ML20234C767

Safety Evaluation Granting 870612,0814,1026 & 1119 Requests for Relief from Certain Section XI ASME Code Requirements Re First 10-yr Interval Inservice Insp Program

ML20234C767
Person / Time
Site:	Grand Gulf
Issue date:	12/23/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20234C765	List: ML20234C761 ML20234C767
References
NUDOCS 8801060318
Download: ML20234C767 (16)

Text

s SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE FIRST TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM-l SYSTEMS ENERGY RESOURCES _, IflCORPORATED GRAND GULF NUCLEAR STATION UNIT 1 DOCKET NO. 50-416 INTRODUCTION The Technical Specification for the Grand Gulf Nuclear Station Unit 1 (GGNS-1) states that inservice examination of ASME Code Class 1, 2', and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required _by 10 CFR 50.55a(g) except where specific written relief has been granted by the Commission.

Some plants were designed in conformance to early editions and addenda of Section XI. Consequently, certain requirements of later editions and addenda of Section XI are impractical to perform because of the plants' design, component geometry, and materials of construction. Regulation 10 CFR 50.55a(g)(6)(i) authorizes the Commission to grant relief from those requirements upon making the necessary findings.

The Licensee submitted the first ten-year Interval Inservice Inspection Program for the Grand Gulf Nuclear Station Unit 1 by letters dated May 11, June 3, June 29, July 25, September 20, 1984, and October 31. 1985. The staff with assistance from its contractor, Science Applications International Corporation (SAIC), reviewed and approved the program for the period from July 1, 1985, to July 1, 1995. The Safety Evaluation Report was issued for that evaluation on July 22, 1986. The ISI program for the Grand Gulf Nuclear Station Unit 1 is based on the examination requirements of Section XI of the ASME Code, 1977 Edition, including Summer 1979 Addenda.

In submittals dated June 12, and August 14, 1987, the Licensee requested' revision to Relief Requests I-00004, I-00009 and I-00010, which were reeviously reviewed and evaluated in the July 22, 1986, Safety Evaluation Report, and the review and evaluation of two new Relief Requests I-00014 and I-00015. The revised and new examination limitations were identified while performing inservice inspection during the first refueling outage. The October 26, 1987, letter withdrew the part of Relief Request I-00015 concerned with inspection of the reactor vessel head in accordance with the commitment to the staff in the October 15, 1987, meeting. The November 19, 1987, letter was to upgrade the examination procedure to the requirements of Section XI, 1983 Edition, including Summer 1983 Addenda, ASME Code, for leakage test boundary definition.

The review and evaluation of the Licensee's submittals was performed by the staff with technical assistance from its contractor, Idaho National Engineering Laboratory.

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1 EVALUATION The determinations addressed by the Licensee in the submittals of. June 12, August 14, October 26, and November 19, 1987, that certain ASME Code j requirements were impractical to perform at the Grand Gulf Nuclear Station Unit I were evaluated. A sumary of our evaluation is shown in Table 1.

The detailed evaluation is attached.

CONCLUS10_N I Based on the review of the Inservice Inspection Program and the evaluation of the relief requests we conclude that for the components for which relief:

was requested and granted, the alternate methods imposed through this document give reasonable assurance of the pipino and component pressure boundary and '

component support structural integrity. The staff has-determined that the  !

Code requirements are impractical and, pursuant to 10 CFR 50.55a(o)(6)(1), l the granting of the requested relief is authorized by. law and'will not.  !

endanger life or property, or the common defense and security, and is .:

otherwise in the public interest considering the burden that could result.

if the requirements were imposed on the facility.

