ML20195D620

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Summary of 990511 Meeting with New York Power Authority in Rockville,Maryland Re Licensee Plans for Insp of Reactor Vessel Welds at Ja FitzPatrick Npp.List of Meeting Attendees & Copy of Meeting Handout Encl
ML20195D620
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 05/24/1999
From: Williams J
NRC (Affiliation Not Assigned)
To:
NRC (Affiliation Not Assigned)
References
NUDOCS 9906090226
Download: ML20195D620 (37)


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UNITED STATES L

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' NUCLEAR REGULATORY COMMISSION

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. LICENSEE; New York' Power Authority l

FACILITY:

James A. FitzPatrick Nuclear Power Plant l

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SUBJECT:

SUMMARY

OF MAY 11,1999, MEETING REGARDING REACTOR VESSEL WELD INSPECTIONS L

On May 11,1999, representatives of the New York Power Authority (NYPA) met with members of the Nuclear Re0ulatory Commission (NRC) staff in Rockville, MD. The licensee had -

1 l

requested this meeting in order to brief the NRC staff on plans for inspection of reactor vessel welds at the James A. FitzPatrick Nuclear Power Plant (JAF). A list of attendees is provided in l. A copy of the handout provided by NYPA is provided in Enclosure 2.

Augmented reactor vessel weld inspections are required by 10 CFR 50.55a(g)(6)(ii)(A)(5). On November 3,1998, the NRC staff authorized relief from this requirement for a single FitzPatrick operating cycle, on the basis that adequate brittle fracture margin.would be maintained. NYPA had requested this relief based on their inability to complete an inspection i

that would fulfilline rule requirements. The licensee committed to investigate how a more

. complete inspection could be completed during the next refueling outage, scheduled for fall l

~ 2000, and to submit its plans to the NRC by December 31,1999. This meeting was held to I

L discuss the options developed by the licensee, and to seek staff feedback on those options.

As shown in Enclosure 2, NYPA claims that FitzPatrick water chemistry and vesse'l fluence are less hmiting than the representative facilities evaluated by the staff for the Boiling Water Reactor Vessel internals Program. Therefore, the reactor vessel conditional failure probability i

- is expected to be lower than the limiting facilities. NYPA also stated that vessel weld l l

inspections at other facilities have not identified any service-related flaws.

L NYPA has worked with 3 vendors to assess their ability to inspect the FitzPatrick reactor vessel welds. The licensee claims that this reactor vessel has an unusual set of obstructions that i

restrict the abihty of existing technologies to inspect the welds sufficiently to fulfill the intent of l-the rule. Drawmgs provided by the licensee as part of Enclosure 2 show these obstructions and their effect on each inspection technique. None of the technologies evaluated to date is capable of fulfilhng the rule requirements due to these obstructions.

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. NYPA stated that 3 options are under consideration. The first option is to request additional rehof from the rule requirements to authorize vessel weld inspections during the current 10-year inservice inspection interval. This option permits the development of more flexible'-

inspection techniques which should result in better inspection coverage. The other options j

apply existing technology from one of the vendors to inspect the welds to the extent possible.

However, NYPA does not expect that either option would fulfill the rule, so additional regulatory action would be required to authorize relief.

1 NYPA said that it intends to submit its preferred option to the staff within the next few months, several months in advance of its December 31,1999 commitment. The staff agreed that it j

may be useful to meet with the licensee after this submittal is received.

4 9906090226 990524 PDR ADOCK 05000333

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'May 24, 1999-i 2-After the meeting, NRC staff members discussed the options presented by the licensee. In a telephone conference on May 18,1999, the staff informed the licensee that the agency's goal is that licensee's obtain a high inspection percentage. Given that the near-term capability to achieve this goal, the staff is receptive to Option 1, which would provide additional time for development of techniques capable of higherinspection coverage. The licensee was informed that it would need to provide sufficient details, such as discussion of the tooling and techniques, and inspection schedule, in order for the staff to authorize this alternative.

