ML20071N260
| ML20071N260 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/30/1982 |
| From: | SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY |
| To: | NRC |
| Shared Package | |
| ML20071N266 | List: |
| References | |
| CON-NRC-03-82-096, CON-NRC-3-82-96 SAI-186-028-34, SAI-186-28-34, NUDOCS 8210040180 | |
| Download: ML20071N260 (32) | |
Text
.
SAI Report No. 186-028-34 t
}
i TECHNICAL EVALUATION REPORT OYSTER CREEK NUCLEAR GENERATING STATION INSERVICE INSPECTION PROGRAM Submitted to:
U.S. Nuclear Regulatory Commission Contract No. 03-82-096 Science Applications Inc.
McLean, Virginia 22102 September 30, 1982 XA_,ppyJos.Been Sent to PDR hb/CB&
Sc6ence Applications,Inc.
i
1 CONTENTS INTRODUCTION................................
1
.I.
CLASS 1 COMPONENTS..........................
4 A.
Re a cto r Ve s sel..........................
4 1.
RequestforRelief, Appendix 3A(Notes 1and2),
Reactor Vessel Pressure Retaining Welds, Categories B-A and B-B, Items Bl.1 and Bl.2...............
4 2.
Primary Nozzle-to-Vessel Welds and Inside Radius Sections, Category B-D, Item Bl.4 8
3.
Relief Request, Inaccessible Nozzle-to-Safe End Wel ds, Cate go ry B-F, I tem B l. 6................
10 4.
Vessel and Closure Head Cladding, Category B-I-1, Items Bl.13 and Bl.14 12 5.
Control Rod Drive Housings, Category B-0, Item Bl.18.....
14 B.
Pressurizer (Not applicable to BWRs)
C.
Heat Exchangers and Steam Generators (No relief requests)
D.
Piping Pressure Boundary.........,............
15 1.
Relief Request R8, Inaccessible Welds in Pipe, Dissimilar Metal Welds, Category B-F, Item B4.6 15 2.
Relief Request R8, Inaccessible Pipe Welds in Penetrations, Category B-J, Item B4.5 17 3.
Relief Request R8, Inaccessible Wolds in Piping (But Not in Penetrations) and Supports, Category B-J, Items B4.5 to B4.8; and Category B-K-1 Item B4.9 19 E.
Pump Pressure Boundary (No relief requests)
F.
Valve Pressure Boundary (No relief requests)
II. CLASS 2 COMPONENTS.......................... 21 A.
Pressure Vessel (No relief itquests)
B.
Piping.............................. 21 1.
Relief Request R8, Inaccessible Pipe Supports, Category C-E-1, Item C2.5; and Support Components, Category C-E-2, Item C2.6 21 2.
Relief Request RS, Class 2 Static Systems 23 1/
science Appucanons.ine.
,4,
l l
III. CLASS 3 COMPONENTS (No relief requests) 25 IV. PRESSURE TESTS..........................
25 A.
General...........................
i 1.
Updating to Newer Code for Performance of 25 Pressure Tests......................
s Class 1 System Pressure Tests (No relief requests)
B.
Class 2 System Pressure Tests (No relief requests)
C.
Class 3 System Pressure Tests (No relief requests)
D.
27 V. GENERAL.............................
27 A.
Ultrasonic Examination Techniques..............
27 1.
Updating to Newer Code for UT Examinations........
Exempted Components (There are no unacceptable exemptions)
B.
C.
Other(Noreliefrequests) 29 R E F E RE N CE S..............................
l
)
1 arY Science Applications,Inc.
1
f' TECHNICAL EVALUATION REPORT
)
OYSTER CREEK NUCLEAR GENERAT!HG STATION i;
INSERVICE INSPECTION PROGRAM k
INTRODUCTION l
The revision to 10 CFR 50.55a, published in February 1976, required that Inservice Inspection (ISI) programs be updated to meet the requirements (to the extent practical) of the Edition and Addenda of Section XI of the
'I American Society of Mechanical Engineers Boiler and Pressure Vessel Code
- incorporated in the Regulation by reference in paragraph (b). This updating of the programs was required to be done every 40 months to reflect the new requirements of the later editions of Section XI.
As specified in the February 1976 revision, for plants with Operating Licenses issued prior to March 1,1976, the regulations became effective after September 1,1976, at the start of the next regular 40-month inspection period.
The initial inservice examinations conducted during the first 40-month period were to comply with the requirements in editions of Section XI and addenda in effect no more than six months prior to the date of start of facility comercial operation.
The Regulation recognized that the requirements of the later editions and addenda of the Section XI might not be practical to implement at facilities because of limitations of design, geometry, and materials of construction of components and systems.
