ML022280337
| ML022280337 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/09/2002 |
| From: | Myers L FirstEnergy Nuclear Operating Co |
| To: | Dyer J NRC/RGN-III |
| References | |
| 1-1281 | |
| Download: ML022280337 (21) | |
Text
Davis-B esse Nuclear Power Station 5501 North State Route 2 Oak Harbor, Ohio 43449-9760 Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 August 9, 2002 Mr. James E. Dyer, Administrator United States Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, IL 60532-4351
Subject:
Replacement of the Reactor Pressure Vessel Head at the Davis-Besse Nuclear Power Station Ladies and Gentlemen:
The purpose of this letter is to provide the Nuclear Regulatory Commission (NRC) with information regarding the FirstEnergy Nuclear Operating Company (FENOC) plans to replace the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS) reactor pressure vessel (RPV) head. On April 25, 2002, FENOC submitted to the NRC letter Serial Number 1-1271 that provided details on repairing the existing degraded RPV head. As the NRC staff was aware, a parallel FENOC effort to the repair plan had been underway since March 2002, evaluating the replacement of the RPV head. Initially, the repair plan was considered the most appropriate course of action. However, as additional information has become available, replacement of the RPV head has become the preferred plan over repairing the existing RPV head.
Recognizing the potential decision to replace the RPV head, the NRC issued a revised Confirmatory Action Letter (CAL) No. 3-02-001A on May 15, 2002, adding a statement to Action Item 4 to address the replacement of the RPV head in lieu of a repair or modification to the existing head. As discussed below, FENOC has submitted three 10 CFR 50.55a requests for alternatives to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) requirements for the replacement head.
!3
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 2 of 5 FENOC is proceeding with plans to replace the existing RPV head at the DBNPS with a RPV head previously designated for use at the canceled Midland Plant. Similar to the DBNPS, the Midland Plant was a 177-fuel assembly Babcock & Wilcox Company (now Framatome-ANP) design. These plans to replace the existing DBNPS RPV head with the never-used Midland RPV head were presented to the NRC at a public meeting on June 4, 2002.
The Midland RPV head is being purchased from Framatome-ANP (FRA-ANP), who in turn has purchased the head from Consumers Energy, the owner of the Midland Plant.
The Midland RPV head is an ASME Code Section III Class A component, certified with an ASME Code N-stamp. FRA-ANP is providing FENOC with the required documentation, supplemental examinations, analyses and ASME Code reconciliation necessary to ensure the original ASME Code N-Stamp documentation remains valid, and that the Midland RPV head complies with appropriate NRC rules and industry requirements. ASME Code related records for the Midland RPV head are located at the Framatome-ANP offices in Lynchburg, Virginia, and at the DBNPS site.
FRA-ANP activities will be governed by their safety-related Quality Assurance Program, including 10 CFR Part 21. The procurement of the RPV head by FRA-ANP from Consumers Energy is also subject to Part 21. In addition, the Authorized Nuclear Inservice Inspector (ANil), as described in Note 1 to Enclosure 1 of this letter, will be involved in various activities related to acceptance, installation and modification of the Midland RPV head.
As discussed in Enclosure 1 to this letter, licensing action requests RR-A26 and RR-A27 (reference: letter Serial Number 2797, dated August 1, 2002) have been submitted pursuant to 10 CFR 50.55a to address the unavailability of the original radiographic film and reader's sheets for the replacement head-to-flange weld and control rod drive nozzle to-flange welds.
Like the DBNPS RPV head, the Midland RPV head was manufactured to the ASME Code,Section III, 1968 Edition, Summer 1968 Addenda. Following its manufacture, the Midland RPV head was hydrostatically tested at 3125 psig per ASME Code requirements.
The DBNPS service structure will be mounted on the Midland service structure support skirt. Inspection ports have been installed on the Midland support skirt to facilitate future RPV head inspections. In addition, minor differences in the Midland RPV head O-ring grooves will require new O-rings with a slightly smaller diameter to be procured and installed. Minor machining of the vessel-to-head keyway surfaces will also be performed for proper fit.
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 3 of 5 The existing DBNPS control rod drive mechanisms (CRDM) will be reused on the Midland RPV head. With the use of the Midland RPV head, modifications to the position locations of the CRDMs is not expected to be required. A modification to the CRDM flange index pins will be performed to provide for proper mating of the CRDM flange joint with the DBNPS CRDMs. A modification will also be performed to the CRDM split nut rings to provide ease of maintenance and to improve leak tight integrity of the flanged joint. This split nut ring modification had been previously performed on the DBNPS split nut rings. The changes discussed above and other changes are minor. They do not involve any change in the DBNPS Operating License Technical Specifications, and do not require a license amendment under 10 CFR 50.59.
