ML20246P823
| ML20246P823 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/16/1989 |
| From: | Crocker L Office of Nuclear Reactor Regulation |
| To: | Matthews D Office of Nuclear Reactor Regulation |
| References | |
| TAC-71943, TAC-71944, NUDOCS 8905220289 | |
| Download: ML20246P823 (34) | |
Text
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NUCLEAR REGULATORY. COMMISSION
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May 16, 1989 Docket Nos.: 50-321 50-366 NEMORANDUM FOR: David B. Matthews, Director Project Directorate 11-3 Division of Reactor Projects -I/II FROM:
Lawrence P. Crocker, Project Manager Project Directorate II-3 Division of Reactor Projects -I/II
SUBJECT:
MEETING
SUMMARY
(TACs 71943/71944)
On April 5,1989, a meeting was held in Rockville, Maryland, with representa-tives of Georgia Power Company (the licensee) to discuss issues related to two relief requests for the Hatch Nuclear Plant. The meeting had been requested by the staff. Attendees are listed in Enclosure 1. is a set of briefing slides used by the licensee for the meeting.
The first relief request concerns a requirement for a hydrostatic test of each-main steam line between the outboard main steam isolation valve (MSIV) and the turbine stop valve (TSV). This is a Class 2 line and requires pressurization in excess of the corresponding) test pressure for the Class 1 portion of the line (out to the outboard MSIV. Further, the MSIV is not designed to withstand pressure in the reverse direction. Thus, to accomplish the test on the Class 2 portion of the line would require disassembly of the MSIV and insertion of a plug in the line. The licensee had requested relief from the code requirement to test the line at the full pressure. The staff, by letter dated October 13, 1988, denied the licensee's request for relief.
However, the licensee, by letter dated January 23, 1989, renewed the request and provided additional justification for the relief requested.
The liter.see discussed the costs and extra time that would be required to accomp-lish the tests as required by the code, and the perceived limited benefit of conducting the test as specified in comparison to testing of the lines in conjunction with the test of Class 1 portions of the system. The licensee also confirmed that it had requested the code committee to reevaluate the need for the tests as now specified.
After considerable discussion, it was agreed that the licensee should provide additional justification regarding the fabrication costs and time necessary to conduct the tests, to better support a finding of impracticality by the staff.
With adequate justification, the staff feels it might be possible to grant at least schedular relief of one fuel cycle to allow time for the code corrmittee to evaluate the licensee's request. The licensee also agreed to examine the feasibility of conducting the test of the Class 1 system components at the higher pressure required by the code for the Class 2 portion of the steam line.
8905220289 890516 PDR ADOCK 05000321 P
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' The staff pointed out, and the licensee agreed, that any relief the staff may grant should not be considered as precedent setting.
Subsequent to the meeting, in early May, the ASME Code Committee approved the licensee's request for a code change. The licensee will notify us formally of j
the status of this issue.
The second relief request p(ertained to IGSCC inspections of the welds in theRWCU) radioactive water cleanup NUREG-0313. The licensee had requested relief from the requirement to examine these welds, and the request had been denied by the staff. The discussion at the meeting centered on the licensee's proposal to conduct the examination on a sampling basis.
It was agreed that the licensee would develop criteria for evaluating the condition of the RWCU welds and would obtain staff agreement on these criteria.
The licensee proposed to identify two groups of five welds in the RWCU system that appeared to be susceptible to IGSCC. During the upcoming Unit 2 outage, the first group of five welds would be inspected against the agreed upon criteria.
If the welds pass, that would be the end of the inspection for this outage.
However, if there were failures, the inspection would be expanded to include the second group of five welds. That would constitute the total sample for inspection during the outage.
If the inspections reveal welds that do not meet the criteria, the licensee will meet with the staff to discuss plans for future corrective action.
t Subsequent to the meeting, the staff informed the licensee that it would accept a sample of 10% of the RWCU welds (7 welds) expandable to an additional 10% if failures were found. Alternatively, we would accept a sample of 10 welds with no expansion unless serious problems were discovered, in which case the sample size might be increased by an additional 10 welds. The licensee will inform the staff of its decision when it submits the evaluation criteria to be used during the inspection.
~
p Lawrence P. Crocker, Project Manager Project Directorate 11-3 l
Division of Reactor Projects -I/11 Office of Nuclear Reactor Regulation l
Enclosures:
1.
Attendance List 2.
Briefing Slides cc w/ enc:
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See next page
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The staff pointed out, and the licensee agreed, that any relief the staff may grant should not be considered as precedent setting.
Subsequent to the meeting, in early May, the ASME Code Committee approved the licensee's request for a code change. The licensee will notify us formally of the status of this issue.
The second relief request p(ertained to IGSCC inspections of the welds in theRWCU) radioactive water cleanup NUREG-0313. The licensee had requested relief from the requirement to examine these welds, and the request had been denied by the staff. The discussion at the meeting centered on the licensee's proposal to conduct the examination on a sampling basis.
It was agreed that the licensee would develop criteria for evaluating the condition of the RWCU welds'and would obtain staff agreement on these criteria.
The licensee proposed to identify two groups of five welds in the RWCU system that appeared to be susceptible to IGSCC. During the upcoming Unit 2 outage, the first group of five welds would be inspected against the agreed upon criteria.
