ML20023A486
| ML20023A486 | |
| Person / Time | |
|---|---|
| Site: | Hatch, 05000000 |
| Issue date: | 09/02/1982 |
| From: | SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY |
| To: | NRC |
| Shared Package | |
| ML20023A487 | List: |
| References | |
| CON-NRC-03-82-096, CON-NRC-3-82-96, TASK-2.K.3.17, TASK-TM SAI-186-028-25, SAI-186-28-25, TAC-07811, TAC-08019, TAC-45691, TAC-45692, TAC-7811, TAC-8019, NUDOCS 8209090218 | |
| Download: ML20023A486 (52) | |
Text
SA! Report No. 186-028-25 TECHilICAL EVALUATION REPORT EDL11NI. HATCH NUCLEAR PLANT Ul4ITS 1 AND 2 INSERVICE INSPECTION PROGRAM Submitted to:
U.S. Nuclear Regulatory Comission Contract No. 03-82-096 Science Applications, Inc.
ficlean, Virginia 22102 XA Copy Hos Been sent to PDR Segeeer 2, 1982 Y
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CONTENTS INTRODUCTI0ii . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 I. CLASS 1 COMPONENTS . . . . . . . . . . . . . . . . . . . . . . . . . 5 A. Reactor Vessel . . . . . . . . . . . . . . . . . . . . . . . . . 5
- 1. Request for Relief 2.1.5; Pressure Retaining Welds in Control Rod Drive Housings, Category B-0, Item Bl.18 .. 5 B. Pressurizer (Does not apply to BWRs) .
C. Heat Exchangers and Steam Generators (No relief requests)
D. Piping Pressure Boundary . . . . . . . . . . . . . . . . . . . . 7
) 1. Request for Relief 2.1.4; Pressure Retaining Welds in Piping, Category B-J, Item B4.5 (Unit 1 only) ....... 7
- 2. Requests for Relief 2.1.6 and Q121.16-1; Pressure Retaining Welds in Piping, Category B-J, Item B4.5 . . . . . 10
- 3. Class 1 Support Members for Piping, Valves and Pumps, Category B-K-1, Items B4.9, B5.4 and B6.4 . . . . . . 12
- 4. Requests for Relief 2.1.2 and 3.1.1; Hydraulic Shock Suppressors for Class 1 and 2 Piping, Pumps and Valves, Categories B-K-2 and C-E-2, Items B4.10, B5.5, B6.5, C2.6, C3.4 and C4.4 .............. 13
- 5. Request for Relief per Letter of March 2, 1982 (Ref. 20); Class 1, 2 and 3 Support Components for Piping, Valves and Pumps, Categories B-K-2 and C-E-2, Items B4.10, B5.5, B6.5, C2.6, C3.4 and C4.4 . . . . . . . . . . . . . . . . . . . . . . . . . . 15
. E. Pump Pressure Boundary . . . . . . . . . . . . . . . . . . . . . 17
- 1. Class 1 Support Members for Pumps, Category B-K-1, Item B5.4 ......................... 17
- 2. Hydraulic Shock Suppressors for Class 1 Pumps, Category B-K-2, Item B5.5 ................. 17
- 3. Class 1 Support Components for Pumps, Category B-K-2, Item B5.5 ......................... 17 Valve Pressure Boundary .................... 17 F.
- 1. Class 1 Support Members for Valves, Category B-K-1, 17 Item B6.4 .........................
- 2. Hydraulic Shock Suppressors for Class 1 Valves, 18 Category B-K-2, Item B6.5 .................
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- 3. Class 1 Support Components for Valves, Category B-K-2 Item B6.5 ......................... 18 4 Relief Request 2.1.3, Internal Surfaces of Valves, Category B-M-2, Item B6.7 ................. 18 II. CLASS 2 COMP 0NENTS . . . . . . . . . . . . . . . . . . . . . . . . 22 A. Pressure Vessels (No relief requests)
B. Piping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
- 1. Request-for Relief Q121.17; Pressure Retaining Welds in Piping, Categories C-F, C-G and C-E-1, Items C2.1, C2.2, C2.3 and C2.5 (Unit 2 only) ............. 22
- 2. Hydraulic Shock Suppressors for Class 2 Piping, Category C-E-2, Item C2.6 ................. 25
- 3. Class 2 Support Components for Piping, Category C-E-2, Item C2.6 ......................... 25 C. Pumps ............................. 26
- 1. Code Relief Requests 3.1.2.and 3.1.3, Class 2 Bolting, Category C-D, Items C3.2 and C4.2 ............. 26
- 2. Hydraulic Shock Suppressors for Class 2 Pumps, Category C-E-2. Item C3.4 ................. 28
- 3. Class 2 Support Components for Pumps, Category C-E-2, Item C3.4 ......................... 28 D. Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
- 1. Hydraulic Shock Suppressors for Class 2 Valves, Category C-E-2, Item C4.4 ................. 29
- 2. Class 2 Support Components for Valves, Category C-E-2, Item C4.4 ......................... 29 III. -CLASS 3 COMPONENTS . . . . . . . . . . . . . . . . . . . . . . . . 29 A. Piping, Pumps and Valves . . . . . . . . . . . . . . . . . . . . 29
- 1. Class 3 Support Components for Piping ........... 29
- 2. Code Relief Request per Section 4.0 of Ref. 14; Inspection of Vertical, Centrifugal River Intake Pumps, per IWD-2410(b) and (c) . . . . . . . . . . . . . . . 30 2l J
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IV. PRESSURE TESTS ......................... 32 A. General . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
- 1. Relief Requests 2.1.1, 3.1.5, 4.1.1 and Letter of May 1, 1980; Hold Time, Class 1, 2 and 3 Systems . . . . 32 B. Class 1 System Pressure Tests . . . . . . . . . . . . . . . . 34
- 1. Code Relief Request 2.1.1 and Letter of May 1, 1980; Hydrostatic Testing, Class 1 Systems ....... 34 C. Class 2 System Pressure Tests . . . . . . . . . . . . . . . . 36
- 1. Systems That Cannot Be Isolated from Class 1 36 Systems,perItem2ofAttachment1{Ref.25 ......
- 2. Relief Request 3.1.5 and Letter of May 1, 1980; Hydrostatic Testing, Class 2 Systems .......... 38 D. Class 3 System Pressure Tests . . . . . . . . . . . . . . . . 40
- 1. Code Relief Request per Section 4.0 of Ref. 14; Testing of Service Water Systems Buried Piping, IWD-2600(b); Testing of Service Water Systems, IWD-2410(b) . . . . . . . . . . . . . . . . . . . . . . . 40 V. GENERAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 A. Ultrasonic Examination Technique (No relief requests) 44 B. Exempted Components . . . . . . . . . . . . . . . . . . . . .
- 1. Code Exemption per Note 9 of Attachment 2, Ref. 25; IWC-1220(a), Components Exempted from Examination Based on Pressure and Temperature . . . . . . . . . . . . 44 46 REFERENCES .............................
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TECHNICAL EVALUATION REPORT EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 INSERVICE INSPECTION PROGRAM IliTRODUCTION l
The revision to 10 CFR 50.55a, published in February 1976, required that Inservice Inspection (ISI) Programs be updated to meet the requirements (to the extent practical) of the Edition and Addenda of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code
- incorporated in the Regulation by reference in paragraph (b). This' updating of the programs was recuired to be done every 40 months to reflect the new requirenents of the later editions of Section XI.
As specified in the February 1976 revision, for plants with Operating Licenses issued prior to March 1, 1976, the regulations became effective after September 1,1976, at the start of the next regular 40-month inspection period.
The initial inservice examinations conducted during the first 40-month period were to comply with the requirements in editions of Section XI and addenda in effect no more than six months prior to the date of start of facility comercial operation.
The Regulation recognized that the requirements of the later editions and addenda of the Section XI might not be practical to implement at facilities because of limitations of design, geometry, and materials of construction of components and systems. It therefore permitted determinations of impractical examination or testi.ng requirements to be evaluated. Relief from these require-ments could be granted provided health and safety of the public were not endan-gered giving due consideration to the burden placed on the licensee if the requirements were imposed. This report provides evaluations of the various requests for relief by the licensee, Georgia Power Company (GPC), of the Edwin I. Hatch iluclear Plant, Units 1 and 2. It deals only with inservice examinations of components and with system pressure tests. Inservice tests of pumps and valves (IST programs) are being evaluated separately.
- Hereinafter referred to asSection XI or Code.
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The revision to 10 CFR 50.55a, effective November 1, 1979, modified the time interval for updating ISI programs and incorporated by reference a later edition and addenda of Section XI. The updating intervals were extended from 40 months to 120 months to be consistent with intervals as defined in Section XI.
For plants with Operating Licenses issued prior to March 1, 1976, the provisions of the November 1, 1979, revision are effective after September 1, 1976, a.t the start of the next one-third of the 120-month interval. 'During the one-third of an interval and throughout the remainder of the interval, inservice examinations shall comply with the latest edition and addenda of Section XI, incorporated by reference in the Regulation, on the date 12 months prior to the start of that one-third of an interval. For Edwin I. Hatch Nuclear Plant, Units 1 and 2, the ISI program and the relief requests evaluated in this report cover the last 80 months of the current 120-month inspection interval, i.e., from April 30, 1979, to fiay 5,1986, for Unit 1 (the second interval was extended approximately four months); and the entire current 10-year inspection interval,1.e. , from September 5,1979, to September 5,1989, for Unit 2.
