ML20023A489

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Inservice Insp Program, Technical Evaluation Rept
ML20023A489
Person / Time
Site: Turkey Point, 05000000
Issue date: 09/10/1982
From:
SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:
NRC
Shared Package
ML17345B073 List:
References
CON-NRC-03-82-096, CON-NRC-3-82-96 SAI-186-028-18, SAI-186-28-18, NUDOCS 8209150251
Download: ML20023A489 (35)
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{{#Wiki_filter:. SAZ Report Np. 136-023-18 1 fi i 1 i 4ECHNICAL EVALUATION REPORT TURKEY POINT NUCLEAR GENERATING STATION UNITS 3 AND 4-4 INSERVICE INSPECTION PROGRAM t E t Submitted to: U.S. Nuclear Regulatory Commission Contract No. 03-82-096 .j i I -l Science Applications, Inc. McLean, Virginia 22102 4 September 10, 1982 4 .:j N i l XA Copy Has Been Sent to PDR Y A_l i, [, .can

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-r - CONTENTS 1 y .] !NTRODUCTION................. 4 J 1. CLASS 1 COMPONENTS........................ 4 A. Rea'ctor Vessel....................... j Relief Request 1, Class 1 and 2 Bolting, Categories 1. B-G-1, B-G-2 and C-D; Items Bl.8 through B1.10; B5.1 4 through B5.3; and C1.4, C2.4, C32.and C4.2....... a Relief Request 2, Interior Clad Surfaces of Reactor 2. 8 Vessels, Category B-I-1, Items B1 13 and Bl.14..... il 3. Relief Request 3, Pressure Retaining Welds in Control Rod Drive Housings, Category B-0, 10 J Item Bl.18....................... 12 B. Pressurizer Relief Request 2, Vessel Cladding, Category B-I-2, 'l 1. 12 Item B2.9 14 C. Heat Exchangers and Steam Generators............ Relief Request 4, Heat Exchangers, Integrafly 1. 14 Welded Supports, Category B-H, Item B3.7........ Relief Request 2, Steam Generator Vessel Cladding, 2. 16 Category B-I-2, Item B3.8 17 0. Piping Pressure Boundary.................. Relief Request 5,- Support Members for Piping and 17 1. Pumps, Category B-K-1, Items 84.9 and 85.4.. 19 E. Pump Pressure Boundary................... Relief Request 1, Class 1 Bo'lting, Category B-G-1, 1. 19 Items B5.1 through B5.3 j -i 2. Relief Request 5, Support Members for Pumps, 20 Category B-K-1, Item B5.4 j t .l F. Valve Pressure Boundary Relief Request 8, Valve Bodies, Category B-M-2, 1 1. 21 Item B6.7 24 II. CLASS 2 COMPONENTS....................... 24 A. Pressure Vessel s...................... Pressure Retaining Bolting, Vessels, Category C-D, 24 1. Item C1.4 Jl J Science Applications,Inc. -i-i

~~ e 1 24 'i B. Piping i j 1. Pressure Retaining Bolting, Piping, Category C-D, j Item'C2.4......... 24 C. Pumps........................... 24 1. Pressure Retaining Bolting, Pumps, Category C-D, Item C3.2 24 s. 25 D. Valves j. 1. Pressure Retaining Bolting, Valves, Category C-D, Item C4.2....................... 25 i III. CLASS 3 COMPONENTS (No relief requests) 26 IV. PRESSURE TESTS 3 A. General.......................... 26 .I i 1. Hold Time.........,............. 26 i I B. Class 1 System Pressure Tests (No relief requests) i C. Class 2 System Pressure Tests (No relief requests) D. Class 3 System Pressure Tests (No relief requests) V. GENERAL,........................... 28 A. Ultrasonic Examination Techniques............. 28 1. Ultrasonic Examination Recording Levels 28 for Piping Welds i B. Exempted Components (None) C. Other (None) 32 REFERENCES J l i 1 !l I 3 i 1 1 L .1 l l ~! i i [

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i TECHNICAL EVALUATION REPORT TURKEY POINT NUCLEAR GENERATING SiATION UNITS 3 AND 4 INSERVICE INSPECTION PROGRAM f INTRODUCTION ~ The revision to 10 CFR 50.55a, published in February 1976, required that 1 Inservice Inspection (ISI) Programs be updated to meet the requirements (to the i '3 extent practical) of the Edition and Addenda of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code

  • incorporated

[ o I in the Regulation by reference in paragraph (b). This updating of the programs was required to be done every 40 months to reflect the new requirements of the '1 later editions of Section XI. f As specified in the February 1976 revision, for plants with Operating f -I Licenses issued prior to March 1,1976, the regulations became effective after l September 1, 1976, at the start of the next regular 40-month. inspection period. l I she initial inservice examinations conducted during the first 40-month period

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.yere to comply with the requirements in editions of Section XI and addenda in l effect no more than six months prior to the date of start of facility comercial f 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 t examination or testing requirements to be evaluated. Relief from these require-ments could be granted, provided health and safety of the public were not endangered, giving due consideration to the burden placed on the licensee if ] j the requirements were imposed. This report provides evaluations of the various requests for relief by the' licensee, Florida Power and Light Company (FPL), of 4 the Turkey Point Nuclear Generati,on Station Units 3 and 4. It deals only with I inservice examinations of components and with system pressure tests. Inservice q "J tests of pumps and valves (IST programs) are being evaluated separately. ] q q Hereinafter referred to as Section XI or Code. 54 L A j _1 science Apphcation5.inc. H

