ML20076C773
| ML20076C773 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/10/1982 |
| From: | SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY |
| To: | NRC |
| Shared Package | |
| ML20076C768 | List: |
| References | |
| CON-NRC-03-82-096, CON-NRC-3-82-96 186-028-14, 186-28-14, NUDOCS 8305200110 | |
| Download: ML20076C773 (27) | |
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SAI Report No. 186-028-14 TECHNICAL EVALUATION REPORT PEACH BOTTOM ATOMIC POWER STATION UNITS 2 and 3 INSERVICE INSPECTI0il PROGRAM Submitted to:
U.S. fluclear Regulatory Comission Contract No. 03-82-096 Science Applications, Inc.
McLean, Virginia 22102 September 10, 1982 83052001to 030502 science Apoiscations.inc.
PDR ADOCK 05000277 O
CONTENTS INTRODUCTION...............................
1 I.
CLASS 1 COMP 0 net 4TS.........................
4 A.
Reactor Vessel (No relief requests)
B.
Pressurizer (Does not apply to BWRs)
C.
Heat Exchangers (No relief requests)
D.
Piping Pressure Boundary....................
4 1.
Request for Relief 2.4.1; Hydraulic Shock Suppressors for Class 1 Piping, Pumps and Valves, Category B-K-2, Items B4.10, B5.5 and B6.5.................
4 E.
Pump Pressure Boundary.....................
7 1.
Hydraulic Shock Suppressors for Class 1 Pumps, Category B-K-2, Item B5.5 7
2.
Request for Relief 2.4.2; Internal Surfaces of Pumps, Category B-l.-2, Item B5.7..............
7 F.
Valve Pressure Boundary 10 1.
Hydraulic Shock Suppressors for Class 1 Valves, Category B-K-2, Item B6.5 10 2.
Request for Relief 2.4.3; Internal Surfaces of Valves, Category B-M-2, Item B6.7 10 i
II.
CLASS 2 COMP 0NENTS (No relief requests)
III. CLASS 3 COMP 0HENTS (No relief requests) 0 IV. PRESSURE TESTS...........................
14 A.
General (No relief requests)
B.
Class 1 System Pressure Tests 14 1.
Request for Relief 2.4.4; Class 1 Systems Hydrostatic Pressure Tests.......................
14 C.
Class 2 System Pressure Tests (No relief requests)
D.
Class 3 System Pressure Tests 16 1.
Request for Relief 4.3.1; Class 3 Systems Hydrostatic Pressure Tests.......................
16 2.
Request for Relief 4.3.2; Class 3 Systems Pressure Testing 18 J/
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GENERAL
............................... 20 A.
Ultrasonic Exami. nations 20 1.
Code Relief Request per letter of February 19, 1980; Ultrasonic Examination Evaluations.............. 20 B.
Exempted Components 22 1.
Class 1 Components and Piping Exemptions Based on Diameter per IWB-1220(b)................... 22 2.
Class 2 Components and Piping Exemptions Based on Chemie+ry Control per IWC-1220(c) 23 C.
Other 24 1.
Request for Relief 3.4.1; Classification of Main' Steam Lines 24.
REFERENCES................................ 27 k
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TECHNICAL EVALUATION REPORT
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PEACH BOTT0:1 ATOMIC POWER STATION - UNITS 2 AND 3 INSERVICE INSPECTION PROGRAM
- NTRODUCTION The revision to 10 CFR 50.55a, published in February 1976, required that
[nservice Inspection (ISI) Programs be updated to meet the requirements (to the extent practical) of the Edition and Addenda of Section XI of the 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.
ihe initial inservice examinations conducted during the first 40-month period vere to comply with the requirements in editions of Section XI and addenda in affect no more than six months prior to the date of start of facility commercial 3peration.
The Regulation recognized that the requirements of the later editions and addenda of the Section XI might not be practical to implement at facilities be-cause of limitations of design, geometry, and materials of construction of components and systems.
It therefore permitted determinations of impractical examino..on or testing requirements to be evaluated. Relief from these require-nents could be granted provided health and safety of the public were not endan-gered giving due consideration to the burden placed on the ' licensee if the requirements were imposed. This report provides evalurit of the various
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requests for relief by the licensee, Philadelphia r y.ic ompany (PEC), of Peach Bottom Atomic Power Station, Units 2 and 3.
b al.
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, s
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0 The revision to 10 CFR 50.55a, effective November 1,1979, modified the
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time interval for updating ISI programs-and incorporated by reference a later edition and addenda of Section XI. The updating intervals were extended frein 40 months to 120 months to be consistent with intervals as defined in Section XI.
j For plants with Operating Licenses issued prior to March 1,1976, the pro-visions of the November 1,1979, revision are effective after September 1,1976, 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 Peach Bottom Atomic Power Station, a
Units No. 2 and 3, the ISI program and the relief requests evaluated in this report cover the last 80 months of the current 120-month inspection interval, j
i.e., from November 5,1977, to July 5,1984, for Unit 2 and from April 23, 1978, to December 12, 1984, for Unit 3.
This program was based upon the 1974 Edition of Section XI of the ASME Boiler and Pressure Vessel Code with Addenda through
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the Sumer of 1975.
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 Nuclear Regulatory Comraission (NRC) approval.
Portions of such editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. These instan-ces are addressed on a case-by-case basis in the body of this report.
Finally,Section XI of the code provides for certain compoilents and systems to be exempted from its requirements.
In some instances, these exemptions are not acceptable to NRC or are only acceptable with restrictions.
As appropriate, these instances are also discussed in this report.
