· IN EL-9510501 Technical Evaluation Report on the Second 10-year Interval Inservice Inspection...

October:1

IdahoNational

EngineeringLaboratory Technical Evaluation Report on the

Second 10-Year Interval Inserviceinspection Program Plan:Pennsylvania Power & Light Company,Susquehanna Steam Electric Station,Units 1 and 2,Docket Numbers 50-387 and 50-388

N. T.'ndersonK Mt'. Hal/A. N. Porter

9'bObi30034 9bOb07>DR ADOCV, OS0003876 PDR

bloc/rhe edIdaho Technologies Co~any

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IN EL-9510501

Technical Evaluation Report on theSecond 10-year Interval Inservice Inspection Program Plan:

Pennsylvania Power 8 Light Company,Susquehanna Steam Electric Station, Units 1 and 2,

Docket Numbers 50-387 and 50-388

IIII. T. AndersonK. W. Hall

A. M. Porter

Published October 1995

Idaho National Engineering LaboratoryMaterials Physics

Lockheed idaho Technologies CompanyIdaho Falls, Idaho 83416

Prepared for theDivision of Engineering

Office of Nuclear Reactor RegulationV.S. Nuclear Regulatory Commission

Washington, D.C. 20555,

Under DOE Idaho Operations OfficeContract DEAC07-S4ID13223

FIN No. L2556 (Task Order 45)

This report presents the results of the evaluation of the Susquehanna SteamElectric Station, Units 1 and 2, Inservice Inspection Program Plan for theSecond Inservice Inspection Interval, Revision 0,. submitted Hay 19, 1994,including the requests for relief from the American Society of MechanicalEngineers (ASHE) Boiler and Pressure Vessel Code Section XI requirements thatthe licensee has determined to be impractical. The Susquehanna Steam ElectricStation, Units 1 and 2, Inservice Inspection Program Plan for the SecondInservice Inspection Interval is evaluated in Section 2 of this report. Theinservice inspection (ISI) program plan is evaluated for (a) compliance withthe appropriate edition/addenda of Section XI, (b) acceptability ofexamination sample, (c) correctness of the application of system or componentexamination exclusion criteria, and (d) compliance with ISI-relatedcomaitments identified during the Nuclear Regulatory Coaeission (NRC) reviewbefore granting an operating license. The requests for relief are evaluatedin Section 3 of this report.

Thi's work was funded under:

U.S. Nuclear Regulatory ComnissionFIN No. L2556, Task Order 45

Technical Assistance in Supportof the NRC Inservice Inspection Program

SUNDRY

The licensee, Pennsylvania Power 5 Light Company, has prepared the Susquehanna

Steam Electric Station, Units I and 2, Inservice Inspection Program Plan forthe Second Inservice Inspection Interval, Revision 0, to meet the requirements

of the 1989 Edition of the ASHE Code Section XI. The second 10-year intervalbegan June 1, 1994, and ends Hay 31, 2004.

The information in the Susquehanna Steam Electric Station, Units I and 2,Inservice Inspection Program Plan for the Second Inservice InspectionInterval, Revision 0, submitted May 19, 1994, was reviewed. In addition, theSusquehanna Steam Electric Station, Units I and 2, System Pressure Test

Program, Revision 0, dated June 8, 1994, and the Susquehanna Steam ElectricStation, Units I and 2, Inservice Inspection Program Haster SelectionDocument', Revision 0, dated June 1, 1994 were reviewed;as part of the ISIProgram Plan. Subsequent references to the ISI Program Plan include thesedocuments. Also included in the review were the requests for relief from theASIDE Code Section XI requirements that the licensee has determined to be

impractical. As a result of this review, a request for additional informationwas prepared describing the information and/or clar ification required from thelicensee to complete the review. The licensee provided the requestedinformation in the submittal dated March 31, 1995.

Based on the review of the Susquehanna Steam Electric Station, Units I and 2,Inservice Inspection Program Plan for the Second Inservice InspectionInterval, Revision 0, and 'of the licensee's response to the Nuclear Regulatory

Commission's request for additional information (RAI), and based on the

recommendations for granting relief from the ISI examinations that cannot be

performed to the extent required by Section XI of the ASIDE Code, no deviationsfrom regulatory requirements or commitments were identified in the Susquehanna

Steam Electric Station, Units I and 2, Inservice Inspection Program Plan forthe Second Inservice Inspection Interval, Revision 0, with the exception ofRequest for Relief RRPT-2.

CONTENTS

BSTRACT o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~A

UHHARY o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~S ~ ~ v

1. INTRODUCTION ............................. 1

2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN........... 4

2.1 Documents Evaluated ........................ 4

2.2 .Compliance with Code Requirements

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

2.2.2 Acceptability of the Examination Sample

2.2.3 Exemption Criteria . . . . . . . . . . . . . ,

2.2.4 Augmented Examination Commitments

2.3 Conclusions ~ i . ~ ~ ~ ~ ~ ~ s ~ e ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~

5

5

5

'6

3.'VALUATIONOF RELIEF REQUESTS................ 7

3.1 Class 1 Components...............;........ 7

3.1.1 Reactor Pressure Vessel . . . . . . .- . . . . . . . . . . . . 7

3.1.1.1 Request for Relief No. RR-2, Examination Category B-D,Item B3.90, Reactor Pressure Vessel (RPV) Nozzle-to-Vessel Welds . . . . . . . . . . . . . . . . . . . . . . . 7

3.1.2.2 Request for Relief No. 'RR-4 (Units 1 and 2),Examination Category B-A, Items Bl.ll, B1.12, 81.22,and Bl.40, Reactor Pressure Vessel (RPV) Pressure-Retaining Welds 10

3.1.2.3 Request for Relief No. RR-S, Examination Category B-O,Item B14.10, Pressure-Retaining Welds in Control RodDrive (CRD) Housings................... 13

3.1.2 Pressurizer (Does not apply to BWRs)

3. 1.3 Heat Exchangers and Steam Generators (No relief requests)

3.1.4 Piping Pressure Boundary . . . . . . . . . . . . . . . . .

3.1.4.1 Request for Relief No. RR-5 (Units 1 and 2),Examination Category B-J, Item B9.11, Class 1 PipingeldsW

15

vii

3.4.4.1 Request for Relief No. RRPT-1, Use of Code CaseN-416-1, Alternative Pressure Test Requirements forfielded Repairs or Installation of Replacement Itemsby Welding. 30

3.4.4.2 Request for Relief No. RRPT-2, Paragraph IMA-5250(2),Corrective Measures for Bolted Connections . . . . . . . . 33

.5 General3 35

3.5.1 Ultrasonic Examination Techniques (No relief requests)

3.5.2 Exempted Components (No relief requests)

.5.3 Other3

3.5.3.1 Request for Relief No. RR-3 (Units 1 and 2), ArticleIMF-5000, Inservice Inspection Requirements forS nubbers . . . . . . . . . . . . . . . . . . . . . . .

3.5.3.2 Request for Relief No. RR-6 (Units 1 and 2), AugmentedExaminations . . . . . . . . . . . . . ... . . . . . .

3.5.3.3 Request for Relief No. N-509, Use of Code Case N-509,Alternative Rules for the Selection and Examination ofClass 1, Z, and 3 Integrally-fielded Attachments,Section XI, Division 1 . . . . . . . . . . . . . . . .

3.5.3.4 Request for Relief No. N-524, Use of Code Case N-524,Alternative Examination Requirements for Longitudinalfields in Class I, and 2 Piping, Section XI,D

~ ~ ~

1 Vl sion 1 o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

36

36

36

39

42

3.5.3.5 Request for Relief No. SS-IMF, Use of Subsection IMFof the 1990 Addenda for Rules for Examination of Class1, 2, and 3 Component. Supports . . . . . . . . . . . . . . 44

3.5.3.6 Request for Relief No. IMX-2430, Use of ParagraphIMX-2430 of the 1992 Edition of the ASME for Rulesfor additional Examinations of Class 1, 2, and 3and Component Supports . . . . . . . . . . . . . .

4. CONCLUSION

5. REFERENCES

46

49

~ ~ ~ ~ 52

TECHNICAL EVALUATION REPORT ON THESECOND 10-YEAR INTERVAL INSERUICE INSPECTION PROGRAM PLAN:

PENNSYLVANIA POMER K LINT COMPANY,SUSQUEHANNA STEAM ELECTRIC STATIONS UNITS 1 AND 2

DOCKET NUMBERS 50-387 AND 50-388

1. INTRODUCTION

Throughout the service life of a water-cooled'nuclear power facility,10 CFR 50.55a(g)(4) (Reference 1) requires that components (includingsupports) that are classified as American Society of Mechanical Engineers

(ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the

requirements, except the design and access provisions and the preserviceexamination requirements, set forth in the ASME Code Section XI, Rules forInservice Inspection of Huclear Poser Plant Components (Reference 2); to the

extent practical within the limitations of design, geometry, and materials ofconstruction of the components. This section of the regulations also requiresthat inservice examinations of components and system pressure tests conducted

during successive 120-month inspection intervals. comply with the requirements

in the latest edition and addenda of the Code incorporated by reference in10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month

inspection interval, subject to the limitations and modifications listedtherein. The components (including supports) may meet requirements set forthin subsequent editions and addenda of this Code that are incorporated by

reference in 10 CFR 50.55a(b) subject to the'imitations and modificationslisted therein and subject to Nuclear Regulatory Commission (NRC) approval.

The licensee, Pennsylvania Power 8 Light Company, has prepared the Susquehanna

Steam Electric Station, Units I and 2, Inservice Inspection Program Plan forthe Second Inservice Inspection Interval, Revision 0 (Reference 3), to meet

the requirements of the 1989 Edition of the ASME Code Section XI. The second

10-year interval began June 1, 1994, and ends May 31, 2004.

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain

Code examination requirements are impractical and requests relief from them,

the licensee shall submit information and justifications to the Nuclear

Regulatory Commission (NRC) to support that determination.

The Susquehanna Steam Electric Station, Units I and 2, Inservice, Inspection

Prograw Plan for the Second Inservice Inspection Intervals is evaluated in

Section 2 of this report. The ISI Program:Plan is evaluated for~ (a) compliance with the appropriate edition/addenda of Section XI,

(b) acceptability of examination sample, (c) correctness of the application ofsystem or component examination exclusion criteria, and (d) compliance with

ISI-related commitments identified during the NRC's previous reviews.

The requests for relief are evaluated in Section 3 of this report. Unless

otherwise stated, references to the Code refer to the ASME Code, Section XI,

1989 Edition. Specific inservice test (IST) programs for pumps and valves are

being evaluated in other reports.

2.2.2

Inservice volumetric, surface, and visual examinations shall be

performed on ASIDE Code Class 1, 2, and 3 components and theirsupports using sampling schedules described in Section XI of the ASHE

Code and 10 CFR 50.55a(b). Sample size and weld selection have been

implemented in accordance with the Code and 10 CFR 50.55a(b) and

appear to be correct.

2.2.3

The criteria used to exempt components from examination shall be

consistent with Paragraphs IMB-1220, INC-1220, INC-1230, IMO-1220,

and 10 CFR 50.55a(b). The exemption criteria have been applied by

the licensee in accordance with the Code, as discussed in the ISI

Program Plan, and appear to be correct.

2.2.4 u ed t on Coma t

In addition to the requirements specified in Section XI of the ASIDE

Code, the licensee has comaitted to perform the following augmented

examinations:

(a) Augmented volumetric or surface examinations to protect againstpostulated piping failures per FSAR 6.6.8;

(b) Augmented ultrasonic in'spection for intergranular stresscorrosion cracking (IGSCC) per NUREG-0313 (Reference 9);

(c) Augmented volumetric, surface, and visual examinations inaccordance with NUREG-0619, SIR Feedwater Nozzle and Control Rod

Drive Return Line Nozzle Cracking .(Reference 10);

(d) Augmented ultrasonic examinations for BNR Jet Pump AssemblyFailure in accordance with NUREG/CR-3052 (Reference 11);

(e) Augmented visual and ultrasonic examinations of RPV internals„,based on industry group recomaendations, BNR plant experience,and PP8L site experience; and

(f) Augmented ISI for vibration-induced failures based on industrygroup recomaendations, BMR plant experience, and PPKL siteexperience.

3. EVALVATIONOF RELIEF RE(UESTS

The requests for relief from the ASIDE Code. requirements that the. licensee has

determined to be impractical for the Second 10-Year Inspection Interval areevaluated in the following sections.

3 I C s e t

3.1.1 e t

3.1.1.1 e

0 o ress e

o t

C~d: I tt XI, I ti IIIX-0000-1, I I ttCategory B-D, Item B3.90, requires a 100% .volumetric examinationof all RPV nozzle-to-vessel welds as defined by FigureIMB-2500-7.

Relief is requested from

performing the volumetric examination, to the extent required by

the Code, for the following RPV nozzle-to-vessel welds.

-"Nozz)e--'": "'---'Umiting"'~":-~~>,'5"'."Comcple'te;,~.:'.: ~C-'Pirt') alai':"'5::iNo',"'Ecxai","

N2A-H J K

Nozzle forgingconfi uration

N1A,B Nozzle forgingconfi uration

77.29.T50 P

75.42 T50 P

4.8

5.67

17.91 T50 P

18.91 T50 P

N3A-D Nozzle forgingconfi uration

73.26 XT

50 P

6.3 20.44 T50 P

N4B,C,E, Nozzle forgingF confi uration

75.42 T50 P

5.67 18.91 T50 P

configuration is slightly more pronounced with the automatedexaminations due to the design of the remote scanner apparatus.The percentages presented in Table RR-2-1 for these nozzles arebased exclusively on automated, examination coverage.

"The N6, N7, NS, and N9 nozzle-to-vessel welds will be examinedsolely by manual ultrasonic examination techniques.

"Automated examinations of two Feedwater nozzle-to-vessel welds-N4A and N4D - are further limited due to plant designobstructions from the N11A and N11B instrumentation nozzles,respectively. A spacing of approximately 4.5 inches'etween theN4 and the Nll nozzles restricts examination of an arc ofapproximately 60 degrees (17%) of the affected nozzle-to-vesselwelds.

"Table RR-2-1 details examination coverage for all the nozzles.These estimates of examination coverage are based on calculationsmade during preservice examinations of the nozzle-to-vesselwelds, and are still considered valid, conservative estimates forthe second inservice inspection interval."

s 0 te v (as stated):

"Examinations will be performed to the maximum extentpracticable. High radiation areas preclude the use ofsupplemental manual examinations; manual examinations yield noappreciable increase in examination coverage. No alternateprovisions are proposed."

Eullil: Th C d q I laDL 1 t I i ti f tlRPV nozzle-to-vessel welds each interval. However; the,configuration of the nozzles restricts access and precludes 10M

volumetric examination. Therefore,: the Code requirement isimpractical for the subject welds. To perform the examinations

to the extent required by the Code, the RPV nozzles would requiredesign- modifications to allow sufficient access. Imposition ofthe requirement would cause a considerable burden on the

licensee.

The licensee stated that 5N of the parallel scans and roughly

75% of the transverse scans can be examined for all of the

Relief is requested from

performing the volumetric examination to the extent required by

the Code for the following RPV welds. The reduced examination

coverage is based on actual coverage from the first ISI interval.

AD Cir cumferential Permanent RPV mirror 85.6%shel l/Bl.11 insulation support

steel

BK Longitudinalshell/81.12

BM Longitudinalshell/B1.12

Permanent RPV mirrorinsulation support'teelPermanent RPV mirrorinsulation supportsteel

81. 1%

81.1%

DG Bottom head Control rod drivemeridional/B1.22 housings limit access

to all but 54" of weld

DH Bottom head Control rod drivemeridional/81.22 housings limit access

to all but 54" of weld

AG Closure head-to- Component flange~flan e/B1.40 eometry

23.7%

23.7%

ice see' for Re est e ef (as stated):

"Examinations of the affected welds will be performed to themaximum extent practical.

"For Item Numbers Bl.ll and B1.12, the limited coveragerepresents a mere 0.56% of the total reactor vessel shell weldlength. The affected welds (AD, BK, and BH) are located outsideof the vessel beltline region. Plant design changes to effectgreater examination coverage represent extreme hardship without a

compensating return in increased plant safety.

"For Item Number B1.22 meridional welds, the total examinationcoverage obtained is the maximum practical due to CRD

obstructions. Examination coverage of the head-to-flange weld(Item Number B1.40) is also the maximum practical due to thecomponent configuration.

3.1.2.3

~C.'I tl Xl. T 01 1110-0000-1,

Examination Category 8-0, Item 814.10, requires a surface orvolumetric examination, as defined by Figure IN8-2500-18, for ISof peripheral CRD housing welds.

cens e' e : Relief is requested from

performing the Code-required examination of the CRD housing-to-

flange welds.

see' e es e (as stated):

"SSES Units 1 and 2 have 185 control rod drive housings per unit;,each control rod drive housing is fabricated with two pressureretaining housing welds - the housing-to-flange weld and thehousing tube A-to-housing tube 8 weld. These welds are subjectto the examination requirements of Examination Category 8-0.

"Relief is requested from examination (surface or volumetric) ofthe CRD housing-to-flange welds due to numerous plant designobstructions. The CRD position indicator probes, CRD shoot outsteel, and CRD flange shields severely limit access to thehousing'-to-flange welds. In addition, high radiation doses inthis area make it impractical to attempt to perform limitedexaminations in the face of these obstacles. The remaininghousing weld is without obstructions and can be completelyexamined.

~ "The CRD housing welds are within the system pressure retainingboundary of Examination Category 8-P; As such, reasonableassurance of the pressure retaining integrity of the flange-to-housing welds is gained through periodic VT-2 visual examinationduring Class 1 system pressure testing."

ce se 's o osed- te native xam a i (as stated):

"No alternate provisions are proposed for the subjectexaminations.".

t: Th 00th 10 tt I h .Itt I 00.have two pressure-retaining welds, 'the housing-to-flange weld and

the housing tube A-to-housing tube 8 weld. The Code requires a

13

3.1.4 o d

3.1.4.1 -5 te 9 C

I II XI, I 01 IN.2500.1, I* I IICategory B-J, Item B9.11, requires surface and volumetricexamination of Class 1 piping welds as defined by

Figure IMB-2500-8.

e see's od e e e t: Relief is requested from


the Code, for the Class 1 piping welds listed below.

