NRC-98-0060, Forwards Relief Request Update for First 10-Yr Interval ISI non-destructive Exam Program.Util Requests Review & Approval of Relief Requests by 980710 to Support RF06 Scheduled to Begin in Aug 1998
| ML20217A341 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/16/1998 |
| From: | Gipson D DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-98-0060, CON-NRC-98-60 NUDOCS 9804220238 | |
| Download: ML20217A341 (44) | |
Text
4 Douglas H. Gipson l Senior Vice l' resident, Nuclear Generation
! Fermi 2 6 W North Daie liw) , New port, h higan 48166 Tel: 313MRS201 Fax, dl3.5M4172 April 16,1998 Detroit Edison NRC-98-0060 .p' 10CFR50.55a l
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l U. S. Nuclear Regulatory Commission l Attention: Document Control Desk l Washington D C 20555-0001 l
Reference:
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
Subject:
Relief Request Update for the First Ten-Year Interval Inservice Insoection (ISI) Non Destructive Examination (NDE) Procram l
l Pursuant to 10CFR50.55(a)(3), Detroit Edison is requesting approval of the attached l Relief Requests. Fermi 2 personnel have identified issues during the performance of inservice inspection where alternatives to ASME Section XI 1980 including the Winter 1981 Addenda are believed to be appropriate. The Relief Requests describe
, specific conditions which would result in hardship or unusual difficulty without a l compensating increase in the level of quality and safety. Detroit Edison will incorporate these Relief Requests into the ISI NDE Program upon receipt of your approval. These Relief Requests are needed to support Refueling Outage 6 (RF06) which is the last scheduled outage of the first ten-year interval. Detroit Edison l
requests review and approval of these relief requests by July 10,1998 to support RF06 scheduled to begin in August,1998.
Should you have any questions or require additional information, please contact Mr. Norman K. Peterson of my staff at (734) 586-4258.
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9804220238 980416 -
.p Enclosures . v U 's a cc: A. B. Beach B. L. Burgess hbj
~- ;I G. A. Harris l
A. J. Kugler Supervisor Electric Operators, Michigan Public Service Commission A Irn:I:nero Company i t j
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ENCLOSURES l FERMI 2 NRC DOCKET NO. 50-341 j NRC LICENSE NO. NPF-43 RELIEF REQUESTS l
RR-Al AND RR-A16 TO RR-A24 i
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RELIEF REQUEST RR-Al REVISION 1 l l
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! RELIEF REQUEST RR-Al REVISION 1 l
l l COMPONENT FUNCTION / DESCRIPTION:
Pressure Retaining Reactor Pressure Vessel (RPV) Shell Welds (See Table 1) l l
l SYSTEM:
l Reactor (B11) l l
! ASME CODE CLASS:
Class 1 i
ASME SECTION XI REOUIREMENTS:
Subsection IWB, Table IWB 2500-1, Examination Categ g B-A, Item No.'s Bl.10 through Bl.40, require volumetric examination of RPV weld and base material regions l described in figures IWB-2500-1 through 2500-3 for pressure retaining welds in the l reactor pressure vessel each inspection interval.
This relief request is being resubmitted to address weld coverage requirements specified in 10CFR50.55a(g). Where ASME Section XI requires essentially 100% weld length l coverage in IWB-2500-1, Note (2), the NRC has stated that greater than 90% coverage is l acceptable providing any limitation is due to part geometry or interference by another component.
l l BASIS FOR RELIEF:
Revision 0 of relief requests RR-Al and RR-A2 documented limitations based on both the installed ultrasonic examination system which used pole tracks for scanning and part l geometry. During RF-02 Fermiimplemented the use of an automated examination l system that uses a magnetic wheel scanning device which maximizes coverage to the i extent possible using current technology. Limitations to automated scanning of RPV shell welds have been essentially eliminated except where physical obstructions are present. Manual examinations may also be perfomied where vessel configuration makes use of the automated system impractical. Current limitations are based only on configuration or interference from other components. Table 1 identifies the welds with limitations encountered or expected and the cause of the limitation (see attached figures).
I With the exception ofinaccessible welds, the largest expected limitation is at the lower shell course to lower intermediate shell course (weld 1-313 - 54% complete.). This limitation occurs because the transducer package cannot maintain contact in the area of the shell thickness transition. The most critical area, at the inside surface of the exam zone, is covered. The stress level of this weld is approximately % of the longitudinal shell welds. BWRVIP-05 provides a strong technical argument that circumferential welds should not be included in the exam population. Some plants (e. g., Brunswick-2, Hope Creek, Peach Bottom-3, and Perry) have been granted technical relief from performance of all circumferential shell welds for at least two cycles while BWR VIP-05 Page 1 of 6
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l l is being evaluated. Fermi intends to apply state-of-the-art techniques to complete at least one inservice examination of all accessible welds.
Composite coverage of critical RPV longitudinal seam welds including thoae in the RPV beltline region will be greater than 90% of the overall length. Further increases in coverage are not practical because of RPV configuration. Therefore Fermi is requesting relief from the greater than 90% coverage requirement where vessel configuration or interference from other components makes coverage using current technology impractical.
ALTERNATIVE EXAMINATION:
Leakage testing and visual examination will be conducted at each refueling outage in accordance with Section XI, Examination Category B-P. No attemative nondestructive i examinations are proposed. Each weld listed was or will be examined to the greatest l extent practical using current technology.
APPLICABLE TIME PERIOD Reliefis requested for the first 10-year inspection interval.
