ML20081E421

TER on Second 10-Yr Interval Inservice Insp Program Plan, Jm Farley Nuclear Power Plant Unit 2

ML20081E421
Person / Time
Site:	Farley
Issue date:	11/30/1990
From:	Beth Brown EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20081E423	List: ML20081E421
References
CON-FIN-D-6022 EGG-MS-8944, NUDOCS 9011130333
Download: ML20081E421 (108)

Text

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EGG MS 8944 I

November 1990 i

TECHNICAL EVALUATION REPORT l

i

/daho TECHNICAL EVALVATION REPORT ON THE SECOND l

Nat/ona/

10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN: ALABAMA POWER COMPANY, Eng/neer/ng JOSEPH H. FARLEf NUCLEAR POWER PLANT, UNIT 2, l

Laboratory DOCKET NUMBER 50-364 l

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Managed B. W. Brown l

by the U. S.

J. D. Hudlin Department j

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EGG-MS 8944 4

1ECHNICAL EVALVATION REPORT ON THE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

ALABAMA POWER COMPANY,'

JOSEPH M. FARLEY NUCLEAR POWER PLANT, UNIT 2, DOCKET NUMBER 50-364 e

B. W. Prown J. D. Mudlin Published November 1990 Idiho National Engineering Laboratory EC&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for:

U.S. Nuclear Regulatory Commission Washington, D.C.

20555 under DOE Contract No. DE-AC07-761D01570 FIN No. D6022 (Project 5) 1

ABSTRACT This report presents the results of the evaluation of the Joseph H. Farley Nuclear Power Plant. Unit 2, Second 10-Year Interval inservice Inspection (ISI) Program, through Revision 1, submitted August 15, 1990, including the requests for relief from the American Society of Mechanical Engineers (ASME) l Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical.

The Joseph H. Earley Nuclear Power Plant, Unit 2, Second 10 Year Interval ISI Program is evaluated in Section 2 of i

this report. The ISI Program is evaluated for (a) compliance with the

)

appropriate edition / addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI-related commitments identified during the previous Nuclear Regulatory Commission reviews.

The requests for relief are evaluated in Section 3 of this report.

I l

This work was funded under:

U.S. Nuclear Regulatory Commission FIN-No. D6022, Project S Operating Reactor Licensing Issues Program, Review of ISI for ASME Code Class 1, 2, and 3 Components 11

o, s.

SUMMARY

The Licensee, Alabama Power Company, has prepared the Joseph H. Farley Nuclear Power Plant, Unit 2, Second 10-Year Interval Inservice Inspection (ISI) Program, through Revision 1, to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examination for Code Class 1 and Code Class 2 piping welds has been determined by the 1974 Edition through Summer.1975 Addenda as permitted and required by 10 CFR 50.55a(b).

This program (including relief requests) was submitted pursuant to the NRC's August 31, 1988 exemption which i

permitted revision of the Unit 2 ISI Program to coincide with the Code of record and updated schedule currently used for Unit 1.

In accordance with this exemption, the updated program was implemented during the Unit 2 sixth refueling outage which began on March 24, 1989.

The ISI Program applies to the third period of the first interval as well as to the first and second periods of the second interval.

The information in the Joseph M. Farley Nuclear Power Plant Unit 2, Second 10-Year Interval ISI Program, Revision 0, submitted March 23, 1989, was

reviewed, included in the review were the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical.

As a result of this review, a request for additional information was prepared describing the information and/or clarification required from the Licensee in order to complete the review.

The Licensee provided additional information in submittals dated October 5,1989; December 7, 1989; and April 12, 1990.

Revision 1 to the ISI Program was submitted in a letter dated August 15, 1990.

Corrections to Revision 1 of three relief requests were submitted in a letter dated September 12, 1990.

Based on the review of the documents listed above and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Joseph M. Farley Nuclear Power Plant, Unit 2. Second 10-Year Interval ISI Program, through Revision 1, is considered unacceptable and not in compliance with 10 CFR 50.55a(g)(4) due to an unacceptable examination sample ar.d i

unacceptable application of the exclusion criteria (see Sections 2.2.2 and iii

2.2.3 of this report).

It is recommended that relief be granted with conditions for Requests for Relief RR-15, RR-16, and RR-17.

For Requests for Relief RR-4 (in part), RR 29, and RR-33 (in part), it is recommended that relief be denied.

Requests for Relief RR 6, RR-24, RR-41, RR-42, and RR-45 either have been withdrawn or are not included in the scope of this document.

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<e CONTENTS ABSTRACT..............................................................

it

SUMMARY

111

-1.

INTRODUCTION......................................................

I 2.

EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN...................

4 2.1 Do c ume n t s E v a l u a t e d...................... /.....................

4 2.2 Compliance with Code Requirements..............................

5 2.2.1 Compl iance with Applicabl e Code Editions...................

5 2.2.2 ' Acceptability of the' Examination Sample....................

5 2.2.3 Exclusion Criteria.........................................-

6 2.2.4 Augmented Examination Commitments..........................

7 2.3 Conclusions.................................................

8 3.

EVALUATION OF RELIEF REQUESTS.....................................

9 3.1 Class 1 Components.............................................

9 3.1.1 Reactor Pressure Vessel....................................

9 3.1.1.1 Request for Relief No. RR-8, Examination Category B-A, item Bl.22, Reactor Pressure vessel Lower Head Meridional Weld.....................

9 3.1.1.2 Request for Relief No. P9-14 Examination Category B-G-1, Item B6.40, Threads-in the Reactor Pressure Vessel Flange........................

9 3.1.2 Pressurizer................................................

11 i

3.1.2.1 Request for Relief No. RR-9, Examination

]

Category B-D, Item B3.110, Pressurizer Nozzl e-to-Ves sel Wel d s................................

11 3.1.3 Heat Exchangers and Steam Generators.......................

13-

'3.1.3.1-Request for Relief No. RR-10 -Examination-Category B F, Item B5.70, Steam Generator 2

Nozzle-to-Pipe Safe End Welds.........................

13 1

3.1.3.2 Request for Relief No.- RR-ll, Examination Category B-D, Item B3.140, Steam Generator Inlet and Outlet Nozzle Inner Radius Sections.........

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3.1.4 Piping Pressure Boundary...................................

17 3.1.4.1 Request for Relief No. RR-13. Examination Category B-J, item B9.31, Class 1 Branch Pipe Connection Welds.................................

17 3.1.5 Pump Pressure Boundary.....................................

19 3.1.5.1 Request for Relief No. RR-15, Examination Category B L-2, item B12.20, Reactor Coolant Pump Internal Pressure Boundary Surfaces..............

19 3.1.6 Valve Pressure Boundary...................................

22 3.1.6.1 Request for Relief No RR-16. Examination Category B N-2, Item B12.50, Internal Pressure Boundary Surf aces of Class 1 Valves...................

22 3.1.7 General (Noreliefrequests) 3.2 Class 2 Components.................................

25 3.2.1 Pressure Vessels..........................................

25 3.2.1.1 Request for Relief No. RR-18, Examination Category C-A, Items Cl.20 and Cl.30, Pressure Retaining Welds in the Regenerative Heat Exchanger....

25 3.2.1.2 Request for Rellaf No. RR-19, Examination Category C-A, l' yAtems are at normal operating pressure.

Licensee's Basis for Reauestina Relief:

The Licensee states that hydrostatic testing of the above systems is net practical since they operate continuously during all modes of plant operations.

Evaluation:

In the Licensee's December 7, 1989 response to the NRC request for additional information, the Licensee stated that a detailed review was conducted to identify those portions of these systems which cannot be hydrostatically tested as required by the Code.

The piping and components listed in that submittal either lie beyond the Code boundary valve used to isolate the system for performance of the -

t hydrostatic test or interconnect the redundant system trains such that removal from service for testing would render the entire system inoperable.

The Reactor Makeup system was not l

included in that listing of systems that cannot be j

hydrostatically tested.

As shown in the drawings referenced in the Licensee's relief request, the subject portions of Class 3 piping in the service 55

_. _ -... _ m. _.

4 wr. cr system are unisolatable from non safety related piping prc'iding service water supply to and from the turbine building.

j As shown in the drawings referenced in the Licensee's relief request, the subject portions of Class 3 piping and components in the pent fuel pool cooling, component cooling water, and chemical and volume control systems cannot be isolated for

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hydrostatic tests since removal from service for testing would i

render the entire system inoperable.

The design 'of these systems, therefore, makes the Code required hydrostatic test of these portions of Class 3 piping and components impractical to perform.

In order to perform the hydrostatic test of these portions of Class 3 piping and com ments-in accordance with the requirements, these systems would have to be redesigned, refabricated, and installed. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from i

imposition of the requirement.