Following cessation of construction at Midland, the Midland RPV head was left in an environment that was not subject to a quality assurance program under Appendix B to 10 CFR Part 50. This fact has been identified as a nonconformance, and is being resolved in accordance with the corrective action program of FRA-ANP. The examinations discussed below will be used to resolve this nonconformance and ensure the RPV can perform its design function.
Examinations to supplement the ASME Code Data Packages include visual examinations, radiograph technique (RT) examination of the head-to-flange weld, RT and liquid penetrant technique (PT) examination of the CRDM flange-to-nozzle welds and PT of the CRDM nozzle J-groove welds. Pre-service examinations in accordance with ASME Code Section XI requirements will be completed and include magnetic particle examination (MT) of the head-to-flange weld, ultrasonic examination (UT) of the head-to-flange weld, and PT of the peripheral CRDM flange-to-nozzle welds. Additional non-destructive examinations include chemical smears, CRDM nozzle baseline UT and eddy current testing (EC) of the CRDM nozzles. A listing of the documentation included in the ASME Code Section III (construction) and Section XI (pre-service inspection) data packages is included as Enclosure 2.
The existing DBNPS reactor vessel closure studs, nuts and washers will be used to install the replacement RPV head. Each refueling outage 12 of the 60 existing DBNPS reactor vessel closure studs, nuts and washers are examined in accordance with the DBN PS Inservice Inspection Program to ensure their acceptability for use. This results in 100%
of the closure studs, nuts and washers being inspected during a 10-year period. These inspections include UT and MT of the closure studs, and visual inspection (VT-1) of the nuts and washers. In addition, an evaluation will be performed by FRA-ANP to verify the design acceptability to use the existing DBNPS reactor vessel closure fasteners with the replacement Midland RPV head.
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 4 of 5 to this letter provides a discussion of implementation of the 1995 Edition with 1996 Addenda of the ASME Code,Section XI, IWA-4000, Repair/Replacement Activities, which governs the replacement of the RPV head at the DBNPS, along with details regarding the involvement of the ANII.
Following the completion of the installation of the replacement RPV head, the Reactor Coolant System will be filled and vented, and a visual inspection performed for leakage.
System temperature will be less than 200 degrees F. The plant will then be brought to normal operating temperature and pressure (approximately 2155 psig) using Reactor Coolant Pump heat, and a second visual inspection performed for leakage. Prior to reactor restart, the safety and regulating control rod drop times will be measured pursuant to Technical Specification 3.1.3.4, "Reactivity Control Systems - Rod Drop Time".
The DBNPS Containment Vessel and Shield Building will require a temporary access opening in order to remove the existing RPV head and install the replacement RPV head.
The current plan is to remove the existing DBNPS RPV head and temporarily store it on site until it can be properly disposed of at a licensed disposal facility. The temporary access opening in the Containment Vessel and Shield Building will be restored to design specifications and regulatory requirements. After restoration of the Containment Vessel, a 10 CFR Part 50, Appendix J, Type A Integrated Leak Rate Test will be performed.
Regarding related licensing action requests previously submitted to the NRC, FENOC has, under separate letters (letter Serial Number 2793 dated June 14, 2002, letter Serial Number 2794 dated June 14, 2002 and letter Serial Number 1-1276 dated June 14, 2002) requested the suspension of the current licensing action requests (repair plan and 10 CFR 50.55a approvals) for the repair of the existing RPV head.
As requested by the NRC, the Inservice Inspection Program for the Third Ten-Year Interval (letter Serial Number 2672 dated September 19, 2000, currently under review by the NRC) has been reviewed with regards to changes needed for use of the Midland RPV head. In particular, 10CFR50.55a requests RR-A8 (examination of the reactor vessel flange-to-shell circumferential weld (weld number RC-RPV-WR-19) using the Performance Demonstration Initiative protocol) and RR-A12 (examination schedule for the reactor vessel shell-to-flange circumferential weld (weld number RC-RPV-WR-19))
have been reviewed and FENOC has determined these remain appropriate with regards to the use of the replacement RPV head. FENOC continues to request NRC approval of these 10 CFR 50.55a requests. A revision to existing 10 CFR 50.55a request RR-A2 (reactor vessel head-to-flange weld (weld number WH-7)) was submitted under letter Serial Number 2798, dated August 1, 2002, to reflect the Midland RPV head.
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 5 of 5 If you have any questions or require additional information at this time, please contact Mr. Patrick J. McCloskey, Manager - Regulatory Affairs, at (419) 321-8450.
