ML20151K395

Technical Evaluation Rept,2nd Interval Inservice Insp Program,Big Rock Point Nuclear Power Plant

ML20151K395
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/07/1984
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20151K400	List: ML20151K395 ML20198A944 ML20198A962
References
CON-NRC-03-82-096, CON-NRC-3-82-96 SAI-84-1652, NUDOCS 8410100501
Download: ML20151K395 (65)

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SAI-84/1652 TECHNICAL EVALUATION REPORT 2nd INTERVAL INSERVICE INSPECTION PROGRAM BIG ROCK POINT NUCLEAR POWER PLANT I

Submitted to:

U.S. Nuclear Regulatory Commission Contract No. 03-82-096

D

. Science Applications, Inc.

McLean, Virginia 22102

.1 August 7, 1984 ,

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CONTENTS

. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 I. CLASS 1 COMPONENTS . . . . . . . . . . . . . . . . . . . . . . . . . 4 A. Reactor Vessel . . . . . . . . . . . . . . . . . . . . . . . . . 4

1. Relief Requests RR-Al and RR-A2, Shell Welds; Circumferential and Longitudinal in Core Region and Longitudinal Above Beltline Circumferential Weld, Category B-A, Items Bl.11 and Bl.12 ......... 4

2. Relief Request RR-A3, Vessel Bottom Head, Circumferential and Meridional Welds,

', Category B-A, Items Bl.21 and Bl.22 ............ 8

3. Relief Requests, RR-A4, A7, A9, All, Primary Nozzle-to- .

Vessel Welds, Nozzle Inside Radius Sections and Nozzle-to-Safe End Welds, Category B-D, Items 53.90 and B3.100, and Ca tegory B-F, Item B5.10 . . . . . . . . . . . . 10

4. Relief Request RR-A6, A8, A12, A13, A42, 3-Inch Reactor Vessel Nozzles, Category B-D, Items B3.90 and ,

B3.100 and Category B-F, Item B5.10 ............ 12 1

5. Relief Request RR-A10, Primary Nozzle-to-Safe End Welds on Six Steam Outlet Nozzles, Category B-F, Item B5.10 . . . . . . . . . . . . . . . . . . .-. . . . . . 14

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6. Relief Requests, Reactor Vessel Integrally Welded

D Attachments, Category B-H, Item B8.10; RR-A14 Suspension Rod Brackets; RR-A15 Vessel Hanger Lugs; RR-A16 Stabilizer Brackets .................... 16

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B. Pressurizer (not applicable to BWRs) i; C. -Heat Exchangers and'0ther Pressure Vessels . . . . . . . . . . . 18

1. Steam Drum Relief Requests: RR-A20, Shell Welds, -

Category B-B, items B2.51 and B2.52;

RR-A21, Nozzle-to-Shell Welds, Category B-D, '

l Items B3.150 and B3.160; RR-A29. Integrally Welded 1 i Supports, Category B-H, Item B8.40 . . . . . . . . . . . . . 18 1

2. Relief Request RR-A22, Clean-up Regenerative Heat .

I Exchangers (RHX) Units.A, B, C, D, and Non-Regenerative Heat Exchanger (NRHX) Unit E Category B-D, Item B3.160 . . 21

3. Relief Request RR-A23, Clean-up Non-Regenerative Heat Exchanger (NRHX) Unit E Category B-D, Item B3.150 . . . . . 23

4. Relief Request RR-A24, Clean-up Demineralizer Tank Nozzles, Category B-D, Item B3.160 . . . . . . . . . . . . . 25 D. Piping Pressure Boundary . . . . . . . . . . . . . . . . . . . . 27

1. Relief Request RR-A30, Shutdown Cooling System Dissimilar Metal Fitting-to-Pipe Weld, Category B-F, Item B5.50 . . . . . . . . . . . . . . . . . . 27

2. Relief Request RR-A31, Dissimilar Metal Socket Welds, Category B-F, Item B5.50 . . . . . . . . . . . . . . 29

3. Relief Request RR-A32, Similar Metal Safe End-to-Pipe Welds; Category B-F, Item B5.50, or Category B-J, Items B9.11, B9.21, and 89.40 . . . . . . . . . . . . . . . 31

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4. Relief Request RR-A32, Similar Metal Pipe-to-Safe End Welds, Category B-J. Items B9.11, B9.21, and 89.40 . . . 33 .

5. Relief Request RR-A36 Integrally Welded Piping Attachments, Main Recirculation System, Category B-K-1 Item B10.10 . . . . . . . . . . . . . . . . 35

6. Relief Request RR-A37. Integrally Welded Piping AttacNnents, Reactor Depressurization System, Category B-K-1, Item B10.10 . . . . . . . . . . . . . . . . ~37

7. Relief Request RR-A38, Component Supports, Piping, Category B-K-2, Item B11.10 . . . . . . . . . . . . . . . . 39 E. Pump Pressure Boundary . . . . . . . . . . . . . . . . . . . . . 41

( 1. Relief Request RR-A39, Pump Casing Welds, Category B-L-1, Item B12.10 . . . . . . . . . . . . . . . . 41

2. Relief Request RR-A41, Pump Internal Surface Examination, Category B-L-2, Item B12.20 . . . . . . . . . . 44 s

F. Valve Pressure Boundary . . . . . . . . . . . . . . . . . . . . 46

1. Relief Requests RR-A40, RR-A43, and RR-A44, Class l' Valve Internal Examination, Category B-M-2, Item B12.40 . . 46 II. CLASS 2 COMPONENTS

1. Relief Request RR-B1, Class 2 Piping at Containment .

Penetrations, IWC-1210 . . . . . . . . . . . . . . . . . . . 49

2. Relief Request RR-B2, Classification of Class 2 Vent and Drain Lines Beyond Normally Closed Valves, IWC-1210 . . . . . . . . . . . . . . . . . . . . . . . . . . 51

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III. CLASS 3 COMPONENTS (no relief requests)

IV. PRESSURE TESTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 A. -General ............................. 53

1. Relief Request RR-D1, Substitution of System Hydrostatic Testing for System Pressure Tests, Categories B-P, C-H, D-A, D-B, D-C . . . . . . . . . . . . . . 53 B. Class 1 System Pressure Tests (no relief requests)

C. Class 2 System Pressure Tests (no relief requests)

D. Class 3 System Pressure Tests (no relief requests)

V. GENERAL ............................... 55

1. Volumetric Examination Methods, Class 1 and 2, Items B5.50, B9.12, B9.31 C5.21, and C5.22 ........... 55 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 ATTACHMENT: CONSUMERS POWER COMPANY CODE APPLICABILITY STATEMENT 1 AND STATEMENT 2 ....................... 59 N

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. 1 TECHNICAL EVALUATION REPORT 2nd INTERVAL INSERVICE INSPECTION PROGRAM i Big Rock Point Nuclear Power Plant INTRODUCTION This report evaluates requests for relief from certain examination and pressure test requirements of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code

• by the licensee, Consumers Power Company (CPC), of the Big Rock Point Nuclear Power Plant. The relief

. requests cover the second 120-month inspection interval starting January 1, k

1982. The requests are based upon the 1977 Edition of Section XI, with addenda through the Summer of 1978, as specified in the applicable revision of 10 CFR 50.55a. -

.) The rest of this introduction summarizes (a) the scope of this report, (b) the previous review of relief requests by Science Applications,-Inc. (SAI)(7) ,

and (c) the history of Big Rock Point since the earlier review (9-I4) .

The current revision to 10 CFR 50.55a requires that Inservice Inspection I (ISI) programs be updated each 120 months to meet the requirements of newer editions of Section XI. Specifically, each program is to meet the requirements (to the extent prac'tical) of the edition and addenda of the Code incorporated in the regulation by reference in paragraph (b) 12 months prior to the start of the current 120-month interval.

f The regulation recognizes that the requirements of the later editions and addenda of the Code might not be practical to implement at, facilities because

of limitations due to design, geometry, and materials of construction of com-ponents and systems. It therefore pennits exceptions to impractical examination or testing requirements to be evaluated. Relief from these requirements can be granted, provided the health and safety of the public are not endangered, giving due consideration to the burden placed on the licensee if the requirements were imposed. This report only evaluates requests for relief dealing with inservice examinations of components and with System pressure tests. Inservice test programs for' pumps and valves (IST programs) are being evaluated separately.

• Hereinafter referred to asSection XI or Code.

The current revision of the regulation also provides that ISI programs niay meet the requirements of subsequent Code editions and addenda, incorpor-ated by reference .in paragraph (b) and subject to Nuclear Regulatory Commission I (NRC). approval. Portions of such editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met.

These instances are addressed on a case-by-case basis in the body of this report.

Finally,Section XI of the Code provides for certain components and systems to be exempted from its requirements. In some instances, these exemp-tions are not acceptable to NRC or are only acceptable with restrictions. As appropriate, these instances are also discussed in this report.

In its previous report dated September 17, 1982, SAI(7) evaluated relief requests for Big-Rock Point covering the last 40 months of the 1st inspection, interval (April 1979 to January 1,1982)*. These requests were also based on 3

the 1977 Edition with addenda through Summer 1978. The applicable Code and interval were in accordance with the revision of 10 CFR 50.55a in effect at the time. Two relief requests were added to the 1st interval program after the program document (3) was issued. The relief requested in Reference (6) was I addressed in the SAI report.(7) The relief requested in Reference (9.) was ad-dressed by NRC in Reference (10). Hence, all 1st interval relief requests have been addressed.

p References (11) to (14) listed at the end of this report pertain to the

' 2nd ISI interval (January 1,1982, to January 1,1992). The present ISI pro-gram was issued December 19,1983.II2) By letter of April 13, 1984,(13) the NRC requested additional information to complete the review in this report.

The information was furnished as an attachment to the May 14, 1984 II4) letter.

),

All relief requests identified to date are contained in Reference (12) and one relief request was amended in Reference (14).

• January 1, 1982, is chronologically the end of Big Rock Point's second 10 years of operation. However, during their first 10-year interval, there were no requirements to perform ISI examinations. For ISI purposes, Big Rock Point's first inspection interval began on January 1,1972, based on the 1971 Code. The last period of the 1st interval was shortened to allow com-pletion of the previous period's inspections. That program resulted in the schedule shown above.

)

As a result of the'above submittals, nine requests for relief (RR-AS, A17, A18, A19, A25, A33, A34, A35, and C1) have been withdrawn. Also, three requests (RR-A26, A27, and A28) have been determined by the licensee not to be actual requests for relief from Code requirements. Therefore, from a total of 49 requests for relief for Big Rock Point's 2nd ISI interval, 37 were identified as requiring disposition. These requests are evaluated in the following sections of this report.

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i. I. CLASS 1 COMPONENTS A. Reactor Vessel

1. Requests for Relief, RR-Al and RR-A2: Shell Welds; Circumferential and Longitudinal in Core Region and Longitudinal Above Beltline Circumferential Weld, Category B-A,: Items Bl.11 and Bl.12 Code Requirement One circumferential and one longitudinal weld in the beltline region are to be volumetrically examined over essentially 1003 of i: th ofeir lengths each inspection interval. following the first interval operation.