Otherwise, the staff could require that the licensee perform inspections each outage until adequate weld coverage is obtained. Licensee representatives indicated that it intends to submit the necessary information to the staff in about 3 months to support a timely decision on the course of action for the next FitzPatrick refueling outage.

Original signed by:

Joseph F. Williams, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosures:

1. List of Attendees
2. Handout cc w/encis: See next page DISTRIBUTION: See next page DOCUMENT NAME: G:\\FITZ\\MT990511.WPD Ts receive a copy of this document, Indicate in the box:

"C" = Copy without attachment / enclosure "E" = copy with attachment / enclosure "W" = No copy 0FFICE PDI 1/W

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[PDI-1/LOQ l l PDI 1/SC

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l NAME JWilliams tM SlittlF SBajwa f%Q DATE 05/ ST/W //

05/( M 99 05/'L(M99 05/ /99 OFFICIAL RECORD COPY

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2-After the meeting, NRC staff members discussed the options presented by the licensee. In a telephone conference on May 18,1999, the staff informed the licensee that the agency's goal is that licensee's obtain a high inspection percentage. Given that the near-term capability to achieve this goal, the staff is receptive to Option 1, which would provide additional time for j

development of techniques capable of higher inspection coverage. The licensee was informed that it would need to provide sufficient details, such as discussion of the tooling and W.hniques, and inspection schedule, in order for the staff to authorize this alternative.

Otherwise, the staff could require that the licensee perform inspections each outage until adequate weld coverage is obtained. Licensee representatives indicated that it intends to submit the necessary information to the staff in about 3 months to support a timely decision on i

the course of action for the next FitzPatrick refueling outage.

I o

Original signed by:

Joseph F. Williams, Project Manager, Section 1 Project Directorate i Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosures:

1. Listof Attendees
2. Handout i

cc w/encis: See next page

_ DISTRIBUTION See next page DOCUMENT NAME: G:WITZ\\MT990511.WPD Ta rec;ive a capr of this document, indicate in the box:

"C" = copy without attachment / enclosure "E" = Copy with attachment / enclosure "we. g, eagg -

OFFICE PDI-1/PN

/A,

l POI 1/LOQ l

PDI 1/SC a l

l 54fE JWilliamsst M StitttV SBajwa fa% Q _

DATE 05/ 98f/99 //

05/ 6( 9 99 05/IMr99 05/ /99 OFFICIAL RECORD COPY

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After the meeting, NRC staff members discussed the options presented by the licensee, in a telephone enforence on May 18,1999, the staff informed the licensee that the agency's goal is that licensee's obtain a high inspection percentage. Given that the near-term capability to achieve this goal, the staff is receptive to Option 1, which would provide additional time for development of techniques capable of higher inspection coverage. The licensee was informed that it would need to provide sufficient details, such as discussion of the tooling and techniques, and inspection schedule, in order for the staff to authorize this altemative.

Otherwise, the staff could require that the licensee perform inspections each outage until adequate weld coverage is obtained. Licensee representatives indicated that it intends to submit the necessary information to the staff in about 3 months to support a timely decision on the course of schon for the next FitzPatrick refueling outage.

Joseph F. Williams, Project Manager, Section 1 Project Directorate l Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-333 -

Enclosures:

1. List of Attendees
2. Handout cc w/encis: See next page 4

l

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i James A. FitzPatrick Nuclear Power Plant I

Mr. Gerald C. Goldstein Mr. F. William Valentino, President Assistant General Counsel New York State Energy, Research, Power Authority of the State and Development Authority of New Yo*

Corporate Plaza West 1833 Broadway 286 Washington Avenue Extension 3

NewYork, NY 10019 Albany, NY 12203-6399 l

I Resident inspector's Office Mr. James Knubel

{

U. S. Nuclear Regulatory Commission Chief Nuclear Officer i

P.O. Box 136 Power Authority of the State of I

Lycoming, NY 13093 New York 123 Main Street Mr. Harry P. Salmon, Jr.

