ML18005A652

Technical Evaluation Rept on First 10-Yr Interval Inservice Insp Program:Shearon Harris Nuclear Power Plant,Unit 1.

ML18005A652
Person / Time
Site:	Harris
Issue date:	07/31/1988
From:	Beth Brown, Mudlin J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML18005A650	List: ML18005A652
References
CON-FIN-D-6022 EGG-MS-8090, NUDOCS 8810170435
Download: ML18005A652 (87)

Text

EGG-HS-8090 July 1988 TECHNICAL EVALUATIONREPORT Idaho TECHNICAL EVALUATION REPORT ON THE FIRST 10-YEAR National INTERVAL INSERVICE INSPECTION PROGRAhl PLAN:

CAROLINA POWER AND LIGHT COh1PANY, Engineering SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1, Laboratory DOCKET NUtlBER 50-400 Managed B. W. Brown by the U.S. J. D. Mudlln Oepartment of Energy 0 E&ZG

++ Idaho Prepared for the U.S. NUCLEAR REGULATORY COMMISSION Work perrormed under DOF Conuect No. DF-AC07-76/D01670 8810i70435 880930 PDR ADOCK 05000400 8

EGG-MS-8090 TECHNICAL EVALUATION REPORT ON THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

CAROLINA POWER AND LIGHT COMPANY, SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1, DOCKET NUMBER 50-400 B. W. Brown J. D. Mudlin Published July 1988 Idaho National Engineering Laboratory EGKG 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 5)

ABSTRACT This report presents the results of the evaluation of the Shear on Harris Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice Inspection (ISI) Program Plan, submitted January 28, 1988, including 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 Shearon Harris Nuclear Power Plant, Unit 1, First 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) exclusion criteria, and (d) compliance with ISI-related commitments identified during the Nuclear Regulatory Commission (NRC) review before granting an Operating License. The requests for relief from the ASME Code requirements which the Licensee has determined to be impractical for the first 10-year inspection interval are evaluated in Section 3 of this report.

This work was funded under:

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

SUMMARY

The Licensee, Carolina Power and Light Company, has prepared the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice Inspection ( ISI) Program Plan to meet the requirements of the 1983 Edition, Summer 1983 Addenda (83S83) of the ASME Code Section XI except that the extent of examination for Code Class 1 and Code Class 2 piping welds has been determined by the 1974 Edition through Summer 1975 Addenda (74S75) as permitted and required by 10 CFR 50.55a(b). The first 10-year interval began May 2, 1987 and ends May 1, 1997.

The information in the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan, submitted January 28, 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.

Sased on the review of the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan, and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan is acceptable and in compliance with 10 CFR 50.55a(g)(4);

CONTENTS ABSTRACT...... ~ ~ ~ 1 1 S UMMARYo ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 111 lo INTRODUCTIONo ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1

2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN......... ~ ~ ~ 3

2. 1 Documents Evaluated.................................................3 2.2 Compliance with Code Requirements.............................. ~ ....3 2.2. 1 Compliance with Applicable Code Editions........................3 2.2.2 Acceptability of the Examination Sample........ ~ ...........,....3 2.2.3 Exclusion Criteria..............................................4 2.2.4 Augmented Examination Commitments...............,...............4 2..3 Conclus1ons.........................................................4

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3. EVALUATION OF RELIEF REQUESTS..........................................5 F 1 Class 1 Components..................................................5

3. 1. 1 Reactor Pressure Vessel..................................... ~ ~ ~

3.1.1.1 Request for Relief No. Rl-004 (Part 1 of 3), Examination Category B-A, Items 81.11, 81.12, 81.21, 81.22, and 81.40, Pressure Retaining Welds in the Reactor Pressure Vessel.....5

3. 1. 1.2 Request for Relief No. Rl-006 (Part 1 of 3), Examination Category B-D, Item 83.90, Full Penetration Welds of Nozzles in Vessels..........................

3. 1.2 Pressurizer....... ..7 3.1.2.1 Request for Relief No. Rl-004 (Part 2 of 3), Examination Category B-B, Item 82. 11, Pressure Retaining Welds in Vessels Other Than Reactor Vessel...........................7 3.1.2.2 Request for Relief No. Rl-006 (Part 2 of 3), Examination Category B-D, Item 83. 110, Full Penetration Welds of Nozzles in Vessels, and Examination Category B-F, Item 85.40, Pressure Retaining Dissimilar Metal Welds......... ...9 3.1.2.3 Request for Relief No. Rl-008, Examination Category B-H, 0

Item 88.20, Pressurizer Integral Attachments....

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3. 1.3 Heat Exchangers and Steam Generators...... . ............... 11

3. 1.3. 1 Request for Relief No. Rl-004 (Part 3 of 3), Examination Category B-B, Item 82.40, Pressure Retaining Welds in Vessels Other Than Reactor Vessel..........................ll

3. 1.3.2 Request for Relief Ho. Rl-006 (Part 3 of 3), Examination Category B-D, Item 83. 130, Full Penetration Welds of Nozzles in Vessels......................................... 13 3.1.4 Piping Pressure Boundary.. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 13

3. 1.4. 1 Request for Relief Ho. R1-003, Examination Category B-J, Item 89. 11, Pressure Retaining Circumferential Piping Welds, and Item 89.31, Branch Pipe Connection Welds........ 13

3. 1.5 Pump Pressure Boundary....................................... ~ . 17

3. 1.5. 1 Request for Relief No. R1-005(8), Examination Category B-L-1, Item 812. 10, Pressure Retaining Welds in Pump Casings, and Examination Category B-L-2, Item 812.20, P ump Casings...............................................17

3. 1.6 Valve Pressure Boundary ..... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 19

3. 1.6. 1 Request for Relief No. Rl-005(A), Examination Category B-M-2, Item 812.50, Valve Bodies Exceeding 4 inch Nominal Pipe Size.woo...o.o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~, ~ ~ ~ ~ ~ 19

3. 1.7 General...... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ .22

3. 1.7. 1 Request for Relief Ho. R1-002, Examination Category F-C, Item F3.50, Functional Testing of Class 1 Snubbers.........22

3. 1.7.2 Request for Relief Ho. R1-006, Examination Category B-D, Items 83.90, 83. 110, and 83. 130, Full Penetration Welds of Nozzles in Vessels, and Examination Category B-F, Item 85.40, Pressure Retaining Dissimilar Metal Welds...........22 3.2 Class 2 Components .26 3.2.1 Pressure Vessels.......................... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 26 3.2. 1. 1 Request for Relief No. R2-005, Examination Category C-A, Items Cl. 10, Cl.20, and C1.30, Pressure Retaining Welds in Class 2 Pressure Vessels, Examination Category C-B, Items C2.21 and C2.22, Pressure Retaining Nozzle Welds in Vessels, and Examination Category C-C, Item C3. 10, Integral Welded Attachments for Vessels....................26 3 .2.2 Piping. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ .31 3.2.2.1 Request for Relief No. R2-001 (Part 1 of 2), Examination Category C-F, Items C5.11, C5.12, and C5.21, Class 2 Pressure Retaining Piping Welds, and Examination Category C-C, Item C3.20, Integral Welded Attachments for Piping....31

3.2.2.2 Request for Relief No. R2-003, Examination Category C-F, Item C5.21, Class 2 Pressure Retaining Circumferential Piping Welds.... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 32 3.2.2.3 Request for Relief No. R2-004, Examination Category C-F, Items C5. 11 and C5.21, Class 2 Pressure Retaining Piping W elds ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o36 3 ~ 2.3 Pumps..........................................................37 3.2.3.1 Request for Relief No. R2-001 (Part 2 of 2), Examination Category C-C, Item C3.30, Integral Welded Attachments for P umps......................................................37 3.2.4 Valves (No relief requests) 3 .2.5 General.............. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 38 3.2.5. 1 Request for Relief No. R2-001, Examination Category C-F, Items C5. 11, C5. 12, and C5.21, Class 2 Pressure Retaining Piping Welds, and Examination Category C-C, Items C3.20 and C3.30, Integral Welded Attachments for Piping and P umps....... t~~~~~~~~~~~~~~~~~~~~~~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o38 3.2.5.2 Request for Relief No. R2-002, Examination Category F-C, Item F3.50, Functional Testing of Class 2 Snubbers.........41 3.3 Class 3 Components.....................,..... ... ................4 A )

3.3. 1 Piping (No relief requests) 3.3.2 Pumps (No relief requests) 3.3.3 Valves (No relief requests) 3 .3.4 General. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 42 3.3.4. 1 Request for Relief No. R3-001, Examination Category F-C, Item F3.50, Functional Testing of Class 3 Snubbers. ~ ~ ~ ~ ~ ~ ~ ~ 42 3,4 Pressure Tests (No relief requests) 3,5 General (No relief requests) 4 ~ CONC LUS ION o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 43

5. REFERENCES ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 45

h TECHNICAL EVALUATION REPORT ON THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

CAROLINA POWER AND LIGHT COMPANY, SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1, DOCKET NUMBER 50-400

1. INTRODUCTION Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) (Reference 1) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except the design and access 'provisions and the preservice examination requirements, set forth in the ASME Code Section XI, "Rules for Inservice Inspection of Nucl'ear Power Plant Components," (Reference 2) to the extent practical within the limitati'ons 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 the initial 120-month inspection interval 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 date of issuance of the operating license, 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. The Licensee, Carolina Power and Light Company, has prepared the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice Inspection (ISI) Program Plan to meet the requirements of the 1983 Edition, Summer 1983 Addenda (83S83) of the ASME Code Section XI except that the extent of examination for Code Class 1 and Code Class 2 piping welds has been determined by the 1974 Edition through Summer 1975 Addenda (74S75) as permitted and required by 10 CFR 50.55a(b). The first 10-year interval began May 2, 1987 and ends May 1, 1997.

