ML20214Q011

Forwards Addl Info on Relief Request from ASME Code Section XI Requirements Re Insp of Longitudinal & Circumferential Pipe Welds,Including up-to-date List of Category B-J Welds to Be Inspected,Per 860512 Request

ML20214Q011
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	09/16/1986
From:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Charemagne Grimes Office of Nuclear Reactor Regulation
References
AO5793, NUDOCS 8609240138
Download: ML20214Q011 (7)

Text

CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N, CONNECTICUT P.o Box 270 HARTFORD, CONNECTICUT 06141-0270 TELEPHONE 203-665-5000 September 16,1986 Docket No. 50-213 A05793 Office of Nuclear Reactor Regulation Attn: Mr. Christopher I. Grimes, Director Integrated Safety Assessment Project Directorate Division of PWR '.icensing - B U. S. Nuclear Regulatory Commission Washin~, ton, D. C. 20555 Gentlemen:

Haddam Neck Plant Response to Requests for AdditionalInformation on the Relief Request Pertaining to Code Inspection of Longitudinal and Circumferential Pipe Welds The purpose of this letter is to provide additionalinformation for a relief request from ASME,Section XI requirements which was denied because of insufficient information originally provided.

By letter dated April 9,1984(l), Connecticut Yankee Atomic Power Company (CYAPCO) submitted an updated Inservice Inspection Program and information related to requests for a relief from certain Code requirements. The updated program is based on the requirements of the 1980 Edition, through Winter 1980 Addenda of Section XI of the ASME Code. As approved, the program will remain in effect until the end of the second ten (10) year interv I or January 1,1988, unless otherwise modified. By letter dated May 12, 1986 I he t Staff forwarded their approval of the updated program and their Safety and Technical Evaluation Reports related to requests for relief from inservice inspection requirements.

Within the Technical Evaluation Report was a discussion of Relief Request 1-0.

This included the reason for denying the relief request along with a discussion of what additional information would be required in order that the Staff consider the relief request. Specifically, the conclusions and recommendation section of the evaluation of Relief Request 1-0 states:

"In order to obtain relief, the licensee must submit:

a. an up-to-date list of Category B-3 welds to be inspected and (1) See the W. G. Counsil letter to D. M. Crutchfield, dated April 9, 1984. 0 (2) See the C. I. Grimes letter to 3. F. Opeka, dated May 12, 1986 8609240138 860916 PDR G

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b. specific information in the cases where relisi is required, which' supports the determination that the requirement is impractical in accordance with- the NRC guidance provided in Reference 11."

-Note that Reference 11 to the Technical Evaluation Report refers to.the A. Schwencer letter to D. C. Switzer, dated November 30,1976, that provided guidance for complying with certain provisions of 10CFR50.55a(g).

In order to further clarify what information and schedule would be acceptable , in supporting a relief from Section XI ' requirements for Category B-3 welds, a conference by telephone was held on July 9,1986

' between our Mr. 3. M. Powers and T. Ickes and your Mr. F.'Akstulewicz and Mr.G. Johnson. It was agreed that in responding to a and b, it would be acceptable to make two (2) submittals. The first, which is included as Attachment I and submitted as agreed, identifies all previously inspected second interval Category B-3 welds that require relief from ASME Code requirements because they. could not be fully examined due to pipe geometry : or support interference. Information is provided on weld identification (isometric sheet number-weld number) and the weld -

configuration / limitation prohibiting full volumetric examination. This information should be adequate to support a relief request for previously identified and examined category B-3 welds. The second submittal will be provided approximately half way through the 1987 refueling outage in order to allow sufficient time to properly identify welds requiring relief and time for the Staff to evaluate these requests prior to start-up. As discussed, the reason for this is that many of these welds are not easily accessible during

- full power operation and none will have been inspected previously.

We trust this information fully satisfies your requests for additional information. Should you have additional questions, feel free to contact us directly.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY E- A

3. F. OpeWa u Senior Vice President

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ATTACHMENT 1 l 1

CONNECTICUT YANKEE ATOMIC POWER COMPANY RELIEF FROM INSERVICE INSPECTION REQUIREMENTS Relief Request 1-0 Code Class: 1 i

Examination Category: B-J, pressure retaining welds in piping _

Item No.: B9.10,' and B9.30 (Items B4.5 and B4.6 in 1974 S75)

Code Requirement:

l As permitted by 10CFR50.55a(b)(2)(ii), Connecticut Yankee has elected to determine the extent of examination for Class 1 piping by the requirements of. Table IWB-2500 and Table IWB-2600, Category B-J of Section XI of the ASME B&PV Code, 1974 Edition, with Addenda through the Summer of 1975.

The code requires volumetric and surface exams of essentially 100 percent of the length of each Code Class 1 piping veld?4" NPS.

i Code Relief Request:

Pursuant to 10CFR50.55(a)(g)5(iii), relief is requested from performing the inservice volumetric exam of the inaccessible portions of the welds listed in Table (1) attached.

