ML20216D954

Safety Evaluation Authorizing Proposed Alternatives for Second 10-year Interval Pursuant to 10CFR50.55a(a)(3)(ii)

ML20216D954
Person / Time
Site:	FitzPatrick
Issue date:	07/28/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20216D948	List: ML20216D942 ML20216D954
References
NUDOCS 9907300209
Download: ML20216D954 (23)

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4 UNITED STATE S s.

NUCLEAR REGULATOF.Y COMMISSION WASHINGTON, D.C. 20555-0001 6

%..+4 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OFTHE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PLAN REQUESTS FOR REllEF l

ILOE I

JAMES A. FITZPATRICK NUCLEAR POWER PLANT

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POWER AUTHORITY OF THE STATE OF NEW YORK l

DOCKET NUMBER 50-333

1.0 INTRODUCTION

Inservice inspection of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Class 1,2, and 3 components shall be performed in accordance with Section XI of the ASME Code and applicable addenda as required by 10 CFR 50.55a(g),

except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements set forth in the ASME Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsejuent intervals comply with the requirements in the latest edition and j

. addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) i twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. For FitzPatrick Nuclear Power Plant, the applicable edition of Section XI of the ASME Code for the second 10-year inservice inspection (ISI) interval is the 1980 Edition through Winter 1981 Addenda.

907300209 99073 Enclosure p

ADOCK 05000333 PDR l

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I 2-l 2.0 EVALUATION l

idaho National Engineering and Environmental Laboratory's (INEEL) evaluation of the subject requests for relief are in the attached Technical Letter Report (TLR). Based on the results of the review, the staff adopts the contractor's conclusions and recommendations presented in the l

TLR attached.

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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 A l

l ASME Code,Section XI, Examination Category B-A, item B1.21 requires a 100 percent volumetric examination of the accessible length of one RPV circumferential head weld, as defined by Figure IWB-2500-3.

Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from 100 percent volumetric examination coverage for the welds VC-BH-1-2.

The licensee has proposed as an alternative examination the fcilowing:

1.

No additional volumetric examinations will be performed. The Reactor Pressure Vessel i

(RPV) welds have been examined to the maximum extent practical from the outside i

surface.

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2. A visual examination (VT-2) is performed in conjunction with the pressure testing conducted on these components every refuel outage (with no evidence of leakage detected) in accordance with IWA5000 and IWB-5000, which provides reasonable assurance of component integrity.

The staff determined that complete examination coverage of the subject welds is restricted by physical obstructions, including control rod drives, in-core instrumentation, the vessel support skirt, and the geometric configuration of the lower head. These conditions make 100 percent i

volumetric examination of the total weld length impractical for the subject welds. To gain additional access for examination of the subject welds, the RPV would require design i

i modifications. Imposition of this requirement would impose a significant burden on the licensee without a compensating increase in quality and safety.

The staff concluded that the volumetric examination of the accessible portion of one weld and the VT-2 visual examinations performed in conjunction with pressure testing each refueling outage provide reasonable assurance of the structuralintegrity of the subject welds. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).

Reauest for Relief B ASME Code,Section XI, Examination Category B-A, item B1.22 requires a 100 percent volumetric examination of the accessible length of one RPV meridional weld, as defined by Figure IWB-2500-3.

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. Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from 100 percent volumetric examination coverage for the following welds: VV-BH-1 A, VV-BH-18, VV BH-1C, VV-BH-1D, W-BH-1 E, W-BH-1 F, VV-BH-1G, VV-BH-1 H, VV-BH-2A, VV-BH-2B, VV-BH-2C, VV-BH-2D, W-BH-2E and VV-BH-2F.

The staff determined that complete examination coverage of the subject welds is restricted by physical obstructions including control rod drives, in-core instrumentation, and permanent insulation. These conditions make 100 percent volumetric examination of the total weld length impractical for the subject welds. Gaining additional access for examination of the subject welds would require design modifications for the RPV. Imposition of this requirement would pose a significant burden on the licensee without a compensating increase in quality and safety.

The licensee has examined a total of 70 inches of the two welds. The length of the longest bottom head meridional weld is 69 inches. Therefore, the cumulative volumetric examination coverage exceeded the coverage requirements for one weld and the volume examined, and the VT-2 visual examinations performed in conjunction with the pressure testing each refueling outage, provides reasonable assurance of the structuralintegrity of the subject weld, Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).

Recuest for Relief C ASME Code,Section XI, Examination Category B-D, item B3.90 requires a 100 percent volumetric examination of RPV nozzle-to-vessel welds as defined by Figure IWB-2500-7(a) through (d). The examination volume includes 100% of the weld length.

Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code examination requirements for the reactor pressure vessel nozzle-to-vessel welds listed in INEEL's TLR.

The licensee has proposed the following as an alternative examination:

1. No adoitional volumetric examinations will be performed. The RPV nozzle welds have been examined to the maximum extent practical from the outside surface.

2. A visual inspection (VT-2) is performed in conjunction with the pressure testing conducted on these components every refuel outage (with no leakage detected) in accordance with IWA-5000 and IWB-5000, which provides reasonable assurance of component integrity.

The staff determined that complete examination was not possible due to restricted access caused by interference from permanent structures such as vessel insulation, instrumentation lines / penetrations, and other nozzles and that the volumetric examinations, to the extent required by the Code, arc impractical. To meet the Code requirements, the nozzle-to-vessel welds would require design modification. Imposition of this requirement would create a considerable burden on the licensee without a compensating increase in quality and safety.

The licensee has completed a significant portion (50-70%) of the Code-required volumetric examinations on all but two of the nozzles. For these two nozz!es,35-50% of the required volume was examined. The staff concludes that the volumetric coverage obtained for each nozzle and the VT-2 visual examinations performed in conjunction with the pressure testing

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each refueling outage provide reasonable assurance of the structuralintegrity of the subject nozzle-to-vessel welds. Therefore, relief is grant ( J pursuant to 10 CFR 50.55a(g)(6)(i).

Reauest for Relief D ASME Code,Section XI, Examination Category B-F, item B5.130 requires 100 percent volumetric and surface examination of dissimilar metal butt welds 24-inches nominal pipe size as defined by Figure IWB-2500-8.

Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the full Code-required volumetric examinatiun for the pressure-retaining dissimilar metal welds listed in INEEL's TLR.

The licensee proposed the following alternative c.3mination:

1. No additional volumetric examinations will bs performed on these welds. The components listed in this relief request have been examined to the maximum extent practical.

2. A visual inspection (VT-2) is performed in conjunction with i' p, sure testing conducted on these components every refuel outage (with no. w. age detected) in accordance with IWA-5000 and IWB-5000, which provides reasonable assurance of component integrity.

The staff determined that complete volumetric examination is impractical due to dramatic thickness transitions on the outside and inside surfaces of the components. To meet the Code requirements for volumetric examination, the subject welds would require design modification.

Imposition of this requirement would create a considerable burden on the licensee with a compensating quality and safety.

The licensee has completed a significant portion (65-80%) of the Code-required volumetric examinations on three of the subject welds. The four additional welds received 25-35% of the Code-required volumetric examinations. The staff concludes that the volumetric exami. ations

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of the subject welds, the Code-required surface examinations, and the VT-2 visual J

examinations performed in conjunction with pressure testing each refueling outage provide reasonable assurance of the structuralintegrity of the subject welds. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).

Recuest for Relief E ASME Code,Section XI, Examination Category B-G-1, item B6.40 requires 100 percent volumetric examination of the threads in the reactor pressure vessel flange as defined by Figure IWB-2500-12.

Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed to examine the threads in the RPV flange for 22 stud holes for the second 10-year interval during the third 10-year interval, first period, first refuel outage (RO13).

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. The licensee noted:

1. The licensee is requesting relief from the twenty-two (22) RPV thrJads in flange examinations for the 2"d 10-year interval and is committing to examine these during the 3'd Interval,1" period, fiist refuel outage (RO13). The twenty-two RPV threads in flango examinations committed to based on this relief will be performed in addition to the 3'8 ten-year ISI requ rements.

2. A visual inspection (VT-2) is performed in conjunction with the pressure testing conducted on these components every refuel outage (with no leakage detected) in accordance with lWA-5000 and IWB 5000, which provides reasonable assurance of component integrity.

The staff determined that, due to an administrative oversight and a Code interpretation discrepancy, the licensee did not perform the required examinations on twenty-two of the fifty-two flange threads.

The licensee's second 10-year interval ended September 30,1997, so it is not possible for the licensee to meet the second 10-year interval requirements. The licensee examined the threads in a significant number of the stud holes (58%) and has identified no degradation mechanisms or had any failures associated with the threads in the flange. Additionally, the licensee has committed to examine the threads in the 22 remaining stud holes during the first refueling outage (RO13) in the first period of the third 10-year interval in lieu of taking the Unit off line and removing the RPV head for the sole purpose of examining the subject RPV threads.

The staff concludes that the examinations performed and the licensee's commitment to perform the remaining examinations during the next (RO13) refueling outage provide reasonable assurance of the structuralintegrity of the components. Requiring the licensee to take the Unit off line for the sole purpose of performing the subject examinations would pose a significant hardship on the licensee without a compensating increase in safety. Therefore, the licensee's proposed attemative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

Recuest for Relief F ASME Code,Section XI, Examination Category B-G-1, item BS.190, Pressure Retaining Bolting, Greater Than 2 inches in Diameter. This request for relief was withdrawn by the licensee in letter dated June 21,1999.