References (1) to (14) listed at the end of this report pertain to previous information transmittals on ISI between the licensee and the NRC. By letters of April 26 and November 22, 1976,II'3) the Commission provided general ISI guidance to all licensees. The licensee responded to the initial guidance on
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June 4, 1976.( ) On May 5, 1977,I4) the licensee submitted a proposed change in the Technical Specifications for both units and on August 4, 1977,(5) sub-l mitted the Inservice Inspection Program for Unit 2.
The Comission granted Science Apphe,ations,Inc.
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interim relief on August 30,1977,(6) for Unit 2, based on the ISI P'rogram submittal, pending ddtailed review. On January 23,1978,(7) the licensee submitted the Inservice Inspection Program for Unit 3..By letters of August 10, 1978,(0) and March 5,1982,(12) the Commission requested additional information i
t to complete this raview.
In response to the August 10, 1978, request, the licensee furnished further information on September 20,1978,(9) and a revised ISI Program on November 22,1978.(10)
In response to the March 5, 1982, I
request, the licensee submitted.infonnation on April 5, 1982,(13) and June 11, i
1982.(I4) The licensee made a request for Code interpretation on February 19, 1980.(11)
From these submittals, a total of 10 requests (a) for relief from Code requirements, (b) for updating to a later code, and (c) for exemptions not necessarily acceptable to the Comission were identified. These requests are evaluated in the following sections of this report.
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9 I.
CLASS 1 COMPONENTS A.
Reactor Vessel No relief requests.
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B.
Pressurizer Does not apply to BWRs.
C.
Heat Exchangers No relief requests.
D.
Piping Pressure Eoundary 1.
Request for Relief 2.4.1, Hydraulic Shock Suporessors for Class 1 Piping, Pumos, and Valves, Cateaory B-K-2, Items B4.10, B5.5 and B6.5 t
Code Requirement The areas shall include the support components that extend from the piping, valve, and pump attachment to and including the attachment to the supporting structure.
The visual examination performed during each inspection i
interval shall cover all support components.
The support settings of constant and variable spring type hangers, snubbers, and shock absorbers shall be verified.
Code Relief Request Licensee requests permission to examine the hydraulic shock suppressors on Class 1 systems according to the require-ments of the plant Technical Specifications instead of accord-ing to the requirements of Table IWB-2500, Category B-K-2, of Section XI.
Proposed Alternative Examination Hydraulic. shock suppressors will be examined and tested in accordance with Technical Specificatio'n requirements.
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r Licensee's Basis for Requesting Relief The hydraulic shock suppressors on Class 1 systems are currently subjected to an ongoing inspection and testing pro-gram detailed'in the plant Technical Specifications which exceeds the requirements of the Section XI. This program is designed to demonstrate continued operational readiness and structural integrity of the shock suppressors. This approach provides for unified testing and reporting requirements and eliminates duplication of records.
Evaluation The requirements of the plant Technical Specifications specify monthly inspections of the hydraulic shock suppressors, whereas the requirements of Table IWB-2500 of Section XI specify only one examination during an inspection interval of ten years.
There would be no need to perform an additional visual inspec-tion during an inspection interval just to satisfy Section XI requirements. The intent of the requirements of the plant Technical Specifications is the same as that of the requirements of Section XI; i.e., the assurance of safety based on the adequate functioning of the hydraulic shock suppressors.
4 The requirements of the plant Technical Specifications meet all the requirements of Section XI for inspection and testing of hydraulic shock suppressors, with the exception of the re-
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pcrting requirements. The principal basis for the licensee's relief request is to eliminate the duplication of records.
Reporting requirements in accordance with the plant Tech-nical Specifications are discussed in Regulatory Guide 1.16, including an explanation of what constitutes a reportable occurrence.
For instance, degradation of hydraulic shock sup-pressors to the extent that they could not perfonn their re-quired safety function would be a reportable occurrence.
- Also, a violation of a technical specification would be a reportable d
occurrence. The reporting requirements for reportable occur-rences are presented in Regulatory Guide 10.1.
t The reporting requirements of the plant Technical Speci-fications are more stringent than those of Section XI, i.e.,
1 IWA-6220. Additional reporting requirements to satisfy In-service Inspection requirements should not be necessary.
Conclusions and_ Recommendations Based on the above evaluation, it is concluded that for the hydraulic shock suppressors discu;3ed above, the Code requirements are impractical, it is further concluded that the alternative examination discussed abov'e will provide necessar/ added assurance of structural reliability. There-fore, the following is recommended:
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Relief from the examination requirements of Table IWB-2500, Category B-K-2, should be granted, provided the licensee examines and tests Class I hydraulic shock suppressors in accordance with the plant Technical Specification require-ments, including the related reporting requirements.
References References 5, 7, 8, 9 and 10.
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Pump, Pressure Boundary 1.
Hydraulic Shock Suporessors for Class 1 Pumps, Category B-K-2, Item 85.5 The request to examine hydraulic shock suppressors for Class 1 piping, pumps and valves in accordance with the re,luire-ments of the plant Technical Specifications (see I.D.1 of this report) applies here. Therefore, the following is recommended:
4 Relief from the examination requirements of Table IWE-2500 Category B-K-2, should be granted, provided the licensee Examines i
and tests Class I hydraulic shock suppressors in accordanc? with the plant Technic 61 Specification requirements, including the related reporting requirements.
2.
Reouest for Relief 2.4.2; Internal Surfaces of Punas, Catecory B-L-2, Item B5.7 Code Reovirement Visual examination of pump internal pressure boundary surfaces is required.
One pump in each of the group of pumps performing similar functions in the system shall be examined during each inspection interval. The examinations may be performed at or near the end of the inspection interval.
