ML20205L043

Technical Evaluation Rept on Second 10-Year Interval Inservice Insp Program Plan, for Beaver Valley Power Station,Unit 2

ML20205L043
Person / Time
Site:	Beaver Valley
Issue date:	01/31/1999
From:	Mary Anderson, Charles Brown, Galbraith S IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC (Affiliation Not Assigned)
Shared Package
ML20205L035	List: ML20205L034 ML20205L040 ML20205L043
References
CON-FIN-J-2229 INEEL-EXT-99-01, INEEL-EXT-99-01168, INEEL-EXT-99-1, INEEL-EXT-99-1168, NUDOCS 9904140106
Download: ML20205L043 (35)

Text

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INEEL/ EXT-98-01168 i

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Technical Evaluation Report on the Second 10-Year interval inservice Inspection Program Plan:

Duquesne Light Company, Beaver Valley Power Station, Unit 2, Docket Number 50-412 l

M. T. Anderson, C. T. Brown, S. G. Galbraith, A. M. Porter t

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Published January 1999 l l

l Idaho National Engineering and Environmental Laboratory i

Materials Physics Department Lockheed Martin Idaho Technologles Company Idaho Falls, Idaho 83415 Prepared for the Division of Engineering Office of Nuclear Reactor Regulatica U.S. Nuclear Regulatory Commissic..

Washington, D.C. 20555 FIN No. J2229 (Task Order A29) 9904140106 990409 PDR ADOCK 05000412 O PDR 1

q. 4 ABSTRACT l

' This report presents the results of the evaluation of the Inservice Inspection Ten-Year Plan for the Secondintervalat Beaver Valley P,wer Station, Unit 2 submitted December 9,1997, including the requests for relief from the American Society of Mechanical j .

Engineers Boiler and Pressure Vessel Code,Section XI, requirements that the licensee has i

determined to be impractical. The Inservice Inspection Ten YearPlan for the Second

• Intervalat Beaver Valley Power Station Unit 2, is evaluated in Section 2 of this report.

The inservice inspection (ISI) plan is evaluated for (a) compliance with the appropriate Jition/ addenda of Section XI, (b) acceptability of examination sample, (c) conectness of

'he application of system or component examination ?xclusion criteria, and (d) compliance l vith ISI-related commitments identified during previous Nuclear Regulatory Commission l reviews. The requests for relief are evaluated in Section 3 of this report.

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l This work was funded under:

U.S. Nuclear Regulatory Commission JCN No. J2229, Task Order A29 Technical Assistance in Support of the NRC Inservice inspection Program

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SUMMARY

i The licensee, Duquesne Light Company, prepared the Inservice Inspection Ten-Year Plan for the SecondIntervalat Beaver Valley Power Station, Unit 2, to meet the requirements of the 1989 Ed;* ion of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code,Section XI. The second 10-year interval began November 17,1997, and will end on November 16,2007.

The information in the Inservice Inspection Ten-Year Plan for the SecondIntervalat Seaver Valley Power Station Unit 2, submitad December 9,1997, was reviewed. The review included mouests for relief from the ASME Code Section XI requirements that the licensee has determined to be impractical. As a result of this review, a request for additionalinformation (RAl) was prepared describing the information and/or clarification required from the licensee in order to complete the review. The licensee provided the requested information in a submittal dated July 29,1998, i Based on the review of the program plan, the licensee's response to the Nuclear Regulatory Commission's RAI, and the recommendations for granting relief from the ISl examinations that cannot be performed to the extent required by Section XI of the ASME Code, no deviations from regulatory requirements or commitments were identified in the i

inservice Inspection Ten Year Plan for the SecondIntervalat Beaver Valley Power Station Unit 2.

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CONTENTS ABSTRACT..................... .................................ii

SUMMARY

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1. I NTR O D U CTI O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 4

2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN . . . . . . . . . . . . . . .. . . 3 2.1 Documents Evaluated . . . . . . . . . . . . . . . . . . . . . . . . . . .............. 3 2.2 Compliance with Code Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.2.1 Compliance with Applicable Code Editions . . . . . . . . . . . . . . . . . . . . . 3 2.2.2 Acceptability of the Examination Sample ...................... 4

2. 2.3 Exem ption Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2.2.4 Augmented Examination Commitments . . . . . . . . . . . . . . . . . . . . . . . . 5 2.3 Conclusion

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3. EVALUATION OF RELIEF REQUESTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.1 Cla ss 1 C omponents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.1.1 R eactor Pressure Vessel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6 3.1.1.1 Request for Relief No. 2 TYP-2 N-521, Rev. O, Use of Code

(.ase N 521 Alternative Rules for DeferralofInspections of Nozzle-to-Vessel Welds, inside Radius Sections, and Nozzle-to-Safe End Welds of a Pressurized Water Reactor (PWR) Vessels 3.1. 2 Pr e s suriz e r . . . . . . . . . . . . . . . . . . . . . . . . . .. . . .8 . . . . . . .

3.1.2.1 Request for Relief No. 2-TYP-2 B3.110, Rev. O, Examination Category B-D, item B3.110, Pressurizer Nozzis-to-Vessel Welds........................................8 3.1.3 Heat Exchangers and Steam Generators . . . . . . . . . . . . . . . . . . . . . . 11 3.1.3.1 Request for Relief No. 2-TYP-2-83.140-1, Rev. O, Examination Category B-D, item B3.140, Steam Generator inside Radius S e ctions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 3.1.3.2 Request for Relief No. 2-TYP-2-B5.701, Rev. O, Examination Category B F, item B5.70, Steam Generator Nozzle Safe End t o Pipe Weld s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 3.1.4 Piping Pressure Boundary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

. 3.1.4.1 Request for Relief No. 2-TYP-2-N-524, Use of Code Case N-524, Alternative Examination Requirements for longitudinal

• Welds in Class 1 and 2 Piping . . . . . . . . . . . . . . . . . . . . . . 13 3.1.5 Pump Pre ssure Boundary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 3.1.6 Valve Pressure Boundary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 3.1. 7 G e ne r a l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 5 3.1.7.1 Request for Relief No. 2 TYP-2-B-G 1, Rev. O, Examination Category B G 1, item B6.10. Reactor Vessel Closure Head Nuts........................................15 iv

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9 3.2 Cla s s 2 C om ponents . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . 17 3.2.1 Pre ssure Vessels . . . . . . . . . . . . . . . . . . . . .

3. 2 . 2 Pi pin g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 7 3.2.3 Pumps ................. 17

.............................................17 3.2.3.1 Request for Relief No. 2-TYP-2 C6.101, Rev. O, Examination CateDory C G, iterb C6.10, Pump Casing Welds . . . . . . . . . . 17 3.2.4 Valves ..............................

• 3. 2. 5 G e n eral . . . . . . . . . . . . . . . . . . . . . .............. . . . . . . . . . . . . 19 ...... ...

3.3 Cla s s 3 Com ponents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 3.4 Pressure Tests . . . . . . . . . . . . . . . . . . . . . . .

3. 5 G e n e ra l . . . . . . . . . . . . . . . . . . . . ......................

. . . . . . . . . . . . . . . . . . .20 ...... ...

3.5.1 Ultrasonic Examination Techniques . . . . . . . . . . . . . . . . . . . . . . . . . . 20 3.5.1.1 Request for Relief No. 2-TYP 2. APP l 1, Rev. O, Examination Category B-G 1, Class 1 Bolts and Studs . . . . . . . . . . . . . . . 20 3.5.1.2 Request for Relief No. 2-TYP 2-UT 1, Rev. O, Proposed '

Alternative to Ultrasonic Examination Requirements of IWA-2232........................................

3.5.2 Exemptsd Components . . . . . . . . . . . . . . . . .

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3. 5. 3 O t he r . . . . . . . . . . . . . . . . . . . . . . ................23

.......................2 3.5.3.1 Request for Relief No. 2 TYP 2 N-509, Rev. O, Use of Code Case N 509. Alternative Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Welded A tta chmen ts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3

4. C O N C t. U S 10 N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

5. R E FE R E N C E S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 O

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TECHNICAL EVALUATION REPORT ON THE '

SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

DUQUESNE LIGHT COMPANY, BEAVER VALLEY POWER STATION, UNIT 2, DOCKET NUMBER 50-412 l

1. INTRODUCTION Throughout the service life of a water cooled nuclear power facility,its components (including supports) that are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code C! ass 1,2, and 3 are required by 10 CFR 50.55a(g)(4) (Reference 1) to meet the requirements, except the design and access provisions and the preservice examination requirements, of the ASME Code,Section XI, Rules for Inservice inspection of Nuclear Power Plant Components, (Reference 2) to the extent practical within the limitations of design, geometry, and materia's of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during successive 120-month inspection intervals comply with the requirements in the latest edition snd addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code that are l incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein, and subject to Nuclear Regulatory Commission (NRC) approval. The licensee, Duquesne Light Company (DLC), has prepared the Inservice inspection Ten-year Plan for the SecondIntervalat Beaver Valley Power Station, Unit 2 (Reference 3) to meet the requirements of the 1989 Edition of the ASME Code,Section XI. The second 10-year interval began November 17,1997, and will end on November 16,2007.

