ML20082Q243

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Rev to 830301 & 0826 Preservice Insp Program Plans
ML20082Q243
Person / Time
Site: Byron Constellation icon.png
Issue date: 12/06/1983
From:
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20082Q238 List:
References
PROC-831206, NUDOCS 8312120080
Download: ML20082Q243 (39)


Text

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Note 4 R v. 1 '

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NOTE 4 System: All J

Number of Items: All ,

ASME Code Class: 1,2, and 3 Pertinent Code Requirements: Examination Categories B-K-2, C-E, D-A, D-B, and D-C all require visual examinations (VT-3 and VT-4) of component supports.

Category B-K-2 requires examination of all Class I component supports. C-E requires examination of Class 2 components supports on piping greater than 4.00 inches. D-A, D-B, D-C all require examination of Class 3 component

. supports on piping greater than 4.00 inches.

Description of Examination: For all required visual examinations (VT-3 and VT-4) though not limited to visual examinations, shop an.d field examinations will be used to satisfy IWB-2200(b) and IWC-2200(b) for Class 1 and 2 respectively. Although subsection IWD does not address shop and field examinations, it is the intent of Byron Station to treat Class 3 components in I a manner similar to Class 1 and 2 components. An inspection program based l upon shop examinations, construction QC inspections, pre-operational testing, i and augmented inspections will be used in lieu of a preservice examination program based solely on section XI.

There are several programs which apply to component support examinations conducted at Byron Station during the Pre-Service phase. These programs are executed by various Commonwealth Edison Company (CECO) departments and are j overseen by respective departments and inspectors in the NRC. For this reason, this note will not provide a detailed discussion of all programs -

covering component support examinations, but rather, give an overview of the programs involved.

CECO Project Construction Department (PCD) is responsible for the proper installation of component supports. To accomplish this, they administer a five part inspection program. This program meetsSection III, Subsection NF requirements and incorporates augmented requirements addressed during inspections by the NRC Region III inspector.

The five part PCD program requires examination at the time of support installation, and four re-examinations to be performed at various stages of construction. This program includes but is not limited to, verification of proper support type, location, weld condition, attaching hardware, etc. For cperable supports such as spring cans and snubbers, the proper cold settings are verified. Further, all snubbers are stroked at the time of installation, and selected snubbers are stroked again before core load. The final phases of the five part program verify that all design changes have been incorporated and that components are in good condition and have not baen damaged as a result of construction activities.

f (0219M) s 8312120080 831206

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, , Noto 4 ,

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,- o In addition to the requirements of the PCD examinations, there are augmented requirements. These requirements are the result of licensing activities between NRR and CECO Project Engineering Department (PED). These requirements are described in detail in the Byron FSAR and in Byron's "Preservice Testing Program Plan for Snubbers." Among the testing /inspe ion act,1vities described in the FSAR is Thermal Expansion Testing performed during Integrated Hot Functionals. These activities were performed through the execution of the EM 2.028.10. Pre-Operational Test, Revision 3. This test has been revised as a result of inspection activities performed at the site by I & E Region II inspectors under Region III authority. The scope of the test is described by FSAR Q110.63 and Q110.37. The pre-operational test verified that (1) there was no evidence of damage during plant heatup and cooldown to installed component supports and snubbers, (2) there was no evidence of inoperability of operable type supports. that there was not interference from thermal expansion and that supports and snubbers were installed properly. In addition, PCD monitored movement of the RCS piping, Steam Generators, and Reactor Coolant Pumps during Integrated Hot Functional Testing. The "Preservice Inspection Testing Program Plan for Snubbers" describes the interrelationship between visual inspections and pre-operational testing as related to snubbers.

In short, the five part PCD examinations, which have been developed through on-site NRC inspections, are used to satisfy the visual examination requirements of ASME Section XI for pre-service inspections. In addition to this, augmented tests and examinations are performed to assure proper design, installation, and operability of component and piping supports.

O e (0219M)

  • NotO 5

,' Rov. 1 -

NOTE 5 System: Reactor Coolant Pumps Number of Itemt: 4(1RC01PA, IRC01PB, IRC01PC, and IRC01PD) ,

l ASME Code Class: 1 Pertinent Code Reouirements: Examination Category B-L-1, B-M-1 Pressure Retaining Welds in Pump Casings and Velve Bodies, Item 812.10 requires a i.

volumetric and surface examination of the regions described in Figure IWS-2500-16. Examination Category B-L-2, B-M-2 Pump Casings and Valve Bodies, Item B12.20 requires a visual examination of the internal surfaces.

