ML20212J863

Safety Evaluation Supporting Licensee Proposed Alternatives to Provide Reasonable Assurance of Structural Integrity of Subject Welds & Provide Acceptable Level of Quality & Safety.Relief Granted Per 10CFR50.55a(g)(6)(i)

ML20212J863
Person / Time
Site:	Crystal River
Issue date:	10/01/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20212J852	List: ML20212J848 ML20212J863
References
NUDOCS 9910060014
Download: ML20212J863 (24)

Text

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.. uny UNITED STATES

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- NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PLAN REQUESTS FOR RELIEF FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302

1.0 INTRODUCTION

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 Code and applicable addenda as required by Title 10 of the Code of Federal l Reauletions (10 CFR), Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). It is stated in 10 CFR 50.55a(a)(3) that altamatives to the requirements of paragraph (g) may be used, when authorized by the l

U.S. Nuclear Regulatory Commission (NRC), if (i) the proposed altamatives 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. l 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 access provisions and the pre-service examination requirements, set forth in the ASkE Code,Section XI, " Rules for l Inservice inspection of Nuclear Power Plant Components," to the extent practical within the

!- limitations of design, geometry, and materials of consNetion of the components. The i

, regulations require that insorsica examination of comptnents rand system pressure tests conducted during the fimt 1G year interval and subsequer : int wvals 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. For Crystal River Unit 3, the applicable edition of Sechon XI of the ASME Code for the second 10-year inservice inspection interval is the 1983 Edition through Summer 1983 Addenda.

2.0 EVALUATION By letter dated July 31,1998, Florida Power Company (licensee), submitted second 10-year interval Requests for Relief 98-009-il,98-010-II, and 98-0111l seeking relief from the requirements of the ASME Code,Section XI, for the Crystal River Unit 3. Additional information was provided by the licensee by letter dated July 19,1999. The Idaho National  ;

Engineering and Environmental Laboratory (INEEL) staff's evaluation of the subject requests l

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for relief is presented in the attached technicalletter report. Based on the results of the review, the staff adopts the contractor's conclusions.

The information provided by the licensee in support of the requests for relief from Code requirements has been evaluated and the basis for disposition is documented below.

Reauest for Relief No. 98-009-ll (Part At )

' in accordance with 10 CFR 50.55a(g)(6)(ii)(A), all licensees must implement once, as part of the inservice inspection interval in effect on September 8,1992, an augmented examination of the reactor pressure vessel (RPV) welds specified in item B1.10 of Examination Category B-A of the 1989 Edition of the ASME Code, Sechon XI. Examination Category B-A, items B1.11

' and B1.12 require volumetric examination of essentially 100% of the RPV circumferential and I longitudinal shell welds, as defined by Figures IWB-2500-1 and -2, respectively. Essentially 100%, as defined by 10 CFR 50.55a(g)(6)(ii)(A)(2), is greater than 90% of the examination volume of each weld.

1 At Crystal River Unit 3, the augmented coverage requirements could not be met for two shell welds due to core guide lugs,~ inlet nozzle openings, and the outlet nozzle boss extensions that

. limit scan coverage. The licensee proposed that the coverage obtained for we4ds B1.2.1, RPV l lower shell-to-transition piece, and B1.2.3, RPV nozzle belt intermediate weld, was an altamative to the examination requirements that provided an acceptable level of quality and safety for these two welds.

For welds B1.2.1 and B1.2.3, the physical obstructions limited coverage to 29% and 75%,  !

respectively, of the required volume. The licensee has examined significant portions of the j subject welds and has met the coverage requirements for the remaining RPV shell welds.

The staff concludes that the volumetric examination coverages attained, and the examinations conducted on other RPV welds provides an acceptable level of quality and safety. Therefore,  ;

the licensee's proposed altemative is authorized pursuant to 10 CFR 50.55a(g)(6)(ii)(A)(5). '

Beauest for Relief 98-009-11 (Part Bh ASME Code, Sechon XI, Examination Category B-A, item B1.40, requires essentially 100% l volumetric and surface examination, as defined by Figure IWB-2500-5, of the reactor pressure vessel (RPV) head-to-flange weld to be performed during each inspection interval. Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code volumetric examination l coverage requirement for RPV head-to lange weld B1.3.2.

The staff determined that the surface geometry of the flange, in combination with access restrictions caused by the head lifting lugs, preclude ultrasonic scans of the full volume of this weld. Therefore, the Code-required 100% volumetric examination is impractical to achieve.

To gain access for 100% coverage, the component would have to be redesigned and modified and would be a significant burden on the licensee.

The licensee obtained 48% of the required volumetric coverage. In addition, the licensee has completed the Code-required surface examination. The examinations performed by the  !

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3-licensee provide reasonable assurance of structural integrity of the weld. Therefore, relief is

_ - granted pursuant to 10 CFR 50.55a(g)(6)(i).

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I Reauest for Relief 98-009-11 (Part C)

ASME Coo =,6ection XI, Examination Category B-D, item B? 00 requires 100% volumetric examination of reactor pressure vessel (RPV) nozzle-to-vessel welds as defined by Figure IWB-2500-7. Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code volumetric examination coverage requirement for the following % nozzle-to-vessel welds: B1.4.7A, B1.4.8A, B1.4.3A, B1.4.4A, B1.4.5A, and 81.4.6A The staff determined that the component geometry, including the boss extension of the outlet L nozzle, and the nozzle radius of the inlet nozzle, limits access and precludes performance of

' 100% volumetric examinations of the subject nozzle-to-vessel welds. These physical restrictions make the Code coverage requirements impractical for the inlet and outlet nozzle-to-shell welds. To meet the Code requirements, design modifications would be needed to provide access for examination. Imposition of this requirement would result in a significant burden on the licensee.