Code Relief Request Relief is requested from the visual examination of the in-ternal surfaces of the reactor recirculation pumps 2AP34 and 2BP34 at the pressure boundary.
Proposed Alternative Examination The internal surfaces of the recirculation pump casings will be visually examined whenever these surfaces are accessible as a result of disassembly for other maintenance purposes.
In 1
the interim, annual perfonnance tests will be conducted to verify pumping capability and to indicate the condition of internal clearances. This data, coupled with the hydrostatic tests per--
formed once per inspection interval and the external inspections performed during seal maintenance, will provide adequate assur-ance of structural integrity.
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Licensee's Basis for Requestina Relief This requirement, in absence of other required maintenance, would necessitate dismantling a recirculation pump solely to perform a visual inspection of internal surfaces, and as such, represents an unnecessary exposure to radiation and contamination and an excessive expense.
A job of this scope also presents an unnecessary risk of an industrial accident due o the cramped quarters and limited visibility resulting from the use of full anti-C protective equipment.
The disassenbly of this pump constitutes a maintenance job of major proportions that, due to plant design, involves re-moving the motor and transporting it outside the containment.
Movement of such large heavy components within the drywell with the attendant hazard of accidental damage to other safety related piping and equipment constitutes a risk to reactor safety. We estimate that the dismantling and reassembly of one pump would consume more than 10,000 manhours and in excess of one month of round-the-clock effort and would result in a cumulative dose of between 100 and 500 man-rem.
The net result of this major effort would be a visual inspection consuming about 8 manhours. The questionable benefit to be obtained from such an inspection when measured against the cost in man-rem appears to be in conflict with the concept of "As Low as Reasonably Achievable."
In view of the cost in dollars, potential hazards, and man-rem and in view of the minimal benefits to be obtained, the licensee concludes that this Code requirement is impractical for Peach Bottom.
Evaluation The visual examination is to determine whether unanticipated severa degradation of the casing is occurring due to phenomena such as erosion, corrosion, or cracking. However, previous ex-perience during examinations of pumps at other plants has not shown any significant degradation of casings.
The disassembly of the reactor recirculation pumps to the degree necessary to examine the internal pressure retaining surfaces is a major effort, involving large personnel exposures and the generation of large amounts of radioactive waste.
In view of the effort required to disassemble a pump, the infor-mation returned from visual examination of its internal surfaces would be marginal.
The licensee has committed to the concept of visual exami-nation if the pump is disassembled for maintenance. Meanwhile, pressure and flow are monitored during pump operation to assess performance.
The visual examination of the internal pressure boundary may be performed at or near the end of the 10-year inspection interval. The Code cannittee and the Electric Power Research Institute (EPRI) are undertaking a prograu to assemble and srl J
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v evaluate results of visual examination of internal pump casing surfaces. Within the next two years, this program should provide a more definitive basis for the Code committee and NRC for upholding or modifying this Code requirement.
Since so many licensees consider this requirement impractical and an undue burden, it is reasonable to postpone a decision to grant relief until at least that program is completed.
The licensee could submit a new relief request at that time.
Visual examination of the externals of the pump casings could be conducted for leakage when pressure tests are per-4 formed as required by IWB-5000.
Conclusions and Recommendations Based on the above evaluation, it is concluded that for the Code-required visual examination discussed above, a more defini-tive technical basis is needed.
It is further concluded that the alternative examination discussed above will provide added assurance of structural reliability. Therefore, the following is recommended:
(a) Relief should not be granted at this time from the visual examination at the internal surfaces of the reactor recirculatien pump at the pressure boundary.
(D) 1he licensee's prorosal to perform a visual examina-tion whenever the iurfaces are made accessible because a pump is disassrobled for maintenance purposes should be accepted.
(c) Visual exEntnation of the externa'is of the pump casings should be conducted for leakage when pressure tests are performed as required by IWB-5000.
References References 5, 7, 10, 12 and 14
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Valve Pressure Boundary 1.
Hydraulic Shock Suporessors for Class 1 Valves, Category B-K-2, Item E6.5 The request to examine hydraulic shock suppressors for i
Class 1 piping, pumps and valves in accordance with the re-quirements of the plant Technical 5pecifications (see I.D.1 of this report) applies here. Therefore, tiic following is recommended:
Relief 'from the examination requirements of Table IWB-2500, Category B-K-2, should be granted, provided the i
i licensee examines and tests Class 1 hydraulic shock sup-pressors in'accordance with the plant Technical Specifica-tion requirements, including the related reporting requirements.
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Request for Relief 2.4.3; Internal Surfaces of valves, 4
Category B-M-2, Item B6.7 i
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Code Requirement Visual inspection of the internal pressure boundary 2
surfaces, on valves exceeding 4-in, nominal pipe size shall be performed.
One valve in each group of valves of the same construc-tional design, e.g., globe, gate, or check valve, manufacturing method and manufacturer that performs similar functions in the system shall be examined during each inspection interval.
d The examinations may be performed at or near the end of
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the inspection interval.
Code Relief Request Relief is requested from the visual examination of the internal surfaces at the pressure boundary of the Class 1 i
valves exceeding 4-inch diameter nominal pipe size, t
Proposed Alternative Examination The following specific valves:
recirculation pump suction valves (M0-2-43A, B), recirculation pump discharge valves (M0-2-53A & B), recirculation loop equalizing valves (M0-2-65A & B), RHR injection line manual block valves (VV-10-81A & B), and any valve whose disassembly would re-quire extreme measures to isolate, or presents a substantial personnel safety hazard, will be subjected to visual inspec-tion of the internal surfaces of the valve body when dis-assembled for maintenance in accordance with the code and J/
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documented procedures.