Subarticle IWB-2200 requires completion of all examinations required by its Article, once, prior to initial plant Startup.

Description of Examination: The above listed pumps are of the integrally cast type and therefore have no pump casing welds. All internal surfaces, received liquid penetrant tests performed by the manufa:turer. This exceeds the Section X1 requirements for visual examination.

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(0219".)

- . Noto 10 Riv121on 1 -

,. i NOTE 10 LIMITED ULTRASONIC EXAMINATIONS DUE TO GEOMETRIC CONFIGURATION SYSTEM: Reactor Coolant, Prescurizer, Safety Injection.  ;

NUMBER OF ITEMS: 23 Geometric System Line Weld Configuration Reactor Coolant IRC04AA-12" J1 Elbow to Sweepolet

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Reactor Coolant IRC04AB-12" J1 Elbow to Sweepolet Reactor Coolant IRC05AB-6" J3 Elbow to Sweepolet Reactor Coolant IRC21AA-8" J1 Elbow to Sweepolet Reactor Coolant IRC21AB-8" J1 Elbow to Sweepolet Reactor Coolant IRC21AB-8" J2 Elbow to Elbow Reactor Coolant IRC21AC-8" J2 Elbow to Elbow 1

Reactor Coolant IRC21AD-8" J1 Elbow to Sweepolet l Reactor Coolant IRC24AD-4" _ J1 Elbow to Sweepolet Reactor Coolant IRC35AA-6" J1 Elbow to Sweepolet

. Reactor Coolant IRC35AB-6" J3 Elbow to Sweepolet Pressurizer 1RY01AA-4" J9 Elbow to Reducer Pressurizer 1RY01B-6" J1 Tee to Reducer Pressurizer 1RY01C-4" J1 Mozzle to Reducer i Pressurizer 1RYO2A-6" J1 Elbow to Nozzle i

! Pressurizer 1RYO2A-6" JS Tee to Reducer i Pressurizer 1Ry03BA-6" J2 Elbow to Flange Pressurizer 1RYO3BB-6" J2 Elbow to Flange l

Safety Injection ISIA4B-8" J25 Reducer to Valve

,i I Safety Injection ISIO4D-8" J20 Reducer to Valve Safety Injection ISIO9BC-10" J12 Elbow to Tee Safety Injection ISIO9BC-10" J15 Elbow to Valve Safety Injection ISIO9BD-10" J17 Elbow to Elbow (0225M)

. Note 10 Rivisitn 1 -

A.S.M.E. CODE CLASS: 1 Pertinent Code Requirements: Examination Category B-J. Item B9.ll requires a surface and volumetric examination of the volume described in figure IWB-2500-8. The volumetric examination performed during the-inspection interval shall cover all the area of 25% of the circumferential joints. The examination includes at least z. pipe diameter length, but no more than 12 inches of each longitudinal weld intersecting the circumferential welds required to be examined.

IWB-2200 states, " Examinations required by this article shall be completed prior to initial plant startup. In addition. these preservice examinations shall be extended to include essentially 100% of the pressure retaining welds i in class 1 components, except in those components exempted from examination by l IWB-1220."

Description of Examination: The circumfere'ntial welds listed above received essentially 10]\ volumetric examination. The examination consisted of a circumferential scan for transverse reflectors in both directions and an axial scan for parallel reflectors from one side only with a full V-path inspection. However, the axial scan from one side only could not guarantee complete coverage of the required volume due to the geometric configuration of the weld.

(0225M)

. Noto 12

. R1 vision 1 -

NOTE 12 LIMITED ULTRASONIC EXAMINATION DUE TO GEOMETRIC CONFIGURATION SYSTEM: Feedwater, Main Steam, Safety Injection l NUMBER OF ITEMS: 29 Geometric System Line Weld Configuration Feedwater 1FWO3DA-16" C24 Elbow to Nozzle Feedwater IEWO3DC-16" C28 Elbow to Elbow Feedwater IFWO3DC-16" C29 Elbow to Nozzle Feedwater IFWO3DD-16" C28 Elbow to Nozzle Feedwater 1FW81AA-6" C9 Elbow to Valve Feedwater IFW81AA-6" C12 Reducer to Valve Feedwater 1FW81AA-6" Cl3 Reducer to Valve Feedwater IFW81AB-6" C9 Elbow to Valve Feedwater IFW81AB-6" C12 Reducer to Valve i

