ML20084Q882
| ML20084Q882 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/24/1994 |
| From: | Mcalister T SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | |
| Shared Package | |
| ML20084Q874 | List: |
| References | |
| PROC-941024, NUDOCS 9506090112 | |
| Download: ML20084Q882 (111) | |
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NUCLEAR OPERATIONS COPY NO.-
ISE-3 REVISION 1 SOUTH CAROLINA ELECTRIC & GAS COMPANY V. C. SUMMER NUCLEAR STATION ASME SECTION XI INSERVICE EXAMINATION MANUAL FOR 2ND INSPECTION INTERVAL REVIEWED BY: 2nN/ Cf. U - a I m / /o/z//9e
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'DAT'E APPROVED BY: ~
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O V. C. SUMMER NUCLEAR STATION INSERVICE EXAMINATION PROGRAM 2ND TEN YEAR INTERVAL OWNER: SOUTII CAROLINA ELECTRIC AND GAS COMPANY COLUMBIA, SOUTH CAROLINA 29218
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PLANT: V. C. SUMMER NUCLEAR STATION POST OFFICE BOX 88 JENKINSVILLE,SC 29065 CAPACITY 1 UNIT of 900 MWE COMMERCIAL SERVICE DATE: JANUARY 1,1984 PREPARED BY: /NJJY[,
Quality Control Engineer Date l
APPROVED BY: /A/?i/ d . e / /k/7/fg Supervisor / Quality Control D' ate /
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APPROVED BY: CMf o [
ManW'uclear Quality Systems
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Date
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REVIEWED BY: aw ! d g,etto ~
/ /# "/f1 Authorized Nuclear Inservice Inspector Date
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l South Carolina Electric & Gas Company V.C. Summer Nuclear Station Second Ten YearInterval l
Inservice Examination Program i
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V.C.SummerNaciser Station Second 10. Year Interval Inservice Examination Program Revision 1 TABLE OF CONTENTS
1.0 INTRODUCTION
. .. .. ..... . . ...... ... . . ..... .... 1 1.1 SCOPE .. .. ... . .... .... .... ........... 2 1.1.1 Program Exclusions . .. ......... . . . . . ...... 2
1.2 BACKGROUND
.. ..... .. .. . .... . .... . ... ...... 2 1.3 APPLICABLE DOCUMENTS . . . . .. ... ... . ... .... ............ 3 1.3.1 Regulatory Documents .. . ............. .. .. ..... .... .. 3 1.3.2 Codes and Standards . ............ .... ... .. ........... 4 1.3.3 SCE&G Documents . ..... . . . . . . . .. ... .. ....... 5 1.3.4 Definitions .. .. . .. .... .. ... .. .... . 5 1.3.5 Abbreviations and Acronyms .. ... . ... .... . ........... . 8 2.0 GENERAL REQUIREMENTS . . . . . . . .... . 10 2.1 RESPONSIBILITIES .... . . ... .. . .. . . ......... 10 2.1.1 Owner . ... . .
.. . . .... . ...... 10 2.1.2 Inspection Agencies . .... . .... . ... . .... ...... 10 2.2 SCOPE OFINSERVICE EXAMINATION ... . .... .. . ... ..... . 10 2.2.1 Classification of Systems, Portions of Systems, and/or Components . . . . . 10 2.2.2 System Boundaries Subject to Inservice Examination . ... .... . 11 2.3 QUALIFICATION OF NONDESTRUCTIVE EXAMINATION PERSONNEL 12 2,4 EXAMINATION EQUIPMENT AND PROCEDURES . . . . . . . . . . . . . . 12 2.4.1 Calibration Standards . . . . . . . . ...... ..... . . .... ... 12 2.4.2 Examination Procedures . . . .. .. . ... ...... 12 2.5 PRESERVICE EXAMINATIONS . . . . . .. .. . .. . .... .. 13 2.6 INSERVICE EXAMINATIONS . . . . . . . . ..... 13 2.6.1 Inspection Schedule .. ....... .. .. . . . ....... 13 2.7 EXAMINATION REQUIREMENTS ... ... . ....... . ... . ..... 16 2.7.1 Examination Methods . ... ... . .. ... . . . .... .. 17 2.7.2 Extent of Examination ..... .. ... .. . ... ....... 20 2.8 EXAMINATION EVALUATION . .... . ... ... 22 2.9 EXAMINATION ACCEPTANCE STANDARDS . .. . ... ........ 23 2.10 ISE DRAWINGS . . . .. . ... ... . . .. 24 2.10.1 ISE Classification and Boundary Identification Drawings .. ... .. 24 2.10.2 ISE Composite (Isometric) Sketches .. . .. .... 25 i
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V.C. Summer Nucher Str.tiin l Second 10-Year Intervs1
. Inservice Exammatwn Program Revision 1 TABLE OF CONTENTS (cont.) !
2.11 RECORDS AND REPORTS ... . . .. .. . .. .. ... .... . 25 2.11.1 ISE Database .. . . . ... ........ .. .. . . .... . 25 2.11.2 Inservice Inspection Outage Summary Report .. .. ... .. ...... 26 3.0 EXEMPTIONS AND POSITION STATEMENTS . . .. . . . .... 27 3.1 CODE ALLOWED EXEMPTIONS . . . . .. .... . ...... 27 ;
i 3.1.1 Class 1 (IWB) Exemptions . . . . . . . . . .. ........ ..... .....,.. 27 i 3.1.2 Class 2 (IWC) Exemptions ..... .. ... . .. ... . ...... ......... 27 l 3.1.3 Class 3(IWD) Exemptions . .. ....... ...... ... . .. ....... 29 3.1.4 Class 1,2, and 3 Component Support Exemptions .... .. .... ..... 29 3.1.5 Class 1,2, and 3 Integral Attachments Exemptions . ..... ... .. 29 3.2 SCE&G POSITION STATEMENTS AND CLARIFICATIONS . . . . . . . . . . 30 :
3.2.1 Exemptions . . .. . . .. ... . ... . ........... 31 3.2.2 Successive Inspections - First Interval verses Second Interval ... . 32 4.0 ASME CODE C ASES . .. . . .. . .. .. . . ........ 34 l
4.1 CODE CASES ENDORSED BY USNRC REGULATORY GUIDE 1.147, REVISION 10 . . . . . . . . .. .. ... .... .... ... . .. 34 4.2 CODE CASES NOT ENDORSED BY USNRC REGULATORY GUIDE 1.147, l REVISION 10 . .. . . ...... . .. ..... ... .. .. .. 35 i 5.0 ISE PROGRAM-WELDS AND COMPONENTS . . ....... . 36 f 5.1 CLASS I COMPONENTS ... .. . ... . . . . ... .... 36 r
5.1.1 Examination Category B-A, Pressure-Retaining Welds in Reactor Vessel 36 !
5.1.2 Examination Category B-B, Pressure Retaining Welds in Vessels Other ,
Than Reactor Vessels .. .. . . .. .... ... . . ....... 38 '
5.1.3 Examination Category B D, Full-Penetration Welds of Nozzles in Vessels - '
Inspection Program B .. . ... .. .. . . .. . ............ 39 5.1.4 Examination Category B-F, Pressure Retaining Dissimilar Metal Welds 41 5.1.5 Examination Category B-G-1, Pressure Retaining Bolting, Greater Than !
2 in. In Diameter .. ... ... . ... . ....... . ......... 42 L 5.1.6 Examination Category B-G-2, Pressure Retaining Bolting,2 in. And Less '
In Diameter . . . . . .... . .. . . .. . . . . . . ...... 45 5.1.7 Examination Category B-H, Integral Attachments for Vessels (See Relief Request RR-XX) .. . .. .. . . . . ...... 48 5.1.8 Examination Category B-J, Pressure Retaining Welds In Piping . .... 48 ,
5.1.9 Examination Category B-K-2, Integral Attachments For Class 1 Piping, '
Pumps and Valves (See Reliedequest RR-02) ... . . . ... . 50 ;
5.1.10 Examination Category B-L-2, Pt.mp Casings . ....
. . . ... 50 5.1.11 Examination Category B-M-2, Vedve Bodies .. .... ... .. ... 51 5.1.12 Examination Category B-N-1, Interior Of Reactor Vessel ... .. . .... 52 5.1.13 Examination Category B-N-2, Integrally Welded Core Support Structures ,
and Interior Attachments To Reactor Vessels . . .... . . . 52 1 5.1.14 Examination Category B-N-3, Removable Core Support Structures . . 53 5.1.15 Examination Category B-0, Pressure Retaining Welds In Control Rod Housings . 53 i
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V.C. Summer Nuctur Statian i Second 10.YearInterval [
Inservice Examination Program Rmsion 1. (
)
TABLE OF CONTENTS (cont.) {
5.1.16 Examination Category B P, All Pressure Retaining Components . . . . . 53 5.1.17 Examination Category B-Q, Steam Generator Tubing .... .......... 54 ,
5.2 CLASS 2 COMPONENTS . ... ..... ..................... ......... 54 !
t 5.2.1 Examination Category C-A, Pressure Retaining Welds In Pressure Vessels 54 l 5.2.2 Examination Category C B, Pressure Retaining Nozzle Welds In '
Vessels . . . .. ...... ................... ................... . 56 i 5.2.3 Examination Category C-C, Integral Attachments For Class 2 Vessels i and Piping (See Relief Request RR-02) ....... ................. .... 58 .
5.2.4 Examination Category C-F-1, Pressure Retaining Welds In Austenitic i Stainless Steel Or High Alloy Piping ....... .. . ... .......... 58 :
5.2.5 Examination Category C-F-2, Pressure Retaining Welds In Carbon Or Low Alloy Steel Piping . . . . . . . . . . . . . . . .......... ... . .......... 64 :
5.2.6 '
Examination Category C-H, All Pressure Retaining Components ..... 68 5.3 CLASS 3 COMPONENTS . . . .. . . ... ... .... .................. 68 5.3.1 Examination Category D-A, System in Support of Reactor Shutdown l Function . ... .. .... .. ........ .. . . ................. 68 l 5.3.2 Examination Category D.B, Systems In Support Of Emergency Core Cool 6g, Containment Heat Removal, Atmosphere Cleanup, and Reactor Residual Heat Removal ...... . ..... ....... .. ........ 69 5.3.3 Examination Category D-C, Systems In Support Of Residual Heat RemovalFrom Spent Fuel Storage Pool .. .. .. .. ...... 69 l
6.0 ISE PROGRAM - COMPONENT SUPPORTS . . . . . . . . ... .. .. ......... 70 6.1 INSERVICE EXAMINATION - CLASS 1,2, AND 3 PIPING SUPPORTS 70 6.1.1 Examination Category F-A, Piping Supports ............ .......... 70 6.2 INSERVICE EXAMINATION CLASS 1,2, AND3 SUPPORTS OTHER THAN PIPING SUPPORTS .. .. . ..... ...... ..... .. ......... 74 6.2.1 Examination Category F-A, Supports Other Than Piping Supports . 74 6.3 INSERVICE TESTING OF SNUBBERS (IWF-5000) ......... ... ....... 75 7.0 ISE PROGRAM -INTEGRAL ATTACHMENTS . ....... .................. 76 7.1 INSERVICE EXAMINATION - CLASS 1,2, AND 3 INTEGRAL ATTACHMENTS .. . . .. . . . . .. .. 76 1 7.1.1 Class 11ntegral Attachments .. . ..... .. . .... .. 76 7.1.2 Class 2 Integral Attachments . . . . . ....... . ......... .. 78 7.1.3 Class 3 Integral Attachments . . .... ...... ....... ....... 80 8.0 ISE PROGRAM - SYSTEM PRESSURE TESTING . . . ... ....... ... . 82 iii
j V.C. Summer Nuclw.r Station Second 10. Year Interval Inservice Exammation Program Revision 1 l
TABLE OF CONTENTS (cont.) .
9.0 AUGMENTED INSERVICE INSPECTION GSE) PROGRAM .... .. . ..... 83
9.1 INTRODUCTION
TO THE AUGMENTED ISE PROGRAM . . . . . . . . . . . . . . 83 9.2 THE AUGMENTED ISE SUBPROGRAMS . .. ... ..... .. ....... . 83 l 9.2.1 AUG-01, Regulatory Guide 1.14 - Reactor Coolant Pump Flywheel Integrity .. . .......... ..... . ... .. .. ... ............ .... 84 9.2.2 AUG-02, Piping Supports Exempt by Code Having Nonexempt Integrally Welded Attachments . . . . . . . . . . ...... .. .......... 85 l
10.0 RELIEF REQUESTS .. . . .. .. .. ... . .... ........ . ....... 86 10.1 RELIEF REQUEST MATRIX . . . . ...... .... .. ............. 87 l 10.2 VCSNS RELIEF REQUESTS - SECOND INSERVICE INSPECTION l INTERVAL . . . .. . . . . . .. . . . . .. . . ..... 89 APPENDIX A - Ultrasonic Examination Calibration Standards . .. .. . .. ....... A-i APPENDIX B Multiple-Component Groups .. . . .... .. . . . . .. ....... B-i APPENDIX C -Inservice Inspection Drawings . .... . . ..... . .. .. .. C-i l
APPENDIX D - Relief Requests . . . . . . . . . . . . . . . . . .. .... ... D-i APPENDIX E -ISE Program Tables .. . . . . . .. . .. .. . . . . . . . . . E-i i
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IV
+ i V.C. Summer Nuciar Station Second 10-YearInterval Inservice Examination Program Revision 1. .
1.0 INTRODUCTION
This document details the Inservice Examination Program for South ;
Carolina Electric & Gas Company's (SCE&G) V.C. Summer Nuclear Station (VCSNS), updated for the second 120-month inservice inspection interval. In ;
accordance with U. S. Nuclear Regulatory Commission rules and ;
regulations, the operating license for a pressurized water reactor (PWR) nuclear power facility is subject to certain conditions mandated in 10CFR50.55afg)(4). As such, throughout the service life of VCSNS, nuclear l
power plant components -including supports - which are classified as ASME i Code Class 1, Class 2, and Class 3, are required to meet the inservice :
1 inspection requirements 1 of the governing ASME Code,Section XI," Rules for Inservice Inspection of Nuclear Power Plant Components". The purpose of this document is to detail the essential parameters which define the VCSNS Inservice Examination Program and, therefore, provide a basis for compliance of this ISE Program (commonly referred to as ISI in the nuclear industry) with the mandated rules and regulations. ,
i The second 10-year inspection interval for VCSNS will commence on i'
January 1,1994, and end on January 1,2004. In accordance with 10CFR50.55a paragraphs (g)(4) and (g)(5)(i), prior to the start of the inservice inspection interval, the inservice inspection program must be revised to incorporate Code editions and addenda as referenced in 10CFR50.55a(b). As such, the ASME Section XI Code of record for the updated second inservice inspection interval ISE Program is the 1989 3 Edition. This ISE Program has been prepared in accordance with, and complies with, the 1989 Edition of the ASME Section XI Code, hereafter, !
simply referred to as the Code. All references in this document to the Code, i e.g. Examination Categories, item Numbers, etc., refer to the 1989 Edition of the Code unless specifically stated otherwise through the use of relief requests. ,
1 1Except design and access provision i
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V.C. Summer Nuclw.r Station Second 10-YserInt:rval Inservice Examinxtion Program Revision 1, 1.1 SCOPE VCSNS Class 1,2, and 3 components subject to the rules and requirements of Code Subsections IWA,IWB,IWC,IWD, and IWF, (with the exception of Articles IWX-4000 and IWX-7000, which deal with repairs and replacements), are included within the scope of this document. In addition, this document may include augmented examination programs to comply with additional and/or supplemental examination requirements imposed by Regulatory Authorities or SCE&G recommendations and/or requirements.
1.1.1 Program Exclusions Specifically excluded from the scope of this ISE Program are the inservice testing requirements of ASME Section XI, Article IWP and IWV (pump and valve testing), and Sub-article IWA-5000 (pressure testing). These requirements are contained in VCSNS's IST Program. Cod Sub-artida IWX-4000 and IWX-7000 regarding repairs and replacements a als.o outside of the scope of this document and are contained in VCSNS's document SAP-641,"ASME Section XI Repair Program" The requirements of Code Article IWE, which addresses the inservice inspection ofcontainments, are not mandated by 10CFR50.55a at this time, and therefore, are not included within the scope of this document.
1.2 BACKGROUND
The V.C. Summer Nuclear Station consists of a one unit,2775 MWT l 1
thermal, approximately 900 MWE,3 loop, Westinghouse Pressurized Water l
Reactor (PWR).
l The first inservice inspection interval for VCSNS commenced on January 1, 1984, coincident with unit commercial operation, and ended on January 1, 1994. The Code of record for the first inservice inspection interval was tiw i
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V.C, Summer Nuclect Station Secorello-YearInterval Inservice Examination Program Revision 1, 1977 Edition, Summer 1978 Addenda of ASME Section XI, except as modified by 10CFR50.55a(B)(2)(iv)2 Per 10CFR50.55a(g)(4)(ii), the governing Code for subsequent inservice inspection intervals is the latest edition and addenda of the Code incorporated by reference in the regulations (10CFR50.55a(b)) 12 months prior to the start of the inspection interval. Given a January 1,1994 start-of-interval date, the Code governing the second inservice inspection interval for VCSNS is the 1989 Edition of ASME Section XI. This is based on Code of Federal Regulations, Title 10, Part 50, as revised by Federal Register, Vol.
57, No.152, dated August 6,1992, which references the 1989 Code Edition, effective September 8,1992, therefore, any inspection interval commencing after September 8,1993, must comply with the 1989 Edition of ASME Section XI.
1.3 APPLICABLE DOCUMENTS 1.3.1 Regulatory Documents 1.3.1.110 CFR50, Code of Federa' Regulations, Title 10, Part 50 as revised by Federal Register, Vol. 57, No 102 dated August 6,1992, pages 34673 through 34676.
1.3.1.2 Regulatory Guide 1.26, " Quality Group Classifications and Standards for Water , Steam , and Radioactive-Waste-Containing Components of Nuclear Power Plants", Revision 3, February 1976.
1.3.1.3 Regulatory Guide 1.147," Inservice Inspection Code Case Acceptability",
Revision 10, July 1993.
2 Pressure-retairung we tds in ASME Code Class 2 piping (applies to Tables BVC-2520 or DVC.25101. Category C.F).
Appropriate Code Class 2 pipe welds in Residual Heat Removal. Emergency Core Cooling, and Containment Heat Removal Systems shall be examined. The extent ofexammation for these systems shall be determined by the requirements of paragraph DVC 1220. Table BVCJ520 Category C.F and C-G.an paragraph DVC-2411. in the 1974 Edition and Addenda throuch the Summer 1975 of Section XI of the ASME Code Page 3 of 89
V.C. Summsr Nucla:r Stotion Second 10-YearInterval 7 Inservice Examination Program Revision 1 1.3.1.4 Regulatory Guide 1.150," Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations", Revision 1 (Alternate .
Method).
1.3.1.5 NUREG-0800, Standard Review Plan For The' Review Of Safety Analysis Reports For Nuclear Power Plants; Section 3.2.2, System Quality Group Classification j l
1.3.2 Codes and Standards 1.3.2.1 ASME Codes >
1.3.2.1.1 American Society of Mechanical Engineers,Section V, " Nondestructive Examination",1989 Edition !
i 1.3.2.1.2 American Society of Mechanical Engineers,Section XI, " Rules for Inservice i Inspection of Nuclear Power Plant Components", Division 1,1989 Edition, !
except as noted by Relief Requests.
i 1.3.2.2 ASME Code Cases (See Section 4.1) ;
i 1.3.2.3 ASME Nonmandatory Appendices 1.3.2.3.1 ASME Section XI, Nonmandatory Appendix A," Analysis of Flaws",1989 !
Edition 1.3.2.3.2 ASME Section XI, Nonmandatory Appendix C," Evaluation Of Flaws In {
Austenitic Piping",1989 Edition i
1.3.2.3.3 ASME Section XI,Nonmandatory Appendix F," Preparation ofInspection Plans",1989 Edition I
I 1.3.2.4 ASNT SNT-TC 1 A,1984 Edition j Page4 of 89
V.C. Summer Nuctser Station
- Second 10-YearInterval Inservice Examination Program Revision 1, 1.3.3 SCE&G Documents l
1.3.3.1 VCSNS Final Safety Analysis Report i
1.3.3.2 VCSNS Operating License and Technical Specification ;
i 1.3.3.3 SCE&G Cornpany Operational Quality Assurance Plan I i
1.3.3.4 SAP-145 - ASME Section XI Pressure Testing Program i
l 1.3.3.5 SAP-641 - ASME Section XI Repair Program
! 1.3.3.6 STP-804.901 - Eddy Current Examination of S/G Tubing l
l 1.3.3." STP-803.003 - Mechanical Snubber Basic Operational Test 1.3.3.8 STP-803.005 - Hydraulic Snubber Operational Test 1
1.3.4 Definitions 1
1.3.4.1 Augmented Requirements - Those NDE or tests required / recommended by documents other than ASME Section XI, such as; Regulatory Guides, NUREG's, NRC Generic Letters, I.E. Bulletins / Notices, FSAR, Technical Specifications, manufacturer's recommendations, etc.
1.3.4.2 Authorized Nuclear Inservice Inspector (ANII) - A person employed and qualified by an Authorized Inspection Agency to verify that NDE, test, and repairs and replacements (excluding welding and brazing) are performed in accordance with the rules of ASME Section XI.
1.3.4.4 Code - ASME Section XI," Rules for Inservice Inspection of Nuclear Power Plant components," 1989 Edition without Addenda.
I 1.3.4.5 Component An item in a nuclear power plant such as a vessel, pump, valve, etc. Component may also be used to refer to systems or portions of systems such as welds, bolting, and supports.