- 'Meld:.'"'IO';;.''„."''-:,".;..:,;:,:.::'~::.::Coiifigur'ation/pg'„.;i;::LiiiiitXing.-.,:~"+~'>@":,:4'::.'-Y~i';.;"'''':"::;~~"~"""'~:""4""':.h'SyNstNe0m'. riit~~~>%:.<.''.'< ':Con0dition'~%;:-:;'8>"::~

VRRB311-FM;A5 Elbow-pump/ReactorRecirc/Unit 1

RR pumpinsulationsupportframework

83K SKV

OLA1011-FM-1 Pipe-valve/ Pipe whipFeedwater Unit 1 restraint

DBA2011-FM-50 Valve-flued Componenthead/Reactor Mater configurationClean-u Unit 2

DCA2101-FM-2 Valve-Flued Head/ ComponentRHR Unit 2 confi ur ation

OLA2031-FM-2 Valve-Flued Head/ ComponentFeedwater/Unit 2 configuration

87% SKV

75K Vol

75% Vol

75% Vol

ensee's B s for Re uestin Re e (as stated):

"The Code requires selection of the affected welds forexamination; that is, the stress levels at these particular weldlocations exceed the limits specified in Note (1)(b)(1).However, based on nondestructive examination data from the firstinspection interval, a complete examination of the Code requiredsurfaces and/or volumes cannot be performed on these welds due tophysical plant access restrictions and/or geometry of theadjoining components. Relief is requested. from completenondestructive examination of these components.

15

examinations and the complete examination of other, similar,welds.

3.1.5 (No relief requests)

3.1.6 e s o (No relief requests)

3.1.7 Geree~

3.1.7.1

got~KR

t: I tl XI. I tt Tilt.tttt.l, E I tlCategory B-G-2, Item B7.80, requires a VT-.1 visual examination ofbolting in CRD housings when the housing is disassembled. For

CRD bolting that reveals flaws or relevant conditions that exceed

the acceptance criteria of INB-3517, additional examinations

shall be performed during the current outage in accordance withIMB-2430;

ce see'de e ef Re es : Relief is requested from

performing the Code-required additional examinations for cracking

detected in CRD housing bolting in the head-to-shank fillet area.

s e's as s fo e estin Re ief (as stated):

"The ASME Section XI required .VT-1 visual examination of the CRD

bolting during the first inservice'nspection interval detectedcracking around the shank on the head-to-shank fillet area of thebolt. Detailed metallurgical analysis of the defects determinedthe cracking mechanism to be stress corrosion blunted by generalcorrosion.

"Subsequent engineering and metallurgical analysis concluded thatthe cracking does not compromise plant safety or CRD boltingintegrity. Samples of bolting wi,th up to seven years of servicelife were examined; the deepest cracking was measured at 0.040".Magnified cross-sections of the defects always showed elongatedcorrosion pits with blunted ends. Crack growth calculationsconcluded that the cracks grow at a'ecreasing rate. Theanalysis indicated that it would take 22 years for the worst case

17

bolts. The replacement of bolting coincides with the inspection

frequency of 24 CRDs per outage.

. Additional examinations are performed to provide an indication ofthe extent of the degradation detected during scheduled inservice

inspection. If the degradation is determined to be more than an

isolated case, analys'is of the condition and subsequent

corrective actions are performed if warranted. In this case, the

licensee has performed engineering and metallurgical analysis ofthe cracked bolting. The resulting corrective actions include

replacement of all the bolting with a new design that is more

resistant to the cracking mechanism found in existing bolts. At

the time of the analysis, replacement of all the bolts was

expected to take 12 years, although the analysis indicated thatworst case cracking would take 22 years to grow to the minimum

required bolt diameter. In addition, analysis has shown thatfive of eight bolts could be fully cracked without affecting the

structural integrity of the housing. Therefore, the licensee's

proposed alternative provides an acceptable level of quality and

safety.

~C1: Tl li 'p d lt ti p id

acceptable level of quality and safety. Therefore, it isrecoaeended that the proposed alternative be authorized pursuant

to 10 CFR 50.55a(a)(3)(i).

3.2 Cl s o e

3.2.1 Pr Td 11 i t t t

3.2.2 ~~i

3.2.2.1 es fo e e No. RR-9 U tsCate o C- - t m C5 C ss C

a nat o

e t

t~d e e t: Section XI, Table IWC-2500-1, Examination

Category C-F-1, Item C5.22, requires a surface and volumetric

19

. h ddd

~~

ddhtdtttm: Th Cd I I Iddd I . I I t I

examination for the subject Class 2 piping welds. However,

physical restrictions limit access and prevent complete

volumetric examination. Therefore, the Code requirement isimpractical for these welds. To meet this requirement, design

modifications would be necessary to allow access for examination.

Imposition of this requirement would create a considerable burden

on the licensee.

For each of the welds in this request, a significant portion(>8%) of the volumetric examination and a complete surface

examination can be performed. In addition, these welds are partof larger population of Class 2 welds that will receive complete

volumetric examination. Therefore, patterns of degradation

should be detected by the planned examinations, and reasonable

assurance of the structural integrity of the residual heat

removal system will be provided.

~C: I d th I ti tht d Ill Iperformed and the impracticality of meeting the Code requirements

for the subject welds, it is recommended that relief be granted

pursuant.to 10 CFR 50.55a(g)(6)(i). The partial examinations ofthe subject welds and the complete examination of other, similar,welds will provide adequate assurance of the operationalreadiness of the subject system.

3.2.3 ~Pum «

3.2.3.1 t o Re ie No. R- a t o C te

t 'C 0 ressure-Ret nin We ds es d

nd Cor ra CS Pum

e ova

Mldtddl t: I I XI, T tl IIIC-IIII-I,I I tlCategory C-G, Item C6.10, requires a surface examination, as

defined by Figure IWC-2500-8, for pressure-retaining welds in

Class 2 pumps. Examinations may be performed from either the

outside or inside surface of the component. In the case of

21

Code; also, the pumps are within the system pressure retainingboundaries of Examination 'Category C-H and will be periodicallyVT-i.visually examined during system pressure testing."

t e (as stated):

"Should any of the subject welds become accessible forexamination due to pump disassembly for repair or maintenance, avisual or surface examination (as deemed appropriate at the time)will be performed to the extent practical."

yllultJm Th dd ql f l tl ftt y

pump casing welds. In accordance with the Code, these

examinations can be performed from either the inside or outside

surface of the component. As stated by the. licensee, the subjectRHR and CS pump casing welds are located either inside the pump

or embedded in concrete, therefore, are impractical to examine

from the outside surface. Access for examination is onlypossible on the internal surface of the pumps, which requirescomplete disassembly of the pumps. The disassembly of the pumps

for the sole purpose of examination is a major effort that could

result in damage to the pumps and requiring the disassembly of a

pump to perform the Code-required surface examination would

create a considerable burden on the licensee.

The licensee's proposed alternative is to perform a visual orsurface examination if the pumps are disassembled for maintenance

or repair. The remaining eight welds on the RHR pumps that are

accessible will be examined as required by the Code. In

addition, the pumps are subject to VT-2 visual examination during

system pressure tests. Thus, reasonable assurance of the

operational readiness will be achieved.

B d th l d tl llty f tf y th t d

requirements and the burden associated with the disassembly ofthe pumps, it is recommended that relief be granted pursuant to

10 CFR 50.55a(g)(6)(.i) provided that the pumps are examined ifdisassembled. The examination of other RHR pump casing welds and

23

the first 10-year interval, and for which relief is now requestedfor the second interval, are:

RCIC Turbine Barometric Condenser (TBC) and piping toflan ed connections

HPIC TBC and piping to flanged connections

RCIC Steam Turbine

HPIC Steam Turbine

RCIC Pump Discharge Piping

HPCI Booster Pump to Lube Oil Cooler/TBg

C7.20C7.40

C7.20C7.40

C7.20C7.40

C7.20C7.40

~ C7.40C7.80

C7.40C7.80

.Note: In the March 31, 1995, RAI response, the licenseestated that relief was not required for the steam supplypiping and pump supply piping; therefore, these items wereremoved from the re uest..

e s 'is e est n e i (as stated):

"During the first inspection interval, multiple relief requestswere generated by the licensee due to the inability tohydrostatically pressure test portions of the RCIC and HPCISystems (ref. 1RR-20.1, 20.2, 20.3, 20.4, 20.5, 20.6, 20.7, 20.8,and 2RR-17.1, 17.2, 17.3, 17.4, 17.5, 17.6, and 17.8). - Thealternate provisions consisted of performance of a systemfunctional test for those portions incapable of beinghydrostatically tested. Code Case N-498 permits use of a systemfunctional test in lieu of a hydrostatic test providing that thesystem is in operation for 4 hours prior to the VT-2 examinationfor insulated system, the RCIC and HPCI system are insulated.The 4 hour hold time is not practical for the RCIC and HPICsystems due to suppression pool temperature limitations from thesteam exhaust.

"Also, during the first interval a significant number of problemswere experienced in 'cold springing'ipe to install blanks,cutting and removing supports for access, and removal ofinsulation to prepare and restore from these tests. In addition,it caused alignment concerns due to the magnitude of thealterations. It also increased radiological exposure to stationpersonnel.

25

from the turbine exhausts. In addition, %he pump discharge

piping is maintained full either via static head or keepfill. Ifa leak existed in .the system, the leakage would eventuallymigrate through the insulation and be detected.

cens 'o o ed A te ve i (as stated):

"In lieu of performing a system hydrostatic pressure test on theRCIC and HPCI systems in accordance with Table INC-2500-1,Category C-H, a system functional test shall be performed with aten minute hold time prior to performance of the VT-2examination. The system shall be in operational standby with thereactor at nominal operating pressure a minimum of 4 hours priorto the inspection."

allllttm: Th Cd ql p t thg,I 1digsystem hydrostatic pressure test, in accordance with INC-5000 forClass 2 pressure-retaining components. Code Case N-498 allows a

system leakage test at nominal operating pressure in lieu of theCode-required hydrostatic test provided the applicable hold timerequirements are met (4 hours for insulated systems and 10

minutes for uninsulated systems). The RCIC and HPCI systems atSusquehanna Units I and 2 are insulated systems, therefore, the4-hour hold time requirement applies: However, the licenseecontends that the hold time requirements impractical for these

systems and has requested relief.

To achieve the hold time, the RCIC and HPCI must be operated for4 hours, which would result in excessive heat-up of the

suppression pool from the turbine exhausts. Therefore, the4-hour hold time requirement is impractical for these systems.

To meet the hold time requirement, the system would have to be

redesigned to accommodate the suppression pool heat-up.

Alternatively,,removal of the insulation for the sole purpose ofperforming the 10-year hydrostatic pressure test (or leakage testper Code Case N-49&) would result in excessive radiation exposure

to plant personnel. Imposition of this requirement would create

a considerable burden on the licensee.

27

lieu of the requirements of IMD-5223(f) of the 1989 Edition ofthe ASHE Code.

n i (as stated):

"In accordance with 10 CFR 50.55a paragraphs (g)(4) and(g)(5)(i), prior to the start of the inservice inspectioninterval, the inservice inspection program must be revised toincorporate Code editions and addenda as referenced in10 CFR 50.55a(b). Per 10 CFR 50.55a(g)(4)(ii), the governingCode for subsequent inservice inspection intervals is the latestedition and addenda of the Code incorporated by reference in theregulations 12'months prior to the start of the inserviceinspection interval. Given a June 1, 1994, start-of-intervaldate, the latest referenced Code is the 1989 Edition of ASHESection XI. Relief is requested to allow the use of ParagraphIMD-5223 of the 1992 Edition incorporating the 1992 Addenda inlieu of Paragraph IMD-5223 of the 1989 Edition of the Code.

"The 1992 Addenda to the 1992 Edition of the Code has deleted therequirement for pneumatic pressure testing the HSRV dischargelines at a 9R head pressure (7.8 psig 'for SSES). This test doeslittle to identify leakage in these lines except gross leakage.Mhen this system is utilized during a relief/safety valveactuation the piping momentarily experiences pressures up toreactor pressure. Any leakage would be detected by containmentpressure and temperature instrumentation."

ice se 's o os d Alter t ve a na ion (as stated):

"Relief is requested to allow the use of Paragraph IMD-5223 ofthe 1992 Edition incorporating the 1992 Addenda in lieu ofParagraph IMD-5223 of the 1989 Edition of the Code."

t : Th tl h p p d f th q I t fIMD-5222 of the 1992 Addenda in lieu of the Code of record.

IN-5223(f) of the 1989 Code requires a pneumatic pressure test(in lieu of a hydrostatic pressure test) at 9N of the pipesubmergence head of water for discharge lines of open-ended

safety or relief valves that discharge into the containment

suppression pool. IMD-5222(f) of the 1992 Addenda exempts thispiping from the hydrostatic pressure test requirements..

The subject open-ended piping is designed to direct the discharge

from the safety and relief valves into the containment

suppression pool and, therefore, leak integrity is not critical

29

weldment and its associyted NDE provides the structural integrity.of a repair/replacement. The intent of a pressure test is toexamine the repair/replacement for leakage only. This can beaccomplished through a System. Leakage, Functional, or InserviceTest as applicable. This provides an acceptable level of qualityand safety while significantly reducing the need to alter systemsto perform a hydrostatic test and reduces worker radiologicalexposures."

o t a i (as stated):

"Per this relief request, Code Case N-416-1 has been included foruse in this ISI Program Plan."

allldJll: S tI Nl f th C d q I y t hyd t t!test to be performed in accordance with IMA-5000 after repairsmade by welding on the pressure-retaining boundary. The 'licensee

has proposed the use of Code Case N-416-1 in lieu of the Code

requirements. Code Case N-416-1 specifies that NDE of the welds

be performed in accordance with the applicable subsection of the

1992 Edition of Section III. The Code Case also allows a VT-2

visual examination to be performed at nominal operating pressure

and temperature in conju'nction with a system leakage test, inaccordance with Paragraph IMA-5000 of the 1992 Edition ofSection XI.

The 1989 Editions of Sections III and XI are the latest Code

editions referenced in 10 CFR 50.55a. The NRC staff has compared

the system pressure test requirements of the 1992 Edition ofSection XI to those of the 1989 Edition. In summary:

I

1) The'test frequencies and the pressure conditions associated

with these tests have not changed;

2) The hold times have either remained unchanged or increased;

3) The terminology associated with the system pressure testrequirements for all three Code classes has been clarified and

streamlined; and

31

of Code Case N-416-1, be authorized pursuant to10 CFR 50.55a(a)(3)(ii) provided that an additional surface

examination is performed on the root pass layer of Class 3 buttand socket welds. The use of this Code Case should be authorize'd,

until the Code Case is approved for general use by reference inRegulatory Guide 1.147. After that time, the licensee may

continue to use Code Case N-416-1 with the limitations, if any,

listed in Regulatory Guide 1.147.5

3.4.4.2

~Cd t: 5 tt XI. I I dt IIIX-525522), 5 I

that if leakage occurs at a bolted connection, the bolting shallbe removed, VT-3 visually examined for corrosion, and evaluated

in accordance with IMA-3100.

e : . Relief is requested from the

requirement of IWA-5250(2) to remove bolting at leakingconnections for performance of the VT-3 visual examination.

e see'i fo e uestin Re ie (as stated):

"Removal of bolting to perform a VT-3 examination requires thesystem to be placed in an inoperable condition without assurancesthat the bolting has corroded sufficiently to mandate itsreplacement. Leakage from bolted connections is. usuallylocalized and does not require removal of all bolting forexamination."

In the November 28, 1994, RAI, two events'ere cited regarding

bolting degradation and the licensee was requested to verify thatat least one bolt closest to leakage would be removed for visual

inspection. In response, the licensee stated:

Event Report Number 26899, dated 3/8/94, and Event Report Number 26992,dated 3/25/94).

33

88189899 1 d 1th th 1989 ddt tl 9 tl C d, h

leakage occurs at bolted connections, all bolting is required tobe removed for VT-3 visual examination. In lieu of the Code-

required removal of bolting to perform a VT-3 visual examination,the licensee has proposed to perform an in-place VT-3 visualexamination. If warranted by the level of corrosion, thelicensee will perform an engineering evaluation, including theremoval of a bolt for further examination, if necessary.

VT-3 visual examinations are conducted to determine the generalmechanical and structural condition of components, including thepresence of corrosion. The licensee states "The level ofcorrosion will be evaluated against applicable VT-3 acceptance

criteria first, then, if required, an engineering evaluation willbe performed." However, the Code does not. contain acceptance

standards for VT-3 visual examination of bolts, only for VT-I

visual examination. Therefore, the licensee's proposal isinadequate. To be found acceptable, the visual examinationshould be based on a definitive standard, such as the VT-I

standard. In addition, it appears that there is no establishedevaluation procedure or criteria, thus the licensee's proposalcannot be evaluated properly.

~C: 8 8 th 1 tl 9, ltl ddthat relief. be denied. The licensee's proposal does not containadequate standards for bolting evaluation and has not provided

adequate information to justify the impracticality or burden

associated with performing the Code-required examination.