Code Relief Request .

Relief is requested from the code requirement to volumetrically

? examine the shell welds in the core region and the portions of the lengths of longitudinal welds above the beltline circumferential weld that are inaccessible.

Proposed Alternative Examination

!' Each refueling outage, a hydrostatic test (prestartup hydro) is performed at 1.1 times the operating pressure.

Licensee's Basis for Requesting Relief O The reactor vessel is closely surrounded by concrete, so l- examination from the outside is not possible. The inner wall of the reactor vessel is inaccessible in the core region due to the-

l. presence of a thermal shield, which is immovable. Design clearance between the thermal shield and reactor vessel + mil is 1.65 inches.

The thermal shield extends 66.50 inches below 'the beltline circumferential weld. .

The surrounding concrete shield and plant design make external access to longitudinal and circumferential reactor vessel welds physically impossible.

The concrete shield surrounds (actually encloses) the reactor piping and varies in thickness from 6 to 10 feet where 4

piping penetrations are located. Removal of this concrete shield would be an enormous task in a high radiation area (500 to 1500 mr/hr). The concrete shield and exterior insulation on the reactor vessel would not permit surface or renote visual exami-nation of longitudinal and circumferential welds from outside the vessel.

.. The non-removable thermal shield and stainless cladding inside the vessel fully cover the lower longitudinal welds and

~c ircumferential welds and therefore cannot be seen via visual

-examination from inside the vessel. It is expected that about 30 to 50% of the longitudinal welds above the beltline circum-ferential welds (#749-1A and #749-1B on ISO-A1) will be accessible for volumetric examination ~. These welds have about 60% of their

-length obscured by internal components -(core spray sparger, baffle' plates, thermal shield top ring, and thermal shield).

The prestartup hydrostatic test is more conservative than the prestartup leak test at operating pressure required by the Code.(IWB-5221). Inspection of the six riser nozzles and vessel-to-flange weld will provide some indication of reactor vessel integrity, along with results of vessel coupon terting. During operation, a failure of any weld in the reactor vessel would be

- _readily detectable by level indication, dew cell indication,-

makeup water flow and/or temperature indication in adequate

-time for safe shutdown. ,

Evaluation LThe Big Rock Point reactor vessel was designed and constructed

.to the rules of ASME Code Sections I and VIII, Nuclear Code Cases 1270N, 1271N, and.1273N, and General Electric Company Specifications. The materials used in construction were SA-302, Grade B plate, and SA-336 forging material. In tenns of Charpy impact energy, these materials i are essentially equivalent to the SA-533, Grade B, Class 1, and SA-508, Class 2, which are currently being used. Additionally, the primary stresses in the beltline region of t 70%ofthoseallowedbySectionIIIoftheCode.gvesselareabout.-

The following information on the material s ,

isexcerptedfromtheSEPreactorvesselreport:geillanceprogram .

!- "The material surveillance program for Big Rock Point was planned prior to the initial issuance of Appendjx H,10 CFR Part 50.

The program is b4 sed on ASTM Recommended Practice E-185 dated 1964...."

c "The program consists of 12 capsules having tensile and Charpy

-specimens from base, HAZ, and weld materials. There are four wall capsules placed at the core midplane at positions where the core

-corners are closest to the vessel wall. These capsules are located

' close to the vessel wall where they will receive a fluence only L slightly higher than the vessel wall ID. Three capsules are located

-inside the' thermal shield at positions about 6 inches from the. flat faces of the core. These accelerated capsules will see a fluence from 20 to 50 times that on the vessel wall ID. The program also

. -includes five thermal control capsules located on top of the baffle ,

plate. These capsules are exposed to the temperature cycles of the vessel and to a neutron flux three or four decades' lower than the '

. vessel wall. The main purpose of. these specimens is to monitor any r - aging effect. experienced by vessel materials."

v .

"The Big Rock Point material surveillance program conforms to almost all the rules of Appendix H,10 CFR Part 50. Some of the capsules contain less than the required number of 12 Charpy specimens for each material type. However, the program contains more than the required number of capsules and total number of specimens.. Some capsules also contain only two tensile specimens instead of the required three. From our review of this program, it is concluded that it is very good and will provide sufficient data to monitor the radiation damage on the reactor vessel materials throughout their service life.

"To date, five capsules have been removed from the vessel.

Accelcrated capsules were removed in 1964 and in 1967. Wall cap-sules were removed in 1964 and 1968. One thermal control capsule was removed in 1968. . Tests on these surveillance specimens were conducted at the Naval Research Laboratory. 2The two wall capsules

. received fluences of 1.5 and 7.1 x 1018 n/cm The two accelerated

. capsules received fluences of 2.3x1019 and 1.07x1020 n/cm2 From -

thesetests,'weconcludethatweldmetalisthelimitingvegel 0

material. Its RT increases 135 F at a flu nce of 7.1x10 n/cm2 ;

and increases by b oF at a fluence of 2.3x10 9 n/cm2 . At the above fluence from about levels, theabout 90 to upper60 shelf energy ft-lbs. At a of the weld fluence metal dgreasesn/cm2, of 1.07x10 the upper shelf energy is still almost 60 ft-lbs. The shelf energy ofplatematepialalsodropstoabout60ft-lbsatafluenceof 2.3x1019 n/(m . These test results do not show any rate effect on the degree of radiation damage. Thus, the results of accel-erated capsules are considered to be comparable to those of the wall capsules."

' The SEP report also concluded, based on the low primary vessel

._ stresses and the use of materials with adequate fracture toughness, t

that assurance is provided that' brittle fracture will not occur.

I Imposition of the Code requirements would necessitate the licensee's removing portions of the concrete biological. shield and the permanently installed insulation to perform the required examination of the welds listed from the vessel, exterior. The L vessel internals, preclude volumetric examination of the belt 1ine weld volume from the vessel interior.

I Adhering to all Category B-A Code requirements for these welds is impractical due to existing plant design and geometry.

The volumetric examinations that will be performed on the upper longitudinal welds will give some knowledge of vessel integrity.

The recommendations of the SEP report should be followed, however, and where practical, the generic safety items described should be addressed. These recomendations include insuring (a) that the vessel-welds are examined to the maximum extent practical and.(b) that the most up-to-date examination methods and most experienced examiners are used to perform the examinations. Also, visual examination for gross leakage should be performed during each system pressure test as proposed by the licensee.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed above, the code requirements are impractical.

It is further concluded that the alternative examinations discussed above will provide necessary added assurance of structural reli-ability. In addition to the limited UT examinations to be attempted on the upper longitudinal shell welds, the following are recommended:

(a) Relief should be granted from the code-required volu-metric examinations on reactor vessel beltline welds.

(b) The licensee should follow the recommendations, where

', practical, of the SEP report.

(c) The proposed pressure testing and visual examinations .

for leakage should be performed per IWA-5000.

)

References References 2 and 12.

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. 2. Request for Relief RR-A3, Vessel Bottom Head, Circumferential and Me'ridional Welds, Category B-A, Items B1.21 and Bl.22 Code Requirement One circumferential and one meridional weld are to be '

volumetrically examined once during each inspection interval.

For each weld, the extent of examination includes the accessible portion up to 100s of weld length.

Code Relief Request Relief is requested from Code requirements to volumetrically examine the circumferential and meridional welds in the reactor

, vessel bottom head.

, Proposed Alternative Examination -

Consumers Power examined the accessible portions of weld (793-1) from 225 degrees to 315 degrees during the 1983 outage and will commit to reexamine this same segment during the next interval. Also, hydro test will be performed as identified in RR-A1.

Licensee's Basis for Requesting Relief No access or penetrations are available to afford access to the meridional welds (793-2A, B, C, D) and circumferential weld

. (794-48) in the reactor vessel bottom head. Access is prevented by a concrete shield wall and stainless steel blanket insulation which surrounds the vessel. The meridional welds are further obstructed by 32 3/4-inch CRD hydraulic lines and incore detector lines located just below the high-density aggregate trays. A recently fabricated access port in the aggregate trays below the reactor vessel provided extremely limited access to about 90 degrees of circumferential weld 793-1 (from 225 degrees'to 315 degrees).

It is considered'at this time that adequate access is not available to allow for external preparation and examination of these welds from the exterior and not feasible due to core support plate structures and stainless steel cladding for interior examination.

Evaluation The code specifies that the accessible lengths of one circum-ferential and one meridional head weld are to be volumetrically examined in this interval. All the bottom head welds, except about 90 degrees of one circumferential weld, are inaccessible for examination. The licensee will examine the accessible weld segment.

The code acknowledges that accessibility may be limited with respect to volumetric examination of head welds, but the intent of i

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the code is clearly .to encourage some volumetric examination of the welds. Accordingly, the licensee meets the code requirement for examining circumfer' ential bottom head welds. Because all the meridional welds are completely inaccessible, it would be approp-riate to grant relief from their examination.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the bottom head circumferential welds, relief is not needed. However, for the bottom head meridional welds, the Code requirements are impractical. It is further concluded that the proposed hydrostatic testing and other Code examinations will provide necessary added assurance of structural reliability. Therefore, the following are recommended:

(a) Relief should be granted from the code-required volumetric examination of bottom head meridional welds. -

' (b) The licensee should perform the code-required partial exami-nation of circumferential weld 793-1 as proposed. Relief from the circumferential head weld examination requirement would then not be needed.

(c) The proposed pressure testing and visual e.vaminations for leakage should be performed.

References i Reference 12.

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3. Requests for Relief, RR-A4, A7, A9, All, Primary Nozzle-to-Vessel Welds, Nozzle Inside Radius Sections and Nozzle-to-Safe End Welds, Category B-D, Items 83.90 and 83.100, and Category B-F, Item B5.10 Code Requirement Category B-D: The nozzle-to-vessel welds and nozzle inside radius sections are to be volumetrically examined once during each inspection interval.

Category B-F: All these dissimilar metal welds are to be l examined by volumetric and surface nondestructive examination (NDE) techniques each inspection interval.

Code Relief Requests Relief is requested from all examination of the following nozzles:

a. 20-in. recirc nozzles 796-1A and 796-1B (except accessible' i portions of nozzle-safe end (B-F) welds); RR-A4 and -A9.

b. 8-in. shutdown unloading nozzle 795-15; RR-A7 and -All.

Proposed Alternative Examination Visual examination of accessible surfaces for leakage during systei- pre:isure testing for all subject nozzles plus Code Category B-F volumetric examinations and exterior visual and surface exami-nations of accessible portions of the 20-inch recirculation nozzles.

I i Licensee's Basis for Requesting Relief

a. Approximately two-thirds of the exteriors and all of the interiors of the 20-inch recirculation nozzles are inac-cessible for volumetric examination due to interferences.

The concrete shield wall and high-density aggregate trays prevent full access to the two recirculation nozzles from the outside. Diffuser plates prevent volumetric inspection of the nozzles from the inside. Geometric configuration prevents meaningful volumetric examination of the Category B-D areas. During the inlet baffle repair in 1979, a visual inspection (remote) was completed or. these nozzles with no indications noted,

b. A direct manual volumetric examination is not possible on the 8-inch shutdown unloading nozzle due to inaccessibility of the nozzle. Interference with the core spray sparger prevents use of the mechanized ultrasonic device. During the baffle repair in 1979, this nozzle was visually (remote) inspected with no indications noted.