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RR-Al Table 1 LIMITED EXAMINATIONS Category Weld Percentage Limitation Description
/ Item Identification Complete B-A/Bi.11 1313 ~54% Thickness transition between shell Vessel Cire. courses Weld B-A/B l.21 5-306 Inaccessible CRD Penetrations Head Cire. Weld (Dollar plate)
B-A/Bl.22 1-319A ~80% Top Head Lifting Lugs Head Cire. Weld B-A/Bl.22 1-319C ~80% Top Head Lifting Lugs Head Circ. Weld B-A/Bl.22 1-319E ~80% Top Head Lifting Lugs IIcad Cire. Weld B-A/Bl.22 1-319G -80% Top Head Lifting Lugs liead Cire. Weld B-A/Bl.22 2-306A Inaccessible Bottom head CRD Penetrations and Head Cire. Weld Skirt Attachment Weld B-A/B l.22 2-306B Inaccessible Bottom head CRD Penetrations and Head Cire. Weld Skirt Attachment Weld ,
B-A/Bl.22 2-306C Inaccessible Bottom head CRD Penetrations and Head Cire. Weld Skirt Attachment Weld B-A/Bl.22 2-306D inaccessible Bottom head CRD Penetrations and Head Cire. Weld Skirt Attachment Weld B-A/B l.22 2 306E Inaccessible Bottom head CRD Penetrations and Head Cire. Weld Skirt Attachment Weld ,
B-A/Bl.22 2 306F Inaccessible Bottom head CRD Penetrations and Head Cire. Weld Skirt Attachment Weld B-A/B l.22 2-306G Inaccessible Bottom head CRD Penetrations and 11ead Cire Weld Skirt Attachment Weld B-A/B l.30 13-308 60 % RPV Flange Configuration (coverage Shell to Flange augmented by scan from flange seal surface)
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Enclosure to l NRC-98-0060 Page 3 RELIEF REQUEST RR-A16 i
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RELIEF REQUEST RR-A16 i
COMPONENT FUNCTION / DESCRIPTION:
Class 1,2, & 3 Pressure Retaining Piping & Components SYSTEM:
All systems included in the ISI NDE Program ASME CODE CLASS:
Class 1,2, and 3 ASME SECTION XI REOUIREMENTS: ASME Section XI,1980 Edition including the Winter 1981 Addenda, Subsection IWA-4000 requires hydrostatic pressure tests for welded repairs and replacements unless specifically exempted in IWA-4400.
BASIS FOR RELIEF: Code Case N 416-1 (copy attached)
ALTERNATIVE EXAMINATION: Code Case N-416-1 allows for the performance of test at nominal operating pressure in lieu of a hydrostatic pressure test required by IWA-4000 providing the following requirements are met.
1 (a) NDE shall be performed in accordance with the methods and acceptance 1 c J.a of the applicable Subsection of the 1992 Edition of Section III.
(b) Prior to or immediately upon return to service, a visual examination (VT-2)
- shall be performed in conjunction with a system leakage test, using the 1992 Edition of Section XI, in accordance with paragraph IWA-5000, at nominal operating pressure and temperature, j I
(c) Use of the Code Case shall be documented on the NIS-2 form.
The NRC has indicated the intention to accept this Code case in Draft Regulatory Guide DG-1050, issued February 1997. A supplementary requirement to perform additional surface NDE on the root-pass layer of butt and socket welds where the surface examination method is selected for Class 3 components is included.
Fermi will use the Code Case with this additional stipulation of DG-1050 until it is approved by the NRC and incorporated into Regulatory Guide 1.147. At that time, this relief request will expire and Fermi will use the Code Case as approved by the NRC.
i APPLICABLE TIME PERIOD: Reliefis requested for the remainder of the first 10-year interval or until Code Case N-416-1 is incorporated into Regulatory Guide 1.147.
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N-4iG=1
, CASEE CF ASME BOILER AND PRESSURE YE55EL CODE t
Approval Date:Fehnaary 15.1994 See Nwnene indes for esaketion and any teeffirmetlen detes.
Case N 4161 placement items by welding, a system leakage test may Alternative Pressure Test Requirement for Walded be used provided the following requirements are met.
Repairs or Installation of Replacement Items by (a) NDE shall be %: formed .in accordance with the Welding, Class I,2 and 3 methods and accepan'c e criteria of the applicable Sub.
Section XI. Division I section of the 1992 Edition of Section III.
(6) Prior to orimmediately upon rerum to service, a visual cammination (VT-2) ahall be performed in con.
Inguiry: What alternative pressure test may be per-junction with a system leakage test using the 1992 Edi-formed in lieu of the hydrostatic pressure test required tion of Section XI. in accordance with para. IWA 5000, by para.1WA 4000 for welded repairs or installation of at nominal operating pressure and temperature.
replacement items by welding?
(c) Use of this Case shall be documemed on an NIS-2 Form.
Reply: It is the opinion of the Committee that in lieu If the previous version of this case were used to defer of performing the hydrostatic pressure test required by a Class 2 hydmstatic test, the deferred test may be clim-para. IWA-4000 for welded repairs orinstallation of re- insted when the requirements of this revision are met.
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Enclosure to NRC-98-0060 Page 4 l i
RELIEF REQUEST RR-A17 l l
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! RELIEF REQUEST RR-A17 COMPONENT FUNCTION / DESCRIPTION:
l Class 1,2, & 3 Pressure Retaining Piping & Components SYSTEM:
All systems included in the ISI NDE Program ASME CODE CLASS:
Class 1,2, and 3 ASME SECTION XI REOUIREMENTS: ASME Section XI,1980 Edition including the Winter 1981 Addenda, Tables IWX-2500-1 for Examination Categories B-P, C-H, D-A, D-B, and D-C require performance of a hydrostatic pressure test once during each ten-year inspection interval.
BASIS FOR RELIEF: Code Case N 498-1 (copy attached)
ALTERNATIVE EXAMINATION: Code Case N-498-1 provides the following alternative requirements that allow VT-2 examinations to be performed at system / component nominal operating pressure in lieu of hydrostatic test pressures.
(a) Category B-P (1) A system leakage test (IWB- 5221) shall be conducted at or near the end of each inspection interval, prior to reactor startup.
(2) The boundary subject to test pressurization during the system leakage test shall extend to all Class 1 pressure retaining components within the system boundary.
(3) Prior to performing the VT-2 examination, the system shall be pressurized to nominal operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for noninsulated systems. The system shall be maintained at nominal operating pressure during performance of the VT-2 examination.
(4) Test temperatures and pressures shall not exceed limiting conditions for the hydrostatic test curve as contained in the plant Technical Specifications.
(5) The VT-2 visual examination shall include all components within the l boundary identified in (a)(2) above.
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. 1 L (b) Category C-H !
- (1) A system pressure test shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection interval ofInspection program B.
(2) The bounday subject to test pressurization during the system pressure test shall extend to all Class 2 components included in those portions of systems required to operate or support the safety system function up to and including the first normally closed valve, including a safety or relief valve, l or valve capable of automatic closure when the safety function is required.
(3) Prior to performing the VT-2 visual examination, the system shall be pressurized to nominal operating pressure for a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for noninsulated systems. The system ,
shall be maintained at nominal operating pressure during performance for ('
the VT-2 visual examination.
(4) The VT-2 visual examination shall include all components within the boundary identified in (b)(2) above.
(5) Test instrumentation requirements ofIWA-5260 are not applicable.
(c) Categories D-A, D-B, & D-C (1) A system pressure test shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection interval ofInspection Program B.
(2) The boundary subject to test pressurization during the system pressure test shall extend to all Class 3 components included in those portions of systems required to operate or support the safety system function up to and including the first normally closed valve, including a safety or relief valve, or valve capable of automatic closure when the safety function is required.