3.5 General

3.5.1 Ultrasonic to ec es (No relief requests)

1

3.5.2 E em ted Co one t (No relief requests) .

35

iiil~ '' ';.::.':;.; .... '.".",,g '.g %)'"'.':.;,4,, >>>;:'; '., 'x; g..'~~,.'F'i.'>".;

.'Exae"'.-':'',':<. %".; l'l::."'""'':4j""''"'"'":,',;,Conf)guratfon/j;',";'.':g(,'LRmft)4g$,':5iurc4i:~~"'~:c'oii"os'ent'i",".':":;::i<'.:.'.",Syst'eai')CPNF4)"'".':<::,:,:Con'dit$ ori'!P;:: .Cove%'8 8~%

FSARSection6.6.8

FSARSection6.6.8

OBA1012-FM-6

DBB1181-1-A

OBA2011-FM-50

DLA2031-FM-2

DBA2011-FW-23

N4B-IR

N4B-Bore

Pipe-Flued Head/Reactor MaterClean-u Unit 1

Pipe-Sweepolet/Feedwater Unit 1

Pipe-Flued Head/Reactor WaterClean-u Unit 1

Pipe-Flued Head/Feedwater Unit 2

Elbow-Valve/Reactor MaterClean-u Unit 2

Nozzle IR/Feedwater Unit 1

Nozzle bore/Feedwater Unit 1

Hanger*;18R field

Meldedsu ortMeldgeometry

Meldeometr

MeldedsupportbracketBio-ShieldMallBio-ShieldMall

N vol

7% vol

75% vol

75% vol

35% vol

84.7%vol84. Rvol

NUREG-0619 N4D-IR

N4D-Bore

DBB1071-1-B

Nozzle IR/Feedwater/Unit 1

Nozzle bore/Feedwater/Unit 1

Elbow-Pipe/RHR/Unit 1

Thermo-couple

ads

Thermo-couple

ads

Permanentpipesupportsaddle

83.6Xvol

84.4%vol

84K vol

DCB1021-FM-2 Val ve-FluedHead RHR Unit 1

Componentconfi .

5Ã vol

NUREG-0313 DCB1021-FM-4

Category C

OBB2071-FM-3 Pipe-Valve/RHR/Unit 2

Adjacentpipesupport,vent lineand.componentconfi .

Flued Head-Elbow/ WeldedRHR Unit 1 i e clam

89.4%vol82.5%vol

37

welds susceptible to intergranular stress corrosion cracking(IGSCC). For the welds listed in this request, physicalrestrictions prevent complete 'volumetric examination. Thus, theaugmented examinations of the subject welds are impractical toperform. To perform a 10K volumetric examination on each weld,

design modifications would be, required to allow access forexamination. This would cause a considerable burden on thelicensee.

In most cases, a significant portion (>75%) of the volumetricexamination can and will be performed. Therefore; reasonable

assurance of structural integrity will be provided. In the case

of Meld DBA1012-FM-6, the volumetric examination cannot be

performed without removal of a hanger, which is located, in an

18R/hr field. Removal of this hanger for the sole purpose ofperforming an examination represents a significant burden.

However, this weld is part of a larger examination sample ofwelds that are being completely examined. In addition, this weld

will receive the Code-required pressure tests with the rest ofthe Class 2 piping. Therefore, reasonable assurance of theoperational readiness will be provided.

C *Idhgth Ip tl iity f tIgthaugmented examination requirements and the examinations that are

being completed, it is recommended that this request be approved.

s or e e No. N-509 Use of Code Case N-5 9 te 've

t Se ectio and m'n t'o o

ded tt chments ct 'o D'

The Code requires examination of integrally-welded attachments as specified under, Examination Categories B-H,

B-K, C-C, D-A, D-B, and D-C. These categories stipulate

39

This Code Case has only recently been approved by ASIDE and was

not available for inclusion in the latest issue of Regulatory

Guide 1.147. 'ndorsement of this Code Case is anticipated in a

future revision of the Regulatory Guide.

e se 's Pro osed te t ve (paraphrased): Code

Case N-509 will be used in lieu of the Code requirements forClass 1, 2, and 3 integrally-welded attachments.

Q Quart o 1: The licensee has proposed, as an 'alternative to the

Code requirements, to apply the requirements of Code Case N-509

for the examination of integr'ally-welded attachments on Class 1,

2, and 3 piping and components. Code Case N-509 provides

alternative sampling requirements for the examination of Class 1,

2, and 3 integral attachments.

Review of this Code Case indicates that there is an ambiguity inthe notes of the examination tables that would allow the

selection of a 1& sample of the integrally-welded attachments

from the percentage of component supports selected forexamination under the rules of the Code (specifically,Subsection INF of the 1990 Addenda). This could potentiallyreduce the examination sample to an insignificant amount, or to

no integral attachments at all. The INEL staff believes thatCode Case N-509 should be enhanced to ensure that this does not

occur. Therefore, use of Code Case N-509 is acceptable provided

that the licensee schedules a minimum of 1% of integralattachments in all Class 1, 2, and 3 systems.

~C: Th li 'p 4 it ti f th

examination of integral attachments will provide an acceptable

level of quality and safety. Therefore, it is recommended that

this alternative be authorized, pursuant to

41

interest of optimizing inservice inspection. examinations; offersa significant reduction in the extent of inservice inspection

examinations while continuing.to provide acceptable levels ofplant quality and safety.

This Code Case has only recently been approved by ASHE and was


Guide 1.147. Endorsement of this Code Case is anticipated in a


e se ' osed lte t t (paraphrased): Code

Case N-524 will be used in lieu of the Code requirements forClass 1 and 2 longitudinal weld seams.

~t: AMES tl XI ql th. i ti f pIp

diameter, but not more than 12 inches,:of Class 1 longitudinal

piping welds. For Class 2 piping welds, the length oflongitudinal weld required to be examined is 2.5 times the pipe

thickness. These lengths are measured from the intersection with

the circumferential weld. The licensee's proposed alternative,Code Case N-524, limits the extent of examination of Class 1 and

2 piping welds to the portion contained within the examination

area of the intersecting circumferential weld.

Longitudinal welds are produced during manufacture of the piping,not in the field as is the case for circumferential welds.

Consequently, the welds are fabricated under the strictguidelines specified by the manufacturing standard, which

provides assurance of structural integrity. These welds have

also been subjected to the preservice and initial inservice

examinations, which provide additional assurance of .structural

integrity. Additionally, no significant loading conditions or

material degradation mechanisms have become evident to date that

43

significant hardship; the requirements are, however, consideredto be cumbersome and difficult to implement. Items Numbers foundin Table IMF-2500-1, may require a single support to be dissectedinto various "sub-components" 'for examination. Given thequantity of supports typically found in a nuclear power facility,the task of managing support examinations would become quitemassive. Subsection IMF of the 1990 Addenda of the Code,however, offers alternative, simplified rules for examination ofClass 1, 2,'nd 3 component supports resulting in a moreeffective, more easily managed component support inspectionprogram.

"The 1990 Addenda has not yet been incorporated into 10CFR50.55aby reference in 10CFR50.55a(b)(2). However, the rules found inSubsection IMF of the 1990 Addenda reflect incorporation of thealternative examination requirements for Class 1, 2, and 3

component supports found in ASIDE Code Case N-491, "AlternativeRules for Examination of Class 1, 2, 3 and MC Component Supportsof Light-Mater Cooled Power Plants". Code Case N-491 isconsidered acceptable for use per Regulatory Guide 1.147.'odeCase N-491, and likewise Subsection IMF (1990 Addenda),effectively provides simplified rules for .selection andexamination of Class 1, 2, and 3 component supports whilemaintaining acceptable levels of plant quality and safety.

"In addition, this ISI Program has adopted the alternative rulesfor examination of Class 1, 2, and 3 integrally weldedattachments found in Code Case N-509, "Alternative Rules for theSelection and Examination of Class 1, 2, and 3 Integrally MeldedAttachments". Code Case N-509 references, and requires theconcurrent use of, Subsection IMF of the 1990 Addenda."

i e see's Pro osed Alternative ami t o (as stated):

"Subsection IMF of the 1989 Edition of the Code with the 1990Addenda will be used 'for rules for examination of SSES Units 1

and 2 Class 1, 2, and 3 component supports in lieu of SubsectionIMF of the 1989 Edition of the Code.".

BtalglttiI: Th C d f d f th S q h s d

10-Year ISI Interval is the 1989 Edition of the ASIDE Code. In

the Program Plan, the licensee has used Subsection IMF of the

1990 Addenda of the 1989 Code. These rules were'riginallypublished in Code Case N-491, which was approved for general use

by incorporation into Regulatory. Guide 1.147, Revision 11

45

flaws or relevant conditions which exceed the specifiedacceptance standards are subject to additional examinations.Imp'lementation of the Code rules governing additionalexaminations does not represent a significant hardship; however,the Additional Examinations rules found in the 1989 Code areconsidered to be somewhat random and difficult to quantify. TheAdditional Examinations rules found in the 1992 Edition of theCode offer an enlightened, clearer approach to additionalexaminations.

"The 1992 Edition of the Code has not yet been incorporated into10CFR50.55a by reference in 10CFR50.55a(b)(2). In accordancewith 10CFR50.55a(a)(3), PP8L proposes the appropriate use of thealternative inservice inspection requirements of ParagraphsIMB-2430, IMC-2430, IMD-2430, and IMF-2430 of the 1992 Edition ofthe Code for rules governing the implementation of AdditionalExaminations of SSES Units 1 and 2 Class 1, 2,'nd 3 components(and component supports). These alternative requirements are tobe invoked in lieu of the requirements found in the 1989 Editionof the Code (or 1990 Addenda for component supports).

"The 1992 Code rules attempt to clarify the quantity ofadditional examinations required, while also allowing for theadditional sample(s) to target components of similar materialsand service, and subject to similar flaws, conditions, andfailure modes, as opposed to a random sampling of "like"components. That is, once a flaw mechanism or relevant conditionis characterized, this information may be utilized to identifyengineered samples of other components to interrogate for similarflaws or relevant conditions. This approach is more in line withthe methodology PPEL has, and will continue to utilize todisposition non-conforming conditions, and in no way compromisesthe level of plant quality and safety."

ic e 's P o ed A ter t ve a tio (as'stated):

"Mhen it becomes necessary to invoke the rules for AdditionalExaminations, the alternative requirements found in ParagraphsIWB-2430, IMC-2430, IMD-2430, and IMF-2430 of the 1992 Edition ofthe Code will be used for additional examination of SSES Units 1

and 2, Class 1; 2, and 3 components and components supports."/

yillmfjm: Additl 1 3 ti q I d by th c d

when examinations performed in accordance with Table IMB-2500-1

reveal'indications that exceed Code acceptance standards. These

additional examinations are to include the remaining welds,

47

4. CONCLUSION

Pursuant to 10 CFR 50.55a(g)(6)(i), it has-been determined that certaininservice examinations cannot be performed to the extent required by

Section XI of the ASNf Code. In the cases of Requests for Relief RR-1, RR-2,

RR-4, RR-5, RR-S, RR-9, and RRPT-3, the licensee has demonstrated thatspecific Section XI requirements are impractical and it is recommended thatrelief be gr anted. The granting of relief will not endanger life, property,or the comon defense and security and is otherwise in the public interest,giving due consideration to the burden upon the licensee that could result ifthe requirements were imposed on the facility.

Pursuant to 10 CFR 50.55a(a)(3)(i), it is concluded that in the case ofRequest for Relief RR-7, the licensee's proposed alternative provides an

acceptable level of quality and safety in lieu of the Code-required

examination and it is recomended that the proposed:alternative be authorized.

In the. case of Requests for Relief RRPT-4, N-509, N-524, SS-IMF, and IMX-2430;

the licensee's proposed alternative provides an acceptable level of qualityand safety if the condition(s) discussed in the evaluation are met. In these

cases, it is recommended that the proposed alternatives be authorized only ifthe licensee meets the specified conditions.

Pursuant to 10 CFR 50.55a(a)(3)(ii,), it is concluded that in the case ofRequest for Relief RRPT-1 the licensee has demonstrated that specific Section

XI requirements would result in hardship or unusual difficultywithout a

compensating increase in. quality and safety. However, it is recoamended thatthe proposed alternative, be authorized only if the licensee meets the

condition contained in the evaluation of the relief request.

For Request for Relief RRPT-2, it is concluded that i) the licensee has not~ provided information to support the determination that the Code requirement is

impractical, and ii) requiring the licensee to comply with the Code

49

F,

Cy

V

Based on the review of the Susquehanna Steam Electric Station, Units 1 and 2,

Second 10-Year Interval Inservice Inspection Program Plan, Revision 0, the

licensee's response to the NRC's request for additional information, and the

recomnendations for granting relief from the ISI examinations that cannot be

performed to the extent required by the Code, no deviations from regulatory

requirements or commitments were identified in the Susquehanna Steam ElectricStation, Units 1 and 2, Second 10-Year Interval Inservice Inspection Program

Plan, Revision 0, with the exception of Request for Relief RRPT-2.

51

«« ~ d I« v* t 4««l«et

NRC oCRM 2252 99s ~

'«RC«d 1 IC2,2201. 202

U4. NUCLEAR REGULATORY COIst, ~ION

BIBUOGRAPHIC DATA SHEETISttinrrnrcrlonr on rht rtrtrrtI

I. REPORT t«U«sERi~ tsr stRc. Aot voc. woo.. Rotto«sot sss««trots. il sr«>.1

'.

TITLE ANO SUBTITLE

Technical Evaluation Report on the Second 10-YearInterval Inservice Inspection Program Plan:.Pennsylvania Power 5 Light CompanySusquehanna Steam Electric Station, Units 1 and 2Docket Numbers 50-387 and 50-388

5. AUTHOR(SI

INEL-95/0507

S. 'DATE REPORT PUELISREO

MQsr 2 st tSAR

October 1995 .

4. FIN OR GRANT NUSISER

FIN-L2556 Task 456. TYPE OF REPORT

~

Technical

M. T. Anderson, K. M. Hall, A. M. Porter 2. PERIOO COVEREO Isocloosr Ones:

~ 6. PERFORMING ORGANIZATION NAMEAND AOORESS IIINRC ProesdeOhs«oo,rIIIsctoriletdon, IIS.HsscsesrRetssrssoetsC«ttotsssion,todrood«rtttddrtsAIIcoolrecror oro «oe

n«ot «sd rr««1 rett tddresal

INEL/LITCOP.O. Box 1625Idaho Falls, ID 83415-2209

9. SPONSORING ORGANIZATION NAMEANO AOORESS IirrIRC. lydt "S«tttosotost lllconrrtcsor drondtIIIICD»rdon. Crr»tor Rertoo, Ild. Itoc»trnttooeoorr Coo««s««ss«o«s.

«sd nt«'ised ods»tsLI

Materials and Chemical Engineering Br anchOffice of Nuclear Regulatory CommissionU.S. Nuclear Regulatory CommissionWashington, O.C. 20555

10. SUPPLEMENTARY NOTES

11. ABSTRACT l2OO wort» or slssl

This report presents the results of the evaluation. of the Susqqehanna Steam Electric. Station, Units 1 and 2, Second 10-Year Interval Inservice Inspection (ISI) ProgramPlan, submitted May 19, 1994, including the requests for relief from the AmericanSociety of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XIrequirements that the licensee has determined to be impractical. The SusquehannaSteam Electric Station, Units 1 and 2, Second 10-Year Interval ISI Program Plan isevaluated in Section 2 of this report. The ISI Program Plan is evaluated for (a)compliance with the appropriate edition/addenda of Section XI, (b) acceptability ofexamination sample, (c) correctness of the application of system or componentexamination exclusion criteria, and (d) compliance with ISI-related commitmentsidentified during previous Nuclear Regulatory Commission (NRC) reviews. Therequests for relief are evaluated in Section 3 of this report.

12. KEY WOR OSIOESCRIPTORS lrlsr s«on» orsshroses cher rr«d os«sr rose«chere ln rocert«t rrN noon.l 12 AVASLASILSrr 1 ~

Unlimitedlc. ssctIRtrr cM ~

Irh» Ates

UnclassifiedIrho Aeoons

UnClaSSiftodI5. NUMSER Os ~ o ~ «

16. PRICE

IIRC I'ORM 22S 12491

' e ~

1

tf

It

C

INEL-95I0507

Technical Evaluation Report on theSecond 10-year Interval Inservice Inspection Program Plan:

Pennsylvania Power 8 Light Company,Susquehanna Steam Electric Station, Units 1 and 2,

Docket Numbers 50-387 and 50-388

M. T. AndersonK.W. Hall

A. M. Porter

Published October 1995

idaho National Engineering LaboratoryMaterials Physics

Lockheed Idaho Technologies CompanyIdaho Falls, idaho 83415

Prepared for theDivision of Engineering

Office of Nuclear Reactor RegulationU.S. Nuclear Regulatory Commission

Washington, D.c. 20555Under DOE idaho Operations Office

Contract DEWC07-94ID13223FlN No. L2556 @ask Order 45)

Es I, ~ ~

0

ABSTRACT

This report presents the results of the evaluation of the Susquehanna SteamElectric Station, Units I and 2, Inservice Inspection Program Plan for theSecond Inservice Inspection Interval, Revision 0, submitted Hay 19, 1994,including the requests for relief from the American Society of HechanicalEngineers (ASHE) Boiler and Pressure Vessel Code Section XI requirements thatthe licensee has determined to be impractical. The Susquehanna Steam ElectricStation, Units I and 2, Inservice Inspection Program Plan for the SecondInservice Inspection I'nterval is evaluated in Section 2 of this report. Theinservice inspection (ISI) program plan is evaluated for (a) compliance withthe appropriate edition/addenda of Section XI, (b) acceptability ofexamination sample, (c) correctness of the application of system or componentexamination exclusion criteria, and (d) compliance with ISI-relatedcommitments identified during the Nuclear Regulatory Commission (NRC) reviewbefore granting an operating license. The requests for relief are evaluatedin Section 3 of this report.

This work was funded under:

U.S. Nuclear Regulatory CommissionFIN No. L2556, Task Order 45

Technical Assistance in Supportof the NRC Inservice Inspection Program

h. ~ g(~

0

SUHNARY

The licensee, Pennsylvania Power & Light Company, has prepared the Susquehanna

Steam Electric Station, Units 1 and 2, Inservice Inspection Program Plan forthe Second Inservice Inspection Interval, Revision 0, to meet the requirements

of the 1989 Edition of the ASHE Code Section XI. The second 10-year intervalbegan June 1, 1994, and ends Hay 31, 2004.

