ML033220099
| ML033220099 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/21/2003 |
| From: | Holden C NRC/NRR/DLPM/LPD1 |
| To: | Christian D Dominion Nuclear Connecticut |
| Ennis R, NRR/DLPM, 415-1420 | |
| References | |
| TAC MC0942 | |
| Download: ML033220099 (5) | |
Text
November 21, 2003 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:
RELAXATION OF THE REQUIREMENTS OF ORDER EA-03-009 REGARDING REACTOR PRESSURE VESSEL HEAD INSPECTIONS, RELAXATION REQUEST NO. RR-89-48, MILLSTONE POWER STATION, UNIT NO. 2 (TAC NO. MC0942)
Dear Mr. Christian:
On February 11, 2003, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-03-009 requiring specific inspections of the reactor pressure vessel (RPV) head and associated penetration nozzles at pressurized water reactors. The NRC issued an errata to the Order on March 14, 2003, to correct an administrative part of the Order related to requests for relaxation of the Order requirements.Section IV.F of the Order states that requests for relaxation associated with specific penetration nozzles will be evaluated by the NRC staff using its procedure for evaluating proposed alternatives to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) in accordance with Section 50.55a(a)(3) of Title 10 of the Code of Federal Regulations (10 CFR).
Sections IV.A and IV.B of the Order provide criteria to categorize each plants RPV head with respect to its susceptibility to primary water stress corrosion cracking (PWSCC). For plants such as Millstone Power Station, Unit No. 2 (MP2), with RPV heads that are categorized as being highly susceptible to PWSCC,Section IV.C(1)(b) of the Order requires that the RPV head penetration nozzles be inspected each refueling outage using either of the following techniques:
(1) ultrasonic testing (UT) from two inches above the J-groove weld to the bottom of the nozzle and an assessment to determine if leakage has occurred in the interference fit zone, or (2) eddy current testing or dye penetrant testing (PT) of the wetted surface of each J-groove weld and nozzle base material to at least two inches above the J-groove weld.
By letter dated October 3, 2003, as supplemented on October 10 and 28, and November 5, 20, and 21, 2003, Dominion Nuclear Connecticut, Inc. (DNC or the licensee), requested relaxation from the requirements in Section IV.C(1)(b) of the Order for MP2. The relaxation request was made pursuant to the procedure specified in Section IV.F of the Order. Specifically, for inspection of the RPV control element drive mechanism (CEDM) penetration nozzles, DNC requested authorization to use a combination of UT and PT on the nozzle base material, and reduced examination coverage below the weld in the non-pressure boundary portion of the nozzle.
D. Christian The NRC staff has completed its review of the information provided in support of your request for relaxation. The staff concludes that the proposed alternative examination of the CEDM penetration nozzles provides reasonable assurance of the structural integrity of the nozzles.
The combined use of UT and PT as proposed demonstrates the integrity of the inspectable portion of the penetration below the J-groove weld, and the results of the crack growth analysis demonstrates that potential cracks emanating from the uninspectable portion of the penetration will not grow into the J-groove weld within one operating cycle. Further inspection of the CEDM nozzles in accordance with Section IV.C(1)(b) of the Order would result in hardship without a compensating increase in the level of quality and safety. Thus, DNC has demonstrated good cause for the requested relaxation. Therefore, pursuant to Section IV.F of the Order, and 10 CFR 50.55a(a)(3), the NRC staff authorizes the proposed relaxation and alternative inspection of the CEDM penetration nozzles at MP2 during the period while NRC Order EA-03-009 remains in effect. As agreed to in your submittal dated October 28, 2003, the NRCs authorization is contingent on the following condition:
If the NRC staff finds that the crack-growth formula in industry report MRP-55 is unacceptable, the licensee shall revise its analysis that justifies relaxation of the Order within 30 days after the NRC informs the licensee of an NRC-approved crack growth formula. If the licensees revised analysis shows that the crack growth acceptance criteria are exceeded prior to the end of the current operating cycle, this relaxation is rescinded and the licensee shall, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, submit to the NRC written justification for continued operation. If the revised analysis shows that the crack growth acceptance criteria are exceeded during the subsequent operating cycle, the licensee shall, within 30 days, submit the revised analysis for NRC review. If the revised analysis shows that the crack growth acceptance criteria are not exceeded during either the current operating cycle or the subsequent operating cycle, the licensee shall, within 30 days, submit a letter to the NRC confirming that its analysis has been revised. Any future crack-growth analyses performed for this and future cycles for RPV head penetrations must be based on an acceptable crack growth rate formula.
