ML20087J887

Requests Relief from Hydrostatic Testing of Feedwater Reducers During Current Refueling Outage.Reducers Replaced After Ultrasonic Exams Found Cracks in Weld Areas. Radiographic & Visual Exams Performed Per IE Bulletin 79-13

ML20087J887
Person / Time
Site:	Farley
Issue date:	03/19/1984
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
IEB-79-13, TAC-49547, TAC-54471, NUDOCS 8403230134
Download: ML20087J887 (4)

Text

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Milling Addr'xs

. Alabama Power Company

. ,600 North 18th Street

. Post Othee Box 2641

' i Birrningham, Alabama 35291 Telephone 2C5 783-6081 F. L Clayton, Jr.

Senior Vice President ennitiose Buiidins AlabamaPower thesouthern e!cctnc sys:em March 19, 1984

, Docket No. 50-348 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Unit 1 Hydrostatic Testing Relief Request _

Gentlemen:

During recent ultrasonic examinations of the feedwater reducers, cracks were found in some of the weld areas. Alabama Power Company has elected to replace the reducers. As discussed with the NRC Staff, this replacement may not constitute the final resolution to the Farley feedwater nozzle cracking concern but does provide an acceptable solution which can be implemented in the current refueling time frame.

The materials and the procedures used in this replacement were qualified in accordance with Section XI of the ASME Code. The Code specifies a hydrostatic test which poses a hardship on Alabama Power Company and could lengthen the current refueling outage. Alabama Power Company is, therefore, requesting relief from hydrostatically testing these reducers. This request has been discussed with members of the Materials Engineering Branch. It is Alabama Power Company's understanding that the NRC Staff concurs with the bases of this request.

Radiographic and visual examinations of the Steam Generator Feedwater System at Farley Nuclear Plant Unit 1 were completed on July 12, 1979 in accordance with the requirements of IE Bulletin 79-13. All welds and pipe to nozzle areas were found to be acceptable and no unacceptable indications were found. This completed the activities required by IE Bulletin 79-13. During the current Unit 1 Fifth Refueling Outage, Alabama Power Company inspected the steam generator feedwater nozzles by ultrasonic examination and discovered cracking in the reducer (16" x 14") heat affected zone of the nozzle to reducer weld areas. This examination, which is included in the Farley

. Nuclear Plant ASME Section XI Inservice Inspection ~(ISI) Program, was not required to be performed during the current refueling outage.but s i

'was performed on the basis.of good engineering practice , Q ddi 84o323o13,a,o33, gDRADOCK 05000348 PDR

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Mr. S. A. Varga March 19, 1984 il U. S. Nuclear Regulatory Commission Page 2 Alabama Power Company is replacing the feedwater nozzle reducers for all three steam generators utilizing materials which meet the requirements of the ASME Section XI Code. These materials will be welded utilizing procedures, qualified to the Code, heat treated por the Code and be nondestructively examined per the Code. In accordante with

, the provisions of the ASME Code, a hydrostatic test of the replacement reducers is required at 1.25 times design pressure prior to placing the feedwater system into operation. The conduct of this hyrostatic test j poses a hardship and is unnecessary at this time for the reasons described below.

The three steam generator feedwater systems are scheduled for 1 hyrostatic testing during one of the next two refueling outages as part

i. of the previously established Inservice Inspection (ISI) program. Plans and procedures are not in place at this time to conduct these tests during the current refueling outage and a delay in return to power would most likely result from an attempt to conduct these tests without adequate pre-planning. In addition, the ASME Code would not consider two of the three steam generator hydrostatic tests as meeting the code schedular requirements, thereby precipitating additional subsequent i hydrostatic testing. Multiple hydrostatic testing needlessly challenges the integrity of piping, equipment and valves. In addition, it is noted that the Westinghouse Steam Generator Technical Hanual allows for only five such tests during the life of the steam generator. To date, two tests have been performed.

The hydrostatic tests, when prformed, would only detect the presence of leakage in the feedwater lines and would provide no indication of improper weld repair. Alabama Power Company, in lieu of 1 the design pressure hydrostatic test, will perform a visual examination 4 at service pressure and will perform an ultrasonic examination and a radiograph of the weld regions prior to return to power. These radiographic and ultrasonic examinations are more predictive of future failure than a hydrostatic test and will provide adequate assurance of system integrity. Alabama Power Company will volumetrically examine these weld regions at the next refueling outage.

After return to power from the current outage, Alabama Power .

Company will make a determination of the final resolution to t.he concern of feedwater nozzle cracking. A final resolution may include use of thermal sleeves, preheating of auxiliary feedwater or the use of a separate auxiliary feedwater nozzle on each steam generator. - Alabama Power Company will apprise the NRC of its determination of the final resolution prior to the next refueling outage.for Unit 1 (scheduled to t

commence in April 1985).

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Mr. S. A. Varga March 19, 1984 U. S. Nuclear Regulatory Commission Page 3 In accordance with 10CFR50.55a(g)(6)(1), Alabama Power Company hereby requests that relief be granted from certain requirements of the 1974 Edition through the Summer 1975 Addenda of the ASME Code,Section XI, Articles IWA-5000 and IWD-4210. A summary of the proposed relief request, existing examination requirements, bases for the relief request and proposed alternative examinations is attached.

Alabama Power Company's Plant Operations Review Committee has reviewed the proposed relief request. It is requested that this relief be granted by March 26, 1984 to preclude extension of the current refueling outage critical path. While the detailed planning for the hydrostatic test has not been completed, it is currently estimated that the outage duration will be extended approximately two days.

This relief request is designated as Class III in accordance with 10CFR170.22 requirements. Enclosed is a check for $4000.00 to cover the total amount of fees required.

If you have any questions, please advise.

Yours very truly

. a FLCJ r/ JAR:drs-029 Attachment cc: Mr. R. A. Thomas ,

Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford

Attachment COMPONENT CODE CLASS: 2 Steam Generator Feedwater Lines EXAMINATION REQUIREMENT:

IWA-4210 requires that a pressure test be performed in accordance with IWA-5000 following repairs made by welding on the pressure retaining boundary components.

BASIS FOR RELIEF:

Repairs are in progress to three feedwater lines on Farley Unit 1 during the current refueling outage.

Hydrostatic pressure testing of the feedwater lines would include the steam generators since the new welds cannot be isolated from the generator secondary side. There are only five hydrostatic test cycles allowed by steam generator design. Two test cycles were conducted as part of initial plant startup leaving three remaining test cycles for the remaining life of the plant. Alabaaia Power Comparty does not believe a post repair hydrostatic pressure test is necessary to confirm the integrity of the new welds. Therefore, relief is requested from this requirement.

ALTERNATIVE EXAMINATION:

As an alternative, a visual examination will be perfonned at operating pressure for the new feedwater system welds.

In addition, extensive non-destructive examinations will be conducted on each new weld including radiographic examinations on the root pass and  ;

intermediate welds and ASME Code radiographic examination and ultrasonic (new baseline) examination of each completed new weld.

It is our position that the above examinations are sufficient to  ;

demonstrate the integrity of the new feedwater system welds.

D-29 l

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