ML20058P626
| ML20058P626 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/15/1990 |
| From: | ALABAMA POWER CO. |
| To: | |
| Shared Package | |
| ML20058P624 | List: |
| References | |
| FNP-2-M-068, FNP-2-M-68, NUDOCS 9008170234 | |
| Download: ML20058P626 (75) | |
Text
.
-- e FNP 2 M 068 ,
i Summary of Revision 1 to the J. M. Farley Nuclear Power Plant Unit 2 Ten-Year Inservice Inspection Program for ASME Code Class 1, 2, and 3 Components Pace No./Descriotion/ Reason for Chanae
- 1. _Page 1-2, Section 1.2: Deleted second paragraph. No longer applicable.
- 2. Page 1-3, Section 1.7.1: Revised to clarify requirements for performing <
ultrasonic examinations, including incorporation of Code Case N-435 1.
Per APCo letter to NRC dated 10/5/89, Enclosure 2, Item J.
- 3. Page 1-6, Section 1.12: Revised to reflect listing of ASME Code. Cases from Regulatory Guide 1.147 applicable for the second 10-year inspection interval. Reference APCo letter to NRC dated 10/5/89, Enclosure 2, item H.
- 4. Pages 3-3A and 3-3B, Residual Heat Exchangers: Revised to reflect correct configuration and examination requirements. Editorial correction
- 5. Page 6-1: Revised " Examination A'ea" description for RR-2 thru RR 6 to reflect required changes to relief requests. Editorial.
- 6. Page 6-3:: Revised " Examination Area" description for RR-24 to reflect required changes to relief request. Editorial. ,
- 7. Page 6 4: Revised " Examination Area" description for RR 45 to reflect ,
required changes to relief request and RR 46 from "(7)" system i hydrostatic tests to "(3)". Editorial.
- 8. Page 6-5: For relief request RR-1, revised description of welds examined ,
using calibration block ALA RV 3. Editorial correction.
- 9. Page 6-7: For RR-2, revised descriptions of welds examined using all three calibration blocks. Editorial correction.
- 10. Page 6 8: -Issued relief request RR-3. Reference APCo letters to NRC ,
dated 10/5/89 and 12/7/89, Enclosure 2, Item J.
- 11. Page 6-9: Previous relief request RR-4 was no longer applicable and was rewritten to allow the use of Code Case N-461 where the thickness '
difference between calibration blocks and the component exceedsSection XI, Appendix Ill allowances. Per APCo letter to NRC dated 12/7/89, Enclosure 2, Jtem J.
- 12. Page 6-10: Added page in conjunction with rewrite of RR-4 and renumbered following pages as required. Editorial.
9008170234 900815 l DR ADOCK 0500 4 1M3
FNP-2-M-068
- i 13.
Page 6 11: General revision of relief request RR-5 based on recent
- dimensional NRC evaluation dated 10/5/89 and 12/7/89, ofEnclosure calibration blocks.-
2, Item J. Reference APCo j
- 14. Page 6-12: Deleted relief request RR 6. .e longer requird. Reference- i APCo letter to NRC dated 12/7/89, Enclosure 2, Item J.
- 15. Page 6-13:
dimensional evaluation of calibration ble ks. General revision of re ;
NRC dated 10/5/89 and 12/7/89, Enclosure i.N Item J. Reference APCo letters
- 16. Pages 6 22, 6-23, and 6 24: Issued relief request RR-13.
- 17. Pages 6-25 and 6-26:
Issued relief requests RR-14 and RR-15. I L
l and RR-23. !
l Reference 4/12/90, Item 3. APCo letters to NRC-dated 10/5/89, Item M and ' !
1-
- 19. Page 6 39: Deleted relief request RR-24. Not required. . Reference ; APCo
-letter to NRC dated 10/5/89, Enclosure 2, Item N. '
i
, 20. Pages-6-40 thru 6-42: (
l Issued relief requests RR-25, RR 26, and RR-27.
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- 21. {
l Page 6 44; following Renumbered pages as required.Attachment 28-1 from 6-42a to 6-44 and renumbered .
Editorial change, !
i
- 22. Page 6-46: Issued relief request RR-30.
dated 4/12/90, Enclosure 2, Item 3. Reference 'APCo letter to NRC;
- 23. Page;6-49 and 6-50:
pages as required. Issued relief request RR-33 and renumbered following 2, Item P. Reference APCo letter'to NRC dated 10/5/89, Encosure l
- 24. Pages 6-51 thru 6-56:
and RR-38. Issued relief requests RR-34, RR-35, RR-36, kR 37,- ;
[ 25. Page 6-58: Issued relief request RR-40.
- 26. Page 6-61 and 6-62: .-
Issued relief requests RR-43 and RR-44, 27.
Page 6-63: Deleted relief request RR-45. No longer required. Reference APCo letter to NHC dated 10/5/89, Enclosure 2, Item V.
- 28. Page 6-64: Issued relief request-RR-46, 2 of 3
- 29. Page 7-1: . Item 9: Revised to reference the current revision of Regulatory Guide- 1.147- applicable f or the second 10 year inspection j interval. Reference' APCo letter to NRC dated 10/5/89, .Enlcosure 2,. Item H. ,
- 30. Page 7-2:^1 tem 13: Added listing of ASME Code Cases from Regulatory i Guide 1.147, Revision 7, applicable to the second 10 year inspection-interval and renumbered following pages as required. Reference APCo ;
letter to NRC dated 10/5/89, Enclosure 2, Item H. t f
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1-1 a
l 1-1 1
001005 3 of 3
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t FNP-2-M-068-1.2 EFFECTIVE DATE-The updated Unit 2 program goes into effect in March, 1989, during the Unit 2 sixth refueling outage and will continue through the third 40-month period of the first 10-year interval and will remain in effect through the first and second 40-month periods of the second ten-year interval until December 1, 1997, the-completion date for the r :ond 10-year interval for Unit 1.
Examinations performed under ection XI, 1983 Ecation through the Summer 1983 Addenda,_dur.'.g the third 40-month period of the first 10-year interval are required only for the remaining items necessary to complete the first 10-year interval. This update is not intended to be retroactive to any items previously examined during the first or second 40-month periods of the first 10-year interval. <
1.3 COMPONENT UPGRADING All-plant components have been reviewed to determine the appropriate classification for inservice inspection. ANSI, N-18.2 " Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants," is used as an acceptable-alternate to Safety Guide 26 in determining component quality group classifications.
It must be noted that the classification of components as ASME Class 1, 2, or 3 equivalent for inservice inspection does not.
Imply.'that the components were_ designed in accordance with'ASME requirements. The component design codes remain as stated in the Final Safety Analysis Report (FSAR).
1.4 SUBSEQUENT ISI PROGRAM REVISIONS .
In accordance with the NRC letter dated August 31, 1988, the Unit 2 Inservice Inspection Program for Class 1, 2, and 3 components will be reviewed near the end of the second 10-year interval for Unit 1 (December 1, 1997). At this time the Unit 2 program will be modified, as required, to bring it into compliance with the latest NRC-approved version of Section XI in effect at that time.
04591 1-2 Rev. 1
FNP-2-M-068 1.5 RESPONSIBILITY
' Alabama Power Company' bears the overall-responsibility for-the performance of the inservice examinations. Certain nondestructive examinations may be performed by a qualified examination agency.
reported to Alabama The results Power Company of such for examinations final. would evaluation and be disposition.
1,6 RECORDS Records and documentation of all information and inspection.
results, which provide the basis for evaluation and which facilitate comparison with results from previous and subsequent ;
inspections, will be maintained and will be available for the active IWA-6000.
life of the plant in accordance with Section XI, 1.7 METHODS OF EXAMINATION The method of examination planned for each area is delineated in subsequent sections. Personnel performing nondestructive s
examinations will be trained in accordance with the American Society for Nondestructive Testing (ASNT) " Recommended Practice SNT-TC-1A, Supplements and Appendices," as applicable for the technique and method used. For methods not covered by SNT-TC-1A, personnel shall be trained to-comparable levels of competence by subjection to comparable examinations on the particular method involved, e.g. VT-1. Personnel performing visual examinations outside the scope of nondestructive examinations shall be trained to the requirements of ANSI N45.2.6 " Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants".
1.7.1 ULTRASONIC =
Ultrasonic examinations will be conducted in accordance with the provision of Appendix 111 of ASME Section XI, paragraphs IWA-2232 and IWA-2240.
Examination of vessels less than or equal to 2 inches in thickness and boltin greater than 2 inches in diameter, and with center-drilled holes, will be
- g performed to the requirements of Code Cases N-435-1 and N 307-1, respectively.
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04591 1-3 Rev. 1 l
FNP-2-M-068 attached1 tabulations have been developed as a result of a design review. Should certain ASME Section XI Code requirements be ,
discovered to be impractical due to unforeseen reasons during the '
process-of performing inspections or tests, relief will be requested i from the specific Section XI Code requirement at that time.
' Radiation levels in certain. areas or of certain components may be found to-prohibit the access for operators or examiners to perform -
the examinations or tests described in this program. If radiation levels cannot be reduced and access is still restricted by t considerations of compliance with the requirements of Regulatory Guides 8.8 and 8.10, relief will be requested from the specific .
Section XI Code requirements and alternative-examination ,
requirements _will be proposed. ,
I i 1.11 AUGMENTED INSPECTIONS l l l
- The NRC has required certain augmented inspections as added j
l assurance of structural reliability. The areas of interest and the examinations to be performed are as follows:
A. Reactor vessel examinations will be performed in l accordance with Alabama Power Company's " Augmented .
t Reactor Vessel Examination Program" dated 10/6/83, l which was developed in response to Generic Letter 83-15 l and Regulatory Guide 1.150, Revision 1.
B. The reactor coolant pump fly wheel will be inspected in j L
' accordance with plant Technical Specification 4.4.11.2 '
i C. The steam generator tubing will be inspected in t
accordance with plant Technical Specification 4.4.6 and-
] '
L Regulatory Guide 1.83, Rev. 1.
d D. The main steam lines will be inspected in accordance L with plant Technical Specification 4.4.11.3 and Branch :'
Technical positions APCSB-3-1 and MEB-3-1.
I b
's 1.12 CODE CASES .
Code cases listed in item 13 of Section 7.1 of this program which are provided in Regulatory Guide 1.147 will be used by Alabama Power Company as necessary.. All a other code cases will be used on a case-by-case basis, i
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i 04591 1-6 Rev. 1
l l Farley Nuclear Plant Unit No. 2 Inservice inspection FNP-2-M-068 Table IWC-2500-1 Examination Categories . .
C-A, PRESSURE RETAININC WELDS IN PRESSURE VESSELS Extent and Frequency of Examination Examination *
- lien Regtni rements/ Examination Acceptance. First interval No. Parts Examined Fiqure No. Reller Method _Standa rd Thi rd Pe riod Request Comments hdown lleat Exchanger i tube sidel C1.10 Shell-to Flange Circuercrential IWC-2500-1 Vol. IWC-3000 Welds' at gross -
strtetteral discon-tinuity' only.
l- C1.20 Head-to Shell'Circumferential IWC-2500-1 Vol. lWC-3000 Head-to-shell weld'. - -
C1.30 Tubesheet-to-Shell SWC-2500-2 N/A N/A N/A -
N/A to FIIP (xcess Letdown Heat Exchanger i tube sidej C1.10 Head-to-Flange Ci rcumfe rentia l IWC-2500-1 Vol. IWC-3000 Welds' at gross - -
st ructeers t discon-tinuity' only.
