ML20084T251
| ML20084T251 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/31/1989 |
| From: | Beth Brown, Mudlin J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20084T253 | List: |
| References | |
| CON-FIN-D-6022 EGG-MS-7783, TAC-M64000, NUDOCS 8911270172 | |
| Download: ML20084T251 (103) | |
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- i-TECHNICAL EVALUATION REPORT
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TECHNICAL EVALUATION REPORT ON THE FIRST 10 YEAR e /daho INTERVAL INSERVICE INSPECTION PROGRAM PLAN:
[' Nat/onal GEORGIA POWER COMPANY, Eng/neering V0GTLE ELECTRIC GENERATING PLANT, UNIT 1, DOCKET NUMBER 50 424 Laboratory li '
Managed by the U S- B. W. Brown Department J. D. Mudlin ofEnergy
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o EGG MS 7783 TECHNICAL EVALUATION REPORT ON THE li- FIRST 10-YEAR INTERVAL INSERVICE:IldPECTION PROGRAM PLAN:
GEORGIA F0WER COMPAN/, ,
V0GTLE ELECTRIC GENERATING PLANT, UNIT 1, DOCKET NUMBER 50 424 B. W. Brown J. D. Mudlin Published October 1989 9
-Idaho National Engineering Laboratory EG&G Idaho, Inc..
Prepared for:
U.S. Nu learLRegulatory Commission-Washington, D.C. 20555-
, : under *
AL. . s .
ABSTRACT This report presents the results of the evaluation of the Vogtle Electric Generating Plant, Unit 1, First 10 Year interval inservice Inspection (ISI)
Program, through Revision 3, .abmitted May 10, 1989, and the Vogtle Electric Generating Plant, Unit 1. First 10 Year Interval 151 Plan, Revision 0, submitted October 21, 1987. The Program includes tLe requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical. The Vogtle Electric Ceneratti.g Plant, Unit 1. First 10 Year Interval ISI Program and Plan are evaluated in Section 2 of this report.
The ISI Program and Plan are evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability of examination sa'nple, (c) correctnass of the application of system or component examinationexclusioncriteria,and(d)compliancewithISI-related commitments identified d9ritig the Nuclear Regulatory Commission (NRC) review before granting an operating license. The requests for relief frcm the ASME Code requirements which the Licensee has determined to be impractical for the first 10 year inspection interval are evaluated in Section 3 of this report.
This work was funded under:
U.S. Nuciear negulatory Commission FIN No. D6022, Project 5 Operating Reactor Licensing issues Program, Review of ISI for ASME Code Class 1, 2, and 3 Components ii
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SUMMARY
i The Licensee, Georgia Power Company, has prepared the Vogtle Electric Generating Plant, Unit 1 First 10 Year Interval inservice Inspection (151)
Program and Plan to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the Class 2 welds in the residual heat removal, emergency core cooling, and containment heat removal systems w m ' selected according to the 1974 Edition throuch Summer 1975 Addend a rs ed by 10 CFR 50.55a(b). The first 10 year interval began June 1, 7 c. ends June 1, 1997.
The information in the Vogtle Electric Generating Plant, Unit 1 First 10 Year Interval 151 Program, Revision 0, submitted November 24, 1986, was reviewed, including the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical. As a result of this review, a request for additional information (RAl) was prepared describing the information and/or clarification required from the Licensee in order to complete the review.
In response to the RAI, the Licensee submitted Revision 0 of the Vogtle Electric Generating Plant, Unit 2. First 10 Year Interval ISI Plan (10 volume set) on October 21, 1987. Revisions 1 and 2 of the Vogtle Electric Generating Plant, Unit 1 First 10 Year Interval 151 Program were ,
received in a submittal dated July 18, 1988. Revision 3 of the Vogtle .
Electric Generating Plant, Unit 1, First 10 Year Interval 151 Program was received in a submittal dated May 10, 1989, based on the review of the Vogtle Electric Generating Plant. Unit 1. First 10 Year Interval DI Program and Plan, the Licensee's responses to the NRC's RAI, and the recounendations for granting relief from the ISI examination requirements that have been determined to be impractical, it has been concluded that the Vogtle Electric Generating Plant, Unit 1, first 10 Year Interval ISI Program and Plan, with the exception of Requests for Relief RR 45, RR 47 RR 48 and RR 54, are acceptable and in compliance with 10 CFR 50.55a(g)(4).
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c.CNTENTS A B S T RA C T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i i
SUMMARY
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- 1. INTRODUCTION ........................................................ 1
- 2. EVALVATION OF INSERVICE INSPECTION PROGRAM PLAN ..................... 4 2.1 Do c t. cn e n t s E v a l u a t e d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.2 Compliance with Code Requirements ................................ 5 2.2.1 Compliance with Applicable Code Editions . . . . . . . . . . . . . . . . . . . . . 5 2.2.2 Acceptability of the Examination Sample ...................... 5 2.2.3 Exclusion Criteria ........................................... 6 2.2.4 Augmented Examination Commitments ............................ 6 2.3 Conclusions ...................................................... 7
- 3. EVALUATION OF RELIEF REQUESTS ....................................... 8 3.1 Class 1 Components ............................................... 8 3.1.1 Reactor Pressure Vessel ...................................... 8 3.1.1.1 Relief Requests RR 1, RR-2, RR 3, RR 4, RR-5, RR-7, and RR 39, Examination Category B A, Pressure Retaining Welds in the Reactor Pressure Vessel .. ... . . . ... 8 3.1.1.2 Relief Requests RR-6, Examination Category B G-1, Reactor Pressure Vessel Flange Ligament Areas ........... 11 3.1.1.3 Relief Request RR 9, Examination Category B G-1, Reactor Pres sure Vessel Studs . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 3.1.1.4 Relief Request RR-ll, Examination Category F 8, Visual Examination of Reactor Vessel Supports . . . . . . . . . . . 15 3.1.1.5 Relief Request RR 40, Basic Ultrasonic Calibration Blocks for Examination of the Reactor Pressure V e s s e l W e l d s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , 17 3.1.1.6 Reitof Request RR 52, Examination Category B-H, e Reactor Pressure Vessel Integrally Welded Attachments ............................................. 18 iv
3 .1. 2 - P r e s s u r i z e r . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 3.1.2.1 Relief Requests RR 10 and RR 16. Examination Category B H, Pressurizer Integrally Welded Attachments ............................................. 19 3.1.2.2 Relief Requests RR 12, RR 14, and RR IS, Examination Categcries B 8, B.0, and B F, Pressurizer Vessel and Surge Nozzle to Vessel Welds ............................ 21 3.1.2.3 Relief Request RR-13. Ultrasonic Calibration Blocks for the Pressurizer Nozzle to Safe End Welds ................................................... 24 3.1.3 Heat Exchangers and Steam Generators ........................ 25 3.1.3.1 Relief Request RR 19, Examination Category B B, Volumetric Examination of Steam Generator Channel Head to Tube Sheet Weld ................................. 25 3.1.3.2 Relief Request RR 42. Examination Category B 0, Volumetric Examination of Steam Generator Inint and Outlet Nozzle Inner Radii . . . . . . . . . . . . . . . . . . . . . 27
- 3. l'. 4 Piping Pressure Boundary .................................... 29 3.1.4.1. Relief Request RR 8 RR 17 RR 20, RR 24, and RR 26 (part 1 of 2), Examination Category B J, Pressure Retaining _ Welds in Class 1 Piping . . . . . . . . . . . . . . 29 3.1.4.2 Relief Request RR 21, Examination Category B J, Class 1 Branch Connection Welds 4 Inch and larger Nomi nal Pipe Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 3.1.4.3 1 Relief Requests RR 22 and RR-23 Ultrasonic .
- Techniques and Calibration Blocks for Examination of Pressure Retaining Welds of Cast-Stainless Steel (GradeSA351-CF8A)Componentsinthe. Reactor C ool a n t Sy s t em . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 3.1.4.4 Relief Request RR 25, Ultrasonic Calibration Block for Examination of Pressure Retaining Reactor Cool ant Pump Nozzle to Pipe Welds . . . . . . . . . . . . . . . . . . . . . . . 41 3.1.4.5 Relief Request RR 41, Basic Ultrasonic Calibration Blocks for Examination of the Reactor Pressure
, Vessel Nozzle-to Safe End Welds . . . . . . . . . . . . . . . . . . . . . . . . . 43 3.1.5 Pump Pressure Boundary ...................................... 45 3.1.5.1 Relief Request RR-27, Examination Categories B-L-2 and B M 2, Visual Examination of Class 1 Pump Casings and Valve Bodies ................................ 45 y
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3.1.6 Valve Pressure Boundary ..................................... 47 3.1.6.1 Relief Request RR 27. Examination Categories B L-2 and B M 2, Visual Examination of Class 1 Pump Casings and Valve Bodies (See the evaluation of this relief request under Section 3 .1. 5 .1 ) . . . . . . . . . . . . . . . . . . . . . . . . . . 47 3.1.7- General (Noreliefrequests) 3.2 Cl a s s 2 C omp on e n t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 3.2.1 Pre s su re Ve s s el s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 3.2.1.1 Relief Requests RR 28 and RR 32. Examination Category C 8, Class 2 Vessel Nozzle Inner Radius Sections ......................................... 48 3.2.1.2 Relief Requests RR 29 and RR 30 (part 1 of 2),
Examination Categories C A and C 8, Class 2 Vessel and Nozzle to Vessel Welds ....................... 50 3.2.1.3 Relief Request RR 31, Use of Piping Calibration Blocks to Examine Thin Wall Vessel s . . . . . . . . . . . . . . . . . . . . . 53 3.2.2 Piping ...................................................... 55 3.2.2.1 Relief Request-RR 26 (part 2 of 2) and RR 34, Examination Category C-F, Pressure Retaining Wel d s i n Cl a s s 2 Pipi ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55 3.2.2.2 Relief Requests RR 35, RR 36, and RR-37, Augmented Volumetric Examination of Class 2 Piping Welds.
in the Engineered Safety Systems ........................ 57 3.2.3 Pumps ....................................................... 61 3.2.3.1. Relief Request-RR 30 (part 2 of 2). Examination Category C G, Class 2 Pump Casing Weld .................. 61 3.2.4 Valves (Noreliefrequests) 3.2.5 General ..................................................... 62 l3.2.5.1 Relief Request RR 33 Examination Category C 0, Pressure Retaining Class 2 Bolting Exceeding 2 Inch Diameter ......................................... 62-3.3 Class'3 Components (No.reliefrequests)-
3 .' 4 Pressure Tests ......s.... ...................................... 63 3.4.1 Class 1 System Pressure Tests (Noreliefrequests) vi lE
m.w 3.4.2 Class 2 System Pressure Tests ............................... 63 3.4.2.1 Relief Request RR 44 Examination Category C H, Hydrostatic Test of Class 2 Components Which Cannot be Isolated from Class 1 Components . . . . . . . . . . . . . . 63 3.4.2.2 Relief Request RR 45 Examination Category C H, Class 2 System Hydrostatic and System Pressure Tests ................................................... 66 3.4.2.3 Relief Request RR 46, Examination Category C-H, Visual (VT 2) Examinations During System functional or System inservice Test ..................... 68 3.4.3 Class 3 System Pressure Tests ............................... 70 3.4.3.1 Relief Request RR 48. Examination Category D A, Class 3 System Inservice Test on Systems Used in Support of Reactor Shutdown Function . . . . . . . . . . . . . . . . . 70 3.4.3.2 Relief Recuest RR 49 Examination Category D A, System Hycrostatic Test and Visual (VT-2) Examination on Cl ass 3 Vertical Pit-Type Pumps . . . . . . . . . . . . . . . . . . . . . . 72 3.4.3.3 Relief Request RR 50. Examination Categories D A, D-B, and D C, Visual (VT-2) Examinations During System Functional or System Inservice Tests ............. 74 3.4.3.4 Relief Request RR 51, Examination Category D 8, Visual (VT 2) Examination During System Functional Test .................................................... 76 3.4.3.5 Relief Request RR 53 Examination Category D-C.
VT 2 Visual Examination During Hydrostatic and System inservice Tests of Spent Fuel Cooling and Purification System ..................................... 78 3.4.4 General ..................................................... 80 3.4.4.1 Relief Request RR 47, Examination Categories C H.
D-A, and D 8, Visual (VT-2) Examinations During System functional or System Inservice Tests of Systems Which Contain Air During System Operation ....... 80 3.4.4.2 Relief Request RR 54, Examination Categories B-P, C H, D A, D-8, and D C, Hydrostatic Testing of Piping Systems 1 Inch and Less Nominal Pipe Size .............................................. 4 .... 82 vii
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3.5 General ......................................................... 84 3.5.1 Ultrasonic Examination Techniques ........................... 84 3.5.1.1 Relief Request RR 18, Use of ASME Code Section XI, Appendix 111 for Ultrasonic Examination of Austenitic and Dissimilar Metal Piping Welds ............ 84 3.5.2 Exempted Components (Noreliefrequests) 3.5.3 Other ....................................................... 86 3.5.3.1 Relief Request RR-38, Subsection IWE, Requirements for Cl a s s HC Component s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86 3.5.3.2 Relief Request RR 43 Visual Examination (VT 4) ofSnubbers............................................. 88
- 4. CONCLUSION ......................................................... 90
- 5. REFERENCES ......................................................... 9?
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l TECHNICAL EVALVATION REPORT ON THE FIRST 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:
GEORGIA POWER COMPANY, V0GTLE ELECTRIC GENERATING PLANT, UNIT 1, DOCKET NUMBER 50 424
- 1. INTRODUCTION Throughout the service life of a water cooled nuclear power facility, 10 CFR 50.55a(g)(4) (Reference 1) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code Section XI, " Rules for Inservice inspection of Nuclear Power Plant Components," (Reference 2) to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during the initial 120 month inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the date of issuance of the operating license, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in ,
10 CFR 50.55a(b) subject to the limitations and modifications listed therein. The Licensee, Georgia Power Company, has prepared the Vogtle Electric Generating Plant, Unit 1. First 10 Year Interval Inservice Inspection (ISI) Program and Plan to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the Class 2 welds in the residual heat removal (RHR), emergency core cooling-(ECC), and containment heat removal (CHR) systems will by selected i according to the 1974 Edition through Summer 1975 Addenda as required by 10 CFR 50.55a(b). The first 10 year interval began June 1, 1987 and ends June 1, 1997.
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I As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief from them, the licensee shall submit information and justifications to the Nuclear Regulatory Commission (NRC) to support that determination.
Pursuant to 10 CFR 50.55a(g)(6), the NRC will evaluate the licensee's determinations under 10 CFR 50.55a(g)(5) that Code requirements are impractical. The Commission may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life or property or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
The information in the Vogtle Electric Generating Plant, Unit 1, first 10-Year Interval 151 Program, through Revision 0 (Reference 3), submitted November 24, 1986, was reviewed, including the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical. The review of the 151 Program was performed using the Standard Review Plans of NUREG 0800 (Reference 4), Section 5.2.4, " Reactor Coolant Boundary inservice Inspections and Testing," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components."
In a letter dated August 14, 1987 (Reference 5), the NRC requested the additional information that was required in order to complete the review of the ISI Program. The requested information was provided by the Licensee in a submittal dated October 21, 1987 (Reference 6). In this response, the Licensee submitted the complete Vogtle Electric Generating Plant, Unit 1.
First 10 Year Interval Inservice Inspection Plan (10 volume set)
(Reference 7), provided the requested clarifications, and revised and/or withdrew several requests for relief, in a telephone conference call with the Licensee and the NRC on February 25, 1988, the Licensee committed to provide further information with regard to the ISI examinations of Code Class 1 branch connection welds and clarification on the sampling of augmented welds in engineered safety 2
e-systems. These commitments were received in the July 18, 1988 (Reference 8) submittal. Also included in this submittal were Revisions 1 and 2 of the 15! Program. Revision 3 of the 151 Program was received in a submittal dated May 10, 1989 (Reference 9).
The Vogtle Electric Generating Plant, Unit 1 First 10 Year Interval 151 Program and Plan are evaluated in Section 2 of this report. The ISI Program and Plan are evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI related commitments identified during the NRC's review before granting an operating license.
The requests for relief are evaluated in Section 3 of this report. Unless otherwise stated, references to the Code refer to Section XI of the ASME Code, 1983 Edition, including Addenda through Summer 1983. Specific inservice test (IST) programs for pumps and valves are being evaluated in other reports.
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- 2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN This evaluation consisted of a review of the applicable program documents to determine whether or not they are in compliance with the Code requirements and any license conditions pertinent to ISI activities. This section describes the submittals reviewed and the results of the review.
2.1 kocuments Evaluated Review has been completed on the following information:
(a) Vogtic Electric Generating Plant, Unit 1, First 10 Year Interval 151 Program, Revision 0, submitted November 24, 1986; (b) Safety Evaluation Report Related to the Operation of Vogtle Electric Generating Plant, Unit 1, dated December 1986 (Reference 10);
(c) Vogtle Electric Generating Plant, Unit 1. First 10-Year Interval ISI Plan, Revision 0 (10-volume set), submitted October 21, 1987; (d) Submittal dated November 2, 1987 (Reference 11), containing missing pages from the October 21, 1987 submittal; (e) Submittal dated July 18, 1988 (Reference 8), containing Revision 1 and Revision 2 of the Vogtle Electric Generating Plant, Unit 1, First 10 Year Interval ISI Program, and; (f) Submittal dated May 10, 1989 (Reference 9), containing Revision 3 of the Vogtle Electric Generating Plant, Unit 1, First 10-Year Interval ISI Program.
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2.2 Comnliance with Code Reauirements 2.2.1 Comolignce with _A.Ipljcable Code Editions The inservice inspection program plan shall be based on the Code editions defined in 10 CFR 50.55a(g)(4) and 10 CFR 50.55a(b). Based on the Operating Licen:, < te of January 16, 1987, the Code applicable to the first interval IS program is the 1983 Edition with Addenda through Summer 1983. As stated in Section 1 of this report, the Licensee has prepared the Vogtle Electric Generating Plant, Unit 1, First 10-Year Interval ISI Program and Plan to n..aet the requirements of the 1983 Edition, Summer 1983 Addenda of t..e Code except that, as required by 10 CFR 50.;5a(b), the extent of examination for Class 2 piping in the RHR, ECC, and CHR systems has been determined by the 1974 Edition througa Summer 1975 Addenda.
2.2.2 Acceotability of the Examination Samole Inservice volumetric, surface, and visual examinations shall be performed on ASME Code Class 1, 2, and 3 components and their supports using sampling schedules described in Section XI of the ASME Code and 10 CFR 50.55a(b).
The NRC and ASME Code Case N-408 have required that 7.5% of the welds in the RHR, ECC, and CHR systems, which only require a surface examination by Section XI of the Code, be volumetrically examined once each 10-year interval. Review of the ISI Plan shows that the Licensee has committed to perform an ultrasonic examination on a minimum of 7.5% of the required welds in the engineered safety systems (safety injection (SI), CHR, and RHR). For Vogtle, Unit 1, this commitment requires that 70 welds be ultrasonically examined each 10 year interval. These added welds are '
mostly in thin-walled or small-diameter piping that dection XI exempts from volumetric weld examinations based on size, thickness, pressure, or temperature.