Feedwater 1FW81AB-6" C13 Reducer to Valve I

Feedwater 1FW81AC-6" C9 Elbow to Valve

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Feedwater 1FW81AC-6" C12 Reducer to Valve Feedwater 1FW81AC-6" Cl3 Reducer to Valve Feedwater 1FW81AD-6" C9 Elbow to Valve Feedwater lW81AD-6" C12 Reducer to Valve Feedwater 1FWSIAD-6" C13 Reducer to Valve Main Steam 1MS01AA-30.25" Cl Elbow to Nozzle Main Steam IMS01AB-32.75" Cl Elbow to Nozzle Main Steam 1MS01AD-32.75" C1 Elbow to Nozzle Main Steam IMs01AD-30.25" Cl Elbow to Nozzle (0226M)

Noto 12 Revision 1 Geometric System Line Weld Configuration Safety Injection ISIO6BA-24" C23 Elbow to Reducer Safety Injection ISIO6BA-24" C24 Reducer to Valve Safety Injection ISIO6BB-24" C32 Elbow to Reducer Safety Injection ISIO6BB-24" C33 Reducer to Valve l

Safety Injection ISIO5CB-8" C24 Elbow to Elbow Safety Injection ISIOSCB-8" C26 Elbow to Elbow Safety Injection ISIOSCB-8" C34 Elbow to Elbow Shfety Injection ISIO5CB-8" C39 Elbow to Elbow Safety Injection ISIOSCB-8" C47 Reducer to Valve A.S.M.E. CODE CLASS: 2 PERTINENT CODE REQUIREMENTS:

Examination Category C-F, Item C5.21 requires a surface and volumetric examination of the volume described in figure IWC-2500-7. The volumetric examination performed during the inspection interval shall cover all of the area of the circumferential joints per figure IWC-2500-7 requirements.

IWC-2200 states, "?.11 examinations required by this Article for those components initially selected for examination in accordance with Inspection Program A or Inspection Program B and not exempt from inservice examinations by IWC-1220 shall be completed prior to initial plant startup."

DESCRIPTION OF EXAMINATION The circumferential welds listed above received essentially 100% volumetric examination. The examination consisted of a circumferential scan for transverse reflectors in both directions, and an axial scan for parallel reflectors from one side only with a full V-path inspection. However, the axial scan from one side only could not guarantee complete coverage of the required volume due to the geometric configuration of the weld.

(0226M)

_ _ _ _ _ _ - _ _ _ _ _ _ _ . _ _ _ _ _ I

NR-5

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RE1.IEF REQUEST NR-5

1. System: Safety Injection
2. Number of Items: 5 Confiquration Line Number Weld Number ISIO4B - 12" C-14 Tee-to-Reducer ISIOSCA - 8" C-48 Reducer -to-Valve ISIOSCC - 8" C-3 Reducer-to-Elbow ISIOSCC - 8" C-4 Raducer-to-Valve ISIOSCD - 8" C-5 Reducer-to-Valve
3. ASME Code Class: 2
4. ASME Section XI Requirements: Table IWB-2500-1 Examination Category C-F, Item C5.21 requires surface and volumetric examination of the regions described in Figure IWC-2500 *1 for piping welds over 0.50" nominal wall thickness. In addition, Examination Category C-H . Item C7.20 requires a 2 system leakage test, IWC-5221, each inspection period for all pressure retaining components.

Article IWC-2200, "Preservice Examination" states that:

a. All examinations required by this Article for those components initially selected for examination in accordance with Inspection Program A or Inspection Program B and not exempted from inservice examinations by IWC-1220 shall be completed prior to initial plant startup.
b. Shop and field examinations may serve in lieu of the on-site preservice examinations, provided:

I 1). in the case of vessels only, the hydrostatic test required by Section III has been completed:

2). such examinations are conducted under conditions and with

( equipment and techniques equivalent to those which are expected to be employed for subsequent inservice -

examinations; 3). the shop and field examination records are or can be documented and identified in a form consistent with those

required in IWA-6000.

! (0219M)

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. . NR-5 R:v. 0 .

III. Article III-4000 require examination for:

a. Reflectors parallel to the weld seam.

The angle beam examination for reflectors parallel to the weld seam shall be performed by a full V-path from'one side or a one-half V-path from two sides of the weld, where practicable.

b. Reflectors transverse to the weld seam.

