NL-03-188, Request for Approval for Alternative to Use Code Case N-613-1 for Reactor Vessel Nozzle to Vessel Weld Inspection

Request for Approval for Alternative to Use Code Case N-613-1 for Reactor Vessel Nozzle to Vessel Weld Inspection

ML040020199
Person / Time
Site:	Indian Point
Issue date:	12/30/2003
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-03-188
Download: ML040020199 (20)

Text

Entergy Nuclear Northeast Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 dEntery Tel 914 734 5340 Fax 914 734 5718 Fred Dacimo Vice President, Operations December 30? 2003 NL-03-188 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1 -17 Washington, DC 20555-0001

SUBJECT:

Indian Point Nuclear Generating Units No. 2 and No. 3 Docket No. 50-247, and 50-286 Alternative to Use Code Case N-613-1 for Reactor Vessel Nozzle to Vessel Weld Inspection

References:

1. NRC Letter from James W. Clifford to Roy A. Anderson, uHope Creek Generating Station - Evaluation of Relief Request HC-RR-B08 (TAC NO.

MB7839)," dated August 26, 2003.

Dear Sir Pursuant to IOCFR50.55a(a)(3)(i), Entergy Nuclear Operations, Inc. (ENO) hereby requests the Nuclear Regulatory Commission (NRC) to approve the use of an alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl requirements regarding the inspection of Class 1, Examination Category B-D, Reactor Vessel Nozzle to Vessel Welds.

Enclosed are two (2) similar requests for relief (RRs) to use the proposed alternatives for Indian Point Nuclear Generating Unit No. 2 (P2, Enclosure 1) and Indian Point Nuclear Generating Unit No. 3 (P3, Enclosure 2). The proposed alternative would allow the plants to perform the required inspections in accordance with Code Case N-613-1, in lieu of the ASME Section Xl Code requirements. In accordance with 10 CFR 50.55a(a)(3)(i), the proposed alternative to use Code Case N-613-1 in its entirety provides an acceptable level of quality and safety for the examination of the affected welds.

These requests for relief for P2 and P3 are for their 3rd ISI Interval, and the applicable code of record is the 1989 Edition, No Addenda of the ASME Section Xi Code.

A similar request for relief was approved for Hope Creek (Reference 1).

Mqq

Entergy requests approval of the P2 relief request (Enclosure 1) by June 2004 to support its Fall 2004 refueling outage. Since these RRs are practically identical, Entergy requests that the P3 relief request (Enclosure 2) be approved at the same time.

There are no new commitments made in this letter. If you have any questions, please contact Ms. Charlene Faison at 914-272-3378.

AdVery truly yours, redR. Dacimo Vice President, Operations Indian Point Energy Center List of

Enclosures:

1. Indian Point Generating Station Unit No. 2, RR-67

2. Indian Point Generating Station Unit No. 3, RR 3-36 cc:

Mr. Hubert J. Miller Mr. Paul Eddy Regional Administrator, Region I New York State Department U.S. Nuclear Regulatory Commission of Public Service 475 Allendale Road 3 Empire State Plaza King of Prussia, PA 19406-1415 Albany, NY 12223 Mr. Patrick D. Milano, Sr. Project Manager Mr. Peter R. Smith, Acting President Project Directorate I New York State Energy, Research, and Division of Licensing Project Management Development Authority Office of Nuclear Reactor Regulation Corporate Plaza West U.S. Nuclear Regulatory Commission 286 Washington Avenue Extension Mail Stop 0-8-C2 Albany, NY 12203-6399 Washington, DC 20555-0001 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511-0337 Senior Resident Inspectors Office Indian Point Unit 2 U.S. Nuclear Regulatory Commission P.O. Box 38 Buchanan, NY 10511-0038 2

P NL-03-188 Enclosure I INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-67 Proposed Alternative InAccordance with IOCFR50.55a(a)(3)(i)

-Alternative Provides Acceptable Level of Quality and Safety-

1. ASME Code Component(s) Affected Component Numbers: ASME Code Class 1 Reactor Vessel Nozzle to Vessel Welds.

Examination Category: B-D Item Number. B3.90 - Nozzle to Vessel Welds

2. Applicable Code Edition and Addenda The Code of Record for the third Inservice Inspection Interval is ASME Section Xl Code, 1989 Edition, No Addenda.

