ML20081E421

TER on Second 10-Yr Interval Inservice Insp Program Plan, Jm Farley Nuclear Power Plant Unit 2

ML20081E421
Person / Time
Site:	Farley
Issue date:	11/30/1990
From:	Beth Brown EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20081E423	List: ML20081E421
References
CON-FIN-D-6022 EGG-MS-8944, NUDOCS 9011130333
Download: ML20081E421 (108)

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EGG MS 8944 I November 1990

- i TECHNICAL EVALUATION REPORT l i

/daho TECHNICAL EVALVATION REPORT ON THE SECOND l Nat/ona/ 10-YEAR INTERVAL INSERVICE INSPECTION  !

PROGRAM PLAN: ALABAMA POWER COMPANY, Eng/neer/ng JOSEPH H. FARLEf NUCLEAR POWER PLANT, UNIT 2, Laboratory l DOCKET NUMBER 50-364 l

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1ECHNICAL EVALVATION REPORT ON THE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

ALABAMA POWER COMPANY,'

JOSEPH M. FARLEY NUCLEAR POWER PLANT, UNIT 2, DOCKET NUMBER 50-364 e

B. W. Prown J. D. Mudlin Published November 1990 Idiho National Engineering Laboratory EC&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for:

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 under DOE Contract No. DE-AC07-761D01570

FIN No. D6022 (Project 5) 1

ABSTRACT This report presents the results of the evaluation of the Joseph H. Farley Nuclear Power Plant. Unit 2, Second 10-Year Interval inservice Inspection (ISI) Program, through Revision 1, submitted August 15, 1990, including the l requests for relief from the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical. The Joseph H. Earley Nuclear Power Plant, Unit 2, Second 10 Year Interval ISI Program is evaluated in Section 2 of i this report. The ISI Program is evaluated for (a) compliance with the )

appropriate edition / addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI-related commitments identified during the previous Nuclear Regulatory Commission reviews. The requests for relief are evaluated in Section 3 of this report.

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This work was funded under:

U.S. Nuclear Regulatory Commission FIN-No. D6022, Project S Operating Reactor Licensing Issues Program, Review of ISI for ASME Code Class 1, 2, and 3 Components 11

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SUMMARY

The Licensee, Alabama Power Company, has prepared the Joseph H. Farley l Nuclear Power Plant, Unit 2, Second 10-Year Interval Inservice Inspection (ISI) Program, through Revision 1, to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examination for Code Class 1 and Code Class 2 piping welds has been determined by the 1974 Edition through Summer.1975 Addenda as permitted and required by 10 CFR 50.55a(b). This program (including relief requests) l was submitted pursuant to the NRC's August 31, 1988 exemption which i permitted revision of the Unit 2 ISI Program to coincide with the Code of record and updated schedule currently used for Unit 1. In accordance with this exemption, the updated program was implemented during the Unit 2 sixth refueling outage which began on March 24, 1989. The ISI Program applies to the third period of the first interval as well as to the first and second periods of the second interval.

The information in the Joseph M. Farley Nuclear Power Plant Unit 2, Second 10-Year Interval ISI Program, Revision 0, submitted March 23, 1989, was reviewed, included in the review were the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical. As a result of this review, a request for additional information was prepared describing the information and/or clarification required from the Licensee in order to complete the review. The Licensee provided additional information in submittals dated October 5,1989; December 7, 1989; and April 12, 1990. Revision 1 to the ISI Program was submitted in a letter dated August 15, 1990. Corrections to Revision 1 of three relief requests were submitted in a letter dated September 12, 1990.

Based on the review of the documents listed above and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Joseph M. Farley Nuclear Power Plant, Unit 2. Second 10-Year Interval ISI Program, through Revision 1, is considered unacceptable and not in compliance with 10 CFR 50.55a(g)(4) due to an unacceptable examination sample ar.d i unacceptable application of the exclusion criteria (see Sections 2.2.2 and iii

2.2.3 of this report). It is recommended that relief be granted with conditions for Requests for Relief RR-15, RR-16, and RR-17. For Requests for Relief RR-4 (in part), RR 29, and RR-33 (in part), it is recommended that relief be denied. Requests for Relief RR 6, RR-24, RR-41, RR-42, and  ;

RR-45 either have been withdrawn or are not included in the scope of this document. i l

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CONTENTS ABSTRACT .............................................................. it

SUMMARY

............................................................... 111

-1. INTRODUCTION ...................................................... I

2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN ................... 4 2.1 Do c ume n t s E v a l u a t e d . . . . . . . . . . . . . . . . . . . . . . /. . . . . . . . . . . . . . . . . . . . . 4 2.2 Compliance with Code Requirements .............................. 5

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2.2.1 Compl iance with Applicabl e Code Editions . . . . . . . . . . . . . . . . . . . 5 2.2.2 ' Acceptability of the' Examination Sample ....................

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2.2.3 Exclusion Criteria .........................................- 6 2.2.4 Augmented Examination Commitments .......................... 7 1

2.3 Conclusions ................................................. . 8  ;

3. EVALUATION OF RELIEF REQUESTS ..................................... 9 3.1 Class 1 Components ............................................. 9 3.1.1 Reactor Pressure Vessel .................................... 9 3.1.1.1 Request for Relief No. RR-8, Examination Category B-A, item Bl.22, Reactor Pressure vessel Lower Head Meridional Weld ..................... 9  ;

3.1.1.2 Request for Relief No. P9-14 Examination Category B-G-1, Item B6.40, Threads-in the  :

, Reactor Pressure Vessel Flange ........................ 9

- i 3.1.2 Pressurizer ................................................ 11 3.1.2.1 Request for Relief No. RR-9, Examination

] Category B-D, Item B3.110, Pressurizer Nozzl e-to-Ves sel Wel d s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 3.1.3 Heat Exchangers and Steam Generators ....................... 13-

'3.1.3.1- Request for Relief No. RR-10 -Examination-  !

2 Category B F, Item B5.70, Steam Generator

Nozzle-to-Pipe Safe End Welds ......................... 13 1

3.1.3.2 Request for Relief No.- RR-ll, Examination Category B-D, Item B3.140, Steam Generator Inlet and Outlet Nozzle Inner Radius Sections ......... 15 a

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3.1.4 Piping Pressure Boundary ................................... 17 3.1.4.1 Request for Relief No. RR-13. Examination Category B-J, item B9.31, Class 1 Branch Pipe Connection Welds ................................. 17 3.1.5 Pump Pressure Boundary ..................................... 19 3.1.5.1 Request for Relief No. RR-15, Examination Category B L-2, item B12.20, Reactor Coolant Pump Internal Pressure Boundary Surfaces . . . . . . . . . . . . . . 19 3.1.6 Valve Pressure Boundary ................................... 22 3.1.6.1 Request for Relief No RR-16. Examination Category B N-2, Item B12.50, Internal Pressure Boundary Surf aces of Class 1 Valves . . . . . . . . . . . . . . . . . . . 22 3.1.7 General (Noreliefrequests) 3.2 Class 2 Components ................................. . . . . . . . . . . 25 3.2.1 Pressure Vessels ......................................... . 25 3.2.1.1 Request for Relief No. RR-18, Examination Category C-A, Items Cl.20 and Cl.30, Pressure Retaining Welds in the Regenerative Heat Exchanger .... 25 3.2.1.2 Request for Rellaf No. RR-19, Examination Category C-A, l'

Discharge Piping ...................................... 43 3.4.2.9 Request for Relief.No. RR-30, Hydrostatic Test of the Class 2 Portion of the Steam Generators and Associated Piping ................................. 45 3.4.2.10 . Request for Relief No. RR-40. Hydrostatic Test of All Class 2 Branch Pipe Lines from the Volume Control Tank to the First Valve . . . . . . . . . . . . . . . . . . . . . . . 46 i 3.4.2.11 Request 'or Relief No. RR 43, Hydrostatic Test i of Class ? Portions of the RCS Head Vent Lines ........ 48-3.4.3 Class 3 System Pressure Tests .............................. 51 L3.4.3.1 Request for Relief No. RR-31 Visual Examination I for-Leakage of Class 3 Service Water Pumps During ,

System Pressure: Tests ................................. 51 3.4.3.2- Request for Relief No. RR-32,'VT-2 Visual Examination of Class 3 Piping Encased in Concrete in the Spent Fuel Pool Cooling System . . . . . . . . . . . . . . . . . 52 L

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3.4.3.3 Request for Relief No. RR-33, Hydrostatic Tests of Portions of Class 3 Piping and Components in Service Water, Spent fuel Pool Cooling, Component Cooling Water, Chemical and Volume Control, and Reactor Makeup Systems ................................ 54 3.4.3.4 Request for Relief No. RR-34 Hydrostatic Test of Class 3 Spray Additive Piping and Components in the Containment Spray System ....................... 57 3.4.3.5 Request for Relief No. RR 35, Hydrostatic Test of Class 3 Portions of Buried Pipihg in the Service Water System .................................. 59 3.4.3.6 Request for Relief No RR-36, VT-2 Visual Examination of Heat Exchanger Tubes of Class 3 Pressure Retaining Safety Related Heat Exchangers ..... 61 3.4.3.7 Request for Relief No. RR-37, VT-2 Visual Examinatten of the Cooling coils for Class 3 Pressure Retaining Safety Related Coolers ............. 63 3.4.3.8 Request for Relief No. RR-38, Hydrostatic Test of Class 3 Piping of the Auxiliary Steam System ....... 66 3.4.3.9 Request for Relief No. RR-39 Hydrostatic Test of Class 3 Auxiliary Feedwater Pump Minimum Flow Piping ................................................ 67 3.4.3.10 Request for Relief No. RR-44, VT 2 Visual Examination of Heat Exchanger Tubes of Class 3 Pressure Retaining Safety Related Hett Exchangers ..... 69 3.4.4 General .................................................... 71 3.4.4.1 Request for Relief No. RR 45, Hydrostatic Test of Class 2 and Class 3 Low Pressure Systems . . . . . . . . . . . 71 3.4.4.2 Request for Relief No. RR-46, Scheduling of Class 2 and Class 3 System flydrostatic Pressure Tests . . . . . . . . . 71 3.5 General ........................................................ 73 3.5.1 Ultrasonic Examination Techniques .......................... 73 3.5.1.1 Request for Relief No. RR-1, Material Requirements for Calibration Blocks ................... 73 3.5.1.2 Request for Relief No. RR-2, Specific Dimensional Requirements for Calibration Blocks . . . . . . . . . . . . . . . . . . . 77 3.5.1.3 Request for Relief No. RR-3, Specific Dimensional Requirements for Calibration Blocks . . . . . . . . . . . . . . . . . . . 78 viii

3.5.1.4 Request for Relief No. RR 4, Wall Thickness Differences Between Calibration Blocks and Components to be Examined ............................. 80 3.5.1.5 Request for Relief No RR 5, Curvature Differences Between Calibration Blocks and Components to be Examined ............................. 84 3.5.1.6 Request for Relief No. RR-6, Materials for Fabrication of Calibration Blos . 3nd Acoustic Compatibility with the Component t,o be Examined ....... 87 3.5.1.7 Request for Relief No. RR-7, Dimensional Requirements for Calibration Notches Placed in Ultrasonic Calibration Blocks ...................... 88 3.5.2 Exempted Components (No relief requests) 3.5.3 Other ...................................................... 89 3.5.3.1 Request for Relief No. RR-12, Delete VT-4 Visual Examination Method and Examination Requirement and Redefine VT-3 Visual Examination Method in Accordance With Paragraph IWA-2213 of the 1986 Edition of the Code .......................... 89 3.5.3.2 Request for Relief No. RR-17, Reference System for All Welds and Areas Subject to Surface or Volumetric Examination ................................ 91 3.5.3.3 Request for Relief No RR-41, Break Away Drag Test for Hydraulic Snubbers ........................... 93 3.5.3.4 Request for Relief No. RR-42, Additional Sample Testing Requirements for Snubbers ..................... 93

4. CONCLUSION ........................................................ 94

5. REFERENCES ........................................................ 96 L

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l TECHNICAL EVALUATION REPORT ON THE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

ALABAMA POWER COMPANY, JOSEPH M. FARLEY NUCLEAR POWER PLANT, UNIT 2, DOCKET NUMBER 50-364

1. INTRODUCTION Throughout the service life of a water cooled nucl, ear power facility, 10 CFR 50.55a(g)(4) (Reference 1) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," (Reference 2) to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requirer that inservice examinations of compenants and system pressure tests conducted during successive 120 month inspection intervals shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120 month inspection interval, subject to the limitations and modifications listed therein. The components (including supports) may meet. requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modi!ications listed therein. The Licensee, Alabama Power Company, has prepared the Joseph M.

Farley Nuclear Power Plant, Unit 2, Second 10-Year Interval Inservice Inspection (ISI) Program, through Revision 1, to meet the requirements of the 1383 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examination for Code Class 1 and Code Class 2 piping welds has been determined by the 1914 Edition, Summer 1975 Addenda as permitted and required by 10 CTR 50.55a(b). This program (including rel!ef requests) was submitted pursuant +.o the fiRC"s August 31, 1988 exemption (Reference 3) which permitted re*/ision of the Unit 2 ISI Program to coincide with the Code of record and updated schedule currently used for Unit 1. In accordance with this exemptiun, the updated program was implemented during 1

the Unit 2 sixth refueling outage which began on March 24, 1989. The IS:

Prcgram applies to the third period of the first interval as well as to the first and second periods of the second '.afa 1.

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requiremants are impractical and requests relief from them, the licensee shall submit information and justifications to the Nuclear Regulatory Commission (NRC) to support that determination.

Pursuant to 10 CFR 50.55a(g)(6), the NRC will evaluate the licensee's ceterminations under 10 CFR 50.S5a(g)(5) that Code requirements are impractical; alternatively, pursuant to 10 CFR 50.55a(a)(3), the licensee must demonstrate that either (1) the proposed alternatives would provide an acceptable level of quality and safety or that (ii) code compliance would resalt in hardship or unusual difficulties without a compensating increase in the level of quality and safety. The NRC may grant relief and may impose alternttive requirements that are determined to be authorized by law, will not er.6 anger life or property or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

The information in the Joseph M. Farley Nuclear Power Plant, Unit 2, Second 10-Year Interval ISI Program, Revision 0 (Reference 4), submitted March 23, 1989, was reviewed, including the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical . The review of the ISI Program was performed using the Standarn Review Plans of NUREG-0800 (Reference 5), Section 5.2.4, " Reactor Coolant Coundary Inservice Inspections and iesting,' and Section 6.6, " Inservice Inspection of Class 2 ar,' 3 Components."

In a letter dated August 3,1989 (Reference 6), the NRC requested additional information that was required in order to complete the review of the ISI Program. The requested information was provided by the Licensee in letters dated October 5, 1989 (Reference 7), December 7, 1989 (Reference 8), and April 12, 1990 (Reference 9). Revision I to the ISI Program was submitted 2

,o ..a in a letter dated August 15, 1990 (Reference 10). Corrections to P.evision 1 of three relief requests were submitted in a letter dated September 12, 1990 (Reference 11).

The Joseph M. Farley Nuclear Power Plant, Unit 2, Second 10-Year Interval ISI Program is evaluated in'Section 2 of this report. The ISI Program is evaluated for (a) compliance with the appropriate edition /eddenda of Section XI, (b) acceptability of examination sample, is correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI-related commitments identified during the prev)*,us NRC reviews.

The requests for relief are evaluated in Section 3 of this report. Unless otherwise stated, references to the Code refer to the ASME Code,Section XI, 1983 Edition, including Addenda through Summer 1983. Specific inservice test (IST) programs for pumps and valves are being evaluated in other reports.

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2. EVALVATION OF INSERVICE INSPECTION PROGRAM PLAN This evaluation consisted of a review of the applicable program documents to determine whether or not they are in compliance with the Code requirements

.and any license conditions pertinent to ISI activities. This section describes the submittals reviewed and the results of the review.

2.1 Documents Evaluatcd .

Review has been completed on the following information:

(a) Joseph M. Farley Nuclear Power Plant, Unit 2, Second 10-Year Interval ISI Program, Revision 0, submitted March 23, 1989.

(b) NRC Inspection Report Nos. 50-348/88-17 and 50 364/88-17, dated June 1, 1988 (Reference 12).

(c) Letter, dated June 22, 1988, request for exemption from requirements of 10 CFR 50.55a(g)(4)(ii) (Reference 13).

(d) Letter, dated August 31, 1988, exemption from certain requirements of 10 CFR 50.55a(g)(4)(ii) (Reference 14).

(e) Letter, dated December 15, 1988, updated ISI program for ASME Code Class 1, 2, and 3 components (Reference 15).

l (f) Letter, dated February 8,1989, list of relief requests for Unit 2

refueling outage (Reference 16).

(g) Letter, dated March 23, 1989, updated inservice inspection program

for ASME Code Class 1, 2, and 3 components (Reference 17).

l (h) Letter, dated March 31, 1989, interim approval of ISI Program for l

Unit 2 (Reference 18).

(i)-Letter, dated June 8, 1989, updated inservice inspection program for ASME Code Class 1, 2, and 3 components (Reference 19).

(j) Letter, dated September 21, 1989, schedule extension for submittal I of response to the NRC request for additional _information I

(Reference 20).

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(k) Letter, dated October 5,1989, partial response to the NRC request l for additional information.

(1) letter, dated November 30, 1989, schedule for submitting the remaining response to the NRC request for additional information '

(Reference 21).

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(m) Letter, dated December 7, 1989, respcnse to the NRC request for additional information.

(n) Letter, dated April 12, 1990, additional information with regard to the ISI Program and relief requests.

(o) Letter, dated August 15, 1990, Revision 1 to the ISI Program.

(p) Letter, dated September 12, 1990, corrections to Revision 1 of three relief requests.

2.2 Compliance with Code Recuirements 2.2.1 Compliance with Apolicable Code Fditions The Inservice Inspection Program shall be based on the Code editions defined in 10 CFR 50.55a(g)(4) and 10 CFR 50.55a(b).

Based on the starting date of December 1,1987, the Code applicable to the second 10-year interval is the 1983 Edition, Summer 1983 Addenda. As stated in Section 1 of this report, the Licensee has prepared the Joseph M. Farley Nuclear Power Plant, Unit 2, Second 10-Year Interval ISI Program, through Revision 1, to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examination for Code Class 1 and Code Class 2 piping welds has been determined by the 1974 Edition, Summer 1975 Addenda as permitted and required by 10 CFR 50.55a(b). This program (including relief requests) was submitted pursuant to the NRC's August 31, 1988 exemption which permitted revision of the Unit 2 ISI Program to coincide with the Code of record and updated schedule currently used for Unit 1. In accordance with this exemption, the updated program was implemented during the Unit 2 sixth refueling outage which began on March 24, 1989. The ISI Program applies to the third period of the first interval as well as to the first and second periods of the second interval.

