ML20006F035

Technical Evaluation Rept on First 10-yr Interval Inservice Insp Program Plan:Public Svc of New Hampshire,Seabrook Station,Unit 1.

ML20006F035
Person / Time
Site:	Seabrook
Issue date:	11/30/1989
From:	Beth Brown, Mudlin J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20006F020	List: ML20006F035
References
CON-FIN-D-6022 EGG-MS-8307, NUDOCS 9002270100
Download: ML20006F035 (31)

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EGG MS-8307 l

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i TECHNICAL EVALUATION REPORT ON THE FIRST 10 YEt,R INTERVAL INSERVICE INSPECTION PROGRAM PLAN: .

PUBLIC SERVICE OF NEW HAMPSHIRE, SEABROOK STATION, UNIT 1, DOCKET NUMBER 50 443  :

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! B. W. Brown J. D. Mudlin l Published November 1989 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho falls, Idaho 83415 Prepared for:

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 under DOE Contract No. DE AC07-761001570 FIN No. 06022 (Project 5) 9002270100 900215 PDR P

ADOCK 05000443 PNV ,,

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ABSTRACT This report presents the results of the evaluation of the Seabrook Station, Unit 1, First 10-Year Interval Inservice Inspection (ISI) Program Plan, Revision 0, submitted April 14, 1987, including the requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical. The Seabrook Station, Unit 1, First 10 Year Interval ISI Program Plan is evaluated in Section 2 of this report. Tne ISI Program Plan is evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI related commitments identified during the Ntclear '

Regulatory Commission (NRC) review before granting an Operating License.

The requests for relief from the ASME Code requirements which the Licensee has determined to be impractical for the first 10 year inspection interval >

are evaluated in Section 3 of this report.

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This work was funded under:

U.S. Nuclear Regulatory Commission FIN No. 06022, Project 5 Operating Reactor Licensing Issues Program, Review of ISI for ASME Code Class 1, 2, and 3 Components 11

SUMMARY

The Licensee, Public Service of New Hampshire, has prepared the Seabrook- I Station, Unit 1, First 10 Year Interval Inservice Inspection (ISI) Program Plan, Revision 0, to meet the requirements of the 1983 Edition, Summer 1983

! Addenda (83S83) of the ASME Code Section XI except that the extent of examination of pressure retaining welds in Code Class 2 piping has been determined using the alternative rules of ASME Code Case N 408, "

Alternative Rules for Examination of Class 2 Piping,Section XI, Division 1."  !

The information in the Seabrook Station, Unit 1, First 10-Year Intarval ISI Program Plan, Revision 0, submitted April 14, 1987, was reviewed. Included in the review were the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical. As a result of this review, a request for additional information (RAI) was prepared describing the information and/or clarification required from the Licensee in order to complete the review. The Licensee provided the requested information in the submittal dated June 3,1988.

Based on the review of the Seabrook Station, Unit 1, First 10-Year Interval ISI Program Plan, Revision 0, the Licensee's response to the NRC's RAI, and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded thet the Seabrook Station, Unit 1, First 10-Year Interval ISI Program Plan, Rev mion 0, is acceptable and in compliance with 10 CFR 50.55a(g)(4).

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CONTENTS

< ABSTRACT ..............................................................., 11

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SUMMARY

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1. INTROC.; TION ......................................................... I

2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN ..................... 4 2.1 Docume n t s ' Ev a l u a t ed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.2 Compliance with Code Requirements ................................ 4 2.2.1 Compl iance wi th Applicable Code Editions . . . . . . . . . . . . . . . . . . . . . 4 2.2.2 Acceptability of the Examination Sample ...................... 5 2.2.3 Exclusion Criteria ........................................... 5 2.2.4 Augmented Examination Commitments ............................ 5 1- 2.3 Conclusion ............................... ....................... 6

3. EVALUATION OF REllEF REQUESTS ....................................... 7 3.1 C' ass 1 Compenents ............................................... 7 i

L 3.1.1 Reactor Pressure Vessel ....................................... 7 3.1.1.1 Request for Relief IR-1 (Part 1 of 2), Examination i Category B-A, Items Bl.ll, B1.12, B1.21, Bl.22, B1.30, and B1.40, Reactor Pressure Vessel Welds .......... 7 3.1.1.2 Request for Relief IR-1 (Part 2 of 2), _ Examination Category B-0, Item 83.90, Reactor Pressure 1

Vessel Nozzle-to Vessel Welds ............................ 9 1'

3.1.2 Pressurizer ................................................. 10 3.1.2.1 Request for Relief IR-2 (Part 1 of 4), Examination Category B-B, Item B2.11, Pressurizer Vessel Welds ...... 10 3.1.2.2 Request for Relief IR-2 (Part 2 of 4), Examination Category B-0, items 83.110 and 83.120, Pressurizer Nozzle-to-Vessel Wolds and Nozzle Inside Radius Sections ................................................ 11 3.1.3 Heat Exchangers and Steam Generators ........................ 12 3.1.3.1 Request for Relief IR 2 (Part 3 of 4), Examination Category B-8, Item B2.40, Steam Generator Tubesheet-to Head Welds ................................. 12 iv

.'6; -c 3.1.3.2 Request for Relief IR 2 (Part 4 of 4), Examination Category B 0, item 83.130, Steam Generator, 5

