ML18038B096

Forwards Response to NRC & Provides Addl Info Re Second 10-yr Interval ISI Program

ML18038B096
Person / Time
Site:	Browns Ferry
Issue date:	01/06/1995
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-M89119, NUDOCS 9501100166
Download: ML18038B096 (82)

Text

PR.XC)R.I EY' ACCELERATED RIDS'PROCESSING REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9501100166'OC.DATE:

.95/01/06 NOTARIZED: NO DOCKET' FACIL:50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 AUTH.NAME AUTHOR AFFILIATION SALAS,P.

Tennessee Valley Authority RECXP.NAME RECXPXENT AFFILIATION Document Control Branch (Document Control Desk).

SUBJECT:

Forwards response to NRC.941114 ltr & provides add info re second 10-yr interval ISI program.

DISTRIBUTION CODE:

A047D COPIES RECEIVED:,LTR ENCL SIZE:

TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code GL-89-04 NOTES:

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RECIPIENT ID CODE/NAME PD2-4 WILLIAMS,J.

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1 RECIPIENT ID CODE/NAME PD2-4-PD AEOD/SPD/RAB NRR/DE/EMCB NUDOCS-ABSTRACT RES/DSIR/EIB LITCO RANSOME I C NRC PDR COPIES LTTR ENCL 1

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'Tennessee Valley Authority, Post Oiiice Box 2000, Decatu~, Alabama 35609 JAN O6 1995 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 Gentlemen:

In the Matter Of Tennessee Valley Authority Docket No. 50-260 BROWNS FERRY NUCLEAR PLANT (BFN)

UNIT 2 REPLY TO NRC 8 REQUEST FOR ADDITIONAL 1NFORMATZON (RAZ) REGARDING THE SECOND 10-YEAR ZNTERVAL INSERVZCE INSPECTZON (ISI)

PROGRAM (TAC NO M89119)

The purpose of this letter is to respond to NRC's November 14,

1994, RAI regarding the second 10-year interval inservice inspection program.

NRC requested TVA to clarify the ISI program (2-SI-4.6.G),

Section 8.1, note 6 regarding the examination schedule for Class 1 equivalent (IWB) components.

In addition, NRC requested information regarding examination coverages specified for certain components listed in relief requests ISI 2-1, ISI 2-2, and ISI 2-4.

Enclosure 1 contains specific details concerning the NRC requested information.

Enclosure 2 contains the commitments contained in this letter. If you have any questions please contact me at extension (205) 729-2636.

Since ly Pe Salas Manager of Site Licensing Enclosure cc:

See page 2

95011001hh 950106 PDR ADOCK 05000260 9

PDR

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U. S. Nuclear Regulatory Commission fAV05 1995 Enclosure cc (Enclosure):

Mr. Mark S. Lesser, Section Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident. Inspector Browns Ferry Nuclear Plant Route 12, Box 637

Athens, Alabama 35611 Mr. J.

F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

Oi

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNIT 2 TVA S REPLY TO NRC S

NOVEMBER 14'994 REQUEST FOR ADDITIONAL INFORMATION (RAI)

PURPOSE The purpose of this enclosure is to provide TVA's reply to NRC's request for additional information dated November 14, 1994.

The following is a restatement of the requested information followed by TVA's reply.

NRC's Request Item 1 Clarification of Note 6. Section 8.1 Zn Note 6 of Section 8.1, "Examination Schedule, Part 1 Class 1

Equivalent (IWB) Components,"

the program states:

Approximately 90~ of the B-J welds, within practical limits of accessibility, shall be examined during the life of the plant.

All carbon steel or low alloy (similar)

RPV nozzle-to-safe end welds plus additional welds to comprise a 25~ sample shall be examined each interval.

All stainless or dissimilar metal welds are examined under Examination Category B-F.

NRC's Request Item l.a Clarify the meaning of this.note 'with respect to successive examinations.

Are. the same B-J and B-F Category welds examined each interval?

Are these welds examined on the same periodic schedule as performed during the previous interval?