Very truly yours, Lew W. Myers Chief Operating Officer FirstEnergy Nuclear Operating Company Enclosures cc:
USNRC Document Control Desk D.V. Pickett, DB-1 NRC/NRR Project Manager C.S. Thomas, DB-1 Senior Resident Inspector Utility Radiological Safety Board
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 1 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda IWA-4100 GENERAL REQUIREMENTS IWA-4110 SCOPE IWA-41 10(a)
The requirements of this Article apply The requirements of IWA-4000 will be applied to regardless of the reason for the the installation of the Midland RPV head.
repair/replacement activity or the method that detected the condition.
IWA-4 110(b)
This Article provides requirements for The requirements of IWA-4000 will be applied to repair/replacement activities associated the installation, preservice examination, and with pressure retaining components and pressure testing of the Midland RPV head.
their supports.
These requirements are applicable to procurement, design, installation, examination, and pressure testing of items within the scope of this Division.
IWA-41 10 (c)
This Article provides requirements for Not Applicable repair/replacement activities performed on concrete containments....
IWA-41 10(d)
This Article does not provide The requirements of IWA-4000 are applicable to requirements for addition of complete the installation of the Midland RPV head as the systems.
RPV head does not represent a complete system.
IWA-4120 APPLICABILITY IWA-4120(a)
The requirements of this Article apply to The Davis-Besse RPV head is Code Class 1.
items classified by the Owner in accordance with IWA-1400(a) as Code Class 1, 2, 3, MC, or CC, and associated supports.
IWA-4120(b)
The requirements of this Article do not The exemptions of the IWA-4120(b) are not apply to the following, except as provided applicable to the RPV head.
in IWA-4120(c) through (g).
IWA-4120(c)
When repair/replacement activities are The exemptions of the IWA-4120(b) are not performed on items identified in IWA-applicable to the RPV head.
4120(b)....
IWA-4120(d)
If items in IWA-4120(b)(6) are replaced The exemptions of the IWA-4120(b) are not applicable to the RPV head.
IWA-4120(e)
If items in IWA-4120(b) require welding The exemptions of the IWA-4120(b) are not
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 2 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda S....
applicable to the RPV head.
IWA-4120(f)
Applicable Construction Code The exemptions of the IWA-4120(b) are not requirements, such as.
shall be met for applicable to the RPV head.
items identified in IWA-4120(b).
IWA-4120(g)
Appendix J provides guidance in The requirements of IWA-4000 are applicable to determining applicability of this Article.
the installation of the Midland RPV head.
IWA-4130 ALTERNATIVE REQUIREMENTS IWA-4131 Small Items This paragraph is not applicable to the installation of the Midland RPV head.
IWA-4132 Items Rotated From Stock This paragraph is not applicable to the installation of the Midland RPV head.
IWA-4140 RESPONSIBILITIES IWA-4141 Owner's Responsibility It is the responsibility of the Owner to provide or cause to be provided the following:
IWA-4141(a)
Repair/Replacement Program and Plans The Midland RPV head will be installed on the required by IWA-4150.
Davis-Besse Reactor Vessel using the Davis-Besse and Framatome ANP Repair/Replacement Programs and Plans which meet the requirements of IWA-4150.
IWA-4141(b)
Specification requirements for FirstEnergy Purchase Order 7094336 requests repair/replacement activities.
Framatome ANP to procure and certify that the Midland RPV head meets the requirements of ASME Section III, Class A, 1968 Edition, Summer 1968 Addenda.
IWA-4142 Repair/Replacement Organization's Quality Assurance Program IWA-4142(a)
The organization that performs repair/replacement activities shall establish a Quality Assurance Program for control of their activities in accordance with the Repair/Replacement
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 3 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda Program and Plans. The Quality Assurance Program shall comply with either of the following:
IWA-4142(a)(1)
IWA-1400(n), when the Owner is the The FENOC Quality Assurance Program and the Repair/Replacement Organization.
Davis-Besse ASME Quality Assurance Manual (Davis-Besse Nuclear Repair (NR) Program) will be used during installation of the Midland RPV head. These programs are in accordance with IWA-1400(n).
IWA-4142(a)(2)
When the Repair/Replacement The procurement and certification that the Midland Organization is other than the owner, the RPV head meets the requirements of ASME Repair/Replacement Organization'sSection III, Class A, 1968 Edition, Summer 1968 Quality Assurance Program shall be Addenda are being performed in accordance with documented and shall comply with the the Framatome ANP Safety Related QA Program applicable quality assurance program which is in compliance with 10CFR50 Appendix criteria of 10CFR50 Appendix B B.
supplemented as necessary to be consistent with the Owner's Quality Supplemental NDE is being performed in Assurance Program; NQA-1, Parts II and accordance with the Framatome ANP Safety III, Basic Requirements and Supplements; Related QA Program.
or NCA-4000. The Repair/Replacement Organization's Quality Assurance Replacement of the Davis-Besse RPV head with Program shall be documented in the Midland RPV head as well as any sufficient detail for the Owner to assure modifications to the pressure retaining portions of that the requirements of this Article will the Midland RPV head are being performed in be met for the activities to be performed.
accordance with the Framatome ANP Nuclear The program shall be reviewed and Repair (NR) Program.
accepted by the Owner.