Pursuant to 10 CFR 50.55a(a)(3), proposed alternatives to the Code requirements may be used when authorized by the NRC. The licensee must demonstrate either that the proposed alternatives provide an acceptable level of quality and safety, or that Cods compliance would result in hardship or unusual difficulty without a compensating increase in safety. Pursuant to 10 CFR 50.55a(g)(5)(iii),if the licensee determines that conformance with certain Code examination requirements is impractical for its facility, the licensee shall submit information to the NRC to support that determination. Pursuant to 10 CFR 50.55a(g)(6)(i), the NRC will evaluate the licensee's determination that Code requirements are impractical. The NRC may grant relief and may impose alternative requirements that it determines to be authorized by law, will not endanger life, property, or l

the common defense and security, and are otherwise in the public interest, giving dee 1

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consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

I The information in the Inservice Inspection Ten-Year Plan for the SecondIntervalat Beaver Vciley Power Station, Unit 2, submitted Dacember 9,1997, was reviewed,

~ including the requests 'or relief from the ASME CodsSection XI requirements tl et tho {

j licensee has determined to be impractical. This review was performed using the standard i review plans of NUREG-0800, Section 5.2.4, " Reactor Coolant Boundary insarvice I Inspections and Testing," and Section 6.6, " Inservice inspection of Class 2 and 3 Components" (Reference 4).

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in a letter dated June 1,1998 (Reference 5), the NRC requested additionalinformation that was necessary to complete the review of the inservice inspection (ISI) program plan.

The requested information was provided by the licensee via a letter dated July 29,1998 i

(Reference 6).

I The Inservice inspection Ten Year Plan tu the SecondIntervalat Beaver Valley Power Station, Unit 2, is evaluated in Section 2 of this report. The ISI program plan is evaluated l

for (a) compliance with the appropriate editionladdenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI-related commitments identified l

during the NRC's previous reviews. The requests for relief are evaluated in Section 3 of this report. Unless otherwise stated, references to the Code refer to the ASME Code,Section XI,1989 Edition. Inservice test programs for snubbers and for pumps and valves are being evaluated in other reports.

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I 2, EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN i

l This evaluation consists of a review of the applicable program documents to determine whether or not they are in compliance with the Code requirements and any previous license conditions pertinent to ISI activities. This section describes the submittals reviewed and the results of the review.

2.1 Documents Evaluated Review has been completed on the following information from the licensee:

Inservice Inspection Ten Year Plan for the SecondIntervalat Beaver Valley Power Station, Unit 2 dated December 9,1997 (Reference 3).

Licensee's " Response to Request for AdditionalInformation Regarding Review of the Second 10 Year Interval Inservice inspection (ISl) Program Plan and Associated Pslief Reouests", dated July 29,1998 (Reference 6).

2.2 Compliance with Code Requirements 2.2.1 Compilance with Applicable Code Editions Inservice inspection program plans are to be based on Section XI of the ASME Code editions defined in 10 CFR 50.55aig)(4) and 10 CFR 50.55a(b). The second interval at Beaver Valley Power StatMn, Unit 2, began November 17,1997, therefore, the Code applicable to the second interval 151 program ic the 1989 Edition. As stated in Section 1 of this report, the licensee has prepared the Inservice inspection Ten-Year Plan for the Secondintervalat Beaver Valley Power Station, Unit 2, to meet the requirements of 1989 Edition of the Code, in accordance with 10 CFR 50.55a(c)(S),10 CFR 50.55a(d)(2), and 10 CFR 50.55a(e)(2), ASME Code cases may be used as alternatives to Ccde reouirements. Code cases that the NRC has approved for use are listed in Regulatory Guide 1.147, Inservice inspection Code Case Acceptability, (Rcterence 7) with any additional conditions the NRC may have imposed. When used, these Code cases must be implemented in their entirety. The licensee may adopt an approved Code case by providing

- writter. notification to the NRC. Published Code cases awaiting approval and subsequent listing in Regulatory Guide 1.147 may be adopted only if the licensee requests, and the NRC authorizes, their use on a case by-case basis.

The licensee's second 10-year I; program includes the Code cases listed below.

These Code cases either have been approved for use in Regulatory Guide 1.147 or are included as requests for relief.

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Code Case N-408 2 Altemative Rules for Examination of Class 2 Fiping Code Case N 4161 Alternative Pressure Test Requirement for Welded Repairs or Installation of Replacement Items by Welding, class 1, 2, and 3.

(Authorized in ar NRC SER dated December 7,1994)

Code Case N-4351 {

Altemative Examination Requirements for Vessels With Wall Thickness 2 in. or less Code Case N-460 Altemative Examination Coverage for Class 1 and Class 2 Welds l

Code Cuse N 481 Altemative Examination Requirements for Cast Austenitic Pump Casings l

Code Case N-489 Alternative rules for LevelIll NDE Qualification Exarninations Code Case N-491 Attemative rules for Examination of Class 1, 2, 3, and MC Component Supports of Light-Water Cooled Power Plants Code Case N-496 Helical Coil ThreadedInserts Code Case N-4981 Alternate Rules for 10-Year System Hydroststic Testing for Class 1,2, and 3 Systems (Authorized in an NRC SER dated January 12,1995)

Code Case N-504 Alternativo Rules for Repair of Class 1, 2, and 3 Austenitic Stainless SteelPiping

' Code Case N-509 Alternative Rules for the Selection and Examination of Class 1, 2 and 3 Integrally Welded Attachments (Eveluated in Section 3.5.3.1 of this report)

Code Case N 521 Alternative Rules for Deferral ofInspection of Nozzle-to-Vessel I

welds, inside Radius Sections, and Nozzle to Safe End Welds of a Pressurized Water Reactor (PWR) Vessel (Evaluated in Section

, 3.1.1.1 of this report)

Code Case N-524 i

• Attemative Examination Requirements for Longitudinal Welds in '

Class 1 and 2 Piping (Evaluated in Section 3.1.4.1 of this report) 2.2.2 Acccptability of the Examination Sample inservice volumetric, surface, and visual examinations shall be performed on ASME Code Class 1,2, and 3 components and their supports using sampling schedules described in Section XI of the ASME Code and 10 CFR 50.55a(b). Sample size and weld selection 4

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procedures have been implemented in accordance with the Code and 10 CFR 50.55a(b) and appear to be correct.

2.2.3 Exemption Criteria

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The criteria used to exempt components from examination shall be consistent with Paragraphs IWB 1220, IWC-1220, IWC 1230, IWD-1220, and 10 CFR 50.55a(b). The

• exemption criteria have been applied by the licensee in accordance with the Code, as discussed in the ISI program plan, and appear to be correct.

2.2.4 Augmerfed Examination Commitments in addition to the requirements specified in Secticn XI of the ASME Code, the licensee has committed to perform the followinr, augmented exeminations:

Reactor Coolant Pump Flywheel Examinations based on the NRC SER Dated September 12,1996 (Refersi7ce 8).

Ultrasonic examination of the RPV per Regulatory Guide 1.150, U/trasonic Testing of Reactor Vessel Welds During Preservice andInservice Examinations IReference 9); DLC will ensure compliance with this Regulatory Guide at the time of the ret,:: tor vessel examination. The impact of impending rulemaking activities and ongoing Code changes shall be included in the evaluation for compliance to this Regulatory Guide.

Examination of postulated high energy line break points based on UFSAR Section 6.6 and High Energy Line Break Inspection Program. (Reference 10) 2.3 Conclusion Based on the mview of the documents listed in Section 2.1, no deviations from regulatory regt .raments or commitments were identified in the Inservice /nspection Ten-Year Plan for I e SecondIntervalat Beaver Valley Power Station, Unit 2. Note that this report does ntiinclude a review of the implementation of the augmented examinations,it merely records that the licensee has committeo to perform them.