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V C. Summer Nuelser Station Semnd 10-YearInterval !
Inservice Examination Program >
Revision 1, j t
1.3.4.6 Form NIS-1, Owners' Data Report forInservice Inspections - An ASME form used to document the results ofInservice Inspection j examinations on Class 1 and 2 components. It is to be used as the certification page for submittal of the ISI Summary Report. l l
1.3.4.7 Fortn NIS-2, Owners' Report for Repairs or Replacements - An ASME form used to document the results of repair or replacernent activities. It will be submitted as part of the ISI Summary Report at the end of each refueling -
r outage.
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1.3.4.8 Inservice Examination (ISE)- Those Nondestructive Examination (NDE) l including visual examinations performed on certain Class 1,2, and 3 componentsand their supports throughout the operating life of the nuclear plant, as required by ASME Section XI, subsections IWA,IWB,IWC,IWD, and IWF. l 1.3.4.9 Inservice Inspection Summary Report - The report that is prepared at ,
the completion of each refueling outage as specified in ASME Section XI.
1.3.4.10 Inspection Interval - As defined by regulations, a ten year time interval, during which the ISE program is applicable using a specific Edition and Addenda of ASME Section XI. The first ten year inspection interval commences on the date of commercial operation with the successive :
intervals beginning on the date the previous interval ends. An inspection interval length may be increased or decreased up to one year, to correspond with plant outages. Additionally, the interval may be extended for a period l equivalent to an catage, which extends continuously for six months or more.
1.3.4.11 Inspection Period - A time frame approximately equivalent to one third of i an interval. It is used for apportioning the implementation ofISE Program NDE during the interval.
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V.C. Summer Nuclaer Station Second 10. Year Int:real Inservice Examination Program Revision 1, 1.3.4.12 ISE Program Document - The document (including applicable drawings) which addresses the overallISE requirements during a ten year interval.
1.3.4.13 ISE Tables - The unit specific listing of the total population ofitems such as welds, bolting, components, supports, and portions of systems which are subject to examination, and repair and replacement during the ten year interval (i.e., all nonexempt cornponents). These listings are included within the ISE program Document, and, as a minimum, identify items selected for examination along with examination frequency requirements and other mandatory requirements, if special consideration is applicable.
These tables provide the prirnary basis for development of the ISE Implementing Plan.
1.3.4.14 ISE Implementing Plan - The listing of nonexempt components identified in the ISE Tables, with the information necessary for implementation of examinations. This listing should include as a minimum, such information as: components selected for examination: scheduling information; :
applicable NDE methods; and calibration blocks, etc.
1.3.4.15 ISE Outage Plan - A listing of those components identified in the ISE Implementing Plan which are required to be examined during a particular 1
outage.
1.3.4.16 Nondestructive Examination (NDE)- Any of several physical, optical, chemical, electrical, or electromagnetic tests used primarily to examine items for surface or internal defects without destroying the items or j impairing their function. Also k2.an as Nondestructive Testing (NDT) and includes visual, surface, and volumetric methods.
l 1.3.4.17 Position Statement - An ISE Program record which documents the details of positions taken by SCE&G with respect to generalized Code requirements. These records amplify the Code requirement and provide consistent guidance for the implementation of the requirement.
1.3.4.18 Preservice Inspection (PSI)- Those Nondestructive Examinations (NDE) including visual examinations performed on certain ASME Class 1,2, and 3 Page 7 of 89
V.C. Summer Nucler Station Second 10-YearInurvcl Inservice Examination Program Revision i, components and their supports once, prior to initial plant operations as part of the Preservice Inspection Program, or following a component repair, replacement, or modification. The results of these examinations provide a baseline for comparison to subsequent ISE required examinations.
1.3.4.19 Regulatory Authority - The United States Nuclear Regulatory Commission, empowered to issue and enforce federal regulations influencing design, construction, and operation of nuclear power plants.
1.3.4.20 Relief Request - A written request submitted to the regulatory authority which identifies specific components which would be impractical to be examined or tested in accordance with ASME Section XI requirements. It includes the reason these requirements are impractical to meet and technicaljustification for performing an alternative to the requirements.
1.3.4.21 Structural Discontinuity Weld s - Includes circumferential weld joints at pipe to vessel nozzle, pipe to valve body, pipe to pump casing, and pipe to fittings. For the purposes of this ISE program, fitting-to-fitting welds and pipe-to-pipe welds having a schedule change, shall also be considered structural discontinuities.
1.3.4.22 Terminal End Welds - The extremities of piping runs that connect to structures, components, or pipe anchors, each of which acts as a rigid restraint or provides at least two degrees of restraint to piping thermal expansion (reference IWA-9000).
1.3.5 Abbreviations and Acronyms ANII Authorized Nuclear Inservice Inspector ;
ASME American Society of Mechanical Engmeers l 1
CS Carbon Steel l FSAR FinalSafety AnalysisReport ISE Inservice Examination MT Magnetic Particle type examination NDE Nondestructive Examination Page 8 of 89 1 1
V.C. Summer Ecle:s Station Second 10-Yest Int:rvs>l Inservice Examination Program Revision i, NDT Nondestructive Testing NPS NominalPipe Size (inches)
NRC Nuclear Regulatory Commission PT Liquid Penetrant type examination SCE&G South Carolina Electric & Gas Company SD Structural Discontinuity (weld)
SS Stainless Steel TE Terminal End (weld)
UT Ultrasonic type examination VCSNS V.C. Summer Nuclear Station VT Visual type examination 10CFR50 Title 10, Code of Federal Regulations, Part 50 l IWX Reference to Section XI Subsection IWA, IWB, IWC, IWD, IWF i
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V.C. Summer Nuclar Statien Second 10.YearInterval ;
Inservice Examination Program Revision 1, 2.0 GEN.)',RAL REQUIREMENTS l 2.1 RESPONSIBILITIES i
2.1.1 Owner The South Carolina Electric & Gas Company (SCE&G), as the organization legally responsible for the operation, maintenance, safety, and power l generation of VCSNS,is designated as Owner of this ISE Program. As such, SCE&G is responsible for the preparation, maintenance, and implementation of this ISE Prograrn in accordance with IWA-1400 of the Code.
t SCE&G, as Owner, is also responsible for contracting for the services of an .
Authorized Inspection Agency and for providing adequate access for the f
Authorized Nuclear Inservice Inspector (ANII) to perform the necessary ,
inspection services (IWA 2130). !
2.1.2 Inspection Agencies i
The Authorized Inspection Agency, and the ANII, have been empowered by -
the jurisdictional enforcement authority to verify that examinations I performed in accordance with this ISE Program are done so in accordance with the rules and requirements of the Code. The duties of the ANII are j defined in paragraph IWA-2110 of the Code.
I 2.2 SCOPE OFINSERVICE EXAMINATION f
2.2.1 Classification of Systems, Portions of Systems, and/or Components Application of Code rules to systems and components is facilitated by the assignment of safety or quality group classifications. That is,in accordance with paragraph IWA-1320, Articles IWB, IWC, and IWD rules apply to systems and components classified as Class 1,2, and 3, respectively. VCSNS plant systems, portions of systems, and/or components, such as vessels, pumps, valves, piping systems, etc., have b 3en reviewed for classification and Page 10 of 89
V.C. Summsr Nuclarr Station Second 10.YearInterval Inservice Examination Program Revision i, subsequent inclusion in this ISE Program. Guidance for establishing the VCSNS ISE classifications has been taken from:
e 10CFR50.2(v), I e Regulatory Guide 1.26, j e NUREG 0800, Section 3.2.2, and the
)
e VCSNS FSAR. I Piping and components within the reactor coolant pressure boundary and, ,
piping and components of other systems containing water and/or steam, have I been classified as Class 1,2, or 3. VCSNS systems, portions of systems, or
]
components, within the ISE boundaries, which have been constructed to a 3 classification higher than the minimum class established in the component design specifications, have been classified for inservice examination in i accordance with the overall system classification or the minimum design i classification. I ISE classification of systems, portions of systems, and/or components are l illustrated on the VCSNS ISE Boundary Classification Drawings (See )
Paragraph ).
]
ASME Code Classes correspond with the safety classification depicted on the l flow diagrams as follows:
]
ASME Code Class Flow Diatram Safety Class 1 1 l
2 2a 3 2b -
2.2.2 System Boundaries Subiect to Inservice Examination System boundaries have been established to identify the extent to which the rules and requirements of the Code need to be applied. Systerns and components within these established boundaries are subject to governing Code rules.
9 Page 11 of 89
V.C. Summer Nucler.r Stztion Second 10.YearInterval Inservice Examination Program Revision 1, Guidance for establishing the boundaries of this ISE Program has been taken from:
e 10CFR50.2(v),
o Regulatory Guide 1.26, o NUREG 0800, Section 3.2.2, e VCSNS FSAR e Plant Piping System Flow Diagrams.
l l l The ISE Program boundaries, as well as the system and component classifications, are illustrated on the VCSNS ISE Boundary Classification Drawings (See Paragraph ).
2.3 QUALIFICATIOli OF NONDESTRUCTIVE EXAMINATION PERSONNEL Personnel performing all nondestructive examinations (NDE), as required by this ISE Program, will be qualified and certified using a written practice prepared in accordance with SNT-TC-1A, Subarticle IWA-2300 of the Code, and SCE&G written practice or equivalent.
2.4 EXAMINATION EQUIPMENT AND PROCEDURES 2.4.1 Calibration Standards Calibration of ultrasonic examination equipment will be accomplished utilizing the calibration standards listed in Appendix A. Additional standards. :. approved by SCE&G, may be designed and fabricated, as needed.
2.4.2 Examination Procedures i
Nondestructive examinations, as required by this ISE Program, will be performed in accordance with written, qualified procedures.
Page 12 of 89
I
. I V.C. Summer Nucher Station Suond 10-YearInterval 1 Inservice Examination Program Revision 1, 2.5 PRESERVICE EXAMINATIONS Preservice examinations of VCSNS components will be performed during the second 10-year inspection interval following repair, replacement, or correction of components, in order to establish a new preservice record.
Preservice examinations will also be performed following modifications or the addition of new systems, portions of systems, or components within the scope of this ISE Program.
2.6 INSERVICE EXAMINATIONS 2.6.1 Inspection Schedule Components required to be examined during the second 10-year inspection interval will be scheduled for examination predominately during plant refueling outages and/or extended maintenance outages. However, where practical, some examinations may be performed during plant operation.
2.6.1.1 Inspection Program B The inservice examinations required by IWB, IWC, and IWD, and the examination of component supports and integral attachments during the second 10-year inspection inter cal, shall be completed in accordance with the requirements ofInspection Prog am B, of the Code, as illustrated in Figure 2.6-1.
Figure 2.6 - 1 Inspection Program B 2nd Inspection Inspection Minimum Examinations Maximum Examinations Interval Period Completed, % Credited, %
1/1/94-1/1/04 1st (3 years: 16 34 l 1/1/94-1/1/97 1/1/94-1/1/04 2nd (4 years) 50 67 1/2/97-1/1/01 1/1/94 1/1/04 3rd (3 years) 100 100 1/2/01-1/1/04 Page 13 of 89
V.C.Summ:rNuclar Station Second 10-YearInterval Inservice Examination Program Revision 1, Inspection Program B not only establishes the distribution and duration of the inspection periods within the VCSNS second 10-year interval, but also l establishes the distribution of examinations to be performed throughout the !
interval. With the exception of the examinations that may be deferred until the end of the inspection interval as specified in TablesIWX-2500-1, the required examinations in each Examination Category shall be completed as {
depicted in Figure 2.6-1 above.
2.6.1.2 Successive Examinations 1
Successive examination has two separate meaningsin ASME XI. One meaning deals with repeatability of exams from one interval to the next.
The other deals with reexamination of the same items at subsequent periods l for only those items requiring corrective measures or accepted for continual -
service via analytical evaluation, as applicable. Our approach to this aspect of successive exams is included in Section 3.2.2 of this program.
To the extent practical, the sequence of VCSNS component examinations j established during the first inspection interval will be repeated during the !
second 10-year inspection interval.
t Successive examinations will also be invoked in the event flaw indications in i VCSNS Class 1 and 2 components are evaluated as acceptable for continued service based on the results of an analytical evaluation. In this case, the area containing the flaw will be scheduled for re-examinations during (the) successive period (s) in accordance with Paragraphs IWB-2420 and IWC-2420 of the Code. I VCSNS Class 1,2, and 3 component supports, whose examinations result in '
unacceptable conditions requiring corrective measures, will be subject to successive reexaminations in accordance with Paragraph - 2420, of Code Case N-491. That is, component supports whose examinations reveal conditions unacceptable for continued service, thereby requiring corrective i action, will be re-examined during the next inspection period. l l
Page 14 of 89 I
l I
V.C.Summxr Nucisar St: tion l Second 10 YearInterval inservice Examination Program Revision 1, l Successive inspection requirements for VCSNS Class 1,2, and 3 integral attachments will be as per Relief Request RR-02. For Class 1 integral attachments, whose scheduled examinations reveal flaw indications which are evaluated as acceptable for continued service based on performance of an analytical evaluation, the rules of paragraph IWB-2420 will be applied; for Class 2 and 3 integral attachments, the rules ofIWC-2420 will be applied.
Ilowever, when unacceptable flaw indications are revealed during (unscheduled) examinations required as a result ofidentified component support deformation, SCE&G will perform and document an evaluation to ascertain the necessity of successive re-examinations of the flawed integral attachment (s).
Following completion of the required successive examination (s) for all affected VCSNS components, the examination schedules for those components containing flaw indications which have remained unchanged, and/or component supports requiring no further correction, will revert back to the original examination schedule.
2.6.1.3 Additional Examinations VCSNS Class 1 and 2 component examinations (excluding VT-2 visual examinations), performed in accordance with the routine examination requirements of this ISE Program, which reveal flaw indications which exceed the prescribed acceptance standards will be extended to include additional examinations in accordance with IWU-2430 and IWC-2430. IWD does not contain any additional examination requ irements for Class 3 components.
VCSNS Class 1,2, and 3, component support examinations requiring corrective measures will be extended to include additional examinations in accordance with Paragraph -2430 Code Case N-491.
2.6.1.4 Supplemental Examinations To assist in the evaluation of examinations of VCSNS compotants required by this ISE Program, particularly those examinations which detect flaws or the evidence of flaws, other examination methods and techniques, in Page 15 of 89
V.C. Summrr NucLar Station Second 10-YearInterval )
Inservice Examination Program Revision 1, addition to those specified in the Code may be employed. These supplemental examinations may serve to:
e confirm the existence of a flaw or flaws, e characterize the size, shape, orientation, and nature of the flaw (s), or e declare a component as acceptable for continued service following an acceptable supplemental examination.
2.7 EXAMINATION REQUIREMENTS i i
l VCSNS Class 1,2, and 3 components within the scope of this ISE Program l will be examined in accordance with the requirements specified in Tables 4
IWB-2500-1, IWC-2500-1, and IWD-2500-1, respectively, except as modified by relief requests. Component supports will be examined in accordance with {
the requirements found in Table 2500-1 of Code Case N-491; integral j attachments will be examined in accordance with Relief Request RR-02. The
{
applicable IWX-2500-1 tables were utilized by this ISE Program to define all i the parameters /information necessary for implementation of the VCSNS l component-by-component examination plan, including some or all of the following-e Examination Categories and the type of components to be included {
within the category, j e Item Numbers and a breakdown of the types of parts to be examined I within the Examination Category, '
e Examination requirement figures, e Examination methods, ;
I e Examination acceptance standards, i e Extent of examination (including selection criteria, if any), l e Frequency of examinations, and !
e Scheduling of examinations. ,
Page 16 of 89 i
l m_ F
V.C. Summir Nucitar Station Second 10-Year Interval Inr.ervice Examination Program Revision 1, 2.7.1 Examination Methods The three types of examination methods to be utilized during inservice examinations in accordance with this ISE Program are visual, surface, and volumetric. The examination method to be utilized in examination of specific VCSNS Class 1,2, and 3 components, or groups of components (except integral attachments), correspond with those specified in Tables IWX-2500-1 of the Code. Class 1,2, and 3 component support examination methods comply with those specified in Table 2500-1 of Code Case N-491; integral attachment examination methods are defined in ReliefRequest RR-02.
A variety ofexamination methods are available for accomplishing examinations specifying the surface or volumetric examination method.
The specific method specified for examination of VCSNS components was determined based on a variety of VCSNS-specific factors, such as:
e component design, e component material specification, e component physical access e ALARA considerations.
2.7.1.1 Visual Examination Visual examination types specified for use in this ISE Program are VT-1, VT-2, and VT-3. These examinations are defined in IWA-2210, and are summarized below: !
e VT-1 visual examinations will be conducted on designated VCS'N S ;
components to determine the condition of the part, component, or I surface examined. Such conditions include cracks, wear, corrosion, erosion, or physical damage on the surfaces of the parts or <
l components. VT-1 visual examinations will be performed either by !
direct or remote visual examination techniques, per IWA-2211.
l l
l 1
l l
l Page 17 of 89 !
1 I
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.. (
V.C. Summer Nuclear Station Second 10-YearInterval i Inservice Examination Program i Revision 1,
{
e VT-2 visual examinations will be conducted on designated VCSNS ;
components to locate evidence ofleakage from pressure retaining f components, or abnormal leakage from components with or without i leakage collection systems, as required during the conduct of system pressure testing. VT-2 visual examinations will be conducted in j accordance with IWA-5240 and IWA-5242. !;
e VT-3 visual examinations will be conducted on designated VCSNS components to determine the generalmechanical and structural condition of the components and component supports, including aspects such as:
?
- the verification of clearances / settings,
- physicaldisplacements, ,
- loose or missing parts, !
- debris, !
- corrosion, l
- wear,
- erosion, or j
- the loss ofintegrity at bolted or welded connections. l The VT-3 visual examinations will also include examinations for conditions that could affect operability or functional adequacy of snubbers and constant load and spring-type supports. This examination was formerly designated as VT-4 in the VCSNS first 10-year interval program. The VT-3 visual examination specified herein includes both the VT-3 and VT-4 visual I
- examination techniques performed during the first interval as referenced in I
the 77/S78 ASME Section XI Code. I 2.7.1.2 Surface Examination Surface examinations will be performed on designated VCSNS components to detect the presence of surface cracks or discontinuities. Surface examination techniques specified for use in this ISE Program are either magnetic particle (MT) or liquid penetrant (PT), depending on surface conditions, material specification, and component accessibility.
Page 16 of 89 i
s wnd ar at Inservice Examination Program Revision i, i Magnetic particle examinations will be conducted in accordance with the !
NDE requirements of Article 7 of ASME Section V (Reference 1.3.2.1.1). ;
Liquid penetrant examinations will be conducted in accordance with the !
NDE requirements of Article 6 of ASME Section V. l l
2.7.1.3 Volumetric Examination Volumetric examinations will be performed on designated VCSNS !
components to detect the presence of discontinuities throughout the required volume of the component material. Volumetric examination j
techniques available for use in this ISE Program are either radiographic '
(RT), or ultrasonic (UT). Ultrasonic examination techniques are the I
preferred volumetric examination techniques for VCSNS components.
Radiographic examination techniques are not specified for volumetric .
examination of any VCSNS components scheduled per this ISE Program; I however, radiography is a permissible volumetric examination technique and may be considered, as needed. ;
Radiographic examinations shall be conducted in accordance with the NDE !
requirements of Article 2 of ASME Section V (Reference ). Ultrasonic j examinations will be conducted in accordance with the NDE requirements of Mandatory AppendixI of the Code.
2.7.1.4 Alternative Examination Methods
{
f In accordance with IWA-2240, alternative examination methods, a s combination of examination methods, or newly developed examination techniques may be substituted for the methods specified in the Code, provided the ANII is satisfied that the results have been demonstrated to be i equivalent or superior to those of the Code specified method. An example of I an alternative method would be the use of acoustic emission. An example of !
an alternative technique would be the performance of high temperature j
liquid penetrant examination.
Page 19 of 89 i
V.C. Summer Nucitar Station
- C.
Second 10-YearInterval eco Inservice Exammation Program aser Revision 1, *vi 2.7.2 Extent of Examination Extent of examination refers to the boundaries within which the 2, r examination requirements of the Code are to be applied, such as the number mi and type of components selected for examination, and including the surfaces, on<
areas, or volumes, within the selected components where the specified .in examination methods are to be directed. The extent of examination of om VCSNS Class 1,2, and 3 components have been established in accordance 2pS with Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1 (pressure testing nei only) of the Code; Table 2500-1 of Code Case N491, establishes the extent of examination for Class 1,2, and 3 component supports. ReliefRequest RR-02 r se provides extent of examination for Class 1,2, and 3 integral attachments. '.e1
>f t 2.7.2.1 Selection of Components For Examination isti All VCSNS components within the scope of this ISE Program are subject to Code requirements; however, the Code employs specific " selection criteria",
such that for many Code Examination Categories and Items, only those components which meet this criteria are required to be examined in sei accordance with Code rules. m e-
- me The specific criteria utilized in selection of VCSNS components for /D-examination during the second inservice inspection interval is addressed in VC-Sections 5.0,6.0, and 7.0 of this ISE Program. A quantitative summary of y' selected components is also provided in these sections. Note, however, that n cc the selections provided represent the initial component selections for the second 10-year inspection interval. Throughout the interval, changes in plant configuration resulting from plant repairs, replacernents, or ;uir modifications, and revisions to the ISE Program, may require revision of ice -
these selections to ensure continued conformance to Code requirements, iont l Unless otherwise stated, the selections provided represent the minimum number of component selections necessary to satisfy the Code requirements.
