ML20245H985

Requests Responses to Encl Questions Re Requests for Relief from ASME Code Requirements of Second 10-yr Inservice Insp within 45 Days of Ltr Receipt

ML20245H985
Person / Time
Site:	Farley
Issue date:	08/03/1989
From:	Reeves E Office of Nuclear Reactor Regulation
To:	Hairston W ALABAMA POWER CO.
References
TAC-65482, TAC-71578, NUDOCS 8908170394
Download: ML20245H985 (23)

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August 3, 1989

• Docket No. 50-348-and 50-364 Mr. W. G. Hairston, III Senior Vice President Alabama Power Company 40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201

SUBJECT:

SECOND 10-YEAR INSERVICE INSPECTION (ISI) PROGRAMS, REQUEST FOR ADDITIONAL INFORMATION FOR JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 (TACS 65482 and 71578)

By letter dated September 8,1988, you provided Revisions 1 and 2 to the subject program for Unit I and requested additional reliefs to ASME Code requirements.

Also, by letters dated December 16, 1988, and February 8, and March 23, 1989, you provided similar ISI programs and relief requests for Unit 2. Our letter dated March 31, 1989 granted interim reliefs for the Unit 2 sixth refueling outage which started March 25, 1989. The enclosed consultant, Idaho National Engineering Laboratory (questions, generated by ourINEL),

for Units 1 and 2.

In order for us to continue the reviews, you are requested to provide responses to these questions within 45 days of receipt of this letter. For expediency, we are providing questions and comments relating to your proposals for both units by enclosures to this letter. However, you may desire to provide two separate letter responses. In addition, please forward a copy of your response directly to INEL, attention Boyd Brown.

The reporting and/or recordkeeping requirements contained in this letter 3 affect fewer than 10 respondents; therefore OMB clearance is not required i under P.L.96-511. I I

Sincerely, Original Signed By:

8908170394 090003 I Edward A. Reeves, Senior Project Manager PDR ADOCK 05000348 j Project Directorate 11-1  ;

Division of Reactor Projects I/II d) PNU Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/encls: 1 See next page i DISTRIBUTION I Docket File- Glainas, 14/H/3 EJordan, 3302MNBB NRC & Local PDRs PAnderson BGrimes, 9/A/2 f PDII-1 Reading EReeves ACRS(10)

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. Mr. W. G. Hairston, III Alabama Power Company Joseph M. Farley Nuclear Plant 1 cc:

Mr.'R. P. Mcdonald Resident Inspector Executive Vice President U.S. Nuclear Regulatory Commission Alabama Power Company P. O. Box 24 - Route 2 I

P. O. Box 2641 Colunbia, Alabama 36319 Birmingham, Alabama 35291-0400 l Mr. Bill M. Guthrie D. Biard MacGuineas, Esquire I l Executive Vice President- Volpe, Boskey and Lyons Alabama Power Company 91B 16th Street, N.W.

P. O. Box 2641 Washington, D.C. 20006 Birmingham, Alabama 35291-0400 Mr. Louis B. Long, General Manager Mr. Charles R. Lowman Southern Company Services, Inc. Alabama Electric Corporation P. O. Box 2625 P. O. Box 550 Birmingham, Alabama 35202 Andalusia, Alabama 35420 Chairman Regional Administrator, Region II Houston County Commission U.S. Nuclear Regulatory Commission Dothan, Alabama 36301 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 Ernest L. Blake, Jr., Esquire Shaw, Pittman, Potts and Trowbridge Claude Earl Fox, M.D.

2300 N. Street, N.W. State Health Officer Washington, DC 20037 State Department of Public Health State Office Building Montgomery, Alabama 36130 Robert A. Buettner, Esquire Balch, Bingham, Baker, Hawthorne, Mr. D. N. Morey Williams and Ward General Manager - Farley Nuclear Plant P. O. Box 306 P. O. Box 470 Birmingham, Alabama 35201 Ashford, Alabama 3631? l l

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• Enclosure 1 ALABAMA POWER COMPANY JOSEPH M. FARLEY NUCLEAR POWER PLANT, UNIT 1, DOCKET NUMBER 50-348 Reauest for Additional Information - Second 10-Year Interval Inservice Inspection Proaram

1. Scoce/ Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which are classified as American Society of Mechanical Ent.neers (ASME) Boiler and Pressure Vessel Code Class 1, 2, and 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in the ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during 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 intervals, 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 modifications listed therein. Based on the start date of December 1,1987 for the second 10-year interval, the Inservice Inspection (ISI) Program has been prepared 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 piping welds 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).