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3. EVALUATION OF RELIEF REQUESTS The requests for relief from the ASME Code requirements that the licensee has determined to be impractical for the second 10-year inspection interval are evaluated in the following sections.

3.1 Class 1 Components 3.1.1 Reactor Pressure Vessel 3.1.1.1 Requeet for Relief No. 2-TYP 2-N 521, Rev. O, Use of Code Case N 521 Alternative Rules for DeferralofInspections of Nozzle to Vessel Welds, inside Redius Sections, and Nozzle to Safe End Welds of a Pressurized Water Reactor (PWR) Vessels Code Requirement-Section XI, Table : 8-2500 1, Examination Category B-D, item Numbers B3.50 and B3.100 require 100% volumetric examination of all nozzle-to vessel welds and nozzle inside radius sections each inspection interval as defined by Figure IWB-2500-7. At least 25% but not more than 50% (credited) of the nozzles shall be by the end of the first inspection period, and the remainder by the end of the inspection interval.

Examination Category B-F, item Number B5.10 requi'es 100% volumetric and surface examination of the reactor vessel nozzle to-s'afe end butt welds. The examinations may be performed coincident with the vessel nozzle examinations required by Examination Category B-D.

Licensee's Proposed Alternative--Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the alternative requirements contained in Code Case N 521, Alternative Rules for Deferral of Inspections of Nozzle-to-Vessel Welds, inside Radius Sections, and Nozzle-to Safe End Welds of a Pressurized Water Reactor (PWR) Vessel, in lieu of the l

examination requirements of the 1989 Edition of ASME XI for the following components:

Norrie to Vessel Weids Norrie Inner Radius Sections Category: B D, item No: B3.90 Norrie to Safe End Welds Category B-D Item No. B3.100 Category B-F. Item No. B5.10 2RC'hEV21 N 17 2 RC'REV21-N-171R 2RC* REV21-N23 2RC'REV21-N 18 2RC'REV21-N 181R 2RC'REV21-N24 2RC'REV21-N 19 2RC'REV21-N-191R 2RC'REV21 N25 2RC'REV21 N 20 2RC'REV21-N 20lR 2RC'REV21 N26 2RC'REV21-N 21 2RC'REV21-N 211R 2RC'REV21 N27 2RC'REV21-N 22 2RC'REV21-N 221R 2RC'REV21 N28 6

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l The licensee stated:

"The alternative to the 1989 Edition of the ASME XI Code examination requirement for the items associated with the reactor vessel nozzle welds is to imp!ement Code Case N-521. Implementation would begin in the Second Ten-Year Interval for BV 2, commencing with 2R07, scheduled for March,1998." ~

Licensee's Basis for Requesting Relief (as stated)-

• "In accordance with 10 CFR 50.55a(a)(3)(i), an alternative to the examination requirements of the 1989 Edition of ASME XIis proposed. Justification of Code Case N-521 was based on the costr,in both radiation exposure and dollars, associated with these examinations versus the benefit of staggering the examinations within the ten-year interval. This code case recognized industry inservice inspection exper!ence associated with examination of these items.

Industry experience has shown no identified inservice problem with PWR reactor vessel nozzle to vessel welds, inside radius sections or nozzle to safe end welds.

Examination of 25% of the reactor vessel nozzle welds in the first period requires use of an automated ' mini-tool' system. Typically the remainder of the reactor vessel welds are examined in the third period using a second automated system.

The majority of manpower and radiation dose fct the first period examination is spent on set up and tear-down of the tool. If all of the nozzle welds were scheduled c. ,ng the same outage, then the need for the mini-tool during the first inspection 9. tiod would be eliminated. All the reactor vessel examinations could be performed m the third period using a single automated system. Elimination of the first period examination effort would provide the following benefits:

Increase the consistency of examinations, since the same personnel, procedures and equ:pment would be used.

Decrease the radiation dose associated with set up and tear-down for the first period examination.

Decrease the radioactive waste resulting from the first period examination.

Decrease critical path time that would otherwise be necessary.

"The supporting documentation for this code case, provided to the ASMF )(I committees during the review process, estimated that radiation exposure and radioactive waste would be reduced by approximately 3 to 4 Person-Rem and 1 to 2 cubic fest, respectively. Reductions in costs were estimated to be $250,000.00 in 1992: reduction of critical path outage time was 1 to 3 days.

"In preparation for implementation of Code Case N 521 in the third inspection interval, all of the BV-2 reactor vessel nozzle welds (which includes the nozzle to vessel welds, inner radius sections and nozzle to safe end welds) were examined in 2R06 (third period of the first interval, September,1996). The examinations of B-D, B3.90 and B3.100 items were performed using the 20% DAC recording criteria of the 1989 Edition of ASME Section V, Article 4. The B-F, B5.10 items (N-23, N-25, N-27) were examined both from the OD (manually) and the ID (automated) at 20% DAC recording criteria for geometric reflectors and all suspected flaws, regardless of amplitude.

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Examination of the items associated with the outlet nozzles in the third period was beyond the code required frequency, since tne items had alreao~y been examined during the first period of the first interval. The 2R06 examinations ensured that the maximum examination frequency for these items will remain ten years. Staggering the examinations within the ten year frequency is t'ot necessary since similar reactor designs are being examined within the industry at different times throughout any given ten year time period. These individua: piant examinations should provide the assurance

. necessary to identif y geners. problems with the items covered by this code case."

Evs/uat/on-The Code requires the examination of at least 25%, but not more than 50% of RPV nozzi6s and associated inside radius (lR) sections and nozzle safe ends during the first inspection period. The licenseo has requested to use Code Case N 521, which defers the examination nf these areas until the end of the second 10 year interval.

i Code Case N 521 states that the examination of RPV nozzles,IR sections and nozzle-to-safe end welds may be deferred provided (a) no inservice repairs or replacements by welding have ever been performed on any of the subject areas (b) none of the subject areas contain identified flaws or relevant conditions that currently require successive  !

inspections in accordance with IWB 2420(b), and (c) the unit is not in the first interval.

The licensee has confirmed that these conditions have been met. in addition, the licensee examined all the subject areas during the third period of the first 10-year interval. By examining the nozzles, associated IR sections, and nozzle to-safe end welds at the end of {

the previous 10 year interval tN licensee has established a new sequence of examinations and will not en 10 years between examinations. By meeting the conditions in the Code Case anu by repeating the examinations at the end of the previous interval, the licensee's proposed attemative will provide an acceptable level of quality and safety since the maximum time of 10 years between inspections will not be exceeded.

Conclusion-Considering that the licensee met all the conditions stated in the Code Case and examined all of the affected creas at the end of the previous interval, a new sequence of examinations has been established. Furthermore, since the time between examinations will not exceed 10-years, the licensee's proposed alternative will provide an acceptable

' lewl of quality and safety. Therefore,it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFR 50 55a(a)(3)(i). The use of Code Case N 521 should be authorized for the second 10 year interval at Beaver Valley Power Station.

Unit 2, or until the Code Case is approved for general use by reference in Regulatory Guide 1.147. After that time, the licensee may continue to use the Code Case with the

, limitations,if any, listed in Regulatory Guide 1.147, 3.1.2 Pressurizer .

3.1.2.1 Request for Relief No. 2 TYP 2 B3.110, Rev. O, Examination Category B D, item B3.110, Pressurizer Nozzle-to Vessel Welds Code Requirement--Examination Category B D, item B3.110 requires 100% volumetric examination of he t pressurizer nozzle to-vessel welds as defined by Figure IWB 2500-7.

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Licensee's Code Relief Request -Pursuant to 10 CFR 50.55a(g)(5Hiii), the licensee requesteo relief from 100% volumetric examination of the following pressurizer nozzle-to-sheli welds:

2RCS* PRE 21 N 9 (14* surge nozzle) 2RCS' PRE 21-N 12 (G" relief nozzlen 2RCS' PRE 21-N 10 (6" relief nozzle) 2RCS

• PRE 21-N-13 (6" relief nozzle) 2RCS* PRE 21 N 11 (6" relief nozzle) 2RCS* PRE 21 N-14 (4" spray nozzle)

Licensee's Basis for Requesting Relief (es stated)'-

... relief is reauested on the basis that ccmpliance with the Code requirement is impractical. These examinations are limited due to the nozzle curvature. The curvature of the outside surface causes the transducer to lose contact with the surface.

Additionally, the heater penetrations further limit examination of the surge nozzle weld (N-9). Each of the Pressurizer nozzle to vessel upper head welds are essentially identicalin configuration. Table 1 identifics the examination coverage for these welds for each *,can angle used. Table 2 identifies tho examination coverage for the lower head surge nozzle weld.

