ML20155F814
| ML20155F814 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 02/28/1986 |
| From: | SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY |
| To: | NRC |
| Shared Package | |
| ML20155F819 | List: |
| References | |
| SAIC-84-1662, NUDOCS 8604240519 | |
| Download: ML20155F814 (31) | |
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SAIC Report No. SAIC-81/1662 4 TECHNICAL EVALUATION REPORT SECOND INTERVAL INSERVICE INSPECTION PROGRAM HADDAM NECK PLANT i l Submitted to
, U. S. Nuclear Regulatory Commission Contract No. 03-83-096 l
Submitted by Science Applications International Corporation Idaho Falls, Idaho 83402 l February 1986
~ l
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CONTENTS 1 INTRODU CTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 I. CLASS 1 COMPONENTS
......................... 3 A. Reactor Yessel (no relief requests) . . . . . . . . . . . . . . .
l 3 i B. Pressurizer .......................... 3
- 1. l j
Relief Request 1-2 (Note 2), Pressurizer Noszle Inside Radius i i Section, Category B-D, Ites B3.120. . . . . . . . . . . . . . 3 l ) C. Heat Exchanger and Steam Generators ............ .. 5
- 1. Relief Request 1-4 (Note 4), Regenerative Heat Exchanger Welds, s
)
Category B-B, Items B2.51, B2.52, and B2.60 . . . . . . . . . 5 i 1 j 2. Relief Request 1-2 (Note 2), Steam Generator Nozzle Inside Radius Section, Category B-D, Iten B3 140 . . . . . . . . . . ,7 i 3 Relief Request 1-5 (Note 5), Regenerative Heat Exchanger i Nozzle-to-7essel Welds, Category B-D, Items B3.150. . . . . . 9 D. Piping Pressure Boundary .................... 10
- 1. Relier Request 1-3 (Note 3), Steam Generator Nozzle-to-Safe-End
- Welds, Category B-F, Item B5 30 . . . . . . . . . . . . . . . to 2.
Relief Request 1-0, Piping Pressure Boundary Welds, 1 Category B-J, Items B9.10, B9.20, B9 30, and B9.40 ..... 12
- E. Pump Pressure Boundary
...... ............... 14
- 1. Relief Request 1-8 (Note 8), Pump Bo) ting, Ca tegory B-C-1, B6 .180. . . . . . . . . . . . . . . . . . . . 14 .
1 1
- 2.
I Relief Request 1-7 (Note 7), Reactor Coolant Pump Pressure l Boundary, Categories B-L-1 and B-L-2, Items B12.10 and B12.20 . . . . . . . . . . . . . . .'. . . . . ... ..... 16 F. Valve Pressure Boundary . . . . . . . . . . . . . . . . . . . . . 20
- 1. Relief Request 1-8 (Note 8), Yalve Bolting, Category B-G-1, Iteu B6.210 ...... ............. ..... 20 i
i II. CLASS 2 COMPONENTS ... ................ ... . . 22 A. Pressure Vessels and Heat Exchangers ... . .... . . .. . . 22
- 1. Relief Request 2-1 (Note 1), Steam Generator Shell Side Nozzle Inside Radius, Category C-B, Ites C2.22 . . . . . . . . . . . 22
-i-
CONTENTS (Cont'd) B. Piping (no relief requests) . . . . '. . . . . . . . . . . . . . . 24 C. Pumps (no relief requests) ................... 24 1 D. Valves (no relief requests) . . . . . . . . . . . . . . . . . . . 24 i III. CLASS 3 COMPONENTS (no relief requests) .............. 24 IV. PRESSURE TESTS
........................... 24 i
- 1. Relief Request P-1, Pressure Test Below Code-Required Pressure, Category C-H, Items C7 20 and C7.21 . . . . . . . . . . . . . 24 i
REFERENCES i ............................... 27 t 1 O I
-ii-
._. . _ . . . . __ . . - _. __ _ . _ _~ _ . _ _
TECHNICAL EVaf-UATION REPORT SECOND INTERVAL INSERVICE INSPECTION PROGRAM HADDAM NECK PLANT ] INTRODUCTION This report evaluates requests for relief from certain requirements of Section II of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code
- by the licensee, Connecticut Yankee Atomic Power Company (CTAPCO), for the Haddam Neck Plant (HNP). The relief requests cover the third period, starting January 1,1985, of the second 120-month inspection interval which began January 1,1978.** The requests are based upon the 1980 Edition of Section II, with addenda through the Winter of 1980, as specified in the applicable I
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 for the second internal, and (c) the - i history of HNP since the earlier review. t The current revision to 10 CFR 50.55a requires that Inservice Inspection (ISI) programs be updated each 120 months to meet the requirements of never editions of Section XI. Specifically, each program is to meet the requirements (to the extent practical) of the edition and addenda of the Code incorporated l in the regulation by reference in paragraph (b) 12 months prior to the start of the current 120 month interval. i I The regulation recognizes that the requirements of the later editions and i addenda of the Code might not be practical to implement at facilities because j of limitations of design, gecaetry, and materials of construction of components and systems. It, therefore, permits exceptions to impractical examination or testing requirements to be evaluated. Relief from these requirements can be j granted pr;vided the health and safety of the public are not endangered, giving due consideration to the burden placed on the licensee if the requirassents 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. t ' Finally, Section II of the Code provides for certain components and systems to be exempted from its requirements. In some instances, these exemptions are } not acceptable to the Nuclear Regulatory Commission (NRC) or are only acceptable ] with restrictions. As appropriate, these instances are also discussed in this i report.
- Hereinafter referred to as Section XI or Code.
**A start date of January 1,1985 for the third period reduces the d the period from 40 to 36 months.. uration of 1
4 .
. . . _ _ . , _ _ . , _ _ _ _ . _ . _ . . . _ _ _ _ _ _ , _ _ _ _ _ _ _ _ . - ._..-_______,___,__._,_-_,,,,..._s._, _ _ _ . _ , _ _ - , . . . _ . - - _ _ .