3. Applicable Code Requirements ASME Boiler and Pressure Vessel Code, Section Xi, Rules for Inservice Inspection of Nuclear Power Plant Components, 1989 Edition with No Addenda: Table IWB-2500-1 Code Item B3.90, Figures IWB-2500-7 (a)thru (d)for defining the examination volume of the reactor vessel nozzle to shell welds. The examination requirements for reactor vessel nozzle to shell welds are defined in the ASME Code, Section Xi, Appendix Vil, Supplements 4, 6 and 7, 1995 Edition, 1996 Addenda as modified by 10 CFR 50.55a. Eight (8) RPV nozzle to shell welds, 4 inlet and 4 outlet, are planned for examination in 2004 as follows:

Nozzle to Vessel Weld RPVN1 @ 220 Azimuth Nozzle to Vessel Weld RPVN2 @ 670 Azimuth Nozzle to Vessel Weld RPVN3 @ 1130 Azimuth Nozzle to Vessel Weld RPVN4 @ 1580 Azimuth Nozzle to Vessel Weld RPVN5 @ 2020 Azimuth Nozzle to Vessel Weid RPVN6 @ 2470 Azimuth Nozzle to Vessel Weld RPVN7 @ 2930 Azimuth Nozzle to Vessel Weld RPVN8 @ 3380 Azimuth 1

S NL-03-1 88 Enclosure 1

4. Reason for Request The Code required examination volume of the nozzle to vessel welds is unnecessarily large. The proposed alternative to use Code Case N-613-1 in its entirety will not affect the flaw detection capabilities in the weld and the heat affected zone, and provides an adequate level of quality and safety for examination of the affected welds.

5. Proposed Alternative In accordance with 10CFR50.55a(a)(3)(i), P2 requests relief from the t2 (t. is equal to the vessel wall thickness) examination volume requirement and instead proposes examination of the base material volume extending 1/2 inch from each side of the weld. This refined examination volume is defined in detail within Code Case N-613-1 (Attachment 1) and the WesDyne sketches (Attachment 2).

Basis for Use The examination (exam) volumes for the reactor vessel nozzle to vessel welds are unnecessarily large. For the P2 reactor vessel, the nozzle to shell volume would extend about 5 inches into the nozzle forging and the same distance into the upper shell course forging. This proposed alternative would re-define the examination volume boundary to 1/2 inch of base metal on each side of the thickest portion of the weld. This reduction in base metal inspection will not affect the flaw detection capabilities in the weld and heat affected zone.

Compliance with these requirements will assure the requisite level of quality and safety is maintained.

The proposed reduction in exam volume is base metal only, extensively interrogated by ultrasonic examination during fabrication, preservice examinations and the last inservice examinations performed in 1995 at the end of the second interval. In 1995, the data was acquired, archived and analyzed using automated ultrasonic systems. Entergy Nuclear Operations, Inc. (Entergy) is confident that reasonable comparisons can be made between the past and present if necessary.

During the 1995 examinations, there were no unacceptable indications found in the eight-reactor vessel nozzle to vessel examination volumes including the base metal areas proposed for exclusion from examination in this request. The 1995 results were based on examinations performed in accordance with the ASME Code, Section Xl,Section V and Regulatory Guide 1.150, Rev. 1.

The Section Xl examination volume for the pressure-retaining nozzle to vessel welds extends from the edge of the weld to include a significant portion of the nozzle forging body (inward) and reactor vessel upper shell course (outward) which is a forged ring. The large volume results in a significant increase in examination time with no corresponding increase in safety as the greatest portion of the volume is base material not prone to inservice cracking.

The implementation of this request for relief would reduce the examination volume next to the widest portion of the weld from half the vessel wall thickness to 1/2 inch from the weld. This reduction applies only to base metal and not the stressed areas of the nozzle to shell weld.

