NRC 2012-0088, 10 CFR 50.55a Request, Relief Request 1 -RR-4 Re-Examination of the Unit 1 Reactor Pressure Vessel Indication on the a Lnlet Nozzle Weld Fifth Ten-Year Inservice Inspection Program Interval

10 CFR 50.55a Request, Relief Request 1 -RR-4 Re-Examination of the Unit 1 Reactor Pressure Vessel Indication on the a Lnlet Nozzle Weld Fifth Ten-Year Inservice Inspection Program Interval

ML12318A125
Person / Time
Site:	Point Beach
Issue date:	11/09/2012
From:	Meyer L Point Beach
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC 2012-0088
Download: ML12318A125 (4)

Text

NEXTera ENERGY&

7 POINT BEACH November 9,2012 NRC 2012-0088 10 CFR 50.55a U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant Unit 1 Docket 50-266 Renewed License No. DPR-24 10 CFR 50.55a Request, Relief Request 1-RR-4 Re-Examination of the Unit 1 Reactor Pressure Vessel Indication on the " A lnlet Nozzle Weld Fifth Ten-Year lnservice Ins~ectionProuram Interval In accordance with 10 CFR 50.55a, "Codes and Standards," Paragraph (a)(3)(i), NextEra Energy Point Beach, LLC (NextEra) requests that the Nuclear Regulatory Commission (NRC) grant relief from the requirements of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code (B&PV Code),Section XI, 2007 Edition with 2008 Addenda for the re-examination of the Point Beach Nuclear Plant (PBNP) Unit 1 reactor pressure vessel (RPV) "A" lnlet Nozzle Weld RC-32-MRCL-Alll-03. Relief is requested on the basis that alternative methods will provide an acceptable level of quality and safety.

Specifi,cally, relief is requested to use the qualification requirements for weld examinations conducted from the inside piping surface contained in ASME Code Case N-695, along with the vendor's root mean square (RMS) error achieved under the Performance Demonstration Initiative (PDI) at the Electric Power Research Institute (EPRI) Nondestructive Examination (NDE) Center. The details of the request for relief are enclosed.

NextEra requests approval of this request prior to Marchl5, 2013. The Unit 1 RPV examinations will be conducted during the Spring 2013 refueling outage. The requested duration of this relief request is until the end of the First Period of the Fifth Inspection Interval, which would end July 31, 2015.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 Summarv of Commitments This submittal contains no new commitments or revisions to existing commitments.

Very truly yours, NextEra Energy Point Beach, LLC Enclosure cc: Regional Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW Mr. Mike Verhagan, Department of Commerce, State of Wisconsin

ENCLOSURE RELIEF REQUEST 1-RR-4 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT UNIT 1 Request for Relief in Accordance with 10 CFR 50.55a(a)(3)(i)

Alternative Requirements to ASME Section XI Appendix VII (Supplements 2 and 10)

Examinations of Class 1 Pressure Retaining Welds Conducted from the Inside Surface ASME Code Component(s) Affected Code Class: 1 Examination Category: Category R-A Item Number: R1.20 Component Number: RC-32-MRCL-Alll-03 Component Designation: Elbow to Inlet Nozzle at 328.5" Drawing Number: ISI-1120

Applicable Code Edition and Addenda

The current inservice inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 2007 Edition with 2008 Addenda. Testing of personnel, procedures, and equipment for the ultrasonic examination of applicable Class 1 and 2 components is governed by Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems," of the ASME Code,Section XI.

Applicable Code Requirements The examination of Class 1 and 2 piping welds are required to be performed using procedures, personnel and equipment qualified to the criteria of the ASME Code,Section XI, Appendix VIII, and specifically Supplement 10, "Qualification Requirements for Dissimilar Metal Pipe Welds,"

for the examination of ltem R1.20 nozzle-to-piping dissimilar metal welds.

Paragraph 3.2, "Sizing Acceptance Criteria," Subparagraph (b) of Supplement 10 states "examination procedures, equipment, and personnel are qualified for depth sizing when the RMS (root mean square) error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125-inch (3.2mm)."

Code Case N-695, "Qualification Requirements for Dissimilar Metal Piping Welds,Section XI, Division 1", provides alternative requirements to Appendix VIII, Supplement 10 and is unconditionally approved for use through Regulatory Guide 1.147, "lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 16.

Paragraph 3.3(c) of Code Case N-695 states, "Examination procedures, equipment, and personnel are qualified for depth-sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, do not exceed 0.125-in. (3 mm)."

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Reason for the Request NextEra Point Beach, LLC (NextEra) is performing a volumetric re-examination of RC-32-MRCL-Alll-03 dissimilar metal (DM) weld from the inside diameter (ID) surface during the upcoming refueling outage as required by Paragraph IWB-2420(b). NextEra will implement the NRC-approved alternative requirements of Code Case N-695 for qualification.

NextEra proposes using an alternative RMS error depth-sizing requirement as compared to the 0.125-inch RMS error value stated in Code Case N-695. A NextEra representative confirmed with the Performance Demonstration Initiative (PDI) Administrator on September 25, 2012, that no vendor has successfully demonstrated compliance with the Code-required 0.1 25-inch RMS value for qualification tests for examinations conducted from the ID surface (for either stand-alone Supplement 10 or combined Supplement 2 and 10 qualifications).

NextEra has verified through the PDI Administrator that the examination vendor selected to perform the scheduled re-examinations at Point Beach Nuclear Plant (PBNP) has achieved a 0.212-inch RMS error for the Supplement 10 qualification, a 0.21 1-inch RMS error for the Supplement 2 qualification, and a 0.21 1-inch RMS error for the Combined Supplement 2 andl0.

Proposed Alternative and Basis for Use Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested for an alternative requirement that will provide an acceptable level of quality and safety.

For the re-examination of indications recorded on weld RC-32-MRCL-AIII-03 (Supplement lo),

NextEra proposes to apply the difference between the examination vendor's achieved RMS error and the Code Case N-695 required 0.1 25-inch RMS error to actual flaw depths during depth-sizing of indications.

Applying the difference between the required RMS error and the achieved RMS error to the actual flaw being sized will ensure a conservative bounding flaw depth for the applicable dissimilar metal weld to be examined at PBNP Unit 1.

Duration of Proposed Alternative The requested duration of this relief request is until the end of the First Period of the Fifth lnspection Interval, which would end July 31, 2015.

Precedents A similar relief request was granted to PBNP:

NRC to FPL Energy Point Beach LLC, letter, Point Beach Nuclear Plant, Units 1 and 2 -

The Fourth 10-Year Interval lnservice lnspection Program Plan Requests for Relief No.

RR-21 (TAC Nos. MD 8319 and MD8320), dated August 25,2008 (ML081690887)

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