ML20236R324

Safety Evaluation Supporting Util Submittal of Rev 2 to First 10-yr Interval Inservice Insp Program Plan

ML20236R324
Person / Time
Site:	Wolf Creek
Issue date:	11/12/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20236R308	List: ML20236R306 ML20236R324
References
NUDOCS 8711230223
Download: ML20236R324 (6)

Text

, ,.g ,

'.! ansa 'o,, UNITED STATES 1

. E o NUCLEAR REGULATORY COMMISSION

{ f WA$HING TON, D. C. 20555 k ,/

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR _ REACTOR REGULATION l

OF'THE FIRST TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN KANSAS GAS AND ELECTRIC COMPANY J

WOLF CREE _K GENERATING STATION DOCKET NO.: 50-482 INTRODUCTION.

l Technical Specification 4.0.5 for the Wolf Creek Generating Station states that the surveillance requirements for Inservice Inspection and Testing i of American Society of Mechanical Engineers (ASME) Boiler and. Pressure Vessel 1 Code Class 1, 2 and 3 components shall bq applicable as follows: Inservice Inspection of ASME Code Class 1, 2 and 3 components shall be pe'rfonned in accordance with Section XI of the ASME Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Comission pursuant to 10 CFR 50, Section 50.55a-(g)(6)(1).

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 3 provisions and the preservice examination requirements, set forth in the ASME 1 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 systems pressure tests . ]

conducted during the first ten-year interval shall comply with the j requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(g) on the date twelve months prior to the date of issuance of the operating license, subject to the limitations and modifications listed therein. Thecomponents(includingsupports)may.

meet the requirements set forth in subsequent editions and addende of the ASME i Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations-and modifications listed therein.  ;

i Pursuant to 10 CFR 50.55a(g)(5), if. the licensee dete, nines. that conformance

• with an examination requirement of Section.XI of the ASME Code is not practical for his facility, information shall be submitted to the Commission in support of that determination and a request made-for relief from'the ASME Code requirement. Af ter evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(i), the Comission may grant relief and may impose alternative requirements as it determines are. authorized by law and will l not' endanger life or property or the common defense and security and are

-otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were. imposed. ,

f i

8711230223 8 12 PDR ADOCK 0 <

G p

1 pr , .

}

l 1

l Or. December 11, 1985, Kansas Gas and Electric Company (the licensee) submitted the first ten-year Interval Inservice Inspection (ISI) Program Plan, (Revision l'

2) for the Wolf Creek Generating Station, to meet the requirements of the 1980 Edition Winter 1981 Addenda, except that the extent of examination for Class 2 piping welds will be determined by the 1974 Edition Sunner 1975 Addenda, of Section XI of the ASME Boiler and Pressure Vessel Code. The staff, with technical assistance from its Contractor, Idaho National Engineering Laboratory (INEL), has evaluated the first ten-year Interval Inservice Inspection Program Plan and additional information related to the plan and to the requests for relief from certain ASME Code requirements determined to be impractical to perfonn at the Wolf Creek Generating Station during the first inspection in terval .

EVALUATION The ISI Program Plan has been evaluated for (a) application of th'e correct Section XI Code editicn and addenda, (b) compliance with examination and test re:uirements of Section XI, (c) acceptability of the examination sample, (c' compliance with comitments made by the licensee prior to plant operation, (e) correctness of the application of system or component examination exclusion criteria, and (f) adequate information in support of requests for relief from ircractical Section XI Code requirements. The staff, with technical assistance a from INEL, has determined that the licensee's ISI Proaram Plan reflects cocpliance with the requirements listed above. The information'provided by tFe licensee in support of requests for relief from impractical requirements has been evaluated and the bases for granting relief from those requirements i I

are documented in the Technical Evaluation Report (TER) attached. We concur with the findings and recommendations contained in the TER. A summary of 1 these reliefs is presented in TABLE 1.

l CCNCLUSION The staff concludes that the Wolf Creek first ten-year Inservice Inspection Program Plan, Revision 2 with the additional information provided and the i specific written reliefs constitute the basis for compliance with 10 CFR 50.55a(g) and Technical Specification 4.0.5 and is therefore acceptable.

Principal Contributors: George Johnson Paul W. O'Connor Dated:

l l

t d d d d d d f ss e e e e e e eeu t t t t t t i ut n n n n n n l qa a a a a a a eet r r r r r r RRS G G G G G G h c c i a e er e d d e d d c ct v l l l l a c ae i e ef e e f i f mtl Wo edt W w w r r runa eea u%t ul ec ssn f e f e f e f e s4 e soti nor epe omu omud omu om u  %

9m u %

Vxt ec cot %l %l l %l %l 0dl 0d a irl 5 o 0 oe 0 o 0o 0no 0 n'o r LPA 7V 9Vw 9v 9v 1 aV 1 at p d d c c c c nc nc i i i i ai ai d r r r r r r e t t t t et et S rd e e e e ce ce T

S i o uh m

u m

u m

u m

u am f u am f u E qt l l l l rl rl U ee o o o o uo uo Q RM V V V V SV SV E

R 1 F E

E I  :

L L ABCD - d s -

B E  : - - - - o o l d W W A R s1 11 1 t e 1 t 1 d e l - -

T e

d d2222 t 5 - 4 aW e4AWBWC F l l 1 1 11 d a 1 dd1 e - W - - - -

O rb oe oe- - - - al - al - H e o 431323 o d tW tW7777 eP 2 ee1 g td - - - - - -

Y oe - - 0000 H 0 HW0 en - n333333 R et n el el 11 11 r 1 1 ra eE000000 A m i ge l e- - - - ra - rl - ul l BBBBBB M uam ns zsVVVV el dV el V sF zeBBBBBB M l ea as zsRRRR wl l R weR o- zfTTTTTT U orx l e oe - - - - ooe - oh - l o oa - - - -

S VAE FV NVI 11 1 LDW1 LS1 Ct NS1 11111 -

r rt e

z on r r i

e r r r r mn eo ol t e ol ol ol ol u t e t e t e t e s t p cs cs cs cs cs s sm as as as as as e yo ee ee ee ee ee r SC RV RV RV RV RV P y

r

. g o

me A D at A A A F xa - - - - - -

EC B B B B B B o

N 0 0 1 1 0 0 m 3 9 2 2 4 4 e

t 1 3 l l 1 5 i 8 B B B 8 B

t d d d d d d f ss e e e e e e t t eeu t t t n

t n n n iut n n a a l qa a a a a r eet r r r r r RRS G G G G G G

~

l a

c

_ t c oi o

_ n i t

e er tt c

e t ct ae c ca c v c cx itl i r i i i l i el f mtl rp edt r a r a runa rna t c ul ec t ec t eea

_ t o t oc e ssn etti eti S oti eti et nor m nt m t vxt mxt mn epe umec umc l aa 0d ec a l uec a

ue l t l cot l at a ox irl oxxr ox r 0nor oor V LPA Veep V ep 1 at p Vtp Ve d

c c nc c c i i i i ai i d r r r r r

_ t t

_ e t t et ce e e S rd e e

_ T io m m am m u

m u

S uh u u f u rl l l E qt l l l U ee o o uo o o

) Q RM V V S v V V V

_ d E

' R

_ t n F W

- o c

E I n 5 o -

(

I L

E R

od -

33 l

l W ni ot m

a e

_ d t a m e pn 22 e - i i l

_ E F e a - e a 00 nh 6 t s S

_ L O rb - e tH e i o 34 oSC - cnd -

B o d oH e S Pi 55 i - A eal A A Y oe t el - t - - t on 1 S re1

_ T R et n m h e B h c: 1 1 ito 0 " TW0 A m i l o sn 1 ces00 s i B l - B

_ M uam ea l td end0 b al BW nnd - -

anl 8B netdB ancl E l oeB et nE M

_ l etl U orx h oe uh eB - roe 88 roee- h - o-S VAE SBW TCWE1 BCW11 TCSW1 SBC1

_ r

_ e r r rt z r

_ on i o o o e r t t t mn eo u

s mr a g n mr a

mr a

t p s a e "B i ae ae sm yo e

r en" t e i p en t e en t e SG P SG SG SC P

_ y r

.o

_ g me B B J A A at

_ xa - - - - -

E C, B B B C C

_ o

_ N 1 0 1 0 0

_ m 1 4 3 1 1

_ e 9 1 1

_ t 2 2 I 8 B B C C

t d d d d d f ss e e e e e eeu t t t t t i ut n n n n n l qa a a a a a eet r r r r r RRS G G G G G l l l a a a c c c c oi oi oi i tt tt tt er e c c c ct v ca ca ca ae i i r ir ir f mtl edt rp rp rp runa eea t t t ul ec e ssn et et et soti c nor epe mn ue mn ue mn ue vxt ec a

% f cot l t l t l t 0d a r irl ox ox ox 0nor u LPA Ve Ve Ve 1atp S c c c c cd i i i i di ecG