(3) Prior to performing the VT-2 visual examination, the system shall be pressurized to nominal operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10- minutes for noninsulated systems. The system shall be maintained at nominal operating pressure during performance of the VT-2 visual examination.
(4) The VT-2 visual examination shall include all components within the -
boundary identified in (2) above.
(5) Test instrumentation requirements ofIWA-5260 are not applicable.
The NRC has indicated the intention to accept this Code case in Draft Regulatory Guide DG-1050 issued February 1997. Fermi proposes use of Code Case 498-1 as published by the ASME Committee, until it is approved by the NRC and incorporated into Regulatory Guide 1.147. At that time, this relief request will expire and Fermi will continue use of the Code Case as approved by the NRC.
APPLICABLE TIME PERIOD: Reliefis requested for the remainder of the First 10-year interval or until Code Case N-498-1 is incorporated into Regulatory Guide 1.147.
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CASE 4
N-498-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: May 11,1994 See NumericalIndex for expiration and any reemrmation dates.
Case N-498-1 (2) The boundary subject to test pressurization Alternative Rules for 10-Year System Hydrostatic during the system pressure test shall extend to all Testing for Class 1,2, and 3 Systems Class 2 components included in those portions of sys.
Section XI, Division 1 tems required to operate or support the safety system function up to and including the first normally closed Inquiry: What alternative rules may be used in lieu valve, including a safety or relief valve, or valve ca-
, of those required by Section XI, Division 1. Table pable of automatic closure when the safety function
(' IWB-2500-1, Category B-P, Table IWC-2500-1, Cat- is required. {
egory C-H and Table IWD-2500-1, Categories D-A, (3) Prior to performing the W 2 visual exami-D B, and D-C, as applicable, for the 10-year system nation, the system shall be pressurized to nominal hydrostatic test? operating pressure for a mmimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for in-sulated systems and 10 minutes for noninsulated sys-tems. The system shall be maintained at nominal op-erating p during performance of the VT-2 Reply: visual ernmination.
(a) It is the opinion of the Committee that as an (4) De W-2 visual exammation shall include alternative to the 10-year system hydrostatic test re- all cornponents within the boundary identified in quired by Table IWB-2500-1, Category B P, the fol- (b)(2) above.
lowing rules shall be used. (S) Test instrumentation requirements of IWA- )
(1) A system leakage test (IWB-5221) shall be 5260 are not applicable.
conducted at or near the end of each inspection in. (c) It is the opinion of the Committee that, as an (D terval, prior to reactor startup, alternative to the 10-year system hydrostatic test re-(2) The boundary subject to test pressurization quired by Table IWD-2500-1, Categories D-A, D-B, during the system leakage test shall extend to all or D-C (D-B for the 1989 Edition with the 1991 and Class 1 pressure retaining components within the sys- subsequent Addenda), as applicable, the following tem boundary. rules shall be used.
(J) Prior to performing the VT-2 visual exami- (1) A system pressure test shall be conducted at nation, the system shall be pressurized to nominal or near the end of each inspection interval or during operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated the same inspection period of each inspection inter-systems and 10 minutes for noninsulated systems. val of Inspection Program B.
The system shall be maintained at nominal operating (2) The boundary subject to test pressurization pressure during performance of the W-2 visual ex- during the system pressure test shall extend to all amination. Cla-s 3 components included in those portions of sys-t (4) Test temperatures and pressures shall not tems required to operate or support the safety system exceed limiting conditions for the hydrostatic test function up to and including the first normally closed curve as contained in the plant Technical Specifica- valve, including a safety or relief valve, or valve ca-tions. pable of automatic closure when the safety function (5) The VT 2 visual examination shall include is required.
all components within the boundary identified in (3) Prior to perfonning the W-2 visual exami-(a)(2) above. nation, the system shall be pressurized to nominal (6) Test instrumentation requirements of IWA- operating pressure for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated 5260 are not applicable. systems and 10 minutes for noninsulated systems.
(b) It is the opinion of the Committee that, as an ne system shall be maintainea at nominal operating alternative to the 10-year system hydrostatic test re- pressure during performance of the VT-2 visual ex-quired by Table IWC-2500-1, Category C H, the fol- amination.
lowing rules shall be used:
(4) The VT-2 visual ernmination shall include (1) A system pressure test shall be conducted at all components tvithin the boundary identified in or near the end of each inspection interval or during (c)(2) above.
the same inspection period of each inspection inter- (5) Test instrumentation requirements of IWA-val of Inspection Program B. 5260 are not applicable.
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Enclosure to NRC-98-0060 l Page5 l
RELIEF REQUEST RR-A18 l
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l RELIEF REQUEST RR-Al8 COMPONENT FUNCTION / DESCRIPTION:
Class 1,2, & 3 Pressure Retaining Piping & Components SYSTEM:
All systems included in the ISI NDE Program ASME CODE CL, ASS:
Class 1,2, and 3 ASME SECTION XI REOUIREMENTS: ASME Section XI,1980 Edition including the Winter 1981 Addenda, Tables IWB-2500-1, IWC-2500-1 and IWD-2500-1 require the performance of a VT-2 examination during the specified pressure tests. IWA-2300 requires that personnel performing the VT-2 examinations be qualified by the owner or i the owner's agent in accordance with owners qualification program having levels of competency comparable to SNT-TC-1 A as defined in ANSI N45.2.6.
l BASIS FOR RELIEF: The use of Code Case N-546 (copy attached) will eliminate the l need to qualify VT-2 examination personnel in the same manner as NDE personnel. VT-l 2 requires no special knowledge of technical principles, it is simply an inspection for evidence ofleakage. No special skills or technical training are required in order to l observe water dripping from a component or bubbles forming on a surface wetted with a i leak detection solution. Therefore, qualification in accordance with the provisions of the
' Code Case will not present any reduction in quality or safety. In fact, it will facilitate the qualification of those personnel most familiar with the walkdown of plant systems.
l ALTERNATIVE: Code Case N-546 provides the following alternative qualification j rules for personnel such as licensed and nonlicensed operators, local leak rate personnel, j
system engineers, and inspection and nondestructive examination personnel. i I
(a) The individual must have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant walkdown experience such as l that gained by licensed and nonlicensed operators, local leak rate personnel, i system engineers, and inspection and nondestructive examination personnel, j (b) At least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of training on Section XI requirements and plant specific j procedures for VT-2 visual examination will be completed. j l (c) Vision test requirements ofIWA-2231 (1995 Edition) will be satisfied. 1 I
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In addition, the following actions will ensure consistent quality in the performance of l l
t examinations. I I
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- 1. Records of the training and qualifications specified in Code Case N-546 will be provided and maintained in accordance with the Fermi written practice. l
- 2. Visual examination will be conducted in accordance with specific written procedures. l i
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- 3. Visual examination procedures will provide for a documented independent review and evaluation of test results.
