ML20248D378

Refers to 971219 Submittal by Gpu Nuclear,Inc Re ISI - Request for Relief Re Semi-Elliptical Circumferential,Rv Nozzle-To-Pipe-Welds. Forwards RAI Re Request for Relief

ML20248D378
Person / Time
Site:	Three Mile Island
Issue date:	06/01/1998
From:	Colburn T NRC (Affiliation Not Assigned)
To:	Langenbach J GENERAL PUBLIC UTILITIES CORP.
References
TAC-MA0437, TAC-MA437, NUDOCS 9806020412
Download: ML20248D378 (13)

Text

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, June 1, 1998 Mr. J:mes W. Lang::nbach, Vice President cnd Director- TMI-1 GPU Nuclear, Inc.

, P.O. Box 480 Middletown, PA 17057 l

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 (TMI-1) - SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF - REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MA0437)

Dear Mr. Langenbach:

By letter dated December 19,1997, GPU Nuclear, Inc. submitted " Inservice inspection - Request for Relief Regarding Semi-Elliptical Circumferential, Reactor Vessel Nozzle-to-Pipe-Welds," to the Nuclear Regulatory Commission. The staff has reviewed your request and has determined that it will need the additional information identified in the enclosure to complete its review. We request that you respond to the enclosed request for additional information within 60 days of the date of this letter anel send a copy of your response directly to our contractor at the following address:

MichaelT. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 if you have any questions, please contact me at (301) 415-1402.

Sincerely, ORIGINAL SIGNED BY Timothy G. Colbum, Senior Project Manager Project Directorate 1-3 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket No. 50-289 Er aosure: Request for,wditionalInformation i

cc w/ encl: See next page g

Distribution: 2  !

Docket File PUBLIC TMcLellan PDI-3 Rdg. J. Zwolinski ACRS T. Clark G. Bagchi C. Hehl, RI T. Colbum OGC NAME: G:\COLBURN\TMA0437.RAI To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attechment/ enclosure "N" = No copy OFFICE PDI-3/LA ne, l6 PDI-3/PM r%,J PD)S/PD C lN NAME TClark O& TColbum (Chdfrras/

DATE 05/h /98 05/2 7 /98 QSd / /98 OFFICIAL RECORD COPY

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T#* 283a! oTo88 P pp 6 NE iiLE C93178 Nw -

l J.Langenbach Three Mile Island Nuclear Station, Unit No.1 cc:

Michael Ross Robert B. Borsum Director, O&M, TMl B&W Nuclear Technologies GPU Nuclear, Inc. Suite 525 P.O. Box 480 1700 Rockville Pike  !

Middletown, PA 17057 Rockville, MD 20852 John C. Fomicola William Domsife, Acting Director Director, Planning and Bureau of Radiation Protection Regulatory Affairs Pennsylvania Department of GPU Nuclear, Inc. Environmental Resources 100 Interpace Parkway P.O. Box 2063 Parsippany, NJ 07054 Hanisburg, PA 17120 Jack S. Wetmore Dr. Judith Johnsrud - j Manager, TMl Regulatory Affairs National Energy Committee 1 GPU Nuclear, Inc. Sierra Club '

P.O. Box 480 433 Orlando Avenue Middletown, PA 17057 State College, PA 16803 I Emest L. Blake, Jr., Esquire Peter W. Eselgroth, Region i Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Commission '

2300 N Street, NW. 475 Allendale Road Washington, DC 20037 King of Prussia, PA 19406 Chairman Board of County Commissioners of Dauphin County Dauphin County Courthouse Harrisburg, PA 17120 Chairman Board of Supervisors of LondonderryTownship R.D. #1, Geyers Church Road Middletown, PA 17057 Wayne L Schmidt Senior Resident inspector (TMi-1)

U.S. Nuclear Regulatory Commission P.O. Box 21g Middletown, PA 17057 Regional Administrator l Region i U.S. Nuclear Regulatory Commission 475 Allendale !;osd King nt Prussia, PA 19406 i

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1 GPU NUCLOAR, INC.