I Th'e revision to 10 CFR 50.55a, effective November 1, 1979, modified the j time interval for updating ISI programs and incorporated by reference a later l edition and addenda of Section XI. The updating intervals were extended from l 40 months to 120 months to be consistent with intervals as defin'ed in Section XI. .} For plants with Operating Licenses issued prior to March 1,1976, the 'j provisions of the November 1,1979, revision are effective after September 1, i 1976, at the start of the next one-third of the 120-month interval. During d the one-third of an interval and throughout the remainder of the interval, in-service 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 Turkey Point Unit 3, the ISI program and relief requests evaluated in this report cover the last 40 months i of the current 120-month inspection interval, i.e., from August-14, 1979, to December 14, 1982. For Unit 4, they cover the last 80 months of the current 120-month inspection interval, i.e., from January 7, 1977, to September 7, 1983. i These crocrams were based upon the 1974 Edition of Section XI of the ASME Boiler and Pressure Vessel Code with Addenda through the Summer of-1975. Tne November 1979 revision of the Regulation also provides that ISI grograms may meet the requirements of subsequent Code editions and addenda, incorporated by reference in paragraph (b) and subject to Nuclear Regulatory Commission (NRC) approval. Portions of such editions or addenda may be used, orovided 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 report. Finally, Section XI of the Code provides for certain components and [, systems to be exempted from its requirements. In some instances, these d exemptions are not acceptable to NRC or are only acceptable with restrictions. l1 As appropriate, these instances are also discussed in this report. I j '1 References (1) to (18) listed at the end of t'his report pertain to L previous transmittals on ISI between the licensee and the Commission. By 3 l letter of April 26,1976,(1) the Comission provided general ISI guidance for l

j both units.

In response to that guidance the licensee rovided schedule in-formation on submittah or both units on June 2,1976.(2 On August 24, 1976,( ) R the licensee amended that schedule for Unit 4. On November 22,1976,(#I the NRC issued further guic nce on ISI submittals. In response to that guidance, FPL li .'f s a I science ApphCations,Inc. l;i L

submitted its program for inservice inspection for Unit 4 as well as proposed 25,1977.(5) FPL further chonges in Technical Specifications on February S requested an exemption from that program on April 28,1977,(6) for a period i ending six months subsequent to NRC approval. That exemption was denied on -1 d May25,1977,(7) and implementation was required. NRC asked for additional f information on September 7,1977.(0) FPL supplied some responses on December 9, f 1977.I9) On April 10,1978,(10) tne licensee submitted revised changes to the l Technical Specifications. A relief request was submitted on November 15, 1978.(11) On March 6,1979,(12) FPL requested a delay in the development of tne Turkey Point 3 ISI program and submitted further proposed Technical Speci-5 fication changes, The request for delay was denied by letter of May 16,1979.(13) 18,1979.(14) In Tne program (including relief requests) was submitted September response to an inquiry by the Commission on April 14,1980,(15) the licensee sub- -itted additional information on this (Unit 3) program on October 15,1980.(16) Tne Comission requested additional information on both programs on March 16, i 1932,(1I) which was submitted by the licensee on June 14, 1982.I M i Frcm these submitta'ls, a total of 9 requests

  • for relief from Code These requests recairements or for updating to a later code were identified.

are evaluated in the following sections of this report. In addition FPL I withdrew two earlier relief requests: (1) No. 6 on Visual Examination of Pump Casings because a mechanized examination system was used successfully on the pump internals duri~ng the steam generator replacement outage. (2) No. 7 on Volumetric Examination of Pump Casing Welds because radiographic examination of the pump welds was conducted success-fully using the MINAC Inspection System device during the steam d generator replacement outage. 'l I .I .1 ,1

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  • The licensee has indicated that a revised ISI program for Turkey Point 4 J

mitted about September 10, 1982. In response tp1phyormiission will be(s whether the relief requests for Turkey Point 3 have ap-inquiry 1 plicability to Turkey Point 4, FPL would propose to request the same relief from the Code as' proposed in Turkey Point 3, except for the relief requests This report is based that have been withdrawn for aforementioned reasons. ) 1 on that premise. J 4q-science Aconcations.inc. -

I. CLASS 1 COMPONENTS A. Reactor Vessel 1. Relief Request 1, Class 1 and 2 Bolting, Categories B-G-1, B-G-2 and C-D; Items Bl.8 through Bl.10; B5.1_throuch B5.3; 'lj and C1.4, C2.4, C3.2 and C4.2 L,j j Code Recuirement f Category B-G-1: Pressure Retaining Bolting, 2 Inches and Larger in Diameter i i The areas shall include bolts, studs, nuts, bushings, i washers, and threads in base material and flange ligaments i between threaded stud holes. p i The examination performed during each inspection interval } shall cover 100% of the bolts, studs, nuts, bushings, and threads in base material and flange ligaments between threaded stud holes. ] l Bushings, threads, and ligaments in base material of flanges are required to b~e examined only when the connection is disassembled. Bolting may be examined either in-place under tension when the connection is disassembled, or when the bolting is removed. Examination Item No.* Components and Parts to be Examined Method B1.8 Reactor Vessel Closure Studs and Surface and Nu,ts when Removed Volumetric i Bl.9 Reactor Vessel Ligaments Between Vol umetric 3 .i Threaded Stud Holes Bl.10 Reactor Vessel Closure Washers, Visual ' Bushings B5.1 Pump Pressure Retaining Bolting, Volumetric In-Place 7 B5.2 Pump Pressure Retaining Bolting, Volumetric i j When Removed and Surface ( B5.3 Pump Pressure Retaining Bolting Visual '] 4

  • Other item numbers in this category (not listed) are not applicable to Turkey Point 3 and 4 P

