ML20211N570
| ML20211N570 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/07/1997 |
| From: | Kofron K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BYRON-97-5224, NUDOCS 9710170011 | |
| Download: ML20211N570 (14) | |
Text
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WRON.97 5224 FILC-13.11.0321 1,.S. Nuclect Regulatory Commission Washington, D.C.
20555 l
Attention:
Document Control Desk
Subject:
13yron Station Responses to NRC Requests for Additional Infonnation (RAl)
Reference:
Letter fro.4 George F. Dick,Jr. (NRC) to Irene Johnson (Comed) dated June 30,.997, transmitting a supplementary Request for Additional Infont ation (RAI) regarding Relief Request NR 20 Attached are Byron Station responses to the referenced letter, requesting additional information related to the Byron First 10-year ISI Frograrn Relief Request NR 20. includes responses to the Request for Additional Infomaation (RAl) dated June 30,1997. Attachment 2 is Relief Request NR 20, Revision 1, for the augmented Reactor Fressure Vesel examination requirement of 10CFR50.55a(g)(6)(ii)(A). Attachment 3 is Relief Request NR 25, Revision 0, for ash!E Code required examination of Category B-A Code item Bl.11 circumferential rhell welds.
Additionally, as discussed in phone conversations with NRR and INEL, Byron Station is i
i forming the NRC via this letter of the extension of the Byron Station Unit 2 First ISI n
Inspection Interval to August 15,1998 as allowed by ash!E 1983 Summer 1983 Addenda lWA-2400(c). Byron Station Unit 2 Commercial Service date is August 22,1987 and as allowed by the referenced paragraph, the First Interval is being extended to encompass Byron Unit 2 refuel outage B2R07 currently scheduled for April throughJune 1998.
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i if you have any questions tegarding this matter, please contact hlarcia Lesniak, Nuclear Licensing Administrator,at 630/663 6484.
Sincerely, b] h
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i K.L.Kofror Station blanager llyron Nuclear Pt. r Station KLK/cb i
Attachment
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A.13 lleach, NRC llegional Administrator - Rlli G. F. Dick,Jr.,13yron Project hianager S. D.13urgess, Senior Resident inspector -Ilyron Oftice of Nuclear Safety - IDNS hiichael T. Anderson, IN!!L
Attaciunent 1 RAI Requests and Responses 1.
For the Category H A,ltem H1.11 Reactor l'essel Circun{crentialShell Welds,it appears that the licensee should have identified this request as an alternalis e pursuant to the augmented reactor vessel examination requirements of 10CFR50.55a(g)(6)(ii)(A).
It appears that the licensee did not meet the augmented reactor vessel volumetric examination requirements of 10CFR50.55a(g)(6)(ii)(A) of essentially 100 percent of the ASM C Code Item H1.11 - Reactor l'essel CircunferentialShell ll' eld; therefore, the licensee must propose an alternative. Consequently, the licensee should: 1) state the correct 10CFR$0.55a paragraph in w hich an alternative is requested: 2) propose an alternative exam 3) justification for using an alternative examination (e.g.,
exams from the OD,if any, stresses on the vessel, equipment used, cic.);.8) identification list of welds and coverage for all the Category B-A, item Hl.10 welds (e.g., circumferential and longitudinal welds); and 5) history of the reactor vessel weld inspections and results.-
Response
Relicf Request NR 20 Hevision 1 (Attachment 2) was revised to request relief pursuant to 10CFR50.55a(g)(6)(ii)(A)(5) on the basis that the alternative to the examination requirements would provide an acceptable level of quality and safety. Funbermore, the relief request revision narrows the request for relief to the augmented requiremems of 10CFR50.55a(g)(6)(ii)(A), removes reference to the ASME Ccde requirements, and eliminates reference to Byron Unit 2. The ASME Code examination requirements are addressed m Relief Request NR 25, Revision O(Attachment 3). Relief Lquest NR 25 is being requested pursuant to 10CFR50.55a(g)(5)(iii) on the basis that confonnance with the ASME Code requirements is impractical. Ilyron Unit 2 augmented examination limitation coverages will be submitted upon completion of the Unit 2 examinations in late spring of 1998.
