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| number = ML060240085
| number = ML060240085
| issue date = 02/08/2006
| issue date = 02/08/2006
| title = Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 - Relief Request for Underwater Welding of Heated Junction Thermocouple Holders, Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (TAC Nos. MC8572 and MC8573)
| title = Relief Request for Underwater Welding of Heated Junction Thermocouple Holders, Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (TAC Nos. MC8572 and MC8573)
| author name = Laufer R J
| author name = Laufer R
| author affiliation = NRC/NRR/ADRO/DORL
| author affiliation = NRC/NRR/ADRO/DORL
| addressee name = Spina J A
| addressee name = Spina J
| addressee affiliation = Calvert Cliffs Nuclear Power Plant, Inc
| addressee affiliation = Calvert Cliffs Nuclear Power Plant, Inc
| docket = 05000317, 05000318
| docket = 05000317, 05000318
Line 14: Line 14:
| page count = 9
| page count = 9
| project = TAC:MC8572, TAC:MC8573
| project = TAC:MC8572, TAC:MC8573
| stage = Approval
| stage = Other
}}
}}


=Text=
=Text=
{{#Wiki_filter:February 8, 2006Mr. James A. Spina, Vice PresidentCalvert Cliffs Nuclear Power Plant, Inc.
{{#Wiki_filter:February 8, 2006 Mr. James A. Spina, Vice President Calvert Cliffs Nuclear Power Plant, Inc.
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs ParkwayLusby, MD 20657-4702
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702


==SUBJECT:==
==SUBJECT:==
CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - RELIEFREQUEST FOR UNDERWATER WELDING OF HEATED JUNCTION THERMOCOUPLE PROBE HOLDERS (TAC NOS. MC8572 AND MC8573)
CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - RELIEF REQUEST FOR UNDERWATER WELDING OF HEATED JUNCTION THERMOCOUPLE PROBE HOLDERS (TAC NOS. MC8572 AND MC8573)


==Dear Mr. Spina:==
==Dear Mr. Spina:==
By letter dated September 30, 2005 (Agencywide Documents Access and Management System(ADAMS) Accession No. ML052770094), Calvert Cliffs Nuclear Power Plant, Inc. (the licensee)submitted a relief request for authorization to use American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI, Code Case N-516-2, "Underwater Welding, Section XI, Division 1," to relocate two (per Unit) heated junction thermocouple (HJTC) probe holder assemblies to the existing upper guide structure (UGS) at the Calvert Cliffs NuclearPower Plant, Unit Nos. 1 and 2. As stated in the conditions on use of Code Case N-516-2 in Regulatory Guide 1.147, Revision 13, licensees must obtain Nuclear Regulatory Commission(NRC) approval in accordance with Section 50.55a(a)(3) of Part 50 of Title 10 of the Code ofFederal Regulations (10 CFR) regarding the method to be used in the weld repair orreplacement of irradiated material underwater.The NRC staff has reviewed and evaluated the information regarding the relief request. The results are provided in the enclosed safety evaluation.The NRC staff concludes that the use of the proposed ASME Code Case N-516-2 to relocatethe HJTC probe holder assemblies to the UGSs will provide an acceptable level of quality andsafety. Pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the use of the proposed J. Spina- 2 -code case for the subject welds. All other ASME Code, Section XI requirements for which reliefwas not specifically requested and approved in this request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.Sincerely,/RA/Richard J. Laufer, ChiefPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-317 and 50-318
 
By letter dated September 30, 2005 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML052770094), Calvert Cliffs Nuclear Power Plant, Inc. (the licensee) submitted a relief request for authorization to use American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI, Code Case N-516-2, Underwater Welding, Section XI, Division 1, to relocate two (per Unit) heated junction thermocouple (HJTC) probe holder assemblies to the existing upper guide structure (UGS) at the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2. As stated in the conditions on use of Code Case N-516-2 in Regulatory Guide 1.147, Revision 13, licensees must obtain Nuclear Regulatory Commission (NRC) approval in accordance with Section 50.55a(a)(3) of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR) regarding the method to be used in the weld repair or replacement of irradiated material underwater.
The NRC staff has reviewed and evaluated the information regarding the relief request.
The results are provided in the enclosed safety evaluation.
The NRC staff concludes that the use of the proposed ASME Code Case N-516-2 to relocate the HJTC probe holder assemblies to the UGSs will provide an acceptable level of quality and safety. Pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the use of the proposed
 
J. Spina                                     code case for the subject welds. All other ASME Code, Section XI requirements for which relief was not specifically requested and approved in this request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Sincerely,
                                            /RA/
Richard J. Laufer, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318


==Enclosure:==
==Enclosure:==
As statedcc w/encl:  See next page


ML060240085OFFICELPLI-1/PMLPLI-1/LACFEB/BCOGCLPLI-1/BCNAMEPMilanoSLittleKGrussRLaufer DATE01/26/0602/02/0601/20/0602/06/0602/08/06 Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 cc:
As stated cc w/encl: See next page
PresidentCalvert County Board of Commissioners 175 Main Street Prince Frederick, MD  20678Mr. Carey Fleming, EsquireSr. Counsel - Nuclear Generation Constellation Generation Group, LLC 750 East Pratt Street, 17 th floorBaltimore, MD 21202Mr. Louis LarragoiteCalvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs ParkwayLusby, MD  20657-4702Resident InspectorU.S. Nuclear Regulatory Commission