Reouest for Relief G ASME Code,Section XI, Examination Category B-H, item B8.10 requires that a volumetric or surface examination, as applicable, be performed on integrally welded attachments on reactor vessels each interval as defined by Figures IWB-2500-13,14, and 15.

l Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code-required examinations on the integral attachments listed in INEEL's TLR.

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. Th9 licensee proposed the following as an alternative examination:

1. No additional volumetric and/or surface examinations will be performed on these welds.

The components listed in this relief request have been examined to the maximum extent practical.

2. A visual inspection (VT-2) is performed in conjunction with the pressure testing conducted on these components every refuel outage (with no leakage detected) in accordance with IWA-5000 and IWB-5000, which provides reasonable assurance of component integrity."

The staff determined that complete Code examinations were impractical due to the design configuration, which restricted access to the components. To meet the Code's examination requiremente, the subject welds would require design modification, imposition of this requirement would create a considerable burden on the licensee without a compensating increase in quality and safety.

The licensee has completed 34-50% of the Code-required examinations on the subject welds.

Supplemental VT-1 visual examinations were performed on each of the subject welds to further enhance the examinations. The staff concludes that the examination covernges obtained for the subject welds, the supplemental VT-1 visual examinations, and the VT-2 visual examinations performed in conjunction with the pressure testing each refueling outage provide reasonable assurance of the structuralintegrity of the subject welds. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).

Reauest for Relief H ASME Code,Section XI, Examination Category B-J, item B9.11," Pressure Retaining Welds In Piping " This request for relief was withdrawn by the licensee by letter dated June 21,1999.

Reuuest for Relief I ASME Code,Section XI, Examination Category B-J, items 89.30 and B9.31," Pressure Retaining Welds In Piping." This request for relief was withdrawn by the licensee by letter dated June 21,1999.

Reauest for ReFef J ASME Code, Section Xi, Examination Category B-K-1, item B10.10," Integral Attachments For Piping, Pumps, and Valves." This request for relief was withdrawn by the licensee by letter dated June 21,1999.

l Recuest for Relief K l

ASME Code,Section XI, Examination Category B-K-1, item B10.10, " Integral Attachments or Piping, Pumps, and Valves." This request for relief was withdrawn by the licensee by letter dated June 21,1999.

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. Reauest for Relief L ASME Code,Section XI, Examination Category B-L-2, item B12.20, requires a VT-3 visual examination of the internal surfaces of at least one pump in each group of pumps performing similar functions in the system. This examination may be performed on the same pump selected for volumetric examination of welds. The examination may be performed at or near the end of the 10 year interval.

Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed to meet the requirements for examination as defined in the evaluation of the second 10-year interval request for relief (R58) found in a safety evaluation (SE) dated October 27,1987.

Examination Category B-L-2, item B12.20, requires a VT-3 visual exer.mation of the internal surfaces of at least one pump in each group of pumps performing similar functions in the system. This examination may be performed on the same pump selected for volumetric examination of welds. The examination may be performed at or near the end of the 10-year interval.

The licensee submitted Request for Relief R5B earlier in the second 10-year interval. It was evaluated in NRC SE dated October 27,1987, which determined that disassembly of the pumps solely for the purpose of inspection is a major effort. The possibility of additional wear or damage to the internal surfaces of the pumps and excessive radiation exposure to plant personnel that could result if the Code requirements were imposed present unusual difficulties without a compensating increase in the level of quality and safety. Therefore, it was concluded that (1) the licensee's proposal to visually examine (VT-3) the internal surfaces of the recirculation pumps whenever they were made accessible due to pump disassembly for maintenance purposes was acceptable, and (2) relief should not be granted outright until the specific components for which relief was requested were identified. The licensee's purpose in the present request for relief is to identify the specific components that were not examined, thereby satisfying the second portion of the original evaluation.

Later editions of the Code approved in the Code of Federal Regulations (1989), require l

examination only when the pump or valve is disassembled. Therefore, based on the evaluation l

performed eadier in the interval on Request for Relief R58, the licensee's identification of the specific components not examined, and the requirements in later editions of the Code, the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

l Reapest for Relief M ASME Code,Section XI, Examination Category B-M-2, item B12.50 requires a VT-3 visual j

examination of the intemal surfaces of valve bodies. The examinations are limited to one valve within each group of valves that are of the same constructional design (e.g. globe, gate, or check), and manufacturing method, and that perform similar functions in the system. The examination may be performed on the same valve selected for volumetric examination. The examination may be performed at or near the end of the interval.

Pursuant to 10 Cn 50.55a(a)(3)(ii), the licensee proposed to meet the requirements for examination as detmed in the eva!uation of the second 10-year interval Request for Relief R5C found in NRC SE dated October 27,1987. The valves are listed in INEEL's TLR.

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The licensee submitted Request for Relief RSC earlier in the second 10-year interval and was I

evaluated in NRC SE dated Ouober 27,1987, which concluded thai (1) the licensee's proposal, to visually examine (VT-1/VT 3) the internal surfaces of the valve bodies whenever they are made accessible by valve disassembly for maintenance, was acceptable, and (2) relief should not be granted outright until the specific comp;nents for which relief is requestM were identified.

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The licensee in this current request for relief identified the specific components that were not examined, thereby satisfying the second conclusion of the previous evaluation. The 1989 Edition of the Code approved in the Code of Federal Regulations requires examinations only when pumps or valves are disassembled. The staff determined that the Code requirements are a hardship without a compensating increase in quality and safety. In addition, the evaluation contained in NRC SE dated October 27,1987, on Request for Relief RSC, the licensee's identification of the specific components not examined, and the requirements in later editions cf the Code provides reasonable assurance of structuralintegrity of the subject valves. The licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

Recuest for Relief N J

ASME Code,Section XI, Examination Category B-O, item B14.10, " Pressure Retaining Welds in Control Rod Housings." This request for relief was withdrawn by the licensee by letter dated June 21,1999.

Reauest for Relief O ASME Code,Section XI, Examination Category C-A, item C1.10 requires 100 percent volumetric examination of pressure vessel shell circumferential welds as defined by Figure IWC-2500-1. In the case of multiple vessels of similar design, size, and service, the required examinations may be limited to one vessel or distributed among the vessels.

Pursuant to 10 CFR 50.55a, the iicensee requested relief from the Code-required volumetric examination of the following RHR heat exchanger circumferential weld C3-B.

The licensee proposed the following alternative:

1. No additional volumetric examinations will be performed on these welds. The component listed in this relief request has been examined to the maximum extent practical.

2. A visual inspection (VT-2) was performed during the pressure testing which is conducted on this component every refuel outage (no leakage detected) in accordance with IWA-5000 and IWC-5000, which provides reasonable assurance of component integrity."

t The staff determined that complete examination coverage is not possible due to restricted access caused by interference from the flange bolting and Nozzle N48. Therefore, the Code's examination requirements are impractical for this weld. To meet the Code requirements, flange bolting must be removed and the design of the heat exchanger nozzle modified to allow i

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additional access to the weld. Imposition of the Code requirement would result in a considerable burden on the licensee.

The licensee's examination of Weld C3-B to the extent practical by completing 70-80% of the Code-required examination pro / ides reasonable assurance of the structuralintegrity of the

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subject pressure-retaining circumferential shell weld. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).

Reauest for Relief P ASME Code,Section XI, Examination Category C-A, item C1.30 requires 100 percent volumetric examination of pressure vessel tubesheet-to-shell welds as defined by Figure IWC-2500-2. In the case of multiple vessels of similar design, size, and service, the required examinations may be limited to one vessel or distributed among the vessels.

Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed the following for the subject welds :

1. No additional volumetric examinations will be performed on these welds. The components listed in this relief request have been examined to the maximum extent practical.

2. A visual inspection (VT-2) was performed during the pressure test which is conducted on this component every refuel outage (no leakage detected) in accordance with IWA-5000 and IWC-5000.

The licensee submitted a similar request for relief (R15) early in the second 10-year interval that was evaluated in NRC SE dated October 27,1987. Due to ALARA considerations (250 mrem /hr to 1 rem /hr) in the work area, the licensee proposed to examine the subject tubesheet-to-shell welds only if the heat exchanger channel head cover was disassembled for maintenance. The October 27,1987, SE accepted the proposed alternative but postponed the decision to grant authorization until the end of the interval because the request for relief would not be required if disassembly of the heat exchangers occurred for some unplanned reason.

The licensee resubmitted the request for relief for the closeout of the interval and verified that the channel head covers of the heat exchangers have not been disassembled during the interval. Therefore, the licensee's original proposed alternative, found acceptable by the SE dated October 27,1987, remains valid. The staff determined that, based on the October 27, 1987, NRC SE of the original request for relief and verification that disassembly of the channel head covers of the RHR heat exchangers has not occurred, the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

Reauest for Relief O ASME Code,Section XI, Examination Category C-A, item C1.20 requires 100 percent volumetric examination of pressure vessel head circumferential welds as defined by Figure IWC-2500-1. In the case of multiple vessels of similar design, size, and service, the required examinations may be limited to one vessel or distributed among the vessels.

