ML20056B401
| ML20056B401 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/20/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20056B395 | List: |
| References | |
| NUDOCS 9008280237 | |
| Download: ML20056B401 (3) | |
Text
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acoagk UNITED STATES
[
g NUCLEAR REGULATORY COMMISSION L
rl WASHINONN, D. C. 20555
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SAFETY. EVALUATION.BY.THE.0FFICE 0F.WUCLEAR. REACTOR. REGULATION REQUEST.FOR. RELIEF.FROM. HYDROSTATIC. TEST. REQUIREMENTS JAMES.A..FITZpATRICK. NUCLEAR. POWER. PLANT 00':KET.NO. 50 333 I.
BACKGROUND The Power Authority of the State of New York (licensee) submitted the James A.
FitzPatrick Power Plant Second Ten-Year Interval, Inservice Inspection Program to the NRC for review and evaluation by letter dated September 30, 1985. The program was rev;ewed and evaluated by the staff with technical assistance from the Idaho National Engineering Laboratory (INEL). The program was based on the requirements of the 1980 Edition through Winter 1981 Addenda of Section XI of the American Society of Mechanical Engineers (ASME) Code. Certain requirements of the Code were determined by the licensee to be imp (ractical to perform at thefa information in support of its determination that the requirements were impractical
-to perform at the James A. FitzPatrick Nuclear Power Plant.
Evaluation of this information by the staff, with technical assistance from INEL, resulted in denying relief requests R13, R14, R15, and R5A. The Safety Evaluation Report documenting the staff's conclusions and the Technical Evaluation Report (TER) prepared by INEL, were transmitted to the licensee by letter dated October 27, 1987.
By letter dated March 23, 1988, the licensee requested that the NRC reconsider
'ts position on Relief Requests R14, R15, and RSA and informed the NRC that delief Request R13 was being withdrawn. The staff's reconsideration of R14 R15, and RSA is documented herein and the appropriate pages from the TER enclosed.
II. EVALUATION.AND. CONCLUSION 0F REQUESTS, A.
RELIEF. REQUEST.R14 1.
LICENSEE's BASIS FOR RECONSIDERATION This relief request refers specifically to the bottom head welds (ASME Section XI. Table IWB-2500-1, Examination Category (69"),and one circumferential weld B-A Items 81.21 and B1.22). The Code requires inspection of one meridian (317").
Relief is required due to interferences from the control rod drive and instrument penetrations. Limited access (four openings) in the vessel skirt also restricts inspection weld length. This Code requirement is more appropriate to a different vessel design.
This relief request was denied.
It had been reconnended for approval, l
however, on page 8 of the TER.
POONObhb$O0bSO33 P
The licensee has requested that the NRC reconsider the technical justification and approve this relief request.
2.
STAFF's EVALUA110N AND CONCLUSION The information presented in support of the.equest establishes the impracticality of the requirements for the examination of the reactor vessel head circumferential and meridional head welds and compliance with the code would require that the RPV be redesigned and refabricated in order to permit the volumetric examinations. The licensee's proposed alternative is to examine equivalent lengths of one circumferential and one meridional head weld by examiiiing accessible lengths of similar welds in the reactor vessel head.
In agreement with the conclusions drawn by INEL (pages 8 and 9 of the INEL TER),
the staff, therefore, concicdes that relief from the Code requirement may be granted.
B.
RELIEF REQUEST R15 1
1.
LICENSEE's BASIS FOR RECONSIDERATION The NRC denied the Residual Heat Removal (RHR) heat exchanger tube sheet to shell weld relief request (ASME Section XI, Table IWC-2500-1, Examination Category C-A, item C1.30).
However, on page 27 of the INEL TER, INEL l
recommends that the licensee's proposal to perform the Code-required volumetric examination if the heat exchanger is disassembled for maintenance be accepted.
l The licensee requests a review of this relief request as s2mitted. This relief request is similar in format, scope, and content to relief requests R5B and R50, which were granted by the NRC as recomended by INEL. The licensee I
suggests that the NRC review the relief request and the TER evaluation for each reiief.
2.
STAFF EVALUATION AND CONCLUSION The licensee proposes to comply with the Code requirements if the heat exchanger is disassembled for maintenance. A proposal to comly with the Code requirements establishes the practicality of ierforming the examinations.
The licensee's assertion that radiation lev is may be high is speculative and does not provide an adequate basis to conclude that the Code requirement is impractical.
