ML20006D679

Second 10-Yr Interval Inservice Insp Program:Bg&E,Calvert Cliffs Nuclear Power Plant,Units 1 & 2, Technical Evaluation Rept

ML20006D679
Person / Time
Site:	Calvert Cliffs
Issue date:	07/31/1989
From:	Beth Brown, Mudlin J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20006D669	List: ML20006D668 ML20006D671 ML20006D679
References
CON-FIN-D-6022 EGG-MS-8403, NUDOCS 9002140225
Download: ML20006D679 (34)

Text

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TECHNICAL EVALUATION REPORT t

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TECHNICAL EVALUATION REPORT ON THE SECOND.10-YEAR n.^

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INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

National BALTIMORE GAS AND ELECTRIC COMPANY, CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2, Eng/neer/ng DOCKET NUMBERS 50-317 AND 50-318 Laboratory

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B. W. Brown Department J. D. Mudlin,

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U.S. NUCLEAR REGULATORY COMMISSION Work performed under DM Contract No. M-AC07-MID01SM 9002140225 900111 PDR ADOCK 05000317 q

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

BALTIMORE GAS AND ELECTRIC COMPANY,.

CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2,

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. DOCKET NUMBERS 50-317 AND 50-318 i

B. W. Brown J. D. Mudlin Published July 1989 i

Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for:

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 under DOE Contract No. DE-AC07-76ID01570 FIN No. D6022 (Project S)

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,4 ABSTRACT This report presents the results of the evaluation of the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Second 10-Year Interval' Inservice Inspection (ISI) Program Plan, submitted January 14, 1988, and the Long Term Plans for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, submitted July 22, 1988 and December 29, 1988, respectively. These documents also included the' 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 Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Second 10-Year Interval ISI Program Plan' is evaluated in Section 2 of this report. The ISI Program Plan 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 Nuclear Regulatory Commission (NRC) previous preservice inspection (PSI) and ISI reviews.

The requests for relief from the ASME Code requirements which the Licensee has determined to be impractical for the second 10-year inspection interval are evaluated in Section 3 of this report.

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U.S. Nuclear Regulatory Commission FIN No 06022, Project 5 Operating Reactor Licensing Issues Program, Review of ISI for ASME Code Class 1, 2, and 3 Components 11

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SUMMARY

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The Licensee, Baltimore Gas and Electric Company, has prepared the Calvert f

Cliffs Nuclear Power Plant, Units 1 and 2, Second'10-Year Interval Inservice-Inspection'(ISI) Program Plan to meet the requirements of the 1983 Edition',-

Summer 1983 Addenda of Section XI of the Code except that the extent of examination for Code Class 1 piping welds has been determined by the 1974 Edition through Summer 1975 Addenda as permitted by 10 CFR 50.55a(b), and the extent of examination for Code Class 2 piping welds has been determined-by ASME Code Case N-408.

The second 10-year interval, for both Units 1 and 2, began April 1, 1987 and ends April 1, 1997.

The information in the Calvert Cliffs Nuclear Power. Plant, Units 1 and 2, Second 10-Year Interval ISI Program Plan, submitted January 14, 1988, 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 (RAI) was prepared describing the information and/or clarification required from the Licensee in order to complete the review.

The Licensee provided the requested information in the submittals dated July 22, 1988 and December 29, 1988.

Based on the review of the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Second 10-Year. Interval ISI Program Plan, Calvert Cliffs Technical _

-Specification 4.4.10.1.2, the Licensee's response to the Nuclear Regulatory Commission's RAI and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it.is-concluded that the Calvert Cliffs Nuclear Power-Plant, Units 1 and 2, Second 10-Year Interval ISI Program Plan is acceptable and in compliance _with-10 CFR 50.55a(g)(4).

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CONTENTS J

ABSTRACT..................................................... -

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SUMMARY

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INTRODUCTION........................................................

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EVALUATION OF INSERVICE INSPECTION PR0 GRAM' PLAN......................

4 2.1 Do c ume n t s - Ev al u a t ed..............................................

4 2.2 Compliance with Code Requirements.................................

5 2.2.1 Compliance with Applicable Code Editions.....................

5 2.2.2 Acceptability of the Examination Sample......................

5 2.2.3 Exclusion Criteria.............................;.............

6 2.2.4 Augmented Examination Commitments............................

7 2.3 Conclusions......................................................

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EVALUATION OF RELIEF REQUESTS.......................................

8 3.1 Class 1 Components...............................................

8 3.1.1 Reactor Pressure Vessel......................................

8 3.1.1.1 Request for Relief No. 3, Examination Category B-0, Item B14.10,. Pressure Retaining Welds in Control Rod Drive Housings.......................................

8 3.1.2 Pressurizer (no relief' requests)'

3.1.3 Heat Exchangers and Steam Generators (no relief requests) 3.1.4 Piping Pressure Boundary....................................

10 3.1.4.1 Request for Relief No.1, Examination Category B-J, Items 89.11 and 89.12, Pressure Retaining Welds of Class 1 Piping Located in the Reactor Ves s el Cavi ty Annul us...................................

10 3.1.5 Pump Pressure Boundary......................................

14 3.1.5.1 Request for Relief No. ', Examination Categories B-L-1 and B-L-2, Items B12.10 and B12.20, Pressure Retaining Class 1 Pump Casing Welds and Pump Casing Internal Surfaces..........

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3.1.6-Valve _ Pressure Boundary (no relief requests) 3.1.7. General (no relief requests)-

j 3.2' Class 2 Components (no relief requests) 3.3 Class 3 Components (no relief requests)

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3.4 Pressure Tests..................................................