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E 10-3 Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code's examination I

requirements for the scram tank head welds TH1-B and BH1-B.

The licensee has proposed the following alternative examination:

1. ' No additional volumetric examinations will be performed on these welds. The components listed in this relief request have been examined to the maximum extent practical.

L2. A visual inspection (VT-2) was performed during the pressure test which is conducted.

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on this componer)t every refuel outage (no leakage detected) in accordance with IWA-5000 and IWC-5000.

The staff determined that complete' examination coverage is not possible because permanent structures, such as four support legs and socket welded nozzles, restr'ct access to the welds.

, Therefore, volumetric examination of the subject welds to the extent required by the Code is impractical. To meet the Code requirements, the rcram tank would require design modification to allow acc(ss to the subject welds. Imposition of this requirement would create a considerable burden on the licensee without a compensating increase in quality and safety.

The licensee has completed a significant portion (80-85%) of the Code-required volumetric examination of the top head weld, and 60-75% of the bottom head weld. The staff determined

' that the volume examined for each weld, and the VT-2 visual examinations performed in conjunction with pressure testing each refueling outage, provides reasonable structuralintegrity of the scram tank head welds. Relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).

Reauest for Relief R A' SME Code,Section XI, Examination Category C-B, item C2.21 requires 100 percent surface and volumetric examination of nozzle-to-shell(or head) welds in Class 2 vessels. In the casa of multiple vessels of similar design, size, and service, the required examinations may be limited to one vessel or distributed among the vessels.

Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code-required volumetric examination of the following welds N3A, N4A, and N4B.

'.ne licensee has proposed the following alternative examination:

1. No additional volumetric or surface examinations will be performed on these welds. The components listed in this relief request have been examined to the maximum extent practical.

2. A visual inspection (VT-2) was performed during the pressure test which is conducted on this component every refuel outage (no leakage detected) in accordance with IWA-L 5000 and IWC-5000.

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The staff determined that volumetric examination of Welds N3A, N4A, and N4B is limited by the I

nozzle design configuration and by the vessel flange and associated bolting. Therefore, the Code's_ examination requirements are impractical for these welds. Imposition of the Code

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o requirements would necessitate design modifications of the RHR heat exchangers to allow access to the subject welds, resulting in a considerable burden on the licensee without a compensating increase in quality and safety.

The licensee has examined the subject welds to the extent practical, examining 10 percent of the Code-required volume for Weld N3A and 40-50% for Welds N4A and N4B. Additionally, tne Code-required 100 percent surface examination was performed on each nozzle weld. The staff determined that the volume examined and the Code-required surface examination performed provides reasonable assutance of the structuralintegrity of the pressure-retaining nozzle welds.

Relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).

Reauest for Relief C ASME Code, Secticn XI, Examination Category C-C, Item C3.10 requires 100 percent surface examination of integrally welded attachments on pressure vessels as defined by Figure IWC-2500-5. Examinations are limitod to attachment welds of components examined under Examination Categories C-F and C-G.

Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed to supplement the surface examinations that could not be completed with a VT-1 visual examination. The following integral attachments are covered by this request. SUP-1 A, SUP-2A, SUP-3A, and SUP-4A.

These integral attachments are welded lugs that are part of the support structure stabilizing the upper portion of the RHR Heat Exchanger. Structural angle members that extend beyond the bottom of the lugs limit access to the subject areas. The limitation restricts access for magnetic particle examination and for surface preparation equipment needed for liquid penetrant testing.

To examine the surface as required, structural members must be removed and reinstalled, which would expose plant personnel to increased levels of radiation. Imposition of this requirement would result in an undue hardship on the licensee without a compensating increase in quality and safety.

The licensee has proposed to supplement the surface examinations (70-83% coverages obtained) with a VT-1 visual examination of the attachment welds. This alternative visual examination, in conjunction with the surface examinations, provides reasonable assurance of structural integrity of the RHR heat exchanger integral attachment welds. Therefore, the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

Reauest for Relief T ASME Code,Section XI, Examination Category C-C, item C3.20 requires 100 percent surface examination of integrally welded attachments on piping as defined by Figure IWC-2500-5.

Examinations are limited to attachment welds of components examined under Examination Categories C-F and C-G.

Pursuant to 10 CFR S0.55a(g)(5)(iii), the licensee requested relief from the Code-required surface examinations on the following welds: 12-10-697A,8-10-862B,20-10-889, and 12 750A.

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... The staff determined that complete examinations were impractical, because access is restricted by structures such as concrete walls, whip restraints, and pipe supports, as well as by the design configuration of the attachments. To meet the Code requirements, the integral attachments and/or interfering structures would require design modification and/or removal to allow access to the subject welds. Therefore, surface examination of the subject integral attachment welds, to the extent required by the Code, is impractical. To meet the Code requirements, the affected systems would require design modification to allow access to the subject welds. Imposition of this requirement would create a considerable burden on the licensee without a compensating increase in safety.

The staff determined that the licensee's completed significant portion (50-90%) of the Code-required surface examinations of the subject components provides reasonable assurance of the structural integrity of the subject nozzle-to-vessel welds. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).

Reauest for Relief U ASME Code,Section XI, Examination Category C-F, item C2.1, Pressure Retaining Welds in Piping, Pumps, and Valves in Systems Which Circulate Reactor Coolant.

This request for relief was withdrawn by the licensee in its letter dated June 21,1999.

Reauest for Relief V ASME Code,Section XI, Examination Category C-G, item C2.3, Pressure Retaining Welds in

. Pipir g, Pumps, and Valves in Systems Which Circulate Other Than Reactor Coolant. This request for relief was withdrawn by the licensee in its letter dated June 21,1999.

Reauest fof Relief W ASME Code,Section XI, Examination Categories C-H, D-A, D-B, and D-C, Periodic Pressure Tests. This request for relief was withdrawn by the licensee in its letter dated June 21,1999.

3.0 CONCLUSION

The staff concludes that, for relief requests E, L, 'M, P and S, compliance with the Code requirements would result in a hardship without a compensating increase in the level of quality and safety and that the licensee's proposed alternatives provide reasonable assurance of structuralintegrity of the subject components. Therefore, the licensee's proposed alternatives are authorized for the second 10-year interval pursuant to 10 CFR 50.55a(a)(3)(ii).

For relief requests A through D, G, O, Q, R, and T, the staff concludes that the Code requirements are impractical and that the licensee's proposed alternatives provide reasonable assurance of structuralintegrity of the subject components. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).

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. Relief requests for F, H through K, N, U, V, and W, were withdrawn by the licensee by letter dated June 21,1999.

Principal Contributor: T. McLellan Date:

July 28, 1999

Attachment:

Technical Letter Report -

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TECHNICAL LETTER REPORT ON SECOND 10-YEAR INTERVAL INSERVICE INSPECTION CLOSEOUT REQUESTS FOR RELIEF l

FOR I

NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NUMBER: 50-333 1.

INTRODUCTION The licensee, New York Power Authority, submitted multiple requests for relief by a letter dated July 15,1997; a revised request for relief by a letter dated May 19,1998; and a response to an NRC request for additional information by a letter dated June 21,1999.

The requests are seeking relief from the requirements of the ASME Code,Section XI, for the James A. FitzPatrick Nuclear Power Plant. These relief requests are for the closeout of the second 10-year inservice inspection (ISI) interval. The Idaho National Engineering and Environmental Laboratory (INEEL) staff's evaluation of the subject requests for relief i

is in the following section.

2.

EVALUATION The information provided by New York Power Authority in support of the requests for relief from Code requirements has been evaluated and the bases for disposition are i

documented below. The Code of record for the James A. FitzPatrick Nuclear Power Plant, second 10-year ISI interval, which ended September 30,1997, is the 1980 Edition i

through Winter 1981 Addenda of Section XI of the ASME Boiler and Pressure Vessel 1

Code.

A.

R_e._cLuest for Relief A' Examination Cateaory B-A. Item B1.21. Pressure Retainina Circumferential Head Welds in the Reactor Pressure Vessel (RPV)

Code Reauirement: Examination Category B-A, item B1.21 requires a 100% voiu:netric examination of the accessible length of one RPV circumferential head weld, as defined i

by Figure IWB-2500-3.

Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from 100% volumetric examination coverage for the welds listed below.

I WELD ITEM DESCRIPTION COVERAG LIMITATION VC-BH-1-2 81.21 RPV Bottom Head 117" Limited access, CRDs, in-Circumferential Weld core instrumentntion Relief Request Numbers were not assigned by licensee. Therefore, for simplicity of reference, letters were assigned by INEEL Staff.