Cl a s s 1, Nozzle to Ve ssel Welds . . . . . . . . . . . . . . . . . . . . . . . . . 14 3.1.4 -Piping Pressure Boundary .................................... 15 3.1.4.1 Request for Relief IR-3, Examination Category B J, Items 89.11 and' B9.31, Class 1, Pressure Retaining -

Wel S in Piping, and Examination Category B-F, Items B5.10 and B5.70, Pressure Retainin Dissimilar Metal Welds ............................g ................. 15 3.1.5 Pump Pressure Boundary (No relief requests)  :

3.1.6 Valve Pressure 9 mdary (No relief requests) 3.1.7 General (No relief requests) 3.2 Class 2 Components .............................................. 18 3.2.1 Pressure Vessels ............................................ 18 3.2.1.1 Request for Relief IR-4 (Part 1 of 2), Examination Category C A, items C1.10, C1.20, and C1.30, Pressure Retaining Welds in Class 2 Pressure Vessel s . . . . . . . . . . . . . .18 3.2.1.2 Request for Relief IR-4 (Part 2 of 2), Examination Category C 8, Items C2.21 and C2.22, Steam Generator, Class 2, Nozzle-to-Vessel Welds and Nozzle Inside Radius Sections ..........................................-19 3.2.2 Piping ...................................................... 21 3.2.2.1 Request for Relief IR-5,-Examination Category C-F-1, Item C5.ll, and Examination Category C-F-2, Items-C5.52-and C5.81, Pressure Retaining Welds in Class 2 Piping .................................................. 21 1 3.2.3 Pumps (No relief requests) 3.2.4 Valves (No relief requests)

l. 3.2.5 General (No relief requests) 3.3 Class 3 Components (No relief requests) 3.4 Pressure Tests (No relief requests) l 3.5 General (No relief requests)

4. CONCLUSION ......................................................... 25

5. REFERENCES ......................................................... 26 v

. .: l TECHNICAL EVALUATION REPORT ON THE FIRST 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

PUBLIC SERVICE OF NEW HAMPSHIRE, SEABROOK STATION, UN!T 1.

DOCKET NUMBER-50-443

1. INTRODUCTION Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) (Reference 1) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," (Reference 2) to the extent practical within the limitations of design, geometry, and materials of co.1struction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during the initial 120-month inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the date of issuance of the operating license, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10'CFR 50.55a(b) subject to the limitations and modifications listed therein. The Licensee, Public Service of New Hampshire, has prepared the Seabrook Station, Unit 1, First 10-Year Interval Inservice Inspection (ISI)

Program Plan, Revision 0, to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examinatic- t pressure retaining welds in Code Class 2 piping has been determined by ASME Code Case N 408, " Alternative Rules for Examination of Class 2 Piping,Section XI, Division 1" (Reference 3).

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief from them, l

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'the licensee shall submit information and justifications to the Nuclear Regulatory Commission (NRC) to support that determination. >

Pursuant to 10 CFR 50.55a(g)(6), the NRC will evaluate the licensee's determinations under 10 CFR 50.55a(g)(5) that Code requirements are

-impractical. 1he NRC may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life or property or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. -

The information in the Seabrook Station, Unit 1, First 10-Year Interval ISI Program Plan, Revision 0, submitted April 14, 1987 (Reference 4), was reviewed, including the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical. The review of-the ISI Program Plan was performed using the Standard Review Plans of NUREG-0800 (Reference 5), Section 5.2.4, " Reactor Coolant Boundary Inservice Inspectior.s and Testing," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components."

In a letter dated April 4,1988 (Reference 6), the NRC requested additional '

information that was required in order to complete the review of the ISI Program Plan. The requested information was provided by the Licensee in the

" Response to Request for Additional Information - ISI Program" dated June 3, 1988 (Reference 7).

The Seabrook Station, Unit 1, First 10-Year Interval ISI Program Plan is evaluated in Section 2 of this report. The ISI Program Plan is evaluated '

for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI-related commitments identified during the NRC's review before I- granting an Operating License.

The requests for relief are evaluated in Section 3 of this report. Unless otherwise stated, references to the Code refer to the ASME Code,Section XI, 2

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1983 Edition including' Addenda through Sumer 1983, Specific. inservice-l test (IST) programs for pumps and valves are being evaluated in other reports.

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% 2.' .EVALVATION OF INSERVICE INSPECTION PROGRAM PLAN This evaluation consisted of a review of the applicable program-documents to determine whether or not they are in compliance with the Code requirements and'any' license conditions pertinent to IS! activities. This section describes the submittals reviewed and the results of the review. ,

2.1 Documents Evaluated

a Review has been completed on.the following information:  ;

(a) "Seabrook Station, Unit 1, First 10 Year Interval inservice Inspection Program Plan," Revision 0, submitted April 14, 1987; f (b) Licensee's " Response to Request for Additional Information - ISI Program;" and (c) NUREG 0896, Supplement No. 5, " Safety Evaluation Report related to the operation of Seabrook Station, Units 1 and 2," (Reference 8),

2.2 Comoliance with Code Reauirements 2.2.1 Comoliance with Acolicable Code Editions The Inservice Inspection Program Plan shall be based on the Code editions defined in 10 CFR 50.55a(g)(4) and 10 CFR 50.55a(b). Based on the operating license date of October 1986, the Code applicable to the first-interval ISI program is the 1983 Edition with Addenda through Summer 1983. As stated in Section 1 of this report, the Licensee has prepared the Seabrook Station, Unit 1, First 10-Year Interval ISI Program i

Plan, Revision 0, to meet the requirements of the 1983 Edition,

.- Summer 1983 Addenda of the Code except that the extent of examination of pressure retaining welds in Code Class 2 piping has been determined by ASME Code Case N-408, " Alternative Rules for Examination of Class 2 Piping,Section XI, Division 1." This Code Case has been approved by the NRC as referenced in Regulatory Guide 1.147, 4

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" Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1" (Reference 9).

