
/~T b)
REACTOR WATER CLEAN-UP SYSTEM P&ID M-1079 (G33) 1.
Number of Class 1 piping welds in system - 89*
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 2-DBA-12 4
4-DBA-ll 16 4-DBA-10 5
4-DBA-9 5
6-DBA-9 24 O'i 11 6-DBA-90 6-DBA-89 24 B.
Total number of welds subject to selection criteria - 89 C.
Total number of examinations - 89 2.
Number of Class 2 piping welds in system - 42**
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 6-EBB-1 2
6-DBB-140 9
6-DBB-104 22 B.
IWC-1220(c) was applied to:
LINE NUMBER NO. OF WELDS T
4-DBB-103 6
(/
x.
4-EBB-1 3
I REACTOR WATER CLEAN-UP SYSTEM (continued)
P&lD M-1079 (G33)
C.
Total number of welds subject to selection criteria - 33 D.
Total number of examinations - 39 (13 of these welds fall under the criteria for NBZ) 3.
Numt>9e of welds examined per NBZ examination criteria and not other-wise examined.
(ref. FSAR 3.6A.2.1 (G) )
LINE NUMBER N0. OF WELDS 8-DBC-1 10 4-DBC-2 6
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e y
w-w-y, - - - - - - - - - - - --y e --
OV RWCU FILTER /DEMINERALIZER SYSTEM P&ID M-1080B (G36) 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system - 7**
A.
IWC-1220(c) was applied to:
LINF NUMBER NO. OF WELDS i
4-HBB-152 7
B.
Total number of welds subject to selection criteria - 0
()
C.
Total number of examinations - 0 l
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i CONTROL R0D DRIVE i
HYDRAULIC SYSTEM l
)
P&ID M-1081A (Cll) l I
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NOTE:
CRD System is 10 longer applicable.
The system was j
capped off due to IGSCC modifications being performed l
in accordance with NUREG 0313.
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O STANDBY LIQUID CONTROL SYSTEM P&ID M-1032 1.
Number of Class 1 piping welds in system - 63*
A.
Non-exempt welds:
LINE NUMBERS NO. OF WELDS lh-DCA-2 6
1 -DCA-3 57 B.
Total number of welds suoject to selection criteria - 63 C.
Total number of examinations - G3 2.
Number of Class 2 piping welds in system - 41**
A.
lWC-1220(b) was applied to:
LINE NUMBERS NO. OF WELDS 6-HCB-16 5
6-HCB-ll 21 fi-HC B-10 2
6-HCC-12 8
B.
IWV-1220(c) was applied to:
I LINE NUMBER NO. OF WELDS 3-HCP.-ll 2
3-HCB-10 3
O STANDBY LIQUID CONTROL SYSTEM (continued)
P&ID M-1082 C.
Total number of welds subject to selection criteria - 0 D.
Total number of examinations - 0 l
l 9
a l
O
O REACTOR CORE ISOLATION COOLING SYSTEM P&ID M-1083B (E51 and M-1085A (E12) 1.
Number of Class 1 piping welds in system - 72*
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 10-DBA-24 13 6-DBA-30 59 B.
Total number of welds subject to selection criteria - 72 O
C.
Total number examinations - 72
~
2.
Number of Class 2 piping welds in system - 214**
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 6-DBB-57 26 6-DBB-58 2
10-DBB-56 7
8-HBB-53 1
16-HBB-53 30 16-HBB-61 4
16-HBB-62 1
6-DBB-44 26 A(_,/
O REACTOR CORE ISOLATION COOLING SYSTEM (continued)
P&lD M-1083B (E51 and M-1085A (E12)
LINE NUMBER NO. OF WELDS 20-HBB-53 12 16-HBB-53 32 B.
IWC-1220(b) was applied to:
LINE NUMBER NO. OF WELDS 6-HBB-49 33 6-HBB-57 15 6-HBB-52 2
C.
