View source for NRC 2008-0017, CFR 50.55a Request, Relief Request RR-21, Examination of the Reactor Pressure Vessels, Fourth Ten-Year Inservice Inspection Program Interval

{{Adams
| number = ML080770188
| issue date = 03/14/2008
| title = CFR 50.55a Request, Relief Request RR-21, Examination of the Reactor Pressure Vessels, Fourth Ten-Year Inservice Inspection Program Interval
| author name = Mccarthy J
| author affiliation = Florida Power &amp; Light 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 2008-0017, RR-21
| document type = Inservice/Preservice Inspection and Test Report, Letter type:NRC
| page count = 5
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:FPL Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241 FPL Energy Point Beach Nuclear Pilan~t March 14,2008                                                                             NRC 2008-0017 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-21, Examination of the Reactor Pressure Vessels Fourth Ten-Year lnservice Inspection Prosram Interval In accordance with 10 CFR 50.55a, "Codes and Standards," Paragraph (a)(3)(i), FPL Energy Point Beach, LLC (FPL Energy Point Beach) 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 with 2000 Addenda for examinations of the Point Beach Nuclear Plant Units 1 and 2 reactor pressure vessels (RPVs). Relief is requested on the basis that alternative methods will provide an acceptable level of quality and safety.
Specifically, relief is requested to use the qualification requirements for weld examinations conducted from the inside piping surface contained in ASME Code Case N-695, along with the vendor's root mean squared error achieved under the Performance Demonstration Initiative (PDI) at the Electric Power Research Institute (EPRI) Nondestructive Examination (NDE) Center. The Enclosure contains the details of the request for relief.
FPL Energy Point Beach requests approval of this request prior to October 1, 2008. The Unit 1 RPV examinations will be conducted during the fall 2008 refueling outage. The Unit 2 RPV examinations will be conducted during the fall 2009 refueling outage. The requested duration of these relief requests is for the remainder of the Fourth Ten-Year lnservice lnspection Program, which is scheduled to end on June 30, 2012, for both PBNP units.
An FPL Group company

Document Control Desk Page 2 Summary of Commitments This submittal contains no new commitments or revisions to existing commitments.
Very truly yours, FPL Energy Point Beach, LLC
( James H. McCarthy 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

ENCLOSURE RELIEF REQUEST RR-21 FPL ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT UNITS 1 and 2 REQUEST FOR RELIEF IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)
ALTERNATIVE REQUIREMENTS TO ASME SECTION XI APPENDIX VII, (SUPPLEMENTS 2 AND 10)
EXAMINATIONS OF CLASS 1 PRESSURE RETAINING WELDS CONDUCTED FROM THE INSIDE SURFACE ASME Code Component(s) Affected Code Class:                           1 Examination Categories:               Category R-A Item Numbers:                         R1.20 (Nozzle-to-Pipe, Elbow-to-Nozzle)
Component Numbers:                    See Table 1 Drawing Numbers:                      See Table 1

===Applicable Code Edition and Addenda===
The current inservice inspection program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, Section XI, 1998 Edition with 2000 Addenda. Testing of personnel, procedures and equipment for the ultrasonic examination of applicable Class 1 and 2 components is governed by Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems," of the ASME Code, Section XI.
Applicable Code Requirements The examination of Class 1 and 2 piping welds are required to be performed using procedures, personnel and equipment qualified to the criteria of the ASME Code, Section XI, Appendix VIII, Supplement 10, "Qualification Requirements for Dissimilar Metal Pipe Welds," for the examination of ltem R1.20 nozzle-to-piping welds.
Paragraph 3.2, "Sizing Acceptance Criteria," Subparagraph (b) of Supplement 10, states that the "examination procedures, equipment, and personnel are qualified for depth-sizing when the RMS [root mean square] error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125-inch (3.2mm)."
Code Case N-695, "Qualification Requirements for Dissimilar Metal Piping Welds, Section XI, Division 1," provides alternative requirements to Appendix VIII, Supplement 10 and is unconditionally approved for use through Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 15.
Paragraph 3.3(c) of Code Case N-695 states, "Examination procedures, equipment, and personnel are qualified for depth-sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, do not exceed 0.125-in. (3 mm)."
Page 1 of 3