Entergy shall ensure that the high stressed areas of the P2 reactor vessel nozzle to shell welds shall be included in the examination. The examinations shall consist of techniques and 2

NL-03-188 Enclosure I procedures qualified in accordance with the ASME Code, Section Xl, Appendix Vil, and supplements 4, 6 and 7. The weld and surrounding 1/2 inch volume will be interrogated from the nozzle bore using techniques and procedures specifically qualified to inspect the nozzle to shell weld from the nozzle bore. These procedures were qualified in January 2003 in accordance with Appendix Vil, Supplement 7 as administered by the PDI.

The nozzle to vessel examination volume is also accessible from the vessel ID surface and will be examined in four orthogonal directions for the first 15 percent of weld thickness with respect to the vessel ID surface using Appendix ViII, Supplement 4 qualified techniques. The remaining 85 percent of weld volume accessible from the vessel ID surface will be examined in two opposing circumferential scanning directions using Appendix Vil, Supplement 6 qualified techniques to interrogate for transverse defects.

This combination of scans addresses the requirements set forth by the ASME Code, Section Xl, 1995 Edition with 1996 Addenda as modified by 10CFR50.55a and assures that current qualified technology will be applied to the re-defined examination volume specified herein to the maximum extent practical. Compliance with these requirements will assure the requisite level of quality and safety is maintained.

6. Duration of Proposed Altemative It is proposed to use the alternative for the remainder of the Third Inservice Inspection Interval for IP2.

7. Precedents A similar request for relief was approved for Hope Creek (Docket No. 50-354, TAC NO. MB7839, dated August 26, 2003).

8. Attachment

1. Code Case N-613-1 (for information)

2. WesDyne Sketch, Indian Point Units 2 and 3 (TYP.), RPV Inlet and Outlet Nozzles Examination Volume - Code Case N-613-1 (2 pages) 3

NL-03-188, Enclosure i Attachment 1, page 1 of 4 N-613-1 CASMS OF ASM BO AM pESSR VES CODE ApPOW Da: August 2. 20 Se Mmik hW&for expkson ind AY nefrfmsfon datu Cse N441.1 Ulra oaEnmunatim of FA Penetraton NozJkS In Veck~ Bzanslraton Category B.D%

11cm NoL BU31D u D30, Reactor Neozle-To.

Vend Weds, Figs M-S0-7(a) (b), and (c section U l,Dwou I InquirY: W cIternaves to die uxaminaon volune Mq=Mts of Ftf. WB-2500-7(a) (b) and (c) ae peMible for ultnsonk examlation of eaWror-0-yenssl we Reply: it Is she opinion of Sc COnuitecSIM Cate-gory B-D wmd-o-vausd welds prviusly ulasoul-cally cxained using the exmino OlU Figs.

IWB-2500-7t (b). and (C) ma1y be, exmlned uing IIX rued eUdnatIon VoIume (A-B-C.DE.F.O-H) of Hp 1,2.Zand 3.

1029 Sp,- lC

NL-03-188, Enclosure I Attachment 1, page 2 of 4 CASE (conUnued)

N-613-1 CAS OF DO AM MSUBE VRSEL O

,t f noe *aU tioknes IS a bell (or hd) Ilnenua q nozle kde ornerdius Co M _ _

Cornrtlaw EXAMINATION EGION INote Ill EXAMIMATlON VOLUME Nle 1211 sheo (orhead dJolnfa region C-D-r-F Aftochant weld region I-C-F-G Nozz cylinder eglon A-B-G-H Nozle Intide corne region M-N-O-P NOTES;

11) Examnation reglons er Identified ler t purpose of differentlinog ow ecpun= andards in MW13512.

