ML080370199
| ML080370199 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/05/2008 |
| From: | Russ Bywater Region 4 Engineering Branch 1 |
| To: | Blevins M Luminant Generation Co |
| References | |
| IR-08-003 | |
| Download: ML080370199 (12) | |
See also: IR 05000445/2008003
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
R E GI ON I V
611 RYAN PLAZA DRIV E, SUITE 400
ARLINGTON, TEXAS 76011-4005
February 5, 2008
Mike Blevins, Executive Vice President
and Chief Nuclear Officer
Luminant Generation Company LLC
ATTN: Regulatory Affairs
Comanche Peak Steam Electric Station
P.O. Box 1002
Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 -
NOTIFICATION OF INSPECTION (NRC INSPECTION REPORT 05000445/2008003
AND 05000446/2008003) AND REQUEST FOR INFORMATION
Dear Mr. Blevins:
From March 31 to April 11, 2008, reactor inspectors from the Nuclear Regulatory
Commissions (NRC) Region IV office will perform the baseline inservice inspection
at Comanche Peak Steam Electric Station, Unit 2, using NRC Inspection
Procedure 71111.08. Experience has shown that this inspection is resource intensive
both for the NRC inspectors and your staff. In order to minimize the impact to your
onsite resources and to ensure a productive inspection, we have enclosed a request for
documents needed for this inspection. These documents have been divided into two
groups. The first group (Section A of the enclosure) identifies information to be provided
prior to the inspection to ensure that the inspectors are adequately prepared. The
second group (Section B of the enclosure) identifies the information the inspectors will
need upon arrival at the site. It is important that all of these documents are up to date
and complete in order to minimize the number of additional documents requested during
the preparation and/or the onsite portions of the inspection.
We have discussed the schedule for these inspection activities with your staff and
understand that our regulatory contact for this inspection will be Mr. Bob Kidwel of your
licensing organization. Our inspection dates are subject to change based on your
updated schedule of outage activities. If there are any questions about this inspection or
the material requested, please contact the lead inspector S. Makor at (817) 276-6507
(stm@nrc.gov).
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter
and its enclosure will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRC's
Luminant Generation
-2-
Company LLC
document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Russell L. Bywater, Chief
Engineering Branch 1
Division of Reactor Safety
Dockets: 50-445; 50-446
Enclosure:
Inservice Inspection Document Request
cc w/enclosure:
Fred W. Madden, Director
Regulatory Affairs
Luminant Generation Company LLC
P.O. Box 1002
Glen Rose, TX 76043
Timothy P. Matthews, Esq.
Morgan Lewis
1111 Pennsylvania Avenue, NW
Washington, DC 20004
Anthony Jones, Chief Boiler Inspector
Texas Department of Licensing
and Regulation
Boiler Program
P.O. Box 12157
Austin, TX 78711
Somervell County Judge
P.O. Box 851
Glen Rose, TX 76043
Richard A. Ratliff, Chief
Bureau of Radiation Control
Texas Department of Health
1100 West 49th Street
Austin, TX 78756-3189
Environmental and Natural
Luminant Generation
-3-
Company LLC
Resources Policy Director
Office of the Governor
P.O. Box 12428
Austin, TX 78711-3189
Brian Almon
Public Utility Commission
William B. Travis Building
P.O. Box 13326
Austin, TX 78711-3326
Susan M. Jablonski
Office of Permitting, Remediation
and Registration
Texas Commission on
Environmental Quality
MC-122
P.O. Box 13087
Austin, TX 78711-3087
Environmental and Natural
Resources Policy Director
Office of the Governor
P.O. Box 12428
Austin, TX 78711-3189
Lisa R. Hammond, Chief
Technological Hazards Branch
National Preparedness Division
FEMA Region VI
800 N. Loop 288
Denton, TX 76209
Luminant Generation
-4-
Company LLC
Electronic distribution by RIV:
Regional Administrator (EEC)
DRP Director (DDC)
DRS Director (RJC1)
DRS Deputy Director (ACC)
Senior Resident Inspector (DBA)
Branch Chief, DRP/A (CEJ1)
Senior Project Engineer, DRP/A (TRF)
Team Leader, DRP/TSS (CJP)
RITS Coordinator (MSH3)
SUNSI Review Completed: ______ ADAMS: Yes
No Initials: ______
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
S:\\DRS\\REPORTS\\CP2008003lt-lee1.doc
RI:EB1
SRI:EB1
C:EB1
SMakor/lmb
LEEllershaw
RLBywater
/RA/
/RA/
/RA/
2/5/08
2/5/08
2/5/08
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
1
Enclosure
INSERVICE INSPECTION DOCUMENT REQUEST
Inspection Dates:
March 31, 2008 - April 11, 2008
Inspection Procedures:
IP 71111.08 Inservice Inspection (ISI) Activities
TI 2515/166 Pressurized Water Reactor Containment Sump Blockage
Inspectors:
S. Makor, Reactor Inspector (Lead Inspector - ISI)
J. Drake, Senior Reactor Inspector
K. Clayton, Senior Reactor Inspector
L. Ellershaw, Senior Reactor Inspector
A.