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"The examinatim volume calculations are based on the required examination volume i

illustrated in ASME Section XI, Figure IWB 2500 7(b). The limitations proventing full coverage are inherent to the design of these nozzles. There are no current NDE methods that would appreciably increase the amount of the examination coverage (see  ;

attached sketch for the nozzle configuration and the scan limitations)."

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TABLE 1: 2RCS

• PRE 21 N 10, -11. -12, -13. -14 Examination Examination  % of WRV Angle (*) Direction Examined Limitation O N/A 80 nozzle curvature 45 1 91 nozzle curvature 45 2 33 nozzle curvature 45 both 1 & 2 22 nozzle curvature 60 1 89 nozzle curvature

'60 2 16 nozzle curvature f

. 60 both 1 & 2 13 nozzle curvature f I

45 & 60 3 80 nozzle curvature I

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45 & 60 4 80 nozzle curvature

1. Figures, drawings. sketches etc. furnished with the licensee's submittal are not included in this report.

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,- 1 TABLE 2: 2RCS' PRE 21 N-9 i

Examination Examination  % of WRV i Angle {} Direction Examined Limitation 0  ?!/A 57 nozzle curvature / heater penetrations 45 1 77  !

nozzle curvature /haeter penetrations 45 2 31

. nozzle curvature / heater penetrations 45 both 1 & 2 20 nozzle curvature / heater pent stions 60 1 46 nozzle curvature /hester penetrations 60 2 17 nozzle curvature / heater penetrations 60 oth 1 & 2 12 nozzfe curvature / heater penetrations 45 & 60 3 66 nozzle curvature / heater penetrations 45 & 60 4 66 nozzle curvature / heater penetrations l Licensee's Proposed A/ternative Examination (as stated)~

"The alternative to the examination requirement is to perform the ultrasor'ic examination to the maximum extent possible. The UT technique used provides the maximum coverage possible, considering the nozzle design and materials used in fabrication."

halust/on-The Code requires 100% volumetric examination of the pressurizer nozzle to-vessel welds. However, volumetric examination of the subject relief, spray, and surge nozzle to-vessel welds is limited due to the radius of curvature in the transition area between the nozzle and the vessel shell. Additionally, the heater penetration locations further limit trie sur0e nozzle examination. Therefore, the nozzles' geometric design configuration makes the volumetric examination impractical to perforrn to the extent required by the Code. To meet the Code requirements, the nozzles would have to be modihsd to facilitate access for ultrasonic search units. Imposition of this requirement would create a considerable burden on the !!censee.

The licenses previously llirst 10 year int rval) examined the subject welds to the extent possible obtaining approximatt,ly 57% coverage of the required asca for each relief and spray nozzle, and approximately 44% coverage of the required area for the surge nozzle.

As a result, the INEEL staff believec that by obtaining the examination coverages

' previously achieved, significant patterns of degradation,if existing, would have been detectcd, thereby providing reasonable assurance of the structuralintegrity.

Conclusion-The geometric configuration of the subject nozzles in conjunction with the pressurizer heater penetrations make the Code-required volumetric examination of the nozzles impractical to complete. Based on the nozzle examinations that can be completed 10

reasonable assurance of the structuralintegrity should be provided. Therefore, pursuant to 10 r:FR 50.55atgl(6)(i),it is recommended that relief be granted.

3.1.3 Heat Exchangers and Steam Generators 3.1.3.1 Request for Relief No. 2-TYP 2 83.1401, Rev. O Examination Category B-D, item B3.140, Steam Generator inside Radius Sections Code Requirement-Examination Category B D, item B3.140 requires 100% volumetric examination of the steam generator (primary side) nozzle inside radius sections as defined in Figure IWB-2500-7.

k Licensee's Code Re//ef Request-Pursuant to 10 CFR 50.55a(g)(5)(iiii, the licensee reaeested relief from 100% volumetric examination of the steam generator (primary side) nozzle inside radius sections:

I 2RCS'SG21 A-N-1 AIR 2RCS'SG218-N 2BIR 2RCS'SG21 A-N 1BIR 2RCS 'SG21 C-N-3 AIR 2RCS*SG21B N 2 AIR 2RCS'SG21C N-3BIR Licensee's Basis for Requesting Relief (a.? stated)-

" ... relief is requested on the basis that compliance with the Code requirement is impractical.

"The configuration of the integrally cast Steam Generator Nozzle at the inner radius sections is such that meaningful interrogation by ultrasonic techniques is not possible due to the following reasons:

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1. " Constantly changing outside surface geometry makes it difficult to correlate the search unit position with the inside surface sound beam impingement point. 3

2. " Thickness variations in nozzle [lR) sections would require a unique calibration l

standard capable of encompassing the metal path required to reach the inner l

radius reflectors representative of code flaws of interest.

3. "The as welded clad inside diameter surface causes spurious reflectors.

4. , "The as-cast outside diame:er surface limits search unit contact.*

Licensee's Proposed Alternative Examination (as stated)-

"A visual examination (VT-1) of the inside surface of the nozzle inside radius sections will be performed instead of the volumetric examination."

Evaluation-The steam generator primary nozzios at Beaver Valley Power Station, Unit 2, are integrally cast with the channel head. This design results in a complex outside surface geometry, making correlation of search unit position difficult and variations in the thickness of the nozzla sections require the use of a calibration standard that encompasses the metal path needed to reach the inner radius reflectors. in addition, the as cast outside surface 11

limits the search unit contact, and the as-welded clad inside surface results in spurious indications. Therefore, the steam generator nozzle design and surface conditions make the Code required examination impractical. Imposition of the Code requirement would cause a significant burden on the licensee.

' As an alternative, the licensee proposed a visual examination (VT-1) of the inside surfact of the nozzle inner radius section. This examination will provide reasonable essurance that unallownt's inservice flaws have not developed in the steam generator nozzle ir:ner radius sections.

Conclusion-Based on the above evaluation, the Code-required volumetric examination of the steam generator nozzle inside sadius sections is impractical at Beaver Valley Power Station, Unit 2. Considering the visual VT-1 examinations that are being performed and the impracticality of meeting the Code requirements,it is recommended that relief be I granted pursuant to 10 CFR 50.55a(g)(6)(il.

3.1.3.2 Request for Relief No. 2 TYP 2 B5.701, Rev. O, Examination Category B-F, item I B5.70, Steam Generator Nozzle Safe End to Pipe Welds Code Requirement-Examination Category B-F. Item 85.70 requires 100% volumetric and surface examination of steam generator nozzia to safe end butt welds that are NPS 4 or larger, as defined in Figure IWB-2500 8. ,

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Licensee's Code Rel,*e/ Request-Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from 100% volumetric examination of the following steam generator nozzle-to-safe end butt welds NPS 4 or larger:

2RCS-001-F04 2RCS-002-F01 2RCS-004-F04 2RCS-005-F01 2RCS-007-F04 2RCS-008 F01 Licensea's Basis for Requesting Relief (as stated)-

"... relief is requested on the basis that compliance with the Code requirement is impractical.

"The Steam Generator nozzle to safe end welds connect the nozzles to loop piping elbows. The as-cast surface of the nozzle precludes examiriation from the nozzle side of the weld. Ultrasonic examinations can be performed on the surface of the weld.

The pipe side of the weld, which is a cast elbow,is machined for a distance of approximately 3 inches from the surface edge of the weld. This distance does not

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provide adequate space to allow compMe interrogation of the required volume in the axial scan directions.

"A 45' refracted longitudinal angle was used for the UT examination. Supplemental l Scan angles were reviewed to .mprove examination coverage. But, none were considered viable for this application due to the material and limitations involved.

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"The surface examination can be performed on 100% of the required surface. Previous ultrasonic examinations covered approximately 70% of the required volume."

Licensee's Proposed A/temative Examination (as stated}--

"The alternative to the examination requirement will be to perform the complete surface examination and to perform the ultrasonic examination to the maximum extent practical. The percentage of the examination limitation will be noted on the examination report and in the outage summary report."

Evaluation-The Code requires 100% volumetric and surface examination of the subject steam generator nozzle-to safe end welds. However, the as-cast nozzle and elbow geometries and suface conditions make the complete volumetric examination impractical.

To meet the Code coverage requirements, the nozzle safe ends and associated piping would require modification to allow access for examination. Imposition of this requirement would create a burden on the licensee.