It, therefore, pennitted determinations of impractical examination or testing requirements to be evaluated. Relief from these require-ments could be granted, provided health and safety of the public were not endan-gered, giving due consideration of the burden placed on the licensee if the requirements we.re imposed. This report provides the basis for granting or denying the various requests for relief by the licensee, Jersey Central Power and Light Company, of the Oyster Creek Nuclear Generating Station.
It
~~
deals only with inservice examinations of components and with system pressure tests.
Inservice tests of pumps and valves (IST programs) are being evaluated separately.
- Hereinafter referred to asSection XI or Code.
Sc6ence Applications,Inc.,
(i l
l
'l The revision to 10 CFR 50.55a, effective November 1,1979, modified the i
time interval for updating ISI programs and incorporated by reference a later edition and addenda of Section XI. The updating intervals were extended from 40 months to 120 months to be consistent with intervals as defined in Section XI.
For plants with Operating Licenses issued prior to March 1,1976, the j
provisions of the November 1,1979, revision are effective after September 1,
.l 1976, at the start of the next one-third of the 120-month interval.
During the one-third of an interval and throughout the remainder of the interval, inservice examinations shall comply with the latest edition and addenda of Section XI, incorporated by reference in the Regulation, on the date 12 months prior to the start of that one-third of an interval. For Oyster Creek, the ISI progrum and the relief requests evaluated in this report cover the current 120-month inspection interval; i.e., from December 8,1979, to December 7,1989.
This program is based on the 1974 Edition of Section XI of the ASME Boiler &
Pressure Vessel Code with Addenda through Summer 1975.
l The November 1979 revision of the Regulation also provides that ISI programs may meet the requirements of subsequent Code editions and addenda, incorporated by reference in Paragraph (b) and subject to Comission approval.
Portions of such editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met. These instances are addressed on a case-by-case basis in the body of this report.
Finally,Section XI of the Code provides for certain components and systems to be exempted from its requirements.
In some instances, these exemp-tions are not acceptable to NRC, or are only acceptable with restrictions. As appropriate, these instances are also discussed in this report.
References (1) to (19) listed at the end of this report pertain to pre-vious information transmittals on ISI between the licensee and the NRC.
In 1976, the Commission provided general ISI guidance to all licensees. Submittal s in response to that uidance were made by the licensee on June 15,1978,(I) 15,1978,(2 June 8,1979,U) September 6,1979,I4) December 11,1979,(5)
November June 5, 1981,I9) August 5, 1981,(10) May 2, 1982,(12) and August 2, 1982.II4)
Pending the results of this review, interim approval was given for the licensee's ISI pro ram on January 14,1980.(6) The November 15,1978,(2) and December 11, 1979,(5 letters submitted for approval, proposed changes to Oyster Creek's technical specifications.
1 Science Applications,Inc.,
l
l I
NRC requested additional infonnation from the licensee on October 30, 1980,(7) and April 26,198?(11) The licensee responded to those requests on February 5,1981,(8) and July 6,1982.(13) The licensee's response (8) to the first request comitted to withdrawing Relief Request R3. The licen-see's response (13) to the second request for additional infonnation comitted to withdrawing the following relief requests:
(a) Appendix 3A; Notes 5,6and10 (b) Appendix 3B; Note 2 (c) Appendix 3C; Relief Requests R1, R2, R4 and R7.
None of the withdrawn relief requests are addressed in this report. Two tele-phone communications between the licensee and NRC with SAI(16,18) resulted in clarifying a number of relief requests by the submittal of a new ISI program plan on August 26,1982,(17) and a September 14, 1982 letter.(19)
The licensee has not formally requested relief from the Category B-L-2 and B-M-2 requirements to visually examine the internal surfaces of certain Class 1 pumps and valves, proposing instead, to perform the examinations when any of.the components are disassembled for maintenance.
If, at the end of the current inspection interval, pumps or valves in some groups have not been dis-assembled and examined, the licensee will need to request relief from the applicable Code requirements. Also, NRC has requested,I7) and the licensee has implemented (8,13) an augmented weld examination program for certain safety related systems that would otherwise be exempt from Code examination by provisions of IWC-1220.
From the above referenced submittals, a total of seven requests for relief and two requests to update to a newer code were identified as requiring disposi-tion. These requests are evaluated in the following sections of this report.
l I.
CLASS 1 COMPONENTS A.
Reactor Vessel 1.
Request for Relief, Appendix 3A (Notes 1 and 2), Reactor Vessel Pressure Retaining Welds, Categories B-A and B-B, Items Bl.1 and Bl.2
[
Code Requirement Category B-A: Volumetric examination of the shell longitudi-nal and circumferential welds (in the core region) may be performed at or near the end of each inspection interval and shall cover at least 10% of the length of each longitudinal weld, and 5% of the length of each circumferential weld, with the minimum length of weld examined equal to one wall thickness.
