ML20203J913

Discusses Preservice Insp & Differences Between Scope of Preservice Exams for Unit 2 & Unit 1.Unit 2 Program Notes & Relief Requests W/Cross Ref Lists for Comparison of Unit 2 Notes & Unit 1 Relief Request Encl

ML20203J913
Person / Time
Site:	Byron
Issue date:	07/23/1986
From:	Ainger K COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8608060071
Download: ML20203J913 (87)

Text

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CeNNnonwealth Esiloon

- One First Nahonal Plazo, Chicago, Enois

.m' j f 33dEss Reply to: Poet Omco Box 767 sd Chece00. lilinois 60800 0767 4

r i  !

i July 23, 1986 i

Mr. Harold R. Denton, Director 1 Office of Nuclear Reactor Regulation

! U.S. Nuclear Regulatory Commission 4 Washington, DC 20555 i

Subject:

Byron Station Unit 2 i preservice Inspection [

i NRC Docket No. 50-455 r j

Dear Mr. Denton:

This letter provides information regarding the Byron Unit 2 preservice Inspection. The differences between the scope of preservice examinations for Unit 2 and the Byron Unit 1 inspection scope are identified i herein. In addition, the Unit 2 program plan notes and relief requests are enclosed.

]

The Byron Unit 2 preservice inspection requirements are identical

( to those for Byron Unit 1. The inspections are being performed to the i

requirements of ASME Code Section XI, 1977 Edition with addenda through the i Summer, 1978 Addenda. In addition to Code-required inspections, augmented j inspections are being performed on high energy lines and reactor coolant l pump flywheels.

1 i The sample of Unit 2 components and parts of the pressure retaining l boundaries that will receive presorvice examinations is essentially identical j to the sample examined during the Byron Unit 1 preservice Inspection.  ;

i volumetric, surface and visual (VT-1) examinations were performed by Ebasco Services, Inc. on ASME Code Class 1 and 2 components per Code or augmented requirements. Automated ultrasonic examinations of the Units 1 and 2 reactor

] pressure vessels were performed by Rockwell International to the requirements j of Regulatory Guide 1.150. Unit 2 components exempted from preservice exami-l nations per Uection XI paragraphs IWB-1220 and IWC-1220 correspond directly ,

j to the Unit 1 exempted components. '

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l 8600060071 860723 \

PDR ADOCK 050004D4 G PDR i

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1 Mr. H. R. Denton July 23, 1986 4

Ebasco Services, Inc. has recently completed ultrasonic examinations of the cast stainless steel elbow and component welds in the Byron Unit 2 reactor coolant system. Ultrasonic scans were performed on the cast side (s) of these welds using 1.0 MHZ refracted longitudinal wave, focused transducers mounted on contoured, removable wedges. By performing tests on calibration standards and weld samples, Commonwealth Edison has demonstrated that these examinations are capable of detecting large flaws in the cast material.

Ultrasonic scans on the non-cast sides of Unit 2 reactor coolant system welds were performed using shear wave transducers. Only the non-cast sides of the Unit I reactor coolant system welds were examined during the Unit 1 Preservice Inspection.

Preservice eddy current examinations have been performed on Unit 2 steam generator tubing. Similar to the Unit 1 inspection, 100% of the tubes in the four steam generators received examination. However, the Unit 2 eddy current examinations were performed by Conam Inspection using MIZ-18 inspection equipment. ASME Code Case N-401 was approved to allow the use of MIZ-18. The Unit I steam generator tubing was examined by Ebasco with MIZ-12 equipment.

Visual VT-2, VT-3 and VT-4 examinations were performed on Unit 2 ASME Class 1, 2 and 3 components per Code or augmented requirements by Commonwealth Edison personnel or contractors other than Ebasco. The visual examination scope for Byron Unit 2 is identical to the Unit I scope.

The preservice inspection program plan for Byron Unit 2 is being finalized. This plan includes tables listing components included in the preservice inspection. The entire program plan is not being provided for NRC review since it is essentially identical to the Unit 1 program plan.

Only the enclosed program notes and relief requests are being provided.

The Unit 2 program notes' are enclosed an Attachment I. These notes identify interpretations of examination requirements made by Commonwealth Edison. They do not request relief from preservice inspection requirements.

The Unit 2 relief requests are enclosed as Attachment II. These requests identify inspection requirements that were determined to be impractical and could not be met. They provide the bases and justification for not performing the required examinations and describe alternate examina-tions which were completed.

Included in Attachments I and II are cross reference lists for comparison of the Byron Unit 2 program notes and relief requests to those for Unit 1. Note that relief requests NR-5, NR-6, NR-16 and NR-17 are unique to Unit 2.

Mr. H. R. Denton July 23, 1986 Relief requests NR-1, NR-2, NR-3, and NR-13 are not included. These requests, which address the cast stainless steel examinations, are currently being prepared. They should be completed by September 1, 1986.

Please direct any questions you or your staff may have regarding this matter to this office.

One signed original and fifteen copies of this transmittal and the attachments are provided for NRC review.

Very truly yours, K. A. Ainger Nuclear Licensing Administrator la Attachments cc: Byron Resident Inspector L. N. Olshan - NRR 1882K

ATTACHMENT I Byron unit 2 Preservice Inspection Program Notes

Page 1 of 1 ATTACHMENT I Byron Units 1 and 2 Preservice Inspection Program Note Cross Reference List Byron Unit 2 Byron Unit 1 Note # Note Description Note #

1 Only 1 vessel or 1 pump of a group of 1 multiple vessels or pumps shall be examined.

2 Longitudinal welds requiring examination 2 were examined for a distance of 2.5t from intersecting circumferential welds.

3 Credit was taken for construction shop and 4 field examinations in lieu of performing Section XI visual (VT-3 and VT-4) examinations.

4 System pressure tests were not executed 7 after Section III hydrostatic tests and prior to initial plant startup.

5 Gamma plugs or branch connection 3, 6, 10 prevented complete axial ultrasonic scans of Class 1 welds.

6 Gamma plug or sockolet prevented 12 complete axial ultrasonic scans of Class 2 welds.

8042b

Note 1 Rev. O NOTE 1 SYSTEM: Vessels and Pumps NUMBER OF ITEMS: 17 ASME CODE CLASS: 2 PERTINENT CODE REQUIRBENTS:

a. Examination Category C-A requires a volumetric examination of pressure retaining welds in pressure vessels. Note (3) under Table IWC-2500-1 Examination Category C-A states, "In the case of multiple vessels of similar design, size and service (such as steam generators, heat exchangers) the required examinations may be limited to one vessel or distributed among the vessels."

b. ExaminationCategoryC-Grequiresasurfaceexaminationohpressure retaining welds in pumps and valves. Note (1) under Table IWC-2500-1 Examination Category C-G states, "In case of multiple pumps and valves of similar design, size and function and service in a system, the examination of only one pump and one valve among each group of multiple pumps and valves is required."

EXTENT OF EXAMINATION: Only one vessel or one pump in a group of multiple vessels or pumps shall be examined.

