ML20081E413
| ML20081E413 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/30/1990 |
| From: | Beth Brown EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20081E418 | List: |
| References | |
| CON-FIN-D-6022 EGG-MS-8943, NUDOCS 9011130331 | |
| Download: ML20081E413 (108) | |
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EGG-MS-8943 TECHNICAL EVALUATION REPORT ON THE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:
ALABAMA POWER COMPANY,'
JOSEPH M. FARLEY NUCLEAR POWER PLANT, UNIT 1, DOCKET NUMBER 50-348 B. W. Brown J. D. Mudlin Published November 1990 Idaho National Engineering 1.aboratory EG1G Idaho, Inc.
Idaho falls, Idaho 83415 Prepared for:
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 under DOE Contract No. DE-AC07-761001570 FIN No. 06022 (Project 5) 4/3 6 t
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ABSTPACT This report presents the results of the evaluation of the Joseph M. Farley Nuclear Power Plant, Unit 1, Second 10-Year Interval Inservice Inspection (ISI) Program, through Revision 3, submitted August 15, 1990, including tre 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 Joseph M. Earley Nuclear Power Plant, Unit 1, Second 10-Year Interval ISI Program is evaluated in Section 2 of this report. The ISI Program 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 previous Nuclear Regulatory Commission reviews. The requests for relief are evaluated in Section 3 of this report.
This vork was funded under:
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U.S. Nuclear Regulatory Commission FIN No. D6022, Project 5 Operating keactor Licensing Issues Program, Raview of ISI for ASME Code Class 1, 2, and 3 Components 11
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SUMMARY
The Licensee, Alabama Power Company, has prepared the Joseph M. Farley [
Nuclear Power Plant, Unit 1, Second 10-Year Interval Inservice Inspection ;
-(ISI) Program, through Revision 3, to meet the requirements of the 1983-Edition, Summer 1983 Addenda of the ASME- Code Section XI except that the extent of examination for Code Class 1 and Code Class 2 piping welds has [
been determined by the 1974 Edition through Summer 1975 Addenda as permitted :
and required by 10 CFR 50.55a(b). The second 10-year interval began f December 1, 1987 and ends December 1, 1997, j The information in the Joseph M. Farley Huclear Power Plant, Unit 1, Second !
10-Year Interval ISI Program, through Revision 2, submitted September 9, [
1988, was reviewed. Included in the review were the requests for relief [
! from the ASME Code Section XI requirements which the Licensee has determined !
to be impractical. As a result of this review, a request for additional f information was prepared describing the information and/or clarification [
required from the Licensee in order to complete the review. The Licensee ;
provided additional information in submittals dated October 5,1989; ;
December 7, 1989; and April 12, 1990. Revision 3 to the ISI Program was submitted in a letter dated August 15, 1990. Corrections to Revision 3 of ;
three relief requests-were submitted in a letter dated September 12, 1990.
Based on the review of the documents listed above and the recommendations for granting relief from the ISI examination requirements that have been !
determined to he impractical, it is concluded that the Joseph M. Farley -5 Nuclear Power Plant, Unit 1, Second 10-Year Interval ISI Program, through- j Revision 3, is considered unacceptable and not in compliance with ;
10 CFR 50.55a(g)(4) due to an unacceptable examination sample and ,
unacceptable application of the exclusion criteria (see Sections 2.2.2 and [
2.2.3 of this report). It.is recommended that relief be granted with l conditions for Requests for Relief RR-15, RR-16, and RR-17. For Requests for Relief RR-4 (in part), RR-29, and RR-33 (in part), it is recommended that relief be denied. Requests for Relief RR-6, RR-24, RR-41, RR-42, and j RR-45 either have been withdrawn or are not included in the scope of this document. ;
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l CONTENTS ABSTRACT .............................................................. ii
SUMMARY
............................................................... iii
- 1. INTRODUCTION ...................................................... 1
- 2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN ................... 4 2.1 Documents Evaluated ......................l..................... 4
%.2 Compliance with Code Requirements .............................. 4 2.2.1 Compliance with Applicable Code Editions . . . . . . . . . . . . . . . . . . . 4 2.2.2 Acceptability of the Examination Sample .................... 5 2.2.3' E x cl u s i on C r i te r i a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2.2.4 Augmented Examination Commitments .......................... 7 2.3 Conclusions .................................................... 7
- 3. EVALUATION OF RELIEF REQUESTS ..................................... 8 3.1 Class 1 Components ............................................. 8 3.1.1 Reactor Pressure Vessel .................................... 8 3.1.1.1 Request for Relief No. RR-8, Examination Category B-A, Item Bl.22, Reactor Pressure Vessel Lower Head Meridional Weld ..................... 8 3.1.1.2 Request for Relief No. RR-14, Examination Category B-G-1, Item B6.40, Threads in the -
Reactor Pressure Vessel Flange ........................ 10 3.1.2 Pressurizer ................................................ 12 3.1.2.1 Request for Relief No. RR-9, Examination Category B-D, Item B3.110, Pressurizer Nozzle-to-Vessel Welds ................................ 12 3.1.3 Heat Exchangers and Steam Generators ................. ..... 14 3.1.3.1 Request for Relief No. RR-10, Examination Category B-F, Item B5.70, Steam Generator Nozzle-to-Pipe Safe End Welds ......................... 14 3.1.3.2 Request for Relief No. RR-11, Examination Category B-D, Item B3.140, Steam Generator Inlet and Outlet Nozzle Inner Radius Sections ......... 16 iv q i
3.1.4 Piping Pressure Boundary ................................... 18 1
3.1.4.1: Request for Relief No. RR-13, Examination Category B-J, Item 09.31, Class 1 Branch Pipe Connection Welds ................................. 18 3.1.5 Pump Pressure Boundary ....................... ............. 20 3.1.5.1 Request for Relief No. RR-15, Examination Category B-L-2, Item B12.20, Reactor Coolant Pump Internal Pressure Boundary Su,rfaces . . . . . . . . . . . . . . 20 1 3.1.6 Valve Pressure Boundary .................................... 23 3.1.6.1 Request for Relief No. RR-16, Examination
- Category B-M-2, Item B12.50, Internal Pressure Boundary Surfaces of Cl ass 1 Valves . . . . . . . . . . . . . . . . . . 23 3.1.7 General (No relief requests) 3.2 C l a s s 2 C omp o n e n t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 3.2.1 Pressure Vessels ........................................... 26 3.2.1.1 Request for Relief No. RR-18, Examination Category C-A, Items C1.20 and C1.30, Pressure Retaining Welds in the Regenerative Heat Exchanger .... 26 3.2.1.2 Reque:t for Relief No. RR-19, Examination Category C-A, Items C1.10 and C1.20, Class 2 Pressure Vessel Welds ................................. 28 3.2.1.3 Request for Relief No RR-28, Examination
. Category C-8, Item C2.22, Class 2 Steam Generator Nozzle Inside Radius Sections ........ ...... 29 3.2.2 Piping (No relief requests) 3.2.3 Pumps ................................. .................... 30 3.2.3.1 Request for Relief No. RR-20, Examination Category C-C, Item C3.30, Class 2 Integrally Welded Attachments on Chargint Pumps .................. 30 3.2.4 Valves (No relief requests) 3.2.5 General (No relief requests) 3.3 Class 3 Components (No relief requests) v
I 3.4 Pressure Tests ................................................. 32 3.4.1 Class 1 System Pressure Tests (No relief requests) 3.4.2 Class 2 System Pressure Tests .............................. 32 3.4.2.1 Request for Relief No RR-21, Hydrostatic Test of Class 2 Containment Pressure Sensing Lines in the Safety Injection System ........................ 32 3.4.2.2 Request for Relief No. RR-22, Hydrostatic Test of Portions of Class 2 Piping and ' Interim Components at Reduced Pressure ........................ 34 3.4.2.3 Request for Relief No. RR-23, Hydrostatic Test of Portions of Class 2 Components to Requirements of the Connecting Cl ass 1 Piping . . . . . . . . . . . . . . . . . . . . . . 36 3.4.2.4 Request for Relief No. RR-24, Hydrostatic Test of the Class 2 Relief Line Discharge Header Piping to the Pressurizer Relief Tank ................. 39 3.4.2.5 Request for Relief No. RR-25, Hydrostatic Test of Class 2 Pressure Retaining Reactor Vessel Fl ange Se al Leako ff Li ne . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 3.4.2.6 Request for Relief No RR-26, Hydrostatic Test of Class 2 Piping Isolated from the Test Boundary by Cl o s ed Ch ec k Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 3.4.2.7 Request for Relief No. RR-27, Hyorostatic Test of the Class 2 Waste Gas Drain Filter Line . . . . . . . . . . . . 43 3.4.2.8 Request for Relief No. RR-29, Hydrostatic Test of Class 2 Boron Injection Recirculetion Pump Discharge Piping ...................................... 44 3.4.2.9 Request for Relief Nc RR-30, Hydrostatic Test of the Class 2 Portion of the Steam Generators and Associated Piping ................................. 46 3.4.2.10 Request for Rel of No. RR-40, Hydrostatic Test of All Class 2 liranch Pipe Lines from the Volume Control Tank to the First Valve ....................... 47 3.4.2.11 Request for Relief No. RR-43 Hydrostatic Test of Class 2 Portions of the RCS Head Vent Lines ........ 49 3.4.3 Class 3 System Pressure Tests .............................. 52 3.4.3.1 Request for Relief No. RR-31, Visual Examination for Leakage of Class 3 Service Water Pumps During System Pressure Tests ................................. 52 vi
i 3.4.3.2 Request for Relief No. RR 32, VT 2 Visual -
Examination of Class 3 Piping Encased-in Contrate in the Spent fuel Pool Cooling System . . . . . . . . . . . . . . . . ._ 53 i j
3.4.3.3- Request for Relief No. RR-33, Hydrostatic Tests j of_ Portions of Class 3 Piping- and Components in - i Service Water, Soent Fuel Pool Cooling,-Component :
Cooling Water, Chemical and Volume Control, and I Reactor. Makeup _ Systems ................................ 55 l 1J.3.4 Request for Relief No. RR-34, Hydrostatic Test ,
of Class 3 Spray Additive Piping and Components !
-in the Containment Spray System ......_................. 58 l 3.4.3.5. Request for Relief No. RR 35, Hydrostatic Test i of-Class 3 Portions of Buried Piping in the l Service Water System .................................. 60 j t
3.4.3.6 Request for Relief No. RR 36, VT-2 Visual !
Examination of Heat Exchanger Tubes of Class 3 :
Pressure Retalning Safety Related Heat Exchangers ..... 62 i 3.4.3.7 Request for Relief No. RR-37, VT-2 Visual !
Examination of the Cooling coils for Class 3 l Pressure Retaining Sa fety Related Coolers . . . . . . . . . . . . . 64 1
'3.4.3.8- Request for Relief No RR 38, Hydrostatic Test ~ i of Class 3 Piping of the Auxiliary Steam System ....... 67 -!
I 3.4.3.9 Request for Relief No. RR-39, Hydrostatic Test of Class 3 Auxiliary feedwater Pump Minimum Flow 1 l
Piping................................................. 68 ji 3.4.3.10 Request for Relief No 'RR-44, VT-2 Visual !
Examination of Heat Exchanger Tubes of Class 3 .
Pressure Retaining Safety Related-Heat Exchangers ..... .:
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.'3.4.4 ' General'.................................................... -72 )
3.4.4.1 Request for Relief No. RR-45, Hydrostatic Test !
-of Class 2 and Class-3 Low Pressure Systems ........... 72- i t
3.4.4.2 Request for Relief No. RR-46, -Scheduling of Class 2 l' land.Cicss 3. System Hydrostatic-Pressure Tests ......... >
3.5_ General ........................................................ 74 L , _.
3.5.1.' Ultrasonic' Examination Techniques ..........................
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- 3. 5.1.1 - Request for Relief No. RR-1, Material Requirements for Calibration Blocks ................... 74 .
3_5.1.2 ' Request for Relief No. RR-2, Specific Dimensional !
Requirements fcr Calibration Blocks . . . . . . . . . . . . . . . . . . . 78 j i
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l 3.5.1.3 Request forl Relief No.f i'R-3, Specific Dimensional Requirement s for Calibra tion Blocks . . . . . . . . . . . . . . . . . . . 79 3.5.1.4_ Request.for Relief No. PR-4, Wall Thickness Differences-Between.Cel bration Blocks and Components to be Eyami*ed .............................._ 81
- 3. 5.1. 5 - Request for Relief No. RR-5,. Curvature Differences 1Between Calibration Blocks and Components'to be Examined .............................. 85 3.5.1.6 Request for' Relief No. RR-6, Materials for Fabrication of Calibration Blocks and Acoustic Compatibility with the Component to be Examined ....... 88 3.5.1.7 Request for Relief No. RR-7, Dimensional Requirements for Calibration Notches Placed in. Ultrasonic Calibration Blocks ...................... 89 3.5.2 Exempted Components (No relief requests) u 3.5.3 Other1...................................................... 90 3.5.3.1 Request for_ Relief No. RR-12, Delete VT-4
- Visual Examination Method and Examination Requirement and Redefine VT-3 Visual Examination l . Method in Accordance With Paragraph IWA-2213 of t- the 1986 Edition of the Code ........................., 90
- 3.5.3.2 . Request for Relief No. RR-17, Reference System
,e for All Welds and Areas Subject to Surface or j, Vol ume t ri c Ex ami n a t i on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92 I 13.5.3.3 Request for Relief _No.-RR-41, Break Away Drag Tert for Hydraulic Snubbers ........................... 94 s 3.5.3.4 Request- for Relief No. RR d.2, Additional Sample i Testing. Requirements For Snubbers .....................
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- '4. CONCLUS10N
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- 5. REFERENCES ........................................................ 97 iz l
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TECHNICAL EVALUATION REP 0di ON TPE i SECOND 10 YEAR INTERVAL INSERVJCE INSPECT'ON FROGRAM PLAN: !
ALABAMA POWER COMPANY, JOSEPH M. FARLEY NUCLEAR POWER PLANT, UNIT 1, l DOCKET NUMBER bO 348 ,
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- 1. INTRODUCTION !
e Throughout thi. service life of a water cooled nuclear power facility, 10 CFR 50.55a(g)(4) (Reference 1) requires tha, components (including ;
supports) which are ciassified as American Society of Mechanical Engineers l (ASMF) Boiler and Pressure Vessel coa Class 1. Class 2, and Class 3 meet j the requirements, except the design and access previsions 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 cons,truction of the components. This section of the
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regulations also ren' was that inservice examinations of components and !
system o essure tests co1 ducted during successive 120 month inspection l' interv shall comply with the requirements in the latest edition and ,
addenda 1,ne Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 mor,ths prior to thi: start of the 120 month inspection interval, subject to the liinitations and modifications listed therein. The components t (including supports) may meat requirements set forth in subsequent editions and addenda of this Code which are ..icorporated by reference in i 10 CFR 50.55a(b) subject to the limitations and modifications listed ,
therein. The Licensee, Alabama Power Company, has prepared the Joseph H.
Farley Nuclear Power Plant, Unit 1, Second 10 Year Interval inservice ,
inspection (ISI) Program, through Revision 3, to meet the requirements of ,
the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examination for Code Class 1 and Code Clacs 2 piping welds has been determined by the 1974 Edition, Sungner 1975 Addends as ,
permitted and required by 10 CFR 50.55a(b). The second 10-year interval began December 1, 1987 and ends December 1, 1997.
Asrequiredby10CFR50.55a(g)(5),ifthelicenseedeterminesthatcertain :
Code examination requirements are impractical and requests relief from them, I
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the licensee shall submit information and justifications to the Nuclear Reguir, tory Commission (NRC) to support that determination.
Pursuant to 10 CF., 50.55a(g)(6), the NRC will evaluate the licensee's determinations under 10 Cf3 50.55a(g)(5) that Code requirements are impractical; alternatively, pursuant to 10 cfR 50.55a(a)(3), the licensee l must demonstrate that either (i) the proposed alternatives would provide an l
acceptable level of quality and safety or that (it) code compliance would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. The NRC may grant relief and may impose titernative requirements that are determined to be authorized by law, will j not endanger life or property or the common defense and security, and are )
otherwise in the public interest, giving due consideratien to the burden upon the licensee that could result if the requirements were imposed on the facility.
The information in the Joseph M. Farley Nuclear Power Plant, Unit 1, Second 10-Year Interval ISI Program, through Revision 2 (Reference 3), submitted September 9, 1988, was reviewed, including the requests for relief from the ASME Code Section XI requireinents which the Licensee has determined to be impractical. The review of the ISI Program was performed using the Standard :
Review Plans of NUREG-0800 (Reference 4), Section 5.2.4, " Reactor Coolant Boundary Inservice Inspections and Testing," and Section 6.6, " Inservice Inspection-of Class 2 and 3 Compnents."
In a letter dated August 3, 1.989 (Reference 5), the NRC requested additional information that was required in order to complete the review of the ISI Program.- Additional information was provided by the Licensee in letters dated October 5,1989 (Reference 6), December 7,19.89 (Reference 7), and April 12, 1990 (Reference 8). Revision 3 to the ISI Program was submitted in a letter dated August 15,1990 3eference 9). Corrections to Revision 3
- of three relief requests were submitted in a letter dated September 12, 1990 L (Reference 10),
l The Joseph M. farley Nuclear Power Plant, Unit 1, Second 19-Year Interval ISI Program is evaluated in Section 2 of this report. The ISI Program is 2
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evaluatedfor(a)compliancewiththeappropriateedi', ton /addendaof Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and j (d) compliance with ISI related commitments identified during previous NRC {
reviews, i i
The requests for relief are evaluated in Section 3 of this repcrt. Unless !
otherwise stated, references to the Code refer to the ASME Code,Section XI, !
1983 Edition, including Addenda thraugh Summer 1983. Specific inservice test (IST) programs for pumps and valves are being evaluated in other reports.
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- 2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN This evaluation consisted of a review of the applicable program documents to determine whether or not they are in compliance with the Code requirements and any license conditions pertinent to 151 activities. This section describes the submittals reviewed and the results of the review.
2.1 Documents Evaluated -
Review has been completed on the following information:
(a) Joseph M. Farley Nuclear Power Plant, Unit 1. Second 10 Year Interval 151 Program, Revision 0, submitted November 23, 1987 (Reference 11).
(b) Joseph M. Farley Nuclear Power Plant, Unit 1, Second 10-Year Interval ISI Program, Revisions 1 and 2, submitted September 9, 1988.
(c) NRC Inspection Report Nos. 50 248/88-17 and 50-364/88 17, dated June 1, 1988 (Reference 12).
(d) Letter, dated October 5, 1989, partial response to the NRC request for additional information.
(e) Letter, dated November 30, 1989, schedule for submitting the remaining response to the NRC request for additional information (Reference 13).
(f) lette , dated December 7, 1989, response to the NRC request for additional information.
(g) letter, dated April 12, 1990, additional information with regard to the ISI Program and relief requests.
(h) letter dated August 15, 1990, submittal of Revision 3 to the ISI Program.
(i) Letter, dated September 12, 1990, corrections to Revision 3 of relief requests RR-1, RR-2, and RR-3.
2.2 fornliance with Code Reauirements 2.2.1 Compliance with Acolicable Code Editioni 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). !
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Based on the starting date of December 1, 1987, the Code applicable
, to the second 10-year interval is the 1983 Edition, Summer 1983 Addenda. As stated in Section 1 of this report, the Licensee has prepared the Joseph M. Farley Nuclear Power Plant Unit 1. Second 10 Year Interval 151 Program, Revision 3, to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examination for Code Class 1 and Code Class 2 piping welds has been determined by the 1974 Edition, Summer 1975 Addenda as permitted and required by 10 CFR 50.55a(b).