Category B-B: This category includes vessel shell welds not in Category B-A or B-C and all head welds. The volumetric exami-nations performed during each inspection interval shall cover at least 10% of the length of each longitudinal shell weld and meri-dional head weld, and 5% of the length of each circumferential shell weld and head weld.
Code Relief Request Relief is requested from the Code required volumetric examinations of the following reactor vessel seam welds:
(1) Longitudinal and circumferential shell welds in the core region - Category B-A.
(2) Longitudinal and circumferential shell welds not in the core region except the upper 6 ft. of each of the three longitudinal welds in the upper shell course -
Category B-B.
(3) All meridional and circumferential welds in the lower head - Category B-B.
Proposed Alternative Examination Visual examination of all vessel welds during pressure testing each refueling outage and hydrcstatic testing each inspection inter-(
val will be performed.
'L Science Applications,Inc.
l ll il Licensee's Basis for Requesting Relief All reactor vessel welds with the exceptions noted above are inaccessible to any local examinations because of interference with the biological shield wall. Minimum pressurization tempera-ture restrictions, the vessel material survefilance program, themal transient restrictions, and coolant leakage monitoring are specified in the plant's technical specifications. These provisions, along with the proposed visual examinations, assure the integrity of the vessel.
Evaluation The SEP Report (15) described the status of Oyster Creek's material surveillance program and its pressure-temperature operating limits. The material surveillance program was planned before Appendix H,10 CFR 50 was first issued and, therefore, does not meet all the Appendix H requirements. The surveillance program now consists of only two capsules and neither dEe' planned to be tested by the licensee at the writing of the SEP report. The report recomends that one of the capsules, prefiirably the #2 capsule, be withdrawn and tested at about 12 to 15 Effective Full Power Years (EFPY).
The report indicates that the licensee's tec.hnical specifica-tions contain pressure-temperature operating limits that conform to Appendix G, 10 CFR 50. Since no material surveillance capsules had been tested before the report was written, the operating limits were based on radiation damage estimates using Regulatory Guide 1.99, Revision 1.
The SEP report concludes that low primary stresses in the vessel beltline region (75% of those allowed by Section III of the Code) and acceptable material fracture toughness properties should provide assurance that brittle fracture will not occur. The
)
report then recommends that a material surveillance cesula be withdrawn and tested at about 12 EFPY. The pressure-temperature operating limits should be revised to reflect the results of the test.
Adherance to the Code requirements would necessitate that J
the licensee remove portions of the biological shield and the per-manently installed insulation to perform the required examination from the vessel exterior of the Category B-A welds and B-B welds listed above. Thus, Code requirements are impractical because of existing plant design and geometry.
3, An alternative examination program should be implemented to provide infomation on the reactor vessel's integrity that would represent the infonnation gained if all Code requirements were met.
l The following program for examination of accessible welds should provide that information:
(a) The longitudinal welds of the upper shell course should be examined to the extent that the sample size is equal to that required for the Category B-A and B-B welds for which relief is requested. science Appucations,ine.
I l
~
(b) If the sample size above is calculated to be greater than the total length of accessible longitudinal vessel welds, the closure head meridional and circumferential (Category B-B only) welds should be examined to an ex-tent greater than nomally reouired by the Code for those welds to make up the difference.
(c)TheCategoryB-C(closurehead-to-flangeandvessel-to-flange) welds should not be included in the above sample size but should be examined to the full extent of the Code.
Additionally, visual examination for gross leakage should be made as proposed during system pressure tests in the area of the lower head and shield annulus below the vessel.
C_onclusions and Reconinendations Based on the above evaluation, it is concluded that for the welds discossed above, the Code requirements are impractical.
It is further concluded that the alternative examinations dis-cussed above will provide necessary added assurance of structural reliability. Therefore, the following is recommended:
Relief should be granted from volumetric examination of the identified welds for the 10-year inspection interval with the following provisions:
~)
(a) All accessible portions of the following reactor vessel welds should be Code examined during each inspection interval as follows:
(1) The longitudinal welds of the upper shell course should be examined to the extent that the sample size is equal to that required for the Category B-A and B-B welds for which relief is requested.
(2) If the sample size above is calculated to be greater that the total length of accessible longitudinal ves-sel welds, the closure head meridional and circumfer-ential (Category B-B only) welds should be examined to an extent greater than normally required by the Code for those welds to make up the difference, l
i (3) The Category B-C (closure head-to-flange and vessel-l to-flange) welds should not be included in the above sample size, but should be examined to the full extent of the Code.
(b) A material surveillance capsule (preferably #2 capsule) should be withdrawn and tested at about 12 to 15 EFPY.
The plant operating limits should be updated based upon those findings.
Science Applications,Inc.
l l
t i
I (c) General visual examinations per IWB-1220(c) should be
{
made during each system pressure test for evidence of leakage in the areas of the lower head and the shield l-annulus below the vessel.
l References References 4, 8,10 and 15.
i f
4
/
I Ye l
science Appiications,ine.