P.O. Box 287 St. Leonard, MD 20685Mr. R. I. McLean, ManagerNuclear Programs Power Plant Research Program Maryland Department of Natural Resources 580 Taylor Avenue (B wing, 3rd floor)
ML060240085 OFFICE LPLI-1/PM          LPLI-1/LA        CFEB/BC          OGC              LPLI-1/BC NAME PMilano              SLittle          KGruss                            RLaufer DATE      01/26/06        02/02/06        01/20/06        02/06/06        02/08/06 Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 cc:
Tawes State Office Building Annapolis, MD 21401Regional Administrator, Region IU.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406Ms. Kristen A. Burger, EsquireMaryland People's Counsel 6 St. Paul Centre Suite 2102 Baltimore, MD 21202-1631Ms. Patricia T. Birnie, EsquireCo-Director Maryland Safe Energy Coalition P.O. Box 33111 Baltimore, MD  21218Mr. Loren F. DonatellNRC Technical Training Center 5700 Brainerd Road Chattanooga, TN  37411-4017 Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING UNDERWATER WELDING OF HEATED JUNCTIONTHERMOCOUPLE PROBE HOLDER WELDSCALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2CALVERT CLIFFS NUCLEAR POWER PLANT, INC.DOCKET NOS. 50-317 AND 50-31
President                                          Ms. Patricia T. Birnie, Esquire Calvert County Board of                            Co-Director Commissioners                                      Maryland Safe Energy Coalition 175 Main Street                                    P.O. Box 33111 Prince Frederick, MD 20678                          Baltimore, MD 21218 Mr. Carey Fleming, Esquire                          Mr. Loren F. Donatell Sr. Counsel - Nuclear Generation                    NRC Technical Training Center Constellation Generation Group, LLC                5700 Brainerd Road 750 East Pratt Street, 17th floor                  Chattanooga, TN 37411-4017 Baltimore, MD 21202 Mr. Louis Larragoite Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. R. I. McLean, Manager Nuclear Programs Power Plant Research Program Maryland Department of Natural Resources 580 Taylor Avenue (B wing, 3rd floor)
Tawes State Office Building Annapolis, MD 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Ms. Kristen A. Burger, Esquire Maryland People's Counsel 6 St. Paul Centre Suite 2102 Baltimore, MD 21202-1631


==81.0 INTRODUCTION==
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING UNDERWATER WELDING OF HEATED JUNCTION THERMOCOUPLE PROBE HOLDER WELDS CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 CALVERT CLIFFS NUCLEAR POWER PLANT, INC.
By letter dated September 30, 2005, Calvert Cliffs Nuclear Power Plant, Inc. (the licensee)submitted a relief request pertaining to the approval, pursuant to the provisions of Section 50.55a(a)(3)(i) of Part 50 of Title10 of the Code of Federal Regulations (10 CFR), to useAmerican Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),
DOCKET NOS. 50-317 AND 50-318
Section XI, Code Case N-516-2, "Underwater Welding," to relocate two (per Unit) heated junction thermocouple (HJTC) probe holder assemblies to the existing upper guide structure (UGS) at the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (CCNPP). ASME CodeCase N-516-2 has been conditionally accepted by the Nuclear Regulatory Commission (NRC)in Regulatory Guide (RG) 1.147, Revision 13. As stated in RG 1.147, the NRC placed acondition that licensees must obtain NRC approval in accordance with 10 CFR 50.55a(a)(3)regarding the technique to be used in the weld repair or replacement of irradiated material underwater. The components listed above have been irradiated as a result of their location in the reactor vessel and meet the definition of an irradiated component. Therefore, the licenseemust obtain the approval to use the above code case, and the September 30, 2005, letterincludes this request.


==2.0REGULATORY EVALUATION==
==1.0      INTRODUCTION==
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (includingsupports) must meet the requirements set forth in the ASME Code, Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. Paragraph IWA-4221(b) of ASME Code, Section XI requires that an item for repair/replacement activities shall meet the original Construction Code. Paragraph  IWA-4221(c) of ASME Code, Section XI allows licensees to use, as an alternative, later editions and addenda of the Construction Code or of ASME Code, Section III, either in their entirety or portions thereof, and code cases. The current CCNPP Code of Record, ASME Code, Section XI, 1998 Edition, no Addenda, doesnot allow underwater welding of irradiated components. Therefore, the licensee is requesting permission to use ASME Code Case N-516-2. As required by RG 1.147, Revision 13, the licensee is requesting NRC approval of the technique (i.e., shielded metal arc welding process)to be used in the weld repair or replacement of irradiated material underwater.