TVA's Response Item l.a The code of record for the second inspection interval for BFN Unit 2 is the 1986 Editi'on of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel

Code,Section XI, Division 1 in accordance with 10 CFR 50.55a(g)(4).

The extent of examination for Category. B-J (Pressure retaining welds in piping) is determined in accordance with the 1974 Code Edition, Summer 1975 Addenda of ASME Section XI.

The extent.of examination is defined as the criteria for the selection of Class 1 B-J welds to be.examined.

The 1974 Code Edition, -Summer of 1975, Section.IWB-2420(c) requires examination of a similar percentage of components not previously inspected during earlier inspection intervals.

Periodic examination of Category B-J welds is addressed in 2-SI-4.6.G paragraph 7.3.2.E(1),

page 33.

0

Note six provides clarification to the examination schedule that similar metal nozzle to nozzle safe-end welds (i.e., terminal ends) are to be examined during each interval.

Nozzle to nozzle safe-end welds are supplemented with Category B-J piping welds selected according to the 1974 Code Edition, Summer 1975 to ensure 25 percent of examination Category B-J welds are scheduled for examination during each inspection interval.

Successive examination of the similar metal nozzle to nozzle safe-end welds supplemented with Category B-J piping welds not previously examined will result in examination of approximately 90 percent of the Category B-J piping welds during the course of four inspection intervals.

The extent of examination for Category B-F (dissimilar metal welds) is determined in accordance with the ASME Section XI, 1986 Code Edition.

Category B-F welds are examined successively each inspection interval and examined on the same periodic schedule as the first inspection interval to the extent practical.

NRC's Request Item 1.b It is unclear what is meant by the description of RPV nozzle-to-safe end welds as being "low alloy (similar)," when these welds are, typically, dissimilar metal welds.

Clarify this characterization.

TVA's Response Item 1.b The term "safe end" is utilized for both carbon steel systems with carbon steel safe ends and stainless steel systems with stainless steel safe ends.

The carbon steel safe end to nozzle welds are similar metal welds and are classified as examination category B-J weldments.

The stainless steel safe end to nozzle welds are dissimilar metal welds and are classified as examination category B-F weldments.

ASME Section XI, 1986 Code Edition, Table IWB-2500-1, Note 3, for examination Category B-F, pressure retaining dissimilar metal welds describes the combination of materials that result in dissimilar metal welds as:

a) carbon or low alloy steels to high alloy steels; b) carbon or low alloy steels to high nickel alloys; or c) high alloy steels to high nickel alloys.

NRC's Request Item 1.c.

The note states that all stainless or dissimilar metal welds are examined under Category B-F.

Provide justification for grouping all stainless steel welds in this Category.

TVA's Response Item 1.c Note 6 reference to stainless metal welds is incorrect.

TVA will revise 2-SI-4.6.G, note six to delete the reference to stainless steel welds, since Category B-F is applicable to only dissimilar metal welds.

NRC's Request Item 2 "Re uest for Relief ISI-2-1 Reactor Pressure Vessel Su ort Inte ral Attachment This request was previously granted in an NRC Safety Evaluation Report (SER) dated October 20,

1994, due to inaccessibility of the RPV support skirt weld.

Two 24-inch sections of the outer surface of.the integral attachment weld, located approximately 180'part, are accessible through access ports in the permanent insulation.

The licensee stated in the initial request. that each of these areas would be examined by the required surface examination method.

This request has now been revised to show that an ultrasonic examination would be performed in lieu of the required surface method.

The Code allows a volumetric technique to be used as an alternative to the surface method only when the configuration of

'the integral attachment weld conforms to Figure INB-2500-14.

However, the licensee's request lists IWB-2500-13 as the configuration of the RPV skirt weld at BFN-2."

NRC's Request Item 2.a.

Submit a cross-sectional drawing of the BFN-2 attachment weld design that shows how the ultrasonic examination will provide effective surface coverage for this weld.

TVA's Response Item 2.a TVA is withdrawing relief request ISI-2-1.