IWC-1220(c) was applied to:
LINE NUMBER NO. OF WELDS 4-DBB-51 21 4-DBB-57
-2 D.
Total number of welds subject to selection criteria - 141 E.
Total number of examinations - 88
(
RESIDUAL HEAT REMOVAL SYSTEM P&ID M-1085A&B (E12) 1.
Number of Class 1 piping welds in system - 88*
A.
Non-exempt welds:
LINE NUMBER
[10. OF WELDS 12-DBA-29 4
12-DBA-28 4
12-DBA-38 27 14-DBA-29 12 14-DBA-28 28 0-20-DBA-64 10 6-DBA-32 3
B.
Total number of welds subject to selection criteria - 88 1
C.
Total number of examinations - 88 2.
Number of Class 2 piping welds in system - 835**
j A.
Number of non-exempt piping welds:
l LINE NUMBER NO. OF WELDS 24-GBB-62 20 24-GBB-73 11 l
24-GBB-30 15 20-GBB-31 4
l 1
I RESIDUAL HEAT REMOVAL SYSTEM (continued)
P&ID M-1085A&B (E12) i LINE NUMBER N0. CF WELDS I
a 20-GBB-81 2
i 20-GBB-18 1
20-GBB-70 3
20-GBB-78 4
i 20-GBB-19 7
18-GbB-58 29 18-GBB-63 2
18-GBB-81 45 llll 18-GBB-89 4
i 18-GBB-75 5
18-GBB-76 11 18-GBB-77 2
18-GBB-74 26 18-GBB-17 3
18-GBB-78 9
18-GBB-32 14 18-GBB-107 4
18-GBB-ll8 3
18-GBB-20 39 18-GBB-52 9
18-GBB-51 9
9
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i
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RESIDUAL HEAT REMOVAL SYSTEM (continued) l i
i P&ID M-1085A&B (E12)
LINE NUMBER N0. OF WELDS i
l 18-GBB-21 5
1 18-GBB-23 3
10-GBB-22 11 18-GBB-18 25 i
18-GBB-19 9
l 18-GBB-33 4
i 18-GBB-31 14 14-GBB-61 5
i 14-GBB-81 2
l lO 14-GBB-96 4
i l
14-GBB-20 6
i i
14-GBB-46 4
i 12-GBB-58 4
12-GBB-170 3
12-GBB-86 7
12-DBB-63 16 l
12-GBB-ll4 3
i 12-DBB-72 i5 1
10-HBB-84 13 10-h L-79 15 8-DBB-70 4
g 8-DBB-87 12
i i
1 RESIDUAL HEAT REMOVAL SYSTEM (continued) i j
P&ID M-1085A&B (E12) i LINE NUMBER NO. OF WELDS 1
t 8-DBB-69 5
I t
8-HBB-84 3
1 6-GBB-84 10 6-DBB-88 11 j
6-GBB-92 2
l 6-GBB-43 2
i 6-DBB-71 9
B.
IWC-1220(a) was applied to:
j h
LINE NUMBER N0. OF WELDS 20-HBB-81 2
24-HBB-81 3
1 18-HBB-82 11 12-HBB-82 10 18-GBB-52 18
[
8-GBB-53 8
l 8-GBB-54 6
8-GBB-55 17 6-GBB-54 13 6-HBB-78 12 C.
