ML20205L040

SER Accepting Util Relief Requests for Inservice Insp Second 10-year Interval for Beaver Valley Power Station, Unit 2

ML20205L040
Person / Time
Site:	Beaver Valley
Issue date:	04/09/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20205L035	List: ML20205L034 ML20205L040 ML20205L043
References
NUDOCS 9904140104
Download: ML20205L040 (12)

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B NUCLEAR REGULATORY COMMISSION W ASHING 10N, D.C. 20$55-0001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 1

REGARDING RELIEF REQUESTS FOR THE INSERVICE INSPECTION SECOND 10-YEAR INTERVAL DUQUESNE LIGHT COMPANY OHIO EDISON COMPANY THE CLEVELAND ELECTRIC COMPANY THE TOLEDO EDISON COMPANY BEAVER VALLEY POWER STATION. UNIT NO. 2 DOCKET NUMBER 50-412

1.0 INTRODUCTION

, inservice inspection (ISI) of the American Society of Mechanical Engineers (ASME) Code Class 1,2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel (B&PV) Code and applicable addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.55a(6)(g)(i). It is stated in 10 CFR 50.55a(a)(3) that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed altematives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, " Rules for Inservice inspection of t4uclear Power Plant Comner.c ,t;," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first l 10-year interval and subsequent ir'tervals comply with the requirements in the latest edition I

and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The Code of record for Beaver Valley Power Station, Unit 2 (BVPS-2), second 10-year interval ISI program plan, is the 1989 Edition.

By letter dated December 9,1997, Duquesne Light Company (DLC, the licensee) submitted its Second 10-Year IntervaliSI Program Plan and associated reauests for relief for BVPS-2. The licensee provided additional information by its letter dated July 29,1998.

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2.0 EVALUATION i 1 1 l

l The NRC staff, with technical assistance from its contractor, the Idaho National Engineering I l and Environmental Laboratory (INEEL), has evaluated the information provided by the l licensee in support of its Second 10-Year Interval ISI Program Plan and associated requests '

for relief for BVPS-2. Based on the results of the review, the staff adopts the contractor's conclusions and recommendations presented in the Technical Evaluation Report (TER) attached.

The NRC staff determined that, based on its review of the licensee's documents provided, no deviations from regulatory requirements or commitments were identified in the licensee's Second 10-Year inspection Interval ISI Program Plan for BVPS-2.

Request for Relief No. 2-TYP-2-N-521, Rev. 0:

ASME Code,Section XI, Table IWB-2500-1, Examination Catep 9-D, item Numbers B3.90 and B3.100, require 100% volumetric examination of all nozzle-to-vessel welds and nozzle inside radius sections each inspection interval as defined by Figure IWB-2500-7. At least 25%

but not more than 50% (credited) of the nozzles shall be examined by the end of the first inspection period, and the remainder by the end of the inspection interval. Examination Category B-F, item Number 85.10, also requires 100% volumetric and surface examination of the reactor vessel nozzle-to-safe end butt welds. The examinations may be performed coincident with the vessel nozzle examinations required by Examination Category B-D.

Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the alternative requirements contained in Code Case N-521, A!temative Rules for Deferral ofInspections of Nozzle-to-Vessel Welds, Inside Radius Sections, and Nozzle-to-Safe End Welds of a Pressunzed Water Reactor (PWR) Vessel, in lieu of the examination requirements of the 1989 Edition of ASME XI for the following components:

Nozzle-to-Vessel Welds Nozzle Inner Radius Nozzle-to-Safe End Welds Category B-D, Item No. Sections Category B-F, item No.

B3.90 Category B D. Item No. B5.10 83.100 2RC*REV21-N-17 2RC*REV21-N-171R 2RC*REV21-N23 2RC*REV21-N-18 2RC*REV21-N-181R 2RC*REV21-N24 2RC*REV21-N-19 2RC*REV21-N-191R 2RC*REV21-N25 l 2RC*REV21-N-20 2RC*REV21-N-20lR 2RC*REV21-N26 1

2RC*REV21-N-21 2RC*REV21-N-211R 2RC*REV21-N27 2RC*REV21-N-22 2RC*REV21-N-22lR 2RC*REV21-N28 The licensee stated:

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l "The altemative to the 1989 Edition of the ASME XI Code examination requirement for the items associated with the reactor vessel nozzle welds is to implement Code Case N-521. Implementation would begin in the Second Ten-Year interval for BV-2, commencing with 2R07, scheduled for March,1998."