The information in the Susquehanna Steam Electric Station, Units 1 and 2,Inservice Inspection Program Plan for the Second Inservice InspectionInterval, Revision 0, submitted Hay 19, 1994, was reviewed. In addition, theSusquehanna Steam Electric Station, Units 1 and 2, System Pressure Test

Program, Revision 0, dated June 8, 1994, and the Susquehanna Steam ElectricStation, Units 1 and 2, Inservice Inspection Program Haster SelectionDocument, Revision 0, dated June 1, 1994 were reviewed as part of the ISIProgram Plan. Subsequent references to the ISI Program Plan include thesedocuments. Also included in the review were the requests for relief from the

~

~

~ ~

~

~ ~

~

~

ASHE Code Section XI requirements that the licensee has determined to be

impractical. As a result of this review, a request for additional informationwas prepared describing the information and/or clarification required from thelicensee to complete the review. The licensee provided the requestedinformation in the submittal dated Harch 31, 1995.

Based on the review of the Susquehanna Steam Electric Station, Units 1 and 2,Inservice Inspection Program Plan for the Second Inservice InspectionInterval, Revision 0, and of the licensee's response to the Nuclear RegulatoryCommission's request for additional information (RAI), and based on therecommendations for granting relief from the ISI examinations that cannot be

performed to the extent required by Section XI of the ASHE Code, no deviationsfrom regulatory requirements or comaitments were identified in the Susquehanna

Steam Electric Station, Units 1 and 2, Inservice Inspection Program Plan forthe Second Inservice Inspection Interval, Revision 0, with the exception ofRequest for Relief RRPT-2.

~ ~ I

CONTENTS

BSTRACT ~ ~ ~ ~ ~ ~ ~'

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~A

SUMMARY o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ v

1. INTRODUCTION

2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN .

2.1

2.2

Documents Evaluated

Compliance with Code Requirements

4

4

2.2.1 Compliance with Applicable Code Editions .

2.2.2 Acceptability of the Examination Sample

2.2.3 Exemption Criteria . . . . . . . . . . . . . . . .

2.2.4 Augmented Examination Commitments

2.3 Conclusions

3. EVALUATION OF RELIEF REQUESTS .

3.1 Class 1 Components .

3. 1. 1 Reactor Pressure Vessel

4

5

5

5

6

~ ~ 7

~ ~ 7

7

3. 1. 1. 1 Request for Relief No. RR-2, Examination Category B-D,Item B3.90, Reactor Pressure Vessel (RPV) Nozzle-to-Vessel Welds . . . . . . . . .„. . . . . . . . . . . . . . 7

3.1.2.2 Request for Relief No. RR-4 (Units 1 and 2),Examination Category B-A, Items Bl.ll, Bl.12, B1.22,and Bl.40, Reactor Pressure Vessel (RPV) Pressure-Retaining Welds 10

3. 1.2.3 Request for Relief No. RR-B, Examination Category B-O,Item B14. 10, Pressure-Retaining Welds in Control RodDrive (CRD) Housings . . . . . . . . . . . . . . . . . . . 13

3.1.2 Pressurizer (Does not apply to BWRs)

3. 1.3 Heat Exchangers and Steam Generators (No relief requests)

3. 1.4 Piping Pressure Boundary . . . . . . . . . . . . . . . . . . . 15

3. 1.4. 1 Request for Relief No. RR-5 (Units 1 and 2),Examination Category B-J, Item B9. 11, Class 1 Pipingel dsW 15

vi 1

3. 1.5 Pump Pressure Boundary (No relief requests)

3. 1.6 Valve Pressure Boundary (No relief requests)

3. 1. 7 General 17

3.1.7.1 Request for Relief No. RR-7 (Units 1 and 2), ParagraphIMB-2430, Additional Examinations for Bolting inControl Rod Drive (CRD) Housings . . . . . . . . . . . . ~ 17

3.2 Class 2 Components .

3.2. 1 Pressure Vessels (No relief requests)

3 ~ 2o2 Piping e ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ' ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

19

19

3.2.'2. 1 Request for Relief No. RR-9 (Units 1 and 2),Examination Category C-F-1, Item C5.22, Class 2

Circumferential Piping Welds . . . . . . . . . . . . . . . 19

.2.3 Pumps3 21

3.2.3. 1 Request for Relief No. RR-l, Examination Category C-G,Item C6. 10, Pressure-Retaining Welds in Residual HeatRemoval (RHR) and Core Spray (CS) Pumps . . . . . . . . . 21

3.2.4 Valves (No relief requests)

3.2.5 General (No relief requests)

3.3 Class 3 Components (No relief requests)

3.4 Pressure Tests . . . 24

3;4. 1 Class 1 System Pressure Tests (No relief requests)

3.4.2 Class 2 System Pressure Tests

3.4.2.1 Request for Relief No. RRPT-3 (Units 1 and 2),Examination Category C-H, Items C7.20, C7.40, C7.60and C7.80, Hydrostatic Pressure Testing of ReactorCore Isolation Cooling (RCIC) and High PressureCoolant Injection (HPCI) Systems . . . . . . . . .

3.4.3 Class 3 System Pressure Tests

3.4.3. 1 Request for Relief No. RRPT-4, ExaminationCategory D-B, Item D2.10, Pressure Testing inAccordance with IWO-5223(f) for Hain Steam ReliefValves (HSRV)

3 .4.4 General ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

24

24

28

28

30

~~

0

0

3.4.4. 1 Request for Relief No. RRPT-1, Use of Code CaseN-416-1, Alternative Pressure Test Requirements forWelded Repairs or Installation of Replacement Itemsby Weldlngo ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 30

3.4.4.2 Request for Relief No. RRPT-2, Paragraph IWA-5250(2),Corrective Measures for Bolted Connections . . . . . . . . 33

.5 General3 35

3.5.1 Ultrasonic Examination Techniques (No relief requests)

3.5.2 Exempted Components (No relief requests)

.5.3 Other3 36

3.5.3. 1 Request for Relief No. RR-3 (Units 1 and 2), ArticleIWF-5000, Inservice Inspection Requirements forS nubbers . 36

3.5.3.2 Request for Relief No. RR-6 (Units 1 and 2), AugmentedExaminations . 36

3.5.3.3 Request for Relief No. N-509, Use of Code Case N-509,Alternative Rules for the Selection and Examination ofClass 1, 2, and 3 I'ntegrally-Welded Attachments,Section XI, Division I .

3.5.3.4 Request for Relief No. N-524, Use of Code Case N-524,Alternative Examination Requirements for LongitudinalWelds in Class I, and 2 Piping, Section XI,Division I .

39

42

3.5.3.5 Request for Relief No. SS-IWF, Use of Subsection IWFof the 1990 Addenda for Rules for Examination of Class1, 2, and 3 Component Supports . . . . . . . . . . . . . . 44

3.5.3.6 Request for Relief No. IWX-2430, Use of ParagraphIWX-2430 of the 1992 Edition of the ASNE for Rulesfor additional Examinations of Class 1, 2, and 3and Component Supports . .

4 CONCLUSION „, ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

5. REFERENCES

46

49

52

TECHNICAL EVALUATION REPORT ON THE

SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:PENNSYLVANIA POWER L LIGHT COMPANY,

SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2sDOCKET NUMBERS 50-387 AND 50-388

1. INTRODUCTION

Throughout the service life of a water-cooled nuclear power facility,10 CFR 50.55a(g)(4) (Reference 1) requires that components (includingsupports) that are classified as American Society of Hechanical Engineers

(ASHE) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the

requirements, except the design and access provisions and the preserviceexamination requirements, set forth in the ASHE Code Section XI, Rules forInservice Inspection of Nuclear Power Plant Components (Reference 2), to the

extent practical within the limitations of design, geometry, and materials ofconstruction of the components. This section of the regulations also requiresthat inservice examinations of components and system pressure tests conducted

during successive 120-month inspection intervals comply with the requirementsin the latest edition and addenda of the Code incorporated by reference in10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month

inspection interval, subject to the limitations and modifications listedtherein. The components (including supports) may meet requirements set forthin subsequent editions and addenda of this Code that are incorporated by

reference in 10 CFR 50.55a(b) subject to the limitations and modificationslisted therein and subject to Nuclear Regulatory Commission (NRC) approval.The licensee, Pennsylvania Power 5, Light Company, has prepared the Susquehanna

Steam Electric Station, Units I and 2, Inservice Inspection Program Plan forthe Second Inservice Inspection Interval, Revision 0 (Reference 3), to meet

. the requirements of the 1989 Edition of the ASHE Code Section XI. The second

10-year interval began June 1, 1994, and ends Hay 31, 2004.

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

the licensee shall submit information and justifications to the Nuclear

Regulatory Commission (NRC) to support that determination.

I 1

0

Pursuant to 10 CFR 50.55a(g)(6), the NRC will evaluate the licensee's

determination that Code requirements are impractical to implement. The NRC

may grant relief and may impose alternative requirements that are determined

to be authorized by law, will not endanger life, property, or the common

defense and security, and are otherwise in the public interest, giving due

consideration to the burden upon the licensee that could result if the

requirements were imposed on the facility.

Alternatively, pursuant to 10 CFR 50.55a(a)(3), the NRC will evaluate the

licensee's determination that either (i) the proposed alternatives provide an

acceptable level of quality and safety or that (ii) Code compliance would

result in hardship or unusual difficultywithout a compensating increase insafety. Proposed alternatives may be used when authorized by the NRC.

The information in the Susquehanna Steam Electric Station, Units I and 2,Inservice Inspection Program Plan for the Second Inservice Inspection

'nterval,Revision 0, submitted Hay 19, 1994, was reviewed, including the

requests for relief from the ASIDE Code Section XI requirements that thelicensee has determined to be impractical. The review of the ISI Program Plan

was performed using the Standard Review Plans of NUREG-0800 (Reference 4),Section 5.2.4, "Reactor Coolant Boundary Inservice Inspections and Testing,"and Section 6.6, "Inservice Inspection of Class 2 and 3 Components."

In a letter dated November 28, 1994 (Reference 5), the NRC requested

additional information that was required to complete the review of the ISI

Program Plan. The requested information was provided by the licensee in the"Response to Request for Information Related to the Inservice InspectionProgram Plan" dated March 31, 1995 (Reference 6).

As a result of telephone conversations with the licensee on August 23, 1995,

it was determined that the use of unapproved Code Cases N-509 and N-524, and

the use of a later and unapproved edition of the ASIDE Code would be evaluated

based on the information contained in the licensee's plan. These issues have

been titled and evaluated as requests for relief in Section 3 of this report.

The Susquehanna Steam Electric Station, Units I and 2, Inservice InspectionProgram Plan for the Second Inservice Inspection Intervals is evaluated inSection 2 of this report. The ISI Program Plan is evaluated for(a) compliance with the appropriate edition/addenda of Section XI,(b) acceptability of examination sample, (c) correctness of the application ofsystem or component examination exclusion criteria, and (d) compliance withISI-related commitments identified during the NRC's previous reviews.

The requests for relief are evaluated in Section 3 of this report. Unless

otherwise stated, references to the Code refer to the ASIDE Code, Section XI,1989 Edition. Specific inservice test (IST) programs for pumps and valves are

being evaluated'n other reports.

1 II y ~

'I

0 2. EVALUATION OF INSERVICE INSPECTION PROGRAN 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 previous license conditions pertinent to ISI activities. This section

describes the submittals reviewed and the results of the review.

2. 1 ocuments valuated

Review has been completed on the following information from the licensee:

(a)

(b)

Susquehanna Steam Electric Station, Units 1 and 2, InserviceInspection Program Plan for the Second Inservice InspectionInterval, Revision 0 (Reference 3);

Susquehanna Steam Electric Station System Pressure Test Programfor Class 1, 2, and 3 Systems 8 Components for the SecondInservice Inspection Interval, Revision 0 (Refer ence 7);

(c) Response to the NRC request for additional information, datedMarch 31, 1995 (Reference 6); and;

(d) Susquehanna Steam Electric Station, Units 1 and 2, InserviceInspection Program Plaster Selection Document, (Reference 8)

2.2 Com liance with Code Re ui ements

2.2.1 Com liance with A licable Code ditions

The Inservice Inspection Program Plan shall be based on the Code

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

on the starting date of June 1, 1994, the Code applicable to the

second interval ISI program is the 1989 Edition. As stated in

Section 1 of this report, the licensee has prepared the Susquehanna

Steam Electric Station, Units 1 and 2, Inservice Inspection Program

Plan for the Second Inservice Inspection Interval, Revision 0, to

meet the requirements of 1989 Edition of the Code.

2.2.2 cce t bilit of the Examination Sam le

Inservice volumetric, surface, and visual examinations shall be

performed on ASIDE Code Class 1, 2, and 3 components and theirsupports using sampling schedules described in Section XI of the ASHE

Code and 10 CFR 50.55a(b). Sample size and weld selection have been

implemented in accordance with the Code and 10 CFR 50.55a(b) and

appear to be correct.

2.2.3 m tion r teria

The criteria used to exempt components from examination shall be

consistent with Paragraphs IWB-1220, IWC-1220, IWC-1230, IWD-1220,

and 10 CFR 50.55a(b). The exemption criteria have been applied by

the licensee in accordance with the Code, as discussed in the ISIProgram Plan, and appear to be correct.

2.2.4 u mented xamination Commitments

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

Code, the licensee has committed to perform the following augmented

examinations:

(a) Augmented volumetric or surface examinations to protect againstpostulated piping failures per FSAR 6.6.8;

(b) Augmented ultrasonic inspection for intergranular stresscorrosion cracking (IGSCC) per NUREG-0313 (Reference 9);

(c) Augmented volumetric, surface, and visual examinations inaccordance with NUREG-0619, N'R Feedwater Nozzle and Control RodDrive Return Line Nozzle Cracking (Reference 10);

(d) Augmented ultrasonic examinations for BWR Jet Pump AssemblyFailure in accordance with NUREG/CR-3052 (Reference 11);

(e) Augmented visual and ultrasonic examinations of RPV internalsbased on industry group recommendations, BWR plant experience,and PPEL site experience; and

(f) Augmented ISI for vibration-induced failures based on industrygroup recommendations, BWR plant experience, and PPSL siteexperience.

2.3

Based on the review of the documents listed above, no deviations from

regulatory requirements or commitments were identified in the Susquehanna

Steam Electric Station, Units I and 2, Inservice Inspection Program Plan

for the Second Inservice Inspection Interval, Revision 0.

3. EVALUATION OF RELIEF RE(UESTS

The requests for relief from the ASIDE Code requirements that the licensee has

determined to be impractical for the Second 10-Year Inspection Interval are

evaluated in the following sections.

3.1 Class Com onents

3.1.1 Reactor ressure essel

3. 1.1. 1 e uest or Relief No, RR- am'tion Cate or B-0

tern B3.90 eactor Press e Ve sel RPV No le-to-Vessel Welds

Code Re uirement: Section XI, Table IWB-2500-1, Examination

Category B-D, Item B3.90, requires a IONo volumetric examination

of all RPV nozzle-to-vessel welds as defined by FigureIWB-2500-7.

i see'de e e t: Relief is requested from


the Code, for the following RPV nozzle-to-vessel welds.

" Hozz)e,.ID

.Table"-'RR-'2-1

".;Um)ting':, O'Complete C;Part) al"Condition . 'Exam 1 2 'Exam 3

5 No'Exam4

N1A, B

N2A-H J K

N3A-D

N4B,C,E,F





77.29 T50 P

75.42 T50 P

73.26 T50 P

75.42 T50 P

4.8

5.67

6.3

5.67

17.91 T50 P

18.91 T50 P

20.44 T50 P

18.91 T50 P

'Table RR-2-1

!„.Nozzle ~;ID ."" ":

;.'.;..'.;,Limiting,; .

--'-">Condition'-;C, Complete,;5 -Partial,Exam 1 2 Exam 3 '-

'4'No:Exam'"'

N4A, 0

N5A, B

N6A, B

NBA,B

N9

Nozzle forgingconfigurationand limitedscan path dueto NllA,Bnozzles






62.85 T50 P

75.42 T50 P

72.36 T50 P

76.24 T50 P

78.22 T50 P

78.22 T50 P

4.73

5.67

9.67

7.27

7.65

7.65

32.42 T50 P

18.91 T50 P

17.97 T50 P

16.49 T50 P

14.13 T50 P

14.13 T50 P

(1) T indicates "T scan" - 45'nd 60'ransverse to weld(2) P indicates "P scan" - 45'nd 60'arallel to weld(3) Partial indicates portion of exam volume partially

examined using 60' scan; no 45'can possible.(4) Unexamined volume is that portion that cannot be

interrogated by either 45'r 60'. P scans of the nozzleside of all welds cannot be performed, therefore, theunexamined P scan volume is 5K for all nozzles.

Licensee's Basis for Re uestin Relief (as stated):

"Complete examination of all of the aforementioned SSES Units 1

and 2 Examination Category B-D nozzle-to-vessel welds is notpractical due to the nozzle forging configuration. In each case,the radius of curvature of the nozzle forging (the nozzle side ofthe weld) causes the ultrasonic search unit to lift and losecontact, thereby limiting complete volumetric examination of theCode-required examination volume. This examination limitationaffects both the transverse and parallel scans of all 30 nozzles.Alternate means, such as small search units and full vee pathexaminations, were cqnsidered, but were found to be ineffectivein improving examination coverage.

"In support of ALARA considerations, 24 of the 30 nozzle-to-vessel examinations - Nl, N2, N3, N4, and N5 - will be performedutilizing remote automated ultrasonic examination equipment.However, the limitation imposed by the nozzle forging

configuration is slightly more pronounced with the automatedexaminations due to the design of the remote scanner apparatus.The percentages presented in Table RR-2-1 for these nozzles arebased exclusively on automated examination coverage.

"The N6, N7, NB, and N9 nozzle-to-vessel welds will be examinedsolely by manual ultrasonic examination techniques.

"Automated, examinations of two Feedwater nozzle-to-vessel welds-N4A and N4D - are further limited due to plant designobstructions from the N11A and N11B instrumentation nozzles,respectively. A spacing of approximately 4.5 inches between theN4 and the Nll nozzles restricts examination of an arc ofapproximately 60 degrees (17%) of the affected nozzle-to-vesselwelds.