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As required.by 10 CFR 50.55a(g)(5), if the' licensee determines that

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certain Code examination requirements are impractical and relief is requested, the licensee shall submit information to tea Nuclear Regulatory Commission (NRC) to support that determination.

The staff has reviewed the available information in the Joseph M. Farley Nuclear Power Plant, Unit 1, Second 10-Year Interval ISI Program, through Revision 2, submitted September 9, 1988, and the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical.

1 Many of the relief requests included in the ISI Program make general statements about component design, mounting, geometry, etc., not permitting the Code-required. examinations. However, in order for the staff to evaluate the relief requests, the Licensee must provide discussions or drawings showing the specific obstruction for each of the-areas for which relief is requested. In order for relief to be granted, sufficient technical justifications must be provided which demonstrate the impracticality of the examinations.

2. Additional Information/ Clarification Reouired Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the ISI Program and relief requests:

i A. Provide the staff with an itemized listing of the components subject to examination during the second 10-year interval.

B. Provide isometric and/or component drawings showing the welds, components, and supports which Section XI of the ASME Code requires to be examined during the second 10-year interval. The drawings, along with the requested listing, will permit the staff to determine if the extent of ISI examinations meets the applicable Code requirements.

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l C. Provide a listing of the NDE examination procedures being used during the second 10-year inspection interval at Farley, Unit 1.

i D. Based on the 74S75 Section XI exclusion criteria contained in l IWC-1220, the Farley, Unit 1, Second 10-Year Interval ISI Program, Paragraph 3.1.1 (page 3-1), exempts components in the RHR, ECC, and CHR systems (i.e., safety injection system) from inservice examinations when both the design pressure and temperature are equal to or less than 275 psig and 200"F, respectively.

10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2 piping welds in the RHR, ECC, and CHR systems be examined; these systems should not be completely exempted from inservice volumetric examination based on the 74S75 Section XI exclusion criteria contained in IWC-1220. To satisfy the inspection requirements of General Design Criteria 36, 39, 42, and 45, the inservice inspection program should include volumetric examination of a representative sample of welds in these systems. The staff points out that later editions and addenda of the Code do not permit the temperature / pressure exclusion for these systems. Verify that the temperature / pressure exclusion will not be used for these systems and that the ISI Program Plan will be revised to include volumetric examinations of a representative sampling of welds in the RHR, ECC, and CHR systems.

E. As stated above, 10 CFR 50.55a(b)(2)(iv) requires that pipe welds in RHR, ECC, and CHR systems shall be examined. The extent of these examinations shall be determined by the requirements of paragraph IWC-1220, Table IWC-2520 Category C-F and C-G, and paragraph IWC-2411 in the 1974 Edition and Addenda through Summer 1975 of Section XI of the ASME Code. The " extent of examination" does not mean that the welds can be exempted by the " chemistry control" exclusion criteria. The control of water chemistry to minimize stress corrosion is not an acceptable basis for exempting components from examination because practical evaluation, review, and acceptance standards cannot be defined. Operating data indicate that " chemistry control" has not supported the exclusion, 3

Ec therefo.re, later editions and addenda of the Code have deleted the chemistry control exclusion. Verify that the chemistry control exclusion will not be used and that the ISI Program will be revised to include examinations for these components.

F. With regard to limitations' due to' metallurgical properties of cast stainless steel-(SA351 Grade CF8A), the staff has continued to monitor the development of new or improved examination techniques.

