W3P86-0099, Forwards Rev 2 to 10-Yr Inservice Insp Program, Per 851203 Request for Addl Info.Program Approval & Relief from ASME Section XI Testing Requirements When Impractical Requested. Summary of Responses to Encl
| ML20206D463 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/16/1986 |
| From: | Cook K LOUISIANA POWER & LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20206D467 | List: |
| References | |
| W3P86-0099, W3P86-99, NUDOCS 8606200010 | |
| Download: ML20206D463 (6) | |
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LOUISI ANA / 317 BARONNESTREET P. O. BOX 60340
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POWER & LIGHT NEW ORLEANS, LOUISIANA 70160 (504)595-3100 SEONI?sE June 16, 1986 W3P86-0099 A4.05 QA George W. Knighton, Director PWR Project Directorate No. 7 Division of PWR Licensing-B Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Ten Year Inservice Inspection Program, Revision 2
Reference:
NRC letter dated 12/3/85 from G.W. Knighton to R.S. Leddick, subject: Request for additional information on Waterford 3 Inservice Inspection Program.
Dear Mr. Knighton:
In accordance with 10CFR50.55a(g), " Inservice Inspection Requirements",
Louisiana Power & Light Company hereby submits seven (7) copies of Revision 2 of the Ten Year Inservice Inspection Program which is prepared in accordance with the ASME Code Section XI, 1980 Edition with Addenda through Winter 1981 as modified by 10CFR50.55a(b)(2)(iv).
Relief from the testing requirements of Section XI is requested when full compliance with the requiremente of the code is not practical.
In such cases, specific information is provided which identifies the applicable code requirements, justification for the relief requests, and the testing method to be used as an alternative.
Revision 2 to the subject Inspection Program is being submitted at this time in response to the Nuclear Regulatory Commission's request for additional information in the referenced letter. The attachment to this letter provides a summary of our response to the questions from the NRC.
There are change bars in the margin of the program to indicate the changes made in this revision.
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i Page 2 W3P86-0099 It is hereby requested that the subject Program be approved and the ASME Section XI code relief requested by granted pursuant to Section j
50.55a(g)(5)(iii) of 10CFR50.
Very truly yours,
-K.W.
Cook Nuclear Support & Licensing Manager KWC:BGM:ssf i
Enclosure cc (w/o enclosure): R.D. Martin, J.H. Wilson, NRC Resident Inspectors 4
Office, B.W. Churchill, W.M. Stevenson cc (w/ enclosure):
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ATTACHMENT to W3P86-0099 Sheet 1 of 4 REQUEST FOR ADDITIONAL INFORMATION FROM THE NRC CONCERNING FIRST INTERVAL INSERVICE INSPECTION PROGRAM Waterford Steam Electric Station Unit 3 The following questions were submitted by the NRC in a letter dated 12/3/85 addressing the ISI program and requests for relief from impractical Code requirements.
1.Q "Section 1.1. of the ISI program states thac the examinations are implemented by outage plans which contain specific drawings, NDE procedures, calibration standard information, and the minimum / maximum number of items to be examined per period. Sections 2.0, 3.0, 4.0, and 5.0 of the ISI program list the total number of Class 1, 2, and 3 welds and supports selected for examination per Item No.
Code Tables IWB-2412-1, IWC-2412-1, and IWD-2500-1, and Paragraph IWF-2410 define requirements for the percentage of examinations that can be completed for each of the three periods during the inspection interval. Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1 show the required extent and frequency of examination for each Item No; Table IWB-2500-1 also indicates whether deferral of the examination (s) to the end of the 10-year interval is permissible. We cannot determine the method of compliance with these Code requirements from the available information.
The following information should be provided to establish the distribution of examinations by Item No.:
A)
The plant zone drawings or examination isometric drawings for ASME Code Class 1 and 2 components.
B)
A list of the pressure boundary welds by system or component that have been selected for volumetric and/or surface examination during the interval.
C)
A revision of the Examination Category tables showing the anticipated distribution of items per perion. The licensee should discuss the method of establishing welds subject to examination, i.e.,
Examination Category C-A appears to include the shell circumferential welds from several different components.
If a single examination is required during the interval and if deferral to the end of the interval is not permissible, the anticipated percentage of the examination to be performed during each period should be shown."
A. (a) Plant flow diagrams and Inservice Inspection drawings have been added for ASME Code Class 1 and 2 components.
(b) A sheet titled " Items Selected for Examination" precedes each Inservice Inspection drawing identifying the items on that particular drawing that have been selected for examination.