_ d r r r r e ertiE e t t e t t c e tttl R

_ S rd e e c e eda c nei

_ T i o m m ad m mnf a d e m m y

_ S uh u u f nu uar f nmumb

_ E qt l l ral l u r a gl o . ec

) U ee o o u o o S u uoco Q RM V V S V V S AV(t s

_ d E R

't n

o F

E W-c I 2

( L - - -

E ndA - m :200

_ 1 R oa1 o a s0225311

_ E F e i e0 tHB tl

- e S e

- d -

W d30O0333 l WWW0000 r s

_ L O rb c B tr - rol 1 eFFFFFFF end B

A Y o

oe d e pE W S o- -

er ea A

1 t et e1 W-A W-5544454 - - - - - - t ol aie

_ T R et n T18 hB 0 ae g0000000 WtW A m i l - - s B wl l 1 n- - - - - - - c uam

_ M l od m ebdB dzl 0 iEEEEEEE l ee M

_ l ea etl a b ul E ezeB pAAAAAAA ajn U orx h - ee ut e- eohB i - - - - - - - eni VAE SDWS S TSW1 FNSE P1111111 SIL rt r r r r on o o o e e t t t t rt mn a a a a on

. eo mr mr mr w t a ae ae

_ t p nd cl p sm yo en en a ene "A i e aom t e t e t e ae eou SG" SC SG SG MF RCP y

r

.g o

me at A A B F F xa - - - - -

EC C C C C C o

N 0 0 1 1 1 m 2 3 2 2 1 e . . . . .

t 1 1 2 5 5 I C C C C C

- t d f ss e eeu t iut n l qa a eet r RRS G s

t a r i no rop e l eip v a ttu

.i c i gt re hi cs edt eea t nicl e ep ssn siw nor epe i l t pn9 0 si p

cot ama/r i rl t al 5 of LPA S sp9f o e0 c10 n53

_ d a24 2

d rF -

e oWF S rd cI W

_ T io c I

_ S uh ah

_ E qt td

_ ) U ee nin

. Q RM I wa

_ d E R

t n F n E c I

_ ( L

_ E &

_ 1 R f

_ o ,t

_ F F e 2 n

_ i O rb n e

_ l l o d o ,ns A Y oe i 1 ot pr

_ T R et n t

_ A m i csmo

_ M u a m_ esop M l ea l aC p U

S orx VAE, el SC3S u

rt on s e t mn eo gr no tp ip sm yo pp iu SC PS y

r o

.o me at F xa W E C_ I o_

N.

_ m e

t

- I i

d EGG-SD-7_483;  ;

1 1

TECHNICAL EVALUATION REPORT ON THE' FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

, KANSAS' GAS'AND ELECTRIC COMPANY, l

WOLF CREEK GENERATING STATION, DOCKET NUMBER 50-482 ' H B. W. Brown J..D.'Mudlin i

i Published April 1987 1

1 Idaho National Engineering Laboratory EG&G Idaho, Inc. ,

Idaho Falls,-Idaho 83415 1 1

Prepared for:

i

. U.S. Nuclear Regulatory Commission  ;

Washington, D.C. 20555 i under DOE Contract No. DE-AC07-761001570 .

FIN No. D6022 (Project 5)-  !

/ /s m i  ! -

[ff'.

%t Jo 5 I .

4 ABSTRACT This report presents the results of the evaluation of the Wolf Creek Generating Station First 10-Year Interval Inservice Inspection (ISI) Program Plan through Revision 2, submitted December 11, 1985, including the requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical. The Wolf Creek Generating Station First j 10-Year Interval ISI Program Plan is evaluated in Section 2 of this report.

The ISI Program Plan is evaluated for (a) compliance with the appropriate 1 edition / addenda of Section XI, (b) acceptability of examination sample, (c) exclusion criteria, and (d) compliance with ISI-related commitments )

identified during the Nuclear Regulatory Commission (NRC) review before I granting an Operating License. The requests for relief from the ASME Code requirements which the Licensee has determined to be impractical for the first 10-year inspection interval are evaluated in Section 3 of this report. )

l t

I This work was funded under:

U.S. Nuclear Regulatory Commission FIN No. D6022, Project 5 Operating Reactor Licensing Issues Program, ,

Review of ISI for ASME Code Class 1, 2, and 3 Components j l

ii l 1

4

SUMMARY

The Licensee, Kansas Gas and Electric Company, has prepared the Wolf Creek Generating Station First 10-Year Interval inservice Inspection (ISI) Program Plan, Revision 2, to meet the requirements of the 1980 Edition, Winter 1981 Addenda (80W81) of the ASME Code Section XI except that'the extent of examination for Code Class 2 piping welds has been determined by the 1974 Edition through Summer 1975 Addenda (74S75), as. permitted by 10 CFR 50.55a(b). The first 10-Year inspection interval began September 3, 1985 and ends September 3, 1995.

The information in the Wolf Creek Generating Station First 10-Year Interval ISI Program Plan, through Revision 2, submitted December 11, 1985, was reviewed, including the requests for relief from the ASME Code Section XI l

requirements which the Licensee has determined to be impractical. As a result of this review, a Request for Additional Information (RAl) was prepared describing the information and/or clarification required from the' Licensee in order to complete the review.

Based on the review of the Wolf Creek Generating Station First 10-Year Interval ISI Program Plan, Revision 2, the Licensee'sLresponse to the NRC's RAI, the " Supplemental Weld Examinations for the Refueling Water Storage and Containment Spray Systems at Wolf Creek Generating Station, Unit 1" document, and the recommendations for the granting of relief from the ISI examination requirements that have been determined to be impractical, it has been concluded that the Wolf Creek Generating Station First 10-Year Interval ISI Program Plan, Revision 2, is acceptable and in compliance with 10 CFR 50.55a(g)(4).

iii

d 1,

4.

CONTENTS ABSTRACT................................................................. 11 1 1

SUMMARY

...............................................................'..iii .

1.

1NiR00uCTiON...........................................................i 1

2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN. . . . . . . . . . . . . . . . . . . . . . . 4 2.1 Do c ume n t s Ev al ua t ed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.2 Compliance with Code Requirements.................................. 5 2.2.1 Compli ance with Applicable Code Edi tions . . . . . . . . . . . . . . . . . . . . . . . 5 2.2.2 Acceptabil ity of the Examination Sampl e. . . . . . . . . . . . . . . . . . . . . . . . 5 2.2.3 Exclusion Criteria............................................. 5

, 2.2.4 Augmented Examination Commitments.............................. 6 2.3 Conclusions........................................................7 <

3. EVALUATION OF RELIEF REQUESTS......................................... 8 3.1 Class 1 Components................................................. 8 3.1.1 Reactor Pressure Vessel........................................ 8-3.1.1.1 Request for Relief H, Examination Category B-A, Item Bl.30, Reactor Pressure Ves Flange-to-Vessel We1d............................sel ........................... 8 3.1.1.2 Request for Relief 1, Examination Category B-D, item B3.90, Reactor Pressure V Nozzle-to-Vessel We1ds..........................essel ............................. 9 3.1.1.3 Request for Relief J. Examination Category B-A, 4

Item Bl.21, Reactor Pressure Vessel Pl ate Weld. . . . . . . . . . . . . . . .......................

. . . . . . . . . . Lower10Head-to-Do

. 3.1.1.4 Request for Relief K, Examination Category B-A, Item Bl.21, Reactor Pressure V Lower Head-to-Shell We1d..........................essel ............................ 11 3.1.1.5 Request for Relief L, Examination Category B-A, Item Bl.22, Reactor Pressure Vessel Lower Head Meridional Welds........(Withdrawn by the Licensee - 3/17/87)........ 13 3.1.1.6 Request for Relief 0, Examination Category B-A, Item Bl.40, Reactor Pressure Vesse Closure Head-to-Flange Weld..............................l... .................... 13 iv I o

_ _ _ _ J

l u

.: )

l 3.1.2 Pressurizer............................................. .......14- ~

3 .1 '. 2 .1 Request for. Relief F, Examinati.on Category B-F, .

Item B5.40, Pressurizer Nozzle ,to-Safe-End Welds. . . . . . . . . .14 J 3.1.2.2 Request for Relief N, Examination Category B-8, Item B2.11, Pressurizer Shell-to-Bottom. Head. Weld. . . . . . . . .16 -

l 3.1.3 Heat Exchangers and Steam Generators........................... 17 3.1.3.1 Request for Relief P, Examination Category B-B, Item B2.40, Steam Generator "B"~Tubesheet-to-Channel.-

Head Weld................................................. 17 3.1.4 Piping Pressure Boundary...................................... 18 3.1.4.1 Request for Relief G, Examination Category B-J, Item B9.31, Class 1 Branch Pipe Connection Welds.......... 19 j 3.1.5 Pump Pressure Boundary (No relief requests)- i 3.1.6 Valve Pressure Boundary (No relief requests) l 3.1.7 General.......................................................20 3.1.7.1 Request for' Relief' E, Examination Category 'F-A, . 1 Reactor Pressure Vessel Supports .

j (Withdrawn by the Licensee - 2/20/87) . . . . . . . . 20 3.2 Class 2 Components................................................'21 .