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Sample size and weld selection have been implemented in accordance with the Code and appear to be correct.
2.2.3 Exclusion Criteria The criteria used to exclude components from examination shall be consistent with Paragraphs IWB-1220, IWC 1220, IWD 1220, and 10 CFR 50.55a(b). The exclusion criteria have been applied by the Licensee in accordance with the Code as discussed in the ISI Program.
Section 7. " Basis for Exemptions." It is noted that the exemptton criteria for Class 2 components have been upgraded to include portions of
, Code Case N-408, " Alternative Rules for Examination of class 2 Piping."
The Licensee has committed to volumetrically examine a minimum of 7.5% of the Class 2 piping welds in the engineered safety systems, including the RHR, ECC, and CHR systems, using the exemption criteria contained in Code Case N 408, 2.2.4 Augm_ented Examination Commitments The Licensee has stated that the following augmented examinations will be implemented during the first 10-year inspection interval:
(a) The Reactor Pressure Vessel will be examined to the requirements of Regulatory Guide 1.150, "U1'.rasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examination," Revision 1 (Reference 12),totheextentpractical.
(b) The Reactor Coolant Pump flywheels will be examined per the recommendations of Regulatory Position C.4 b. of Regulatory Guide 1.14, Revision 1 (Reference 13), dated August 1975, as required by the Technical Specifications.
(c) As required by the Technical Specifications, the four main steam lines and feedwater lines from the containment penetration flued i
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head outboard weld to the upstream weld of the five-way restraint, which is downstream ci the main steam isolation valves, will receive a 100% volumetric examination of circumferential and longitudinal pipe welds to the extent practical,
, (d) A minimum of 7.5% of the total number of Class 2 welds in the c engineered safety systems (RHR, ECC, and CHR systems) will be subjected to an ultrasonic examination in accordance with the requirements of the Yogtle Electric Generating Plant Sa7ety Evaluation Report paragraph 6.6.3. These added welds are mostly in-thin walled or small-diameter piping that Section XI exempts from volumetric weld examinations because of size, thickness, pressure, or temperature.
(e) Snubbers installed on safety-related systems, as well as snubbers whose failure of the system on which they are installed would adversely affect a safety related system, will be examined as required by Section 3/4.7.8 of the Plant Technical Specifications. ;
(f) 'A visual observation for leakage will be performed on accessible ASME Code Class 3 portions of the nuclear service cooling water
- system. This visual observation is required to be performed with the system at operating pressures during each refueling outage for the first ten years of service. In-addition, an ultrasonic examination of two representative wclds, which are in piping
- 24 inches in diameter, one in each unit, will be performed every 40 months for the first 10 years of_ service (see letter from
. Licensee, datrd february 9, 1987 (Reference 14)).
2.3 Conclusions >-
Based on the review of the documents listed above, it is concluded that the Vogtle Electric Generating Plant, Unit'1, First 10 Year Interval ISI Program and Plan are acceptable and in compliance with 10 CFR 50.55a(g)(4).
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- 3. EVALVATION OF RELIEF REQUESTS The requests for relief from the ASME Code requirements that the Licensee has determined to be impractical for the first 10 year 151 interval are evaluated in the following sections.
3.1 Class 1 Comoonents 3.1.1 Beactor Pressure Vessel 3.1.1.1 Relief Reauests RR 1. RR-2. RR 3. RR 4. RR 5. RR-7. and RR 39.
Examination Cateogry B-A. Pressure Retainina Welds in thg_
Re:ctor Pressure Vessel Code Reauirement: Section XI, Table IWB 2500-1, Examination Category B-A, items B1.11 and Bl.12 require a 100% volumetric examination of the Reactor Pressure Vessel shell welds as defined in figures IWB 2500-1 and IWB-2500-2. Items 81.21 and B1.22 require a 100% volumetric examination of the Reactor ,
Pressure Vessel head welds as defined in Figure IWB-2500 3.
Item Bl.30 requires a 100% volumetric examination on the Reactor Pressure Vessel shell-to flange weld as defined in Figure IWB 2500 4. Item Bl.40 requires both 100% volumetric and surface examinations of the Reactor Pressure Vessel head-to-flange weld as defined in Figure IWB 2500-5.
Licensae's Code Relief Reauest: Relief is requested from examining 100% of the Code required volume (CRV) of the following 16 welds as listed in Revision 0 of the Vogtle, Unit 1, First 10-Year Interval ISI Program relief requests:
CRV Eglitf_Reauest Weld Number ltts Examinable RR-1,39: ll201-V6 001-WO3 B1.30 98%
RR-2,39: ll201-V6 001-WO6 B1.11 66%
RR-3: ll201-V6-001-WIS Bl.12 71%
ll201-V6-001-W19 Bl.12 71%
ll201-V6-001 W20 81.12 71%
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CRV i Relief Reauest Weld Number 111m Lxaminable l RR 4,39: 11201 V6 001 W21 Bl.22 89% !
Il201 V6 001 W22 Bl.22 95% 4 11201 V6 001 W23 81.22 92% '
11201 V6 001 W24 B1.22 98% .
RR 5,39: 11201 V6 001 WO7 B1.21 74%
. RR 7: 11201 V6 001 W01 Bl.21 96% !
Il201 V6 001 WO2 81.40 65%
RR 39: ll201 V6 001 WO4 :
11201 V6 001 W12 ll201 V6 001 W13 '
11201 V6 001 Y14 ,
licensee's Prooosed Alternative Examination: None. The ,
Code required volumetric examination will be performed to the maximum extent possible.
Licensee's Basis for Reauestina Relief: RR.1, kn r, RR 3, RR 4, RR 5, and RR 7: The Licensee reports that volumetric examination of the subject welds can be performed only on a limited scope due to keyways, support lugs, lifting lugs, !
instrumentation tubes, control rod drive housings, and -
component geometries preventing 100% coverage of the required volume.
RR 39:. For RPV welds outside the beltline region, the -
nominal 45' and 60' ultrasonic examinations are gated as near as possible to the near surface without causing nearly continuous spurious signals in the gate. The Licensee reports that, typically, this gating arrangement causes a slight amount of missed volume for these examinations of approximately 0.35 inch depth for the 45' examination and 0.27 inch depth for the 60' examination.
Evaluation: The Licensee's submittal has been reviewed, including a listing of the welds for which relief is being requested, the weld design, the Code-requirement for which relief is being requested, and the specific obstruction which ,
limits the examination.
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Based on the above review, it is noted that a significant percentage of the Code required volumetric examination of tha subject welds, as well as the Code required leakage and hydrostatic tests, will be performed. The volumetric examination of these welds is impractical to perform to the extent required by the Code because of the limitations discussed above. To fully comply with the Section XI requirements would necessitate extensive modifications of the RPV support lugs, lifting lugs, instrumentation tubes, control rod drive housings, etc., along with modifications of the mechanical scanning equipment. The percentage of the Code required examination that will be performed for 151 is consistent with that reported dure.g PSI examinations.
Conclusions:
Based on the above evaluation, it is concluded that the volumetric examination is impractical to perform to the extent required by the Code and that the limited Section XI volumetric examination of the subject welds, along with the Code required leakage and hydrostatic tests, provides reasonable assurance of the continued inservice structural integrity. Therefore, it is recommended that relief be granted as requested.
10
w- a 3.1.1.2 Relief Reauest RR-6. Examination Cateocry B G 1. Reactg.,
Pressure Vessel Flance Licament Areas Code Reautrement: Section XI, Table IWB 2500 1 Examination Category B G 1, item B6.40 requires a 100% volumetric
^
examination of the threads in the Reactor Pressure Vessel flange as defined by Figure IWB 2500-12.
Licensee's Cqde Relief Reauest: Relief is requested from examining 100% of the Code required volume of the threads in the Reactor Pressure Vessel flange.
Licensee's Prooosed Alterna.tjve Examination: None. The Code required volumetric examination will be completed to the maximum extent possible.
Licensee's Basis for Reauestina Relief: The Licensee states that 100% of the Code required volumetric examination of the flange ligament area cannot be performed as a surface discontinuity, due to the flange mating surface, exists in the flange ligament scan region. The Licensee reports that approximately 92% of the required volume will be covered for each of the 54- flange ligaments.
I Evaluation: Review of the Licensee's aubmittal shows that a significant percentage (92%) of the Code required volumetric examination can be completed on each stud hole ligament area. The remainder of the examination is limited by the-lip of the flange seal surface. The limitation to examination and the percent of examination that can-be completed are -
consistent with other plants of similar_ design.
Conclusions:
Based on the above eval'uation, it -is concluded that the volumetric examination is impractical to perform to the extent required by the Code and that the limited 11
, --.--.,-.~....--.,,,,,,,-n.~-,., .. .,..,,.. - ,-.,...- <-. ,- -,-.,,.-~ .,.. ., ,.._.- ,. ,.-,.- ,.- ~.
m .u .,
Section XI volumetric examination provides reasonable assurance of the continued inservice structural integrity.
Therefore, it is recommended that relief be granted as requested.
O 12
3 .l.3 Relief Reouest RR 9. Examination Cateoorv 0 G 1. Reactor Pressure Vessel Studs Code Reauirement: Section XI, Table IWB 2500 1 Examination Category B G 1, item B6.30 requires both 100% surface and volumetric examinations of the Reactor Pressure Vessel closure studs (when removed). These examinations are to be as defined in Figure IWD 2500 12.
Licensee's Code _ Relief Reauest: Relief is requested from performing the volumetric examination of the Reactor Pressure Vessel closure studs per the requirements of ASME Code Section V. Article S.
Licensee's Proposed Alternative Examination: The more sensitive shear wave examination, as described below, will be used. The Code required surface examination will be performed if the studs are removed.
Licensee's Basit orf ReQuestina Relief: The Licensee reports that a more sensitive examination, wherein a shear wave transducer is lowered into the heater hole in the center of the stud, has been developed. The calibration block contains three notches of varying lengths and depths which were electrical discharge machined (EDM) into the thread area.
This calibration technique will be used in lieu of the bottom hole technique.
Evaluali2D: In the Licensee's response to the staff's request for additional information (RAI), the Licensee
-verified that the subject bolting examination is based on ASME Code Case N 307 which allows for a revised ultrasonic examination volume when the examinations are conducted from the center drilled hole. Code Case N 307 is listed in Regulatory Guide 1.147 as an NRC approved Code Case.
l 13
Therefore, the intent of the Code requirement will be met by the use of Code Case N 307.
Also ASME Code Section XI, PL-agraph IWA 2240 permits the use of alternative examination methods, a combination of methods, or newly developed techniques, provided the Inspector is sat' fled that the results are demonstrated to be equivalent or superior to those of the specified method.
Conclusioni: Based on the above evaluation, it is concluded that the intent of the Code will be met and, therefore, relief is not required for RR 9.
l l
14
g,--_,_
3.1.1.4 Reifef Reauest RR-il. Examination Cateaory F B. Visual Examination of Reactor Pressure Vessel Sucoorts -
Code Recuirement: Section XI. Table IWF 2500 1. Examination Category F 8, Item F2.30 requires a visual (VT 3) examination on linear type component :;upports as defined in Figure IWF 1300 1.
Licensee's Code Relief Reauest Relief is requested from ;
performing the Code required visual (VT 3) examination of the following four Reactor Pressure Vessel supports:
ll201 V6 001 RS1 ll201 V6 001 RS2 ll201 V6 001 RS3 ll201 V6 001 RS4
. Licensee's Proposed Alternative Examination: None. >
Licensee's Basis for Reauestina Relief: The subject Reactor i Pressure Vessel supports are encased in concrete which renders them inaccessible for visual-examination. The reactor vessel nozzles render them inaccessible from the top side. Removal of i the examination barriers is impractical.
Evaluation:. The Licensee's submittal has been reviewed, including the listing of the supports for which relief is being requested and Attachment 1_ showing the support design and ths concrete obstruction. Based on this review, it~has been -
determined that, as the Licensee has stated, a visual examination of the subject supports is impractical to perform-from the bottom side because the supports are encased in -
concrete and the visual examination is impractical to perform ,
~
-from the top _ side because of interference from the nozzles.
-The. subject supports would require extensive modification in order to perform the Code required visual examination.
^
15 ,
Conclusions:
Based on the above evaluation, it is concluded that the Code-required visual (VT 3) examination of the subject Reactor Pressure Vessel supports is impractical to perform.
Therefore, it is recommended that relief be granted as requested.
16
m .
3.1.1.5 Relief Reauest RR-40. Basic Ultruonic Calibration Blocks for Examination of the Reactor Pressure Vessel Welds Code Reauirement: ASME Code Section V, Article 4, Figure T-434.1 requires a notch length of 2 inches in basic ultrasonic calibration blocks for examination of vessel welds.
Licensee's Code Relief Reauest: Relief is requested from the required notch length of 2 inches for Calibration Block Nos.ISI-D400AthroughISI0-403A(fourblockstotal).
Licensee's Prooosed Alternative Examination: The Code required examination will be performed using instruments enlibrated on the subject blocks containing notches less than 2 inches long.
Licensee's Basis for Reauestina Relief: The four subject calibration blocks, supplied by the reactor pressure vessel manufacturer, contain notches that are approximately
- 13/4 inches in length, de Licensee repo ts that these notches provide no difficulty in establishing acceptable calibrations.
Evaluation: The Licensee's submit ;al of relief request RR 40 has been reviewed and it has been determined that the use of 1 3/4 inch long notches, in lieu of the Code required 2-inch notch, will have no detrimental effect on_the examination as it can only provide for.a more sensitive examination.
Conclusions:
Based on the'above evaluation, it is concluded that the-use of the subject calibration blocks will meet or, exceed the Code requirement. Therefore, it is recommended that_
relief be granted as requested.
L l
17
. -- ,. - , - w
r 3.1.1.6 Relief Reauest RR 52. Examination Cateaory B H. Reactor Er.gnore Vessel Intearally Welded Attachments )
l Cadf..Reautrement: Section XI Table IWB 2500 1. Examination '
Category B H. Item B8.10 requires a 100% surface examination of RPV integrally welded attachments as defined by !
Figure IWB 2500 15. !
t Licensee's Code Relief Reouest: Relief is requested from examining 100%oftheCoderequiredarea(CRA)ofthefollowing
-integrally welded attachments:
CRA r Weld Number Examinable i ll201 V6 001 W204 75%-- !
Il201-V6 001-W205 75%
ll201-V6 001 W206 75%
licensee's proposed Alternative Examination: None. The Code required surface examination will be performed to the
- maximum extent possible.
Licensee's Basis for Reouestina Relief: Geometric !
configuration and the location of the control rod drive support ;
braces presents physical limitations that prevent complete coverage of- the RPV Closure Head'11fting lugs required for the surface examination.
Evaluation: Review of the Licensee's submittal shows that a significant percentage of.the Code required surface examination will be performed on each of the subject lifting lugs. This limited Section XI surface examination will provide reasonable assurance of the continued inservice structural integrity.
Conclusions:
It-is concluded that the surface examination.is
' impractical to perform to the extent required by the Code.
Therefore, it is recommended that relief be granted as -
requested.-
18
. __ _ _ _. .__ ._ ____, _ __ . , _ _ . ~ - _
l l
3.1.2 Pressurirer 3.1.2.1 Relief Reauests RR 10 and RR-16. Examinatiog Intecorv B H.
Effmurizer Intearally Welded Attachments ,
code Reauirement: Section XI. Table IWB 25001, Examination Category B H, Item B8.20 requires a 100% surface examination of :
the Pressurizer integrally welded attachments as defined by figures IWB 2500 13 and IWB 2500 15. j Licensee's Code Relief Reauest RR 10: Relief is requested from examining 100% of the Code required surface of Pressurizer support skirt weld 11201 V6 002 W35.
RR 16: Relief is requested fron performing the Code required surface examination of Pressurizer integral welded attachments ll201-V6 002-W23 through W30 (eight welds).
- Licensee's Proposed Alternative Examination: RR 10: None.
The Licensee reports that area A B as shown on Figure IWB-2500 13 will-receive the Code required surface examination, pR-16: None.
Licensee's Basis for Reauestina Relief: RR 10: The Pressurizer heater penetrations restrict access'for personnel to perform a surface examination of the Pressurizer skirt weld area as described by C D on Figure lWB-2500-13. o RR 16 ' The support rack assembly, which holds the spray and-relief piping of the Pressurizer, rests above the integrally l welded attachments and restricts access to the walds. .The
- Licensee reports that removal of the rack assembly to perform the necessary surface examination is not feasible.
19
-. . ~ ..= . -... a. - . - - . - . . ~ - =. -.-- : - . : - . - .:
- - - _ . - . = - . _ __ - . - - . .- -
1 Evaluation: The Licensee's requests for relief have been reviewed and it has been determined that a significant percentage of the Code required surface examination of Pressurizer skirt wela No. Il201 V6 002 W35 can and will be l completed, in order to complete the Code-required surface examination on the remainder of this weld and the eight welds listed in RR 16, the Pressurizer would require extensive modifications.
Conclusions:
Based on the above evaluation, it is concluded that compliance with the specific requirements of Section XI for the subject welds is impractical. Therefore, it is recommended that relief be granted as requested.
l 20 J
l l
l
)
3.1.2.2 Relief Reauests RR-12. RR 14. and RR-15. Examination Cateaori9s B B. B D. and B-F. Pressurizer Vessel and Sgtgg Nozzle to Vessel Welds Code Reauirement: RR 12: Section XI, Table IWB 25001, Examination Category B F, Item B5.40 requires both 100% surface and volumetric examinations of Pressurizer nozzle-to-fafe end welds as defined by Figure IWB 2500 8.
RR 12, RR-14, and RR 15: Section XI, Table IWB 2500-1, Examination Category B B, item B2.11 requires a 100% volumetric examination of the Pressurizer shell-to head welds as defined in Figure IWB-2500-1. Examination Category B D, Items B3.110 and B3.120 require a 100% volumetric examination of the Pressurizer nozzle-to-vessel welds and the nozzle inside radius sections as defined in Figure IWB 2500 7(b).
Licensee's Code Relief Reauul: Relief is requested from examining 100% of the Code-required volume (CRV) of the following Pressurizer welds:
CRV Identification No. Descriotion Examinable RR-12: ll201-V6-002 W01 Upper Head to-Upper 68%
Shell Weld RR-12: ll201-V6-002-WO5 Lower Shell-to-Lower 84%
Head Weld RR 12: ll201-V6-002 W10 Upper Head to 6" 50%
Safety Nozzle Weld RR 12: 11201-V6 002 W11 Upper Head-to-G" 50%
Safety Nozzle Weld RR 12: 11201-V6-002 W12 Upper Head-to-6" 50%
Safety Nozzle Weld RR-12: 11201-V6-002 W13 Upper Head to-6" 50%
Safety Nozzle Weld RR 12: 11201 V6 002 W14 Upper Head-to-4" 50%
Spray Nozzle Weld 1
21
W..