APPLICABLE TIME PERIOD: Reliefis requested for the remainder of the First 10-year interval.
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e CASE N-546 CASES OF ASME Boll.ER AND PitE55UAE VE55Et, CODE Approval Date: August 24, 1995 See NumencalIndex for exoiration and any teatformation dates.
Case N 546 -
. accordance with the referenced standard (i.e.. ANSI Alternative Requirements for Qualification of N45.2.6. ASNT SNT TC 1 A. or ASNT CP-189) iw.
VT 2 Examination Personnel vided the examination personnel are qualified in accord.
Section XI, Division I ance with the following requirements.
(a) At least 40 hrs plant walkdown expenence. such Inquiry. What alternative to the requirements of as that gained by licensed and nonficensed operators.
IWA 2300 may be used for qualification of VT 2 visual I cal leak rate penonnel, nstem ensimen, and inye.
examination persnnnel? tion and nondestructive examination personnel.
(h) At least 4 hrs of training on Section XI require.
ments and plant specific procedures for VT 2 vnual Repiv h is the opinion of the Committee that VT. exerninstion.
l 2 visual examination personnel need not be qualified (c) Vision test requirements of IWA-2321.1995 nor certified to comparable levels of competence in Edition. 1 N
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Enclosure to NRC-98-0060 l Page 6 l
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RELIEF REQUEST RR-A19 1
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l RELIEF REQUEST l RR-A19 j COMPONENT FUNCTION / DESCRIPTION:
Insulated portions of High Pressure Coolant Injection (HPCI) turbine / exhaust lines, and associated vents and drains. I l
SYSTEM:
High Pressure Coolant Injection (E41) l l ASME CODE CLASS: l l
Class 2 ASME SECTION XI REOUIREMENTS: Section XI Code Case N-498 (Alternative Rules for 10-year Hydrostatic Pressure Testing) which is included in the Fermi Inservice Inspection Program, requires a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> hold time after attainirg nominal operating pressure conditions for insulated systems.
I HASIS FOR RELIEF:
l As part of the Emergency Core Cooling System (ECCS), the HPCI system is not required to operate during normal plant operation. However, the system is periodically tested in accordance with applicable inservice testing and Technical Specification requirements.
These periodic tests are conducted to verify the operability of system components. The quarterly operability test (24.202.001) normally includes about 30 minutes of pump run time. In order to satisfy ASME Section XI hold time requirement, the test would require a HPCI pump run for greater than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (hold time plus exam time). Running the HPCI pump for this duration is not practical and represents an undue hardship on the facility I
without a compensating increase in the level of quality and safety.
l Operating the HPCI pump for this amount of time would subject the facility to excessive heat loads. Control of these heat loads would require the operation of additional ECCS subsystems to remove heat from the suppression pool.
Extended operation of the HPCI pump would clso challenge the Technical Specification limitation on maximum suppression pool P.orus) water temperature. The Fermi Technical Specifications require the torus average water temperature to be maintained less than 105 F during testing which adds heat to the torus. Operating the HPCI pump for a period substantially longer than the system operability test could cause this temperature to be exceeded. If the torus average water temperature exceeds 110 F, Technical Specifications require the reactor mode switch to be placed in the shutdown position.
Removal of the insulation from the subject components in order to use the ten minute hold time allowed by the Code or Code Case N-498, would be equally burdensome. The impacts associated with insulation removal and reinstallation, include personnel radiation Page1of2
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. exposure, radwaste generation, manpower resource, and monetary costs, are not justified by a compensating increase in the level of quality and safety, k
Performing a HPCI system hydrostatic test per IWA 3213 (d) would also be burdensome. 1 A hydrostatic test would require installation of blank flanges and temporary pipe l supports, and gagging or removal of relief valves. The time, costs and radiation exposure )
incuired in carrying out a hydrostatic test would result in a hardship without a compensating increase in the level of quality and safety. 4 Other inspection and test activities performed that verify system integrity include the l - following:
1
! e Quarterly inservice testing of HPCI raises the pressure of the system to nominal I operating conditions. Any leakage would migrate through the insulation over a period of time and would become evident.
- Nondestructive examination of 25% or 14 of the circumferential welds on this line receive a surface examination per Section XI Table IWB-2500-1, Category C-F. All of the weld selections on this line were random selections because none of the welds met the moderate or high stress criteria.
i e Every 18 months this line is inspected in accordance with the Fermi Leakage l Reduction Program per Technical Specification 6.8.5.
ALTERNATIVE EXAMINATION:
The system pressure test described in Code Case N-498 will be conducted as required, except that a 20 minute hold time will be used in lieu of the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> hold time requirement.
The 20 minute hold time will allow time for abnormal leaks to migrate through the l insulation without challenging the Technical Specification limitation on maximum torus j water temperature.
Any evidence of abnormal leakage will be investigated by locally removing insulation.
APPLICABLE TIME PERIOD:
Reliefis requested for the first 10-year inspection interval.
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Enclosure to NRC-98-0060 Page 7 RELIEF REQUEST RR-A20 l
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I RELIEF REQUEST l RR-A20 l COMPONENT FUNCTION / DESCRIPTION:
l Piping Integral Attachment Welds (Stiffeners)Inside The Suppression Pool (Torus)
RHR Torus Penetrations X-210A, and B and Core Spray Penetration X227A, and B ISI Isometric Drawings: 1 6M7213160 RHR Test Line & Suppression Chamber Spray Header (North) l 6M7213161 RHR Test Line & Suppression Chamber Spray Header (South) '
6M7213145 North Core Spray Min / Low Flow By-pass & Test Line 6M7213150 North Core Spray Min / Low Flow By-pass & Test Line
, SYSTEMS:
Residual Heat Removal (El 1) and Core Spray (E21)
ASME CODE CLASS: )
Class 2 l ASME SECTION XI REOUIREMENTS:
ASME Section XI,1980 Edition including the Winter 1981 Addenda, Subsection IWC,
- Table IWC-2500-1, Category C-C requires surface examination ofintegrally welded attachments that have a base metal design thickness of %" or greater.
BASIS FOR RELIEF:
Fermi design includes torus stiffener pads and gusset plates that are welded to the system piping that penetrates the torus. Because of the base metal thickness (>3/4") these welds require a surface examination.
The interior surfaces of the torus are coated to prevent corrosion of surfaces that are exposed to the humid atmosphere. Performing a magnetic particle examination of the torus stiffener pads and gusset welds would require this coating to be ground off and reapplied after the examinations are complete. Grinding off the coating to allow a proper examination takes a substantial amount of time and the grinding process could result in paint chips and dust entering the torus pool.
