Letter Sequence Supplement |
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Results
Other: L-13-035, Firstenergy Nuclear Operating Companys Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1, L-13-057, Overall Integrated Plan in Response to March 12, 2012 Commission Order Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051), L-13-243, Firstenergy Nuclear Operating Companys, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No, L-13-244, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses Re Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), L-13-254, Online Reference Portal for Review of Mitigation Strategies Submittal in Response to Order EA-12-049, L-14-024, Firstenergy Nuclear Operating Companys (Fenocs) Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), L-14-025, Firstenergy Nuclear Operating Companys Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-, L-14-257, Davis-Bes, Perry, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Reqard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, L-14-259, Firstenergy Nuclear Operating Companys (Fenocs) Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), L-15-001, Firstenergy Nuclear Operating Companys (Fenocs) Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool, L-15-002, Firstenergy Nuclear Operating Companys (Fenocs) Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies, L-15-218, Firstenergy Nuclear Operating Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051), L-15-219, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External, L-15-337, Completion of Required Action by NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events and NRC Order EA-12-051, Reliable Spent Fuel Pool, ML13364A166, ML14029A021, ML15152A218, ML15292A139
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MONTHYEARL-13-057, Overall Integrated Plan in Response to March 12, 2012 Commission Order Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)2013-02-27027 February 2013
Overall Integrated Plan in Response to March 12, 2012 Commission Order Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)
Project stage: Other
L-13-035, Firstenergy Nuclear Operating Companys Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12013-02-27027 February 2013
Firstenergy Nuclear Operating Companys Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1
Project stage: Other
DCL-13-021, Areva Calculation 32-9200249-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis - Non Proprietary2013-03-0505 March 2013
Areva Calculation 32-9200249-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis - Non Proprietary
Project stage: Request
DCL-13-021, Areva Affidavit for Areva Calculations 32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and 32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer N2013-03-0505 March 2013
Areva Affidavit for Areva Calculations #32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and #32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Noz
Project stage: Request
ML13078A2912013-03-0505 March 2013
Areva Calculation 32-9200291-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Nozzles (Non-Proprietary)
Project stage: Request
DCL-13-024, Supplement to ASME Section XI Inservice Inspection Program Relief Request REP-1 U2, Revision 22013-03-0707 March 2013
Supplement to ASME Section XI Inservice Inspection Program Relief Request REP-1 U2, Revision 2
Project stage: Supplement
ML13081A0742013-04-11011 April 2013
Summary Conference Call Between Pacific and Electric Co., and NRC Regarding Verbal Authorization of Relief Request Rep-1 U2, Revision 2
Project stage: Approval
ML13172A1792013-06-25025 June 2013
Request for Additional Information Regarding Overall Integrated Plan in Response to Order Number EA-12-051, Reliable Spent Fuel Pool Instrumentation
Project stage: RAI
L-13-156, Capability of Perform Offsite Dose Assessment During an Event Involving Multiple Release Sources2013-06-25025 June 2013
Capability of Perform Offsite Dose Assessment During an Event Involving Multiple Release Sources
Project stage: Request
ML13183A2162013-07-0303 July 2013
Online Reference Portal for Review of Mitigation Strategies Submittal in Response to Order EA-12-049
Project stage: Approval
ML13170A1962013-07-11011 July 2013
Request for Withholding Information from Public Disclosure - 3/5/2013 Affidavit Executed by G. Elliott, Areva Np Inc., Regarding Areva Calculations Provided for Relief Request REP-1 U2, Revision 2
Project stage: Withholding Request Acceptance
L-13-234, Response to Request for Additional Information Regarding Firstenergy Nuclear Operating Companys (Fenocs) Overall Integrated Plan in Response to 03/12/2012 Commission Order Issuance of Order to Modify2013-07-18018 July 2013
Response to Request for Additional Information Regarding Firstenergy Nuclear Operating Companys (Fenocs) Overall Integrated Plan in Response to 03/12/2012 Commission Order Issuance of Order to Modify
Project stage: Response to RAI
ML13211A1682013-07-26026 July 2013
Westinghouse, Notification of Potential Existence of Defects Pursuant to 10 CFR Part 21 Inconsistency Between the Intended Design Functionality of the Shield Passive Thermal Shutdown Seal (SDS) and That Observed During Post-Service Testing
Project stage: Request
L-13-254, Online Reference Portal for Review of Mitigation Strategies Submittal in Response to Order EA-12-0492013-08-0505 August 2013
Online Reference Portal for Review of Mitigation Strategies Submittal in Response to Order EA-12-049
Project stage: Other
L-13-244, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses Re Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)2013-08-26026 August 2013
First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses Re Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)