C1.20 Head Circumferential . IWC-2500-1 N/A N/A N/A -
N/A to FMP C1.30 Tubesheet-to-Shell IWC-2500-1 N/A N/A N/A -
N/A to'FMP Pegenerative_ Heat Exchanger I tube sidel C1.10 Shell Ci rcumfe rent ia l lWC-2500-'s N/A N/A N/A -
N/A to FNP C1.20 Hesd-to-Sheli Ci rcumfe rent ia l (6)- 'IWC-2500 'Vol. IWC-3000 84ead-to-She l i RR-18 -
Sur.' Weld'.
C1.30 Shell-to-Tubesheet (6) IWC-2500-2 Vol. SW,-3000 Tubesheet-to- RR-18 -
Sur.' shell weld'.
Residual Heat Exchangers - 2 Itube side)
Welds' at gross C1.10 Shell-to Flange Circuarerential IWC-2500-1 Vol. IWC-3000 st riecttera l d i scon- - -
s tinuity' only.
C1.20 Head-to-Shell IWC-2500-1 Vol. IWC-3000 Head-to-shell - -
Circumferential weld'.
C1.30 Tubesheet-to-Shell IWC-2500-2 N/A N/A N/A ~~
N/A E8 IMI Sea l Wa ter Re tu rn F i l te r C1.10 Cove r We ldmen t-to-She l l . IWC-2500-1 Su r. '
- IWC-3000 Welds' at gross Ci rcumfe rent ia l RR-19 ' -
VT-1' st rtsctu ra l d i scon-tinuity' only.
01:601 3-3/A Rev. ].
. . . . . ,. - .~-. . . - . .
ar- m.
f orley Nucicar Picnt Unit peo. 2 FMP-2-M-068-.
Inservice inspection-Table IWC-2500-1 Examination Categories ,
I' 'C-A, PRESSORE RETAINING WELDS IN PRESSORE VESSEt_S I'xtent and ~
Examination . frequency of ttem Requi rcacret s/ Examinstion . Acceptance. E x am i,__nsjlon' '. Retier Nom Pa rts Examined Tiqure No, Method ; Standard Second f ote rva t Neouest Comments letdown Heat Exchanger f itsbe side]
C1.10 Shell-to F lange Ci rcumferent ial IWC-2500-1 Vol. IWC-3000 Welds' at gross - -
structural discon-tinuity' only.
C1.20 Head-to SheiI Ci rcumfe rent ia l IWC-2500-1 Vol. IWC-3000 Head-to-sheti weld'. - -
C1.30 Tubesheet-to-Shell IWC-2500-2 N/A N/A N/A -
N/A to INP Excess tetdown Heat Exchanger f tube sidel C1.10 Head-to-flange Circumferential IWC-2500-1 Vol. IWC-3000 Welds' at gross - -
structurai discon-tinuity' only.
C1.20 Head Circumferential IWC-2500-1 N/A N/A N/A -
N/A to INP C1.30 Tubesheet-to-Shell IWC-2500-1 N/A N/A N/A -
.N/A to INP Regenerat ive Heat Exchanger f tube side)
C1.10 Shell Ci rcumfe rent i s t IWC-2500-1 N/A N/A N/A -
N/A to INP C1.20 Head-to-Shell Ci rcumfe rent ia l (6) IWC-2500-1 Vol. lWC-3000 Head-to-Shell RR-18 -
Sur.' Weld'.
Ct.30 Shell-to-lubesheet (6) IWC-2500-2 Vol. IWC-3000 Tubesheet-to- RR-18 -
Sur,' shell weld'."
Residual Heat Exchangers - 2 Itube side _}
Welds' at g ross SWC-3000 s t ruc tu ra l discon- .
C1.10 Shet t-to flange Ci rcumferential - IWC-2500-1 Vol.
tinuity only.
C1.20 Head-to-Shell SWC-2500-1 vol. IWC-3000 64 cad-to-she l l - -
Ci rcumfe rent ia l weld'.
C1.30 Tubesheet-to-Shell IWC-2500-2 N/A N/A N/A -
N/A to IMP Sea I Water Return f ii ter C1.10 Cover Wetdeent-to-Shell IWC-2500-1 Sur.' IWC-3000 Welds' JL gross RR-19 -
Circumferential VI-1 5
- h t ruc tu ra l d i scon-tinuity* only.
e Ota608 3-3/8 Rev. 1
FNP 2-M-068-6.0 RELIEF REQUESTS FNP-2 The following relief requests are applicable to Farley Nuclear Plant Unit 2
' second-10 year 151, and include all pertinent examination areas and details where the requirements of ASME Code,Section XI, 1983 Edition with Adaenda through Summer 1983, could not be satisfied completely, t Relief _%ouest No. Examination Area RR-1 Material requirements for calibration blocks used for ultrasonic examination of ;
heavy wall vessels. .!
RR 2 Notch location requirements for calibration blocks used for ultrasonic examination of heavy wall vessels.
RR-3 Hole location requirements for calibration blocks used for ultrasonic examination of heavy wall vessels.
RR-4 Thickness differences =between the calibration blocks used for examination of piping systems and thin wall vessels and -
the components to be examined.
RR-5 Curvature differences between the calibration blocks used for examination of piping systems and thin wall vessels and the components to be examined.
RR-6 Deleted RR-7 Dimensional requirements for calibration notches placed on. calibration blocks. used.
for ultrasonic examination of piping systems and thin wall vessels.
RR 8 Intentionally left blank. Corresponding .
Unit I relief request not applicable to
- Unit 2.
RR-9 Volumetric examination of nozzle-to-vessel welds in the pressurizer.
RR-10' Volumetric examination of nozzle to-safe end welds in steam generators.
000563 6-1 Rev. I t
i
FNP-2-M-068 RELIEF REQUESTS.
FNP-2
- . Relief Requer.t No. Examination Area RR-23 Hydrostatic' testing of portions of '
Class 2 piping'to the connecting Class 1 requirement.
o RR-24 Deleted RR-25 Hydrostatic-test for the Class 2 L reactor vessel flange seal leakoff line i (line No. CCB-36).
1 L RR-26 Hydrostatic testing of portions of, l Class 2 piping systems isolated from ,
the test boundary by closed check f valves.
RR-27 Hydrostatic test for Class 2 waste gas l
drain filter line to volume control L tank (line No. HCB-92). l RR-28 Volumetric examination of the no::le 1 s
inside radius section of the steam L outlet nozzle on steam generators.
RR-29 Hydrostatic testing of boron injection recirculation- discharge piping (line No. CCB-62).
RR-30 Hydrostatic testing of Class 2 portion f L of the steam generator (4-hour hold i time), r RR-31 Visual.(VT-2) examination for leakage-of Class 3: service water pumps. ,
ERR-32 Visual (VT-2) examination for leakage in encased piping in' spent fuel pool -j cooling system, s
RR-33 Hydrostatic testing of portions of .
Class 3 piping and components which-operate continuously during all modes of plant operation.
RR-34 Hydrostatic testing of Class 3 spray additive lines in containment spray system. <
04611 6-3 Rev. 1
FNP-2-M-068 1 RELIEF' REQUESTS !
FNP-2 Relief Request No. Examination Area 4
.RR-35 Hydrostatic testing of Class 3 buried' piping in the service water system.
RR-36 Visual (VT-2) examination of the tubes I in the Class 3. component cooling. water '
heat exchangers.
RR-37 Visual (VT-2) examination of condenser coils (tubes) in Class 3 coolers. H RR-38 Hydrostatic testing of Class 3 portions of auxiliary steam piping. 1 l- RR-39 Hydrostatic testing of Class 3 ;
L auxiliary feedwater pump minimum flow i piping. *
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1 RR-40 Hydrostatic testing of all Class 2 d L branch pipe lines from VCT to first valve. I RR-41 Break away drag test for hydraulic l snubbers, l L
l RR-42 Additional sample testing requirements for snubbers.
RR-43 Hydrostatic testing of 01 ass 2 portions l
of the RCS head vent lines. :l RR-44 Operational monitoring of the Class.3 spent fuel pool cooling heat exchangers. !
RR-45 Deleted l
RR-46 Schedule adjustment for three (3) -
system hydrostatic tests. H i
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l 0461I 6-4 Rev. 1
W( -
t FNP-2-M-068 ir S RELIEF REQUESTS V FNP-2 4 RR-1 a
x Component or
. Relief Areas Relief from the material requirements-for calibration blocks used to perform y' , ultrasonic exam. nation of the following:
APR-6: Steam generator channel head-to-tubesheet welds.
APR-7 Boron injection tank head-to-shell circumferential u
welds'and nozzle-to-head welds.
h ALA-RV-1: Reactor vessel lower l head-to-lower shell weld and' L all lower head welds. Boron l injection tank head-to-shell circumferential welds.
ALA-RV-3: Reactor vessci tap head welds. l:
Requirement from i
.which Relief is Requested: Section XI, 1983 Edition with Addenda through
/ Summer 1983,. paragraph IWA-2232 requires that l ultrasonic examination of vessel welds in ferritic materials greater than 2.in. in-thickness be performed in accordance with Article 4,Section V. Paragraph T-434.1.1(3), ,
Article 4, requires that.the.materialifrom which' a calibration blocks are~ fabricated be of the same y n material specification, product form, and heat-treatment as one of the materials being joined. <
Basis for Relief: During fabrication of the Farley Unit 2 nuclear ,
steam. supply system vessels,1the calibration
- g blocks used to perform examinations by the
- vessel manufacturer were fabricated to the !
o requirements.of American Society of Mechanical Engineers (ASME)Section III. When ASME
[, Section XI was issued for inservice inspection, l-the new> requirements for vessel calibration ;
M blocks rendered the existing blocks unacceptable ;
L for use. The original blocks had to be replaced l but some vessel materials were no longer t available. The vessel calibration blocks had i to be refabricated to the Section XI I requirements applicable at that time.
L 04611 6-5 Rev. 1 1
F FNP 2 H 068 RELIEF REQUESTS f.lif.:2 Component or l
Relief Area: Reitof from notch location requirements for calibration blocks used to perform the following:
ALA RV 1: Boron injection tank head to shell circumferential welds. Reactor vessel l
I lower head to lower shell weld and all lower head welds.,
ALA RV-3; Reactor ve.:sel snell welds, sh' ell-to nozzle welds, and top head welds.
l L ALA RV 5: Reactor vescel flange to shell weld. I Requirement from which Relief is ;
Requested: Section XI, 1983 Edition with Addenda through Summer 1983, !
paragraph IWA-2232, requires that ultrasonic examination of vessel welds in ferritic materials greater than 2 in.
in thickness be conducted in accordance with Article 4,Section V, 1983 Edition. Figure T-434.1, Article 4, requires that the minimum distance from the ends of the 2 in, long 2 percent T notches to the edges of the block be >
3 in. ;
Basis for Relief: Figure T-546.1, Article 5 Sectier, V, 1983 Edition, is a 1 similar calibration block; however, the clearance required from the ends of the 2-percert notches is 2 in, instead of the 3 in, required by Fioure T 434.1, Article 4.
Experienceperformingcalibrationcusingtheseblockshas proven fully satisfactory.
Alternate Examination: The above calibration blocks are in compliance with the clearance dimensions required for notches by Figure .
T 546.1 Article 5,Section V, 1983 Edition.
000563 67 Rev. 1
'N FNP 2 M 068 x
RELIEF REQUEST EE-1 EB:1 Component or Relief Area: Relief from hole location requirementi for calibration blocks used to perform the following:
ALA-RV-1: Reactor vessel lower head-to-lower shell weld, all lower head welds and boron injection tank head circumferential welds.