3.2.1 Pressure Vessels............................................... 21 J

3.2.1'.1 Request for Relief B, Examination Category C-A,'

Items C1.10, C1.20, and C1.30, Pressure Eetainin l 1

Steam Generator Vessel We1ds....................g- .......... 21 h

3.2.1.2 Request for Relief Q, Examination Category C-8,  ;

Item C2.21, Steam Generator "A" Feedwater '

Nozzl e- t o-Shell We1 d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 3.2.2 Piping......................................................... 24-3.2.2.1 Request for Relief A, Examination Category C-F, Item C5.21, Pressure Retainin Main Feed.ater System Welds.................g............................. 24 3.2.2.2 _ Request for Relief- C, Examination Category C-F, i Item C5.11, Pressure Retaining Reactor Ccolant l

Pump Seal Water Injection Line Welds...........e.......... 25 3.2.3 Pumps-(Noreliefrequests) l l'

V

3.2.4 Valves (No relief requests) 3.2.5 General (No relief requests) 3.3 C l a s s 3 C omp o n e n t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 8 3.3.1 Piping (No relief requests) 3.3.2 Pumps (No relief requests) 3.3.3 Valves (No relief requests) 3.3.4 General....................................................... 28 3.3.4.1 Request for Relief D, Examination Category D-A, Essential Service Water System Pump Supports

]

(Withdrawn by the Licensee - 2/20/87)........ 28  ;

i 3.4 Pressure Tests (No relief requests) )<

l 3.5 General........................................................... 28 f I

l 3.5.1 Ultrasonic Examination Techniques (No relief requests) i 3.5.2 Exempted Components (No relief requests) 3.5.3 0ther......................................................... 28 3.5.3.1 Request for Relief M, Class 1, 2, and 3, Piping Supports Requiring Examination per Subsection IWF......... 28 4.

CoNCtuStoN........................................................... 32 i 5.

REFERENCES........................................................... 34 i

i I

l 1

l vi

4 4

TECHNICAL EVALUATION REPORT ON THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

KANSAS GAS AND ELECTRIC COMPANY, WOLF CREEK GENERATING STATION, DOCKET-NUMBER 50-482-

1. INTRODUCTION <

l Throughout the service life of a water-cooled nuclear power facility, -l

. 10 CFR 50.55a(g)(4) (Reference 1) requires that components (including i l

supports) which 'are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class'2, and Class 3 meet the requirements, except the design and access provisions and the preservice f examination requirements, set forth in the ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," (Reference 2) to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requires that inservice examinations of. components and-system pressure tests conducted 'during the _ initial 120-month inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b)'on the date 12 months prior to the date of issuance of the operating license, subject to the limitations and modifications listed therein. The components.

(including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in l 10 CFR 50.55a(b) subject to the limitations and modifications listed therein. The Licensee, Kansas Gas and Electric Company, has prepared the Wolf Creek Generating Station First 10-Year Interval Inservice Inspection (ISI) Program Plan, Revision 2, to meet the requirements of the 1980 Edition, Winter 1981 Addenda (80W81) of the ASME Code Section XI except that the extent of examination for Class 2 piping welds has been determined by the 1974 Edition through Summer 1975 Addenda (74S75), as permitted by 10 CFR 50.55a(b). Based on the date of commercial operation, the first 10-year interval began September 3,1985 and ends September 3,1995.

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain.

i 1

__- = L

i

, Code examination requirements are impractical and requests relief.from them, the licensee shall submit information and justifications to the Nuclear Regulatory Commission (NRC) to support that determination.

i z

Pursuant to 10 CFR 50.55a(g)(6), the. Commission will evaluate the licensee's l determinations-under 10 CFR 50.55a(g)(5) that Code requirements are-impractical. The Commission may grant relief and may impose alternative 1 l requirements as it determines are authorized by law and will not endanger )

life or property or the common defense and security and are otherwise in the public interest, giving due consideration to the burden upon the licensee I that could result if the requirements were imposed on the facility.

The information in the Wolf Creek Generating Station First 10-Year Interval ISI Program Plan, through Revision 2 (Reference 3), submitted q December 11, 1985, was reviewed including the requests for relief from the '

ASME Code Section XI requirements which the Licensee has determined.to be impractical. The initial requests for relief were received in submittals.

dated December 11, 1985 (Reference 4) and December 13, 1985 (Reference 5). j Review was also completed on letters from the Licensee dated I

January 20, 1986 (Reference 6) and July 10, 1986 (Reference 7) regarding partial exemptions from the ASME Code Section XI requirements for snubber inspection. The review of the ISI Program Plan was performed using the Standard Review Plans of NUREG-0800 (Reference 8), Section 5.2.4, " Reactor Coolant Boundary Inservice Inspections and Testing," Section 5.4.2.2, " Steam Generator Tube Inservice Inspection," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components".

In a letter dated August 27, 1986'(Reference 9), the NRC requested additional information that was required in order to complete the review of

. the ISI Program Plan. The requested information was provided by the Licensee in the " Response to Request for Information Related to the

i. Inservice Inspection Program Plan" dated October 17, 1986 (Reference 10).

As a result of the Licensee's response .to the request for additional information and several telephone conference calls with the Licensee and the NRC staff, the Licensee provided further information in a submittal dated February 20, 1987 (Reference 11). In this submittal, the Licensee withdrew 2

C

' ft i f, a

~ two relief requests (D and E), revised five relief requests ((9 -F, G, H,' .i l

and L), and provided a copy'of a supplemental exami f atfon proha'm for'ije's a y RefuelingWaterStorageSystem,ChemicalVolumeardCon' trol $ystg/[ {

Containment Spray System. 'J j ,

, , {

1 />/ 1 l RequestforReliefLwassubsequentlywithdrawnby-the1.icensee'inakettsr dated March 17,1987 (Reference 12) and four new requests for relief. were received in a submittal dated March 20,1987(Referenc'e).3') . The new relief s

k4

,, y. , e d requests resulted from the inservice inspections, performed during the first- (,'

refueling outage at Wolf Creek Generating Station.. ,

9 The Wolf Creek Generating Station First 10-Year Interval,..ISI Program Plan is evaluated in Section 2 of this report. The ISI Program Plhn is evalua .6s , . . ,

3 A for (a) compliance with the appropriate edition / addenda of Section XI, ,\ ~

q /

(b) acceptability of examination sample, (c) exclusion criteria, and' s

%g'

{

(d) compliance with ISI-related commitments identified during the NRC's '

review before granting an Operating License. 1, 1

The requests for relief are evaluated in Section 3 of'this report. 'U ess) j otherwise stated, references to the Code refer to the ASME Code,Section XI, I 1980EditionincludingAddendathroughWinter19ql. Specific irfurvice test (IST) programs for pumps and valves are being evaluated in other reports.

) ")

1 o

s s

\

I i

,i 'i ,

l . l

, , .? j

. o ,a l q

' I 64 4 ;

ji(;,I <f _

( k [ f. /

o ,  !

7

/ ,.

t

. 3j q

T

, /, -

I 'i,,,

[ '

i s

2. ,

EVALUATION 0r INSERVICE INSPECTION PROGRAM PLAN

. I s .

$I This evaluation consistpd of a review of the applicable program documerds to determine whether or not they are in compliance with the Code requirements and any drense cdnditions pertinent to IS,1 activities.This section describes the su5aittals reviewed an0 the Fesults of the review.

l pE 1\f -

2.1 Docursnts Evaluated U

' /l Review has been completet on the following information provided by the

/ Licensee: i

' (a) Wolf Creek Generating Stailfon Fihst 10-Year Interval ISI t)rogram Plan, Revision 2,submittch'5ecember 11, 1985; (b) letter, dated Decembe 11, 1985, containing " Inservice Inspection Relief Requests for Wolf Creek Generating Station";

(c) Letter, dated December 13, 1985, containing " Inservice Inspection Relief Request /for Wolf r, reek Generating Station"; "

(d) Letter,;baiedJanuary 20,1986, " Partial Exemption to ASME.

Sectiort XI Requirements for Srkbbe(Inspection"; '

\ '

(e) Letter, dated July 10.' 1986, " Clarification on Partial Exemption to ASME Section XI P.9. retirements for Snubber Intpection";

(f) Letter, dated October 17, 1986, " Response to Request for Information Related to the Inservice inspectica Program Plan";

(9) Letter, dated February 20, 1987, containing reviserf and withdrawn relief requests and a document titled " Supplemental Weld Examinations for the Refueling liater Storage and Containment Spray Systems at Wolf Creek Generating Station, Unit 1";

I

\

4 e

\ o

(h) Letter, dated March 17, 1987, withdrawing Relief Request L for further evaluation by the Licensee; and (i) letter, dated March 20, 1987, submitting four new relief requests resulting from the inservice inspections performed during the first c!

refueling outage at Wolf Creek Generating Station.