This program was based upon the 1974 Edition of Section XI of the AStiE Boiler and Pressure Vessel Code with Addenda through the Sumer of 1975.
The November 1979 revision of the Regulation also provides that ISI programs'may meet the requirements of subsequent code editions and addenda, incorporated by reference in paragraph (b) and subject to U.S. Nuclear Regu-latory Commission (NRC) approval. Portions of such editions or addenda may l be used, provided that all related requirements of the respective editions or addenda are met. These instances are addressed on a case-by-case basis in the body of this r,eport.
Finally,Section XI of the Code provides for certain compon e and systems to be exempted from its requirements. In some instances, m s exemp-tions are not acceptable to NRC or are only acceptable with restrictions. As appropriate, these instances are also discussed in this report.
References (1) to (25) listed at the end of this report pertain to
! previous transmittals on ISI between the licensee and the NRC. By letters
! of April 24'and November 22,1976,(1,3) the Coninission provided general ISI t
guidance to all licensees. A submittal in response to that guidance was made science 4ppocations. ine.
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by the licensee on Hovember 15,1976,(2) for Unit 2 Further guidance-was given by the Comission on January 7,1977.I4) An additional submittal by tae licensee was made on June 7,1977,(5) for Unit 2 which included early relief requests. The Comission ruled on.these requests by letter of July 7, 1977,(6) and on December 19, 1977,I7) requested additional information pertain-ing to the Hatch No. 2 inservice inspection program, which had been publisned in the Final Safety Analysis Report (FSAR) and amended periodically. On August 3,1978,(8) the licensee submitted the inservice inspection program for Unit 1. In September 1978,(9) the licensee submitted Amendment No. 46 to the FSAR for Unit 2, which contains the inservice inspection program being reviewed in this technical evaluation report. A submittal for Unit I was made by the licensee on January 24,1979.(10) On March 28, 1979,III) the NRC re-quested additional information pertaining to the Hatch No. 1 inservice inspec-tion program. An amended issuance of the Hatch No. 1 inservice inspection program was made on June 6,1979.(12) Relief requests were submitted by the licensee for Hatch Units 1 and 2 on May 1, 1980.(13) Amendment 2 of the Hatch No. 1 inservice inspection program was issued on January 27,1981.(14)
On November 10,1981,(15) the licensee requested an extension for the inservice inspection period for Unit 1. Approval of this request was given by the Com-mission on November 23,1981.(17) On November 18,1981,(10) the licensee requested relief, which the NRC granted on January 27, 1982.II9)* A summary of"the limitations experienced during 1981 Class 1 inservice examinations for Unit I was issued by the licensee on November 24,1981.(18) On March 2, 1982,(20) relief requests were submitted for Units 1 and 2. On March 12,1982,(22) and April 6,1982,(23) the Commission requested additional information pertain-ing to the inservice inspection programs for Units 1 and 2, respectively. The licensee furnished this information on June 11,1982.(25) Another relief request was made by the licensee on March 11,,1982,(21) and the NRC granted relief on April 7,1982.(24)*
From these submittals a total of 28 requests (a) for relief from Code requirements, (b) for updating to a later Code, and (c) for exemptions not necessarily acceptable to the Comission were identified. These reque ts are evaluated in the following sections of this report. In addition, other relief requests originally made(9,14) were withdrawn by the licensee in Reference 25. These included: Repair Procedures; Categories C-F and C-G,
- These two relief requests are discussed also in this report.
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Class 2 piping Pressure Boundary Welds; Class 3 System Pressure Testing; Exemptions for 2-Inch Diameter and Smaller Piping; Category B-B, Pressure Retaining Welds in Vessels; Category B-D, Full Penetration Welds of Nozzles in Vessels; Category B-H, Vessel Supports; Category B-L-2, Pump Casings; and Categories C-F and C-G, Class 2 Pressure Retaining Welds in Pump's.
Another relief request (IWD-5000, Temperature Limitation for Testing Class 3 Systems) is not discussed in this report since the Code does not specify a temperature requirement.
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I. CLASS 1 COMPONENTS A. Reactor Vessel
- 1. Request for Relief 2.1.5; Pressure Retaining Welds in Control Rod Drive Housings, Category B-0, Item Bl.18 Code Requirement Volumetric weld examinations shall be performed during each inspection interval and shall include 100% of the welds in 10% of the peripheral control rod drive (CRD) housings.
The examinations may be performed at or near the end of the inspection interval.
Code Relief Request Relief is requested from the volunetric examination of the peripheral CRD housing welds.
Proposed Alternative Examination All peripheral CRD housing welds shall be visually ex-amined during the system hydrostatic pressure tests in accor-dance with IWB-5000.
Licensee's Basis for Requesting Relief Unit 1 Each control rod drive housing has one upper weld located near the reactor vessel bottom head and one lower weld located at the housing flange. Because of the proximity of the upper weld to the vessel, the dose rate is too high to pennit examina-tion of this weld. Dose rates are typically 20 to 30 R/hr and i an examination would expend 10-15 man-rem per housing. The l lower welds are inac'cessible for examination because of the location and design of the housings. Physical accessibility l
by an inspector is extremely limited by the close proximity of the housings to each other and by the support arrangement.
Also, the insert and withdraw lines to the CRD are connected at the top of the housing flange and prevent access to much of the weld. The combination of these factors prevents these welds from being examined.
Unit 2 l
l Licensee claims exemption from Category B-0 welds per IWB-1220(b)(1). This exemption claim is based on the follow-
! ing statement by the licensee:
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Figure 4.2-8 of the FSAR shows that there are 28 peripheral CRD housings. Each housing has an attachment weld to the reactor vessel and a weld joining the housir.9 to l
the flange. Section 4.2 of the FSAR shows that the failure of a CRD housing weld will produce a maximum leakage rate of 840 gal / min. The available makeup systems are RCIC-400 gal / min.,
CRD-160 gal / min., and the transfer system to feedwater-1000 gal / min. Therefore, the reactor can be shut down and copled down in an orderly manner using makeup systems supplied by onsite power, as required by IWB-1220. Note: Since loss of coolant l
occurs during normal operation, it is our interpretation that the service transformer is the source of onsite power.
Evaluation Even though the licensee has presented different bases for requesting relief for the two units, both bases apply to both units.
Because of the physical inaccessibility of the lower welds and the high radiation fields to which examining personnel would be exposed, examination of the peripheral control rod drive housing welds is impractical.
The licensee has shown that the makeup system has sufficient capacity to shut down and cool the reactor in an orderly manner, should a complete failure of a CRD housing weld occur. Tnus, the requirements of paragraph IWB-1220(b)(1) are satisfied and the examinations required for Code exempted components would be performed by the licensee.
Both of these bases contain sufficient justification for code relief.
Conclusio..s and Recommendations Based on the above evaluation, it is concluded that for the welds discussed above, the code requirements are impractical ard the code requirements for exemption of volumetric examina-tions have been satisfied. It is further concluded that the alternative examination discussed above will provide necessary added assurance of structural reliability. Therefore, the fol-lowing is reconinended:
Relief should be granted from the volumetric examination of 100% of the welds in 10% of the peripheral CRD housings, with the following provision:
All peripheral CRD housing welds are visually examined during the system hydrostatic pressure tests in ac-cordance with IWB-5000, as proposed by the licensee.
References References 8, 9, 12, 14, 23 and 25.
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B. Pressurizer ,
Does not apply to BWRs. _.
C. Heat Exchangers and Steam Generators No relief requests.
D. Piping Pressure Boundary
- 1. Regtest for Relief 2.1.4; Pressure Retaining Welds in Piping, l
Category B-J, Item B4.5 (Unit 1 only)
Code Requirement Volumetric weld examinations shall be performed during each inspection interval and shall cover all of the area of 25% of the circumferential joints including the adjoining 1 ft. section of longitudinal joints and 25% of the pipe branch connection joints.
Code Relief Request Relief is requested from the volumetric examination of the following pressure retaining welds:
Penetration Flued Head to Process Pipe Welds (Unit 1)
Penetration No. Weld Identification No.
X-9A B21-FW-18A-71 X-9B B21-FW-18B-6A X-10 E51-RCIC-4-0UT-20A
- X-11 E41-HPCI-10-0UT-15A X-12 E11-RHR-20-B-Discharge-13A X-13A E11-RHR-24-A-Return-3A X-13B E11-RHR-24-B-Return-3B X-14 G31-RWCU-6-0VT-15B X-14 G31-RWCU-6-0UT-15C 3
X-16A E21-CORE SPRAY-10-A-3A g
X-16B E21-CORE SPRAY-10-B-4A X-17 E11-RHR-4-HS-6A FW - Feedwater RCIC - Reactor Core Isolation Cooling RHR -
Residual Heat Removal RWCU - Reactor Water Cleanup Al science Appocations.inc.
proposed Alternative Examination In accordance with IWB-5221 a system leakage test is to be performed prior to startup following each reactor refueling outage.
