ML17334A627
| ML17334A627 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/14/1998 |
| From: | John Hickman NRC (Affiliation Not Assigned) |
| To: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| References | |
| TAC-M94871, TAC-M94872, NUDOCS 9801260067 | |
| Download: ML17334A627 (10) | |
Text
January 14, 1998 Mr. E. E. Fitzpatrick, Vice President Indiana Michigan Power Company Nuclear Generation Group 500 Circle Drive Buchanan, MI 49107
SUBJECT:
REQUEST FOR ADDITIONALINFORMATIONREGARDING THE D.C.COOK NUCLEAR PLANT, UNITS 1 AND 2 THIRD 10-YEAR INTERVALINSERVICE INSPECTION PROGRAM PLAN ANDASSOCIATED REQUESTS FOR RELIEF (TAC NOS. M94871 and M94872)
Dear Mr. Fitzpatrick:
The staff, with assistance from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL), is reviewing and evaluating the third ten-year interval inservice inspection program plan requests for relief from the ASME B8 PV Code,Section XI requirements for the D.C. Cook Nuclear Plant, Units 1 and 2. Additional information is required in order for the staff to complete its review.
The staff requests that a response be provided within sixty days to meet the staffs inservice inspection program plan review schedule.
In addition, to expedite the review process, please send a copy of the RAI response to the NRC's contractor, INEEL, at the following address:
Michael T. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Please call me at (301) 415-3017 ifyou have any questions.
Sincerely, John IN. AicKmak, $'ro~ect Manager Or' a3, si n d by:
Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.: 50-315 and 50-316
Enclosure:
, Request for Additional Information Distribution: Docket File PUBLIC PDIII-3 Reading OGC J. Hickman R. Savio
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January 14, 1998 Mr. E. E. Fitzpatrick, Vice President Indiana Michigan Power Company Nuclear Generation Group 500 Circle Drive Buchanan, Ml 49107
SUBJECT:
REQUEST FOR ADDITIONALINFORMATIONREGARDING THE D.C.COOK NUCLEAR PLANT, UNITS 1 AND 2 THIRD 10-YEAR INTERVALINSERVICE INSPECTION PROGRAM PLAN ANDASSOCIATED REQUESTS FOR RELIEF (TAC NOS. M94871 and M94872)
Dear Mr. Fitzpatrick:
The staff requests that a response be provided within sixty days to meet the staff's inservice inspection program plan review schedule.
In addition, to expedite the review process, please send a copy of the RAI response to the NRC's contractor, INEEL, at the following address:
Michael T. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Please call me at (301) 415-3017 ifyou have any questions.
Sincerely, Jonn II. AicKmak, Prospect Manager Or' a3, si n
d by:
Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.: 50-315 and 50-316
Enclosure:
Request for Additional Information Distribution: Docket File PUBLIC PDIII-3 Reading OGC J. Hickman R. Savio
'OCUMENT NAME: G:iDCCOOKic094871.RAI To receive a of this document. hdicate n the tox C*
w/o attachment/enctostxe Es with attachment/enctostxe N ~ No E. Adensam B. Burgess, Rill The staff, with assistance from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL), is reviewing and evaluating the third ten-year interval inservice inspection program plan requests for relief from the ASME B&PVCode,Section XI requirements for the D.C. Cook Nuclear Plant, Units 1 and 2. Additional information is required in order for the staff to complete its review.
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-0001 January 14, 1998 Mr. E. E. Fitzpatrick, Vice President Indiana Michigan Power Company
, Nuclear Generation Group 500 Circle Drive Buchanan, Ml 49107
SUBJECT:
REQUEST FOR ADDITIONALINFORMATIONREGARDING THE D.C.COOK NUCLEAR PLANT, UNITS 1 AND 2 THIRD 10-YEAR INTERVALINSERVICE INSPECTION PROGRAM PLAN ANDASSOCIATED REQUESTS FOR RELIEF (TAC NOS. M94871 and M94872)
Dear Mr. Fitzpatrick:
The staff, with assistance from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL), is reviewing and evaluating the third ten-year interval inservice inspection program plan requests for relief from the ASME B8 PV Code,Section XI requirements for the D.C. Cook Nuclear Plant, Units 1 and 2. Additional information is required in order for the staff to complete its review.
The staff requests that a response be provided within sixty days to meet the staffs inservice inspection program plan review schedule.
In addition, to expedite the review process, please send a copy of the RAI response to the NRC's contractor, INEEL, at the following address:
Michael T. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Please call me at (301) 415-3017 ifyou have any questions.
