Text

Safety Evaluation Granting Relief Requests RR-B1,RR-C1,RR-D1 & RR-B3.Finds That Proposed Alternative for RR-B3 Provides Acceptable Level of Quality & Safety & Authorizes Alternative Pursuant to 10CFR50.55a(a)(3)(i)
	ML20210F333
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Site:	Hope Creek
Issue date:	07/22/1999
From:	; NRC (Affiliation Not Assigned)
To:	;
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ML20210F331	List: ML20210F327; ML20210F333;
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	NUDOCS 9907300032
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NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RE_ QUESTS FOR RELIEF ON THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PUBLIC SERVICE ELECTRIC & GAS COMPANY

_ HOPE CREEK GENERATING STATION DOCKET NO. 50-354

1.0 INTRODUCTION

The inservice inspection of the American Society of Mechanical Engineers (ASME) Code Class 1,2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel (B&PV) Code and applicable addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). Title 10 of the Code of Federal Reoulations (10 CFR) Part 50.55a(a)(3) states that altematives to the requirements of paragraph (g) may be used, when authorized by ihe NRC, if (i) the proposed attematives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and excess provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, " Rules for laservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in_10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable ASME Code,Section XI, for the first 10-year inservice inspection (ISI) interval for Hope Creek Generating Station (HCGS), is the 1983 Edit!on through Summer 1983 Addenda.

Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement. After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and may impose attemative requirements that are determined to be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed.

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l By letter dated March 3,1998, Public Service Electric And Gas Company (PSE&G or the licensee), submitted four requests for relief from the ASME Code,Section XI requirernents for .

HCGS. These relief requests are for the first 10-year ISIinterval. Additionalinformation was i provided in PSE&G's [[letter::LR-N980574, Submits Response to RAI Re First 10-yr ISI Interval Requests for Relief for Plant.Attachment 1 Responds to Each RAI Item & Refers to Other Attachments,As Necessary,To Provide Responses.Attachment 2 Provides List of Acronyms Used|letter dated December 15,1998]].

The NRC staff, with technical assistance from the Idaho National Engineering and i Environmental Laboratory (INEEL), has reviewed and evaluated the relief requests. The staff i adopts the evaluations and recommerdations for granting relief or authorizing altematives contained in the Techaical Letter Report (TLR) prepared by INEEL, as reflected or as modified '

by this safety evaluation (SE). The INEEL TLR is provided as Attachment 2 to this SE. The staff has taken a (0w exceptions to the INEEL conclusions on the reliefs that are denied in the i TLR due to lack of information. The staff has subsequently obtained clarifications from PSE&G l on the specific iteins in the TLR pertaining to the denial of the reliefs and, therefore, has I granted the licensee's requests for relief. The stafl's evaluation of the licensee's relief requests l for the first 10-year ISI interval is provided below.

2.0 EVALUATION in reference to the technicalletter report (TLR) of INEEL (Attachment 2), the staff concurs with INEEL evaluations and conclusions in regard to the following.

I Relief Request RR-B1, ASME Section XI, Examination Category item Numbers B1.12, B1.22, B1.30, B3.90, and 88.10 pertaining to the reactor vessel, item Number B9.31 for the main steam piping, and item Number B9.12 pertaining to weld 2LD on Line 1-BC-12CCA-115 and weld SLD on Line 1-BB-28VCA-014.

Relief Request RR-C1, item Numbers C1.10, C2.21, and C2.22 pertaining to the residual heat removal system.

Relief Request RR-83, item Numbers B12.20, and B12.50 pertaining to the pump casing and ,

valve body welds.

The reliefs in RR-B1 and RR-C1 for the items stated above are granted pursuant to 10 CFR 50.55a(g)(6)(i) and the proposed attemative in RR-B3 is authorized pursuant to 10 CFR 50.55a(a)(3)(i).

In Attachment 2, INEEL recommended that the foliowing relief requests be denied due to lack of information in the submittal. Af ter obtaining clarifications from the licensee, the staff has determined that the Code requirements are impractical and is granting relief pursuant to 10 CFR 50.55a(g)(6)(i). The clarifications along with discussions of the adequacy of the l examinations performed are provided below.

t Relief Reauest RR-B1. Item Numbers 89.11. B9.21. B10.10 Item number 89.11 pertains to Weld 6 cn Line 1-FD-10DBA-001 which was magnetic-particle examined over only 71 percent of the surface due to interference from a pipe restraint.

However, the volumetric coverage of the weld is greater than 90 percent with no recordable indication. Item number B9.21 pertains to Welds 3 and 7 on Line 1-BH-2CCA-011 and Weld 1 on Line 1-BH-1.50CCA-011 which was surface examined between 46 and 60 percent of the surface due to close proximity of a wall which limited access to the welds. Item number B10.10 pertains to integrally welded attachments to piping which were surface examined between 72 and 88 percent, due to the component support itself at each of the four lugs. The staff believes that if there was a pattern of degradation in the welds, the percentage of surface examination conducted on the welds should have detected it. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for these items.

RR-C1. Item Numbers C3.20. C6.10 Item number C3.20 pertains to welded attachments to Class 2 piping which were surface examined between 49 and 81 percent, due to component support obstructions / interferences at each of the lugs. The staff believes that there is reasonable assurance of structural integrity of the welded attachments with the examination coverage since any pattern of degradation should have been detected item number C6.10 pertains to surface examination of Class 2 pump casing welds for the residual heat removal pumps and the core spray pumps. The surface examination of pump casing welds on these pumps was restricted due to obstruction from either the pump suppor1 or the concrete pedestal. The licensee has obtained examination i coverages between 18 and 73 percent for the accessible welds and no coverage for the j inaccessible welds. The material for the pump casing is cast carbon steel which is compatible with chemically controlled primary coolant and there is no known degradation mechanism believed to exist on the external surface of the casing weld, which the code required surface examination would have detected. The industry experience in regard to the structural integrity of the pump casing welds has been very satisfactory. Nevertheless, any pressure boundary leakage would be easily detected during the system pressure test and, thus, will continue to ensure leak tight integrity of the welds. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for these items.

l RR-D1. Item Numbers D2.20 end F3.1040 Item numbers D2.20 and F3.1040 pertain to VT-3 visual examination of Class 3 integral attachments and component supports. The integral attachments and the supports are located on the diesel generator exhaust line. The integral attachments and the component supports identified as H002-1 A and 1KJ034H004 are inaccessible for VT-3 visual examination due to a fire barrier enclosure around the component. The licensee has clarified that during the first 10-year ISI interval, the component supports were VT-3 examined prior to the installation of the fire barrier and were found acceptable; and, therefore, no relief is required. However, the integral attachments on the exhaust piping were not visually examined and are now j inaccessible due to the fire barrier. The licensee further clarified that the adjacent supports and l their integral attachments to the ones that are inaccessible on the subject piping were also

visually examined. The staff, therefore, believes that since there was no structural distress

found during the VT-3 visual examination of the component support itself, the integral attachments have been capable of meeting their intended function. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for these items. -

3.0 CONCLUSION

With respect to Relief Requests Nos. RR-B1, RR-C1, and RR-D1, the requirements of the Code are impractical. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i). The relief granted is authorized by law and will not endanger life or property, or the common defense and security, and is otherwise in the public interest. In making this determination, the staff has considered the burden upon the licensee that could result if the requirements were imposed on the facility.

With respect to Relief Request No. RR-B3, the proposed attemative provides an acceptable level of quality and safety. Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).

A summary of the NRC action on each relief request is provided in Attachment 1 to this SE.

Attachments: 1. Summary of Relief Requests and Proposed Altematives

2. Technical Letter Report Principal Contributor: P. Patnaik Date: July 22, 1999 l

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l l TECHNICAL LETTER REPORT l ON FIRST 10-YEAR INTERVAL INSERVICE INSPECTION

) REQUESTS FOR RELIEF FOR l PUBLIC SERVICE ELECTRIC AND GAS COMPANY (PSE&G)

HOPE CREEK GENERATING STATION DOCKET NUMBER: 50-354

1. INTRODUCTION By letter dated March 3,1998, the licensee, Public Service Electric And Gas Company (PSE&G), submitted four requests, seeking relief from the requirements of the ASME Code,Section XI, for the Hope Creek Generating Station. The licensee submitted additionalinformation regarding these requests and one additional request in a submittal dated December 15,1998. These relief requests are for the first 10-year inservice inspection (ISI) interval. The Idaho National Engineering and Environmental Laboratory (INEEL) staff's evaluation of the subject requests for relief are in the following section.

2. EVALUATION The information provided by PSE&G in support of the requests for relief from Code requirements has been eva!uated and the bases for disposition are documented below.