Whenever the process piping to flued head weld (outside containment) is volumetrically inspected, the accessible weld of the flued head penetration will have a surface examination performed on it.
Licensee's Basis for Requesting Relief These welds are inaccessible for examination due to the )
design of the flued head. All of the twelve circumferential ;
butt welds, except for two located in the RWCU penetration, !
are carbon steel and not subject to intergranular stress cor-rosion cracking (IGSCC).
Two stainless steel welds that are located in the RWCU penetration were made to replace a Type 304 SS pipe that had undergone IGSCC. They are a flued head with a Type 308L over-lay ( > 5% ferrite) on the inside surface to a Type 304L solution annealed pipe ( < .035% carbon), and a Type 304L pipe-to-pipe weld. These welds were made in accordance with the guidelines of NUREG-0313 to minimize susceptibility to IGSCC. A. UT baseline was run for each new weld while the weld was accessible during the repair to insure a high quality weld.
Evaluation .
The identified welds are completely inaccessible for volumetric or surface examination because they are located inside a containment penetration. Each primary containment penetration assembly, due to its design, leaves one pressure retaining piping weld inaccessible for examination by either surface or volumetric means. The welds can only be examined by inspecting for evidence of leakage during system hydro- i l
tests.
The licensee has proposed a surface examination of the '
accessible welds of the flued head penetration whenever the l
process piping to the flued head weld (outside containment) l is volumetrically examined. Only 25% of these welds are l
required to be examined each inspection interval, and the surface examination proposed is not on a pressure boundary .
weld.
The initial design of the assemblies did not provide for l
accessibility for inservice examinations. If it is assumed, l
though, that the workmanship and quality assurance of the l
welding as well as the preservice examinations are adequate, then an examination of the first pressure boundary weld outside j
the containment should reflect service induced failures for Jl1 science Apphcanons.inc.
that particular piping section. Thus, the first pressure boundary weld outside the containment on each of these pro-cess pipes could be volumetrically examined, where practical, over 100% of its length during each inspection interval. Such an examination would maintain sample size.
The licensee conducts system leakage tests in accordance with IWB-5221 prior to startup, following each reactor refueling outage. The licensee, however, could also conduct visual examinations at these penetrations whenever system leakage tests or hydrostatic tests are conducted in accordance with IWB-5210.
Conclusions and Reconnendations Based on the above evaluation, it is concluded that for these welds, the Code requirements are impractical. It is further concluded that the alternative examinations as proposed by the licensee are inadequate, but the alternative examinations discussed in the evaluation above will provide necessary added assurance of structural reliability. Therefore, the following is reconnended:
Relief should be . granted from the volunetric examination of the identified welds with the following provisions:
(a) The first pressure boundary weld outside the contsinment on each of these process pipes should be volumetrically examined, where practical, over 100% of its length during each inspection interval.
(b) Visual examinations should be perte.nied on thh con-tainment penetration assemblies when leakage and hydrostatic tests are conducted in accordance with
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References References 8, 12, 14, 22 and 25.
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- 2. Requests for Relief 2.1.6 and Q121.16-1; Pressure Retaining Welds in Piping, Category B-J, Item 84.5 Code Requirement Volumetric weld examinations shall be performed during each inspection interval and shall cover all of the area of 25% of the circumferential joints including the adjoining 1 ft' sections of longitudinal joints and 25% of the pipe branch connection joints.
Code Relief Request Relief is requested from performing the full 100% volumetric exmnination of the following pressure retaining welds:
Unit 1 Weld Identification % of Weld Examination Possible IE41-1HPCI-14-R-7 80 1E11-1RHR-24A-R-6 90 Unit 2_ % of Required Examination Completed 2B31-1RC-4AA 67 2B31-1RC-4AB 67 2B31-1RC-4BC 67 2B31-1RC-4BD 67 2B31-1RC-28A-17 67 2B31-1RC-28A-18 67 2B31-IRC-288-17 67 2B31-1RC-288-18 67 2E11-1RHR-24A-R-1 67 2E11-1RHR-24B-R-1 67 2E11-1RHR-24A-R-1A 61 2E11-1RHR-24B-R-1A 67 2821-1MS-24C-15 75 2B21-1MS-248-14 50 Proposed Alternative Examination A code-required volumetric examination of the subject welds will be performed to the extent possible. In addition, surface examination will be performed to the extent possible to supplement the limited volumetric examination.
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Licensee's Basis for Requesting Relief The arrangements and details of the piping systems and com-ponents are such that some examinations (as required by IUS-2600) are limited due to geometric configuration or accessibility.
Generally, these limitations exist at pipe-to-fitting welds, where examination can be fully perfonned only from the pipe side, the fitting geometry limiting or even precluding examination from the opposite side. Welds having such restrictions will be examined a the exte practical. However, all welds examined during the preservice examination for Unit I were fully Code inspectable.
Since hangers or other obstructions may have been added after the preservice examination, examination limitations may be en- ,
countered during the performance of the ISI weld examinations. !
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The results from Unit 2 show that a full Code examination 1 can be performed on 93% of the B-J welds. Similar results are i expected for Unit 1. !
Relief will be requested at the time any weld is found not to be fully Code inspectable as provided by 10 CFR 50.55a(g).
Evaluation The two identified welds for Unit 1 did not receive a full Code examination during the 1981 maintenance / refueling outage. The examinations were performed in accordance with the requirements of the 1974 Edition of the ASME Section XI Code, with Addenda through Summer 1975.
For Unit 2, the identified welds did not receive a full Code examination during preservice inspection. The examinations were performed in accordance with Section XI requirements of the Code.
The licensee has demonstrated that the subject welds cannot be fully examined in accordance with the Code. Efforts have been made to perform a full volumetric examination and in most instances,
'a surface examination as well. Hence, a full Code-required volu-metric examination of the identified welds is impractical.
The licensee's commitment to perform a surface examinati.on to the extent possible is reasonable. Also, visual examinations during hydrostatic pressure testing could be performed.
Conclusions and Recorrnendations Based on the above evaluation, it is concluded that for the welds discussed above, the Code requirements for 100%
volumetric examination are impractical. It is further 2l 1
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, concluded that the alternative examination discussed above will provide necessary added assurance of structural reliability. Therefore, the following is recommended:
Relief should be granted from the 100% volumetric ex-amination of the identified welds provided that the following examinations are performed:
(a) A best-effort volunetric examination, of the volumes estimated in the relief request (b) A surfa e examination, as proposed by the licensee (c) Visual examinations during system leakage and hydro-static pressure tests in accordance with IWB-5210.
References References 7, 8, 9, 12, 14, 18, 22, 23 and 25.
- 3. Class 1 Support f1 embers for Piping, Valves and Pumps, Category B-K-1, Items B4.9, B5.4 and B6.4 The licensee requested relief from the volumetric exami-nation of Category B-K-1 welded supports in Reference 16.
Relief was obtained by updating to the 1977 Edition, Summer 1979 Addenda, which permits a surface examination of Category B-K-1 welded supports. Permission to update was granted by the NRC in Referenc'e 19.
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4 Requests for Relief 2.1.2 and 3.1.1; Hydraulic Shock Suppressors for Class 1 and 2 Piping, Pumps and Valves, Categories B-K-2 and C-E-2, Items B4.10, B5.5, B6.5, C2.6, C3.4 and C4.4 Code Requirement The areas shall include the support componenfs that extend from the piping, valve, and pump attachment to and including the attachment to the supporting structure.
Visual examination shall be performed during each inspec-tion interval and shall cover all support components.
The support settings of constant and variable spring type hangers, snubbers, and shock absorbers shall be verified.
Code Relief Request The licensee requests relief from the examination requirements of Table IWB-2500, Category B-K-2, and Table IWC-2520, Category C-E-2, of Section XI.
Proposed Alternative Examination Hydraulic shock suppressors will be inspected and tested in accordance with Technical Specification requirements.
Licensee's Basis for Requesting Relief The hydraulic shock suppressors on Class 1 and 2 systems are currently subjected to an ongoing inspection and testing program detailed in the plant Technical Specifications that exceeds the requirements of the Section XI. This program is designed to demonstrate continued operational readiness and structural integrity of the shock suppressors and exceeds the requirements of Tables IWB-2500 and IWC-2520.
Evaluation The requirements of the plant Technical Specifications specify monthly inspections of the hydraulic shock suppressors, A
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whereas the requirements of Tables IWB-2500 and IWC-2520 of Section XI specify only one examination during an inspection interval of ten years.- There would be no need to perform an additional visual inspection during an inspection interval just to satisfy Section XI requirements. The intent of the requirements of the plant Technical Specifications is the same as that of the requirements of Section XI; i.e., the assurance of safety based on the adequate functioning of the hydraulic shock suppressors.
The requirements of the plant Technical Specifications meet all the requirements of Section XI for inspection and testing of hydraulic shock suppressors, with the exception of the reporting requirements. The principal basis for the licensee's relief request is to eliminate the duplication of records.
