View source for AECM-84-0335, Forwards Requests for Relief from ASME Section XI Code Requirements for Inservice Insp of 11 Items.Requests Submitted in Accordance W/Requirements of 10CFR50.55a(g)(5)(IV)

{{Adams
| number = ML20092N397
| issue date = 06/29/1984
| title = Forwards Requests for Relief from ASME Section XI Code Requirements for Inservice Insp of 11 Items.Requests Submitted in Accordance W/Requirements of 10CFR50.55a(g)(5)(IV)
| author name = Dale L
| author affiliation = MISSISSIPPI POWER &amp; LIGHT CO.
| addressee name = Denton H
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000416, 05000417
| license number = 
| contact person = 
| document report number = AECM-84-0335, AECM-84-335, TAC-55522, TAC-55524, TAC-57222, NUDOCS 8407030088
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 46
| project = TAC:55522, TAC:55524, TAC:57222
| stage = Other
}}

=Text=
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MISSISSIPPI POWER & LIGHT COMPANY
                                 ]                          Helping Build Mississippi M                 P. O, B O X 16 4 0. J A C K S O N. MIS SIS SIP PI 3 9 2 05 June 29, 1984 NUCLE AR LICENSING & $AFETY DEPARTLENT U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C. 20555 Attention:       Mr. Ilarold R. Denton, Director

==Dear Mr. Denton:==

==SUBJECT:==
Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-4!6 and 50-417 License No. NPF-13 File: 0260/L-860.0/L-952.0/
M-189.0 Inservice Inspection to ASME Section XI (Request Nos. I-00001 through I-00011)
AECM-84/0335 This letter transmits requests for relief (Nos. I-00001 through I-00011) f rom ASME Section XI Code requirements for the Inservice Inspection of eleven items for the Grand Gulf Nucleac Station (GGNS)
Unit 1 in accordance with 10CFR50.55a(g)(5)(IV).
The attachment delineates the information with regard to such relief requests for your review.
If you have any questions or require further information, please contact this office.
Yours truly, L. F. Dale Director, Nuclear Licensing
                                                                             & Safety GS/JGC:db

==Attachment:==
Request for Relief from ASME Section XI cc:     (See Next Page) 8407030008 840629                                                 Q PDR ADOCK 05000416 G                        PDR                                    l i 1anRV L
MGdb 1 Member Middle South Utilities System