2.2.2 Acceptability of the Examination Samole Inservice volumetric, surface, and visual examinations shall be performed on ASME Code Class 1, 2, and 3 components and their 5

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supports using sampling schedules described in Section XI of the ASMECodeand10CFR50.55a(b). 10CFR50.55a(b)(3)(iv)(A) states that " Appropriate Code Class 2 pipe welds in Residual Heat Removal Systems, Emergency Core Cooling Systems and Containment Heat Removal Systems shall be examined." The Licensee should be required to increase the number of volumetric examinations of Class 2 piping welds in the RHR, ECC, and CHR systems as only six Class 2 piping welds in these systems are scheduled for volumetric examination during the second 10-year inspection interval. This is not considered to be a prudent sample size for volumetric examination.

The Licensee should also be required to perform examinations of a sampling of the Class 2 piping welds in the Containment Spray System because these lines contain stagnant borated water and n y be susceptible to intergranular stress corrosion cr3cking. Ot e similar plants are performing augmented volumetric examinations of at least a 7.5% sampling of the welds in a single train between the Containment Spray pump and the first weld beyond the isolation valve inside containment.

2.2.3 Exclusion Criteria The criteria used to exclude components from examination shall be consistent with Paragraphs IWB-1220, IWC-1220, IWC-1230, IWD-1220, and 10 CFR 50.55a(b). The exclusion criteria have been applied by the Licensee in accordance with the Code as discussed in the ISI Program and appear to be correct with the following exceptions:

(a) The Licensee should not be permitted to use the " chemistry control" exemption in Paragraph IWC-1220(c) of the 1974 Edition, Summer 1975 Adenda of Section XI. Other plants are not using this exemption as the control of water chemistry to minimize stress corrosion 1s not an acceptable basis for exempting components from examination because practical evaluation, review, and acceptance standards cannot be 6

defined. Operating data indicate that " chemistry control" has not supported the exclusion; therefore, later editions and addenda of the Code have deleted the chemistry control exclusion.

(b) A significant number of Class 2 welds in ECC, CHR, and RHR systems (e.g., Safety Injection System) have been exempted based on the pressure / temperature exemption in Paragraph IWC-1220(s) of the 1974 Edition, Summer 1975 Addenda of Section XI. As noted above, 10 CFR 50.55a(b)(3)(iv)(A) states that " Appropriate Code Class 2 pipe welds in Residual Heat Removal Systems, Emergency Core Cooling Systems and Containment Heat Removal Systems shall be examined." The Licensee should not exempt the ECC, CHR, and RHR systems from volumetric and surface examinations based on the pressure / temperature exemption. As shown in later editions and addenda of the ASME Code Section XI and the NRC approved ASME Code Case N-408, the pressure / temperature exemption is not allowed for the ECC, CHR, and RHR systems.

2.2.4 Auamented Examination Commitments In addition to the requirements as specified in Section XI of the ASME Code, the Licensee has committed to perform the following augmented examinations:

(a) Reactor vessel examinations will be performed in accordance with NRC Regulatory Guide 1.150, Revision 1 (Reference 22).

(b) The reactor coolant pump flywheel will be inspected in accordance with plant Technical Specification 4.4.11.2 and NRC Regulatory Guide 1.14 (Reference 23).

(c) The steam generator tubing will be inspected in accordance with plant Technical Specification 4.4.6 and NRC Regulatory Guide 1.83, Revision 1 (Reference 24).

(d) Augmented examinations of portions of high energy lines in the Main Steam System will be performed.

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2.3 Conclusions ,

Based on the review of the documents listed above, it is concluded that the Joseph M. Farley Nuclear Power Plant, Unit 2 Second 10-Year ,

Interval Inservice Inspection Program, through Revision 1, is considered unacceptable and not in compliance with 10 CFR 50.55a(g)(4) due to an unacceptable examination sample and unacceptable application of the exclusion criteria (see Sections 2.2.2 and 2.2.3 of this report).

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3. EVALVATION OF REllEF REQUESTS The requests for relief from the ASME Code requirements that the Licensee has determined to be impractical for the second 10-year inspection interval are evaluated in the following sections.

3.1 Class 1 Components 3.1.1 Reactor Pressure Vessel 3.1.1.1 Recuest for Relief No. RR-8. Examination Cateoory B-A.

Item B1.22. Reactor Pressure Vessel Lower Head Meridional Weld NOTE: The corresponding Request for delief No. RR-8 for Farley, Unit 1, is not applicable to Farley, Unit 2.

3.1.1.2 Reauest for Relief No. RR-14. Examination Cateaory B-G 1.

Item BE.40. Threads in the Reactor Pressure Vessel Flance Code Reauirement: Section XI, Table IWB-2500-1, Examination Categorf B-G-1, item B6.40 requires a 100% volumetric examination of the threads in the RPV flange as defined by Figure IWB-2500-12.

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

! performing the Code-required voiumetric examination of the

[ threads in the flange ligaments around each guide stud (Numbers 26, 42, and 58) as well as the threads in the flange ligaments l between the stud holes on either side of the guide studs (Numbers 1, 25, 27, 41, 43, and 57).

Licensee's Proposed Alternative Examination: None. The Licensee states that the threads in the remaining 49 flange i ligaments will be ultrasonically examined as required by the ASME Code.

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- Licensee's Basis fgn Reguestino Relief: The Licensee states

' that, during the examination,-these guide studs-prevent the ultrasonic transducers mounted on the remote tool-arm from

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accessing the. threads in the _ flange ligaments around each guide

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- stud as well as the threads in the' flange ligaments between the stud holes on either side of the guide studs.

Evaluation: To facilitate safe removal and reinsta11ation of the RPV head and positioning of the remote RPV examination tool, three guide studs are installed in stud holes. During the ultrasonic examination performed by the remote tool, the-guide studs prevent the ultrasonic transducers mounted on the remote tool arm from accessing the threads in the flange ligaments around.each guide stud as well as the threads in the flange _ ligaments between the stud holes on either side of the--

guide studs. The presence of the three guide studs, therefore, makes the Code-required examination impractical to perform using the remote inspection tool. In order to examine the subject threads in the RPV flange in accordance with:the requirements, manual ultrasonic: examination would be required which would result-in personnel receiving excessive radiation exposure. The increase in plant safety would not compensate for the burder, placed on the Licensee that would result from imposition of the requirenent.

Alabama Power has stated that the remote ultrasonic inspection tool will examine the remaining 49. (84.5%) out of the 58 threads in the flar.ge. - Alabama Power. Company's proposal is-to

- perform ultrasonic examination cf the remaining 49 threads in the RPV flange using the remote RPV examination tool. This examination will provide adequate assurance that the flange threads have not developed unallowable inservice flaws or that unallowable inservice flaws will be detected and removed or repaired prior to the return of the reactor vessel to service, 10 ec mi=,-, y- w ww e - w n-* v r e, n -y - ~,p-ww.%,,, e,

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Conclusiani.

The volumetric examination of the threads in the reactor-_ vessel flange is _ impractical to perform at Farley,

-Unit 2,:to the extent required by Section XI of the ASME Code because of the presence of three guide studs. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that-provided by the proposed examination. The proposed examination will provide assurance that structural '

integrity of the reactor vessel flange -is maintained.

Therefore', it is concluded that public health and safety _ will not be endangered by allowing the proposed examination to be performed in lieu of the Code requirements. It is recommended that relief be granted-as requested.

3.1.2 Pressurizer I 3.1.2.1 Reauest for Relief No. RR-9. Examination Cateaory B-D. Item B3.110. Pressurizer Nozzle-to-Vessel Weldi-Code Reauirement: -Section XI, Table IWB-2500-1,- Examination Category B-0, Item B3.110 requires a 100% volumetric examination of the pressurizer nozzle-to-vessel welds as j

' defined by Figure IWB-2500-7(b).

Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume of the pressurizer 4 nozzle-to-vessel welds, licensee's Proposed Alternative Examination: The Licensee

-i' states that- all of these welds will receive a surface examination of the areas not receiving an ultrasonic examination.

Licensee's Basis for Reauestina Relief: There is unrestricted access to perform examination of the required volume of both L

11 j L

.- - - - - -. - .-. - . - ~.. -~ - - . - - . - -

46 - ...

weld and base _ metal ~ from the head side of these welds; however, the Licensee states that the geometric configuration of all six nozzies prevents ultrasonic examination from the nozzle sido of r

the weld to the extent required. While the required volume of weld metal can be examined, only approximately 25% of the base metal on the nozzle side of. the weld _can be examined.- >

Evaluation: The. sketch-included in the Licensee's relief request'shows that the geometric configuration of the pressurizer nozzles is such that the pressurizer nozzle-to-vessel welds cannot be examined 100%. The pressurizer nozzle design, therefore, makes the Code-required examination impractical to perform. In order to examine the welds in accordance with the requirements, the pressurizer nozzles, and thus the pressurizer, would-have to be-redesigned, fabricated, and installed. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

The Licensee has stated that all of the weld volume, the base metal on the vessel side of the weld, and approximately 25% of the base _ metal on the nozzle side of the weld are' unrestricted; therefore, a significant percentage of the weld and-base metal  ;

would be examined. The Licensee's proposed alternative is to-

-perform the ultrasonic examination of the weld to_the maximum:

extent-practical and a_ surface examination.of the areas not receiving an ultrasonic examination. These examinations will ,

provide adequate assurance that the pressurizer nozzle-to-vessel welds have not developed unallowable inservice  !

flaws or that unallowable inservice flaws will be detected'and removed or repaired prior to the return of the pressurizer to ,

service.

1

[gnslusions: The volumetric examination of the - j nozzle-to-vessel welds in the pressurizer is impractical to j perform at Farley, Unit 2, to the extent required by Section XI j i

i F

12 I

w ..

of the ASME Code because of the geometric configuration of the nozzles. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative examination will provide assurance that structural integrity of the pressurizer is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirements. It is recommended that relief be granted as requested.

3.1.3 Heat Exchanaers and Steam Generators 3.1.3.1 Recuest for Relief No, RR-10. Examination Cateoory B-F. Item 85.70. Steam Generator Nozzle-to-Pioe Safe End Welds Code Reauirement: Section XI, Table IWB-2500-1, Examination Category B-F, Item 85.70 requires both 100% volumetric and surface examinations of the steam generator nozzle-to-safe end butt welds nominal pipe size 4 inches and greater as defined by Figure IWB-2500-8.

Licensee's Cooe Relief Reauest: Relief is requested from examining 100% of the Code-required volume of the steam generator nozzle-to-safe end welds.

Licensee's Proposed Alternative Examination: None. The Licensee states that surface examinations of the required area will be performed. Alsc, ultrasonic examinations will be performed from both the pipe and weld surfaces as allowed by T-532 of Section V. All of the weld metal, including the weld root, will be examined.

13

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

L ' ou -

L - .

i-ticensee's Basis'for Reouestino Relief: The Licensee states  !

D

, that examination of these welds:is limited both by nozzle  !

geometry and the _ presence of a weld-deposited clad overlayfon. >

the safe end nozzle interface - Ultrasonic examinations ~can be I performed!from-the pipe side'and the weld-surface but are i

[ _ severely limited from the nozzle side by the rough,-as-cast .

surface and the. clad overlay.- Coverage of approximately 90% of '!

the required volume is achieved from.the. pipe side of the weld. '$

Evaluation

The sketch included in the Licensee's relief

request shows that the nozzle geometry and the presence of the ,

. as-welded clad overlay at the nozzle to-safe end interface are such-that the volume of the steam generator nozzle-to-safe end  !

- welds cannot be: examined 100%. The steam generator nozzle  ;

design, therefore, makes the Code-required examination '

impractical _ to perform. In order to examine the nozzle-to-safe l end welds in accordance with the requirements, the steam 2

generator nozzles, and thus the steam generators, wouldLhave to  ;

be redesigned, fabricated, and installed._ The increase in -

l ' plant safety-would not compensate for the burden placed on the

- Licensee that;would result from imposition of the requirement.

d The Licensee has stated that the ultrasonic examination would cover all; of the weld metal, including the weld roott coverage of approximately 90% of the required volume is achieved from :

- the pipe-side'of the weld. Alabama. Power Company's proposal is to perform an ultrasonic examination from both the pipe and weld surfaces as allowed by T-532 of Section-V, along with the-Code-required surface examination._ These examinations will provide adequate assurance that unallowable inservice flaws have not developed-in the ste;m generator nozzle-to-safe end welds or that they-will be detected and removed or repaired prior to the return of the steam generators to service.

Conclusions:

The volumetric examination of the steam generator nozzle-to-safe end welds is impractical to perform at Farley, 14

Unit 2, to the extent required by Section XI of the ASME Code because of the geometric configuration of the nozzles and the presence of the as-welded clad overlay at the nozzle-to-safe end interface. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed examination. The proposed examination will provide assurance that structural integrity of the steam generator nozzle-to-safe ends is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the proposed examination to be performed in lieu of the Code requirements. It is recommended that relief be granted as requested.

3.1.3.2 Reauest for Relief No. RR-ll. Examination Cateaory B-D. Item B3.140. Steam Generator Inlet and Outlet Nozzle Inner Radius Sectiont Code Reauirement: Section XI, Table IWB-2500-1, Examination Category B-D, Item B3.140 requires a 100% volumetric examination of the steam generator (primary side) nozzle inside radius sections as defined by Figure IWB-2500-7.

Licensee's Code Relief Reauest: Relief is requested from performing the Code-required volumetric examination of the inlet and outlet nozzle inner radius sections of steam generators 2A, 28, and 2C.

Licensee's Pronosed Alternative Examination: The Licensee states that the inside surface of each steam generator primary side nozzle inner radiused section will be visually examined, lhe examination area will include the inner radius surface

. region shown in Figure IWB-2500-7 of Section XI to the extent practical.

15

-e, ..

Licensee's Basis for Requestina Relief: The Licensee states that the steam generator primary side nozzles are integrally cast as part of the channel head; therefore, no welds exist that require volumetric examination. The steam generator nozzle inner radiused section cannot be volumetrically examined from the outside of the nozzle or channel head because the rough, as-cast contact surface is not suitable for ultrasonic coupling and the geometrical e,nfiguration requires an excessively 1cng test metal disu e resulting in high ultrasonic attenuation. The s.eas inside of the nozzles and channel head are covered with cladding in the "as-welded" condition; therefore, the associated surface contours and roughness do not provide the conditions necessary to perform the examination. Even with proper preparation of the inside surface for volumetric examination, an adequate examination of the area of interest (base metal just below the cladding) could not be achieved due to the resulting ultrasonic response at the clad-to-base metal interface.

Evaluation: The steam generator nozzle sections at Farley, Unit 2, were not designed for external examination of the inside radius using ultrasonic methods. The component geometry and the as-cast surface of the steam generator heads, along with the excessively long test metal distance that results in high ultrasonic attenuation, preclude the volumetric examination of the nozzle inside radius section from the external surface. The steam generator nozzle design, therefcre, makes the Code-required examination impractical to perform. In order to examine the nozzle inside radius sections in accordance with the requirements, the steam generator nozzles, and thus the steam generators, would have to be redesigned, fabricated, and installed. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

Surface examination is not practical to perform because of the l

16

e, .,

rough surface of the as-welded cladding and because inspection personnel would receive excessive radiation exposure.

Alabama Power Company's proposed alternative is to perform a visual examination of the inside surface of each steam generator primary side nozzle inner radiused section to the maximum extent practical. This examination will provide reasonable assurance that the steam generator nozzle inner radius sections have not developed unallowable inservice. flaws or that unallowable inservice flaws will be detected and removed er repaired prior to the return of the steam generators

to service.

Conclusions:

The volumetric examination required by Section XI of the ASME Code for the nozzle inside radius sections in the steam generators is impractical to perform at Farley, Unit 2, because of the component geometry and the as-cast surface of the steam generator heads, along with the exce:sively long test metal distance that results in high ultrasonic attenuation.

Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative examination will provide assurance that structural integrity of the steam generator nozzles is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to De performed in lieu of the Code requirement. It is recommended that relief be granted as requested.

3.1.4 Pioina Pressure Boundary 3.1.4.1 Recuest for Relief No. RR-13. Examination Cateaory B-J. Item B9.31. Class 1 Branch Pioe ronnection Welds Code Reauirement: Section XI, Table IWB-2500-1, Examination Category B-J, Item B9.31 requires both 100% volumetric and 17

oo ..

t l

! surface examinations of the Class 1 branch pipe connection welds nominal pipe size 4 inches and greater as defined by Figures IWB-2500-9, -10, and -11.

Licensee's Code Relief Reouest: Relief is requested from examining 100% of the Code-required volume of the following Class 1 branch pipe connection welds:

Weld Number Conficurations 16BC Hot leg loop #1, 12-inch branch connection 22BC Cold leg loop #1,12-inch branch connection 16BC Hot leg loop #2, 14-inch branch connection 21BC Cold leg loop #2, 12-inch branch connection 16BC Hot leg loop #3,12-inch branch connection 21BC Cold leg loop #3, 12-inch branch connection Licensee's Proposed Alternative Examination: None. The Code required surface examinations will be performed, and the volumetric examination will be performed to the maximum extent

(

possible.

Licensee's Basis for Reouestina Relief: The Licensee states that the geometric configuration of these welds prevents ultrasonic examinations from being performed from the weld surfaces. Approximately 80% of the Code-required volume can and will be examined.

Evaluation: The Class 1 branch pipe connection design is shown in the sketch attached to the Licensee's relief request. The geometric configuration is such that the Code-required volume of the branch pipe connection welds cannot be examined 100%.

The subject Class 1 branch pipe connection design, therefore, makes the Code-required examination impractical to perform. In order to examine the weld in accordance with the requirements, these branch pipe connections would have to be redesigned, fabricated, and installed. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

18

.-, - M

. 1

-The: Licensee has stated that-the ultrasonic examination of the

. . welds would cover approximately 80%_of the Code-required volume:

M of.the~ subject branch pipe connection welds. The Licensee's.

- proposal is to perform the volumetric examination of the welds.

to the' maximum extint practical, along with the Code-required -

i surface examination; These examinations will provide adequate assurance that unallowable inservice flaws have not developed .

in the Class 1 branch pipe connection welds or that they will be detected and removed or repaired prior to the return of these-lines to service.

Conclusions:

The volumetric examination of the _ subject Class l'

-branch pipe connection welds is' impractical to perform at

" Farley, Unit-2' to the extent required by Section XI of the ASME Code because.of the geometric _ configuration of the branch

-pipe connections. Impesition of the requirements-on Alabama Power Company would cause a burden that would not be compensated significantly by an_ increase :in safety above that provided by the proposed _ examination. The proposed: examination:

will provide assurance that structural integrity-of these lines is maintained.. Therefore, it is concluded that public health and safety will not be endangered by allowing the proposed examination to_ be . performed in lieu of the Code requirements.-

-It is recommended that relief be granted as requested, e

-3.1.5 .Pumo Pressure Boundary 3.1.5.1 Recuest for Relief No. RR-15. Examination Cateaory B-L-2. Item B12.20. Reactor Coolant Pumo-Internal Pressure- Boundary Surfaces .