Both the Framatome ANP Safety Related QA Program and the Framatome ANP NR Program have'been reviewed and accepted by FENOC.
IWA-4142(b)
When the performance of As noted above the Framatome ANP Safety repair/replacement activities is split Related Quality Assurance Program will be used to between the Owner and a procure, perform supplemental NDE, and perform Repair/Replacement Organization, each any required modifications to the non-pressure organization's Quality Assurance retaining portions of the Midland RPV head. The Program shall comply with IWA-Framatome ANP NR Program will be used to 4142(a)(1) or (a)(2) for their respective install and perform any required modifications to activities. The Owner shall be the pressure retaining portions of the Midland RPV responsible for establishing interfaces and head.
for assuring that the requirements of this
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 4 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda Article are met by the combination of the An engineering work package will be prepared in two Quality Assurance Programs.
accordance with the FENOC QA Program and Davis-Besse NR Program to provide the engineering requirements related to installation of the Midland RPV head on the Davis-Besse Reactor Vessel.
IWA-4143 Stamping for Installation No Code Symbol Stamp will be applied following Application of the ASME NA Symbol installation of the Midland RPV head.
Stamp is neither required or prohibited for installation. When stamping is As noted above, the Framatome ANP NR and the performed it may be performed by either Davis-Besse NR Programs will be used during the of the following:
installation of the Midland RPV head. Framatome (a) the Owner, provided the Owner is in ANP holds National Board Certificate of possession of the appropriate Certificate Authorization NR-64. Davis-Besse holds National of Authorization; Board Certificate of Authorization NR-20.
(b) the Owner's designee, provided the designee is in possession of the appropriate Certificate of Authorization.
IWA-4150 REPAIR/REPLACEMENT PROGRAM AND PLAN IWA-4150(a)
Repair/replacement activities shall be The installation, including any modifications to the completed in accordance with the Midland RPV head will be performed in Repair/Replacement Program. The accordance with the Framatome ANP NR Program is a document or set of Program. The engineering work package for the documents that defines the managerial installation of the Midland RPV head will be and administrative control for completion performed under the FENOC QA Program Manual of the repair/replacement activities, and the Davis-Besse NR Program.
IWA-4150(b)
The Edition and Addenda of Section XI Davis-Besse is in its Third 10-Year Inservice used for the Repair/Replacement Program Inspection Interval. The Code Edition of ASME shall correspond with the Edition and Section XI applicable to this interval is the 1995 Addenda identified in the inservice Edition, through the 1996 Addenda. This same inspection program applicable to the Code Edition will be used for the installation and inspection interval. Alternatively,...
any modifications to the Midland RPV head.
IWA-4150(c)
As part of the Repair/Replacement The Repair/Replacement Plans will be documented Program, repair/replacement activities in the engineering and field work packages shall be accomplished in accordance with prepared for the installation of the Midland RPV Repair/Replacement Plans that include head. An engineering work package will be the essential requirements for completion prepared in accordance with the Davis-Besse NR of the repair/replacement activities. A Program to document the technical requirements
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 5 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda Repair/Replacement Plan shall identify for the installation of the Midland RPV head.
the following:......
Framatome ANP will provide engineering expertise in the development of the engineering work package. The engineering and field work packages will address the activities addressed in IWA-4150(c).
IWA-4150(d)
The Repair/Replacement Program, Plans, The documents will be available for review by the and evaluations required by IWA-4160 NRC and State of Ohio.
shall be subject to review by enforcement and regulatory authorities having jurisdiction at the plant site.
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 6 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda IWA-4160 VERIFICATION OF ACCEPTABILITY If an item does not satisfy the requirements of this Division, the Owner The Verification of Acceptability will be included shall determine the cause of in the engineering work package for the unacceptability. Prior to returning the installation, including modifications of the item to service the Owner shall evaluate Midland RPV head.
the suitability of the item subjected to the repair/replacement activity. If the requirements for the original item are determined to be deficient, appropriate corrective provisions shall be included in the Owner's Requirements and Design Specification, as applicable. Any such corrective provisions shall be consistent with the Construction Code or Section III, in effect at that time. The report of the evaluation shall be made part of the record (IWA-4180).
