ML20028A681
| ML20028A681 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/04/1982 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20028A680 | List: |
| References | |
| NUDOCS 8211240233 | |
| Download: ML20028A681 (7) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO REQUESTS FOR RELIEF FROM INSERVICE INSPECTION REQUIREMENTS q
NORTHEAST NUCLEAR ENERGY COMPA'iY -
MILLSTONE NUCLEAR POWER STATION UNIT 2 g
DOCKET NO. 50_-336 T
INTRODUCTION Technical Specification 4.0.3 for the Millstone Unit 2 Nuclear Facility states that inservice exardination of ASME Code Class 1, 2, and 3 com-ponents shall be performed in,vrordarice with Section XI of the ASME Boiler and Pressure Vessel Cc
_ applicable Addenda as required by 10 CFR 50.55a(g) except where specific written relief has been granted by the Commission.
Ceytain requirements of.later editions and addenda s
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of Section XI are imdractical to perform on older plants because of the plants' design, comphnen[ geometry, and materials of constructon.
Thus,110TFR'50.55a(g)(6)(i)authorizesthe'Commissiontograntrelief
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from those requirements upon making.the necessary findings.
s By letters dated January 25 and January; 31 and June 25, 1979 May 1, 1981, and April 14, 1982, Northeast N = lear Energy Company submitted its inservice inspection program, revisions, cr additional information related to request i
for relief from certain Code requireine.7ts dete, dined to bk impractical to
' perform on the Millstone Nuclear Fower Station Unit 2 during the inspection
- interval. The program is based on the-the requirements of the 1974 Edition l
through Summer 1975 Addenda of ection XI of AiME ~ Code.'
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EVALUATION f
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Requests for relief from th'e requirements of Section XI which have been determined to be impractical to perform have been reviewed by the Staff's c'ontractor, Science Applications, Inc.
The contractor's evaluation of the licensee's requests for relief and his recommenda-tions are presented in the Technical Evaluation Report (TER) attached.
The staff has reviewed the TER and agrees with the evaluations and recom-mendations. A summary of the determinations made by the sta ff is presented in tables' I through 5.
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Conclusion Based on the review summarized, the staff concludes that relief granted from the examination requirements and a'iternate methods imposed through this document give reasonable assurance of the piping and component pres-sure boundary and support structural integrity, that granting relief where the Code requirements are impractical is authorized by law and will not endanger life or property, or the common defense and security, and is
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otherwise iri the public interest considering the burden that could result if they were imposed on the facility.
Attachments:
1.
Table 1 - Class 1 Components 2.
Table 2 - Class 2 Components 3.
Table 3 - Class 3 Components 4
Table 4 - Pressure Tests 5.
Table 5 - Ultrasonic Examination Technique Principal Contributor:
George Johnson
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. TABLE 1 CLASS 1 COMPONENTS LICENSEE 4
PROPOSED IWB-2600 IWB-2500 SYSTEM OR AREA TO BE REQUIRED ALTERNATIVE RELIEF REQUEST IIEM NO.
EXAM. CAT.
COMPONENT EXAMINED METHOD EXAM.
STATUS l
I Bl.13 B-I-1 Reactor Cladding Visual and Visual at Granted Vessel Surface or end of Closure Volumetric interval Head Bl.14 B-I-1 Reactor Cladding Visual Visual at Granted Vessel end of Shell interval 1
B2.9 B-I-2 Pressurizer Cladding Visual Visual at Relief not required; end of Code Requirements interval being met B3.8 B-I-2 Heat Cladding Visual Visual at Relief not required; Exchanger end of Code Requirements and interval being met Steam Generators 85.4 B-K-1 Pump Integrally-Volumetric Surface Granted Supports Welded j
Supports i
B5. 6 B-L-1 Pumps Casing Volumetric None Not Granted Welds B6.1 &
B-G-1 Valves Bolting Volumetric Require-Granted B6.2 (B6.1) ments for Volumetric B-G-2
& Surface (86.2)
- TABLE 2 CLASS 2 COMPONENTS i
I LICENSEE PROPOSED IWB-2600 IWB-2500 SYSTEM OR AREA TO BE REQUIRED ALTERNATIVE RELIEF REQUEST ITEM NO.
EXAM. CAT.
COMPONENT EXAMINED METHOD EXAM.
STATUS C1.2 C-B Shutdown Nozzle-Volumetric Ultrasonic Granted Heat To-Vessel (To extent Exchanger Weld practical) and surface C1.3 C-C Steam Snubber Surface None Not Granted Generators Lugs 2
C1.4 C-D Steam
- Bolting, Visual None Granted Generators Two-inch
& Shutdown Diameter Heat and Less Exchangers C2.4 C-D Main
- Bolting, Visual None Granted Steam Two-inch
& Safety Diameter Injection and less C3.2 C-D High & Low
- Bolting, Visual None Granted Pressure Two-inch Safety Diameter Injection and Less Pumps C4.2 C-D Valves
- Bolting, Visual None Granted Two-inch Diameter and Less
TABLE 3 CLASS 3 COMPONENTS LICEhSEE PROPOSED RELIEF IWB-2600 IWB-2500 SYSTEM OR AREA TO BE REQUIRED ALTERNATIVE REQUEST ITEM NO.