Attachment

a 2

VC-BH-2-3 B1.21 RPV Bottom Head 0%

Limited access, CRDs, Circumferential Weld In-core instrumentation Licensee's Basis for Reauestina Relief (as stated):

" Inspections of the Code-required accessible length of one weld was conducted on the RPV Bottom Head Circumferential Welds with limitations based on restricted access. Access to the area is limited to four 18" diameter manways 90* apart in the vessel support skirt. In addition, the one hundred and thirty-seven (137) control rod drives and forty-three (43) in-core monitor instrumentation penetrations presen' extensive interference. The positioning and spacing of these components prevent an inspector from physically being able to reach them and allows access to a very limited portion the welds. There is also interference from the vessel support skirt which is welded to the bottom head on the lower portion of weld VC-BH-1-2. This combined with the curvature of the bottom head and the Bio-shield wall narrowing in this area precludes access. Permanent vesselinsulation and limited storage space for those insulation panels which require removal is extremely limited because of the small size of the manways."

Licensee's Proposed Altemative Examination (as stated):

"1.

No additional volumetric examinations will be performed. The RPV welds have been examined to the maximum extent practical from the outside surface.

"2.

A visual examination (VT-2) is performed in conjunction with the pressure testing conducted on these components every refuel outage (with no evidence of leakage detected) in accordance with IWA-5000 and IWB-5000, which provides reasonable assurance of component integrity.

"RPV Pressure Retaining Welds addressed by this Relief Request are listed in 2

Table 1. Drawings highlighting component design, configuration of interferences, and limitations associated with the examinations are included in Enclosure 1."

Evaluation: The Code requires 100% volumetric examination of the accessible length of one RPV circumferential head weld. Completa examination coverage of the subject welds is restricted by physical obstructions, including control rod drives, in-core instrumentation, the vessel support skirt, and the geometric configuration of the lower head. These conditions make 100% volumetric examination of the total weld length impractical for the subject welds. To gain additional access for examination of the subject welds, the RPV would require design modifications. Imposition of this requirement would impose a significant burden on the licensee.

Tables. Figures and attachments furnished with the licensee's submittal are not included in this report.

T 3

Based upon the volumetric examination of the accessible portion of one weld, and the VT-2 visual examinations performed in conjunction with pressure testing each refueling outage, it is reasonable to conclude that patterns of degradation, if present, would have been detected and reasonable assurance of the structuralintegrity of the subject welds has been provided. Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

B.

Reauest for Relief B. Examination Cateoorv B-A. Item B1.22. Pressure Retainina Meridional Welds in th0 Reactor Pressure Vessel (RPV)

Code Reouirement: Examination Category B-A, item B1.22 requires a 100% volumetric examination of the accessible length of one RPV meridional weld, as defined by Figure IWB-2500-3.

Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from 100% volumetric examination coverage for the welds listed below.

WELD ITEM DESCRIPTION COVERAG LIMITATION E

W-BH-1 A B1.22 RPV Bottom Head Meridional 36" of 69" Restricted Access Weld W-BH-1 B B1.22 RPV Bottom Head Meridional 34" of 69" Restricted Access W eld i

W-BH-1C B1.22 RPV Bottom Head Meridional 0" of 69" Restricted Access i

l Weld i

l W-BH-1 D B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access j

Weld j

l W-BH-1E B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access I

Weld l

W-BH-1 F B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access W eld W-BH-1 G B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access Weld W-BH-1 H B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access Weld W-BH-2A B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access Weld W-BH-28 B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access W eld I

(

W-BH-2C B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access W eld

4 W-BH-2D B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access Weld W-BH-2E B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access Weld W-BH-2F B1.22 RPV Bottom Head Meridional 0" of 54" Restricted Access Weld I.icensee's Basis for Reauestino Relief (as stated):

" Inspection of the Code-required accessible length of one weld (Note 1) has been achieved and fully satisfies the extent of examination in accordance with ASME Section XI,1980 Edition up to and including Winter Addenda 1981. Components addressed by this Relief Request are in compliance with Relief Request (R14) and listed in Table 1 A."

Licensee's Proposed Altemative Examination:

None given.

Evaluatio_n: The Code requires 100% volumetric examination of the accessible length of one RPV meridional weld. Based upon a review of the drawings submitted by the licensee, it appears that complete examination coverage of the subject welds (relief required for one weld only) is restricted by physical obstructions including control rod drives, in-core instrumentation, and permanent insulation. These conditions make 100%

volumetric examination of the total weld length impractical for the suoject welds. Gaining additional access for examination of the subject welds would require design modifications for the RPV. Imposition of this requirement would pose a significant burden on the licensee.

The licensee has examined a total of 70 inches of the two welds. The length of the longest bottrn head merid;onal weld is 69 inches. Therefore, the cumulative volumetric examination coverage exceeded the coverage requirements for one weld and will provide reasonable assurance of operational readiness.

Based upon the volume examined, and the VT-2 visual examinations performed in conjunction with the pressure testing each refueling outage, it is reasonable to conclude that pattems of degradation, if present, would have been detected and reasonable assurance of the structuralintegrity of the subject welds has been provided. Therefore, i

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

l l

C.

Reauest for Relief C. Examination Cateoory B-D. Item B3.90. Full Penetration RPV Nozzle-to-Vessel Welds Code Reauirement: Examination Category B-D, item B3.90 requires a 100% volumetric examination of reactor pressure vessel (RPV) nozzle-to-vessel welds as defined by

0 f

i Figure IWB-2500-7(a) through (d). The examination volums includes 100% of the weld I

length.

Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code examination requirements for the reactor pressure vessel nozzle-to-vessel welds listed below.

COMPONEN ITEM DESCRIPTION COVERAGE LIMITATION T

N-1 A B3.90 RPV Recirc. Noz.

35-50 %

Configuration, insulation N-1 B B3.90 RPV Recirc. Noz.

50-65%

Configuration, insulation N-2A B3.90 RPV Recirc. Noz.

50-65 %

Conf!;,uration, insulation N-28 B3.90 RPV Recirc. Noz.

50-65%

Configuration, Insulation N-2C B3.90 RPV Recirc. Noz.

50-65 %

Configuration, insulation N-2D B3.90 RPV Recirc. Noz.

50-65%

Configuration, insulation N-2E B3.90 RPV Recirc. Noz.

50-65%

Configuration, insulation N-2F B3.90 RPV Recire. Noz.

50-65%

Configuration, insulation N-2G B3.90 RPV Recirc. Noz.

50-65 %

Configuration, insulation N-2H B3.90 RPV Recire. Noz.

50-65%

Configuration, insulation N-21 B3.90 RPV Recirc. Noz.

50-65%

Configuration, insulation N-2J B3.90 RPV Recire. Noz.

50-65 %

Configuration, insulation N-2K B3.90 RPV Recirc. Noz.

50-65%

Configuration, insulation N-3A B3.90 MS Noz.

50-60%

Configuration N-3B B3.90 MS Noz.

50-60%

Configuration N-3C B3.90 MS Noz.

50-60 %

Configuration N-3D B3.90 MS Noz.

50-60%

Configuration N-4A B3.90 RPV FW Noz.

60-70%

Configuration, insulation N-4B B3.90 RPV FW Noz.

60-70%

Configuration, insulation N-4C B3.90 RPV FW Noz.

60-70 %

Configuration, insulation N-4D B3.90 RPV FW Noz.

60-70 %

Configuration, insulation N-5A B3.90 RPV CS Noz.

70%

Configuration, insulation N-8A B3.90 JPlNoz.

60-70 %

Configuration, insulation N-8B B3.90 JPlNoz.

60-70%

Configuration, Insulation

o e

6 COMPONEN ITEM DESCRIPTION COVERAGE LIMITATION T

N-5B B3.90 RPV CS Noz.

70 %

Configuration, insulation VN-TH-A B3.90 RPV Head Noz.

60-70 %

Configuration VN-TH-B B3.90 RPV Head Noz.

60-70 %

Configuration VN-TH-C B3.90 RPV Head Noz.

60-70%

Configuration N-9 B3.90 RPV CRD Noz.

Est.* 60-70%

Configuration, insulation Exannnation data lacks sufficient surface measures to further quantifv the volume examined.

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

" Complete inspection of the Code-required volume is not possible based on restricted access caused by interference from permanent structures such as non-removable vessel insulation, instrumentation lines / penetrations and other nozzles, which is typical for a given configuration (i.e.: N1(s), N2(s), N4(s), and N5(s)). The examination data detailing restricted access associated with the N-9 nozzle does not have the necessary detail to calculate the exact coverage achieved. In this case an estimate of examination coverage is used, based on the examination data sketch generated during the inspection."

Licensee's Proposed Alternative Examination (as stated):

"1.

No additional volumetric examinations will be performed. The RPV nozzle welds have been examined to the maximum extent practical from the outside surface.

"2.

A visual inspection (VT-2) is performed in conjunction with the pressure testing conducted on these components every refuel outage (with no leakage detected) in accordance with IWA-5000 and IWB-5000, which provides reasonable assurance of component integrity."

Evaluation: The Code requires 100% volumetric examination of the subject nozzle-to-vessel welds. Complete examination was not possible due to restricted access caused by interference from permanent structures such as vessel insulation, instrumentation lines / penetrations, and other nozzles. Therefore, the volumetric examinat,ans, to the extent required by the Code, are impractical. To meet the Code requirements, the nozzle-to-vessel welds would require design modification. Imposit: ion of this requirement v.ould create a considerable burden on the licensee.