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9 ^ Category B-G-2: Pressure Retaining Bolting, Smaller than 2-Inches in Diameter The areas shall include bolts, studs, and nuts. The visual examinations performed during each i'nspection .i interval shall cover 100% of the bolts, studs, and nuts. Bolting may be examined either in place under tension when the connection is disassembled, or when the bolting is removed. Category C-D: Pressure Retaining Bolting Exceeding 1-Inch in D,iameter j The areas shall include bolts, studs, nuts, bushings, washers, I and threads in base material and flange ligaments between threaded stud holes. Visual examinations perfomed during each inspection interval shall cover 100% of the bolts, studs, nuts, bushings, and threads in base material and flange ligaments between 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 disassembled. Bolting may be examined either in place under tension,when the connection is disassembled, or when the bolting is removed. ~ Examination item No. Comoonents and Parts to be Examined Method i C1.4 Pressure Vessel Pressure Retaining Visual and Bolting either Surface or Volumetric C2.4 Piping Pressure Retaining Bolting Visual and j i either Surface t H. or Volumetric t.j C3.2 Pumps Pressure Retaining Bolting Visual and t' either Surface L or Volumetric (- C4.2 Valves Pressure Retaining Bolting Visual and L either Surface L or Volumetric l L[j Ef s /)

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tj ' j Code Relief Recuest The licensee requests permission to update to examination category definitions B-G-1, B-G-2 and C-D as provided in the later editions and addenda of Section XI. In later editions of the Code, Class 1 bolting. exactly 2-in. in diameter.is shifted from Category B-G-1 to B-G-2 by revision of the Category defini-tion. Similarly Class 2 bolting between 1-and 2-in diameter j is' eliminated from Category C-D of the later editions of the Code. Procosed Alternative Examination None. 4 Licensee's Basis for Recuestino Relief j These portions of the later Code are adopted pursuant to paragraph (g) of 10 CFR 50.55a as revised in the proposed rule published in the Federal Register, Vol. 44 No.13 on January 18, 1979. This rule change approves for use the later. edition and addenda of the Code. Paragraph (g)(4)(iv)'of the rule change allows the adoption of portions of later approved editions and addenda to the Code, provided that all related requirements of the respective editions and addenda are met. It is felt that ,j the above stated adoptions are in compliance.with the proposed i change in the regulations. 1 1 1 Evaluation The 1977 Edition, Summer 1978 Addenda, of Section XI has 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 recent edition (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) A'ny requirement of the more recent edition which is i related to the one(s) under consideration must also qi be met. The requirements for examining Class 2 bolting 2-in. in diameter aid less are deleted from the 1977 Edition, addenda through Summer 1978, but volumetric examination is substituted for visual examination of bolts and studs of larger diameters. Class 1 bolting exactly 2-in in diameter is shifted from Category B-G-1 to Category B-G-2. This shift substitutes visual for volumetric (and in some cases, surface) examinations in most instances, as shown in the above Code requirement. H 4 Al 1 m - science Apphcations,Inc.

1 Recommendations Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted for the licensee's request to update to the requirements of the 1977 Edition, Sumer 1978 Addenda, for Category B-G-1 and B-G-2, and C-D items. This approval would delete.the requirement to examine Class 2 bolting ~1 to 2 in. in diameter and would shift Class 1 bolting of exactly 2 in, diameter from Category B-G-1 to B-G-2. References i Reference 14. 'l 1 1 I s- ',3 Y 4 y AI - s'cience Acphcatiens. Inc. rs

i .i. ~ Relief Request 2, Interior Clad Surfaces of Reactor Vessels, 2. Cateoory B-I-1, Items Bl.13 and Bl.14 i Code Recuirement The examinations performed during each inspection interval shall cover 100% of the patch areas. The areas shall include at least six patches (each 36 sq. in.) evenly distributed in the closure head, and six patches (each 36 sq. in.) evenly distributed in accessiole sections of vessel shell. The examination shall be (1) visual.and surface or (2) volumetric for the closure head cladding, and visual for the vessel cladding. Code Relief Recuest Relief is requested from making the cladding examination. Procosed Alternative Examination ilone. Licensee's Basis for Reauesting Relief Analysis has shown that flaws which may initiate in the reactor vessel cladding, at locations other than nozzles, are not likely to propagate through the clad-base metal interface. Because of these data, the need to confirm the initiation of clad fissures is not considered relevant. Detection of flaws in the r.ozzle area'is covered by the requirement to volumetric-ally examine the nozzle to vessel welds and nozzle inside radiused This examination will detect the presence of flaws section. which may have propagated through the cladding into the base Accordingly, the ASME has completely eliminated the material. B-I-1 and B-I-2 examination categories from later editions of Section XI. Performing these cladding examinations constitutes needless l radiation exposure to personnel with no compensatory increase in The licensee, therefore, will net perform the above j safety. The ] l mentioned examinations in the remaining inspection period. examinations will not be required for subsequent intervals since si the requirements have been deleted from the Code. i Evaluation The 1977 Edition, Summer 1978 Addenda, of Section XI has 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: Al 3 science ApphcabonsJnt ), -~

i - (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 Editio', all of the addenda n through Summer 1978 Addenda must be used; ) (c) Any requirement of the more recent edition which is j related to the one(s) under consideration must also be met. The requirements for examining closure head cladding and vessel cladding are deleted from the 1977 Edition through Summer 1978 Addenda. 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 requirements of the 1977 Edition, Summer 1978 Addenda, for Category B-I-1 items. This approval would delete the require-ment to examine these items. References Reference 14. I t e w F d 4 )l-1l JF t Science ApphCations,Inc. Il..._.-.