_~ - . . . l . l The Haddam Neck Plant began commercial operation in January 1968. Since Section II of the ASME code had not been published at that time, ISI on the Haddas Neck Plant was governed by Section 4.0 of the Technical Specifications. Following acceptance of ASME Section XI by the NRC, the licensee, in accordance with direction from NRC, requested a change to the Technical 3 ification and submitted a proposed Inservice Inspection and Testing Program A subsequent f letter from the licensee dated May 26,19T8,( ' provided revisions to the ISI Program and relief requests. As a result of a meeting between CTAPCO and the ; staff on January 17-19, 1979, the licensee submitted further information i additional revisions of the ISI Progr ) i June 29,1979,W and March 25, 1980. )inThe letters of April 27, 1979, ISI Program encompassed in j References 1-5 was evaluated by the staff, and the Safety Evgtion Report w issued February 26, 1981, as an attachment in Amendment No. 37 to the facility ! operating license. The licensee requested an extension of temporary relief fron j l reactor coolant pump examinations in References 5 and 7 and permanent relief j j from these examinations for the cond interval in Reference 6. The requested relief was subsequently granted. ' Accordingly, the licensee, CTAPC0, has on 3 record an approved ISI Program for the Haddas Neck Plant covering the second n inspection interval that began January 1,1978, and ends January 1,1988. Subsequent to approval of the ISI program, the utility elected to update the program to the 1980 Edition of the Code with addenda through Winter 1980. l The updated program was submitted April 9,1984, for staff review and approval { in Reference 10 and is intended to apply to the third period of the second i interval that began January 1,1985. The requests for relief contained in the April 9,1984, submittal are l reviewed in this report. The relief requests were neither complete nor clearly i stated in this submittal. In scoe instances, - the licensee referred to previous relief requests for which staff approval had been granted. We have interpreted f 1 that CTAPCO is requesting relief in 11 specific areas in the April 9,1984, submittal, and the following paragraphs address these relief requests. I 4 The requested relief has been granted in all instances where sufficient information has been provided. The predominate reasons for granting relief have j been the unavailability of suitable inspection equipment and high radiation ) exposure to inspection personnel if the examinations were attempted. i The technology of volumetric testing is changing rapidly, and significant improvements can be expected in the future. It is clearly incumbent on the licensee to keep up with and use volumetric examination tools that are among the most up-to-date commercially available to maximize the quality of examination ! results. In addition,. the licensee should document the radiation levels and estimate precisely the exposure to personnel conducting examinations for consideration of alternate examinations consistent with ALAR A in subsequent
- intervals.
i- . . 2
, I. CLASS 1 COMPONENTS A. Reactor Vessel No relief requests. .
B. Pressurizer 1. Relief Raouest 1-2 (Note 2) Pressurizer Norrie Inside Radius Section. Caterory B-D. Item B"L 120 Code Recuirement All nozzle-to-vessel welds and inside radius sections in the pressurizer shall be volumetrically examined in accordance with Figures IVB-2500-7(a) through (d) during the second interval of operation. The nozzle-to-vessel weld and adjacent areas of the nozzle and vessel are included. Code Relief Recuest Relief is requested from volumetric examination of the nozzle inside radius section of the pressurizer nozzles. Procesed Alternative Framination ! None. Licensee's Basis for Recuestina Relief No acceptable ultrasonic inspection technique is presently available to perform completely the nozzle inner radius evamination from the outer surface (Reference NUREG-0619). Present ultrasonic techniques are not capable of accurately and repeatedly characterizing flaws and quantifying their size from the exterior. Up to the present time, the only effective examination of this area is a surface examination. However, very limited stay times due to radiation in the area of the primary nozzles of the pressurizer and steam generator preclude this examination without extensive decontamination. Connecticut Yankee will continue to defer the inner radius examination on the steam generators and pressurizer until such ultrasonic techniques for this examination are available and acceptable for use. _, , , 3- _ _ - .- - - - - - - -- -
, Evaluation Meaningful volumetric examination of the nozzle inside radius I
section from the external surf ace is difficult
- with existing inspection equipment. Typical nozzle configurations involve different radii of curvature on the inside and outside surfaces in the transition region where the inside radius section is to be
[ examined. Changes in section thickness are also typical in this i region. These gecanetry factors cause the attenuation and redirection j of ultrasonic signals and result in unreliable interpretation of 4 examination data. Current radiographic methods are also of little use in detecting fine surface cracks on the inside radius of nozzles. 1
}
Saface examination of the inside radius is a useful alternative aethod. This method, however, must be performed from inside of f{ the vessel where radiation exposure to inspection personnel beocess i a factor. ' l The Haddaa Neck Plant has been operating since 1%8, and thus, the design of the plant was completed before ASDE Section XI was in use. Accordingly, the nozzle sections were not designed for external examination of the inside radius using ultrasonic i methods. The many years of operation have also undoubtedly resulted j in significant radiation levels in the pressurizer. The licensee j - has not specified the current radiation levels but has indicated
) that extensive decontamination would be required to bring the levels down such that exposure to inspectors woulit be acceptable.
} Based on the difficulty of conducting volumetric e==inations f of the inside radius section with currently svailable volumetric j equipment, the potentially high radiation exposure to examination
} personnel that would result from alternative methods, and the l {
short time lef t in the examination interval, relief should be ! granted. i I 4 j Visual examination (VT-2) of the nozzles should be conducted during Code-required pressure tests. Conclusions and Recommandations i i Based on the above evaluation, it is concluded that for_the l areas discussed above, adherence to the Code requirements is impractical. It is further concluded that the proposed examinations " i will provide necessary assurance of structural reliability during 1 j
this interval. Therefore, relief is recommended as requested provided visual examination (VT-2) of the nozzles is conducted during the Code-required system pressure tests performed. Reference . Reference 10. C. Heat Exchangers and Steam Generators
- 1. Belief Renuest No. 1-4. (Note 4). Regenerative Heat Exchanaer Welds. Caterory B-B.
