ML20042F108

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

ML20042F108
Person / Time
Site:	Perry
Issue date:	12/31/1989
From:	Beth Brown, Mudlin J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20042F098	List: ML20042F108
References
CON-FIN-D-6022 EGG-MS-8378, NUDOCS 9005070228
Download: ML20042F108 (46)

Text

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EGG-MS 8378 December 1989 t

l TECHNICAL EVALUATION REPORT' Y

I -/deho TECHNICAL EVALUATION REPORT ON THE FIRST l Net /ons/ 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM Eng/neer/n8 PLAN: CLEVELAND ELECTRIC ILLUMINATING COMPANY, PERRY NUCLEAR POWER PLANT, UNIT 1, Laboratory DOCKET NUMBER 50-440' Manageo' B. W. Brown by the U.S. J. D. Mudlin Department

. of Energy 1

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Prepared for the l4EGcG ,

U.S. NUCLEAR REGULATORY COMMISSION Wont performed under DOE Contract

. No. DE AC07 MIO015?O 9003070228 900425 PDR ADOCK 05000440 f PDC

EGG-MS 8378 TECHNICAL EVALUATION REPORT ON THE ,

'FIRST 10-YEAR-INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

CLEVELAND ELECTRIC ILLUMINATING COMPANY,

' PERRY NUCLEAR POWER PLANT, UNIT I, DOCKET NUMBER'50 440 i

l B. W. Brown. J J. D. Mudlin l 1

1 Published December 1989 -

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^l Idaho National Engineering Laboratory EG&G Idaho, Inc. ,

Idaho Falls, Idaho 83415 '

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! . Prepared for:

U.S. Nuclear Regulatory Commission.

l Washington, D.C. 20555 l l* under 1 DOE Contract No. DE-AC07-761D01570 'l FIN No. D6022 (Project 5)  ;

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, ABSTRACT This report presents the results of the evaluation of the Perry Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice Inspection (ISI).

Program Plan, Revision 0, submitted March 31, 1987, 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 Perry Nuclear Power Plant, Unit 1, First 10 Year Interval ISI Program Plan is evaluated in Section 2 of this report. 1 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 l exclusion criteria, and (d) compliance with ISI-related commitments  ;

identified.during the Nuclear l Regulatory Commission (NRC) . review before granting an Operating License. The requests for.' relief are evaluated in Section 3 of this report.

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l This work was funded under:

L U.S. Nuclear Regulatory Commission .

l FIN No. D6022, Project 5 t L Operating Reactor Licensing Issues Program, L

Review of ISI for ASME Code Class 1, 2, and 3 Components f 11 f

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SUMMARY

The Licensee, Cleveland Electric Illuminating Company, has prepared the i Perry Nuclear. Power Plant, Unit 1, First 10-Year Interval Inservice Inspection (ISI)' Program Plan, Revision 0, 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 2 piping welds has been [

determined by ASME' Code Case'N-408, " Alternative Rules for Examination of Class.2 Piping." The first 10-year interval began November 13, 1987 and.  ;

ends November 13, 1997.

The information in the Perry Nuclear Power Plant, Unit 1, First 10-Year-Interval-ISI Program Plan, Revision 0, submitted March 31,'1987, was

- reviewed. 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 sub'mittals dated April 12, 1988 and November 18, 1988. Included in the November 18, 1988 submittal were the

. requests for ralief from the ASME Code Section XI requirements which the Licensee has determined to be impractical.

Based on the review of the Perry Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan, Revision 0, the Licensee's responses to the l.

Nuclear Regulatory Commission's RAI, and the recommendaticas for granting ,

i relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Perry Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan, Revision.0, is acceptable and in compliance with 10 CFR 50.55a(g)(4).

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. CONTLNTS l ABSTRACT .......................-.......................................... it i

SUMMARY

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

2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN ..................... 4 2.1 ' Documents: Evaluated .............................................. 4- l 1

2.2 Compliance with Code Requirements ................................. 4 2.2.1 Compliance with Applica' ale Code Editions . . . . . . . . . . . . . . . . . . . . . 4-2.2.2 Acceptability of the Etamination Sample ...................... 5 2.2.3 Exclusion Criteria .......................... ................ 5  !

2.2.4 . Augmented Examination Commitments ............................ 5 2 . 3 C o n cl u s i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - 6

3. EVALUATION OF RELIEF REQUESTS..............-.......................... 7 3.1 Cl a s s 1 C omp o n e nt s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

'3.1.1 Reactor Pressure Vessel ...................................... 7 3.1.1.1 - Request for Relief IR-001 (part 1 of 3),  !

Examination Category B-A, Items Bl.ll, Bl.12,  :

Bl.21, Bl.22,,and Bl.40, Reactor Pressure Ve s sel Shell 1.nd Head Wel d s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.1.1.2 Request for Relief IR-001 (part 2 of 3),

Examination Category B-0, Items B3.90 and f B3.100, Reactor Pressure Vessel Nozzle Welds and Nozzle Inside Radius Sections ........................ 9 3.1.1.3 Request for Relief IR-003, Examination Category B-3-1, Item B6.40, Reactor Pressure 4

Vessel Fl ar ge Ligament Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 i 3.1.1.4 Request for Relief IR-009, Examination Category E-0, Item B14.10, Control Rod Drive Housing Flange Welds ..................................... 14 3.1.2 Pressurizer (Does not. apply to BWRs) 3.1.3 Heat Exchangars (No relief requests) iv 4 l

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.. 3.1.4 Piping? Pressure Boundary..................................... 15 3.1.4.l' Request for. Relief IR-00l=(part 3 of 3), -l Examination Category B F, Item B5.10, Pressure. j Retaining-Nozzle-to Safe End Welds ...................... 15

3. l ~. 4. 2 Requests for Relief IR-004 and IR-006, i Examination Category B-J, Items B9.11 and B9.12, -

. Class 1-Pressure Retaining Piping Welds ................. 17 l 3.1.4.3 -Request for Relief IR 005, Examination

, Category'B-J, Item B9.11, Class 1 Pressure ,

Retaining: Piping Welds With Corrosion Resistant Cladding ................................................ 19-3.1.4.4 Request for Relief IR&OO7, Examination: -

_ Category B-K-1, Item B10.10, Integrally Welded-Support Attachments for Cl ass 1 Piping . . . . . . . . . . . ... . . . ... . 21 3.1.5 . Pump Pressure _ Boundary ...................................... 23 3.1.5.1 Request for: Relief IR-002, Examination Category B G-1~, Item B6.180,. Reactor-Recirculation Pump Studs ................................ 23 j 3.1.6 V al ve Pre s s u re ' Bound a ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ' 24 3.1.6.1 Request for Relief IR-008, Examination. l Categcry B-M-1, Item B12.40, Class 1~ Valve Bo dy We l d s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 3.1.7 General (No relief requests) 3.2 C l a s s 2 C om p o n e n t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 3.2.1 P re s s u re Ve s s el s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 l 3.2.1.1 Request for Relief IR-010, Examination

! Category C-A, Item C1.'20, Pressure Retaining l Welds in Cl ass 2 Pressure - Vessel s . . . . . . . . . . . . . . . . . . . . . . . 26 3.2.1.2 Request for Relief ~IR-Oll, Examination Category C-B, Item C2.21, Pressure Retaining-Nazzle Welds in Cl ass 2 Pressure Vessel s . . . . . . . . . . . . . . . . 27 3.2.2 Piping ...................................................... 29-

.- 3.2.2.1 Request for Relief IR-012, Examination Category C-C, Items C3.10 and C3.20, Class .2 System Integrally Welded Attachments .................... 29-3.2.2.2 Request for Relief IR-015, Examination Category C-C, Item C3.20, Class 2 Penetration-to-Process Pipe Attachment Welds ............ 30 ,

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l3 2.3. Pumps .......................................................