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(0950M/0095M)

Note 2 Rev. O l

NOTE 2 SYSTEM: All NUMBER OF ITEMS: All Longitudinal Welds ASME CODE CLASS: 2 PERTINENT CODE REQUIREMENTS: Examination Category C-F, Item C5.12 requires a surface examination and Item C5.22 requires volumetric and surface examinations of longitudinal pipe welds for a distance of 2.5t from the intersecting circumferential weld where t equals the nominal wall thickness of the pipe.

EXTENT OF EXAMINATION: All required longitudinal welds will be examined for a distance of 2.5t from the intersecting circumferential weld.

(0950M/0095M)

Note 3 Rev. O NOTE 3 SYSTEM: All NIEEER OF ITEMS: All A M CODE CLASS: 1,2, and 3 P M INENT CODE REQUIREMENTS: Examination Categories B-K-2, C-E, D-A, D-B, and D-C all require visual examinations (VT-3 and VT-4) of component supports. Category B-K-2 requires examination of all Class 1 component supports. C-E requires examination of Class 2 components supports on piping greater than 4.00 inches. D-A, D-B, D-C all require examination of Class 3 component supports on piping greater than 4.00 inches.

DEERIPTION OF EXAMINATION: For all required visual examinations (VT-3 and VT-4) though not limited to visual examinations, shop and field examinations will be used to satisfy IWB-2200(b) and IWCJ2200(b) for Class 1 and 2 respectively. Although subsection IWD does not address shop and field examinations, it is the intent of Byron Station to treat Class 3 components in a manner similar to Class 1 and 2 components. An inspection program based upon shop examinations, construction QC inspections, pre-operational testing, and augmented inspections will be used in lieu of a preservice examination program based solely on section XI.

There are several programs which apply to component support examinations conducted at Byron Station during the Pre-Service phase. These programs are executed by various ca==nnwealth Edison Company (CECO) departments and are overseen by respective departments and inspectors in the NRC. For this reason, this note will not provide a detailed discussion of all programs covering component support examinations, but rather, give an overview of the programs involved.

CE00 Project Construction Department (PCD) is responsible for the proper installation of component supports. To accomplish this, they administer a five part inspection program. This program meetsSection III, Subsection i Ni requirements and incorporates augmented requirements addressed during inspections by the NRC Region III inspector.

The five part PCD program requires examination at the time of support installation, and four re-examinations to be performed at various stages of construction. This program includes but is not limited to, verification of proper support type, location, weld condition, attaching hardware, etc. For operable supports such as spring cans and snubbers, the proper cold se: tings are verified. Further, all snubbers are stroked at the time of installation, and selected snubbers are stroked again before core load. The final phases of the five part program verify that all design changes have been incorporated and that components are in good condition and have not been damaged as a result of construction activities.

i (0950M/0095M)

1 i

Note 3 Rev. O In addition to the requirements of the PCD examinations, there are augmented requirements. These requirements are the result of licensing activities between NRR and CECO Project Engineering Department (PED).

These requirements are described in detail in the Byron FSAR and in Byron's "Preservice Testing Program Plan for Snubbers." Among the testing / inspection activities described in the FSAR is Thermal Expansion Testing performed during Integrated Hot Functionals. These activities were performed through the execution of the EM 2.028.60, Pre-Operational Test, Revision 2. This test has been revised as a result of inspection activities performed at the site by I & E Region II inspectors under Region III authority. The scope of the test is described by FSAR Q110.63

[ and Q110.37. The pre-operational test verified that (1) there was no l evidence of damage during plant heatup and cooldown to installed component IL-J ~

supports and snubbers, (2) there was no evidence of inoperability of operable type supports, that there was not interference from thermal expansion and that supports and snubbers were installed properly. In addition, PCD monitored movement of the RCS piping, Steam Generators, and Reactor Coolant Pumps during Integrated Hot Functional Testing. The "Preservice Inspection Testing Program Plan for Snubbers" describes the interrelationship between visual inspections and pre-operational testing as related to snubbers.

In short, the five part PCD examinations, which have been developed through on-site NRC inspections, are used to satisfy the visual examination requirements of ASME Section XI for pre-service inspections.

In addition to this, augmented tests and examinations are performed to assure proper design, installation, and operability of component and piping supports.

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Note 4 Rev. O NOTE 4 SWTEM: All Class 1, 2, and 3 NWEBER OF ITEMS: All Class 1, 2, and 3 ASME CODE CLASS: 1, 2, and 3 PEETINENT CODE REQUIREMENTS: Table IWB-2500-1, Examination Category B-P, Table IWC-2500-1, Examination Category C-H, and Table IWD-2500-1 all require system pressure tests per IWA-5000, " System Pressure Tests".

Though Subarticles IWB-2200, IWC-2200, and IWD-2100 require completion of all examinations required by their respective Articles, once prior to initial plant startup, paragraph IWA-5215 states, "A preservice system hydrostatic test is not required by this Section".

DESCRIPTION OF EXAMINATION: All ASME Class 1, 2, -and 3 pressure retaining casponents will be hydrostatically tested per the requirements of ASME Section III prior to fuel load. Per IWA-5215, system pressure tests will not be re-executed prior to initial plant startup, except for ASME Class 1 components which will receive a Section XI leakage test during start-up and befuro initial criticality. ASME Class 2 and 3 inservice leakage tests will begin during startup and continue for the first inspection period until all tests are completed.

(0950M/0095M)

I l

l Note 5 Rev. O NOTE 5 Limited Class 1 Examinations SYSTEM: Safety Injection NUISER OF ITEMS: 4 ASIS CODE CLASS: 1 PERTINENT CODE REQUIREMENTS: Examination Category B-J, Item B9.ll requires a surface and volumetric examination of the volume described in figure IWB-2500-8. The volumetric examination performed during the inspection interval shall cover all the area of 25% of the circumferential joints. The examination includes at least a pipe diameter length, but not more than 12 inches of each longitudinal weld intersecting the circumferential welds required to be examined. .

IWB-2200 states, " Examinations required by this article shall be completed prior to initial plant startup. In addition, these preservice examinations shall be extended to include essentially 100% of the pressure retaining welds in Class I components, except in those components exempted from examination by IWB-1220."

LIMITATION OF EXAMINATION: The circumferential welds listed below were examined 100% by volumetric techniques. 100% of the required weld volume was examined by a complete circumferential scan. However, a small percentage of each weld (in no case greater than 8.29%) was not examinable by an axial half-v-path or full-v-path scan.

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In all cases below, a surface examination (liquid penetrant) and a visual examination (leak test) will be performed.

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Line Weld Blocked By  % Missed Attachment 2SIO9BA-10" J18 Gamma Plug 6.29* 1 2SIO9BA-10" J27 Gama Plug 6.29* 2 2SIO9BD-10" J1 Branch Connection 8.29* 3 2SIO9BD-10" J25 Gama Plug 6.66* 4 I Note: *In all cases above, the percentage missed is a conservative l estimate as shown on Attachment 5 to this note.

The procedure for axially scanning these welds requires that the transducer be twisted back and forth while scanning. As a result, more volume is actually examined than that reflected by the above numbers.