The Licensee stated in the December 7, 1989 submittal that those portions of the service water, component cooling water, chemical and volume control, and spent fuel pool cooling i

systems, which can be isolated without loss of-redundant trains within the system, will be hydiostatically tested to the extent practical as required by the Code.

These Code-required hydrostatic tests and the Licensee's proposed

't visual-. examination at normal operating pressure (functional pressure test) for_those_ portions of piping for which relief is requested will provide reasonable assurance of the continued inservice structural integrity.

==

Conclusions:==

The hydrostatic test required by Section XI of the ASME Code for the subject Class 3 piping and components, with the exception of the Reactor Makeup system, is 56

,2 impractical to perform at Farley, Unit 2, because the piping and components either lie beyond the Code boundary valve used i

to isolate the system or interconnect the redundant system trains such that removal from service for testing would render the entire system inoperable.

Imposition of the requirements i

on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the functional pressure test.

The proposed

[

test will provide adequate assurance that structural integrity of the subject piping and components is maintained.

Therefore, it is concluded that public health and safety will not be endangered by allowing the functional t-< to be performed in lieu of the Code requirement.

It is re::ommended that relief be granted as requested for the piping listed above with the exception of the Reactor Makeup -/ stem. With regard to the Reactor Makeup system, it is recommended that relief be denied.

3.4.3.4 Reauest for Relief No. PR-34. Hydrostatic Test of Class 3 Sorav Additive Pioina and Comoonents in the Containment Sorav System l

Code Reauirement:

Section XI, Paragraph IWD-2510 and Table IWD 2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD 5000.

Licensee's Code Relief Recuest:

Relief is requested from f

performing the Code-required hydrostatic pressure test of Class-3 spray additive piping and components in the containment spray system.

Licensee's Proposed Alternative Examination: The Licensee states that a measured flow test in accordance with plant 57

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Technical Specification paragraph 4.6.2.2d will be conducted f

periodically. to-assure the leaktightness of these Class 3 j

c'omponents.-

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-Licensee's-Basis for Reauestino Relief:

The Licensee states that, while in' service, these spray additive lines have an operating pressure of 15 psig and temperature of 100'F, which are well below the design conoitions af 210 psig pressure and

-j 300*F temperature.

Therefore, a syst a hydrostatic test at i

1.25 times service pressure would not' provide a meaningful test.

In addition, this piping system contains sodium hydroxide at a concentration of 30 to 32% per Technical ll Specification 3.6.2.2a.

Sodium hydroxide is a hazardous substance according to.40 CFR part 302 '(CERCLA). Alabama Power Company does not consider it practical to perform the i

hydrostatic testing since it would expose personnel, equipment, and the' environment to a hazardous substance at l'.25Pd when this system operates at only 15;psig and 100'F.

Evaluation: These lines contain highly corrosive sodium j

hydroxide and the system operates at a pressure of 15 psig and 7

temperature of 100'F, which is significantly less than the

[

design corditions. The presence of the highly corrosive sodium hydroxide in the spray additive piping and the fact j

that the system % rates at-a-pressure that is far below the design prcssi' mn the Code-required hydrostatic test impractical n rar iorm.

If the hydrostatic test was perfccmed 1

in accordance with the requirements, personnel, equipment, and j

the environment could be exposed to a hazardous substance.

The increase. in plant safety would not compensate for the j

burden placed on the Licensee that would result from l

imposition of the requirement.

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Alabama Power Company's proposed alternative is to perform a measured flow test in accordance with the Farley Technical l

Specifh.ations to assure the leaktightness of system.

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alternative will provide reasonable assurance of the continued inservice structural integrity of the Class 3 spray additive piping-and_ components.

4

-Conclusions: The hydrostatic test requirei by Section XI of I

-the ASME Code for the Class 3 spray additive piping and components is impractical to perform at Fcriey, Unit 2, because the lines contain highly cor.rosive sodium hydroxide _

and the system operates at a pressure significantly less than the design-conditions (upon which the Code requirement is based). -Imposition of the Code requirement on-Alabama Power Company would cause a burden that'would not be compensated by an increase in safety above tnat provided by the proposed alternative.

The proposed alternative exanination will provide assurance that_ structural integrity of the spray vdditive piping and components is maintained.

Therefore, it is-concluded that public health and safety will not be endangered by allowing the alternative examination to be-performed in lieu of the Code requirement.

It is recommended 4

that relief be' granted as requested.

3.4.3.5 Reques' for Relief No. RR-35. Hydrostatic Test of Class 3 Portio % of Buried Pinino in the Service Water System Code Recuirement:

Section XI, Paragraph.IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of-Article IWD-5000. Subarticle IWA-5244 defines the VT-2 visual examination for buried components.

Licensee's Code Relief Recuest:

Relief is requested from performing the Code-required visual examination of Class 3 portions of buried piping in the service water system during hydrostatic testing.

59

c, Licensee's Proposed Alternative Examination:

The Licensee j

states that buried piping will be inspected by conducting a visual observation of the ground (at ground elevation) for wet spots while the systems are at operating pressure.

This is in accordance with the Final Safety Analysis Report, Paragraphs 3.1.41 and 9.2.1.4.

Licensee's Basis for Reauestina Relief:

The Licensee states that the design of this system does not allow access for visual examination as required by IWA-5244.

Evaluation:

Portions of the Class 3 piping in the service water system are buried.

The design of the service water system does not provide access to the the portions of buried piping to perform the Code-required visual examination during hydrostatic testing.

The system design, therefore, makes the Code required examination impractical to perform.-

In order to perform the Code-required visual examination during the hydrostatic test in accordance with the requirements, the service water system would require design modifications to provide access for examinations.

The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

The Licensee's proposed alternative examination is to conduct a visual observation (in accordance with the Final Safety Analysis Report, Paragraphs 3.1.41 and 9.2.1.4) of the ground (at ground elevation) for wet spots while the systems are at operating pressure. This examination will provide reasonable assurance of the continued inservice structural integrity of the buried piping.

==

Conclusions:==

The VT-2 visual examination required by Section XI of the ASME Code during hydrostatic testing of the subject Class 3 service water system piping is impractical to perform at Farley, Unit 2, because the piping is buried with l

60 l

u no access for visual examinations referenced in IWA 5244.

Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative examination will provide assurance that structural integrity of the buried piping is maintained.

Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative to be performed in lieu of the Code requirement and it is recommended that relief be granted as requested.

3.4.3.6 Reouest for Relief No. RR-36. VT-2 Visual Examination of Heat Exchanaer Tubes of Class 3 pressure Retainina Safety Related Heat Exchanaers Code Reouirement:

Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.

Licensee's Code Relief Reouest:

Relief is requested from performing the Code-required VT-2 visual examination of heat exchanger tubes of Class 3 component cooling water heat exchangers HX-Q2P17 H001A-8, H001B-AB, and H001C-A.

Licensee's Proposed Alternative Examination:

The Licensee states that tube side inspection will be performed by j

isolating the heat exchanger, removing the waterbox covers, and pressurizing the shell side with water.

Tube leakage is indicated if there is any flow from the tubes while in this l

configuration. This type inspection will be performed at least once per inspection interval.

l 61

Licensee's Basis for Reauestino Relief:

The Licensee states that, due to component design and limited accessibility, these heat exchanger tubes cannot be visually inspected under high pressure hydrostatic test conditions.

Integrity of the component is assured by testing the component as a unit.

Evaluation:

Although it is our interpretation that it is not the intent of the Code to require VT.-2 visual examination of the heat exchanger tubes during the hydrostatic test of the heat exchangers, the Code does not specifically exclude these items. The design of the heat exchanger does not provide access to the subject heat exchanger tubes in order to perform the VT-2 visual examination during hydrostatic testing.

Inaccessibility during a hydrostatic test, therefore, makes the VT-2 visual examination of the heat exchanger tubes during the hydrostatic test impractical to perform.

In order to perform the VT-2 examination during hydrostatic testing, the heat exchangers would require redesign to provide access for the examination. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the rcquirement.

Alabama Power Company's proposed alternative is to perform a tube side inspection by isolating the heat exchanger, removing the waterbox covers, and pressurizing the shell side with l

water at least once per inspection interval.

Because tube leakage will be detected if there is any flow from the tubes while in this configuration, assurance of the continued inservice structural integrity will be provided.

==

Conclusions:==

The VT-2 visual examination required by Section XI of the ASME Code for Class 3 pressure retaining components during hydrostatic tests is impractical to perform at Farley, Unit 2, with regard to heat exchanger tubes because the tubes are inaccessible.

Imposition of the requirement on Alabama Power Company would cause a burden that would not be 62

se compensated by an increase in safety above that provided by.

the proposed alternative.

The proposed alternative test-will provide assurance that structural -integrity of these-Class 3 heat exchanger tubes is maintained. Therefore, it is

.~ concluded that public health and safety will.not be endangered by allowing the alternative examination to be performed in lieu-of the Code requirement.