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3.4.1 Class 1 System Pressure Tests.(no relief requests) 3.4.2 Class 2 System Pressure Tests...............................

18 3.4.2.1 Request for Relief No. 4, Hydrostatic Testing of Class 2 Piping at Class 1 1

Hydrostatic Test Pressures...........-...................

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3.4.3 Class 3 System Pressure Tests...............................

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3.4.3.1 Request for Relief No. 5, Hydrostatic H

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Tests of Class 3 Piping Containing Bu t t e r fl y Va l ve s........................................

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3.4.4 General (no relief requests) l 3.5 General (no relief requests) 4.

CONCLUSION........................................................

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REFERENCES.......................................................... 27 r

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TECHNICAL EVALUATION REPORT ON THE-4 L"

SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

BALTIMORE GAS AND ELECTRIC COMPANY, CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2, DOCKET NUMBERS 50 317 AND 50-318 L

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INTRODUCTION Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) (Reference 1) requires that components (including.

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-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 requires that inservice examinations of components and system pressure tests conducted during successive inspection intervals shalli 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 u

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 l=

limitations and modifications listed therein. The Licensee, Baltimore Gas

- and Electric Company, has prepared the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Second 10-Year Interval Inservice Inspection (ISI) Program L

Plan (Reference 3) to meet the requirements of the 1983 Edition, Summer 1983 Addenda-(83S83) of Section XI of the Code except that the extent of L

examination for Code Class 1 piping welds has been determined by the 1974 Edition through Summer 1975 Addenda (74S75) as permitted _by 10 CFR 50.55a(b), and the extent of examination for Code Class 2 piping welds-has been determined by ASME Code Case N-408 (Reference 4).

The second 10-year interval, for both Units 1 and 2, began April 1,1987 and ends l-April 1, 1997.

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As required' by ~10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirement's 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 determinations under 10 CFR 50.55a(g)(5) that Code requirements are impractical.

The NRC may grant relief and may impose alternative

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requirements-that are determined to be authorized' by law, will not endanger 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 impcsed on the facility.-

The information in the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Second 10 Year Interval ISI Program Plan, submitted January 14, 1988, was reviewed, including the requests for relief from the ASME Code Section-XI requirement's which the: Licensee has-determined to be impractical.

The review of the ISI Program Plan was performed using the Standard Review Plans

. of NUREG-0800 (Reference 5), Section 5.2.4, " Reactor Coolant Boundary-Inservice Inspections and Testing," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components."

. In a letter ' dated May 25,1988 (Reference 6), the NRC requested additional' information that was required in order to complete the review of-the ISI Program Plan.

The requested information was provided by the Licensee in-letters dated July 22, 1988 (Reference 7) and December 29, 1988 (Reference 8).

In the July 22, 1988 submittal, the ' Licensee addressrs.' the specific NRC concerns and provided a copy of the Long-Term Plan for Calvert Cliffs Nuclear Power Plant, Unit 1.

The December 29, 1988 submittal contained a copy of the Long-Term Plan for Calvert Cliffs Nuclear Power Plant, Unit 2.

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The Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Second 10-Year L

Interval ISI Program Plan is evaluated in Section 2 of this report.

The ISI Program Plan is evaluated for (a) compliance with the appropriate l

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dition/addendagofSectionXI',(b)acceptabilityofexaminationsample, e

(c) correctness of the application of system or component examination

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exclusion criteria, and (d) ct npliance with ISI-related commitments identified during the NRC's pievious preservice inspection.(PSI) and ISI

reviews, i

-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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EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN This evalustion 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 151 activities.

This section describes the submittals reviewed and the results of the review.

2.1 Documents Evaluated Review has been completed on the following information provided by the Licensee:

(a) Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Second 10 Year Interval ISI Program Plan, submitted January 14, 1988; (b)

Letter, dated June 29, 1988 (Reference 9), notifying the NRC of the intended schedule for the Licensee's response to the NRC's request for additional information; (c)

Letter, dated July 22, 1988, containing a partial response to the NRC's request for additional information; (d) long Term Plan for Calvert Cliffs Nuclear Power Plant, Unit 1, submitted with the July 22, 1988 lettcr; 5

(c) letter, dated December 29, 1988, containing the Long-Term Plan for Calvert Cliffs, Unit 2; and (f) Technical Specification 4.4.10.1.2 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2.

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g 2.2 Como11ance with Code Reauirements t

2.2.1 Como11ance with Aeolicable Code Editions

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The Inservice Inspection Program Plan shall be based on the Code editions

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defined in 10 CFR 50.55a(g)(4) and 10 CFR 50.55a(b).

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starting date of April 1,1987, the Code applicable to the second interval l

ISI program is the 1983 Edition with Addenda through Summer 1983. As j

stated in Section 1 of this report, the Licensee has written the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Second 10 Year Interval ISI Program Plan to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the Code except that the extent of examination for Code Class 1 piping welds has been determined by the 1974 Edition through Summer 1975 Addenda as permitted by 10 CFR 50.55a(b), and the extent of examination for Code Class 2 piping welds has been determined by ASME Code Case N 408.

Code Case N 408 has been approved fcr use by reference in NRC Regulatory Guide 1.147 (Reference 10).

2.2.2 Accentability of the Ex2mination Samolt t

Inservice volumetric, surface, and visual examinations shall be performed on ASME Code Class 1, 2, and 3 components and their supports using sampling schedules described in Section XI of the ASME Code and.