AECM-84/0335 MISSISSIPPI POWER Q LICHT CCMPANY                     P:ga 2 i
ec:      Mr. J. B. Richard (w/a)
Mr. R. B. McGehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. G. B. Taylor (w/a)
I                         Mr. Richard C. DeYoung, Director (w/a)
Office of Inspection & Enforcement U. S. Nulear Regulatory Commission Washington, D.C. 20555
.'                       Mr. J. P. O'Reilly, . Regional Administrator (w/a)
U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N.W., Suite 2900 1                       Atlanta, Georgia      30323 1
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INSERVICE INSPECTION RELIEF REQUESTS FOR GRAND GUIF NUCLEAR STATION (I-00001 THROUGH I-00011) i 4
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Page 1 of 3 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00001 INSERVICE INSPECTION OF PIPE SUPPORTS WITHIN GUARD PIPES I.       . Component:         Internal process pipe supports (guides #2 and #3) are inaccessible for inservice inspection because they are located inside guard pipes. The affected internal supports and their associated piping systems are as follows:
Support Guide #      Identification            System 2        Q1E51G001C09         R'eactor Core Isolation Cooling 2        Q1E51G004C03         Main Steam to RCIC 3        Q1E51G001C08         Reactor Core Isolation Cooling 3        Q1G33G002C04         Reactor Water Cleanup 3        Q1B21G021C02         Main Steam Drain 2        Q1B21G021H02         Main Steam Drain 3        Q1B21G531C01         Main Steam 3        Q1B21G531C02         Main Steam 3        Q1B21G531C03         Main Steam 3        Q1B21G531C04         Main Steam Sketch 1 is attached for clarification.
II. Code:                     These supports were fabricated in accordance with Section III, Subsection NF, requirements. Applicable inservice inspection is to be performed in accordance with ASME Section XI,' 1977 Edition through and including Summer.
1979 Addenda.
III. Code requirements: The component supports are required te be inservice examined once every 10 years in accordance with Section XI, Tables IWF-2500-1 and IWF-2500-2.
IV.       Information to      The component suports were provided for ~the guard pipes support the deter- as required by stress analysis to actias restraints mination that the which limit-lateral movement'and as dead-weight code requirement    supports for'the process pipe within the' guard pipe.
is impractical:     These inaccessible supports are located inside guard pipes-that extend from the drywell wall through the containment . building to the auxiliary building.
During installation of the process pipe and guard pipe
;                                        assembly between.drywell wall and the first outboard isolation valve, the supports were accessible for j                                       ; examination because of the installation sequence used.
                                        ~After guard pipe components were assembled and welded in place, the access to the supports-was no longer available.
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Pagn 2 of 3 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00001 INSERVICE INSPECTION OF PIPE SUPPORTS WITHIN GUARD PIPES V. Specific relief         Permission is requested to delete all visual requested:              examinations for the supports identified.
VI. Reason why relief         Exemption is requested- for inservice visual examination should be granted       of these component supports for the following reasons:
: 1. The supports are inaccessible because they are located in guard pipes which are filled with reflective insulation that cannot be removed.
: 2. These supports were visually inspected in accordance with ASME Section III, Subsection NF.
: 3. These supports were preservice examined in accordance with ASME Section XI.
: 4. Th2se supports serve as pipe guides to
                                       . restrict lateral movement of the pipe to which they are attached. In addition, these supports also serve as dead weight support for the process pipe.
Additional restraints are provided outside-the no-break zone as required by pipe break analysis. The failure of any of these inaccessible supports would not damage the
                            ,           pressure boundary of the process pipe or affect the integrity of the guard pipe.
VII. Alternative        No alternative testing is proposed at this time.
testing:
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GRAND GULF NUCLEAR STATION - UNIT 1 IWSERVICE INSPECTION REQUEST FOR RELIEF NO. 1-00001 1
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               .    .                                                                 Page 1 of 3 GRAND GULF NUCLEAR STATION UNIT 1-RELIEF FOR REQUEST NO. I-00002 INSERVICE INSPECTION.
OF PRESSURE RETAINING WELD IN SCRAM DISCHARGE VOLUME PIPING I. Component:           An inaccessible portion of weld No. 91 on the scram discharge volume piping-(12" EBB line) is located in the Control Rod Drive Hydraulic (C11) System.      (See the attached sketch)
II. Code:                The subject pressure retaining piping weld was designed and fabricated to ASME Section III, Class 2 requirements.
Applicable inservice inspections are to be performed in accordance with ASME Section XI, 1977 Edition through and including Summer 1979 Addenda.
III. Code requirement:       Class 2 pressure retaining piping welds are required to be volumetrically and surface examined once every
 ;                                ten-year interval in accordance with ASME Section XI, Table IWC-2500-1, Category C-F.
IV. Information to       The instal' ation of a bracket directly above the support the deter- circumferential. weld No. 91 has limited the mination that the    accessibility to the weld for ultrasonic code requiremeut     examination. The inaccessible portion of the weld is impractical:      is approximately-5.5 inches of the circumference of the 12. inch NPS pipe, or 14 percent of the weld length.
V.      Specific relief      Permission is requested to obtain a relief from-the requested:           requirement to volumetrically exasine the portion of weld No. 91 inaccessible due to the installed bracket.
VI. Reasons why relief Request for exemption from inservice volumetric should be granted (ultrasonic) examination of the inaccessible portion of this weld should be granted for the following reasons:
                                 '1. The' entire weld was examined by radiography and-passed in accordance with ASME Section III,. Class
                                       .2 requirements.
: 2. The entire weld was surface examined (liquid
                                       , penetrant) and passed in accordance with ASME Section XI, Table IWC-2500-1 Category C-Fo requirements.                                             ,
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Pagn 2 of 3 GRAND GULF NUCLEAR STATION UNIT 1 RELIEF FOR REQUEST NO. I-00002 INSERVICE INSPECTION OF PRESSURE RETAINING WELD IN SCRAM DISCHARGE VOLUME PIPING
: 3. The accessible portion of this weld was volumetrically examined using ultrasonic techniques       -)
and passed in accordance with ASME Section XI,             i Table IWC 2500-1 requirements.
: 4. This weld has been hydrostatically tested in accordance with ASME Section III, Class 2 requirements.
: 5. This weld will be subject to a system functional test and a system hydrostatic test in accordance with ASME Section XI, Table-IWC 2500-1 requirements.
: 6. The portion of this weld inaccessible for volumetric examination will be surface examined each inspection interval in accordance with ASME Section XI, Table IWC 2500-1, Category C-F requirements.
VII. Alternative        The accessible portion of the weld will be volumetrically and surface examined each inspection interval in accordance with ASME Section XI, Table IWC 2500-1. Portion of the weld which cannot be volumetrically examined would be surface examined in accordance with ASME Section XI,
                                  ~
Table IWC 2500-1, Category C-F requirements. Should indications be found, an engineering evaluation will be made to determine if the inaccessible portion of the.
weld has been affected. The inaccessible portion of this weld represents approximately 14 percent of'the total weld length.
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l GRAND CULF NUCLEAR STATION - UNIT 1 Page 3 of 3 SCRAM DISCHARGE VOLUME PIPING h     I- 00 2 INSERVICE INSPECTION BRACKET
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i GRAND GULF NUCLEAR STATION UNIT I REQUEST FOR RELIEF NO. I-00003
*                                                                   ' INSERVICE INSPECTION OF CIRCUMFERENTIAL DISSIMILAR METAL WELD I.       Component:                 Circumferential dissimilar metal weld (FW-13) between reactor core' isolation cooling (RCIC) line 20"-HBB-53.and 3                                               20"-HCB-29. Line 20"-HCB-29 is the RCIC turbine exhaust sparger.
II.      Code:                    The subject pressure retaining, circumferential, dissimilar metal weld is fabricated in accordance with ASME Section III, Class.2 requirements. Inservice inspection is to be performed in accordance with ASME Section-XI, 1977 Edition through and including Summer 1979 Addenda.
 ;         III. Code requirements: The pressure retaining, circumferential, dissimilar metal, i
Class 2 weld is required to be surface (PT or MT) and volumetrically (ultrasonically) inspected once every ten-year interval'in accordance with ASME Section XI, Table IWB-2500-1, Examination Category C-F, Item #C5.21, Note (1) (c).
IV.       Information to,         The implementation of the code requirement is impractical support.the deter        as the subject weld is in constant contact with the water mination that the        in the suppression pool. When the suppression pool is at 4
code requirement         its lowest. level (Post-LOCA 111'-4 3/4"), the subject-weld is submerged under 6'-4 3/4" of water.
is impractical:
V.        Specific relief          Permission is requested to exe'mpt RCIC turbine exhaust
.                    request                  sparger weld (FW-13) from inservice inspection,_except
]                                             as-noted in alternative testing'.                        -
)1       . VI.       Reasons why relief Request for. exemption should be' granted for the following should be granted: - reasons:
4                                                               .                .-
: 1.          The subject weld has been volumetrically-examined by..-
                                                        . radiography.and found acceptable ~in accordance with
                                                        .ASME Section III,. Class 2 requirements.
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: 2.         LThe subject' weld will only be exposed'to design-pressure and temperature a small percentage _of.the
;~                                                      (time the plant operates. _The balance'of that time, it will:see-static conditions'at near atmospheric,
                                                         . pressure, along with relatively low temperatures.
: 3.           The open area of the sparger hole is over 300% of-the cross . sectional area'of the pipe itself. : The steam will-flow through the sparger relatvely'                .
                                                        ; unimpeded, permitting only: low pressure buildup-in-the pipe..
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Page 2 of 2 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00003 INSERVICE INSPECTION OF CIRCUMFERENTIAL DISSIMILAR METAL WELD VII. Alternative   No alternative testing is proposed at this time. However, if the suppression pool is drained for other reasons, laspection of the weld will be performed.
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Page 1 of 4 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00004 INSERVICE INSPECTION PROGRAM RPV LOWER HEAD-TO-SHELL WELD A-A
:I .       Component:         _The lower one-half of Unit I reactor pressure vessel lower-head-to shell weld A-A.
           - II.       Code:              The Unit I reactor pressure vessel was designed and fabricated to ASME Section III', Class 1 requirements.
Applicable inservice inspections are to be performed in accordance with the ASME Section XI, 1977 Edition with addenda through and including Summer 1979 Addenda.
III. Code requirements: The upper portion of this weld is a circumferential shell weld and is required to be_ volumetrically examined for essentially 100% of the weld length once during the first 10-year inservice inspection interval, in accordance with ASME Section XI, Table IWB-2500-1, Category B-A, Item Bl.11. The lower portion of this weld is a circumferential head weld and is thus required to be volumetrically examined for essentially 100% of the weld length, once every 10 year inservice inspection interval, in.accordance with ASME Section XI, Table IWB-2500-1, Category B-A, Item Bl.21.
IV.       Information to     The A-A weld joins the lo' west ring of circumferential support the        shell plates on the reactor pressure vessel-(RPV) to the determination      RPV bottom-head and is located 80.66 inches above vessel that the code      zero. The bottom of the core is located at 216.31 inches requirement is-    above vessel zero. .The weld is approximately 135.65 impractical:       inches below the bottom of the core. In addition, the weld is approximately_91.2 inches below the centerlines of the recirculation pump suction nozzels-(N1 nozzels) and approximately 98.4 inches below the centerlines of the recirculation pump discharge nozzle (jet pump suction nozzle-N2).
                                         -The upper portion of the A-A weld'is a_ typical.
circumferential shell weld. -Automated ultrasonic examination procedure and equipment have been develope'd
                                        - which_will permit the required inservice volumetric inspections to be performed remotely. - The. lower -portion of the A-A weld is a.circumferential head weld. Due to the curved geometry of this~ portion of the weld,.
                                                                           ~
automated means for ultrasonic examinatin of this portion of the weld have not been developed; thus, this' portion of the weld must bef ultrasonically-examined by manual procedure.
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GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00004 INSERVICE INSPECTION PROGRAM RPV LOWER HEAD-TO-SHELL WELD A-A IV. Information to  The containment design of Grand Gulf Nuclear Station support the      Unit 1 is designated Mark III. A feature of this determination    design is that an annulus space of approximately 30 that the code    inches width exists between the reactor vessel outer requirement is   circumference and the biological shield wall inner impractical:     circumference. The examiners must enter this annulus -
(Continued)      space to perform manual ultrasonic examir.ation of the A-A weld. Contact radiation levels on, and area radiation levels near, the recirculation inlet and outlet nozzles, recorded at other BWR plants during the first three to six years of reactor operation have been in the range of 200 mR/hr to 2000 mR/hr. We anticipate the area radiation levels at the A-A weld to be approximately the same as those near the nozzels due to their proximity to_each other, the constricted space in annulus, the proximity to.the core, which is treated as an area source, and possible reflection from the. metallic insulation-on the inner surface of the biological shield wall. For; purposes of estimating exposure, we have assumed an area radiation level at the-A-A weld of 800 mR/hr at the end of the first 40 month inservice inspection period. .The level'is expected to.
                                   . increase as:the~ plant ages.                                          1 Due to the large~ amount of weld area required to be examined and the. nature of_the radiation. sources in the area,-shielding is not practical. Such shielding ~would need to' shield the entire body, would be heavy and difficult to move and would require _significant exposure
                                   -to erect and move.
Based on the results of the examinations performed during the preservice inspections, it is estimated that_16 man-hours will be required to perform the required manual, ultrasonic. examinations. This time does not include the           .
time _ required for~ personnel to enter and exit the annulus
.                                    space; however, it does include an allowance'for_the l
extra time' required by personnel due to wearing protective clothing.and for mapping three recordable, but-not.        ..       ,
reportable indications, which were found during preservice-
!      s                             inspections.
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Page 3 of 4 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00004 INSERVICE INSPECTION PROGRAM RPV LOWER HEAD-TO-SIIELL WELD A-A We estimate that the manual ultrasonic examination of the A-A weld will require approximately 12,800 millirem of personnel exposure. Entry and exit of the annulus region plus support personnel exposure during the examinations is estimat'ed to require an additional 1,700 millirem for a total estimated exposure of 14,500 millirem.
V. Specific relief   Permission is requested to delete all ultrasonic inservice requested:        inspections of the lower one-half (Category B-A, Item Bl.21 requirement) of the entire circumference of the A-A weld, except as noted under alternate examinations.
VI. Reasons why relief Relief from the ultrasonic inservice inspection of the should be granted A-A weld is requested for the following reasons.
: 1. The upper one-half (Category B-A, Item Bl.11) of the A-A weld was examined by remote ultrasonics as a preservice inspection in accordance with ASME Section XI and no recordable indications were found.
: 2. The lower one-half (Category B-A, Item B1,21) of the A-A v Id was examined by manual' ultrasonics as a preservice inspection in.accordance with ASME Section XI and a total of three recordable, but not reportable, indications were found. The examination report shows that the indications are outside the heat affected zone of the weld.
: 3. The entire reactor pressure vessel was subjected to.
a hydrostatic pressure' test in accordance with ASME Section III.
1
: 4. The upper one-half of the A-A weld will be examined by remote ultrasonics'during the first inservice             i inspection interval in accordance with the                   !
requirements of ASME Section XI.
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Page 4 of 4 GRAND GULF NUCLEAR STATION
                                         . UNIT 1 REQUEST FOR' RELIEF NO. I-00004 INSERVICE INSPECTION PROGRAh RPV LOWER HEAD-TO-SHELL WELD A-A
: 5. The entire reactor pressure vessel.will be subjected to a system leakage test at each refueling outage-and to a system hydrostatic test during each inservice inspection interval in accordance with the requirements of ASME Section XI.
VII. Alternative    Instead of examining the entire lower one-half of the A-A examinations: weld, we propose to perform manual ultrasonic examinations only of the section of the weld in which the three recordable indications were found (approximately a 12 inch by 12 inch surface area), once per inservice inspection interval. . We will monitor the sizes of the indications and, if any of the indications appears to be increasing in size, we will evaluate the indications and take appropriate actions, which may include ultrasonic examinations of other sections of the weld.
The anticipated exposure for performing the alternative examination would be less than 500 mrem.
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                                                                              -Page 1 of 5 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00005 INSERVICE INSPECTION PROGRAM RPV SSAM WELD A-B LOWER HALF I. Component:        The lower half of seam weld AB of the Unit I reactor pressure vessel (See Sketch #1).
II. Code:             The Unit I reactor pressure vessel was designed and fabricated to ASME Section III, Class I requirements.
Applicable inservice inspections are to be performed in accordance with the ASME Section XI, 1977 Edition with addenda through and including Summer 1979 Addenda.
III. Code requirements: Seam weld A-B is a circumferential'shell weld and it is required to be volumetrically examined for essentally 100% of the weld length, .once during.the first 10 year inservice inspection interval, in accordance with ASME Section XI, Table IWB-2500-1, Category B-A, Item Bl.11.
IV. Information to    The circumferential weld AB joins together ring 1 and support the       ring 2 of'the' reactor pressure vessel (RPV) and is determination     located 210.66 inches above vessel zero. The bottom-that the code     of the core is' located at-215.31 inches above vessel requirements is   zero. The weld is approximately 4.65 inches below the impractical.      bottom of the core. The centerlines of the recirculation pump discharge nozzles . (jet pump suction nozzles-N2); and the recirculation pump suction nozzles (N1 nozzles) are located approximately 30.96 inches and 37.92 inches-respectively below the weld.
The upper portion of seam AB is a typical circumferential shell weld. An' automated ultrasonic examination procedure and equipment have been developed which will permit the.
required inservice volumetric inspections to be performed-remotely.1                        ,
However, due to the nozzle interference with lhe automated-ultrasonic equipment and the irregular geometry on the lower portion of weld AB, remote examination is not possible. Therefore~,"this portion of the weld must.be examined by the manual procedure.
The containment' design of Grand. Gulf-Nuclea'r Station.     .
Unit 1Eis designated Mark III. :A feature of this design is an annulus space of approximately 30' inches width which exists between the reactor vessel outer circumference and the biological shield wall-inner circumference. The examiners must enter: this annulus space to perfona the manual ultrasonic examination of RUFNdh 11' W     (