The licensee has completed a significant portion (50-70%) of the Code-required volumetric examinations on all but two of the noales. For these two nozzles,35-50% of the required volume was examined. Based upon '.he volumetric coverage obtained for each nozzle, and the VT-2 visual examinations pecformed in conjunction with the pressure testing each refueling outage, it is reasonable to conclude that pattems of

E' '

]

7 degradation, if present, would have been detected and reasonable assurance of the structuralintegrity of the subject nozzle-to-ves.iel welds has been provided. Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

D.

Reauest for Relief D. Examination Cateaory B-F. Item B5.130. Pressure Retainina Dissimilar Metal Welds Code Reauirement: Examination Category B-F, item B5.130 requires 100% volumetric and surface examination of dissimilar metal butt welds 24-inch nominal pipe size as defined by Figure IWB-2500-8.

Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the full Code-required volumetric examination for the pressure-retaining dissimilar metal welds listed below.

COMPONEN ITEM DESCRIPTION COVERAG LIMITATION T

E 24-10-142 B5.130 tee-to-valve (RHR) 25-35%

OD Surface Contour 24-10-143 B5.130 valve-to-valve (RHR) 25-35%

OD Surface Contour 24-10-144 B5.130 valve-to-elbow (RHR) 70-80 %

OD Surface Contour 24-10-130 B5.130 tee-to-valve (RHR) 25-35%

OD Surface Contour 24-10-131 B5.130 valve-to-valve (RHR) 25-35 %

OD Surface Contour 24 10-132 B5.130 valve-to-elbow (RHR) 70-80 %

OD Surface Contour i 10-14-481 B5.130 pipe-to-valve pup piece 65-75%

OD Surface Contour i

extension (Core Spray)

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

' Complete inspection of the Code-required volume is not possible based on restricted access due to the component's design. These welds represent the tie ;n of the RHR system to the Recirculation System on Loops A and B. The configuration of these welds are Valve-to-Valve, and Valve-to-Tee. The configuration of Welds 24-10-143,24-10-142,24-10-131, and 24-10-130 are not conducive to conventional ultrasonic examination techniques. This is attributed to dramatic thickness transitions on the outside and inside surfaces. On-going modifications to equipment and ultrasonic techniques currently being used are improving the testing parameters presently utilized to examine these components.

Inspections of these components are based on calibration mock-up blocks of the same configuration and materials as the welds. These calibration mock-up blocks l

are designed with side drilled (SDH), end drilled (EDH) calibration holes along with nunerous ID notches located within the heat effective zones, base material, buttered; material and the weld. Supplemental liquid penetrant examinations were performed on these components which exceeds those required by Code Category

B B-F, Table 2500-1. An evaluation of testing results utilizing current ultrasonic technology has deemed these exams as best effort. The inspections conducted on Welds 24-10-132,24-10-144 both (Elbow-to-Valve) and 10-14-481 are considered limited examinations employing industry acceptable inspecthn techniques. Weld 24-10-144 does not have a limited exam notation included on the inspection data but is clearly a one-sided exam and therefore is being submitted for relief."

Licensee's Proposed Altemative Examination (as stated):

l "1.

No additional volumetric examinations will be performed on these welds.

The components listed in this relief request have been examined to the maximum extent practical.

"2.

A visual inspection (VT-2) is performed in conjunction with the pressure testing conducted on these components every refuel outage (with no leakage detected) in accordance with IWA-5000 and IWB-5000, which provides reasonable assurance of component integrity. "

Evaluation: The Code requires 100% volumetric and surface examination of the subject welds. Review of the drawings and sketches provided by the licensee revealed that complete volumetric examination is impractical due to dramatic thickness transitions on the outside and inside surfaces of the components. To meet the Code requirements for volumetric examination, the subject welds would require design modification. Imposition of this requirement would create a considerable burden on the licensee.

The licensee has completed a significant portion (65-80%) of the Code-required volumetric examinations on three of the subject welds. The four additional welds received 25-35% of the Code-required volumetric examinations. Based upon the volumetric examinations of the subject welds, the Code-required surface examinations, and the VT-2 visual examinations performed in conjunction with pressure testing each refueling outage, it is reasonable to conclude thet pattems of degradation, if present, would have been detected. Consequently, reasonable assurance of the structural i

integrity of the subject welds has been provided. Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

E.

Reauest for Relief E. Examination Cateaorv B-G-1. Item B6.40. Pressure Retainino Boltina. Greater Than 2 inches in Diameter Code Reauirement: Examination Category B-G-1, item BS.40 requires 100% volumetric examination of the threads in the teactor pressure vessel flange as defined by Figure IWB-2500-12.

Licensee's Proposed Altemative: In accordance with 10 CFR 50.55a(a)(3)(ii), the licensee proposed to examine the threads in the RPV flange for 22 stud holes for the second 10-year interval during the third 10-year interval, first period, first refuel outage (RO13).

The licensee stated;

f 9

"1.

The Authority is requesting relief from the twenty-two (22) RPV Threads in Flange examinations for the 2* Ten-Year Interval and is committing to examine these during the 3* Interval,1" period, first refuel outage (RO13).

The twenty-two RPV Threads in Flange examinations committed to based l

on this relief will be performed in addition to the 3* Ten-Year ISI Inspections requirements.

"2.

A visual inspection (VT-2) is performed in conjunction with the pressure testing conducted on these components every refuel outage (with no leakage detected) in accordance with IWA-5000 and IWB-5000, which provides reasonable assurance of component integrity."

The following table shows the status of the Flange Thread exams.

COMPONENT ITEM DESCRIPTION COVERAG LIMITATION E

1 through 15 B6.40 Threads in Flange 100 %

None 16 through 37 B6.40 Threads in Flange 0%

None 38 through 52 B6.40 Threads in Flange 100 %

None Licensee's Basis for Proposed Altemative (as stated):

"During the closecut review of JAF's 2* Ten-Year Inservice Inspection Interval for Code Category B-G-1, Item No. B6.40, RPV Threads in Flange, a total of thirty (30) examinations were performed out of a total population of fifty-two (52). The inspection requirement to examine 100% of the RPV Threads in flange was not met in its entirety due to an administrative oversight and a Code interpretational discrepancy.

" Industry experience has not identified a degradation mechanism or failure associated with the RPV Threads in Flange. The Authority does not consider taking the unit off line and removing the RPV Head for the sole purpose of examining the twenty-two (22) RPV Threads in Flange as providing an increase in the level of quality and safety already achieved by the examinations performed."

]

1 Evaluation: Examination Category B-G-1, item B6.40 requires 100% volumetric examination of the threads in the reactor pressure vessel flange as defined by Figure IWB-2500-12. Due to an administrative oversight and a Code interpretation j

discrepancy, the licensee did not perform the required examinations on twenty-two of the fifty-two flange threads.

The licensee's second 10-year interval ended September 30,1997, so it is not possible for the licensee to meet the second 10-year interval requirements. The licensee examined the threads in a significant number of the stud holes (58%) and has identified no degradation mechanisms or had any failures associated with the threads in the

10 flange. Additionally, the licensee has committed to examine the threads in the 22 remaining stud holes during the first refueling outage (RO13) in the first period of the third 10-year interval in lieu of taking the unit off line and removing the RPV head for the i

sole purpose of examining the subject RPV threads. Considering the examinations that have been performed, and the licensee's commitment to perform the remaining examinations during the next (RO13) refueling outage, reasonable assurance of the structural integrity of the component will be provided. Requiring the licensee to take the unit off line for the sole purpose of performing the subject examinations would pose a significant hardship on the licensee without a compensating increase in safety.

Therefore, the INEEL staff recommends that the licensee's proposed attemative be authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

F.

Reauest for Relief F. Examination Cateaory B-G-1. Item B6.190. Pressure Retainino Boltina. Greater Than 2 inch in Diameter This request for relief was withdrawn by the licensee in letter dated June 21,1999.

G.

Reauest for Relief G. Examination Cateaory B-H. Item B8.10. RPV Intearally Welded Attachments Code Reauirement: Examination Category B-H, Item 88.10 requires that a volumetric or surface examination, as applicable, be performed on integrally welded attachments on reactor vessels each interval as defined by Figures IWB-2500-13,14, and 15.

Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code-required examinations on the following integral attachments.

COMPONEN ITEM DESCRIPTION COVERAG LIMITATION T

E VC-SKC B8.10 RPVIntegral Attachment 50 %

Configuration Stabilizer-1 B8.10 RPV Integral Attachment 34 %

Configuration Stabilizer-2 B8.10 RPV Integral Attachment 34 %

Configuration Stabilizer-3 B8.10 RPVintegral Attachment 34 %

Configuration Stabilizer-4 B8.10 RPVIntegral Attachment 34 %

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

l

" Complete inspection of the Code-required volume is not possible based on restricted access caused by design. Examination coverage of VC-SKC (vessel skirt weld) includes 100% of the OD surface being examined using the MT method and a supplemental examination using remote visual equipment (VT-1) was performed on 100% of the inside surface. Access to the inside surface.of weld VC-u

11 SKC is restricted due to the component's design. Drawings of vessel skirt weld VC-SKC are in Enclosure 6 which highlight the inspection surfaces and restricted access caused by design. Examination coverage of Stabilizer-1,2,3, and 4 included 35% of these welds being inspected by MT and the remaining 65% being inspected by VT-1. Components addressed by this Relief Request ara listed in Table 6. Drawings and sketches that illustrate the restricted conditions encountered that limit access to the Vessel Skirt Weld and Stabilizer Brackets are

{

included in Enclosure 6."