The Code requires the examination of at least 25%, but not more than 50% (credited) of Reactor Pressure Vessel (RPV) nozzles and associated inside radius (IR) sections and nozzle safe ends during the first inspection period. The licensee has requested to use Code Case N-521, which defers examination of these areas until the end of the second 10-year interval.

Code Case N-521 states that the examination of RPV nozzles, IR sections and nozzle-to-safe end welds may be deferred provided that (a) no inservice repairs or replacements by welding have ever been performed on any of the subject areas, (b) none of the subject areas contain identified flaws or relevant conditions that currently require successive inspections in accordance with IWB-2420(b), and (c) the unit is not in the first interval. The licensee has confirmed that these conditions have been met. In addition, the licensee examined all the subject areas during the third period of the first 10-year interval. By examining the nozzles, associated IR sections, and nozzle-tn-safe end welds at the end of the previous 10-year interval, the licensee has established a new sequence of examinations and will not exceed 10 years between examinations. By meeting the conditions in the Code Case and by repeating the examinations at the end of the previous interval, the licensee's proposed alternative will provide an acceptable level of quality and safety since the maximum time of 10 years between inspections will not be exceeded.

The staff finds that the licensee met all the conditions stated in the Code Case and examined all of the affected areas at the end of the previous intervtl. Thus, a new sequence of examinations has been established. Furthermore, since the time between examinations will not exceed 10-years, the licensee's proposed alternative will provide an acceptable level of quality and safety by providing reasonable assurance of component integrity. Therefore, the licensee's proposed altemative is authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use of Code Case N-521 is authorized for the second 10-year interval at BVPS-2, or until the Code Case is approved for general use by reference in Regulatory Guide (RG) 1.147. After that time, the licensee may continue to use the Code Case with the limitations, if any, listed in RG 1.147.

Request for Relief No. 2-TYP-2-83.110-1, Rev. 0:

ASME Code,Section XI, Examination Category B-D, item B3.110, requires 100% volumetric examination of the pressurizer nozzle-to-vessel welds as defined by Figure IWB-2500-7.

Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from 100% volumetric i examination of the following pressurizer nozzle-to-shell welds:

2RCS* PRE 21-N-9 (14" surge nozzle) 2RCS* PRE 21-N-12 (6" relief nozzle) 2RCS* PRE 21-N-10 (6" relief nozzle) 2RCS* PRE 21-N-13 (6" relief nozzle) 2RCS* PRE 21-N-11 (6" relief nozzle) 2RCS* PRE 21-N-14 (4" spray nozzle) i

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The Code requires 100% volumetric examination of the pressurizer nozzle-to-vessel welds.

However, volumetric examination of the subject relief, spray, and surge nozzle-to-vessel welds l is limited due to the radius of curvature in the transition area between the nozzle and the -

vessel shell. The heater penetration locations further limit the surge nozzle examination.

l Therefore, the nozzles' geometric configuration makes the volumetric examination impractical to perform to the extent required by the Code. To meet the Code requirements, the nozzles would have to be modified to facilitate access for ultrasonic search units. Imposition of this requirement would create a burden on the licensee.

The licensee's proposed alternative to the Code-required 100% examination is to perform the ultrasonic examination to the maximum extent possible. The licensee previously (first 10-year interval) examined the subject welds to the extent possible, obtaining approximately 57%

coverage of the required area for each relief and spray nozzle, and approximately 44%

coverage of the required area for the surge nozzle. The staff determined that, by obtaining the examination coverages previously achieved, significant patterns of degradation, if existing, would be detected. Thus, the proposed alternative provides reasonable assurance of structural integrity.

Therefore, the NRC staff finds that the geometric configuration of the subje :t nozzles, in conjunction with the pressurizer heater penetrations, make the Code-required volumetric examination impractical to complete. Additionally, the staff concludes that, ts. sed on the nozzle examinations that can be completed, the proposed alternative provides reasonable assurance of the structuralintegrity of the subject components. Therefore, relief is granted and the alternative imposed pursuant to 10 CFR 50.55a(g)(6)(i).