EXAM. CAT.
COMPONENT EXAMINED METHOD EXAM STATUS No request for relief J
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TABLE 4 PRESSURE TESTS Licensee Relief Proposed Request System or Component Requirements Alternate Status All Systems Test Pressure Use 1977 Granted and temperature
- Edition, shall be main-Winter 1977 tained at least Addenda four hours Requirements prior to performance of examinations Service Water System Test Test at Granted System Pressure shall 1.10 Times be at least 1.10 design pressure times systera of lowest design design pressure pressure portion of system I
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. TABLE 5 ULTRASONIC EXAMINATION TECHNIQUE Licensee Relief Proposed Request System Alternate Status Component Requirements Class 1 Section XI, 1974 Update Requirements Approved to 1977 edition, Piping Welds Edition, Appendix !
Summer 1978 Addenda or Article V of of Section XI.
(3)
Section V (1) Reference letter dated May 1, 1981 from W. G. Counsil (Northeast Nuclear) to Robert A. Clark
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SAI Report No. 186-028-02
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MILLSTONE NUCLEAR POWER STATION UNIT NUMBER 2 INSERVICE INSPECTION PROGRAM 3
TECHNICdlEVALUATIONREPORT
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Submitted to:
U.S. Nuclear Regulatory Comission Contract No. 03-82-096
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Science Applications, Inc.
McLean, Virginia 22102
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July 30, 1982
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i CONTENTS 1
INTRODUCTION..............................
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4 I.
CLASS 1 COMP 0NENTS........................
A.
Rea cto r Ve ssel........................
4 1.
Closure Head Cladding and Vessel Cladding, Category B-I-1, Items Bl.13 and Bl.14 4
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6 B.
Pressurizer.........................
1.
Vessel Cladding, Category B-I-2, Item B2.9........
6 C.
Heat Exchar.gers and Steam Generators.............
7
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1.
Vessel Cladding' Category B-I-2, Item B3.8........
7.
D.
Piping Pressure Boundary (no relief requests)
E.
Pump Pres sure Bounda ry....................
7 1.
Integrally-Welded Supports, Category B-K-1, Item B5.4 7
3 2.
Pump Casing Welds, Category B-L-1 Item B5.6.......
8 F.
Va l ve Pre s su re Bounda ry,...................
10 1.
Bolting on Valves for Safety Injection System,
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Category B-G-1, Item s 86.1 and B6.2...........
10 12 II. CLASS 2 COMPONENTS........................
A.
Pressure Vessels.......................
12 1.
Nozzle-to-Vessel Welds on Shutdown Heat Exchanger, 12
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Category C-B, Item C1.2 2.
Integrally Welded Supports, Steam Generator 14 Snubber Lugs, Category C-C, Item C1.3 3.
Pressure-Retainir.g Bolting, Steam Generators and 2
Shutdown Heat Exchangers, Category C-D, Item C1.4 15 j
17 B.
Piping............................
1.
Pressure-Retaining Bolting, Main Steam Piping and Safety Injection System, Category C-D, Item C2.4...
17
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17 C.
Pumps............................
1.
Pressure-Retaining Bolting, Low-Pressure and High-Pressure Safety Injection Pumps, Category C-0 17 Item C3.2........................
17 fI D.
Valves............................
l 1.
Pressure-Retaining Bolting, Class 2 Valves, 17 Category C-D, Item C4.2
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III. CLASS 3 COMPONENTS (no relief requests)
IV. PRESSURE TESTS.......................... 18
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A.
General 18 1.
Hold Time 18 B.
Class 1 System Pressure Tests (no relief requests)
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C.
Class 2 System Pressure Tests (no relief requests)
D.
Class 3 System Pressure Tests 20 1.
Se rv i c e Wa te r Sy s tem...................
20
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V.. GENERAL......................'.......
22 A.
Ultrasonic Examination Technique...............
22 1.
Recording Levels for Piping Welds 22 25 B.
Exempted Components
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1.
Class 2 25 28 REFERENCES..............................
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.3 TECHNICAL EVALUATICN REPORT MILLSTONE NUCLEAR POWER STATION UNIT NUMBER 2
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IN.,ERVICE INSPECTION PROGRAM S
INTRODUCTION 3
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). TMs updating of the programs was ' required to be done every 40 months to reflect the.nsw requirements of the later editions of Section XI.
As specified in the February 1976 revision, for plants'with Operating
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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 3
effect no more than six months prior to the date of start of facility commercial operation.
The Regulation recognized that the requirements of the later editions
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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 testing requirements to be evaluated. Relief from these re-
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quirements could be granted provided health and safety of the public were not endangered, giving due consideration to the burden placed on the licensee if l
the requirements we-e imposed. This report provides evaluations of the various requests for relief by the licensee Northeast Nuclear Energy Company (NNEC),
5 of the Millstone 2 unit.
It deals only with inservice examinations of com-ponents and with system pressure tests.
Inservice tests of pumps and valves (IST programs) are being evaluated separately.
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- Hereinafter referred to asSection XI or Code.