Reporting requirements in accordance with the plant Tech-nical Specifications are discussed in Regulatory Guide 1.16, including an explanation of what constitutes a reportable occurrence. For instance, degradation of hydraulic shock sup-pressors to the extent that they could not perform their re-quired safety function would be a reportable occurrence. Also, a violation of a technical specification would be a reportable occurrence. The reporting requirements for* reportable occur-rences are presented in Regulatory Guide 10.1.
The reporting requirements of the plant Technical Specifi-cations are more stringent than those of Section XI, i.e. ,
IWA-6220. Additional reporting requirements to satisfy In-service Inspection requirements should not be necessary.
Conclusions and Recommendations Based on the above evaluation, it is concluded that for the i
hydraulic shock suppressors discussed above, the Code requirements are impractical. 'It is further concluded that the alternative examination discussed above will provide necessary added assur-ance of structural reliability. Therefore, the following is recomended:
Relief from the examination requirements of Table IWB-2500, Category B-K-2, and Table IWC-2520, Category C-E-2, should be granted, provided the licensee inspects and tests Class 1 and 2 hydraulic shock suppressors in accordance with the plant Tech-nical Specification requirements, including the related reporting l
requirements.
I References References 8, 9, 12 and 14.
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5 Request for Relief per letter of March 2,1982 (Reference 20);
Class 1, 2 and 3 Support Components for Piping, Valves and Pumps, Categories B-K-2 and C-E-2, Items B4.10, B5.5, B6.5, C2.6, C3.4, and C4.4 Code Requirement e Categories B-K-2 and C-E-2, Support Components for Piping, Valves and Pumps i l
The areas shall include the support components that extend from the piping, valve, and pump attachment, and including the attachment to the supporting structure.
Visual examination shall be performed during each inspec-tion interval and shall cover all support components.
The support settings of constant and variable spring type hangers, snubbers, and shock absorbers shall be verifie..
I e IWD-2410(c), Class 3 Inspection Program (c) In addition, 100% of the components shall have been examined in accordance with IWA-5240 and IWD-2600 while in operation or during system inscryice testing, by the expiration of every one-third of each inspection interval.
e IWD-2600(c), Class 3 Examination Requirements (c) Supports (restraints) and hangers for components exceeding four-inch nominal pipe size whose structural in-tegrity is relied upon to withstand design loads when the system function is required shall be visually examined to de-tect any loss of support capability and evidence of inadequate restraint.
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Code Relief Request Relief is requested from the visual inspection require-ments of Category B-K-2 supports, Category C-E-2 supports, and Subsection IWD-2400 Class 3 supports.
A Science Apphcations,Inc.
proposed Alternative Examination The visual inspections for Class 1, 2, and 3 supports will be performed per the requirements of the 1980 Edition of ASME Section XI with addenda through Winter 1980.
Licensee's Basis for Requesting Relief Relief is primarily requested in that the 1974 Edition of the Code contains an ambiguous statement (i.e., IWD-2410(c))
concerning the frequency of visual inspection for Class 3 supports.
Evaluation The 1980 Edition of Section XI has been referenced in 10 CFR 50.55a and inservice examinations may meet the require-ments of this edition in lieu of those from previous editions with the following provisions:
(a) Commission approval is required to update to the more recent edition (pursuant to 10 CFR 50.55a (g)(4)(iv)).
- (b) Any requirement of the more recent edition which is related to the one(s) under consideration must also be met.
Visual examinations of the Class 1, 2 and 3 support com-ponents for piping, valves and pumps are also required by the 1980 Edition with Addenda through Winter 1980. Table IWF-2500-1 of the 1980 Edition presents uniform requirements for the. frequencies of the visual examinations.
Recommendations Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1980 Edition of Section XI, with Addenda through Winter 1980, for Categories B-K-2, C-E-2, and Class 3 support components.
References Reference 20.
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E. Pump Pressure Boundary
- 1. Class 1 Support Members for Pumps, Category B-K-1, Item B5.4 The licensee requested relief from the volumetric examina-tion of Category B-K-1 welded supports in Reference 16. Relief was obtained by updating to the 1977 Edition, Addenda through Summer 1979, which permits a surface examination of Category B-K-1 welded supports. Permission to update was granted by the NRC in Reference 19.
- 2. Hydraulic Shock Suppressors for Class 1 Pumps, Category B-K-2, Item B5.5 The request to examine hydraulic shock suppressors for Class 1 and 2 piping, pumps and valves in accordance with the
. requirements of the plant Technical Specifications (see I.D.4 of this report) applies here. Therefore, the following is recommended:
Relief from the examination requirements of Table IWB-2500, Category B-K-2, should be granted, provided the licensee examines and tests Class 1. hydraulic shock suppressors in accordance with the plant Technical Requirements, including the related reporting requirements.
- 3. Class 1 Support Components for Pumps, Category B-K-2 Item B5.5 The request to examine support components for Class 1, 2 and 3 piping, pumps and valves in accordance-with the require-ments of the 1980 Edition of Section XI (see I.D.5 of this report) applies here. Therefore, the following is recomended:
Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1980 Edition, Addenda through Winter 1980, of Section XI for Category
- B-K-2 support components.
F. Valve Pressure Boundary
- 1. Class 1 Support liembers for Valves, Category B-K-1, Item B6.4 The licensee requested relief from the volumetric examina-tion of Category B-K-1 welded supports in Reference 16. Relief was obtained by updating to the 1977 Edition, Addenda through Summer 1979, which permits a surface examination of Category B-K-1 welded supports. Pennission to update was granted by the NRC in Reference 19.
Al J science Applications. ine.
- 2. Hydraulic Shock Suppressors for Class 1 Values, Category B-K-2, Item B6.5 ,
The request to examine hydraulic shock suppressors for Class 1 piping, pumps and valves in accordance with the requirements of the plant Technical Specifications (see I.D.4 of this report) applies here. Therefore, the following,is recommended:
Relief from the examination requirements of Table IWB-2500, Category B-K-2, should be granted, provided the licensee examines and tests Class I hydraulic shock suppressors in accordance with the plant Technical Specification requirements, including the related reporting requirements.
- 3. Class 1 Support Components for Valves, Category B-K-2, Item B6.5 The request to examine support components for Class 1, 2 and 3 piping, pumps and valves in'accordance with the require-ments of the 1980 Edition, Addenda through Winter 1980, of Section XI (see I.D.5 of this report) applies here. There-fore, the following is reconmended:
Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1980 Edition of Section XI, Addenda through Winter 1980, for Category B-K-2 support components.
- 4. Relief Request 2.1.3, Internal Surfaces of Valves, Category B-M-2, Item B6.7 Code Requirement Visual inspection shall be performed of the internal pressure boundary surfaces, on valves exceeding 4-in, nominal pipe size.
One valve in each group of valves of the same construc-tional desigr., e.g., globe, gate, or check valve, manufacturing method and manufacturer that performs similar functions in the system shall be examined during each inspection interval.
The examinations may be perfonned at or near the end of the inspection interval.
A Science Apphcations,Inc.
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Code Relief Request Relief is requested from the visual examination of the internal surfaces at the pressure boundary of the Class 1 valves exceeding 4-in. diameter nominal pipe size.
Proposed Alternative Examination Class 1 valves exceeding 4-in. nominal pipe size are subjected to visual inspection of the internal surfaces of the valve body when disassembled for maintenance. The cover-age provided by inspections during routine maintenance coupled with periodic leak tests and hydrostatic tests will provide adequate assurance of the structural integrity of the Class 1 valve bodies, while keeping exposure to radiation and contamina-tion as low as reasonably achievable.
Licensee's Basis for Requesting Relief Disassembly of these valves solely for visual inspection during the inspection interval, in absence of other required maintenance, represents an unnecessary exposure to radiation and contamination and an excessive expense. The opening, visual in-spection, and closing of these valves would require an exposure of approximately 2 to 3 man-rem per valve. High conta levels produce airborne activities of 6 to 10 MPC ofwhich Igation requires the use of in-line or constant-flow respiratory equip-ment. Dose rates from the disassembled valves are typically 0.5 R/hr gamma and greater than 200 R/hr beta.
Valves on the recirculation loop suction piping would require off-loading the fuel elements and draining the reactor prior to dis-assembly. Work on recirculation pump discharge valves and residual heat removal injection valves would require installation of plugs in the jet pump risers. Preparatory work of this scope is considered impractical for the sole purpose of conducting a visual examina-tion. Contamination levels in the valves associated with the re-circulation loops are particularly high due to the physical loca-tion of these valves at the bottom of the system.
During routine maintenance, the valve body internal surfaces are vis'ually examined. Many of these valves, particularly the containment isolation valves, are disassembled for maintenance of leak-tightness. Disassembly of other Class 1 valves solely for internal inspection- is counter to the "ALARA" guidelines to keep the occupational dose rates as low as reasonably achievable.
In view of the cost in dollars and man-rem, and in view of the minimal benefits obtained, the licensee concludes that this code requirement does not provide sufficient benefits to justify such expenditures.
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science Appncations.inc.
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Evaluation The disassembly of large valves to the degree necessary to inspect the internal pressure retaining surfaces (bodies) is a major effort involving large personnel exposures. To do this disassembly solely to perform a visual examination of the inter-nal casing is impractical.