1 (continued)
CP.V Identification No. Descriolion Examinable RR-12: 11201-V6 002-W17 6" Safety Nazzle-to- 50" Safe End Wr;ld I r.R-12 : 11201-V6 002-W18 6" Safety Nozzle-to- 50%
Safe End lleld RR 12: ll201-V6 002-W19 6" Safety Nozzle-to- 50%
Safe End Weld RR-12: ll201-V6-002 W20 6" Safet,y Nozzle-to- 50%
Safe Erid Weld RR-14: 11201-V6 002-W16 Surge Wozzle-to- 20 to 30%
Vessel We'd (head side)
RR-15: ll201-V6-002-IR06 Surg 9 Nozzle inner 0%
radius section Licensee's Proposed Alternative Examination: RR-12: The Code-required surface examination of the nozzle-to-safe end welds will be performed. The Code-required volumetric examination will be performed to the maximum extent possible (see above table). In additien, a surface examination will be performed on the head-to-nozzle welds to supplement the limited volumetric examinations.
RR-14: In additic h the limited volumetric examination as outlined in the above table, a sur', ace examination covering 85%
of the Pressurizer surge nozzle-to-vessel weld will be performed during ISI.
RR-15: None.
Licensee's Basis for Reauestino Relief: RR-12: The Pressurizer upper head-to-shell weld can receive only 68% of the Code-required volumetric examination because of interferences caused by nozzles, supports, and identification plates. The lower head-to-shell weld can receive only 84% of the Code-required volumetric examination because the 22
Pressurizer skirt-limits access. The five Pressurizer head to nozzle and four nozzle-to-safe end welds can receive only 50% of the Code required volumetric examination as volumetrie examination is not possible from the nozzle side of-the welds.
RR-14: The electrical heater well couplings and associated cables surround the Pressurizer surge nozzle on the bottom head. These heater couplings restrict coverage of the required examination volume of weld 11201-V6-002 W16. The extent of the coverage that was obtained it v4 from the nozzle side and 20 to 30%.from the head side f
- weld. In-addition to the limited volumeu L examinativo coverage, a surface examination covering 85% of the subject weld will be performed for 151.
RR-15: Pressurizer surge nozzle inner iadius section ll201-V6 002-IR06 cannot be volumetric 411y examined as the
-nozzle barre 1' prohibits an ultrasonic scan from the noz71e side and'the heater well couplings prohibit the scan-from the vessel s ide=.
Evaluatign: Based on review of RR-12, RR 14, and RR-15,.the .
Pressurizer would require extensive modification in order to
. perform the volumetric examination to the. extent required by-the Code because of the geometric _ restrictions: discussed above. The limited volumetric examinations, in conjunction:
=with the Code-required and/or augmented surface examinations and the hydrostatic tests, provide reasonable assurance of the continued inservice structural integrity.
Conclusions:
Based on the above evaluation, it is concluded that the volumetric examination is impractical to perform to the extent required by the Code. Therefore, it is recommended
^
that relief-be granted as requested.
23
wb.
i 3.1.2.3 Relief Reauest RR-13. Vltrasonic Calibration Blocks for the Pressurizer Nozzle-to-Safe End Welds EQII: Relief was requested from using calibration blocks made from material of the same nominal diameter and nominal wall thickness as the Pressurizer nozzle-to-safe end welds. This relief request had been previously granted for PSI with the condition that proper calibration blocks be obtained and utilized for all future ISI examinations.
In the October 21, 1987 response to the NRC request for additional information with regard to the above, the Licensee withdrew Request for Relief RR-13.
24
3.1.3 BgA1 Exchanaers and Steam Generators 3.1.3.1 Relief Reouest RR-19. Examination Cateoory B-B. Volumetric Examination of Steam Generator Channel Head-to-Tube Sheet Weld
~
Code Reovirement: Section XI, Table IWB 2500-1, Examination Category B B, Item B2.40 requires a 100% volumetric examination of the tubesheet-to-head weld on the primary side of the Steam Generators as defined by Figure IWB 2500-6.
Licensee's Code Relief Reouest: Relief it requested from examining 100% of the Code-required volume of the following Steam Generator tubesheet-to head welds:
ll201-B6-001-WOB 11201-B6-002-WO8 Il201-B6-003-WOB ll201-B6-004-WO8 Licensee's Prooosed Alternative Examination: None. The Code-required volumetric examination will be completed to the maximum extent possible, as outlined in the Attachment I to RR-19.
Licensee's Basis for Reouestino Relief: Four vessel supports and an identification tag prevent access to 100% of the weld length by the transducer. The tubesheet interferes with transducer placement for the upstream scans and the curvature of the channel head interferes with the downstream scans.
Evaluation: Attachment 1 of the Licensee's submittal identifies the percentage of the Code-required volumetric examination which can be completed for each type of search unit scan in both the upstream and downstream directions. For each of the four subject welds, it is noted that a significant percentage of the Code-required volume can and will be examined. The Steam Generators would require extensive 25 i . . . . .. .. . . . . . . . .. ..
modification in. order to comply with the exact Section XI requirements.
Conclusions:
Based on the above evaluation, it is concluded that the volumetric examination of the subject welds is impractical to perform to the extent required by the Code and that the limited Section XI volumetric examination, along with the required hydrostatic test, will provide reasonable assurance of the continued inservice structural integrity.
Therefore, it is recommended that relief be granted as requested.
26 l
- 3. 'l . 3. 2 Relief Reauest RR 42. Examination Cateoorv 8-D. Volumetric Examination of Steam Generator Inlet and Outlet Nozzle Inner Radii I
(ode Reauirement: Section XI, Table IWB 25001, Examination Category B D, Item B3.140 requires a 100% volumetric
, examination of the Steam Generator nozzle-inside radius section as defined by Figure IWB-2500 7.
Licensee's Code Relief Reauest: Relief is requested from performing 100% of the Code-required volumetric examination of the'following Steam Generator inlet and outlet nozzles: )
Examination identification Nos.
Il201 86-001 IR-01 ll201-86-001-IR-02 11201 B6-002-IR 01 11201-86-002-IR 02-Il201-B6-003-IR-01 ll201-86-003-IR-02 ll201-B6-004-IR-01 ll201-B6-004-IR-02 i Licensee's Procosed Alternative Examination: None. The Licensee reports in Reference 6.that the inside surface of each steam generator primary side. nozzle inner radius section will be visually examined to the maximum extent practical.
Licensee's Basis for Reauestino Relief: The Steam Generator primary side nozzles are-integrally cast as part of the channel head.. The nozzle inner radius sections cannot be volumetrically examined from the outside of the nozzle or-channel head because the rough, as-cast contat.t surface is not- -
suitable for ultrasonic coupling and the geometrical-
- configuration requires an excessively long test metal distance, resulting inLhigh ultrasonic attenuation. The inside of the nozzle and channel head areas are covered with cladding in the "as-welded" condition; therefore, meaningful volumetric 27
- . - . -- .w .. .
. examination cannot be performed from the "as-welded" surface.
Even with proper preparation of the inside surface for volumetric. examination, an adequate examination of the area of interest (base metal just below the cladding) could not be achieved due to the resulting ultrasonic response at the clad to-base metal interface.
Evaluation: The Licensee's submittal has been reviewed and it has been determined that the reported as-cast surface condition, along with the excessively long test metal distance which results in high ultrasonic attenuation, precludes the Code-required volumetric examination from being performed from the outside surface. The as-welded surface of the 10 cladding prohibits ultrasonic examination from the inside surface.
Therefore, the Steam Generator channel heads would. require extensive rework in order to comply with the Code-Section XI requirements.
Conclusions:
Based on the above, it-is concluded that the Licensee's proposed visual examination and the Code-required pressure test will provide reasonable assurance of the continued inservice structural integrity. Compliance with the specific requirements of Section XI for the specific nozzle
- inside radius sections is impractical. Therefore, it is recommended that relief be granted as requested.
A l.
28 l
i
3.1.4 Pioino Pressure Boundary 3.1.4.1 Relief Recuests RR-8. RR-17. RR-20. RR-24. and RR 26 f eart 1 of 2). Examination Cateaory B.J. Pressure Retainina Welds in Class 1 Pioins Code Reouirement: Section XI, Table IWB-2500-1, Examination Category B-J, Item B9.11 requires both 100% surface and volumetric examinations of Class 1 pressure retaining circumferential welds 4 inch and greater nominal pipe size as defined by Figure IWB 2500-8.
Licensee's Code Relief Recuest: Relief is requested from examining 100% of the Code-recuired volume (CRV) of the following 44 Class I circumferential piping welds:
CRV Relief Reavest Examination ID No. Examinable RR- 8: 11201-009-9 46%
-11201-010-7 50%
11201-011-8 50%
11201 012-9 50%
RR-17: 11201 001-5 50%
11201-002-5 50%
11201-003-5 50%
11201-004-6 50%
11201-005-1 50%
11201-006-1 50%
11201-007-1 50%
11201-008-1 50%
RR-20: 11201-049-3 93%
11201-059-11 90%
RR-24: 11201-005-8 90%
11201-006-8 90%
11201-007-8 90%
11201-008 3 905 11201-009-1 764 11201-010-1 75%
11201-011-1 75%
11201-012-1 75%
29
(continued)
CRV Relief Reauesi Examination 10 No. Examinable RR 26: 11204-124-1 50%
11204-124-7 50%
11204-124-8 50%
11204-124-11 88%
11204-124-12 88%
11204-124-15 50%
11204-124-16 50%
11204-125-1 50%
11204-125-7 50%
11204-125-8 50%
11204-125 15 50%
11204-125-16 50%
11204-126-1 50%
11204-126-7 50%
11204-126-8 50%
11204-126-15 50%
11204-126-16 50%
11204-127-1 50%
11204-127-7 50%
11204-127-8 50%
11204-127-19 50%
11204-127-20 50%
Licensee's Prooosed Alternative Examination: RR-8: In addition to the Code-required surface examination and the limited mechanized ultrasonic examination, a supplemental manual ultrasonic examination using a refracted longitudinal wave, calibrated on the centrifuga11y cast piping calibration block, will be performed from the safe-end outside diameter to obtain the examination coverage listed above.
RR-17, RR-20, RR-24, and RR-26: None. In addition to the Co'de-required surface examination, the volumetric examination will be performed to the ' extent practical (as identified abeve).
Licensee's Basis for Reauestino Relief: RR-8: The four Reactor Vessel safe end-to-elbow welds listed above can receive only a limited Code-required volumetric examination (65%
coverage from the safe-end side and 0% from the elbow side) because of physical limitations due to the geometric 30
configuration of the elbows. The Licensee reports that, in addition to the limited mechanized volumetric examination, a supplemental manual ultrasonic examination using a refracted longitudinal wave, calibrated on-_the centrifugally cast piping l:
calibration block, will be performed from the safe end side.
With this technique, 92% cover' age can be obtained on one weld and-100% coverage can be obtained on the other three. The refracted loagitudinal wave is required due to the close L proximity of the nozzle-to-safe end weld. No coverage can be L obtained from the elbow side due to 0.D. taper.
RR-17: The eight Steam Generator Class 1 nozzle-to elbow welds listed above can receive only. 50% of the Code-required volumetric examination from the elbow side of the weld due to nozzle geometry. The Licensee reports that these wolds will be l' ultrasonically examined 100% from the elbow side using the
_ refracted longitudinal wave examination technique discussed in l
RR-22 (evaluated in Paragraph 3.1.4.3 of this report).
RR-20:' The'two pipe-to-tee welds listed above can receive only 90% and 93% of the Code-required volumetric examination due to physical restrictions caused by the tee geometry.
RR-24: The four Reactor Coolant (RC) Pump inlet nozzle-to-elbow welds listed.above can. receive only 90% of -the -
Code-required volumetric examination and the four RC Pump i
outlet nozzle-to-pipe welds can receive only 75% of the j_ Code-required volumetric examination. Full-Code-required coverage is-not possible because of _the increasing taper of the nozzle with increasing distance from the weld.
l RR-26: The two 10-inch pipe-to-tee welds listed above can receive only 88% of the Code-required volumetric examination and the 2010-inch pipe-to-valve welds can receive only 50% of the Code-required volumetric examination due to metallurgical constraints and the geometric configuration of the tees and 31
valves. Because the SA-376 material exhibited severe angular variations and significant attenuation problems during the attempted shear-wave ultrasonic examinations, a refracted longitudinal wave, which is a 1/2 V-path examination technique, will be'used. On the pipe-to-valve configuratiens, the weld will be examined from the pipe side. Scanning from the valve side is not possible due to valve geometry. On pipe-to tee configurations, the weld will be examined from the pipe side using the refracted longitudinal wave. Only partial scanning l
from the tee side is possible due to tee geometry. l Evaluation: The Licensee's submittal was reviewed, including the Attachments that list the welds for which relief is being requested, the weld configurations, the Code requirements, a brief description of the restriction, and the approximate percentage of the e de-required examination that can be completed.
Complete examinations that meet the requirements of ASHE Code Section XI will be performed on welds of similar configuration using the same inspection techniques, equipment, and procedures as those for the partially inspected welds. Since the welds receiving limited examination are seeing the same operating and environmental conditions as the inspected welds, reasonable assurance of the structural integrity of the welds for which relief is requested will be attained.
l With regard to limitations due to the metallurgical properties of cast stainless rteel, the Licensee should monitor the l development of new or improved examination techniques and, as improvements are achieved, incorporate these techniques as part
! of the inservice examination requirements for the components or welds which received a limited ISI examination.
Conclusions:
Based on the above review, it is concluded that
! the volumetric examination of the subject welds is impractical 32
to perform to the extent required by the Code. The Code-required surface examination and the limited volumetric examination of these welds, in conjunction with the required hydrostatic test and the complete Code-required examinations on welds of similar configuration, will provide reasonable assurance of the continued inservice ;tructural integrity.
Therefore, it is recommended that relief be granted as requested.
33
3.1.4.2 Relief Reauest RR 21. Examination Cateaory B-J. Class 1 Branch Connection Welds 4 Inch and Larcer Nominal Pioe Size Code Reauirement: Section XI, Table IWB-2500-1, Examination
~ Category B-J, Item B9.31 requires both 100% surface and volumetric examinations of branch pipe connection welds 4 inch and greater nominal pipe size as defined by Figures IWB-2500 9,
-10, and -11.
Licensee's Code Relief Reauest:- Relief is _ requested from examining 100% of the Code-required volume (CRV) of the following 11 Class l1 branch pipe connection welds:
CRV Pyaminable -
Weld Number -__l%1d Description Pioe Side Branch Side 11201-001-2 12" Branch Connection 50% 90%
11201-002-2 6" Branch-Connection 50% 90%
11201-003-2 6" Branch Connection 50% 90%
11201-004-2 16" Branch Connection 50% 90%
~
11201-004-3 12" Branch Connection 50% 90%
11201-009-4 4" Branch Connection 0% 100%
11201-009-6 10" Branch Connection 50% 0%
11201-010-4 10"-Branch Connection. 50% 0%
11201-011-5 10" Branch Connection 50% 0%
11201-012-4 4" Branch Connection 0% 100%
11201-012-6 - 10" Branch Connection 50% 0%
Licensee's Procosed Alternative Examination: None. In addition to the Code-required surface examination, an ultrasonic examination will be performed to the extent possible (asdefii.adabove).
Licensee's Basis for Reauestino Relief: Two basic weld configurations are used for the branch connection designs on the main loop piping. The 4-inch branch connections were
- installed using.a " set-on" weld design, while the 6 ,10 ,12 ,
and 16-inch branch connections were installed using a " set-in" design.
l l-f-
L I' 1 34 i i;
~
~ - - _. - - .- -- - -
a \
m+-
Typically, examination. coverage of branch connection welds can
- be-obtained by.-scanning from the: main run of pipe using a-45' shear wave technique. In this case, due_to the cast stainless-material used:in the main loop, the examination is limited to a 1/2 V-path examination using a refracted longitudinal (RL) wave
-technique developed for this piping.
Examination of the 4-inch branch connection welds from the main
- run of piping using the 1/2 V-path'RL wave is not possible due
- to the geometry of the " set-on" configuration. However, partial coverage of the 6 , 10 , 12 , and 16-inch branch connection welds from the main run using the 1/2 V-path RL technique -is possible because ~ of the " set-ir" configuration.
Approximately _50% of the Code-required vclumo (oae taam
- direction only) for the 6 , 10 ,:12 ,-and 16-inch bianch connection _ welds can be examined using this technique.
- To increase coverage _and provide two-directional-coverage, scanning from the branch connection side will also be used where possible. The ' rged stainless-steel material used in all but the 10-inch branch connections allows the use of shear wave ultrasonic techniques; however, the geometry of the fi_ttings still presents problems in obtaining Code-required coverage.
Based on plots and calculations, the Licensee determined that -
- the only feasible exam'ination from the branch connection side would be a shear wave technique from the _ taper of the fitting..
This technique will rely on the ability of the shear wave to reflect - of' '
the inner wall at the fitting bore, and should result in ktb axkl.tely 80% of the required volume being
- examined on the 4-inch branch connections.
1 The fitting side of the 10-inch branch connection is cast stainless steel; this precludes thf use of a shear wave 35 er *- -,e1- -r - + m,-
m -
technique. Also, due to the geometry of the part, examination from the branch connection side using the 1/2 V-path RL technique is not feasible.
When examinations are conducted from the branch connection side, calibration blocks will be fabricated to match the actual configuration of the components to the extent practical.
Reflectors would be machined into these " mockups" in the appropriate locations. In cates where it is determined that one mockup would provide adequate representation for two branch connection sizes, only one calibration block will be fabricated. For example, only one mockup would be provided for the 12- and 16-inch branch connections if it is determined to provide appropriate calibration.
Evaluation: The Licensee's submittal has been reviewed, including the list of specific branch connection welds with an estimate of the accessible percentage of each and a sketch showing the configurations of the branch connections for which relief is being requested.
The Licensee has made significant efforts, as described above, to perform the Code-required volumetric examinations on the subject branch connections. Examination of branch connection welds is typically difficult due to the configuration of the branch connection fittings and weld design. These problems exist for branch connection welds in the Vogtle main loop piping, in addition to the problems of examining cast stainless steel piping material. Based on the materials of construction and the branch connection design, the complete Code required volumetric examination cannot be performed. However, a significant percentage can and will be performed.
Conclusions:
Based on the above evaluation, it is concluded that the vol wetric examination is impractical to perform to 36
the extent required by the Code and that the limited Section XI volumetric examination of the branch connection welds, along with the Code-reqJired surface examination and pressure test, provide reasonable assurance of tne continued inservice structural integrity. Therefore, it is recommended that relief be granted as requested.
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3.I.4.3 Reljylhsts RR 2r and RR 23. Ultrasonic Technioues and-Q]_lp ation Blocks for Examination of Pressure Retainina Welds of Cast Stainless Steel (Grade SA 351-cr8A) Comoonents in the Reactor Coolant System Code Recuirement: RR 22: Sectioni XI, Appendix III, Paragraph III-4420 requires that the ultrasonic examination be performed using sufficiently long examination beam paths to provide coverage of the required examination volume in two beam path directions, The examination shall be performed from two sides of the weld, where practicable, or from one side of the weld as a minimum, Paragraph 111-4430 requires that the angle beam examination for reflectors transverse to the weld be performed on the weld crown on a single scan path to examine the weld root by 1/2 V-path in two directions along the weld.
Paragraph 111-2430 requires that manual scanning be done at twice (+6 dB) the primary reference level, as a minimum.