2.2 Comoliance with Code Requirements f 2.2.1 Os11afge with Acolicable Code Editions I l

The Inservice Inspection Program Plan shall be based on the Code editions defined in 10 CFR 50.55a(b). Based on the Operating License date of l

March 11, 1985, the Code applicable to the first interval ISI program is the 1980 Edition with Addenda through Winter 1981. As stated in Section 1 1

of this report, the Licensee has prepared the Wolf Creek Generating i Station First 10-Year Interval ISI. Program Plan, Revision 2, to meet the  ;

requirements of the 1980 Edition, Winter 1981 Addenda of the Code except that, as required by 10 CFR 50.55a(b), the extent of examination for -

Class 2 piping has been determined by the 1974 Editien through Summer 1975 Addenda.

2.2.2 Acceptability of the Examination Samole l

Inservice volumetric, surface, and visual examinations shall be performed on ASME Code Class 1, 2, and 3 components and their supports using 1

sampling schedules described in Section XI of the ASME Code and 10 CFR 50.55a(b). Sample size and weld selection have been implemented in accordance with the Code and appear to be correct.

2.2.3 Lxclusion Criteria The criteria used to exclude components from examination shall be consistent with Paragraphs IWB-1220, IWC-1220, IWD-1220, and 10 CFR 50.55a(b). The exclusion criteria have been applied by the i

5 i\

4s

+

Licensee'in accordance with the Code as discussed in the' General Reference.

Text of the ISI Program Plan (Document No. 83A1692, Rev. 2, Section 3.2,  :

" Exemptions and Exceptions") and appear to be correct.

2.2.4 Acomented Examination Commitments The Licensee has stated, in the ISI Program Plan,'that the following augmented examinations are'being implemented during.the first 10-year inspection. interval: l l

(a) The weld selection for the High Pressure Coolant Injection System i on the Safety Injection Pump suction lines contain, at a minimum, a 7.5% representative sample of these welds. j (b) Augmented examinations per NUREG-0800, Section'3.6.1, "P1 ant Design )

1 i

for Protection Against Postulated Piping Failures in Fluid Systems l Outside Containment."

l (c) Augmented examinations per Regulatory Guide 1.14, " Reactor Coolant I

Pump Flywheel Integrity" (Reference 14).

, < (d) Examinations for the Reactor Pressure Vessel are in compliance with Paragraph 8 (Alternative Method) of Regulatory Guide 1.150,

" Ultrasonic Testing of Reactor Vessel Welds During Preservice and l

Inservice Examination" (Reference 15).

In addition, in the February 20, 1987 submittal of " Supplemental Weld Examination for the Refueling Water Storage.and Containment Spray Systems at Wolf Creek Generating Station Unit 1" . the Licensee committed to include 7.5% of the austenitic stainless steel or high alloy welds for piping in the Refueling Water Storage System, Chemical and Volume Control System, and the Containment Spray System.for. surface and volumetric examinations during ISI., The welds selected are in piping 4 inches and greater nominal pipe size with nominal wall thicknesses 3/8 inch and greater which had been previously exempted'from examination by IWC-1220. ASME Code Case N-408 was

,used as guidance in establishing the weld selection criteria.

1 l

6 l

2.3 Conclusions Based on the review of the documents listed above, it is concluded that the Wolf Creek Generating Station First 10-Year Interval ISI Program Plan, Revision 2, is acceptable and in compliance with 10 CFR 50.55a(g)(4). The  !

requests for relief from the ASME Code requirements which the Licensee has  !

determined to be impractical are evaluated in the following sections. i 1

l 1 \

\

l \

l i

7

3. EVALUATION OF RELIEF REQUESTS The requests for relief from the ASME Code requirements which the Licensee has determined to be impractical for the first 10-year inspection interval are evaluated in the following sections. '

3.1 Class 1 Comoonents 3.1.1 Reactor Pressure Vessel 3.1.1.1 Reouest for Relief H. Examination Cateoory B-A. Item B1.30.

Reactor Pressure Vessel Flance-to-Vessel Weld I

Code Requirement: Section XI, Table IWB 2500-1, Examination  !

Category B-A, Item B1.30 requires a 100% volumetric examination of the Reactor Pressure Vessel Shell-to-Flange weld as defined by Figure IWB-2500-4.  !

l Licensee's Code Relief Reouest: Relief is requested from  !

examining 100% of the Code-required volume of the Flange-to-Vessel Weld #1-RV-101-121.

Licensee's ProDosed Alternative Examination: None; the Code )

required volumetric examination will be completed to the maximum extent practical.

Licensee's Basis for Reauestina Relief: The parallel scan portion of the volumetric examination can only be performed i from the lower side of the weld due to the presence of the flange taper above the weld. Therefore, approximately 25% of the required weld volume will not be examined.

Evaluation: The Licensee's submittal has been reviewed and it has been concluded that, based on the vessel design, an acceptable percentage (approximately 75%) of the Code-required volumetric examination will be performed on the subject weld 8

g and that the Reactor Pressure Vessel would have to be redesigned and prefabricated in order to complete the remainder. Based on the limited Code examination of this weld and the full Code examination of other similar welds in the vessel, the integrity of the subject weld will be verified by sampling.

Conclusions:

Based on the above evaluation, it is concluded

. that the limited Section XI volumetric examination, along with the Code-required pressure test, provides 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, it is recommended that relief be granted as requested.

3.1.1.2 Reauest for Relief I. Examination Cateoory B-D. Item 83.90.

Reactor Pressure Vessel Nozzle-to-Vessel Welds Code Requirement: Section XI, Table IWB-2500-1, Examination Category B-D, Item B3.90 requires a 100% volumetric examination of the Reactor Pressure Vessel Nozzle-to-Vessel welds as defined by Figure IWB-2500-7.

Licensee's Code Relief Reouest: Relief is requested from examining 100% of the Code-required volume on the following 4 RPV Outlet Nozzle-to-Vessel welds:

WELD NUMBERS 1-RV-107-121-A 1-RV-107-121-B l-RV-107-121-C 1-RV-107-121-D Licensee's Proposed Alternative Examination: None; the Code required volumetric examination will be completed to the maximum extent practical.

9

i j

z 1

4 Licensee's Basis for Reauestino Relief: The Licensee states I that approximately 10% of the total weld volume for each of the I subject nozzles is obstructed by contact between the ,

examination head and the nozzle knuckle extending from the nozzle opening through the plane of the Reactor Pressure Vessel inner diameter.

l Evaluation: The Licensee's submittal has been reviewed and it <

has been concluded that, based on the nozzle design, an acceptable percentage (approximately 90%) of the Code-required volumetric examination will be performed on the subject welds and that these nozzles would have to be redesigned in order to complete the remainder. Based on the limited Code examination of these welds and the full Code examination of other similar  !

welds in the Reactor Pressure Vessel, the integrity of the j subject welds will be verified by sampling.

I

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examination, along with l the Code-required pressure test, provides 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 l

level of quality and safety. Therefore, it is recommended that relief be granted as requested.

3.1.1.3 Reauest for Relief J. Examination Cateoory B-A. Item B1.21.

Reactor pressure Vessel Lower Head-to-Dollar Plate Weld Code Reautrement.Section XI, Table. IWB-2500-1, Examination Category B-A, Item Bl.21 requires a 100% volumetric examination of the Reactor Pressure Vessel head welds as defined by Figure  !

IWB-2500-3.

Licensee's Code Relief Reauest: Relief is requested from L

i 1

I examining 100% of the Code-required volume of lower j head-to-dollar plate weld Number 1-RV-102-151. '

l Licensee's Procosed Alternative Examination: None; the Code )

required volumetric examination will be completed to the '

maximum extent practical, i

Licensee's Basis for Reauestina Relief: The Licensee reports that approximately 10% of the required weld volume of the l subject lower head-to-dollar plate weld can not be examined due to obstructions presented by the instrumentation nozzles.

Evaluation: The Licensee's submittal has been reviewed and it has been concluded that, based on the design of the Reactor

{

Pressure Vessel's lower head, an acceptable percentage l (approximately 90%) of the Code-required volumetric examination will be performed on the subject weld and that the lower head would have to be redesigned in order to complete the remainder. Baseo on the limited Code examination of this weld and other similar welds in the lower head, the integrity of the subject weld will be verified by sampling.

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examination, along with the Code-required pressure test, provides 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, it is recommended that relief be granted as requested.

3.1.1.4 Reauest for Relief K. Examination Cateaorv 8-A. Item 81.21.

Reactor Pressure Vessel lower Head-to-Shell Weld Code Requirement: Section XI, Table IWB-2500-1, Examination Category B-A, Item B1.21 requires a 100% volumetric examination 11

on the Reactor Pressure Vessel head welds-as defined by Figure IWB-2500-3.

Licensee's Code Relief Reauest: Relief is requested from examining 100*/. of the Code-required volume of lower L head-to-shell weld Number 1-RV-101-141.

