ML033080003
| ML033080003 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/07/2004 |
| From: | Darrell Roberts NRC/NRR/DLPM/LPD1 |
| To: | Christian D Dominion Nuclear Connecticut |
| Nerses V, NRR//DLPM, 415-1484 | |
| References | |
| TAC MB6943 | |
| Download: ML033080003 (13) | |
Text
January 7, 2004 Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.
Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PLAN, REQUEST FOR RELIEF IR-2-27 FOR MILLSTONE POWER STATION, UNIT NO. 3 (TAC NO. MB6943)
Dear Mr. Christian:
By letter dated November 26, 2002, as supplemented July 1, 2003, Dominion Nuclear Connecticut, Inc. submitted to the U.S. Nuclear Regulatory Commission (NRC), Relief Request No. IR-2-27, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i), requesting approval of an alternative to the requirements of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code)Section XI. The alternative would allow the one-time use of a non-ASME Code Section III N-type certificate holder to perform fabrication activities at its facility while meeting the requirements of 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
Based upon the review of the information you provided, the NRC concluded that the proposed alternative provides reasonable assurance of structural integrity, and the NRC finds that removing the subassemblies from the Feedwater System and reworking the entire A and D Trains would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, your proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the life of the replacement. The NRC staffs Safety Evaluation is enclosed. If you have any questions, please contact the Project Manager, Victor Nerses at (301) 415-1484.
Sincerely,
/RA by REnnis for/
Darrell J. Roberts, Acting Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-423
Enclosure:
As stated cc w/encl: See next page
January 7, 2004 Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.
Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PLAN, REQUEST FOR RELIEF IR-2-27 FOR MILLSTONE POWER STATION, UNIT NO. 3 (TAC NO. MB6943)
Dear Mr. Christian:
By letter dated November 26, 2002, as supplemented July 1, 2003, Dominion Nuclear Connecticut, Inc. submitted to the U.S. Nuclear Regulatory Commission (NRC), Relief Request No. IR-2-27, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i), requesting approval of an alternative to the requirements of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code)Section XI. The alternative would allow the one-time use of a non-ASME Code Section III N-type certificate holder to perform fabrication activities at its facility while meeting the requirements of 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
Based upon the review of the information you provided, the NRC concluded that the proposed alternative provides reasonable assurance of structural integrity, and the NRC staff finds that removing the subassemblies from the Feedwater System and reworking the entire A and D Trains would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, your proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the life of the replacement. The NRC staffs Safety Evaluation is enclosed. If you have any questions, please contact the Project Manager, Victor Nerses at (301) 415-1484.
Sincerely,
/RA by REnnis for/
Darrell J. Roberts, Acting Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-423
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
PUBLIC CRaynor OGC BMcDermott, RGN-I PDI-2 Reading DRoberts ACRS EReichelt CHolden TChan GHill (2)
JJolicoeur ADAMS Accession Number: ML033080003
- see previous concurrence OFFICE PDI-2/PM PDI-2/LA EMCB/SC OGC**
PDI-2/SC(A)
NAME VNerses CRaynor TChan RHoefling REnnis for DRoberts DATE 01/06/04 01/05/04 01/06/04 12/12/03 01/07/04 OFFICIAL RECORD COPY
Millstone Power Station, Unit No. 3 cc:
Lillilan M. Cuoco, Esquire Senior Counsel Dominion Resources Services, Inc.
Rope Ferry Road Waterford, CT 06385 Edward L. Wilds, Jr., Ph.D.
Director, Division of Radiation Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 First Selectmen Town of Waterford 15 Rope Ferry Road Waterford, CT 06385 Mr. P. J. Parulis Manager - Nuclear Oversight Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Mr. W. R. Matthews Senior Vice President - Nuclear Operations Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Mr. John Markowicz Co-Chair Nuclear Energy Advisory Council 9 Susan Terrace Waterford, CT 06385 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terrys Plain Road Simsbury, CT 06070 Senior Resident Inspector Millstone Power Station c/o U.S. Nuclear Regulatory Commission P. O. Box 513 Niantic, CT 06357 Mr. G. D. Hicks Director - Nuclear Station Safety and Licensing Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Ms. Nancy Burton 147 Cross Highway Redding Ridge, CT 00870 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale Electric Company Moody Street P.O. Box 426 Ludlow, MA 01056 Mr. J. Alan Price Site Vice President Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Mr. Chris Funderburk Director, Nuclear Licensing and Operations Support Dominion Resources Services, Inc.