Information Requested for the In-Office Preparation Week
The following information should be sent to the Region IV office in hard copy or
electronic format (ims.certrec.com preferred), in care of L. Ellershaw, by March 17, 2008,
to facilitate the selection of specific items that will be reviewed during the onsite
inspection week. The inspector will select specific items from the information requested
below and then request from your staff additional documents needed during the onsite
inspection week (Section B of this enclosure). We ask that the specific items selected
from the lists be available and ready for review on the first day of inspection. *Please
provide requested documentation electronically if possible. If requested documents are
large and only hard copy formats are available, please inform the inspector(s), and
provide subject documentation during the first day of the onsite inspection. If you have
any questions regarding this information request, please call the inspector as soon as
possible.
A.1
ISI/Welding Programs and Schedule Information
a)
A detailed schedule (including preliminary dates) of:
i)
Nondestructive examinations (NDEs) planned for Class 1 & 2 systems and
containment, performed as part of your ASME Section XI, Risk Informed (if applicable),
and augmented ISI programs during the upcoming outage.
Provide a status summary of the NDE inspection activities vs. the required inspection
period percentages for this Interval by category per ASME Section XI, IWX-2400 (Do not
provide separately if other documentation requested contains this information)
ii)
Reactor pressure vessel head (RPVH) examinations planned for the upcoming
outage.
iii)
Examinations planned for Alloy 82/182/600 components that are not included in
the Section XI scope. (If applicable)
2
Enclosure
iv)
Examinations planned as part of your Boric Acid Corrosion Control Program
(Mode 3 walkdowns, bolted connection walkdowns, etc.)
v)
Welding activities that are scheduled to be completed during the upcoming
outage (ASME Class 1, 2, or 3 structures, systems, or components (SSCs))
b)
A copy of ASME Section XI Code Relief Requests and associated NRC Safety
Evaluations applicable to the examinations identified above.
c)
A list of NDE reports (ultrasonic, radiography, magnetic particle, dye penetrant,
Visual VT-1, VT-2, and VT-3), which have identified relevant conditions on Code Class 1
& 2 systems since the beginning of the last refueling outage. This should include the
previousSection XI pressure test(s) conducted during start up and any evaluations
associated with the results of the pressure tests. Also, include in the list the NDE reports
with relevant conditions in the RPVH penetration nozzles which have been accepted for
continued service. The list of NDE reports should include a brief description of the SSC
where the relevant condition was identified.
d)
A list with a brief description (e.g., system, material, pipe size, weld number, and
NDE performed) of the welds in Code Class 1 and 2 systems which have been
fabricated due to component repair/replacement activities since the beginning of the last
refueling outage, or are planned to be fabricated this refueling outage.
e)
If reactor vessel weld examinations required by the ASME Code are scheduled to
occur during the upcoming outage, provide a detailed description of the welds to be
examined and the extent of the planned examination. Please also provide reference
numbers for applicable procedures that will be used to conduct these examinations.
f)
Copy of any 10 CFR Part 21 reports applicable to your SSCs within the scope of
Section XI of the ASME Code that have been identified since the beginning of the last
refueling outage.
g)
A list of any temporary non-code repairs in service (e.g., pinhole leaks).
h)
Please provide copies of the most recent self assessments for the ISI, Welding,
and Alloy 600 Programs.
A.2
Reactor Pressure Vessel Head (RPVH)
a)
Provide the detailed scope of the planned NDE of the reactor vessel head which
identifies the types of NDE methods to be used on each specific part of the vessel head
to fulfill commitments made in response to NRC Bulletin 2002-02 and NRC Order EA-03-
009. Also, include examination scope expansion criteria and planned expansion sample
sizes if relevant conditions are identified. (If applicable)
3
Enclosure
b)
A list of the standards and/or requirements that will be used to evaluate
indications identified during NDE of the reactor vessel head (e.g., the specific industry or
procedural standards which will be used to evaluate potential leakage and/or flaw
indications).
A.3
Boric Acid Corrosion Control Program (BACCP)
a)
Copy of the procedures that govern the scope, equipment and implementation of
the inspections required to identify boric acid leakage and the procedures for boric acid
leakage/corrosion evaluation.
b)
Please provide a list of leaks (including Code class of the components) that have
been identified since the last refueling outage and associated corrective action
documentation. If during the last cycle, the Unit was shutdown, please provide
documentation of containment walkdown inspections performed as part of the BACCP.
c)
Please provide a copy of the most recent self-assessment performed for the
BACCP.