If.the welds pass, that would be the end of the inspection for this outage.
However, if there were failures, the inspection would be expanded to include the second group of five welds. That would constitute the total sample for inspection during the outage.
If the inspections reveal welds that do not meet the criteria, the licensee will meet with the staff to discuss plans for future corrective action.
Subsequent to the meeting, the staff informed the licensee that it would accept a sample of 10% of the RWCU welds (7 welds) expandable to an additional 10% if f ailures were found. Alternatively, we would accept a sample of 10 welds with no expansion unless serious problems were discovered, in which case the sample size might be increased by an additional 20 welds. The licensee will inform the staff of its decision when it submits the evaluation criteria to be used during the inspection.
/s Lawrence P. Crocker, Project Manager Project Directorate 11-3 Division of Reactor Projects -I/11 Office of Nuclear Reactor Regulation
Enclosures:
1.
Attendance List i
2.
Briefing Slides l
cc w/ enc:
See next page a
l PDII-3 PD11-3 LCrocker:sw 4%DMatthews 5////89 U 5/ g /89
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-Mr. W. G. Hairston, III~
Edwin I. Hatch Nuclear Plant,.
Georgia' Power. Company Units Nos. 1 and 2-CC:-
r G. F._Trowbridge,-Esq.
Mr. R..P.' Mcdonald
- Shaw, Pittman, Potts and Trowbridge Executive Vice President -
2300 N Street,'N.' W.
Nuclear. Operations Washington, D.C. _.20037 Georgia' Power Company P.O. Box-1295-Mr. L.'T. Gucwa Birmingham, Alabama 35201 Engineering Department
... ' Georgia Power Company Mr. Alan R. Herdt, Chief
. P. 0. Box.1295' Project: Branch #3 Birmingham, Alabama 35201:
'U.S. Nuclear Regulatory Commission 101'Marietta Street,,NW,-. Suite 2900 Huclear Safety and Compliance Manager'
-Atlanta, Georgia 30323 Edwin I. Hatch' Nuclear Plant Georgia Power Company P. O. Box 442-Baxley, Georgia 31513 Mr. Louis B. Long Southern Company-Services,..Inc.
P; 0. Box'1295 Birmingham,' Alabama: 35201 Residen't Inspector:
. U.S..- Nuclear Regulatory Consnission Route 1, Box 725 Baxley, Georgia ~ 31513
- Regional Administrator, Region 11
- U.S.' Nuclear. Regulatory Commission 1
101 Marietta. Street, Suite 2900 Atlanta, Georgia 30323 Mr. Charles H. Badger.
Office of Planning ~and Budget Room 610.
270' Washington Street, S.W.
Atlanta, Georgia 30334 Mr. J. Leonard Ledbetter, Director Environmental Protection Division Department of Natural Resources 205 Butler Street, S.E.,.
Suite 1252 Atlanta, Georgia:'30334 Chairman
-Appling County Commissioners County Courthouse Baxley, Georgia 31513
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DISTRIBUTION FOR MEETING
SUMMARY
DATED: -May 16, 1989 Facility: Hatch 1/2 N M fN %"" or-Central; File-NRC~PDR~^
L Local PDR-PDII-3 Reading T. Murley1 12-G J.'Sniezek 12-G-18 D. Matthews 14-H-25 M. Rood.
14-H '
1 L. Crocker' 14-H-25 OGC.
15-B-18 E. Jordan
.MNBB-3302 B. Grimes-9-A-2 G. Johnson
'9-H J. Hall.
13-E-21 R.-Hermann 9-H-15 W. Koo' 9-H-15 F.'Litton-9-H-15 LT. McLellan 9-H-3 ACRS (10)
P-315 B. Borchardt-17-D-19 1 - /
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. ATTENDANCE LIST-'
HATCH RELIEF REQUEST MEETING April 5, 1989 fu NAME-REPRESENTING POSITION' L'. P. Crocker NRR, PDII-3 Hatch-Project Manager-L.,T. Gucwa -
Georgia Power Co.
MGR., Nucl. Eng. & Lic.
M.'Belfor'd
_ Southern Co.
Supvr,.ISI Engineering-K..McElroy Georgia Power Co.
Licensing Eng. - Hatch
- R. L.Dy_le
~
Southern Co.
- J. R. Hall-
~ NRR, PDII-3 Duane Arnold, Project'Mgr.
' P.-ChRiccardella'
. Structural Integrity Consultant-to GPC R. A.Hermann NRR/ DEST /EMTB Section Leader Georgia Johnson NRR/ DEST /EMTB Materials Engineer Thomas McLellan NRR/ DEST /EMTB Materials Engineer NRR/ DEST /EMTB
^ Materials Engineer
'W. A; Koo.
4 Felix B. Litton NRR/ DEST /EMTB Materials Engineer Frank Schaaf, Jr.
Nebraska Public Project Engineer-Power District
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ve En dlows. 'A
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3, AGENDA NRC/GPC MEETING ISI-RELIEF REQUESTS APRIL 5, 1989 HHITE FLINT BUILDING
~
9:00 - 11:30 ROOM 10811 I.