Reason for the Request FPL Energy Point Beach is performing volumetric examinations of all reactor pressure vessel (RPV) nozzle-to-piping dissimilar metal (DM) welds from the inside diameter (ID) surface during the upcoming ten-year IS1 inspections. FPL Energy Point Beach will implement the NRC-approved alternative requirements of Code Case N-695 for qualification.
FPL Energy Point Beach proposes using an alternative RMS error depth-sizing requirement as compared to the 0.125-inch RMS error value stated in Code Case N-695. An FPLE Point Beach representative was at the Electric Power Research Institute (EPRI) NDE Center on August 22 and 23, 2007, and confirmed with the Performance Demonstration Initiative (PDI) Administrator that no vendor has successfully demonstrated compliance with the Code-required 0.125-inch RMS value for qualification tests for examinations conducted from the ID surface (for either stand-alone Supplement 10 or combined Supplement 2 and 10 qualifications).
FPL Energy Point Beach has verified through the PDI Administrator that the examination vendor selected to perform the scheduled examinations at FPLE Point Beach has achieved a 0.212-inch RMS error for the Supplement 10 qualification; a 0.211-inch RMS error for the Supplement 2 qualification; and a 0.211-inch RMS error for the Combined Supplement 2 and10.
Proposed Alternative and Basis for Use Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested for an alternative requirement that will provide an acceptable level of quality and safety.
For examinations of DM welds (Supplement 1O), FPL Energy Point Beach proposes to apply the difference between the examination vendor's achieved RMS error and the Code Case N-695 required 0.125-inch RMS error to actual flaw depths when depth-sizing of indications is required.
Applying the difference between the required RMS error and the achieved RMS error to the actual flaw being sized will ensure a conservative bounding flaw depth for dissimilar metal welds examined at Point Beach Nuclear Plant (PBNP) Units 1 and 2.
Duration of Proposed Alternative This relief request will be implemented during the remainder of the Fourth Ten-Year lnservice lnspection Program, which is scheduled to end on June 30, 2012, for both PBNP units.
Precedents Similar relief requests have been granted to the following plants:
NRC to Southern Nuclear Operating Company Inc. letter, "Joseph M. Farley Nuclear Plant, Unit 1, and Vogtle Electric Generating Plant, Units 1 and 2 - Evaluation of Relief Request ISI-GEN-ALT-06-02," (TAC Nos. MD 2482, MD2483 and MD2484), dated September 29,2006, (ML062770359)
NRC to Exelon Generating Company, LLC letter, "Braidwood Station, Units 1 and 2 - Relief Request (12R-49) Regarding lnservice lnspection Program Alternative Method (TAC Nos.
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MD5996 and MD5997)," dated November 8,2007, (ML072760048)
Table 1 Applicable Components at Point Beach Nuclear Plant Units 1 and 2 Unit          Weld Number                     Description             Former ASME  Current XI Item  RI-IS1 Item Number    Number 1        RC-34-MRCL-AI-01           Outlet Nozzle to Pipe at 28.5"      B5.10      R1.20 1        RC-32-MRCL-AI11-03        Elbow to Inlet Nozzle at 328.5"      B5.10      R1.20 1        RC-34-MRCL-BI-01          Outlet Nozzle to Pipe at 208.5"      B5.10      R1.20 1        RC-32-MRCL-Blll-03        Elbow to Inlet Nozzle at 148.5"      B5.10      R1.20 1         RC-04-SI-1001-33       SI Safe-End to Nozzle (Az. 288.5")     B5.10      R1.20 1         RC-04-SI-1002-19       SI Safe-End to Nozzle (Az. 108.5")     B5.10      R1.20 2         RC-34-MRCL-AI-01           Outlet Nozzle to Pipe at 28.5"      85.10      R1.20 2         RC-32-MRCL-AIII-03        Elbow to Inlet Nozzle at 328.5"      B5.10      R1.20 2         RC-34-MRCL-BI-01          Outlet Nozzle to Pipe at 208.5"      B5.10      R1.20 2         RC-32-MRCL-BII1-03        Elbow to Inlet Nozzle at 148.5"      B5.10      R1.20 2           RC-04-SI-2001-26       Safe-End to SI Nozzle at 288.5"       85.10      R1.20 2           RC-04-SI-2002-29       Safe-End to SI Nozzle at 108.5"       B5.10      R1.20 RC = Reactor Coolant SI = Safety Injection Page 3 of 3}}