i                                           Page 2 of 5            )
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    ,                                             GRAND GULF NUCLEAR STATION
,                                                             UNIT 1 REQUEST FOR RELIEF NO. I-00005 INSERVICE INSPECTION PROGRAM RPV SEAM WELD A-B LOWER HALF IV. 'Information to           weld AB. Sin:e we have no actual radiation data from support the           GGNS, we are basing our estimates on data from other determination that plants. The information we received from the other BWR the code              plants indicated that seam AB is located in a radiation                                  >
4 requirements          field of approximately 8-10 R/hr. This is a a
is impractical.       conservative estimate for the end of the first fuel cycle (Continued)           (first re-fueling outage). The actual exposures will probably be less; however, the area and contact readings can be expected to rise as the plant ages.
l                                     Based on the results of the preservice inspections, it
;                                       is estimated that 16 man-hours will be required to perform the manual ultrasonic examinations of weld AB.
This time also does not include the time required for j
personnelf to enter and exit the annulus space; however, it does include an allowance for the extra time required by personnel due to wearing protective clothing and for mapping four recordable, but not reportable indications, which were found during the preservice examination.
As stated earlier, personnel performing manual ultrasonic examinations on this particular weld will be subject to very i
high area radiation fields, in the neighborhood of 8-10.
3 R/hr. Even assuming GGNS daily and weekly administrative                                 '
 >                                      whole body limits are waived and the inspectors are allowed to accumulate their entire GGNS quarterly administrative limit of 2500 millirem in one dose, personnel stay times in this area would be less than 20 minutes.                    e We estimate that the manual ultrasonic examination of the AB
'                                       weld will require approximately 128,000 millirem of exposure per-10-year interval or-42,666 millirem each inspection-period. The calculations do not include exposure to support personnel.
Due to,the large amount of weld area required to be examined and the nature'offthe radiation sources in the area,
                                       ' temporary shielding is not practical; Such shielding would
                                       .need to protect the entire body, would be heavy.and difficult'to move and would! require significant exposure to
                                      ' erect.in and remove from the annulus region. If the
            ~
shielding were worn on the body (lead vests,-for example),
i-the extra weight of the shielding would slow personnel entry and exit, thus negating any advantages.                   -
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Page 3 of 5 l
l GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00005 INSERVICE INSPECTION PROGRAM RPV SEAM WELD A-B LOWER &\LF V. Specific relief        Permission is requested to delete all ultrasonic inservice requested:              inspection on the lower one-half (Category B-A Item Bl.11 requirements) of the entire circumference of the AB weld, except as noted under alternate examinations.
VI. Reasons why relief Relief from ultrasonic inservice inspection of weld AB is should be granted:      requested for the following reasons:
1
: 1. The entire reactor pressure vessel was subjected to a hydrostatic pressure test in accordance with ASME Section III.
 .                                  2.      The entire reactor pressure vessel will be subjected to a system leakage test at each' refueling. outage and to a system hydrostatic test each inservice inspection interval in accordance with the requirements.of'ASME Section,XI.
: 3.      The upper one-half (Category B-A, Item Bl.11) of-the AB weld was examined by remote ultrasonics
                                        , as a preservice inspection in;accordance >
with ASME Section XI and 13 recordable,.but not reportable,, indications were found.
: 4.      The lower one-half (Category B-A, Item Bl.11) of the AB weld was examined by manaual ultrasonics as a preservice inspection' in accordance with ASME Section XI and a total of four recordable, but not
 ,                                          reportable, indications were~found. These-indications were laminar reflectors in the' base metal and are located outside the heat affected zone of the weld.
: 5.       Based on the information we received from other.
BWR plants, we have estimated that the manual ultrasonic-examination on weld AB-could require as many as 48 examiners.
: 6.      Weld AB will be examined by remote ultrasonics
                                          ~from the #2 ring side lof the weld during the first inservice inspection interval. (1st 10 years). It 4
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Page 4 of 5 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00005 INSERVICE INSPECTION PROGRAM RPV SEAM WELD A-B LOWER HALF
                               -is not practical to perform a remote ultrasonic examination from the #1 ring side of the weld due to nozzle interference'.   (See attached drawing).
However, a minimum of 70% coverage of the weld will be attained with the 0*, 45*, 60*
transducers scanning from_the #2 ring. Full coverage is not possible with. the remote equipment because of-the seam configuration.
  .VII. Alternative       Instead of examining the entire lower one-half of the examinations:    AB weld, we propose to perform manual ultrasonic examinations only on the section of the weld in which the four recordable indications were found (approximately i                         a 13 inch by 22 inch surface area), once per inservice inspection interval. We will monitor the' sizes of the indications and, if any of the indications appear to be i                         increasing in size, we will evaluate the indications
;                         and take appropriate action, which may include ultrasonic examinations of other sections of the weld.
The anticipated exposure for performing these alternative examinations would be less than 4600 mrem.
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Pace 5 of 5 GRAND GULF NUCLEAR STATION UNIT 1
,.                                                                                   INSERVICE INSPECTION REQUIREMENTS REQUEST FOR RELIEF NO. I-00005 7"
im             IE           .
I '_             _
                                                                                                                      .                                   l RING # 2 N
15' RING # 1 I"
7T Na 182 GIRTH SEAM A8 O' AZIMUTH 225'        l.0'       135'          90'           45'                      515'        270*     225'
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                                  ' ' " ''                 RPV DEVE LOPE 0 E L E VATIO N                     mot oma== to scan motr Ntaab' sic' tuauination
       .r.'.                  1                                                           J.

