ML20133J220

Forwards Fee Inadvertently Omitted from Encl Util 851014 Request for Relief from Certain Requirements of ASME Code,Section XI

ML20133J220
Person / Time
Site:	Farley
Issue date:	10/15/1985
From:	ALABAMA POWER CO.
To:	NRC
References
NUDOCS 8510180334
Download: ML20133J220 (1)

Text

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.' Afabama Power Company

', 600 North 18th Street ',

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Post Office Box 2641 U Q-i- Birm6ngham, Alabame 35291 Tetephone 205 250-1000

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!. AlabamaPower i  !

i October 15, 1985 "

i CHECK: $150 i

PURPOSE: Application Fee i

SUBJECT:

Joseph M. Farley Nuclear Plant - Units 1 and 2 Inservice Inspection Program for ASME Code Class 1, 2 and 3

Components

ATTACHMENT T0

Letter from R. P. Mcdonald, Alabama Power Company, dated ,

October 14, 1985 (Dockets No. 50-348 and 50-364)  ;

The enclosed check was inadvertently left out of the contents previously sent with the above referenced letter (copy enclosed).

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, Bmmgnarn. A:atama 35291 Te er*.0*e 205 783-6090 R P. Mcdonald Se9 c Ere FrE5'CeY h 5' M' : e B ";

Alahama POWCf Docket Nos. 50-348 50-364 October 14, 1985 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Consission Washington, D.C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2 Inservice Inspection Program for ASME Code Class 1, 2 and 3 Components Gentlemen:

Alabama Power Company has reviewed the remaining inservice inspection activities requiring completion by the end of the first ten year interval for Farley Nuclear Plant Units 1 and 2. Based on this review, it has been determined that three additional reliefs are needed where the ASME Code required examinations are impractical to perform. One relief request was previously granted, however, Alabama Power Company has subsequently determined that a portion of the alternative examination is impractical.

The remaining relief requests were not identified at the time of the previous submittels.

The ASME Code,Section XI requires that a volumetric examination of eaci. reactor vessel flange ligament between the threaded stud holes (58 total) be performed during each ten year inspection interval. To facilitate safe removal and reinstallation of the reactor vessel head and positioning of the remote reactor vessel examination tool, three guide studs are installed in stud hole Numbers 26, 42 and 58. During the ultrasonic examination performed by the remote tool, the guide studs prevent the ultrasonic transducers mounted on the remote tool are from accessing the ligaments around each guide stud as well as the ligaments between the stud holes on either side of the guide studs (Numbers 1, 25, 27, 41, 43 and 57). To date, 66% of the ligaments have been cxamined on both units and no recordable indications have been found. Since the ligaments are located in the flange base material and are not in the most highly stressed region of the flange, the probability of any service buW W

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Director, Nuclear Reactor Regulation October 14, 1985 1 U. S. Nuclear Regulatory Commission Page 2

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5 induced indications occurring in this area is minimal. Therefore, relief i is requested to exempt ligament Numbers 1, 25, 26, 27, '+1, 42, 43, 57 and

' 58 from the volumetric examination requirements of the ASME Code. The remaining 49 ligaments will be examined as required by the ASME Code. A j summary of the relief request is included as Attachment 1.

, For one reactor coolant pump (RCP) per unit,Section XI of the ASME i

Code requires that volumetric examination of the pressure retaining casing welds and visual examination of the casing interior pressure retaining

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i surfaces be performed once each ten year interval of operation. The RCP casings for Farley Nuclear Plant Units 1 and 2 are one piece casings and therefore do not contain pressure retaining welds. Since the pump does not

, require disassembly for volumetric weld examination, the disassembly of a 4

RCP solely for the purpose of visually examining the interior surface is impractical. The pump manufacturer (Westinghouse) neither recommends nor requires pump disassembly for the performance of routine maintenance or inspections. If the RCP internals are removed, they would require complete 4

' disassembly because a gasket internal to the pump would need replacement as i

a result of relaxing the main flange bolts. It has been estimated that complete RCP disassembly and reassembly could require up to 15 days of

critical path outage time to complete since the radiation exposure, which is estimated at 50 man-rem, may limit access to and mobility in the containment fcr routine refueling outage activities. An activity of this i

complexity, performed under adverse field conditions, could potentially result in handling damage which could degrade the RCP. In the absence of the need for volumetric weld examination and considering the hardship imposed by pump disassembly and potential for RCP degradation, the visual examination of the internal pressure boundary is not justified. The exterior of the RCP casing will be visually examined during the RCS hydrostatic pressure test required by IWB-5000. A visual examination, not to exceed once per interval, will be performed on the internal pressure boundary surface of one RCP if maintenance or operational problems are encountered which require the removal and disassembly of the internals. A summary of the relief request is included in Attachment 2.

