ML20136H116

SER Supporting Request for Relief from Certain ASME Code Inservice Insp Requirements.Relief Granted & Alternate Methods Imposed Give Assurance of Piping & Component Pressure Boundary & Support Structural Integrity

ML20136H116
Person / Time
Site:	Hatch
Issue date:	11/07/1985
From:	NRC
To:
Shared Package
ML20136H113	List: ML20136H108 ML20136H116
References
TAC-59304, NUDOCS 8511250036
Download: ML20136H116 (39)

Text

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/ 'o,, UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION 8 ,E WASHINGTON, D. C. 20555

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SAFETY EVALUATION REPORT RELATED TO REQUESTS FOR RELIEF FROM INSERVICE INSPECTION REQUIREMENTS GEORGIA POWER COMPANY HATCH NUCLEAR PLANT UNIT 1 DOCKET NO. 50-321 Introduction Technical Specification 3.6.K for the Hatch Nuclear Power Plant Unit I requires cn inservice inspection program which essentially conforms to the requirements of 10 CFR 50.55a(g). The present inservice inspection program -

for the first ten-year interval conforms to the requirements of the 1974 Editio'n of the ASME Section XI Code with Addenda through Summer 1975. By letter dated July 18, 1985, Georgia Power Company (GPC) stated their intention to complete the examinations for the Hatch Unit 1 first ten-year inspection interval, which will be concluded on December 31, 1985, basing the examinations on a program written to the 1980 Edition of the ASME Code Section XI with Addenda through Winter 1980. The rationale'for the Hatch Unit 1 end-of-the-interval update is to have both Hatch units examined to the same Code Edition.

• In order to complete the first ten-year inspection interval at Hatch Unit 1, with the updated program, relief from certain Code inservice inspection requirements is required. 10 CFR 50.55a(g)(6)(1) authorizes the Commission to grant relief from those requirements upon making the necessary findings m

that the requirements are impractical to perfonn.

Evaluation The requests for relief from certain requirements of Section XI which have been determined by the licensee to be impractical to perfonn are reviewed as follows:

Volumetric Examination of Reactor Pressure Vessel and Closure Head Welds 0511250036 851107 PDR ADOCK 0500 1

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Code Requirements and Code Relief Rtquest Item Nos. Bl.11, Bl.12, Bl.21, and B1.22 of Table IWB-2500-1 for the 1980 Edition of ASME Section XI require the volumetric examination of Reactor Pressure Vessel (RPV) and Closure Head circumferential, longitudinal, and meridional welds. At Hatch, these examinations will be performed using ultrasonic techniques. The applicable examination voTures are shown in

, figures IWB-2500-1, -2, and -3. The Code also requires that welds selected for examination are to be examined for essentially 100% of their length.

Relief from this requirement is requested. ,

Proposed Alternative Examination -

The 1974 Edition with Addenda through Summer 1975 and earlier editions of the ASME Section' XI Code required that the examination cover at least 10% of the '

length of each longitudinal weld and 5% of the. length of each circumferential weld. For Hatch 1, the minimum lengths described above were met for those

, welds examined previously. For Hatch 1 RPV circumferential and longitudina' welds, approximately 5 to 15% of the total length of the welds are to be examined.

To complete.the examinations for the first ten-year interval, the examination coverage for the following welds will still be per the 1974 Edition of the ASME Section XI Code with the following limitations:

Weld No./ Description Coverage / Limitations C-7 5% of weld to be examined; (Bottom Head Torus to examination will be performed BottomHeadDomeCirc. Weld) from one side onl 1

head torus side)due y (bottom to the RPV support skirt BHT-A,-B -C,-D,-E,-F,-G, and -H 10% of weld to be examined (Bottom Head Torus Meridional Welds) 6

. - - _ . . _ _ . . . -, ,. - . , - . , _ . . - . _ . - . . .-,._m_,-., - . - - . . . _ ,

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The examination of the following welds is not possible due to inaccessibility. The RPV support skirt surrounds these welds and prohibits j any examination.

Weld No./ Description Coverage / Limitation I C-8 No examination (Bottom Head Dollar Plate l Circumferential Weld) .

l BHD-A.-8,-C.-D,-E, and -F No examination '

(Bottom Head Dome Meridional Welds)

Licensee's Basis for Requesting Relief

• l At Hatch, physical limitations prevent the examinations of the entire length  ;

of these welds. Limitations.also exist for the ultrasonic exa..:ination of RPV  !

l bottom head circumferential and meridional welds. .

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-Evaluation Portions of the concrete biological shield and the permanently installed  !

insulation would have to be removed to perfom the required examination of the

l welds from the vessel exterior. The vessel internals, shroud, and jet pumps 4

preclude volumetric examination of almost all the beltline weld volume from j the vessel interior. Due to the existence of physical limitations and '

l inaccessibility which prevent inspections in.accordance to Code Requirements, j

the proposed alternative examinations are reasonable substitutes for the Code l

required examinations during the first ten-year interval.  !

l Conclusions Based upon the above, it is concluded that for the welds discussed above, the

] Code requirements are impractical. However, it is further concluded that 1 relief for 1st ten-year interval only be granted provided that the licensee f

examines to the extent possible, additional RPV welds, such that the length of total welds examined will equal the length of the individual welds requiring j examination.

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I Volumetric Examination of Reactor Pressure Vessel and Closure Head Nozzle-to Vessel Welds and Nozzle Inside Radius Sections Code Requirements and Code Relief Request Item Nos. B3.90 and B3.100 of Table IW8-2500-1 for the 1980 Edition of ASME Section XI require the volumetric examination of RPV and Closure Head Nozzle-to-Vessel welds and Nozzle Inside Radius Sections. The applicable examination volumes are shown in Figures IW8-2500-7(a) through (d). At l Hatch, these examinations will be perfonned using ultrasonic techniques. ,

. l Proposed Alternative Examination '

1 At a minimum, eight-five percent (85%) of the examination volume has J

ultrasonic sound beams passing through it. Showing the Nozzle-to-Vessel weld <

j as N to V and the Nozzle Inside Radius Section as IRS, the following Hatch 1 i nozzles cannot' receive a full-Code examination:

Nozzle Identification Limited Examinations J

N2A Recirc. Inlet N to V

! N2B Recirc. Inlet N to V N2C I Recire. Inlet I

l N to V N20 I Recirc. Inlet N to V N2E I Recire. Inlet i N to V ,

N2F i Recirc. Inlet l N to V N2G I Recire. Inlet i N to V N2H I Recirc. Inlet i N to V '

! N2J I N to V

['Recirc.