As improvements in these areas are achieved, the staff is requiring that these new techniques be made part of the ISI examination procedures. Discuss the ISI examination procedures for the ultrasonic examination of the Farley, Unit 1, Primary Coolant System and, in particular, any improved examination techniques which may have been incorporated.

G. Paragraph 1.11(D), " Augmented Inspections," states: "The main steam lines will be inspected in accordance with plant Technical }

Specification 4.4.11.3 and Branch Technical positions APCSB-3-1 and MEB-3-1."

Verify that the feedwater lines will also be examined as required by these documents.

H. Paragraph 1.12 (page 1-5), " Code Cases," of the ISI Program states: " Code cases listed in Regulatory Guide 1.147 will be used by Alabama Power Company as necessary. All other code cases will be used on a case-by-case basis."

List the ASME Code Cases that will be used for the second 10-year inspection interval.

I. Provide sketches and a list of the ultrasonic calibration standards being used during the second 10-year interval ISI at Farley, Unit 1. This list should include the calibration standard identifications, material specifications, and dimensions.

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J. Relief Requests RR-1, RR-4, RR-5, and RR-6: Relief is requested from using the Code required calibration blocks for ultrasonic

] examinations of cer nin welds.

Appendix III, " Ultrasonic Examination of Piping Systems," of Section XI of the Code requires that basic calibration blocks be made from material of the same nominal diameter and nominal wall thickness or pipe schedule as the pipe to be examined. The calibration blocks for similar metal welds shall be fabricated from the material specified for the piping being joined by the weld.

Calibration blocks for dissimilar metal welds shall be fabricated l from the material specified for the side of the weld from which the l 1

examination will be conducted. If the examination will be conducted from both sides, calibration reflectors shall be provided in both materials.

The staff considers inservice volumetric examinations of Code Class 1 and 2 systems crucial to plant safety and, therefore, feels that proper calibration standards should be obtained and utilized for all ISI examinations.

Provide tho following information with regard to ISI calibration standards:

(1) For each of the subject relief requests, provide technical justification as to why obtaining the appropriate calibration block is impractical.

(2) Relief Request RR-1: What are the specific differences between the Code-required calibration blocks and the proposed alternative calibration blocks?

(3) Relief Request RR-4: Has ASME Code Case N-435-1, as approved and documented by the NRC in Regulatory Guide 1.147, been considered as an alternative to Relief Request RR-47 (4) Relief Request RR-5: Identify the calibration blocks for which relief is requested and provide information with regard to the actual wall thickness and curvature differences between the calibration blocks and the components to be extmined.

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(5) Relief Request RR-6: Identify the calibration blocks for which relief is requested and provide additional information with regard to the materials of fabrication and acoustic compatibility with the component to be examined.

K. Relief Requests. RR-8, RR-9, RR-10, RR-11, RR-14, RR-18, RR-19, and RR-20: Provide the drawings referenced in each of the subject-relief requests with the applicable weld (s) or component (s) for which relief. is requested identified on the drawing.

L. ' Relief Request RR-8 requests relief from examining 100% of the Code-required volume of one of the Reactor Pressure Vessel lower head meridional welds. Approximately what percentage of the weld can be examined manually? Is it practical to examine portions of other lower head meridional welds to achieve an aggregate weld length total that is equivalent to the length of one lower head meridional weld and, therefore, meet the intent of the Code?

M. It is stated in Relief Request RR-9 that only 25% of the base metal on the nozzle side of the weld can receive the Code-required examination. Confirm that the pressurizer nozzle-to-vessel weld material and heat-affected zone on the vessel side of the weld will receive a 100% examination.

N. Relief Request RR-11: If relief from examining the nozzle inner radius sections is to be considered, sufficient technical justification demonstrating impracticality must be provided. What attempts have been made to obtain construction drawings, to select j

transducers, and to perform the Code-required volumetric examination of the nozzle inner radius sections? If the full Code-required volumetric examination cannot be completed, describe a "best effort" volumetric examination that could be performed.

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0. Relief Request RR-17: With regard to the reference system for welds and areas subject to surface or volumetric examination, what is the impact of marking the welds as the Code-required examinations are being performed?