RR-23: Section XI, Appendix III, Paragraph 111-3410 requires that basic calibration blocks be made from material of the same nominal diameter and nominal wall thickness or pipe schedule as the pipe to be examined, licensee's Code Relief Reauest: RR-22: Relief is requested from performing volumetric examinations on the cast stainless steel using conventional shear-wave techniques.
RR-23: Relief is requested from obtaining calibration blocks for each nominal pipe size ranging from 27.5- to 31-inch ID with wall thicknesses ranging from 2.32 to 2.62 inches.
Licensee's Prootu i fi ernative t Examination: RR-22: In addition to the Code-required surface examination, a refracted longitudinal wave ultrasonic examination, which is a 1/2 V-path examination, will be performed. Scanning will be done at the primary reference level.
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RR 23: The calibration block fabricated from the hot leg piping (29-inch I.D. and 2.45-inch nominal wall thickness) will be used to examine the cold leg (27.5-inch I.D. and 2.32 inch nominal well thickness) and the crossover leg (31-inch I.D. and 2.6-inch nominal wall thickness) piping welds. This calibration block will also be used to examine the 27.5 , 29 ,
and SI inch I.0, elbows of the 2.35 , 2.48 , and 2.62-inch wall thicknesses, respectively.
Licensee's Basis for Recuestina Relief: RR 22: The cast SA-351, CF8A material contains a banded microstructure that consists of grains ranging in size from extremely coarse to very fine. This irregular grain structure causes significant attenuation and some angf ar variations during a typical shear wave ultrasonic examination. A technique was developed wherein a 1.0-inch, dual-element, focused transducer utilizirg a 45' refracted longitudinal wave with a frequency of 1.0 MHz is used. During calibration, the primary reference level is set using side-drilled holes. Calibrations using side-drilled holes are more sensitive than those using notches and cause the primary reference level to be set higher. Scanning is possible only at the primary reference level due to excessive noise associated with the higher gain levels and the metallurgical structure of the material. A demonstration using this technique was performed for NRC Region II, during PSI, and determined to be a conservative method of detecting ID reflectors (NRC report numbers 50-424/85-18 (Reference 15) and 50-424/85-25 (Reference 16)].
RR-23: Section XI, Paragraph IWA-2232(c) allows the use of Article 5 of Section V for the ultrasonic examination of piping made of other than ferritic materials.Section V, Article 5, Paragraph T-540 delineates the examination requirements of welds in wrought and cast materials. Paragraph T-543.3.1 allows for use of a block of essentially the same curvature or, 39
alternatively, a flat block for examinations where the examination surface diameter is greater than 20 inches. Also, Figure T-546.1 allows a calibration block thickness of 3 inches to be used for thicknesses between 2 and 4 inches. Using this analysis, the single calibration block, fabricated from hot leg pipe, is appropriate for examination of the cold leg and crossover leg components.
Evaluation: The Licensee's submittal has been reviewed, including NRC Region 11 report Numbers 50 524/85 18 and 50-524/85-25, and it has been determined that the examination procedures meet the methodology requirements of ASME Code Section XI and, as reported by Region 11, the Licensee has successfully demonstrated his techniques, equipment, and procedures for examination of the Primary Coolant System at Vogtle Electric Generating Plant, Unit 1.
With regard to limitations due to the metallurgical properties of cast stainless : teel, the Licensee should monitor the development of new or improved examination techniques and, as improvements are achieved, incorporate these techniques as part of the inservice examination requirements for the components or welds which received a limited ISI examination.
==
Conclusions:==
Based on the above evaluation, it is concluded that the Licensee's proposed ext.minations provide reasonable as urance of the continued inservice structural integrity and that compliance with the specific requirements of Section XI for the subject welds is impractical. Therefore, it is recommended that relief be granted as requested.
40
3.1.4.4 Relief Reauest RR 25. Ultrasonic Calibration Block for Examination of Pressure Retainina Reactor Coolant Pumn Nozzle-to-Pine Weldi Code Recuirement: Section XI, Appendix III, Paragraph 111-3411 ttates that calibration blocks shall be fabricated from one of the materials specified for the piping being joined by the weld and, if material of the same specification is not available, material of similar chemical analysis, tensile properties, and metallurgical structure may be used.
Licensee's C2de Relief Recuest: Relief is requested from obtaining a calibration block for the following Reactor Coolant Pump outlet nozzle to pipe welds:
11201 009 1 11201 010 1 11201-011-1 11201 012-1 Licensee's Drecosed Alternative Examination: The Code-required surface examination will be performed and an ultrasonic examination will be performed from the pipe side through the overlay material.
Licensee's Basis for Reauestino Relief: The 27.5-inch piping is significantly thinner than the Reactor Coolant Pump discharge nozzles. Weld metal was deposited on the pipe to increase the thickness of the pipe to that of the nozzle so that a full penetration weld could be made. This overlay material extends approximately 6 inches on the pipe side of the welds. The Licensee reports that the refracted longitudinal wave examination, which has previously been demonstrated to be the superior technique for examining cast material, will be completed using high scanning levels. The Licensee also reports that the pipe 1.0, geometry can be observed during this inspection. Thus, the longitudinal wave will penetrate the 41
r
- pipe overlay. As:a result, defects will.be observed, if ,
present, regardless of the calibration technique usad. The ;
ultrasonic calibration-block to be used will be the cast piping-block that has not been overlaid with weld material. ,
. Evaluation: The Licensee's submittal has been reviewed, including a drawing showing the pump nozzle-to-pipe weld with ?
the weld overlay. The limited Section XI-volumetric ,
examination, which has been demonstrated to detect I.D.
geometric-indications, along with the Code-required surface ,
examination and the hydrostatic test, will provide reasonable-assurance of the continued inservice' structural integrity.
The Licensee should monitor the development of new or improved-examination techniques and, as improvements are achieved, incorporate these techniques as part. of the inservice examination requirements for the components or welds-which ,
received a limited ISI examination.
Conclusions:
Based on the tbove evaluation, it is concluded that compliance with the specific requirements of Section.XI >
- for the subject _ welds is impractical. Therefore, it is recommended that relief be granted as requested.
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3.1.4.5 Relief Reouest RR-41. Basic Ultrasonic Calibration Blocks for l Examination of the Reector pressure Vessel NgIzle-to-Safe End_
Welds Code Reouirement: Section XI, Article 111-3411 requires that l i
basic calibration blocks be fabricated from one of the l materials specified for the piping being joined by the weld.
Licensee's Code Relief Reouest: The Licensee has requested to use a cast stainless steel piping calibration block (No. ISI-D-331A) in conjunction with a composite calibration block (No. ISI-D-405A) for the mechanized examination of Reactor Pressure Vessel nozzle-to safe end welds ll201-V6-001-W33 through 11201-V6-001-W40 (eight welds total).
Licensee's Procosed Alternative Examination: The Code-required surface examination will be performed from the outsitie of the weld. Also, a mechanized ultrasonic examination will be performed from the inside using the composite calibration block in conjunction with the curved surface cast piping calibration block as discussed below.
Licensee's Basis for Reouestino Relief: The RPV manufacturer supplied a flat block fabricated from SA-508 CL-2 and SA-240 Type-316 welded together to form a composite block to be used for the examination of the nozzle-to-safe end welds. Due to
+he special near-surface examination technique being applied from inside the vessel during the mechanized examination, the flat contour of the composite calibration block could not be used alone to establish a calibration which was representative of the examination to be performed. An attenuation compari' son performed between the centrifugally cast block (ISI-D-331A) and the flat composite calibration block (ISI-D-405A) revealed that calibration using ISI-D-331A would provide a more sensitive 43
examination for three of the four channels used for the examination. Based on this information, calibration block ISI-D-331A was used to establish both the sweep position and calibration sensitivity for three channels. The sweep position for the other channel was established from ISI-D 331A and the sensitivity was established from ISI-D 405A. The Licensee reported that the use of the curved surface of the centrifuga11y cast calibration block, as well as adding the increased sensitivity, provided a superior calibration for the special near-surface examination technique applied to these welds.
Evaluation: It is noted hat Section XI, Paragraph IWA-2240, permits the use of alternative examination methods, a combination of methods, or newly developed techniques, provided the Inspector is satisited that the results are demonstrated to be equivalent or superior to those of the specified method.
The examination technique proposed by the Licensee meets the intent of ti,e Code requirements for the RPV nozzle-to-safe end welds.
==
Conclusions:==
Based on the above evaluation, it is concluded that the intent of the Code will be met. Therefore, relief is not required for RR-41.
44
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3.1.5 Pumo Pressure Boundary 3.1.5.1 Relief Reauest RR-27. Examination Cateaories B-L-2 and B-M-2.
Visual Examination of Class 1 Pumo Casinas and Valve Bodies Code Reauirement: Section XI, Table IWB-2500-1, Examination Category B L-2 Item B12.20, and Examination Category B-M-2, Item B12.50, require a visual examination (VT-3) of the internal surfaces of Class 1 pump casings and valve bodies, respectively, that exceed 4 inch nominal pipe size. The examinations are limited to one pump or valve within a group of pumps or valves which are of the same construction design and manufacturing method, and that perform similar functions. The examination may be performed at the end of the 10-year interval, licensee's Code Relief Reauest: Relief is requested from performing the Code-required visual examination (VT-3) of the internal pressure boundary surfaces of the Class 1 pump casings and valve bodies, licensee's Proposed Alternative Examination: Class I pumps and valves, exceeding 4 inch nominal pipe size, will receive a visual examination of the internal surfaces when disassambled for maintenance, licensee's Basis for Reauestina Relief: The Licensee states that disassembly of these pumps and valves for the visual examination during the. inspection interval, in the absence of required maintenance, represents an unnecessary exposure to radiation and contamination and is counter to the ALARA guidelines to keep the occupational dose rates as low as reasonably achievable. In view of the cost in man-rem and in L view of the minimal benefits obtained, the Licensee concludes that this Code requirement does not provide sufficient benefits to justify the radiation exposure.
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Evaluation: l The visual examination is to determine whether unanticipated severe degradation of the pump casing or valve body is occurring due to phenomena such as erosion, corrosion, or cracking. However, previous experience during examination of similar pumps and valves at other plants has not shown any significant degradation of pump casings or valve bodies. The concept of visual examination if the pump or valve is disassembled for maintenance is acceptable. The disassembly of the pumps or valves for the sole purpose of inspection is a major effort and, in addition to the possibility of wear or damage to the internal surfaces of the components, could result in personnel receiving excessive radiation exposure. However, if the pumps or valves are disassembled for maintenance, the internal surfaces would be examined, in which case relief would not be required for those particular components.
Conclusions:
Based on the above evaluation, it is concluded that the Code requirement is impractical. Therefore, it is recommended that relief be granted provided that: (a) the visual examination (VT-3) of the internal surfaces of the pumps and valves is performed whenever the internal surfaces are made accessible due to disassembly for maintenance, and (b) if the subject pumps or valves have not been disassembled, this fact
- ! auld be reported by the Licensee in the ISI Summary Report at the end of the interval.
46
3.1.6 Valve Pressure Boundary 3.1.6.1 Relief Reouest RR 27. Examination Csteaories B-t-2 and B M-2.
Visual Examination o.f Class 1 Pumo Casinos and Valve Bodies NOTE: See the evaluation of this relief request under Section 3.1.5.1.
3.1.7 General -(No relief requests) 47
- ._ ~ _ .. _ _ _ . . _.
L3.2 -Class 2 Comoonents l
. . l 3.2.1 Pressure Vessels 1
3.2.1.1 Relief Rearests RR-28 and RR-32. Examination Cateoory C-B.
Class 2 Vessel Nozzle Inner Radius Sections Code Recuirement: Section XI, Table IWC-2500-1, Examination Category C-8, item C2.22 requires a 1% volumetric examination of~the Class 2 vessel nozzle inside radius sections (vessels with greater than 1/2 inch nominal wall thicknesses) as defined by Figure IWC-2500-4.
. Licensee's Code Relief Recuest: RR-28: Relief is requested from performing the Code-required volumetric examination of the l
LSteam Generator outlet nozzle inside radius section of nozzle ll201-B6-001-IR03.
RR-32: Relief is requested from performing the Code-required volumetric examination of the Residual Heat Removal Heat Exchanger inlet and outlet nozzle inside radius sections 1205-E6-002-IR01 and 1205-E6-002-IR02.
-licensee's Proposed ~ Alternative Examination: None, licensee's Basis for Recuestino Relief: RR-28: The configuration of the. Steam Generator steam outlet nozzle is such that the nozzle does not have an inner radius. The nozzle is manufactured from a forging that is a solid block of steel.
Seven holes, each 8.5 inches in diameter, have been drilled through this forging to provide an outlet for the steam. Thus,.
-this nozzle does not have.a conventional inner radius.
RR-32: The configuration of the Residual Heat Removal Heat Exchanger inlet and outlet nozzles are such that the nozzles do 48
not have anLinner radius. The subject nozzles-have a sharp inner corner, with a reinforcing metal: plate welded behind the
. inner corners, instead of the usual smooth, round configuration.-
Evaluation: The Steam Generator outlet nozzle was designed with an internal multiple hole type flow restrictor. This design does not use a radiused nozzle as described in-Figure IWC-2500-4, but instead has several individual inner radii, corresponding to each hole. Therefore, the ,
Code-required volumetric examination of the nozzle inside radius sections cannot~be performed.
As shown in the-drawing of the Residesl Heat Removal Heat E changer nozzle-to vessel welds, the subject nozzles were designed without a nozzle inside-radius section. Therefore.
-the Code-required volumetric examination cannot be performed.
Compliance with the exact Section XI requirements would require redesign of.these nozzles.
Conclusions:
Based on the above, it is concluded that
- compliance with the specific requirements of Section XI for the
-subject. nozzle inside_ radius sections is-impractical.
Therefore, it' is recommended that' relief-be granted:as-requested.
=
49 C, , . - . 2 - -_ , a _ _ _ _ . _ _ _ _ _ _ _ - _ _ _ __. .-
3.2.1.2 Relief Reagests RR 29 and RA 30 (Part 1 o.(_2). Examination _
Cateaories C A and C 0. Class 2 Vessel and Nozzle to Vessel Etldi Code Reauirement: Section XI. Table IWC-2500 1, Examination Category C A, Items C1.10, C1.20, and C1.30 require a 100%
volumetric examination of pressure retaining welds in Class 2 pressure vessels as defined by figures IWC 2500 1 and IWC-2500 2. Examination Category C B, item C2.21 requires both 100% surface and columstric examinations of nozzle to shell (or head) welds as defined by figure IWC 2500 4.
Littsste's Code Relief Reauest: Relief is requested from examining 100% of the Code required vnbr*a (CRV) of the following welds:
RR-29: Steam Generators CRV Identifigation No. .
Descriotion [taminable ll201 B6-001 W18 32" Steam Outlet Nozzle- 50%
to Head Weld 11201-B6-002 W19 16" Main feedwater Nortle- 50%
to Shell Weld 11201 B6 003 WO5 Lower Cone End Stub Barrel- 90%
to Lower Shell Barrel "B" Weld ll201 86-004 WO7 Lower Shell Barrel "A"- 94% -
to Tube Plate Weld 11201 B6 004 W26 6" Aux. Feedwater Nozzle- 46%
to-Shell Weld RR-30: Recenerative Heat (xchanaer CRV idgJtification No. Descriotion Examinable ll200 E6 001 W01 Head-to-Tube Sheet Weld 94%
11208-E6-001-WO2 Tube Sheet-to-Shell Weld 93%
ll203-E6-001 WO9 Tube Sheet-to Shell Wold 93%
ll208 E6-001 W10 Tube Sheet-to Head Weld 94%
50 m w erden naamrumman a g, -
RR 30: Excess letdown, Heat Exchan0RI CRV Identification % Descriotion [nm_inttle 11208 E6 002 W01 Unit Flange to Cliannel Head 45%
Weld RR 30: Letdown Heat Exchancer CRV Identification No. _
Description Examinable ll208 E6 003 WO3 Vessel Head to Head flange 29%
RR 30: Letdown Reheat Heat Exchanaer CRV Identification No. Descriotion Examinable ll208 E6 007 WO3 ' Vessel flange to Vessel Shell 84%
RR-30: Discharae Pulsation Damoener CRV Identification No. Descriotion Examinable ll208 V4 002 W01 Hemi Head to-Hemi Head Weld 89%
RR 30: Boron iniection Tank CRV Identification No. Descriotion Examinable ll204 V6 001-W01 Nozzle to Head Weld 50%
ll204-V6-001 WO2 Head to Shell Weld 38%
ll204-V6 001 WO3 Head to Shell Weld 50%
ll204 V6 001 WO4 Nozzle-to Head Weld 50%
Licensee's Proposed Alternative Examination: None. The Licensee reports that the Code required volumetric examinatioa will be performed to the maximum percentage pos...le (see percentagesabove).
Licensee's Basir for Reauestina Relief: Access limitations are generally due to geometric configuration of the welded areas.
Flanges and supports restrict coverage of the required examination volume on some of the subject welds. The specific restrictions for each ws i are described by the Licensee in the tables attached to relief rs,"ests RR 20 and RR-30.
51
Evaluation: The Licensee's submittals have been reviewed, including the Attachments listing the welds or components for which relief is being requested, the weld configuration, the Code requirement, the reason for the limited examination, and the approximate percentage of the Code required examination that can be completed. It is noted that, in most cases, a significant portion of the Code required volumetric examination can and, as the Licensee states, will be completed. The subject components would require extensive modifications in order to obtain complete compliance with the specific requirements of Section XI.
Conclusions:
Based on the above, it is concluded that the volumetric examination is impractical to perform to the extent required by the Code and that the limited Section XI volumetric examination, in conjunction with the required hydrostatic tests, provide a reasonable assurance of the conti.nued inservice structural integrity. Therefore, it is recommended that relief be granted as requested.
3 52
3.2.1.3 Relief Reauest RR 31. Use of Pipina Calibration Blocks to Examine Thin Wall Vessels Code Reauirement: Section XI Paragraph IWA 2232 requires the use of the applicable requirements of Article 5 of Section V for the ultrasonic examination of Class 1 and Class 2 vessel welds in material other than ferritic steel.
However, Article 5 does not provide specific guidance or, how to perform these examinations.
Licensee's Code Relief Reauest: The Licensee requests the
' modification of the Section V, Article 5 requirement to allow the use of Section XI Appendix !!! for examination of the following Class 2 thin wall vessels :
RHR Heat Exchanger 11205 E6 002 Letdown Heat Exchanger ll208 E6 003 ,
Letdown Reheat Heat Exchanger ll208 E6 007 Excess Letdown Heat Exchanger 11208 E6 002 Regenerative Heat-Exchanger 11208 F6 001 Suction Dampener 11208-V4 001 Licensee's Proposed Alternative Examination: Calibration standards, designed in accordance with Figures T-547.1 and .;
T 546.1 of ASME Section V and containing 10% T notch depths and side drilled holes, will be utilized to-perform ultrasonic examinations 1on the above listed thin wall vessels.
Licensee's Basis for Mauestino Reitti: Article 5 of Section V does not give complete guidance for performing ultrasonic examination of austenitic welds. However, Paragraph T-548 does give permission to modify or supplement the provisions of this article.. The calibration blocks that will be used were fabricated from the same diameter and wall thickness piping as the heat exchangers.