'3. Relief Recuest 3, Pressure Retaining Wolds in Control Rod i ~i Drive Housings, Category B-0, Item Bl.18 1 Code Recuirement 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 examina-A tions may be performed at or near the end of the inspection interval. Code Relief Recuest Relief is requested from the volumetric examination of the peripheral CRD housing welds. Procosed Alternative Examination Surface examination of the pressure retaining welds in the CRD housings, as provided for in the 1977 Edition, Summer 1978 Addenda, of Section XI. ~ Licensee's Basis for Reouesting Relief paragraph (portions of the late'r Code are adopted pursuant tog) of 1 (1) These l' published in the Federal Register, Vol. 44-No. 13 on January 18, 1979. This rule change approves later Edition and Addenda of the Code. Paragraph (g)(4)(iv) of the rule change allows the adoption of. portions of later approved editions and addenda to the Code, provided that all related requirements of the respec-i tive editions and addenda are met. It is felt that the above stated adoptions are in compliance with the proposed change in the regulations. (2) Volumetric examinations of these welds are impractical due to design configuration, accessibility and materials of construc-tion. (a) Ultrasonic examination will not provide meaningful results due to the geometric configuration of the joint, the internal configuration (thermal sleeve pressed in the CRD tube) and material properties (Inconel-to-stainless steel welds). i (b) Radiographic examination cannot be performed without removing the control rod from the housing. The radio-graphic examination results will not be conclusive due to the interference of the thermal sleeve. 4 (3) The licensee believes that the later Edition and Addenda of Section XI provides more assurance to the overall structural integrity of the canponents. sr A science Aponcanons.inc. . n

I Evaluation

  • l The 1977 Edition, Summer 1978 Addenda, of Section XI has

'i 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) Comission approval is required to update to the more recentedition(pursuantto10CFR50.55a(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 j related to the one(s) under consideration must also be met. + Pressure retaining welds in CRD housings are Item B14.20, Category B-0 in the Sumer 1978 Addenda (Table IWB-2500-1). Examination requirements are given in Figure IWB-2500-18, and surface examination is one of the acceptable methods. Extent and frequency of examination remain unchanged from the 1974 Edition, Summer 1975 Addenda. - a Conclusions and Recommendations l Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to the licensee's request to update to the require-ments of the 1977 Edition, Summer 1978 Addenda, for Category B-0, 514.20 items. This approval would pemit the licensee to substitute surface for volumetric examination for pressure retaining welds in Control Rod Drive Housings. References Reference 14 i s l i I A science Applications. Inc. 4 ~ ** voy-w a e, wm e r

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m B. Pressurizer .l 1. Relief Request 2, Vessel Cladding, Category B-I-2,' Item B2.9 i

i Code Requirement The areas shall include at least one patch (36 sq. in.)

near each manway in the primary side of the vessel. The visual examinations perfomed during each inspection interval shall .j cover 100% of the patch areas. These examinations may be -l perfomed at or near the end of the inspection interval.

j Code Relief Recuest Relief is requested from making the cladding examination.

Procosed Alternative Examination j None. Licensee's Basis for Recuesting Relief Analysis has shown that flaws which may initiate in the reactor vessel cladding, at locations other than nozzles, are not likely to propagate through the clad-base metal interface. Because of these data, the need to confim the initiation of clad fissures is not considered relevant. Detection of flaws in the nozzle area is covered by the requirement to volumetric-ally examine the nozzle to vessel welds and nozzle inside radiused section. This examination will detect the presence of flaws whi-ch may.have propagated through the cladding into the base material. Accordingly, the ASME has completely elimi-

j nated the B-I-1 and B-I-2 examination categories from later editions of Section XI.

Perfoming these cladding examinations constitutes needless radiation exposure to personnel with no compensatory increase in safety. The licensee, therefore, will not perform the above I mentioned examinations in the remaining inspection period. The examinations will not be required for subsequent intervals since the requirements have been deleted from the Code. Evaluation .j .j The 1977 Edition of Section XI, Sumer 1978 Addenda, has ~ 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) Comission approval is required to update to the more recent edition (pursuant to 10 CFR 50.55a(g)(4)(iv)); ii b 4 ' science Appncations.ine.

(b) When applying the 1977 Edition, all of the addenda through Summer 1978 Addenda must be used; l j (c) Any requirement of the more recent edition which is related to the one(s) under consideration must also j4 be met. The raquirements for examining vessel cladding are deleted from the 1977 Edition, through Summer 1978 Addenda. l Conclusions and Recmanendations i 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-J ments of the 1977 Edition, Summer 1978 Addenda for Category B-I-2 items. This approval would delete the requirement to examine these items. References Reference 14. i j 1 i i

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n C. Heat Exchangers and Steam Generators 1. Relief Recuest 4, Heat Exchangers, Integrally Welded Supports, f Category B-H, Item B3.7 i t Code Reauirement Volumetric examination of 10% of the circumference of the weld (or 100% of the weld lug attachment) to the vessel shall be t perfonned during each inspection interval. ' Code Relief Reauest Relief is requested from making a volumetric (ultrasonic) examination of the weld (s). Proposed Alternative Examination Surface examination of the integrally welded vessel supports, as provided in the later Edition and Addenda of Section XI, shall be performed. Licensee's Basis for Recuesting Relief (1) These portions of the later Code are adopted pursuant to paragraph (g) of 10 CFR 50.55a as revised in the proposed rule published in the Federal Register, Vol. 44-No.13 on January 18, 1979. This rule change approves later edition and addenda of the Code. Paragraph (g)(4)(iv) of the rule change allows tne adop-tion of portions of later approved editions and addenda to the Code, provided that all related requirements of the respective editions and addenda are met. It is felt that the above stated adoptions are in compliance with the proposed change in the regulations. l (2). Volumetric examinatio6s on numerous integrally welded supports are found to be impractical. Because of their design .and configuration, these welds are not generally conducive to meaningful nor conclusive ultrasonic or radiographic examina-tions. (3) Performing examinations to these items which are not con-ducive to volumetric examinations, under adverse conditions of dose rates as high as 15 R/hr, provides no additional information i as to the component's structural integrity. i (4) The licensee believes that the later Edition and Addenda of j l Section XI provide more assurance to the overali structural integ-rity of the components. 1 a 6 e -14. Science Ap0hcations,Inc.