(0950M/0095M)

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ATTACHMENT 5 NOTE 5

Note 6 Rev. O NOTE 6 Limited Class 2 Examinations SYSTEM: Safety Injection -

NUMBER OF ITEMS: 2 -

ASME CODE CLASS: 2 PERTINENT CODE REQUIREMENTS: Examination Category C-F, Item C5.21 requires both surface and volumetric examinations of the regions described in Figure IWC-2520-7 for circumferential welds in piping over 1/2 in, nominal wall thickness. Subarticle IWC-2200 requires completion of all examinations required by its article, once, prior to initial plant startup.

DESCRIPTION OF EXAMINATION: -The circumferential welds listed below were examined 100% by volumotric Eechniques. 100% of the required weld volume was examined by a complete circumferential scan. However, a small percentage of each weld (in no case greater than 7.49%) was not examinable by an axial half-v-path or full-v-path scan.

In all cases below, a surface examination (liquid penetrant) and a visual examination (leak test) will be performed.

Line Weld Blocked By  % Missed Attachment 2SIO4B-12" C1 Sockolet 7.49* 1 2SIO6BA-24"- Cl Gamma Plug 2.98* 2 Note: *In all cases above, the percentage missed is a conservative estimate as shown on Attachment 3 to this note.

l l The procedure for axially scanning these welds requires that the transducer be twisted back and forth while scanning. As a result, more volume is actually examined than that reflected by the above numbers.

(0950M/0095M)

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ATTACHMENT 3 NOTE 6

ATTACHMENT II Byron Unit 2 Preservice Inspection Relief Requests i

. ---_ -_ _ __ . _ _ - _- -. - -_ =_ .

Page 1 of 2 ATTACHMENT II Byron Units 1 and 2 Preservice Inspection Program Relief Request Cross Referrence List i Byron Unit 2 Byron Unit 1 i

Relief Request # Relief Request Description Relief Request #

NR-1 Limited ultrasonic examinations were NR-3 performed on cast stainless steel elbow-to-cast pump or valve welds.

NR-2 Limited ultrasonic examinations were NR-8 performed on cast stainless steel elbow-to-reactor vessel nozzle safe-end welds.

NR-3 Limited ultrasonic examinations were NR-4 performed on cast stainless steel elbow-to-steam generator nozzle welds.

NR-4 Surface examinations on Class 2 welds NR-2 were not performed due to locations under saddleplates.

l' NR-5 Surface examinations were not performed N/A

. on Class 2 welds due to locations in floor or wall penetrations.

NR-6 Surface examinations were not performed N/A on Class 2 welds due to locations under l

permanent restraints or in wall penetrations.

NR-7 Credit was taken for manufacturer's NR-7 test data in lieu of performing visual (VT-1) examinations on Class 1 valve internals.

NR-8 Credit was taken for manufacturer's NT-5 test data in lieu of performing visual (VT-1) examinations on internal surfaces of reactor coolant pumps.

Page 2 of 2 Attachment II, Continued Byron Unit 2 Byron Unit 1

Relief Request # Relief Request Description Relief Request #

NR-9 Ultrasonic examinations were not NR-13 performed on pressurizer and steam generator primary nozzle inner radii due to geometric constraints.

NR-lO Limited ultrasonic examinations were NR-9 performed on reactor pressure vessel

, circumferential welds due to

! inaccessibility.

NR-ll Limited ultrasonic examinationL were NR-10 performed on reactor pressure vessel nozzle-to-vessel welds due to inaccessibility.

NR-12 Limited ultrasonic examinations NR-6 were performed on cast stainless steel j elbow, pump or valve-to-pipe welds.

NR-13 Limited ultrasonic and/or surface NR-14 I examinations were performed on steam i generator and residual heat exchanger secondary nozzles due to geometric constraints.

1 j NR-14 Limited surface examinations NR-15

, were performed on pump integrally welded attachments due to inaccessibility.

NR-15 Limited ultrasonic examinations were NR-12 performed on excess letdown heat exchanger shell weld due to inaccessibility.

NR-16 Limited ultrasonic examinations N/A were performed on regenerative heat exchanger welds due to inaccessibility.

NR-17 Limited ultrasonic examinations were N/A performed on pressurizer system Class 1 pipe weld due to inaccessibility.

8042b-(2&3)

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l REI IEF REQUEST NR-1 Limited Ultrasonic Examination of Cast Stainless Steel Elbow-to-Cast Pump or Valve Welds J

! (To Be Provided Later)

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RELIEF REQUEST NR-2 Limited Ultrasonic Examination of Cast Stainless Steel Elbow-to-Reactor Nozzle Safe-End Welds (To Be Provided Later)

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RELIEF REQUEST NR- 3 Limited Ultrasonic Examination of Cast Stainless Steel Elbow-to-Steam Generator Nozzle Welds (To Be Provided Later) l

NR-4 Rev. O  ;

l RELIEF REQUEST NR-4

01. SYSTEM: Main Steam, Safety Injection and Residual Heat Removal

2. NUMBER OF ITEMS: 24 Line Number Weld Number Attachment 2MS07AA-28" C-12, C-13, C-14, C-15 and C-16 1 2MS07AB-28" C-15, C-16, C-17, C-18 and C-19 2 2MS07AC-28" C-15, C-16, C-17, C-18 and C-19 3 2MS07AD-28" C-12, C-13, C-14, C-15 and C-16 4 2SIO6BA-24" C-26 5 2SIO6BB-24" C-26 6 2RH01CA-16" C-lL 5 2RH01CB-16" C-lL 6

3. ASME CODE CLASS: 2

4. ASME CODE SECTION XI REQUIREMENTS: Examination Category C-F, items C5.31 and C5.02, require a surface examination of the volume described in Figure IWC-2500-9. The required volume is 100% of each circumferential weld requiring examination and 2.5t of the longitudinal weld at the intersecting circumferential weld. IWC-2200 states:

L a) All examinations required by this article for those components initially selected for examination in accordance with Inspection Prcgram A or Inspection Program B and not exempt from inservice examinations by IWC-1220 shall be completed prior to initial plant startup.

b) Shop and field examinations may serve in lieu of the on-site preservice examinations, provided:

1) in the case of vessels only, the hydrostatic test required by Section III has been completed;

2) such examinations are conducted under conditions and with equipment and techniques equivalent to those which are expected l to be employed for subsequent inservice examinations;

3) the shop and field examination records are or can be documented and identified in a form consistent with those required in IWA-6000."

l

5. BASIS FOR RELIEF: The above listed welds are inaccessible to surface examinations, due to the location of saddle plates over the pressure retaining welds. The welds are depicted on attachments 1 through 6 as indicated above.

6. ALTERNATE TEST METHOD: A surface examination, (liquid penetrant) and visual examination (leak test) will be performed on the saddle plate fillet welds in lieu of the required surface examinations for the pressure retaining welds listed above.

(0946M/0095M)

NR-4 Rev. 0

7. JUSTIFICATION: Performing a surface and visual examination of the saddle plate fillet welds provides an acceptable level of structural integrity for system operation. Radiographs performed on the branch pipe circumferential welds verify its structural integrity at the time of construction. Therefore, an adequate level of plant operational safety can be assured on these welds.