Code-Recuirement: Section XI, Table IWB-2500-1, Examination Category B-1.-2,-Item B12.20 requires a 100% visual (VT-3) examination of the Class 1 pump casing internal surfaces.

l Examinations are limited to Lt least one pump in each group of purps performing similar functions in the system.

I 19

b4 '44 Licensee's Code Relief Reauest: Relief is requested from performing the Code-required visual (VT-3) examination of the internal surfaces of a reactor coolant pump (RCP).

Licensee's Proposed Alternative Examination: None. The Licensee states that the exterior of the RCP casing will be visually examined during the RCS hydrostatic pressure test as required by IWB-5000. A visual examination, not to exceed once per interval, will be performed on the internal pressure boundary surface of one RCP as required by the Code, if maintenance or operational problems are encountered which require the removal and disassembly of the internals.

Licensee's Basis for Reauescino Relief: The Licensee states that disassembly of a reactor coolant pump for the visual examination during the inspection interval in the absence of required maintenance represents an unnecessary exposure to radiation and contamination and violates ALARA guidelines for occupational dose rates. In view of the cost in man-rem and the minimal- benefits obtained, the Licensee cencludes that this Code requirement does not provide sufficient benefits to justify the radiation exposure.

Evaluation: The examination requirement for internal surfaces of pumps necessitates complete disassembly of the pump. The disassembly of the reactor coolant pumps for the sole purpose of visual exaaination of the casing internal surfaces is a major effort and requires many manhours from skilled maintenance and inspection personnel. In order to examine the internal surfaces of a reactor coolant pump in accordance with the requirements, complete disassembly of the pump would be required which, in addition to the possibility of damage to the pump,- would result in personnel receiving excessive radiation exposure. Therefore, the Code requirement is impractical. The visual examination is performed to determine if unanticipated ,

severe degradation of the casing is occurring due to phenomena i

20 i

-s ,.

such as erosion, corrosion, or cracking. Howevur, previous experience during examination of similar pumps at other plants has not shown any significant degradation of pump casings. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

Alabama Power has stated that, in addition to the Code-required visual examination of the exterior of the reactor coolant pump casing during the hydrostatic test, the Code-required visual examination will be performed on the internal pressure boundary surface of one reactor coolant pump if maintenance or operational problems are encountered which require disassembly of the pump such that access for conducting the examination is provided.

Later editions and addenda of the ASME Code (1988 Addenda) have eliminated disassembly of pumps for the sole purpose of performing examinations of the internal surfaces and states that the internal surface visual examination requirement is only applicable to pumps that are disassembled for reasons such as maintenance, repair, or volumetric examination. Therefore, the concept of visual examination of the internal surfaces of the pump casing, if the pump is disassembled for maintenanca, is acceptable. Since no major problems have been reported in the industry with regard to pump casings, the Licensae's proposal will provide adequate assurance of the continued inservice structural integrity.

Conclusions:

The disassembly of a pump for the sole purpose of inspection is impracticai to perform at Farley, Unit 2, because this activity, in addition to the possibility of damage to the pump, would result in personnel receiving excessive radiation 4

exposure. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by 21

Ao %v the proposed examination. Therefore, it is concluded that public health and safety will not be endangered by allowing the proposed examination to be performed in lieu of the Code requirement. It is recommended that relief be granted provided that, if the pump has not been disassembled, this fact should be reported by the Licensee in the ISI Summary Report at the end of the interval.

3.1.6 Valve Pressure Boundary 3.1.6.1 Recuest for Relief No. RR-16. Examination Cateaory B-M-2. Item B12,50. Internal Pressure Boundary Surfaces of Class 1 Valves Code Reauiremeat: Section XI, Table IWB-2500-1, Examination Category B-M-2, Item B12.50 requires a 100% visual (VT-3) examination of the internal surfaces of Class 1 valve bodies exceeding 4 inches nominal pipe size.

Licensee's Code Relief Reauest: Relief is requested from performing the Code-required visual (VT-3) examination of the internal surfaces of one valve in each of the following groups of Class 1-valves:

Group No, Manufacturer System Description 1 Copes-Vulcan RHR 12-inch gate valve 2 Velan RHR (Low head 6-inch check valve safety injection) 3 Velan RHR (High head 6-inch check valve safety injection) 4 Crosby Pressurizer safety 6-inch safety valve 5 Copes-Vulcan Accumulator discharge 12-inch check valve Licensee's Proposed Alternative Examination: None. The

, Licensee states that the exterior of the valve body will be visually examined during the RCS hydrostatic test. A visual -

examination, not to exceed once per interval, will be performed on the internal-pressure boundary surface of one valve in each 22

7

-e .o group listed above as required by the Code if maintenance or  ;

operational problems-are encountered which require disassembly j and complete removal of the valve internals, s censee's Basis for Regmtina Relief: The Licensee states that disassembly of these valves for visual examination during the inspection interval in the absence of required maintenance represents an uns cessary exposure to radiation and .)

contamination and violates ALARA guidelines for occupational dose rates. In view of tne cost in man-rem and the minimal benefits obtained the Licensee' concludes that this Code l requirement does not provide sufficient benefits to justify the l radiation exposure. In addition, the-ranufacturer of these i valves nither recommends nor requir' valve disassembly for the performance of routine mair .....ce or inspections.

4 Evaluation: The examination requirement for internal- surfaces of valve bodies necessitates complete disassembly of the valve. The disassembly of the subject valves for the sole -

purpose of visual examination of the. valve body internal surfaces is a major effort and. requires many manhours from ski _11ed maintenance and inspection personnel. In order to examine the-internal surfaces of a valve body _in'accordance with the requirements, complete disassembly of the valve would

~

be required which, in addition to the possibility of damage to the valve, would result in personnel receiving excessive radiation exposure.- Therefore, the Code requirement is

. impractical. The visual examination is performed to determine if unanticipated severe degradation of the valve body is occurring-due to phenomena such as erosion, corrosion, or cracking.. However, previous experience during examination of L similar valves at other plants has not shown any significant j degradation-of valve bodies. The increase in plant safety L

would not-compensate for the burden placed on the Licensee that L would result from imposition of the requirement.

t l 23 ,

l

.. .s Alabama Power has stated that, in addition to the Code-required visual examination of the exterior of the valve body during the hydrostatic test, the Code-required visual examination will be performed on the internal pressure boundary surface _of one valve in each of the groups of valves listed above if maintenance or operational problems are encountered which require disassembly of the valve such that access for conducting the examination is provided.

Later editions and addenda of the ASME Code (1988 Addenda) have eliminated disassembly of valves for the sole purpose of performing examinations of the internal surfaces and states that the internal surface visual examination requirement is only applicable to valves that are disassembled for reasons such as maintenance, repair, or volumetric examination. ,

Therefore, the concept of visual examination of the internal surfaces of the valve body, if the valve is disassembled for maintenance, is acceptable. Since no major problems have been reported in the industry with regard to valve bodies, the Licensee's proposal will provide adequate assurance of the continued inservice structural integrity.

Conclusions:

The disassembly of a valve for the sole purpose of inspection is impractical to perform at Farley, Unit 2, because this activity, in addition to the possibility of damage to the valve, would result in personnel receiving excessive radiation exposure. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed examination. Therefore, it is concluded that public health and safety will not be endangered by allowing the proposed examination to be performed in lieu of the Code requirement. It is recommended that relief be granted provided that, if the valve has not been disassembled, this fact should be reported by the Licensee in the ISI Summary

. Report at the end of-the interval.

l l l l 24

s. .,

3.1.7 General (No relief _ requests) 3.2 Class 2 Comoonents 3.2.1 Pressure Vessels 3.2.1.1 Reauest for Relief No. RR-18. Examination Cateaory C-A. Items C1.20 and C1.30. Pressure Retainina Welds in the Reaenerative Heat Exchanaer Code Reouirement: Section XI, Table IWB-2500-1, Examination Category C-A, Items C1.20 and C1.30 require a 100% volumetric examination of the head-to-shell weld and tubesheet-to-shell weld in Class 2 pressure vessels as defined by Figures IWC-2500-1 and -2.

Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume of the regenerative heat exchanger welds 1 through 12.

Licensee's Proposed Alternative Examination: The Licensee states that ultrasonic examination will be performed to the meximum extent practical (approximately 50 to 60%) on a best effort basis. Surface examination will also be performed to supplement the volumetric examinations.

Licensee's Basis for Reauestino Relief: The Licensee states that the regenerative heat exchanger shell is fabricated from centrifugally cast austenitic steel material, which limits ultrasonic examination to the half-node technique. In addition, the geometric configuration of the weld surface and the location of adjacent nozzles and supports provide l

limitations to the extent of the examination coverage.

l Approximately 50 to 60% of the required volume can be examined.

l 25

+ .c Evaluation:' The regenerative heat exchanger is fabricated from-

! centrifugally cast austenitic steel material. Ultrasonic-examination of this material is limited to the half node technique. Also, the geometric configuration of the weld surface'and the location of adjacent-nozzles'and supports are such that the Code required volume of the subject regenerative heat exchanger' welds cannot be fu11v examined. These conditions, therefore, make the Code. required examination impractical to perform.' In order to-examine the welds in accordance with the requirements, the regenerative heat exchanger would have to be redesigned, fabricated, and installed. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from

imposition of this requirement.

Alabama Power has stated that the approximately 50 to 60% of the Code-required volume can be examined. Alabama Power Company's proposed' alternative is to perform ultrasonic examination of the these welds to the maximum extent practical

f. on a best effort basis, along with a supplemental surface l examination. These examinations will provide adequate-

! assurance that the~ regenerative heat excha'nger welds have not developed. unallowable inservice flaws or that unallowable ir evice flaws will be detected and removed or repaired -prior

to=the return of the regenerative heat cxchanger to service.

Conclusions:

- The volumetric examination of the welds in the ,

' regenerative heat' exchanger'is impractical to perform at Farley, Unit 2, to the' extent required by Section XI of the b ASME Code becau'se of the centrifuga11y cast austenitic steel

! material, the geometric configuration of the weld surface, and--

the location of adjacent nozzles and supports. Imposition of j_ the requirements on Alabama Power Company would cause a burden

! that would'not be compensated significantly by an increase in i safety above that provided by the proposed alternative. The p

i l-l 26

.s .s proposed alternative examination will provide assurance that structural integrity of the regenerative heat exchanger is e maintained.- Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirements, it is recommended that relief be granted as requested.

3.2.1.2 Reouest for Relief No. RR-19. Examination Cateaory C-A. Items C1.10 and C1.20. Class 2 Pressure Vessel Welds Code Reouirement: Section XI, Table IWC-2500-1, Examination Category C-A, Items C1.10 and C1.20 require a 100% volumetric examination of the shell circumferential welds and head-to-shell circumferential welds in Class 2 pressure vessels as defined by Figure IWC-2500-1.

Licensee's Code Relief Reouest: Relief is requested from performing the-Code-required volumetric. examination of the head-to-shell and flange-to-shell welds in the following thin wall Class 2 pressure vessels:

Seal Water Heat Exchanger Letdown Reheat Heat Exchanger Reactor Coolant Filter Seal Water Return Filter Licensee's Proposed Alternative Examination: The Licensee states that the welds on these components will be examined by surface and visual methods.

Licensee's Basis for Reonestina Relief: The Licensee states that the thickness of the materials utilized for the construction of these components (0.165 to 0.188 inches) is such that meaningful results could not be expected with ultrasonic examination.

4 27

Evaluation: Alabama Power Company's proposed alternative is to perform surface and visual examinations of the welds on these vessels in lieu of the Code-required volumetric examination.

It is-stated in ASME Code Case N-435-1, " Alternative Examination Requirements for Vesse'is With Wall Thickness 2 Inch or Less," that, for welds in vessels with nominal wall thickness of 1/5 inch or less, surface examination may be applied in lien of volumetric examination. Code Case N-435-1 is listed as an acceptable code case in NRC Regulatory Guide 1.147, " Inservice Inspectioa Code Case Acceptability, ASME Section XI, Division 1," Revision 7 (Reference 17), and, therefore, may be used without requesting relief.

Conclue.inni: The Licensee's proposed examination is an accept.ible alternative based on ASME Code Case N-435-1 and NRC Regulatory Guide 1.147. Therefore, relief is not required.

3.2.1.3 Recuest for Relief No. RR-28. Examination Cateoory C-B. Item C2.22. Class 2 Steam Generator Nozzle inside Radius Sections

[ ode Recut ement: Section XI, Table IWC-2500-1, Examination Category C-B, Item C2.22 requires a 100% volumetric examination of the nozzle inside radius sections of nozzles in Class 2 vessels of 1/2 inch or less nominal wall thickness as defined by Figure IWC-2500-4(a) or (b).

Licensee's Code Relief Reauest: Relief is requested from performing the Code-required volumetric examination of the nozzle inside radius section of the steam cutlet nozzle on the steam generators.

Licensee's Proposed Alternative Examination: None.

Licensee's Basis for Reauestino Relief: The Licensee states that the steam outlet nozzle is manufactured from a solid l 1

28 l

no ....

forging with seven holes, _each _81/2 inches in diameter,

' drilled through the forging to provide flow' restriction. The

. geometry of this nozzle with the drilled. flow restrictor holes does not have an inner radius and, therefore, no mer.ningful-examination can be performed.

. Evaluation

- As;shown in the sketch attached to the relief

[ request, the steam outlet nozzle was designed with an internal

] multiple hole _ type flow restrictor. This design does not use a j radiused nozzle as described in Figure IWC-2500-4, but:instead 4

has several individual inner radii, corresponding to each hole. Therefore, the design of the nozzle is not applicable to 5

the Code requirement. Alabama Power Company has demonstrated

[ that compliar.ce with this Code requirement would result in I -hardship or unusual difficulties without a compensating

-increase in the level of quality and safety.

1 j:

Conclusions:

Based on the above, it is concluded that the y design of the steam generator nozzle is not applicable to the

! Code requirement. Therefore,pursuantto10CFR50.55a(a)(3),

l- it is recommendec that relief be granted as reque.ted, c ,

1:

l 1 f 3.2.2 Pioina (No relief requests) i  :

I 3.2.3 Pumos j 4

l- 3.2.3.'l- -Reauest for Relief No. RR-20. Examination Cateaory C-C. Item i: C3.30; Class 2 Intearally Welded Attachments on Charaina Pumos

- Code Reauirement

Section X1, Table IWC-2500-1, Examination I

Category C-C, Item C3.30 requires a 100% surface examination of l

~the integrally-welded attechments of Class 2 pumps as defined i by Figure IWC-2500-5.

3 l  !

1 i j

29

i. ;l i-

i Licensee's Cade Relief Reauest: Relief it requested froa  ;

examining 100% of the Code required surface of the integrally welded ' ?,hments Wh 1, 2, 3, and 4 on each of charging pumps 2A, io, and 20.

Ucensee's Prongsed Alternative Examination: Nor'. The i Licensee states that all accessible portions of welded  ;

attachments will receive a surfee examination supplemented by  :

a visual examination. ,

l Licensee's Basis for Recuestina Relief: The Licensee states  !

that, due to the component configuration, location, and support design, approximately 20% of each integrally welded attachment  ;

is inaccessible for examination.

Evaluation: The drawings included in the Licensee's relief  :

riquest show that the component configuration, location, and .

support design are such that the code-required surface of the charging pump integrally welded attachments cannot be fully examined. These conditions, therefore, make the Code-required examination impractical to perform. In order to examine the ch;rging pump integrally welded atthchments in accordance with i the requirements, the pump supports would require design modifications. The increase in plant safety would noi. f compensate for the burden placed on the Licensee that would result from imposition of the requirement. >

The Licensee has stated that the surface examination would cover approximately 80% of the required surface area. Alabama Power Company's proposal is to perform a surface examination of all accessible portions of the welded attachments, along with a ,

supplemcntal visual examination of the uninspected portions. 1 These examinations will provide adequate assurance that ,

unallowable inservice (16ws have not developed in the pump integral attachment welds or that they will be detected and L removed or repaired.  :

{

{

30 >

Conclusions:

The surface examination H tne charging pump integrally welded attachments is impractical to perform at Farley, Unit 2, to the extent required by Section XI of the ASME Code because of the component configuration, location, and support design. Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by '

the proposed examination. The proposed examination will provide assurance that structural integrity of the charging pump integrally welded attachments is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the proposed examination to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested.

3.2.4 Valves (No relief requests) 3.2.5 General (No relief requests) 3.3 Class 3 Coroonents (Noreliefrequests) 3.4 Pressure Tests 3.4.1 Class 1 System Pressure Tests (Noreliefrequests) 3.4.2 Class 2 System Pressure Tests 3.4.2.1 Reauest for Relief No. RR-21. Hydrostatic Test of Class 2 l Containment Pressure Sensina lines in the Safety Iniection System Code Reauirement: Section XI, Table IWC 2500-1, Examination Category C H Item C7.40 requires a hydrostatic test of all +

Class 2 pressure retaining components once every 10 year inspection interval in accordance with IWC-5222.

31 f l

.. .. j i

Licensee's Code Relief Rectuuil: Relief is requested from [

performing the Code required hydrostatic test of the Class 2 l i

containment pressure sensing lines in the safety injection j system.

t Licensee's Pronosed Alternative Examination: The Licensee (

states that the calibration of these sensors will be performed  !

in lieu of a hydrostatic or pressure test.  ;

Licensee's Basis for Reouestino Relief: The Licensee states that these containment pressure sensing capillaries are filled i "ith silicono oil and are sealed. There are no provisions to pressurize these lines with additional silicone oil to satisfy 5 the ASME Section XI hydrostatic test requirements, liowever, a ,

full range (0 to 65 psi for low pressure sensors and 0 to i 225 psi for high pressure sensors) calibration is performed on these lines every 18 months to verify their accuracy and [

integrity, in accordance with Farley Surveillance Test  !

Procedures STP-220.1 through 220.4, STP-220.11, and STP 220.12 l (T.S.4.3.3.8/6B). Any leakage from these pressure sensing {

lines during. normal operation would result in instrument  ;

failure and would be corrected to maintain instrument i operability.

Evaluation: The design of Class 2 containment pressure sensing  ;

lines in the safety injection system is such that the lines are filled with silicone oil and are sealed. There are no ,

provisions to pressurize these lines with additional silicone  !

oil to satisfy the Cude requirements. The design of these lines, therefore, makes the Code required hydrostatic test ['

impractical to perform. In order to perform the hydrostatic test in accordance with the requirements, these lines would  ;

have to be modified to include test connections. The increase in plant safety would not compensate for the burden placed on f the Licensee that would result from imposition of this ,

requirement.  :

i

[

32 [

);

e. ..

The Licensee's proposal to perform the calibration of these sens9rs in lieu of the hydrostatic test will provide reasonable assurance of the continued inservice structural integrity as leakage of these lines would be identified.

Conclusions:

The hydrostatic test required by Section XI of the ASME Code for the Class 2 containment pressure sensing lines in the safety injection system is impractical to perform at Farley, Unit 2, because these lines are filled with silicone oil and are sealed, with no provisions to pressurize these lines with additional silicone oil. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative examination will identify a leak in these pressure sensing lines thus providing assurance that structural integrity of these lines is maintained. Therefore, it is concluded that public health and safety will not be endangered ,

by allowing the alternative examination to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested.