The penetrations are over water surface and are not accessible from the cat-walk.
Gaining accessibility to the penetrations would require a suspended scaffold to be built and catch material hung to prevent debris entry into the torus pool. Craft personnel have estimated that it would take six laborers three shifts per location to build this type of structure. Performance of this work would not be consistent with good ALARA practices.
I Both of the subject piping systems are open ended into the torus. The ASME Section XI 1989 Edition currently approved by the NRC and incorporated into 10 CFR 50.55a by Page1of2
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reference and later Editions through the 1995 Edition pending NRC approval, provide exemption from examination for open ended piping beyond the last shutoff valve (IWC -
1220). When Fermi completes the required program update these welds will no longer require examination.
These penetrations also have integral attachments on the torus external surface that require examination per the 1980 Edition of ASME Section XI. Examination of these external attachment welds would indicate any damage to the piping system at the penetrations that would prevent the fluid from reaching the torus.
Performance of these exams presents an undue hardship without a compensating increase in the level of quality or safety. Therefore Fermi is requesting relief from the examination requirement.
1 AL,TERNATIVE EXAMINATION:
{
Fermi proposes that in addition to the examination of the external portion of the torus j stiffener, that a remote VT-3 examination to the extent practical from the catwalk using l binoculars. l APPLICABLE TIME PERIOD:
Reliefis requested for the first 10-year inspection interval. I x - /
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/ V Typical Torus Internal Stiffener Sketch i l l l l
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4 RELIEF REQUEST RR-A21 l 1
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RELIEF REQUEST RR-A21 COMPONENT FUNCTION / DESCRIPTION:
Piping Integral Attachment Welds (see attached Table for identification)
SYSTEMS: '
Main Steam (B21)
Reactor Recirculation (B31)
Residual lleat Removal (El1)
Core Spray (E21)
Feedwater (N21)
ASME CODE CLASS:
Class 1 ASME SECTION XI REOUIREMENTS:
ASME Section XI,1980 Edition including the Winter 1981 Addenda, Subsection IWB, Table IWB-2500-1, Category B-K-1, item B10.10 requires surface examination of all integrally welded piping attachments that have a base metal design thickness of 5/8" or greater.
BASIS FOR RELIEF:
The structural integrity of the piping pressure boundary including welded attachments was demonstrated during construction by meeting the requirements of ASME Section Ill.
Design, fabrication, installation, inspection, and examination satisfied the appropriate Code requirements. Construction examinations used techniques similar to those used for inservice examinations (surface NDE methods). During the Fermi 'Preservice Inspection volumetric examinations were also performed. The construction and preservice examinations were completed prior to installation of the support members. Therefore the extent of accessibility is not specifically know until the first inservice examination is completed. Integral attachment locations remaining to be examined were compared to locations similar in design and any expected limitations are listed in the table.
The pressure boundary passed the required preservice hydrostatic test and all subsequent pressure tests through the fifth refueling and inspection outage (RF-05). .
l Complete examinations meeting the coverage requirements of ASME Code Section XI are performed on welds of similar configurations which utilized the same weld l techniques, procedures and materials. The welds with complete examinations are spread i throughout the Class I systems and subject to similar operating and environmental l conditions as the partially examined welds. No service related discontinuities have been j discovered on welds fully examined or those partially examined. Additionally, there is no industry history of ASME Class I service induced attachment weld failures.
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4 It is reasonable to expect that the unexamined portions are also acceptable.
The absence of significant integral attachment weld problems is further evidenced by ASME Code Case N-509 which allows a reduced sample size of only 10% of all integral attachments. This Code Case has been approved at other nuclear facilities (e. g., Duane Arnold) and was incorporated into the 1995 Addenda of ASME Section XI. Fermi has not requested to implement this Code Case, which would reduce the inspection population to approximately 10 locations, during our first inspection interval. We are asking for partial relief of coverage on specific locations included in the 30 locations where examinations can be performed.
The average surface coverage for the incomplete examinations completed is 73%. To i obtain complete Code coverage at each location, the component support would have to be {
disassembled and the pipe clamp assembly removed. Temporary line support would have to be evaluated by engineering and installed as necessary. The additional engineering resources, time, field personnel, and radiation exposure required to attain full coverage is I not consistent with the minimal risk associated with these items, as reflected by plant and industry experience as well as current Code requirements.
Performance of these exams presents an undue hardship without a compensating increase in the level of quality or safety. Therefore Fermi is requesting relief from the examination requirement.
ALTERNATIVE EXAMINATION:
Fenni proposes that in addition to the surface examination of the exposed portion oflug welds and required base metal volume, that a supplemental visual examination to the extent practical by the examiner be performed.
APPLICABLE TIME PERIOD:
Reliefis requested for the first 10-year inspection interval.
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RR-A21 Table 1 l Limited Examinations Category Weld Percentage Limitation Alternate
/ Item Identification Complete Description Examination B-K-1/B 10.10 FW-PS-2-B2- 70 % Clamp at spring B215353 Supplemental AAl-AA4 Expected HB1 Visual B-K l/B10.10 FW-PS-2-D2- 70 % Clamp at spring B21-5355- Supplemental AAl-AA4 HDI Visual B-K 1/B10.10 FW-RD-2-A2- 68% Clamp at spring B315357- Supplemental ALl-AL4 HA2 Visual B-K 1/B!0.10 FW-RD-2-B2- 68% Clamp at spring B31-5359- Supplemental .