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TABLE 1 Request Examination Number Cateaory Description Status I-00004, B-A Reactor Pressure Vessel Granted (Rev. 2) Item Bl.21 l

I-00009 C-C Pump Casing and Granted I (Revised) Item C3.70 Pump Integral Attachment Welds I-00010, B-J Pressure Retaining Piping Welds Granted I (Rev. 1) Items 89.11 in Class 1 Systems and B9.12 1-00014 B-0 Reactor Pressure Vessel Granted 3b I-00015 B-A Reactor Pressure Vessel Granted (Revised) Items Bl.11, l 81.12, Bl.22 l B.130 and 81.40 l B-D i Items B3.90 and B3.100 1 B-F l Item B5.10  ;

1 1-00016 0-A, D-B and D-C Integral Attachment, Granted l Class 3 I-00017 C-H Pressure Retaining Granted l Components, Class 2 1-00018 B-P Pressure Retainino Granted Components, j Class 1 -

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1 SALP REPORT

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i PLANT: Grand Gulf Nuclear Station Unit 1 LICENSEE: Systems Energy Resources, Inc. 4 DOCKET N0.: 50-416 REVIEWER: FBlitton l TAC #65984, 65610 and 66631 LICENSING'ACT. Evaluation of Relief Requests for ISI. Program EVALUATION CRITERIA RATING REMARKS-1.- Management Involvement ".

and Control in Assuring Quality

2. Approach to Resolution 2 of Technical Issues from a safety standpoint

3. Responsiveness to NRC 2 Initiatives 4 Enforcement History NA I

5. Reporting and Analysis NA

6. Staffing NA-Overall 2 i

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ATTACHMENT TO THE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE FIRST TEN-YEAR INTERVAL IN5ERVICE IN57ECTION PROGRAli SYSTEM ENERGY RESOURCES, INC6RPORATED GRAND GULF NUCLEAR STATION - UNIT 1 DOCKET NO.: 50-416 I. INTRODUCTION This document was prepared with the technical assistance of U.S. Department of Energy (DOE) contractors from the Idaho National Engineering Laboratory (INEL).

Technical Specification 4.0.5 for the Grand Gulf Nuclear Station Unit 1 states that the inservice examination of ASME Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Yessel Code and applicable Addenda as required by 10 CFR E0.55a(g) except . i where specific written relief has been granted by the Comr:ission. Some plants )

were designed in conformance to early editions of this Code Section, l consequently certain requirements of later editions and addenda of Section XI ,

are impractical to perform because of the plant's design, component geometry, and materials of construction. Regulation 10 CFR 50.55a(g)(6)(i) authorizes l the Commission to grant relief from those requirements upon making the l necessary findings. l II. TECHNICAL REVIEW CONSIDERATIONS '

On July 22, 1986, the NRC issued a Safety Evaluation Report (SER) discussing the evaluation of the First 10-Year Interval Inservice Inspection (ISI)

Program for Grand Gulf Nuclear Station, Unit 1, and information related to requests for relief from certain Code requirements which the Licensee had determined to be impractical to perform during the first inspection interval.

In a submittal dated June 12, 1987, the Licensee submitted revisions to Relief Requests I-00004 (Rev. 2), 1-00009 (Revised), and 1-00010 (Rev. 1), which were j previously reviewed and evaluated in the July 22, 1986 SER, and two new relief j requests (I-00014 and I-00015). These revised and new relief requests are  :

necessary due to examination limitations identified while performing inservice j inspections during the first refueling outage.

In submittals dated August 14 and November 19, 1987, the Licensee submitted three additional relief requests (I-00016, I-00017 and I-C0018). The purpose of these requests was to allow the use of ASME Code Secticn XI, 1983 Edition, Sumer 1983 Addenda for examinations of integral attachments and test boundary definition. In a submittal dated October 26, 1987, the Licensee submitted a revision to relief request I-00015.

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III. EVALUATION OF RELIEF REQUESTS This evaluation, which addresses the June 12, Auoust 14, October 26, and November 19, 1987, submittals, amends the review of Relief Requests I-00004, 1-00009, and I-00010 as reported in the July 22, 1986 SER, and evaluate:;

Relief Requests I-00014, I-00015 (Revised), I-00016 I-00017 and I-00018 in their entirety. The Licensee has demonstrated that either (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specific requirements of this section would result in i hardship or unusual difficulties without a compensating increase in the level l of quality and safety.