Recirc. Inlet!l Inlet'l j N2K I N to V N48 I Feedwater) N to V; IRS

' N to V; IRS N4DI!Feedwater)

Licensee's Basis for Requesting Relief t l The licensee indicates that the above nozzles have physical limitations which prevent the ultrasonic sound beam from passing through the entire  !

examination volume. However, at a minimum, 85% of the examination volume has ultrasonic sound beams passing through it.

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v Evaluation The licensee has committed to the ultrasonic examination of the above nozzles and indicates that a minimum, 85% of the examination volumes have ultrasonic i sound beams passing through it. The proposed alternative examination is a reasonable substitute for the Code-required examinations.

Conclusions Based upon the above, it is concluded that for the nozzles discussed above. -

. the Code require *ments are impractical. It is further concluded that relief is granted for the first ten-year ISI Interval only and that the examination of the above nozzles be performed to the extent practical during this interval, Volumetric Examination of Austenitic and Dissimilar Metal Piping Welds .

Code Requirement and Code Relief Request Item Nos. 85.10, B5.50, 89.11, and 89.12 of Table IWB-2500-1 for the 1980 Edition of ASME Section XI require a volumetric and surface examination of austenitic and dissimilar metal piping welds. In addition, Item No. B14.10 of Table IWB-2500-1 requires either a volumetric or a surface examination of the pressure retaining welds in Control Rod Drive (CRD) housings. These volumetric examinations are to be performed using ultrasonic techniques in accordance with Paragraph IWA-2232 of Section XI. This paragraph specifies that austenitic and dissimilar metal piping welds are to be examined in" accordance with Article 5 of ASME Section V.

Proposed Alternative Examination Since ferritic piping welds will be examined per Appendix !!! of ASME Section XI and to provide consistency, austenitic, dissimilar metal piping welds and clad overlaid piping welds will also be examined in accordance with Appendix

Licensee's Basis for Requesting Relief The licensee indicates that Article 5 of ASME Section V does not provide the detailed guidance necessary to examine austenitic and dissimilar piping welds with the exception of austenitic welds which have been repaired by welds overlay. Therefore, the licensee proposes to examine these welds per Appendix III of ASME Section XI.

• l Evaluation Ultrasonic examination of austentic welds is usually more d'ifficult than in i ferritic materials, because of the wide variations that may occur in the acoustic properties of the austenitic welds, even those in alloys of the same nominal composition, product form, and heat treatment. It may be necessary to modify and/or supplement the provisions of Article 5 of the ASME Section V as allowed in accordance with paragraph T-110(c) of Article 1. Appendix III defines the ultrasonic examination methods, equipment and requirements applicable to Class 1 and 2 ferritic steel piping system.- However Article III-1000 r,efers to supplement 7 of Appendix III for dissimilar metal welds and austenitic steels.

Conclusion i

The licensee's request to perfonn austenitic steel and dissimilar piping welds ultrasonic examinations in accordance with Appendix III is in i conformance with the requirements of Appendix III of the 1980 Edition of the Code, therefore relief is not necessary provided the licensee perform the examinations in accordance with Supplement 7, Appendix III.

l Reactor Pressure Vessel Nozzle to Safe-End Welds (Nominal Pipe Size 44 Inches)

Code Requirement and Code Relief Request l

Item No. B5.11 of Table IWB-2500-1 for the 1980 Edition of ASME Section XI

requires a surface examination of the RPV nozzle-to-safe-end welds with nominal pipe sized ( 4 inches. Relief from this requirement is requested.

Proposed Alternative Examination The nozzle-to-safe-end welds listed below will receive,a remote visual examination with the exception of the 2-inch drain no'zle z weld. In addition, these nozzles will be pressure tested per IW8-5000 of ASME Section XI since they are located within the hydrostatic test boundary of the Nuclear Steam Supply System. -

Licensee's Basis for Request Relief The nozzle-to-safe-end welds for the instrumentation nozzles listed below are physically inaccessible for surface examination. The affected Hatch I nozzles are: -

N10 N11A N118 N12A ,

N12B N16A N168 In addition, the 2-inch RPV bottom head drain nozzle-to-safe-end weld cannot be examined due to inaccessibility. This drain line is surrounded by

, n, instrumentation lines and CRD housings which prevent the examiner from performing this examination.

Evaluation The licensee has committed to a remote v1.ual inspection of the affected nozzles plus an examination for leakage during hydrostatic testing. The propo. sed alternative examination and hydrostatic tests are reasonable '

substitutes for the Code-required examination.

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, -8 Conclusions Based upon the above, it is concluded that for the nozzles discussed above, the Code requirements are impractical. It is further concluded that the licensee's alternative examinations discussed will provide the necessary added assurance of structural reliability. Therefore ,the request for relief is granted for the 1st ten-year interval only.

• Volumetric and Surface Examinations of Pressure Retaining Welds in Piping with Nominal Pipe 512eJk4 Inches Code Requirement and Code Relief Request

• Item No. B9.11 of Table IWB-2500-1 for. the 1980 Edition of ASME Section XI requires the examination of pressure retaining welds in piping that are located within flued head containment penetration assemblies. These welds -

and their penetration assembly number for Hatch 1 are listed below.

Weld Identification No. Penetration No.

1821-1FW-18A-7A X-9A 1821-1FW-188-6A X-9B

. 1E51-1RCIC-4-D-20A X-10 1E41-1HPCI-10-D-15A X-11 1E11-1RHR-208-D-13A X-12 1E11-1RHR-24A-R-3A X-13 IE11-1RHR-24B-R-3B X-138 1G31-1RWCU-6-D-158 .

X-14 1G31-1RWCU-6-D-15C X-14 1E21-1CS-10A-3A X-16A 1E21-1CS-108-4A X-16B IE11-1RHR-4-HS-6A X-17 The licensee requests relief from the surface and volumetric requirements of the Code for these twelve welds.

a Proposed Alternative Examination .

In accordance with !WB-5521 of ASME Section XI, a system leakage test is to be performed on all 12 welds prior to startup following each reactor refueling outage.

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i All pipe-to-penetration (flued head) welds outside containment will be examined volumetrically. In addition, a surface examination will be performedontheaccessibleweld(s)ofthefluedheadpenetrationassembly.