2.2.2 Accentability of the Examination Samole Inservice volumetric, surface, and visual examinations shall be performed on ASME Code Class 1, 2, and 3 ccmponents and their supports using sampling schedules described in Section XI of the ASME Code and 10 CFR 50.55a(b). 10 CFR 50.55a(b)(3)(iv)(A) states that " Appropriate Code Class 2 pipe wolds in Residual Heat Removal Systems, Emergency Core Cooling Systems and Containment Heat Removal Systems shall be examined." The Licensee should be required to increase the number of volumetric examinations of Class 2 piping welds in the RHR, ECC, and CHR systems as only six Class 2 piping welds in these systems are scheduled for volumetric examination during the second 10-year inspection interval. This is not considered to be a prudent sample size for volumetric ;
examination.
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The Licensee should also be required to perform examinations of a sampling of the Class 2 piping welds in the Containment Spray System because these lines contain stagnant borated water and may l be susceptible to intergranular stress corrosion cracking. Other similar plants are performing augmented _ volumetric examinations of at least a 7.5% sampling of the welds in a single train between the Containment Spray pump and the first weld beyond the isolation valve inside containment.
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2.2.3 Exclusion Criteria The criteria used to exclude components from examination shall be consistent with Paragraphs IWB-1220, IWC-1220, IWC-1230, IWD 1220, and 10 CFR 50.55a(b). The exclusion criteria have been applied by the Licensee in accordance with the Code as discussed in the ISI Program and appear to be correct with the following exceptions:
(a)TheLicenseeshouldnotbepermittedtousethe" chemistry !
control" exemption in Paragraph IWC 1220(c) of the 1974 l Edition, Summer 1975 Addenda of Section XI. Other plants are !
not using this exemption as the control of '.sater chemistry to minimize stress corrosion is not an acceptable basis for >
exempting components from examination because practical l
evaluation, review, and acceptance standards cannot be defined. Operating data indicate that " chemistry control" has !
not' supported the exclusion; therefore, later editions and addenda of the Code have deleted the chemistry control }"
exclusion.
(b) A significant number of Class 2 welds in ECC, CHR, and RHR !
systems (e.g., Safety Injection System) have been exempted !
based on the pressure / temperature exemption in Paragraph ,
IWC-1220(a) of the 1974 Edition, Summer 1975 Addenda of '
Section XI. As noted above, 10 CFR 50.55a(b)(3)(iv)(A) states that " Appropriate Code Class 2 pipe welds in Residual Heat Removal Systems, Emergency Core Cooling Systems and Containment Heat Removal Systems shall be examined." The Licensee should ;
not exempt the ECC, CHR, and RHR systems from volumetric and ;
surface examinations based on the pressure / temperature exemption. As shown in later editions and addenda of the ASME
, Code Section XI and the NRC approved,ASME Code Case N 408, the l- pressure / temperature exemption is not allowed for the ECC, CHR, ,
and RHR systems. i f
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.. l 2.2.4 Auamented Examination Commitments In addition to the requirements as specified in Section XI of the ASME Code, the Licensee has committed to perform the following augmented examinations:-
(a) Reactor vessel examinations will be performed in accordance with NRC Regulatory Guide 1.150. Revision 1 (Reference 14),
(b) The reactor coolant-pump flywheel wil1 be inspected in accordance with plant Technical Specification 4.4.11.2 and NRC Regulatory Guide 1.14 (Reference 15).
(c) The steam generator tubing will be inspected in accordance with plant Technical Specification 4.4.6 and NRC Regulatory p Guide 1.83, Revision 1(Reference 16).
(d) Augmented examinations of portions of high energy lines in the Main Steam System will be performed.
2.3 Conclusions- ,
Based on the review of_ the documents listed above, it is concluded that the Joseph M. Farley Nuclear Power Plant, Unit 1,-Second 10 Year
! Interval. Inservice Inspection Program, through Revision 3, is considered unacceptable and not in compliance with 10 CFR 50.5Sa(g)(4) due to an_ unacceptable-examination sample'and unacceptable application of the exclusion criteria (see Sections 2.2.2 and 2.2.3 of this --
report).-
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- 3. EVALVATION OF RELIEF REQUESTS I r
The requests for relief from the ASME Code requirements that the Licensee I has determined to be impractical for the second 10-year inspection interval I are evaluated in the following sections. !
t 3.1 Class 1 Components l
. I 3.1.1 Reactor Pressure Vessq), ;
I 3.1.1.1 Recuest for Relief No. RR 8. Examination Cateaory B A. r item Bl.22. Reactor Prestgre Vessel Lower Head Meridional Weld ,
Code Reauirement: Section XI, Table IWB-2500-1, Examination $
Category B A, Item B1.22 require; a 100% volumetric examination of one of the reactor pressure vessel (RPV) meridional head f welds as defined by figure IWB-2500-3. l h
licensee's Code Relief Recuest: Relief is requested from l examining 100% of the Code required volume of one of the RPV ;
lower head peel segment meridional welds.
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Licensee's Pronosed Alternative Examination: None. The !
Licensee states that manual ultrasonic examination will be .
performed from the outside of the vessel to the maximum extent ,
on a best effort basis, i
.U.qgn;3e's Basis for Reapestina Rel_igf: The Licensee states !
l that incore instrumentation housings penetrating the vessel l bottom head limits coverage of the required volume and length ,
of the weld. 1 Evaluation: The reactor vessel lower head design incorporates penetrations for incore instrumentation. These penetrations
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l are located such that the length of a meridional head weld j cannot be examined 100%. The lower head design, therefore, ;
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makes the Code-required examination impractical to perform. In i
% order to examine the weld in ac:ordance with the requirements. l the reactor vessel lower head, and thus the reactor vessel, l would have to be redesigned, fabricated, and installed. The l increase in plant safety would not compensate for the burden l placed on the Licensee that would result from impositiot, of the !
r requirement. j The Licensee has stated that a manual ultrasonic scan of the l weld would cover in excess of 90% of the length of a meridional l head weld. The Licensee's proposal is to perform a manual i ultrasonic examination of the weld to the maximum extent 3 practical. This examination will provide adequate assurance l that unallowable inservice-flaws have not developed in the ]
lower head meridional welds or that they will be detected and !
removed or repaired prior to the return of the reactor vessel l 1 to service. f Conclusionst The volumetric examination of the lower head [
meridional welds in the reactor vessel-is impractical to !
_perf orm at Farley, Unit 1, to the extent required by Section XI '!Y of the ASME Code because of the close proximity of incore _ j
-instrument penetrations. Imposition of the requirements on !
Alabama Power Company would cause a burden that would not be- j compensated significantly by an-increase in safety above that i provided by the proposed examination. The proposed examination j will provide assurance that structural integrity of the reactor j vessel lower head is maintained. Therefore, it is concluded [
q that public health and safety will not be. endangered by- :l allowing the proposed examination to be performed in lieu of _ j the Code requirements. It is recommended that relief be '!
granted as requested.
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3.1.1.2 Reauest for Relief No. RR-14. Examir.ation Cateoory B G 1. - !
Item B6.40. Threads in the Reactor Pressure Vessel Flance i Code Reauireniqt: Section XI, Table IWB 2500 1, Examination l
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 Recueit: Relief is requested from j performing the Code-required volumetric examination of the i threads in the flange ligaments around each guide stud (Numbers l
26, 42, and 58) as well as the threads in the flange ligaments between the stud holes on either side of the guide studs ,
(Numbers 1, 25, 27, 41, 43, and 57).
t Licensee's Proposed Alternative Examination: None. The l Licensee states that the threads in the remaining 49 flange [
ligaments will be ultrasonically examined as required by the i ASME Code. !
Licensee's Basis for Recuestino Relief: The Licensee states !
that, during the examination, these guide studs prevent the -
ultrasonic transducers mounted on the remote tool arm from accessing the threads in the flange ligaments around each guide f stud as well as the threads in the flange ligaments between the !
stud holes on either side of the guide studs.
Evaluation: To facilitate safe removal and reinsta11ation of the RPV head and positioning of the remote RPV examination tool, three guide studs are installed in stud holes. During -
the ultrasonic examination performed by the remote tool, the guide studs prevent the ultrasonic transducers mounted on the remote tool arm from accessing the threads in the flange i ligaments around each guide stud as well as the threads in the flange ligaments between the stud holes on either side of the guide studs. The presence of the three guide studs, therefore, 10 l
, . i makes the Code required examination impractical to perform using the remote inspection tool. In order to examine the j subject threads in the RPV flange in accordance with the requirements, manual ultrasonic examination would be required :
which would result in personnel receiving excessive radiation l exposure. The increase in plant safety would not compensate i for the burden placed on the Licensee that would result from !
imposition of the requirement. -
t Alabama Power has stated that the remote ultrasonic inspection tool will examine the remaining 49 (84.5%) out of the 58 l threads in the flange. Alabama Power Company's proposal is to ;
perform ultrasonic examination of the remaining 49 threads in i the RPV flange using the remote RPV examination tool. This ;
examination will provide adequate assurance that the flange [
-threads have not developed unallowable inservice flaws or that unallowable inservice flaws will be detected and removed or i repaired prior to the return of the reactor vessel to service.
Conclusions:
The volumetric examination of the threads in the reactor vessel flange is impractical to perform at farley, :
Unit 1, to the extent required by Section XI of the ASME Code l because of the presence of three guide studs. Imposition of i
'the requirements on Alabama Power Company would cause a burden ;
that would not be compensated significantly by an increase in ,
safety above that provided by the proposed examination. The proposed examination will provide assurance that structural ;
integrity of the reactor vessel flange is maintained. l Therefore, it is concluded that public health and safety will ,
not be endangered by allowing the proposed examination to be performed in lieu of the Code reauirements, it is recommended ,
that relief be granted as requested.
[
l i
I I
[
11
i 3.1.2 Pressurizer i 3.1.2.1 Reouest for Relief No. RR-9. Examination Cateaory B D. Item 83.110. Pressurizer Norzle-to Vessel Welds i
Code Reauirement: Section XI, Table IWB-25001, Examination ;
Category B D, item B3.110 requires a 100% volumetric examination of the pressurizer nozzle to vessel welds as defined by Figure IWB 2500-7(b).
Licensee's Code Relief Reouest: Relief is requested from examining 100% of the Code required volume of the pressurizer nozzle to vessel welds.
Licensee's Proposed Alternative Examination: The Licensee states that all of these welds will receive a surface examination of the areas not receiving an ultrasonic examination.
Licensee's Basis for Reouestino Relief: There is unrestricted access to perform examination of the required volume of both weld and base metal from the head side of these welds, Fowever, the Licensee states that the geometric configuration of all six nozzles pr) vents ultrasonic exe.mination from the nozzle side of
- the weld to the extent required. While the required volume of I
l weld metal can be examined, only approximately 25% of tne base metal on the nozzle side of the weld can be examined.
Evaluation: The sketch included in the Licensee's relief request shows that the geometric configuration of the pressurizer nozzles is such that the pressurizer nozzle-to vessel welds cannot be examined 100%. The pressurizer nozzle design, therefore, makes the Code required examination impractical to perform. In order to examine the welds in accordance with the requirements, the pressurizer nozzles, and thus the pressurizer, would have to be redesigned, 12
o .
y L
fabricated, and installed. The increase in plant safety would not compensate for the burden placed on the Licensee that would ;
result from imposition of the requirement. !
I The Licensee has stated that all of the weld volume, the base j metal on the vessel side of the weld, and approximately 25% of i the base metal on the nozzle side of the weld are unrestricted; i therefore, a significant percentage of the weld and base metal -
would be examined. The Licensee's proposed alternative is to !
perform the ultrasonic examination of tho weld to the maximum !
extent practical and a surface examination of the areas not receiving an ultrasonic examination. These examinations will [
provide adequate assurance that the pressurizer ;
nozzle-to vessel welds have not developed unallowable inservice l flaws or that unallowable inservice flaws will be detected and l removed or repaired prior to the return of the presturizer to service. ,
Conclusions:
The volumetric examination of the !
nozzle to-vessel welds in the pressurizer is impractical to perform at Fariey, Unit 1, to the extent required by Section XI l of the ASME Code bscause of the geometric configuration of the t
nozzles. Impositien of the requirements on Alabama Power Company would cau:0 a burden that would not be compensated !
significantly by an increase in safety above that provided by i the proposed alternative, lhe proposed alternative examination will provide assurance that structural-integrity of the pressurizer is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code i requirements. It is recommend (d that relief be granted as ;
requested, s I
13 t
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o ,
3.1.3 Heat behanaers and Steam Generators 3.1.3.1 Recuest for Relief No. RR-10. Examination Calenorv B-F. Item B5.70. Steam Generaior Nozzle-to Pine Safe End Welds Code Reauirement: Section XI, Table IWB-25001, Exan.ination Category B F, item B5.70 requires both 100% volumetric and surface examinations of the steam generator nozzle to safe end butt welds nominal pipe size 4 inches and greater as defined by Figure IWB-2500 8.
Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code required volume of the steam generator nozzle-to safe end welds.
Licenste's Pronosed Alternative Examination: None. The Licensee states that surface examinations of the required area will be performed. Also, ultrasonic examinations will be performed from both the pipe and weld surfaces as allowed by T-532 of Section V. All of the weld metal, including the weld root, will be examined.
Licensee's Basis for Recuestina Relie{: The Licensee states that examination of these welds is limited both by nozzle geometry and the presence of a weld deposited clad overlay on the safe end nozzle interface. Ultrasonic examinations can be performed from the pipe side and the weld surface but are severely limited from the nozzle side by the rough, as cast surface and the clad overlay. Coverage of approximately 90% of the required volume is achieved from the pipe side of the weld.
Evaluation: The sketch included in the Licensee's relief request shows that the nozzle geometry and the presence of the as-welded clad overlay at the nozzle-to-safe end interface are such that the volume of the steam generator nozzle-to-safe end welds cannot be examined 100%. The steam generator nozzle 14 I
e ,
design, therefore, makes the Code required examir ation impractical to perform. In order to examine the nozzle to safe end welds in accordance with the requirements, the steam generator nozzles, and thus the steam generators, would have to be redesigned, fabricated, and installed. 1he increase in plant safety would nnt compensate for the burden placed on the Licensee that would result from imposition of the requirement.
The Licensee has stated that the ultrasonic examination would cover all of the weld metal, including the weld root; coverage of approximately 90% of the required volume is achieved from the pipe side of the weld. Alabama Power Company's proposal is to perform an ultrasonic examination from both the pipe and weld surfaces as allowed by T 532 of Section V, along with the Code required surface examination. These examinations will provide adequate assurance that unallowable inservice flaws have not developed in the steam generator nozzle-to-safe end welds or that they will be detected and removed or repaired prior to the return of the steam generators to service.
Conclusions:
The volumetric excmination of the steam generators nozzle-to-pipe safe end welds is impractical to perform at Farley, Unit 1, to the extent required by Section XI of the ASME Code because of the geometric configuration of the nozzles and the presence of the as-welded clad overlay at the nozzle-to safe end interface, imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed examination. The proposed examination will provide assurance that structural integrity of the steam generator nozzle-to-safe ends is maintained. Therefore, it is concluded that public realth and safety will not be endangerec, by allowing the propostd examination to be performed in lieu of the Code requirements. it is recommended that relief be granted as requested.
I 15
3.1.3.2 Reouest for Relief No. RR-11. Examination Cateaory B D. Iteni, i B3.140. Steam Generator Inlet and Outlet Nozzle Inner Radius Sections !
Code Reauirement: Section XI. Table IWB-2500-1, Examination I Category B 0, item B3.140 requires a 100% volumetric examination of the steam generator (primary side) nozzle inside !
radius sections as defined by Figure,IWB-2500 7.
Licensee's Code Relief Reauest: Relief is requested from performing the Code required volumetric examination of the inlet and outlet nozzle inner radius sections of steam generators IA, IB, and 10. !
Licensee's Pronosed Alternative Examination: The Licensee ;
states that the inside surface of each steam generator primary side nozzle inner radiused section will be visually examined. i The examination area will include the inner radius surface region .hown in Figure IWB-2500-7 of Section XI to the extent ;
practical. [
l Licensee's Basis for Recuestina Relief: The Licensee states that the steam generator primarp side nozzles are integrally ;
cast as part of the channel head; therefore, no welds exist t that require volumetric examination. The steam generator ;
nozzle inner radiused section cannot be volumetrically examined )
from the outside of the nozzle or channel head because the rough, as-cast contact surface is not suitable for ultrasonic coupling and the geometrical configuration requires an excessively long test metal distance resulting in high !
I ultrasonic attenuation. The areas inside of the nozzles and channel head are covered with cladding in the "as-welded" condition; therefore, the associated surface contours and ;
roughness do not provide the conditions necessary to perform l the examination. Even with proper preparation of the inside surface for volumetric examination, an adequate examination of .
l 16 ,
f f
the area of interest (base metal just below the cladding) could not be achieved due to the resulting ultrasonic response at the clad-to base metal interface.
Evaluation: The steam generator nozzle sections at Farley, Unit 1, were not designed for external examination of the inside radius using ultrasonic methods. The component geometry and the as-cast surface of the steam. generator heads, along with-the excessively long test metal distance that result.s in high ultrasonic attenuation, preclude the volumetric l examination of the nozzle inside radius section from the ,
external surface. The steam generator nozzle design, i therefore, makes the Code-required examination impractical to ;
perform. In order to examine the nozzle inside radius sections in accordance with the requirements, the steam generator nozzles, and thus the steam generators, would have to be redesigned, fabricated, and installed. The increase in plant i i
safety would not compensate for the burden placed on'the Licensee that would result from imposition of the requirement.
Surface examination is not practical to perform because of the ;
rough surfaca of the as-welded cladding and because inspection personnel would receivo excessive radiation exposure.
Alabama Power Company's proposed alternative is to perform a visual. examination of the ir. side surface of each steam generator primary side nozzle inner radiused section to the maximum extent practical. This examination will provide reasonable. assurance that- the steam generator nozzle inner radius' sections have not developed unallowable inservice flaws ,
or that unallowable inservice flaws will be detected and -
removed or_ repaired prior to the return _of the steam generators ,
to service.
- i.
Conclusions:
The volumetric examination required by Section XI of the ASME Code for the nozzle inside radius sections in the
- - - steam generators is impractical. to perform at Farley, Unit 1,-
17
= ... .
. - - - , . . - ..a.--._ -- - - . . - . , _ - -.
l because of the component geometry and the as-cast surface of the steam generator heads, along with the excessively long test i metal distance that results in tigh ultrasonic attenuation. !
Imposition of the requirements on Alabamt. Power Company would ,
cause a burden that would not be compensated significantly by i an increase in safety above that provided by the proposed !
alternative. The proposed alternative examination will provide f assurance that structural integrity of the steam generator nozzles is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the !
alternative examinaticn to be performed in lieu of the Code requirement. It is recommended that relief be granted as :
requested. l 3.1.4 Pioina Pressure Boundary
{
3.1.4.1 Recuest for Relief No. RR-13. Examination Cateaory B-J. Item B9.31. Class 1 Branch Pine Connection Welds Code Reauirement: Section XI, Table IWB-2500-1, Examination !
Category B-J, Item B9.31 requires both 100% volumetric and f
surface examinations of the Class i branch pipe connection welds nominal pipe size 4 inches and greater as defined by f Figures IWB-2500-9, -10, and -11. _
l Licensee's Code Relief Reauest: Relief is requested from ;
examining 100% of the Code-required volume of the following Class 1 branch pipe connection welds:
(
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18 +
m-- , -- -- - - - - - - ,. _ 4 ,- . . - -
e ,
1 Weld Number Confiourations ISBC Hot leg loop #1, 6-inch branch connection 16BC Hot leg loop fl. 12-inch branch connection 20BC Cold leg loop #1, 6-inch branch connection 21BC Cold leg loop #1, 4-inch branch connection 22BC Cold leg loop #1, 12-inch branch connection 15?C Hot leg loop #2, 6 inch branch connection 16BC Hot leg loop #2, 14-inch branch connection 20BC Cold leg loop #2, 4-inch branch connection 218C Cold leg loop #2, 12-inch branch connection 23BC Cold leg loop #2, 6-inch branch connection ISBC Hot leg loop #3, 6-inch branch connection 16BC Hot leg loop #3, 12-inch branch connection 20BC Cold leg loop #3, 6-inch branch connection 21BC Cold leg loop #3, 12-inch branch connection Licencu's Proposed Alternative Examination: None. The Code required surface examinations will be performed, and the volumetric e,tamination will be performed to the maximum extent possible.
