ML20084F457

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Forwards Remaining Relief Requests Identified in Plant First ten-yr ISI Interval for Snp Units 1 & 2
ML20084F457
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 05/26/1995
From: Shell R
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9506020200
Download: ML20084F457 (48)


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HM Tennessee Valley Ashorny. Post OtSce Box 2000 Soddy Da<sy Tennessee 37379 May 26,1995 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SON) - IN-SERVICE INSPECTION (ISI) PROGRAM RELIEF REQUESTS TO CLOSE-OUT THE FIRST 10-YEAR ISI INTERVAL

Reference:

NRC letter to TVA dated April 15,1994, "First 10-Year Interval Inservice Inspection Program, Sequoyah Nuclear Plant, Units 1 and 2 (TAC Nos. M84707 and M84708)

The purpose of this letter is to submit the remaining rel:ef requests that were identified in SON's first 10-year ISIinterval for both units. The subject relief requests deal with limitations for examining American Society of Mechanical Engineers Class 1 and 2 welds. Weld examination is limited due to design configuration and location of the components.

SON's ISI program (through Revisions 20 for Unit 1 and 19 for Unit 2) were previously evaluated and found acceptable by NRC in the referenced letter. Enclosed are new relief requests that were identified subsequent to the reference letter (i.e., during the Cycle 6 refueling outages for both units). These relief requests comprise the final items to close-out SON's first 10-year ISIinterval. The relief requests are submitted in accordance with 10 CFR 50.55a(g)(5)(iii). TVA requests that NRC provide approvalin accordance with 10 CFR 50.55a(g)(6(i). NRC response is requested before the end of the first 10-year ISIinterval for both units. The current schedule for the end of this intervalis December 15,1995.

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U.S. Nuclear Regulatory Commission Page 2 May 26,1995 Please direct questions concerning this issue to D. V. Goodin at (615) 843-7734.

Sincerely, s Y, R. H. Shell Manager SON Site Licensing Enclosure cc (Enclosure):

Mr. D. E. LaBarge, Project Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission Region il 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711

ENCLOSURE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 REQUEST FOR RELIEF FIRST 10-YEAR INTERVAL i

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P REQUEST FOR RELIEF 1-1S1-19 Components: Pressure-Retaining Welds in Piping Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWB-2500-1 Code Category: B-J Code item Number: 89.11 Code Requirement: 100 percent volumetric and surface examination of 4-inch nominal pipe size (NPS) and greater circumferential pipe welds.

Impractical Requirement: To achieve 100 percent ultrasonic examination of 4-inch NPS and greater circumferential pipe welds.

Basis for Relief: The ultrasonic examination of the piping welds are limited due to physical configuration and cast stainless steel material. The limitations are noted on the ultrasonic examination data sheet and Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed a surface examination on essentially 100 percent of the weld and an ultrasonic examination on the accessible area of these welds.

Justification: The physical configuration at structural discontinuities (elbow to nozzle, elbow to pipe, pump to elbow, etc.) may create scan limitations preventing 100 percent code examination volume coverage.

In addition the reactor coolant main loop piping is fabricated of cast j stainless steel with a nominal wall thickness ranging from 2.69 inches nominal wall (NW) for cold leg, 2.84 inches NW for hot leg, and 2.99 inches NW for the crossover leg. Current ultrasonic capabilities {

are not sufficient to examine cast stainless materials of this thickness. t Due to the physical configuration and material type, these piping welds (

were ultrasonically examined, but unable to achieve essentially 100 percent code coverage.

Conclusion:

Based on the above justification,it is concluded that the code requirement for piping welds listed on Attachment A of this request for relief is impractical. TVA's examinations provide an acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

REQUEST FOR REllEF 1-151-1 9 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RC-02 29" B-J Cast CHM-2333-B Elbow to S/G No Scan From 25% No Scan Due Stainless Nozzle Nozzle To S/G Steel Nozzle Config.

RC-10 29' B-J Cast CHM-2333-B SIG Noz Safe No Scan From 25% No Scan Due Stainless End To Bbow Nozzle To S/G Steel Nozzle Config.

RC-11 31' B-J Cast CHM-2333-B S/G Noz Safe No Scan From 14% No Scan Due Stainless End To Bbow Nozzle To S/G Steel Nozzle Config.

RC-12 31" B-J Cast CHM-2333-B Bbow Elbow 81 % CCSS Materiai Stainless To Pipe Configuration Difficult to Steel Examine RC-18 29" B-J Cast CHM-2333-B S/G Noz Safe No Scan From 25% No Scan Due Stainless End to Nozzle To S/G Steel Elbow Nozzle Config.

RC-22 31" B-J Cast CHM-2333-B RC Pump No Scan From 80% No Scan Due Stainless To Bbow RC Pump To Reactor Steel Coolant Pump RC-23 27.5" B-J Cast CHM-2333-B RC Pump No Scan From 75% No Scan Due Stainless To pipe RC Pump To Reactor Steel Coolant Pump

4 REQUEST FOR RELIEF 1 ISI-20 Components: Pressure-Retaining Welds in Piping Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWB-2500-1 Code Category: B-J Code Item Number: B9.31 Code Requirement: 100 percent volumetric and surface examination of branch connection welds greater than 2-inch NPS.

Impractical Requirement: To achieve 100 percent ultrasonic examination of piping branch connection welds greater than 2-inch NPS.

Basis for Relief: The ultrasonic examination of the branch connection welds are limited due to design configuration (i.e. the branch connection being " set on" the reactor coolant main loop piping), also the reactor coolant main loop piping is cast material. The limitations are noted on the ultrasonic examination data sheet and Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed a surface examination on essentially 100 percent of the weld and an ultrasonic examination on accessible areas of these welds.

Justification: The configuration of the branch connection being set on the reactor coolant main loop piping fabricated of thick wall cast materialis not amenable to ultrasonic examination. Due to the branch connection configuration and material type, current ultrasonic examination techniques are not sufficient to achieve essentially 100 percent code coverage of these branch connection piping welds.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the branch connection piping welds greater than 2-inch NPS listed on Attachment A of this request for relief is impractical.

TVA's examinations provide an acceptable level of quality and safety.

Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

d REQUEST FOR RELIEF 1-ISI-20 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS CVCW-3 3* B-J Stainless CHM-2335-C 3* SCH 160 Scan From 85% Limited Due To Steel SH 2 Branch Conn. One Side Configuration

  • Set on RxML Only And Cast 31" ID Pipe" Material RCW-01 3" B-J Stainless CHM-2333-B 3* Sch 160 Scan From 50% Limited Due To Steel SH 3 Branch Conn Ore Side Configuration

" Set on RxML Only And Cast 31* ID Pipe

  • Material RCW-22 14" B-J Stainless CGN-2333-B 14" Sch 160 Scan From 50 % Limited Due To Steel SH-1 Branch Conn One Side Configuration

" Set on RxML Only And Cast 29" ID Pipe" Material SIW-05 6" B-J Stainless CHM-2333-C 6* Sch 160 Scan From 25"6 Limited Due To Steel SH 7 Branch Conn One Side Configuration

  • Set on RxML Only And Cast 29" ID Pipe" Material RHRW-02 6" B-J Stainless CHM-2336-C 6" Sch 160 Scan From 80 % Limited Due To Steel SH 6 Branch Conn One Side Configuration

" Set on RxML Only And Cast 27.5" ID Pipe" Material RCW-14 4" B-J Stainless ISI-0369-C 4" Sch 120 Scan From 75% Limited Due To Steel SH 2 Branch Conn One Side Configuration

  • Set on RxML Only And Cast 27.5" ID Pipe" Material SIW-08 10" B-J Stainless CHM-2333-C 10" Sch 140 Scan From 75% Limited Due to Steel SH 9 Branch Conn One Side Configuration

" Set on RxML Only And Cast 27.5"lD Pipe" Material NOTE: RxML - REACTOR COOLANT MAIN LOOP PIPE W

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% l REQUEST FOR RELIEF 1-fSI-21 l

Component: Pressurizer Full Penetration Welds of Nozzles in Vessels Class: ASME Code Class 1 (Equivalent) l l

1 Section XI Edition: 1977 Edition Summer 1978 Addenda  !

Code Table: IWB-2500-1 Code Category: B-D Code item Number: B3.110 Code Requirement 100 percent volumetric examination of pressurizer nozzle-to-vessel full penetration welds.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the pressurizer nozzle-to-vessel welds. -

Basis for Relief: The ultrasonic examination of the pressurizer nozzle-to-vessel welds are limited due to configuration of the pressurizer nozzle. The limitations are noted on the ultrasonic examination data sheet and on Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed an ultrasonic examination on accessible areas of the nozzle-to-vessel welds from the vessel head side of the weld, Justification: The configuration of the pressurizer nozzle to head prevent ultrasonic scanning techniques from the nozzle side of the pressurizer nozzle to vessel weld.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the pressurizer nozzle-to-vessel welds listed on Attachment A of this request for relief is impractical. TVA's ultrasonic examination provides an acceptable level of quality and safety.

Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

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REQUEST FOR RELIEF 1-ISI-21 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RCW-15 4" B-D Carbon ISI-0394-C 4" PZR Spray No Scan From 50 % No Scan Due Steel Nozzle To Nozzle Side To Nozzle &

Vessel Top Head Pressurizer Configuration RCW-16 6" B-D Carbon ISI-0394-C 6* PZR Safety No Scan From 50% No Scan Due Steel Nozzle To Nozzle Side To Nozzle &

Vessel Top Head Pressurizer Configuration RCW-17 6" B-D Carbon ISI-0394-C 6" PZR Relief No Scan From 50 % No Scan Due Steet Nozzle To Nozzle Side To Nozzle &

Vessel Top Head Pressurizer Configuration RCW-18 6" B-D Carbon ISI-0394-C 6* PZR Safety No Scan From 50 % No Scan Due Steel Nozzle To Nozzle Side To Nozzle &

Vessel Top Head Pressurizer Configuration RCW-19 6" B-D Carbon ISI-0394-C 6" PZR Safety No Scan From 50 % No Scan Due Steel Nozzle To Nozzle Side To Nozzle &

Vessel Top Head Pressurizer Configuration RCW-21 14" B-D Carbon ISI-0394-C 14" PZR Surge No Scan From 50 % No Scan Due Steet Nozzle To Nozzle Side To Nozzle &

Vessel Bottom Head Pressurizer Configuration m -

m REQUEST FOR RELIEF 1-ISI-22 Components: Pressurizer and Steam Generator (S/G) Pressure Retaining Dissimilar Metal Welds Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWB-2500-1 Code Category: B-F Code item Number: B5.20 and B5.30 Code Requirements: 100 percent volumetric and surface examination of pressure retaining dissimilar metal welds.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the pressurizer and S/G nozzle-to safe end welds.

Basis for Relief: The ultrasonic examination of the pressurizer nozzle-to-safe end welds and the S/G nozzle-to-safe end welds are limited due to the design configuration and cast stainless material. Due to the design configuration, no ultrasonic examination was performed from the nozzle side on each weld. Additionallimitations were noted on the S/G safe end due to the cast stainless material. The limitations are noted on the ultrasonic examination data sheet and Attachment A of ,

this request for relief.

Proposed Alternative Examination: TVA performed a surf ace examination on essentially 100 percent of the weld and an ultrasonic examination on accessible areas of the pressurizer and S/G nozzle-to-safe end welds.

Justification: The design configuration of the pressurizer and S/G nozzle-to-safe end weld and the cast stainless materiallimit the ultrasonic examinations.

No ultrasonic examination was perforrned from the nozzle side of each weld and a limited ultrasonic examination was performed on the S/G safe ends due to cast stainless material.

Conclusion:

Based on the above justification,it is concluded that the code requirements for pressurizer and S/G nozzle to-safe end welds listed on Attachment A of this request for relief is impractical. TVA's examinations provide an acceptable level of quality and safety.

Therefore. pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

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I i REGUEST FOR RELIEF 1-ISI-22 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE Z CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RC-02-SE 29" B-F Stainless ISI-0399-C S/G Nozzle No Scan From 25% No Scan Due Steel Safe End Nozzle And To Nozzle Cast Material Configuration RC-03-SE 31* B-F Stainless ISI-0399-C S/G Nozzle No Scan Frorn 25% No Scan Due Stect Safe End Nozzle And To Nozzle Cast Material Configuration RC-10-SE 29" B-F Stainless ISI-0399-C S/G Nozzle No Scan From 22 % No Scan Due Steel Safe End Nozzle And To Nozzle Cast Material Configuration RC-11-SE 31* B-F Stainless T-0399-C S/G Nozzle No Scan From 15% No Scan Due Steel Safe End Nozzle And to Nozzle Cast Material Configuration RC-18-SE 29" B-F Stainless ISI-0399-C S/G Nozzle No Scan From 25% No Scan Due Steel Safe End Nozzle And To Nozzle Cast Material Configuration RC-19-SE 31* B-F Stainless ISI-0399-C S/G Nozzle No Scan From 25% No Scan Due Steel Safe End Nozzle And To Nozzle Cast Material Configuration RC-26-SE 29" B-F Stainless ISI-0399-C S/G Nozzle No Scan From 17% No Scan Due Steel Safe End Nozzle And To Nozzle Cast Material Configuration RC-27-SE 31* B-F Stainless ISI-0399-C S/G Nozzle No Scan From 12% No Scan Due Steel Safe End Nozzle And To Nozzle Cast Material Configuration RCW-24-SE 4- B-F Stainless / ISI-0394-C 4* PZR Spray No Scan 50 % No Scan Due Carbon Steel Nozzle Safe From Nozzle To Nozzle End Configuration

1 REOUEST FOR REllEF 1-ISI-22

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(CONTINUED)

ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RCW- 27-SE t," B-F Stainless / ISI-0394-C 6" PZR Safety No Scan 75% Na Scan Due Carbon Steel Nozzle Safe From Nozzle To Nozzle End Configuration RCW-28-SE 6* B-F Stainless / ISI-0394-C 6* PZR Safety No Scan 75% No Scan Due Carbon Steel Nozzle Safe From Nozzle To Nozzle End Configuration RCW-29-SE 14" B-F Stainless / ISI-0394-C 14" PZR Surge No Scan 75% No Scan Due Carbon Steel Nozzle Safe From Nozzle To Nozzle End Configuration L---- __ __

REQUEST FOR RELIEF 1-ISI-23 Component: S/G and Centrifugal Charging Pump Tar.k (CCPT) Pressure-Retaining Nozzle Welds in Vessels Class: ASME Code Class 2 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWC-2500-1 Code Category: C-B Code item Number: C2.20 Code Requirement: 100 percent surface and volumetric examination of nozzles in vessels over 1/2-inch nominal thickness.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the S/G and centrifugal charging pump tank nozzle-to-vessel welds.