Licensee's Proposed Alternative Examination (as stated):

"1.

No additional volumetric and/or surface examinations will be performed on these welds. The components listed in this relief request have been examined to the maximum extent practical.

"2.

A visual inspection (VT-2) is performed in conjunction with the pressure testing conducted on these components every refuel outage (with no leakage detected) in accordance with IWA-5000 and IWB-5000, which provides reasonable assurance of component integrity."

Evaluation: The Code requires 100% volumetric or surface examination, as applicable, for the subject welds. Review of the drawings and sketches supplied by the licensee revealed that complete Code examination was impractical due to the design i

configuration, which restricted access to the components. To meet the Code's examination requirements, the subject welds would require design modification.

imposition of this requirement would create a considerable burden on the licensee.

The licensee has completed 34-50% of the Code-required examinations on the subject welds. Supplemental VT-1 visual examinations were performed on each of the subject welds to further enhance the examinations. Based upon the examination coverage obtained for the subject welds, the supplemental VT-1 visual examinations, and the VT-2 visual examinations performed in conjunction with the pressure testing each refueling outage, it is reasonable to conclude that pattems of degradation, if present, would have been detected. Consequently, reasonable assurance of the structuralintegrity of the subject welds has been provided. Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

H.

Reauest for Relief H. Examination Cateaory B-J. Item B9.11. Pressure Retainina Welds in Pioina This request for relief was withdrawn by the licensee in letter dated June 21,1999.

I

I 12 l

l.

Reauest for Relief I. Examination Cateaory B-J. Items B9.30 and B9.31. Pressure l

Retainina Welds in Pioina l

This request for relief was withdrawn by the licensee in letter dated June 21,1999.

l J.

Reauest for Relief J. Examination Cateaory B-K-1. Item B10.10. Intearal Attachments For Pipina. Pumos. and Valves This request for relief was withdrawn by the licensee in letter dated June 21,1999.

l K.

Reauest for Relief K. Examination Cateaory B-K-1. Item B10.10. Intearal Attachments For Pioina. Pumos. and Valves This request for relief was withdrawn by the licensee in letter dated June 21,1999.

L.

Reauest for Relief L. Examination Cateaory B-L-2. Item B12.20. Pumo Casina Intemal Surfaces Code Reauirement: Examination Category B-L-2, item B12.20, requires a VT-3 visual examination of the internal surfaces of at least one pump in each group of pumps performing similar functions in the system. This examination may be performed on the same pump selected for volumetric examination of welds. The examination may be performed at or near the end of the 10-year interval.

Licensee's Proposed Alternative: In accordance with 10 CFR 50.55a(a)(3)(ii), the licensee proposed to meet the requirements for examination as defined in the evaluation of the second 10-year interval request for relief (R58) found in a safety evaluation report (SER) dated October 27,1987.

The licensee stated:

"Tne requirements for examination on these components met the approved Relief Request (R5B) for the 2nd Ten-Year ISI inspection Interval in its entirety.

Components addressed in this request for relief are listed in Table 9."

l The following is a list of the pumps affected.

COMPONENT ITEM DESCRIPTION COVERAG LIMITATION E

02-2P-1A B12.20 Centrifugal Pump 0%

Not Disassembled 02-2P-1 B B12.20 Centrifugal Pump 0%

Not Disassembled Licensee's Basis for Proposed Altemative (as stated):

"This request for relief is being submitted in accordance with NRC Safety Evaluation (SE) of the 2nd Ten-Year Inservice Inspection Program, Dated October 27,1987, Docket No. 50-333 approved Relief Request 5 (R58). Relief Request 5

1 13 (R5B) requires visual (VT-3) inspection of intemal surfaces of pump casings once per interval when these components are disassembled for maintenance and stipulates th'at relief from examination of specific components not disassembled

{

will be submitted at the end of the interval.

"The recirculation pump intemal surfaces are only accessible when the pumps are disassembled. These pumps were not disassembled during the 2nd Ten Year l

Interval. A visual inspection (VT2), pressure test is conducted on these components every refuel outage in accordance with IWA-5000 and !WB-5000.

This request for relief is being submitted in accordance with JAPs 2n 1 Ten-year l

Interval Inservice inspection Program approved Relief Request 5 (R5B).

l Components addressed by this Relief Request are listed in Table 9."

Evaluation: Examination Category B-L-2, item B12.20, requires a VT-3 visual examination of the intemal surfaces of at least one pump in each group of pumps perf')rming similar functions in the system. This examination may be performed on the same pump selected for volumetric examination of welds. The examination may be l

performed at or near the end of the 10-year interval.

The licensee submitted Request for Relief R5B earlier in the second 10-year interval. It was evaluated in an SER dated October 27,1987, which determined that disassembly of the pumps solely for the purpose of inspection is a major effort. The possibility of additional wear or damage to the internal surfaces of the pumps and excessive radiation exposure to plant personnel that could result if the code requirements were imposed present unusual difficulties without a compensating increase in the level of quality and safety. Therefore, it was concluded that (1) the licensee's proposal to visually examine (VT-3) the intemal surfaces of the recirculation pumps whenever they were made accessible due to pump disassembly for maintenance purposes was acceptable, and (2) relief should not be granted outright until the specific components for which relief was requested were identified. The licensee's purpose in the present request for relief is to identify the specific components that were not examined, thereby satisfying the second portion of the original evaluation.

Later editions of the Code approved in the Code of Federal Regulations (1989), require examination only when the pump or valve is disassembled. Therefore, based on the evaluation performed earlier in the interval on Request for Relief R58, the licensee's identification of the specific components not examined, and the requirements in later editions of the Code, it is recommended that the licensee's proposed attemative be authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

l M.

Reauest for Relief M. Examination Cateaorv B-M-2. Item B12.50. Intemal Surfaces _of Valve Bodies i

Code Reauirement: Examination Category B-M-2, item B12.50 requires a VT-3 visual i

examination of the intemal surfaces of valve bodies. The examinations are limited to one valve within each group of valves that are of the same constructional design (e.g.

globe, gate, or check), and manufacturing method, and that perform similar functions in l

the system. The examination may be performed on the same valve selected for l

4 I

14 volumetric examination. The examination may be performed at or near the end of the interval.

Licensee's Proposed Altemative: In accordance with 10 CFR 50.55a(a)(3)(ii), the licensee proposed to meet the requirements for examination as defined in the evaluation of the second 10-year interval Request for Relief RSC found in an SER dated October 27,1987.The following valves are affected.

COMPONENT ITEM DESCRIPTION COVERAG LIMITATION E

02MOV-43A B12.50 Gate Valve 0%

Not Disassembled 02MOV-43B B12.50 Gate Valve 0%

Not Disassembled i

02MOV-53A B12.50 Gate Valve 0%

Not Disassembled 02MOV-538 B12.50 Gate Valve 0%

Not Disassembled 13MOV-21 B12.50 Gate Valve 0%

Not Disassembled 34FWS-29A B12.50 Gate Valve 0%

Not Disassembled 34FWS-29B B12.50 Gate Valve 0%

Not Disassembled Licensee's Basis for Proposed Alternative (as stated):

"This request for relief is being submitted in accordance with NRC Safety Evaluation 1

(SE) of the 2nd Ten-Year Inservice Inspection Program, Dated October 27,1987, Docket No. 50-333 approved Relief Request 5 (RSC). Relief Request 5 (R5C) requires visual

{

(VT-3) inspection of internal surfaces of valve bodies once per interval when these components are disassembled for maintenance and stipulates that a relief from examination of specific components not disassembled will be submitted at the end of the j

interval.

l "The valve internal surfaces are only accessible when the valves are disassembled.

l These valves were not disassembled during the 2nd Ten-Year Interval. A visual l

l inspection (VT-2), pressure test is conducted on these components every refuel outage in accordance with IWA-5000 and IWB-5000. This request for relief is being submitted in I

accordance with JAFs 2nd Ten-Year Interval, inservice Inspection Program approved Relief Request 5 (RSC). The Authority has elected to implement a conservative inspection criteria for valves. This inspection selection criteria is based not only on type of valve and function but also on which system requires a larger population, (i.e.: gates valves), and an increased frequency of inspection for those valves that are disassembled more than once per interval. This request is being submitted in accordance with the approved NRC Relief Request (RSC) for the 2nd Ten Year Interval.

Components addressed by this Relief Request are fisted in Table 10."

l Evaluation: Examination Category B-M-2, item B12.50 requires a VT-3 visual examination of the intemal surfaces of valve bodies. The examination is limited to one i

I

l 15 valve within each group of valves that are of the same constrtctiora:i,nign (e.g. globe,

{

gate, or check) and manufacturing method, and that perform simil3r 'uacuons in the system.

I The licensee submitted Request for Relief RSC eari!9r in ths acond 10-year interval. It was evaluated in an SER dated October 27,1987, which concluded that (1) the licensee's proposal, to visually examine (VT-1NT-3) the internal surfaces of the valve bodies whenever they are made accessible by valve disassembly for maintenance, was acceptable, and (2) relief should not be granted outright until the specific components for which relief is requested were identified. The licensee's purpose in the present request for relief is to identify the specific components that were not examined, thereby satisfying the second conclusion of the previous evaluation.