Page 20 of 59
m__< ~; ._ _ - _ _ _ _ _ . _ - _ _
V.C.Summir Nuchar Station Second lo YearIntarval Inservice Examination Program Revision 1, 2.7.2.2 Multiple-Component Concept Multiple components, as defined in this ISE Program, refers to a grouping of like components based on similarities in design parameters, and/or function within their respective system. The " multiple-component concept"is used freqvently in the selection of nonpiping components in a variety of Code Examination Categories. Basically, for a multiple-component group (i.e., ,
multiple nonpiping components, such as valves, pumps, heat exchangers, etc.), the Code allows for selection of only one component from the group of these multiple components for examination.
Where the multiple-component concept is applied for selections of VCSNS components,it is so noted under the appropriate Code Examination ;
Category / Item Number in Sections 5.0,6.0, and 7.0 of this ISE Program.
Appendix B contains a complete identification and listing of all VCSNS i multiple-component groups.
2.7.2.3 Examination Requirements Figures The required surfaces, areas, or volumes, within the selected VCSNS components and supports, where the specified NDE methods are to be directed are illustrated by the Examination Requirements Figures IWB-2500-1 through 18,IWC-2500-1 through 13,IWD-2500-1, and IWF-1300-1, as referenced in Tables IWB-2500-1, IWC-2500-1, IWD-2500-1 (Relief Request RR-02), and IWF-2500-1 respectively. These figures will be utilized to determine whether adequate examination coverage has been obtained.
Surfaces, areas, or volumes of which 100% of the required surfaces, areas, or volumes cannot be completely examined in accordance with the t Examination Requirements Figures will be dispositioned by one of the i following:
e alternative examination methods /tec!ntiques, ,
e alternative component selections, Page 21 of 89
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V.C. Summer Nuclar Station Second 10-YearInterval I Inservice ExaminationProgram Revision 1, e acceptance of reduced examination coverage in accordance with Code Case N-460, and/or e preparation of a relief request tojustify acceptance of the reduction in coverage.
2.7.2.3.1 ASME Code Case N 460 F
Reduced examination coverage of VCSNS Class 1 and 2 welds will be ,
evaluated in accordance with ASME Code Case N-460, adopted by this ISE Program (See 4.0). In accordance with Code Case N-460, reduced examination coverage of Class 1 and 2 welds due to interference by another component or geometry of the part may be accepted, provided the reduction in coverage is less than 10%. VCSNS Class 1 and 2 weld examinations in which the examination coverage exceeds 90% of the required surfaces, }
areas, or volumes willbe considered " essentially complete" 2.8 EXAMINATION EVALUATION i
Flaws detected during ISE examinations or preservice examinations of VCSNS Class 1,2, and 3, components and component supports will be characterized and evaluated in accordance with the standards for examination evaluation in Article IWA-3000 of the Code.
Evaluation of flaws willinclude comparison of the examination results with:
e the recorded results of preservice examinations (if any) and prior inservice examinations (if any), and e the applicable Code examination acceptance standards (See ).
Verified changes of known flaws from prior examinations shall be recorded in accordance with the Code.
1 l
Page 22 of 89 1
l
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.-- ~ .--
V.C. Summer Nucbar Station Second 10-YearInterval Inservice Examination Program Revision 1.
VCSNS Class 1,2, and 3 component examination results, with flaws which exceed the specified acceptance standards, may be evaluated as acceptable for continued service by analytical evaluation. Analytical evaluation of flaws will be conducted in accordance with IWB-3600, IWC-3600, or IWD-3000. Also,in accordance with Code Case N-491, component supports which do not meet acceptance standards may also be analyzed to substantiate the supports' integrity for its intended service.
2.9 EXAMINATION ACCEPTANCE STANDARDS Examinations performed on VCSNS components will be evaluated by comparison of the examination results with examination acceptance standards, typically provided in the Code Articles IWX-3000. Acceptance standards to be utilized are as referenced in Tables IWX-2500-1 for Class 1, 2, and 3 components; component support acceptance standards are as referenced in Table 2500-1 from Code Case N-491 and integral attachment acceptance standards are as referenced in Relief Request RR-02.
Where acceptance standards for a particular component are not available in the Code, flaws detected may be evaluated in accordance with acceptance standards applicable to the construction of the component, such as ASME Section III or the component design specifications. Flaw disposition in this manner will be fully documented and is subject to review byjurisdictional regulatory and enforcement authorities. :
VCSNS Class 1,2, and 3 cornponents whose examinations reveal flaw indications which exceed the specified acceptance standards or exhibit unacceptable conditions shall be unacceptable for continued service until j the unacceptable condition is rectified in accordance with the Code.
1 Page 23 of 89 l
V C.Summxr Naciatr Station l Second 10-Year Intervs! i Inservice Examination Program
[
Revision 1 2.10 ISE DRAWINGS l The ISE drawings are a collection of VCSNS plant-specific drawings !
designed to facilitate implementation and documentation of this ISE }
Program. The ISE drawings consist of the:
e ISE Classification and Boundary Identification drawings, (Piping [
System Flow Diagrams depicting nonexempt ISE boundaries) e ISE Composite (Isometric) Sketches, (weld maps and component sketches) s The ISE drawings, intended solely for inservice examination, have been l prepared from the VCSNS plant design drawings, and are controlled and i maintained as ISE record's. !
1 Tables listing the drawings applicable to the ISE Program are found in ;
Appendix C.
2.10.1 ISE Classification and Boundary Identification Drawings i
The systems or portions of systems subject to the examination of the ISE !
Program for VCSNS and the associated Class 1,2, and 3 boundaries are f
documented on Piping System Flow Diagrams - the ISE Classification I t
Boundary Drawings. These drawings graphically: :
e establish the VCSNS boundaries within which the ASME Section XI !
rules are applied;
{
i e define the ISE classification (Class 1,2, or 3 equivalent to 1,2a,2b) !
assigned to systems / components within the ISE boundaries; and ,
e illustrate specific systems /cornponents within the ISE boundaries which are exempt from certain Section XI requirements via Code- l allowed exemptions. i f
?
f i
Page 24 of 89 I l
V.C. Summer Nuclar Station j Second 10-YetrIntervel Inservice Exammation Program Revision 1, 2.10.2 ISE Composite (Isometric) Sketches l
The ISE Composite Sketches are drawings prepared from the VCSNS plant design drawings to locate, and uniquely identify, all Class 1 and 2 non-exempt welds, and equipment within the scope of the ISE Program boundaries.
The weld identification composite sketches, modeled similar to the VCSNS piping fabrication isometrics, illustrate the location of all nonexempt circumferential and longitudinal butt welds, socket welds, branch connection welds, and Class 1 and 2 integrally welded attachments associated with supports, within the scope of the ISE Program. Unique ISE identification numbers for each weld on the drawing are also provided. The weld identification numbers are utilized for documentation of Code nondestructive examinations, and also, provide traceability to records of previous nondestructive exarninations of the welds, both PSI /ISE and during plant construction. l The component detail composite sketches illustrate all nonexempt welds, bolting, and integral attachments on Class 1 and 2 VCSNS plant equipment d e.g. RPV, heat exchangers, pumps, etc.) within the scope of the ISE Program. These drawings have been compiled from the equipment supplier's design drawings and records. As with the weld identification composite sketches, all ISE components are located and uniquely identified.
2.11 RECORDS AND REPORTS 2.11.1 ISE Database In order to control the monutuental task of managing the data necessary to define and implement the VCSNS ISE Program, a computer database is utilized. The database is maintained as a listing of all nonexempt components within the ISE Program scope, including the related Code requirernents pertinent to each of the components. Moreover, the ISE database is used to schedule and track nondestructive examinations.
Pace 25 of 89
V C. Summer Nucir.r Station Second 10 Yeer Intervel Insernce Examination Program Revision i, The ISE database is a controlled access database and is maintained as-built for components within the ISE boundaries.
2.11.2 Inservice Inspection Outage Summary Report Following the completion of an inservice inspection conducted during a VCSNS plant refueling and inspection outage, SCE&G will prepare the
" Inservice Inspection Summary Report"in accordance with the applicable requirements of Article IWA-6000. Note however,in addition to the Code requirements, the scope of the subject report may be optionally expanded by SCE&G to provide a more comprehensive outage report, including such areas as:
e Class 3 component examinations e Augmented inservice inspections e Technical Specification snubber functional testing As such, the VCSNS " Inservice Inspection Summary Report" will, typically, address the following-e Piping and components examinations e Reactor pressure vessel examinations e System pressure tests e Snubber functional tests e Snubber visualexaminations e ASME repairs and replacements, including Form NIS-2 The " Inservice Inspection Summary Report" will be submitted along with Form NIS.1, " Owners Report for Inservice Inspections", found in Mandatory Appendix II of the Code and Form (s) NIS-2 if any repairs or replacements 1 have been performed.
The " Inservice Inspection Summary Report" will be submitted within 90 days of completion of the inservice examination conducted during a VCSNS plant refueling outage, and will include all examinations, tests, repairs, and replacements performed since the preceding summary report.
Page 26of 89 l
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V.C. Summer Nuclar Station
- Second 10-YearInterval i Inservice Examination Program Revision 1, 3.0 EXEMPTIONS AND POSITION STATEMENTS :
3.1 CODE ALLOWED EXEMPTIONS
[
The Code rules and requirements allow certain Class 1,2, and 3 components f or portions of components (and/or their component supports), which meet !
certain conditions specified in the Code, to be exempt from certain examination requirements of the Code. The specific Code exemptions which have been applied to this ISE Program are detailed below. !
3.1.1 Class 1 (IWB) Exemptions Class 1 exemptions are taken directly from the Code, Paragraph IWB 1220.
VCSNS Class 1 components, within the scope of this ISE Program, and which meet the following conditions, have been exempted from the volumetric and surface examination requirements of Subarticle IWB 2500:
3.1.1.1 Piping of NPS 1 and smaller, along with components and their connections in piping of NPS I and smaller.
3.1.1.2 Reactor vessel head connections and associated piping, NPS 2 and smaller, +
made inaccessible by control rod drive penetrations. [
3.1.2 Class 2 (IWC) Exemptions Class 2 exemptions are taken directly from the Code, paragraphs IWC-1220, IWC-1221,IWC-1222, and IWC-1230.
VCSNS Class 2 components, within the scope of this ISE Program, and which meet the following conditions, have been exempted from the volumetric and surface examination requirements of Subarticle IWC-2500:
- .1.2.1 Components within VCSNS Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) Systems i
e Vessels, piping, pumps, valves, and other components NPS 4 and smaller in all systems except High-Pressure Safety Injection Systems.
Page 27 of 89
V.C Summ:r Nucirr Station Second 10-Year Interval Inservice Examination Program Revision 1, e Vessels, piping, pumps, valves, and other components NPS 1-1/2 and smaller in High-Pressure Safety Injection Systems.
e Cornponent connections NPS 4 and smaller (including nozzles, socket fittings, and other connections) in vessels, piping, pumps, valves, and other components of any size in all systems except High-Pressure Safety Injection Systems.
e Component connections NPS 1-1/2 and smaller (including nozzles, socket fittings, and other connections) in vessels, piping, pumps, valves, and other components of any size in High-Pressure Safety Injection Systems.
e Vessels, piping, pumps, valves, other cornponents, and component connections of any size in statically pressurized, passive (i.e., no pumps)
Safety Injection Systems.
e Piping and other cornponents of any size beyond the last shutoff valve in open-ended portions of systems that do not contain water during normal plant operating conditions.
3.1.2.2 Components within VCSNS Systems (or Portions of Systems) other than RHR, ECC, and CHR Systems e Vessels, piping, pumps, valves, and other components NPS 4 and smaller, o Component connections NPS 4 and smaller (including nozzles, socket fittings, and other connections)in vessels, piping, pumps, valves, and other components of any size, Page 28 of 69 b
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4 V.C. Summer Nuclxr Station Second 10-Yearinterval ;
Inservice Examination Program [
Revision 1 !
e Vessels, piping, pumps, valves, other components, and component I connections of any size in systems or portions of systems that operate l t
(when the system function is required) at a pressure equal to or less ;
than 275 psig and at a temperature equal to or less than 200cF.
{
e Piping and other components of any size beyond the last shutoff valve :
in open-ended portions of systems that do not contain water during i normalplant operating conditions. l 3.1.2.3 VCSNS piping support members and piping support components (in all l
Class 2 systems within the scope of this ISE Program) that are encased in f
concrete shall also be considered exempt (Refer also to Paragraph 3.2.1.4). !
3.1.3 Class 3 (IWD) Exemptions l
The only exemptions associated with Class 3 systems are contained in section 3.1.5.2. ,
i 3.1.4 Class 1,2, and 3 Component Support Exemptions ;
i l
In accordance with Code Case N-491, component supports (piping and non-piping) connected to VCSNS Class 1,2, and 3 components that are exempted from examination in accordance with IWB 1220,IWC-1220, and IWD-1220 shall be considered exempt from the requirements of 2500 of Code Case
, N-491. In addition, portions of supports that are inaccessible by being encased in concrete, buried underground, or encapsulated by guard pipe, are also exempt from the examination requirements of-2000 of Code Case N-491. '
3.1.5 Class 1,2, and 3 Intecral Attachments Exemptions VCSNS integral attachments to Class 1 and 2 components within the scope of this ISE Program, are subject to the alternative examination requirements, including the exemption criteria, found in Relief Request RR-02. !
Page 29 of 89 i
_ _ _ _. - _ _ _ _ . _ ~ _
t secono Au a ser Amerve Innervica Enminsti:n Program -
, Revision 1, 3.1.5.1 Integral attachments of Class 1 and 2 components, exempted in accordance '
with IWB 1220 and IWC-1220, shall be considered exempt from the ,
alternative examination requirements of Relief Request RR-02.
3.1.5.2 Class 3 integral attachment exemptions are taken directly from the Code, ,
Paragraph IWD-1220. VCSNS Class 3 integral attachments within the :
scope of this ISE Program, and which meet the following conditions, have l been exempted from the alternative examination requirements of Relief Request RR-02: !
e VCSNS Class 3 integral attachments of supports and restraints to >
components that are NPS 4 and smaller within the system boundaries of Examination Categories D-A, D-B and D-C of Table IWD-2500-1, except for Auxiliary (Emergency) Feedwater Systems, shall be exempt from VT-3 visual examination. !
e VCSNS Class 3 integral attachments of supports and restraints to components that exceed NPS 4 within the system boundaries of Examination Categories D-A, D-B and D-C of Table IWD-2500 1 shall be exempt from VT-3 visual examination provided: ;
the components are located in systems, or portions of systems, whose function is not required in support of reactor residual heat removal, containment heat removal, and emergency core cooling, and the components operate at a pressure of 275 psig or less and at a temperature of 200*F or less.
3.2 SCE&G POSITION STATEMENTS AND CLARIFICATIONS i
in some cases, certain Code rules and requirements,in SCE&G's opinion, are subject to interpretation and, therefore, require further clarification on l their use. The following " Position Statements and Clarifications" have been l
included to discuss / clarify SCE&G's interpretation and intended application of the subject Code rules in this ISE Program.
i Page 30 of 89
V.C. Summtr Nucler Station Second 10-Year Interval Inservice Examination Program Revision 1, 3.2.1 Exemptions 3.2.1.1 Class 2/3 Nonpiping Component Exemptions In addition to the Class 2 and Class 3 exemptions listed in , step 3.1.4, and above, nonpiping component size exemptions shall be based. on the following: Nonpiping components having a cumulative inlet and a cumulative outlet nominal cross-sectional area, neither of which exceeds the nominal cross-sectional area of the applicable exemption size, shall be exempted from the surface and volumetric examination requirements of IWC-2500 and IWD-2500.
SCE&G's position on component exemptions is based on the clarification made by footnote 1 ofIWC-1220 and IWD-1220 in the 1989 Addenda to ASME Section XI. When applying this criteria,it is assumed that it is not the intention of the Code to accumulate the cross-sectional areas of piping from different fluid systems entering a given component when~each fluid system has separate pressure boundaries within that component.(e.g., heat exchanger shell and tube sides).
3.2.1.2 Class 3 Integral Attachment Exemptions In addition to the Class 3 exemptions listed in above, integral attachments of supports and restraints to components that are NPS I and smaller for the Auxiliary (Emergency) Feedwater System, within the system boundaries of Examination Categories D-A, D-B, and D-C of Table IWD-2500-1, shall be exempt from the visual examination, VT-3. This position is based on the minimum size exemption given for Class 1 piping and components.
3.2.1.3 Storage Tank Exemptions Tanks vented to the attnosphere, and their associated piping to the first isolation valve shall be defined as a " storage tank." Based on ASME Interpretation: XI-1-89-51, storage tanks will not be subject to volumetric or surface examinations. Storage tanks will be included within the scope of applicable visual exams.
Page 31 of 89
V.C. Summer Nuclea Station
- Second 10-Yes.rInterval Inservice Examination Program Revision 1,
?
3.2.2 Successive Inspections - First Interval verses Second Interval In accordance with Paragraphs IWB-2420 and IWC-2420, the sequence of component examinations established during the first inservice inspection ,
t interval shall, to the extent practical, be repested during the second 10-year
- inspection interval. As such, to facilitate conformance with Code requirements, the following guidelines will be applied when scheduling examinations for the second inservice inspection interval:
l e Examinations will be scheduled for the same period, (i.e. an examination performed during the first period of the first inspection interval will be scheduled for the first period of the second .
inspection interval), l e The requirements ofIWB-2420 and IWC-2420 may not be practical ;
for those Examination Categories where the selection criteria has l
changed dramatically from the first interval to the second interval ,
(e.g. Examination Category C-F verses C F-1/C F 2). All components may not be reselected thereby, making it impractical to repeat the examination sequence. In this case, scheduling will be handled on a case-by-case basis. '
3.2.2.1 Reexamination of Components Initially Selected for Examination During The First Inservice Inspection Interval
- In many Examination Categories throughout Table IWC-2500-1, a note stating that the components " selected for the initial examination shall be reexamined over the service lifetime of the component". This requirement is interpreted to be applicable only for those Examination Categories where the Code examination requirements of the fh onservice inspec*, ion interval, which used the 77S78 Code, remained essentially unchanged in this second interval using the 1989 Code. As such, components selected for examination during the first inservice inspection interval should be reselected for examination during the second inservice inspection interval. j Page 32 of 89
V.C. Summer Nuckrr Stadon Second 10 YmrInterval Inservice Examination Program Revision i, Examination Categories in which examination requirements, including the selection criteria, have changed significantly from the first inservice inspection interval are considered excluded from this requirement.
Note, this position also applies to Note 4 of Table 2500-1, Examination Category F.A of Code Case N-491 which states;"To the extent practical, the same supports selected for examination during the first inspection interval shall be examined during each successive inspection interval."
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V.C. Summer Nuclzar Station Second 10 YearInterval Inservice Examination Program Reviuon 1, 4.0 ASME CODE CASES The ASME periodically publishes Code Cases to ASME Section XI. These
, Code Cases are issued to clarify the intent of existing Code rules, to provide alternative rules to existing Code rules, or to provide timely rules and requirements for circumstances not covered by existing Code rules.
Adoption of various pertinent Code Cases allows the ISE program ths advantages of these alternative rules / clarifications prior to their later integration into Code requirements.
All Code Cases intended to be used during the inservice inspection interval must be identified in the ISE program and are subject to acceptance by the jurisdictional regulatory and enforcement authorities.
The Code Cases applicable to the 1989 Code Edition to be used during the VCSNS second 10-year inspection interval are identified in the following section.
4.1 CODE CASES ENDORSED BY USNRC REGULATORY GUIDE 1.147, REVISION 10
- TSNRC Regulatory Guide 1.147 periodically provides an updated listing of tne ASME Section XI Code Cases that are generally acceptable to the NRC for implementation in the ISE program. The Code Cases adopted by this ISE Program which have been endorsed by USNRC Regulatory Guide 1.147, Revision 10, are listed as follows
4.1.1 N-307-1, Revised Ultrasonic Examination Volume for Class 1 Bolting, Table IWB-2500-1, Examination Category B-G-1, When the Examinations Are Conducted From the Center Drilled Hole.
I 4.1.2 N-457, Qualification Specimen Notch Location for Ultrasonic Examination of Bolts and Studs 4.1.3 N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds Page 34 of 89
V.C. Summer Nuclear Station
, Second lo YearInterval inservice Examination Program Rension 1.
4.1.4 N-461, Alternative Rules for Piping Calibration Block Thickness 4.1.5 N-491, Alternative Rules for Examination of Class 1,2,3, and MC -
Component Supports of Light-Water Cooled Power Plants,Section XI, Division 1 4.2 CODE CASES NOT ENDORSED BY USNRC REGULATORY GUIDE 1.147, REVISION 10 4.2.1 N-509, Alternative Rules for the Selection and Examination of Class 1,2, and 3 Integrally Welded Attachments,Section XI, Division 1 Note: Approval for use of this Code Case is addressed in Relief Request RR-02.
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, V.C. Summer Nuclear Station Second 10. Year Interval inservice Examination Program Revision 1, !
5.0 ISE PROGRAM WELDS AND COMPONENTS i
This section herein summarizes the Code requirements applicable to <
VCSNS Class 1,2, and 3 welds and components. Code Examination Categories and/or Item Numbers not applicable to VCSNS have been ,
intentionally excluded.
NOTE:Where the Code only specifies a general examination method (i.e.,
surface or volumetric), SCE&G has identified a specific NDE method expected to be utilized, based on the type of material and examinations performed during the first interval. Although unlikely, the specific NDE method used may be changed during the inspection interval, as allowed by the Code. ,
5.1 CLASS 1 COMPONENTS I 5.1.1 Examination Category B A, Pressure Retaining Weldsin Reactor Vessel 5.1.1.1 Shell Welds, Item Numbers Bl.11, and Bl.12 In accordance with Table IWB-2500-1, Examination Category B-A, ,
essentially 100% of the weld length of all VCSNS circumferential and longitudinal reactor vessel shell welds will be volumetrically (UT) examined during the second 10-year inspection interval.