IWA-4170 INSPECTION The services of an Authorized Inspection The Authorized Nuclear Inservice Inspector Agency shall be used. The Owner shall (ANII) reviews all Framatome ANP process notify the Authorized Inspection Agency travelers, including revisions thereto, to establish prior to starting a repair/replacement hold/witness points.
activity and keep the Inspector informed of progress so that necessary inspections To date, the site ANII has been, and will be may be performed.
actively involved in the acceptance, installation, and modifications to the Midland RPV head. Note 1 provides a listing of activities with which the ANII has been or will be involved with.
IWA-4180 Documentation IWA-4180(a)
The reports and records required by IWA-The records, as applicable to the installation and 6000 shall be completed for all modification of the Midland RPV head on the repair/replacement activities.
Davis-Besse Reactor Vessel will be retained in the Davis-Besse Records Management System. The data package demonstrating compliance with the original Construction Code will be compiled by Framatome ANP and retained in the Davis-Besse Records Management System. (See Note 2)
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 7 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda The replacement of the Davis-Besse RPV head will be included in the summary report required by IWA-6230.
IWA-4180(b)
The following reports and records shall, The following records will be included in the to the extent required by the Construction engineering work package for the installation of Code, Owner's Requirements, and this the Midland RPV head on the Davis-Besse Reactor Article, be maintained by the Owner, as Vessel.
applicable:
- 1. Report of Reconciliation (1) Design Specification....
- 2.
Verification of Acceptability (IWA-4160)
- 3.
Applicability and disposition of Midland RPV head nonconformances to Davis-Besse
- 4.
Updates, as necessary, to the Davis-Besse Design Report, Design Drawings, and Design Specification A Midland RPV head QA Documentation Package with Manufacturer's Data Report, Material Certifications, and fabrication records will be furnished.
IWA-4180(c)
Revisions or updates to existing reports, Updates, as necessary, to the Davis-Besse Design records, and specifications shall be Report, Design Drawings, and Design traceable to and from the original record Specification will be included in the engineering or report to provide a record of the work package. These documents will be updated current status of the item. The review and after installation of the Midland RPV head during certification requirements for these closeout of the engineering work request.
revisions or updates shall be in accordance with the Owners' Framatome ANP will certify that the Midland RPV Requirements and the Construction Code.
head meets the requirements of ASME Section III, Class A, 1968 Edition, Summer 1968 Addenda.
IWA-4180(d)
Form NIS-2 shall be completed for all Forni NIS-2 will be prepared to document the repair/replacement activities repair/replacement activities.
IWA-4200 ITEMS FOR REPAIR/REPLACEMENT ACTIVITIES IWA-4210 GENERAL REQUIREMENTS In course of preparation.
IWA-4220 CODE APPLICABILITY
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 8 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda IWA-4221 Construction Code and Owner's Requirements IWA-4221(a)
An item to be used for repair/replacement The Davis-Besse RPV head was fabricated as a activities shall meet the Owner's Class A vessel to the 1968 Edition, Summer 1968 Requirements and the applicable Addenda of ASME Section III. The Midland RPV Construction Code to which the original head was also fabricated as a Class A vessel to the item was constructed, except as provided 1968 Edition, Summer 1968 Addenda of ASME in IWA-4221(b) and (c).
Section III. RR-A26 and RR-A27 have been submitted to address the unavailability of the original radiographic film and reader's sheets for the replacement RPV head-to-flange weld and CRDM nozzle-to-flange welds.
IWA-4221(b)
The item may meet all or portions of the This paragraph is not applicable. Both the Davis requirements of different Editions and Besse and Midland RPV head's were fabricated to Addenda of the Construction Code....
the same Code Editions and Addenda.
IWA-4221(c)
Revised Owner's Requirements may be The Midland RPV head Design Specification will used provided they are reconciled in be reconciled with the Davis-Besse RPV head accordance with the IWA-4222. A Design Specification in accordance with IWA Report of Reconciliation shall be 4222. The Report of Reconciliation will be prepared.
included in the engineering work package.
IWA-4222 Reconciliation of Code and Owner's Requirements IWA-4222(a)
Code Requirements and Owner's Requirements may be technical or administrative IWA-4222(a)(1)
Only technical requirements that could The Midland RPV head will be reconciled with the affect materials, design, fabrication, or Davis-Besse RPV head. This ývill include:
examination, and affect the pressure
- 1. Reviews and evaluations to confirm that boundary, or core support or component materials, fabrication, and examination support function, need be reconciled.
techniques are consistent between the two RPV heads
- 2.
Reviewing any Midland RPV head non conformances for applicability to Davis-Besse and dispositioning these non-conformances for Davis-Besse
- 3.
Comparing the Midland and Davis-Besse Design Specifications, Design Reports, and
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 9 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda Drawings to identify and resolve any differences.
- 4.