2.2.2 Accentability of the Examination Samole Inservice volumetric, surface, and visual examinations shall be performed ori ASME Code Class 1, 2, and 3 components and their supports using .

sampling schedules described in Section XI of the ASME Code and 10 CFR 50.55a(b). Sample size and weld selection have been implemented in accordance with the Code and appear to be correct.

2.2.3 I nl.psion Criteria The criteria used to exclude components from examination shall be consistent with Paragraphs IWB-1220, IWC-1220, IWC-1230, IWD-1220, and 10 CFR 50.55a(b). The exclusion criteria have been applied by the Licensee in accordance with the Code as discussed in the ISI Program Plan, Section 6, " Exemptions," and appear to be correct. It is noted that the exemption criteria for Code Class 2 components have been revised to include portions of ASME Code Case N-408, " Alternative Rules for Examination of Class 2 Piping,Section XI, Division 1." Using the exemption criteria contained in ASME Code Case N 408, the Licensee has committed to volumetrically examine a minimum of 7.5% of the Class 2 piping welds in the engineered safety systems, including the Residual Heat Removal (RHR) Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems.

2.2.4 Auamented Examination Commitments The Licensee has stated in the ISI Program Plan that augmented examinations are being implemented during the first 10-year inspection interval per the following documents:

(a) Regulatory Guide 1.150, Revision 1, " Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examination" (Reference 10).

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(b) Regulatory; Guide 1.14,- Revision 1 " Reactor Coolant Pump Flywheel Integrity" (Ref.erence 11).

(c) IE-Bulletin 79-13, Revision 2, " Cracking in Feedwater System Piping" (Reference 12),

in-addition, the L censee's Final Safety Analysis Report (FSAR),

Section 6.6.8, contains a commitment for an augmented inservice inspection program to protect against postulated pipe failures in certain high energy lines penetrating the containment building. -The main steam and feedwater system piping between the first pipe whip restraint inside containment'and the first pipe whip restraint outside containment, and the 3-inch letdown '

line between the containment penetration and the outermost containment isolation valve, are subject to augmented inservice inspection. The augmented inspection consists of examination of essentially 100% of the longitudinal and circumferential piping welds within the defined boundaries during each inspection interval.

'2.3 Conclusion Based on the review of the documents listed above, it is concluded that the Seabrook Station, Unit 1, First 10-Year Interval Inservice Inspection Program Plan, Revision 0, is acceptable and in compliance with 10 CFR 50.5a(g)(4).

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3. EVALUATION OF RELIEF REQUESTS The requests for relief from the ASME Code requirements which the Licensee

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-has determined to be impractical for the Seabrook Station, Unit 1, first 10-year inspection interval are evaluated in the following sections.

3.1 Class 1 ComDonents 3.1.1- Reactor Pressure Vessel r

3.1.1.1 Reauest for Relief IR-1 (Part 1 of 2). Examination Cateaory B-A. Items 81.11. Bl.12. Bl.21. Bl.22. B1.30. and Bl.40. Reactor Pressure Vessel Welds Code Reauirement: Section XI, Table IWB-2500-1, Examination Category B-A, Items B1.11, Bl.12, B1.21, Bl.22, Bl.30, and Bl.40 require a 100% volumetric examination of all'the Reactor

. Pressure Vessel (RPV) shell, head, shell-to-flange, and head-to-flange welds, licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required and/or Regulatory Guide 1.150-required volume of the following RPV welds:

Item Percent Examinable Number comoonent ID ASME Code RG 1.150 81.11 RPV shell circumferential welds:

1 RC-RPV-103-121 93% 100% >

L RC-RPV-104-141 68% 74%

1 i Bl.12 RPV shell longitudinal welds:

RC-RPV-101-122-42' 68% 73%

RC-RPV-101-122-162* 82% 88%

RC-RPV-101-122-282* 94% 85%

81.21 RPV circumferential head welds:

RC-RPV-103-101 50% 50%

RC-RPV-102-151 68% N/R 7

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- Pe acent Exam'inable Number comoonent ID ASMR Code RG 1.150-Bl.22 RPV meridional head welds:-

RC RPV-101-154 0' 80% 80%

RC RPV-101-154-90': 89% 88%'

RC RPV-101-154-180' 82% 83%  :

RC RPV-101-154-270' 93%. 98%

Bl.30- RPV shell-to flange weld L. RC RPV-101-121 82% 56%

Bl.40- RPV head-to flange weld RC-RPV-101-101 50% 50% -

Licensee's Procosed Alternative Examination: None. The Code-required volumetric examination will be completed to the-  ;

maximum extent practical.

Licensee's Basis for Reouestina Relief: Geometric configuration and permanent obstructions prohibit 100%

volumetric examination of the Code-required volume of the subject welds.

Evaluation: The volumetric examination of the subject welds is impractical to perform to the extent required by the Code due to the obstructions described in the Licensee's submittal (i.e., weld geometry, control rod drive interference, ,

obstructions presented by instrumentation nozzles, nozzle knuckles, lifting lug, and core support lug). A significant percentage of the Code-required and/or Regulatory Guide 1.150 required volumetric examination will be completed; this percentage is consistent with plants of similar design.