"Table RR-2-1 details examination coverage for all the nozzles.These estimates of examination coverage are based on calculationsmade during preservice examinations of the nozzle-to-vesselwelds, and are still considered valid, conservative estimates forthe second inservice inspection interval."

ice see's P o osed lternative xaminat'on (as stated):

"Examinations will be performed to the maximum extentpracticable. High radiation areas preclude the use ofsupplemental manual examinations; manual examinations yield noappreciable increase in examination coverage. No alternateprovisions are proposed."

j 1 i: Th Cd qi 10IN 1 i i i fRPV nozzle-to-vessel welds each interval. However, the

configuration of the nozzles restricts access and precludes 10Ãvolumetric examination. Therefore, the Code requirement isimpractical for the subject welds. To perform the examinations

to the extent required by the Code, the RPV nozzles would requiredesign modifications to allow sufficient access. Imposition ofthe requirement would cause a considerable burden on the

licensee.

The licensee stated that 50% of the parallel scans and roughly

75% of the transverse scans can be examined for all of the

9

subject welds. This amounts to approximately 63K of the required

coverage for each weld. This is a significant portion of the

weld area and should detect patterns of degradation that could

occur. Therefore, reasonable assurance of the structuralintegrity of the nozzle-to-vessel welds has been provided.

Concl sion: Based on the impracticality of the Code requirements

and the examinations that are being performed on the subjectwelds, it is recommended that relief be granted pursuant to10 CFR 50.55a(g)(6)(i). The volumetric examinations performed

(to the extent practical) and the Code-required pressure testingprovide reasonable assurance of the operational readiness of ~he

RPV nozzle-to-vessel welds.

3. 1.2.2 Re uest for Relief No. RR-4 Units 1 and 2 xamination

Cate or B-A tems B1.1 Bl. B1.22 and Bl 40 Reactor

ressure Vessel RPV Pressure-Retainin Welds

Note: The following request for relief has been evaluatedagainst the requirements of 10 CFR 50.55a(g)(6)(i) for the second

10-year ISI interval. As stated by the licensee, the augmented

volumetric examination specified by 10 CFR 50.55a(g)(6)(ii)(A)for the RPV shell welds was performed during the first 10-yearISI interval, and the results and limitations of the augmented

examination will be evaluated by the NRC in a separate document.


Category B-A, Items B1.11, B1.12, and B1.22, require volumetricexamination of RPV circumferential and longitudinal shell welds,and meridional welds, as defined by Figures IWB-2500-1, -2, and

-3, respectively. Item B1.40 requires surface and volumetricexamination of the head-to-flange weld as defined by

Figure IWB-2500-5.

10

icensee's Code Relief Re uest: Relief is requested from

performing the volumetric examination to the extent required by

the Code for the following RPV welds. The reduced examination

coverage is based on actual coverage from the first ISI interval.

'Meld,ID

AD

BK

DG

DH

AG

Description/;Item 0,

Circumferenti alshel 1/Bl. 11

Longitudinalshel 1/B1. 12

Longitudinalshel 1/Bl. 12

Bottom headmeridional/Bl.22

Bottom headmeridional/Bl.22

Closure head-to-flange/81. 40

Table'RR-4-"1''

.'."L'imi ting ''Cond) tion,

Permanent RPV mirrorinsulation supportsteel



Control rod drivehousings limit accessto all but 54" of weld

Control rod drivehousings limit accessto all but 54" of weld

Component flangeeometry

-;:ExamCovera e

85.6%

81.1%

81.1%

23.7%

23.7%

80%


"Examinations of the affected welds will be performed to themaximum extent practical.

"For Item Numbers Bl.ll and Bl. 12, the limited coveragerepresents a mere 0.56% of the total reactor vessel shell weldlength. The affected welds (AD, BK, and BM) are located outsideof the vessel beltline region. Plant design changes to effectgreater examination coverage represent extreme hardship without a

compensating return in increased plant safety.

"For Item Number Bl.22 meridional welds, the total examinationcoverage obtained is the maximum practical due to CRD

obstructions. Examination coverage of the head-to-flange weld(Item Number B1.40) is also the maximum practical due to thecomponent configuration.

~ ~

"The reactor pressure vessel pressure retaining welds are subjectto VT-2 visual examination during system pressure testing inaccordance with the requirements of Examination Category B-P."

ic nsee's Pro osed Altern tive xamination (as stated):

"No alternate provisions are proposed for the subjectexaminations."

C 1 1: Th td tl ltdt 1 tl 1 tl fthsubject RPV welds. However, complete examination is not. possible

due to physical obstructions that restrict access to the

examination areas. Therefore, the Code coverage requirements are

impractical for these welds. To perform a complete volumetric

examination, the RPV and associated insulation support steel

would require design modifications. Imposition of thisrequirement would cause a considerable burden on the licensee.

For Melds AD, BK, BH and AG, at least 8% of the volumetric

examination was completed. This represents a significant portion

of the Code-required volume; therefore, these examinations should

detect significant patterns of degradation, if any occurs, and

will provide adequate assurance of structural integrity for these

welds. For Melds DG and DH, only 24K of the examination area

could be examined. However, any significant patterns ofdegradation should be detected by the complete examination of the

other twelve meridional welds, which provides adequate assurance

of the structural integrity of these welds.

d d h 1 d 1 11 f tl d h d

coverage requirements for the subject welds and on the

examinations that can be performed, it is recommended that reliefbe granted pursuant to 10 CFR 50.55a(g)(6)(i). The volumetric

examinations performed to the extent practical and the Code-

required pressure testing provide reasonable assurance of the

operational readiness of the RPV welds.

12

e uest for Relief No RR-8 Exami ation ate or -0

tern B14. 10 Pressure-Retainin Welds in Control Rod Drive CRD

ousin s

Code Re uirement: Section XI, Table IMB-2500-1,

Examination Category B-O, Item B14.10,-requires a surface or

volumetric examination, as defined by Figure IQB-2500-18, for 1S

of peripheral CRD housing welds.


performing the Code-required examination of the CRD housing-to-

flange welds.

icensee's asis or Re uestin Relief (as stated):

"SSES Units 1 and 2 have 185 control rod drive housings per unit;each control rod drive housing is fabricated with two pressureretaining housing welds - the housing-to-flange weld and thehousing tube A-to-housing tube B weld. These welds are subjectto the examination requirements of Examination Category B-O.

"Relief is requested from examination (surface or volumetric) ofthe CRD housing-to-flange welds due to numerous plant design

'obstructions. The CRD position indicator probes, CRD shoot outsteel, and CRD flange shields severely limit access to thehousing-to-flange welds. In addition, high radiation doses inthis area make it impractical to attempt to perform limitedexaminations in the face of these obstacles. The remaininghousing weld is without obstructions and can be completelyexamined.

"The CRD housing welds are within the system pressure retainingboundary of Examination Category B-P. As such, reasonableassurance of the pressure retaining integrity of the flange-to-housing welds is gained through periodic VT-2 visual examinationduring Class 1 system pressure testing."

Licensee's Pro osed Alternative xamination (as stated):


R 1 tt: Th gtgh ig tg R h,dit 1 dt, h

have two pressure-retaining welds, the housing-to-flange weld and

the housing tube A-to-housing tube B weld. The Code requires a

13

surface or volumetric examination of the pressure-retaining welds

in lOX of the peripheral CRD housings. However, the licensee

contends that examination of the housing-to-flange weld is

impractical due to numerous physical obstructions that limitaccess and to high radiation doses associated with this area. In

response to a November 28, 1994, RAI question, the licensee

provided drawings to support the relief request.

Based on the review of the licensee's drawings and supporting

information, the INEL staff concurs with the licensee's

determination that the Code-required examinations are impractical

for the subject welds. The lower housing-to-flange welds are

located well below the tube A-to-tube B weld in an area with

little access. To gain access for examination, the CRD housings

and surrounding obstruction would require design modifications.

Imposition of the Code requirements would cause a considerable

burden on the licensee.

The licensee can and will perform the Code-required examinations

of the upper welds of the housing. In addition, the CRD housings

receive periodic leakage tests with the balance of the Class 1

systems. Therefore, any significant patterns of degradation

should be detected and adequate assurance of the structuralintegrity will be provided.

2 d 2 lp tt 122 Pp 2 lp 2 Cd-required examinations on the subject CRD welds, it is recommended

that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i). The

examinations that will be performed provide reasonable assurance

of the operational readiness of the CRD housing welds.

2.1.2 ~P* 1 (P * t ppll' dilll 2

3.1.3 eat xchan ers and Steam Generators (No relief requests)

14

3. 1.4 Pi in Pressure Boundar

3. 1.F 1 Re uest for Relief No. RR-5 Units and 2 Examination

Cate or 8-J Item B9. 11 Class 1 Pi in Welds

~dR I: I II XI, I Bl IIIB-2555-1, I I IlCategory B-D, Item B9.11, requires surface and volumetricexamination of Class 1 piping welds as defined by

Figure IMB-2500-8.



the Code, for the Class 1 piping welds listed below.

"- . '=""""'~;:.'~': "-";- '"'" 'abl e"-'RR-5-":1, "",Meld'ID,";." .;,";,.

VRRB311-FW-A5

DLA1011-FW-1

Configuration/System nit"';- "=

'lbow-pump/

ReactorRecirc/Unit 1

Pipe-valve/Feedwater Unit 1

LimitingCondition

RR pumpinsulationsupportframework

Pipe whiprestraint

Coverae-'-'3fo

SKV

87K SKV

DBA2011-FW-50 Valve-fluedhead/Reactor MaterClean-u Unit 2

Component . 75% Volconfiguration

DCA2101- F W-2

DLA2031-FM-2

Valve-Flued Head/RHR Unit 2

Valve-Flued Head/Feedwater/Unit 2

Componentconfi urationComponentconfiguration

75K Vol

75% Vol

icensee's Basis for Re uestin Relief (as stated):

"The Code requires selection of the affected welds forexamination; that is, the stress levels at these particular weldlocations exceed the limits specified in Note (l)(b)(l).However, based on nondestructive examination data from the firstinspection interval, a complete examination of the Code requiredsurfaces and/or volumes cannot be performed on these welds due tophysical plant access restrictions and/or geometry of theadjoining components. Relief is requested from completenondestructive examination of these components.

15

"Given the Examination Category B-J selection criteria as appliedto SSES Units I and 2, (See'. 1.2.4), many other welds meetingthe selection criteria can and will be examined. The affectedwelds represent only a small percentage of the total welds to beselected per the criteria; also, the examination coverage is 751.or better for the affected welds and, for most, the limitationaffects only the volumetric examination and a complete surfaceexamination can be performed.

"All examinations will be completed to the maximum extentpractical. The affected welds are also subject to VT-2 visualexamination during system pressure testing in accordance with therequirements of Examination Category B-P."

tl

i ensee's Pro osed Alte ative xaminat'o (as stated):


valuation: The Code requires 10Ã surface and volumetricexamination of the subject welds. However, complete examination

of the welds is restricted by component configuration orobstructions that limit access to the examination area.

Therefore, the Code requirements are impractical for the subjectwelds. To meet the Code requirements, design modifications would

be necessary to allow access to the examination areas.Imposition of this requirement would create a considerable burden

on the licensee.

In all cases, a significant portion (>75%) of the requiredsurface and/or volumetric examinations can be completed. Inaddition, these welds are'ar t of a larger sample of welds thatwill receive complete examination. Therefore, adequate assurance

of the structural integrity of these welds will be provided by

the partial examinations and the complete examination of other,similar, welds.

Conclusion: Based on the examinations that can be completed and

the impracticality of meeting the Code requirements, it isrecommended that relief be granted pursuant to10 CFR 50.55a(g)(6)(i). Reasonable assurance of the operationalreadiness for these welds will be provided by the partial

16

examinations and the complete examination of other, similar,welds.

3.1.5 Pum ressure Boundar (No relief requests)

3.1.6 Valve ressure Boundar (No relief requests)

3.1.7 General

3.1.7.1 uest for l ef o RR-7 Un s and P ra r h IW - 430

dd tiona amina 'ons fo B t'n in C t ol Rod Drive CRD

~ousin s

Code Re u'rement: Section XI, Table IWB-2500-1, Examination

Category B-G-2, Item B7.80, requires a VT-1 visual examination ofbolting in CRD housings when the housing is disassembled. For

CRD bolting that reveals flaws or relevant conditions that exceed

the acceptance criteria of IMB-3517, additional examinationsshall be performed during the current outage in accordance withIWB-2430.


performing the Code-required additional examinations for crackingdetected in CRD housing bolting in the head-to-shank fillet area.

licensee's Basis for Re uestin Relief (as stated):

"The ASHE Section XI required VT-1 visual examination of the CRDbolting during the first inservice inspection interval detectedcracking around the shank on the head-to-shank fillet area of thebolt. Detailed metallurgical analysis of the defects determinedthe cracking mechanism to be stress corrosion blunted by generalcor rosion.

"Subsequent engineering and metallurgical analysis concluded thatthe cracking does not compromise .plant safety or CRO boltingintegrity. Samples of bolting with up to seven years of servicelife were examined; the deepest cracking was measured at 0.040".Magnified cross-sections of the defects always showed elongatedcorrosion pits with blunted ends. Crack growth calculationsconcluded that the cracks grow at a decreasing rate. Theanalysis indicated that it would take 22 years for the worst case

17

I

0

0

crack in a single bolt to grow to th'e minimum required averagebolt diameter. However, the longest period of time a bolt willbe in service without receiving the Code-required visualexamination is 12 years. Since Code visual examinations arerequired only when the drives are disassembled, inspectionfrequencies coincide with CRD mechanism refurbishment exchangefrequency (approximately 24 CRDs per outage/8 bolts per CRD

housing). Any cracked bolting will be detected prior to theworst case single bolt failure. In addition, engineeringanalysis of the CRD bolted joint indicated that only 3 bolts outof 8 wer e needed to meet ASHE Code margins. Thus adequate safetymargins exist even in the event a bolted joint containspotentially crack bolts.

"New design bolts, resistant to this cracking mechanism, areinstalled during CRD maintenance every outage. It is expected,however, that further visual indications which exceed acceptancecriteria will be detected in the original bolting, and additionalexaminations will continue to be required during the secondinservice inspection interval. Performance of the additionalexaminations whenever rejectionable visual indications aredetected is not practical, and poses unreasonable plant hardshipand radiological hazard with no return in increased plant safety.Engineering and metallurgical analysis performed during the firstinservice inspection interval characterized the crackingmechanism, therefore, additional examinations would serve littlepurpose. As the bolting is replaced with new design bolts, thecondition of the original bolting is continuously monitored viaongoing Code VT-I visual examination coupled with metallurgicaland engineering analysis."

icensee's Pro osed Alternative xaminatio (as stated):

"Plant maintenance practices require all visually rejectedbolting to be documented on a plant nonconformance report. Asampling of bolts with cracks in the head-to-shank fillet areaundergo subsequent engineering and metallurgical analysis toconfirm the results of prior analysis. If the analysis disclosesnew conditions which have not been evaluated, then additionalexaminations (to the extent practical) will be performed.Meanwhile, replacement of bolting with new design bolting willcontinue each outage."

Evaluation: The Code requires a VT-I visual examination forbolting in CRD housings when the housing is disassembled. When

conditions exceeding acceptance criteria are identified,additional visual examinations are required in accordance withIWB-2430. In lieu of performing additional examinations, thelicensee is in the process of replacing all the CRD housing

18

II'

0

bolts. The replacement of bolting coincides with the inspectionfrequency of 24 CRDs per outage.

Additional examinations are performed to provide an indication ofthe extent of the degradation detected during scheduled inserviceinspection. If the degradation is determined to be more than an

isolated case, analysis of the condition and subsequent

corrective actions are performed if warranted. In this case, the

licensee has performed engineering and metallurgical analysis ofthe cracked bolting. The resulting corrective actions includereplacement of all the bolting with a new design that is more

resistant to the cracking mechanism found in existing bolts. At

the time of the analysis, replacement of all the bolts was

expected to take 12 years, although the analysis indicated thatworst case cracking would take 22 years to grow to the minimum

required bolt diameter. In addition, analysis has shown thatfive of eight bolts could be fully cracked without affecting thestructural integrity of the housing. Therefore, the licensee'sproposed alternative provides an acceptable level of quality and

safety.

Conclusion: The licensee's proposed alternative provides an

acceptable level of quality and safety. Therefore, it isrecommended that the proposed alternative be authorized pursuantto 10 CFR 50.55a(a)(3)(i).

3.2 Class Com onents

3.2.1 ~P* 1 tN li f q t )

3.2.2 ~Pi in

3.2.2.1 Re uest for Relief No. RR-9 Units and 2 Examination

Cate or C-F- Item C5. Class 2 Circumferential Pi in Welds

Code Re ui ement: Section XI, Table IWC-2500-1, Examination

Category C-F-I, Item C5.22, requires a surface and volumetric

19

examination, as defined by Figure IWC-2500-7, of circumferential

welds in piping greater than 4 inch NPS and greater than or equal

to 3/8 inch nominal wall thickness.

icensee's Code Relic Re uest: Relief is requested from

performing the 10% volumetric examinations of the following

Class 2 piping welds.

'Table 'RR-9-'1

, =: .': ";,-'-'-.-::.. =,".; Configuration'Com onent ".:ID ." .System'it" .Limitin Condition'' 'Covara e

DBB1071-1-B Elbow-Pipe/ Permanent pipeRHR Unit 1 su ort saddle

DBB2071-FW-3 Pipe-Valve/ Adjacent pipeRHR/Unit 2 support, vent line,

and componentconfiguration

84% vol

82.5% vol

icensee's Basis or Re uestin Relief (as stated):

"The Code requires selection of the affected welds forexamination. Based on nondestructive examination data from thefirst inservice inspection interval, complete volumetricexamination of the Code required volumes cannot be performed dueto physical plant access restrictions and/or geometry of theadjoining components. Relief is requested from completenondestructive examination of these components.

"Examination coverage is greater than 80K for the affected weldsand the limitations affect only the volumetric examination; a

complete surface examination can be performed. Also, since theaffected welds are included for examination in the AugmentedInservice Inspection Program, the welds will be examined morefrequently throughout the second inservice inspection interval.