Items B2.91. B2.52. and B2.60 Code Recuirement One circumferential shell (or head) weld in the primary side of the heat e*= nears shall be voltmetrically examined in accordance with Figures IW-2500-1 and'-3 over essentially 100% of its length during the second inspection interval. . I During the second inspection interval, one longitudinal weld in the primary side of the heat exchangers shall be voltaetrically examined in accordance with Figures IVB-2500-2 and -3 over one foot of its length at the intersection with the circumferential
' weld selected for examination. The examinations may be limited to one vessel among the group of vessels performing similar functions.
The tubesheet-to-shell (or head) weld shall be voltmetrically examined in accordance with Figure IVB-2500-6 over essentially 100% of its length during the interval. _ Code Relief Recuest Relief is requested from examination of primary side vessel welds on the regenerative heat exchangers. Procosed Alternative Ernmination The licensee has proposed a visual examination during the j Code-required system leakage and system hydrostatic tests. l licensee Basis for Recuestina Relier j Radiation in the vicinity of the regenerative heat exchanger ) was measured at 9R to 12R during the 1983 outage. CYAPCO has t 5_ _ __
determined that the time needed for the Code-required volumetric examination of the head-to-shell and head-to-tubesheet welds is approximately 40 minutes for each. If indications required mapping and evaluation, much additional time would be required. The 40-minute examination would subject the examiner to an exposure of approximately 6R. In addition to the examiner, personnel are required to remove and reinstall insulation, clean the welds, and to perform a surface examination. There are no connections to enable these heat exchangers to be flushed to lower the radiation levels. In accordance with Regulatory Guides 8.8 and 8.10, CYAPCO requests relief from the Code-required examinations and proposes that a visual examination be made during the system leakage and system hydrostatic tests. Evaluation Measured radiation levels on the Haddam Neck regenerative heat exchangers are from 9-12R and would result in significant personwl radiation exposure if the required ISI examinations were implemented. The licensee has estimated that at least 40 minutes wculd b'e required to conduct the examination of each weld and that additional exposure to personnel would be accumulated during related operations, i.e. , insulation removal and reinstallation, weld cleanup, etc. Relief frca these examinations is justified since the estimated radiation exposure is excessive. The alternate visual examinations (VT-2) during system leakage and hydrostatic tests should provide adequate assurance of structural reliability. Conclusions and Recommandations I i 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 examinations discussed above will provide necessary added assurance of structural i reliability. Therefore, relief is recommended as requested provided the proposed visual examinations (VT-2) are performed in conjunction with Code-required pressure tests. . Reference Reference 10. n
2. Relier Recuest 1-2 (Note 2). Steam Generator Monte inside Raritus Section. Catererv B-D. Item B1.140 Code Recuirement All nozzle-to-vessel welds and inside radius sections in the primary side of the steam generator shall be volumetrically examined in accordance with Figures IWB-2500-7(a) through (d) during the second interval of operation. The nozzle-to-vessel weld and adjacent areas of the nozzle and vessel are included. Code Relief Recuest Relief is requested from volumetric examination of the nozzle inside radius section of the steam generator primary nozzles. frocosed Alternative Ermaination \ None. . Licensee's Basis for Recuestina Relief No acceptable ultrasonic inspection technique is presently available to perform completely the nozzle inner radius examination from the outer surface (Reference NUREG-0619). Present ultrasonic techniques are not carable of accurately and repeatedly characterizing flaws and quantifying their size from the exterior. Up to the present time, the only effective examination of thic area is a surface examination. However, very limited stay times due to radiation in the area of the primary nozzles of the pressurizer and steam generator preclude this examination without extensive decontamination. . Connecticut Yankee will continue to defer the inner radius examination on the steam generators and pressurizer until such ultrasonic techniques for this examination are available and acceptable for use. 1 Evaluation , l Meaningful volumetric examination of the nozzle inside radius section from the external surface is difficult with existing inspection equipment. Typical nozzle configurations involve i
.different radii of curvature on the inside and outside surf aces i I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _E i
in the transition region where the inside radius section is to be examined. Changes in section thickness are also ' typical in this region. These geometry factors cause the attenuation and redirection of ultrasonic signals and result in unreliable interpretation of examination data. Current radiographic methods ~ are also of little use in detecting fine surface cracks on the inside radius of nozzles. Surface examination of the inside radius is a useful alternate method. This method, however, must be performed from inside of j the vessel where radiation exposure to the inspector becomes a factor. The Haddam Neck Plant has been operating since 1968. The design of the plant was completed before ASME Section XI was in use. Accordingly, the nozzle sections were not designed for external examination of the inside radius using ultrasonic methods. The many years of operation have also undoubtedly resulted in significant radiation levels in the steam generator. The licensee has not specified the current radiation levels but has indicated that extensive decontamination would be required to bring the levels down such that exposure to inspectors would be acceptable. Based on the difficulty of conducting volumetric ermminations of the inside radius section with currently available volumetric equipment, the potentially high radiation exposure to examination personnel that would result from alternate methods, and the short time left in the examination interval, relief should be granted. , Visual examination of the nozzles should be conducted during Code-required pressure tests.
\
_ Conclusions and Recommendations Based on the above evaluation, it is concluded that for the areas discussed above, adherence to the Code requirements is impractical. It is further concluded that the recommended examinations will provide necessary assurance of structural l reliability during this interval. Therefore, relief is recommended as requested provided visual examination of the nozzles is conducted during the Code-required system pressure tests performed. I References References 6 and 10. I 8
. 3 H*11er Haanast 1-9 fNote 91 ****n*rative Heat exchan2er- var,te-tuv&mi Welds. Category B-D. Items B't.150
. Code Recuirement All nozzle-to-vessel welds and inside radius sections in the primary side of the heat exchanger shall be volunetrically examined in accordance with Figures IWB-2700-7(a) through (d) during the second interval of operation.