10 CFR 50.55a(b).

Based on the review of Calvert Cliffs, Units 1 and 2, Second 10-Year Interval ISI Program Plan and Calvert Cliffs Technical Specification 4.4.10.1.2, which meets or exceeds the intent of the Code for examination of the Main Steam and Feedwater system welds (see paragraph 2.2.4(a)), it has been determined that the sample size and weld selection have been implemented in accordance with Section XI of the Code, Code Case N 408, and 10 CFR 50.55a(b) and appear to be correct.

However, the following are some of the observations noted (with regard to 5

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a Class 2 piping syn ams/ components) based on the tall thickness criteria contained in Code Case N 408:

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(a) The Containment Spray System (CS) (at both Units 1 and 2) has been I

completely exempted from all ISI examinations.

This includes the 8 inch and 10-inch lines containing stagnant borated water.

(b) The Shutdown Cooling System (SC) at Unit I will receive'ISI l

examinations of only two of the 152 welds in the system.

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Unit 2 is scheduled to receive ISI examinations of two of the 159 welds in the SC system.

(c) Class 2 piping integrally welded attachments are also exempted from ISI examinations for those lines exempted by Code Case N 408.

Appropriate Code Class 2 welds in the Residual Heat Removal Systems, Emergency Core Cooling Systems, and Containment Heat Removal System should be examined.

These systems should not be completely exempted from inservice examinations based on the exemption criteria contained in IWC-1220 or Code Case N 408. The Licensee should be encouraged to include ISI examination of a representative sample of welds in each of these systems.

2.2.3 Exclusion Criteria The criteria used to exclude components from examination shall be consistent with Paragraphs IWB 1220, IWC-1220, IWD-1220, and 10 CFR 50.55a(b). Code Case N 408 has been implemented, which provides alternative exemptions for Class 2 piping and replaces IWC 1220. The exclusion criteria have been applied by the Licensee in accordance with the Code as discussed in the ISI Program Plan and appear to be correct.

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2.2.4 Auomented Examination Commitments i

i In addition to the requirements as specified in Section XI of the ASME Code, the Licensee has committed to perfona the following augmented examinations:

(a) Technical Specification 4.4.10.1.2 for Calvert Cliffs, Units 1 and 2, provides for an augmented ISI program for Main Steam and Feedwater piping welds. This augmented program requires that all

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unencapsulated welds greater than 4 inches in nominal pipe diameter in the Main Steam and Feedwater piping runs located outside the containment and traversing safety related areas or located in compartments adjoining safety related areas receive a 100%

volumetric and/or surface examination every 10-year inspection interval; (b) Ultrasonic examination of Reactor Pressure Vessel welds during ISI will be in compliance with MRC Regulatory Guide 1.150, " Ultrasonic Testin0 of Reactor Vessel Welds During Preservice and Inservice Examinations," Revision 1 (Reference 11); and (c) The Reactor Coolant Pump flywheels shall be examined per the recommendations of NRC Regulatory Guide 1.14, Revision 1, " Reactor Coolant Pump Flywheel Integrity" (Reference 12), as required by the Technical Specifications.

2.3 Conclusions t

i Based on the review of the documents listed above, it is concluded that the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Second 10-Year Interval ISI Program Plan is acceptable and in compliance with 10 CFR 50.55a(g)(4).

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EVALUATION OF RELIEF REQUESTS The requests.for relief from the ASME Code re,uirements that the Licensee has determined to be impractical for the second 10 year inspection interval-are evaluated in the following sections, i

i 3.1 Class 1 (~

nnnti 3,,1,1 Reactor Pressure Vessel 3.1.1.1 Reauest for Relief No. 3. Examination Cateoory B-0. Item B14.10. Pressure Retainina Welds in Control Rod Drive Housinas t

Code Reauirement:

Section XI, Table IWB 2500-1, Examination Category B 0, Item B14.10 requires a 100% volumetric or surface examination, as defined by Figure IWB-2500-18, of 10% of the peripheral control rod drive (CRD) housing welds, i

i Licensee's Code Relief Reauest:

Relief is requested from examining 100% of the Code-required surface of 10% of the peripheral CRD housing welds.

Licensee's Prooosed Alternative Examination: The Licensee states that, in order to meet the intent of the ASME Code requirements, portions of additional CRD housing welds will be examined to satisfy the equivalent of 100% of three welds.

This will be done by e:tamining 75% of three welds and 50% of two welds.

Licensee's Basis for Reauestina Relief: The Licensee states that a 100% examination of these welds is impractical due to design configuration, accessibility limitations, and material of construction.

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Ultrasonic examination will not provide meaningful results due'=

to the geometric configuration of the joint and the material properties (inconel to-stainless steel welds). Radiographic Y

examination cannot be performed due to the design configuration and accessibility. Therefore, a surface examination has been l

elected as the method of examination.

Three of the 28 peripheral CRD Housing welds should be examined to meet the Code. However, only a portion of each weld is

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accessible for examination since the welds are partially i

obstructed because'they extend into the closure head itself.

l Evaluation:

The surface examination of the subject welds is impractical to perform to the extent required by the Code because portions of the welds are obstructed by adjacent CRD housings.

The alternative examination proposed by the Licensee will provide examination of an aggregate weld length total that is greater than or equivalent to the Code requirement.

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Therefore, the proposed alternative, along with the system pressure tests, provides reasonable assurance of the continued inservice structural integrity.

t conclusions:

Based on the above evaluation, it is concluded that, for the subject welds, the Code req'Jired examination is j

impractical to perform to the extent required by the Code and that the proposed alternative meets the intent of the Code.