! Reason for Relief:

The arrangements and details of the Class 1 piping systems and t components were designed and fabricated before the examination requirements cf Section XI of the code were formalized. Generally, limitations exist at all fitting-to-fitting welds such as elbow to tee, elbow to valve, reducer to valve, etc., where geometry and sometimes surface conditions preclude ultrasonic coupling or access for the required scan length. The limitations exist to a lesser degree at pipe l to fitting welds, where examination can only be fully performed from the i

pipe side, the fitting geometry limiting or even precluding examination from the opposite side.

In scs cases, examinations in these areas were accomplished as a best effort attempt to cover as much of the code. required area or volume (generally, the weld and base metal for one "T" on each side) as is i

possible, however, the extent of examination coverage in the base metal of the fitting or component cannot be specifically qualified.

The resulting coverage is such that examination of the weld, heat affected zone, and base metal for one "T" on the pipe side can be achieved by scanning from the pipe side of the weld. An indeterminate coverage of the base metal on the fitting or component side may be achieved during this pipe side scan depending on the calibrated sweep length, attenuation, joint configuration, etc., however, the volume on

the fitting or component side, additionally, cannot be scanned completely for transverse indications as required by Code. In either case 3 100 percent of this one "T" volume cannot be assured.

Relief is therefore requested from performing inservice examinations on the inaccessible portions of the volume required as noted in Table 1.

Proposed Alternative Examinations A. The subject welds received a full surface examination and ultra-sonic examination to the full extent practical, in accordance with ASME Section XI. Any advances in UT technology will be evaluated to determine its application for achieving maximum volume coverage and results.

B. Inservice System Leakage Tests were performed per Category B-P, IWB-2500-1.

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Table 1 Weld Configuration / Limitation 12-2 One side only, pipe to valve / weld crown as welded 12-4 SG radius step in safe end 12-4A Step in safe end 12-5 SG radius step in safe end 12-5A Step in safe end 12-6 Elbow geometry / weld crown as welded 12-12 One side only, pipe to valve / weld crown as welded 14-1BC Branch connection to hot leg pipe, scanned 10" pipe only 14-7 Valve to elbow, one side only 15-4 Pipe to fitting mismatch, weld crown as welded, elbow geometry 16-21 Elbow geometry 16-22 Weld geometry

'16-25 Weld location 2" from weld #24 17-1 Pipe geometry, branch connection to elbow.

17-1BC Branch connection to cold leg pipe, scanned 4" pipe only 25-1

• Pipe to elbow weld scanned pipe side only 26-1BC Branch connection to cold leg pipe, scanned 4" pipe only 27-10 Elbow geometry 27-11 Elbow geometry 28-82 One side only, pipe to elbow geometry 28-83 One side only, pipe to elbow geometry 28-102 One side only, pipe to elbow geometry 35-4 Pipe to elbow, inside radius

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35-5 Pipe to elbow, inside radius 36-1BC Branch connection to cold leg pipe, scanned 4" pipe only 43-6 Limited scan on elbow side of pipe to 2" 43-7 Limited scan on elbow side of pipe to 2" 48-6 Pipe to valve, one side only, weld crown as welded 48-7 Pipe to valve, one side only, weld crown as welded 54-12A Weld crown as welded 54-15 Hanger lug 2" from weld at 45* and 315'54-20A Elbow geometry / weld crown as welded 54-21 3" to 6" reducer / weld crown as welded 54-22 Nozzle configuration / weld crown as welded PR-SV-584 55-3 h" Sockolet for branch connection 55-4 Pipe to valve, one side only PR-SV-585 55-3 Pipe to valve, one side only 55-4 Pipe to valve, one side only PR-SV-586 55-3 Elbow geometry / weld #2 1.5" from weld #3 1" pipe joining at 90*

l 55-4 One side only, pipe to valve / weld crown as welded 56-1 Nozzle to pipe geometry / weld crown as welded l

l 57-1 One side only, partial scan 'ued to tee connection 57-2 One side only, partial scan due to tee connection 57-5 Tee connection 2" obstructed on tee side 57-6 Tee connection 2" obstructed on tee side 68-4 Reducer to orifice weld geometry, we2d crown and welded name tag on orifice side 1

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, Revisita No. 11 8-27-86 COTRAP LEITER NUMBER : jpoS77 3 DISTRIBUTION MILLSTONE 1 MILLSTONE 2 MILLSTONE 3 V.L. ANDERSON (EPM) E. AB0LAFIA N-12 R.V. BISHOP J.R. BARNETI V-119 E-247 P.A. BLASIOLI V-119 M.V. BONACA V-141 P.A. BLASIOLI V-119 T.J. HONAN V-141 J.O. CROGEIT MP R.J. FACTORA/J.CORSI N-118 J.J. KELLEY MP R.G. JOSHI . V-119 E.R. FOSTER s.. MP-ROB J.S. KEENAN MP J.J. KELLEY -

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