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief from them,

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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 requirements that are determined to be authorized by law, will not endanger life or proper ty or the common defense and security, and are otherwise in the'ublic interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

The information in the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan (Reference 3), submitted January 28, 1988, was reviewed, including the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical. The review of the ISI Program Plan was performed using the Standard Review Plans of NUREG-0800 (Reference 4), Section 5.2.4, "Reactor Coolant Boundary Inservice Inspections and Testing," and Section 6.6, "Inservice Inspection of Class 2 and 3 Components."

The Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan is evaluated in Section 2 of this report. The ISI Program Plan is evaluated for (a) complia'nce with the appropriate edition/addenda of Section XI, (b) acceptability of examination sample, (c) exclusion criteria, and (d) compliance with ISI-related commitments identified during the NRC's review before granting an Operating License.

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

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2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN This evaluation consisted of a review of the applicable program documents to determine whether or not they are in compliance with the Code requirements and any license conditions pertinent to ISI activities. This section describes the submittals reviewed and the results of the review.

2. 1 Documents Evaluated The Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice Inspection Program Plan (3 volumes), submitted January 28, 1988, was reviewed.

2.2 Com liance with Code Re uirements 2.2. 1 Com liance with A licable Code ditions The Inservice Inspection Program Plan shall be based on the Code 'editions defined in 10 CFR 50.55a(g)(4) and 10 CFR 50.55a(b). Based on the Operating License date of October 1986, the Code applicable to the first 10-year inspection interval ISI program plan is the 1983 Edition with Addenda through Summer 1983. As stated in Section 1 of this report, the Licensee has written the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan to meet the requirements of the 1983 Edition, Summe'r 1983 Addenda of the Code except that the extent of examination for. Code Class 1 and Code Class 2 piping welds has been determined by the 1974 Edition through Summer 1975 Addenda as permitted and required by 10 CFR 50.55a(b).

2.2.2 Acce tabilit of the Examination Sam le Inservice volumetric, surface, or 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). Sample size and weld selection have been implemented in accordance with the Code and appear to be correct.

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

2.2.4 Au mented Examination Commitments In addition to the requirements as specified in Section XI of the ASHE Code, the Licensee has committed to perform augmented examinations in accordance with the following documents:

(a) NUREG-0800, Standard Review Plan, Section 3.6. 1, "Plant Design for Protection-Against Postulated Piping Failures in Fluid Systems Outside Containment," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components."

(b) Regulatory Guide 1. 14, "Reactor Coolant Pump Flywheel Integrity" (Reference 5).

(c) Ultrasonic examination of Reactor Pressure Vessel welds during ISI will be in compliance with Regulatory Guide 1. 150, "Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations," Revision 1 (Reference 6),

(d) Request for additional information (RAI) from NRC to Carolina Power and Light Company by letter dated October 11, 1983 (Reference 7).

In response to the RAI, the Licensee committed to perform volumetric examination of a 10% sample of Class 2 piping welds in the RHR, ECC, and CHR systems.

2.3 Conclusions Based on the above review, it is concluded that the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan is acceptable and in compliance with 10 CFR 50.55a(g)(4).

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3. EVALUATION OF RELIEF REQUESTS The requests for relief from the ASME Code requirements which the Licensee has determined to be impractical for the first 10-year inspection interval are evaluated in the following paragraphs. Requests for Relief Rl-001 and Rl-007 were deleted during PSI and are not included in the ISI Program Plan.

3. 1 Class 1 Com onents

3. 1. 1 Reactor Pressure Vessel

3. 1. 1, 1 Re uest for Relief No. Rl-004 Part 1 of 3 Examination Cate or 8-A Items 81.11 81.12 81.21 81.22 and 81.40 Pressure Retainin Welds in the Reactor Pressure Vessel Code Re uirement: Section XI, Table IW8-2500-1, Examination Category B-A, Items 81. 11, 81. 12, 81.21, and 81.22 (RPV head and shell welds) require a 100% volumetric examination as defined by Figures IW8-2500-1, -2, and -3, Item 81,40 (RPV head-to-flange weld) requires both 100% volumetric and surface examinations as defined by Figure IW8-2500-5.

Licensee's Code Relief Re vest: Relief is requested from examining 100% of the Code-required volume of the following Reactor Pressure Vessel welds (12 welds), due to obstructions such as noz"le interference, lifting lugs, etc:

Item Number Weld Number 81.11 II-RV-001CSW-RV-02 81.12 II-RV-001LSW-RV-05 81.12 II-RV-001LSW-RV-06 81.21 I I- RV-001CHW- RV-17 81.21 I I-RV-001STHW- RV-04 81.22 I I - RV-001MHW-RV-11 81.22 I I -RV-001MHW-RV-12 81.22 I I - RV-001MHW-RV-13 81.22 I I -RV-001MHW-RV-14 81.22 I I- RY-001MHW- RV-15 81.22 I I-RV-001MHW-RV-16

81. 40 II-RV-001FTHW-RV-18

Li censee's Pro osed A1 ternati ve Examinati on: Hone. The Licensee states that the Reactor Vessel pressure retaining welds will be volumetrically (UT) examined to the maximum extent possible in accordance with the Code requirements. In addition, the components will be subject to system pressure tests during each refueling outage.

Licensee's Basis for Re uestin Relief: The Licensee states that numerous obstructions (nozzles, lifting lugs, etc.)

prevent a 100/ volumetric (UT) examination of the pressure retaining weIds listed in the relief request. The listing also indicates the type of obstruction, as well as the size of the obstruction, when applicable. The limitations/obstructions

. were documented on the applicable preservice data sheet(s).

The Licensee reports that, pressure retaining welds in the Reactor Vessel were volumetrically (UT) examined to the maximum extent possible during preservice inspection activities. The design of the components presents obstructions that will not allow 100/ volumetric (UT) examinations to be performed.

The Licensee states that no impact on overall plant quality, safety, or reliability is expected. In addition, the pressure retaining welds will be subject to the Code-required system pressure tests and visual examinations, to the maximum extent possible, during each refueling outage.

Evaluation: The relief request Table lists the component and weld identification, the weld configuration, the Code-requirement for which reIief is being requested, the examination angle and technique being used, the specific obstruction which limits the examination, and the estimated percentage of the Code-required examination that was completed.

Of the 12 Reactor Pressure Vessel welds, 7 will receive greater than 93/, 4 will receive greater than 78%, and I weld will

receive 48% of the Code-required examination. The volumetric examination of the subject welds, to the extent required by the Code, is impractical because permanent obstructions (nozzle interference, lifting lugs, etc.) limit the examinations. A significant percentage of the Code-required examination will be performed.

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examinations and the Code-required surface examination (for the RPV head-to-flange weld) ensure an acceptable level of inservice structural integrity. Compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, it is recommended that relief be granted as requested.

3. 1. 1.2 Re uest for Relief No. Rl-006 Part 1 of 3 Examination Cate or 8-0 Item 83.90 Full Penetration Welds of Nozzles in Vessels

~NOT  : See the evaluation of this request for relief under Section 3. 1.7.2'of this report.

3. 1.2 Pressurizer

3. 1.2. 1 Re uest ,or Relief No. Rl-004 Part 2 of 3 Examination Cate or 8-8 Item 82. 11 Pressure Retainin Welds in Vessels Other Than Reactor Vessel Code Re uirement: Section XI, Table IWB-2500-1, Examination Category B-B, Item 82. 11 (Pressurizer circumferential shell-to-head welds) requires a 1005 volumetric examination as defined by Figure IW8-2500-1.

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Licensee's Code Relief Re uest: Relief is requested from examining 10'/ of the Code-required volume of the following Pressurizer welds (four welds), due to obstructions such as welded plates, weld support plates, manways, etc.

II-PZR-OICSM-03 II-PZR-OILSM-06 II -PZR-0 1 STHM-01 I I - PZR-0 1 STHM-04 Licensee's Pro osed Alternative Examination: None. The Licensee states that the subject Pressurizer pressure retaining welds will be volumetrically (UT) examined to the maximum extent possible in accordance with the Code requirements. In addition, the components will be subject to system pressure tests during each refueling outage.

Licensee's Basis for Re uestin Relief: The Licensee states that numerous obstructions (manways, support plates, etc.)

prevent a 100/ volumetric (UT) examination of the pressure retaining welds listed in the relief request. The listing also indicates the type of obstruction, as well as the size of the obstruction, when applicable. The limitations/obstructions were documented on the applicable preservice data sheet(s).

The Licensee reports that pressure retaining welds in the Pressurizer were volumetrically (UT) examined to the maximum extent possible during preservice inspection activities. The design of the components presents obstructions that will not allow 100/. volumetric (UT) examinations to be performed.

The Licensee states that no impact on overall plant quality, safety, or reliability is expected. In addition, the pressure retaining welds will be subject, to the Code-required system pressure tests and visual examinations, to the maximum extent possible, during each refueling outage.

Evaluation: The relief request Table lists the component and weld identification, the weld configuration, the 8

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Code-requirement for which relief is being requested, the examination angle and technique being used, the specific obstruction which limits the examination, and the estimated percentage of the Code-required examination that was completed.

It is noted that the 4 Pressurizer welds will receive 90% or greater of the Code-required examination. The volumetric examination of the subject welds, to the extent required by the Code, is impractical because permanent obstructions (welded plates, weld support plates, manways, etc.) limit the examinations. A significant percentage of the Code-required examination will be performed.