If one valve in each group of valves 1
of the eme d? sign, manufacturing method, manufacturer, and function, is not disassembled for maintenance which provides access to the internal pressure boundary during an inspection interval, an examination consisting of UT wall thickness read-ings on selected valves will be considered as an alternate.
The number of valves to be examined will be based on Section XI 4
requirements.
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This inspection program coupled with periodic leak tests and hydrostatic tests will provide adequate assurance of the structural integrity. Other Class 1 valves will be inspected in accordance with Section XI requirements.
j l.icensee's Basis for Requesting Relief Disassembly of diese valves solely for visual inspec-tion, in absence of other required mainteriance, represents an unnecessary exposure to radiation and contamination and an excessive expense.
The recirculation pump suction valves would require off-loading the fuel elements and draining the reactor prior to l
disassembly. Work on recirculation pump discharge valves, recirculation loop equalizing valves, and RHR injection manual 1
block valves would require installation-o? plugs in the jet i
l pump risers.
Preparatory work of this scope is considered impractical for the sole purpose of conducting a visual examina-I l
tion. Contamination levels in the valves associated with the recirculation loops are particularly high due to the physical location of these valves at the bottom of the system.
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The disassembly of large valves to the degree necessary to 4
examine the internal pressure retaining surf.ces (bodies) is a major effort involving 1.arge personnel exposures. To do this disassembly solely to perform a visual examination of the in-ternal casing is impractical. The visual examination specified is to determine whether unanticipated severe degradation of the casing is occurring due to pheomena such as erosion or corrosion.
The licensee has committed to the concept of visual examina-tion when any valve whose disassembly would require extreme measures to isolate, or presents a substantial personnel safety j
hazard, is disassembled for maintenance. This commitment by the licensee should be accepted.
The visual examination of the internal pressure boundary may be performed at or near the end of the 10-year inspection interval. The end of the first interval for Peach Bottom Units 2 and 3 are July and December 1984, respectively. Therefore, i
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relief from examination requirements is not necessary until then because the licensee will be in compliance with the regu-lation up to that time. Since so many licensees consider this
- requirement impractical and an undue burden, it is reas-l onable to postpone a decision to grant relief until near the end of the inspection interval when additional' relevant 4
information fr.om this unit and from the industry in general will be available.
1 The licensee could submit a new relief request at that time for each valve classification for which a valve has not 2
l been disassembled and examined in each unit.
Submitting such I
relief requests as soon as possible after the next-to-last l
scheduled outage of the inspection interval and at least six i
months before the scheouled start of the last outage would j
minimize delays and outage time.
In the event that a Code required valve is not disassembled for maintenance during the interval, the licancee pres:25 to consicier uir.rasonic waii tnickness measurements.
Such measure-i ments, using the minimum wall thickness requirements of Section III of the ASME Code as the acceptance standard and done to paragraph T-560,Section V, 1977 Edition, Winter 1978 Addenda, are potentially an acceptable alternative examination. However, detailed procedures, establishing such parameters as frequency and location of measurements, would have to be developed. If the Iciensee is seriously considering UT thickness measurements for future inspection intervals, he would be well advised to make i
baseline measurements at representative locations on any valve opened for maintenance.
The licensee has proposed to perform visual examinations of the valves when the system pressure tests are conducted. This
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commitment should be accepted.
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Conclusions and Recormlendations-Based en the above evaluation, it is concluded that for the valves discussed above, there is not presently enough l
justification for granting relief from the impractical Code requirements. Therefore, the following is recommended:
(a) Relief should not be granted at this time from visual examination of the internal pressure boundary surfaces on valves exceeding 4-in, nominal pipe size.
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l (b) The licensee's proposal to perform the Code-required examinations whenever the valves are opened because of maintenance should be accepted.
(c) During other inspection periods, the licensee should perform visual examinations for leakage as proposed when the system pressure tests (IWA-5000) are conducted in accordance with the requirements for Category B-P.
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(d) The licensee should submit specific relief requests as the end of the inspection interval approaches for each valve clasM fication for which a valve has not been disassembied and examined in each unit.
(e) When the licensee is properly prepared to perform UT thickness measurements of the valve bodies, and so requests, permission should be granted to do so.
References References 5, 7, 8, 9, 10, 12 and 14.
II. CLASS 2 COMPONENTS No relief requests.
III. CLASS 3 COMPONENTS No relief requests.
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PRESSURE TESTS I
A.
General f
No relief requests.
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Class 1 System Pressure Tests 4
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Request for Relief'2.4.4; Class 1 Systems Hydrostatic Pressure i
Tests l
j Code Requirement IWB-5222 requires that Class 1 systems and components be j
subjected to a systen hydrostatic test at pressures ranging from 110% to 102% of nominal operating pressure (P ), dependent o
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upon test temperatures n the range of 1000F to 5000F.
l Code Relief Request 2
Relief is requested from the Class 1 system hydrostatic test pressure requirements.
Proposed Alternative Examination The test would be conducted at 1075 psig instead of 1088 psig 0
at 185 F.
The Class 1 system hydrostatic test will be conducted with all relief valves in place at a test pressure approximately 30 psig below the lowest nominal relief valve setting.
In the event relief valve settings are changed, test pressure will be changed accordingly, but will not be less than 105% of the system nominal operating pressure (Po) at test temperatures below 350 F.
Licensee's Basis for Requesting Relief At present, Technical Specifications require a minimum temperature of 1850F before pressurizing-to greater than 250 psig.