2.
For the Category H A, item Bl.21 - Reactor VesselLower Head Circumferential Welds,it appears that the licensee should have identified this request as an ASME Code,Section XI, relief request or alternative from/to the Code requirements, it appears that the lleensee is requesting an alternative pursuant to
' 10CFR50.55a(a)(3)(ii) for the Category B-A, Item Hl.21 - Reactor l'essel Lower Head Circumferential Welds and the Category U A, Item Hl.30 - Reactor Venel Shell-to-Flange Welds; however, this is not evideat; therefore,information Is required for the subject welds regarding the 10CFR50.55a requirement since the licensee is requesting relief or alternatiw from/to the Code requirement.
The licensee is requested to: 1) provide the correct 10CFR50.55a paragraph in which the relief / alternative is requested; 2) provide its bases u hy the Code requirement is impractical (10CFR50.55a(g)(6)(i)) or compliance would result in hardship without compensating increase in safety (10CFR50.55a(a)(3)(ii)); amt 3)
provide w hy its proposed alternative prmides reasonable assurar.cc of operational readiness, and in the case of 10CFR50.55a(g)(6)(i) discuss the hurden on the licensee if the Code requirements were imposed.
Response
The sequest for relit f for the Code item Bl.21 - Reactor Vessel Lower llead Circumferential Weld - RPVC WR16 hrs been removed in Relief Request NR 20, I
Revision 1,(Attachment 2) and NR 25, Revision 0 (Attachment 3). The examination tooling employed at Byron Station Unit I achieved an aggregate volume of 81% for weld RPVC WRl6.
In the SER dated August 1991, for Relief Request NR 1, the evaluation states:" The Licensee has stated that the volumetric examination will be performed to the maximum extent practical, which includes a signi0 cat.t percentage of the Code required volume.
Thus the limited volumetric examination will provide reasonable assurance of the continued inservice structural integrity."
The Framatome Technologies Inc. (FTI)"URSULA" delivery system and the FTl "ACCUSONEX" ultrasonic examination system provided 81% aggregate volume coverage as the maximum extent possible. Therefore, Byron Station believes it has met the intent nf the provisions in approved Relief Request NR l.
3.
For the Category ll-A, Item 111.30 - Reactor Vessc/Shell-to-Flange if'e/ds, it appears that the licensee should have identifl' 1 this request as an ASME Code,Section XI, relief request of alternathe from/to the Code requirements, it appears that the licensee is requesting an alternative pursuant to 10CFR$0.55a(a)(3)(ll) for the Category U-A, item 111.21 - Reactor VesselLower Head Circumferential H' elds and the Category U A, Item B1.30 - Reactor Vessel Shc//-to-Flange li'e/ dst how ever, this is not evident; therefore,information is required for the subject welds regarding the 10CFR50.55a requirement since the lictnsee is requesting relief or alternative frmn/to the Code requirement.
The licensee is requested to: 1) provide the correct 10CFR50.55a paragraph in w hich the relief / alternative is requestedt 2) provide its bases why the Code requirement is impractical (10CFR50.55a(g)(6)(i)) or compliance w ould result in hardship without compensating increase in safety (10CFR50.55a(a)(3)(ii))t and 3) provide w hy its proposed alternative provides reasonable assurance of operational readiness, and in the case of 10CFR50.55a(g)(6)(i) discuss the burden on the licensee if the Code requirements were imposed.
Response
The reference to Category B A, item Bl.30 - Reactor Vessel Shell-to-Flange Welds -
component RPVC-WR7 has been removed in Relief Request NR 20, Revision 1.