Evaluation: It is noted that the later 1986 Code Edition of Section XI,' Mandatory Appendix 1, " Ultrasonic Examinations,"
53 i
e A.h . ,,,-,y-..n - = n.N, ,,_-., n n la w lcew.n.,m_,,,,,,.,.., ,,_,,,,,,,_,,,,,_.,__.__,_,,,,_,,,-,_..,,+,..,.,_._,,,.,a,.n.,,-v
Paragraph 1 2000 requires that ultrasonic examination of vessel welds less than or equal to 2 inches in thickness and all piping welds shall be conducted in accordance with Appendix 111, as supplemented by Appendix 1.
Also,Section XI, Paragraph IWA 2240 states that alternative examination snethods, a combination of methods, or newly developed techniques may be substituted for the methods specified in Division 1 of Section XI, provided the Inspector is satisfied that the results are demonstrated to be equivalent or superior to those of the specified method.
Since the later Code Edition requires the use of Appendix Ill, as supplemented by Mandatory Appendix 1, and Paragraph IWA 2240 permits the use of alternative examination methods, provided the inspector is satisfied that the results are demonstrated to be equivalent or superior, the Licensee's proposal should be considered acceptable.
e
Conclusions:
Based on the above, it is concluded that the Licensee's proposed alternative examination method is technically justified as being equivalent or superior to the specified method. Therefore, it is recommended that relief be granted as requested.
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1 3.2.2 Pioina 3.2.2.1 Relief Reauest RR-26 f eart 2 of 2) and RR-34. Examination Cateaory C-F. Pressure Retainina Welds in Class 2 Pioina Code Reauirement: Section XI, Table IWC 2500-1, Examination i Category C-F, item C5.21 requires both 100% surface and volumetric examinations of pressure retaining circumferential welds in Class 2 piping as defined by Figure IWC-2500 7.
Licensee's-Code Relief Reauest: Relief is requested from examining 100% of the Code required volume (CRV) on the following welds:
CRV Relief Reauest Examination ID No. Examinable RR-26: 11204-120 6 50%
11204-121-6 50%
11204-122 6 50%
11204-123 6 50%
RR-34: 11301-001-5 32%
11301-001-6 50%
11301-001 8 41%
11301-002 5 41%
11301 002 6 50%
11301-002 8 50%
11301-002-9 99%
11301-002-10 99%
11301-003-5 32%
11301-003-6 32%
11301-003 8 32%
11301-004 5 44%
11301-004 6 41%
11301-004-8 41%
11301-108-14 86%
Licensee's Proposed Alternative Examination: None. In addition to the Code-required surface examination, the Code-required ultrasonic examination will be performed to the maximum extent possible (see above table).
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Licensee's. Basis for Reauestina Relief: Physical limitations i due to geometric configuration of the welded areas (valve to-pipe or pipe to-penetration welds) restrict coverage of the Code-required examination volume.
EvaluatioD: The Licensee's submittal was reviewed, including the Attachments that list the welds for which relief is being requested, the weld configurations, the Code requirements, a brief description of the restriction, and the approximate percentage of the Code required examination that can be cornpleted. As the Licensee has stated, the geometric configurations of the subject welds restrict coverage of the Code required examination volume.
Complete examinations which meet the requirements of ASME Code Section XI will be performed on welds of similar configuration using the same inspection techniques, equipment, and procedures as those for the partially inspected welds. Since the welds receiving limited examination are seeing the same operating and environmental conditions as the inspected welds, reasonable assurance of the continued inservice structural integrity of the welds for which relief is requested will be attained.
Conclusions:
Based on the above review, -it is concluded that the volumetric examination is impractical to-perform to the extent required by the Code. Therefore, it is r* commended that relief be granted as requested.
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i 3.2.2.2 Relief Reauests RR 35. RR 36. and RR-37. Auamented Volumetric Examination of Class 2 Pinina Welds in the Enaineered Safety Systems Auament3d Reauirement: As a condition of licensing, Georgia Power Company agreed to volumetrically examine a minimum of 7.5% of the Class 2 welds in the engineered safety systems (Containment Heat Removal, Emergency Core Cooling, and Residual Heat Removal Systems). These examinations should be performed in accordance with the following requirements:
Section XI, Paragraph 111 4420 requires that the volumetric examination be performed using a sufficiently long beam path to provide coverage of the required examination volume in two beam path directions. The examinations shall be performed from two sides of the weld, where practicable, or from one side of the weld as a minimum. Paragraph III-4430 requires that the angle beam examination for reflectors transverse to the weld be performed on the weld crown on a single scan path to examine the weld root by I/2 V-path in two directions along the weld.
Paragraph 111-3410 requires that the basic calibration block be made from materials of the same nominal diameter and nominal wall thickness or pipe schedule as the pipe to be examined.
Paragraph III-3430 requires that basic calibration blocks contain circumferential and longitudinal notches whose sides are perpendicular to the surface and at least 1.0 inch long on the 0.D. and I.D. surfaces.
Licensee's Relief Reauest: RR 35: Relief is requested from performing the angle beam examination for reflectors transverse to the weld.
RR-36 and RR-37: Relief is requested from examining 100% of the augmented examination required volume (ARV) of the l following 89 welds (6 inch and larger NPS) as listed in RR-36,
, and 46 welds (2- to 4-inch NPS) as listed in RR-?7:
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- ~ - . - - - - . - . .
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Relief Reauest 26 ARV ARV i Examinittien ID No. Examinable Dutm.intjpa_ID_jh Examinable 11202 001-1 50% 11206 007-1 50%
11202 001 17 50% 11206 007-10 50%
11202 140 9 50% 11206 008 1 50%
11202-140 27 50% 11206 008 10 50%
11202 141-19 50% 11206 008 16 94%
11202 188 4 50% 11204 001-9 50%
11202 188-5 50% 11204 006 1 50%
11202 189 1 50% 11204-006 64 50%
11202 189 2 50% 11204 006 72 50%
11202-189 3 44% 11204 007-17 50%
11202 189 7 50% 11204 008 33 50%
11202 192 16 50% 11204 011-8 50%
11202 196 7 50% 11204 012 2 50%
11202-197 3 50% 11204 038 1 80%
11202 202 18 50% 11204-038 8 80%
11202 202-22 50% 11204 123 5 85%
11202 204 1 50% 11204-177-13 50%
11202 204-15 50% 11204-192 1 50%
11202-205-1 50% 11205 003 62 97%
11202-205-14 50% 11205 003 64 50%
11202 207-14 50% 11205-004 54 50%
11202-209 4 50% 11205 005 1 50%
11202-209 5 93% 11205 005 32 50%
11202 211-1 50% 11205 006-1 50%
11202 211-3 50% 11205 006 2 50%
11202 211 17 50% 11205 006 3 50%
11202-212 15 50% 11205 006-20 50%
11202 212 19 50% 11205-006-27 50%
11202 212 36 50% 11205-007-1 50%
11202-216-41 50% -11205 007-23 94%
11202-216 42 50% 11205 007-77 50 11202 218-1 50% 11205 008-1 50%
11202-218-20 50% 11205 009-1 50%
11202 220 2 97% 11205 009 24 50%
11202 220-12 50% 11205-039 3 50%
11202-225-50 50% 11208-137-1 37%
11202 229-12 50% 11208 137-8 94%
11202 229 13 50% 11208 137-15 50%
11206 003 1 50% 11208 139-4 94%
11206-004 4 50% 11208-139-8 93%
11206 004-17 -50% 11208-139-30 50%
11206 005 1 48% 11208-139-35 50%
11206 005 55 50% 11208 411 2 50%
11206-006-1 48% 11208-411-51 88%
11206 006 51 50%
t 58
Belief Reauest 11 ARY ARV Examination ID No. Examinable Examinatipn 10 No. Examinable 11204-014-13 50% 11208 022 7 88%
11204 014 20 50% 11208 022-22 88%
11204-014 26 92% 11208 023 36 88%
, 11204-014 54 50% 11208 023-43 88%
11204 015 13 50% 11208-023 55 88%
11204 028-1 93% 11208 023 56 88%
11204 037 56 50% 11208 023-59 81%
11204-063 54 50% 11208-023 76 88%
11204 169 1 50% 11208 044-1 50%
11204-169-45 50% 11208-044 2 75%
11204 197 8 88% 11208 044 4 75%
11208 003 2 50% 11208 046-2 75%
11208-003 4 50% 11208-046-3 75%
11208 003 6 50% 11208 046 4 75%
11208 003 17 50% 11208 099-4 75%
11208 003 21 50% 11208 101 6 50%
11208 003 30 50% 11208-123 55 50%
11208 003 33 50% 11208-146 5 50%
11208 003 49 75% 11208-146-17 95%
11208-003-57 75% 11208 147 2 75%
11208-022 2 85% 11208 147-3 75%
11208 022 5 91% 11208-147-5 50%
11208-022-6 88% 11208 147 8 75%
Licensee's Prooosed Alternative Examinatl0B: RR-35: An axial ultrasonic scan, using a 1/4 inch diameter 60' shear wave transducer will be performed nn the required welds. This transducer will use a modified wedge to reduce the front wedge to index point distance.
RR-36, RR 37: None, in addition to a surface examination, an ultrasonic examination will be performed to the maximum extent possible.
Licensee's Basis for Reauestina Relief:- RR-35: The Licensee-states that because the thin wall piping welds at Vogtle have extremely wide weld crowns on both circumferential and longitudinal welds the scans parallel to the welds will not be performed since the sound beam cannot be made to hit the root area of the weld. The weld crowns cannot be ground flush because of minimum wall thickness violations due to weld shrinkage at the root.-
59
l RR-36 and RR 37: The Licensee states that physical limitations due to geometric configuration of the welded areas (i.e.,
valve-to pipe, reducer-to pipe, flange to-pipe, elbow to pipe) I and piping support obstructions prevent complete coverage of ;
the required volume.
Evaluation: The information submitted by the Licensee has baen reviewed, including the attachments that list the welds for which relief is being requetud, the weld configuration, the restriction, and the approximate percentage of the augmented examination that can be completed. The physical limitations described prevent complete coverage of the subject thin wall and small diameter piping welds to the extent described by the Licensee. A significant portion of the augmented examination counitment will be completed. The augmented examinations provide reasonable assurance of the continued inservice structural integrity.
NOTE: In the original submittal of RR 35 (Revision 0) for ISI, the Licensee also requested relief from using calibration standards as required by Section XI, Article III. The Licensee proposed using a flat calibration block containing-side drilled holes in lieu of the Code requirement. This relief request had been previously granted for PSI with the condition that proper calibration blocks be obtained and utilized for all future 151-examinations.
In the October 21, 1987 response to the NRC request for additional information with regard to why the proper calibration blocks were not being obtained for use during ISI examinations, the Licensee committed to modify RR-35 to delete the request for relief from calibration block requirements. This request was deleted in RR-35 (Revision 1), submitted July 18, 1988.
Conclusions:
Based on the above, it is concluded that the augmented examination of thess welds is impractical to perform to the extent required. Therefore, it is recommended that relief be granted as requested provided that proper calibration blocks are obtained and used c'uring ISI examinations.
60
._ .~.. -- -
l 3.2.3 Pu?Ds ;
3.2.3.1 Relief Reauest RR-30 (Part 2 of 21. Examination Cateoory C G u I
Class 2 Purro Casina Weld l
Code Reauirement: Section XI, Table IWC 25001, Examination ;
Category C G, item C6.10 requires a 100% surface examination of Class 2 pump casing welds as defined by Figure IWC 2500 8.
Licensee's Code Relief Recuest: Relief is requested from examining 100Y. of the Code required surface area on Safety ;
Injection Pump casing to-suction nozzle weld 11204 P6 003 WO2.
- Licensee's proposed Alternative Examination: None. The Code-required surface examination will-be completed to the maximum extent practical.
Licensee's Basis for Reauestina Relief: The Licensee reports that only 66% of the Code required surface area can be examined l
. because the pump supports prevent access to the remaining area.
Evaluation: The'information submitted by the Licensee has been reviewed and it is noted that a significant portion of the Code-required surface examination can and will.be performed.
Because of the interference caused by the pump supports, the Safety Injection Pump would require extensive modification in order to obtain complete compliance with the specific 7 requirements of Section XI.
Conciusions: Based on the above,'it is conclu'ded that the .
Section XI surface examination is impractical to perform to the- . ,
extentLrequired by the Code and that the limited surface examination will provide reasonable assurance of the continued-inservice structural integrity. Therefore, it~is recommended that relief be granted as requested.
61 pea
-e r-,4ergurw- we +.0ews.-ag.a'smy s--W'Tf e* g W 1 my gag.ag4m e, pi.i ye -w-#m 9, pp' p wwg r g,N'-.-.ig-9gaq. +,&-.;p_ 9_y_.g-q.4, ,-97 mw9
i 3.2.4 Valves (No relief requests) 3.2.5 General 3.2.5.1 Relief Reauest RR 33. Examination Cateaory C D. Pressure Retainino Class 2 Boltina Exceedina 2 Inch Diameter ,
@li: Relief was requested from performing the Code required volumetric examination of the Safety injection Pump casing studs if the pumps were not disassembled for maintenance. In the.0ctober 21, 1987, response to the NRC request for additional information -the Licensee withdrew Request for Relief RR 33.
3.3 Class 3 Comconents (No relief requests) 62
3.4 Pressure Tests 3.4.1 (13ss 1 System Pressure Tests (No relief requests) 3.4.2 . Class 2 System Pressure Tests 3.4.2.1 Relief Reauest RR 44. Examinatian,Cateaory C H. Hydrostatic Test of Class 2 Components Which fannot be Isolated from Class 1 Comnonents Code Recuirement: Section XI Article IWC-5000 requires that Class 2 pressure retaining components within each system boundary be subjected to a system hydrostatic pressure test for each system or portions of systems. The system hydrostatic test pressure shall be at least 1.10 times the system pressure for systems with design temperatures of 2n0'F ..' less, and at least 1.25 times the system pressure for systems with design temperatures above 200*F. The system pressure shall be the lowest pressure setting among the safety or relief valves provided for overpressure protection within the boundary of the system to be tested. For systems (or portions of systems) not provided with safety or relief valves, the system design pressure shall be substituted for the system pressure.
Ligpnsee'i Code Relief Reouest: Relief is requested from performing the Code-required hydrossetic test at the specified test pressure for the following portions of piping and valves between the boundary valves r.7d the first shutoff valves:
Line No. Check Valve (s) __ Shutoff Valves 1208 023 1208 U4-006 1208 U4-005 1208-042 1208-U4-359 1208 U4 356 1208 044 1208-U4-360 1208-U4 357 1208-046 1208 U4 361 1208 U4-358 1208-488 1208-06 037 HV-8147 1208 008 1208 U6 035 HV-8146 & 1208-U4 498 1204-063 1".04-06-013 HV-8801A&B 1204-082 1204 U6-013 HV-8843 1204-058 1204-06-013 HV-1204-U4-007 1204-016 1204-U4 120 HV-8802A & HV-8881 1204-197 1204 U4-121 HV 8802A & HV-8881 63
- - . _ . . ~ - . _ - - ~ . _ - - . - - _ . . - . - - - _. -_
(continued)
Line No m Check Valve (s) Shutoff Valves r 1204 020 1204 U6 128 HV 8840 & HV 8825 l 1204-201 1204 U6-129 HV 8840 & HV 8825 1204 017 1204 U4 123 HV 8802B & HV 8824 1204-199 1204 04 122 HV 8802B & HV 8824 1204 029 1204 U4 146 HV 8835 & HV 8823 1204 030 nGa U4-145 HV 8835 & HV 8823 1204 031 uh4 U4-144 HV 8835 & HV-8823 1204 032 1204 U4 143 HV 8835 & HV 8823 1204 039 1204-06-147 HV 8809A 1204 06 148 HV 8890A 1204 041 1204-06 149 HV-8809B 1204 U6 150 HV-88908 Licensee's Prooosed Alternative Examination: In lieu of pressurizing the above portions of piping to Class 2 requirements, the piping will be pressurized to Class 1 requirements.
Licensee's Basis for Reauestina Relief: The test pressures required by IWC-5222 (Class 2) are higher than those required by IWB 5222 (Class 1). Paragraph IWC-5222 requires a test pressure of 1.25 times the system pressure or system design pressure. Paragraph IWB 5222 requires a test pressure of 1.02 to 1,10 times the system nominal operating pressure depending on the temperature. These portions of Class 2 piping are ,
isolated from Class 1 piping by utilizing check valves which open with flow.to Class 1. To pressurize the upstream side of the check valves to Class 2 requirements would result in exceeding the Class I hydrostatic test pressure requirements for adjacent ~ Class 1 piping.
Evaluation: 'Th'e system's design does not permit pressurizing the sections of piping to the Code required pressure without either extensive temporary valve modifications or overpressurizing the Class I sections of connected piping.
Because of this, the Code-required test pressure is impractical to attain. However, these sections of piping will be subjected 64
to a pressure slightly higher than normal operation pressure.
The visual inspection of the piping during the pressure test, as well as other NDE examinations for selected welds in the systems, will provide reasonable assurance of the continued inservice structural integrity of the piping. >
Conclusions:
Based on the above evaluation, it is concluded ,
that the Code required test pressure is impractical to attain.
Therefore, it is recommended that relief be granted as '
requested.
65
3.4.2.2 Relief Recuest RR 45. Examination Category C H. Chss 2 SysteL livdrostatic and System Pressure Tests Code Reouirement: Section XI, Table IWC 2500 1 Examination Category C H, Jtems C7.30, C7.40, C7.70, and C7.80 require a system hydrostatic test and a system pressure test during system functional and system inservice testing of Class 2 piping and valves.
Licensee's Code Relief Recuest: Relief is requested from performing the Code-required hydrostatic and system pressure tests on Class 2 piping systems of contrinment penetrations which are not required for operation to support engineere) safety features systems.
Licensee's Proposed Alternative Examination: None. The Licensee states that piping systems that penetrate the containment vessel will be tested as required by Appendix J of 10 CFR 50.
Licensee's Basis for Reouestina Relief: The Licensee's Basis for Relief states, "lWA 1320(d) states 'The portion of piping that penetrates e containment vessel, which is required by Section 111 to be constructed to Class 1 and 2 rules for piping and which may differ from the classification of the balance of the piping system, need not affect the overall system classification that determines the applicable rules of this Division.' Relief is requested from the system pressure test requirements of Examination Category C-H on the Class 2 portions of piping that penetrate the containment vessel on the piping systems described above. The safety related function of these piping penetrations is to minimize the release of radioactivity to the outs!de atmosphere following a ' Loss of Coolant Accident.' Appendix J of 10 CFR Part 50 requires 66
~ ~-
O adequate testing of containment penetrations to provide assurance of structural integrity and, as such, further testing by Section XI is not necessary,"
Evaluation Appendix J addresses the structural integrity of the primary containment, not the structural integrity of the Code Class 2 piping for which reitef is being requested. The request for relief does not contain a specific itsting of Class 2pipingsystem(s)/line(s)involvedandtheLicenseehas not provided adequate technical information to justify the determination that the Code requirement is impractical,
Conclusions:
Based on the above evaluation, it is concluded that the Licensee has not justified the determination of impractictlity and that imposing the Code requirement on the Licensee would not result in hardship. Therefore, it is recommended that relief be denied, 67
3.4.2.3 Relief Reauest RR-46. Examination Cateagry 0 H. Visual (VT 2) .
Examinations Durino System functional or System Inservice Test Code Reouirement: Section XI, Table IWC 25001, Examination Category C H Items C7.10 C7.30, C7.50, and C7.70 require a VT-2 examination during a system functional or a system inservice test of Class 2 pressure vessels, piping, pumps, and vahes, respectively par IWC 5221.