White Plains, NY 10601 Vice President - Engineering Power Authority of the State Mr. Richard L. Patch, Director of NewYork Quality Assurance 123 Main Street Power Authority of the State White Plains, NY 10601 of NewYork 123 Main Street Ms. Charlene D. Faison White Plains, NY 10601 Director Nuclear Licensing Power Authority of the State Mr. Gerard Goering of NewYork 28112 Bayview Drive -

123 Main Street Red Wing, MN 55066 White Plains, NY 10601 Mr. James Gagliardo Supervisor Safety Review Comittee Town of Scriba 708 Castlewood Avenue Route 8, Box 382 Arlington, TX 76012 Oswego, NY 13126 Mr. Arthur Zaremba, Licensing Manager Mr. Eugene W. Zeltmann James A. FitzPatrick Nuclear President and Chief Operating Power Plant Officer P.O. Box 41 l

Power Authority of the State Lycoming, NY 13093 of NewYork 99 Washington, Ave., Suite No. 2005 Mr. Paul Eddy Albany, NY 12210-2820 New York State Dept. of Public Service Charies Donaldson, Esquire 3 empire State Plaza,10th Floor Assistant Attorney General Albany, NY 12223 J

, New York Department of Law 120 Broadway Michael J. Colomb New York, NY 10271 Site Executive Officer James A. FitzPatrick Nuclear Power Plant Regional Administrator, Region i P.O. Box 41 U.S. Nuclear Regulatory Commission Lycoming, NY 13093 475 Allendale Road King of Prussia, PA 19406 Mr. Eric Beckjord 2909 29* St., NW Washington, DC 20008-3416 I

Ib Meeting Summary Distribution:

LICENSEE: Now York Power Authority FACILITY: James A. FitzPatrick Nuclear Power Plant

SUBJECT:

SUMMARY

OF MAY 11,1999, MEETING REGARDING REACTOR VESSEL WELD INSPECTIONS E-MAIL (w/ encl.1)

HARD COPY (w/all encls.)

J. Zwolinski/S. Black Docket File S. Bajwa PUBLIC S. Uttle PDI-1 R/F J. w J. Williams P. Patnaik -

OGC B. Elliott ACRS H. Conrad

' E. Sullivan M. Tschiltz cc: Licensee & Service List (w/all encis)

A. Blough, RGN-l i

c t-1

o Meeting Summary Distribution:

LICENSEE: New York Power Authority FACILITY: James A. FitzPatrick Nuclear Power Plant

SUBJECT:

SUMMARY

OF MAY 11,1999, MEETING REGARDING REACTOR VESSEL WELD INSPECTIONS E-MAIL (w/ encl.1)

HARD COPY (w/all encls.)

J. Zwolinski/S. Black (Oseletfiled S. Bajwa PUBLIC S. Little PDI-1 R/F J. Williams J. Williams P. Patnaik OGC B. Elliott ACRS H. Conrad E. Sullivan M. Tschiltz cc: Ucensee & Service List (w/all encis)

A. Blough, RGN-1 NBC RU REN11EB COPY

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r Attendees NRC/NYPA Meeting FitzPatrick Reactor Vessel Weld Inspections May 11,1999 Name Affiliation George Tasick NYPA Bob Steigerwald NYPA AIMcKeen NYPA Tom Dougherty NYPA Bob Penny NYPA Pete Okas NYPA Jeff Circle NYPA Jenny Weil McGraw Hi!!

Joe Williams NRC/DLPM/PDI Pat Patnaik NRC/DE/EMCB '

Barry Elliot NRC/DE/EMCB Herb Conrad NRC/DE/EMCB Ted Sullivan NRC/DE/EMCB S

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4 NewWrkPower 4# Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT RPV SIIELL WELD EXAM OPTIONS MEETING WITH NRC MAY l1,1999,9:30 A.M.

Prepared by:

P. Okas R. Penny y

Engineering Programs

Jilll> NewWrkPower 4ff Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT RPV SHELL WELD EXAM OPTIONS AGENDA FOR MEETING WITH NRC MAY11,1999,9:30 A.M.

I.

PURPOSE OF MEETING II.

BACKGROUND III.

PLANT SPECIFIC DATA IV.

INDUSTRY RESULTS OF PAST WELD EXAMINATIONS V.

COVERAGE OPTIONS VI.