A.4
Steam Generator Tube (SGT) Inspections
a)
A detailed schedule of:
i)
SGT inspection, data analyses, and repair activities for the upcoming outage. (If
occurring)
ii)
SG secondary side inspection activities for the upcoming outage. (If occurring)
b)
Please provide a copy of your SG ISI Inspection Program and Plan. Please
include a copy of the Operational Assessment from last outage and a copy of the
following documents as they become available:
i)
Degradation Assessment
ii)
Condition Monitoring Assessment
c)
If you are planning on modifying your Technical Specifications such that they are
consistent with TSTF-449, please provide copies of your correspondence with the NRC
regarding deviations from the STS.
d)
Copy of SG history documentation given to vendors performing eddy current (ET)
testing of the SGs during the upcoming outage.
e)
Copy of SG Eddy Current Data Analyst Guidelines and Site Validated Eddy
Current Technique Specification Sheets (ETSS). Additionally, please provide a copy of
EPRI Appendix H ETSS Qualification Records.
4
Enclosure
f)
Identify and quantify any SGT leakage experienced during the previous operating
cycle. Also provide documentation identifying which SG was leaking and corrective
actions completed or planned for this condition (If applicable).
g)
Provide past history of the condition and issues pertaining to the secondary side
of the steam generators (including items such as loose parts, fouling, top of tube sheet
condition, crud removal amounts, etc.)
h)
Please provide copies of your most recent self assessments of the SG
monitoring, loose parts monitoring, and secondary side water chemistry control
programs.
i)
Please also indicate where the primary, secondary, and resolution analyses are
scheduled to take place.
j)
Please provide a summary of the scope of the SGT examinations, including
examination methods such as Bobbin, Rotating Pancake, or Plus Point, and the
percentage of tubes to be examined. *Do not provide these documents separately if
already included in other information requested.
A.5
Metals Reliability (MRP-139) Program Activities
a)
A list of, with verification, that the baseline inspections of all applicable Dissimilar
Metal Butt Welds (DMBWs) have been completed by December 31, 2007.
b)
Verification that baseline inspection of hot leg and cold leg temperature DMBWs
have been included in the inspection program and that the schedules for the baseline
inspections are consistent with the baseline schedules in MRP-139.
c)
A list and schedule (examination dates) of all DMBW examinations planned for
the upcoming refueling outage. If none are scheduled, then data from previous
examinations should be available for review.
d)
A list and schedule for any welding to be performed on DMBWs in the upcoming
outage. If no welding will be performed then records of previous welding on DMBWs
and postweld NDE documentation.
e)
A list and schedule of any stress improvement (SI) activities planned for the
upcoming refueling outage. If none are scheduled then have qualification reports for any
SIs previously performed.
f)
Documentation and description of how the baseline and inservice inspection
specifications in MRP-139 are satisfied at your facility.
A.6
Additional information related to all ISI activities
5
Enclosure
a)
A list with a brief description of ISI, BACCP, and SGT inspection related issues
(e.g., condition reports) entered into your corrective action program since the beginning
of the last refueling outage (for Unit 2). For example, a list based upon data base
searches using key words related to piping or SG tube degradation such as: ISI, ASME
Code,Section XI, NDE, cracks, wear, thinning, leakage, rust, corrosion, boric acid, or
errors in piping/SGT examinations.
b)
Please provide names and phone numbers for the following program leads:
ISI contacts (Examination, planning)
Containment Exams
RPVH Exams
Snubbers and Supports
Repair and Replacement Program Manager
Licensing Contact
Site Welding Engineer
Boric Acid Corrosion Control Program
SG Inspection Activities (site lead and vendor contact)
B.
Information to be provided onsite to the inspector(s) at the entrance meeting
(March 31, 2008):
B.1
ISI / Welding Programs and Schedule Information
a)
Updated schedules for ISI/NDE activities, including SGT inspections, planned
welding activities, and schedule showing contingency repair plans, if available.
b)
For ASME Code Class 1 and 2 welds selected by the inspector from the lists
provided from section A of this enclosure, please provide copies of the following
documentation for each subject weld:
i)
Weld data sheet (traveler)
ii)
Weld configuration and system location
iii)
Applicable Code Edition and Addenda for weldment
iv)
Applicable Code Edition and Addenda for welding procedures
v)
Applicable weld procedures (WPS) used to fabricate the welds
vi)
Copies of procedure qualification records (PQRs) supporting the WPS from
B.1.b.v
vii)
Copies of mechanical test reports identified in the PQRs above
viii)
Copies of the nonconformance reports for the selected welds (If applicable)
ix)
Radiographs of the selected welds and access to equipment to allow viewing
radiographs (If RT was performed)
x)
Copies of the preservice examination records for the selected welds.