A -l Eealuation ) The 1977 Edition, Sumer 1978 Addenda, of Section XI has been referenced in 10 CFR 50.55a and inservice examinations may meet the requirements of this edition in lieu of those from pr'evious editions with the following provisions: l (a) Comission approval is required to update to the more j recent edition (pursuant to 10 CFR 50.55a(g)(4)(iv)); i (b) When applying the 1977 Edition, all of the addenda 1 j through Summer 1978 Addenda must be used; i. (c) Any requirement of the more recent edition which is related to the'one(s) under consideration must also j s j : :, be met. 1 !! Integrally welded attachments for heat exchangers are Item B8.40, Category B-H in the Sunner 1978 Addenda (Table IWB-2500-1) of the 1977 Edition. Examination requirements are given in Figures IWB-2500-13, -14, and -15, depending on } geometry of the weld. In all instances, surface examination 'i is an acceptable method. During the first inspection interval, 100% of the length of the weld in one heat exchanger support shall be examined. Also included in this examination is 100% of the welding of each lug on the vessel. ' i. Conclusions and Recommendations Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be I, granted to the licensee's request to update to the requirements of the 1977 Edition, Sumer 1978 Addenda, for Category B-H, lll: ) Item B8.40 items. This approval would pennit the licensee l to substitut.e su.rface for volumetric examination for integrally i .t welded attachments on heat exchangers. References + 'll Reference 14 I 1

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l. i l 2. Relief Request 2, Steam Generator Vessel Cladding, Catego'y r s. B-I-2, Item B3.8 J Except for item number, this Code relief request is identical to the one for pressurizer cladding in I.B.1 of l this report. Therefore, the following is recommended: Relief from Code requirements should not be granted. Instead,pursuantto10CFR50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1977 Edition, Summer 1978 Addenda, for Category B-I-2 items. This approval would delete the requirement to examine these items. 4 j i } E 9 AI '. science Apphcahons,Inc. l...__..._ ~

l 1r D. Piping Pressure Boundary Relief Request 5, Succort Members for Piping and Pumos, 1 1. i j Category B-K-1, Items B4.9 and B5.4 h s[l j Code Requirement Volumetric examination during each inspection interval l shall cover 25% of the integrally welded supports. .l t i Code ~ Relief Recuest Relief is requested from the volumetric examination. } Proposed Alternative Examination Surface examination stiall be perfonned on 100% of the integrally welded external supports whose support base material i design thickness is 5/8 in, and greater, as provided in the later edition of Section XI. Licensee's Basis for Recuesting Relief (1) These portions of the later Code are adopted pursuant to paragraph (g) of 10 CFR 50.55a as revised in'the proposed rule published in the Federal Register, Vol. 44 - No. 13 on January 18, l'979. This rule change approves later edition and Paragraph (g)(4)(iv) of the rule change addenda of the Code. allows the adoption of portions of later approved editions and addenda to the Code, provided that all related requirements of It is felt that the respective editions and addenda are met. the above stated idoptions are in ccnpliance with the proposed change in the regulations. (2) Volumetric examinations on numerous integrally welded i Because of the design and supports are found to be impractical. configuration, these welds are not generally conducive to mean-ingful nor conclusive ultrasonic or radiographic examinations. (3) The licensee believes that the later edition and i addenda of Section XI provide more assurance to the overall I i structural integrity of the canponents. I Evaluation The 1977 Edition, Summer 1978 Addenda, of Section XI has been referenced in 10 CFR 50.55a and inservice examinations may meet the requirements of this edition in lieu of those from j previous editions with the following provisions: (a) Comission approval is required to update to the more i i recent edition (pursuant to 10 CFR 50.55a(g)(4)(iv)); d

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(b) When applying the 1977 Edition, all of' the addenda through Summer 1976 Addenda must be used; 1 4 (c) Any requirement of the more recent edition which is -j related to the'one(s) under consideration must also be met. i Integrally welded attachments for piping and pumps are Items B10.10 and B10.20, respectively, in Category B-K-1 in . I the Summer 1978 Addenda (Table IWB-2500-1). Examination requirements are given in Figures IW5-2500-13, -14 and -15, depending on geometry of the weld. In all instances, surface j exanination is an acceptable metaod. Examination includes only those attachments whose base material design thickness is 5/8 in. (16 mm) and' greater, and which are of piping required l to be examined in Category B-J or of associated punps integral to such piping. Essentially 100% of weld length is included. i Conclusions and Recommendations i l Pursuant to 10 CFR 50.55a(g)(4)(iv),~ approval should be granted to the licensee's request to update to the requirements of the 1977 Edition, Summer 1978 Addenda for Category B-K-1 This approval would permit the licensee to substitute i tems. surface for volumetric examination for support members for i piping and pumps. References Reference 14. 1 ' l I I .1 i ll - Science Applicabons,Inc. I

i I E. Pump Pressure Boundary 1. Relief Recuest 1, Class 1 Bolting, Category B-G-1, Items 85.1 I i through B5.3 l The request to update examination category definitions B-G-1, B-G-2 and C-D to the 1977 Edition, Summer 1978 Addenda (see I.A.1 of this report) applies here. Therefore, the following is recomended: Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be j granted for the licensee's request to update to the require-ments of the 1977 Edition, Summer 1978 Addenda, for Category l B-G-1 items. This approval would shift Class 1 bolting of exactly 2 in diameter from Category B-G-1 to B-G-2. I i i i - i 1 s b 1 ' i i / 2 - science ApplicatlOns. Inc. .,... ~.. . +,,..

