ML071870153
| ML071870153 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/03/2007 |
| From: | Spina J Constellation Energy Group |
| To: | NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 72FR16731 00022, PR-50, RIN 3150-AH76 | |
| Download: ML071870153 (7) | |
Text
James A. Spina Calvert Cliffs Nuclear Power Plant, Inc.
Vice President 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410:495.5200 410.495.3500 Fax O Constellation Energy Generation Group PR 50 DOCKETED (72FR16731) July 3, 2007 USNRC July 5, 2007 (11:05am)
OFFICE OF SECRETARY Secretary RULEMAKINGS AND U.S. Nuclear Regulatory Commission ADJUDICATIONS STAFF Washington, DC 20555-0001 ATTENTION: Rulemakings and Adjudications Staff
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Proposed Rule, 10 CFR Part 50, Industry Codes and Standards; Amended Requirements (RIN 3150-AH76)
REFERENCE:
(a) Federal Register Notice, 72 FR 1673.1, dated April 5, 2007 Per Reference (a), the Nuclear Regulatory Commission (NRC) requested comments related to RIN 3150-AH76, Request from NRC for Comments on a proposal to amend NRC regulations to incorporate by reference the 2004 Edition of Section III, Division I and Section XI, Division I of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPV Code) and the 2004 Edition of the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code).
The attached comments from Calvert Cliffs Nuclear Power Plant, Inc. are provided for your consideration.
Should you have questions regarding this matter, please contact Mr. Jay S. Gaines at (410) 495-5219 or Mr. Bernard C. Rudell at (410) 495-4815.
Very truly yours, JAS/MJY/bjd
Attachment:
(1) Comments Related to RIN 3150-AH76, Federal Register Notice 72 FR 16731, dated April 5, 2007 cc: Document Control Desk, NRC Resident Inspector, NRC D. V. Pickett, NRC R. I. McLean, DNR S. J. Collins, NRC C- -7
ATTACHMENT (1)
COMMENTS RELATED TO RIN 3150-AH76, FEDERAL REGISTER NOTICE 72 FR 16731, DATED APRIL 5, 2007 Calvert Cliffs Nuclear Power Plant, Inc.
July 3, 2007
ATTACHMENT (1)
COMMENTS RELATED TO RIN 3150-AH76, FEDERAL REGISTER NOTICE 72 FR 16731, DATED APRIL 5,2007 Paragraph ITG Rule Text Comment
- Proposed Alternative D (1) All Reactor Vessel Head Inspections. MRP is developing a qualification All licensees of pressurized water (1) All licensees of pressurized water reactors program for vessel head reactors shall augment their shall augment their inservice inspection program penetrations based on ASME inservice inspection program by by implementing ASME Code Case N-729--1 Section V, Article 14, intermediate implementing ASME Code Case subject to the conditions specified in paragraphs rigor so there is no need for these N-729-1 except that the (g)(6)(ii)(D)(2) through (6) of this section. conditions. qualification program shall meet the intermediate rigor requirements of ASME,Section V, Article 14.
(2) Assessment Item B4.40 of Table 1 must be inspected at least This is an unwarranted A condition of not more than every fourth refueling outage or at least every disadvantage to plants on a 24 8 years, should be applied.
seven calendar years, whichever occurs first, month refueling outage.
after the first ten-year inspection interval.
(3) Assessment Instead of fulfilling the specified 'examination A surface examination of the Delete: A surface examination Primarily method' requirements for volumetric and surface J-groove weld is not necessary as must be performed on all J-groove examinations of Note 6 in Table 1, the licensee this is not a safety issue. It is welds.
Inspection shall perform a volumetric or surface estimated that these examinations Secondary examination or both of essentially 100 percent of will increase the duration of the the required volume or equivalent surfaces of the examinations by 7-21 days and nozzle tube, as identified by Fig. 2 of ASME result in a personnel dose rate of 5-Code Case N-729-1. A surface examination 20 Rem. Experience since the must be performed on all J-groove welds. If a issuance of the Order has shown a surface examination is substituted for a low frequency of leaks. This is a volumetric examination on a portion of a new requirement that should penetration nozzle that is below the toe of the receive a backfit analysis.