Since this examination is permitted by the Code to be performed at or near the end of the inspection interval, the INEL TER states that "(2)
Relief should not be granted at this time."
(See pages 25, 26, and 27 of the INEL TER).
In agreement with INEL, the staff concludes that relief from the Code requirements is denied.
. C.
RELIEF REQUEST R5A 1.
LICENSEE's BASIS FOR RECONSIDERATION The licensee requested relief from ASME Code Section XI Catagory B-G-2 which requires visual examinations of valve bolting surfaces.
On page 24 of the TER, INEL recommends that relief be denied. This recommendation is based on the fact that the Code allows in-place visual examination of bolting which is under tension.
INEL recommends that the licensee submit any changes to the ASME Code Committee for consideration.
However, examining bolting in place under tension misses the area of concern, i.e.
the bolt / nut threaded mating surface. Also, radiation exposure due to scaffoldingrequirements,insulationremoval,andinspectiontimeisnot consist mt with ALARA considerations. Many of the valves in the ISI program are in n.d. radiation areas and require extensive person-hours of preparation I
for the inspection. The licensee has updated valve maintencnce procedures to include an inspection per the Inservice Inspection program during maintenance when the valve is disassembled.
The licensee requests that the NRC review the original relief request for reevaluation'and approval.
2.
STAFF's EVALUATION AND CONCLUSION l
The INEL TER recommended that relief from t;ie examination requirements be denied.
(See pages 23, 24, and 25 of the INEL TER). The staff continues to i
agree with the recommendation. The licensee has not provided sufficient and l
specific information to support its conclusion that tne requirements are impractical and that the ALARA considerations are applicable to all bolting required to be examined. Therefore, the staff's position remains as originally stated, and relief is denied.
1 Dated: August 20, 1990 Pri ;ipal Contributor:
G. Johnson i
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ENCLOSURE
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EGG SD-7412 TECHNICAL EVALUATION REPORT ON THE SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLA NEW YORK POWER AUTHORITY, JAMES A. FITZPATRICK NUCLEAR POWER PLANT, DOCKET NUMBER 50-333 B. W. Brown J. D. Mudlin Y
Published March 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for:
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 under 00E Contract No. DE AC07-761001570 FIN No. D6022 (Project 5)
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3.1.1.2' Recuest for Relief No. R14. Examination C4tecory B A. Ith 81.21 and Bl.22. Pressure Retainino Welds in the Reactor-Pressure Vessel-Code Reauirement:
.Section XI, Table.!WB 2500 1 Examination l
j
-Category 'B-A, Items B1.21 (circumferential head welds) and Bl.22 (meridional head welds)'each requires a 100%-volumetric examination, as defined by Figure IWB-2500 3, of the. length of-one' weld.
licensee's' Code Relief Recuest:
Relief is requested from q
examining 100% of the Code-required volume on the length of one i
circumferential head weld and on the length of one meridional head weld.
License h Prc,cosed Alternative Examination:
4 The Licensee' l
propotes to examine a composite weld length of circumferential head welds and a composite weld length of meridional head welds where access allows to meet the Code requirements of the f
inspecth of one circumferential head weld (317 inches) and
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one merioivnal head weld (69 inches).
Licenseo's b d-for Reauestina Relief:
The design of ti.e Reactor Pressurc Vessel presents. obstructions (vessel skirt'and i
numerous interferences from the control rod' drive and instrument penetrations)-that will not allow 100% of the required volume to be examined.
j
. 4 Evaluation _:
The Licensee's submittal has been reviewed, including the referenced interference drawings.
Based on the-RPV design, the performance of volumetric examina: ions of a composite weld length of circumferential head welds that will equal one circumferential head weld length (317 inches) and the performance of volumetric examinatior.s of a composite weld length of meridional head welds that will equal one meridional head weld length (69 inches) are acceptable alternatives to the 8
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.-fv Code requirements.- The RPV would have to be redesigned and'
.refabricated in order to complete the: volumetric examinations as required by the Code.
-Conclusions:~ Based on the above evaluation, it is concluded i
that the proposed alternative examinations provide an
~ acceptable' level of inservice structural integrity and that p
compliance with the specific requirements of Section XI-would
'~
result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
Therefore, it_is recommended that rel_ief be granted as requested.
I n
3.1.1.3 Recuest for Relief No. R6. Examination Cateaory B 0. Item B14.10. Pressure Retainino Welds in Control Rod Housinas
. Code Reauirement:
Section XI, Examination Category B-0, Item B14.10 requires a 100". volumetric or surface examination of 10f.
of peripheral control rod drive (CRD) housings.