                                        . _ ~ -          .- - .             - - -.         _
                                                                                                   .-~
Page 1 of 4 s
GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00006-INSERVICE INSPECTION PROGRAM' RPV SEAM WELD AC I. Component:         Section of seam weld AC of Unit I reactor pressure vessel.
(See Sketch #1).
3
'~
II. Code:             The Unit I reactor pressure vessel was designed and fabricated to ASME Section III, Class I requirements.
;                                 Applicable inservice inspections are to' be performed in accordance with the ASME Section XI, 1977 Edition with addenda through and including Summer 1979 Addenda.
III. Code requirements: This weld is a circumferential shell weld and is thus i                                 to be volumetrically examined for essentially 100% of i                               the weld length, once during the. first 10 year inservice i-                                inspection interval, in accordance with ASME Section XI, Table IWB-2500-1, Category B-A, Item Bl.11.
        'IV. Information to    The circumferential weld AC joins together ring 2'and support the       ring.3 of the reactor pressure vessel (RPV) and is determination     located 388.84 inches above vessel zero. The top of 4-              that the code     core is located 366.61 inches above vessel zero, and requirement is    the seam is 22.23 inches above the top of the Lore.
               ' impractical:
Both the upper and lower portions of seam AC are typical-circumferential shell welds. : Automated ultrasonic examination procedure and equipment have been developed which will permit the required inservice. volumetric inspections to be performed remotely. However, due to                    ,
the nozzle interference.with the automated ultrasonic equipment,1a remote examination is not.possible.
Therefore, this portion'of the weld must.be examined by the manual procedure.
t                                .Except for areas around the N6 nozzles and the' N12 nozzles, seam AC was examined with the automated ultrasonic equipment. Approximately 23 inches on each side of each N6 nozzle's centerline and 18 inches on each side of each N12 nozzle's centerline required' manual ultrasonic. inspection. The nozzles-are located so close to the seam that they interfere with the automated equipment.
i The containment design of Grand Gulf Nuclear Station Unit 1 is designated Mark III. A feature of this design is that an annulus space of approximately 30 inches width.
exist, between the reactor vessel outer circumference and the biological shield wall inner circumference.
f RUFNdb 15i