IWC-1220 (d) was applied to:
i LINE NUMBER N0. OF WELDS O
4-GBB-53 11 4-GBB-142 9
4
O RESIOUAL HEAT REMOVAL SYSTEM (continued)
P&ID M-1085A&B (E12)
LINE NUMBER NO. OF WELOS 4-GBB-37 10 4-GBB-27 3
4-GBB-24 10 4-GBB-75 2
4-GBB-154 2
4-HBB-120 9
4-GBB-95 8
4-GBB-50 16 9
4-GBB-141 4
4-GBB-122 5
4-GBB-64 8
4-HBB-ll5 4
4-GBB-119 5
4-GBB-88 7
4-GBB-90 12 4-GBB-91 2
4-HBB-ll4 3
4-HBB-113 10 4-GBB-110 10 4-GBB-ll2 4
h 4-HBB-117 10 4-HBB-52 5
l 1
i i O RESIDUAL HEAT REMOVAL SYSTEM (continued)
P&ID M-1085A&B (E12)
LINE NFl'3ER NO. OF WELDS i
4-GBB-83 9
4-GBB-72 11 1
4-GBB-85 13 4-HBB-ll8 4
4-GBB-59 5
4-GBB-101 3
3-GBB-24 9
g D.
Total number of welds subject to selection criteria - 508 E. Total number of examinations - 109
(
i l
0
O HIGH PRESSURE CORE SPRAY SYSTEM P&lD M-1086 (E22) 1.
Number of Class 1 piping welds - 42*
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 14-DBA-5 33 3-DBA-7 5
12-DBA-5 4
B.
Total number of welds subject to selection criteria - 42 C.
Total number of examinations - 42 2.
Number of Class 2 piping welds - 166**
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 12-DBB-8 3
16-DBB-8 26 14-DBB-16 9
10-DBB-18 12 12-DBB-16 3
B.
(continued. page 2)
O
- Doe, mot inclede weids i inco neS end ies, for Code C,ess i ninin9
O HIGH PRESSURE CORE SPRAY SYSTEM (continued)
P&ID M-1086 (E22)
B. IWC-1220( a) was applied to:
LINE NUMBER NO. OF WELDS 12-HBB-32 3
14-HBB-32 18 24-HBB-19 5
18-HBB-19 7
24-HBB-21 17
'O 20-HBB-21 2
%-)
18-HCB-1 18 C.IWC-1220(d) was applied to:
LINE NUMBER NO. OF WELDS 4-DBB-20 4
4-DBB-13 8
4-DBB-14 9
4-DBB-ll 9
4-DBB-31 5
4-DBB-25 3
D. Total number of welds subject to selection criteria - 53 E. Total number of examinations - 7 O-t s_
I
LOW PRESSURE CORE SPRAY P&lD M-1087 (E21) 1.
Number of Class 1 piping welds in system - 32*
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 14-DBA-1 32 B.
Total number of welds subject to selection criteria - 32 C.
Total number of examinations - 32 2.
Number of Class 2 piping welds in system - 100**
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 14-GBB-7 3
16-GBB-7 34 14-GBB-14 4
B.
(continued, page 2)
. _ _ = -.. _ _. _. _ _...
t 1
l@
LOW PRESSURE CORE SPRAY (continued)
P&ID M-1087 t
B.
IWC-1220(a) has been applied to:
LINE NUMBER NO. OF WELDS 14-HSB-9 8
24-HBB-8 18 4
20-HBB-8 2
18-HBB-14 3
C.
IWC-1220(d) has been applied to-g l
LINE NUMBER NO. OF WELDS 1
4-GBB-5 3
4-GBB-10 2
)
4-GBB-ll 12 4-GBB-9
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l 4-HBB-13 5
4-HBB-17 3
D.
Total number of welds subject to selection criteris - 43 i
E.
fotal number of examinations - 5
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FUEL POOL COOLING & CLEAN-UP SYSTEM P&l's M-1088C (G41) 1.
Number of Class 1 piping welds in system - 0*
2.
Number of class 2 piping welds in system - 22**
A.
IWC-1220(b) was applied to:
LINE NUMBER NO. OF WELDS 8-HBB-7 6
8-HBB-6 7
B.
IWC-1220(c) was applied to:
LINE NUMBER NO. OF WELDS 3-HCB-9 9
C.
Total number of welds subject to selection criteria - 0 D.
Total number of examinations - 0
O LEAK DETECTION SYSTEM P&ID M-1090A (E31) 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system -
0**
(As can be seen by the P&ID, all Class 2 lines in this system are 4 inches NPS and less.