NRC's Request Item 2.b Discuss the qualification plan for the ultrasonic technique.

TVA's Response Item 2.b See item 2.a above E1-3

0

NRC's Request Item 3 Re uest for Relief ISI-2-2: Reactor Pressure Vessel Threads in Flange This request states that the configuration of the cladded sealing

surface, and the stud hole locations themselves, limit accessibility to perform the volumetric examination to approximately 684 of that required by the Code.

Inspection Report R0034 was submitted to provide justification of the impracticality due to poor accessibility.

However, the hand-drawn sketch attached to R0034 does not clearly identify the geometric restrictions that cause a reduced examination volume.

Submit a detailed drawing that supports the argument for limited accessibility for the threaded areas of the flange.

TVA's Response Item 3 Relief request ISI-2-2 is withdrawn.

After further evaluation, TVA has determined that additional examination coverage may be obtained by using specialized search units which were not available during the time of the examinations.

Smaller search units and those of an offset angle are needed in order to examine the area between the reactor pressure vessel flange hole and the raised cladded seal area.

The reactor pressure vessel flange hole and the raised cladded seal areas of limitation will be examined during the second period of this interval along with the second period sample.

The first period sample percentage completed for Code Category B-G-1 was 21 percent which is in accordance with ASME Section XI Code, IWB-2412.

NRC's Request Item 4

Re uest for Relief No. ISI-2-4: Class 1 and or Class 2 Pi in Welds The table attached to ISI-2-4 specifically lists nine B-J and two B-F Examination Category welds.

No Class 2 welds are currently included in this request for relief.

Provide a list of any Class 2 (C-F-l or C-F-2 Category) welds for which relief is being requested, along with the proper justification for each, or revise this relief request to include only Class 1 welds.

TVA's Response Item 4

TVA has revised relief request ISI-2-4 (enclosed).

The revised relief request deletes the reference to examination categories C-F-1 and C-F-2 (class 2 welds), since no limitations have been identified during the second ten year inspection interval.

E1-4

NRC's Request Item 4.a Define the ultrasonic scan nomenclature used in the table attached to ISI-2-4, i.e., what orientations and angles do scans 1 through 5 represent?

TVA's Response Item 4.a The ultrasonic scan nomenclature utilized in ISI-2-4 is depicted in Figure 1.

The beam angles utilized during the examination are noted on the Examination Summary and Resolution Sheet and on the individual calibration reports provided in the previous submittal for each applicable weld examined.

The applicable scans are given the following nomenclature:

Scan 1,

a visual exam to determine if the weld is amenable for ultrasonic examination; Scan 2, zero degree base material scan, when applicable; Scan 3, an axial scan from the upstream side of the weld; Scan 4,

an axial scan from the downstream side of the weld; Scan 5,

a circumferential scan in the clockwise direction.

NRC's Request Item 4.b Please describe the method of computing the examination completion percentages listed in this table.

The volumetric coverage for the majority of the welds listed in the attached table appears to be low, and the information provided for each is insufficient to justify relief.

Outer surface contours and other geometric configurations that limit each of these examinations must be described in sufficient detail to provide an acceptable basis for impracticality per 10 CFR 50.55a(g)(6)(i).

The drawings included in recent inspection reports do not support this conclusion, i.e., several of the weld drawings appear to suggest increased accessibility with the application of specialized ultrasonic search units.

TVA's Response Item 4.b The method of computing weld examination completion percentages is based on the following suppositions.

Welds with access from both sides (scans 3, 4, 5,

6) are equal scans for calculating examination volume.

The formula used is: 0.25(scan 3)+ 0.25 (scan 4)

+ 0.25 (scan 5)+ 0.25 (scan 6).

2.

For welds with access from one side due to configuration (e.g., pipe, valve) the axial scan (scan 3 or 4) will equal 50% of the volume attained and the circumferential scans (scans 5 and

6) equal 50% combined.

Use the formula:

0.50(scan 3 or 4)

+.25(scan 5)

+ 0.25(scan 6)

= 1004.