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examinations ensure an acceptable level of inservice structural integrity. Compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, it is =

recommended that relief be granted as requested.

3. 1.2.2 Re uest for Relief No. Rl-006 Part 2 of 3 Examination Cateaor B-0 Item 83.110 Full Penetration Welds of Nozzles in Vessels and Examination Cate or B-F Item B5.40 Pressure Retainin Dissimilar Metal Welds

~NOT  : See the evaluation of this request for relief under Section 3. 1.7.2 of this report.

3. 1.2.3 Re uest for Relief No. Rl-008 Examination Cateaorv 8-H. Item 88.20 Pressurizer Inte ral Attachments Code Re uirement: Section XI, Table IWB-2500-1, Examination Category B-H, Item B8.20 requires a 100% surface or volumetric examination, as applicable, of Class 1 integrally welded attachments to the Pressurizer as defined by Figures IWB-2500-13, -14, and -15.

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icensee's Code Relief Re uest: Relief is requested from examining 100% of the Code-required surface area of the following 8 Pressurizer integrally welded attachments:

Examination Cate or 8-H Item 88.20 Required Weld Number Examination Area Not Accessible I I - PZR-01SBW-A1A MT 1/2" base metal past top end of weld I I- PZR-01SBW-A18 1/2" base metal past top end of weld II-PZR-01SBW-A2A MT 1/2" base metal past top end of weld I I -PZR-01SBW-A28 MT 1/2" base metal past top end of weld II-PZR-01SBW-A3A MT 1/2" base metal past top end of weld II-PZR-01SBW-A38 1/2" base metal past top end of weld I I - PZR-01SBW-A4A 1/2" base metal past top end of weld I I - PZR-01SBW-A48 MT 1/2" base metal past top end of weld Licensee's Pro osed Alternative xamination: The Licensee states that the inaccessible portions of the attachments will be visually (VT-1) examined to ensure structural integrity.

Licensee's Basis for Re uestin Relief: The Licensee states that the design of integral welded attachments on the pressurizer will not allow access to 1/2 inch of the base material to facilitate completion of the Code-required surface examination.

The integral welded attachments will be surface examined for essentially 100% of the weld length. The inaccessible portions of the attachments will be visually (VT-1) examined to ensure structural integrity. No impact on plant safety, quality, or reliability is expected as the attachments will be periodically examined to ensure structural integrity.

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Evaluation: The surface examination of the subject welds, to the extent required by the Code, is impractical because of the configuration of the attachment, which does not allow access to I/2 inch of the base material past the top end of the welds. A significant percentage of the Code-required surface examination will be performed. These integral welded attachments would have to be redesigned and refabricated in order to complete the remainder.

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI surface examination of the subject welds ensures an acceptable level of inservice structural integrity. Compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, it is recommended that relief be granted as requested.

3. 1.3 Heat Exchan ers and Steam Generators 3.1.3. 1 Re uest for Relief No. Rl-004 Part 3 of 3 Examination Cate or 8-B Item B2.40 Pressure Retainin Welds in Vessels Other Than Reactor Vessel Code Re uirement: Section XI, Table IWB-2500-1, Examination Category B-B, Item B2.40 (Steam Generator tubesheet-to-head weld) requires a 100% volumetric examination as defined by Figure IWB-2500-6.

Licensee's Code Relief Re uest: Relief is requested from examining 100% of the Code-required volume of the following Steam Generator tubesheet-to-head welds, due to obstructions such as welded plates, weld support plates, etc:

II-SG-001SGA-TSTHW-06 II-SG-001SGB-TSTHW-06 II-SG-001SGC-TSTHM-06 11

Licensee's Pro osed Alternative Examination: None. The Licensee states that the Steam Generator tubesheet-to-head welds will be volumetrically (VT) examined to the maximum extent possible in accordance with the Code requirements. In addition, the components will be subject to system pressure tests during each refueling outage.

Licensee's Basis for Re uestin Relief: The Licensee states that numerous obstructions (support plates, welded plates, etc.) prevent a 1005 volumetric (UT) examination of the tubesheet-to-head welds listed in the relief request. The listing also indicates the type of obstruction, as well as the size of the obstruction, when applicable. The limitations/obstructions were documented on the applicable preservice data sheet(s).

The Licensee reports that pressure retaining welds in the Steam Generators were volumetrically (UT) examined to the maximum extent possible during preservice inspection activities. The design of the components presents obstructions that will not allow 10'!. volumetric (VT) examinations to be performed.

The Licensee states that no impact on overall plant quality, safety, or reliability is expected. In addition, the pressure retaining welds will be subject to the Code-required system pressure tests and visual examinations, to the maximum extent possible, during each refueling outage.

Evaluation: The relief request Table lists the componen and weld identification, the weld configuration, the Code-requirement for which relief is being requested, the examination angle and technique being used, the specific obstruction which limits the examination, and the estimated percentage of the Code-required examination that was completed.

It is noted that the 3 Steam Generator, welds will receive 92%

or greater of the Code-required examination. The volumetric 12

ps 1

examination of the subject welds, to the extent required by the Code, is impractical because permanent obstructions (welded plates, weld support plates, etc.) limit the examinations. A significant percentage of the Code-required examination will be performed.

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examinations ensure an acceptable level of inservice structural integrity. Compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of qualityand safety. Therefore, it is recommended that relief be granted as requested.

3,1.3.2 -

Re uest for Relief No. Rl-006 Part 3 of 3 Examination Cate or 8-D Item 83.130 Full Penetration Welds of Nozzles in Vessels NOTE: See the evaluation of this request for relief under Section 3. 1.7.2 of this report.

3. 1.4 Pi in Pressure Boundar

3. 1.4. 1 Re uest for Relief No. Rl-003 Examination Cate or 8-J Item

89. 11 Pressure Retainin Circumferential Pi in Welds and Item 89.31 Branch Pi e Connection Welds Code Re uirement: Section XI, Table IWB-2500-1, Examination Category B-J, Items 89. 11 and 89.31 require a 100% surface and volumetric examination of Class 1 circumferential piping welds and of Class 1 branch pipe connection welds 4 inch and greater nominal pipe size as defined by Figures IW8-2500-8, -9, -10, and -11.

Licensee's Code Relief Re uest: Relief is requested from examining 100% of the Code-required volume of the 77 13

IVV II, 1

circumferential piping welds and the 14 branch connection welds listed in the Table attached to Request for Relief No. Rl-003.

Licensee's Pro osed Alternative Examination: None. The Licensee states that the piping systems will be subject to system leakage pressure tests and visually (VT-2) examined during each refueling outage. The subject welds will be volumetrically examined to the maximum extent possible.

Licensee's Basis for Re uestin Relief: The Licensee reports that piping weld configurations (reducer-to-tee, pipe-to-tee, pipe-to-flange, etc.) are not conducive to a 100% volumetric examination from both sides of the weld, as required by the Code. Some of the piping systems and components were designed and fabricated before the access and examination requirements of "ode Section XI, and especially, the requirements of Code Case N-335-1 could be applied. Consequently, some examinations are limited or not practical due to geometric configuration or accessibility problems. The limitations exist at joints where geometry and sometimes surface condition preclude ultrasonic coupling or access for the required scan length.

The Licensee also reports that, during PSI, examinations in limited areas were accomplished as a "best effort" attempt to cover as much of the Code-required area or volume as possible (generally, the weld and base metal of 1 "T" on each side).

However, the extent of examination coverage could not be specifically quantified as being 100%. The areas where a complete 100% examination could not be achieved were documented, along with the limitation, on the data sheets.

The Licensee states that no impact on plant quality, safety, or reliability is expected in that, in addition to the limited volumetric examination, the systems will be subject to system leakage pressure tests and will be visually (VT-2) examined during refueling outages.

14

I Evaluation: The relief request Table lists the component and weld identification, the weld configuration, the Code-requirement for which relief is being requested, the examination angle and technique being used, and the approximate extent of the Code-required examination that can be completed.

Of the 91 welds listed in the relief request, our review shows that only the 32 welds listed below are scheduled (in the Component Listing of the ISI Program Plan) for examination during the first 10-year inservice inspection interval.

xamination Cate or B-J Item B9. 11 Required Weld Number Examination  % Accessible I I - FMR-01RC-10 FW-2 UT-45L Circ. 67%, Axial 50%

I I - FMR-02RC-10 FW-3 UT-45L Circ. 67%, Axial 50%

I I-FMR-02RC-10 FW-8 UT-45L Circ. 50%, Axial 100%

I I -FMR-03RC-10-19-FW-2 UT-45L Circ. 67%, Axial 50%

II-RC-009RC-FW-1 UT-45S Circ. 67%, Axial 50%

II-RC-023RC-FW-327 UT-45S Circ. 63%, Axial 63%

II-RC-023RC-SW-B4 UT-45S Circ. 80%, Axial 80%

II-RC-023RC-SW-B5 UT-45S Circ. 90%, Axial 90%

II-RC-023RC-SW-C13 UT-45S Circ. 73%, Axial 73%

II-RC-023RC-SW-C9 ,UT-45S Circ. 87%, Axial 87%

II-RC-024RC-FW-318 UT-45S Circ. 100%, Axial 50%

II-RC-025RC-FW-331 UT-45S Circ. 67%, Axial 50%

II-RC-025RC-SW-A3 UT-45S Circ. 85%, Axial 85%

II-RC-027RC-SW-All UT-45S Circ. 100%o Axial 50%

II-RH-009RC-FW-292 UT-50S Circ. 67%, Axial 50%

II-RH-009RC-SW-A4 UT-50S Circ. 100%, Axial 93%

II-RH-009RC-SW-A5 UT-50S Circ. 100%, Axial 90%

II-RH-009RC-SW-A6 UT-50S Circ. 100%, Axial 90%o I I -SI -017RC- FW-297 UT-45S Circ. 67%, Axial 50%