Unless otherwise stated, reference to the Code refers to the ASME Code, l Section XI,1977 Edition including Addenda through Sunner 1979. l l

A. Relief Request No. I-00004 (Revision 2), Examination Cateacry B-A l

FEB1.21, RPV Lower Hea3-to-Shell Weld A-A Revision 2 to Relief Request No. I-00004 provided additional information with regards to the extent of the alternative manual ultrasonic examina-tions of lower head-to-shell weld A-A. The Licensee reported that manual examinations will be performed to the maximum extent possible, considering the interferences caused by the RPV support skirt. The support skirt prevents both the 60" and 45* T-Sccns from examining the total weld volume. The three recordable indications, previously identified, were recorded in the base material of the head utilizino the 0 scan. These indications will be monitored and, if any of the indications appear to be increasing in size, the Licensee will take appropriate actions.

Evaluation _: As reported in the Safety Evaluation Report dated July 22, 1986, the lower head-to-shell weld A-A on the RPV is the transition from the cylindrical shell to the spherical lower head. The weld is accessible through an annular gap approximately 30 inches wide between the RPV and the biological shield wall. The upper portion of the weld will be examined over 100% of the Code required volume using remote, automated ultrasonic inspection equipment. However, the Licensee reports that the automated equipment, as currently configured, cannot be used to examine the lower portion of the weld due to the spherical curvature of the lower head. Manual ultrasonic examination of the lower portion of J the weld is the only alternative currently available. '

The lower portion of weld A-A was examined over 100% of the length during the preservice examination using manual ultrasonic methods. Based on this examination, the Licensee estimates that approximately 16 man-hours are required exclusive of exit and entry time to conduct a complete manual ultrasonic scan of the lower portion of weld A-A. The radiation field in the region of weld A-A has been estimated to be 800 mR/hr based on radiation fields in similar BWRs following 40-months operation.

Combining the estimates of inspection time and radiation level, the Licensee estimates that a total exposure of 14,500 millirem would be required to conduct the inservice examination of the lower portion of weld A-A in the first period. Higher exposures would occur if the examinations are deferred.

In this revised relief request, the Licensee has reported that manual  !

examinations will be performed to the maximum extent possible, )

considering the interferences caused by the RPV support skirt. In '

addition, the three indications previously identified will be monitored and, if any of the indications appear to be increasing in size, the Licersee will take appropriate actions. .

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Conclusions:

Based on the review of Relief Request No. I-00004 (Revision  !

'd) and the safety Evaluation Report dated July 22, 1986, the staff has concluded that the alternative manual examination will be performed to j the maximum extent possible with the available access discussed above and  !

the equipment and technology being used. We grant the relief as 1 requested, j B. Relief Request No. I-00009 (Revised), Exam,ination Cateoories C-G and i C-0, Pump Casing and Pump Integral Attacnment Welds i

NOTE: The pump casing welds are evaluated in the SER dated j July 22, 1986. Relief Request No. 1-00009 was revised j to include Examination Category C-C, pump integral  ;

attachment welds. The request for relief for the pump l integral attachment welds is evaluated below.

Code Requirement: Section XI, Table IWC-2500-1, Examination Category t-C, Item U E equires a 100% surface examination of Class 2 pump integral welded attachments as defined by Figure IWC-2500-5. This examination is limited to attachments whose base material design thickness is 3/4 inch or greater and to those components required to be examined under Examination Category C-G.

1 Licensee's Code Relief Request Relief is requested from performing 100% of the Code required surf ace examination of the integrally welded l attachments, within the surrounding concrete pump support encasements, for the following pumps:

PUMP _P_ UMP NO.

Residual Heat Removal IE1200028 Low Pressure Core Spray 1E210001 High Pressure Core Spray 1E220001 Licensee's Proposed Alternative Examination: None.

Licensee's Basis for Requestina Relief: The subject pumps have a support integrally welded to the bottom exterior of the pump barrel that rests against the sump floor. The clearance between the floor and the bottom of the barrel is approximately 1 inch, which prevents sufficient at ess to perform the surface examination of the 1/2 inch of base material on each side of the attachment weld.