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3.2.3.1 Request-for Relief IR-013 ' Examination . ,

Category C-G, Item C6,10, Class 2. Pump Casing Welds . . . . . 32  ;

3.2.4 Valves.......................................................33 3.2.4.1 Request for Relief IR-014, Examination .

, Category C-G, C6.20, Class 2 Valve Body Weld ............ 33 3.2.5 General (No relief requests) l 1-3.3, Class 3 Components (No relief requests) 3.4 Pressure Tests (No relief requests) ,

3.5 General (No relief requests) .[

4. CONCLUSION ......................................................... 35  ;

- 5. REFERENCES ......................................................... 37 ,

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. TECHNICAL EVALUATION-REPORT ON THE . .

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. FIRST 10-YEAR--INTERVAL INSERVICE INSPECTION PROGRAM PLAN:.

CLEVELAND ELECTRIC ILLUMINATING COMPANY, PERRY NUCLEAR POWER PLANT, UNIT l',- i DOCKET NUMBER 50-440

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

c supports) which are classified as American Society of' Mechan.ical Engineers (ASME) Boiler and Pressure Vessel- Code Class 1, Class 2,. and Class' S 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 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 I therein. The Licensee, Cleveland Electric-Illuainating Company, has  !

I prepared the Perry Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice Inspection (ISI) Program Plan, Revision 0, to mee~t the requirements of.the 1983 Edition, Summer 1983 Addenda (83S83) of the ASME Code Section XI except that the extent of examination for Class 2 piping welds has been determined by ASME Code Case N-408, " Alternative Rules for Examination of Class 2 Piping" (Reference 3). The first 10-year interval began November 13, 1987 and ends November 13, 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 tMm, 1

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fthe licensee shall- submit information and-justifications to the Nuclear-

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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 property or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the '

licensee that could result'if the requirements were imposed on the facility.

The informatio'n in the Perry Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan, Revision 0 (Reference 4), submitted March 31, 1987, was reviewed. The. review of the ISI Program Plan was i 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." r

In.a latter dated' February 9,1988 (Reference 6)', th'e 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 attachments to letters dated April- 12, 1988 (Reference 7)', and November 18,'1988 (Reference 8). The November 18, 1988' response also contained requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical'for the first .10-year inspection interval.

As a result of a telephone conversation with the Licensee'on January 4,1989, the Licensee provioed additional information for clarification of Request for Relief IR-002 in a submittal dated January 6, 1989 (Reference 9).

- The Perry 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) correctness of the  ;

- application of system or component examination exclusion criteria, and 2

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

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2.1 Documents Evaluated ,

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Review has been completed on the.following information from the Licensee: l (a) Perry Nuclear Power Plant, Unit.1,. First' 10 Year Interval Inservice Inspection Program Plan, Revision 0, submitted March 31, 1987; (b) Letter, dated April 12, 1988,. containing the Licensee's response'to the NRC's February 9,1988 request for additional information with regard to Revision 0 of the ISI Program Plan; ,

(c) Letter, dated November 18, 1988, from the Licensee containing requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical for the first 10-year ,

inspection interval; and l l

(d) Letter, dated January 6,1989, containing a drawing for Relief Request IR-002 and color-coded boundary diagrams.

2.2 Comoliance with Code Recuirements 2.2.1 Como11ance with Acolicable Code Editions 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 March 18, 1986, the Code applicable to the first 10 year interval is the 1980 Edition through Winter 1981 Addenda (80W81).

Effective October 28, 1985, the NRC amended this Code reference by updating to the 83S83 Code for applicable facilities. Therefore, the 4

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o C Licensee elected ~to update to 83S83 of the-ASME Code Section XI except  ;

.- thatl,the extent of examination for Code Class 2 piping ' welds has been- F determined by ASME Code Case N 408,'" Alternative Rules for Examination of I

Class 2 Piping." This Code Case has been approved by the NRC.as l- referenced in NRC Regulatory Guide 1.147, " Inservice Inspection Code Case l Acceptability, ASME.Section XI, Division 1" (Reference 10). 1 2.2.2 - Acceptability of the Examinsiion Samole '

Inservice volumetric, surface, and visual ' examinations shall be performed ,

oa ASME Code Class 1, 2, and 3 components and their supports using ,

sampling schedules described in Section XI of the ASME Code and ~

L 10 CFR 50.55a(b). Sample size and weld selection have been implemented in ,

accordance with the Code and 10 CFR 50.55a(b)'and appear to be correct. ,

F Exclusion Criteria 2.2.3 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). . Sample size and weld selectlon have been _ implemented in-accordance with the Code and 10 CFR 50.55a(b) and appear to.be correct, c

2.2.4 Auomented Examination Commitments >

In addition to the requirements specified in Section XI of the ASME Code,

. the Licensee has committed to the following augmented examinations:

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l. (a) Examinations will be performed in accordance with NUREG-0519, "BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking" (Reference 11). This augmented ISI program is directed solely to the i

volumetric,l surface, and visual examination requirements for the feedwater nozzles.

(b) Augmented' volumetric and surface examinations are being performed on the high energy piping system welds in the containment break -

, exclusion regions.

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(c) ' Augmented volumetric examinations will be performed on the jet pump

'holddown beams to ensure the_ integrity of the beam area. These examinations will- be performed, commencing with the final refueling j:

outage of the inspection interval,_ and continuing as. applicable.

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_(d) Augmented visual examinations'are scheduled for the reactor pressure  ;

i vessel dry tubes (which are accessible) to determine the condition of the tubes. One-third (33'/.) of the dry tubes are scheduled for ,

examination during each. inspection period. i (e) An augmented visual examination is scheduled for the reactor vessel jet pump sensing lines and support brackets. This visual examination will determine the integrity of.the weld between the support brackets and the vertical run on the sensing line of the jet pumps. closest to-the recirculation outlet nozzles. The initial examination is tentatively scheduled to commence during the final refueling outage of the inspection interval.  ;

l 2.3 Conclusions Based on the review of the documents listed above, it is concluded that' the  ;

Perry Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan, Revision 0, 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 that the Licensee has determined to be impractical for the first 10-year-inspection interval are evaluated in the following sections.

3.1 Class 1' Comoonents ,

3.1.1 Reactor Pressure Vessel 3.1.1.1 Reauest for Relief IR-001 (part 1 of 3). Examination Cateaory B-A. Items B1.11. Bl'.12. 81.21. Bl.22. and Bl.40.

Eggtpr Pressure Vessel Shell and Head Welds Code Reauirement: Section XI, Table IWB-2500 1, Examination Category B-A,' Item B1.11 requires a 100% volumetric examination of Reactor Pressure Vessel (RPV) circumferential shell welds as defined by Figure IWB-2500 1.

RPV longitudinal shell welds, Item'~Bl.12. are recuired to receive a 100% volumetric examination as defined by Figure IWB-2500-2.

RPV circumferential head welds, Item Bl~.21, are required to receive a 1.00% volumetric examination as defined by Figure l IWB-2500-3.

l RPV meridional head walds, Item Bl.22, are required to receive a 100% volumetric examination as defined by Figure IWB-2500-4.

l The RPV head-to-flange weld,. Item Bl.40, is required to receive l

both 100% surface and volumetric examinations as defined by Figure _IWB-2500 5.

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

! examining 100% of the Code-required volume of the following RPV I welds: ,

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. Examination Cov'eraae .

. Item Perp . Parallel. . Scan Path Obstructions Number d'31 d ID Scan Scan 'and/or Limitations B1.11 1-613 AA- 50% 50% . Support skirt and base

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Adjacent nozzle.