The licensee has performed the Code-required volumctric examinations to the extent practical, i obtaining 47% coverage for the outlet nozzle-to-shell welds and 71% coverage for the inlet  !

nozzle-to-shell welds. Furthermore, essentially 100% of the required weld volume and adjacent base material have received two axial angle beam scans from the nozzle bore. The l

staff concludes that the significant percentage of coverage obtained on the nozzle-to-vessel welds provides reasonable assurance of structurai integrity for the subject welds. Therefore, j relief is granted pursuant to 10 CFR 50.55a(g)(6)(i)  ;

i Reauest for Relief No. 98-010-11: j ASME Code,Section XI, Examination Category B-D, items B3.110, B3.120, B3.130, and B3.140 require 100% volumetric examination of nozzle-to-shell welds and inside radius 4 sections, as defined in Figure IWB-2500-7. Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee j requested relief from the Code-required volumetric examination of the Table IWB-2500-1, Category B-D, welds, as listed in the attached contractor's report.

The staff determined that a complete examination of these welds ir restricted by the geometric l configuraten of the nozzles and by physical restrictions around the rozzles. The geometric l and physical restnchons make the required volumetric examination impractical for these areas. l To gain access for examination would require design modifications of the nozzles. Imposition  ;

l of the Code requirement would be a significant burden on the licensee.

The licensee has examined the twenty-two subject welds and inner radius sections to the extent practical, obtaining 31% to 63% coverage (52% average coverage for the nozzle welds

. and 41% average coverage for the inner radius sections). The staff concludes that the coverage obtained provides reasonable assurance of the structuralintegrity of the subject  ;

welds. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).

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4-Reauest for Relief No. 98-011-II:

'ASME Code, Sechon XI, Examination Category B-H, item B8.20,. requires 100% volumetric or surface examination, as soplicable, as defined by Figures IWB-2500-13, -14, -15, for .

pressurizer integrally welded attachments. Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code-required 100% surface examination for the following pressurizer integrally welded attachments: B2.8.1, B2.8.3, B2.8.5, B2.8.7, B2.8.9, B2.8.11, B2.8.13, and B2.8.15.

The staff determined that complete examination is restricted by physical obstructions that make the 100% surface examination impractical for these areas.- To gain access for examination, disassembly of the building structure would be required, imposition of the Code requirement would be a significant burden on the licensee.

The licensee has examined the subject integral attachments to the extent practical, obtaining a significant portion (73%) of the required coverage of each of the integral attachments. The staff concludes that the significant amount of coverage obtained provides assurance of structural integrity of the subject welds. Therefore, relief is granted pursuant to i 10 CFR 50.55a(g)(6)(i). j l

3.0 CONCLUSION

The staff con::ldes that for Request for Relief 98-009-11, Part A, the augmented coverage ,

requirements could not be met for two shell welds due to core guide lugs, inlet nozzle openings, and the outlet nozzle boss extensions that limit scan coverage. The vnlumetric examination coverages attained, and the examinations conducted on other RPV Gelds provides an acceptable level of quality and safety. Therefore, the licensee's proposed

. altemative is authorized pursuant to 10 CFR 50.55a(g)(6)3!)(A)(5).

For Requests for Relief 98-009-11, Parts B and C,98-010-II, and 98-011-11, the staff concludes that the Code requirements are impractical and the licensee's proposed alternatives provide reasonable assurance of structuralintegrity of the subject welds and provide an acceptable level of quality and safety. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for Requests for Relief 98-009-II, Parts B and C,98-010-11, and 98-011-11.

Attachment:

INEEL Technical Letter Report I Principal Contributor: T. McLellan Date: October 1, 1999 I

TECHNICAL LETTER REPORT ON SECOND 10-YEAR INTERVAL INSERVICE INSPECTION REQUESTS FOR RELIEF 98-009-il. 98-010-11. AND 98-011-ll E.O.h FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER: 50-302

1. INTRODUCTION l

By letter dated July 31,1998, the licensee, Florida Power Corporation, submitted Requests for Relief 98-009-11,98-010-II, and 98-011-11, seeking relief from the l

requirements of the ASME Code,Section XI, for the Crystal River, Unit 3 second 10-year inservice inspection (ISI) interval. Additionally, the licensee responded to an NRC 1 request for additional information by letter dated July 19,1999. The Idaho National I Engineering and Environmental Laboratory (INEEL) staff's evaluations of the subject requests for relief are in the following section.

2. EVALUATION' The information provided by Florida Power Corporation in support of the requests for relief from Code requirements has been evaluated and the bases for disposition are documented below. The Code of record for the Crystal River, Unit 3, second 10-year ISI interval, which ended August 13,1998, is the 1983 Edition through Summer 1983 l Addenda of Section XI of the ASME Boiler and Pressure Vessel Code.

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' Enclosures, tables, figures, and attachments furnished with the licensee's submittal are not included in this report.

ATTACHMENT I M_ - -

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.2 A. Reauest for Relief No. 98-009-11. (Part A)2. Altemative to 10 CFR 50.55a(alf6)(ii)(A). i l

Auamented Reactor Pressure Vessel Examination j Reaulatory Reauirement: In accordance with 10 CFR 50.55a(g)(6)(ii)(A), all licensees must implement once, as part of the inservice inspection interval in effect on

' September 8,1992, an augmented examination of the reactor pressure vessel (RPV) welds specified in item B1.10 of Examination Category B-A of the 1989 Edition of the ,

i ASME Code,Section XI. Examination Category B-A, items 81.11 and 81.12 require I i

volumetric examination of essentially 100% of the RPV circumferential and longitudinal shell welds, as defined by Figures IWB-2500-1 and -2, respectively. Essentially 100%,

j as defined by 10 CFR 50.55a(g)(6)(ii)(A)(2), is greater than 90% of the examination volume of each weld.

1 Licensee's Proposed Alternative: In accordance with 10 CFR 50.55a(a)(3)(ii), the licensee proposes that the coverages obtained for the subject welds be found acceptable for the following welds.