Evaluation: The Licensee's revised submittal has been reviewed, including the weld design, the Ccde requirement from which relief is being requested, and the figure which shows the examination limitation.

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Based on this review, it is noted that the Licensee will examine the surface area of the welds and that the pump supports have to be redesigned in order to complete 100% of the Code-required surface examination on the adjacent base :naterial.

Conclusions:

It is concluded that the limited Section XI surface examination ensures an acceptable level of inservice structural integrity and that compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating

' increase in the level of quality and safety. Therefore, relief is

, granted as requested.

C. Relief Request No. I-00010 (Revision 1)s Examination Category B-J.

Pressure Retaining Pipina Welds in Class 1 Piping Systems Revision I to Relief Request No. I-00010.(Rev. 1) includes an additional twenty Class 1 piping system welds for which relief is requested. The Licensee identified these additional welds during the first refueling outage at Grand Gulf Nuclear Station, Unit 1. All of the additional welds are pump-to-pipe, valve-to-pipe or fitting-to-pipe welds where the pump, valve, and/or fitting restrict volumetric examination. The subject welds are listed below, along with the system, the weld configuration, _

and the type of scan with the percent of the weld which cannot be examined for that type of scan.

SYSTEM WELD WELD P-SCAN T-SCAN NO. H0. CONFIG. LIMITATION LIMITATION B33 M W5 ELBOW / PUMP 50% 27.2%

B33 G001W6 PDMP/ PIPE 51% 42.4%

B33 G001W8 VALVE / PIPE 50%

B33 G001W28 ELBOW / PIPE 50% 38.4%

B33 G001W29 PUMP / PIPE- 50% 38.6%

B33 G001W31 VALVE / PIPE 50% 50%

B33 GS-B1-B PIPE / SWEEP 50% 40.8%

B3S GS-B1-E PIPE / SWEEP 50% 36.5%

B33 G023W37 TEE / PIPE 50% 34.5%

B33 G024W8 SWEEP / PIPE 50%

B33 G024W27 SWEEP / PIPE 50%

B33 G10-B1-L PIPE / SWEEP 50%

B33 G10-B1-K PIPE / SWEEP 50%

B33 G10-B1-J PIPE / SWEEP 50%

B33 G10-B1-H PIPE / SWEEP 50%

B33 G10-B1-G PIPE / SWEEP 50%  ;

B33 G10-B1-F PIPE / SWEEP 50%

B33 G001W34 PIPE / CROSS 50%

B33 G001W34 PIPE / CROSS 50% i i

B33 G10-B1-A PIPE / CROSS 50%

B33 G10-B1-B PIPE / CROSS 50%

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i 5-l Evaluation: As reported in the Safety Evaluation Report dated July 22, 1986, all of the subject welds will receive volumetric examination of the accessible portions during the inspection interval. j The Licensee has also connitted to conduct an engineering evaluation ,

of the entire weld condition if indications are found during the i volunetric examinations. The Code-required surface examination and l pressure tests will be conducted on all the welds. j The Licensee has also stated failure of any of the subject welds would not have an adverse effect on plant safety since all of the areas can be 3 isolated or the system can be shutdown in a manner consistent with plant i design. In addition, continuous leak detection monitoring is provided on  ;

all of the systems containing inaccessible welds. ,

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Conclusions:

Based on the review of Revision 1 of Relief Regt.est l No. I-00010 (Rev. 1) and the SER dated July 22, 1986', it is concluded  !

that the limited Section XI volumetric examination, along with the j Code-required Section XI surface examination and the hydrostatic test, j ensure an acceptable level of inservice structural integrity and that i compliance with the specific requirements of Section XI would result is, j hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, relief is granted as requested, D. Relief Pequest No. I-00014, Examination __Cateoory B-D 1 Items

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83.90 a and 83.100, Reactor Pressure Vessel Nozzle-to-Vessel Elds and )

Nozzle Inside Radius Sections j i

Code Requirement: Section XI, Table IWB-2500-1, Examination Category B-D, Items B3,90 and B3.100 require a 100% solumetic examination of Reactor Pressure Vessel (RPV) nozzle-to-vessel welds and the nozzle  ;

inside radius sections as defined by Figure IWB-2500-7. j i

Licensee's Code Relief Request _: Relief is requested from examining i Mil of the Code-required volume on the nozzel-to-vessel welds that j are examined utilizing automated methods. Also, relief is requested q from examining those areas that are inaccessible with manual techniques j for the nozzles that require manual examinations. The following are the j affected nozzles: .

