View source for NRC 2013-0105, 10 CFR 50.55a Request, Relief Request RR-5 Examination of the Pressurizer Surge Nozzle Inner Corner Region Fifth Ten-Year Lnservice Inspection Program Interval

{{Adams
| number = ML13331A910
| issue date = 11/27/2013
| title = 10 CFR 50.55a Request, Relief Request RR-5 Examination of the Pressurizer Surge Nozzle Inner Corner Region Fifth Ten-Year Lnservice Inspection Program Interval
| author name = Meyer L
| author affiliation = NextEra Energy Point Beach, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000266, 05000301
| license number = DPR-024, DPR-027
| contact person = 
| case reference number = NRC 2013-0105
| document type = Letter type:NRC
| page count = 6
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:NEXTera**
ENERGY~
POINT BEACH November 27, 2013                                                                     NRC 2013-0105 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 Request RR-5 Examination of the Unit 1 and Unit 2 Pressurizer Surge Nozzle Inner Corner Region Fifth Ten-Year lnservice Inspection Program Interval In accordance with 10 CFR 50.55a, "Codes and Standards," Paragraph (a)(3)(ii), this letter requests that the Nuclear Regulatory Commission (NRC) grant NextEra Energy Point Beach, LLC (NextEra) 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 examination of the Point Beach Nuclear Plant (PBNP) Unit 1 and 2 Pressurizer Surge Nozzle Inner Corner Region. Relief is requested on the basis of hardship or unusual difficulty due to the location of the examination area.
NextEra requests approval of this request prior to December, 2014. The requested duration of this relief request is until the end of the Fifth Inspection Interval, which is scheduled to end on July 30, 2022.
This submittal contains no new commitments or revisions to existing commitments.
Very truly yours, NextEra Energy Point Beach, LLC
   ~YVl~                      icr L. All.ttw Larry Meyer Site Vice President Enclosure cc:      Regional Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Mr. Mike Verhagan, Department of Commerce, State of Wisconsin NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

ENCLOSURE POINT BEACH NUCLEAR POWER PLANT UNITS 1 AND 2 10 CFR 50.55a REQUEST RELIEF REQUEST 5, PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a{a){3)(11)
HARDSHIP OR UNUSUAL DIFFICULTV WITHOUT COMPENSATING INCREASE IN LEVEL OF QUALITY OR SAFETY 1.0  ASME Code Component{s) Affected Code Class:                         1 Component Numbers:                  PZR-SurgeNoz-IRS (Unit 1 and Unit 2)
Examination Category:               B-D Item Number(s):                     B3.120

== Description:==
Full Penetration Welded Nozzles In Vessels 2.0  Applicable ASME Code Edition and Addenda Point Beach Nuclear Plant (PBNP) started the Fifth 10-year lnservice Inspection (lSI)
Program Interval on August 1, 2012 and is required to follow the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," (ASME Section XI), 2007 Edition with the 2008 Addenda with the conditions of 10 CFR 50.55a.

===3.0 Applicable Code Requirement===
Examination category B-D, Item B3.120 [1998 Edition of Section XI per 10 CFR 50.55a(b)(2)(xxi)(A)], requires 100% volumetric examination, as defined in Figures IWB-2500-7(a) through (d) as applicable, of Class 1 pressurizer nozzle inside corer regions (aka inner radius), during each inspection interval.

===4.0 Reason for Request===
Pursuant to 10 CFR 50.55a(a)(3)(ii), relief is requested from the requirements of ASME Section XI, IWB-2500, Category B-D, Item B3.120, on the basis of hardship or unusual difficulty due to the location of the examination area. The Unit 1 and Unit 2 pressurizer surge nozzles (PBNP identification number PZR-SurgeNoz-IRS) are located in a cubicle underneath the pressurizer which includes ventilation duct work, as well as the electrical cabling leading to the 78 pressurizer heater penetrations (see Attachment A). This configuration limits safe access to the examination area. Accessing the area requires personnel to build a scaffold platform, remove insulation around the surge nozzle, clean the examination region, and then perform the examination while being within inches of the electrical cabling running to the heaters. While the heaters themselves can be de-energized for personnel safety, the possibility of damage occurring to either the Page 1 of 3

cables or the heaters is increased due to this activity. In addition, the extremely cramped location does not allow personnel to move away froni the primary source of radiation, (the surge piping and nozzle), which subjects personnel to an expected radiation field of 60-200 mR per hour. This field rate is based upon previous Radiation Protection dose surveys. The radiation exposures to all personnel associated with the performance of these examinations are as follows:
Scaffold erection:                    4 personnel   x 4 hours Insulation removal:                   3 personnel   x 6 hours Examination area preparation:         2 personnel   x 1 hour Ultrasonic examination:               2 personnel   x 1 hour Insulation installation:              3 personnel   x 6 hours Scaffold removal:                     4 personnel   x 2 hours Total person hours:                   64 x 100 mR average rate     =6.4R The pressurizer surge nozzles are integrally cast into the lower head of the pressurizer, thus there are no nozzle-to-vessel welds requiring examination (see Attachment A). In review of industry operability assessments, PBNP has found no examples of pressurizer nozzle inner radius failures over 40 years of operating experience. In addition, PBNP has performed a total of six (6) previous examinations between the two units with no recorded indications.
5.0 Proposed Alternative and Basis for Use .
Proposed Alternative:
A visual (VT-2) examination is performed at the end each refueling outage during the system leakage test as required by Table IWB-2500-1, Examination Category B-P, Item B 15.1 0, of the 2007 Edition through 2008 Addenda of Section XI. The required VT-2 visual examination provides reasonable assurance of continued structural integrity.
Basis for Use:
The pressurizer cast surge inner corner region is subject to a VT-2 visual examination as part of the system leakage test on the pressurizer vessel conducted each refueling outage as specified in Table IWB-2500-1, Examination Category B-P of the 2007 Edition through 2008 Addenda of ASME Section XI.
It is PBNP's position that based on the acceptable results of VT -2 visual examinations performed during the Class 1 system leakage test, there is a reasonable assurance of continued structural integrity of the subject component and an acceptable level of quality and safety is maintained without performing the required inner radius section examinations required by Table IWB-2500-1, Category B-0, Item B3.120.
6.0 Duration of Proposed Alternative The proposed alternative will be used for the Fifth 10-Year lnservice Inspection Interval of the lnservice Inspection Program for the PBNP that is scheduled to end on July 30, 2022.
Page 2 of 3

7.0 Precedents NRC Safety Evaluation to Kewaunee Nuclear Power Plant, dated February 18, 2005, Kewaunee Nuclear Power Plant - Fourth 10-Year lnservice Inspection Interval Program Requests for Relief (TAC Nos. MC 2497, MC2498, MC2499, MC2500, MC2501, MC2503, MC2504, MC2505, MC2506, MC2507 and MC2509) (ML050350225) 8.0 References None Page 3 of 3

Attachment A Pressurizer layout
                                .-**
                ...    \                                0
             .,/* ..:*.l. .,
l il
         / {l              _../
I i 'I' l ! (')
I ,II
*(!>-- -- !
             *,I
       \ I
               *,  \
                  *. \       \
          \ \\ . -**
            \\ ... \.,.<-;"!'.
           ,.-* ) ~~./ \ \
             - ~* \.
Page 1 of 2

Attachment A Pressurizer Layout Note proximity of heater cables to inner radius region Page 2 of 2}}