Comp. Component ASME Item Aggregate Limitation ID Description Category Number Coverage B1.2.1 RPV Lower B-A B1.11 29% The core guide lugs and flow Shell-to- distributor remnants interfere with Trantition Piece the scan paths.

B1.2.3 RPV Nozzle Belt B-A B1.11 75 % inlet and outlet nozzles interfere Intermediate with the scan paths Weld 1, {

I The licensee stated:

" Examinations of the identified components have been pe. formed to the maximum extent practical within the limits of design and geometry.

'The volumetric examination coverage of the Reactor Pressure Vessel Lower Shell-to-Transitien Piece Weld. Unique identifier B1.2.1, is limited to 29%.

l 2 For simplicity of reference and evaluation, Request for Relief 98-009-11 was broken into Parts A, B, and C by the l INEEL Staff.

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, "The volumetric examination coverage of the Reactor Pressure Vessel Nozzle Belt interr.1ediate Shell Weld, Unique Identifier 81.2.3, is limited to 75%"

Licensee's Basis for Proposed Altemative (as statedh

" Vessel Volumetric Examinations "The 1983 Edition of ASME Section V, Article 4 requires the weld and adjacent base metal to be examined using nominal angles of 0,45, and 60 degroes.

Deviation from the 45 and 60 degree angles is permitted if geometry limits the coverage; however, separation of angles must be at least 10 degrees.

"Four basic scans are required:

1. Axial scans of the weld area - 2 angle beam paths from 2 directions for reflectors parallel to the weld. For nozzle-to-vessel we!d examinations conducted from the nozzle bore, beam angles sufficient to provide complete coverage from one direction is acceptable. (ASME Section V, Article 4, T-441.5.1)

2. Axial scans of the adjacent base metal- 2 angle beam paths from at least i direction for reflectors parallel to the weld. (ASME Section V, Article 4, T-441.5.1)

3. Circumferential scans of the weld and adjacent base metal- 2 angle beam paths from 2 directions for transverse reflectors. Areas blocked by geometric conditions shall be exarnned from at least one direction. (ASME Section V, Article 4, T-441.5.2)

4. Zero degree scans of the weld and adjacent base metal for planar and laminar reflectors (ASME Section V, Article 4, T-441.3.2.3(a) and T-441.3.2.3(b))

" Additional near-surface ::ircumferential and axial scans are required for reactor pressure vessel welds examined in accordance with the 1989 Edition of ASME Section XI and USNRC Regulatory Guide 1.150.

"For each individual required scan, the amount of sound beam that passed through the required examination volume has been plotted on scaled cross sectional drawings of each component configuration. The examination coverage obtained from each of the required scans for the required examination volume.

"These examinations are limited by part geometry or interferences with other components, such that the reduction in coverage is greater than 10 percent.

" Examination Details

" Component B1.2.1, Reactor Pressure Vessel Lower Shell-to-Transition Piece Weld.-

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! I "The Preservice records reported the examination coverage as 'best effort' due to the interferences with core guide lugs and flow stabilizer vanes. (See Enclosure 1 for scan plan sketches and En::losure 2, FPC drawing 135546E for lug and vane locations). No preservice indications were recorded.

I "During the First interval examination, the core guide lugs and flow stabilizer vanes were reported as limitations and no indications were recorded.

"During the Second Interval examination, the average amount of coverage has been calculated to be 29 percent. Twelve (12) degrees of the weld between the 12 lugs was accessible for examination (144 degrees). Forty (40) percent of the required weld and adjacent base material has been examined with 2 axial full-node angle beam scans from one side of the weld. Twenty Eight (28) percent of the required weld and adjacent base material has been examined with 2 angle beam circumferential scans from at least one direction. No unacceptable indications have been recorded.

(From RAI response)

"Due to interferences caused by the core support lugs and flow stabilizer vanes, the angle beam metal paths were increased using a full-vee technique in an effort to maximize examination coverage of this weld. 40% of the required weld and l adjacent base material between each guide lug (360 degrees around the vessel) was examined with 2 axial full-node angle beam scans and 70-degree near-surface beams. No unacceptable indications were detected in the 40% of available weld length between each lug. Any evidence of serious inservice i degradation of this weld would have been detected. Since this weld is located

[ outside of the area of highest irradiation in the reactor vescel, and the weld areas inside the belt-line region of the reactor vessel (inspected in March 1996 during the 10-year inspection of the Reactor Vessel) have not experienced any rejectable indications, no inservice degradation is expected in the areas not examined at this weld location.

"Although the weld area beneath the lugs received no ultrasonic examination coverage, no flaws were identified during a remote VT-3 visual examination of the i lug areas. This weld is located outside of the area of highest irradiation in the reactor vessel.

" Component B1.2.3, Reactor Pressure Vessel Nozzle Belt Intermediate Weld "No limitation areas were reported during the preservice examination of this  !

component. The weld was examined to the maximum extent possible. No relevant preservice indications were recorded. ,

'i "During the First Interval examination, only 5 percent of the weld length was examined to satisfy the requirements of Table IWB-2500 of the 1974 Edition of ASME Section XI through Summer 1975 Addenda. No indications were recorded.

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"During the Second Interval examination, a total of 25 percent of the weld length was not accessible due to scanning interferences with the inlet nozzle oper.ings and the outlet nozzle boss extensions. This number is based on getting 100 percent coverage for 80 percent of the length of weld under each core flood nozzle between the inlet nozzles (2 places), as well as 72 percent of the weld length between the inlet nozzles and outlet nozzles (4 places). (See Enclosure 3 ,

for a drawing depicting the coverage areas). No unacceptable indications were j

, recorded. This weld is located outside of the area of highest irradiation in the i

reactor vessel. A total of 75 percent of the weld has been examined and no unacceptable indications have been recorded.