Request for Relief No. 2-TYP-2-83.140-1, Rev. 0: ASME Code,Section XI Examination Category B-D, item B3.140, requires 100% volumetric examination of the steam generator (primary side) nozzle inside radius sections as defined in Figure IWB-2500-7. i Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from 100% volumetric examination of the steam generator (primary side) nozzle inside radius sections:

2RCS*SG21 A-N-1 AIR 2RCS*SG218-N-2BIR 2RCS*SG21 A-N-1 BIR 2RCS*SG21C-N-3 AIR 2RCS*SG218-N-2 AIR 2RCS*SG21C-N-3BIR The steam generator primary nozzles at BVPS-2, are integrally cast with the channel head. j This design results in a complex outside surface geometry, making correlation of search unit position difficult. Variations in the thickness of the nozzle sections require the use of a calibration standard that encompasses the metal path needed to reach the inner radius I reflectors. In addition, the as-cast outside surface limits the search unit contact, and the as- l l welded clad inside surface results in spurious indications. The configuration of the steam  ;

generator primary nozzle inside radius does not lend itself to meaningfulinterrogation by t ultrasonic techniques. To achieve the Code-Required volumetric examination of the steam generator nozzle inside radius sections, the nozzles would have to be redesigned and i modified or replaced. Therefore, the steam generator nozzle design and surface conditions I make the l r ,

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Code-required examination impractical. Imposition of the Code requirement would cause a burden on the licensee.

I As an alternative, the licensee proposed to perform visual examination (VT-1) of the inside surface of the nozzle inner radius section. This examination will provide reasonabk assurance l that unacceptable inservice flaws have not developed in the steam generator nozzle inner i

radius sections; and will provided reasonable assurance of structuralintegrity of the subject components.

Therefore, the NRC staff finds that the Code-required volumetric examina'. ion of the steam generator nozzle inside radius sectior s is impractical at BVPS-2 and that the licensee's proposed alternative provides reasonable assurance of structuralintegrity of the subject components. Hence, relief is granted and the alternative imposed pursuant to 10 CFR 50.55a(g)(6)(i).

Request for Relief No. 2-TYP 2 B5.70-1, Rev. 0:

ASME Code,Section XI, Examination Category B F, Item 85.70, requires 100% volumetric and surface examination of steam generator nozzle-to-safe end butt welds that are NPS 4 or larger, as & fined in Figure IWB-2500-8.

Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from 100% volumetric examination of the following steam generator nozzle-to-safe end butt welds that are NPS 4 or larger:

2RCS-001-F04 2RCS-002-F01 2RCS-004-F04 2RCS-005 F01 2RCS-007-F04 2RCS-008-F01 The Code requires 100% volumetric and surface exarnination of the subject steam generator nozzle-to-safe end welds. However, the as-cast nozzle and elbow geometries and surface conditions make the complete volumetric cramination impractical. To meet the Code coverage requirements, the nozzle safe ends and associated piping would require modification to allow access for examination. !mposition of this requirement would create a burden on the licensee.

The licensee's proposed alternative is to perform a complete surface examination and to perform the ultrasonic (volumetric) examination to the maximum extent practical.

Approximately'70% of the Code-required volume can be examined and 100% of the Code-required surface can be examined. The combination of the complete surface examination and the volumetric examination to the maximum extent practical will provide reasonable assurance of continued structuralintegrity.

The NRC staff has determined that completion of the Code-required 100% volumetric l examination is impractical for the listed steam generator nozzle-to-safe end butt welds.

l Additionally, the NRC staff finds that 70% volumetric coverage coupled with the Code-required surface examinations will provide reasonable assurance of the structuralintegrity of the safe end welds. Therefore, based on the impracticality of meeting the Code coverage requirements l

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for the subjm 'ds and the reasonable assurance provided by the proposed alternative, relief is granteo ai.J the alternative imposed pursuant to 10 CFR 50.55a(g)(6)(i).