Automated Techniques  :

N1(A&B) Recirculation Outlet Nozzles N2(A-M) Recirculation Inlet Nozzles N3(A-D) Mainsteam Nozzles  !

N4(A-F) Feedwater Nozzles  !

N5(A&B) Core Spray Nozzles i

N6(A-C) RHR/LFCI Nozzles Manual Techniques ]'

N7 & N8 Top Head Cooling Spray and Spare Nozzle N9(A&B) Jet Pump Instrument Nozzles  ;

N10 CRD Return Nozzle N16 Vibration Nozzle i

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Licensee's Proposed Alternative Examination: None. The Licensee will- I perform the Code-required volumetric examinations using automated or l manual techniques to the maximum extent practical.

Licensee's Basis for Requesting Relief: The Licensee reports that the

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! nozzle design We BWR-6 does not allow for a full volume examination 1 of the weld and associated 1/2T of base material for the following ]

reasons: i

1. Due to the short distance from the weld centerline to the

! nozzle-to-shell radius, the examination volume can only be  !

scanned from one side (shell side).

2. Also, this short distance prevents extending the scanning arm far enough past the weld towards the nozzle to obtain full coverage of the required volume while scanning from the shell side.

NOTE 1 See Relief Request No. I-00015 (Revised) for additional limitations I due to adjacent components.

Evaluation: The Licensee's submittal has been reviewed, including the ta61es listing the total Code-required volume of the subject welds with ,

regards to the percentage of the accessible portions of the Code-required volume that can be examined, the information to support the determination that the Code-requirements are impractical, and the figure showing the examination limitations.

The tables provide a comparison of Code requirements and the examinations that are achievable. In this table, the Code-required vol me has been subdivided into the areas recognized by Regulatory Guide 1.150 as being more critical and, additionally, the weld and head affected zone coverage has been reported separately. The table also compares the examination coverage that can be obtained manually aoainst what is obtained with automated equipment. This limited additional volume does not appear to be justified based on the ALARA information provided by the Licensee.

The Licensee's submittal also provided supporting technical justifications with regard to applied stress levels, fatigue crack initiation / propagation, radiation embrittlement, consequences of postulated cracking, allowable crack size, and leak before break.

For further ISI examinations, the Licensee should continue to monitor the 4 development of new or improved examination technqiues. As improvements in these areas are achieved, the Commission will require that these enhanced techniques be made a part of the inservice examination require-ments for the components or welds which received a limited examination.

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Conclusions:

Based on the above evaluation, it is concluded that a j significant percentage of the Code-required volumetric examination j will be performed and that this examination, in conjunction with the j system leakage test at each refueling outage and a system hydrostatic test each inspection interval, will ensure an acceptable level of l

inservice structural integrity. Compliance with the specific require-l ments of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.

Therefore, relief is granted as requested.

E. Relief Request No. I-00015 (Revised), Examination Categories B-A, B-D, and B-F, Reactor Pressure Vessel Welds i Code Requirement: Section XI Table IWB-2500-1, Examination t~ategory B-A, Items Bl.11 (shell circumferential welds), Bl.12 l (shell longitudinal welds), Bl.22 (meridional head welds), and .

Bl.30 (shell-to-flange weld) all require a 100% volumetric examination i l as defined by Figures IWB-2500-1, -2, -3, and -4 respectively. Item 81.40 (head-to-flange weld) requires both 100% surface and volumetric  ;

examinations as defined by Figure IWB-2500-5 i Examination Category B-D, Items B3.90 (RPV nozzle-to-shell welds) and 4 B3.100 ozzle inside radius sections) both~ require a.100% volumetric '

examination as defined by Figure IWB-2500-7.