ALA RV 5: Reactor vessel flange to shell weld.
APR 5: Steam generator stub barrel to upper tubesheet weld, lower shell-to stt4 barrel weld, transition cone to lower shell weld, upper shell to transition cone weld, and feedwater nozzle to upper shell weld.
APR-7: Pressurizer top head-to nozzle welds, top head to upper shell, upper-to middle shell weld, lower to bottom lead weld, all longitudinal shell welds, and bottom head to nozzle weld.
Requirement from which Relief is Requested: Section XI, 1983 Edition with Addenda through Summer 1983, paragrapn IWA-2232 requires that ultrasonic examination of vessel welds in ferritic materials greattr than 2 inches in thickness be conducted in accordance with Article 4,Section V, 1983 Edition. Figure T-434.1 of Article 4 requires the aligned side-drilled holes to be located a minimum distance of T/2 froni the end . the block. The aligned holes in ALA RV 1 and ALA-RV are .25 end .50 inches less .than the required distance, respectively. The non aligned holes are to be located a minimum of 1.5 inches from the end of the block. The non aligned holes on ALA RV 1, APR 5 and APR 7 are .25, .625 and .625 inches less than the required distance, respectively.
- Basis for Relief: Experience perf orming calibrations using the blocks mentioned above has proven fully satisfactory.
Alternate Examination: None; the calibration blocks are acceptable for use as is.
000563 6-8 Gen. Rev. 1
FNP 2 M 068 RELIEF REQUEST !
FNP-2 i RR 4 ;
i Component or Relief Area: Thickness differences between calibration blocks used to l perform ultrasonic examinations and the following piping systems and vessels less than or equal to 2 inches in thickness: I ALA 5: Excess Letdown Heat Exchanger ALA-RV 7: Reactor Coolant Piping ALA-24: Main Steam Piping .
ALA 25: Feedwater Piping A1.A 31 Volume Control Tank ;
Requirement from which Relief is ,
Requested: Section XI, 1983 Edition with Addenda through Summer 1983 (piping systems), Code Case N 435 1 (which references the ;
- Winter 1985 Addenda for thin wall vessels), Appendix 111, ;
L paragraph 111 3410 requires that the basic calibration block o shall be made from material of the same nominal wall '
thickness or pipe schedule as the pipe to be examined. ,
1 Basis for i l
l Relief: The design of the existing calibration blocks used for piping ,
and thin wall vessels was done under the provisions of f Section V, 1974 Edition with Addenda through Summer 1975. i I
Thickness differences between the above calibration blocks and the components to be examined are inconsequential and ,
would in most cases produce conservative examination results.
l Fabrication of new calibration biccks solely for the purpose '
of achieving exact thickness congruity with the component will not improve examination quality. i Alternate
, Examination: Code Case N 461, Alternate Rules for Piping Calibration Block t
! Thickness will be incorporated for use of the above calibration blocks with the following stipulations: .
- a. Ultrasonic (UT) thickness measurements and weld joint measurements of the pipe or camponent must be available to the UT inspector prior to performing the angle beam 3 examination, it is acceptable to use measurements from a l previous inspection.
000563 69 Rev. 1
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, FNP 2 M 068
,n RR-4 (Cont'd) m e , b. The 10-year ISI plan and current outage a'lan shall annotate components / calibration blocks witch require thickness tolerances per Code Case N 461.
- c. In addition, all UT reflectors 50% distance-amplitude correction (DAC) and above must also be recorded and their position in the weld joint plotted to determine
( if the reflectors are relevant indications.
r 9
l 000563 6-10 Rev. 1 i
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o
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FNP 2 M 068 i
REllEF REQUEST EhE 2 RB-l i
Component or i Relief Area: Curvature differences between calibration blocks used to '
perform ultrasonic examinations and the following piping systems and vessels less than or equal to 2 inches in thickness: . ;
ALA 5: Excess Letdown Heat Exchanger i ALA RV-7: Reactor Coolant Piping ALA-21: Pressurizer Skirt ALA 23: Mainsteam Piping ALA 25: Feedwater Piping ALA 31: Letdown Heat Exchanger Volume Control Tank ,
1 ALA 32: Residual Heat Exchanger ALA/APR-33: Reactor Coolant Piping Requirement from which Relief is Requested: Section XI, 1983 Edition with Adnda through Summer 1983 (piping systems), Code Case N 435 (which references the Winter 1985 Addenda for thin wall vessels), Appendix III, paragraph !!! 3410 requires that the basic calibration block shall be the same nominal diameter as the pipe to be examined.
Basis for :
Relief: The design of. the existing calibration blocks used for piping and thin wall vessels was done under the provisions of Section V, 1974 Edition with Addenda through Summer 1975.
Curvature differences between the above calibration blocks :
and the components to be examined are inconsequential and would in most cases produce conservative examination results.
Fabrication of new calibration blocks solely for the purpose of achieving exact curvature congruity with the component .
will not improve examination quality.
Alternate Examination: The above calibration blocks are in compliance with the curvature tolerances between the blocks and the test part as required by Section V, 1983 Edition with Addenda through Summer 1983, paragraph T-543.3. ,
000563 6-11 Gen. Rev. 1
FNP-2-M-068 i i
RELIEF REQUESTS FNP-2 RR-6 '
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DELETED .
i (NotRequired) t i
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04611 I 6-12 Rev.
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i FNP 2 Mo068 !
REllEF REQUEST TE:.2 RB:2 Component or I Relief Area: Dimensional requirements for calibration notches placed in ultrasonic calibration blocks used for piping and vessels less than or equal to 2 inches in thickness.
ALA 21 ALA-23 ALA-26 ALA 28 Requirement from Which Relief is Requested: Section XI, 1963 Edition with Addenda through Summer 1983 (piping systems), Code Case N 435 1 (which references the Winter 1985 Addenda for thin wall vessels), Appendix 111, paragraph 111 3430, requires that basic calibration blocks shall contain notches that are at least 1.0 inches long and 0.104t-0.009t2 + 10%/ 20% in depth.
Basis for Relief:
ALA 21 ALA 23: The notch depth is at 2% and should be 10%.
ALA 26: The notch is .125 in, under the required length of 1.0 inches.
ALA 28: The notch is .012 in. less than the 20% tolerance requirement for depth.
The only possible consequences of these discrepancies is that the sensitivity level of the ultrasonic instrument would be slightly higher than required, resulting in a more critical examination. Correcting these conditions on any of the above blocks would not be prudent and would be of questionable value when considering possible damage to the blocks by subjecting them to additional machining.
Alternate Examination: None; all blocks are acceptable for use as is.
000563 6 13 Gen. Rev. 1 L
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FNP-2 M 068 RELIEF REQUESTS FNP 2 E!L2 Component or Relief Area: Volumetric examination of all nozzle to-vessel welds in the pressurizer. Reference drawings APRl-2110, weld Nos. I through 6, and D 356354, sheet 2 of 3.
Requirement from which Relief is Requested: Item No. B3.110, Category B 0, Table IWB-25001 of ASME Section XI requires a volumetric examination of the nozzle to-vessel weld The applicable examination volume is shown in figure IWB 2500 7(b) and includes 100 percent of the weld length.
Basis for Relief: There is unrestricted access to perform examination of the required volume of both weld and base metal from the head side of these welds; however, the geometric configuration of all six nozzles (Attachment 9-1) prevents ultrasonic examination from being performed from the nozzle side of the weld to the extent
- required. While the required volume of weld metal can '
be examined, only approximately 25% of the base metal i
on the nozzle side of the weld can )e examined.
Alternate Examination: All these welds will receive a sr.rface examination of
- the areas not scanned by the ul*.rasonic method.
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04611 6-15 Gen. Rev. I
i FNP-2-M-068 i-
, RR-9 i ATTACHMENT 9-1 l
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NOZZLE FORGING -
(CARBON STEEL)
NOZZLE-TO-VESSEL WELD .
(CARBON STEEL) l VESSEL HEAD (CARBON STEEL)
WELD DEPOSITED CLADDING (STAIN LESS STEE L WELD)
PRESSURIZER NOZZLE-TO-VESSEL WELD CONFIGURATION 6-16 Gen. Rev. 1
FMP-2-M-068 RELIEF REQUESTS FNP-2 RR-10 Component.or Relief Area: Volumetric examination of no::le-to-pipe safe-end welds in all steam generators (primary side). Reference drawings APRl-4100, APRl-4200, and APRl-4300, weld Nos. 4DM and SDM, and D-356354 sheet 1 of 3.
Requirement from which Relief is Requested: Item No. B5.70, Category B-F, Table IWB-2500-1 of ASME Section XI requires a volumetric examination of nostle-to-safe-end butt welds in the steam generator.
Applicable examination volume is shown in Figure IWB-2500-8 and includes 100 percent of the weld length.
Basis for Relief: The configuration of the steam generator nostle-to-safe-end welds is shown in Attachment 10-1. Examination of these welds is limited both by no::le geometry and the presence of a weld-deposited clad overlay on the safe-end no::le interface. Ultrasonic examinations can be performed from the pipe side and the weld surface, but are severely limited from the no :le side by the rough, as-cast surface and the clad overlay.
Coverage of approximately 90 percent of the required volume is achieved from the pipe side of the weld.
Alternate Examination: Surface examinations will be performed on essentially 100 percent of the required examination area. Also, ultrasonic examinations will be performed from both the pipe and weld surfaceo as allowed by T-532 of ,
Section V. All of the weld metal, including the weld root, will be inspected.
04611 6-17 Gen. Rev. I
l S.G. NOZZLE INTEGRALLY CAST WITH HEAD QCAST CARSON STEEL)
FERRITIC WELD SUILD UP WELD OVERLAY llNCONEL)
"DUTTE RED" SAFE IND (STAINLESS STEEL WELD)
REACTOR COOLANT PIPE
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FNP 2 M 068 REllEF REQUESTS IE _Z RR-ll :
Component or Relief Area: Volumetric examination of the nozzle inner radius section for steam generator inlet and outlet nozzles.
Reference drawings APRl 3100, examination areas IRl and IR2, steam generators 2A, 2B, and 20, and D 356354, sheet I of 3.
Requirement from which Relief is -
Requested: ASME Code Item No. B3.140, Category B D, requires volumetric examination of the nozzle inside-radius section for steam generator nozzles. Figure IWB 2500 7 shows the applicable examination volume. Relief is !
requested from performing this examination for the inlet and outlet nozzles on all steam generators.
Basis for Relief: The steam generator primary side nozzles (Attachment 11.1) are integrally cast as part of the channel head; therefore, no welds exist which require volumetric examination. The steam generator nozzle inner radiused section cannot be volumetrically examined from the ,
outside of the nozzle or channel head because the rough, as-cast contact surface is not suitable for ultrasonic coupling and the geometrical configuration +
requires an excessively long test metal distance resulting in high ultrasonic attenuation. The areas inside of the nozzles and channel head are covered with-cladding in the "as-welded" condition; therefore, the associated surface contours and roughness do not provide the conditions necessary to perform the examination. Even with proper preparation of the inside surface for volumetric examination, an adequate examination of the area of interest (base metal just below the cladding) could not be achieved due to the resulting ultrasonic response at the clad-to base metal .
interface.
Alternate Examination: The inside surface of each steam generator primary side nozzle inner radiused section will be visually examined. The examination area will include the inner radius surface region shown in Section XI, Figure IWB 2500 7, to the extent practical.