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

3.1.2 Pressurizer (no relief requests) 3.1.3 Heat Exchanaers and Steam Generators (no relief requests) i.

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3.1.4 Pinino Pressure Boundary

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3.1.4.1 Reauest for Relief No. 1. Examination Cateaory B.J. Items B9.11 i

and 89.12. Pressure Retainina Welds of Class 1 Pinino located in the React (,r Vessel Cavity Annulus Code Reauirement:

Sectian XI, Table IWB 2500-1. Examination Category B-J Items 89.11 and B9.12 require both 100%

volumetric and surface examinations of the Class I circumferential and longitudinal piping welds, 4 inches or greater nominal pipe size, as defined by Figure IWB 2500 8.

l Licensee's Code Relief Reauest:

Relief is requested from' performing the Code-required surface examination of the following Reactor Coolant System 42 inch and 30-inch piping welds located in the reactor vessel cavity annulus:

UNIT 1 Line Number Weld Number WgJd Tvoa 42 RC-11 1

Nozzle to-Transition Piece t

2 Transition Piece to-Pipe 2 LO 1 Longitudinal Seam 2 LO-2 Longitudinal Seam 42-RC-12 1

Nozzle to-Transition Piece 2

Transition Piece-to Pipe 2 LD 1 Longitudinal Seam 2 LO 2 Longitudinal Seam 30-RC-11A 12 LU-l Longitudinal Seam 12 LU-2 Longitudinal Seam 12 Elbow to-Transition Piece 13 Transition Piece-to Nozzle 30-RC-IIB 12 LU l Longitudinal Seam 12 LU 2 Longitudinal Seam 12 Elbow to-Transition Piece 13 Transition Piece-to Nozzle 30 RC-12A 12 LU l Longitudinal Seam 12 LU-2 Longitudinal Seam 12 Elbow to Transition Piece 13 Transition Piece-to-Nozzle 10

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Mlfll.1-Line Numbe-Weld Number Weld Tvoe 30 RC 128 12 LU l Longitudinal Seam 12 LU 2-Longitudinal Seam 12 Elbow-to Transition Piece 13 Transition Piece-to Nozzle f

UNIT 2 (ine Number Weld Number Weld Tvoe 42-RC-21 1

Nozzle-to-Transition Piece 2

Transition Piece to-Pipe u

2 LD-1 Longitudinal Seam 2 LD-2 Longitudinal Seam 42 RC 22 1

Nozzle to-Transition Piece 2

Transition Piece-to-Pipe 2 LD-1 Longitudinal Seam 2 LD 2 Longitudinal Seam 30-RC-21A 12 LU-l Longitudinal Seam i 12 LU 2 Longitudinal Seam 12 Elbow to-Transition Piece 13 Transition Piece to-Nozzle 30 RC-218 12 LU-l Longitudinal Seam 12 LU 2 Longitudinal Seam 12 Elbow to-Transiticri Piece 13 Transition Piece to-Nozzle 30 RC-22A 12 LU l Longitudinal Seam 12 LU 2 Longitudinal Seam 12 Elbow-to-Transition _ Piece 13 Transition Piece-to-Nozzle 30-RC-22B 12 LU l Longitudinal Seam 12 LU 2 Longitudinal Seam 12 Elbow-to-Transition Piece 13 Transition Piece to-Nozzle Licensee's prooosed Alternative Examination: The Licensee states that, as an alternative to performing a surface examination, a 45-degree shear wave ultrasonic examination of the outside surface will be performed by utilizing mechanized ultrasonic techniques.from the inside of the pipe or component, i

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Licensee's Basis fo,r Reauestina Relief: The Licensee states b-that, in order to perform the required surface examination of the weld crown and heat-affected zone, the examiners must gain g

g access to the reactor vessel annulus area housing these reactor i

coolant piping welds.

These areas are extremely difficult to-

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enter, provide marginal room for mobility, and are very high radiation areas. The Licensee has determined that a surface l

method examination of these welds, such as magnetic particle, is not practical and that the proposed alternative should be f

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used, Therefore, the proposed ultrasonic (volumetric) examination has been qualified for the detection of unacceptable outside surface flaws that would otherwisa be detected using the magnetic particle method of surface examination. This will allow examination of the entire circumference of the outside surface of the weld while reducing personnel radiation exposure.-

In order to qualify this technique for Calvert Cliffs, i

Southwest Research Institute (SwRI) developed'a mockup of the nozzle and pipe welds and induced cracks at specific locations cn the inside and outside surfaces.

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these cracks were tightly controlled in order to allow the cracks to be used for qualification purposes. Crack depths ranged from one-half the maximum allowable Code flaw depth for the pipe thickness to the maximum allowable Code flaw depth.

All flaws were less than the largest acceptable surface' flaw in length. The cracks were then investigated with ultrasonic examination techniques (performed by SwRI) to the satisfaction of the Licensee to demonstrate that the largest acceptable surface flaw could be detected with this technique.

Evaluation:

The Licensee has reported that, in lieu of the surface examination, the remote volumetric examination includes i

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1 the entire weld volume and heat affected zone instead of only l

the inner one-third of the weld as required by the Code.

The outside surface of the subject welds and heat affected zone (HAZ) are examined using a 45-degree shear wave.

The lower one-third volume of the subject welds and HAZ are examined using a 50/70-degree multibeam transducer.

In addition, a full-vee path 45-degree shear wave examination is performed to supplement the 50/70-degree examinations. Because of the -

.i proximity of the examination volume to the "near field"'of the i

45 degree transducer, only the second half of the 45 degree vee path is calibrated. However, this examination is performed from two directions, assuring Code required two-direction coverage.

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The ultrasonic testing instrumentation and procedures have been demonstrated to be capable of detecting defects in a laboratory test block with the defects being cracks and not machined notches.

Therefore, the proposed alternative, along with the system pressure tests, provides reasonable assurance of the continued inservice structural integrity.