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i
   .       .                                                                                               1 Page 2 of 4 GRAND GULF NUCLEAR STATION UNIT 1-REQUEST FOR RELIEF'NO. I-00006 INSERVICE INSPECTION PROGRAM RPV SEAM WELD AC a
IV. Information to     The examiners must enter this annulus space to perform support the        the manual ultrasonic examination on weld AC. Since determination      we have no actual radiation data from GGNS, we based
              .that the code      our estimates on data from other plants. The requirements is     information we received from the other BWR plants impractical:       indicated the AC weld is located in a radiation field (Continued)        of approximately 8-10 R/hr. These are conservative estimates for the end of the first fuel cycle (first refueling outage). The actual exposures will probably be less; however, the area and contact readings can be expected to rise as the plant ages.
The total length of weld subject to manual inspection is approximately 23.5 feet; therefore it will take approximately 4 hours to perform the manual inspection
,                                 on weld AC. This estimation includes an allowance for the extra time required by personnel due to wearing protective clothing, but it does not include -
the time required by. personnel to enter and exit the annulus area.
As stated earlier, personnel performing manual ultrasonic
                                 - examinations on this particular weld will be subject to very high area radiation fields, in the neighborhood of 8-10-R/hr. Even assuming GGNS daily'and weekly .
                                 . administrative whole body limits are waived and the inspectors are allowed'to accumulate their entire-GGNS
                                 - quarterly administrative . limit of 2500 mtem for one dose,.
personnel stay times'in this area'would be less than?
20 minutes.-
:                                Our calculations indicate that seam AC will; require approximately.32,000 millirem of personnel: exposure per 10-year-interval or 10,666 milliren'each ~ inspection period.. These figures do not. include radiation
                                                                              ~
exposure to support'persor.ael.                    '
Due to the amount of weld area required to be, examined and the nature of the radiation sources'in the area,
                                 - temporary shielding is'not-practical. Such. shielding
                                 . would need to protect the entire body, would be' heavy and difficult to move and would require significant-exposure to' erect in and remove from the. annulus region.
RUFNdb 16-p 9 e        er,   -     , w     a                     +

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Page 3 of 4 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00006 INSERVICE INSPECTION PROGRAM RPV SEAM WELD AC V. Specific relief    Permission is requested to delete all manual ultrasonic requested:         inservice inspection on the areas of weld AC affected by the presence of intruding N6 and N12 nozzles. This length consists of approximately 23.5 ft out of total 138 ft circumference of the AC weld on both sides
 ,                             (approximately 69 ft for one side). Therefore, approximately 83 percent of the required examinations are performed by the remote method.
VI. Reasons why relief Relief from the manual ultrasonic inservice inspection should be granted: of weld AC is requested for the following reasons:
: 1. The entire reactor pressure vessel was subject to a hydrostatic pressure test in accordance with ASME Section III.
: 2. The entire reactor pressure vessel will be subject to a system leakage test at each refueling outage and to a system hydrostatic test each inservice inspection interval in accordance with the requirements of the ASME Section XI.
: 3. The entire AC weld, except for the areas around N6 and N12 nozzles, was examined by remote ultrasonics from both sides of the weld as a preservice inspection in accordance with ASME Section XI and 19 recordable, but not reportable indications were found. Manual ultrasonic inspection of the areas not scanned by the remote equipment revealed no recordable indications.
: 4. The accessible AC weld will be examined by remote ultrasonics during the first inservice inspection interval (1st 10 years) in accordance with the requirements of ASME Section XI. Complete coverage of the weld'around the N6 and N12 nozzles will be attained with the 0*, 45*, & 60 transducers scanning from the side of the seam opposite the nozzles.
VII. Alternate           Since weld AC did not have any recordable indications examinations:      by manual examination, no alternate examinations are planned for this seam.
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GRAND GULF NUCLEAR STATION UNIT 1
 . ,                                                                                                      INSERVICE INSPECTION REQUIREMENTS REQUEST FOR RELIEF No. I-00006 7"
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                                                                                                                          ~l v
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.I                                                                                               GIRTH SEAM 4
AC l                                                                                                                                                                                                 -
i 0* AZIMUTH 225'                  180'         135'            90'            45'                           315'            270'        22S'
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PaSe 1 of 5 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST.FOR RELIEF NO. I-00007 INSERVICE INSPECTION
,                                         OF PIPING WELDS WITHIN GUARD PIPES-l I. Component:             ASME Section III Class 1 pressure retaining circumferential welds located in Feedwater Loops A and B (B21), Main Steam (B21), Main Steam Drain (B21),
Reactor Core Isolation Cooling (E51), Residual Heat i                                     Removal (E12) and Reactor Water Clean-up (G33) piping.
These welds are located on system piping inside guard pipes, which extend beyond the containment. The applicable welds are listed on Table 1.
II. Code:                  These welds were designed and fabricated to ASME Section III, Class I requirements. Applicable inservice inspection is to be performed in accordance with ASME Section XI, 1977 Edition through and including summer of 1979 Addenda.
III. Code requirements: Class 1 pressure retaining piping welds are required l
to be volumetrically and surface examined once each ten-year inspection interval in accordance with ASME
                                   - Section XI, -Table IWB 2500-1, Examination Category B-J.
IV. Information to'        The.circumferential welds joining the flued head and support the deter- the process pipe are encapsuled by the portion of the mination that the      guard pipe-which protrudes beyond the containment. To code requirement       comply with the inservice inspection requirements of is impractical:        ASME Section XI, two 4 x 6 inch elliptical access ports spaced 180 degree apart are provided for access-to the welds. During the development of the access port design,.the inservice contractor had indicated that the ports were adequate to permit performance of i-ultrasonic examination of the entire weld. After fabrication and -installation of the process pipe, guard pipe and the flued' head, it was determined .
                                           ~
that the entire length'of the weld is not accessible through the two access ports. Approximately 50% of the weld is accessible for . inservice inspection.
V. Specific relief        Permission is requested to permit only ultrasonic requested:             examination of the accessible areas of the weld,'except as--
noted under alternate examination.
VI. Reasons why relief Exemption is requested for;the inservice inspection-of should be-granted: inaccessible portions,of welds located inside' guard' pipes for the following reason:
       'RUFNdb 18

1 Page 2 of 5
* 1 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00007 INSERVICE INSPECTION OF PIPING WELDS WITHIN GUARD PIPES VI. Reasons why relief  1. All but two of these lines were designed to high should be granted:       energy pipe break criteria. The exceptions are (Continued)              Q1E12G012W47 and Q1E51G001W12 which are classified as moderate energy pipes.
: 2. These welds were designed and fabricated in accordance with ASME Section III, Class 1 requirements and were examined by radiographic and liquid penetrant techniques.
: 3. These welds have satisfactorily passed both liquid penetrant and ultrasonic examination.in accordance with ASME Section XI, Class 1 requirements.
: 4. Class 1 isolation valves in the process pipe on both sides of the guard pipes are capable of completely isolating each pipe in the event of a pipe failure.
: 5. The guard pipes have been designed and constructed in accordance with ASME Section III, Class 2 requirements and were hydrostatically tested in accordance with ASME Section III, Class.2 requirements.
: 6. The guard pipes are open to the drywell environment; thus, any leakage due to weld failure will be contained within the drywell. The guard. pipes-will prevent any leakage from escaping to the Containment Building.
: 7. The process pipes inside the guard pipes were.
hydrostatically tested in accordance with ASME Section III,. Class.I requirements.
: 8. The process piping inside each guard pipe assembly will be subject to periodic pressure tests in accordance with ASME Section XI, Table IWB-2500-1, Category B-P, requirements.
VII. Alternate           The accessible length of-each weld will be ultrasonically examination:       examined in accordance with ASME Section XI, Table IWB-2500-1, Examination Category B-J. Should signs of weld deterioration or discrepancies be noted during regular inspections, evaluation of the conditions will be made.
RUFNdb 19                                                                         '