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P. Relief Request RR-18: What percentage of each of the subject regenerative heat exchanger welds can and will receive the Code-required volumetric examination?

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Relief Request RR-20: Provide a discussion and/or sketches of the component configuration, location, and support design which demonstrates impracticality for surfaco examination of 20% of each of the charging pump integrally welded attachments.

l R. Relief Request RR-28: It appears that the Licensee is not sure whether or not relief is required as the relief request states "The flow restrictor assembly appears to be welded to the nozzle at the location of the inner radius. . . ." If relief from examining the nozzle inner radius sections is to be considered, sufficient technical justifications demonstrating impracticality must be provided. What attempts have been made to obtain construction drawings, to select transducers, and to perform the Code-required volumetric examination of the nozzle inner radius sections? If the full Code-required volumetric examination cannot be completed, describe a "best effort" volumetric examination that could be performed.

S. Relief Requests RR-21, RR-22, RR-23, RR-25, RR-29, and RR-30:

Provide a discussion of the operating, design, Code-required, and proposed alternative test pressures for each of the portion (s) of piping for which relief is requested and the adjacent piping from which it cannot be isolated. Discuss any modifications (temporary or permanent) which could be made in order to comply with the Code requirement and provide technical justifications as to why making such modifications is impractical for each of the subject relief requests.

T. Relief Request RR-24: It is stated that "Since at least one train of the RHR system is always required to operate, a system hydrostatic test down.tream of the relief valves is impractical."

Is this statement true during all plant conditions such as during vessel examinations when fuel is removed from the reactor?

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U. Relief Request RR-30: An alternative holding time for the h.ydrostatic test is proposed. The Licensee's " Basis for Relief"

'- states that Westinghouse recommends that the hydrostatic test of the secondary side of the steam generators be conducted at a pressure that is 1.25 times Pd; however, in the Licensee's proposed " Alternative Examination," it is stated that the Class 2 portions of the steam generator and related piping will be hydrostatically tested at a pressure that is 1.25 times P sv-Provide clarification of this discrepancy.

V. Relief Request RR-31: Discuss the component cesign and mounting details that preclude visual examination of the Class 3 service water pumps.

W. Relief Request RR-33: Relief is requested from performing the Code-required system hydrostatic pressure test of portions of Class 3 piping and components in the Service Water, Component Cooling Water, Chemical and Volume Control, Reactor Makeup, and Spent Fuel Pool Cooling systems. It is stated that hydrostatic testing is " impractical since these systems operate continuously during all modes of plant operation." This is considered to be an inadequate technical basis. Provide detailed technical justifications demonstrating impracticality and discuss the following concerns with regard to most of the systems involved (i.e., service water, component cooling water, chemical and volume control, reactor makeup): Are these systems required by the Technical Specification to be operable in all modes (e.g., during vessel examinations when fuel is removed from the reactor)? Do any of these systems have multiple trains of which one could receive the Code-required examination? Do these systems have portions which can be " valved out" to accommodate the Code-required hydrostatic test?

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X. Relief Request RR-34: Relief is requested from hydrostatic testing of C h ss 3 spray additive piping and components in the containment spray system. It is stated that "a system hydrostatic test at 8

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1.25 P gy would not provide a meaningful test." The regulations provide for granting relief-from certain Code requirements if.they are demonstrated to be impractical. Relief cannot be granted just because the Licensee does not have confidence in the results of the Code-required hydrostatic test. Technical justifications demonstrating impracticality are required for granting relief.

Provide information that demonstrates that the Code-required hydrostatic test is impractical and that relief is justified.

Y. Relief Request RR-35: Relief is requested from the visual (VT-2) examination of the buried piping of the Service Water system in accordance with Paragraph IWA-5244 of Section XI. Confirm that the system hydrostatic test pressure will be as required by Paragraph IWD-5223. Verify that the Code-required visual (VT-2) examination of all unburied portions of the Service Water system piping will be performed as well as the proposed alternative examination of the buried piping.