SUMMARY
AND MEETING PURPOSE II. _ MAIN STEAM CLASS 2 HYDROSTATIC TEST y
GPC will present the following:
1.
Regulatory Requirements and Historical Perspective /
Impractibility of Test.
2.
Limited Benefit of Hydro Tests / Validity of Proposed Test Method Relative to Code Test.
3.
Industry Survey of BWR Plants.
III. RHCU HELD EXAMS OUTSIDE CONTAINMENT GPC will present the following:
1.
Regulatory Requirements and Historical Perspective /
Impractibility of Exams.
2.
Proposed Exam Plan 3.
Industry Survey of BHR Plants.
IV. NRC CAUCUS V.
DISCUSSION 0068V
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I NRC/GPC MEETING ISI RELIEF REQUESTS i
GPC SUBMITTED TH0 ISI RELIEF REQUESTS HHICH HAVE BEEN DENIED.
o 10-YR HYDRO TEST ON CL2 MSL BETHEEN OUTBOARD MSIV AND TSV L-ASME CODE SECTION XI REQUIREMENT GPC PROPOSED ALTERNATE TEST METHOD AT CLASS 1 PRESSURE o IGSCC EXAMINATIONS ON RHCU PIPING OUTSIDE OUTBOARD ISOLATION VALVE APPROXIMATELY 80 HELDS PER UNIT IN HIGH RADIATION AREA GENERIC LETTER 88-01/NUREG-0313, REV. 2 REQUIREMENT MEETING PURPOSE:
GPC HILL PRESENT TECHNICAL INFORMATION TO THE STAFF TO SHOW THAT PERFORMING HYDRO AT CL2 PRESSURE AND ULTRASONICALLY TESTING ALL RHCU HELDS IS IMPRACTICAL, REQUIRES EXTENSIVE OUTAGE RESOURCES, INCREASED PERSONNEL DOSE (ALARA),
AND DOES NOT SIGNIFICANTLY ADD TO PLANT SAFETY 0068V
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HYDROSTATIC TEST OF CLASS 2 PORTION OF MAIN STEAM LINES I
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o an o CODE REQUIRES HYDRO OF CL2 PIPING AT 1.25 TIMES DESIGN PRESSURE (APPROXIMATELY 1560 PSI FOR U-2 AND 1400 PSI FOR UNIT 1) o CLASS 2 PORTION OF 4 MSLs BETHEEN OUTBOARD MSIV AND TURBINE STOP VALVES o MSIVs HILL NOT PRESSURIZE IN REVERSE DIRECTION (Y-GLOBE VALVES) o GPC PROPOSED TO PRESSURIZE THE RPV, CL1 and CL2 PIPING TO TSV TO 1.1 TIMES OPERATING PRESSURE (APPROXIMATELY 1100 PSI)
MSL DESIGN MAKES HYDRO IMPRACTICAL 0068V
s HYDRO OF CL2 MSL (CONTINUED)
HISTORICAL AND REGULATORY PERSPECTIVE o UNIT 1 (CP PRIOR TO 1/1/71) - 10.CFR 50.55a(g)(1)
" Components... shall meet the requirements of paragraphs (g)(4) and (5) of this section to the extent practical...
Other safety-related pressure vessels, piping, pumps and valves shall meet the requirements applicable to components which are classified ASME Code Class 2 or Class 3" o UNIT 1 NOT BUILT TO SECTION III CLASS 1, 2, 3 o CFR SAYS EXAMINE AS CL 1,
2, 3 HHERE PRACTICAL (CL2, 3, NOT EXPLICITLY DEFINED) o GPC USED REG GUIDE 1.26 GUIDANCE AND UNIT 2 TO DEFINE CL2, CL3 o UNIT 2 (CP 12/27/72) - 10 CFR 50.55a(g)(2)
" Components... which are classified as ASME Code Class 1 and Class 2 shall be designed and be provided with access to enable the performance of (i) inservice examination of j
such components set forth in editions of Section XI
... in effect 6 months prior to the date of issuance of the construction permit."
UNIT 2 BUILT TO SECTION III CLASS, 1, 2, 3 HOWEVER, THERE HAS NO SECTION XI REQUIREMENT TO PERFORM HYDRO TESTS ON CL 2 PIPING UNTIL 1974 EDITION 1
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HYDRO 0F CL2 MSL (CONTINUED) o DESIGN OF HSL/MSIV SYSTEM PRIOR TO ASME SECTION XI HYDRO REQUIREMENTS FOR CL2 ON BOTH UNIT 1 AND UNIT 2 o 10 CFR 50.55a(g)(4) STATES:
"Throughout the service life... components... classified as ASME Code Class 1,
Class 2 and Class 3 shall meet the requirements set forth in [ subsequent editions of the Section XI Code]
to the extent practical within the limitations of design, geometry and materials of construction of the components."
o 10 CFR 50.55a(g)S(iii) STATES:
"If the licensee has determined that conformance with certain code requirements is impractical for its
- facility, the licensee shall notify the commission and submit, as specified in Section 50.4, information to support the determinations."
o 10 CFR 50.55a(g)(6)(i) STATES:
"The commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical.
The commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility."