THREE MILE !SLAND NUCLEAR STATION, UNIT 1 DOCKET NUMBER 50-289 civil ENGINEERING AND GEOSCIENCES BRANCH DIVISION OF ENGINEERING l

l I Reauest for Additional Information - Second 10-Year Interval inservice Inspection (ISI) Reauests for Relief

1. Scope / Status of Review l

. Throughout the service life of a water-cooled nuclear power facility,10 CFR 50.55a(g)(4) requires that components (including supports) that 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 design and access provisions and preservice examination 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. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during a 120-month inspection interval 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 start of the 120-month interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Nuclear Regulatory Commission (NRC) approval.

On December 19,1997, the licensee submitted " Inservice inspection - Request for Relief Regarding Semi-Elliptical Circumferential, Reactor Vessel Nozzle-To-Pipe Welds," to the U.S. Nuclear Regulatory Commission. The information provided by the licensee has been reviewed by the NRC staff.

2. AdditionalInformation Reauired in the referenced correspondence, the licensee refers to a previous request for relief, cites an NRC generic Safety Evaluation, and provides information conceming the subject welds.

It appears that this letter is intended to be a request for relief from the requirements of the ASME Section XI Code. Based on the initial review of the licensee's December 19,1997, submittal the staff has concluded that the following information and/or clarification is required to complete the review.

1 GPU Nuclear, Inc. letter no. 6710-97 2098, from James W. Langenbach, Vice President and Director, Three Mile Island (TMa l

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2 A. For each relief request, cite the appropriate paragraph of the regulations to ensure that the request is evaluated in accordance with the appropriate criteria, as discussed below, and verify that the regulatory basis has been adequately supported.

The Regulations provide that a licensee may propose an attemative to CFR or Code l requirements in accordance with 10 CFR 50.55a(a)(3)(i) or 10 CFR 50.55a(s)(3)(ii).

Under 10 CFR 50.55s(a)(3)(i), the proposed altemative must be shown to provide an acceptable level of quality and safety, i.e., essentially, be equivalent to the original requirement in terms of quality and safety. Under 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original requirement would result in hardship or

, unusual difficulty without a compensating increase in the level of quality and safety.

Examples of hardship and/or unusual difficulty include, but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examination, and development of sophisticated tooling that would result in only minimal increases in examination coverage.

A licensee may also submit a request for relief from ASME requirements. In accordance with 10 CFR 50.55a(g)(5)(iii), if a licensee determines that conformance with certain Code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in $50.4, information to support that determination. When a licensee determines that a.1 lnservice inspection requirement is impractical, e.g., the system would have to be redesigned, or a component would have to be replaced to enable inspection, the licenses should cite 10 CFR 50.55a(g)(5)(iii).

The NRC may, giving due consideration to the burden placed on the licensee, impose an attemative examination requirement, B. Cite the Edition and Addenda of the ASME Code being used for the ISI interval affected by the current request.

C. Identify, by number and disposition, the previous relief request submitted with the second 10-year interval ISI program that is affected by the current request. The current relief request must identify the welds that are covered, the applicable ASME Code requirement from which relief is requested, the basis for requesting relief, and the proposed attemative. A typical format and the required content for licensee's requests for relief are given in Appendix A (attached).

The schedule for timely completion of this review requires that the licensee provide, by the requested date, the above requested information and/or clarifications regarding the relief requests affected by this letter.

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Appendix A INSERVICE INSPECTION: GUIDANCE FOR PREPARING l

REQUESTS FOR RELIEF FROM CERTAIN CODE REQUIREMENTS PURSUANT TO 10 CFR 50.55a(g)(5) 1 The guidance in this Appendix is intended to illustrate the type and extent of information that is l

riocessary in a " request for relief" submittal for those items that cannot be fully inspected to the l requirements of ASME Code Section XI. I A. Description of Raquests for Relief The inservice inspection program should contain requests for relief that identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitations of design, geometry, radiation considerations, or materials of construction of the components. Each request for relief should provide the information identified in the following sections of this Appendix for the inspections and pressure tests considered impractical.

B. Request for Relief From Certain inspection and Testing Requirements Many requests for relief from inservice inspection requirements submitted by licensees have not i been supported by adequate descriptive and detailed technicalinformation. This detailed

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information is necessary to: (1) document the impracticality of the ASME Code requirements because of the limitations of design, geometry, and materials of construction of components; and (2) determine whether the use of altematives will provide an acceptable level of quality and safety.