Z. Relief Requests RR-36 and RR-44: Relief is requested from performing the Code-required visual (VT-2) examination of Class 3 heat exchanger tubes. Verify that these components will be pressurized to the Code-required test pressure and evaluated for leakage.

AA. Relief Request RR-37: Relief is requested from performing the ]

l Code-required visual examination of Class 3 cooling coils. Verify that these components will be pressurized to the Code-required test pressure and evaluated for leakage.

BB. Relief Request RR-38: Provide technical justifications which demonstrate the impracticality of performing the Cede-required l hydrostatic tests of the Class 3 pressure retaining piping of the l auxiliary steam system. Provide the operating, design, and l Code-required hydrostatic test pressure for this piping. Discuss any modifications (temporary or permanent) which could be made in order to comply with the Code requirement and provide technical 9

justifications as to why making such modifications is impractical.

If modifications are impractical, can these lines be hydrostatically testcJ 11ong with the adjacent piping from which they cannot be isolated?

CC. Relief Request RR-45 is considered generic in nature. The Licensee has not provided adequate technical justifications for the specific systems (lines) to justify granting relief based on impracticality. The regulations do not provide for granting generic relief requests. In order to determine that the Code requirement is impractical and to evaluate the effects on the overall plant safety by performing an alternative test, the specific systems (lines) for which relief is being requested would have to be evaluated.

The Licensee should provide explicit information so that this relief request can be evaluated. This information should include, but not be limited to:

(1) A list of the lines and the boundaries of the portions of those lines for which relief is being requested; l (2) Specific P&ID drawings with the applicable portion of the piping for which relief is requested identified on the drawing;

' (3) The operating, design, Code-required, and proposed alternative test pressures (the range in test pressures between the system's high and low elevations during the hydrostatic test) for the portion of piping for which relief is requested; and {

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(4) A discussion of the modifications required to comply with the l Code requirement and of the impact of makir.g the '

modifications.

DD. Relief Request RR-46: The regulations provide for granting relief from certain Code requirements if they are demonstrated to be impractical. Relief cannot be granted just because the Code-requirement is inconvenient. Technical justifications  !

demonstrating impracticality are required for granting relief. I Provide information that demonstrates that the Code required 10 i

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scheduling of hydrostatic tests is impractical and that relief is I

justified. If relief were to be considered, confirm that any alternative scheduling of the hydrostatic tests will not result in ,

greater than ten years elapsed time between hydrostatic tests. j The schedule for timely completion of this review requires that the Licensee provide, by the requested date, the above requested information and/or clarifications with regard to the Joseph M. Farley Nuclear Power Plant, Unit 1, Second 10-Year Interval ISI Program, through Revision 2.

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Enclosure 2

. ALABAMA POWER COMPANY

, JOSEPH M. FARLEY NUCLEAR POWER PLANT,-UNIT 2, DOCKET NUMBER 50-364 Reauest for Additional Information - Second 10-Year Interval Inservice Insocction Proaram

1. Scoce/ Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, 2, and 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in the ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during 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 intervals, 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 modifications listed therein.

Per the Nuclear Regulatory Commission's (NRC) letter, " Exemption from Certain Requirements of 10 CFR 50.55a(g)(4)(ii) - Joseph M. Farley Nuclear Plant, Unit 2," dated August 31, 1988, the Farley, Unit 2, Inservice Inspection (ISI) Program has been updated to the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section X1, which is also the Code of record for Farley, Unit 1, based on the stut 1

date of December 1,1987 for the second 10-year interval for Unit 1.

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Except 'for minor editorial and technical differences in design, the

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updated Unit 2 ISI Program is identical to the Unit 1 Second 10-Year Interval ISI Program, submitted by letters dated November 23, 1987

.(Revision 0) and September 9, 1988 (Revisions 1 and 2).

The ISI Program has been prepared to meet the requirements of the 83S83 except that the extent of examination for Code Class 1 piping welds 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).

The updated Farley, Unit 2, ISI Program will be used for the completion of examinations performed on Unit 2 during the third 40-month period of the first 10-year interval and will remain in effect through the first and second 40-month periods of the second 10-year interval until December 1, 1997.

