ML20213F440
| ML20213F440 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/07/1986 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| ULNRC-1399, NUDOCS 8611140208 | |
| Download: ML20213F440 (29) | |
Text
UNK)N Etscrmc n
1901 Gratet Street. St. Louos Donald F. Schnell Vce Presxtent November 7, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ULNRC-1399
Dear Mr. Denton:
DOCKET NO. 483 CALLAWAY PLANT UNION ELECTRIC RESPONSE FOR ADDITIONAL INFORMATION CONCERNING THE CALLAWAY_P_LA,NT INS _ERVICE INSP,ECTION PROGRAM PLAN
Reference:
P. W. O'Connor letter to D.
F.
Schnell dated August 27, 1986 Additional information requested by the referenced letter concerning the Callaway Plant Inservice Inspection (ISI) Program Plan for the first inspection interval is attached.
If you have any additional questions, please contact me.
Very truly yours, Donald F. Schnell DFS/ mat Attachments 8611140208 861107 DR ADOCK 05000483 1
PDR O
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Mailing Address: P.O. Box 149. St. Louis, MO 631C6
P
$ STATE OF MISSOURI )
)
Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By
~
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Donafd F.
Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this [
day of Nt9 tmh, 198b.
f
(
A4 4-0 0 BARBARA J. PFAFr NOTARY PUCUC, STATE Of UtSSOURI MY CCMM SSION EXPIRES APRIL 22.193'J ST. LOUIS COUNTY.
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cc Gerald Charnoff, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.
Washington, D.C.
20036 Nicholas A. Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 C. W. Hehl Division of Projects and Resident Programs, Chief, Section lA U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Of fice i
U.S. Nuclear Regulatory Commission RR$1 Steedman, Missouri 65077 Paul O'Connor (2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 l
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O RESPONSE TO NRC COMMENTS PERTAINING TO THE FIRST INTERVAL INSERVICE INSPECTION PLAN FOR THE UNI _OJLELECTRI,C,,CALLAWAY_ PLANT, _ _
NRC Comment,2A ASME Code Section XI paragraph IWF-2510, " Supports Selected for Examination", states that component supports selected for examination shall be the supports of those components that are required to be examined under IWB, IWC, IWD, and IWE during the first inspection interval, and for multiple components within a system of similar design, function, and service, the supports of only one of the multiple components supports (NES document No.
83A1003 Rev. 2),
the support assemblies are divided as (1)
Equipment support assemblies, and (2) Piping support assemblies.
Demonstrate that the selection of piping support assemblies for examination meets or exceeds the Code requirements.
UE Response The selection of the piping supports in the ISI Program Plan for component supports (NES document No. 83A1003 Rev. 2) exceeds the Code requirements in some respects while it deviates from the Code in other respects.
In regards to the areas of deviation, Callaway ISI Relief Request F is submitted.
This Relief Request is included in the UE Response to NRC Comment 2D.
The sampling plan employed in the Callaway component support plan exceeds the Code requirements in two important ways.
The component support population base from which supports are selected for examination at Callaway contains the supports of all Class 1,
2, and 3 piping.
The only exemptions allowed are for supports that are completely inaccessible or for supports of piping with a
nominal pipe size of one inch or less.
This results in a
total population base of approximately 4000 supports.
This is in contrast to the Code which only requires inspection of supports on those non-exempt components that are required to be examined by volumetric, surface, or visual (VT-1 l
or VT-3) examination methods, which would yield a population base l
of approximately 1000.
This results in a population base for the I
Callaway plan which is four times greater than that of a
plan developed strictly to the Code requirements.
The Callaway method of component selection for examination is based on a systematic and unbiased statistical analysis.
This is in comparison to a Code plan which would allow selection based on accessability and similarity between component design (i.e.,
only one of a
number of similar components is required to be examined).
The statistical analysis employed is described within the Callaway plan.
The goal is to select a specific number of Attachment A Page 1 of 5
supports in order to provide a
95 percent confidence that populations containing 10 percent or more unacceptable support assemblies will be detected (95/90 criteria).
The 10 percent unacceptable figure does not pertain to generic type failures.