==3.0TECHNICAL EVALUATION==
By letter dated September 30, 2005, Calvert Cliffs Nuclear Power Plant, Inc. (the licensee) submitted a relief request pertaining to the approval, pursuant to the provisions of Section 50.55a(a)(3)(i) of Part 50 of Title10 of the Code of Federal Regulations (10 CFR), to use American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),
Section XI, Code Case N-516-2, "Underwater Welding," to relocate two (per Unit) heated junction thermocouple (HJTC) probe holder assemblies to the existing upper guide structure (UGS) at the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (CCNPP). ASME Code Case N-516-2 has been conditionally accepted by the Nuclear Regulatory Commission (NRC) in Regulatory Guide (RG) 1.147, Revision 13. As stated in RG 1.147, the NRC placed a condition that licensees must obtain NRC approval in accordance with 10 CFR 50.55a(a)(3) regarding the technique to be used in the weld repair or replacement of irradiated material underwater. The components listed above have been irradiated as a result of their location in the reactor vessel and meet the definition of an irradiated component. Therefore, the licensee must obtain the approval to use the above code case, and the September 30, 2005, letter includes this request.


===3.1 Components===
==2.0      REGULATORY EVALUATION==
for which Relief is Requested
 
Relief is requested, as required in RG 1.147, Revision 13, to allow the use of Code Case N-516-2 for underwater welding on the CCNPP Unit Nos. 1 and 2 UGSs at locations where theHJTC probe holder will be installed. These components have been irradiated as a result oftheir location in the reactor vessel and can be considered to be an irradiated component. The CCNPP UGSs were formed from austenitic stainless steel. The HJTC probe holder brackets are ASME Code, Section II, Material Classification SA-479 Type 304 austenitic stainless steel.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements set forth in the ASME Code, Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. Paragraph IWA-4221(b) of ASME Code, Section XI requires that an item for repair/replacement activities shall meet the original Construction Code. Paragraph IWA-4221(c) of ASME Code, Section XI allows licensees to use, as an alternative, later editions and addenda of the Construction Code or of ASME Code, Section III, either in their entirety or portions thereof, and code cases.
Enclosure
 
The current CCNPP Code of Record, ASME Code, Section XI, 1998 Edition, no Addenda, does not allow underwater welding of irradiated components. Therefore, the licensee is requesting permission to use ASME Code Case N-516-2. As required by RG 1.147, Revision 13, the licensee is requesting NRC approval of the technique (i.e., shielded metal arc welding process) to be used in the weld repair or replacement of irradiated material underwater.
 
==3.0    TECHNICAL EVALUATION==
 
3.1    Components for which Relief is Requested:
Relief is requested, as required in RG 1.147, Revision 13, to allow the use of Code Case N-516-2 for underwater welding on the CCNPP Unit Nos. 1 and 2 UGSs at locations where the HJTC probe holder will be installed. These components have been irradiated as a result of their location in the reactor vessel and can be considered to be an irradiated component. The CCNPP UGSs were formed from austenitic stainless steel. The HJTC probe holder brackets are ASME Code, Section II, Material Classification SA-479 Type 304 austenitic stainless steel.
The funnels are SA-479 austenitic stainless steel or SA-240 Type 304 austenitic stainless steel.
The funnels are SA-479 austenitic stainless steel or SA-240 Type 304 austenitic stainless steel.
The filler metal is austenitic stainless steel meeting the requirements of ASME, Section IIC,"Specification for Stainless Steel Electrodes for Shielded Metal Arc Welding," SFA 5.4. The production filler metal will meet all the applicable filler metal certification requirements ofparagraph 4.0 of Code Case N-516-2, with the results of the chemical, ferrite, and tensile tests provided to the NRC, if desired. The minimum ferrite number for the production filler metal isFN 5.Code Requirements for which Relief is Requested
The filler metal is austenitic stainless steel meeting the requirements of ASME, Section IIC, Specification for Stainless Steel Electrodes for Shielded Metal Arc Welding, SFA 5.4. The production filler metal will meet all the applicable filler metal certification requirements of paragraph 4.0 of Code Case N-516-2, with the results of the chemical, ferrite, and tensile tests provided to the NRC, if desired. The minimum ferrite number for the production filler metal is FN 5.
:The current Code of Record, ASME Code, Section XI, 1998 Edition, no Addenda, does notallow underwater welding of irradiated components. Therefore, permission must be requested to use Code Case N-516-2. As required by RG 1.147, Revision 13, the licencee is requesting
Code Requirements for which Relief is Requested:
The current Code of Record, ASME Code, Section XI, 1998 Edition, no Addenda, does not allow underwater welding of irradiated components. Therefore, permission must be requested to use Code Case N-516-2. As required by RG 1.147, Revision 13, the licencee is requesting NRC approval of the technique (i.e., shielded metal arc welding process) to be used in the weld repair or replacement of irradiated material underwater.
Proposed Alternative:
The NRC documented its conditional acceptance of Code Case N-516-2 in RG 1.147, Revision 13, dated January 2004. The specific condition noted in RG 1.147, Revision 13, requires licensees to obtain NRC approval in accordance with 10 CFR 50.55a(a)(3) regarding the technique to be used in the weld repair or replacement of irradiated material underwater.
The licensee requested NRC approval of ASME Code, Section XI, Code Case N-516-2 for use at CCNPP on the basis that it provides an acceptable level of quality and safety.
The licensee requested approval for the use of Code Case N-516-2 in order to relocate two (per Unit) HJTC probe holder assemblies to the UGSs. The specific application request is for wet underwater welding.
 