1 Examination Category B-F, Item B5.10 (RPV safe-end welds) requires both 100% surface and volumetric examinations as defined by Figure IWB-2500-8.  ;

L_ic_ensee's Code Relief Request: Relief is requested from examining i 100% of the Code-required volume on the following RPY welds:

Circumferential Weld - AO Longitudinal Weld - BA, BB, BC, BH, BJ, BK, BM, BN, BP, & BR Meridional Head Welds - DA, DR, BC, and DD Shell-to-Flance Weld - AE Nozzle-to-Vessel Welds - N20, N2C, N2J, N2K, N4A, N4C, N40, N4F N9A, & N9B Nozzle Inside Radius - N7 & N8 RPV Saf,e-End Welds - N1A, N1B, N2A thru N2N, N4A thru N4F, NSA, N58, N6A, N6B, N60, N9A, and N98 Licensee's Proposed Alternative Examination: None. The Licensee states that the Code-required volumetric examination of the subject welds will be performed to the maximum extent practical.

L,1censee_'s Basis for Requesting Relief: The Licensee's submittal provided descriptions of the geometric limitations for each of the subject welds.

The RPV welds, including the nozzle-to-vessel welds, all have geometric interferences caused by adjacent nozzles, welded name plates, head pene-trations, or restrictions caused by the closure head flanges.

i The two nozzle inside radius sections (N7 and N8) will receive limited examinations due to twelve 1-3/8 inch diameter holes drilled and tapped 31/4 inches deep into the nozzle face. These holes prevent volumetric examination of the bore region of the nozzle inner radius, i

Due to the geometric configuration of the nozzle-to-safe end assembly, full Code coveraoe cannot be obtained from two directions. The Licensee will be performing these examinations with either shear wave, refracted 3 longitudinal wave, or both due to the complex bt and trimetallic '

structures of the nozzle-to-safe end assembly.

Evaluation: The Licensee's submittal has been reviewed, including the figures showing the geometric configuration of the welds and the i examination limitations, the tables providing a listing of the affected .

components and RPY welds with a detailed description of the cause and '

degree of the limitation, and the technical justifications for the granting of relief.

The examination limitations of the RPV welds, including the nozzle-to-vessel 3 welds, appear to be consistent with those reported on plants with similar i vessel design.  !

I Currently, examinations of the nozzle-to-safe end assembly welds are performed utilizing automated systems. The coverage reported in the Licensee's submittal indicates that a limited additional coverage can be obtained in the event future examinations are performed with manual techniques. However, relief would still be required even if the manual volumetric examinations are performed because 100% of the Code-required coverage cannot be obtained.

For future ISI examinations, the Licensee should continue to monitor  !

the development of new or improved examination techniques. As  ;

improvements in these areas are achieved, the Commission will require j that these enhanced techniques be made a part of the inservice i examination requirements for the components or welds which received a l limited examination.

Conclusions:

Based on the above evaluation, it is concluded that  ;

compliance with the specific requirements of Section XI would result in i hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, relief is granted as requested.

i Relief Request _No_. I-00016. ISI of Examination Cateoory 0-A, D-8, and F.

D-C, Intearal Attachments Code Requirement: Section XI, Table IWD-2500-1, Examination TaTegories a D-A, D-B, and D-C, all require Class 3 integral attachments to receive a visual examination (VT-3) each inspection period.

Licensee';s Code Relief Request: Relief is requested from performing the Code-requirea VT-3 examinations on Class 3 integral attachments on a frequency consistent with the requirements of ASME Code Section XI, I 1977 Edition, Summer 1979 Addenda, Table IWD-2500-1. l l

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Li_c_en_see's Pr_oposed Alternative Examination: The Licensee proposes to perform the Code-required VT-3 examinations on Class 3 integral attachments on a frequency consistent with the requirements of ASME Code Section XI, 1983 Edition, Summer 1983 Addenda Table IWD-2500-1.