3.4.2.2 Recuest for Relief No. RR-22. Hydrostatic Test of Portions of Class 2 Pipino and Interim Components at Reduced Pressure

[gde Reauirement: Section XI, Table IWC 2500-1, Examination Category C H requires a hydrostatic test of all Class 2 pressure retaining components once every 10-year inspection interval in accordance with Paragraph IWC-5222.

l Licensee's Code Relief Recuest: Relief is requested from performing the Code required hydrostatic test of the following portions of Class 2 piping:

(a) Chemical Injection to Main Feedwater lines between valves Q2N25V002A, B, and C and Main Feedwater lines (line Nos. OCB-1A, DCB-10, and DCB-lC).

! 33

.. ,o (b) Main feedwater lines from valves 02N21V001A A. B B, and C U to the Steam Generators (line No. DBB 1).

(c) Steam Generator blowdown lines to valves 02G24V003A, B, and C from the Steam Generators (line Nos. CBB 5, CBB-6, CBB-7, CBB 8, CBB-9, and CBB 10).

(d) Auxiliary feedwater piping from valves Q2N23V0llA, B, and C to the Main Feedwater lines (line No. DBB 2).

(e) Charging Pump discharge line Letween the charging pumps and isolation valves Q2E21V123A,' B and C; the mini flow piping to isolation valve Q2E21V265 (line Nos. CCB 16, CCB-17,andCCB-18).

Items (a) through (d) are nonisolable piping associated with the steam generators, secondary side. Testing at reduced holding time is addressed in relief request RR-30.

Licensee's Procosed Alternative Examination: The Licensee states that visual examination for evidence of leakage will be conducted on the portions of Class 2 systems listed above while at the test pressure for the lowest pressure rated Class 2 piping.

Licensee's Basis for Recunstinn Relief: The Licensee states that the portions of the Class 2 systems listed above cannot be isolated from lower pressure rated Class 2 piping. Performing hydrostatic tests at the required pressure would result in overpressurizing the lower pressure rated Class 2 piping.

Evaluation: The design of the system does not provide adequate shutoff boundaries to prevent overpressurization of the lower pressure rated Class 2 piping. The design of these lines, therefore, makes the Code-required hydrostatic test impractical to perform. In order to perform the hydrostatic test in l

accordance with the requirements, these lines would have to be modified to be isolatable from lower pressure rated Class 2 piping. The increase in plant safety would not compensate for l

the burden placed on the Licensee that would result from i

imposition of this requirement.

34

c. ..

The Licensee has committed to examine the piping while at the test pressure (1344 psi) for the lowest pressure rated Class 2 piping. Since the alternative test pressure is greater than the normal operating pressures of these lines, the proposed alternative test will provide adequate assurance that the subject portions of piping have not developed unallowable inservice flaws or that unallowable inservice flaws will be detected and removed or repaired prior to the return of this piping to service.

Conclusions:

The hydrostatic test required by Section XI of the ASME Code for the subject Class 2 lines is impractical to perform at Farley, Unit 2, because these lines are unisolatable from lower pressure rated Class 2 piping. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative test will provide assurance that structural integrity of these lines is maintained. Therefore, it is

. concluded that public health and safety will not be endangered by allowing the alternative test to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested for the lines listed.

3.4.2.3 Reauest for Relief No. RR-23. Hydrostatic _Isst of Portions of Class 2 Components to Reautrements of the Connectina Class 1 Pinina Code Recuirement: Section XI, Table IWC-2500-1, Examination Category C-H requires a hydrostatic test of all Class 2 pressure retaining components once esery 10-year inspection interval in accordance with Paragraph IWC-5222.

Licensee's Code Relief Reauest: Relief is requested from performing the Code-required hydrostatic test at the required l test pressure for the fo110 win 3 portions of Class 2 piping:

35

'O 80 (a) Vents, drains, instrumentation lines, and branch connections off Class I lines (line Nos. CCB 27 33, 34,

-38, -39, -40, 41, 42, 43, -44, 46A, 468, 46C, -47A, 478, and 47C). ,

(b) Pressurizer spray valves bypass lines (line No. CCB-57).

(c) Sample lines off reactor coolant system (RCS) loops and pressurizer (line Nos. CCB 37, -54. 55, and -56).

(d) BoronInjectionTankdischargetoRCS(coldlegs)between valves Q2E21V004A and B, Q2E21V0'29, and 02E21V062A, B, and C (line Nos. CCB-21 and CCB 50).

(e) High Head Safety Injection (HHSI) pump discharge to RCS (cold legs) between valves Q2E21V063 and Q2E21V066A B, and C (line No. CCB 22).

(f) HHSI pump discharge to RCS (hot legs) between valves Q2E21V06B and Q2E21V07BA, B, and C (line No. CCB 30).

(g) HHSI pump discharge to RCS (hot legs) between valves Q2E21V072 and Q2E21V079A, B, and C (line No. CCB 31).

(h) Branch lines connecting the accumulator discharge lines to the accumulator test line (line No. CCB-24, -53, and 54).

(1) Residual Heat Removal (RHR) pump discharge to RCS (hot legs) between valves Q2E21V044 and Q2E21V076A and B (line No. CCB-29)

(j) RHR to RCS (cold legs) between valves 02E21V023A and B and Q2E21V021A, B, and C (line Nos. CCB 22 .nd-32).

(k) Alternate charging line between valves Q2E21V243 and Q2E21Vll3 (line No. CCB 9).

(1) Normal charging line between valvas 02E21V244 and Q2E21Vll2 (line No. CCB 10).

(m) Normal charging line control valve bypass line between valves Q2E21V143 and Q2E21Vil2 (line No. CCB-45).

(n) Reactor Coolant Pump No I seal leakoff lines to valves Q2E21V623A, B, and C (line Nos. CCB-4BA, -488, and -4BC).

(o) Reactor Pressure Vessel (RPV) head vent line from Class I line to valves Q2B13HV-2 and 02B13HV-4 (line No. CCB 63).

Licensee's Proposed Alternative Examination: The Licensee states that visual examination for evidence of leakage will be conducted on these portions of systems in conjunction with the hydrostatic test performed on the adjoining Class 1 system.

36

, -. - - ~. - -

i, ,.

Licensee's Basis for Reauestina Relit {: The Licensee states that it is impractical to conduct a Class 2 hydrostatic test on the portions of the systems listed where the only means of pressurizing the Class 2 system is through the Class I system or when the boundary between ae two systems is a check valve arranged for flow from the Class 2 system to the Class 1 system.

Evaluation: The Licensee provided a list of operating pressures, design pressures, Code required test pressures, and the proposed alternative test pressures for the subject lines in Attachment 10 of the October 5, 1989 submittal (Attachment 10 revised in April 12, 1990 submittal). The design of each of these systems does not provide adequate shutoff boundaries to prevent overpressurization of the adjacent Class 1 piping. The design of these lines, therefore, makes the Code-required hydrostatic test impractical to perform. In order to perform the hydrostatic test in accordance with the requirements, these lines would have to be modified to be isolatable from the adjacent Class 1 piping.

The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

Alabama Power Company has committed to visually examine the piping while at the test pressure (850 psi for lines listed in item (h) above; 2280 psi for all other lines listed above] for the adjacent Class 1 piping. The proposed alternative test will provide adequate assurance that unallowable inservice flaws have not developed in the subject portions of piping or that they will be detected and removed or repaired prior to the return of this piping to service.

[anclusions: The hydrostatic test required by Section XI of the ASME Code for the subject Class 2 lines is impractical to perform at Farley, Unit 2, because these lines are unisolatable l

37

l l

from the adjacent Class 1 piping. Imposition of the i requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety I above that provided by the proposed alternative. The proposed alternative test will provide assurance that structural integrity of these lines is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative test to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested for the lines listed.

3.4.2.4 Reauest for Relief No. RR-24. Hydrostatic Test of the Class 2 Relief Line Diicharae Header pioina to the Pressurizer Relief it.0.h NOTE: As stated in the Licensee's October 5, 1989 submittal, Request for Relief No. RR 24 is not required and will be deleted by the Licensee with the next ISI Program Plan revision on the basis that the Code-required test can be accomplished as suggested in the NRC request for additional information.

3.4.2.5 Reauest for Relief No, RR-25. Hydrostatic Test of Class 2 Pressure Retainino Reactor Vessel Flanae Seal Leakoff line Code Reauirement: Section XI, Table IWC-2500-1, Examination Category C-H requires a hydrostatic test of all Class 2 pressure retaining components once every 10-yur inspection L interval in accordance with Paragraph IWC-5222.

j Licensee's Code Relief Reauest: Relief is requested from performing the Code-required hydrostatic test of the Class 2 pressure retaining reactor vessel flange seal leakoff line from the reactor vessel to valves Q2B13V019 and Q2B13V018 (line No. CCB-36).

38

Lig.pnsee's proposed Alternative ExaminA1.iau The Licensee states that, for the reactor vessel flange seal leakoff line from the reactor vessel, the portion of Class 2 piping up to valves Q2813V019 and 02B13V018 will be visually examined during the Class I hydrostatic test.

Ljcensee's Basis for Reouestino Relief: The Licersee states that performance of a hydrostatic tes,t for this system is impractien1 because pressurization of the flange seal leakoff line could potentially result in damage to the reactor vessel flange seals.

Evaluation: There is a possibility that the reactor vessel flange seals will be damaged if the flange seal leakoff line is pressurized to the Class 2 requirew nts. The design of this line, therefore, makes the Code required hydrostatic test impractical to perform, in order to perform the hydrostatic test in accordance with the requirements, the reactor vessel flange seals and flange seal leakoff line, and thus the reactor pressure vessel, would have to be redesigned, fabricated, and

installed. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of this requirement.

The Licensee has committed to perform the alternative hydrostatic test at a test pressure of 2280 psi as listed in Attachment 10 of the Licensee's April 12, 1990 letter. The proposed alternative test will provide adequate assurance that unallowable inservice flaws have not developed in the subject line or that they will be detected and removed or repaired prior to the return of this line to service.

Conclusions:

The hydrostatic test required by Section XI of the ASME Code for the subject Class 2 line is impractical to l

perform at Farley, Unit 2, because of the possibility of damage to the reactor vessel flange seals. Imposition of the 39 1

.. .o requirements on Alabama Power Company would cause a burden that -

would not be compensated significantly by an increase in safety 7 above that provided by the prvposed alternative. The proposed ,

alternative test will provide assurance that structural '

integrity of this line is maintained. Therefore, it is concluded that public health and safety will not be endangered  !

by allowing the alternative test to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested. l 3.4.2.6 flgouest for Relief No sRR 26. Hydrostatic Test of Class 2  !

Pioina isolated from the Test Boundary by Closed Chttk Valves Code Recuirem. gal: Section XI, Table IWC 2500 1. Examination ,

Category C H requires a hydrostatic test of all Class 2 pressure retaining components once every 10 year inspection interval in accordance with Paragraph IWC 5222.

Licensee's Code Re_ lief Reouest: Relief is requested from performing the Code-required hydrostatic pressure test of the following portions of Class 2 systems isolated from the test  !

boundary by closed check valves: ,

P (a) Charging pump suction piping from the chemical mixing tank between valve Q2E21V186 and check valve Q2E21V187 (line No. HCB-ll). .

(b) Hydrogen and nitrogen supply piping to the VCT from check '

valve Q2E21V201 to isolation valves Q2E21V202 and Q2E21V203 (line No. HCB-68).

(c) Charging pum) suction piping from volume control tank between checc valve 02E21V211 and locked closed valve Q2E21V212 (line No. 2'HCB-16).

(d) Charging pump suction piping from boric acid blender between eneck valve Q2E21V210 and normally closed valve .

Q2E21V264 (line No. HCB-16).

Licensee's Proposed Alternative Examination: None. The 5 Licensee states that portions of the above mentioned Class 2 40

piping will be visually examined during the Class 2 system functional test.

Licensee's Basis for Reouestina Relief: The Licensee states that pressurization of the portions of system piping listed above cannot be assured due to the position of the check valves. The check valves listed prevent flow from the test I fill point to the specified boundary valves. l Evaluation: Drawing 0356356, Sheet 2 of 5, in the ISI Program shows that the design of the suction piping incorporates check valves ti.t prevent flow from the test fill point to the specified boundary valves. The position of the chock valves, therefore, precludes pressurization of these portions of piping to Class 2 reouirements. These portions of 1 inch and 2-inch diameter piping would have to be modified to include test connections in order to perform the Code required hydrostatic test. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of this requirement.

The Licensee has stated that a visual examination will be performed during the Class 2 system functional pressure test to assess the general condition of the lines. This will provide reasonable assurance of the continued inservice structural integrity of the piping.

Conclusions:

The hydrostatic test required by Section XI of the ASME Code for the subject Class 2 lines is impractical to i

perform at Farley, Unit 2, because of the position of the check valves. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the visual examination during the functional pressure test.

( This examination will provide assurance that structural integrity of these lines is maintained. Therefore, it is concluded that pubile health and safety will not be endangered 41 l

i. ..

l by allowing the alternative test to be performed th ite9 of the Code requirement. It is recommended that relief he grante --  !

requested.

3.4.2.7 Recuest for Relief No. RR-27. Hydrostatic Test _of the Class L Waste Gas Drain Filter h (ode Reauirement: Section XI Table IWC 2500 1 Examination Category C H requires a hydrostatic test of all C1tss 2 l pressure retaining components once every 10-year inspection interval in accordance with Paragraph IWC-5222.

Licensee's Code Relief Recue11: Relief is requested from performing the Code-required hydrostatic pressure test of the Class 2 waste gas drain filter line to VCT from isolation valve 02G22V249 through check valve Q2G22V248 (line No. HCB 92).

Licensee's Proposed Alternative Examination: The Licensee states that the portion of Class 2 piping between valve Q2G22V249 and check valve Q2G22V248 will be visually examined during the Class 2 system functional test.

Licensee's Basis for Reauestina Relief: The Licensee states that pressurization of this portion of the waste gas drain filter line would require check valvi Q2G22V248 to hold the hydrostatic test pressure. Leakage through this valve could potentially result in overpressurization and subsequent damage of the waste gas filter.

Evaluation: Design of the waste gas drain filter line does not provide a shutoff valve to protect the waste gas filter from overpressurization during hydrostatic testing of the line. The design of this line, therefore, makes the Code-required hydrostatic test impractical to perform. In order to perform the hydrostatic test in accordence with the requirements, this line would have to be modified to be isolatable from the waste 42

.vo .,

gas filter. The increase in plant safety would not compensato for the burden placed on the Licensee that would result from imposition of the requirement.

Alabama Power Company's proposed alterntive to perform a visual examination during the Class 'e system functional pressure test to determine the general condition of the line will provide reasonable assurance of the continued inservice structural integrity.

Conclusions:

.The hydrostatic test required by Section XI of the ASME Code for the waste gas drain filter line is impractical to perform at farley, Unit 2, because the line is unisolatable from the waste gas filter. Imposition of the specific Code requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative pressure test will provide assurance that structural integrity of these lines is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative test to be performed in lieu of the CoJe requirement. it is recommended that relief be granted as requested for the lines listed.

3.4.2.8 Reauest for Relief No. RR-29. Hydrostatic Test of Class 2 Boron Iniection Recirculation Pumn Discharoe Pipina Code Reouirement: Section XI, Table IWC 2500-1. Examination Category C-H requires a hydrostatic test of all Class 2 pressure retaining components once every 10-year inspection interval in accordance with Paragraph IWC-5222.

Licensee's Code Relief Reauest: Relief is requested from performing the Code-required hydrostatic pressure test of the Class 2 boron injection recirculation pump discharge piping 43

.= -- ... . - - -_ . . - _ - . . _ - - . _

j u .. j 4

between valves Q2E21V006A and B, Q2E21Y005A and B, and the 4

adjoining drain piping (line No. CCB 62).-

l J

Licensee's Proposed Alternative Examination: The Licensee  !

states that these lines will be visually examined during ,

operation as a part of the adjoining Class 3 system leakage  !

test which will be performed at 150 psi.

, Licensee's Basis for Reauestino Relief: The Licensee states

. that performance of a hydrostatic test at 3107 psi (1.25 Pd )

on the portion of the system described above requires the use  ;

of check valves which are subject to leakage when used as a hydrostatic test boundary. These valves, which are welded in place, cannot be removed and replaced by blind flanges. l Experience has shown that these 1-inch Kerotest check valves ,

.- have some leakage when subjected to pressures in this range.

Leakage past these valves could potentially pressurize-and  !

overstress the adjoining Class 3 piping which has a design -i pressure of 150-psi.  ;

i Evaluatign: The design of the system does not provide adequate l

~

shutoff boundaries to prevent overpressurization of the Class 3 ,

piping. The Licensee has committed to examine the piping -

during_ tests of the-Class 3 system at 150 psi. However, in Attachment 10 of the Licensee's April 12, 1990 letter, the >

Licensee indicated that the subject piping could be pressurized to en alternative test pressure of 2750 psi. This test pressure is considerably higher than the test pressure of-150 psi listed in the Licensee's proposed alternative examination discussed in Revision 3 of this relief request submitted on August 15, 1990. Since the operating pressure of the subject piping is 2735 psi, the Licensee's proposed visual examination of the Class 2 piping during the Class 3 leak test at 150 psi would serve no useful purpose.

Conclusions:

Based on the above evaluation, it is concluded

that the Licensee's proposed alternative examination at 150 psi I

44

i will not provide assurance of the continued inservice  !

structural integrity. Thereforc, it is recommended that relief be denied.

3.4.2.9 Reouest for Relief No. RR-30. Hydrostatic Test of the Class 2 Portion of the Steam Generators and Associjtied Pinina .

Code Reouirement: Section XI, Table IWC-2500 1, Examination ,

' Category C H requires a hydrostatic test of all Class 2 i pressure retaining components once every 10 year inspection i interval in accordance with Paragraph IWC 5222.  ;

r Licensee's Code Relief Reouest: Relief is requested from the l required pressure and required 4-hour holding time for ['

hydrostatic testing of the Class 2 portion of the steam generators and as:,ociated piping. (Testing at reduced pressure  !

for pertions of this piping is addressed in relief request  :

RR-22, items A through 0.)

{

Licensee's Proposed Alternative Examination: The Licensee states that the Class 2 portions of the steam generators and related piping will be hydrostatically tested at 1.25 times j service pressure for a minimum of 10 minutes and a maximum of 30 minutes. The test pressure will then be reduced to 5 1.0 times design pressure for the remainder of the required l 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> holding time.