Project stage: Other
IR 05000412/20132012013-08-26026 August 2013
FENOC, Closed Meeting Notice 13-02, Requested a Regulatory Conference with the NRC to Discuss IR 05000354 and 05000412/2013201
Project stage: Request
L-13-243, Firstenergy Nuclear Operating Companys, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No2013-08-26026 August 2013
Firstenergy Nuclear Operating Companys, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No
Project stage: Other
ML13232A3082013-08-28028 August 2013
Relief Request REP-1 U2, Revision 2, Alternative to Code Requirements for Pressurizer Structural Weld Overlays, for the Third 10-Year Inservice Inspection Interval
Project stage: Approval
ML13297A2332013-11-19019 November 2013
Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation
Project stage: RAI
ML14029A0212014-01-28028 January 2014
Mega-Tech Services, LLC Technical Evaluation Report Regarding the Overall Integrated Plan for Beaver Valley Power Station, Units 1 and 2, TAC Nos.: MF0841 and MF0842 (Revision 2)
Project stage: Other
ML13364A1662014-01-29029 January 2014
Interim Staff Evaluation Related to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)
Project stage: Other
L-14-025, Firstenergy Nuclear Operating Companys Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-2014-02-27027 February 2014
Firstenergy Nuclear Operating Companys Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-
Project stage: Other
L-14-024, Firstenergy Nuclear Operating Companys (Fenocs) Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)2014-02-27027 February 2014
Firstenergy Nuclear Operating Companys (Fenocs) Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
Project stage: Other
L-14-259, Firstenergy Nuclear Operating Companys (Fenocs) Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)2014-08-28028 August 2014
Firstenergy Nuclear Operating Companys (Fenocs) Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
Project stage: Other
L-14-257, Davis-Bes, Perry, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Reqard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events2014-08-28028 August 2014
Davis-Bes, Perry, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Reqard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
Project stage: Other
L-15-002, Firstenergy Nuclear Operating Companys (Fenocs) Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies2015-02-26026 February 2015
Firstenergy Nuclear Operating Companys (Fenocs) Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies
Project stage: Other
L-15-001, Firstenergy Nuclear Operating Companys (Fenocs) Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool2015-02-26026 February 2015
Firstenergy Nuclear Operating Companys (Fenocs) Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool
Project stage: Other
ML15152A2182015-06-0909 June 2015
Plan for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051
Project stage: Other
L-15-218, Firstenergy Nuclear Operating Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)2015-08-18018 August 2015
Firstenergy Nuclear Operating Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)
Project stage: Other
L-15-219, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External2015-08-27027 August 2015
Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External
Project stage: Other
ML15292A1392015-11-0202 November 2015
Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051
Project stage: Other
L-15-337, Completion of Required Action by NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events and NRC Order EA-12-051, Reliable Spent Fuel Pool2015-12-21021 December 2015
Completion of Required Action by NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events and NRC Order EA-12-051, Reliable Spent Fuel Pool
Project stage: Other
2013-08-28
[Table View] |
Text
Pacific Gas and Electric Company March 7, 2013 PG&E Letter DCL-13-024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-323, OL-DPR-82 Diablo Canyon Unit 2 Barry S. Allen Site Vice President 10 CFR 50.55a Diablo Canyon Power Plant Mail Code 104/6 P. O. Box 56 Avila Beach, CA 93424 805.545.4888 Internal: 691.4888 Fax: 805.545.6445 Supplement to ASME Section XI Inservice Inspection Program Relief Request REP-1 U2, Revision 2
References:
- 1. PG&E Letter DCL-07-038, "ASME Section XI Inservice Inspection Program Relief Request REP-1 U2," dated March 28, 2007.
- 2. PG&E Letter DCL-07-099, "ASME Section XI Inservice Inspection Program Relief Request REP-1 U2, Revision 1, and Response to Request for Additional Information," dated October 22, 2007.
- 3. PG&E Letter DCL-07-105, "ASME Section Xllnservice Inspection Program Relief Request REP-1 U2, Revision 1; Response to Request for Additional Information," dated November 29, 2007.
- 4. NRC Letter, "Diablo Canyon Power Plant, Unit No.2 - Approval of Relief Request REP-1 U2, Revision 1, for the Application of Weld Overlay on Dissimilar Metal Welds of Pressurizer Nozzles (TAC No. MD4974 )," dated February 6, 2008.
- 5. PG&E Letter DCL-13-021, "ASME Section XI Inservice Inspection Program Relief Request REP-1 U2, Revision 2,"
dated March 5,2013.
Dear Commissioners and Staff:
On March 5, 2013 Pacific Gas and Electric Company (PG&E) submitted
. Reference 5, pursuant to 10 CFR 50.55a(a)(3)(i), requesting NRC approval for ASME Section XI Inservice Inspection Program Relief Request REP-1 U2, Revision 2. PG&E is submitting this supplement to clarify that all of Relief Request REP-1 U2, Revision 2 is pursuant to 10 CFR 50.55a(a)(3)(i) except for Sections 3.a.(3)(a)(i) and ii) of Attachment 1 to Enclosure 1 of Reference 5.
These two sections are requested for NRC authorization pursuant to 10 CFR 50.55a(a)(3)(ii).