Relief requests submitted with a justification such as " impractical", " inaccessible", or any other categorical basis, require additional information to permit an evaluation of that relief request.

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The objective of the guidance provided in this section is to illustrate the extent of the information required to make a proper evaluation and to adequately document the basis for the granting of relief in the Safety Evaluation Report. Requests for additional information and delays in completing the review can be considerably reduced if this information is provided in the licensee's initial submittal.

Each relief request should contain adequate information to act as a " stand alone" document and should include the following:

1. The ASME Code Class, Examination Category, and item Number (s) or the specific Code paragraph number from which relief is being requested. I

2. ASME Code Section XI examination or test requirements for the weid(s) and/or component (s) for which relief is being requested.

3. The number of items associated with the requested relief.

4. Identification of the specific ASME Code requirement that has been determined to be impractical.

5. An itemized list of the specific welds (s) and/or component (s) for which relief is requested.

6. An estimate of the percentage of the Code-required examination that can be completed for each of the individual welds (s) and/or component (s) requiring relief.

7. Information to support the determination that the requirement is impractical; i.e., state and explain the basis for requesting relief, if the Code-required examination cannot be performed because of a limitation or obstruction, describe or provide drawings showing the specific limitation or obstruction.

8. Identification of the attemative examinations that are proposed: (a) in lieu of the requirements of Section XI; or (b) to supplement partial Section XI examinations performed.

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g. A discussion of the failure consequences of the weld (s) and/or component (s) that would not receive the Code required examination. Discuss any changes expected in the overall level of plant safety by performing the proposed altemative examination in lieu of the examination required by Section XI. If it is not possible to perform attemative examinations, discuss the impact on the overall level of plant quality and safety.

10. State when the proposed altemative examinations will be implemented and performed.

11. State when the request for relief would apply during the inspection period or interval (i.e.,

whether the request is to defer an examination).

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12. State the time period for which the requested re!ief is needed. l Technicaljustification or data must be submitted to support the relief request. Stating without  !

substantiation that a change will not affect the quality level is unsatisfactory (i.e., because a licensee does not agree with a Code requirement is not considered justification for the granting of relief). If the reliefis requested for inaccessibility, a detailed description or drawing that depicts the inaccessibility must accompany the request.

C. Reauest for Relief for Radiation Considerations i Radiation exposures of test personnel to accomplish the examinations prescribed in ASME Code Section XI can be an important factor in determining whether, or under what conditions, an examination must be performed. A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently approved by the NRC staff.

Some of the radiation considerations will only be known at the time of the test. However, from experience at operating facilities, the licensee generally is aware of those areas where relief will be necessary and should submit as a minimum (in addition to the previous general requirements in Section B) the following additional information regarding the request for relief:

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1. The total estimated man-rom exposure involved in the examination.

2. The radiation levels at the test area.

3. Flushing or shielding capabilities that might reduce radiation levels.

4. A discussion of the considerations involved in remote inspections.

5. The results of any previous inservice inspections regarding Al. ARA for the welds for which the reliefis being requested.

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Succested Format For Relief Reauests LICENSEEIUTILITY NAME PLANT NAME, UNIT 10-YEAR INTERVAL REQUEST FOR RELIEF NO.

l. Provide an itemizedlist of the speci6c weld (s) and/or component (s) for which reliefis requested. Include the ASME Code Class, Examination Category, anditem Number (s).

Relief cannot be granted forgeneric Requests for Relief.

NOTE: Each Relief Request should contain only one Examination Category.

EXAMPLE:

SystemIComponentis) for Which Relief is Requested: Six RPV Nonie4o-Pipe Welds Examination Catenorv B-J. Item B9.10 36" Outlet Reactor Nonle (A)4o-Pipe Weld (WELD-1) 36" Outlet Reactor Nonle (B)4o-Pipe Wald (WELD-2) 28" Inlet Reactor Nonle (C)4o-Pipe Weld (WELD-3) 28" Inlet Reactor Nonle (D)-to-Pipe Weld (WELD 4) 28" Inlet Reactor Nonle (E)4o-Pipe Weld (WELD-5) 28" Inlet Reactor Nonle (F)40-Pipe Wold (WELD-6)

II. Report the Code-requirement (s) for the speci6c weld (s) and/or component (s) for which reliefis being requested.

EKAMPLE:

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Code Requirement: Section XI, Table IWB-2500-1, Examination Category B-J, item B9.11 requires an OD surface examination of the weld and adjacent base metal and a volumetric examination of the weld and adjacent base metal (interior one-third

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volume) on all dissimilar metal piping welds and terminal end piping welds at vessels as defined by Figure IWB-2500-8.

ill. Identify the speci6c Section XI examination or test requirements for the weld (s) and/or component (s) for which reliefis being requested.