That is any generic failure which is discovered warrants addi tiona, l group examinations while an isolated failure would only warrant additional group examination if that failure exceeds the number of allowed failures within the 95/90 criteria.
In all cases, discovery of a failure warrants examination of adjacent supports.
The not result of the statistical selection method is two fold.
- One, the Callaway plan requires examination of approximately 440 supports.
This is in comparison to approximately 500 supports which would be examined under the Code plan.
And two, the Callaway plan does not require expanded group examination if a non-generic failure does not exceed the 95/90 criteria.
Therefore this selection plan, in conjunction with the increased population, provides a systematic means for selection and a
broad population from which generic type failures can be discovered.
The second area where the Callaway plan exceeds Code requirements is in the philosophy of examination for generic type failures.
The Callaway plan is designed on the basis of initial examinations looking for generic type failures within a specific support type.
This is in excess of the Code which only looks for generic type failures after an unacceptable support has been found.
The Callaway plan accomplishes this aspect by grouping supports into six (6) generic types:
- rigid, frame,
- anchor, variable spring, constant spring, and snubber support assemblies.
From these groups the supports are selected for examination and generic problems can be systematically discovered.
The positive result of these two aspects is that with a larger population base and the generic type of examination, generic types of failures should be discovered with the Callaway plan which may not have been observed under a
Code plan.
Yet generic or isolated failures observed under a Code plan should be discovered with the Callaway Plan.
The advantage to the utility for using such a plan is that additional group examinations do not always have to be performed for isolated failures and a
higher confidence can be placed on the selection method used.
Union Electric believes this plan increases plant safety and provides a more reasonable method for examination expansion when required.
Attachment A Page 2 of 5
NRC_ Comment 2B Paragraph 10 CFR 50.55a (b) (2) (iv) requires that ASME Code Class 2
piping welds in the Residual Heat Removal (RHR),
Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems shall be examined.
These systems should not be completely exempted from inservice volumetric examination based on Section XI exclusion criteria contained in IWC-1220.
The inservice inspection program for the Containment Cooling System (NES document No. 83A0988) must include volumetric examination of a
representative sample of welds.
Justify why this system has been completely exempted from inservice volumetric examination.
UE Response The Containment Cooling System contains only six (6) lines that are ASME Class 2 piping.
These lines have a
nominal pipe size of 1/2"
- and, therefore, are exempted from examination by IWC-122 0 (d ), of the 1974 Edition / Summer 1975 Addenda of the Code, which exempts piping of 4"
nominal pipe size and less.
The remaining portions of this system are ASME Class 3 piping and are not subject to paragraph 10 CFR 50.55a (b) (2) (iv).
1 Attachment A Page 3 of 5
NRC Comment 2C, Paragraph IWC-1220 (d ),
" Exempted Components", of the ASME Code Section XI 1974 Edition, Summer 1975
- Addenda, states that component connections, piping, and associated valves, and vessels (and their supports), that are 4
in.
nominal pipe size and smaller may be exempted from the examination requirements of IWC-2520.
In the ISI Program Plan for the Chemical and Volume Control System (NES document No. 83 A0983), piping 442-BCB-12" and 444-BCD-10" are listed as exempt per IWC-1220 (d)
S
'75 Addenda and treated as vessels with 3 in. connections, and section 2.1,
" Exemptions and Exceptions", states " Letdown delay lines 442-BCB-12" and 444-BCB-10", with inlet and outlet lines of 3 in. and 1 in. NPS, respectively, are considered exempt because the failure of the 10 in, and 12 in. lines are of no greater consequences than the failure of the 1 in. and 3 in. lines, which are exempt per Section XI."
The Licensee may not arbitrarily rename a pipe as a vessel.
If the Licensee has determined the ASME Code requirements for examination of these two lines to be impractical to perform, a request for relief from the ASME Code Section XI requirements should be submitted for staff review.
UE Response These two lines will be included in the Inservice Inspection Program as specified in the Code.
1 Attachment A Page 4 of 5
NRC Comment 2D 10 CFR 50. 55a (g) (5) requires that if the licensee determines that certain code examination requirements are impractical and relief is requested, the licensee shall submit information to the staff to support that determination.