I Previous NRC Safety Evaluations for each unit granted relief to perform the ASME Code required volumetric and surface examinations of the RCP main flange bolts, studs, nuts, bushings, threads and ligaments when a

the bolting is removed for RCP maintenance or when the pump is disassembled

! for the visual examination of the casing interior pressure retaining

, surfaces. Alabama Power Company is requesting relief from the visual examination of the RCP casing interior as stated previously, and pending

granting of this relief, does not intend to disassemble a RCP. The main flange bolting for all three Unit 1 RCPs and two Unit 2 RCPs has been 4

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Director, Nuclear Reactor Regulation October 14, 1985 U. S. Nuclear Regulatory Commission Page 3 volumetrically and visually examined in place as requirod by the ASME Code j and no recordable indications have been found. If mair,tenance or operational problems are encountered which require the removal of the main flange bolts and disassemaly of the RCP internals, the bolts, nuts,

' bushings, threads and ligaments between the bolts for one pump (per inspection interval) will receive the volumetric and surface examinations in accordance with the ASME Code while the bolts are removed. The revised relief request incorporating the proposed change is included as Attachment 3.

Pursuant to the requirements of 10CFR50.55a(g)(6)(1), Alabama Power 4

i Company herewith requests that relief be granted from certain requirements of the ASME Code,Section XI, 1974 Edition through the Summer 1975 Addenda. It is respectfully requested that these relief requests be granted by December 31, 1985. The ISI activities required to be performed at the Unit 1 seventh refueling outage include these impractical inspections. The planning for this outage is expected to be completed by late 1985, and the granting of these reliefs will influence the development of the critical path schedule.

This relief request is designated as a required approval in accordance with S150.00, 10CFR170.21 requirements. Enclosed is the required application fee of i

Yours truly, s

/ 1, ,

i V. -L R. P. Mcdonald RPM / STB:drs/D-363 l

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Attachments i

cc/Att: Mr. L. B. Long Mr. S. A. Varga  !

Mr. E. A. Reeves Mr. W. H. Bradford '

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I ATTACHMENT 1 RELIEF REQUEST - RELIEF IS REQUESTED FROM THE VOLUMETRIC EXAMINATION OF REACTOR VESSEL FLANGE LIGAMENT NUMBERS 1, 25, 26, 27, 41, 42

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43, 57 AND $8 (ITEM Bl.9, CATEGORY B-G-1)

EXAMINATION REQUIREMENT:

', Table IWB-2600, Item Bl.9 and Table IWB-2500, Category B-G-1 require volumetric examination of 100% of the ligaments between the threaded stud holes of the reactor vessel flange during each inspection interval.

BASIS FOR RELIEF:

I 3 To reduce the critical path outage time required to perform reactor l i vessel examinations and reduce the exposure of examination personnel, '

j reactor vessel volumetric examinations, including examination of the

, ligaments between the threaded stud holes, are performed utilizing a remote ultrasonie examination tool. For the purpose of safely removing and reinstalling the reactor vessel head, and positioning the i remote examination tool, three guide studs are placed in the reactor  :

vessel flange at stud hole Numbers 26, 42, and 58. During the ,

examination, these guide studs prevent the ultrasonic transducers mounted on the remote tool arm from accessing the ligaments around each guide stud as well as the liganents between the stud holes on either side of the guide studs (Numbers 1, 25, 27, 41, 43 and 57).

i ALTERNATIVE EXAMINATION:

The remaining 49 ligaments will be ultrasonically examined as required [

by the ASMI Code,Section XI.