The Code of record for the Hope Creek Generating Station, first 10-year ISI interval, which began December 20,1986, is the 1983 Edition through Summer 1983 Addenda of Section XI of the ASME Boiler and Pressure Vessel Code.

l A. Recuest for Relief RR-B1 (Part 1L Examination Cateoorv B-A. Items B1.12. B1.22. and B1.30. Pressure Retainino Reactor Pressure Vessel Welds l

Code Recuirement: Examination Category B-A, Item B1.12, B1.22, and B1.30 requires 100% volumetric examination of pressure retaining longitudinal shell, meridional head, and shell-to-flange pressure retaining welds in the reactor pressure vessel (RPV) as defined by Fig. Nos. IWB-2500-2, -3, and -4, respectively, each inspection interval.

ATTACHMENT 2 1

2 Licensee's Code Relief Reauest: Pursuant to 10 CFR 50.55a(g)(5)(iii) the licensee has requested relief from performing volumetric examinations to the extent required by the Code for the inaccessible portions of the Category B-A weld examination areas identified in the following table.

Class 1, Category B-A Welds Code Comp. lD item No. Licensee's Basis for Relief RPV1-W3 B1.30 " Ultrasonically examined [using 45 & 60 degree M-UT and 45 & 60 degree manual UT in the areas of the thermocouple attachment lug restrictions and areas not covered by M-UT) a total of 49.2% of the code required volume.

"The flange configuration prohibts scanning from the flange side of the weld.

Thermocouple pads limited scanning from the shell side of the Weld, as shown in tsb labeled 100005 of RR-B1 Manual and automated UT Exams were employed for maximum coverage."

RPV1-W12-2 B1.12 " Ultrasonically examined (using 45 & 60 degree M UT and 45 & 60 degree manual UT) a total of 79.0% of the code required volume. The examinations were restricted near the W4 weld intersection, due to the pror.irrRy of a vessel stabilizer bracket.

" Manual UT exams were performed in the limited area. The M-UT examinations were also restricted due to the proximity of the NSB nozzle near the intersection with weld W5, as shown in tab labeled 100060 of RR-B 1."

l RPV1-W12 3 81.12 " Ultrasonically examined (using 45 & 60 degree M-UT and 45 & 60 degree manual UT) a total of 78.7% of the code required volume. The examinations were restricted near the W4 weld intersectbn, due to the proximity of a vessel stabilizer support bracket.

Manual UT exams were performed in this area. The M-UT examinations were also restricted due to the proximity of the N11D nozzle and a welded insulation pad located just above the N11 D nozzles, as shown in tab labeled 100065 of RR-B1."

RPV1-W13 2 B1.12 " Ultrasonically oxamined (using 45 & 60 degree M-UT and 45 & 60 degree manualVT) a totalof 89.0% of the code required volume. The examinations were restricted near the intersection with cire. Weld W-6, due to the proximity of the N17B & N16C nozzle.

"The M-UT exams were also restricted on the right side of the weld, due to ,

the proximity of the N9A nozzle, as shown in tab labeled 100067 of RR-B1." l RPV1 W16-1 B1.22 "Ultrasoncally examined (using 45 & 60 degree UT) a total of 77.9% of the code required volume. The examinations were restricted, due to the proximity of the vessel support skirt, as shown in tab labeled 100100 of RR-B 1."

RPV1 W16-2 81.22 " Ultrasonically examined (using 45 & 60 degree UT) a total of 77.9% of the code required .olume. The examinations were restricted, due to the proximity of the vesset support skirt, as shown in tab labeled 100105 of RR-B 1."

RPV1-W 16-3 B1.22 " Ultrasonically examined (using 45 & 60 degree UT) a total of 77.9% of the code required volume. The examinations were restricted, due to the proximity of the vessel support skirt, as shown in tab labeled 100110 of RR-B 1."

3 code Comp.lD hem No. Licensee's Basis for Relief RPV1-W16-4 B1.22

Ultrasonically examined (using 45 & 60 degree UT) a total of 77.9% of the code required volume. The examinations were restricted, due to the proximity of the vessel support skirt, as shown in tab labeled 100115 of RR-B 1."

RPV1-W 16-5 B1.22 " Ultrasonically examined (using 45 & 60 degree UT) a total of 77.9% of the code required volume. The examinatons were restricted, due to the proximity of the vessel support skirt, as shown in tab labeled 100120 of RR-B 1."

RPV1-W16-6 B1.22 " Ultrasonically examined (using 45 & 60 degree UT) a total of 77.9% of the code required volume. The examinations were restricted, due to the proximty of the vessel support skirt, as shown in tab labeled 100125 of RR-B 1.*

RPV1-W16 7 B1.22 " Ultrasonically examined (using 45 & 60 degree UT) a total of 77.9% of the code required volume. The examinatons were restricted, due to the proximity of the vessel support skirt, as shown in tab labeled 100130 of RR-B 1."

RPV1-W16-8 B1.22 " Ultrasonically examined (using 45 & 60 degree UT) a total of 77.9% of the code required volume. The examinations were restricted, due to the proximty of the vessel support ::kirt, as shown in tao labeled 100135 of RR-B 1."

Licensee's Basis for Reouestino Relief (as stated):

"For each of the subject examination areas, geometric configuration and permanent obstructions affect the ability to obtain complete Code coverage. The prevailing limitations and ine specific reliefs for each weld are noted in Attachment 2 (above table) along with the individual weld numbers, the estimated areas of coverage, and the bases for limitation.

"The subject welds received volumetric examination by radiography and/or surface examinations during fabrication in accordance with ASME Section lli requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds prior to plant operation."

Licensee's Proposed Altemative Examination (as stated): 1 1

"Altemate examinations were considered for each exam area where a limitation exists; however, no attemate examinations were considered to be appropriate.

"The system pressure test conducted on the Class 1 pressure boundaries provides an acceptable level of assurance of system integrity and plant safety."

Evaluation: The Code requires 100% volumetric examination of pressure retaining longitudinal shell, meridional head, and shell-to-flange reactor pressure vessel welds.

However, complete volumetric examination is limited by physical obstructions, such as 1

4 1

~

1 4

the proximity of the weld area to the vessel support skirt, nozzles, weldments, or welded thermocouple pads that obstruct access to the examination area (these limitations are described and/or shown in the attachments to the licensee's submittal dated December 15,1998),. Therefore, the Code coverage requirements are impractical for ti,ese welds.

To complete the examinations to the extent required by the Code the licensee would have to redesign and modify the reactor pressure vessel. Imposition af the Code requirements would result in a considerable burden on the licensee. ,

The licensee has examined the subject welds to the extent practical, attaining approximately 49% of the cumulative code-required coverage for weld RPVI-W3. The licensee has completed a significant portion of the Code required volumetric examination

(>78%) for the remaining welds. Therefore, any significant pattems of degradation would have been detected by the examinations that were completed and reasonable assurance of the structural integrity of these longitudinal shell, meridional head, and shell-to-flange pressure retaining welds has been provided.

Based on the impracticality of meeting the Code coverage requirements for the subject welds, and the reasonable assurance provided by the examinations that are completed, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i). ,

i B. Reauest for Relief RR-B1 (Part 2). Examination Cateaorv B-D. Item B3.90. RPV Nozzle-to-Vessel Welds Code Reauirement: Examination Category B-D, item B3.90 requires 100% volumetric examination of all RPV pressure retaining nozzle-to-vessel welds as defined by Figs.

lWB-2500-7(a) through (d), as applicable, each inspection interval. ,

Licensee's Code Relief Reauest: Pursuant to 10 CFR 50.55a(g)(5)(iii) the licensee has

! requested relief from performing volumetric examinations to the extent required by the l

Code for the inaccessible portions of the RPV closure head nozzle-to-vessel welds I

identified in the following table.

~

l 5 i

Class 1. Category B D Welds Code item

]i Comp.ID No. Licensee's Examination Coverage and Bases for Relief RPV1 N1B B3.90 " Ultrasonically examined (using 45 & 60 degree M-UT and 45 & 60 degree manual UT) a totalof 71.44"'.of the code required volume. The examinatons were restricted, due to proximity of the N1B door guide rails on the left and right sides of the nozzle, and the norrie configuration as shown ,

in tab labeled 100190 cf RR B1 Manual UT eAaIr S were performed in the restricted areas."

RPV1-N2D B3.90 " Ultrasonically examined rusing 45 & 60 degree M UT) a total of 79.7% of the code required volume. Tha nozzle configuraton limits effective examination .

of the full nozzle and the M-UT So degree T-scan examinatons were i restricted, due to proximity of the NBA nozzle, as shown in tab labeled 100210 of RR-B1."