Reconciliation of all dimensional differences between the Midland RPV head and the Davis-Besse RPV head.
The results of the reconciliation will be included in the engineering work package. Any modifications to the Midland RPV head will be documented in Framatome ANP modification packages and implemented via either the Framatome Safety Related QA Program (for non-pressure boundary modifications) or the Framatome NR Program (for pressure boundary modifications).
IWA-4222(a)(2)
Administrative requirements, i.e. those See Note 2.
that do not affect the pressure boundary or core support or component support function, need not be reconciled.
Examples of such requirements include quality assurance, certification, Code Symbol Stamping, Data Reports, and Authorized Inspection.
IWA-4222(b)
The administrative requirements of either Both the Midland RPV head and the Davis-Besse the Construction Code of the item being RPV head were fabricated to the 1968 Edition, replaced or the Construction Code of the Summer 1968 of ASME Section III. The signature item to be used for replacement shall be on the Manufacturer's Data Report (Form N-1A) met.
by B&W and the Authorized Nuclear Inspector certify that the Code Requirements, including the administrative requirements have been met.
IWA-4223 Reconciliation of Components IWA-4223(a)
Reconciliation of later Editions and This paragraph is not applicabl,. Both the Davis Addenda....
Besse and Midland RPV heads were fabricated to the same Code Editions and Addenda.
IWA-4223(b)
An earlier Edition and Addenda....
This paragraph is not applicable. Both the Davis Besse and Midland RPV heads were fabricated to the same Code Editions and Addenda.
IWA-4224 Reconciliation of Material This paragraph is not applicable. The RPV head is considered a piece of the component, Reactor
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 10 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda Vessel.
IWA-4225 Reconciliation of Parts, This paragraph is not applicable. The RPV head is Appurtenances, and Piping considered a piece of the component, Reactor Subassemblies Vessel.
IWA-4226 Reconciliation of Design Requirements IWA-4226.1 Design to All Requirements of a Later This paragraph is not applicable. Both the Davis Edition or Addenda of the Besse and Midland RPV heads were designed to Construction Code.
the same Code Editions and Addenda.
IWA-4226.2 Design to Portions of the Requirements This paragraph is not applicable. Both the Davis of a Later Edition or Addenda of the Besse and Midland RPV heads were designed to Construction Code.
the same Code Editions and Addenda.
IWA-4300 DESIGN IWA-4310 GENERAL REQUIREMENTS IWA-4311 Material, Design, or Configuration Changes When a change is made to the design or The installation of the Midland RPV head, configuration of an item or system, including any modifications are being reconciled in including material substitution, the accordance with IWA-4220. Included in this change shall meet the following reconciliation is a review to determine if analyses requirements:
need revised.
IWA-4312 Rerating The provisions of this paragraph shall This paragraph is not applicable. Rerating is not apply for rerating....
being performed.
IWA-4320 Piping This paragraph is not applicable.
IWA-4400 WELDING, BRAZING, METAL No welding or brazing activities are planned on the REMOVAL, AND INSTALLATION pressure retaining portions of the Midland RPV head. Metal removal, when necessary, will be conducted in accordance with the Framatome ANP NR Program.
IWA-4500 EXAMINATION AND TEST IWA-4510 GENERAL REQUIREMENTS (In course of preparation)
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 11 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda IWA-4520 EXAMINATION IWA-4520(a)
Welding or brazing areas and welded No welding or brazing activities are planned on the joints made for installation pressure retaining portions of the Midland RPV head nor its installation on the Reactor Vessel.
IWA-4520(b)
Welding, brazing, or metal removal areas No welding, brazing, or metal removal activities to associated with flaw correction....
correct flaws are planned. Should any such activities be required on the pressure retaining portions of the Midland RPV head, they will be performed in accordance with the Framatome ANP NR Program.
IWA-4520(c)
These examinations may be performed No examinations related to this section are concurrently with the preservice planned.
inspections required by IWA-4530.
IWA-4530 PRESERVICE INSPECTION AND TESTING IWA-4530(a)
When portions of items requiring The following preservice examinations are being preservice or inservice inspection are performed on the Midland RPV head.
affected by repair/replacement activities,
or for items being installed, including B 1.40). The UT examination of this weld is welded joints made for installation of limited due to the lifting lugs, directional items, preservice inspections shall be arrow, and the configuration of the weld.
performed in accordance with IWB-2200, Request RR-A2 is being revised to reflect this IWC-2200, IWD-2200, IWE-2200, IWF-limitation..
2200, or IWL-2200 prior to return of the
- 2.
MT of the head-to-flange weld (Code Item system to service. The preservice No. B 1.40).
inspection may be performed either prior
- 3.