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.i j ATTACHMENT 2 L i

RELIEF REQUEST - RELIEF IS REQUESTED FROM THE VISUAL EXAMINATION OF THE REACTOR COOLANT PUMP CASING INTERNAL PRESSURE BOUNDARY l i SURFACES (ITEM B5.7, CATEGORY B-L-2)

EXAMINATION REQUIREMENT:

Table IWB-2600, Item B5.7 and Table IWB-2500, Category B-L-2 require l visual examination of the internal pressure boundary surfaces of one reactor coolant pump during each inspection interval.

BASIS FOR RELIEF:

3 The ASME Code,Section XI permits the visual inspection of the reactor coolant pump (RCP) internal pressure boundary surfaces to be performed  ;

' on the same pump disassembled for the purpose of performing the t

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required volumetric examination of the pressure retaining casing i t

welds. The RCP casings for Farley Nuclear Plant are one piece casings and therefore do not contain pressure retaining velds. Since the pump  ;

does not require disassembly for volumetric weld examination, the  ;

i disassembly of a RCP solely for the purpose of visually examining the '

i interior surface is impractical. The pump manufacturer (Westinghouse) <

neither recommends nor requires pump disassembly for the performance of routine maintenance or inspections. If the RCP internals are ,

removed, they would require complete disassembly because a gasket i i internal to the pump would need replacement as a result of relaxing e i

the main flange bolts. It has been estimated that complete RCP disassembly and reassembly could require up to 15 days of critical t

path outage time to complete since the radiation exposure, which is [

i estimated at 50 man-rem, may limit access to and mobility in the l containment for routine refueling outage activities. An activity of '

this complexity, performed under adverse field conditions, could I potentially result in handling damage which could degrade the RCP. In the absence of the need for volumetric weld examination and considering the hardship imposed by pump disassembly and potential for RCP degradation, the visual examination of the internal pressure boundary surface is not justified. e ALTERNATIVE EXAMINATION:

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r The exterior of the RCP casing will be visually examined during the }

4 RCS hydrostatic pressure test required by IWB-5000. A visual  :

examination, not to exceed once per interval, will be performed on the internal pressure boundary surface of one RCP as required by Item {

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B5.7, Category B-L-2 if maintenance or operational problems are j encountered which require the removal and disassembly of the {

internals.

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ATTACHMENT 3 RELIEF REQUEST - RELIEF IS REQUESTED FROM REMOVAL OF THE REACTOR  !

} COOLANT PUMP MAIN FLANGE BOLTS FOR VOLUMETRIC AND SURFACE l

EXAMINATIONS (ITEM B5.2, CATEGORY B-G-1) i l EXAMINATION REQUIREMENT:

During each inspection interval, Table IWB-2600, Item B5.2 and Table IWB-2500, Category B-G-1 require the performance of volumetric and

{ surface examinations on 100% of the reactor coolant pump (RCP) main flange bolts, studs, nuts, threads, bushings and ligaments, when the bolting is removed.

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{ BASIS FOR RELIEF: I 1

2 Removal of the main flange bolts for examination would require the removal and complete disassembly of the RCP internals, because a

! gasket internal to the pump would need replacement as a result of relaxing the main flange bolts. The pump manufacturer (Westinghouse)

' neither recommends nor requires pump disassembly for the parformance  ;

of routine maintenance or inspections. The RCP casings for Farley Nuclear Plant are one piece casings and therefore do not contain pressure retaining welds which require volumetric examination

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accordance with the ASME Code,Section XI. Relief has been rei nsted

! f rom the ASME Code required visual examination of the RCP internal

pressure boundary surfaces, to eliminate the need for RCP disassembly. The basis for this relief, which is also applicable to the removal of the main flange bolts, is that the high level of

, radiation exposure, additional critical path outage time required to j

disassemble the pump and potential damage and degradation to the RCP, solely for the purpose of performing ISI, is not justified. '

f ALTERNATIVE EXAMINATION:

l- The RCP main flange bolting will be volumetrically and visually '

i examined in place in accordance with the ASME Code,Section II, Items i

i B5.1 and.35.3, Category B-G-1. Not to exceed once per interval, the main flange bolts, nuts, bushings, threads and ligaments of each pump will be examined when the bolting is removed as required by Item B5.2,

! Category B-G-1, if maintenance or operational problems are encountered

} which require the removal and disassembly of the RCP internals.

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