LE.

Evaluation The design of Big Rock Point is such that not much access was provided for ISI of components on and near the reactor vessel.

For this reason, attempting to gain acc ,s to and code examine every nozzle would be impractical in terms of personnel exposure, downtime, and cost. Because some of the above nozzles are known to have sggsitized safe ends, they are covered under SEP Topic V-4t l' 4 ' l. Examination of these nozzles should be in accordance with these references. Otherwise, the performance of the proposed alternative examinations should provide some information on the integrity of those nozzles not covered by Topic V-4.

Conclusions and Recommendations Based upon the above evaluation, it is concluded that for the nozzles discussed above, the Code requirements are. impractical.

It is further concluded that the alternative examinations discussed, will provide necessary added assurance of structural reliability.

Therefore, the following is recommended:

Relief should be granted from the Category B-D and B-F requirements for the subject nozzles as requested. Relief should be contingent on performing the SEP Topic V-4 and pro-posed alternative examinations as described above. In addition, remote visual examinations of accessible surfaces should be performed each interval.

Referen'ces P,eferences 1, 4, 8, and 12.

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' 4. Requests for Relief, RR-A6, A8, A12, A13, A42, 3-Inch Reactor Vessel Nozzles, Category B-D, Items B3.90 and B3.100, and Category B-F, Item B5.10 Code Requirements Category B-D: The nozzle-to-vessel welds and nozzle inside radius sections are to be volumetrically examined once during each inspection interval.

Category B-F: All these dissimilar metal welds are to be examined by volumetric and surface nondestructive examination (NDE) techniques each inspection interval. l Code Relief Requests

- Relief is requested from Code surface and volumetric exami-nations of the following 3-inch nozzles as described:

Nozzle Examination Area Relief Recuest No. -

A. 795-1A Nozzle-to-Vessel Weld RR-A8 Inside Radius Section RR-A42 Nozzle-to-Safe End RR-A13 B. 795-1B* Nozzle-to-vessel weld RR-A6 Inside Radius Section RR-A6 Nozzle-to-Safe End RR-A12 & -A13 C. 795-1C Inside Radius Section RR-A42 Nozzle-to-Safe End RR-A13

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D. 795-1D Inside Radius Section RR-A42 Nozzle-to-Safe End RR-A13 I

E. 795-1E Inside Radius Section RR-A42 Nozzle-to-Safe End RR-A13 F. 796-6 Nozzle-to-Vessel Weld RR-A6 Inside Radius Section RR-A6 Nozzle-to-Safe End TR-A12

• Previously identified as nozzle 795-6(3) ,

Proposed Alternative Examination Remote visual examinations of accessible internal surfaces and hydrostatic testing are proposed.

Licensee's-Basis for Requesting Relief Generally, access is limited on the outside by concrete walls, high density aggregate trays, and various system lines.

Access to the insides of these nozzles is limited by shield water interference, high radiation, thermal sleeves, and other vessel internals. The nozzle-to-vessel welds of three of these nozzles (795-IC, -10, and -1E) are accessible and will be examined.

The inside radii of four nozzles (795-1A, -1C. -10, and -1E) cannot be examined because materials are not available for calibra-tion block fabrication. During fabrication of the Big Rock reactor vessel 3-inch nozzles, a unique composition of 70% manganese and 30% nickel was used as a brazing foil. The brazing foil was wrapped around a stainless steel sleeve which was inserted into the nozzle.

The nozzle was -then heat treated to 22000F. This process is no

. longer used in nozzle fabrication. Efforts to obtain the brazing foil material have been futile. The nozzle fabrication process and material are required for calibration block fabrication. -

Evaluation See previous item (I.A.3). Attempting to gain access to and code-examine these nozzles would be impractical in terms of per-sonnel exposure, downtime, and cost. Also, the absence of adequate calibration blocks with the unique metallurgical configuration of the nozzles precludes meaningful UT examination of inside radii.

The proposed alternative examinations and other Code examinations on nozzles should provide some information on the nozzles' integrity.

Conclusions and Recommendations Based upon the above evaluation, it is concluded that for the nozzles discussed above, the Code requirements are impractical.

It is further concluded that the alternative egaminations discussed will provide nec,essary added assurance of structural reliability.

Therefore, the following is recommended: -

Relief should be granted from the Code requirements for the subject nozzles as listed above. Relief should be contingent on performing the Topic V-4 examinations described in the previous item (I.A.3) and the proposed alternative examinations described above.

References References 1, 4, 8, and 12.

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5. Request for Relief RR-A10, Primary Nozzle-to-Safe End Welds on Six Steam Outlet Nozzles, Category B-F, item B5.10 Code Requirement Nozzle-to-safe end dissimilar metal welds are to be examined by volumetric and surface nondestructive examination (NDE) tech-niques each inspection interval.

Code Relief Request Relief is requested from the code surface examinations on the 14-in. steam outlet nozzles, 795-11a to -11f.

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Proposed Alternative Examination

-Mechanized UT, visual VT-1, and system hydrostatic test.

Licensee's Basis for Requesting Relief These nozzles are inaccessible for surface examination from outside due to concrete walls which enclose these nozzles. During refueling, these nozzles are submerged in the shielding water, making dye penetrant or magnetic particle testing impossible.

(Total core unloading and 1 to 2 R/hr fields also make surface examination from inside the nozzles impossible.) A mechanized ultrasonic examination is performed underwater along with the prestartup hydrostatic test. These nozzles are also visually inspected, also underwater, per code requirements.

I Evaluation The external surfaces of the subject welds are inaccessible for surface NDE. The welds are to be volumetr.ically examined

according to code requirements. The code, however, only requires the inner one-third of the weld volume (CDEF on Figure IWB-2500-8) to be volumetrically examined. For these welds, the entire volume (ABDEFC on Figure IWB-2500-8) should be so examined. This alter-nate procedure should give an indication of the external surface condition of these welds. The welds will also be given internal VT-1 examinations and visually examined for leaks during system pressure testing. The code surface examinations in this case are impractical.

Conclusions and Recommendations Based on the above evaluation, it is. concluded that for the welds discussed above, the code required surface examinations are impractical. It is further concluded that the alternative exami-nations discussed above will provide necessary added assurance of structural reliability. Therefore, the following are recommended:

.(a) Relief should be granted from the code surface examinations on the subject welds, (b) The code volumetric examinations should be performed on these welds as scheduled. The examination volumes should be expanded, however, to include 100~ of each

' weld's volume. This volume corresponds to volume ABDEFC of Figure IWB-2500-8, (c) Internal visual VT-1 examinations should be performed

. a,long with the volumetric examinations above, .

(d) General visual examinations in the areas of the nozzles should be performed during system pressure tests for evidence of leakage per IWB-5000.

References Reference 12.

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6. -Requests for Relief, Reactor Vessel Integrally Welded Attachments, Category B-H, Item B8.10; RR-A14 Suspension Rod Brackets; RR-A15 Vessel Hanger Lugs; RR-A16 Stabilizer Brackets Code Requirement The volumetric or surface examination of attachment welds includes essentially 100" of the length of.the weld to vessel and the integral attachment weld to a cast'or forged integral attachment to the vessel, as applicable. Welds are to be examined each inspection interval.

Code Relief Request

.. Relief is requested from the code volumetric or surface

. examinations of the following integrally welded attachments:

(a) Suspension Rod Brackets (801-1A through lil) -

(b)- Vessel Hanger Lugs (801-2A through 2D)

(c) Stabilizer Brackets (801-3A through 3D).

Proposed Alternative Examination For welds in which defects would affect the integrity of the reactor- vessel boundary, the"prestartup hydrostatic test serves as an alternative inspection. Remote visual equipment was secured as a result of access engineering conducted during the 1982 refueling outage. An extremely limited remote visual examination was per-

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formed on the suspension bracket mounting bolts and accessible i-weld surface on support hanger lug (No. 802-5).

'l Licensee's Basis for Requesting Relief Plant design does not allow access to the 12 suspension rod brackets. The integrally welded support is located 9 ft. below the flange and at this location, there is 1 f t. between the reactor vessel wall and shield cooling jacket. The exterior surfaces of the vessel and its welded attachments are covered with a stainless l steel blanket insulation creating limitations to the remote visual examination.

The hanger lugs, whose purpose is to prevent torsional move-ment of the reactor vessel, are approximately 3 ft. above the-suspension rod brackets or about 6 ft. below the flange. Direct access to the lugs is impossible due to the concrete shield wall.

Remote visual access is also limited due to lug support structure whose disassembly is impossible for safety considerations. The lugs are considered non load-bearing.

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- The stabilizer brackets are approximately 5.5 ft. above the benchmark of the vessel and are inaccesible for direct inspections due to the concrete shield wall. Forces caused by the stabilizers are compressive in nature, thereby elimi-nating shear forces. Since there are no shear forces, the weld is essentially non load-bearing. Defects in the weld would, therefore, have no effect on the intended use of the-lug.

The application of a PAR mechanized inspection device on welded stabilizer brackets (801-3A and -3D) was attempted during the 1983 outage. It was determined that UT results were not meaningful due to geometric configuration.

Evaluation

.. The supports described above are inaccessible for any type of local examination from the exterior of the vessel. The licen-see-has used a PAR device to UT some of the stabilizer brackets -

from the interior of the vessel, but the weld geometrics made UT results uncertain. The licensee has attempted remote visual examinations of the attachments and found access to be.very limited. That effort should be repeated for the current interval.

The licensee has also proposed to visually examine the general area of the shield annulus for leaks during system pressure testing. This should give an indication of the integrity of the welds attached directly to the pressure vessel membrane.

Conclusions and Recommendations 1

Based on the above evaluation, it is concluded that for the I welds discussed above, the code requirements are impractical.

It is further concluded that the alternative examinations dis-cussed above will provide necessary added assurance of structural reliability. Therefore, the following is recommended:

nr 3 Relief should be granted from the code required examinations of the above integrally welded attachments, contingent on the fol-lowing examinations being performed as proposed by the licensee:

(a) Visually examine the general area of the ' shield annulus for leakage during system pressure tests.

(b) Visually examine by remote means any accessible portions of all subject attachments.

References Reference 12.

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B. ' Pressurizer

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Hot applicable to BilRs.

C. Heat Exchangers and Other Pressure Vessels

1. Steam Drum Relief Requests:

RR-A20, Shell Welds, Category 0-B, Items 82.51 and B2.52 RR-A21, flozzle-to-Shell tiel,ds, Category B-D, Items B3.150 and B3.160 RR-A29 Integrally tielded Supports, Category B-H, Item B8.40 Code Requirements

. Category B-B: One circumferential weld and 1 foot of a longi-tudinal weld in the heat exchanger shell which intersects the examined circumferential weld are to be volumetrically examined -

once during each inspection interval.

Category B-D: All nozzle-to-vessel welds and nozzle inside radius sections are to be volumetrically examined once during each inspection interval.

Category B-H: The applicable weld in one heat exchanger support is to be exanined by volumetric or surface methods each inspection interval.