' l
' l 1
l' l
2.
Primary Nozzle-to-Vessel Welds and Inside Radius ' Sections, Category B-D, Item Bl.4 l
l Code Requirement The extent of volumetric examination of each nozzle shall 4
cover 100% of the volume to be inspected as shown in Figure IWB-
. 1 2500-D of the Code. All nozzles shall be examined during each inspection interval.
t Code Relief Request Relief is requested from the volumetric examinations required by the Code on the following nozzles:
~
(a) Recirculation inlet and outlet nozzles:
N1A N2A N1B N2B N1C N2C N1D N2D HIE N2E.
(b) CRD Hydraulic Return Nozzle, N9.
Proposed Alternative Examination The nozzles are to be visually examined during system pressure tests.
Licensee's Basis for Requesting Relief There is not sufficient space to perform a UT scan from the reactor vessel wall because of interference from the bio-shield insulation.
E;aluation These nozzles are physically inaccessible, being surrounded by the bioshield insulation, making examination of these nozzles impractical,
l Relief is requested for 11 of 24 nozzles on the reactor vessel; the other 13 nozzles are planned to be examined to Code
?
requirements. All the nozzles are subject to similar environ-mental conditions. The Code examination of the 13 accessible nozzles and a visual examination in the general area of the lower head during system pressure tests (IWA-5000) should pro-vide adequate information as to the integrity of the subject nozzles.
SClence AppltCations,Inc. ;
~.
Conclusions and Recommendations Based on the above evaluation, it is concluded that for the nozzles discussed above, the Code requirements are im-practical.
It is further concluded that the alternative examinations discussed above will provide necessary added assurance of structural reliability. Therefore, the following is recommended:
Relief should be granted from the Code required volumetric examinations of these nozzles. General visual examinations per IWA-5000 should be required, however, during each system pres-sure test for evidence of leakage in the area of the lower head.
Code examinations on the remaining reactor vessel (Category B-D) nozzles should also be performed.
References References 4, 8, 16, 17 and 18.
t e
J 6
i Science Applications,Inc.
I l
i 3.
Relief Request, Inaccessible Nozzle-to-Safe End Welds, Category B-F, item Bl.6 I
l Code Requirement i
The volumetric and surface examinations perfonned each inspection interval shall cover the circumference of 100% of the welds.
Code Relief Request Relief is requested from the Code required examinations on i'
the following reactor vessel nozzle welds:
I' (a) Recirculation nozzle welds:
NG-A-26 NG-A-1 %
i NG-B-25 NG-B-1 Vf j
NG-C-24 NG-C-1
[
- NG-D-23 NG-D-1 NG-E-27 NG-E-1 (b) CRD hydraulic return nozzle weld:
NC-4-1 (c) Liquid poison nozzle welds:
NP-2-1 i
NP-2-2 i
Proposed Alternative Examination (1) Visual examination during system pressure test, each refueling outage.
(2)Visualexaminationduringsystemhydrostatictest, each inspection interval.
i Licensee's Basis for Reques'ti_ng Relief Oyster Creek has nozzle safe ends fabricated from 300 Series Stainless Steel. The safe ends are furnace sensit.ized.
For this reason, during installation the safe ends were clad on the I.D. with an overlay of 308L material and as a result of I
surface cracking on the 0.D., were repaired by removing defects and cladding on the 0.D. with an overlay of 308L material.
NUREG-0313 recognizes that clad overlay is an acceptable remedy l
for stress corrosion cracking. Based on this joint configuration, the licensee feels that meaningful volumetric and surface i.
examination is impossible.
i Science Apphcations.Inc.
j,
Evaluation The welds above all have external weld overlays with rough surfaces. This configuration precludes adequate coupling of a, UT probe to the surface and produces a geometry that does not i
allow the return of meaningful UT data.
Relief is requested I
from examining roughly one-half of the Category B-F nozzle welds (13 of 27). The remaining Category B-F welds are scheduled to j',
be examined, and the examination results from these welds should provide general infonnation on the material condition of all 6
nozzles. Visually examining the general area of the reactor I.
vessel during system pressure tests (IWA-5000) will provide l
additional information on the integrity of the subject nozzles.
Conclusions and Recommendations Based on the above evaluation, it is concluded that for b
the welds discussed above, the Code requirements are impracti-
[.
cal. It is further concluded that the alternative examinations discussed above will provide necessary added assurance of structural reliability. Therefore, the following is recomended:
~
Relief shou 1d be granted from the Category B-F required examinations on the subject welds. Relief should be contingent upon the Code examination of the remaining Category B-F welds on reactor vessel nozzles and on the visual examination of the general area of the reactor vessel during system pressure testing (IWA-5000).
L t
References References 4, 8, 10, 16, 17, 18, 19 and 20.