5.1.1.2 Head Welds, Item Numbers Bl.21, and Bl.22 In accordance with Table IWB-2500-1, Examination Category B A, the accessible length (essentially 100% of the weld length) of all VCSNS reactor vessel circumferential and meridional head welds will be volumetrically (UT) examined during the second 10 year inspection interval. While the Code permits these examinations to be deferred to the end of the interval, individual weld examinations will be scheduled to parallel the sequence of examinations established during the first interval, where practical.
Page 36 of 89
l V.C. Summer Nuebar Station Second 10 Year Interval Inservice Examination Program j Revision i, 5.1.1.3 Shell to Flange Weld, Item Number Bl.30 In accordance with Table IWB 2500-1, Examination Category B-A, essentially 100% of the weld length of the VCSNS reactor vessel shell-to-flange welds will be volumetrically (UT) examined during the second
)
10-year inspection interval. The required examinations are to be coropleted j in accordance with the scheduling requirements of Paragraph IWB-2412, l Inspection Program B, however, the alternative scheduling requirements of Table IWB-2500-1, Notes 3 and 4, may be utilized to partially defer thi:
examination to the end of the inspection interval. Where practical, this h examination will be scheduled to parallel the sequence of examinations established during the first interval. :al se 5.1.1.4 Head to Flange Weld, Item Number Bl.40 In accordance with Table IWB-2500-1, Examination Category B-A, essentially 100% of the weld length of the VCSNS reactor vessel head-to-flange weld will be volumetrically (UT) and surface (MT) examined during the second 10-year inspection interval. The required examinations are to be completed in accordance with the scheduling requirements of Paragraph i IWB-2412 Inspection Program B, however, the alternative scheduling requirements of Table IWB-2500-1, Note 3, may be utilized to partially defer .d this examination to the end of the inspection interval. Where practical, this examination will be scheduled to parallel the sequence of examinations established during the first interval.
5.1.1.5 Examination Category B A Summary Number of Number of Components Remarks item Number Selected for Components Examination B 1.10 B1.11 3
Examine at end ofinterval
'"*""' 3 Shell Welds '
6 6 Examine at end of interval n t dinal 0 1 1 Examine at end of interval
_,Circumf'erential Head Welds B1.22 6 6 Examine at end of interval Meridional
, Partial deferral allowed per -
B1.30 Shell-to-Flange Weld 1 1 notes 3 of IWB-2500.
Pa d alaH wed er B1.40 Head-to-flange Weld 1 1 ,
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V.C. Summir Nuctrar Station Second 10 YearIntrrva!
Inservice Examination Program Revision 1 I l
5.1.2 Examination Category B-B. Pressure Retaining Welds in Vessels Other
]
Than Heactor Vessels l l
5.1.2.1 Pressurizer Shell to IIcad Welds, Item Numbers B2.11, and B2.12 In accordance with Table IWB-2500-1, Examination Category B-B, essentially l
100% of all VCSNS circumferential shell-to-head welds, and one foot ofone longitudinal weld per head (intersecting the circumferential weld) will be volumetrically (UT) examined during the second 10-year inspection interval. The ;
required examinations will be performed in accordance with the scheduling requirements of paragraph IWB-2412, Inspection Program B and, where practical, will be scheduled to parallel the sequence of examinations established during the first interval.
5.1.2.2 Steam GeneratorTubesheet to IIcad Welds, Item Number B2.40 In accordance with Table IWB-2500-1, Examination Category B-B, essentially 100% of one VCSNS tubesheet-to-head weld of one of the three steam generators (multiple-component concept) will be volumetrically (UT) examined during the second 10-year inspection interval. The required examinations will be performed in accordance with the scheduling requirements of paragraph IWB-2412, Inspection Program B.
5.1.2.3 Examination Category B B Summary Number of Number of Compone ts item Number Remarks Components Examination item Number B2.11 2 2 Pressurizer Shell-to-Head Welds item Number 82.12 Pressurizer LongitudinalWelds 3 2 Item Number B2.40 SIG Tubesheet-to-Head Welds 3 1 Page 38 of 89
Vf. Summer Nuclear Station ,
Second 10-Year Interval inr.ervice Exammaion Program i Revision 1, i
5.1.3 Examination Category B D, Full Penetration Welds of Nozzles in '
Vessels -Inspection Program B 5.1.3.1 Reactor Vessel Nozzle-to Vessel Welds, Item Number B3.90 In accordance with Table IWB-2500-1, Examination Category B-D, all i VCSNS reactor vessel full penetration nozzle-to-vessel welds will be volumetrically (UT) examined during the second 10-year inspection interval.
Relief Request 1-RPV-1 was approved in the first interval by the NRC. This i Relief Request allows the reactor vessel nozzle examinations required by I categories B-D, B-F and B,J to be deferred to the end of the second interval and all subsequent intervals. Therefore,100% ofitem B 3.90 welds will be completed at or near the end of the interval. A portion of the required !
examination volume for these welds may be deferred to the end of the inspection interval,in accordance with the requirements of Table IWB-2500-1, Note 3. Individual weld examinations, where practical, will be scheduled to parallel the sequence of examinations established during the first interval.
5.1.3.2 Reactor Vessel Nozzle Inside Radius Section, Item Number B3.100 t
In accordance with Table IWB-2500-1, Examination Category B-D, all VCSNS reactor vessel nozzle inside radius sections (of nozzles to be examined per Item B3.90 above) will be volumetrically (UT) examined during the second 10-year inspection interval. The required examinations will be scheduled to be completed coincident with the examinations ofItem B3.90 l above.
5.1.3.3 Pressurizer Nozzle to-Vessel Welds, Item Number B3.110 In accordance with Table IWB 2500-1, Examination Category B-D, all l
VCSNS pressurizer full penetration nozzle-to-vessel welds will be !
volumetrically (UT) examined during the second 10 year inspection interval.
The required examinations will be completed such that at least 25%, but not more than 50% of the nozzles will be examined by the end of the first inspection period. The remaining examinations will be completed by the end of the interval. Individual weld examinations, where practical, will be scheduled to parallel the sequence of examinations established during the first interval.
Page 39 of 89
V.C. Summer Nuclu.r Station Second 10'YearInterval Inservice Examination Program Revision 1, 5.1.3.4 Pressurizer and Steam Generator Nozzle Inside Radius Section, Item Numbers B3.120, and B3.140 In accordance with Table IWB-2500-1, Examination Category B-D, all VCSNS pressurizer and steam generator nozzle inside radius sections will be volumetrically (UT) examined during the second 10-year inspection interval.
The required examinations will be completed such that at least 25%, but not more than 50% of the nozzles will be examined by the end of the first inspection period, and will typically be completed coincident with the examinations ofItem B3.110 above. Similarly, the remaining examinations will be completed by the end of the interval. Note: The steam generators have integrally cast nozzles and, therefore, no nozzle to vessel welds (Item B3.130).
5.1.3.5 Examination Category B-D Summary Number of Number of Components item Number Remarks Components Selected for Examination item Number B3.90 6 6 Deferral to end of interval is allowed Rector Vessel per first interval Relief Request Nozzle-to-VesselWelds 1-RPV-1.
Item Number B3.100 6 6 Examination to be conducted in Rector Vessel Nozzle conjunction with item B3.90 inside Radius Section item Number B3.110 6 6 Pressurizer Nozzle-to-Vessel Welds Item Number B3.120 6 6 Pressurizer NozzleInside Radius Section item Number B3.140 6 6 5/G Nozzle inside Radius l , Section l
Page 40 of 89
V.C. Summer Nuclear Station Second 10-Yee Interval Inservice Examurtion Program Revision 1, 5.1.4 Examination Category B-F, Pressure Retaining Dissimilar Metal Welds ;
5.1.4.1 Reactor Vessel Nozzle to Safe End Butt Welds - NPS 4 or Larger, Item '
Number B5.10 In accordance with Table IWB-2500-1, Examination Category B-F, all VCSNS reactor vessel nozzle-to-safe end dissimilar metal welds - NPS 4 or 3 larger - will be volumetrically (UT) and surface (PT) examined during the l second 10-year inspection interval. In accordance with Table IWB-2500-1, , ,
Note 2, the required examinations may be performed coincident with the g vessel nozzle examinations of Examination Category B-D, Item B3.90 (Reference 5.1.3.1 ). ,;
5.1.4.2 Pressurizer & Steam Generator Nozzle-To-Safe End Butt Welds NPS 4 or Larger, Item Number B5.40 and B5.70 In accordance with Table IWB-2500-1, Examination Category B-F, all I. ,
VCSNS pressurizer and steam generator nozzle-to-safe end dissimilar raetal '!
welds - NPS 4 or larger - will be volumetrically (UT) and surface (PT) examined during the second 10-year inspection interval. The required examinations will be performed in accordance with the scheduling requirements of Paragraph IWB-2412, Inspection Program B and, where practical, will be scheduled to parallel the sequence of examinations established during the first interval. j 5.1.4.3 Examination Category B-F Summary Number of
, Number of Components Remarks Components Selected for Examination B 5.10 Reactor Vessel 6 6 May be performed coincident with Nozzle to Safe End Butt B-D, B3.90 examinations Welds NPS 4 or Larger i B 5.40 Pressurizer No?zle-to- 6 6 Safe End Dissimilar Metal l Butt Welds NPS 4 or carger ;
B5.70 5/G Nozzle-to-Safe End 6 6 Dissimilar Metal B utt Welds i NPS 4 or Larger l
1 Page 41 of 89 l
V.C. Summer Nuctsar Station Second 10 YearIntsrval inservice Examination Program Re isioni, 5.1.5 Examination Category B G-1, Pressure Retaininr. Bolting, Greater Than 2 in. In Diameter 5.1.5.1 Reactor Vessel Closure Head Nuts, Item Number B6.10 l In accordance with Table IWB-2500-1, Examination Category B-G-1, all VCSNS reactor vessel closure head nuts will receive a surface (MT) examination during the second 10-year inspection interval. The required examinations will be completed in accordance with the scheduling requirements of Paragraph IWB-2412, Inspection Program B, and where practical, will be scheduled to parallel the sequence of examinations established during the first interval.
5.1.5.2 Heactor Vessel Closure Stude in Place, Item Number B6.20 In accordance with Table IWB-2500-1, Examination Category B-G-1, reactor vessel studs may be examined either in place (under tension), when the connection is disassembled, or when the studs are removed. All VCSNS reactor vessel studs will be examined during the second 10-year inspection interval. When the stud (s) are to be examined in place, a volumetric (UT) examination will be performed. Examination ofreactor vessel studs, in place, will be scheduled in accordance with the Paragraph IWB-2412, Inspection Program B, however,if the studs are removed they will be examined per the requirements ofitem B6.30.
5.1.5.3 Reactor Vessel Closure Studs When Removed, Item Number B6.30 In accordance with Table IWB-2500-1, Examination Category B-G-1, reactor vessel studs shall be examined when the studs are removed during the second 10-year inspection interval. All VCSNS reactor vessel studs will be examined . Both volumetric (UT) and surface (MT) examinations will be performed.
5.1.5.4 Heactor Vessel Threads in Flange, Item Number B6.40 In accordance with Table IWB-2500-1, Examination Category B-G-1, the threads in VCSNS reactor vessel flange stud holes are to be examined volumetrically (UT) during the second 10-year inspection interval. The required examinations will be completed only in the event the connections are disassembled.
Page42 of 89
. V.C. Summer Nucicer Ststion Second 10.YearInterval inservice Examination Program Revision 1, 3.1.5.5 Reactor Vessel Closure Washers and Bushings, Item Number B6.50 In accordance with Table IWB-2500-1, Examination Category B-G-1, the VCSNS reactor vessel stud closure washers and bushings will be visually (VT-1) examined during the second 10-year inspection interval. These examinations are to be accomplished in accordance with the scheduling requirements of Paragraph IWB-2412, Inspection Program B and, where practical, will be scheduled to parallel the sequence of examinations established during the first interval.. The required examinations of bushings will be accomplished only in the event the connections are disassembled.
5.1.5.6 Pump Bolts and Studs Greater Than 2 in. In Diameter, Item Number
- B6.180
- In accordance with Table IWB-2500-1, Examination Category B-G-1, VCSNS pump bolts / studs will be volumetrically (UT) examined during the second 10-year inspection interval. The Reactor Coolant Pumps are the only pumps applicable to Item B6.180. Per Note 3 (Table IWB-2500-1),"For ..
! pumps, ... examinations are limited to components selected for examination i
under Examination Categories ... B-L-2, .. ." Referring to Examination Category B-L-2, Pump Casings, the multiple-component concept applies, and examinations are limited to one pump per multiple-component group (i.e.,
one Reactor Coolant Pump). See Appendix B for multiple-cornponent group listings.
The required examinations may be performed with the bolting in place (under tension), when the connection is disassembled, or when the bolting is removed. Bolting examinations are to be completed in accordance with the scheduling requirements of Paragraph IWB-2412, Inspection Program B and, where practical, examinations will be scheduled to parallel the sequence of examinations established during the first interval.
5.1.5.7 Pump Flange Surfaces, Item Number B6.190 In accordance with Table IWB-2500 J, Examination Category B-G-1, VCSNS pump flange surfaces (1 in. annular surface of flange surrounding each stud) will be visually (VT-1) examined only if the flange connection is disassembled. The Reactor Coolant Pumps are the only pumps applicable to Item B6.190. Per Note 3 of Table IWB-2500-1 (which refers to Category B-L 2 concerning multiple components selected for examination), the required examinations will be limited to one Reactor Coolant Pump.
Page43 of 89
. V C. Summer Nuclear Station becond 10-Year Interval inservice Examination Program Revision 1, 5.1.5.8 Pump Nuts, Bushings, and Washers, Item Number B6.200 In accordance with Table IWB-2500-1, Examination Category B-G 1, VCSNS pump nuts, bushings, and washers will be visually (VT-1) examined during the second 10-year inspection interval. The Reactor Coolant Pumps are the only pumps applicable to Item B6.200 and, as with Items B6.180 and B6.190, the multiple-component concept applies and examinations will be limited to one Reactor Coolant Pump schedule per B-L-2.
5.1.5.9 Examination Category B-G-1 Summary Number of Number of Components item Number Components ...ecte or E 4 amination B6.10 Rector Vessel 58 58 Closure Head Nuts B6.20 Reactor Vessel Closure Studs, 58 58 in place B6.30 58 Examine only if stud is 58 Reactor Vessel Closure Studs, removed when removed 58 58 Ex ne only if stud is Reactor Vessel C osure Threads in Flange B6.50 Reactor Vessel Closure 58 58 Washers, B ushings 86.180 3 sets of 24 1 set RCP- A, RCP-B, & RCP-C Pump Bolts and Studs Greater (24/ pump).
Than 2 in. in Diameter (72) (24) 3 RCP-A, RCP-B, & RCP-C.
Pump Flan e Surfaces 1 i B6.200 3 sets of 24 1 set RCP-A, RCP-B, & RCP-C Pump Nuts, Bushings, and (24/ pump).
Washers (72) (24)
Page 44 of 89
.)
, V.C. Summer Nuclear Station Second 10-Year Interval i inservice Examination Program !
Revision 1, 5.1.6 Examination Category B-G-2, Pressure Retaining Bolting,2 in. And f Less In Diameter '
5.1.6.1 Reactor Vessel Bolts, Studs, and Nuts, Item Number B7.10 In accordance with Table IWB-2500-1, Examination Category B G-2, all l VCSNS reactor vessel bolts, studs, and nuts,2 inches and under, will be >
visually (VT-1) examined during the second 10-year inspection interval. l The required examinations may be performed with the bolting in place (under tension), when the connection is disassembled, or when the bolting is removed. Bolting examinations will be completed in accordance with the i scheduling requirements of Paragraph IWB-2412, Inspection Program B and, where practical, will be scheduled to parallel the sequence of :
r examinations established during the first interval. '
5.1.6.2 Pressurizer Bolts, Studs, and Nuts, Item Number B7.20 .
In accordance with Table IWB-2500-1, Examination Category B-G-2, all VCSNS pressurizer bolting,2 inches and under, will be visually (VT-1) !
examined during the second 10-year inspection interval. The required examinations may be performed with the bolting in-place (under tension),
when the connection is disassembled, or when the bolting is removed.
Bolting examinations will be completed in accordance with the scheduling :
requirements of paragraph IWB 2412, Inspection Program B and, where !
practical, will be scheduled to parallel the sequence of examinations established during the first interval.
l 5.1.6.3 Steam Generator Bolts, Studs, and Nuts, Item Number B7.30 !
In accordance with Table IWB-2500-1, Examination Category B-G-2, all VCSNS steam generator pressure retaining bolting,2 inches and under, will be visually (VT-1) examined during the second 10-year inspection interval.
The required examinations may be performed with the bolting in-place (under tension), when the connection is disassembled, or when the bolting is removed. Bolting examinations will be completed in accordance with the scheduling requirements of paragraph IWB-2412, Inspection Program B.
Page 45 of 89
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. V.C Summer Nuclear Station Second 10. Year Interval inservice Examination Program Revision i, 5.1.6.4 Piping Bolts, Studs, and Nuts, Item Number B7.50 In accordance with Table IWB-2500-1 Examination Category B-G-2, all VCSNS piping bolting (2 inches and under), on piping required to be examined in accordance with Category B-J, will be visually (VT-1) examined during the second 10-year inspection interval. The required examinations may be performed with the bolting in place (under tension), when the connection is disassembled, or when the bolting is removed. Bolting examinations will be completed in accordance with the scheduling requirements of Paragraph IWB-2412, Inspection Program B and, where practical, will be scheduled to parallel the sequence of examinations established during the first interval.
5.1.6.5 Pump Bolts, Studs, and Nuts, Item Number B7.60 In accordance with Table IWB-2500-1, Examination Category B-G-2, VCSNS pump pressure retaining bolting,2 inches and under, will be visually (VT-1) examined during the second 10-year inspection interval. The required examinations may be performed with the bolting in-place (under tension), when the connection is disassembled, or when the bolting is removed. Per Note 2 (Table IWB-2500-1),"For... pumps, examinations are limited to components selected for examination under Examination Categories...B L-2." Referring to Examination Category B-I 2, the multiple-component concept applies, and examinations are limited to one pump in a multiple-component group, based on size, constructional design, manufacturing method, and system function. See Appendix B for multiple-component listings. Bolting examinationn will be completed in accordance with the scheduling requirements of paragraph IWB-2412, Inspection Program B.
5.1.6.6 Valves Bolts, Studs, and Nuts, Item Number B7.70 In accordance with Table IWB-2500-1, Examination Category B-G-2, VCSNS valve pressure retaining bolting,2 inches and under, will be visually (VT-1) examined during the second 10-year inspection interval. The required examinations may be performed with the bolting in place (under tension), when the connection is disassembled, or when the bolting is Page 46 of 89
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. V.C. Summer Nuclear Station Second 10-Year Interval Inservice Examination Program Revision 1, l removed. Per Note 2 (Table IWB-2500-1) valve bolting " examinations are limited to components selected for examination under Examination ,
Categories . . B-M 2." Referring to Examination Category B-M-2, Valve Bodies, the multiple-component concept applies, and examinations are !
limited to one valve in a multiple-component group based on size, constructional design, manufacturing method, and system function. See '
Appendix B for multiple-component group listings. Bolting examinations will be completed in accordance with the scheduling requirements of ;
Paragraph IWB-2412, Inspection Program B and, where practical, will be ,
scheduled to parallel the sequence of examinations established during the ;
first interval. ;
5.1.6.7 Examination Category B G-2 Summary l Number of Number of omponents item Number Remarks Components .
l' Examination ,
t 87.10 '
Rector Vessel 4 4 Conoseal bolting Bolts, Studs, and Nuts l
B7.20 1 set 1 set !
Pressurizer Manway bolting 16 bolts I Bolts, Studs, and Nuts (16) (16)
Manway botting - 32 bolts 87.30 3 sets 3 sets per5/G:(Each set of 32 l; S/G consists of 2 manways per Bolts, Studs, and Nuts (90) I9b) 5/G - 16 bolts each).
B7.50 Piping 6 sets 6 sets bolts, Studs, and Nuts l
B7.60 6 sets 2 sets RCP seal housing bolting l
Pumps (2 seals per pump,12 bolts ,
Bolts, Studs, and Nuts Per seal).
(96) (24) j i
B7.70 Exr.. une one set for each valves 21 sets 5 sets v dve group: (VL-02,03, i Bolts, Studs, and Nuts C 4,05, and 06).
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. V.C. Summer Nuclear Station Second 10-Year Interval Inservice Examination Program Revision 1 5.1.7 Examination Category B-H, Integral Attachments for Vessels (See Relief Request RR-02) ;
5.1.7.1 PressurizerIntegrally Welded Attachments, Item Number B8.20 f See 7.0, Inservice Examination Program -Integral Attachments:
Examination Category B-K :
l 5.1.8 Examination Category B-J, Pressure Retaining Welds In Piping l
In accordance with Table IWB-2500-1, Examination Catagory B-J, essentially 100% of the weld length of a selected sample of VCSNS Class 1 non- exempt circumferential (and intersecting longitudinal welds), branch connection, and socket welds will be volumetrically (UT) and/or surface (PT) ,
examined during the second 10-year inspection interval. The sample selection of these welds will be in accordance with Note 1 of table IWB-2500 1, Catagory B-J which is summarized as follows:
e All terminal ends in each pipe or branch run connected to vessels. l e All terminal ends and joints in each pipe or branch run connected to other components where stress levels exceed the following limits under loads associated with specific seismic events and operational conditions: *
- 1. Primary plus secondary stress intensity of 2.45m for ferritic and austenitic steel, or
- 2. Curnulative usage factor U of 0.4 (same criteria used in 1st interval, highest potential for failure) i r
e All Dissimilar Metal welds between: >
l
- 1. Carbon or alloy and high alloy steel, or i
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. V.C. Summer Nuclear Station Second 10. Year Interval Inservice Examination Program Revision 1, e Additional welds as necessary to Ensure the sample contains 25% of the circumferential welds. (These additional welds may be selected from one loop as defined in the 1977 Edition)
Currently (during Cycle 8) VCSNS does not have any Class 1 dissimilar metal piping welds, however if a future modification adds any of these welds they will be included in the Category B,J sample.