RPV1-N2E B3.90 " Ultrasonically examined (using 45 & 60 degree M-UT) a total of 76.9% of the code required volume. The examinations were restncted, near the nozzle due to the configuration of the outer diameter blend radius, as shown in tab labeled 100215 of RR-B1."

RPV1-N2F B3.90 "Uhrasonically examined (using 45 & 60 degree M-UT) a total of 77.5% of the code required volume. The examinations were restricted, due to nozzle configuration, as shown in tab labeled 100220 of RR-B1."

RPV1 N2G B3.90 " Ultrasonically examined (using 45 & 60 degree M-UT) a total of 77.5% of the code required volume. The examinatons were restricted, due to nozzle configuration, as shown in tab labeled 100225 of RR-B1."

RPVI-N2H B3.90 " Ultrasonically examined (using 45 & 60 degree M-UT) a total of 73.9% of the code required volume. The examinations were restricted, due to nozzle configuratio') and the proximity of the N8 nozzle, as shown in tab labeled 100230 of RR-B1."

Licensee's Basis for Recuestina Relief (as stated):

"For each of the subject examination areas, geometric configuration and permanent obstructions affect the ability to obtain complete Code coverage. The prevailing limitations and the specific reliefs for each weld are noted in Attachment 2 [above table) along with the individual weld numbers, the estimated areas of coverage, and the bases for limitation. i "The subject welds received volumetric examination by radiography and/or surface examinations during fabrication in accordance with ASME Section til requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds prior to plant operation."

i l

Licensee's Proposed Altemative Examination (as stated): '

"Altemate examinations were considered for each exam area where a limitation exists; however, no altemate examinations were considered to be appropriate.

l "The system pressure test conducted on the Class 1 pressure boundaries provides an

! acceptable level of assurance of system integrity and plant safety."

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6 Evaluation: The Code requires 100% volumetric examination of the subject RPV nozzle-to vessel welds. However, as shown in the drawings provided by the licensee, nozzle configurations and outside surf ace geometry restrict access and make 100% volumetric examination of these welds impractical to perform. To complete the examinations to the extent required by the Code the licensee would have to redesign and modify the reactor pressure vessel. Imposition of the Code requirements would result in a considerable burden on the licensee.

The licensee has examined the subject welds to the extent practical, attaining greater than approximately 71% of the cumulative code-required volumetric coverage for these welds. Therefore, any significant existing pattems of degradation should have been detected by the examinations that were completed and reasonable assurance of the structuralintegrity of these nozzle-to-vessel pressure retaining welds has been provided.

Based on the impracticality of meeting the Code coverage requirements for the subject welds, and the reasonable assurance provided by the examinations that can be completed, it is recomrnended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

C. Reauest for Relief RR-B1 (Part 3). Examir.ation Cateaorv B-H. Item B8.10.RPV Intearally Welded Attachments I

Code Reauirement: Examination Category B H, item B8.10 requires 100% volumetric or '

surface examination of RPV integrally welded attachments as described in Figure IWB-2500-13, -14, and -15, each inspection interval.

Licensee's Code Relief Reouest: Pursuant to 10 CFR 50.55a(g)(5)(iii) the licensee has requested relief from performing volumetric examinations to the extent required by the Code for the inaccessible portions of the attachment Weld RPV1-WSB(1-8) as identified in the following table.

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Class 1, Categont B-H Welds Comp.lD Cooe Licensee's Examination Coverage and Bases for Relief hem Ne.

RPV1 WsB(1-8) 88.10

Examined (MT) a total of 34.0% and 59,0% (bracket 0 and 45 degree respectivey out 8 brackets) of the code required surface. The exam was restricted, due to permanenty installed insulation support brackets, as shown in tab labeled 100889 of RR-B1."

Licensee's Basis for Reouestino Relief (as stated):

"For each of the subject examination areas, geometric configuration and permanent l

obstructions affect the ability to obtain complete Code coverage. The prevailing limitations and the specific reliefs for each weld are noted in Attachment 2 [above table] ;

along with the individual weld numbers, the estimated areas of coverage, and the bases '

for limitation.

1 "The subject welds received volumetric examination by radiography and/or surface examinations during fabrication in accordance with ASME Section 111 requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds prior to plant opera!!on." ,

Licensee's Proposed Altemative Examination (as stated):

"Altemate examinations were considered for each exam area where a limitation exists; however, no attemate examinations were considered to be appropriate.

"The system pressure test conducted on the Class 1 pressure boundaries provides an acceptable level of assurance of system integrity and plant safety."

Evaluation: The Code requires 100% volumetric or surface examination of integrally ,

welded attachments. However, as shown in the drawings provided by the licensee, complete surface or volumetric examination is limited by permanently installed insulation support brackets that obstruct access to the examination area. Therefore, the Code examination coverage requirements are impractical for these welds. To complete the examinations to the extent required by the Code the licensee would have to redesign and modify the insulation support brackets on the RPV. Imposition of the Code requirements would result in a considerable burden on the licensee.

l The licensee has examined the subject welds to the extent practical, attaining 34.0%

Code-required surface coverage of the attachment bracket at 0 degrees and 59% of the bracket at 45 degrees using magnetic particle testing. Therefore, any significant pattems of degradation should have been detected by the examinations that were completed and

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reasonable assurance of the structuralintegrity of these nozzle-to-vessel pressure retaining welds has been provided.

Based on the impracticality of meeting the Code coverage requirements for the subject welds, and the reasonable assurance provided by the examinations that can be completed, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

D. Reauest for Relief RR B1 (Part 4). Examination Cateaory B-J. Items 89.11 and 89.12.

Pressure Retainina Circumferential Pipe Welds Code Reauirement: Examination Category B-J, items B9.11and 89.12 require 100%

surface and volumetric examination of, circumferential and longitudinal welds in pressure retaining piping NPS 4 or larger, as defined by Fig. No. IWB-2500-8, each inspection interval.

Licensee's Code Polief Reauest: Pursuant to 10 CFR 50.55a(g)(5)(iii) the licensee has requested relief from performing surface and volumetric examinations to the extent required by the Code for the welds identified in the following table.

Class 1, Category B-J Welds Code Comp.lD item No. Licensee's Examination Coverage and Bases for Relief Weld 7 89.11

Examined (MT) a total of 70.5% of the code required surface. The line AB-26DLA-030 examination was restricted, due to a permanently installed instrumentation bracket and brar.ket banding, as shown in tab labeled 101850 of RR-B1. A 100% UT exam was performed on the Code required volume."

Weld 5 B9.11

Examined (MT) a total of 87.0% of the code required surface. The line AB-26DLA-033 examination was restricted, due to a permanent box support pad interference (no drawings are available). A 100% UT exam was performed on the Code required volume."

Weld 8 89.11

Examined (PT) a total of 80.0% of the code required surf ace, due line AB ESDLA-033 to a con;ponent support obstruction, as shown in tab labeled 102835 of RR-B1. A 100% UT exam was performed on the Code i required volume."

Weld 4 89.11

Examined a totaf of (MT) 85.3% & (UT) 89.7% of the code required hne FD-10DBA-001 surface & volume. The examinations were restriction, due to a pipe restraint interference (3/8" clearance wth pipe. restraint) as shown in tab labeled 110565 of RR-B1.*

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9 Code Comp.lD ltem No. Licensee's Examination Coverage and Bases for Relief Weld S B9.11 " Examined (MT) a totalof 70.6% of the code required surface. The hne FD-10DBA-001 examinaton was restricted, due to a ppe restraint interierence at 0

& 180 degrees as shown in tab labeled 110575 of RR-B1."

Weld 2LD 89.12

Examined a total of (PT) 87.5% and UT (83.3%) of the code line BE-12DLA-023 required surface & volume. The examinations were restricted, due to the interference of two welded strapping bands, as shown in tab labeled 109106 of RR-B1."

Weld SLD B9.12 " Ultrasonically examined (using 45 degree UT ) a total of 58.0% of line BB-28VCA-014 the code required volume. The examinations were restricted. due to a component support interference (no examination coverage from length equals 7"to 12" (5" of the weld was restricted) (no drawings are available). A 100% PT exam was performed on the Code required volume."

Licensee's Basis for Reauestina Relief (as stated):

"For each of the subject examination areas, geometric configuration and permanent obstructions affect the ability to obtain complete Code coverage. The prevailing limitations and the specific reliefs for each weld are noted in Attachment 2 (above table) along with the individual weld numbers, the estimated areas of coverage, and the bases for limitation.

'The subject welds received volumetric examination by radiography and/or surf ace examinations during fabrication in accordance with ASME Section 111 requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds prior to plant operation."

Licensee's Proposed Altemative Examination (as stated):

"Altemate examinations were considered for each exam area where a limitation exists; however, no attemate exarninations were considered to be appropriate.