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and relief is requested, the licensee shall submit information to the NRC to support that determination.

The staff has reviewed the available information in the Joseph M. Farley Nuclear Power Plant, Unit 2, Second 10-Year Interval ISI Program, Revision 0, submitted December 16, 1988, and the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical. The staff has also reviewed the Licensee's March 23, 1989 submittal which provided additional information on outage specific relief requests.

Many of the relief requests included in the ISI Program make general statements about component design, mounting, geometry, etc., not permitting the Code-required examinations. However, in order for the staff to evaluate the relief requests, the Licensee aust provide discussions or drawings showing the specific obstruction for each of the 2

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areas for which relief is requested. In order for relief to be granted,'

sufficient technical justifications must be provided which demonstrate the~ impracticality of. the examinations.

2.'" A'dditional Information/ Clarification Reauired Based on the above review, the staff has concluded that the following-information and/or clarification is required in order to complete the review of the ISI Program and relief requests:

L. A. Provide the staff with an~ itemized listing of the' components subject-to examination during the second 10-year interval.

B. Provide isometric an'd/or component drawings showing the welds, l components, and supports which Section XI of the ASME Code requires to be examined during the second 10-year interval. The drawings, along with. the requested listing, will permit the staff to determine if the extent of ISI examinations meets the applicableJ Code requirements.

C. Provide a listing of the NDE examination procedures being used during the second 10-year inspection interval at Farley, Unit 2.

D. Based on the 74S75 Section XI exclusion criteria contained in IWC-1220, the farley, Unit 2, Second 10-Year Interval ISI Program, Paragraph 3.1.1 (page 3-1), exempts components in the RHR, ECC, and CHR systems (i.e., safety injection system) from inservice examinations when both the design pressure and temperature are equal to or less than 275 psig and 200*F, respectively.

10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2 piping welds in the RHR, ECC, and CHR systems be examined; these systems should not be completely exempted from inservice volumetric examination based on the 74S75 Section XI exclusion criteria contained in IWC-1220. To satisfy the inspection requirements of General Design Criteria 36, 39, 42, and 45, the inservice inspection program should include volumetric examination of a 3

representative sample of welds in these systems. The staff points out that later editions and addenda of the Code do nt,t permit the

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temperature / pressure exclusion for these systems. Verify that the temperature / pressure exclusion will not be used for these systems and that the ISI Program Plan will be revised to include volumetric examinations of a representative sampling of welds in the RHR, ECC, j and CHR systems.

E. As stated above,10 CFR 50.55a(b)(2)(iv) requires that pipe welds  ;

in RHR, ECC, and CHR systems shall be examined. The extent of these examinations shall be determined by the requirements of paragraph IWC-1220, Table IWC-2520 Category C-F and C-G, and paragraph IWC-2411 in the 1974 Edition and Addenda through Summer 1975 of Section XI of the ASME Code. The "cxtent of examination" does not mean that the welds can be exempted by the " chemistry control" exclusion criteria. T. he control of water chemistry to minimize stress corrosion is not an acceptable basis for exempting components from examination because practical evaluation, review, and acceptance standards cannot be 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. Verify that the chemistry control exclusion will not be used and that the ISI Program will be revised to include examinations for these components.

F. With regard to limitations due to metallurgical properties of cast stainless steel (SA351 Grade CF8A), the staff has continued to monitor the development of new or improved examination techniques.

As improvements in these areas are achieved, the staff is requiring that these new techniques be made part of the ISI examination procedures. Discuss the ISI examination procedures for the ultrasonic examination of the Farley, Unit 2, Primary Coolant System and, in particular, any improved examination techniques which may have been incorporated.

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G. Paragraph 1.ll(D), " Augmented Inspections," states: 'The main st~eam lines will be inspected in accordance with plant Technical Specification 4.4.11.3 and Branch Technical positicnr APCSB-3-1 and MEB-3-1."

Verify that the feedwater lines will also be examined as required by these documents.