The nozzle-to-vessel weld and adjacent areas of the nozzle and vessel are included. Code Relief Recuest Relief is requested from volumetric examination of the nozzle-to-vessel welds on the regenerative heat exchanger. ProDosed Alternate Ermaination A visus.1 examination of the nozzles during the Code-required system leakage and hydrostatic tests is proposed. Licensee Basis for Recuestina Relief The reinforcing collar on the nozzle-to-vessel weld precludes volumetric examination. High radiation also precludes a surface examination. As explained in Relief Request 1-4 above, CYAPCO requests relief from the Code-required examination and proposes that a visual examination be made during the system leakage and system hydrostatic tests. Evaluation Vessel nozzle configurations that include a reinforcing collar i are typically unsuitable for examination by volumetric methods. i The licen.*ee did not provide a detailed drawing of the nozzle configuration on the Haddam Neck regenerative heat exchanges but did state that the reinforcing collar precluded volumetrio l examination. Accordingly, we have concluded that the configuration is typical of reinforced nozzle configurations and that volumetric examination is impractical. Surface examination is normally used as an alternate for voltaetric examination for reinforced nozzle installations, hcuever, the licensee has stated that high radiation also precludes surface j examination.
)
9
As a minimum, visual examination of the nozzles should be conducted during the Code-required system leakage and hydrostatic tests. l - Conclusions and Reen==endations Based on the above evaluation, it is concluded that for the volumetric examinations discussed above, the Code requirements are lapractical. It is further concluded that the alternative examinations discussed above will provide necessary added assurance of structural reliability. Therefore, relief should be, granted from the required volumetric exasinations of the subject nozzles, provided the proposed visual examinations (VT-2) are performed in conjunction with Code-required pressure tests. References References 6 and 10. D. Pipir.g Pressure Boundary 1 1. Relief Recuest 1-1 (Note 1). Steam Generator No 21e-t o-Sa fe-End Welds. Category B-F. Item B81.10 Code Recuirement i All nozzle-to-safe-end butt welds in nominal pipe size greater than 4 inches in the steam generator shall be surface and volumetrically examined in accordance with Figure IWB-2500-8 during the second inspection interval. Dissimilar metal welds between combinations of (a) carbon or low alloy steels to high alloy steels, (b) carbon or low alloy steeis to high nickel alloys, and (c) high alloy steels to high nickel alloys are included. l Code Relief Recuest Relief is requested f rom volumetric examination of 100% coverage of the Code-required volume on the steam generator nozzle-to-safe-end welds. I Procesed titernative Enminalig None, except the Code-required surfaco examinations will be conducted. 9 61 I
Licensee's Basis for Reouestina Relief Due to the geometry of the eight (8) steam generators nozzle-to-safe-end weld, only approximately 60% of each nozzle to safe end can be volumetrically examined. The carbon steel casting on one side and the safe-end forging on the other prevent full ultrasonic coverage from being performed. Surface examination of the weld will be performed as required by Code. The safety evaluation accompanying Amendment 37 to the license of the Haddam Neck Plant granted relief from the 100% volumetric examination. Evaluation In previous considerations of the relief n! quest, the licensee provided a drawing illustrating the geometric configuration of the safe-end-forging-to-pipe weld and the volume of coverage possible with ultrasonic examination. A total of 60% of the examination volume can be inspected. All the inside surface of
' the weld adjacent base metal will be examined. This is the location at which most flaws would be expected to develop inservice.
De licensee has committed to conducting the Code-required surface examination of the areas. Flaws originating on the 0.D. will be detected by this examination.
~
Conclusions and Reen===ndations Based on the above evaluation, it is concluded that for the welds discussed above, adherence to the Code requirements is impractical. It is further concluded that the proposed examinations will provide necessary assurance of structural reliability during this interval. Therefore, relief is recommended as requested provided i
- a. !
the volumetric examinations are performed to the maximum l extent practical and i
- b. the Code-niquired surface examinations and system pressure j tests are performed.
l l References References 6 and 10. l l 1 1
, 11
- 2. Relier Recuest 1-0. Pinina Pressure Boundarv Welds. Category B-J.
Itema B9.10. B9.20. B9.10. and B9.40. (Items B4.5. B4.6. B4.7. and B4. 8 in 1974 S79 ) . Code Recuirement As permitted by 10 CFR 50.55a(b) (2)(11), the licensee has elected to determine the extent of examination for Class 1 pipir4 by the requirements of Table IWB-2500 and Table IWB-2600, Category B-J of Section II of the ASME Code 1974 Edition with Addenda through the Summer of 1975. This Code version requires examination of longitudinal and circumferential welds and base metal for one wall thickness beyond the edge of the weld. Longitudinal welds shall be examined for at least 1 ft free the intersection with the edge of the circumferential weld selected for examination. For pipe branch connections, the areas shall include the weld metal, the base metal for one pipe wall thickness beyond the edge of the weld on the main pipe run, and at least 2 in, of the base metal along the branch run. The examinations performed during each inspection interval shall cover all of the area of 25% of the circumferential joints including the adjoining 1 ft sections of longitudinal joints and 25% of the pipe branch connection joints. A different 255 is to be examined each interval. The 1980 WC0 Code requires a voltmetric and surface examination in accordance with Figure IWB-2500-8 of longitudinal and circumferential welds in pipes 4 in. or larger. For pipes analler than 4 in. , only a surface examination is required. For branch connection welds in pipe 4 in. or larger, a surface and voltnetric examination is required in accordance with Figures IWB-2500-9, l , -10, and -11. For pipes smaller than 4 in. , only a surface examination is required. For socket welds, a surface examination in accordance with Figure IWB-2500-8 is required. Code Relief Recuest The licensee has indicated that the examination of piping welds will be conducted to the extent practical in cases where piping geometry or supports interfere with examinations. Procored Alternative Examination