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i 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 9
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 p'ovisions of the November 1, 1979, revision are effective after September 1, 3
1976,at the start of the next one-third of the 120-month interval. During the one-third of an interval and througho;tt 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
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the start of that one-third of an interval. For Millstcie-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 26, 1979, to December 26, 1985. This program was based upon the 1974 Edition of Section XI
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of the ASME Boiler and Pressure Vessel Code with Addenda through the Suam_e_r of 1975.
The November 1979 revision of the Regulation also provides that ISI
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programs may meet the requirements of subsequent code editions and addenda, incorporated by reference in paragraph (b) and subject to fluclear Regulatory Cormission (NRC) approval.
Portions of sucn editions or addenda may be used provided that all related requirements of the respective editions or addenda
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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 9
exemptions are not acceptable to NRC or are only acceptable with restrictions.
As appropriate, these instances are also discussed in this report.
References (1) to (11) listed at the end of this report pertain to previous infomation transmittals on ISI between the licensee and the Com-mission. By letters of April 26 and November 22,1976,(1,3) the Commission provided general ISI guidance to all licensees. Submittals in response to that guidance were made by the licensee on May 28, 1976,I2) October 26,1978,I4)
January 25,1979,(5) and January 31,1979.(6) On May 11,1379,I7) the Comis-D sio'n granted interim approval of the ISI program pending detailed review. By A
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letters of June 7,1979,(8) and February 26,1982,(10) the Comission requested additional information to complete this review. This information a
III) was furnished by the licensee on June 25, 1979,I9) and on April 1_4, 1982 respectively.
From these submittals, a total of 16 current requests (a) for
'D relief from code requirements, (b) for updating to a later code, and (c) for exeaptions not necessarily acceptable to the Commission were identified. These requests are evaluated in the following sections of this report.
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CLASS 1 COMPONENTS A.
Reactor Vessel D
1.
Closure Head Cladding and Vessel Cladding; Category B-I-1, Items 81.13 and Bl.14 Code Requirement 3
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 accessible sec-tions of vessel shell. The examination shall be 1) visual and a
surface or 2) volumetric for the closure head cladding,.and visual
'for the vessel cladding.
Code Relief Requested Relief requested from performing Code-required examinations 3
of closure head cladding and vessel cladding.
Proposed Alternative Examination The licensee will perform visual examinations of cladding when 3
the internal components are removed at the end of the interval to perform the Category B-N-3 inspe.ctions.
Licensee's Basis for Requesting Relief l
The licensee requests a waiver on performing Code cladding
, 3 examinations based on the following:
l (a) Examinations of clad surfaces in the reactor vessel and reactor vessel head were attempted during the last refueling outage (December 1977 to March 1978) and were limited by access problems in the vessel and surface oxidation in the 3
closure head.
(b) The Sumer 1976 Addenda to Section XI deleted the require-ments for these examinations.
Evaluation D
The 1977 Edition 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 l
provisions:
(a) Comission approval is required to update to the more g
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; 4
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3 The requirements for examining closure head. cladding and vessel cladding are deleted from the 1977 Edition with addenda through Sumer 1978.
Conclusions and Recomendations 3
Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1977 Edition, Sumer 1978 Addenda for Category D-I-1 items. This approval would delete the requirement to examine these items. The licensee's proposed alternative examination is not required.
's References Reference 5, pp I-5 and I-10 (Note 6).
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Pressurizer 1.
Vessel Cladding, Category B-I-2, Item B2.9 9
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 exami-nations perfomed during each inspection interval shall cover s
100% of the patch areas. These examinations may be performed at or near the end of the inspection interval.
Code Relief Request A waiver is requested on perfonning Code cladding 3"
examinations.
Proposed Alternative Examination The licensee will perfom visual examinations of cladding 3
at the end of the interval.-
Licensee's Basis for Requesting Relief None stated.
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Evaluation His statement to the contrary, the licensee is meeting Code requirements by the proposed alternative examination.
5 Conclusions The licensee's proposed alternative examination meets Code requirements, and so this is not a relief request.
8 References Reference 5, pp I-5 and I-10 (Note 6).
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Heat Exchangers and Steam Generators 1.
Vessel Cladding, Category B-I-2, Item B3.8
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Except for item number, this code relief request is identical to the one for Pressurizer Cladding in I.B.1 of this report. There-fore, the following is concluded:
The licensee's proposed alternative examination meets
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requirements, and so this is not a relief request.
D.
Piping Pressure Boundary No relief requests.
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E.
Pump Pressure Boundary 1.
Integrally-Welded Supports, Category B-K-1, Item B5.4 i
Code Requirement The volumetric examination perfomed during each inspection interval shall cover 25% of the integrally-welded supports. The areas shall include the integrally-welded external support attach-y ments. This includes the welds to the pressure-retaining boundary and the base metal beneath the weld zone along the support attach-ment member for a distance of two support thicknesses, Code Relief Request y
Relief is requested from the volumetric examination requirements for integrally welded pump supports.
l Proposed Alternative Examination
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A surface examination will be utilized as an alternative, l
Licensee Basis for Requesting Relief Volumetric examination of attachment welds is not possible d
because of the cast stainless steel pump casing.
