ML20059J172

Safety Evaluation Accepting First 10-yr Interval ISI Program Through Rev 5,except Where Relief Denied

ML20059J172
Person / Time
Site:	Waterford
Issue date:	11/08/1993
From:	Office of Nuclear Reactor Regulation
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ML20059J163	List: ML20059J160 ML20059J172
References
NUDOCS 9311120067
Download: ML20059J172 (30)

Text

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7. Ifi J E l UNITED STATES :  !

1[ pi E NUCLEAR REGULATORY COMMISSION  ;

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,/ WASHINGTON, D.C. 20555 4 001

1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE FIRST 10-YEAR INTERVAL INSERVICE  !

l INSPECTION PROGRAM. THROUGH REVISION 5-ENTERGY OPERATIONS. INC.

WATERFORD STEAM ELECTRIC STATION. UNIT 3 l l

DOCKET NO. 50-382 t

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1.0 INTRODUCTION

I The Technical Specifications (TS) for Waterford 3 Steam Electric Station, Unit 3, state that the inservice inspection (ISI) and testing of American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure  !

Vessel Code and applicable Addenda as required by 10_ CFR 50.55a(g), except 1 where specific written relief has been granted by the Commission pursuant to =t 10 CFR 50.55a(g)(6)(1). Paragraph 50.55a(a)(3) of Title 10 of the Code of  :

Federal Regulations states that alternatives to' the requirements of paragraph  :

(g) may be used, when authorized-by the NRC, if (1) the proposed alternatives t would provide an acceptable level of quality and safety, or (ii) compliance -  ;

with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. _i Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components I (including supports) shall meet the requirements, except the design and access i provisions and the preservice examination requirements, set forth.in the ASME 'i Code,Section XI, " Rules for Inservice Inspection' of Nuclear Power Plant.  :

Components," to the extent practical within the limitations of design, i geometry, and materials of construction of the components. The regulations  ;

require that inservice examination of components and system pressure tests conducted during the first 10-year interval comply with-the requirements ~ 1n ,

the latest edition and addenda of Section XI of the ASME Code incorporated by  :

reference in 10 CFR 50.55a(b) on the date 12 months prior to the date of' ,

issuance of the operating license subject to the limitations.and modifications listed therein. The applicable edition of the ASME Section XI Code for the-Waterford 3 first 10-year ISI interval is the 1980 Edition through Winter 1981 Addenda.

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The components (including supports) may meet the requirements set forth in i subsequent editions and addenda of the ASME Code incorporated by reference.in '

10 CFR 50.55a(b) subject to the limitations and modifications listed therein.  ;

9311120067 931108 PDR ADOCK 05000382 2 u  :

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Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement. After eva1uation of the determination, pursuant to 10 CFR 50.55a(g)(6)(1), the Comission may grant relief and may impose alternative requirements that are determined to be authorized by law, wili not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the ,

licensee that cou1d result if the requirements were imposed. '

In a letter dated September 17, 1992, the licensee, Entergy Operations, Inc., )

submitted Revision 5 of the Waterford 3 Steam Electric Station, First 10-Year i Interval inservice Inspection (ISI) Program. Additiona1 information needed to i complete the review was requested by the NRC in a request for additional  !

information (RAI) dated April 5, 1993. The licensee provided most of the i requested information in a letter dated June 4,1993. However, after review of this information, further c1arification was required and was obtained from  !

the licensee during a conference call on June 30, 1993.

2.0 EVALUATION The staff, with technical assistance from its contractor, the Idaho National l Engineering Laboratory (INEL), has evaluated the Waterford 3 First 10-Year j Interval ISI Program, Revisions 4 and 5, the requests for relief from certain l ASME Code requirements determined to be impractical for Waterford 3 during the i first inspection interval, and additional information related to the Program j Plan in the fol1owing sections. l 1

A. Evaluation of the Waterford 3 F1rst 10-Year Interval ISI Procram. l Revisions 4 and 5 The foliewing are the significant additions or changes that have been made since Revision 3 of the Waterford 3 First 10-Year Interval ISI Program.  !

(1) Section 1.2.3: Paragraph IWA-2213, Visual Examination VT-3, of the l Winter 1984 Addenda and paragraph IWA-2300(a)(1), Qualifications of  ;

Hondestructive Examination Personnel, of the Winter 1983 Addenda w111 be  !

used in lieu of the applicable Code. l The Winter 1984 Addenda revised the definition of the VT-3 visual i examination by incorporating some of the VT-4 examination requirements l into the VT-3 visual examination requirements and eliminating the VT-4 visual examination. Paragraph IWA-2300(a)(1) of the Winter 1983 Addenda  !

revised the recertification period of Level III personnel from 3 years to l 5 years. i As permitted by 10 CFR 50.55a(g)(4)(iv), the requirements set forth in .

subsequent editions that are referenced in 10 CFR 50.55a(b) may be used I with NRC approval. Portions of editions and addenda may be used provided l that al1 re1ated requirements are met. Considering that the subject Code 2

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4 Addenda have been approved by the NRC by reference in 10 CFR 50.55a(b) and that the licensee has committed to meet all the related requirements of the respective Addenda, the staff concludes that the use of these portions of the Code is an acceptable revision to the Program.

(2) Section 1.2.4: Three Code cases have been added to the Program that are approved for general use by reference in Regulatory Guide 1.147, Revision 9, dated April 1992. These are Code Case N-307-1, Revised Ultrasonic Examination Volume for Class 1 Bolting, Table IWB-2500-1, Examination Category B-G-1, When Examinations Are Conducted From the Center-Drilled Hole,Section XI, Division 1; Code Case N-435-1, Alternative Examination Requirements for Vessels With Wall Thickness '

2 in. or less,Section XI, Division 1; and Code Case N-498, Alternative '

Rules for 10-Year Hydrostatic Pressure Testing for Class 1 and 2 Systems,Section XI, Division 1.

(3) Section 1.6: A number of piping lines in the Safety Injection and Containment Spray Systems have been added to the Supplemental Program for Intergranular Stress Corrosion Cracking (IGSCC) in stainless steel piping containing stagnant borated water. These supplemental volumetric examinations are in addition to Code requirements and are therefore permissible.

(4) Section 4.1: The licensee has recategorized the boundary of Examination Category IWD integral attachments such that the IWD-examination boundary is included in the Examination Category IWF component support boundary. Re-categorizing the components in this manner essentially eliminates Examination Category IWD for integral attachments. This concept was contained in Request for Relief 151-005 (Revision 2), where the licensee requested to perform the Code-required visual examination of the integral attachments as part of the Examination Category IWF component support. This request was evaluated in an NRC safety evaluation (SE), dated June 6, 1989, where it was determined that relief was not required since the licensee's request did not affect the examination method, extent of examination, or scheduling requirements for Class 3 integral attachments. It was also noted in the SE that any relief granted for supports under IWF does not relieve the licensee of the responsibility of examining the integral attachments. Since it was previously determined that this approach met the intent of the Code and relief was not required, incorporation of this concept into the Program is permissible.

B. Reauest for Relief No.1S1-001 (Part A). Examination Cateaory B-A. Items Bl .11. Bl .21. Bl .22. and 81.40. Reactor Pressure Vessel (RPV) Welds Code Reauirement: Table IWB-2500-1, Examination Category B-A, Items Bl.ll, Bl.21, and Bl.22 require volumetric examination of all reactor pressure vessel (RPV) circumferential shell welds and the accessible length of all circumferential and meridional head welds during the first inspection interval as defined by Figures IWB-2500-1 and IWB-2500-3, respectively.

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1 Table IWB-2500-1, Examination Category B-A, Item Bl.40, requires a volumetric and surface examinations of the RPV head-to-flange weld as -;

defined by IWB-2500-5.