3g
~
[-
I.
t I
E IIil i
1 L
n li i:
L Science Apphcations,Inc.
o
~:
, l Il Vessel and Closure Head Cladding, Category B-I-1, Items Bl.13 4
and 81.14 l-Code Requirement 100% of the area of six patches (each 36 sq. in.) of the clad of the closure head and accessible portions of the reactor The vessel shell shall be examined each inspection interval.
closure head cladding is to be examined (1) by visual and surface The vessel cladding is to be 3
means,or(2) volumetrically.
visually examined.
code Relief Request Relief is requested from the Category B-I-1 clad examination requirements for the reactor vessel and closure head.
f2 Proposed Alternative Examination f
The Category B-N-1 vessel interior examination assesses the general condition of the vessel clad.
Licensee's Basis for Requesting Relief The Category B-I-1 examination requirements have been eliminated from more recent editions of the Code because the cladding is not a pressure retaining component and, therefore, not subject to the ASME Code.
Evaluation The licensee may update (with NRC approval) to the 1977 Code, Sumer 1978 Addenda, per 10 CFR 50.55a(g)(4)(iv), and there-
[
The licensee has by eliminate the Category B-I-1 examinations.
chosen, though, to request relief from the 1974 Code provisions
[
and to consider updating to the newer code after the next re-Since a portion of the examinations is required fueling outage.
to be perfonned each inspection period, relief would appear to The elimination of the B-I-1 requirements from the 1
newer code justifies granting relief from the 1974 Code B-I-1
[
be needed.
requirements.
t Conclusions and Recomendations Based on the above evaluation, it is concluded that for the cladding discussed above, the Code requirements are impractical.
L l
It is further concluded that the alternative examination proposed will p'rovide necessary added assurance of structural reliability.
I-Therefore, the following is recomended:
Sc6ence Applications,inc.,
nn-,
..-w-.,
-e-
,-.--,a s
Relief should be granted from the Category B-I-1 require-ments to examine the reactor vessel and closure head cladding.
This relief should apply only to that cladding which should have been examined during the first period of the current interval. The licensee should consider updating to the 1977 Code, Summer 1978 Addenda, to eliminate the need to perfonm i
the examinations during future inspection periods.
[
f References References 4,13 and 18.
6 e
t l
t h
3 sci.ne. Appi.e uons,inc.
l B.
Pressurizer Not applicable to BWRs.
l i
t C.
Heat Exchangers and Steam Generators No relief requests.
l l
D.
Piping Pressure Boundary 1.
Relief Request R8, Inaccessible Welds in Pipe, Dissimilar (l
Metal Welds, Category B-F, Item B4.6 Code Requirement The volumetric and surface examinations perfonned each inspection interval shall cover the circumference of 100% of the welds.
Code Relief Request Relief is requested from the Code required examinations on the following isolation condenser nozzle-to-safe end welds:
Nozzle NSA to penetration X-SA Nozzle NSB to penetration X-5B i
Nozzle N3A to penetration X-2A r
Nozzle N3B to penetration X-2B l
t Proposed Alternative Examination The welds above will be volumetrically examined from one i
side only and surface examined according to Code requirements.
I t
Licensee's Basis for Requesting Relief 3
The welds above can only be examined from one side due to insufficient axial-clearance.
t Evaluation j
The licensee will be examining pipe welds according to Appendix III of the Ccde. Article 111-4420 provides for the angle beam ultrasonic examination (UT).of welds from one side only, using a full V-path. Relief is not necessary for the welds above.
I SClence ApphCations,Inc.,
l Conclusions and Recommendations _
Based on the above evaluation, relief is not necessary to perfonn the proposed alternative examinations. Therefore, relief should not be granted.
References References 4 and 8 5
1 I
sf 1
science Applications,Inc.
,g, s
i!
\\
h 2.
Relief Request R8, Inaccessible Pipe Welds in Penetrations, jl Category B-J, Item B4.5
!l 1
1 Code Requirement
'l The volumetric examinations performed during each inspection interval shall cover all of the area of 25% of the circumferential joints including the adjoining 1 ft. sections of longitudinal joints and 25% of the pipe branch connection joints.
Code Relief Request Relief is requested from the Code required examination of pipe welds in the following 17 containment penetrations:
(a X-SA, X-5B, X-3A, X-3B b X-6 c X-12b, X-70 d X-2A, X-28, X-72 X-7, X-8 X-9, X-10 X-4A, X-4B
) X-61 i
Proposed Alternative Examination Visual examinations of the areas of these penetrations l
will be made during hydrostatic tests.
i Licensee's Basis for Requesting Relief Each process pipe has a weld inside the penetration assembly that is inaccessible for any local examinations. The areas of these penetrations are monitored by temperature and radiation monitors that will help detect leaks in these lines.