- None, o
12
__ _- ._. m . _ __ - . . _ _ _ _ . _ _ _ _ . _ _ _ _ _____ ____ _ _ . . _ _ _ _ . __ __ 1 ...
. Licensee's Ramin for Renummtinn Reiter 1
j
' With respect to the examination of piping system welds during the ten-year inspection interval, the inspection schedules contain l reference to specifically identified welds. These have been identified by reference to pipeline and the allotted weld designation f
given on the system isometric sketches. The welds chosen for examination are selectively distributed within the systes boundaries and may be changed at the discretion of the plant operating and maintenance personnel. The arrangements and details of the piping systems and ' components are such that some examinations are limited due to geometric configuration or accessibility. Additionally, the $; arrangements and details of the Class 1 piping systems and components were designed and fabricated before the examination requirements [ of Section XI of the Code were formalized, and, again, some j examinations are limited or not practical due to geometric j configuration or accessibility. Generally, these limitations I exist at all fitting-t> fitting welds such as elbow to tee, elbow to valve, reducer to valve, etc., where geometry and sometimes
! surface conditions preclude ultrasonic coupling or access for the '
required scan length. The limitations exist to a lesser degree 3 at pipe to fitting welds, where examination can only be fully 1 - performed from the pipe side, the fitting geometry limiting or i even precluding examination from the opposite side. No effort has been made to identify individual welds in the ten-year plan i ){ where such restrictions exist. Welds having such restrictions ' i, will be examined to the extent practical. i i In instances where the location of pipe supports or hangers l a restrict the access available for the examination of pipe welds, examinations will be performed to the extent practical unless )' removal of the support is permissib1e' without unduly stressing the system.
; Evaluation 1
i a The licensee has stated that the welds selected for examination are selectively distributed among the systems. The licensee has I t further stated that the weld distribution may be changed at the ; discretion of plant operating and maintenance personnel. Certain 4 1 j changes in the distribution require that relief be approved, i.e., j 25% of all circuarerential welds and adjoining longitudinal welds aust be examined, and 25% of the branch connections must be examined. ! l 13
. The licensee anticipates that some welds selected for examination will be subjected to limited examinations due to
- geometric configuration, access or interference by supports. In
, these cases, the licensee has stated that the examinations will i
be conducted to the extent practical. The licensee should make every effort to select the required 255 sample for the second interval, thus minialzing the number of relief requests. i Relief approved by the staff is required where the distribution of areas examined is not in accordance with the Code. Approval
- is also required for examinations that cover less than the
- Code-required volume. The licensee has not provided sufficient i
information to evaluate the extent of relief required for piping
- examinations. Further, it is not the policy of the staff to grant blanket relief as indicated. Accordingly, no relief should be i granted at this time for piping examinations. The licensee should i provide a submittal detailing the specific relief required for
) staff review. l 4 Conclusions and Recommendations ) Based on the above evaluation, it is concluded that relief j should not be granted at this time. In order to obtain relief, j the licensee must submit
- a. an up-to-date list of Category B-J welds to be inspected d
and I
- b. specific information in the cases where relief is 4
required, which supports the determination that the requirement is impractical in accordance with the NRC guidance provided in Reference 11. l References l References 10 and 11. E. Pump Pressure Boundary
- 1. Relief Recuest 1-8 (Note 8). Pumn Boltina. Ca tegerv B-C-1. B6.180 {
I i Code Recuirement All bolts and studs larger than 2 inches in diameter in punps j shall be voltmetrically examined in accordance with FiEure IWB-2500-12 l l l j 14 .
during the second inspection interval. Bolting may be examined (a) in place under tension, (b) when the connection is disassembled, or (c) when the bolting is removed. Examinations may be performed - at or near the end of the inspection interval. Examinations are limited to bolts and studs on components selected for examination under Examination Categories B-B, B-J, B-L-1, and B-M-1, as applicable. Code Relief Recuest Relief is requested to eliminate volumetric examination of bolts and studs. Procosed Alternative Ernmination Surface examination of the bolts and studs will be conducted when the bolts and studs are removed. Licensee's Basis for Recuesting Relief Bolts and studs, when removed, may be surface examined in lieu of the code volumetric examination. Concurrence for this alternate examination was received from NRC in a telecom on i March 4,1983, between Bartron-Weyland (NUSCO) and G. Johnson, C. Cheng, and D. Sellers (NRC). Evaluation Ultrasonic testing of bolts and studs is an accepted means of examining for inservice flaws. Alterna tively, some experts believe that surface examination of bolts and studs when removed provides better results. The intent of th'e Code is that the bolting on at least one reactor coolant pump be examined each interval. Normally, the examinations of bolting are conducted on the same pump selected for ernmination under Category B-L-1. However, CYAPCO has requested and been granted relief from conducting pump inspections under Category B-L-1 (see Helier Request 1-7). Reller from examination under Category B-L-1 implies that a pump may not be disassembled to permit surface examination of the bolting. Relief should not be granted such that no examina tions of the pump bolting are conducted during the second interval. If the bolting is removed from a reactor coolant pump during the 15 .
- a. -
interval, surface examination of the bolting is an acceptable alternate for the Code required volumetric examination under Category B-G-1. If the bolting is not removed free a reactor coolant pump, volumetric examination of the bolting should be implemented in place, under tension as required under Category B-G-1. 4 Conclusions and Recommendations Based on the above evaluation, it is concluded that for the pump bolting discussed above, adherence to the Code requirements is impractical. It is further concluded that the proposed examinations will provide necessary assurance of structural reliability during this interval. Therefore, relief is reccannended as requested provided
- a. surface examinations are performed on the bolting removed from a pump and
- b. if the bolting is not removed from a ptap, the Code-required
, volumetric examination is conducted in place, under tension. Peterence r i Reference 10.
