LIC-03-0019, Answer to Commission Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors

Answer to Commission Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors

ML030640403
Person / Time
Site:	Fort Calhoun
Issue date:	03/03/2003
From:	Ridenoure R Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-03-0019
Download: ML030640403 (4)

Text

Hippo OmahaPublic PowerDistnct 444 South 16th Street Mall Omaha NE 68102-2247 March 3, 2003 LIC-03-0019 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

References:

1. Docket No. 50-285

2. Letter from NRC (Samuel J. Collins) to OPPD (R. T. Ridenoure) dated February 11, 2003, Issuance of Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors (NRC-03-025)

SUBJECT:

Answer to Commission Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors Pursuant to the requirements of 10 CFR 2.202(a)(2), Omaha Public Power District (OPPD) hereby submits its answer to the Order establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors (hereinafter "Order") issued by the United States Nuclear Regulatory Commission (NRC) on February 11, 2003.

I declare under penalty of perjury that the foregoing is true and correct and copies of the answer were sent to the addressee and listed individuals. (Executed on March 3, 2003).

No commitments are made to the NRC in this letter. If you have additional questions, or require further information, please contact Dr. R. L. Jaworski at (402) 533-6833.

Attachment c: see attached Certificate of Service A, IC)ý Emplopnent with Equal Opportunity 4171

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

Omaha Public Power District ) Docket No. 50-285 Fort Calhoun Station Unit 1, DPR-40 )

)

LICENSEE'S ANSWER TO FEBRUARY 11, 2003 COMMISSION ORDER ESTABLISHING INTERIM INSPECTION REQUIREMENTS FOR REACTOR PRESSURE VESSEL HEADS AT PRESSURIZED WATER REACTORS On February 11, 2003, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an immediately effective order in the captioned matter entitled Order Modifying Licenses (Effective Immediately) ("Order") to, inter alia, Omaha Public Power District (OPPD). The Order stated that the discovery of leaks and nozzle cracking at the Davis-Besse Nuclear Power Station and other pressurized water reactor (PWR) plants has made clear the need for more effective inspections of RPV heads and associated penetration nozzles. The current RPV head inspection requirements require visual examination of the insulated surface or surrounding area for signs of leakage. Based on recent experience, current inspection requirements in the ASME Code and related NRC regulations do not provide adequate assurance that reactor coolant pressure boundary integrity will be maintained for all combinations of construction materials, operating conditions, and operating histories at PWRs and are not sufficient to reliably detect circumferential cracking of RPV head nozzles and corrosion of the RPV head. Revising the ASME Code and subsequently the NRC regulations will take several years. Licensees actions to date in response to the NRC bulletins have provided reasonable assurance of adequate protection of public health and safety for near term operating cycles, but cannot be relied upon to do so for

the entire interim period until NRC regulations are revised. Circumferential cracking of RPV head nozzles and corrosion of the RPV head pose a safety concern because of the possibility of a nozzle ejection or loss-of-coolant accident if the conditions are not detected and repaired.

Therefore, the NRC stated it was imposing requirements as set forth in the Order. The Order establishes interim requirements to ensure that licensees implement and maintain appropriate measures to inspect and, as necessary, repair RPV heads and associated penetration nozzles.

OPPD has responded to the substantive requirements of the Order by letter LIC-03-0018 dated March 3, 2003 in accordance with the provisions of 10 C.F.R. § 50.4, as directed by the Order.

In accordance with Section IV of the Order and 10 CFR 2.202, OPPD hereby submits its answer to the Order. OPPD consents to the Order and specifically does not request a hearing.

I declare under penalty of perjury that the foregoing is true and correct. (Executed on March 3, 2003).

Respectfully submitted,

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ))

Omaha Public Power District

)

Fort Calhoun Station Unit 1

) Docket No. 50-285 DPR-40

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of the ANSWER TO JANUARY 7, 2003, COMMISSION ORDER ESTABLISHING INTERIM INSPECTION REQUIREMENTS FOR REACTOR PRESSURE VESSEL HEADS AT PRESSURIZED WATER REACTORS in the captioned action have been served on the following by deposit in express mail service or fax, this 3rd day of March 2003. I declare under penalty of perjury that the foregoing is true and correct. (Executed on March 3, 2003).

Secretary Senior Resident Inspector - Fort Calhoun Office of the Secretary Station Unit 1 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission ATTN: Rulemakings and Adjudications Highway 75, 3 miles South of Blair, Staff Nebraska Washington, DC 20555-0001 Fort Calhoun, NE 68023 Director, Office of Nuclear Reactor U.S. Nuclear Regulatory Commission Regulation ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 (signed original and three copies)

Region Administrator - Region 4 Winston and Strawn U.S. Nuclear Regulatory Commission 1400 L Street, N. W.

611 Ryan Plaza Drive, Suite 400 Washington, DC 20005-3502 Arlington, TX 76011 (two copies)

Assistant General Counsel for Materials Litigation and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Manager, Nuclear Operations