"All examinations will be completed to the maximum extentpractical. The affected welds are also subject to VT-2 visualexamination during system pressure testing in accordance with therequirements of Examination Category C-H."

icensee's Pro osed A ternative xamination (as stated):


20

I S~ ~

1

~

~ d

Th Cd ht 1dd 1 d 1 ttexamination for the subject Class 2 piping welds. However,

physical restrictions limit access and prevent complete

volumetric examination. Therefore, the Code requirement isimpractical for these welds. To meet this requirement, design

modifications would be necessary to allow access for examination.

Imposition of this requirement would create a considerable burden

on the licensee.

For each of the welds in this request, a significant portion{>8K) of the volumetric examination.and a complete surface

examination can be performed. In addition, these welds are partof larger population of Class 2 welds that will receive complete

volumetric examination. Therefore, patterns of degradationshould be detected by the planned examinations, and reasonable

assurance of the structural integrity of the residual heatremoval system will be provided.

~ti: d d th 1 tt th t d 111 h

performed and the impracticality of meeting the Code requirementsfor the subject welds, it is recommended that relief be grantedpursuant to 10 CFR 50.55a(g){6)(i). The partial examinations ofthe subject welds and the complete examination of other, similar,welds will provide adequate assurance of the operationalreadiness of the subject system.

3.2.3 ~Pum s

3.2.3. 1 Re uest for Relief No. RR- Examination Cate or C-G

Item C6. 0 Pressure-Retainin Welds in Residu 1 Heat Removal

RHR and Core S ra CS Pum s

Code Re uirement: Section XI, Table IWC-2500-1, Examinationd

Category C-G, Item C6. 10, requires a surface examination, as

defined by Figure IWC-2500-8, for pressure-retaining welds inClass 2 pumps. Examinations may be performed from either the

outside or inside surface of the component. In the case of

21

I I

0

multiple pumps and valves of similar design and service in a

system, the examination of only one pump and one valve among each

group of multiple pumps and valves is required.

'censee's Code Relief Re uest: Relief is requested from

performing the Code-required surface examination of 9 of 17 welds

in one of four RHR pumps and all 16 welds in one of four CS

pumps.

[Note: Each unit at Susquehanna Steam Electric Station (SSES) has

eight Class 2 pumps with pressure-retaining pump casing welds.There are four CS pumps (Unit 1 1P-206A, B, C, D and Unit 2 2P-

206A, B, C, D) and four RHR pumps (Unit 1 1P-202A, B, C, D andUnit 2 2P-202A, B, C, D). Each RHR pump has 17 pressure-retaining welds and each CS pump has 16 pressure-retainingwelds.]

icensee's asis for Re uestin Rel e (as stated):

"Relief is being requested from complete examination for 9 of 17

RHR pump casing welds (on one pump), and 16 CS pump casing welds(on one pump) due to component inaccessibility for examination.All eight pumps (per unit) are equally limited.

"Three welds, 361-6-7, 361-2-6, and 361-7-8 (See Figure RR-1-1 ),are located within the pump casing and are not normallyaccessible without disassembly of the pump and removal of thepump motor.

"The remaining six welds (per pump), 359-1-2, 359-2-L2, 359-2-2,359-2-Ll, 359-2-3, and 359-3-7 (See Figure RR-1-1 ), are locatedbelow floor elevation 645'-0" and are totally surrounded byconcrete. The pump casing is flooded with water, thereby,completely limiting normal access to these components forexamination.

"Pump motor removal and/or disassembly of a pump to gain accessto these components for surface examination is not practical andrepresents undue hardship with minimal safety return.

"Finally, other required examination/tests of the pumps will beperformed to provide reasonable assurance of structuralintegrity. The Residual Heat Removal and Core Spray pumps aresubject to the functional testing requirements of IMP of the

Not included in this report.~ ~ ~

~

22

I

0

0

Code; also, the pumps are within the system pressure retainingboundaries of Examination 'Category C-H and will be periodicallyVT-2 visually examined during system pressure testing."

icensee's Pro osed Alternative ami at'on (as stated):

"Should any of the subject welds become accessible forexamination due to pump disassembly for repair or maintenance, avisual or surface examination (as deemed appropriate at the time)will be performed to the extent practical."

f 1 iTh :d I f*i i f Cl 2

pump casing welds. In accordance with the Code, these

examinations can be performed from either the inside or outsidesurface of the component. As stated by the licensee, the subjectRHR and CS pump casing welds are located either inside the pump

or embedded in concrete, therefore, are impractical to examine

from the outside surface. Access for examination is onlypossible on the internal surface of the pumps, which requirescomplete disassembly of the pumps. The disassembly of the pumps

for the sole purpose of examination is a major effort that couldresult in damage to the pumps and requiring the disassembly of a

'pump to perform the Code-required surface examination would

create a considerable burden on the licensee.

The licensee's proposed alternative is to perform a visual orsurface examination if the pumps are disassembled for maintenance

or repair. The remaining eight welds on the RHR pumps that are

accessible will be examined as required by the Code. Inaddition, the pumps are subject to VT-2 visual examination duringsystem pressure tests. Thus, reasonable assurance of theoperational readiness will be achieved.

Conclusion: Based on the impracticality of meeting the Code

requirements and the .burden associated with the disassembly ofthe pumps, it is recommended that relief be granted pursuant to10 CFR 50.55a(g)(6)(i) provided that the pumps are examined ifdisassembled. The examination of other RHR pump casing welds and

23

l l

0

the performance of the system pressure tests will provide

reasonable assurance of the pumps operational readiness.

3.2.4 Valves (No relief requests)

3.2.5 ~Ge eral (No relief requests)

3.3 Class 3 om o ents (No relief requests)

.4

3.4.1 Class S stem Pressure Tests (No relief requests)

3.4.2 Class stem Pressure ests

3.4.2. 1 e uest or Relief No. RRPT-3 Units and xamination

Cate or C-H tems C7. 0 C7,40 C7.60 and C7.80 H drostaticP essure Testin of Reactor Core solation Coolin RCIC and

Hi h Pressur Cool nt ect'on PC S stems

Code Re ui ement: Section XI, Table IWC-2500-1, Examination

Category C-H, Items C7.20, C7.40, C7.60, and C7.80 require a

system hydrostatic test in accordance with IWC-5222 once each ISIinterval. ASIDE Code Case N-498, Alternative Rules for 10-Year

Hydrostatic Pressure Testing of Class 1 and 2 Systems,

Section X1, Division 1, permits the use of a system leakage test't nominal operating pressure in lieu of the system hydrostatictest provided the appropriate hold time requirements are met.

The hold time requirements specified in both the Code and theCode Case are 4 hours for insulated systems and 10 minutes foruninsulated systems.

icensee's Code Relief Re uest: Relief is requested from the

Code-required system hydrostatic pressure test for the pressure-

retaining components in the Class 2 RCIC and HPCI systems. The

components and item numbers for which relief was required during

24

~ ~

the first 10-year interval, and for which relief is now requested

for the second interval, are:

'',TABLE 'RRPT-3

'Com onent "'.RCIC Turbine Barometric Condenser (TBC) and piping toflan ed connections

HPIC TBC and piping to flanged connections

RCIC Steam Turbine

HPIC Steam Turbine

RCIC Pump Discharge Piping

HPCI Booster Pump to Lube Oil Cooler/TBC

'-",Item:-'7.20

C7.40

C7.20C7.40

C7.20C7.40

C7.20C7.40

C7.40C7.80

C7.40C7.80

Note: In the Parch 31, 1995, RAI response, the licenseestated that relief was not required for the steam supplypiping and pump supply piping; therefore, these items wereremoved from the request.


"During the first inspection interval, multiple relief requestswere generated by the licensee due to the inability tohydrostatically pressure test portions of the RCIC and HPCISystems (ref. 1RR-20. 1, 20.2, 20.3, 20.4, 20.5, 20.6, 20.7, 20.8,and 2RR-17.1, 17.2, 17.3, 17.4, 17.5, 17.6, and 17.8). Thealternate provisions consisted of performance of a systemfunctional test for those portions incapable of beinghydrostatically tested. Code Case N-498 permits use of a systemfunctional test in lieu of a hydrostatic test providing that thesystem is in operation for 4 hours prior to the VT-2 examinationfor insulated system, the RCIC and HPCI system are insulated.The 4 hour hold time is not practical for the RCIC and HPICsystems due to suppression pool temperature limitations from thesteam exhaust.

"Also, during the first interval a significant number of problemswere experienced in 'cold springing'ipe to install blanks,cutting and removing supports for access, and removal ofinsulation to prepare and restore from these tests. In addition,it caused alignment concerns due to the magnitude of thealterations. It also increased radiological exposure to stationpersonnel.

"The basis for relief from hydrostatic testing the RCIC and HPCIsystems is that ASHE has recognized that hydrostatic test providelittle increased quality or safety to the Code Systems over afunctional test while increasing system out-of-service time,potentially damaging plant equipment and components whileincreasing radiological exposure to station personnel. Theintent of extending the hold time at operating pressure to4 hours for insulated systems under Code Case N-498 was toprovide assurance that any pressure boundary leakage wouldmigrate through the insulation during that time. The licenseeproposes to perform a system functional test with only a tenminute hold time based on the following considerations:

"Pum Su 1 and Dischar e

"The RCIC and HPCI pump supply and discharge is constantlymaintained full via a keepfill system which would causeleakage to eventually migrate through the insulation and becapable of detection.

"Steam Su 1 Turbine a d aust

"The RCIC and HPCI Turbine supply piping is also constantlypressurized, at reactor pressure, up to the steam admissionvalve at the inlet to the turbine.

"The turbines and connected piping cannot be hydrostaticallytested without damaging the sea'is and contaminating thesystems lube oil system. Based on the configuration of theturbine a pneumatic test is also impractical. The turbineshowever are covered with a blanket style insulation whichmakes steam leaks easily detectable when the system isplaced in operation.

"The turbine exhaust piping is open to the suppression pooldu~ing operation. In accordance with IWC-5221(d) for openended discharge lines to the suppression pool onlydemonstration of an open flow path is required to beperformed to satisfy the system hydrostatic testrequirements. This can be verified within a ten minute holdtime."

In the March 31, 1995, RAI response, the licensee stated that thesystems are not designed to be hydrostatically tested and that,during the first interval, blanks had to be installed at turbineand pump connections, permanent piping supports had to be

removed, and temporary supports installed, all with substantialexpenditure of .radiological dose. The Class 2 RCIC and HPCI

systems cannot be operated for the required 4-hour hold time as

required by the Code Case due to heat-up of the suppression pool

26

from the turbine exhausts. In addition, the pump discharge

piping is maintained full either via static head or keepfill. Ifa leak existed in the system, the leakage would eventuallymigrate through the insulation and be detected.

icensee's Pro osed Alternat've xamination (as stated):

"In lieu of performing a system hydrostatic pressure test on theRCIC and HPCI systems in accordance with Table IWC-2500-1,Category C-H, a system functional test shall be performed with aten minute hold time prior to perFormance of the VT-2examination. The system shall be in operational standby with thereactor at nominal operating pressure a minimum of 4 hours priorto the inspection."

va atio : The Code requires pressure testing, including a

system hydrostatic pressure test, in accordance with IWC-5000 forClass 2 pressure-retaining components. Code Case N-498 allows a

system leakage test at nominal operating pressure in lieu of theCode-required hydrostatic test provided the applicable hold timerequirements are met (4 hours for insulated systems and 10

minutes for uninsulated systems). The RCIC and HPCI systems atSusquehanna Units I and 2 are insulated systems, therefore, the4-hour hold time requirement applies. However, the'icenseecontends that the hold time requirements impractical for these

systems and has requested relief.

To achieve the hold time, the RCIC and HPCI must be operated for4 hours, which would result in excessive heat-up of thesuppression pool from the turbine exhausts. Therefore, the4-hour hold time requirement i's impractical for these systems.

To meet the hold time requirement, the system would have to be

redesigned to accommodate the suppression pool heat-up.Alternatively, removal of the insulation for the sole purpose ofperforming the 10-year hydrostatic pressure test (or leakage testper Code Case N-498) would result in excessive radiation exposure

to plant personnel. Imposition of this requirement would createa considerable burden on the licensee.

27.

In lieu of the 4-hour hold time, the licensee proposes that the

systems receive a system functional test with a 10-minute hold

time prior to performance of the VT-2 examination. The systems

will be in operational standby with the reactor at nominal

operating pressure a minimum of 4 hours prior to the inspection.

The intent of the hold time requirement is to allow leakage to

penetrate the insulation prior to the visual inspection. If the

system is leaking, placing the system in operational standby for

four hours prior to the functional test will allow time forleakage to seep through the insulation and, therefore, provides

adequate assurance of the leak tightness of the RCIC and HPCI

systems.

Conclusion: Considering the impracticality of meeting the hold-

time requirements for the specified portions of the HPCI and RCIC

systems and licensee's proposed alternative, it is recommended

that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i). The

licensee's alternative will provide reasonable assurance of theI

operational readiness of the subject systems.

3.4.3 Class 3 S stem Pressure Tests

3.4.3. 1 Re uest for Relief No. RRPT-4 Examination Cate or D-B

Item D2.10 Pressure est in Accordance with IWD-52 3 f forMain Steam Relic Va ves MSRV

Code Re uirement: Section XI, Table IWD-2500-1, Examination

Category D-B, Item D2.10, requires a system pressure test in

accordance with IWD-5223. For safety or relief valve piping thatdischarges into the containment pressure suppression pool, a

pneumatic test (at a pressure of 90K of the pipe submergence head

of water) that demonstrates leakage integrity shall be performed

in lieu of the system hydrostatic test.

'censee's Code R lief Re uest: Relief is requested to use the

requirements of IWD-5222 of the 1992 Addenda of the 1992 Code in

+Q

lieu of the requirements of IWD-5223(f) of the 1989 Edition ofthe ASHE Code.

censee's Basis for Re uestin Relief (as stated):

"In accordance with 10 CFR 50.55a paragraphs (g)(4) and(g)(5)(i), prior to the start of the inservice inspectioninterval, the inservice inspection program must be revised toincorporate Code editions and addenda as referenced in10 CFR 50.55a(b). Per 10 CFR 50.55a(g)(4)(ii), the governingCode for subsequent inservice inspection intervals is the, latestedition and addenda'f the Code incorporated by reference in theregulations 12 months prior to the start of the inserviceinspection interval. Given a June 1, 1994, start-of-intervaldate, the latest referenced Code is the 1989 Edition of ASHESection XI. Relief is requested to allow the use of ParagraphIMD-5223 of the 1992 Edition incorporating the 1992 Addenda inlieu of Paragraph IWD-5223 of the 1989 Edition of the Code.

"The 1992 Addenda to the 1992 Edition of the Code has deleted therequirement for pneumatic pressure testing the HSRV dischargelines at a 9K head pressure (7.8 psig for SSES). This test doeslittle to identify leakage in these lines except gross leakage.Mhen this system is utilized during a relief/safety valveactuation the piping momentarily experiences pressures up toreactor pressure. Any leakage would be detected by containmentpressure and temperature instrumentation."

icensee's Pro osed Alter ative Examination (as stated):

"Relief is requested to allow the use of Paragraph IWD-5223 ofthe 1992 Edition incorporating the 1992 Addenda in lieu ofParagraph IWD-5223 of the 1989 Edition of the Code."

f 1 iTh 1I *:h p p 4

fthm

qi fIMD-5222 of the 1992 Addenda in lieu of the Code of record.IMD-5223(f) of the 1989 Code requires a pneumatic pressure test{in lieu of a hydrostatic pressure test) at 9K of the pipesubmergence head of water for discharge lines of open-ended

safety or relief valves that discharge into the containment

suppression pool. IMD-5222(f) of the 1992 Addenda exempts thispiping from the hydrostatic pressure test requirements.

The subject open-ended piping is designed to direct the discharge

from the safety and relief valves into the containment

suppression pool and, therefore, leak integrity is not critical

provided an open flow path exists. The Code committees have

recognized this and have eliminated the hydrostatic pressure testrequirement for these lines. The licensee's proposal to use

IWD-5222 of the 1992 Addenda will provide an acceptable level ofquality and safety provided that adequate flow is verified.

~C1 ': tti ddt| tth |i 'p 4

alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i)provided that adequate flow is verified.

3.4.4 General

3.4.4.1 Re uest for elief No. RRPT- Us o Code Case N-416-

Alternative ressure est Re i ements fo fielded Re irs orstallation of Re lacement Items b Veldin .

Code Re uirement: Section XI, Paragraph IWA-4700, Pressure Test,requires a system hydrostatic test in accordance with IWA-5000

after repairs by welding on the pressure-retaining boundary.

Following welding, the Code requires volumetric examination

(depending on wall thickness) of repairs or replacements in Code

Class 1 and 2 systems, but only requires a surface examination ofthe final weld pass in Code Class 3 piping components. There areno ongoing NDE requirements for Code Class 3 components exceptfor VT-2 visual examination for leaks in conjunction with the 10-

year hydrostatic tests and the periodic pressure tests.

ce see's Code Relief Re uest: Relief is requested to use Code

Case N-416-1, Alternative Pressure Test Requirements for fieldedRepairs or Installation of Replacement Items by holding, SectionXI, Division l.


"Code Case N-416-1 provides an alternative to hydrostaticallypressure testing ASIDE Section XI Class 1, 2, E 3 components thathave been repaired or replaced by welding. The design of the

30

~ ~

0 weldment and its associated NDE provides the structural integrityof a repair/replacement. The intent of a pressure test is toexamine the repair/replacement for leakage only. This can be

accomplished through a System Leakage, Functional, or InserviceTest as applicable. This provides an acceptable level of qualityand safety while significantly reducing the need to alter systemsto perform a hydrostatic test and reduces worker radiologicalexposures."

'censee'ro osed lternative xaminat'on (as stated):

"Per this relief request, Code Case N-416-1 has been included foruse in this ISI Program Plan."

f 1 iI:i Nl ftl Cd q't hyd tti

test to be performed in accordance with IMA-5000 after repairs

made by welding on the pressure-retaining boundary. The licensee

has proposed the use of Code Case N-416-1 in lieu of the Code

requirements. Code Case N-416-1 specifies that NDE of the welds

be performed in accordance with the applicable subsection of the

1992 Edition of Section III. The Code Case also allows a VT-2

visual examination to be performed at nominal operating pressure

and temperature in conjunction with a system leakage test, in

accordance with Paragraph IMA-5000 of the 1992 Edition ofSection XI.