1). The angle beam examination for reflectors transverse to the weld seam shall be performed on the weld crown on a single scan path to examine the weld root by one-half V-path in two directions along the weld.

2). For inservice examination, only those welds showing repottable preservice indications need to be examined for

. transverse reflectors.

5. Basis for Relief: The above listed welds are of the component-to-component type. We have completed acceptable radiography and liquid penetrant tests to meet the preservice volumetric and surface examination requirements.

In addition an ultrasonic inspection in the circumferential direction for reflectors transverse to the weld was also performed. However, the axial scan for parallel reflectors could not be performed from either side due to the geometrical configuration of the components. Also, the Section III hydrostatic test was performed without any reportable indications.

6. Alternate Test Method: A 0* calibrated L-wave was also performed as an alternate to the axial scan.

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7. Justification: In performing the limited ultrasonic inspection along with the additional calibrated L-wave and the surface and leak tests, all with no reportable indications, an acceptable level of structural integrity can be assured for these welds.

(0219M)

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NOTE 7 R:v. 0 NOTE 7 System: All Class 1, 2, and 3 Number of Items: All Class 1, 2, and 3 ASME Code Class: 1, 2, and 3 Pertinent Code Requirements: Table IWB-2500-1, Examination Cucegory B-P, Table IWC-2500-1, Examination Category C-H, and Table IWD-2500-1 all require system pressure tests per IWA-5000 " System Pressure Tests". Though Subarticles IWB-2200 IWC-2200, and IWD-2100 require completion of all examinations required by their respective Articles, once prior to initial plant startup, paragraph IWA-5215 states, "A preservice system hydrostatic test is not required by this Section".

Description of Examination: All ASME Class 1, 2, and 3 pressure retaining components will be hydrostaticly tested per the requirements of ASME Section III prior to fuel load. Per IWA-5215, system pressure tests will not be re-executed prior to initial plant startup, except for ASME Class I components which will receive a section XI leakage test during start-up and before initial criticality. ASME Class 2 and 3 inservice leakage tests will begin during startup and continue for the first inspection period until all tests are completed.

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(0219M)

NOTE 8 Revision 0 NOTE 8 System: Steam Generator (Main Steam Nozzles)

Number of Items: 4 Component Number Nozzle Number Attachment Number 1RC01BA SGN-3 1 1RC01BB SGN-3 1 1RC01BC SGN-3 1 1RC01BD SGN-3 1 ASME Code Class: 2 Pertinent Code Requirements: Examination Category C-B, Item C2.20 requires surface and volumetric examination of the volume described in Figure IWC-2520-4. Figure IWC-2520-4 shows a volumetric inspection of the nozzle inner radii. In addition, Examination Category C-H, Item C7.10 requires a visual examination (VT-2) on all pressure vessel pressure retaining components.

Description of Examination: The main steam nozzles contain an internal multiple venturi type flow restrictor having an equivalent throat diameter of 16 in., which is designed to limit the flow in the event of a postulated steam line break. This design does not utilize a radiused nozzle as described in Figure IWC-2520-4 and therefore is not considered subject to inner radii inspection by IWC-2520-4. It is considered subject to all other requirements of ASME Section III and Section XI and therefore, will receive the hydrostatic tests and leakage tests as required by ASME Section III and Section X respectively.

(0219M)

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NOTE 11 Rev. 1 NOTE 11 System: Chemical and Volume Control, Excess Letdown Heat Exchanger: Safety Injection Piping.

Number of Items: 2 Component Number Weld Number *% Missed Attachment Number ICV 01AA ELHXC-02 3% 1 ISIO5CB-8" C-17 9.73% 2

  • Note: In all cases above, the percent missed is a conservative estimate as shown on Attachment 3.

ASME Code Class: 2 Pertinent Code Requirements:

VESSEL REQUIREMENT Examination Category C-A, Item C1.10 requires volumetric examination of the regions described in Figure IWC-2520-1 for vessel shell circumferential welds.

Note (1) from Examination Category C-A states, "... essentially 100% of the weld length." shall be examined.

PIPING REQUIREMENT Examination Category C-F, Item C5.21 requires surface and volumetric examination of the regions described in Figure IWC-2520-7 for circumferential welds in piping over 1/2 in, nominal well thickness.

PRESERVICE REQUIREMENT Subarticle IWC-2200 requires completion of all examinations required by its Article, once, prior to initial plant startup.