Licensee's Code Relief Reuuest:
Relief is requested from examining 100% of the welds in 10% of the peripheral CRD housings.
Licensee's Procosed Alternative Examination:
A partial examination will be performed on an estimated 24 to 32 of the f
upper housing welds which are accessible through the vest skirt personnel access openings.
The Licensee will att upt to in,spjtet the accessible upper _C,RD.ttouting welds so that the total weld length inspected will equal the weld length of 107.
L of the peripheral CRD housings.
In addition, a visual' examination (VT-2) on 100% of the welds l
in the CRD housings will be performed during the hydrostatic examination at the end of the inspection interval in accordance with IWA-5000 and IWB-5000 and the requirements of Examination Category B-P of Section XI of the Code.
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performed at or near.the'end of the second interval, therefore, f
relief from the examination requirements is not necessary until that time.
The= Licensee will be in compliance with the Code
- requirements up to the last examination period of the-
^
-interval.
Since it is not known at this time which components will require relief,'it is reasonable for the decision to grant
.a relief to be postponed until after the Licensee determines!that relief is required.
The Licensee should submit a new relief-s request,_ near the end of the second 10 year interval, which k
identifies the specific components for which relief is requested.
==
Conclusions:==
Based on the above evaluation, it is concluded t
that compliance with the specific requirements of-Section XI
-would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
The
)
Licensee should submit a new relief request near the end of the second 10 year interval.which identifies the specific components for which relief is reque+ ted.
Therefore, it is recommended that:
(1) The Licensee's proposal to perform the visual examinations ~(VT-1/VT-3) on the internal surfaces of the valve bodies whenever they are made accessible due to valve disassembly for maintenance purposes should be accepted; and' f
(2) Relief should not be granted until the specific components for which relief is requested are identified.
3.1.7 General-
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3.1.7.1 Reauest for Relief No. R5A. Examination Cateoorv B-G-2. Items B7.10. B7.50. B7.60. B7.70, and B7.80. Pressure Retainina 1
Boltino. 2 inches and less in Diameter Code Reauirement:
Section XI, Examination Category B-G-2, Items B7.10 (bolts, studs, and nuts on Reactor Pressure Vessel), B7.50 (bolts, studs, and nuts on piping), 87.60 (bolts, studs, and nuts on pumps), B7.70 (bolts, studs, and i
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nuts on valves), and B7.80 (bolts, studs, and nuts in CRD-y a
housings) require a visual examination (VT-1)' of.the surfaces of all bolts, studs, and nuts.
The bolting may,be examined:
(a) in place under tension;' (b)
^
L when the connection is disassembled;-or (c) when the bolting is removed.
Bolts,. studs, and nuts in CRD housing should~be
^
examined when disassembled.- Deferral of inspections to the end of the interval is not permissible.
1 Licensee's Code Relief Reouest:
Relief. is requested from a
performing the Code-required visual examination (VT-1) on the pressure-retaining ~ bolting.
licensee's Prooosed Alternative Examination:
The surfaces of the pressure-retaining bolting will be visually examined (VT-1) whenever the surfaces are made accessible due to routine maintenance.
L Licensee's Basis for Recuestino Relief:
The Licensee states that it has been and continues to be the Licensee's policy to examine the pressure-retaining bolting whenever the components-are made accessible due to routine maintenance.
It is the r
Licensee's position that in-place visual examination of bolting does not reveal the areas most susceptible to' failure and J
subsequent degradation of pressure-retaining integrity, and that in-place inspection results in large amounts of radiation b;
The Licensee states that it does not intend to exposure.
disassemble components solely for the purpose of inspection because this could cause additional wear and the possibility, however slight, exists for damage to the bolting.
1 The bolting not examined during the 10 year period, because the-component was not disassembled, will be examined during the hydrostatic examination for leakage in accordance with IWA-5000 and IW8 5000 and the requirements of Examination Category B-P i
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~of Section XI of the Code, l
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Relief-from examination.of specific components will be i
requested near the end of.the 10-year interval.
l Evaluation:- Although'the Licensee may not have confidence-in this method of examination for determi,ning the condition of the L
subject components, it has not supplied enough justification to l
establish that the Code-required visual examination is impractical.
. Lack of confidence in examination results is not a justification for relief from the Code requirements.