(From RAI response)-

L "The reactor pressure vessel nozzle belt intermediate weld examination was l

performed using 2-inch by 2-inch ultrasonic transducer arranged in a two by two array. The size of the transducer head was not the limiting factor in this examination. The inlet nozzle holes, core flood nozzle holes, and the 6-inch tall l outlet nozzle bosses were the limiting factors with respect to examination coverage of this weld. No unacceptable indications were detected in the 75% of the weld length examined in March 1996,10-year inspection of the Reactor Vessel. No unacceptable indications have ever been detected during the preservice, first interval, or second interval examinations of this weld (~19 years of operation).

Since this weld is located outside of the crea of highest irradiation in the reactor vessel, and the weld areas inside the belt-line region of the reactor vessel have l not experienced any rejectable indications, no inservice degradation is expected at  !

the areas not examined at this weld location. l Extemal Examination of the Reactor Vessel (from RAI response)

• Examination from the outside surface (OD) is not feasible without dose intensive activities and/or extensive modifications as described below:

'i The design of the CR-3 Nuclear Steam Supply System (NSSS) locates the reactor

. vessel inside a concrete cylinder (primary shield wall), with approximately 2-3 feet of clearance between the reactor vessel and the concrete surface. This annular cavity contains the reactor vessel mirror insulation and its support structure. The annular cavity is sealed at the top by the fuel transfer canal seal plate, which is I permanently welded to the fuel transfer canal liner and the reactor vessel closure head flange. The design of the mirrorinsulation, coupled with limited access, does not permit removal of the mirror insulation panels at the areas of interest only. In order to gain access to these welds, the BARRITE plugs (used for neutron shielding) and the reactor vessel mirror insulation would have to be removed starting with the top ring and working progressively down to the areas of interest, until sufficient access to perform the examination had been provided. The design of the fuel transfer canal and design of the reactor vessel support wirt further restrict access to the annular cavity. Access from the bottom blocked by the design of the reactor vessel support skirt. The support skirt is a welded steet

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. k structure with limited penetrations, none of which is of sufficient size to allow personnel access to the annular cavity.

"FPC personnel estimated dose to remove and reinstall the BARRITE plugs, the mirror insulation, and its support structure would be in excess of 25 person-Rem.

The estimate is conservatively based on actual doses associated with the Core Flood Nozzle surface examinations."

Evaluation: To comply with the augmented reactor vessel examination requirements of 10 CFR 50.55a(g)(6)(ii)(A), licensees must volumatrically examine essentially 100% of each of the item B1.10 shell welds. The Regulations define " essentially 100%" as coverage greater than 90% of the examination volume of each weld. As an altemative to the requirement of the Regulations, the licensee proposed that the examination coverage obtained be considered to provide an acceptable level of quality and safety for the RPV welds.

1 At Crystal River, Unit 3, the augmented coverage requirements cannot be met for two l shell welds due to core guide lugs, inlet nozzle openings, and the outlet nozzle boss  !

extensions that limit scan coverage. For Welds B1.2.1 and B1.2.3, the physical obstructions limited coverage to 29% and 75%, respectively, of the required volume. To achieve complete coverage for the subject welds, design modifications would be i required to increase access from the inside surface (lD).

As a result of the augmented volumetric examination rule, licensees must make a reasonable effort to maximize examination coverage cJ their reactor vessels. In cases where examination coverage from the ID is inadequate, examination from the outside surface (OD) using manualinspection techniques may be an option. However, j extensive surface preparation (removal of insulation, Barrite plugs and support structure) would be required for the licensee to perform supplemental examinations from the outside diameter. The effort expended to obtain access to the examination surface for

- the OD examination would result in considerable radiological exposure (>25 person-Rom) that is not warranted for the additional volumetric coverage achieved. Therefore, imposition of this requirement would result in a significant hardship without a compensating increase in the level of quality and safety.

The licensee has examined a significant portion of the subject welds, in addition, the licensee has met the coverage requirements for the remaining RPV shell welds. Based on the volumetric examination coverages attained, and the examinations conducted on other RPV welds, the INEEL staff concludes that any significant pattems of degradation, if present, would have been detected and that the examinations performed provide reasonable assurance of the continued structuralintegrity of the subject welds.

Therefore, it is recommended that the licensee's proposed altemative be authorized pursuant to 10 CFR 50.55a(s)(3)(ii).

B. Reauest for Relief 98-009-1l (Part B). Examination Cateaory B-A. Item B1.40. Reactor Pressure Vessel Head-to-Flance Weld l

Code Reauirement: Examination Category B-A, item B1.40, requires essentially 100%

volumetric and surface examination, as defined by Figure IWB-2500-5, of the reactor pressure vessel (RPV) head-to-flange weld to be performed during each inspection interval. Essentially 100%, as defined by ASME Code Case N-460, is greater than 90%

coverage of the examination volume or surface area, as applicable.

Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code volumetric examination coverage requirement for RPV Head-to-flange Weld B1.3.2.

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-Comp. Component ASME ltem Aggregate Limitation ID Description Lawpy Number Coverage B1.3.2 RPV Head-to- B-A B1.40 48% The flange geometry and lifting Flange Wold lugs interfere with the scan paths.

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

"The 3 lifting lug interferences and the flange geometry have provided the same limitations during the preservice, first interval, and second interval volumetric

examinations of this component. (See Enclosure 4 scan plan sketches and ,

Enclosure 5, FPC drawing 135551E for lug locations). 75 percent of the required weld and adjacent base material has been examined with at least 2 angle beam axial scans from the vessel head side of the weld. Thirty Nine (39) percent of the required weld and adjacent base material has been examined with 2 angle beams

w from 2 circumferential directions. 97 percent of the weld length has been examined -

by the magnetic particle technique. No indications associated with material discontinuities have been recorded during the Preservice, First Interval, and Second Interval nondestructive (NDE) examinations. This weld is located outside of the area of highest irradiation in the reactor vessel."