. Code Relief Request Relief is requested from any code requirements associated with welds or portions of welds in the steam drum that are-located within a 150-degree arc either side of the bottom longi-tudinal centerline. These welds include:

(a) All above located portions of the circumferential shell welds, (b) The longitudinal shell welds, (c) One-half of the full penetration-weld nozzles:

(1) downcomers B-1, -2, -3, -4 (2) risers C-1, -2, -3, -4, -5, -6 (3) feedwater E-1, -2 (4) condensate G-1, -2 -

(5) gauge glass J-2 (6) level M-2, -4 (d) The above located integrally welded steam drum supports.

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, P,roposed Alternative Examination The examinations in ,the upper portions will disclose the condition of those areas representative of the most severe service conditions to which the steam drum is exposed, and therefore, will disclose any incipient general degradation, The hydrostatic examinations performed each refueling outage (prestartup hydro) and the nozzle-to-safe end examinations of the risers and downcomers will provide additional indication of the steam drum structural integrity.

Licensee Basis for Requesting Relief Access to the upper areas of the steam drum, within approxi-mately a 30-degree arc either side of the top longitudinal center-line, is good without extensive scaffolding. The general field is

'- relatively low, approximately 0.06 R/hr. The combination of good access and low general field will permit shell weld examinations without excessive e,xposure. Access to the lower portions of the steam drum, within approximately 150 degrees of arc either side of -

the bottom longitudinal centerline, is poor without extensive scaffolding. The general field in this area is approximately 10 times (0.6 R/hr) that of the upper portion.

For shell welds, no examinations will be conducted in the lower portions due to the combination of high fields and poor access; i.e., approximately 20 to 25 man-hours will be required (scaffolding, insulation, weld preparation, examination) to per-form each examination in the lower areas. With six of the ten longitudinal and circumferential welds being located entirely in this region, an additional 170-240 man-rem exposure will be required (28-40 man-rem per weld) to perform a complete Category B-B examina-T tion over the interval. liowever, by restricting inspection to the upper portions of the steam drum, the Code requirements can be fulfilled on four of the ten welds without accumulating the excess exposure.

Performing the Category B-D examinations en nozzles in the lower portions of the steca drum will require 595-850 man-rem exposure over the interval (35-50 man-rem per nozzle for 17 nozzles).

These figurcs are based on the general field in the area of the nozzles. Contact readinos on the nozzle-to-shell weld area are on the order of three tiines that of the general field. Similarly, high radiation fields preclude examining 10 of the 14 integrally welded supports. The four T2 supports can be examined.

Evaluation -

For all the above welds, adhering to code requirements would result in excessive personnel exposure. Adequate knowledge of vessel integrity should be gained by performing the proposed code examinations and visually examining the steam drum during prestartup hydrostatic tests. The sample size for shell welds, however, needs clarification. The Code requires 100% of one circum-forential weld (the entire circumference) and a 1-ft length of a longitudinal weld to be examined. The total length of shell welds to be examined in the proposed upoer portion of the steam drum should (1) equal the circumference of the steam drum plus I ft or (2) equal the total length of all shell welds in the upper portion, whichever is less.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed above, the Code requirements are impractical.

It is further concluded that the alternative examinations dis-cussed above will provide necessary added assurance of structural

. reliability. Therefore, the following are recommended:

(a) Relief should be granted from the Category B-B require- -

ao ments on shell welds. Instead, shell welds within a 30-degree arc either side of the upper longitudinal centerline should be Code examined. The total length of.the sample should be (1) equal to the circumference of the steam drum plus I ft or (2) equal the total length of all shell welds within the above described upper portion of the steam drum, whichever is less.

(b) Relief should be granted from the Category B-D require-ments to examine the above listed nazzles. All other

' steam drum nozzles in this category should be Code examined as proposed.

(c) Relief should be granted from the Category B-H require-1 ments on the 10 of 14 integrally welded supports not in i the upper portion of the vessel. The four supports in

' the upper portion (T2-1, 2, 3, 4) should be Code examined as proposed. ,

(d) The stea'm drum should be visually examined during system

! pressure tests (per IWB-5000) as proposed.

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References Reference 12.

, 2. Request for Relief RR-A22, Clean-Up Regenerative Heat Exchangers.

(RHX) Units A, B, C, D; and Non-Regenerative Heat Exchanger (NRHX)

Unit E, Category B-D, Item B3.160 Code Requirement All nozzle inside radius sections are to be volumetrically examined once during each inspection interval.

Code Relief Request For the clean-up RHXs (Units A, B, C, D) and NRHX (Unit E),

relief is requested from the code requirement to volumetrically examine the inside radius sections on the following nozzles:

(a) channel inlets (A 5, B-5, C-5, D-5, E-5)

- (b) channel outlets (A-6, B-6, C-6, D-6 E-6)

(c) shell inlets (A-7, B-7, C-7, D-7) .

(d) shell outlets ( A-8, B-8, C-8, D-8) .

Proposed Alternative Examination None.

Licensee's Basis for Requesting Relief These nozzle inside radius sections cannot be UT examined

- due to geometry. The RHX nozzle-to-shell welds on the channel inlets and outlets and shell inlets and outlets will be examined in'accordance with the Code requirements. These examinations will provide adequate information concerning the general inter-nal condition of the nozzle and shell. The inside radius section examinations have been unsuccessfully attempted and will, therefore, not be scheduled. .

Evaluation Because of the geometry of these nozzles, UT of the inside radius sections returns inadequate results. These examinations have been attempted and the results were not meaningful. Other examinations on these heat exchangers, including the UT of RHX nozzle-to-shell welds and visual examinations during prestartup hydrostatic testing should give adequate indication of the heat exchangers' integrity. '

F Conclusions and Recommendations Based on the' above evaluation, it is concluded that for the nozzles discussed above, the Code requirements are impractical.

It is further concluded that 9ther Code examinations and the alternative examination discus;ed above will provide necessary added assurance of structural reliability. Therefore, the following is recommended:

Relief should be granted from the Code requirement to volu-metrically examine the inside radius sections of the subject nozzles. Along with the scheduled nozzle-to-shell examinations on these nozzles, they should also be visually examined during system pressure tests.

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-References Reference 12.

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3. Request for Relief RR-A23, Clean-Up Non-Regenerative Heat - 1 Exchanger-(NRHX) Unit E, Category B-D, Item B3.150 Code Requirements For full penetration welds of. nozzles, a volumetric examination is to be performed on all subject nozzles each inspection interval. For Item B3.150, the area to be examined includes the nozzle-to-vessel weld and adjacent. areas of the nozzle and vessel.

Code Relief Request w Relief is requested from code requirements to volumetrically

. examine the clean-up NRHX (Unit E) nozzles' nozzle-to-shell welds

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,as follows:

(a) -channel inlet nozzle (E-5)

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(b) channel outlet nozzle (E-6).

Proposed Alternative Examination 3 The channel inlet and outlet nozzle-to-shell welds will be

' subjected to visual and surface examinations in lieu of the code required volumetric examinations. In addition, the prestartup hydro.will provide a routine monitoring of the condition of these welds.

9 r Licensee's Basis for Requesting Relief The' channel. inlet (E-5) and outlet (E-6) nozzles, nozzle-to ' '

.shell welds cannot be UT inspected due to the close proximity of shell circumferential welds and internal baffle arrangements.

, s.

Evaluation '

Internal baffle interference and poor geometry'due to interferences from other welds make code UT impractical for these nozzles. The licensee has proposed to perform surface NOE and visual VT-1 examinations on these nozzles' nozzle-to-shell welds as well as visual examinations during system pressure-testing. Performing the proposed alternative examinations should give adequate information on the structural integrity of the' nozzles in. this heat exchanger.

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Conclusions and Recommendations Based on the above evaluation, it is concluded that for the nozzles discussed above, the code requirements are imprac-

' tical. It is further concluded that the alternative examinations discussed above will provide necessary added assurance of struc-tural reliability. Therefore, the following is recommended:

Relief should be granted from the Category B-D examinations on the subject nozzles, provided that the following examinations are included in the program, as proposed by the licensee:

(a) Surface and-VT-1 examinations on the subject nozzles' nozzle-to-shell welds.

', (b) Visual examination during prestartup hydrostatic tests.

References Reference 12.

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4. Request for Relief RR-A24, Clean-Up Demineralizer Tank Nozzles, Category B-D, Item B3.160 Code Requirement For heat exchangers, all nozzle inside radius sections are to be volumetrically examined once during each inspection 1.nterval.

Code Relief Request Relief is requested from the Category B-D examinations of the five nozzle inside radius sections on the cleanup demineral-izer tank.

- Proposed Alternative Examination The prestartup hydro and the remainder of the Category B-D testing will provide adequate indication of tank structural .

integrity.

Licensee's Basis for Requesting Relief The cleanup demineralizer tank nozzles are fabricated by welding square-ended pipe nipples into the tank shell. The portion of the pipe nipple corresponding to a nozzle inside radius section has a radius of essentially zero and, therefore, cannot be UT inspected.

T'he examination of the nozzle inside radius section was incorporated into the Code primarily to detect thermal cycling stress degradation. The primary system water flowing into the cleanup demineralizer tank first passes through the cleanup re-generative and non-regenerative heat exchangers to reduce and stabilize the water temperature to below 110 F to prevent decom-position of the demineralizer resins. This tank is, therefore, not subject to significant thermal cycling, and inspection of the nozzle inside radius sections is therefore not required.

Evaluation -

The only Class 1 vessels required to be examined according to the Code are the reactor vessel, the pressurizer, the steam generators, and other heat exchangers. None of the vessel exami-nation categories (B-B, B-D, B-E, B-F, B-G-1 and -2, B-H, B-P) have any provisions for the examination of other Class 1 pressure vessels (suchasademineralizertank)d)Althoughtheprevio'us recommendation on this relief request stated that relief was not needed because no examination was required, it is felt that 'this is an oversight in the Code and that every Class 1 vessel not

4 exempted by IWB-1220 should be examined. The cleanup demineralizer tank could be appropriately examined according to the various heat exchanger categories and items (such as B-B, B2.50). The licensee  ;

has stated that the tank's low operating temperature (1100F) and lack of thermal cycling of the nozzles during normal operat ion mini-mize the stresses on the nozzles. Also, the Category B-D nozzle-to-vessel weld examinations will be perforned, and relief is only requested from the required inside radius section examinations.

Since the nozzles have a geometry that precludes good UT results, relief is justified.

Conclusions and Recommendations Based upon the above evaluation, it is concluded that for

, the cleanup demineralizer tank nozzles, the code requirements are impractical. It is further concluded that the alternative examinations proposed will provide necessary added assurance of structural reliability. Therefore, the following are recommended:'

(a) The cleanup demineralizer tank should be examined by all the requirements that govern Class 1 heat exchangers.

(b) Relief should be granted from the Category B-D require-ment to examine the tank nozzles' inside radiused sections.

(c) Th2 licensee's proposed alternative actions should be performed.

l References References 12 and 14.

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D. Piping Pressure Boundary

1. Request for Relief RR-A30, Shutdown Cooling System Dissimilar Metal Fitting-to-Pipe Weld, Category B-F, Item B5.50 Code Requirement Welds are to be examined by volumetric and surface means once during each inspection interval.