H. Paragraph 1.12 (page 1-5), " Code Cases," of the ISI Program states: " Code cases listed in Regulatory Guide 1.147 will be used by Alabama Power Company as necessary. All other code cases will be used on a case-by-case basis."

List the ASME Code Cases that will be used for the second 10-year inspection interval.

1. Provide sketches and a list of the ultrasonic calibration standards being used during the second 10-year interval ISI at Farley, Unit 2. This list should include the calibration standard identifications, material specifications, and dimensions.

J. Relief Requests RR-1, RR-4, RR-5, and RR-6: Relief is requested from using the Code-required calibration blocks for ultrasonic examinations of certain welds.

Appendix III, " Ultrasonic Examination of Piping Systems," of Section XI of the Code requires that basic calibration blocks be made from material of the same nominal diameter and nominal wall thickness or pipe schedule as the pipe to be examined. The calibration blocks for similar metal welds shall be fabricated from the material specified for the piping being joined by the weld.

Calibration blocks for dissimilar metal welds shall be fabricated from the material specified for the side of the weld from which the examination will be conducted. If the examination will be conducted from both sides, calibration reflectors shall be provided in both materials.

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>- The staff considers inservice volumetric examinations of Code l Class 1 and 2 systems crucial to plant safety and, therefore, feels j I

that proper calibration standards should be obtained and utilized for all ISI examinations.

Provide the following information with regard to ISI calibration l

standards:

(1) For each of the subject relief requests, provide technical justification as to why obtaining.the appropriate calibration I block is impractical.

(2) Relief Request RR-1: What are the specific differences between the Code-required calibration blocks and the proposed alternative calibration blocks?

(3) Relief Request RR-4: Has ASME Code Case N-435-1, as approved and documented by the NRC in Regulatory Guide 1.147, been considered as an alternative to Relief Request RR-47 (4) Relief Request RR-5: Identify the calibration blocks for which relief is requested and provide information with regard to the actual wall thickness and curvature differences between the calibration blocks and the components to be examined.

(5) Relief Request RR-6: Identify the calibration blocks for which relief is requested and provide additional information with regard to the materials of fabrication and acoustic compatibility with the component to be examined.

K. Relief Request RR-17: With regard to the reference system for welds and areas subject to surface or volumetric examination, what is the impact of marking the welds as the Code-required examinations are being performed?

1. . Relief Request RR-20: Provide a discussion and/or sketches of the component configuration, location, and support design which demonstrates impracticality for surface examination of 20% of each of the charging pump integrally welded attachments.

Relief Requests RR-21, RR-22, RR-23, RR-25, and RR-30: Provide a M.

discussion of the operating, design, Code-required, and proposed alternative test pressures for each of the portion (s) of piping for 6

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l l ' , 'i ' which relief is requested and the adjacent piping from which it .

l ca'nnot be isolated. Discuss any modifications (temporary or permanent) which could be made in order to comply with the Code f

) requirement and provide technical justifications as to why making such modifications is impractical for each of the subject relief

requests.

N. Relief Request RR-24: It is stated that "Since at least one train I of the RHR system is always required to operate, a system hydrostatic test downstream of the relief valves is impractical." .

Is this statement true during all plant conditions such as during i l

1 vessel examinations when fuel is removed from the reactor?

0. Relief Request RR-30: An alternative holding time for the hydrostatic test is proposed. The i.icensee's " Basis for Relief" states that Westinghouse recommends that the hydrostatic test of l' the secondary, side of the steam generators be conducted at a pressure that is 1.25 times Pd; however, in the Licensee's proposed " Alternative Examination," it is stated that the Class 2 portions of the steam generator and related piping will be hydrostatically tested at a pressure that is 1.25 times P sv-Provide clarification of this discrepancy.