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Conclusions:==

Based on the above evaluation, it is concluded that for the subject welds, the Code-required examination is impractical to perform and that the proposed alternative meets l

the intent of the Code. Therefore, it is recommended that relief be granted as requested.

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3.1.5 Pumo Pressure Boundary 3.1.5.1 Reauest for Relief No. 2. Examination Cateaories B-L.1 and l

B-L-2. Items B12.10 and B12.20. Pressure Retainino Class 1 Pumo l

i Casina Welds and Pumo Casina Internal Surfaces Code Recuirement: Section XI, Table IWB-2500-1, Examination Category B-L-1, Item B12.10 requires a 100% volumetric examination of the Class 1 pump casing welds as defined by l

Figure IWB-2500 16.

Examinations are limited to welds in at least one pump in each group of pumps performing similer j

functions in the system.

Supplementary surface examinations may be performed on interior and/or exterior surfaces to assist in determining the location of indications detected by volumetric examinations.

t Examination Category B-L-2, Item B12.20 (pump casings) requires a visual examination (VT-3) of the internal surfaces of at least one pump in each group of pumps performing similar functions in the system.

This examination may be performed on the same pump selected for volumetric examination of welds.

4 This examination may be performed at the end of the 10 year interval.

Licensee's Code Relief Reauest:

Relief _is requested from performing the Code-required volus tric examination of pump casing welds and the visual (VT-3) examination of the pump casing internal surfaces of the Calvert Cliffs, Unit 1, Reactor Coolant Pump llA, llB,12A, or 12B and Calvert Cliffs, Unit 2, I

Reactor Coolant Pump 21A, 21B, 22A, or 228.

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Licensee's Procosed Alternative Examination:

The Licensee states that one pump interior will be inspected to the extent practical (in recognition of the vanes therein) should the pump be disassembled for any other reason.

The reactor coolant pumps shall be hydrostatically tested per the requirements'of 14 1

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ASME Code Section XI. A surface exaaination of one reactor coolant pump in each unit shall be performed once each interval on the exterior casing weld surface areas by the liquid-l penetrant method. A visual examination of one reactor coolant l

pump in each unit shall be performed once each interval on the exterior pump case surfaces.-

I Licensee's Basis for Recuestino-Relief:

The Licensee states

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that, due to the design configuration of each pump (Type E l

pump), no practical technique currently exists to perform ISI radiographic examination (RT) or ultrasonic examination (UT)'of this type pump.

l The presence of the diffuser vanes precludes conventional RT.

The vanes and radiation field prevent placement of the RT film I

cassettes inside the pump.

Placement of the film on the outside of the pump is feasible, but there is no radiographic source suitable for placement inside the pump.

Standard e

isotopic radiation sources are too weak to penetrate the thick casting and background radiation from the inside surface of the pump would diminish film sensitivity.

Special strong isotopic sources would be impractical to handle and position inside the pump due to personnel radiological exposure from the radiographic source itself. The Miniature Linear Accelerator (MINAC) was considered, but the Type E pump design precludes positioning of the accelerator inside the pump.

Double wall radiography utilizing the MINAC may be useful for a portion of the casing welds. This technique has not been qualified and may not be adequate.

1 The coarse grain structure inherent in thick stainless steel castings precludes the use of conventional UT.

Developments in ultrasonic techniques to date have not provided a method to examine thick stainless steel castings; ultrasonic examination would be preferred over the difficulties and dangers of thick wall radiography.

15

1 l

The pump casing is fabricated from cast stainless steel-(ASTM A351,GradeCF8M). The material is essentially a cast type 316 i

stainless steel.

This material is widely used in the nuclear industry, and no industry failures of this type material in reactor coolant pumps have been noted.

The presence of delta ferrite (typically 15Y,or more) imparts increased resistance to intergranular stress corrosion cracking (IGSCC). The delta ferrite also improves resistance to pitting corrosion.

The Licensee states that Report Number ERP-06-102, Revision 0, E

Eng ne r In rpora e c es hat 1.

Based on the generic pump casing analysis, there is justification for the extension of the pump casing examination up to 15 years.

2.

Plant unioue analysis probably will show greater margins of safety.

3.

The fracture mechanics analysis shows that large, final flaw sizes can be tolerated in the pump casing before fracture is predicted.

4.

The recent 10-year inservice inspection of several pump l

casings (Type F) indicates no detectable flaw growth from i

base line inspections, which corroborates the above analytical conclusion.

The Licensee further states that pump disassembly for a limited visual examination of the interior pressure boundary surfaces of a reactor coolant pump is of little merit.

Over 700 manhours and over 20 person / rem is estimated for disassembly, visual inspection, and reassembly of one reactor coolant pump.

Additional manhours and person-rem will be expended by radiation protection personnel providing direct coverage of this work. Most of the work would be performed under full face mask conditions.

The radiation exposure cannot be justified considering the limitations of the internal visual examinatione i

i l

16 l

I

_q L

4 The volumetric exaaination is impractical to Evaluation:

=, _

perform to the extent required by the Code because radiographic f

techniques for the subject pump casing welds are limited due to

[

the high radiation levels and fixed internals and ultrasonic

[

examinations are limited by the coarse grain structure inherent in thick stainless steel casings (ASTM A351, Grade CF8M).

The pump casing internal visual examination is performed to determine whether unanticipated severe degradation of the 1

casing is occurring due to phenomena such as erosion, corrosion, or cracking.

However, previous experience during examination of similar pumps at other plants has not shown any significant degradation of pump casings.

The Licensee has committed to surface examination of the external surface of the pump casing welds and visual examination of the external surfaces of the pump casing.