10 CFR RECOGNIZES SITUATIONS AND HHERE UPGRADING TO LATER VERSIONS OF SECTION XI EXAMS MAY BE IMPRACTICAL.
THE LICENSEE IS PERMITTED TO ASK FOR RELIEF, AND THE NRC IS EMPOWERED TO GRANT RELIEF.
0068V
HYDRO OF CL2 MSL (CONTINUED) o IN GENERAL, GPC HAS APPLIED EXAM REQUIREMENTS FROM LATER EDITIONS OF SECTION XI CODE TO BOTH HATCH UNITS MANY HYDROSTATIC TESTS ON CL2 RHR, CS, CRD. AND HPCI PIYING AUGHENTED VOLUMETRIC EXAMS ON ECCS PIPING HELDS o GPC APPLIED FOR RELIEF ON CL2 MSL HYDRO ON JULY 11, 1988 TEST IMPRACTICAL BECAUSE SPECIAL MSL
" PLUGS" HERE NECESSARY TO PRESSURIZE PROPOSED ALTERNATE TEST TO PRESSURIZE THE RPV, CL1, AND CL2 PIPING TO TSV TO CL1 PRESSURE GPC'S RELIEF REQUEST DENIED ON 10/13/88, "0FFICIALLY" BECAUSE OF
" INSUFFICIENT TECHNICAL INFORMATION TO JUSTIFY THAT THE...
REQUIREMENT IS IMPRACTICAL..."
o GPC RESUBMITTED RELIEF REQUEST ON 1/23/89
- ADDITIONAL TECHNICAL INFORMATION DIFFERENCE BETHEEN CL1 AND CL2 PRESSURES FOR HYDROTEST 4
IS " TECHNICALLY NEGLIGIBLE" STRESSES HIGHER DURING PIPING SYSTEM SERVICE (NORMAL OPERATION) THAN HYDRO TEST PRESSURE (EXCEPT HOOP STRESS)
I ADDITIONAL INFORMATION ON BURDEN OF HIGHER PRESSURE TEST PURCHASE / RENTAL OF SPECIAL MSL PLUGS
($200K/ UNIT ORIGINAL QUOTE - VENDOR HESITANT TO QUOTE A FIRM PRICE AT THIS TIME) 4-6 DAYS TO DISASSEMBLE VALVES (PROBABLY ALL 4 MSIVs AT ONCE) 0068V l
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IlYDRO OF CL2 MSL (CONTINUED)
FINAL MACHINING OF PLUGS MUST BE DONE AFTER MSIVs ARE DISASSEMBLED - 5 DAYS
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2-3 DAYS TO PERFORM TEST HITH SPECIAL CHARGING PUMPS TO REACH TEST PRESSURE 3-4 DAYS TO REMOVE PLUGS AND REASSEMBLE MSIV POSSIBILITY OF DAMAGE TO MSIVs ADDITIONAL APPENDIX J TYPE C TEST ON VALVES DIFFERENT PLUGS FOR UNIT 1 AND UNIT 2 THIS HOULD BE CRITICAL PATH FOR MOST OUTAGES - GPC IS REPLACING THE MAIN CONDENSER TUBES THIS OUTAGE FOR INCREASED HYDROGEN HATER CHEMISTRY EFFECTIVENESS AND FUEL PERFORMANCE HHICH HAY REDUCE CRITICAL PATH IMPACT o GPC ALSO SUBMITTED ASME CODE CASE TO CODE COMMITTEE CODE HILL NOT BE REVISED IN TIME NRC'S HAS AUTHORITY TO MAKE DETERMINATION TEST HILL TAKE 10-15 DAYS DURING OUTAGE TO PERFORM; REQUIRES NEEDLESS DISASSEMBLY OF HSIVs AND A RISK OF DAMAGE; HILL COST GPC i
HUNDREDS OF THOUSANDS OF DOLLARS, AND HILL GIVE NO MORE ASSURANCE OF PLANT SAFETY THAN A TEST AT CLI PRESSURE I
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1 TECHNICAL EVALUATION OF ASME SECTION XI CLASS 1 VERSUS. CLASS'2 HYDRO-TEST REQUIREMENTS FOR:
PLANT HATCH MAIN STEAM LINE PIPING by:
Peter C. Riccardella, Ph.D.
Structural Integrity Associates April 5,1989 STRUCTURAL Es'o'c fr's's?mc.
e OUTLINE OF PRESENTATION
= HISTORICAL PERSPECTIVE
= TECHNICAL CONSIDERATIONS
- Applied Stresses
- Test Temperature
= FUTUAE ASME CODE ACTIONS
- General Revision to Section XI
- Georgia Power Co. Code Case
= CONCLUSIONS PR452
s" e
HISTORICAL PERSPECTIVE
- m. ORIGINAL CONCEPT OF " PROOF TESTING" OF PRESSURE COMPONENTS
- Intentional Overload of Structure Prior to Service
- Form of " Destructive Examination" (Unacceptable Defects Will Be Screened Out by Causing Failure When Consequences Are Less Than in Service)
VALIDITY OF " PROOF TEST" CONCEPT LIMITED
=
TO SITUATIONS IN WHICH:
- Pressure is Predominant Loading Mechanism
. Material Behavior is Non-Ductile, Such that Flaws or Defects Would Cause Failure Under One-Time Load
- Service Loading Not Prone to Suboritical Flaw Growth Mechanisms (e.g. Fatigue, Corrosion, Stress Corrosion, etc.)