xi)
Copies of welder performance qualifications records applicable to the selected
welds, including documentation that welder maintained proficiency in the applicable
6
Enclosure
welding processes specified in the WPS (at least six months prior to the date of subject
work)
xii)
Copies of NDE personnel qualifications (VT, PT, UT, RT), as applicable
c)
For the ISI related corrective action issues selected by the inspector(s) from
section A of this enclosure, provide a copy of the corrective actions and supporting
documentation.
d)
For the NDE reports with relevant conditions on Code Class 1 & 2 systems
selected by the inspector from section A above, provide a copy of the examination
records, examiner qualification records, and associated corrective action documents.
e)
A copy of (or ready access to) most current revision of the ISI Program Manual
and Plan for the current Interval.
f)
For the NDEs selected by the inspector from section A of this enclosure, provide
copy of the NDE procedures used to perform the examinations (including calibration and
flaw characterization/sizing procedures). For ultrasonic examination procedures
qualified in accordance with ASME Code,Section XI, Appendix VIII, provide
documentation supporting the procedure qualification (e.g., the EPRI performance
demonstration qualification summary sheets). Also, include qualification documentation
of the specific equipment to be used (e.g., ultrasonic unit, cables, and transducers
including serial numbers) and NDE personnel qualification records.
B.2
Reactor Pressure Vessel Head (RPVH)
a)
Provide the NDE personnel qualification records for the examiners who will
perform examinations of the RPVH.
b)
Provide drawings showing the following: (If a visual examination is planned for
the upcoming refueling outage)
i) RPVH and CRDM nozzle configurations
ii) RPVH insulation configuration
The drawings listed above should include fabrication drawings for the nozzle attachment
welds as applicable.
c)
Copy of NDE reports from the last RPVH examination.
d)
Copy of evaluation or calculation demonstrating that the scope of the visual
examination of the upper head will meet the 95% minimum coverage required by NRC
Order EA-03-009 (If a visual examination is planned for the upcoming refueling outage).
e)
Provide a copy of the procedures that will be used to identify the source of any
boric acid deposits identified on the RPVH. If no explicit procedures exist which govern
7
Enclosure
this activity, provide a description of the process to be followed including personnel
responsibilities and expectations.
f)
Provide a copy of the updated calculation of effective degradation years (EDY)
for the RPVH susceptibility ranking.
g)
Provide copy of the vendor qualification report(s) that demonstrates the detection
capability of the NDE equipment used for the RPVH examinations. Also, identify any
changes in equipment configurations used for the RPVH examinations which differ from
that used in the vendor qualification report(s).
B.3
Boric Acid Corrosion Control Program (BACCP)
a)
Please provide boric acid walkdown inspection results, an updated list of boric
acid leaks identified so far this outage, associated corrective action documentation, and
overall status of planned boric acid inspections.
b)
Please provide any engineering evaluations completed for boric acid leaks
identified since the end of the last refueling outage. Please include a status of corrective
actions to repair and/or clean these boric acid leaks. Please identify specifically which
known leaks, if any, have remained in service or will remain in service as active leaks.
B.4
Steam Generator Tube (SGT) Inspections
a)
Copies of the Examination Technique Specification Sheets (ETSS) and
associated justification for any revisions.
b)
Copy of the guidance to be followed if a loose part or foreign material is identified
in the SGs.
c)
Please provide a copy of the ET procedures used to perform the SGT
inspections (sp
ecifically calibration and flaw characterization/sizing procedures, etc.). Also include
documentation for the specific equipment to be used.
d)
Please provide copies of your responses to NRC and industry operating
experience communications such as Generic Letters, Information Notices, etc. (as
applicable to SGT inspections) *Do not provide these documents separately if already
included in other information requested such as the degradation assessment.
e)
List of corrective action documents generated by the vendor and/or site with
respect to SG inspection activities.
B.5
Codes and Standards
8
Enclosure
a)
Ready access to (i.e., copies provided to the inspector(s) for use during the
inspection at the onsite inspection location, or room number and location where
available):
i)
Applicable Editions of the ASME Code (Sections V, IX and XI) for the inservice
inspection program and the repair/replacement program.
ii)
EPRI and industry standards referenced in the procedures used to perform the
SGT eddy current examination.
Inspector Contact Information:
L.E. Ellershaw
Senior Reactor Inspector
Reactor Inspector
817-860-8127
817-276-6507
lee1@nrc.gov
stm@nrc.gov
Mailing Address:
US NRC Region IV
Attn: L. Ellershaw
611 Ryan Plaza Drive, Suite 400
Arlington, TX 76011