Page 3 of 5' GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00007 INSERVICE INSPECTION-                                ,
OF PIPING WELDS WITHIN GUARD PIPES                           ;
i NOTE:   In addition, a relief request No. 00001 based on
                  .the above logic for four (4) welds on main steam pipes was submitted earlier with the Unit 1 preservice inspection. The Nuclear Regulatory Commission accepted this request for relief in GGNS Safety Evaluation Report, Sapplement #2.
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.c GRAND GUIF NUCLEAR STATION UNIT 1 REQUEST EUR RFITFP NO. I-00007 TABLE 1 APPIOX   TYPE        REASON EOR ITEM SYSTDi                         PIPE SIZE       O NPONENT       EXAM AREA SCAN  CIASS  LIMITATIONS NO. NO.       WELD NO. ISO NO.
PIPE 'IO PIPE       53%     T      1   GUARD PIPE 1  B21        G12-Cl-A MS-11-9    28" 28"        PIPE 'IO PIPE       53%     T      1   GUAIO PIPE i    2  B21        G12-Al-A MS-11-3 PIPE 'IO PIPE       53%     T      1   GUARD PIPE 3  B21        G12-Dl-A MS-11-12   28" PIPE 'IO PIPE       53%     T       1  GUARD PIPE
:$     4  B21        G12-B1-A MS-11-6    28" N 11-1     24"        PIPE 'IO PIPE       50%     T       1  GUARD PIPE 5  B21        W2 N 11-7     24"         PIPE 'IO PIPE      50%     T       1  GUARD PIPE 6  B21        W18 3"        PIPE 'IO PIPE      50%     T       1  GUARD PIPE 7  B21'       W9       SD-11-2 PIPE 'IO PIPE      50%    T       1   GUARD PIPE 8  E12        W47      RH-11-1     20" 6"         PIPE 'IO PIPE      50%     T      1   GUARD PIPE 9  E51        W12      RI-8-9
;;                                                                               T      1   GUARD PIPE 10  E51        W7       RI-11-3     10"         PIPE 'IO PIPE      50%
6"         PIPE '1D PIPE      50%     T       1  GUARD PIPE 11  G33        W18      CU-11-3 m
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GRAND GULF NUCLEAR STATION - UNIT 1 INSERVICE 12SPECTION REQUEST FOR ERLIEF NO. I-00007                                                                         .
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GRAND GULF NUCLEAR STATION                                                                       "
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Page 1 of 2 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00008 INSERVICE INSPECTION l'                 0F CONTROL ROD DRIVE AND IN-CORE HOUSINGS WELDS & FLANGE BOLTING I. Component:           Peripheral control rod drive housing welds (tube-to-tube, tube-to-flange) and bolting located on CRD housings.
II. Code:                These portions of the CRD and in-core housing were designed and fabricated to the ASME Section III, Class I requirements. Applicable. inservice inspections are to be performed in accordance with ASME Section XI, 1977 Edition through and including Summer 1979 Addenda.
III. Code requirements:     1. Welds located in 10% of the peripheral CRD housings require surface examination (dye penetrant) during each ten-year inservice inspection interval in accordance with ASME Section XI, Table IWB-2500-1, Examination Category B-0.
: 2. Pressure retaining bolting for the flange-to-flange joints, located _on te CRD and incore housings, are required to be visually examined (VT-1) once every-ten-year inspection interval in accordance with ASME Section XI, Table IWB-2500-1, Examination Category B-G-2.                   ,
IV. Information to       The weld areas and bolting are not accessible for support the          inspection unless the control rod drive (CRD) support determination that structure is removed. .A 360 degree surface examination code requirements    cannot be accurately accomplished from the outsi6e, due are impractical:     to' interference from adjacent CRD housings. Inspection of the weld from the inside of the CRD housing would require that the control rod drive mechanism be removed, which could result in damage to the drive. With removal of-the drive, a small amount of reactor water would escape to the CRD cavity area, possibly causing contamination of personnel and equipment. The time-frame associated with the CRD support structure removal, and CRD mechanism would be approximately six (6) man hours per drive. Dosage received by personnel in this interval cannot justify the -inspection process to possibly find a fault which could be discovered by excessive leakage in the drywell sump monitored per Operating License Manual (Technical Specification)
           .                  . limits in effect.
   -V. Specific relief      Permission is requested to exempt from inservice requested:           inspection,.the peripheral CRD housing welds (tube-to-                   -
tube, tube-to-flange),-the eight-(8) bolts associated' RUFNdb 21-