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Licensee's Code Relief Reouest: Relief is requested from performing the ,

volumetric and surface examinations to the extent required by the. Code  ;

for the following RPV welds: s Weld # Item #  % Completed Descriotion of Limitation .{

01-008* Bl.11 Partial Core stop lugs at 10", 40*, 85*,

160", 205*, 250*, and 325' 01-012* Partial Material surveillance brackets at  ;

83*, 97*, 104*, 263*, 277*, and i 284*

02-010 Bl.21 0% Weld completely inaccessible due -

to shroud covering entire weld ,

length  :

02-002 Bl.22 24% Six-inch wide lifting lugs at-15*,02-003 75*, 105*, and 345*; and the i shroud l 02-004 Bl.22 30% Six-inch wide lifting lugs at 1 02-005 165*, 195*, 255*, and_285*; _ 1 shroud; and adjacent weld 02-001  !02-001 Bl.40 Partial surface Six-inch wide lifting lugs at 15*,

50% volumetric 45*, 75*, 105*, 135*, 165*,- ,

195*, 225*, 255*, 285*, 315*, i and 345*; shroud 8 inches from ,

the toe of the weld on one  !

side; and the flange 1 5 inches from the toe on the other side l

• -- Relief granted in NRC SE dated June 6,1989 l ticensee's Basis for Recuestina Relief: Access to the subject welds is j either partially or completely restricted by permanently installed  ;

lifting lugs, RPV internals, adjacent welds, or the RPV shroud as noted  ;

in the above table. During the June 30, 1993 conference call, the '

licensee stated that the shroud was located between RPV head welds02-010 -

and 02-001 as shcwn in Drawing WTR-1-1300 (contained in Revision 5 of the ,

Program). The licensee also confirmed that the shroud covered 100% of  :

weld 02-010 and approximately 50% of meridional welds02-002, 02-003,02-004, and 02-005. Also noted in the June 30, 1993, conference call was that coverage of welds02-004 and 02-005 was.not 70%, as stated in the '

September 17,1992,-submittal, but approximately 30%.

Licensee's Proposed Alternative Examination: None.

Staff Evaluation: Welds01-008 and 01-012 were previously evaluated and relief was granted in an NRC SE dated June 6, 1989. Since there are no j

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technical changes to the relief request regarding these welds, relief remains granted. . ..

For the remaining welds, the Code-required examinations are limited by physical obstructions that impede access to the welds. In order to ,

perform the Code-required examinations, the reactor vessel head would j require significant design modifications or would require removal of the shroud. Even with the shroud removed, it is evident from Drawing WTR-1-1300 that the control rod penetratiors would severely limit the volumetric examinations. Therefore, it te concluded that the volumetric examinations are impractical to perform to the extent required by the 1 Code. Imposition of the requirement on the licensee would cause a burden that would not be compensated by an increase in safety above that provided by the limited examinations. Volumetric examinations to the maximum extent practical, along with the Code-required pressure tests, will provide adequate assurance of the continued structural integrity of the RPV weld:. Therefore, pursuant to 10 CFR 50.55a(g)(6)(1), relief is granted as requested.

C. Reauest for Relief No. ISI-001 (Part B). Examination Cateuory B-B. Items 82.11. 82.12. B2.31. B2.32. and B2.40. Pressure Retainino Welds in the Pressurizer and Steam Generator j l

Code Recuirement: Table IWB-2500-1, Examination Category B-B, l Items B2.11 and B2.12 require volumetric examination of the pressurizer shell-to-head welds as defined in Figures IWB-2500-1 and -2, respectively.  ;

Examination Category B-8, Items B2.31, B2.32, and B2.40 require <

volumetric examinations of the primary side steam generator head welds  !

and the tubesheet-to-head weld as defined by Figures IWB-2500-3 and l IWB-2500-6, respectively. i Licensee's Code Relief Reauest: Relief is requested from performing volumetric examinations of the following pressurizer and steam generator welds to the extent required by the Code:

Weld # Item #  % Completed Rescription of Limitation 05-002 B2.ll 92% Pressurizer support skirt and weld configuration 05-003 B2.12 95% Weld configuration and adjacent insulation support ring 03-002 B2.31 27% Base support configuration 03-00B* Partial 3/4-inch instrument nozzles at 21*, 33*, 327*, and 339' 03-032* Partial Weld geometry and configuration 04-002 27% Base support configuration 04-008* 75% 3/4-inch instrument nozzles at 21*, 33*, 327*, and 339'; two 24-inch manways at 0* and 112*;

nozzle at 180*; and weld 04-009 1 5

Weld # Item #  % Completed , Description of limitation 04-032 B2.11 92% Weld configuration 03-005 B2.32 87% Nozzle configuration 03-007 82% Manway nozzle configuration and adjacent 1-inch instrument line 04-009 B2.40 65% Weld configuration and adjacent welds04-009 and 04-024

• -- Relief granted in NRC SE dated June 6,1989.

Licensee's Basis for W ouestino Relief: The physical obstructions listed above restrict access for the Code-required volumetric examinations.

Licensfe's Preposed Alternative Examination: None.

Staff Evaluation: Complete examination of the subject steam generator and pressurizer welds is not possible due to physical obstructions that restrict access to the welds. Therefore, the volumetric examinations are impractical to perform to the extent required by the Code. In order to perform 100% of the Code-required examination, design modifications of the pressurizer and steam generator would be necessary. Imposition of the requirement on the licensee would cause a burden that would not be compensated by an increase in safety above that provided by the limited examination. Considering that a significant portion of the Code-required examinations is being performed in most cases and that examining 100% of the Code-required volume is impractical, relief is granted pursuant to 10 CFR 50.55a(g)(6)(1). The limited examinations, along with the Code-required pressure tests, will provide adequate assurance of the continued structural integrity of the subject welds.

D. Beauest for Relief No. 151-001 (Part C). Examination Cateoory B-D.

Items B3.100. B3.110 and B3.130. RPV Nozzle Inside Radius Sections and  ;

Pressurizer and Steam Generator Nozzle-to-Vessel Welds Code Reouirement: Table IWB-2500-1, Examination Category B-D, f Items 83.100, B3.110 and B3.130 require 100% volumetric examination of the RPV nozzle inside radius sections and the pressurizer and steam generator nozzle-to-vessel welds as defined by figure IWB-2500-7.

Licensee's Code Relief Recqul: Relief is requested from performing the volumetric examination of the following nozzle inside radius sections and pressurizer and steam generator nozzle-to-vessels welds:

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Weld # Item #  % Completed Descriotion -6f Limitation 01-027 B3.100 73% Core barrel and nozzle taper 01-030 68% ,

'l 05-011 B3.120 25% Nozzle configuration 05-012 ,04-011 B3.130 91% Nozzle configuration I 04-012 0  ;

Licensee's Basis for Reouestino Relief: The physical obstructions listed I above restrict access for the Code-required volumetric examinations. As i stated by the licensee during the June 30, 1993, conference call, the ,

configuration of pressurizer nozzle-to-shell welds05-011 and 05-012 is  !

consistent with Figure IWB-2500-7(a) of the Code. j Licensee's Proposed Alternative Examination: None. i Staff Evaluation: Complete examination of steam generator nozzle-to-  !

vessel welds04-011 and 04-012 is impractical because the nozzle configuration restricts access to the Code-required examination volume.

To meet the Code requirements, the subject welds would require design modifications to allow access for examination. Considering that a significant percent of the Code-required volume (91%) was examined, 1 imposition of this requirement * '" W- ee would cause a burden that would not be compensated by an increase in safety above that provided by the limited examination. Therefore, the staff concludes that, pursuant to 10 CFR 50.55a(g)(6)(1), relief is granted for steam generator nozzle-to-vessel welds04-011 and 04-012. The limited volumetric examination, along with the Code-required pressure tests, will provide adequate assurance of the continued structural integrity of these welds.

l For the RPV nozzle inside radius sections, the licensee states that only l a portion (approximately 70%) of each nozzle could be examined because the core barrel obstructs the area. IWB-2412 requires that at least 16%,

but not more 34%, of the examinations be completed during the first i

l inspection period. Based oc the infcrmation provided by the licensee, l partial examinations were performed on two of the six RPV nozzles with l the core barrel in place. Hence, approximately 24% of all RPV nozzle inside radii have been examined and relief is not required for the first period. The remaining four nozzles will be examined during the third inspection period with the core barrel removed. Based on these considerations, the staff concludes that relief is not required at this time and should not be granted. The remainder of RPV inside radius sections01-027 and 01-030 should be examined with the other four nozzles with the core barrel removed at the end of the interval.