Therefore, they are all exempt per IWC-1220(c) ).
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O COMBUSTIBLE GAS CONTROL SYSTEM P&ID M-1091 (E61) 1.
Number of Class 1 piping welds - 0*
2.
Number of Class 2 piping welds - 79**
A.
Non-exempt welds:
LINE NUMBER NO. OF WELDS 12-HBB-90(A) 3 12-HBB-90(B) 2 B.
IWC-1220(b) was applied to:
LINE NUMBERS NO. OF WELDS 6-HBB-185(A) 3 6-HBB-185(B) 2 12-HBB-135(A) 1 12-HBB-135(B) 1 10-HBB-135(A) 16 10-HBB-135(B) 15 10-HBB-136(A) 2 10-HBB-136(B) 2 8-H3B-137 10 10-HBB-139 8
10-HBB-138 8
6-HBB-140 4
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COMBUSTIBLE GAS CONTROL SYSTEM (continued)
P&ID M-1091 (E61)
I C.
IWC-1220(c) was applied to:
LINE NUMBER N0. OF WELDS 6-HBB-190(A) 1 I
6-HBB-190(B) l i
D.
Total number of welds subject to selection criteria - 5 t
E.
Total number of examinations - 2 1
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, FLOOR & EQUIPMENT DRAINS SYSTEM P&ID M-1094A,B (P45) 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system - 64**
A.
IWC-1220(b) was applied to:
LINE NUMBER NO. OF WELDS 6-HBB-101 8
6-HBB-102 10 B.' IWC-1220(c) was applied to:
LINE NUMBER NO. OF WELDS 4-HBB-95 15 3-HBB-95 3
3-HCB-19 10 3-HBB-96 3
4-HBB-96 15 C.
Total number of welds subject to selection criteria - 0 D.
Total number of examinations - 0
O SUPPRESSION P0OL MAKE-UP SYSTEM P&ID M-1096 (E30) 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system - 33**
A.
IWC-1220(b) was applied to:
LINE NUMBER N0. OF WELDS 30-HCB-26 2
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30-HBB-162 31 B.
Total number of welds subject to selection criteric - 0 C.
Total number of examinations - 0 i
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O MAIN STEAM ISOLATION VALVE LEAKAGE CONTROL SYSTEM P&ID M-1097 (E32) 1.
Number of Class 1 piping welds in system - 32*
A.
Non-exempt welds:
LINE NUMBERS NO. OF WELDS 1 -DBA-69 32 B.
Total number of welds subject to selection criteria - 32 C.
Total number of examinations - 32 f
2.
Number of Class 2 piping welds in system - 34**
A.
IWC-1220(b) was applied to:
LINE NUMBER NO. OF WELDS 6-HBB-176 5
B.
IWC-1220(c) was applied to:
LINE NUMBER NO. OF WELDS 3-HBB-176 5
4-HBB-169 4
4-HBB-170 20 C.
Total number of welds subject to selection criteria - 0 D.
Total number of examinations - 0
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O SUPPRESSION P0OL CLEANUP SYSTEM P&ID M-1099 (P60) 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system - 17**
A.
IWC-1220(b) war applied to:
LINE NUMBER N0. OF WELDS 12-GBB-143 8
12-GBB-131 9
B.
Total number of welds subject to selection criteria - 0 C.
Total number of examinations - 0 O \\
b
(,, )
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l 1 O CONTAITNEtiT C00LIfiG SYSTEM P&ID M-1100A & B (M-41) l
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f;0TE:
All Class 2 piping welds in this system are exempt per IWC-1220(b) l i O i
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O PLANT CHILLED WATER SYSTEM P&lD M-11090 (P71) 1.
Number of Class 1 piping welds in system - 0*
2.
Number of Class 2 piping welds in system - 12**
A.