Later editions of the Code approved in the Code of Federal Regulations (1989) require examination only vvhen the pump or valve is disassembled. Therefore, based on the evaluation performed earlier in the interval on Request for Relief RSC, the licensee's identification of the specific components not examined, and the requirements in later i

editions of the Code, it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

N.

Reauest for Relief N. Examination Cateaory B-0. Item B14.10. Pressure Retainina Welds in Control Rod Housinas This request for relief was withdrawn by the licensee in letter dated June 21,1999.

O.

Reauest for Relief O. Examination Cateaory C-A. Item C1.10. Pressure Retainina Welds in Pressure Vessels Code Reauirement: Examination Category C-A, Item C1.10 requires 100% volumetric examination of pressure vessel shell circumferential welds as defined by Figure IWC-2500-1. In the case of multiple vessels of similar design, size, and service, the required examinations may be limited to one vessel or distributed among the vessels.

Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a, the licensee requested relief from the Code-required volumetric examination of the following RHR heat exchanger circumferential weld.

COMPONENT ITEM DESCRIPTION COVERAG LIMITATION E

C3-B C1.10 RHR Ht. Exch. B 70-80%

Flange Bolting / Nozzle 1

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

i

" Complete inspection of the Code-required volume is not possible based on restricted access caused by interference due to the close proximity of the vessel flange bolting and the N4B nozzle. Drawings and sketches which illustrate the l

l l

i

a e

16 restricted conditions encountered that limit examination coverage are included in 2."

Licensee's Proposed Altemative Examination (as stated):

"1.

No additional volumetric examinations will be performed on these welds. The component listed in this relief request has been examined to the maximum extent practical.

"2.

A visual inspection (VT-2) was performed during the pressure testing which is conducted on this component every refuel outage (no leakage detected) in accordance with IWA-5000 and IWC-5000, which provides reasonable assurance of component integrity."

Evaluation: The Code requires 100% volumetric examination of the subject circumferential shell weld. Drawings submitted by the licensee show that complete examination coverage is not possible due to restricted access caused by interference from the flange bolting and Nozzle N4B. Therefore, the Code's examination requirements are impractical for this wela. To meet the Code requirements, flange bolting must be removed and the design of the heat exchanger nozzle modified to allow additional access to the weld. Imposition of the Code requirement would result in a considerable burden on the licensee.

l The licensee examined Weld C3-B to the extent practical, completing 70-80% of the Code.-required examination. Consequently, any significant patterns of degradation would have been detected, and reasonable assurance of the structuralintegrity of this pressure-retaining circumferential shell weld has been provided.

Based on the impracticality of meeting the Code's examination requirements for the I

subject weld, and the reasonable assurance provided by the examination that was completed, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

P.

Reauest for Relief P. Examination Cateaory C-A. Item C1.30. RHR Tubesheet-to-Shell W eld Code Reauirement: Examination Category C-A, Item C1.30 requires 100% volumetric examination of pressure vessel tubesheet-to-shell welds as defined by Figure IWC-2500-2. In the case of multiple vessels of similar design, size, and service, the required examinations may be limited to one vessel or distributed among the vessels.

Licensee's Proposed Altemative: In accordance with 10 CFR 50.55a(a)(3)(ii), the licensee proposed the following for the subject welds (as stated):

"1.

No additional volumetric examinations will be performed on these welds. The components listed in this relief request have been examined to the maximum extent practical.

4

O 17 "2.

A visual inspection (VT-2) was performed during the pressure test which is conducted on this component every refuel outage (no leakage detected) in accordance with IWA-5000 and IWC-5000."

Licensee's Basis for Proposed Alternative (as stated):

" Relief from the Code-required volume was requested in the initial 2nd Ten-Year Inservice inspection Program submittal (Reference NRC Safety Evaluation, dated October 27,1987, Relief Request (R15). The NRC denied this application for relief based on the possibility of disassembly and inspection during the Interval. The RHR Heat Exchangers have not been disassembled during the 2nd Ten-Year Interval and, therefore, the Authority is re-submitting this request for relief from the Code-required extent of examination for the Tubesheet-to-Shell Welds which was a part of the original inservice inspection Program's 2nd Ten-Year submittal.

Evaluation: The Code requires 100% volumetric examination of pressure vessel tubesheet-to-shell welds. The licensee submitted a similar request for relief (R15) early in the second 10-year interval that was evaluated in an SER dated October 27,1987.

Due to ALARA considerations (250 mrem /hr to 1 rem /hr) in the work area, the licensee proposed to examine the subject tubesheet-to-shell welds only if the heat exchanger channel head cover was disassembled for maintenance. The October 27,1987, SER accepted the proposed alternative but postponed the decision to grant authorization until the end of the interval because the request for relief would not be required if disassembly of the heat exchangers occurred for some unplanned reason.

The licensee resubmitted the request for relief for the closecut of the interval and verified that the channel head covers of the heat exchangers have not been disassembled during the interval. Therefore, the licensee's original proposed alternative, found acceptable by the SER dated October 27,1987, should remain valid. Based on the October 27,1987, evaluation of the original request for relief and verification that disassembly of the channel head covers of the RHR heat exchangers has not occurred, it is recommended that the licensee's proposed altemative be authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

Q.

Reauest for Relief O. Examination Cateoorv C-A. Item C1.20. Pressure Retainino Circumferential Head Welds in Pressure Vessels Code Reauirement: Examination Category C-A, Item C1.20 requires 100% volumetric examination of pressure vessel head circumferential welds as defined by Figure IWC-2500-1. In the case of multiple vessels of similar design, size, and service, the required examinations may be limited to one vessel or distributed among the vessels.

Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code's examination requirements for the scram tank head welds listed below.

COMPONENT ITEM DESCRIPTION COVERAG LIMITATION t

E A

b-

0 1

l 18 s

TH1-B C1.20 Head Welds 80-85 %

4 Socket Weld Nozzles BH1-B C1.20 Head Welds 60-75 %

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

" Complete inspection of the Code-required volume is not possible based on welded appurtenances c.) the vessel which restrict accessibility. Drawings and sketches which illustrate the restricted conditions encountered that limit examination coverage are included in Enclosure 13."

Licensee's Proposed Altemative Examination (as stated):

"1.

No additional volumetric examinations will be performed on these welds. The components listed in this relief request have been examined to the maximum extent practical.

2.

A visual inspection (VT-2) was performed during the pressure test which is conducted on this component every refuel outage (no leakage detected) in accordance with IWA-5000 and IWC-5000."

Evaluation: The Code requires 100% volumetric examination of the subject head circumferential welds. Review of the drawing submitted by the licensee revealed that complete examination coverage is not possible because permanent structures, such as four support legs and socket welded nozzles, restrict access to the welds. Therefore, volumetric examination of the subject welds to the extent required by the Code is impractical. To meet the Code requirements, the scram tank would require design modification to allow access to the subject welds. Imposition of this requirement would create a considerable burden on the licensee.

The licensee has completed a significant portion (80-85%) of the Code-required volumetric examination of the top head weld, and 60-75% of the bottom head weld.

Based upon the volume examined for each weld, and the VT-2 visual examinations performed in conjunction with pressure testing each refueling outage, it is reasonable to conclude that pattems of degradation, if present, would have been detected. Therefore, reasonable assurance of the structuralintegrity of the scram tank head welds has been provided, and it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

R.

Reauest for Relief R. Examination Cateaory C-B. Item C2.21. Pressure Retainina Nozzle Welds in Vessels Code Recuirement: Examination Category C-B, item C2.21 requires 100% surface and volumetric examination of nozzle-to-shell (or head) welds in Class 2 vessels. In the case of multiple vessels of similar design, size, and service, the required examinations may be limited to one vessel or distributed among the vessels.

~

19 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.

COMPONENT ITEM DESCRIPTION COVERAG LIMITATION E

N3A C2.21 RHR Ht. Exch.

10%

One-sided Configuration N4A C2.21 RHR Ht. Exch.

40-50 %

One-sided Configuration N4B C2.21 RHR Ht. Exch.

40-50%

One-sided Configuration Licensee's Basis for Reauestina Relief (as stated):

" Complete volumetric inspection of the Code-required volume is not possible based on nozzle design and the proximity of the vessel flange and associated bolting. Inspection data performed on these compnents include sketches which illustrate the restricted conuitions encountered that limit the examination coverage.

Full examination coverage for the required surface examination was achieved.

Drawings and sketches which illustrate the restricted conditions encountered that limit examination coverage are included in Enclosure 14.