0 4l

3.

Examination volume coverage may be increased by utilization of high angle longitudinal wave techniques.

Increasing the angle and the ability of L-waves to penetrate stainless steel weld material will increase the examination volume coverage by the amount depicted on the exam coverage drawing (ASME Section XI Code, 1986 Edition, Appendix III, figure III-3230-1).

4.

Examination limitations must factor weld length into account when an area is restricted due to lug attachments and other interferences.

As an example, the following is given:

a.

weld length = 100 inches b.

length of interferences

= 5 inches 5/100 =.05 or 54 reduction in coverage or 954 coverage of the weld length.

The ASME Section XI Code requires that the examination volume for each weld must be determined in order to establish the required beam path angles to maximize coverage and verify technique parameters.

The following paragraphs explain the determination of the Code required volumes, what constitutes a complete ASME Section XI examination for piping welds, the effects of examination limitations, and compliance with Code Case N-460, Alternate Examinations coverage for Class 1 and Class 2 weldsSection XI, Division 1.

The ASME Section XI required examination volume for each type of piping weld is shown in the IWB-2500 figures.

The volume generally contains the weld and 1/4" on each side of the weld.

The volume thickness contains (1/3 piping thickness) 1/3 (t) for the length of the examination volume.

The volume changes with variations in weld configuration (e.g. transition between different pipe thickness).

It is necessary to determine the required volume for each group of similar welds to allow setting of scanner limits for automated examinations and scan paths for manual examinations.

The ASME Section XI, 1986 Code Edition, No

Addenda, Section IWA-2232 states that piping weld required volume shall be examined per ASME Section XI Appendix III requirements.

Appendix III specifies the examination angles and scan directions for examining piping welds. It also specifies how the examinations are to be performed.

Variables such as weld preparation, weld crown width, or physical interference may preclude obtaining two-beam path direction coverage of the complete examination volume with half-V examination from two sides as shown in Appendix III of the 1986 Edition of the Code, Fig. III-3230-1. If this interference with examination coverage

occurs, the beam path is increased as required to obtain full coverage of the examination volume in two E1-6

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Alternatively, the interference may be eliminated by one or more of the following:

Reducing the dimension of the wedge edge-to-beam entry point.

2.

Reducing the search unit size.

3.

Increasing the beam angle.

4.

Conditioning the weld surface.

Examination for reflectors parallel to. the weld seam is normally performed using a sufficiently long examination beam path to provide coverage of the required examination volume in two-beam path directions.

The examination is performed from two sides of the weld, where practicable, or from one side of the weld, as

.a minimum.

Examination for reflectors transverse to the weld seams is normally performed on the weld crown on a single, scan path to examine the weld root by one half-V path in two directions along the weld where crowns have been reduced allowing access.

If access does not preclude examination on the crown due to loss of

contact, then the beam path is increased to obtain full coverage by skewing the search unit suffice;ently to cover the weld root area.

ASME Section. XI Code Case N-460 defines the "essentially 1004 of the, weld length" statement in the IWB-2500-1.

The Code Case states that a reduction in coverage up to 10 percent is permissible.

ASME Section XI interpretation XI-1-89-32 further clarifies the Code Case by defining that the exclusion cannot exceed 104 when the limitations from all required scans are combined additively.

All of the required scans are therefore equal in value.

The equality of scans is used when calculating the effect(s) of limitations as well as determining compliance with Code Case N-460.

Several items must be known about the weld being examined and the equipment used to perform the examination.before limitations and Code Case N-460 compliance can be calculated.

These include the required volume, as previously determined, the length of weld being examined, transducer offsets for automated exam equipment, and the length(s) of any.exam interference(s).

Most interferences do not affect both sides of a weld.

When both sides are affected the effect is not equal.

When a portion of a weld is partially examined, it is necessary to determine the start and stop points for each scan.

With these items known, i~t is possible to calculate the effect of a limited exam and whether "essentially,100< of the weld length" has been examined per Code Case N-460.