Although it is our-interpretation that it is not the. intent of the Code to require VT-2 visual examination of these heat exchanger tubes during the hydrostatic test, the Code does not specifically.

exclude these items-from the VT-2 visual examination.

Therefore, it is recommended that relief be granted as requested.

3.4.3.7 Recuest for Relief No. RR-37. VT-2 Visual Examination of the Coolino Coils for Class 3 Pressure Retainino Safety Related Coolers o

Code Recuirement:

Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that.all Class-3 pressure retaining j

components be subjected to VT-2 visual examinat!on in conjunction with the system pressure test requirements of Article IWD-5000.

Licensee's Code Relief Recuest:

Relief is requested from performing the Code-required VT-2 visual examination of the cooling coils for the following Class 3 pressure retaining i.

. safety related coolers:

(a)

Four containment coolers - 02E12-H001A-A, H001B-A, H001C-B, and H001D-B.

1-(b) Two auxiliary feedwater pump room coolers - 02E16-H005A-A-l-

and H005B-B.

(c)

Two component cooling water pump room coolers Q2E16-H004A-A and H004B-B.

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-(d) :Two containmentispray pump room coolert Q2E16-H002A-A and.

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H0028-B.

(e); Two RHR/LHSI pump room coolers-Q2E16-H003A-A and H0038-B.

(f) Three battery charging room coolers Q2E16-H006A-A, LH006B-B, and H006C-AB.

(g) Three charging pump room coolers Q2E16-H001A-A,'H0018-AB, 4

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and H0010-8.

(h) Two 600-V load center coolers Q2E16-H009-A and H010-B.

(i) Two motor control center room coolers Q2C16-H007-A and H008-B.

Licensee's Proposed Alternative Examination:

The Licensee states that the normal operation of these cooling units demonstrates their structural and leaktight integrity.

Visual inspection to verify leaktightness will be performed while the system is at normal operating pressure. - Also, the coolers

. provided with the drain basin will be inspected by observing for abnormal flow (other than normal-condensation).

Licensee's Basis for Reauestina Relief:

The Licensee states

- that, due to the. component design, the cooling coils (heat exchanger _ tubes) cannot _be visually inspected during the conduct of system pressure test.

Evaluatio'ni AlthoughLit is our interpretation'that it is not the intent of the Code to require VT-2 visual examination of the cooling coils of-the subject Class-3 safety related coolers during the system pressure test, the Code does.not specifically exclude these items.

The design of the coolers does not provide-access to the subject cooling coils to perform the-VT-2 visual examination.during pressure testing.

Inaccessibility during a system pressure test, therefore, makes.the VT-2 visual ~ examination of the cooling coils during l-the system pressure test-impractical to perform.

In order to L

perform the VT-2 examination during pressure testing, the coolers would require redesign to provide access for the

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examination.

The increase in plant safety could not compensate for-the burden placed on the Licensee that would result from imposition of the requirement.

Because normal operation of these cooling units demonstrates tneir structural and leaktight integrity, Alabama Power Company's proposed alternative to perform a visual inspection to verify leaktightness while the system is at normal operating pressure and to observe for abnormal flow (other than normal condensation) on the coolers provided with a drain basin provides assurance of the continued inservice structural integrity.

==

Conclusions:==

The VT-2 visual examination required by Section XI of the ASME Code for Class 3 pressure retaining components during system pressure tests is impractical to perform at Farley, Unit 2, with regard to the cooling coils of the subject Class 3 safety related coolers because the cooling coils are inaccessible.

Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated by an increase in safety above that provided by the proposed alternative.

The proposed alternative test will provide assurance that structural integrity of these Class 3 cooling coils is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement. Although it is our interpretation that it is not the intent of the Code to require VT-2 visual examination of these cooling coils during the system pressure test, the Code does not specifically exclude these items from the VT-2 visual examination. Therefore, it is recommended that relief be granted as requested.

65

3.4.3.8 Reouest for Relief No. RR-38. Hydrostatic Test of Class 3 Piping of the Auxiliary Steam System Code Reauirement:

Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.

Licensee's Code Relief Reauest:

Relief is requested from performing the Code-required hydrostatic pressure test of the Class 3 pressure retaining piping of the auxiliary steam system downstream of valves Q2N12V002B and Q2N12V003.

Licensee's pronosed Alternative Examination:

The Licensee states that the VT-2 visual examination to verify leaktightness will be performed while these lines are at normal operating pressure.

Licensee's Basis for Reauestina Relief: The Licensee states that there is no practical means of isolating these portions

^

of the auxiliary steam system and, therefore, hydrostatic testing cannot be conducted on these lines.

Evaluation: The ISI Program drawing referenced in the Licensee's relief request shows that there are no valves downstream of valves Q2N12V002B and Q2N12V003 in the auxiliary steam supply lines capable of providing a positive isolation when performing a hydrostatic test. The system design, therefore, makes the Code-required hydrostatic test impractical to perform.

In order to perform the hydrostatic test in accordance with the requirements, the subject lines would require design modifications to provide isolability.

The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

66

Alabama Power Company's proposed alternative to perform the VT-2 visual examination to verify leaktightness while these lines are at normal operating pressure will provide reasonable assurance of the continued inservice structural integrity.

==

Conclusions:==

The hydrostatic test required by Section XI of the ASME Code for the subject auxiliary steam system piping is impractical to perform at Farley, Urtit 2, because there are no valves downstream of valves 02N12V002B and Q2N12V003 capable of providing a positive isolation when performing a hydrostati: test.

Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety abcvu that provided by the proposed alternative. The proposed VT-2 visual examination at operating pressure will provide assurance that structural integrity of the subject lines is maintained. Therefore, it is concluded that public health and safety will not be endangerad by allowing the alternative examination to be performed m lieu of the Code requirement.

It is recommended that relief be granted as requested for the subject auxiliary steam supply lines.

3.4.3.9 Recuest for Relief No. RR-39. Hydrostatic Test of Class 3 Auxiliary Feedwater Pumo Minimum Flow Pinj.cg Code Recuirement:

Section XI, Paragraph FWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be' subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.

l Licensee's Code Relief Recuest:

Relief is requested from performing the Code-required hydrostatic pressure test of the following Class 3 pressure retaining auxiliary feedwater pump minimum flow piping:

67 h

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-i i

(a); Line No -2"DBC between valve Q2N23V019A and flow f

orifice F03214A.

e (b) -Line No. 2"DCB between valve Q2N23V0198 and flow orifice F032148.

(c)

Line No. 2"DBC-4 and 3*DBC between valve-Q2N23V010 and-flow orifice F03219.

j Licensee's Proposed Alternative Examination:- The Licensee states that these lines will receive a visual examination during normal operation at system operating temperature and j

pressure, j

I Licensee's Basis for Reouestino Relief:

The Licensee states

_that performance of a hydrostatic test on the portions of the f

piping system listed could overpressurize the lower pressure, i

non-Code piping downstream of these flow orifices.

I Evaluation:' The ISI Program drawing referenced in the j

Licensee's relief request-shows that the. design of the i

auxiliary feedwater pump minimum flow piping system does not f

provide distinct class boundaries to-allow pressurization of I

the class 3 piping without overpressurizing adjacent non-Code

-i

-piping. The system design, therefore,'makes the Code-required hydrostatic test impractical to perform..In order to perform I

the hydrostatic test in accordance with the requirements, the subject lines-would require-design: modifications 'to provide isolability. The increase-in plant safety would not compensate for the burden placed on the Licensee that would

-resul't.from imposition of the requirement.

Alabama Power Company's proposed alternative to perform the VT-2 visual examination during normal operation at system operating temperature and-pressure will provide reasonable

-assurance of the continued inservice structural integrity.

==

Conclusions:==

The hydrostatic test required by Section XI of the ASME Code for the subject Class 3 pressure retaining 68

.. t eT C

auxiliary feedwater pump minimum flow piping is impractical to perform at Farley, Unit 2, because the subject lines cannot be isolated from adjacent non-Code piping.

Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative.

The proposed alternative will provide assurance that structural integrity of the subject lines is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement.

It is recommended that relief be granted as requested.

3.4.3.10 Reouest for Relief No, RR-44. VT-2 Visual Examination of Heat Exchanaer Tubes of Class 3 Pressure Retainina Safety Related Heat Exchancers Code Reouirement:

Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Cless 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.

Licensee's Code Relief Reouest:

Relief is requested from performing the Code-required VT-2 visual examination of the heat exchanger tubes of Class 3 pressure retaining safety related heat exchangers (two each spent fuel pool cooling HX-Q2G31 H001A-B and H001B-A).

Licensee's Proposed Alternative Examination:

The Licensee states that tube side leakage will be identified by the existing in-line radiation monitoring system and existing periodic sampling of the Component Cooling Water and Spent fuel Pool Cooling Systems.