Licensee's Basis for Reouestino Relie.[: The Licensee states that the geometric configuration of these welds prevents ultrasonic examinations from being performed from the weld surfaces. Approximately 80% of the Code-required volume can and will be examined.
Evaluation: The Class 1 branch pipe connection design is shown in the sketch attached to the Licensee's relief request. The geometric configuration is such that the Code-required volume of the branch pipe connection welds cannot be examined 100%.
The subject Class 1 branch pipe connection design, therefore, makes the Code-required examination impractical to perform. In order to exaraine the weld in accordance with the requirements, these branch pipe connections would have to be redesigned, fabricated, and installed. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.
The Licensee has stated that the ultrasonic examination of the welds would cover approximately 80% of the Code-required volume i
19
of the subject branch pipe connection welds. The Licensee's proposal is to perform the volumetric examination of the welds to the maximum extent practical, along with the Code required surface examination. These examinations will provide adequate assurance that unallowable inservice flaws have not developed in the Class 1 branch pipe connection welds or that they will be detected and removed or repaired prior to the return of these lines to service. .
Conclusions:
The volumetric examination of the subject Class 1 branch pipe ccnnection welds is impractical to perform at farley, Unit 1, to the extent required by Section XI of the ASME Code because of the geometric configuration of the branch pipe connections. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed examir.ation. The proposed examination will provide assurance that structural integrity of these lines is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the proposed examination to be performed in lieu of the Code requirements.
It is recommended that relief be granted as requested.
l 3.1.5 Pumn Pressure Boundary L
3.1.5.1 Reauest for Relief No. RR-15. Examination Cateoory B-L 2. Item B12.20. Reactor Coolant Pump Internal Pressure BouDdary L
Surfaces
{_qde Reouirectat: Section XI, Table IWB 2500-1, Examination Category B L 2, Item B12.20 requires a 100% visual (VT 3) l examination of the Class 1 pump casing internal surfaces.
L Examinations are limited to at least one pump in each group of pumps performing similar functions in the system.
20 l
4 .
Licensee's Code Relief Reacest: Relief is requested from performing the Code required visual (VT-3) examination of the internal surfaces of a reactor coolant pump (RCP).
Licensee's Proposed Alternative Expination: None. The Licensee states that the exterior of the RCP casing will be visually examined during the RCS hydrostatic pressure test as required by IWD-5000. A visual examination, not to exceed once per interval, will be performed on the internal pressure boundary surface of one RCP as required by the Code, if maintenance or operational problems are encountered which require the remov.1 and disassembly of the internals.
Licensee's Basis for Recuer,,tino Relief: The Licensee states that disassembly of a reactor coolant pump for the visual examination during the inspection interval in the absence of required maintenance represents an unnecessary exposure to radiation and contamination and violates ALARA guidelines for occupational dose rates. In view of the cost in man rem and the minimal benefits obtained, the Licensee concludes that this Code requirement does not provide sufficient benefits to justify the radiation exposure.
Evaluation: The examination requirement for internal surfaces of pumps necessitates complete disassembly of the pump. The disassembly of the reactor coolant pumps for the sole purpose of visual examination of the casing internal surfaces is a f
major effort and requires many manhours from skilled maintenance and inspcction personnel.. In order to examine the internal surfaces of a reactor coolant pump in accordance with the requirements, complete disassembly of the pump would be required which, in addition to the possibility of damage to the ;
pump, would result in personnel receiving excessive radiation f exposure. Therefore, the Code requirement is impractical. The j visual examination is performed to determine if unanticipated l severe degradation of the casing is occurring due to phenomena 21 r
- - . .y, ,-- ,.-,--_.-_.m.. ww..._--c-r-,c,. , .-m-,- ,y. . , -.,,_,.,-r.- -+-,--c- ,.-,,,-,,-_---,,,,---,m..-- .
such as erosion, corrosion, or cracking. However, previous experience during examination of similar pumps at other plants has not shown any significant degradation of pump casings. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.
Alabana Power has stated that, in addition to the Code required visual examination of the exterior of the reactor coolant pump casing during the hydrostatic test, the Code-required visual extmination will be performed on the internal pressure boundary surface of one reactor coolant pump if maintenance or operational problems are encountered which require disassembly of the pump such that access for conducting the examination is provided.
Later editions and addends of the ASME Code (1988 Addenda) have eliminated disassembly of. pumps for the sole purpose of performing examinations of the internal surfaces and states that the internal surface visual examination requirement is only applicable to pumps that are disassembled for reasons such as maintenance, repair, or volumetric examinatton. Therefore, the concept of visual examination of the internal surfaces of the pump casing, if the pump is disassembled for maintenance, is acceptable. Since no major problems have been reported in the industry with regard to pump casings, the Licensee's proposal will provide adequate assurance of the continued inservice structural integrity.
Conclusioni: The disassembly of a pump for the sole purpose of inspection is impractical to perform at Farley, Unit 1, because this activity, in addition to the possibility of damage to the pump, would result in personnel receiving excessive radiation exposure. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by 22
the proposed examination. Therefore, it is concluded that public health and safety will not be endangered by allowing the proposed examination to be performed in lieu of the Code requirement. It is recommended that relief be granted provided that, if the pump has not been disassembled, this fact should be reported by the Licensee in the ISI Summary Report at the i end of the interval. ,
3.1.6 Valve Pressure Boundary l
i 3.1.6.1 Reuuest for Relief No. RR-16. Examination Cateaory B M-2.11.ca_
B12.50. Internal Pressure Boundary Surfaces of Class 1 Valves Code Reauirement: Section XI, Table IWB-2500-1, Examination }
Category B M-2, item B12.50 requires a 100% visual (VT-3) !
examination of the internal surfaces of Class 1 valve bodies !
exceeding 4 inches nominal pipe size. !
Licensee's Code Relief Recuest: Relief is requested from ;
performing the Code-required visual (VT-3) examination of the internal surfaces of one valve in each of the following groups I
of Class 1 valves:
Group No. Manufacturer System Description 5 1 Copes-Yulcan RHR 12-inch gate valve !
2 Velan RHR (Low head 6-inch check valve ,
safety injection) '
3 Velan RHR (High head 6-inch check valve :
safety injection) 4 Crosby Pressurizer safety 6-inch safety valve !,
5 Copes Vulcan Accumulator discharge 12-inch check valve Licensee's Proposed Alternative Examination: None. The !
Licensee states that the exterior of the valve body will be .!
visually examined during the RCS hydrostatic test. A visual !
examination, not to exceed once per interval, will be performed i on the internal pressure boundary surface of one valve in each ,
l i 23
. ,-r . - - - , , - .
+ .
group listed above as required by the Code if maintenance or operational problems are encoutitered which require disassembly and complete removal of the valve internals.
Licensee's Basis for Recuestina Relief: The Licensee states that disassembly of these valves for visual examination during the inspection interval in the absence of required maintenance represents an unnecessary exposure to radiation and contamination and violates ALARA guidelines for occupational dose rates. In view of the cost in man rem and the miaimal benefits obtained, the Licensee concludes that this Code requirement does not provide sufficient benefits to justify the radiation exposure. In addition, the manufacturer of these valves neither recommends nor requires valve disassembly for the performance of routine maintenance or inspections.
Evaluation:- The examination requf mant for internal surfaces of valve bodies necessitates complete dsassembly of the valve. The disassembly of the subject valves for the scle purpose of visual examination of the valve body internal surfaces is a major Effort and raquires many manhours from skilled maintenance and inspection personnel. In order to examine the internal surfaces of a valve body in accordance with the requirements, complete disassembly of the valve would be required which, in addition to the possibility of damage to <
the valve, would result in personnel receiving excessive !
radiation exposure. Therefore, the Code requirement is >
impractical. The visual examination is performed to determine if unanticipated severe degradation of the valve body is ,
occurring due to phenomena such as crosion, corrosion, or ,
cracking. However, previous experience during examination of similar valves at other plants has not shown any significant degradation of valve bodies. The increase in plant safety would not compensate for the burden placed on the Licensee _ that would result from imposition of the requirement. l t
24
- - _ . -- - . .- __,_. _ - _ - . - , - ~ . . _.
l Alabama Power has stated that, in addition to the Code-required visual examination of the exterior of the valve body during the hydrostatic test, the Code required visual examination will be performed on the internal pressure boundary surface of one valve in each of the groups of valves listed above if maintenance or operational problems are encountered which require disassembly of the valve such that access for conducting the examination is provide.d.
Later editions and addenda of the ASME Code (1988 Addenda) have eliminated disassembly of valves for the sole purpose of performing examinations of the internal surfaces and states that the internal surface visual examination requirement is only applicable to valves that are disassembled for reasons such as maintenance, repair, or volumetric examination.
Therefore, the concept of visual examination of the internal surfaces of the valva body, if the valve is disassembled for maintenance, is acceptable. Since no major problems have been reported in the industry with regard to valve bodies, the Licensee's proposal will provide adequate assurance of the continued inservice structural integrity.
Conclusions:
The disassembly of a valve for the sole purpose of inspection is impractical to perform at Farley, Unit 1, because this activity, in addition to the possibility of damage to the valve, would result in personnel receiving excessive radiation exposure. Imposition of the requirements on Alabama f
Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed examination. Therefore, it is concluded that public health and safety will not be endangered by allowing the proposed examination to be performed in lieu of the Code requirement, it is recomended that relief be granted l
provided that, if the valve has not been disassembled, this fact should be reported by the Licensee in the ISI Summary Report at the end of the interval, 25 1
3.1.7 General (No relief requests) i 3.2 Class 2 Comnonents .
3.2.1 Pressure Vessels j 3.2.1.1 Reauest for Relief No. RR-18. Examination Cateaory C.A. Items i C1.20 and C1.30. Pressure Retainina Welds in the Recenerative Ritat Exchanaer :
Code Reauirem.,gnt: Section XI, Table IWD 2500-1, Examination ;
Category C-A, Items C1.20 and C1.30 require a 100% volumetric examination of the head-to shell weld and tubesheet to-shell weld in Class 2 pressure vessels as defined by :
Figures IWC-2500 1 and 2.
Licensee's Code Relief Reouest: Relief is requested from examining 100% of the Code-required volume of the regenerative heat exchanger welds 1 through 12.
Licensee's Proposed Alternittive Examination: The Licensee -
states that ultrasonic examination will be performed to the !
maximum extent practical (approximately 50 to 60%) on a best l effort basis. Surface examination will also be performed to :
supplement the volumetric examinations. (
Licensee's Basis for Reauestina Relief: The Licensee states f that the regenerative heat exchanger shell is fabricated from j centrifuga11y cast austenitic steel material, which limits ultrasonic examination to the half node technique. In '
addition, the geometric configuration of the weld surface and the location of adjacent nozzles and supports provide limitations to the extent of the examination coverage.
Approximately 50 to 60% of the required volume can be examined. ;
26 i
?
O . f Evaluation: The regenerative heat exchanger is fabricated from centrifuga11y cast austenitic steel material. Ultrasonic !
examination of this material is limited to the half node l
technique. Also, the geometric configuration of the weld i surface and the location of adjacent nozzles and supports are !
such that the Code required volume of the subject regenerative f heat exchanger welds cannot be fully examined. These conditions, therefore, make the Code required examination i impractical to perform. In order to examine the welde in 1
. accordance with the requirements, the regenerative heat l exchanger would have to be redesigned, febricated, and !
installed. .The increase in plart safety would not compensate f for the burden placed on the Licensee that would result from l
imposition of this requirement. !
Alabama Power has stated that the approximately 50 to 60% of the Code required volume can be examined. Alabama Power Company's proposed alternative is to perform ultrasonic examination of the these welds to-the maximum extent practical on a best effort basis, along with a supplemental surface examination. These examinations will provide adequate assurance that the regenerative heat exchanger welds have not developed unallowable inservice flaws or that unallowable inservice flaws will be detected and removed or repaired prior to the return of the regenerative heat. exchanger-to service.
Conclusions:
The volumetric examination of the welds in the regenerative heat exchanger is impractical to perform at n Farley, Unit 1, to'the extent required by Section XI-of the l
l- ASME Code recause of the centrifuga11y cast austenitic steel .
material,.the geometric configuration of thL weld surface, and the location of adjacent nozzles and supports. Imposition of the re_quirements on Alabama Power Company would cause a burden L that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The 27
proposed alternative examination will provide assurance that structural integrity of the regenerative heat exchanger is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Cod: requirements, it is recommended that relief be granted as requested.
3.2.1.2 Reauest for Relief No. RR-19. Examination Cateoory C-A. Items (1,10 apd C1.20. Class 2 Pressure Ygssel Weld),
Code Recuirement: Section XI, Table IWC-2500-1, Examination Category C-A, items C1.10 and C1.20 require a 100% volumetric examination of the shell c.tcumferential welds and head-to-shell circumferential welds in Class 2 pressure vessels as defined by Figure IWC-2500-1.
Licensee's Code Relief Renuest: Relief is requested from performing the Code-required volumctric examinat',on of the head-to shell and flange-to-shell welds in the following thin wall Class 2 pressure vessels:
Seal Water Heat Exchanger Letdown Reheat Heat Exchanger Reactor Coolant Filter Seal Water Return Filter Licensee's Proc.gsed Alternative Etaminatign: The Licensee states that the welds on these components will be examined by surface and visual methods, licensee's Basis for Reauestina Relief: The Licensee states that the thickness of the materials utilized for the construction of these components (0.165 to 0.188 inches) is such that meaningful results could not be expected with ultrasonic examination.
28
. , .y _ _ _ _ .- .. _. _ _ _ _ - - _ _ _ . _. _ __ _
4' ; Q_ g 1
i Iv Evaluation: Alabama Power Company's proposed alternative-is to j, perform surface;and visual.examinationsiof the welds on these c
. vessels 1; lieu of the Code-required volumetric examination. '
2 It is stated in ASME Code Case N-435-1, " Alternative
. Examination Requirements for Vessels With Wall Thickness 2 Inch
- or Less " that,. for welds in vessels with nominal- wall
. thickness of 1/5 inch or less, surface examination may.be
[ applied in lieu of volumetric examint. tion. Code Case N-435-1
[ isl11sted as-an acceptable code case in NRC Regulatory 1
- Guide 1.147, " Inservice Inspection Code Case Acceptability,
[ ASME Section XI, Division 1," Revision 7 (Reference 17), and,
. therefore, may-be used without requesting-relief.
t
[
Conclusions:
The-Licensee's proposed examination is an B acceptable alternative based on ASME Code Case N-435-1 and NRC i- Regulatory Guide 1.147. Therefore, relief is not required. -
L 3.2.1.3 .Recuest for Rt11ef No. RR-28. Examination Cateaory C-B. Item
- i. C2.22. Class 2 Steam Generator Nozzle Inside Radius Sections l:
Code Feautrement: - Section~ XI, Table IWC-2500-1,- Examination Category C-B, item C2.22 requires a 100% volumetric examination
- of the nozzle inside radius se-tions of ectzles in Class 2 vessels of 1/2 inch.or less nt 4inal wall thickness as defined :
by Figure IWC-2500-4(a) or_(b).
Licensee's Code Relief Reauest: Relief is requested- from performing the Code-required volumetric examination of the nozzle-inside radius section of the steam outlet-nozzle.cn the steam generators.
Licensee's Proposed Alternative Examinatt.i.gn: None.
Licensee's Basis for Reauestinc Relief: The Licensee states
-that:the steam outlet nozzle is manufactured from a solid 29
\
forging with seven holes, each 8 1/2 inches in diameter, drilled through the forging to provide flow restriction. The geometry of this nozzle with the drilled flow restrictor holes does not have an inner radius and, therefore, no meaningful examination can be perfor.ned.
Evaluation: As shown in the sketch attached to the relief request, the steam outlet nozzle was. designed with an internal multiple hole type flow restrictor. This design does not use a radiused nozzle as described in Figure IWC-2500-4, but instead has several individual inner radii, corresponding to each hole. Therefore, the design of the nozzle is not applicable to the Code requirerant. Alabama Power Company has demonstrated that complianc; with this Code requirement would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
Conclusions:
Based on the above, it is concluded that the design of the steam generator nozzle is not applicable to the Code requirement. Therefore, pursuant to 10 CFR 50.55a(a)(3),
it is recommended that relief be granted as requested.
3.2.2 Pinina (No relief requests) 3.2.3 Pumns 3.2.3.1 Reauest for Relief No. RR-20. Examination Cateaory C-C. Item C3.30. Class 2 Intearally Welded Attachments on Charaina Pumns Code Reauirement: Section XI, Table IWC-2500-1, Examination Category C-C, Item C3.30 requires a 100% surface examination of the integrally welded attachments of Class 2 pumps as defined by Figure IWC-2500-5.
30
. .. 1
a .
Licensee's Code Relief Reouest: Relief is requested from examining 100% of the Code-required surface of the integrally welded attachments CS-1, -2, 3, and -4 on each of charging pumps lA, IB, and IC.
Licensee's Proposed Alternative Examination: None. The Licensee states : hat all accessibia portions of welded attachments will receive a surface examination supplemented by a visual examination.
Licensee's Basis for Reouestina Relief: The Licensee states that, due to the component configuration, location, and supnort design, approximately 20% of each integrally welded attachment is inaccessible for examination.
Evaluadun: The drawings included in the Licensee's relief request show that the component configuration, location, and support design are such that the Code-required surface of the charging pump integrally welded attachments cannot be fully examined. There conditions, therefore, make the Code-required examinat$an impractical to perform. In order to examine the charging pump integrally welded attachments in accordance with the requirements, the pump supports would require design modifications. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.
The Licensee has stated that the surface examination would cover approximately 80% of the required surface area. Alabama Power Company's proposal is to perform a surface examination of all accessible portions of the welded attaci,ments, along with a supplemental visual examination of the uninspected portions.
These examinations will provide adequate assurance that unallowable inservice flaws have not developed in the pump integral attachment welds or that they will be detected and removed or repaired.
31
- - - - - - - - - - - - - - - - - - _ a
s .
I
[gnelusions: The surface examination of the charging pump integrally welded attachments is impractical to perform at Farley, Unit 1, to the extent required by Section XI of the ASME Code because of the component configuration, location, and support design. Imposition of the requirement on Alabama Power Company would cause a burden that would not te compensated significantly by an increase in safety above that provided by the proposed examination. The proposed examination will provide assurance that structural integrity of the charging pump integrally welded attachments is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the proposed examination to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested.
3.2.4 Valves (No relief requests) 3.2.5 General (No relief requests) 3.3 []as3 3 Components (No relief requests) 3.4 Pressure Tests 3.4.1 Class 1 System Pressure Tests (No relief requests) 3.4.2 Class 2 System Pressure Tests 3.4.2.1 Reauest for Relief No. RR-21. Hydrostatic Test of Class 2
[pntainment Pressure Sensina lines in the Safety iniection System Code Reauirement: Section XI, Table IWC-2500-1, Examination Category C-H, Item C7.40 requires a hydrostatic test of all Class 2 pressure retaining components once every 10-year inspection interval in accordance with IWC-5222.
32
1 a .:
I Licensee's Code Relief Reauest: Relief is requested from performing the Code-required hydrostatic test of the' Class 2 containment pressure sensing lines in the safety injection system.
Licensee's Proposed Alternative Examination: The Licensee
, states that the calibration of these sensors will be performed in lieu of a hydrostatic or pressure test.