B1.11 1-B13 AB 85% 99%

Bl.11 1-B13-AC 91% 100%: Adjacent nozzle. .;.-

Bl.11' B13-AD- 99%- 97% Shell taper 4

Bl.12 1-B13-BA -70% 78% . Adjacent nozzle 81.12 1-B13-BB- 74% 76% Adjacent' nozzle i Bl.12 1-B13-BC 75% 75% Adjacent nozzle Bl.12 1-B13 BE 92% 90%. Adjacent nozzle

Bl.12 1-B13-BG 70% 75% Adjacent nozzle Bl.12 1-B13 BJ 69% 68% Adjacent nozzle Bl.12 1-B13-BK 88% '100% Adjacent nozzle Bl.12 1-B13-BN 64%- 69% Adjacent nozzle and mechanical limits of scanner B1.12 1-B13-BP 85% 88% Adjacent nozzle and-  ;

mechanical limits of scanner 81.12. 1-B13-BR 89% 86% Adjacent. nozzle and mechanical limits of -

scanner 81.21 1-B13-AH .96% 100% . Lifting lug '

Bl.22 1-B13-DG 29% 29%: CRD tube bundle and-skirt. knuckle' Bl.22 1-B13-DH. 29% 29% CR0 tube bundle and- a skirt knuckle Bl.40 1-B13-AG 50% 50% Head flange Licensee's Proposed Alternative Examination: None. The Code-required volumetric examination will be performed to thel maximum extent possible as indicated above. The Code-required ,

l surface examination of weld 1-B13-AG will be performed.

L Licensee'sBasisforReauestinoReliefi The Licensee states

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l- that relief is requested from the. required 100% volumetric examination because of partial inaccessibility of the' subject.

i. RPV welds due to adjacent nozzle obstructions, support skirt and base ring obstruction on lower head, shell taper, lifting lugs, CRD tube bundle and skirt knuckle. obstructions, and mechanical limitations.of the scanner.-.

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, 1, l Evaluatio'n: 'The-volumetric examination of the subject RPV weldi is' impractical:to perform to the extent required by the' ]

Code because of the obstructions ~ listed above. The percentages (listed above) of the Code-required volumetric examinations that. can and will be completed are consistent with other plants - l of similar design. The limited Section XI' volumetric q examination of ~ these welds'will provide' reasonable assurance of 1 the continued' inservice structural integrity.- .

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The development of new or~ improved examination techniques should continue.to be mon _itored. As improvements in these.

f areas are achieved, the Licensee should incorporate these techniques in the ISI program plan examination requirements.

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Conclusions:

Based on the above evaluation, it is concluded that the volumetric examination of the subject welds is

• impractical to perform to.the extent required by the Code.

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

3.1.1.2 Recuest for Relief IR-00i (Dart 2 of 3). Ex, amination Cateoory B-D. Items-B3,90 and B3.100. Reactor Pressure Vessel Nozzle Welds and hazzle Inside R@s Sections Code Reouirement: Section XI', Table IWB-2500-1, Examination  !

Category B-D, Items B3.90 and B3.100 ' requires - t 100% volumetric "

examination of'the RPV nozzle-to-vessel welds and nozzle inside radius sections as defined by the applicable figure as shown in-

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Figures IWB-2500-7(a) through (d).-

Licensee's Code Relief Recuest: Relief _ is requested from.

examining 100% of the Code-red . red volume of the following RPV l

I nozzle-to-vessel welds and nozzle inside radius sections:

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'N0ZZLE-TO-VESSEL WELDS - Item'B3.90 Estimated  ;

Examination Coveraae >

Perp.- Parallel Scan Path Obstructions.

Weld ID Scan Scan and/or Limitations-1-B13-NIA-KA 89% 46% Nozzle geometry and ,

o mechanical limits of- 1 scanner l-B13-N1B KA 83% 10% Nozzle ' geometry and L

mechanical limits of- r scanner-1-B13-N2A-KA 65% 36% Nozzle geometry,;

biowall. doors, and mechanical limits of .

scanner 1-B13 N28-KA 86% 49% Nozzle geometry and-mechanical . limits of ,

scanner 1-B13-N2C-KA '86% 74% Nozzle geometry,-

adjacent nozzle, and mechanical ~ limits-ofL scanner ,. ,

1-B13-N2D-KA 74% 46% Nozzle geometry, adjacent nozzle, ,

permanent vessel tracks,- and mechanical.

111mits of scanner -

1-B13-N2E-KA 73% 67% Nozzle geometry, permanent vessel track, and mechanical limits of. scanner 4 1-B13-N2F-KA 87% 37% ' Nozzle geometry, permanent vessel track, and mechanical limits of' scanner:

1-B13-N2G-KA 83% 37%~ Nozzle geometry and-I mechanicalLlimitsiof-scanner l 1-B13-N2H-KA 89% 37% Nozzle geometry, d adjacent nozzle, and mechanical' limits of =

scanner 1-B13-N2J KA 88% 53% - Nozzle geometry, adjacentinozzle, and mechanical limits of.

scanner 1-B13-N2K-KA -86%- 46% . Nozzle geometry, permanent vessel .

track, and mechanical limits of scanner 1-B13-N4A-KA 97% 32% Nozzle geometry.

1-B13-N48-KA 99% 59% Nozzle geometry 1-B13-N4C-KA 93% 32% Nozzle geometry'

. 1-813-N4D-KA 83% 32% . Nozzle geometry.and permanent vessel track 10

i -a 1 N0ZZLE-TO-VESSEL 1 WELDS'- Item B3.90!(continued) j

- Estimated:

Examination Coveraoe Perp. . Parallel Scan Path.0bstructions- (

Weld ID Scan Scan- and/or' Limitations 1-B13-N4E-KA- 98% 59% Nozzle geometry.  ;

Nozzle" geometry 1-B13-N4F-KA 97% -59%

1-B13-NSA-KA- 98% 61%- Nozzle geometry. t 1-B13-N58 KA 98% 29% Nozzle geometry -

1-B13-N6A-KA- 95% 56%. Nozzle-geometry 3 1-B13-N6B-KA 93% 70% Nozzle geometry  !

u 1-B13-N6C-KA' 95%. 56% Nozzle geometry )'

l-B13 N7-KA- - 89% .: 1100% Adjacent nozzle i

1-B13-N8-KA 89% 100% Adjacent nozzle l l-B13-N9A-KA 81% :100% Adjacent; nozzles 1-B13-N9B-KA 81% 100%.- Adjacent nozzles i 1-B13-N15-KA 0% 0% CRD' tube' bundle N0ZZLE.INSIDE RADIUS SECTIONS - Item E3.100 Estimated. .

~ Examination Scan Path Obstructions Weld 10 Coveraoe and/or-Limitations

, 1-B13-NIA-IR 92% Shell. side limited by taper-

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1-B13-NIB-IR: 92% Shell side--limited by taper-1-B13-N2A-IR '88% Shell side limited by taper.

1-B13-N28-IR- 88%- Shell sidellimited by taper 1-B13-N2C-IR 86% Shell side limited by taper and adjacent nozzle. '

l-B13-N2D-IR 86% Shell side.--limited'by taper and adjacent nozzle '

• l-B13-N2E-IR 88% Shell side limited by taper 1-B13-N2F-IR 88% Shell side limited by taper.

l l-B13-N2G-IR 88% Shell side l.imited by_ taper l-B13,N2H-IR 86% Shell side-limited by taper '

and ~ adjacent! nozzle - .