Licensees Basis for Relief:
The proposed welds will be performed using a weld procedure specification qualified in accordance with Code Case N-516-2 and the welds will be visually examined. The licensees weld procedure specification has been qualified with tensile and bend tests in accordance with ASME Code, Section IX, and the additional requirements of Code Case N-516-2. The filler material will be qualified using chemical, ferrite, and tensile tests performed in accordance with Code Case N-516-2. To support the new probe holder, intermittent fillet welds will be made underwater with the shielded metal arc welding (SMAW) process joining new funnels and support brackets for the probe holders (two per Unit) to the existing UGSs. Mockup testing for welders will be used. The mockup testing will be performed using similar materials and conditions as the production welds. These welds will be subjected to the same inspection requirements as the production welds. The subject fillet welds will only be used to relocate the HJTC probe holders to the UGSs. They will not become structural welds performing a core support structure function, nor will they become pressure boundary welds. The mockup tests and inspections on the welds are licensee requirements that will ensure the performance of the welds is conservative with respect to their safety function. If required, the control element assembly shrouds and UGS plate will be prepared for welding by removal of the non-tightly adherent oxide layer.
Welding will be performed after 23 effective full-power years of operation, corresponding to a calculated thermal neutron fluence of less than 5 x 1016 neutrons per square centimeter (5E16 n/cm2) at 42 inches above the fuel alignment plate (FAP). The water depth of the lowest weld, which is located at 42 inches above the FAP, will be approximately 25 feet. The qualification depth rules of Code Case N-516-2 will be met. The mockup tests and inspections on the welds, combined with the alternative requirements of Code Case N-516-2, provide an acceptable level of quality and safety for underwater welding. Non-destructive examination will be performed by visual examination only, per Code Case N-516-2, by a certified examiner.
Ongoing examinations of the welds will fall under the normal In-service Inspection intervals, per ASME Code, Section XI.
This relief request will be implemented during the next refueling outages for each unit and will remain in place for the life of the plant.
3.3    Staff Evaluation ASME Code Case N-516-2 has been conditionally accepted by the NRC in RG 1.147, Revision 13. As stated in RG 1.147, the NRC staff placed a condition that [l]icensees must obtain NRC approval in accordance with 10 CFR 50.55a(a)(3) regarding the technique to be used in the weld repair or replacement of irradiated material underwater. The components listed above have been irradiated to a calculated thermal neutron fluence of less than 5E16 n/cm2, as a result of their location in the reactor vessel and can be considered to be an irradiated component. Therefore, the licensee must obtain NRC approval to use the above code case.
Welded repairs in stainless steel components that are located in high thermal neutron fluence regions in the reactor pressure vessel have been complicated by cracking and the resultant decrease in mechanical properties in the welded joint. This material degradation is caused by transmutation of various elements contained in the materials to be welded, such as boron and
 
nickel, and the formation of helium. Helium tends to have a low solubility in metals and forms small clusters with diameters on the order of a few tenths of a nanometer. These clusters form at preferred nucleation sites which are lattice inhomogeneities such as radiation-induced defects, precipitate interfaces, dislocations and most importantly, grain boundaries. At elevated temperatures, these clusters and bubbles can grow very rapidly and under applied stress can severely weaken grain boundaries. Because conventional, deep penetration, fusion welding processes produce high stress (above yield strength) as well as high temperatures (above the melting point), entrapped helium can severely affect the weldability and postweld properties of irradiated materials. The severity of the observed effects is dominated by the helium content and the extent and magnitude of the temperature and stress fields that prevail near the fusion line during welding. However, welded repairs of components can be performed using various welding techniques which minimize the extent and magnitude of the temperature and stress fields. These techniques for welding stainless steel components located in high thermal neutron fluence regions are available from various sources; however, the techniques are held as proprietary.
Although industrys research on the phenomenon of the cracking of weld repairs in highly irradiated material due to helium formation is ongoing and much of the data is proprietary, there are certain threshold values below which this phenomenon does not occur. The licensees calculated maximum thermal neutron fluence of 5E16 n/cm2 for these components is well below these values. Therefore, it is unlikely that cracking and the resultant decrease in mechanical properties will occur in the welded joint of the HJTC probe holder assembly to the UGSs. As an added safety margin, the weld procedure specification has been qualified with tensile and bend tests in accordance with ASME Code, Section IX, and the additional requirements of ASME Code Case N-516-2. The filler material will be qualified with chemical, ferrite, and tensile tests performed in accordance with Code Case N-516-2. Also, mockup testing for welders will be used. The mockup testing will be performed using similar materials and conditions as the production welds. The proposed welds will be subjected to the same inspection requirements as the production welds. The welds described above assist in the relocation of the HJTC probe holder assemblies and provide support to the HJTC probe holder assemblies, which will be positioned against the existing UGSs. The proposed welds will only be used to join a guide for inserting the HJTC probes into the probe holder to the UGSs. The welds do not perform an ASME core support structure function and are not ASME pressure boundary welds.
Non-destructive examination will be performed by visual examination, per Code Case N-516-2, by a certified examiner.
The requirements imposed on the welds are conservative with respect to the safety function of the welds. The qualification depth rules of Code Case N-516-2 for performing the test welds underwater will be met. The conditions stated above relative to the thermal neutron fluence, combined with the licensees proposed testing and examination requirements of the ASME Code, Section IX, and Code Case N-516-2, provide an acceptable level of quality and safety for underwater welding of the subject components.
 