The required examinations will be cornpleted in accordance with the scheduling requirements of paragraph IWB-2412, Inspection Program B and, where practical, will be scheduled to parallel the sequence of examinations established during the first interval.
5.1.8.1 Examination Category B.J Item Number Summary Number of item Number Number of Components Remarks Components selected for Examination B9.10 B9.11 Piping Circumferential Welds 359 91 Welds 89.12 2 NPS4 LongitudinalWelds 0 N/A B9.21 B9.20 CircumferentialWelds 74 22 Piping Welds B9.22
< NPS 4 Longitudinal Welds 0 N/A B9.30 B9.31 Branch 2 NPS 4 Connection B9.32 Welds < NP5 4 25 16 89.40 Socket Welds 301 211 l
= !
Page 49 of 89 I
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. V.C. Summer h'uclear Station ,
Second 10-Yearinterval !
Inservice Examination Program Revision i, 5.1.9 Examination Category B K 1 Integral Attachments For Class 1 Piping. Pumps and Valves (See Relief Request RR-02) t 5.1.9.1 Piping Integrally Welded Attachments, Item Number B10.10 See 7.0, Inservice Examination Program -Integral Attachments; ;
Examination Category B K t
5.1.10 Examination Category B L-2, Pump Casings 5.1.10.1 Pump Casing, Item Number B12.20 In accordance with Table IWB-2500-1, Examination Category B-L-2, certain VCSNS Class i pump casing internal surfaces are required to be visually '
(VT-3) examined during the second 10-year inspection interval. The Reactor i Coolant Pumps are the only components applicable to Item B12.20.
Examination of the internal pressure boundary surfaces will be performed to the extent practicable, and only when a pump is disassembled for maintenance or repair.
The multiple-component concept applies to Examination Category B-L-2 and, therefore, the required examination may be limited to one Reactor Coolant Pump, if disassembled and accessible for examination. See '
Appendix B for multiple-component group listings. l 5.1.10.2 Examination Category B L-2 Summary ,
No. of Components Item Number No.of Components Selected for Remarks Examination B12.20 3 1 RCP-A, B, & C Pump Casing Page 50 of 89
s V.C. Summer Nuclear Station Second 10-Year interval inservice Examination Program Revision 1, 5.1.11 Examination Category B-M-2, Valve Bodies 5.1.11.1 Valve Body, Exceeding NPS 4, Item Number B12.50 g, In accordance with Table IWB-2500-1, Examination Category B-M-2, the s3-internal surfaces of certain VCSNS valve bodies exceeding NPS 4 will be visually (VT-3) examined during the second 10-year inspection interval.
II Examinations will be performed only, in the event a valve is made accessible for examination by disassembly of the valve for maintenance or repair.
h Examinations will be performed to the extent practicable.
to ta Selection of valves for examination is in accordance with Note 3 (Table IWB-2500-1)," Examinations are limited to at least one valve in each group ti "
of valves that are of the same size, constructional design, and manufacturing method, and that perform similar functions in the system, .
" The multiple-component concept applies, and examinations are limited to y one valve in each valve group. Therefore, should a valve within a multiple- .g component group be disassembled and become accessible for examination, is the completed examination will satisfy the Examination Category B-M-2 examination requirements for that group for the second 10-year inspection r interval. See Appendix B for multiple-component group listings. c 1
l 5.1.11.2 Examination Category B-M-2 Summary 3
h No. of No.of Components l Remarks g item Number Selected for -
Components Examination l2 6 Valve Groups VI,01 thru VI,06 I 24 y y, Exceeding NPS 4 r 5.1.12 Examination Category B N 1, Interior Of Reactor Vessel 5.1.12.1 Reactor VesselInterior, Item Number B13.10 e.
In accordance with Table IWB-2500-1, Examination Category B-N-1, e VCSNS reactor vesselinterior areas made accessible for examination by removal of components during normal refueling outages will be visually l
(VT-3) examined at approximately 3 year intervals during the second 10-year inspection interval.
Page 51 of 89
i V.C.summsr Nuclaar Station Second 10-Year Interval !
Inservice Examination Program [
Revision 1 5.1.13 Examination Category B.N.2. Integrally Welded Core Support Structures and Interior Attachments To Heactor Vessels 5.1.13.1 Reactor Vessel (PWR) Interior Attachments Beyond Beltline Region, Item Number B13.60 In accordance with Table IWB-2500-1, Examination Category B-N-2, all accessible VCSNS reactor vessel interior attachments outside of the beltline region will be visually (VT-3) examined during the second 10-year inspection ;
interval. The Code permits these examinations to be deferred to the end of i the interval. Where practical, however, individual weld examinations will be scheduled to parallel the sequence of examinations established during the first interval.
l 5.1.14 Examination Category B N-3. Removable Core Support Structures 5.1.14.1 Core Support Structure, Item Number B13.70 In accordance with Table IWB-2500-1, Examination Category B-N-3, surfaces of the VCSNS removable core support structure will be visually (VT-3) examined during the second 10-year inspection interval. The Code permits this examination to be deferred to the end of the interval. Where i practical, however, this examination will be scheduled to parallel the sequence of the examination established during the first interval. l 5.1.15 Examination Category B.O. Pressure Retaining Welds In Control Hod IIousings i 5.1.15.1 Heactor Vessel Welds in CHD Housing, Item Number B14.10 In accordance with Table IWB-2500-1, Examination Category B-0, all VCSNS pressure retaining welds of10% of the peripheral CRD housings (10% of 24 peripheral housings equals 3 housings) will be volumetrically (UT) examined during the second 10-year inspection interval. The Code permits these examinations to be deferred to the end of the interval. Where practical, however, individual weld examinations will be scheduled to parallel the sequence of examinations established during the first interval.
Page 52 of 89 l
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l
. V C. Summer Nuclear Station Second 10-Year Interval inservice Examination Program ,
Revision 1, I 5.1.15.2 Examination Category B-O Summary l No. of Item Number m M nent* Remarks Components Selected for Examination Item Number B14.10 24 l
3 ;
Reactor Vessel Weldsin CRD Housing -
5.1.16 Examination Category B-P, All Pressure Retaining Components See 8.0, Inservice Examination Program - System Pressure Testing I 5.1.17 Examination Category B-0. Steam Generator Tubing In accordance with Table IWB-2500-1, Examination Category B-Q, Note 1, l i
the extent and frequency requirements for volumetric examination (ET) of the VCSNS steam generator tubing during the second 10-year inspection interval shall be in accordance with the Plant Technical Specifications.
5.2 CLASS 2 COMPONENTS 5.2.1 Examination Categorv C-A, Pressure Retainine Welds In Pressure Vessels 5.2.1.1 Shell Circumferential Welds, Item Number C1.10 In accordance with Table IWC-2500-1, Examination Category C-A, essentially 100(~c of the weld length of pressure retaining welds at gross structural discontinuities in VCSNS Class 2 pressure vessels will be volumetrically (UT) examined during the second 10-year inspection interval.
Therefore, for the second inspection interval, the same welds examined during the first interval will be selected for examination during the second interval. Note that the multiple-component concept was applied to selection of welds during the first interval;likewise, the second interval required examinations will be limited to one vessel (or the equivalent of one vessel) 2n a multiple-component group. See Appendix B for multiple-component group listings. Per Note 4 (Table IWC-2500-1), the vessel areas selected for examination during the first inservice inspe: tion interval shall be reexarnined over the service lifetime of the components.
Page 53 of 89
v C i ummer Nuclear Station Second 10. Year Interval l Inservice E xamination Prvam I Revision 1, The required examinations will be performed in accordance with the '
scheduling requirements of paragraph IWC 2412, Inspection Program B and, where practical, will be scheduled to parallel the sequence of examinations established during the first interval. i 5.2.1.2 Head Circumferential Welds, Item Number C1.20 In accordance with Table IWC-2500-1, Examination Category C-A, essentially 100% of the weld length of VCSNS Class 2 pressure vessel head- l to-shell welds will be volumetrically (UT) examined during the second !
10-year inspection interval. Therefore, for the second inspection interval, the same welds examined during the first interval will be selected for examination during the second interval. Note that the multiple-component concept was applied to selection of welds during the first interval;likewise, !
the second interval required examinations will be limited to one vessel (or j the equivalent of one vessel)in a multiple-component group. See Appendix B !
for multiple-component group listings. Per Note 4 (Table IWC-2500-1), the '
vessel areas selected for examination during the first inservice inspection interval shall be reexamined over the service lifetime of the components. ;
The required examinations will be performed in accordance with the i scheduling requirements of paragraph IWC-2412, Inspection Program B and, where practical, will be scheduled to parallel the sequence of examinations !
established during the first interval. ,
t 5.2.1.3 Tubesheet-to Shell Welds, Item Number C1.30 !
In accordance with Table IWC-2500-1, Examination Category C-A, ;
essentially 100% of the weld length of VCSNS Class 2 pressure vessel tubesheet-to-shell welds will be volumetrically (UT) examined during the second 10-year inspection interval. Therefore, for the second inspection i interval, the same welds examined during the first interval will be selected for examination during the second interval. Note that the multiple-component concept was applied to selection of welds during the first interval; likewise, the second interval required examinations will be limited to one Page 54 of 89 l
V C Summer Nuclear 8tation Second 10. Year Interval Inservice Examination Program Revision 1, vessel (or the equivalent of one vessel)in a multiple-component group. See Appendix B for multiple-component group listings. Per Note 4 (Table l IWC-2500-1), the vessel areas selected for examination during the first inservice inspection interval chall be reexamined over the service lifetime cf the components.
The required examinations will be performed in accordance with the scheduling requirements of paragraph IWC-2412, Inspection Program :1and, where practical, will be scheduled to parallel the sequence of examinations established during the first interval. !
5.2.1.4 Examination Category C-A Summary No. of Item Number Components Remarks Components Selected for Examination C1.10 17 6 SG-A/B/C (5 welds per SG)
Shell Circumferential RHRHX-A/B (1 weld per HX)
Welds C1.20 5 2 SG-A/B/C (1 weld per SG)
Head Circumferential RHRHX-A/B (1 weld per HX)
Welds C1.30 3 1 SG-A/B/C (1 weld per SG)
Tubesheet-to-Shell Welds 5.2.2 Examination Category C-B, Pressure Retaining Nozzle Welds In Vessels In accordance with Note 2 of Table IWC-2500-1 for Category C-B, only those vessel nozzles at terminal ends of piping runs which are required to be ,
examined per Category C F are applicable to the requirements of Category C-B. That is, vessel nozzles at terminal ends of thinwall piping runs are not ;
required to be examined per category C-B. However, no thin wall piping is !
associated with VCSNS Class 2 nozzles, therefore all of the nozzles are subject to the requirements of Category C-B. !
Page 55 of 89
V C. Summer .N'uclear station Second 10. Year Interval
, Inservice Examination Program Revision i, Per Note 4 (Table IWC-25001), "In the case of multiple vessels ofsimilar design, size. and service... the required examinations may be limited to one vessel or distributed among the vessels," therefore, the multiple-component concept applies. See Appendix B for multiple-component group listings. _l 1
The required examinations will be performed in accordance with the !
scheduling requirements of paragraph IWC-2412, Inspection Program B and, where practical, will be scheduled to parallel the sequence of examinations established during the first interval.
l 5.2.2.1 Nozzle-to Shell Weld of Nozzles Without Reinforcing Plate in Vessels l l
> 1 in. Nominal Thickness, Item Number C2.21 '
i In accordance' with Table IWC-2500 1, Examination Category C-B, VCSNS i Class 2 pressure retaining nozzle-to-shell or nozzle-to-head welds in pressure vessels will be surface (MT) and volumetrically (UT) examined during the r second 10-year inspection interval.
5.2.2.2 Nozzle Inside Radius Section of Nozzles Without Reinforcing Plate in [
Vessels > fin.NominalThickness, Item NumberC2.22 l In accordance with Table IWC-2500-1, Examination Category C B, VCSNS Class 2 nozzle inside radius sectionsi will be volumetrically (UT) examined I during the second 10-year inspection interval. This willinclude all nozzles at terminal ends of non-exempt piping runs.
l l
5.2.2.3 Reinforcing Plate Welds to Nozzle and Vessel of Nozzles With l
Reinforcing Plate in Vessels > 1/2" Nominal Thickness, Item Number :
C2.31 i
In accordance with Table IWC-25001, Examination Category C-B, VCSNS l
reinforcing plate to nozzle and vessel welds in Class 2 pressure vessels, will I be surface (PT) examined during the second 10-year inspection interval. l This will include all vessel nozzles at terminal ends of nonexempt piping runs.
Page 56 of 89
9 V.C. Summer Nuclezr Station Second 10 Year Interval inservice Examination Program Revision 1 5.2.2.4 Nozzle to Shell(or Head) welds when Inside of Vesselis Inaccessible l for Nozzles With Reinforcing Plate in Ves:,els > 1/2" Nominal Thickness, Item Number C2.33 i In accordance with Table IWC-2500-1, Examination Category C-B, VCSNS nozzle to shell(or head) welds,in Class 2 pressure vessels, when the inside of ,
the vessel is inaccessible, will be visually (VT 2) examined during system l pressure test required by Examination Category C-H, each inspection period
]
during the second 10-year inspection interval. I
\
i 5.2.2.5 Examination Category C B Summary J l
l i
Number of 1 Number of Components Item Number Remarks Components Selected for ,
Examination C2.20 C2.21 !
Nozzles Without Nozzle-to Shell 3 SG-A/B/C: FW, AFW, & MS 9
Reinforcing WeM Nozzles Plate in Vessels C2.22
> 1/2 in. Nominal Nozzle inside 5/G-A/B/C: FW, & MS Thickness 6 Nozzles !
Radius 5ection C2.31 Reinforcing 4 2 ggggx gfg C2.20 Plate to Nozzle Nozzles With and Vessel Reinforcing i Plate in Vessels C2.33 RHRHX-A/B
> 1/2 in. Nominal Nozzle to shell 4 !
2 Thickness or head) welds Note: VT 2 Examination, wheninside of Controlled by SCE&G vesselis Procedure SAP-145.
inaccessible 5.2.3 Examination Category C C, Integral Attachments For Class 2 Vessels and Piping (See Relief Request RR-02)
See 7.0, Inservice Examination Program-Integral Attachments; Examination Category C-C l
i l
Page 57 of 89
I V C. Summer Nuclar Str.tirn Second D-YearInterval
)
Inservice Exammation Program Revision 1 5.2.4 Examination Category C-F-1, Pressure Retaining Welds In Austenitic Stainless Steel Or High Allov Piping Selection of Examination Category C-F-1 welds for examination will be in accordance with Note 2 of Table IWC-2500-1, as follows:
e 7.5%, but not less than 28, of all nonexempt austenitic stainless steel or high-alloy circumferential piping welds will be selected for examination.
e Welds not exempted by IWC-1220 (e.g., piping welds > NPS 4 which l are < 3/8 nominal wall, or piping welds s NPS 4 and a NPS 2 which are s 1/5 nominal wall) are not required to be nondestructively examined per Examination Category C-F-1; however, these welds are to be included in the total weld count to which the 7.5% sampling rate is applied. Note: for accountability purposes, these "thinwall" piping welds are identified by adding the suffix " TW" to the appropriate Code item number.
e Longitudinal welds are excluded from the total to which the 7.5%
sample is applied, since they are scheduled for examination in conjunction with a selected intersecting circumferential weld.
e Any Class 2 dissimilar metal welds which contains a combination of C-F-1 and C.F 2 material are included in Category C-F-1 in accordance with Code Interpretation XI-1-89-57.
e The required examinations will be distributed among the Class 2 systems prorated, to the degree practicable, on the number of circumferential welds in each system (i.e., if a system contains 30% of the nonexempt welds, then 30% of the nondestructive examinations required by Examination Category C-F-1 should be performed on that system). Longitudinal welds will only be examined when found intersecting a selected circumferential weld. However, as explained by interpretation XI-1-83-80R, if the longitudinal seam is in SA-403 material and was welded without the addition of filler material, examination is not required.
Page 58 of 89
V.C. Summer Nucint Station Second 10-YearInterval Inservice Examination Program Revision 1, e Within a system, the required examinations will be distributed among terminal ends (TE's) and structural discontinuities (SD's) . . prorated, to the degree practicable, on the number of nonexempt terminal ends )
and structural discontinuities in that system. In the event that proration calculations indicate essentially zero TE selections, a minimum of one TE selection will be made. Refer to paragraphs ;
1.3.4.21,1.3.4.22, and 3.2.3 for definitions and clarifications of terminal ends and structural discontinuities.
i e Within each system, the required examinations will be distributed between lines sizes, prorated to the degree practicable.
Due to the dramatic change, from the first inspection interval to the second, in the Code rules dealing with examination of Class 2 pressure retaining welds, scheduling of second inspection interval required examinations to parallel the sequence established during the first inspection intervalis not practical. Examination Category C-F-1 welds selected for examination during the second inservice inspection interval that were previously examined during the first interval will, where practical, be scheduled for the corresponding period in the second interval; however, the scheduling requirements of Paragraph IWC-2412, Inspection Program B will take precedence.
5.2.4.1 Circumferential Piping Welds 2: 3/8 in. Nominal WallThickness for Piping > NPS 4, Item Number C5.11 In accordance with Table IWC-2500-1, Examination Category C-F-1, VCSNS nonexernpt stainless steel circumferential welds in piping greater than or equal to 3/8" (.375) nominal wall thickness, for piping greater than NPS 4, will be examined by both surface (PT) and volumetric (UT) methods during the second 10-year inspection interval. Selection and scheduling will be in accordance with paragraph 5.2.4 above.
l I
Page 59 of 89
, V.C. Summer Nuchsr Station Second lo Yearinterval inservice Examination Program Revision i.
5.2.4.2 Longitudinal Piping Welds a 3/8 in. Nominal Wall Thickness for Piping > NPS 4, Item Number C5.12 In accordance with Table IWC-2500-1, Examination Category C-F-1, VCSNS nonexempt stainless steel longitudinal welds in piping greater than or equal to 3/8" (.375) nominal wall thickness, for piping greater than NPS 4, will be examined by both surface (PT) and volumetric (UT) methods during the second 10-year inspection interval. Longitudinal welds will be selected and scheduled for examination based on their intersection with a selected circumferential weld, and will be examined for a distance from the intersecting weld equal to 2.5 times the nominal wall thickness.
5.2.4.3 Circumferential Piping Welds > 1/5 inch Nominal Wall Thickness for Piping a NPS 2 and s NPS 4 (High Pressure SafetyInjection), Item Number C5.21 In accordance with Table IWC-2500-1, Examination Category C-F-1, VCSNS nonexempt stainless steel circumferential welds in piping greater than 1/5"
(.2") nominal wall thickness, for piping greater than or equal to NPS 2 and less than or equal to NPS 4, will be surface (PT) and volumetrically (UT) examined during the second 10-year inspection interval. Selection and scheduling will be in accordance with paragraph 5.2.4 above.
5.2.4.4 Socket Welds. Item Number C5.30 In accordance with Table IWC-2500-1, Examination Category C-F-1, VCSNS nonexempt staitJess steel socket welds will be surface (PT) examined during the second 10-year inspection interval. Selection and scheduling will be in accordance with paragraph 5.2.4 above.
5.2.45. Circumferential Welds of Pipe Branch Connections of Branch Piping a NPS2, Item NumberC5.41 In accordance with Table IWC-2500-1. Examination Category C F-1, VCSNS nonexempt stainless steel circumferential branch connection welds of branch piping greater than or equal to NPS 2 will be surface (PT) examined during the second 10-year inspection interval. Selection and scheduling will be in accordance with paragraph 5.2.4 above.
Page 60 of 89
9 Y C. Summer Nuclear Station Second 10-Year Interval Inservice Examination Program Resision 1, 5.2.4.6 Examination Category C-F-1 Item Summary l Item Number Number of Remarks .
Components l
ltem No. C5.11-TW 567 Thinwall piping - not required to be f Nonexempt circumferential piping examined j welds > NPS 4, and < 3/8" nominal item No. C5-12 TW 401 Thinwall piping - not required to be Nonexempt Longitudinal piping examined welds >NP54 and < 3/8" nominal wall item No. C5.21-TW Thinwall piping - not required to be 0 examined Nonexempt circumferential piping welds 2NPS 2, and s NPS 4, and s 1/5" i nominal wall.