Licensee's Proposed Altemative Examination (as stated):

" Examinations of the identified components have been performed to the maximum extent practical within the limits of design and geometry.

'"The volumetric examination coverage of the Reactor Pressure Vessel Head-to-Flange Weld, Unique identifier B1.3.2, is limited to 48%."

Evaluation: The Code requires 100% volumetric and surface examination of the RPV closure head-to-flange weld during each inspection interval. However, the surface geometry of the flange, in combination with access restrictions caused by the head lifting lugs, preclude ultrasonic scans of the full volume of this weld. Therefore, the Code-required 100% volumetric examination is impractical to achieve. To gain access for 100% coverage, the component would have to be redesigned and modified. This would place a significant burden on the licensee.

As shown in the table submitted by the licensee,48% of the required volumetric j coverage was obtained. In addition, the licer.see has completed the Code-required surface examination. These examinations would have detected any existing pattems of l degradation, and provide reasonable assurance of the continued structuralintegrity of the weld. Therefore, based on the impracticality of the Code volumetric coverage

requirements, and the extent of examinations that were performed, it is recommended

! that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

C. Reauest for Relief 98-009-11 (Part CL Examination Cateaorv B-D. Item B3.90. Reactor Vessel Nozzle-to-Vessel Welds Code Reauirement: ASME Section XI, Examination Category B-D, items 83.90 require 100% volumetric examination of reactor pressure vessel (RPV) nozzle-to-vessel welds as defined by Figure IWB-2500-7.

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Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code volumetric examination coverage requirement for the following RPV Nozzle-to-Vessel Welds.

Comp. Component ASME ltem Aggregate Limitation ID Description Category Number Coverage 81.4.7A RPV Outlet B-D B3.90 47% Outlet Nozzle boss B1.4.8A Nozzle-to- geometry interferes Vessel with the scan paths.

Welds 81.4.3A RPV Inlet B-D B3.90 71 % The configuration of 81.4.4A Nozzle-to- the inlet nozzle radius l 81.4.5A Vessel geometry interferes i B1.4.6A Welds with the scan paths.

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

" Components B1.4.7A and B1.4.8A, Reactor Pressure Vessel Outlet Nozzle-to-Shell Welds l "The outlet nozzle extension geometry has provided the same limitation area j during the preservice, first interval, and second interval volumetric examinations of these nozzle welds (See Enclosure 6, FPC drawing 135540E). The boss extension limits the circumferential scan coverage to 26%. However,100% of the required weld volume and adjacent base material has received 2 axial angle beam scans from the nozzle bore. No unacceptable indications have been identified during the Preservice, First Interval, or Second Interval examinations of these outlet nozzle-to-shell welds.

" Components B1.4.3A, B1.4.4A, B1.4.5A, and B1.4.6A, Reactor Pressure Vessel inlet Nozzle-to-Shell Welds "The inlet nozzle geometry has provided the same limitation during the Preservice, First interval, and Second interval volumetric examinations of these nozzle welds.

The nozzle radius limits the circumferential scan coverage to 76%. However,99%

of, the required weld volume and adjacent base material has received 2 axial angle beam scans from the nozzle bore. 95 % W.e .aq.; tua neer-surface volume has received circumferential and axial angle beam coverage. No unacceptable indications have been identified during the Preservice, First interval, or Second Interval examinations of these inlet nozzle-to-shell welds."

Licensee's Proposed Altemative Examination (as stated):

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" Examinations of the identified components have been performed to the maximum extent practical within the li: nits of design and geometry.

" Examination Category B-D, Full Penetration Welds of Nozzles in Vessel-Inspection Program B.'

"The volumetric examination coverage of the Reactor Pressure Vessel Outlet Nozzle-to-Shell welds, Unique Identifiers B1.4.7A and 81.4.8A is limited to 47%.

"The volumetric examination coverage of the Reactor Pressure Vessel' Inlet Nozzle-to-Shell Welds, Unique Identifiers 81.4.3A, B1.4.4A, B1.4.5A, and B1.4.6A, is limited to 71%."

Evaluation: ASME Section XI requires 100% volumetric examination of all RPV nozzle-to-vessel welds. However, component geometry, including the boss extension of the outlet nozzle, and the nozzle radius of the inlet nozzle limits access and precludes performance of 100% volumetric examination of the subject nozzle-to-vessel welds.

These physical restrictions make the Code coverage requirements impractical for the inlet and outlet nozzle-to-shell welds. To meet the Code requirements, design modifications would be needed to provide access for examination. Imposition of this requirement would result in a significant burden on the licensee.

The licensee has performed the Code-required volumetric examinations to the extent

! practical, obtaining 47% coverage for the outlet nozzle-to-shell welds and 71% coverage for the outlet nozzle-to-shell welds. Furthermore, essentially 100% of the required weld j volume and adjacent base material has received 2 axial angle beams scans from the

l. nozzle bore. Therefore, based on the significant percentage of coverage obtained on the nozzle-to-vessel welds, it is concluded that any existing pattems of degradation would have been detected and that reasonable assurance of the structural integrity has been provided. Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i)

D. Reauest for Relief No. 98-010-11. Examination Cateaory B-D. Full Penetration Nozzle-to- ,

Vessel Welds and Inside Radius (IR) Sections I

Code Reauirement: Examination Category B-D, items B3.110, B3.120, B3.130, and I 1

B3.140 require 100% volumetric examination of nozzle-to-shell welds and inside radius j sections, as defined in Figure IWB-2500-7.

Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code-required volumetric examination of the following welds.

Comp. ID Component ASME Item Aggregate Limitation Description Category . Number Coverage B2.2.1 A PZR Relief B-D B3.110 50 % The nozzle geometry interferes 82.2.2A Nonle-to-Upper with the required scans paths.