OPTIONS UNDER CONSIDERATION VII.

REFERENCES VIII.

LIST OF ATTACHMENTS l

T I

I.

PURPOSE OF MEETING To review FitzPatrick Plant Specific Datafor:

I. Water Chemistry (Section III.)

2. Belt-Line Fluence (Section III.)
3. Condition of Weld Failure Probability (PRA) (Section III.)
4. RPV Internal Obstructions (Section V.)
5. OD RPV Shell Weld Exam Performed To Date (Section V.)
  • To review Industry Results of past examinations (Section IV.)
  • To review the Various Coverage Options for performing augmented examination of the RPV vertical shell welds to maximum extent possible. (Section V.)
  • To review Details on Explanation Coverage ofeach weld, specifically detLing vertical weld coverage in the belt-line region. (Section V.)

. To review the Options Under Considerationfor the RPV verticalshell welds that would provide an acceptable level of quality and safety. (Section VI.)

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I II. BACKGROUND NRC Information Notice 96-32, " Implementation of 10 CFR e

50.55a (g) (6) (ii) (A), " Augmented Examination of Reactor Vessel".

Licensees unable to completely satisfy the requirements for the augmented reactor vessel examination must propose an alternative that would provide an acceptable level of quality and safety. The proposed alternative may be used when authorized by l

the Director of the Office ofNuclear Reactor Regulation (NRR). [ Paragraph (A) (5)]

" Proposed Alternatives in Accordance with 10 CFR 1

50.55a (a) (3) (i) for RPV Shell Welds Examinations".

"RPV Shell Weld Examination Proposed Alternative".

" Proposed Alternatives in Accordance with 10 CFR 50.55a (a) (3) (i) for RPV Shell Weld Examinations".

  • NRC letter to NYPA, S. Singh Bajwa to J. Knubel, November 3,1998.

" Authorization of Alternative Reactor Vessel Weld Examinations (TAC No. MA 1954)"

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III. PLANT SPECIFIC DATA 1.

Water Chemistry (Attachment 1)

Lowest average reactor water chloride and sulfate e

in the history of the plant for 1998 and cycle 13 and reactor water conductivity for cycle 13.

Average conductivity in 1998 was best in the G.E.

BWR fleet.

+ Conductivity 0.067 S/cm

+ Fleet range 0.07 - 0.15 Better than fleet average for reactor water e

chloride.

+ Chloride 0.5 ppb within fleet range 0.2-2.4 Hydrogen Water Chemistry and zinc addition since 1989 Noble Metal Chemical Application planned for e

November 1999 Improved water chemistry over last several cycles.

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2. Belt-Line Fluence - Attachment 2.

. Lower fluence value than at representative (limiting ) plants for 32 EFPY.

(3 JAF - vessel peak fluence is:

i 1.57 E + 18 N/cm2.

f (3 JAF - peak fluence at belt-line weld VV-4A is:

1.1 E + 18 (top of weld VV-4A at 40 ).

(O Plant 1 - peak fluence at belt-line weld is:

6.76 E + 18.

(O Plant 2 - peak fluence at belt-line weld is:

1.5 E + 18.

(4) BWRVIP response to NRC Request for Additional Information on BWRVIP-05, June 8,1998.

Transmitted to NRC on December 15,1998.

(5) Memorandum RE-99-223, JAF Vessel Belt-Line Fluence, A. Ramachandran to P. Okas, April 22, 1999.

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3.

Condition ofFailure Probability - Attachment 3.

Frequency of Low Temperature Overpressurization (LTOP) event.

LTOP event occurs at COLD-SHUTDOWN LTOP event frequency per year ") is:

7.0E-4/ [ Industry value]

1.0E-3 [NRC value]

") Comparison of Probability of Failure for e

Vertical Welds Probability Probability Failure Plant w/o Exam w/ ISI Exam Freauency/Yr.W FitzPatrick 4.78 E-03 Clinton 1.55 E-02 9.86 E-5 9.86 E-8 Pilgrim 1.05 E-02 1.30 E-5 1.30 E-8

(*) Failurc Frequency = Probability x LTOP Event Frequency

. As shown above, FitzPatrick's Probability of vertical j

welds failure is lower than limiting plants Clinton (BWR 5) and Pilgrim (BWR 3). FitzPatrick is a BWR4.