For pressurizer nozzle-to-vessel welds05-011 and 05-012, the licensee states that only 25% of the Code-required volume can be examined due to nozzle configuration. The licensee specified the nozzle configuration to be similar to that of figure IWB-2500-7(a). The percentage of the Code-7

requirad examination that was performed appears low and cannot be justified by nozzle configuration alone. Therefore, relief is denied for the pressurizer nozzle-to-vessel welds05-011 and 05-012.

E. Reouest for Relief No. 151-001 (Part D). Examination Cateoory B-F and B-J. Items 85.40. B5.130. B9.11. 89.12. and B9.31. Class 1 Dissimilar Metal Welds and Pioina Welds '

Code Reauirement: Table IWB-2500-1, Examination Category B-F and B-J, items 05.40, B5.130, B9.ll, and B9.12 require 100% surface and volumetric-examinations of dissimilar metal welds and piping welds as defined by Figure IWB-2500-B. Examination Category B-J, Item B9.31 requires j 100% surface and volumetric examinations as defined by Figure IWB-2500-9,

-10, and -11.

Licensee's Code Relief Recuest: Relief is requested from performing the volumetrir. and surface examinations to the extent required by the Code for the. Class I piping welds listed below.

Weld # Item f  % Comoleted Description of Limitation 1

25-029* B5.40 90% Weld crown and nozzle config.26-006 93% Nozzle configuration 26-010* 90% Nozzle configuration 06-006* B5.130 90% Nozzle configuration 07-002* Partial OD mismatch 08-044* 65% Weld config. and adjacent weld 09-016 65% Weld config. and adjacent weld 13-002* 65% Weld config. and adjacent weld 7.1-002* Partial OD mismatch 12-009* Partial 00 mismatch, shrinkage, and nozzle configuration -

12-012* Partial OD mismatch 13-016* Partial OD mismatch .

14-002* Partial OD mismatch 07-00l* B9.11 82% OD mismatch and 1-inch nozzle 07-010 73% Weld configuration 07-016 Partial OD geometry 07-017* 65% OD geometry 07-018 Partial OD geometry 08-015* 65% Weld config. and adjacent weld 09-001* Partial OD geometry 09-002 90% OD geometry 09-008 Partial Weld geometry 09-017 B9.11 65% Weld config. and adjacent weld 09-018 Partial DD geometry 10-001* 65% Weld config. and adjacent weld 10-009 91% OD mismatch 10-012* 91% OD mismatch 10-013* Partial Weld configuration, OD mismatch and supp wt lug 8

. Weld i Item #  % Completed Descriotion of limitation 11-00l* Partial OD mismatch,1-inch line 11-010 77% OD geometry 11-016 90% OD geometry 11-017* 3% Nozzle config. and adjacent weld 11-018 90% OD geometry 12-00l* 70% Nozzle config. and support lug 12-002* 99% OD configuration 12-013* Partial OD mismatch 13-00l* 3% Nozzle config. and adjacent weld 13-002 Partial OD geometry 13-008 Partial OD geometry 13-017* Partial OD mismatch 13-018 Partial OD gecmetry 14-001* Partial 00 mismatch - 16-001 Partial Weld geometry 16-002 Partial Weld geometry and config.16-003 Partial Weld geometry and config.16-006 Partial Weld geometry and config.16-007 Partial OD mismatch 16-008 Partial OD mismatch 16-011 Partial Weld geometry ,16-016 Partial Weld geometry 17-003 Partial Whip restraint  !17-014 Partial Valve body configuration 17-016 47% Weld geometry and config.17-017 90% OD geometry 17-023 Partial Weld geometry and config.17-030 64% Weld geometry and config.

17-032* 95% Weld geometry and config.17-033 Partial Weld geometry and config.18-008 Partial Weld configuration 18-022 50% Weld configuration 18-025* 75% Weld configuration 18-027 50% Weld configuration 18-042 Partial Weld configuration 19-002 Partial Whip restraint 19-008 Partial Weld configuration 19-024 Partial Weld configuration 19-026* Partial Weld configuration 19-027* Partial Weld configuration 19-038 Partial Weld configuration 19-042 Partial Weld configuration 20-016 37% Weld geometry and config.20-025 72% Weld geometry and config.

20-029* 99% Adjacent branch connection weld 20-056* 47% Weld configuration 21-066* B9.11 Partial Weld geometry and config.

21-068* Partial Weld geometry and config.22-004 Partial surface Restraint ,

Partial vol. ,

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Weld f Item #  % Comoleted Description of limitation 22-023 Partial surface Whip restraint Partial vol.

22-053* 70% Weld geometry and config. '25-009 70% Weld configuration 25-015 70% Weld configuration 25-024* 95% Weld geometry 25-026* 93% Weld configuration 25-027* 93% Weld configuration 25-028* 90% Weld geometry and config.26-002 80% Weld geometry and config. .26-003 90% Weld geometry 26-007 94% Weld geometry and config.26-008 90% Weld geometry and config.

26-009* Partial Weld geometry and config.

07-019tA B9.12 95% OD geometry ,

07-020LB 95% OD geometry 09-019tB <50% OD geometry 09-020LA <50% OD geometry 11-019LA 90% OD geometry 11-020LB Partial OD mismatch 13-019LB 90% OD geometry 13-020LA 90% OD geometry 06-005 B9.31 Partial Weld geometry and config.

08-008* 89% Weld configuration 10-007* 70% Weld configuration 15-007 Partial Weld geometry and config.

• -- Relief granted in NRC SE dated June 6,1989.

Licensee's Basis for Reouestino Relief: In addition to the specific limitations listed above, the licensee also states that Class I piping and components are designed with welded joints, such as pipe-to-elbow and pipe-to-component, that physically obstruct all or part of the required examination. Every effort has been made when selecting welds to minimize the number of welds requiring relief. Alternative analyses, search units, vee paths, and other techniques will be used to provide additional coverage where practical. Waterford 3 has generated a detailed summary of the ASME Code Class 1 and 2 piping and component welds / areas that will receive a limited or partial examination. The summary, which was provided with the relief request, identifies the specific weld / area and the specific cause for the partial examination. This information is provided with as much detail as possible through a thorough review of the preservice examination data and Partial Examination Summary which was included in the Preservice Inspection Report.

Licensee's Proposed Alternative Examination: None. '

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Staff Evaluation: Based on the NRC evaluation dated June 6,1989, relief remains granted for welds, denoted by an asterisk (*). ,

For a number bf the new welds contained in this relief request, there is no indication of the percentage of the Code-re-quired examination (volumetric or surface) that could be performed. This infnrmation was '

requested in the NRC RAI dated April 5, 1993, and again during the conference call held on June 30, 1993. In response, the licensee stated that the description of the limitation was based on preservice inspection data, and that percentages were not available because inservice examinations had not yet been performed. The staff concludes that for these welds, which are listed as " partial" in the table above, relief cannot be granted until the " percentage completed" can be provided. For ,

these welds, which include 07-016,07-018, 09-008,09-018, 13-002, '13-008, 13-018,16-001, 16-002,16-003, 16-006,16-007, 16-008,16-011, 16-016,17-003, 17-014,17-023, 17-033,18-008, 18-042,19-002, '19-008,19-024, 19-038,19-042, 22-004,22-023, ll-020LB,06-005, and 15-007, relief is denied.

For the remaining welds, physical restrictions such as weld geometry, weld configuration, or adjacent obstructions limit access and make the Code-required examinations impractical to complete. In order to perforg the examination to the extent required by the Code, the subject welds and adjacent obstructions would require design modifications to allow access for examination. Imposition of the requirement on the licensee would cause a burden that would not be compensated by an increase in safety above that provided by the limited examination. It is evident from the information provided by the licensee that, for a majority of the subject welds, a significant portion is being examined. Considering this and the fact that these welds are part of a larger population of welds that are being examined, the staff has determined that sufficient examinations are being performed, and that inservice degradation, if it does occur, will be detected. Therefore, pursuant to 10 CFR 50.55a(g)(6)(1), relief is granted for welds where the percent completed has been specified. The '

partial examinations, along with the Code-required pressure tests, will provide adequate assurance of the continued structural integrity of these welds.