- 2. Relief Recuest 1-7 (Note 7). Reactor Coolant Pumo Pressure Boundary.
Categories B-L-1 and B-t-2. Items B12.10 and B12.20 Code Recuirement Pume Casing Welds. Item B12.10 1 Essentially 100% er the pressure-retainihg welds in at least one pump in each group of pumps performing similar functions in the system (e.g., recirculating coolant ptmps) shall be volumetrically examined in accordance with Figure IWB-2500-16 during each inspection interval. The examinations may be performed at or near the end of the inspection interval. Pumo Casings. Item B12.20 The internal surfaces of at least one pump in each group of ptaps performing similar functions in the system (e.g. , recirculating coolant pumps) shall be visually examined (VT-3) during each
m . . . .. . . . . .. inspection interval. The examination may be perfor1 sed on the same ptap selected for voltaetric examination of welds. The examinations may be performed at or near the end of the inspe,ction interval. _ Code Relief Recuest . Relief is requested from conducting the required primary reactor coolant pump examinations. frocosed Alternative Ernmination l The licensee has committed to conduct the required visual examinations if a pump is disassembled for maintenance or other ! reasons and evaluate the potential for conducting the volumetric
- examinations. A vibration monitoring system has been installed on the pumps, and addi.,tional vibration data have been taken to evaluate fatigue-related behavior. Visual examinations of the i
! ptap casings will be conducted during system leakage and hydrostatic tests. Licensee's Basis for Recuestine Relief CYAPCO evaluation has determined that the hardships that must be endured to perform this inspection are not justified on a technical basis for the following reasons: e The reactor coolant pump casing consists of four Type 316 stainless steel cast rings with minimum thickness of approximately eight inches. Considering - the stainless steel Type 316 characteristics and the water chemistry limitations for the reactor coolant system, the potential for any stress corrosion mechanism is considered to be negligible. e Thermal embrittlement is a function of ferrite content in duplex cast stainless steels. Connecticut Yankee's casing material is made of CF-Si (316 S. S. ) with a maximum ferrite content on the order of 15-25 percent, based on industry standards. Using EPRI data for cast austenitic stainless CF-8 (304 s. s.) and a maxista ferrite level of 25 percent for the specific CY CF-8M RCP casing, the minimum time required for thermal embrittlement to lower the Charpy-V-flotch toughness below 50 joules (37 ft.-lbs. ) is 36 years. Therefore, adequate fracture tou6hress will be retained over the lifetime of the plant, thereby eliminating potential nonductile fracture concerns. 17
e - Service--induced flaws woald more likely be generated 1 l from a cyclical loading mechanism such as fatigue. However, the pump bowl geometry as well as endurance limit of the given material make this a r:egligible Concern. The examination completed on four Westinghouse Model 93 pump casings have shown that no detectable interior service-induced flaws have occurred. The CYAPCO pumps are Westinghouse Model 63 pumps, which are a smaller and similar version of the Model 93 3 e Disassembly of _the. pump for instection could result in significant duage as the peps were designac 1 prior to ISI requirements and ease of disasseab,1y in the field was not part cf the design basis. j e Radiation levels will be very high, estimated at 60-80 rea/hr at the pump impeller prior to decontamination. Actual eard rsur for removal, cecontamination, storage radiop;raphy, replacecent, insulation, and general support at the three plants that have completed their pump examinations are as follows: ' Ginna - 93.071 Turkey Point - 43.67 ' Point Beach - 36.5 4 e At the Haddam Neck Plant, total exposures for this RCP examination considered probable.effort of 50-100 man-rea are The radiation exposure at ' the Haddam Neck Plant for ISI work in 1980 was 4 6.00 8 man-ree and in 1981 was 41.582 man-rea. The RCP casing examination, if conducted, would cause this figure to more than double, c. e The reactor coolant ptmps have performed satisfactorily at Haddas Neck Plant. No operational problems have been encountered which have required disassembly of a reactcr coolant pump. e The pump inspection is not justified f rom a ' cost / benefit. perspective? The pump: disassembly, inspection, and reassembly are estimated to cost
$500,000.
The- dollar value associated with the radiation exposure required to perform this work is $105,000 (50 man-rm valued at $2100 per man-rea). The dollar per man-rm value is based upon guidelines presented in NU Corporate ALARA Manual. The total examination cost is, therefore, in exce ss of
$600,000.
This cost is not justified in light of
~ "
18
.6 d the lack of improvement in safety provided by this examination. These costs exclude the expenditures associated with any unique decontamination process if a feasible proc 4ss is found to be available.