The licensee has committed to the concept of visual exami-nation if the valve is disassembled for maintenance. The visual examination specified is to detennine whether unanticipated severe degradation of the casing is occurring due to phenomena such as erosion or corrosion.
The visual examination of the internal pressure boundary may be performed at or near the end of the 10-year inspection interval. Therefore, relief from examination requirements is not necessary until then because the licensee will be in com-pliance with the regulation up to that time. Since so many licensees consider this requirement impractical and an undue burden, it is reasonable to postpone a decision to grant relief until near the end of the inspection interval when additional relevant information from this plant and from the industry in general will be available.
The licensee could submit a new relief request at that time for each valve classification for which a valve has not been disassembled and examined in each unit. Submitting such relief requests as soon as possible after the next-to-last scheduled outage of the inspection interval and at least six months before the scheduled start of the last outage would minimize delays and outage time.
For those inspection periods when valve maintenance does not occur, visual examinations could be perfomed when the system pressure tests (IWA-5000) are conducted in av ordance with the requirements for Category B-P.
Conclusions and Recommendations l Based on'the above evaluation, it is concluded that for i the valves discussed above, there is not presently enough i justification for granting relief from impractical Code re-l quirements. Therefore, the following is recommended:
(a) Relief should not be granted at this time from visual examination of the internal pressure boundary surfaces on valves exceeding 4-in, nominal pipe size.
i I (b) The licensee's proposal to perform the Code required examinations whenever the valves are opened because of maintenance should be accepted.
science Apphcations,Inc.
(c) During other inspection periods, the licensee should perform visual examinations for leakage when the system pressure tess (IWA-5000) are conducted in accordance with the requirements for Category B-P.
(.d) The licensee should submit specific relief requests as the end of the inspection interval approaches for each valve classification for which a valve has not been disassembled and examined in each unit.
References References 8, 9, 12, 14, 22, 23 and 25.
Science Applications,Inc.
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II. CLASS 2 COMPONENTS A. Pressure Vessels No relief requests.
B. Piping
- 1. Request for Relief Q121.17; Pressure Retaining Welds in Piping, Ca?.egories C-F, C-G and C-E-1, Items C2.1, C2.2, C2.3 and C2.5 (Unit 2 only)
Code Requirement Categories C-F and C-G: Pressure-Retaining Welds in Piping, Pumps, and Valves in Systems which Circulate Reactor Coolant and which Circulate other than Reactor Coolant Volumetric weld examinations shall cover 100% of all the welds. This examination shall be scheduled over the lifetime of the plant (four intervals with three periods within each interval).
Category C-E-1: Support Members for Piping, Valves and Pumps Surface examinations shall be performed during each in-spection interval and shall cover 100% of the major load bear-ing elements of the support structure and hanger.
The areas 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.
Code Relief Request Relief is requested from the full 100% volumetric exami-nation of the Category C-F and C-G pressure-retaining welds, and the full 100% surface examination of the Category C-E-1 welds listed in Table 0121.17-1 of the Hatch Ho 2 Final Safety Analysis Report (FSAR).
l science Appiications inc.
1 Proposed Alternative Examination A "best effort" ultrasonic examination will be performed on all piping welds except for those few-which are totally inaccessible due to encapsulation. A surface examination will be performed on all piping welds to the maximum extent possible, except for those which are totally inaccessible.
A "best effort" surface examination will be performed on all Category C-E-1 welds which are partly accessible. However, most of these welds are totally inaccessible for all examinations.
Licensee's Basis for Requesting Relief The arrangement and details of the Class 2 piping systems and components were designed and fabricated before the examina-tion requiremfnts of Section XI of the Code were formalized, and some examinations (as required by IWC-2600) are limited or not practical due to geometric configuration or accessiblity.
Generally, the limitations exist at all fitting-to-fitting welds such as elbow-to-tee, elbow-to-valve, reducer-to-valve, etc.,
where geometry and sometimes surface conditions preclude ultra-sonic coupling or access for the required scan length. Welds having such restrictions will be examined to the extent practical.
In instances where the location of pipe supports on hangers restricts the access available for the examination of pipe welds as required by IWC-2600, examinations will be performed to the extent practical unless removal of the support is permissible without unduly stressing the system.
The results from Unit 2 show that a full Code examination can be performed on 97% of the C-F welds and 99% of the C-G welds.
Table Q121.17-1 was compiled during the preservice inspec-Evaluation l
The identified welds for Unit 2 did not receive a full
' Code examination during the preservice inspection. The exam'.-
nations were perfomed in accordance with Section XI requirements of the Code. Of the several dozen welds involved, most are Category C-F welds.
The licensee has demonstrated that the subject welds cannot be fully examined in accordance with the Code. Efforts have been made to perform a full volumetric examination of the piping welds and in most instances a surface examination as well. Efforts I
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have also been made to perform a full surface examination of the Category C-E-1 welds. Hence, a full Code required examination of the welds identified in the FSAR is imprac- 1 tical. I As proposed by the licensee, a best-effort ultrasonic examination and surface examination of the accessible areas i of the piping welds are practical for the above Category C-F and C-G welds. The ultrasonic examination should cover the estimated extent of examination given in the FSAR. Visual examinations could also be performed during system leakage and hydrostatic tests and would be the only type of exami-nation that could be perfonned on the inaccessible Category C-E-1 welds.
Conclusions and Recomendations l Based on the above evaluation, it is concluded that for j the identified Category C-F, C-G and C-E-1 welds, the Code l requirements are impractical. It is further concluded that the alternative examinations discussed above will provide nec-essary added assurance of structural reliability. Therefore, the following is reconsnended: -
Relief should be granted from the full 100% volumetric examination of the Category C-F and C-G piping welds and from the full 100% surface examination of the Category C-E-1 welds, as identified in Table Q121.17-1 of the FSAR, provided that the following alternative examinations are performed:
Category C-F and C-G welds: f.
(a) a best-effort ultrasonic examination of the acces-sible weld volume to the extent estimated in the FSAR and a surface examination, as proposed by the licensee, and (b) visual examinations during system hydrostatic pressure tests in accordance with IWB-1220(c).
Category C-E-1 welds:
Visual examinations during system hydrostatic pressure tests in accordance with IWB-1220(c).
i References References 8, 9,12,14, 22, 23 and 25.
Science Applications Inc.
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- 2. Hydraulic Shock Suppressors for Class 2 Piping, Category C-E-2, Item C2.6 The request to examine hydraulic shock suppressors for Class 1 and 2 piping, pumps, and valves in accordance with the requirements of the plant Technical Specifications-(see I.D.4 of this report) applies here. Therefore, the following is recomended:
Relief from the examination requirements of Table IWC-2520, Category C-E-2, should be granted, provided the licensee examines and tests Class 2 hydraulic shock suppressors in accordance with the plant Technical Specification requirements including the related reporting requirements.
- 3. Class 2 Support Components for Piping, Category C-E-2, Item C2.6 f
The request to examine support components for Class 1, 2 and 3 piping, pumps and valves in accordance with the require-ments of the 1980 Edition, through Winter 1980 Addenda, of Section XI (see I.D.5 of this report) applies here. Therefore, the following is recommended:
Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1980 Edition of Section XI, Addenda through Winter 1980, for Category C-E-2 support components.
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science Applications.inc.
C. Pumps
- 1. Code Relief Requests 3.1.2 and 3.1.3, Class 2 Bolting, Category C-D, Items C3.2 and C4.2 Code Requirement -
The examination shall be visual and either surface or volumetric.
The areas shall include bolts, studs, nuts, bushings, '
washers, and threads in base material and flange ligaments be-tween threaded stud holes.
Visual examinations performed during each inspection in-terval shall cover 100% of the bolts, studs, nuts, bushings, and threads in base material and flange ligaments between threaded stud holes.
Nondestructive examinations shall be performed on 10% of the bolting in each joint, but not less than two bolts or studs per joint.
Bushings, threads, and ligaments in base material of flanges are required to be examined only when the connection is dis ,
assembled.
Bolting may be examined either in place under tension, when the connection is disassembled, or when the bolting is removed.
Code Relief Request Relief is requested from the inservice examination of pressure-retaining bolting over 1-in. in diameter for the High Pressu're Coolant Injection (HPCI) and the Reactor Core Isolation Cooling (RCIC) pumps (or turbines) and valves.
Proposed Alternative Examination The bolting will receive a surface examination when the pumps (or turbines) and valves are disassembled for maintenance.
Al J science Appucations ine.
Licensee's Basis for Requesting Relief The examination of the obscured stud bolts can be ac-complished only by detensioning all bolting in sequence. If this is done,the pump (or turbine, or valve) cover should be lifted for gasket replacement.
It is anticipated'that the pump (and turbine and valves) will require disassembly for maintenance at various times. As the pump / turbine is tested per Section XI, Articles IWP and IWV, the disassembly for the purpose of examining four studs is not practical.
The licensee plans to update'the inservice inspection pro-gram for Units 1 and 2 in January 1983 to the 1980 Edition of Section XI with Addsnda through Winter 1.980. '
Evaluation s The licensee can ot:tain relief from these requests by updating-to either the 1977 Edition or the 1980 Edition. The requirements for examining Class 2. bolting 2-in.zdiameter and under are deleted from the 1977 Edition with Addenda through Suntaer 197.8', but volumetric examination is subst,ituted for visual examination of boltstand studs ofslerger diameters.