PRA53
i EXAMPLE OF PRESSURE VESSEL FAILURE DURING PROOF TEST i
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Reference:
Hertzberg, Deformation and Fracture i
Mechanics of Engineering Materials J. Wylie & Sons,1983 1
i PR454
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HISTORICAL PERSPECTIVE (Continued)
=
PROOF" OR " HYDRO" TESTING HAS BEEN INTEGRAL PART OF ASME BOILER AND PRESSURE VESSEL CODES SINCE THEIR INCEPTION (EARLY 1900'S)
= PRESSURE TEST REQUIREMENTS INCLUDED IN ORIGINAL SECTION XI CODE (EARLY 1970'S) WITHOUT MUCH CONSIDERATION OF ABOVE VALIDITY REQUIREMENTS:
- " Leak Test" at Slightly Elevated Pressure After Each Outage
- " Hydro-Test" at Higher Pressures Every Ten Years, Or After Major Repairs.
(Basically a " Proof Test")
PR455
HISTORICAL PERSPECTIVE (Concluded)
= HOWEVER, VALIDITY OF PROOF TEST CONCEPT CLEARLY QUESTIONABLE FOR INSERVICE TESTING OF NUCLEAR PRESSURE VESSELS AND PIPING:
- Many Other Loading Mechanisms Besides Pressure (Thermal Expansion, Seismic, Thermal Transients)
- Tests and Service Temperatures are Required to be Well Above Brittle-to-Ductile Transition Temperature
- Virtually All Service Failures Have Occurred Due to Slow Flaw Growth Mechanisms--Not Amenable to Detection by Proof Testing
- Practical Limitations on Inservice Hydro-Test Pressures Sometimes Make Difference Between Section XI Leak Tests and Hydro-Tests Meaningless PR456
F P
b PLANT HATCH MAIN STEAM LINE Technical Considerations i
= SERVICE STRESSES IN LINE EQUAL OR EXCEED THOSE PRODUCED BY EITHER CLASS '1 OR CLASS 2 HYDRO-TEST
=. BOTH TESTS ARE EFFECTIVELY JUST A LEAK TEST
= CLASS 1 HYDRO-TEST LIKELY TO BE CONDUCTED AT A HIGHER TEMPERATURE BECAUSE OF VESSEL FRACTURE CONSIDERATIONS, AND THUS WOULD BE i,
BETTER LEAK TEST PR457 l
L L-
HYDRO OF CL2 MSL (CONTINUED)
COMPARISON OF APPLIED SERVICE LOADING AND HYDROTEST $7RESSES IN HATCH-UNIl 1 MAIN STEAM PIPING Maximum
- ASME Hydrotest-Code Stress Applied Code Stresses Catecorv Stresses Allowable Class 1 Class ?
(1.1 x Pop)
(1.25 x PDesign)
Primary 10.7 ksi 17.7 ksi 11.8 ksi 14.9 ksi Membrane (Eq. 1)**
Primary 14.9 ksi 26.5 ksi 6.2 ksi 7.9 ksi Membrane +
Bending (Eq. 9)**
Primary +
49.2 ksi 53.3 ksi 11.8 ksi 14.9 ksi Secondary
( Eq. 10) * *
- From Hatch-Unit 1 Main Steam Piping Stress Report. Drawing Nos. 5-51562-65 Revision 1.
l
- Standard ASME Code Section III stress equations for piping design.
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ASME CODE ACTIONS l
= ASME SC XI CURRENTLY RE-EVALUATING PRESSURE TEST REQUIREMENTS
- Special Task Group
= Likely Outcome Will Be Single
" Leak-Test" Requirement
= GEORGIA POWER COMPANY SUBMITTED CODE CASE SPECIFICALLY ADDRESSING MAIN STEAM LINE HYDRO-TEST ISSUE
- Can Be Acted On More Promptly Than Generic Code Change PR458
DEALL Prenesed code came ASE Section XI, Division 1 Systen Hydrostatic Testing of class 2 Piping Inquiry:
In accordance with As s section XI IWA-5000, Zwn-5000 and 2WC-5000, the system hydrostatic test of the class 2 and class 2 portions of a
system are tested at different pressure requirements.
In cases where the performance of separate pressure tests are impractical or when unusual requirements exist (such as the installation of specially-designed test disks), what alternative rules may be used?
Reply:
The following alternate rules may be used in the performance of system hydrostatic tests on portions of class 2 systems where the performance of a separate pressure test is impractical or when unusual requirements are necessary to perform such tests.
The system hydrostatic test of the class 2 portion shall be a.
performed in conjunction with the class 1 system hydrostatic test and shall meet the requirements of 2WA-5000 and IWB-5000.
b.
The use of this code case shall be documented on all test reports and on the Code Data Report (Fora NIS-1).
