ML20046C189
| ML20046C189 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 06/14/1993 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20046C188 | List: |
| References | |
| PROC-930614, NUDOCS 9308090320 | |
| Download: ML20046C189 (74) | |
Text
I I
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i THIRD TEN-YEAR INSPECTION INTERVAL INSERVICE INSPECTION PLAN -
FOR t
ZION NUCLEAR POWER STATION UNITS 1 AND 2 101 SHILOH BOULEVARD i
ZION, ILLINOIS 60099 i
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F i
r COMMONWEALTH EDISON COMPANY i
P.O. BOX 767 CHICAGO, ILLINOIS 60690 i
- i 9308090320 930803 M
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1 Zion Station 3rd Interval Inservice Inspection Plan REVISION
SUMMARY
SIIEET l
Section Effective Page(s)
Revision Date I
l-1 0
6/14/93 2
2-1 0
6/14/93 3
3-1 to 3-6 0
6/14/93 4
4-1 to 4-2 0
6/14/93 5
5-1 to 5-7 0
6/14/93 6
6-1 to 6-8 0
6/14/93 7
7-1 to 7-40 0
6/14/93 8
8-1 to 8-2 0
6/14/93 i
9 9-1 0
6/14/93 10 10-1 to 10-5 0
6/14/93 i
1
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COE-275-012 1-1 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan TABLE OF CONTENTS Section Description Page(s)
Revision Summary Sheet 1-1 1
2 Table of Contents 2-1 3
Introduction and Plan Description 3-1 to 3-6 4
List of Applicable Piping and Instrumentation 4-1 to 4-2 Diagrams (P&lDs) 5 Units 1 & 2 Inservice Inspection Summary Table 5-1 to 5-7 6
Inservice Inspection Technical Approach and 6-1 to 6-8 Positions 7
Inservice Inspection Relief Requests 7-1 to 7-40 8
Units 1 & 2 System Pressure Testing Summary Table 8-1 to 8-2 9
System Pressure Testing Technical Approach and 9-1 Positions 10 System Pressure Testing Relief Requests 10-1 to 10-5 COE-275-012 2-1 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan INTRODUCTION AND PLAN DESCRIPTION 1.
Introduction 1.1 This Inservice Inspection Plan outlines the requirements for the examination of-ISI Class 1,2, and 3 pressure retaining components and their supports at Zion Nuclear Power Station, Units 1 and 2.
1.2 This Inservice Inspection Plan will be effective from December 31,1993 through and including December 31,2003 for Zion Unit I and effective from September 17,1994 through and including September 17,2004, for Zion Unit 2 for the third ten year interval, and may be adjusted per IWA-2430.
1.3 The key features of this Plan are the Introduction and Plan Description, Relief Requests, Technical Approach and Positions, and Summary Tables. The details of the Inservice Inspection Program are addressed in other documents that are available at Zion Station. These documents include, but are not limited to:
Component drawings; piping and instrumentation diagrams; piping isometric drawings; a component listing of each weld, valve, support, etc., subject to selection for inservice inspection; procedures; schedules; and other records required to define and execute the Inservice Inspection Plan at Zion Station.
2.
Basis of Inservice Insnection Plan 2.1 This Plan was developed in accordance with the requirements delineated in the 1989 Edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Subsections IWA, IWB, IWC, and IWD, per Inspection Program B of IWA-2432 except as follows:
The ISI Plan for Subsection IWF was developed in accordance with Code Case N-491, which is approved for use in ISI Programs per Regulatory Guide 1.147, Revision 10. Inspection Program B of Table 2410-2 in Code Case N-491 will be employed.
/
Inservice pressure testing for Class 1 and 2 components will be performed in accordance with Code Case N-498, which is approved for use in ISI Programs per Regulatory Guide 1.147, Revision 10. Class 3 inservice pressure testing will be performed in accordance with Relief Request PR-01.
2.2 An ISI Plan per Subsections IWE and IWL are not included in this submittal.
These subsections are currently not required to be part of Inservice Inspection programs per 10CFR50.55a.
COE-275-012 3-1 Revision 0 L
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Zion Station 3rd Interval Inservice Inspection Plan 2.3 As allowed by 10 CFR 50.55a(c)(B) and USNRC Regulatory Guide 1.147, Revision 10, the following Code Cases are being incorporated into the Zion ISI Program:
Case N-460 - Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1.
Case N-463 Evaluation Procedures and Acceptance Criteria for Flaws in Class 1 Ferritic Piping that Exceed the Acceptance Standards of IWB-3514.2.
Case N-491 - Alternative Rules for Examination of Class 1, 2, 3 and MC Component Supports of Light-Water Cooled Power PlantsSection XI, Division 1.
)
Case N-498 - Alternate Rules for 10 Year Hydrostatic Pressure Testing for Class 1 and 2 Systems,Section XI, Division 1.
3.
System Classification 3.1 The construction permit for Zion Units 1 and 2 was issued on December 26, 1968. At that time, the ASME Boiler and Pressure Vessel Code covered only nuclear vessels. Piping, pumps, and valves were built primarily to the rules of USAS B31.1.0-1967, Power Piping.
3.2 The system classifications used for the Inservice Inspection Program are based on the requirements of 10 CFR 50 and Regulatory Guide 1.26, Revision 3. These classifications were developed for the sole purpose of assigning appropriate inservice inspection requirements for water, steam, and radioactive waste containing components.
3.3 Components within the reactor coolant pressure boundary, as defined in 10 CFR 50.2, are designated as Inservice Inspection Class 1, while other safety related components, that meet the requirements for Class B and Class C components, are designated as Inservice Inspection Class 2 or 3 in accordance with the guidelines of Regulatory Guide 1.26, Revision 3. Pursuant to 10 CFR 50.55a, paragraph (a)(1), the inservice inspection requirements of the ASME Boiler and Pressure Vessel Code,Section XI are assigned to these components, within the constraints of existing plant design.
4.
Auemented Inservice Insoection Requirements 4.1 The following augmented inservice inspection requirements are being implemented at Zion Station Units 1 and 2 in accordance with the latest licensing agreements pertaining to these requirements:
COE-275-012 3-2 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan 4.1.1 Regulatory Guide 1.14. Revision 1, Reactor Coolant Pump Flywheel Examination.
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4.1.2 Regulatorv Guide 1.150. Revision 1, Ultrasonic Testing of Reactor Vessel i
Welds During Preservice and Inservice Examinations.
5.
Contents of Inservice Inspection Plan 5.1 The Inservice Inspection Plan addresses the requirements for inservice inspection of components and system pressure testing separately, although some Sections of the Plan are common to both. The applicability of each of the Sections identified in this Plan are as follows:
5.1.1 Inservice Insoection and System Pressure Testing i
Sections 1, 2, 3, and 4.
5.1.2 Inservice Inspection Sections 5, 6, and 7.
5.1.3 System Pressure Testing Sections 8,9, and 10.
5.2 Section 1 - Revision Summary Sheet i
Provides the revision status of the effective pages in the Inservice inspection Plan.
5.3 Section 2 - Table of Contents Provides the organizational format for the Inservice Inspection Plan.
5.4 Section 3 - Introduction and Plan Description Provides details on the scope, basis and contents of the Inservice Inspection Plan, system classifications, and augmented inservice inspection requirements.
5.5 Section 4 - List of Applicable Piping and Instrumentation Diagrams (P&lDs)
Provides a listing of P&lDs corresponding to each system that contains components subject to examination under this Plan.
COE-275-012 3-3 Revision 0
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Zion Station 3rd Interval Inservice Inspection Plan 5.6 Section 5 - Inservice Inspection Summary Tables The Inservice Inspection Summary Tables for Units 1 and 2 provide the following information:
5.6.1 Examination Category and Examination Category Descriotion Provides the examination category and description as identified in AShiE Section XI, Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.
Only those examination categories applicable to Zion Station are identified.
I t
5.6.2 Item Number and Item Description Provides the item number and description as defined in ash 1E Section XI, Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1. Only those item numbers applicable to Zion Station are identified.
l 5.6.3 Exam Reauirements Provides the examination method (s) required by ASME Section XI, Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.
5.6.4 Relief Request Provides a listing of relief requests applicable to the item number. If a relief request number is identified, see the corresponding relief request in Section 7.
5.6.5 Technical Approach and Position Provides a listing of technical approach and positions applicable to the item number. If a technical approach and position number is identified, see the corresponding technical approach and position in Section 6.
5.7 Section 6 - Inservice Inspection Technical Approach and Positions When the requirements of ASME Section XI are not easily interpreted, Zion Station has reviewed general licensing / regulatory requirements and industry practice to determine a practical method ofimplementing the Code requirements.
The technical approach and position documents contained in this section have been provided to clarify Zion Station's implementation of ASME Section XI requirements for inservice inspection. An index which summarizes each technical i
approach / position is included at the beginning of this section.
COE-275-012 3-4 Revision 0 i
Zion Station 3rd Interval Inservice Inspection Plan 5.8 Section 7 - Inservice Inspection Relief Requests 1
This section contains relief requests written in accordance with 10 CFR 50.55a (g)(5) when specific ASME Section XI included requirements for inservice inspection are considered impractical or pose an undue burden on the licensee.
The enclosed relief requests are subject to change throughout the inspection interval. If examination requirements are determined during the course of the interval to be impractical, or result in hardship or unusual dif5culty without a compensating increase in the level of quality and safety, additional or modified
?
relief re@ests will be submitted in accordance with 10 CFR 50.55a (g)(5). ' An index which summarizes each relief request is included at the beginning of this
- section, i
5.9 Section 8 - System Pressure Testing Summary Table The Unit 1 and 2 System Pressure Testing Summary Table, provides the following information:
5.9.1 Examination Category
{
l r
Provides the examination category as identified in ASME Section XI, l
Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1.
t 5.9.2 ltem Number i
Provides the item number as identified in ASME Section XI, Tables IWB-2500-1, IWC-2500-1 and IWD-2500-1. Only those examination item numbers applicable to Zion Station are included.
5.9.3 Description of Parts Examined l
l Provides the description of parts examined as identified in ASME Section XI, Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1.
]
5.9.4 E3 amination Reauirements Provides the examination method required by ASME Section XI, Tables IWB-2500-1, IWC-25001, and IWD-2500-1.
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5.9.5 Svstem Provides the Zion system applicable to the Technical Approach and Position and Relief Request of Sections 9 and 10, respectively.
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l COE-275-012 3-5 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan j
5.9.6 Belief Request
+
Provides a listing of applicable relief requests. If a relief request l
number is identified, the corresponding relief request may be found in Section 10.
5.9.7 Technical Approach and Position 5
Provides a listing of applicable technical approach and positions. If a technical approach and position number is identified, see the corresponding technical approach and position may be found in Section l
9.
5.10 Section 9 - System Pressure Testing Technical Approach and Positions When the requirements of ASME Section XI are not easily interpreted, Zion Station has reviewed general licensing / regulatory requirements and industry practice to determine a practical method of implementing the Code requirement.
t The technical approach and position documents contained in this section have I
been provided to clarify Zion Station's implementation of ASME Section XI requirements for system pressure testing. An index which summarizes each technical approach / position is included at the beginning of this section.
5.11 Section 10 - System Pressure Testing Relief Requests This section contains relief requests written in accordance with 10 CFR 50.55a (g)(5) when specific ASME Section XI requirements, as modified by Code Case N-498 for system pressure testing are considered impractical. The enclosed relief requests are subject to change throughout the inspection interval. If testing requirements are determined to be impractical during the course of the interval, i
additional or modified relief requests will be submitted in accordance with 10
{
CFR 50.55a(g)(5). An index which summarizes each relief request is included at the beginning of this section.