Licensee's Basis for Refueling Relief These welds are inaccessible for examination due to th' e design of the flued head. All twelve circumferential butt welds, except the two located in the Reactor Water Cleanup (RWCU) penetration, are carbon steel.

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, The two stainless steel welds that are located in the RWCU penetration were made t6 replace a Type 304 SS pipe that had undergone IGSCC. The welds involved are a flued head with a Type 308L corrosion resistant clad on the inside surface to a Type 304L solution annealed pipe ( .035% carbon), and a Type 304L pipe-to-pipe weld. These welds were made in accordance with the guidelines of NUREG-0313 to minimize susceptibility to IGSCC.

Evaluation The identified welds are completely inaccessible for volumetric or surface examination because the welds are located inside a containment penetration.

Each primary containment penetration assembly, due to its design, leaves one pressure-retaining piping weld inaccessible for examination by either surface or volumetric means (the RWCU penetration has two inaccessible welds). The welds can only be examined by inspecting for evidence of leakage during system hydrostatic pressure tests. ,

The two stainless steel welds that are located in the RWCU penetration were made to replace a Type 304 SS pipe that had undergone IGSCC. The welds involved are a flued head with a Type 308L corrosion resistant clad on the inside surface to a Type 304L solutton annealed pipe ((.035% carbon), and a .

Type 304L pipe-to-pipe weld. These welds were made in accordance with the guidelines of NUREG-0313 to minimize s0sceptib111ty to IGSCC.

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The initial design of the assemblies did not provide for accessibility for inservice examinations. If, however, the workmanship and quality assurance of the welding as well as the preservice examinations are assumed adequate, then an examination of the first pressure boundary weld either upstream or downstream of the inaccessible weld should reflect the integrity of that particular piping section under the service condition. Thus, the first pressure boundary weld adjacent to the inaccessible we'1d on each of these process pipes should be volumetrically examined, where practical, over 100%

of its length during each inspection interval. Such an examination would maintain the Code required sample size and the licensee should also conduct .

visual examinations at these penetrations, as proposed, which would further indicate the existence of any through-wall cracks.

The licensee has committed to a system leakage test prior to startup following refueling. In addition, all pipe-to-penetration (flued head) welds outside containment will be examined volumetrically. Surface examination will also be performed on the accessible weld (s) of the flued head penetration assembly. These proposed alternative examinations and tests are reasonable substitutes for the Code-required examination provided that the licensee examines additional welds adjacent to welds for which relief is requested.

Conclusion l Based upon the above, it is concluded that for the welds discussed above, the i Code requirements are impractical. It is further concluded that the l alternative examinations discussed will provide necessary added assurance of l structural reliability. Therefore, relief is granted from performing l the Code-required examinations during the first ten-year interval provided the additional welds are examined.

ASME Class 1 (Equivalent) Valves Exceeding 4 Inches Nominal Pipe size and ASME Class 1 (Equivalent) Pump Casings

• Code Requirement and Code Relief Request

• l Table IWB-2500-1, Item No. 812.40 for the 1980 Edition of ASME Section XI i

requires a visual examination of the internal pressure boundary surfaces of one valve in each group of valves that are of the same constructional design, such as globe, gate, or check valve, and manufacturing method and that are performing similar functions in the system.

Table IW8-2500-1, Item No. 812.20 of ASME Section XI requires a visual examination of the internal pressure boundary surface *of one of the two

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Reactor Recirculation system pumps. '

Relief is requested from the visual examination of internal surfaces at the -

, pressure boundary of the Class 1 pumps and valves.

Proposed Alternative Examination Class 1 pumps and Class 1 valves exceeding four inches nominal pipe size are subject to visual examination of the internal surfaces when disassembled for maintenance. The licensee proposes that the coverage provided by examinations during routine maintenance coupled with periodic leak tests and hydrostatic tests will provide adequate assurance of the structural integrity i of the Class 1 pumps and valves, while keeping exposure to radiation and contamination as low as reasonably achievable.

Licensee's Basis for Requesting Relief Disassembly of these valves and pumps for the visual examination during the inspection interval, in the absence of other required maintenance, represents an unnecessary exposure to radiation and contamination. Valves on the ReactorRecirculation(RC)systemandtheResidualHeatRemoval(RHR) system suction lines would require #t 'eading the fuel elements and draining the RPV prior to disassembly.

• A on the RC system pump discharge valves and the RHR system injection valves would require the installation of plugs in the jet pump risers. Preparatory work of this scope is considered impractical for the sole purpose of conducting a visual examination. Contamination levels in the valves and pumps associated with the RC system loops are particularly

high due to the physical location at the bottom of the system. During routine maintenance, the valve body and the pump casing internal surfaces are visually examined. Many of the valves, particularly the containment isolation valves are disassembled for maintenance of leak-tightness. Disassembly of other Class 1 valves and the pumps solely for internal examination is counter to the "ALARA" guidelines to keep the occupational dose rates as low as reasonably achievable. In view of the cost in man-rein and in view of the minimal benefits obtained, the licensee concludes that this Code requirement

, does not provide sufficient benefits to justify the exposure.

, Evaluation The visual examination is to determine whether unanticipated severe degradation of the casing is occurring due to phenomena such as erosion, corrosion, or cracking. However, previous experience during examinations of pumps at other plants has not shown any significant degradation of casings.

Disassembly of large valves to the degree necessary to examine the internal pressure-retaining surfaces is a major effort which may involve large personnel exposures. To do this disassembly solely to perfonn a visual u examination of the internal body is impractical.

The proposed alternative visual examinations and normal visual examination ,

during system pressure tests are reasonable substitutes for the Code-required examinations.

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! Conclusions Based upon the above, it is concluded that for the pumps and valves discussed above, the Code requirements are impractical. It is further concluded that the alternative visual examinations discussed will provide necessary added assurance of structural reliability. Therefore, the request for relief is i

granted from performing the Code required examinations on pumps and valves during the first ten-year interval. In addition, the licensee shall perform l

the Code examination on Hatch Unit 1 pumps and valves disassembled for maintenance or any other purpcae during the first ten-year interval.

Pressure Retaining Welds in Control Rod Drive Housings Code Requirement and Code Relief Request Table IW8-2500-1, Item No. 814.10 for the 1980 Edition of ASME Section XI requires a volumetric or surface examination of the pressure retaining welds in 10% of the peripheral Control Rod Drive, housings. Each housing has a

, pipe-to-pipe weld located near the RPV and a pipe-to-flange weld. Relief is requested from the volumetric or surface examinations for the pipe-to-pipe and pipe-to-flange welds.