1-B13-N2J-IR 86% Shell side limited by. taper t and-adjacent nozzle

j. 1-B13-N2K-IR 88% Shell side limited by taper

1-B13-N4A IR 96% Shell side limited by j adjacent nozzle' ,

e 1-B13-N4C-IR 96% Shell side limited.by adjacent nozzle.

l' 1-B13-N4D-IR 96% Shell side limited by

l. adjacent nozzle L 'l-B13-N4F-IR 96% Shell side limited by adjacent nozzle L 1-B13-N7-IR- .94% Shell side limited by

! adjacent nozzle L 1-B13-N8-IR 94% Shell side limited by adjacent nozzle 1-B13-N9A-IR 96% Shell side limited by adjacent nozzles l- 1-B13-N9B-IR 96% Shell side limited by '

l-adjacent nozzles n

l 11

i

" Q__ xe Licensee's Proposed Alternative Examination: None. The l Code-reouired volumetric examination willLbe performed to the maximum extent possible as indicated above.. 3

, Licensee's Basis for Reouestino Relief:' The Licensee states that relief is requested from the required-100% volumetric examination because of partial inaccessibility of the subject RPV nozzle-to-vessel welds and~ nozzle inside radius sections.-

due:to nozzle geometry, permanent vessel tracks, adjacent ,

nozzle obstructions, shell taper, CRD' tube bundle obstructions, and mechanical limitations of the scanner.

. Evaluation: The volumetric exami.na'tions of'the subject RPV 2 nozzle-to-vessel welds and nozzle inside'. radius sections are impractica? ta perform to-the extent required by the' Code because of the obstn:ctions listed above. -The percentages

~(listed above) of the Code-required volumetric examinations l that can and-will be completed are consistent with other plants 4

of similar design. The limited Section!XI volumetric examination of these welds and inner radius sections wills provide reasonable assurance of the continued inservice.

structural integrity.

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

l'

Conclusions:

Based on the above evaluation, it is concluded-that the: volumetric examinations of the subject RPV nozzle-to-vessel welds and nozzle inside radius sections are impractical to perform to the extent required by[the Code.

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

. 12 V

3 .c l

'3.1.1.3 'Recuest'for Relief IR-003. Examination Cateoorv B-G-1.

Item B6.40. Reactor Pressure Vessel Flance Licament Araa i

Code Reouirement:--Section'XI, Table IWB-2500-1, Examination Category B-G-1, Item B6.40: requires a 100% volumetric examination of the threads'.in the RPV flange -as defined by

- Figure'IWB-2500-12.  :

Licensee's Code Relief Reouest: Relief is requested from l examining 100% of the Code-required volume of the RPV flange' l J

ligaments.

Licensee's Proposed Alternative Examination: e e..'The l Licensee states that:the threads in the RPV flange will receive volumetric examination to the maximum extent possible'.- j 1

Licensee's' Basis for Reouestino Relin.f: The Licensee' states that the examination of the threads in the RPV flange is limited to 93% because of interference with the. lip of the~

' flange seal' . surface. . Examinations meeting the requirements-of "

the ASME Code Section XI will continue to be performed on 93%

of the subject' volume, which is subject to the same operating and-environmental conditions as the unexamined volume. It.is, i therefore, reasonable to apply the results from examined. volume L to the non . examined volume. In addition, catastrophic reactor vessel failure is precluded by avoiding nil ductile L

temperatures at sionificant stress levels according to the-design, surveillance, and operating provisions described in the Perry USAR Sections 5.3.1 and 5.3.2 and the Technical Specifications 3/4.4.6.

)

Evaluation: The volumetric examination of the threads in.the RPV flange is irpractical to perform to the extent required by )

the Code because of interference with the lip of the. flange . I L seal surface as shown in Figure ISI-B13-014 of the ISI. Program .)

j- Pl an . A significant percentage (93%) of the Code-required j 1

1 L 13 we ,.,,

volume will be examined. The limited Section XI volumetric  !

-examinat' ion provides reasonable e.ssurance of the continued inservice structural integrity.-

(pnclusions: Based on' the above evaluation, it is' concluded that the volumetric examination is impractical to perform to

.the extent required by the Code. Therefore, it is recommended that relief be granted as requested.

4 3.1.1.4 Reauest for Relief IR-009' Examination Cateaory B-0.

Item B14.10. Control Rod Drive Housina Flanae Welds j 1

Code Reauirement:- Section XI, Table IWB-2500 1, Examination 1 i

Category.B-0, Item B14.10 requires a 100% volumetric or surface  !

examination of 10% of the peripheral control' rod drive; (CRD) housing welds as defined by Figure IWB-2500-18.-

l 1

Licensee's Code Relief Reauest: Relief is requested from l examining 100% of the Code-required surface of the flange welds j in the CRD housings.  !

licensee's Procosed Alternative Examination: None. The Licensee states that the subject weld surfaces will receive l

surface examination to the maximum extent possible. l 1

Licensee's Basis for Recuestina Relief:- The subject-  !

examination areas are partially inaccessible for surface- ,

examination due to hydraulic control line interferences. The d portions of welds being examined are subject to Lthe same

]

operating and environmental conditions as the unexamined - q portions. Approximately 85% of weld surface will'be examined. j It is, thereforc, reasonable to apply the results from examined

{

weld portions to the unexamined portions.  !

s 1)

Evaluation: The surface examination of the CRD 1 housing'-to-flange welds is impractical to perform to the: extent .j i

14 -!

q d

i

required by the Code because of hydraulic control 11ne

. interferences. However, as shown in pages 215.through 218 of>

the' ISI Program Plan, the Licensee has scheduled six welds to be' examined of which only 85% of each weld is1 accessible.

Since the Code requires that 100% of four of the'CRD l housing-to-flange welds be examined (10%' of peripheral CRD .

housing-to-flange welds), an aggregate weld length total that-is greater than or equivalent to-the Code requirement will receive surface examination.

Conclusions:

Based on the' above. evaluation, it is concludea that the surface examination of the subject welds is impractical to perform to the extent required:by the-Code.

Therefore, it is recommended that relief be granded as -

-3 requested.

3.1.2 Pressurizer (Does not apply to- BWRs) 3.1.3 Heat Exchanaers '(No relief. requests) 3.1.4 Pioina Pressure Boundary t 3.1.4.1 Reauest for Relief IR-001-(part 3 of 3)', Examination Cateoorv B-F. Item B5.10. Pressure Retainino Nozzle-to-Safe End Welds ,

Code Reauirement: Section XI,-Table IWB-2500-1, Exas.ination Category B-F, Item B5.10 requires both '100% volumetric and surface examinations of the RPV nozzle-to-safe end butt welds

[

nominal pipe size 4 inches and greater as defined by i

Figure IWB-2500-8.

i_icensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume of the following RPV' nozzle-to-safe end welds:

15 i

-?

t t

Estimated Examination Coverace Perp.- Parallel _

Scan Path 10bstructions

. Weld ID Scan -Scan and/or Limitations-1-813-N2A-KB 55% -75% Nozzle geometry-and .

1 permanent vessel track 1-B13-N2B-KB 74% 87% Nozzle-geometry and OD  :

weld contour.  ;

1-B13-N2C-KB 22%- '75% Nozzle geometry and 0D' weld . contour 1-B13-N2D-KB. 47%- 100%- Nozzle geometry and OD- '

weld contour- '

l-B13-N2E-KB 75% 88%- Nozzle geometry ['

.1-B13-N2F-KB; 12%~ 85% Nozzle. geometry and 0D-weld contour "

1-B13-N2G-KB- 20.' 97% Nozzle geometry and'0D weld contour 1-B13-N2H-KB- 57% 97%l Nozzle geometry and 00~ <

weld contour.