6 i
l COE-275-012 3-6 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan LIST OF APPLICABLE PIPING AND INSTRUMENTATION DIAGRAMS (Page 1 of 2)
Unit 1 Unit 2 Title Drawing Number Drawing Number M-20 M-500 Diagram of Main Steam Piping M-22 M-502 Diagram of Steam Generator Feedwater Piping M-32, SH.1 & 2 M-32, SH.1 & 2 Diagram of Service Water M-34 M-34 Diagram of Service Water M-37, SH.1 M-37, SH. 2 Diagram of Condensate Storage System M-39 M-512 Diagram of Isolation Valve Seal Water M-43 M-513 Diagram of Screen Wash & Fire Protection M-44 M-514 Diagram of Containment System Spray System M-45, SH.1 M-45, SH. 3 Diagram of Waste Disposal System (Liquid)
Blowdown System M-47 M-47 Diagram of Waste Disposal System (Liquid)
Auxiliary Building, Drains M-52 M-515 Diagram of Reactor Coolant Diagram Loops 1&2 M-53 M-516 Diagram of Reactor Coolant Diagram Loops 3&4 M-54 M-517 Diagram of Chemical & Volume Control Systems M-55 M-518 Diagram of Chemical & Volume Control Systems M-56 M-519 Diagram of Chemical & Volume Control Systems M-57 M-57 Diagram of Chemical & Volume Control Systems M-62 M-520 Diagram of Residual Heat Removal M-63 N/A Diagram of Spent Fuel Pit Cooling &
Cleanup Piping COE-275-012 4-1 Revision 0
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Zion Station 3rd Interval l
Inservice Inspection Plan LIST OF APPLICABLE PIPING AND INSTRUMENTATION DIAGRAMS (Page 2 of 2) t Unit 1 Unit 2 Title Drawing Number Drawing Number M-64 M-521 Diagram of Safety Injection System M-65 M-522 Diagram of Safety Injection System M-66 M-523 Diagram of Component Cooling System M-67 M-523 Diagram of Component Cooling System M-69 M-69 Diagram of Demineralized Flushing Water M-70, SH.1 M-70, SH.1 Diagram of Cont. Air Monitoring Sampling
& Equipment Vent System M-71 M-71 Diagram of Service Air M-74, SH.1,3 & 4 M-529, SH.1,2&3 Diagram of Nuclear Sample System (Primary)
M-84, SH.1 M-84, SH.1 Diagram of Heating System Hot Water M-87 M-87 Diagram of Waste Drain System j
M-93 M-527 Diagram of Penetration & Support Cooling M-536 M-537 Diagram of Containment Purge & Relief System M-793 M-794 Diagram of Reactor Vessel Level System M-956 M-959 Diagram of Reactor Vessel Head Vent System i
COE-275-012 4-2 Revision 0 i
Zion Station 3rd Interval inservice Inspction Plan Units 1 & 2 Inservice Inspection Summary Table (Page 1 of 7)
Examination Itan Description Exam Relief T-chnical Category Number Requirenents Request Approach &
(
Position B-A Bl.11 Circumferential Shell Welds, Reactor Vessel Volumetric Pressure Bl.12 1.ongitudinal Shell Welds, Reactor Vessel Volumetric
. Retaining Welds Bl.21 Circumferential IIead Welds, Reactor Vessel Volumetric in Reactor Vessel Bl.22 Meridional llead Welds, Reactor Vessel Volumetric Bl.30 Shell-to-Flange Weld, Reactor Vessel Volumetric Bl.40 liead-to-Flange Weld, Reactor Vessel Volumetric &
Surface B-B B2.11 Circumferential Shell-To-11ead Welds, Pressurizer Volumetric Pressure B2.12 Longitudinal Shell-To-IIead Welds, Pressurizer Volumetric in V s
r Than Reactor Vessels B2.40 Tube Sheet-To-licad Weld, Steam Generator Volumetric B-D B3.90 Nozzle-to-Vessel Welds, Reactor Vessel Volumetric CR-18 Full Penetration B3.100 Nozzle Inside Radius Section, Reactor Vessel Volumetric CR-18 Welds of B3.110 Nozzle-to-Vessel Welds, Pressurizer Volumetric CR-01 (U-2 only)
Nozzles in Vessels B3.120 Nozzle Inside Radius Section, Pressurizer Volumetric CR-02 B3.140 Nozzle Inside Radius Section, Steam Generator Volumetric COE-275-012 5-1 Revision 0
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Zion Station 3rd Interval Inservice Inspection Plan Units 1 & 2 Inservice Inspection Sununary Table (Page 2 of 7)
Examination Itan Description Exam Relief Technical Category Number Requirements Request Approach &
Position B-F B5.10 Dissimilar Metal Nozzle-to-Safe End Butt Welds Volumetric &
CR-17 NPS 4 or Larger, Reactor Vessel Surface CR-18 Pressure Retaining B5.40 Dissimilar Metal Nozzle-to-Safe End Butt Welds Volumetric &
Dissimilar Metal NPS 4 or Larger, Pressurizer Surface Welds B5,70 Dissimilar Metal Nozzle-to-Safe End Butt Welds Volumetric &
CR03 NPS 4 or Larger, Steam Generator Surface B-G-1 B6.10 Reactor Vessel Closure IIead Nuts Surface CR-19 Pressure B6.20 Reactor Vessel Closure Studs, in place Volumetric e' n E B6.30 Reactor Vessel Closure Studs, when Removed Volumetric &
g9;
"'I*'*
Than 2 in.
in Diameter B6.40 Threads in Reactor Vessel Flange Volumetric B6.50 Reactor Vessel Closure Washers, Bushings Visual, VT-1 B6.180 Bolts & Studs in Pumps Volumetric B6.190 Flange Surface, When Connection Disassembled, in Pumps Visual, VT-1 B6.200 Nuts, Bushings, & Washers in Pumps Visual, VT-1 B6.210 Bolts & Studs in Valves Volumetric B6.220 Flange Surface, When Connection Disassembled in Valves Visual, VT-1 B6.230 Nuts, Bushings, & Washers in Valves Visual, VT-1 COE-275-012 5-2 Revision 0
-Zion Station 3rd Interval Inservice Inspection Plan Units I & 2 Inservice Inspection Summary Table (Page 3 of 7)
Examination item Description Exam Relief Technical Category Number Requiranents Request Approach &
Position B-G-2 B7.20 Bolts, Studs, & Nuts in Pressurizer Visual, VT-1 Pressure B7.30 Bolts Studs & Nuts in Steam Generator Visual VT-1 B7.50 Bolts. Studs, & Nuts in Piping Visual, VT-1 Bol reater Than 2 in.
B7.60 Bolts Studs. & Nuts in Pumps Visual, VT-1 in Diameter B7.70 Bolts. Studs, & Nuts in Valves Visual, VT-1 B?. 80 Bolts, Studs, & Nuts in CRD liousings Visual, VT-1 B-J B9.1i Circumferential Welds in Piping Volumetric &
CR-04 -05 Pressure NPS 4 or Larger Surface Retaining Welds in Piping B9.12 lamgitudinal Welds in Piping Volumetric &
CR-04, -06 NPS 4 or Larger Surface B9.21 Circumferential Welds in Piping Surface CR-Gi Less than NPS 4 B9.31 Branch Pipe Connection Welds Volumetric &
CR-04, -07 NPS 4 or Larger Surface B9.32 Branch Pipe Connection Welds surface CR-04 less than NPS 4 B9.40 Socket Welds Surface CR-04 B-L-1 B12.10 Pump Casing Welds Volumetric CR-08 Pressure Retaining Welds in Pump Casings B-L-2 B12.20 Pump Casings Visual, VT-3 Pump Casings COE-275-012 5-3 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan -
Units 1 & 2 Inservice Inspection Summary Table (Page 4 of 7)
Examination item Description Exam Relief Technical Category Number Requimnents Request Appruach &
Position B-M-2 B12.50 Valve Bodies, Exceeding NPS 4 Visual VT-3 Valve Bodies B-N-1 B13.10 Vessel Interior Visual, VT-3 Interior of Reactor Vessel B-N-2 B13.50 Interior Attachments within Beltline Region in Reactor Vessel Visual, VT-1 Integrally Welded Core Bl3.60 Interior Attachments beyond Beltline Region in Reactor Vessel Visual, VT-3 Support Structures and Interior Attachments to Reactor Vessels B-N-3 B13.70 Core Support Structure in Reactor Vessel Visual, VT-3 Removable Core Support Structures B-O B 14.10 Welds in CRD llousing Volumetric or Pressure Surface Retaining Welds in Control Rod flousings B-Q B16.20 Steam Generator Tubing in U-Tube Design Volumetric CT-05 Steam Generator Tubing COE-275-012 5-4 Revision 0
Zion Station 3rd Intetval
'Inse:vice Inspection Plan Units 1 & 2 Inservice Inspection Suminary Table (Page 5 of 7)
Examination Itein Description Exam Relief Technical Category Number Requirements Request Approach &
Position C-A Cl.10 Shell Circumferential Welds Volumetric Pressure Retaining Cl.20 liead Circumferential Welds Volumetric CR-09 Welds in Pressure Vessels C1.30 Tubesheet-To-Shell Welds Volumetric CR-09 C-B C2.21 Nozzle-to-Shell (or liead) in Vessels without Reinforcing Plate, Surface &
CR-10 Pressure
> l/2" Nominal nickness Volumetric Retaining Nozzle Welds C2.22 Nozzle Inside Radius Section in Vessels without Reinforcing Volumetric in Vessels Plate, > I/2" Nominal nickness C-C C3.10 Integrally Welded Attachments to Pressure Vessels Surface Integral Attachments for C3.20 Integrally Welded Attachments to Piping Surface Vessels, Piping,
- P** and C3.30 Integrally Welded Attachments to Pumps Surface y,g,
C-F-1 C5.11 Circumferential Welds in Austenitic Stainless Steel or fligh Volumetric &
Pressure Alloy Piping 2 3/8" Nominal Wall Thickness for Piping >
Surface Retaining Welds NPS 4 in Austenitic Stainless Steel C5.12 longitudinal Welds in Austenitic Stainless Steel or liigh Alloy Volumetric &
CR-11 or liigh Alloy Piping 2 3/8" Nominal Wall Thickness for Piping > NPS 4 Surface Piping C5.21 Circumferential Welds in Austenitic or fligh Alloy Piping Volumetric &
> l/5 in. Nominal Wall Thickness for Piping 2 NPS 2 and Surface s; NPS 4 C5.30 Socket Welds Surface C5.41 Pipe Branch Connections of Branch Piping 2 NPS 2, Surface CR-12 Circumferential Weld C5.42 Pipe Branch Connections of Brr.nch Piping 2 NPS 2, Surface CR-11 i Longitudinal Weld COE-275-012 5-5 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan Units 1 & 2 Inservice Inspection Stuninary Tnble (Page 6 of 7) l Examination item Description Exam Relief Technical Category Number Rettuirements Request Approach &
Position C-F-2 C5.51 Circumferential Welds in Carbon or Low Alloy Volumetric &
Pressure Steel Piping 2 3/8" Surface Retaining Nominal Wall Thickness for Piping > NPS 4 Welds in Carbon or Low Alloy C5.52 Longitudinal Welds in Carbon or Low Alloy Volumetric &
CR-ll Steel Piphig Steel Piping 2 3/8* Nominal Wall Thickness Surface for Piping > NPS 4 C5.81 Circumferential Welds in Carbon or Low Alloy Surface CR-12 Steel Piping. Branch Connections of Branch t
Piping > NPS 2 C5.82 Longitudinal Welds in Carbon or Low Alloy Volumetric &
CR-11 Steel Piping, Branch Connections of Branch Surface Piping > NPS 2 C-G C6.10 Pump Casing Welds Surface Pressure Retaining Welds in Pumps l
t and Valves D-A DI.10 -
Integral Attachments - Component Supports Visual, VT-3 Systems in Support DI.60 of Reactor Shutdown Function l
D-B D2.20 -
Integral Attachments - Component Supports Visual, VT-3 Systems in Support D2.60 of Emergency l
Core Cooling, l
Containment Ilent l
- Removal, Atmosphere Cleanup, and Reactor Residual 11 eat Removal i
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Zion Station 3rd Interval-Inservice Inspection Plan Units 1 & 2 Inservice Inspection Summary Table (Page 7 of 7)
L Examination Item Description Exam Relief Technical Category Number Requirements Request Approach &
Position D-C D3.20 -
Integral Attachments - Component Supports Visual, VT-3 Systems, in D3.60 Support of Residual IIcat Removal from Spent Fuel Storage Pool F-A Fl.10 Class 1 Piping Supports Visual. VT-3 Supports F1.20 Class 2 Piping Supports Visual. VT-3 F1.30 Class 3 Piping Supports Visual, VT-3 Fl.40 Supports Other *Ihan Piping Supports Visual. VT-3 IWF-5000 Code Class Snubbers, examination per IWF-5300(a)
Visual. VT-3 Snubbers Testing per CR-15 i
Code Class Snubbers, testing per IWF-5300(b)
OMa-1988. Part 4 l
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COE-275-012 5-7 Revision 0 l
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i Zion Station 3rd Interval Inservice Inspection Plan 1
INSERVICE INSPECTION TECIINICAL APPROACII AND POSITION INDEX/SUA1A1 ARIES Position Page(s)
Summary CT-01 6-2 Preparation of Inservice Inspection Summary Reports CT-02 6-3 Class 2 and 3 Components Exempt from Examination CT-03 6-4 Use of Existing Calibration Blocks for Ultrasonic Examination of Class 1 and 2 Components CT-04 6-5 Weld Reference System CT-05 6-6 Steam Generator Tubing Acceptance Criteria CT-06 6-7 Additional Examinations of Class 1 and 2 Components I
COE-275-012 6-1 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan
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TECIINICAL APPROACII AND POSITION NUMBER: CT-01 (Page 1 of 1)
COMPONENT IDENTIFICATION Code Class:
1 and 2 i
Reference:
IWA-6220(c)
Examination Category:
Not Applicable Item Numbers:
Not Applicable
==
Description:==
Preparation of Inservice Inspection Summary Reports l
CODE REOUIREMENT IWA-6220(c) states Inservice inspection summary reports shall be prepared at the completion i
of each inspection conducted during a refueling outage. Examinations, tests, replacements, and repairs conducted since the preceding summary report shall be included."