The 1989 Editions of Sections III and XI are the latest Code

editions referenced in 10 CFR 50.55a. The NRC staff has compared

the system pressure test requirements of the 1992'Edition ofSection XI to those of the 1989 Edition. In summary:

1) The test frequencies and the pressure conditions associated

with these tests have not changed;

2) The hold times have either remained unchanged or increased;

3) The terminology associated with the system pressure testrequirements for all three Code classes has been clarified and

streaml'ined; and

31

~ ~

4) The NDE requirements for welded repairs remain the same.

Piping components are designed for the number of loadings thatare postulated to occur under the various modes of plantoperation. Hydrostatic testing subjects the piping components toa small increase in pressure over the design pressure and,

therefore, does not present a significant challenge to pressure

boundary integrity. Accordingly, hydrostatic pressure testing isprimarily regarded as a means to enhance leak detection duringthe examination of components under pressure rather than a

measure of the structural integrity of the components.

Considering the NDE performed on Code Class 1 and 2 systems and

that the hydrostatic pressure, tests rarely result in pressure

boundary leaks that would not occur during system leakage tests,the INEL staff believes that the added assurance of integrityprovided by the hydrostatic test is not commensurate with theassociated burden, which typically includes the installation ofblanks, cutting and removing supports for access, and removing

insulation to prepare and restore the systems, all of which

increase radiation exposure for plant personnel.

For Class 3 components, there are no ongoing NDE requirements

except for the visual examination for leaks in conjunction withthe 10-year hydrostatic test and periodic pressur e tests.Therefore, eliminating the hydrostatic test and only performingthe system pressure test for Class 3 components should only be

considered acceptable if an additional surface examination isperformed on the root pass layer of butt and socket welds on thepressure-retaining boundary during repair and replacement

activities.

Conclusion: Compliance with the Code-required hydrostatictesting for welded repairs or replacements of Code Class 1, 2,and 3 components would result in a hardship without a

compensating increase in the level of quality and safety.Therefore, it is recommended that the proposed alternative, use

32

of Code Case N-416-1, be authorized pursuant to

10 CFR 50.55a(a)(3)(ii) provided that an additional surface

examination is performed on the root pass layer of Class 3 butt

and socket welds. The use of this Code Case should be authorized

until the Code Case is approved for general use by reference in

Regulatory Guide 1. 147. After that time, the licensee may

continue to use Code Case N-416-1 with the limitations, if any,

listed in Regulatory Guide 1. 147.

3.4.4.2 e uest for Re ief No. RRPT- Para r h WA-5250

easures for olted Co ections

Corrective

Code Re uirement: Section XI, Paragraph IWA-5250(2), requires

that if leakage occurs at a bolted connection, the bolting shall

be removed, VT-3 visually examined for corrosion, and evaluated

in accordance with IWA-3100.

icensee's Code elief Re uest: . Relief is requested from the

requirement of IWA-5250(2) to remove bolting at leakingconnections for performance of the VT-3 visual examination.


"Removal of bolting to perform a VT-3 examination requires thesystem to be placed in an inoperable condition without assurancesthat the bolting has corroded sufficiently to mandate itsreplacement. Leakage from bolted connections is. usuallylocalized and does not require removal of all bolting forexamination."

In the November 28, 1994, RAI, two events'ere cited regarding

bolting degradation and the licensee was requested to verify thatat least one bolt closest to leakage would be removed for visual

inspection. In response,'he licensee stated:

Event Report Number 26899, dated 3/8/94, and Event Report Number 26992,dated 3/25/94).

33

"PPEL has requested relief from the requirements. of IWA-5250(2)for the removal of bolting at leaking mechanical connections toperform a VT-3 visual examination. Our proposal is to perform an

in-place VT-3 visual examination as part of the evaluationprocess. The NRC has cited Event Report Numbers 26899 and 26922

as reinforcement that this requirement should remain for removaland examination of at least one bolt, closest to leakage.

"The reasoning behind placing this requirement in the ASNE

Section XI Code in the 1986 Edition and the topic of the above

two Event Reports was the concern over boric acid corrosion inprimary coolant systems in PWRs. Because Susquehanna is a BWR,

the only boric acid system is Standby Liquid Control. Thissystem is small in relation to piping length and size plus thenumber of mechanical joints are few. In addition, the system isonly run on a quarterly basis to satisfy surveillancerequirements. At the time of each quarterly surveillance test,our Standby Liquid Control System is flushed, filled, and runwith clean demineralized water. We will maintain therequirements for insulation removal (IWA-5242) during systemleakage exams and take any corrective action as required based on

a thorough evaluation of the identified leakage. Susquehannaalso has an aggressive program to identify leakage and takecompensatory measures for mitigating problems that could occur inthe systems associated with the ISI program. The only corrosioninduced problem that has occurred at Susquehanna is the boltingassociated with the CRD housings. This was identified duringroutine maintenance and is being replaced during scheduled refueloutages. The corrosion (IGSCC) was thoroughly evaluated anddocumented prior to placing the system back into service and isnot as aggressive as boric acid corrosion. The performance of an

engineering evaluation without removal of bolting at the jointspermits the licensee to determine (I) if the corrosion isevident, (2) if the corrosion appears aggressive enough towarrant removal for closer examination, (3) if the boltingmaterials are susceptible to failure, and (4) „if the potentialrate of corrosion would permit continued operation of the systemuntil the next scheduled maintenance outage for the system. Thisevaluation would not increase the risk of an accident or endangerpublic safety, but would permit the licensee some flexibility indetermining the magnitude of the corrosion and when to take thesystem out of service to disturb the joint."

icensee's Pro osed Alternative Examination (as stated):

"An 'in-place'T-3 examination will be performed of the boltedconnection with emphasis placed on the bolting subjected to theleakage. The level of corrosion will be evaluated againstapplicable VT-3 acceptance criteria first, then, if required, an

engineering evaluation will be performed. If necessary,individual bolting will be removed for further examination. Allrejected bolting will be replaced, and the bolted connection willbe reinspected when the system is returned to service."

34

valuation: In accordance with the 1989 Edition of the Code, when

leakage occurs at bolted connections, all bolting is required tobe removed for VT-3 visual examination. In lieu of the Code-

r equired removal of bolting to perform a VT-3 visual examination,

the licensee has proposed to perform an in-place VT-3 visualexamination. If warranted by the level of corrosion, the

licensee will perform an engineering evaluation, including the

removal of a bolt for further examination, if necessary.

VT-3 visual examinations are conducted to determine the general

mechanical and structural condition of components, including thepresence of corrosion. The licensee states "The level ofcorrosion will be evaluated against applicable VT-3 acceptance

criteria first, then, if required, an engineering evaluation willbe performed." However, the Code does not contain acceptance

standards for VT-3 visual examination of bolts, only for VT-Ivisual examination. Therefore, the licensee's proposal isinadequate. To be found acceptable, the visual examinationshould be based on a definitive standard, such as the VT-Istandard. In addition, it appears that there is no establishedevaluation procedure or criteria, thus the licensee's proposalcannot be evaluated properly.

Bdhd i b,i i ddthat relief be denied. The licensee's proposal does not containadequate standards for bolting evaluation and has not providedadequate information to justify the impracticality or burden

associated with performing the Code-required examination.

3.5 General

3.5. 1 Ultrasonic xamination Techni ues (No relief requests)

'3.5.2 xem ted Com onents (No relief requests)

35

3.5.3 Other

3.5.3.1 R est for Relief o RR-3 Units and Article F-5000

nservice ns ection Re uirements or Snubbers

Note: This request for relief is not considered part of the ISI

Program review and is, therefore, not evaluated in this report.This rel,ief request will be evaluated by the Mechanical

Engineering Branch of the NRC.

3.5.3.2 e uest for Relief No. RR-6 Units and Au mented

Au mented amination: Susquehanna Steam Electric Station, FSAR,

Section 6.6.8 specifies a 10K volumetric examination of allClass 1 and 2 circumferential welds in piping between containment

isolation valves for which no breaks are postulated. NUREG-0619,

BVR Feedwater Hozzle and Control Rod Drive Return Line Hozzle

Cracking specifies an ultrasonic examination (UT) of allfeedwater nozzle safe ends, bores, and inside blend radii, everysecond startup/shutdown cycle (except for clad nozzles withinterference fit spargers, UT is performed at each

startup/shutdown cycle). NUREG-0313, Technical Report on

Ptaterial Selection and Processing Guidelines for N'R Coolant

Pressure Boundary Piping (Reference 9), specifies ultrasonicexamination of piping that is prone to intergranular stresscorrosion cracking (IGSCC). Selection of welds and inspectionscheduling requirements are based on material type, crackinghistory, and preventive and repair measures taken (e.g. stressimprovement and weld overlay).

Licensee's Relief Re uest: Relief is requested from performingthe following augmented examinations to the extent required by

the Code.

36

Augmented-'xam-.

Source: '- 0,

Com onent.

. 'Tab]e'R-6-1-

Configuration/, .',: Limiting . ExamSystem nit - 'ond)tion Covera e

FSARSection6.6.8

DBA1012-FM-6 Pipe-Flued Head/Reactor WaterClean-u Unit 1

Hanger*;18R field

0% vol

FSARSection6.6.8

DBB1181-1-A Pipe-Sweepolet/Feedwater Unit 1

DBA2011-FW-50 Pipe-Flued Head/Reactor MaterClean-u Unit 1

Weldedsu ortMeldgeometry

79% vol

75% vol

OLA2031-FW-2 Pipe-Flued Head/Feedwater Unit 2

Weldeometr

75% vol

OBA2011-FM-23 Elbow-Valve/Reactor MaterClean-u Unit 2

Weldedsupportbracket

35% vol

N4B- IR

N4B-Bore

Nozzle IR/Feedwater Unit 1

Nozzle bore/Feedwater Unit 1

Bio-Shield 84.7%Wall volBio-Shield 84.9%Mall vol

NUREG-0619 N4D- IR

N4D-Bore

DBB1071-1-B

Nozzle IR/Feedwater/Unit 1

Nozzle bore/Feedwater/Unit 1

Elbow-Pipe/RHR/Unit 1

Thermo-couple

ads

Thermo-couple

ads

Permanentpipesupportsaddle

83.6%vol

84.4%vol

84% vol

DCB1021-FM-2 Valve-FluedHead RHR Unit 1

Componentconfi

50% vol

NUREG-0313Category C

DCB1021-FM-4 Flued Head-Elbow/ WeldedRHR Unit 1 i e clam

89.4%vol

DBB2071-FM-3 Pi pe-Val ve/RHR/Unit 2

Adjacentpipesupport,vent lineandcomponentconfi

82.5%vol

37

AugmentedExamSource .

NUREG-0313Cate or B

Com onent

DCA2101- FW-2

.. Table RR-6-1

Configuration/System

nit'alve-Flued Head/RHR Unit 2

LimitingConditionComponentconfi

ExathCovera e

75K vol

* Hanger removal required to facilitate exam. Area surveyindicates 18R field; estimate 801 mhrs to complete exam


"The SSES Units 1 and 2 Augmented Inservice Inspection Programincludes mandatory component examination requirements in additionto the inservice inspection requirements in ASHE Section XI.These mandatory augmented examination requirements originate fromregulatory direction found in the SSES FSAR, NRC NUREGs,

IE Bulletins, etc. and each varies with regard to the type ofexamination and the extent and frequency of examination.

"Relief is requested for those components listed in Table RR-6-1where the governing augmented examination requirements areimpractical to implement due access restrictions, metallurgicalconstraints, and/or radiological environment.

"Complete examination in accordance with the governing augmentedexamination requirements is not practical due to the limitationsnoted .in Table RR-6-1. All examinations will be completed to themaximum extent practical."

Licensee's Pro osed Alternative xamination (as stated):


A td i i p f d 1 dddassurance of structural integrity is deemed necessary. Documents

that include augmented examinations for SSES, Units 1 and 2, are

the FSAR, Section 6.6.8; NUREG-0619; and NUREG-0313. The FSAR,

Section 6.6.8 specifies a 10Ã volumetric examination for Class 1

and 2 circumferential welds in piping between containment

isolation valves for which no breaks are postulated. In

accordance with NUREG-0619, UT examination is performed on the

reactor vessel nozzle bore and inside blend radius. NUREG-0313

specifies 10@i volumetric examination of stainless steel piping

38

welds susceptible to intergranular stress corrosion cracking

(IGSCC). For the welds listed in this request, physical

restrictions prevent complete volumetric examination. Thus, the

augmented examinations of the subject welds are impractical to

perform. To perform a 100% volumetric examination on each weld,

design modifications would be required "to allow access forexamination. This would cause a considerable burden on the

licensee.

In most cases, a significant portion (>75%) of the volumetric

examination can and will be performed. Therefore; reasonable

assurance of structural integrity will be provided. In the case

of Meld DBA1012-FM-6, the volumetric examination cannot be

performed without removal of a hanger, which is located in an

18R/hr field. Removal of this hanger for the sole purpose ofperforming an examination represents a significant burden.

However, this weld is part of a larger examination sample ofwelds that are being completely examined. In addition, this weld

will receive the Code-required pressure tests with the rest ofthe Class 2 piping. Therefore, reasonable assurance of the

operational readiness will be provided.

Conclusion: Considering the impracticality of meeting the

augmented examination requirements and the examinations that are

being completed, it is recommended that this request be approved.

3.5.3.3 e uest for Relief No. N-509 Use of Code Case N-5 9 Alternativeules for the Selection and E amination o Class

nte rail -fielded Attachments Sect 'on X Division

Code Re 'rement: The Code requires examination of integrally-r

welded attachments as specified under Examination Categories B-H,

B-K, C-C, D-A, D-B, and D-C. These categories stipulate

39

volumetric or surface examinations, as appropriate, and the

'xtent of examinations.

icensee's Code Relief Re uest: In the Program Plan, the

licensee used Code Case N-509 for weld selection in lieu of the

requirements of the Code.

icensee's Basis for Re uestin Relief (paraphrased): Code Case

N-509 offers alternative examination requirements for Class 1, 2,

and 3 integrally-welded attachments. While implementation of the

governing Code requirements does not represent significanthardship, the extent of examinations prescribed far exceeds the

levels necessary to support continued plant quality and safety.Overall inservice inspection experience has shown good

serviceability of these components, with little evidence offailure. This Code Case, which was written in the interest ofoptimizing inservice inspection examinations, offers a

significant reduction in the extent of inservice inspectionexaminations while continuing to provide acceptable levels ofplant quality and safety.

Code Case N-509 references, and stipulates, the concurrent use ofSubsection IWF of the 1990 Addenda for the examination ofcomponent supports. This is because the selection of integrally-welded attachments for examination is contingent upon component

support selections. Per Section 5.3 of the ISI plan, to ensure

appropriate use of Code Case N-509, the requirements ofSubsection IWF of the 1990 Addenda have been adopted. In

addition, to ensure adequate sampling of integrally-weldedattachments, selection of component supports may be prorated by

the number of integrally attached component supports by Code

Class.

40

This Code Case has only recently been approved by ASIDE and was


Guide 1. 147. Endorsement of this Code Case is anticipated in a


icensee's Pro osed Alternative Examination (paraphrased): Code

Case N-509 will be used in lieu of the Code requirements forClass 1, 2, and 3 integrally-welded attachments.

j 1 i: Th li h p p*d, 1«i «hCode requirements, to apply the requirements of Code Case N-509

for the examination of integrally-welded attachments on Class 1,

2, and 3 piping and components. Code Case N-509 provides

alternative sampling requirements for the examination of Class 1,

2, and 3 integral attachments.

Review of this Code Case indicates that there is an ambiguity in

the notes of the examination tables that would allow the

selection of a 1% sample of the integrally-welded attachments

from the percentage of component supports selected forexamination under the rules of the Code (specifically,Subsection IWF of the 1990 Addenda). This could potentiallyreduce the examination sample to an insignificant amount, or tono integral attachments at all. The INEL staff believes thatCode Case N-509 should be enhanced to ensure that this does not

occur. Therefore, use of Code Case N-509 is acceptable provided

that the licensee schedules a minimum of 10K of integralattachments in all Class 1, 2, and 3 systems.

Conclusion: The licensee's proposed alternative for the

examination of integral attachments will provide an acceptable

level of quality and safety. Therefore, it is recommended thatthis alternative be authorized, pursuant to

41

10 CFR 50.55 a{a){3){i), provided that at least a 1(C sample ofall Code Class 1, 2, and 3 integral attachments is examined.

Code Case N-509 should be acceptable for use for the Susquehanna,

Units 1 and 2, second 10-year interval until such time as the

Code Case is adopted for general use in Regulatory Guide 1. 147.

After that time, the licensee must follow the conditions, if any,

specified in the regulatory guide.

3.5.3.4 Re uest for elief No. N-524 Use of Code Case N-524 Alternativexamination e uirements for on itudi al fields in Class I and 2

Pi i Section Xl'vision


Categories B-J, C-F-1, and C-F-2 require surface and/orvolumetric examination of Class 1 and 2 longitudinal pipingwelds. For Class 1 welds, examination is required on at leastone pipe-diameter length, but not more than 12 inches, oflongitudinal weld seams intersecting circumferential welds

selected for examination. For Class 2 welds, at least 2.5 t ofthe intersecting longitudinal weld seams must be examined.

icensee's Code Relief Re uest: In the Program Plan, thelicensee used Code Case N-524 for selection in lieu of the Code.

Licensee's Basis for Re uestin Relief {paraphrased): Code

Case N-524 provides alternative requirements for the examinationof longitudinal welds in Class 1 and 2 piping. While

implementation of the governing Code requirements does notrepresent a significant hardship, the extent of examinationsprescribed far exceeds the levels necessary to support continuedplant quality and safety. Overall inservice inspectionexperience has shown good serviceability of these components,

with little evidence of failure. This Code Case, written in the

42

interest of optimizing inservice inspection examinations, offers

a significant reduction in the extent of inservice inspection

examinations while continuing to provide acceptable levels of

plant quality and safety.