Conclusions:

Based on the above evaluation, it is concluded that the Code requirement is impractical-for the subject welds and that the limited Section XI volumetric examination, along-I with the Code-required pressure test, provides reasonable assurance of the continued inservice structural integrity.

Therefore, it is recommended that relief be granted as requested.

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.c 3. l'.1. 2 Reauest for Relief 'IR (Part 2 of 2). Examination ,

Cateaory B-0. Item 83.90; Reactor Pressure Vessel Nozzle-to-Vessel Welds Code Reouirement: Section XI, Table IWB 2500-1, Examination Category B D, Item B3.90' requires a 100% volumetric examination of the RPV nozzle-to-vessel welds as defined by Figure IWB-2500-7.

Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required and/or Regulatory Guide 1.150 required volume of the following RPV nozzle-to vessel welds:

Reauired Volume Coveraae Nozzle ID ASME Code RG 1.150 RC-RPV-107-121-A 84% 74% 1 RC-RPV-107-121-D 84% 74%

RC-RPV-107-121-E 84% 67%

RC-RPV-107 121-H 85% 80%

RC-RPV-107-121-B 100% 96%

L RC-RPV-107-121-C 100% 99%

RC-RPV-107-121-F 100% 99%

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RC-RPV-107-121-G 100% 98%

Licensee's Proposed Alternative Examination: None. The Code-required volumetric examination will be completed to the  ?

l maximum extent practical.

Licensee's Basis for Reauestina Relief: The geometric configuration of the nozzle knuckles prohibits 100% volumetric examination of the Code-required volume of the subject RPV nozzle-to-vessel welds.

Evaluation: The volumetric examination of the subject welds is impractical to perform to the extent required by the Code due to the obstructions described in the Licensee's submittal (i.e., outlet nozzle knuckle obstructing examination of the inlet nozzle-to-vessel weld). A significant percentage of the Code-required and/or Regulatory Guide 1.150-required volumetric 9

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, examination will be completed; this percentage is consistent  ;

with plants of similar design. I i

Conclusions:

' Based on the above evaluation, it is concluded that the Code requirem,nt is impractical for the subject welds.

and that the limited Section XI volumetric examination,-along 4 with the Code-required pressure test, provides reasonable assurance of the continued inservice structural integrity.

Therefore, it is recommended that relief be granted as requested.

3.1.2 Pressurizer 3.1.2.1 Reauest for Relief IR-2 (Part 1 of 4). Examination '

Cateoorv B-B. Item B2.11. Pressurizer Vessel Welds Code Reauirement: Section XI, Table IWB-2500-1, Examination 1 Category B-B, Item B2.11 requires a 100% volumetric examir ation of Pressurizer circumferential shell-to-head welds as defined by Figure IWB-2500-1.

Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume (CRV) of the '

following Pressurizer circumferential welds:

CRV Weld ID Examinable L l-RC-E-10-4 96%

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~ 1-RC-E-10-9 95%

1-RC-E-10-1 80% .

Licensee's Prooosed Alternative Examination: None. The Code-required volumetric examination will be completed to the

maximum extent practical.

Licensee's Basis for Reauestina Relief: The Licensee reports that geometric configuration and permanent obstructions prohibit performance of a 100% volumetric examination of each of the subject welds.

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i Evaluation:- The volumetric examination of the circumferential shell-to head welds is impractical to perform to the extent required by the Code because of OD interferences. A significant percentage (80 to 96%) of the Code-required volumetric examination will be completed on each of the subject welds. '

Conclusions:

Based on the above evaluation, it is concluded '

that the Code requirement is impractical for the subject' welds and that the limited Section XI volumetric examination, along i with the Code-required pressure test, provides reasonable assurance of the continued inservice structural integrity.

Therefore, it is recommended that relief be granted as requested. <

3.1.2.2 Reauest for Relief IR-2 (Part 2 of 4). Examination Cateaorv B D. Items 83.110 and B3.120. Pressurizer  ;

Nozzle-to-Vessel Welds and Nozzle Inside Radius Sections Code Reauirement: Section XI. Table IWB-2500-1, Examination Category B-0, Items 83.110 and B3.120 require a 100% volumetric examination of the . Pressurizer nozzle-to-vessel welds and l- nozzle inside radius sections, respectively, as. defined by Figure IWB-2500-7.

Licensee's Code Relief Reauest: Relief is requested from l'

examining 100% of the Code-required volume (CRV) of the  !

following Pressurizer nozzle-to-vessel welds and nozzle inside radius sections

CRV Nozzle ID Examinable RC-E-10-A-NZ 75% 4 RC-E-10-B-NZ 75%

RC-E-10 C-NZ 75%

l , RC-E-10-0-NZ 75%

L RC-E-10-SP-NZ 75%

L RC-E-10-S-NZ 74%

L RC-E-10-S-IR 74%

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. , . Licensee's Procosed Alternative Examination: None. The' Code required volumetric examination will-be completed to the maximum-extent = practical. '

ticensee's Basis for Reouestino Relief: The Licensee reports that geometric configuration and/or I.D. cladding prohibit performance of a 100% volumetric examination on each of the subject welds.

Evaluation: The volumetric examination of the Pressurizer ,

nozzle-to-vessel welds' and nozzle inside radius sections listed above is impractical to perform to the extent required by the Code due to the geometric configuration, I 0, cladding, and heater penetrations. A significant percentage (at least 74%)-

of the Code-required volume can and will-be examined.