This temperature would require a hydrostatic test pressure of 108.3% Po (approximately 1088 psig). The present setting of the j
four lowest set relief valves is 1105 psig + 11 psig. The licensee proposes to conduct the hydrotest with all relief valves in place and to raise the pressure to within 30 psig of the lowest nominal relief valve setting.
This provides a reasonable margin to allow for pressure control, while recognizing the setting tolerance of the valves. Under present conditions this would result in a hydro-i test which is 13 psig less than the Code requirement at the minimum 0
test temperature. At higher test temperatures ( > 250 F), Peach Bottom would be in compliance with the Code; however, the higher temperatures make inspection of the drywell upper elevations very j
difficult from the standpoint of personnel stay time.
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i The only alternative that pennits meeting the Code at the lowest test temperature is removal of the relief valves.
This job is expensive both in dollars and man-rem and necessarily results in lengthening the refueling outage because such work is always on the critical path to returning the reactor to service. The licensee concludes that adequate confidence in l
the structural integrity of the Class I systems and components can be gained by the proposed hydrostatic test and that removal of the relief valves to permit testing to a slightly higher pressure is not justified.
Evaluation System hydrostatic testing is required by the plant Technical Specifications to be conducted at a minimum tempera-ture of 1850F to meet the fracture toughness criteria applicable to ferrite materials of which the system components are con-structed.
The licensee indicates that there is a need to meet the Codg at the lowest test temperature, which in this case is 185 F, and that rieed is not really evident.
The Code allows testing at reduced pressures as the testing temperature is 0
raised up to 500 F.
The licensee states that temperatures above 2500F make inspection of the dry well upper elevations very difficult l
fromthestandpointofgersonnelstaytime. Hence, it follows that on this basis, 250 F or lower would be an acceptable testing temperature. From IWB-5222(b), 2500F corresponds to 1.07 Po, or 1075 psig, based on the licensee's calcula-Therefore, the licensee can tions of 1088 psig at 108.3% P.
testat250Fand1075psigan0remainwithintheCoderequire-0 ments. This allows the licensee to keep the testing pressure within 30 psig of the lowest nominal relief valve setting of 1105 psig.11 psig.
Conclusions and Recommendations Based on the evaluation above, it is concluded that the licensee can comply with the requirements in IWB-5222 for the pressure test discussed above. Therefore, relief is not nec-essary from these requirements and should not be granted.
References References 5, 7 and 10.
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Class 2 System Pressure Tests l
Ho relief requests.
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Class 3 System Pressure Tests 1.
Request for Relief 4.3.1; Class 3 Systems Hydrostatic Pressure j
Tests i
i Code Requirement The system test pressure shall be at least 1.10 times l
the system design pressure.
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Code Relief Request 1
Relief is requested from the requirement of testing at 1.10 times the system design pressure for the High Pressure i
Service Water (HPSW) System, Emergency Service Wa.ter (ESW) r System, and their respective portions of the Emergency Cooling System.
t Proposed Alternative Examination The HPSW system, the ESW system, and their re'spective portions of the Emergency Cooling Systems will be pressure i
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tested to 1.10 times the system operating pressure.
i Licensee's Basis for Requesting Relief Testing these systems to 110% design pressure is beyond
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the capability of the system pumps and therefore would require the use of a special hydrostatic test pump.
The available I
test connections on these systems are 3/4 and 1 inch lines and i
would sharply limit the inflow capability from the hydrostatic pump, thereby necessitating leak-tightness of system 14, j
16, 20, and 24 inch valves to successfully perform the tests.
j Such leak-tightness is not otherwise a requirement for systems l
of this type and considerable maintenance expense would be required to make the valves leak-tight for test purposes only.
l, In addition, testing to 110% design pressure would require taking the entire ESW or HPSW system out of service at the same. time which would require the cessation of all shutdown cooling.
For l
the above reasons, the licensee concludes that a hydrostatic test to 110% design pressiere is impractical for systems of this type.
Testing to 110% of operating pressure is practical a; J could be accomplished using the system pumps and throttling at the cooling tower inlet valves: M0-4B-0502 (A,B,C) for the HPSW system, and M0-48-0501 (A,B,C) for the ESW system.
Testing in this manner will provide adequate assurance of l
the structural integrity of these systems.
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- Evaluation The 1977 Edition of the Section XI has been referenced in 10 CFR 50.55a and inservice examinations may meet the re-quirements of this edition in lieu of those from previous editions with the following provisions:
(a) Commission approval is required to update to the more recent edition (pursuant to 10 CFR 50.55a (g)(4)(iv)).
(b) When applying the 1977 Edition, all of the addenda through Sunmer 1978 Addenda must be used.
(c) Any requirement of the more recent edition which is related to the one(s) under consideration must
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also be' met.
The 1977 Codh, Summer 1978 Addenda, allows the system hydrostatic test pressure to be 1.10 times the nominal ogerat-ing pressure for systems with Design Temperatures of 200 F or less.
Conclusions and Recommendations Based on the above evaluation, relief from the Code requirements on hydrostatic pressure testing of the HPSW System and the ESW System should not be granted.
- Instead, pursuant to 10 CFR 50.55a(g)(4)(iv), approval should be granted to update to the requirements of the 1977 Edition, Summer 1978 Addenda. This approval would allow testing at 1.10 times operating pressure.
References References 5, 7, 8, 9 and 10.
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Request for Relief 4.3.2; Class 3 Systems Pressure Testing Code Requirement In the case of buried components (e.g., ' nderground u
piping), valves shall be provided to permit isolation of the buried portions of piping for the purpose of conducting a system pressure test in lieu of the visual examination.