If a tube leak is indicated, the water box covers will be removed and a VT-2 visual examination 69

w performed to identify the leaking tubes.

The tubes will be plugged prior to returning the heat exchanger to service.

Licensee's Basis for Reouestino Relief:

The Licensee states that, due to component design and limited accessibility, these heat exchanger tubes cannot be visually inspected ender high pressure hydrostatic test conditions.

Integrity of the component is assured by normal operation of the system.

Evaluation:

Although it is our interpretation that it is not the intent of the Code to require VT-2 visual examination of the heat exchanner tubes during the hydrostatic test of the heat exchangers, the Code does not specifically exclude these items.

The component design does not provide access to the heat exchanger tubes of the subject Class 3 safety related heat exchangers in the spent fuel pool cooling system to perform the VT-2 visual examination during hydrostatic g

testing.

Inaccessibility during a hydrostatic test, l

therefore, makes the VT-2 visual examination of the heat exchanger tubes during the hydrostatic test impractical to perform.

In order to perform the VT-2 examination during hydrostatic testing, the heat exchangers would require redesign to provide access for the examination.

The increase in plant safety would not compensate for the burden placed on tha (Mr.see that would result from imposition of the requiremert.

Alabama Power has stated that tube side leakage will be identified by the existing in-line radiation monitoring system and existing periodic sampling of the component cooling water and spent fuel pool cooling systems and that, if a tube leak is indicated, the water box covers will be removed and a VT-2 visual examination performed to identify the leaking tubes (the tubes will be plugged prior to returning the heat l

exchanger to service). This examination will provide reasonable assurance of the continued inservice structural integrity.

70 l

w Conclusiqu:

The VT-2 visual examination required by Section XI of the ASME Code for Class 3 pressure retaining components during hydrostatic tests is impractical to perform at-Farley, Unit 2, with regard to heat exchanger tubes because the tubes are inaccessible, imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated by an increase in safety above that provided by the proposed a'lternative.

The propased alternative will provide assurance that structural integrity of these Class 3 heat exchanger tubes is maintained.

Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement. Although it is our interpretation that it is not the intent of the Code to require VT-2 visual examination of these heat exchanger tubes during the hydrostatic test, the Code does not specifically exclude these items from the VT-2 visual examination.

Therefore, it is recommended that relief be granted as requested.

3.4.4 General 3.4.4.1 Recuest for Relief No. RR-45. Hydrostatic Test of Class 2 and Class 3 Low Pressure Systems NOTE: As stated in the Licensee's October 5, 1989 submittal, Request for Relief No. RR-45 is not required and will be deleted in the next ISI Program revision.

3.4.4.2 Recuest for Relief No. RR-46. Schedulino of Class 2 and Class 3 System Hydrostatic Pressure Tes11 Code Recuirement:

Section XI, Table IWC-25001, Examination Category C-H, Note 5 requires that system hydrostatic tests be 1

71

n conducted at or near the end of the inspection interval or during the same inspection period of each inspection interval for Inspection Program B.

Note 2 of Table IWD-2500-1, Examination Categories D-A, D-B, and D-C. requires that system hydrostatic tests be conducted at or near the end of the inspection interval or during the same inspection period of each inspection interval for laspection Program B.

Licensee's Code Relief Reouest:

Relief is requesi.ed from scheduling Class 2 hydrostatic tests in accordance with Note 5 of Table IWC-2500-1, Examination Category C-H and from scheduling Class 3 hydrostatic tests in accordance with Note 2 of Table IWD-2500-1, Examination Categories D-A, D-8, and D-C.

Licensee's Proposed Alternative Examination:

The Licensee states that all 25 hydrostatic tests will be performed during the second inspection interval.

They will be scheduled to distribute the testing evenly among the three periods for the second interval.

Licensee's Basis for Reauestina Relief:

The Licensee states that the system hydrostatic tests are scheduled on a periodic basis in accordance with Inspection Program B.

As a result of performing additional tests during the first 10-year interval, it is necessary to move eight hydrostatic tests forward one l

period. The original schedule-for performing hydrostatic testing was based on dividing the systems to be tested into 18 procedures.

Due to operational conditions during the course of the interval, several procedures were divided L

resulting in additional hydrostatic testing procedures to be l

performed. At the end of the interval, 25 procedures existed to cover the systems to be tested.

Evaluation:

The Licensee has committed to scheduling the hydrostatic tests such that the elapsed time between a system examination will not exceed 10 years.

Therefore, the intent 72 l

m

.i of the Code requirement will be met.

The Licensee has demonstrated that the proposed alternative scheduling provides an acceptable level of quality and safety and that compliance with the Code schedule would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.

==

Conclusions:==

Based on the above evaluation, it is concluded that the Licensee's proposed scheduling of hydrostatic pressure tests meets the intent of the Code requirements.

j Therefore, it is concluded that public health and safety will j

not be endangered by allowing the alternative scheduling in l

lieu of the Code requirement.

Pursuant to 10 CFR 50.55a(a)(3), it is recommended that relief be granted as requested, l

3.5 General 3.5.1 Ultrasonic Examinjtlion Technioues 3.5.1.1 Recuest for Relief No. RR-1. Material Reauirements for Calibration Bloch Code Reovirement:

Section XI, Paragraph IWA-2232 requires that ultrasonic examination of vessel welds in ferritic materials greater than 2 inches in thickness be performed in accordance with Article 4,Section V.

Paragraph T-434.1 l(3) of Article 4 requires that the material from which calibration blocks are fabricated be of the same material specification, product form, and heat treatment as one of the materials being joined.

Licensee's Code Relief Recuest:

Relief is requested from the material requirements for calibration blocks used to perform ultrasonic examination of the following:

73

j e

Cal. Block Comoonent to be examined APR-6:

Steam generator channel head to-tubesheet welds-APR-7:

Boron injection tank head-to-shell circumferential welds and nozzle-to-head wolds.

ALA RV-1:

Reactor vessel lower head to-lower shell weld and all lower head welds.

Boron injection tank-head to shell circumferential welds l

ALA-RV-3:

Reactor vessel top he,ad welds t

ALA-RV-5:

Reactor vessel shell welds lig.ensee's Procosed Alternative Examination:

The Licensee states that the subject calibration blocks are in compliance with-the material requirements -of Paragraph T-533,- Article 5, Section V-of the 1974 ASME Code.

This paragraph requires the block to.be of'similar metallurgical structure and the same or an equivalent P-number grcuping as the finished component.

l l

Licensee's Basis for Recuestino Relief:

The Licensee states j

that, during fabrication of the Farley, Unit 2, nuclear steam supply system vessels, the calibration blocks used to perform examinations by the vessel manufacturer were fabricated to-the

]

requirements of.ASME Section III. -When ASME Section XI was issued for inservice inspection, the new requirements for vessel calibratiu. blocks rendered the existing blocks-j unacceptable for use. The original blocks had to be replaced

{

but some vessel materials were no longer available. The vessel calibration blocks had to:be refabricated to the Section XI requirements applicable at that. time.

l Information was submitted in the Licensee's October 5, 1989 j

l response to the NRC request for additional information.

The L

following summarizes evaluations which were conducted to determineithe suitability of the alternative calibration block j

materials:

APR-6: The SA-216 Gr. WCC and SA-508 C1. 2 or 3 materials

.l

{

examined and SA-336 C1. F-l' alternative calibration block 74

s material have the same product form, are similar in chemistry, received equivalent postweld heat treatments, and are all classified as P-3.

APR-7:

The SA-516 Gr. 70 base materials examined and the alternative SA-533 Gr. B Cl. I calibration block material are the same product form and have equivalent P-numbers for acoustic purposes per Section V of the 1974 Edition of the ASME Code.

As required by Section V, the calibration block was given a postweld heat treatment.

ALA-RV-1: The SA-508 C1. 2 alternative calibration block material and SA-533 Gr. B material examined are similar in chemistry, received equivalent postweld heat treatments and are both classified as P-3.

ALA-RV-3 and ALA-RV 5:

The SA-533 Gr. B C1. 2 material examined and the SA-508 C1. 2 alternative calibration block material are similar in chemistry, received equivalent postweld heat treatments and are both classified as P-3.

In each case, the parameters judged to be essential for acoustical compatibility were considered in the evaluatior.s.

The materials examined and the alternative calibration block materials were found to be similar enough to ensure acoustical compatibility.

From the standpoint of acoustics, attenuation characteristics and velocity are of the utmost concern in determining material compatibility.

The velocity and attenuation differences of the materials are immeasurable and are, for the most part, equivalent. Therefore, the existing calibration blocks are acceptable, based on acoustic compatibility.

To fabricate new Code-required calibration blocks would be j

impractical, if not impossible, due to availability of t

75 t

6 o

material and will not make a substantial improvement in the quality of the examinations. Obtaining the appropriate product form and material specification may require procurement of nozzle forgings, nozzle ring castings, tubesheet forgings, and other difficult-to-obtain product forms.