[onclusions: ' Based on the above evaluation, it is concluded that the Code requirement is impractical for the subject l nozzles and that the limited Section XI volumetric examination, along with the Code-required pressure test, provides reasonable assurance-of the continued inservice structural integrity. '

Therefore, it is recommended that relief be granted as requested.- i E 3.1.3 Heat Exchancers and Steam Generators 3 .1. 3 '.1 Reouest for Relief IR 2 (Part 3 of 4). Examination Cateoory B-B. Item B2.40. Steam Generator Tubesheet-to-Head EAldi l

Code Reouirement: Section XI, Table IWB-2500-1, Examination Category B-B. Item B2.40 requires a 100% volumetric examination

). of Steam Generator tubesheet to-head welds as defi~ned by Figure IWB-2500-6. ,

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Licensee's Code Relief Recuest: Relief is requested from a examining 100% of the Code-required volume (CRV) of the  ;

following Steam Generator tubesheet-to-head welds: l t

CRV Weld 10 Examinable l RC-E-IIA Seam 1 78%

l-RC-E-llB Seam 1 78%

l-RC-E-llc Seam 1 78%

l-RC E-llD Seam 1 78%

Licensee's Prooosed Alternative Examination: None. The Code-required volumetric examination will be completed to the '

maximum extent practical.

Licensee's Basis for Reauestina Relief: The Licensee reports t that the Steam Generator supports prohibit performance of a 100% volumetric examination of each of the subject welds. In addition, the surface contour further restricts examination of Weld 1-RC-E-llA, Seam 1, during the 60* scan.

Evaluation: The volumetric examination of the Steam Generator tubesheet-to-head welds listed above is impractical to perform to the extent required by the Code due to support l obstructions. A significant percentage (78%) of the l Code-required volumetric examination will be completed on each of the subject welds.

Conclusions:

Based on the above evaluation, it is concluded that the Code requirement is impractical for the subject welds L and that the limited Section XI volumetric examination, along I with the Code-required pressure test, provides reasonable assurance of the continued inservice structural integrity.

Therefore, it is recommended that relief be granted as

[ requested.

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., 3.1.3.2 Reouest for Relief IR-2 (Part 4 of 4). Examination Cateaorv!3-D. Item 83.130. Steam Generator. Class 1.

Nozzle-to-Vessel-Welds Code Reauirement: Section XI. Table IWB-2500 1 Examination Category B-C, item B3.130 requires a 100% volumetric examination of Steam Generator, Class 1, nozzle-to-vessel welds as defined by Figure IWB 2500-7.

Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume (CRV) of the following Steam Generator, Class 1, nozzle-to-vessel welds:

CRV Nozzle ID Examinable 1-RC-E-IIA 2A NZ 75%

l-RC-E llA-2B-NZ 75%

l-RC-E-llB-2A-NZ '75%

l RC-E-llB-28-NZ 75%

l-RC-E-11C-2A-NZ 75%

l-RC-E llc-28-NZ 75%

l-RC-E-llD-2A-NZ 75%

l-RC-E-llD 2B NZ 75%

Licensee's Prooosed Alternative Examination: None. The Code-required volumetric examination will be completed to the maximum extent practical.

Licensee's' Basis for Reauestina Relief: The Licensee reports that gecmetric configuration and/or I.D. cladding prohibit performance of a 100% volumetric examination on each of the subject welds.

Evaluation: The volumetric examination of the Steam Generator nozzle-to-vessel welds listed above is impractical to perform to the extent required by the Code due to the geometric configuration and/or I.D. cladding. A significant percentage (75%) of the Code-required volume can and will be examined.

Conclusions:

Based on the above evaluation, it is concluded that the Code requirement is impractical for the subject welds 14

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and-that the limited Section XI volumetric examination, along I with the Code required pressure test, provides. reasonable assurance of the continued inservice structural' integrity.

Therefore, it is recommended that relief be granted as requested. -

3.1.4 Pioina Pressure Boundary 3.1.4.1 Reauest for Relief IR-3. Examination Cateoorv B-J. Items 89.11 and 89.31. Class 1 Pressure Retainino Welds in Pioina, and Examination Cateoory B F. Items 85.10 and B5.70. Pressure

~Retainino Fissimilar Metal Welds Code Reauirement: Section XI, Table IWB-2500-1, Examination Category B-J, Items 89.11 and 89,31, and Examination Category B-F, Items 85.10 and 85.70 all require both 100%

surface and volumetric examinations as defined by Figure IWB-2500-8.

,. Licensee's Code Relief Reauest: Relief is requested from i examining 100% of the Code-required volume (CRV) of the

} following welds:

Item CRV Number Weld Identification Examinable 89.11 Reactor Coolant Main Loop 1 piping welds:

1-RC-1-1-1 75%- -

1-RC-2-1-2 95%

l l-RC-2-1-5 95%

l-RC-2-1-6 99%

, 1-RC-3-1-3 <1%

B9.11 Reactor Coolant Main Loop 4 piping welds:

1-RC-10-1-1 75%

1-RC 12-1-3 <l%

B9.11 Reactor Coolant Main Loop 2 piping welds:

1-RC-4-1-1 75%

l-RC-5-1-2 93%

l-RC-5-1-5 95%

l-RC-6-1-3 <1%

15

3

' Item CRV Number Weld Identification Examinahh _  ;

B9.11 Reactor Coolant Main loop 3 piping welds: .