P. Relief Request RR-33: Relief is requested from performing the Code-required system hydrostatic pressure test of portions of Class 3 piping and components in the Service Water, Component Cooling Water, Chemical and Volume Control, Reactor Makeup, and Spent Fuel Pool Cooling systems. It is stated that hydrostatic testing is " impractical since these systems operate continuously during all modes of plant operation." This is considered to be an inadequate technical basis. Provide detailed technical justifications demonstrating impracticality and discuss the following concerns with regard to most of the systems involved (i.e., service water, component cooling water, chemical and volume control, reactor makeup): Are these systems required by the Technical Specification to be operable in all modes (e.g., during 7

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vessel examinations &en fuel is removed from the reactor)? Do any of'these systems have multiple trains of which one could receive the Code-required o-w nation? Do these systems have portions which can be " valved out" to accommodate the Code-required l

hydrostatic test?

Q. Relief Request RR-34: Relief is requested from hydrostatic testing of Class 3 spray additive piping and components in the containment spray system. It is stated that "a system hydrostatic test at 1.25 P,y would not provide a meaningful test." The regulations provide for granting relief from certain Code requirements if they are demonstrated to be impractical. Relief cannot be granted just because the 1.icensee does not have confidence in the results of the Code-required hydrostatic test. Technical justifications 1 demonstrating impracticality are required for granting relief.

Provide information that demonstrates that the Code-required hydrostatic. test is impractical and that relief is justified.

R. Relief Request RR-35: Relief is requested from the visual (VT-2) examination of the buried piping of the Service Water system in accordance with Paragraph IWA-5244 of Section XI. Confirm that the system hydrostatic test pressure will be as required by Paragraph IWD-5223. Verify that the Code-required visual (VT-2) examination of all unburied portions of the Service Water system piping will be performed as well as the proposed alternative examination of the buried piping.

S. Relief Requests RR-36 and RR-44: Relief is requested from performing the Code-required visual (VT-2) examination of Class 3 heat exchanger tubes. Verify that these components will be pressurized to the Code-required test pressures and evaluated for leakage. l T. Relief Request RR-37: Relief is requested from performing the Code-required visual examination of Class 3 cooling coils. Verify l

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that these components will be pressurized to the Code-required test pr'essures and evaluated for leakage.

-U. Relief Request RR-38: Provide technical justifications which demonstrate the impracticality of performing the Code-required hydrostatic tests of the Class 3 pressure retaining piping of the auxiliary steam system. Provide the operating, design, and Code-required hydrostatic test pressure for this piping. Discuss any modifications (temporary or permanent) which could be'made in order to comply with the Code requirement and provide technical justifications as to why making such modifications is impractical.

If modifications are impractical, can these lines be hydrostatically tested along with the adjacent piping from which they cannot be isolated?

V. Relief Request RR-45 is considered generic in nature. The Licensee has not provided adequate technical justifications for the specific systems (lines) to justify granting relief based on impracticality. The regulations do not provide for granting generic relief requests. In order to determine that the Code requirement is impractical and to evaluate the effects on the overall plant safety by performing an alternative test, the specific systems (lines) for which relief is being requested would

have to be evaluated.

The Licensee should provide explicit information so that this relief request can be evaluated. This information should include, but not be limited to:

I (1) A list of the lines and the boundaries of the portions of those lines for which relief is being requested; (2) Specific P&ID drawings with the applicable portion of the l piping for which relief is requested identified on the drawing; (3) The operating, design, Code-required, and proposr:d alternative test pressures (the range in test pressures betu en the system's high and low elevations during the hydrostatic test) for the portion of piping for which relief is requested; and 9

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(4) A discussion of the modifications required to comply with the Co'de requirement and of the impact of making the modifications.

W. Relief Request RR-46: The regulations provide for granting relief from certain Code requirements if they are demonstrated to be impractical. Relief cannot be granted just because the Code-requirement is inconvenient. Technical justifications demonstrating impracticality are required for granting relief.

Provide information that demonstrates that the Code-required scheduling of hydrostatic tests is impractical and that relief is justified. If relief were to be considered, confirm that any alternative scheduling of the hydrostatic tests will not result in greater than ten years elapsed time between hydrostatic tests.

The schedule for timely completion of this review requires that the Licensee provide, by the requested date, the above requested information and/or clarifications with regard to the Joseph M. Farley Nuclear Power Plant, Unit 2, Second 10-Year Interval ISI Program, Revision O.

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