NRC's Request Item 4.c Provide a more detailed description of the limitation(s) for each of the piping welds listed in the request.

~I

TVA's Response Item 4.c Relief request ISI-2-4 (enclosed) has been revised.

The revision deleted four examination category B-Z welds and one examination category B-F weld.

Each weld contained in the revised relief request is addressed individually with a more detailed description of the limitation(s) and justification for the. basis for relief.

The photographs contained in relief request ISI-2-4 are BFN Unit 3 welds.

BFN Unit 3 weld limitations are typical of the limitations encountered in BFN Unit 2.

Photographs for BFN Unit 2 welds could not be obtained because of unit operation.

The photographs are for information only.

Welds deleted from relief request ISI-2-4 are listed below with a reason for the deletion.

Weld DRHR-2-12 was not examined for ASME Section XI credit and is deleted from relief request ISI-2-4.

DRHR-2-12 is not scheduled for examination during the second'en-year interval.

Weld GMS-2-10-LS Weld GMS-2-10-LS is a longitudinal seam weld.

This weld is deleted from relief request ISI-2-4 based on NRC approval of Code Case N-524 Alternative Examination Requirements for Longitudinal Welds in Class 1 and 2 Piping Section XI, Division 1.

Reference NRC's letter from Fredrick J.

Hebdon to Oliver Kingsley, Jr. dated September 28, 1994.

Welds RWC-2>>001-G002, RWCU-2>>004-G073, and RWCU-2-004<<G074 are new welds.

They were installed during the Unit 2 Cycle 6

refueling outage.

They are being deleted from the revised relief request ISI-2-4, since the construction code radiography serves as the preservice examination in accordance with IWB-2200(b).

NRC's Request Item 5 Additional Re uests for Relief Please verify that no additional requests for relief are required at this time. If additional relief requests are required, please submit them for staff review.

TVA'esponse Item 5 During the Unit 2 Cycle 7 refueling outage, TVA identified other components with examination limitations.

In accordance with 10 CFR 50.55a (g)(5)(iv), TVA will submit any additional new or revised inservice inspection relief rec{uests.

Although 10 CFR 50.55a (g)(5)(iv) does not require these relief requests to be submitted until one year after the end of the current 10-year inspection interval (interval began May 24, 1992),

TVA expects to submit these relief requests within six months of the date of this letter.

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m nen RE T F R RELIEF I I-2-4 (Unit 2)

Class 1 Piping Welds (refer to attached list)

Item Num er:

B-F and B-J B5.130, B9.10, or B9.30

'In i n R ir men:

ASME Section XI, Table IWB-2500-1, Examination Categories B-F and B-J piping welds greater than or equal to NPS 4-inch f

i f:

In some cases it is not possible to perform the volumetric ultrasonic examination from both sides of the weld due to configuration or permanent features such. as:

piping supports;. or fire retardant insulation in the adjacent wall penetration.

Also attached is a detailed description of the limitations for each weld. listed and a summary of the scans performed.

Al em te Ins ection:

None.

E1-10

WELD CODE NUMBER CAT.

REQUEST FOR RELIEF ISI-2-4 (continued)

ITEM SIZE ISI CODE NUMBER MAT'L.

NPS DRAWING CONFIGURATION SCAN % REMARKS DCS-2-03 B-J B9.11 SS 12 ISI-0271-C VALVETO BELLOWS 37.4 No scan 3 or 4, limited scans 5 and 6 DCS-2-12 B-J B9.11 SS 12 ISI-0271-C VALVETO BELLOWS 37.4 No scan 3 or 4, limited scans 5 and 6 TCS-2-422 B-F GMS-2-10 B-J B5.130 DM B9.11 CS 12 ISI-0271-C PIPE TO VALVE 86.5 26 ISI-0222-C VALVETO PIPE 86 No scan 4, limited scans 5 and 6; supplemented with 45 degree search No scan 3 and surface restriction; scan 4 limited'cans 5 and 6 limited DRHR-2-03 B-J B9.11 SS 24 ISI-.0221-C VALVETO PENETRATION 52 Limited due to surface contour; Scans 3, 4, 5, and 6, limited Scans 3 and 4 supplemented with a

WELD CODE NUMBER CAT.