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CONCLUSIONS
= DIFFERENCE BETWEEN CLASS 1 VERSUS CLASS 2 HYDRO-TEST OF PLANT HATCH MAIN STEAM LINE TECHNICALLY NEGLIGIBLE
- Neither Poses Significant Structural
)
Challenge to Line
- Both Effective " Leak-Tests"
- Small incremental Probability of
" Destructively" Finding Defects With Higher Pressure Test Does Not Outweigh Costs of Higher Pressure Test
= ASME CODE REQUIREMENTS LIKELY TO BE CHANGED,.SUCH THAT DIFFERENCE IN TEST PRESSURES WILL NOT BE REQUIRED IN FUTURE
- Georgia Power Code Case on This Topic Under Consideration by Committee PR459
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RHCU CL3 IGSCC HELD EXAMINATIONS o GENERIC LETTER 88-01/NUREG-0313. REVISION 2 TRANSMITTED FINAL IGSCC HELD EXAM REQUIREMENTS ON PRIMARY COOLANT PRESSURE BOUNDARY PIPING HELDS
.HELDS IN PIPING 14 INCHES DIA. HITH OPERATING TEMPERATURE AB0VE 200'F RWCU PIPING OUTSIDE PRIMARY CONTAINMENT IS INCLUDED THIS PIPING PROVIDES NO SAFETY FUNCTION, HAS TWO AUTOMATIC ISOLATION VALVES, HAS REDUNDANT ISOLATION SIGNALS, AND HAS NOT BEEN - PART OF OUR ASME SECTION XI PROGRAM OR OUR AUGMENTED IGSCC EXAMS THUS FAR l
0068V
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, g RHCU HELD EXAMS (CONTINUED)
HISTORICAL.AND REGULATORY PERSPECTIVE o DEFINITION OF. " REACTOR COOLANT PRESSURE BOUNDARY", IN 10' CFR 50.2 EXCLUDES THIS PIPING SINCE IT IS OUTSIDE THE " OUTERMOST CONTAINMENT ISOLATION VALVE IN SYSTEM PIPING HHICH PENETRATES PRIMARY REACTOR CONTAINMENT" o SINCE PIPING IS NOT SAFETY-RELATED,' IT DOES NOT HAVE TO BE INCLUDED IN ASME SECTION XI PROGRAM [10 CFR 50.55a(c)(2),
10 CFR 50.55a(g)(1) and (2)]
o UNIT 1 AND UNIT 2 PIPING NOT BUILT CL3 - VOLUNTARILY UPGRADED TO CL3, BUT NOT SAFETY-RELATED, NOT CATEGORY I (SEISMIC) o NUREG-0313, REVISION 1 (1980) RECOMMENDED AUGMENTED ISI ON LARGE BORE (GREATER THAN 12 INCH) PRIMARY PRESSURE B0'JNDARY PIPE. SUBJECT RHCU PIPE HELDS NOT INCLUDED.
o THIS PIPING HAS ALSO NOT INCLUDED IN INSPECTION SCOPE OF IEB 82-03 OR IEB 83-02.
o UNTIL GL 88-01/NUREG-0313 REVISION 2 NAS ISSUED, GPC (AND MOST OF THE BWR INDUSTRY) PERFORMED AUGMENTED INSPECTIONS OF PIPING HELDS FOR IGSCC BASED ON:
GL 84-11 (THROUGH EARLY 1986)
DRAFT NUREG 0313, REVISION 2 HITH BHROG-II COMMENTS o GL 84-11 AND THE INDUSTRY-COMMENTED DRAFT NUREG BOTH EXCLUDED RHCU PIPING OUTSIDE OUTBOARD ISOLATION VALVE o PIPING HELDS MAY NOT HAVE BEEN RADIOGRAPHER DURING CONSTRUCTION (N0 BASELINE UT) AND EXAMS HAVE NOT BEEN REQUIRED UNDER SECTION XI OR AUGMENTED ISI PROGRAMS j
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PIPING NOT INCLUDED PREVIOUSLY NO REGULATORY BASIS FOR THEIR INCLUSION N0H 0068V
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RHCU HELD EXAMS (CONTINUED) o 10 CFR 50.109 (BACKFITTING)
REQUIRES A
VALUE/ IMPACT ASSESSMENT UNLESS THE " modification is necessary to bring, a facility into compliance with a license" OR "an' immediately effective regulatory action is necessary to ensure that the facility poses.no undue risk to the public health and safety" (10 CFR 50.109(a)(4))
o AUGMENTED INSPECTIONS OF PRIMARY SYSTEM PIPING HELDS MAY FALL UNDER " EFFECTIVE REGULATORY ACTION", (HHICH IS THE SUBJECT OF GL 88-01) BUT, SPECIFICALLY, THE HELDS IN THE NON-SAFETY RHCU PIPING CLEARLY DO NOT FALL UNDER