Description of Examination: Welds ELHXC-02 and C-17 were examined with radiography to meet the Section III requirements. In addition, both welds received 100% ultrasonic examination for reflectors transverse to the weld seam. Weld ELHXC-02 was examined axially for reflectors parallel to the weld seam for approximately 97% of the weld length. There is a 3/4 in, drain connection on the bottom of the shell which prevented complete ultrasonic examination. Weld C-17 was examined axially for reflectors parallel to the weld seam for approximately 90% of the weld length. There is a pipe which runs perpendicular to ISIO5CB-8" at weld C-17 which obstructed the examination. In addition, weld C-17 received the surface examination required by Item C5.21.

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(0219M) i

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.. 1 RELIEF REQUEST NR-6

1. SISTEM: Reactor Coolant
2. NUMBER OF ITEMS: 36 Cast Stainless Steel SA-351-CF8A (Elbow) to Stainless Steel SA-376 Type 304N (Pipe)

Line Number Weld Numbers Attachments Numbers 1RC02AA-31" J-1, J-2, J-3, J-7 1&2 1RC02AB-31" J-1, J-2, J-3, J-7 1&2 1RC02AC-31" J-1, J-2, J-3, J-7 1&2 1RC02AD-31" . J-1, J-2, J-3, J-7 1&2 1RC03AA-27.5" J-10 1&2 1RC03AB-27.5" J-9 1&2 1RC03AC-27.5" J-ll 1&2 1RC03AD-27.5" J-9 1&2 Cast Stainless Steel SA-351-CF8 (Pump) to Stainless Steel SA-376 Type 304N (Pipe)

Line Number Weld Numbers Attachment Numbers IRC03AA-27.5 J-l 1&3 1RC03AB-27.5 J-l 1&3 1RC03AC-27.5 J-l 1&3 1RC03AD-27.5 J-l 1&3 Cast Stainless Steel SA-351-CF8M (Valve) to Stainless Steel SA-376 Type 304N (Pipe) .

Line Number Weld Number Attachment Number IRC01AA-29" J-3 1&4 1RC01AB-29" J-3 1&4 1RC01AC-29" '

J-3 1&4 1RC01AD-29" J-4 1&4 1RC03AA-27.5" J-4, J-5 1&4 1RC03AB-27.5" J-4, J-5 1&4 1RC03AC-27.5" J-4, J-5 1&4 1RC03AD-27.5 J-3, J-4 1&4

3. ASME CODE CLASS: 1 (0219M)

. NR-6 Revision 0 -

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4. 7.SME CODE SECTION XI REQUIREMENTS: Table IWB-2500-1. Examination Category B-J. Items B9.11 and B9.12 require surface and volumetric examination of the regions described in Figure IWB-2500-8 for piping 4'in, nominal pipe size and greater. In addition. Examination Category B-P, Item B15.50 requires a system leakage test, IWB-5221, each refueling outage for all pressure retaining components.

Article IWB-2200, "Preservice Examination" states that:

a. Examinations required by this Article shall be completed prior to initial plant startup. In addition, the preservice examination shall-be extended to include essentially 100% of the pressure retaining "

welds in all Class I components except in those components exempted from examination by IWB-1220 (a), (b), or (c).

b. Shop and field examinations may serve in lieu of on-site preservice examinations provided:
1) In the case of vessels only, the examination is performed after the hydrostatic test required by Section III has been completed:
2) such examinations are conducted under conditions and with equipment and techniques equivalent to those that are expected to be employed for subsequent inservice inspections:
3) the shop and field examination records are, or can be, documented and identified in a form consistent with those required in IWA-6000.

Ultrasonic examination requirements from Mandatory Appendix III, Article 111-4000 require examination for:

a. Reflectors parallel to the weld seam.

The angle beam examination for reflectors parallel to the weld seam shall be performed by a full V-path from one side or a one-half V-path from two sides of the weld, where practicable. *

b. Reflectors transverse to the weld seam

! 1) The angle beam examination for reflectors transverse to the weld

. seam shall be performed on the weld crown on a single scan path i to examine the weld root by one-half V path in two direction i along the weld, l

2) For inservice examination, only those welds showing reportable preservice indications need be examined for transverse 4eflectors.