All-AL4 Expected HB2 Visual B-K-l/B 10.10 S W-RS-2-A2-~W4 - 68 % Clamp at spring B31-5357- Supplemental l W7 Expected HAl Visual B-K-1/B l0.10 SW-RS-2-B2- 68 % Clamp at spring B31-5359- Supplemental W6A-W9A HBI Visual B-K-l/B 10.10 PSFW-El 1-2298- 69% per lug Clamp at rigid support Supplemental 833A-F Ell-2298-G04 Visual B K 1/B10.10 PSFW-El 1-2299- 50% per lug Clamp at spring El1-2299- Supplemental 836A-F Expected G03 Visual B-K-l/B10.10 PSFW El1-2299- 50% per lug Clamp at spring El1-2299- Supplemental ,
781A-D G01 Visual l B-K 1/Bl0.10 SW-E l 1 -2327- 90% per lug Clamp at restraint Ell- Supplemental 2WD-2WJ 2327-G03 Visual B-K-1/B 10.10 SW E21-3052- 88% per lug Clamp at spring E213052 Supplemental 2WN-2WR G02 Visual B-K-1/B 10.10 PSFW E21-3052- 84% per lug Clamp at spring E21-3052- Supplemental 803A D G04 Visual B-K 1/Bl0.10 SW-E21-3053- 86% per lug Clamp at spring E21-3053- Supplemental 2WN-2WR G02 Visual B-K l/B10.10 SW E21-3052- 88% per lug Clamp at spring E21-3052- Supplemental 2WS-2WV Expected G09 Visual l
B-K-l/B 10.10 SW-E21 3053- 69% per lug Clamp at spring E21-3053- Supplemental 2WS-2WV GIO Visual B-K-l/B10.10 SW.E21-3053- 88% per lug Clamp at spring E21-3053- Supplemental 795A-795D G08 Visual B-K-1/Blo.10 SW-N21-2336- 86% per lug Clamp Limitation Supplemental 12WC-12WH Visual
, B-K 1/Bl0.10 SW N21-2336- 66% per lug Clamp Limitation Supplemental l 12WJ-12WP Visual l B-K l/B10.10 SW N21-2336- 0% per lug inaccessible for MT due to Supplemental
! 19WB-19WE lug retainers at N21-3537- Visual ,
G29 i B-K-1/B10.10 SW-N21-2336- 90% perlug Clamp at snubber Supplemental 9WB-9WE N21-3536-G29 Visual B-K-1/B 10.10 SW-N21-2336- 90% per lug Clamp at spring N213537- Supplemental 2WC-2WN G26 Visual
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0 Enclosure to NRC-98-0060 Page 9 l
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RELIEF REQUEST RR-A22
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RELIEF REQUEST RR-A22 COMPONENT FUNCTION / DESCRIPTION:
Piping Integral Attachment Welds (see attached Table for identification)
SYSTEMS:
Residual Heat Removal (El1)
High Pressure Coolant Injection (E41)
ASME CODE CLASS:
Class 2 ASME SECTION XI REOUIREMENTS:
ASME Section XI,1980 Edition including the Winter 1981 Addenda, Subsection IWC, Table IWC-2500-1, Category C-C, items C3.10 and C3.20 requires surface examination ofintegrally welded piping attachments that have a base metal design thickness of 3/4" or greater, i BASIS FOR RELIEF:
- The structural integrity of the piping pressure boundary including welded attachments was demonstrated during construction by meeting the requirements of ASME Section III.
i Design, fabrication, installation, inspection, and examination satisfied the appropriate Code requirements c nstruction o examinations used techniques similar to those used for inservice examinatia (surface NDE methods). The construction and preservice examinations were completed prior to installation of the support members. Therefore the extent of accessibility is not specifically known until the first inservice examination is completed. The integral attachment locations remaining to be examined were compared
- to locations similar in design and any expected limitations are listed in the table.
The pressure boundary passed the required preservice hydrostatic test and all subsequent pressure tests through the fifth refueling and inspection outage (RF-05).
Complete examinations meeting the requirements of ASME Code Section XI are performed on welds of similar configurations which utilized the same weld techniques, procedures and materials. The welds with complete examinations are subject to similar operating and environmental conditions as the partially examined welds. No service related discontinuities have been discovered on welds fully examined or those partially examined. Additionally, there is no industry history of ASME Class 2 service induced attachment weld failures. It is reasonable to expect that the unexamined portions are also acceptable.
The absence of significant integral attachment weld problems is further evidenced by ASME Code Case N-509 which allows a reduced sample size of only 10% of all integral attachments. This Code Case has been approved for use at other nuclear facilities and i
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l l was incorporated into the 1995 Addenda of ASME Section XI. Fermi has not requested l to implement this Code Case, which would reduce the inspection population to approximately 19 locations, during the first inspection interval. We are asking for partial relief from coverage of specific locations included in the 40 locations where examinations can be performed.
l l The average surface coverage for the incomplete examinations completed is 87%. To l obtain complete Code coverage, the component support would have to be disassembled l and the pipe clamp assembly removed. Temporary line support would have to be l evaluated by engineering and installed as necessary. The additional engineering l resources, time, field personnel, and radiation exposure required to attain full coverage is not consistent with the minimal risk associated with these items, as reflected by plant and
- industry experience, as well as current Code requirements.
Performance of these exams presents an undue hardship without a compensating increase in the level of quality or safety. Therefore Fermi is requesting relief from the examination requirement.
ALTERNATIVE EXAMINATION:
Fermi proposes that in addition to the surface examination of the exposed portion oflug l welds and required base metal volume, that a supplemental visual examination to the l extent practical by the examiner be performed.
1 APPLICAHLE TIME PERIOD:
l Reliefis requested for the first 10-year inspection interval.
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i RR-A22 Table 1 i
Limited Examinations Category Weld Percentage Limitation Alternate l / Item Identification Complete Description Examination l- C-C/C3.20 PSFW-El 1 3146- 83% per lug Clamp supplemental I
606A-L visual C-C/C3.20 SW-El 1-3151 ~90% per lug Clamp at spring supplemental i 4WE-4WK cxpected Ell-3151-G05 visual C-C/C3.20 SW-El 1-3151- ~90% per lug Clamp at spring supplemental 10WC-10WH expected Ell-3151-G01 visual C-C/C3.20 SW-El 1 3158- 87% per lug Lugs A,C,D, & F supplemental 583A-583F lugs B & E inaccessible due to lug visual l retainers on restraint Ell-3158-G52 '
C-C/C3.20 SW-El 1-3158- 85% per lug Clamp at spring El13158- supplemental 7WC-7WII G51 visual ;
C-C/C3.20 PSFW-E41-3162- 90 % Clamp at snubber E41- supplemental l
583A F 3162-G20 visual {
C-C/C3.20 PSFW-E41-3172- 90 % Clamp at snubber E41- supplemental l 592A-D 3172-Gl9 visual C-C/C3.20 PSFW-E41-3172- significant lug retainers at E41-3172- supplemental 625A-625D limitation G14 visual possible i i
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i RELIEF REQUEST RR-A23 l
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s RELIEF REQUEST RR-A23 COMPONENT FUNCTION / DESCRIPTION: l Pressure Retaining Piping Welds (see attached Table for identification numbers)
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i SYSTEMS: !
Main Steam (B21)
Reactor Recirculation (B31)
Residual IIcat Removal (El1) l Feedwater (N21)
ASME CODE CLASS:
Class 1 i
l ASME SECTION XI REOUIREMENTS: i ASME Section XI,1980 Edition including the Winter 1981 Addenda, Subsection IWB, Table IWB-2500-1, Category B-J, item 9.11 requires a volumetric and surface l examination of circumferential piping welds greater than or equal to 4" diameter. Item B9.12 also requires examination of any intersecting longitudinal seams. Note 3 of Table IWB-2500-1 requires that the examination include essentially 100% of the weld length and volume specified in figure IWB-2500-8.