1-B13-N2J-KB 83% 88%' , Nozzle geometry; l-B13-N2K-KB 74%: 88% Nozzle geometry 4 1-B13-N4A-KB 87% 100% Nozzle geometry :t 813-N48-KB 77%- 98% Nozzle geometry 1-B13-N4C-KB 83% 98%. ' Nozzle _ geometry

~1-B13-N4D-KB 83% 98%- Nozzle gecmetry 1-813-N4E-KB 80% 98% Nozzle geometry 1-B13-N4F-KB 79% 73% Nozzle geometry and OD weld contour 1-813-NSA-KB 86% 100%. Safe end transition '

taper L 1-B13-N58-KB 86% -100% Safe end transition t taper-l' 1-B13-N6A-KB 91% 100% Nozzle geometry _and l safe end transition taper, 1-B13-N68-KB 93%- 74% Nozzle._ geometry, safe i end transition taper, and OD weld. contour >

l-B13-N6C-KB 95% 82%' Nozzle geometry, safe  ;

end transition ~ taper, i and OD weld contour Licensee's Proposed Alternative Examination: None. The q Code-required volumetric examination will ~ be performed to the maximum extent possible as indicated above and the ,

Code-required 100% surface examination will be_ performed.

l Licensee's Basis for Reauestina Relief: The Licensee' states j that relief is requested from the required 100% volumetric I examination because of partial inaccessibility of the subject 16 -

I

RPV nozzle to safe end welds due to nozzle geometry, permanent vessel tracks. 00 weld contour, and safe end transition taper.

Evaluation: The volumetric examination of the subject RPV nozzle-to safe end welds is impractical to perform to the +

extent required by the Code because of the obstructions listed ,

above. The percentages (as listed above) of the Code-required volumetric examinations that can and will be completed are consistent with other plants of similar design.- The limited Section XI volumetric examination and the Section XI 100%

surface examination of these welds will provide reasonable assurance of the continued inservice structural integrity. .

(pnelusions: Based on the above evaluation, it is concluded i that the volumetric examination of the subject RPV nozzle to safe end welds is impractical to perform to the .

extent required by the Code. Therefore, it is recommended that ,

relief be granted as requested.

3.1.4.2 Reauests for Relief IR 004 and IR 006. Examination Cateaory B-J. Items B9.11 and 89.12. Class 1 Pressure Retainina Eipi,.a Welds l

Code Reauirement: Section XI, Table IWB 25001, Examination Category B.J Items 89.11 and B9.12 require both 100%  :

volumetric and surface examinations of the pressure retaining circumferential and longitudinal welds in Class 1 piping of -

nominal pipe sizes 4 inches and greater. These examinations are to be as defined by Figure IWB 2500-8.

1 Licensee's Code Relief Reouest: Relief Request IR-004: Relief  ;

is requested from examining 100% of the Code required volume of the following Class 1 piping welds:

L a

17

i e ..

Estimated Examination Coveraae Item Weld Perp. Parallel Nature of Number Number Sean Sean Obstruction '

89.11 1 B21 0025 50% 100% Geometry B9.12 1-821 01220 95% 95% Branch Connection ,

B9.11 1 821 0133 50% 100% Geometry.

B9.11 1 E12 0406 50% 75% Structural i B9.11 1 E12 0880 80% 100% Containment Penetration and Weld Geometry B9.11 1 E22 0012 95% 100% Joint Geometry B9.12 1 833-002701 92% 92% Lug 89.11 1-B33 0062 100% 75% Geometry Relief Request IR 006: Reitef is requested from examining 100%

of the Code required surface of weld 1.B33-0027U1 (also limited for volumetric examination as listed above) in the reactor recirculation system. The Licensee states that only 90% of this weld is accessible for surface examination due to a pipe lug which prevents contact with the remainder, i

licensee's Proposed Alternative Examination: None. The Licensee states that partial volumetric examinations will be  ;

performed on the subject welds to the extent listed above. The Code-required surface examinations will be performed on all welds except weld 1 B33-002701 which will receive a partial surface examination.

Licensee'sBasisforReauestinoRelief: The L$censee states q that the subject Class 1 piping welds are partially inaccessible for the Code required volumetric examinations due to weld and/or component geometry, structural-interferences,-

and interference due to a piping lug. The Licensee also states

.that, since the construction, operating conditions, and ,

environmental conditions.of the non examined portion of the welds are identical to the examined portions, it is reasonable to apply satisfactory rekults from examined to'the non-examined l portions.

i 18  ;

1

.N

_=

1 l .,

Evaluation: The volumetric (and surface for weld 1-B33-0027Ul) I examination of the subject Class 1 piping welds is imppactical l to perform to the extent required by the Code due to the i component / weld geometry (nozzle-to-flange, nozzle to-pipe, pipe-to valve, pipe to elbow, elbow to penetration), structural ,

I interference, and interference due to pipe lug. A significant i

!' percentage of the Code required volume of the subject welds can i and will be examined. The limited Section XI volumetric and 100% Code required surface (limited surface examination for weld 1-833 0027U1) examinations provide reasonable assurance of the continued inservice structural integrity of the welds, l

Conclusions:

Based on the above evaluation, it is concluded ,

that the volumetric (and surface for weld 1-B33 0027U1) ,

examinations of the subject welds are impractical to perform to  ;

the extent required by the Code. Therefore, it is recommended that relief be granted as requested.

3<l.4.3 Reauest for Relief 1R 005. Examination Cateaory S-J.

I Item B9.11. Class 1 Pressure Retainina Pioina Welds With Corrosion Resistant Claddina l Code Reauirement: Section XI, Table IWB 2500-1, Examination '

Category B-J, Item B9.11 requires both 100% volumetric and  !

l I

surface examinations of the pressure retaining circumferential welds in Class 1 piping of nominal pipe sizes 4 inches and l greater. These examinations are to be as defined by Figure IWB-2500 8.

Licensee's Code Relief Recuest: Relief is requested from examining 100% of the Code-required volume of the following -

Class I circumferential piping welds in the reactor recirculation system due to geometry:

e t

19

Estimated Examination Coverace Weld Weld Perp. Parallel Number Dajeriotion Sean $_q)n 1 B33-0027 16" cap to-pipe 95% 100*.'

1 B33 003B 12" pipe to nozzle 50% 100%

l B33-0043 12" pipe-to nozzle 50% 100%

l B33-0049 12" pipe to nozzle 50% 1007.

1 B33-0054 12" pipe to nozzle 50% 100Y.

1-B33 0056 16" x 12" sweepolet 50% 100%

to 12" pipe 1-B33 0059 12" pipe-to nozzle 50% 100%

l B33 0074 22" elbow to pump 50% 100%

l-B33-0076 24" pipe-to pump 50% 100Y.

1-B33 4081 24" valve to pipe 50% 100Y.

1 B334088 24" pipe to 24 x 16" 50% 100%

Cross 1-B33-0017 16" x 12" sweepolet 50% 100%

to 12" pipe 1 B33 0100 12" pipe to-nozzle 507. 100%

l B33 0195 12" pipe to-nozzle 50% 100%

l B33-0111 12" pipe to nozzle 50% 100%

l-833-0116 12" pipe to nozzle 50% 1007.

1 B33 0118 16" x 12" sweepolet 50% 1007.

to 12" pipe 1 B33 0121 12" pipe-to nozzle 50% 1007.

Licensee's ProDosed Alternative Examination: None. The licensee states that the Code-required volumetric examination  ;

will be performed on the subject welds te tne maximum extent possible. The Code required surface examinations of the subject welds will be performed.

Licensee's Basis for Recuestina Relief: The Licensee states that ultrasonic examinations conducted on welds in the recirculation loops which were inlaid and overlaid with  !

corrosion resistant cladding required specialized techniques.

Typical techniques identified in Appendix !!! of.Section XI-proved to be ineffective.