I 2. Relief Recuest 5, Support Members for Pumos, Category B-K-1, l 4 Item B5.4 .I The request for relief from volumetric examina' tion of i integrally welded external support attachments for piping and pumps (see 1.D.1 of this report) applies here. Therefore, the following is recomended: Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be I, granted to the licensee's request to update to the requirements _i of the 1977 Edition, Sumer 1978 Addenda,for Category B-K-1 i tems '. This approval would pemit the licensee to substitute surface for volumetric ' examination for support members. ij o O 'I j -4 L k ap l. i li 11 i /! Al science Aconcanons.ine. lf t-i-

i F. Valve Pressure Boundary 1. Relief Request 8, Valve Bodies, Category B-M-2, Item 86.7 l Code Recuirement f Visual inspection of the internal pressure boundary 3 d surfaces, on valves exceeding 4 in, naninal pipe size. j One valve in each. group of valves of the same construc-tional design, e.g., globe, gate, or check valve, manufacturing method and manufacturer that performs similar functions in the i system shall be examined during each inspection interval. j Tne examinations may be performed at or near the end 9 of the inspection interval. ~j 1 l Code Relief Request l Relief is requested from a visual examination of the required valve (s) internal surfaces at a specified time during the inspection interval. Procosed Alternative Examination An examination of the internal pressure boundary surfaces will be performed to the extent practical, each time a valve is disassembled for maintenance purposes, i i Licensee's Basis for Reauesting Relief ~ (1) Tne requirement to disassemble primary system valves for the sole purpose of performing a visual examination of the internal' pressure boundary surfaces has cnly a very small poten-tial of increasing plant safety margins and a very dispropor-tionate impact on expenditures of plant manpower and radiation exposure. I (2) Performing these visual examinations under such adverse conditions of dose rates as high as 10 R/hr and as-cast surface conditions, provides little additional information as to the valve's internal surface integrity. i (3) The performance of both carbon and stainless cast valve bodies has been excellent in all PWR applications. Based on this experience and both industry and regulatory acceptance of these alloys, continued excellent service performance is anticipated. y i (4) The licensee believes a more practical approach would ll be to examine the internal pressure boundary of only those valves fj ii u AI Science AppleCations,Inc _21

r that require disassembly for maintenance purposes. This would essentially provide an equivalent sampling of primary system valves, reduce radiation exposure to plant personnel, 1; and give adequate assurance that the integrity of these 'l components is being maintained. Evaluation i, The disassembly of large valves to the degree necessary to inspect the internal pressure retaining surfaces (casing) is a majcr effort, involving large personnel exposures. To do this disassembly solely to perform a visual exa.mination of the internal casing is impractical. s The licensee has committed to the concept of visual exami-nation if the valve is disassembled for maintenance. The visual examination specified is to determine 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 b6 in' compliance 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 rel evant 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 inspec' tion 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 performed when the system pressure tests (IWA-5000) are conducted in accordance with the requirements for Category B-P. i Conclusions and Recommendations Based on the above evaluation, it is concluded that for the valves discussed above, there is not presently enough justification for granting relief from the impractical Code requirements. Therefore, the following is recommended: l W j J l Science Appbcations. Inc.

r, 1. (a') Relief should not be granted at this time from visual l examination of the internal pressure boundary surfaces on valves exceeding 4 in, nominal pipe size. (b) The licensee's proposal to perform the Code-required examinations whenever the valves are opened because of 4 ]' I maintenance should be accepted. (c) During other inspection periods, the licensee should perform visual examinations for leakage when the system pressure tests (IWA-5000) are conducted in accordance with the requirements for Category B-P. (d) The licensee should submit specific rel'ief 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 Reference 14. ] I ,I j 4 t 54 'I

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II. CLASS 2, COMP 0NENTS A. Pressure Vessels l [ 1. Pressure Retaining Bolting, Vessels, Category C-D, Item C1.4 1 i' The request to update to the 1977 Edition, Summer 1978-Addenda (see I.A.1 of this report) applies here. Therefore, the following is recomended: } Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be l granted for the licensee's request to update to the require-oi ments of the 1977 Edition, Sumer 1978 Addenda for Category C-D il items. This approval would delete the requirement to examine pressure retaining bolting (1 to 2-in. diameter) for Class 2 4 pressure vessels. B. Piping 4 1. Pressure Retaining Bolting, Piping, Category C-D, Item C2.4 il The request to update to the 1977 Edition, Sumer 1978 Addenda (see I.A.1 of this report) applies here. Therefore, the following is recommended: Pursuant to 10 CFR 50.55a(g)(4)(iv), a~ppro' val should be l granted for the licensee's proposal to update to the require-l ments of the 1977 Edition, Summer 1978 Addenda for Category C-D l l items. This approval would delete the requirement to examine I pressure retaining bolting (1 to 2-in. diameter) for Class 2 i j piping. C. Pumps 1. Pressure Retaining Bolting, Pumos, Category C-D, Item C3.2 The request to update to the 1977 Edition, Summer 1978 Addenda (see I.A.1 of this report) applies here. Therefore, the following is recomended: Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted for the licensee's proposal to update to the require-ments of the 1977 Edition, Sumer 1978 Addenda for Category C-D items. This approval would delete the requirement to examine pressure retaining bolting (1 to 2-in. diameter) for Class 2 4 pumps. i 4 i i H! t b ) J l m science Applications. Inc.,, Ii [

r D. Val.ves 1. Pressure Retaining Bolting, Valves, Category C-0, Item C4.2 The request to update to the 1977 Edition, Sumer 1978 Addenda (see I.A.1 of this report) applies here. Therefore, 3 the following is reca= ended: Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted for the licensee's proposal to update to the require-i I ments of the 1977 Edition, Summer 1978 Addenda, for Category C-D items. This approval would delete the requirement to examine pressure retaining bolting (1 to 2-in, diameter) for Class 2 valves. i i I l l t t -4 i f Jl J . l