In summary, it is Alabama Power Company's judgement that the evaluations summarized above suitably demonstrate the acceptability of the alternative calibration block material requirements. While the Code requirements have not been explicitly met (and thus a relief request has been submitted),

the intent of the Code to ensure acoustic compatibility has been met.

Evaluation:

Evaluation of the calibration blocks by the Licensee has shown that the velocity and attenuation differences of the material are immeasurable and are, for the most part, equivalent.

While the Code requirements have not been explicitly met, the intent of the Code to ensure acoustic compatibility has been met.

All of the proposed calibration blocks have been in use since the plant was built; therefore, their continued use would provide consistent results.

Because procuring calibration blocks of the exact materials would be difficult, if not impossible, and because the velocity and attenuation characteristics of the materials are equivalent, the increase in plant safety would not compensate for the burden placed on the Licensee that would result from requiring the Licensee to fabricate new calibration blocks to meet the i

current Code. The Licensee has demonstrated that the proposed alternative provides an acceptable level of quality and safety and that compliance with the specific Code requirement would result in hardship or unusual difficulties without a l

compensating increase in the level of quality and safety.

l 76 l

N o

==

Conclusions:==

Based on the above, it is concluded that public health and safety will not be endangered by allowing the use of the alternative calibration blocks in lieu of the specific Code requirement. Therefore, pursuant to 10 CFR 50.55a(a)(3),

it is_ recommended that relief be granted as requested.

3.5.1.2 Reauest for Relief No. RR-2. Soecif}c Dimensional Reauirements for Calibration Blocks Code Reauirement: Section XI, Paragraph IWA-2232 requires that ultrasonic examination of vessel welds in ferritic materials greater than 2 inches in thickness be conducted in accordance with Article 4,Section V, 1983 Edition.

Figure T-434.1, Article 4, requires that the minimum distance from the ends of the 2-inch long 2% T notches to the edges of the block be 3 inches.

Licensee's Code Relief Recuest:

Relief is requested from notch location requirements for calibration blocks used to perform ultrasonic examination of the following:

ALA-RV-1:

Boron injection tank head-to-shell circumferential welds.

Reactor vessel lower head-to-lower shell weld and all lower head welds ALA-RV-3:

Reactor vessel top head welds ALA-RV-5:

Reactor vessel flange-to-shell weld and shell welds Licensee's Proposed Alternative Examination:

The Licensee states that the subject calibration blocks are in compliance with the clearance dimensions required for notches by Figure T-546.1, Article 5,Section V, 1983 Edition.

Licensee's Basis for Reauestino Relief: The Licensee states that Figure T-546.1, Article 5,Section V, 1983 Edition, is a similar calibration block; however, the clearance required from the ends of the 2% notches is 2 inches instead of the 77 3

N

' O 3 inches required by Figure T-434.1, Article:4.

Experience

- performing calibrations using these tilocks has proven fully satisfactory.

. Evaluation: All of the proposed calibration blocks-have been in' use since the plant ~ was built; therafore, their continued use would provide consistent results.

Because procuring-calibration blocks.of the exact materials would be difficult, if not impossible, _ and because the existing blocks have been proven satisfactory for performing calibrations, the increase t

in plant safety.would not compensate for-the burden placed on the Licensee that would result from requiring the Licensee to fabricate new calibration blocks to the current Code.

The Licensee has demonstrated that the proposed alternative provides an acceptable level of qu:lity and safety and that compliance with the specific Code. requirement would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.

==

Conclusions:==

Based on the above, it'is concluded that public health and safety will not.be endangered by allowing the use of the alternative calibration blocks in lieu of the specific Code-requirement.

Therefore, pursuant to 10 CFR 50.55a(a)(3),

it -is recommended that relief be granted as requested.

3.5.1.3 Reauest for Relief No. RR-3. Soecific Dimensional Reauirements fpr Calibration Blocks-

[ ode Reauirement:

Section XI, Paragraph IWA-2232 requires that ultrasonic examination of vessel welds in ferritic

. materials greater than 2 inches in thickness be conducted in accordance with Article-4,Section V, 1983 Edition.

Figure T-434.1 in Article 4 requires the aligned side-drilled holes

[

and notches _to _be_ located a minimum distance of T/2 from the 78

8 o

end of the block.

The_non-aligned holes are to be located a minimum of 1.5 inches from the end of the block.

Licensee's Code Relief Reay_eit:

Relief is requested from the hole location requirements for the following calibration blocks:

ALA-RV-1:

Reactor vessel lower head-to-lower shell weld, all lower head welds, and bor'on injection tank head circumferential welds, l

ALA-RV-5:

Reactor vessel flange-to-shell weld and shell welds APR-5:

Steam generator stub barrel-to upper tubesheet weld, lower shell-to-stub barrel weld, transition cone-to-lower shell weld, upper shell-to-transP.lon 4_

cone weld, and feedwater nozzle-to-epper shell weld.

APR-7:

Pressurizer top head-to-nozzle welds, top head-to-upper shell, upper-to-middle shell weld, lower-to-bottom head weld, all longitudinal shell welds, and bottom head-to-nozzle weld.

The aligned holes in ALA-RV-1 and ALA-RV-5 are 0.25 and 0.5 inches less than the required distance, respectively. The non-aligned holes on ALA-RV-1, APR 5, and APR-7 are 0.25, 0.625, and 0.625 inches less than the required distance, respectively.

Licensee's ProDosed Alternative Examination:

None.

The Licensee states that the calibration blocks are acceptable for use as is.

Licensee's Basis for Reauestino Relief: The Licensee states that experience performing calibrations using these blocks has f

proven fully satisfactory.

Evaluation:

All of the proposed calibration blocks have been in use since the plant was built; therefore, their continued

[

use would provide consistent results.

Because procuring calibration blocks of the exact materials would be difficult, 79

k

-I

~g j

if-not impossible, and bec6use the existing blocks have been proven satisfactory for performing calibrations, = the increase

-in plant safety would not~ compensate for.the burden placed on i

the Licensee that would result from requiring the' Licensee-to fabricate new calibration ~ blocks to meet the current' Code.

The Licensee has demonstrated that the proposed alternative provides an acceptable level of quality and safety and that compliance with the specific Code requirement would result in hardship or unusual difficulties without.a compensating increase in the level of quality and safety.-

j i

I conclusions:

Based on the above, it is concluded that public health and safety will not be endangered by allowing the use i

.of the alternative calibration blocks in lieu of the specific l

Code requirement. Therefo:e, pursuant to 10 CFR 50.55a(a)(3),

j it is recommended that relief be granted as requested.

[

i 3.5.1.4 Reauest for Relief No. RR-4. Wall Thickness Differences Between Calibration Blocks and Components to-be Examined Gnde Reauirementi Section XI, Appendix III, Paragraph f

111-3410 requires that the basic calibration-block be made from material of the same nominal wall thickness or pipe schedule as the pipe to be examined.

Licensee's Code Relief Reouest:

Relief is requested from the f

g.

wall thickness requirements for ~the following~ calibration blocks:

l L

ALA-5; Excess letdown heat exchanger AWRV-7:

Reactor coolant piping ALA 24:

M31n steam piping AL M E:

Feydwater piping i

ALA-31:

Volume control tank j

i The oeviations in ' wall thickness are indicited below:

l l

80 l

i l

-l

_.... _ =

l=(

.o

. WALL THICKNESS DEVIATIONS Cal. Block Cal Block-Pipe Diam.

Pipe Pipe Wall

' Number 1 Thick. fin.)' 1f32)

Sched.

Thick. fin.) Material ALA-5 _

0.906

- 8.0 160 0.750 Stainless i

ALA-RV-7 3.000 Flat N/A 2.0 to 3.0 CS/SS ALA-24 1.200 32.0 Special 1.033 -

Carbon.

-f Carbon.

ALA-25 0.750 16.0 100-1.031 ALA-31.

0.388 Flat N/A 0.250 Stainless Licensee's Proposed Alternative Examination:

ASME Code Case N-461, Alternate Rules for Piping Calibration Block

-Thickness, will be incorporated for use of the above calibration blocks with the following stipulations:

(a)- Ultrasonic (UT) thickness measurements and weld joint

. measurements of the pipe or component must be available to ~the~ UT inspector prior to performing the angle beam examination.

It is accepteble to use measurements from h previous inspection.

(b)' The 10-year ISI plan and current outage plan shall annotate components / calibration blocks which require thickness tolerances per ASME-Code Case N-461.

'(c) 'In' addition, all UT reflectors 50%. distance-amplitude correction (DAC) and above must also be recorded and-their position in the weld joint plotted to determine if the reflectors are relevant indications.