BASIS FOR RELIEF During the course ofinservice examination,6 of 156 Category B-J circumferential welds have been encountered that cannot be fully examined in accordance with ASME Section XI (> 90% oflength and volume).
Technicaljustification is provided for all affected welds as follows:
Main Steam (B21)
Category Weld Percentage Limitation Alternative
/ Item Identification Complete Description Examination B-J/B9.11 SW PS2-B3-A 78% UT Whip Restraint Examine 40% MT accessible area B-J/B9.12 SW-PS2-B3- 100% UT Whip Restraint Examine ALD 42%MT accessible area B-J/B9.11 SW-PS2-C3-A 100% UT Whip Restraint Examine 44%MT accessible area B-J/B9.12 SW-PS2-C3- 100% UT Whip Restraint Examine ALD 42%MT accessible area These carbon steel welds were selected for exam based on a moderate stress category as defined in the Fermi UFSAR. This is a more conservative approach to selecting welds than a supplemental random selection to bring the examination sample to 25%, as Pageiof5 m
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- specified in the Code. The moderate stress category results in a main stes a t spection sample of 42% of all circumfbrential welds. The increased inspection sai ple is comprised of welds with the highest probability of failure and results in add? .surance !
of system integrity. The inspection sample set is larger than required by ASME Code and l will provide for reliable detection of representative degradation. ' Inspections completed :
through the fifth refueling outage (RF-05) have detected no service induced defects in any carbon steel piping welds subject to ISI. There is no decrease in the ability to detect system degradation as a result of this limitation. Removing the obstructions to facilitate )
l further inspection of these welds would increase manpower, dose, and monetary costs l without a compensating increase in plant safety. I i
l Reactor Recirculation (B31)
Category Weld Percentage Limitation Alternative l
/ Item Identification Complete Description Examination B-J/B9.11 FW-RS-2-A5 86% PT Insulation Support Examine l >90% UT Bracket and Weld accessible area This stainless steel weld is a low stress random selection. The weld was given an IGSCC mitigation treatment (Induction Heat Stress Improvement) as defined in NUREG 0313 Rev. 2, prior to service. Fermi has also implemented an augmented inspection program in accordance with Generic Letter 88-01. The combined Code and GL-88-01 selections result in greater than 50% of all Reactor Recirculation System welds being inspected each interval. The inspection sample set is sufficiently large to provide for reliable detection of representative degradation. There is no decrease in the ability to detect system degradation as a result of this limitation. Removing the obstructions to facilitate further inspection of these welds would increase manpower, dose, and monetary costs without a compensating increase in plant safety.
RHR (El1)
Category Weld Percentage Limitation Alternative
/ Item Identification Complete Description Examination B-J/B9.11 FW El1-2299- >50% UT Tee Configuration Examine 0W1 100% MT Limits UT Only accessible area This carbon steel tee-to-pipe weld is a high stress weld selection. The weld was radiographed during construction and satisfied Section III acceptance criteria. There are also six other high stress locations in the RHR system that will be fully examined. The surface of the weld is fully accessible for magnetic particle examination. Ultrasonic examination is limited to effective scanning from the pipe side only because of reducing-tee configuration. The ultrasonic examination covers all of the base material on the pipe side of the weld and the weld root area. Because the examination covers the weld root area which is the thinnest section of this pipe-to-tee weld zone, there is adequate i assurance that fatigue cracking could be detected. Additionally, two adjacent welds on both sides of this weld are fully examined. This weld is also subject to pressure testing each refueling outage in accordance with Category B-P Page 2 of 5
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t Radiographic examination was considered as an alternative but has the following limitations. The radiation emitted from the pipe would negatively impact the sensitivity of the examination. Performance of the examination would take approximately one shift to complete and prevent other outage activities from be performed during the radiography evolution. Radiographic examination of the weld would require draining of the recirculation loop piping and a portion of RIIR. This would require pluggingjet-pumps
! and recirc suction lines inside the vessel. RIIR Shutdown cooling would not be available i to remove decay heat. For these reasons radiography is not a feasible alternative for the l ultrasonic examination.
i Because of the acceptable initial condition, pressure test history and continued performance, the capability to complete the surface exam and greater than 50 percent of l the exam volume including the root area, it is reasonable to conclude there is no significant impact on the level of plant quality and safety by the reduction in volumetric coverage of this weld.
Feedwater (N21)
Category Weld Percentage Limitation Alternative
/ Item Identification Complete Description Examination B-J/B9.11 FW-N21-2336- ~76% UT Tee to Valve Examine 0W1 100% MT Configuration accessible area This carbon steel tee-to-pipe weld is a moderate stress weld selection category as defined in the Fenni UFSAR. The moderate stress category results in an inspection sample of 28% of all Category B9.11 circumferential welds. The increased inspection sample is comprised of welds with the highest probability of failure and results in added assurance of system integrity. This is a more conservative approach to selecting welds than a '
supplemental random selection to bring the examination sample to 25%, as specified in the Code. The inspection sample set exceeds ASME Code requirements and is sufficiently large to provide for reliable detection of system degradation.
The weld was radiographed during construction and satisfied Section III acceptance criteria. The valve body and weld ends were also radiographed in accordance with NB 2570. The surface of the weld is fully accessible for magnetic particle examination.
Ultrasonic examination is limited because of tee-to-valve configuration. The ultrasonic examination does cover the weld and the weld root area in at least one direction base material on the valve side is not fully covered in two directions. The adjacent weld, which is also a moderate stress weld is fully examined. Inspections completed through the fifth refueling outage (RF-05) have detected no reportable service induced defects in any carbon steel piping welds subject to ISI. This weld is also subject to pressure testing each refueling outage in accordance with Category B-P l Because of the acceptable initial condition, pressure test history and continued perfonnance, the capability to complete the surface exam and approximately 50 percent i
of the exam volume including the root area, it is reasonable to conclude there is no significant impact on the level of plant quality and safety by the reduction in volumetric Page 3 of 5
1 coverage of this weld. Because inspection sample exceeds ASME Code requirements, there is no decrease in the ability to detect system degradation as a result of this limitation.