F. Recuest for Relief No. 151-001 (Part Ei. Examination Cateoory B-t-2.

Item B12.20. Pumo Casino internal Surfaces Code Reouirement: Table IW8-2500-1, Examination Category B-L-2,  ;

Item B12.20, requires a VT-3 visual examination of pump casing internal surfaces.

Licensee's Code Relief Recuest: Relief is requested from performing the Code-required VT-3 visual examination of the internal surface of reactor coolant pump (RCP) 2A (component f39-005 in the licensee's September 17, 1992, submittal).

Licensee's Basis for Recuestino Relief: The licensee states that, ,

because of the high radiation level of the pump interna'ls, remote visual 11

. equipment was used to perform the VT-3 visual examination. Because of tight spacing of the vanes in the pump and the type of equipment used, the exam was limited to 2 inches of the leading edge of the vanes and the top and bottom wear rings. The pump casing behind the vanes was inaccessible for examination.

Licensee's Proposed Alternative Examination: None.

Staff Evaluation: The VT-3 visual examination is performed to determine if unanticipated degradation of the pump casing is occurring due to phenomena such as erosion, corrosion, or cracking. However, previous experience during examination of similar pumps att other plants has not shown any significant degradation of pumps casings. Later editions and addenda of the ASME Code (1988 Addenda and later) have eliminated disassembly of pumps for the sole purpose of performing examinations of the internal surfaces and state that the visual examination requirement is only applicable to pumps that are disassembled for reasons such as  !

maintenance, repair, or volumetric examination.

The licensee states that, because of the high radiation level of the pump internals, remote visual equipment was used to perform the VT-3 visual ,

examination. Thus, the licensee has performed a best-effort visual examination without complete disassembly of _ the pump. Normally, the -

Code-required VT-3 visual examination of pump casing internal surfaces necessitates complete disassembly of the pump. This is a major effort -

that requires many manhours from skilled maintenance and inspection personnel. In addition, radiation exposure is excessive. Therefore, the t Code requirement is impractical.  ;

Considering the impracticality assoc'.sted with the disassembly of a RCP, the Code changes mentioned above, and the partial remote visual examination that was performed, the staff concludes that, pursuant to 10 CFR 50.55a(g)(6)(1), relief is granted. The limited visual examination along with the Code-required VT-2 visual examination ,

performed during pressure testing will provide adequate assurance of the continued structural integrity of the reactor coolant pumps. However, considering that only a partial visual examination has been performed, a visual examination should be performed if another RCP is disassembled for  ;

maintenance or any other reason.

G. Recuest for Relief No. 151-001 (Part F). Examination Cateaory C-A. Items C1.10. C1.20. and C1.30. Class 2 Pressair_e Vessel Welds Ep_ta: The welds contained in this request for relief were previously  ;

evaluated and relief was granted it the NRC SE dated ' June 6,1989. Since

• there have been no significant changes to the contents of the request, J relief remains granted as requested. The contents of Request for Relief 151-001 (Part F) as listed in Revision 5 of the Waterford 3 First 10-Year ISI Program are presented below.

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Weld # Item #  % Comoleted Description 'of limitation -

04-025* C1.10 96% Two handholes and adjacent weld 04-026* 57% Weld config. and insulation support ring 04-027* Partial Insulation pads ,

54-074* Partial Flange radius and weld geometry  ;

04-028* C1.20 93% Insulation support ring 04-029* Partial Instrument nozzles at 40*, 80*,

120*, 160*, 200*, 280*, 320*, '

360*

04-024* C1.30 91% Weld config. and adjacent weld 54-075* Partial Flange radius and weld geometry ,

• -- Relief granted in NRC SE dated June 6,1989.

H. Reauest for Relief No. 151-001 (Part G). Examination Cateoory C-B. Item C2.21. Steam Generator Nozzle-to-Shell Welds Note: Relief from the Code-required volumetric examination of ,

welds04-030 and 04-031 was previously evaluated and relief was granted '

in an NRC SE dated June 6, 1989. Since there have been no significant changes, relief remains granted for the volumetric examination of these  :

welds. The limited surface examination of weld 04-031 is evaluated below.

Code Reauirement: Table IWC-2500-1, Examination Category C-B, Item C2.21 requires 100% volumetric and surface examinations of all Class 2 nozzle- l to-shell welds without reinforcing plates at terminal ends of piping runs  ;

as defined by IWC-2500-4(a) or (b).

Licensee's Code Relief Reauest: Relief is requested from performing ,

surface examination of steam generator nozzle-to-shell weld 04-031 to the l extent required by the Code.

Licensee's Basis for Reauestino Relief: The licensee states that the magnetic particle probe is obstructed in one of two directions for approximately 15 of 125 inches of the weld surface due to the adjacent insulation support ring. Thus, only 94% of the magnetic particle surface examination can be performed.

Licensee's Proposed Alternative Examination: None.

Staff Evaluation: For steam generator weld 04-031, the Code-required surface examination is partially obstructed in one direction by an i insulation support ring that restricts access of the magnetic particle probe for 15 inches of the 125-inch-long weld. Therefore, the magnetic  !

particle examination is impractical to perform to the extent required by the Code. Code Case N-460, which has been approved for general use by reference in Regulatory Guide 1.147, states that, when the entire 13

examination volume or area cannot be examined due to interference by another component or part geometry, a reduction less than 10% is acceptable. Since over 90% of the subject weld is receiving the Cok-required surface examination, a significant and acceptable portion 6.*s been performed and imposing the Code requirement on the licensee to examine the remainder of the weld by another surface examination method (i.e., penetrant examination) would cause a burden that would not be compensated by an increase in safety above that provided by the limited examination. Based on this and pursuant to 10 CFR 50.55a(g)(6)(1), the staff concludes that relief is granted. The limited magnetic particle examination along with the partial volumetric examination will provide adequate assurance of the continued structural integrity of steam generator weld 04-031.

I. Recuest for Relief No. 151-001 (Part H). Examination Cateoory C-C. Item C3.20. Inteorally Welded Attachment 51-WS-4 Note: This request for relief was previously evaluated and relief was granted in an SE dated June 6, 1989. Since there have been no significant changes, relief remains granted.

J. Recuest for Relief No. 151-001 (Part I). Examination Cateoory C-F.

Items C5.11. C5.21. and C5.22. Class 2 Pipino Welds Code Recuirement: Table IWC-2500-1, Examination Category C-F, Item C5.11 requires a 100% surface examination of welds less than or equal to 1/2-inch nominal wall thickness that are selected for examination as defined by IWC-2500-7. Items C5.21 and C5.22 require 100% ~ volumetric and surface examinations of Class 2 piping welds greater than 1/2-inch nominal wall thickness that are selected for examination as defined by Figure IWC-2500-7.

Note: In lieu of the Code-required surface examinations for Item C5.ll, volumetric examinations are being performed on certain suction lines of the safety injection and containment spray systems. These alternative examinations were reviewed and approved in an NRC SE dated June 6,1989 as part of Request for Relief 151-002.

Licensee's Code Relief Recuest: Relief is requested from performing 100%

of the Code-required volumetric examination of the Class 2 piping welds listed below.

Weld # Item #  % Completed Description of Limitation 50-023 C5.11 97% Adjacent branch connection 51-005 25% Component configuration 51-033 25% Weld configuration 52-005 25% Weld configuration 52-027 25% Weld configuration 55-066 43% Weld configuration 61-051* 85% Weld configuration 14

l

[ .