Proposed Alternative Examination These welds will be visually examined during the system hydrostatic test per IW8-5000 of ASME Section XI since they are located within the hydrostatic test boundary of the Nuclear Steam Supply system.

Licensee's Basis for Requesting Relief The examination of the pipe-to-pipe welds is not possible due to

, inaccessibility.. The RPV support skirt surrounds the CRDs and prohibits any examination.

The examination of the pipe-to-flange welds is limited because of the location and design of the housings. Physical accessibility by an examiner is extremely limited by the close proximity of the housings to each other and by the support arrangement. Also, the insert and withdraw lines to the Control Rod Drive system are connected at the top of the housing flange and limit access to much of the lower weld. The combination of these factors i limit the examination of these welds.

Evaluation Because of the physical inaccessibility of the lower welds and the high radiation fields to which examining personnel would be exposed, examination of the peripheral control rod drive housing welds is impractical.

The licensee has shown that the makeup system has suff'icient capacity to shut

. Jown and cool the reactor in an orderly manner, should a complete failure of a CRD housing weld occur. Each CRD housing has an attachment weld to the reactor vessel and a weld joining the housing to the flange. The failure of ,.

, a CRD housing weld will produce a maximum leakage rate of 840 gal / min. The available makeup systems are RCIC-400 gal / min., CRD-160 gal / min., and feedwater-1000 gal / min. Therefore, the reactor can be shut down and cooled down in an orderly manner using makeup systems supplied by onsite power, as required by IW8-1220. Note: Since loss of coolant occurs during' normal operation, it is our interpretation that the service transformer is the source of onsite power. Thus, the requirements of paragraph IW8-1220(a) are satisfied and the examinations required for Code exempted components would be performed by the licensee. -

Conclusions Based upon the above, it is concluded that for the welds discussed above, the Code requirements are impractical. It is further concluded that the alternative visual examination discussed will provide necessary added assurance of structural reliability. Therefore, relief is granted from performing the Code-required examination on these welds during the first ten-year interval, i Volumetric Examination of pressure Retaining Welds in Class 2 Vessels Code Requirement and Code Relief Request 7

Item Nos. C1.10, C1.20, and C1.30 of Table IWC-2500-1 for the 1980 Edition of

ASME Section XI require the volumetric examination of Class 2 vessel shell circumferential, head circumferential, and tubesheet-to-shell circumferential welds, respectively. The volumetric examination of the Residual Heat Removal (RHR) system heat exchanger circumferential welds will be performed using ultrasonic techniques. The required examination volumes are shown in ASME Section XI Figures IWC-2500-1 and -2. Relief from this requirement is requested.

• Proposed Alternative Examination The ultrasonic examination of the shell and head circumferential welds will be supplemented by a surface examination, in addition to the examinations described above, system pressure tests per Article IWC-5000 of ASME Section XI will be performed on these welds.

Licensee's Basis for Requesting Relief The shell and head circumferential weld examinations are limited by vessel supports adjacent to these welds. In addition, the ultrasonic examination of the head circumferential weld from the head side cannot be perfomed due to configuration. The examination volume as required by Figure IWC-2500-2 for the tubesheet-to-shell weld cannot fully be met due to configuration also.

The tubesheet to shell weld cannot be properly prepared for surface examination nor can the examination be performed due to the tubesheet studs and nuts adjacert to the weld.

Evaluation Due to configuration problems, Code-required weld examinations are limited.

The licensee has conunitted to an ultrasonic examination to the extent possible and surface examinations except for the tubesheet to shell weld. In addition, system pressure test will be perfomed on those welds. The proposed alternative ultrasonic, surface and visual examinations during system pressure tests are reasonable substitutes for Code-required examinations.

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Conclusions Based upon the above, it is concluded that for the welds discussed above, the Code requirements are impractical. It is further concluded that the alternative examinations discussed will provide added assurance of structural reliability during the remaining period of the first ten-year interval.

Therefore, relief is granted from performing the Codeirequired examinations on these welds during the first ten-year interval.

Surface Examination of Welded Attachments on RHR, Core Spray, HPCI, and RCIC 5uction Lines from Torus .

Code Requirement and Code Relief Request Item No. C3.40 of Table IWC-2500-1 for the 1980 Edition of ASME Section XI requires 100% surface examination of integrally welded attachments on piping. Figure IWC-2500-5 detennines the surface area of this examination.

Suction lines for RHR, Core Spray HPCI, and RCIC systems penetrating the

, torus are seal welded to the outside surface of the torus wall. Relief is requested from the surface examination of these welded attachments.

Proposed Alternative Examination

• Visual examination (VT-1) in accordance with IWA-2211 will be performed to insure the integrity of these attachments.

Licensen's Basis for Requesting Relief At Hatch Unit 1 these integrally welded attachments on Ifnes penetrating the torus are obstructed by reinforcement plates added after plant construction. Onehundredpercent(100%)ofthesealweldisinaccessible for a meaningful surface examination.

Evaluation The licensee indicates that the above discussed seal welds are inaccessible for a meaningful surface examination as required by the Code. The licensee has comitted to a visual examination (VT-1) in accordance with IWA-2211.

The proposed alternative examination is a reasonable substitute for the Code-required examination. -

Conclusions,

, Based upon the above, it is concluded that for the welds discussed above, the Code requirements are impractical. It is further concluded that the ,

alternative visual examination discussed will provide necessary added assurance of structural reliability. Therefore, relief is granted from performing the Code-required examinations on these welds during the first ten-year interval.

Surface Examination of Pressure Retaining Welds in Class 2 Pumps Code Requirement and Code Relief Request Item No. C6.10 of Table IWC-2500-1 for the 1980 Edition of ASME Section XI requires a surface examination of the pump casing welds from one Class 2 pump

. in each group of pumps that are of similar design, size, function, and service in a system. Relief from this requirement is requested.