Licensee's Basis for Reauestino Relief: The Licensee states that _these containment pressure sensing capillaries are filled with silicone oil and aro sealed. There are no provisions to '
. pressurize these lines with additional silicone oil to satisfy the ASME Faction XI hydrostatic test' requirements. However, a
-full range (0 to 65 psi for low pressure sensors and 0 to 225 psi-for high pressure sensors) calibration is performed on these lines every 18 months to verify their accuracy and integrity, in accordance with Farley Surveillance Test Procedures STP-220.1 through 220.4, STP-220.ll, and STP-220.12
-(T.S. 4.3.3.8/68). Any leakage from these pressure sensing lines during normal operation would result in instrument .
failure and would be corrected to ma'..tain instrument operability.
Evaluation: -The design of Class 2 containment pressure sensing lines in the safety injection system is such that the lines are filled with silicone oil and are sealed. There are no-provisions to pressurize these lines with additional silicone oil to satisfy the Code. requirements. -The design of these lines, therefore, makes the Code-required hydrostatic test impractical to perform. In order to perform the hydrostatic testiin accordance with the requirements, these lines would have to be modified to include test connections. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of this rt.quirement.
33
l The Licensee's proposal to perform the calibration of these sensors in lieu of the hydrostatic test will provide reasonable assurance of the continued inservice structural integrity as leakage of these lines would be identified.
Conclusions:
The hydrostatic test required by Section XI of the ASME Code for the Class 2 containment pressure sensing lines in the safety injection system is impractical to perform at farley, Unit 1, because these lines are filled with silicone oil and are sealed, with no provisions to pressurize these lines with additional silicone oil. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative examination will identify a leak in these pressure sensing lines thus providing assurance that structural integrity of these lines is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested.
3.4.2.2 Reauest for Relief No. RR-22. Hydrostatic Test of portions of Class 2 Pioina and Interim Comnonents at Reduced Pressure Code Reauirement: Section XI, Table IWC-2500-1, Examination Category C-H requires a hydr;. 6tc test of all Class 2 pressure retaining components once every 10-year inspection interval in accordance with Paragraph IWC-5222.
Licensee's Code Relief Reauest: Relief is requested from performing the Code-required hydrostatic test of the following portions of Class 2 piping:
(a) Chemical Injection to Main Feedwater lines between valves Q1N25V002A, B, and C and Main Feedwater lines (line Nos. DCB-1A, DCB-1B, and DCB-lC).
34
I 4 4 (b) Main'Feedwater lines from valves Q1N21V001A, B, and C to the Steam Generators (line No. DBB-1).
-(c) Steam Generator blowdown lines to valves Q1G24V003A, B,-
_ and C from the Steam Generators-(line Nos. CBB-5, CBB-6, CBB-7,_CBB-8, CBB-9,-.and CBB-10). 'J
- (d) ' Auxiliary Feedwater. piping from valves Q1N23V0llA, B,=and-C to the Main Feedwater lines (line No. DBB-2).
(e) Charging Pump discharge mini-flow piping from valves i QlE21V259A, B, and C up-to valve' Q1E21V265 (line No. 1
-CCB-18).
Items-(a) through-(d) are nonisolable-piping associated with j the steam generators, secondary side. LTesting at reduced
- holding time is addressed in relief request RR-30.- _
-Licensee's Proposed-Alternative Examination: The Licensee states that visual examination for evidence of leakage will be
-conducted on the' portions of Class 2 systems-listed above while j
, - at the test pressure for the-lowest pressure rated Class 2 1 piping.
~!
Licensee's Basis- for Reouestino Relief: The Licensee states that'the~ portions of the Class 2 systems listed above cannot be isolated- from lower pressure rated Class.2 piping. Performing hydrostatic: tests at the required pressure ~would result in.
overpressurizing.the lower pressure rated Class 2-piping.
i -Evaluation: The design of'the system does not provide adequate g-shutoff boundaries to prevent overpressurization of the lower l -pressure rated Class 2 piping. The' design of these lines,-- a I therefore, takes the Code-required hydrostatic test-impractical- _
t to perform.- In order to perform the hydr _ostatic test-in
.accordance'with the requirements, these lines would have to be modified to be isolatable from lower pressure rated Class 2' q l: ' piping. The-increase in' plant safety would not compensate for ,
i 1 the burden placed'on the Licensee that would result from imposition of this requirement.
j 35
~
-q 6 I
The Licensee has committed to examine the piping while at the-
- test pressure (1344 psi)-for the lowest pressure rated Class 2 piping. Since the alternative test pressure is greater than the normal operating pressures .of these lines, the proposed alternative test will_ provide adequate assurance that the subject- portions of piping have not developed unallowable inservice flaws or that unallowable inservice flaws will be detected and removed or repaired prior to the return of this piping to service.
Conclusions:
The hydrostatic test required by Section XI of the ASME Code for the subject Class 2 lines is impractical to perform at Farley, Unit 1, because these lines are unisolatable from lower pressure rated Class 2 piping. Imposition of the .
requirer?nts on Alabama Power Company would cause a burden that would not-be compensated significantly by-an increase in safety above that provided by the proposed alternative. The proposed alternative test will provide assurance that structural '
integrity of-these lines is maintained. Therefore, it is concluded that' public health and safety will not be endangered by allowing the alternative test to be performed in' lieu of the
._ Code requirement. It is recommended that relief be granted as requested for the lines listed.
~
3.4.2.3 Reouest for Relief No RR-23. Hydrostatic Test of Portions of
-Class 2 Components to Reouirements of the Connectina Class 1 Pioino Code Reouirement: Section XI, Table IWC-2500-1, Examination -
Category C-H requires a hydrostatic test of all Class 2 pressure-retaining components once every 10-year inspection intervalsin accordance with Paragraph IWC-5222.
Licensee's Code Relief Reauest: Relief is requested from performing the Code-required hydrostatic test at the required -
test pressure for the following portions of Class 2 piping:
36
4 i
(a) Vents, drains, instrumentation lines, and branch i connections off Class I lines (line Nos. CCB-27, -33, -34,
-38, -39, -40, -41, -42, -43, -44, -46A, 46B, -460, -47A,
-47B, and -47C). ;
(b) Pressurizer spray valves bypass lines (line No. CCB 57). ;
(c) Sample lines off reactor coolant system (RCS) loops and ,
pressurizer (line Nos. CCB-37, -54, -55, and -56). ;
(d) Boron Injection Tank discharge to RCS (cold legs) between valves QlE21V004A and B, QlE21VCT29, and QlE21V062A, B, and C (line Nos. CCB 21 and CCB-50).
t (e) High-Head Safety Injection (HHSI) pump discharge to F.CS (cold legs) between valves QlE21V063 and QlE21V066A, B, and C (line No. CCB-22).
(f) HHSI pu:np discharge to RCS (hot legs) between valves ;
QlE21V06B and QlE21V078A, B, and C (line No. CCB-30),
{
(g) HHSI pump discharge to RCS (hot legs) between valves ole 21V072 and Q1E21V079A, B, and C (line No. CCB-31).
(h) Branch lines connecting the accumulator discharge lines to the accumulator test line (line No. CCB-24, -53, and -5/.). '
(i) Residual Heat Removal (RHR) pump discharge to RCS (hot legs) between valves QlE21V044 and QlE21V076A and B (line ';
No. CCB-29)
(j) RHR to RCS (cold legs) between valves QlE21V023A and B and Q1E21V021A, B,- and C (line Nos. CCB 22 and-32).
(k) Alternate charging line between valves QlE21V243 and QlE21V113 (line No. CCB-9).
(1) ' Normal charging line between valves QlE21V244 and QlE21Vil2 (line No. CCB-10).
(m) Normal charging line control valve bypass line between :
valves Q1E21V143 and QlE21Vll2 (line No. CCB-45).
+
(n) Reactor Coolant Pump No. I seal let.koff lines to valves ,
i Q1E21V589A,- B, and C (line Nos. CCB-48A, -488, and -48C).
(o) Reactor Pressure Vessel (RPV) head vent line from Class I line to valves QlB13HV-2 and QlB13HV-4 (line No. CCB-63).
p Licensee's ProDosed Alternative Examination: The Licensee states that visual examination for evidence of leakage will be
- conducted on these portions of systems in conjunction with the ;
l hydrostatic test performed on the adjoining Class I system. [
37 L
-a 6 Licentee's Basis for Reauestino Relief: The Licensee states that it is impractical to conduct a Class 2 hydrostatic test on the portions of the systems listed where the only means of pressurizing the Class 2 system is through the Class I system or when the boundary between the two systems is a check valve arranged for flow from the Class 2 system to the Class I system.
Evaluati.pJ1: The Licensee provided a list of operating pressures, design pressures, Code-required test pressures, and the proposed alternative test pressures for the subject lines in Attachment 10 of the October 5,1989 submittal (Attachment 10 revised in April 12, 1990 submittal). The design of each of these systems does not provide adequate shutoff boundaries to prevent overpressurization of the adjacent Class 1 pipir:0 The design of these lines, therefore, maKes the Code-required hydrostatic test impractical to perform. In order to perform the hydrostatic test in accordance with the requirements, these lines would have to be modified to be isolatable from the adjacent Class 1 piping.
l The increase in plant safety would not compensate for the L burden placed on the Licensee that would result from imposition of the requirement.
Alabama Power Company has committed to visually examine the piping while at the test pressure [850 psi for lines listed in item (h) above; 2280 psi for all other lines listed above) for i the adjacent Class 1 piping. The proposed alternative test will provide adequate assurance that unallowable inservice flaws have not developed in the subject portions of piping or -
l that they will be detected and removed or repaired prior to the i return of this piping to service.
Conclusions:
The hydrostatic test required by Section XI of the ASME Code for the subject Class 2 lines is imoractical to perform at Farley, Unit 1, because these lines are unisolatable 38
e ,
from the adjacent Class 1 piping. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety i above that provided by the proposed alternative. The proposed alternative test will provide assurance that structural integrity of these lines is maintained. Therefore, it is concluded that public health and safety will not be endangered i by allowing the alternative test to be performed in lieu of the ,
Code requirement. It is recommended that relief be granted as '
requested for the lines listed. (
3.4.2.4 Rgguest for Relief No. RR.24. Hydrestatic Test of the Class 2 Relief line Discharce Bgader Pinino to the Pressurizer Relief ,
11Ph NOTE: As stated in the Licensee's October 5, 1989 submittal, ;
Request for Relief No. RR-24 is not required and will be ;
deleted by the Licensee with the next ISI Program Plan revision ,
on the basis that the Ccde-required test can be accomplished as suggested in the NRC request for additional informatior..
3.4.2.5 Reauest for Relief No. RR-25. Hydrostatic Test of Class 2 '
Pressure Retainino Reactor Vessel Flance Seal Leakoff line Code Reauirement: Section XI. Table IWC-2500-1, Examination Category C-H requires a hydrostatic test of all Class 2 pressure retaining components once every 10-year inspection interval in accordance with Paragraph IWC-5222.
Licensee's Code Relief Reauest: Relief is requested from per. arming the Code-required hydrostatic test of the Class 2 .
pressure retaining reactor vessel flange seal leakoff line from ,
the reactor vessel to valves Q1813V019 and Q1813V018 (line No. CCB-36). ,
i r
39
- O ticensee's Procosed Alternative Examination: The Licensee states that, for the reactor vessel flange seal leakoff line from the reactor vessel, the portion of Class 2 piping up to valves QlB13V019 and QlB13V018 will be visually examined during the Class I hydroststic test.
Licensee's Basis for Reauestina Relief: The Licensee states that performance of a hydrostatic tesrt for this system is impractical because pressurization of the flange seal leakoff line could potentially result in damage to the reactor vessel flange seals.
Evaluation: There is a possibility that the reactor vessel flange seals will be damaged if the flange seal leakoff line is pressurized to the Class 2 requirements. The design of this line, therefore, makes the Code-required hydrostatic test impractical to perform. In order to perform the hydrostatic test in accordance with the requirements, the reactor vessel flange seals and flange seal leakoff line, and thus the reactor pressure vessel, would have to be redesigned, fabricated, and installed. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of this requirement.
The Licensee has committed to perform the alternative hydrostatic test at a test pressure of 2280 psi as listed in Attachment 10 of the Licensee's April 12, 1990 letter. The proposed alternative test will provide adequate assurance that unallowable inservice flaws have not developed in the subject line or that they will be detected and removed or repaired prior to the return of this line to service.
Conclusions:
The hydrostatic test required by Section XI of the ASME Code for the subject Class 2 line is impractical to perform at Farley, Unit 1, because of the possibility of damage to the reactor vessel flange seals. Imposition of the 1
40
requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative test will provide assurance that structural integrity of this line is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative test to be performed in lieu of the Code requirement, it is recommended.that relief be granted as requested.
3.4.2.6 Reouest for Relief No. RR-26. Hydrostatic Test of Class _jL Pioina isolated from the Test Boundary by Closed Check Valves Code Reouirement: Section XI, Table IWC-2500-1, Examination Category C-H requires a hydrostatic test of all Class 2 pressure retaining components or.a every 10-year inspection interval in accordance with Paragraph IWC-5222.
Licensee's Code Relief Reouest: Relief is requested from performing the Code-required hydrostatic pressure test of the followint portions of Class 2 systems isolated from the test boundary by closed check valves:
(a) Charging pump suction piping from the chemica! mixing tank between valve QlE21V186 and check valve QlE21V187 (line No. HCB-ll).
(b) Hydrogen and nitrogen supply piping to the VCT from check valve QlE21V201 to isolation valves 01E21V202, Q1E.'.1V583, and Q1E21V260 (line Nos. HCB-68 and HCB-99).
(c) Charging pump suction piping from volume control tank between check valve QlE21V211 and locked closed valve Q1E21V212 (line No. 2"HCB-16).
(d) Charging pump suction piping from boric acid blender between check valve QlE21V210 and normally closed valve QlE21V264 (line No. HCB-16).
Licensee's ProDosed Alternative Examination: None. The Licensee states that portions of the above mentioned Class 2 41 l
\
1 piping will be visually examined during the Class 2 system functional test.
I.icensee's Basis for Reauestina Relief: The Licensee states tnat pressurization of the portions of system piping listed above cannot be assured due to the position of the check valves. The check valves listed prevent flow from the test fill point to the specified boundary. valves.
Evaluation: Drawing D351116, Sheet 2 of 4, in the ISI Program shows that the design of the suction piping incorporates check valves that prevent flow from the test fill point to the specified boundary valves. The position of the check valves, therefore, precludes pressurization of these portions of piping to Class 2 requirements. These portions of 1-inch and 2-inch diameter piping would have to be modified to include test connections in order to perrorm the Code-required hydrostatic test. The increase in plant nfety would not compensate for the burden placed on the Licensee that would result from imposition of this requirement.
The Licensee has stated that a visual examination will be performed during the Class 2 system functional pressure test to assess the general condition of the lines. This will provide reasonable assurance of the continued inservice structural integrity of the pipins
Conclusions:
The hydrostatic test required by Section XI of the ASME Code for the subject Class 2 lines is impractical to perform at Farley, Unit 1, because of the position of the check valves. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the visual examination during the functional pressure test.
This examination will provide assurance that structural integrity of these lines is maintained. Therefore, it is concluded that public health and safety will not be endangered 42
i ,
i by allowing the alternative test to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested.
3.4.2.7 Reauest for Relief No. RR-27. Hydrostatic Test of the Class 2 Waste Gas Drain Filler Line Code Reauirement: Section XI, Table IWC-2500-1, Examination Category C-H requires a hydrostatic test of all Class 2 pressure retaining components once every 10-year inspection interval in accordance with Paragraph IWC-5222.
Licensee's Code R? lief Reauest: Relief is requested from performing the Code-required hydrostatic pressure test of the Class 2 waste gas drain filter line to VCT from isolation valve Q1G25.V249 through check valve QlG22V248 (line No. HCB-92).
Licensee's Proposed Alternative Examination: The Licensee states that the portion of Class 2 piping between valve Q1G22V249 and check valve Q1G22V248 will be visually examined during the Class 2 system functional test.
Licensee's Basis for Reouestina Relief: The Licensee states that pressurization of this portion of the waste gas drain filter line would require check valve Q1G22V248 to hold the hydrostatic test pressure. Leakage through this valve could potentially result in overpressurization and subsequent damage of the waste gas filter.
Evaluation: Design of the waste gas drain filter line does not provide a shutoff valve to protect the waste gas filter from overpressurization during hydrostatic testing of the line. The design of this line, therefore, makes the Code-required hydrostatic test impractical to perform. In order to perform the hydrostatic test in accordance with the requirements, this line would have to be modified to be isolatable from the waste 43
.i gas filter. The increase.in plant _ safety would not compensate
. for the burden placed on the Licensee that would result from j imposition of the requirement, Alabama Power. Company's proposed alternative to perform a l visual examinatinn during the Class 2 system functional !
. pressure test to determine the general condition of the line I will provide reasonable assurance of the continued inservice structural-integrity.
1
Conclusions:
The hydrostatic test required by Section XI of l the ASME Code for the waste gas drain filter line is !
impractical to perform at Farley, Unit 1, because the line is i unisolataMe from the waste gas filter. Imposition of the l specific Code requirements on Alabama Power Company would cause [
.a burdentthat would not-be compensated'significantly by an j
' increase in safety above that provided by the proposed j alternative. The proposed alternative pressure test will l provide assurance that structural integrity of-these lines is j maintained. Therefore, it is concluded that public. health and ;
p safety will not be endangered by allowing the alternative test j to be performed in lieu of the Code requirement. It is f recommended that relief be granted as requested for the lines listed.- l
. p L .
i l 3.4.2.8 Reouest for Relief No. RR-29. Hydrostatic Test of Class 2 Boron
- In.iection Recirculation Pumo Discharoe Pinina k
Code Reauirement: Section XI, Table IWC-2500-1, Examination -
5 Category C-H requires a hydrostatic test.of all Class 2 t pressure retaining components once every 10-year inspection l interval .in accordance with Paragraph IWC-5222.
L Licensee's Code Relief Recuest: Relief is requested from- -
performing the Code-required hydrostatic pressure test of the !
Class 2 boron injection recirculation pump discharge piping l
i 44 [
t
between valves QlE21V006A and B, QlE21V005A and B, and the adjoining drain piping (line No. CCB-62).
Licensee's Procosed Alternative Examination: The Licensee states that these lines will be visually examined during operation as a part of the adjoining Class 3 system leakage test which will be performed at 150 psi.
Licensee's Basis for Reauestino Relief: The Licensee states that performance of a hydrostatic test at 3107 psi (1.25 Pd) on the portion of the system described above requires the use of check valves which are subject to leakage when used as a hydrostatic test boundary. These valves, which are welded in place, cannot be removed and replaced by blind flanges.
Experience has shown that these 1-inch Kerotest check valcas have some leakage when subjected to pressures in this range.
Leakage past these valves could potentially pressurize and overstress the adjoining Class 3 piping which has a design pressure of 150 psi.
Evaluation: The design of the system does not provide adequate shutoff boundaries to prevent overpressurization of the Class 3 piping. The Licensee has committed to examine the piping during tests of the Class 3 system at 150 psi. However, in Attachment 10 of the Licensee's April 12, 1990 letter, the Licensee indicated that the subject piping could be pressurized to an alternative test pressure of 2750 psi. This test pressure is considerably higher than the test pressure of 150 psi listed in the Licensee's proposed alternative examination discussed in Revision 3 of this relief request -
submitted on August 15, 1990. Since the operating pressure of the subject piping is 2735 psi, the Licensee's proposed visual examination of the Class 2 piping during the Class 3 leak test at 150 psi would serve no useful purpose.
Conclusions:
Based on the above evaluation, it is concluded that the Licensee's proposed alternative examination at 150 psi 45
will not provide assurance of the continued in::ervice structural integrity. Therefore, it is recommended that relief be denied.
