ML060250649

RAI Concerning Response to GL 2004-01, Requirements for Steam Generator Tube Inspections.

ML060250649
Person / Time
Site:	San Onofre
Issue date:	01/18/2006
From:	Kalyanam N Plant Licensing Branch III-2
To:	Rosenblum R Southern California Edison Co
Kalynanam N, NRR/DLPM,415-1480
References
GL-04-001, TAC MC4849
Download: ML060250649 (5)

Text

January 18, 2006 Mr. Richard M. Rosenblum Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION (SONGS), UNIT 2 -

REQUEST FOR ADDITIONAL INFORMATION CONCERNING RESPONSE TO GENERIC LETTER 2004-01, REQUIREMENTS FOR STEAM GENERATOR TUBE INSPECTIONS (TAC NO. MC4849)

Dear Mr. Rosenblum:

On August 30, 2004, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2004-01, Requirements For Steam Generator Tube Inspections. The purpose of GL 2004-01 was to obtain information that would enable the NRC staff to determine whether licensees steam generator tube inspection programs comply with the existing tube inspection requirements (the plant technical specifications in conjunction with Appendix B to Part 50 of Title 10 of the Code of Federal Regulations).

By letter dated October 26, 2004 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML043020250), as supplemented by letter dated November 23, 2005 (ADAMS Accession Number ML053320210), Southern California Edison (SCE), the licensee for SONGS, submitted the response to GL 2004-01.

The NRC Staff has reviewed the SCE response to GL 2004-01 for SONGS, Unit 2, and determined that additional information is needed in order for the NRC staff to complete a review. The NRC staff requests that you forward the enclosed questions to the licensee.

If you have any questions, please me at (301) 415-1480.

Sincerely,

/RA/

N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-361

Enclosure:

Request for Additional Information cc w/encl: See next page

Mr. Richard M. Rosenblum January 18, 2006 Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION (SONGS), UNIT 2 -

REQUEST FOR ADDITIONAL INFORMATION CONCERNING RESPONSE TO GENERIC LETTER 2004-01, REQUIREMENTS FOR STEAM GENERATOR TUBE INSPECTIONS (TAC NO. MC4849)

Dear Mr. Rosenblum:

On August 30, 2004, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2004-01, Requirements For Steam Generator Tube Inspections. The purpose of GL 2004-01 was to obtain information that would enable the NRC staff to determine whether licensees steam generator tube inspection programs comply with the existing tube inspection requirements (the plant technical specifications in conjunction with Appendix B to Part 50 of Title 10 of the Code of Federal Regulations).

By letter dated October 26, 2004 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML043020250), as supplemented by letter dated November 23, 2005 (ADAMS Accession Number ML053320210), Southern California Edison (SCE), the licensee for SONGS, submitted the response to GL 2004-01.

The NRC Staff has reviewed the SCE response to GL 2004-01 for SONGS, Unit 2, and determined that additional information is needed in order for the NRC staff to complete a review. The NRC staff requests that you forward the enclosed questions to the licensee.

If you have any questions, please me at (301) 415-1480.

Sincerely,

/RA/

N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-361

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION PUBLIC LPLIV r/f RidsNrrDorl (CHaney/CHolden)

RidsNrrDorlLplg (DTerao) RidsNrrPMNKalyanam RidsNrrLALFeizollahi AHiser RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn4MailCenter (TPruett) RidsNrrDorlDpr PKlein MYoder ACCESSION NO: ML OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NAME NKalyanam LFeizollahi DTerao DATE 1/10/06 1/10/06 1/18/06 OFFICIAL RECORD COPY DOCUMENT NAME: E:\Filenet\ML060250649.wpd

REQUEST FOR ADDITIONAL INFORMATION RELATED TO SOUTHERN CALIFORNIA EDISON SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 2, GL-2004-01 RESPONSE DOCKET NO. 50-361 On August 30, 2004, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2004-01, "Requirements For Steam Generator Tube Inspections." The purpose of GL 2004-01 was to obtain information that would enable the NRC staff to determine whether licensees steam generator (SG) tube inspection programs comply with the existing tube inspection requirements (the plant technical specifications in conjunction with Appendix B to Part 50 of Title 10 of the Code of Federal Regulations).