Proposed Alternative Examination Class 2 pump casing welds are subject to surface examination when disassembled for maintenance. The coverage provided by examinations during routine maintenance coupled with hydrostatic tests will provide adequate assurance of th6 structural integrity of these pumps, while keeping exposure to radiation and contamination as low as reasonably achievable.

i Licensee's Basis for Requesting Relief Disassembly of these pumps for the surface examination during the inspection interval, in the absence of other required maintenance, represents an unnecessary exposure to radiation and contamination. During routine .

maintenance, the pump casing welds receive a surface e,xamination. In view of the cost in man-rem and in view of the minimal benefits obtained, the licensee concludes that this Code requirement does not provide a l

corresponding benefit in reliability.

. Evaluation The licensee indicates that disassembly of these pumps would be required to perform the Code-required surface examination. The NRC staff believes that i surface examination of these casing welds is possible from the outside without the disassembly of the pumps. Therefore, the proposed alternative visual examination is not acceptable because the Code-required examination is not impractical based upon the staff's evaluation.

Conclusions Based upon the above, it is concluded that for the welds discussed above, the Code requirements are not impractical for Hatch Unit 1. Therefore, relief is not granted from performing the Code-Tequired surface examinations on welds during the first interval.

System Pressure Tests on Class 3 Small Diameter Piping l

l Code Requirement and Code Relief Request l

Table IWD-2500-1 for the 1980 Edition of ASME Section XI requires a system pressure test for Class 3 lines regardless of size (D1.10, 02.10, 03.10).

Relief is requested on systen pressure test requirements for Class 3 piping lines two inches and smaller.

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Proposed Alternative Examination

! Accessible piping two inches and smaller will be visually examined undar normal operating pressure.

Licensee's Basis for Requestino Relief '

The system pressure test requirements for Class 3 will not be performed on '

s lines two inches and smaller unless: r o

a. They are connected to larger lines which will be pressure tested.

b.  ! solation valves are not provided so that these smaller lines may be isolated in case of leakage. .

These smaller lines have wall thicknesses in excess of what ASME Section !!! ~

requires for retaining internal pressure. Using heavier walled piping in these small lines essentially means they are over-designed for the pressure they are retaining and are not susceptible to the type leakages found during hydrostatic testing. '

Evaluation The Code requirement for the pressure-retaining components within each system  ;

boundary is that each component shall be subject to a pressure test each inspection period and a hydrostatic test each inspection interval. There are

' r4 no exemptions or exclusions from these requirements. * '

s The nominal operating pressure of the system or component functional test' <

shall be acceptable as the system test pressure. The licensee has requested relief from performing the required pressure tests based on the fact that the subject lines are over designed for the pressure they are retaining. The '

requirements of Section XI should not be mitigated by the over-design conditions of the compon2nts. -

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, Conclusions Based upon the above evaluation and in the absence of any practical reason why the required pressure tests cannot be performed, it is concluded, that the Code required examinations are not impractical. Therefore the request for relief from performing the required pressure tests,on Class 3 piping less than 2 inches is not granted.

System Pressure Tests on Class 3 Buried Piping

. Code Requirement and Code Relief Request '

Table IWD-2500-1 of the 1980 Edition of ASME Section XI requires a system pressure test for Class 3 components including buried piping (D1.,10, 02.10, ,

D3.10).

Relief is requested from system pressure tests for Class 3 buried piping.

Proposed Alternative Examination 4

The licensee proposes that normal system functional testing will demonstrate leaktight integrity of all buried piping.

Licensee's Basis for Requesting Relief The service water systems were designed without including provisions for testing buried piping as required by Paragraph IWA-5244. In addition, the visual examination for leakage at the ground level is not feasible since a majority of the piping is buried under asphalt.

Evaluation Since the service water systems do not have provisions fo'r testing buried piping and visual examination for leakage at ground level is not feasible, the Code-required examinations are impractical.

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The licensee's proposed system functional testing is a reasonable substitute for the Code-requ" ired examir.stion.

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Conclusions s

% s Based upon the above, it is concluded that for the buried pressure retaining components discusied above, the Code requirements are impractical. It is

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_further concluded that the system function testing will provide necessary

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added assurance'of structural reliability. Therefore, relief is's' ranted from performing the Code-required examinations'en buried pressure retaining ,

components during the first ten-year interval.

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Pressure Test on Plant Service Water System s

.c Code Requirement and Code Relief Request IWD-5223 of the 1980 Edition of ASME Section XI requires that the Plant Servic'e, Water System be tested at a pressure of 1.10 times the design pressure. Relief is requested from testing those portions where it is necessary'to use a butterfly valve tan inches in diameter or greater as a hydrostatic <test boundary valve. ~

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Proposed Alternative Examination '

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'A hydrostatic test will be performed on those portions of the Plant Service '

Water System which have a butterfly vaive ten. inches in diameter or greater .

at the normal operating pressure rather than 1.10 times the design pressure.

T Licensee's Basis for Requesting Relief I Butterfly valves are basically ficw control valves and are not intended to be block valves. The normal ?eakage through these large valves makes it >

impractical to attain and maintain the hydrostatic test pressure.

6 Evaluation l

Since butterfly valves are not intended to be block valves and, therefore, nonnal leakage through these valves makes it impractical to do a hydrostatic pressure test. The only way to test the subject piping sections to Code requirements is to install hydrostatic pump fittings. Based on the fact that .

the plant would be promptly shutdown to repair the seals, if they leak, the pressure test should provide adequate assurance of system integrity without compromising public safety.

Conclusions Based upon the above evaluation, it is concluded that for the examinations

, discussed above, the Code requirement are impractical. It is further

~

cohcluded that the a1 ternate examinations discussed above will provide added assurance of structural integrity. Therefore request for relief from the pressure test requirements on the Plant Service Water System is granted for the dura' tion of the 1st ten-year interval.

Requirement to Verify Hot or Cold Settings on Spring Cans and Snubbers Code Requirement and Code Relief Request Subparagraph IWF-3410(a)(5) of the 1980 Edition of ASME 5ection XI states that a component support condition which 11 unacceptable for continued service is improper hot or cold positions for spring supports or snubbers.

Relief from this requirement is requested.

Proposed Alternative Examination The licensee proposes a visual examination which will verify that the indicator falls within the operational limits.

Licensee's Basis for Requesting Relief The licensee indicates as justification for this relief request that there are no exact design positions on the scales for spring supports or snubbers but an operational range where the indicator should be located.

Evaluation "

l The licensee has not provided sufficient justification and basis for this f

relief request. The staff notes that the Section III stress analyses of the piping system should have resulted in hot and cold loads for springs and travel' range for the snubbers. The design of the particular support should have used this design data to pick the appropriata standard support. The proposed relief request is unacceptable because insufficient justification has been provided by the licensee to support this relief request.