LLeensee's Basis for Reouestina Relief: The Licensee states that, in order to prevent ur.due stress on the steam generators, i Westinghouse recommends that the hydrostatic test of the i secondary side of the steam generators be conducted at 1.25 times the design pressure for a minimum of 10 minutes and a ,

maximum of 30 minutes, and then reduced to 1.0 times the design l pressure for the balance of the 4-hour holding period. The related Class 2 piping is hydrostatically tested along with the f steam generator. l t

45

o. .,

Evaluation: The operating pressure for the secondary side of the steam generators is 775 psig, the design pressure is l 1085 psip, and the Code required test pressure is 1344 psig, j The Code-required holding time is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after attaining the f test pressure and temperature conditions for insulated i systems. This is to allow any leakage to penetrate the insulation that is not removed. In lieu of a holding time of i 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> at 1344 psig, the Licensee proposes to pressurize the i secondary side of the steam generators to 1344 psig for 10 to (

30 minutes and then reduce the pressure to 1085 psig for the [

balance of the 4-hour holding period. The alternative holding  :

time and pressures recommended by the manufacturer, which are

(

proposed in lieu of the Code required holding time and -

pressure, meet the intent of the Code reg'uirement and will [

provide reasonable assurance of the continued inservice structural integrity. Compliance with the specific requirement of the Code would not provide a compensating  ;

increase in the level of quality and safety.

r fonclusion: It is concluded that the proposed alternative  ;

test meets Be intent of the Code requirements. Imposition of l the specific Code requirement would not provide a significant j increase in safety above that provided by the proposed alternative. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative E test to be performed in lieu of the specific Code requirement. Pursuant to 10 CFR 50.55t.(a)(3), it is ,

recommended that relief be granted as requested.

3.4.2.10 Reouest for Relief No. RR 40. Hydrostatic Test of All Class 2 Branch Pine Lines from the Volume Control Tank to the First i

.YJL).y_e Code Reouirtmf_qt:

m Section XI. Table IWC-25001. Examination Category C-H requires a hydrostatic test of all Class 2  ;

i i

46 l

pressure retaining components once every 10-year inspection interval in accordance with Paragraph IWC-5222.

Licensee's Code Relief Reouest: Relief is requested from performing the Code required hydrostatic pressure test of all Class 2 branch pipe lines from the volume control tank to the first valve as listed below:

(a) LinasfromVCTtovalves02E21d260,02E21V209,02E21V356, 02E21V152, 02E21V201, Q2E21Vl96, Q2E21V262, Q2E21V261, Q2E21Vl93, Q2E21V376A, Q2E21V337, and Q2E21V423.

(b) Line from VCT to valve Q2G12V029.

(c) Line from VCT to valve 02G22V249, and line from VCT to

. valve Q2G22V189.

(d) Line from VCT to valve Q2G22V081.

(e) Line from VCT to valve 02P15HV3117.

Licensee's Proposed Alternative Examination: The Licensee states that the connecting lines to the VCT will be hydrostatically tested to the same pressure as the tank.

Licensee's Basis for Recuestina Relief: The Licensee states that the subject Class 2 portions of piping cannot be isolated from the tank. The VCT tank is designed to 75 psig and the associated piping is designed to 150 psig. Therefore, the only practical means to hydrostatically test the tank associated piping is based on the VCT design pressure.

Evaluation: The ISI Program drawings referenced in the Licensee's relief request show that the design of the system does not provide shutoff valves to protect the volume control tank from overpressurization during hydrostatic testing of the connecting lines. The system design, therefore, makes the Code required hydrostatic test impractical to perform. In order to perform the hydrostatic test in accordance with the

! requirements, these lines would have to be modified to be l

47

I isolatable from the volume control tank. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement. l i

The Licenne has stated that the volume control tank is i designed to 75 psig and the associated piping is designed to ,

150 psig. Alatama Power Company's proposed alternative is to l hydrostatically test these Class 2 branch pipe lines to the [

same pressure as the volume control tank. The proposed  ;

alternative test will provide adequate assurance that unallowable inservice flaws have not developed in the subject ,

portions of piping or that they will be detected and removed  ;

or repaired prior to the return of this piping to service.

I conclusions: The hydrostatic test required by Section XI of [

the ASME Code for the subject Clan 2 lines is impractical to perform at farley, Unit 2, because these lines are unisolatable from the volume control tank. Imposition of the -

requirements on Alabama Power Company would cause a burden  :

that would not be compensated significantly by an increase in saf e above that provided by the proposed alternative. The ,

proposed alternative test will provide assurance that ,

structural integrity of these lines is maintained. Therefore,  !

1t is concluded that public health and safety will not be  !

endangered by allowing the alternative test to be performed in  !

lieu of the Code requirement. It is recommended that relief  ;

be granted as requested fcr the lines listed. i 3.4.2.11 Reouest for Relief No. RR-43. Hydrostatic Test of Class 2 Portions of the RCS Head Vent linet l Code Rtouirement: Section XI, Table IWC-2500-1, Examination Category C H requires a hydrostatic test of all Class 2  ;

pressure retaining components once every 10-year inspection  !

interval in accordance with Paragraph IWC-5222. .

t 48 i

.. s, licensee's Code Relief Reauest: Relief is requested from [

performing the Code-required hydrostatic pressure test of the l Class 2 portions of the RCS head vent line (line No. l*CCB 63 >

i between solenoid valves Q2B13HV 2 to Q2B13HV 1 and Q2B13HV 4 to Q2B13HV-3).

Licensee's Procosed Alternative Examination: The Licensee states that functional operation of -this ,ystem demonstrates [

structural integrity. Visual inspection will be performed while the system is at normal operating pressure to verify  ;

lenktightness.

Licensee's Basis for Reouestina Relief: The Licensee states that hydrostatic testing of the RCS is performed in mode 2 of the reactor plant shutdown, in this mode, the plant Technical  ;

Specifications require that all solenoid valves on the RCS I

head vent be maintained clnsed. This being the case, hydrostatic testing of the portion between the;c valves at i this time would be a violation of the Technical  !

Specifications.

Another way to hydrostatically test these lines would be to ,

pressurize the line after the head has been removed. This would require actuating solenoid valves Q2B13HV-2 and [

Q2813HV-4 with the aid of a temporary electric power source. i The work associated with actuating these valves, installing test connections, and performing the hydrostatic test would require excessive radiation exposure (approximately 1.5 man-rem),

l l  !

This level of exposure is unwarranted in view of the minimal j benefits gained by testing this relatively small section of {

pipe which is approximately 6 inches long.

l e l

49

.. .a Evaluation: Pressurizing this 6-inch long line after tha head has been removed is impractical because personnel would raceive excessive radiation exposure (approximately 1.5 man-rem to examine the 6 inch line). Duo to Farley Technical Specification requirements, t.he Code required hydrostatic test of this line cannot be performed in mode 2 of the reactor plant shutdown. In order to perform the hydrostatic test in accordance with the requirements, Farley Technical Specification requirements would have to be violated or inspection personnel would receive excessive radiation exposure. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

The L1censee's proposed alternative is to visually examine this line while the system is at normal operating pressure (system functional pressure test) to verify leaktightness.

The proposed alternative will provide reasonable assurance of the continued inservice structural integrity.

Conclusions:

The hydrostatic test required by Section XI of the ASME Code for this 6-inch portion of 1-inch RCS piping is impractical to perform at Farley, Unit 2, because it would result in inspection personnel receiving excessive radiation exposure and violates the Technical Specification requirements if performed in mode 2 of the reactor plant shutdown.

Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative test will provide assurance that structural integrity of this line is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative test to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested.

50

3.4.3 Class 3 System Pressure Tests (

3.4.3.1 Rgauest for Relief No. RR-31. Visual Examination for leakaae _  !

of Class 3 Service Water Pumos Durina System Pressure Tests Code Recuirement: Section XI, Paragraph IWD-2510 and Table IWD 2500-1 require that all Class 3 pressure retaining components be subjected to VT 2 visual examination in  !

conjunction with the system pressure test requirements of Article IWD 5000.  :

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

performing the Code required VT-2 visual examination of the ,

Class 3 service water pumps except at the pump discharge  !

nozzle.

Licensee's_P_rocosed Alternative Examination: The Licensee states that visual inspection of the discharge nozzles will be performed while the pumps are operating. The pump casings will be visually inspected each time the pumps are removed for .

t maintenance.

i licensee's Basis for Reauestino Relief: The Licensee states that, due to component design and mounting details, the visual inspection of this vertical centrifugal pump is impractical except at the pump discharge nozzle.

Ev?untlan: The service water pumps are vertical pumps and,  ;

due to component design, the pump and supporting column are submerged in an inaccessible wet pit. Only the motor and  ;

discharge nozzle are accessible above the operating deck. The component design, therefore, makes the Code-required visual examination impractical to perform. In order to perform the

.v t ual examination during the hydrostatic test in accordance rK.h the requirements, the Class 3 service water pumps would have to be redesigned, fabricated, and installed. The  ;

51

~ _

increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

The Licensee has stated that the pump discharge nozzle is the only portion of each of the service water pumps that is accessible for visual examination during the hydrostatic test. Alabama Power Company's proposed alternative is to visually examine the discharge nozzles while the pumps are operating and to perform a visual examination of the pump casings each time the pumps are removed for maintenance.

These examinations will provide reasonable assurance of the continued inservice structural integrity.

Conclusi.qni: The VT-2 visual examination required by Section XI of the ASME Code during hydrostatic testing of the Class 3 service water pumps is impractical to perform at Farley, Unit 2, because the pump and supporting column are submerged in an inaccessible wet pit. Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative examination will provide assurance that structural integrity of the service water pumps is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement.

It is recommended that relief be granted as requested.

3.4.3.2 Reauest for Relief No. RR-32. VT-2 Visual Examination of Class 3 Pipino Encased in Concrete in the Soent Fuel Pcol Coolino System Code Reauirement: Section XI, Paragraph IWD 2510 and Table IWD-2500-1 require that all Class 3 pressure retaining 52

- ~

components be subjected to a VT-2 visual examination in i conjunction with the system pressure test requirements of ,

Article IWD-5000, .

Licensee's Code Relief Reauest: Relief is requested from performing the Code-required VT-2 visual examination of the j Class 3 pressure retaining piping encased in concrete in the spent fuel pool cooling system. .

licensee's Proposed Alternative Examination: None. The Licensee states that the integrity of the encased piping will .

be demonstrated during normal system functional testing.

Licensee's Basis for Reauestina Relief: The Licensee states that the design of the piping system does not provide any  !

means to visually access the encased portions. The Licensee  :

also states that visual examination for leakage at ground level is also not possible. ,

Evaluation: These portions of spent fuel pool cooling system piping cannot be visually examined because they are encased in '

Cd quir v a e ti pr ti a o p rform. In order to perform the visual examination during the hydrostatic test in accordance with the requirements, the spent fuel pool cooling system would require design modifications. The j increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement. The continued inservice structural integrity of the encased piping will be demonstrated during normal ,

system functional testing,  !

Conclusiors: The VT 2 visual examination required by Section XI of the ASME Code during hydrostatic testing of the l' subject Class 3 spent fuel pool cooling piping is impractical to perform at Farley, Unit 2, because the piping is encased in ,

t 53 i i

a

• .. .. I concrete. Imposition of the requirement on Alabama Power '

, Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the system functional pressure test. The functional test will I provide assurance that structural integrity of the encased piping is maintained. Therefore, it is concluded that public  :

health and safety will not be endangered by allowing the alternative to be performed in lieu of the Code requirement  !

and it is recommended that relief be granted as requested.  !

b 3.4.3.3 Reauest for Relief No. RR-33. Hydrostatic Tests of Portions of  :

Class 3 Pioina and Comoonents in Service Water. Soent Fuel t Pool Coolina. Component Coolina Water. Chemical and Volume Control and Reactor Makeue Systui Code Reauirement: Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that.all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.

Licensee's Code Relief Reauest: Relief is requested from performing the Code required hydrostatic testing of the following portions of Class 3 piping and components:

Service Water System:

(1) Portion of piping upstream of valves Q2P16V540 and Q2P16V541.

(2) -Portion of piping downstream of valves Q2P16V516 and Q2P16V517.

Spent Fuel Pool Cooling:

-(1) Portion of. piping downstream of valves Q2G31V003A and 02G31V0038.

(2) Portion of piping downstream of valve Q2G31V005.

(3) Portion of piping upstream of valves Q2G31V001A and Q2G31V001B, 54

Component Cooling Water System:

(1) Component Cooling Water (CCW) surge tank.

(2) Portion of piping from CCW surge tank to valves 02Pl7Vil7A, 02Pl?Vll78, Q2Pl7V121A, Q2Pl7V121B, Q2Pl7V110A, 02Pl7V1108, 02Pl7V110E, 02Pl7V110F, Q2Pl7V109A, Q2Pl7V1090, Q2Pl7V278A, Q2Pl7V2788, ,

Q2Pl7V278C, Q2P17V144A, Q2Pl7V144C, Q2Pl7V017A, Q2Pl7V017B. I 1

Chemical and Volume Control System: 1 (1) Portion of piping from valve 02E21V019 to discharge of Boron Injection Recirculation ifumps - valves Q2E21V006A J and Q2E21V0068.

Reactor Makeup System: (no details provided by Licensee)

Licensee's Proposed Alternative Examination: None. The Licensee states that functional operation of these portions of piping and components demonstrates structural and leaktight integrity. Visual iMaction to verify leaktightness will be performed while the >yAtems are at normal operating pressure.

Licensee's Basis for Reauestina Relief: The Licensee states that hydrostatic testing of the above systems is net practical since they operate continuously during all modes of plant operations.

Evaluation: In the Licensee's December 7, 1989 response to the NRC request for additional information, the Licensee stated that a detailed review was conducted to identify those portions of these systems which cannot be hydrostatically tested as required by the Code. The piping and components listed in that submittal either lie beyond the Code boundary valve used to isolate the system for performance of the -

t hydrostatic test or interconnect the redundant system trains such that removal from service for testing would render the entire system inoperable. The Reactor Makeup system was not l included in that listing of systems that cannot be j hydrostatically tested.

As shown in the drawings referenced in the Licensee's relief request, the subject portions of Class 3 piping in the service 55

_ . _ -... _ m. _ . .. ,

,. .. i 4

wr. cr system are unisolatable from non safety related piping prc'iding service water supply to and from the turbine I l

building. j As shown in the drawings referenced in the Licensee's relief request, the subject portions of Class 3 piping and components in the pent fuel pool cooling, component cooling water, and chemical and volume control systems cannot be isolated for

)

hydrostatic tests since removal from service for testing would i render the entire system inoperable.  !

The design 'of these systems, therefore, makes the Code required hydrostatic test of these portions of Class 3 -

piping and components impractical to perform. In order to perform the hydrostatic test of these portions of Class 3 piping and com ments-in accordance with the requirements,  ;

these systems would have to be redesigned, refabricated, and installed. The increase in plant safety would not compensate  ;

for the burden placed on the Licensee that would result from i imposition of the requirement.

The Licensee stated in the December 7, 1989 submittal that ,

those portions of the service water, component cooling water, chemical and volume control, and spent fuel pool cooling i systems, which can be isolated without loss of-redundant trains within the system, will be hydiostatically tested to the extent practical as required by the Code. These Code-required hydrostatic tests and the Licensee's proposed 't visual-. examination at normal operating pressure (functional pressure test) for_those_ portions of piping for which relief ,

is requested will provide reasonable assurance of the -

continued inservice structural integrity.

Conclusions:

The hydrostatic test required by Section XI of the ASME Code for the subject Class 3 piping and components, with the exception of the Reactor Makeup system, is 56

.. ,2 impractical to perform at Farley, Unit 2, because the piping _

l and components either lie beyond the Code boundary valve used i to isolate the system or interconnect the redundant system ,

trains such that removal from service for testing would render the entire system inoperable. Imposition of the requirements i on Alabama Power Company would cause a burden that would not ,

be compensated significantly by an increase in safety above that provided by the functional pressure test. The proposed [

test will provide adequate assurance that structural integrity of the subject piping and components is maintained. ,

Therefore, it is concluded that public health and safety will not be endangered by allowing the functional t-< to be  ;

performed in lieu of the Code requirement. It is re::ommended ,

that relief be granted as requested for the piping listed above with the exception of the Reactor Makeup -/ stem. With regard to the Reactor Makeup system, it is recommended that relief be denied.

3.4.3.4 Reauest for Relief No. PR-34. Hydrostatic Test of Class 3 Sorav Additive Pioina and Comoonents in the Containment Sorav System l Code Reauirement: Section XI, Paragraph IWD-2510 and Table  :

IWD 2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of .

Article IWD 5000.

Licensee's Code Relief Recuest: Relief is requested from f performing the Code-required hydrostatic pressure test of Class-3 spray additive piping and components in the containment spray system.

Licensee's Proposed Alternative Examination: The Licensee states that a measured flow test in accordance with plant 57

e. .  :,,

[

Technical Specification paragraph 4.6.2.2d will be conducted f periodically. to-assure the leaktightness of these Class 3 j c'omponents.- .

l t

-Licensee's-Basis for Reauestino Relief: The Licensee states f that, while in' service, these spray additive lines have an  !

operating pressure of 15 psig and temperature of 100'F, which are well below the design conoitions af 210 psig pressure and -j 300*F temperature. Therefore, a syst a hydrostatic test at i 1.25 times service pressure would not' provide a meaningful  !

test. In addition, this piping system contains sodium  !

hydroxide at a concentration of 30 to 32% per Technical ll Specification 3.6.2.2a. Sodium hydroxide is a hazardous  ;

substance according to.40 CFR part 302 '(CERCLA). Alabama  !

Power Company does not consider it practical to perform the hydrostatic testing since it would expose personnel, i equipment, and the' environment to a hazardous substance at l'.25Pd when this system operates at only 15;psig and 100'F. >

Evaluation: These lines contain highly corrosive sodium j hydroxide and the system operates at a pressure of 15 psig and 7 temperature of 100'F, which is significantly less than the [

design corditions. The presence of the highly corrosive  !

sodium hydroxide in the spray additive piping and the fact j that the system % rates at-a-pressure that is far below the design prcssi' mn the Code-required hydrostatic test impractical n rar iorm. If the hydrostatic test was perfccmed j

1 in accordance with the requirements, personnel, equipment, and the environment could be exposed to a hazardous substance. -

The increase. in plant safety would not compensate for the j

burden placed on the Licensee that would result from l imposition of the requirement.  !

t I

Alabama Power Company's proposed alternative is to perform a measured flow test in accordance with the Farley Technical l Specifh.ations to assure the leaktightness of system. This i f

[

58 i i

alternative will provide reasonable assurance of the continued '

inservice structural integrity of the Class 3 spray additive piping-and_ components.

4

-Conclusions: The hydrostatic test requirei by Section XI of I

-the ASME Code for the Class 3 spray additive piping and components is impractical to perform at Fcriey, Unit 2, because the lines contain highly cor.rosive sodium hydroxide _ '

and the system operates at a pressure significantly less than <

the design-conditions (upon which the Code requirement is based). -Imposition of the Code requirement on-Alabama Power Company would cause a burden that'would not be compensated by an increase in safety above tnat provided by the proposed alternative. The proposed alternative exanination will provide assurance that_ structural integrity of the spray -,

vdditive piping and components is maintained. Therefore, it is-concluded that public health and safety will not be <

endangered by allowing the alternative examination to be-performed in lieu of the Code requirement. It is recommended 4 that relief be' granted as requested.