C5.10 C5.11 l Piping Welds Circumferential 380 2 3/8" Nominal Weld Wall for Piping C5.12
> NPS 4 Longitudinal 286 Weld C5.20 C5.21 Piping Welds Circumferential 252
> 1/5" Nominal Weld Wall for Piping C5.22 2 NPS 2 and Longitudinal 0 s NPS 4 Weld C5.30 Socket Welds 76 C5.40 C5.41 Branch Circumferentral 10 Connections of Weld Branch Piping sNPS2 C5.42 Longitudinal 0 Weld i
Page 61 of 89
V C.SummerNucletrSt tion Second 10-Year Interval Inservice Exammation Program Revision 1, 5.2.4.7 Examination Category C F-1 System Summary Total C-F-1 Circumferential Piping Welds (including Thinwall piping) = 12851 Calculated Overall C-F-1 Circumferential Weld Sample Requirement - 972 Including Thinwall Piping Excluding Thinwall Piping items System overall Code Percent Prorated Total Total Total TE% Of SD% Of TE% Of SD% Of Name Total Reg'd of System TE'S SD'S PP'S Total Total Total Total Welds Total System Sample 4 TE + 5D TE-5D TE +5D TE + 50 Welds 3 Total C5 305 152 21.17 % 21 7 139 6 4.8% 95.2 % 1 20 RHR 278 99 13.79 % 14 6 78 15 7.1 % 92.9 % 1 13 51 455 382 53.20 % 52 15 316 51 4.5 % 95.5 % 2 50 SP 247 85 11.84 % 12 0 80 5 0.0% 100.0 % 0 12 Totals 1285 718 -
99 28 613 77 - -
4 95 Note I: Overall system weld total includes those welds identified as Ca'tegory C-F-l' thinwall piping Item Numbers (ltem numbers with suffix "-TW"), and excludes longitudinal welds, in order to produce the total welds for which the overall Category sample calculation is based. Actual distribution (proration) calculations of the overall Category sample shall exclude the thinwall piping welds as well as the longitudinal welds.
Note 2: The overall system sample calculation for the Category is 7.57c of the total nonexempt population of circumferential welds, including the thinwall piping. This sample number is rounded up in the event of fractional results.
In the event that this number equates to less than 28, the sample number is increased to the minitnum of 28. In the event that the resulting sample number is greater than the total number of Code required welds (excludes thinwall) available to sample, the sample is lowered to equal 1007c of the available Code required welds (total of column 3).
Note 3: Code required welds exclude the thinwall piping welds.
Note 4: The prorated system sample calculations are rounded up in the event of fractional results to ensure minimum sample requirernents are maintained Page 62 of 89
.- i V.C. Summer h*uctsar Station Second 10-Year Interval f
t Inservice Examination Program {
Revision i, Note 5: Final TE and SD sample calculations which result in fractional values are j rounded to the nearest whole number, however,in the event that the !
resultant required TE sample rounds down to zero, the TE required sample will be rounded up to one, and the SD required sample will be lowered by one. Note that the pipe-to-pipe (PP, column 8iwelds are not part of the ,
required sample proration, and are only shown to provide clarity of weld totals.
5.2.4.8 Examination Category C-F-1 Summary by Line Size System Weld Type Pipe Size Total Welds Total Selected CS TE-P 3 3 1 CS TE-A 4 2 0 CS TE-A 3 2 0 CS SD 4 24 3 CS SD 3 77 12 ,
RHR TE P 14 2 0 l RHR TE-A 12 4 1 .
RHR SD 12 51 9 i RHR LS 14 59 10 I RHR LS 12 52 5 ,
SI TE V 20 1 1 SI TE A 14 2 0 SI TE-A 10 6 0 SI TE-A 4 1 0 4 SI TE-A 3 4 1 l SI TE-A 2 1 0 i SI SD 20 8 2 :
SI SD 14 39 5 i SI SD 12 1 1 l
SI SD 6 55 8 i SI SD 4 9 2 SI SD 3 134 22 SI SD 2 32 4 SI LS 20 27 6 !
SI LS 14 96 9 SP SD 12 80 12 SP LS 12 52 5 i
Page 63 of 89 i
V.C. Summer Nuclear Station Second 10-Year Interval Inservice Examination Program Revision 1.
5.2.5 Examination Category C-F-2, Pressure Retainjng Welds In Carbon Or Low Allov Steel Piping Selection of Examination Category C-F-2 welds for examination will be in accordance with Note 2 of Table IWC-2500-1, as follows:
e 7.5%, but not less than 28, of all nonexempt carbon steel circumferential piping welds will be selected for examination.
e Welds not exempted by IWC-1220 (e.g., piping welds > NPS 4 which i are < 3/8 nominal wall, or piping welds :s; NPS 4 and 2: NPS 2 which are s 1/5 nominal wall) are not required to be nondestructively examined per Examination Category C-F-2: however, these welds are to be included in the total weld count to which the 7.5% sampling rate is applied. Note: for accountability purposes, these "thinwall" piping welds are identified by adding the suffix "-TW" to the appropriate Code Item number.
e Longitudinal welds are excluded from the total to which the 7.5%
sample is applied, since they are scheduled for examination in conjunction with a selected intersecting circumferential weld.
- Any Class 2 dissimilar metal welds which contain a combination of C-F-1 and C F-2 material are included in Category C-F-1 in accordance with Code Interpretation XI-1-89-57.
e The required examinations willbe distributed among the Class 2 systems prorated, to the degree practicable, on the number of circumferential piping welds in each system (i.e., if a system contains 30% of the nonexempt circumferential welds, then 30% of the nondestructive examinations required by Examination Category C-F-2 should be performed on that system). Longitudinal welds will only be examined when found intersecting a selected circumferential weld.
However, as explained in interpretation XI-1-83-80R, if the longitudinal seam is in SA-403 material and was welded without the addition of filler material, examination is not required e Within a system, the required examinations will be distributed among t erminal ends (TE's) and structural discontinuities (SD's) . . prorated, I to the degree practicable, on the nurnber of nonexempt terminal ends i and structural discontinuities in that system. In the event that proration calculations indicate essentially zero TE selections, a minimum of one TE selection will be made. Refer to paragraphs 1.3.4.21,1.3.4.22, and 3.2.3 for definitions and clarifications of terminal ends and structural discontinuities.
Page 64 of 89
V C.Summtr Nuclar Ststion Second 10-YearInterval Inservice Examination Program Revision 1.
i e Within each system, the required examinations will be distributed between lines sizes, prorated to the degree practicable Due to the dramatic change, from the first inspection interval to the second, in the Code rules dealing with examination of Class 2 pressure retaining welds, scheduling of second inspection interval required examinations to parallel the sequence established during the first inspection interval is not
. practical. Examination Category C-F-2 welds selected for examination during the second inservice inspection interval that were previously examined during the first interval will, where practical, be scheduled for the corresponding period in the second interval; however, the scheduling requirements of Paragraph IWC-2412, Inspection Program B, will take precedence.
5.2.5.1 Circumferential Piping Welds a 3/8 in. Nominal WallThickness for Piping > NPS 4, Item Number C5.51 In accordance with Table IWC-2500-1, Examination Category C-F-2, VCSNS nonexempt carbon steel circumferential welds in piping greater than or equal to 3/8"(.375) nominal wall thickness, for piping greater than >
NPS 4, will be examined by both surface (MT or PT) and volumetric (UT) methods during the second 10-year inspection interval. Selection and scheduling will be in accordance with paragraph 5.2.5 above.
5.2.5.2 Longitudinal Piping Welds 2 3/8 in. Nominal Wall Thickness for Piping > NPS 4, Item Number C5.52 In accordance with Table IWC-2500-1, Examination Category C-F-2, VCSNS nonexempt carbon steel longitudinal welds in piping greater than or equal to 3/8"(.375) nominal wall thickness, for piping greater than NPS 4, will be examined by both surface (MT or PT) and volumetric (UT) methods during the second 10-year inspection interval. Longitudinal welds will be selected and scheduled for examination based on their intersection with a selected circumferential weld, and will be examined for a distance from the intersecting weld equal to 2.5 times the nominal wall thickness.
i Page 65 of 89
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V.C. Summer h*uclear Station )
Second 10 Year Interval l Inservice Examination Program ;
Revision i, 5.2.5.3 Circumferential Welds of Pipe Branch Connections of Branch Piping 2: NPS E Item Number C5.81 In accordance with Table IWC-2500-1, Examination Category C-F-2, VCSNS i nonexempt carbon steel circumferential branch connection welds of branch ,
piping greater than or equal to NPS 2 will be surface (MT or PT) examined ;
during the second 10-year inspection interval. Selection and scheduling will be in accordance with paragraph 5.2.5 above.
5.2.5.4 Examination Category C-F-2 Item Summary f Number of Remarks item Number Components Item No. C5.51-TW Thinwall piping- not required to be '
Nonexempt circumferential piping 0 examined welds >NPS 4. and < 3/8" nominal wall.
Item No. C5.61-TW Thinwallpiping notrequiredtobe Nonexempt circumferential piping "'
0 [
welds aNPS 2,and s NPS 4,and s 1/5" I nominal wall.
C5.50 C5.51 Piping Welds Circumferential 256 2 3/8" Nominal Weld Wall for Piping C5.52
> NPS 4 Longitudinal 182 ;
Weld ;
C5.60 C5.61 Piping Welds Circumferential 0
>1/5" Nominal Weld Wall for Piping C5.62 '
a NPS 2 and Longitudinal 0 s NPS 4 Weld C5.70 0 -
Socket Welds C5.80 C5.81 !
Branch Circumferential 23 Connections of Weld Branch Piping s NPS2 C5 82 l Longitudinal 0 W eld i
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V C.SummerNuctsar Station Second 10-Year Interval Inservice Examination Program Revision 1, 5,2.5.5 Examination Category C-F-2 System Summary Total C-F-1 Circumferential Piping Welds (including Thinwall piping) = 12851 Calculated Overall C-F-1 Circumferential Weld Sample Requirement - 972 including Excluding Thinwall Piping item 5 Thinwall Piping System overall Code Percent Prorated Total Total Total TE% of SD% of TE% of 50% of Name Total R ea'd of System TE'S SD'S PP'S Total Total Total Total Welds Total System Sample 4 TE - SD TE + 5D TE + 5D TE + 5D Welds 3 Total EF 10 10 3.58 % 2 2 8 0 20.0 % 80.0% 1 1 FW 93 93 33.33 % 10 10 72 11 12.2 % 87.8 % 1 9 MS 141 141 50.54 % 15 12 107 22 10Eo 8m 2 13 SW 30 35 12.54 % 4 4 30 1 11.8 % 88.2 % 1 3 Totals 27p. 279 -
31 28 217 34 - -
5 26 Note 1: Overall system weld totalincludes those welds identified as Category C-F-2 thinwall piping Item Numbers (Item numbers with sufTix "-TW"), and excludes longitudinal welds, in order to produce the total welds for which the overall Category sample calculation is based. Actual distribution i proration) calculations of the overall Category sample shall exclude the
, thinwall piping welds as well as the longitudinal welds.
Note 2: The overall system sample calculation for the Category is 7.5?c of the total nonexempt population of circumferential welds, including the thinwall piping. This sample number is rounded up in the event of fractional results.
In the event that this number equates to less than 28, the sample number is increased to the minimum of 28. In the event that the resulting sample number is greater than the total number of Code required welds (excludes thinwall) available to sample, the sample is lowered to equal 1007c of the available Code required welds (total of column 3).
Note 3: Code required welds exclude the thinwall piping welds.
Note 4: The prorated system sample calculations are rounded up in the event of ;
fractional results to ensure minimum sample requirements are maintained i Note 5: Final TE and SD sarnple calculations which result in fractional values are rounded to the nearest whole number, however,in the event that the !
resultant required TE sample rounds down to zero, the TE required sample {
will be rounded up to one, and the SD required sample will be lowered by one. Note that the pipe-to-pipe (PP, Column 8) welds are not part of the required sample proration, and are only shown to provide clarity of weld totals.
Page 67 of 89
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V C. Summer N*uelear Station Second 10-YearInterval Inservice Examination Program Revision 1, 5.2.5.6 Examination Category C F-2 Summary by Line Size Weld Type Pipe Size Total Welds . Total Selected System EF TE-V 6 2 1 i EF SD 6 8 1 .
FW TE-V 16 3 0 l
FW TE-V 6 1 1 FW TE-A 18 6 0 FW SD 18 65 7 FW SD 16 3 1 FW SD 6 4 1 FW LS 18 10 0 FW LS 16 2 0 MS TE-V 32 3 1 MS TE B 8 3 0 MS TE-A 32 6 1 MS SD 33.5 6 1 MS SD 32 53 6 MS SD 14 15 2 MS SD 8 18 2 L MS SD 6 15 2 MS LS 33.5 14 1 .
MS LS 32 156 16 l SW TE-A 16 4 1 I SW SD 16 24 2 SW SD 12 6 1 1 5.2.6 Examination Category C-H All Pressure Retaining Components See 8.0, Inservice Examination Program - System Pressure Testing 5.3 CLASS 3 COMPONENTS 5.3.1 Examination Category D-A, System in Support of Reactor Shutdown Function See 8.0, Inservice Examination Prograrn - System Pressure Testing i l
See 7.0, Inservice Examination Program -Integral Attachments '
Page 68 of 89 ,
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t V.C. Summer Nuciser Statka Second 10-YearInterval Inservice Examination Program Revision 1, 5.3.2 Examination Category D B, Systems In Support Of Emergency Core j Cooling, Containment Heat Removal, Atmosphere Cleanup, and Reactor Residual Heat Removal See 8.0, Inservice Examination Program - System Pressure Testing See 7.0, Inservice Examination Program -Integral Attachments 5.3.3 Examination Category D-C, Systems In Support Of Residual Heat Removal From Spent Fuel Storage Pool !
9 See 8.0, Inservice Examination Program - System Pressure Testing l See 7.0, Inservice Examination Program -Integral Attachments f
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V.C. Summer Nucletr Station
, Second 10-YearIntsrval Inservice Examination Program Revision 1, 6.0 ISE PROGRAM - COMPONENT SUPPORTS Inservice inspection of VCSNS Class 1,2, and 3 component supports during the second 10-year inspection interval will be performed in accordance with Code Case N-491.
6.1 INSERVICE EXAMINATION-CLASS 1,2, AND 3 PIPING SUPPORTS 6.1.1 Examination Categorv F-A, Piping Supports 6.1.1.1 Class 1 Piping Supports, Item Number F1.10 In accordance with Table -2500-1, Examination Category F-A, Code Case N-491,25% of the total VCSNS nonexempt Class 1 piping supports, willbe visually (VT-3) examined during the second 10-year inspection interval.
Selection of Examination Category F-A supports for examination will be in accordance with Note 2 of Table -2500-1, such that the total percentage sample will be comprised of supports from each system within the scope of ;
this ISE Program, and the sample sizes within each system will be prorated l i
by support type! function based on the total number of nonexempt supports of ;
each type / function in that system. l l
1 To facilitate selection of supports, and in accordance with Note 1 of Table l 1
-2500-1, Item Numbers will be categorized to identify support types, as i illustrated in the summary table of 6.1.1.4. The four support types utilized are Anchor, Rigid, Snubber, and Spring.
Due to the dramatic change, from the first 10-year inspection interval to the second, in the rules dealing with examination of Class I supports, scheduling of second inspection interval required examinations to parallel the sequence established during the first inspection interval (-2420 of Code Case N-491 ) may not be practical in all car,es. Likewise, Note 4 of Table 2500-1, regarding re-selection of the same supports from the first interval, Page 70 of 89
V C.SummtrNuclatr Statirn Second 10-YearIntzrvel Inservice Exammation Program Revision 1, is considered not applicable. Therefore, only where practical, supports examined during the first 10-year inspection interval will be scheduled for j the corresponding period in the second interval. Note, however, that other factors, such as the scheduling requirements of Table -2410-2, Inspection Program B and the presence of associated integral attachments, will take )
l precedence.
6.1.1.2 Class 2 Piping Supports, Item Number F1.20 l l
In accordance with Table -2500-1, Examination Category F-A, of Code Case d N-491,157c of the total VCSNS nonexempt Class 2 piping supports, will be visually (VT-3) examined during the second 10-year inspection interval.
Selection of Examination Category F-A supports for examination will be in accordance with Note 2 of Table -2500-1, such that the total percentage sample will be comprised of supports from each system within the scope of this ISE Program, and the sample sizes within each system wil'1 be prorated by support type / function based on the total number of nonexempt supports of each type / function in that system.
To facilitate selection of supports, and in accordance with Note 1 of Table
-2500-1, Item Numbers will be categorized to identify support types, as illustrated in the summary table of 6.1.1.4. The four support types utilized are Anchor, Rigid, Snubber, and Spring.
Due to the dramatic change, from the first 10 year inspection interval to the second, in the rules dealing with examination of Class 2 supports, scheduling of second 10-year interval required examinations to parallel the sequence established during the first inspection interval (-2420 of of Code Case 491) may not be practicalin all cases. Likewise, Note 4 of Table
-2500-1, regarding re-selection of the same supports frorn the first interval, is considered not applicable. Therefore, only where practical, supports examined during the first 10-year inspection interval will be scheduled for the corresponding period in the second interval.
Page 71 of 89
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L V.C. Summer Nuclear Station i Second lo Yearintsrval l Inservice Examination Program
)
Revision 1.
Note, however, that other factors, such as the scheduling requirements of i Table -2410-2, Inspection Program B and the presence of associated integral _ !
attachments, will take precedence.
6.1.1.3 Class 3 Piping Supports, Item Number F1.30 j in accordance with Table -2500-1, Examination Category F-A, of Code Case !'
N-491,10% of the total VCSNS nonexempt Class 3 piping supports, willbe visually (VT-3) examined during the second 10-year inspection interval. i Selection of Examination Category F-A supports for examination will be in accordance with Note 2 of Table -2500-1, such that the total percentage i sample will be comprised of supports from each system within the scope of this ISE Program, and the sample sizes within each system will be prorated by support type / function based on the total number of nonexempt supports of each type / function in that system.
1 To facilitate selection of supports, and in accordance with Note 1 of Table ;
-2500-1, Item Numbers will be categorized to identify support types, as !
illustrated in the sumrnary table of 6.1.1.4. The four support types utilized ,
are Anchor. Rigid, Snubber, and Spring. !
Due to the dramatic change, from the first interval to the second, in the j t
rules dealing with examination of Class 3 supports, scheduling of second interval required examinations to parallel the sequence established during )
the first inspection interval (IWF-2420 of the 90 Addenda) may not be practicalin all cases. Likewise, Note 4 of Table -2500-1, regarding re- l selection of the same supports from the first interval,is considered not applicable.
l The required examinations will be performed in accordance with the j scheduling requirements of Table -2410-2. Inspection Program B.
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V.C. Summer Nuclear Station Second 10 Year Interval inservice Exammation Program Revmon 1.
6.1.1.4 Pipe Support Summary by Class, System, and Support Type Required Sample For Class 1 Piping Supports = (254
- 341) = 86 Required Sample For Class 2 Piping Supports = (15%
- 745) = 113 Required Sample For Class 3 piping Supports = (10%
- 619) = 62 (Note 1)
Anchor Rigid Snubber Spring Rea d
% of Req'd Class Sys Tti class % % 8"* % Reg'd Rea a Reo'd sample Total Tti System sampie Tti sampic Ttl System sample Ttl system sampie 2 Total 3 3 Total 3 Total 3 Total 1 C5 60 17.60 16 0 0.0 o 11 18.3 3 35 58.3 9 14 23.3 4 16 1 RC 112 32.84 29 3 2.7 1 17 15.2 4 77 68.8 20 15 13.4 4 29 1 51 169 49.56 43 2 1.2 1 64 37.9 16 86 50.9 22 17 10.1 4 43 Class Ttis 341 -
88 5 -
2 92 -
23 198 -
51 46 -
12 88 1
2 C5 91 12.08 14 6 6.6 1 68 47.7 10 12 13.2 2 5 5.5 1 14 2 FW 39 5.18 6 3 4.2 0 19 26.8 4 40 56.3 6 9 12.7 1 11 2 MS 71 9.43 11 3 4.2 0 9 23.1 2 20 51.3 3 7 17.9 1 6 2 RH 229 30.41 35 4 1.7 1 49 21.4 7 137 59.8 21 39 17.0 6 35 2 51 188 24.97 29 8 4.3 1 118 62.8 18 56 29.8 9 6 3.2 1 29 2 SP 128 17.00 20 0 0.0 0 65 50.8 10 53 41.4 8 10 7.8 2 20 2 SW 7 0.93 2 2 28.6 1 4 57.1 1 0 0.0 0 1 14.3 0 2 Class Ttls 753 -
117 26 -
4 332 -
52 318 -
49 77 -
12 117 '
2 3 CC 223 35.28 23 1 0.4 0 177 79.4 19 42 18.8 4 3 1.3 0 23 3 DG 4 0.63 1 0 0.0 0 4 100.0 1 0 0.0 0 0 0.0 0 1 !
3 EF 124 19 62 13 3 2.4 0 98 79.0 10 17 13.7 2 6 4.8 1 13 3 SW 117 18.51 12 0 0.0 0 102 87.2 11 11 9.4 1 4 3.4 0 12 3 VU 164 25.95 17 0 0.0 0 164 100.0 17 0 00 0 0 0.0 0 17 Class Ttis 632 -
66 4 -
0 545 -
58 70 -
7 13 -
1 66 3
Gtnd Ttis 1776 -
271 ! 35 -
6 969 - !133 586 -
107 136 -
25 271 Note 1: Initial sample requirement calculation for each Class is rounded up in the event of fractional results.
Note 2: Overall system sample (column 5) which result in fractional values are rounded up, thus ensuring that the minimum required examination samples are achieved.
Note 3: Required sample calculations for each support type are rounded to the nearest whole number, which may result in slight differences between the initial overall required system sample t column 5) and the final overall required system sample (last column - which is the cumulative required sample by support type). Although not readily apparent, thi8 deviation has been compensated for by adjusting column ll, the required rigid support sample by ( 1), as necessary. This column was chosen for this compensation, since there l are more of these supports overall. Without this compensation', the final required sample j (last column) could equate to less than the minimum required sample overall for the given i Class' Item Number. l l
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Page 73 of 89 l
V.C. Summsr Nucher Stztion Second 10-YearInterval Inservice Examination Program l Revision 1 i 6.2 INSERVICE EXAMINATION CLASS 1,2, AND 3 SUPPORTS OTHER THAN PIPING SUPPORTS t 6.2.1 Examination Category F.A, Supports OtherThan Piping Supports 6.2.1.1 Supports Othcr Than Piping Supports (Class 1,2, and 3), Item Number F1.40 In accordance with Table 2500-1, Examination Category F-A, of Code Case ,
N-491, VCSNS nonexempt component supports, other than piping supports, will be visually (VT-3) examined during the second 10-year inspection ;
interval.