Conclusions Based upon the above, it is concluded that for spring supports or snubbers e

discussed above, the Code requirements have not been shown to be impractical.

Therefore, relief is not granted from performing the Code-required examinations for spring supports or snubber during the first ten-year interval.

t i

Visual Examination of ASME Class 1, 2, and 3 Component Supports Code Requirement and Code Relief Request IWF-2510 and 2520 of the 1980 Edition of ASME Section XI require that visual examinations of the selected component supports be completed in accordance with the applicable section of IWB, IWC, or IWD. Relief is requested from examining supports on ASME Class 1 lines, 2-inch nominal pipe diameter and less, during the completion of the Hatch Unit No.1 first 10-year interval.

Also, supports on ASME Class 2 and 3 lines' 4-inch nominal pipe diameter and less will not be examined.

Proposed Alternative Examination All supports on ASME Class 1 lines greater than 2-inch nominal pipe diameter-will be visually examined. All supports on ASME Class 2 and 3 lines greater than 4-inch nominal pipe diameter will be visually' examined.

Licensee's Basis for Requesting Relief

• The hanger surveillance program for the first 10-year interval was originally i

based on the 1974 Edition of ASME Section XI with Addenda through Summer .

1975. In this edition of the Code, IWB-1220(b)(1) allowed the exemption of i all components where under the postulated condition of loss of coolant from the component during normal reactor operation, the reactor can be shut down using only a nomal makeup system. For the Hatch Plant, 2-inch nominal pipe ,

diameter lines and smaller with associ,ated supports may be exempted using IWB-1220(b)(1). Also,-IWC-1220(d) and I'WD-2600(c) allowed the exemption of

supports on lines 4-inch nominal pipe diameter and less.

Since all supporting documentation, examination plans, and procedures

. incorporate this exemption, the scope of examinations to complete the first 10-year interval will continue to be detemined fro'n the 1974 Edition of the Code. Examination techniques will be determined from the 1980 ' Edition of - r ASME Section XI with Addenda through Winter 1980. ,

Evaluation The licensee has not offered a sufficient technical basis to support the request relief. 10 CFR 50.55a(g)(4)(iv) requires all related requirements of the later Code be used unless specific relief is granted by the Commission.

In addition the regulations require inspection of RHR, ECCS and CHR system-l piping and components, and therefore their supports must also be inspected.

Conclusion i

Based upon the evaluation above, the request for relief is not granted.

l J

Basic Calibration Blocks for Pipe Weld Examinations Code Requirement and Code Relief Request Appendix III of the 1980 Edition of ASME Section XI delineates the requirements for the design and fabrication of basic calibration blocks for pipe weld examinations. It specifies that the basic ta'libration block shall be fabricated with notches and that the basic calibration block nominal diameter and thickness be equivalent to the component to be examined. Relief is requested so that existing basic calibration blocks may be used for pipe .

weld examinations.

l Proposed Alternative Examination The basic calibration blocks using side-drilled holes as calibration reflectors will be used for the majority of the pipe weld examinations.

Licensee's Basis for Requesting Relief

, The majority of existing Hatch basic calibration blocks used for pipe weld examinations were fabricated with diameters, thicknesses, and side-drilled holes in accordance with the 1974 Edition of ASME Section V. For the two primary. reasons listed below, these same basic calibration blocks will be used to provide the most meaningful and thorough examinations possible:

1. Side-drilled holes as calibration reflectors result in a more sensitive ultrasonic examination than one using notches.

2. Correlation of ultrasonic data with previous examinations as required by Subarticle IWA-1400 of ASME Section XI makes it necessary that these basic calibration blocks be used so future examination results can be correlated with past results.

Evaluation i .

Technical evaluation of the proposed calibration blocks prior to the preservice and first ten-year interval examination indicated that examination e

3 7-i effectiveness would not be reduced by use of the proposed calibration blocks. An important feature of the overall ISI program is that the preservice inspection serves as a baseline by which inservice examination results are evaluated. Accordingly, it is appropriate to use methods during inservice inspection which are consistent with preservice inspection methods provided the preservice methods were technically acceptable.

. Conclusions Based on the above evaluation, it is concluded that for the methods, discussed above, adherence to the Code requirements' is impractical. It is further conclude.d that the proposed methods will provide necessary assurance of structural reliability during this interval. Therefore, relief is granted .

as requested.

Straicht Beam Examination of Reactor Pressure. Vessel and Closure Head Welds Inclucing Nozzel-to-Vessel Welds Code Requirements and Code Relief Request -

Subparagraph T-441.4.3 of Article 4 of the 1980 Edition of ASME Code Section V requires that prior to the angle beam examination, the base material through which the angle beam will travel shall be scanned with a straight beam transducer to detect laminar reflectors which might affect the angle beam results.

Proposed Alternative Examination The licensee states that other examinations designed to detec'; service-induced j flaws are required by ASME Section XI on these welds.

i Licensee's Basis for Requesting Relief During the preservice examination at Hatch 1, the adjacent base material for the RPV and Closure Head welds, including the Nozzle-to-Vessel welds, were i

examined with a straight beam transducer and any laminar reflectors which 1

would interfere with the angle beam scans were recorded. Since the size of these reflectors will not change, it is unnecessary to perform the straight beam scans again. Also, these scans would only result in additional radiation exposure without a corresponding benefit in reliability.

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Evaluation ~

The licensee has not provided sufficient technical justification to support the statement "Since the size of these reflectors will not change, it is unnecessary...." Since the previous statement is not sufficiently justified the following statement is also inadequately supported. The licensee should

, provide (1). additional justification to support the reason why the laminar reflectors will not change and that the laminar reflectors recorded during preservice examination were. scanned and recorded in accordance with a procedure consistent with T-441.4.3 of Article 4 of 1980 Edition of ASME Code Section V. (2). estimates of personnel radiation exposure for the straight beam,45degreeand60degreescans,and(3). applicabiMty of remote automated examination techniques. In additi,on, the intent of straight beam examinations is not only limited to the detection of laminar reflectors but also to detect the planar reflectors.

Conclusions Based upon the evaluation above the request is not granted because of ,e .

insufficient technical justification.