Licenseejs Code Relief Reauest: Relief is requested to allow VT-2 visual examination of pressure retaining components during conditions other than system functional or system inservice testing.
Licensta's Proposed Alternative Expinatio.n: A VT 2 visual examination will be performed on pressure retaining components at pressures which meet or exceed the requirements of IWC 5221.
Ligensee's Basis for Recuestina Relief: Portions of some systems are normally pressurized or can be pressurized to their normal operating pressures without the system being pressurized during a system functional test or a system inservice test. A typical example of the above is the portion of a system from an atmospheric storage tank to the suction side of a pump.
Evaluation: ASME Code Section XI, Paragraph IWA-2240 permits the use of alternative examination methods, a combination of methods, or techniques, provided the Inspector is satisfied that the results are demonstrated to be squivalent or superior to those specified.
The Licensee has stated that the VT-2 visual examination will be performed on pressure retaining components at pressures which meet or exceed the Code requirements. However, the 68
=
1 Licensee has not addressed the test pressure hold time prior to the start of VT 2 examinations, it is noted that the system functional test, conducted to verify operability in systems (or components) not required to operate during normal plant operation while under system operating pressure, requires a hold time of 10 minutes after attaining the system operating pressure. The system inservice test, conducted to perform VT-2 visual examination while the system is in service under operating pressure, requires no holding time provided the system has been in operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The appropriate test pressure hold times should be adhered to for the alternative visual examination.
Conclusions:
Based on review of the Licensee's submittal and the above evaluation, it is concluded that relief should be granted provided that (a) the appropriate hold time, as well as the test pressures, meet or exceed the Code *cquirement, and (b) the subject VT-2 visual examination for leakage is performed once each inspection period.
69
3.4.3 Class 3 System Pressure Tests 3.4.3.1 Relief Reauest RR-48. Examination Cateaorv 0 A. Class 3 Sys(tm_
intgryfte Test of Systems Used in Support of Reactor Shutdown Function Code Reoutre_gni: Section XI. Table IWD 2500-1, Examination Category D A, Item 01.10 requires a VT 2 visual examination of pressure retaining components during a system inservice test (IWD+5221). ParagraphIWA5213(c)requiresthatsystemsbein operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to the start of the VT 2 visual examination during the system inservice test.
Licensee's Code Relief Reauest: Relief is requested from performing the Code required VT-2 visual examination during the system inservice test s~or the following Class 3 Chemical and Volume Control (CVC) lines:
Line 1208 242 from 1208 P6 006 to 1208 F6 003 Line 1208-243 from 1208-P6 007 to line 1208 242 Line 1208 213 from line !?08 24? to 1208-T4-003
& valve 273 Line 1208 131 frum 1208 F6 003 to valve HV 8104
& line 1208 134 Line 1208 134 from line 1208 131 to valve 188, line 1208118
& valve llV 8439 Line 1208-118 from line 1208 134 to valve 174 Line 1208 116 from line 1208 134 to valves FV Olll8
& FV-01108 Line 1208 127 from line 1208-116 to valve 171 Line 1208 450 from line 1208-131 to line 1208-213 Licensee's Proposed Alt,ernative Examination: A VT-2 visual examination will be performed during system functional testing in lieu of system inservice testing.
Licensee's Basis for Reauestino Relief:. Paragraph IWA-5213(c) requires that systems be in operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to the start of VT-2 visual examination during system E 70 l
- _ . ~ . . _ _ _ --
inservice test. The Licensee states that those portions of systems listed above are not normally in operation for durations of at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Evaluation: Paragraph IWA-5213(b) requires a hold time of only ,
10 minutes for system functic..a1 tests. This hold time may be adequate if the subject lines are not insulated. However, if the subject lines are insulated, the Licensee should address the following: Can the insulation be removed for the functional testing? If the insulation cannot be removed and if the operating time is less than the Code-required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, what would the maximum operating time be prior to the VT 2 visual examination? Is it possible for the subject system to remain in operation for the Code required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in order to meet the Code requirement? The Licensee has not provided adequate information to justify that the Code required examination is impractical.
Conclusions:
Based on the above evaluation, it is concluded that the Licensee has not justified the determination of impracticality and that imposing the Code requirement on the Licensee would not result in hardship. Therefore, it is recommended that relief be denied.
71
3.4.3.2 Relief Reauest RR 49. Examination Cateaory D A. System Hydrostatic Trst and Visual (VT 2) Examination of Class 3 Vertical Pit Tvoe Pomos
[ ode Reauirement: Section XI. Table IWD-25001, Examination Category D A, item 01.10 requires a system hydrostatic test (IWD 5223) and a VT-2 visual examination during system inservice testing (IWD 5221) of Class 3 components in support of reactor shutdown function.
Licensee's Code Relief Reauest: Relief is requested from performing the Code required hydrostatic test and VT-2 visual examination during the system inservice test of the Class 3 vertical pit type pumps. The following nuclear service cooling water (NSCW) pumps and transfer pumps are affected by this relief request:
1-1202-P4 001 1-1202 P4 005 1-1202-P4 002 1-1202-P4 006 1 1202 P4 003 1 1202-P4 007 1 1202-P4-004 1 1202-P4-008 Licensee's Procosed Alternative Examinatign: None. These pumps are periodically tested as required by Subsection IWP.
These tests verify operability of the pumps and, by doing so, would detect significant leakages through the pressure retaining boundary. A VT-2 visual examination will be performed each inspection period during system inservice testing of portions of the pumps which are not submerged in the NSCW tower basin.
Licensee's Basis for Recuestina Relief: The NSCW pumps and transfer pumps are vertical pit type pumps which take suction from the NSCW tower basins. Since these pumps are vertical pit type pumps, there are no isolation valves on the suction side of the pumps to facilitate hydrostatic testing. Therefore, the performance e a hydrostatic test on the pumps and the piping 72
to the first discharge shutoff valve is impractical. In addition, the performance of a VT-2 visual examination during system inservice testing is also impractical on the suction side portion of these pumps because they are submerged in the NSCW tower basin.
Evaluation: As there are no isolation valves on the suction side of these vertical pit type pumps, a hydrostatic test is impractical. Likewise, the performance of the VT 2 visual examination for evidence of leakage of the submerged section on the suction side of the pumps is impractical. The inservice tests, as required by Subsection IWP to verify operability of these pumps, would detect significant leakages through the pressure retaining boundary.
Conclusions:
Based on the above evaluation, it is concluded that the Code required hydrostatic testing and VT-2 requirements are impractical for the portions of Class 3 piping listed above end that the fune.tional tests of these pumps will provide reasonable assurance of the continued inservice structural integrity. Therethre, it is recommended that relief be granted as requested.
73
h 3.4.3.3 Relief Reauest RR-50. Examination Cateaories D A. D B and D.C.
Visual (VT-2) Examinations Durina System Functional or System Inservice Tests Code Reauirement: Section XI, Table IWD 2500 1, Examination Category D A, item D1.10 and Examination Category D C, Item 3.10 require a VT 2 visual examination of pressure retaining components during a system inservice test per IWD 5221. Examination Category 0 0, item D2.10 requires a VT-2 visual examination of pressure retaining components during a system functional test per IWD 5222.
Licensee's Code Relief Reauest: Relief is requested to allow VT 2 visual examination of pressure retaining components during
. conditions other than system functional or system inservice testing.
Licensee's Proposed Alternative Examination: The Code-required VT-2 visual examination will be performed on pressure retaining components at pressures which meet or exceed the requirements of IWD 5221 or IWD 5222.
Licensee's Basis for Reauestina Relief: Portions of some systems are normally pressurized or can be pressurized to their normal operating pressures without the system being pressurized during a system functional test or a system inservice test.
The Licensee states that a typical example of the above is the portion of a system from an atmospheric storage tank to the suction side of a pump. Relief is requested to allow VT-2 visual examination of the pressure retaining components at any time as long as the portion of the system being examined is subjected to pressures which meet or exceed the requirements of IWD-5221 or IWD 5222.
74
. _- =. .. _ . _ - - _ - _ . - - . -_ - -
Evaluati2D: ASME Code Section XI Paragraph IWA 2240 permits the use of alternative examination methods, a combination of methods, or techniques, provided the Inspector is satisfied that the results are demonstrated to be equivalent or superior to those specified.
The Licensee has stated that the VT-2 visual examination will be performed on pressure retaining components at pressures which meet or exceed the Code requirerents. However, the Licensee has not addressed the test pressure hold time prior to the start of VT 2 examinations. It is noted that the system functional test, conducted to verify operability in systems (or components) not required to o,rcnte during normal plant operation while under system operating pressure, requires a hold time of 10 minutes after attaining the system operating pressure. The system inservice test, conducted to perform VT-2 visual examination while the system is in service under operating pressure, requires no holding time provided the system has been in operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The appropriate test pressure hold times should be adhered to for the alternative visual examination.
-Conclusions: Based on review of the Licensee's submittal and the above evaluation, it is concluded that relief should be granted provided that (a) the appropriate hold time, as well as the test pressures, meet or exceed the Code-requirement, and (b) the subject VT-2 visual examination for leakage is performed once each inspection period.
l l 75
3.4.3.4 Relief Reauest RR 51. Examination Cateaory 0 B. Visual (VT-2)
Examination Durina System F9nctional Test Code Reauiremeq1: Section XI, Table IWD-2500 1. Examination Category D-B, item D2.10 requires a VT-2 visual examination of Class 3 pressure retaining components during a system functional test as defined by IWD 5222.
Licensee's Code _ Relief Reauest: Relief is requested from performing the Code-required VT-2 visual examination during a system functional test of the following portions of systems:
Line 1217-267 from valve 084 to line 1217 071 Line 1217 268 from valve 085 to line 1217-072 l Line 1217 266 from valve 086 to-line 1217-073 Line 1217-265 from valve 087 to line 1217 150 Line 1217 073 from line 1217-266 to line 1217-150 Line 1217-071 from line 1217 267 to line 1217 150 line 1217 072 from-line 1217 268 to line 1217 150 '
Line 1217-150 from valve HV 2041 to lines 1217-071, 1217-022, 1217-073, & 1217-265 Licensee's Proposed Alternative Examination: A VT-2 visual examination will be performed during system inservice testing in lieu of system functional test.
Licensee's Basis for Reauestino Relief: The Licensee states that the portions of systems listed above are pressurized during normal system operation and, as such, it is requested that the VT-2 visual examination be allowed to be performed during a system inservice test.
I Evaluation: A system functional test is conducted to verify operability in systems (or components) not required to operate during normal plant operation while under system operating pressure. A system inservice test VT-2 examination is conducted while the system is in service under operating pressure. Therefore, the Licensee's proposal to perform the 1
76
l l
VT 2 visual examination on the subject piping when pressurized during normal system operation meets the intent of the Code.
Conclusions:
Based on the above evaluation, it is concluded ,
that the specific Code requirement is impractical and that the alternative test proposed by the Licensee meets the intent of the Code, Therefore, it is recommended that relief be granted as requested.
s e
77
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5.3.5 Relief Recue RR-53. Examination Cateaory 0-C. VT-2 Visual
> .aminat. ion Durina Hydrostatic and System inserv,1ce Tests of
^
Sfstnt Fuel Coolina and Purification System Code Re_quirement: Section XI, Table IWD 2500-1, Examination Category 0-C, Item b3.10-requires VT-? visual examinations during hydrostatic and tystem inservice tes'.s of Class 3 7,[ pressurt <" - %ing components.
4 ? 1.q1nigg' _ tode Relief Reouest: Relief is requested from perfnrming the Code-required VT-2 visual examination during h;drostatic and rystem inservice tests on Class 3 piping of the Spent Fue" 'coling and Purification System which are encased in concrete or submerged in the spent fuel pit.
Licensee's Proposed Alternative Examination: None.
Liccnsee's Basi: for Recuestina Relief: Portions of the Spent Fuel Cooling and Purification System are encased in concrete or
( submerged in the spent fuel pit precluding any direct or remote means of performing the Code-required VT-2 visual examination.
In addition, the requirements of Para 5caph IWA-5244(b) for buried piping cannot be met because tr.e piping is sutmerged ,
preventing the use of flow in'. ' mentation. Tha Licensee also reports that the Technical Specifications require that spent fu:1 pit water level ha maintained. 0 Evaluation: B . se the subject portions of the Spent Fuel Cooling and Purification System are encased in concrete or )f submerged in the spent fuel pit, the Code-required VT-2 visual examination during hydrostatic and system inservice tests is impractical. The continued monitoring of the spent fuel pit water level, as required by the Technical Specifications, will provide reasonatle assurance of the continted inservice st.uctural integrity of the subject piping.
78
~ .. . -. -. - . -.
Conclusions:
Based on the above evaluation, it is concluded that the Code-required VT-2 visual eramination during hydrostatic and system inservice tests of the encased or submerged por_tions of these lines is impractical to perform.
Therefore, it is recommended that relief be granted as requested.
4 L 79
3.4.4 General 3.4.4.1 Relief Reaggit RR-47. Examination Cateaories C-H. D A. and D-B.
Visual (VT-2) Examinations Durina System Functional or Syst2m_
Inservice Tests of Systems Which Contain Air Durina System Doeration Code Reauirement: Section XI, Table IWC-2500-1, qamination
- ategcry C H, items C7.10, C7.30, and C7.70, and Examination Categories D A and D-8, items 01.10 and D2.10, resp 1ctively, all require a VT-2 visual examination of pressure r ? Tining components during a system functional or system inservice test.
Licensee's Code Relief Rqqqgil: Relief is requested from performing a VT-2 visual examination during system functional or system inservice testing of the containment hydrogen monitor system and the radiation monitor system. Both of these systems cor.tain air during system operation.
e Licensee's Proposed Alternatiyg, Examination: None, ticensee's Basis for Reauestina Relief: The Licensee reports that the containment hydrogen monitor system and the radiation monitor system contain air during system operation. The VT-2 visual examinations are conducted to 1ccete evidence of leakage from pressure retaining components. Since these systems are
- air-containing systems, a VT-2 visual examination will not locate evidence of leakage and, as such, a VT-2 visual examination is unnecessary. The Licensee also reports that sue l system hydrostatic tests required once per interval are sufficient to ensure the integrity of the pressure-retaining boundary.
l I
l 80
-Evaluation: Paragraph IWC 5210(b) of the Code states, in part, that "The system pressure tests and visual examinations shall be conducted in accordance with IWA-5000 and this Article. The conta.ined fluid in the system shall serve as the pressurizing medium . . . . Where air is used, the test procedure shall permit the detection and location of through-wall leakages in components of the system tested." The Licensee has not provided technical information to justify the determination that the Code-required examination and test procedures are impractical.
Conclusions:
Based on the above evaluation, it is concluded that the Licensee has not justified the determination of impracticality and that imposing the Code requirement on the Licensee would not result in hardship. Therefore, it is recommended that relief be denied.
81 i
l
i 3.4.4.2 Eglief Reouest RR 54. Examination Cateaccies B P. C-H. D A.
D B. and D C. Hydrostatic Testing _of Pioino Systems I Inch and less Nominal Pioe Size Code Reouirement: Section XI, Tables IWB , IWC , and IWD 2500 1 Examination Categories B-P, C-H, D A, D B, and D C all require systerr hydrostatic testing on all sizes of pressure retaining components.
Licensee's Code Relief Reouest: Relief is requested from performing system hydrostatic testing on (a) piping s 1-inch nominal pipe site (NPS) and (b) components and their connections in piping i 1-inch NPS.
Licensee's Proposed Alternative Examination: None. The Licensee states that system hydrostatic testir.g and the accompanying VT-2 visual examination will be performed on piping s 1-inch NPS and components and their connections in piping s 1-inch NPS which are unisolatable from larger diameter piping which require system hydrostatic testing.
Licensee's Basis for Reouestinn Relid: The Licensee states that specific system hydrostatic testing on piping s 1-inch NPS and components and their connections in piping 1 1-ir.ch NPS is impractical. Typically piping and components of this small diameter are used for sampling systems, reactor pressure vessel head vent systems, excess letdown systems, and for instrumentation applications. The systems mentioned are seldom operated and, as such, degradation is expected to be negligible. Piping and c.omponents used for instrumentation applications (i.e., pressure indicators, flow indicators) are subjected to essentially no-filow conditicns and, as such, failure mechanisms which cause degradation are minimal.
82
t
.e Evaluation: . The only Code-required examination for the subject
'small diameter (4 1-inch-NPS) pressure retaining components-is the system hydrostatic-test with a VT-2 visual- examination for leakage.- -Just because the Licensee feels the Code-requirement is unjustified is not sufficient for granting relief based on impracticality. Requiring the Licensee to perform the Code required hydrostatic test with a.VT-2 visual examination-for evidence of leakage would not result-in hardship.
Conclusions:
Based on-the above evaluation, it is concluded
'that'the Licensee has not demonstrated that the Code requirement is -impractical and, therefore, the subject small diameter (s-1-inch NPS) pressure retaining components should
-not be generically exempted from the Code-required hydrostatic testing requirements. Imposing-the Code-requirement would not result in undue hardship. Therefore. it is recommended-that relief be denied.-
1 83
. .c _ - - _ - _ . . _ - - - _ _ . . .
3.5 General 3.5.1 Vitrasonic Examination Techntaues 3.5.1.1 Relief Reouest RR-18. Use of %SME Code Section XI. Aooendix III for Ultrasonic Examination of Austenitic and Dissimilar Metal Pioina Welds
[.qdf,__Raaui rement : Section XI, Paragraph IWA-2232(c) requires the use of Section V, Article 5 for the ultrasonic examination of non-ferritic piping.
Liceneee's__ Code Relief Recuest: Relief is requested from the requirement of Paragraph IWA-2232(c).
Licensee's Prooosed Alternative Examinatipp: Ultrasonic examination of austenitic and dissimilar itttal piping welds will be performed using the requirements of ASMC Code Section XI, Appendix III.
Licensee's Basis for Reauestina Relief: ASME Code Section XI, Appendix III, Supplement 7 provides more appropriate guidance for ultrasonic examination of austenitic and dissimilar metal piping welds.
Evaluation: Review has been completed on the Licers e's submittal and also on the Licensee's response to NRC Question 250.4 with regard to the use of Appendix III as modified by Supplement 7. The Licensee has stated that, when the examination can be conducted from only one side of the weld, other angles may be used to ensure adequate examination-of the weld and adjacent base material on both sides of the weld. Also, any crack-like indicat en, regardless of amplitude, will be investigated m recorded by a Level II 84
or III examiner to accurately identify and locate the indication. All recordable indications are to be evaluated and disposition 9d by Level II or 111 personnel to the extent practical in order to determine the nature of the indication.