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(0946M/0095M)

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NR-5 Rev. O RELIEF REQUEST NR-5

1. SYSTEM: Residual Heal Removal

2. NtBIBER OF ITEMS: 5

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3. ASME CODE CLASS: 2

4. ASME CODE SECTION XI REQUIREMENTS: Examination Category C-F, Item C5.ll requires a surface examination of the surface area described in Figure DIC-2520-7 of circumferential piping welds 1/2 inch or less nominal wall thickness. In addition, Examination Category C-F, Item C5.12 requires a surface examination of the surface area described in Figure IWC-2520-7 for a distance of 2.5t (t = nominal pipe wall thickness) from the intersecting circumferential weld of longitudinal piping welds 1/2 inch or less nominal wall thickness.

In an effort to increase the level of confidence in system integrity, the scope of preservice examinations for Class 2 systems, as delineated in Article IWC-2000, was expanded to include 100% of all non-exempt Class 2

piping systems.

5. BASIS FOR RELIEF: On line 2RH01BA-12", circumferential weld C-16 is i inaccessible to a surface examination. Its location (See Attachment 1 for j details), inside a floor penetration, prevents any meaningful surface examination.

On line 2RH03AB-8", circumferential weld C-53 and longitudinal welds C-50-L, C-52-L and C-54-L are inaccessible to a surface examination.

Their locations (See Attachment 2 for details), inside a wall penetration, l prevent any meaningful surface examinations.

6. ALTERNATE TEST METHOD: A visual examination (leak test) is proposed in l lieu of the required surface examination. Visual aids suitable to VT-2 requirements will be utilized for the inspection of the subject welds.

l 7. JUSTIFICATION: In performing a visual examination (leak test) on the subject wslds (C-16, C-50-L, C-52-L, C-53 and C-54-L), an acceptable level of structural integrity for system operation is provided. Austenitic stainless steel type 304 possesses a high degree of toughness. Crack propagation through this material is slow and leak testing is a viable method of identifying flaws prior to weld failure in this type of material.

I l

l In the 1977 Edition, through Summer 1978 Addenda, of ASME Section XI, paragraph IWB-2420(a) states, in part, "The sequence of component examinations established during the first inspection interval shall be repeated during each successive inspection interval to the extent practical." This methodology acknowledges that an accurate overview of system integrity can be developed by re-examining and trending a representative sample of welds.

(0946M/0095M) 1

NR-5 Rev. O All welds contained in lines 2RH01BA-12" and 2RH03AB-8", other than the subject welds, are examinable, including the welds adjacent to the subject velds. Examination of these adjacent welds will provide an accurate status of the structural integrity of the subject welds.

In addition, radiographs performed on welds C-16, C-50-L, C-52-L, C-53 and C-54-L verify structural integrity at the time of system construction.

Therefore, an adequate level of safety can be assured for these welds, both now and during plant life.

(0946M/0095M)

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DETAIL A ATTACHMENT 2 NR-5

NR-6 Rev. O t'

RELIEF REQUEST NR-6

l. SYSTEM: Containment Spray

2. NIMBER OF ITEMS: 5 a

3. ASME CODE CLASS: 2

4. ASNB CODE SECTION XI REQUIREMENTS: Examination Category C-F, Item C5.ll requires a surface examination of the surface area described in Figure IWC-2520-7 of circumferential piping welds 1/2 inch or less nominal wall thickness. In addition, Examination Category C-F, Item C5.12 requires a surface examination of the surface area described in Figure IWC-2520-7 for a distance of 2.5t (t = nominal pipe wall thickness) from the intersecting circumferential weld of longitudinal piping welds 1/2 inch or less nominal h wall thickness.

In an effort to increase the level o confidence in system integrity, the i scope of preservice examinations for Class 2 systems, as delineated in

, Article IWC-2000, was expanded to include 100% of all non-exempt Class 2 piping systems. In addition, the Containment Spray system was selected for preservice examination despite the allowance for exemption by L'

paragraph IWC-1220(b). Only those portions of the Containment Spray system exempted by paragraph IWC-1220(c) were not selected for preservice i examination.

5. BASIS FOR RELIEF: On line 2CS02AA-10", circumferential weld C-61 and longitudinal weld C-62-L are inaccessible to a surface examination. Their locations (See Attachment I for details), underneath a permanent restraint, prevent any meaningful surface examinations.

On line 2CS02AB-10", circumferential weld C-35 and longitudinal welds C-34-L and C-36-L are inaccessible to a surface examination. Their locations (See Attachment 2 for details), inside a floor penetration, prevent any meaningful surface examinations.

6. ALTERNATE TEST MElaiO_D: A visual examination (leak t.est) is proposed in lieu of the required surface examination. Visual aids suitable to VT-2 requirements will be utilized for the inspection of the subject welds.

7. JUSTIFICATION: In performing a visual examination (leak test) on the subject welds (C-34-L, C-35, C-36-L, C-61 and C-62-L), an acceptable level of structural integrity for system operation is provided. Austenitic stainless steel type 304 possesses a high degree of toughness. Crack propegation through this material is slow and leak testing is a viable method of identifying flaws prior to weld failure in this type of material.

l The containment spray system, including the subject welds, is exempt from inservice inspection requirements by application of the conditions of paragraph IWC-1220(b). l l

(0946M/0095M)

NR-6 Rev. O All other welds on lines 2CS02AA-10" and 2CS02AB-10", other than the subject welds, are examinable, including the welds adjacent to the subject welds. Examination of these adjacent welds provides an accurate status of the structural integrity of the subject welds. In addition, radiographs performed on welds C-34-L, C-35, C-36-L, C-61 and C-62-L verify structural integrity at the time of system construction. Therefore, an adequate level of safety can be arsured for these welds, both now and during giant life.

1 l

l I

i (0946M/0095M) l l

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NR-6

i NR-7 Rev. O RELIEF REQUEST NR-7

1. SYSTEM: Reactor Coolant, Reactor Coolant Pressurizer, Safety Injection, and Residual Heat Removal.

2. NUMBER OF ITEMS: 41 Reactor Coolant 2RC8001-A 2RC8002-A 2RC8003-A 2RC8001-B 2RC8002-B 2RC8003-B 2RC8001-C 2RC8002-C 2RC8003-C 2RC8001-D 2RC8002-D 2RC8003-D Pressuriser 2RY8010-A 2RY8010-B 2RY8010-C Residual heat Removal 2RH8701-A ~ 2RH8702-A 2RH8701-B 2RH8702-B Safety Injection 2SI8808-A 2SI8818-A 2SI8841A 2SI8808-B 2SI8818-B 2SI8841B 2SI8808-C 2SI8818-C 2SI8808-D 2SI8818-D l 2SI8948-A 2SI8949-A 2SI8956-A 2SI8948-B 2SI8949-B 2SI8956-B 2SI8948-C 2SI8949-C 2SI8956-C 2SI8948-D 2SI8949-D 2SI8956-D

3. ASME CODE CLASS: 1

4. ASME CODE SECTION XI REQUIREMENT: Examination Category B-L-2, B-M-2, Item B12.40 requires a visual, (VT-1) examination of the valve body internal surfaces on valves exceeding 4 inches nominal pipe size. Examinations are limited to one valve within each group of valves that are of the same constructional design, e.g. globe, gate or checic valve, manufacturing method and that are performing similar functions in the system, e.g.

containment isolation, system overpressure protection.