POSITION The primary purpose ofinservice inspection summary reports is to document 1) the examinations and tests performed as required by the Inspection Plan, 2) the results of these examinations and tests, and 3) the repairs, replacements, and corrective measures taken in response to the results of these examinations and tests.
In addition to 1), 2), and 3) above, repairs and replacements that are the result of plant modifications, planned component change outs, and routine maintenance are also required to be included on Form NIS-2 per IWA-4000 and IWA-7000, but have no relationship to repairs, replacements or corrective measures taken in response to the results of required Section XI examinations and tests.
Zion Station position is that only Form NIS-2s which document repairs and replacements resulting from Section XI inservice examinations and tests will be included in the ISI Summary Reports.
7 ion Station will maintain records including NIS-2 forms, as required by IWA-4000 and IWA-7000 for repairs and replacements resulting from activities other than required inservice inspection examinations and tests.
COE-275-012 6-2 Revision 0 i
Zion Station 3rd Interval Inservice Inspection Plan TECIINICAL APPROACII AND POSITION NUMBER: CT-02 (Page 1 of 1)
COMPONENT IDENTIFICATION Code Class:
2 and 3
Reference:
IWC-1220 IWD-1220 i
==
Description:==
Components Exempt from Examination CODE REOUIREMENTS IWC-1220, Components Exempt from Examination and IWD-1220, Items Exempt from l
Examination detail the Class 2 and Class 3 components which are not required to be examined per Tables IWC-2500-1 and IWD-2500-1, respectively.
POSITION When evaluating Class 2 and Class 3 components per IWC-1220 and IWD-1220, respectively, components Exempt from Examination, the phrase " components that are NPS 4 and smaller" will be understood to mean that vessels, pumps, valves and other components with cumulative inlet piping of 4 NPS and less and cumulative outlet piping of 4 inch NPS and less are exempt from the examinations of Tables IWC-2500-1 and Table IWD-2500-1, except Class 2 components in the High Pressure Safety Injection System and Class 3 components in the Auxiliary Feedwater System.
This position is consistent with the exemption of piping NPS 4 and less because fluid loss due to failure of vessels, pumps, valves and other components connected by NPS 4 piping and smaller would not exceed the capacity of the NPS 4 piping.
This position is also supported by Code Case N-408-2, which states:
"(a)(2) vessels, pumps, and valves and their connections in piping NPS 4 and smaller in all systems except high pressure safety injection systems of pressurized water reactor plants."
In piping is defined in N-408-2 as having a cumulative inlet and a cumulative outlet pipe cross-sectional area neither of which exceeds the nominal OD cross-sectional area of the designated size.
Case N-408-2 is approved for use in Regulatory Guide 1.147, Revision 10.
i COE-2754)12 6-3 Revision 0 I
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Zion Station 3rd Interval Inservice Inspection Plan TECIINICAL APPROACII AND POSITION NUMBER: CT-03 j
(Page1of1)
COMPONENT IDENTIFICATION Code Class:
I and 2
Reference:
IWA-2232 Appendix I, I-2200 i
Appendix III, 111-3411 Examination Categories:
B-F, B-G-1, B-J, C-F-1, C-F-2
~
Item Numbers:
B5.10, B5.130, B6.40, B9.ll, B9.12, B9.31, C5.11, i
C5.12, C5.51, C5.52
==
Description:==
Use of Existing Calibration Blocks for Ultrasonic Examination of Class 1 and 2 Components i
CODE REOUIREMENTS IWA-2232 states that ultrasonic examination shall be conducted in accordance with Appendix I.
Appendix I, I-2200 states that ultrasonic examination of vessel welds less than 2 inches thick and all piping welds shall be conducted in accordance with Appendix III, as supplemented by Appendix I.
Appendix III, III-3411 outlines the material specification requirements for calibration blocks.
It basically requires calibration blocks to be fabricated from the same material specification as the piping being joined by the weld. It also states that if material of the same specification is not available, material of similar chemical analysis, tensile properties, and metallurgical structure may be used.
POSITION It is the position of Zion Station to use the currently existing calibration blocks at Zion Station.
These standards were designed and manufactured to the applicable Edition of Section XI at the time of manufacture.
Future calibration blocks will be manufactured in accordance with the 1989 Edition of Section XI.
l COE-275-012 6-4 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan TECIINICAL APPROACII AND POSITION NUMBER: CT-04 (Page1of1)
COMPONENT IDENTIFICATION Code Class:
I and 2
Reference:
IWA-2600 Examination Category:
Not Applicable Item Numbers:
Not Applicable
==
Description:==
Weld Reference System f
CODE REOUIREMENTS IWA-2610 states a reference system shall be established for all welds and areas subject to surface or volumetric examination.
Each such weld and area shall be located and identified by a system of reference points. The system shall permit identification of each weld, location of each weld center line, and designation of regular intervals along the length of the weld.
POSITION r
i It is Zion Station's position to continue using the present weld identification method. This is
~
accomplished by procedurally describing datum or reference points such that subsequent relocation of the examination area can be repeatedly achieved. Experience has shown this method to be adequate in describing examinations and results. This system and procedure for identifying welds meets the intent of both Section XI and V.
h COE-275-012 6-5
- Revision 0
Zion Station 3rd Interval Inservice Inspection Plan TECIINICAL APPROACII AND POSITION NUMBER: CT-05 (Page 1 of 1)
COMPONENT IDENTIFICATION Code Class:
1
Reference:
Table IWB-2500-1 Examination Category:
B-Q Item Numbers:
B16.20 l
==
Description:==
Standards for Examination Category B-Q, Steam Generator l
Tubes 1
CODE REOUIREMENTS 1
Table IWB-2500-1 requires that the acceptance standards of IWB-3521 be employed for the volumetric examinations of the steam generator tubing with U-tube design.
l POSITION Zion Station will utilize the acceptance criteria stated in the Plant Technical Specifications. This criteria is identical to the acceptance standards of IWB-3521. This position is consistent with 10CFR50.55a(b)(2)(iii).
i l
COE-275-012 6-6 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan TECIINICAL APPROACII AND POSITION NUMBER: CT-06 (Page 1 of 2)
COMPONENT IDENTIFICATION Code Class:
I and 2
Reference:
IWB-2430, IWC-2430 Examination Category / Item No.:
Various
==
Description:==
Additional Examinations of Class 1 and 2 Components CODE REOUIREMENTS IWB-2430 Additional Examinations (a)
Examinations performed in accordance with Table IWB-2500-1 that reveal indications exceeding the acceptance standards of Table IWB-3410-1 shall be extended to include additional examinations at this outage The additional examinations shall include the remaining welds, areas, or parts' included in the inspection item listing and scheduled 2
for this and the subsequent period.' If the examinations for that inspection item are not scheduled in the subsequent period, the most immediate period containing scheduled examinations shall be taken as the subsequent period.
(b)
If the additional examinations required by (a) above reveal indications exceeding the acceptance standards of Table IWB-3410-1, the examinations shall be further extended to include additional examinations at this outage. The additional examinations shall i
include all the welds, areas, or parts of similar design, size, and function.
(c)
For the inspection period following the period in which the examinations ~of (a) or (b) above were completed, the examinations shall be performed as normally scheduled in accordance with IWB-2400.
' Welds, areas, or parts are those described or intended in a particular inspection item of Table IWB-2500-1.
2An inspection item, as listed in Table IWB-2500-1, may comprise a number of welds, L
areas, or parts of a component required to be examined in accordance'with the inspection plan and schedule (IWA-2420).
$The subsequent period is the next following period, even if it is in the following interval.
COE-275-012 6-7 Revision 0
)
Zion Station 3rd Interval Inservice Inspection Plan j
TECIINICAL APPROACII AND POSITION NUMBER: CT-06 (Page 2 of 2)
CODE REOUIREMENTS (cont'd)
IWC-2430 Additional Examinations (a)
Examinations that detect indications exceeding the allowable standards of IWC-3000 shall be extended to include an additional number of components (or areas) within the same examination category, approximately equal to the number of components (or areas) examined initially during the inspection.
(b)
If these additional examinations detect further indications exceeding the allowable standards of IWC-3000, the remaining number of similar components (or areas) within the same examination category shall be examined to the extent specified in Table IWC-2500-1.
POSITION Zion Station interprets this requirement to be limited to service-induced flaws or flaws that were present during construction and have exhibited service induced growth. Flaws which are construction-related and have not exhibited any growth will not require additional examinations.
Zion Station, upon concurrence with jurisdictional authorities, may substitute additional examinations of components with those with similar susceptibility of service induced indications such as corresponding welds or components of multiple streams in lieu of the above requirements.
The purpose of this position is to eliminate unnecessary inspections which result when: Sample expansion occurs due to non-service related indications which, in general, are unique to a single component; and when sample inspections include components not similarly susceptible to the same service related indication as the component with the original indication. For example, including a stainless steel pipe in the expansion which resulted from an indication in a carbon steel pipe. With this methodology for sample expansion, Zion Station hopes to reduce radiation exposure to plant personnel while performing sample expansions that will find :.ervice induced flaws in components.
i COE-275-012 6-8 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan INSERVICE INSPECTION RELIEF REQUEST INDEX/ SUMMARIES Relief Request Page(s)
Summary CR-01 7-3 to 7-8 Inspection of Pressurizer Surge Nozzle to Vessel Weld CR-02 7-9 to 7-13 Inspection of Pressurizer Lower Head Nozzle Inner Radius Sections CR-03 7-14 Inspection of Steam Generator Nozzle-to-Safe End Welds CR-04 7-15 to 7-16 Selection of Class 1 Piping Welds for Examination CR-05 7-17 Inspection of Reactor Coolant Loop Circumferential Piping Welds l
CR-06 7-18 Inspection of Reactor Coolant Loop I_ongitudinal Piping Welds CR-07 7-19 Inspection of Branch Pipe Connection Welds NPS 4 and Larger CR-08 7-20 to 7-22 Reactor Coolant Pump Casing Welds CR-09 7-23 Inspection of Regenerative Heat Exchanger Circumferential Welds CR-10 7-24 Inspection of Main Steam Nozzle-to-Shell Welds CR-11 7-25 Inspection of Class 2 Longitudinal Piping Welds CR-12 7-26 to 7-28 Inspection of Branch Pipe Connections Designed with Reinforcement Saddles CR-13 7-29 to 7-30 Alternative Rules for Insulation Removal at l
Bolted Connections CR-14 7-31 to 7-32 Alternative Rules for Corrective Action Resulting from Leakage at Bolted Connections CR-15 7-33 to 7-34 ISI of Snubbers Included in the Technical i
Specification Snubber Testing and Visual Examination Programs CR-16 7-35 to 7-36 Successive Examinations of Class 1 and 2 Vessels i
CR-17 7-37 to 7-38 Inspection of Reactor Vessel Nozzle to Safe End Butt Welds i
COE-275-012 7-1 Revision 0
Zion Station 3rd Interval l
Inservice Inspection Plan INSERVICE INSPECTION RELIEF REQUEST INDEX/ SUMMARIES Relief Request Page(s)
Summary CR-18 7-39 Alternate Rules for the Deferral of Inspections of Nozzle-to-Vessel Welds, Inside Radius Sections and Nozzle-to-Safe End Welds of Reactor Vessels CR-19 7-40 Use of Alternative Examination Requirements, Examination Method and Acceptance Criteria for Reactor Vessel Closure Head Nuts i
P t
,i COE-275-012 7-2 Revision 0
i Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-01 (Page 1 of 6)
COMPONENT IDENTIFICATION Code Class:
1
References:
IWB-2500 Table IWB-2500-1 Examination Category: B-D Item Number:
B3.110
==
Description:==
Inspection of Pressurizer Surge Nozzle to Vessel Weld CODE REOUIREMENT IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.