                                                              .4a Page 2 of 2 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00008 INSERVICE INSPECTION OF CONTROL R0D DRIVE AND IN-CORE HOUSINGS WELDS & FLANGE BOLTING V. Specific relief. with each flange of 193 CRD housings and the four (4) requested:           bolts associated with each flange of 58 incore housings.
(Continued)                                                         .
VI. Reasons why relief Request for exemption from inservice inspection should should be granted: be granted for the following reasons:
: 1. The peripheral CRD housitig. welds have been examined by radiography and liquid penetrant methods and have been hydrostatic tested in accordance with                                                               i ASME Section III-code requirements.
: 2. All incore and CRD Housing bolting has been examined in accordance with the requirements of ASME Section III, which exceed the Section XI (VT-1) visual ~.
examination requirements.
: 3. The welds and bolting will be subject to. hydrostatic                                                 -
testing per-the requirements of ASME SectionfXI upon completion of each outags.
                                                                                  ~
: 4. If the welds and/or bolts fail while 'in operation, the maximum leakage rate, by calculation, will                                 '
occur at the peripheral CRD housing tube-to-frenge weld. The maximum calculated leak rate is 681 gpm. By criteria established in subartic'le,IWB-1200,.
                                      "exi ptions by make up capacity", the r.orm.1 makeup .
capability for'-GGNS 14 878 gpm,-whfch exceeds the calculated' maximum leakage.
: 5. Leak detection is provAded with the 'leaIcage'                        .
detection system, wint continuous :aafiitoring in the control room.
: 6. The CRD housing supports, would prevent ~ ejection of
                                    .'the' housings in. case oi~ total failure of the welds.                              .                         ,
or bolts.-                                                                              ' -
4-_
t                         #                                      1 7.
Removal cf.the controO rod drive support structure,                                                          c; would result' in hardships with 'no' compensatory -                                        >
increase in the level'of 'qnlity andt safetys.                     .
s                     .
VII. Alternate testing: None.                ,
4p  -
T                       So                                   -
                                        ..              .      .      .   .            dV              s s
NOTE: A similar request for relief from pre-se~ryihe insp'ection requirements was accepted,by NRC in GGNS Safe'ty Evalua' tion Report, Supplement.#2 3ry "                                          fA .g
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Page 1 of 6 GRAND GULF NUCLEAR STATION UNIT I REQUEST FOR RELIEF NO. I-00009 INSERVICE INSPECTION OF PUMP CASING WELDS I.       Component:            Pump casing welds located within the surrounding concrete pump support' encasement for the following pumps (see attached list and sketches):
PUMP                               PUMP NO. SKETCH NO.              +
Residual Heat Removal (RHR)        1E12 C002B   RH-8-12 Low Pressure Core Spray (LPCS) .1E21 C001       LP-9-4 High Pressure Core Spray (HPCS) IE22 C001       HP-8-10 1
II. Code:                  LPCS, HPCS and the RHR "B". pumps were designed and fabricated to the ASME Section III, Class 2 requirements.
Applicable inservice inspection is to be performed in accordance with ASME Section XI, 1977 Edition through and including Summer 1979 Addenda.
III. Code requirements: The. pressure retaining welds located on the LPCS, HPCS and RHR "B" pumps are required to be surface examined (magnetic particle) once every. ten-year interval in accordance with the ASME Section XI, Table IWC-2500-1 Category C-G.
IV. Information to '       Inaccessible' pump' casing welds are located where the support the            concrete pump support encasement only allows a 3" clearance determination - that . between the pump casing and,the concrete encasement wall
 ,             the code require-      (see attached drawing for details of the design). -Due to ments are impracti- this-limited accessibility,' it is impractical to surface cal:                   examine those portions of the welds located within.the surrounding concrete pump support encasement.
                                                                           ~
 ,     V.      Specific relief       . Permission is requested to exempt from inservice inspection requested:             the~ inaccessible portions of the pump casing welds listed 4
on Table 1.
VI. Reasons why relief Request for an exemption should be granted for the following
              ,should be granted: reasons:
: 1. These welds have been volumetrically examined by1 radiography and' passed in accordance with the ASME Section III, Class 2~ requirements.
: 2.   -The-accessible length of each applicable weld willibe '
surface examined '(magnetic particle method) -in accordance with ASME Section XI.
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Page 2 of 6
                             ' GRAND GULF NUCLEAR STATION UNIT I REQUEST FOR RELIEF NO. I-00009 (Continued)
INSERVICE INSPECTION OF PUMP CASING WELDS
: 3. The failure of these welds, thus leading to failure of the pump, would have no adverse effect on plant safety, as redundant emergency core cooling systems are provided.
: 4. Annunciators (i.e., low suction pressure, discharge pressure abnormal, etc.) are provided in the control room, along with other system indicators, to alert the operators to abnormal operating conditions.
: 5. The systems, including the pumps, are tested at least once per 31 days per Operating License Manual (Technical Specifications) requirements to ensure operability.
: 6. Pumps will be subject to a system pressure test in accordance with ASMF. Section XI, Class 2 requirements.
: 7. Approximately 87 percent.of the welds on the subject-pump, which require surface examination, are accessible. Performance of the required examinations on these accessible welds-should ensure that generic degradation is not occurring in these pump casing welds.
VII. Alternate  None
          ' testing:
NOTE:     A similar request for~ relief from pre-service inspection of the welds has been accepted by the NRC in GGNS Safety Evaluation Report, Supplement #2.
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Page 3 of 6 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00009 INSERVICE INSPECTION 5
TABLE 1 LIST OF PUMP CASING WELDS E12 - RHR PUMP "B" CASING WELDS SURFACE'THAT SHALL BE EXAMINED DH-1        DH-4                 DH-7             DH-25           SB-5 DH-2        DH-5                 DH-11            SB-3            SB-6 DH-3        DH-6                 DH-12            SB-4            SB-7 WELDS THAT CAN BE PARTIALLY' EXAMINED               WELDS THAT CANNOT BE SURFACE EXAMINED SB-2 (18" Accessible, 54" inaccessible)                         SB-1 (Inaccessible)
E21 - LPCS PUMP CASING WELDS SURFACE THAT SHALL BE EXAMINED DH-1        DH-4                 DH-7            DH-27           ~ SB-5 DH-2        DH-5                 DH-11           SB-3'            SB-6 DH-3         DH-6                 DH-12           SB-4             SB-7
                                                                            ~
WELDS THAT CAN BE PARTIALLY EXAMINED.                     WELDS THAT-CANNOT BE EXAMINED SB-2 (3" accessible, 69" Inaccessible)                          SB-1 (Inaccessible)
             .E22 - HPCS PUMP CASING WELDS SURFACE THAT SHALL BE EXAMINED-
                               ^ DH-1        DH-4'                DH-7.           DH-19            SB-6.
DH-2'        DH-5                 DH-11           DH-28            SB-7<
DH-3         DH-6                 DH-12           SB-5 WELDS THAT-CAN BE PARTIALLY EXAMINED                      WELDS THAT CANNOT BE. EXAMINED SB-4;(68" Accessible,i4" Inaccessible).                        SB-1 (Inaccessible).
SB-2.(Inaccessible)
SB-3-(Inaccessible)
            .RUFNdb~25 s            ,      w          v.,                                    g                  w- -
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;                                                                                                                            Page 1 of 4 GRAND GULF NUCLEAR STATION
        ,                                                                           UNIT 1 REQUEST FOR RELIEF NO. I-00010 INSERVICE INSPECTION 0F PRESSURE RETAINING WELDS I.       Component:                   Inaccessible portions of Class I and Class II pressure
;                                                           retaining piping welds located on residual heat removal (RHR,- E12), reactor core isolation cooling (RCIC, E51), main steam (MS, B21) recirculation (Recire., B33), and reactor water cleanup (RWCU, G33) systems. (See Table 1 for                                        -
details.)
                     . II. Code:                        These portions of the pressure retaining piping welds were designed and fabricated to the ASME Section.III, Class 1 and Class 2 requirements. Applicable inservice inspections are to be performed in accordance with the ASME Section XI,1977 Edition through and including Summer 1979 Addenda.
III. Code requirements: Class 1 and Class 2 pressure retaining piping welds are
 ,                                                          required to be volumetrically and surface examined, f
                                         ,                  essentially 100% of the weld, once every ten-year interval >
in accordance with ASME Section XI, Table IWB-2500-1, i-                                                          Category B-J, Table IWC-2500-1, Category C-F.
J' IV.      Information to               Portions _of. welds that were'preservice examined have
                             , support ht e deter - physical obstructions due to design. Due to this limited mination that the             accessibility, itzis impractical to volumetrically examine code requirements            100% of the welds listed on Table 1.
are impractical:
          ~
                    - V.      Specific relief               Permission is' requested to exempt from volumetric examination 4
requested:                   the inaccessible portions of the Class 1 and Class 2 welds listed on Table 1.
VI. Reasons why relief Request for an exemption should be granted for the should be granted:           following reasons:
: 1.      The inaccessible portions of' listed welds were examined by radiography, passed'in accordance with ASME Section III, Class 1.and Class 2 requirements.
: 2.      The inaccessible portions of listedLwelds were surface
                                                                              ~
                                                                   -examined'(magnetic particle'or' liquid penetrant),
_ passed in accordance with ASME III and/or XI, Class'1 and Class 2-requirements.
i
: 3.     -The inaccessible portions of listed piping welds will be subject to' a system leakage testf after ;each refueling .
+             _
                                                                   . outage for Class-1, and each inspection' period'for Class
                                                                 ~
                                                                   -2'in accordance with ASME_Section XI requirements.
R FNdb~26 c.,
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Page 2 of 4 GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00010 (Continued)
INSERVICE INSPECTION OF PRESSURE RETAINING WELDS 9
4 .-  The inaccessible portions of listed piping welds will be subject to a system hydrostatic test each inspection interval in accordance with ASME Section XI, Class 1 and 2 requirements.
: 5. The portions of listed welds inaccessible for volumetric examination will be surface examined each inspection interval,_in accordance with ASME Section XI.
: 6. Accessible portions of listed welds will be volumetrically and surface examined each inspection interval in accordance with ASME Section XI. Should indications be found, an engineering evaluation will be made to determine if the inaccessible portions of listed welds have been affected.
: 7.   -Leak detection is provided, by way of the leakage detection system with continuous monitoring, for the RWCU, RECIRC, RHR, RCIC, and MS systems.
: 8. The failure of any of these welds would have no adverse effect on plant safety as there is isolation capability and/or shut down capability as part of the plant design.
!   VII. Alternative All the welds identified in Table.1 will be inspected twice testing:    by volumetric examination during the 10-year interval.
RUFNdb 27 i              g Y