L Licensee's Basis for Reouestina Relief:

The-Licensee states that the existing calibration blocks used for piping and thir-wall vessels were designed under the provisions of Section V, 1974 Edition, Summer 1975. Thickness differences between the above calibration blocks and the components to be examined are inconsequential and would in most cases produce conservative examination results.

Fabrication of new l

l calibration blocks for the sole purpose of achieving exact 81

.-w..~.

,.,y,,,-,...y,.~.,,....

.m

o-thickness congruity with the component will not improve examination quality.

Calibration blocks ALA-5 and ALA-24 have a nominal thickness greater ;han the examined piping. Use of a thicker cGibrationblockisconservativesinceexaminationofa thinner component would tend to decrease ultrasoni.

attenuation. ASME Code Case N-461 allows the use of calibration blocks which are within plus or minus 25% of the component-thickness.

The ASME has approved this Code Case and the NRC is considering incorporation of N-461 into a future revision of NRC Regulatory Guide 1.147.

Calibration block ALA-25 has a nominal thickness less than the examined piping The reducer is schedule 100 with a nominal thickness of 1.031 inches; however,. in the area of interest, it is machined to a nominal thickness of 0.758 inch to match the steam generator nozzle thickness.

Therefore, use of _the 0.750-inch thick calibration block will provide a representative examination of the nozzle to reducer weld.

Again, application of ASME Code Case N-461, once NRC approval is obtained, would permit use of this calibration block.

Calibration blocks ALA-RV-7 and ALA-31 have a nominai thickness greater than the examined piping.

Use of a thicker calibration block is conservative since examination of a thinner component would tend to decrease ultrasonic attenuation.

Evaluation:

Pending final review and evalu. tion by the NRC staff of ASME Code Case N-461, it appears tt ; the code case will be approved in Revision 8 of NRC Regulatory Guide 1.147 for generic use with supplemental requirements; the supplemental requirements are listed as part of the Licensee's proposed alternative examination.

82

. ts :

fr l

. Use of' ASME Code. Case N 461 for calibration -blocks ALA-5, ALA 24, and ALA-25 is, therefore, -

ptable with the stipulations. listed in the Licensees proposed alternative 1

examination.

For calibration block ALA-31, the wall thickness of the calibration block is not within the range of 125% of l

the Volume Control Tank shell wall thickness to be examined.

j Therefore ASME-Code Case N-461 cannot be applied to

.l calibration block ALA-31.

~

Section XI,-Paragraph IWA-2232(c) allowsLthe use of Article 5.

-of'Section V-for the ultrasonic examination of piping made of i

other than ferritic materials. With regard to calibration l

block ALA-RV-7,-Section V,- Article 5, Figure T 546.1 ~ a110ws a calibration block thickness of 3-inches to be used for-l thicknesses between 2--and 4 inches.

Therefore, use of this 1

- calibration block is acceptable, f

With the exception of calibration block ALA-31, the Licensee has demonstrated that the-proposed alternative, with the above supplemental requirement, provides an acceptable level of quality and safety. and that compliance with the specific Code

]

- requirement would result-in hardship or unusual difficulties l

without-a-compensating increase in the level of quality and f

safety.

l f

==

Conclusions:==

- Based on the above, it is concluded that public

{

health and safety will not be endangered by allowing the

{

proposed alternative to be performed in lieu of the Code

_j requirements.

Therefore, for the calibration blocks listed except calibration block ALA-31, it is recommended that relief-

=be granted pursuant to 10 CFR 50.55a(a)(3).

For calibration l

block ALA-31, it is recommended that relief be denied.

[

t 83

[

li

~. --

o 3.5.1.5 Reouest for RelieLNo. RR-5. Curvature Differences Between Calibration Blocks and Components to be Examined f

Code Reauirement:

Section XI, Appendix 111, Paragraph 111-3410 requires that the basic calibration blocks be made from material of the same nominal diameter as the pipe to be examined.

9 Licensee's Code Relief Reauest:

Relief is lequesteo from the curvature requirements for the following calibratic' blocks used to perform ultrasonic examinations cn piping and thin-wall vessels:

ALA-5:

Excess letdown heat exchanger ALA-RV-7:

Reactor coolant piping ALA-21:

Pressurizer skirt ALA-23:

Main steam piping ALA-25:

Feedwater piping ALA-31:

Letdown heat exchanger; Volume control tank ALA-32:

Residual heat exchanger ALA/APR-33:

Reactor coolant piping The deviations in curvature are indicated below:

CURVATURE DEVIATIONS Cal. Block Cal. Block Component Component Number Diam. fin.)

Descriotion Diam. fin.) Material ALA-5 8

Thin-walled 9.5 Stainless vessel ALA-RV-7 Flat RPV nozzle 27.5, 29.0 CS/SS safe end ALA-21 Flat Press. skirt 87.00 Carbon ALA-23 Flat Pipe 34.55 Carbon ALA-25 14 Reducer 16 x 14 Carbon ALA-31 Flat Thin-walled 21.78 Stainless vessel ALA-31 Flat Thin-walled 84.00 Stainless vessel ALA-32 Flat Thin-walled 39.75 Stainless vessel ALA/APR-33 29 Pipe 27.5 Cast SS ALA/APR-33 29 Pipe 31.0 Cast SS 84

v Licensee's Proposed Alternative Examination:

The Licensee states that the existing calibration blocks for piping and thin-wall vessels are in compliance with the curvature tolerances between the blocks and the test part as reovired by Section V, 1983 Edition, Summer 1983 Addenda, Paragraph T-543.3.

Licensee's Basis for Reouestino Relief: The Licensee states that the design of the existing calibration blocks was based on the provisions of Section V, 1974 Edition, Summer 1975 Addenda.

Curvature differences between the above calibration blocks and the components to be examinad are inconsequential and would, in most cases, result in conservative examination results.

Fabrication of new calibration blocks, for the sole purpose of achieving exact curvature congruity with the component, will not, in Alabama Power Company's judgement, improve examination quality.

Calibration block ALA-25 differs in diameter from the 16-inch diameter reducer which connects the 14-inch diameter feodwater piping to the steam generator nozzle.

The calibration block is 14 inches in diameter and is used for examining the 16-inch diameter reducer to steam generator nozzle weld.

Calibration block ALA/APR-33 is used for examination of cast austenttic stainless steel reactor coolant loop piping materials in the hot, cold, and the crossover legs which have different diameters. The calibration block is the same nominal dirmeter as the hot leg but is of smaller diameter than the crossover leg piping and larger diameter than the cold leg piping.

Regardless of the differences in diameter, the NRC has reviewed and accepted the :pecial examination techniques which Alabama Power Company utilizes for reactor coolant loop examination as permitted by Section XI, Paragraph IWA-2240.

This review included an attenuation comparison of the calibration block and the coolant loop t

i 85

i w

(

piping.

It was concluded thkt the calibration block was f

representative of the installed piping and would therefore provide a conservative examination.

Calibratior, block ALA-5 was fabricated from 8-inch diameter stainless steel pipe and is utilized for examination of a 9.5 inch diameter cc:nponent.

Regardless, Alabama Power Company utilizes enhanced vitrasonic examination techniques on all atainless steel components.

This technique includes requirements that the refracted angle be recorded for each examined component.

In addition to the required 46' examination, a 60' examinetlon is also utilizeo and both are performed et increased sensitivity by adjusting tha gain to t.n average noise level of 10% of full screen height.

This j

enhanced examination technique more than adequately compensates for any mismatch between the calibration block and l

the examined component.

Calibration block ALA RV 7 is a flat plate fabricated from dissimilar metals and is used to examine the reactor pressure l

vessel nozzle safe end welds in 27.5 and 29.0 inch diameter piping. Calibration block ALA 21 is fabricated from carbon steel plate and it is used to exaaine the 87.0 inch diameter pressurizer skirt.

Calibration block ALA 23 is fabricated from carbon steel plate and it is used in examine 34.5 inch diameter piping.

Calibration blocks ALA 31 and ALA-32 are fabricated from stainless steel plate and are used to examine thin walled vessels ranging from 22 to 84 inches in nominal diameter. Use of these flat calibration blocks is considered acceptable based on guidanca from the ASME Code,Section V, Articles 4 and 5, which state that, for diameters greater than 20 inches, a block of essentially the same curvature or, alternately, a flat basic calibration block shall be used.

Given the large diameter of the components being examined, the flat calibration blocir is considered to be acceptable.

As discussed above, use of the enhanced ultrasonic examination 86

w a

technique more than adequately compensates for any mismatch between the calibration block and curvature of the examined component.

Evaluati2D:

Section XI Paragraphs IWA 2232(a) and (c) allow the use of Articles 4 and 5 of Section V, which allow for use of a block of essentially the same curvature or, alternatively, a flat block for cuminatient where the examination surface diameter is graattr than 20 inches.