A loss of system pressure during the test shall constitute evidence of component leakage.
Code Relief Request Relief is requested fran performing system pres-sure tests on buried piping in the High Pressure Service Water (HPSW) System, Emergency Service Water (ESW) System, and their respective portions of the Emergency Cooling System.
Procosed Alternative Examination These systems will be visually inspected at accessible portions of the piping and at pipe tunnel penetrations.
Licensee's Basis for Requesting Relief Selected isolation valves and test connections were not incorporated into the design of these cooling systems to per-mit a pressure decay test of the buried piping.
Isolation of the entire cooling system is impractical since it would require taking the entire ESW or HPSW systems out of service, resulting in the cessation of all ;hutdown cooling. More than 955 of the ESW and HPSW piping is accessible for visual inspection.
1 Evaluation The 1977 Edition of the Section XI has been referenced in 10 CFR 50.55a and inservice examinations may meet the re-quirements of this edition in lieu of those from previous editions with the following provisions:
(a) Commission approval is required to update to the more recent edition (pursuant to 10 CFR 50.55a (g)(4)(iv)).
(b) When applying the 1977 Edition, all of the addenda through Summer 1978 Addenda must be used.
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(c) Any recuirement of the more recent edition which is l
relatec to the one(s) under consideration must also j
be met.
The 1977 Code Sumer 1978 Addenda, allows the visual examination for ev Jence of leakage at the areas of each end f
of the buried components.
Conclusions and Recommendations Based on the above evaluation, relief from the Code requirements on hydrostatic pressure testing of the buried piping in the HPSW System and the ESW System should not i
be granted.
Instead, pursuant to 10 CFR 50.55a(g)(4)(iv),
approval should be granted to update to the requirements of s
the 1977 Edition, Sumer 1978 Addenda. This approval would allow visual examination for leakage at each end of the t
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buried components.
I References References 5, 7, 8, 9 and 10.
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GENERAL t
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Ultrasonic Examinations i
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Code Relief Request per letter of February 19, 1980; I
Ultrasonic Examination Evaluations l
2 Code Requirement l
i Where acceptance standards for a particidar component or Examination Category are in the course of preparation,
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evaluation shall be made of any indications detected during i
any inservice examination that exceed tne acceptance stan-dards for materials and welds specified in the Section III l
edition applicable to the construction of the component in order to determine disposition. Such disposition shall be i
subject to review by the enforcement authority having juris-diction at the plant site.
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Code Relief Request Philadelphic Electric Company requests modification to
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an ultrasonic examination requirement in the 1974 edition of j
SectiLn XI of the ASME Boiler and Pressure Vessel Code, as 1
1 app'icable to the Inservice Inspection Program at Peach Bottom i
j Atomic Power Station.
Specifically, the licensee requests j
that the acceptance criteria in Article IWA-3000, Paragraph IWA-3100(b) referenced to the original construction code be i
l based on a code no earlier than that utilized during the base-1 line inservice inspection examinations (1968 Edition of ASME l
l SectionIII).
4 l-Proposed Alternative Examination The licensee proposes that the construction code re-l ferenced in Paragraph IWA-3100(b) be interpreted at Peach Bottom to mean the 1968 Edition of ASME Section III. This 4
approach will maintain the necessary consistency between the
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baseline examinations and future ISI examinations to meet the intent of ASME Section XI.
It is requested that this relief be considered applicable to all examinations conducted i
at Peach Bottom under the 1974 Edition of Section XI.
Licensee's Basis for Requesting Relief The adoption of the 1974 Edition of= Section XI has I
created some inconsistencies between examinations conducted 1
today and those conducted during previous ISI examinations, including the baseline. The governing code for the baseline 1/
sClence AppleCations. Inc..
examinations at Peach Bottom was the 1971 Edition of ASME Section XI and where practicable the guidelines of Addenda through Winter 1971. Examinations performed to the 1971 Edition of the Code were evaluated as per Article 1S-300, in accordance with the acceptance criteria specified in the 4
1968 Edition of the ASME Code,Section III.
Baseline ex-aminations and all examinations conducted prior to September 1978 were evaluated in accordance with this Code. Subsequently, the standard for the Peach Bottom Inservice Inspection Program 4
was upgraded to the 1974 Edition of ASME Code Section XI, including Addenda through Summer 1975 in accordance with i
10 CFR 50.55a. The adoption of the 1974 Edition of Section XI creates an inconsistency for Peach Bottom in that Article IWA-3000, Paragraph IWA-3100(b), now specifies that indica-i tions be evaluated in accordance with the acceptance criteria of the Code applicable to the construction of the component.
At Peach Bottom, certain components were constructed to the 1965 Edition of ASME Section III, which predates the 1968 Edition of ASME Section III used for the entire baseline ex-amination. The calibration blocks, examination procedures, and l
evaluation criteria are so significantly different between the 1965 Code and later editions, that there is very little cor-j relation between respective examination results.
j Evaluation i
The governing code for the baseline examinations was the l
1971 Edition of Section XI.
Examinations performed to the 1971 Edition of the Code were evaluated, as allowed, in accor-4 dance with the acceptance criteria specified in the 1968 Edition of Section III. The baseline examinations and all examinations conducted prior to 1978 were evaluated in accor-
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dance with the 1968 Edition of Section III, and this forms the t
data bank for the preservice and inservice inspection programs at Peach Bottom.
It would be impractical to discard the pre-sent data bank in favor of establishing a new evaluation cri-i j
teria, especially where it is based on earlier Section III Code requirements.
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Conclusions and Recommendations 1
Based on the above evaluation, it is concluded that for the code required evaluations discussed above, the code re-quirements. ore impractical.