5. BASIS FOR RELIEF: The requirement to disassemble an operable valve for the sole purpose of performing a visual examination (VT-1) of the internal pressure retaining boundary is impractical and not commensurate to the increased safety achieved by this inspection. Class 1 valves are installed in their respective systems and many have completed functional testing. To disassemble these valves would provide a very small potential for increasing plant safety margins with a very disproportionate impact on expenditures of plant manpower and resources.

(0946M/0095M)

NR-7 Rev. 0

6. ALTERNATE TEST METHOD: The manufacturers test data will be used in lieu of a preservice visual examination (VT-1). This includes documentation of examinations performed during fabrication and installation of the subject valves. The examinations performed may include volumetric, surface, and visual exams, as required by ASME Section II, Material Specifications for Ferrous and Nonferrous materials.

7. JUSTIFICATION: The integrity of the pressure retaining boundary of both carbon steel and stainless steel valve bodies has been excellent. Class 1 valve bodies can not historically be linked to breaching of the pressure retaining boundary in plant systems. Class 1 valves are subjected to numerous types of nondestructive testing and a rigorous quality assurance program during all stages of fabrication, storage, and installation.

These valves have been found acceptable by the Manufacturer, the ASME Authorized Nuclear Inspector and Commonwealth Edison's Quality Assurance.

[

l (0946M/0095M)

NR-8 Rev. O RELIEF REQUEST NR-8

1. SYSTEM: Reactor Coolant Pumps

2. NIDSER OF ITEMS: 4 (IRC0lPA, IRC0lPB, IRC0lPC, IRC0lPD)

=

3. ASME CODE CLASS: 1

4. ASME CODE SECTION XI REQUIREMENTS: Examination Category B-L-1, B-M-1 Pressure Retaining Welds in Pump Casings and Valve Bodies, Item B12.10 requires a volumetric and surface examination of the regicas described in Figure IWB-2500-16. Examination Category B-L-2, B-M-2 Pump Casings and Valve Bodies, Item B12.20 requires a visual examination of the internal surfaces. Subarticle IWB-2200 requires completion of all examinations required by its Article, once, prior to initial plant Startup.

5. BASIS FOR RELIEF: The requirement to disassemble an operable pump for the sole purpose of performing a visual examination (VT-1) of the internal pressure retaining boundary is impractical and not commensurate to the increased safety achieved by this inspection. To disassemble these pumps would provide a very small potential for increasing plant safety margins with a very disproportionate impact on expenditures of plant manpower and resources.

6. ALTERNATE TEST METHOD: The above listed pumps are of the integrally cast l type and, therefore, have no pump casing welds. All internal surfaces,

! received liquid penetrant tests performed by the manufacturer. This exceeds the Section XI requirements for visual examination.

7. JUSTIFICATION: The Reactor Coolant Pump casing is cast austenitic stainless steel, which is extremely tough and resistant to intergranular stress corrosion cracking. The combination of these material properties and the liquid penetrant test performed by the manufacturer assures an acceptable level of structural integrity. In addition, these pumps are i subjected t.o numerous types of nondestructive testing and a rigorous quality assurance program during all stages of fabrication, storage, and installation. These pumps have been found acceptable by the Manufacturer, the Authorized Nuclear Inspector and Conunonwealth Edison's Quality Assurance.

(0946M/0095M)

l NR-9 Rev. 0 ,

RELIEF REQUEST NR-9

1. SYSTEM: Pressurizer Vessel and Steam Generator Vessel (Primary Side)

2. NUMBER OF ITEMS: 14

=

Component Number Weld Numbers 2RC01BA Primary Nozzles (2) 2RC01BB Primary Nozzles (2) 2RC01BC Primary Nozzles (2) 2RC01BD Primary Nozzles (2) 2RY01S PN-1, PN-2, PN-3, PN-4, PN-5, PN-6

3. ASME CODE CLASS: 1

4. ASME CODE SECTION YI REQUIREMENTS: Table IWB-2500-1, Examination Category B-D, Items B3.120 and B3.140 require volumetric examination of the regions described in Figure IWB-2500-7 for the inner radius of full penetration welded nozzles in the pressuriser and steam generators (primary side) respectfully. In addition, Examination Category B-P, Items B15.20 and B15.30 require a system leakage test, IWB-5221, each refueling outage for pressure retaining component in the pressurizer and steam generators respectively.

Subarticle IWB-2200, "Preservice Examination" states that:

a. Examinations required by this Article shall be completed prior to initial plant startup. In addition, these preservice examinations shall be extended to include essentially 100% of the pressure retaining welds in all Class 1 Components, except in those components exempted from examination by IWB-1220 (a), (b) and (c). However, in the case of Examination Category B-O (Table IWB-2500-1), the examination shall be extended to include essentially 100% of the welds in the installed peripheral control rod drive housings only.

5. BASIS FOR RELIEF: The nozzles listed above all contain inherent geometric constraints and clad inner surfaces which limit the ability to perform 1 meaningful volumetric examinations. In an attempt to develop a technique I to locate flaws in the nozzle inner radii area, a mock-up was used with little success. The only notch which was detectable was the deepest one which penetrated the cladding and extended to a depth of approximately ,

5/16" into the carbon steel.

l l

l (0946M/0095M)

. - . . _ _ _ _ _ - . _ . . _ . _ _ _ _ _ . _ - - _ _ _ _ _ - ~ _ - - _ _ - _ _ . . . _ . _ _ . _ . . . _ . . . . . - . . . _ - - _ . _ _ -

T I

1 NR-9 Rev. 0

6. ALTERNATE _ TEST ME"fHOD: The steam generator primary side nozzles were surface tested using the liquid penetrant method. The nozzle was examined up to a ring welded to the inner radii which is used to hold down the nozzle cover during steam generator channel head work. All pressure retaining components were hydrostatically tested to the requirements of ASME Section III prior to plant startup. When a viable alternative test method is developed to inspect this area of a nozzle it will be cons (dered.

7. JUSTIFICATION: In performing the alternate inspection on the steam generators and the hydrostatic test on all pressure retaining components, an adequate level of structural integrity is assured for plant operation.

l I

(0946M/0095M) ,

NR-lO Rev. O RELIEF REQUEST NR-10

1. SYSTEM: Reactor Pressure Vessel

2. NIBIBER OF ITEMS: 3 4

Wold Number Attachment Numbers RPVC-WR29 1, 2 & 5 RPVC-WR16 1, 3 & 5 RPVC-WR7 1, 4 & 5

3. ASME CODE CLASS: 1

4. ASME CODE SECTION XI REQUIREMENTS: Table IWS-2500-1, Examination Category B-A, Items Bl.11, Bl.21 and 81.30 require volumetric examination of the regions described in Figures IWB-2500-1, 3 and 4 respectfully for welds in the reactor pressure vessel. In addition, examination Categorf B-P, Item B15.10 requires a leakage test in accordance with IWB-5221 each refueling outage for the reactor pressure vessel.