This Code Case has only recently been approved by ASHE and was

not available for .inclusion in the latest issue of Regulatory

Guide 1. 147. Endorsement of this Code Case is anticipated in a


icensee's Pro osed Alternative Examination (paraphrased): Code

Case N-524 will be used in lieu of the Code requirements forClass 1 and 2 longitudinal weld seams.

Evaluation: ASIDE Section XI requires the examination of one pipe

diameter, but not more than 12 inches, of Class 1 longitudinal

piping welds. For Class 2 piping welds, the length oflongitudinal weld required to be examined is 2.5 times the pipe

thickness. These lengths are measured from the intersection with

the circumferential weld. The licensee's proposed alternative,Code Case N-524, limits the extent of examination of Class 1 and

2 piping welds to the portion contained within the examination

area of the intersecting circumferential weld.

Longitudinal welds are produced during manufacture of the piping,not in the field as is the case for circumferential welds.

Consequently, the welds are fabricated under the strictguidelines specified by the manufacturing standard, which

provides assurance of structural integrity. These welds have

also been subjected to the preservice and initial inservice

examinations, which provide additional assurance of structuralintegrity. Additionally, no significant loading conditions or

material degradation'echanisms have become evident to date that

43

specifically relate to longitudinal seam welds in nuclear plant

piping.

Conclusion: The use of Code Case N-524 provides an acceptable

level of quality and safety. Therefore, it is recommended that

the licensee's proposed alternative, Code Case N-524, be

authorized pursuant to 10 CFR 50.55a(a)(3)(i) until such time as

the Code Case is published in Regulatory Guide 1. 147. After that

time, the licensee is to follow all the provisions in Code Case

N-524, with the limitations issued in Regulatory Guide 1. 147, ifany.

3.5.3.5 Re uest for Relief No. SS-IWF Use of Subsection IWF of the 1990

Addenda for Rules for Examination of Class 1 2 and 3 Com onent

~Su orts

Code Re uirement: The Code requires the examination of component

supports as specified in Subsection IWF Examination Category F-A.

Component supports selected for examination shall be the supports

of those components that are required to be examined under IWB,

IWC, and IWD during the first inspection interval.

Licensee's Code Relief Re uest: The licensee proposed the use ofthe requirements of Subsection IWF of the 1990 Addenda in lieu ofthe requirements of the Code of record.


"In accordance with 10CFR50.55a(a)(3), PPEL proposes theappropriate use of Subsection IWF of 1990 Addenda to the 1989Edition for rules for examination of SSES Units 1 and 2 Class 1,2, and 3 component supports in lieu of Subsection IWF of the 1989Edition of the Code.

"Implementation of the examination requirements for componentsupports found in the governing Code do not represent a

44

significant hardship; the requirements are, however, consideredto be cumbersome and diffi'cult to implement. Items Numbers foundin Table IWF-2500-1, may require a single support to be dissectedinto various "sub-components" for examination. Given thequantity of supports typically found in a nuclear power facility,the task of managing support examinations would become quitemassive. Subsection IWF of the 1990 Addenda of the Code,however, offers alternative, simplified rules for examination ofClass 1, 2, and 3 component supports resulting in a moreeffective, more easily managed component support inspectionprogram.

"The 1990 Addenda has not yet been incorporated into 10CFR50.55a

by reference in 10CFR50.55a(b)(2). However, the rules found inSubsection IWF of the 1990 Addenda reflect incorporation of thealternative examination requirements for Class 1, 2, and 3

component supports found in ASNE Code Case N-491, "AlternativeRules for Examination of Class 1, 2, 3 and NC Component Supportsof Light-Water Cooled Power Plants". Code Case N-491 isconsidered acceptable for use per Regulatory Guide 1. 147. Code

Case N-491, and likewise Subsection IWF (1990 Addenda),effectively provides simplified rules for selection andexamination of Class 1, 2, and 3 component supports whilemaintaining acceptable levels of plant quality and safety.

"In addition, this ISI Program has adopted the alternative rulesfor examination of Class 1, 2, and 3 integrally weldedattachments found in Code Case N-509, "Alternative Rules for theSelection and Examination of Class 1, 2, and 3 Integrally WeldedAttachments". Code Case N-509 references, and requires theconcurrent use of, Subsection IWF of the 1990 Addenda."

icensee's Pro osed Alternative Examination (as stated):

"Subsection IWF of the 1989 Edition of the Code with the 1990Addenda will be used for rules for examination of SSES Units 1

and 2 Class 1, 2, and 3 component supports in lieu of SubsectionIWF of the 1989 Edition of the Code."

Th Cd f df th h h d d

10-Year ISI Interval is the 1989 Edition of the ASNE Code. In

the Program Plan, the licensee has used Subsection IWF of the

1990 Addenda of the 1989 Code. These rules were originallypublished in Code Case N-491, which was approved for general use

by incorporation into Regulatory Guide 1. 147, Revision ll

45

(Reference 12); therefore, this Subsection is considered

acceptable. The simplified rules for selection and examination

of Class 1, 2, and 3 component supports provide acceptable levelsof plant quality and safety.

B d 'ttp t pt f Cd C N-ddt,

it is recommended that the licensee's proposed alternative be

authorized pursuant to 10 CFR 50.55a(a)(3)(i) with the

stipulation that the proposed alternative may not be used inconjunction with Code Case N-509 (see Section 3.5.3.3 of thisreport).

e ue t for Relief No. W - 430 Use o P ra X-2430 of t e

99 dition of the ASH for ules for Additional Examinations ofClass 1 and 3 and Com onent Su orts

Code Re uirement: The Code requires additional examinations tobe performed in accordance with Paragraph IWX-2430 of the

appropriate subsection for indications found in components

examined under IWX-2500-1 that exceed the acceptance standards.Additional examinations, per the Code, are to include theremaining welds, areas, or parts that are included in the Code

inspection item number and scheduled for the current and

subsequent period.

icensee's Code Relief Re uest: In the Program Plan, thelicensee used the requirements of Paragraphs IMB-2430, IWC-2430,

IMD-2430, and IWF-2430 of the 1992 Edition of the ASIDE in lieu ofthe Code of record.

icensee's Basis for Re uestin Relief {as stated):

"In compliance with the Code, SSES Units 1 and 2 Class 1, 2, and3 components and component supports, whose examinations reveal

46

flaws or relevant conditions which exceed the specifiedacceptance standards are subject to additional examinations.Implementation of the Code rules governing additionalexaminations does not represent a significant hardship; however,the Additional Examinations rules found in the 1989 Code areconsidered to be somewhat random and difficult to quantify. The

Additional Examinations rules found in the 1992 Edition of theCode offer an enlightened, clearer approach to additionalexaminations.

"The 1992 Edition of the Code has not yet been incorporated into10CFR50.55a by reference in 10CFR50.55a(b)(2). In accordancewith 10CFR50.55a(a)(3), PP&L proposes the appropriate use of thealternative inservice inspection requirements of ParagraphsIMB-2430, IMC-2430, IWD-2430, and IWF-2430 of the 1992 Edition ofthe Code for rules governing the implementation of AdditionalExaminations of SSES Units 1 and 2 Class 1, 2, and 3 components(and component supports). These alternative requirements are tobe invoked in lieu of the requirements found in the 1989 Edition ,

of the Code (or 1990 Addenda for component supports).

"The 1992 Code rules attempt to clarify the quantity ofadditional examinations required, while also allowing for theadditional sample(s) to target components of similar materialsand service, and subject to similar flaws, conditions, andfailure modes, as opposed to a random sampling of "like"components. That is, once a flaw mechanism or relevant conditionis characterized, this information may be utilized to identifyengineered samples of other components to interrogate for similarflaws or relevant conditions. This approach is more in line withthe methodology PPLL has, and will continue to utilize todisposition non-conforming conditions, and in no way compromisesthe level of plant quality and safety."

Licensee's Pro osed Alternative Examination ('as stated):

"Mhen it becomes necessary to invoke the rules for AdditionalExaminations, the alternative requirements found in ParagraphsIMB-2430, IMC-2430, IWD-2430, and IWF-2430 of the 1992 Edition ofthe Code will be used for additional examination of SSES Units 1

and 2, Class 1, 2, and 3 components and components supports."

Evaluation: Additional examinations are required by the Code

when examinations performed in accordance with Table IWB-2500-1

reveal indications that exceed Code acceptance standards. These

additional examinations are to include the remaining welds,

47

areas, or parts that are contained in the Code inspection item

number and scheduled for the current and subsequent period. In

lieu of the Code requirement, the licensee proposes to use the

additional examination requirements of the 1992 Edition of the

ASIDE Code for Class I, 2, and 3 components and component

supports. These additional examination requirements are similar

to those of the Code of record, but are limited to welds, areas,

or parts of similar material and service and subject to the same

type of flaws or relevant conditions as the original component.

The additional examinations required by the Code of record

blanket all components within the inspection item without

consideration for the cause of the unacceptable flaw. This

approach requires examination of unrelated components that may

not be susceptible to the flaw-causing condition. The licensee's

proposed alternative allows some latitude so that engineering

judgement can be applied to determine where additionalexaminations are needed. Thus, generic problems can be

identified and examinations concentrated on only susceptiblecomponents. Although the use of the 1992 Code may result in a

reduced number of additional examinations, the examinations thatare performed will be more effective because they willconcentrate on areas susceptible to the conditions that caused

the original flaw. In addition, the alternative has potentialALARA benefits without compromising the level of quality and

safety.

Conclusion: The proposed alternative will provide an acceptable

level of quality and safety. Therefore, it is recommended thatthe licensee's proposed alternative be authorized, pursuant to10 CFR 50.55a(a)(3)(i), provided that all associated requirements

are also met.

48

4. CONCLUSION

Pursuant to 10 CFR 50.55a(g)(6)(i), it has been determined that certain

inservice examinations cannot be performed to the extent required by

Section XI of the ASHE Code. In the cases of Requests for Relief RR-I, RR-2,

RR-4, RR-5, RR-8, RR-9, and RRPT-3, the licensee has demonstrated that

specific Section XI requirements are impractical and it is recommended thatrelief be granted. The granting of relief will not endanger life, proper ty,or the common defense and security and is otherwise in the public interest,giving due consideration to the burden upon the licensee that could result ifthe requirements were imposed on the facility.

Pursuant to 10 CFR 50.55a(a)(3)(i), it is concluded that in the case ofRequest for Relief RR-7, the licensee's proposed alternative provides an

acceptable level of quality and safety in lieu of the Code-required

examination and it is recommended that the proposed alternative be authorized.In the case of Requests for Relief RRPT-4, N-509, N-524, SS-IWF, and IWX-2430,

the licensee's proposed alternative provides an acceptable level of qualityand safety if the condition(s) discussed in the evaluation are met. In these

cases, it is recommended that the proposed alternatives be authorized only ifthe licensee meets the specified conditions.

Pursuant to 10 CFR 50.55a(a)(3)(ii), it is concluded that in the case ofRequest for Relief RRPT-1 the licensee has demonstrated that specific Section

XI requirements would result in hardship or unusual difficulty without a

compensating increase in quality and safety. However, it is recommended thatthe proposed alternative be authorized only if the licensee meets the

condition contained in the evaluation of the relief request.

For Request for Relief RRPT-2, it is concluded that i) the licensee has not

provided information to support the determination that the Code requirement isimpractical, and ii) requiring the licensee to comply with the Code

49

~ ~

rp

requirement would not result in hardship. Therefore, it is recommended thatrelief be denied for this request.

Based on the information contained in Request for Relief RR-6, the INEL

recommends that the licensee's limited augmented examination be approved.

Request for Relief RR-3 is being evaluated by the Mechanical Engineering

Branch of the NRC.

I

This technical evaluation has not identified any practical method by which the

licensee can meet all the specific inservice inspection requirements ofSection XI of the ASIDE Code for the existing Susquehanna Steam ElectricStation, Units 1 and 2, facility. Compliance with the exact Section XI

requirements would necessitate redesign of a significant number of plantsystems, sufficient replacement components to be obtained, installation of thenew components, and a baseline examination of these components. Even afterthe redesign efforts, complete compliance with the Section XI examination

requirements probably could not be achieved. Therefore, it is concluded thatthe public interest is not served by imposing certain provisions of Section XI

of the ASHE Code that have been determined to be impractical. Pursuant to10 CFR 50.55a(g)(6), relief is allowed from the requirements that are

impractical to implement, or alternatively, pursuant to 10 CFR 50.55a(a)(3),alternatives to the Code-required examinations may be authorized provided thateither (i) the proposed alternatives provide an acceptable level of qualityand safety or (ii) Code compliance would result in hardship or unusual

difficulty without a compensating increase in safety.

The licensee should continue to monitor the development of new or improved

examination techniques. As improvements in these areas are achieved, thelicensee should incorporate these techniques in the ISI program planexamination requirements.

50

Based on the review of the Susquehanna Steam Electric Station, Units I and 2,Second 10-Year Interval Inservice Inspection Program Plan, Revision 0, the

licensee's response to the NRC's request for additional information, and the

recommendations for granting relief from the ISI examinations that cannot be

performed to the extent required by the Code, no deviations from regulatoryrequirements or commitments were identified in the Susquehanna Steam ElectricStation, Units I and 2, Second 10-Year Interval Inservice Inspection Program

Plan, Revision 0, with the exception of Request for Relief RRPT-2.

51

I > g'

0

5. REFERENCES

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

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

1989 Edition

3. Susquehanna Steam Electric Station, Units 1 and 2, Inservice InspectionProgram Plan for the Second Inservice Inspection Interval, Revision 0,submitted May 19, 1994.

4. NUREG-0800, Standard Review Plans, Section 5.2.4, "Reactor CoolantBoundary Inservice Inspection and Testing," and Section 6.6, "InserviceInspection of Class 2 and 3 Components," July 1981.

5. Letter dated November 28, 1994, NRC to PPKL, containing NRC request foradditional information.

6. Letter dated March 31, 1995, R. G. Byram (PP8L) to NRC document ControlDesk, containing response to the November 28, 1994, request foradditional information.

.7. Susquehanna Steam Electric Station System Pressure Test Program forClass 1, 2, and 3 Systems 8 Components for the Second InserviceInspection Interval, Revision 0, dated June 8, 1994.

8. Susquehanna Steam Electric Station, Units 1 and 2, Inservice InspectionProgram Haster Selection Document, Revision 0, dated June 1, 1994.

9. NUREG-0313, Revision 2, Technical Report on Haterial Selection andProcessing Guidelines for BVR Coolant Pressure Boundary Piping,January 1988.

10. NUREG-0619, BMR Feedwater Nozzle and Control Rod Drive Return LineNozzle Cracking, November 1980.

ll. NUREG/CR-3052 (Closeout of IE Bulletin 80-07), BN'R Jet Pump AssemblyFailure, November 1984.

12. Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability,ASHE Section XI, Division 1, Revision ll, dated July 1993.

i ~ I

li v ~ ~ iv

NRC IChv 33533i

30t 30

U.S. NUCLEAR REGULATORY COMHIISSION

BIBLIOGRAPHIC DATA SHEETtScc tntfittcttont on thf rovtrtct

OEOOIAuidhcd tty trAC, Add vdi. Svoo htv i~hd Adiuhdvm ttvmdott, it IhI ~

2. TITLE AND SUBTITLE.

Technical Evaluation Report on the Second 10-YearInterval Inservice Inspection Program Plan:Pennsylvania Power 5 Light CompanySusquehanna Steam Electric Station, Units 1 and 2Docket Numbers 50-387 and 50-388

S. AUTHORISI

H. T. Anderson, K. W. Hall, A. H, Porter

INEL-95/0507

3 'DATE REPORT PUBiIS~EO'MotrTi.

I

Octobern 1 ho

1995

7, PERIOD COVEREO ttnciirti» Oucl.

4. FIN QR GRANT NUMBOR

FIN-L2556 Task 456. TYPE OF REPORT

Technical

B. P ERFQRMING ORGANIZATION - NAME ANO ADDRESS lilHIIC ortwtdr Owtuon. Otticc or itrpon, I/*Hoctcu itrfotctory Commiuion, ond mcdmf oddlrut it contr%tot ontwor

noM ond iMlttnfoddrctjl

INEL/LITCOP.O. Box 1625Idaho Falls, ID 83415-2209

9, SPONSORING ORGANIZATION—NAME AND ADDRESS Nl HttC. tyttr 'Some u Idote"i itcomroc tot ttrovidr HitC Ownion. Otttcc or ttcfion, MS. Hirctccr ttcftttttoty Commnuon,

ond IMilinfJddrotht

Haterials and Chemical Engineering BranchOffice of Nuclear Regulatory CommissionU.S. Nuclear Regulatory CommissionWashington, D.C. 20555

10. SUPPLEMENTARY NOTES

11. ABSTRACT t300 wonu or uut

This report presents the results of the evaluation of the Susquehanna Steam Electric. Station, Units 1 and 2, Second 10-Year Interval Inservice Inspection (ISI) ProgramPlan, submitted Hay 19, 1994, including the requests for relief from the AmericanSociety of Hechanical Engineers (ASHE) Boiler and Pressure Vessel Code Section XIrequirements that the licensee has determined to be impractical. The SusquehannaSteam Electric Station, Units 1 and 2, Second 10-Year Interval ISI Program Plan isevaluated in Section 2 of this report. The ISI Program Plan is evaluated for (a)compliance with the appropriate edition/addenda of Section XI, (b) acceptability ofexamination sample, (c) correctness of the application of system or componentexamination exclusion criteria, and (d) compliance with ISI-related commitmentsidentified during previous Nuclear Regulatory Commission (NRC) reviews. Therequests for relief are evaluated in Section 3 of this report.

12. KEY WORDSIOESCRI PTORS tSill wordt or ttnrcut lhtt willulul lcutrchcll m loco ttnf lhc htoort I IS. AVAILABILITVSTA'TSMSIIT

UnlimitedIA SSCVRITV CLASSIIICATtou

tyhtt hofrt

Unclassifiedtyhit Arpdru

Unclassified'IS. NUMBER OF PAGES

16. PRICE

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