" EFFECTIVE REGULATORY ACTION" VALUE/ IMPACT ASSESSMENT NECESSARY TO BACKFIT IMPACT VERY PLANT-UNIQUE (FROM 8 AFFECTED HELDS AT ONE BHR TO OVER 100 AFFECTED HELDS)
ASSESSMENT HOULD FAIL TO SH0H (PER 10 CFR 109.(a)(3)]
"a substantial increase in overall protection of the public health and safety and that the direct and indirect costs of implementation... are justified" -
FOR PLANT HATCH i
0068V I
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,2 RNCU NELD EXAMS (CONTINUED) o INCREASE IN OVERALL SAFETY NEGLIGIBLE AUTOMATIC ISOLATION OF BOTH SAFETY-GRADE RNCU
=-
ISOLATION VALVES REACTOR HATER LEVEL 2
-- -HIGH TEMPERATURE IN RHCU AREA-HIGH DELTA T (RHCU SUPPLY / EXHAUST VENTILATION)
HIGH FLUID TEMPERATURE LEAVING NON-REGENERATIVE HX (OUTBOARD ONLY)-
HIGH DIFFERENTIAL FLOH SLCS ACTUATION (OUTBOARD ONLY)
PIPING NOT SEISMIC /NOT NECESSARY FOR MITIGATION OF ANY LICENSING-BASIS EVENT LEAKS / BREAKS ISOLATABLE - NO SAFETY CONCERN INSPECTIONS OF 4"
PIPE HOULD NOT PRECLUDE LEAKAGE IN SMALLER DIAMETER (E.G., 3") PIPE
- o. DIRECT AND INDIRECT COSTS HIGH HELDS OUTSIDE OUTBOARD ISOLATION VALVE HOULD BE CONSIDERED CATEGORY "G" PER THE GL/NUREG SENSITIVE TO IGSCC NOT INSPECTED 78 HELDS IN UNIT 2 ALONE i
.0068V
.i 1
RHCU HELD EXAMS (CONTINUED)
NONE OF THE CL3 HELDS HERE INITIALLY RADIOGRAPHER DURING CONSTRUCTION AND NONE HAVE BEEN ULTRASONICALLY EXAMINED SINCE THEN NO BASELINE DATA FOR INSPECTION INDICATIONS DETECTED DURING ULTRASONIC TESTING (UT) COULD BE RESULT OF CONSTRUCTION IMPERFECTIONS CONDITION OF HELDS MAY BE TOO POOR FOR RELIABLE UT RESULTS.
GPC DID UT TWO HELDS OF U-1 PIPING REMOVED DURING RNCU PUMP REPLACEMENT INSULATION (ASBESTOS) HARD TO REMOVE SURFACE FINISH NOT SUITABLE FOR LIQUID PENETRANT
-- ROUGli GRINDING PRESENT WHICH INTERFERES HITH UT PIPE ELB0H GEOMETRY NOT SUITABLE FOR UT GRINDING / SANDING NECESSARY NO IGSCC DETECTED IN THE TWO HELDS REMOVED DURING RHCU PUMP REPLACEMENT RHCU HELDS IN HIGH RADIATION AREA (See 10 CFR 50.109 (c)(4)). " potential impact on radiological exposure of facility employees" 0.4 TO 6 REM PER HELD FOR EXAM HELL OVER 100 REM TOTAL EXPOSURE ($5K/ REM)
AVAILABILITY OF QUALIFIED NDE INSPECTORS A REAL PROBLEM i
i REQUIREMENT TO EXAMINE ALL HELDS HILL DOUBLE SCOPE OF INSPECTION PER GL 88-01 IN ESSENCE, BY REQUIRING' THESE EXAMS, IT ELEVATES THE IMPORTANCE OF THE STRUCTURAL ADEQUACY OF THE NON-SAFETY RHCU PIPING 6HQyVI
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o REPRESENT CONTACT DOSE RATES HITH h
INSULATION (APPROXIMATELY 25% LESS ONE FOOT d
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a DECONTAMINATION NOT TOO EFFICTIVE
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HELP REDUCE DOSE. BUT ENGINEERING HORK E*'
IS NECESSARY TO TAP IN LINES, ETC.
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- SHIELDING MAY HELP AROUND HX, BUT l
MAJORITY OF DOSE COMES FR0 PIPE HHICH IS
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ESTIMATE 15 REM JUST FOR SCAFFOLDING FOR f,
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PHASE SEPARATOR ROOM VERY HIGH, BUT CAN BE DRASTICALLY REDUCED HITH FLUSHING
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RNCU HELD EXA'S (CONTINUED)-
M
- o GPC PROPOSAL (TELECOPIED DRAFT ON 3/7/89)
DURING THE APRIL 1989 MINI-0UTAGE HAVE HEALTH PHYSICS:
HALK. DOWN. THE RHCU PIPING HELDS.
(THE MINI OUTAGE IS SCHEDULED BECAUSE WE ARE REPLACING THE MAIN CONDENSER 5
TUBES IN THE FALL.)