The concept of examination of the pump interior if the pump is disassembled for maintenance is acceptable. The disassembly of the pumps for the sole purpose of inspection is a major effort and, in addition to the possibility of damage to the pumps, could result in personnel receiving excessive radiation exposure.

==

Conclusions:==

Based on the above evaluation, it is concluded that the Code-requirement is impractical.

Therefore, it is recommended that the proposed alternative examinations, as outlined by the Licensee, be accepted and that relief be granted provided that:

(a) the visual examination (VT-3) of the internal surfaces of the pumps is performed whenever the 1

internal surfaces are made accessible due to maintenance, (b) 1 an examination of the pump casing welds-is performed, to the maximum extent practical, whenever the welds are exposed due to disassembly of the pump, and (c) if the pumps have not been disassembled, this fact should be reported by the Licensee in the ISI Summary Report at the end of the interval.

17 1

-y nm---e-~-

f i' 9 t,

3.1.6 Valve Pressure Boundarv (no relief requests) 3.1.7 General (no relief requests)

'3.2 Class 2 Comoonents (no relief requests) 3.3 Class 3 Components (no relief requests) 3.4 Pressure Tests 3.4.1 Class 1 System Pressure Tests (no relief requests) 3.4.2 Class 2 System Pressure Tests 3.4.2.1 Reauest for Relief No. 4. Hydrostatic Testina of Class 2 Pioina at Class 1 Hydrostatic Test Pressures __

Code Recuirement: Section XI requires hydrostatic testing of all Class 2 piping and components in accordance with Articles IWA-5000 and IWC-5000.

The test pressure requirement for Class 2 piping and components is 1.25 times system pressure for systems with design temperatures above 200'F.

The system pressure shall be the lowest pressure setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested.

For systems (or portions of systems) not provided with safety or relief valves, the system design pressure shall be substituted for the system pressure.

Licensee's Code Relief Reauest:

Relief is requested from performing the Code-required hydrostatic pressure test of the following (Table 1) Class 2 piping associated with the High Pressure Safety injection (HPSI), Auxiliary HPSI, and Low Pressure Safety injection (LPSI) motor operated valves (MOVs) to the Reactor Coolant System (RCS),

18 l

r,

's TABLE 1 UNIT 1 FROM TO LINE NUMBERS 1-S1-118 1-$1-615 MOV 6"CC-13-1001 l-SI 616-MOV 2"CC-13-1019 l SI 617-MOV 3"CC-13-1014 e

2"CC-13-1005 2"CC 6-1002 1-51-128 1 SI 625-MOV 6*CC-13 1002 1 SI 626-MOV 2"CC-13-1018 1-SI-627-MOV 3"CC-13 1015

+

2"CC-13-1006 2"CC-6 1004 1-SI 138 1 SI-635 MOV 6"CC 13-1003 h

1 SI 636 MOV 2"CC-13-1016 1-SI 637 MOV 3"CC-13-1021 i

2"CC-13-1007 2"CC-6-1005 1-SI-148 1-SI 645-MOV 6"CC-13-1004 1-SI-646 MOV 2"CC-13-1017 1-SI-647-MOV 3"CC-13-1020 2"CC-13-1008 2"CC-6-1006 UNIT 2 FROM TO LINE NUMBERS 2 S1 118 2-SI-615-MOV 6*CC-13-2001' 2 SI 616-MOV 2"CC-13-2019 2-SI-617-MOV 3"CC-13 2014 2"CC-13 2005 2"CC-6-2002 2-51-128 2 SI-625-MOV 6"CC-13-2002 2-SI-626-MOV 2"CC-13-2018 2-SI-627-MOV 3"CC-13-2015 2"CC-13-2006 2"CC-6-2004 2 S1-138 2-SI-635-MOV 6"CC-13-2003 2 SI-636-MOV 2"CC-13 2016 2-SI-637-MOV 3"CC-13-2021 2"CC-13-2007 2"CC-6-2005 2-SI 148 2-SI-645 MOV 6"CC-13-2004 2-SI-646 MOV 2"CC-13 2017 2 SI 647-MOV 3"CC-13-2020 2"CC-13-2008 2"CC-6-2006 19 nm,,

,~

.* a - )

')

Licensee's Pronosed Alternative Examination: The Licensee states that, excluding the portions of the subject piping listed in Table 3 below, the pining will be hydrostatically pressure tested to the requirement of IWB 5000 for Class 1 piping. This piping can be pressurized via alignment of the J

charging system to the Auxiliary HPSI header to obtain the required test pressure of IWB 5000.

For the portions of piping which cannot be hydrostatically i

pressure tested (Table 3), a leakage test will be performed i

each refueling cycle in accordance with Technical i

Specification 6.14.

In this test, the piping will be pressurized to LPSI pump discharge pressure and a VT-2 visual examination for leakage will be conducted.

In addition, welds will continue to be selected and examined per Section XI, Article IWC 2000.

i Licensee's Basis for Recuestino Relief: The Licensee states that the portions of Class 2 piping (listed above) from HPSI, l

Auxiliary HPSI, and LPSI Loop Isolation MOVs to the RCS are isolated from the RCS by two check valves.

The Code-required test pressure for Class 2 exceeds the hydrostatic pressure test I

i requirements of the Class 1 system (1.02 times the operating-pressure) downstream of the check valve.