Code Relief Request Relief is requested from the Category B-F requirements to perform volumetric and surface examinations on weld 6-SCS-101-7. ,

i Proposed Alternative Examination A hydrostatic test (prestartup hydro) is performed before each startup at 1.1 times the operating pressure. This is more conservative than the prestartup leak test at operating pressure as required by the Code (IWB-5221). Inspection of the remaining I accessible portion of this line will provide some indication of the piping integrity.

Licensee's Basis for Requesting Relief y . Pipe weld is not physically accessible for NDE due to plant design. Access is precluded due to a straight, uninterrupted vertical drop of 35 feet. No safe access from overhead is

, available.

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,) Evaluation ' '.

Attempting to examine this weld would create excessive risk to personnel safety. Visual examination during pressure tests and examination of other welds in the line should provide information as to the integrity of the subject weld.

h

.. m Conclusions and Recommendations Based on the above evaluation, it is concluded that for the weld discussed above, the code requirements are impractical.

It is further concluded that the alternative examination dis-cussed above will provide necessary added assurance of struc-tural reliability. Therefore, the following is recommended: -

Relief should be granted from the Code requirements to volumetrically and surface examine this weld, provided that the weld is visually examined during pressure tests as.

prope, sed.

, ,P.eferences Reference 12.

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2. Request for Relief RR-A31, Dissimilar Metal Socket Welds, Category B-F, Item B5.50 Code Requirement-All dissimilar metal welds are to be examined by volu - i metric and surface methods once during each inspection interval.

l l

Code Relief Request '

Relief is requested to examine dissimilar metal socket welds by surface examination only. The following dissimilar metal socket welds have been designated B5.50, B-F, and will be inspected by

, surface examination:

2-RCS-101-64 2-RCS-111-8, -9 ^

1.5-RDS-112-5, -6 1.5-RDS-113-5, -6 1.5-RDS-114-5, -6 1.5-RDS-115-5, -6 1.5-MSS-117-41.

Proposed Alternative Examination Surface examination of these welds.

Licensee's Basis for Requesting Relief

i Section XI does not address the subject of dissimilar metal Plant piping contains 11* dissimilar metal socket j socket welds.

welds. Meaningful volumetric examination of socket welds is not i possible.

Evaluation -

Category B-F requires volumetric and surface examination of

.these dissimilar metal welds. However, UT of socke.t welds produces poor results because of the fillet weld type geometry. This is recognized in Category B-J where socket welds are to be examined only by surface methods. The Code volumetric examination require-ment is then impractical for socket welds. These welds will be adequately examined by surface examination and regularly scheduled pressure tests. ,

• Note that 12 welds are actually listed in relief requests.

o Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed ~above, the Code volumetric examination requirements are impractical. It is further concluded that the Code surface examinations, along with regularly scheduled pressure tests as discussed above, will provide necessary added assurance of structural reliability. Therefore, the following is recommended:

Relief should be granted from the Code requirement to

' volumetrically examine the above twelve dissimilar metal Class I socket welds as required by Category 0-F, provided that they are visually examined for leaks during system pressure tests (IWA-5000). Surface examinations should be performed on these welds in accordance with Category B-J, item B9.40.

References Reference 12.

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. 3. Request for Relief RR-A32, Si.nilar Metal Safe End-to-Pipe Welds; Category B-F, Item B5.50, or Category B-J, Items B9.11. B9.21, and B9.40 Code Requirements Category B-F: All dissimilar metal welds are to be volu-metrically and surface examined once during each inspection interval.

Category _B-J: 25% of similar metal pipe welds are to be examined volumetrically during each inspection interval.

Code Relief Request

- The licensee is asking to classify all similar metal safe end-to-pipe welds as Category B-J. Item B9.11, B9.21, or B9.40 instead of Category B-F, Item B5.50. Relief is then requested '

on certain of these welds due to inaccessibility. Following is a list of known similar metal safe end-to-pipe welds and their appropriate category / item numbers:

20-PRS-121-20 89.11 B-J 20-MRS-122-20 89.11 B-J J 14-MRS-101-2 B9.11 B-J 14-MRS-102-2 B9.11 B-J 14-MRS-103-2 B9.11 B-J 14-MRS-104-2 89.11 B-J 14-MRS-105-2 B9.11 B-J 14-MRS-106-2 89.11 B-J l

6-SCS-101-1 89.11 B-J 3-LPS-102-47 B9.21 B-J 2-MSS-121-1 B9.40 B-D 2-1155-131-1 B9.40 B-J 2-MSS-134-1 89.40 B-J 2-MSS-124-1 B9.40 B-J 3-CSS-104-20 B9.21 B-J Conclusions Category B-F requirements pertain to dissimilar metal welds only. Any similar metal safe end-to-pipe welds in piping would appropriately be classified as Category B-J and examined according to Category B-J requirements. Thus, in the request for relief that follows (see I.D.4 of this report) the Category B-J require-ments are applied to those welds that are inaccessible to examination.

References ,

Reference 12.

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4. Request for Relief RR-A32, Similar Metal Pipe-to-Safe End Welds, Category B-J. Items B9.11, B9.21, and 89.40 Code Requirements The extent and frequency of examination of piping are option-ally taken by the licensee from the 1974 Edition, Summer 1975 Addenda. Welds in piping are to be examined by volumetric and/or surface methods. The extent of the examinations includes a minimum of -25% of the total number of circumferential welds in the reactor coolant system. A different group of 25% of system welds is to be

-examined each inspection interval.

. Code Relief Requests Relief is requested fran the Category B-J requirements to examine the following welds: .

3 20-MRS-121-20' 89.11 B-J 20-MRS-122-20' B9.11 8-J 6-SCS-101-1 B9.11 B-J 2-ftSS-121-1 B9.40 B-J c 2-MSS-131-1 89.40 B-J 2-MSS-134-1 B9.40 B-J 2-f1SS-124-1 89.40 B-J Proposed Alternative Examination Prestartup hydrostatic testing.

Licensee's Basis for Requesting Relief -

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Examining these welds would result in excessive risk to personnel safety or excessive personnel exposure due to one or more of the following: -

(a) No access due to physical interference such as narrow pipe chases.

(b) High radiation fields (1-2 R/hr).

• Approximately one-third of the weld length will be volumetrically examined.

(c) long vertical drops (30-55 feet), no overhead access and inability to build scaffolding en a sloping floor which, as a part of the primary containment pressure boundary, would suffer damage if restraints were attached.

Evaluation Imposition of Code examination requirements on these welds is not practical due to their inaccessibility and high risk to examiners. However, the number of inaccessible welds is suffi-ciently small and random, compared with the total number of welds in Category B-J (or in any of the above affected systems), that none of these welds needs to be (nor is scheduled to be) included in the 25% sample to be examined during this inspection interval.

For subsequent inspection intervels, the licensee has the option of updating to subsequent Code versions or of staying .

with the 1974 Edition and Addenda through the Summer 1975, pur-suant to 10 CFR 50.55a(b)(2)(ii). Updating would allow the licensee to examine the same 25% sample, if the provisions of the Sumner 1978 Addenda, 1977 Edition, continue to prevail (see footnote (2) of Category B-J in Tatle IWB-2500-1). By adopting 10 CFR 50.55a(b)(2)(ii) the Commission was offering an option whereby " operating facilities with ongoing inservice inspection programs would have continuity in the extent and frequency of examinations for pipe welds" (see 44 FR 57913).

i Because a 25% sample of inspectable welds exists, relief from Category B-J requirements is not required at this time for the subject welds. It is preferable to defer any relief until f l;

' an interval when these welds are required to be included in the 4 Category B-J examination sample.

Conclusions and Recommendations ,,

Based on.the above evaluation, it is concluded that for these welds, relief from the impractical Code requirements is not needed. Therefore, it is recommended that relief from volumetric examination not be granted for this inspection interval.

References Reference 12. ,

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5. Request for Relief RR-A36, Integrally Welded Piping Attachments, Main Recirculation System, Category B-K-1, item B10.10

. Code Requirement The welded attachments of piping required to be examined by Examination Category B-J are to be volumetrically or surface examined during two of the four inspection intervals.

Code Relief Request Relief is requested from performing the code examinations on the following integrally welded pipe supports:

i 12-MSS-105-10PL 1 through 4,

', 14-MRS-103-3PL 1 through 8, and 14-MRS-105-3PL 1 through 8. ,

I Proposed Alternative Examiration For the case in which a weld defect would affect the

' integrity of the piping pressure boundary, the prestartup hydro serves as an alternative inspection. A remote visual examination will be made of the support to try to determine t its integrity as a support.

Licensee's Basis for Requesting Relief The above pipe attachments are not accessible for volu-

,, metric or surface examination due to plant design and high radiation fields. These supports are located 30 feet above the lower deck area of containment. The floor in this area is curved due to contair. ment configuration and the use of

. scaffolding or ladders is not possible. Access from above is also not possible due to plant layout. -

'I The genebl radiation field in this area is 0.6 R/hr, and 11-13 man-rem exposure per support per interval would be absorbed solely in preparation for the examination; i.e., weld prep and insulation removal, performing the examination and post-examination cleanup, provided access to the supports were possible, which is not the case.

Eva lua tion .

Examining these welds would result in excessive risk to personnel safety and excessive personnel exposure. The Code requirements are therefore impractical. The above proposed visual examinations and Code examinations of other pipe attach-ments should provide adequate information on the integrity of the subject supports.

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Conclusions and Recommendations Based on the above evaluation, it is concluded that f9r

- the welds discussed above, the Code requirements are impracti-cal. -It is further concluded that the alternative examination discussed above will provide necessary added assurance of

- structural reliability. Therefore, the fol'owing is recommended:

Relief should be granted from the Code aequired examinations of the subject welds, provided that the above described visual examinations are performed as proposed.

References

. Reference 12.

se 4

i r

I i

l l

l 6.- Request for Relief RR-A37, Integrally Welded Piping Attachments, Reactor Depressurization System, Category B-K-1, Item B10.10 Code Requirement The welded attachments of piping required to be examined by Examination Category B-J are to be volumetrically or surface examined during two of the four inspection intervals.

Code Relief Request Relief is requested from the Code required examinations on the following pipe supports:

12-RDS-101-3PL, and 12-RDS-101-13PL.

Proposed Alternative Examination .

This system is hydrostatically tested during the prestartup hydrotest.

Licensee's Basis for Requesting Relief The pipe attachments are welded to the pipe, and during normal operation, do not contact the pipe support structure.

The pipe attachments serve to resist torsional movement during severe or abnormal conditions and are nonload-bearing during normal. opera tion.

The welded pipe lugs are enclosed by 1.5-inch plate steel saddles top and bottom. The saddles were fabricated with openings to allow about 0.375-inch to 0.5-inch of unrestricted movement.

e The openings in the saddles do not permit enough clearance for volumetric or surface inspection equipment (as available by state-of-the-art technology) to perform the code-required exami-na tions . Relief is requested from code-required examinations based on nonload-bearing conditions during normal operation and inaccessibility. '

Evaluation The pipe lugs are surrounded by support saddles that leave enough clearance to avoid contact with the lugs during normal operation. However, the clearances are too small to allow access for volumetric and surface examinations of the lugs. The saddles appear non-removable because of their welded construction.