To overcome the metallurgical properties impeding conventional shear wave ultrasonic transmission, refracted longitudinal wave l examinations were employed. The acoustic properties of  !

refracted longitudinal wave propagation limit the technique to 1/2 vee path. The Code-required volume necessitates a full vee path through the weld and required volume.

20

.o .

.  ?

Therefore, when access to a butt weld was limited to one side i only due to component geometry (e.g., pipe-to valve), the l perpendicular examination is considered to be only 50%

! complete.  ;

Evaluation: The volumetric examination of the subject Class 1 .

piping welds is impractical to perform to the extent required l by the Code due to the component geometry. .The limited Section XI volumetric examination, along with the Code required.

surface examination, provides reasonable assurance of the ,

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

l

Conclusions:

Based on the above evaluation, it is concluded that the volumetric examination of the subject welds is -

impractical to perform to the extent required by the Code. .

Therefore, it is recommended that relief be granted as  :

requested.

3.1.4.4 Recuest for Relief IR-007. Examination Cateaory B K-1.

Item B10.10. Inteorally Welded Sucoort Attachments for Class 1 Pioina Code Reauirement: Section XI, Table IWB-2500-1, Examination l

Category B K-1, item B10.10 requires a 100% surface or volumetric examination, as applicable, of the integrally welded attachments for Class 1 piping as defined by  :

Figures IWB-2500 13. -14, and -15. ,

i licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required surface of the following penetration-to-process pipe attachment welds:

21

Component 1.0, System l-E12 P411-WA  ;

Residual Heat "

Removal (RHR) 1-E12 P421 WA l-E12-PRB2035 WA l E12 PRB2036-WA

" " " j

, 1 E12 PRB2044-WA l-E21-Pll2 WA low Pressure Core Spray (LPCS) 1-E21-PRB3046-WA l-E22-P410 WA High Pressure Core Spray (HPCS) 1 E22-PRB3052-WA

. 1-E51-P123 WA Reactor Core Isolation Cooling (RCIC)  : '

• l-E51-P422 WA

• l-N27-P121-WA Feedwater (FW)

• l-N27 P414 WA

• l-G33-P131-WA Reactor Water Cleanup (RWCU) i

• l-N22 P423 WA Main Steam (MS)

"l 821-P122-WA j

• l-B21-P124 WA

• l B21 P415 WA

• l-821 P416 WA )

• Received augmented ultrasonic examination as part of high energy break exclusion region. 1 I

Licensee's Procosed Alternative Examination: None. The i Licensee states that the Code-required surface examination will be performed to the mhximum extent possible.

'l Licensee's' Basis for Reauestino Relief: Relief is requested from the required 100% surface examination of the q penetration-to-process pipe attachment welds due to i inaccessibility of the weld face within the ID of the.

l penetration. Only 50% of the required surface is accessible. j l

Since the construction, operating conditions, and environmental  ;

conditions of the non-examined portions of the welds are )

L identical to the examined portions, it is reasonable to apply satisfactory results from examined to the non-examined portions.

L 1

! Evaluation: The surface examination of the l l penetration-to-process pipe attachment welds is impractical to perform to the extent required by the Code due to inaccessibility of the weld face within the ID of the 1

22 -

i penetration. A significant percentage (50%) of the

. Code-required surface will be examined. The limited Section XI j surface exa.nination will provide ~ reasonable assurance of the continued inservice structural integrity of the welds.  !

i fonclusions: Based on the above evaluation, it is concluded l that the surface examination of the penetration to process pipe j attachment welds-is impractical to perform to the extent ,

required by the Code. Therefore, it is recommended that relief be granted as requested.

3.1.5 Pumo Pressure Boundary 3.1.5.1 Reauest for Relief IR-002. Examination Cateaory B-G-1.

Item B6.180. Reactor Recirculation Pumo Studs Code Reauirement: Section XI, Table IWB 2500-1, Examination Category B-G-1, item B6.180 requires a.100% volumetric examination of the Class 1 pump bolts and studs as' defined by Figure IWB 2500-12. The bolting may be examined in place under tension, when the connection is disassembled, or when the l bolting is removed, l i

licensee's Code Relief Reauest: Relief is reqitested from I examining 100% of the Code-required vclume of studs 1 through 16 of reactor recirculation pump B.

l Licensee's Proposed Alternative Examination:- None. The Licensee states that the Code-required volume of the subject studs will be examined to the maximum extent possible.

1 Licensee's Basis for Reauestina Relief: The Licensee states )

that volumetric examination of the reactor recirculation. pump studs is limited by the elongation measurement hole. This hole

, (approximately 0.5 inch diameter) extends through 80% of stud length and interferes with UT examination of the stud volume 23

below the hole. The volume affected is approximately 22Y. of  ;

. the total required volume. The Licensee also states that the ,

5 major area of interest, the thread root area, will receive 100Y.

volumetric examination. j Evaluation: The volumetric examination of the reactor '!

recirculation pump studs is impractical to perform to the  !

extent required by the Code because the elongation measurement hole, which extends through approximately 60Y. of the stud, j limits the examination. As shown in the drawing submitted j January 6, 1989, a significant percentage (approximately 78Y.) 1 of the Code-required volume can and will be examined using a-75-degree angle transducer from the center drilled hole. The limited Section XI volumetric examination of the studs will provide reasonable assurance of the continued inservice ]

structural integrity. I l

Conclusions:

Based on the above evaluation, it is concluded '

that the volumetric examination of the subject studs is )

impractical to perform to the extent required by the Code.  !

Therefore, it is recommended-that relief be granted as ,

requested. I 3.1.6 Valve Pressure Boundarv ]

3.1.6.1 Reauest for Relief IR-008. Examination Cateacry B-M-1.

Item B12.40. Class 1 Valve Body Welds i

l Code Reauirement: Section XI, Table IWB-2500-1, Examination Category B-M-1, Item B12.40 requires a 1007. volumetric examination of the Class 1 valve body welds nominal pipe size  !

4 inches and greater as defined by Figure IWB 2500-17.  ;

Licensee's Code Relief Reouest: Relief is requested from examining 100Y. of the Code-required volume of the following

)

valve body welds: l 8

l 24 i

. Estimated

. Seam Examination-Coveraae Weld Weld Perp. Parallel Number System Descriotion Scan Sean 1-E12-F019 RHR 6" forged check 92% 100%

valve body weld 1-E12-F042A RHR 12" forged gate 90% 100%

valve body weld 1-E21.F005 LPCS 12" forged gate 90% 100%

valve body weld 1-E22-F036 HPCS 12" forged gate 90% 100%

valve body weld 1-E51 F064 RCIC 10" forged gate 93% 100%

valve body weld 1-E51-F013 RCIC 6" forged gate 94% 100%

valve body weld 1-G33 F004 RWCU 6" forged gate 89% 100%

valve body weld 1-G33-F100 RWCU 4" forged gate 92% 100%-

valve body weld Licensee's Procosed Alternative Examination: None. The Licensee states that the Code-required volumetric examination will be performed to the maximum extent possible.

1 Licensee's Basis for Reauestina Relief: The Licensee states that relief is requested from the required 100% volumetric examinations because component geometry and code plate obstructions limit examination of the required volume.

Approximately 90% of the required weld volume is accessible for the perpendicular scan.

Since the construction, operating conditions, and environmental conditions of the non examined portions of the welds are identical to the examined portions, it is reasonable to apply satisfactory results of the examined portions to the non-examined portions.

Evaluation: The perpendicular scan of the volumetric  !

examination of the subject valve body welds is impractical to perform to the extent required by the Code because of the component geometry and code plate obstructions. A significant percentage (approximately 90%) of the Code-required volume will

-l 25

__ l

receive the perpendicular scan of the volumetric examination.

- The limited Section XI volumetric examination will provide reasonable assurance of the continued inservice structural int egri ty.