PT of the peripheral CRDM nozzle body-to to or following the pressure test required flange welds (Code Item No. 14.10).
by IWA-4540.
IWA-4530(b)
Prior to returning a valve to service....
This paragraph is not applicable.
IWA-4530(c)
During the first inservice test performed This paragraph is not applicable.
after a pump is put into service....
IWA-4530(d)
For repair/replacement activities on a This paragraph is not applicable.
snubber....
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 12 of 13 ARTICLE IWA-4000 REPAIR/REPLACEMENT ACTIVITES Code Paragraph Code Requirement - ASME Section Discussion XI, 1995 Edition through the 1996 Addenda IWA-4540 PRESSURE TESTING OF CLASS 1, 2, AND 3 ITEMS IWA-4540(a)
After welding on a pressure retaining The Midland RPV head was hydrostatic tested to boundary or installation of an item by 3125 psig after fabrication in accordance with welding or brazing, a system hydrostatic ASME Code requirements. No welding or brazing test shall be performed in accordance activities are planned on the pressure retaining with IWA-5000.
portions of the Midland RPV head nor its installation on the Reactor Vessel. Therefore additional hydrostatic testing is not required.
IWA-4540(b)
The following may be exempted from the As noted in IWA-4540(a), additional hydrostatic system hydrostatic tests:
testing is not required.
IWA-4540(c)
Mechanical joints made in installation of A system leakage test as required by IWA-521 1(a) pressure retaining items shall be pressure will be performed while in Mode 3 at full Reactor tested in accordance with IWA-521 1(a).
Coolant System temperature and pressure.
Mechanical joints for component connections, piping, tubing (except heat exchanger tubing), valves, and fittings, NPS-1 and smaller, are exempt from the pressure test.
IWA-4550 CLASS MC AND METALLIC This paragraph is not applicable.
PORTIONS OF CLASS CC CONTAINMENTS IWA-4600 ALTERNATIVE WELDING No welding activities are planned on the pressure REQUIREMENTS retaining portions of the Midland RPV head.
IWA-4700 HEAT EXCHANGER TUBING This paragraph is not applicable.
Note 1: The ANII has been or will be involved in the following activities related to acceptance, installation, and modification of the Midland RPV head.
- 2.
Witnessing RPV flange-to-dome weld radiography, including review and acceptance of the radiographs.
- 3.
Witnessing CRDM flange-to-nozzle welds (69 welds) radiography. Also, reviewing and accepting these radiographs.
- 4.
Review and acceptance of the PT exams of all 69 J-groove welds.
- 5.
Review and acceptance of the PT exams of all 69 CRDM flange-to-nozzle welds.
- 6.
Review and acceptance of the PT exams of the clad inspection sampling areas.
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 13 of 13
- 7.
Review and acceptance of the Framatome ANP Process Traveler for the Modification and Preparation of Midland RPV head. This step includes the establishment of ANII Hold Points associated with traveler NDE sequences.
- 8.
Witness, review and accept all future revisions to the Process Traveler sequences.
- 9.
Review and acceptance of NDE Procedures used on the Midland Head Project.
- 10. Review and acceptance of NDE Personnel Certifications for NDE examiners working at Midland or Davis-Besse.
- 11. Final Review and Closeout of the Framatome ANP Process Traveler when activities are completed.
- 12. Final review and acceptance of Framatome ANP "NR-1" Form and Certificate of Conformance.
Note 2: The Midland RPV head is an ASME Section III Code Stamped Class A Vessel meeting the requirements of the 1968 Edition, Summer 1968 Addenda of ASME Section III. This is attested to by the Manufacturer's Data Report for Nuclear Vessels (Form N-1 A) for the Midland Reactor Vessel, of which the RPV head is a piece. This Manufacturer's Data Report is signed by both Babcock & Wilcox (B&W) and the Authorized Nuclear Inspector indicating that all 1968 Edition, Summer 1968 Addenda ASME Section III design, fabrication, and examination requirements have been met. It should be noted that the original radiographic film and reader's sheets for the Midland RPV head center disc-to-flange weld (also called head-to-flange weld) and the CRDM nozzle body-to-flange welds are not available. However, a log indicating the performance and acceptance of the radiographs is available. This, coupled with the signed Manufacturer's Data Report signifying compliance with ASME Section III, provides assurance that the radiographic examination of the RPV head head-to-flange weld and the CRDM nozzle body-to-flange welds were performed and accepted. Request RR-A26 was submitted to address the unavailability of the original radiographic film and reader's sheets for the replacement RPV head head-to-flange weld.
Upon cessation of construction activities at Midland, the Midland RPV head was left in an environment not subject to a 10 CFR 50, Appendix B quality assurance program. To assess the health of the Midland RPV head, FENOC is performing an extensive sequence of inspections and nondestructive examinations. These inspections include:
- 1. A visual examination of the entire RPV head to identify any signs of degradation or evidence of welding while the RPV head was in storage.