l-RC 7-1-1 75%

~

l-RC-8-1-2' 95%

l RC-9-1-3 <1%

B9.31 Branch connection piping welds:

1 RC-1-1-5B 33%  !

l RC-3-1-5B 50%

l-RC-4-1 5B 50%

l-RC-6-1-38 50%

l-RC-7-1-5B 50% >

l-RC-7 1-6B 50%

l-RC-9 1-4B 50%

l-RC 10-1-5B '50%

l-RC-12-1 4B 50%

B9.11 Branch piping welds:

1-SI-203-2-2 84%

1-RH-158-5-19 75%

l-RH-158 5 20 78%

l RH-160-17-2 50%

l RC-48 2-2 50%

l B5.10 Reactor Vessel safe end weld RC-RPV-SE-301-121-D 97%-

B5.70 Steam Generator safe end welds:

! l-RC 1-1-3 25%

l-RC-2-1-1 25%

l-RC-4-1-3 25%  :

1-RC-5 1-1 25% <

L 1-RC-7-1-3 25%

l-RC-8-1-1 25%

l-RC-10-1-3 25%

1-RC-11-1-1 25%

Licensee's Procosed Alternative Examination: None. The Code-required volumetric examination will be completed to the maximum extent practical. These welds will receive the Code-required surface examination.

Licensee's Basis for Recuestinn Relief: The Licensee reports that geometric configurations (i.e., elbow-to-pump, elbow-to-safe end), permanent obstructions, and/or metallurgy restrictions prohibit 100% of the Code-required volumetric examination on the subject welds.

16

y 3 ,

a Evaluation: The volumetric examinations of the welds listed above are impractical to perform to the extent required by the Code due to the geometric configurations, permanent.

obstructions, and/or metallurgy restrictions.

4 With regard to the metallurgical properties of the cast stainless steel fittings and based on discussions and demonstrations performed by the Licensee during a meeting at '

the plant site in May 1986, it is determined that the volumetric examinations of the cast stainless steel fittings in ,

the primary coolant system at Seabrook meet the methodology requirements of Section XI of the ASME Code and that-the -

detection of significant defects, if.present, would be possible with the equipment and procedures being used.

It is also reported that complete examinations which meet the requirements of ASME Section XI will be completed on welds of ,

similar configuration using the same inspection techniques, equipment, and procedures as the partially inspected or uninspected welds. Since the partially inspected or uninspected welds will see the same operating and environmental-conditions as .the inspected welds, reasonable assurance of the structural integrity of the welds for which relief is requested will be attained.

Conclusions:

Based on the above evaluation, it is concluded that the Code requirement is impractical for the subject welds and that the limited Section XI volumetric examination, along with the Code-required surface examination and-pressure test, provides reasonable assurance of the continued inservice structural integrity. Therefore, it is recommended that relief be granted as requested.

3.1.5 Pumo Pressure Boundarv (No relief requests) 3.1.6 Valve Pressure Boundary (No relief requests) 17

.. .. j

. 3.1.7 General (No relief requests) ,

3.2 Class 2 Comoonents .

-3.2.1 Pressure Vessels 3.2.1.1 Recuest for Relief IR-4 (Part 1 of 2). Examination Cateaory C A. Items C1.10. C1.20. and C1.30. Pressure Retainina Welds in Class 2 Pressure Vessels Code-Recuirement: Section XI, Table IWC 2500-1 Examination Category C A, Items C1.10, Cl.20, and C1.30 require a 100%

volumetric examination of Class 2 Pressure Vessel pressure 4 retaining shell circumferential welds, head circumferential welds, and tubesheet-to shell welds, respectively, as defined by Figures IWC-2500-1 and IWC-2500-2, Licensee's Code Relief Reauest: Relief is requested from  !

examining 100% of the Code required volume (CRV) of the following welds:

CRV Number Weld Identification Examinable L

Cl.10 Steam Generator shell circumferential welds:

1-RC-E-11A Seam 6 96%

L l-RC-E-llA Seam 5 80%

( l-RC-E-11A Seam 3- 99%

l l-RC-E-118 Seam 6 95%

1-RC-E-llB Seam 5 79%

l-RC-E-118 Seam 3 80%

l-RC-E-llc Seam 6 95%

1-RC-E-Ilc Seam 5 78%

l-RC-E-110 Seam 6 92% '

l-RC-E-llD Seam 5 83%

i C1.20 Steam Generator head circumferential weld 1-RC-E-11A Seam 8 98%

C1.30 Steam Generator tubesheet

-to-shell weld 1-RC-E-llA Seam 2 86%

18

j i

CRV Number- Weld Identification Examinable C1.10 Regenerative Heat Exchanger shell circumferential welds: -

1-CS F-2-REG-4A 70.4% -

1-CS-E 2-REG-4B 70.4%

C1.20 Excess Letdown Heat Exchanger head circumferential weld 1-CS-E 3C 46.4%

Licensee's Prooosed Alternative Examination: None. The Code-required volumetric examination will be completed to the maximum extent practical.

Licensee's Basis for Reouestino Relief: The Licensee reports that geometric configuration and permanent obstructions prohibit the performance of a 100% volumetric examination of each of the subject welds.

Evaluation: The volumetric examination of the subject welds is -

impractical to perform to the extent required by the Code due to the geometric configuration and permanent obstructions (i.e., surface / weld contour, plates, instrumentation lines, surfacegouge). A significant percentage of the Code-required volume will be volumetrically examined.