The imposition of this requirement will result in technical, financial hardships and unusual difficulties without a compensating increase in the level of quality or safety associated with the reactor coolant pumps. A vibration monitoring system has been installed on the reactor coolant pumps and is providing on-line monitoring of the pump's mechanical condition. In addition, more comprehensive vibration data are taken on all four reactor coolant ptmps prior to shutdown for refueling. We are, therefore, confident that a progressing mechanical malfunction will be detected before failure. In summary, confidence in the safe conditilon of the existing pssps, the significant radiation exposure, the potential of damaging pump components during disassembly and reassembly, the lack of l benefit to plant integrity, and the significant expense in both dollars and time have led CYAPCO to conclude that pump casing examinations as required by the ASME Code using existir4 techniques are not justifiable. Evaluation t Visual examination of the internal ptmp surfaces and volumetric examination of the pump casing welds are very extensive and costly efforts. Disassembly of the pumps for the internal examina tion has the potential to result in damage to the ptaps since they were { not designed for disassembly. The licensee has p ovided extensive ' detail above in this regard. In addition, the radiation exposure accumulated by examination personnel would be considerable. Volumetric examination of the pump casing welds is also considered impractical since, at present, suitable results can only be obtained using radiographic methods such as Minac or Linac. These methods require disassembly of the pump with the attendant risk of pump damage, as 'well as extensive personal radiation exposure accumulated during the disassembly. Surface examination of the external surface of the pump casing welds should be implemented as an alternate to volumetric examinations. The Haddam Neck primary coolant ptaps have operated satisfactcrily since installation, and plant conditions have not been such that stress corrosion, thermal e=brittlement or fatigue could be
~~
n., '
considered to have initiated flaws. Pump vibration is monitored routinely at the Haddam Neck Plant to assess fatigue failure mechanisms. Based on the impracticality of conducting the examina tions and the acceptable operating history of the pumps, relief should be granted free internal visual and volumetric examinations. '!he required examinations should be conducted, however, if a pump is disassembled for other reasons. Surface examination of the external surface of the pimp casing welds should be implemented. Vibration monitoring of the pimps should continue, and visual examinations (VT-2) of the pump casing should be conducted during system pressure tests. Conclusions and Reen===ndations Based on the above evaluation, it is concluded that for the examinations discussed above, adherence to the Code requirements is impractical. It is further concluded that the proposed examinations will provide necessary assurance of structural reliability during this interval. Therefore, relief is reccamended as requested provided
- a. vibration monitoring of the pumps is continued,
. b. surface examination of the external surface of the pump casing welds is implemented, i
- c. visual examination (VT-2) of the pump casing for leakage 1 is conducted in conjunction with system leakage and hydrostatic tests under Category B-P, and
- d. the required examinations are conducted under Categories B-L-1 and B-te2 if a reacter coolant pump is disassembled for maintenance.
References References 5, 6, 7, 8, 9, and 10. F. Valve Pressure Boundary
- 1. Relief Recuest 1-8 (Note 8). Valve Boltinc. Catecory B-G- 1. Item B6.210.
20
Code Recuirement All bolts and studs larger than 2 inches in diameter in valves shall be volumetrically examined in accordance with IWB-2500-12 during the first inspection interval. Bolting may be examined (a) in place under tension, (b) when the connection is disassembled, or (c) when the bolting is removed. Examinations may be perfonned at or near the end of the inspection interval. Examinations are limited to bolts and studs on components selected for examination under Examination Categories B-B, B-J, B-L-1, and B-M-1, as applicable. Code Relief Recuest Relief is requested to eliminate volumetric examination of bolts and studs. Procosed Alternative Ernmination Surface examination of the bolts and studs will be conducted when the bolts and studs are removed. Licensee's Basis for Recuestine Relief Bolts and studs, when removed, may be surf ace examined in lieu of the code volumetric examination. Concurrence for this alternate examination was received from NRC in telecom on March 4, 1983, between Bartron-Weyland (NUSCO) and G. Johnson, C. Chang and D. Sellers (NRC). Evaluation Ultrasonic testing of studs is an accepted means of examining for inservice flaws. However, some experts believe that surface examination of the studs when removed provides better results. Examination of valve bolting is limited to valves examined under Category B-M-1. Since the licensee has not requested relief under Category B-M-1, all affected valves will be disassembled with the bolting removed. Accordingly, the surface examina tion proposed by the licensee will provide adequate assurance of the structural reliability of valve bolting.
- 21
. Conclusions and Recommendations Based on the above evaluation, it is concluded that for the valve bolting discussed above, adherence to the Code requirements is impractical. It is further concluded that the proposed examinations will provide necessary assurance of structural reliability during this interval. Therefore, relief is reccamended as requested provided surface examinations are performed on the valve bolting. References Reference 10. II. CLASS 2 COMPONDITS A. Pressure Vessels and Heat Exchangers
- 1. Relier Recuest 2-1 (Note 1). Steam Generator Shell Side Nozzle Inside Radius. Category C-B. Item C2.22.
Code Recuirement The inside radius sections of all nozzles in vessels over 1/2 inch in nominal thickness at terminal ends of piping runs shall be voltaetrically examined in acmrdance with Figure T4C-2500-4 during each inspection interval. Terminal ends include nozzles
~
welded to or integrally cast in vessels that conriect to piping runs (manways and handholds are excluded). Only those piping runs ! selected for examination under t%mination Category C-F are ' included. l Code Relief Recuest Relief is requested from volumetric examination of the nozzle inside radius section on the shell side of the steam generators. l i Procosed Alternative Examination
- None.
1 Licensee's Basis for Recuesting Relier No ac'ceptable ultrasonic inspection technique is presently available to perform completely the nozzle inner radius examination from the outer surface. Reference NUREG-0619. Present ult w aic 22 .
r techniques are not capable of accurately and repeatedly characterizing flaws and quantifying their size from the exterior. Connecticut Yankee will continue to defer the inner radius examinations on the steam generators until such ultrasonic techniques for this examination are available and acceptable for use. Evaluation Meaningful volumetric examination of the nozzle inside radius section from the external surface is difficult with existing inspection equipment. l Typical nozzle configurations involve different radii of curva'ture on the inside and outside surfaces in the transition region where the inside radius section is to be examined. Qianges in section thickness are also typical in this region. These , gecaetry factors cause the attenuation and redirection of ultrasonic { signals and result in unreliable interpretation of examination data. Current radiographic methods are also of little use in i detecting fine surface cracks on the inside radius of nozzles. t l 4 Surface examination of the inside radius is a useful alternate method. This method, however, must be performed from inside of the vessel, and access is severely limited on the interior of the secondary side.