Evaluation The identified welds are completely inaccessible for volu.
metric or surface examination because the welds are located inside i
a containment penetration. Each primary containment penetration assembly, due to its design, leaves one pressure retaining piping weld inaccessible for examination by either surface or volumetric means. The welds can only be examined by inspecting for evidence of leakage during system hydrotests.
l The initial design of the assemblies did not provide for accessibility for inservice examinations.
If it is assumed, though, that the workmanship and quality assurance of the welding as well as the preservice examinations were adequate, then an examination seine: Appucations.Inc.
o
{
4 of the first pressure boundary weld outside the containment should reflect service-induced failures for that particular piping section. Thus, the first pressure boundary weld out-side the containment on each of these process pipes should be volumetrically examined, where practical, over 100% of its i
length during each inspection interval. Such an examination r
would maintain sample size. Also, the licensee should conduct visual examinations at these penetrations as proposed, t
s Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed above, the Code requirements are impractical.
It is further concluded that the alternative examination dis-cussed above will provide necessary added assurance of structural reliability. Therefore, the following is recoramended:
Relief should be granted from the volumetric examination of the identified welds with the following provisions:
(a) The first pr:ssure boundary weld outside the contain-ment on each of these process pipes should be volumet-rically examined, where practical, over 100% of its length during each inspection interval.
(b) The proposed visual examinations should be performed on the containment penetration assemblies when leakage and hydrostatic tests are conducted in accordance with IWB-1220(c).
References References 4 and 8.
7 i
i-l Science Applications,inc.
_ _. ___L.
.. _.1
.. i._ ? ' _. " _.M_ -- _i i -- -_ - - _
1-l 3
4 3.
Relief Request R8, Inaccessible Welds in Piping (But Not in Penetrations)and Supports, Category B-J Items B4.5 to B4.8; and Category B-K-1, Item B4.9 Code Requirement Category B-J: The volumetric examinations performed during each inspection interval shall cover all of the area of 25% of the circumferential joints including the adjoining 1 ft. sections of longitudinal joints and 25% of the pipe branch connection joints.
Category B-K-1: The volumetric examinations performed during each inspection interval are to cover 25% of the integrally welded supports.
Code Relief Request Relief is requested from the Code required examinations of various Category B-J welds (other than those located inside penetrations) and associated supports. Relief for welds located inside penetrations is discussed in I.D.2 of this report.
Proposed Alternative Examination Welds are to be visually examined during hydrostatic testing.
Licensee's Basis for Requesting Relief The subject welds are inaccessible due to their physical locations either in high radiation areas, very high in a room, adjacent to a wall, or other restrictions without sufficient clearance to perform examinations.
Evaluation The number of inaccessible welds needing relief is suffi-ciently small and random, compared with the total number of welds in Category B-J (or in any of the affected systems), that t
none of these welds needs to be included in the 25% sample to be examined during this inspection interval.
For subsequent inspection intervals, the licensee has the option of updating to subsequent Code versions or of staying with the 1974 Edition, through Summer 1975 Addenda, pursuant to 10 CFR 50.55a(b)(2)(ii). Updating would allow the licensee to examine the same 25% sample, if the provisions of the Sumer note (2) of Category B-J in. Table IWB-2500-1) prevail (see foot-1978 Addenda of the 1977 Edition continue to g'
By adopting l
Science Applications,inc. -
L :. : '
... :...:-..
- L L...:.L. :.... - -.:
~
.~
_ -. - ~.
I e, '
10 CFR 50.55a(b)(2)(ii), the Comission was offering an option whereby " operating facilities with ongoing inservice inspection programs would have continuity in the extent and frequency of examinationsforpipewelds"(see44FR57913).
l Based on these considerations, relief from these requirements is not required at this time for these welds.
It is preferable to defer a decision until the next inspection interval, after the licensee has reevaluated which of the above options he wishes to exercise.
s Conclusions 'and Recomendations Based on the above evaluation, it is concluded that for
~
these welds, relief from Code requirements is not needed.
Therefore, relief from volumetric examination should not be granted for this inspection interval.
References
~
References 4 and 8.
E.
Pump Pressure Boundary No relief requests.
F.
Valve Pressure Boundary No relief requests.
sc6ence Appucat6 ens,inc.
1 l
d r
~~'
..~.2 z.
w..
s II. CLASS 2 COMPONENTS A.
Pressure Vessels
(
No relief requests.
t B.
Piping 1.
Relief Request R8, Inaccessible Pipe Supports, Category C-E-1, Item C2.5; and Support Components, Category C-E-2, Item C2.6 Code Requirements Category C-E-1:
Integrally welded support attachments are to be surface examined over 100% of each major load bearing element each inspection interval.
Category C-E-2: All Class 2 support components are to be visually examined each interval.
l Code Relief Request Relief is requested from the Code required examinations on piping supports and support components for the following con-l tairment penetrations:
a X-66, X-63 b X-23 c X-20A, X-20B Proposed Alternative Examination None.