Evaluation Each reactor coolani. pump has four welded lugs used in 3
supporting the pumps. The pump casing itself is cast stainless steel. The lugs are made of stainless steel and are fillet welded to the casing. Because the grain structure produced in the fabri-cation process is large, cast austenitic materials attenuate#
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ultrasound to a high extent. The combination of high ultrasonic beam attenuation in the cast material and the geometry of the fillet welds makes a meaningful ultrasonic examination impractical. Based
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on welds, geometry, and loading conditions, the most probable in-service defect would occur at the surface of the welds or base metal snd would be detected by surface examination. Therefore, a surface examination of these fillet welds and the surrounding base material would provide a more sensitive and reliable means of detecting defects in these welds than ultrasound.
3 Conclusions and Recomendations Based on the above evaluation, it is concluded that for the welds discussed above, the code requirements are impractical.
It is further concluded that the alternative examination discussed I
above will provide necessary added assurance of structural reli-ability. Therefore, the following is recor,inended:
. Relief should be granted from the volumetric examination requirement, with the folicwing provision:
A~ surface examination of the fillet weld and of the surround-ing base material on one lug on each recirculation pump casing should be done during each inspection interval.
References
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Reference 5, pp I-7 r.nd I-10 (Note 8).
2.
Pump Casing Welds, Category B-L-1, Item B5.6
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Code Requirement The volumetric examination perfonned during each inspection interval shall include 100% of the pressure-retaining welds in at least one pump in each grou-) of pumps performing sinilar functions p
in system (e.g., recirculating coolant pumps). The examination may be performed at or near the end of the inspection interval.
The area shall include the weld metal and the base metal for one wall thickness beyond the edge of the weld.
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Code Relief Request Relief is requested from volumetric examination requirements for pump casing welds.
Proposed Alternative Examination I
None at this time.
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Licensee's Basis for Requesting Relief _
Millstone Unit No. 2 utilizes Byron-Jackson /Borg-Warner Type 3
DFSS pumps manufactured in 1972. With the dual casings which comprise these pumps, use of the MINAC (miniature linear accelerator) for examinations is not possible since placement of either the radiographic source or film on the inside of the welds under examination is impossible.
Ultrasonic examination of these heavy 'all castings using w
current techniques would be of questionable benefit due to the grain size and back refle: tion problems.
The reactor coolant pumps presently being examined using the MINAC are of a different design which enables single wall radio-
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graphs. No deterioration of pump. casings has been reported. to date. The examinations r,esult in large expenditures in time and.
radiation exposure and are extremely expensive.
With the current state-of-the-art, the licensee hereby requests relief from the ISI requirements for reactor coolant pumps
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(RCPs) since no valid examinacion techniq;e is available. If, before 1985, a reasonable examination technique is developed for Byron-Jackson type pumps, the licensee will reevaluate this relief request.
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Evaluation A radiographic examination of the RCP casing welds appears technically marginal for the Byron-Jackson type pumps, even if the pump is disassembled. Such examinations are, as the licensee points out, time consuming and expensive in exposure and dollars.
At Point Beach, radiographic examination of welds on one RCP 3
casing and visual examination of the pump inside pressure re-taining surfaces were performed using MINAC and a manipulator. This examination required about 25 days (including pump disassembly and reassembly).
It resulted in a total accumulated radiation exposure of 36 man-rem and a cost of about $700,000. Radiographing through two wall thicknesses to examine a weld in one wall, as would be 3
necessary for the Byron-Jackson type pump casings, is not likely to produce meaningful results without further development work.
The MINAC has been used at Ginna, Turkey Point, Point Beach, and Robinson. No notable indications were found in any of the pumps examined, 3
l At this time, disassembly of pumps solely for making this volumetric examination does not appear warranted in view of the radiation exposure and lack of a viable examination technique. However, an examination could be done by the most feasible means if a pump at Millstone 2 requires disassembly for 9
maintenance. At this stage of technology development, a surface
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3 examination of at least a portion of these welds would be the most appropriate. Since the technology is being actively dev-eloped, a final decision on this relief request could be y
reasonably postponed until near the end of the inspection interval (1985).
Conclusions and Recor.vnendations Based on the above evaluation, it is corcluded that for y
the RCP casing welds discussed above, there is not presently enough justification for declaring the code. requirements im-practical. Therefore, the following is recommended:
(a) Relief from volumetric examination requirements for RCP casing welds should not be granted at this time.
2 (b) The licensee should be encouraged to comit to examine these welds, by the most feasible means, on the first such pump disassembled for maintenance during this inspection interval.
(c) An updated relief request should be submitted near the
)
end of the inspection interval. in time for an NRC decision and for implementation of that decision, if necessary, during the last outage of the interval.
References Reference 5, pp I-3 and I-10 (Note 7); Reference 11, pp 2 and 3.
F.
Valve Pressure Boundary 1.
Bolting on Valves for Safety Injection System, Category B-G-1.
Items B6.1 and B6.2 l
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Code Requirement 1
l The examinations 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.