Basis For Relief: The ultrasonic examination of the S/G and centrifugal charging pump tank nozzle-to-vessel welds are limited due to the design configuration.

No ultrasonic examination was performed from the nozzle side on each weld. The limitations are noted on the ultrasonic examination data sheets and on Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed a surf ace examination on essentially 100 percent of the weld and an ultrasonic examination on accessible areas of the S/G and centrifugal charging pump tank nozzle-to-vessel welds.

Justification: The configuration of the S/G and centrifugal charging pump tank nozzle-to-vessel welds prevents ultrasonic scanning techniques from the nozzle side of each weld.

Conclusion:

Based on the above justification,it is concluded that for the S/G and centrifugal charging pump tank nozzle-to-vessel welds listed on Attachment A of this request for relief, the code requirements are impractical. TVA's examinations provide an acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

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REQUEST FOR RELIEF 1-1S1-23 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM

IDENTIFIER SIZE CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS FDW-1 16" C-B Carbon ISI-0399-C 16* Nozzle To No Scan From 75% No Scan Due Steel Vessel (Shet!) Nozzle Side To Nozzle S/G Configuration FDW-2 16" C-B Carbon ISI-0399-C 16" Nozzle To No Scan From 75% No Scan Due Steel Vessel (Shell) Nozzle Side To Nozzie S/G Configuration FDW-3 16" C-B Carbon ISI-0399-C 16" Nozzle To No Scan From 75% No Scan Due Steel Vessel (Shell) Nozzle Side To Nozzle S/G Configuration FDW-4 16" C-B Carbon ISI-0399-C 16" Nozzle To No Scan From 75% No Scan Due Steel Vessel (Shell) Nozzle Side To Nozzle S/G Configuration l

l MSW-1 32" C-B Carbon ISI-0399-C 32" Nozzle To No Scan From 75% No Scan Due l Steel Vessel (Shell) Nozzle Side To Nozzle I S/G Configuration l MSW-2 32" C-B Carbon ISI-0399-C 32" Nozzle To No Scan From 75% No Scan Due Steel Vessel (Shell) Nozzle Side To Nozzle i S/G Configuration MSW-3 32" C-B Carbon ISI-0399-C 32* Nozzle To No Scan From 75% No Scan Due l Steel Vessel (Shell) Nozzle Side To Nozzle S/G Configuration l

MSW-4 32" C-B Carbon ISI-0399-C 32" Nozzle To No Scan From 75% No Scan Due Steel Vessel (Shell) Nozzle Side To Nozzle S/G Configuration BIT-2 6" C-B Carbon ISI-OO69-A 6" CCP Tank No Scan From 75% No Scan Due Steel with Nozzle To Nozzle Side To Nozzle Stainless Cladding Vessel (Head) Configuration BIT-5 6" C-B Carbon ISI-OO69-A 6* CCP Tank No Scan From 75% No Scan Due Steel With Nozzle To Nozzle Side To Nozzle Stainless Cladding Vessel (Head) Configuration

0-REQUEST FOR RELIEF 1-1S1-24 Component: Residual Heat Removal (RHR) Heat Exchanger (Two per Unit)

Class: ASME Code Class 2 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWC-2500-1 Code Category C-A Code item Number C1.20 Code Requirement: 100 percent volumetric examination of pressure retaining welds in pressure vessels.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the RHR heat exchanger head-to-shell circumferental welds.

Basis for Relief: Each RHR heat exchanger consists of an inlet-outlet head chamber with one inlet and one outlet nozzle, two integrally attached support brackets, and e circumferential vessel head-to-shell weld. The design configuration of the head, nozzles, and support brackets restricts examination of the head-to-shell weld. The vessel head-to-shell weld is 113 inches in length. The weld examinations are distributed in three segments, identified as: RHRW-17-A-1,37 inches: RHRW-17-A-2, 38 inches; and RHRW-17-A-3,38 inches. RHRW-17-A-1 was ultrasonically examined in the first inspection period. RHRW-17-A-2 >

was examined in the second period. RHRW-17-A-3 was examined l during the third period. Based on the examinations performed, 80 percent examination volume coverage of the RHR heat exchanger I l

circumferential head-to-shell weld was achieved. These limitations are noted on the ultrasonic examination data sheet and on Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed an ultrasonic examination on the accessible areas on one head to-shell circumferential weld on one RHR heat exchanger to achieve maximum code coverage with meaningful results.

Justification: The design configuration of the RHR heat exchanger (head, nozzles, and support brackets) restrict ultrasonic examination of the

. head-to-shell circumferential weld.

Conclusion:

Based on the above information,it is concluded that the code requirement for the RHR heat exchanger head-to-shell circumferential weld listed on Attachment A of this request for relief is impractical.

TVA's examinations provide an acceptable level of quality and safety.

Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that

! relief be granted.

REQUEST FOR REllEF 1-ISI-24 ATTACHMENT A WELD WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER LENGTH CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RHRW A-1 37" C-A Stainless CHM-2404-A RHR Heat Scan Restriction 80% Ultrasonic Scan Restrictions Steel Exch. Due To Head, Due To Configuration Of Head-To Nozzles And Head, Nozzles, And Shell Support Brackets Support Brackets RHRW-17-A-2 38" C-A Stainless CHM-2404-A RHR Heat Scan Restriction 80 % Ultrasonic Scan Restrictions Steel Exch. Due To Due To Configuration Of Head-To Head Nozzles And Head, Nozzles, And Shell Support Brackets Support Brackets RHRW-17-A-3 38" C-A Stainless CHM-2404-A RHR Heat Scan Restriction 80% Ultrasonic Scan Restrictions Steel Exch. Due To Due To Conhguration Of Head-To Head, Nozzles And Head, Nozzles, And Shell Support Brackets Support Brackets

4 4

REQUEST FOR RELIEF 1-1S1-25 ,

l Component: Reactor Vessel Welds l Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWB-2500-1 Code Category: B-A Code item Number: B1.11 Code Requirement: 100 percent volumetric examination of pressure retaining welds in the reactor vessel.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the reactor vessel bottom-head to lower-shell circumferential weld, WO2-03.

Basic For Relief: The ultrasonic examination of the reactor vessel bottom-head to lower-shell circumferential weld (WO2-03)is limited due to the design configuration, (i.e., location of the reactor vessel core support lugs).

The limitations are noted on the ultrasonic examination data sheets and on Attachment A of this request for relief.

Proposed Alternative Examination: TVA utilized 0 *,45 *,60 *,50*/70

  • scans oriented clockwise, counterclockwise, up and down of the bottom-head to lower-shell weld to achieve 290 percent code examination coverage for reflectors oriented parallel to the weld and 67 percent code examination coverage for reflectors oriented transverse to the weld.