1 Request for Relief No. 2-TYP-2-N 524:

I ASME Code,Section XI, Examination Category B-J requires that volumetric and/or surface examinations be performed on longitudinalwelds as defined by Figure IWB-2500-8. The 1 examination must include at least one pipe-diameter length but not more than 12 inches of each longitudinal weld intersecting the circumferential weld required to be examined by Examination Categories B-J and B-F. Examination Categories C-F-1 and C-F-2 require 100%

volumetric and/or surface examination, as defined by Figure IWC-2500-7, -12 and -13, for a length equal to 2.5 times the pipe thickness for each longitudinal weld intersecting j circumferential welds that are examined. I l

Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the alternative requirements contained in Code Case N-524 in lieu of the Code examination requirements for Class 1 and 2 longitudinal welds.

ASME,Section XI requires the examination of one pipe diameter, but not more than 12 inches, of Class 1 longitudinal piping welds. For Class 2 piping welds, the length of longitudinal weld required to be examined is 2.5 times the pipe thickness. These lengths are measured from the intersection with the circumferential weld. The licensee's proposed alternative is to examine only the portions of longitudinal weld within the examination area of the intersecting circumferential weld in accordance with Code Case N-524, Altemative Examination Requirements for Longitudinal Welds in Class 1 and Class 2 Piping.

Longitudinal welds are produced during the manufacture of the piping, not in the field as are circumferential welds. Consequently, longitudinal welds are fabricated under strict manufacturing standards, which provides assurance of structuralintegrity. These welds have also been subjected to the preservice and initial inservice examinations, which provide additional assurance of structuralintegrity. No significant loading conditions or material degradation mechanisms have been identified to date that specifically relate to longitudinal seam welds in nuclear plant piping. The most critical region of the longitudinal weld is the portion that intersects the circumfmntial weld. Since this region will be examined during the examination of the circumferential weld, the t.tah cetermined that the licensee's proposed attemative provides an acceptable level of qus'ity and safety, and reasonable assurance of weld integrity.

The NRC staff concludes that the most critical region of the longitudinal weld will be examined during the examination of the circumferential weld; and the licensee's proposed alternative, to use Code Case N-524, provides an acceptable level of quality and safety. Therefore, the licensee's proposed attemative is authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use of i Code Case N-524 is authorized for the second 10-year interval at BVPS-2, or until the Code Case is approved for general use by reference in RG 1.147. After that time, the licensee may continue to use the Code Case with the limitations, if any, hsted in RG 1.147.

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l Request for Relief No. 2-TYP-2 B-G-1, Rev. 0:

l ASME Code,Section XI, Examination Category B-G-1, item B6.10, requires a 100% surface examination of RPV closure head nuts once each 10-year interval.

Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed an alternative to the surface {

examination of the reactor vessel closure head nuts. The licensee stated- l "The altemative to the examination requirement is to adopt the 1989 Addenda to the 1989 Edition of ASME XI for Examination Category B-G-1, which requires a visual VT-1 examination on all 58 closure head nuts once during the ten-year intental.

The licensee requested relief from performing the Code-required surface examination on the RPV closure head nuts. As an alternative, the licensee proposed to adopt the 1989 Addenda to the 1989 Edition of ASME XI which requires a VT-1 visual examination of RPV closure head nuts. The 1989 Edition, Examination Category B-G-1 requires that all items, with the exception of the surface examination for RPV closure head nuts and closure head studs (when removed), be examined using VT-1 examination and/or volumetric examination (as applicable).

The 1989 Edition of the Code, Examination Category B-G-1, item B6.10, does not provide j acceptance criteria for surface examination of RPV c'osure head nuts. (At that time the acceptance criteria were in the course of preparation). However, acceptance criteria for surface examinations relating to other components, such as piping, are available and are related to linear indications. Acceptance or rejection of linear indications is based upon their length. Typicalindications that would require corrective action on RPV closure head nuts are associated with degradation mechanisms such as boric acid attack, corrosion, or handling mechanisms such as galled threads and deformation. Typical surface examination procedures and techniques are not qualified to identify these forms of degradation.

Article IWB-3000, Acceptance Standard, IWB-3517.1, VisualExamination, VT-1, describes conditions that require corrective action prior to continued service of bolting and associated nuts. lWB-3517.1 requires crack-like flaws to be compared to the flaw standards of (WB-3515.