DRHR-2-03 (Cont'd) 52 60 degree search unit; Scans 5 and 6 supplemented with a 45 degree refracted longitudinal wave search unit REQUEST FOR RELIEF ISI-2-4 (continued)

ITEM SIZE ISI CODE NUMBER MAT'L.

NPS DRAWING CONFIGURATION SCAN % REMARKS TRWCU-2-02 B-J B9.11 SS 4

ISI-0272-C VALVETO VALVE 52.

Obtain best scans 3 and 4 and supplemented scans 5 and 6 E1-12

RE UEST FOR RELIEF ISI-2-4 continued Weld Number Cd C

C~fi Scan Examination Limitation Details DCS-2-03 B-J Valve to Bellows 37.4 Basis for Relief No axial scan from the upstream side of the weld (Scan 3) was performed due to a stainless steel valve (FCV-75-25).

The combined effect of the valve surface taper and the anisotropic nature of the static cast stainless material creates a scan limitation and prevents a scan from this side of the weld.

No axial scan from the downstream side of the weld (Scan 4) performed due to a bellows configuration.

Search unit contact is lost by the radius of curvature from the bellows side, Circumferential scan in the clockwise ( Scan 5) and circumferential scan in the counter clockwise direction (Scan 6) are limited due to the weld to fittingjunction.

Loss of contact of the search unit impedes obtaining code coverage for scans 5 and 6.

Scans 5 and 6 were supplemented with a 45 degree refracted longitudinal wave search unit in order to maximize coverage.

The limitations are noted on the ultrasonic examination data sheets provided with the original response.

(See attached photograph of similar weld in Unit 3, DCS 03)

E1-13

RE UEST FOR RELIEF I I-2-4. continued Weld Number C~d.

~C' Scan 0

Examination Limitation Details DCS-2-03 (Cont'd)

B-J Valve to Bellows 37.4 Justification for Relief:

TVAperformed a surface and ultrasonic examination on accessible areas of the 12 inch circumferential valve to flued head weld, DCS-2-03.

The design configuration of the subject weld limits ultrasonic examination preventing 100% code examination coverage.

==

Conclusion:==

Based on the above justification, it is concluded that the code requirements are impractical.

TVA's supplemental examinations provide an acceptable level of quality and safety.

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RE UEST FOR RELIEF ISI-2-4 continued Weld Number Cd C

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Examination Limitation Details DCS-2-12 B-J Valve to Bellows 37.4 Basis for Relief No axial scan from the upstream side of the weld (Scan 3) was performed due to a stainless steel valve (FCV 75-53).

The combined effect of the valve surface taper and the anisotropic nature of the static cast stainless material creates a scan limitation and prevents a scan from this side of the weld.

No axial scan from the downstream side of the weld (scan 4) was performed due to a bellows configuration.

Search unit contact is lost by the radius of curvature from the bellows side.

Circumferential scan in the clockwise (Scan 5) and circumferential scan in the counterclockwise direction (Scan 6) are limited due to the weld to fittingjunction.

RE UEST FOR RELIEF ISI-2-4 continued Weld Number CCC.C~A

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Examination Limitation Details DCS-2-12 (Cont'd)

B-J Valve to Bellows 37.4 Loss of contact of the search unit impedes obtaining code coverage for scans 5 and 6.

Scans 5 and 6 were supplemented with a 45 degiee refracted longitudinal wave search unit in order to maximize coverage and improve attenuation loss by shear wave search units on weld metal.

( See attached photograph of similar weld in Unit 3, DCS-3-12)

Justification for Relief:

TVAperformed a surface and ultrasonic examination on accessible areas of the 12 inch circumferential valve to flued head weld, DCS-2-12.

The design configuration of the subject weld limits ultrasonic examination preventing 100% code examination coverage.

