NRC 2013-0018, CFR 50.55a Request. Relief Request RR-4L1 Inservice Inspection Impracticality Examination Limitations Due to Configuration Fourth Ten-Year Inservice Inspections Program Interval

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CFR 50.55a Request. Relief Request RR-4L1 Inservice Inspection Impracticality Examination Limitations Due to Configuration Fourth Ten-Year Inservice Inspections Program Interval
ML13079A142
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 03/19/2013
From: Meyer L
Point Beach
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC 2013-0018
Download: ML13079A142 (10)


Text

NEXT ENEM-March 19,2013 7 POINT BEACh NRC 2013-0018 10 CFR 50.55a U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 10 CFR 50.55a Request. Relief Reauest RR4L1 lnservice lns~ectionIm~racticality Examination Limitations Due to Configuration Fourth Ten-Year lnservice lns~ectionProgram 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, 1998 Edition through 2000 Addenda, for I 0 0 percent coverage of the subject weld(s) due to geometric or design configuration, which limited the examination coverage which could be obtained. Relief is requested on the basis that alternative methods will provide an acceptable level of quality and safety.

NextEra requests approval of this request as described in the enclosure prior to December 31,201 3.

Summarv of Commitments This submittal contains no new commitments or revisions to existing commitments.

Very truly yours, NextEra Energy Point Beach, LLC Enclosure 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 NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

ENCLOSURE RELIEF REQUEST RR-4L1 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT UNITS 1 AND 2 10 CFR 50.55a REQUEST, RELIEF REQUEST RR4L1 INSERVICE INSPECTION IMPRACTICALITY EXAMINATION LIMITATIONS DUE TO CONFIGURATION FOURTH TEN-YEAR INSERVICE INSPECTION PROGRAM INTERVAL ASME Code Component(s) Affected Code Class: 1 and 2 Examination Category: B-A, B-Dl B-K, C-B

==

Description:==

Listed In Table 4L1-1 Applicable ASME Code Edition and Addenda ASME Section XI, 1998 Edition through 2000 Addenda.

Applicable Code Requirement

ASME Section XI requires examination of 100 percent of the weld length as defined in the applicable Code Tables and shown in the applicable Code Figures. The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory Guide 1.147, Revision 16, allows credit for essentially I 0 0 percent coverage of welds provided greater than 90 percent of the required volume has been examined.

Reason for Request

Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the 100 percent coverage of the subject weld(s) due to geometric or design configuration, which limited the examination coverage which can be obtained.

Proposed Alternative and Basis for Use Proposed Alternative:

There are no alternative examinations proposed. The subject welds received a volumetric or surface examination to the maximum extent practical utilizing the best available techniques on the accessible portions of the weld. Additionally, a visual (VT-2) examination is performed each refueling outage or once each period during the system Page 1 of 9

leakage test as required by Section XI. Based on the volumetric or surface examination coverage attained with acceptable results, along with the VT-2 examination performed with acceptable results, it is reasonable to conclude that service-induced degradation would be detected, which provides an acceptable level of quality and safety for the subject welds.

Duration of Proposed Alternative Relief is requested for the fourth 10-year inservice inspection interval for Point Beach Nuclear Plant, Units 1 and 2, which began on July 1, 2002 and ended on July 31, 2012.

Precedents Similar relief requests documenting limited examinations have been granted to the following plants:

NRC Letter to Point Beach Nuclear Plant, Dated January 28, 2000, Point Beach Nuclear Plant, Units 1 and 2 - Safety Evaluation Regarding Relief Requests Associated with the Third 10-Year Inservice Inspection (ISI) Interval (TAC Nos. MA5234 and MA5235), (ML003677847)

NRC Letter to Point Beach Nuclear Plant, Dated September 1, 2004, Point Beach Nuclear Plant, Units 1 and 2, Re: Request for Relief from American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, Required Examination Coverage (TAC Nos. MB9932 and MB9933),

(ML042380592)

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Table 4Ll-I Limited Examinations of Vessels and Welded Attachments for the Fourth IS1 Interval Point Beach Unit I Component Identification / 1 Figure 1 Category 1 System or I Exam I Exam I Limitation Description Description No. /Item No. Component Coverage Technique RPV-17-683 N/A B-A / Reactor 72.7% AUT Limited due to proximity of core barrel anti-Lower Shell to Lower Head Ring Bl.11 Vessel rotation lugs.

RPV-02-686-A N/A B-A / Reactor 76.6% AUT Limited due to proximity of nozzle integral Outlet Nozzle to Shell at 28.5" B3.90 Vessel extension.