B2.2.3A Head Weids 82.2.1B PZR Relief B-D B3.120 42 % The nonle geometry interferes 82.2.28 Nozzle inside with the required scans paths.

B2.2.3B Radius Sections B2.2.4 PZR Spray B-D B3.110 57 % The nonle geometry interferes Nonle-to-Upper with the required scans paths.

Head Welds i B2.2.48 PZR Spray B-D B3.120 48 % The non!e geometry interferes Nonle Inside with the required scans paths.

Radius Section B2.2.6A PZR Surge B-D B3.110 47 % The nonle geometry interferes Nozzle-to-Lower with the required scans paths.

Head Weld B2.2.6B PZR Surge B-D B3.120 37 % The nozzle geometry interferes Nonle inside with the required scans paths.

Radius Section B3.2.1 S/G Inlet Nozzle- B-D B3.130 46 % The nozzle geometry interferes B37,4 to-Upper Head with the required scans paths.

Wold nuo e3 B3.2.1.1 S/G Inlet Nonle B-O B3.140 31 % The nozzle radius geometry B3.2.4.1 Inside Radius interferes with the scan paths.

Section B3.2.2 S/G Outlet B-D B3.130 - 63% The tubesheet support skirt B3.2.5 Nozzle-to-Lower and nozzle configuration Head Weld interfere with the scan paths.

B3.2.2.1 S/G Outlet B-D B3.140 48 % The tubesheet support skirt B3.2.5.1 Nozzle inside and nozzle configuration Radius Section interfere with the scan paths.

4 Comp. ID Component ASME Item . Aggregate Limitation Description Category Number Coverage B3.2.3 S/G Outlet B-D B3.130 49% The tubesheet support skirt B3.2.6 Norzie-to-Lower and nozzle configuration Head Wold interfere with the scan paths.

B3.2.3.1 S/G Outlet B-D 3.140 43% The tubesheet support skirt B3.2.6.1 Nozzle inside . and nozzle configuration Radius Section interfere with the scan paths.

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

i "Nonle-to-Vessel Volumetric Examinations "ASME Section XI requires 100 percent volumetric examination of Class 1 nonle-

. to-vessel welds and inside radius sections. Inservice volumetric examinations of pressure vessel welds using radiography is not practical due to their heavy wall l thicknesses and component geometries. The ultrasonic volumetric examination

! techniques for pressure vessel welds in ferritic material greater than 2 inches thick -

l are described in Article 4 ASME Section V. ASME Section V, Article 4 requires the weld and adjacent base metal to be examined using nominal angles of 0,45, and 60 degrees. Deviation from the 45 and 60 degree angles is permitted if geometry l limits the coverage; however, separation of angles must be at least 10 degrees.

l "(a) Four basic scans are required for the nonle-to-vessel welds:

1. Axial scans of the weld area - 2 angle beam paths from 2 directions for I reflectors parallel to the weld. (ASME Section V, Article 4, T-441.5.1) l

2. Axial scans of the adjacent base metal- 2 angle beam paths from at  ;

least 1 direction for reflectors parallel to the weld. (ASME Section V, .

Article, T-441.5.1) I l

3. Circumferential scans of the weld and adjacent base metal-2 angle beam paths from 2 directions for transverse reflectors. (ASME Section V, Article 4, T-441.5.2)

4. Zero degree scans of the weld and adjacent base metal for planar and laminar reflectors.

"(b) Nozzle inside radius section scans are not specifically addressed by ASME Section V. For the purpose of evaluating whether a limited examination condition exists, scanning requirements must be established. The scanning techniques described below are required for the detection of flaws which extend radially from the noule bore and are either axial or circumferential with respect to the nonle axis.

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l 1. ' Circumferential flaws should be detected by scanning radially toward the nozzle bore with angle beams that intercept the nozzle bore.

2. Axial flaws should be detected by scanning in pattems that are tangent to the nozzle bore form two opposing beam directions.

Yor each individual required scan, the amount of sound beam passing th(r)ough the required examination volume defined by ASME Section XI, Figure IWB-2500-7, has been plotted on scaled cross sectional drawings of the component. The examination coverages reported in Table I have been determined by averaging the amount of coverage obtained from each of the required scans. Where geometry permits, the 45 and 60 degree angle beam techniques have been supplemented with an additional 35 degree angle beam scan to increase the examination coverage. These examinations are limited by part geometry, such that the reduction in coverage is greater than 10 percent.

" Component and Examination Details "Due to the design and geometries of these components, an extended full-vee beam path examination technique is required to achieve bi-directional axial beam coverage. Figure i provides an illustration of a typical nozzle configuration and axial examination coverage. An extended full-vee path examination is not feasible due to the inability to ' bounce' the ultrasonic beam from the inside cladded surface. This ultrasonic technique restriction

' is common to all cladded components. The reduced examination coverages identified in this relief request have been present during the preservice, first ten-year interval, and second ten-year interval examinations.

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"1. Pressurizer Relief Nozzle-to-Head Welds, Unique Iderdfiers B2.2.1 A, B2.2.2A, and B2.2,3A. i

" Pressurizer Relief Nozzle inside Radius Sections, Unique Identifiers B2.2.1B, B2.2.28, and B2.2.3B.

"79 percent of the nozzle to-head weld volume has received axial beam scans from the vessel head. 63 percent of the weld volume has received circumferential angle beam scans from 2 directions.

49 percent of the nozzle inside radius section has-received circumferential and axial scan coverage with at least one angle beam.

During normal operation of the reisctor coolant system, these components experience no fluid flow. (An operating condition similar to manways and handhole nozzles which renders them exempt form

. ASME Section XI examination requirements). The absence of fluid flow l through these nozzles should minimize thermal gradients and I associated stresses across these components. No indications L associated with component degradation have been detected during the

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, 1 Preservice, First Interval', or Second interval examinations of these components.