Class 1 bolting exactly 2nin. in diameter is shifted from '
Category B-G-1 to Cate' gory B-G-2. This shift substitutes visual for? volumetric (and in so % cases, surface) examina-tions in virtually sii instances.*
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The 1977 Edition of Section XI has been referenced in 10 CFR.50.55a and intervice examinations may meet the require-ments of this edition in lieu of those from previous editions with the following provisions:
(a) Commission approval is required to update to the'
! ~ mors recent edition (pursuasjt 'to 10 CFR 50.55.c l
- (g)(4)(iv)).
(b) When applying .the 1977 Edition, all of the, ddenda through Surinefl$0 Addenda must be used. ,
! (c) Any requirement of;the more recent edition which '
is related to the one(s) under consideration ~
_ must also be met.
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Recommendations Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the Summer 1978 Addenda for Category B-G-1, B-G-2, and C-D items. This approval would delete the requirement to examine Class 2 bolting 2-inches in diameter and under and would shift Class 1 bolting exactly 2-inches in diameter from Category B-G-1 to B-G-2.
I References References 8, 9, 12, 14, 22, 23 and 25.
- 2. Hydraulic Shock Suppressors for Class 2 Pumps, Category C-E-2, Item C3.4 The request to examine hydraulic shock suppressors for Class 1 and 2 piping, pumps, and valves in accordance with the requirements of the plant Technical Specifications (see I.D.4 of this report) applies here. Therefore, the following is reconsnended:
Relief from the examination requirements of Table IWC-2520, Category C-E-2 should be granted, provided the licensee examines and tests Class 2 hydraulic shock suppressors in accordance with the plant Technical Specification require-ments, including the related reporting requirements.
- 3. Class 2 Support Components for Pumps, Category C-E-2, Item C3.4 The request to examine support components for Class 1, 2 and 3 piping, pumps and valves in accordance with the require-ments of the 1980 Edition, through Winter 1980 Addenda (see I.D.5 of this report) applies here. Therefore, the following is recommended:
Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1980 Edition of Section XI, with Addenda through Winter 1980, for Category C-E-2 support components.
Science Applications,Inc.
D. Valves
- 1. Hydraulic Shock Suppressors for Class 2 Valves, Category .
~
C-E-2, Item C4.4 The request to examine hydraulic shock suppressors for Class 1 and 2 piping, pumps, and valves in accordance with the requirements of the plant Technical Specifications (see I.D.4 of this report) applies here. Therefore, the following is recomended:
Relief from the examination requirements of Table IWC-2520, Category C-E-2, should be granted, provided the licensee examines and tests Class 2 hydraulic shock suppressors in accordance with the plant Technical Specification requirements, including the related reporting requirements.
- 2. Class 2'Supoort Components for Valves, Category C-E-2, Iten C4.4 The request to examine support components for Class 1, 2 and 3 piping, pumps and valves in accordance with the require-ments of the 1980 Edition of Section XI, through Winter 1980 Addenda (see I.D.5 of this report) applies here. Therefore, '
the following is recommended:
Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1980 Edition of Section XI, with Addenda through Winter 1980, for Category C-E-2 support components.
III. CLASS 3 COMP 0iiENTS A. Piping, Pumps and Valves
- 1. Class 3 Support Components for Piping The request to examine support components for Class 1, 2 and 3 piping, pumps and valves in accordance with the require-ments of the 1980 Edition of Section XI, through Winter 1980 Addenda (see I.D.5 of this report) applies here. Therefore, the following is recomended:
Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1980 Edition of Section XI, with Addenda through ; linter 1980, for Class 3 support components.
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science Appocations,Inc.
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- 2. Code Relief Request per Section 4.0 of Reference 14; Inspection of Vertical, Centrifugal River Intake Pumps, per IWD-2410(b) and (c)
Code Requirement IWD-2410: Inspection Program (b) 100% of the components shall have been tested and examined in accordance with IWA-5000, IWD-5000, and IWD-2600 by the expiration of each inspection interval.
(c)- In addition, 100% of the components shall have been examined in accordance with IWA-5240 and IWD-2600 while in operation or during system inservice testing, by the expira-tion of every one-third of each inspection interval.
IWD-2600 : Examination Requirements Components in systems
- or portions of systems shall be subjected to the following examination:
(a) Visual examination shall be conducted for evidence of component leakages (other than controlled or collected leakages), structural distress, or corrosion when the system is undergoing either a system inservice test, component func-tional test (i.e., valves and pumps) or a system pressure test.
Code Relief Request Relief is requested from the requirements of IWD-2410 (b) frd (c) for inspection of the vertical, centrifugal river intake pumps, except at the pump discharge nozzle.
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i Proposed Alternative Examination j!
Visual inspection of the dischfrge nozzle will be performed while the pump is operating. Should the pump be pulled for maintenance, the casing will be visually inspected at that time.
Licensee's Basis for Requesting Relief Pumps are submerged in water.
- The service water system, including the river intake pumps, is included in this group.
A science Apphcations,Inc.
Evaluation Visual inspection of the pumps per the Code requirements is impractical. Since the pumps are submerged in river water, there are no safety implications involved. Significant leaks.
from the pump casings to the river would be indicated by drops in both the discharge pressure and flow from the pumps measured by instrumentation. The licensee's proposed alternative examina-tion is practical and should be accepted.
Conclusions and Recommendations Based on the above evaluation, it is concluded that for the visual examination discussed above, the code requirements are impractical. It is further concluded that the alternative examination discussed above will provide necessary added assur-ance of structural reliability. Therefore, it is recommended that this code relief request be. granted provided that the alternative examination is performed.
References References 8, 9, 12 and 14.
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IV. PRESSURE TESTS A. General
- 1. Relief Requests 2.1.1, 3.1.5, 4.1.1 and Letter of May 1, 1980; Hold Time, Class 1, 2 and 3 Systems Code Requirement IWA-5210(a): The pressure retaining components shall be visually examined while the system is under the hydrostatic test pressure and temperature. The test pressure and temperature shall be maintained for at least four hours prior to the per-formance of the examinations.
Code Relief Request Relief is requested from the Code requirement to hold test pressure for four hours prior to visual examination of non-insulated systems and components.
Proposed Alternative Examination For non-insulated piping, the test pressure and temperature will be held for 10 minutes before walkdown.
Licensee's Basis for Requesting Relief The 1974 Edition of Section XI, Summer 1975 Addenda, does not differentiate between test duration for insulated /non-insulated systems or components. Currently, test pressure and temperature must be held for four hours prior to performance of examination.
All later addenda (e.g. , Winter 1975) and codes (particularly the recently approved 1977 Section XI Code) differentiate between insulated /non-insulated piping for test duration.
Evaluation The 1977 Edition, Summer 1978 Addenda, of Section XI has l
been referenced in 10 CFR 50.55a and inservice examinations may meet the requirements of this edition in lieu of those from previous editions with the following provisions:
(a) Commission approval is required to update to the more i
recent edition (pursuant to 10 CFR 50.55a(g)(4)(iv));
(b) When applying the 1977 Edition, all of the addenda through Summer 1978 Addenda must be used; (c) Any requirement of the more recent edition which is related to the one(s) under consideration must also be met.
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The licensee ccald update to the 1977 Code, Sumer 1978 Addenda, in which IWA-5213 would allow a 10-minute bold time for non-insulated piping / components during pressure tests.
IWA-5213 refers to types of tests and to pressure and temp-erature conditions that are defined in other paragraphs of Subsubarticle IWA-5210. ' The entire subsubarticle needs to be adopted to comply with requirements of (c) above.
Recomendations Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of Subsubarticle IWA-5210 in the 1977 Edition, Summer 1978 Addenda. This approval wculd permit the licensee to use a 10-minute hold time for non-insulated piping / components during pressure tests.
References References 13 and 14.
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B. Class 1 System Pressure Tests
- 1. Code Relief Request 2.1.1 and Letter of May 1, 1980; Hydrostatic Testing, Class 1 Systems Code Requirements IWB-5000 requires that hydrostatic tests be performed at a test temperature of > 100 0F.
Code Relief Request Relief is requested from the above requirement of IWB-5000 for all Class 1 systems except for the nuclear boiler system which is restricted by fracture toughness requirements.
Proposed Alternative Examination The piping contract for Hatch specified 0 that the hydro-static test pressure be performed at 70 F plus the nil ductility factor. This factor has been detennined to be a negative number for the piping at Hatch. Therefore, the test temperature 0 for hydrostatic testinc will be > 700F only where the 100 F tempera-ture requirement cannot be met.
Licensee's Basis for Requesting Relief The 1974 Edition of the Code specifies that hydrostatic 0 testing for Class 1 piping and components be performed at 100 F.
It is not possible for the licensee to meet the particular temperature requirement for the majority of the hydrostatic tests. There is one test, however, that can be conducted at the required test temperature: ,
Class 1 - 2B21-PT-1.