Licensee's Basis for Requesting Relief The subject welds are inaccessible due to their physical locations either in high radiation areas, very high in a room, adjacent to a wall, or other restrictions without sufficient clearance to perform examinations.
Evaluation The licensee has not provided enough infomation to justify granting relief. The licensee should submit specific relief requests that detail the access restrictions for each support.
The infomation provided should include area radiation levels, j
expected personnel exposures, degree of accessibility for surface and visual examinations for both integral attachments and support components.
Science ApphCatioes inc.,
L -~ --. :-..
_..... _....__. L
~ ^^-
a.
.I Conclusions and Recommendations Relief from Code requirements is not justified and should not be granted. The licensee should submit specific relief 1
requests that detail the access restrictions for each support.
l The information described in the evaluation above should be
{~
included.
References j
References 4 and 8.
l
?
i l
i s
l
=
I l
1/
^
T.
. - - - --- - L.
^ ^ ' '
4
- \\
2.
Relief Request R5, Class 2 Static Systems j
Code Requirements 1
IWC-1220(b):
Components in systems or portions of systems, other than emergency core cooling systems, which do not function during normal reactor operation may be exempted.
Code Relief Request i
The licensee apparently requests relief to use the exemption i
requirement for static systems (IWC-1220(a), see below) from the
!l 1977 Code, Sumer 1978 Addenda, rather than the analagous require-I!
ment (IWC-1220(b), see above) from the 1974 Code Sumer 1975 Addenda.
s IWC-1220(a): Components of systems or portiens of systems that during nomal plant operating conditions are not required to operate or perform a system function but remain flooded under static conditions at a pressure of at least 80% of the pressure 3
that the component or system, will be subjected to when required
~
to operate.
Proposed Alternative Examination Visual examinations are to be perfomed during hydrostatic testing.
Licensee's Basis for Requesting Relief These static systems are constantly subjected to system pressure and thus have continuous leak checks. Flow induced stress and erosion are not present. Additional testing of welds in these systems is therefore unnecessary.
Evaluation Each edition of the Code has a different set of Class 2 exemptions (IWC-1220), which treats safety related systems dif-ferently. Accordingly, to insure adequate surveillance of safety related systems, the licensee should not combine exemp-tions from both codes. Since the licensee has chosen to base the majority of exemptions on the IWC-1220 requirements of the 1974 Code, Sumer 1975 Addenda, all Class 2 exemptions should be based on that Code. Therefore, the Class 2 static system i
exemption should be according to IWC-1220(b) of the 1974 Code, Summer 1975 Addenda, and relief should not be granted.
'l
')
'6
$ClenCe Applications,Inc.,
^
. =. = - = = -. -
= - - - - - -
v Conclusions and Reconenendations Based on the above evaluation, relief should not be I
granted to exempt Class 2 static systems from examination based on IWC-1220(a) of the 1977 Code, Summer 1978 Addenda.
The requirements of IWC-1220(b) of the 1974 Code, Sunner 1975 Addenda, should be applied if exemptions are desired.
I References References 4 and 13.
?
')
i I
f I
)
I 4
SClence Applications,Inc.
~
3 III. CLASS 3 COMPONENTS No relief requests.
IV. PRESSURE TESTS l,
l A.
General 1.
Updating to Newer Code for Performance of Pressure Tests i
Code Requirement Article IWA-5000 with applicable IWB, IWC and IWC articles applied are to be used for performance of pressure tests. The 1974 Edition of the Code, Sumer 1975 Addenda, was originally
{
i
~-
specified as the applicable edition.
Update Request Since the original issue of the ISI program, the licen-see has stated that Articles IWA,.IWB, IWC and IWD-5000 from the 1980 Edition, Winter 1981 Addenda, will be used to conduct pressure tests on Class 1, 2 and 3 systems, i
Proposed Alternative Examination See above.
i Licensee's Basis for Request l
This action is intended to apply Code articles that were
')
improved over those included in the 1974 Edition through Sumer i
1975 Addenda.
Evaluation The 1980 Edition of Section XI has been referenced in 10 CFR 50.55a and inservice examinations may meet the requirements of this edition in lieu of those from previous editions with the following provisions:
(a) Comission approval is required to update to the more y
recentedition(pursuantto10CFR50.55a(g)(4)(iv));
(b) When applying the 1980 Edition, only the addenda through Winter 1980 Addenda may be used; (c) Any requirement of the more recent edition which is relatedtotheone(s)underconsiderationmustalso be met.
r
~...