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I l (0219M)

NR-6 RIvision 0 '

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5. BASIS FOR RELIEF: The welds listed above are all cast austenitic stainless steel to stainless steel pipe. We have completed acceptable radiographic and surface examinations to meet the preservice volumetric and surface requirements. In addition, ultrasonic examinations were performed circumferential1y in both directions for transverse reflectors, and axially from the pipe side for parallel reflectors with a one-half V-path scan. Neither the circumferential nor the axial scan located any rejectable indications. The one-half V-path scan from the casting side of the weld could not be performed due to the poor acoustic properties of the cast austenitic stainless steel.

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6. ALTERNATE TEST METHOD: None
7. JUSTIFICATION: A high level of structural integrity has been assured for the noted welds over the life of the plant by;
a. Having performed an acceptable one-sided ultrasonic examination:
b. Having performed acceptable radiographic and surface examinations: and
c. Having the leakage detection system described in NR-3.

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NR-ll Rev. O REl.IEF REQUEST NR-ll

1. SYSTEM: Chemical and Volume Control, Letdown Heat Exchanger
2. NUMBER OF ITEMS: 1 Component Number Weld Number Attachment Number

. 1CV04AA LHXC-01 1

3. ASME CODE CLASS: 2
4. ASME CODE SECTION XI REQUIREMENTS: Table IWC-2500-1 Examination Category C-A,~ Item C1.10 requires a volumetric examination of the regions described in Figure IWC-2520-1 for shell circumferential welds. In addition, Examination Category C-H, Item C7.10 requires a system leakage test in accordance with IWC-5221 each inspection period for pressure vessel pressure retaining components.

Subarticle IWC-2200, "Preservice Examination," states that:

a. All examinations required by this Article for those components initially selected for examination in accordance with Inspection Program A or Inspection Program B and not exempted by IWC-1220 shall be completed prior to initial plant startup.
b. Shop and field examinations may serve in lieu of on-site preservice examinations, provided:

1), in the case of vessels only, the hydrostatic test required by Section III has been completed:

2). such examinations are conducted under conditions and with equipment and techniques equivalent to those which are expected to be employed for subsequent inservice examinations:

3). the shop and field examination records are or can be documented and identified in a form consistent with those required in IWA-6000.

Mandatory Appendix III, Article III - 4000 requires examination for:

a. Reflectors parallel to the weld seam.

The angle beam examination for reflectors parallel to weld seam shall be performed by a full V path from one side or a one-half V path from  ;

two sides of the weld, where practicable.

(0219M) l

NR-ll Rev. O

b. Reflectors transverse to the weld seam.

1). The angle beam examination for reflectors transverse to the weld seam shall be performed on the weld crown on a single scan path to examine the weld root by one-half V path in two directions along the weld. 5 2). For inservice examination, only those welds showing reportable preservice indications need be examined for transverse

. reflectors.

5. BASIS FOR RELIEF:

The above listed weld was inspected volumetrically by the radicgraphic method to meet the ASME Section III requirements. In addition, an ASME Section XI volumetric inspection was performed in the axial direction for reflectors parallel to the weld seam. The circumferential scan for reflectors transverse to the weld seam could not be performed due to the flange bolting extending over the weld crown. The ASME Section III radiographs could be used to meet the preservice examination requirements except it is not our intent to use radiography inservice.

6. ALTERNATE TEST METHODS: In lieu of the required ultrasonic examination for reflectors transverse to the weld seam, a surface examination by the liquid penetrant method will be performed.
7. JUSTIFICATION: Per ASME Section III, radiography and hydrostatic tests have been completed on this weld. Por ASME Section XI, an ultrasonic inspection for reflectors parallel to the weld seam and an alternate surface examination have been completed. Based upon the results of the above examinations, an adequate level of structural integrity exists for plant operations.

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NR-12 Rev. O RELIEF REQUEST NR-12

l. SYSTEM: Chemical and Volume Control, Excess Letdown Heat Exchanger
2. NUMBER OF ITEMS: 1 Component Number Weld Number Attachment Number

. 1CV01AA ELHXC-03 1&2

-3. ASME CODE CLASS: 2

4. ASME CODE SECTION XI REQUIREMENTS: Table IWC-2500-1. Examination Category C-A, Items C1.10 and C1.20 requite volumetric examination of the regions described in Figure IWC-2520-1 for shell and head circumferential welds.

In addition Examination Category C-H, Item C7.10 requires a system

leakage test in accordance with IWC-5221 for pressure vessel pressure retaining components.