I I -S I -021RC- FM-300 UT-53S Circ. 67%, Axial 50%

I I -S I -022RC- FW-301 UT-53S Circ. 67%o, Axial 50%

II-SI-023RC-FW-299 UT-53S Circ. 67%, Axial 50%

II-SI-024RC-FW-293 UT-45S Circ. 67%, Axial 50%

I I - S I -024S I - FW-588 UT-45S Circ. 67%, Axial 50%

I I-S I-025S I- FM-536 UT-45S Circ. 67%, Axial 50%

II-SI-027RC-FW-298 UT-45S Circ. 67%, Axial 50%

II-SI-027SI-FW-542 UT-45S Circ. 67%, Axial 50%

I I-S I-028RC- FM-296 UT-45S 15

h

Examination Cate or B-J Item B9.31 Required Weld Number Examination  % Accessible I I-FHR-01RC-10-17-SW-L2 UT-45L Circ. 67%, Axial 50%

I I-FHR-02RC-10-18-SW-K8 UT-45L Circ. 67%, Axial 50%

I I-FHR-03RC-10-19-SW-N2 UT-45L Circ. 67%, Axial 50%

I I-FHR-03RC-10-19-SW-N3 UT-45L Circ. 67%, Axial 50%

It is noted that 25 of the welds listed above will receive at least 50% of the Code-required examination and 6 welds will receive at least 85% of the Code-required examination. The volumetric examination of the subject welds, to the extent required by the Code, is impractical because of the fitting/component configurations. A significant percentage of the Code-required examination will be performed. These components would require redesign and refabrication in order to complete the remainder.

The remaining 59 welds listed in the relief request are not scheduled (in the Component Listing of the ISI Program Plan) for examination during the first 10-year inservice inspection interval. The Licensee should not request relief for those welds which are not required to be examined during the first 10-year inspection interval.

==

Conclusions:==

Based on the above evaluation, it is concluded that the Section XI surface examination and the limited Section XI volumetric examination ensure an acceptable level of inservice structural integrity. Compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, the following are recommended:

(a) relief should be granted for the 28 circumferential piping welds and the 4 branch connection welds listed above, and (b) relief should not be granted for the remaining 59 welds which are listed in the relief request but are not scheduled for examination during the current inspection interval.

16

3. 1.5 Pum Pressure Boundar 3.1.5.1 Re uest for Relief No. Rl-005 8 Examination Cateaor 8-L-1 Item 812.10 Pressure Retainin Welds in Pum Casin s and Examination Cate or 8-L-2 Item 812.20 Pum Casin s Code Re uirement: Section XI, Table IW8-2500-1, Examination Category B-L-1, Item 812.10 requires a 1005 volumetric examination of the Class 1 pressure retaining welds in pump casings as defined by Figure IWB-2500-16. Examination Category B-L-2, Item 812.20 requires a 100% visual (VT-3) examination of the internal surfaces of Class 1 pump casings.

The examinations are limited to welds in at .least one pump in each group of pumps performing similar functions in the system. The visual examination of the internal surfaces may be performed on the same pump selected for volumetric examination of the welds.

Licensee's Code Relief Re uest: Relief is requested from performing the Code-required volumetric examination of the pump casing welds and the visual (VT-3) examination of the internal surfaces of the pump casing of the reactor coolant pumps.

Licensee's Pro osed Alternative Examination: None. The Licensee states that the components will be subject to system leakage pressure tests during refueling outages, as well as system hydrostatic tests every 10-year interval. In addition, the subject pumps are continuously monitored in the control room, during pump operation, for bearing temperature, flow, vibration, motor current, leakage, and seal water flow, which will provide early indication of pump degradation.

Licensee's Basis for Re uestin Relief: The Licensee states that to perform volumetric (radiography) and visual examinations (VT-3) on the subject pumps would require disassembly of at least one pump. The Licensee feels that th'.s 17

Itsy C h

jX s'

disassembly process would be a hardship without any appreciable increase in the level of quality and/or safety.

The Licensee also states that the non-performance of volumetric and visual examinations of pump casing welds and pump casings should not have any adverse impact on plant quality, safety, or reliability for the following reasons:

4 (a) The reactor coolant pumps, being part of the primary system, are continuously monitored in accordance with the plant Technical Specifications, via control room instrumentation, for abnormal leakage during plant operation.

(b) 'he reactor coolant pumps are monitored in the control room during operation for bearing temperature, flow, vibration, motor current, and seal water flow, which will provide early detection of pump degradation.

(c) Pump casing base and weld materials utilized for fabrication of the pumps are widely used in nuclear industry with no known history of degradation or breach of primary system boundary.

(d) Pumps are subject to periodic system leakage/hydrostatic pressure tests to ensure structural integrity.

(e) The disassembly process, which may cause unnecessary damage to the pump, requires the expenditure of an estimated 1000 man-hours and 50 man-rem dose to disassemble, with essentially no compensating increase in plant afety or reliability.

Evaluation: The visual examinat'.on is to determine whether unanticipated severe degradation of the casing is occurring due to phenomena such as erosion, corrosion, or cracking. However, 18

i i"h 1,

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

The disassembly of the pumps for the sole purpose of inspection is a major effort and, in addition to the possibility of additional wear or damage to the pumps, could result in personnel receiving large amounts of radiation exposure. If the pumps are not disassembled for maintenance, the Licensee should perform a surface examination of the pump casing weld.

However, if the pumps are disassembled for maintenance, the Code-required volumetric and visual examinations should be performed.

Conclusions:

Based on the above evaluation, it is concluded that compliance with the specific requirements of,Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.

Therefore, it is recommended that relief be granted provided that the Licensee: a) performs the volumetric examination of the pump casing weld and visual examination of the internal surfaces of the pump casing whenever they are made accessible due to disassembly for maintenance; and b) performs a surface examination of the pump casing weld if the pumps are not disassembled for maintenance.

3. 1.6 Valve Pressure Boundar

3. 1.6. 1 Re uest for Relief No. Rl-005 A . Examination Cateoorv B-fl-2.

Item 812.50 Valve Bodies Exceeding 4 inch Nominal Pipe Size Code Re uirement: Section XI, Table IMB-2500-1, Examination Category B-H-2, Item B12.50 (Valve Body, Exceeding 4 in.

Nominal Pipe Size) requires a visual examination (VT-3) of the internal surfaces of valve bodies. The examinations are limited to one valve within each group of valves that are of the same constructional design, such as globe, gate, or check 19

ily v NVl

, ~

valve, and manufacturing'method, and that perform similar functions in the system such as containment isolation and system over-pressure protection. This examination may be performed at the end of the 10-year interval.

Licensee's Code Relief Re uest: Relief is requested from performing the Code-required visual (VT-3) examination of all Class 1 valves greater than 4 inches nominal pipe size as listed in the relief request.

Licensee's Pro osed Alternative Examination: Hone. The Licensee states that these components will be subject to system leakage pressure tests and visual (VT-2) examinations during refueling outages. In addition, the Class 1 primary system is continuously monitored for leakage during plant operations in accordance with the plant Technical Specifications.

Licensee's Basis for Re uestin Relief: The Licensee reports that the requirement to disassemble primary system valves for the sole purpose of performing a visual examination of the internal pressure boundary surfaces is considered to be a hardship, without any appreciable compensating increase in the level of quality and/or safety.

The Licensee states that the non-performance of visual examinations (VT-3) on the internal surfaces of safety Class 1 valves, exceeding 4 inch nominal pipe size, should not have any adverse impact on plant quality, safety, or reliability for the following reasons:

(a) The primary side Class 1 systems are continuous'.y monitored for abnormal leakage during plant operations in accordance with the plant Technical Specifications.

(b) Valves will be subject to system leakage tests, as well as system hydrostatic tests, in accordance with the ASHE 20

Section XI Code, which will provide added assurance of the structural integrity of Class I valves.

(c) Performing these visual examinations, under such adverse conditions such as high dose rates and poor as-cast surfaces, realistically, provides little additional information as to the valve casing integrity. In addition, disassembly of valves may also cause unnecessary damage to occur due to the disassembly process.

(d) The disassembly of the majority of the Class I valves would require fuel removal, or would require the primary system to be placed in a mid-loop condition.

Evaluation: The visual examination is to determine whether unanticipated severe degradation of the valve body is occurring due to phenomena such as erosion, corrosion, or cracking.

However, previous experience during examination of valves at other plants has not shown any significant degradation of valve bodies'.

Disassembly of the valves for the sole purpose of inspection is a major effort and, in addition to the possibility of additional wear or damage to the internal surfaces of the valves, could expose personnel to large amounts of radiation.

However, if the valves are disassembled for maintenance, the internal surfaces should be examined.

==

Conclusions:==

Based on the above evaluation, it is concluded that compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.

Therefore, it is recommended that relief be granted provided that the Licensee performs the visual examination (VT-3) of the internal surfaces of the valves whenever they are made accessible due to disassembly for maintenance.

21

3.1.7 General

3. 1.7. 1 Re uest for Relief No. Rl-002 Examination Cate or F-C Item F3.50 Functional Testin of Class 1 Snubbers NOTE: The functional testing of snubbers is not included in this evaluation. Functional tests are not within the scope of this document and will be evaluated elsewhere.