(2) Eanuaion bms any e dtermIned ter by dlrect mumurements on e ompn or by m sement based en dusdgn drawdngsi FIG. 1 NOZZLE IN SHELL OR HEAD (ExamInatbn Zones ael T* Nozzes JolneOd by Fun Petvon Cer Welw 1030 SUPP. -NC

NL03-188, Enclosure I Attachment 1, page 3 of.4 CASE (continued)

N-613-1 fjt, rQ - nozzle wa tickn is - shall or heedl lknss q - noze Inside corner radius GC IN I where

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Corno no^w EXAMINATION REGION INote M1) XAMINATIN VOLUME Plote 121 Shell (or haed) sdoinng region C-D-E-F Atachment weld region B-C-f-G Nozzle cinder region A-B-G-H Nol hslde corner region bl-N-O-P NOTES (1) ExamInatonreglons ar IdenUled b rthspurpose ofdifferentianggUapsun erands In NWMS12 12)Eaminationvolumesmsybe dermnedeIther bydirectmeasumenuon temponentorby .

musurements based on design drawings.

FIG. 2 NOZZLE IN SHELL OR HEAD (Examinaton Zones In Flnge Type Nozzles Joined by Ful Penetration Butt Welds) 1031

NL03-188, Enclosure I Attachment 1, page 4 of 4 VADC Ilomnluuai N-613-1 CS OF AIM I l AMD FRE= VSEL CODE 4- .lzil %Wlhkineu t dll orh ead) gss t a Iside co norroida l i.

where prust Corner fw EXAMINATIO RIEGION INoto lle EXAMINATION VOLUME INoto Oil Sha bored) adoialng region . C-D-E-F-G Attedwrt Ield region U-C-G Nodo cyndor region A-D-O-H Nozzle bide coner region M-N-0-P NOIES:

11) Examneon regionedended Ir eurpos f dlflmbllng Ve panc ads h MI94S1Z

1) Exrninalon volums m be detrmined eihr by dw tmeuremens en ecoasnim r by maesurements based an design drawingL II FIG. 3 NOZZLE IN SHELL OR HEAD iI (Examination Zenes In Set-On Te Nzts Joined by Full Penetration Comer Welds) I SUPP. I - NC 1032

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NL-03-188 Enclosure 2 INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR 3-36 Proposed Alternative InAccordance with 10CFR50.55a(a)(3)(i)

-Alternative Provides Acceptable Level of Quality and Safety-

1. ASME Code Comoonent(s) Affected Component Numbers: ASME Code Class 1 Reactor Vessel Nozzle to Shell Welds.

Examination Category: B-D Item Number B3.90 - Nozzle to Vessel Welds

2. Applicable Code Edition and Addenda The Code of Record for the third Inservice Inspection Interval is ASME Section Xl Code, 1989 Edition, No Addenda.

3. Applicable Code Requirements ASME Boiler and Pressure Vessel Code, Section Xl, Rules for Inservice Inspection of Nuclear Power Plant Components, 1989 Edition with No Addenda: Table WB-2500-1 Code Item B3.90, Figures IWB-2500-7 (a)thru (d)for defining the examination volume of the reactor vessel nozzle to shell welds. The examination requirements for reactor vessel nozzle to shell welds are defined in the ASME Code, Section Xl, Appendix Vil, Supplements 4, 6 and 7, 1995 Edition, 1996 Addenda as modified by 10 CFR 50.55a. Eight (8) RPV nozzle to shell welds, 4 inlet and 4 outlet, are planned for examination in 2009 as follows:

Nozzle to Vessel Weld 21 @ 1130 Azimuth Nozzle to Vessel Weld 22 @ 1580 Azimuth Nozzle to Vessel Weld 23 @ 2020 Azimuth Nozzle to Vessel Weld 24 @ 247° Azimuth Nozzle to Vessel Weld 25 @ 2930 Azimuth Nozzle to Vessel Weld 26 @ 338° Azimuth Nozzle to Vessel Weld 27 @ 220 Azimuth Nozzle to Vessel Weld 28 @ 670 Azimuth 1

NL-03-1 88 Enclosure 2

4. Reason for Reauest The Code required examination volume of the nozzle to vessel welds is unnecessarily large. The proposed alternative to use Code Case N-613-1 in its entirety will not affect the flaw detection capabilities in the weld and the heat affected zone, and provides an adequate level of quality and safety for examination of the affected welds.