04611 6-19 Gen. Rev. I
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FNP-2-M-068 l
RELIEF REQUESTS FNP-2 RR-12 Component or Relief Area: Delete VT-4 visual examination method and examination requirement and redefine VT-3 visual examination method in accordance with Paragraph IWA-2213 of ASME Section XI, 1986 Edition.
R.,'vement from which ) lief is Requessad: Item No. F3.50, Category F-C, Table IWF-2500-1 and paragraph IWA-2214 of ASME Section XI, 1983 Edition, require that VT-4 visual examination shall be conducted to determine conditions relating to the operability of components such PS snubbers and spring loaded / constant weight hangers.
Also VT-4 testing confirms functional adequacy, verification of the setting, or freedom of motion, which may require operability testing.
Basis for Relief Operability testir.g was inapproiately included in VT-4 as an examination method.
Also, paragraph IWA-2214(b) from the 1983 Section XI code is inconsistent with industry visual examination practices. An inspector does net perform bench testing of snubbers / constant-load / spring type supports.
Thests activities are performed by maintenance tecraicians. The 1986 Edition of ASME Sec': ion XI has deleted VT-4 examination altogether and has redefined VT-3 to include examinations for conditions that could affect operability or functional adequacy of snubbers, and constant load and spring typa supports.
A1 ternate Examination: None. Operability tests shall be perforaed in accordance with the Farley Technical Specifications.
04611 6-21 Gen. Rev. 1 l
FNP-2-M-068 l
1 RELIEF REQUESTS l I
FNP-2 ;
RR-13 l
Component or Relief Areas. Volumetric examination of pressure retaining branch pipe connection: welds in Class 1 ;
piping. Attachment 13-2 lists all affected i welds. Reference drawing D-356354, sheet 1 !
of 3. 1 1
Requirement from )
which Relief is .
Requested: Item No. B9.31, Category B-J, Table IWB-2500-1 of ASME Section XI, requires 1 volumetric examination of branch pipe ;
connection welds 4 in, nominal pipe size and 1 larger. Applicable examination volumes.are shown in Figures IWB-2500-9, -10, and -11 and i include 100 percent of the weld length.
Basis for Relief: The geometric configuration of these welds i (see Attachment 13-1) prevent ultrasonic l examinations from being performed from the . i weld surfaces. Attachment 13-2 describes the ;
location of those limited areas and the- ,
approximate examination coverage.
Alternate i Examination: None; however, the surface examinations as required by'the. Code will also be performed on these welds.
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04611 6-22 Gen. Ret. I '
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CENTERLINE NOZZLE l NOZZLE FORGING ,
(STAINLESS STEE L) !
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(CAST AUSTENITIC STAINLESS STEEL) l BRANCH NOZZLE CONNECTION WELD 6-23 cen. Rev. 1
i FNP-2-M-068 RELIEF REQUESTS FNP-2 i RR-13 ATTACHMENT 13-2 i f
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Category B-J, Branch Pipe Connection Welds j with Exam. Limitations ,
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Examinations >
Configurations Dwg. No. Weld No. Extent ,
Hot leg loop #1 APR1-4100 16 BC 80%. !
12 in, branch connection j
t Cold leg loop #1 APR1-4100 22 BC 80% :
12 in, branch connection iF
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Hot leg loop #2 APRI-4200 16 BC 80%
14 in, branch connection i Cold leg loop #2 APR1-4200 21 BC 80%
12 in, branch connection j
Hot. leg' loop #3 APR1-4300 16 BC 80% .
12'in. branch connection l
Cold leg loop #3 APR1-4300 21 BC 80% ;
12 in. branch connection
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t 0461I 6-24 Gen. Rev. 1 .,
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i FNP-2-M-068 ,
RELIEF REQUESTS l FNP-2 !
l RR-14 f
component or i Relief Area: Volumetric examination of the' reactor vessel '
flange ligament areas. Reference drawing APR1-1100A and APR1-1300, Examination :
Identification No. L1, L25, L26, L27, L41, ,
L42, L43, L57, L58, and D-356354, sheet 1 of ;
3.=
i Requirement from l which Relief is Requested: Item No. B6.40, Category B-G-1, Table !
IWB-2500-1 of ASME Section XI, requires a j volumetric examination of threads in reactor ;
vessol flange stud holes. The applicable examination volume is shown in Figure ,
Basis for Relief: During the examination, these guide studs prevent:the ultrasonic transducers mounted on .
the remote _ tool arm from accessing the I ligaments around each guide stud as well as (
the ligaments between the stud holes on '
either side of the guide studs (numbers 1, _,
25, 27, 41, 43, and 57). $
Alternate Examination: None; however, the remaining 49 ligaments .
will be ultrasonically examined as required by the ASME Code,Section XI.
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I 04611 6-25 Cen. Rev. 1 4
l FNP-2-N-068
)
RELIEF REQUESTS :
FNP-2 RR-15 ,
Component or Relief Area Visual examination of reactor coolant pump internal pressure boundary surfaces.
Reference drawing D-356354, sheet I of 3.
Requirement from which Relief is !
Requested: Item No. B12.20, Category B-L-2, Table IWB-2500-1 of ASME Section XI, requires a visual-(VT-3) examination of Class I pump internal pressure boundary surfaces. This examination is limited to one pump in a group performing similar functions in a system.
Basis for Relief: Disassembly of a reactor coolant pump for the visual examination during the inspection ;
interval in the absence of required maintenance represents an unnecessary exposure te radiation and contamination and ,
violates as-low-as-reasonably-achievable (ALARA) guidelines for occupational dose ,
rates. In view of the cost in man-rem and in view of the minimal benefits obtained, we conclude that this code requirement does not provide sufficient' benefits to justify the radiation exposure.
Alternate Examination: The exterior of the RCP casing will be visually examined during the RCS hydrostatic pressure test as required by IWB-5000. A visual examination, not to excecd once per interval, will be performed on the internal pressure boundary surface of one RCP as required by Item B12.20, Category'B-L-2, if maintenance or operational problems are encountered which require the removal and ,
disassembly of the internals.
1 i
04611 6-26 Gen. Rev. 1
FNP-2-M-068 RELIEF REQUESTS FNP-2 RR-16 Component or Relief Area: Visual examination of the internal pressure boundary surfaces of Class 1 valves. See Attachment 16-1 for valves requiring this examination.
Requirement fram which Relief is Requested: Item No. 12.50, Category B-L-2, Table IWB-2500-1 of ASME Section XI, requires a visual (VT-3) examination of the internal pressure boundary surfaces of Class I valves exceeding 4 in. nominal pipe size. The examinations are limited to one valve within '
each group that are of the same constructional design and manufacturing method, and that perform similar functions in the system.
Basis for Relief: Disassembly of these valves for visual examination during the inspection intorval in the absence of required maintenance represents an unnecessary exposure te radiation and contamination and violtates ALARA guidelines for occupational dose rates. In view of the cost in man-?em and in view of the minimal benefits obtair.ed, we conclude that this code requiremer.t does not provide sufficient benefits to justify the i radiation exposure. In addition, the manufacturer of these valves neither recommends nor requires valve disassembly for the performance of routine maintenance or inspections.
Alternate Examination: As required by Section XI, IWA-5000, the -
exterior of this valve body will be visually examined during the RCS hydrostatic test. A visual examination, not to exceed once per interval, will be performed on the internal pressure boundary surface of one valve in each group listed in Attachment 16-1 as required by item B12.50 and Category B-M-2 if maintenance or operational problems are encountered which require disassembly and complete removal of the valve internals.
04611 6-27 Gen. Rev. 1
e "r-
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e-futR-2-M-064 RR-16 A TACl#tElIT 16-1 l ~
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. VALVE CROUPtIIG Croup .. Reference 86 0 Manufacture r System Valve 800. Description Dwe . 100.
1 Copes-Vulcan RHR Q2011V001A & B 12 in, gate valve D-356356, Q2E11VOOl6A & B sheet 1 of 1 2 Velan RHR Q2f11VO21A, 8,& C 6 in. check valve D-356355, sheets Q2E11VO51A, B,& C 1 or 4 and (Low head safety 2 of 4 injection) 3 Velan High head safety ' Q2E21V016A & 9 6 in. chech valve D-356355, sheet injection Q2E21V077A, B&C 1 or 4 4 Crosby Pressurizer safety Q2813V031A, B&C ti in. safety valve D-356354, sheet 2 of 3 5 Copes-Vulcan Accumula tor 02E21V032A, B&C 12 in. check valve D-356355, sheet
. d i scha rge Q2E21V037A, B&C 2 or 4 fe0IE:
One valve in each or the above graups is required to be examined.
6-28
- Cen. Rev. 1 a
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FNP-2-M-068 RELIEF REQUEST FNP-2 RR-17 Component or Relief Area Reference system for all welds and areas subject to surface or volumetric examination.
Requirement from which Relief is Requested: IWA-2600 of ASME Section XI requires the establishment of a reference system for all r welds and areas subject to surface or volumetric examination. This system shall permit identification of each weld, the location of each weld centerline, and marking at regular intervals along the length of each weld.
Basis for Relief: To perform actual marking of welds in order to identify each weld centerline, length locations, etc., would require many manhours of radiation exposure. Many of the welds are <
insulated and as such many manhours of radiation exposure would be required to remove and reinstall insulation just to facilitate marking. Also many manhours cf radiation exposure would be involved in ,
marking the welds.
Alternate Examination: Administrative controls which are detailed in procedures provide adequate instructions to ensure measurements are repeatable and that any indications can be accuratel*/ located.
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1 04611 Gen. Rev. 1 6-29 l
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FNP-2 M 068 REllEF REQUEST FNP 2 RR.18 I l
Component or !
Relief Area: Volumetric examination of pressure retaining welds in the re enerative heat exchanger. Reference drawings APR2 llb0, we ds No. I through 12, and D 356356, sheet 1 of 4.
Requirement from :
which Relief is 1 Requested: Items No. 01.20 and Cl.30, Category C A, Table IWC-2500 1 of ASME Section XI, require volumetric examination of pressure vessel head circumferential welds and tube sheet-to shell welda. The applicable examination volume is shown in figures IWC 2500-1 and -2, and includes essentially 100 percent of the weld length.
Basis for Relief: The regenerative heat exchanger shell is fabricated from centrifuga11y cast austenitic steel material which limits ultrasonic examination to the half node technicue. The geometric configuration of the weld surface anc the location of adjacent nozzles and supports provide limitations to the 1 extent of the examination coverage. Approximately 50 to 60 ,
percent of the required volume can be examined. !
Alternate l- Examination: Ultrasonic examination will be performed to the maximum extent practical (which is approximately 50 to 60 percent) on a best effort basis. Surface examination of all accessible surfaces within the examination boundaries will t also be performed to supplement volumetric examinations. ;
04611 l-6-30 cen. Rev. 1 l
FNP-2-M-063 RELIEF REQUEST FNP-2 ,
RR-19 I i
Component or Relief Areat Volumetric examination of the pressure retaining welds in thin wall Class 2 pressure vessels. Affected areas are head-to-shell and flange-to-shell welds in the following: .
f o seal water heat exchanger - reference l
, drawings APR2-1130 and D-356356, sheet 2 ,
f of 4.
o Letdown reheat heat exchanger - reference .,
drawings APR2-1150 and D-356357, sheet 1. 1 i
o Reactor coolant filter - reference !
drawings APR2-1310 and D-356356, sheet 2 ,
of 4. l r >
o Seal water return filter - reference drawings APR2-1300 and D-356356, sheet 2 :
of 4. j Requirement from 4 which Relief is Requested: Items No. C1.10 and C1.20, Category C-A, Table IWC-2500-1 of ASME Section XI, requires volumetric examination of pressure retaining welds in Class 2 pressure vessels.