Article IWB-2200 "Preservice Examination" states that:

a. Examinations required by this Article shall be completed prior to initial plant startup. In addition, the preservice examinations shall be extended to include essentially 100% of the pressure retaining welds in all Class 1 components except those components exempted from examination by IWB-1220 (a), (b) or (c).

b. Shop and field examinations may serve in lieu of on-site preservice examination provided:

1) In the case of vessels only, the examination is performed after the hydrostatic test required by Section III has been completed;

2) Such examinations are conducted under conditions and with equipment and techniques equivalent to those that are expected to be employed for subsequent inservice inspections; and

3) The shop and field examination records are, or can be, documented and identified in a form consistent with those required in IWA-6000.

5. BASIS FOR RELIEF:

l a. Lower shell course-to-Dutchman weld RPVC-WR29 has six (6) core barrel-locating lugs welded to the interior surface of the reactor vessel approximately 4.0 inches above the weld (Attachment 2, Figure 1). These lugs restricted the automated inspection tool from inspecting the required volume from the shell course side in the areas of the lugs. All of the weld metal was examined from the i

1 (0946M/0095M)

NR-10 Rev. O shell course side where access was available between the lugs. Even below the lugs, the inner 2 to 4 inches of weld metal was examined.

Examinations from the Dutchman side for parallel reflectors covered 100 percent of the weld metal and heat-affected zone (HAZ).

Likewise,100 percent of the weld metal and HAZ was examined for transverse reflectors in two opposing directions. Attachment 2, Figures 2 and 3 show exactly what was inspected. Note, the .

dimensions used for actual and required coverage in these figures are for transducer position, not volume inspected.

b. Lower disk-to-Dutchman weld RPVC-WR16 has 58 instrument tubes (Attachment 3, Figure 1) that penetrate the lower disk and physically obstruct the search unit and/or search unit position device. The weld and HAZ received essentially 100-percent coverage for parallel reflectors from the Dutchman side and for transverse reflectors in two opposing directions. Full coverage for parallel reflectors from the disk side was limited to about 85 percent of the weld length; partial coverage was achieved on the remainder of-the weld.

Attachment 3, Figures 2 and 3, gives a detailed picture of the areas inspected and those which were obstructed by the tubes. Note, dimensions given are for transducer position, not area inspected.

c. Nossle shell course-to-flange weld RPVC-WR7 is located just below the tapered portion of the flange which prevents 100-percent examination of the required adjacent base metal, Attachment 4, Figure 1. All of the required volume was inspected for parallel reflectors, manually, from the vessel flange. All of the weld metal and approximately 90 percent of the adjacent base metal was inspected for transverse reflectors as shown in Attachment 4, Figure 2.

In addition, Attachment 5 outlines the extent of near-surface volume

! not effectively examined for each of the above-listed welds.

6. ALTERNATE TEST METHOD

None

7. JUSTIFICATION: Completion of the remaining portions of the required examination is impractical and would result in undue hardship without a

! compensating increase in safety. The limited Section XI examination, the volumetric examination performed during fabrication, and the hydrostatic test demonstrate an acceptable level of preservice structural integrity.

l l

(0946M/0095M)

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O %D* , U. 4 -100.8 Cht SEGMEN T.S FIGURE 2 ATTACHMENT 4 NR-IO

NR-10 Rev. O Estimate of the Extent of Near Surface Volume Not Effectively Examined:

Weld Inspection Beam Base Metal Near Surface Designation Angle & Direction Not Examined (inches)

_____ _ _______________ _ _ _ _ _ .a ____

WR-16 and WR-29 60' Parallel & Transverse Reflectors 0.35 45' Parallel Reflectors 0.85 45' Transverse Reflectors 0 0' Contact 1.15 0' Water Path 0.75 WR-18 and WR-34 60' Parallel Reflectors 0 45' Parallel Reflectors -

0.1 0* I.:.minar and Planar ~

1.25 60' Transverse Reflector 0 45' Transverse Reflectors 0.5 WR-18 70' Near Surface 0.31 WR-7 and Transvers 60' Transverse O Examinations of 45* Transverse O Nossle-to-Vessel O' Iaminar and Planar 1.6 Welds (8) f Attachmtnt 5 NR-10_

(0946M/0095M)

NR-11 Rev. O RELIEF REQUEST NR-ll

1. SYSTD(: Reactor Pressure Vessel

2. NUMBER OF ITEIS: 4 e

Neld 1hasber Attachment Number RPVN-A,D,E and H 1, 2, 3 & 4

3. ASME CODE CLASS: 1

4. ASME CODE SECTION XI REQUIREMENTS: Table IWB-2500-1, Examination Category B-J, Item B3.90 requires volumetric examination of the regions described in Figure IW5-2500-7 for full penetration welds of nossles in vessels. In addition, examination Category B-P, Item B15.50-requires a system leakage test, IWB-5221 each refueling outage for the reactor pressure retaining components.

Article IWB-2500-1, "preservice Examination" states that

a. Examinations required by this Article shall be completed prior to initial plant startup. In addition, the preservice examination shall be extended to include essentially 100% of the pressure retaining welds in all Class 1 components except in those components exempted from examination by INB-1220 (a), (b) or (c).

b. Shop and field examinations may serve in lieu of the on-site preservice examinations provided:

1) In the case of vessels only, the examination is performed after the hydrostatic test required by Section III has been completed;

2) Such examinations are conducted under conditions and with equipment and techniques equivalent to those that are expected to be employed for subsequent inservice examinations; and

3) The shop and field examination records are, or can be, documented and identified in a form consistent with those requiced in IWA-6000.

5. BASIS FOR RELIEF: Nossle-to-vessel welds on outlet nossles A, D, E and H are obstructed by the integral extension from receiving complete ultrasonic examination. The required volume was inspected for parallel reflectors from the ID surface of the nossle, however, approximately 15%

of the required base metal was not inspected for transverse reflectors from the vessel side as shown in Attachments 2 and 3. In addition, Attachment 4 provides an estimate of the near surface volume not effectively examined.

(0946M/0095M)

NR-ll Rev. 0

7. JUSTIFICATION: Completion of the required examination is impractical and would result in undue hardship without a compensating increase in safety.

The limited Section XI examination, the volumetric examination performed during fabrication, and the hydrostatic test demonstrate an acceptable level of preservice structural integrity.

a.

I (0946M/0095M)

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NR-ll Rev. O Estimate of the Extent of Near Surface Volume not Effectively Examined Base Metal Near Weld Designation Transducer Surface Not Examined (inches)

=

Examination of Nozzle-to-Vessel O' Laminar and Planar 1.6 Welds (8)

Attachment 4 NR-ll (0946M/0095)

l RELIEF REOUEST NR-12 Limited Ultrasonic Examination of Cast Stainless Steel Elbow, Pump or Valve-to-Pipe Welds (To Be Provided Later)

L l

NR-13 Rev. 0 RFLIEF REQUEST NR-13

1. SYSTD(: Steam Generator Vessel (Secondary Side) Nozzles, Residual Heat Exchanger Nozzles

2. NUMBER OF ITEMS: 10 Component Number Nozzle Number 2RC01BA SCN-02,03 i 2RC01BB SGN-02,03 .

{ 2RC01BC SGN-02,03 2RC01BD SGN-02,03 2RH02AA RHXN-01,02

3. ASME CODE CLASS: 2

' ~

4. ASME CODE SECTION XI REQUIRDIENTS: Table INC-2500-1, Examination Category, C-B, Itest C2.20 requires surface and volumetric examination of

, the regions described in Figure INC-2500-4 for nozzles in vessels over 1/2 in. in nominal thickness. Figure INC-2500-4 requires volumetric examination of the inner radii on nozzles over 12 in. nominal pipe size.

t In addition, Examination Category C-H, Item C7.10 requires a system leakage test, IWC-5221, each inspection period for all pressure vessel pressure retaining components.