(c) The examination tables have been revised to show the anticipated distribution per period. This information is shown by individual code item.
r ATTACHMENT to W3P86-0099 Sheet 2 of 4 2.Q "The 1980 Edition, Winter 1981 Addenda of the ASME Code requires that the ultrasonic examination calibration block standards conform to the current edition of Article 4 of Section V for Class 1 and 2 ferritic steel vessel welds greater than 2 inches in thickness and Appendix III of Section XI for Class 1 and 2 ferritic steel piping welds. For all other velds, calibration block standards shall conform to Article 5 of Section V.
Section 1.11 of the ISI program states that the calibration standards used for the first ten-year interval were designed and manufactured to satisfy the intent of Article 5 of Section V and Appendix III of Section XI of the 1974 Edition of the ASME Code. The code of record is the 1980 Edition, Winter 1981 Addenda, which has different calibration block requirements than the 1974 Code.
The licensee should provide a discussion of the method used to determine that the existing calibration blocks meet the requirements of 80W81.
In addition, a technical justification should be provided to show that the examination, with the existing calibration blocks, will provide results that are equivalent or superior to the requirements of 80W81."
A. A review has been performed on all calibration standards which will be needed during the first 10 year interval and it has been determined that the standards meet the current requirements.
3.Q "Section 5.0 of the ISI program contains three tables that identify the total number of ASME Code Class 1, 2 and 3 supports subject to examination. These tables indicate the following:
Examination Category Total Supports F-A, Plate and Shell Type Supports 24 F-B, Linear Type Supports 0
F-C, Component Standard Supports 1,429 In order for the staff to evaluate the visual examination program for component supports, the licensee should indicate the approximate number of ASME Code Class 1, 2 and 3 supports included in the totals for each Examination Category. The licensee should provide a description of the methodology used to determine the total number of Code Class 1, 2 and 3 supports."
A. The examination tables for IWF (supports) have been revised to show the total number of supports, the total number of supports which have been selected for examination, and the anticipated distribution of supports by period.
All of the above information is shown by Code Class.
4.Q " Relief has been requested, ISI-001, from obtaining 100% coverage when examining certain items scheduled in Tables IWB-2500-1 (Category B-J) and IWC-2500-1 (Category C-F).
In those tables, notes 1(a) through 1(d) for Examination Categories B-J and C-F define the criteria for selecting piping welds to be examined. Notes 1(a),1(b), and 1(c) d i
ATTACHMENT to W3P86-0099 Sheet 3 of 4 allow no latitude in selecting welds for examinations. However, note 1(d) of both categories allows the choice of additional welds to be examined up to a required percentage. The limitations to examination should be considered in the selection of these welds to minimize the number of welds requiring relief.
The piping welds selected for examination in the interval should be identified. For each weld with a limitation to examination, the following information should be provided:
(1) identification of the specific weld, (2) the corresponding isometric drawing, (3) the required examination method, (4) the specific cause for the partial examination, (5) the region of the weld which can actually be examined, and (6) alternative examinations employed (if any)."
A. Request for Relief No. ISI-001 has been revised to identify each weld which has been selected for examination that will receive a partial examination. Every effort was made when selecting welds to minimize the selection of welds which will require a request for relief.
5.Q " Relief Request Numbers ISI-006 through ISI-010 request partial or complete relief from the visual (VT-3) examination requirements of Examination Category F-C that are inaccessible due to non-removable insulation, permanent fire seals or encapsulated in penetrations.
IWF-1300(e) permits the support boundary to extend from the component insulation, where the support is buried in insulation and the support either carries the weight of the component or serves as a structural restraint in compression. The staff cannot determine the specific relationship between the subject requests for relief and the table on Examination Category F-C in Section 5.0 of the ISI program. To clarify this issue the licensee should address the following:
A)
Do the individual supports listed in ISI-006, ISI-007, ISI-009 and ISI-010 meet the requirements of IWF-1300(e)? Is the objective of these relief requests to indicate that the specific Code requirements will be met and to document that the support boundary has been established at the component insulation or fire seal?
B)
Does the ISI program include the examination of the portion of the supports identified in ISI-006 through ISI-010 that are not obstructed by non-removable insulation, permanent fire seals or encapsulated in penetrations?
C)
Are the pressure boundaries of the lines identified in ISI-006 through 151-010 scheduled for hydrostatic tests based on IWA-5000?"
A. (a)
No, No.
If a support meets IWF - 1300(e) criteria it would not be identified in the relief request.
(b) Yes. The accessible portions of the supports listed on ISI-009 and ISI-010 are examined to the extent and frequency of IWF-2500-1 and IWF-2500.
ISI-006, 007 and 008 request total relief.
ATTACHMENT to W3P86-0099 Sheet 4 of 4 (c) Yes. These relief requests identify supports only.
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