5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. David W. Dodson Licensing Supervisor Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385
Millstone Power Station, Unit No. 3 cc:
Mr. S. E. Scace Assistant to the Site Vice President Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Mr. M. J. Wilson Manager - Nuclear Training Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Mr. A. J. Jordan, Jr.
Director - Nuclear Engineering Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Mr. S. P. Sarver Director - Nuclear Station Operations and Maintenance Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SECOND TEN-YEAR INTERVAL INSERVICE INSPECTION REQUEST FOR RELIEF NO. IR-2-27 MILLSTONE POWER STATION, UNIT NO. 3 DOMINION NUCLEAR CONNECTICUT, INC.
DOCKET NUMBER 50-423
1.0 INTRODUCTION
By letter dated November 26, 2002, as supplemented July 1, 2003, Dominion Nuclear Connecticut, Inc. (DNC or the licensee), submitted to the U.S. Nuclear Regulatory Commission (NRC or the Commission), Relief Request No. IR-2-27, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i), requesting approval of an alternative to the requirements of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code)Section XI. The alternative would allow the one-time use of a non-ASME Code Section III N-type certificate holder to perform fabrication activities at its facility while meeting the requirements of 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
2.0 REGULATORY REQUIREMENTS Inservice Inspection (ISI) of the ASME Code Class 1, 2, and 3 components are performed in accordance with Section XI of the ASME Code and the applicable addenda, as required by 10 CFR 50.55a(g), except where written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). Section 50.55a(a)(3) of 10 CFR states that alternatives to the requirements of 10 CFR 50.55a(g) may be used, when authorized by the NRC, if: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection (ISI) of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examinations of components and system pressure tests conducted during the first ten-year interval, and subsequent intervals, comply with the requirements in the latest edition and addenda of Section XI of the ASME Code, incorporated by reference in 10 CFR 50.55a(b), 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable ASME Code of record for the second ten-year ISI for Millstone Power Station, Unit No. 3 (MP3) is the 1989 Edition of the ASME Code Section XI.
When performing replacements in accordance with the ASME Code Section XI, 1989 Edition, IWA-7210(b) requires that items to be used for replacement meet the Construction Code and the existing design requirements. If the original Construction Code wasSection III, then all the requirements of ASME Code Section III apply unless they are modified or exempted by the other provisions of IWA-7000. Because of this, ASME Code Section XI general requirements for quality assurance and documentation of ASME Code Section III, Subsection NA, and Class 2 requirements of Subsection NC that are applicable to this request shall be met. When piping subassemblies are fabricated by a vendor at the vendors facility to meet ASME Code Section III requirements, an ASME Code N-type certificate of authorization is required to be used with at least an NPT stamp, and all of the quality assurance provisions that are associated with the vendors authorization shall be applied. When all these requirements have been met, an applicable Code Data Report would be issued by the fabricator and signed by an Authorized Nuclear Inspector (ANI).
3.0 PROPOSED ALTERNATIVE AND BASIS FOR RELIEF DNC proposes, as an alternative to the requirements of ASME Code Section XI, 1989 Edition, IWA-7210(b), and ASME Code Section III, 1971 Edition, with the Summer 1973 Addenda that require a vendor to have an ASME Code N-type certificate of authorization (NPT-type) and provide with a completed subassembly a Code Data Report Form NPP, that the provisions of 10 CFR 50, Appendix B be used along with the participation of an ANI. The application of the 10 CFR 50, Appendix B criteria proposed in this alternative is specific to the MP3 ASME Code Section XI Repair and Replacement Program regarding the vendor portion (i.e. subassembly fabrication) for the replacement activity described in this request.
The original ASME Code Section XI Repair and Replacement activity described in this request took place during Refueling Outage 6 in the spring of 1999 and was intended to be performed solely at the Millstone site with the vendor working under the Millstone ASME Code Section XI Repair and Replacement Program and 10 CFR 50 Appendix B. The licensee stated that if the work had been performed at the licensees facility, no issue would exist as MP3 would have been in full compliance with Section XI. However, the licensee decided that schedule enhancements would result if the vendor could fabricate the piping subassemblies at the vendor facility. The revised purchase order, to allow this work, did not identify that the vendor needed to have an ASME Code Section III, N-type certificate of authorization to perform the work at the vendor facility.