Because the VT-1 visual examination acceptance criteria include evaluation of crack-like indications and other relevant conditions requiring corrective action, such as deformed or sheared threads, localized corrosion, deformation of part, and other degradation mechanisms, it can be concluded that the VT-1 visual examination provides a more comprehensive assessment of the condition of the closure head nut. The NRC staff determined that a VT-1 visual examination provides an acceptable leve: of quality and safety, and reasonable assurance of component integrity for the RPV closure head nuts.

The licensee has proposed, as an attemative to the surface examination requirement of the 1989 Code, the use of the 1989 Addenda, which requires a VT-1 visual examination. The VT-1 visual examination, with its associated acceptance criteria, provides a more comprehensive assessment of the condition of the closure head nuts and, thus, an acceptable level of quality and safety. Therefore, the licensee's proposed alternative is authorized pursuant to 10 CFR l

50.55a(a)(3)(i).

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Request for Relief No. 2-TYP-2-C6.10-1, Rev. 0:

ASME Code,Section XI, Table IWC-2500-1, Examination Category C-G, item C6.10, requires ~

a surface examination on the inside or outside surface of pump casing welds as defined in Figure IWC-2500-8. In the case of multiple pumps of similar design, size, function, and service in a system, the examination of only one pump among a group of multiple pumps is required.

Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed an alternative to the Code-required surface examinations of the following pump casing welds:

1 Recirculating Spray Pump Casing Welds 2RSS*P21 A-C-9,10,12,15,17,18,23 25, and ,

2RSS*P21 A-L-11,13,16, 21., 24. l The licensee stated:

"The altemative to the examination requirement will be to perform the surface examination on the accessible portions of the welds to the maximum extent possible. If any of the l Recirculating Sprey Pumps are disassembled for Maintenance or other reasons, the required examinations shall be performed. The complete examination of the other eleven l casing welds and the periodic functional testing and associated VT-2 examinations will I provide an adequate measure of assurance of the integrity of the noted welds. If the pump l casing welds do not become accessible during the 10 year interval, it will be so noted in the l final outage summary report of the interval."

The pump casing welds listed in this request for relief are below floor level, or are inaccessible due to welded gusset plate interference. Gaining access to the subject welds would require removal of the pump casings from the sump or removal of the welded gusset plates.

Disassembly of the pump and removal of the gusset plates for the sole purpose of examination is quite involved and poses a significant risk of damage to the pump components.

Disassembly of the pumps solely for the purpose of inspection would result in a considerable burden for the licensee.

The licensee is able to perform essentially 100% of the required examinations on eleven of the pump casing welds and will examine the accessible portions of the remaining welds to the maximum extent possible. Also, if any recirculating spray pumps are disassembied for maintenance or other reasons, the Code-required examinations will be performed.

The NRC staff finds that performing the required examinations of the subject pump casing welds in accordance with the Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The NRC staff has determined that the licensee's proposed altemative will detect any significant degradation and provide reasonable assurance of operational readiness of the subject pumps. Therefore, the licensee's proposed attemative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

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1 Request for Relief No. 2-TYP-2-APP l-1, Fiev. 0:

ASME Code, Section Xi. IWB-2500-1, Examination Category B-G-1, Class 1 Bolts and Studs, Appendix 1, Paragraph l-2300, requires th&t ultrasonic inspection of bolts and studs M conducted in accordance with Appendix VI, as supplemented by Appendix 1.

Pursuant to 10 CFR 50.55a(a)(3)(i), tne licensee proposed an alternative to the Code requirement:

• DLC UT personnel will be qualified using the PDI Performance Demonstration In:tiative Program and DLC written practice OSP 2.11, which meets the requirements of Section XI, Appendix Vil (1989 Edition). The UT examination procedure applied by these qualified individuals is based on PDi Procedere PDI-UT-5, Revision A, and has been demon *trated l on DLC qualification standards, which meet both Appendix VI and Appendix Vlli, l Supplement 8 requirements with respect to qualification notch depth and reflective area.

Through the use of the PDI program for personnes qualification and IWA-2300 demonstration on BVPS bolting configurations for procedure qualification, valid quar ?d techniques will be used by qualified individuals to perform UT examinations on Class (Category B-G-1) bolts and studs."