Justification: The design configuration of the reactor vessel bottom-head to lower-shell weld limits ultrasonic examinations due 17 the location of the core support lugs. TVA performed ultrasonic examinations on the accessible areas of the weld.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the reactor vessel bottom-head to lower-shell circumferential weld listed on Attachment A of this request for relief is impractical. TVA's examinations provide an acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

REQUEST FOR RELIEF 1-ISI-25 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER CATEGORY NUMBER CONFIGURATION COVERAGE WO2-03 B-A CHM-2343-B Bottom Head 190% Code Coverage for Reflectors To Lower Shell Oriented Para!!el to the Weld.

Circumferential Weld 67% Code Coverage for Reflectors Oriented Transverse to the Weld.

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REQUEST FOR RELIEF 1-ISI-26 r

Component: Reactor Vessel Weld  !

Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda  !

Code Table: IWB-2500-1 Code Category: B-A Code item Nubmer: B1.30  ;

Code Requirement: 100 percent volumetric examination of pressure retaining welds in the reactor vessel.

impractical l Requirement: To achieve 100 percent ultrasonic examination of the reactor vessel shell to flange weld, WO6-07.

Basis for Relief: The ultrasonic examination of the reactcr vessel upper shell to flange weld, (WO6-07)is limited due to the design configuration. The upper shell to flange weld has limitations on the shell side due to the reactor vessel nozzle locations and on the flange side due to the keyway location. The limitations are noted on the ultrasonic examination data sheets and Attachment A of this request for relief.

Proposed I

Alternative Examination: TVA utilized 0 * , 4 5 * , 60 * , 5 0 * /7 0

  • scar.s oriented clockwise, counterclockwise, up and down of the upper shell to flange weld, to achieve 85 percent code examination coverage for reflectors oriented parallel to the weld and 65 percent code examination coverage for reflectors oriented transverse to the weld.

Justification: The design configuration of the reactor vessel upper shell to flange weld limits ultrasonic examination due to the location of the keyways <

and nozzles.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the reactor vessel upper shell to flange weld listed on Attachment A of this request for relief is impractical. TVA's examinations provide an acceptabale level of quality and safety.

Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

j

REQUEST FOR RELIEF 1-ISI-26 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER CATEGORY NUMBER CONFIGURATION COVERAGE WO6-07 B-A CHM-2343-B Upper Shell 85% Code Coverage for Reflectors To Flange Oriented Parallel to the Weld.

65% Code Coverage for Reflectors Oriented Transverse to the Weld.

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

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REQUEST FOR RELIEF 11S127 )

Component: Reactor Vessel Outlet Nozzle Welds Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWB-2500-1  !

I Code Category: B-D Code Item Nubmer: B3.90 I l

Code Requirement: 100 percent volumetric examination of full penetration welds of -)

nozzics in the vessels. ]

Impractical Requirement: To achieve 100 percent ultrasonic examination of the reactor vessel outlet nozzle to vessel welds, N-15, N-16, N-17, and N-18.

Basis for Relief: The ultrasonic examination of the reactor vessel outlet nozzle to vessel welds (N-15,-16,-17 and -18) are limited due to the design configuration, (i.e., the integral extensions and the location of the adjacent nozzles). The limitations are noted an the ultrasonic examination data sheets and Attachment A of this request for relief.

Proposed Alternative Examinations: TVA utilized 0*,45',60*,50*/70* and 10' examinations to achieve 100 percent code examination coverage for reflectors parallel to the weld. For reflectors transverse to the weld, code examination coverage for N 15 is 55 percent, N-16 is 39 percent, N-17 is 46 percent and N-18 is 37 percent.

Justification: The design configuration of the reactor vessel outlet nozzle to vessel welds, integral extensions, and the proximity of adjacent nozzles limits ultrasonic examination. An ultrasonic examination was performed on the accessible areas of these welds.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the reactor vessel outlet nozzle to shell welds listed on Attachment A of this request for relief is impractical. TVA's  ;

examinations provide an acceptable level of quality and safety.

Therefore, pursuant to 10CFR50.55a(g)(6)(i)it is recommended that relief be granted.

O REQUEST FOR RELIEF 1-ISI-27 ATTACHMENT A i

WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER CATEGOSI NUMBER CONFIGURATION COVERAGE N-15 B-D CHM-2343-B Outtet Nozzle 100% Code Coverage for Reflectors (With Integral Oriented Parallel to the Weld.

Extension) 55% Code Coverage for Reflectors To Shell Oriented Transverse to the Weld.

N-16 B-D CHM-2343-B Outlet Nozzle 100% Code Coverage for Reflectors (With Integral Oriented Parallel to the Weld.

Extension) 39% Code Coverage for Reflectors To Shell Oriented Transverse to the Weld.

N-17 B-D CHM-2343-B Outlet Nozzle 100% Code Coverage for Reflectors (With Integral Oriented Parallel to the Weld.

Extension) 46% Code Coverage for Reflectors To Shell Oriented Transverse to the Weld.

N-18 B-D CHM-2343-B Outlet Nozzle 100% Code Coverage for Reflectors (With Integral Oriented Parallel to the Weld.

Extension) 37% Code Coverage for Reflectors To Shell Oriented Transverse to the Weld.

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REQUEST FOR RELIEF 2-1S1-20 Components: Pressure-Retaining Welds in Piping Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWB-2500-1 Code Category: BJ Code item Number: 89.31 Code Requirement: 100 percent volumetric and surface examination of branch connection welds greater than 2-inch NPS.

Impractical Requirernent: To achieve 100 percent ultrasonic examination of piping branch connection welds greater than 2-inch NPS.

Basis for Relief: The ultrasonic examination of the branch connection welds are limited due to the design configuration (i.e the branch connection being " set on" the reactor coolant main loop piping). Also, the reactor coolant main loop piping is cast stainless material. The limitations are noted on the ultrasonic examination data sheet and Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed a surface examination on essentially 100 percent of the weld and an ultrasonic examination on accessible areas of these wolds.

Justification: The configuration of the branch connection being set on the reactor coolant main loop piping, which is fabricated of thick wall cast stainless material,is not amenable to ultrasonic examination. Due to the branch connection configuration and material type, current ultrasonic examination techniques are not sufficient to achieve essentially 100 percent code coverage of these branch connection piping welds.

Conclusion:

Based on the above justification,it is concluded that the code requirement for branch connection piping welds greater than 2-inch NPS listed on Attachment A of this request for relief is impractical. TVA's examinations provide an acceptable level of quality and safety.

Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

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REQUEST FOR RELIEF 2-ISI-20 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RCW-01 3" B-J Stainless ISI-0008-B Branch Scan From One 50 % Limited Due to Steel Connection Side Only Configuration and 3"SCH160 Cast Material Forged Nozzle set on 31"ID Header RCW-22 14" B-J Stainless 1S1-0008-B Branch Scan From One 65% Limited Due to Steel Connection Side Only Configuration and 14" SCH160 Cast Material Forged Nozzle set on 29" ID Header RHRW-02 6" B-J Stainless ISI-0003-C Branch Scan From One 80% Limited Due to Steel Connection Side Only Configuration and 6" SCH160 Cast Material Forged Nozzle set on 29"ID Header SIW-09 10" B-J Stainless ISI-0002-C Branch Scan From One 80 % Limited Due to Steel Connection Side Only Configuration and 10"SCH140 Cast Material Forged Nozzle set on 27-1/2" ID Header

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REQUEST FOR RELIEF 2-1S1-21 Component: Pressurizer Full Penetration Welds of Nozzles in Vessels Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWB-2500-1 Code Category: B-D Code item Number: B3.110 Code Requirement: 100 percent volumetric examination of pressurizer nozzle-to-vessel full penetration welds.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the pressurizer nozzle-to-vessel welds.