3. 1.7.2 Re uest for Relief No. Rl-006 Examination Cate or B-O Items 83.90 83. 110 and 83. 130 Full Penetration Welds of Nozzles in Vessels and E amination Cate or 8-F Item 85.40 Pressure Retainin Oissimilar Metal Welds Code Re uirement: Section XI, Table IWB-2500-1, .Examination Category B-O, Items 83.90, 83.110, and 83.130 require a 100%

volumetric examination of full penetration nozzle welds in Class 1 vessels as defined by Figure IWB-2500-7. Examination Category B-F, Item 85.40 requires both 100% surface and volumetric examinations of Class 1 pressure retaining dissimilar metal welds as defined by Figure IWB-2500-8.

Licensee's Code Relief Re uest: Relief is requested from examining 100% of the Code-required volume of the 23 full penetration nozzle-to-vessel welds (4 on the Reactor Pressure Vessel, 7 on the pressurizer, and 12 on the steam generators) and the 6 pressurizer nozzle-to-safe end welds (29 welds total) listed in the Table submitted in Request for Relief No. R1-006.

Licensee's Pro osed Alternative Examination: None. The Licensee states that volumetric (UT) examinations will be performed to the maximum extent possible from one side of each of the welds. In addition, component welds will be subject to system pressure tests during refueling outages in which visual (YT-2) examinations will be performed. Should a more advanced volumetric scanning technique to improve coverage become 22

I'I l

available, it will be evaluated for possible incorporation into the ISI Program.

icensee's Basis for Re uestin Relief: The Licensee states that, due to nozzle configurations of these components, 100%

volumetric examinations will be limited, mostly, to the shell side of the nozzle welds. In addition, shell side examinations will be limited, somewhat, due to obstructions (insulation tabs, heater obstructions). The Pressurizer nozzle to safe-end butt welds are also limited due to nozzle configurations and insulation tab obstructions. Volumetric examinations in limited areas will be accomplished as a best effort attempt to cover as much of the Code-required area or volume as possible.

The Table submitted with this relief request listed each component for which complete examination of the required volume or area could not be achieved and the reason as noted during the preservice examinations. The examiner data sheets for the preservice examinations are available at the plant for review.

The Licensee states that nozzle to vessel welds and nozzle to safe-end butt welds are not conducive to the two-sided volumetric examination due to nozzle configurations. In addition, obstructions, as part of the component design, prevent access to the full weld volume to perform 100%

volumetric examination.

The Licensee also states that no impact on plant sa ety, quality, or reliability is expected, as these components will be examined to the maximum extent possible, as well as be subject to visual examination (VT-2) during refueling outages, to ensure component integrity.

Evaluation: The relief request Table lists the component and weld identification, the weld configuration, the Code-requirement for which relief is being requested, the examination angle and technique being used, the specific cause for the limitation of the examination, and the approximate extent of the Code-required examination that can be completed.

23

Of the 29 welds listed in the relief request, our review shows that only the 22 welds listed below are scheduled (in the Component Listing of the ISI Program Plan) for examination during the first 10-year inservice inspection interval.

Examination Cate or 8-F Item 85.40 Required Weld Number xamination / Accessible I I-PZR-01NSEW-15 UT-50S 45%

I I-PZR-01NSEW-16 UT-45S 50%

I I -PZR-01NSEW-17 UT-45S 50%

II-PZR-01NSEW-18 UT-45S 50%

I I-PZR-01NSEW-19 UT-45S 50%

I I -PZR-01NSEW-20 UT-45S 50%

xamination Cate or 8-0 Item 83.90 Required Weld Number Examination / Accessible I I-RV-001RVNOZAI-N-01 UT 96%

II-RV-001RVNOZAO-N-06 UT 88%

II-RV-001RVNOZBO-N-02 UT 88%

II-RV-001RVNOZCO-N-04 UT 88%

Examination Cate or 8-0 Item 83.110 Required Weld Number Examination - Accessible I I-PZR-01NTHW-08 UT-OO. 40%

UT-45S 40%

-

UT-60S 35%

I I-PZR-01NTHW-09 UT-00 50%

UT-45S 50%

UT-60S 50%

I I- PZR-01NTHW-10 UT-00 50%

UT-45S 50%

UT-60S 50/o I I - PZR-01NTHW-11 UT-00 50%

UT-45S 50%

UT-60S 50%o II-PZR-01NTHW-12 UT-00 50%

UT-45S 50%

UT-60S 50'Io I I - PZR-01NTHW-13 UT-00 50%

UT-45S 50/o UT-60S 50%

Examination Cate or~ B-0 Item B3. 130 Required Weld Number Examination / Accessible I I -SG-001SGA-CLNTVW-12 UT-00 49%

UT-45S 49%

UT-60S 49%

II-SG-001SGA-HLNTVW-07 UT-00 49%

UT-45S 49%

UT-60S 49%

II-SG-001SGB-CLNTVW-12 UT-00 49%

UT-45S 49/o UT-60S 49%

II-SG-001SGB-CLNTVW-07 UT-00 49%

UT-45S 49%

UT-60S 49%

II-SG-001SGC-CLNTVW-12 UT-00 49/o UT-45S 49%

UT-60S 49%

II-SG-001SGC-CLNTVW-07 UT-00 49%

UT-45S 49%

UT-60S 49%

It is noted that 18 of the welds listed above will receive approximately 50% of the Code-required examination and 4 welds will receive at least 88% of the Code-required examination.

The volumetric examination of these welds, to the extent required by the Code, is impractical due to nozzle configurations and insulation tabs and heater obstructions. A significant percentage of the Code-required examination will be performed. These components would have to be redesigned and refabricated in order to complete the remainder.

The remaining 7 welds listed in the relief request are not scheduled (in the Component Listing of the ISI Program Plan) for examination during the first 10-year inservice inspection interval. The Licensee should not request relief for those welds which are not required to be examined during the first 10-year inspection interval.

==

Conclusions:==

Based on the above evaluation, it is concluded that the limited Section XI volumetric examination and the 25

4 1I',

Code-required surface examination (Examination Category B-F welds) ensure an acceptable level of inservice structural integrity. Compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, the following are recommended: (a) relief should be granted for the 22 welds listed above, and (b) relief should not be granted for the remaining 7 welds which are listed in the relief request but are not scheduled for examination during the current inspection interval.

3.2 Class 2 Com onents 3.2.1 Pressure Vessels 3.2. 1. 1 Re uest for Relief No. R2-005 Examination Cate orv C-A Items C1.10 C1.20 and Cl.30 Pressure Retainin Welds in Class 2 Pressure Vessels Examination Cate or C-8 Items C2.21 and C2.22 Pressure Retainin Nozzle Welds in Vessels and Examination Cate or C-C Item C3. 10 Inte ral Welded Attachments for Vessels Code Re uirement: Section XI, Table IWC-2500-1, Examination Category C-A, Items Cl. 10, C1.20, and Cl.30 require a 100%

volumetric examination of Class 2 vessel shell circumferential welds, head circumferential welds, and tubesheet-to-shell welds as defined by Figures IWC-2500-1 and -2.

Examination Category C-B, Item C2.21 requires both 100% surface and volumetric examinations of Class 2 nozzle-to-shell welds, and Item C2.22 requires "a 100% volumetric examination of the vessel nozzle inside radius section as defined by Figures IWC-2500-4(a) or (b).

Examination Category C-C, Item C3. 10 requires a 100% surface examination of integrally welded attachments to Class 2 vessels as defined by Figure IWC-2500-5.

26

Ql

'1 lw i

icensee's Code Relief Re uest: Relief is requested from examining 100% of the Code-required volume of the following welds:

Bor on In 'ecti on Tank 2 vessel head circumferential welds (Item C1.20) 2 nozzle-to-shell welds (Item C2.21)

Excess Letdown Heat Exchan er I vessel head circumferential welds (Item C1.20)

Steam Generator 7 vessel shell circumferential welds ( Item Cl. 10) 3 vessel head circumferential welds (Item Cl.20) 3 vessel tubesheet-to-shell welds (Item C1.30) 9 nozzle-to-shell welds (Item C2.21) 4 nozzle inside radius sections (Item C2.22)

Re enerative Heat xchan ers 6 vessel head circumferential welds (Item Cl.20) 6 vessel tubesheet-to-shell welds (Item C1.30)

Re idual Heat Removal Heat Exchan ers 2 vessel shell circumferential welds (Item Cl. 10) 2 vessel head circumferential welds (Item Cl.20)

Relief is also requested from examining 100% of the Code-required surface area of the Regenerative Heat Exchanger integrally welded attachment ( Item C3. 10) listed in the Table attached to Request for Relief No. R2-005.

Licensee's Pro osed Alternative xamination: None. The Licensee states that volumetric and surface examinations will be performed to the maximum extent possible. Components will be subject to periodic system leakage/hydrostatic pressure tests and visual (VT-2) .examinations.

Licensee's Basis for Re uestina Relief: The Licensee states that the weld configurations (end cap geometry, flanges, nozzles, etc.) and obstructions (reinforcement plates, welded attachments, permanent hangers, insulation tabs, access ports, etc.) will prevent 100% volumetric and/or surface 27

il examinations. In addition, some nozzles on each steam generator [SG-001 SG(A), (B), (C) HSNIR-15] were designed without a nozzle radius section, thus the volumetric examination cannot be performed. Volumetric and surface examinations in limited areas will be accomplished as a best effort attempt to cover as much of the Code-required area or volume as possible.

During preservice activities, the areas where complete examination of the Code-required area or volume could not be achieved were indicated and the extent of limitations or obstructions noted on the examiners data sheet.

The piping systems and components were designed and fabricated before the access and examination requirements of the Code could be applied. Consequently, some examinations are limited or not practical to perform due to geometric configuration or accessibility.