Weld # Item # % Coroleted Descriotion of limitation 61-071* 40% Weld configuration 61-073* 99% Weld geometry l 61-080* 99% Weld geometry 62-047* 75% Weld configuration 62-078* 50% Weld confi5aration 62-089* 50% Weld configuration 62-094* 98% Adjacent branch connection 18-059* C5.21 95% Weld geometry 19-055* 90% Weld geometry 41-00l* 85% Weld configuration 41-020* 80% Weld geometry and penetration 41-022* 65% Weld geometry 42-001* C5.21 90% Weld configuration 42-005* 93% Weld configuration 42-011* 95% Weld geometry 42-024* 90% Weld configuration 43-00l* Partial Adjacent pipe 43-004* Partial Weld configuration 43-079* 70% Weld configuration 43-082* 70% Weld configuration 44-089* 98% Adjacent branch connection 45-019* 98% Adjacent branch connection 46-021* i. Partial Weld configuration.51-003 98% Adjacent branch connection 51-004* Partial Weld configuration 51-009* Partial Weld configuration 51-018 Partial Weld configuration and geometry

-900*

52-004* Partial Weld configuration 52-009* Partial Weld configuration 52-019 Partial Weld configuration and geometry

-900*

55-040* 85% Weld geometry and adjacent drain

, line 55-042* 97% Adjacent drain line 55-051* 70% Weld configuration 55-068* Partial Weld configuration and geometry 55-070* Partial Adjacent drain line 55-075* Partial Weld configuration 55-078* Partial Weld configuration 56-040* 15% Weld configuration and geometry 56-042* 95% Weld geometry and adjacent branch connection 56-047* 80% Weld geometry and penetration

• 56-050* Partial Weld configuration 56-070* 96% Adjacent drain line 56-072* 97% Adjacent drain line  !

56-080* Partial Weld configuration and geometry -

43-049LA C5.22 84% Adjacent whip restraints 15 i

l l -j

Weld # Item #  % Completed Description of timitation 44-026LA 99% Adjacent welds 44-086LA 99% Adjacent welds 44-086LA 99% Adjacent welds

• -- Relief granted in NRC SE dated June 6,1989.

Licensee's Basis for Reauestino Relief: In addition to the specific limitations listed above, the licensae also states that Class 2 piping and components are designed with welded joints, such as pipe-to-elbow and pipe-to-component, that physically obstruct all or part of the required examination. Every effort has been made when selecting welds to minimize the number of welds requiring relief. Alternative analyses, search units, vee paths, and other techniques will be used to provide additional coverage where practical. Waterford 3 has generated a detailed summary of the ASME Code Class 1 and 2 piping and component welds / areas that will receive a limited or partial examination. The summary, which was provided with the relief request, identifies the specific weld / area and the specific cause for the partial examination. This infemation is provided with as much detail as possible through a thorough review of the preservice examination data and Partial Examination Summary, which was included in the Preservice Inspection Report.

Licensee's proposed Alternative Examination: None.

Staff Evaluation: Based on the NRC evaluation dated June 6,1989, relief remains granted for welds denoted by an asterisk (*).

For the remaining welds, physical restrictions such as weld geometry, weld configuration, or adjacent obstructions limit access and make the Code-required examinations impractical to complete. In erder to perform the examination to the extent required by the Code, the subject welds and adjacent obstructions would require design modifications to allow access for examination. Imposition of the requirement on the licensee would cause a burden that would not be compensated by an increase in safety above that provided by the limited examination. It is evident from the information provided by the licensee that for a majority of the subject welds a significant portion is being examined. Considering this and the fact that these welds are part of a larger population of welds that are being completely examined, the staff has determined that an acceptable percentage of the Code-required examinations is being performed and that inservice degradation, if it does occer, will be detected. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), relief is granted. The partial examinations, along with the Code-required pressure tests, will provide adequate assurance of the continued structural integrity of these welds.

K. Reauest for Relief No. 151-001 (Part J). Non-Safety Class Welds in the Anomented ISI Prooram for Hioh-Enerov Pioina or Exemot Welds in the Supplemental Prooram for IGSCC 16

. .. j Code Reauirement: None. The welds included in this request receive augmented volumetric examination.

Licensee.'s Code Relief Reauest: Relief is requested from performing 100%

of the aJgmented Volumetric examinations of the following welds:

Weld # Item #  % Comoleted Descriotion of limitation 43-089* N/A 55% Weld configuration 47-034* N/A 60% Weld configuration 60-098 N/A 93% Weld configuration 60-131 N/A 30% Weld configuration

• -- Relief granted in NRC SE dated June 6,1989.

Licensee's Basis for Reauestino Relief: Volumetric examination of the welds listed above is limited by physical obstructions that restrict  !

access to the welds.

Licensee's Proposed Alternative Examination: None.

Staff Evaluation: A Code relief is not applicable to non-Code augmented inspections; however, licensees should inform the NRC of their intentions regarding difficulties in meeting the requirements of augmented inspections. In this case the licensee informed the NRC that it could '

not perform 100% of the augmented volumetric examinations of the subject welds, because physical obstructions created by the weld configuration (e.g., pipe-to-valve, pipe-to-tee) restrict access to these welds.

Considering that, in most cases, a significant portion of the examination was completed and that these welds are part of a larger examination population, generic degradation will be detected. Therefore, the staff concludes that the licensee's proposal is technically acceptable and that the limited examinations will provide adequate assurance of the continued structural integrity of the subject welds.

L. Reauest for Relief No.1S1-002. Examination Cateoory C-F. Class 2 Pipino Systems Note: This relief request was previously evaluated and granted in an NRC SE dated June 6, 1989. Since the technical contents of this request have not changed, relief remains granted.

M. Peouest for Relier No. 151-003. Examination Cateoories B-t-2 and B-M-2. i Items B12.20 and B12.50. Visual Examination of RCP and Valve Body Internal Surfaces i

Note: The issues contained in this relief request were previously l evaluated in an NRC SE dated June 6, 1989. In a letter dated '

September 6,1990, the licensee submitted a revised version of this  !

request that incorporated the issues and components described in Request i for Relief 151-004. Since the technical content has not changed and 4

17 l I

i i

t

. since both Request for Relief 151-003 and ISI-004 were previously evaluated and granted, relief remains granted for ISI-003, Revision 5.

N. Recuest for R'elief ISI-004. Examination Cateaory B-t-1 and B-t-2. Items B12.10 and 812.20. RCP Casino Welds and Internal Surfaces Note: Request for Relief 151-004 was deleted from the ISI Program by the licensee in a letter dated September 6. 1990. The issues described in-this request were incorporated into ISI-003 (Item B12.20) or withdrawn (Item B12.10) by the licensee.

O. Reauest for Relief 151-005. Examination Cateoory D-A. 0-B. and D-C.

Class 3 Inteoral Attachments Enig: Request for Relief 151-005 was previously evaluated in an NRC SE dated June 6,1989, where it was determined that relief. was not required.

Thus, the concepts contained in Request for Relief 151-005 were incorporated into the Program and the request for relief was deleted.

P. Reauest for Relief No. 151-006. Examination Cateaory F-C. Items F3.10 throuch F3.40. Chilled Water System (AC) Component Sunoorts Code Recuirement: Table IWF-2500-1, Examination Category F-C, Items F3.10 through F3.40, require a VT-3 visual examination as defined by IWF-1300-1. Component supports selected for examination shall be the supports of those components that are required to be examined under IWB, IWC, IWD, and IWE. For multiple components within a system of similar design, function, and service, the supports of only one of the multiple components are required to be examined.

Licensee's Code Relief Reouest: Total or partial relief is requested from the Code-required VT-3 visual examination for the Class 3 supports listed below. In cases where partial relief is requested, relief is requested from the portion beneath permanent insulation where the support connects to the pressure boundary.

Support No. Line No. Relief Reouired ACR-458 3AC6-22A Total ACR-559 3AC6-43A, 209A Total ACR-562 3AC6-288, 29B Total ACR-423 3ACS-41B, 42B Partial ACR-424 3AC6-41B, 42B Partial .

ACR-433 3AC6-415, 42B Partial ACR-450 3AC6-21A/B Partial ACR-454 3AC8-14A Partial ACR-468 3ACS-1B, 20B Partial ACR-544 3AC6-28B, 29B Partial '

ACR-1059 3AC10-6A Partial ACR-1094 3AC6-28B Partial >

18

j Relief was previously granted for the' following totally inaccessible supports in an SE dated June 6, 1989: .;

Sucoort No. Line No.

.ACR-408 3AC6-41A, 42A ,{

ACR-410 3AC6-41A,-42A  ;

ACR-419 3AC6-41A, 42A ACR-513 3AC8-7A, 14A j ACR-515 3AC8-7A, 14A  !