  • An ISI exam significantly reduces the probability of a weld failure. A comparison oflimiting plants' failure frequency values with ISI exams completed (and with no relevant indications) indicates the probability of failure frequency is then lower than the FitzPatrick's core damage frequency of W 2.44 E-6.

(4) BWRVIP response to NRC Request for Additional Information on BWRVIP-05, June 8,1998.

Transmitted to NRC on December 15,1998.

(6) Memorandum RE-99-236, JAF Request for RPV Probability Risk Assessment Analysis, J. Favara to P. Okas, April 28,1999.

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IV. INDUSTRY RESULTS OF PAST WELD EXAMINATIONS 1.

A summary of & Industry Results ofPast Exams by General Electric were provided to NRC in FitzPatrick ISI - Relief Request 15.

Of the 386 welds examined, there were 16 ID indications total, located in 5 welds.

All indications were determined to be construction related, and were evaluated and accepted for operation.

No service related flaws present.

2.

A separate Survey by & EPRIfor the BWRfleet yielded the following conclusions:

5,257 feet of weld is the total length of weld examined to date, or 36% of the total possible weld length of 24 units.

Only 16 indications were found which exceeded the acceptance criteria of ASME Section XI, IWB-3500.

(1) NYPA letter (JAFP-98-0316) to NRC, Proposed Alternatives in Accordance with 10 CFR 50.55a (a)(3)(i) for RPV shell weld exam, september 29,1998 (RR No.15).

(3) BWRVIP-05 (EPRI TR-105697), BWR RPV shell Weld Inspection Recommendations, september 1995.

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  • All 16 were subsurface flaws that were shown to be acceptable by meeting the criteria ofIWB-3600.
  • The total length of the indications was 29.9",

which is just 0.05%, or the total weld length examined.

It is clear from these survey results that a substantial amount of examinations have been performed which verify the integrity of BWR vessels, and that only a negligible number ofindications have been detected as a result of these inspections.

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V.

COVERAGE OPTIONS 1.

General NYPA has obtained exam coverage proposals e

from three vendors. Only these vendors appear to I

have the capability, although some are still in conceptual / experimental stages, to fulfill exam requirements.

  • Weld inspection coverage drawings, one for each vendor are included in the List of Attachments -

Section IX.

  • An OD accessibility survey during RO-13 confirmed there is no access for further OD exams.
2. RPVInternalObstructions
  • Unusual set of circumstances prevent an exam of

" essentially 100%" of the length of all RPV vertical welds. In that, there is an excessive amount of vessel internal obstructions / interference's such as:

+ Guide rod at 180 restricts access to two vertical welds at the same azimuth.

+ Steam dryer brackets obstruct local access for 2 welds.

+ FW sparger and core spray piping restrict significant coverage to at least 34% length at 3 vertical welds.

+ Jet pump raiser / restrainer brackets, sensing lines, support plates and gussets restrict access to at least 3 welds.

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+ Core shroud - repair tie rods (10). Tie rods severely restrict access to at least 2 vertical welds.

+ RPV internal obstructions have not been removed at any domestic plant for augmenting weld coverage.

3.

OD RPVShell Weld Exam Performed To-Date

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  • FitzPatrick has performed OD volumetric exams in RO-8, RO-9,.RO-10 and RO-11 for a total of.

Circumferential welds:

827" Vertical welds:

500"

  • Some welds received partial coverage or incomplete scans.
  • Recorded total of 4 spot indications, with no measurable length or width.
  • Coverage included 3 of total 6 belt-line intersecting welds.
  • A mapping of these exams is included in the attached drawings (Section IX.).
4. EstimatedExam CoverageforEach Vendor, Schedule. Advantages and Disadvantegn_(work with drawings - Section IX.).