Bushings, threads, and ligaments in base material of flanges are required to be examined (surface) only when tne connection is y
l disassembled. Bolting may be examined (volumetrically) either l
in place under tension when the connection is disassembled, or when the bolting is removed.
Code Relief Request
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Relief is requested from the volumetric examination require-ment for valve bolting on the safety injection system.
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y Proposed Alternative Examination The examination requirements for Category B-G-2 will.be y
applied.
Licensee 's Basis for Requesting Relief The 2-in.-diameter bonnet bolting in the safety injection system valves has spherical ends and cannot be volumetrically 3
exarained.
Evaluation The geometry of these bolts does not permit volumetric exami'-
,2 nation because of the spherical ends.. I.n the Summer 1978 Addenda of Section XI, pressure-retaining bolting 2-in; in diameter has
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been assigned to Category B-G-2 for which a visual examination is specified by the Code.
The 1977 Edition of Section XI has been referenced in 10 CFR
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50.55a and inservice examinations may meet the requirements of this edition in lieu of those from previous editions with the following i
provisions:
(a) Comission approval is required to update to the more recent edition (pursuant to 10 CFR 50.55a(g)(4)(iv));
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(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.
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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 Sumer 1978 Addenda 3
for this valve bolting. This approval wculd shift this bolting to Category B-G-2 for which a visual examination is specified by the Code.
References 3
Reference 5, pp I-7 and I-11 (Note 10',.
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y II. CLASS 2 COMP 0iiENTS A.
Pressure' Vessels 1.
Nozzle-to-Vessel Welds on Shutdown Heat Exchanger, Category C-B, Item C1.2 Code Requirement The volumetric examination shall cover 100% of the nozzle-to-vessel attachment welds.
Code Relief Request
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Relief is requested from the full volumetric examination-requirements of ~four nozzle-to-vissel welds (Nos. SIAC B-1 and B-2 and SIBC B-1 and B-2) on the shutdown heat exchanger.
Proposed Alternative Examination
)
Ultrasonic examination will be used to the extent practical, supplemented by a surface examination.
Licensee's Basis for Requesting Relief
)
Category C-B nozzle-to-vessel welds in the shutdown heat exchangers were originally inspected using liquid penetrant (surface examination).
Evaluation After the initial request, the licensee withdrew the relief request and proposed the alternative examination "in the event that a code-acceptable examination utilizing ultra-sonic techniques cannot be performed." The licensee effectively has not withdrawn the relief request because he proposes to do
)
the ultrasonic examination to the extent practical, supplemented by a surface examination.
The welds are difficult to examine because the nozzles are inserted into the shell and the full penetration thickness of the weld is in the shell.
5 One way to address this relief request is to apply the requirements of the Sumer 1978 Addenda of the 1977 Edition for Item C2.20 in Category C-B in Table IWC-2500-1. This item is for nozzles in vessels where the nozzles are over 1/2-in, in nominal thickness. The examination method is a combination of 7
(a) surface covering the entire weld plus some of the adjacent flat surface (A-B) and (b) volumetric of the lower third of the weld penetration plus adjacent heat-affected zone (CDEF) as
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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) Comission 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 Summer 1978 Addenda must be used; (c) Any requirement of the more recent edition which is 3
. related to the one(s) under consideration must also be met.
Reconnendations Pursu' ant to 10 CFR 50.55a(g)(4)(iv), approval should be
)
granted to update to the requirements of the 1977 Edition, Sumer 1978 Addenda for the welds described above. This approval would pennit the licensee to perform an ultrasonic examination, as supplemented by a surface examination.
If the licensee can meet the requirements for Item C2.20 in Category C-B in the new'er code, no further relief request y
would be necessary.
References Reference 5, pp II-2 and II-6; Reference 11, Item 4.
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Integrally Welded Supports, Steam Generator Snubber Lugs, Category C-C, Item.1.3 c
G Code Requirement The surface examinations shall cover 100% of the weld.
The areas shall include the welds of external support attach-ments, brackets, lugs, etc.
Code Relief Request Delete this examination requirement.
D Proposed Alternative Examination-None.
Licensee's Basis for Jtequestino Relief 3
These snubber lugs are not subject to loading during normal operations and, therefore, are not considered supports. They are expected to carry seismic loads. Because they do not carry loads during normal reactor operations, they are exempt per IllC-1220(b).
Evaluation 3
The steam generators are vertically mounted on bearing plates 1
that allow lateral motion due to thermal expansion of the reactor coolant piping. Stops are provided to limit this motion in case of a coolant pipe rupture. The top of each unit is restrained from sudden lateral movement by suitable stops and hydraulic O
snubbers mounted rigidly to the concrete structure.
If a seismic event occurs during nomal reactor operation, these lugs are expected to carry loads. Loads would also be expected on them due to thermal expansion from changes in oper-ating temperature. The intent of the Code does not appear to O
exempt supports of this type under the tems of this paragraph.
The examination is apparently not impractical.
Conclusions and Recomendations Based on the above evaluation, it is concluded that for the O
welds discussed above, there is not enough justification for de-claring the code requirement impractical. Therefore, the following I
is recomended:
Relief should not be granted from surface examination of' the above welds.