These lugs are not highly stressed during normal operation, but the Code does not specifically allow exemption of nonload-bearing integral supports from examination. Relief, however, is warranted on the basis of inaccessibility.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the integral pipe attachments (lugs) di-c.ussed above, the Code requirements are impractical . It is .her concluded that the licensee's proposed alternative examination will provide neces-sary added assurance of structural reliability. Therefore,'

the following are recommended:

(a) Relief should be granted from the code-required examinations of the subject pipe lugs.

(b) The lugs should be visually examined during pre-startup hydrostatic tests as proposed.

References References 12 and 14.

i 4

4 "l

3 e

9 t

• e

. 7. Request for Relief RR-A38, Component Supports, Piping, Category B-K-2, Item B11.10 3: Code Requirement-Visual examinations of piping supports are to be made each inspection interval. . The examinations include verification of the settings of snubbers, shock absorbers, and spring-type hangers.

Code Relief Request Relief is requested from direct visual examination of the following pipe supports:

3-LPS-102-21PR-1, 3-LPS-102-21PR-2, 3-LPS-102-23PR, 6-SCS-101-6PS, -

8-SCS-101-8PR, and-

. 8-SCS-101-10PR.

Proposed Alternative Examination Inspection shall be done remotely as allowed by Paragraph IWA-2213(c) of the Section 'XI Code,1977 Edition.

License.e's Basis for Requesting Relief The supports are located 50 feet above the lower deck area

.of containment. The floor in this area is curved due to contain-

' ment configuration and the use of scaffolding is not possible.

Access from above is also not possible.

The general radiation field is 0.6 R/hr, and 11-13 man-rem exposure per support per interval would be abs,, orbed before, during, and after examining these welds, provided access to the support were possible, which is not the case.

Evaluation The licensee's program states that Subsection IWF will be adopted for examining Class 1, 2, and 3 component supports as it was for the previous interval. This subsection was issued with the Winter 1978 Addenda and superseded Category B-K-2 for Class 1 supports. Both Category B-K-2 and Subsection IWF require a combi-nation of visual VT-3 and VT-4 examinations. Only the VT-3 exami-nation is allowed to be performed remotely (IWA-2213(c)), and relief for that examination is not required. For VT-4 examinations, the inaccessibility of the supports justifies remote examination.

The licensee should, however, update to the 1977 Edition, Winter 1978 Addenda, to make use of Subsection IWF.. The Winter 1978 Addenda'has been referenced in 10 CFR 50.55a and inservice examinations may meet the requirements of that addenda in lieu of previous editions, provided that all related requirements are also met. NRC approval is required to update.

Conclusions and Reconmendations Based on the above evaluation, updating to Winter 1978

~ Addenda to implement Subsection.IWF for examining all pipe and component-supports should be approved.. Further, relief from the direct examination VT-4 requirement should be granted for those supports identified above, provided that those areas are visually examined by remote means according to the prescribed schedule.

. =

^

References t

References 12 and 14.

jr' 4 6+

I5' e

e 4

r l

l l

1  !.

, E. Pump Pressure Boundary

1. Request for Relief RR-A39, Pump Casing Welds, Category B-L-1, Item B12.10 Code Requirement Volumetric examinations of Class 1 pump casing welds are to be performed each inspection interval. Examinations are limited to welds in at least one pump in each group of pumps performing similar functions in the system. The examinations may be deferred to the end of the interval.

Code Relief Request

', Relief is requested from the Code required volumetric exami-nations of pump casing welds in the cleanup and main recirculation pumps. -

Proposed Alternative Examination Surface examinations are to be conducted on accessible areas.

Visual examinations will also be made during system hydrostatic tests.

Licensee's Basis for Requesting Relief Approximately 600 man-hours would be required and a total exposure in excess of 1000 man-rem would be experienced in per-1 forming the examination. All work would have to be performed 1 in full face mask or under supplied air conditions. Shielding

would reduce the total exposure by only 25%.

l The man-hour estimate is based only on the onsite work per-formed by maintenance, operations and NOT personnel and does not include engineering time, pre-outage job planning, or the man-hour.; expended by Radiation Protection personnel.providing direct coverage. -

The pump casing was fabricated from cast stainkess steel (ASTM A-351, Grade CF8ti). This alloy corresponds roughly to Type 316 stainless steel (Ni/Cr ratio modified to facilitate casting). The thickness, material, and manufacturing process lead to extraordinarily large grain sizes. Large grain cast stainless steels are considered non-inspectable with ultasoni.cs because this material is highly attenuative. The presence of delta ferrite (typically 15% or more) provides increased resis-tance to intergranular stress corrosion cracking (IGSCC). Delta ferrite also improves resistance to pitting corrosion. Neither Byron-Jackson (pump manufacturer) or Southwest Research Institute use or advocate ultrasonic examination of primary coolant pump casing weld.

External access to the pump casing welds is not possible

- due to the base plate configuration. Furthermore, external placement of radiographic testing (RT) film is also precluded due to the base plate configuration of the pump.

The RCP has a double volute configuration and according to the manufacturer (Byron-Jackson), lacks access for internal visual or surface examination of the pump casing. The RCP design cor-responds to the Type C pump illustrated in Figures NB-3441.3-2 and 3423-2 (1980 Edition, ASME P&PV Code,Section III). The " splitter" prevents placement of RT film cassettes or an exposure device inside the pump, thus precluding radiographic testing.

Consumers Power Company is a member of the EPRI Owners Group for Byron-Jackson pumps, and is presently investigating a method (i.e., MINAC) that might be used in the examination of the RCPs

- at Big Rock Point.

Evaluation .

A radiographic examination of the RCP casing welds appears technically difficult for the Byron-Jackson type pumps, even if the pump is disassembled. Such examinations are, as the licensee points out, time consuming and expensive in exposure and dollars.

At Point Beach, radiographic examination of welds on one RCP casing and visual examination of the pump inside pressure retaining surfaces were performed using MINAC and a manipulator. This exami-nation required about 25 days (including pump disassenbly and re-assembly). It resulted in a total accumulated radiation exposure of 36 man-rem and a cost of about $700,000. Radiographing through two wall thicknesses to examine a weld in one wall, as would be

~

necessary for the Byron-Jackson type pump casings, requires further development work, which'the EPRI NDE Center hopes to undertake shortly for the Owner's Group.

The MINAC has been used at Ginna, Turkey Point, Point Beach, and Robinson. No notable indications were found in any of the pumps examined.

At this time, disassembly of pumps solely for making this

' volumetric examination does not appear warranted in view of the radiation exposure and lack of a viable examination technique.

However, an examination should be done by the most feasible means if a pump at Big Rock Point requires disassembly for maintenance.

At this stage of technology development, a surface examination of at least a portion of these welds, where practical, would be most appropriate. The inspection interval considered in this report ends in January 1992. No pumps were disassembled for maintenance or examination during the last interval. Since the examination technology is only currently being actively developed, it is reasonable to give relief for the present inspection interval.

Any decisions on relief requests for future intervals should be deferred until then and be based on developments in UT and RT technology and on industry experience.

~ .._- _ . - .

, ' Conclusions and Recommendations

_-Based on-the above evaluation, it is concluded that for the welds discussed above, the Code requirements are impractical._ It is further concluded that the' alternative examination discussed above will provide necessary added assurance of structural reli-ability.. Therefore, the following are recommended:

(a) Relief should be granted from the volumetric examination of the subject welds for the current inspection interval.

(b) As a condition of relief, the licensee should be required to examine these welds, by the most feasible means, on the first such pump disassembled for maintenance during this interval.

e References -

Reference 12.

4 1

l'

~.

a 6

= _ . _ - . ~ . . _ - . . _._ _. -

2. Request for Relief RR-A41, Pump Internal Surface Examination,

' Category B-L-2, Item B12.20

' Code Requirement Visual examinations of Class 1 pump casing internal surfaces are to be performed each inspection interval. Examinations are limited to at least one pump is each group of pumps performing similar functions in the system. The examinations may be deferred to-the end of the interval.

Code Relief Request .

Relief is requested from the requirement to visually examine the casing internal surfaces of the cleanup and main recirculation

', pumps.

Proposed Alternative Examination

'( A pump interior will be examined to the extent practical should it be disassembled for any other reason.

Licensee's Basis for Requesting Relief Visual examination of the internal surfaces (cleanup pump, main recirculation pumps 1 and 2) is not possible due to config-uration. During the Big Rock Point 1982 refueling outage, access engineering was conducted on the cleanup pump and main recircula-tion pump internal surface by Southwest Research Institute. Due to internal, configuration, visual examination of the internal li surfaces is not practical. All accessible external welds of the

cleanup pum'p will be examined during the 1983 refueling outage.

(See also the previous item, l.E.1).

.f Evaluation The visual' examination specified is to determine whether unanticipated severe degradation of the casing is occurring due '

to phenomena such as erosion or corrosion. At this. time, dis- ,

assembly of pumps solely for making this visual examination does not appear warranted in' view of the radiation exposure.

Ilowever, an examination should be done if a pump at Big Rock Point requires disassembly for maintenance. (See the previous item 1.E.1 for additional evaluation.)

i Conclusions and Recommendations Based on the above evaluation, it is concluded that for the examinations discussed above, the Code requirements are

. impractical . It is further concluded that the alternative examination discussed above will provide necessary added assurance of structural reliability. Therefore, the following are reconmended:

.(a)' Relief should be granted from the visual examination t of .these casings for the current inspection interval.

-(b) The licensee should be-required to visually examine'the casings on 'the first such pump disassembled for naintenance during this interval.

o References .

1 Reference 12.

9 m

w e f

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[ 45-

F. ' Valve Pressure Boundary

1. Requests for Relief RR-A40, RR-A43, and RR-A44, Class 1 Valve Internal Examination, Category B-M-2, Item B12.40 Code Requirement One valve in each group of valves of the same constructional design, e.g., globe, gate, or check, manufacturing method, and manufacturer, that performs similar functions in the system shall be visually examined during each inspection interval. This exami-nation may be performed on the same valve selected for the Category B-M-1 examination.

The examinations may be performed at or near the end of the

- inspection interval.

Code Relief Request Following is a list of 25 Class 1 valves in 11 groups at Big Rock Point. Relief is requested from the visual examination of the internal surfaces of valves in the six noted categories, r

Class 1 Valves Remarks

.i

1. 5-Inch Valves (Chapman-Gate)

M0-N002A Relief requested. Examine M0-N002B only if maintenance required.

i 2. 6-Inch Valves (Anchor-Darling Gate)

~

CV-4180 Examine one valve in this CV-4181 group each inspection CV-4182 interval.

CV-4183 ,

3. 6-Inch Valves (Powell-Gate)

M0-7052 Examine one valve in this M0-7062 group each inspection 6-Inch Valves (Target Rock) interval.

4.

SV-4984 Examine one valve in this SV-4985 group each inspection SV-4986 interval.

SV-4987 .