Subarticle IWC-2200, "Preservice Examination," states that:

a. All examinations required by this Article for those components initially selected for examination in accordance with Inspection Program A or Inspection Program B and not exempted by IWC-1220 shall be completed prior to initial plant startup,
b. Shop and field examinations may serve in lieu of on-site preservice

. examinations, provided:

i 1). in the case of vessels only, the hydrostatic test required by i

Section III has been completed:

L 2). such examinations are conducted under conditions and with l equipment and techaiques equivalent to those expected to be employed for. subsequent inservice examinations:

l 3). the shop and field examination records are or can be documented and identified in a form consistent with those required by

! IWA-6000.

1 Mandatory Appendix III, Article III - 4000 requires examination for:

3. a. Reflectors parallel to the weld seam.

The angle beam examination for reflectors parallel to the weld seam shall be performed by a full V path from one side or a one-half V path from two sides of the weld, where practicable.

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, (0219M) t L

NR-12 Rev. O

b. Reflectors transverse to the weld seam.

1). The angle beam examination for reflectors transverse to the weld seam shall be performed on the weld crown on a single seam path to examine the weld root by one-half V path in two directions along the weld.

2). For inservice examination, only those welds showing reportable preservice indications need be examined for transverse

, reflectors.

5. BASIS FOR RELIEF: Weld ELHXC-03 received radiographic examination to meet the requirements of ASME Section III. These examinations could be used to meet the requirements of ASME Section XI. However, we do not intend to use radiography as our inservice test method.

Ultrasonic examination of weld ELHXC-03 was limited for approximately 70%

of the weld length due to four branch connections welded to the vessel.

6. ALTERNATE TEST METHOD: In lieu of the required ultrasonic inspection a surface examination utilizing the liquid penetrant test will be performed on the above welds.
7. JUSTIFICATION: The ASME Section III radiograph and hydrostatic test along with the limited ultrasonic examination and alternate surface examination will provide an adequate level of structural integrity for plant operation.

(0219M)

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NR-13 Rev. 0 1

I RELIEF REQUEST NR-13 i

1. SYSTEM: Pressurizer Vessel and Steam Generator Vessel (Primary Side)
2. NUMBER OF ITEMS: 14 Component Number Weld Numbers a

1RC01BA Primary Nozzles (2)

'lRC01BB Primary Nozzles (2) 1RC01BC Primary Nozzles (2) 1RC01BD Primary Nozzles (2) 1RY0lS PN-1, PN-2, PN-3, PN-4, PN-5, PN-6

3. ASME CODE CLASS: 1
4. ASME CODE SECTION XI REQUIREMENTS: Table IWB-2500-1. Examination Category B-D, Items B3.120 and B3.140 requite volumetric examination of the regions described in Figure IWB-2500-7 for the inner radius of full penetration welded nozzles in the pressurizer and steam generators (primary side) respectfully. In addition, Examination Category B-P, Items B15.20 and B15.30 require a system leakage test, IW3-5221, each refueling outage for pressure retaining component in the pressurizer and steam generators respectively.-

Subarticle IWB-2200, "Preservice Examination" states that:

a. Examinations required by this Article shall be completed prior to

, initial plant startup. In addition, these preservice examinations j shall be extended to include essentially 100% of the pressure retaining welds in all Class 1 Components, except in those components l exempted from examination by IWB-1220 (a), (b) and (c). However, in l the case of Examination Category B-O (Table IWB-2500-1), the examination shall be extended to include essentially 100% of the welds'in the installed peripheral control rod drive housings only.

5. BASIS FOR RELIEF: The nozzles listed above all contain inherent geometric constraints and clad inner surfaces which linit the ability to perform meaningful volumetric examinations. In an attempt to develop a technique l to locate flaws in the nozzle inner radii area, a mock-up was used with little success. The only notch which was detectable was the deepest one which penetrated the cladding and extended to a depth of approximately 5/16" into the carbon steel.

l (0219M)

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NR-13 Rev. 0

6. ALTERNATE TEST METHOD: The steam generator primary side nozzles were surface tested using the liquid penetrant method. The nozzle was examined up to a ring welded to the inner radii which is used to hold down the nozzle cover during steam generator channel head work. All pressure i retaining components were hydrostatic 1y tested to the requirements of ASME l Section III prior to plant startup. When a viable alternative test method I is developed to inspect this area of a nozzle it will be considered.
7. JUSTIFICATION: In performing the alternate inspection on the steam

} . generators and the hydrostatic test on all pressure retaining components, an adequate level of structural integrity is assured for plant operation.