5XAMPLE Code Reautrement from Which Relief is Requested: Relief is requested from performing the Code-required surface examination on above identified Reactor ,

Pressure Vessel inlet and outlet nozzle-to-pipe welds.

IV. Provide technicaljustification to support the determination that the Code requirements impractical: 1.e., state and explain the basis forrequesting relief. If the Code-required  !

examination cannot be performed because of a limitation or obstruction, describe or provide drawings showing the specific limitation or obstruction. ,

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-If a partial Code-required examination can be performed, provide an estimate of the i percentage of the Code-required examination that can be completed foreach of the

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individual weld (s) and/or component (s) covered by the Request for Relief.

-11 justification for the request for reliefis based on radiation considerations (ALARA), '

address the following:

a. The total estimated man-tem exposure involved in the examination;

b. the radiation levels at the test area;

c. flushing or shielding capabilities that might reduce radiation levels; A-6

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d. proposed attemative inspection techniques;

e. the considerations involved in remote inspections;

f. similarcomponents in redundant systems or similar welds in the same syctems that can be inspected;

g. the results of previous inservice inspections that may help provide technical justification for the granting of relief; and

h. the failure consequences of the component (s) that would not receive the Code required examination (s).

EXAMPLE Basis for Relief: The subject welds are located inside the reactor vessel primary shield wall (see attached Drawing No. NLU RPV-XX.xx) and the Code-required examination would necessitate removal of sand plugs and insulation to gain access into the high radiation environment. NLU (Name Licensee / Utility) estimates the radiation level would be in excess of 10 R/hr at the examination area and that a cumulative exposure of 87 Person Rem would be necessary to complete the Code-required surface examination of these welds.

V. Identify proposed altamative examinations:

(a) in lieu of the requirements of Section XI; or (b) to supplement partial examinations performed per ASME Code Section XI requirements.

NOTE: - Code required examinations are not considered attematives.

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WAMPLE Altemate Examinations: NLU proposes that, in lieu of the Code-required OD surface examination, the subject reactor vessel nozzle to-pipe butt weld OD surfaces will receive an ultrasonic examination from the nozzle bore using the automated reactor vessel tool. This volumetric examination will include the entire weld volume and heat affected zone instead of only the inner one third of tha weld.

VI. Address the following regarding why the Ucensee feels re'ief should be granted:

(a) How the pmposed attematives orpartial examination provide a reasonable assurance of the continued structurelintegrity; (b) the burden upon the Ucensee should the Requs.st for Relief be denied; and (c) why public health and safety will not be }eopardized by the granting of relief.

WAMPLE Justification for the Grantino of Relief: NLU has contracted with NIA (Name 1

Inspection Agency) to perform the attemative volumetric examinations. The remote volumetric examinations will include the entire weld volume a nd the heat affected zone instead of only the inner one-third of the weld as required by the Code. NIA will be utilizing stats of the-art techniques and equipment that has been demonstrated to NLU and the NRC to be capable of detecting OD surface conneccted defects in the circumferential orientation in a labomtory test block. The laboratory test block contained cracks and not machined notches.

The proposed altomative volumetric examination will provide reasonable assurance i that unallowable inservice flaws have not developed in the subject welds or that they l

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acceptable level of quality and safety will have been achieved and public health and safety will not be endangered by allowing the proposed alternative exarnination in lieu of the Code requirement.

Vll. D*scuss the pedod of time for which reliefis required.

NOTE: Requests forrelief are only applicable forthe 10-yearinspection interval dudng which relief was requested and approval does not apply for subsequent inspection intervals.

~ - EXAMPLE Implementation Schedule: Four of the subject examinations will be performed during the first period, and the remaining examinations will be performed during the third period of the 10-year interval.

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