Approximately 70% of the Code-required volume can be examined and 100% of the Code required surface can be examined. The combination of the complete surface examination and the volumetric examination to the maximum extent practical will provide reasonable assurance of continued structuralintegrity.

Conclusion-Provided that the licensee obtains the 70% volumetric coverage, the licensee's proposed alternative, to perform the ultrasonic examinations to the maximum extent practical, coupled with the Code-required surface examinations, will provide reasonable assurance of the structuralintegrity of the safe end welds. Therefore,it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

l 3.1.4 Piping Pressure Boundary 3.1.4.'l Reque.,t for Relief No. 2 TYP 2-N-524, Use of Code Case N-524, A/temative Examination Requirements for Longitudinal Welds in Class 1 and 2 Piping l

l Code Requirement-Examination Category B-J requires that volumetric and/or surface l examinations be performed on longitudinal welds as defined by Figure IWB-2500-8. The examinatien must includa at least one pipe diameter length but not more than 12 in of each longitudinal weld intersecting the circumferential weld required to be examined by

' Examination Categories B-J and B-F. Examination Categories C F-1 and C-F-2 require 100% volumetric and/or surface examination, as defined by Figure IWC-2500-7,-12 and -

13, for 2.5t of each longitudinal weld intersecting circumferential welds examined.

Licensee's Proposed Altemative--Pursuant to 10 CFR 50.55afa)(3)(i), the licensee proposed to use the alternative requirements contained in Code Case N-524 in lieu of the Code examination requirements for Class 1 and 2 fongaudinal we!ds. The licensee stated:

"The alternative to the 1939 Edition of the ASME XI Code examination requirement for Class 1 and 2 inngitudinst welds is to implement Code Case N-524. Implementation 13

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t would begin in the Second Ten-Year Interval for BV-2, commencing with 2R07, l scheduled for March,1998."

Licensee's Basis for Requesting Relief (as stated)-

"In accordance with 10 CFR 50.55a(a)(3)(i), an alternative to the examination

, , requirements of the 1989 Edition of ASME XIis proposed. Code Case N 524 l directs the examination of longitudinal welds at the intersection to the adjacent circumferential weld. Therefore the time required to perform examination of the longitudinal welds is decreased, reducing the potential radiological exposure associated with the examination.

"The supporting documentation for this code case, provided to the ASME XI committees during the review process, emphasized that there have been no significant loading conditions or known material degradation mechanisms which have become evident to date, which specifically relate " longitudinal welds. Inservice inspections of longitudinal welds performed at BVPS e' d throughout the nuclear industry have provided assurance of the structuralintegrity of these welds during the service life of the plants to date. Longitudinal welds are typically produced during the manufacturing process of the piping or titting under controlled shop conditions. This results in a more uniform residual stress pattem in longitudinal welds as compared to circumferential welds. Most longitudinal welds undergo heat treatment in the shop, which enhances the material properties of the weld and reduces the residual stresses created by welding. Heat treatment of the fitting and longitudinal weld makes the material properties more uniform throughout the fitting to the degree that the longitudinal weld is often indistingu n able from the fitting material. The one portion of the longitudinal weld affected by fi6.1 welding is that portion adjacent to the circumferential field weld.

This portion willlikely undergo material and configuration changes. Examination of this portion of the longitudinalis required under the provisions of Code Case N 524.

"DLC will continue to include longitudinal welds in the Ten-Year Plan and schedule the examinations in accordance with the required frequency. This will ensure the examination requirements for both transverse and parallel fiaws are met for that length of the longitudinal weld within the circumferential weld volume. The actual arnount of weld length examined will be less per this code case, but the number of individcal longitudinal welds scheduled for examination will actually increase from 8 welds per the Code, rules to 11 welds per this code t'ase."

' Evaluation-ASME Section XI requires the examino? ion of one pipe diameter, but not more than 12 inches, of Class 1 longitudinal piping welds. For Class 2 piping welds, the length of longitudinal weld required to be examined is 2.5 times the pipe thickness. These lengths are measured from the intersection with the circumferential weld. The licensee's proposed alternative is to examine only the portions of lont,itudinal weld within the examination area of the intersecting circumferential weld in accordance with Code Case N 524, Altemative Examination Requirements for Longitudinal Welds in Class 1 and Class 2 Piping.

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t.ongitudinal welds are produced during the manufacture of the piping, not in the field as is the case for circumferential welds. Consequently, longitudinal welds are fabricated under strict manufacturing standards, which provides assurance of structuralintegrity.

These welds have also been subjected to the preservice and initialinservice examinations, which provide additional assurance of structuralintegrity. No significant loading conditions -

or material degradation mechanisms have been identified to date that specifically relate to longitudinal seam welds in nuclear plant piping. The most critical region of the longitudinal

- weld is the portion that intersects the circumfsrential weld. Since this region will be examined during the examination of the circumferential weld, the licensee's alternative provides an acceptable level of quality and safety.

Conclusion-Considering that the most critical region of the longitudinal weld will be examined during the examination of the circumferential weld, the licensee's proposed alternative to use Code Case N 524 will provide an acceptable level of quality and safety.

Therefore,it is recommanded that the licensee's proposed alternative be authorized I pursuant to 10 CFR 50.55ata)(3)(i). The use of Code Case N 524 should be authorized for the second 10-year interval at Beaver Valley Power Station, Unit 2, or until the Code Case is approved for general use by reference in Regulatory Guide 1.147. After that time, the licensee may continue to use the Code Case with the limitations,if any, listed in Regulatory Guide 1.147.

3.1.5 Pump Pressure Boundary i

No relief requests l

3.1.6 Valve Pressure Boundary No relief requests 3.1.7 General 3.1.7.1 Request for Relief No. 2 TYP 2-B G 1, Rev. O, Examination Category B-G-1, Item B6.10, Reactor Vessel Closure Head Nuts Code Requirement-Examination Category B-G 1, item B6.10 requires a 100% surface examination of RPV closure head nuts once each ten-year interval.

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• L/censee's Proposed Alternative-Pursuant to 19 CFR 50.55afa)(3)(i), the licensee proposed an alternative to the surface ext aination of the reactor vessel closure head nuts. The licenseo stated:

"The alternative to the examination requirement is to adopt the 1989 Addenda to the 1989 Edition of ASME XI for Examination Category B G 1, which requires a visual VT-1 examination on all 58 closure head nuts once during the ten-year interval.

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Licensee's Basis for Requesting Relief (as stated)-

"In accordance with 10 CFR 50.55a(a)(3)(i), an alternative to the examination requirements of Examination Category B-G-1 is requested. The code of record for the

) BV 2 Ten Year Plan is the 1989 Edition, which requires a surface examination on reactor vessel closure head nuts. The 29 Addenda of ASME XI, changed the j

, examination requirement to a visual VT 1 examination on the reactor vessel closure head nuts. All remaining requirements of Examination Category B-G-1 are unchanged.

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. The 1989 Addenda of ASME XI has not been referenced in 10 CFR 50.55a.

" Extensive cleaning is necessary to perform the surface examination, resulting in additional costs and inefficient use of available manpower during refueling outages. ,

Since the stripping areas of the female threads in the nuts are higher than the mating I male threads of the studs (per ANSI B1.1, American Standard Unified Screw Threads),

service induced defects would occur in the male threads of the stud before developing in the nut's threads due to higher stresses in the male threads. Surface and volumetric examinations are performed on the closure head studs. Industry experience has shown j

that problems found on the reactor coolant closure head nuts are typically due to handling of the nuts. There has been no evidence of service induced problems with closure head nuts. Implementation of the requirements of the 1989 Addenda of the 1989 Edition of ASME XI will adequately identify problems occurring due to handling or galled threads."

Evaluation-The licensee has reauested relief from performing the Code-required surface j examination on the RPV closure head nuts. As an alternative, the licensee proposed to i adopt the 1989 Addende to the 1989 Edition of ASME XI. The 1989 Addenda requires a VT 1 visual examination of RPV closure hea6 ats. The 1989 Edition, Examination Category B G 1 requires that allitems, with the exception of the surface examination for RPV closure head nuts and closure head studs (when removed), be examined using VT-1 examination and/or volumetric examination (as applicable).

The 1989 Edition of the Code, item 6.10, does not provide acceptance criteria for surface examination of RPV closure head nuts. (At that time the acceptance criteria was in the course of preparation). However, acceptance criteria for surface examinations relating to other components such as piping are available. Acceptance criteria for surface examinations for components such as piping are related to linear indications andacceptar)ce or rejection of linear indications is based upon the length of the linear indication. Typicalindications that would require corrective action on RPV closure head l

' nuts are associated with degradation mechanisms such as boric acid attack, corrosion, or ,

handling mechanisms such as galled threads and deformation. Typical surface examination  !

procedures and techniques are not qualified to identify these forms of degradation.  !