- 2.
RT of the center disc-to-flange weld. RT of this weld is limited by the three lifting lugs that were installed after the construction radiograph. These lugs limited the examination to approximately 95%
of the weld surface.
- 3.
RT and PT of the CRDM flange-to-nozzle welds.
- 4.
PT of the CRDM clad inspection sampling areas.
- 5.
PT of the CRDM nozzle to RPV head J-groove welds.
- 6.
EC of the CRDM nozzle internal surfaces.
- 7.
UT of the CRDM nozzles to include the area up to and including the portion extending through the RPV head base material.
- 8.
UT and MT of the RPV head head-to-flange weld to satisfy the preservice examination requirements
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 1 of 2 MIDLAND REPLACEMENT REACTOR PRESSURE VESSEL CLOSURE HEAD ASME B&PV CODE SECTION III DATA PACKAGE
- 1. Quality Assurance Certification Records
- a. B&W Manufactured Equipment Supplier Certificate of Conformance
- b. Form N-lA Manufacturers' Data Report for Nuclear Vessels
- c.
Section III Code Data Stamp Rubbing
- d. Certification of Meeting Design Specifications and ASME Code Section III, 1968 Edition, Summer 1968 Addenda
- 2. Contract Variations and Original Disposition*
- 3. Weld Numbers and Records of Radiographic and Surface Examinations (Note: Radiographic film is not available.)
- 4. Record of Section III Hydrostatic Test
- 5. As-Built Drawings of Closure Head to Satisfy Equipment Specification
- 6. List of Technical Procedures
- 7. List of Materials, including Post Weld Heat Treat Times
- 8. Certified Material Test Reports
- a. Closure Head Flange
- b. Closure Head (Center Disc)
- c. CRDM Nozzle Body
- e. CRDM Split Nut Rings
- f. Closure Head Lift Lug
- g. Service Structure Segments
- 9. Weld Material Records
- a. CRDM J-Groove Buttering
- b. CRDM J-Grooves
- The variations which affected the Midland closure head will be reconciled to the Davis Besse design requirements in the Section XI reconciliation phase. These variations were acceptable for Midland and the Davis-Besse requirements are similar to the Midland requirements.
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 2 of 2 MIDLAND REPLACEMENT REACTOR PRESSURE VESSEL CLOSURE HEAD ASME B&PV CODE SECTION XI DATA PACKAGE
- 1. Framatome ANP Certificate of Compliance,
- 2. Framatome ANP NR-1 Form for Section XI Modifications
- 3. Midland Closure Head Dedication Plan
- 4. Applicable Documents Listing including List of Non-Destructive Examination Procedures
- 5. Signature Log
- 6. Completed Framatome ANP Process Traveler for Modification and Preparation of the Midland RVCH which includes the following records:
- a. Liquid Penetrant (PT) Examination Records of all CRDM J-Groove Welds (Weld WH-26)*
- c. PT Examination Records of Cladding Inspection Sampling Areas*
- d. PT* and Radiographic* (RT) Examination Records of all 69 CRDM Flange-to Nozzle Welds (Weld No. WH-9)
Note: The PT examination of the Peripheral CRDM Flange-to-Nozzle Welds satisfied the Section Xl Preservice Examination Requirements
WH-7) to satisfy Section XI Preservice Examination Requirements
- h. Modification of CRDM Index Pin Hole Plugs
- i.
Modification of the CRDM Nut Rings
- j.
Machining of keyways
- k. Eddy Current (EC) Records of all 69 CRDM Nozzles*
- 1.
100% Visual Inspection of Closure Head*
- 7. Nonconformance Reports
- Supplemental examination
Docket Number 50-346 License Number NPF-3 Serial Number 1-1281 Page 1 of 1 COMMITMENT LIST The following list identifies those actions committed to by the Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by the DBNPS. They are described only for information and are not regulatory commitments. Please notify the Manager - Regulatory Affairs (419-321-8450) at the DBNPS of any questions regarding this document or associated regulatory commitments.
COMMITMENTS The Authorized Nuclear Inservice Inspector (ANII),
as described in Note 1 to Enclosure 1, will be involved in various activities related to acceptance, installation, and modification of the Midland RPV head.
An evaluation will be performed by Framatome-ANP to verify the design acceptability to use the existing DBNPS reactor vessel closure fasteners with the replacement Midland RPV head.
After restoration of the Containment Vessel, a 10 CFR Part 50, Appendix J, Type A Integrated Leak Rate Test will be performed.
DUE DATE Ongoing Prior to restart Prior to restart