By letter dated October 26, 2004 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML043020250), as supplemented by letter dated November 23, 2005 (ADAMS Accession Number ML053320210), Southern California Edison, the licensee for San Onofre Nuclear Generating Station, Unit No. 2, submitted a response to GL 2004-01. The NRC staff has reviewed these letters and has determined that additional information is needed in order for the NRC staff to complete a review. The NRC staff requests that the licensee respond to the following:

In its response to GL 2004-01, the licensee indicated the following concerning inspections of the parent tube behind (i.e., adjacent to) the nickel band portion of Combustion Engineering Alloy 690 tungsten inert gas welded sleeves: (1) the inspections adjacent to the nickel band are limited; (2) completion of the ongoing evaluation and technical basis development is expected within the next year; (3) this issue is being tracked within their corrective action program; and (4) flaws in the parent tube adjacent to the nickel band are not safety significant.

Given that it is not clear whether inspection techniques are capable of finding the forms of degradation that could be occurring in the parent tube adjacent to the nickel band and the licensee is relying on a safety assessment indicating that inspections in this region are not needed to ensure structural and leakage integrity, it would appear that a license amendment is required consistent with the NRC staff position outlined in GL 2004-01.

With respect to the qualification of a technique for inspecting the parent tube adjacent to the nickel band, the NRC staff notes that existing analysis is based on electro-discharged machined (EDM) notches with adjustments to account for differences between cracks and EDM notches.

As discussed in Regulatory Issue Summary 2000-22, Issues Stemming from NRC Staff Review of Recent Difficulties Experienced in Maintaining Steam Generator Tube Integrity, the NRC staff position is that technique qualifications based on EDM notched specimens do not provide an adequate basis for evaluating the technique capability since EDM notched specimens produce much larger amplitude signals and have better signal-to-noise levels.

EDM notches may also produce different signal response characteristics.

As a result of the above, we request the licensee discuss their plans (and schedule) for submitting an amendment demonstrating that structural and leakage integrity of the joint are ensured without inspecting the parent tube behind (i.e., adjacent to) the nickel band region.

Alternatively, the licensee could either (1) demonstrate that the techniques they are using are capable of finding the forms of degradation that could be in the parent tube behind the nickel band region, or (2) commit to remove all sleeves with a nickel band from service.

San Onofre Nuclear Generating Station Units 2 and 3 cc:

Mr. Daniel P. Breig Resident Inspector/San Onofre NPS Southern California Edison Company c/o U.S. Nuclear Regulatory Commission San Onofre Nuclear Generating Station Post Office Box 4329 P. O. Box 128 San Clemente, CA 92674 San Clemente, CA 92674-0128 Mayor Mr. Douglas K. Porter, Esquire City of San Clemente Southern California Edison Company 100 Avenida Presidio 2244 Walnut Grove Avenue San Clemente, CA 92672 Rosemead, CA 91770 Mr. James T. Reilly Mr. David Spath, Chief Southern California Edison Company Division of Drinking Water and San Onofre Nuclear Generating Station Environmental Management P.O. Box 128 P. O. Box 942732 San Clemente, CA 92674-0128 Sacramento, CA 94234-7320 Mr. James D. Boyd, Commissioner Chairman, Board of Supervisors California Energy Commission County of San Diego 1516 Ninth Street (MS 31) 1600 Pacific Highway, Room 335 Sacramento, CA 95814 San Diego, CA 92101 Mr. Ray Waldo, Vice President Eileen M. Teichert, Esq. Southern California Edison Company Supervising Deputy City Attorney San Onofre Nuclear Generating Station City of Riverside P.O. Box 128 3900 Main Street San Clemente, CA 92764-0128 Riverside, CA 92522 Mr. Brian Katz Mr. Gary L. Nolff Southern California Edison Company Power Projects/Contracts Manager San Onofre Nuclear Generating Station Riverside Public Utilities P.O. Box 128 2911 Adams Street San Clemente, CA 92764-0128 Riverside, CA 92504 Mr. Steve Hsu Regional Administrator, Region IV Department of Health Services U.S. Nuclear Regulatory Commission Radiologic Health Branch 611 Ryan Plaza Drive, Suite 400 MS 7610, P.O. Box 997414 Arlington, TX 76011-8064 Sacramento, CA 95899 Mr. Michael Olson Mr. A. Edward Scherer San Diego Gas & Electric Company Southern California Edison Company P.O. Box 1831 San Onofre Nuclear Generating Station San Diego, CA 92112-4150 P.O. Box 128 San Clemente, CA 92674-0128 Mr. Ed Bailey, Chief Radiologic Health Branch State Department of Health Services Post Office Box 997414 (MS7610)

Sacramento, CA 95899-7414 November 2005