ACR-522 3AC6-53A 2 ACR-523 3AC6-52A F ACR-551 3AC6-40A ~ .l ACR-561 3AC6-288, L3B j ACR-563 3AC6-2BA, 29B ,

ACR-570 3AC6-43B i ACR-1034 3AC10-15A i ACR-1036 3AC6-42A_ _

ACR-1058 3AC6-40A  !

ACR-1087 3AC6-40B +

ACR-ll31 3AC6-43B  !

l Relief was previously granted (Request for Relief 151-009) for the partially inaccessible supports listed below in an NRC SE dated -l June 6, 1989:

Support No. Line No. 1 ACR-406 3AC6-41A,.42A j ACR-407 3AC6-41A, 42A.  !

ACR-409 ACR-417 3AC6-41A, 42A 3AC6-41A, 42A l

ACR-421 3AC6-41A, 42A  !

ACR-422 3AC6-42A ACR-425 3AC6-41B, 42B j ACR-426 3AC6-41B, 42B .;

ACR-427 3AC6-418, 42B l ACR-428 3AC6-42B i ACR-429 -3AC6-428 'i ACR-430 3AC6-42A '

ACR-431 3AC6-41B .

ACR-435 '3AC6-41A, 42A  !

ACR-441 3ACS-22B 1 ACR-442 3AC6-I A, 7B, ' 14B.. ,

ACR-443 3AC6-22A .;

ACR-444 3AC10-6A,'68, 15A, 15B3AC6-2A,-2A/B,. l 14B, 19A,:19A/B, 278, 928. '

ACR-445 3AC6-1B  :.

ACR-446 3AC6-1B ACR-448.

ACR-449 3AC6-22A/B ll' 3AC6-22A/B ACV-451 3AC6-22A/B i

19 i

[

Sucoort No. Line No.

ACR-452 3AC6-19A/B,22A/B ACR-453 3AC6-1A/B -

ACR-455 3ACB-7A ACR-457 3AC6-2A/B,19A/B ACR-459 3AC6-1A, IA/B, 2B, 19A, 19B, 19A/B ;

ACR-462 3AC6-2A, 2B, 19A, 19B ACR-470 3AC6-21A >

. ACR-471 3AC6-20B ACV-472 3AC6-22A ACV-473 3AC6-22B ACR-474 3AC6-22B ACR-476 3AC6-78, 14B ACR-478 3AC6-22B ACR-479 3AC6-22B ACR-480 3AC6-22A ACR-497 3AC6-78, 14B ACR-499 3AC6-78, 14B ACR-512 3AC8-7A, 14A ACR-514 3AC8-7A, 14A ACR-516 3AC8-28A, 29A ACR-517 3AC8-28A, 29A ACR-520 3AC6-52A ,

ACR-521 3AC6-53A ACR-524 3AC6-52A, 53A ACR-525 3AC6-52A, 53A ACR-526 .3AC6-52A, 53A ACR-535 3AC6-78, 14B ACR-536 3AC6-78, 14B ACR-540 3AC6-288, 29B ACR-543 3AC6-28B, 29B ACR-550 3AC6-40A, 53A ACR-552 3AC6-52A, 53A ACR-560 3AC6-288, 29B ACR-564 3AC6-288, 29B ,

ACR-565 3AC6-288, 29B ACR-566 3AC6-288, 29B ACR-568 3AC6-40B ACR-669 3AC6-408, 43B, 49B ACR-574 3AC6-209B ACR-575 3AC6-209B, 210B ACR-576 3AC6-210B ACR-588 3AC6-209A, 210A ACR-589 3AC6-2098, 210A ACR-595 3AC6-209B ACR-596 3AC6-209B ACR-597 3AC6-209B ACR-604 3AC6-210B ACR-605 3AC6-210B ACR-607 3AC6-209A, 210A  :

ACR-612 3AC6-43A, 209A '

20 i

4 Support No. Line No.

ACR-l019 3AC6-42B ACR-1027 3AC6-41B ACR-1037 3AC6-42A ACR-1060 3AC6-428 ACR-1064 3AC10-6B ACR-1088 3AC6-S3A ACR-1093 3AC6-29B ACR-1100 3AC6-22A/B ticensee's Basis for Reouestino Relief: Component support access is completely or partially blocked by permanent non-removable insulation.

Supported lines operate at temperatures substantially below ambient and are, therefore, subject to severe condensation. The type of insulation used has a permanently sealed vapor barrier to exclude moisture, and removal of insulation in the support area results in vapor contamination -

of the surrounding insulation. Possible alternative, removable, vapor barrier insulation is not acceptable due to fluoride / chloride content.

Thus, the requirement for a vapor barrier necessitates nonremovable insulation. During the construction phase, examinations were conducted 3 to verify acceptability of the entire component support installation in accordance with the applicable construction codes. Examination records are on file by support number.

Licensee's Proposed Alternative Examination: The licensee will examine l 100% of the component supports in the Chilled Water (AC) system from the i insulation surface to the building structure.

i Staff Evaluation: The issues contained in this relief request were  :

previously evaluated and conditionally granted as Requests for Relief j 151-006 and 1S1-009 in an NRC SE dated June 6, 1989. The conditions specified in the SE were that 1) the Code-required system pressure tests are performed, 2) an additional, similar support is examined to the extent possible for each support for which relief was requested, and i

3) the VT-3 visual examinations of the supports are performed as if the support boundary extends from the surface of the insulation. The j differences since the last evaluation, contained in Revision 5, are the -

addition of 12 new component supports, the consolidation of the supports contained in Relief Request ISI-009 into 151-006, and the deletion of Request for Relief ISI-009 (in Revision 4). Since the technical content i

has not changed and the conditions of the June 6,1989, SE appear to have I been met, relief remains granted based on the previous evaluation. i Q. Recuest for Relief No.1S1-007. Examination Cateaory F-C. Items F3.10. I F3.20. F3.30. and F3.40. Class 2 and 3 Component Standard Supporti Code Reouirement: Table IWF-2500-1, Examination Category F-C, ,

Items F3.10, F3.20, F3.30, and F3.40 require VT-3 visual examination as l defined by Figure IWF-1300. Components selected for examination shall be l the supports of those components that are required to be examined under l IWB, IWC, and IWD during the first inspection interval. For multiple 21 l

l i

components of similar design, function, and service within a system, the supports of only one of the multiple components are required to be ,

examined.

Licensee's Code Relief Reauest: Relief is requested from the Code-  !

required VT-3 visual examinations of the following component suppori.s:

)

Support No. Line No. Code Class Status l

ACR-412* 3AC6-42A 3 Granted (ISI-007)

ACR-413* 3AC6-41A 3 Granted (151-007)

ACR-586* 3AC6-41A 3 Granted (151-008)

ACR-587* 3AC6-42A 3 Granted (151-008)

ACR-600* 3AC6-41B 3 Granted (ISI-007)

ACR-601* 3AC6-42B 3 Granted (ISI-007) '

CCRR-37* 3CC6-144A/B 3 Granted (ISI-007)

CCRR-420 3CC16-144A/B 3 Granted (ISI-007)

CCRR-445 3CC20-201B 3 Granted (ISI-008) .

CCRR-465* 3CC6-71A 3 Granted (ISI-007)

CCRR-471* 3CC6-71A 3 Granted (ISI-007)

CCRR-712 3CC20-3B 3 Granted (ISI-007)  :

CCRR-715 3CC20-2B 3 Granted (ISI-008)

CCRR-781 3CC20-2B 3 Granted (151-007)

CCRR-948 3CC20-2B 3 Not Evaluated i CCRR-1091 3CC6-106B 3 Granted (ISI-007)

CCRR-1122 3CC10-290B 3 Granted (ISI-007)

CSRR-361 2CS10-9B 2 Granted (ISI-007)

CSRR-372 2CS10-9B 2 Granted (151-007)

SIRR-391 2 SIB-Il3RLIA 2 Granted (ISI-007)

• -- All supports within this system that are similar in type, design, and function have been selected for examination.