==4.0    CONCLUSION==


NRC approval of the technique (i.e., shielded metal arc welding process) to be used in the weldrepair or replacement of irradiated material underwater.Proposed Alternative:The NRC documented its conditional acceptance of Code Case N-516-2 in RG 1.147,Revision 13, dated January 2004. The specific condition noted in RG 1.147, Revision 13, requires licensees to obtain NRC approval in accordance with 10 CFR 50.55a(a)(3) regardingthe technique to be used in the weld repair or replacement of irradiated material underwater.
The NRC staff has reviewed the licensees relief request and determined that the use of the proposed ASME Code Case N-516-2 to relocate two (per Unit) HJTC probe holder assemblies to the UGSs will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the use of the proposed code case for the
The licensee requested NRC approval of ASME Code, Section XI, Code Case N-516-2 for useat CCNPP on the basis that it provides an acceptable level of quality and safety.The licensee requested approval for the use of Code Case N-516-2 in order to relocate two (perUnit) HJTC probe holder assemblies to the UGSs. The specific application request is for wet underwater welding. Licensee's Basis for Relief
: The proposed welds will be performed using a weld procedure specification qualified inaccordance with Code Case N-516-2 and the welds will be visually examined. The licensee'sweld procedure specification has been qualified with tensile and bend tests in accordance with ASME Code, Section IX, and the additional requirements of Code Case N-516-2. The fillermaterial will be qualified using chemical, ferrite, and tensile tests performed in accordance withCode Case N-516-2. To support the new probe holder, intermittent fillet welds will be madeunderwater with the shielded metal arc welding (SMAW) process joining new funnels and support brackets for the probe holders (two per Unit) to the existing UGSs. Mockup testing for welders will be used. The mockup testing will be performed using similar materials and conditions as the production welds. These welds will be subjected to the same inspectionrequirements as the production welds. The subject fillet welds will only be used to relocate theHJTC probe holders to the UGSs. They will not become structural welds performing a coresupport structure function, nor will they become pressure boundary welds. The mockup testsand inspections on the welds are licensee requirements that will ensure the performance of thewelds is conservative with respect to their safety function. If required, the control element assembly shrouds and UGS plate will be prepared for welding by removal of the non-tightlyadherent oxide layer.Welding will be performed after 23 effective full-power years of operation, corresponding to acalculated thermal neutron fluence of less than 5 x 10 16 neutrons per square centimeter(5E16 n/cm
: 2) at 42 inches above the fuel alignment plate (FAP). The water depth of the lowestweld, which is located at 42 inches above the FAP, will be approximately 25 feet. Thequalification depth rules of Code Case N-516-2 will be met. The mockup tests and inspectionson the welds, combined with the alternative requirements of Code Case N-516-2, provide an acceptable level of quality and safety for underwater welding. Non-destructive examination willbe performed by visual examination only, per Code Case N-516-2, by a certified examiner.
Ongoing examinations of the welds will fall under the normal In-service Inspection intervals, perASME Code, Section XI.This relief request will be implemented during the next refueling outages for each unit and willremain in place for the life of the plant.3.3Staff EvaluationASME Code Case N-516-2 has been conditionally accepted by the NRC in RG 1.
147,Revision 13. As stated in RG 1.147, the NRC staff placed a condition that "[l]icensees mustobtain NRC approval in accordance with 10 CFR 50.55a(a)(3) regarding the technique to beused in the weld repair or replacement of irradiated material underwater."  The components listed above have been irradiated to a calculated thermal neutron fluence of less than5E16 n/cm 2, as a result of their location in the reactor vessel and can be considered to be anirradiated component. Therefore, the licensee must obtain NRC approval to use the abovecode case. Welded repairs in stainless steel components that are located in high thermal neutron fluenceregions in the reactor pressure vessel have been complicated by cracking and the resultant decrease in mechanical properties in the welded joint. This material degradation is caused by transmutation of various elements contained in the materials to be welded, such as boron and  nickel, and the formation of helium. Helium tends to have a low solubility in metals and formssmall clusters with diameters on the order of a few tenths of a nanometer. These clusters form at preferred nucleation sites which are lattice inhomogeneities such as radiation-induced defects, precipitate interfaces, dislocations and most importantly, grain boundaries. At elevated temperatures, these clusters and bubbles can grow very rapidly and under applied stress can severely weaken grain boundaries. Because conventional, deep penetration, fusion welding processes produce high stress (above yield strength) as well as high temperatures (above the melting point), entrapped helium can severely affect the weldability and postweld properties ofirradiated materials. The severity of the observed effects is dominated by the helium content and the extent and magnitude of the temperature and stress fields that prevail near the fusionline during welding. However, welded repairs of components can be performed using various welding techniques which minimize the extent and magnitude of the temperature and stressfields. These techniques for welding stainless steel components located in high thermal neutron fluence regions are available from various sources; however, the techniques are held as proprietary.Although industry's research on the phenomenon of the cracking of weld repairs in highlyirradiated material due to helium formation is ongoing and much of the data is proprietary, there are certain threshold values below which this phenomenon does not occur. The licensee's calculated maximum thermal neutron fluence of 5E16 n/cm 2 for these components is well belowthese values. Therefore, it is unlikely that cracking and the resultant decrease in mechanical properties will occur in the welded joint of the HJTC probe holder assembly to the UGSs. As anadded safety margin, the weld procedure specification has been qualified with tensile and bend tests in accordance with ASME Code, Section IX, and the additional requirements of ASME Code Case N-516-2. The filler material will be qualified with chemical, ferrite, and tensile testsperformed in accordance with Code Case N-516-2. Also, mockup testing for welders will beused. The mockup testing will be performed using similar materials and conditions as theproduction welds. The proposed welds will be subjected to the same inspection requirementsas the production welds. The welds described above assist in the relocation of the HJTC probe holder assemblies and provide support to the HJTC probe holder assemblies, which will bepositioned against the existing UGSs. The proposed welds will only be used to join a guide forinserting the HJTC probes into the probe holder to the UGSs. The welds do not perform an ASME core support structure function and are not ASME pressure boundary welds.
Non-destructive examination will be performed by visual examination, per Code Case N-516-2,by a certified examiner. The requirements imposed on the welds are conservative with respect to the safety function ofthe welds. The qualification depth rules of Code Case N-516-2 for performing the test welds underwater will be met. The conditions stated above relative to the thermal neutron fluence,combined with the licensee's proposed testing and examination requirements of the ASME Code, Section IX, and Code Case N-516-2, provide an acceptable level of quality and safety for underwater welding of the subject components.