Applicable examination volumes are shown on Figures IWC-2500-1 and -2 and include t
essentially 100 percent of the weld length, Basis for Relief: The thickness of the materials utilized for the construction of these components (0.165 I to 0.188 inches) is such that meaningful results could not be expected with ultrasonic examination.
Alternate Examination: Welds on thw e components will be examined by surface and visual methods. ,
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04611-6-31 Gen. Rev. I
r FNP-2-M-068 RELIEF REQUEST FNP-2 RR-20 ,
Component or Relief Area: Surface examination of integrally welded attachments on charging pumps. Reference pump No. 2 A, 2B, and 2C, drawings APR2-3110, and D-356356, sheet 2 of 4.
Requirement from which Relief is Requested: Item No. C3.30, Category C-C, Table IWC-2500-1 of ASME Section XI, requires a surface examination of 100 percent of the -
areas required by Figure IWC-2500-5 for each welded attachment of one charging pump, t
Bacis for Relief: Due to the component configuration, location, '
and support design, approximately 20 percent-of each integrally welded attachment is inaccescible for examination.
Alternate Examination: None; all accessible portions of welded attachments will receive a surface examination supplemented by a visual examination.
l l
l 9
I I
I 04611 cen. Rev. 1 6-32
FNP-2-M-068 RELIEF REQUEST FNP-2 RR-21 Component or Relief Area: Hydrostatic testing of Class 2 containment pressure sensing lines. Reference drawings D-356355, sheet 3 of 4, penetration no. 65, 73, 74, 75, 76, and 97a. ,
Requirement from which Relief is ,
Reque sted: Item No. C7.40, Category C-H, Table IWC-2500-1 of ASME Section XI, requires a hydrostatic test for all Class 2 pressure retaining components once every 10-year inspection interval, in accordance with paragraph IWC-5222.
Basis for Relief: These containment pressure sensing capillaries are filled with silicone oil and are sealed. There are no provisions to pressurize these lines with additional silicone oil to satisfy the ASME Section XI hydrostatic test requirements. However, a full range (0-65 pai for low pressure sensoric ,
and 0-225 psi for high pressure sensors) calibration is performed on these lines every 18 months to verify their accuracy and integrity, in accordance with Farley Surveillance Test Procedures STP-220.1 through 220.4 and STP-220.11, 220.12
' (T.S. 4.3.3.8/6B). Any leakage from these pressure sensing lines during normal operation would result in instrument failure and would be corrected to maintain instrument operability.
Alternate Examination: The calibration of these sensors will be performed in lieu of a hydrostatic or >
pressure. test.
1 l
l l
04611 6-33 Gen. Rev. 1
I FNP 2 M 068 l REllEF REQUEST ,
f2:.2 i
ILR:.22 Component or Relief Area: Hydrostatic testing of portions of Class 2 piping and '
interim components at reduced pressure.
s 1
The following portions of Class 2 piping are affected.
A. Chemical injection to main feedwater lines between valves 02N25V002A, B, and C and main feedwater lines (line Nos. DCB 1A, DCB-1B and DCB lC). Reference drawing 0-356342, Sheet 1 of 2. ,
B. Main feedwater lines from valves Q2N21V001A B, B B, and C B to the steam generators (line No. DBB 1).
Reference drawing D 356363, Sheet 1 of 1.
C. Steam generator blowdown lines to valves Q2G24V003A, B, and C from the steam generators (line Nos. CBB-5, CBD 6, CBB-7, CBB 8, CBB 9, and CBB 10). Reference e drawing D 356362, Sheet 1 of 3.
D. Auxiliary feedwater piping from valves Q2N23V0llA, B, and C to the main feedwater lines (line No. DBB 2).
Reference drawing D-356346, Sheet 1 of 1.
E. Charging pump discharge line between the charging pumps andisolationvalvesQ2E21V123A,B,andC;the mini-flow piping to isolation valve Q2E2)V265 (line Nos. CCB-16, CCB-17, and CCB 18). Reference drawing D 356356, sheet 2 of 5.
NOTE: Items A thre D are nonisolable piping associated with the steam generators, secondary side. Testing at reduced holding time is addressed in relief request RR 30.
Requirement from which Relief is Category C H, Table IWC-25001 of ASME Section XI, requires Requested:
a hydrostatic test of all Class 2 pressure retaining ;
components once every 10 year inspection interval in accordance with paragraph IWC-5222.
000563 6-34 cenc Rev. I
h FNP-2-M 068.
REllEF REQUEST FNP-2 RR-22 (Continued)
Basis.For Relief: The portions of the Class 2 systems listed above cannot be isolated from lower pressure rated Class 2 piping. >
Performing the hydrostatic tests at the required pressure would result in overpressurizing the lower pressure rated Class 2 pipirg.
Alternate Examination:' Visual examination for evidence of leakage will. be co1 ducted on the portions of Class 2 systems listed above while at the test pressure for the lowest pressure rated Class 2 piping.
L i
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i a
000563 6-35 Gen. Rev. 1 f
i FNP-2-M-068 l
RELIEF REQUEST FNP-2 RR-23 Component or Relief Area: Hydrostatic testing of. portions of: Class 2 components to the requirements of the connecting Class-1 piping. Affected portions are as follows:
A. . Vents, drains, instrumentation-lines, and branch connections off Class 1 lines (line No. CCB-27, CCB-33, CCB-34, CCB-38, CCB-39, CCB-40,-CCB-41, CCB-42, CCB-43, CCB-44, CCB-46A, CCB-46B, CCD-46C, CCB-47A, CCB-47B, and CCB-47C).
Reference drawings D-356354, sheets'l-of 3, 2 of 3, 3 of 3, D-356347, sheet 1 of 3, and D-356356 sheet 1 of 5.
B. Pressurizer cpray valves. bypass lines (line No. CCB-57). Reference drawing D-356354, sheet-2 of 3. ,
C. Sample lines off reactor coolant system (RCS) loops and pressurizer.(line No.
CCB-37,-CCB-54, CCB-55, and CCB-56).
Reference drawing D-356354, sheets 1 of 3, 2 of 3, and D-356347, sheet 2 of 3.
D. Boron injection' tank;dischargeLto RCS (cold legs) between valves Q2E21V004A and B, Q2E21V029, and-Q2E21V062A, B,.and C (line No..CCB-21Eand CCB-50). Reference drawing D-356355, sheet 1 of-4.
E. High-head safety injection (HHSI) pump.
discharge to RCS (cold legs) between valves Q2E21V063 and Q2E21VO66A, B, and C (line No. CCB-22). Reference' drawing
- D-356355, sheet 1 of 4. l F. HHSI. pump discharge to RCS (hot legs) -l between valves Q2E21V068 and Q2E21V078A, B, and C (line No. CCB-30). Reference drawing D-356355, sheet 1 of 4.
}
G. HHSI pump discharge to RCS (hot-legs) ,
between valves Q2E21V072 and Q2E21V079A, 1 B, and C (line No. CCB-31). Reference drawing D-356355, sheet 1 of 4.
1 0461I 6- 6 Gen. Rev. 1 l
' 41
- e Mr a a
i i
n FNP-2-M-068 i
RELIEF REQUEST FNP-2 RR-23 (Continued)
H. Branch lines connecting the accumulator- ;
7: discharge lines to the accumulator test ;
line (line No. CCB-24, CCB-53, and CCB-54). Reference drawing D-356355, sheet 2 of 4. ;
I.. Residual heat removal (RHR) punp discharge to RCS (hot legs) between valves Q2E21V044 and Q2E21V076A and B .
(line No. CCB-29). Reference drawing !
D-356355, sheets 1 of 4 and 2 of 4.
J. RHR to RCS (cold legs) between valves -;
Q2E21V023A and B and Q2E21VO21A, D, and C
!=
(lines No. CCB-22 and CCB-32). Reference '
drawing D-356355, sheets 1 of 6 rnd 2 of 4.
l K. Alternate charging line between valves-
, Q2E21V243 and Q2E21V113 (line No. CCB-9). *
< Reference drawing ~D-356356, sheet 1 of 5.
L L. Normal charging line between-valves L (Q2E21V244 and Q2E21V112-(line No.
CCB-10). Reference drawing.D-356356, f
1 sheet 1 of 5.
L M. Normal charging line control valve bypass line between valves Q2E21V143 and Q2E21V112 (line No. CCB-45).
Reference:
drawing D-356356, sheet 1 of 5.
N. Reactor coolant pump No. I seal leakoff lines to valves Q2E21V623A, B, and C (line No. CCB-48A, CCB-48B, and CCB-48C).-
Reference drawing D-356356, sheet 1 of 5. -
O.- Reactor pressure vessel (RPV) head' vent line from Class I line to' valves Q2B13HV-2 and Q2B13HV-4 (line No.
CCB-63). Reference drawing D-356354, sheet 1 of 3.
04611 6-37 Gen. Rev. 1 i
a o
FNP-2-M-068 b RELIEF REQUEST q FNP-2 RR-23 (Continued)
Requirement from which Relief is Reque sted : - Category C-H, Table IWC-2500-1 of ASME -1 Section XI ;;equires a hydrostatic test for i all Class 2 pressure retaining components 9 once every s 10-year inspection interval, in :
accoc3 nee with paragraph IWC-5222.
Basis for Relief: It is impractical to conduct.a Class 2 .
. hydrostatic test on the portion of the system i
. listed where the only means ofspressurizing i
..the ClassL2 system is through the Class 1 system or when the boundary between the two systems is.a check valve arranged for flow from the Class 2 system to the Class 1 l system.
Alternate
' Examination: Visual examination for evidence'of leakage- i will be conducted on these portions of "
l systems'in conjunction with the hydrostatic test performed on the adjoining Class 1 system.
i
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e a.
04611 6-38 Gen. Rev. I a: 1
FNP-2-M-068-RELIEF REQUEST FNP-2 RR-24 1
t i
!, DELETED e .
E, (NotRequired)
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04611
_ 6-39 Rev. 1
2
FNP-2-M-068:
RELIEF REQUEST FNP RR-25 Component or Relief Areas Hydrostatic test for the Class 2 pressure retaining reactor vessel flange seal leakoff ;
line.from the reactor vessel to valves Q2B13V019 and Q2B13V018 (line No.-CCB-36).
Reference drawing D-356354, Sheet 1 of 3.
Requirement from which Relief ic Requested: Category.C-H, Table IWC-2500-1 of ASME Section XI, requires a hydrostatic test for all Class 2 pressure retaining components once every 10-year inspection interval, in ,
accordance with paragraph IWC-5222.
Basis for Relief: Performance of a hydrostatic test for this system is impractical because pressurization of the flange seal leakoff line could potentially result in damage to the reactor ,
vessel flange seals. '
Alternate Examination: For the reactor vessel flange seal leakoff line from the reactor vessel, the portion of Class 2 piping'up to valves Q2B13V019 and Q2B13V018 will.be visually examined during the Class I hydrostatic test.
0461I 6-40 cen. Rev. 1
FNP-2-M-068 f RELIEF' REQUEST FNP-2 q RR-26 Component or Relief Areas Hydrostatic testing.of portions of. Class 2 piping systems isolated from the~ test boundary by closed check valves.- Affected lines are as follows, Reference dr& wing l D-356356, Sheet 2 of 5.