This test can be performed at 1000 F because it is on the nuclear boiler system (2B21) where heat is already being generated. It is necessary that all0 remaining Class I hydrostatic tests be conducted at > 70 F. The piping .
contractforUnit2originallyspeciffedthathydrostatic testing can be performed at around 70 F, plus nil ductility factor. This factor has been determined to be negative numbers 0
and should have no bearing on the desired > 70 F hydrostatic test temperature. In order to perfonn hydrostatic testing at the ASME required temperature, it would be necessary to temporarily and/or permanently heat trace piping, not to mention extensive piping insulation removal and/or modifications to accommodate testing at the required 100 0F. Testing at 100 F would prove to be an undue hardship. Change to the lower temperature is justified and should be allowed.
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The licensee has advised that it is currently performing hydrostatic testing at 2,70 0F at Units 1 and 2 after consulting with the liatch NRC Project Manager.
Evaluation To adhere to the requirements of IWB-5000 for maintaining test temperatures of Class 1 systems at > 1000F would require extensive time and costs to remove insula' tion and to heat trace lines. Clearly, i,t. is impractical for Units 1 and 2 to test Class 1 systems pqr the full requirements of IWB-5000.
Conclusions and Recanmendations Based on the above evaluation, it is concluded that for the test temperature requirements of IWB-5000 discussed above, the Code requirements are impractical. It is further concluded that the alternative examination discussed above will provide necessary added assurance of structural reliability. Therefore, l it is recmanended that relief be granted from the temperature requirements of IWB-5000, provided that the proposed alternative examination is performed; i.e., testing Class 1 systems at
> 700F only where the 100 F temperature requirement cannot Ee met.
References References 13 and 14.
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C. Class 2 System Pressure Tests
- 1. Systems That Cannot Be Isolated from Class 1 Systems, per Item 2 of Attachment 1, Reference 25 Code Requirement The system hydrostatic test pressure shall be at least 1.25 times the system design pressure (PD) and conducted at a test temperature not less than 1000F except as may be required to meet the test temperature requirements of IWA-5230.
Code Relief Request Relief is requested from hydrostatically testing the Class 2 portion of the four-inch reactor water cleanup system return line between check valve 1G31-F039 and globe valve IG31-F.042 at 1.25 times design pressure.
Proposed Alternative Examination In lieu of the Class 2 pressure requirements, this section of piping will be hydrostatically tested to the Class 1 pressures specified in IWB-5222.
Licensee's Basis for Requesting Relief Testing at this pressure will overpressurize the Class 1 piping downstream of valve 1G31-F039. .
Evaluation The design of the subject system prevents isolation of Class 1 and 2 systems at the class boundary. To prevent over-pressurization of the Class 1 components requires that the portions of the Class 2 system be tested at the same time as the hydrostatic test for the reactor vessel. Hence, the code requirements for testing the Class 2 system are impractical.
The difference in test pressure between Class 1 and 2 is not large and leaks will be adequately detected in the Class 2 lines sub-jected to the Class 1 test pressures. The alternative test pro-cedure would be adequate in providing assurance of the systems' integrity during the inspection interval.
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Conclusions and Recannendations Based on the above evaluation, it is concluded that for the portions of Class 2 systems discussed above, the Code requirements are impractical. It is further concluded that the alternative examination discussed above will provide neces-sary added assurance of structural reliability. Therefore, it is recommended that this Code relief be granted, provided that the piping be hydrostatically tested to the pressure specified in IWB-5222.
References References 8,12,14,19, 23 and 25.
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- 2. Relief Request 3.1.5 and Letter of f4ay 1,1980; Hydrostatic Testing, Class 2 Systems Code Requirement IWC-5000 requires that hydrostatic tests be performed at a test temperature of > 1000F.
Code Relief Request Relief is requested from the above requirements of IWC-5000 for all Class 2 systems except portions of the standby liquid control system which are normally heat-traced.
Proposed Alternative Examination The piping contract for Hatch specified 0 that the hydro-static test pressure be performed at 70 F plus the nil ductility factor. This factor has been determined to be a negative number for the piping at Hatch. Therefore,thetesttemperagurefor 0
hydrostatic testing will be > 70 F only where the 100 F temper-ature requirement cannot be net.
Licensee's Basis for Requesting Relief The 1974 Edition of the Code specifies that hydrostatic testing for Class 2 piping and components be performed at 100 F.
It is not possible for the licensee to meet that particular temperature requirement for the majority of the hydrostatic tests. There is one test, however, which can be conducted at the required test temperature:
Class 2 - 2C41-PT-1.
The reason the above referenced test can be performed at 100 F is because some of the piping of the standby liquid control l system (2C41) is heat traced due to the sodium pentaborate solu-tion temperature requirements. Itisnecessarfthatallremaining Class 2 hydrostatic tests be conducted at > 70 F. The piping con-tract for Unit 2 originally specified that hydrostatic testing be performed at around 70 F, plus nil ductility factor. This factor l
has been detemined to be negative numbers and should have no bearing on the desired > 700F hydrostatic test temperature. In order to perfom hydrostatic testing at the ASME required temp-l erature, it would be necessary to temporarily and/or permanently heat trace piping, not to mention extensive piping insulation removal and/or modifications go accomodate testing at the re-quired 1000F. Testing at 100 F would prove to be an undue t
hardship. Change to the lower temperature is justified and
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Thelicenseahasadvisgdthatitiscurrentlyperforming hydrostatic testing at >_ 70 F at Units 1 and 2 after consulting with the Hatch Ni<C Project Manager.
Evaluation Relief from the requirements of IWC-5000 as requested by the licensee can be obtained by updating to the 1977 Edition of Chapter XI, through Summer 1978 Addenda.
The 1977 Edition of Section XI has been referenced in 10 CFR 50.55a and inservice examinations may meet the require-ments of this edition in lieu of those from previous editions with the following provisions:
(a) Commission approval is required to update to the more recent edition (pursuant to 10 CFR 50.55a(g)(4)(iv));
(b) When applying the 1977 Edition, all of the addenda through Sumer 1978 Addenda must be used; (c) Any. requirement of the more recent edition which is related to the one(s) under consideration must also be met.
The temperature specification in the 1977 Edition, Summer 1978 Addenda, is at the discretion of the licensee (IWC-5230(b)),
effectively allowing Class 2 systems to be hydrotested at ambient temperatures. Updating to the 1977 Edition, Sumer 1978 Addenda, would eliminate the need for relief from Code requirements.
Conclusions and Recommendations Based on the above evaluation, relief from Code require-ments should not be granted. Instead, pursuant to 10 CFR 50.55a (g)(4)(iv), approval should be granted to update to the require-ments of the 1977 Edition. Summer 1978 Addenda for IWC-5230.
References References 13 and 14.
Al Science AppHcahons,Inc.
f D. Class 3 System Pressure Tests
- 1. Code Relief Request per Section 4.0 of Reference 14; Testing of Service Water Systems Buried Piping, IWD-2600(b);
Testing of Service Water Systems, IWD-2410(b)
Code Requirement IWD-2410 Inspection Program:
(b) 100% of the components shall have been tested and examined in accordance with IWA-5000, IWD-5000 and IWD-2600 by the expiration of each inspection interval. i (c) In addition, 100% of the components shall have been e examined in accordance with IWA-5240 and IWD-2600 while in operation or during system inservice testing, by the expira-tion of every one-third of each inspection interval.
IWD-2600 Examination Requirements:
Components in systems
- or portions of systems shall be subjected to the following examination:
(a) Visual examination shall be conducted for evidence of component leakages (other than controlled or collected leakages),
structural distress, or corrosion when the system is undergoing either a system inservice test, component functional test (i.e.,
valves and pumps) or a system pressure test.
(b) In the case of buried components (e.g., underground piping), val'ves shall be provided to permit isolation of the buried portions of piping for the purpose of conducting a system pressure test in lieu of the visual examination. A loss of system pressure during the test shall constitute evidence of component leakage.
IWD-5200 System Test Requirements:
(a) The system test pressure shall be at least 1.10 times the system design pressure.
Code Relief Request Code relief is requested from the requirements of IWD-5200 in regard to hydrostatically testing the Plant Service Water System (PSW).
The service water system is included in this group.
A science AppHcahonsJnc.
Proposed Alternative Examination In lieu of the hydrostatic test, the PSW will be examined at operating pressure for any signs of leakage and for the general condition of the piping.
Licensee's Basis for Requesting Relief At least 22 various systems are cooled by the PSW. All the components are essential to the plant during operation and more than half of these normal loads must still be cooled during plant shutdown conditions. Due to the arrangement of these cooling loads between the two trains of PSW, it is not feasible to completely remove one train from service to perform hydrostatic testing.
It is also not feasible to subdivide the trains into smaller, separate hydrostatic tests. Heat exchangers and instruments would be isolated prior to testing to prevent damage to these components. Thus, only common headers would be left for testing, and these headers cannot be isolated due to cooling requirements.
The PSW lines are uninsulated, and therefore, any evidence of leakage would easily be detected during a walkdown at system operating pressure. Also, the general condition of the piping will be examined for any signs of excessive corrosion. There-fore, testing performed in lieu of hydrostatic testing will adequately ensure that the integrity of the PSW piping is maintained.