Licensee's Proposed Alternative Examination: A 45' l

longitudinal wave examination will be performed _in lieu of the 60* shear wave examination.

Licensee's Basis for Recuestino Relief: The perpendicular examination (scanning down) for the 60* ultrasonic shear wave examination cannot be performed because the outside diameter (0.D.) surface taper geometry limits ultrasonic head contact on the subject lower head-to-shell weld. A 45' longitudinal wave examination will be performed. in lieu of the 60* shear wave examination. Approximately 10% of the Code-required weld volume will not be examined.

Evaluation: The Licensee's submittal.has been reviewed and it has been concluded that, based on the design of the_ subject-lower head-to-shell weld, an acceptable percentage l (approximately 90'/.) of the Code-required volumetric examination will be performed and that the_ weld would have to be redesigned in order to complete the remainder. Based on'the limited Code examination of this weld and the full Code examination of other similar welds, the integrity of the- subject weld will be verified by sampling.

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examination, along with the alternative 45' longitudinal wave examination and the Code-required pressure test, provides an acceptable level of inservice structural integrity and that compliance with the specific requirements of Section XI would result in hardship or.

l 12

l 8

l i .

unusual difficulties without a compensating increase in the level of quality and safety. Therefore, it is recommended that relief be granted as requested.

I 3.1.1.5 ftfauest for Relief L. Examination Cateoory B-A. Item Bl.22.

Reactor Pressure Vessel Lower Head Meridional Welds MII: In the letter dated March 17, 1987, the Licensee l

withdrew Request for Relief L for further evaluation.

3.1.1.6 Reauest for Relief 0. Examination Cateaory B-A. Item Bl.40.

Reactor Pressure Vessel Closure Head-to-Flance Weld 1 1 1

1 f Code Requirement: Section XI, Table IWB-2500-1, Examination Category B-A, Item Bl.40 requires a 100% surface and volumetric 1 examination of the RPV Closure Head-to-Flange weld as defined 'j by Figure IWB-2500-5.

Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume of Closure Head-to-Flange Weld CH-101-101.

Licensee's Proposed Alternative Examination: None; the Code i required volumetric examination will be completed to the maximum extent practical.  !

Licensee's Basis for Reauestina Relief: The Licensee reports that three lifting lugs obstruct 42% of the examination volume at the lug locations. In the areas not obstructed by the lugs, 4.3% of the examination volume is obstructed by the head flange. The length of the weld obstructed by' the lugs is 4.4%. A total of 6% of the Code-required weld volume cannot be examined. The Licensee also notes that the circumferential scan (parallel to the weld axis), as well as the surface examinations, were unaffected by these obstructions.

L 13

Evaluation: The Licensee's submittal has been reviewed and it has been concluded that, based on the vessel design, a significant percentage (approximately 94%) of the Code-required volumetric examination will be performed on the subject weld and that the Reactor Pressure Vessel Closure Head would have to be redesigned and prefabricated in. order to complete .the remainder. Based on the limited Code examination of this weld and other similar welds .in the vessel, the integrity of. the subject weld will be verified by sampling.

Conclusions:

Based on the above evaluation, it is concluded that a significant portion of :he Section XI volumetric examination will be completed and that this examination,-along with the Code-required surface examination and the VT-2 examination during the pressure test, provides an acceptable l 1evel 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, it is recommended that relief be granted as requested.

3.1.2 Pressurizer 3.1.2.1 Reouest for Relief F. Examination Cateaory B-F. Item B5.40.

Pressurizer Nozzle-to-Safe-End Welds Code Requirement: Section XI, Table IWB-2500-1, Examination l Category B-F, Item B5.40 requires both.100% volumetric and surface examinations on the Pressurizer nozzle-to-safe-end welds as defined by Figure IWB-2500-8.

Licensee's Code Relief Reauest: Relief is-requested from-examining 100% of the Code-required volume of the following six Pressurizer nozzle-to-safe-end welds:

14

e Weld Number Description , Percent not Examined 1-TBB03-4-W Relief Nozzle to 20% - 60* axial scan Safe-end Weld 45% - 45' axial scan 1-TBB03-3-A-W Safety Nozzle to 50% - 60* axial scan Safe-end Weld 35% - 45' axial scan Weld Number __, Description Percent not Examined 1-TBB03-1-W Surge Nozzle to 15% - 60* axial scan Safe-end Weld 40% - 45' axial scan

. 1-TBB03-3-B-W Safety Nozzle to 55% - 60* axial scan Safe-end Weld 40% - 45* axial scan l

l l-TBB03-2 W Spray Nozzle to 10% - 60* axial scan j l Safe-end Weld 407. - 45' axial scan '

l l-TBB03-3-C-W Safety Nozzle to 20% - 60' axial scan l l Safe-end Weld 40% - 45' axial scan )

I l

I i

licensee's Procosed Alternative Examination: None; the Code I required volumetric examination will be corpleted to the maximum extent practical.

{

Licensee's Basis for Reouestino Relief: The Licensee reports that component surface undulations restrict search unit l

movement and the metal structure of inconel buttering inhibit i

1 shear wave transmission. The approximate loss of volumetric examination coverage is listed in the above table.

Evaluation: The Licensee's submittal has been reviewed and it has been concluded that, based on the reported surface condition (undulations) of the subject components and the inhibited shear wave transmission caused by the inconel buttering, a significant percentage of the Code-required volumetric examination will be performed. It is also noted that the percentage of the Code-required volumetric examination which cannot be completed is consistent with that reported during the preservice examinations. However, the Licensee l

should continue to monitor the development of new or improved examination techniques and, as improvements in these areas are 15

i

. 1 e

achieved, incorporate any enhanced techniques in the ISI program plan for the ccmponents or welds which received a limited examination.

1

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examination, along with l the Code-required surface examination and pressure test, provides an acceptable level of inservice structural integrity and that compliance with the ::pecific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, it is recommended that relief be granted as requested. I 3.1.2.2 Reouest for Relief N. Examination Cateaory B-B. Item B2.11.

Pressurizer Shell-to-Bottom Head Weld j Code Requirement: Section XI, Table IWB-2500-1, Examination l Category B-B, Item B2.11 requires a 100% volumetric examination of the Pressurizer Shell-to-Head Welds as defined by Figure IWB-2500-1.

, licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume of Pressurizer Shell-to-Bottom Head Weld TBB03-Circum-5-W.

l Licensee's Proposed Alternative Examination: None; the Code required volumetric examination will be completed to the maximum extent practical.

Licensee's Basis for Reouestino Relief: The Licensee reports that, on the bottom head side of the weld, the support skirt to bottom head weld obstructs perpendicular scanning with 2.5%

loss of volume in the 45' angle beam scan and 19.5% loss of l volume in the 60* angle beam scan. On the shell side, l integrally welded lugs and instrumentation nozzles interfere 16

- with perpendicular scanning with 6% loss of volume. The Licensee also reports that the circumferential scan (parallel to weld axis) is unaffected.

Evaluation: The Licensee's submittal has been reviewed and it has been concluded that, based on the Pressurizer design, an acceptable percentage of the Code-required volumetric-examination will be. performed on the subject weld and that the Pressurizer would have to be redesigned and prefabricated in order to complete the remainder. Based on the limited Code examination of this weld and other similar welds in the vessel,. j 1

the integrity of the subject weld will be verified by sampling.

J l

Conclusions:

Based on the above evaluation, it is concluded j that the limited Section XI volumetric examination, along with the Code-required pressure test, provides an acceptable level of inservice structural integrity and that compliance with the specific requirements of Section XI would result in hardship or i I

unusual difficulties without a compensating increase in the level of quality and safety. Therefore, it is recommended that' relief be granted as requested.

3.1.3 Heat Exchancers and Steam Generators j l

l 3.1.3.1 Reauest for Relief P. Examination Cateaory B-B. Item B2.40. 1

_ Steam Generator "B" Tubesheet-to-Channel Head Weld .

I Code Requirement: Section XI, Table IWS-2500-1, Examination  !

Category B-8, Item 82.40 requires a 100% volumetric examination of the Steam Generator Tubesheet-to-Channel Head Weld as defin'ad by Figure IWB-2500-6.

Licensee's Code Relief Reouest: Relief is requested from examining 100% of the Code-required volume of Steam Generator-

"B" Tubesheet-to-Channel Head Weld EBB 01B-Seam-1-W.

h .

17 ,

i i'8 4

Licensee's Proposed Alternative Examination: None; the Code required volumetric examination will be completed to the maximum extent practical. l l Licensee's Basis for Recuestina Relief: The Licensee states that volumetric examination of the subject weld from the )

tubesheet side of .the weld is 22.4% obstructed by four supports. The 45' angle beam examination is 9.3% ,

I obstructed by' design of the component and the 60' angle beam examination is' obstructed 33.4% by the design.of the component. Insufficient base metal'.is provided by the design I to perform complete angle beam examinations. The Licensee has j l

l calculated the total . loss as 16.7% of the weld and required i f volume during perpendicular scanning.