I, l A. Charging pump suction piping from the l chemical mixing tank between valve Q2E21V186 and check valve Q2E21V187 (line No. HCB-11).
B. Hydrogen and nitrogen supp'y piping to ,
the VCT from check valve (2E21V201 to isolation valves Q2E21V2CJ, and Q2E21V2O3 (line No. HCB-68).
l C. Charging pump suction piping from volume
-control tank between check valve-Q2E21V211 and locked: closed valve .;
Q2E21V212 (line No. 2" HCB-16).
D. Charging-pump suction piping from boric acid blender between check valve Q2E21V210 and normally closed valve p Q2E21V264 (line No. HCB-16). 4 Requirement from .
which Relief is Requested: -Category C-H, Table IWC-2500-1 of ASME-Section XI, requires a hydrostatic. test for
(
L all. Class 2 pressure. retaining. components ~
g once every 10-year-inspection interval in y accordance-with IWC-5222. -i n
R Basis-for. Relief: Pressurization of the portions of system 4' piping' listed above cannot behassured due to '
a the position of the check valves. The check
- . valves listed prevent flow from the test fill point to the specified boundary. valves.
Alternate Examination: Portions of the above mentioned Class 2 0 /- piping will be visually examined during the Class 2 system functional test.
04611- 6-41 Gen. Rev. I u
FNP-2-M-068 RELIEF REQUEST [
FNP-2 4 RR-27 i Component or Relief Areat Hydrostatic test for the Class 2 waste gas-drain filter line to VCT from isolation valve >
Q2022V249 through check valve Q2G22V248 (line No. HCE-92). Reference drawing D-356359, i sheet 5 of 8.
Requirement from which Relief is ;
Requested: Category C-H, Table IWC-2500-1 of ASME Section XI, requires a hydrostatic test of all Class 2 pressure retaining components once every 1.0-year inspection interval, in accordance with IWC-5222.
Basis for Relief: Pressurization of this portion of the waste gas drain filter line would require check valve Q2G22V248 to hold the hydrostatic test pressure. Leakage through this valve could potentially result in overpressurization and ;
subsequent damage of-the waste gas filter.
Alternate Examination: The portion of Class 2 piping between valve Q2G22V249 and check valve Q2G22V248 will be visually examined during the Class 2 system functional test.
e l
L 0461I 6-42 Gen. Rev. I l
FNP 2-M 068
?
REllEF REQUESTS i FNP-2 RR-28 i
Component or Relief Area: Volumetric examination of the nozzle inside radius section of the steam outlet nozzle on the Steam
~
Generators. . Reference drawing D-356350, sheet 1 of 3.
Requirement from which Relief is Requested: Item No. C2.22, Category C B, Table IWC-2500-1 of ASME L. Section XI, requires a volumetric examination of the L nozzle inside radius section for nozzles in pressure retaining vessels. The required examination volume is shown in Figure IWC-2500 4.
L Basis for Relief: The steam outlet nozzle is manufactured from a solid forging with seven (7) holes,feach 8 1/2 inches in diameter, drilled through the forging (Attachment 2a-1) l to provide flow restriction. The geometry of this.
nozzle with the drilled flow restrictor holes does not have-an inner radius and therefore no meaningful examination can be performed.
Alternate r L Examination: None.
l L
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f 04611 6-43 Gen. Rev. 1 n:
RR-28 Attachment 28 /
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, 6-44 Gen. Rev. I 9
x FNP 2-M-068 RELIEF REQUESTS f.F.El 81 12 Component or Relief Area: Hydrostatic testing of Class 2 boron injection recirculation' pump discharge piping between valves Q2E21V006A and B, Q2E21V005A and B, and the adjoining drain piping (line No. CCB 62). Reference drawing D-356355, sheet 1 of 4.
Requirement from which Relief is Requested: Category C-H, Table IWC-2500-1 of ASME Section XI, requires a hydrostatic test for all Class 2 pressure retaining components once every 10-year inspection interval, in accordance with IWC-5222.
Basis for Relief: Performance of a hydrostatic test at 3107 psi (1.25 Pd) on the portion of the system described above requires the use of' check valves which are subject to leakage when used as a hydrostatic test boundary. . These valves, which are welded in place, = cannot be removed and replaced by blind flanges. Experience has shown that these.1-inch Kerotest check valves have some leakage when subjected to pressures in this range.
Leckage past these valves could potentially pressurize and overstress the adjoining Class 3 piping which has a design pressure of 150 psi, t Alternate Examination: -These lines will_ be visually examined during operation as a part of the' adjoining Class'3 system leakage test which will be performed at 150 psi.
04611 6-45 Gen. Rev. 1
I' -
m n
FNP-2-M 068 RELIEF REQUEST s
-FNP 2 t
RR-30 Component or ,
- Relief Area: Hydrostatic testing of the Class 2 portion of the steam' i generators and associated piping. Reference drawings-o .U 356350, sheet 1 of 2 and D 356362, sheet-1 of 3.
Eq1g: Testing at reduced pressure for portions of this piping.is addressed in relief request RR-22, items A thru D. 1 Requirement from which Relief is Requested: Item No. C7.10, Category C-H, Table IWC-2500-1 of ASME Section XI, requires a system hydrostatic test of Class 2 -i pressure retaining pressure vessels once every 10 year 1 inspection interval, in accordance with IWC-5222. Also, '
paragraph IWA 5213(d) requires a 4-hour holding time for hydrotest of the insulated system.
Basis for Relief: In order to prevent undue stress on the steam generators, ,
Westinghouse recommends that the hydrostatic _ test of-the i secondary side of the steam generators be conducted at~1.25 I Pd for a minimum of 10 minutes and a maximum of 30 minutes, and then reduced to operating pressure, 1.0 Pd, for the-balance of the 4-hour holding period. .The related Class 2 piping is hydrostatically tested along with the steam generator.
Alternate.
L , Examination:- The Class 2 portions of the steam nonerator and related piping will be hydrostatically tested at 1.25 Psv for a
- - minimum of.10 minutes and a maximum of 30 minutes. -The L test pressure will then be reduced to 1.0 Pd for the.
remainder of the required 4-hour holding time.
l i
e 000563 Gen. Rev. 1 6-46 J <
FNP 2-M 068 REllEF REQUEST [
$ FNP-2 h
RR-31 Component or L
Relief Area: Visual- (VT-2): examination for leakage of Class 3 service-water pumps. Reference drawings D-356370, sheet 2 of 9.
l' Requirement from which Relief is -
Requested: Paragraph IWD 2510 and Table IWD-2500-1 of ASME Section XI require that all Class 3 pressure retaining components be o subjected to visual examinations (VT-2) in conjunction with the system pressure tests required by paragraph IWD 5000.
, Basis for Relief: The service water pumps are vertical pumps and, due to
_ component design, the pump and supporting column are submerged in an inaccessible wet pit. Only the motor and l discharge nozzle are accessible above the operating deck.
L
! Alternate l Examination: Visual inspection of the discharge nozzles will be performed p while the pumps are operating. The pump casings will-be ,
f visually inspected each time the pumps are removed for h maintenance.
}
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l 1
04611 6-47 Gen. Rev. 1 1
e f
FNP-2-M-068 4
RELIEF REQUEST FNP-2 RR-32 Component or-Relief Areat Visual (VT-2) examination of Class 3 pressure J retaining piping which is encased in concrete in the spent-fuel pool cooling system.
Reference drasing D-356360, Sheet 1 (line I Nos. HCC-105, HCC-107, and HCC-108). ,
Requirement from which Relief is Requested: Paragraph IWD-2510 and Table IWD-2500-1 of ASME Section XI require that all Class 3 pressure retaining components be subjected to visual examination (VT-2) in conjunction with ,
the system pressure test requirements of l IWD-5000.
Basis for. Relief: The design of'the piping system does not provide any means to visually access the enct. sed portions. Visual examination for leakage at ground. level is also_not possible.
Alternate Examination: Integrity of the encased piping will be demonstrated during normal system functional testing.
04611 Gen. Rev. 1 6-48
FNP 2-M-068-RELIEF REQUEST FNP-2 RR 33 ;
4
[ Component or Hydrostatic testing of portions of Class 3 piping and f . Relief Area: -
components in the following systems which operate continuously during.all modes of plant operation: l L o Service water (1) - reference drawings ;
D-356368, sheet 1, D 356370, sheets 1, 2, '
and 3 of 9, and D-356344,- sheets 1, 2, 3, and 4. l 1
- 1. Portion of piping upstream of valves Q2P16V540' and.Q2P16V541. 4
- 2. Portion of piping downstream of valves Q2P16V516 j and Q2P16V517.
o Component cooling water (2) - reference drawing.
l D-356343, sheets 1, 2, and 3.
- 1. Component Cooling Water Surge Tank q L 2. Portion of piping from CCW surge tank to valves l l 02Pl7Vll7A, Q2P17Vil?B, Q2P17V121A, Q2Pl7V121B, Q2Pl7V110A, Q2Pl7V1108, Q2Pl7V110E, Q2Pl7V110F, Q2Pl7V109A, Q2Pl7V109C, Q2Pl7V278A,'02Pl7V278B,.
-02Pl7V278C, Q2P17V144A, 02Pl7V1440, Q2Pl7V017A,-
Q2Pl7V0178 l o Chemical and volume centrol (2) - reference drawings D-356356, sheet 3, and D-351115, sheet 1.
- 1. Portion of piping from valve Q2E21V019 to discharge of Boron Injection Recirculation Pumps - valves
~Q2E21V006A and Q2E21V006B.
L o Reactor makeup - reference drawings D-356353,. sheet _1 and D-356369, sheet 1. .
l 1
o Spent fuel pool cooling (2) - reference ' drawing 4 D-356360, sheet 1. '
- l. Portion of piping downstream of valves Q2G31V003AL and Q2G31V0038.
- 2. Portion of piping downstream of valve Q2G31V005.
- 3. Portion of piping upstream of valves Q2G31V001A and 02G31V0018.
000563 6-49 Gen. Rev. 1
________.___---.m.._ .--______._____________-___m _ _ _ _ - _ _ . - . . _ _ _ . - . _ _ _ . _ _ _ _ _ _ - _ _ ____ _
4 FNP-2-M 068 RR-33 (Continued)
Notes:
-(l) These portions of Class 3 piping are unisolable from non-safety related piping providing service water supply to and from the turbine building.
(2) These portions of Class 3 piping and components cannot-be isolated for hydrostatic test since removal from-service for testing would render the entire system inoperable.
Requirement from which Relief is Requested: Paragraph IWD-2510 and Table IWD-25001 of ASME Section XI require that all Class 3 pressure retaining components be subjected to visual examination (VT-2) in conjunction with 1 the system pressure tests of IWD-5000.
Basis for Relief: Hydrostatic testing of the above systems is not practical since they operate continuously during all modes of plant l operations.
Alternate Examination: Functional operation of the systems demonstrates structural and leaktight integrity. Visual inspection to verify leaktightness will be performed while the systems are at
- normal operating pressure.
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L 000563' 6-50 Gen. Rev. 1 l.
l o
FNP-2-M-068 .
1 RELIEF REQUEST FNP-2 RR-34 Component or .
Relief Areas Hydrostatic testing of Class 3 spray additive '
piping and components in the containment spray system (reference drawing D-356355, Sheet 3).
Requirement from ;
w).ich-Relief is 1 Requested:- Paragraph IWD-2510 and Table IWD-2500-1 of ASME Section XI require that all Class 3 ,
pressure retaining components be subjected to ;
visual examination (VT-2) in conjunction with the system pressure test of IWD-5000.