Previously granted Relief Request NR 1 addressed examination limitations for weld RPVC WR7, however, during DIR07, full 100% Code required volume examination was achieved, and therefore, no reliefis required.
l 11TTilCHMENT 2 i
RELIEF REQUEST i
NR-20 REVISION 1 4
4
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liVRON STATION UNIT I FIRST INTERVAL l
ISI PROGRAM rLAN NRC SUllMITTAL RELIEF REQUEST NR 20 Revision i (Page I of 4) i
[OMPONENT IDENTiflCATIONt Code Class:
1
Reference:
IWil 2500, Table IWil 25001 Examination Category: Il A Item Number:
111.11 Descriptiont Volumetric Examination of Reactor Vessel Circumferential Shell Weld Component Numbers: RPVC WR29
- Drawing Numberst IRPV 1 ISl(Unit 1) f col #E REOUIRF. MENT:
4 l
10CFR50.55a(g)(6)(iiXAX2) requires that all licenses shall augment their Reactor Pressure Vessel (RPV) examination by implementing once, as part of the inservice inspection interval in effect on September 8,1992, the i'
examination requirements for the RPV shell welds specified in item Bl.10 of Examination Category 13 A," Pressure Retaining Welds in Reactor Vessel,"in Table IWD-25001 of Subsection lWB of the 1989 Edition of Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code. For the purpose of this augmented examination,
" essentially 100%" as used in Table IWB 25001 means more than 90% of the examination volume of each w rid, where the reduction in coverage is due to interference by another component, or part geometry.
lilSTORY 1
During Refuel Outage BIR07,13yron Station conducted ultrasonic examinations (UT) of the Dyron Unit 1 RPV.
nis was the last refuel outage of the third period of the First inservice inspection Interval and occurred in April through June 1996. Framatome Technologies Inc. (FTI) was contracted to perform the examinations with their state of the art "URSULA" manipulator and their "ACCUSONEX" UT system. The examinations were performed in accordance with the requirements in ASME Section XI, Article IWA 2232, USNRC Regulatory Guide 1.150 and 10CFR50.55 a (g)(6)(ii)(A). The examination scope included 100% of the Reactor Shell welds,llead welds, and Shell to Flange welds (ASME Section XI Table IWB 25001, Category B A), all eight Reactor Nonte to-Vessel welds and Inner Radius sections (Category B D), and Reactor Flange threads (Category 110 1). Byron Station RPVs do not have any longitudinal shell welds.
De DI R07 examinations revealed two minor recordable indications in item 131.10 RPV circumferential shell weld WR 29, I minor recordable indication in item Bl.10 PRV shell weld WR 34, and one minor recordable indication in item B5.010 RPV noule to safe end weld RPVS-II. All indications are within the accep'ance criteria of ASME Section XI, Article IWB 3500.
During the performance of the 131R07 examinations, physical obstructions and geometry prevented UT coverage in ercess of 90% of the required volume for component RPVC-WR29. Full 100% UT coverage was obtained for the item D1.10 RPV shell welds WR 18 and WR 34. Full 100% UT coverage was obtained for the item 131.30 RPV shell to flege welds WR 7. Additionally, limited amount of examination coverage was attained for item Bl.20 RPV head weid WR 16. The examination limitation for WR 16 is addressed in Byron Station Unit 1 First Inspection Interval Relief Request NR 1 that was previously approved by the NRC in an SER dated August 1991 (EGO MS 9117). The portion of NR ' that addressed the examination limitations of weld WR 16 was not affected by 50.55a(gX6XiiXA).
IlYRON STATION UNIT I FIRST INT ERVAL ISI PROGRAM PLAN NRC SUllMITTAL RELIEF REQUEST NR 20 Resision I (Page 2 of 4)
S:rict ASME Section 111 quality controls were used wben designing, fabricating, and installing these w elds. In addition, these w elds wcre volumetrically examined during Preservice Inspections. Presenice Inspection ultrasonle examination of the Byron Unit i RPV was conducted during the fall of 1981 and did not reveal any recordable indications for the Category B A RPV shell u elds. Preservice ExatrJnation ultrasonic limitations were addressed in the Byron Units I and 2 Inservice inspection Program First inspection Interval Relief Request NR l. Portions of previously granted relief request NR 1 for 13) ton Station Units 1 and 2 first inspection interval for the Reactor Shell welds specified in Code item Bl.10, were revoked in 10CFR 50.55a(g)(6)(li)(A) with respect to examination coverages, llASIS FOR REll0F:
Pursuant to 10 CFR 50.55a(g)(6)(ii)(A)(5), relief is requested from the augmented requirement to examine " essentially 100%" of the examination volume of the RPV circumferential shell wcld, RPVC WR29, on the basis that the alternalise to the examination requirements provides an acceptable level of quality and safety.