The licensee proposed that DLC UT personnel be qualified using the Performance Demonstration Initiative (PDI) Program and DLC written practice QSP 2.11, which meets the iequirements of the 1989 edition of Section XI, Appendix Vil,in lieu of meeting ASME Appendix Vi requirements. Appendix VI, Ultrasonic Examination of Bolts and Studs, requires that the personnel qualification for ultrasonic examination of bolts and studs be renewed using a performance qualification test when the examiner has not performed the bolting examination technique for which he was originally qualified for a period of 6 months. The ISI examinations for Class 1 and Class 2 botting are performed during refueling outages, which are typically on an 18-rmnth cycle. Therefore, performing bolting examinations within a 6-rnonth period is unlikely with a single- or dual unit plant. Appendix VI, has been removed from later editions of the Code and superseded by Appendix Vll and Vill.

Appendix Vil, Qualification of Nondestructive Examination Personnel Fct Ultrason.c Examination, Paragraph V//-4400 requires demonstration of continued profic;ency by successful completion of a Practical Examination (Level I and il personnel) or Specific Examination (Level 111 personnel) after a 12-month period of inactivity. Therefore, allowing the licensee to requalify personnel after 12 months of inactivity for ultrasonic examination of B-G-1 l

bolting is consistent with other Class 1 ultrasonic examination qualification requirements.

Hence, the NRC staff determined that the licensee's proposed alternative, to qualify DLC personnel usir.g the PDI program meeting the requirements of Section XI. Appendix Vil for Category B-G-1 bolting, provides an acceptable level of quality and safety.

The NRC staff conrNdes that the licensee's proposed alternative provides an acceptable level of quality and safety. Therefore, the licensee's proposed altemative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).

E Request for Relief No. 2-TYP 2-UT-1, Rev. 0:

ASME Code,Section XI, Article i provides rules for the ultrasonic examinations required by IWA-2232 through reference to other Code Sections and Articles as supplemented by specific Appendix I Supplements.

Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed an attemative to the ultrasonic examination requirements of the 1989 Edition of ASME XI. The licensee stated:

"The altemative to the 1989 Edition of the ASME XI Code examination requirements for volumetric UT examination of austenitic piping welds, ferritic piping welds and bolting is implementation of ultrasonic examination procedures meeting the requirements of the PDI Program Description, Revision 1.

"The attemative to the 1989 Edition of ASME XI Code examination requirements for cast austenitic piping weld and dissimilar metal welds is implementation of DLC ultrasonic procedures that have been qualified and demonstrated to the ANil, and incorporate technical guidance from PDI techniques and procedures, where applicable.

The licenwe has proposed, as an altemative to the requirements of the 1989 Edition of XI, the use of ultrasonic examination procedures that either meet the requirements of, or take technical guidance from, the PDI. The PD) has been developed by a group of utilities responsible for implementing a performance demonstration program that meets the intent of Appendix Vill of ASME Section XI. Four of the six procedures in the proposed alternative were prepared using the technical requirements associated with the applicable PDI procedures. The remaining two procedures, for dissimilar metal and cast austenitic piping, take technical guidance from the PDI procedures. The PDI procedures were qualified and demonstrated successfully to three domestic Authorized Nuclear Inservice Inspection (ANil) organizations. In addition, DLC has demonstrated the subject UT procedures to their ANil. The proposed altemative examina{ ions have been demonstrated to be equivalent or superior to those specified in the 1989 Edition of Section XI and, therefore, provide an acceptable level of quality and safety.

The staff concludes that the licensee's proposed alternative to the examination requirement provides an acceptable level of quality and safety. Therefore, the licensee's proposed attemative examination is authorized pursuant to 10 CFR 50.55a(a)(3)(i).

Request for Relief No. 2 TYP-2-N-509, Rev. 0:

ASME Code,Section XI, IWB-2500-1 Examination Categories B-H and B-K-1, require 100%

volumetric or swface examinationi as applicable, of integrally welded attachments exceeding 5/8 inches design thtekness Exemination Category C-C, Table IWC-2500-1, requires a surface examination of integrally welded attachments exceeding a 3/4-inch design thickness.

Categories D-A, D-B and D-C, Table IWD-2500-1, requires a visual (VT-3) examination of integrally welded attachments.