Code requirement changes should be submitted to the ASME Code CcamW.ee for consideration.
Therefore, it is not unreasonable to require the Licensee to perform the Code-requirr' examination.
==
Conclusions:==
Based on the above evaluation, it is concluded that the Licensee has not justified-the determination of t
l impracticality for the visual examination (VT-1) of the i
pressure-retaining bolting surfaces a that requiring the
' Licensee to perform the Code-required examination would not j
result in hardship.
Therefore, i+. is recommended that relief be denied.
i 1
3' 2 Class 2 Comoonents 3.2.1 Pressure Vessels
.3.2.1.1 Recuest for Relief 'lo. R15. Examination Cateaory C A.
Item Cl.30 ftubesheet-to shell weld). Pressure Retainine Welds in Pressure Vessels Code Recuirement:
Section XI, Table IWC-2500-1, Examination Category C-A, Item C1.30 requires a 100% volumetric examination, as defined by Figure IWC-2500 2, of the tubasneet-to-shell weld.
In the case of multiple vessels of 25
3.
similar design, size,'and service, the required examinations 4
may be limited to one vessel or distributed among the vessels.
1 The vessel areas selected for the initial examination shall be 1
i reexamined over.the service lifetime of the component. :
Licensee's Codo Relief Recuest:- Relief is requested from performing the Code-required volumetric examination of the~
tubesheet to-shell weld of the heat exchanger (RHR).
Licensee's Procesed Alternative Examinalj.gn:
Volumet'ric examination will be made if the heat wchanger is diassembled for maintenance.
Licensee's Basis for Reauestino Relief:
The channel head cover will require removal to inspect the tubesheet-to-channel head weld.
The channel head cover has a clearance of 2 feet-from the RHR Heat Exchanger floor.
Upon removal-of the channel head cover, inspector access to the channel head to tubesheet weld is available.
General Area radiation levels have been approximately 250mr/hr to Irem/hr during previous ISI inspections of the RHR heat exchanger welds.
It is estimated that disassembly, inspection, and reassembly would require approximately 4.5 person rem exposure to complete this work.
Actual exposure within the channel head-(inspector access) is not available, and radiation levels'may be significantly higher.
Evaluation:
The Licensee's submittal has been reviewed I
including the referenced drawing.
Because the disassembly of the heat exchanger is a major effort and o' the ALARA concerns, n.
the concept of performing the volumetric examination on the tubesheet-to-shell weld if the heat exchanger is disassembled for maintenance is acceptable.
However, if the heat exchanger L
is disassembled for maintenance, relief would not be required L
since'the Code-required volumetric examination would be performed.
Since the volumetric examination of the 26 I
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tubesheet to-shell weldLmay be performed at or near the end of-(
i the second 10-year interval, relief from the examination requirements is..not necessary until then because the Licensee
-will-be in compliance with the Code requirements up to:that time.
Since. it is not known at this' time if-the weld 'will be
. examined or not, it is reasonable to postpone the decision to
~
l
. grant relief, if required, until after the Licensee submits a new relief request near the end of the second interval.
t
==
Conclusions:==
Based on the above evaluation, it is concluded-
'that, if needed, the Licensee should submit a new relief; request near the end of the second 10-year interval, l
Therefore, it-is recommended that:
(1) The Licensee's proposal to perform the Code-required volumetric examination if the heat exchanger is disassembled for maintenance should.be accepted; and (2) Relief should not be granted at this time.
3.2.2 Pioino 3.2.2.1 Reauest for Relief'No RI. Examination Cateacey C F. ' Pressure Retainino Welds in Class 2 Pioina of RHR. ECC, and CHR Systems
~
Code Reauirement:
Section XI, Table IWC-2500 1, Examination Category C F, Note (1) states that the. welds selected for q
examination shall include:
(a) all welds at locations where the stresses under the loadings resulting from Normal and Upset plant conditions, as calculated by the sum of Eqs. (9) and (10) 1 in NC 3652, exceed 0.8(1.2Sh + S ); (b) all wel.ds at A
terminal ends of piping or branch runs; (c) all dissimilar metal welds; (d) additional welds, at structural
~
discontinuities, such that the total number of welds selected for examination includes the following pecentages of circumferential-piping welds for boiling water reactors:
(1) none of the welds tecpted by IWC-1220, (2) none of the j
welds in residual t u t rem 6 val and emergency core cooling systems, (3) 50% of the main steam system welds, (4) 25% of the L
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