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References Reference 11, pg 2; Reference 12, Section 4.3.3 l
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Pressure-Retaining Bolting, Steam Generators and Shutdown Heat Exchangers, Catego y C-D, Item C1.4 3
Code Requirement For pressure-retaining bolting exceeding 1-inch-diameter, visual examinations performed during each inspection interval shall cover 100% of the bolts, studs, nuts, bushings, and threads 3
in the base material and flance ligaments between threaded stud holes.
Code Relief Request 3
Delete the examination of Class 2 bolting of 2 inches and below.,
Proposed Alternative Examination None.
9 Licensee 's Basis for Requesting Relief This deletion is in accordance with the 1977 Edition, Sumer 1978 Addenda (Category C-D) which has been amended to 3
require examination of pressure-retaining bolting exceeding 2 inches. Millstone 2 does not have Class 2 bolting exceeding 2 inches.
Evaluation O
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) Comission approval is required to update to the more O
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 O
be met.
The requirements for examining Class 2 pressure-retaining bolting 2 inches or below are deleted from the 1977 Edition with addenda through Summer 1978.
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References 3
Reference 11, pg. 2.
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Piping 1.
Pressure-Retaining Bolting, Main Steam Piping, and Safety
'3 Injection System, Category C-D, Item C2.4 Except for item number, this code relief request is identical to the one for steam generator and heat exchanger bolting, II.A.3 above. Therefore, the following is recomended:
3 Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1977 Edition, Sumer 1978 Addenda for Category C-D items. This approval would delete the requirement to examine the pressure-retaining bolting for Class 2 piping.
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C.
Pumps 1.
Pressure-Retaining Bolting, Low-Pressure and High-Pressure 3
Safety Injection Pumps, Category C 0, Item C3.2 Except for item number, this code relief request is identical to the one for steam generator and heat exchanger bolting, II.A.3 above. Therefore, the following is recomended:
3 Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1977 Edition, Sumer 1978 Addenda for Category C.-D items. This approval l
would delete the requirement to examine the pressure-retaining l
bolting for Class 2 pumps.
9 D.
Valves i
1.
Pressure-Retaining Bolting, Class 2 Valves, Category C-D, 3
Item C4.2 Except.for item number, this code relief request is identical to the one for steam generator and heat exchanger bolting, II.A.3 above. Therefore, the following is recomended:
Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be 9
granted to update to the requirements of the 1977 Edition, Sumer 1978 Addenda for Category C-D items. This approval would delete the requirement to examine the pressure-retaining bolting for Class 2 valves.
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IV. PRESSURE TESTS 3
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General 1.
Hold Time Code Requirement y
IWA-5210(a) of the 1974 Edition, Summer 1976 Addenda states that the test pressure and temperature shall be maintained for at least four hours prior to the performance of the examinations.
3 Code Relief Request Relief is requested from pressure-testing hold time requirements of the Code.
Proposed Alternative Examination The licensee proposes t'o use the 1977 Edition, Hinter 1977 Addenda, IWA-5213, to define test condition hold time.
Licensee's Basis for Requesting Relief
}
Hone given.
Evaluation The 1977 Edition of Section XI has been referenced in 10 CFR 3
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));
9 (b) When applying the 1977 Edition, all of the addenda through Summer 1978 Addenda must be used; (c) Any requirement cf the more recent edition which is related to the one(s) under consideration must also be met.
IWA-5213 of the 1977 Edition, Winter 1977 Addenda of the Code D
was included in the Sumer 1978 Addenda.
IWA-5213 refers to types of tests and to pressure and temperature conditions that are defined in other paragraphs of Subsubarticle IWA-5210. The entire subsub-article needs to be adopted to comply with requirements of (c) above.
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granted to update from the requirements of Paragraph IWA-5210 of the 1974 Edition Sumer 1975 Addenda to the requirements of Subsubarticle IWA-5210 in the 1977 Edition, Summer 1978 Addenda. This approval would pemit the licensee to carry out its proppsed alternative enmination..
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Referer.ces Referecce 5, pg PT-1.
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Class 1 Systea Pressure Tests (No relief reauests)
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Class 3 System Pressure Tests 1.
Service Water System Code Requirement 3
IWD-5200(a) states the system test pressure shall be at least 1.10 times the system design pressure.
Code Relief Request
)
Relief is requested from code pressure requirements for the hydrostatic test of the service water system.
Proposed Alternative Examination
)
The licensee proposes to test the entire service water.systen to 94 psig test pressure, based on the underground portion of the-service water system.
)
Licensee's Basis for Requesting Relie_f The service water system consists of piping and components designed to three different pressures, depending upon service con-ditions and material selection:
Cast Iron Underground PD= 85 psig 3
Relief Valve Inlets PD = 150 psig Balance (majority) of System PD = 100 psig.
In most instances, it is not possible to isolate these sections from each other to permit Code pressure tests..The licensee requests
)
a waiver from the requirements of IWD-5220(a) for the two higher pressure sections. Although this pressure is lower than the design pressure for most of the service water system, it is approximately 1-1/2 times the system operating pressure and would constitute a meaningful hydrostatic test.
