ML20099M484

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Requests Clarification of Jr Miller 840406 Response to 830707 Request for Exemptions Re Class 1,2 & 3 Weld Exams, Per ASME Code Section XI on Inservice Insp & Testing Program in Final SER
ML20099M484
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 03/12/1985
From: Andrews R
OMAHA PUBLIC POWER DISTRICT
To: John Miller
Office of Nuclear Reactor Regulation
References
LIC-85-055, LIC-85-55, NUDOCS 8503250257
Download: ML20099M484 (2)


Text

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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 402/536-4000 March 12, 1985 LIC-85-055 Mr. James R. Miller, Chief Office of Nuclear Reactor Regulation Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555

References:

(1) Docket No. 50-285 (2) Letter OPPD (W. C. Jones) to NRC (J. R. Miller) dated July 7, 1983 (LIC-83-161)

(~). Letter OPPD (W. C. Jones) to NRC (J. R. Miller) dated September 26, 1983 (LIC-83-226)

(4) Letter OPPD (W. C. Jones) to NRC (J. R. Miller) dated March 19, 1984 (LIC-84-052)

(5) Letter NRC (J. R. Miller) to OPPD (W. C. Jones) dated April 6, 1984

Dear Mr. Miller:

Inservice Inspection and Testing Program Relief from ASME Boiler and Pressure Vessel Code,Section XI In Reference (2), the Omaha Public Power District sent a preliminary list of exemption requests to the NRC with regard to the Class 1, 2 and 3 weld exam-inations required to be perfonned at the Fort Calhoun Station to satisfy the ASME Section XI requirements. References (3) and (4) amended and finalized these exemption requests.

In References (2), (3), and (4) the relief request to item B3.10 of Table IWB-2500-1 of Section XI has remained the same, viz.:

B 3.10 The nozzle-to-vessel welds cannot be 100f, volumetrically examined since the nozzle supports present an interference to currently available equipnent. The nozzle-to-vessel welds will be examined during the reactor vessel examination. This examination will be fran the inside, in the NRC "Staf f Evaluation" (fran Reference (5)) of this exemption request, the following statement was made:

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Mr. James R. Miller, Chief LIC-85-055 Page Two The NRC staff has detemined that the volume accessible for exam-ination from the nozzle-to-vessel external surface in addition to the volume examined from the nozzle-to-vessel internal surface will cover a sufficient amount of the volume required to be exam-ined to provide a high degree of assurance that inservice flaws either do not exist, or will be detected in the vessel-to-nozzle weld and base netal .

Please note the words "in addition to" in the above evaluation. During the

< District's 1983 refueling outage, an examination of the nozzle-to-vessel welds was perfomed from the inner diameter of the nozzle just as stated in our exemption request. Our ISI vendor, in their final report, indicated no difficulty in achieving 100% weld volume coverage from the inner diameter.

The District wishes to clarify that using the standard 0*, 45*, 60*, and 70*

ultrasonic scans from the inner diameter,100% of the code-required weld volume can be scanned.

Therefore, if the examination is deferred to the end of the 10-year interval, 100% of the code-required weld volume can be examined. Unlike the Code fol-lowed for the first ten-year interval, the 1980 edition of the Code allows deferral of the examination until the end of the interval. Further, the 1980 edition of the Code allows for either internal or external examination.

Thus, the District does not believe an outer diameter examination, as pre-scribed in Reference 5 is required, and, based upon the 1980 edition of the Code, an exemption is no longer required either.

l We respectfully request that this matter be clarified when you issue the final SER for the remaining ASME Boiler and Pressure Vessel Code exemption requests for the interval 1983-1993.

Sincerely, Aw R. L. Andrews Division Manager Nuclear Production RLA/DJM/rh-M cc: LeBeetsf, Lamb, Leiby and MacRae

. 1333 New Hampshire Avenue, N.W.

Washington, DC 20036 Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, NRC Resident Inspector i

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