"The system pressure test conducted on the Class 1 pressure boundaries provides an acceptable level of assurance of system integrity and plant safety."

Evaluation: The Code requires 100% volumetric and surface examinations of circumferential and longitudinal welds in Class 1, pressure retaining piping NPS 4 or l larger. However, the extent of surface and volumetric examinations of item B9.11, circumferential Welds 4 and 6 are limited by interference from pipe supports that l obstruct access to the examination areas. The extent of surface examinations of circumferential Welds 5,7, and 8 are limited by a permanently installed box support pad, i an instrumentation bracket and bracket banding, and a component support, respectively.

Therefore, the Code volumetric and/or surf ace coverage requirements are impractical for l

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these welds. To complete the examinations to the extent required by the Code the licensee would have to redesign and modify the subject piping and/or support pad.

Imposition of the Code coverage requirements would result in a considerable burden on the licensee.

The licensee has performed examinations of item B9.11 Welds,4,5,7, anc 8 to the extent practical, attaining 87.0%,70.5%, and 80.0% of the cumulative code-required surface coverage, respectively, and 100% volumetric coverage for these welds. Item B9.11, Weld 4, was examined with a total of 85.3% surface and 89.7% volumetric coverage. Therefore, any significant pattems of degradation of these welds should have been detected by the examinations that were completed and reasonable assurance of the structuralintegrity of these circumferential welds in pressure retaining piping NPS 4 has been provided.

The extent of surface and volumetric examinations of item B9.12 longitudinal Welds 2LD l

and SLD was limited by welded strapping bands and a component support interference, respectively, that obstructs access to the weld area. Therefore, the Code volumetric l and/or surface coverage requirements are impractical for these welds. To complete the examinations to the extent required by the Code the licensee would have to redesign and modify the subject piping. Imposition of the Code coverage requirements for these welds I would result in a considerable burden on the licensee.

l l The licensee has examined Welds 2LD and SLD to the extent practical. Weld 2LD received greater than approximately 87.5% of the Code-required surface and 83.3% of the Code-required volumetric coverage. Weld SLD received a total of 58.0% of the Code-required volumetric and 100% of the Code-required surface coverage. Therefore, any ;

significant pattems of degradation of these welds should have been detected by the examinations that were completed and reasonable assurance of the structuralintegrity of these longitudinal welds has been provided.

Based on the impracticality of meeting the Code coverage requirements for the subject examination areas, and the reasonable assurance provided by the examinations that can

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l 11 be completed,it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i) for Welds 4,5,7,8,2LD, and SLD.

Item B9.11, Weld 6 was examined with a totai of 70.6% sarface coverage; however, the licensee has provided neither information regarding volumetric examination coverage for Weld 6, nor past examinations and examination results which provide reasonable assurance of structural integrity. The licensee may propose to use an authorized altemative or to obtain relief from the Code requirements, however, the licensee must provide adequate information to evaluate to make one of the following determinations as required by 10 CFR 50: 1) 10 CFR 50.55a(a)(3)(i)- the proposed altematives would provide an acceptable level of quality and safety, or; 2) 10 CFR 50.55a(a)(3)(li)-

compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or 3) i 10 CFR 50.55a(g)(6)(i) - the Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such altemative requirements as it determines is authorized l by law and will not endanger life or property or the common defense anri security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

The licensee has not provided sufficient information to support a determination that relief should be granted for item B9.11 Weld 6 according to the criteria of 10 CFR 50.55a.

Therefore, relief should not be granted. The licensee should comply with the Code examination requirements or resubmit the request for Weld 6 (line 1-FD-10DBA-001),

identifying the regulatory basis; equivalency, hardship, or impracticality, as stated in 10 i CFR 50.55a, and other needed information, such as the results of other examinations !

that have been performed, to support an adequate review and favorable determination.

! E. Reouest for Relief RR-B1 (Part 5). Examination Cateoorv B-J. Items 89.21. Pressure Retalnina Circumferential Ploe Welds Less Than 4 inch NPS Code Reauirement: Examination Category B-J, item B9.21 requires 100% surface I

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12 examination of circumferential welds in pressure retaining piping less than NPS 4 as defined by Fig. No. IWB-2500-8, each inspection interval.

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Licensee's Code Relief Reouest: Pursuant to 10 CFR 50.55a(g)(5)(iii) the licensee has I requested relief from performing surface examinations to the extent required by the Code for the welds identified in the following table.

Class 1, Category B-J Welds Code Comp.lD ltem No. Licensee's Examination Coverage and Bases for Relief Weld 3 B9.21

Examined (MT) a totalof 45.5% of the code required suMace. The line BH 2CCA-011 examination was restricted, due to the close proximity of a wall. (No drawings are available)"

Weld 7 89.21 " Examined (PT) a totalof 60.0% of the code required surface. The line BH 2CCA-011 exarnination was restricted, due to the close proximity of a wall. (No drswings are availablef Weld 1 B9.21

Examined (PT) a totalof 46.2% of the code required surface. The line BH-1.50CCA-011 examination was restrkted, due to the close proximity of a wall (only 3" of 6.5" total weld length was examined) (no drawings are availablef Weld 12B 89.21 " Examined (PT) a totalof 0% of the code required surface. The line BH-1.50CCA-011 examination was restricted, due to the weld location being within penetration P-18 (inaccessble weldj, as shown in tab labeled 112414 of RR B1."

Weld 12C B9.21

Examined (PT) a totalof 0% of the code required surface. The line BH-1.50CCA-011 examination was restricted, due to the weld location being within penetration P 18 (inaccessible weld), as shown in tab labeled 112416 of RR-B1."

Weld 12D B9.21

Examined (PT) a totalof 0% of the code required surface. The line BH-1.50CCA-011 examination was restricted, due to the weld location being within penetration P-18 (inaccessible weki), as shown in tab labeled 112418 of RR-B1.*

Licensee's Basis for Reouestino Relief (as stated):

"For each of the subject examination areas, geometric configuration and permanent obstructions affect the ability to obtain complete Code coverage /The prevailing limitations and the specific reliefs for each weld are noted in Attachment 2 [above table] ,

along with the individual weld numbers, the estimated areas of coverage, and the bases I fo( limitation.

"The subject welds received volumetric examination by radiography and/or surf ace examinations during fabrication in accordance with ASME Section ill requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds prior to plant operation."

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13 Licensee's Proposed Alternative Examination (as stated): ;

"A; ternate examinations were considered for each exam area where a limitation exists; however, no alternate examinations were considered to be appropriate.

"The system pressure test conducted on the Class 1 pressure boundaries provides an acceptable level of assurance of system integrity and plant safety." 1 Evaluation: The Code requires 100% surface examination of circumferential welds in Class 1, pressure retaining piping less than NPS 4. The licensee has examined Item 89.21 Welds 1,3, and 7, attaining approximately 46.2%,45.5%, and 60.0% surface coverage, respectively. No surface examination coverage was achieved on item 89.21 Welds 128,12C, and 12D.

The licensee has stated that it is impractical to examine 100% of the Code-required surf ace for Welds 1,3, and 7 because access is limited by the proximity of a nearby wall.

However, the licensee has not provided drawings and has not provided a sufficiently detailed description of the limitations for the reviewer to judge whether compliance with the Code requirements is indeed impractical.

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The licensee may propose to use an authorized attemative or to obtain relief from the Code requirernents, however, the licensee must provide adequate information to evaluate to make one of the following determinations as required by 10 CFR 50: 1) 10 CFR 50.55a(a)(3)(i)- the proposed alternatives would provide an acceptable level of quality and safety, or; 2) 10 CFR 50.55a(a)(3)(ii) - compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or 3) 10 CFR 50.55a(g)(6)(i) the Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such altemative requirements as it determines is authorized by law and will not endanger life or propedy or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were impcsed on the facility.

The licensee has not provided sufficient information to support a determination that relief

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l 14 should be granted according to the criteria of 10 CFR 50.55a. Therefore, relief should not be granted for Welds 1,3, and 7. The licenseo should comply with the Code examination requirements or rcsubmit this request, identifying the regulatory basis; equivalency, hardship, or impracticality, as stated in 10 CFR 50.55a, and other needed information. such as the specific physical or geometrical obstructions and the results of other examinations that have been performed, to support an adequate review and favorable determination.