J-groove weld (Point E on Fig. 2'of ASME Code The proposed change does not Performance of this exam should Case N-729-1), the surface examination must recognize leak path ultrasonic be allowed as an alternative to be of the inside and outside wetted surfaces of examination in lieu of surface performing a surface exam of the the penetration nozzle not examined examination of the reactor vessel wetted portions of the reactor volumetrically. head penetration as was permitted vessel head penetrations when when Calvert Cliffs Nuclear Power volumetric examination is Plant, Inc. performed the performed on the nozzle tube: The examinations under Revised Order condition paragraph EA-03-009. This will add (g)(6)(ii)(D)(3) should be
ATTACHMENT (1)
COMMENTS RELATED TO RIN 3150-AH76, FEDERAL REGISTER NOTICE 72 FR 16731, DATED APRIL 5,2007 Paragraph ITG Rule Text Comment Proposed Alternative substantial unwarranted dose, cost, modified as such.
and time to the examination. The ultrasonic leak path exam has been demonstrated and was previously accepted by the Nuclear Regulatory Commission.
Reactor vessel head replacement The condition paragraph designs which have leak pathway (g)(6)(ii)(D)(3) should be designs that permit leakage passage modified as such.
through the nozzle interference fit zone for external detection should be exempt from performing surface examination of the wetted portions of the reactor vessel head penetrations when volumetric examination and the external leakage detection at these leak pathways is performed on the nozzle tube.
(4) Inspection Ultrasonic examinations must be performed MRP is developing a qualification **** using a methodology that using personnel, procedures and equipment that program for vessel head meets the (Insert) intermediate have been qualified by blind demonstration on penetrations based on ASME rigor requirements of ASME representative mockups using a methodology Section V, Article 14, intermediate Section V, Article 14.
that meets the conditions specified in paragraphs rigor so there is no need for these (g)(6)(ii)(D)(4)(i) through (iv) of this section conditions. Delete the rest of the paragraph instead of using a methodology that satisfies the beginning with "conditions" conditions specified by the qualification requirements of Paragraph-2500 of ASME Code Case N-729-1.
(i) Inspection The diameters of pipes in the specimen set shall No comment.
be within 1/2 in. (13 mm) of the nominal diameter of the qualification pipe size and a thickness tolerance of -:25 percent of the I nominal through-wall depth of the qualification 2
ATTACHMENT (1)
COMMENTS RELATED TO RIN 3150-AH76, FEDERAL REGISTER NOTICE 72 FR 16731, DATED APRIL 5,2007 Paragraph ITG Rule Text Comment Proposed Alternative pipe thickness. The specimen set must contain geometric and material indications that normally require discrimination from primary water stress corrosion cracking (PWSCC) flaws.
(ii) Inspection The specimen set must have a minimum often The current set of mockups that Replace after 2nd sentence with -
(10) flaws that provide an acoustic response have been in use for over 10 years A minimum of 20% of the total similar to that of PWSCC indications. All flaw do not meet all of these conditions. flaws shall initiate from the inside depths in the specimen set must be greater than New mockups would be necessary surface and 20% from the outside 10 percent of the nominal pipe wall thickness. A to meet these conditions. surface. At least 20% of the flaws minimum number of 30 percent of the total shall be in the depth ranges of flaws must be connected to the outside 10%-30% and 31% -50%. At least diameter and 30 percent of the total flaws must 20% and no more than X% (TBD) be connected to the inside diameter. Further, at of the flaws shall be oriented least 30 percent of the total flaws must measure axially. Mockups do not meet all from a depth of 10 to 30 percent of the wall the conditions in the proposed thickness and at least 30 percent of the total rule.
flaws must measure from a depth of 31 to 50 percent of the wall thickness and be connected to the inside or outside diameter, as applicable.
At least 30 percent, but no more than 60 percent, of the flaws must be oriented axially.