Evaluation: The relief request Table lists the component and weld identification, the weld configuration, the Code-requirement for which relief is being requested, the examination technique being used, and the approximate extent of the Code-required examination that can be completed.

Of the 48 welds listed in the relief request, our review shows that only the 31 welds listed below are scheduled (in the Component Listing of the ISI Program Plan) for examination during the first 10-year inservice inspection interval.

Examination Category C-A. Item C1.10 Required Meld Number Examination I(oneAccessible I I - RHR-01RHRA-CSM-02 UT-00 50% side only)

UT-45S 50% (one side only)

II-SG-001SGA-CSM-03 UT-00 99.9%

UT-60S 99.9%

II-SG-001SGC-CSW-10 UT-00 99.9%

UT-60S 99.9%

28

Examination Cate or C-A Item C1.20 Required Weld Number Examination  % Accessible I I-BIT-01STHW-01 UT-00 89%

UT-45S 89%

I I - BIT-01STHW-02 UT-00 49% (upper side only)

UT-45S 49% (upper side only)

I I-EL-001STHW-01 UT-45S 82%

I I -RHR-01RHRA-STHW-01 UT-00 50%

UT-45S 50%

I I -RHX-01CHTSW-01 UT-00 99%

UT-45L 30%

I I-RHX-01CHTSW-02 UT-00 99%

UT-45L 30%

I I-RHX-01CHTSW-03 UT-00 99%

UT-45L 30%

I I -RHX-01CHTSW-04 UT-00 99%

UT-45L 40%

I I- RHX-01CHTSW-05 UT-00 99%

UT-45L 40%

II-RHX-01CHTSW-06 UT-00 99%

UT-45L 40%

II-SG-001SGB-STHW-02 UT-00 99.9%

UT-45S 99 '%

UT-60S 99.9%

Examination Cate or C-A Item C1.30 Required Weld Number Examination  % Accessible II-RHX-01TSTSW-07 UT-00 80%

UT-45L 55%

I I -RHX-01TSTSW-08 UT-00 80%

UT-45L 55%

II-RHX-01TSTSW-09 UT-00 80%

UT-45L 55%

I I -RHX-01TSTSW-10 UT-00 80%

UT-45L 65%

I I -RHX-01TSTSW-11 UT-00 80%

UT-45L 65%

I I-RHX-01TSTSW-12 UT-00 79/

UT-45L 65%

II-SG-001SGC-TSTSW-09 UT-00 81 '%

UT-45S 88.7%

UT-60S 35%

29

xamination Cate or C-B Item C2.21 Required Weld Number Examination " Accessible I I - B IT-01NTHW-03 UT-00 50/ (head side only)

UT-45S 50% (head side only)

I I - BIT-01NTHW-04 UT-00 50% (head side only)

UT-45S 50% (head side only)

I I-SG-001SGA-AFWNTSW-11 UT-00 50/. (shell side only)

UT-45S 50/ (shell side only)

UT-60S 50/ (shell side only)

II-SG-001SGB-FWNTSW-05 UT-00 49.9% (shell side only)

UT-45S 50% (shell side only)

UT-60S 49.9% (shell side only)

II-SG-001SGC-MSNTHW-01 UT-00 50% (shell side only)

UT-45S 50/ (shell side only)

UT-60S 50% (shell side only)

E amination Cate or C-B Item C2.22 Required Weld Number Examination  % Accessible I I -SG-001SGA-MSN IR-15 VOL 0%

II-SG-001SGB-MSNIR-15 VOL 0%

II-SG-001SGC-MSNIR-05 VOL 0% (UT-70S)

I I-SG-001SGC-MSNIR-15 VOL 0%

Examination Cate or C-C Item C3.10 Required Weld Number xamination  % Accessible I I - RHX-01HSTSW-A1 PT 99%

The volumetric examination of these welds, to the extent required by the Code, is impractical due to the weld configurations and/or permanent obstructions. It is noted that in all cases, except the Steam Generator nozzle inside radius sections, a significant percentage of the Code-required examination will be completed.

Attachment 2 of the Licensee's August 6, 1986 (Reference 8) submittal provided a description of the Steam Generator nozzle inside radius section. The nozzle is a one-piece forging containing a set of seven holes bored parallel to the nozzle centerline. A venturi type flow restrictor is installed in 30

'la H

e

each of these holes. This design does not utilize a radiused nozzle as described in Figure IWC-2500-4 but instead has seven individual inner radii, corresponding to each venturi.

Therefore, the Code-required volumetric examination of the Steam Generator nozzle inside radius sections is impractical.

The remaining 17 welds listed in the relief request are not "

scheduled (in the Component Listing of the ISI Program Plan) for'examination during the first 10-year inservice inspectior, interval. The Licensee should not request relief for those welds which are not required to be examined during the first 10-year inspection interval.

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric and/or surface examinations ensure an acceptable level of inservice structural integrity. Compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, the foll'owing are recommended: (a) relief should be granted for the 31 welds listed above, and (b) relief should not be granted for the remaining 17 welds which are listed in the relief request but are not scheduled for examination during the first 10-year inspection interval.

3.2.2. 1 Re uest for Relief No. R2-001 Part I of 2 Examination Cate or C-F Items C5.11 C5.12 and C5.21 Class 2 Pressure Retainin Pi in Welds and Examination Cate orv C-C Item C3.20 nte ral Welded Attachments for Pi in NOTE: See the evaluation of this request for relief under Section 3.2.5. 1 of this report.

0 0

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'd\

3.2.2.2 Re uest for Relief No. R2-003 xamination Cate or C-F Item C5.21 Class 2 Pressure Retainin Circumferential Pi in Welds Code Re uirement: Section XI, Table IMC-2500-1, Examination Category C-F, Item C5.21 requires both 100% sur face and volumetric examinations of Class 2 circumferential piping welds greater than 1/2 inch nominal wall thickness as defined by Figure IMC-2500-7.

icensee's Code Relief Re uest: Relief is requested from examining 100% of the required volume of the 206 circumferential piping welds listed in the Table attached to Request for Relief No. Rl-003.

This list includes 51 circumferential piping welds required to be examined by the Code, 124 circumferential piping welds that the Licensee selected as part of an augmented examination (This augmented examination requires a sample of welds in the ECCS, CHR, and RHR systems to be volumetrically examined.), and 31 circumferential piping welds that the Licensee selected as part of an augmented examination for high-energy fluid system p'.ping between containment isolation valves.

icensee's Pro osed Alternative xamination: None. The Li'censee states that each of these piping welds will be volumetrically examined to the extent indicated in the Table attached to the relief request.

Licensee's Basis for Re uestin Relief: The Licensee states that the piping weld configurations (reducer-to-tee, pipe-to-tee, pipe-to-flange, etc.) will not be conducive to 100% volumetric (UT) examination as required by the Code and/or Code Case N-335-', as applicable. The arrangement and details of the piping systems and components were designed and fabricated before the access and examination requirements of the Code, and especially the requirements of Code Case N-335-1 32

could be applied. Consequently, some examinations will be limited, or not practical to perform due to geometric configuration or accessibility. The limitations exist at fitting-to-fitting joints, where geometry and sometimes surface conditions will preclude ultrasonic coupling or access for the required scan length.

In most cases, ultrasonic examination, in limited areas, will be accomplished as a best effort attempt to cover as much of the Code-required area or volume as possible (generally, the weld and base metal of I "T" on each side). These areas, where complete examination of 100% of the required volume or area could not be achieved, are documented on each applicable examination data sheet, and the limitations noted.

The Licensee states that no impact on overall plant quality, safety, or reliability is expected as subject components will be examined to the maximum extent possible and will be subject to periodic pressure tests and visual examinations in accordance with the Code tto ensure component integrity.

~valuatio : The relief request Tab1e lists the component and weld identification, the weld configuration, the Code-requirement for which relief is being requested, the examination technique being used, and the approximate extent of the Code-required examination that can be completed.

Of the 206 welds listed in the relief request, our review shcws that only the 51 welds listed below are scheduled (in the Component Listing of the ISI Program Plan) for examination during the first 10-year inservice inspection interval.

Exam. Category/ Required Weld Number Item Number Examination  % Accessible II-AF-005AF-FM-249 Augmented UT-45S Circ. 67%, Axial 50%

II-AF-005AF-FM-251 Augmented UT-45S Circ. 67%, Axial 50%

II-AF-006AF-FM-246 Augmented UT-45S C rc. 67%, Axial 50%

II-AF-007AF-FM-239 Augmented UT-45S Circ. 67%, Axial IG0%

33

~Q h 1 II

%go I

C,

(continued)

Exam. Category/ Required Weld Number Item Number Examination  % Accessib1e II-AF-007AF-FM-241 Augmented UT-45S Circ. 67%, Axial 100%

II-CS-007SI-FM-25 Augmented UT-45S Circ. 67%, Axial 50%

II-CS-022CS-FM-561 Augmented UT-45S Circ. 67/, Axial 50%

II-CS-022CS-FM-562 Augmented UT-45S Circ. 67%, Axial 50%

II-CS-092CS-FW-3029 Augmented UT-45S Circ. 67%, Axial 50%

II-CT-001CT-FW-8 Augmented UT-45S Circ. 67%, Axial 50%

II-CT-001CT-FW-9 Augmented UT-45S Circ. 100%, Axia1 50%

II-CT-002CT-FW-19 Augmented UT-45S Circ. 67%, Axial 50%

II-CT-002CT-FM-20 Augmented UT-45S Circ. 67/, Axial 50%

I I -CT-014CT- FW-175 'Augmented UT-45S Circ. 67%, Axial 43%

I I-CT-016CT-FW-145 Augmented UT-45S Circ. 67%, Axial 50%

I I - F W-001F W- SW- 04 Augmented UT-45S Circ. 67%, Axial 100%

I I -FW-001FW-32-4-SW-1 Augmented UT-45S Circ. 67%, Axial 100%

II-FW-001FM-32-5-SW-5 Augmented UT-45S Circ. 67%, Axial 100%

II-FW-002AF-FW-259 Augmented UT-45S Circ. 67%, Axial 67%

II-FW-003AF-FW-266 Augmented UT-45S Circ. 67/, Axial 67% .