IWC-1220(b) was applied to:
LINE NUMBER NO. OF WELDS 5-HBB-44 2
5-HBB-43 2
B.
IWC-1220(c) was applied to:
LINE NUMBER NO. OF WELDS 4-HBB-44 4
4-HBB-43 4
C.
To'.al number of welds subject to selection criteria - 0 D.
Total number of examinations - 0
P e
4 CONTAINMENT LEAKAGE RATE TEST SYSTEM l
P&ID M-llllA (M61) i i
I NOTE: All Class 2 piping welds in this system are exempt under
'NC-1220(b).
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O FEEDWATER LEAKAGE CONTROL SYSTEM P&ID M-lll2 (E38)
I 1.
Number of Class 1 piping welds in system - 11*
A.
Non-exempt welds:
LINE NUMBER NO. OF WELD 5 1 -DBA-87 11 B.
T,tal number of we'.d subject to selection criteria - 11 C.
Total number of examinations - 11 O
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RESPONSE TO 121.7 Responses to 121.10,121.11,121.12,121.13, and 121.14 constitute a response to this question.
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I RESPONSE TO 121.10 O
MP&L was asked to discuss the apparent inconsistency between MP&L's selection criteria and the selection criteria described in ASME Section XI, Sumer 1975 Addenda, paragraphs IWC-1220, IWC-2520, and IWC-2411.
GENERA _L: The Section XI, selection criteria, is based on examining welds at structural di". continuities.
The total of the welds to be exaniined is based on the average number of welds in the multiple streams of a system; or, if no multiple streams exist, the total number of welds in the stream.
The exemp-tions of IWC-1220 are applied; the remaining welds are categorized into either the "C-F" or "C-G" portion of IWC-2520; taking advantage of multiple streams where possible; and the number of welds in the scope of the PS!/ISI program is then determined.
The Inservice portion of the program then requires the examinations performed over the forty year life of the plant to cover 100%
of the required welds, i.e. 25% of the welds are examined each 10 year inter-val.
The MP&L selection criteria achieves basically the same results.
The exemptions of IWC-1220 are -applied to the systems; the remaining welds make up the basis for the selection process.
The sampling plan is based on stress values and is very similar to the sampling criteria presented in the Sumer 1978 addenda to the 1977 edition of ASME Section XI and the sampling philosophy of NUREG-0313.
The welds chosen are examined for the preservice portion of the program; subse-quently,100% of those welds are examined each 10 year interval over the forty year life of the plant.
COMPARISON OF SAMPLING PLANS FOR RHR, LPCS AND HPCS SYSTEMS: The following paragraphs provide a detailed comparison of the examinations which would take place under the ASME Section XI selection criteria (referred to as the " Code Plan"), versus the MP&L selection criteria (referred to as the "MP&L Plan").
RHR SYSTEM:
The most complicated system to consider is the Residual Heat Re-moval System,; since this system involves (a) large numbers of welds, and (b) i, more f 5an one mode of operation, i.e. performs several system functions.
Some system functions involve circulation of Reactor coolant, in which case the more strigent category "C-F' of IWC-2520 must be used.
Other system functions fall under category "C-G".
The majority of the RHR system can be categorized con-servatively as "C-F", requiring the equivalent of 100% examination of one of the multiple streams.
l Under the Code Plan, the system breakdown would be as follows:
- 1) Two major loops are treated as category "C-F".
One loop (appearing in P&lD M-1085A) is associated with the suction and discharge of pump C002B-B and Heat Exchangers B001B/B002B, The other loop appears on P&ID M-1085B and is associated with the suction and discharge of pump C002A-A and Heat Ex-changers B001A/B002A.
Loop A contains 194 welds at structural discontinuities.
~
Loop B contains 188 weeds at structural discontinuities.
Averaging the two loops would place 191 welds in *h scope of the 151 program.
2)
Suction / discharge piping 6 sociated with pump C002C-9 (M-1085A) is treated as category "C-G".