Basis for Relief: The ultrasonic examination of the pressurizer nozzle-to vessel welds are limited due to the configuration of the pressurizer nozzle. The limitations are noted on the ultrasonic examination data sheet and on Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed an ultrasonic examination on accessible areas of the nozzle-to-vessel welds from the vessel head side of the weld.

Justification: The configuration of the pressurizer nozzle to head prevents ultrasonic scanning techniques from the nozzle side of the pressurizer nozzle to vessel weld.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the pressurizer nozzle-to-vessel welds listed on Attachment A of this request for relief is impractical. TVA's examination provides an acceptable level of quality and safety.

Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

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i REQUEST FOR RELIEF 2-ISI-21 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE CATEGORY MATERfAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RCW-15 4* B-D Carbon ISI-0396-C 4* Nozzle-To- No Scan From 50 % No Scan Due To Nozzle Steel Pressurizer Nozzle Side & Pressurizer Configuration Vessel (Top Head)

RCW-16 6* B-D Carbon ISI-0396-C 6" Nozzle-To- No Scan From 50 % No Scan Due To Nozzle Steel Pressurizer Nozzle Side & Pressurizer Configuration Vessel (Top Head)

RCW-17 6" B-D Carbon ISI-0396-C 6" Nozzle-To- No Scan From 50 % No Scan Due To Nozzle Steel Pressurizer Nozzle Side & Pressurizer Configuration Vessel (Top Head)

RCW-18 6" B-D Carbon ISI-0396-C 6* Nozzle-To- No Scan From 50 % No Scan Due To Nozzle Steel Pressurizer Nozzle Side & Pressurizer Configuration Vessel (Top Head)

RCW-19 6" B-D Carbon Isi-0396-C 6" Nozzle-To- No Scan From 50% No Scan Due To Nozzle Steel Pressurizer Nozzle Side & Pressurizer Configuration Vessel (Top Head)

RCW-21 14" B-D Carbon ISI-0396-C 14" Nozzle-To- No Scan From 50 % No Scan Due To Nozzle Steel Pressurizer Nozzle Side & Pressurizer Configuration Vessel (Bottom Head)

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Reauest for Relief 2-ISI-22 Component: Pressurizer and S/G Pressure-Retaining Dissimilar Metal Welds Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWB-2500-1 Code Category: B-F Code item Number: B5.20 and B5.30 Code Requirement: 100 percent volumetric and surface examination of pressure retaining dissimilar metal welds.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the pressurizer and S/G nozzle-to-safe end welds.

Basis for Relief: The ultrasonic examination of the pressurizer nozzle-to-safe end welds and the S/G nozzle-to-safe end welds are limited due to the design configuration and cast stainless material. Due to the design configuration, no ultrasonic examination was performed from the nozzle side on each weld. Additionallimitation was noted on the S/G safe end due to the cast stainless material. The limitations are noted on the ultrasonic examination data sheet and Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed a surface examination on essentially 100 percent of the weld and an ultrasonic examination on accessible areas of the pressurizer and S/G nozzle-to-safe end welds.

Justification: The design configuration of the pressurizer and S/G nozzle-to-safe end weld and the cast stainless materiallimit the ultrasonic examinations.

No ultrasonic examination was performed from the nozzle side of each weld and a limited ultrasonic examination was performed on the S/G safe ends due to cast stainless material.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the pressurizer and S/G nozzle-to-safe end welds listed on Attachment A of this request for relief is impractical. TVA's examinations provide an acceptable level of quality and safety.

Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

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REQUEST FOR RELIEF 2-ISI-22 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RC-02-SE 29" B-F Stainless ISI-0401-C 29" S/G No Scan From 25% Nu Scan Due To Steel Nozzle Safe Nozzle & Nozzle Configuration End Cast Material RC-03-SE 31" B-F Stainless ISI-0401-C 31" S/G No Scan From 25% No Scan Due To Steel Nozzle-Safe Nozzle & Nozzle Configuration End Cast Material RC-10-SE 29" B-F Stainless ISI-0401-C 29" S/G No Scan From 25% No Scan Due To Steel Nozzle-Safe Nozzle & Nozz!e Configuration End Cast Material RC-11 -SE 31" B-F Stainless ISI-0401-C 31" S/G No Scan From 25% No Scan Due To Steel Nozzle-Safe Nozzle & Nozzle Configuration End Cast Material RC-18-SE 29" B-F Stainless ISI-0401-C 29" SIG No Scan From 25% No Scan Due To Steel Nozzle-Safe Nozzle & Nozzle Configuration End Cast Material RCW-25SE 6" B-F Stainless / ISI 0396-C 6" Pressurizer No Scan From 70 % No Scan Due To Carbon Steel Safety Nozzle- Nozzle Nozzle Configuration Safe End RCW-26SE 6" B-F Stainless / ISI-0396-C 6" Pressurizer No Scan From 70 % No Scan Due To Carbon Steel Safety Nozzle- Nozzle Nozzle Configuration

) Safe End RCW-27SE 6" B-F Stainless / Ist-0396-C 6" Pressurizer No Scan From 80% No Scan Due to Carbon Steel Relief Nozzle Nozzle Nozzle Configuration Relief RCW-28SE 6" B-F Stainless / ISI-0396-C 6" Pressurizer No Scan From 80% No Scan Due To Carbon Steel Safety Nozzle- Nozzle Nozzle Configuration Safe End RCW-29SE 14" B-F Stainless / ISI-0396-C 14" Pressurizer No Scan From 75% No Scan Due To Carbon Steel Surge Lirie Nozzle Nozzle Configuration Nozzle-Safe End

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Reouest for Relief 2-ISI-23 Component: S/G and Centrifugal Charging Pump Tank (CCPT) Pressure Retaining Nozzle Welds in Vecsels -

Class: ASME Code Class 2 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: lWC-2500-1 Code Category: C-B Code itern Number: C2.20 Code Requirement: 100 percent surface and volumetric examination of nozzles in vessels over 1/2-inch nominal thickness.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the S/G and centrifugal charging pump tank nozzle to-vessel welds.

Basis for Relief: The ultrasonic examination of the S/G and centrifugal charging pump tank nozzle-to-vessel welds are limited due to the design configuration.

No ultrasonic examination was performed from the nozzle side on each weld. The limitations are noted on the ultrasonic examination data sheets on Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed a surface examination on essentially 100 percent of the weld and an ultrasonic examination on accessible areas of the S/G and centrifugal charging pump tank nozzle-to-vessel welds.

