ML082261495
| ML082261495 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/13/2008 |
| From: | Russ Bywater Region 4 Engineering Branch 1 |
| To: | Blevins M Luminant Generation Co |
| References | |
| IR-08-005 | |
| Download: ML082261495 (12) | |
See also: IR 05000445/2008005
Text
UNITE D S TATES
NUC LEAR RE GULATOR Y C OMMIS SI ON
R EG I O N I V
612 EAST LAMAR BLVD , SU ITE 400
AR L IN GTON , TEXAS 7 6 011 - 4125
August 13, 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, UNIT 1- NOTIFICATION OF
INSPECTION (NRC INSPECTION REPORT 05000445/2008005) AND
REQUEST FOR INFORMATION
Dear Mr. Blevins:
From September 29 to October 10, 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 1, using NRC Inspection Procedure 71111.08 and
Temporary Instruction 2515/172, "Reactor Coolant System Dissimilar Metal Butt Welds."
Experience has shown that this inspection is a resource intensive inspection 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) identified 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 Kidwell 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 Kelly Clayton at (817) 860-8216 (Kelly.Clayton@nrc.gov).
Luminant Generation Company, LLC -2-
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 NRCs 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
Licenses: NPF-87
Enclosure: Request for Information
cc:w/enclosure
Mr. 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
County Judge
P.O. Box 851
Glen Rose, TX 76043
Mr. Richard A. Ratliff, Chief
Bureau of Radiation Control
Texas Department of Health
1100 West 49th Street
Austin, TX 78756-3189
Environmental and Natural
Resources Policy Director
Office of the Governor
P.O. Box 12428
Austin, TX 78711-3189
Luminant Generation Company, LLC -3-
Mr. Brian Almon
Public Utility Commission
William B. Travis Building
P.O. Box 13326
1701 North Congress Avenue
Austin, TX 78701-3326
Ms. Susan M. Jablonski
Office of Permitting, Remediation
and Registration
Texas Commission on
Environmental Quality
MC-122
P.O. Box 13087
Austin, TX 78711-3087
Anthony Jones
Chief Boiler Inspector
Texas Department of Licensing
And Regulation
Boiler Division
E.O. Thompson State Office Building
P.O. Box 12157
Austin, TX 78711
Luminant Generation Company, LLC -4-
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov )
DRP Director (Dwight.Chamberlain@nrc.gov)
DRP Deputy Director (Anton.Vegel@nrc.gov )
DRS Director (Roy.Caniano@nrc.gov )
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (John.Kramer@nrc.gov)
Resident Inspector (Brian.Tindell@nrc.gov )
Branch Chief, DRP/A (Claude.Johnson@nrc.gov
Senior Project Engineer, DRP/A (Thomas.Farnholtz@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov )
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov )
RITS Coordinator (Marisa.Herrera@nrc.gov )
Mark Cox, OEDO RIV Coordinator (Mark.Cox@nrc.gov )
ROPreports
CP Site Secretary (Sue.Sanner@nrc.gov )
SUNSI Review Completed: ________ ADAMS: Yes No Initials: ______
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
S:DRS:/REPORTS/CP Request Info ltr.KDC ML
EB1 EB1 C:EB1
KDClatyon MRBloodgood RLBywater
/RA/ /RA/ /RA/
8/11/08 8/11/08 8/13/08
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
INSERVICE INSPECTION DOCUMENT REQUEST
Inspection Dates: September 29, 2008 - October 10, 2008
Inspection Procedures: IP 71111.08 "Inservice Inspection (ISI) Activities"
TI 2515/172 "Reactor Coolant System Dissimilar Metal Butt Welds"
Inspectors: K. Clayton, Senior Reactor Inspector (Lead Inspector - ISI)
M. Bloodgood, Reactor Inspector
A. Information Requested for the In-Office Preparation Week
The following information (Section A of this enclosure) should be sent to the Region IV
office in hard copy or electronic format (ims.certrec.com preferred), in care of K. Clayton,
by September 22, 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 day
indicated in this request. *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)
iv) Examinations planned as part of your Boric Acid Corrosion Control
Program (Mode 3 walkdowns, bolted connection walkdowns, etc.)
-1- Enclosure
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 penetrate,
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)
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).
-2- Enclosure
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.
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).
-3- Enclosure
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 Materials Reliability (MRP-139) Program Activities (TI-172)
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 should be available for review.
e) A list and schedule of any stress improvement (SI) activities planned for the
upcoming refueling outage. If none are scheduled then qualification reports for
any SIs previously performed should be available for review.
f) Documentation and description of how the baseline and inservice inspection
specifications in MRP-139 are satisfied at your facility.
-4- Enclosure
A.6 Additional information related to all ISI activities
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 1). 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
(September 29, 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)
-5- Enclosure
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 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
-6- Enclosure
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 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 (specifically 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.
-7- Enclosure
B.5 Codes and Standards
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:
Senior Reactor Inspector
817-860-8216
Kelly.Clayton@nrc.gov
Mailing Address:
US NRC Region IV
Attn: K. Clayton
612 E. Lamar Blvd., Suite 400
Arlington, TX 76011
-8- Enclosure