5. Proposed Alternative In accordance with 10CFR50.55a(a)(3)(i), P3 requests relief from the tJ2 (ts is equal to the vessel wall thickness) examination volume requirement and instead proposes examination of the base material volume extending 1/2 inch from each side of the weld. This refined examination volume is defined in detail within Code Case N-613-1 (Attachment 1) and the WesDyne sketches (Attachment 2).

Basis for Use The examination (exam) volumes for the reactor vessel nozzle to vessel welds are unnecessarily large. For the 1P3 reactor vessel, the nozzle to shell volume would extend about 5 inches into the nozzle forging and the same distance into the upper shell course forging. This proposed alternative would re-define the examination volume boundary to 1/2 inch of base metal on each side of the thickest portion of the weld. This reduction in base metal inspection will not affect the flaw detection capabilities in the weld and heat affected zone.

Compliance with these requirements will assure the requisite level of quality and safety is maintained.

The proposed reduction in exam volume is base metal only, extensively interrogated by ultrasonic examination during fabrication, preservice examinations and the last inservice examinations performed in 1999 at the end of the second interval. In 1999, the data was acquired, archived and analyzed using automated ultrasonic systems. Entergy Nuclear Operations, Inc. (Entergy) is confident that reasonable comparisons can be made between the past and present if necessary.

During the 1999 examinations, there were no unacceptable indications were found in the eight-reactor vessel nozzle to shell examination volumes including the base metal areas proposed for exclusion from examination in this request. The 1999 results were based on examinations performed in accordance with the ASME Code, Section Xl,Section V and Regulatory Guide 1.150, Rev. 1.

The Section Xl examination volume for the pressure-retaining nozzle to shell welds extends from the edge of the weld to include a significant portion of the nozzle forging body (inward) and reactor vessel upper shell course (outward) which is a forged ring. The large volume results in a significant increase in examination time with no corresponding increase in safety as the greatest portion of the volume is base material not prone to inservice cracking.

The implementation of this request for relief would reduce the examination volume next to the widest portion of the weld from half the vessel wall thickness to 1/2 inch from the weld. This reduction applies only to base metal and not the stressed areas of the nozzle to shell weld.

2

NL-03-188 Enclosure 2 Entergy shall ensure that the high stressed areas of the P3 reactor vessel nozzle to shell welds shall be included in the examination. The examinations shall consist of techniques and procedures qualified in accordance with the ASME Code, Section Xl, Appendix Vill, and supplements 4, 6 and 7. The weld and surrounding 1/2 inch volume will be interrogated from the nozzle bore using techniques and procedures specifically qualified to inspect the nozzle to shell weld from the nozzle bore. These procedures were qualified in January 2003 in accordance with Appendix Vil, Supplement 7 as administered by the PDI.

The nozzle to vessel examination volume is also accessible from the vessel ID surface and will be examined in four orthogonal directions for the first 15 percent of weld thickness with respect to the vessel ID surface using Appendix Vil, Supplement 4 qualified techniques. The remaining 85 percent of weld volume accessible from the vessel ID surface will be examined in two opposing circumferential scanning directions using Appendix Vill, Supplement 6 qualified techniques to interrogate for transverse defects.

This combination of scans addresses the requirements set forth by the ASME Code, Section Xi, 1995 Edition with 1996 Addenda as modified by 10CFR50.55a and assures that current qualified technology will be applied to the re-defined examination volume specified herein to the maximum extent practical. Compliance with these requirements will assure the requisite level of quality and safety is maintained.

6. Duration of Proposed Alternative It is proposed to use the alternative for the remainder of the Third Inservice Inspection Interval for IP3.

7. Precedents A similar request for relief was approved for Hope Creek (Docket No. 50-354, TAC NO. MB7839, dated August 26, 2003).