Augmented examination of the subject RPV shell weld was conducted on Byron Unit I during the lilR07 refuel outage (fall 1996). During this exam, physical obstructions and geometry prevented (UT) coverage in excess of 90% of the required volume. The examination of the Unit i Lower Shell Course-to-Dutchman weld, RPVC WR29, is restricted by six core barrel locating lugs welded to the inner surface of the vessel approximately four inches above the weld (See figure 1) These lugs obstruct the automated UT inspection tool from examining the Code required volume of the weld below each lug (156'). The FTl"URSULA" tool has a six degree movement arm.
The physical size of the lugs and the " yaw" Joint of the tool prevents scanning below the lugs back into the weld and surrounding base metal. All weld metal can be examined from both sides where access is availaole between the lugs (204'). Examinatmns for perpendicular and parallel renectors covered areas accounting for 57% of the weld metal and heat affected zone (llAZ). Similarly 57% of the w eld metal can be examined for transverse reDectors from two opposing directions. Examination of the welds from the OD of the vessel is not practicable due to the structural concrete surrounding the vessel. The annulus between the vessel and the structural concrete does not allow for even remote ultrasonic techniques to be employed. To achieve 100% ultrasonic examination coverage of this u cid would require redesign and refabrication of the RPV to eliminate the core barrel lower lugs.
For weld RPVC WR29, the probability of a Daw occurring only in one of the areas not being examined is extremely small. Most future indications of significant size will be found by the exemination of the weld as it is currently performed.
PROPOSED Al TERNATE EXAMJNATION:
The ultrasonic examination of the reactor vessel was performed to the maximum extent possible. No alternative volumetric examination is proposed to examine the areas not scanned due to obstructions or geometric constraints, VT 1 inspection was conducted on the weld and ilAZ from the inside clad surface utilizing a submersible robot during the Byron Unit 1 Refuel Outage BIR07, Additionally, a VT 2 examination during system pressure testing per Category B-P is performed on the RPV cach refueling outage to verify leaktight integrity of these welds.
Additionally, leakage during operation would be detected by operating shiftly surveillance of the RPV incore tunnel samp run data.
IlYRON STATION UNIT I FIRST INTERVAL ISI PROGRAM PLAN NRCSUllMITTAL REll0F REQUEST NR 20 Resision 1 (Page 3 of 4)
JUSTIFICATION:
The Code required volumetric examination has been completed to the maximurn c. stent practical using ultrasonic examination techniques for il> ron Unit 1. The RPV examinhtions are conducted using an automated technique from the ID of the s essel. Access to allow !nspection from the OD (shell wide) of these welds is restricted due to j
the $tructural concrete structure surrounding the vessel.
j Reasonable assurance of the continued inservice structural integrity of the subject welds is achieved without performing a complete Code examination. The weld has received visual examinations (VT 1 and VT 2) to visually verify the integrity of the weld.
Compliance with the applicable Code requirements can only be accomplished by redesigning and tefabricating the Reactor Vessel and'or building structure surrounding the vessel. Dyron Station believes this course of action is a hardship without a compensating increase in the level of quality and safety and that the alternative provides an acceptable level of quality and safe. v.
PERIOli FOR WillCll HELil.F IS REOUESTED:
Reliefis requested for the first 10 year inspection interval for flyton Unit 1.
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IlYitON STATION UNIT 1 filtST INTEltVAL Isi l'ItOGitAM I'LAN NHC SUllMITTAI.