Incorporation of Changes in Design, Testing, and Procedures without any Unreviewed Safety Questions into The Inservice Inspection Program / Plan Code Requirement and Code Relief Request 10 CFR Part 50.59 a11ows changes to a nuclear facility and procedural changes in accordance with Plant Technical Specifications and the safety analysis

, report, without prior approval from the NRC, provided there are no unreviewed safety questions. The facility's Inservice Inspection Program / Plan should be revised to include these changes. .  ;

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s.

Changes such as valve operator, stroke time, pump performance, welds, etc.,

made in compliance with 10 CFR 50.59, which affects the ASME Section XI requirement,s may not be shown on the existing revision of the ISI progra n plan document. A relief is requested from this inconsistency.

Proposed Alternative Examination Records of all changes will be maintained. Changes affecting ASME Section XI requirements shall be incorporated into the ISI Program Plan, whenever a need for their update is warranted.

Licensee's Basis for Requesting Relief Records of these changes will be maintained and any changes in ASME Section XI requirements pertaining to these changes will be complied with. However, a revision to the ISI Program Plan for every minor change is unrealistic, costly and time consuming task. Any delay. in revising the ISI program plan will not endanger public health and safety.

Evaluation The licensee has agreed to perform any additional examinations required as a result of any changes affecting the ISI plan. The licensee will also l maintain appropriate' records as required by 10 CFR Part 50.59. In addition, the records required in paragraphs IWA-6220 will provide documentation of examinations performed during the refueling outage.

l Conclusions Based on the above evaluation, it is concluded that the relief request to delay revising the ISI program for minor changes is allowable. Therefore relief as requested is granted for the 1st ten-year interval only,. provided any additional examinations that may be required which result from.a ch'ange in

{

procedures or, equipment are performed before the end of the 1st ten-year interval.

7, Due Date for Owner's Date Report for Inservice Inspection, Form NIS-1 Code Requirement and Code Relief Request -

Paragraph IWA-6230 of the 1980 Edition of ASME Section XI requires that the Owner's Data Report for Inservice Inspection, Form NIS-1, shall be filed with ,

the enforcement and regulatory authorities (in this case, the Nuclear Regulatory Commission) within 90 days of the completion of the inservice inspection. Relief from the ISI completion date relative to the reporting requirement and the due date are requested.

propos5d Alternative Examination Form NIS-1 will be submitted to the NRC within 120 days after completion of the outage in which the examinations were performed.

Licensee's Basis for Requesting Relief ,

The 90-day due date from the completion of the inservice inspection is unrealistic to prepare the NIS-1 Form and to have the multiple reviews required. The preparation of the NIS-1 Form itself requires almost 90 days with at least another 30 days needed for the review by site personnel and the i Inspector.

Evaluation The licer see has requested relief from submitting the NIS-1 form in the required 90-days from completion of the inservive inspection. Other licensee's have found that 90 days is an adequate period of time to file the l

NIS-1 form. The licensee's basis for th5 request, i.e. 90 days is

unrealistic to prepare the N1S-1 form, is not consistent with industry-wide practice.

l .

l

7 , .,

r..

I Conclusion Based on the above evaluation, it is concluded that the licensee has not provided sufficient justification to warrant the request for relief from the requirement to file form NIS-1 with the NRC within 90 days. Therefore the request for relief is not granted.

Summary and Conclusion The staff has discussed with the licensee the concept of having concurrent ten-year inspection intervals and updating the inservice inspection programs for both units to the same ASME Code Edition. We agree with this concept.

We are now evaluating an updated second ten-year interval inservice inspection program for Units 1 and 2. The change in the inservice inspection program for completion of the first ten-year inservice inspection interval is approved, provided that all components that were required to be inspected in this interval based on the 1974 Edition of Section XI Code will have been inspected by the close of this interval.

- Based on the above review as summarized in Attachment 1, the staff concludes that relief granted from the examination requirements and the alternate methods imposed through this document give reasonable assurance of the piping and component pressure boundary and support structural integrity, that 6

granting relief where the code requirements are impractical is authorized by law and will not endanger life or property, or the common defense and secLeity, and is otherwise in the public interest considering the burden that could result if they were imposed upon the facility.

The specific relief requests granted are only applicable for the extent of the first ten-year interval.

6 ATTACHMENT 1 TABLE 1 CLASS 1 COMPONENTS LICENSEE i

PROPOSED l IWB-2500 IWB-2500 SYSTEM OR AREA TO BE REQUIRED ALTERNATIVE RELIEF REQUEST l ITEM NO. EXAM. CAT. COMPONENT EXAMINED METHOD EXAMINATION STATUS B1.11 8-A Reactor Circumferential Volumetric Examination Granted l Bl.12 Vessel and Longitudinal per 1974 Edition for 1st Shell Welds ASME Code Sec. XI ten-year ISI Interval only with  ;

conditions.

See Note 1.

B1.21 B-A Reactor Circumferential Volumetric Examination per. Granted Bl.22 Vessel and Meridional 1974 Edition ASME for 1st Bottom Head Welds Code Sec. XI ten-year Head ISI Interval only with conditions.

See Note 1.

83.90 B-D Reactor Nozzles-to- Volumetric 85% of exarh Granted B3.100 Vessel Vessel volume. for 1st Nozzle In- Nozzles cannot ten-year side Radius receive full- ISI Interval Code exam. only provided N2A N2D N2G N2K exam perfomed to N2B N2E N2H N4B extent practical.

N2C N2F N2J N4D B-5.10 B-F Reactor Dissimilar Metal Volumetric Examire per Appendix No Relief l Vessel Nozzle-to-Safe Surface III Section XI Required l EndsWeldh4in. l B5.50 B-F Piping Dissimilar Volumetric Examine per Appendix No Relief B9.11 B-J Metal Fitting Surface .III Sec. XI Required i B9.12 to Pipe Welds  !

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O P

TABLE 1

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CLASS 1. COMPONENTS (Continued)

LICENSEE PROPOSED j IWB-2500-1 IWB-2500 SYSTEM OR AREA TO BE REQUIRED ALTERNATIVE RELIEF REQUEST 1 ITEM NO. EXAM. CAT. COMPONENT EXAMINED METHOD EXAMINATION STATUS _

B5.11 B-F Reactor Dissimilar Surface Remote Visual. Granted for 1st i

Metal Examined for ten-year interval l Nozzle-to-Safe leakage during only

! Ends. Weldsal_

""~

hydrostatic i

4 in. testing.

Nozzles affected.