Subarticle IWC-2200 "Preservice Inspection" states that:

a. All examinations required by this Article for those components initially selected for examination in accordance with Inspection Program A or Inspection Program B and not axempted from inservice examination by IWC-1220 shall be completed prior to initial plant startup.

5. BASIS FOR RELIEF: The nozzles listed above contain inherent geometric constraints which limit the ability to perform meaningful ultrasonic l examinations. The main steam nozzles (SGN-03's) have an internal multiple venturi type flow restrictor, see Attachment 1. This design does not have a nozzle inner radii as described in Figure IWC-2500-4. This nozzle has seven individual inner radii, corresponding to each venturi, none of which could be examined by ultrasonic examination. The main feedwater nozzles (SGN-02's) also have an internal multiple venturi type flow restrictor but have a thermal sleeve in addition, see Attachment 2. This design could not be examined due to the geometry of the nozzles internal design.

(0946M/C095M)

4 NR-13 Rev. O I

The Residual Heat Removal Heat Exchanger is approximately 7/8 in, nominal wall thickness with nozzles of 14 inch diameter and approximately 3/8 in.

in nominal wall thickness. Attachment 3 shows the actual nozzle-to-shell weld configuration for the Residual Heat Removal Heat Exchangers primary side nozzles. This configuration is best characterized as a fillet welded nozzle and, thereby, is not analogous to a full penetration butt welded nczzle as shown in Figure IWC-2520-4. In addition, the inner radius of

, the reinforcement pad would be representative of the nozzle inner radius

) required for inspection. The inherent geometric constraints of the nozzle design prevent the performance of the required ultrasonic examinations of the nozzle-to-shell weld and the nozzle inner radius.

6. ALTERNATE TEST METHOD: Ultrasonic examination of the above listed nozzle inner radii is not practicable and the inner radii is not accessible to direct contact for surface examination or even remote visual examination.

However, the Steam Generator (Secondary Side) Nozzles have been examined at the point of attachment to the vessel by radiography per ASME Section III, and by ultrasonic examination per ASME Section XI. The Residual Heat

, Removal Heat Exchanger Nozzles have been examined by radiography per ASME Section III, and by surface examination per ASME Section XI. In addition, a system hydrostatic test, at 125% of the design pressure, has been performed in accordance with ASME Section III and a system leakage test, at 100% of the system nominal operating pressure, will be performed each inspection period in accordance with ASME Section XI.

7. JUSTIFICATION: The above listed main steam and main feedwater nozzles are designed with multiple venturi type flow restrictors to limit flow during a Main Steam line or Main Feedwater line break. This design thus enhances the plant's inherent level of safety but does not allow meaningful ultrasonic examination of the nozzles inner radii. However, the increased safety margin afforded by these nozzles makes them a desirable part of plant design. The actual nozzle-to-shell weld configuration of the Residual Heat Removal Heat Exchanger nozzles is most closely approximated by Figure IWC-2500-4(c) of the 1980 Edition, Winter j 1981 Addenda of Section XI. The examination requirement associated with this figure, with the inside of the vessel inaccessible, is a surface examination of the nozzle-to-shell weld. Therefore, it is believed the performance of the surface examination meets the intent of Section XI relative to the examination requirements for a fillet welded nozzle. In performing the ASME Section III inspections and the ASME Section XI ultrasonic and/or surface examinations of the point of attachment to the vessel, along with the inservice leakage test, an adequate level of structural integrity for these nozzles is assured for plant operation.

(0946M/0095M)

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NR-14 Rev. O RELIEF REQUEST NR-14

1. SYSTEM: Containment Spray, Chemical and Volume Control, Residual Heat Removal

2. NUMBER OF ITEMS: 8 Component Number Weld Numbers Attachment Number 2CS0lPA CSPE-01, CSPE-02, &

CSPE-03 1 2CV01PA CVPE-01, CVPE-04 2 2RH0lPA RHPE-01, RHPE-02, &

RHPE-03 3

3. ASME CODE CLASS: 2

4. ASME CODE SECTION XI REQUIREMENTS: Table IWC-2500-1, Rwn-ination Category C-C and C-E, Item C3.70 requires surface examination of the regions described in Figure IWC-2520-5 for integrally welded attachments to pumps.

Subarticle IWC-2200, "Preservice Examination," states that:

a. All examinations required by this Article for those components initially selected for examination in accordance with Inspection Program A or Inspection Program B and not exempted by IWC-1220 shall be conducted prior to initial plant startup.

b. Shop and field examinations may serve in lieu of on-site preservice i examinations, provided: .

l 1). in the case of vessels only, the hydrostatic test required by Section III has been completed; 2). such examinations are conducted under conditions and with equipment and techniques equivalent to those which are expected to be employed for subsequent inservice examinations:

3). the shop and field examination records are or can be documented and identified in a form consistent with those required in IWA-6000.

(0946M/0095M)

. I NR-14 Rev. 0

5. BASIS FOR RELIEF: The above listed welds connect the support lugs to the pump casings. These integrally welded attachments were examined by the manufacturers using a surface examinaticn technique. The preservice examination was performed on three sides of each attachment, but the fourth side could not be inspected due to the structural support members being installed.

=

6. ALTERNATE TEST METHOD: The manufacturers surface examination results will serve as the alternate test method preservice. Inservice, a visual examination (VT-1), will be utilized for the inaccessible portions of these welds.

NOTE: The Containment Spray (CS) System is exempted from examination by IWC-1220 but was included in the preservice inspection program plan. Inservice examinations will not be conducted on this pump.

7. JUSTIFICATION: In using the manufacturers examination results and the partial preservice examination results, an adequate level of structural integrity is assured for plant operation.

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I (0946M/0095M)

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NR-15 Rev. O RELIEF REQUEST NR-15

1. SYSTEM: Chemical and Volume Control, Excess Letdown Heat Exchanger

2. NUMBER OF ITEMS: 1 Component Number Weld Number Attachment Number 2CV01AA ELHXC-03 1&2

3. ASME CODE CUSS: 2

4. ASME CODE SECTION XI REQUIREMENTS: Table IWC-2500-1, Examination Category C-A, Items C1.10 and C1.20 require volumetric examination of 6he regions described in Figure IWC-2520-1 for shell and head circumferential welds.

In addition, Examination Category C-H, Item C7.10 requires a system leakage test in accordance with IWC-5221 for pressure vessel pressure retaining components.