.Cfnclusions: Based on the above evaluation, it is concluded that the perpendicular scan of the volumetric examination of

.these welds is impractical to perform to the extent required by i

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

,, 3.1.7 Egrafull (No relief requests) t 3.2 Class 2 Components 3.2.1 Pressure Vessels 3.2.1.1 Recuest for Relief IR-010. Examination Cateaory C A.

Item C1.?0. Pressure Retainino Welds in Class 2 Pretsure Vessels l

Code Recuirement: Section XI, Table IWC-2500-1, Examination Category C A, Item Cl.20 requires a 100% volumetric examination of the circumferential head welds in Class 2 pressure vessels as defined by Figure IWC-2500 1.

l Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume of pressure i retaining shell cylinder-to-head weld number 1-E12-B001A-003 in RHR heat exchanger number B001A. [

l Licensee's Proposed Alternative Examination: None. The

.i Licensee states that the Code-required volumetric examination

! will be performed to the maximum extent possible.

Licensee's Basis for Reauestina Relief: The Licensee states .,

r that relief is requested from the required 100% volumetric l'

i 26' C >

. . j examination because of seismic lug interferences. .  ;

Approximately 43% of the required weld volume is accessible for l the perpendicular scan.

Since the construction, operating conditions, and environmental conditions of the non examined portions of the welds are identical to the examined portions, it is reasonable to apply satisfactory results of the examined portions to the non examined portions.

Evaluation: As shown in drawing ISI-E12-025 of the ISI Program Plan, the perpendicular scan of the volumetric examination of the RHR heat exchanger shell cylinder-to-head weld is impractical to perform to the extent required by the Code because of the seismic lug interferences. The limited Section XI volumetric examination will provide reasonable assurance of the continued inservice structural integrity. i i

Conclusions:

Based on the above evaluation, it is concluded that the perpendicular scan of the volumetric examination of the subject weld is impractical to perform to the. extent required by the Code, Therefore, it is recommended that relief be granted as requested.

3.2.1.2 Reauest for Relief IR-011. Examination Cateoory C-B. s item C2.21. Pressure Retainino Nozzle Welds in Class 2 Pressure Vessels Code Reouirement: Section XI, Table IWC-25001, Examination Category C-B, item C2.21 requires-both 100% volumetric end surface examinations of nozzle-to-shell (or head) welds for nozzles without reinforcing plate in vessels greater than 1/2 inch nominal thickness. These examinations are to be as defined by Figure IWC-2500-4(a) or (b).

27

s * ,

Licensee's Code Relief Recuest: Relief is requested from examining 100% of the Code required volume of inlet nozzle old 1 E12-B001A 004 in the RHR heat exchanger head.

licensee's ProDosed Alternative Examination: None. The Code required volumetric examination will be performed to the maximum extent possible. The Code-required surface examination will be performed.  !

Licensea's Basis for Reauestina Relief: - The Licensee states that relief is requested from the required 100% volumetric examination of the subject weld because instrumentation line ,

obstructions limit examination to 95% of the'reouired weld volume.

Since the construction, operating conditions, and environmental conditions of the non-examined portion of the weld are identical to the examined portion (95%), it is reasonable to apply the satisfactory results to the non-examined portion. -

Evaluation: -The volumetric examination of the RHR heat exchanger head inlet nozzle weld is impractical to perform to -

the extent required by the Code because of instrument-line ,

obstructions. A significant percentage of the Code-required volume can and will be examined. The limited Section XI l volumetric examination and the Section XI 100% surface examination will provide reasonable assurance of the continued inservice structural integrity.

l 1

j

Conclusions:

Based on the above evaluation, it is concluded l that the volumetric examination of the subject weld is impractical to perform to the extent required by the Code. ,

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

! t requested.

(

28 l

l

i- .

3.2.2 Pinina o .

. l 3.2.2.1 Reouest for Relief IR 012. Examination Cateoorv C-C.

Items C3.10 and C3.20. Class 2 System Intearally Welded -

Attachments ,

i e l

Code Recuirement: Section XI, Table IWC-25001, Examination i Category C-C,-Items C3,10 and C3.20 require a 100% surface examinat' ion of the integrally welded attachments of Class 2 l-L pressure vessels and piping as defined by figure IWC 2500 5.

L l

Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required s.urface of the following' integrally welded attachments for Class 2 pressure vessels and piping:

Estimated item Weld Nature of Examination N_um_bJtr Number System Obstruction Coveraoe C3.10 1-E12-B001A SL1 RHR Geometry 95%

C3.10 1-E12-8001A-SL2 RHR Geometry 95%

C3.10 1-E12-B001A-SL3 RHR Geometry 95%

C3.10 1-E12-B001A-SL4 RHR Geometry 95%

C3.20 1-E22-H087-WA HPCS Hanger / code band 85%

1 and drain line

! interferences C3.20 1-E12-H173 WA RHR Hanger clamp 90%

C3.20 1 E12-H289 WA RHR Geometry 60%

C3.20 1 E12-H290 WA RHR Geometry 60% .

C3.20 1-E12-H359-WA RHR Geometry 50%

C3.20 1-E12-H360 WA RHR Geometry 50% -

C3.20 1-E12 H368 WA RHR Geometry 60% i C3.20 1 E12-H369 WA RHR Geometry 60%

Relief is also requested from performing the Code-required surfge examination of the following integrally welded l

attachments for Class 2 piping (Item C3.20):

Weld Number System Natitre of Obstruction 1-Nll-H221-WA MS ___ Seismic restraint blocks access 1-Nil H222 WA MS Seismic restraint blocks access 1-Nil-H223 WA MS Seismic restraint blocks access 1-Nil-H224-WA MS Seismic restraint blocks access 1 N27 H031-WA FW Seismic restraint blocks access 1-N27-H032 WA FW Seismic restraint blocks access 29

t

• Licensee's Proposed Alternative Examination: None. The Code required surface examination of the subject welds will be performed to the maximum extent possible.

Licensee's Basis for Recuestino Relief: The Licensee states that relief is requested from the required 100% surface examinations because of partial or complete inaccessibility of the examination area.

[ygluat it,n: The surface examination of the subject welds is impractical to perform to the extent required by the Code because of partial or complete inaccessibility due to geometry, hanger, code band, and drain line interferences, hanger clamp interferences, or seismic restraints blocking access. Complete examinations meeting the requirements of Section XI of the ASME Code are performed on. welds of similar configurations which utilize the same weld techniques, procedures, and materials.

Since the partially or unexamined welds will see the same operating and environmental conditions as the examined welds, the limited Section XI surface examint. tion will provide reasonable assurance of the continued inservice structural integrity.

Conclusions:

Based on the above evaluation, it is concluded that the surface examination of the subject welcis is impractical to perform to the extent required by the Code.

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

3.2.2.2 Reauest for Relief IR 015. Examination Cateaory C-C.

Item C3.20. Class 2 Penetration-to Process Pipe Attachment _

l Welds Code Reauirement: Section XI, Table IWC-2500-1, Examination Category C-C, Item C3.20 requires a 100% surface examination of i

30

l c

s the integrally welded attachments of Class 2 piping as defined j by Figure IKC-2500 5. , j Licensee's Code Relief Reouest: Relief is requested from examining 100% of the Code-required surface of the following penetration to process pipe attachment welds:

Component I.D. System 1-G33 P132-WA RWCU 1-E12-P105 WA RHR l-E12 P407-WA RHR

• l-E21-Pil3 WA LPCI l-E21-P412 WA LPCI .

Licensee's Procosed Alternative Examination: None. The Code-required surface examination will be completed to the ,

maximum extent possible. P Licensee's Basis for Reapestino Relief: Relief is requested  ;

from the required 100% surface examination of the l penetration-to process pipe attachment welds due to l

inaccessibility of the weld face within the ID of the l

penetration. Only 50% of the required surface is accessible.