1 Table IWB-2500-1 requires a volumetric examination to be performed on the pressurizer nozzle-to-vessel l
welds each inspection interval.
BASIS FOR RELIEF Relief is requested on the basis that compliance with the Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
i Zion Unit 1 pressurizer nozzles are integrally cast with the vessel heads, thus there are no welds in this category requiring examination. Zion Unit 2 pressurizer nozzles are welded to the vessel heads j
(reference Figure CR.01.04).
During the Unit 21987 refueling outage, an investigation was conducted on performing surface and volumetric examinations on the Unit 2 pressurizer surge nozzle to vessel weld. The investigation entailed a study that included field verifications of component geometries and physical locations, accessibility.of the examination area, and the inspection area environment.
Insulation on the lower head of the pressurizer prohibits access needed to perform the examination of i
the surge nozzle to vessel weld. The removal of the insulation covering the lower pressurizer head will result in high radiation exposure to plant personnel.
Even if the insulation was removed, the examination coverage is reduced due to obstructions from the nozzle and heater penetrations.
A 1987 radiological survey performed in the trea of the Unit 2 lower pressurizer head found dose rates of 2.25 R/hr on contact with the surge nozzle,1.2 R/hr at 18", and 700 mR/hr in the general area. The dose rates would increase if the mirror insulation was removed.
The pressurizer has a single surge nozzle in the lower vessel head. In order to perform exams on the 1
Pressurizer surge nozzle to vessel weld, the " lower vessel head" (reference Figure CR.01.2), which is i
the optimal scanning surface, must be accessible for proper surface preparation and ultrasonic scanning.
COE-275-012 7-3 Revision 0
]
1 I
Zion Station 3rd Interval i
Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-01 (Page 2 of 6)
BASIS FOR RELIEF (cont'd)
The optimal scanning surface is not accessible since it is covered by the lower pressurizer head insulation that was not designed for removal. The impact of removing the lower head insulation is presented below.
The lower head of the pressurizer is covered by 4 inch thick multi-layered stainless steel mirror insulation which was not designed for removal. In order to remove the insulation, the 78 pressurizer heater cables would have to be disconnected (reference Figure CR-01.1 and CR-01.2). In addition, each of the 78 convection stops which are riveted to the insulation would have to be cut and removed su that the insulation could be removed over the pressurizer heaters (reference Figure CR-01.3). The radiation exposure to plant personnel for insulation removal, surface preparation, and inspection is estimated to be 53 person-rem (based on a dose rate of 1.2 R/hr).
Even if the insulation was removed, full examination coverage is not achievable. The pressurizer surge nozzle geometry limits transducer contact. Consequently, scanning on the nozzle side of the weld is impossible. The heater penetrations obstruct scanning from the shell side of the weld. The resulting coverage would only be a small percentage of the weld volume. The limited data obtained from this inspection does not provide a compensatory increase in quality and safety to justify the hazards of personnel radiation exposure to obtain the data.
i The radiological conditions for the required surge nozzle inspections would result in significant individual and cumulative radiation exposure and conflicts with Zion Station's ALARA objectives.
PROPOSED ALTERNATE EXAMINATION i
Visual examination (VT-2) will be performed after each refueling outage in accordance with the
[
requirements of IWB Category B-P and Code Case N-498. The VT-2 exams performed after each refueling outage will verify integrity of the pressurizer surge nozzle.
j t
j i
]
4 COE-275-012 7-4 Revision 0
l Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-01 (Page 3 of 6)
FIGURE CR-01.1 BOTTOM VIEW OF UNIT 2 PRESSURIZER e@@@@g@
@g@@@@
g@@@@@
g O
O g
O 1,0" I
g O
Q
@ =O g@
g g @g g Q
Surge Nozzle Q
h O@@@
g O
O@@@O f
g Heater netration ggg COE-275-012 7-5 Revision 0 i
~..
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-01
[
(Page 4 of 6)
FIGURE CR-01.2 i
ELEVATION VIEW OF UNIT 2 PRESSURIZER IIEAD CONFIGURATION WITH INSTALLED i
INSULATION AND SUPPORT SKIRT 4
$ Pressurizer
/
e'W 1
i
[
8 Debris screen
[
f f m ::
- . wv i
A
- ..p o:4 w.
. +:,:.. q f) If
/
' {}
, 'i O
[
.~~
\\
f Head i
insulation 8' i
"' * * # ( D ')
Blend region
[
i i
i lp;;
- 2,l j
i i
Wh
- j. s k
i Nozzle h
insulation
~
7 ii li ll r
iI iI i
i l
COE-275-012 7-6 Revision 0 i
l
. _ =. _ - - - -
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-01 (Page 5 of 6) i FIGURE CR-01.3 l
ELEVATION AND BOTTOM VIEWS OF A TYPICAL CONVECTION STOP FOR A PRESSURIZER HEATER r
i C ^
\\l 1.1350 Immersion Heater Pipe I
i s
e i
i Outer Case l
l t
0 l
v I
Pop-Rivet
{
Washer i
t Sliding Convection Stop (78 Required)
Field Install l
/
s l
- -4q
- -t From Vessel Center
\\
,/
l N-j
\\ _
' Pivot Point For Seal j
i I
i COE-275-012 7-7 Revision 0 l
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-01 (Page 6 of 6)
FIGURE CR-01.4 PRESSURIZER NOZZLE-TO-VESSEL WELD Cladding b
/
s
/
N 5
/
/
Nozzle-to-Vessel Weld I
s
/
5 f.
COE-275-012 7-8 Revision 0
I Zion Station 3rd Interval -
Inservice Inspection Plan l
RELIEF REQUEST NUMBER: CR-02 (Page 1 of 5) l i
COMPONENT IDENTIFICATION Code Class:
1 i
References:
~
l i
Table IWB-2500-1 Examination Category: B-D i
Item Number:
B3.120
==
Description:==
Inspection of Pressurizer Lower Head Nozzle Inner Radius Sections Component Numbers: Unit 1: 1RC002 Unit 2: 2RC002 i
CODE REOUIREMENT IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.
Table IWB-2500-1 requires a volumetric examination to be performed on the inner radius section of all pressurizer nozzles each inspection interval.
BASIS FOR RELIEF Reliefis requested on the basis that compliance with the Code requirement would result in hardship or j
unusual difficulty without a compensating increase in the level of plant quality and safety.
i Insulation on the lower head of the pressurizer prohibits access needed to perform the examination of the surge nozzle inside radius section. The removal of the insulation covering the lower pressurizer head will result in high radiation exposure to plant personnel.
A 1987 radiological survey performed in the area of the Unit 2 lower pressurizer head found dose rates' of 2.25 R/hr on contact with the surge nozzle,1.2 R/hr at 18", and 700 mR/hr in the general area. ' The dose rates would increase if the mirror insulation was removed.
I The pressurizer has a single surge nozzle in the lower vessel head. In order to perform exams on the j
pressurizer surge nozzle inside radius, the " blend region" (reference Zion Figure CR-02.2), which is the optimal scanning surface, must be accessible for proper surface preparation and ultrasonic scanning.
-[
The blend region is not accessible since it is covered by the lower pressurizer head insulation that was not designed for removal. Zion Station investigated the impact of removing the lower head insulation, i
as well as, the possibility of conducting a limited exam by removing the surge nozzle insulation and scanning on the nozzle surface. The results' of these investigations are presented below.
t COE-275-012 7-9
- Revision 0 t
6
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-02 (Page 2 of 5)
BASIS FOR RELIFII(cont'd)
The lower head of the pressurizer is covered by 4 inch thick multi-layered stainless steel mirror insulation which was not designed for removal. In order to remove the insulation, the 78 pressurizer heater cables would have to be disconnected (reference Figures CR-02.1 and CR-02.2). In addition, each of the 78 convection stops which are riveted to the insulation would have to be cut and removed so that the insulation could be removed over the pressurizer heaters (reference Figure CR-02.3). The radiation exposure to plant personnel for insulation removal, surface preparation, and inspection is estimated to be 53 person-rem (based on a dose rate of 1.2 R/hr).
Insulation covering the pressurizer surge nozzle can be removed. However, the " blend region" will still not be accessible to allow for adequate surface preparation and inspection. A limited exam is possible if ultrasonic scanning is conducted from the nozzle. However, due to the complex geometry of the nozzle, the resulting coverage would provide very limited data from which to assess the condition of the pressurizer surge nozzle inside radius. The estimated radiation exposure for insulation removal, surface preparation, and to perform the scan from the nozzle would be 4.0 person-rem (based on a dose rate of 1.2 R/hr). The limited data obtained from this inspection does not provide a compensatory increase in quality and safety tojustify the hazards of personnel radiation exposure received to obtain the data.
The radiological conditions for the required surge nozzle inspections would result in significant individual and cumulative radiation exposure and conflicts with Zion Station's ALARA objectives.
PROPOSED ALTERNATE EXAMINATION Visual examination (VT-2) will be performed after each refueling outage in accordance with the requirements of IWB Category B-P and Code Case N-498.
The VT-2 exams performed after each refueling outage will verify integrity of the pressurizer surge nozzle.
i i
l l
4 i
COE-275-012 7-10 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-02 (Page 3 of 5)
FIGURE CR-02.1 BOTFOM VIEW OF UNIT 2 PRESSURIZER
@g@@@O g@
@g@@@@
g @ @ @ @@
U@
p g
t o-1T g@
g V
U =@
as' O
Surge h
@g g@ @ @ @ Nozzle
@ @@ggg@
ueaer nerauon cos-275-012 7-11 Revision o
Zion Station 3rd Interval inservice Inspection Plan RELIEF REQUEST NUMBER: CR-02 (Page 4 of 5)
FIGURE CR-02.2 ELEVATION VIEW OF UNIT 2 PRESSURIZER HEAD CONFIGURATION MTTIIINSTALLED INSULATION AND SUPPORT SKIRT
$ Pressurizer I
/
Debris screen h
- [
- W:M*
2 h -i
/y.:.n.2
, /
g,D;,g' 7f
/
1 T~7:
l,y ri
- f
' \\ ~~ ' ~ /r
[. n f
Head i
Heater (Typ.)
i"*"l"ti " "
l Blend region lll l
gh Nozzle J h
m m, (
insulation her
/
1 ll il ll l
ll COE-275-012 7-12 Revision 0 l
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-02 I
(Page 5 of 5) i FIGURE CR-02.3
?
ELEVATION AND BOTTOM VIEWS OF A TYPICAL CONVECTION STOP FOR A PRESSURIZER IIEATER -
C hi 1.1350 Immersion Heater Pipe
,N l
Outer Case l
l i
8 0
s v
Washer Pop-Rivet I
Sliding Convection i
.Stop (78 Required).
,,.-s Field Install i
i s
\\
/
l 7
, - 4q
- -% From Vessel Center i
\\
j
\\
s
,i N_ _'
' Pivot Point For Seal t
i i
i c
I COE-275-012 7-13 Revision 0
Zion Station 3rc. Interval Inservice Inspecth n Plan RELIEF REQUEST NUMBER: CR-03 (Page 1 of 1)
COMPONENT IDENTIFICATION Code Class:
1
References:
IWB-2500 Table IWB-2500-1 Examination Category: B-F Item Number:
B5.70
==
Description:==
Inspection of Steam Generator Nozzle-to-Safe End Welds CODE REOUIREMENT IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.
- Table IWB-2500-1 requires a volumetric examination to be performed on all nozzle-to-safe end welds of the steam generator each inspection interval.
BASIS FOR RELIEF Relief is requested on the basis that full compliance with the Code requirement is impractical.
Examination of the steam generator primary nozzle safe-end to pipe welds is restricted by the nozzle geometry, surface condition, and the limited surface preparation on the pipe side of the weld. The surface on the pipe side of the weld, which is a cast elbow, is machined for a distance of approximately 3 inches from the edge of the weld. Transducer contact is limited to this distance from the edge of the weld. Examinations can be performed on the surface of the weld but are severely limited from the nozzle side by the rough, cast surface which limits transducer contact.