Subarticle IWC-2200, "Preservice Examination," states that:

a. All examinations raquired by this Article for those components initially selected for examination in accordance with Inspection Program A or Inspection Program B and not exempted by IWC-1220 shall be completed prior to initial plant startup.

b. Shop and field examinations may serve in lieu of on-site preservice examinations, provided: -

1). in the case of vessels only, the hydrostatic test required by Section III has been completed; 2). such examinations are conducted under conditions and with equipment and techniques equivalent to those expected to be employed for subsequent inservice examinations; 3). the shop and field examination records are or can be documented and identified in a form consistent with those required by IWA-6000.

Mandatory Appendix III, Article III - 4000 requires examination for

l a. Reflectors parallel to the weld seam.

l f The angle beam examination for reflectors parallel to the weld seam i shall be performed by a full V path from one side or a one-half V path from two sides of the weld, where practicable.

(0946M/0095M)

NR-15 Rev. O

b. Reflectors transverse to the weld seam.

1). The angle beam examination for reflectors transverse to the weld seam shall be performed on the weld crown on a single seam path-to examine the weld root by one-half V path in two directions along the weld.

2). For inservice examination, only those welds showing reportable preservice indications need.be examined for transverse reflectors.

5. BASIS FOR RELIEF: Weld ELHXC-03 received radiographic examination to meet the requirements of ASME Section III. These examinations could be used to meet the requirements of ASME Cection XI. However, we do not intend to use radiography as our inservice test method.

Ultrasonic examination of weld ELHXC-03 was limited for approximately 70%

of the weld length due to four branch connections welded to the vessel.

6. ALTERNATE TEST METHOD: In lieu of the required ultrasonic inspection a surface examination utilizing the liquid penetrant test will be performed on the above welds.

7. JUSTIFICATION: The ASME Section III radiograph and hydrostatic test along with the limited ultrasonic examination and alternate surface examination will provide an adequate level of structural integrity for plant operation.

i (0946M/0095M)

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1. SYSTEM: Chemical and Volume Control, Regenerative Heat Exchanger

2. NUMBER OF ITEMS: 2 Component Number Weld Number  % Missed Attachment Number 2CV03AA RGXC-01 10% 1 2CV03AA RGXC-06 10% 1

3. ASME CODE CLASS: 2

4. ASME CODE SBCTION XI REQUIREMENTS: Table IWC-2500-1, Examination Category C-A, Item C1.20 requires a volumetric examination of the regions described in Figure IWC-2520-1 for head circumferential welds. In addition, Examination Category C-H, Item C7.10 requires a system leakage test in accordance with IWC-5221 each inspection period for pressure vessel pressure retaining components.

Subarticle IWC-2200, "Preservice Examination," states that:

i

a. All examinations required by this Article for those components

, initially selected for examination in accordance with Inspection l Program A or Inspection Program B and not exempted by IWC-1220 shall be completed prior to initial plant startup.

b. Shop and field examinations may serve in lieu of on-site preservice examinations, provided:

1). inthecaseofvesseisonly,thehydrostatictestrequiredby Section III has been completed; 2). such examinations are conducted under conditions and with equipment and techniques equivalent to those which are expected to be employed for subsequent inservice examinations; 3). the shop and field examination records are or can be documented i and identified in a form consistent with those required in IWA-6000.

Mandatory Appendix III, Article III - 4000 requires examination for:

a. Reflectors parallel to the weld seam.

The angle beam examination for reflectors parallel to weld seam shall 4

be performed by a full V path from one side or a one-half V path from two sides of the weld, where practicable.

(0946M/0095M)

NR-16 Rev. O

b. Reflectors transverse to the weld seam.

1). The angle beam examination for reflectors transverse to the weld seam shall be performed on the weld crown on a single scan path to examine the weld root by one-half V path in two directions along the weld. _

l 2). For inservice examinatiion, only those welds showing reportable preservice indications need be examined for transverse reflectors.

5. BASIS FOR RELIEF:

The above listed weld was inspected volumetrically by the radiographic method to meet the ASME Section III requirements. In addition, an ASME Section XI volumetric inspection was performed in the axial direction for reflectors parallel to the weld seas. The circumferential scan for reflectors transverse to the weld seam was limited to approximately 90% of the weld length due to the shell side nozzles. The ASME Section III radiographs could be used to meet the preservice examination requirements except it is not our intent to use radiography inservice.

6. ALTERNATE TEST METHODS: In lieu of the required ultrasonic examination for reflectors transverse to tne weld seam, a surface examination by the liquid penetrant method will be performed.

7. JUSTIFICATION: Per ASME Section III, radiography and hydrostatic tests have been completed on this weld. Per ASME Section XI, an ultrasonic inspection for reflectors parallel to the weld seam and an alternate surface examination have been completed. Based upon the results of the above examinations, an adequate level of structural integrity exists for plant operations.

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NR-17 Rev. O RELIEF REQUEST NR-17

1. SYSTEM: Pressurizer (Line 2RY01AA-4")

2. NUMBER OF ITEMS: 1 (Weld J3) .

3. ASME CODE CLASS: 1

4. ASME CODE SECTION XI REQUIREMENTS: Table IWB-2500-1, Examination Category B-J, Item B9.ll requires a surface and volumetric examination of the volume described in figure IWB-2500-8. The volumetric examination performed during the inspection interval shall cover all the area of 25%

of the circumferential joints. The examination includes at least a pipe diameter length, but not more than 12 inches of each longitudinal weld intersecting the circumferential welds required to be examined.

IWB-2203 states, " Examinations required by this article shall be completed prior to initial plant startup. In addition, these preservice examinations shall be extended to include essentially 100% of the pressure retaining welds in all Class 1 component, except in those components exempted from examination by IWB-1220."

Mandatory Appendix III, Article III-4000 requires examination for:

a. Reflectors parallel to the weld seam.

The angle beam examination for reflectors parallel to the weld seam shall be performed by a full V path from one side or a one-half V path from two sides of the weld, where practicable.

b. Reflectors transverse to the weld seam.

The angle beam examination for reflectors transverse to the weld seam j shall be performed on the weld crown on a single scan path to examine  !

the weld root by one-half V path in two directions along the weld.

5. BASIS FOR RELIEF: The above listed weld was inspected volumetrically by the radiographic method to meet the ASME Section III requirements. In addition, an ASME Section XI volumetric inspection was performed in the circumferential direction for reflectors transverse to the weld seam. The axial scan for reflectors parallel to the weld seam was limited to approximately 82% of the weld length due to a sockolet connection. The ASME Section III radiographs could be used to meet the preservice examination requirements, except, it is not our intent to use radiography inservice.

@ D OC Q 9@ @l E 33- - - - - - - - - - - - - - - - - - - - - - - - - -

NR-17 Rev. 0

6. ALTERNATE TEST METHOD: In lieu of the required ultrasonic examination for reflectors transverse to the weld seam, a calibrated O' longitudinal wave examination of the miesed area has been performed.

7. JUSTIFICATION: Per ASME Section III, radiography and hydrostatic tests have been completed on this weld. Per NiME Section XI, an ultrasonic inspection for reflectors, parallel to the weld seam and an alternate" volumetric examination have been completed. Based upon the results of the above examinations, an adequate level of structural integrity exists for plant operations.

i (0946M/0095M)

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__ . _ _ _ . _ . _ . - - - - _ - _ _ . - - - _ . _--