Therefore, another similar support cannot be examined as an alternative to this support.  :

Licensee's Basis for Reauestina Relief: The subject component supports are in penetrations that are closed off by permanently installed fire seals. Fire seal material is pumped into the penetration in a semi-liquid state and solidifies into a nonremovable mass. Fire seal integrity is a Limiting Condition for Operation as identified in the Waterford 3 TS paragraph 3.7.11. Removal of this fire seal constitutes undue hardship in conducting exams.

During the construction phase, examinations were conducted to verify acceptability of the component support installations in accordance with  :

the applicable construction code (s). Examination records are on file by '

support number. ,

Licensee's Proposed Alternative Examination: An additional support, I similar in type, design, and function, will receive a 100% visual examination for each support listed in this relief request, with the exception of those marked with an asterisk. The asterisk identifies the 22 l

1 .

~.

1 .

l sup' ports located on systems in which 100% of the supports of similar I type, design, and function have been selected for examination.

Staff Evaluation: With the exception of one support, all of the supports listed above have previously been evaluated in an SE dated June 6,1989.

In that SE, relief was granted provided that the Code-required system pressure tests were performed and that an additional similar support would be examined for each support for which relief was requested. Since that evaluation, Request for Relief 151-008 was deleted from the program I

and four supports contained in 151-008 were incorporated into 151-007.

In addition, nine supports appear to have bsen eliminated and one new support added to Request for Relief 15I-007.

Since the technical content has not changed and the conditions of the ,

June 6,1989 SE appear to have been met, relief remains granted based on the previous evaluation.

R. Reauest for Relief No. 151-008. Examination Cateoory F-C. Class 3 Component Supports Note: Request for Relief No. 151-008 was consolidated with 15I-007 and i deleted from the Program in Revision 4.

S. Fecuest for Relief No.1S1-009. Examination Cateoory F-C. Class 3 i Component Supports

. i Note: Request for Relief No. 151-009 was consolidated with ISI-006 and deleted from the Program in Revision 4.

T. Reauest for Relief No. 151-010. Examination Cateoory F-C. Class 3 Component Supports Note: 151-010 was evaluated and relief was granted in an NRC SE dated June 6, 1989, because it was impractical to remove permanently installed fire / heat resistant insulation to inspect the component supports and the licensee would be in violation of the plant TS. Relief was granted with ,

the condition that an additional, similar support would be examined in lieu of each support contained in the request. In a letter dated September 6, 1990, and in Revision 4 of the Waterford 3 Program Plan, the

" Alternate Examinations" paragraph was modified to state that other, similar supports could not be examined as alternatives to these supports because 100% of the supports within this system that are of similar type, design, and function have already been selected for examination. Hence, the condition of the previous evaluation cannot be met. Although these conditions cannot be met, the conclusion in that SE that the Code- '

requirements are impractical for the subject component supports still holds and relief remains granted. In addition to the change mentioned i above, an additional support has been added since the evaluation of '

Revision 2 of the Waterford 3 Program Plan. An up-to-date listing of the ,

supports included in Revision 5 of this relief request is shown below.

l 23

Sucoort No. Line No. Code Class -

~

~

CCRR-467- 3CC6-71A 3 CCRR-468 3CC6-71A 3 CCRR-469 3CC6-71A 3 CCRR-470 3CC6-71A 3 CCRR-529 3CC6-71B 3 CCRR-530 3CC6-71B 3 CCRR-531 3CC6-71B 3 CCRR-1058 3CC6-71A 3 U. Recuest for Relief No. 151-011. Examination Cateoory C-B. Item C2.22.

Mainsteam and Feedwater Nozzle Inside Radius Sections Ho_tg:

o 151-011 was previously evaluated and relief was granted in an NRC SE dated June 6, 1989, with the condition that a surface examination would be performed at the location (s) of potential flaw indications and/or a segment that consists of at least 10% of the area subject to examination. Revisions of this request since the June 6, 1989, evaluation are limited to editorial changes and the addition of the above stipulation to the " Alternative Examination" section of Request for Relief 151-011. Therefore, relief remains granted as requested.

V. Recuest for Relief No. 151-012. Examination Cateoory C-H. D-A. and D-B.

Items C7.30. C7.70. D1.10 and D2.10 Pressure Test for Class 2 and 3 Systems Code Recuirement: Table IWC-2500-1, Examination Category C-H, Items C7.30 and C7.70 require a VT-2 visual examination during the system pressure test as defined by IWC-5221 for Class 2 pressure retaining components.

Table IWD-2500-1, Examination Categories D-A and D-B, Items D1.10 and D2.10, respectively, require a VT-2 visual examination during the performance of the system inservice test (IWD-5221) and the system hydrostatic test (IWD-5223) for Class 3 pressure-retaining components, ticensee's Code Relief Recuest: Relief is requested from performing the Code-required VT-2 visual examinations during system functional and inservice testing for the portions of the Component Cooling (CC),

Charging (CH), and Feedw?ter (FW) lines. The relief request included valves listed below.

Group #1 Piping located in areas that are inaccessible during operation Line # Jhg Affected Lenoth -

2CH1-30 1" l' 2CH1-33 1" l' 2CH4-40A/B 4" 83' 2CH4-41A 4" 4' 2CH4-41A/B 4" 4' 24 )

l 1

Line # 111g Affected tenoth ,

2CH4-41B 4" 4'  !

2CH2-44A/B 2" 17' 2CH2-51A 2" 4' 2CH2-51A/B 2" 4' 2CH2-51B 2" 4' 2CH2-52A/B 2" 17' 2CH2-53A/B 2" 71' 2 CHI-1/2-137A/B 1-1/2" l' 2CH3/4-152 3/4" l' >

Group #2 Piping located in a radioactive pipe chase Line # Siza Affected tenoth l 2CH1-33 1" l' 2CH2-53A/B 2" 124' 2CH2-1/2-54A/B 2-1/2" 6' 2CHl/2-233 1/2" 2' 2CH2-60A/B 2" 6' Groun #3 Piping located in an inaccessible radioactive pipe' chase Line # Sfig Affected tenoth -

3CC20-2A 20" 45' ,

3CC20-2B 20" 32' 3CC20-3A 20" 32' 3CC20-3B 20" 40' '

3CC20-4A 20" 28' 3CC20-4B 20" 34'  ;

3CC10-8A 10" 16' 3CC10-8B 10" 4' 3CC10-10A 10" 30' 3CC10-10B 10" 11' 3CCIB-IIA /B 18" 34' 3CC6-71A 6" 62' 3CC6-71B 6" 34' '

3CC10-83A 10" 19' 3CC10-83B 10" 3' 3CC10-89A 10" 3' 3CC10-89B 10" 3' *s 3CC6-106A 6" 32' i 3CC6-106B 6" 42' 3CC20-107A 20" 40' 3CC20-107B 20" 83' '

3CC8-119A/B 8" 13' 3CC8-139A/B 8" 56' 3CC4-145A 4" 19'  !

3CC4-145B 4" 21' 3CC18-156A/B 18" 27' 25 i

-r

I Line # SfIg Affected tenoth l

3CC16-202A 16" 53' 3CC16-202B 16" 27' 3CC16-203A 16" 30' 3CC16-203B 16" 25' 3CC10-289A 10" 38' 3CC10-290B 10" 40' 2CH-53A/B 2" 80' 3EG2-4A 2" 58' '

3EG2-5B 2" 60' 3FW-19A 6" 64' 3FW6-22B 6" 92' 3FW4-46 4" 22' 3FW4-47 4" 12'  !

3MS8-91A/B 8" 8' Licensee's Basis for Recuestino Relief: Lines in each of these three groups are located in areas of the plant that have been determined to be inaccessible during operation. Although a system functional or inservice test will not be performed on the subject lines or portions of lines, i these lines will be pressure tested to the extent and frequency required ,

by Section XI or Code Case N-498, as applicable.

Groun 1: This group consists of piping that has been determined to be inaccessible because of its location in crawl spaces (22' x 15' x 4'9")

under each of the three charging pump rooms. High contamination and radiation levels of 100-500 mr/hr (1000 mr/hr on contact) during '

operation of the charging pumps are the reasons that this piping is completely encased in the concrete enclosure.