The licensee also stated that surface examination (PT) of Welds 128,12C, and 12D, is not practical due to their location inside containment penetration P 18. The inaccessibility I of these welds makes compliance with the Code requirements irnpractical. To complete the Code required examinations, the licensee would have to redesign and modify the piping and/or the containment penetration. Based on the impracticality of performing the )

Code required surface examinations, it is recommended that relief be granted for Welds 1 12B,12C, and 12D pursuant to 10 CFR 50.55a(g)(6)(i). t i

I F. Reouest for Relief RR B1 (Part 6L Examination Cateaory B-J. Item B9.31. Class 1 Component Limited Exams. j Code Reauirement: Examination Category B-J, item B9.31 requires 100% surf ace and volumotric examination of branch pipe connection welds in pressure retaining piping NPS 4 or larger, as defined by F!gures IWB-2500-9,10, and 11 each inspection interval. i Licensee's Code Relief Reauest: Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee has I

requested relief from performing volumetric examinations to the extent required by the Code for the welds identified in the following table. '

l Class 1., Category B-J Welds Code Comp.ID item No. Licensee's Examination Coverage and Bases for Relief l

Weld 6BC1 89.31

Ultrasonically examined (using 45 degrees) a total of 82.0% of the Ene AB-26DLA-033 code required volume, due to a permanently installed restraint interference,(no drawings are available).100% MT exam was performed on the Code required surface."

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I 15 Code Comp.lD ltem No. Licensee's Examination Coverage and Bases for Relief Wold 3BC1 B9.31 " Ultrasonically examined (using 45 and 60 degree UT ) a total of line BB-22VCA-014 85.0% of the code required volume. The examinations were restricted, due to a whip restraint interference (no drawings are available).100% PT exam was performed on the Code required surface."

Licensee's Basis for Reouestino Relief (as stated):

"For each of the subject examination areas, geometric configuration and permanent obstructions affect the ability to obtain complete Code coverage. The prevailing limitations and the specific reliefs for each weld are noted in Attachment 2 (above table]

e along with the individual weld numbers, the estimated areas of coverage, and the bases for limitation.

"The subject welds received volumetric examination by radiography and/or surface examinations during fabrication in accordance with ASME Section Ill requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds prior to plant operation."

Licensee's Proposed Attemative Examination (as stated):

"Altemate examinations were considered for each axam area where a limitation exists; however, no attemate examinations were considered to be appropriate.

"The system pressure test conducted on the Class 1 pressure boundaries provides an acceptable level of assurance of system integrity and plant safety."

Evaluation: The Code requires 100% volumetric and surface examinations of branch pipe connection welds in Class 1, pressure retaining piping NPS 4 or larger. The volumetric examinations of item B9.31 branch pipe connection Welds 6BC1 and 3BC1 are limited due to permanently installed restraint interference and whip restraint interference, respectively, that obstruct access to the examination area. Therefore, the Code volumetric coverage requirements are impractical for these welds. To gain access for examination of these welds, the pipe restraints would have to be removed and reinstalled, or redesigned and modified. Imposition of the Code coverage requirements for these welds would result in a considerable burden on the licensee.

The licensee has examined Welds 6BC1 and 3BC1 to the extent practical, attaining significant volumetric coverage of 82.0% and 85.0%, respectively. The licensee also completed 100% of the required surface examination for these welds. Therefore, any f

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! 16 significant pattems of degradation would have been detected by the examinations that were completed and reasonable assurance of the structuralintegrity of these branch pipe connection welds has been provided.

Based on the impracticality of meeting the Code coverage requirements for the subject examination areas, and the reasonable assurance provided by the examinations that can be completed, it is recornmended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

G. Reouest for Relief RR B1. Examination Cateoorv B-K-1. Item B10.10. Class 1 Component Limited exams.

Code Reauirement: Examination Category B-K-1, item B10.10 requires 100% surface or volumetric examination of integrally welded attachments to piping as defined by Figures

!WB-2500-13, -14, and -15, each inspection interval.

Licensee's Code Relief Reauest: Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee has requested relief from performing surface examinations to the extent required by the Code for the inaccessible portions of the Category B-K-1, Item B10.10, attachment weld examination areas as identified lii the following table.

Class 1, Category B-K-1 Welds Code Cornp.10 item No. Licensee's Examination Coverage and Bases for Relief 17LG (1 -8) B10.10 " Examined (MT) a totalof 83.0% of the code require l surf ace. The line AE-24DLA-035 examination was restricted. due to a component support obstructon on one side (2") of each of the eight lugs. (No drawrigs are available)"

5LG (1-8) 810.10

Examined (MT) a total of 87.5% of the code required surf ace. The

, line AE-12DLA-035A examination was restricted, due to a component support obstruction on one side (2") of each of the eight lugs. (No drawings are avaliable)"

4LG (1-4) B10.10

Examined (MT) a totalof 87 5% of the code required surface. The line AE-12DLA-035C examination was restricted, due to a componont support obstruction on one side (1") of each of the tour lugs. (No drawings are available)"

4LG (14) B10.10 " Examined gMT) a totalof 71.6% of the code required surface. The line AE-12DLA-036E examination was restricted, due to a componant support obstruction on each of the four lugs, as shown in tab labeled 105120 of RR B1."

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17 Code Comp.1D item No. Licensee's Examination Coverage and Bases for Relief SLG (1-4) 810.10 " Examined (PT) a totalof 84.4% of the code required surface. The I line BB 28VCA-014 examinaton was restricted. due to a component support clamp and shim inteiference on one side of each of the lugs, as shown in tab labeled 106805 of RR-B1." j 11LG (1-8) 810.10 " Examined (MT) s.totalof 83.3% of the code required surface. The line BC-6DBA-003 examination was restrict 6,d, due to a ppe clamp interference on one side of each of the eight lugs. (No drawings are available)"

GLG (1-4) B10,10 " Examined (MT) a totalof 83.3% of the code required surface. The line BC-12DLA-056 examination was restricted, due to a pipe clamp interference on one side (1") of each of the 4 lugs. (No drawings are available)"

16LG (1-4) B10.10 " Examined (MT) a totalof 83.3% of the code required surface. The line BC-12DLA 056 examination was restricted, due to a pipe clamp interference on one side (1") of each of the 4 lugs, as shown in tab labeled 108755 of R R-B 1."

17LG (1-4) 810.10 " Examined (MT) a totalof 71.6% of the code required surface. The line BC-12DLA 056 examination was restricted. due to a component support obstruction at each of the four lugs, as shown in tab labeled 108780 of RR-B1."

18LG (1-4) 810.10 " Examined (MT) a totalof 71.6% of the code required surface. The line BE 12DLA-023 examination was restricted, due to a component support obstruction at each of the four lugs as shown in tab labeled 109500 of RR B1."

Licensee's Basis for Recuestino Relief (as statedh "For each of the subject examination areas, geometric configuration and permanent obstructions affect the ability to obtain complete Code coverage. The prevailing limitations and the specific reliefs for each weld are noted in Attachment 2 [above table) along with the individual weld numbers, the estimated areas of coverage, and the bases for limitation.

"The subject welds received volumetric examination by radiography and/or surf ace examinations during fabrication in accordance with ASME Section kl requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds

, prior to plant ope'ation."

Licensee's Proposed Attemative Examination (as stated):

"Altemate examinations were considered for each exam area where a limitatian exists; I however, no attemate examinations were considered to be appropriate. ;

"The system pressure test conducted on the Class 1 pressure boundaries provides an acceptable level of assurance of system integrity and plant safety." i Evaluation: The Code requires 100% su. ;ce or volumetric examination, as applicable, of integrally welded attachments to Class 1 pressure retaining piping. The licensee has j examined the item B10.10 attachment welds listed in the as se table, attaining between a

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71.6% and 87.5% surf ace coverage. The licensee has stated that it is impractical to l examine 100% of the Code-required surface due to component support obstructions and pipe clamp interferences. Volumetric examinations of these type of welded attachments are not applicable. However, the licensee either has not provided drawings, or the drawings provided do not clearly show the obstructions. Additionally, the licensee has not j provided a sufficiently detailed description of the limitations for the reviewer to judge whether compliance with the Code requirements is indeed impractical.

l The licensee has stated that no practical additional examinations are available to i 1

increase or supplement the limited examinatinns. However, the licensee has not !

provided information supporting this statement. Additionally, the licensee's submittal does not provide information regarding indications (if any) found with the limited surface examination coverage.. I The licensee may propose to use an authorized attemative or to obtain relief from the Code requirements, however, the licensee must provide adequate information to evaluate to make one of the following determinations as required by 10 CFR 50: 1) 10 CFR 50.55a(a)(3)(i)- the proposed attematives would provide an acceptable level of quality and safety, or; 2) 10 CFR 50.55a(a)(3)(ii)- compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or 3) 10 CFR 50.55a(g)(6)(l) the Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements 4

are impractical. The Commission may grant such relief and may impose such altemative requirements as it determines is authorized by law and will not endanger life or 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 result if the requirements were imposed on the facihty.