==4.0CONCLUSION==
subject welds at CCNPP for the remainder of the third 10-year inservice inspection interval. All other ASME Code, Section XI requirements for which relief was not specifically requested and approved in this request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
The NRC staff has reviewed the licensee's relief request and determined that the use of theproposed ASME Code Case N-516-2 to relocate two (per Unit) HJTC probe holder assemblies to the UGSs will provide an acceptable level of quality and safety. Therefore, pursuant to10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the use of the proposed code case for the  subject welds at CCNPP for the remainder of the third 10-year inservice inspection interval. Allother ASME Code, Section XI requirements for which relief was not specifically requested and approved in this request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.Principal Contributor: E. Andruszkiewicz Date: February 8, 2006}}
Principal Contributor: E. Andruszkiewicz Date: February 8, 2006}}

Latest revision as of 10:46, 14 March 2020

Relief Request for Underwater Welding of Heated Junction Thermocouple Holders, Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (TAC Nos. MC8572 and MC8573)
ML060240085
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 02/08/2006
From: Richard Laufer
Plant Licensing Branch III-2
To: Spina J
Calvert Cliffs
Milano P, NRR/DLPM 415-1457
References
TAC MC8572, TAC MC8573
Download: ML060240085 (9)


Text

February 8, 2006 Mr. James A. Spina, Vice President Calvert Cliffs Nuclear Power Plant, Inc.

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - RELIEF REQUEST FOR UNDERWATER WELDING OF HEATED JUNCTION THERMOCOUPLE PROBE HOLDERS (TAC NOS. MC8572 AND MC8573)

Dear Mr. Spina:

By letter dated September 30, 2005 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML052770094), Calvert Cliffs Nuclear Power Plant, Inc. (the licensee) submitted a relief request for authorization to use American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Code Case N-516-2, Underwater Welding,Section XI, Division 1, to relocate two (per Unit) heated junction thermocouple (HJTC) probe holder assemblies to the existing upper guide structure (UGS) at the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2. As stated in the conditions on use of Code Case N-516-2 in Regulatory Guide 1.147, Revision 13, licensees must obtain Nuclear Regulatory Commission (NRC) approval in accordance with Section 50.55a(a)(3) of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR) regarding the method to be used in the weld repair or replacement of irradiated material underwater.

The NRC staff has reviewed and evaluated the information regarding the relief request.

The results are provided in the enclosed safety evaluation.

The NRC staff concludes that the use of the proposed ASME Code Case N-516-2 to relocate the HJTC probe holder assemblies to the UGSs will provide an acceptable level of quality and safety. Pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the use of the proposed

J. Spina code case for the subject welds. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

Sincerely,

/RA/

Richard J. Laufer, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

As stated cc w/encl: See next page

ML060240085 OFFICE LPLI-1/PM LPLI-1/LA CFEB/BC OGC LPLI-1/BC NAME PMilano SLittle KGruss RLaufer DATE 01/26/06 02/02/06 01/20/06 02/06/06 02/08/06 Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 cc:

President Ms. Patricia T. Birnie, Esquire Calvert County Board of Co-Director Commissioners Maryland Safe Energy Coalition 175 Main Street P.O. Box 33111 Prince Frederick, MD 20678 Baltimore, MD 21218 Mr. Carey Fleming, Esquire Mr. Loren F. Donatell Sr. Counsel - Nuclear Generation NRC Technical Training Center Constellation Generation Group, LLC 5700 Brainerd Road 750 East Pratt Street, 17th floor Chattanooga, TN 37411-4017 Baltimore, MD 21202 Mr. Louis Larragoite Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. R. I. McLean, Manager Nuclear Programs Power Plant Research Program Maryland Department of Natural Resources 580 Taylor Avenue (B wing, 3rd floor)

Tawes State Office Building Annapolis, MD 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Ms. Kristen A. Burger, Esquire Maryland People's Counsel 6 St. Paul Centre Suite 2102 Baltimore, MD 21202-1631

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING UNDERWATER WELDING OF HEATED JUNCTION THERMOCOUPLE PROBE HOLDER WELDS CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 CALVERT CLIFFS NUCLEAR POWER PLANT, INC.