Evaluation Subarticle IWD-5200 was significantly expanded in subsequent versions of Section XI. By the Summer 1978 Addenaa of the 1977 Edition, the requirements for the system hydrostatic test pressure were relaxed. According to Paragraph IWD-5223. "the system hydro-static test pressure shall be at least 1.10 times the system pressure P for systems with design temperature of 2000F (930C) or less...sv The system pressure P shall be the lowest pressure sy setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested."
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of each Class 3 system undergo other pressure tests specified in Paragraph IWD-5210, in accordance with system examination cate-gories specified in Table IWD-2500-1. The service water system for Millstone 2 falls into Category D-B that includes systems in support of containment heat removal and reactor residual heat removal, among others.
The 1977 Edition 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 fol-lowing provisions:
)
(a) Comission 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 y
related to the one(s) under consideration must also be met.
Accordingly, relief from the pressure test requirement, as Al requested by the licensee, could be accomplished provided l
subarticle IWD-5200 in the Sumer 1978 Addenda of the 1977 Edition
)
is adopted to comply with requirements of (c) above.
Recomendations Pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update from the requirements of Subarticle IWD-5200
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of the 1974 Edition, Sumer 1975 Addenda to the requirements of IUD-5200 in the 1977 Edition, Summer 1978 Addenda. This approval would reduce the system's required hydrostatic test pressure.
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References References 5 and 13.
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GENERAL A.
Ultrasonic Examination Technique 3
1.
Recording Levels for Piping Welds Code Requirements ASME Code Section XI (1974 Edition), Paragraph IWA-2232, 3
Ultrasonic Examination: " Ultrasonic examination shall be con-ducted in accordance with the provisions of Appendix I.
Where Appendix I (I-1200) is not applicable, the provisions of Article 5 of Section V shall apply."
ASMECode~SectionV(1974 Edition),ParagraphT-537,
- 3 Evaluation of Indications:
"All indications which produ.ce a response greatei than 20% of the reference level shall be investi-gated to the extent that the operator can evaluate the shape, identity, and location of all such reflectors in terms of the acceptance-rejection standards of the referencing Code section."
)
Code Relief Request
~
Relief is requested to use another appendix of the Code
. -. in lieu of the above requirement.
Proposed Alternative Examination The licensee would use Appendix III of the 1974 Edition through Winter 1975 Addenda of Section XI.
Licensee's Basis for Requesting Relief Ultrasonic examinations are required to be conducted in ac-cordance with the provisions of Appendix I and Article 5 of Section V as required by Paragraph IWA-2232. As an alternative to using Article 5 of Section V, the licensee proposes to use
)
Appendix III of Section XI of the 1974 Edition, Winter 1975 Addenda of the ASME Boiler and Pressure Vessel Code for ultra-sonic examination of piping systems.
It is recognized that Appendix III of Section XI was issued in the Winter 1975 Addenda and, as such, has not been officially recognized by the NRC by reference in 10 CFR 50. However, Appendix III is the first
}
guideline that has been published in the ASME Codes for the ultrasonic examination of pipe welds and, as such, its use is essential.
Evaluation
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Recording and evaluating indications at 20% of the reference level is impractical for the following reasons:
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(a) The welded joints in nuclear piping frequently contain Code-allowable wall thickness differences (12% of nominal thickness) as well as some weld drop-through, 3
counterbore taper, crown height, etc. These conditions 9enerate an extremely large number of geometric reflec-tors that produce UT indications greater than 20% of i
the reference level.
(b) Weld metal in stainless steel piping contains reflectors due to the metallurgical structure that produce a large
'8 number of UT indications.
(c) All examination personnel experience radiation exposure during inservice examinations. The Section V requirement to record and evaluate UT indications at the 20% level places an unnecessary burden on the limited number of ex-
)
perienced and qualified examiners ava-ilable to the licensee.
The 1977 Edition 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) Comission 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 l
through Sumer 1978 Addenda must be used; (c) Any requirement of the more recent edition which is 3
related to the one(s) under consideration must also be met.
Appendix III was incorporated into Paragraph IWA-2232 of the l
1977 Edition through Sumer 1978 Addenda of Section XI. To meet the requirements of (c) above, the entire Paragraph IWA-2232 in I
the Sumer 1978 Addenda should be adopted by the licensee. This paragraph includes the following:
(a) For examination of welds, reflectors that produce a response greater than 50% of the reference level shall be recorded. (IWA-2232(c)(1))
(b) For examination'of welds, all reflectors which produce l
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 standardsofIWA-3100(b).
(IWA-2232(c)(2))
l 9 (c) 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 3
which are interpreted to be a crack must be identified and evalu-
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ated according to the rules of Section XI.
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3 Recomendations Pursuant to 10 CFR.50.55a(g)(4)(iv), approval should be 3
granted to update from the requirements of Paragraph IWA-2232 of the 1974 Edition, Sumer 1975 Addenda to the requirements of the same paragraph in the 1977 Edition, Sumer 1978 Addenda, with the additional requirement that indications 20% of reference level or greater that are interpreted to be a crack must be identified and evaluated according to the rules of Section XI.
References Reference 5, pg I-2 (Note 4); Reference 9, Attachment 2.