The Licensee should submit complete list of requests for relief from ASME Code Section XI arequirements which the Licensee has determined to be impractical to perform at Callaway.
When preparing requests for relief, the staff suggests that the Licensee follow the attached Appendix A,
" Guidance for Preparing Requests for Relief from Certain Code Requirements Pursuant to 10 CFR 50.55a (a) (3) ".
UE Response Relief Requests have been generated and are attached.
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Attachment A Page 5 of 5
ATTACHMENT B UNION ELECTRIC CALLAWAY PLANT FIRST INTERVAL INSERVICE INSPECTION i
l RELIEF REQUESTS l
Attachment B 1.
INTRODUCTION The ISI Program Plan for the first Interval at the Callaway Plant has been developed to meet the letter and intent of the ASME
- Code,Section XI 1980 Edition /1981 Winter Addenda and Section XI 1974 Edition /1975 Summer Addenda as required by 10 CFR 50.55a.
-The Relief Requests contained herein describe the areas in the plant where deviation from the examination requirements as allowed by 10 CFR 50.55a have taken place.
Requests for relief from the ASME Section XI required examinations have been submitted to the Regulatory Authority as allowed by 10 CPR
- 50. 55 ( A) (2).
This is allowable with the provision that design, fabrication, installation,
- testing, and inspection were performed in compliance with the generally recognized codes and standards and are in compliance with the requirements described in paragraphs (c) through (i) of 10 CFR 50.55 or portions thereof would result in hardship or unusual difficulties without a
compensating increase in the level of
^
quality or safety; or with the provision that the proposed alternatives to the described requirements or portions thereof will provide an acceptable level of quality of safety.
2.
RELIEF REQUESTS Appendices A through F contain the requests for relief from some examination requirements specified by the code.
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CALLAWAY.ISI RELIEF REQUEST A f
System:
Chemical volume and' Control Category:
C-F Component
Description:
Sixteen (16) small bore piping welds within the Reactor Coolant Pump Seal Water Injection Lines.
.S.ee Appendix C for detailed description and weld identification.
i Code Requirements:
None; Augmented volumetric examination required for Break Exclusion Piping 1.
(NUREG 0800).
Areas for Relief:
Volumetric examination of piping welds.
Basis for Relief:
Combination of small pipe diameter and minimum wall thickness cause volumetric examination to be meaningless.
i Alternate Testing:
Dye Penetrant Testing; the combination of the Alternate
- Test, the ISI visual inspection for
- leakage, and the Code required fabrication examinations l
establish the integrity of these welds.
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Appendix A Page 1 of 1 i
'l CALLAWAY ISI RELIEF REQUEST B System:
Reactor Coolant Category:
B-J Component
Description:
Two (2) branch connection welds on the primary loops, weld identification:
2BB-Ol-S302-3, 6 inch branch; 2BB-01-S402-3, 14 inch branch.
Code Requirement:
Surface and Volumetric examination as required by item B.9.31, category B-J, figures lWB-2500-8 and lWB-2500-11 (see attached figures 1 and 2).
1 Areas for Relief:
100%
Volumetric examination of the two branch connections identified above.
I Basis for Relief:
Due to the materials of construction (austenitic) and the design and fabrication geometry of the corner type branch connection depicted in attached figure 1, it is concluded that meaningful examination by ultrasonic methods is not feasible and that no other practical volumentric method is available.
l I
Alternate Test Method
- None; the combination of required surface examination, visual examination for leakage and the Code required fabrication examinations establish the integrity of the pressure boundary.
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Appendix B Fig. IWB 2500-11 Figure 1
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NOTE: E xamination volumes C E - F are defined per Fig. iW8 2500-8.