The multiple-component concept applies to selection of Examination Category F-A, Item Number F1.40 supports. In accordance with Note 3 of Table -2500-1, the required examinations will be limited to the supports of only one component in each multiple-component group. For single ;
components (not belonging to a multiple-component group),100% of the ;
supports associated with that component will be examined. See Appendix B ,
for multiple-component group listings.
Note 4 of Table -2500-1, regarding re-selection of the same supports from the ,
first interval, is considered applicable to non piping supports. Therefore, to the extent practical, supports that were previously examined during the first inservice inspection interval will be reselected, and will be scheduled for the corresponding period in the second interval.
Page 74 of 89
t V C. Summer Nuclsar Stztion Second lo Year Interval Inservice Examination Program Revision 1, 6.2.1.2 Examination Category F-A Summary (Supports OtherThan Piping '
Supports)
No. of No. of Components item Number Components Selected for ema s1 Examination F1.40 7 3 Reactor Coolant Pumps A,B,C Class 1 Supports Steam Generators A,B,C Other Than Piping Pressurizer (WA)
Supports F1.40 7 3 Charging Pumps A,B,C (WA's) .
Class 2 Supports RHR Pumps A,B (WA's) l Other Than Piping R.B. SPRAY Pumps A,B l Supports i
F1.40 o9
~ 13 Turbine Driven EFW Pump l Class 3 Supports Motor Driven EFW Pumps A,B l Other Than Piping Chillers A,B,C (WA's)
Supports Chilled Water Pumps A,B,C Service Water Booster Pumps A,B Service Water Pumps A,B,C (WA's)
Component Cooling Heat Exchangers A,B (WA's)
Component Cooling Pumps A,B,C RHR Heat Exchangers A,B (WA's)
Component Cooling Surge Tank (WA's)
Condensate Storage Tank (WA's)
Reactor Building Coolers 1 A/B, & 2A/B Diesel Generator Coolers A.B (WA's)
Note 1: "WA" = Welded Attachment 6.3 INSERVICE TESTING OF SNUBBERS (IWF-5000)
Inservice testing of hydraulic and mechanical snubbers will be performed as required by the V.C Summer Nuclear Station's Technical Specification and the 803 Series of Surveillance Test Procedures per Relief Request RR-06 Page 75 of 89
a >
t V C. Summer Nucizer Station Second 10 YearInterval Inservice Examination Program Revision i, ,
s 7.0 ISE PROGRAM -INTEGRAL ATTACHMENTS l Examination of VCSNS Class 1,2, and 3 integral attachments during the second 10-year inspection interval will be performed in accordance with the alternative examination requirements of Code Case N-509, detailed in Relief Request RR-02. l This section herein summarizes the examination requirements of Code Case l N-509, applicable to VCSNS Class 1,2, and 3 integral attachment welds.
f Code Examination Categories and/or Item Numbers not applicable to l VCSNS have been intentionally excluded, a
7.1 INSERVICE EXAMINATION - CLASS 1,2, AND 3 INTEGRAL ATTACHMENTS l
Class 1,2, and 3 integral attachments subject to the examination requirements of 7.1.1,7.1.2 and 7.1.3 are limited to those nonexempt
}
integrally welded attachments that meet the following conditions:
v e the attachment is on the outside surface of the pressure retaining !
component, I
e the attachment provides component support as defined in NF-1110, and e the attachment weldjoins the attachment either directly to the surface f of the component or to an integrally cast or forged attachment to the component.
7.1.1 Class 1 Integral Attachments 7.1.1.1 Examination Category B K, Integral Attachments ForClass 1 Vessels, Piping, Pumps, and Valves j Page 76 of 89 l
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t'.C. Summsr Nuclx.r Statitn Second 10-YearInterval l Inservice Examination Program Revision i, i
7.1.1.1.1 Pressure VesselIntegrally Welded Attachments, Item Number B10.10 In accordance with Relief Request RR-02,100% of the VCSNS pressure ;
vesselintegrally welded attachments willbe surface (MT) examined durmg ;
the second 10-year inspection interval. The required examinations will be i completed in accordance with the scheduling requirements of Paragraph IWB-2412, Inspection Program B, and where practical, will be scheduled to parallel the sequence of examinations established during the first interval. ,
i Examinations will also be performed in the event component support member deformation is identified during operation, refueling, maintenance, inservice examination, or testing. These examinations will not be credited toward meeting the required examinations ofIWB-2412. ,
i 7.1.1 1.2 Piping Integrally Welded Attachments, Item Number B10.20 In accordance with Relief Request RR-02, a sample of 10% of the VCSNS piping welded attachments associated with the Class 1 piping supports as described in IWF-2510,1990 Addenda, will be surface (MT or PT) examined during the second 10-year inspection interval.
The required examinations will be completed in accordance with the scheduling requirements of Paragraph IWB-2412, Inspection Program B.
Since the examination requirements of Relief Request RR-02, difier significantly from the Examination Category B-K-1 requirements of the first inservice inspection interval, scheduling of examinations to parallel the sequence of examinations established during the first interval may not be practical, and will be addressed on a case-by-case basis.
Examinations will also be performed in the event component support ,
member deformation is identified during operation, refueling, maintenance, i inservice examination, or testing. These examinations will not be credited .
toward meeting the required examinations ofIWB-2412.
Page 77 of 89
1 l
V.C. Summer Nuctur St: tion Second 10.YearInterval !
Inservice Examination Program ,
Revision 1, !
7.1.1.1.3 Examination Category B K Summary No. of j No. of Components !
Item Num ber Components Selected for Remarks !
Examination B10.10 1 1 Pressurizer Pressure Vessel Integrally Welded Attachments B10.20 10 1 10% of10 = 1,therefore Piping 1 IWA willbe examined Integrally Welded Attachments l 7.1.2 Class 2 Integral Attachments 7.1.2.1 Examination Category C-C, Integral Attachments For Class 2 I Vessels, Piping, Pumps, and Valves 7.1.2.1.1 Piping Integrally Welded Attachments, Item Number C3.20 t
In accordance with Relief Request RR-02, a sample of 10% of the VCSNS piping welded attachments associated with the Class 2 piping supports as descriped in IWF -2510,1990 Addenda will be surface 01T or PT) examined during the second inservice inspection interval.
The required examinations will be completed in accordance with the scheduling requirements of Paragraph IWC-2412, Inspection Program B. !
Since the examination requirements of Relief Request RR-02, difTer significantly from the Examination Category C-C requirements of the first inspection interval, scheduling of examinations to parallel the sequence of examinations established during the first interval may not be practical, and will be addressed on a case-by-case basis. 4 i
Examinations will also be performed in the event component support '
member deformation is identified during operation, refueling, maintenance, ;
inservice examination, or testing. These examinations will not be credited toward meeting the required examinations ofIWC-2412.
Page 78 of 89 r
V.C. Summzr Nuclear Statien
, Second 10 YearInterval Inservice Examination Program Revision i, 7.1.2.1.2 Pump Integrally Welded Attachments, Item Number C3.30 In accordance with Relief Request RR-02, a sample of10% of the VCSNS !
l Class 2 pump integrally welded attachments associated with component l supports selected for examination (6.2.1.1) will be surface (MT or PT) !
examined during the second 10-year inspection interval.
The required examinations will be completed in accordance with the scheduling requirements of paragraph IWC-2412, Inspection Program B.
Since the examination requirements of Relief Request RR-02 difTer significantly from the Examination Category C-C requirements of the first inspection interval, scheduling of examinations to parallel the sequence of examinations established during the first interval may not be practical and, will be addressed on a case-by-case basis.
Examinations will also be performed in the event component support member deformation is identified during operation, refueling, maintenance, inservice examination, or testing. These examinations will not be credited toward meeting the required examinations ofIWC-2412.
7.1.2.1.3 Examination Category C-C Summary i
No. of Item Num ber C mPonents Remarks Components Selected for Examination C3.20 10% of 189 - 18.9, 189 19 PipingIntegrally therefore 19 IWAr. will be Welded Attachments examined C3.30 RHR Pump A,B 5 1 Pump Integrally Welded Charging Pump A,B,C Attachments 10% of 5= .5, therefore 1 IWA willbe examined.
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V C.Summzr Nacl #ar Station Second 10-Year Interval Inservice Examination Program Revision i.
7.1.3 Class 3 Integraj, Attachments 7.1.3.1 Examination Category D-A, Integral Attachments For Class 3 Vessels, Piping, Pumps, and Valves 7.1.3.1.1 VesselIntegrally Welded Attachments, Item Number D1.10 In at wdance with Relief Request RR-02, one integrally welded attachment of one vessel in each group of nonexempt Class 3 vessels of similar design, function, and service, shall be visually (VT-1) examined during the second 10-year inspection interval.
The required examinations will be scheduled during the interval in accordance with Table IWD-2412-1, Inspection Program B.
Examinatione vill also be performed in the event component support member deformation is identified during operation, refueling,. maintenance, inservice examination, or testing. These examinations will not be credited toward meeting the required examinations ofIWD-2412-1.
7.1.3.1.2 PipingIntegrally Welded Attachments, Item Number DI.20 In accordance with Relief Request RR-02, a 10% sample of all nonexempt ;
VCSNS Class 3 piping integral attachments, in those systems where corrosive attack of the integral attachment is expected to be prevalent, shall be visually (VT-1) examined during the second 10-year inspection interval.
This percentage sample shall be proportional to the total number of nonexempt integrally welded attachments located within each system subject to these examinations.
The required examinations will be scheduled during the interval in accordana with Table IWD-2412-1 Inspection Program B.
Examinations will also be performed in the event component support member deformation is identified during operation, refueling, maintenance, inservice examination or testing.These examinations will not be credited i toward meeting the required examinations cfIWD-2412-1 Page 80 of 89
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4 V.C. Summer Nuclur Station
, Second 10-Year Interval Inservice Exammation Program Revision 1.
7.1.3.1.3 Pump Integrally Welded Attachments, Item Number DI.30 In accordance with Relief Request RR42, a 10% sample of all nonexempt :
VCSNS Class 3 pump integral attachments, in those systems where i corrosive attack of the integral attachment is expected to be prevalent, shall be visually (VT-1) examined during the second 10-year inspection interval.
This percentage sarnple shall be proportional to the totalnumber of nonexempt integrally welded attachments located within each system subject to these examinations.
The required examinations will be scheduled during the interval in accordance with Table IWD-2412 1, Inspection Program B.
Examinations will also be performed in the event component support .
member deformation is identified during operation, refueling, maintenance, l
inservice examination, or testing. These examinations will not be credited toward meeting the required examinations ofIWD-2412-1 7.1.3.1.4 Examination Category D-A Summary -
No. of Item Number C mPonents Remarks I Components Selected for Examination D1.10 Component Cooling Surge Tank 11 6 Vessel Condensate Storage Tank Integrally Welded Diesel Generator Coolers A,B Attachments CCW Heat Exchanger A,B RHR Heat Exchanger A,B Chiller A,B,C Examine 1 per group.
D1.20 82 10% sample of Class 3 piping 9
Piping integrally welded attachments.
Integrally Welded Attachments
- D1.30 3 Service Water Pump A,B,C 1
i Pump Integrally Welded 10% sample of Class 3 pump Attachments integrally welded attachments.
l Page 81 of 89 f
V C. Summ:r Nucinr Station Second 10-Yezr Intervel Inservice Examination Program Revision 1, 8.0 ISE PROGRAM - SYSTEM PRESSURE TESTING VCSNS has elected not to include system pressure tests in the ISE Program.
System Pressure Tests will be controlled by a separate program and therefore shall be conducted in accordance with Procedure SAP-145, ASME Section XI Pressure Testing Program.
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Page 82 of 89
V.C.Summ:r Nuclaer Station Second 10-YearInterval Imervice Examination Program Revision 1, 9.0 AUGMENTED INSERVICE INSPECTION (ISE) PROGR AM
9.1 INTRODUCTION
TO THE AUGMENTED ISE PROGRAM The Code provides rules and requirements for the inservice inspection of systems and components in a nuclear power plant facility. These rules and requirements are intended to provide assurance of the structural and pressure-retaining integrity of'utclear power plant systems and components within the Section XI scope. However, throughout the service life of VCSNS, situations such as regulatory and enforcement authority rulings, industry events, and/or SCE&G specific concerns, may necessitate " augmented" inservice examinations which are outside of the scope of the Code.
Per 10CFR50.55a(g)(6)(ii), the NRC may at any time (via 10CFR50, NUREGs, I.E. Bulletins, Regulatory Guides, etc.) impose or request that augmented inservice examinations be performed on systems and components for whi4 sdded assurance of structural reliability is desired.
Industry group reco a .endations, or SCE&G specific concerns in response to a plant site event or any other situation, may necessitate examination and/or testing of a system! component to assure continued plant safety and/or reliability. The Augmented Inservice Examination Program - a subprogram within the overall SCE&G ISE program - exists to facilitate inspection of VCSNS critical systems and components in response to these sources.
Augmented inservice examination requirements are exclusive of any Code inservice inspection requirements for the affected components.
9.2 THE AUGMElfrED ISE SUBPROGRAMS Figure 9.2-1 illustrates the individual"subprograms" which make up the VCSNS augmented examination program and their applicability to the second 10-year inspection interval. Since most of subprograms follow a subprogram-defined time line - and not the Code ten year interval- most programs are a continuation from the first inspection interval into the second. While these programs do not commence with the start of the second interval, and are not necessarily updated for the second inservice inspection interval, any references within these subprograms to the Code will be updated to the 1989 Edition.
Page 83 of 89
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V.C. Summer Nuciaer Station
- Second 10 Yearlmerval Inservice Examination Program Revision i, Figure 9.2-1 Augmented Inservice Examination Subprograms Requirement A ugmented Reference Applicable Program for Number Title Remarks to the First the Second ISE interval? ISE interval?
N/A Cracking in Feedwater I.E.Bulletin 79-13 Yes No ;
System Piping N/A Degradation of Threaded I.E. L 'letin 82-02; Yes N/A Fasteners in the Reactor Procedurally controlled Coolant Pressure by maintenance Boundary of PWR Plants activities.
N/A Undersized Nozzle-to- yes yo I.E. Notice 85-33 Shell Welded Joints in '
Tanks and Heat Exchangers Constructed Under the Rules of the ASME Boiler and Pressure Vessel Code N/A Thennal Stresses in Yes No NRC Bulletin No. 88-08 Pipmg Connected to Reactor Coolant Systems AUG-01 Reactor Coolant Pump Yes Yes Regulatory Guide 1.14 FlywheelIntegnty AUG-02 Piping Supports Yes Yes Exempted by Code Having Nonexempt Integrally Welded Attachments 9.2.1 AUG-01. Regulatory Guide 1.14 - Reactor Coolant Pump Flywheel Integritv The reactor coolant pump flywheels at VCSNS shall be examined in accordance with the recommendations outlined in Regulatory Guide 1.14, Revision 1, utilizing both surface and volumetric examination methods as specified. In accordance with Regulatory Guide 1.14, the extent and frequency ofinservice examination should be as follows:
i Page 84 of 89
. _ . . . - ~ ._ . _ . - . _ - - , - . - - ._ - .. - - -.. . -. .
V C. Summer Nuclar Station l
Second 10-YearInterval Inservice Examination Program ;
Revision 1, !
i (1)An in-place ultrasonic (UT) volumetric examination of the areas of higher l stress concentration at the bore and key way at approximately 3-year ,
intervals, during the refueling or maintenance shutdown coinciding with !
the inservice inspection schedule as required by Section XI of the ASME Code. :
i i
(2)A surface (MT or PT) examination of al! expose.1 surfaces and a complete '
ultrasonic volumetric examination at approximately 10-year intervals, j during the plant shutdown coinciding with the inservice inspection schedule t as required by Section XI of the ASME Code. !
9.2.2 AUG 02, Piping Supports Exempt by Code Having Nonexempt l Integrally Welded Attachments 1
e Certain piping supports which are exempt from Code examination i requirements, have nonexempt integrally welded attachments connected to l adjacent nonexempt piping systems. These supports have been identified by I SCE&G for an augmented visual (VT-3) examination during the second inspection interval since they are considered important to the integrity of the nonexernpt piping systems to which they are attached. Each of these i supports will be examined once during the interval. These supports are (
listed in Appendix E.
{
Page 85 of 89 4
V.C. Summer Nucletr St: tion Second lo YestIntervzt Inservice Examination Program Revision 1, '
I 10.0 RELIEF REQUESTS ,
In implementing the requirements of the Code and this ISE Program during the second IO-year inspection interval, circumstances may exist whereby, a ;
request for relief frotn Code and/or ISE Program requirements may be l necessary. Pursuant to 10CFR50.55a(g)(6)(i), where conformance with an !
examination requirement of the Code is deemed impractical, details of that ;
determination and a request for relief from Code requirements, shallbe t submitted to the NRC.
In this ISE Program, and those augmented ISE subprograms which are mandated by the NRC, petitions for relief willbe prepared, as needed,in the !
event:
i e that conformance with certain Code or augmented )
examination requirements is impractical, '
e that certain Code or augmented examinations or tests are irnpractical to perform (or to fully comply with) due to limitations in plant design, component geometry and/or materials of construction, e when alternative requirements (in lieu of Code requirements),
as found in unsanctioned Code Cases or Code editions and addenda, are deemed beneficial to this ISE Program.
P Page 86 of 89
V C. Summer Nuchsr Station Second 10-Year Intervst Inservice Examination Program Revision i.
10.1 RELIEF REQUEST MATRIX Figure 10.1 1 First ISE Interval Relief Requests vs.
Second ISE Interval Relief Requests Second Mrst Interval Interval Granted by Relief Relief the NRC fo.i Request Request the First ,
Number Number Interval? l (Note l) 1 RPV 1 (Note 2) Class 1, B-F, B5.10 + 3.90 reactor vessel outlet nozzle to Yes*
safe end welds (weld 1 on drawings CGE-1-4100,-4200, & - Note 2 ,
l 4300). Second interval exam to be performed at end of ist j l interval. '
Class 1, B4, B9.11 + 3.90 reactor vessel outlet safe end to I pipe welds (weld 2 on drawings CGE-1-4100,-4200, & - !
4300). Second interval exam to be performed at end of1st '
interval.
1-RPV 2 N/A Class 1, B-A, Bl.40 - RPV Closure head to flange weld 1 - Not Extent of examination coverage. Required 1-PRESS-1 N/A Class 1, B-F, B5.20 - PZR nozzle to safe end welds - Extent Yes of examination coverage.
Class 1, BJ, B9.11 - PZR nozzle safe end to pipe welds -
Extent of examination coverage.
1-PRESS-2 N/A Class 1, B-D, B3.110 & B3.120 - PZR nozzle to vessel welds, Yes and inside radius sections - Extent of examination coverage.
1-PRESS-4 N/A Class 1, B-B, B2.11 - PZR circumferential head to shell Not welds - Extent of examination coverage. Required 1-SG-1 N/A Class 1, B-F, B5.30 - SG nozzle to safe end welds - Extent of Yes examination coverage.
Class 1, BJ, B9.11 - SG nozzle safe end to pipe welds -
Extent of examination coverage.
1-PIPE-1 N/A Class 1, BJ, B9.31 - Branch connection welds - Extent of Yes examination coverage.
1-PIPE-2 N/A Class 1, BJ, B9.11 & B9.12 - Circumferential & Yes longitudinal welds - Extent of examination coverage.
Page 87 of 89
V C. Summer Nuclear Station Second 10. Year Interval Inservice Examination Program Revision i, Second First Interval Interval Granted by {
Relief Relief g the NRC for Request Request the First '
Number Number Interval?
(Note 1) i 2-HX-1 N/A Class 2, C-A, C1.10 & C1.20 - Vessel welds - Extent of Yes examination coverage. ,
2-HX-2 N/A Class 2, C-B, C2.20 - Nozzle to vessel welds - Extent of Yes examination coverage.
2-HX 3 N/A Class 2, C-A, C1.10 & C1.20 - Vessel welds - Relief from UT Yes examination, surface and visual as alternative methods.
2-HX 4 N/A Class 2, C-B, C2.20 - Nozzle to vessel welds - Relief from Yes '
Code required UT & surface exams, surface exam on -
reinforcement saddle as alternative method. !
2-SG 1 N/A Class 2, C-B, C2.20 - Nozzle to vessel welds - Extent of Yes f examination coverage.
2 SG-2 N/A Class 2, C-A, C1.10 & C1.20 - Vessel welds - Extent of Yes i examination coverage. !
2-PIPE-1 N/A Class 2. C-F, C5.21 & C5.22 - Circumferential & No !
longitudinal welds - Extent of examination coverage. ;
2-PIPE-2 N/A Class 2, C-F, C5.21 & C5.22 - Circumferential & No longitudinal welds - Extent of examination coverage. ,
RR-02 Examination of Class 1,2, & 3 nonexempt integrally 5 welded attachments in accordance with the requirements I of Code Case N 509. '
RR-06 Class 1,2 & 3 Snubbers will be examined and tested per ;
Technical Specifications in lieu of ASME requirements. l f
Note 1: N/A indicates that a parallel relief request for the second inspection interval l is not needed.