N10 N128 N11A N16A N11B N16B

N12A d

4 Except 2", RPV l bottom drain nozzle no test.

I 89.11 B-J Piping Welds within Surface and Visual exam Granted for 1st containment Volumetric during leakage ten-year interval penetrations. test prior' only.

i 12 welds to startup

• i after refueling.

l All pipe-to- l l

penetration welds i outside contain-j ment exam volu-metric. Surface exam accessible welds of pene-tration assembly.

} ,

TABLE 1 CLASS 1 COMPONENTS (Continued)

LICENSEE PROPOSED IWB-2500-1 IWB-2500 SYSTEM OR AREA TO BE REQUIRED ALTERNATIVE RELIEF REQUEST ITEM NO. EXAM. CAT. COMPONENT EXAMINED METHOD EXAMINATION STATUS B12.40 B-M-1 Valve "

Internal Visual Visual during Granted for B-M-2 bodies surfaces hydro ist ten-year B-L-1 Pump Pressure Volumetric ISI interval B12.20 B-t-2 casings retaining only provided welds any valve or

' pump disassembled has visual examination B14.10 B-0 Control Pressure Volumetric Visual during ' Granted for Rod drive retaining or Surface hydro ist ten-year Housing welds ISI interval only.

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TABLE 2 CLASS 2 COMPONENTS, 1

LICENSEE PROPOSED IWC-2500 IWC-2500 SYSTEM OR AREA TO BE REQUIRED ALTERNATIVE RELIEF REQUEST ITEM NO. EXAM. CAT. COMPONENT EXAMINED METHOD EXAMINATION STATUS C1.10 C-A Residual Shell and Volumetric Volumetric to Granted only C1.20 Heat Ex- Head circum- the extent for 1st ten-C1.30 changer ferential possible. year interval welds. Surface except only.

Tubesheet- shell weld.

l to-shell visual during I

welds system test.

C3-40 C-C Suction Piping Surface Visual Granted only for lines attachment first ten-year penetra- welds interval, provided ting into surface exam on torus for attachment plates RHR, Core is performed.

spray, HPC1, RCIC C6-10 C-G Pumps Casing Surface Visual wheh Not Granted Welds disassembled surface exam from -

for main- outside is possible.

tenance.

. visual during

. hydro

. - - - - - - . . _ .. ~. ..

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TABLE 3 CLASS 3 COMPONENTS * ,

LICENSEE PROPOSED -

IWD-2500-1 IWD-2500 SYSTEM OR AREA TO BE REQUIRED ALTERNATIVE RELIEF REQUEST ITEM NO. EXAM. CAT. COMPONENT EXAMINED METHOD EXAMINATION STATUS DI.10 D-A Pressure Pressure ' Visual Accessible Relief not D2.10 D-B retaining Retaining VT-2 PipingdL 2 in. granted.

D3.10 D-C Components Boundary Visual"Huring l operation.

DI.10 D-A Buried Pressure Visual System function Granted for D2.10 D-B Pressure Retaining VT-2 testing. Ist ten-year D3.10 D-C Retaining Boundary ISI interval Components only.

IWD-5000 LICENSEE PROPOSED -

SYSTEM OR PRESSURE TEST ALTERNATIVE RECIEF REQUEST COMPONENT REQUIREMENT TEST STATUS Plant Service IWD-5223 of 1980 Hydrostatic test Granted for 1st Water System requires Plant on portions of ten-year interval Service Water system which have only System test at butterfly valve pressure 1.10 '10' inch or greater times design at normal operating pressure pressure

TABLE 4 t

COMPONENT SUPPORTS i

1 LICENSEE i IWF-2500-1 IWF-2500-1 SYSTEM OR ITEM TO BE REQUIRED PROPOSED ITEM NO. EXAM. CAT. RELIEF REQUEST COMPONENT EXAMINED METHOD ALTERNATIVE STATUS

~

F3.50 F-C Spring Proper hot Visual Visual to verify Not Granted Support or cold position VT-3 indicator in Insufficient or snubbers per design operational range Justification See note 2.

i i

F1.10-F3.40 F-A, F-B Class 1 Supports for Visual Visual Class Not Granted and F-C 2&3 Class 1 piping VT-3 13>2 inch  !

component 251 inch and-

• supports for Class 2 and 3 l piping)>4 inch Visual Class Not Granted -

) and systems 2 and 3) 4 inch j

operating at:>275 psig and;>200*F, i

) and RHR, CHR and

• 1 ECC systems irrespective of . -

s;ze, operating '

pressure and

], temperature ,

I 1

l 1

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TABLE 5 l

V0LtNETRIC EXAMINATION METHODS LICENSEE PROPOSED RELIEF ALTERNATIVE REQUEST REQUIREMENT TEST METHOD STATUS Ultrasonic examina- Calibration block Granted for 1st.

1 tion of class 1 and with side drilled ten-year ISI i class 2 ferritic holes -

only.

steel piping system shall be conducted in accordance with Appendix III ,

Subpara. T-441.4.3 of Article 4 Other exams rec'd. Not Granted requires that prior to angle by Sec. XI. Preservice beam exam, the base material plot of laminar reflectors shall be scanned with a will not change because -

straight beam to detect of service.

laminar reflectors.

s P

TABLE '6 GENERAL RELIEF REQUESTS i LICENSEE PROPOSED RELIEF ALTERNATIVE REQUEST i REQUIREMENT METHOD STATUS I 10 CFR 50.59 allows changes Records of all changes will be Granted only for 1st to facility and procedures maintained. Changes affecting ten-year ISI without NRC approval provided ASME Code Section XI will be interval . Any that there are no unreviewed incorporated in the ISI program / additional exams safety issues. The facility plan whenever plan is updated. required which ISI program / plan should be result from revised to include changes. changes in procedures or equipment are performed prior to the end of 1st ten-year interval.

IWA-6320 requires Owner's Owner's report will be filed Not granted Data shall be filed with with NRC within 120 days of -

NRC within 90 days of completion of outage in which completion of inservice inspections are performed inspection. J e

i Y

7 Notes: ,

1. Relief is granted provided that the licensee examines, to the ex' tent possible, additional RPV welds, such that the length of total welds examined will equal the length of the individual welds requiring examination.

2. The Section III stress analysis of the piping system should have resulted in hot and cold loads for springs and travel range.for the snubbers. The design of the particular support should have used this design data to pick the appropriate standard support.

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