Therefore, with regard to the curvature deviations, the use of the subject calibration blocks is acceptable.

The Licensee has demonstrated that the proposed alternative provides an accept.ible level of quality and safety and that compliance with the specific Code requirement would result in hardship or unusual difficulties without a compensating increase in the i

level of quality and safety.

==

Conclusions:==

Based on the above, it is concluded that public health and safety will not be endangered by allowing the use of the alternative calibration blocks in lieu of the specific Code requirement.

Therefore,pursuantto10CFR50.55a(a)(3),

it is recommended that relief be granted as requested.

3.5.1.6 Egouest for Relief No. kR 6. Materials for Fabrication of Calibration Blocks and Acoustic Comnatibility with the Component to be Examined Note:

Relief Request No. RR 6 was withdrawn by the Licensee l

in the December 7, 1989 submittal which states the following:

" Relief Request RR 6 pertains to calibration block l

materials for piping and thin-walled vessel examinations. After a substantial comparison of the calibration block and component materials and a review of the examination requirements of Section XI, Appendix III, Paragraph 111-3451 as clarified by ASME Code Interpretation XI-1 86 61, it was found that all calibration block materials are I

87

a.

in compliance, therefore, relief request RR 6 is not required and will be deleted from the 151 Program with the next revision."

3.5.1.7 Reauest for Relief No. RR-7. Dimensional Requirements for D11bration Notches Placed in Ultrasonic (_alibration Blocks Code Reauiremant:

Section XI, Appendix !!!,

Paragraph 111 3430 requires that basic calibration blocks conta notches that are at least 1.0 inch long and 0.104t 0.009t2 + 10%/-20% in depth.

Licensee's Code Relief Reauest:

Relief is requested from the dimensional requirements for calibration notches placed in ultrasonic calibration blocks ALA 21, ALA-23, ALA 26, and ALA-28.

Licensee's proposed Alternative Examination:

None.

The Licensee states that these piping calibration blocks are acceptable for use as is.

Licensee's Basis for Reauestina Relief:

The deviations in the calibration notch dimensions are as follows:

ALA-21:

The notch depth is at 2% and should be 10%.

ALA-23:

The notch depth is at 2% and should be 10%.

ALA 26:

The notch is 0.125 inch under the required length of 1.0 inches.

ALA 23:

The notch is 0.012 inch less than the 20% tolerance requirement for depth (the notch depth is at 6% and should be 10%).

The Licensee states that the only possible consequences of these discrepancies is that the sensitivity level of the ultrasonic instrumer' would be slightly higher than aquired, resulting in a more critical examination.

Correcting these conditions on any of the above blocks would not be prudent and would be of questionable value when considering possible damage to the blocks by subjecting them to additional machining.

88

a.

r I

t Evaluation: The undersize notches in the four subject

{

calibration blocks can only provide for a more sensitive j

examination.

The proposed calibration blocks have been in use j

since the plant was builti therefore, their continued use would provide consistent results.

The Licensee has demonstrated that the proposed alternative provides an acceptable level of quality and safety and that compliance with the specific Code requirentent would result in hardship or unusual difficulties without a compensating increase in the

[

1evel.of quality and safety.

l

==

Conclusions:==

Based on the above, it is concluded that the j

proposed alternatives meet or exceed the intent of the Code l

requirements and that public health and safety will not be endangered by allowing the alternative calibration blocks to be used in-lieu of the Code requirement.

Therefore, pursuant to II CFR 50.55a(a)(3), it is recommended that relief be grantel as requested.

3.5.2 Exemoted comoonents (Noreliefrequests) 3.5.3 Other 3.5.3.1-Reauest for Relief No. RR 12. Delete VT-4 Visual Examination i

Method and Examination Reauirement and Redefine VT-3 Visual Examination Method in Accordance With Paraoraoh IWA-2213 of-the 1986 Edition of the Code I

code Reauirement:

Section XI, Table IWF 2500-1. Examination Category F-C,-Item F3.50 requires a 100% VT-4 visual examination of spring type supports, constant load type f

supports, shock absorbers, and hydraulic and mechanical type snubbers as defined by figure IWF-1300 1.

l Licensee's Code Relief Reauest:

Relief fs requested from performing the Code required VT 4 visual examination of spring 89 i

i

,_ - _ x_._.._

type supports, constant load i/pe supports, shock absorbers, and hydraulic and mechanical type snubbers.

Licensee's Proposed Alternative Examinatign:

None.

The

-Licensee states that operability tests shall be performed in accordance with the Farley Technical Specifications.

Licensee's Basis for Recuestina Relief:

The Licensee states that operability testing was-inappropriately included in YT-4 as an examination method.

Also, Paragraph IWA 2214(b) of the 1983 Section XI' Code is inconsistent with industry visual examination practices._ An inspector does not perform bench testing.of snubbers / constant load / spring type supports.

These activities are performed by maintenance technicians.

The 1986 Edition of ASME Section X1 has deleted VT 4 examination altogether and has redefined VT-3 to include examinations for conditions that could affect operability or functional adequacy of snubbers, and constant load and spring type supports.

Evaluation:.The VT 3 and VT-4 visual examinations have been combined as the VT-3 visual examination in the later editions-of the Code (1986)-to-more clearly define the visual examination requirements.

The-VT-3 visual examination requirement in the-1986 Edition is equivalent to the Code requirements of the 1983 Edition, Summer 1983 Addenda and, therefore, is an acceptable alternative.

==

Conclusions:==

Based on the above evaluation, it is concluded that the_ proposed alternative examination is equivalent to the Code required examination and provides an acceptable level of quality.and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3), it is recommended that relief be granted as requested, f

90 L

• ~

n 3.5.3.2 Etquist for Relief No. RR 17. Reference System for All Weldt and Areas Subiect to Surface or Volumetric Examination i

Code Reauirement:

Section XI, Paragraph IWA 2610, ' Weld Reference System - General," requires that a reference system shall be established for all welds and areas subject to surface or volumetric examination.

Each su:h weld and area shall be located and idcntified by a system of reference points.

The system shall permit identification of each weld, location of each weld center line, and designation of regular intervals along the 14ng% 'f the nld.

Licensee's Crde Relief.M qs>.

Relief is requested from establishing a weld referere,e sastem for all welds a!,d areas subject to surface or voiumetric examination.

Licensee's Proposed Alternative Examination:

The Licensee states that administrative controls which are detailed in procedures provide adeouate instructions to ensure measurements are repeatable and ' hat any indications can be accurately located.

Licensee's Basis for Recuestino Relief:

The Licensee states that to perform actual marking of welds in order to identify each weld centerline, length locations, etc. would require many manhours of radiation exposure. Many of the welds are insulated and as such many manhours of radiation exposure would be required to remove and reinstall insulation just to facilitate marking.

Also, many manhours of radiation exposure would be involved in marking the welds.

Evaluation:

For an operating plant, establishing a weld reference system for all welds and ar'.as subject to surface or volumetric examination is a major effort and, in some cases, is prohibited due to inaccessibility and/or high radiation levels.

Therefore, the Code requirement for establishing a 91

r.

weld reference system for all welds subject to e', amination in the absence of examination is impractical for an coerating

plant, in order to establish a weld refe.*ence system for all wolds and areas subject to surface and volumetric examinations in accordance with the requirements, many manhours and man rems of radiation exposure would be required to perform such tasks cs locating the welds, removing insulation, marking the welds, and reinstalling insulation, regardless of whether or not the weld is scheduled for examination.

The increase in plant safety would not compensate for the burden placed on the t.icensee that would result from imposition of the requirement for all welds.

However, as inservice examinations of Class 1 and 2 piping systems are performed, each piping weld examined should receive the required reference markings.

Impracticality will not exist for these welds since access will have been provided to perform examinations.

==

Conclusions:==

The marking of all welds and areas subject to surface or volumetric examinations required by Section XI of the ASME Code in the absence of inspection is impractical at f arley, Unit 2, because it is an operating plant.

Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated by an increase in public health and safety.

However, as each Class 1 and 2 piping system is examined, access for marking each weld will be provided and impracticality for that particular weld will not exist. Therefore, in order to provide assurance of traceability of 112 piping welds and repeatability of examinations, it is recommended that relief be granted provided that each Class 1 and 2 piping weld examined receives the required reference markings as the inservice examinations are performed.

92

A.

3.5.3.3 Reouest for Relief No. RR-41. Break Away Drao Test for Hydraulic Snubbers 821g:

The functional testing of snubbers is not included in this evaluation.

Functional tests are not within the scope of this document and will be evaluated elsewhere.

3.5.3.4 Eggy.est for Re Ugf Ho. RR-42. Additional Samele Testino Reouirements for Snubbers 821g:

The functional testing of snubbers is not included in this evaluation.

Functional tests are not within the scope of this document and will be evaluated elsewhere.