. 1 l
The Haddam Neck Plant has been operating since 196 8. The design of the plant was completed before ASME Sec' tion XI was in l use. Accordingly, the nozzle sections were not designed for external examinatico of. the inside radius using ultrasonic methods. Based on the difficulty of conducting volinetric erm*aticns of the inside radius ection with currently available volumetric equipment and the short time lef t in' the examina tion, interval relief should be granted. Visual examination of the nozzles should be conducted during Code-required pressure tests. Conclusions and Recommendations Based on the above evaluation, it is concluded that for the areas discussed above, adherence to the Code. requirements is impractical. It is further concluded that the proposed examinations will provide necessary assurance of structural reliability during
.= - - _ _ - _ _ . . _ . - _
23., .- - . . _ - , - . - _ - , _ . . . . .-.
this interval. Therefore, relief is recommended as requested provided visual examination of the nozzles is conducted during the Code-required system pressure tests performed. Reference Reference 10. B. Piping No relief requests. C. Pumps No relief requests. D. Valves No relief requests. III. CLASS 3 COMPONENTS No relief requested. IV. PRESSURE TESTS
- 1. Relief Recuest P-1. Pressure Test Below Code-Recuired Pressure .
Catesory C-H. Items C7.20 and C7.21 _ Code Recuire g Piping pressure-retaining boundaries (other than open-ended portions of systems) shall be visually examined (VT-2) during the system hydrostatic test performed in accordance with IWC-5222 during each inspection period. No components within the pressure-retaining boundary are exempt or excluded from the examination requirements, except as specifi~ed in IWA-5214(c) for r'epairs and replacements. The system hydrostatic ~ test (IWC-5222) shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection interval of Inspection Program B. The pressure-retaining boundary includes only those portions of the system required to operate or support the safety system function up to and including the first nomally closed valve (including a safety or relier valve) ce valve capable of automatic closure when the safety function is required. 24 _ _ _ _
1 As stated in IWC-5222, the system hydrostatic test pressure ; 1 shall be at least 1.25 times the system pressure P 3y for systems . with Design Temperature above 200 F (93 C). The system pressure P, shall be the lowest pressure setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested. For systems (or portions of systems) not provided with safety or relief valves, the system design pressuredP shall be substituted for P3 ,. Code Relief Recuest l
, Relief is requested to conduct pressure tests on the chemical
{ and volume control charging system, seal injection system, and letdown system at pressures below the Code-required hydrostatic test pressure. Procesed Alternative Examination I l Pressure tests on the chemical and volume control charging system, seal injection system, and letdown system will be conducted at operating pressure. Licensee's Basis for Recuestine Relief The chemical and volume control charging, seal injection, and letdown systems are in operation during normal plant operation and are continuously monitored to ensure integrity and performance. In addition, the potential for inadvertent overpressurization of the' reactor coolant system causes. additional concerns on the advisability of pressurizing the Class 2 system to considerably higher pressure than the adjacent Class 1 system. In lieu of the Code requirements and for the reasons stated above, a visual examination at operating pressure will be conducted. Amendment 37, section 3131 granted relief for this alternate pressure testing. Evaluation The licensee proposes to conduct pressure tests of the subject systems at the pressures indicated on the next page: l
e e System Operating Pressure Test Pressure psig psig Qianical & Volume Control 2300 2300 Ptap Discharge 2300 2300 Seal Injection 2000 2000 Letdown 200 200 1 15 15 Because of the design of the systems, the possibility of over-pressurizing the. Class 1 portion of the systems makes the Code requirement impractical. Portions of these systems will be
, subjected to other nondestructive examinations as well as visual examination (VT-2) at operating pressure. These examirations will provide assurance of the structural integrity of the sys'tems.
i Conclusions and Recommendations Based on the above evaluation, it is concluded that for the pressure tests discussed above, adherence to the Code requirements is impractical. It is further concluded that the proposed examinations will provide necessary assurance of structural reliability during this interval. Therefore, relief is reocanended j as requested provided the VT-2 visual examinations are conducted with the systems at operating pressure. } References References 4, 6, and 10. J O l 1
\
i 4 e i
. - - . *. ~ . , ,,,-,.,n, - . .-.
. -- __- - - - - _ - _=
T ~ REFERENCES
- 1. D. C. Switzer (CYAPCO) to A. Schwencer (NRC), June 29, 1977; submits Haddam Neck Plant, Proposed Revisions to Technical Specifications, Inservice Inspection (ISI) Program Update.
- 2. D. C. Switzer (CYAPCD) to D. L. Zieman (NRC), May 26,17T8; submits additional Information on ISI Program, in response to NRC staff request.
3 W. G. Counsil (CTAPCO) to D. L. Zieman (NRC), April 27,19'T9; submits a revisions to ISI Program. I , l 4 W. G. Counsil (CYAPCO) to D. L. Zieman (NRC), June 29, 1979; sutaits updates l to ISI Program related to pressure tests. !
- 5. W. G. Counsil (CYAPCO) to D. L. Zieman (NRC), Nrch 25, 1980; sutaits updates i to ISI relief requests related to pumps, clad surfaces and regenerative heat i exchanger welds. '
l
- 6. Aneroved Technical soeciriention channes Related to IsI and contained safety l Evaluation Reoort on IsI, Amendment No. 37 to Facility Operating License l j No. DPR-61, February 26, 1981.
- 7. W. G. Counsil (CIAPCO) to Dennis M. Crutchfield (NRC), August 6,1981; requested temporary relief on ISI relief requests.
- 8. W. G. Counsil (CYAPCO) to Dennis M. Crutchfield (NRC), September 3, 1982, i
', requested permanent relief on reactor coolant pump inspection for second )
interval. I
- 9. Action 7590-01, December 21, 1982.
- 10. W. G. Counsil (CYAPCO) to Dennis M. Crutchfield (NRC), April 9, 1 9818; sutaits
; the Haddam Neck Plant Inservice Inspection and Testing Program.
- 11. A. Schwencer (NRC) to D. C. Switzer (CYAPCO), November 30, 1776; provides NRC staff guidance for complying with certain provisions of 10 CFR 50.55a(g).
l l i 27
-_ _ - .. - . _ - - - - . _ . - . , . - _ _ . . . _ _ - _ - _ _ _ - . . _ . , _ _ . _ , _ . _ _ _ - ~ _ .}}