W80 FIG. [WB 2500-11 PIPE BRANCH CONNECTION W81 Page 2 of 3
p1g IWB-M Appendix B Figure 2 e
Profile of velve body, vessel nozzle, or Exem. sue face pump connection A-B 4
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W80 FIG. IWB-2500-8 SIMILAR AND DISSIMILAR METAL WELDS IN COMPONENTS AND PIPING (CONT'D)
Page 3 of 3 1
I
CALLAWAY ISI RELIEF REQUEST C
-System:
See Appendix C, Pages 2, 3, and 4 Category:
See Appendix C, Pages 2, 3, and 4 Component
Description:
See Appendix C, Pages 2, 3, and 4 Code Requirement:
See Appendix C, Pages 2, 3, and 4 Areas for Relief:
See Appendix C, Pages 2, 3, and 4 Basis for Relief:
See Appendix C, Pages 2, 3, and 4 Alternate Test Method:
None; the combination of the required surface examination, visual examination for leakage and the Code required fabrication examinations establish the integrity of the pressure boundary.
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Appendix C Page 1 of 4 l
CALLAWAY ISI RELIEF REQUEST C Systen: Reactor Coolant Category Description Component I.D.
Code Requirement Area For Relier Basis For Relief B-J 4" Pipe to Valve 2-BB-04-F015 Volumetric examination 5% of weld volume Valve geometry 2-BB-04-F014 from two directions of obstructs scan the weld path System: Accumulator Safety Injection Category Description Component I.D.
Code Requirement Area For Relier Basis For Relier B-J 6" Pipe to 6" X 2-EP-01-F-012 Volumetric examination 9% of weld volume Tee geometry 10" X 10" Tee from two directions of obstructs scan the weld path B-J 10" Pipe to 6" X 2-EP-01-S003E Volumetric examination 20% of weld volume Tee geometry 10" X 10" Tee from two directions of obstructs scan the weld path B-J 10" Pipe to 6" X 2-EP-01-S003F Volumetric examination 20% of weld volume Tee geometry 10" X 10" Tee from two directions of obstructs scan the weld path C-F 10" Pipe to Valve 2-EP-01-F002 Volumetric examination 13% of weld volume Valve geometry from two directions of obstructs scan the weld path B-J 6" Pipe to 10" X 2-EP-02-F020 Volumetric examination 9% of weld volume Tee geometry 10" X 6" Tee from two directions of obstructs scan the weld path C-F Valve to Pipe 2-EF-02-F003 Volumetric examination 20% of weld volume valve geometry from two directions of obstructs scan the weld path Appendix C Page 2 of 4
Systen: Accumulator Safety Injection (Continued)
Category Description Component I.D.
Code Requirement Area For Relier Basis For Relier B-J 6" Pipe to 10" X 2-EP-02-F009 Volumetric examination 5 of weld volume Tee geometry 10" X 6" Tee from two directions of obstructs scan the weld path B-J 6" Pipe to 10" X 2-EP-01-S013K Volumetric examination 9% of weld volume Tee geometry 10" X 6" Tee from two directions of obstructs scan the weld path B-J 10" X 10" X 6" 2-EP-02-S003-G Volumetric examination 2% of weld volume Tee geometry Tee to 10" Pipe from two directions of obstructs scan the weld path B-J 10" X 10" X 6" 2-EP-02-S003-F Volumetric examination 2% of weld volume Tee geometry Tee to 10" Pipe from two directions of obstructs scan the weld path System: High Pressure Coolant Injection Category Description Component I.D.
Code Requirement Areas For Relief Basis For Relier B-J 6" Pipe to 6" 2-EM-05-F007 Volumetric examination by 9% of weld volume Sweepolet geom-Sweepolet scanning both sides of etry obstructs weld scan path B-J 6" Pipe to 6" 2-EM-03-F016 Volumetric examination by 13% of weld volume Nozzle geometry Nozzle scanning both sides of obstructing scan J
weld path System: High Pressure Coolant Injection Category Description Component I.D.
Code Requirement Areas For Relief Basis For Relief B-J 6" Pipe to 2-EJ-04-F017 Volumetric examination 13% of weld volume Valve geometry Valve from two directions of obstructs scan the weld path Appendix C Page 3 of 4
Syntsn: Residual Heat' Removal Category Description Component I.D.
Code Requirement Areas For Relief Basis For Relier B-J 12" Pipe to 12" 2-EJ-04-F026 Volumetric examination 13% of weld volume Nozzle geometry.