It is further concluded that the alternative evaluations and examinations discussed above i
will provide necessary added assurance of structural reliability.
Therefore, it is recommended that the relief request be g'n ot ranted to substitute the acceptance criteria of the 1968 Editio ASME Section III for those components for which it is not the applicable edition for construction.
i References Reference 11.
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V B.
Exempted Components 1.
Class 1 Components and Piping Exemptions Based on Diameter per IWB-1220(b)
Code Requirement Under the postulated conditions of loss of coolant from the component during nomal reactor operation, the reactor can be shut down and cooled down in an orderly manner, assuming makeup is provided by the reactor coolant makeup system only.
(Makeup system to use onsite power only.) liowever, in no instance may size exemption be more than 3 in, nominal pipe size.
Exemption Licensee claims exemption from inspection in Class 1 piping systems for water piping 11/2 inches in diameter and less and for steam piping 3 inches in diameter and less.
Evaluation Analysis shows that the reactor can be cooled down in an orderly manner using only the reactor coolant makeup system when there is a complete break in a 1 1/2-inches diameter water line, or a 3-inch diameter steam line. Therefore, the requirements of IWB-1220(b) have been met and the Code re-quirements to exempt these components satisfied.
Conclusions and Recommendations l
Based on the above evaluation, it is concluded that for Class 1 piping systems, the justification for exemption from code requirements has been demonstrated. Therefore, it is recommended that exemption from volumetric examination of component and piping welds of water line. sizes 1 1/2-inches diameter and under, and of steam line sizes 3-inches diameter l
and under, per IWB-1220(b), should be allowed.
References References 5, 7, 8, 9, 10, 12 and 14.
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2.
Class 2 Components and Pipino Exemptions Based on Chemistry Control per IWC-1220(c)
Code Requirements Components which perform an emergency core cooling function, provided the control of the chemistry (to minimize corrosive effects) of the contained fluid is verified by periodic sampling and test.
Exemption Licensee claims exemption from inspection of C1' ass 2 com-ponents and piping based on IWC-1220(c) for portions of the following systems:
Residual Heat Removal System, Core Spray Cooling System and the High Pressure Coolant Injection System.
Evaluation The chemistry control provision was deleted from Para-graph IWC-1220 in the 1977 Edition of Section XI because prac-tical evaluation, review and acceptance standards could not be defined.
Hence, water chemistry control to minimize stress corrosion described in Paragraph IWC-1220(c) of Section XI, 1974 Edition, is not an acceptable basis for exempting ECCS components from inservice examination.
Conclusions and Recommendations
. Based on the above evaluation, it is concluded that for the Class 2 components and piping systems discussed above, the claims for exemption from examination per code require-ments should not be allowed.
It is recommended that the licensee revise the inservice inspection (ISI) program for Peach Bottom Nuclear Plant to include examination of those portions of the Residual Heat Removal System, the Core Spray Cooling System, and the High Pressure Coolant Injection System that were deleted from the current ISI program based on exemptions allowed by IWC-1220(c).
References References 5, 7, 8, 9 and 10. science Appiications.ine.
C.
Other 1.
Request for Relief 3.4.1; C1'assification of Main Steam Lines Code Requirement IWA-1400 - Owner's Responsibility:
Performance of the inservice inspections required by this Division shall be the responsibility of the owner of the nuclear power system. This responsibility shall include the following:
The owner of the nuclear power plant is responsible for detemining the appropriate code class (es) for each component of the nuclear power plant.
(Classification criteria are speci-fied in 10 CFR 50, and in AEC Regulatory Guide 1.26, " Quality Group Classification and Standards".)
Regulatory Guide 1.26, Quality Group Classifications and Standards for Water, Steam, and Radioactive-Waste-Containing Comoonents of Nuclear Power Plants:
C.I The Group B quality standards given in Table 1* of this guide should be applied to, water-and steam-containing pressure vessels, heat exchangers (other than turbines and condensers),
storage tanks, p.iping, pumps, and valves that are either part of the reactor coclant pressure boundary defined in Paragraph 50.2(v) but excluded from the requirements of Paragraph 50.55a pursuant to footnote 1 of that section or not part of the reactor coolant pressure boundary but part of:
L Those portions of the steam systems of boiling water reactors extending from the outemost containment isolation valve up to but not including the turbine stop and bypass valves and connected piping up to and including the first valve that is either normally closed or capable of automatic closure during all modes of nomal reactor operation.
- Excerpt from Table 1 Components Quality Standard B Pressure Vessels ASME Boiler and Pressure Vessel Code,Section III, " Nuclear Power Plant Com-l ponents," Class 2 (see notes a,b,c next page)
Piping As above Pumps As above Valves As above l
Atmospheric Storage Tanks As above 0-15 psig Storage Tanks As above f
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(a) See Szction 50.55a for guidance with regard lto the Code and Addenda to be applied.
(b) ASME Code N-symbol need not be applied.
(c) The specific applicability of code case will' be covered separately in other regulatory guides or in Commission regulations, where appropriate. Applicants proposing the i
use of code cases not covered by guides or regulations j
il should demonstrate that an acceptable level of quality and safety would be achieved.
j Code Relief Request i
Licensee requests relief from performing code-required Class 2
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j examinations of the main steam lines outside the outermost contain-l ment isolation valves.