Sincerely, John B. Hickman, Project Manager Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.: 50-315 and 50-316
Enclosure:
Request for Additional Information
E. E. Fitzpatrick Indiana Michigan Power Company CC:
Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Attorney General Department of Attorney General 525 West Ottawa Street Lansing, Ml 48913 Township Supervisor Lake Township Hall P.O. Box 818 Bridgman, Ml 49106 Al Blind, Site Vice President Donald C. Cook Nuclear Plant 1 Cook Place Bridgman, MI 49106 U.S. Nuclear Regulatory Commission Resident Inspector's Office 7700 Red Arrow Highway Stevensville, MI 49127 Gerald Chamoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, NW.
Washington, DC 20037 Mayor, City of Bridgman P.O. Box 366 Bridgman, Ml 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, Ml 48909 Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P.O. Box 30630 CPH Mailroom Lansing, Ml 48909-8130 Donald C. Cook Nuclear Plant Units 1 and 2 Steve J. Brewer Indiana Michigan Power Company Nuclear Generation Group 500 Circle Drive Buchanan, Ml 49107
INDIANAMICHIGANPOWER COMPANY, DONALDC. COOK NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NUMBERS 50-315 AND 50-316 REQUEST FOR ADDITIONALINFORMATION(RAI)
THIRD 10-YEAR INTERVALINSERVICE INSPECTION (ISI) PROGRAM PLAN 1.
co
/
us o view Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) 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 design and access provisions and preservice examination requirements, set forth in ASME Code Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components.
This section of the regulations also requires that 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 in 10 CFR 50.55a(b) 12 months prior to the start of a successive 120-month interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Nuclear Regulatory Commission (NRC) approval.
The staff has reviewed the available information in the Donald C. Cook Nuclear Plant, Units 1 and 2, Third Ten Year Inservice Inspection Plan, Revision 0, submitted January 25, 1996, and the licensee's responses, dated September 10, 1996 and November 7, 1996, to the NRC's request for additional information.
- 2. A d'ion I
ion Based on the above review, the staff has concluded that additional information and/or clarification is required to complete the review of the ISI Program.
A.
Request for Relief No. 2 proposes ultrasonic examination of the full examination volume ofthe recirculation loop nozzle-to-safe end welds in lieu of the Code-required surface examination.
The request states "Mockups of this area have been fabricated and the capability of the ultrasonic examination technique and procedure to detect outside surface indications has been demonstrated."
Confirm that the ultrasonic examination technique has been demonstrated using outside surface connected cracks, and not notches.
In addition, provide documentation and/or details including when and where the demonstration was performed, who performed it, and who, if anyone, from the NRC witnessed the demonstration.
B.
Relief Request No. 4 states that limited access to the reactor vessel closure and lower head dollar plate welds prevent any examination of either weld. Considering that no volumetric examination willbe performed on these welds, describe how reasonable assurance of their structural integrity willbe provided. Are there other RPV circumferential head welds that are being examined'P What percentage of the intersecting meridional welds can be examined?
In the licensee's proposed alternative, it is stated that the accessible length of one closure head meridional weld will be examined.
The Code requires examination of all head welds, is this a typographical error?
C.
Requests for Relief Nos. 5 and 6 are for Class 2 welds within penetrations.
However, relief cannot be granted on a generic basis.
Identify each weld for which relief is requested.
D.
Relief Request No. 7 seeks authorization to perform a full-vee examination from the vessel side in lieu of performing half-vee examinations from both sides of the pressurizer surge nozzle-to-vessel weld. Generally, full-vee path examinations are
difficultto perform on cladded vessels.
What is the level of confidence in the effectiveness of this examination and what portion of the Code-required volume can be examined?
Can the circumferential scans be performed to the extent required by the Code?
Provide coverage plots or a technical discussion summarizing volumetric coverage obtained for pressurizer nozzle-to-vessel Weld 2-RC-21.
E.
The licensee has requested authorization to implement Code Case N-509, Alternative Rules forthe Selection and Examination of Class 1, 2, and 3 Integrally Welded Attachments.
The NRC has allowed the use of Code Case N-509 provided that f
'/
piping, pump, and valve integral attachments distributed among all Class 1, 2, and 3 systems.
Confirm that this condition willbe met.
F.
IWA-2441(a) requires that the inservice inspection plan identify the Code cases that willbe used during the interval.
In the licensee's September 10, 1996 response to the NRC's RAI, Code Case N<81 is the only Code Case listed. Based on the difference between relief requests submitted with the second interval program plan and those submitted with the third interval program plan, it appears that there are other Code cases being implemented at D. C. Cook (e.g., N-460). Provide a list ofyllthe Code Cases being used at Donald C. Cook, Units 1 and 2, that are included in Regulatory Guide 1.147, Inservice inspection Code Case Acceptability ASME Section XIDivision 1.
G.
The licensee must state the specific paragraph of 10 CFR 50.55a under which the request is submitted and provide supporting justification as discussed below.