Due to geometric configuration and surface preparation of areas around these welds, it is impossible to obtain meaningful results for ultrasonic examinations on 100% of the Code-required volume. An estimated 80% of the required volume can be inspected. The majority of the volume which cannot be inspected consists of base metal of the tapered, machine prepared side.
The alternative examinations proposed will provide adequate assurance of the continued structural integrity and will maintain an acceptable level of safety at the plant.
PROPOSED ALTERNATE EXAMINATION Volumetric examinations to the extent practical, and visual (VT-2) examinations will be performed in addition to the Code required surface examination.
COE-275-012 7-14 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-04 (Page 1 of 2)
COMPONENT IDENTIFICATION Code Class:
1
References:
IWB-2500 Table IWB-2500-1 Examination Category: B-J Item Numbers:
B9.11, B9.12, B9.21, B9.31, B9.32, B9.40
==
Description:==
Selection of Class 1 Piping Welds for Examination Component Numbers: Various Class 1 Welds i
CODE REOUIREMENT IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.
Table IWB-2500-1, Category B-J requires that Note 1(b) be used in the selection of Class 1 piping welds for examination.
Note 1(b) states that examinations shall include all terminal ends and joints in each pipe or branch run connected to other components where the stress levels exceed the following limits under loads associated with specific seismic events and operational conditions:
(1) primary plus secondary stress intensity range of 2.4S for ferritic steel and austenitic steel (2) cumulative usage factor, U, of 0.4.
BASIS FOR RELIEF Relief is requested on the basis that the proposed alternatives would provide an acceptable level of-quality and safety.
Because Zion Station piping was designed primarily per ANSI B31.1.0-1967, the parameters S and U are not available for weld selection purposes. These parameters are ASME Section III piping design characteristics. Stress data per ANSI B31.1.0 does exist; however, correspondence to Class 1 weld locations is not evident or available in many cases. ANSI B31.1.0 does not include a cumulative usage factor parameter similar to U of ASME Section III.
By selecting all Class 1 terminal end welds and branch connections welds as discussed in the Proposed Alternate Examination section, most potentially high stressed welds should be included in the third interval weld selection.
~
This selection methodology is deemed an acceptable alternative based on the design code employed for -
Zion Class 1 piping and the stress data availability / correspondence situation described previously.
COE-275-012 7-15 Revision 0 i
i
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-04 (Page 2 of 2)
PROPOSED ALTEENATE EXAMINATION ISI Class 1 piping welds will be selected for examination such that 25% of the total welds not exempted by IWB-1220 are examined during the interval per the following criteria:
a)
All accessible terminal end welds in each pipe or branch run connected to vessels.
b)
All accessible terminal end welds in each pipe or branch run cennected to other components.
t c)
All branch connection welds.
d)
All dissimilar metal welds between combinations of:
(1) carbon or low alloy steels to high alloy steels (2) carbon or low alloy steels to high nickel alloys i
(3) high alloy steels to high nickel alloys e)
Additional piping welds so that the total number of circumferential butt welds (or branch connection or socket welds) selected for examination equals 25% of the circumferential butt welds (or branch connection or socket welds) in the reactor coolant piping system. This total does not include welds excluded by IWB-1220.
These additional welds may be located in one loop (one loop is defined for both PWR and BWR plants in the 1977 Edition).
?
COE-275-012 7-16 Revision 0 I
,m.
x v.
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-05 (Page 1 of 1) i COMPONENT IDENTIFICATION Code Class:
1
References:
IWB-2500 Table IWB-2500-1 Examination Category: B-J Item Number:
B9. Il
==
Description:==
Inspection of Reactor Coolant Loop Circumferential Piping WeMs CODE REOUIREMENT t
IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.
Table IWB-2500-1 requires a volumetric examination to be performed on 25% of the Code Class 1 circumferential welds and the adjoining I foot section of the longitudinal welds each inspection interval.
BASIS FOR RELIEF 1
Relief is requested on the basis that the proposed alternatives would provide an acceptable level of quality and safety.
The reactor coolant loop piping is made of Cast Austenitic Stainless Steel.
The metallurgical characteristics of cast and electroslag welded stainless steel materials are such that ultrasonic signals are greatly dispersed and attenuated in these media. Experience has shown that results vary greatly from plant-to-plant and weld-to-weld depending in part upon the structure of the base metal. Consequently, ultrasonic testing (UT) is currently not a consistently practical method for volumetrically examining components of this construction. These examination limitations are well documented in the industry.
Radiography is an impractical technique to use and, if applied, is not expected to provide any meaningful increase in benefit beyond the alternative presented due to the high levels of background radiation emitting from these areas.
PROPOSED ALTERNATE EXAMINATION Zion Station proposes as an alternative to the Code required volumetric examination of the circumferential welds, to perform an ultrasonic examination of the circumferential weld, to the maximum extent practical.
COE-275-012 7-17 Revision 0
'l
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-06 (Page1of1)
COMPONENT IDENTIFICATION Code Class:
1
References:
IWB-2500, Table IWB-2500-1 Examination Category: B-J Item Number:
B9.12
==
Description:==
Inspection of Reactor Coolant Loop Longitudinal Piping Welds CODE REOUIREMENT IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.
Table IWB-2500-1 requires a surface and volumetric examination to be performed on 25% of the Code Class I circumferential welds and the adjoining I foot section of the longitudinal welds each inspection interval.
BASIS FOR RELIEF Relief is requested on the basis that the proposed alternatives would provide an acceptable level of quality and safety.
Each of the eight reactor coolant loops at Zion Station include two 90 elbows which are fabricated by an electroslag welding process joining the two stainless steel, cast halves.
These elbows are circumferentially welded to other cast, stainless steel components in the loops.
The metallurgical characteristics of cast and electroslag welded stainless steel materials are such that ultrasonic signals are greatly dispersed and attenuated in these media. Experience has shown that results vary greatly from plant-to-plant and weld-to-weld depending in part upon the structure of the base metal.
Consequently, ultrasonic testing (UT) is currently not a consistently practical method for volumetrically examining components of this construction.
In addition to the examination difficulties encountered due to material characteristics, the Code required examination of a 1 foot section of the adjoining longitudinal welds is impractical based on the plant safety benefit the exam provides.
The area of a longitudinal seam weld which is most susceptible to failure is that portion immediately adjacent to the circumferential weld. During the circumferential welding process, this area is most likely to undergo material and configuration changes, resulting in flaw development and potential failure. This critical area is examined during the volumetric scans of the circumferential weld.
PROPOSED ALTERNATE EXAMINATION As an alternate examination, surface and volumetric examinations will be performed on the portion of the longitudinal weld included in the examination volume of the associated circumferential welds (as necessary to meet the 25% sampling criteria). Ultrasonic scans will be conducted to search for both transverse and parallel flaws. The resulting coverage of ultrasonic examination will be to the maximum extent practical.
COE-275-012 7-18 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-07 (Page1of1) 1 COMPONENT IDENTIFICATION Code Class:
1
References:
IWB-2500 Table IWB-2500-1 Examination Category: B-J Item Number:
B9.31
==
Description:==
Inspection of Branch Pipe Connection Welds NPS 4 and Larger CODE REOUIREMENT IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.
Table IWB-2500-1 requires a surface and volumetric examination to be performed on 25 % of the branch pipe connection welds each inspection interval.
BASIS FOR RELIEF Relief is requested on the basis that the proposed alternatives would provide an acceptable level of quality and safety.
Weld configuration and materials of construction preclude any meaningful volumetric examinations using current inspection technology. The combined Code-required surface examination and a "best effort" volumetric examination will provide assurance of continued structural integrity and will maintain an adequate level of safety.
PROPOSED ALTERNATE EXAMINATION As an alternate examination, Zion Station will perform a volumetric examination of the subject welds to the maximum extent practical.
5 l
COE-275-012 7-19 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUh1BER: CR-08 (Page 1 of 3) i COMPONENT IDENTIFICATION
[
Code Class:
1 i
References:
IWB-2500 Table IWB-2500-1 Examination Category: B-L-1 Item Number:
B12.10
==
Description:==
Reactor Coolant Pump Casing Welds r
CODE REOUIREMENT IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.
Table IWB-2500-1 requires that the pump casing welds in at least one (1) pump in each group of pumps performing similar functions in the system shall have essentially 100% of the weld length volumetrically examined during each inspection interval.
BASIS FOR RELIEF Reliefis requested on the basis that compliance with the Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Zion's Reactor Coolant Pumps are Westinghouse Model 93A and are constructed of cast stainless steel material (ASTM A-351, Grade CF8) nominally 4.5" in thickness. The top and bottom portions of the casing are joined by a single circumferential weld. The volumetric examination methods permitted are ultrasonic examination (UT) or radiographic examination (RT).
Both of these methods of examination would result in considerable hardship and provide little useful data as discussed below. In addition, the operating history of these pumps and an abbreviated materials evaluation are also provided.
The preferred method of UT from the pump exterior involves extensive weld preparation for examination. Consequently, the radiation worker exposures are very significant. The estimated '
radiation exposures for the examination and support activities are indicated below. (Note: The exposure estimates are based on surveys taken in Unit I during 1990).
Scaffolding:
3-4 person-Rem Insulation Work:
15-20 person-Rem Weld Preparation:
5-7 person-Rem Weld Examination:
3-5 person-Rem Health Physics:
1-3 person-Rem Total Exposure:
27-39 person-Rem J
COE-275-012 7-20 Revision 0
e Zion Station 3rd Interval Inservice Inspection Plan i
RELIEF REQUEST NUMBER: CR-08 (Page 2 of 3)
BASIS FOR RELIEF (cont'd) i It should be noted that the radiation exposure associated with the insulation work is most significant.
This is a result of the insulation configuration relative to the location of the casing weld. The casing weld is located in the bottom most ring of insulation panels. Since the insulation for the entire casing is supported by the lowest panel, the entire pump casing must be deinsulated to access the exterior surface of this weld. Additionally, the plant configuration in the area below the casing does not provide accessibility for the installation of temporary bracing for the casing insulation above the lowest panel.
In light of this, no external examinations have been included as proposed alternatives.
Ultrasonic examination of cast stainless steel material, particularly of this thickness, does not produce reliable or meaningful results. The ineffectiveness of the ultrasonic examination is caused by sound i
beam attenuation and beam scattering inherent to coarse grained stainless steel materials of this type.
These examination limitations are well documented in the industry.
There are two available techniques for performing radiography of the pump casing welds, conventional gamma source and the miniature linear accelerator (MINAC) developed through EPRI. The use of a conventional gamma source has had questionable success in meeting Code acceptability to obtain the best image. Poor radiograph quality primarily results from a " fog" effect created by the radiation from the pump casing and the background radiation in the vicinity of the film. Although the support and examination activities for the RT method differ slightly from those activities associated with the UT l
method, the total radiation exposure is estimated to be similar for both methods (27-39 person-rem).
i The use of MINAC requires reactor coolant pump disassembly as well as scaffolding erection / removal and insulation removal / replacement. The estimated exposure for pump disassembly is 32R based upon the ID Reactor Coolant Pump replacement performed in January 1991. An additional radiation exposure of 18-24R will be received for insulation and scaffolding. The total exposure is estimated to be 50-56R.
The industrial performance of these pump casings has proven their excellent ability to resist service induced flawing or degradation. There is no history (over 400 reactor-years) of service induced cracking failure on the interior or exterior of these components. The potential for stress corrosion.
- cracking (SCC) is minimized through proper material selection resistant to SCC and preventing the occurrence of a corrosive environment. The operating history of this material has proven its resistance to SCC. Strict control of chemicals used on these casings as well as careful water chemistry control during operation prevent the occurrence of a corrosive environment. Thus, the potential for SCC of the casing interior is minimized. The exterior of the_ casing weld is not er. posed to a corrosive environment and there is no potential for SCC on the casing exterior.
COE-275-012 7-21 Revision 0
Zion Station 3rd Interval I
Inservice Inspection Plan RELIEF REQUEST NUh!BER: CR-08 (Page 3 of 3) 1 BASIS FOR RELIEF (cont'd)
Several studies have shown that the casing material possesses good fracture toughness properties over the service life of this component. Therefore, the potential for non-ductile fracture due to thermal aging is negligible. Service induced flaws would more likely be initiated from cyclical loading mechanisms such as water hammer or fatigue. Because the reactor coolant system (RCS) is designed and operated to preclude a voiding condition in normally filled lines, there is a very low potential for water hammer.
Fatigue considerations are also addressed through design and limits on operating parameters, such as pump vibration.