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Vendor 1 Summary of Estimated Exam Coverage (%):

Total Vertical Welds

(*) 34%

Total Vertical Welds (including prior OD exam)

(*) 39%

Total Belt-Line Vertical Welds

(*) 33%

Total Bel-Line Vertical Welds (including prior OD exam)

(*) 44%

(*) Coverage might increase by additional use of a possibly retrofitted UT shroud scanner equipment, but presently is conceptual design only.

SCHEDULE:

In-Vessel total (between fuel moves) 6-8 days ADVANTAGES:

Vendor has extensive experience with UT scanning equipment.

Preparatory work was already completed for RO-13.

One vendor only for refuel /RPV welds and IVVI.

PDI qualified.

DISADVANTAGES:

Low examination coverage.

May require a Design Change for " cattle chute" retrofit to avoid ring mounting interference.

Large laydown area on refuel floor.

Heavy equipment into RPV.

Requires a Design Change for the main steam line plugs to avoid equipment interference's.

10

Vendor 2 Summary of Estimated Exam Coverage (%):

Total Vertical Welds 55 %

Total Vertical Welds (including prior OD exam) 60 %

Total Belt-Line Vertical Welds 51 %

Total Belt-Line Vertical Welds (including prior OD exam) 59 %

SCHEDULE:

In-Vessel total 8-10 days (between fuel moves)

Refuel Bridge Requirements:

  • Exam above shroud 30 min./ shift (can share bridge)

. Exam below shroud Full time for (can share bridge) camera handling ADVANTAGES:

Respectable exam coverage.

Does not require heavy load analysis.

Light weight scanner.

PDI qualified.

~

Proven data acquisition system.

Small laydown area on refuel floor.

DISADVANTAGES:

Scanner has limited commercial experience (performed l

well in testing).

i Slower scanner speed.

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Vendor 3 Summary of Estimated Exam Coverage (%):

Total Vertical Welds 64 %

Total Vertical Welds 68 %

(including prior OD exam)

Total Belt-Line Vertical Welds 52 %

Total Belt-Line Vertical Welds 56 %

(including prior OD exam)

SCHEDULE:

In-Vessel total (between fuel moves) 6-8 days Refuel Bridge or 0-H crane use:

1 to 2 moves per shift for vertical welds.

12 moves total for the cire. weld.

e ADVANTAGES:

Respectable exam coverage.

Does not require heavy load analysis.

Light weight equipment.

PDI qualified.

Proven scanning components and design.

Will perform full mock-up testing.

Manageable laydown area on refuel floor.

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DISADVANTAGES:

Mast requires re-design.

Experience (with new tooling mast) limited to mock-up testing.

Would require constant coordination with vendor performing IVVI/ Refuel activities.

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VI. OPTIONS UNDER CONSIDERATION Recognizing that there is a substantial cost and person-rem exposure associated with the performance of RPV inservice inspections, FitzPatrick is committed in complying with implementing the requirements of 10 CFR 50.55a(g)(6)(ii)(A),

" Augmented examination of Reactor Vessel", by proposing alternate plans that would provide an acceptable level of quality

]

and safety.

Unusual and large number of obstructions / interferences require use of newer, partially proven technologies and/or tooling to achieve larger exam coverage than by use of conventional methods.

Removal of other obstructions / interferences than the surveillance specimen holder (to access weld VV-3C), would involve substantial risk, cost and person-rem exposure. Per NYPA review no domestic BWR Plant has removed RPV internal obstructions to augment exam coverage.

The Options under consideration are as listed below. For either option, FitzPatrick will submit, per Regulatory requirements, a Relief Request to exempt examination of circumferential welds.

1)

Request to Inspect Vertical Welds during 3rd-10 year ISI Interval (9/97-9/06) due to Plant Specific Attributes and Industry Data - Option 1.

Very Good Water Chemistry j

Lower Fluence Values than at Referenced Limiting Plant e

Lower Probability of Weld Failure than at Referenced j

Limiting Plants Vessel Pre-Service NDT Exams / Tests (RT, Hydro, etc.)

e i

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  • Previous OD Shell Weld Exams with no Reportable Indications and, with Industry Results of Past Ex:ans Showing that e

service related indications have not been found in the RPV

)

Shell Welds and those found were construction related, determined to be acceptable.