Table 2 below is a breakdown of the pressure requirements:

TABLE 2 i

Class 1 Portion Class 2 Portion Design Temperature 650'F 650'F Operating Temperature 550*F 294*F Design Pressure (P )

2485 psi 2485 psi D

OperatingPressure(Po)(1.02P) 2235 psi 2235 psi u

Class 1 Hydro Pressure 0

2280 psi N/A Class 2 Hydro Pressure (1.25P )

tVA 3106 psi l

D i

Thus, the hydrostatic test pressure for the Class 2 side l-(3106 psi) exceeds the hydrostatic test pressure for the Class I side (2280 psi) by 826 psi.

Because the Class I side 20 1

l t.

of this-piping cannot be isolated from the Class 2 side, the higher pressure requirements of Class 2 cannot be accomplished.

l In addition, the portions of piping listed in Table 3 below cannot be hydrostatically tested due to the inability to align I

l the charging pumps to pressurize this piping and the operability requirements of these systems when the RCS is pressurized.

TABLE 3

-l UNIT 1 FROM TO LINE NUMBERS l

l S1-114 1-SI-615-H0V 6"CC-13 1001 1 51-124 1 SI-625-MOV 6"CC-13-1002

~

1-SI-134 1-SI-635 MOV 6"CC-13 1003 1 51-144 1-SI-645 MOV 6"CC 13 1004 i

UNIT 2 FROM TO LINE NUMBERS 2-S1-114 2 SI 615-MOV 6"CC-13 2001 2 S1-124 2-SI 625 MOV 6"CC-13 2002 2 SI 134 2-SI-635 MOV 6"CC-13-2003 2-SI-144 2-SI-645-MOV 6"CC-13-2004 Evaluation:

The section of piping upstream of check valves S1-118, -128, -138, and 148, for Units 1 and 2, cannot be tested at the Code required test pressure without making extensive temporary modifications to keep the valves closed or permanent modifications to isolate the Class 1 and Class 2 portions of the system.

As reported in the NRC Safety Evaluation Report, dated November 14, 1985 Reference 13), temporary modifications of the valves would require:

(a) disassembly of the valves, (b) welding of temporary blocks (on the oownstream side) inside the valve bodies to hold a " jack screw" type arrangement to keep the valve closed, (c) removal of the temporary blocking devices from the valves after testing, and (d) performing i

21 o e v

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necessary nondestructive testing to assure the integrity of the l

valve bodies before returning them to service, f

r Permanent modi1 cations considered by the Licensee consist of l

adding flanged pipe spool pieces in the 6-inch Class 1 piping downstream of check valves SI 118,128,138, and 148.

This would permit spool piece removal and temporary blan< flange j

installation when testing is performed.

This modification would result in eight additional Class 1 pressure boundary l

flanged gasket joints, which typically result in additional maintenance requirements and maintenance personnel radiation ~

f exposure. The Licensee also reported that the permanent l

modifications would be extensive, costly (approximately t

$960,000 per unit), incur significant personnel radiation I

exposure (24 person-rem per unit), and result in a reduction in the integrity now afforded by the all welded design.

Additionally, requests for relief may be required to permit avoiding Class I construction code hydrostatic testing on the j

new Class I welds installed by the modification.

l l

Without one of the above described modifications, the Class 1 system downstream of the check valves would be pressurized to the test pressure of the Class 2 system which exceeds the Class 1 './drostatic pressure requirements.

Because of the system design and the extent of the modifications necessary to perform the Code required test, the i

Code-required hydrostatic pressure test is impractical to perform. The proposed alternative tests provide reasonable 1

assurance of the continued inservice structural integrity.

==

Conclusions:==

Based on the above evaluation, it is concluded that the Code required hydrostatic test of the subject Class 2 piping is impractical to perform.

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

l i

L 22 l

i L

1 il

0, l

-a, 3.4.3 Class 3 System Pressure Tests 3.4.3.1 Reouest for Relief No. 5. Hydrostatic Tests of Class 3 Pioino Containino Butterfly Valvu_

[

i Code Reouirement:

Section XI, Subarticles IWA 5200 and IWD 5200 require hydrostatic pressure testing of all Class 3 3

systems.

Paragraph IWD 5223(a) specifies that the hydrostatic test. pressure shall be at least 1.10 times the system pressure for systems with design temperatures o N)'F or less.

j Licensee's Code Relief Reauest:

Relief is requested from performing the Code required system hydrostatic pressure test of isolated portions of Class 3 piping of the Component Cooling, Service Water, and Salt Water Cooling Systems.

Licensee's Procosed Alternative Examination: The Licensee states that a system inservice pressure test will be performed on an annual basis for portions of these systems outside of containment and on a refueling outage basis for those portions located inside containment.

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

'that hydrostatic pressure on isolated portions cannot be achieved because butterfly valves are installed on the main headers of these systems and a sufficient seal to maintain hydrostatic pressure cannot be obtained.

Evaluation:

The Code required hydrostatic pressure test of isolated portions of Class 3 piping associated with the Component Cooling, Service Water, and Salt Water Cooling Systems is impractical to perform because the butterfly valves on the main headers of these systems are unable to sustain the l

pressure required for a hydrostatic test (1.1 times the design pressure).

The annual leakage testing of those portions p

23

G' **. 7, i

outside containment, which is normally required every 40 month

)

4 period by the Code, and the leakage testing of.those portions-

{

located inside containment performed every refueling outage are acceptable alternatives to the Code required hydrostatic pressure test and provide reasonable assurance of the continued inservice structural integrity.:

==

Conclusions:==

Based on the above evaluation, it is concluded i

that the Code-required hydrostatic pressure test of the subject i

Class 3 piping is impractical' to perform. Therefore, it is recommended that relief Le granted as requested.

i 1

3.4.4 General (no relief requests) 3.5 General (no relief requests) i Y

l P

24 l

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e

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4. CONCLUSION 6

}

Pursuant to 10 CFR 50.55a(g)(6), it has been determined that certain Section XI required inservice examinations are impractical to perform.