The combination of the very low potential for flaw detection and the excessive radiation exposures associated with performing the Code required examination does not provide a compensating increase in pump casing weld safety, reliability or integrity commensurate with the radiation exposure to be i
expended. The implementation of the proposed alternative examinations in lieu of the volumetric examination will provide continued assurance of pump casing integrity. These conclusions are further l
supported by the excellent operating history of these pumps and the minimization of flaw initiation / propagation mechanisms on the casing interior and exterior through design and operating controls.
l EBOPOSED ALTERNATE EXA5flNATIONS l
e The following alternative examinations will be implemented:
)
1.
Perform VT-3 examination of accessible internal pump casing surfaces whenever a pump is disassembled for maintenance.
2.
Perform VT-2 examination of all pump exteriors during the system leakage test required by Table IWB-2500-1, Category B-P, Item B15.60.
3.
Perform VT-2 examination of all pump exteriors during the hydrostatic test required by Table
)
IWB-2500-1, Category B-P, Item B15.61, per Code Case N-498.
]
4.
Perform a PT examination, as a supplemental NDE method, on areas of relevant indications of cracking identified by the VT-3 examination of the casing interior.
COE-275-012 7-22 Revision 0 1
Zion Ststion 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-09 (Page 1 of 1) l COMPONENT IDENTIFICATION Code Class:
2
References:
IWC-2500 l
Table IWC-2500-1 i
Examination Category: C-A Item Number:
C1.20, C1.30
==
Description:==
Inspection of Regenerative Heat Exchanger Circumferential Welds CODE REOUIREMENT IWC-2500 states that components shall be examined and tested as specified in Table IWC-2500-1.
Table IWC-2500-1 requires a volumetric examination to be performed on the circumferential welds of the regenerative heat exchanger each inspection interval.
BASIS FOR RELIEF Relief is requested on the basis that the implementation of Code requirements is impractical.
Regenerative heat exchanger is constructed of cast stainless material. Ultrasonic examination of cast stainless steel material does not produce reliable and meaningful results. The material properties of cast stainless steel attenuate and scatter ultrasound to the degree that some examinations do not produce reliable or meaningful results. The examination limitations are well documented in the industry.
Radiography of the subject welds is also impractical to perform due to the fogging effect created by high background levels of radiation.
PROPOSED ALTERNATE EXAMINATION As an alternative, surface examinations will be performed on the circumferential welds of this -
component. These examinations will provide adequate assurance that the structural integrity and safety
~
will be maintained during this interval.
Surface indications will be evaluated per Table IWB-3514-2.
COE-275-012 7-23 Revision 0
Zion Station 3rd Intenal Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-10 (Page1of1)
COMPONENT IDENTIFICATION Code Class:
2
References:
IWC-2500 Table IWC-2500-1 Examination Category: C-B Item Number:
C2.21
==
Description:==
Inspection of Main Steam Nozzle-to-Shell Welds i
CODE REOUIREMENT IWC-2500 states that components shall be examined and tested as specified in Table IWC-2500-1.
Table IWC-2500-1 requires surface and volumetric examinations to be performed on the nozzle-to-shell weld of the steam generators each inspection interval.
BASIS FOR RELIEF Reliefis requested from performing volumetric examinations of the code required volume on the basis that implementation of the Code requirements is impractical.
Limitations exist at these welds where the nozzle geometry and surface conditions preclude ultrasonic coupling or access for the required scan length to accomplish the full volume.
PROPOSED ALTERNATE EXAMINATION As an alternative, volumetric examinations shall be performed on the maximum volume reasonably l
achievable with the current methodology.
Surface exams will be performed as required. The S
combination of both ultrasonics and surface examinations will provide both assured means for flaw detection and will maintain an adequate level of safety.
l COE-275-012 7-24 Revision 0 U
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-11 (Page 1 of 1)
COMPONENT IDENTIFICATION Coc'e Class:
2
References:
IWC-2500 Table IWC-2500-1 Examination Category: C-F-1, C-F-2 Item Number:
C5.12, C5.22, C5.42, C5.52, C5.82
==
Description:==
Inspection of Class 2 Longitudinal Piping Welds CODE REOUIREMENT IWC-2500 states that components shall be examined and tested as specified in Table IWC-2500-1.
Table IWC-2500-1 requires a surface and a volumetric examination to be performed on Class 2 longitudinal welds each inspection interval.
BASIS FOR RELIEF Relief is requested on the basis that the proposed alternatives would provide an acceptable level of quality and safety.
The area of a longitudinal seam weld which is most likely to fail is that portion immediately adjacent to the circumferential weld. During the circumferential welding process, this area is most likely to undergo material and configuration changes, resulting in flaw development and potential failure. This critical area is examined during the volumetric scans of the circumferential weld.
PROPOSED ALTERNATE EXAMINATIOE Zion Station proposes as an alternative to the Code required volumetric examination of longitudinal welds, to perform an ultrasonic examination of those portions of the longitudinal weld that fall within the examination volume of the intersecting circumferential weld. Scans will be performed for both parallel and transverse reflectors.
As an alternative to the Code required surface examinations oflongitudinal welds, surface examinations will be conducted on the portion of the longitudinal weld which falls within the examination boundary of the intersecting circumferential weld.
COE-275-012 7-25 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-12 (Page 1 of 3)
COMPONENT IDENTIFICATION Code Class:
2
References:
IWC-2500 Table IWC-2500-1 Examination Category: C-F-1, C-F-2 Item Number:
C5.41, C5.81
==
Description:==
Inspection of Branch Pipe Connections Designed with Reinforcement Saddles Component Numbers: 8" and 6" Branch Connections to the Main Steam Lines CODE REOUIREMENT IWC-2500 states that components shall be examined and tested as specified in Table IWC-2500-1.
Table IWC-2500-1 requires a surface examination to be performed on branch pipe connection welds greater than NPS 2.
BASIS FOR RELIEF Relief is requested on the basis that implementation of the Code requirements is impractical.
The design of certain branch pipe connection welds calls for the use of reinforcement saddles. These saddles are fillet welded over the actual pressure retaining branch pipe to main pipe, completely encasing it as illustrated on Figures CR-12.1 and CR-12.2. This design precludes any type of surface or volumetric examination from being performed on the pressure retaining branch connection weld.
Additional assurance of the continued integrity of these joints is afforded by the fact that the reinforcement saddle strengthens thejoint and reduces the stresses on the obstructed branch to pipe weld.
Based on the above, Zion Station requests relief from the ASME Section XI requirements for the surface examination of Class 2 branch pipe connection welds that are designed with a reinforcement saddle.
PROPOSED ALTERNATE EXAMINATION As an alternative examination, Zion Station will perform a surface examination of the saddle to main pipe weld and the saddle to branch pipe weld, when the pressure retaining weld is made inaccessible due to the use of a reinforcement saddle. Additionally, a VT-2 visual examination at the reinforcement saddle telltale hole will be performed in conjunction with the required Class 2 System Pressure Tests.
i l
COE-275-012 7-26 Revision 0 l
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-12 (Page 2 of 3)
FIGURE CR-12.1 TYPE 1 TYPICAL BRANCII CONNECTION REINFORCEMENT SADDLE P
- Fillet Welds Telltale Hole n
lI' j!!
u--
)
,/
'IuN
\\\\
(f)
Pressure Retaining Weld J
COE-275-012 7-27 Revision 0
l Zion Station 3rd Interval j
Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-12 (Page 3 of 3)
FIGURE CR-12.2 TYPE 2 TYPICAL BRANCII CONNECTION REINFORCEMENT SADDLE i
i Fillet Welds Telltale Hole o
ft.
lT' ll ll t
,/
}
i l
4 N'
i i
\\\\
[J Pressure Retaining i
Weld 1
1 i
J COE-275-012 7-28 Revision 0
)
i i
t Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-13 (Page 1 of 2)
COMPONENT IDENTIFICATION Code Class:
1
References:
IWA-5242(a)
Examination Category: B-P Item Number:
B15.10, B15.11, B15.20, B15.21, B15.30, B15.31, B15.50, B15.51, B15.60, B15.61, B15.70, B15.71
==
Description:==
Alternative Rules for Insulation Removal at Class 1 Bolted Connections CODE REOUIRE11ENT IWA-5242(a) states "For systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolted connections for visual examination VT-2."
[
BASIS FOR RELIEF t
Reliefis requested on the basis that compliance with the Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
i The removal of insulation at all pressure retaining bolted connections (e.g., piping flanges, valve 3
bonnets, CRD housings and vessel closures, etc.) in borated systems during pressure testing activities represents an undue burden to Zion Station in personnel safety and radiation exposure.
The incorporation of this requirement into the pressure testing activities represents an arbitrary and inflexible method to verify and maintain the integrity of bolted connections in borated systems.
The Class I systems borated for the purpose of controlling reactivity at Zion Station include Reactor
[
Coolant, Residual Heat Removal, Safety Injection and Chemical and Volume Control. These systems encompass a large portion of the overall ISI program. These systems physically cover a large expanse of the reactor building. Many areas in which this piping and the associated bolted connections are located are difficult to access (scaffolding and/or laddering is required) and many of these areas are such that significant radiation exposures would be encountered. In addition, the removal and installation of
~
insulation with plant equipment in operation increases the risk of personnel injury and presents a safety concern to plant personnel. Clearly, the manpower and radiation exposure is significant for the removal and reinstallation ofinsulation of these bolted connections during pressure testing activities. In addition, the incorporation of these requirements into existing procedures to perform pressure testing will unnecessarily complicate an already complex activity, as these procedures are typically an integral part of reactor startup.
Based on the previously stated reasons, Zion Station requests relief from the insulation removal requirements detailed in IWA-5242(a) for Class I components. In lieu of these requirements, Zion Station proposes the alternative examination scenario that follows.
These alternative rules will provide reasonable assurance that the safety and integrity of Class 1 bolted l
connections will be maintained.
i COE-275-012 7-29 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan i
RELIEF REQUEST NUMBER: CR-13 (Page 2 of 2)
PROPOSED ALTERNATE EXAMINATION Category B-G-1 bolting will be VT-3 examined in place with the insulation removed during each inspection period of the third interval when the unit is out of service and the systems depressurized.
Other bolted connections in borated systems will be VT-1 examined in place with the insulation removed during each inspection period of the third interval when the unit is out of service and the systems depressurized.
VT-2 examinations as required by the Code will be performed with insulation in place.
i Performance of the above VT-1 or VT-3 examinations each inspection period will assure that mmor j
boric acid leakage and accumulation will be detected in a timely manner that will not affect the integrity of plant components. Significant leakage will still be detectable by the performance of the code requried VT-2 examinations with the insulation in place.
l 3
l i
p
)
I i
a
- t COE-275-012 7-30 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan i
RELIEF REQUEST NUMBER: CR-14 (Page 1 of 2)
COMPONENT IDENTIFICATION Code Class:
1, 2 and 3
References:
IWA-5250(a)(2), IWB-2430, IWC-2430 Examination Category: N/A Item Number:
N/A
==
Description:==
Alternative Rules for Corrective Action Resulting from Leakage at Bolted Connections l
CODE REOUIREMENT IWA-5250(a)(2) states "if leakage occurs at a bolted connection, the bolting shall be removed, VT-3 visually examined for corrosion, and evaluated in accordance with IWA-3100."
IWB-2430, IWC-2430 " Additional Examinations" BASIS FOR RELIEF Relief is requested on the basis that the proposed alternatives would provide an acceptable level of i
quality and safety.
As an alternative to the requirements of IWA-5250(a)(2), Zion Station proposes the rules stated below.
These rules will provide reasonable assurance that the safety and integrity of Class 1, 2 and 3 bolted connections will be maintained.
PROPOSED ALTERNATE EXAMINATION l
As an alternative to the existing requirements, an evaluation to determine the susceptibility of the bolting to corrosion by an evaluation that considers as a minimum:
a)
Type and location of the leakage b)
Historical leakage c)
Materials of the leaking component d)
Visual evidence of corrosion e)
Corrosiveness of the process fluid f)
History of the bolt material degradation due to corrosion in similar environments g)
Other components (and materials) in the vicinity of the leaking component including consideration of leak path, insulation effects, etc.