Be aware that when vessel head inspections are performed using ASME Code requirements, acceptance criteria, or qualified personnel, those activities and all related activities fall within the jurisdiction of the ASME Code. Therefore, Order-related inspection activities may be subject to third party review, including those by the Authorized Nuclear Inservice Inspector.
Sincerely,
/RA by ELeeds for/
Cornelius F. Holden, Director Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-336 cc: See next page
D. Christian The NRC staff has completed its review of the information provided in support of your request for relaxation. The staff concludes that the proposed alternative examination of the CEDM penetration nozzles provides reasonable assurance of the structural integrity of the nozzles.
The combined use of UT and PT as proposed demonstrates the integrity of the inspectable portion of the penetration below the J-groove weld, and the results of the crack growth analysis demonstrates that potential cracks emanating from the uninspectable portion of the penetration will not grow into the J-groove weld within one operating cycle. Further inspection of the CEDM nozzles in accordance with Section IV.C(1)(b) of the Order would result in hardship without a compensating increase in the level of quality and safety. Thus, DNC has demonstrated good cause for the requested relaxation. Therefore, pursuant to Section IV.F of the Order, and 10 CFR 50.55a(a)(3), the NRC staff authorizes the proposed relaxation and alternative inspection of the CEDM penetration nozzles at MP2 during the period while NRC Order EA-03-009 remains in effect. As agreed to in your submittal dated October 28, 2003, the NRCs authorization is contingent on the following condition:
If the NRC staff finds that the crack-growth formula in industry report MRP-55 is unacceptable, the licensee shall revise its analysis that justifies relaxation of the Order within 30 days after the NRC informs the licensee of an NRC-approved crack growth formula. If the licensees revised analysis shows that the crack growth acceptance criteria are exceeded prior to the end of the current operating cycle, this relaxation is rescinded and the licensee shall, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, submit to the NRC written justification for continued operation. If the revised analysis shows that the crack growth acceptance criteria are exceeded during the subsequent operating cycle, the licensee shall, within 30 days, submit the revised analysis for NRC review. If the revised analysis shows that the crack growth acceptance criteria are not exceeded during either the current operating cycle or the subsequent operating cycle, the licensee shall, within 30 days, submit a letter to the NRC confirming that its analysis has been revised. Any future crack-growth analyses performed for this and future cycles for RPV head penetrations must be based on an acceptable crack growth rate formula.
Be aware that when vessel head inspections are performed using ASME Code requirements, acceptance criteria, or qualified personnel, those activities and all related activities fall within the jurisdiction of the ASME Code. Therefore, Order-related inspection activities may be subject to third party review, including those by the Authorized Nuclear Inservice Inspector.
Sincerely,
/RA by ELeeds for/
Cornelius F. Holden, Director Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-336 cc: See next page DISTRIBUTION:
PUBLIC CRaynor OGC SBloom PDI-2 Reading REnnis ACRS RPulsifer CHolden TChan GHill (2)
BMcDermott, RGN-I JClifford AKeim JJolicoeur SSheng ADAMS Accession Number: ML033220099
- See previous concurrence OFFICE PDI-2/PM PDI-2/LA EMCB/SC OGC*
PDI-2/SC PDI/D NAME REnnis CRaynor TChan DDambly JClifford ELeeds for CHolden DATE 11/21/03 11/21/03 11/21/03 11/21/03 11/21/03 11/21/03 OFFICIAL RECORD COPY
Millstone Power Station, Unit No. 2 cc:
Lillian 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 Charles Brinkman, Director Washington Operations Nuclear Services Westinghouse Electric Company 12300 Twinbrook Pkwy, Suite 330 Rockville, MD 20852 Senior Resident Inspector Millstone Power Station c/o U.S. Nuclear Regulatory Commission P.O. Box 513 Niantic, CT 06357 Mr. W. R. Matthews Senior Vice President - Nuclear Operations Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Mr. P. J. Parulis Manager - Nuclear Oversight Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Mr. J. Alan Price Site Vice President 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 Ms. Nancy Burton 147 Cross Highway Redding Ridge, CT 00870 Mr. G. D. Hicks Director - Nuclear Station Safety and Licensing Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Mr. S. E. Scace Assistant to the Site Vice President Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385 Mr. Chris L. Funderburk Director, Nuclear Licensing and Operations Support Dominion Resources Services, Inc.
Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
Millstone Power Station, Unit No. 2 cc:
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 Mr. David W. Dodson Licensing Supervisor Dominion Nuclear Connecticut, Inc.
Rope Ferry Road Waterford, CT 06385