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j A TTACHMENT3 RELIEFREQUEST NR-25 REVISION 0 l
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IlYRON STNilON UNIT 1 FIRST INTERVAL ISI PROGRAM PLAN NHC SUllMITTAL RELIEF REQUEST NR 25 Resision 0
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(Page 1 of 4)
- COMPONENT IDENTIFICATION:
l Code Classt 1
Reference:
IWB 2500. Table iWB.25001 i
Examination Category BA.
Item Number:
Bl.Il
==
Description:==
Volumetric Examination of Reactor Vessel Circumferential Shell Weld Component Numbers:
RPVC WR29 Drawing Numbers.
IRPV 1 ISl(Unit 1) i CODE RFOUIREMENT:
Table IWB 25001, Examination Category B A, item Numbers B1.11 require a 100% volumetric examination of the Reactor Vessel Circumferential Shell welds as detailed in Figure IWB-25001.
HISTORY '
During Refuel Outage BIR07, Byron Statien conducted ultrasonic examinations (UT) of the Byron Unit i Reactor Pressure Yessel(RPV). This was the last refuel outage of the third period of the First inservice Inspection Interval and occurred in April through June 1996. Framatome Technologies Inc. (FTI) was contracted to perform the examinations with their state of the art "URSULA" manipulator and their "ACCUSONEX" UT system. The examinations were performed in accordance with the requirements in ASME Section XI, Article IWA 2232 USNRC Regulatory Guide 1.150 and 10CFR50.55 a (g)(6)(ii)(A). The examination scope included 100% of the beactor Shell welds, llead welds, and Shell to Flange welds (ASME Section XI Table IWB 2500-1, Category B A),
all eight Reactor Nozzle to Vessel welds and Inner Radius sections (Category B D), and Reactor Flange threads (Category B G 1). Byron Station RPVs do not hase any longitudinal shell welds.
The B1R07 examinations revealed two minor recordable indications in item Bl.1I shell weld RPVC WR29, one i
minor recordabic indict. tion in item Bl.ll shell weld RPVC WR34, and one minor recordable indication in item B5.010 RPV nozzle to-safe end weld RPVS II. Allindications are within the acceptance criteria of ASME Section XI ArticleIWB 3500.
During the perfarmance of the BIR07 examinations, physical obstructions and geometry prevented UT coverage in excess of 90% of the required volume for component number RPVC WR29. Full 100% UT coverage was obtained for the item B1.11 RPV she!! welds RPVC WR18 and RPVC WR34. Full 100% UT coverage was obtained for the item Bl.30 RPV shcIl to Bange welds RPVC-WR7. Additionally, limited amount of examination coverage was attained for item Bl.21 head weld RPVC WR16. The examination limitation for RPVC WR16 is addressed in Byrco Station Unit i First inspection Interval Relief Request NR 1 that was granted reliefin an SER dated August 1991(EGG MS 9117).
Strict ASME Section Ill quality controls were used w hen designing, fabricating, and installing these welds, in addition, these welds were volumetrically examined during Preservice inspections. Preservice Inspection ultrasonic
- examination of the Byron Unit i RPV was conducted during the fall of 1981 and did not reveal any recordable indications for the Category B A RPV shell welds. Preservice Examination ultrasonic limitations were addressed in the Byron Units I and 2 Inservice Inspection Program First inspection Interval Relief Request NR 1. Portions of previously granted Relief Request NR 1 for Byron Station Units 1 and 2 First inspection Interval for the Reactor Shell welds specined in Code item Bl.10, were revoked in 10CFR 50.55 a (g)(6)(ii)(A) with respect to examination coverages.
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IlYRON STATION UNIT I FIRST INTERVAL IST PROGRAM PLAN NRC SUllMITTAL RELIEF REQUEST NR 25 Resision 0 (Page 2 of 4) 1
_lWilSJOR RFLIEF:
l l
Pursuant to 10 CFR 50.55a(g)(5)(lii), reliefis requested from the ASME rode item B1.11 requirement to exe.mine l
" essentially 100%" of the examination volume of the RPV circumferential shell weld, RPVC WR29, on the basis that conformance with the Code requirements is impractical.