SELECT APPROXIMATELY 10 WELDS FOR UT EXAM PER GL 88-01 i
NEXT OUTAGE SELECTION BASED ON IGSCC SUSCEPTIBILITY
.(E.G.,
TEMPERATURE, DUTY),
ACCESSIBILITY AND EXPOSURE MINIMIZATION DETERMINATION AND REPAIR (IF NECESSARY) 0F REPORTABLE INDICATION PER GL/NUREG DON'T-AUTOMATICALLY EXPAND SCOPE IF INDICATIONS ARE DETECTED o
PROPOSAL OFFERS SEVERAL ADVANTAGES SAMPLE INSPECTIONS ALLOW US TO DETERMINE CONDITION OF PIPING HELDS HHICH HAVE NEVER BEEN "BASELINED" BEFORE SAMPLE INSPECTIONS CAN BE PLANNED TO MINIMIZE ALARA CONCERNS-HE CAN DISCUSS CONDITION OF PIPING HITH NRC AFTER ITS CONDITION IS DETERMINED
- DECISION-ON HHETHER TO INSPECT / REPAIR OR TO REPLACE THE PIPE CAN BE MADE AFTER OUTAGE OTHERWISE. IF INDICATIONS ARE DISCOVERED, HE MIGHT BE FORCED TO REACT WITH EXTENSIVE INSPECTION AND REPAIR HHEN THE BETTER ALTERNATIVE HOULD BE TO REPLACE PIPING THIS PROPOSAL ALLOWS FOR GPC TO DETERMINE CONDITION OF PIPE, DISCUSS HITH NRC, AND ALLOHS TIME TO ORDER NEW PIPING, VALVES, IF REQUIRED 0068V
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RHCU HELD EXAMS (CDNTINUED)'
INDUSTRY SURVEY OF BHR PLANTS (DATA 3 MONTHS OLD)
PLANT A (BWR/4 - 3 UNITS) - 304 SS' IN RHCU OUTSIDE DRYHELL, NEVER EXAMINED AND ARE BEING CA1. LED "UNINSPECTABLE" CATEGORY G BECAUSE THEY DON'T KN0H. HELD ' CONDITION OR BASELINE.
PLAN TO VISUALLY INSPECT, ABOUT 95 HELDS PER UNIT.
HIGH RAD NEAR HXs.
PLANT B (BHR/4 - 2 UNITS) - 304 SS IN RHCU '0UTSIDE DRYHELL.
SAME STORY AS PLANT A - ABOUT 95-100 NELDS/ UNIT.
PLANT C (BHR/4 - 2 UNITS) -'THE PIPE IS NON-CONFORMING AND HAVE
-l FOUND CRACKING.
OVER 100 HELDS 4-6 l
INCHES IN DIAMETER.
UNABLE TO OBTAIN RELIEF FROM NRR.
THE UTILITY ESTIMATES 75 REM TO INSPECT 44 HELDS.
PLAN TO REPLACE PIPE HITH CARBON STEEL.
PLANT D (BHR/3)
- CHANGED TO CARBON STEEL PLANT E (BWR/6)
- CARBON STEEL ORIGINALLY PLANT F (BHR/6)
- CARBON STEEL ORIGINALLY PLANT G (BWR/3 - 2 UNITS) - RESPONDED TO GL 88-01 THEY HOULD ONLY DO EXAMS ON ASME CL1, CL2, CL3 PIPING (RHCU NON-CODE CLASS).
NRR NOT RESPONDED - ABOUT 100 HELDS/ UNIT HHICH HAVE NEVER SEEN EXAMINED AND HILL NEED SURFACE PREPARATION IN HIGH RAD AREA.
PLANT H (BHR/3 - 2 UNITS) - SAME AS PLANT G PLANT I (BWR/4 - 3 UNITS) - NON-CONFORMING
- MATERIAL, NEVER INSPECTED ONLY ABOUT 12 HELDS/ UNIT.
RESPONDED TO GL 88-01 SAYING THEY DID NOT PLAN TO EXAMINE.
RECEIVED SER AND THEN NRR RECONSIDERED.
RAD LEVELS NOT TOO HIGH BECAUSE PLANT HAS BEEN D0HN FOR AN EXTENDED PERIOD OF TIME.
l 0068V 1
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.o RHCU NELD EXAMS (CONTINUED)
PLANT J (BWR/2)
- NON-CONFORMING MATERIAL NEVER INSPECTED.
DO NOT PLAN TO EXAMINE THE SYSTEM AND HAVE NOT HEARD FROM THE NRC ABOUT THEIR RESPONSE.
^ BOUT 100 NELDS.
HIGH RAD LEVELS (1.5 - 2 REM /HR).
PLANT K (BHR/4)
- CHANGED TO CARBON STEEL PLANT L (BHR/3)
- EXAMINED SOME RHCU HELDS OUTSIDE DRYHELL. TOTAL OF 8 HELDS AFFECTED.
PLANT H (BHR/3)
- NON-CONFORMING, NON--CODE CLASS.
THE PLANT HAS A TOTAL OF ABOUT 45 HELDS IN THE RHCU OUTSIDE DRYWELL.
FIFTY PERCENT ARE UT'D EACH OUTAGE.
FOUND NO CRACKS AS YET.
RAD LEVELS ARE SUCH THEY RECEIVE ABOUT 6 REM TOTAL PERFORMING EXAMS (AVERAGE LEVEL ABOUT 50 MR/HR).
PLANT L (BHR/2)
- NON-CONFORMING MATERIAL.
NRC DISAGREED WITH THE UTILITY'S ASSESSMENT THE PIPE SHOULD NOT BE INCLUDED.
TOTAL OF 96 HELDS.
ESTIMATES OF-540 MR TO ERECT i
REMOVE AND REPLACE i
INSULATION, PREPARE
- HELDS, AND EXAMINE HITH0VT DECONTAMINATION AND 110 HITH DECON.
THREE HELDS HERE EXAMINED IN 1989 AT 2 REM PER HELD.
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