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Article IWB-3000, Acceptance Standard, lWB-3517.1, VisualExamination, VT-1, describes conditions that require corrective action prior to continued service of botting and associated nuts. IWS 3517.1 requires crack like flaws to be compared to the flaw

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f standards of IWB-3515. Because the VT-1 visual examir'ation acceptance criteria include l

evaluation of crack-like indications and other relevant conditions requiring corrective 16  !

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action, such as deformed or sheared threads, localized corrosion, deformation of part, and other degradation mechanisms, it can be concluded that the VT-1 visual examination provides a more comprehensive assessment of the condition of the closure head nut. As a result, the INEEL staff believes that VT 1 visual examination provides an acceptable level of quality and safety.

Conclusion-The licensee has proposed, as an alternative to the surface examination requirement of the 1989 Code, the use of the 1989 Addenda, which requires a VT-1 visual examination. The VT-1 visual examination, with its associated acceptance criteria, provides a more comprehensive assessment of the condition of the closure head nuts:

thus, an acceptable level of quality and safety is provided. Therefore, it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i).

3.2 Class 2 Components 3.2.1 Pressure Vessels No relief requests 3.2.2 Piping No relief requests 3.2.3 Pumps 3.2.3.1 Request for Relief No. 2 TYP-2-C6.101, Rev. O, Examination Category C-G, item C6.10, Pump Casing Welds Code Requirement-Examination Category C-G, item C6.10 requires a surface examination on the inside or outside surface of pump casing welds as defined in Figure IWC-2500-8. In the case of multiple pumps of similar design, size, and function, and service in a system, the examination of only one pump among a group of multiple pumps is required.

Licensee's Proposed A/temative-Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed an alternative to the Code-required surface examinations of following pump casing welds:

Recirculating Spray Pump Casing Welds 2RSS *P21 A-C-9,10,12,15,17,18,23, 25, and 2RSS *P21 A L-11,13,16, 21, 24.

The licensee stated:

"The alternative to the examination requirement will be to perform the surface examination on the accessible portions of the welds to the maximum extent possible.

If any of the Recirculating Spray Pur.1ps are disassembled for Maintenance or other reasons, the required examinations shall be performed. The complete examination of the other eleven casing welds and the periodic functional testing and associated VT 2 examinations will provido an adequate measure of assurance of the integrity of the 17

r, noted welds. If the pump casing welds do not become accessible during the 10 year interval, it will be so noted in the final outage summary report of the interval."

Licensee's Basis for Requesting Relief (as stated)~

"In accordance with 10 CFR 50.55a(a)(3)(ii), relief is requested on the basis that compliance with the Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

f "The Code required surface examination cannot be performed on the welds listed below for the reasons noted. The portion of the weld length that can be examined is specified in the middle column. Access to these welds requires disassembly of the pump casing for those welds located in the floor sleeve; disassembly and removal from i

the sump for the lower casing section; removal of welded gusset plates for welds 9, 10,17 and 18. This evolution risks damage to the pump, in order to examine plant components that have a proven reliability record throughout the industry.

WELD NUMBER

• EXAMINABLE AMOUNT INTERFERING CONDITION 2RSS*P21 A C 9 70 % Gusset plates 2RSS*P21 A C-10 70 % Gusset blates 2RSS*P21A L11 0% Located in floor sleeve 2RSS*P21 A-C 12 0% Located in floor sleeve -

2RSS'P21A L13 0% Located in floor sleeve 2RSS *P21 A-C-15 0%

Located in floor sleeve 2RSS *P21 A-L-16 20 % Located in floor sleeve (80%)

2RSS

• P21 A-C-17 70 % Gusset plates 1 l

2RSS*P21 A C-18 70 % Gusset plates 2RSS*P21 A L-21 0% Located in sump 2RSS*P21 A C 23 0% Located in sump 2RSS*P21 A L 24 0% Located in sump i 2RSS

• P21 A-C-25 0% Located in sump I

The licensee stated in their Response to NRC Request for Additional Information that:

"The pumps were designed to require no preventative maintenance, if repairs to the pumps are required, pump dismantling and re-installation instructions are available.

These instructions are quite involved, and include special cautions for handling the pressure chamber assembly and fabrications of special tools to preclude diaphragm and piston damage. "...Since there has been no evidence of generic industry problems with welds on these types of pumps, the effort to gain access to these welds and the 18

increased potential for damage incurred, for the sole purpose of performing the surface examinations is considered a hardship and unusual difficulty without a compensating increase in the level of quality and safety."

Evaluat/on-The pump casing welds listed in this request for relief are below floor level, or are inaccessible due to welded gusset plate interference. Access to the subject welds would require removal of the pump casings from the sump or removal of the welded

- gusset plates. Disassembly of the pump and removal of the welded gusset plates for the sole purpose of examination performance is quite involved and poses a significant risk of damage to the pumps components. Disassembly of the pumps solely for the purpose of inspection would result in a considerable burden for the licensee.

The licensee is able to perform essentially 100% of the required examinations on eleven cf the pump casing welds and will examine the accessible portions of the remaining welds to the maximum extent possible. Also, if any recirculating spray pumps are disassembled for maintenance or other reasons the Code required examinations will be performed. The INEEL staff believes that the licensee's proposed alternative will detect significant degradation and provide reasonable assurance of operational readiness, i

Conclusion-The licensee has provided information to support the determination that the Code requirement to examine the subject pump casing welds presents a hardship without a compensating increase in safety, therefore, it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFF,50.55a(a)(3)(ii).

3.2.4 Valves No relief requests 3.2.5 General No relief reo /.sts 3.3 Class 3 Components No relief,recuests 3.4 Pressure Tests No relief requests 6

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3.5 General 3.5.1 Ultrasonic Examination Techniques 3.5.1.1 Request for Relief No. 2-TYP 2 APP-1-1, Rev. O, Examination Category B-G-1, CLss 1 Bolts and Studs I

• Code Requ/rement--Appendix 1, Paragraph 1-2300 requires that ultrasonic inspection of bolts and studs be conducted in accordance with Appendix VI, as supplemented by Appendix 1.

L/censee's Proposed A/ternet/ve Exam /nat/on--Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed an alternative to the Code requirement. The proposed alternative is stated below.

"DLC UT personnel will be qualified using the PDI Performance Demonstration initiative Progam and DLC written practice OSP 2.11, which meets the requirements of Section XI, Appendix Vil (1989 Edition). The UT examination procedure applied by these qualified individuals is based on PDI Procedure PDI-UT-5, Revision A, and has been demonstratad on DLC qualification standards, which meet both Appendix VI and Appendix Vill, Suppfement 8 requirements with respect to qualification notch depth and reflective area.

Through the use of the PDI program for personne! qualification and IWA 2300 demonstration on BVPS bolting configurations for procedure qualification, valid qualified techniques will be used by qualified individuals to perform UT examinations on Class 1 (Category B G 1) bolts and studs."

i licensee's Basis for Requesting Relief (as stated)-

"In accordance with 10 CFR 50.55a(a)(3)(i), an alternative is proposed to the requirements of Appendix 1. Paragraph I-2300 specif;es examinations be conducted in accordance with Appendix VI.

" Appendix VI requirements are not consistent with later Code requirements, with respect to personnel renewal of qualification requirements. Specifically, Paragraph VI-2250 (a) requires renewal by performance qualification test 'when an examiner has not performed the botting examination technique for which he was orig;nally qualified for a i period of 6 months,' This requirement is impractical due to the frequency of scheduled botting examinations and number of individuals qualified. This requirement has been deleted from later Code Editions and does not exist in Appendix Vill or any of the Supplements."

"The requirement is addressed in Appendix Vil, Paragraph Vll 4400, " Interrupted Service", which requires a limited requalification for a 12 month period of inactivity.

This 12 month requirement is also contained in the DLC written practice, OSP 2.11."

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Evaluation-The licensee has proposed that DLC UT personnel be qualified using the PDI Performance Demonstration initiative Program and DLC written practice QSP 2.11, which i

meets the requirements of the 1989 edition of Section XI, Appendix Vil,in lieu of meeting ASME Appendix VI requirements. Appet6 w, Ultrasonic Examination of Bolts and Studs, {

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requires that the personnel qualification for ultrasonic examination of bolts and studs be l renewed using a performance qualification test when the examiner has not performed the botting examination technique for which he was originally qualified for a period of 6

- months. The ISI er.aminations for Class 1 and Class 2 bolting are performed during refueling outags, which are typically on a 18 month cycle. Therefore, performing bolting examinations within a 6 rnonth period is unlikely with a single or dual unit plant. Appendix VI, has been removed from later editions of the Code and superseded by Appendix Vil and Vllt.