DOCKET NOS. 50-317 AND 50-318

1.0 INTRODUCTION

By letter dated September 30, 2005, Calvert Cliffs Nuclear Power Plant, Inc. (the licensee) submitted a relief request pertaining to the approval, pursuant to the provisions of Section 50.55a(a)(3)(i) of Part 50 of Title10 of the Code of Federal Regulations (10 CFR), to use American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),

Section XI, Code Case N-516-2, "Underwater Welding," to relocate two (per Unit) heated junction thermocouple (HJTC) probe holder assemblies to the existing upper guide structure (UGS) at the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (CCNPP). ASME Code Case N-516-2 has been conditionally accepted by the Nuclear Regulatory Commission (NRC) in Regulatory Guide (RG) 1.147, Revision 13. As stated in RG 1.147, the NRC placed a condition that licensees must obtain NRC approval in accordance with 10 CFR 50.55a(a)(3) regarding the technique to be used in the weld repair or replacement of irradiated material underwater. The components listed above have been irradiated as a result of their location in the reactor vessel and meet the definition of an irradiated component. Therefore, the licensee must obtain the approval to use the above code case, and the September 30, 2005, letter includes this request.

2.0 REGULATORY EVALUATION

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements set forth in the ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. Paragraph IWA-4221(b) of ASME Code,Section XI requires that an item for repair/replacement activities shall meet the original Construction Code. Paragraph IWA-4221(c) of ASME Code,Section XI allows licensees to use, as an alternative, later editions and addenda of the Construction Code or of ASME Code,Section III, either in their entirety or portions thereof, and code cases.

Enclosure

The current CCNPP Code of Record, ASME Code,Section XI, 1998 Edition, no Addenda, does not allow underwater welding of irradiated components. Therefore, the licensee is requesting permission to use ASME Code Case N-516-2. As required by RG 1.147, Revision 13, the licensee is requesting NRC approval of the technique (i.e., shielded metal arc welding process) to be used in the weld repair or replacement of irradiated material underwater.

3.0 TECHNICAL EVALUATION

3.1 Components for which Relief is Requested:

Relief is requested, as required in RG 1.147, Revision 13, to allow the use of Code Case N-516-2 for underwater welding on the CCNPP Unit Nos. 1 and 2 UGSs at locations where the HJTC probe holder will be installed. These components have been irradiated as a result of their location in the reactor vessel and can be considered to be an irradiated component. The CCNPP UGSs were formed from austenitic stainless steel. The HJTC probe holder brackets are ASME Code,Section II, Material Classification SA-479 Type 304 austenitic stainless steel.

The funnels are SA-479 austenitic stainless steel or SA-240 Type 304 austenitic stainless steel.

The filler metal is austenitic stainless steel meeting the requirements of ASME, Section IIC, Specification for Stainless Steel Electrodes for Shielded Metal Arc Welding, SFA 5.4. The production filler metal will meet all the applicable filler metal certification requirements of paragraph 4.0 of Code Case N-516-2, with the results of the chemical, ferrite, and tensile tests provided to the NRC, if desired. The minimum ferrite number for the production filler metal is FN 5.

Code Requirements for which Relief is Requested:

The current Code of Record, ASME Code,Section XI, 1998 Edition, no Addenda, does not allow underwater welding of irradiated components. Therefore, permission must be requested to use Code Case N-516-2. As required by RG 1.147, Revision 13, the licencee is requesting NRC approval of the technique (i.e., shielded metal arc welding process) to be used in the weld repair or replacement of irradiated material underwater.

Proposed Alternative:

The NRC documented its conditional acceptance of Code Case N-516-2 in RG 1.147, Revision 13, dated January 2004. The specific condition noted in RG 1.147, Revision 13, requires licensees to obtain NRC approval in accordance with 10 CFR 50.55a(a)(3) regarding the technique to be used in the weld repair or replacement of irradiated material underwater.

The licensee requested NRC approval of ASME Code,Section XI, Code Case N-516-2 for use at CCNPP on the basis that it provides an acceptable level of quality and safety.

The licensee requested approval for the use of Code Case N-516-2 in order to relocate two (per Unit) HJTC probe holder assemblies to the UGSs. The specific application request is for wet underwater welding.

Licensees Basis for Relief:

The proposed welds will be performed using a weld procedure specification qualified in accordance with Code Case N-516-2 and the welds will be visually examined. The licensees weld procedure specification has been qualified with tensile and bend tests in accordance with ASME Code,Section IX, and the additional requirements of Code Case N-516-2. The filler material will be qualified using chemical, ferrite, and tensile tests performed in accordance with Code Case N-516-2. To support the new probe holder, intermittent fillet welds will be made underwater with the shielded metal arc welding (SMAW) process joining new funnels and support brackets for the probe holders (two per Unit) to the existing UGSs. Mockup testing for welders will be used. The mockup testing will be performed using similar materials and conditions as the production welds. These welds will be subjected to the same inspection requirements as the production welds. The subject fillet welds will only be used to relocate the HJTC probe holders to the UGSs. They will not become structural welds performing a core support structure function, nor will they become pressure boundary welds. The mockup tests and inspections on the welds are licensee requirements that will ensure the performance of the welds is conservative with respect to their safety function. If required, the control element assembly shrouds and UGS plate will be prepared for welding by removal of the non-tightly adherent oxide layer.