3.4.3.5 Reques' for Relief No. RR-35. Hydrostatic Test of Class 3 Portio % of Buried Pinino in the Service Water System Code Recuirement: Section XI, Paragraph .IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of-Article IWD-5000. Subarticle IWA-5244 defines the VT-2 visual examination for buried components. -

Licensee's Code Relief Recuest: Relief is requested from performing the Code-required visual examination of Class 3 portions of buried piping in the service water system during hydrostatic testing. ,

59

• . c, 1

l Licensee's Proposed Alternative Examination: The Licensee j states that buried piping will be inspected by conducting a l visual observation of the ground (at ground elevation) for wet spots while the systems are at operating pressure. This is in accordance with the Final Safety Analysis Report, Paragraphs 3.1.41 and 9.2.1.4.

Licensee's Basis for Reauestina Relief: The Licensee states that the design of this system does not allow access for visual examination as required by IWA-5244.

Evaluation: Portions of the Class 3 piping in the service water system are buried. The design of the service water system does not provide access to the the portions of buried piping to perform the Code-required visual examination during hydrostatic testing. The system design, therefore, makes the Code required examination impractical to perform.- In order to perform the Code-required visual examination during the hydrostatic test in accordance with the requirements, the service water system would require design modifications to provide access for examinations. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

The Licensee's proposed alternative examination is to conduct a visual observation (in accordance with the Final Safety Analysis Report, Paragraphs 3.1.41 and 9.2.1.4) of the ground (at ground elevation) for wet spots while the systems are at operating pressure. This examination will provide reasonable assurance of the continued inservice structural integrity of the buried piping.

Conclusions:

The VT-2 visual examination required by Section XI of the ASME Code during hydrostatic testing of the subject Class 3 service water system piping is impractical to perform at Farley, Unit 2, because the piping is buried with l

60 l

..- u no access for visual examinations referenced in IWA 5244.

Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative examination will provide assurance that structural integrity of the buried piping is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative to be performed in lieu of the Code requirement and it is recommended that relief be granted as requested.

3.4.3.6 Reouest for Relief No. RR-36. VT-2 Visual Examination of Heat Exchanaer Tubes of Class 3 pressure Retainina Safety Related Heat Exchanaers Code Reouirement: Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.

Licensee's Code Relief Reouest: Relief is requested from performing the Code-required VT-2 visual examination of heat exchanger tubes of Class 3 component cooling water heat exchangers HX-Q2P17 H001A-8, H001B-AB, and H001C-A.

Licensee's Proposed Alternative Examination: The Licensee states that tube side inspection will be performed by j isolating the heat exchanger, removing the waterbox covers, and pressurizing the shell side with water. Tube leakage is indicated if there is any flow from the tubes while in this l configuration. This type inspection will be performed at least once per inspection interval.

l 61

Licensee's Basis for Reauestino Relief: The Licensee states that, due to component design and limited accessibility, these heat exchanger tubes cannot be visually inspected under high pressure hydrostatic test conditions. Integrity of the component is assured by testing the component as a unit.

Evaluation: Although it is our interpretation that it is not the intent of the Code to require VT.-2 visual examination of the heat exchanger tubes during the hydrostatic test of the heat exchangers, the Code does not specifically exclude these items. The design of the heat exchanger does not provide access to the subject heat exchanger tubes in order to perform the VT-2 visual examination during hydrostatic testing.

Inaccessibility during a hydrostatic test, therefore, makes the VT-2 visual examination of the heat exchanger tubes during the hydrostatic test impractical to perform. In order to perform the VT-2 examination during hydrostatic testing, the

heat exchangers would require redesign to provide access for the examination. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the rcquirement.

Alabama Power Company's proposed alternative is to perform a tube side inspection by isolating the heat exchanger, removing the waterbox covers, and pressurizing the shell side with l water at least once per inspection interval. Because tube leakage will be detected if there is any flow from the tubes while in this configuration, assurance of the continued inservice structural integrity will be provided.

Conclusions:

The VT-2 visual examination required by Section XI of the ASME Code for Class 3 pressure retaining components during hydrostatic tests is impractical to perform at Farley, Unit 2, with regard to heat exchanger tubes because the tubes are inaccessible. Imposition of the requirement on Alabama Power Company would cause a burden that would not be '

62

• • - se compensated by an increase in safety above that provided by.

the proposed alternative. The proposed alternative test-will provide assurance that structural -integrity of these- Class 3  ;

heat exchanger tubes is maintained. Therefore, it is

.~ concluded that public health and safety will.not be endangered by allowing the alternative examination to be performed in lieu-of the Code requirement. Although it is our-interpretation that it is not the. intent of the Code to require VT-2 visual examination of these heat exchanger tubes during the hydrostatic test, the Code does not specifically.

exclude these items-from the VT-2 visual examination.

Therefore, it is recommended that relief be granted as  !

requested.

3.4.3.7 Recuest for Relief No. RR-37. VT-2 Visual Examination of the Coolino Coils for Class 3 Pressure Retainino Safety Related Coolers o

Code Recuirement: Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that.all Class-3 pressure retaining j components be subjected to VT-2 visual examinat!on in conjunction with the system pressure test requirements of Article IWD-5000.

Licensee's Code Relief Recuest: Relief is requested from performing the Code-required VT-2 visual examination of the cooling coils for the following Class 3 pressure retaining

i. . safety related coolers:

(a) Four containment coolers - 02E12-H001A-A, H001B-A, H001C-B, and H001D-B. .

1- (b) Two auxiliary feedwater pump room coolers - 02E16-H005A-A-l- and H005B-B.

(c) Two component cooling water pump room coolers Q2E16-H004A-A and H004B-B.

I 63 l-

a - +- g .w- - .,,.ma ..n.a.~n , -m m - & +>.+ 1 c..a m i ~ .. s a a , .u~ . . - -

e. - ,,;

r 1

-(d) :Two containmentispray pump room coolert Q2E16-H002A-A and. +

H0028-B.

(e); Two RHR/LHSI pump room coolers-Q2E16-H003A-A and H0038-B.

(f) Three battery charging room coolers Q2E16-H006A-A, LH006B-B, and H006C-AB.

(g) Three charging pump room coolers Q2E16-H001A-A,'H0018-AB, 4

~-

and H0010-8.

(h) Two 600-V load center coolers Q2E16-H009-A and H010-B.

(i) Two motor control center room coolers Q2C16-H007-A and H008-B.

Licensee's Proposed Alternative Examination: The Licensee states that the normal operation of these cooling units demonstrates their structural and leaktight integrity. Visual inspection to verify leaktightness will be performed while the system is at normal operating pressure. - Also, the coolers

. provided with the drain basin will be inspected by observing for abnormal flow (other than normal-condensation). -

Licensee's Basis for Reauestina Relief: The Licensee states

- that, due to the. component design, the cooling coils (heat exchanger _ tubes) cannot _be visually inspected during the conduct of system pressure test.

Evaluatio'ni AlthoughLit is our interpretation'that it is not the intent of the Code to require VT-2 visual examination of the cooling coils of-the subject Class-3 safety related coolers during the system pressure test, the Code does.not specifically exclude these items. The design of the coolers does not provide-access to the subject cooling coils to perform the-VT-2 visual examination .during pressure testing.

Inaccessibility during a system pressure test, therefore, makes.the VT-2 visual ~ examination of the cooling coils during l- the system pressure test-impractical to perform. In order to L perform the VT-2 examination during pressure testing, the coolers would require redesign to provide access for the

. 64-L

. . - , . , ,~.

e, s, 1

I examination. The increase in plant safety could not compensate for-the burden placed on the Licensee that would result from imposition of the requirement.

Because normal operation of these cooling units demonstrates tneir structural and leaktight integrity, Alabama Power Company's proposed alternative to perform a visual inspection to verify leaktightness while the system is at normal operating pressure and to observe for abnormal flow (other than normal condensation) on the coolers provided with a drain basin provides assurance of the continued inservice structural integrity.

Conclusions:

The VT-2 visual examination required by Section XI of the ASME Code for Class 3 pressure retaining components during system pressure tests is impractical to perform at Farley, Unit 2, with regard to the cooling coils of the subject Class 3 safety related coolers because the cooling coils are inaccessible. Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated by an increase in safety above that provided by the proposed alternative. The proposed alternative test will provide assurance that structural integrity of these Class 3 cooling coils is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement. Although it is our interpretation that it is not the intent of the Code to require VT-2 visual examination of these cooling coils during the system pressure test, the Code does not specifically exclude these items from the VT-2 visual examination. Therefore, it is recommended that relief be granted as requested.

65

3.4.3.8 Reouest for Relief No. RR-38. Hydrostatic Test of Class 3 Piping of the Auxiliary Steam System Code Reauirement: Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000. .

Licensee's Code Relief Reauest: Relief is requested from performing the Code-required hydrostatic pressure test of the Class 3 pressure retaining piping of the auxiliary steam system downstream of valves Q2N12V002B and Q2N12V003.

Licensee's pronosed Alternative Examination: The Licensee states that the VT-2 visual examination to verify leaktightness will be performed while these lines are at normal operating pressure.

Licensee's Basis for Reauestina Relief: The Licensee states that there is no practical means of isolating these portions

^

of the auxiliary steam system and, therefore, hydrostatic testing cannot be conducted on these lines.

Evaluation: The ISI Program drawing referenced in the Licensee's relief request shows that there are no valves downstream of valves Q2N12V002B and Q2N12V003 in the auxiliary steam supply lines capable of providing a positive isolation when performing a hydrostatic test. The system design, therefore, makes the Code-required hydrostatic test impractical to perform. In order to perform the hydrostatic test in accordance with the requirements, the subject lines would require design modifications to provide isolability.

The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.

66

Alabama Power Company's proposed alternative to perform the VT-2 visual examination to verify leaktightness while these lines are at normal operating pressure will provide reasonable assurance of the continued inservice structural integrity.

Conclusions:

The hydrostatic test required by Section XI of the ASME Code for the subject auxiliary steam system piping is impractical to perform at Farley, Urtit 2, because there are no valves downstream of valves 02N12V002B and Q2N12V003 capable of providing a positive isolation when performing a hydrostati: test. Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety abcvu that provided by the proposed alternative. The proposed VT-2 visual examination at operating pressure will provide assurance that structural integrity of the subject lines is maintained. Therefore, it is concluded that public health and safety will not be endangerad by allowing the alternative examination to be performed m lieu of the Code requirement.

It is recommended that relief be granted as requested for the subject auxiliary steam supply lines.

3.4.3.9 Recuest for Relief No. RR-39. Hydrostatic Test of Class 3 Auxiliary Feedwater Pumo Minimum Flow Pinj.cg Code Recuirement: Section XI, Paragraph FWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be' subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.

l Licensee's Code Relief Recuest: Relief is requested from performing the Code-required hydrostatic pressure test of the following Class 3 pressure retaining auxiliary feedwater pump minimum flow piping:

67 h

% g -

-i i

(a); Line No -2"DBC between valve Q2N23V019A and flow  !

orifice F03214A.

f e

(b) -Line No. 2"DCB between valve Q2N23V0198 and flow orifice F032148. -!

(c) Line No. 2"DBC-4 and 3*DBC between valve-Q2N23V010 and-flow orifice F03219. j Licensee's Proposed Alternative Examination:- The Licensee states that these lines will receive a visual examination during normal operation at system operating temperature and j pressure, j I

Licensee's Basis for Reouestino Relief: The Licensee states  !

_that performance of a hydrostatic test on the portions of the f piping system listed could overpressurize the lower pressure, i non-Code piping downstream of these flow orifices. -!

I Evaluation:' The ISI Program drawing referenced in the j Licensee's relief request-shows that the. design of the i

auxiliary feedwater pump minimum flow piping system does not f provide distinct class boundaries to-allow pressurization of I the class 3 piping without overpressurizing adjacent non-Code -i

-piping. The system design, therefore,'makes the Code-required  !

hydrostatic test impractical to perform. .In order to perform I the hydrostatic test in accordance with the requirements, the subject lines-would require-design: modifications 'to provide isolability. The increase-in plant safety would not compensate for the burden placed on the Licensee that would

-resul't.from imposition of the requirement.

Alabama Power Company's proposed alternative to perform the VT-2 visual examination during normal operation at system operating temperature and-pressure will provide reasonable

-assurance of the continued inservice structural integrity.

Conclusions:

The hydrostatic test required by Section XI of the ASME Code for the subject Class 3 pressure retaining 68

..C t eT auxiliary feedwater pump minimum flow piping is impractical to perform at Farley, Unit 2, because the subject lines cannot be isolated from adjacent non-Code piping. Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative will provide assurance that structural integrity of the subject lines is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested.

3.4.3.10 Reouest for Relief No, RR-44. VT-2 Visual Examination of Heat Exchanaer Tubes of Class 3 Pressure Retainina Safety Related Heat Exchancers Code Reouirement: Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Cless 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.

Licensee's Code Relief Reouest: Relief is requested from performing the Code-required VT-2 visual examination of the heat exchanger tubes of Class 3 pressure retaining safety related heat exchangers (two each spent fuel pool cooling HX-Q2G31 H001A-B and H001B-A).

Licensee's Proposed Alternative Examination: The Licensee states that tube side leakage will be identified by the existing in-line radiation monitoring system and existing periodic sampling of the Component Cooling Water and Spent fuel Pool Cooling Systems. If a tube leak is indicated, the water box covers will be removed and a VT-2 visual examination 69

w .,

performed to identify the leaking tubes. The tubes will be plugged prior to returning the heat exchanger to service.

Licensee's Basis for Reouestino Relief: The Licensee states that, due to component design and limited accessibility, these heat exchanger tubes cannot be visually inspected ender high pressure hydrostatic test conditions. Integrity of the component is assured by normal operation of the system.

Evaluation: Although it is our interpretation that it is not the intent of the Code to require VT-2 visual examination of the heat exchanner tubes during the hydrostatic test of the heat exchangers, the Code does not specifically exclude these items. The component design does not provide access to the heat exchanger tubes of the subject Class 3 safety related heat exchangers in the spent fuel pool cooling system to perform the VT-2 visual examination during hydrostatic g testing. Inaccessibility during a hydrostatic test, therefore, makes the VT-2 visual examination of the heat l

exchanger tubes during the hydrostatic test impractical to perform. In order to perform the VT-2 examination during hydrostatic testing, the heat exchangers would require redesign to provide access for the examination. The increase in plant safety would not compensate for the burden placed on tha (Mr.see that would result from imposition of the requiremert.

Alabama Power has stated that tube side leakage will be identified by the existing in-line radiation monitoring system -

and existing periodic sampling of the component cooling water and spent fuel pool cooling systems and that, if a tube leak is indicated, the water box covers will be removed and a VT-2 visual examination performed to identify the leaking tubes (the tubes will be plugged prior to returning the heat l exchanger to service). This examination will provide ,

reasonable assurance of the continued inservice structural integrity.

70 l

w ,,

Conclusiqu: The VT-2 visual examination required by Section XI of the ASME Code for Class 3 pressure retaining components during hydrostatic tests is impractical to perform at-Farley, Unit 2, with regard to heat exchanger tubes because the tubes are inaccessible, imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated by an increase in safety above that provided by the proposed a'lternative. The propased alternative will provide assurance that structural integrity of these Class 3

, heat exchanger tubes is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement. Although it is our interpretation that it is not the intent of the Code to require VT-2 visual examination of these heat exchanger tubes during the hydrostatic test, the Code does not specifically exclude these items from the VT-2 visual examination.

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

3.4.4 General 3.4.4.1 Recuest for Relief No. RR-45. Hydrostatic Test of Class 2 and Class 3 Low Pressure Systems NOTE: As stated in the Licensee's October 5, 1989 submittal, Request for Relief No. RR-45 is not required and will be deleted in the next ISI Program revision.

3.4.4.2 Recuest for Relief No. RR-46. Schedulino of Class 2 and Class 3 System Hydrostatic Pressure Tes11 Code Recuirement: Section XI, Table IWC-25001, Examination Category C-H, Note 5 requires that system hydrostatic tests be 1

71

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conducted at or near the end of the inspection interval or during the same inspection period of each inspection interval for Inspection Program B. Note 2 of Table IWD-2500-1, Examination Categories D-A, D-B, and D-C. requires that system hydrostatic tests be conducted at or near the end of the inspection interval or during the same inspection period of each inspection interval for laspection Program B.

Licensee's Code Relief Reouest: Relief is requesi.ed from scheduling Class 2 hydrostatic tests in accordance with Note 5 of Table IWC-2500-1, Examination Category C-H and from scheduling Class 3 hydrostatic tests in accordance with Note 2 of Table IWD-2500-1, Examination Categories D-A, D-8, and D-C.

Licensee's Proposed Alternative Examination: The Licensee states that all 25 hydrostatic tests will be performed during the second inspection interval. They will be scheduled to distribute the testing evenly among the three periods for the second interval.

Licensee's Basis for Reauestina Relief: The Licensee states that the system hydrostatic tests are scheduled on a periodic basis in accordance with Inspection Program B. As a result of performing additional tests during the first 10-year interval, it is necessary to move eight hydrostatic tests forward one period. The original schedule-for performing hydrostatic l

testing was based on dividing the systems to be tested into 18 procedures. Due to operational conditions during the course of the interval, several procedures were divided L resulting in additional hydrostatic testing procedures to be l performed. At the end of the interval, 25 procedures existed to cover the systems to be tested.

Evaluation: The Licensee has committed to scheduling the hydrostatic tests such that the elapsed time between a system examination will not exceed 10 years. Therefore, the intent 72 l

m .i of the Code requirement will be met. The Licensee has demonstrated that the proposed alternative scheduling provides an acceptable level of quality and safety and that compliance with the Code schedule would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.

Conclusions:

Based on the above evaluation, it is concluded that the Licensee's proposed scheduling of hydrostatic pressure tests meets the intent of the Code requirements. j Therefore, it is concluded that public health and safety will j not be endangered by allowing the alternative scheduling in l lieu of the Code requirement. Pursuant to 10 CFR 50.55a(a)(3), it is recommended that relief be granted as requested, l

3.5 General 3.5.1 Ultrasonic Examinjtlion Technioues 3.5.1.1 Recuest for Relief No. RR-1. Material Reauirements for Calibration Bloch Code Reovirement: Section XI, Paragraph IWA-2232 requires that ultrasonic examination of vessel welds in ferritic materials greater than 2 inches in thickness be performed in accordance with Article 4,Section V. Paragraph T-434.1 l(3) of Article 4 requires that the material from which calibration blocks are fabricated be of the same material specification, product form, and heat treatment as one of the materials being joined.

Licensee's Code Relief Recuest: Relief is requested from the material requirements for calibration blocks used to perform ultrasonic examination of the following:

73

e  :.. j Cal. Block Comoonent to be examined  !

APR-6: Steam generator channel head to-tubesheet welds-APR-7: Boron injection tank head-to-shell - -

circumferential welds and nozzle-to-head wolds.  !