  • It is believed that improved technology in the future would increase exam coverage. One vendor is considering modifying shroud tooling for RPV Exams.

Industry Data included in the B WR VIP-05 (3) Document together with Plant Specific attributes indicate that, there are no degradation mechanisms that have affected the RPV and when combined with the high quality oforiginalfabrication, substantiates vesselintegrity which supports a possible request to defer inspection of vertical welds during the 3- 10 year ISI Interval

2) Inspect with the Conventional / Well-Experienced Tooling -

Option 2.

  • Acceptability studies performed by the three vendors provide a wide range ofID exam coverage for vertical welds. NYPA review shows that these are the only vendors in the market place capable of performing the work. Exam coverage range values are:

34 % - 64 %

all vertical welds i

33 % - 52 %

belt-line region only While the low end range values can be achieved by the e

conventional /well-experienced tooling, there may be unwanted risk in attempting to use newer technology - less 15

-ammme-

experienced tooling methods in having to achieve the higher end values.

  • The benefit - cost to achieve the increased percentage may notjustify cost and risk.
  • Would maximize ID volumetric UT coverage but with the only known, experienced and proven technology in the market place, and to the extent practical.
  • This option requires a Design Change to the Fuel Handling

" Cattle Chute" and possibly to the Main Steam Plugs to allow placement of tooling equipment.

  • FitzPatrick is committed to a 35 day outage. As such, would use a critical path window of 10 days /24 hour days for combined IVVI and RPV shell weld exams.
  • A well planned 10 day /24 hour days allocated window for IVVI and RPV shell weld exam should provide sufficient time to complete the work. Should there be any delays either due to tooling fit-up related problems, FitzPatrick would, in such case, defer the remaining work over one cycle to RO15.

e' Previous OD weld examination coverage would add approximately 5% to total vertical welds and 11% to belt-line vertical welds for a total expected coverage of 39% and 44%,

respectively.

Because ofIndustry Data and FitzPatrick Plant specific attributes listed in Option 1, this plan offers an acceptable level ofquality and safety.

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P 3)

Inspect with Newer Technology / Less Experience Tooling

- Option 3

. It would require the use of the newer technology - but less experienced tooling methods to achieve the higher end values listed in Option 2.

. Would maximize with this tooling ID volumetric UT coverage to the extent practical.

  • This entails the possible assembling of a plant specific mock-up for a test run.
  • Since FitzPatrick is committed to a 35 day outage for RO14, as such, would also use a 10 day /24 hour days to complete all planned IVVI and RPV shell weld exams.
  • Prior OD weld examinations would add a minimum of 4%

l to total coverage.

Same asfor Option 2, this option would alsoprovide an acceptable levelofquality andsafety with potentialfor higher exam coverage but at higher risk.

l 17

L VII. REFERENCES l

1. NYPA letter (JAFP-98-0316) to NRC, Proposed Alternatives in Accordance with 10 CFR 50.55a (a)(3) l

. (i) fcr RPV shell weld exam, September 29,1998. (RR No.15)

2. NRC letter to NYPA, JAFNPP-Authorization of Alternative Reactor Vessel Weld Exams (TAC No.

MA 1954), November 3,1998.

3. BWRVIP-05 (EPRI TR-105697), BWR RPV Shell Weld Inspection Recommendations, September 1995.

I

4. BWRVIP response to NRC Request for Additional Information on BWRVIP-05, June 8,1998.

Transmitted to NRC on December 15,1998.

5. Memorandum RE-99-223, JAF Vessel Belt-Line Fluence, A. Ramachandran to P. Okas, April 22,1999.
6. Memorandum RE-99-236, JAF Request for RPV l

Probability Risk Assessment Analysis, J. Favara to P.

Okas, April 28,1999.