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I !!!. CLASS 3 COMP 0NENTS j No relief requests. 1 I TV. PRESSURE TESTS s l A. General 1. Hold Time li Code Requirement i i IWA-5210(a): The pressure retaining components shall be visually examined while the system is under the hydrostatic i i test pressure and temperature. The test pressure and tempera-ture shall be maintained for at least four hours prior to the performance of the examinations. a I i l Code Relief Recuest l l Relief is requested from the Code requirement to hold test pressure for four hours prior to visual examination of non-i insulated systems and components. Proposed Alternative Examination The duration of hydrostatic test holding time prior to examination for all non-insulated Safety Class 1, 2 and 3 i i Systems will be 10 minutes. Licensee's Basis for Recuesting Relief f iione given. l i i Evaluation j The1977 Edition, Summer 1978dddenda,ofSectionXIhas j been referenced in 10 CFR 50.55a and inservice examinations may i 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 l l! 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; ll (c) Any requirement of the more recent edition which is lj related to the one(s) under consideration must also be met, lj li i: / 4 science ApphcaDons,Inc

.n ii the licensee should update to the 197.7 Code, Summer 1978 Addenda, in which 1WA-5213 would allow a 10-minute hold time l cl for non-insulated piping / components during pressure tests. IWA-5213 refers to types of tests and to pressure and tempera-l ture conditions that are defined in other paragraph.s of Subsub-article IWA-5210. The entire subsubarticle needs to be adopted i to comply with requirements of (c) above. -i / Recomendations Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update frcra the requirements of Paragraph IWA-5210 of the 1974 Edition,' Summer 1975 Addenda, to the requirements of Subsubarticle IWA-5210 in the 1977 Edition, Summer 1978 Addenda. This approval would permit the licensee to use a 10-minute hold time for non-insulated piping / components during pressure tests. References Reference 14 l B. Class 1 System Pressure Tests No relief requests. C. Class 2 System Pressure Tests No relief requests. D. Class 3 System Pressure Tests No relief requests. i -{ i

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~ V. GEtiERAL A. Ultrasonic Examination Techniques Ultrasonic Examination Recording Levels for Pioing Welds l I 1. t Code Requirements ASME Code Section XI, 1974 Edition, Summer 1975 Addenda, " Ultrasonic exami-Paragraph IWA-2232, Ultrasonic Examination: nation shall be conducted in accordance with the provisions of l Where Appendix I (I-200) is not applicable, the Appendix I. 1 provisions of Article 5 of Section V shall apply." ASME Code Section V', 1974 Edition, Summer 1975 Addenda, "All indications Paragraph T-537, Evaluation of Indications: which croduce a response greater than 20% of the reference l level shall be investigated to the extent that the operator can evaluate the shape, identity, and location of all such i reflectors in tems of the acceptance-rejection standards of j the referencing Code section." t ];.- b Code Relief Recuest For piping welds, relief is requested from the requireme it i that ultrasonic examinations be conducted in accordance with the provisions of Appendix I and Article 5 of Section V as required by Paragraph IWA-2232. .i Proposed Alternative Examination .l As an alternative to using Article 5 of Section V, the } following evaluation criteria will be used for ultrasonic examination of piping systems: } .i (1) Indications 50% of DAC or greater shall be recorded. l-(2) Any indication 100% of DAC or greater shall be invesi-gated by a Level II or Level III examiner to the extent necessary l to detemine the shape, identity, and location of the reflector. f. (3) Any non-geometric indication, regardless of DAC, dis-covered during the Ultrasonic (UT) examination of piping welds and base metal materials shall be recorded and investigated by ~j a Level II or Level III examiner to the extent necessary to determine the shape, identity, and location of the. reflector. ( 'i I (4) The owner shall evaluate and take corrective acticn for the disposition of any indication investigated and found to be other than geometric in nature. l

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I 'l Licensee's Basis for Requesting Relief I Recording and evaluating indications at 20% DAC is impractical for the following reasons: (1) The welded joints in nuclear piping frequently contain Code-allowable wall thickness differences (12% of nominal thick-ness) as well as some weld drop-through, counterbore taper, crown height, etc. These conditions generate an extremely large number of geometric reflectors which produce UT indications greater { than 20% DAC. (2)' Weld metal in stainless steel piping contains reflec-l tors due to the metallurgical structure which produce a large number of UT indica'. ions. i L d (3) Although stress corrosion cracking in stainless steel l' has been found to exist in low-level amplitudes, experience has ,Il shown that the typical mode of failure in this type of cracking 'i is not in the weld metal per se, but in the heat affected zone (HAZ) and base metal of the pipe. An experienced UT operator can discriminate stress corrosion cracks from geometric and i metallurgi. cal reflectors. Thus, it is not necessary to record and evaluate all reflectors as Section V requires, but only those l, which are real flaws. It should also be noted that the recording of real flaws is done regardless of Code evaluation criteria (in-i sofar as percentage of DAC is concerned) as part of good l i examination practice. I (4) All examination personnel experience radiation exposure l during inservice examinations. The Section V requirement to record and evaluate UT indications at the 20% DAC places an un-necessary burden on the limited number of experienced and qualified examiners available to the licensee. The primary reference evaluation (100% DAC) of indicaticns j establishes an adequate level of information for the following reasons: l (1) Historically, Section XI establishes the 20% DAC evalu-ation criteria by referencing other Sections of the ASME Code, j For example, Paragrapt U 213.2 of the 1970 Code and the 1971 Code -] references Appendix '.X J Section III. Also, as quoted above 4 in part II of t W t e *. ment, Paragraph IWA-2232 of the 1974 Code reference" / t # i of Section V. Until 1976, when 10 CFR 50.55a(g) tv. alt e nservice inspection programs to be up-graded to the 13/4 Edition of Section XI, most of these programs had been 7nducted in accordance with Paragraph IS-213.2 of the Summer 1w/1 Addenda to Section XI. These programs invoked the 100% DAC evaluation criteria and took exception to the 20% DAC i O <j evaluation criteria of Appendix IX of Section III. Such programs

1 were very successful and provided a ccnprehensive safety level for the ccrnponents examined.