Conclusions:
Based on the above, it is concluded that Appendix !!! of Section XI is an acceptable alternative because it is technically acceptable and is also referenced in 10 CFR 50,55a(b). Therefore, it is recommended that relief be granted as requested.
I l
y*
I
~
i 85 l-
3.5.2 Exemoted Components (Noreliefrequests) 3.5.3 Other 3.5.3.1 Relief Re2.uest RR-38. Subsection IWE. Recuirements for Class MC Components Code Recuirement: Section XI, Table IWE-2500-1, delineates examination requirements for Class MC components.
Licensee's Code Relief Recuest: Relief is requested from performing the Code required examinations as outlined in Table IWE 2500-1.
Licensee's Pronosed Alternative Exanination: None.
Licensee's-Basis for Recuestina Relief: The Licensee states
-that the Federal Register, Volume 48, No. 28, Honday, February 7,1983, Page 5532, relative to 10 CFR 50 Codes and Standards for Nuclear Power Plants, Item No. 4 indicateo that Subsection IWE, " Requirements for Class MC Components of Light Water Cooled Power Plhnts," wa; added to Section XI of the ASME Code by the Winter 1981 Addenda. However, 10 CFR 50.55a presently only incorporates those portions of Section XI that address the-ISI requirements for Class 1, 2, and 3 components and their supports. The regulations.do not currently address the ISI of containments. Since this amendment is only intended to update current regulatory requirements to include the latest Code addenda, the requirements of Subsection lWE are not imposed upon Licensees by the NRC as a result of this- ,
amendment.
Evaluation: 10 CFR 50.55a requires compliance with Section XI of the ASME Code, which included Subsection !WE. Federal 1
1
' 86 i
Register, Volume 48, No. 28, Monday, February 7, 1983, Page 5532 indicates that Subsection IWE is not required since this subsection is, at the current time, under evaluation.
==
Conclusions:==
Based on the above review, it is concluded that relief is not required.
87
3.5.3.2 Relief Reauest RR 43. Visual Examination (VT-4) of Snubbers Code Reauirement: Section XI, Article IWF-5000 outlines the inservice test requircments for hydraulic and mechanical type snubbers. Personnel performing these tests are to be qualified to both VT-3 and VT-4 visual examination requirements.
Licensee's Code Relief Reauest: Relief is requested from using Article IWF-5000 and qualified VT-4 visual examination personnel.
Licensee's Procosed Alternative Examination: The Licensee proposes performing the subject testing of snubbers per the Plant Technical Specifications.
Licensee's Basis for Reauestina Relief: Instead of using Article IWF-5000, the testing of snubbers per the Plant Technical Specifications will be performed. This testing program is designed to demonstrate the functional integrity of the snubbers. The Licensee states that this program is, at least, equivalent to the requirements of Article IWF-5000. The functional testing of the snubbers will be performed by personnel trained in the proper use of-the test apparatus using approved procedures. In addition, the required VT-3 examination will be-performed using qualified personnel.
Evaluation: ASME Code Section XI requires an additional 10%
sample if a snubber fails. The Licensee's Technical Specification requires that additional samples are based on the number of failures within a snubber type and in no case less than one-half of the initial sample size. Therefore, generic component support failures which would be found under examinations as required by Subsection IWF should also be found under the sampling plan proposed by tha Licensee.
l 88 l
Conclusioni: Based on the above evaluation, it is concluded that the Licensee's proposed alternative for the selection and examination of supports to be examined provides En acceptable level of quality and safety as it meets exceeds the Code requirements. Therefore, it is recommenn' .' that relief be granted as requested.
89
- 4. CONCLUSION Pursuant to 10 CFR 50.55a(g)(6), it has been determined that certain Section XI requf red inservice examinations are impractical to perform. In all cases except Requests for Relief RR-45, RR 47. RR-48, and RR-54, the Licensee has either withdrawn a request for relief (RR-13 and RR 33) or demonstrated that specific Section XI requirements are impractical.
Conditional relief should be granted for Rcquests for Relief RR-27. RR-35, RR-36, RR-37, RR-46, and RR-50 provided that the Licensee meets the conditions / additional requirements defined in the relief request evaluations and conclusions in Section 3 of this report. Relief is not required for Requests for Relief RR-9, RR-38, and RR-41 as the Licensee is meeting the Regulations and Code requirements. In the cases of Requests for Relief RR-45, RR-47, RR-48, and RR-54, it is concluded that: (a) the Licensee has not provided information to support the determination that the Code requirement is impractical and (b) requiring the Licensee to comply with the Code requirement would not result in hardship.
This technical evaluation report has not identified any practical method by which the Licensee can meet all the pecific inservice inspection requirements of Section XI of the ASME Code for the existing Vogtle Electric Generating Plant, Unit 1, facility. Requiring compliance with all the exact Section XI required inspections would require redesign of a significant number of plant systems, sufficient replacement components to be obtained, installation of the now components, and a baseline examination of these components. Even after the redesign efforts, complete compliance with the
-Section XI examination requirements probably could not be achieved.
-Therefore, it is concluded that the public interest is not served by imposing certain provisions of Section XI of the ASME Code that have been determined to be impractical. Pu-suant to 10 CFR 50.55a(g)(6), relief is allowed from these requirements which are impractical to implement if granting the relief will not endanger life or property or the common defense anJ security and is otherwise in the public interest giving due consideration to the burden upon the Licensee that could result if the requirements were imposed on the facility.
90
The development of new or improved examination techniques-should continue to be monitored. As improvements in these areas are achieved, the Licensee should incorporate these techniques in the ISI program plan examination requirements.
Based on the review of the Vogtle Electric Generating Plant, Unit 1, First 10-Year Interval Inservice Inspection Program, through Revision 3, the-Vogtle Electric Generating Plant, Unit 1, First 10-Year Interval ISI Plan, Revision 0, the Licensce's responses to the NRC's request for additional information,- and the recommendations for1 granting relief from the ISI examination requirements that have been determined to be impractical, it has been concluded that the Vogtle Electric Generating Plant, Unit 1, First 10 Year Interval utservice Inspection Program and Plan, with the exception of Requests for Relief RR-45, RR-47, RR-48, and RR-54, are acceptable and in compliance with 10 CFR 50.55a(g)(4).
91
- 5. REFERENCES
- 1. Code of Federal Regulations, Volume 10, Part 50.
- 2. American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Division 1:
1983 Edition through Summer 1933 Addenda 1974 Edition through Summer 1975 Addenda
- 3. Vogtle Electric Generating Plant, Unit 1 First 10 Year Interval Inservice Inspection Program, Revisien 0, submitted November 24, 1986.
- 4. NUREG 0800, Standard Review Plcns, Section 5.2.4, " Reactor Coolant Boundary inservice Inspection snd Testing," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components," July 1981.
- 5. Letter, datea August 14, 1987, M. A. Miller (NRC) to J. P. O'Reilly
-(Georgia-Power Company (GPC)], " Request for Addit'onal Information on the First 10-Year Interval Inservice Inspection Program Plan."
- 6. Letter, dated October 21, 1987, L. T. Gucwa (GPC) to Document Control Desk (NRC), Response to Request for Additional Information on the First 10-Year Interval Inservice Inspection Program Plan.
- 7. Vogtle Electric Generating Plant, Unit 1, first 10-Year Interval
_ Inservice Inspection Plan (10-volume set), Revision 0, dated June 11, 1987. ,
- 8. Letter, dated July 18, 1988, W. G. Hairston, III (GPC) to Document Control Desk _(NRC), containing Revisions 1 and 2 to Vogtle Electric Generating Plant, Unit 1, First 10-Year Interval inservice Inspection Program.
- 9. Letter, dated May 10, 1989, W. G Hairston, III (GPC) to Document Control Desk (NRC), containing. Revision 3 to Vogtle Electric Generating Plant, Unit 1, First 16 Year Interval inservice Inspection Program.
92
- 10. NUREG-ll37, Supplement 4, Safety Evaluation Report Related to the Operation of Vogtle Electric Generating Plant, Unit 1, dated Jecember 1986.
- 11. I.etter, dated November 2, 1987, L. T. Gucwa (GPC) to Document Control Desk (NRC), forwarding panes inadvertently omitted from October 21, 1987 submittal of inservice inspection plan.
- 12. Regulatory Guide 1.150, " Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations." Revision 1, dated February 1983.
- 13. Regulatory Guide 1.14, Reactor Coolant Pump Flywheel Integrity,"
Revision 1, dated August 1985,
- 14. Letter, dated February 9, 1987, J. A. Bailey (GPC) to Document Control Desk (NRC), Nuclear Service Cooling Water Systems.
- 15. Letter, dated May 8,1985, V. L. Brownlee (NRC) to R. J. Kelly (GPC),
forwarding NRC Inspection Report Nos. 50-424/85-18 and 50-425/85-18 regarding GPC demonstration of ultrasonic examination procedures and equipment on centrifugally cast stainless st*-el.
- 16. Letter, dated July 1, 1985, V.'L. Brownlee (NRC) to R. J. Kelly (GPC),
forwarding NRC Inspection Report Nos. 50-424/85-25 and 50-425/85-25 regarding (in part) PSI examination procedures.
93
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EE d BIBLIOGRAPHIC DATA SHEET
<s +,,vr e s e ,,o .w,.,
2.tiraisos # '" EGG-MS-7783-cTechnical Fvaluation Report on-the' First 10-Year-Interval Inservice Inspection Program Plan: a cata ntecat aus-so iGeorgia Power Company, -e o..
October- j 1989 Vogtle Electric Generating Plant, Unit-1, ;
Docket Number 50 424 4 m oa caa~t wveia FIN-06022 (Proj. 5)
% AWTMQatsi 6 TYPE of atPonT Technical B.W. Brown, J.D. Mudlin t riaico coviaio u .~ c.c...
o~ ., . . u.a m. .- , . ,-
i ngag gayzatio . w s a~ o c on a ss yn.c. - ..
EG&G Idaho, Inc.
P.-0. Box 1625 Idaho Falls, ID 83415-2209 soni~o s, ..,, - -c o ow ., . . u s - .. - e-e &'.
s,o~.ef.af.889.cacasizaTion LJ . aus ano mocaiss o.uc. , ,
_ Materials and Chemical- Engineering Branch
. Office of Nuclear Reactor Regulation U.S. Nyclear Regulatory Commission Washington, D.C. 20555 10 $yPPLIMENTARY NOTE 5
- 11. ASSTa ACT tyco .r ees This report presents the results of the evaluation of the Vogtle Electric Generating Plant,. Unit _l, First 10-Year Interval -Inservice .Inspectinn (ISI) Program, through
~
Ravision 3, submitted May 10, 1989, and the Vogtle Electric Generating Plant,
. Unit 1, First '10-Year Interval ISI- Plan, Re,ision 0, submitted October 21, 1987.
The Progra, includes the requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section-XI requirements which the 1.icensee has determined to be impractical. The Vogtle Electric Generating Plant, Unit 1,rFirst 10-Year Interval ISI Program and Plan are evaluated in Section 2 of' this report. The ISI Program.and Plan.are evaluated for (a) compliance with:the appropriate _ edition / addenda of Section XI, (b) acceptability of examination sample,
-(c) correctness of the application of: system or' component examination exclusion
- criteria, and,(d) compliance with ISI-related commitments identified during the Nuclear Regula~ ,ry Commission (NRC) review before granting.an operating license.
The requests for. relief from the ASME Code-requirements which the Licensee.has-L . determined to be impra:tical for the first 10-year inspection interval are; evaluated in Section 3 of.this report.
1 w n o a os c a sc a :,r oa s . , - .,,,, . ,.
- - - ...,, , . . ,,. , o . ..v..un u.nwa Un1imited
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, fAss #.p.i Unclassified
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Unclassified a w ueta v **cas 16 791CE NaC 8C*W D$ 4249'
Vogtle Electric Generating Plant, Unit l' Page 1 of 18 TABLE 1
SUMMARY
OF RELIEF REQUESTS Relief Licensee Relief Request System or Exam. Item Volume or Area Required Proposed Request Number Component Cat. No. to be Examined Method Alternative Status Shell-to-Flange Weld: Volumetric RR-1 Reactor B-A Bl.30 Hone Withdrawn by Pressure 11201-V6-001-WO3 (volumetric 10/2/91 letter Vessel examination to maximum extent practical)
RR-2 Reactor B-A B1.11 Circumferential Shell Volumetric None Granted Pressure Weld: (volumetric Note (1)
Vessel II201-V6-061-WO6 examination to maximum extent practical)
RR-3 Reactor B-A B1.12 Longitudinal Shell Welds: Volumetric Hone Granted Pressure ll201-VG-001-W18, W19, (voluretric Note (1)
Vessel and W20 examination to maximum extent practical)
RR-4 Reactor B-A Bl.22 Heridienal Head Welds: Volumetric Hone Granted Pressure ll201-V6-001-W21, W22, (volumetric Note (1)
Vessel W23 and t 4 examination to maximum extent practical)
RR-5 Reactor B-A Bl.21 Circumferential llead Volumetric '% ne Granted Pressure Weld: (vslumetric Note (1) ni Vessel ll201-V6 001-WO7 examination to M maximum extent Es practical) E T4 w
k Vogtle Electric Generating Plant, Unit 1 Page 2 of 18 TABLE I
SUMMARY
OF REllEF REQUESTS Relief Licensee Relief Request System or Exam. Item Volume or Area Required Proposed Request Number Component Cat, No. to be Examined Method Alterna tive Status RR-6 Reactor B-G-1 B6.40 Flange L:3 ament Areas Volumetric None Granted Pressure (volumetric Note (1)
Vessel examination to maximum extent practical)
RR-7 Reactor B-A Bl.21 Circumferential Clr are Volumetric Hone Granted Pressure llead Weld: (volumetric Note (1)
Vessel 11201-V6-001-W01 examination to B1.40 Closure Head-to-Flange Volumetric maximum extent Weld: and practical and ll201-V6-001-WO2 Surface 100% surface if required)
RR-8 Class 1 B-J 89.11 RPV Safe-end Welds: Volumetric None Granted Piping 11201-009-9 and (100% surface Note (1)
Welds 11201-010-7 Surface examination and 11201-011-8 volumetric 11201-012-9 examination to maximum extent practical)
RR-9 Reactor B-G-1 86.30 RPV Closure Studs Volumetric Ultrasonic Relief not Pressure and shear-wave required Vessel Surface examination per (when Code Case N-307 removed)
RR-10 Pressurizer B-li B8.20 Sepport Skirt 'i'Id: Surface None (surface Granted ll201-V6-002-W35 examination to Note (1) maximum extent practical)
Vogtle Electric Generating Plant, Unit 1 Page 3 of 18 TABLE 1
SUMMARY
OF RELIEF REQUESTS Relief Licensee Relief Request System or Exam. Item Volume or Area' Required Proposed Request Number Component C a t _. _ _ No. to be Examined _. Method Alternative' Status RR-ll Reactor F-B F2.30~ RPV Supports: VT-3 None Granted Pressure ll201-V6-001-RS1, -RS2, Visual Note (1)
Vessel -RS3, and -RS4 RR-12 Pressurizer B-B B2.ll Circumferential Volumetric Hone (surfaca Granted Shell-to-liead Welds: examination of Note (1) llt'J.-V6-002-W01, -WOS nozzle-to-safe end welds and B-D B3.110 Head-to-Nozzle Welds: Volumetric head-to-nozzle ll201-V6-002-W10. -Wil, welds and
-W12, -W13, and -W14 volumetric examination to B-F BS.40 Nozzle-to-Safe End Welds: Voluwetric maximum extent Il201-V6-002-W17, -W18, and practical)
-W19, and -W20 Surface RR-13 Pressurizer Ultrasonic calibration Withdrawn blocks for the in 10/21/87 Nozzle-to-Safe cnd welds submittal RR-14 Pressurizer B-D B3.110 Surge Nozzle-to-Vessel Volumetric Surface and Granted weld: Volumetric Note (1)
Il201-V6-002-W16 examination to maximum extent practical RR-15 Pressurizer B-D B3.120 Surge Nozzle inner radius Volumetric Hone Granted section: Note (1)
Il201-V6-002-IR06
Vogtle Electric Generating Plant, Unit'l Page 4 of 18 TABLE 1
SUMMARY
OF RELIEF RE00ESTS Relief Licensee Relief Request System or Exam. Item Volume or trea Required Proposed Request Number. Component Cat. No. to be Ex,ained Method Alternative _ Status RR-16 Pressurizer B-fl B8.20 Support Brackets: Surface None Granted Il201-V6-002-W23 through Note (1)
-W30 (eight welds)
RR-17 Steam B-J 89.11 Nozzle-to-Elbow Welds: Surface None (100% Granted Generator 11201-001-5 11201-002-5 and surface Note (1)
Class I 11201-003-5 11201-004-6 Volumetric examination and Piping 11201-005-1 11201-006-1 volumetric 11201-007-1 11201-008-1 examination to maximum extent practical)
RR-18 Piping All anstenitic and Volumetric Volumetric Granted Welds dissimilar metal piping exams per exams per Note (2)
(general) welds Section V, Section XI, Article 5 Appendix III RR-19 Steam B-B B2.40 Channel llead-to-Tube Volumetric Hone Granted Generator Sheet Welds: (volumetric Note (1) ll201-B6-001-WO8 examination to 11201-B6-002-WO8 maximum extent il201-B6-003-WOB practical)
II201-86-004-WO8 RR-20 Class 1 B-J 89.11 Class 1 Piping Welds: Surface No. g100% Granted Piping 11201-049-3 and surface Note (1) 11201-059-11 Volumetric examination and volumetric examination to maximum extent practical)
Vcgtle Electric Generating Plant, Unit 1 Page 5 of 18 TABLE 1
SUMMARY
OF RFLIEF REQUESTS Relief licensee Relief Request System or Exam. Item Volume or Area Required Proposed Request Number Component Cat. No, to be Examined Method Alternative Status RR-21 Class 1 B-J 89.31 Branch Connection Piping Surface None (100% Granted Piping Welds: and surface Note (1) 11201-001-2 11201-002-2 Volumetric examination and 11201-003-2 11201-004-2 volumetric 11201-004-3 11201-009-4 examination to 11201-009-6 11201-0:0-4 maximum extent 11201-011-5 11201-012-4 practical) 11201-012-6 PR-22 Class 1 Pressure Retainine Cast Surface 100% surface Granted Piping Stainless Steel (brade SA and examination and Note (1) 351-CF8A) Welds in the Volumetric a refracted Reactor Coolant System longitudinal wave ultrasonic examination RR-23 Class 1 Ultrasonic Calibration Material Use 29-inch Granted Pip *ng Block for Reactor Coolant of same calibration Note (1)
System Pressure Retaining diameter block for 27.5 Cast Stainless Steel and wall through 31-inch (Grade SA 351-CF8A) Welds thickness piping rLiging in size from 27.5 to 31-inch 10 and wall thickness from 2.32 to 2.62 inches RR-24 Class 1 B-J 89.11 RC Pump Hozzle-to Surface None (100% Granted Piping -Elbow / Pipe Welds: and surface Except telus 11201-005-8 11201-006-8 Volumetric t amination and 11201-005-8 5 11201-007-8 11201-008-8 volumetric 11201-009-1 11201-009-1 11201-010-1 examination to which have been 11201-011-1 11201-012-1 maximum extent wi thdrawn by practical) 10/2/91 letter
I Vogtle Electric Generating Plant, Unit 1 Page 6 of 18 TABLE 1 l
SUMMARY
OF RELIEF REQUESTS gq I
! Relief Licensee Relief Request System or Exam. Item Volume or Area Required Proposed Request
_ Number Component Cat, No, to be Exanined Method Alternative Status RR-25 Class 1 Ultrasonic Calibration Volumetric Volumetric Granted Piping Block for RC Pump examination Note (1)
Nozzle-to-Pipe Welds: will be 11201-009-1 11201-010-1 performed using 11201-011-1 17201-012-1 existing calibration block without weld overlay RR-26 Class 1 B-J 89.11 Welds: Surface None (100% Granted Piping 11204-124-1 11204-124-7 and surface Note (1) 11204-124-8 11204-124-11 Volumetric examination and 11204-124-12 11204-124-15 volumetric 11204-124-16 11204-125-1 examination to 11204-125-7 11204-125-8 maximum extent 11204-125-15 11204-125-16 practical) 11204-126-1 11204-126-7 11204-126-8 11204-126-15 11204-126-16 11204-127-1 11204-127-7 11204-127-8 11204-127-19 11204-127-20 Class 2 C-F C5.21 Welds:
Piping 11204-120-6 11204-121-6 11204-122-6 11204-123-6
Vogtle Electric Generating Plant, Unit 1 Page 7 of 18 TABLE 1 SUW W' 0F REllEF REUVESTS Relief Licensee Relief.