The licensee received and reviewed the following documentation from the vendor to support the vendor subassembly fabrication:
(a)
Welding Procedures (b) Welding Procedure Qualifications (c)
Heat Treatment/Bending/Cleaning Procedures-Covered By Weld Procedures (d) Nondestructive Examination (NDE) Procedures (e) NDE Reports (f) Radiographic Records and Film (g) Material Certificates (Including Filler Metal)
(h) Control Isometrics (i) Pipe Weld Data Sheets (j) Nonconformance Reports and Dispositions - No Nonconformance Reports were issued. However, several welds were repaired during the fabrication. Repair weld and acceptance documentation is provided in the Vendors Data Package for Fabrication (k) Third Party ANI Inspection - Evidence of ANI involvement is provided on the Vendor Quality Assurance Travelers for the subassemblies.
(l) Pressure Testing Reports - Part of the Millstone installation work documentation.
The licensee stated that similar documentation would be used to support the vendor subassembly fabrication under ASME Code Section III requirements if a Code Data Report Form NPP had been issued.
Based upon the above information, the licensee concluded that the proposed alternative would provide an acceptable level of quality and safety and would not adversely impact the health and safety of the public. The licensees proposed alternative is to be applied for the life of the replacement.
4.0 EVALUATION The licensee requested relief from the requirements of the ASME Code,Section XI, 1989 Edition, Subsection IWA 7000, Replacement. Specifically, the following non-conformance was identified: work performed under the requirements of ASME Code Section XI, 1989 Edition, IWA-7210(b), and the ASME Code Section III, 1971 Edition, with the Summer 1973 Addenda was performed at the vendors facility on the licensees A (Table I) and D (Table II)
Trains of the Feedwater System by a vendor who did not have an ASME Code N-type certificate of authorization.
The affected welds included the application of ID stainless steel cladding using ER309L filler material to 18", 16", and 8" SA-106 Grade C Schedule 100 piping, with two 16"x 18" SA-234 Gr.
WPC Schedule 100 reducers, and the shop welds listed in Table I and II:
The licensee stated that all the applied cladding had a penetrant dye test performed, and the subassemblies were pressure-tested following installation.
The NRC staff evaluated the information provided by the licensee and sent a Request for Additional Information (RAI) to the licensee in a letter dated March 28, 2003. The letter requested the licensee to verify that procedures and qualifications involving various in-process work by the vendor were witnessed and approved by the licensee. The licensee responded to the RAI in a letter dated July 1, 2003 and verified the following:
- 1. The licensees welding engineer reviewed the vendors production welding procedures and supporting qualification data and found them to be acceptable.
- 2. The licensee reviewed the vendors non-destructive evaluation reports and found them to be acceptable. Reviews of the NDE procedures and inspection documentation (including radiography testing (RT) film) verified that the required quality levels of the tests performed were sensitive enough to identify discontinuities that may have been detrimental to the integrity of the welds. This was supported by four flaws found during the in-process welding. The flaws were as follows:
The A Train weld FW83 had two (2) areas of incomplete fusion, excavated by grinding, and repair welded. The inspection results of Radiography Testing (RT) and Magnetic Particle Testing (MT) were acceptable per ASME Section III, 1992 Edition.
The B [D] Train weld FW67 had two (2) areas of incomplete fusion, excavated by grinding, and repair welded. The inspection results of RT and MT were acceptable per ASME III, 1992 Edition.
- 3. The licensee verified that the radiograph results and technique were reviewed by a Level III Examiner and found to be acceptable. The licensee also stated that the tests were determined by the Level III Examiner to be sensitive enough to identify discontinuities that may have been detrimental to the integrity of the welds. The RT, MT and penetrant testing (PT) met the requirements of the ASME Code Section III, 1992 Edition.
- 4. The licensee verified that the base material and filler material certifications used for production were reviewed, and met the requirements of the ASME Code.
- 5. The licensee stated that production weld records were reviewed and found to be acceptable against the parameters of the production weld procedures. Production welds were performed by qualified welders. The licensees welding engineer also observed some of the production welding at the vendors facility. The licensee also stated that production welding was witnessed and the welding documentation was approved and signed by an ANI on the vendors Quality Assurance Travelers (travelers are forms that contain the process steps involved in the fabrication, welding, etc. of a component) and Weld Process Travelers contained in the Final Vendors Data Package.
- 6. The licensee stated that the repair welding that was performed during fabrication exceeded 10% of the base material wall thickness and were considered major. The flaws were detected by RT. The licensee stated that the size of the flaws are documented on the RT data sheets and the vendors weld repair data sheets contained in the Final Vendors Data Package. The flaws were removed by grinding and the indications were dimensionally inspected. This documentation is provided on the vendors weld repair data sheets and NDE reports. The in-process inspection and discrepancy was documented on the vendors Weld Process Travelers and then on the RT and weld repair data sheets described above, which are all included in the Final Vendors Data Package.