I i
COE-275-012 7-31 Revision 0
. = _ _ _.
i i
Zion Station 3rd Interval
.l Inservice Inspection Plan i
RELIEF REQUEST NUMBER: CR-14 (Page 2 of 2) 1 If any of the above parameters indicates a need for further evaluation, the bolt closest to the source of i
leakage shall be removed, receive a VT-1 Examination, and be evaluated in accordance with IWA-3100(a). If the leakage is identified when the bolted connection is in service, and the information I
in the evaluation is supportive, the removal of the bolt for VT-1 examination may be deferred to the next refueling outage. When the removed bolt has evidence of degradation, all remaining bolting shall be
)
removed, VT-1 examined, and evaluated in accordance with IWA-3100(a).
i i
The additional examinations of IWB-2430 and IWC-2430 will not be performed unless the need is established by the above evaluation.
t i
I I
i i
i l
l i
COE-275-012 7-32 Revision 0
~
l Zion Statica 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-15 (Page 1 of 2)
COMPONENT IDENTIFICATION Code Class:
1, 2 and 3
References:
IWF-5000 Examination Category: Not Applicable Item Number:
Not Applicable
Description:
ISI of Snubbers Included In The Technical Specification Snubber Testing and Visual Examination Program CODE REOUIREMENT Preservice examination per IWF-5200(a) and Inservice examination per IWF-5300(a) in accordance with the first addenda to ASME/ ANSI OM-1987 Edition, Part 4, published in 1988 (OMa-1988 Part 4).
i Preservice testing per IWF-5200(b) and Inservice testing per IWF-5300(b)in accordance with the first addenda to ASME/ ANSI OM-1987 Edition, Part 4, published in 1988 (OMa-1988 Part 4).
10CFR50.55a, paragraph (b)(2)(viii), published August 6,1992).
f BASIS FOR RELIEF Relief is requested on the basis that the proposed alternatives would provide an accepuble level of quality and safety.
Current Zion Station Technical Specifications (TS) include comprehensive programs for visual examination and functional testing of all safety related hydraulic and mechanical snubbers. The program scope encompasses all Code Class 1,2, and 3 snubbers.
A large portion of the safety related snubbers at Zion Station are also Code Class. The overlap of the visual examination and testing programs per ASME Section XI and Technical Specifications for the i
Code Class snubbers presents an unnecessary redundancy.
j The TS snubber visual examination program and the program presented in OMa-1988, Part 4 per IWF-5200(a) and IWF-5300(a) are similar in content. Both programs include parallel criteria for operability, schedule, and sample size.
i The TS snubber testing program and the program presented in OMa-1988, Part 4 per IWF-5200(b) and 1
IWF-5300(b) are also very similar in content. Both programs include parallel requirements for operability testing. Similar requirements for testing frequency, sample size, and additional sampling for failures are also included in both programs.
Regarding testing frequency and sample size, Zion's TS Program calls for random testing of 10% of the total snubber population each refueling outage. Due to the random TS sampling,10% of the Code snubbers may or may not be tested in a given outage, as required per OMa-1988; however, each program requires a 10% sample be tested (per outage) such that over a ten outage cycle,100% of the total snubber population is tested.
[
COE-275-012 7-33 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan i
RELIEF REQUEST NUMBER: CR-I5 (Page 2 of 2)
BASIS FOR RELIEF (cont'd)
Regarding sample expansion for failures, Zion's TS Program is similar to OMa-1988, Part 4. The requirements of the Technical Specification's Program are such that for each snubber that does not meet the functional test criteria, an additional 10% of that type of snubber shall be functionally tested.
OMa-1988, Part 4 requires an additional sample lot of at least one-half the size of the initial sample to be tested until the total number tested is equal to the initial sample size multiplied by the factor 1+C/2, where C is the total number of snubbers found to be unacceptable. Zion's TS Snubber Program sample expansion criteria definition of a type follows. The similar OMa-1988, Part 4 requirements are shown in parenthesis.
1.
Snubbers from similar environments, where ' environment' takes into consideration temperature, humidity, and radiation. (Snubbers from other piping systems that have i
similar operating conditions such as temperature, humidity, vibration, and radiation.)
2.
Snubbers of similar size. (Snubbers of the same manufacturer's design.)
3.
Snubbers of the same piping system. (Snubbers from the same piping system.)
j 4.
Snubbers which were previously untested. (Snubbers which are previously untested.)
5.
Snubbers immediately adjacent to those found unacceptable. (OMa-1988, Part 4 only, not included in Technical Specifications.)
[
It is Zion Station's position that the snubber visual examination and testing programs of Technical Specification 3.22/4.22 meet the intent of the program required by OMa-1988, Part 4. No plant safety benefits will be realized by imposing both programs on the Code Class snubbers at Zion Units 1 & 2.
Based on the above, Zion Station requests relief from the ASME Section XI requirements for visual examination and testing of Code Class snubbers.
l PROPOSED ALTERNATE PROVISIONS i
)
Zion Station will perform visual examinations of Code Class snubbers in accordance with the latest j
approved revision of Station Technical Specifications in lieu of the requirements of IWF-5200(a) and IWF-5300(a).
i Zion Station will perform functional testing of Code Class 1,2 and 3 snubbers per plant Technical Specification 3.22/4.22 in lieu of the requirements ofIWF-5200(b) and IWF-5300(b). These exams will be tracked and reported per Station Technical Specifications.
J As required by IWF-5200(c) and IWF-5300(c) the examination of snubber integral and nonintegral attachments will be performed in accordance with Subsection IWF.
t i
j COE-275-012 7-34 Revision 0 4
Zion Station 3rd Interval Inservice Inspection Plan i
RELIEF REQUEST NUMBER: CR-16 (Page 1 of 2)
COMPONENT IDENTIFICATION Code Class:
1, 2
Reference:
IWB-2420, IWC-2420 Examination Category / Item No.:
Various
==
Description:==
Successive Examinations of Class 1 and 2 Vessels I
CODE REOUIREMENTS IWB-2420 Successive Inspections l
(a)
The sequence of component examinations established during the first inspection interval shall be repeated during each successive inspection interval, to the extent practical.
(b)
If flaw indications or relevant conditions are evaluated in accordance with IWB-3132.4 or i
IWB-3142.4, respectively, and the component qualifies as acceptable for continued service, the areas containing such flaw indications or relevant conditions shall be re-examined during the next three inspection periods listed in the schedules of the inspection programs of IWB-2410.
(c)
If the re-examinations required by (b) above reveal that the flaw indications remain essentially unchanged for three successive inspection periods, the component examination schedule may revert to the original schedule of successive inspections.
(d)
For steam generator tubing, the successive examinations shall be gover.ted by the plant Technical Specification.
IWC-2420 Successive Inspections (a)
The sequence of component examinations established during the first inspection interval shall be repeated during each successive inspection interval, to the extent practical.
(b)
If component examination results require evaluation of flaw indications in accordance with IWC-3000, and the component qualifies as conditionally acceptable for continued service, the areas containing such flaw indications shall be re-examined during the next iNpection period i
listed in the schedules of the inspection programs of IWC-2411 and IWC-2412.
(c)
If the re-examinations required by (b) above reveal that the flaw indications remain essentially unchanged for the next period, the component examination schedule may revert to the original schedule of successive inspections.
l COE-275-012 7-35 Revision 0
i Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-16 (Page 2 of 2)
BASIS FOR RELIEF Relief is requested on the basis that the alternatives would provide an acceptable level of quality and safety.
e
-t Industry experience has shown that most vessel flaws located durmg mservice inspection volumetric examinations are not planar or cracklike; they are embedded volumetric anomalics resulting from material manufacture or component fabrication, e.g., laminations, mid-plate segregate, slag, side-wall lack of fusion. Similarly, most of those flaws are located at mid-wall or a neutral zone with regard to 4
stresses. Analysis show these flaws to be non-propagating or benign for growth considerations. The industry's ultrasonic examination capability for flaw identification is available and can be readily demonstrated. The cost to perform out-of-interval or unscheduled examinations on benign embedded fabrication flaws are extensive and have no value added benefit with regard to safety.
PROPOSED ALTERNATE PROVISIONS As an alternate to IWB-2420 and IWC-2420, Zion Station will not perform successive examinations per IWB-2420 or IWC-2420 on vessel Daws which are determined to originate from material manufacture or fabrication subject to the following limitations:
i a)
The flaw is characterized as subsurface in accordance with IWA-3000; b)
The NDE technique and evaluation which identified the flaw as originating from I
material manufacture or fabrication is documented in the flaw evaluation report; and c)
The flaw is acceptable for continued service in accordance with IWB-3132.4,or IWC-3122.4, and demonstrated to have acceptable growth until the next scheduled inspection or the end of service lifetime of the component.
I i
i COE-275-012 7-36 Revision 0 -
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-17 (Page 1 of 2)
COMPONENT IDENTIFICATION Code Class:
1
References:
IWB-2500, Table IWB-2500-1 Examination Category: B-F Item Number:
B5.10
==
Description:==
Inspection of Reactor Vessel Nozzle to Safe End Butt Welds CODE REOUIREMENT IWB-2500 states that components shah be examined and tested as specified in Table IWB-2500-1.
Table IWB-2500-1 requires volumetric and surface examinations to be performed on all reactor vessel nozzle to safe end welds.
HASIS FOR RELIEF Relief is requested from performing surface examinations on the basis that the proposed alternatives would provide an acceptable level of quality and safety.
The outside surface of Reactor Vessel Nozzle to Safe End Butt Welds are located below shield blocks in the reactor cavity. In order to access each weld, the stainless steel reactor cavity cover plate must be removed followed by removal of the borated concrete shield plugs. Then, the insulation must be removed and the weld surface needs to be prepared.
In the past, Zion Station personnel have received approximately 1.0 R accessing, preparing, and inspecting each weld.
It is possible to perform volumetric examinations of the inner surface of these welds using the Reactor Vessel tool. It may be possible to perform volumetric examinations of the outer surface of these welds using the Reactor Vessel tool. However, examination of the outer surface may be limited because the pipe side of the safe end welds is made. of Cast Stainless Steel which has a coarse grained microstructure that is difficult to examine volumetrically. Using the Reactor Vessel tool to perform examination of these welds will result in dose savings to plant personnel.
PROPOSED ALTERNATE EXA3_JINATION i
As an alternative to the code required surface exam, Zion Station will perform a " surface equivalent" exam by performing a volumetric exam of the outer surface (See Figure CR-17.1 for inspection volume) from the inside diameter to the extent practical using the automated Reactor Vessel tool. The examination procedure will be qualified by placing a 0.05t notch in the calibration block and detecting it with the Reactor Vessel tool. If the procedure qualification is successful, Zion Station will perform the proposed alternative exam. The volumetric exam of the outer surface meets the intent of the Code required surface exam.
COE-275-012 7-37 Revision 0
l Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-17 (Page 2 of 2)
FIGURE CR-17.1 IEACTOR VESSEL NOZZLE TO SAFE END WELD 1/2 in.
1/2 in.
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EXAMINATION 1
VOLUMES:
A-B-C-D AND E-F-G-H i
COE-275-012 7-38 Revision 0 i
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: CR-18 (Page 1 of 1)
COMPONENT IDENTIFIGATION Code Class:
1
References:
IWB-2500, Table IWB-2500-1 Examination Category: B-D; B-F Item Number:
B3.90, B3.100; B5.10
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Description:==
Alternative Rules for the Deferral of Inspections of Nozzle-to-Vessel Welds, Inside Radius Sections and Nozzle-to-Safe End Welds of the Reactor Vessel i
CODE REGUIREMENT IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.
Table IWB-2500-1 does not allow the required examinations of Category B-D, Item Nos. B3.90, B3.100 (volumetric) and Category B-F, Item No. B5.10 (surface and volumetric) to be deferred to the end of the third inspection interval.
BASIS FOR RELIEF Relief is requested on the basis that the proposed alternatives would provide an acceptable level of quality and safety.
PROPOSED ALTERNATE EXAMINATION As an alternative to the existing requirements, inspections of Nozzle-to-Vessel Welds, Inside Radius Sections and Nozzle to Vessel Safe End Welds of the Reactor Vessel may be deferred to the end of an inspection interval at Zion Station if the following conditions are met for the Reactor Vessel in question:
(a)
No inservice repairs or replacements by welding have ever been performed on any of the Nozzle-to-Vessel Welds, Inside Radius Sections or Nozzle-to-Safe End Welds; l
(b)
None of the Nozzle-to-Vessel Welds, Inside Radius Sections or Nozzle-to-Safe End welds contains identified flaws or relevant conditions that currently require successive inspections in accordance with IWB-2420(b).
In addition, the inside surface of the nozzle to vessel weld and the nozzle inside radius will receive VT-3 examinations during the required Category B-N-1 exams of the Reactor Vessel Interior.
