ML043030420
| ML043030420 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/29/2004 |
| From: | Ridenoure R Omaha Public Power District |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-04-001, LIC-04-0120 | |
| Download: ML043030420 (4) | |
Text
444 South 16th Street Mall Omaha NE 68102-2247 October 29,2004 LIC-04-0120 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Reference:
- 1.
Docket No. 50-285
- 2.
NRC Generic Letter 2004-01, Requirements for Steam Generator Tube Inspections (NRC-04-0 1 16)
SUBJECT:
Response to Generic Letter 2004-01, Requirements for Steam Generator Tube Inspections In response to Reference 2, the Omaha Public Power District (OPPD) provides the attached response infomation. The attachment contains the initial 60 day response information requested in Reference 2.
I declare under penalty of perjury that the foregoing is true and correct. (Executed on October 29, 2004.)
If you have additional questions, or require further information, please contact Thomas R. Byrne at (402) 533-7368. No commitments are made to the NRC in this letter.
ice Preside - Response to NRC Generic Letter 2004-0 1, Response to Generic Letter 2004-0 1,
Requirements for Steam Generator Tube Inspections Employment with Equal Opportunity
LIC-04-0 120 Page 1 ATTACHMENT 1 Response to Generic Letter 2004-01, Requirements for Steam Generator Tube Inspections
LIC-04-0 120 Page 2 Response to Generic Letter 2004-01, Requirements for Steam Generator Tube Inspections NRC Request 1:
Addressees should provide a description of the SG tube inspections performed at their plant during the last inspection. In addition, if they are not using SG tube inspection methods whose capabilities are consistent with the NRCs position, addressees should provide an assessment of how the tube inspections performed at their plant meet the inspection requirements of the TS [technical specification]
in conjunction with Criteria IX and XI of 10CFR Part 50, Appendix B, and corrective action taken in accordance with Appendix B, Criterion XVI. This assessment should also address whether the tube inspection practices are capable of detecting flaws of any type that may potentially be present along the length of the tube required to be inspected and that may exceed the applicable tube repair criteria.
OPPD Answer:
Steam generator tube inspections performed at Fort Calhoun Unit No. 1 (FCS) are consistent with the NRCs position regarding tube inspections and the FCS Technical Specifications. The Omaha Public Power District (OPPD) uses tube inspection methods that are capable of detecting flaw types that may be present. Prior to each inspection, a degradation assessment, which includes operating experience, is perfonned to identify degradation mechanisms that may be present, and a technique validation assessment is performed to verify that the eddy current techniques are capable of detecting those flaw types identified in the degradation assessment. The description of the SG tube inspections performed during the last inspection was provided in Reference 1 of this attachment.
NRC Request 2:
If addressees conclude that full compliance with the TS in conjunction with Criteria IX, XI and XVI of 10 CFR Part 50, Appendix B, requires corrective action, they should discuss their proposed corrective actions (e.g., changing inspection practices consistent with the NRCs position or submitting a TS amendment request with the associated safety basis for limiting the inspections) to achieve full compliance. If addressees choose to change their TS, the staff has included in the Attachment suggested changes to the TS definitions for a tube inspection and for plugging limits to show what may be acceptable to the staff in cases where the tubes are expanded for the hull depth of the tube sheet and where the extent of the inspection in the tube sheet region is limited.
OPPD Answer:
Steam generator tube inspections performed at FCS are consistent with the FCS Technical Specifications. Therefore this question does not apply.
LIC-04-0120 Page 3 NRC Request 3:
For plants where SG tube inspections have not been or are not being performed consistent with the NRCs position on the requirements in the TS in conjunction with Criteria IX, XI, and XVI of 10 CFR Part 50, Appendix B, the licensee should submit a safety assessment (ie., a justification for continued operation based on maintaining tube structural and leakage integrity) that addresses any differences between the licensees inspection practices and those called for by the NRCs position.
Safety assessments should be submitted for all areas of the tube required to be inspected by the TS, where flaws are not being used, and should include the basis for not employing such inspection techniques. The assessment should include an evaluation of (1) whether the inspection practices rely on an acceptance standard (e.g., cracks located at least a minimum distance of x below the top of tube sheet, even if these cracks cause complete severance of the tube) which is different from the TS acceptance standards (i.e.,
the tube plugging limits or repair criteria), and (2) whether the safety assessment constitutes a change to the method of evaluation (as defined in lOCRF50.59) for establishing the structural and leakage integrity of the joint. If the safety assessment constitutes a change to the method of evaluation under 10 CFR 50.59, the licensee should determine whether a license amendment is necessary pursuant to that regulation.
OPPD Answer:
Steam Generator tube inspections performed at FCS are consistent with the NRCs position regarding tube inspections. Therefore this question does not apply.
Reference
- 1. Letter from OPPD (R. L. Phelps) to NRC (Document Control Desk) dated March 26, 2004, Fort Calhoun Station (FCS) Steam Generator Eddy Current Test Report - 2003 Refueling Outage (LIC-04-0040) (ML040910288)