E i

f 93 i

A o

4.

CONCLUSION Pursuant to 10 CFR 50.55a(g)(6) or, alternatively, 10 CFR 50.55a(a)(3), it has been determined that certain Section XI required inservice examinations j

cannot be performed to the extent required by the Code.

In all cases except Requests for Relief RR 4 (in part), RR-29, and RR-33 (in part), the Licensee l

has demonstrated that specific Section XI requirements are impractical or that alternative examinations should be performed.

It is recommended that relief be granted with conditions for Requests for Relief RR-15, RR-16, f

and RR-17.

For Requests for Relief RR-4, RR-29, and RR-33, it is concluded l

that:

(a) the Licensee has not provided information to support the determination that the Code requirement is impractical, and (b) requiring the Licensee to comply with the Code requirement would not result in i

hardship, Requests for Relief RR-6, RR-24, and RR 45 were withdrawn by the Licensee and deleted from the ISI Program Plan.

Requests for Relief RR-41 and RR-42 request relief from the functional testing requirements of IWF-5000 for snubbers.

The functional testing of snubbers is not included in this evaluation.

Functional tests are not within the scope of this document and will be evaluated elsewhere, i

l This technical evaluation has not identified any practical method by which l

the Licensee can meet all the specific inservice inspection requirements of Section XI of the ASME Code for the existing Joseph M. Farley Nuclear Power Plant, Unit 2, facility.

Requiring compliance with all the exact Section XI required inspections would require redesign of a significant number of plant systems, sufficient replacement components to be obtained, installation of f

the new components, and a baseline examination of these components.

Even after the redesign efforts, complete compliance with the Section XI i

5

(

li f s 1

e fr he e eme ts c are impractical to implement, or alternatively, pursuant to 10 CFR 50.55a(a)(3),

alternatives to the Code-required examinations may be granted provided that l

either (i) the alternative proposed provides an acceptable level of quality l

and safety or the (ii) Code compliance would result in hardship or unusual difficulty without a compensating increase in safety.

Relief may granted l

only if granting the relief will not endanger life or property or the common 94

s.

n.

defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Therefore, it is concluded that the public interest is not served by imposing certain provisions of Section XI of the ASME Code ti.at have been determined to be impractical.

The development of new or improved examination techniques should continue to be monitored.

As improvements in these areas are. achieved, the Licensee should incorporate these techniques in the ISI program plan examination requirements.

Based on the review of the Joseph H. Farley Nuclear Power Plant, Unit 2, Second 10 Year Interval ISI Program, through Revision 1, the Licensee's responses to the NRC request for additional information, and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Joseph M. Farley Nuclear Power Plant, Unit 2, Second 10 Year Interval ISI Progrtm, through Revision 1, is considered unacceptable and not in compliance with 10 CFR 50.55a(g)(4) due to an unacceptable examination sample and unacceptable application of the exclusion criteria (see Sections 2.2.2 and 2.2.3 of this report).

It is recommended that relief be granted with conditions for Requests for Relief RR 15, RR-16, and RR-17.

For Requests for Relief RR-4 (in part), RR 29, and RR-33 (in part), it is recommended that relief be denied.

Requests for Relief RR 6, RR-24, RR-41, RR-42, and RR-45 either have been withdrawn or are not included in the scope of this document.

i 95

6 5.

REFERENCES 1.

Code of Federal Regulations, Volume 10, Part 50.

2.

American Society of Mechanical Engineers Boiler and Pressure Yessel Code,Section XI, Division 1:

1983 Edition through Summer 1983 Addenda 1974 Edition through Summer 1975 Addenda 3.

Letter, dated August 31, 1990, E. A. Reeves (NRC) to W. G.

Hairston, Ill (APCo), exemption which permitted revision of the Unit 2 ISI Program to coincide with the Code of record and updated schedule currently used for Unit 1.

4.

Joseph H. Farley Nuclear Power Plant, Unit 2. Second 10-Year f rterval Inservice Inspection Program, Revision 0, submitted March 23, 1989.

5.

NUREG 0800, Standard Review Plans, Section 5.2.4, " Reactor Coolant Boundary Inservice Inspection and Testing," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components," July 1981.

6.

Letter, dated August 3, 1989 E. A. Reeves (NRC) to W. G. Hairston (Alabama Power Company (APCo)], request for additional information on the Second 10 Year Interval ISI Program.

7.

Letter, dated October 5, 1989, W. G. Hairston, 111 (APCo) to NRC, response to the NRC request for additional information.

8.

Letter, dated December 7, 1989, W. G. Hairston, 111 (APCo) to NRC, response to the NRC request for additional information.

9.

Letter, dated April 12, 1990, W. G. Hairston, III (APCo) to NRC, additional information with regard to the 151 Program.

10.

Letter, dated August 15, 1990, W. G. Hairston, 111 (APCo) to NRC, Revision 1 to the ISI Program, 11.

Letter, dated September 12, 1990 W. G. Hairston, !!! (APCo) to NRC, corrections to Revision 1 of relief requests RR-1, RR-2, and RR-3.

12.

Letter, dated June 1, 1988, A. R. Herdt (NRC) to R. P. Mcdonald (APCo),

j j

NRC Inspection Report Nos. 50-348/88-17 and 50-364/88-17.

13.

Letter, dated June 22, 1988, W. G. Hairston, Ill (APCo) to NRC, request for exemption from requirements of 10 CFR 50.55a(g)(4)(ii).

14.

Letter, dated August 31, 1988, S. A. Varga (NRC) to W. G. Hairston, 111 (APCo), exemption from certain requirements of 10 CFR 50.55a(g)(4)(ii).

15.

Letter, dated December 16, 1988 W. G. Hairston, 111 (APCo) to NRC, updated ISI program for ASME Code Class 1, 2, and 3 components.

96 i

4.)

e JL 16.

Letter, dated February 8, 1989 W. G. Hairston, !!! (APCo) to NRC, list of relief requests for Unit 2 refueling outage.

17.

Letter, dated March 23, 1989 W. G. Hairston, 111 (APCo) to NRC, updated inservice inspection program for ASME Code Class 1, 2, and 3 components.

18.

Letter, dated March 31, 1989 E. A. Reeves (NRC) to R. P. Mcdonald (APCo), interim approval of ISI Program for Unit 2.

19.

Letter, dated June 8, 1989, W. G. Hairston, 111 (APCo) to NRC, updated inservice inspection program for ASME Code Class 1, 2, and 3 components.

20.

Letter, dated September 21, 1989, W. G. Hairston, !!! (APCo) to NRC, schedule extension for submittal of response to the NRC request for additicaal information.

21.

Letter, dated November 30, 1989, W. G. Hairston, 111 (APCo) to NRC, response to the NRC request for additional information.

22.

NRC Regulatory Guide 1.150, " Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations," Revision 1, February 1983.

23.

NRC Regulatory Guide 1.14, ' Reactor Coolant Pump Flywheel Integrity,"

Revision 1, August 1975.

24.

NRC Regulatory Guide 1.83, ' Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes,' dated July 1975, 25.

NRC Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 7 July 1989.

97

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,s nwwe, owe,,mo,

a. rat: 4~os a m 6' EGG MS 8944 Technical Evaluation Report on the Second 10 Year Interval inservice inspection Progra'n Plan:

a cariaircave.%,5.ia Alabama Power Company, November j 19~90 e '-

Joseph H. Farley Nuclear Power Plant Unit 2, Docket Number 50 364

.,~oaca.~twveia flN 06022 (Proj. 5) t i wac%

,tvrio, necar l

Technical i

B.W. Brown, J.D. Mudlin o s a ico co v i a d,,......

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EG&G Idaho, Inc.

P. O. Box 1625 Idaho Falls, ID 83415 2209 e vogag casa a v ios savi *~o ano a isi u,..c.,, u..

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Materials and Chemical Engineering Branch i

Offt:e of Nucioar Reactor Regulation U.S. Nuclear Regulatory Commission i

Washington, D.C.

20555

10. $UPPLIMINI AR Y ~orl$

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l This report presents the results of the evaluation of the Joseph H. Farley Nuclear Power Plant, Unit 2, Second 10 Year Interval Inservice inspection (ISI) Program, through Revision 1, submitted August 15, 1990, including the requests for relief from the American Society of Mechanical Engineers (ASME) Boller and Pressure Vessel l

Code Section XI requirements which the Licensee has determined to be impractical.

l The Joseph M. Farley Nuclear Power Plant, Unit 2, Second 10 Year Interval 151 l

Program is evaluated in Section 2 of this report, The ISI Program is evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability i

of examination sample,, (c) correctness of the application of system or component 4

examination exclusion criteria, and (d) comp'liance with ISI-related commitments identified during the previous Nuclear Regulatory Commission reviews.

The requests for relief are evaluated in Section 3 of this report.

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