Basis for Relief: While in service these spray additive lines have an operating pressure of 15.psig and temperature of 100*F, which is well below the design conditions.of 210 psig pressure and 300'F temperature. Therefore, a. system hydrostatic test at 1.25 Psy would not provide a-moaningful tent. In addition, the '
hydrostatic test will involve handling of highly corrosive sodium hydroxide, which is i undesirable and hazardous to personnel safety.
..i Alternate Examination: A measured flow test in accordance with plant l Technical Specification paragraph 4.6.2.2d
[ will be conducted periodically to assure the !
leaktightness of these Class 3 components.
1 l
l
-0461I Ocn. Rev. 1 6-51
FNP-2-M-068 RELIEF REQUEST FNP-2 l.
RR-35 Component or j Relief Area Hydrostatic testing of Class 3 portions of j buried piping in the following system o Service water - reference drawing D-356370, Sheet 2, virtually all of the lines on.this drawing.
Requirement from which Relief is Requested: Paragraph IWD-2510 and Table IND-2500-1 of ASME Section XI require that all Class 3 l pressure-retaining components be subjected to L visual examinatirn (VT-2) in conjunction with l
the system pressure tests of IWA-5000.
Paragraph IWA-5244 describes the detailed requirements for buried components.
Basis for Relief: .The design of this system does not allow access for visual examination as required by IWA-5244.
Alternate Examination: Buried piping will be inspected by conducting a visual observation of the ground-(at ground '
elevation) for wet spots while the systems are at operating pressure. This is in accordance with the Final Safety Analysis Report, paragraphs 3.1. 41 and 9.2.1. 4.
04611 Gen. Rev. 1 6-52
FNP-2-M-068-RELIEF' REQUEST FNP-2 RR-36 Component or Relief Area Visual (VT-2) examination of heat exchanger tubes of Class 3 pressure retaining safety-related heat exchangers.
o Three each component cooling water ,
HX-Q2?17 H003A-B, H001B-AB and H001C-A -
~
reference drawing D-356343, sheet 1 of 3.
Requirement from which Relief is Reque s ted : Paragraph IWD-2510 and Table IWD-2500-1 of ASME Section XI require that all Class 3' pressure retaining components be subjected to a visual examination (VT-2) in conjunction with the. system pressure tests of'IWD-5000.
Basis for Relief: Due to component design and limited accessibility, these heat exchanger tubes.
cannot be visually inspected-under high' . ,
pressure hydrostatic test conditions. !
Integrity of the component is assured by testing the component as a unit.
Alternate Examination: Tube side inspection will be performed by isolating the heat exchanger, removing the waterbox covers, and pressurizing the shell side with' water. Tube leakage is indicated if there is any flow from the tubes while in this configuration. This type inspection will be performed at least once per ;
inspection interval.
5 9 i
.0461I 6-53 Gen. Rev. 1
p FNP-2-M-068. !
I ,
RELIEF REQUEST FNP-2 RR-37 Component or Relief Area Visual-(VT-2) examination of the cooling.
coils for the following Class 3-pressure retaining safety-related coolers o .Four units containment coolers -
Q2212H001A-A, H001B-A, H001C-B and HOO1D-B.
Reference drawing D-356344, sheet 4 of 4 -;
I e Two units auxiliary feedwater pump room 1 coolers - Q2E16H005A-A and HOO5B-B.
o Two units component cooling water pump. room coolers Q2E16H004A-A and H004B-B.
o Two units containment spray pump, room-coolers Q2E16H002A-A and H002B-B.
c -Two units RHR/LHSI pump room coolers' ;
Q2E16H003A-A and-H003B-B. l Reference drawing D-356344, sheet 2 of 4.
L i
-o Three units battery charging room coolers "1 Q2EiGH006A-A, H006B-B, and H006C-AB. I I
I o Three units charging pump room coolers l Q2E16H001A-A, H001B-AB, and H001C-B. !
l .i l o" o Two units 600-V: load center coolers l
Q2E16H009-A and H010-B.
F4 o Two units motor control center room coolers 1 Q2E16H007-A, H008-B.
Reference drawing D-356344, sheet -- 3 of: 4.
.s Requirement from' which Relief is Requested: Paragraph IWD-2510 and-Table I"9-2500-1 of ASME Section XI require that all Class 3 .
pressure retaining components be subjected to 1 visual examination (VT-2) in conjunction with the system pressure tests of IWA-5000' .
L E 04611 6~54 L Gen. Rev. 1 I
l
-FNP-2-M-068-RELIEF REQUEST-FNP-2 RR-37 (Continued)
Basis for Relief: Due to the component design, the cooling coils (heat exchanger tubes) cannot be visually inspected during the conduct of system pressure test.
Alternate Examination: The normal operation of these cooling units ,
demonstrates their structural and leaktight integrity. Visual inspection to-verify leaktightness will be performed while the system is at normal operating pressure.
-Also, the coolers provided with the drain basin will be inspected by observing for abnormal flow (other than normal condensation). >
i 0461I Gen. Rev. 1 6-55
1-l FMP-2-M-068 RELIEF REQUEST FNP-2 RR-38 Component or Relief Areas Hydrostatic testing of Class 3 pressure retaining piping of the auxiliary steam system. Reference drawing D-356350, sheet 2 of 2 (all class 3 portion).
-Requirement from which Relief is Requested ' Paragraph IWD-2510 and Table IWD-2500-1 of ASME Section XI require that all Class 3 pressure retaining components be subjected to visual = examination (VT-2) in conjunction with:
the system pressure test described in IWD-5000.
Basis for Relief: There is no practical means of isolating the above portions of the auxiliary steam system-and, therefore, hydrostatic testing cannot be conducted on these lines.
Alternate Examination: Visual inspection to verify leaktightness-will be performed while these lines are at normal operating pressure.
I l
04611 6-56 Gen. Rev. 1
,, o 3
FNP-2-M-068 i
' RELIEF REQUEST FNP-2 RR-39 Component or Relief. Areas Hydrostatic testing of Class 3 pressure retaining auxiliary feedwater pun.p minimum flow piping. Reference drawing D-3563AC sheet 1.
o Line No. 2"DBC between valve-Q2N23V019A and flow orifice F03214A. <
o Line No. 2"DCB between valve Q2N23VOl9B and flow-orifice F03214B. I o Line No. 2"DBC-4 and 3"DBC-4 -'between valve Q2N23V0lO and flow orifice F03219.
Requirement from which Relief is Requested: Paragraph'IWD-2510 and Table IWD-2500-1 of T ASME Section XI require that all' Class.3
- pressure. retaining components be subjected-to= ,
a visual examination (VT-2)-in.:enjunction with the system pressure tests of.IWD-5000,-
Basis for Relief: Performance of a hydrostatic test on the portions of the piping system' listed above could overpressurize thetiower pressure,
.'noncode piping downstream of these flow orifices. ,
q
, Alternate .
L Examination: These lines'will receive a visual. examination
! during normal. operation 1at system operating; l temperature.and pressure.
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04611 Gen. Rev. I 6-57 t
l FNP-2-M-068 !
i h,' <
RELIEF REQUEST FNP-2 !
RR-40 Component or .
Relief Area Hydrostatic testing of all Class 2' branch pipe lines from the volume control tank (VCT) to the first valve. Affected'11nes are listed belows o ' Reference drawings D-356356, sheet 2 of 5, lines from VCT to valves Q2E21V260, 7 Q2E21V209, Q2E21V356,.Q2E21V152,- i; Q2E21V201, Q2E21V196, Q2E21V262, l Q2E21V261, Q2E21V193, Q2E21V376A, Q2E21V337, and Q2E21V423.
o Reference drawing D-356357, sheet 1:of 1, line from VCT to valve Q2G12V029.
o Reference drawing D-356359,-sheet 5 of 8, line from VCT to valve Q2G22V249, and line from-VCT to valve'Q2G22V189.
l o Reference. drawing D-356359, sheet 6 of 8, line from VCT to valve Q2G22V081.
i o Reference drawing D-356347, sheet 1 of 3, line from VCT_to valve Q2P15HV3117.
Requirement from '
which Relief is E . Requested:
Category C-H, Table IWC-2500-1 of ASME-Ps Section_XI, requires a hydrostatic: test for
- . all Class 2 pressure retaining components once every.10-year' inspection interval, in accordance with IWC-5222.
Basic for Rel.4 tf: The Class 2 portion'of piping as referenced above cannot-be-isolated from the tank. The i 1VCT tank is designed to 75 psig and the .
associated piping is designed to 150 psig.
Therefore, the only practical means to t hydrotest the tank associated piping-is based on the VCT design pressure.
T , Alternate
- g Examination: None. The connecting lines to the VCT tank will be hydrostatically tested to the same pressure as the tank.
U: 0461I' 6-58 Gen. Rev. 1 Y
E.
FNP-2-M-068 RELIEF' ' QUEST FNP-2:
RR-41 Component or '
Relief Area: Break away drag test for hydraulic snubbers.-
Requirement from a which Relief is Requested: Paragraph IWF-5400(b)(1) of ASME Section XI _
- requires test verification of snubbers for maximum drag during low velocity displacements.
i l Basis for Relief: Hydraulic snubbers are inherently l
inconsistent when this particular test is considered. The load required to initiate movement will vary considerably between identical snubbers. The break-away force s L required to initiate movement would be l determined by a number of variables (viscosity of hydraulic fluid, valve spring H rates, temperature, etc.), all of which have no. relevancy to snubber integrity. .While ,
l break-away force for mechanical snubbers is a l relatively consistent'value whose increase is
- related to snubber integrity, this is not the i
case with hydraulic snubbers. The manufacturers of hydraulic snubbers have not i
. recognized break-away force as a test variable that is relevant to snubber integrity in that they have not addressed this parameter in their technical information. .!
- Alternate
= Examination: None.
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i i 04611 6-59 Gen. Rev. 1
e !
FNP-2-M-068 RELIEF REQUEST-FNP-2 RR-42 Component or Relief Area: Additional sample testing requirements for snubbers.
Requirement from which Relief is Requested:' Paragraph IWF-5400(c) of ASME Section XI-requires an additional sampling of 10 percent-of the total number of snubbers to be tested.
if the initial 10-percent representative-sample has failed inservice testing.
Additional sample testing is to continue 1 until all units within the sample have passed.
inservice testing.
Basis for Relief: The additional. sampling plan required by.
IWF-5400(c) is more restrictive than the existing expansj.n plan detailed in Farley Technical-Speci.1 cation 3/4.7.9c. The existing expansion plan detailed in 3/4.7.9c /?
meets the following statistical goals set forth as the Bases in Farley Technical Specifications B 3/4.7.9: 1 To provide assurance of snubber functional reliability, a representative sample of the installed snubbers will be functionally .
tested during plant' shutdowns.at 18-month intervals. . Selection of a representative sample according to the expression 35(1+c/2) provides a confidence level of approximately 96 percent that 90_ percent to 100 percent of.
the snubbers in the plant will be OPERABLE within acceptance limits, where c.is the_ l allowable number 1xf snubbers not meeting the acceptance criteria. Observed failures of these sample snubbers shall require .
functional testing of additional units, Alternate Examination: Snubber surveillance testing will be performed in accordance with the Farley Technical Specifications. o t
6-60 0461I Gen. Rev. 1
FNP-2-M-068: 1 RELIEF REQUEST
, FNP-2 RR-43 Component or '
Relief Areas Hydrostatic testing of Class 2 portions of the RCS head vent lines. Reference drawing D-356354, sheet 1 of 3, line No. 1" CC8-63 ,
y between solenoid valves Q2B13HV-2 to ;
Q2B13HV-1 and Q2B13HV-4 to Q2B13HV-3.