Appendix Vll, Qualification of Nondestructive Examination Personnct for Ultrasonic Examination, Paragraph Vll 4400 requires demonstration of continued proficiency by f successful completion of a Practical Examination (Level I and 11 personnel) or Specific Examination (Level til personnel) after a 12 month period of inictivity. Therefore, allowing the licensee to perform requalifications of personnel after 12 months of inactivity for ultrasonic examination of B-G-1 bolting is consistant with other Class 1 ultrasonic examination qualification requirements. Therefore, the INEEL staff believes that the licensee's proposed alternative, to qualify DLC personnel using the PDI program meeting the requirements of Section XI, Appendix Vll for Catepory B-G 1 boiting will provide an l acceptable level of quality and safety.

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Conclusion-The licensee's proposed alternative will provide an acceptable level of quality and safety. Therefore,it is recommended that the proposed alternative be authorized 1

pursuant to 10 CFR 50.55a(a)(3)(i). l 3.5.1.2 Request for Relief No. 2 TYP 2 UT-1, Rev. O, Proposed Alternative to Ultrasonic Examination Requirements of IWA 2?32 l

Code Requirement-Article I provides rules for the ultrasonic oxaminations requi.ed by IWA-2232, through reference to other Code Sections and Articles as supplemented by specific Appendix i Supplements.

Licensee's Proposed Alternative-Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposes an alternative to the ultrasonic examination requirements of the 1989 Edition of ASME XI. The licensee stated:

"The alternative to the 1989 Edition of the ASME XI Code examination requirements for volumetric UT examination of austenitic piping welds, ferritic piping welds and bolting is implementation of ultrasonic examination procedures meeting the requirements of the PDI Proc,em Descriotion. Revision 1.

"The alternative to the 1989 Edition of ASME XI Code examination requirements for cast austenitic pipiig weld and dissimilar metal welds is implementation of DLC 21

ultrasonic procedures that have been qualified and demonstrated to the ANil, and incorporate technical guidance from PDI techniques and procedures, where applicable.

" Implementation would begin in the Second Ten-Year intarval for BV-2, commencing with 2R07, scheduled for March 1998."

Licensee's Basis for Requesting Relief (as stated)-

"In accordance with 10 CFR 50.55afa)(3)(i), an afternative to the examination requirements of the 1989 Edition of ASME XIis proposed. In the following applications, DLC proposes to use DLC ultrasonic procedures derived from and incorporating all the technical procedural requirements of the applicable PDI procedures:

PDI Procedure DLC Procedure PDI UT-1, Revision A, "PDI Generic UT-323, Revision 0, " Ultrasonic Procedure for the Ultrasonic Examination Examination of Ferritic Pipe Welds" of Ferritic Pipe Welds" PDl-UT-2, Revision A, 'PDI Generic UT-321, Revision 0, " Ultrasonic Procedure for the Ultrasenic Examination Examination of Austenitic Pipe Welds" of Austenitic Pipe Welds" PDI-UT 2, Revision B, "PDI Generic UT-312, Revision 0, " Ultrasonic Procedure for the Ultrasonic Through Wall Through Wall Flaw Depth Sizing in Pipe Sizing in Pipe Welds" Welds" PDI UT 5, Revision A, "PDI Generic UT-317, Revision 1, " Manual Straight Procedure for Straight Beam Ultrasonic Beam Ultrasonic Examination of Examination of Bolts and Studs" Bolting" "The above proposed DLC procedures will be used for the UT examination of applicable Class 1 and 2 austenitic and ferritic piping welds as well as bolting.

" Ado.tionally, tL .ol'owing UT procedures will be used for the UT examination of class 1 and 2 Dissimilar Metal Welds and Class 1 Cast Austenitic Piping Welds:

UT-322, Revision 0, " Ultrasonic Examination of Dissimilar Metal Welds' UT 323, Revision 0, " Ultrasonic Examination of Welds Joining Cast Austenitic Piping Components" "These procedures have been qualified and demonstrated to the ANil, and incorporate technical guidance from PDI techniques and procedures, where applicable."

The licensee stated in their Response to NRC Request for AdditionalInformation that:

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"The proposed alternative examinations have been demonstrated to be equivalent or superior to those specified in the 1989 Edition of ASME Section XI."

Evaluation-The licensee has proposed, as an alternative to the requirements of the 1989 Edition of XI, the use of ultrasonic examination procedures that either meet the ~

l , requirements of, or take technical guidance from, the Performance Demonstration initiative l

! (PDl). PDI has been developed by a group of utilities responsible for implementing a

• performance demonstration prograni that meets the intent of Appendix Vill of ASME XI.

Four of the six procedures in *e proposed alternative were prepared using the technical requirements associated wr , aw applicable PDI procedures. The remaining two procedures, for dissimilar metai and cast austenitic piping, take technical guidance from the PDI procedures. The PDI procedures were qualified and demonstrated successfully to three domestic Authorized Nuclear Inservice Inspection (ANil) organizations. In addition, Dl.C has demonstrated the subject UT procedures to their ANil. The proposed alternative I examinations have been demonstrated to be equivalent or superior to those specified in the 1989 Edition of Section XI and, therefore, provide an acceptable level of quality and safety.

Conclusion-The licensee's proposed alternative to the examination requirement will provide an acceptable level of quality and safety. Therefore, it is recommended that the proposed alternative examination be authorized pursuant to 10 CFR 50.55a(a)(3)(i).

3.5.2 Exempted Components No relief requests 3.5.3 Other 3.5.3.1 Request for Relief No. 2 TYP 2 N 509, Rev. O, Use of Code Case N 509, Attemative Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Welded Attachments Code Requirement-Examination Categories B H and B-K-1 require 100% volumetric or surface examination, as applicable, of integrally welded attachments exceeding 5/8 inches design thickness. Examination Category C-C requires a surface examination of integrally welded attachments exceeding 3/4 inches design thickness. Categories D A, D B and D C require a visual (VT-3) examination of integrally welded attachments.

Licensee's Proposed Altemative--Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the alternative requirements contained in Code Case N 509, Altemative t .

Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Welded Attachments. The licensee stated:

"The alternative to the 1989 Edition of the ASME XI Code examination requirement for welded attachments is to implement Code Case N-509 with the exceptions noted above, implementation would begin in the Second Ten-Year Interval for BV 2, commencing with 2R07, scheduled for March,1998." {

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'o e Licensee's Basis for Requesting Relief (as stated)-

"In accordance with 10 CFR 50.55a(a)(3)(i), an alternative to the examination requirements of the 1989 Edition of ASME XIis proposed. Code Case N 509 provides alternative rules for selection and examination of welded attachments.

This code case requires a surface examination of 10% of the Class 1 and 2 welded

, attachments on piping, pumps and valves associated with the component supports selected for examination under IWF 2510. For Class 1 configurations of Figure IWB-2500-14, a volumetric examination is permitted in lieu of the surface examination, which is also permitted by the Code. For welded attachments of Class 1 and 2 vessels, examination of one welded attachment is required on ead vessel, in the case of Class 1 and 2 vessels, examination of one welded j attachment is required on each vessel. In the case of Class 1 and 2 multiple vessels of similar design, function and service, only one integrally welded attachment of only one of the multiple vessels is required to be examined. For Class 3 integrally welded attachments on piping, pumps and valves, a visual (VT-1) examination of a 10% sample is required, in the case of Class 3 multiple vessels, only the welded attachments of one of the multiple vessels are required to be examined. Code Case N 509 also requires examination of welded attachments whenever component support member deformation is identified. This Case does not include the exemptions of base material design thickness less than 5/8" (Class

1) and 3/4" (Class 2) that the ASME XI Code allows. Therefore, DLC has included all applicable integrally welded attachments regardless of design thickness in the population from which sampling percentages were applied.

"DLC will apply the fo!!owing exceptions to the alternative rules of Code Case N 509:

1. The 10% sample percentage will be applied to the entire population of Class 1 and 2 welded attachments rather than to the smaller population of welded attachments associated with the component supports selected for examination. Therefore, the number of welded attachments selected for examination will be greater. This approach remoses the variability associated with using the number of component supports selected for examination, that might happen to have welded attachments, as the basis for the population of potential candidates for examination.