3.4.2.9 Reauest for Relief No. RR-30. Hydrostatic Test of the Class 2 ,
Portion of the Steam Generators and Associated Pioino ,
4 Code Reauirement: Section XI, Table IWC-2500-1, Examination Category C-H requires a hydrostatic test of all Class 2 ;
pressure retaining components once every 10-year inspection !
interval in accordance with Paragraph IWC-5222.
l l Licensee's Code Relief Reauest: Relief is requested from the required pressure and required 4-hour holding time for ,
hydrostatic testing of the Class 2 portion of the steam generators and associated piping. (Testing at reduced pressure :
for portions of this piping is addressed in relief request (
RR-22, items A through D.) ,
P Licensee's Proposed Alternative Examination: The Licensee states that the Class 2 portions of the steam generators and ;
related piping will be hydrostatically tested at 1.25 times service pressure for a minimum of 10 minutes and a maximum of l' 30 minutes. The test pressure will then be reduced to <
1.0 times design pressure for the remainder of the required l 4-hour holding time.
Licensee's Basis for Reauestino Relief: The Licensee states that, in order to prevent undue stress on the steam generators,- -
l Westinghouse recommends that the hydrostatic test of the secondary side of the steam generators be conducted at 1.25 -
times the design pressure for a minimum of 10 minutes and a ,
maximum of 30 minutes, and then reduced to 1.0 times the design pressure for the balance of the 4-hour holding period. The .
related Class ^ piping is hydrostatically tested along with the ;
l 46
l Evaluation: Tos operating pressure for the secondary side of the steam generators is 775 psig, the design pressure is 1085 psig, and the Code-required test pressure is 1344 psig.
The Code-required holding time is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after attaining the test pressure and temperature conditions for insulated systems. This is to allow any leakage to penetrate the insulation that is not removed. In lieu of a holding time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> at 1344 psig, the Licensee proposes to pressurize the secondary side of the steam generators to 1344 psig for 10 to 30 minutes and then reduce the pressure to 1085 psig for the balance of the 4-hour holding period. The alternative holding time and pressures recommended by the manufacturer, which are proposed in lieu of the Code-required holding time and pressure, meet the intent of the Code requirement and will provide reasonable assurance of the continued inservice structural integrity. Compliance with the specific requirement of the Code would not provide a compensating increase in the level of quality and safety.
Conclusions:
It is concluded that the proposed alternative test meets the intent of the Code requirements. Imposition of the specific Code requirement would not provide a significant increase in safety above that provided by the proposed alternative. Therefore, it is concluded that public health and safety will rot be endangered by allowing the alternative test to be performed in lieu of the specific Code requirement. Pursuant to 10 CFR 50.55a(a)(3), it is recommended that relief be granted as requested.
3.4.2.10 Reauest for Relief No. RR-40. Hydrostatic Test of All Class 2 Branch Pioe lines from the Volume Control Tank to the First Valve Code Reauirement: Section XI, Table IWC-2500-1, Examination Category C-H requires a hydrostatic test of all Class 2 47
. o pressure retaining components once every 10-year inspection interval in accordance with Paragraph IWC-5222.
Licensee's Code Relief Recuest: Relief is requested from performing the Code-required hydrostatic pressure test of all Class 2 branch pipe lines from the volume control tank to the first valve as listed below:
(a) Lines from VCT to valves QlE21 260, Q1E21V209, QlE21V356, Q1E21V152, ole 21V201, QlE21V196, QlE21V262, QlE21V261, QlE21Vl93, QlE21V376A, QlE21V337, and QlE21V423.
(b) Line from VCT to valve Q1G12V029.
(c) Line from VCT to valve Q1G22V249, and line from VCT to valve Q1G22V189.
(d) Line from VCT to valve 0lG22V081.
(e) Line from VCT to valve QlP15HV3117.
Licensee's Proposed Alternative Examination: The Licensee states that the connecting lines to the VCT will be hydrostatically tested to the same pressure as the tank.
Licensee's Basis for Recuestina Relief: The Licensee states that the subject Class 2 portions of piping cannot be isolated from the tank. The VCT tank is designed to 75 psig and the associated piping is designed to 150 psig. Therefore, the only practical means to hydrostatically test the tank associated piping is based on the VCT design pressure.
Evaluat n: The ISI Program drawings referenced in the Licensee's relieT request show that the design of the system _
does not provide shutoff valves to protect the volume control tank from overpressurization during hydrostatic testing of the connecting lines. The system design, therefore, makes the Code-required hydrostatic test impractical to perform. In orde: to perform the hydrostatic test in accordance with the requirements, these lines would have to be modified to be 48
.l 1solatable from the volume control tank. The increase in -l
. plant safety would not compensate for the burden placed on the Licensee that would result _ from imposition of the requirement.
The Licensee has stated that the volume control tank-is designed-to 75 psig and the associated piping is designed to 150 psig. Alabama-Power Company's proposed alternative is to hydrostatically test these Class 2 branch pipe lines to the same pressure as the volume control tank. The proposed alternative test will' provide adequate assurance that unallowable inservice flaws have not developed in the subject portions of piping or that they will be detected and removed or repaired prior to the return of this piping to service.
Conclusions:
The hydrostatic test required by Section XI of the ASME Code for the subject Class 2 lines is impractical to perform at Farley, Unit 1, because these lines are unisolatable.from the volume control; tank. Imposition of the requirements on Alabama Power Company would cause a burden
.that would-not be compensated significantly by an increase in safety above that-provided by the proposed alternative. The proposed al_ternative test will provide assurance that structural . integrity of these lines is maintained. Therefore, it is concluded that public health and safety will not-be
-endangered by allowing the-alternative test to-be performed in lieu of the Code requirement. It-is recommended that relief .
be granted as requested for the lines listed.:
3.4.2.11 Reauest' for Relief No RR-43.- Hydrostatic Test of Class 2 Portions of the RCS Head Vent lines-Code Reauirement: Section XI, Table IWC-2500-1, Examination -
Category C-H requires a' hydrostatic test of all Class 2 pressure retaining-components once every 10-year inspection interval in accordance with Paragraph IWC-5222, 49
, .~ , . - --. . -. . - . -.
s; ,
-Licensee's Code Relief Reauest:- Relief is requested from performing the Code-required hydrostatic pressure test of the l Class 2 portions of the RCS head vent line (line-No. 1"CCB-63 -l between solenoid valves QlB13HV-2 to QlB13HV and QlB13HV-4 -1 to'Q1G13HV-3), ,
licensee's Proposed Alternative Examination: The Licensee states that functional operation of this system demonstrates structural-integrity. Visual inspection will be performed while the system is at normal operating pressure to verify ,
leaktightness.
Licensee's Basis for Reauestino Relief: The Licensee states-that hydrostatic testing of the RCS is performed in mode 2 of the reactor plant shutdown. In this mode, the plant Technical Specifications- require- that all solenoid valves on the RCS head' vent be maintained closed. This being the case, hydrostatic testing of the portion between these valves at this time.would be a violation of the Technical Specifications.
Another way to hydrostatically test these lines would be to pressurize the l_ine after the head has been removed. This would require actuating solenoid valves-QlB13HV-2 and QlB13HV-4 with the= aid of a temporary electric power source.
The. work associated with actuating these valves, installing test connections,'and performing'the hydrostatic test-would require. excessive radiation exposure (approximately 1.5 man-rem)..
This level of exposure is unwarranted in view of the minimal'
~
benefits. gained by testing this relatively small section of pipe which is approximately 6 inches long.
50 I . .- .- - - .-
Inlation: Pressuriring this 6-inch long line after the head i has ban removed is impractical because personnel would r
receive excessive radiation exposure (approximately 1.5 man-rem to examine the 6-inch line). Due to Farley Technical Specification requirements, the Code-required hydrostatic test of this line cannot be performed in mode 2 of l the reactor plant shutdown. la order to perform the i hydrostatic test in accordance with.the requirements, Farley Technical Specification requirements would have to be violated ;
or inspection personnel would receive excessive radiation ;
exposure. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement. ]
The Licensee's proposed alternative is to visually examine '
this line while the system is at normal operating pressure .
(system functional pressure test) to verify leaktightness.
The proposed alternative will provide reasonable assurance of ;
the continued inservice structural integrity. ,
Conclusions:
The hydrostatic test required by Section XI of the ASME Code for this 6-inch portion of 1-inch RCS piping is impractical to perform at Farley, Unit 1, because it would :
result in'inspeccion personnel receiving excessive radiation ,
exposure and violates the Technical Specification requirements ;
if performed in mode 2 of the reactor plant shutdown.
Imposition of the requirement on Alabama Power Company would cause a burder. that would not be compensated significantly by ,
an increase in safety above that provided by thd proposed alternative. The proposed alternative test will provide .
l assurance that structural integrity of-this line is [
maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative test I to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested. :
5 i
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4 :g ;
L3.4.3' Class 3 System pressure Tests !
.3.4.3.1 Recuest for Relief No. RR-31. Visual Examination for leakaae of Class 3 Service Water Pumos Durina System Pressure Tests j
.. ode Recuirement: Section XI, Paragraph IWD-2510 and Table i IWD-2500-1 require-that all Class 3 pressure retaining components be subjected to VT-2 visual examination in ;
conjunction with the system pressure test requirements of l Article IWD-5000. l Licensee's Code Relief Recuest: Relief is requested from i performing the Code-required VT-2 visual examination of 'the l Class 3 service water pumps except at the pump discharge- ;
nozzl e.- _
Licensee's Procosed Alternative Examination: The Licensee {
states that visual inspection of the discharge nozzles will be j j
performed while the pumps are operating. The pump casings will be visually inspected each time the pumps are removed for l maintenance. {
t
' ' i Licensee's Basis for Reauestina Relief: The Licensee states- :
that, due to component design and mounting details the visual !
l inspection of this vertical centrifugal- pump is . impractical .
l except'at-the pump discharge nozzle.
Evaluation: The service water pumps are vertical pumps and, e due to component design,x the pump and supporting column are i
j submerged in an inaccessible wet pit. Only the motor and j discharge nozzle are accessible above the operating deck. The l
]
l component design, therefore, makes the Code-required visual
(: examination impractical to' perform. In order to perform the !
h- visual examination during the hydrostatic test in accordance !
L with the requirements, the Class 3 service water pumps would !
L have to be redesigned, fabricated, and installed. The !
l .!
h 52 j
, i
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o ,
l increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.
The Licensee has stated that the pump discharge nozzle is the only portion of each of the service water pumps that is accessible for visual examination during the hydrostatic test. Alabama Power Company's proposed alternative is to '
visually examine the discharge nozzies while the pumps are operating and to perform a visual examination of the pump casings each time the pumps are removed for maintenance.
These examinations will provide reasonable assurance of the continued inservice structural integrity.
Conclusions:
The VT-2 visual examination required by Section XI of the ASME Code during hydrostatic testing of the Class 3 service water pumps is impractical to perform at Farley, Unit 1, because the pump and supporting column are submerged in an inaccessible wet pit. imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative examination will provide assurance that structural integrity of the service water pumps is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement.
It is recommended that relief be granted as requested.
3.4.3.2 Recuest for Relief No. RR-32. VT-2 Visual Examination of
_(lass 3 Pipina Encased in Concrete in the Scent Fuel pool Coolino System Code Reauirement: Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining 53 l
________________________...________________._-_____m _-
^
o ,
V
- . components be subjected to a VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.
Licensee's Code Relief Reauest: Relief is requested from performing the Code required VT-2 visual examination of the Class 3 pressure retaining piping encased in concrete in the ;
spent fuel pool cooling system. .
[
Licensee's Proposed Alternative Examination: None. The .
Licensee states that the integrity of the encased piping will ;
be demonstrated during normal system functional testing. ,
licensee's Basis for Beauestina Relief: The Licensee states that the design of the piping system does not provide any means'to visually access the encased portions. The Licensee also states that visual examination for leakage at ground level is also not possible.
t Evaluat'on: These portions of spent fuel pool cooling system piping cannot be visually examined because they are encased in concrete. The system design, therefore, makes the Code-required visual examination impractical to perform. In order to perform the visual examination during the hydrostatic '
test in accordance with the_ requirements, the spent fuel pool cooling system would require design modifications. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement. The continued inservice structural integrity of_ the encased piping will be demonstrated during normal - -
system functional testing.
[
Conclusions:
The VT-2 visual examination required by Section XI of the ASME Code during hydrostatic testing of the subject Class 3 spent fuel pool cooling piping is impractical I
to perform at Farley, Unit 1, because the piping is encased in 54
+ .
concrete. Imposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the system functional pressure test. The functional test will provide assurance that structural integrity of the encased piping is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative to be performed in lieu of the Code requirement and it is recommended that relief be granted as requested.
3.4.3.3 Recuest for Relief No. RR-33. Hydrostatic Tests of Portions of Class 3 Pinino and Components in Service Water. Soent Fuel Pool Coolina. Component Coolina Water. Chemical and Volume Control, and Reactor Makeuo Systems Code Reauirement: Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.
Licensee's Code Relief Reauest: Relief is requested from performing the Code-reovired hydrostatic testing of the following portions of Class 3 piping and components:
Service Water System:
(1) Portion of piping upstream of valves QlP16V540 and Q1P16V541.
(2) Portion of piping downstream of valves QlP16V516 and QlP16V517.
Spent Fuel Pool Cooling:
(1) Portion of piping downstream of valves Q1G31V003A and Q1G31V0038.
(2) Portion of piping downstream of valve 0lG31V005.
(3) Portion of piping upstream of valves Q1G31V001A and Q1G31V001B.
55
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Component Cooling Water System:
(1) Component Cooling Water (CCW) surge tank.
(2) Portion of piping from CCW surge tank to valves QlPl7V117A, QlPl7Vil78, Q1Pl7V121A, QlPl7V121B, Q1Pl7V110A, QlPl7V110B, QlPl?V110E, QlPl7V110F, QlPl7V109A, QlPl7V109C, QlPl7V278A, QlPl7V2788, QlPl7V278C, QlPl7V144A, QlPl7V1440, QlPl7V017A, QlPl?V0178.
Chemical and Volume Control System:
(1) Portion of piping from valve QlE21V019 to discharge of Boron Injection Recirculation Pumps - valves QlE21V006A and 01E21V006B.
Reactor Makeup System: (no details provided by Licensee)
Licensee's Prooosed Alternative Examination: None. The Licensee states that functional operation of these portions of piping and components demonstrates structural and leaktight integrity. Visual inspection to verify leaktightness will be performed while the systems are at normal operating pressure, LLC 10see's Basis for Reauestina Relief: The Licensee states that hydrostatic testing of the above systems is not practical since they operate continuously during all modes of plant operations.
Evaluation: In the Licensee's December 7, 1989 response to the NRC request for additional information, the Licensee stated that a 4 tailed review was conducted to identify those portions of these systems which cannot be hydrostatically tested as required by the Code. The piping and components listed in that submittal either lie beyond the Code boundary valve used to isolate the system for performance of the hydrostatic test or interconnect the redundant system trains such that removal from service for testing would render the entire system inoperable. The Peactor Makeup system was not included in that listing of systems that cannot be hydrostatically tested.
As shown in drawing D-351130, Sheet 2 of 11, the subject portions of Class 3 piping in the Service Water System are 56 l
o ,
unisolatable from non safety relateo piping providing Service Water supply t's and froa the turbine building.
p As shown in Boundary Diagrams D 351120. Sheet 1 of 1, i D 3bl103 Sheet 1 of 3, and D 351115 Sheet 1 of 4, the
! subject portior.s of Class 3 piping and components in the spent fuel _ pool cooling, component cooling water, and chemical and volume control systems cannot be isolated for hydrostatic tests since removal from service for testing would render the l entire system inoperable.
The design of these systems, therefore, makes the Code required hydrostatic test of these portions of Class 3 piping wd components impractical to perform. In order to l
-- perf ar- S e hydrostatic test of these_ portions of Class 3 ,.
pipir..; 4...d components in ac ordance with the requirements, these rystems would have to be redesigned, refabricated, and l installed. The increase in plant ".fety would not compensate !
I for the burden placed on the Licensee that would result from i imposition of the-requirement. l The Licensee stated in the Dececher 7, 1989 submittal that !
those portions of the service water, component cooling water, ;
chemical and volume control, and spent fuel pool cooling i systems, which can be isolated without loss of redundant l I
g trains within the system, will be hydrostatically tested te--
! -the extent practical as required by the Code. These !
I Code required hydrostatic tests and the Licensee's proposed j visual examination at normal operating pressure (functional {
pressuretest)forthose-portionsofpipingforwhichrelief ,
L is repested will provide reasonable assurance of the !
continued inservice stru',cural integrity.
I l
Conclusions:
The hydrostatic test required by Section XI of f l the ASMC Code for the subject Class 3 piping and components, with the exception of the Reactor Hakeup system, is ;
f 57 l:
-.a..._._,,_, . , _. . a _ . - _ . , _ , _ . . _ . _ , , , _ _ _ . , _ . _ - _ _ . . _ . - _ _ _ _ . _ _ _m I
o .
impractical to perform at farley, Unit 1, because the piping i
, and components either lie beyond the Code boundary valve used to isolate the system or interconnect the redundant system trains such that removal from service for testing would render the entire system inoperable. Imposition of the requirements on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the functional pressure test. The proposed test will provide adequate assurance that structural integrity of the subject piping and components is maintained.
Therefore, it is concluded that public health and safety will not be endangered by allowing the functional test to be ,
performed in lieu of the Code requirement. It is recommended that relief be granted as requested for the piping listed above with the exception of the Reactor Makeup system. With regard to the Reactor Makeup system, it is recommended that relief be denied.
3.4.3.4 Reouest for Relief No. RR 34. Hydrostatic Test of Class 3 Sorav Additive Pinina and Comoonents in the Contpinment Sorav ,
System Code Recuirement: Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be subjected to VT 2 visual examination in con,iunction with the system pressure test requirements of Article IWD-5000.
Licensee's Code Relief kequest: Relief is requested from performing the Code required hydrostatic pressure test of Class 3 spray additive niping and components in the Containment Spray System.
Licensee's Procosed Alternative Examination: The Licensee states that a measured flow test in accordance with plant l
58
9 .
't Technical Specification paragraph 4.6.2.2d will be conducted periodically to assure the leaktightness of these Class 3 I
components.
P Licensee's Basis for Reauestina Relief: The Licensee states !
that, while in service, these spray additive lines have an operating pressure of 15 psig and temperature of 100*F. which i are well belnw the design conditions of 210 psig pressure and ,
300'F temperature. Therefore, a system hydrostatic test at l
1.25 times service pressure would not provide a meaningful test. In addition, this piping system contains sodium '
hydroxide at a concentration of 30 to 32% per Technical '
Lpecification 3.6.2.2a. Sodium hydroxide is a hazardous i substance according to 40 CFR part 302 (CERCLA). Alabama Power Company does not consider it practical to perform the hydrostatic testing since it would expose personnel, .
equipment, and the environment to a hazardous substance at ,
1.25Pd when this system operates at only 15 psig and 100'F. !
Evaluation: These lines contain highly corrosive sodium l
hydroxide and the system operates at a pressure of 15 psig and '
temperature of 100'F, which is significantly less than the design conditions. The presence of the highly corrosivo sodium hydroxide in the spray additive piping and the fact that the system operates at a pressure that is far below the
- design pressure make the Code required hydrostatic test !
impractical to perform. If the hydrostatic test was performed in accordance with the requirements, personnel, equipment, and the environment could be exposed to a hazardous substance. ;
The increase in plant safety would not compensate for the !
burden placed on the Licensee that would result from imposition of the requirement. '
Alabama Power Company's proposed alternative is to perform a measured flow test in accordance with the Farley Technical Specifications to assure the leaktightness of system. This !
[
59
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alternative will provide reasonable assurance of the continued inservice structural integrity of the Class 3 spray additive piping and components.