Feedwater(N21)
Category Weld Percentage Limitation Alternative
/ Item Identification Complete Description Examination B-J/B9.11 FW-N21-2336- 50% UT Sweepolet to Valve Examine IWO3 100% MT Configuration accessible area This carbon steel reducer-to-valve weld is a high stress weld selection. The weld was radiographed during construction and satisfied Section III acceptance criteria. The valve l body and weld ends were also radiographed in accordance with NB 2570. There are also eleven other high stress locations (includes terminal ends) in the Feedwater system that will be fully examined. The surface of the weld is fully accessible for magnetic particle examination. Ultrasonic examination is limited to effective scanning from the crown of the weld. The ultrasonic examination covers most of the base material on both sides of l the weld in one direction. The entire weld and root can be scanned in the circumferential direction. Additionally, the high stress weld directly adjacent to this weld is fully examined. This weld is also subject to pressure testing each refueling outage in accordance with Category B-P There are over 50 high stress carbon steel weld selections spread among the systems subject to inservice inspection. The Fermi Class 1 inspection population for all systems ;
exceeds ASME Code requirements by 15 welds because moderate stress welds are j included in the selection basis. The welds that were selected are the most probable i locations for stress related failure. The selection methodology used was more stringent than required by Code. Because of the selection methodology and sample size there is no j reduction in capability to detect system degradation as compared to Code requirements. l Through the fifth refueling outage (RF-05) there have been no service induced defects detected. Industry experience does not indicate cracking of carbon steel butt welds to be a problem.
Radiographic examination was considered as an alternative but is undesirable for the following reasons. Performance of the examination would prevent drywell outage activities from be performed during the radiography evolution and would add critical path time to the outage schedule. The benefit ofincreasing the coverage of this weld by radiographic examination has only a small potential ofincreasing plant safety margin and i a disproportionate impact on expenditures. Since the Fermi inspection program exceeds ASME Code requirements for the sampling program this alternative is not considered to be necessary.
Because of the acceptable initial condition, pressure test history and continued performance, the capability to complete the surface exam and approximately 50 percent Page 4 of 5
e of the Code exam volume, it is reasonable to conclude there is no significant impact on the level of plant quality and safety by the reduction in volumetric coverage of this weld.
l ALTERNATIVE EXAMINATION:
! Examine the welds to the greatest extent possible using appropriate surface and ultrasonic j examination methods.
APPLICABLE TIME PERIOD:
l Reliefis requested for the first 10-year inspection interval.
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9 Enclosure to NRC-98-0060 Page 11 l
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RELIEF REQUEST RR-A24 1
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,s RELIEF REQUEST RR-A24 COMPONENT FUNCTION / DESCRIPTION:
Class 1& 2 Pressure Retaining Longitudinal Piping Welds SYSTEM:
All systems included in the ISI NDE Program ASME CODE CLASS:
Class 1& 2 i
l ASME SECTION X! REOUIREMENTS: ASME Section XI,1980 Edition including l the Winter 1981 Addenda, Table IWB-2500-1, Category B-J, Note 4 requires l examination of at least one pipe-diameter length but not more than 12 inches of each longitudinal weld intersecting the circumferential welds required to be examined by Category B-J. Category C-F requires examination of 2.St of the long seam at the intersecting circumferential weld.
BASIS FOR RELIEF: Longitudinal welds are fabricated during the product form manufacturing process under controlled shop conditions. This results in high quality welds with even stress distribution.
The welds were subjected to full radiography and pressure testing in accordance with ASME Section III.
There has been no history of degradation oflongitudinal seam welds beyond the zone of the intersecting cercumferential weld. When cracking does occur, such as IGSCC in austenitic stainless materials, it initiates and will be evident in the zone of the circumferential weld. The absence of significant longitudinal weld problems is evidenced by ASME Code Case N-524, which has been tentatively approved without restrictions in Draft Guide DG 1050. This Code Case has been approved at other nuclear facilities and .
was incorporated into the 1995 Addenda of ASME Section XI.
Because Code Case N-524 eliminates examination of the longitudinal weld beyond the intersection with a circumferential weld, use of N-524 can significantly reduce examination time requirements, thus reducing the cost of such examinations and unnecessary radiation exposure to examination personnel. In addition to the man-rem savings obtained by reduced examination time. additional radiological benefits can be realized due to the significant reduction cf dose and effort associated with j removing / reinstalling insulation and interferences (component supports) and preparing the welds for examination.
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o ALTERNATIVE EXAMINATION: Code Case N-524 allows for the examination of the intersecting longitudinal weld in the zone required by the circumferential weld as follows:
(a) When only a surface examination is require, examination oflongitudinal piping welds is not required beyond those portions of the welds within the examination boundaries ofintersecting circumferential welds.
(b) When both surface and volumetric examinations are required, examination of longitudinal piping welds is not required beyond those portions of the welds within the examination boundaries ofintersecting circumferential welds provided the ,
following requirements are met: l (1) Where longitudinal welds are specified and locations are known, examination requirements shall be met for both transverse and parallel flaws at the intersection of I the welds and for that length oflongitudinal weld within the circumferential weld !
examination volume; I (2) Where longitudinal welds are specified but locations are unknown, or the I existence oflongitudinal welds is urcertain, the examination requirements shall be met for both transverse and parallel flaws within the entire examination volume of intersecting welds. i APPLICABLE TIME PERIOD: Reliefis requested for the remainder of the First 10-year interval or until Code Case N-416-1 is incorporated into Regulatory Guide 1.147.
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0
( CASE N-524 CASES OF ASME BOILER AND PRESSURE VESSELCODE Approval Date: August 9,1993 s
See NumericalIndex for expiration and any reef &mstion dates.
l Case N 524 '
Alternative Examination Requirements for Iongitudinal Welds in Class 1 and 2 Piping
! Section XI, Division 1 I l
Inquiry: What alternative requirements may be ap-plied to the surface and volumetric examination of longitudinal piping we!O specified in Table IWB-l 2500-1, Examination Category B-J, Table IWC-2500-1, Examination Categories C-F-1 and C-F-2 (Exam-ination Category C-F prior to Winter 1983 Adden-da), and Table IWC 2520, Examination Category C- )
G (1974 Edition, Summer 1975 Addenda)?
Reply: It is the opinion of the Committee that the following shall apply:
(a) When only a surface examination is required, examination of longitudinal piping welds is not re- ;
i quired beyond those portions of the welds within the -
examination boundaries of intersecting circumfer-ential welds.
(b) When both surface and volumetric examina- ;
tions are required, examination oflongitudinal piping :
welds is not required beyond those portions of the welds within the examination boundaries of inter-secting circumferential welds provided the following requirements are met.
(1) Where longitudinal welds are specified and locations are known, examination requirements shall be met for both transverse and parallel flaws at the intersection of the welds and for that length of lon-gitudinal weld within the circumferential weld ex-amination volume; (2) Where longitudinal welds are specified but locations are unknown, or the existence of longitu-dinal welds is uncertain, the examination require-ments shall be met for both transverse and parallel flaws within the entire exaniination volume ofinter-secting circumferential welds.
l 903 SUPP. 6 - NC