ALA RV-1: Reactor vessel lower head to-lower shell weld and all lower head welds. Boron injection tank-head to shell circumferential welds l

ALA-RV-3: Reactor vessel top he,ad welds t

ALA-RV-5: Reactor vessel shell welds  ;

lig.ensee's Procosed Alternative Examination: The Licensee .

states that the subject calibration blocks are in compliance with- the material requirements -of Paragraph T-533,- Article 5,  ;

Section V-of the 1974 ASME Code. This paragraph requires the block to.be of'similar metallurgical structure and the same or .!

an equivalent P-number grcuping as the finished component. l l

Licensee's Basis for Recuestino Relief: The Licensee states j that, during fabrication of the Farley, Unit 2, nuclear steam .;

supply system vessels, the calibration blocks used to perform  !

examinations by the vessel manufacturer were fabricated to-the

]

requirements of.ASME Section III. -When ASME Section XI was issued for inservice inspection, the new requirements for  !

vessel calibratiu. blocks rendered the existing blocks- j unacceptable for use. The original blocks had to be replaced {

but some vessel materials were no longer available. The  ;

vessel calibration blocks had to:be refabricated to the Section XI requirements applicable at that. time. l.

Information was submitted in the Licensee's October 5, 1989 j l

response to the NRC request for additional information. The L following summarizes evaluations which were conducted to ,

determineithe suitability of the alternative calibration block j materials:  ;

APR-6: The SA-216 Gr. WCC and SA-508 C1. 2 or 3 materials .l examined and SA-336 C1. F-l' alternative calibration block {

74  :

s . -

material have the same product form, are similar in chemistry, received equivalent postweld heat treatments, and are all classified as P-3.

APR-7: The SA-516 Gr. 70 base materials examined and the alternative SA-533 Gr. B Cl. I calibration block material are the same product form and have equivalent P-numbers for acoustic purposes per Section V of the 1974 Edition of the ASME Code. As required by Section V, the calibration block was given a postweld heat treatment.

ALA-RV-1: The SA-508 C1. 2 alternative calibration block material and SA-533 Gr. B material examined are similar in chemistry, received equivalent postweld heat treatments and are both classified as P-3.

ALA-RV-3 and ALA-RV 5: The SA-533 Gr. B C1. 2 material examined and the SA-508 C1. 2 alternative calibration block material are similar in chemistry, received equivalent postweld heat treatments and are both classified as P-3.

In each case, the parameters judged to be essential for acoustical compatibility were considered in the evaluatior.s.

The materials examined and the alternative calibration block materials were found to be similar enough to ensure acoustical compatibility. ,

From the standpoint of acoustics, attenuation characteristics and velocity are of the utmost concern in determining material compatibility. The velocity and attenuation differences of .

the materials are immeasurable and are, for the most part, equivalent. Therefore, the existing calibration blocks are acceptable, based on acoustic compatibility.

To fabricate new Code-required calibration blocks would be j impractical, if not impossible, due to availability of ,

t 75 t

6 o material and will not make a substantial improvement in the quality of the examinations. Obtaining the appropriate product form and material specification may require procurement of nozzle forgings, nozzle ring castings, tubesheet forgings, and other difficult-to-obtain product forms.

In summary, it is Alabama Power Company's judgement that the evaluations summarized above suitably demonstrate the acceptability of the alternative calibration block material requirements. While the Code requirements have not been explicitly met (and thus a relief request has been submitted),

the intent of the Code to ensure acoustic compatibility has been met.

Evaluation: Evaluation of the calibration blocks by the Licensee has shown that the velocity and attenuation differences of the material are immeasurable and are, for the most part, equivalent. While the Code requirements have not been explicitly met, the intent of the Code to ensure acoustic compatibility has been met. All of the proposed calibration blocks have been in use since the plant was built; therefore, their continued use would provide consistent results. Because procuring calibration blocks of the exact materials would be difficult, if not impossible, and because the velocity and attenuation characteristics of the materials are equivalent, the increase in plant safety would not compensate for the burden placed on the Licensee that would result from requiring i

the Licensee to fabricate new calibration blocks to meet the current Code. The Licensee has demonstrated that the proposed alternative provides an acceptable level of quality and safety and that compliance with the specific Code requirement would result in hardship or unusual difficulties without a l compensating increase in the level of quality and safety.

l 76 l

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Conclusions:

Based on the above, it is concluded that public health and safety will not be endangered by allowing the use of the alternative calibration blocks in lieu of the specific Code requirement. Therefore, pursuant to 10 CFR 50.55a(a)(3),

it is_ recommended that relief be granted as requested.

3.5.1.2 Reauest for Relief No. RR-2. Soecif}c Dimensional Reauirements for Calibration Blocks Code Reauirement: Section XI, Paragraph IWA-2232 requires that ultrasonic examination of vessel welds in ferritic materials greater than 2 inches in thickness be conducted in accordance with Article 4,Section V, 1983 Edition. Figure T-434.1, Article 4, requires that the minimum distance from -

the ends of the 2-inch long 2% T notches to the edges of the block be 3 inches.

Licensee's Code Relief Recuest: Relief is requested from notch location requirements for calibration blocks used to perform ultrasonic examination of the following:

ALA-RV-1: Boron injection tank head-to-shell circumferential .

welds. Reactor vessel lower head-to-lower shell weld and all lower head welds ALA-RV-3: Reactor vessel top head welds ALA-RV-5: Reactor vessel flange-to-shell weld and shell welds Licensee's Proposed Alternative Examination: The Licensee states that the subject calibration blocks are in compliance with the clearance dimensions required for notches by Figure T-546.1, Article 5,Section V, 1983 Edition.

Licensee's Basis for Reauestino Relief: The Licensee states that Figure T-546.1, Article 5,Section V, 1983 Edition, is a similar calibration block; however, the clearance required from the ends of the 2% notches is 2 inches instead of the 77 3

N 'O

, l 3 inches required by Figure T-434.1, Article:4. Experience

, - performing calibrations using these tilocks has proven fully  ;

satisfactory.

. Evaluation: All of the proposed calibration blocks-have been in' use since the plant ~ was built; therafore, their continued

use would provide consistent results. Because procuring- '

calibration blocks.of the exact materials would be difficult, if not impossible, _ and because the existing blocks have been proven satisfactory for performing calibrations, the increase t in plant safety.would not compensate for-the burden placed on the Licensee that would result from requiring the Licensee to fabricate new calibration blocks to the current Code. The

! Licensee has demonstrated that the proposed alternative provides an acceptable level of qu:lity and safety and that compliance with the specific Code. requirement would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.

Conclusions:

Based on the above, it'is concluded that public health and safety will not .be endangered by allowing the use of the alternative calibration blocks in lieu of the specific Code-requirement. Therefore, pursuant to 10 CFR 50.55a(a)(3),

it -is recommended that relief be granted as requested.

3.5.1.3 Reauest for Relief No. RR-3. Soecific Dimensional Reauirements fpr Calibration Blocks-

[ ode Reauirement: Section XI, Paragraph IWA-2232 requires that ultrasonic examination of vessel welds in ferritic

. materials greater than 2 inches in thickness be conducted in accordance with Article-4,Section V, 1983 Edition. Figure T-434.1 in Article 4 requires the aligned side-drilled holes

[ and notches _to _be_ located a minimum distance of T/2 from the 78

8 o end of the block. The_non-aligned holes are to be located a minimum of 1.5 inches from the end of the block.

Licensee's Code Relief Reay_eit: Relief is requested from the !

hole location requirements for the following calibration blocks:

ALA-RV-1: Reactor vessel lower head-to-lower shell weld, all lower head welds, and bor'on injection tank head circumferential welds, l

ALA-RV-5: Reactor vessel flange-to-shell weld and shell welds APR-5: Steam generator stub barrel-to upper tubesheet weld, lower shell-to-stub barrel weld, transition 4_

cone-to-lower shell weld, upper shell-to-transP.lon cone weld, and feedwater nozzle-to-epper shell weld.

APR-7: Pressurizer top head-to-nozzle welds, top head-to-upper shell, upper-to-middle shell weld, lower-to-bottom head weld, all longitudinal shell welds, and bottom head-to-nozzle weld.

The aligned holes in ALA-RV-1 and ALA-RV-5 are 0.25 and 0.5 inches less than the required distance, respectively. The non-aligned holes on ALA-RV-1, APR 5, and APR-7 are 0.25, 0.625, and 0.625 inches less than the required distance, respectively.

Licensee's ProDosed Alternative Examination: None. The Licensee states that the calibration blocks are acceptable for .

use as is.

Licensee's Basis for Reauestino Relief: The Licensee states f

that experience performing calibrations using these blocks has

proven fully satisfactory.

Evaluation: All of the proposed calibration blocks have been in use since the plant was built; therefore, their continued

[ use would provide consistent results. Because procuring calibration blocks of the exact materials would be difficult, 79

k '--

~g -I

.. j if-not impossible, and bec6use the existing blocks have been .:

proven satisfactory for performing calibrations, = the increase  !

-in plant safety would not~ compensate for.the burden placed on i the Licensee that would result from requiring the' Licensee-to  !

fabricate new calibration ~ blocks to meet the current' Code.

The Licensee has demonstrated that the proposed alternative -l provides an acceptable level of quality and safety and that  :

compliance with the specific Code requirement would result in  !

hardship or unusual difficulties without .a compensating _

increase in the level of quality and safety.- j i

I conclusions: Based on the above, it is concluded that public health and safety will not be endangered by allowing the use i .of the alternative calibration blocks in lieu of the specific l Code requirement. Therefo:e, pursuant to 10 CFR 50.55a(a)(3), j it is recommended that relief be granted as requested. [

i 3.5.1.4 Reauest for Relief No. RR-4. Wall Thickness Differences Between Calibration Blocks and Components to-be Examined  !

Gnde Reauirementi Section XI, Appendix III, Paragraph f 111-3410 requires that the basic calibration-block be made -

from material of the same nominal wall thickness or pipe -

schedule as the pipe to be examined.  !

Licensee's Code Relief Reouest: Relief is requested from the f

g. wall thickness requirements for ~the following~ calibration

!. blocks: l L ALA-5; Excess letdown heat exchanger AWRV-7: Reactor coolant piping ALA 24: M31n steam piping .

AL M E: Feydwater piping i ALA-31: Volume control tank j i

The oeviations in ' wall thickness are indicited below:  !

l l

80 l i

l

! -l

._ . .. __ _ __ _ . _ _ _ -. _ . . . . _ = _ _ . .

l=( .o

. WALL THICKNESS DEVIATIONS Pipe Cal. Block Cal Block- Diam. Pipe Pipe Wall ,

' Number 1 Thick. fin.)' 1f32) Sched. Thick. fin.) Material ALA-5 _ 0.906 - 8.0 160 0.750 Stainless i ALA-RV-7 3.000 Flat N/A 2.0 to 3.0 CS/SS ALA-24 1.200 32.0 Special 1.033 - Carbon.  :

ALA-25 0.750 16.0 100- 1.031 Carbon. -f ALA-31. 0.388 Flat N/A 0.250 Stainless Licensee's Proposed Alternative Examination: ASME Code Case N-461, Alternate Rules for Piping Calibration Block

-Thickness, will be incorporated for use of the above calibration blocks with the following stipulations:

(a)- Ultrasonic (UT) thickness measurements and weld joint

. measurements of the pipe or component must be available  ;

to ~the~ UT inspector prior to performing the angle beam examination. It is accepteble to use measurements from h previous inspection.

(b)' The 10-year ISI plan and current outage plan shall annotate components / calibration blocks which require thickness tolerances per ASME-Code Case N-461.

'(c) 'In' addition, all UT reflectors 50%. distance-amplitude correction (DAC) and above must also be recorded and-their position in the weld joint plotted to determine if -

the reflectors are relevant indications. -

L Licensee's Basis for Reouestina Relief: The-Licensee states that the existing calibration blocks used for piping and thir-wall vessels were designed under the provisions of Section V, 1974 Edition, Summer 1975. Thickness differences

, between the above calibration blocks and the components to be examined are inconsequential and would in most cases produce l conservative examination results. Fabrication of new l

calibration blocks for the sole purpose of achieving exact 81

.-w..~. ,.,y,,,-,...y,.~.,,.... - - - . , . , , , . , , , , _ , , , . . . . . , , , . . . , , . . .

%- o-thickness congruity with the component will not improve examination quality.

Calibration blocks ALA-5 and ALA-24 have a nominal thickness greater ;han the examined piping. Use of a thicker cGibrationblockisconservativesinceexaminationofa thinner component would tend to decrease ultrasoni.

attenuation. ASME Code Case N-461 allows the use of calibration blocks which are within plus or minus 25% of the component-thickness. The ASME has approved this Code Case and the NRC is considering incorporation of N-461 into a future revision of NRC Regulatory Guide 1.147.

Calibration block ALA-25 has a nominal thickness less than the examined piping The reducer is schedule 100 with a nominal thickness of 1.031 inches; however,. in the area of interest, it is machined to a nominal thickness of 0.758 inch to match the steam generator nozzle thickness. Therefore, use of _the 0.750-inch thick calibration block will provide a representative examination of the nozzle to reducer weld.

Again, application of ASME Code Case N-461, once NRC approval is obtained, would permit use of this calibration block.

Calibration blocks ALA-RV-7 and ALA-31 have a nominai thickness greater than the examined piping. Use of a thicker calibration block is conservative since examination of a thinner component would tend to decrease ultrasonic -

attenuation.

Evaluation: Pending final review and evalu. tion by the NRC staff of ASME Code Case N-461, it appears tt ; the code case will be approved in Revision 8 of NRC Regulatory Guide 1.147 for generic use with supplemental requirements; the supplemental requirements are listed as part of the Licensee's proposed alternative examination.

82

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. fr l

. Use of' ASME Code. Case N 461 for calibration -blocks ALA-5, ALA 24, and ALA-25 is, therefore, - ptable with the stipulations. listed in the Licensees proposed alternative 1

examination. For calibration block ALA-31, the wall thickness of the calibration block is not within the range of 125% of l the Volume Control Tank shell wall thickness to be examined. j Therefore ASME-Code Case N-461 cannot be applied to .l calibration block ALA-31. .

~

Section XI,-Paragraph IWA-2232(c) allowsLthe use of Article 5.

-of'Section V-for the ultrasonic examination of piping made of i other than ferritic materials. With regard to calibration l block ALA-RV-7,-Section V,- Article 5, Figure T 546.1 ~ a110ws a  !

calibration block thickness of 3-inches to be used for- l thicknesses between 2--and 4 inches. Therefore, use of this 1

- calibration block is acceptable, f

With the exception of calibration block ALA-31, the Licensee has demonstrated that the-proposed alternative, with the above  ;

supplemental requirement, provides an acceptable level of  ;

quality and safety. and that compliance with the specific Code

]

- requirement would result- in hardship or unusual difficulties l without-a-compensating increase in the level of quality and f safety. l f

Conclusions:

- Based on the above, it is concluded that public {

health and safety will not be endangered by allowing the

{

proposed alternative to be performed in lieu of the Code _j requirements. Therefore, for the calibration blocks listed  !

except calibration block ALA-31, it is recommended that relief-

=be granted pursuant to 10 CFR 50.55a(a)(3). For calibration l block ALA-31, it is recommended that relief be denied. [

t 83 [

l i

.. . . . -- - .-. - . . . - . ~. -- . , .- -

%- o 3.5.1.5 Reouest for RelieLNo. RR-5. Curvature Differences Between Calibration Blocks and Components to be Examined f

Code Reauirement: Section XI, Appendix 111, Paragraph 111-3410 requires that the basic calibration blocks be made from material of the same nominal diameter as the pipe to be examined.

9 Licensee's Code Relief Reauest: Relief is lequesteo from the curvature requirements for the following calibratic' blocks used to perform ultrasonic examinations cn piping and thin-wall vessels:

ALA-5: Excess letdown heat exchanger ALA-RV-7: Reactor coolant piping ALA-21: Pressurizer skirt ALA-23: Main steam piping ALA-25: Feedwater piping ALA-31: Letdown heat exchanger; Volume control tank ALA-32: Residual heat exchanger ALA/APR-33: Reactor coolant piping .

The deviations in curvature are indicated below:

CURVATURE DEVIATIONS Cal. Block Cal. Block Component Component Number Diam. fin.) Descriotion Diam. fin.) Material ALA-5 8 Thin-walled 9.5 Stainless vessel ALA-RV-7 Flat RPV nozzle 27.5, 29.0 CS/SS safe end ALA-21 Flat Press. skirt 87.00 Carbon ALA-23 Flat Pipe 34.55 Carbon ALA-25 14 Reducer 16 x 14 Carbon ALA-31 Flat Thin-walled 21.78 Stainless vessel ALA-31 Flat Thin-walled 84.00 Stainless vessel ALA-32 Flat Thin-walled 39.75 Stainless vessel ALA/APR-33 29 Pipe 27.5 Cast SS ALA/APR-33 29 Pipe 31.0 Cast SS 84

% v Licensee's Proposed Alternative Examination: The Licensee states that the existing calibration blocks for piping and thin-wall vessels are in compliance with the curvature tolerances between the blocks and the test part as reovired by Section V, 1983 Edition, Summer 1983 Addenda, Paragraph T-543.3.

Licensee's Basis for Reouestino Relief: The Licensee states that the design of the existing calibration blocks was based on the provisions of Section V, 1974 Edition, Summer 1975 Addenda. Curvature differences between the above calibration blocks and the components to be examinad are inconsequential and would, in most cases, result in conservative examination results. Fabrication of new calibration blocks, for the sole purpose of achieving exact curvature congruity with the component, will not, in Alabama Power Company's judgement, improve examination quality.

Calibration block ALA-25 differs in diameter from the 16-inch diameter reducer which connects the 14-inch diameter feodwater piping to the steam generator nozzle. The calibration block is 14 inches in diameter and is used for examining the 16-inch diameter reducer to steam generator nozzle weld.

Calibration block ALA/APR-33 is used for examination of cast austenttic stainless steel reactor coolant loop piping materials in the hot, cold, and the crossover legs which have different diameters. The calibration block is the same nominal dirmeter as the hot leg but is of smaller diameter than the crossover leg piping and larger diameter than the cold leg piping. Regardless of the differences in diameter, the NRC has reviewed and accepted the :pecial examination

! techniques which Alabama Power Company utilizes for reactor coolant loop examination as permitted by Section XI, Paragraph IWA-2240. This review included an attenuation comparison of the calibration block and the coolant loop t

i 85

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piping. It was concluded thkt the calibration block was f representative of the installed piping and would therefore provide a conservative examination.