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VIII. LIST OF ATTACHMENTS

1. Water Chemistry Data
2. Belt-Line Fluence Data
3. Condition of Failure Probability Data j
4. Drawings - Weld Coverge:

. Vendor 1

. Vendor 2

. Vendor 3 19

ATTACHMENT 1 WATER CHEMISTRY DATA

I JAMES A. FITZPATRICK NUCLEAR POWER PLANT REACTOR COOLANT CHEMISTRY 1989 - 1998

(>10% power)

YEAR CONDUCTIVITY HWC AVAILABILITY CllLORIDE SULFATE (umhos/cm)

(percent)

(nob)

.. (ppb) 1998 0.067 87 0.5 2.5 1997 0.066 89 0.5 2.6 1996 0.071 88 0.5 3.4 1995 0.074 91 1

4.2 1994 0.095 83 2.3 3.9 1993 0.100 90 4.4 6.5 1992 Note: Plant was shutdown all of 1992 1991 0.I12 64 1.8 5.6 1990 0.310 81 3.5 17 1989 0.27I 88 4.I 9.2 Chronoloey of Chemistry Channes Since 1989:

1989 HWC @ l1 SCFM (.35 ppm), Zine Addition 1990 HWC @ l3.5 SCFM (.4 ppm) 1994 Retube Condenser 1995 HWC @ l8.5 SCFM (.5 ppm) 1996 DZO(Depleted Zinc Oxide) 1997 4% Power Uprate 1999 Noble Metal Chemical Application Planned 4

i

f 4

e ATTACHMENT 2 BELT-LINE FLUENCE DATA 4

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/ 2.-//r/92 REPRESENTATIVE I

AXIAL WELD FLUENCE PROFILE

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REPRESENTATIVE 2 AXIAL WELD PLUENCE PROPILE

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1 ATTACHMENT 3 CONDITION OF FAILURE PROBABILITY DATA 1

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t EPRI Propri:tery Table 2 i

I Axial Weld Data and VIPER Results (From Prior Analyses-RAl-3)

' Initial Fluence ART Cond. Failure Plant Name

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%Ni RTndt ART x10^18 (VIPER) Probability Browns Feny 1 0.25 0.35 10 132 1.25 98.04 8.12E-03 Browns Ferry 2 0.28 0.35 10 110 0.605 82.52 6.52E-03 Browns Ferry 3 0.25 0.35 10 127 1.06 93.2 7.58E-03 Brunswick 1 0.05 0.96 10 73 1.23 63.8 5.45E-03 Brunswick 2 0.05 0.96 10 73 1.27 64.24 5.38E-03 g

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Cooper 0.19 0.97

-50 118 1.6 93.92 2.80E-03 Dresden 2 0.24 0.36 23 84 0.36 79.5 6.73E-03 Dresden 3 0.24 0.36 23 93 0.51 86.6 7.81 E-03 j

Duane Amold 0.03 0.91

-50 9

3.6 1.82 3.50E-04 Fermi 2 0.26 0.87

-44 83 0.56 49.4 1.23E-03 i

Fitzoatrick 0.22 1

-48 128 1.61 94.7 4.78E-03 Grand Gulf 1 0.06 1.08

-30 72 2.5 43.35 1.97E-03 Hatch 1 0.28 0.76

-50 143 1.8 87.6 4.48E-03 q

Hatch 2 0.23 0.5

-50 85 1.54 51 1.37E-03 Hope Creek 0.08 0.59

-30 46 0.75 30.61 4.30E-04 LaSalle 1 0.37 0.75

-30 93 0.45 58.9 1.94E 03 LaSalle 2 0.03 0.9

-6 19 0.536 29.06 1.20E-03 Limerick 1 0.04 1.08

-12 48 1.9 40.84 2.40E-03 Limerick 2 0.04 1.08

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-65 101 5.1 67.37 3.42E-03 Nine Mile Pt 1 0.22 0.2

-50 73 2.21 39.38 1.31 E-03 Nine Mile Pt 2 0.07 0.71

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-50 114 6.6 80.19 4.88E-03 Susquehanna 1 0.04 1.1

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-20 41 0.78 32.64 8.50E-04 Vermont Yankee 0.04 1

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J ATTACHMENT 4 DRAWINGS - WELD COVERAGE eVENDOR1 eVENDOR2

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