Group 2: This group consists of piping that has been determined to be inaccessible because of its location in a radioactive pipe chase. This piping runs from the charging pumps to the regenerative heat exchanger (HX) and is encased in lead brick shielding. To access the piping, the shielding must be removed. Radiation levels vary between 120 and 150 mr/hr with the shielding removed.

Group 3: This group consists of piping that is located in an '

inaccessible radioactive pipe chase. Piping from several systems is contained within the pipe chase. This piping includes the line that runs from the charging pumps to the regenerative HX (same line as Group 2);

therefore, radiation levels during operation of the charging pump are '

high (120-150 mr/hr). This area is completely behind a concrete block ,

wall .

l ticensee's Proposed Alternative Examination: None. The VT-2 visual examination will be performed as required during the pressure tests specified by Paragraph IWC-5222 or Code Case N-498.

Staff Evaluation: The Code requires a VT-2 visual examination to be performed on the subject components during applicable pressure tests.

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. I Paragraph IWA-5241 states that VT-2 visual examinations shall be  ;

conducted on the accessible external exposed surfaces of pressure  ;

retaining components for evidence of leakage. For components whose  ;

external surfaces are inaccessible for direct visual examination, only j examination of the surrounding area for evidence of leakage, including the floor areas or equipment surfaces located underneath the components, is required.

Group I consists of Class 2 piping contained in a 22' x 15' x 4'9" crawl i space. The radiation fields are 100-500 mr/hr during operatio;. of the charging pumps. Considering the flexibility that the Code offers in performing the VT-2 (described above), the impracticality of the Code- i required VT-2 visual examination is not evident. Therefore, relief is ,

denied.

For Groups 2 and 3, access to perform the Code-required visual examinations is restricted by physical obstructions. For the piping lines in Group 2, access is restricted by lead brick shielding. For Group 3, the subject lines are completely encased behind a concrete block wall. Although the radiation fields in these areas are not extremely high, the combination of radiologic conditions and physical restrictions deter entry for either direct VT-2 visual examination or indirect examination of surrounding areas during operation. Therefore, the Code requirements are impractical for these groups. In order to perform the Code-required visual examination, the concrete and lead brick walls would have to be removed to gain access to the respective areas. Imposition of <

the requirement on the licensee would cause excess radiation exposure to personnel and a burden that would not be compensated by an increase in safety above that provided by the limited examination. As stated by the licensee, the Code-required VT-2 visual examination will be performed as

< required during the pressure tests of Paragraph IWC-5222 (hydrostatic pressure test) or the alternative pressure tests of Code Case N-498.

, Thus, pursuant to 10 CFR 50.55a(g)(6)(1), relief is granted as requested i for Groups 2 and 3.

W. Recuest for Relief No. 151-013. Schedulino Recuirements of Paracraoh ,

IWB-2412-1. Examination Catecorv B-J Welds  ;

9 Code Recuirement: Paragraph IWB-2412, Inspection Program B, requires 1 that examinations be completed during each successive inspection interval in accordance with Table IWB-2412-1 with the exception of examinations  ;

that may be deferred until the end of an inspection interval as specified -

. in Table IWB-2500-1 and for steam generator tubing. The inspection period may be increased or decreased by as much as 1 year to coincide '

with a plant outage, within the limitations of IWB-2400(c). For the first 10-year inspection interval, Table IWB-2412-1 reads as follows:

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Table IWB-2412-1 Inspection Prooram B Inspection Period, '

Calendar Years of Minimum Examinations Maximum Examinations i Plant Service Completed. % Credited. %

3 16 34 '

7 50 67 10 100 100 Licensee's Code Relief Recuest: Relief is requested from the scheduling requirements of IWB-2412-1 that a minimum of 50% of the examinations be completed by the end of the second inspection period for Examination Category B-J circumferential and longitudinal welds.

Licensee's Basis for Reouestino Relief: The licensee states that Table IWB-2500-1, Examination Category B-J, Note 1(b) requires the examination of all nonexempt welds that meet or exceed a specified stress intensity. During construction, the architect engineer provided a list of 11 welds that met this criterion.

Early in the third inspection period, Waterford 3 determined that another review of the latest stress calculations for this piping should be performed. This determinaticn was based upon a number of developments including a snubber reduction program which deleted approximately 200 mechanical snubbers, thermal stratification issues, and several plant modifications involving component supports.

As a result of this review, approximately 90 welds were identified that now meet the high stress criteria of Section XI. Also, approximately 50 longitudinal welds (Item B9.12) that intersect the high-stress welds- -

are also required to be examined per Note 4 of Examination Category B-J.

After removing randomly selected welds that were not yet examined (credited), a net total of 126 welds were added to the 10-year selection.

This addition of welds in the third inspection period resulted in an uneven distribution of B-J examinations. In summary, 20% of Examination Category B-J welds were examined in the first inspection period, and 41%

were examined by the end of the second inspection period.

Licensee's Proposed Alternative Examination: None. The remainder of the Examination Category B-J welds will be examined during the third-inspection period.

Staff Evaluation: The Code requires that at least-16% but not more than '

34% of the welds required to be examined under Examination Category B-J be examined during the first inspection period and at least 50% but not more than 67% be examined during the second period. However, due to plant modifications and thermal stratification issues, there is an exceptionally large number of additional welds that must be examined  ;

during the third inspection period. With a net increase of  ;

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126 Examination Category B-J welds, the distribution of examinations has

. been significantly altered. The licensee has committed to examine the balance of these welds during the third inspection period, thus the Code- .

requirements will be met for the interval with the exception of the scheduling requirements of IWB-2412 during the second period. Since the second period is past, the Code scheduling requirements are impractical. 1 Considering that the Code scheduling requirements have been met for the  ;

first inspection period, that a significant portion (41%) of Examination Category B-J welds have been examined through the second period, and that all the Code required welds will be examined by the end of the first 10-year inspection interval, the proposed scheduling will provide reasonable assurance of the continued operational readiness of the 4 subject Examination Category B-J welds. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), relief is granted as requested.

3.0 CONCLUSION

Paragraph 10 CFR 50.55a(g)(4) requires that components (including supports)  !

that are classified as ASME Code Class 1, 2, and 3 meet the requirements, -

except design and access provisions and preservice requirements, set forth in applicable editions of ASME Section XI to the extent practical within limitations of design, geometry, and materials of construction of the components.

Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee determined that conformance with certain Code requirements is impractical for its facility and submitted supporting information. The staff has reviewed the licensee's submittal and -

has concluded that there are cases where relief can be granted as requested.

Pursuant to 10 CFR 50.55a(g)(6)(1), the staff concludes that the requirements of the Code are impractical and relief is granted or remains granted for Requests for Relief 1S1-001 Parts A, B, E, F, G, H, I, and J, 151-002, 151-003, 151-006, ISI-007, 151-010, 151-011, and 151-013. Such relief is authorized by law and will not endanger life, property, or the common defense and security, and is otherwise in the public interest. The relief has been granted giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. ,

For Request for Relief 1S1-001, Part C, Relief is granted for steam generator welds04-011 and 04-012. For RPV inside radius sections01-027 and 01-030, it ,

is concluded that relief is not required at this time and that the subject volumetric examinations should be completed when the core barrel is removed.

For pressurizer nozzles04-011 and 04-012, relief is denied based on inadequate technical justification.

For Request for Relief 151-001 Part D, partial relief is granted as specified in Section E of this report. For certain welds contained in Part D, it was l determined that relief could not be granted until an approximation of the percentage of the Code-required examinations that could be performed was provided. Therefore, relief was denied for these welds.

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For Request for Relief 151-012, relief is granted for Groups 2 and 3, but denied for Group 1. The impracticality of examining Gioup I was not evident. l Requests for Relief 15I-004, 151-005, 151-008, and 151-009 were deleted from the Program in Revision 4. The concepts or components were incorporated into the Program or into other relief requests. '

Based on the evaluation contained in previous sections of this report, the staff concludes that the Waterford 3 First 10-Year Interval ISI Program, .

through Revision 5, is acceptable and in compliance with the regulations with '

the exceptions where relief was denied as addressed above.

Principal Contributor: T. K. McLellan  ;

Date: November 8, 1993 I

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