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Proposed Alternative Examination The main steam lines up to the turbine stop and bypass valves will be subjected to a hydrostatic test at the same time and under the same test conditions as the Class 1 components, j
i Licensee's Basis for Requesting Relief i
Peach Bottom was designed and built prior to the requirement l
for a third valve in the main steam line. There are no safety-
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related structures, systems, or components which could be adversely affected by a pipe break in the main steam line downstream of the outermost containment isolation valve and such a pipe break does not result in significant offsite doses as set forth in the Final Safety Analysis Report (FSAR) Chapter 14 and Supplement 2.
Con-i sequently, there is no need to classify the Peach Bottom main steam i
lines as ASME Class 2 (equivalent) for purposes of inservice inspection.
Additionally, the following provides a more detailed justi~fi-cation for not performing the type of inspection required of.ASME Class II piping-(1) Physical access to welds in subject lines is not readily available. Scaffolds and platforms of significant size would have to be erected.
Both dollar costs and radiation exposure would be significant.
(2) The as-built weld configuration in' subject lines are not conducive to a UT examination (licensee's presently employed volumetric inspection technique). Weld crowns would have to be extensively reworked, again at a significant dollar j
and radiation exposure cost, to facilitate UT examinations.
In addition, the alternative radiographic technique for volumetric examination could not be employed because of the vast anount of routine maintenance work that is performed.n the surrounding areas.
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(3) The piping material is mild steel and the licensee's records show that the same Class 1 piping' at Peach Bottom has experienced no reportable indications during past inservice inspections. The licensee knows of no struc-tural integrity problems or reports of failure in mild l
steel (main steam line) piping throughout the BWR industry.
Evaluation Based on Regulatory Guide 1.26 the main steam lines outside the outermost containment isolation valves are classified Group B for quality standards, and Class 2 for Nuclear Power Plant Compon-ents per Section III. The requirements to examine Class 2
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74 Edition of the components were not established until tg8 XI only required Code was issued. The 1971 Edition of C..,.
i exa:nination of Class 1 components. Since the construction' permits i
for these units were issued in January 1968, no provisions were made for future weld examinations at the time that the main steam lines were designed.
The principal justification for the licensee's relief request is based upon the cost in exposure and in dollars to provide access to the welds and to prepare the weld crowns to facilitate ultra-sonic examination.
Since both of these units have been in commer-cial operation approximately eight years now, it would be impractical to require the code examinations for these steam lines.
The service life of carbon steel in main steam piping in the BWR industry has been excellent. The analysis of a pipe break accident in these steam lines has been demonstrated by the licensee in the FSAR as not being a safety hazard to the public.
These same steam lines are not being inspected in other BWR plants, i.e.,
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Cooper, Quad Cities 1 & 2, Hatch 1 & 2 and Pilgrim. Yet they are being inspected in Browns Ferry 1, 2 & 3, and at WPPSS WNP-2.
i Conclusions and Recommendations Based on the above evaluation, it is concluded that for the j
welds discussed above, the Code requirements are impractical.
It i
is further concluded that the alternative examination discussed above will provide necessary added assurance of structural reli-l ability. Therefore, it is reconsnended that relief from perfonning l
Code-required Class 2 examinations of the main steam lines outside l
the outermost containment isolation valves be granted, provided l
that the proposed alternative examination is perfonned.
References References 5, 7, 10, 12 and 14.
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REFERENCES i
1.
G. Lear (NR[)' to E. G. Bauer, Jr. (PEC), Peach Bottom Unit Nos. 2 and 3, Docket Nos. 50-277 and 50-278, April 26,1976.
2.
J. L. Hankins (PEC) to G. Lear (NRC), Docket Nos. 50-277 and 50-278, June 4, 1976.
3.
G. Lear (NRC) to E. G. Bauer, Jr. (.PEC), Peach Bottom Atomic Power Station Unit Nos. 2 and 3, November 22, 1976.
4.
E. J. Bradley (PEC) *.o E. G. Case.(NRC), Peach Bottom Atomic Power Station Units 2 and 3, Docket Nos. 50-277 and 50-TT8, May 5,1977, 4
i 5.
E. J. Bradley (PEC) to G. Lear (NRC), Peach Bottom Atomic Power Station Unit 2, Docket No. 50-277, August 4, 1977.
6.
G. Lear (NRC) to E. G. Bauer, Jr. (PEC), Peach Bottom Atomic Power Station Unit No. 2, Docket No. 50-277, August 30, 1977.
7.
E. J. Bradley (PEC) to G. Lear (NRC), Peach Bottom Atomic Power Station, Inservice Inspection Program', Unit 3, Docket No. 50-278, January 23, 1978.
8.
T. A. Ippolito (NRC) to E. G. Bauer, Jr. (PEC), Docket Nos. 50-277 and 50-278, August 10, 1978.
9.
S. L. Daltroff (PEC) to T. A. Ippolito (NRC), Docket Nos. 50-277 and 50-278, September 20, 1978.
10.
S. L. Daltroff (PEC) to T. A. Ippolito (NRC), November 22, 1978.
11.
S. L. Daltroff (PEC) to T. A. Ippolito (NRC), Peach Bottom Atomic Power Station Inservice Inspection for Units No. 2 and 3, Docket Nos. 50-277 and 51T-T/8, February 19, 1980.
12.
J. F. Stolz (NRC) to E. G. Bauer, Jr. (PEC), Docket Nos. 50-277 and 50-278, March 5, 1982.
13.
S. L. Daltroff (PEC) to J. F. Stolz (NRC), Docket Nos. 50-277 and 50-278, April 5, 1982.
14.
S. L. Daltroff (PEC) to J. F. Stolz (NRC), Peach Bottom Atomic Power Station.
Units 2 and 3, NRC Request for Additional Information on the Peach Bottom ISI Program, Docket Nos. 50-277 and 50-278, June 11, 1982.
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