The licensee has not provided sufficient information to support a determination that relief should be granted according to the criteria of 10 CFR 50.55a. Therefore, relief should not be granted. The licensee should comply with the Code examination requirements or resubmit this request, identifying the regulatory basis; equivalency, hardship, or

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impracticality, as stated in 10 CFR 50.55a, and other needed information, such as the specific physical or geometrical obstructions, results of examinations that have been performed, and the impracticality of other attematives, to support an adequate review and favorable determination.

l H. Request for Relief RR-C1 (Part 11. Examination Cateaorv C-A. Item C1.10. Class 2 Shell Circumferential Welds Code Reouirement: Examination Category C-A, Item C1.10, requires 100% volumetric examination, as defined by Figure IWC-2500-1, for Class 2 pressure retaining vessel shell circumferential welds, each inspection interval.

Licensee's Code Relief Reauest: Pursuant to 10 CFR 50.55a(g)(S)(iii), the licensee has requested relief f rom performing volumetric examinations to the extent required by the Code for the inaccessible portions of the Class 2, Category C-A, weld examination identified in the following table. (The licensee's attachment is excerpted in the following table).

Class 2, Category C-A Welds Comp. Code % of Completed Code Required Exams, Requiring Relief, W/ Limitation ID item No. Descriptions RHX-W4 C1.10 " Ultrasonically examined (using a 4s degree UT) a total of 88.6% of the code required volume. The examination was restricted, due to the flange stud interference, as shown in tab labeled 200080 of RR.C1."

Licensee's Basis for Reouestina Relief (as stated):

"For each of the subject examination areas. geometric configuration and permanent obstructions affect the ability to obtain complete Code coverage. The prevailing limitations and the specific reliefs for each weld are noted in Attachment 3 [above table]

a',ong with the individual weld numbers, the estimated areas of coverage, and the bases for limitation.

"The subject welds received volumetric examination by radiography and/or surface examinations during fabrication in a?cordance with ASME Section XI requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds l prior to plant operation."

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20 Licensee's Proposed Altemative Examination (as stated):

i "Altemate examinations were considered for each exam area where a limitation exists; however, no allemate examinations were considered to be appropriate.

'The system pressure test conducted on the Class 2 pressure boundaries provides an I acceptable level of assurance of system integrity and plant safety." l l

Evaluation: The Code requires 100% volumetric examination of pressure retaining circumferential shell welds in Class 2 pressure vessels. However, complete volumetric examination b limited by interference from the flance studs that obstructs access to the l examination area. Therefore, the Code coverage requirements are impractical for this '

weld. To obtain increased examination enverage, tha component would have to be redesigned and modified. Imposition of the Code requirements would result in a considerable burden on the licensee.

The licensee has examined the subject welds to the extent practical, attaining 88.6% of the cumulative code required coverage for Weld RHX-W4. Therefore, any significant pattems of degradation should have been detected by the examination that were completed and reasonable assurance of the structuralintegrity of the pressure retaining circumferential chell welds has been provided.

Based on the impracticality of meeting the Code coverage requirements for the subject welds, and the reasonable assurance provided by the examinations that were completed, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

l. Reauest for Relief RR-C1 (Part 2). Examination Cateaory C-B. Items C2.21 and C2.22.

Class 2 Limited Exams Code Recuirement: Examination Category C-B, item C2.21 requires 100% surface and

, volumetric examination for Class 2 nozzle-to-shell welds in pressure retaining vessels, as 1

defined by Figures IWC-2500-4(a) or (b), each inspection interval. Examination Category C-B, Item C2.22 requires 100% volumetric examination for Class 2 nozzle inside radius sections, as defined by Figures IWC-2500-4(a) or (b), each inspection interval.

I

21 Licensee's Code Relief Reauest: Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee has ;

requested relief from performing volumetric examinations to the extent required by the Code for the inaccessible portions of the Class 2, Category C-B, weld examinations identified in the foi.owing table. (The licensee 4 attachment is excerpted in the following table).

Class 2, Category C B Welds Comp. Code 10 item No. Licensee's Examination Coverage and Bases for Relief RHX.W6 C2.21 " Ultrasonically examined (using a 4s degree UT) a total of 89.0% of the code required volume. The examinaton was restricted, due to the nozzle configuration (no UT from the nozzle side), as shown in tab labeled 200100 of q R R-C1." j l

RHXIR2 C2.22 Ultrasonically examined (using a 35 degree UT) a total of 26.4% of the code l required volume. The examination was restricted, due to the nozzle blend j radius configuration, as shown in tab labeled 200120 of RR-C1."

Licensee's Basis for Reauestina Relief (as stated):

"For each of the subject examination areas. geometric configuration and permanent obstructions affect the ability to obtain complete Code coverage. The prevailing limitations and the specific reliefs for each weld are noted in Attachment 3 [above table) along with the individual weld numbers, the estimated areas of coverage, and the bases for limitation.

1 "The subject welds received volumetric examination by radiography and/or surface examinations during fabrication in accordance with ASME Section XI requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds prior to plant operation."

Licensee's Proposed Altemative Examination (as stated):

"Altemate examinations were considered for each exam area where a limitation exists; however, no attemate examinations were considered to be appropriate.

"The system pressure test conducted on the Class 2 pressure boundaries provides an acceptable level of assurance of system integrity and plant safety."

Evaluation: The Code requires 100% surface and volumetric examination of Class 2 pressure vessel nozzle-to-shell welds and 100% volumetric examination of nozzle inside 1

i radius sections, However, complete volumetric examination of Welds RHX-W6 and RHX-IR2 is limited by due to the nozzle configuration and the nozzle inner bend radius.

Therefore, the Code coverage requirements are impractical for these welds. To obtain j l

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1 l

22 l increased examination coverage, the vessel would have to be redesigned and modified.

Imposition of the Code requirements wou!d result in a considerable burden on the licensee.

The licensee has examined the subject welds to the extent practical, attaining 89.0% of the cumulative code-required coverage for Weld RHX-W6 and 26.4% coverage for Weld RHX-IR2. Therefore, any significant pattems of degradation should have been detected by the examinations that were completed and reasonable assurance of the structural integrity of the pressure retaining circumferential shell welds has been provided.

Based on the impracticality of meeting the Code coverage requirements for the subject welds, and the reasonable assurance provided by the examinations that were completed, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

J. Reauest for Relief RR-C1 (Part 3). Examination Cateoorv C-C. Items C3.20. Class 2 Intearally Welded Attachments For Pinino Code Reauirement: Examination Category C-C, item C3.20 requires 100% surf ace examination of integrally welded attachments (lugs) for piping, as defined by Figure IWB-2500-5, each inspection interval.

Licensee's Code Relief Reauest: Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee has requested relief from performing surface examinations to the extent required by the Code for the inaccessible portions of the Category C-C, item C3.20, attachment weld examination areas as identified in the following table.

Class 2, Category C-C Welds Code Comp.lD ltem No. Licensee's Examination Coverage and Bases for Relief 13LG (1-8) C3.20 " Examined (MT) a total of 71.2% of the code required surface. The line BC-18GBB-004B examinaton was restricted due to a component support clamp interference, as shown in tab labeled 202368 of RR-C1.*

I .

23 Code Comp.1D item No. Licensee's Examination Coverage and Bases for Relief 11 LG (1-8) C3.20 " Examined (MT) a totalof 80.7% of the code required surface. The line BC-16GBD-004 examinaton was restricted, due to a component support obstruction on one side of each of the eight lugs, as shown in tab labeled 202605 of RR-C1."

11 LG (1-e) C3.20 " Examined (MT) a totalof 76.0% of the code required surface. The line BC-1 BGBB-0019A examination was restricted, due to a component support obstructon on one side of each of the eight lugs, as shown in tab labeled 203255 of RR-C1."

10LG (1-8) C3.20 " Examined (MT) a totalof 49.2% of the code required surface. The line BC-8 DEB-025 examination was restricted, due to a component support obstruction on one side of each of the eight lugs, as shown in tab labeled 203700 of RR-C1."

SLG (18) C3.20

Examined (MT) a totalof 80.7% of the code required surface. The line BC-20HBB-044 examination was restricted, due to a component support obstruction on one side of each of the eight lugs, as shown in tab labeled 204862 of RR-C1."

11LG (1-8) C3.20

Examined (MT) a total of 80.7% of the code required surf ace. The line BC-18GBB-066A examinaton was restricted, due to a component support obstruction on one side of each of the eight lugs, as shown in tab labeled 207105 of RR-C1."

Licensee's Basis for Recuestino Relief (as stated):

"For each of the subject examination areas. geometric configuration end permanent cbstructions affect the ability to obtain complete Code coverage. The prevailing l limitations and the specific reliefs for each weld are noted in Attachment 3 [above table) along with the individual weld numbers, the estimated areas of coverage, and the bases for limitation.