Conclusions:
The hydrostatic test required by Section XI of the ASHE Code for the Class 3 spray additive piping and coreponents is impractical to perform at farley, Unit 1, because the lines contain highly corrosive sodiuin hydroxide and the system operates at a pressure significantly less thar.
the design conditions (upon which the Code requinment is based). Imposition of the Code requirement on Alabama Power Company would cause a burden that would not be compensated by an increase in safety above that provided by the proposed alternative. The proposed alternative examination will provide assurance that structural integrity of the spray additive piping and components is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement. It is recommended that relief be granted as requested.
3.4.3.6 Reonest for Relief No. RR-35. Hydrostatic Test of Class 3 Portions of Buried P.loina in the Service Water System l
l Code Reauirement: Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requi.rements of l Article IWD-5000. Subarticle IWA 5244 defines the VT-2 visual -
examination for buried components.
Licensee's Code Relief Reouest: Relief is requested frnm L performing the Code-required visual examination of Class 3 portions of buried piping in the Service Water System during hydrostatic testing.
I 60
Ucensee's Proposed Alternative Examination: The Licensee states that buried piping will be inspected by conducting a '
visual observation of the ground (at ground elevation) for wet !
spots while the systems are at operating pressure. This is in !
accordance with the final Safety Analysis Report, Paragraphs 3.1.41 and 9.2.1.4.
i licensee's Basis for Reauestina Relief: The Licensee states l that the design of this system does'not allow access for visual examination as required by IWA-5244.
l f.yaluat ion: Portions of the Class 3 piping in the service water system are buried. The design of the service water -
system does not provide access to the the portions of buried piping to perform the Code required visual examination during [
hydrostatic testing. The system design, therefore, makes the !
Code required examination impractical to perform. In order te '
perform the Code-required visual examination during the hydrostatic test in accordance with the requirements, the ,
service water system would require design modifications to provida access for examinations. The increase in plant safety ;
would not compensate for the burden placed on the Licensee ,
that would result from imposition of the requirement.
The Licensee's proposed alternative examination is to condurt ,
a visual observat;on (in accordance with the Final Safety ;
Analysis Report, Paragraphs 3.1.41 and 9.2.1.4) of the ground [
(at ground elevation) for wet spots while the systems are at operating pressure. This examination will provide reasonable assurance of the continued inservice structural integrity of the buried piping. -
Conclusions:
The VT-2 visual examination required by l Section XI of tho ASME Code during hydrostatic testing of the ;
subject Class 3 service water system piping is impractical tr !
perform at farley, Unit 1, because the piping is buried with ;
1 61 m ,_ x _ . _ . . - - . . , _ ,-- . _ -
o .
no access for visual examinations referenced in IWA-5244.
'mposition of the requirement on Alabama Power Company would cause a burden that would not be compensated significantly by an increase in safety above that provided by the proposed alternative. The proposed alternative examination will provide assurance that structural integrity of the buried piping is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative to be performed in lieu of the Code requirement and it is recommended that relief be granted as requested.
3.4.3.6 Reauest for Relief No. RR-36m VT-2 Visual Examination of Heat Exchanaer Tubes of Class 3 Pressure Retainina Safety Related Heat Exchancers Code Rcouirement: Section XI, Paragraph IWD-2510 and Table IWD 2500-1 requi- that all Class 3 pressure retaining components be subaceted to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD 5000.
Licensee's Code Relief Reauest: Relief is requested from performing the Code-required VT-2 visual examination of heat exchanger tubes of Class 3 component cooling water heat exchangers HX-QlPl7 H001A-B, H001B AB, and H001C-A.
Licensee's Proposed Alternative Examination: The Licensee states that tube side inspection will be performed by isolating tha heat exchanger, removing the waterbox covers, _
and pressurizing the shell side with water. Tube leakage is indicated if there is any flow from the tubes while in this configuration. This type inspection will be performed at least once per inspection interval.
l 62
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Licensee's Basis for Reauestina Relief: The Licensee states that, due to component design and limited accessibility, these heat exchanger tubes cannot be visually inspected under high pressure hydrostatic test conditions, Integrity of the component is assured by testing the component as a unit.
Evaluation: hough it is our interpretation that it is not the intent of the Code to require VT-2 visual exauination of the heat exchanger tubes during the hydrostatic test of the heat exchangers, the Code does not specifically exclude these items. The design of the heat exchanger does not provide access to the subject heat exchanger tubes in order to perform the VT-2 visual examination during hydrostatic testing, inaccessibility during a hydrostatic test, therefore, makes the VT-2 visual examination of the heat exchanger tubes during the hydrostatic test impractical to perform. In order to perform the VT-2 examination during hydrostatic testing, the heat exchangers would require redesign to provide access for the examination. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.
Alabama Power Company's proposed alternative is to perform a tube side inspection by isolating the heat exchanger, removing the waterbox covers, and pressurizing the shell side with water at least once per inspection interval. Because tube leakage will be detected if there is any flow from the tubes while in this configuration, assurance of the continued inservice structural integrity will be provided.
Conclusions:
The VT-2 visual examination required by Section XI of the ASME Code for Class 3 pressure retaining components during hydrostatic tests is impractical to perform at Farley, Unit 1, with regard to heat exchanger tubes because the tubes are inaccessible. Imposition of the requiremcat on Alabama Power Company would cause a burden that would not be 63
o ,
compensated by an increase in safety above that provided by the proposed alternative. The proposed alternative test will provide assurance that structural integrity of these Class 3 heat exchanger tubes is maintained. Therefore, it is concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement. Although it is our interpretation that it is not the intent of the Code to require VT-2 visual examination of these heat exchanger tubes during the hydrostatic test, the Code does not specifically exclude these items from the VT 2 visual examination.
Therefore, it is recommended that relief be granted as requested.
3.4-.3.7 Reauest for Relief No. RR-37. VT-2 Visual Examination of the Coolino Coils for Class 3 Pressure Retainina Safety Related-(21l_tri Code Reauirement: Section XI Paragraph IWD-2510 and Table IWD 2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD 5000.
Licensee's Code Relief Reauest: Relief is requested from performing the Code-required VT-2 visual examination of the cooling coils for the following Class 3 pressure retaining safety related coolers:
~
(a) Four containment coolers - QlE12 H001A-A, H0018 A, H001C-8, and H001D B.
(b) Two control room air-conditianing condensers -
QSV491-K001A-A and'K0018-B.
(c) Two auxiliary feedwater pump room coolers - QlE16-H005A-A and H0058-8.
l 64
e .
(d) Two' component cooling water pump room coolers QlE16-H004A A and H0048 B.
(e) Two containment spray pump room coolers QlE16-H002A-A and H0028 8.
(f) Two RHR/LHSI pump room coolers QlE16 H003A A and H003B B.
(g) Three battery charging room coolers 01E16 H006A A, H0068-B, and H006C-AB.
(h) Three charging pump room coolers QlE16 H001A A, H0018 AB, and 11001C 8.
(i) Two 600-V load center coolers QlE16-H009-A and H010 B.
(j) Three motor control center room coolers 01E16 H007-A, H00BA B, and H00BB B.
Licensee's Proposed Alternative Examination: The Licensee states that the normal operation of these cooling units demonstrates their structural and leaktight integrity. Visual inspection to verify leaktightness will be performed while the 4 system is at normal operating pressure. Also, the coolers provided with the drain basin will be inspected by observing for abnormal flow (other than normal condensation).
Licensee's Basis for Reauestina Relief: The Licensee states that, due to the component design, the cooling coils (heat '
exchanger tubes) cannot be visually inspected during the conduct of system pressure test.
Evaluation: .Although it is.our interpretation that it is 'not the intent of the Code to require VT-2 visual examination of the cooling coils of the subject Class 3 safety related coolers during the system pressure test, the Code does.not ,
specifically exclude these items. The design of the coolers doestnot provide access to the subject cooling coils to perform the VT 2 visual examination during pressure testing. .
Inaccessibility during a system pressure test, therefore, makes the VT-2 visual examination of the cooling coils during the system pressure test impractical to perform. In order to 65 p - .
o .
pqrform the VT 2 examination during pressure testing, the coolers would require redesign to provide access for the examination. The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.
Because normal operation of these cooling units demonstrates their structural and leaktight integrity, Alabama Power Company's proposed alternative to po'rform a visual inspection to verify leaktightness while the system is at normal operating pressure and to observe for abnormal flow (other than normal condensation) on the coolers provided with a drain basin provides assurance of the continued inservice structural integrity.
Conclusions:
The VT-2 visual examination required by Section XI of the ASME Code for Class 3 pressure retaining components during system pressure tests is impractical to perform at Farley, Unit 1, with regard to the cooling coils of [
the subject Class 3 safety related coolers because the cooling <
coils are inaccessible, imposition of the requirement on Alabama Power Company would cause a burden that would not be I compensated by an increase in safety above that provided by !
the proposed alternative. The proposed alternative test will provide assurance that structural integrity of these Class 3 -
cooling coils is maintained. Therefore, it is concluded that i
public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the ;
Code requirement. Although it is our interpretation that it l l
is not the intent of the Code to require VT-2 visual !
examination of these cooling coils during the system pressure test, the Code does not specifically exclude these items from ;
the VT-2 visual examination. Therefore, it is recommended l
l that relief be granted as requested.
l 1
1 66 l
l
3..i.3.8 Eguuest for Relief No. RR-33. Hydrostatic Test of Class 3 E12.lDa of the Auxiliary Steam System Code Reguirement: Section XI, Paragraph IWD 2510 and Table IWD 25001 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD 5000. .
LLeensee's Code Relief Recuest: Relief is requested from performing the Code required hydrostatic pressure test of the Class 3 pressure retaining piping of the auxiliary steam system downstream of valves Q1N12V0028 and Q1N12V003.
Licensee's Proposed Alternative Examination: The Licensee states that the VT-2 visual examination to verify leaktightness will be performed while these lines are at normal operating pressure.
Licensee's Basis for Reauestino Relief: The Licensee states that there is no practical means of isolating these portions of the auxiliary steam system and, therefore, hydrostatic testing cannot be conducted on these lines.
Evaluation: The ISI Program drawing referenced in the Licensee's relief request shows that there are no valves downstream of valves Q1N12V002B and QlN12V003 in the auxiliary steam supply lines capable of providing a positive isolation when performing a hydrostatic test. The syste,n design, therefore, makes the Code-required hydrostatic test impractical to perform. In order to perform the hydrostatic test in accordance with the requirements, the subject lines would require design modifications to provide isolability.
The increase in plant safety would not compensate for the burden placed on the Licensee that would result from imposition of the requirement.
l 67
{
Alabama Power Company's proposed alternative to perform the l VT-2 visual examination to verify leaktightness while these lines are at normal operating pressure will provide reasonable '
assurance of the continued inservice structural integrity. t
Conclusions:
The hydrostatic test required by Section XI of ,
the ASME Code for the subject auxiliary steam system piping is !
impractical to perfonn at farley, Unit 1, because there are no {
valves downstream of valves 0lN12V00'2B and Q1N12V003 capable ;
of providing a positive isolation when performing a hydrostatic test. Imposition of the requirement on Alabama Power Cvmpany would cause a burden that would not be compensated significantly by an increase in safety above that ;
I provided by the proposed alternative. The proposed VT 2 visual examination at operating pressure will provide ,
assurance that structural integrity of the subject lines is I maintained. Therefore, it is concluded that public health and i safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement. ;
It is recommended that relief be granted as requested for the subject auxiliary steam supply lines.
3.4.3.9 Reauest for Relief No. RR-39. Hydrostatic Test of Class 3 -
Auxiliary Feedwater Pumo Minimum Flow Pioina Code Reauireffnl: Section XI, Paragraph IWD-2510 and Table IWD-2500-1 require that all Class 3 pressure retaining components be subjected to VT-2 visual examination in conjunction with the system pressure test requirements of Article IWD-5000.
Licensee's Code Relief Reauest: Relief is requested from i per. forming the Code-required hydrostatic pressure test of the l following Class 3 pressure retaining auxiliary feedwater pump minimum flow piping:
68 ,
e (a) Line t!o. 2"DBC between valve Q1N23V019A and flow orifice f03214A.
(b) Line No. 2"DCB between valve Q1N23V019B and flow orifice F032148.
(c) Line No. 2"DBC-4 and 3"DBC between ialve Q1N23V010 and flow orifice F03219.
Licensee's Pronosed Alternative Examination: The Licensee states that these lines will receive a visual examination during normal operation at system operating temperature and pressure.
Licensee's Basis for Recyestino Relief: The Licensee states that performance of a hydrostatic test on the portions of the piping system listed could overpressurize the lower pressure, non-Code piping downstream of these flow orifices.
Evaluation: The ISI Program drawing referenced in the Licensee's relief request shows that the design of the auxiliary feedwater pump minimum flow piping system does not provide distinct class boundaries to allcw pressurization of tho Class 3 piping without overpressurizing adjacent non-Coda piping. The system design, therefore, makes the Code-required hydrostatic test impractical to perform. In order to perform the hydrostatic test in accordance with the requirements, the subject lines would require design modifications to provide isolability. The increase in plant safety would not compensate fcr the burden placed on the Licensee that would result from imposition of the requireme,t.
Alabama Power Company's proposed alternative to perform the VT-2 visual examination during normal operation at system operating temperature and pressure will provide reasonable assurance of the continued inservice structural integrity.
Conclusions:
The hydrostatic test required by Section XI of the ASME Code for the subject Class 3 pressure retaining l
69 l
i-auxiliary feedwater pump minimum flow piping is impractical to perform at Farley, Unit 1, because the subject lines cannot be ;
isolated from adjacent non-Code piping. Imposition of the f requirement on Alabama Power Company would cause a burden that I would not be compensated significantly by an increase in l safety above that provided by the proposed alternative. The l proposed alternative will provide assurance that structural j integrity of the subject itnes is ma,intained. Therefore, it l is concluded that public health and safety will not be ;
endangered by allowing the alternativt examination to be j performed in lieu of the Code requirement. It is recommended j that relief be granted as requested, j i
I 3.4.3.10 Reauest for Relief No. RR-44. VT-2 V,hual Examination of Hni_ j Exchanaer Tubes of Class 3 Pressure Retainino Safety Related. !
Heat Exchanaers i
Code Reauirement: Section XI, Paragraph IWD-2510 and Table l
IWD 2500 1 require that all Class 3 pressure retaining l
~
- components be subjected to VT-2 visual examination in {
conjunction with the system pressure test requirements of l Article IWD-5000. l i licensee's Code Relief ReaeJ1: Relief is requested from 3 l performing the Code-required VT-2 visual examination of the l - heat exchanger tubes of Class 3 pressure retaining safety {
L-related heat exchangers (two each spent fuel pool cooling !
HX-Q1G31 H001A-B and H0018-A). i
- i. .
E Licensee's Proposed Alternative.Jamination: The Licensee l
- states that tube side leakage will be identified by the {
L existing in-line radiation monitoring system and existing {
periodic sampling of the Component Cooling Water and Spent {
Fuel Pool Cooling Systems. If a tube leak is iridicated, the 1
- water box covers will be removed and a VT-2 visual examination ,
i 4
f 70 i
- m. - , ,,._ .,~. m_.,_. . . . . - . , ~ , . . . - . , . - _ _ ._,.m..m_., . . , , , , _ . . , . - , . _ . , - , . , , , . . - . . - -.m.m.-~,,
I o .
performed to identify the leaking tubes. The tubes will be plugged prior to returning the heat exchanger to service. [
i licensee's BasiLfor Reouestina Relief: The Licensee states that, due to cornponent design and limited accessibility, these l heat exchanger tubes cannot be visually inspected under high {
pressure hydrostatic test conditions. Integrity of the l component is assured by normal operation of the system.
Evaluation: Although it is our interpretation that it is not the intent of the Code to require VT-2 visual examination of the heat exchanger tubes during the hydrostatic test of the ;
heat exchangers, the Code does not specifically exclude these f items. The component design does not provide access to the {
heat exchanger tubes of the subject Class 3 safety related I heat exchangers in the spent fuel pool cooling system to i perform the VT-2 visual examination during hyd:ostatic l testing. Inaccessibility during a hydrostatic test, therefore, makes the VT-2 visual examination of the heat I exchanger tubes during the hydrostatic test impractical to -
perform, in order to perform the VT-2 examination during i hydrostatic testing, the heat exchangers would require redesign to provide access for the examination. The increase ;
in plant safety would not compensate for the burden placed on ;
the Licensee that would result from imposition of the requirement, i
Alabama Power has stated that tube side leakage will be ;
identified by the existing in-line radiation monitoring system '
and existing periodic sampling of the component cooling water !
and spent fuel pool cooling systems and that, if a tube leak [
is indicated, the water box covers will be removed and a VT-2 visual examination performed to identify the leaking tubes (the tubes will be plugged prior to returning the heat exchangertoservice). This exaraination will provide reasonable assurance of the continued inservice structural integrity, p i
I 71 !
l
Conclusions:
The VT 2 visual examination required by :
Section XI of the ASME Code for Class 3 pressure retaining i components during hydrostatic tests is impractical to perform at farley, Unit 1, with regard to Frat exchanger tubes because the tubes are inaccessible. Imposition of the requirement on ,
Alabama Power Company would cause a burden that would not be compensated by an increase in safety above that provided by the proposed alternative. The propo, sed alternative will :
provide assurance that structural integrity of these Class 3 heat exchanger tubes is maintained. Therefore, it is ;
concluded that public health and safety will not be endangered by allowing the alternative examination to be performed in lieu of the Code requirement. Although it is our interpretation that it is not the intent of the Code to require VT-2 visual examination of these heat exchanger tubes during the hydrostatic test, the Code does not specifically !
exclude these items from the VT 2 visual examination. ;
Therefore, it is recommended that relief be granted as I requested.
3.4.4 General 3.4.4.1 Eg.qugil_for Relief No. RR-45. Hydrostatic Test of Class 2 aad_ ,
[lgj_s 3 Low Pressure Systems i NOTE: As stated in the Licensee's October 5, 1989 submittal,
- Request for Relief No. RR~45 is not required and will be '
deleted in the next ISI Program revision.
t 3.4.4.2 Egauest for Relief No. RR 46. Scheduling of Class 2 and Class 3 System Hydrostatic Pressure Tests i Code Reauirement: Section XI, Table I"C 2500-1. Examina* ion Category C-H, Note 5 requires that system hydrostatic tests be >
I *
! 72 ,
e
,-.-,<m- , , - - - - - ,- ,- - ,.---+---wg -- 3 -we ---, - ---
3-nr -,r- r -er-----
o ,
conducted at or near the end of the inspection interval or during the same inspection period of each inspection interval for Inspection Program B. Note 2 of Table IWD 2500-1, Examination Categories D A, D B, and D-C, requires that system hydrostatic tests be conducted at or near the end of the inspection interval or during the same inspection period of each inspection interval for Inspection Program B.
LtCIDfee's Code Relief Reauest: Relief is requested from scheduling Class 2 hydrostatic tests in accordance with Note 5 of Table IWC 2500-1, Examinatien Category C-H and from scheduling Class 3 hydrostatic te;ts in accordance with Note 2 of Table IWD 25001, Examination Categories D A, D-B, and D C.