Licensee's Basis for Requesting Relief: This request for relief is based on the following:

1. The subject integral attachments were designed, fabricated and examined to the requirements of ASME Code Section III, Class 3 requirements.

2. The requested change would be consistent with the examination frequencies specified in ASME Code Section XI for Class 1 and Class 2 components of similar function.

3. Examining the integral attachments once each interval compared to, three times each interval reduces total man rem exposure by 66%.

4. The material stress allowables and' method of analysis used in the design of Class 3 integral attachments is the same as those used in Class 2 designs. The design safety margin for a Class 3 integral attachment is therefore the same as for a Class 2 design. For this reason, examiritions of Class 3 integral attachments at a frequency I exceeding that of Class 2 is not necessary. I

5. This request for relief is consistent with the currently approved edition of ASME Section XI (1983 Edition, Suniner 1983 Addenda).

Evaluation: 10CFR50.55a(g)(3)(v) permits updating to the requirements of I later approved editions and addenda of the ASME Code, or portions thereof, i which are incorporated by reference in paragraph 50.55a(b), subject to the limitations and modifications listed therein.

Conclusions:

Based on the above evaluation, it is concluded that the Licensee-is permitted to update to later editions and addenda of the Code and that compliance with the specific requirements of Section XI (77S79) would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, relief is granted as requested.

G. Relief Request No. I-00017. Examination Cateaory C-H, Class 2 System Pressure Tests Code Requirement: Class 2 pressure retaining components, Examination Category C-H. are required to receive a system pressure or functional test each inspection period and a system hydrostatic test each inspection interval.

Licensee's Code Relief Request: Relief is requested from performing the Tode-required system pressure test in accordance with ASME Code Section XI,1977 Edition, Summer 1979 Addenda (77S79).

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Licensee's Proposed Alternative Examination: The Licensee proposed to perform the Code-required system pressure test utilizing boundaries consistent with ASME Code Section XI,1983 Edition, Sunner 1983 Addenda (83S83), Table IWC-2500-1, Examination Category C-H, note 7.

Licensee's Basis for Requestina Relief: This relief request is based on tne following:  !

1. All components excluded from pressure testing by the clarification ]

provided in 83S83 are designed, fabricated, installed, and tested to the requirements of ASME Code Section III, Class 2. l

2. The components excluded from pressure testing by this relief request are not reouired to aid the system', in performing their safety function.

3. This request for relief is consistent with the currently appraved edition of ASME Ser. tion XI (83S83) which provides definitten or scope of the pressure boundary that is required to be tested.  ;

Evaluation: 77579, Table IWC-2500-1, Exar ination Category C-H t'oes not provide definition or scope of the pressi re boundary that is re'.1uired to be pressure tested. Later editions added clarification that the pressure boundary includes only those portions ei the system required to operate or supportclosed normally the safety valvesystem function (including up to a sa'ety orand including)the relief first valve or valve capable of automatic closure when thr safety function is required. With the addition of this clarification, non-essential piping is removed from the pressure test boundaries, thus eliminating unnecessary man rem exposure.

10 CFR 50.55a(g)(3)(v) permits updating to the requirements of later approved editions and addenda of the ASME Code, or pcrtions thereof which are incorporated by reference in paragraph 50.55a(b), subject to the .

limitations and modifications listed therein,

Conclusion:

Based or the above evaluation, it is concl.sded that the.

Elcensee is pemitted to update to later editions and e.ddenda of the Code and that compliance with the specific requirements of 3ection XI (77S79) would result in bardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, relief is granted as requested.

H. Relief Request No. I_-00018, Examin_ation Cateaory B-P, Class 1 Pressure fetainina Coroponent_s_

Code Rr Exa_mina;quirement:

tion Cate Class 1 pressure retaining components, test (IWB-5221)each gory refueling B-P, are outage, requiredand to receive a system a system leakage hydrostatic test (IWB-5222) each inspection interval.