Request System or Exam. Item Volume or Area Required Proposed Request Number Component Cat. No. to be Examined Method t.lternative Status RR-27 Class 1 B-t-2 B12.20 Internal Surfaces of VT-3 None (VT-3 exam Granted Pumps and B-M-2 812.50 Class 1 Pumps and Valves Visual if disassembled Note (1)
Valves as applicable for maintenance)
RR-28 Steam C-B C2.22 Outlet Nozzle inside Volumetric None Granted Generator radius section: Note (1) ll201-BS-001-lR03 RR-29 Steam C-A Cl.10 Shell Circumferential Volumetric None Granted Generators Weld: ll201-86-003-WO5 (volumetric Note (1) examination to '
01.30 Tubesheet-to-Shell Neld: maximum extent ll201-B6-004-WO7 practical and 100% surface C-B C2.21 Nozzle-to-Shell Welds: Surface examination of Il201-86-001-W18 and C-B welds) ll201-86-002-W19 Volumetric ll201-B6-004-W26
- ~
Vogtle Electric Generating Plant, finit 1 '
Page 8 of~18 . .
TABLE 1
SUMMARY
OF RE8.IEF REQUESTS L
Relief' Licensee Relief f I
- Request System or . Exam. Item . Volume or Area- . Required Proposed - Request .;
Numoer Component __ Cat. No. to be Examined Method _ Alternative Status ;
i RR-30 -Class 2 C-A 01.10 Letdown Reheat HX Weld: Volumetric. None (all .
Granted !
Vessels ll208-E6-007-WO3 . Code-required Note (1)
' Pulsation Dampener Weld: examinatians ll208-V4-002-W01 will be :
performed to j C1.20 Excess Letdown HX Weld: the maximum i ll208-E6-002-W01. extent Letdown HX Weld: practical) ll208-E6-003-WO3 Boron Inj. Tank Weldst-Il204-V6-001-WO2 1 il204-V6-001-WO3 1 I
Cl.30 Regenerative HX Welds:
Il208-E6-001-WOI ll208-E6-001-WO2 !
Il208-E6-001-WO9 ll208-E6-001-W10 -t C-B C2.21 Boron Inj. Tank Nozzle: Surface i 1
Il204-V6-001-W01 and ;
ll204-V6-001-WO4 Volumetric C-O ' C6,10 Safety Inj. Pump Casing Surface l Weld: 11204-P6-003-WO2 RR-31 Class 2 C-A ll205-E6-002 (RHR HX) Volumetric . Volumetric Granted Thin-wall 11208-E6-003 (LHX) exams per exams per Note (2)'.
Vessel 11208-E6-007 (LR11X) Section V, Section XI, i Welds- 11208-E6-002 (Ell 1X) Article 5 Appendix III ,
, 11208-E6-001 (RilX) ll208-V4-001 (SD) i
-i
1 Vogtle Electric Generating Plant, Unit 1 Page 9 of 18 TABt.E 1 EUMMARY Of RELIEF REQUESTS Licensee Relief Relief ReqJired Proposed Request Request System or Exam. Item Volume ar Area
_ Method Alternative Status Number Component Cat. No. ____ b be fd sdatd _ l 4
Volumetric t, None Granted l RR-32 RilR Heat C-B C2.22 Inside Radius Sections: Note (1)
Exchanger 11205-EG-002-IR01 Surface Nozzles 11205-E6-002-IR02 11205-E6-002-WO9,W10,W11 and W12 Withdrawn SI Ptmp C-D Casing studs RR-33 in 10/21/87 submittal Surface None (100% Granted Class 2 C-f C5.21 Welds:
RR-34 11301-001-5 11301-001-6 and surface Note (1)
Piping Volumetric examination and 11301-001-8 113C1-002-5 11301-002-6 11301-002-8 volumetric 11301-002-9 11301-002-10 examination to 11301-003-5 11301-003-6 maximum extent practical) 11301-003-8 11301-004-5 11301-004-6 11301-004-8 11301-108-14 Surface 100% Surface Granted RR-35 Class 2 C-F Augmented Examinations of -provided thin-walled and and and Axial scan Piping in Volumetric using 60-degree proper Engineered small-diameter piping 1/4-inch dia. calibration Safety welds in ES systems {7.5% of the wolds transducer with blocks are Systems modificd wedge obtained in each ES system) Note (1)
. . . _ . . .m 7
Vogtle Electric Generating l Plant," Unit I-
' Page 10 of :18 q TABLE I.
SUMMARY
OF REllEF REQUESTS R Relief Licensee Relief Request System or- Exam. Iter' Volume or Area Required- Proposed Request Number Component: Cat. _.No. to be Examined Method Alternative -Status
-RR-36 Class 2 C-F _ Augmented Examinations of . Surface None (100%. Granted.
liping P in 'the following thin-walled and surface -provided.
Engineered piping welds (greater Volumetric examination and proper. ,
Safety 'than 4-inch nominal pipe (7.5% of volumetric . calibration Systems size) in the.ES systems the welds examination to blocks are (89 total): in each ES maximu= 6: tent obtained-system) practical). Note (1) 11202-001-1 11202-001-17 11202-140-9 Il202-14n-27 11202-141-19
' 11202-188-4 11202 188-5 :11202-189-1 11202-189-2 11202-189 ' 11202-189-7. '11202-192 16 11202-196-7 11202-197-3 11202-202-18
- 11202-202-22 11202-204-1 11202-204-15 11202-205-1 11202-205-14 11202-207-14 11202-209-4 11202-209-5 11202-211-1 11202-211-3 11202-211 11202-212-15 11202-212-19 11202-212-36 11202-216-41 11202-216-42 11202-218-1 11202-218-20 11202-220-2 11202-220-12 11202-225 11202-229-12 '11202-229-13 11206-003-1 11206-004-4
- 11206-004-17 11206-005-1 11206-005-55 11?06-006 11206-006-51 11206-007-1 11206-007-10 11206-008-1 11206-008-10 11206-008-16 11204-001-9' 11204-006-1 11204-006-64 11204-006-72 11204-007-1i 11204-008-33 11204-011-C 11204-012-2 11204-038-1 ti204-038-8
- 11204-123-5 11204-177-13 11204-192-1 11205-003-62 11205-003-64 11205 004-54 11205-005-1 11205-005-32 11205-006-1 11205-006-2 11205-006-3 11205-006-20 11205-006-27 11205-007-1 11205-007-23 11205-007-77 11205-098-1 11205-009-1 11205-009-24 11205-039-3 11208-137-1 11208-137-8 11208-137-15 11208-139-4 11208-139-8 11208-139-30 11208-139-35 11208-411-2 11208-411-51 4 . ~ _ ._ - _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ . .
Vogtle' Electric Generating Plant, Unit 1
- Page 11 of 18 TABLE I
SUMMARY
OF RELIEF RE00ESTS Relief Licensee Relief Request System or Exam. Item Volume or Area Required Proposed Request Number Component Cat. No. to be fxamined Method Alternative Status RR-37 Class 2 C-F Augmented Examinations of Surface None (100% Granted Piping in the following and surface -provided Engineen'ed small-diameter piping Volumetric examination and proper.
Safety welds (46 total) in the (7.5% of volumetric calibration Systems ES systems: the welds examination to blocks are in each ES maximum extent obtained.
system) practical)
Note (1) 11204-014-13 11204-014-20 11204-014-26 11204-014-54 11204-015-13 11204-028-1 11204-037-56 11204-063-54 11204-169-1 '
11204-169-45 11204-197-8 11208-003-2 11208-003-4 11208-003-6 11208-003-17 11208-003-21 11208-003-30 11208-003-33 !
11208-003-49 11208-003-57 11208-022-2 11208-022-5 11208-022-6 11208-022-7 11208-022-22 11208-023-36 11208-023-43 i 11208-023-55 11208-023-56 11208-023-59 11208-023-76 11208-044 11208-044-2 11208-044-4 11208-046-2 11208-046-3 11208-046-4 11208-099-4 11208-101-6 11208-123-55 11208-146-5 11208-146-17 11208-147-2 11208-147-3 11208-147-5 11208-147-8
Vogtle Electric Generating Plant, Unit 1 Page 12 of 18 1ABLE 1 .
SUMMARY
Of Rftiff REQUESTS Licensee Relief Relief Required Proposed Request Request System or Exam. Item Volume or Area to be Examined Method Alternative Status Number Component Cat. No.
As outlined in IWE-2500-1 Exams None Relief not RR-38 class HC outlined required Components i in Table IWE-2500-1 l
l Near surface gating Volumetric None Granted l RR-39 Reactor B-A B1.11 Note (1) l Pressure B1.12 prevents examination of (volumetric Bl.21 .350-inch or less of the examination to l Vessel maximum extent Bl.22 following welds; l
Bl.30 practical) ll201-V6-001-WO3, -WO4,
-WO6, -WO7, -W12, -W13,
-W14 -W21, -W22 -W23, and -W24 2-inch 1 3/4-inch Granted RR-40 Reactor Ultrasonic Calibration notch lengths Note (2)
Blocks: notch Pressure lengths Vessel ISI-D-400A, -401A, -402A, and -403A
W -
Vogtle Electric Generating Plant Unit 1 Page 13 of 18 TABLE 1
SUMMARY
Of REtiff RIO!RSTS Licensee Relief Relief Volume or Area Required Proposed Request Request System or Exam. Item Status Component Cat. No. to be Examined Method Alternative Number Basic UT Calibration Surface 100% surface Relief not RR-41 Reactor and examination and required Coolant Blocks for RPV Nozzle-to-Safe End Welds: Volumetric mechanized UT System examination Piping Il201-V6-001-W33, -W34,
-W35, -W36, -W37, -W38, from I.D. using
-W39, and -W40 composite calibration block in co.ijunction with cast piping calibration block Volumetric None (inside Granted RR 42 Steam B-D B3.140 Inside Radius Sections: radii wil' be Note (1)
Generator ll201-86-001-IR-01, -02 ll201-86-002-IR-01, -02 visually Nozzles examined to ll201-B6-003-IR-01, -02 11201-86-004-IR-01, -02 maximum extent practical)
VT-3 Perform subject Granted RR-43 Snubbers IWF Hydraulic and mechanical Note (2)
VT-4 testing of type snubbers Visual snubbers per the Plant Technical Specifications
, x -
l Vogtle Electric Generating Plant, Unit 1 j Page 14 of 18
' - TABLE I
SUMMARY
OF REllEF Rf00ESTS Licensee Relief Relief Volume or Area Required Proposed Request Request System or Exam. Item Alternative Status l to ha Examined Method
! Number Component Cat. No, Class 2 components which Hydrostatic Hydrostatic Granted Class 2 C-H RR-44 cannot be isolated from test per test at Class 1 Note (1)
Components IWA-5000 test pressures Class I components and per IWA-5000 IWC-5000 and IW8-5000 Line No. Check Valve {s) Shutoff Valves 1208-023 1208-U4-006 1208-U4-005 1208-042 1208-U4-359 1208-U4-356 ,
1208-044 1208-U4-360 1208-U4-357 1208-046 1208-U4-361 1208-04-358 1208-488 1208-06-037 IIV-8147 1208-008 1208-U6-035 HV-8146 & 1208-U4-498 1204-063 1204-U6-013 liv-880iA&8 1204-082 1204-U6-013 HV-8843 1204-058 1204-06-013 liv-1204-U4-007 1204-016 1204-04-120 llV-8802A & HV-8881 1204-197 1204-U4-121 HV-8802A & ilV-8881 1204-020 1204-06-128 HV-8840 & HV-8825 l
1204-201 1204-06-129 liv-8840 & liv-8825 l
1204-017 1204-U4-123 HV-88028 & HV-8824 1204-199 1204-04-122 IIV-88028 & ilV-8824 1204-029 1204-U4-146 HV-8835 & HV-8823 1204-030 1204-U4-145 ilV-8835 & HV-8823 1204-031 1204-U4-144 ilV-8835 & ilV-8823 1204-032 1204-04-143 HV-8835 & HV-8823 1204-039 1204-06-147 HV-8809A 1204-U6-148 IIV-8890A 1204-041 1204-U6-149 11V-88098 1204-06-150 HV-8890B
Vogtle Electric denerating Plant, Unit 1 Page 15 of 18 TABLE I
SUMMARY
OF PEllEF REQUESTS Relief Licensee . Relief Request System or Exam. Item Volume or Area Required Proposed Request Number Component Cat. No. to be Examined Method Alternative Status RR-45 Class 2 C-li C7.30 Class 2 containment Hydrostatic Pressure tests- Withdrawn by Components C7.40 penetrations which are and System as required by 4/26/90 letter C7.70 not required for Pressure Appendix J of C7.80 operation to support Tests 10 CfR 50 engineered safety systems t RR-46 Class 2 C-il C7.10 System pressure test of VT-2 VT-2 performed Granted-Components C7.30 Class 2 components Visual at pressures provided C7.50 during which meet or hold time, C7.70 system exceed the test functional requirements of pressures, or system IWC-5221 during and inservice conditions frequency testing other than of exam system meet or functional or exceed Code system requirements inservice Note (2) testing ;
RR-47 Systems C-H C7.10 System functional or VT- None Withdrawn by containing C7.30 system inservice testing Vis-c: 4/26/90 letter air during C7.70 of the containment during system D-A D1.10 hydrogen monitor and system operation D-B D2.10 radiation monitor systems functional or system ,
inservice testing
Vogtle Electric Generating Plant, Unit i Page 16 of 18 IABLE I
SUMMARY
Of RELIEF REQUESTS Licensee Relief Relief Required Proposed Request Request System or Exam. Item Volume or Area Cat. No. to be Examined Method Alternative _ Status Number Cnmoonent D-A Cl.10 System inservice test for VT-2 VT-2 Visual Withdrawn by RR-48 Class 3 Visual during system 4/26/90 letter Systems in the following CVC lines:
during functional test support of system reactor inservice shutdown test Line 1208-242 from 1208-P6-006 to 1208-F6-003 Line 1208-243 from 1208-P6-007 to line 1208-242 Line 1208-213 from line 1208-242 to 1208-14-003
& valve 273 Line 1208-131 from 1208-F6-003 to valve HV-8104
& line 1208-134 Line 1208-134 from line 1208-131 to valve 188, line 1208-118
& valve fiV-8439 Line 1208-118 from line 1208-134 to valve 174 Line 1208-116 from line 1208-134 to valves FV-OlllB
& FV-01108 Line 1208-127 from line 1208-116 to valve 171 Line 1208-450 from line 1208-131 to line 1208-213 Nuclear Service Cooling Hydrostatic None (VT-2 Granted RR-49 Class 3 0-A D1.10 Note (1)
Water Pumps and Transfer test and Visual Vertical 1-1202-P4-001, VT-2 examination Pit Pumps Pumps:
-002, -003, -004, -005, Visual will be
-006, -007, and -008 examination performed on during portions of system pumps not inservice submerged in test the NSCW tower basin)
I Vogtle Electric Generating Plant, Unit I j Page 17 of 18 1ABLE 1
SUMMARY
Of RELIEF Rf00ESTS Licensee Relief Relief Volume or Area Required Proposed Request Request System or Exam. Item Alternative Status No. to be Examined Method Number Comnonent, Cat.
VT-2 VT-2 performed Granted RR-50 Class 3 0-A D1.10 Pressure tests of Class 3 -provided l
D-C D3.10 pressure retaining Visual at pressures Pressure exam which meet or hold times Retaining systems and during exceed the Code Systems system requirements frequency inservice during of inspections I
test conditions other than as well as system pressures VT-2 functional or meet or D-B D2.10 Pressure tests of Class 3 system exceed Code pressure retaining Visual exam inservice tests requirements systems Note '2) during system functional tests l
functional test of the VT-2 VT-2 Visual Withdrawn by RR-51 Class 3 D-B D2.10 exam per 10/2/91 letter following Class 3 lines: Visual Pressure exam per IWD-5221 Retaining IWD-5222 Systems
( Line 1217-267 from valve 084 to if ne 1217-071 Line 1217-268 from valve 085 to line 1217-072 Line 1217-266 from valve 086 to line 1217-073 Line 1217-265 from valve 087 to line 1217-150 l
Line 1217-073 from line 1217-266 to line 1217-150 Line 1217-071 from line 1217-267 to line 1217-150 Line 1217-072 from line 1217-268 to line 1217-150 l'ne 1217-150 from valve llV-2041 to lines 1217-071, 1217-022, 1217-073, & 1217-265
Vogtle Electric Generating Plant, Unit 1 Page 18 of 18 TABLE I
SUMMARY
OF RELIEF REQUESTS Licensee Relief Relief Required Proposed Request Request System or Exam. Item Volume or Area Number _ Component Cat. No, to be Examined Method Alternative Status 88.10 RPV Integrally Welded Surface None (surface Granted RR-52 Reactor B-H examination to Note (1)
Pressure Attachments:
ll201-V6-001-W204 m.ximum extent Vessel practical) ll201-V6-001-W205 ll201-V6-001-W206 Spent Fuel Cooling and VT-2 None Granted RR-53 Class 3 D-C B3.10 Piping Purification System welds Visual Note (1) i submerged or encased in during j Welds concrete pressure i testing Class 1, 2, B-P Piping, components, and Hydrostatic None Withdrawn by RR-54 4/26/90 ietter and 3 C-H their connections in Test Pressure D-A piping $ l-inch NPS Retaining D-B isolatable from lar- r Components D-C diameter piping RR-55 Intentionally Blank RR-56 Intentionally Blank Notes: 1. Relief s granted pursuant to 10 CFR av. coat g)(6)(i)
- 2. Reliefs granted pursuant to 10 CFR 50.55a(a)(3)(i)
_ _ _ _ _ _ -