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Exempted Components 0
1.
Class 2 Code Requirement IWC-1220, Exempted Components: The following components O
may be exempted from the examination requirements of IWC-2520:
(a) Components in systems where both the design pressure and temperature are equal to or less than 275 psig and 0
200 F, respectively.
'g' (b) Components in systems or portions of systems, other than
_ emergency core cooling systems, which do not function during normal reactor operation.
(c) Components which perfom an emergency core cooling function, provided the ccatrol of the chemistry 1 of the contained fluid is verified by periodic sampling 9
and test.
(d) Component connections, piping, and associated valves, and vessel (and their supports) that are 4-in. nominal pipe size and smaller.
3 Augnented Requirement The augmented requirements of the NRC may be met by updating to IWC-1220 of the Sumer 1978 Addenda, which states:
The following components shall be exempted 'from the inservice examination requirements of IWC-2500.
(a)Componentsofsystemsorportionsofsystgmsthat during normal plant operationg conditions are not required to operate or perform a system function but remain flooded under static conditions at a pressure of at least 80% of the pressure that the component or system will be subject to when O
required to operate; or (b) Components of systems or portions of systems, other than Residual Heat Removal Systems (RHRS) and Emergency Core Cooling Systems (ECCS), tnat are not required to operate above a pressure of O
275 psig 1900 kPa) or above a temperature of 2000F (93 C); or
- 1. The control of fluid chemistry is intended to minimize corrosive effects, particularly stress corrosion.
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- 2. Normal conditions include operating conditions during reactor startup, operation at power, hot standby, and reactor cooldown to cold shutdown conditions. Test conditions are excluded.
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and vessels (and their supports) that are 4-in.
nominal pipe size and smaller.
Licensee's Position
)
ECCS, RHRS, and CHRS (Containment Heat Removal System) piping are now and have been inspected except for (1) IWC-1220(c) com-ponents that are 4-inches and less in diameter, and (2) IWC-1220(a) piping from the Refueling Water Storage Tank (RWST) to the pumps suction which remains flooded and pressurized to the head of the 3
RWST. This program is contained within the Class 2 Inspection Manual and is in compliance with the exemption criteria of the 1977 Edition, Summer 1978 Addenda.
Evaluation 9
Paragraph IWC-1220(c) of Section XI,1974 Edition, permits the exemption from examination of ECCS components provided that the control of water chemistry is verified by periodic sampling and testing to minimize corrosive effects, particularly stress corrosion. The " chemistry control" provision was deleted from Paragraph IWC-1220 in the 1977 Edition of Section XI because o
practical evaluation, review, and acceptance standards could not be defined.
Paragraph IWC-1220(a) of Section XI, 1974 Edition, permits the exemption from examination of components where both the design O
pregsure and temperature are equal to or less than 275 psig and 200 F, respectively.
Paragraph IWC-1220(b) of Section XI, Sumer 1978 Addenda, does not permit the exemption from examination of components in0 the ECCS and the RHRS that operated below 275 psig or below 200 F.
O Welds in these Code-exempted systems have experienced service failures and were the subject of I&E Bulletins such as No. 79-17,
" Pipe Cracking in Stagnant Borated Water Systems at PWR Plants."
Paragraph 10 CFR 50.55a(b)(2)(iv)(A) requires that approp-riate ASME Code Class 2 pipe welds in the RHRS, ECCS, and CHRS O
be examined.
The licensee's program addresses these concerns and meets the exemption criteria of the 1977 Edition, Sumer 1978 Addenda.
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The licensee's program provides for adequate inservice inspection of Emergency Core Cooling, Residual Heat Removal, and Containment Heat Removal systems.
3 References C.
Other 3
None.
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.e REFERENCES 1.
G. Lear (NRC) to D. C. Switzer (NNEC), April 26, 1976.
3 2.
D. C. Switzer (NNEC) to G. Lear (NRC), May 28, 1976.
3.
G. Lear (NRC) to D. C. Switzer (NNEC), November 22, 1976.
4.
W. G. Counsil (NNEC) to R. Reid (NRC), Proposed Revisions to
)
Technical Specifications, October 26, 1978.
5.
W. G. Counsil (NNEC) to R. Reid (NRC), Inservice Inspection and Testing Program, January 25, 1979.
6.
W. G. Counsil (NNEC) to R. Reid (NRC), January 31, 1979.
)
7.
R. Reid (NRC) to W. G Counsil (NNEC), May 11, 1979.
8.
R. Reid (NRC) to W. G. Counsil (NNEC), June 7,1979.
9.
W. G. Counsil (NNEC) to R. Reid (NRC)
Inservice Inspection and y
Testing Program, June 25, 1979.
10.
R. A. Clark (NRC) to W. G. Counsil (NNEC), Request for Additional Information, February 26, 1982.
- 11. A02327, W. G. Counsil (NNEC) to R. A. Clark (NRC), Additional y
Information, Inservice Inspection and Testing Program, April 14, 1982.
- 12. Final Safety Analysis Report, August 1972.
- 13. Ffnal Safety Analysis Report, Amendment 39, July 18, 1975.
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