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COE-275-012 7-39 Revision 0 1
Zion Station 3rd Interval Inservice Inspection Plan i
RELIEF REQUEST NUMBER: CR-19
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(Page 1 of 1) 1 COMPONENT IDENTIFICATION Code Class:
1
Reference:
IWB-2500, Table IWB-2500-1 Examination Category:
B-G-1 Item Number:
B6.10
==
Description:==
Use of Alternative Examination Req.uirements, Examination Method, and Acceptance Standard for Reactor Vessel Closure Head Nuts.
Component Numbers:
All reactor vessel closure head nuts CODE REOUIREMENT IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.
Table IWB-2500-1 requires a surface examination to be performed on reactor vessel closure head nuts.
HASIS FOR RELIEF Table IWB-2500-1 of the 1989 Edition of ASME Section XI requires a surface examination to be performed on the reactor vessel closure head nuts. However, Table IWB-2500-1 does not provide the corresponding " Examination Requirements / Figure Number" and " Acceptance Standard".
These provisions were stillin the course of preparation.
The 1989 Edition of ASME Section XI, Category B-G-1, employs a VT-1 visual examination for nuts associated with Heat Exchangers, Piping, Pumps, and Valves (Item Numbers B6.140, B6.170, B6.200, and B6.230, respectively). These Category B-G-1 requirements also provide an Acceptance Standard, l
IWB-3517, for the VT-1 examinations. Accordingly, these rules are deemed by Zion Station as an acceptable and complete set of rules to assure the integrity of reactor vessel closure nuts.
Based on the above, Zion Station requests relief from the requirements specified in Table IWB-2500-1 of the 1989 Edition of ASME Section XI for reactor vessel closure head nuts.
PROPOSED ALTERNATE PROVISIONS r
As an alternate examination, Zion Station will perform a VT-1 visual examination of the surface of all reactor closure head nuts, utilizing the acceptance criteria of IWB-3517, as delineated in the 1039 Edition of ASME Section XI.
r COE-275-012 7-40 Revision 0 l
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Zion Station 3rd Interval Inservice Inspection Plan Units 1 & 2 System Pressure Test Sununary Table (Page 1 of 2)
Examination Item Description Exam Relief Technicri Category Number Requirements Request Approach &
Position B15.10 RPV - System Leakage Test Visual, VT-2 CR-13 B15.11 RPV - System Hydrostatic Test Visual. VT-2 B15.20 Pressurizer - System Leakage Test Visual, VT-2 CR-13 B-P B15.21 Pressuriwr - System Hydrostatic Test Visual, VT-2 All Pressure Retaining B15.30 Steam Generator - System Leakage Test Visual, VT-2 CR-13 Com nents B15.31 Steam Generator - System Hydrostatic Test Visual, VT-2 B15.40 Heat Exchangers - Steam Leakage Test Visual, VT-2 CR-13 B15.41 Heat Exchangers - System Hydrostatic Test Visual, VT-2 B 15.50 Piping - System Leakage Test Visual, VT-2 CR-13 B15.51 Piping System Hydrostatic Test Visual, VT-2 B15.60 Pumps - System Leakage Test Visual. VT-2 CR-13 B15.61 Pumps - System Hydrostatic Test Visual, VT-2 B15.70 Valves - System Leakage Test Visual. VT-2 CR-13 B15.71 Valves - System Hydrostatic Test Visual, VT-2 C-H C7.10 Pressure Vessels - System Pressure Test Visual, VT-2 All Pressure C7.20 Pressure Vessels - System Hydrostatic Test Visual, VT-2 Retaining C7.30 Piping - System Pressure Test Visual, VT-2 Comrmnents (Class 2)
C7.40 Piping - System Hydrostatic Test Visual, VT-2 C7.50 Pumps - System Pressure Test Visual, VT-2 C7.60 Pumps - System Hydrostatic Test Visual, VT-2 C7.70 Valves - System Pressure Test Visual, VT-2 C7.80 Valves - System Hydrostatic Test Visual. VT-2 COE-275-012 8-1 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan Units 1 & 2 System Pressure Test Summary Table (Page 2 of 2)
Examination item Description Exam Relief Technical Category Number Requirements Request Approach &
Position B-E B4.l l Partial Penetration Visual, VT-2 Vessel Nozzle Welds Pressure B4.12 Partial Penetration Visual, VT-2 Retaining Partial Penetration Control Rod Drive Nozzle Welds Welds in B4.13 Partial Penetration Visual, VT-2 Vessels Instrumentation Nozzle Welds B4.20 Partial Penetration Pressurizer Visual, VT-2 Heater Penetration D-B D2.10 Class 3 Pressure Retaining Components 8{ * "
- System Pressure Test Visual, VT-2 3
g of Emergency Core Cooling.
- System Ilydmstatic Test Visual, VT-2 PR-01 Containment IIeat Removal, Atmosphere Cleanup, and Reactor Residual lleat Removal D-C D3.10 Class 3 Pressure Retaining Components Systems in Support of
- System Pressure Test Visual, VT-1 Residual fleat Removal from
- System flydrostatic Test Visual, VT-1 PR-01 Spent Fuel Storage Pool COE-275-012 8-2 Revision 0
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Zion Station 3rd Interval Inservice Inspection Plan SYSTEM PRESSURE TESTING TECIINICAL APPROACII AND POSITION INDEX/ SUMMARIES Currently, there has been no need identified for Technical Positions at Zion Station covering System Pressure Testing COE-275-012 9-I Revision 0
Zion' Station 3rd Interval Inservice Inspection Plan SYSTEM PRESSURE TESTING RELIEF REQUEST INDEX/ SUMMARIES LNSERVICE INSPECTION Relief Request Page(s)
Summary l
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PR-01 10-2 to 10-3 Alternate Rules for Hydrostatic Testing of Class' 3 Components PR-02 10-4 to 10-5 Alternate Pressure Testing Requirement for Repairs, Replacements and Modifications i
I Zion Station is evaluating the implementation of Code Case N-498; To date, no
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additional relief requests have been identified. The need for relief requests will be determined as the evaluation proceeds and any additional relief requests will be submitted as they are developed.
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I COE-275-012 10-1
. Revision 0
l Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: PR-01 (Page 1 of 2)
COMPONENT IDENTIFICATION Code Class:
3
References:
IWD-2500 Table IWD-2500-1 Examination Category: D-A, D-B, D-C Item Number:
D1.10, D2.10, D3.10
==
Description:==
Alternative Rules for Hydrostatic Testing of Class 3 Components CODE REOUIREMENT IWD-2500 states that components shall be examined and pressure tested as specified in Table IWD-2500-1.
Table IWD-2500-1 requires a hydrostatic test to be performed on the pressure retaining boundary of all Class 3 systems and components each inspection interval.
l BASIS FOR RELIEF t
Relief is requested on the basis that the proposed alternatives would provide an acceptable level of quality and safety.
Recent ASME Code Committee activities have included the adoption of Code Case N-498,
" Alternative Rules for 10-Year Hydrostatic Pressure Testing for Class 1 and Class 2 Systems",
which allows a system pressure test at operating pressure to be performed in lieu of the Section XI required hydrostatic test, which is performed at higher pressures. It has been demonstrated by research conducted by the ASME Special Working Group on Pressure Testing that an elevated pressure test, as required by ASME Section XI, will neither challenge the structural integrity of the system or increase the chances of detecting leakage. Leakage signaling potential component defects were readily noticed at the operating system pressure. Code Case N-498 has been approved for use in ISI Programs in Regulatory Guide 1.147.
The ASME Boiler and Pressure Vessel Code is currently engaging in activities to provide alternative rules for pressure testing for Class 3 Systems as a logical extension of Code Case N-498. Zion Station proposes the following altemative rules, based on proposed Code Case N-498-1, as stated below.
These requirements will provide reasonable assurance that the safety and integrity of Class 3 i
components will be maintained.
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1 COE-275-012 10-2 Revision 0 i
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: PR-01 (Page 2 of 2)
PROPOSED ALTERNATE EXAMINATION Zion Station will adopt the following rules in lieu of the 10-year hydrostatic pressure test required by Table IWD-2500-1, Categories 3 A, D-B, and D-C:
(1)
A system pressure test shall be conducted at or near the end of each inspection interval or during the same inspect:on period of each inspection interval of Inspection Program B.
(2)
The boundary subject to test pressurization during the system pressure test chall extend up to and including the Erst normally closed valve or valve capable of automatic closure as required to perform the safety system function.
(3)
The system shall be pressurized to nominal operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for noninsulated systems. The system shall be maintained at normal operating pressure during the performance of the VT-2 examination.
(4)
The VT-2 viscl examination shallinclude all components within the boundary identi6ed in (2) above.
(5)
Test instrumentation specified for hydrostatic pressure test is not required.
COE-275-012 10-3 Revision 0
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: PR-02 (Page 1 of 2)
COMPONENT IDENTIFICATION Code Class:
1, 2 and 3
References:
IWA-4400, IWA-4600, IWA-4700, IWA-5214 4
Examination Category: N/A Item Number:
N/A
==
Description:==
Alternative Pressure Testing Requirement for Repairs, Replacements and Modifications CODE REOUIREMENT l
4 IWA-4700(a), Pressure Test, stater "after repairs by welding on the pressure retaining boundary, a system hydrostatic test shall be performed in accordance with IWA-5000."
IWA-5214, Repairs and Replacements, states "a component repair or replacement shall be pressure tested prior to resumption of service if required by IWA-4400 and IWA-4600.
The test pressure and temperature for a system hydrostatic test subsequent to the component repair or replacement shall comply with the system test pressure and temperature specified in IWB-5222, IWC-5222, and IWD-5223, as applicable to the system which contains the repaired or replaced component."
BASIS FOR RELIEF Relief is requested on the basis that compliance with the Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Recent ASME Code Committee activities have included the adoption of Code Case N-498,
" Alternative Rules for 10-Year Hydrostatic Pressure Testing for Class 1 and 2 Systems", which i
allows a system leakage test (IWB-5221) for Class I systems and a system pressure test (IWC-5210) for Class 2 components at operating pressure to be performed in lieu of the Section XI hydrostatic test. It has been demonstrated by research conducted by the ASME Special Working Group on Pressure Testing that an elevated pressure test, as required by Section XI, will neither challenge the structural integrity of the system or increase the-chances of detecting leakage.
Leakage signaling potential component defects were readily noticed at the operating system i
pressure. Code Case N-498 has been approved for use in ISI programs by the NRC in j
i Proposed Code Case N-416-1 " Alternative Pressure Test Requirements for Welded Repairs of Installation of Replacement Items by Welding", is under consideration for publication in the ASME Boiler and Pressure Vessel Code. Code Case'N-416-1 applies to Division 1, Class 1, j
2 and 3 components. The basis for Code Case N-416-1 is similar to that of Code Case N-498.
I COE-275-012 10-4
. Revision 0
Zion Station 3rd Interval Inservice Inspection Plan RELIEF REQUEST NUMBER: PR-02 (Page 2 of 2)
BASIS FOR RELIEF (cont'd)
Zion Station requests relief from the current Section XI rules for hydrostatic testing of Repairs, Replacements, and Modifications, for Class 1,2, and 3 components and proposes to apply the alternative requirements derived from proposed Code Case N-416-1 as stated below.
l These alternative examinations will provide sufficient information to assure the safety and reliability of ASME Code piping and vessels and will not adversely affect the safety or integrity of the plant.
PROPOSED ALTERNATE EXAMINATIONS l
Zion Station will follow the alternative requirements stated below, based on proposed Code Case f
N-416-1, in lieu of the hydrostatic pre-ssure test requirements stated in IWA-4000.
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1.
NDE shall be performed in accordance with the Original Code of f
Construction.
2.
Additional NDE shall be performed in accordance with the methods and acceptance criteria of the 1989 Edition of Section III in instances where the 1989 Edition of Section III states methods and acceptance criteria beyond those stated in the Original Code of Construction. In addition, UT will be performed on Class 1 full penetration corner welded nozzles, branch, and piping connections.
3.
Prior to or immediately upon return to service, a VT-2 examination shall be performed in conjunction with a system leakage test at nominal operating pressure. The system shall be pressurized at nominal operating pressure for at least four hours for insulated systems and 10 minutes for noninsulated systems.
4.
The use of this relief request will be documented for specific repairs, replacements, or modifications on the NIS-2 form.
In cases where this relief request is not practical, Zion Station will perform hydrostatic exams per IWA-4000.
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COE-275-012 10-5 Revision 0 i