==

Conclusion:==

Based on the above justification, it is concluded that the code requirements are impractical.

TVA's supplemental examinations provide an acceptable level of quality and safety.

E1-18

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RE UEST FOR RELIEF ISI-2-4 continued Weld Number TCS-2-422 B-F Pipe to Valve Cd C

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86.5 Examination Limitation Details Basis for Relief:

No axial scan from the downstream side of the weld (Scan 4) performed due to a stainless steel valve (HCV-75-27).

The combined effect of the valve surface taper and the anisotropic nature of the static cast stainless material creates a scan limitation and prevents a scan from this side of the weld.

Circumferential scan in the clockwise direction (Scan 5) and circumferential scan in the counter clockwise direction (Scan 6) are limited due to the weld to fittingjunction.

Loss of contact of the search unit impedes obtaining code coverage for scans 5 and 6.

Scans 5 and 6 were supplemented with a 45 degree refracted longitudinal wave search unit in order to maximize coverage and improve attenuation loss by shear wave search units on weld metal. ( See attached photograph of similar weld in Unit 3, TCS-3-.422)

Justification for Relief:

TVAperformed a surface and ultrasonic examination on accessible areas of the 12 inch circumferential pipe to valve weld, TCS-2-422.

A high percentage of code

4l II

RE VEST FOR RELIEF ISI-2-4 continued Weld Number Cd C

~Cfi Scan Examination Limitation Details TCS-2-422 (Co'nt'd)

B-F Pipe to Valve 86.5 coverage was obtained (86.5%).

The design configuration of the subject weld limits ultrasonic examination preventing 100% code examination coverage.

==

Conclusion:==

Based on the above justification, it is concluded that the code requirements are impractical. TVA's supplemental examinations provide an acceptable level of quality and safety.

E1-22

REFERENCE ORAK DRAVO E-245!J-IC.

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Weld Number CdC.~Cfi Scan Examination Limitation Details GMS-2-10 B-J Valve to Pipe Basis for Relief:

No axial scan from the upstream side of the weld

( Scan 3) was performed due to valve (FCV-01-026).

The combined effect of the valve surface taper and the anisotropic nature of the static cast material creates a limitation and prevents scan from this side of the weld.

An axial scan from the downstream side of the weld (Scan 4) was limited due to fire retardant insulation inside the penetration.

Scan 4 was limited to a distance of 1.9 inches from centerline for the 45 degree shear and a distance of 1.5 inches for the 60 degree shear.

Scans 5 and 6 are limited due to the weld to fitting junction.

Loss of contact of the search unit impedes obtaining code coverage for the circumferential scan in the clockwise direction (scan 5) and the circumferential scan in the counter clockwise direction (Scan 6).

(See attached photograph of similar weld in unit 3, GMS-3-10)

E1-25

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RE UEST FOR RELIEF ISI-2-4 continued Weld Number Cd C.

~Cfi Scan Examination Limitation Details GMS-2-10 (Cont'd)

B-J Valve to Pipe Justification for Relief:

TVAperformed a surface and an ultrasonic examination on accessible areas of the 26 inch circumferential valve to pipe weld, GMS-2-10.

A hi h ercenta e of code covera e was obtained

~86 o. The design configuration of the subject weld limits ultrasonic examination preventing 100% code examination coverage. This limitation is due to permanent asbestos-type insulation installed inside the penetration up to the subject weld. Removal requires: (1) a Design Change Notice to revise drawings depicting removed insulation from the mechanical drywell penetration assemblies, (2) a calculation to evaluate the impact of the removed insulation, (3) the design and fabrication of special metal reflective insulation sections to replace removed insulation, (4) a work area ventilated tent to contain asbestos insulation, (5) insulation workers having to contend with the requirements of working in both a contaminated area (C-Zone) and an asbestos hazard area.

E1-26

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Weld Number CCC.~C

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Examination Limitation Details GMS-2-10 (Cont'd)

B-J Valve to Pipe

==

Conclusion:==

Based on the above justification and hardship, it is concluded that the code requirements are impractical.