There is only one " stream" invalved, so the 60 welds at structural discontinuities in this portion of the system would mean 50% of those, or 30 welds, would be added to the scope of the ISI progeam.
- 3) The HBB-79 line on M-1085A and the HBB-84 line on M-1085B would be treated as too systems.
These lines contain 15 welds and 16 welds, respec-tively.
Since these wcold be category "C-G", the average of 15.5 welds would mcan 50% of these, or 8 welds, wcald be added to the scope of the ISI program.
- 4) The DBB '0/DBB-87 lines in M-1085A and the DBB-69/DBB-87 lines on M-1085B would be treated as two streams.
The lines contain 10 welds and il welds, respectively.
Since these would be category "C-G", the average of 10.5 welds would mean 50% of these, or 6 welds, would be added to the scope of the ISI program.
- 5) Two additional lines circulate P.eactor coolant (category "C-F") and are not considered multiple streams.
These are 6"-GBB-84 on P&ID M-1085A (10 welds) and 20"-GBB-31 on P&ID M-1085B (4 welds).
These would add 14 welds to the scope of the ISI program.
- 6) Thus, the use of the code plan would require the inservice ex.minacion of:
191 welds (from paragraph (1) above) 30 welds (from paragrapn (2) above) 8 welas (from paragraph (3) above) 6 welds (from paragraph (4) above)
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14 welds (from paragraph (5) above)
__249 welds Total Approximately 62 welds on the RHR system would be examined each 10 years, for a total of 249 examinations over the life of the plant.
Under tte MP&L plan, 101 welds are within the scope of the ISI program.
Each weld would be examined each 10 years, for a total of 404 examinations conducted over the life of the plant.
LpCS AND HPCS SYSTEMS: A similar analysis of the Low and High Pressure Core Spray syntems yields the following totals:
For LPCS, the system has a total of 36 welds at structural discontinuities.
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Applying category "C-G",18 welds in the scope of the ISI program would be examined under the Code Plan, broken down into 10 year intervals as 5'4+5+4 = 18 total examinations.
Under the MP&L Plan, the 5 welds in the ISI program would be examined eact 10 years, for a total of 5+5+5+5 = 20 total examinations.
For the HPCS the system has a total of 47 welds at structural discontinuities.
Applying category "C-G", 24 welds in the scope of the ISI program would be examined under trie Code Plan, broken down into 10 year intervals of O
6+6+6+6 = 24 total examinations.
Under the MP&L Plan, the 7 welds in the ISI program would be examined each 10 years, for a total of 7+7+7+7 = 28 total examinations.
1
__--,.,_____,,.~.-._ ____,.-,----._,..
CONCLUSIONS:
The MP&L Plan exceeds the ASME Code requirements in tenns of total examination effort.
In addition, a higher percentage of welds is ex-p.ined during Inservice Inspection (as compared to the baseline examinations) under the MP&L selection criteria.
The MP&L Plan concentrates examinations O
at locations where failure mechanisms are postulated to occur (high stress welds) and provides for better probability of detection of adverse trends in the pressure boundary since the same representative sample of welds is moni-tored over the life of the plant.
Any apparent inconsistency between the regulatory-required plan (the " Code Plan") and the MP&L selection criteria results from the fact that MP&L's plan is more olant specific than the generic code requirements and is more responsive to the needs of the BWR-6/ Mark III containment system as installed at the Grand Gulf Nuclear Station.
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RESPONSE TO 121.11 The anticipated date for the submittal of the finalized Preservice Inspection Report is June 1982, based on current fuel load schedule of December 1981.
The results of the RPV Unit 1 Preservice Examinations were provided by way of NIS-1 owners Data Reports submitted for NRC review by letter, MP&L serial no. AECM 81/328 A)
Per responses to NRC questions, 121.7 and 121.12, G.E. ISI Isometrics are being provided, confirTning the MP&L PSI Program was performed in accordance with ASME Section XI Code requirements.