The Regulations allow a licensee to propose an alternative to CFR or ASME Code requirements in accordance with 10 CFR 50.55a(a)(3)(I) or 10 CFR 50.55a(a)(3)(ii).
Pursuant to 10 CFR 50.55a(a)(3)(l), the proposed alternative must be shown to provide an acceptable level of quality and safety, i.e., essentially be equivalent to the original requirement in terms of quality and safety.
Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original
requirement results in a hardship or unusual difficultywithout a compensating increase in the level of quality and safety.
Examples of hardship and/or unusual difficultyinclude, but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examination, and development of sophisticated tooling that would result in only minimal increases in examination coverage.
A licensee may also submit a request for relief from ASME Code requirements.
In accordance with 10 CFR 50.55a(g)(5)(iii), ifa licensee determines that conformance with certain Code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in f50.4, information to support that determination.
When a licensee determines that an inservice inspection requirement is impractical, e.g., the system would have to be redesigned or a component would have to be replaced to enable inspection, the licensee should cite 10 CFR 50.55a(g)(5)(iii). The NRC may, giving due consideration to the burden placed on the licensee, impose an alternative examination requirement.
Provide appropriate references to the Code of Federal Regulations for the following requests:
Requests 1 through 7, which were submitted without reference to a specific paragraph of the Code of Federal Regulations.
Requests provided in the letter dated November 7, 1996, which are referred to as alternatives to Code requirements.
H.
In the November 7, 1996, submittal, the licensee stated that approval to use Code Case N-498-1 was provided by letter dated July 5, 1995. Was NRC authorization to use this Code Case for the third 10-year interval obtained?
Ifso, provide a copy of the NRC Safety Evaluation Report authorizing the use of Code Case NP98-1 for the third 10-year ISI interval. Ifnot, a new request for authorization must be submitted for the third 10-year ISI interval.
I.
ASME Section XI, paragraph IWB-2420 states that the sequence of component examinations established during the first interval shall be repeated during each successive inspection interval to the extent practical.
In the NRC RAI, the licensee was requested to provide a,detailed technical discussion regarding why the successive examination requirement could not be met.
In the September 10, 1996, submittal, the licensee stated that the requirements of IWB-2420 were met to the extent practical and provided a list of welds that did not meet this requirement.
A majority of the welds listed were shifted from the first period to the third period during the third interval. This deviation from IWB-2420 does not meet the intent of the Code and has not been adequately justified. To find this acceptable, a request for relief (or proposed alternative) must be submitted for staff review with the appropriate technical and regulatory basis.
J.
In accordance with 10 CFR 50.55a(g)(6)(ii)(A), all licensees must implement once, as part of the inservice inspection interval in effect on September 8, 1992, an augmented volumetric examination of the reactor pressure vessel (RPV) welds specified in Item B1.10 of Examination Category B-A of the 1989 Edition of the ASME Code,Section XI. Examination Category B-A, Items B1.11 and B1.12 require volumetric examination of essentially 100% of the RPV circumferential and longitudinal shell welds, as defined by, Figures IWB-2500-1 and -2, respectively.
Essentially 100%, as defined by 10 CFR 50.55a(g)(6)(ii)(A)(2), is greater than 90% of the examination volume of each weld. Licensees unable to satisfy the requirements of 10 CFR 50.55a(g)(6)(ii)(A) must propose an alternative to the examination requirements, which may be used when authorized by the Director of the Office of Nuclear Reactor Regulation.
Based on the table provided by the licensee in Request for Relief No. 1, there are six welds that could not be examined to the extent required by the Regulations.
Have the Regulations been satisfied by the submission of a proposed alternative'?
Ifso, provide the dates of the submittal(s) and the subsequent NRC Safety Evaluation Report.
Ifnot, a proposed alternative must be submitted and authorized before the limited examinations for the RPV shell welds can be evaluated for the third 10-year ISI interval.
K.
Request for Relief No. 1 regards limited examinations for six RPV shell welds and four RPV nozzle-to-vessel welds for Unit 1, and four shell welds and four nozzle-to-vessel welds in Unit 2. A note with the Unit 2 table states that coverage estimates are based on the Unit 1 10-year ISI examination results.
Considering that Unit 2 is in the third 10-year interval, actual coverage information from previous examinations should be available and provided.
In addition, the coverage obtained appears low for some of the welds and has not been adequately justified. Provide a detailed technical discussion describing the limitations and the coverage obtained.
The schedule for timely completion of this review requires that the licensee provide, by the requested date, the above requested information and/or clarification regarding the Donald C.
Cook Nuclear Plant, Units 1 and 2, Third Ten Year Inservice Inspection Plan, Revision 0.