8. Attachment

1. Code Case N-613-1 (for information)

2. WesDyne Sketch, Indian Point Units 2 and 3 (TYP.), RPV Inlet and Outlet Nozzles Examination Volume - Code Case N-613-1 (2 pages) 3

NL-03-1 88, Enclosure 2 Attachment 1, page 1 of 4 N-613-1 CWSES OFS3OU=RMND rssU VES oDn DAl Da . Augut .2 SHe IAl ha fr exatOn and any eatimaon dat.&

Case N4131 UlUrso Examitto of Fa Petration Nozzles In Vasek Ex fmlu Catory B-D Uem No% B31g rnd B390, Rector N=ze-To-Vesed Weds, SL IWB 70, (b), and W Setion l OhuoU 1 lnguir Wit ves Ia e esmnlion volume Mequh= ts f Figs. lWB-2S007(4 (b), ad (c) ae PMnissibe for alsonlc eamiAon of Arnozle-o-vesselW s RCpAY. It is the Cpinion of Ihe Comn)tehaz Cato-gory B D =zIlCeO-vssd welds pr:ibusly urasoni-aly eanausing & exanination VOlum or FIS IWB-2500-7(. (W. and c) inay be exanined using the reduced examinlation volume (A-B-C-D-E-F-0H) of Figs. 1. , an 3.

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NL-03-188, Enclosure 2 Attachment 1, page 2 of 4 CASE (continued)

N-613-1 CASZS 0O AB DO AD PRISSURE VSEL CODE 4gdS 4 a nowesaivlt aes

• sehaUorhaaihidmass a nozzle kuld corner radlux CD Cornertaw EXAMINATiON REGION INot 11i EXAMINATIONVOUME INote(211 hul (or hesal adiolhnt ulan C-D-E-F Aftschmertweld rgton B-C-F-¢ Nozle cUnder rgion A-B-C-H Nozzle eld,orner lion U-R-O-P NOTES:

11) Exambuilon reglons are dandfied fort purpose of differendatng thr ecpance slandards In 1YB451 1 Examiration volumes may be determined elther by diec mneasuremeot an the componat or by neasurements based an design drawings.

.S flG I NZZL I SHELL OR HAD (Examination Zones In Barrel Type Nozzles Joined by Ful Peneratulon Corner Weds)

SUPP. , - NC 1030

NL-03-188, Enclosure 2 Attachment 1, page 3 of.4 CASE (contlnued)

N-613-1 rta *a nozdI walf thiks 1, sheR r hordl ShIunuss q

• nozne iside corner rsdius

_12 L Whomno poso Corner flow EXAMINATION REGION INoto 1111 XAMINAMION VOUM E INoto 12) ho (or adl ao~hingdregion C-D-E-F Aftachmentwold rooin B-C-f-t Nozzl cylinder region A-5-G-H Noe Inside cor regin U-N-O-P NOTES:

(1) ExamInation glon art Iderfied fbr f pufpoe cf dlfferenatgit eptanca.sundard In M 412 M Examinaton 1tume may bO dtermnbwd ther by ect mesurmmenu oni scnmponen trby mouuramontas based on design drwings.

FIG. 2 NOZZLE IN SHELL OR HEAD (Exambiaton Zones In Flange Type Nozzles Jolned by Fll Penetation Buu Welds) 1031

NL3-188, Enclosure 2 Attachment 1, page 4 of 4 VAuC 10olnueal N-613-1 CASMS OF "M I0If AM P&SU VIS CME I

&I . aoszl I tiflm s* al IMrhad) thickes q* azle kiidaeeonw dus present

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Cor faw EXAMINATION REGION INote 1 EXAMINATION VOLUME INote 1n SheD lorhad) dning region C-0-E-F-G Atachment wold nglon No2e cylndar rgion A-B-O-H Nozzle Inside corner region M-N-O-NOlES:

11) ExadnatbnregionIdenffl forhei efdiffrenitingtecceptaetndadsHVW4512

42) Exanintlon volumes may be detramined elther by 4rece measurements on th compcnernt or by meesuremants bed on design drawings.

a FIG. 3 NOZZLE IN SHELL OR HEAD I (Examination Zones I Set-On Type Noes Joined by ull Penetration Corner Welds)

II iII 1032 SUPP. - NC tII

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