Licensee's Proposed Alternative Examination: The Licensee states that all 25 hydrostatic tests will be performed during the second inspection interval. They will be scheduled to distribute the testing evenly among the three periods for the second interval, licensee's Ba',is for Reauestinn Rell' .he Licensee states that the system hydrostatic testr cheduled on a periodic basis in accordance with Inspectn.. /rogram B. As a result of performing additional tests during the first 10 year interval, it is necessary to move eight hydrostatic tests forward one period. The original schedule for performing hydrostatic testing was base.d on dividing the systems to be tested into 18 procedures. Due to operational conditions during the course of the interval, several procedures were divided resulting in additional hydrostatic testing procedures to be performed. At the end of the interval, 25 procedures existed to cover the systems to be tested.
l Evaluation: The Licensee has committed to scheduling the hydrostatic tests such that the elapsed time between a system examination will not exceed 10 years. Therefore, the intent 73
m _ _ . __._._.__.__.__..___ _ _ _ -
i 8
o !
of the Code requirerront will be met. The Licensee has I
demonstrated that the proposed alternative scheduling provides an acceptable level of quality and safety and that compliance ;
with the Code schedule would result in hardship or unusual l difficulties without a compensating increase in the level of l quality and safety. }
l
Conclusions:
Based on the above eva,1uation, it is concluded j that the Licensee's proposed scheduling of hydrostatic j pressure tests meets the intent of the Code requirements. [
Therefore, it is concluded that public health and safety will
]
not be endangered by allowing the alternative scheduling in i lieu of the Code requirement. Pursuant to l
10 CFR 50.55a(a)(3), it is recommended that relief be granted _!
as requested.-
t E
3.5 General j I
i 3.5.1 Ultrasonic Examination Technioues j i
3.5.1.1 Reauest for Relief No. RR 1. Material Reauirements for l Calibration Blocks I Code Reauirement: Sec. tion XI,. Paragraph IWA-2232 requires [
that ultrasonic examination of vessel welds in ferritic '
materials greater than 2 inches in thickness be performed in {
accordance with-Article 4 LSection V. ParagraphT434.1.l(3) ;
of Article 4 requires that the material from which calibration i blocks'are fabricated be of the sama material specification, . [
product form, and heat treatment as-one of the materials being .l joined, j Licensee's Code Relief Reauest: Relief is requested from the j material ' requirements .for calibration blocks used to perform !
ultrasonic examination of the following: !
I 74 l
.1 ., _ - , , ,....,,._.____u...
, _ . , _ _ - . - _ - . _ _ _ . _ . . - . - _ . - _ _ - . _ _ _ _ . - _ _ _ . . ~ _ - -
Cal. Block Component to be examined Steam generator channel head-to-tubesheet welds APR 6:
APR-7: Boron injection tank head-to-shell circumferential welds and nozzle to head welds ALA-RV 1: Reactor vessel lower head-to lower shell weld and all lower head welds. Boron injection tank head to-shell circumferential welds ALA-RV-3: Reactor vessel top head welds ALA RV-5: Reactor vessel shell welds licensee's Proposed Alternative Examination: The Licensee states that the subject calibration blocks are in compliance with the material requirements of Paragraph T-533, Article 5,Section V of the 1974 ASME Code. This paragraph requires the block to be of similar metallurgical structure and the same or an equivalent P nu.tber grouping as the finished component.
Licensee's Basis for Reauestino Relief: The Licensee states that, during fabrication of the Farley, Unit 1, nuclear steam supply system vessels, the calibration blocks used to perform examinations by the vessel manufacturer were fabricated to the requirements of ASME Section III. When ASME Section XI was issued for inservice inspection, the new requirements for vessel calibration blocks rendered the existing- blocks-unacceptable for use. The~ original blocks-had to be replaced but some vessel materials were no longer available. The vessel calibration blocks had to be refabricated to-the Section XI requirements applicable at that time.
Information was' submitted in the Li_censee's October 5, 1989 responsa to the NRC-request for additional information. The following sumarizes evaluations which were conducted to -
determine the suitability of the alternative calibration block materials:
The SA 216 Gr. WCC and SA-508 C1. 2 or 3 materials APR-6:
examined and SA-336 C1. F-1 alternative calibration block L 75 h
l}
material have the same product form, are similar in chemistry, received equivalent postweld heat trtatments and are all classified as P 3.
APR-7: The SA 516 Gr. 70 base materials examined and the alternative SA 533 Gr. B C1, I calibration block material are the same product form and have equivalent P-numbers for acoustic purposes per Section V of the 1974 Edition of the ASME Code. As required by Section V, the calibration block was given a postweld heat treatment.
ALA RV-1: The SA-508 C1. 2 alternative calibration block material and SA-533 Gr. B material examined are similar in chemistry, receind equivalent postweld heat treatments and are both classified as P-3.
ALA RV 3 and ALA RV-5: The SA-533 Gr. B C1.-2 material examined and the SA-508 C1.'2 alternative calibration block material are similar in chemistry, received equivalent postweld heat treatments and are both classified as _P 3.
-In each case, the parameters judged to be essential for acoustical compatibility were considered in the evaluations.
The materials examined and the alternative calibration block materials were found to be similar enough to ensure acoustical compatibility.
From the'standpoin_t of acoustics, attenuation characteristics and velocity are of the utmost concern in determining material compatibility._ The velocity and attenuation differences of- ,
-the materials are immeasurable __ and are, for the most part,
-equivalent.- Therefore, the existing calibration blocks are acceptable, based on -acoustic compatibility.
Tn fabricate new Code-required calibraticn blocks would be impractical, if r.ot impossible, due to availability of u
76 l
material and will not make a substantial impmyentent in the quality of the examinations. Obtaining the appropriate product form and material specification may require
- procurement of nozzle forgings, nozzle ring castings, tubesheet forgings, and other difficult-to obtain product forms, in summary, it is Alabama Power Company's judgement that the evaluations summarized above suitably demonstrate the acceptability of the alternative calibration block material requirements. -While the Code requirements have not been explicitly met (and thus a relief request has been submitted),
the intent of the Code to ensure acoustic compatibility has been met.
Evalua_timi: Evaluation of the calibration blocks by the Licensee has.shown that.the velocity and attenuation differences.of the material are immeasurable and are, for the most part, equivalent. While the Code requirements have_not
- been explicitly met, the intent of the Code to ensure acoustic compatibility has been met. All of the proposed calibration blocks have been in use since the plant was built; therefore, their continued use would provide consistent results. Because procuring calibration blocks of the exact materials would be difficult, if not impossible, and because the velocity and attenuation characteristics of the materials are equivalent, the increase in plant cafety would not compensate for the burden placed on the. Licensee that would result from requiring q the Licensee to fabricate new calibration blocks to meet the current Code. The Licensee has demonstrated that the proposed i alter _ native provides an acceptable level of quality and safety and that compliance with the specific Code requirement would ,
! result in hardship or unusual difficulties without a'
! compensating' increase in the level of quality and safety.
4 4
i :
77
=
Conclusions:
Based on the above, it is concluded that public health and safety will not be endangered by allowing the use of the alternative calibration blocks in lieu of the specific Code requirement. Therefore, pursuant to 10 CFR 50.55a(a)(3),
it is recommended that relief be granted as requested.
3.5.1.2 Reauest for Relief No. RR-2. Specific Dimensional Reauirements for Calibration Blocks Code Reauirement: Section XI, Ptragraph IWA 2232 requires that ultrasonic examination of vessel welds in ferritic materials greater than 2 inches in thickness be conducted in accordance with Article 4,Section V, 1983 Edition. Figure T-434.1, Article 4, requires that the minimum distance from the ends of the 2-inch long 2% T notches to the edges of the block be 3 inches.
Licensee's Code Relief Reauest: Relief is requested from notch location requirements for calibration blocks used to perform ultrasonic examination of the follou ;;
ALA-RV-1: Boron injection tank head-to-shell circumferential welds. Reactor vessel lower head-to lower shell '
weld and all lower head welds ALA-RV-3: Reactor vessel top head welds ALA-RV-5: Reactor vessel flange-to-shell weld and shell welds Licensee's Proposed Alternative Examination: The Licensee states that the subject calibration blocks are in compliance with the clearance dimensions required for notches by Figure T-546.1, Article 5,Section V, 1983 Edition. ,
Licensee's Basis for Reauestina Relief: The Licensee states ;
that figure T-546.1, Article 5,Section V, 1983 Edition, is a i similar calibration block; however, the clearance required from the ends of the 2% notches is 2 inches instead of the 78
^
t 3 inches required by Figure T-434.1, Article 4. Experience performing calibrations using these blocks has proven fully satisfactory.
Evaluation: All of the proposed calibration blocks have been in use since the plant was built; therefcre, their continued use would prov1.'e consistent results. Because procuring calibration blocks of %e exact mate, rials would be o;fficult, if not impossible, anu because the existing blocks have been proven satisfactory for performing calibrations, the increase in plant safety would not compensate for the burden placed on the Licensee that would result from requiring the Licensee to fabricate new calibration blocks to the current Code. The Licensee has demonstrated that the proposed alternative provides an acceptable level of quality and safety and that compliance with the specific Code iequirement would result in hardship or unusual difficulties wi iut a compensating increase in the level of quality and safety.
Conclusions:
Based on the above, it is concluded that public health and safety will not be endangered by allowing the use of the alternative calibration blocks in lieu of the specific Code requirement. Therefore, pursuant to 10 CFR 50.55a(a)(3),
it is recommended that relief oe granted a: requested.
3.5.1.3 Recuest for Relief No. RR-3. Specific Dimensional Reauirements for Calibration Blocks Code Reauirement: Section XI, Paragraph IWA 2232 requires .
that ultrasonic examination of vessel welds in ferritic e materials greater than 2 inches in thickness be conducted in-accordance with Article 4.Section V, 1983 Edition. Figure T-434.1 in Article 4 requires the aligned side-drilled holes-
.and notches to be located a minimum distance of T/2 from the end of the block. The non-aligned holes are to be located a minimum of 1.5 inches f, rom the end of the block.
79
- 0 licensee's Code Relief Reouest: Relief is requested from the hole location requirements for the following calibration blocks:
ALA-RV-1: Reactor vessel lower head-to-lower shell weld, all lower head welds, and boron injection tank head circumferential welds.
ALA-RV-5: Reactor vessel flange-to-shell weld and shell welds !
APR-5: Steam generator stub barr'el-to-upper tubesheet !
weld, lower shell-to-stub barrel weld, transition cone-to-lower shell weld, upper shell to-transition
APR-7: Pressurizer top head-to nozzle welds, top ,
head-to-upper shell, upper to middle shell weld, lower-to-bottom head weld, all longitudinal shell welds, and bottom head-to-nozzle weld.
The aligned holes in ALA-RV-1 aiid ALA RV-5 are 0.25 and O.5 inches less than the required distance, respectively. The non-aligned holes on ALA-RV-1, APR-5, and APR-7 are 0.25, 0.625, and 0.625 inches less than the required distance, respectively.
Licensee's Prooosed A1(ernative Examination: None. The i Licensee states that the calibration blocks are acceptable for :
use as is..
Licensee's Basis.for Reouestina Relief: The Licensee states that experience performing calibrations using these blocks has proven fully satisfactory.
Evaluation: All of the proposed calibration blocks have been in use since the plant was built; therefore, their continued use would provide consistent results. Because procuring ;
calibration blocks of the exact materials would be difficult, if not impossible, and because the existing blocks have been proven satisfactory for performing calibrations, the increase in plant safety would not compensate for the burden placed on 80
a- ,
}
I the Licensee that would result from requiring the Licensee to !
s fabricate new calibration blockt to meet the current Code, i The Licensee has demonstrated that the proposed alternative j ovides an acceptable level of quality and safety and that l compliance with the specific Code reoui*ement would result in f hardship or unusual difficulties without a compensating i increase in the level of quality and safety. l
Conclusions:
Based on the above, it is concluded that public-health and safety will not be endangered by allowing the use -
l of the alternative calibration blocks in lieu of the specific 'l Code requirement.- Therefore,pursuantto10CFR50.55a(a)(3), i it is recommended that relief be granted as requested, l i
?
'3.5.1.4 Reouest for Relief No. RR-4.11all Thickness Differences Between Calibration Blocks and Components to be Examined i
Code Reouirement: Section XI, Appendix 111, Paragraph l 111-3410 requires that the basic calibration block be made ;
from material of the same nominal wall thickness or pipe !
schedule as the pipe to be examined.
l j
Licensee's Code Relief Reouest: Relief is requested from the wall thickness requirements for the-following calibration l blocks: .
ALA-5:. Excess. letdown heat exchanger i ALA-RV-7: Reactor _ coolant piping !
.ALA-?4: Main' steam piping )
N A ::5: Feedwater piping 2 Volume control tank
~
AtA 31: -
l
?
The deviations in wall thickness are indicated below: !
l
{
h f
(
81 _
p :
l I l- -F
. -- _ . - . . = - - . . . - . - . . - . - . . - . . . . . . - - . -
- . 'o t
WALL THICKNESS DEVIATIONS Pipe .
Cal. Block Cal. Block Diam. Pi )e Pipe Wall j Number _ Thick. fin.) Lim) Sc ied. Thick. fin.) Material j ALA-5 0.906 8.0 160 0.750 Stainless h ALA-RV 3.000 Flat N/A 2.0 to 3.0 CS/SS j ALA 24 1.200 32.0 Special 1.033 Carbon t ALA-25 0.750 16.0. 100 1.031 Carbon 3 ALA-31 0.388 Flat N/A 0.250 Stainless j t
Licensee's Proposed Alternative Examination: ASME Code I t
Case N-461, Alternate Rules for Piping Calibration Block l Thickness, will be incorporated for use of the above l calibration blocks with the following stipulations: !
i (a) Ultrasonic (UT) thickness measurements and weld joint ;
I measurements of the pipe or component must be available. ;
to the UT inspector prior to performing the angle beam l
examination. It is acceptable to use measurements from a j previous inspection.
I (b) _The 10-year ISI plan and current outage plan shall ;
annotate. components / calibration. blocks which require thickness tolerances per ASME Code Case N-461.
(c) In addition, all UT reflectors 50% distance-amplitun f correction (DAC) and above must also.be recorded and l their position in the weld joint plotted to determine if j the reflectors are relevant indications, 1 I
Licensee's Basis for Reauestina Relief: The Licensee states
[
.that.the existing calibration blocks used for piping and [
-thin wall vessels were designed under the provisions of_ ;
Section V,1974 Edition, Summer 1975. Thickness differences j between the above calibration blocks and the components to be j examined are inconsequential-and would in most cases produce conservative examination results. Fabrication of new j i.
82 l h
w - .,_,_...u..____......_.... - . - , . . . . , , , . . . . . . . , . , . . ,,,,,_-__.,..~,..._.,_,_.__m. ,,..._...,U
calibration blocks for the sole purpose of achieving exact thickness congruity with the component will not improve examination quality.
Calibration blocks ALA-5 and ALA-24 have a nominal thickness greater than the examined piping. Use of a thicker calibration block is conservative since examination of a thinner component would tend to decrease ultrasonic attenuation. ASME Code Case N 461 allows the use of calibration blocks which are within plus or minus 25% of the
. component thickness. The ASME has approved this Code Case and the NRC is considering incorporation of N-461 into a future revision of NRC Regulatory Guide 1.147.
Calibration block ALA-25 has a nominal thickness less than the examined piping The reducer is schedule 100 with a nominal thickness of 1.031 inches; however, in the area of interest, it-is machined to a nominal thickness of 0.758 inch to match the steam generator nozzle thickness. Therefore, use of the 0.750-inch thick calibration block will provide a representative examination of the nozzle to reducer weld.
- Again, application of ASME Code Case N 461, once NRC approval is obtained, would permit use of this calibration block.
. Calibration blocks ALA RV-7 and ALA-31 have a nominal thickness greater than the examined piping. Use of a thicker
~
calibration block is conservative since examination of a thinner component would tend to decrease ultrasonic attenuation.-
- Evaluationi- Pending final review and evaluation by the NRC staff:of ASME Code Case N-461, it appears that the code case will be approved in Revision 8 of NRC Regulatory Guide 1.147 for generic use with supplemental requirements; the supplemental requirements are listed as part of the Licensee's proposed alternative examination.
83
._ -- ~__ . .
?
}
Use of ASME Code Case N 461 for calibration blocks ALA 5, l ALA 24, and ALA 25 is, therefore, acceptable with the f
stipulations listed in the Licensee's proposed alternative !
examination. For calibration block ALA 31, the wall thickness l of the calibration block is not within the range of 125% of j the Volume Control Tank shell wall thickness to be examined. !
-Therefore, ASME Code Case N 461 cannot be applied to calibration block ALA-31. , l i
SectionXI,ParagraphIWA2232(c)allowstheuseofArticle3 ;
of Section V for the ultrasonic examination of piping made of l other than ferritic materials. With regard to calibration block ALA RV-7,Section V, Article 5. Figure T-546.1 allows a calibration block thickness of 3 inches to be used for {
thicknesses between 2 and 4 inches. Therefore, use of this j calibration block is acceptable. :
With the exception of calibration block ALA 31, the Licensee l has demonstrated that the proposed alternative, with the above supplemental requirement, provides an acceptable level of .;
. quality and safety and that compliance with the specific Code .}
l ,
l' requirement would result in hardship or unusual difficulties i without' a _ compensating increase in the level of quality and f safety. [
Conclusions:
Based on the above, it is concluded that public ;
health and safety will not be endangered by allowing the q proposed alternative to be performed in lieu of the-Code j requirements. Therefore, for the calibration blocks listed ;
except calibration block ALA 31, it is recommended that relief _ l be granted pursuant to 10 CFR 50.55a(a)(3). For calibration
. }
, block ALA 31, it is recommended that relief be denied. !
l' ,
f r
l l f 84 [
. _ . _ _ ~ , . _ _ __.. .. _ _ .. _ _ _.. _ .. _ . , _ _ _ . _ . . . _ . . . . . , _ .-
l * ,
3.5.1.5 Recuest for Relief No. RR-5. Curvatur a Differences Betpeen Calibration Blocks and Components to be Examined Code Reouiremani: Section XI, Appendix Ill, Paragraph 111 3410 requires that the basic calibration blocks be made from material of the same nominal diameter as the pipe to be examined.
Licenste's_, Code Relief Recuest: Relief is requested from the curvature requirements for the following calibration blocks used to perform ultrasonic examinations on piping and thin-wall vessels:
ALA-5: Excess letdown heat exchanger ALA-RV-7: Reactor coolant piping ALA 21: Pressurizer skirt ALA 23: Main steam piping ALA-25: Feedwater piping ALA 31: Letdown heat e>, changer; Volume control tank
.ALA-32: Residual heat exchanger ALA/APR-33: Reactor coolant piping The deviations in curvature are indicated below:
CURVATURE DEVIATIONS Cal. Block Cal. Block Con.ponent Component Number Djam. f in . ) Qgscrintion Diam. fin.) Material ALA-5 8 Thin-walled 9.5 Stainless vessel ALA-RV-7 Flat RPV nozzle 27.5, 29.0 CS/SS safe end AL/.-21 Flat Press, skirt 87.00 Carbon ALA 23 Flat Pipe 34.55 Carbon ALA-25 14 Reducer 16 x 14 Carbon ALA-31 Flat Thin-walled 21.78 Stainless vessel ALA-31 Flat Thin-walled 84.00 Stainless vessel ALA-32 Flat Thin-walled 39.75 Stainless vessel ALA/APR-33 29 Pipe 27.5 Cast SS ALA/APR-33 29 Pipe 31.0 Cast SS 35
~ . _
o .
Licensee's Proposed Alternative Examination: The Licensee '
states that the existing calibration blocks for piping and thin-wall vessels are in compliance with the curvature ;
tolerances between the blocks and the test part as required by Section V, 1983 Edition, Summer 1983 Addenda, Paragraph !
T 543.3.
Licensee's Basis for Reauestina Relief: The Licensee states :
that the design of the ex' +1ng calibration blocks was based on the provisions of Se. . ion , 1974 Edition, Summer 1975 Addenda. 0:rr' 7e dif. ..nces between the above calibration blocks ar.d the components to be examined are inconsequential and would, in most cases, result in conservative examination l results. Fabrication of new calibration blocks, fer the sole '
purpose of achieving exact curvature congruity with the component, will not, in Alabama Power Company's judgement, improve examination quality.
Calibration block ALA-25 differs in diameter from the 16-inch diameter reducer which connects the 14 inch diameter feedwater piping to the steam generator nozzle. The talibration block is 14 inches in diameter and is used for examining the 16-inch diimeter reducer to steam c nerator nozzle weld.