5. 8-Inch Valves (Powell-Gate)

M0-7056 Examine one valve in this M0-7057 group each inspection MO-7058 interval.

M0-7059 l

{

L

Class 1

• . Valves Rema rks

6. 10-Inch Valves (Edwards-Globe)

Relief requested. . Examine VFW-9 only if maintenance is required.

7. 10-Inch Valves ( Anchor-Darling-Check)

VFW-304 Relief requested. Excmine only if maintenance is required.

8. 12-Inch Valves (Powell-Gate)

M0-7050 Examine each inspection interval.

9. 20-Inch Valves (Chapman-Gate)

'- M0-N001A Relief requested. Examine M0-N001B only if maintenance is required. ,

10, 20-Inch Valves (Allis-Chalmers-Butterfly)_

M0-N006A Relief requested. Examine MO-N006B only if maintenance is required.

11. 24-Inch Valves (Chapman-Gate)

M0-N003A Relief requested. Examine M0-N003B only if maintenance is-required.

h

' Proposed Alternative Examination A hydrostatic test (prestartup hydro) conducted at 1.1 times

~

' the operating pressure will serve as an alternate test. The inspec--

tion of other valves and the results will also?give an indication of the conditio~n of the internals of these valves. Should it be necessary to disassemble these valves for maintenance, the licensee has consnitted to visual examinations. .

Licensee's Basis for Requesting Relief The main recirculation pump discharge and butterfly valves are not fully isolable from the reactor and are, therefore, not inspec-table. Examination of the above valves requires complete draining of the reactor vessel which is not practical and requires 100% core

> off-loading, which creates tremendous maintenance and exposure prob-lems. Examining the 24-inch valves reouires the draining of the downcomers, which wou1d increase the radiation fields. Examining the feedwater valves would lead to 40-50 man-rem exposure each during the interval.

Evaluation .

The visual examination specified is to determine whether unanticipated severe degradation of valve bodies is occurring due to phenomena such as erosion or corrosion. However, the disassembly of large valves to the degree necessary to inspect the internal pressure retaining surfaces is a major effort in terms of exposure to personnel and radioactive waste generation.

To do this disassembly solely to perform a visual examination of the internal surfaces is impractical.

Of the 11 valves required to be examined, five are scheduled for examination. Therefore, information on the overall condition of Class 1 valves will be available. In addition, the licensee will examine any valve disassembled for maintenance. Hence, for the current interval, relief appears warranted.

For subsequent intervals, specific relief should be requested ,

toward the end of each interval for each group of valves in which no valve was disassembled for maintenance and Code examined.

For those valve groups in which no valve is disassembled and examined, system pressure tests (IWD-5000) should be adequate to determine system integrity.

Conclusions and Recommendations Based upon the above evaluation, it is concluded that for the valves discussed above and for the inspection interval con-sidered in this report, the Code requirements are impractical.

It is further concluded that the alternative visual examination

! discussed above will provide necessary added assurance of struc-tural reliability. Therefore the following is recommended:

Relief should be granted from the code-required internel visual examinations on 'he subject valves for the current in-spection interval. As proposed, any valve aisessembled for maintenance should be code-examined. The valves should also be examined during system hydrostatic tests as proposed.

References References 12 and 14.

s II. CLASS 2 COMPONENTS

1. Request for Relief RR-B1, Class 2 Piping at Containment Penetrations',

IWC-1210 Code Requirement IWC-1210: The examination requirements of IWC shall apply to Class 2 pressure retaining components and their integral attachments.

Code Relief Request Where certain containment penetrations classified as Class 2 connect to either Class 3 or non-classed piping (see below), relief is requested from applicable Class 2 (IWC) examinations.

The following penetrations are affected:

Penetration Piping on Either Side Number- P&ID No. of Penetration H-12 M-111 Class 3 H-13 M-111 Class 3 H-15 M-108 Non-classed / Class 3 H-17 M-108 Non-classed H-18 M-110 Class 3 I H-21 M-108 Non-classed H-22 M-107 Non-classed / Class 3 H-23 , M-107 Non-classed H-31 M-121 Non-classed i -

f Proposed Alternative Examination Since the proposed examinations (see the licensee's basis for requesting relief below) on the Class 2 portions of the above refer-enced systems are in accordance with Code intent,,,no alternate inspections or test,s are considered necessary. This request for

'l relief is submitted primarily to obtain confirmation of IWA-1300(f),

which was issued with the Winter 1979 Addenda to Section XI.

Licensee's Basic for Requesting Relie_f_

The classification of the _' lass 2 portion of the piping is governed by the leak-tightness requirement associated with the con-tainment barrier, while the Class 3, or non-nuclear classification, is dictated by system function under pressure and temperature oper-ating conditions. In all cases, the system operating conditions impose more severe loadings on the components than the external loadings imposed when the containment functions are tested.

The system pressure tests and visual examinations of Subsection IWD of the ASME Code are intended to detect any service-induced degradation resulting from the more severe operational loads that the components are expected to sustain over their service lifetime.

Accordingly, the system function governs the classification under which the applicable rules of ASME Section XI Code must be applied.

This position is consistent with the revision of IWA-1300(f) ap-proved by ASME Subcommittee on Nuclear Inservice Inspection (Agenda No. ISI-77-14) which states:

"The portion of piping penetrating a containment vessel required by Section III to be constructed to Class 1 or 2 rules, and which may differ from the classification of the balance of the system, need not affect the overall system classification which determines the applicable rules of this section."

Accordingly, where the components beyond the containment pene-tration areas delineated on the referenced P and I diagrams are classified as ASME Class 3, the Class 2 process piping and associated .

pressurization pipe will be subjected to the requirements of Sub-section IWD of ASME Section XI Code. Where the components beyond the containment penetration area are classified non-nuclear class, the Class 2 components and associated pressurization pipe will not be subject to any Section XI requirements.

Evaluation IWA-1300(f) was issued in the 1977 Edition, Winter 1979 Addenda.

However, rather than saying that a Class 2 penetration can be exam-ined according to the classification (Class 3 or non-classed) of its connecting piping, it could be interpreted to say that the connecting piping need not be examined according to the classification of the "l penetration (Class 2 in this case).

USNRC Regulatory Guide 1.26, however, gives guidance for quality group classifications of plant systems / components. This regulatory guide does not make special mention of containment. penetrations and therefore, by omission, allows penetrations to belclassed the same as their connecting piping. Accordingly, each of the above penetrations would appropriately be examined according to the higher quality group

. classification of its connecting piping. ,

Conclusions and Recommendations No relief from Code requirements is needed. Each subject penetration should be classified and examined according to the higher classification of its two connecting pipes. The intent -

of the Code would then be met.

References Reference 12.

, 2. Request for Relief RR-B2, Classification of Class 2 Vent and Drain Lines Beyond Normally Closed Valves, IWC-1210 Code Requirement IWC-1210: The examination requirements of IWC shall apply ~to Class 2 pressure retaining components and their integral attachments.

Code Relief Request The vent and drain lines off the regenerative and non-regenerative heat exchangers beyond the second normally closed valve are classified Class 2, although allowed to be classified as Class 3. However, the licensee proposes to classify these

_ lines as non-nuclear, thereby performing no ISI examinations on

. them.

~

Proposed Alternative Examination None.

Licensee's Basis for Requesting Relief The portions of the nonregenerative and regenerative heat exchanger channel vents and drains and shell vents and drains beyond.the second normally closed valve would generally be classi-fied as Class 3. Since these vents and drains could have been classified'as Class 3, and since the venting and draining does not relate to any of the functions listed in Table IWD-2500-1, these portions of the vents and drains will be classified as non-

' nuclear for the purposes of inservice inspection and will not be subjected to examinations under Section XI of the ASME Code.

Evaluation y The case wherd a system was constructed to a'. higher quality group classification than required was not addressed in the Code until the issuance of IWA-1300(d) in the Winter 1979 Addenda, i.e.:

" Optional construction of a component within a system boundary to a classification higher than the minimum class established in the component Design Specification (either upgrading from Class 2 to Class 1, or from Class 3 to Class 2) shall not affect the over-all system classification by which the applicable rules of this Section are determined. " .

The above piping should then be allowed to be examined using the Class 3 criteria of Subsection IWD.

i _

Since Table IWD-2500-1 re

• or components to be examined (quires systems only certain supporting Classshut-a reactor 3 piping down function, ECC, RHR, containment heat removal, atmosphere cleanup, or spent fuel heat removal), and since the subject piping provides none of those functions, no Code requirements would be violated if the piping were not examined.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the piping discussed above, the Code requirements are impractical.

It is further concluded that the recognition of the above cir-cumstances in subsequent addenda of the Code makes an alternative examination unnecessary.

It is therefore recommended that relief be granted to allow the subject piping to be classified as Class 3 for purposes of ISI examination. The intent of the Code would then be met if the piping were not examined. .

I References Reference 12.

3 III. Class 3 Components.

No relief requests.

j

i IV. , PRESSURE TESTS A. General

1. Request for Relief RR-01, Substitution of System Hydrostatic Testing for System Pressure Tests, Categories B-P, C-H, D-A, D-B, D-C Code Requirements IWA-5000, IWB-5000, IWC-5000, IWD-5000 are to be used to perform system leak or functional tests once per period and system hydro-static tests once per interval.

Code Relief Request Relief is requested from performing a system pressure test (leak or functional test) during the inspection poriod in which the hydro-static test is scheduled. This request applies to all Class 1, 2 ,

and 3 systems.

Proposed Alternative Examination Hydrostatic test.

Licensee's Basis for Requesting Relief Table IWB-2500 (Category B-P), Table IWC-2520 (Category C-H) and Table IWD-2500-1 (Items D1.2 and D3.1) require the performance of both system pressure tests and system hydrostatic tests during the third inspection period. Implementation of the requirement for system pressure tests during the third inspection period is inappropriate in view of the performance of a system hydrostatic

test.

In view of the higher pressures applied during the system hydro-static test, it represents a more severe test than the system pressure tests which are required by the Code; therefore, perfor-mance of the system hydrostatic test would make performance of the system pressure test redundant and unnecessary.

Evaluation The Code does not appear to preclude performing a system pressure test at hydrostatic test pressure or temperatures.

Therefore, a hydrostatic test can be recorded as both of the -

code required tests while being performed once. Component functional tests car. be performed at lower pressures during the hydrostatic test performance. Relief from Code require-ments is not necessary.

Conclusions and Recommendations Since a hydrostatic test fulfills the requirements of the Code for the other pressure tests, it can be used to record the results of those tests also, while being performed once. There-fore, the licensee's proposed substitution meets the intent of the Code, and relief from Code requirements is not necessary.