Relief Request are being submitted as part of this response (see attached).
B) All Preservice RPV Unit 1 examinations have been complete and no Relief Request are required.
c)
Relief Request for specific components and piping welds, with primary reasons that a specific examination is impractical, as well as technical justifications for relief, are being provided as part of this response.
d) The following is a list of those Request For Relief:
RELIEF REQUEST NO.
SUBJECT 00001*
Guard Pipe Access O
00002 Pheripheral CRD's 00003 Pump Casing Welds 00004 RHR Heat Exchanger 00005 Thermal Tee Welds 00006 Recirculation Pumps l
- Previously submitted to NRC by way of MP&L letter, serial no.
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RESPONSE T0 121.12 MP&L has been asked to discuss the criteria used to select ASME Code Class 2 components for Preservice Examination.
O General: The GGNS PSI Program Abstract is based upon the MP&L letter AECM-801238, dated October 2, 1980.
This letter documented MP&L's intent to adopt the 1977 Edition of the Section XI Code and Addenda through Summer 1978, as permitted by the Federal Register dated October 1974.
However, the Register also requires that ECCS, RHR and CHR (CHR is not applicable to BWR) systems shall be examined per the 1974 Edition of Section XI and Addenda through Summer 1975.
The specific criteria used to select Class 2 piping welds is as follows:
Non-ECCS and RHR Systems:
Components in these systems not exempted by the provisions of IWC-1220 shall be examined, in so far as practical, by the requirements listed in Table IWC-2500-1, Examination Category C-F.
As per-mitted by this table, the piping weld examinations performed shall total 25%
of the non-exempt piping welds for that system.
(50% for Main Steam) Portions of systems subject to this examination include the Main Steam and Feedwater Lines in the Auxiliary Buildi^g, the steam supply to the RCIC turbine, the Control Rod Drive System ar.d portions of lines carrying steam to the RHR heat exchangers.
Rh.i and ECCS: The criteria used in selection of Code Class 2 piping welds in these systems shall be referred to as the "MP&L Plan".
The MP&L Plan consists of the application of IWC-1220 (a) (the pressure and temperature exemption) and IWC-1220 (d) (size exemption) and not taking credit for IWC-1220 (b) (exemption of non-RHR and ECCS which do not function during normal reactor operation) and IWC-1220 (c) (water chemistry exemption).
Therefore, MP&L's sampling plan is based upon the welds that are no longer exempted by water chemistry (IWC-1220 (b) was never applied).
From this total number of welds, MP&L has elected to examine 10% as a sample.
The 10% was applied as follows:
1.
The welds to be examined shall be 100% of the terminal ends of pipe at vessel nozzles, with the ramainder of the 10% selected proportionally from the fcllowing:
a)
Circumferential welds at locations where loadings due to Normal and J;, et conditions would result in stress levels calculated to exceed the value 0.8 (1.2 sb + sA) when determined by the sum of equations (9) and (10) in Paragraph NC-3652 of Section III of the ASME Code, b)
c) Welds which cannot be pressure tested in accordance with IWC-5000.
d)
A sufficient number of additionsl welds at structural discontinuities.
2.
The welds to be examined shall be distributed approximately equally among runs (or portions of runs) that are essentially similar in design.
In addition, all welds within the No Break Zone (NBZ), not examined, per the 10% criteria, have been 100% Ultrasonically examined per FSAR Paragraph 3.6. A-15.
Therefore, the total number of weld examinations reflected by the GGNS PSI O
eie" wiii be io excees of ioz of tae nom-exempt weiae.
MP&L's response to the NRC question 121.10 discusses, in detail, the com-parison between the MP&L Plan and the " Code Plan".
This response concludes O
that the MP&L Plan exceeds the ASME Code requirements in terms of total examination effort.
In addition, a higher percentage of welds is examined during Inservice Inspection (as compared to the baseline examinations) under the MP&L selection criteria.