Nozzle of weld obstructs scan path i
B-J 12" Pipe to 2-EJ-04-F031 Volumetric examination 13% of weld volume Valve geometry Valve of weld obstructs scan path t
Appendix C Page 4 of 4 i
CALLAWAY ISI RELIEF REQUEST D System:
Pressurizer Category:
B-F Component
Description:
1(a)
Relief Nozzle to Safe-end Weld, 2-T-BB03-4-W 1(b)
Safety Nozzle to Safe-end Weld, 2-TBB03-3-A-W 1(c)
Safety Nozzle to Safe-end Weld, 2-TBB03-3-B-W 1(d)
Safety Nozzle to Safe-end Weld, 2-TBB03-3-C-W 2.
Surge Nozzle to Safe-end Weld, 2-TBB03-1-W 3.
Spray Nozzle to Safe-end Weld, 2-TBB03-2-W Code Requirement:
100% volumetric Examination Areas for Relief:
1(a) - 1(d) 20% of total weld volume 2.
25% of total weld volume 3.
5% of total weld volume Basis for Relief:
All examination limitations were due to a combination of weld geometry and metallurgical obstruction caused by Inconel buttering used in the components.
Alternate Testing:
None; the combination of required surf ace 4
examination,-
visual examination for leakage and the Code required fabrication examinations establish the integrity of the pressure boundary.
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l Appendix D Page 1 of 1 i
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CALLAWAY ISI RELIEF REQUEST E i
System:
Reactor Pressure Vessel Category:
B-A Component
Description:
Lower Head to Shell Weld, (I.D. # 2-RV-101-141)
Code Requirement:
100% Volumetric Examination Areas for Relief:
The weld area immediately beneath the six (6)
RPV Core Support
- lugs, totalling approximately 15%
of the total weld i
volume.
Basis for Relief:
When performing the perpendicular scan of the weld, the search unit cannot reach the weld area below the core support lugs due to the obstruction created when the examination head contacts the outside edge of each lug.
A slight loss of coverage,. reflected in the 15% total loss figure, is also encountered due to the lug-obstruction when performing the parallel scan.
Alternate Testing:
None; the combination of the visual examination for
- leakage, the
-Raactor Coolant System leakage detection system, and the Code required fabrication examinations establish the integrity of the pressure boundary.
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Appendix E i
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CALLAWAY ISI RELIEF REQUEST E
' System:
Reactor Pressure Vessel Category:
B-A Component
Description:
Lower Head to Dollar Plate Weld, (I.D. # 2-RV-102-ISI),
Meridional Welds in Lower Head (I.D. # 2-RV-101-154A, i 2-RV-101-154B, t 2-RV-101-154C,
- 2-RV-101-154D)
Code Requirement:
100% Volumetric Examination Areas fo'r Relief:
A total of approximately 10% of the Lower Head to Dollar Plate Weld and 10% of the combined weld volumes of the four meridional welds.
Basis for Relief:
Obstructions presented by.
the instrumentation nozzles when scanning the Lower Head to Dollar Plate Weld and meridional welds preclude complete i
volumetric coverage.
l Alternate Testing:
None; the combination of the visual examination for
- leakage, the Reactor Coolant System leakage detection system, and the Code required fabrication examinations establish the integrity of the pressure boundary.
t I
i Appendix E Page 2 of 8 l
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4 CALLAWAY ISI RELIEF REQUEST E System:
Reactor Pressure Vessel Category:
B-A Component
Description:
Flange to Vessel Weld, (I.D. # 2-RV-101-121)
I Code Requirement:
100% Volumetric Examination Areas for Relief:
25% of Weld Volume Basis for Relief:
Parallel scan portion of examination can only be done from lower side due to presence of flange taper above the weld.
Complete perpendicular scan was done from flange mating surface.
Alternate Testing:
None; the combination of the visual examination for
- leakage, the Reactor Coolant System leakage detection system, and the Code required fabrication examinations establish the integrity of the pressure boundary.
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Appendix E Page 3 of 8 l
I.