I t
The licensee, however, wishes to update to the Winter 1981 Addenda, which would require an exemption from regulations. But since the general objective of improving the pressure test pro-cedures can be accomplished by updating to the refenenced Winter
(-
1980 Addenda of the 1980 Edition, this edition should be used.
r Conclusions and Recomendations Based on the above evaluation and pursuant to 10 CFR 50.55a (g)(4)(iv), approval should be granted to update to Articles IWA, r-IWB, IWC and IWD-5000 of the 1980 Edition, Winter 1980 Addenda, for pressure testing.
References References 4 and 14.
B.
Class 1 System Pressure Tests No relief requests.
C.
Class 2 System Pressure Tests No relief requests.
D.
Class 3 System Pressure Tests No relief requests.
i'
)
'l i
t I
l I
Science Applications,Inc. i ;
' l
.-._..--.--._-..=.2
- =---=--.
-..---=--=--;-------
w V.
GENERAL A.
Ultrasonic Examination Techniques 5
1.
Updating to Newer Code for UT Examinations i
Code Requirement Various articles and subarticles from Sections V and XI as i
presented in the 1974 Code, Sumer 1975 Addenda.
Update Request The licensee has stated that the following portions of Sections V and XI of the 1977 Code, Sumer 1978 Addenda, will be used in lieu of the same portions from the 1974 Code, Sumer 1975 Addenda.
(a)SectionXI:
IWA-2200 IWA-3000 (with applicable IWB, IWC and IWD applied)
Appendix III (b) Section V:
Article 4 Article 5 S
Article 6 Article 7 Proposed Alternative Examination See above.
Licensee's Basis for Request to Update This action is intended to apply Code articles that either did not exist or were improved over those included or referenced in the 1974 Edition, Sumer 1975 Addenda, of Section XI.
Evaluation The 1977 Edition of Section XI has been referenced in 10 CFR 50.55a and inservice examinations may meet the require-ments of this edition in lieu of those from previous editions with the following provisions:
(a) Commission approval is required to update to the more recentedition(pursuantto10CFR50.55a(g)(4)(iv));
I; (b) When applying the 1977 Edition, all of the addenda i
through Sumer 1978 Addenda must be used; SC6enCS ApphCations,Inc. l
%^
L.
(c) Any requirement of the more recent edition which is related to the one(s) under consideration must also be met.
Updating to the newer Code for the requirements of the above articles would improve the UT examination program at Oyster Creek. All related requirements are included in the update.
j Conclusions and Reconrnendations j
Based on the above evaluation and pursuant to 10 CFR 50.55a (g)(4)(iv), approval should be granted to update to the 1977 i
Edition, Sununer 1978 Addenda, for the above subject Code require-ments.
References References 4 and 9.
3 i'
B.
Exempted Components
~
There are no unacceptable. exemptions.
C.
Other No relief requests.
1.'
6
.~
Science Applications,Inc.. -
I i
I REFEREllCES i
1.
I.R.Finfrock(JCP&L)toNRC, June 15,1978.
j I
.2.
I. R. Finfrock (JCP&L) to NRC, November 15, 1978.
i 3.
I. R. Finfrock (JCP&L) to NRC, June 8, 1979.
i 4.
I.R.Finfrock(JCP&L)toNRC, September 6,1979.
5.
I. R. Finfrock (JCP&L) to NRC, December 11, 1979.
6.
D. L. Ziemann (NRC) to I. R. Finfrock (JCP&L), January 14, 1980.
7.
D. M. Crutchfield (NRC) to I. R. Finfrock (JCP&L), October 30, 1980.
[
8.
I. R. Finfrock (JCP&L) to D. M. Crutchfield (NRC), February 5,1981.
9.
I. R. Finfrock (JCP&L) to NRC, June 5, 1981.
10.
J. T. Carroll (JCP&L) to D. M. Crutchfield (NRC), August 5, 1981.
l 11.
D. M. Crutchfield (NRC) to P. B. Fiedler (JCP&L), April 26, 1982.
12.
P. B. Fiedler (JCP&L) to.D. M. Crutchfield (NRC), May 2,1982.
- 13. P.B.Fiedler(JCP&L)toD.M.Crutchfield(NRC),undatedletter, received July 6, 1982.
14.
P. B. Fiedler (JCP&L) to NRC, August 2,1982.
15.
K. G. Hoge, Evaluation of the Integrity of SEP Reactor Vessels, NUREG-0569, December 1979.
- 16. Telephone conversation: D. Holland (GPU), J. Lombardo (NRC), and R. Yorg (SAI), August 12, 1982.
17.
D. Holland (GPU) to D. Outlaw (SAI), August 26, 1982.
T
- 18. Telephone conversation: D. Holland and R. Joffe (GPU), G. Johnson (NRC),
and G. Freund and R. Yorg (SAI), Septembe.r 2,1982.
19.
D. Holland (GPU) to R. Yorg (SAI), September 14, 1982.
- 20. Telephone conversation: D. Holland (GPU) to R. Yorg (SAI), September 20, 1982.
h i
Science Applications,lnc..