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"2. Pressurizer Spray Nozzle-to-Head Weld, Unique Identifier B2.2.4A Pressurizer Spray Nozzle inside Radius Section, Unique Identifier l B2.2.4B j "94 percent of the weld volume has received axial angle beam scans from the vessel head. 55 percent of the weld volume has received -,

circumferential angle beam scans from 2 directions. 56 percent of the nozzle inside radius section has received circumferer dal and axial scan coverage with at least one angle beam. A thermal sleeve located I inside of the pressurizer protects this nozzle frorr. thermal gradients and associated stresses acmss the nozzle and inside radius section.

No indications associated with component degradation have been recorded during the preservice, first interval, or second interval examinations of this component.

"3. Pressurizer Surge Nozzle-to-Head Weld, Unique Identifier 82.2.6A Pressurizer Surge Nozzle Inside Radius Section, Unique Identifier B2.2.68 "88 percent of the weld volume has received axial angle beam scans from the vessel head. 62 percent of the weld volume has received circumferential angle beam scans from 2 directions. 66 percent of the nozzle inside radius section has received axial scan coverage with at least one angle beam. A surge diffuserlocated inside of the pressurizer surge nozzle minimizes thermal gradients and associated stresses to the nozzle and inside radius areas.

"During the second interval examination of the pressurizer surge nozzle-to-head weld, one mid-wall fabrication-related indication was detected in the pressurizer surge nozzle-to-head weld. This indication was initially evaluated as unacceptable to ASME Section XI, lWB-3500. Further investigation using ennanced ultrasonic techniques (focused transducer technique) revealed that the indication was considerably smaller than originally sized and exhibited characteristics typical of a slag inclusion (FPC to NRC letter,3F0597-04, dated May 14,1997, TAC No. M90489). The indication has been re-evaluated as acceptable to ASME Section X!, IWB-3500. No indications associated with component degradation have been recorded during the

cavice, First interval, or Second Interval examinations of the pressurizer surge nozzle and inside radius section. j "4. Steam Generator Inlet Nozzle-to-Head Welds, Unique identifiers ,

B3.2.1 and B3.2.4 i

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" Steam Generator inlet Nozzle inside Radius Sections, Unique identifiers B3.2.1.1 and B3.2.4.1 "89 percent of the weld volume has received axial angle beam scans from the vessel head. 61 percent of the nozzle inside radius section has received axial scan coverage with at least one angle beam.

"No indications associated with component degradation have been recorded during the Preservice, First Interval, or Second Interval examinations of the steam generator inlet nozzles and inside radius sections.

"5, Steam Generator Outlet Nozzle-to-Head Welds, Unique identifiers B3.2.2, B3.2.3, B3.2.5, and 83.2.6

" Steam Generator Outlet Nozzle inside Radius Section Unique identifier B3.2.2.1, B3.2.3.1, B3.2.5.1, and B3.2.6.1 "In audition to the ultrasonic technique restrictions common to all cladded nozzle-to-head welds mentioned above, the steam generator outlet nozzles have a scanning restriction due to an interference near the support skirt interference near the top of the nozzle. 83% percent of the weld volume has received axial angle beam scans from the vessel head. 88 percent of the weld volume has received circumferential angle beam scans from 2 directions. 68 percent of the nozzle inside radius section has received axial scan coverage with at least one angle beam. No indications associated with component degradation have been recorded during the preservice, first interval, or second interval examinations of the steam generator outlet nozzles and inside radius sections.

Licensee's Proposed Attemative Examination (as stated);

l l " Examinations of the identified welds have been performed to the maximum extent practical within the limits of design and geometry.

"The volumetric examination coverage of the Pressurizer Relief Nozzle-to-Vessel Welds, Unique Identifiers B2.2.1 A, B2.2.21, and B2.2.3A, is limited to 50 percent. i l

The volumetric examination coverage of the Pressurizer Relief Nozzle inside

! Radius Sections, Unique Identifiers B2.2.1B, B2.2.28, and B2.2.3B, is limited to 42 l

percent.

?The volumetric examination coverage of the Pressurizer Spray Nozzle-to-Vessel Weld, Unique identifier B2.2.4A is limited to 57 percent. The volumetric examination coverage of the Pressurizer Spray Nozzle inside Radius Section, Unique Identifier B2.2.48, is limited to 48 percent.

4 "The volumetric examination coverage of the Pressurizer (PZR) Surge Nozzle-to-Vessel Weld, Unique identifier B2.2.6A is limited to 47 percent. The volumetric examination coverage of the Pressurizer Surge Nozzle Inside Radius Section, Unique identifier B2.2.6B, is limited to 37 percent.

"The volumetric examination coverage of the Steam Generator (S/G) Inlet Nozzle-to Vessel Weids, Unique identifiers B3.2.1 and B3.2.4, is limited to 46 percent.

The volumetric examination coverage of the Steam Generator inlet Nozzle Inside Radius Sections, Unique identifiers 83.2.1.1 and B3.2.4.1, is limited to 31 percent.

"The volumetric examination coverage of the Steam Generator Outlet Nozzle-to Vessel Welds, Unique Identifiers B3.2.2 and B3.2.5, is limited to 63 percent. The volumetric examination coverage of the Steam Generator Outlet Nozzle inside Radius Sections, Unique Identifiers B3.2.2.1 and B3.2.5.1, is limited to 48 percent.

"The volumetric examination coverage of the Steam Generator Outlet Nozzle-to-Vessel Welds, Unique Identifiers B3.2.3 and B3.2.6, is limited to 49 percent. The volumetric examination coverage of the Steam Generator Outlet Nozzle inside Radius Sections, Unique Identifiers B3.2.3.1 and B3.2.6.1, is limited to 43 percent."