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
Document Control Desk March 7,2013 Page 2 PG&E Letter DCL-13-024 The Enclosure to this letter contains a revised Section 5.13, "Potential Hardship,"
of Enclosure 1 to Reference 5 as the basis for hardship without a compensating increase in the level of quality and safety for Sections 3.a.(3)(a)(i) and ii) of of Enclosure 1 to Reference 5.
PG&E makes no regulatory commitments (as defined by NEI 99-04) in this letter.
This letter includes no revisions to existing regulatory commitments If you have any questions, or require additional information, please contact Tom Baldwin at (805) 545-4720.
Sincerely, J57 &A-a-Barry S. Allen Site Vice President pns3/6984 SAPN 50540188 Enclosure cc:
Diablo Distribution cc/enc:
Gonzalo L. Perez, Branch Chief, California Department of Public Health Elmo E. Collins, NRC Region IV Thomas R. Hipschman, NRC Senior Resident Inspector James T. Polickoski, NRR Project Manager State of California, Pressure Vessel Unit A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
Enclosure PG&E Letter DCL-13-024 Revised Section 5.13, "Potential Hardship," of Enclosure 1 to PG&E Letter DCL-13-021, "ASME Section Xllnservice Inspection Program Relief Request REP-1 U2, Revision 2," dated March 5, 2013 5.13 Potential Hardship To restore the weld overlays to compliance with the 3-inch linear dimension requirement specified in the relief request, the flaws in the overlays will have to be excavated and repaired using the same automated welding process with which they were originally installed. The repairs of the overlays present a hardship for the following reasons:
- 1. Repairs to the weld overlay would be required on two safety relief valve nozzles and the pressurizer spray nozzle. These pressurizer nozzles are located at the top of the pressurizer, which is approximately 25 feet from the containment floor with intervening hazards. Repair of the overlays will expose personnel to potential fall hazards. Exacerbating the fall hazard is the tight and awkward environment in which the work is required to be performed, requiring workers to maneuver around pipes and openings in grating.
- 2. Completion of the repair would incur increased dose. Although the average effective dose rate is not excessive in the area (approximately 4.5 mR per hour), the amount of work and number of people required to prepare, perform, monitor, inspect and demobilize from the repair is such that the total dose accumulated is high. Based on the current schedule and personnel estimates, the total dose required to perform the repair work is at least 2.6 Rem. This would result in this single activity being approximately 10 percent or more of the total dose expected for this outage.
- 3. Excavation and repair of the overlays has the potential to degrade the overlay and beneficial compressive stress on the inner diameter of the nozzles.
- a. The flaws would be excavated, creating a cavity that would be repair welded. However, the weld cavity will reduce welding accessibility as compared to the original welding operation. The decreased accessibility will make performance of the welds more difficult and create the possibility of introduction of additional flaws that would then require subsequent excavation and repair, increasing the total time that personnel are exposed to fall hazards and the total dose for the work.
- b. The potential for incomplete inter-bead and side wall fusion is much greater when welding in narrow cavities as compared to the original 1
Enclosure PG&E Letter DCL-13-024 structural weld overlay installation. These flaws are more likely to have a planar orientation due to incomplete fusion to the side wall of the repair cavity. Even though these flaws may be acceptable to the NDE requirements, they may be more detrimental to the integrity of the weld overlay than the laminar flaws that were removed by the repair.
- c. Weld thermal cycles on a multilayer Alloy 52M excavation increases the risk of ductility dip cracking and opening of grain boundaries. Multiple repairs also increase the risk of forming deleterious phases such as Laves phase, which can promote liquation cracking.
- d. Grinding and welding will potentially alter the stress profile of the overlay. Although the design of the repair would be planned to minimize the impact on the overall effectiveness of the overlay, the potential exists to decrease the beneficial compressive stress that the weld overlay imparts to the inner surface of the nozzle. The compressive stress decreases the probability of primary water stress corrosion cracking in the susceptible material by reducing the stress responsible for crack initiation and propagation.
- 4. Grinding will be required to excavate the flaws prior to weld repair.
Because the flaws cannot be readily seen, complete flaw removal cannot be assured until the weld repair is completed and a post-repair ultrasonic test is performed. If flaws are identified that do not meet the acceptance criteria of the relief request, additional grinding and repair would be required, further increasing the potential to introduce localized stress and increase personnel exposure to fall hazards and radiation.
- 5. The installation of the original weld overlays required rework of pipe hangers and realignment of piping. Although the repair work is not as extensive as the original overlay work, it does have the potential to require rework of some pipe hangars and cutting and re-welding to realign the discharge piping for the two safety relief valves that would require repairs.
This would further increase personnel exposure to fall hazards and radiation.
Based on the structural analysis and fracture mechanics flaw growth analyses that have been performed that demonstrates that the existing structural integrity of the weld overlay is acceptable with significant margin, repair of the identified flaws on safety relief valve nozzles A, B and the pressurizer spray line nozzle does not provide a compensating increase in safety to offset the hardships discussed above.
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