2. ,

Code Case N-509 requires that Class 1,2 and 3 component supports be selected for examination in accordance with IWF of the 1989 Edition with

• the 1990 Addenda. The BV 2 Ten-Year Piari'has used for the selection criteria of component supports, Code Case N-491, " Alternative Rules for Examination of Class 1,2,3, and MC Component Supports of Light Water Cooled Power Plants". This code case is acceptable for use per Regulatory Guide 1.147, and is essentially identical to the requirements of the 1989 Edition with the 1990 Addenda for the selection of component supports for examination. I l

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oe The following table identifies, by examination category and item number, the total number of non-exempt welded a:tachments and the number of examinations scheduled.

ASME Item Total Examinations Category No. Number Scheduled N 509 Examination Requirement B-K B10.10 5 1 One Welded Attachment per vessel

• B-K B10.20 20 3 10% of total nurnber C-C C3.10 38 l 3 One welded attachment per vessel

• I CC C3.20 155 16 10% of totalnumber CC C3.30 62 8 10% of total numoer D-A D1.10 26 12 All welded attachments per vessel

• D-A D1.20 405 47 10% of total number, prorated by system

• ln the case 6 8 multiple vesseis of similar design. function and service, enemination is hmited to one of the multiple vessels.

l Evaluation-The licensee has proposed to apply the requirements of Code Case N-509 as an alternative to the Code requirements for the examination of integrally-welded l

attachments on Class 1,2, and 3 piping and components. The licensee has also~

committed to supplement the Code Case with a minimum examination sample of 10% of integral attachments to non-exempt Class 1,2, and 3 components. Considering that most of the Code examination requirements are based on sampling to ensure the detection of service-induced degradation, extending the sampling philosophy to the integral attachment welds will provide an equivalent level of quality and safety. Therefore, it is recommended  !

j that the alterna;ive, to use Code Case N 509 with the minimum sample size of 10%, of all i non-exempt Class 1,2, and 3 integrally welded attachments, will provide an acceptable level of quality and safety.

Conclusion--Use of Code Case N-509 for the subject components provides an acceptable level of quality and safety. Therefore, it is recommended that the licensee's propu ed alternative, to use Code Case N-509, with the commitment to ensure that the sample size i specified for piping, pumps, and valves will be a minimum of 10% of the total number of l

Class 1,2, and 3 integrally welded attachments, be authorizcd pursuant to 10 CFR l

50.55ala)(3)(i). The use of this Code Case should be authorized for the second interval at l Beaver Valley, Unit 2, or until the Code Case is approved for general use by reference in l ,

Regulatory Guide 1.147. After that time, the licensee must follow the conditions,if any, specified in the regulatory guide.

25 t

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4. CONCLUSION Pursuant to 10 CFR 50.55a(g)(6)(i),it has been determined that certain inservice examinations cannot be performed to the extent required by Section XI of the ASME Code.

In the cases of Relief Requests 2 TYP-2-83.1101-1,2-TYP-2-83.140-1, and 2-TYP ,

B5.70-1, the licensee has demonstrated that specific Section XI requirements are impractical. It is, therefore, recommended that relief be granted as requested. Granting

• relief will not endanger life, property, or the common defense and security and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could I result if the requirements were imposed on the facility.

Pursuant to 10 CFR 50.55ala)(3),it is concluded that for Relief Requests 2-TYP 2-B G 1, 2-TYP-2-APP-1 1, 2-TYP-2-C6.10 1, 2-TYP-2-UT-1, 2 TYP-2-N-509, 2 TYP-2-N-521, and 2-TYP 2 N-524, the licensee's proposed alternatives will (a) provide an acceptable level of quality and safety, or (b) Code compliance will result in hardship or unusual difficulty without a compensating i.1 crease in safety. It is recommended that the proposed alternative be authorized.

This technical evaluation has not identified any practical method by which Duquesne Light Company can meet all the specific inservice inspection requirements of Section XI of the ASME Code for the existing Beaver Valley Power Station, Unit 2. Compliance with all of the Section XI examination requirements would necessitate redesign of a significant number of plant systems, procurement of replacement components, installation of the new components, and performance of baseline examinations for these components. Even after the redesign efforts, complete compliance with the Section XI examination requirements I

probably could not be achieved. Therefore,it is concluded that the public interest is not l served by imposing provisions of Section XI of the ASME Code that have been determined to be impractical.

Duquesne Light Company should continue to monitor the development of new or improved examination techniques. As improvements are achieved, Duquesne Light Company should incorporate these techniques in the ISl program plan examination requirements.

Based on the review of the Inservice inspection Ten-Year Plan for the SecondInterval at Beaver Valley Power Station, Unit 2, the Duquesne Light Company 's response to the NRC's request for additionalinformation, and the recommendations for granting relief from

• the ISI examinations that cannot be performed to the extent required by Section XI of the ASME Code, no deviations from regulatory requirements or commitments were identified.

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5. REFERENCES

1. Code of Federal Regulations Title 10, Part 50.

2. American Society of Liechanical Engineers Boiler and Pressure Vessel Code, Section -

, XI, Division 1,1989 Edition.

3.

Inservice Inspection Ten-Year Plan for the SecondIntervalat Besver Valley Power I Station Unit 2 submitted December 9,1997.

4. NUREG-0800, Standa'd Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, Section 5.2.4, " Reactor Coolant Boundary inservice inspection and Testing," and Section 6.6, " Inservice inspection of Class 2 and 3 Components,"

July 1981.

5.

Letter dated June 1,1998, D. S. Brinkman (NRC) to J. E. Cross (Duquesne Light Company) containing request for additionalinformation.

6. Letter dated July 29,1998 to Document Control Desk (NRC), containing response to the NRC RAI dated June 1,1998.

7. NRC Regulatory Guide 1.147, inservice Inspection Code Case Acceptability, Revision 11, October 1994.

B. Safety Evaluation Report dated September 12,1996, B. W. Sheron (NRC) to S. C.

Jain, concerning reactor coolant pump flywheel examinations.

9. NRC Regulatory Guide 1.150 Ultrasonic Testing of Reactor Vessel Welds During Preservice andInservice Examinations, Revision 1. February 1983

10. UFSAR Section 6.6; High Energy Line Break Inspection Program 4

27

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. s-i Nac form 335 Ow U s Nudect Reguistory commasion gg 1. REPORT NUhGER (Ass.gned by NRC, Add Vol., Supp.. Rev and 32o1.22 9 Addendum Numbers. af any)

BIBLIOGRAPillC DATA SHEET INEEUEXT.98 Oll68

2. TIT 1.E AND SUBITII.E

3. DATE REPORT PUBLISHED Technical Evaluation Report on the Second 10-year Intenal Inserdce Insnection Program Plan: Mone. Year Duquesne Light Company, January 1999 Beaver Valley Power Station, Unit 2' Docket Number $6-412 4. FIN OR GRANT NUMBER

• JCN J2229 (Task Order A29)

5. AUmOR(S)

6. TYPE OF REPORT M. T. Anderson C. T. Brown Technical S. G. Galbraith A. M. Porter 7. PERIOD COVERED Ondusive Data)

8. PERFORMING ORGANIZATION - NAME AND ADDFI.SS Of NRC, provide Division, Offge or Regier mailing address, if contractor, provide r.ame and mailing a.ia, 5) ,

Idaho National Engineering and Environmental I.aboratory Materials Physics Lockheed Idaho Technologies Company Idaho Falls, Idaho 83415 Nuclear Regulatory Commasion, and mailing address)9. SPONSORING ORGAN 12ATION Civil and Geosciences Branch Division ofEngineering Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D C. 20$55

10. SUPPLEMENTARYNOTES

11. ABSTRACT (200 warda or i s)

Power Station, Unit 2, submitted December 9,1997, including the req Boiler and Pressure Vessel Code,Section XI, requirements that the licensee has determined to be imp Year Plan for the Second Interval at Beaver Valley Power Station Unit 2, is evaluated in Section 2 of t plan is evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability of the application of system or component examination exclusion criteria, and (d) compliance with IS previous Nuclear Regulatory Commission revient The requests for relief are evaluated in Section 3 of this equi

12. KEY WORDS/DESCRIPTORS (1.ist words or phrases that mil assim researchm in 8~% the a,~,a

13. AVAILABlWTYSTATEMENT Unlimited

14. SECURfrY CLASSIFICATION finis page) Unclassified ft% report) Unclassified

15. NUMBER OF PAGES

16. PRICE l

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