Calibration block ALA/APR-33 is used for examination of cast austenitic stainless steel reactor coolant loop piping materials in the hot, cold, and the crossover legs which have I different diameters. The calibration block is the same i nominhl diameter as the hot leg but is of smaller diameter ;
than the crossover leg piping and larger diameter than the ,
cold leg piping. Regardless of the differences in diameter, the NRC has reviewed and accepted the special examination techniques which Alabama Power Company utilizes for reactor coolant loop examination as permitted by Section XI, Paragraph IWA-2240. This review included an attenuation comparison of the calibration block and the coolant loop i
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a piping. It was concluded that the calibration block was
-representative of the installed piping and would therefore provide a conservative examination.
Calibration block ALA-5 was fabricated from 8-inch diameter stainless steel pipe and is utilized for examination of a 9.5-inch diameter component. Regardless, Alabama Power Company utilizes enhanced ultrasonic examination techniques on all stainless steel components. This technique includes requirements that the refracted angle be recorded for each examined component. In addition to the required 45' examination, a 60' examination is also utilized and both are performed at increased sensitivity by adjusting the gain to an average noise level of 10Y,of full screen height. This enhanced examination technique more than idequately compensates for any mismatch between the calibration block and the examined component.
Calibration block ALA-RV-7 is a flat plate fabricated from dissimilar metals and is used to examine the reactor pressure vessel nozzle safe end welds in 27.5 and 29.0-inch diameter piping, Calibration block ALA-21 is fabricated fror carbon steel _ plate and it is used to examine the 87.0-inch diameter pressurizer skirt. Calibration block ALA-23 is fabricated from carbon steel plate and it is used to examine 34.5-inch diameter piping. Calibration blocks ALA 31 and ALA-32 are fabricated from stainless steel plate and are used to examine thin-walled vessels ranging from 22 to 84 inches in nominal diameter. Use of these flat calibration blocks is considered acceptable based on guidance from the ASME Code,Section V, Articles 4 and 5, which state that, for diameters greater than 20 inches, a block of essentially the same curvature or, alternately, a flat basic calibration block shall be used.
Given the large diameter of the components being examined, the flat calibration block is considered to be acceptable. As discussed above, use of the enhanced ultrasonic examination 87 I
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- technique more-than-adequately compensates for any mismatch between.the calibration block and curvature of the examined
' component.
Evaluation: Section XI, Paragraphs-IWA-2232(a) and (c) allow the use of Articles 4 and 5 of Section V, which allow for use of a block of essentially the same curvature or, alternatively, a flat block-for examinations where the examination surface diameter is greater than 20 inches.
Therefore, with regard to the curvature deviations, the use of the subject calibration blocks is acceptable. The Licensee has demonstrated that the proposed alternative provides an acceptable level of quality and safety and that compliance with the specific Code re'quirement would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
Conclusions:
Based on the above, it is concluded that public health and safety will not be endangered by allowing the use of the alternative calibration blocks in lieu of the. specific Code requirement. Therefore, pursuant to 10 CFR 50.55a(a)(3),
it is_ recommended that relief be granted as requested.
-3.5;1.6 'Reauest for Relief'No. RR-6. Materials for Fabrication of 4
Calibrat' ion-Blocks and Acoustic Comoatibility with the Component to be Examined Note: -Relief: Request No. RR-6 was withdrawn by the Licensee
' in the December 7,1989 submittal which states the following: ,
" Relief Request RR-6' pertains to calibration block materials; for piping and thin-walled vessel examinations. After.a substantial comparison of the calibration block and component materials and a review of-the examination requirements of Section XI, Appendix III, Paragraph 111-3411 as clarified by ASME Code Interpretation XI-1-86-61, it was found that all calibration block materials ars
, 88_
I in compliance, therefore, relief request RR.6 is not required and.will be deleted from the ISI-Program with the next revisien.'
3.5.1,7 Reouest for Relief-No. RR-7. Dimensional Reauirements for Calibration Notches Placed in Ultrasonic Calibration Blocks Code Reauirementi Section XI, Appendix III, Paragraph 111-3430 requires that basic calit < tion blocks contain notches that are at_least 1.0 inch lcog and 0.104t - 0.009t2 + 10%/-20% in depth.
Licensee's Code Relief Reauest: Relief is requested from the dimensional requirements for calibration notches placed in ultrasonic calibration blocks ALA-21, ALA-23, ALA-26, and
'ALA-28.
Licensee's-Proposed Alternative Examination: None. The Licensee states that these-piping calibration blocks are acceptable for use as is.
Licensee's Basis for Reauestina Relief: The deviations in the
. calibration- notch dimensions' are as follows:
-ALA-21: The notch depth is_at 2% and should be 10%.
LALA-23: The notch depth is at 2% and.!,hould be 10%.
.ALA-26: The notch is 0.125 inch unia r the required length of 1.0 inches.
ALA-28: The notch is 0.012 inch less.than the -20% tolerance requirement- for depth (the notch depth is at .6% and -
, should:be 10%).
The Licensee states that the.only-possible consequences of these discrepancies is that-the sensitivity level of the-ultrasonic instrument would be sligntly higher than required, resulting in a more critica1' examination. Correcting these conditions on any of the above blocks would not'be prudent and would be of questionable value when considering possible damage to the blocks by subjecting them to additional machining.
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Evaluation: The. undersize notches in the four subject c&libration blocks can only. provide for a more sensitive examination. The proposed calibration blocks have been in use since the plant was built; therefore, their_ continued use would provide consistent results. The Licensee.has demonstrated that~the proposed alternative provides an acceptable level of quality and safety and that compliance ,
with the specific Code requirement would result in hardship or unusual difficulties without a compe'nsating increase in the
' level of quality and safety.
Conclusions:
Based on the above, it is concluded that the proposed alte. natives ~ meet or exceed the intent of the Code requirements and that public health and safety will not be endangered by allowing the alternative calibration blocks to l'e used in lieu of the Code requirement. Therefore,. pursuant to 10 CFR 50.55a(a)(3), it is recommended that relief be .
granted as requested.
3.5.2 Exemoted Comoonents (No relief requests)
.3.5.3 Other-
. 3.5.3.1 Recuest for Relief No. RR-12. Delete VT-4 Visual Examination
[ -Method and Examination Recuirement and-Redefine VT-3 Visual'
~
Examination Method in Accordance With Paraaraoh IWA-2213 of the 1986 Edition of the Code
- i. .
F Code Recuirement: Section XI, Table IWF-2500-1, Examination ,
p . Category F-C, Item F3.50 requires a 100% VT-4 visual examination-of spring type supports, constant load type supports, shock absorbers, and hydraulic and mechanical type snubbers as defined by Figure IWF-1300-1.
Licensee's Code Relief Recuest: Relief is requested from
- performing the Code-required VT-4 visual examination of spring 90
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type supports, constant load type supports, shock absorbers, and hydraulic and mechanical type snubbers.
Licensee's Proposed Alternative Examination: None. The Licensee states that operability tests shall be performed in accordance with the Farley Technical Specifications.
Licensee's Basis for Recuestina Relief: The Licensee states that operability testing was inappropriately included in VT-4 as an examination method. Also, Paragraph IWA-2214(b) of the 1983 Section XI Code is inconsistent with industry visual examination practices. An inspector does not perform bench testing of snubbers / constant load / spring type supports. These activities are performed by maintenance technicians. The 1986 Edition of ASME Section XI has deleted VT-4 examination altogether end has redefined VT-3 to include examinations for conditions that could affect operability or functional adequacy of snubbers, and constant load and spring type supports.
Evaluation: The VT-3 and VT-4 visual examinations have been combined as the VT-3 visual examination in the later editions of the Code (1986) to more clearly define the visual examination requirements. The VT-3 visual examination requirement in the 1986 Edition is equivalent to the Code requirements of the 1983 Edition, Summer 1983 Addenda and, therefore, is an acceptable alternative.
Conclusions:
Based on the above evaluation it is concluded that the proposed alternative examination is equivalent to the _
Code-required examination and provides an acceptable level of quality and safety. Therefore, pursuant to 10'CFR 50.55a(a)(3), it is recommended that relief be granted as requested.
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3.5.3.2 Feouest for Relief No. RR-17. Reference System for All Welds and Areas Sub_iect to Surface or Volumetric Exam.jaation Code Reouirement: Section XI, Paragraph IWA-2610,
- Weld Reference System - General," requires that a reference system shall be established for all welds and areas subject to surface or volumetric examination. Each such weld and area shall be located and identified by a system of reference points. The system shall permit ide'ntification of each weld, location of each weld center line, and designation of regular intervals along the length of the weld.
Licensee's Code Relief Reauest: Relief is requested from establishing a weld reference system for all welds and areas subject to surface or volumetric examination.
Licensee's Proposed Alternative Examinaugn: The Licensee states that administrative controls which are detailed in procedures provide adequate instructions to ensure measurements are repeatable and that any indications can be accurately located.
Licensee's Basis for Reauestina Relief: The Licensee states that to perform actual marking of welds in order to identify each weld centerline, length locations, etc. would require many manhours of radiation exposure. Many of the welds are insulated and as such many manhours of radiation exposure would be required to remove'and reinstall insulation just to facilitate marking. Also, many manhours of radiation exposure would be involved in marking the welds.
Evaluation: For an operating plant, establishing a weld reference system for all welds and areas subject to surface or volumetric examination is a major effort and, in some cases, is prohibited due to inaccessibility and/or high radiation levels. Therefore, the Code requirement for establishing a 92 l
p j i
weld reference system for. all welds subject to examination in j e the absence of examination is impractical- for an operating !
plant.- -In order to establish a weld reference system "or all [
- welds and areas subject to surface and volumetric examinations
'l in accordance with.the requirements, many manhours and j
- man-rems of radiation exposure would be required to perform f
such tasks as locating the welds, removing insulation, marking j the welds, and reinstalling insulation, regardlass of whether j or not the weld is scheduled for examination. The increase in !
plant safety would not compensate for_the burden placed on the- .l Licensee that would result from imposition of the requirement- {
for all welds. .
However,:as. inservice examinations of Class 1 and 2 piping. 1 systems-are performed, each piping weld examined-should !
receive the required reference markings. Impracticality will j not exist for these welds since access will have been provided !
to perform examinations. !
Conclusions:
The marking of all_ welds and' areas subject to:
surface or volumetric examinations required by Section XI of l the ASME Code in the absence of-inspection is irtpractical- at i Farley, Unit 1, because?it-is an operating plant. Imposition l of the requirement on Alabama Power Company would cause.-a: j
- burden that:would-not be compensated.by-an increase-in public - ;
- health and safety. However, as each Class. I and-2 piping; }
' l system is examined, access for marking each weld will be i t
_ provided and impracticality for_ that particular weld will^ not [
exist. Therefore, in order to provide-assurance of t traceability of-the piping welds and repeatability of !
examinations, it is reco: amended that relief be granted -
provided that each Class 1 and-2 piping weld examined receives :
- the required reference markings as the inservice-examinations !
are performed. ;
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e s - - . - . , - _ - ~ _ _ . _ . , . , . . , _ ~ _ , . . . . , _ , , - .. , . , _ - ,,
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3.5.3.3 Reauest for Relief No. RR-41. Break Away Draa Test for 6 -Hydraulic Snubbers Hnig: -The functional- testing of snubbers is not included-in this ~ evaluation. Functional tests are not within the scope of. l I this document and will be evaluated elsewhere.
- 3.5.3.4 Reauest for Relief No. RR-42'.-Additional Samole Testino Recuirements For' Snubbers i
1 I
! Ngig:- The functional testing of snubbers is not-included in E this evaluhtion. Functional tests-are not within the scope of
- j. this document and'will be evaluated elsewhere..
I
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- 4. CONCLUSION i
Pursuant to 10 CFR 50.55a(g)(6) or, alternatively, 10 CFR 50.55a(a)(3), it !
has been determined that certain Section XI required inservice examinations v cannot be performed to the extent required by the Code. In all cases except i Requests for Relief RR-4 (in part), RR-29, and RR-33 (in part), the Licensee j has demonstrated that specific Section XI requirements are impractical or i that alternative examinations should be performed, It is recommended that i relief be granted with conditions for Requests for Relief RR-15, RR-16, and e RR-17. For Requests for Relief RR-4 (in part), RR-29, and RR-33 (in part), l it is concluded that: (a) the Licensee has not provided information to l support the determination that the Code requirement is impractical, and l
(b) requiring the Licensee to comply with the Code requirement would not result in hardship. Requests for Relief RR-6, RR-24, and RR-45 were {
withdrawn by the Licensee and deleted from the ISI Program Plan. Requests l
for Relief RR-41 and RR-42 request relief from the functional testing requirements of IWF-5000 for snubbers. The functional testing of snubbers f is not included in this evaluation. Functional tests are not within the {
scope of this document and will be evaluated elsewhere. t This technical evaluation has not identified any practical method by which the Licensee can nieet all the specific inservice inspection requirements of !
Section XI of the ASME Code for the existing Joseph M. Farley Nuclear Power Plant, Unit 1, facility. Requiring compliance with all the exact Section XI f required inspections would require redesign of a signifi;: ant 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 t edesign efforts, con.plete compliance with the Section XI I
examination requirements probably could not be achieved. Therefore, it is concluded that the public interest is not served by imposing certain provisions of Section XI of the ASME Code that have been determined to be impractical. Pursuant to 10 CFR 50.55a(g)(6), relief is allowed from these !
requirements which are impractical to implement, or alternatively, pursuant I to 10 CFR 50.55a(a)(3), alternatives to the Code-required examinations may [
be granted provided that either (1) the alternative proposed provides an I acceptable level of quality and safety or the (ii) Code compliance would
{
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a .,
result in hardship or unusual difficulty without a compensating increase in safety. - Relief may granted only if granting the relief will not endanger f life or property or the common defense and security and is otherwise in the i public interest giving due consideration to the burden upon the licensee I that could result if the requirements were imposed on the facility.
i The development of new or improved examination techniques should continue to i be monitored. As improvements in these areas are achieved, the Licensee r should incorporate these techniques in the ISI program plan examination requirements. I Based on the review of the Joseph M. Farley Nuclear Power Plant, Unit 1, ;
Second 10-Year Interval ISI Program, through Revision 3, the Licensee's !
responses to the NRC 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 Joseph M. Farley Nuclear Power Plant, Unit 1, Second 10-Year Interval ISI h Program, through Revision 3, is considered unacceptable and not in f compliance with 10 CFR 50.55a(g)(4) due to an unacceptable examination -
sample and unacceptable application of the exclusion criteria (see l' Sections 2.2.2 and 2.2.3 of this report). It is recommended that relief be granted with conditions for Requests for Relief RR-15, RR-16, and RR-17. !
For Requests for Relief RR-4 (in part), RR-29, and RR-33 (in part), it is recommended that relief be denied. Requests for Relief RR-6, RR-24, RR-41, RR-42, and RR-45 either have been withdrawn or are not included in the scope of this document.
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1.- .,. ;
- 5. REFERENCES-l t
a
- 1. Code of Federal Regulations, Volume 10, Part 50. j
~
2.- American Society of Mechanical Engineers Boiler and Pressure Vessel :
Code,Section XI, Division 1: ;
-1983 Edition'through Summer 1983 Addenda j 1974 Edition through Summer 1975 Addenda !
- 3. . Joseph M. 'Farley Nuclear Power Plant, Unit 1, Second 10-Year Interval i Inservice Inspection Program, Revisions 1 and 2, dtted September 9, ,
1988.
- 4. NUREG-0800, Standard Review Plans, Section 5.2.4, " Reactor Coolant f Boundary Inservice Inspection and Testing," and Section 6.6, " Inservice i Inspection of Class _2-and 3 Components," July 1981. !
i 5.. Letter, dated August-3, 1989,-E. A. Reeves (NRC) to W. G. Hairston l (Ala'bama_ Power Company (APCo)), request for-additional information on ;
the Second 10-Year Interval ISI Program.'
- 6. _ Letter, dated October 5, 1989, W. G. Hairston, III (APCo)-to NRC, response to the NRC request for additional information. .
t
- 7. Letter, dated December 7,1989, W. G. tiairston, III (APCo) to NRC, l response to the NRC request for additional information.
- 8. Letter, dated April 12, 1990,.W. G. Hairston, III (APCo) to NRC,.
additional information with regard to the ISI Program and relief-requests. l
- 5. Letter, dated August 15, 1990, W.' G. Hairston,LIII (APCo) to NRC, ;
Revision 3 to the inservice inspection program. !
=10. Letter, dated September 12, 1990, W. G. Hairston, III_(APCo) to NRC, *
< corrections to- Revision 3 of relief requests RR-1,- RR-2, and RR-3.. ;
I 11._ Joseph M. Farley Nuclear Power Plant, Unit 1, Second 10-Year Interval i Inservice Inspection Program,. Revision 0, dated November 23, 1987. l
- 12. Letter, dated ' June 1,1988, A.. R. Herdt. (NRC) to R. P. Mcdonald (APCo),
NRC.Inspecti.on Report Nos. 50-348/88-17 and 50-364/88-17. !
-13. Letter,' dated November-30, 1989, W. G. Hairston, III (APCo) to NRC, j response to the NRC request- for additional =information. ;
14.'- NRC Regulatory Guide l.150,_-." Ultrasonic Testing of Reactor Vessel Welds ,
'During Preservice and Inservice Examinations," Revision 1, l*
February 1983.
L - 15 . NRC Regulatory Guide 1.14, " Reactor Coolant Pump Flywheel Integrity,"
L LRevision 1, August 1975. l t
97 I
F
- 16. NRC Regulatory Guide 1.83, " Inservice Inspection of Pressurized Water i
. Reactor Steam Generator Tubes," dated July 1975. !
- 17. NRC Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 7, July 1989, i
i I:
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BIBLIOGRAPHIC DATA SHEET *
<sa mvre, an ram w .;
a,rateasosesTate EGG-MS-8943 :
Technical Evaluation Report on the Second 10-Year Interval Inservice Inspection Program P1an: 3 - o. n . . oar ,v us so -
Alabama Power Company, Joseph M. Farley Nuclear Power Plant, Unit 1 Novcem 3er l 19g Docket Number 50-348 o m oaca.Nr,vmia FIN D6022 (Proj. 5) ;
6-. Aytwoa(58 6 TYPE oF aEPORT Technical '
B.W. Brown, J.D. Medlin us aioo cova ato ,, , ,..
ysgagg,Ap rion - uaui 4~o .ooa .'
- s. P o..c.,..,-u.,c..-,_,,,,,,,,,,,,,...,,,
EG&G Idaho, Inc. l P. O. Box 1625 ;
I Idaho Falls, -ID 83415-2209 ego g yaAueariou.saveasoaooness,,,..c.,,. w . .,-,.,. - ..co o,,.,. .u . -c .
Materials.and Chemical Engineering Branch Office of Nuclear Reactor Regulation
- U.S. Nuclear Regulatory Commission Washington, D.C. 20555 IQ, StJPPL(VENTARY NQTES e
- 11. ABSTRACT Inc e.= w om
! This report presents'the results of the evaluation of the Joseph M. Farley Nuclear Power Plant, Unit 1, Second 10-Year Interval Inservi e Inspection (ISI) Program, th'ough Revision 3,. submitted August 15, 1990, 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 Joseph M. Farley Nuclear Power Plant, Unit 1, Second 10-Year Interval ISI ;
Program-is evaluated in Section 2 of this report. The ISI Program is evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability l 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- previous Nuclear Regulatory Commission reviews. The requests l for relief are evaluated in Section 3 of this report.
a e v w o a os, o e sc n +1o a s ,v .,,. ,. .,, - ..,,,,, ,. . . , u . . . . . m 1. c . , - ,, ,
Unlimited
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Unclassified ;
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Unclassified '
t h NUM8184 06 P.GEs 16 P541cf
- NAC PCRM 336 W94
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