Since the construction, operating conditions, and environmental conditions of the non-examined portion of the welds are l identical to the examined portions, it is reasonable to apply  ;

satisfactory results from examined to the non-examined ,

portions.

i Evaluation: The surface examination of the r penetration-to-process pipe attachment welds is impractical w perform to the extent required by the Code due to inaccessibility of the weld within the ID of the penetration.

A significant percentage (50%) of the Code-required surface -

will be examined. The limited Section XI surface examination will provide reasonable assurance of the continued inservice structural integrity.

31-

s s

Conclusions:

Based on the above evaluation, it is concluded that the surface examination of the penetration to-process pipe attachment welds is impractical to perform to the extent required by the Code. Therefore, it is recommended that rel'.ef be granted as requested.

3.2.3 Pumps 3.2.3.1 4eauest for Relief IR-013. Examination Cateaory C-G.

Item C6.10. Class 2 Pumo Casina Weldi Code Reauirement: Section XI, Table IWC 25001, Examination-Category C G, Item C6.10 requires a 100% surface examination cf the Class 2 pump casing welds as defined by Figure IWC 2500 8.

Licensee's Code Relief Reauest: Relief is requested from performing the Code required surface examination of the pump barrel welds on the following pumps:

Pumo I.D. System i 1-E22-C001 HPCS 1-E21 C001 LPCS 1-E12-C002A RHR l-E12-C002C RHR ,

i licensee's Proposed Alternative Examinatinn: The Licensee states that, if any of the subject pumps are disassembled for repair or maintenance, with the pump barrei removed, accessible welds will be inspected at that time.

Licensee's Basis for Reauestina Relief: The Licensee states that relief is requested from the required surfice examinations because the pump barrel is located below floor level making the welds inaccessible.

Evaluation: As shown in drawings ISI-E22-005, ISI-E21-004, ISI-E12 026, and ISI-E12-027 of the ISI Program Plan, the pump barrel of each of the four subject pumps is located below floor 32

O o level. The disassembly of the pumps'for the sole purpose of inspection is a major effort and could result in damage to the pumps. Therefore, the Code-required surface examination of the subject welds is impractical to perform. The Licensee's proposed alternative to examine these welds if any of the subject pumps are disassembled for repair or maintenance is acceptable.

Conclusions:

Based on the above evaluation, it is concluded that the Code requirement is impractical for the subject welds. Therefore, it is recommended that relief be granted provided that: (a) the surface examination of.the pump casing welds is performed whenever the welds are made accessible due to disassembly for maintenance, and (b) 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.

3.2.4 Valves 3.2.4.1 Reauest for Relief IR-014. Examination Cateoory C-G. l Item C6.20. Class 2 Valve Body Weld Code Reauirement: Section XI, Table IWC-25001, Examination Category C-G, Item C6.20 requires a 100% surface examination of Class 2 valve body welds as defined by Figure IWC 2500-8.

Licensee's Code Relief Recuest: Relief is requested from examining 100% of the Code-required surface of weld 1-E22 F003-SEAM on the 6-inch high pressure core spray check valve.

Licensee's ProDosed Alternative Examination: None. The Code required surface examination will be completed to the maximum extent possible.

Licensee's Basis for Reouestino Relief: The Licensee states that relief is requested from the required 100% surface I

. 33

6 l

examination because a code plate partially obstructs about 5% [

.+

~

of the examination area. l I

s Since the construction, operating conditions, and environmental conditions of the non-examined portion of the weld are identical to the examined portion, it is reasonable to apply satisfactory results from the examined portion to the non-examined portion.

Evaluation: The surface examination of the subject valve body.  !

weld is impractical to perform to the extent required by the Code because of partial obstruction of 5% of the examination l area due to a code plate. A significant percentage (95%) of  :

the Code required surface examination can and will be ,

performed. The limited Section XI surf. ace examination of this  :

valve body weld will provide reasonable assurance of the continued inservice structural integrity.

Conclusions:

Based on the above evaluation, it is concluded that the surface examination of the subject weld is impractical

• to perform to the extent required by the Code. Therefore, it is recommended that relief be granted as requested.

3.2.5 General (No relief requests) l 3.3 Class 3 Components (No relief requests)  !

3.4 Pressure Tests (No relief requests) 3.5 General (No relief requests) l 34 ,

4 -o

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 these cases, the Licensee has demonstrated that 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 Perry Nuclear Power Plant, Unit 1, facility. Requiring compliance with all the exact ,

Section XI required inspections would require redesign of a significant ,

number of plant systems, sufficient replacement components to be obtained, installation of 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 i determined to be impractical. Pursuant to 10 CFR 50.55a(g)(6), relief is 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.

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

Based on the review of the Perry Nuclear Power Plant, Unit 1 First 104 ear Interval Inservice Inspection Program Plan, Revision 0, the Licensee's '

L responses to the NRC's request for additional information, and the i recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Perry l

35

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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.

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

4. Perry Nuclear Power Plant, Unit 1, First 10-Year Interval Inservice Inspection Program Plan, Revision 0, submitted March 31, 1987.

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

6. Letter, dated February 9, 1988,'1. G. Colburn (NRC) to A. Kaplin (Cleveland Electric illuminating Company (CEI)), request for additional information on the ISI Program Plan.

7. Letter, dated April 12, 1988, A. Kaplin (CEI) to NRC, partial response to the NRC's request for additional information.

8. Letter, dated November 18, 1988, A. Kaplin (CEI) to NRC, response to the NRC's request for additional information. i

9. Letter, dated January 6, 1989, W Elgin (CEI) to T. Colburn (NRC),

submitting a drawing, which shows inspectable volume of a recirculation pump stud, for Relief Request IR-002 and color-coded P&l diagrams for Perry plant systems.

10. NRC Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 6, May 1988.

11. NUREG 0619, *BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking," November 1980.

l 37 q

i n . 09 338 U.S. NvC4 tam alGvk A roa v CoM*i5540N ag -

es

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$ cees # BISL10 GRAPHIC DATA SHEET  ;

• aa n vreerrnen ,

z. tit.s aso se.t. EGG MS 8378 i Technical Evaluation Report on the First 10 Year Interval Inservice Inspection Program Plan: a oats aie:aT

• ses-n Cleveland Electric Illuminating Company, **'- j E** l December 1989 Perry Nuclear Power Plant, Unit-1, Docket Number 50 440 a 'ia oR oa*Ni suveia FIN D6022 (Proj. 5)

6. avtaca m Tveto,meroRt Technical B.W. Brown, J.D. Mudlin N 00Cov5"Da~~*~

s. e gegaggNaAttoN - N AML ANo AooR L$$ W 48C.aw.0=en. ONese y Am y,1 wepy Aspasm Cynamp, pf mmutt me,Wppew, pqgem EG&G Idaho, Inc.

P. O. Box 1625 Idaho Falls, ID 83415-2209 egoggcaNaarioN - Naus *No aconass m .c. .. s, . . u-, - . eo o~.., ua = ,- c Materials and Chemical Engineering Branch

. Office of Nuclear Reactor Regulation 1 l U.S. Nuclear Regulatory Commission l Washington, D.C. 20555

10. SUPPLEMENTARY NOTES ,

11. AS$1RACT tJap ewee w mes This report presents the results of the evaluation of the Perry Nuclear Power Plant,

-Unit 1, First 10-Year Interval inservice Inspection (ISI) Program Plan, Revision 0, submitted March 31, 1987, 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 Perry 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) 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) review before granting an Operating  ;

License. The requests for relief are evaluated in Section 3 of this report. i 4

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