CALLAWAY ISI RELEIF REQUEST E I
System:
Reactor Pressure Vessel Category:
B-D Component
Description:
Outlet Nozzle A to Vessel. Weld, (I.D. I 2-RV-107-121-A),
Outlet Nozzle D to Vessel Weld, (I.D. I 2-RV-107-121-B),
Outlet Nozzle E to Vessel Weld, (I.D. # 2-RV-107-121-C),
Outlet Nozzle H to Vessel Weld, (I.D. I 2-RV-107-121-D)
Code Requirement:
100% Volumetric Examination Areas for Relief:
Approximately 10%
of total weld volume for each nozzle.
Basis for Relief:
Approximately 10%
of the total weld volume for each outlet nozzle is j
obstructed by contact between the l
examination head and the nozzle knuckle extending from the nozzle opening through the plane of the Reactor Pressure Vessel Inner Diameter.
Alternate Testing:
None; the combination of the visual 4
examination.for
- leakage, the Reactor i
Coolant ' System leakage detection system, and the-Code required fabrication examinations establish the integrity of the pressure boundary.
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Appendix E Page 4 of 8 t-
CALLAWAY ISI RELIEF REQUEST E I
System:
Reactor Pressure Vessel Category:
B-A Component
Description:
Top circumferential weld in the RPV Closure head, (I.D. # 2-CH-103-101)
Code Requirement:
Volumetric examination from two directions of the weld.
Areas for Relief:
35% of total weld volume Basis for Relief:
Control Rod Drive mechanism penetrations, three lifting lugs welded directly onto 2-CH-103-101, and obstructing closure head shrouding, preclude complete volumetric examination.
Removal and reinstallation of closure head shroud during ISI will require 1000 manhours of I
effort.
This would result in personnel exposure totaling 10 manrem minimum and would still not permit complete weld coverage.
Alternate Testing:
None; Accept as is; the combination of the visual examination for
- leakage, the Reactor Coolant System leakage detection system, and the Code required fabrication examinations ~ establish the integrity of the pressure boundary.
Appendix E Page 5 of 8 l
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l CALLAWAY ISI RELIEF REQUEST F System:
All ASME Class 1, 2, and 3 Systems Category:
F-A, F-B, F-C Code Requirement:
IWF 2510 (b) :
For multiple components within a
system of similar
- design, function, and
- service, the support of only one of the components are required to be examined.
Areas for Relief:
Selection of the Component supports based upon the selection criteria identified in the code requirements above.
A total of approximately 60 supports will not be examined.
Basis for Relief:
Alternate method provides a better method for detecting generic problems.
Alternate Testing:
Alternative test method provides a better selection method.
Select supports from the entire population of ASME class 1, 2, and-3 component supports.
Base the selection on generic failures and statistical analysis to meet a
95%
confidence that support populations containing 10%
or more unacceptable assemblies will be detected (95/90 criteria).
Only exemptions are allowed for unaccessible supports and supports on piping with a nominal pipe size of 1 inch and less.
Appendix F Page 1 of 2
CALLAWAY ISI RELIEF REQUEST F System:
All ASME Class 1, 2, and 3 systems Category:
F-A, F-B, F-C Component
Description:
IWF-2430:
(a)
When the results of examinations require corrective measures in accordance with the provisions of IWF-3000, the component supports immediately adjacent.to those requiring corrective i
action shall be examined.
- Also, the examinations shall be extended to include additional supports equal in number and similar in type, design, and function to those initially examined during the inspection.
(b)
When these' additional examinations require corrective measures in accordance with the provisions of IWF-3000, the remaining component supports i
within the system of the same
- type, design, and function as in (a) above shall be examined.
Areas for Relief:
The requirement
'for examination of additional supports equal in number and similar in
- type, design, and function when a non-generic failure is discovered.
Basis for Relief:
Alternate method provides a
more reasonable method for examination expansion with no decrease in plant safety.
Alternate Testing:
Expansion of ex4mination will be based upon generic an6 statistical failures.
The expan5ico will include supports of similar Ot sim and function within the entir( rapu' 4 ion of supports.
Expansion will ocbur when any generic failure is discovered and when the statistical criteria is exceeded.
This method of
(
expansion will ensure generic failures are discovered.
System integrity is maintained by looking at adjacent supports on any discovered failure.
l Appendix F Page 2 of 2 l
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