e                                                                                                                                                                          .
GRAND GUIF NUCLEAR STATION UNIT 1 RFLTFP RtJUUtsr 10. I-00010                                                           .
TABLE 1 LIMITED  TYPE        REASON EOR ITIM SYSTIM .                            PIPE SIZE       CmPONENT         AREA   SCAN CLASS  LIMITATIONS
  ~
NO. NO.     ' WEED NO. ISO NO.
6"      VALVE 'IO ELBOW     42%   T      1   RADIUS OF 1  E12        G014-EW-44   Ril-8-8                                                   EWOW MS-11-8     28"      EIBOW SEAM          50%   T      1   RUP1URE 2  B21        G9-Cl-B-L/B                                                            RESTRAINT SEAM 6"                         32%   T      2   EEBOW RADIUS
  ;                                                3  E51        G004 8-8-1   RI-8-2               ELBOW 'IO ELBOW 28"      ELBOW SEAM           50%  T      1   RUPIURE 4  B21        Gil-DI-B-L/B MS-11-11 RESTRAINT o
28"      ELBOW SEAM           50%  T       1  RUPIURE 5  B21        G8-Al-B-L/B  MS-11-2 RESTRAINT 24"      VALVE 'IO PIPE         5% T       1  SOCK-O-Irr 6  B21        G030 EW-23    EW-8-2 24"      VALVE 'IO PIPE         5%  T      1  SOCK-O-IEP 7  B21        G030 EW-36    EW-8-4 6"     PIPE 'IO TEE           5%  T      1  SOCK-O-IEr e                                                8  B21        G026 EW-17    EW-11-7 28"      VALVE 'IO PIPE        13%  T      1   RUPIURE 9  B21        G001-W4       MS-11-3 RESTRAINT HS-11-9    28"      VALVE 'IO ELBOW       13%  T      1   RUPIURE 10  B21        G001-W4 RESTRAINT 28"      ELBOW SEAM           50%  T       1  RUPIURE 11  B21        G9-Cl-B-L/A   MS-11-8 RESTRAINT
                                                                                                                                                                             ?
w Sheet 1 of 2                       o n

GRAhD GULF NUCLEAR STATION INIT 1 REQUEST EUR RELIEF NO. I-00010                                                                                    ,
                                                         "ABLE 1                                                                                             ,
(Continued)
PIPE                      LIMITED   TYPE         REASoli EUR                                                  ,
ITEM   SYSTEM LIMPIATIONS WEID NO. ISO NO. SIZE       CINPCNENT        AREA    SCAN  CIASS NO. NO.
RR-11-9     24"      PIPE TO               5%   T        1  SWEEP-0-IEr 12   B33       GS-B1-E SWEEP-O-IET 10"                           19%   T        2  TEE 13   E51       G004-7-8-4   RI-8-1               REDUCER TO TEE RI-8-1      10"      REDUCER 10 TEE       19%   T        2  TEE 14   E51       G004-7-8-9 G004-7-8-8   RI-8-1      10"      REDUCER 70 TEE       19%   T        2  TEE 15   E51 4"     ELBOW TO TEE         24%   T        1  TEE 16   B33       G024-W2      RR-11-19 CU-8-7        4"     ELBOW TO VEFURI        8%  T        3  EIBOW RADIUS 17   G33       G002-W179 G11-D1-B-L/A MS-11-11    28"      EIBOW SEAM           50%   T         1 RUPIURE 18   B21 RESTRAINT G001 W9      MS-11-12    28"      VALVE TO PIPE        13%   T         1  RUPTURE 19   B21                                                                                 RESTRAIN" G8-Al-B-L/A  MS-11-2     28"      EIBOW SEAM           50%    T        1  RUPIURE 20   B21                                                                                 RESTRAINF G001 W1       RI-8-12      6"     VALVE TO EIBOW        16"   T        2  ELBOW RADIUS
      -21   E51 E51        G001 W40     RI-11-4      6"     PIPE TO VALVE         21"   T        1  ELBOW RADIUS 22 Sheet 2 of 2 5

I-                     *
* Page 1 of 5 c                                                 GRAND GULF NUCLEAR STATION                                                   ,
j                                                             UNIT 1 REQUEST FOR RELIEF NO. I-00011 INSERVICE INSPECTION                                                     .
OF THERMAL TEE SLEEVE WELDS ~
t -
I.      Component:          Thermal tee sleeve welds D011-A-1 and D011-B-1 located on
;                                         the' residual heat removal (RHR) return from reactor water cleanup (RWCU) line (see attached sketch for location of the welds).
,             II. . Code:                 Pressure retaining thermal tee sleeve welds D011-A-1 and D011-B-1 were fabricated in accordance with ASME Section III, Class 2 requirements.       Inservice inspections are to be performed in accordance with ASME Section XI, 1977 Edition i                                        through and including Summer 1979 Addenda.
             ~III. Code requirements: Thermal tee sleeve welds are required to be surface (magnetic particle) and volumetrically (ultrasonic) inspected once every ten-year inservice inspection interval in accordance with ASME Section XI, Table IWB-2500-I, i                                         Examination Category C-F, Item #CF.21.
IV. Information to      Due to-the design of the thermal. tee sleeve, there is not support the deter- ~sufficient  area to perform 'a meaningful ultr'asonic exami -
: i.                    mination that the  -nation. Also,'the position of the' thermal sleeve, as well code requirement    as lack of internal access, precludes the use of radiography.
j                     is impractical:
g
;             V.      Reason why relief ~ Request for exemption ~from inservice volumetric (ultrasonics-should be granted: and radiography) inspections of thermal tee welds D011-A-1 and D011-B-1.on the RHR' return to RWCU line, should be granted for the following. reasons:
: 1. The' thermal-tee welds have been volumetrically' examined by radiography and~found acceptable in accordance with.
ASME Section III, Class 2 requirements.
: 1.                                                                       .
2.
                                                                       ~
l                                               The thermal tee welds have been surface examined by magnetic particle and found acceptable in accordance with ASME Section XI, Class 2 requirements.
,                                         3.   .The thermal' tee welds will be subject to magnetic particle inspection every ten-year interval-in :
accordance with ASME Section XI, Class 2 requirements, f
: 4. Thermal tee welds will be subject.to a system pressure-                         ,
test in accordance with ASNE Section'XI, Class:2                       <
l requirements.
RUFNdb 28 i
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Page 2 of 5 l
l GRAND GULF NUCLEAR STATION UNIT 1 REQUEST FOR RELIEF NO. I-00011 (Continued)
INSERVICE INSPECTION OF THERMAL TEE SLEEVE WELDS
: 5.   -Leak detection is provided for the main steam tunnel, via the leak detection system in the control room which would detect a leak in the thermal tee sleeve weld.
: 6. The system design would allow for isolation of the thermal sleeve without adversely affecting plant safety.
      'VI. Alternative   Our inservice inspection plan requires that the thermal tee testing:      sleeve weld be examined twice during the-ten-year interval by the magnetic particle technique.
      'RUFNdb 29

l                                                                                                                                                                        Page 3 of 5             I i          ,
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CRAND GULF NUCLEAR STATION - UNIT 1                                                             .
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