II-FW-004AF-FW-273 Augmented UT-45S Circ. 67%, Axial 50%

I I -'F W'-004AF - FW-276 'C-F/C5.21 (Aug.) UT-45S Circ. 67%, Axial 50%

I I -MS-001MS-SW-All C-F/C5.21 (Aug.) UT-45S To be determined I I-MS-001MS-SW-Bl I C-F/C5.21 (Aug.) UT-45S To be determined I I-MS-001MS-SW-Cl 1 C-F/C5.21 (Aug. UT-45S To be determined II-MS-002MS-FW-566 Augmented UT-45S Circ. 67%, Axial 100%

II-MS-002MS-FW-567 Augmented UT-45S Circ. 67%, Axial 100%

II-MS-002MS-FW-568 Augmented UT-45S Circ. 67%, Axial 100%

II-MS-002MS-FW-690 Augmented UT-45S Circ. 67/, Axial 100%

II-MS-002MS-FW-691 Augmented UT-45S Circ. 6?%, Axial 100%

II-MS-002MS-FW-692 Augmented UT-45S Circ. 67%, Axial 100%

II-MS-007MS-FW-678 Augmented UT-45S Circ. 67%, Axial 100%

! I-RH-001RH-FM-8 Augmented UT-45S Circ. 67%, Axial. 50%

II-RH-002RH-FM-21 Augmented UT-45S Circ. 91%, Axial 82%

I I-RH-OOZSI-FW-21 Augmented UT-45S Circ. 91/, Axial 82%

!I-RH-009RH-FM-14 C-F/C5.21 (Aug.) UT-50S Circ. 67%, Axial 50%

II-RH-009RH-FW-15 Augmented UT-45S Circ. 67%, Axial 50%

I I -RH-010RH-FM-193 C-f/C5.21 (Aug.) UT-50S Circ. 67%, Axial 50%

I I -RH-010RH-FW-2 Augmented UT-45S Circ. 67%, Axial 50%

I I-S I -008S I-FM-450 C-F/C5.21 UT-60S Circ. 100%, Axia1 67%

II-SI-016SI-FW-36 Augmented UT-45S Circ. 100%, Axia1 75o II-SI-019SI-FW-277 Augmented UT-45S Circ. 67%, Axial 50%

I I -S I -021S I-FW-557 C-F/C5.21 UT-53S Circ. 67%, Axial 50%

II-SI-024SI-213-FW-573 C-F/C5.21 UT-45S Circ. 100%, Axia 50" 1

II-SI-025SI-FW-578 C-F/C5.21 UT-45S Circ. 67%, Axial 50%

I I -S I -025S I -FW-580 C- F/C5. 21 UT-45S Circ. 67%, Axial 50%

I I- S I-025S I- FM-583 C-f/C5.21 UT-45S Circ. 100/, Axia1 71%

I I -S I -026S I -FM-582 C-F/C5.21 UT-45S Circ. 67%, Axial 50%

I I -S I -026S I -FW-592 C-F/C5.21 UT-60S Circ. 67%, Axial 50%

I I -S I -028S I -FM-610 C-F/C5.21 UT-45S Circ. 67%, Axial 50%

II-SI-029SI-SW-C14 Augmented UT-45S Circ. 67%, Axial 50%

34

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The volumetric examination of these welds, to the extent required by the Code and/or augmented requirements, is impractical due to geometric configuration or accessibility. A significant percentage of the Code-required examination will be performed.

It is noted that complete examinations which meet the requirements of ASHE Code Section XI will be performed on welds of similar configuration using the same inspection techniques, equipment, and procedures as those partially inspected. Since the partially inspected welds will see the same operating and environmental conditions as the fully inspected welds, reasonable assurance of the structural integrity of the welds for which relief is requested will be attained.

The remaining 155 welds listed in the relief request are not scheduled (in the Component Listing of the ISI Program Plan) for examination during the first 10-year inservice inspection interval. The Licensee should not request relief for those welds which are not required to be examined during the First 10-year inspection interval.

==

Conclusions:==

Based on the above evaluation, it is concluded that the limited Section XI volumetric examination, along with the Code-required surface examination, ensures an acceptable level of inservice structural integrity. Compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, tl e following are recommended: (a) relief should be granted for the 51 welds listed above, and (b) relief should not be granted for the remaining 155 welds which are listed in the relief request but are not scheduled for examination during the first 10-year inspection interval.

3.2.2.3 Re uest for Relief No. R2-004 Examination Cate or C-F Items C5. 11 and C5.21 Class 2 Pressure Retainin Pi in Welds Code Re uirement: Section XI, Table IWC-2500-1, Examination Category C-F, Item C5. 11 requires a 100% surface examination of Class 2 circumferential pressure retaining piping welds 1/2 inch or less nominal pipe thickness, and Item C5.21 requires both 100/ surface and volumetric examinations of Class 2 circumferential pressure retaining piping welds greater than 1/2 inch nominal wall thickness as defined by Figure IWC-2500-7.

icensee's Code Relief Re uest: Relief is requested from performing the required volumetric and/or surface examination of the 34 circumferential piping welds listed in the Table attached to Request for Relief No. R2-004.

This list includes 26 circumferential piping welds required to be examined by the Code, 4 circumferential piping welds the 'I Licensee selected as part of an augmented examination (This augmented examination requires a sample of welds in the ECCS, CHR, and RHR systems to be volumetrically examined.), and 4 circumferential piping welds the Licensee selected as part of an augmented examination for high-energy fluid system piping between containment isolation valves.

icensee's Pro osed Alternative xamination: None. The Licensee states that these components will be subject to periodic system leakage tests and visual (VT-2) examinations.

Containment penetrations are also subject to testing in accordance with 10 CFR 50 Appendix J on a period'.c basis as required by the plant Technical Specifications.

Licensee's Basis for Re uestin Relief: The Licensee states that the component welds are located inside of containment penetrations (flued heads, valve chambers) and are inaccessible 36

lrt sf

for performing Code-required examinations. System leakage/hydrostatic pressure tests will be performed as required to ensure structural integrity.

The Licensee states that no impact on plant quality, safety, or reliability is expected as the welds will be subject to periodic system leakage/hydrostatic testing, as well as testing in accordance with 10 CFR 50 Appendix J on a periodic basis as required by the plant Technical Specifications.

~va1uation: Our review shows that none of the 34 welds listed are scheduled (in the Component Listing of the IS I Program Plan) for examination during the first 10-year inservice inspection interval. The Licensee should not request relief for those welds which are not required to be examined during the current inspection interval; however, these welds should be included in the population from which the examination sample is selected.

This request for relief is not applicable for the first 10-year inspection interval and, therefore, should be withdrawn by the Licensee.

Conclusions:

Based on the above evaluation, it is concluded that the Licensee should withdraw this request for relief because it is not applicable for the current 10-year inspection interval. Therefore, it is 'recommended that relief should not be granted.

3.2.3 ~Pum s 3.2.3.1 Reouest for Relief No. R2-001 Part 2 of 2 Examination Cate or C-C Item C3.30 Inte ral Melded Attachments for Pum s

~NOT : See the evaluation of this request for relief under Section 3.2.5. 1 of this report.

37

i1 p

"1' pl/ t P'

3.2.4 Valves (No relief requests) 3.2.5 General 3.2.5. 1 Re uest for Relief No. R2-001 xamination Cate or C-F Items C5. 1 C5. 12 and C5.21 Class 2 Pressure Retainina Pi in Welds and Examination Cate or C-C Items C3. 0 and C3.30 nte ral Welded Attachments For Pi in and Pum s Code Re uirement: Section XI, Table IWC-2500-1, Examination Category C-F, Items C5. 11 and C5. 12 require a 1001. surface examination of Class 2 circumferential and longitudinal pressure retaining piping welds 1/2 inch or less nominal wall thickness as defined by Figure IWC-2500-7. Item C5.21 requires both 100/ surface and volumetric examinations of Class 2 circumferential piping welds greater than 1/2 inch nominal wall thickness as defined by Figure IWC-2500-7.

Section XI, Table IWC-2500-1, Examination Category C-C, Items C3.20 and C3.30 require a 100K surface examination of Class 2 piping and pump integrally welded attachments whose base material design thickness is 3/4 inch or greater as defined by Figure IWC-2500-5.

icensee's Code Relief Re uest: Relief is requested from examining 100'5 of the required surface area and/or volume of the 29 welds listed in the Table submitted in Request for Relief No. R2-001.

This list includes 5 circumferential piping welds ( Items C5.11 and C5.21), 1 longitudinal piping weld (Item C5.12), 14 integral welded attachments (Items C3.20 and C3.30), 8 circumferential piping welds the Licensee selected as part of an augmented examination (This augmented examination requires a sample of welds in the ECCS, CHR, and RHR systems to be volumetrically examined.), and 1 circumferential piping weld 38

the Licensee selected as part of an augmented examination for high-energy fluid system piping between containment isolation valves.