Evaluation: The Licensee's submittal'has been reviewed and it has been concluded that, based on the vessel design, an j acceptable percentage (approximately 83%) of the Code-required volumetric examination will be performed on the subject weld and that the Steam Generator'would have to be redesigned and prefabricated in order to complete the remainder. )

Conclusions:

Based on the above evaluation,.it is concluded l that a significant portion'of the Section XI volumetric examination has been completed'and that this examination, along with the Code-required pressure test, provides an acceptable j level of inservice st'ructural integrity and th'at compliance with the specific requirements of Section XI would result in i hardship or unusual difficulties without a compensating i increase in the level of quality and safety. Therefore, it is  ;

recommended that relief be granted as requested. 'l 3.1.4 Pioino Pressure Boundary I 18 l

3.1.4.1 Reouest for Relief G. Examination Catecorv B-J. Item B9.31.

Class 1 Branch Pipe Connection Welds Code Requirement: Section XI, Table IWB-2500-1, Examination Category B-J, Item B9.31 requires both 100% volumetric and surface examinations on Class 1 branch connection welds 4 inch and larger nominal pipe size as defined by Figures IWB-2500-9,

-10, and -11.

Licensee's Code Relief Reouest: Relief is requested from examining 100% of the Code-required volume of the following 2 branch connection welds:

1 Volume Weld Number Sile Unexaminable 188-01-S302-3 6" 55%

IBB-01-S402-3 14" 10%

Licensee's Proposed Alternative Examination: None; the Code required volumetric examination will be completed to the maximum extent practical. {

I l

Licensee's Basis for Reouestino Relief: The Licensee reports that due to the materials of construction (austenitic) and the design and fabrication geometry of corner type branch connections, it is concluded that meaningful examination by ultrasonic methods is not feasible and that no other practical volumetric method is available. In addition to the Code-required surface examination, VT-2 examinations for leakage will be conducted in accordance with IWA-5240 during the leakage test specified under IWB-5221.

Evaluation: The Licensee's submittal, including the figures showing the design of the corner type branch connections, has been reviewed and it has been concluded that, based on the 19

i i

design of the subject components and the materials of fabrication, a significant percentage (45% and 90%) of the Code-required volumetric examination will be performed. I However, the Licensee should continue to monitor the development of new or improved examination techniques for I branch connections and, as improvements in these areas are j achieved, incorporate any enhanced techniques in the ISI-Program P1an. i

Conclusions:

Based on the above evaluation, it is concluded j that the limited Section XI volumetric examination, along with the Code-required. surface examination and the VT-2. examination during the pressure test, provides 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 1evel of quality and safety. Therefore, it is recommended that l

relief be granted as requested.

The Licensee should continue to monitor the development of new or improved examination techniques. As improvements'in.these areas are achieved, these enhanced techniques should be made a '

part of the inservice examination requirements for the components or welds which received a limited examination.

3.1.5 Pumo Pressure Boundary (No relief requests) 3.1.6 Valve Pressure Boundary (No relief requests)

. 3.1.7 General 3.1.7.1 Reouest for Relief E. Examination Cateaory F-A. Visual-(VT-3)

Examination of Reactor Pressure Vessel Sucoorts l NOTE: NUREG-0881 (Reference 16) states that for ISI the l Licensee should incorporate remote visual inspection devices which will allow the Code-required VT-3 20

i j

examinations to be part of the ISI program. Therefore, in a letter dated February 20, 1987, the Licensee ';

withdrew Request for Relief E and is evaluating the possibility of performing the Code-required VT-3 '

examination remotely with optical aids.

3' 2 Class 2 Comoonents i

. 3.2.1 Pressure Vessels 3.2.1.1 Reauest for Relief B. Examination Cateaory C- A ' Items C1.10.

C1'.20. and C1.30. Pressure Retainino Steam Generator Vessel Welds j Code Requirement: Section XI, Table IWC-2500-1, Examination Category C-A, Items C1.10, C1.20, and C1.30 require a 100%

volumetric examination of pressure retaining welds in Class 2 )1 pressure vessels as defined by Figures IWC-2300-1 and j IWC-2500-2.

licensee's Code Relief Recuest: Relief is requested from l examining 100% of the Code-required volume of the following Class 2 Steam Generator Vessel welds:

I Weld Number Description Basis for Relief 1-EBB 01A- Tube Sheet Flange obstruction limiting scan SEAM-2-W -to- length.on tube sheet side. Three Stub Barrel latches, instrumentation, nozzle and I.D. plate obstructing scan j path on stub barrel side. 5% i

, loss of volume coverage at j 60* and 45*.

1-EBB 01A- Transition Cone Four instrumentation nozzles, two SEAM-6-W -to- lugs, gauges and a feedwater Shell Section C nozzle obstructing scan path.

5% loss of volume coverage at 60' scan angle and 10% at a  :

45' scan angle.

1-EBB 01A- Shell Section D Loss of transducer contact due to ,

SEAM-8-W -to- transition section, lug and gauge  ;

Top Head obstructions. 10% loss of volume coverage.

21 u________._______.-___. ._

s (continued) .i Weld Number Description Basis for Relief

, 1-EBB 01A- Shell Section B Loss of transducer contact due to l SEAM-5-W -to- transition section and two  ;

Transition Cone gauges. 10% loss of volume at l 60* and 5% loss of volume at 0*. i

' ~

1-EBB 01A- Stub Barrel loss of transducer contact due to SEAM-3-W -to- transition section and two L Shell Section A gauges. 10% loss of volume 1 1

coverage.

1 Licensee's Prooosed Alternative Examination: None; the Code j required volumetric examination will be completed to the I maximum extent practical.

'l Licensee's Basis'for Reauestina Relief: As reported in the j above table, lugs, gauges, and nozzles on the steam generators J

obstruct part of the Class 2 welds requiring Section XI examinations.

Evaluation: The Licensee's submittal has been reviewed and it has been concluded that the volumetric examination of the i

subject welds to the extent required by the Code is impractical I because of the design of the steam generators. A large portion (90 to 95%) of the inservice examination will be performed as required by the Code. Failure to perform a 100% inservice examination of these welds will not significantly affect the i assurance of the structural integrity..

1

Conclusions:

Based on the above evaluation, it has been concluded that the limited Section XI ultrasonic examination and the hydrostatic test provide 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 l level of quality and safety. Therefore, it is recommended that '

relief be granted as requested.

22

3.2.1.2 Reauest for Relief 0. Examination Cateaory C-B. Item C2.21.

Steam Generator "A" Feedwater Nozzle-to-Shell' Weld f;ede Requirement: Section XI, Table IWC-2500-1, Examination Category C-B, Item C2.21 requires a 100% surface and volumetric.

examination of Class 2 pressure retaining nozzle welds in vessels as defined by Figure IWC-2500-4.

i Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required-volume of Steam Generator "A" Feedwater Nozzle-to-Shell Weld EBB 01A-11-W.  !

Licensee's Procosed Alternative Examination: None;.the Code.. )

required volumetric examination will be completed .to the-maximum extent practical. The Licensee also states that a l O' ultrasonic examination was performed at the time of ISI j examination to reduce the chance of missing' a reflector I parallel to the initial required scan.

Licensee's Basis for Reauestina Relief: Because of forging i geometry, the examination of the weld and required volume can only be performed from one beam path-direction. An area of the examination surface is contoured such that the search unit-loses contact with the examination surface. The loss is 2.5%

of the weld and required volume in one direction. Weld geometry precludes examination from the opposite direction in

. its entirety. The Code-required surface examination has been.

performed.

Evaluation: The Licensee's submittal has been reviewed and it has been concluded that, based on the subject Steam Generator Nozzle design, a reasonable percentage of the Code-required.

]

volumetric examination has been performed on the' subject weld and the Steam Generator Nozzle would have to be redesigned and.

prefabricated in order to complete the remainder.

23

Based on the above evaluation, it is concluded

Conclusions:

that the limited Section XI volumetric examination, along with the Code-required pressure test, provides 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 increa'se in the-level of quality and safety. Therefore, it is recommended that-relief be granted as requested.

3.2.2 Pioina 3.2.2.1 Recusst for Relief Ac Examination Cateaory C-F. Item C5.21.

Pressure Retainina Main Feedwater System Welds Code Requirement: Section XI, Table IWC-2500-1, Examination Category C-F, Item C5.21 requires both 100% volumetric and surface examinations on Class 2 pressure retaining piping welds with greater than 1/2 inch nominal wall thicknesses as defined by Figure IWC-2500-7.

! Licensee's Code Relief Reauest: Relief is requested from l \

l examining 100% of the Code-required volume of. each of the following seven welds:

l l ' Weld Number Description Basis for Relief 1-AE-05-FW302 14" Valves Valve geometry and 1-AE-05-F020 -to- sockolet obstruction 1-AE-04-F020 14" Pipes affects scan path.

1-AE-04-F005 5% loss of volume coverage.