Augmented examination of the subject RPV shell weld was conducted on Byron Unit I during BIR07 refuel outage (fall 1996). During this exam, physical obstructions and geometry prevented UT coverage in excen of 90% of the required volume. The examination of the Unit 1 Lower Shell Course-to-Dutchman weld, RPVC WR29, is restricted by six core barrel locating lugs welded to the inner surface of the vessel approximately four inches above the weld (See Figure 1). These lugs obstruct the automated UT inspection tool from examining the code required volume of the weld below each lug (156'). He FTl "URSULA" tool has a six degree movement arm. 'he physical size of the lugs and the " yaw" joint of the tool prevents scanning below the lugs back into the w eld and surrounding t,ase metal. All weld metal can be examined from both sides where access is available between the lugs (204*).
Examinations for perpendicular and parallel reDectors covered areas accounting for 57% of the weld metal and hea affected zone (llAZ). Similarly,57% of the weld metal can be examined for transverse reflectors from two opposing directions.
Examination of the welds from the OD of the vessel is not practicable due to the structural concrete surrounding the vessel. Removal of the obstruction (stmetural concrete) would require extensive str=tural modifications and the manhour/ exposure expenditures are impractical. %e annulus between the vessel and the structural concrete (Reference Figure 1) does not allow for any existing remote ultrasonic techniques to be employed. The development of new sophisticated tooling to examine the wcid from the OD would result in only marginal increases in the examiration coverages. To achieve 100% ultrasonic examination coverage from the ID of this weld would require redesign and refabrication of the RPV to eliminate the core barrel lower lo: s or reposition the weld relative to the lugs.
For weld RPVC WR29, the probability of a flaw occurring only in one of the areas not being examined is extremely small. Most future indications of significant size will be found by the examination of the weld as it is currently perfonned.
PROPOSED AlTFRNATE EXAMINATION:
The ultrasonic examination of the reactor vessel was performed to the maximum extent possible. No alternative volumetric examination is proposed to examine the areas not scanned due to obstructions or geometric constraints.
VT 1 inspection wa$ conducted on the weld and ilAZ from the inside clad surface utilizing a submersible robot during the Byron Unit i Refuel Outage BIR07. Additionally, a VT 2 examination during system pressure testing per Category B-P is performed on the Reactor Vessel each refueling outage to verify leaktight integrity of these welds. Additionally, leakage during operation would be detected by operating shiftly surveillance of the RPV incore tunnel sump rua data.
JUSTIFICATlON:
The Code required volumetric examination has been completed to the maximum extent practical using ultrasonic examination techniques for Byron Unit 1. The.RPV examinations are conducted using an automated techn:que from the ID of the vessel. Access to allow inspection from the OD (shell side) of this weld is restricted due to the structural concrete structure surrounding the vessel.
i
1 IlYRON STATION UNIT I FIRST INTERVAL IST l'ROGRAM l'LAN NRC SUllMITTAl, RELIEF REQUEST NR 25 Resision 0 (l' age 3 of 4)
Reasonab< assurance of the continued inservice structural integrity of the subject weld is achieved without performing a complete Code examination. The weld has received 5isual examinations (VT 1 and VT 2) to visually 4
verify the integrity of the weld.
Compliance with the applicable Code requirements can only be accomplished by redesigning and tefabricating the Reactor Vessel and'or building structure surrounding the vessel or the developme,.t of sophisticated tooling that would result in only minimal increases in exarnination coverages. Byron Station believes this course of action is impractical and w ould result in a hardship without a compensating increase in the level of quality and safety, p0RIOD FOR WillCil RELIEF IS It00UESTEut Reliefis requested for the first 10 year inspection interval for Byron Unit 1.
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llYRON STAllON UNIT IFiltST INTEltVAL ISI PitOGRAM l'LAN NRC SUllMITTAL l
HELIEF ltEQUEST NH 25 Hrshion 0 i
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