"The subject welds received volumetric examination by radiography and/or surface examinations during f abrication in accordance with ASME Section XI requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds prior to plant operation."

Licensee's Proposed Attemative Examination (as stated):

"Altemate examinations were considered for each exam area where a limitation exists; however, no attemate examinations were considered to be appropriate.

"The system pressure test conducted on the Class 2 pressure boundaries provides an acceptable level of assurance of system integrity and plant safety."

Evaluation: The Code requires 100% surface examination of integrally welded attachments to Class 2 pressure retaining piping. The licensee has examined item C3.20 attachment welds listed in the above table, attaining between 49.2% and 80.7% surface coverage.

24 The licensee has stated that it is impractical to examine 100% of the Code-required surface due to component support obstructions and pipe clamp interferences. However, the drawings provided by the licensee do not clearly show the obstructions. Additionally, the licensee has not provided a sufficiently detailed description of the limitations for the reviewer to judge whether compliance with the Code requirements is indeed impractical.

The licensee has stated that no practical additional examinations are available to increase or supplement the limited examinations. However, the licensee has not provided information supporting this statement. Additionally, the licensee's submittal does not provide information regarding indications (if any) found with the limited surf ace examination coverage.

The licensee may propose to use an authorized attemative or to obtain relief from the Code requirements, however, the licensee must provide adequate information to evaluate to make one of the following determinations as required by 10 CFR 50: 1) 10 CFR 50.55a(a)(3)(l)- the proposed attematives would provide an acceptable level of quality and safety, or,2) 10 CFR 50.55a(a)(3)(ii) - compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or 3) 10 CFR 50.55a(g)(6)(i) the Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such attemative requirements as it determines is authorized by law and will not endanger life or 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 result if the requirements were imposed on the facility.

The licensee has not provided sufficient information to support a determination that relief should be granted according to the criteria of 10 CFR 50.55a. Therefore, relief should not be granted. The licensee should comply with the Code examination requirements or resubmit this request, identifying the regulatory basis; equivalency, hardship, or impracticality, as stated in 10 CFR 50.55a, and other needed information, such as the

specific physical or geometrical obstructions, and the results of examinations that have

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l 25 been performed, and the impracticality of other alternatives, to support an adequate review and favorable determination.

K. Reauest for Relief RR-C1 (Part 4). Examination Category C-G. Item C6,10. Class 2 Pumo Casina Welds Code Reauirement: Examination Category C-G, item C6.10 requires 100% surface examination for Class 2 pressure retaining pump c3 sing welds, as defined by Figure IWC-2500-8, each inspection interval.

Licensee's Code Relief Reauest: Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee has requested relief from performing surface examinations to the extent required by the Code for the Class 2, Category C-G, welds identified in the following table. (The licensee's attachment is excerpted in the following table).

Class 2. Category C-G Welds Comp. Code ID ltem No. Licensee's Examination Coverage and Bases for Relief CSP-W1 C6.10

Examined (MT) a total of 0% of the code require surface. The examination was inaccessble, due to the pump cover section being within a concrete pump padestal, as shown in tab labeled 250120 of RR C1."

CSP W2 C6.10

Examined (PT) a total of 73.0% of the code required surf ace. The examination was restricted, due to the proximity of a pump support obstruction, as shown in tab labeled 250130 of RR-C1."

CSP-W5 C6.10

Examined (PT) a total of 0% of the code required surface. The examination was inaccessible, due to the flange bolting interference, as shown in tab labeled 250155 of RR C1."

RHP-W1 C6.10

Examined (MT) a total of 0%, of the code required surface. The weld is inaccessble, due to pump lower section being within a concrete pump pedestal, as shown in tab labeled 250480 of RR C1."

RHP-W2 C6.10

Examined (PT) a totalof 18.0%. of the code required surface. The examination was restricted, due to a concrete pump pedestal obstruction, as shown in tab labeled 250490 of RR-C1."

RHP-W3 C6.10

Examined (PT) a totalof 23.0%. of the code required surface. The examination was restricted, due to a concrete pump pedestal encasement obstruction, as shown in tab labeled 250500 of RR-C1."

Licensee's Basis for Reauestina Relief (as stated):

"For each of the subject examination areas, geometric configuration and permanent obstructions affect the ability to obtain complete Code coverage. The prevailing limitations and the specific reliefs for each weld are noted in Attachment 3 [above table)

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0 26 i 1

along with the individual weld numbers, the estimated areas of coverage, and the bases for limitation.

l "The subject welds received volumetric examination by radiography and/or surface examinations during f abrication in accordance with ASME Section XI requirements.

These examinations provided adequate assurance of the structuralintegrity of the welds prior to plant operation."

Licensee's Proposed Altemative Examination (as stated):

" Alternate examinations were considered for each exam area where a limitation exists; however, no attemate examinations were considered to be appropriate.

l "The system pressure test conducted on the Class 2 pressure boundaries provides an acceptable level of assurance of system integrity and plant safety."

Evaluation: The Code requires 100% surface examination of the pressure retaining Class 2 pump casing welds. The licensee has stated that it is impractical to examine 100% of '

the Code-required sudace because the welds are inaccessible or are obstructed as explained above and shown in the drawings supplied by the licensee (ISI Weld Identification Figures B-2 and B-3). The licensee has examined the subject pump casing welds, attaining 0.0% coverage on the inaccessible welds and between 18.0% and 73.0%

coverage on the welds with restricted access.

ISI Weld Identification Fig. B-2 (for the core spray pumps) and Fig. B-3 (for the RHR pumps) are essentially identical except for the weld numbers. Weld numbers CSPW1 through CSPW5 on the core spray pumps correspond to RHPW1 through RHPW5 on the RHR pumps. Per Figs. B 2 and B-3, the location, orientation, and interferences are identical between the corresponding core spray pump and RHR pump welds (i.e.,

CSPW1 is identical to RHPW1, etc.). Therefore, based on the information supplied by the licensee, one would expect the coverage and accessibility to be the same for corresponding core spray and RHR pump welds. However, the licensee states that only 18.0% coverage is possible on Weld RHP-W2 while 73.0% coverage is possible on Weld CSP W2. The !'censee has requested relief for examination of Welds RHP-W3 and CSP-W5, but not for welds CSP-W3 and RHP-W5. No additional supporting information is available.

The licensee has stated that no practical additional examinations are available to

27 increase or supplement the limited examinations. However, the licensee has not provided information supporting this statement. Additionally, the licensee's submittal does not provide information regarding indications (if any) found with the limited surf ace examination coverage.

The licensee may propose to use an authorized attemative or to obtain relief from the Code requirements, however, the licensee must provide adequate information to evaluate to make one of the following determinations as required by 10 CFR 50: 1) 10 CFR 50.55a(a)(3)(i) - the proposed altematives would provide an acceptable level of quality and safety, or; 2) 10 CFR 50.55a(a)(3)(ii) - compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or 3) 10 CFR 50.55a(g)(6)(i) the Commission will i evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such attemative requirements as it determines is authorized by law and will not endanger life or 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 result if the requirements were imposed on the facility.

l The licensee has not provided sufficient information to support a determination that relief l should be granted according to the criteria of 10 CFR 50.55a. Therefore, relief should

! not be granted. The licensee should comply with the Code examination requirements or resubmit this request, identifying the regulatory basis; equivalency, hardship, or impracticality, as stated in 10 CFR 50.55a, and other needed informatbn, such as the specific physical or geometrical obstructions, and the results of examinations that have been performed, and the impracticality of other allematives, to support an adequate review and favorable determination.

L. Recuest for Relief RR-D1. Examination Cateoorv D-8. Item D2.20. and Cateoorv F-C.

Class 3 Inteoral Attachments and Comoonent Supports Code Reauirement: Examination Category D-8, Item D2.20, requires visual VT-3 examination for Class 3 integral attachments each inspection interval, as defined by

r 28 Figure IWD-25001. Examination Category F-C, requires visual VT 3 examination for component standard supports each inspection interval, as defined by Figure IWF-1300-1.

Licensee's Code Relief Reouest: Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee has requested relief from performing visual VT-3 examinations for the inaccessible Class 3 integral attachment and component support identified in the following table. (The licensee's attachment is excerpted in the following table).

Class 3 Category D-B Integral Attachment and Category F-C Support Comp. Code

-10 item No. Licensee's Examination coverage and Bases for Relief H002-IA D2.20 Examined (VT-3) a totalof 0% of the code required component. This component is inaccessble, a fire barrier enclosure prevents access as shown in tab labeled 303000 of RR D1.