Pursuant to 10 CFR 50.55a(a)(3)(i), the !icensee proposed to use the alternative iequirements contained in Code Case N-509, Altemative Rules forthe Selection and Examination of Class 1, 2, and 3 Integrally Welded Attachments. The licensee stated; "The attemative to the 1989 Edition of the ASME XI Code examination requirement for welded attachments is to implement Code Case N-509 with the exceptions noted above, implementation would begin in the Second Ten-Year Interval for BV-2, commencing with 2R07, scheduled for March,1998."

"The following table identifies, by examination category and item number, the total number of non-exempt welded attachments and the number of examinations scheduled.

ASME ltem Total Examinations Category No. Number Scheduled N-509 Examination Requirement B-K B10.10 5 1 One Welded Attachment per vessel

• B-K B10.20 20 3 10% of total number C-C C3.10 38 3 One welded attachment per vessel

• C-C C3.20 155 16 10% of total number C-C C3.30 62 8 10% of total number D-A D1.10 26 12 All welded attachments per vessel

• D-A D1.20 405 47 10% of total number, prorated by system l

• ln the case of muniple vessels of similar design. func+on and service. examination is limited to one of the muttspie vessels I

The licensee has proposed to apply the requirements of Code Case N-509 as an altemative to i the Code requirements for the examination of integrally-welded attachments on Class 1,2, and 3 piping and components. The licensee, as part of its alternative, proposed to supplement the Code Case with a minimum examination sample of 10% of integral attachments to non-ex6mpt  ;

Class 1,2, and 3 piping, pumps, and valves distributed in each Code Class / System. The staff l determined that most of the Codo examination requirements are based on sampling to ensure the detection of service-induced degradation, extending the sampling philosophy to the integral attachment welds provides an equivalent level of quality and safety. The 'are, the licensee's l proposed attemative, to use Code Case N-509 with the minimum sample size of 10% )

distributed in each Code Class / System of all non-exempt Class 1,2, and 3 integrally welded  ;

attachments to piping, pumps, and valves provides an acceptable level of quality and safety.

l The NRC staff concludes that the use of Code Case N-509 for the subject components provides an acceptable level of quality and safety. Therefore, the licensee's proposed attemative, to use Code Case N-509, with the additional proposal to ensure that the sample size specified for piping, pumps, and valves will be a minimum of 10% of the total number of Class 1,2, and 3 integrally welded attachments, is authorized pursuant to 10 CFR

.o 50.55a(a)(3)(i). The use of Code Case N-509 is authorized for the second interval or until the Code Case is approved for general use by reference in RG 1.147. After that time, the licensee must follow the conditions, if any, specified in the RG.

3.0 CONCLUSION

The NRC staff concludes that, based on its review of the licensee's documens provided, no deviations from regulatory requirements or commitments were identified in the licensee's Second 10-Year inspection Interval ISI Program Plan for BVPS-2.

The staff concludes that certain inservice examinations for Relief Requests 2-T' - 83,110-1,2-TYP-2-83.140-1, and 2-TYP-2-85.70-1 are impractical and that the licenseek Japused alternatives provide reasonable assurance of structuralintegrity of the subject components.

Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), relief is granted and the alternative imposed.

The relief granted is authorized by law and will not endanger life or property or the common G.efense 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. ,

l The staff concluded that the licensee's proposed alternatives contained in Requests for Relief Nos. 2-TYP-2-B-G-1,2-TYP-2-APP-l-1,2-TYP-2-UT-1,2-TYP 2-N-509,2-TYP-2-N-521, and 2-TYP-2-N-524, provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 60.55a(a)(3)(i) the licensee's proposed alternatives are authorized for the current interval, in addition, Requests for Relief Nos. 2-TYP-2-N-509,2-TYP-2-N-521, and 2-TYP-2-N-524, are authorized until the Code Cases contained in the requests for relief are approved for general use by reference in RG 1.147. After that time, the licensee must foilow the conditions, if any, specified in the RG.

l The staff concluded that for the alternative contained in Request for Relief No. 2-TYP-2-C6.10-1, that Code compliance results in hardship or unusual difficulty without a compensating increase in safety and that the proposed alternative provides reasonable assurance of structuralintegrity of the subject components. Therefore, the alternative contained in Request for Relief No. 2-TYP-2-C6.10-1, is authorized pursuant to 10CFR50.55a(a)(3)(ii) for the current interval.

Attachment:

Technical Evaluation Report Principal Contributers: D. Collins T. McLellan Date: April 9,1999 l

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