Evaluation: The Code requires 100% volumetric examination of the suyact nozzle-to-vessel welds and inner radius sections. However, complete examination is restricted by the geometric configuration of the nozzles and by physical restrictions around the nozzles. The geometric and physical restrictions make the 100% volumetric examination impractical for these areas. To gain access for examination, the nozzles would require design modifications. Imposition of this requirement would create a significant burden  !

on the licensee. I i

i The licensee has examined the twenty-two subject welds and inner radius sections to the extent practical, obtaining 31% to 63% coverage (52% average coverage for the j l

nozzle welds and 41% average coverage for the inner radius sections). Based on the l coverages obtained, it is reasonable % conclude that existing patterns of degradation, if present, would have been detected by the examinations that were completed. 1 Therefore, reasonable assurance of the structuralintegrity has been provided.

Based on the impracticality of meeting the Code examination requirements for the subject nozzle-to-vessel welds, and the reasonable assurance provided by the

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i examinations that were completed, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

E.- Reauest for Relief No. 98-011-11. Examination Cateoorv B-H. Pressurizer Inteoral Attachment Welds Code Reauirement: Examination Category B-H, item B8.20 requires 100% volumetric or surface examination, as applicable, as defined by Figures IWB-2500-13, -14, -15, for pressurizer integrally welded attachments.

Licensee's Code Relief Recuest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code-required 100% surface examination for the following pressurizer integrally welded attachments.

B2.8.1 B2.8.9 B2.8.3 B2.8.11

! B2.8.5 B2.8.13 82.8.7 B2.8.15 Licensee's Basis for Reauestino Relief (as stated):

"The pressurizer support integral attachments consist of 2 pieces of steel, welded in the shape of an upside-down "T". This arrangement is depicted in Enclosure 1, l FPC Drawing 16044E. The support lugs are welded to the outside side of the vessel and bolted to building steel. The arrangement of the structural steel ]'

support is located in Enclosure 2, Drawing S-521-024. The vertical welds and the top of the horizontal weld are accessible for the surface exam. Access to the l l length of weld beneath the pressurizer support beams is not possible without i i disassembly of the building structure. During Preservice and First Interval Ultrasonic Examinations were performed in accordance with the 1974 Edition of ASME Section XI through Summer 1975 Addenda. However, the 1983 Edition

. through Summer 1983 Addenda changed the requirements to surface exams.

"The accessible length examined, during the Second Interval, by the magnetic particle method has been determined to be 73 percent. There is a total of 72.75" i of weld length for each support. 53.25" of the weld length has been examined by l I

,. magnetic particle examination.16" of the horizontal weld length is not accessible under the support due to the building structure. 3.5" of the weld length at the top q l

f I

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of the vertical support is not accessible due to an insulation support ring that circles the vessel. The percent examined was calculated as (53.25/72.75) x 100=73.

"No indications were detected by magnetic particle examinations of the pressurizer support integral attachment welds."

Licensee's Proposed Altemative Examination (as stated):

" Surface examinations of the pressurizer support integral attachment welds have been performed to the maximum extent practical within the limits of design and geometry. Seventy three (73) percent of the length of eat pressurizer support integral attachment weld has been examined by the magnetic particle method."

Evaluatign: The Code requires 100% surface examination of the subject pressurizer integral dttachment Wid. Drawings supplied by the licensee confirm that complete examination is restricted by physical obstructions that make the 100% surface examination impractical for these areas. To gain access for examination, disassembly of the building structure would be required. Imposition of this requirement would create aa undue burden on the licensee.

l The licensee has examined the subject integral attachments to the extent practical, obtaining a significant portion (73%) of the required coverage of each of the integral attachments. Based on the significant amount of coverage obtained, it is reasonable to conclude that any existing pattoms of degradation, if present, would have been detected. Therefore, reasonable assurance of the structuralintegrity has been provided.

Based on the impracticality of meeting the Code examination requirements for the subject integral attachments, 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).

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-3. CONCLUSION The INEEL staff has reviewed the licensee's submittal and concludes that for Request for Relief R98-009-Il Part A, full compliance with the augmented reactor pressure vessel examination requirements would result in hardship without a compensating increase in the level of quality and safety. Therefore, it is recommended that the proposed alternative be authorized pursuant to 10 CFR 50.55a(3)(ii).

For Requests for Relief 98-009-II, Parts B and C,98-010-11, and 98-011-11, it is concluded that the Code requirements are impractical. There' ore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

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l Mr. John Paul Cowan CRYSTAL RIVER UNIT NO. 3 Florida Power Corporation cc:

Mr. R. Alexander Glenn Chairman Corporate Counsel (MAC-BT15A) Board of County Commissioners j Florida Power Corporation Citrus County j P.O. Box 14042 110 North Apopka Avenue  !

St. Petersburg, Florida 33733-4042 Inverness, Florida 34450-4245 l

Mr. Charles G. Pardee, Director Ms. Sherry L. Bernhoft, Director Nuclear Plant Operations (PA4A) Nuclear Regulatory Affairs (NA2H)

Florida Power Corporation Florida Power Corporation Crystal River Energy Complex Crystal River Energy Complex 15760 W. Power Line Street 15760 W. Power Line Street Crystal River, Florida 34428-6708 Crystal River, Florida 34428-6708

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Mr. Michael A. Schoppman Senior Resident inspector Framatome Technologies Inc. Crystal River Unit 3 1700 Rockville Pike, Suite 525 U.S. Nuclear Regulatory Commission Rockville, Maryland 20852 6745 N. Tallahassee Road Crystal River, Florida 34428 Mr. William A. Passetti, Chief Department of Health Mr. Gregory H. Halnon Bureau of Radiation Control Director, Quality Programs (SA2C) 2020 Capital Circle, SE, Din #C21 Florida Power Corporation Tallahassee, Florida 32399-1741 Crystal River Energy Complex 15760 W. Power Line Street Attorney General Crystal River, Florida 34428-6708 Department of Legal Affairs The Capitol Tallahassee, Florida 32304 '

Mr. Joe Myers, Director l

Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 '

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