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^ w (2) The Summer 1973 Addenda and the Winter 1975 Addenda, with the introduction of Appendix 1 for vessel UT examination and Appendix III for piping UT examination, confimed the ASME j Section XI Committee position on 50% DAC recording and 100% DAC evaluation of UT indications. In addition, the 100% DAC evalu-j] ation criteria for indications found during UT examination of ,i piping welds was reconfirmed by the 1977 Edition of Section XI (Paragraphs IWA-2232(b)(1) and III-4500(1)). l fj Evaluation l The licensee has advanced a number of valid reasons why I recording and evaluating indications at 20% of the reference l level is impractical and why t.he proposed alternative estab-lishes an adequate level of infomation. The 1977 Edition, Summer 1978 Addenda, of Section XI has been referenced in 10 CFR 50.55a and inservice examinations may meet the requirements of this edition in lieu of those from ]i previous editions with the following provisions: -{ (a) Comission approval is required to update to the more recent edition (pursuant to 10 CFR 50.55a(g)(4)(iv)); "l (b) When applying the 1977 Edition, all of the addenda through Summer 1978 Addenda must bd ussd; (c) Any requirement of the more recent edition which is related to the one(s) under consideration must also be met. j j Appendix III was incorporated into Paragraph IWA-2232 of 1 the 1977 Edition through Summer 1978 Addenda of Section XI. To meet the requirements of (c) above, the entire Paragraph i IWA-2232 in the Summer 1978 Addenda should be adopted by the j licensee. This paragraph includes the following: i (1) For examination of w ids, reflectors that produce a 3] response greater than 50% of the reference level shall be recorded. (IWA-2232(c)(1)) 4 A (2) For examination of welds, all reflectors which produce a response greater than 100% of the reference level shall be investigated to the extent that the operator can ~ detemine the shape, identity, and location of all such reflectors in tems of the acceptance-rejection standards of IWA-3100(b). (IWA-2232(c)(2)) (3) The size of reflectors shall be measured between points which give amplitudes equal to 100% of the reference level. (IWA-2232(c)(3)) In addition, indications of 20% of reference level or greater which are interpreted to be a crack must be identified and evalu-ated to the rules of Section XI. Al J Science Apphcations,Ind.._ _ _._ _,_. _ _.

The above is consistent with the recormiended position on a relief requests by other licensees and is essentially the same i as the licensee's proposal and as shown in his program. 4 '} Conclusions and Recor:rnendations 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 requirements of Paragraph IWA-2232 in the 1977 Edition, Summer 1978 Addenda, with the additional requirement that indications 20*.' of reference level or greater that are inter-i preted to be a crack'ust be identified and evaluated according m to the rules of Section XI. -l References j, References 11, 14 and 18. 1 i 4 B. Exempted Components None. I a C. Other a -q None. .I, .l 1 a t i l: J/ 21 science Aconcations.ine.

REFERENCES 1 1. G. Lear (NRC) to R. E. Uhrig (FPL), April 26, 1976. ~ 2. R. E. Uhrig (FPL) to G. Lear (NRC), L-76-210, June 2, 1976. 3. R. E. Uhrig (FPL) to G. Lear (NRC), L-76-306, August 24, 1976. 4. G. Lear (NRC) to R. E. Uhrig (FPL), November 22, 1976. 5. R. E. Uhrig (FPL) to V. Stello (NRC), L-77-58, February 25, 1977. 6. R. E. Uhrig (FPL) to V. Stello, Jr. (NRC), L-77-130, April 28, 1977 7. V. Stello (NRC) to R. E. Uhrig (FPL), May 25, 1977. 8. G. Lear (NRC) to R. E. Uhrig (FPL), September 7, 1977. R. E. Uhrig (FPL) to V. Stello (NRC), L-77-372, December 9,197'7 9. 10. R. E. Uhrig (FPL) to V. Stello (NRC), Turkey Point 4 Proposed Amendment l to DPR-41, L-78-123, April 10, 1978. i .t 11. R. E. Uhrig (FPL) to V. Stello (NRC), Ultrasonic Examinations of Piping l . c! f Welds, L-78-361, November 15, 1978. j . i 12. R. E. Uhrig (FPL) to V. Stello (NRC), L-79-52, March 6,1979. i 13. A. Schwencer (NRC) to,R. E. Uhrig (FPL), May 16, 1979.

4 14 R. E. Uhrig (FPL) to D. Eisenhut (NRC), Turkey Point Unit 3, Inservice 2

Insoection Program, L-79-261, September 18, 1979. 15. A. Schwencer (NRC) to R. E. Uhrig (FPL), April 14, 1980. 16. R. E. Uhrig (FPL) to D. G. Eisenhut (NRC), Turkey Point Unit 3, Inservice .I Inspection Program, L-80-341, October 15, 1980. ti 17. S. A. Varga (NRC) to R. E. Uhrig (FPL), March 16, 1982. 18. R. E. Uhrig (FPL) to S. A. Varga (NRC), Inservice Insoection Program L-82-245, June 14, 1982. Af i science AppHcations,Inc. 32-q

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