Note 2: The NRC approval of this Relief applies to the second interval and all !
subsequent intervals. i i
)
i Page 88 of 89
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V.C. Summsr Nuctur Station Second lo YearInterval inservice Examination Program Revision i, 10.2 VCSNS RELIEF REQUESTS - SECOND INSERVICE INSPECTION INTERVAL i
l All VCSNS requests for relief for the second inservice inspection interval )
submitted with this ISE Program, will include the following information, as j applicable: l e A unique alphanumeric identifier for the Relief Request, e Identification of the component (s) for which reliefis being requested, including a brief description of the component, l t
e The ASME Code Class, Examination Category, and Item Number applicable to the component (s), !
e The specific requirement (s) from which reliefis requested, or for which ;
alternative requirements are proposed, I
e The basis for relief (e.g. information supporting the determination that the Code requirement is impractical to conform to),
e Where reasonable, a description of the substitute examination (s) or test (s) which will be performed in lieu of the requirements deemed
- impractical, and e The schedule for implementation of the alternate examination or test.
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)
I Page 89 of 89 j
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V.C. Summer Nucler.r Station Second 10 YesrIntarval Inservice Examination Program Revision i, l
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I I
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l APPENDIX A -Ultrasonic Examination Calibration Standards I
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V.C. Suminer Nuctur Station Second 10.YearInterni Inservice Examination Program Revision i, APPENDIX A Ultrasonic Examination Calibration Standards Calibration Standard Identification heNh CGE-1 SS 2" Sch 160 0.355 CGE-2 SS 3" Sch 160 0.448 CGE-3 SS 4" Sch 160 0.536 CGE-4 SS 6" Sch 160 0.746 CGE-5 S3 12" Sch 140 1.077 CGE-6 SS 14" Sch 140 1.217 CGE-7 RV Stud CS 7" 7" CGE-8 Press. Skt. CS 1 1/2" x 4" x 13" 1.507 CGE-9 RC Pipe CC/SS 3" x 3" x 8" 3.000 CGE-10 SS 1-1/2" Sch 160 0.285 CGE-11 SS 6" Sch 40 0.274 CGE-12 SS 8" Sch 40 0.341 CGE-13 SS 10" Sch 40 0.404 CGE-14 SS 12" Sch 40 0.374 CGE-15 SS 14" Sch 40 0.450 CGE-16 SS 10" Sch 140 1.053 CGE-17 CS 6" Sch 40 0.305 CGE-18 CS 8" Sch 100 0.625 CGE-19 CS 16" Sch 80 0.846 CGE-20 CS 12" Sch 80 0.669 CGE-21 CS 18" Sch 80 0.933 CGE-22 CS 32" 1.201 CGE 23 Unclad CS
)
3-1/2" x 6" x 18" 3.500 CGE-24 Clad CS 3-1/2" x 6" x 12-1/4" 3.500 CGE-25 Clad CS 5-1/2" x 6" x 19-1/4" 5.500 ;
CGE-26 CS 30" 1.810 I CGE-27 CS 24" Sch 80 1.198 CGE-28 SS 6" Sch 120 0.581 CGE-29 SS 8" Sch 160 0.904 CGE-30 SS .312" x 4" x 9" 0.313 CGE-31 SS .755" x 4" x 9" 0.755 CGE-33 CS 7" x 6" x 27" 7.000 CGE-34 CS 14" Sch 60 0.598 CGE-35 CS 16" Sch 30 0.373 CGE-36 CS 2" x 6" x 10-3/4" 2.000 CGE-37 CS 8" Sch 40 0.323 UT-002 RC Pitse SS 4" x 2.6" x 9" 2.330 l
A-1 l
r V C. Summer Nuchu Station Second 10 YearInterval Inservice Examination Program Revision i, Appendix B - Multiple-Component Group 1
en
V C. Summer Nuclear Station Second 10-Yea r interval Inservice E xammation Program Revision i, APPENDIX B Multiple-Component Groups Group Component Component CastJorged Code Number Idr si Description Matenal Class
' SG-01 XSG-2A-RC Steam Generator i1) SA-216 GR- 1/2 Steam Generators XSG-2B-RC WCC XSG-2C-RC (2) SA-533 GR-A HX-01 XHE-5A RH Heat Exchanger SA-304 CS 2/3 Residual Heat Removal Heat XHE-5B-RH Exchangers HX-02 XHE-2A-CC Heat Exchanger SA-515 GR-70 3 Component Cooling Heat XHE-2B-CC Exchangers HX-03 XAA-0001 A Heat Exchanger SA-36 Plate 3 Reactor Building Coolers XAA-0001B XAA-0002A XAA-0002B HX-04 XHE-0017A Heat Exchanger SA-106 3 Diesel Generator Coolers XHE-0017B HX-05 XHX-0001A Heat Exchanger SA-515 GR-70 3 Chillers XHX-0001B XHX-0001C PU-01 XPP-30A-RC Pump SA-351 CFB 1 Reactor Coolant Pumps XPP-30B-RC XPP-30C-RC PU-02 XPP-43A-CS Pump SA-182 GR-F304 2 Charging Pumps XPP-43B-CS XPP-43C-CS PU-03 XPP-38A-SP Pump SA-316 2 Reactor Building Spray Pumps XPP-38B-SP PU-04 XPP-31 A-RH Pump SA-182 GR-F304 2 Residual Heat Removal Pumps XPP-31B-RH PU-05 XPP-48A-VU Pump SA-216 WCB 3 Chilled Water Pumps XPP-48B-VU XPP-48C-VU l
l
V C. Sumroer Nuclear Station Second 10. Year interval Inservice Examination Program Revision 1, Multiple-Component Groups Group Coroponent Component Cast,Torged' Code Number Idts) Description Matenal Class PU-06 XPP-1 A-CC Pump SA-216 3 Component Cooling Pumps XPP-1B-CC XPP-1C-CC PU-07 XPP-21A-EF Pump SA-487 3 Emergency Feedwater Pumps XPP-21B-EF PU-08 XPP-39A-SW Pump SA-352 3 Service Water Pumps XPP-39B-SW XPP-39C-SW PU-09 XPP-45A SW Pump SA-216 WCB 3 Service Water Booster Pumps XPP-45B-SW VL-01 XVS-8010A 6" Relief Valve Forged 1 Over pressure protection of RCS XVS-8010B SA-182 during transients.
XVS-80100 )'
VL-02 XVG-8701 A 12" Gate Valve Forged 1 XVG-8701B SA-182 XVG-8702A XVG-8702B VL-03 XVC-8948A 12" Check Valve Forged 1 SI accumulator isolation from the XVC-8948B SA-182 RCS.
XVC-8948C XVC-8956A l XVC-8956B j XVC-8956C '
VL-04 XVC-8998A 6" Check Valve Forged 1 Low-Head /Hi-Head SIisolation to XVC-8998B SA-182 the RCS cold leg. ;
XVC-8998C 1 i
VL-05 XVC-8993A 6" Check Valve Forged 1 Low-Head /Hi-Head SIisolation to j XVC-8993B SA-182 the RCS hot leg. '
XVC-8993C VL-06 XVC-8973A 6" Check Valve Forged 1 Low-Head SIisolation when Hi-XVC-8973B SA-182 Head S1is in service.
XVC-8973C XVC-8988A XVC-8988B l
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V.C.Summar Nuctur Station
- Second 10 YearInstrval Inservice Examination Pregram Revision 1, i
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i APPENDIX C - INSERVICE INSPECTION DRAWINGS '
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V C. Summ2r Nueher Station Second 10-YearIntzrval Inservice Exammauon Program Revision 1, Inservice Inspection Drawings ISE Classification and Boundarv Identification Drawings (Flow Diagrams)
D-302-011 Main Steam (Nuclear)
D-302-083 Feedwater (Nuclear)
D-302-085 Emergency Feedwater (Nuclear)
D-302-221 Service Water Cooling D-302-222 Service Water Cooling D-302-353 Diesel Generator - Miscellaneous Services E-302-601 Reactor Coolant E-302-602 Reactor Coolant D-302-611 Component Cooling D-302-612 Component Cooling Inside Reactor Building D-302-613 Component Cooling System Non-Essential Cooling E-302-641 Residual Heat Removal D-302-651 Spent Fuel Cooling D-302-661 Reactor Building Spray System E-302-671 Chemical & Volume Control E-302-672 Chemical & Volume Control E-302-673 Chemical & Volume Control E-302-675 Chemical & Volume Control E-302-691 Safety Injection E-302-692 Safety Injection E-302-693 Safety Injection D-302-841 Chilled Water - Pump and Chiller Area D-302-842 Chilled Water - To Cooling Coils "A" D-302-843 Chilled Water - To Cooling Coils "B" C-1
f V.C. Summsr NucLacr Station Second 10-Year Intervst Inserv ce Examination Program Revision i, ISE Composite Isometric Sketches & Component Drawing 1MS-17-084-5 C-314-251-02 C-314-671-03 1MS-22-108-0 5 C-314-251-04 C-314-671-06 1MS-22-110 C-314-251-05 C-314-671-07 1MS-22-2262-1 C-314-251-07 C-314-671-08 1MS-22-2263-1 C-314-251-08 C-314-671-10 i 1MS-22-2264-1 C-314-251-11 C-314-671-11 l 1MS-22-260-0-9 C-314-251-12 C-314-671-12 '
1MS-22 261-0-9 C-314-251-13 C-314-671-23 ,
IMS-22-2692-4 C-314-251-15 C-314-671-24 1MS-22-303-0-2 C-314-251-17 C-314-671-25 1MS-22-384-4 C-314-601-01 C-314-671-27 1MS-22-391-2 C-314-601-03 C-314-671-31 l 1MS-22-550-0-3 C-314-601-04 C-314-691-01 1MS-22-551-0-4 C-314-601-05 C-314-691-02 1MS-22-552-0-3 C-314-60128 C-314-691-03 1MS-22-553-0-4 C-314-611-01 C-314-691-04 1MS-22-554-0-4 C-314-611-06 C-314-691-05 1MS-22-559-0-5 C-314-611-08 C-314-691-06 1 1MS-22-560-0-8 C-314-611-09 C-314-691-07 1MS-22-561-0-5 C-314-611-10 C-314-691-08 1MS-22-623-0-3 C-314-611-11 C-314-691-09 1MS-22-624 0-4 C-314-611-12 C-314-691-10' 1MS-22-625-0-3 C-314-611-13 C-314-691-11 1MS-22-626-6 C-314 611-14 C-314-691-12 1MS-22-638-0-2 C-314-611-15 C-314-691-13 1MS-22-698-0-2 C-314-611-16 C-314-691-14 1MS-54-087-1-8 C-314-611-17 C-314-691-15 1MS-54-617-1 C-314-611-18 C-314-691-16 C-314-011-01 C-314 641-01 C-314-691-17 C-314-011-02 C-314-641-02 C-314-691-18 C-314-011 03 C-314-641-03 C-314-691-19 C-314-011-14 C-314-641-04 C-314-691-20 C-314-011-15 C-314-641-05 C-314-691-21 C-314-011-16 C-314-641-06 C-314-691-22 C-314-011-20 C-314-641-07 C-314-691-23 C-314-011-21 C-314-641-08 C-314-691-24 C-314-011-22 C-314-641-11 C-314-691-25 C-314-081-01 C-314-641-14 C-314-691-26 C-314-081-02 C-314-641-15 C-314-731-01 C-314-081-03 C-314-661-01 CGE-11100 C-314-081-23 C-314-661-02 CGE-1-1100A C-314-081-25 C-314-661-03 CGE-1-1100B C-314-081-27 C-314-661-04 CGE-1-1200
- C-314-081-30 C-314-661-05 CGE-1-1200A C-314-081-31 C-314-661-06 CGE-1-1250 C-314-081-32 C-314-661-07 CGE-1-1300 C-314-085-01 C-314-661-08 CGE-1-1300A C-314-085-02 C-314-661-09 CGE-1-1400 C-314-085-03 C-314-661-12 CGE-1-2100A ,
C-314-085-04 C-314-661-13 CGE-1-2100B C-314-085-05 C-314-671-02 CGE-1-3100 C-2 i
V.C. Summer N ucbu Stati:n
, Second 10-Year Inttrvel Inservice Exannnation Program Revision 1, ISE Composite Isometric Sketches & Component Drawing CGE-1-4100A CGE-2-1130A CGE-2-2558 CGE-1-4101A CGE-2-1140A CGE-1-4102A CGE-2-1150 CGE-2-2559 CGE-1-4103A CGE-2-1160 CGE-2-2560 CGE-1-4104A CGE-2-1200 CGE-2-2561 CGE-1-4105A CGE-2-1220 CGE-2-2562 CGE-1-4106A CGE-2-1310 CGE-1-4107A CGE-2-1320 CGE-2-3000 CGE-1-4110A CGE-2-2100A CGE-2-3001 CGE-1-4111A CGE-2-2101A CGE-2-3002 CGE-1-4112A CGE-2-2101B CGE-2-3003 CGE-1-4113A CGE 2-2102A CGE-1-4114A CGE-2-2103A CGE-2-3004 CGE-1-4200A CGE-2-2104A CGE-2-3005 CGE-1-4201A CGE-2-2200A CGE-2-3006 CGE-14202A CGE-2-2201A CGE-2-3007 CGE-1-4203A CGE-2-2202 CGE-1-4205A CGE-2-2203 CGE-2-3008 CGE-1-4208A CGE-2-2204A CGE-2-3009 CGE-1-4209A CGE-2-2300 CGE-2-3010 CGE-1-4209E CGE-2-2301 CGE-2-3011 CGE-1-4210A CGE-2-2302 CGE-1-42?.1A CGE-2-2303 CGE-2-3012 CGE-1-423 2 CGE-2-2304 CGE-2-3013 CGE-1-4309A CGE-2-2500 CGE-2-3014 CGE-1-430i CGE-2-2501 CGE-2-3100 CGE-1-4302 CGE-2-2520A CGE-1-4303 CGE-2-2521A CGE-2-3110 CGE-1-4304 CGE-2-2521B CGE-2-4100 CGE-1-4308 CGE-2-2522A E-302-085 CGE-1-4309 CGE-2-2522B E-302-221 CGE-1-4310 CGE-2-2523A CGE-1-4311 CGE-2-2523B E-302-222 CGE-1-4312 CGE-2-2523C E-302-601 CGE-1-4500A CGE-2-2524 E-302-611 CGE-1-4501 CGE-2-2525 CGE-1-4502 CGE-2-2526 CGE-1-4503 CGE-2-2540A CGE-1-4504 CGE-2-2540B CGE-1-4505A CGE-2-2541 CGE-1-4506A CGE-2-2550 j CGE-2-2551A CGE-1-5100A CGE-2-2551B CGE-1-5100B CGE-2-2552 CGE-1-5100C CGE-2-2553 C CGE-2-2554 CGE-2-1100 CGE-2-2556A CGE-2-1110 CGE-2-2557A CGE-2-1120A C-3
V.C. Summer Nucl=r St tion Second 10 YsarIntervsl Inservice Examination Program Revision 1, l
l APPENDIX D - Relief Requests 1
I D-i
V C. Summrr Nuciar Station
' Second 10 Year Interval Inservice Examination Program Revision 1, RELIEF REQUEST 1-RPV-1 I. IDENTIFICATION OF COMPONENTS V.C. Summer Nuclear Station, Class 1 Reactor Vessel Outlet Nozzle-to-safe End Welds, and Outlet Safe End-to-pipe Welds: .
Isometric Drawing Weld Number Category item Number CGE-1-4100 1* B-F; B-D B5.10; 3.90 CGE-14200 1* B-F;B-D B5.10; 3.90 CGE 14300 1* B-F;B-D B5.10; 3.90 CGE-1 4100 2 B-J; B-D B9.11; 3.90 CGE-1-4200 2 B-J; B-D B9.11; 3.90 CGE-1-4300 2 B-J; B-D B9.11; 3.90
- Dissimilar Metal -
II. CODE REQUIREMENTS FROM WHICH RELIEF IS REQUESTED ASME Boiler and Pressure Vessel Code,Section XI,1977 Edition including ;
Summer 1978 Addenda, Table IWB-2500-1, Category B-D: Item B3.90, l requires the following inspection in the second interval.
l All Welds which apply to Item B3.90 are to have volumetric examinations .
performed each inspection interval such that at least 25% but not more than 50% (credited) of the nozzles shall be examined by the end of lai. inspection period and the remainder by the end of 3rd inspectionperiod of each inspection interval. (The above welds represent 50% of the welds).
III. ALTERNATE TEST Perform the second ten year interval examinations on the welds listed above during the seventh refueling (RF-7) outage; which is eight months prior to the beginning of the second interval. Also, revise the examination requirements such that 100% of the nozzle-to-vessel welds are inspected in the 3rd period of the 2nd and subsequent inspection intervals.
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V.C.SummerNucLar Stati:n Second 10-YearInterval Innervice Examination Program Revision 1 IV. BASIS FOR RELIEF ,
l First, the second ten year inspection interval begins approximately eight months after RF-7. Second, by performing these examinations during RF-7, i 1
the outlet nozzles will be inspected in the same outage as the inlet nozzles !
utilizing one Ultrasonic Testing (UT) acquisition system. This provides l common acquisition data which willincrease the reliability of the data as it !
relates to the condition of both the inlet and outlet nozzles. Third, the reactor lower internals will be removed during the RF-7 outage as opposed to being in place during the second interval inspection. This prevents the possibility of the remote examination equipment causing damage to the lower internals during the second intervalinspection. '
Furthermore, delaying these examinations will result in the following hardships:
(1) The predicted dose related to performing these examinations in the second 10 year interval is 2.5 REM greater than performing the inspection during RF-7.
(2) The additional manpower, cost, and critical path outage time associated with performing these examinations in the second interval would be saved by performing the examnations in RF-7.
In summary, performing the examinations approximately eight months prior j to the second ten year interval creates several advantages and avoids some hardships without affecting the level of quality of safety in the plant.
i D-2 i
I V.C.SummerNuclar Station second 10-YearIntervsl l Inservice Examination Program Revision i,
{
RELIEF REQUEST RR-02 i INTEGRALLY WELDED ATTACHMENT RELIEF REQUEST (CODE CASE N-509)
COMPONENTS:
All Class 1,2, and 3 integrally welded attachments subject to inspection per Section XI of the 1989 Edition of the ASME Code.
I CODE REQUIREMENT:
IWB-2500,IWC-2500 and IWD-2500 of the 1989 Edition of ASME Section XI requires i that all integrally welded attachments that apply to the examination categories B-H, B-K-1, C-C, D A, D-B and D-C are examined each interval.
RELIEF REQUEST:
To be allowed the option of utilizing the provisions of Code Case N-509, " Alternative Rules for The Selection and Examination of Class 1, 2, and 3 Integrally Welded AttachmentsSection XI, Division 1".
BASIS FOR RELIEF:
Code Case N-509 has been developed and approved (11-25-92) by the ASME as an acceptable alternative to the above requirements. This alternative is based on the optimization of support inspection which combines the focus of integrally welded attachments with overall support inspection and emphasizes those attachments associated with a deformed support member. The approval of the Code Case by ASME demonstrates the position that the current requirements are more extensive than is required to assure system integrity. Thus, SCE&G believes that applying the current Code Requirements presents an undue hardship without a corresportding -
increase in safety. Therefore SCE&G request approval to allow the option of applying Code Case N-509 to the 2nd ten-year interval.
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V.C. Su2nmer Nuclear statirn second 10-YearInterval Inservice Examination Program Revision 1 RR-06 SNUBBER RELIEF REQUEST COMPONENTS:
All Non-exempt snubbers re<pired to be inspected and tested by the provisions of IWF-5300.
CODE REQUIREMENT: i Subarticle IWF-5300 of the 1989 edition of the ASME Boiler Pressure Vessel Code,Section XI requires that snubbers are to undergo inservice examination and testing per the 1988 Addenda to ASME/ ANSI OM-1987, Part 4. These requirements provide the methodology and corrective actions for examining snubbers and for functional testing snubbers.
RELIEF REQUEST:
To exempt the applicable snubbers from the requirements of IWF-5300 and as an alternative, perform the required examination and testing of snubbers as prescribed by Technical Specifications.
1 ALTERNATE TEST:
Apply the visual examination and functional testing requirements that are prescribed by Technical Specifications (including samphng and frequency requirements) to the components identified above.
BASIS FOR RELIEF:
V. C. Summer Nuclear Station (VCSNS) is required to incorporate the 1989 edition of the ASME Code as the governing requirement for the second ten-year inservice inspection interval. These requirements contain snubber examination and testing methodologies that are nearly identical to the methodologies prescribed in the Technical Specification for examination and testing of snubbers. Having two nearly redundant sets of snubber requirements presents unnecessary confusion in sample selection, data collection, acceptance criteria, and corrective actions. These requirements will in some cases cause a duplication of test documentation. However, in other cases, additional confusion is created by the difference in snubber categories. :
Approximately half of the snubbers at VCSNS are required to be tested by both Technical Specifications and the ASME Code. The other half are only required to be tested by one of the requirements. Therefore, sampling becomes very confusing since some snubbers may be applicable to both requirements and others to only one. For the same reason acceptance criteria and corrective actions become diflicult to apply. I I
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One area where the requirements do not closely resemble each other is the inspection frequency changes in response to visual examination failures. The differences can cause different frequency requirements to be prescribed to a single group of snubbers as a result of the same inspection. This situation obviously would increase the possibility of applying the wrong action thus creating a nonconformance, an inoperability or even a violation of Technical Specifications. Also, the ASME has ,
recently approved a revision to the snubber examination requirements that I incorporates the Technical Specification Table for inspection frequency into Section XI. Therefore, the ASME is in agreement that these actions should not be in conflict.
In order to remove the confusion and impracticability of trying to administer such similar requirements to snubber categories that partially overlap and to remove the !
aossibility of requiring contradicting actions to apply to the same snubber (s), VCSNS believes that meeting the requirements that are contained in the Technical Specifications for all the snubbers which apply to either category will provide sufficient testing of snubbers. Therefore, the proposed alternate test will provide an ,
acceptable level of quality, and compliance with the Code would result in a hardship without a compensating increase in quality or safety.
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