1-AE-04-F033 4" Elbows - Valve geometry obstructs 1-AE-05-F031 -to- scan path resulting in 1-AE-04-F031 4" Valves loss of transducer contact on:the elbow l inner radius, 10% loss of volume coverage.

24

Licensee's Proposed Alternative Examination: None; the Code required volumetric examination will be completed to the maximum extent practical.

Licensee's Basis for Reauestina Relief: As reported in the above table, the design of the Class 2 Main Feedwater system has welded joints, such as component-to-pipe and fitting-to-component, which physically obstruct all or part of the required Section XI examinations from the fitting or component side of the weld.

Evaluation: The Licensee's submittal has been reviewed and it has been concluded that the volumetric examination of the subject welds, to the extent required by the Code, is.

impractical because of the design of the subject fittings

and/or components. A large portion (90 to 95%) of the inservice examination, as required by the Code, will be l

performed. Failure to perform a 100% inservice examination of these welds will not significantly affect the assurance of the j structural integrity.

Conclusions:

Based on the above evaluation, it has been concluded that the limited Section XI ultrasonic examination and the hydrostatic test provide 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

- 1svel of quality and safety. Therefore, it is recommended that relief be granted as requested.

3.2.2.2 Reauest for Relief C. Examination Cateaory C-F. Item C5.11.

Pressure Retainino Reactor Coolant pumo Seal Water Iniection Line Welds Code Requirement: Section XI, Table IWC-2500-1, Examination Category C-F, Item C5.11 requires a 100% surface examination of 25

_ - _ ___A

Class 2 pressure retaining welds with 1/2. inch or less nominal wall thicknesses as defined by Figure IWC-2500-7.  !

NOTE: Although the ASME Code Section XI does not require a volumetric examination of these welds, the Licensee. committed to perform an augmented volumetric examination per NUREG-0800,:

Section 3.6.1.

i k

Licensee's Code Relief Reauest: Relief is requested from

, performing the augmented volumetric examination'of the following small diameter,1/2 inch or less wall thickness l welds-Pumo A. Seal Water Injection line Welds Component I.D. Comoonent Weld Description i

1-BG-09-W686 2" x 1 1/2" Reducer to 1 1/2" Pipe 1-BG-09-FW881 1 1/2" Pipe to Valve 1-BG-09-FW882 Valve to 1 1/2" Pipe .

1-BG-09-W779 1 1/2 Pipe to 2" x 1 1/2" Reducer j Pumo B. Seal Water Injection Line Welds Comoonent I.D. Comoonent Weld Description 1-BG-09-W814 2" x 1 1/2" Reducer to 1 1/2" Pipe 1-BG-09-FW875 1 1/2" Pipe to Valve 1-BG-09-FW876 Valve to 1 1/2" Pipe 1-BG-09-W696 1 1/2" Pipe to 2" x 1 1/2" Reducer Pumo C. Seal Water Iniection Line Welds ,

Comoonent I.D. Comoonent Weld Description 1-BG-09-W806 2" x 1 1/2" Reducer to 1 1/2" Pipe 1 1/2" Pipe to Valve 1-BG-09-FW877 1-BG-09-FW878 Valve to 1 1/2" Pipe 1-BG-09-W807 1 1/2" Pipe to 2" x 1 1/2" Reducer Pumo D. Seal Water Injection line Welds Comoonent I.D. Comoonent Welf Description 1-BG-09-W790 2" x 1 1/2" Reducer to 1 1/2" Pipe 1-BG-09-FW879 1 1/2" Pipe to Valve 1-BG-09-FW880 Valve to 1 1/2" Pipe 1-BG-09-W859 1 1/2" Pipe to 2" x 1 1/2" Reducer 26

o 1

Licensee's Prooosed Alternative Examination: None licensee's Basis for Reauestino Relief: The Licensee states l that a meaningful augmented volumetric examination cannot be .

performed on the subject small diameter (1 1/2 inches or less) pipe-to-component welds due to a combination of the small pipe  !

1 diameter and the minimum wall thickness. The Licensee has also j stated that the Code-required surface examination (liquid j penetrant) will be performed.

4 Evaluation: The licensee's submittal has been reviewed and it has been concluded that, as the Licensee has stated, the i

volumetric examination of the subject welds is impractical  ;

because of the small pipe diameter and the thin wall. The l Code-required surface examination and the hydrostatic test provide an acceptable level of structural integrity. However,- )

the Licensee should continue to monitor the development of new or improved examination techniques for the subject welds and, as improvements in these areas are achieved, incorporate any enhanced techniques in the ISI program plan.

Conclusions:

Based on the above evaluation, it is concluded that the Code-required surface examination and the pressure test provide an acceptable level of inservice structural integrity. Therefore, it is recommended that relief from the augmented volumetric examination be granted as requested.

3.2.3 Pumos (No relief requests) l 3.2.4 Valves (No relief requests) l 3.2.5 General (No relief requests) l 27

3.3 Class 3 Components 3.3.1 Pioino (No relief requests) 3.3.2 Pumos (No relief requests) 3.3.3 Valves (No relief requests) 3.3.4 General 4

3.3.4.1 Recuest' for Relief D. Exam'ination Cateoory D-A. Visual (VT-3)

Examination of Essential Service Water System Pumo Supports l

NOTE: NUREG-0881 (Reference 16) states that for ISI the Licensee should incorporate remote visual inspection devices which will- allow the Code-required VT-3 examinations to be part of the ISI program. Therefore, in a letter dated February 20, 1987, the Licensee withdrew Request for Relief 2) and is evaluating the possibility of performing the Code-required VT-3 examination remotely with optical aids.

3.4 Pressure Tests (No relief requests) l 3.5 General l

l 3.5.1 Ultrasonic Examination Technioues (No relief requests) l l 3.5.2 EKgented Components (No relief requests) 1 .

3.5.3 Other 3.5.3.1 Recuest for Relief M. Class 1. 2. and 3. Pioino Sucoorts Reouirino Examination oer Subsection IWF l

Code Requirement: Section XI, Article IWF-2510 requires that:

(a) Component supports selected for examination shall be the supports of those components that are required to be examined 28

under IWB, IWC, IWD, and IWE during the first inspection interval. (b) For multiple components within a system of similar design, function, and service, the supports of only one q of the multiple components are required to be examined.

Article IWF-2430 requires that: (a) When the results of  ;

examinations require. corrective measures in accordance with the provisions of IWF-3000, the component supports immediately adjacent to those requiring corrective action shall be examined. Also, the examinations shall be extended to include )

additional supports equal in number and similar in type, design, and function to those initially examined during the l

inspection. (b) When these additional examinations require

]

corrective measures in accordance with the provisions of. 1 IWF-3000, the remaining component supports within the system of the same type, design, and function as in (a) above shall be i examined.

l Licensee's Code Relief Reauest: Relief is requested from l utilizing Articles IWF-2510 and IWF-2430 for the selection of 1 Class 1, Class 2, and Class 3 supports to be examined for ISI.

Licensee's Procosed Alternative Examination: The Iicensee proposes a statistical sampling plan with a 95/90 criteria for selection of pipe supports.

Licensee's Basis for Reauestino Relief: The Licensee states i

, that the above proposed alternative will provide a 95%

confidence that a population containing 10*,or more unacceptable assemblies will be detected and that the proposed <

alternative to the requirements of ASME Section XI, Subsection IWF, provides an acceptable level of quality and safety. In addition, it is reported that the above proposed I alternative will reduce overall radiation exposure to plant-personnel during the ISI examinations, l l

l 29

__ _A

l

~

o Evaluation: 10 CFR 50.55a(a)(3) allows alternatives to the-requirements of Section XI, provided the Licensee demonstrates that: (1) The proposed alternatives would provide an I acceptable level of quality and safety, or (2) compliance with the specified requirements of Section XI would result in hardship or unusual difficulties without a compensating. :l increase in the level of quality and safety.

Section XI, Subsection IWF is based on examination of supports l of those non-exempt components that are required to be. examined by volumetric, surface, or visual (VT-1 or VT-3) examination methods as required by Subsections IWB, IWC, and IWD. Using the proposed alternative, the selection of piping support )

assemblies for examination is based on the requirements 'of sample plans developed to identify generic and isolated component support failures, coupled with an exemption from examination for completely inaccessible supports, and supports '

for one inch and smaller diameter piping. The propased statistical sampling plan is base'd not only on a population that includes all supports Tequired to be examined by Section XI, but all non-exempt supports on components within the Section XI boundaries not required to be examined under IWB, IWC, and IWD.

l Therefore, generic component support failures which would be found under examinations as required by Subsection IWF should

, also be found under the statistical sampling plan proposed by the Licensee. In addition, the statistical performance criteria provides a 95% confidence that populations containing 10% or more unacceptable. isolated failures will be detected (95/90 criteria). Article IWF-2510 provides no such determination for isolated failures for supports not required to be examined.

30

' \ ',-

/

em y( ,

1

. /. i

Conclusions:

Based on the above evaluation, il is conci ded that the Licensee's proposed alternative for\th$selectionof ,)

si Class 1, Class 2, and Class 3 supports to be exam,hed provides y an acceptable level of quality and safety as,it m9kcs or '!