(iii) Inspection The procedures must identify the equipment and MRP is evaluating requalification essential variable settings used to qualify the and will provide recommendations procedures. An essential variable is defined as based on Art. 14; for example use any variable that affects the results of the of Technical Justifications, examination. The procedure must be requalified modeling, hierarchical approach when an essential variable is changed to fall and non-blind demonstrations and outside the demonstration range. A procedure PDI strategies could be used to must be qualified using the equivalent of at least effectively use resources to meet three test sets that are used to demonstrate this condition.
personnel performance. Procedure qualification The MRP Program Description for must require at least ofie successful personnel penetration qualifications already performance demonstration. includes the requirement to use the equivalent of three test sets for 3
ATTACHMENT (1)
COMMENTS RELATED TO RIN 3150-AH76, FEDERAL REGISTER NOTICE 72 FR 16731, DATED APRIL 5,2007 Paragraph ITG Rule Text Comment Proposed Alternative
_ procedure qualification.
(iv) Inspection Examination procedures, equipment, and The condition of flaw sizing Insert - The RMS error of the flaw Primarily personnel must be considered qualified for depth tolerance is generally less than the depths shall not exceed .125 inch sizing only if the root mean square (RMS) error accuracy of the flaw fabrication and and the length sizing error shall Assessment of the flaw depth measurements, as compared to a significant number of current not exceed .375 inch, respectively.
Secondary for the true flaw depths, does not exceed 1/32-inch techniques cannot meet this. (These values are based on acceptance (0.8 mm). Examination procedures, equipment, probabilistic and deterministic criteria and personnel must be considered qualified for calculations.)
length sizing if the RMS error of the flaw length measurements, as compared to the true flaw lengths, does not exceed 1/ 16-inch (1.6 mm).
(5) Assessment If flaws attributed to PWSCC have been No comment.
identified, whether acceptable or not for continued service under Paragraphs -3130 or -
3140 of ASME Code Case N-729-1, the reinspection interval must be each refueling outage instead of the reinspection intervals required by Table 1, Note (8) of ASME Code Case N-729-1.
(6) Assessment Appendix I of ASME Code Case N-729-1 must No comment.
not be implemented without prior NRC approval.
E (1) Reactor Coolant PressureBoundary Visual No comment.
Assessment Inspections. (1) All licensees of pressurized water reactors shall augment their inservice inspection program by implementing ASME Code Case N-722 subject to the conditions specified in paragraphs (g)(6)(ii)(E)(2) through (4) of this section. The inspection requirements of ASME Code Case N-722 only apply to components fabricated with Alloy 600/82/182 materials not mitigated by weld overlay or stress improvement.
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ATTACHMENT (1)
COMMENTS RELATED TO RIN 3150-AH76, FEDERAL REGISTER NOTICE 72 FR 16731, DATED APRIL 5,2007 Paragraph ITG Rule Text Comment Proposed Alternative (2) All If a visual examination determines that leakage It should be sufficient to is occurring from a specific item listed in Table demonstrate the ability to I of ASME Code Case N-722 that is not characterize the location, exempted by the ASME Code, Section Xl, orientation and length of cracks IWB-1220(b)(1), additional actions must be with calibration blocks or mockups performed to characterize the location, containing a notch in the axial and orientation, and length of crack(s) in Alloy 600 circumferential orientation.
nozzle wrought material and location, orientation, and length of crack(s) in Alloy 82/182 butt welds. Alternatively, licensees may replace the Alloy 600/82/182 materials in all the components under the item number of the leaking component.
(3) Assessment If the actions in paragraph (g)(6)(ii)(E)(2) of this No comment.
section determine that a flaw is circumferentially oriented and potentially a result of primary water stress corrosion cracking, licensees shall perform non-visual NDE inspections of components that fall under that ASME Code Case N-722 item number. The number of components inspected must equal or exceed the number of components found to be leaking under that item number. If circumferential cracking is identified in the sample, non-visual NDE must be performed in the remaining components under that item number.
(4) Inspection If ultrasonic examinations of butt welds are used No comment.
Primarily to meet the NDE requirements in paragraphs (g)(6)(ii)(E)(2) or (g)(6)(ii)(E)(3) of this section, Assessment they must be performed using the appropriate Secondary supplement of Section XI, Appendix VIII of the ASME Boiler and Pressure Vessel Code.
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