Licensee's Pro osed Alternative Examination: None. The Licensee states that the components will be subject to periodic systems pressure tests, as well as periodic hydrostatic and visual (VT-2) examination. The welds will be volumetrically (UT) examined to the maximum extent possible in accordance with the ISI Program schedule. In addition, the components will be subject to system pressure tests during each refueling outage.

Licensee's Basis for Re uestin Relief: The Licensee states that relief is requested from performing 100% volumetric and/or surface examinations on subject circumferential piping weld and integral welded attachments due to component configurations (pumps, valves) not being conducive to examination, and/or structural obstructions (permanent hangers, saddle plates, support structures, or intervening members for other systems) not allowing accessibility to perform the Code-required surface and/or volumetric examination.

In addition, in response to NRC question 250. 1 and FSAR Section 6.6.8, a large sample of welds in the ECCS, CHR, and RHR Systems, as well as No-Break-Zone-Criteria components were examined during PSI activities (1064 examinations, including 525 surface and 539 volumetric), providing additional assurance of structural integrity.

The request for relief included an itemized listing of components, percentages of completion based on preservice data, and identification of specific reasons as to why a 100% Code examination cannot be performed. The Licensee states that, should a more advanced nondestructive examination technique become available, it will be evaluated for possible incorporation into the ISI Program.

39

I'

• The Licensee also states that no impact on plant quality, safety, or reliability is expected, as the subject components will be examined to the maximum extent possible, as well as be subject to periodic pressure tests and visual examinations in accordance with the Code to ensure component integrity.

Evaluation: The relief request Table lists the component and weld identification, the weld configuration, the Code-requirement for which relief is being requested, the examination technique being used, and the approximate extent of the Code-required examination that can be completed.

Of the 29 welds listed in the relief request, only the 11 welds listed below are scheduled (in the Component Listing of the ISI Program Plan) for examination during the first 10-year inservice inspection interval.

Exam. Category/ Required Weld Number Item Number Examination  % Accessible II-AF-006AF-FW-245 Augmented UT-45S Circ. 75%, Axial 75%

I I-CS-021CS-H-0011 I (4) C-C/C3.20 PT 95%

I I -CS I P-1CS I P-A-WAI C-C/C3.30 PT 80%

II-CSIP-1CSIP-A-WA2 C-C/C3.30 PT 78%

I I-.CS I P-1CS IP-A-WA3 C-C/C3.30 PT 78%

I I -CS IP-1CSIP-A-WA4 C-C/C3.30 PT 70%

II-FMR-OIFW-H-02121(8) C-C/C3.20 HT 83%

II-FW-002AF-FW-257 C-F/C5.21 (Aug.) UT-45S Circ. 50%, Axial 50%

II-FW-002AF-FW-258 C-F/C5.21 (Aug.) UT-45S Circ. 67%, Axial 100%

II-FW-003AF-FW-269 C-F/C5.21 (Aug. UT-45S Circ. 67%, Axial 100%

II-FW-004AF-FW-277 C- F/C5. 21 HT 95%

C-F/C5.21 (Aug.) UT-45S Circ. 67%, Axial 100%

The volumetric and/or surface examinations of these welds, to the extent required by the Code, are impractical because of component configurations and/or structural obstructions not permitting accessibility for the examinations. A significant percentage of the Code-required examination will be performed.

These components would have to be redesigned and refabricated in order to complete the remainder.

40

The remaining 18 welds listed in the relief request are not scheduled (in the Component Listing of the ISI Program Plan) for examination during the first 10-year inservice inspection interval. The Licensee should not request relief for those welds which are not required to be examined during the first 10-year inspection interval.

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric and/or surface examinations ensure an acceptable level of inservice structural integrity. Compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, the following are recommended: (a) relief should be granted for the 11 welds listed above, and (b) relief should not be granted for the remaining 18 welds which are listed in the relief request but are not scheduled for examination during the first 10-year inspection interval.

3.2.5.2 Re uest for Relief No. R2-002 xamination Cate or F-C Item F3.50 Functional Testin of Class 2 Snubbers

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

3.3 Class 3 Com onents 3.3.1 ~pioio (No relief requests) 3.3.2 ~Pum s (No relief requests) 3.3.3 Valves (No relief requests)

3.3.4 General 3.3.4. 1 Re uest for Relief No. R3-001 Examination Cate or F-C Item F3.50 Functional Testin of Class 3 Snubbers NOTE: The functional testing of snubbers is not included in this evaluation. Functional tests are not within the scope of this document and will be evaluated elsewhere.

3.4 Pressure Tests (No relief requests) 3.5 General (No relief requests)

J

~1 4t

4. CONCLUSION 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 except Requests for Relief Rl-003 (in part), R1-006 (in part),

R2-001 (in part), R2-003 (in part), R2-004, and R2-005 (in part), the Licensee has demonstrated that either the proposed alternatives would provide an acceptable level of quality and safety or that compliance with the requirements would result in hardships or unusual difficulties without a compensating increase in the level of quality and safety. For Requests for Relief R1-003, R1-006, R2-001, R2-003, R2-004, and R2-005, welds are listed that are not scheduled (in the Component Listing of the ISI Program Plan) for examination during the first 10-ye'ar inspection interval. The Licensee should not request relief for those welds which are not required to be examined during the current inspection interval. Requests for Relief R1-002, R2-002, and R3-001 request relief from the functional testing of Code Class 1, 2, and 3 snubbers. Evaluations of these requests are not included in this document because functional tests of snubbers are not within the scope of this document and are being evaluated elsewhere.

This technical evaluation report has not identified any practical method by which the existing Shearon Harris Nuclear Power Plant, Unit 1, can meet all the specific inservice inspection requirements of Section XI of the ASHE Code. Requiring compliance with all the exact Section XI required inspections would require redesign of a significant number of plant systems, sufficient replacement components to be obtained, installation of 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,ASHE Code that have been determined to be impractical.

Pursuant to 10 CFR 50.55a(g)(6), relief is allowed from these requirements which are impractical to implement.

The development of new or improved examination techniques should continue to be monitored. As improvements in these areas are achieved, the Licensee 43

should incorporate these techniques in the next inspection interval ISI program plan examination requirements.

Based on the review of the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice Inspection Program Plan, and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice, Inspection Program Plan is acceptable and in compliance with 10 CFR 50.55a(g)(4).

ll '

0

5. REFERENCES

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. Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice Inspection Program Plan, dated January 28, 1988.

4. NUREG-0800, Standard Review Plans, Section 3.6. 1, "Plant Design for Protection Against Postulated Piping Failures in Fluid Systems Outside

, Containment," Section 5.2.4, "Reactor Coolant Boundary Inservice Inspection and Testing," and Section 6.6, "Inservice Inspection of Class 2 and 3 Components," July 1981.

5. Regulatory Guide 1. 14, "Reactor Coolant Pump Flywheel Integrity,"

Revision 1, dated August 1975.

6. Regulatory Guide 1. 150, "Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations," Revision 1, February 1983.

7. Letter, dated October 11, 1983, G.W. Knighton (NRC) to E.E. Utley (Carolina Power and Light Company), request for additional information.

8. Letter, dated August 6, 1986, S.R. 2immerman (Carolina Power and Light Company) to H.R. Denton (NRC), response to NRC request for additional information.

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45+OAT NVMBER IAN TIIId OI rrOC Idd I m Hd IIIIIA V.S NVCLEAR REGVLATORY COMMISSION

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NRC lORM $ 25 I2 Sds vRCM ~ 102 2201 2202 BIBLIOGRAPHIC DATA SHEET EGG-HS-8090 SEE IHSTRVCTIO'NS ON TIIE REVERSE i EAVE SLAHI(

Ir' AHO SVSrlr' Technical Evaluation Report on the First 10-Year Interval Inservice Inspection Program Plan:

Carolina Power and Light Company, Shearon Harris MONTH QATE 4$ 404T CQM4'TEO

>EAR Nuclear Power Plant, Unit 1, Docket Number 50-400 5 AVT>QRISI Jul 1988 5 GATE RETORT ISSI'EO MQN'rII Y E*R B.W. Brown, J.D. Hudlin Jul 1988 AERdORMING ORGANIZATIONNAME ANQ MAILING*CORESS 114rlddd Zd CodN 5 rROlECrnASrAYORR VHIT NVMSER 2

EG8G Idaho, Inc. 5 FIN OR GRAN'r NVMSER P. 0. Box 1625 Idaho Falls, IO 83415-2209 FIN-06022 (Project 5) 11 ~ T~TE OF RETORT IO $ 404$ 04ING ORGANIZATION NAME ANQ MAR IHG AOORE$ $ 114II4dd C 4 Cdddl Haterials Engineering Branch Technical Office of Nuclear Reactor Regulation 4 +ERIOQ CQVEREO rl444I~Id IHNIl U.S..Nuclear Regulatory Commission Washington, D.C. 20555 12 5VrdLEMENTARYNOTES 12, AESTR ACT l200 I44IYI AI IMI This report presents the results of the evaluation of the Shearon Harris Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice Inspection ( ISI) Program Plan, submitted January 28, 1988, including the requests for relief from the American Society of Hechanical Engineers (ASHE) Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical. The Shearon Harris Nuclear Power Plant, Unit 1, First 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 the examination sample, (c) exclusion criteria, and (d) compliance with ISI-related commitments identified during the Nuclear Regulatory Commission (NRC) review before granting an License. The requests for relief from the ASHE Code requirements which the 'perating Licensee has determined to be impractical for the first 10-year inspection interval are evaluated in Section 3 of this report.

ICE~WOROSIOESCRIATQRS 15 AVAII,ABI'TY IA QQCVMENT ANALYSIS ~,

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