The licensee stated in their response to the NRC request for additional information i

that; l

"At Fitzpatack there are two RHR heat Exchangers A and B, which each has two (2) Class 2 nozzles (4 total) for this code Category. As shown on drawing MSK-3037, nozzles N-3A and B are located on the top head; and the other Class 2 nozzles are N-4A and B which are on the vessel shell in close proximity to the shell flange. As shown on drawing MSK-3037, Detail 'D', the configuration fit up for both welds only allows an effective ultrasonic examination for volume coverage to be performed from the shell side or head side. As an additional restriction, the N-4A and B nozzles, due to their close proximity to the flange and flange bolting, impeded examination coverage for approximately 20" along the bottom of the nozzle. In the case of the N4 nozzles both A and B were inspected to the extent practical during the 2* Ten-Year Interval. Enclosed (Enclosure 1) is a full size drawing of the RHR Heat Exchanger along with sketches of the nozzles generated during examinations, which illustrate the restrictive conditions encountered during their inspections. The nozzles are also inspected by the VT-2 method each period during the pressure test required by Code C-H. No leakage has been noted."

Licensee's Proposed Altemative Examination (as stated):

"1.

No additional volumetric or surface examinations will be performed on these welds. The components listed in this relief request have been examined to the maximum extent practical.

a e

20 "2.

A visual inspection (VT-2) was performed during the pressure test which is conducted on this component every refuel outage (no leakage detected) in accordance with IWA-5000 and IWC-5000."

Evalcation: The Code recuires 100% surface and volumetric examination of Class 2 pressure vessel nonle-to-shell welds. However, volumetric examination of Welds N3A, N4A, and N4B is limited by the nonle design configuration and by the vessel flange and

{

associated bolting. Therefore, the Code's examination requirements are impractical for i

these welds. Imposition of the Code requirements would necessitate design modificatons of the RHR heat exchangers to allow access to the subject welds, resulting in a considerable burden on the licensee.

The licensee has examined the subject welds to the extent prac*ical, examining 10% of the Code-required volume for Weld N3A and 40-50% for Welds N4A and N4B.

Additionally, the Code-required 100% surface examination was performed on each nonle weld. Therefore, based on the volume examined and the Code-required surface examination performed, it is concluded that any signifie, ant patterns of degradation, if present, would have been detected and reasonable assurance of the structural integrity of the pressure-retaining nonle welds has been provided.

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

S.

Reauest for Relief S. Examination Cateaorv C-C. Item C3.10. Intearal Attachments for Vessels Code Reauirement: Examination Category C-C, item C3.10 requires 100% surface examination of integrally welded attachments on pressure vessels as defined by Figure IWC-2500-5. Examinations are limited to attachment welds of components examined under Examination Categrries C-F and C-G.

Licensee's Proposed Alternative: In accordance with 10 CPR 50.55a(a)(3)(ii), the I

licensee proposed to supplement the surface examinativ.; that could not be completed with a VT-1 visual examination. The following integral attachments are covered by this request.

COMPONEN ITEM DESCRIPTION COVERAG LIMITATION T

E SUP-1A C3.10 RHR Heat Exch 70%

Whip Restraint Attached SUP-2A C3.10 83%

SUP 3A C3.10 81 %

SUP-4A C3.10 0%

The licensee stated:

o 21 "1.

A supplemental visual inspection (VT-1) was performed on the inaccessible areas (lower portion) of these welds with no adverse or reportable conditions observed.

"2.

No additional examinations will be performed on these welds. The components listed in this relief request have been examined to the maximum extent practical."

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

" Complete inspection of the Code-required surface area utilizing a surface inspection method was not possible based on restricted accessibility due to the interferences of design. These welds are support lugs which are part of the rigid support structure that stabilizes the upper portion of the RHR Heat Exchanger.

The lower portion of these lugs are restricted by an attached structural angle member frame which extends beyond the bottom edge of the lugs limiting access to these areas. This limiting condition restricts the access necessary to perform a magnetic particle inspection and the ability to use surface preparation equipment needed to prepare for liquid penetrant testing. In order to obtain full Code examination coverage on these components, it would require removal of the structural angle members and increase radiological exposure which would constitute a hardship and unusual difficulty for the sole purpose of providing access to obtain additional examination coverage. Partial code required coverage was obtained examining components SUP-1A, SUP-2A, SUP-3A, and SUP-4A using magnetic particle, liquid penetrant surface inspection methods and visual examination (VT-1). A visual inspection (VT-2) was performed during the pressure test (no leakage detected) which is conduct'ed on these components every refuel outage in accordance with IWA-5000 and IWC-5000. Drawings and sketches which illustrate the restricted conditions encountered that limit examination coverage are included in Enclosure 15."

Evaluation: The Code requires 100% surface examination of the subject integral attachment welds. These integral attachments are welded lugs that are part of the support structure stabilizing the upper portion of the RHR Heat Exchanger. Structural angle members that extend beyond the bottom of the lugs limit access to the subject areas. The limitation restricts access for magnetic particle examination and for surface preparation equipment needed for liquid peneuant testing. To examine the surface as required, structural members must be removed and reinstalled, which would expose plant personnel to increased levels of radiation. Imposition of this requirement would result in an undue hardship on the licensee.

As an attemative to the Code's examination requirements, the licensee has proposed to supplement the surface examinations (70-83% coverages obtained) with a VT-1 visual examination of the attachment welds. This attemative visual examination, in conjunction with the surface examinations, should have detected any significant degradation that may exist and provides reasonable assurance of the structuralintegrity of the RHR heat exchanger integral attachment welds. Based on the proposed attemative examination and the extent of Code examinations performed, it is ccncluded that imposition of the Code requirements would result in an undue hardsh:p without a compensating increase

r a

l 22 1

in the l'evel of quality and safety. Therefore, it is recommended that the licensee's proposed altemative be authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

T.

Reauest for Relief T. Examination Catecory C-C. Item C3.20. Intearal Attachments for Pipino Code Reauirement: Examination Category C-C, item C3.20 requires 100% surface examination of integrally welded attachments on piping as defined by Figure IWC-2500-1

5. Examinations are limited to attachment welds of components examined under Examination Categories C-F and C-G.

Licensee's Code Relief Reduest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the Code-required surface examinations on the following welds.

COMPONEN ITEM DESCRIPTION COVERAGE LIMITATION T

12-10-697A C3.20 RHR Piping 50 %

Design 8-10-8628 C3.20 RHR Piping 80-90%

Pipe Support 20-10-889 C3.20 RHR Piping 75%

Pipe Support 12-14-750A C3.20 Core Spray 86 %

Concrete Wall l

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

" Complete inspection of the Code-required surface volume for components listed in Table 15A is not possible based on restricted accessibility caused by interferences due to design limitations and/or support structures encountered when employing the surface inspection methods. Drawings and sketches which illustrate the restricted conditions encountered that limit examination coverage are included in Enclosure 15A."

Licensee's Proposed Altemative Examination (as stated)

"1.

No additional surface examinations will be performed. These welds have been examined to the maximum extent practical.

I "2.

A visual inspection (VT-2) was performed during the pressure test (no leakage detected) which is conducted on these components every refuel outage in accordance with IWA-5000 and IWC-5000."

Evaluation: The Code requires 100% surface examination of the subject integrally welded attachments. Review of the drawings / sketches submitted by the licensee i

revealed that complete examination was impractical because access is restricted i

l structures such as concrete walls, whip restraints, and pipe supports, as well as by the l

design configuration of the attachments. To meet the Code requirements, the integral l

attachments and/or interfering structures would require design modification and/or i

3 n*

a 23 removal to allow access to the subject welds. Therefore, surface examination of the subject integral attachment welds, to the extent required by the CoJe, is impractical. To meet the Code requirements, the affected systems would require design modification to allow access

.he subject welds. Imposition of this requirement would create a considerable burden on the licensee without a compensating increase in safety.

The licensee has completed a significant portion (50-90%) of the Code-required surface examinations of the subject components. Based on the surface examined for each component, it is reasonable to conclude that patterns of degradation, if present, would have been detected thus, providing reasonable assurance of the structural integrity of the subject nozzle-to-vessel welds. Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).

U.

Request for Relief U. Examination Cateaory C-F. Item C2.1. Pressure Retainina Welds in Pipina. Pumps. and Valves in Systems Which Circulate Reactor Coolant This request for relief was withdrawn by the licensee in letter dated June 21,1999.

V.

Recuest for Relief V. Examination Cateaory C-G. Item C2 3. Pressure Retainina Welds in Pioina. Pumps, and Valves in Systems Which Circulat9 Other Than Reactor Coolant This reque; for relief was withdrawn by the licensee in letter dated June 21,1999.

W.

_Reauest for Relief W. Examination Cateaories C-H. D-A. D-B. and D-C. Periodic Pressure Tests This request for relief was withdrawn by the licensee in letter dated June 21,1999.

3.0 CONCLUSION

S l

The INEEL staff reviewed the licensee's submittal and concludes that, for Requests for Relief E, L, M. P and S, compliance with the Code requirements would result in a hardship without a compensating increase in the level of quality and safety and that the licensee's proposed attematives will provide reasonable assurance of structural integrity.

Therefore, it is recommended that these proposed altematives be authorized for the second 10-year interval pursuant to 10 CFR 50.55a(a)(3)(ii).

For Requests for Relief A through D, G, O, Q, R, and T it is concluded that the Code requirements are impractical. Therefore, it is recommended that relief be granted pursuant to 10 CFR 59.55a(g)(6)(i).

Requests for Relief F, H through K, N, U, V, and W, were withdrawn by the I.fcensee in letter dated June 21,1999.

i c