Justification: The configuration of the S/G and centrifugal charging pump tank nozzle-to-vessel welds prevents ultrasonic scanning techniques from the nozzle side of each weld.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the S/G and centrifugal charging pump tank nozzle-to-vessel welds listed on Attachment A of this request for relief is impractical. TVA's examinations provide an level of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i)it is recommended that relief be granted.

REQUEST FOR RELIEF 2-ISI-23 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS FDW-1 16" C-B Carbon ISI-0401-C 16" Nozzle-To- No Scan From 75% No Scan Due To Nozzle Steel Vessel (Shell) Nozzle Side Configuration S!G FDW-2 16" C-B Carbon ISI-0401 -C 16' Nozzle-To- No Scan From 75% No Scan Due To Nozzle Steet Vessel (SheII) Nozzle Side Configuration S/G FDW-3 16" C-B Carbon ISI-0401-C 16" Nozzle-To- No Scan From 75% No Scan Due To Nozzle Steel Vessel (Shell) Nozzle Side Configuration S/G FDW-4 16" C-B Carbon ISI-0401-C 16" Nozzle-To- No Scan From 75*4 No Scan Due To Nozzle Steel Vessei (Shell) Nozzle Side Configuration S/G MSW-1 32" C-B Carbon ISI-0401-C 32" Nozzle-To- No Scan From 75% No Scan Due To Nozzle Steel Vessel (Head) Nozzle Side Configuration S/G MSW-2 32" C-8 Carbon ISI-0401-C 32" Nozzle-To- No Scan From 75% No Scan Due To Nozzle Steel Vessel (Head) Nozzle Side Configuration S/G MSW-3 32" C-B Carbon ISI-0401-C 32" Nozzle-To- No Scan From 75% No Scan Due To Nozzle Steel Vessel (Head) Nozzle Side Configuration S/G MSW-4 32* C-B Carbon ISI-0401-C 32" Nozzle-To- No Scan From 75% No Scan Due To Nozzle Steel Vessel (Head) Nozzle Side Configuration S/G BIT-2 6* C-B Carbon ISI-0074-A 6" Nozzle-To- No Scan From 75% No Scan Due To Nozzle Steel With Vessel (Head) Nozzle Side Configuration Stainless Cladding CCP Tank BIT-5 6" C-B Carbon ISI-OO74-A 6" Nozzle-To- No Scan From 75% No Scan Due To Nozzle Steel With Vessel (Head) Nozzle Side Configuration Stainless Cladding CCP Tank 1

Reauest for Relief 2-1S1-24 1

l Components: RHR Heat Exchanger (Two per Unit) I 1

1 ASME Code Class 2 (Equivalent)

Class:

Section XI Edition: 1977 Edition Summer 1978 Addenda j Code Table: IWC-2500-1 Code Category: C-A Code item Number: C1.20 Code Requirement: 100 percent volumetric examination of pressure retaining welds in the pressure vessels.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the RHR heat exchanger head-to-shell circumferential welds.

Basis for Relief: Each RHR heat exchanger consists of an inlet-outlet head chamber with one inlet and one outlet nozzle, two integrally attached support brackets and a circumferential vessel head-to-shell weld. The design configuration of the head, nozzles, and support brackets restricts examination of the head to shell weld. The vessel head-to-shell weld is 113 inches in length. The weld examinations are distributed in three segments, identified as: RHRW-17-A-1,37 inches: RHRW-17-A-2, 38 inches; and RHRW-17-A-3,38 inches. RHRW-17-A-1 was ultrasonically examined in the first inspection period. RHRW-17-A-2 was examined in the second period. RHRW-17-A-3 was examined during the third period. Based on the examinations performed, 75 percent examination volume coverage of the RHR heat exchanger circumferential head-to-shell weld was achieved. These limitations are noted on the ultrasonic examination data sheet and on Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed an ultrasonic examination on the accessible areas on one head-to-shell circumferential weld on one RHR heat exchanger to achieve maximum code coverage with meaningful results.

Justification: The design configuration of the RHR heat exchanger (head, nozzles, and support brackets) restrict ultrasonic examination of the head-to-shell circumferential weld.

Conclusion:

Based on the above information,it is concluded that the code requirement for the RHR heat exchanger head-to-shell circumferential weld listed on Attachment A of this request for relief is impractical.

TVA's examination provides an acceptable level of quality and safety.

Therefore, pursuant to 10CFR5055a(g)(6)(i),it is recommended that relief be granted.

REQUEST FOR REUEF 2-ISI-24 ATTACHMENT A WELD WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER LENGTH CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RHRW-17-A-1 37" C-A Stainless ISI-0289-A RHR Heat Exch Scan Restriction 80% Ultrasonic Scan Length Steet Head-To-Shell Due To Head, Restrictions Due To Nozzle and Configuration Of Head Support Brackets Nozzles, and Support Brackets RHRW-17-A-2 38' C-A Stainless ISI-0289- A RHR Heat Exch Scan Restriction 80 % Ultrasonic Scan Length Steel Head-To-Shell Due To Head, Restrictions Due To Nozzle and Configuration Of head, Suppcrt Brackets Nozzles and Support Brackets RHRW-17-A-3 38' C-A Stainless ISI-0289-A RHR Heat Exch Scan Restriction 65% Ultrasonic Scan Length Steel Head-To-Shell Due To Head, Restrictions Due To Nozzle and Configuration Of Head, Support Brackets Nozzles and Support Brackets

Reauest for Relief 2-ISt-25 Component: Pressure-Retaining Welds in Piping

. Class: ASME Code Class 1 (Equivalent) l Section XI Edition: 1977 Edition Summer 1978 Addenda  !

, Code Table: IWB-2500-1 Code Category: B-J '

Code Item Number: B9.11 Code Requirement: 100 percent volumetric and surface examination of 4-inch NPS and greater circumferential pipe welds.

Impractical Requirement: To achieve 100 percent ultrasonic examination of 4-inch nominal pipe i size and greater circumferential pipe welds.

Basis for Relief: The ultrasonic examination of the piping welds are limited due to

, physical configuration and/or cast stainless material. The limitations are i t

noted on the ultrasonic examination data sheet and Attachment A of this request for relief, j Proposed

Alternative Examination
TVA performed a surf ace examination on essentially 100 percent of the weld and an ultrasonic examination on accessible areas of these welds.

. Justification: The physical configuration at structural discontinuities (elbow to nozzle, i elbow to pipe, pump to elbow, etc.) may create scan limitations preventing 100 percent code examination volume coverage, in  ;

addition, the reactor coolant main loop piping is f abricated of cast

! stainless material with a nominal wall thickness ranging from 2.69 inches NW for cold leg,2.84 inches NW for hot leg, and 2.99 inches l NW for the crossover leg. Current ultrasonic capabilities are not sufficient to examine cast stainless materials of this thickness. Due to

! the physical configuration and material type, these piping welds were ultrasonically examined, but unable to achieve essentially 100 percent

code coverage.