(0219M)

NR-14 Rev. O RELIEF REQUEST NR-14

( l. SYSTEM: Steam Generator Vessel (Secondary Side) Nozzles l

2. NUMBER OF ITFM_S: 8 Component Number Nozzle Number

. IRC01BA SGN-2 1RC01BB SGN-2 1RC01BC SGN-2 1RC01BD SGN-2

3. ASME CODE CLA53: 2
4. ASME CODE SECTION XI REQUIREMENTS: Table IWC-2500-1, Examination Category, C-B Item C2.20 requires surface and volumetric examination of the regions described in Figure IWC-2500-4 for nozzles in vessels over

-1/2 in in nominal thickness. Figure IWC-2500-4 requires volumetric examination of the inner radii on nozzles over 12 in. nominal pipe size.

In addition. Examination Category C-H, Item C7.10 requires a system leakage test, IWC-5221, each inspection period for all pressure vessel pressute retaining components.

Subarticle IWC-2200 "preservice Inspection" states that:

a. All examinations required by this Article for those components initially selected for examination in accordance with Inspection Program A or Inspection program B and not exempted from inservice examination by IWC-1220 shall be completed prior to initial plant startup.
5. BASIS FOR RELIEF: The nozzles listed above contain inherent geometric constraints which limit the ability to perform meaningful ultrasonic examinations. In an attempt to develop a technique to locate flaws in the nozzle inner radii area, a mockup was used with little success. The only notch which was detectable was the deepest one which penetrated the cladding and extended to a depth of approximately 5/16 in. into the carbon steel. .Although the nozzles listed above are not internally clad, it was determined that this mockup was representative of the required inspection.

(0219M) l

NR-14 Rev. 0

6. ALTERNATE TEST METHOD: Inservice visual examinations will be performed to the extent practical using remote techniques whenever the secondary side of the generator is opened for maintenance. Preservice inspection is limited to the ASME Section III radiograph of the nozzle to vessel weld and the hydrostatic test.
7. JUSTIFICATION: In performing the ASME Section III inspections and the inservice visual examination, an adequate level of structural integrity is assured for plant operation.

(0219M)

NR-15 Rev. O RELIEF REQUEST NR-15 5

1. SYSTEM: Containment Spray, Chemical and Volume Control, Residual Heat Removal
2. NUMBER OF ITEMS: 8 Component Number Weld Numbers Attachment Number ICS0lPA CSPE-01, CSPE-02, &

CSPE-03 1 1CY0lPA CVPE-01, CVPE-04 2 1RH0lPA RHPE-01, RHPE-02, &

RHPE-03 3

3. ASME CODE CLASS: 2
4. ASME CODE SECTION XI REQUIREMENTS: Table IWC-2500-1. Examination Category C-C and C-E, Item C3.70 requires surface examination of the regions described in Figure IWC-2520-5 for integrally welded attachments to pumps.

Subarticle IWC-2200, "Preservice Examination," states that:

a. All examinations required by this Article for those components initially selected for examination.in accordance with Inspection Program A or Inspection Program B and not exempted by IWC-1220 shall be conducted prior to initial plant startup.
b. Shop and field examinations may serve in lieu of on-site preservice examinations, provided:

1). in the case of vessels only, the hydrostatic test required by Section III has been completed:

2). such examinations are conducted under conditions and with equipment and techniques equivalent to those which are expected to be employed for subsequent inservice examinations:

3). the shop and field examination records are or can be documented and identified in a form consistent with those required in IWA-6000.

(0219M)

NR-15 Rev. 0

5. BASIS FOR RELIEF: The above listed welds connect the support lugs to the pump casings. These integtally welded attachments were examined by the manufacturers using a surface examination technique. The preservice examination was performed on three sides of each attachment, but the fourth side could not be inspected due to the structural support members being installed.
6. ALTERMATE TEST METHOD: The manufacturers surface examination results will serve as the alternate test method preservice. Inservice, a visual examination (VT-1), will be utilized for the inaccessable portions of these welds.

NOTE: The Containment Spray (CS) System is exempted from examination by IWC-1220 but was included in the preservice inspection program plan. Inservice examinations will not be conducted on this pump.

7. JUSTIFICATION: In using the manufacturers examination results and the partial preservice examination results, an adequate level of structural integrity is assured for plant operation.

(0219M).

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