Welding will be performed after 23 effective full-power years of operation, corresponding to a calculated thermal neutron fluence of less than 5 x 1016 neutrons per square centimeter (5E16 n/cm2) at 42 inches above the fuel alignment plate (FAP). The water depth of the lowest weld, which is located at 42 inches above the FAP, will be approximately 25 feet. The qualification depth rules of Code Case N-516-2 will be met. The mockup tests and inspections on the welds, combined with the alternative requirements of Code Case N-516-2, provide an acceptable level of quality and safety for underwater welding. Non-destructive examination will be performed by visual examination only, per Code Case N-516-2, by a certified examiner.

Ongoing examinations of the welds will fall under the normal In-service Inspection intervals, per ASME Code,Section XI.

This relief request will be implemented during the next refueling outages for each unit and will remain in place for the life of the plant.

3.3 Staff Evaluation ASME Code Case N-516-2 has been conditionally accepted by the NRC in RG 1.147, Revision 13. As stated in RG 1.147, the NRC staff placed a condition that [l]icensees must obtain NRC approval in accordance with 10 CFR 50.55a(a)(3) regarding the technique to be used in the weld repair or replacement of irradiated material underwater. The components listed above have been irradiated to a calculated thermal neutron fluence of less than 5E16 n/cm2, as a result of their location in the reactor vessel and can be considered to be an irradiated component. Therefore, the licensee must obtain NRC approval to use the above code case.

Welded repairs in stainless steel components that are located in high thermal neutron fluence regions in the reactor pressure vessel have been complicated by cracking and the resultant decrease in mechanical properties in the welded joint. This material degradation is caused by transmutation of various elements contained in the materials to be welded, such as boron and

nickel, and the formation of helium. Helium tends to have a low solubility in metals and forms small clusters with diameters on the order of a few tenths of a nanometer. These clusters form at preferred nucleation sites which are lattice inhomogeneities such as radiation-induced defects, precipitate interfaces, dislocations and most importantly, grain boundaries. At elevated temperatures, these clusters and bubbles can grow very rapidly and under applied stress can severely weaken grain boundaries. Because conventional, deep penetration, fusion welding processes produce high stress (above yield strength) as well as high temperatures (above the melting point), entrapped helium can severely affect the weldability and postweld properties of irradiated materials. The severity of the observed effects is dominated by the helium content and the extent and magnitude of the temperature and stress fields that prevail near the fusion line during welding. However, welded repairs of components can be performed using various welding techniques which minimize the extent and magnitude of the temperature and stress fields. These techniques for welding stainless steel components located in high thermal neutron fluence regions are available from various sources; however, the techniques are held as proprietary.

Although industrys research on the phenomenon of the cracking of weld repairs in highly irradiated material due to helium formation is ongoing and much of the data is proprietary, there are certain threshold values below which this phenomenon does not occur. The licensees calculated maximum thermal neutron fluence of 5E16 n/cm2 for these components is well below these values. Therefore, it is unlikely that cracking and the resultant decrease in mechanical properties will occur in the welded joint of the HJTC probe holder assembly to the UGSs. As an added safety margin, the weld procedure specification has been qualified with tensile and bend tests in accordance with ASME Code,Section IX, and the additional requirements of ASME Code Case N-516-2. The filler material will be qualified with chemical, ferrite, and tensile tests performed in accordance with Code Case N-516-2. Also, mockup testing for welders will be used. The mockup testing will be performed using similar materials and conditions as the production welds. The proposed welds will be subjected to the same inspection requirements as the production welds. The welds described above assist in the relocation of the HJTC probe holder assemblies and provide support to the HJTC probe holder assemblies, which will be positioned against the existing UGSs. The proposed welds will only be used to join a guide for inserting the HJTC probes into the probe holder to the UGSs. The welds do not perform an ASME core support structure function and are not ASME pressure boundary welds.

Non-destructive examination will be performed by visual examination, per Code Case N-516-2, by a certified examiner.

The requirements imposed on the welds are conservative with respect to the safety function of the welds. The qualification depth rules of Code Case N-516-2 for performing the test welds underwater will be met. The conditions stated above relative to the thermal neutron fluence, combined with the licensees proposed testing and examination requirements of the ASME Code,Section IX, and Code Case N-516-2, provide an acceptable level of quality and safety for underwater welding of the subject components.

4.0 CONCLUSION

The NRC staff has reviewed the licensees relief request and determined that the use of the proposed ASME Code Case N-516-2 to relocate two (per Unit) HJTC probe holder assemblies to the UGSs will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the use of the proposed code case for the

subject welds at CCNPP for the remainder of the third 10-year inservice inspection interval. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: E. Andruszkiewicz Date: February 8, 2006