Conclusion:

Based on the above justification,it is concluded that the code I

i requirement for the piping welds listed on Attachment A of this request for relief is impractical. TVA's examinations provide an acceptable level

of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

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REQUEST FOR RELIEF 2-ISI-25 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RC-15 27.5* B-J Stain 8ess 1S1-0008-B 27.5" Main Loop No Scan On 40% No Scan Due To Reactor Steel Reactor Coolant Pump Coolant Pump Pump Casing Outlet RC-02 29" B-J Stainless ISI-0008-B 29" Elbow to No Scan From 25% No Scan Due To Steel S/G Nozzle Nozzle S/G Nozzle Configuration RC-23 27.5" B-J Stainless 1S1-0008-B 27.5 Main Loop No Scan On 65% No Scan Due To Steel Pipe to Reactor Pump Reactor Coolant Coolant Pump Pump Casing Outlet RC-35 14" B-J Stainless 1S1-0008-8 14" Pipe to No Scan From 85% No Scan Due To Steel Pressurizer Nozzle Pressurizer Nozzle Nozzle Configuration l

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l J3pouest for Relief 2-ISI-26 Components: ' Pressure-Retaining Weld in Piping Class: ASME Code Class 2 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWC-2500-1 Code Category: C-F Code Item Number: C5.21 Code Requirement: 100 percent surface and volumetric examination of pressure retaining-circumferential welds in piping over 1/2-nominal wall thickness.

Impractical Requirement: To achieve 100 percent ultrasonic examination of circumferential piping welds over 1/2-inch nominal wall thickness.

Basis for Relief: The ultrasonic examination of the 6-inch circumferential flange to main ,

steam piping header weld (MSS 32)is limited due to the design '

configuration. The limitations are noted on the ultrasonic examination data sheets and Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed a surface on essentially 100 percent of the weld and an ultrasonic examination on accessible areas of the 6 inch circumferential flange to main steam pipe header weld, MSS-32.

Justification: The design configuration of the 6-inch circumferential flange to header weld limits ultrasonic examination preventing 100 percent code examination coverage.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the pressure retaining circumferential weld over 1/2-inch nominal wall thickness, MSS 32, listed on Attachment A of this request for relief is impractical. TVA's examinations provide an acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

REQUEST FOR RELIEF 2-ISI-26 ATTACHMENT A VELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER SIZE CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS MSS-32 6' C-F Carbon ISI-0015-C 6" Flange Main Scan Restrictions 75% Scan Restrictions Steel Steam Header Due To Configuration Pipe of The 6* Flange to Main Steam Header Circumferential Weld Connection

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1 Reauest for Relief 2-1S1-27 l I

i Components: RHR heat exchanger integrally welded support attachment.

1 Class: ASME Code Class 2 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWC-2500-1 Code Category: C-C Code item Number: C 3.10 Code Requirement: 100 percent surface examination of pressure vessels integrally welded support attachments.

Impractical Requirement: To achieve 100 percent surface examination pressure vessels integrally welded support attachments.

Basis for Relief: The surface examination of the RHR heat exchanger integrally welded support attachment is limited due to the design configuration of the RHR heat exchanger head and integrally welded support attachment.

The limitations are noted on the examination data sheet and on Attachment A of this request for relief.

Proposed Alternative Examination: TVA performed a surface examination on the accessible areas of the RHR heat exchanger integrally welded support attachment weld, RH RW-19 A-l A.

Justification: The design configuration of the RHR heat exchanger inlet nozzle, outlet nozzle, and head flange limits the surface examination of the RHR heat exchanger integrally welded support attachment.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the RHR heat exchanger integrally wolded support attachment, RHRW-19-A-lA, listed on Attachment A of this request for relief is impractical. TVA's examination provides aa acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

REQUEST FOR RELIEF 2-ISI-27 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS RHRW A-I A C-C Stainiess ISI-0289-A Integrally Weld Partially 75% Access Limited Due To Steel Welded Support inaccessible Configuration of Attachment to RHR Heat Exchanger RHR Heat Exchanger and Integral Attachment Head i

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. I Reauest for Relief 2-ISl 28

- Components: Support Members, Feedwater System Piping integrally Welded Support Attachments .

Class: ASME Code Class 2 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWC-2500-1 Code Category: C-C 4

. Code Item Number: C3.40 Code Requirement: 100 percent surface examination.

Impractical Requirement: To achieve 100 percent surface examination of feedwater system piping integrally welded support attachment,2-FDH-204-IA.

Basis for Relief: Due to the design of the piping support, a surface examination can not be performed on the integrally welded attachment. The four integrally welded attachments have access limitations due to nonremovable pipe clamp interferences. Access to the integrally welded attachments would require removing support brackets for each support attachment lug and removing the pipe clamp by cutting out support welds. The removal of the pipe clamp on the 16-inch diameter pipe is also limited due to the physical location to wall pipe penetration and the location to 3 the floor. These limitations are noted on the surface examination data sheet and on the Attachment A of this request for relief.

Proposed Alternative l Examination: TVA performed VT-3 examination on the integrally welded support l attachment,2-FDH-204-IA. A VT-3 was performed to determine the l general mechanical condition and structuralintegrity of the attachments.

Justification: The design configuration of the feedwater system piping integrally )

welded support attachment prevents a surface examination. I

Conclusion:

Based on the above justification,it is concluded that the code i requirement for the feedwater system piping intergrally welded support attachments,2 FDH 204 IA, listed on Attachment A of this request for i relief is impractical. TVA's examination (VT-3) provides an acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

REQUEST FOR RELIEF 2-1S1-28 ATTACHMENT A COMPONENT EXAMINATION DRAWING  % EXAM SYSTEM IDENTIFIER CATEGORY NUMBER COVERAGE LIMITATIONS Feedwater 2-FDH-204-IA C-C MSG-OOl 6-C 0% Surface Due to the Design of the Support, Access to the integrally Welded Attachment Cannot Be Obtained Without Cutting Out Eight Support Bracket Welds and Removing the Pipe Support 16" Clamp. The Removal of the 16' Pipe Clamp Is Limited Due to Configuration of the Pipe at the Wall Penetration and the Close Proximity to the Floor. No Surface Examination Coverage Was Obtained Due to the Configuration of the Support. TVA Performed the Visual Examination VT-3 on the Accessible Areas of the Integral Attachments.

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.b Reauest for Relief 2-1S1-29 Component: Reactor Outlet Nozzle Welds Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWB-2500-1 Code Category: B-D Code item Number: B3.90 Code Requirement: 100 percent volumetric examination of full penetration wolds of nozzles in the vessels.

impractical Requirement: To achieve 100 percent ultrasonic examination of the reactor vessel outlet nozzle to vessel welds, N-15, N-16, N 17, and N-18.

Basis for Relief: The ultrasonic examination of the reactor vessel outlet nozzle to vessel welds (N-15,-16, -17 and -18) are limited due to the design ,

configuration, (i.e. the integral extensions and the location of the adjacent nozzles). The limitations are noted on the ultrasonic e examination data sheets and Attachment A of this request for relief.

Proposed Alternative Examination: TVA utilized 0*,45 *,60*,50*/70* and 10' examination to achieve l 100 percent code examination coverage for reflectors parallel to the weld. For reflectors transverse to the weld, code examination coverage for N-15 is 80 percent, N-16 is 71 percent, N-17 is 71 percent, and l N-18 is 71 percent.

Justification: The design configuration of the reactor vessel outlet nozzle to vessel J welds, integral extension and the proximity of adjacent nozzles limits ultrasonic examination. An ultrasonic examination was performed on the accessible areas of these welds.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the reactor vessel outlet nozzle to shell welds listed on Attachment A of this request for relief is impractical. TVA's examinations provide an acceptable level of quality and safety.