The MP&L Plan concentrates examinations at locations where failure mechanisms are postulated to occur (high stress welds) and provides for better probability of detection of adverse trends in the pressure boundary since the same representative sample of welds is mon-itored over the life of the plant.
Any apparent inconsistency between the regulatory-required plan (the " Code Plan") and the MP&L selection criteria results from the fact that MP&L's Plan is more plant specific tnan the generic code requirements and is more responsive to the needs of the BWR-6/ Mark III containment system as installed at the Grand Gulf Nuclear Station.
In regards to the request for additional ISI Isometrics, MP&L is providing those ISI Isometrics as part of this response.
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RESPONSE T0121.13 O
Supplement 7 of ASME Section XI, Appendix III was used as the basis for exam-ination of stainless steel piping welds.
This supplement pennits three recommended modifications of the Appendix III requirements.
(a) 1.
Angles of other than 45 are permitted where metallurgical characteristics impede the effective use of 450 beams. This is not of major significance, since other angles could already be used for flaw evaluation or when weld geometry was more amendable to other angles.
2.
The substitution of a reflector depth requirement of a flat 10%
of (t) in lieu of the equation specified in 111-3430.
The standard equation specifies notch depth to be calculated as:
.104t
.009t2 (Equation 1) 2 The effect of the expression (.009t ) is to require a correspondingly smaller notch depth as (t) becomes large.
At a (t) of 2.0 inches, the notch droth ds calculated by Equation 1 would be:
.104(2.0)
.009(2.0)
.208
.009(4)
.208
.0036 0
.172" deep Substitution of a flat 10% of (t) would yield a notch depth of.200 under the supplement 7.
An ultrasonic truism is that a smaller reference reflector provides a greater sensitivity than a larger reference re-flector, all other things being equal.
Therefore, we continued to manufacture calibration standards to Equation 1.
3.
Supplement 7 states that Figure 111-3230 may not apply to austenitic material.
However, this is not actually the case.
Figure III-3230 sets up a requirement relating search-unit-to-weld-centerline distance, wall thickness "t", and the tangent of the beam angle.
The purpose is to ensure that the sound beam reaches the weld root area when examina-tions are limited to the half-vee examination.
The actual relationship of the th.ee parameters is the same regardless of material type.
What does change is the angle of the beam as the material changes from ferritic to austenitic.
(b) Adequate examination sensitivity over the required enmination volume was assured.
Calibration standards used were of the same material type, wall thickness, and diameter as the piping system being examined.
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reflectors were incorporated into the Distance Amplitude Correction (DAC) curves st the same metal paths as defects would be encountered during ex-amination.
In two cases, it was recognized that attenuation of the sound beams was excessive.
These two cases were the large diameter /large wall O
thickness stainless steel recirculation piping clad with corrosion resistant 308L weld metal, and the dissimiliar metal welds on the RPV safe ends.
In both instances, separate examination procedures were developed and utilized.
For the CRC clad pipe welds, additional calibration standards were fabricated which were clad in the same manner as the welds in the plant.
For the safe j
end welds, calibration was performed on side drilled holes located in weld l
metal and the angle beam examinations were supplemented by straight beam examinations.
The use of straight beam examinations to supplement angle beam examinations is addressed in ASME Section V.
(c) All examination procedures used were demonstrated to the satisfaction of the Authorized Nuclear Inservice Inspection agency representative in accordance with ASME Section XI requirements.
(d) The suggestions made in paragraph (d) and (e) of question 121. i3 are (e) appreciated.
However, similar requirements are already in place, or will be incorporated for the inservice examinations.
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O RESPONSE TO 121.14 Augmented Liquid Penetrant Examinations, of the inner radius and bore regions of the entire nozzle of each of the Feedwater Nozzles, was performed ni tor to installation of the Sparger in accordance with Sec-tion 4.3 of NUREG-0619.
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