RPV-02-686-C N/A B-A I Reactor 76.2% AUT Limited due to proximity of nozzle integral Outlet Nozzle to Shell at 208.5" B3.90 Vessel extension.

RPV-687-0 1-A N/A B-A / Reactor 67.9% AUT Limited due to proximity of nozzle integral Safety lniection Nozzle to Shell B3.90 Vessel extension.

at 288.5" RPV-687-01-B NIA B-A / Reactor 65% AUT Limited due to proximity of nozzle integral Safety lniection Nozzle to Shell B3.90 Vessel extension.

at 108.5" PZR-SPRAYNOZ-IRS 4L1-1 B-D / Pressurizer 73.3% UT Examination limited due to permanent insulation Inside Radius Section 83.1 10 straps (14.7%) and raised lettering (cast-in) on head (12%).

PZR-SAFNOZ-1-IRS 4L1-2 B-D / Pressurizer 81.6% UT Examination limited due to permanent insulation lnside Radius Section B3110 straps.

PZR-SAFNOZ-2-IRS 4L1-3 B-D / Pressurizer 81.6% UT Examination limited due to permanent insulation lnside Radius Section B3.110 straps.

RHE-IWA-1 4L1-4 B-K / Regenerative 75% PT Examination limited 1/2 inch on either end of the Welded Attachment #I 810.10 Heat top attachment due to excessive bleed-out from Exchanger non-welded portions (attachment is welded on front and back only).

SG-B-7 4L1-5 C-B/ Steam 77.45% UT 100% coverage obtained in 1 axial direction.

Shell to Main Steam Nozzle C2.21 Generator 54.9% coverage obtained in CW / CCW direction. Limitation due to configuration.

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Table 4Ll-1 Limited Examinations of Vessels and Welded Attachments for the Fourth IS1 Interval Point Beach Unit 2 Component Identification I Figure Category System or Exam Exam Limitation Description Description No. /Item No. Component Coverage Technique RPV-I 7-683 N/A B-A / Reactor 72.1 % AUT Limited due to proximity of core barrel anti-Lower Shell to Lower Head Ring B1.ll Vessel rotation lugs.

RPV-02-686-A N/A B-A / Reactor 80.2% AUT Limited due to proximity of nozzle integral Outlet Nozzle to Shell at 28.5" B3.90 Vessel extension.

RPV-02-686-C N/A B-A / Reactor 80.8% AUT Limited due to proximity of nozzle integral Outlet Nozzle to Shell at 208.5" B3.90 Vessel extension.

RPV-687-01-A N/A B-A / Reactor 63% AUT Limited due to proximity of nozzle integral Safety Injection Nozzle to Shell B3.90 Vessel extension.

at 288.5" RPV-687-01-B NIA B-A I Reactor 63% AUT Limited due to proximity of nozzle integral Safety Injection Nozzle to Shell B3.90 Vessel extension.

at 108.5" PZR-SPRAYNOZ-IRS 4L1-1 B-D / Pressurizer 88% UT Examination limited due to permanent insulation lnside RadiusSection I

I IB3.110 I

I I

I I

straps (14.7%) and raised lettering head (12%).

- (cast-in)

. on PZR-SAFNOZ-1-I RS I 4L1-2 I B-D / I Pressurizer 1 81.6% UT Examination limited due to permanent insulation Inside Radius Section B3.110 straps.

PZR-SAFNOZ-2-1RS 4L1-3 B-D / Pressurizer 81.6% UT Examination limited due to permanent insulation Inside Radius Section B3.110 straps.

RHE-IWA-1 4L1-4 B-K I Reaenerative 75% PT Examination limited % inch on either end of the Welded Attachment # I top attachment due to excessive bleed-out from

" non-welded portions (attachment is welded on I front and back only). .

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Figure 4L1-1 Manway Pressurizer Spray Nozzle Limitations (Typical)

- Area of no scan due to insulation ring Area of no scan due to raised lettering (Cast in Head)

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Figure 4Ll-2 Manway Pressurizer Limitations Safety Nozzle 1 Inside Radius Examination PZR-SAFNOZ- 1-1RS (Typical)

Area of no scan due to insulation strap.

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Figure 4L1-3 Manway Pressurizer Limitations Safety Nozzle 2 Inside Radius Examination PZR-SAFNOZ-2-IRS (Typical)

Area of no scan due to insulation strap.

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Figure 4L1-4 Regenerative Heat Exchanger Welded Attachments Attachment 1 welded on two sides (back and fiont) only. Welds are 3 inches long. Only the middle 2 inches can be examined due to Page 8 of 9

Figure 4L1-5 PBNP Unit I Steam Generator Main Steam Outlet Nozzle Examination Coverage Plot G

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