Therefore, pursuant to 10CFR50.55a(g)(6)(i)it is recommended that relief be granted, l

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REQUEST FOR RELIEF 2-ISI-29 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER CATEGORY NUMBER CONFIGURATION COVERAGE N-15 B-D ISI-0298-B Outlet Nozzle &Vith 100% Code Coverage for integral Extension) Reflectors Oriented to Shell Paratiel to the Weld. 80%

Code Coverage for Reflectors Oriented Transverse to the Weld.

N-16 B-D 151-0298-B Outlet Nozzle 100% Code Coverage for SVith Integral Reflectors Oriented Extension) To Shell Parallel to the Weld. 71% Code Coverage for Reflectors Oriented Transverse to the Weld N-17 B-D ISI-0298-B Outlet Nozzle 100% Code Coverage for (VAth Integral Refixtors Oriented Extension) to Shell Parallel to the Weld. 71% Code Coverage for Reflectors Oriented Transverse to the Weld.

N-18 B-D ISI-0298-B Outlet Nozzle 100% Code Coverage for (With Integral Reflectors Oriented Extension) to Shell Parallel to the Weld. 71% Code Coverage for Reflectors Oriented Transverse to the Weld.

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Reouest for Relief 2-191-30 J l

Component: Reactor Vessel Weld  :

i Section XI Edition: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda . .

Code Table: IWB-2500-1 Code Category: BA Code item Number: B1.11 Code Requirement: 100 percent volumetric examination of pressure retaining welds in the reactor vessel.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the reactor vessel bottom-head to lower-shell circumferential weld, WO2-03.

Basis for Relief: The ultrasonic examination of the reactor vessel bottom-head to lower-shell circumferential weld (WO2-03)is limited due to the design configuration, (i.e. location of the reactor vessel core support lugs).

The limitations are noted on the ultrasonic examination data sheets and on Attachment A of this request for relief.

Proposed i Alternative '

Examination: TVA utilized 0 * , 45 * , 60 * , 50 * /70

  • scans oriented clockwise, counterclockwise, up and down of the bottom-head to lower-shell weld to achieve 73 percent code examination coverage for reflectors oriented parallel to the weld and 70 percent code examination coverage for reflectors oriented transverse to the weld. l Justification: The design configuration of the reactor vessel bottom-head to lower-shell weld limits ultrasonic examinations due to the location of the ,

core support lugs. TVA performed ultrasonic examinations on the accessible areas of the weld.

Conclusion:

Based on the above justification,it is concluded that the code requirement for the reactor vessel bottom head to lower-shell circumferential weld listed on Attachment A of this request for relief is impractical. TVA's examinations provide an acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted. ,

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o REQUEST FOR RELIEF 2-1S1-30 ATTACHMENT A WELD EXAM DRAWING PHYSICAL  % EXAM 1DENTIFIER CATEGORY NUMBER CONFIGURATION COVERAGE WO2-03 B-A ISI-0298-B Bottom Head to Lower 73% Code Coverage for Shell Circumferential Reflectors Oriented Parallel Weld to the Weld. 70% Code Coverage for Reflectors Oriented Transverse to the Weld, i

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. Reauest for Reli3f 2-ISI-31 Component: Reactor Vessel Weld  !

Class: ASME Code Class 1 (Equivalent)

Section XI Edition: 1977 Edition Summer 1978 Addenda '

Code Table: IWB-2500-1 Code Category: B-A Code item Number: B1.30 Code Requirement: 100 percent volumetric examination nf pressure retaining welds in the ,

reactor vessel.  !

Impractical Requirement: To achieve 100 percent ultrasonic examination of the reactor vessel ,

shell to flange weld, WO6 07.  !

Basis for Relief: The ultrasonic examination of the reactor vessel upper shell to flange weld (WO6-07)is limited due to the design configuration. The upper ,

shell to flange weld has limitations on the shell side due to the reactor vessel nozzle locations and on the flange side due to the keyway location. The limitations are noted on the ultrasonic examination data sheets and Attachment A of this request for relief.

Proposed Alternative  :

Examination: TVA utilized 0 * , 45 * , 60 * , 50 * /70

  • scans oriented clockwise, i counterclockwise, up and down of the upper shell to flange weld, to achieve .2. 90 percent code examination coverage for reflectors oriented parallel to the weld and 65 percent code examination coverage for  ;

reflectors oriented transverse to the weld.

Justification: The design configuration of the reactor vessel upper shell to flange weld limits ultrasonic examination due to the location of the keyways and nozzles.

1

Conclusion:

Based on the above justification,it is concluded that the code requirement for the reactor vessel upper shell to flange weld listed on  :

Attachment A of this request for relief is impractical. TVA's examinations provide an acceptable level of quality and safety.

Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

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  • i Reauest for Relief 2-ISI-32 Component: Centrifugal Charging Pump Tank Pressure Retaining Welds in Pressure  !

Vessels L Class: ASME Code Class 2 (Equivalent) l Section XI Edition: 1977 Edition Summer 1978 Addenda Code Table: IWC-2500-1 Code Category: C-A Code item Number: C1.10 Code Requirement: 100 percent volumetric examination of pressure retaining welds in the pressure vessels, head to shell circumferential welds.

Impractical Requirement: To achieve 100 percent ultrasonic examination of the centrifugal charging pump tank head to the shell circumferential weld. ,

4 Basis for Relief: The ultrasonic examination of the centrifugal charging pump tank head to shell weld is limited due to the design configuration. The centrifugal charging pump tank consists of two circumferential shell welds, one intet nozzle, one outlet nozzle, and four integrally welded support attachments. The design configuration restricts ultrasonic examination of circumferential head to shell weld, BIT-4. The limitations are noted ,

on the ultrasonic examination data sheets and on Attachment A of this i request for relief. >

Proposed Alternative Examination: TVA performed an ultrasonic examination on the accessible areas of the cer'trifugal charging pump tank circumferential head to shel! weld.

Justification: The design configuration of the centrifugal charging pump tank restricts l titrasonic examination of circumferential head to shell weld, BIT-4. I 1VA performed an ultrasonic examination to achieve maximum code e < amination volume coverage and with meaningful results,79 percent e.< amination volume coverage was achieved.

Conclusion:

B ased on the above justification,it 4 concluded that the code re luirement for the centrifugal charging pump tank circumferential head to shell weld, BIT-4, listed on Attachment A of this request for relief is irr practical. TVA's examination provides an acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55a(g)(6)(i),it is recommended that relief be granted.

II

REQUEST FOR REllEF 2-ISI-32 ATTACHMENT A VELD VELD EXAM DRAWING PHYSICAL  % EXAM IDENTIFIER LENGTH CATEGORY MATERIAL NUMBER CONFIGURATION LIMITATIONS COVERAGE REMARKS BIT-4 151" C-A Carbon ISI-0074-A Shell to Lower Scan Restrictions, 79% Scan Restrictions Due Steel With Head Weld Weld Partially to Configurations of Stainless inaccessible Due Tank Integrally Welded Cladding to Four integrally Support Attachments Welded Attachments

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