The designs nf the service water systems do not include provision for testing buried piping as required by IWD-2600(b).
Visual inspection for leakage at ground level is also impossible for portions which are buried. Normal system functional testing demonstrates leaktight integrity of all buried or encased piping.
Evaluation The two trains of the service water system are supposed to be sufficiently redundant that operation with one train only is permissible for a limited time, according to the technical specifications.
Subarticle IWD-5200 which provided the above Code require-ment in the 1974 Edition, Summer 1975 Addenda, was significantly expanded in subsequent versions of Section XI. In the Summer 1978 Addenda of the 1977 Edition, Paragraph IWD-5210, that subarticle required that pressure-retaining components within the boundaries of each Class 3 system undergo various pressure tests, including a system hydrostatic test. For pressure testing, Class 3 systems are divided into three examination categories specified in Table IWD-2500-1. These categories involve supporting one of the following functions: reactor shutdown, emergency core cooling, Al1 Science Apphcations,Inc.
E containment heat removal, atmosphere cleanup, reactor residual
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heat removal, and residual heat removal from spent fuel storage pool. The service water system cited in the licensee's basis for requesting relief provides functions in all three of these categories.
The 1977 Edition of Section XI has been referenced in 10 CFR 50.55a and inservice examinations may meet the require-ments of this edition in lieu of those from previous editions with the following provisions:
(a) Commission approval is required to update to the more recent edition (pursuant to 10 CFR 50.55a(g)(4)(iv));
(b) When applying the 1977 Edition, all the addenda through Sumer 1978 Addenda must be used; (c) Any requirement of the more recent edition which is related to the one(s) under consideration must also be met.
In view of the detailed requirements in the Sumer 1978 Addenda of the 1977 Edition, it is not appropriate to grant the total code relief from hydrostatically testing the service water system, as requested by the licensee. Instead, the requirements of Subarticle IWD-5200 in the Sumer 1978 Addenda can be applied.
These requirements, while more specific than those in the Sumer .
1975 Addenda, do provide some relief; for example, the hydro-static test pressure is lower. If the licensee finds specific technical justification for not being able to comply with any part of these requirements, a relief request for individual portions of the service water system could be submitted.
Paragraph IWA-5244 of the Sumer 1978 Addenda,1977 Edition, gives alternative VT-2 examinations during pressure tests for buried lines of various types and configurations. The licensee can comply with these requirements in Paragraph IWA-5244.
Conclusions and Recomendations
! Based upon the above evaluation, it is concluded that there is not enough justification for granting blanket relief from Code l
requirements for hydrostatically testing the service water. system.
Therefore, the following is recommended:
(a) Relief should not be granted from the system pressure test requirements; (b) The licensee should update to the requirements of
' Subarticle IWD-5200 and Paragraph IWA-5244 in the 1977 Edition, Sumer 1978 Addenda, pursuant to 10 CFR 50.55a(g)(4)(iv);
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(c) If any of the updated Code requirements are determined to be impractical, the licensee should submit a specific relief request for indisidual portions of this system.
References References 8, 9, 14, 22, 23 and 25.
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V. GENERAL A. Ultrasonic Examination Technique No relief requests.
B. Exempted Components
- 1. Code Exemption per Note 9 of Attachment 2, Reference 25; IWC-1220(a),
Components Exempted from Examination Based on Pressure and Temperature Code Requirement 1974 Edition Section XI - IWC-1220(a):
The following components may be exempted from the examina-tion requirements of IWC-2520:
(a) Components in systems where both the design pressureapdtemperatyreareequaltoorless than 275 psig and 200 F respectively.
1977 Edition Section XI (Summer 1979 Addenda) - IWC-1220(b):
The following components shall be exempted from the inservice examination requirements of IWC-2500:
(b) Components of systems or portions of systems, other than Residual Heat Removal Systems and Emergency Core Cooling Systems, that are not required to oper-ate above a pressure of 275 psig (1900 kPa) or above a temperature of 200 F (93 C).
Exemption Exemption from examination of piping welds in the Residual Heat Removal Systems (RHRS), Emergency Core Cooling Systems (ECCS),
and Containment Heat Removal Systems is claimed according to IWC-1220(a),1974 Edition of Section XI.
Evaluation Paragraph IWC-1220(b) of Section XI, Summer 1978 Addenda, does not pennit the exemption from examination of components in the ECCS and the RHRS that operate below 275 psig or below 200U F. Hence, low operating pressure and temperature is not an acceptable basis for exempting ECCS and RHRS components from inservice examination.
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Components in the RHRS and the ECCS cannot be examined underIWC-1220(a). It is required that a representative sample of welds on these components be examined.
Conclusions and Recommendations Based on the above evaluation, it is concluded that com-ponents in the RHRS and ECCS should not be exempted. The licensee should include a representative sample of welds on the RHRS and ECCS components in the Inservice Inspection Program.
References References 8,12,14, 23 and 25.
I AI science Apphcations,Inc.
REFERENCES
- 1. G. Lear (NRC) to I. S. Mitchell, III (GPC, April 26, 1976.
- 2. GPC to NRC, Intention to Develop ISI Program, November 15, 1976.*
- 3. G. Lear (NRC) to I. S. Mitchell, III (GPC), Edwin I. Hatch Nuclear Plant Unit No. 1, November 22, 1976.
- 4. NRC to GPC, Guidance, January.7, 1977.*
- 5. C. F. Whitmer (GPC) to J. F. Stolz (NRC), Construction Permit CPPR-90, Edwin I. Hatch Nuclear Plant Unit 2, Inservice Inspection Program, NRC Docket 50-366, June 7, 1977.
- 6. J. F. Stolz (NRC) to C. F. Whitmer (GPC), Inservice Inspection Program, Edwin I. Hatch Nuclear Planti,' Unit 2 (HNP-2), July 7,1977.
- 7. J. F. Stolz (NRC) to C. F. Whitmer (GPC), Request for Additional Information - Preservice and Inservice Inspection Programs (Edwin I.
Hatch Nuclear Plant, Unit lio. 2), December 19, 1977.
- 8. C. F. Whitmer (GPC) to Director, NRR (NRC), ISI Proc ram Submittal, Edwin I. Hatch Nuclear Plant Unit 1, NRC Docket 50-121, August 3,1978.
- 121 Q's, September 1978.
- 10. C. F. Whitmer (GPC) to Director NRR (NRC), inservice Inspection, Edwin I. Match Nuclear Plant Unit 1, January 24, 1979.
- 11. T. A. Ippolito (NRC) to C. F. Whitmer (GPC), ISI Meeting Sumary, March 28, 1979.
- 12. C. F. Whitmer (GPC) to Director NRR (NRC), ISI Program Amendment #1, Edwin I. Hatch Nuclear Plant Unit 1, June 6, 1979.
- 13. W. A. Widner (GPC) to Director NRR (NRC), Additional Information on Inservice Inspection and Relief Request, Edwin I. Hatch Nuclear Plant Unit 2, May 1, 1980.
- 14. W. A. Widner (GPC) to Director NRR (NRC), ISI Program Amendment #2, Edwin I. Hatch Nuclear Plant, Unit 1, January 27, 1981.
- 15. J. T. Beckham (GPC) to Director NRR (NRC), Inservice Inspection Period Extension Request, Edwin I. Hatch Nuclear Plant, Unit 1, November 10, 1981.
- 16. J. T. Beckham (GPC) to Director NRR (NRC), Inservice Inspection of ASME Category B-K-1 Welded Sup) orts - Relief Request, riatch Nuclear Plants, Units 1 and 2, November 13, 1981.
science.sooncauons. ine.
- 17. J. F. Stolz (NRC) to J. T. Beckham (GPC), Approval of Inservice Inspection Extension Request, Edwin I. Hatch Nuclear Plant Unit 1, November 23, 1981.
- 18. J. T. Beckham (GPC) to Director NRR (NRC), Limitations Experienced During 1981 Class 1 Inservice Examinations, Edwin I. Hatch Nuclear Plant Unit 1,.
November 24, 1981,
- 19. J. F. Stolz (NRC) to J. T. Beckham (GPC), January 27, 1982.
- 20. J. T. Beckham (GPC) to Director NRR (NRC), Inservice Inspection of Supports for Class 1, 2 and 3 Components, Edwin I. Hatch Nuclear Plant Units 1 and 2, March 2, 1982.
- 21. J. T. Beckham (GPC) to Director NRR (NRC), Inservice Inspection Relief Request, March 11, 1982.
- 22. J. F. Stolz (NRC) to J. T. Beckham (GPC), Request for Additional Infomation, Hatch Plant Unit 1, Program Relief Requests, March 12,
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1982.
- 23. J. F. Stolz (NRC) to J. T. Beckham (GPC), Additional Infomation Request, Hatch Plant Unit 1, April 6,1982.
- 24. J. F. -Stolz (NRC) to J. T. Beckham (GPC), April 7,1982.
- 25. W. A. Widner (GPC) to Director NRR (NRC), Additional Infomation on Inservice Inspection Programs Relief Request, Units 1 and 2, June 11, 1982.
Do not have copies of these in our files.
Science Applications,Inc.
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