Calibratior, block ALA-5 was fabricated from 8-inch diameter stainless steel pipe and is utilized for examination of a 9.5 inch diameter cc:nponent. Regardless, Alabama Power Company utilizes enhanced vitrasonic examination techniques on all atainless steel components. This technique includes requirements that the refracted angle be recorded for each examined component. In addition to the required 46' examination, a 60' examinetlon is also utilizeo and both are performed et increased sensitivity by adjusting tha gain to t.n average noise level of 10% of full screen height. This j enhanced examination technique more than adequately compensates for any mismatch between the calibration block and l the examined component. '

Calibration block ALA RV 7 is a flat plate fabricated from dissimilar metals and is used to examine the reactor pressure l vessel nozzle safe end welds in 27.5 and 29.0 inch diameter piping. Calibration block ALA 21 is fabricated from carbon steel plate and it is used to exaaine the 87.0 inch diameter .

pressurizer skirt. Calibration block ALA 23 is fabricated from carbon steel plate and it is used in examine 34.5 inch diameter piping. Calibration blocks ALA 31 and ALA-32 are fabricated from stainless steel plate and are used to examine thin walled vessels ranging from 22 to 84 inches in nominal diameter. Use of these flat calibration blocks is considered acceptable based on guidanca from the ASME Code,Section V, Articles 4 and 5, which state that, for diameters greater than 20 inches, a block of essentially the same curvature or, alternately, a flat basic calibration block shall be used.

Given the large diameter of the components being examined, the flat calibration blocir is considered to be acceptable. As discussed above, use of the enhanced ultrasonic examination 86

w a technique more than adequately compensates for any mismatch between the calibration block and curvature of the examined component.

Evaluati2D: Section XI Paragraphs IWA 2232(a) and (c) allow the use of Articles 4 and 5 of Section V, which allow for use of a block of essentially the same curvature or, alternatively, a flat block for cuminatient where the examination surface diameter is graattr than 20 inches.

Therefore, with regard to the curvature deviations, the use of the subject calibration blocks is acceptable. The Licensee has demonstrated that the proposed alternative provides an accept.ible level of quality and safety and that compliance with the specific Code requirement would result in hardship or unusual difficulties without a compensating increase in the i

level of quality and safety.

Conclusions:

Based on the above, it is concluded that public health and safety will not be endangered by allowing the use of the alternative calibration blocks in lieu of the specific Code requirement. Therefore,pursuantto10CFR50.55a(a)(3),

it is recommended that relief be granted as requested.

3.5.1.6 Egouest for Relief No. kR 6. Materials for Fabrication of Calibration Blocks and Acoustic Comnatibility with the Component to be Examined Note: Relief Request No. RR 6 was withdrawn by the Licensee l in the December 7, 1989 submittal which states the following:

" Relief Request RR 6 pertains to calibration block l materials for piping and thin-walled vessel examinations. After a substantial comparison of the calibration block and component materials and a review of the examination requirements of Section XI, Appendix III, Paragraph 111-3451 as clarified by ASME Code Interpretation XI-1 86 61, it

was found that all calibration block materials are I

87

% a.

in compliance, therefore, relief request RR 6 is not required and will be deleted from the 151 Program with the next revision."

3.5.1.7 Reauest for Relief No. RR-7. Dimensional Requirements for D11bration Notches Placed in Ultrasonic (_alibration Blocks Code Reauiremant: Section XI, Appendix !!!,

Paragraph 111 3430 requires that basic calibration blocks conta notches that are at least 1.0 inch long and 0.104t 0.009t2 + 10%/-20% in depth.

Licensee's Code Relief Reauest: Relief is requested from the dimensional requirements for calibration notches placed in ultrasonic calibration blocks ALA 21, ALA-23, ALA 26, and ALA-28.

Licensee's proposed Alternative Examination: None. The Licensee states that these piping calibration blocks are acceptable for use as is.

Licensee's Basis for Reauestina Relief: The deviations in the calibration notch dimensions are as follows:

ALA-21: The notch depth is at 2% and should be 10%.

ALA-23: The notch depth is at 2% and should be 10%.

ALA 26: The notch is 0.125 inch under the required length of 1.0 inches.

ALA 23: The notch is 0.012 inch less than the 20% tolerance requirement for depth (the notch depth is at 6% and should be 10%).

The Licensee states that the only possible consequences of these discrepancies is that the sensitivity level of the ultrasonic instrumer' would be slightly higher than aquired, resulting in a more critical examination. Correcting these conditions on any of the above blocks would not be prudent and would be of questionable value when considering possible damage to the blocks by subjecting them to additional machining.

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t Evaluation: The undersize notches in the four subject {

. calibration blocks can only provide for a more sensitive j examination. The proposed calibration blocks have been in use j since the plant was builti therefore, their continued use would provide consistent results. The Licensee has demonstrated that the proposed alternative provides an acceptable level of quality and safety and that compliance  ;

with the specific Code requirentent would result in hardship or  !

unusual difficulties without a compensating increase in the [

1evel.of quality and safety.

l

Conclusions:

Based on the above, it is concluded that the j proposed alternatives meet or exceed the intent of the Code l requirements and that public health and safety will not be endangered by allowing the alternative calibration blocks to be used in-lieu of the Code requirement. Therefore, pursuant to II CFR 50.55a(a)(3), it is recommended that relief be grantel as requested.

3.5.2 Exemoted comoonents (Noreliefrequests) .

3.5.3 Other 3.5.3.1- Reauest for Relief No. RR 12. Delete VT-4 Visual Examination i Method and Examination Reauirement and Redefine VT-3 Visual Examination Method in Accordance With Paraoraoh IWA-2213 of-the 1986 Edition of the Code  ;

I code Reauirement: Section XI, Table IWF 2500-1. Examination -

Category F-C,-Item F3.50 requires a 100% VT-4 visual examination of spring type supports, constant load type f supports, shock absorbers, and hydraulic and mechanical type l

snubbers as defined by figure IWF-1300 1.

l Licensee's Code Relief Reauest: Relief fs requested from performing the Code required VT 4 visual examination of spring  !

89 i i

,_ - _ x_._.._ _._.. ,.. . . - - . _ _ _ . . _ _ . ,#,, _ , , . . . . - _ . - . _ _ _ _ _ _ . . _ . _ . - _ , _ . . _ - . - . _ _ . , . . - -

type supports, constant load i/pe supports, shock absorbers, and hydraulic and mechanical type snubbers. _

Licensee's Proposed Alternative Examinatign: None. The

-Licensee states that operability tests shall be performed in accordance with the Farley Technical Specifications.

Licensee's Basis for Recuestina Relief: The Licensee states that operability testing was-inappropriately included in YT-4 as an examination method. Also, Paragraph IWA 2214(b) of the 1983 Section XI' Code is inconsistent with industry visual examination practices._ An inspector does not perform bench testing.of snubbers / constant load / spring type supports. These activities are performed by maintenance technicians. The 1986 Edition of ASME Section X1 has deleted VT 4 examination altogether and has redefined VT-3 to include examinations for conditions that could affect operability or functional adequacy of snubbers, and constant load and spring type supports.

Evaluation: .The VT 3 and VT-4 visual examinations have been combined as the VT-3 visual examination in the later editions-of the Code (1986)-to-more clearly define the visual examination requirements. The-VT-3 visual examination requirement in the-1986 Edition is equivalent to the Code requirements of the 1983 Edition, Summer 1983 Addenda and, therefore, is an acceptable alternative.

Conclusions:

Based on the above evaluation, it is concluded that the_ proposed alternative examination is equivalent to the Code required examination and provides an acceptable level of quality.and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3), it is recommended that relief be granted as requested, f

90 L

• ~ n 3.5.3.2 Etquist for Relief No. RR 17. Reference System for All Weldt and Areas Subiect to Surface or Volumetric Examination i

l Code Reauirement: Section XI, Paragraph IWA 2610, ' Weld Reference System - General," requires that a reference system shall be established for all welds and areas subject to i surface or volumetric examination. Each su:h weld and area shall be located and idcntified by a system of reference l points. The system shall permit identification of each weld, location of each weld center line, and designation of regular intervals along the 14ng% 'f the nld.  !

l Licensee's Crde Relief .M qs>. Relief is requested from ,

establishing a weld referere,e sastem for all welds a!,d areas subject to surface or voiumetric examination.

Licensee's Proposed Alternative Examination: The Licensee states that administrative controls which are detailed in procedures provide adeouate instructions to ensure measurements are repeatable and ' hat any indications can be accurately located.

Licensee's Basis for Recuestino Relief: The Licensee states that to perform actual marking of welds in order to identify each weld centerline, length locations, etc. would require many manhours of radiation exposure. Many of the welds are insulated and as such many manhours of radiation exposure would be required to remove and reinstall insulation just to facilitate marking. Also, many manhours of radiation exposure would be involved in marking the welds.

Evaluation: For an operating plant, establishing a weld reference system for all welds and ar'.as subject to surface or volumetric examination is a major effort and, in some cases, is prohibited due to inaccessibility and/or high radiation levels. Therefore, the Code requirement for establishing a 91

• . r.

weld reference system for all welds subject to e', amination in the absence of examination is impractical for an coerating plant, in order to establish a weld refe.*ence system for all wolds and areas subject to surface and volumetric examinations in accordance with the requirements, many manhours and man rems of radiation exposure would be required to perform such tasks cs locating the welds, removing insulation, marking the welds, and reinstalling insulation, regardless of whether or not the weld is scheduled for examination. The increase in plant safety would not compensate for the burden placed on the t.icensee that would result from imposition of the requirement for all welds.

However, as inservice examinations of Class 1 and 2 piping systems are performed, each piping weld examined should receive the required reference markings. Impracticality will not exist for these welds since access will have been provided to perform examinations.

Conclusions:

The marking of all welds and areas subject to surface or volumetric examinations required by Section XI of the ASME Code in the absence of inspection is impractical at f arley, Unit 2, because it is an operating plant. Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated by an increase in public

- health and safety. However, as each Class 1 and 2 piping system is examined, access for marking each weld will be provided and impracticality for that particular weld will not exist. Therefore, in order to provide assurance of traceability of 112 piping welds and repeatability of examinations, it is recommended that relief be granted provided that each Class 1 and 2 piping weld examined receives the required reference markings as the inservice examinations are performed.

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A. %.

3.5.3.3 Reouest for Relief No. RR-41. Break Away Drao Test for Hydraulic Snubbers 821g: The functional testing of snubbers is not included in this evaluation. Functional tests are not within the scope of this document and will be evaluated elsewhere.

3.5.3.4 Eggy.est for Re Ugf Ho. RR-42. Additional Samele Testino Reouirements for Snubbers

. 821g: The functional testing of snubbers is not included in this evaluation. Functional tests are not within the scope of this document and will be evaluated elsewhere.

E i

f 93  :

i

A o

4. CONCLUSION l

Pursuant to 10 CFR 50.55a(g)(6) or, alternatively, 10 CFR 50.55a(a)(3), it has been determined that certain Section XI required inservice examinations l

j cannot be performed to the extent required by the Code. In all cases except  !

Requests for Relief RR 4 (in part), RR-29, and RR-33 (in part), the Licensee l has demonstrated that specific Section XI requirements are impractical or  !

that alternative examinations should be performed. It is recommended that .

relief be granted with conditions for Requests for Relief RR-15, RR-16, f and RR-17. For Requests for Relief RR-4, RR-29, and RR-33, it is concluded l that: (a) the Licensee has not provided information to support the determination that the Code requirement is impractical, and (b) requiring the Licensee to comply with the Code requirement would not result in i hardship, Requests for Relief RR-6, RR-24, and RR 45 were withdrawn by the Licensee and deleted from the ISI Program Plan. Requests for Relief RR-41 ,

and RR-42 request relief from the functional testing requirements of '

IWF-5000 for snubbers. The functional testing of snubbers is not included in this evaluation. Functional tests are not within the scope of this ,

document and will be evaluated elsewhere, i

l This technical evaluation has not identified any practical method by which l the Licensee can meet all the specific inservice inspection requirements of Section XI of the ASME Code for the existing Joseph M. Farley Nuclear Power Plant, Unit 2, facility. Requiring compliance with all the exact Section XI

required inspections would require redesign of a significant number of plant  !

systems, sufficient replacement components to be obtained, installation of f the new components, and a baseline examination of these components. Even  ;

after the redesign efforts, complete compliance with the Section XI i 5 ( li f s 1 e fr he e eme ts c are impractical to implement, or alternatively, pursuant to 10 CFR 50.55a(a)(3),

alternatives to the Code-required examinations may be granted provided that .

l either (i) the alternative proposed provides an acceptable level of quality  !

l and safety or the (ii) Code compliance would result in hardship or unusual  !

difficulty without a compensating increase in safety. Relief may granted l only if granting the relief will not endanger life or property or the common 94

s. . n.

defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Therefore, it is concluded that the public interest is not served by imposing certain provisions of Section XI of the ASME Code ti.at have been determined to be impractical.

The development of new or improved examination techniques should continue to be monitored. As improvements in these areas are. achieved, the Licensee should incorporate these techniques in the ISI program plan examination requirements.

Based on the review of the Joseph H. Farley Nuclear Power Plant, Unit 2, Second 10 Year Interval ISI Program, through Revision 1, the Licensee's responses to the NRC request for additional information, and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Joseph M. Farley Nuclear Power Plant, Unit 2, Second 10 Year Interval ISI Progrtm, through Revision 1, is considered unacceptable and not in compliance with 10 CFR 50.55a(g)(4) due to an unacceptable examination sample and unacceptable application of the exclusion criteria (see Sections 2.2.2 and 2.2.3 of this report). It is recommended that relief be granted with conditions for Requests for Relief RR 15, RR-16, and RR-17.

For Requests for Relief RR-4 (in part), RR 29, and RR-33 (in part), it is recommended that relief be denied. Requests for Relief RR 6, RR-24, RR-41, RR-42, and RR-45 either have been withdrawn or are not included in the scope of this document.

i 95

6

5. REFERENCES

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

2. American Society of Mechanical Engineers Boiler and Pressure Yessel Code,Section XI, Division 1:

1983 Edition through Summer 1983 Addenda 1974 Edition through Summer 1975 Addenda

3. Letter, dated August 31, 1990, E. A. Reeves (NRC) to W. G.

Hairston, Ill (APCo), exemption which permitted revision of the Unit 2 ISI Program to coincide with the Code of record and updated schedule <

currently used for Unit 1.

4. Joseph H. Farley Nuclear Power Plant, Unit 2. Second 10-Year f rterval Inservice Inspection Program, Revision 0, submitted March 23, 1989.

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

6. Letter, dated August 3, 1989 E. A. Reeves (NRC) to W. G. Hairston (Alabama Power Company (APCo)], request for additional information on the Second 10 Year Interval ISI Program.

7. Letter, dated October 5, 1989, W. G. Hairston, 111 (APCo) to NRC, response to the NRC request for additional information.

8. Letter, dated December 7, 1989, W. G. Hairston, 111 (APCo) to NRC, response to the NRC request for additional information. ,

9. Letter, dated April 12, 1990, W. G. Hairston, III (APCo) to NRC, additional information with regard to the 151 Program.

10. Letter, dated August 15, 1990, W. G. Hairston, 111 (APCo) to NRC, Revision 1 to the ISI Program,

11. Letter, dated September 12, 1990 W. G. Hairston, !!! (APCo) to NRC, corrections to Revision 1 of relief requests RR-1, RR-2, and RR-3.

j 12. Letter, dated June 1, 1988, A. R. Herdt (NRC) to R. P. Mcdonald (APCo),

j NRC Inspection Report Nos. 50-348/88-17 and 50-364/88-17.

13. Letter, dated June 22, 1988, W. G. Hairston, Ill (APCo) to NRC, request for exemption from requirements of 10 CFR 50.55a(g)(4)(ii).

14. Letter, dated August 31, 1988, S. A. Varga (NRC) to W. G. Hairston, 111 (APCo), exemption from certain requirements of 10 CFR 50.55a(g)(4)(ii).

15. Letter, dated December 16, 1988 W. G. Hairston, 111 (APCo) to NRC, updated ISI program for ASME Code Class 1, 2, and 3 components.

96 i

4.) e JL

16. Letter, dated February 8, 1989 W. G. Hairston, !!! (APCo) to NRC, list of relief requests for Unit 2 refueling outage.

17. Letter, dated March 23, 1989 W. G. Hairston, 111 (APCo) to NRC, updated inservice inspection program for ASME Code Class 1, 2, and 3 components.

18. Letter, dated March 31, 1989 E. A. Reeves (NRC) to R. P. Mcdonald (APCo), interim approval of ISI Program for Unit 2.

19. Letter, dated June 8, 1989, W. G. Hairston, 111 (APCo) to NRC, updated inservice inspection program for ASME Code Class 1, 2, and 3 .

components.  ;

20. Letter, dated September 21, 1989, W. G. Hairston, !!! (APCo) to NRC, schedule extension for submittal of response to the NRC request for additicaal information.

21. Letter, dated November 30, 1989, W. G. Hairston, 111 (APCo) to NRC, response to the NRC request for additional information.

22. NRC Regulatory Guide 1.150, " Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations," Revision 1, February 1983.

23. NRC Regulatory Guide 1.14, ' Reactor Coolant Pump Flywheel Integrity,"  ;

Revision 1, August 1975.

24. NRC Regulatory Guide 1.83, ' Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes,' dated July 1975,

25. NRC Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 7 July 1989.

97

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I BIBLIOGRAPHIC DATA SHEET ,

l ,s nwwe , owe ,,mo,

a. rat: 4~os a m 6' EGG MS 8944 Technical Evaluation Report on the Second 10 Year 'l Interval inservice inspection Progra'n Plan: a cariaircave.% ,5.ia Alabama Power Company, e '-

November j Joseph H. Farley Nuclear Power Plant Unit 2, 19~90 Docket Number 50 364 . ,~oaca.~twveia ,

flN 06022 (Proj. 5) '

t i wac% ,tvrio, necar l ,

Technical i B.W. Brown, J.D. Mudlin o s a ico co v i a d ,,... .. .

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ye,o,a g gue.te,-~ Ave

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EG&G Idaho, Inc.

P. O. Box 1625

! Idaho Falls, ID 83415 2209

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e vogag casa a v ios savi *~o ano a isi u, ..c. ,, u . . ..c ,, ,,

Materials and Chemical Engineering Branch i Offt:e of Nucioar Reactor Regulation U.S. Nuclear Regulatory Commission i Washington, D.C. 20555

10. $UPPLIMINI AR Y ~orl$ 1 r

t 1. AS$I a ACT (700 wo,y. ., ,

l This report presents the results of the evaluation of the Joseph H. Farley Nuclear

, Power Plant, Unit 2, Second 10 Year Interval Inservice inspection (ISI) Program, through Revision 1, submitted August 15, 1990, including the requests for relief

! from the American Society of Mechanical Engineers (ASME) Boller and Pressure Vessel l Code Section XI requirements which the Licensee has determined to be impractical.

l The Joseph M. Farley Nuclear Power Plant, Unit 2, Second 10 Year Interval 151 <

l Program is evaluated in Section 2 of this report, The ISI Program is evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability i of examination sample,, (c) correctness of the application of system or component 4 examination exclusion criteria, and (d) comp'liance with ISI-related commitments identified during the previous Nuclear Regulatory Commission reviews. The requests for relief are evaluated in Section 3 of this report.

e t v we a o s o e sc a ,i o a 5 ,. - ., ~. .. ..,, -, ~..- , . ,

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~IC Pomas 33s trat,

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