- 7. The licensee verified that the ANI witnessed the production welding, inspection and subassemblies and provided signatures on the travelers. These documents are contained in the Final Vendors Data Package.
- 8. The licensee stated that pressure testing was performed to Code Case N-416-1 upon installation of the subassemblies. The pressure testing was found to be acceptable.
TABLE I A Train Vendor Weld Number Construction NDE ISI Weld Number ISI Item No./
Category Section XI PSI NDE Description FW72 RT, PT FWS-11-FW-72 C5.81/C-F-2 RT, PT Pressure Retaining 18" Pipe to Reducer Butt Weld FW82 MT N/A N/A N/A Non-Pressure Retaining Reinforcement Plate Full Penetration Weld FW83 RT Repair Welded FWS-11-FW-83 C5.81/C-F-2 Construction RT Used.
Inaccessible After Welding Reinforcement Plate 8" To 18" Pipe Stab-In Partial Penetration Weld.
Original Design FW84 MT N/A N/A N/A Non-Pressure Retaining Reinforcement Plate Full Penetration Weld FW85 MT FWS-11-FW-85 C3.20/C-C MT Reinforcement Plate Fillet Weld Attachment FW86 MT FWS-11-FW-86 C5.20/C-C MT 8" To 18" Partial Penetration Plate Weld/Fillet Attachment TABLE II D Train Vendor Weld Number Construction NDE ISI Weld Number ISI Item No./
Category Section XI PSI NDE Description FW67 RT, PT Repair Welded FWS-17-FW-67 C5.81/C-F-2 RT, PT Pressure Retaining 18" Pipe to Reducer Butt Weld FW76 MT N/A N/A N/A Non-Pressure Retaining Reinforcement Plate Full Penetration Weld FW77 RT FWS-17-FW-77 C5.81/C-F-2 Construction RT Used Inaccessible After Welding Reinforcement Plate 8" to 18" Pipe Stab-In Partial Penetration Weld Original Design FW78 MT N/A N/A N/A Non-Pressure Retaining Reinforcement Plate Full Penetration Weld FW79 MT FWS-17-FW-79 C3.20/C-C MT Reinforcement Plate Fillet Weld Attachment FW80 MT FWS-17-FW-80 C3.20/C-C MT 8" To 18" Partial Penetration Plate Weld/Fillet Attachment
- 9. The licensee verified that the vendors facility and work was audited. The vendor is an approved supplier under 10 CFR 50, Appendix B. Additionally, the licensee stated that the welding engineer was at the vendors facility and observed some of the welding being performed on butt welds and the cladding on parts of the subassemblies. The licensee stated that the welding engineer confirmed the work being performed by the vendor was acceptable.
The NRC staff reviewed the information provided by the licensee to support the request to use an alternative to the ASME Code,Section XI at MP3. Based upon its review of the information, the staff concludes that the proposed alternative provides reasonable assurance of structural integrity and is acceptable pursuant to 10 CFR 50.55a(a)(3)(ii). This conclusion is based upon the following: the licensee has verified that the work performed by its subcontractor was performed by qualified personnel; procedures were reviewed and approved by the licensee; inspections were performed and reviewed by qualified personnel; and all required quality assurance documentation was provided to the licensee. Pressure testing was performed on the subassemblies and were acceptable. The licensee also stated that some production welding was witnessed by the licensees welding engineer and was acceptable. The licensee also verified that the ANI witnessed the production welding, inspection and subassemblies, and provided signatures on the travelers. The licensee stated that similar documentation would be used to support the vendors subassembly fabrication under ASME Code Section III requirements if a Code Data Report Form NPP had been issued along with any pertinent notes.
In addition, it would be a hardship for the licensee to comply with the requirements of the ASME Code because the licensee would have to remove the subassemblies from the Feedwater System which were fabricated by the vendor and rework the entire A and D Trains.
Performing this rework by the licensee would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety over what has been performed by the vendor.
4.0 CONCLUSION
The NRC staff has reviewed the licensees request to use an alternative to the ASME Code,Section XI at MP3. Based upon its review of the information provided by the licensee in support of its request for relief, the staff finds that the above listed alternative is acceptable pursuant to 10 CFR 50.55a(a)(3)(ii). Removing the subassemblies from the licensees Feedwater System and reworking the entire A and D Trains would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the licensees proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the life of the replacement.
All other ASME Code Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the ANI Inspector.
Principal Contributors: E. Reichelt Date: January 7, 2004