/

exceeds the Code-requirements. Therefore, it is ry ommanded ')

thatreliefbegrantedshrequested. +

r,1

<: e

{

. o h

~ , ,

\

{, -

t '- , j< i l

$, I i i

I . #, t

]

li, .

'/ < I, , ,

( f.;

r .

,. /

t

). i 7

b  !

, e t s

6l fi.I i

i

.f .

f i .

,.. q

\ )

/ ,. /; ',u.,' ,

• ' \

.J

[ (

,r

, . ),

,1 'l , ,l . ' -rj.

, ,( L ,,

s ' \ \

k f \.

l I 4I. l

, _f ')i, l' I,

, ,/ _'/ I '.

I '

' l_ ' '

. (.

\

f' .

1

's 31 >

I

$1 k'

i

M -

/<'f"

'f/ g-j r ,

a 4. CONCLUSION S ,

Pursuant to 10 CFR 50.55a(g)(6), it has been determined that certain Section XI[ required inservice examinations ,

are impractical. In all cases the Licensee has demonstrated that q'ther the proposed alternatives would  ;

provice an acceptable level of quality and safety or that compliance with l the' requirements would result in hardships or unu'sual difficulties without a J q

o

.T compensating increase in the level of quality and safety.  ;

! o

^

This technical saluation has not identified any practical method by which the existing Wolf Creek Generating Station can meet all the specific i inservice inspection requirements of Section XI of the ASME Code. Requiring ,

.r compliance with all the exact Section XI required inspec'tions would require .

I redesign of'a significant number of plant systems, sufficient replacement I

components ,to be obtained, installation of the new components, and a i g<

baselineerambptionofthesecomponents. Examples of components that would require redesign'to meet the specific inservice examination provisions are:

the rpctor prdssure vessel, the steam generator, and a number of the piping .)

and omponent support systems. Even Nter the redesign efforts, complete compiLance with the Section XI examination requirements.dprobably could not be achieved. Therefore, it is concluded that the public. interest is not i served by imposing certain provisions of Sectinn XI of the ASME Code that I

chave been determined to be impractical. PurstnSt to 10 CFR 50.55a(g)(6),

relief is allowed from these requirements which are impractical to implemen The development of new or imprcved examination techniques will continue to L

, be\ monitored. As improvements;in these area.3 a n achieved, the NRC may  !

r$ quire 't nat these techniques be incorporated in. the next inspection f

interval ISI program plan examnation pequirennts.

Based on the review of the Wolf Creek Generating Station First 10-Year (r Interval intervice Inspection Program Plan, Revision 2, the Licensee's ,

response to tha NRC's Request for Additional Information, and the 3 recommendat. ions for the gran{ing of relief from the ISI examination requirements that have been determined to be impractical, it has been

( \

3,2 q l

Q i

c:ncluded that the Wolf Creek Genera!ing Station First 10 Year Interval , ,

InserviceInspectionProgramPlan,kevision2isacceptableandin 5

compliance with 10 CFR 50.55a(g)(4). -

I i

\ / ,

l l- ,

I i ';

i l

f i s

4 k ' 4

, /

l 1

1

'5 l

1 l ,

i r

O f j

i F,

33 y 1 ,

L ' '5

j

____. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . 1-

s.

5. REFERENCES.

1. Code of Federal Regulations, Volume 10, Part. 50.

2. American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Division 1:

1980 Edition through Winter 1981 Addenda 1974 Edition through Summer 1975 Addenda

3. " Wolf Creek Generating Station First 10-Year Interval Inservice

, Inspection Program Plan", Revision 2, submitted December 11, 1985.

1

4. Letter, G.L. Koester (Kansas Gas and Electric Company (KG&E)] to H.R. Denton (NRC), " Inservice Inspection Relief Requests for Wolf Creek Generating Station," dated December 11, 1985.

5. Letter, G.L. Koester (KG&E) to H.R. Denton (NRC), " Inservice Inspection Relief Request for Wolf Creek Generating Station," dated December 13, 1985.

6. Letter, G.L. Koester (KG&E) to H.R. Denton (NRC), " Partial Exemption to ASME Section XI Requirements for Snubber Inspection," dated January 20, 1986.

7. Letter, G.L. Koester (KG&E) to H.R. Denton (NRC), " Clarification on Partial Exemption to ASME Section XI Requirements for Snubber Inspection," dated July 10, 1986.

8. NUREG-0800, Standard Review Plans, Section 3.6.1, " Plant Design for Protection Against Postulated Piping Failures'in Fluid Systems Outside Containment", Section 5.2.4, " Reactor Coolant Boundary Inservice Inspection and Testing", Section 5.4.2.2, " Steam Generator Tube Inservice Inspection", and Section 6.6, " Inservice Inspection of. Class 2 and 3 Components," July 1981.

i 34

____-__________________a_____. sw

}

,, ]1

~

9. Letter, P.W O'Connor (NRC) to G.L. Koester (KG&E), " Request'for l Additional Information on the First 10-Year Interval Inservice Inspection Program Plan," dated August' 27,1986.

10. Letter, G.L. Koester (KG&E) to H.R. Denton (NRC), " Response to Request 3 for Information Related to the Inservice Inspection Program Plan," dated- 1 October 17, 1986.

11. Letter, dated February 20, 1987, J.A. Bailey (KG&E)'to Document. Control l (NRC), containing revised and withdrawn relief requests and a copy of

" Supplemental Weld Examinations for the Refueling Water Storage and Containment Spray Systems at Wolf Creek Generating Station, Unit 1."

J

)

12. Letter, dated March 17, 1987, B.D. Withers (KG&E) to Document Control (NRC), withdrawing Relief Request L for further evaluation by the i Licensee.

13. Letter, dated March 20, 1987, B.D. Withers.(KG&E) to Document Control (NRC), submitting four new requests for relief as identified during inservice inspection performed during the first refueling outage at Wolf Creek Generating Station.

14. Regulatory Guide 1.14, " Reactor Coolant Pump Flywheel Integrity," k Revision 1, dated August 1975.

15. Regulatory Guide 1.150, " Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations", Revision 1, dated February 1983.

16. NUREG-0881, Supplement 05, " Safety Evaluation Report Related to the Operation of Wolf Creek Generating Station, Unit 1," issued March 31, 1985.

4 35

1

. m e.o. ' s.we s = e= e e, r eo c .u . *. .. ...

4x. sas u s =vetaas secu6avon, cowuissio=

's",',*d'S' BIBUOGRAPHIC DATA SHEET EGG-SD-7483 1 1 .A $18 *%$ta v CtioNs o~ f at *tvtelf 2 TMk t .Ne s.s' 1.8 , a 6..vt36.ma Technical Evaluation Report on the First 10-Year Interval Inservice Inspection Program Plan:

Wolf Creek Generating Station . o.n .i.o e co .re, q o r- e.a Docket Number 50-482 1

..v-o is' April' l 1987

)

. ca, . .o u.so B.W.' Brown, J.D. Mudlin " * "

April' l 1987  ;

,....o.... o. ..2.,.o~. ..~o...v o.ooain u .i.c , . aoac: 1.s. aca.v~a au eia EG&G Idaho, Inc. ,

P. O. Box 1625 j Idaho Falls, ID 83415 1 FIN-D6022 (Project S) 1 50 :Pohsomeno omG wil.fio* 4.wt .mo w...thG .comiss is,r J., c.s., sie ?vPl o8 8t'o*T Division of Licensing - PWR-A Technical ]

Office of Nuclear Reactor Regulation - ,,,,,,,,,,,,,,,,,,,,,,,,,,, J U.S. Nuclear Regulatory Commission j Washingtca, D.C. 20555 1

.: sw..+. s v .., son s 2 ..c..e, a . n This report presents the results of the' evaluation of the Wolf Creek Generating .

Station First 10-Year Interval Inservice Inspection (ISI) Program Plan through Revision 2, submitted December 11, 1985, including the. requests for relief from the ASME Code Section XI requirements which the Licensee has determined.to be impractical. The Wolf Creek Generating Station First 10-Year Interval ISI Program Plan is evaluated in Section 2 of this report.. The ISI Program Plan is evaluated for (a) compliance with the appropriate edition of Section XI, (b)' acceptability of l examination sample, (c) exclusion criteria, and (d) compliance with ISI related :J commitments identified during the NRC's review before granting.an Operating License.

The requests for relief from the ASME Code requirements which the Licensee has  :

determined to be impractical for the first 10-year inspection interval are evaluated in Section 3 of this report.

.i I

-)

6 s.: . . an acacs otsc. noas .-

2. occai%t . is g.qa Unlimited j 16 SGCW88*v CL.ss .'C. TIC A d

' ,r.

. .o ~, .. .. .s ,o.. . ~ oi c , s Unclassified

. a r. ,, J Unclassified

,, .w... . o. . .c n  ;

'l

_ _ _ - - - _ -