References Reference 12.

l l

B. Class 1 System Pressure Tests No relief requests.

C. Class 2 System Pressure Tests No relief requests.

D. Class 3 System Pressure Tests No relief requests.

e 9

e

V. GENERAL

1. Volumetric Examination Methods, Class-1 and 2, Items B5.50, B9.12, B9.31, C5.21,and C5.22 Code Requirements T

. IWA-2232(b): Ultrasonic examination of Class 1 and Class 2 ferritic steel p'iping systems shall be conducted in accordance with Appendix III, amended as follows: (1) .For examination of welds, reflectors that produce a response greater than 50" of the reference level shall be recorded.

i Code Relief Request

< It is requested that relief be granted from the provisions of IWA-2232 with respect to calibration block design and cali-

• bration procedures, and that the provisions of the two Code applicability statements be substituted in lieu thereof (see attachment to this report).

i Licensee's Basis for Requesting Relief ASME B&PV Code Section XI, 1977 Edition, with addenda through

! Sumer 1978, Paragraph IWA-2232(b) requires the utilization of Appendix III,Section XI for ultrasonic examinations of piping. '

Appendix III, Paragraph III-1100(d) pennits the utilization of alternative examination techniques and calibration block design

in accordance with IWA-2240 (Alternative Examinations). Con-sumers Power Company elects to utilize hole-type reflectors in i lieu of notch reflectors required by Paragraph III-3430 for ultra-I sonic examinations performed on piping thicker than 0.400-inch.

[

In order to effect the change in reflector type, the licensee elects, per IWA-2232, to conduct ultrasonic examinations of piping

. welds in accordance with Article 5,Section V,' ASME Code. The requirements of Article 5,Section V will be' modified by the attached Code' applicability statements.

Utilization of hole-type reflectors for material thicker than 0.400-inch in lieu of notch-type reflectors will increase the sen-sitivity of the examination by a factor of two over the standard 45-degree angle beam examination. The licensee will implement the two Code applicability statements attached in order to effect this change in reflectors. The Code applicability statements will en-hance procedure and calibration control and control of calibration block procurement fabrication.

-Evaluation Section XI, Appendix III, Paragraph III-1100(d) does allow

' alternate examination techniques and calibration block design in accordance with IWA-2240. The alternate methods are to be approved

, by NRC. 'The licensee wishes to substitute side-drilled holes as reflectors in their calibration blocks in lieu of the notch reflectors required by Appendix III,Section XI. The licensee has requested permission to follow Article 5 Section V, includ-ing only up to the Sumer 1978 Addenda. The Winter 1978 Addenda to Section V, however,. requires notches as part of the calibra-tion block. ASME, in the Winter 1978 Addenda, recognized in both Section V and Section XI the value of using notches for angle beam calibration reflectors.

Calibration notches provide calibration signals that closely approximate the signals produced by stress corrosion cracks, lack of penetration, or other discontinuities found normal to the sur-

~ face of the metal. Side drilled holes used for calibration purposes produce reference signals of less amplitude and markedly differing frequency response. This infonnation was recently

,y -

presented in a technical paper, " Discrimination Between Defect Echo and Dissimilar Metal Boundary Echo with Ultrasonic Frequency l.

j Analysis",S.Sugiyama(5). K Suzuki,andA.Hosoda, Materials -

' ~

Evaluation, June 1982.

1*- ~ This paper compares the frequency, spectra, and the echo 6 amplitude from a side drilled hole, a slit representing a stress i corrosion crack and a weld representing a dissimilar nietal boun-dary. The parent metal tested was Stainless Steel Type 304 and the weld was Type 304L. At 2.25 MHz, the amplitude of the re-flected signal from the notch was about two times the amplitude

!' of the side drilled hole, but it was very difficult to differ-entiate between a 5-m side drilled hole and the weld boundary.

The amplitudes of the reflected signals were almost identical.

lbN -

It would be impractical to consider other comonly used I frequencies. At 5 MHz the amplitude of the reflected signal i from the side drilled hole was more than three times the ampli-

1. tude of a dissimilar metal boundary, but the reflection ampli-

[ tude from a slit representing a crack was only one-third the amplitude of a reflection of a side drilled hole and all -

sensitivity for cracks was lost. y The conditions .just described are specific to comonly used Stainless Steel Type 304 welded with 304L. Many other dissimilar metal bonds likely will show boundary reflections of greater or lesser amplitude.

Several interpretations can result when a UT system is calibrated to a side drilled hole. For example, a pip with

- a 100% of DAC amplitude could represent:

(l) an indication of a discontinuity that might have only one-half the reflective surface of what is defined as a relevant discontinuity; l

(-

t .

(2) a reflection from a dissimilar metal boundary; (3) a round indication approximating the side drilled hole to which the system was calibrated.

Condition (1) approximates a relevant indication, but the increased sensitivity would lead to the recording and subsequent historical accounting of many non-relevant indications.

Conditions (2) and (3) represent confusing non-relevant indications that would lead to the recording and historical accounting of non-relevant data.

The added inspection and book work would tend to increase both manhours and man-rem with, most likely, less reliable information being accrued.

'. ASME Section XI, Appendix III criteria should be used. The only justification for constructing new calibration blocks in ac-cordance with ASME Section V, Article 5, addenda through Summer -

1978, is that many inspectors prefer to calibrate to procedures

, and blocks with which they are familiar. It is possible that existing inspectors within the licensee's organization are able to adjust for the errors introduced in using side-drilled hole calibration blocks. Future inspectors likely will not be so experienced.

. Calibration blocks with hole reflectors have been shown to produce less reliable data during UT examinations than those using notch-type reflectors. For this reason, the most recent Code requirements have deliberately specified notch reflectors in favor of side drilled hole-type reflectors for calibration 4

blocks.

16 Conclusions and Reconnendations Based on the above evaluation, it is concluded that there is not enough justification for declaring the Code requirements im-practical. Therefore, the following is rec'ommended:

Relief from the IWA-2232 requirements should not be granted.

The licensee should base his UT examination program upon the pro-visions of IWA-2232 (hence, Appendix III for piping whose thickness is 0.2 inch to 6 inches) with respect to calibration block design and calibration procedure.

References ,

References 5 and 12.

t

REFERENCES

1. NUREG-0313, Rev. 1, Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping, C. Y. Cheng et al, October 1979. ,

2. NUREG-0569, Evaluation of the Integrity of SEP Reactor Vessels, K., G. Hoge, December 1979.

3. T. C. Bordine (CPC) to D. M. Crutchfield (NRC), May 3, 1982; includes re-vised 1st Interval ISI Program.

4. D. J. VandeWalle (CPC) to D. M. Crutchfield (NRC), May 28, 1982; response to NUREG-0313.

. 5. S. Sugiyama, K. Suzuki, and A. Hosoda, " Discrimination Between Defect Echo and Dissimilar Metal Boundary Echo with Ultrasonic Frequency Analysis",

Materials Evaluation, June 1982.

6. D. J. VandeWalle (CPC) to D. M. Crutchfield (NRC), September 3,1982; Additional' relief requested for 1st interval.

7. Science Applications. Inc., Big Rock Point Nuclear Power Plant, Inservice Inspection Program, Technical Evaluation Report, 186-028-10, September 17, 1982, t

8. D. M. Crutchfield (NRC) to D. J. VandeWalle (CPC), SEP Topic V-4, December 30, 1982.

9. T. C. Bordine (CPC) D. M. Crutchfield (NRC), May 16, 1983; additional

^

relief requested for 1st interval.

I

' D. M. Crutchfield (NRC) to D. J. VandeWalle (CPC), June 10, 1983; Safety 10.

Evaluation Report on 1st Interval.

s

11. D. J. VandeWalle (CPC) to J. G. Keppler (NRC), Novem,ber 21, 1983; Special Report No. 32, 1983 ISI.

12. D. J. VandeWalle (CPC) to D. M. Crutchfield (NRC), December 19, 1983; ISI Program for 2nd Interval.

13, D. M. Crutchfield (NRC) to D. J. VandeWalle (CPC), April 13, 1984;

- Request for Additional Information on 2nd Interval Program.

14. R. M. Krich (CPC) to D. M. Crutchfield (NRC), May 14, 1984; Response to RAI and Amended Relief Request for 2nd Interval. ,

15. Informal Communication with EPRI NDE Center, Charlotte, N.C., June 6,1984.

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Attachment i

, CONSUMERS POWER COMPANY

, CODE APPLICABILITY STATEMENT 1

Subject:

Piping Examination -

I. The basic requirements for ultrasonic examination of piping shall be in accordance with the following:

l Type of Material Nominal Thickness Applicable Code Austenitic and fer- Greater than 0.4 Article 5 of ASME Section V ritic piping and to 6 inches with Addenda through dissimilar metal Sumer 1978 welds Austenitic and fer- 0.1 to 0.4 inches Appendix III w/ Supplement 7

.ritic piping and of ASME Section XI, Addenda

'. dissimilar metal welds through Sumer 1978 II. The following modifications of the requirements of Article 5,Section V,

-and Appendix III,Section XI, 77S78 Addenda are applicable.

A. The following Code Cases shall be utilized:

1. Code Case N-211, Recalibration of Ultrasonic Equipment Upon

, Change of Personnel

2. Code Case N-234. Time Between Ultrasonic Calibration Checks,Section XI, Division 1 to

3. Code Case N-235, Ultrasonic Calibration Checks per Section V,

.j Section XI, Division 1.

B. For examinations conducted in accordance with At ticle 5 of ASME Section V, the basic calibration block for production material thickness 1.0 in. or less shall be as follows: The basic calibration block shall have the same nominal thickness as the production material or no more than 25% less than the nominal production material thick- '

ness or closer in thickness to the production material than the 3/4-in.

alternate thickness allowed by Article 5. This modification will assure a more accurate calibration than the basic calibration block design allowed by the Code.

! C. Subparagraph T-535.1(d)(1) and (2) of Article 5 requires that transfer i

(attenuation compensation) be accomplished between the production material and the basic calibration block and a correction made for the difference. In accordance with Code Interpretation V-78-01 and Case 1698 (N-92), the transfer method will not be used. Attenuation measurements will be recorded and considered during analysis and evaluation of indications; however, no attempt will be made by the examiner to compensate for any observed difference before or during the ultrasonic examination.

h l

h

i e

D/ For examination conducted on welds, the following requirements from  !

. Appendix III,Section XI, 77S78, shall be used in lieu of Paragraph T-530,Section V, 77S78.

111-2300, Written Procedure Requirements  ;

l 111-2400, General Examination Requirements 111-3100, Instrument Calibration (to include Supplements 5 'and 6)

III-3210, System Calibration - General Requirements III-3300, Calibration Confirmation III-3500, Calibration Data Record 111-4000, Examination. '

Data shall be recorded as per IWA-2232(b).

E.

CONSUMERS POWER COMPANY CODE APPLICABILITY STATEMENT 2

Subject:

UT Piping Calibration Blocks I. All new piping ultrasonic' calibration blocks will be procured, designed, -

and fabricated, as follows:

._ A. Material t Basic calibration block material shall conform to the requirements of Paragraph III-3411,Section XI.

B. Radius of Curvature Basic calibration blocks shall conform to the radius of curvature required by Paragraph 111-3410,Section XI.

C. Thickness Basic calibration blocks shall conform to the requirements of Paragraph III-3410.

D. Calibration Reflectors

1. Thickness: .10 inches to .40 inches: Calibration reflectors shall conform to the requirements of Paragraph III-3430,Section XI.

2. Thickness: Greater than .4 inches to 6 inches: Calibration ref-lectors shall be holes and shall conform to the requirements of Paragraph T-533(a), Article 5,Section V, 77S78, ASME B8PV Code.

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