Conclusions:

Based on the above evaluation, it is. concluded that the Code requirement is impractical for the subject welds and that the limited Section XI volumetric examination will provide reasonable assurance of the continued inservice structural integrity. Therefore, it is recommended that relief be granted as requested.

3.2.1.2 Reouest for Relief IR-4 (Part 2 of 2). Examination (jttecory C-8. Items C2.21 and C2.22. Steam Generator. Class 2.

Nozzle-to-Vessel Welds and Nozzle inside Radius Sections Code Reouirement: Section XI, Table IWC-2500-1, Examination Category C-8, Items C2.21 and C2.22 require a 100% volumetric

~

19

7:ge v v y

examination of the Steam Generator Class 2 nozzle-to-vessel-nelds and nozzle inside radius sections as defined by-Figure IWC-2500 4. F licensee's Code Relief Recuest: Relief is requested from examining' 100% of the Code-required volume (CRV) of the following Steam Generator, Class 2, nozzle-to vessel welds and  ;

nozzle inside radius sections:

CRV I Nozzle ID Examinable 1-RC E-llB llNZ 89%

l RC-E-llD-16NZ 57%

l-RC E-llA-161R 0% - due to I.D. geometry 1 RC-E-II.B-161R 0% - due to I.D. geometry 1-RC-E-llc-161R 0% - due to I.D. geometry 1-RC E-llD 161R 0% - due to I.D. geometry 1-RC-E-11C-111R 0% - due to surface contour Licensee's Procosed Alternative Examination: None. The Code-required volumetric examination on the Steam Generator nozzle to-vessel welds will be completed to the maximum extent practical.

Licensee's Basis for Reauestino Relief: The Licensee states that the volumetric examinations of the Steam Generator nozzle-to-vessel welds and the nozzle inner radius on 1-RC-E llc-IIIR are_ limited by surface roughness and that the volumetric examinations of the nozzle inner radius sections on the steam outlet nozzles (16IR) are prohibited due to the nozzle configuration.

Evaluation: The volumetric examination of the Steam Generator ,

nozzle-to-vessel welds is impractical to perform to the extent required by the Code due to nozzle and surface contours. A significant percentage (57 and 89%) of the Code requireo volume <

x will be examined.

The Licensee provided a drawing of a portion of the Steam Generator vessel, in the submittal dated June 3,1988, showing the steam outlet nozzle. The drawing shows that the steam 20

43 e e; 4

outlet nozzle was designe'd with an internal multiple venturi L

type flow restrictor. This design does not utilize a radiused nozzle as described in Figure IWC-2500 4, but instead has '

several individual inner radti,' corresponding to 'each venturi.

Therefore, the Code required volumetric examination of these nozzle inner radius sections is impractical to perform.

Conclusions:

Based on the above evaluation, it is concluded i that the Code requirement is impractical for the subject nozzles and that the limited Section XI volumetric examination of the nozzie to vessel welds provides reasonable assurance of the continued inservice structural integrity. Therefore, it is ,

recommended that relief be granted as requested.

4 3.2.2 Pioino 3.2.2.1 Reauest for Relief IR-5. Examination Cateaory C-F-1. Item C5.11. and Examination Cateoory C-F-2. Items C5.52 and C5.81.

Pressure Retainino Welds in Class 2 Pipina' Code Reauirement: For Seabrook Unit 1, these examinations will be performed in accordance with ASME Code Case N 408. ASME Code Case N-408, Examination Category C-F-1, Item C5.11 requires both 100% surface and volumetric examinations of y Class 2 pressure retaining circu.nferential piping welds with equal to or greater than 3/8 inch nominal wall thicknesses for ,

piping greater than 4 inch nominal pipe size as defined by Figure IWC-2500-7. Examination Category C F-2, Item C5.52 requires both surface and volumetric examinations of Class 2 pressure retaining longitudinal piping welds with equal to or '

l greater than 3/8 inch nominal wall thicknesses for piping greater than 4 inch nominal pipe size as defined by Figure IWC 2500-7. The length of the longitudinal weld examined shall be at least 2.5 times the wall thickness at the intersecting circumferential weld. Item C5.81 requires a 100%

surface examination of the Class 2 branch connection welds L

21

'.g.;w

. t'

. greater than 2 inch nominal pipe size as defined by' Figures -'

IWC 2500 9, -10, -11, -12, and -13.  ;

In addition, in the Seabrook FSAR, the Licensee committed to q

. perform 100% volumetric examination of the seven branch ,

connection welds listed below.

licensee's Code Relief Reauest: Relief is requested from-examining 100% of the Code-required volume (CRV) of the

• following pressure retaining welds in Class 2 piping:

CRV Weld Identification . Examinable t

Circumferential piping weld 1-RH-158-4-2 50%

Longitudinal piping weld l-MS-4002-36-LU-7 99.6%

Relief is also requested from examining 100% of the required

. volume (FSAR augmented volumetric examination commitment) of the following Class 2 pipe branch connection welds:

Required i Volume i Weld ID' Examinable MS-4000-41-4B 70%

MS-4000 41-13B 59%

.MS-4001-41-48 70% 7 MS-4003-37-3B 95%. 1 MS-4001-41-3B 65%  !

MS-4002-37-3B 95% I MS-4001-41-138 70%

Licensee's Prooosed Alternative Examination: None. The Code-required and FSAR-required volumetric examinations will be completed to the maximum extent practical. These welds will receive the full Code-required surface examination.  ;

~

Licensee's Basis for Reauestina Relief: The Licensee reports that geometric configurations and/or permanent obstructions 22

' q (4 o  !