Requirement from which Relief is Requested: Item No. C7.40, Category C-H, Table
IWC-2500-1 of ASME Section XI, requires a hydrostatic test of all Class.2 pressure retaining components once every 10-year inspection interval, in accordance with paragraph IWC-5222.=
Basis for Relief: Hydrostatic testing of the RCS is performed in mode 2 of the reactor plant shutdown. In .i this mode the plant Technical Specifications require that all solenoid valves on the RCS head vent be maintained closed. This being the case, hydrostatic testing of the portion t between these valves at this time would be a violation of the Technical Specifications.
Another way to hydrotest these lines would be to pressurize the line after the head'has been removed. This would require actuating solenoid valves Q2B13HV-2 and Q2B13HV-4 with the aid of a temporary electric power source. The work associated with actuating these valves, installing test connections, and performing the hydrostatic test would-
% require excessive radiation exposure (approx.
- e. 1.5 man-rem).
This level of exposure is unwarranted in view ,
of the minimal benefits gained by : testing this relatively small section of pipe which is approximately 6 inches long.
Alternate Examination: Functional operation of this system demonstrates structural integrity. Visual inspection will be performed while the system is at normal operating pressure to verify leaktightness.
0461I 6-61 cc. Rev. 1
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f FNP 2-M 068 REllEF REQUEST ENP-2 RR-44 Component or -
Relief Area: Visual-(VT-2) examination of heat exchanger tubes of Class 3 -
pressure retaining safety-related heat exchangers. ,
o Two each spent fuel pool cooling HX-Q2G31 H001A B and-H001B A - reference drav:ings D 356343, Sheet 1 of 3, and D-356360, sheet I of- 1.
t Requirement from which Relief is .
Requested: Paragraph IWD 2510 and Table IWD-2500-1 of ASME Section XI require that all Class '3 pressure retaining components be subjected'to a visual examination (VT-2) in conjunction with the system pressure tests of IWD-5000.-
.i
? Basis for Relief: Due to component design and limited accessibility, these >
l heat exchanger tubes cannot be visually inspected under high ;
L pressure hydrostatic test conditions. Integrity of the component is assured by normal operation of the-system.
Alternate p Examination: Tube side leakage will'be identified by the existing in-line .
J radiation monitoring system and existing periodic sampling l of the Component Cooling Water and Spent Fuel Pool Cooling i Systems. If a tube leak is indicated, the water box covers will be removed and a visual examination (VT-2) performed to identify the leaking tubes. The tubes will be plugged prior l to returning the' heat exchanger'to service. l t
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000563 6-62 Gen. Rev. 1 l'
FNP-2aM-068 RELIEF REQUEST FNP-2 l RR-45 r
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DELETED -
(fiot Required) i l:
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l 04611 6-63 Rev. 1 l
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l FNP-2-M-066 :
, l RELIEF REQUEST l FNP-2 RR-46 ,
Component or Relief Area Scheduling for the performance of Class 2 and !
3 system hydrostatic tests to be accomplished I during the second ten-year inspection ;
interval.
Requirement from ,
which Relief is Requested: Table IWC-2500-1, Examination Category C-H, Note 5 and Table IWD-2500-1, Examination Categories D-A, 0-3, and D-C, Note 2 require that system hydrostatic tests be conducted at
- or near the end of the inspection interval or during the same inspection period of each inspection interval for Inspection Program B.
Basis for Relief: The system hydrostatic tests are scheduled on a periodic basis in accordance with Inspection Program B. As a result of performing additional tests during the first ten-year interval, it is necessary to move >
three (3) hydrostatic tests forward one period. The original schedule for performing l
hydrostatic testing was based on dividing the systems to be tested into s i.ghteen (18) ,
procedures. Due to operational conditions during the course of too interval, several ,
procedures were divided resulting in additional hydrostatic testing procedures to be performed. At the end of the interval twenty five (25) procedures reisted to cover the systems to be tested. ,
Alternate Examinations: All twenty five (25) hydrotest piocedures will be performed during the second ,
inspection interval. They will de scheduled to dictribute the testing evenly between the three (3) periods for the secend inte.tval.
6-64 0461I p,y,
l FNP-2-M-068
7.0 REFERENCES
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7.1 Documents
- 1. Title 10, Code of Federal Regulations, Parc 50, Section 55a.
l
- 2. ASME Boiler and Pressure Vessel Code,Section XI, 1974 :
Edition with Addenua through Summer, 1975.
- 3. ASME Boiler and Pressure Vessel Code,Section XI, 1983 i Edition with Addenda through Summer, 1983. l
- 4. Reg. Guide 1.14: Reactor Coolant Pump Flywheel i Integrity (Safety Guide 14, dated l 10-27-71).
- 5. Reg. Guide 1.26: Quality Group Classifications and Standards for Water-Steam and !
Radioactive-Waste Containing l Components of Nuclear Power Plants ;
(Safety Guide 26, Dated 3-23-72). !
- 6. Reg. Guide 1,65, Materials and Inspection for Rev. 0: Reactor Vessel Closure Studs, j
- 7. Reg. Guide 1.82, Sumps for Emergency Core Cooling l Rev. Os and Containment Spray Systems. l l
- 8. Reg. Guide 1.83, 'nrervice Inspection of Rev. 1: Pre :surized Water Reactor Steam Gen rator Tubes. ;
I
- 9. Reg. Guide 1.147, Inservice Inspection Co4e case :
Rev. 7: Acceptability - ASME Sr tion XI l 1 Division 1. l
- 10. Reg. Guide 1.150, Ultrasonic 7esting of Reactor Rev. 1: Vessel Welds During Preservice and Inservice Examinations.
- 11. Branch Technical General Information Required for Positions APCSB 3-1 Consideration of the Effects of a and MEB 3-1 Piping System Break Outside Con ta 4 mnant.
- 12. FSAR-Volume 5 Listing of Codes applicable to Section 3.2, construction of components.
Table 3.2-1 9
04611 7-1 Rev. I
i FNP 2 M 068 l
- 13. The following is a list of Code Cases from Regulatory Guide 1.147 that :
may be used at Farley Nuclear Plant:
N 98 12/05/84 N-408 07/12/84 N 211 05/07/87 N 409 1 12/07/87 N 216 05/07/87 N 415 09/05/85 N 234 12/05/84 N 416 12/05/85 !
N 235 02/14/85 N 419 07/17/85 l N 278 02/19/86 N 424 07/18/85 i N 306 05/07/87 N 426 07/18/85 i N 307-1 12/05/87 N 427 12/05/85 N 308 09/30/84 N 429 1 02/23/87 l N 311 05/07/87 N 432 02/20/86 j N 335-1 06/20/85 N 425 1 12/07/87 N 343 02/14/85 N 4361 12/07/87 N 355 02/14/85 N 437 07/30/86 N 356 07/01/88 N 444 12/07/87 .
N 375-2 04/05/86 N 445 05/07/87 ;
N 389 05/14/86 N 446 05/07/87 !
N 401 05/20/84 N 448 07/27/87 !
N 402 02/20/84 N 449 07/27/87 i
. N 406 04/05/84 N-457 12/07/87 i j
s T
s 000563 72 Rev. I t
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FNP-2-M-068 7.2 Letters i 1.
Inservice Inspection Program Initial Submittal letters dated July 25, 1980, from F. L. Clayton, APC, to A.
Schwencher, USNRC.
2.
Relief January dated Requested10, from Vessel Cladding Examinations, letter Varga, USNRC. 1983, frou F. L. Clayton, APC, to S. A.
3.
Relief January dated Requested28, from Pressure Testing Requirements, letter Varga, USNRC. 1983 from F. L. Clayton, APC, to S. A.
4.
Nuclear Regulatory Commission Notice of Granting Relief for Vessel Cladding Examinations, letter dated August 24, 3983, from S. A. Varga, USNRC, to F. L. Clayton, APC.
5.
Neclear Regulatory Commission Notice of Granting an Extension in Time for Certain Reactor Vessel Weld Examinations, letter dated September 9, 1983, frou S. A.
Varga, USNRC, to F. L. Clayton, APC.
6.
Nuclear Regulatory Commission Notice of Granting Relief After Completion of ISI Program Revtew, letter dated September 22, 1983, from S. A. Var 9a, USNRC, to F. L' Clayton, APC.
7.
Relief Requested from Charging Pump Examinations and Steam Generator Hydrostatic Test Examinations, letter dated July 27, 1984, from R. P. Mcdonald, APC, to S. A. Varga, USNRC.
l 8.
Nuclear Regulatery Commission Notice of Granting Relief for Charging Pump C4 sing Welds and Integrally Welded Supports, l
and for2 Hydrostatic Class Test Pressure for Steam Generators and Piping, letter dated December 18, 1984, from S. A.
L Varga, USNRC, to R. P. Mcdonald, APC, 9.
t-APC response to the USNRC Generic Letter 83-15 and ,
Regulatory letter from Guide 1.150, Revision 1, for Units 1 and 2 by F. L. Clayton, dated October 26, 1983. Jr., APC, to S. A. Varga, USNRC, 10.
Relief Requested from Inspection Requirements of certain Reactor Vessel Flange Tdge.mento, R? actor Coolant Pump Casing Internal Surfaces and Flange Bolts, letter dated October USNRC. 14, 1985, from R. P. Mcdonald, APC, to S. A. Varga, 11.
Nuclear Regulatory Commission Notice of Granting Relief for Reactor Vessel Flange Ligaments, Reactor Coolant Pump DecemberInternal Casing Surfaces 27, 1985, from L.
and Flange Bolts, letter dated S.
Mcdonald, APC. Rubenstein, USNRC, to R. P.
04611 73 Gen. Rev.I m
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FNP-2-M-068 1
- 12. Relief Requested from Inspection Requirements for Certain !
Pressure-Retaining Valve. Body Welds and Internal pressure I Boundary Surfaces, Letter dated March 11, 1986, from R. P.
Mcdonald, APC, to L. S. Rubenstein, USNRC.
- 13. Nuclear Regulatory Commission Notice of Granting Relief for i Pressure-ketaining Valve Body Welds and Internal Pressure Boundary Surfaces, letter dated June 19, 1986, from D. G.
Mcdonald, USNRC, to R. P. Mcdonald, APC. j i
- 14. Relief Requested from Inspection Requirements of Steam Generator primary side Nozzla Inner Radiused Sections. i Letter dated January 13, 196/ from R. P. Mcdonald, IT , to l L. S. Rubenstein, USNRC. '
- 15. Nuclear Regulatory Commission Notice of Granting Relief for l Steam Generator primary side Nozzle Inner Radiused Sections. Letter dated July 22, 1987 from E. G. Adensam, USNRC to R. P. Mcdonald, APC.
- 16. Request for Exemption from the Requirements of 10 CFR 50.55a(g)(4)(ii), .:etter dated June 22, 1988 from W. G.
Hairston, III, APC. to USNRC. ,
- 17. Nuclear Regulatory Commission Notice of granting ' Exemption from Certain Requirements of 10 CFR 50.55a(g)(4)(ii) -
Joseph M. Farley Nuclear Plant, Unit 2. Letter dated August 31, 3988 from Edward A. Reeves, USNRC to W. G.
Hairston, I!!, APC.
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04611 7-4 Gen. Rev. 1 i
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