In all cases for which relief is requested, the Licensee has demonstrated that l

specific Section XI requirements are impractical, This technical evaluation report has not identified any practical method by which the Licensee can meet all the specific inservice inspection requirements of Section XI of the ASME Code for the existing Calvert Cliffs Nuclear Power Plant, Units 1 and 2, facility.

Requiring compliance with all the exact Section XI required inspections would require redesign of a l

significant number of plant systems, sufficient replacement components to be obtained, installation of the new components, and a baseline examination of these components.

Even after the redesign efforts, complete compliance with the Section XI examination requirements probably could not be achieved.

Therefore, it is concluded that the public interest is not served by imposing certain provisions of Section XI of the ASME Code that have been determined to be impractical.

Pursuantto10CFR50.55a(g)(6),reliefis allowed from these requirements which are impractical to implement if granting the relief will not endanger life or property or the common 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.

[

l The development of new or improved examination techniques should continue to

+

he monitored. As improvements in these areas are achieved, the Licensee should incorporate these techniques in the ISI program plan examination requirements.

L Based on the review of the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, the Second 10 Year Interval Inservice Inspection Program Plan, I

Calvert Cliffs Technical Specification 4.4.10.1.2, the Licensee's responses to the NRC's Request for Additional Information, and the recommendations for L

25 I

E 1

+

e,

?

granting relief from the ISI-exanination requirements that have been j

. determined to be impractical, it is concluded that the Calvert Cliffs Nuclear Power. Plant, Units 1 and 2, Second 10 Year Interval Inservice Inspection Program Plan is acceptable and in compliance with 10CFR50.55a(g)(4).

However, the Licensee should be encouraged to perform examinations on a representative sampling of the Class 2 piping welds in the Containment Spray and Shutdown Cooling systems, including the associated integrally welded attachments, as they have been exempted from surface and volumetric examinations based on the wall thickness criteria contained in

[

Code Case N-408.

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REFERENCES l

. 4

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

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

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

3. Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Second 10-Year Interval Inservice Inspection Program Plan, submitted January 14, 1988.

4. American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Code Cases - Nuclear Components, 1986 Edition.

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

j

6. Letter, dated May 25, 1988, S. A. McNeil (NRC) to J. A. Tiernan (Baltimore Gas and Electric (BG&E)], request for additional information.

7. Letter, dated July 22, 1988, J. A. Tiernan (BG&E) to Document Control Desk (NRC), containing a partial response to the NRC's May 25, 1988, request for additional information and the Long-Term Plan for Calvert l

Cliffs Nuclear Power Plant, Unit 1.

8. Letter, dated December 29, 1988, J. A. Tiernan (BG&E) to Document Control Desk (NRC), containing the Long-Term Plan for Calvert Cliffs Nuclear Power Plant, Unit 2, as required by the NRC's May 25, 1988, request for additional information.

9. Letter, dated June 29, 1988, W. J. Lippold (BG&E) to Document Control Desk (NRC), providing a schedule for response to the NRC's May 25, 1988 request for additional information, i

10 NRC Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 5, dated August 1986,

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

12. NRC Regulatory Guide 1.14

" Reactor Coolant Pump Flywheel Integrity,"

Revision 1 dated August 1975.

13. Letter, dated November 14, 1985, H. R. Denton (NRC) to A. E. Lundvall (BG&E), containing " Safety Evaluation Report, Request For Relief From Inservice Pressure Test Requirements."

L l

l 27

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2. nt 6: *No5.stit6e D3G4tS-8403 l

TWhnical Evaluation Report on tM Second 10-Year Interval Inservice Inspection PA%s.iu Plant oatsatacaro m s.ic i

Baltimore Gas and Electric Co.,

Calvert Cliffs Nuclear Power Plant, Unita 1 aM 2, July l 198h**

j 4 nw ca ca*Nr svesa Docket Numbe.rs 50-317 and 50-318 FIN-D6022 (Proj. 5)

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B.W. Brown, J.D. Mudlin

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D3&G Idaho, Inc.

.1 P. O. Box 1625 I

Idaho Falls, ID 83415-2209 l

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~~o Materials Engineering Branch Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comnission Washington, D.C.

20555

10. SUPPLEVENtamv NoTis I

J ll. A$st R Ac7 IM e.,ue.r es, This report presents the results of the evaluation of ths Calvert Cliffs Nuclear Power Plant, Units 1 aM 2, Second 10-Year Interval Inservice Inspection (ISI)

Program Plan, subnitted January 14,.1988, and the I.org-Term Plans for Calvert Cliffs 1

Nuclear Power Plant, Units 1 and 2, subnitted July 22, 1988 and December 29, 1988, respectively. These documents also included the requests for relief frun the American Society of Mechanical Dgineers (ASME) Boiler and Pressure Vessel Code Section XI requirement which the Licensee has determined to be inpractical. 'Ihn Calvert Cliffs Nuclear Power Plant, Units 1 aM 2, SecoM 10-Year Interval ISI Program Plan is evaluated in Section 2 of this report. The ISI Pi@uun Plan is evaluated for (a) ocmpliance with the appropriate editiorVaddenda of Section XI, (b) acceptability of examination sarple, (c) correctness of the application of system or cuyoient examination exclusion criteria, and (d) canpliance with ISI-related ocanitments identified during the Nuclear Regulatory Comnission's (NRC) previous preservice inspection (PSI) and ISI reviews. The requests for relief frun the ASME Code requirements which the Licensee has determined to be inpractical for i

l the second 10-year inspection interval are evaluated in Section 3 of this report.

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