TVA's supplemental examinations and high percentage of coverage provides an acceptable level of quality and safety.

E1-27

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Weld Number Cd'C C~d Scan Examination Limitation Details DRHR-2-03 Valve to Penetration 52 Basis for Relief:

An axial scan from the upstream side of the weld (Scan 3) is limited due to a stainless steel valve (FCV-74-53).

The combined effect of the valve surface taper and the anisotropic nature of the static cast stainless material creates a scan limitation; however a best effort scan was performed from this side of the weld in order to maximize coverage.

A 60 degree search unit was used to increase effective coverage.

An axial scan from the downstream side of the weld (Scan 4) was limited due to a flued head penetration.

Search unit scan area is limited by the penetration configuration. A 60 degree search unit was used to increase effective coverage.

A circumferential scan in the clockwise direction (Scan 5) and a circumferential scan in the counter clockwise direction (scan 6) are limited due to the weld to fitting junction.

Loss of contact of the search unit impedes obtaining code coverage for Scans 5 and 6. Scans 5 and 6 were supplemented with a 45 degree El-30

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Weld Number Cd Ci.

C~fi Scan Examination Limitation Details DRHR-2-03 (Cont'd)

B-J Valve to Penetration 52 refracted longitudinal wave search unit in order to maximize coverage and improve attenuation loss by shear wave search units on weld metal.

( See attached photograph of similar weld in unit 3, DRHR-3-03)

Justification for Relief:

TVAperformed an ultrasonic examination on accessible areas of the 24 inch circumferential valve to flued head weld, DRHR-2-03.

The design configuration of the subject weld limits ultrasonic examination preventing 100% code examination coverage.

==

Conclusion:==

Based on the above justification, it is concluded that the code requirements are impractical. TVA's supplemental examinations provide an acceptable level of quality and safety.

E1-31

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Examination Limitation Details TRWCU-2-02 B-J Valve to valve 50 Basis for Relief:

Note: This weld was replaced prior to startup during the Unit 2, Cycle 6 outage due to the 69-580 valve replacement.

TVArequests relief in order to maintain code percentage requirements for the first period.

Best effort axial scan from the upstream side of the weld (Scan 3) performed from stainless steel valve side (69-579).

The combined effect of the valve surface taper and the anisotropic nature of the static cast stainless material creates a scan limitation and prevents a meaningful scan from this side of the weld.

Loss of search unit contact due to fitting taper radius is a major contributor to the limitation noted.

Best effort axial scan from the downstream side of the weld (Scan 4) performed from stainless steel valve side (69-580).

The combined effect of the valve surface taper and the anisotropic nature of the static cast stainless material creates a scan limitation and prevents a meaningful scan from this side of the weld. Circumferential scan in the clockwise direction

- (Scan 5) and a circumferential scan in the counter clockwise direction ( Scan 6) were supplemented with a 45 degree refracted longitudinal wave search unit in order to maximize coverage.

El-34

Weld Number CCC.~C Scan o

Examination Limitation Details TRWCU-2-02 (Cont'd)

B-J Valve to valve 50

( See attached photograph of similar weld in Unit 3, RWCU-3-004-002)

Justification for Relief:

TVAperformed a surface and an ultrasonic examination on accessible areas of the 4 inch circumferential valve to valve weld, TRWCU-2-02.

~occlusion:

The design configuration of the subject weld limits ultrasonic examination preventing 100% code examination coverage.

Based on the above justification, ifis concluded that the code requirements are impractical. TVA's supplemental examinations provide an acceptable level of quality and safety.

El-35

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ENCLOSURE, 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

L'IST OF COMMITMENTS TVA will revise 2-SI.-4.6.G, note six to delete the reference to stainless steel welds, since Category B-F is app'licable to only dissimilar metal welds.

TVA expects to revise 2-SI-4.6.G by June 23, 1995.

The reactor pressure vessel flange hole and the raised cladded seal areas of limitation will be examined during the second period of this interval along with the second period sample.

V.