1KJ034H F3.1040 Examined (VT-3) a totalof 0% of the code required component. This component 004 is inaccessible, a fire barrier enclosure prevents access as shown in tab labeled 633490 of RR-D1.

Licensee's Basis for Reouestino Relief (as stated):

"For each of the subject examination areas / component supports permanent obstructions affect the ability to obtain complete Code coverage. The prevailing limitations and the specific reliefs for each area / component supports are noted in the attachment (see above table) along with the individual area / component support identification, the estimated areas of coverage, and the bases for the limitation."

Licensee's Proposed Altemative Examination (as stated):

"Altemative examinations were considered for each exam area where a limitation exists; however, no altemate examinations were considered to be appropriate."

Evaluation: The Code requires VT-3 visual examinations of the integral attachments and component supports for certain Class 3 piping. The licensee has requested relief from the requirements of Category F-C, item No. F3.1040. However, this item number does not exist in the Code. Regardless, the licensee has stated that it is impractical to perform the Code-required inspections for components H002-IA and 1KJ034H004 because they are inaccessible. However, the drawings provided by the licensee do not clearly show I

that the required inspections are impractical. Additionally, the licensee has not provided a sufficiently detailed description of the limitations for the reviewer to judge whether compliance with the Code requirements is indeed impractical.

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29 The licensee has stated that alternatives were considered but were determined not to be appropriate. However, the licensee has not provided specific information regarding the attematives that were considered and the bases for determining that these attematives are impractical.

The licensee may propose to use an authorized altemative or to obtain relief from the Code requirements, however, the licensee must provide adeouate information to evaluate to make one of the following determinations as required by 10 CFR 50: 1) 10 CFR 50.55a(a)(3)(1)- the proposed attematives would provide an acceptable level of quality and safety, or; 2) 10 CFR 50.55a(a)(3)(ii)- compliance with the specified requirements of this section would result in hardship or unusual di!ficulty without a compensating increase in the level of quality and safety; or 3) 10 CFR 50.55a(g)(6)(i) the Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such altemative requirements as it determines is authorized by law and will not endanger life or 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 result if the requirements were imposed on the facility.

The licensee has not provided sufficient information to support a determinatlon that relief should be granted according to the criteria of 10 CFR 50.55a. Therefore, relief should l not be granted. The licensee should comply with the Code examination requirements or resubmit this request, identifying the regulatory basis; equivalency, hardship, or impracticality, as stated in 10 CFR 50.55a, and other needed information, such as the specific physical or geometrical obstructions and the impracticality of other alternatives, to support an adequate review and favorable determination.

l l

M. Reouest for Relief RR-B3. Examination Cateoories B-L-2 and B-M-2. Item Nos. B12.20 and B12.50 Class 1 Pumo Casino and Valve Body Intemal Surfaces Code Reouirement: Examination Categories B-L-2 and B-M-2, items B12.20 and B12.50, require visual VT-3 examination of intemal surfaces for Class 1 pump casings l

1 p

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30 and valve bodies exceeding NPS 4 each inspection interval. I 1

Licensee's Pronosed Alternative: Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee has

~

proposed that visual examinations (VT-3) of pump and valve intemal surf aces be performed consistent with the requirements of ASME Section XI,1989 Edition in lieu of the requirements of the 1983 Edition through 1983 Summer Addenda.

Licensee's Basis for the Proposed Altemative (as stated):

"The requirement to disassemble primary system pumps and valves for the sole purpose of performing a visual examination of the intemal pressure boundary surfaces has only a very small potential of increasing plant safety margins and a very disproportionate impact on expenditures of plant man power, resources, and radiation exposure."

"The performance of both carbon and stainless steel cast pump casings and valve bodies has been excellent in BWR applications. Based on this experience in the industry and regulatory acceptance of these alloys, continued excellent service perfnrmance is anticipated."

"A more practical approach, that would provide an equivalent sampling program and significantly reduce radiation exposure to plant personnel, is to examine the intemal pressure boundary of only those pumps and valves that require disassembly for maintenance purposes. This would continue to provide a reasonable sampling of the primary system pumps and valves and provide adequate assurance that the integrity of these components is being maintained. This approach is supported by ASME Section XI, 1989 Edition, which is approved for use in 10CFR50.55a(b)."

Evaluation: The 1983 Edition of the Code through the Summer 1903 Addenda requires VT 3 visual examination of the intemal weld surfaces of pump casings and valve bodies exceeding NPS 4. The Code requires examination of at least one pump in each group of pumps performing similar functions in the system, and examination of one valve in each group of valves that are of the same constructional design and manufacturing method that perform similar functions in the system.

The 1989 Edition of the Code contains less stringent VT-3 examination requirements for intemal surfaces of pump casings and valve bodies. The 1989 Edition of the Code requires VT-3 examinations of the intemal surfaces only of those pumps and valves that require disassembly for rnaintenance purposes. The visual examination requirements for pump and valve intemals contained in the 1989 Edition of the Code have been reviewed

I e

31 by the NRC staff and approved for use. Use of the pump and valve intemal visual examination requirements listed in the 1989 Code in lieu of the 1983 Code requirements, in conjunction with Code-required pressure and inservice tests, will provide reasonable assurance of the operational readiness of the Class 1 pumps and valves.

Based on the determination that the visual examination requirements of the 1989 Code Edition for the Class 1 pump casings and valve bodies greater than NPS 4 would provide an acceptable level of quality and safety, it is recommended that the licensee's proposed altemative be authorized pursuant to 10 CFR 50.55a(a)(3)(i).

2. CONCLUSION 1

The INEEL staff has reviewed the licensee's submittal and concluded that certain inservice examinations are impractical to perform to the extent required by the Code. For Request for Relief No. RR-B1, Examination Categories B-A, B-D, and B-H, it is recommended that relief be granted pursuant to 10CFR50.55a(g;(6)(i). For Request for Relief No. RR-81, Category B-J, it is recommended that relief be granted pursuant to 10CFR50.55a(g)(6)(i) for the following: Items B9.11 and 89.12, Wel@ 4 (line FD-10DBA-001),5 and 8 (line AB-26DLA-033),7 (line AB-26DLA-030),2LD (line BE-12DLA-023),

and SLD (line BB-28VCA-014); Item B9.21. " Velds 12A,128, and 12C (line BH-1.50CCA-011); Item B9.31, Welds 6BC1 (line AB-26DLA-033) and 3BC1 (line BB-22VCA-014).

For Request for Relief No. RR-C1, Examination Category C-A, item C1.10, Weld RHX-W4; and Examination Category C-B, Items C2.21 and C2.22, Welds RHX-W6 and RHX-IR2, it is recommended that relief be granted pursuant to 10CFR50.55a(g)(6)(i).

Additionally, it is recommended that Request for Altemative No. RR-B3 be granted pursuant to 10CFR50.55a(a)(3)(i).

The INEEL staff concludes that the licensee has not provided adequate information to j support a determination that the Code requirements are impractical, therefore, relief should be denied for Request for Relief No. RR-B1, Examination Category B-J, Item j B9.11, Weld 6 (line FD-10DBA-001); Item B9.21, Weld 1 (line BH-1.50CCA-011); Welds 3 and 7 (line BH 2CCA-011); and the Examination Category B K-1 welds. Additionally, I

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r l

1 *

= , ,

l 32 the INEEL staff concludes that the licensee has not provided adequate information to support a determination that the Code requirements are impractical for Request for Re'Jef No. RR-C1, Examination Category C-C and C G welds, and Request for Relief No. RR-D1. Therefore,it is recommended that relief be denied for these components.

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H. Keiser If you have any questions regarding this matter, please contact the Hope Creek Project f Manager, Richard B. Ennis, at (301) 415-1420.

Sincerely, ORIGINAL SIGNED BY:

James W. Clifford, Chief, Section 2 Project Directorate l Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

Safety Evaluation cc w/ encl: See next page DISTRIBUTION Docket File JClifford OGC PPatnaik PUBLIC REnnis ACRS RScholl(E-Mail SE)

PDI-2 Reading TClark MTschiltz GMeyer, RGN-l l EAdensam (EGA1) GHill(2) ESullivan l

OFFICE PDI-2/PM PDI-2/LA EMCB/SC , OGC PDI-2/SC NAME REnnis: b TClarkN' ESullivan h [/)$to/m@n b rd v -

/

DATE 7 / 1 /99 1 / 9 /99 l /') /99 9 //0 /99 7 / J2/99

. OFFICIAL RECORD COPY DOCUMENT NAME: G:\PDI 2\ Hope Creek \ Sea 1231.wpd i

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l

ML20210F333

Contents

Text

1.0 INTRODUCTION

3.0 CONCLUSION

Enclosure:

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ML20210F333

Text

1.0 INTRODUCTION

3.0 CONCLUSION

Enclosure:

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