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L_i__censee's Code Relief Request: Permission is requested to perform j system leakage testing of the Class 1 boundary pursuant to the requirements of Section XI of the ASME Code, 1983 Edition, Summer 1983 Addenda, Table IWB-2500-1, Category B-P. The request applies to the leakage test and not to the hydrostatic test required each interval. A list of the systems that are examined by the VT-2 method but excluded  :

from pressurization is as follows: )

ITEM SYSTEM LINE CLASS DESCRIPTION 1 B21 2"-DBA-19 LINE DOWNSTREAM 0F Q1821-F002 2 B21 1"-DBA-87 LINE DOWNSTREAM 0F Q1B21-F136A 3 B21 1"-DBA-87 LINE DOWNSTREAM 0F Q1621-F136B 1 4 B33 2"-DBA-42 LINE DOWNSTREAM OF Q1833-F029 .

5 833 2"-DCA-24 LINE DOWNSTREAM 0F QlB33-F051A 6 B33 2"-DCA-24 LINE D0WNSTREAM 0F Q1833-F051B l 7 C41 3/4'-DCA-4 LINE DOWNSTREAM OF Q1C41-F2158 i 8 C41 1"-DCA-31 LINE DOWNSTREAM 0F Q1C41-F210 9 C41 3/4"-DCA-33 LINE DOWNSTREAM OF Q1E12-F219 i 10 E12 1"-DBA-80 LINE DOWNSTREAM 0F Q1 Elf-F344 l 11 E21 1"-DBA-31 LINE DOWNSTREAM OF Q1E21-F207 12 G33 3/4"-DBA-82 LINE' DOWNSTREAM OF Q1G33-F001 i 13 G33 1"-DBA-86 LINE D0WNSTREAM OF Q1G33-F241 14 E22 1"-DBA-78 LINE DOWNSTREAM 0F Q1E22-F218 l 15 E22 12"-DBA-75 LINE UPSTREAM 0F Q1E22-F005 i 16 E22 14"-DBA-5 LINE UPSTREAM OF Q1E22-F003  ;

17 E38 1 1/2"-DBA-87 LINE UPSTREAM 0F Q1E38-F002A&B l l

Licensee'sProposedAJter_nativeE_x_ amination: None i Licensee's Basis for Lequestina Relief: The request is based on the following considerations:

1. All components excluded from the system leakage test are designed, fabricated installed and tested to the requirements of ASME Section III, Subsection NB (Class 1).

2. The components e:i:cluded from the system leakage test are subjected to the system hydrostatic test once each interval.

3. The high/ low pres.sure interfaces identified by Grand Gulf Nuclear Station Technical Specification 4.4.3.2.3 are exempt from this request for relief.

4. This request for relief is consistent with the current NRC approved edition of ASME Section XI (1983 Edition, Summer 1983 Addenda).

Evaluation: 10 CFR 50.55a(g)(3)(v) permits updating to the examination requirements of later approved editions and addenda of the ASME Code, or portions thereof, which are incorporated by reference in paragraph 50.55a(b), subject to the limitations and modifications listed therein.

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, Conclusions 1 It is concluded that the Licensee is permitted to update the examination requirements to later editions and addenda of the ASME Code and that compliance with the specific requirements of Section XI, 1977 Edition including Summer 1979 Addenda, would result in a hardship on  !

the Licensee without a compensating increase in the level of quality and I safety. The relief is granted as requested.in letter dated November 19, l 1987 I

IV. CONCLUSIONS 1

We conclude from our evaluation of the Licensee's determination that certain Section XI ASME Cede,1977 Edition Summer 1979 Addenda, examination requirements.are not practical to perform' at the Grand Gulf Nuclear Station Unit 1. The Licensee requested relief from performing f those requirements. Pursuant to 10 CFR 50.55a(g)(6)(i), relief is l

granted for the following requests: 1-00004 (Rev. 2) .I-0009 (Revised), j I-00010(Rev.1),I-00014,1-00015(Revised), 1-00016. I-00017, and (I-00018).

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