' (

- prohibit 100Y. of the Code-required volumetric examination on  :

t the' subject welds.

1 Evaluation: The volumetric examinations of welds 1-RH-158-4 2 .

and 1-MS 4002 36 LU-7 are impractical to perform to the extent i required by the Code because of surface geometry.

With regard to the branch connection welds, volumetric 'I examination is not required for branch connections of this size  :

under the 83S83. Examination Category C-F, Item C5.30 or the '[

alternative rules of ASME Code Case N-408, Examination.

Category C-F 2, Item C5.81. However, the Seabrook FSAR commits to augmented ISI of main steam and feedwater piping which t consists of 1007. examination of the longitudinal and circumferential welds. These connections on the main steam ,

header are not the normal 6-inch tee fitting but rather a sweep-o-let. Since these fittings represent a large weld area on the main header, a conservative judgement was made during PSI to include these welds under Examination Category C-F-2, Item C5.81 of ASME Code Case N-408.

This request for relief is requesting variance due to geometric configuration, permanent obstructions, and/or structural interferences on 100f. examination for these welds which are >

. being examined under C5.81. Based on these limitations, the L volumetric examination of the pipe branch connection welds is impractical to perfonn to the extent required by Item C5.81 of i ASME Code Case N 408.

, In addition to all of the welds receiving the full l

Code-required surface examination, a significant percentage of the Code-required or FSAR-r6 quired volumetric examination will be performed.

23 l

4 0... -. o -'

Conclusions:

Based on the above, it is concluded that the Code requirement and the FSAR augmented examination requirement are impractical for the subject welds-and that the limited inservice volumetric examinations, along with the Code-required surface examinations, provide reasonable assurance of the continued inservice structural integrity. Therefore, it is recommended that relief be granted as requested. ,

3.2.3 Egmg1 (No relief requests)  !

3.2.4 Valves (No relief requests) 3.2.5 General- (No relief requests) 3.3 C. lass 3 Cgynonents (No relief requests) 3.4 P,, tenure "f est s (No relief requests) 3.5 DE atal (No relief requests) l.

i

.l 1

24

!+o,i e t r: r

4. CONCLUSION Pursuant'to 10 CFR 50.55a(g)(6), it has been determined that certain '

Section XI required ' inservice examinations are impractical to perform. In all cases, the Licensee has demonstrated that specific Section XI ,

requirements are impracti^ cal. '

This technical evaluation has not identified any practical method by which ,

the Licensee can meet all the specific inservice inspection requirements of Section XI of the ASME Code for the existing Seabrook Station, Unit 1, E

-facility. Requiring compliance with al_1 the exact Section XI required  ;

inspections would entail redesign of a significant number of plant systems, '

sufficient replacement components to be obtained, installation of the new components, and a baseline examination of these components. Even after the redesign efforts, complete compliance with the Section XI examination

• requirements probably could not be achieved. Therefore, it is concluded that the peblic interest is not served by imposing certain provisions of Section XI of the ASME Code that have been determined to be impractical.

Pursuant to 10 CFR 50.55a(g)(6), relief is allowed from these requirements which are impractical to implement if granting the relief will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. ,

The development of new or improved examination techniques should continue to

'be monitored. As improvements in these areas are achieved, the Licensee should incorporate these techniques in the 7.51 program plan examination requirements.

Based on the review of the Seabrook Station, Unit 1, First 10-Year Interval Inservice Inspection Program-Plan, Revision 0, the Licensee's response to the NRC's request for additional information, and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Seabrook Station, Unit 1, First 10-Year Interval Inservice Inspection Program Plan, Revision 0, is acceptable and in compliance with 10 CFR 50.55a(g)(4).

25

o ... .

i 4

5. REFERENCES

1. Code of Federal Regulations, Volume 10, Part 50.

2. American Society of Mechanical Engineers Boiler and Pressure Yessel Code,Section XI Division 1: 1983 Edition through Summer 1983 Addenda.

3. American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Code Cases Nuclear Components, 1986 Edition.

l 4. Seabrook Station, Unit 1, First 10 Year Interval Inservice Inspection Program Plan, Revision 0, submitted April 14, 1987.

5. NUREG 0800, Standard Review Plans Section 5.2.4, Reactor Coolant Boundary Inservice Inspection and Testing," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components," July 1981.

6. Letter, dated April 4, 1988 V. Nerses (NRC) to R. J. Harrison (Public Service of New Hampshire (PSNH)), Request for Additional Information on First Ten Year Interval IS! Program - Seabrook Station, Unit 1.

7. Letter, dated June 3, 1988, G. S. Thomas (PSNH) to Document Control Desk (NRC), Response to Request for Additional Information - !$1 Program.

8. NUREG-0896, Supplement No. 5. " Safety Evaluation Report related to the operation of Seabrook Station, Units 1 and 2," July 1986.

O. Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability,  !

l ASME Section XI, Division 1," Revision 5, August 1986. i

10. Regulatory Guide 1.150, tlitrasonic Testir.g cf Reactor Vessel Welds During Preservict 2nd Inservice Examinations," Revision 1, Februcry 1983.

11. Regulatory Guide 1.14. " Reactor Coolant Pump Flywheel Integrity,"

Revision 1, August 1975.

12. IE Bulletin 79-13. " Cracking in Feedwater System Piping," Revision 2, October 17, 1979.

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