ML100560603

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Notification of Inspection (IR 05000445-10-003) and Request for Information
ML100560603
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 02/24/2010
From: Greg Werner
NRC/RGN-IV/DRS/PSB-2
To: Flores R
Luminant Generation Co
References
IR-10-003
Download: ML100560603 (11)


See also: IR 05000445/2010003

Text

UNITED STATES

NUC LE AR RE G UL AT O RY C O M M I S S I O N

R E GI ON I V

612 EAST LAMAR BLVD , SU I TE 400

AR LI N GTON , TEXAS 76011-4125

February 24, 2010

Rafael Flores, Senior Vice President

and Chief Nuclear Officer

Attention: Regulatory Affairs

Luminant Generation Company LLC

P.O. Box 1002

Glen Rose, TX 76043

SUBJECT: Comanche Peak Steam Electric Station - NOTIFICATION OF INSPECTION

(NRC INSPECTION REPORT 05000445/2010003) AND REQUEST FOR

INFORMATION

Dear Mr. Flores:

From April 5-9 and April 19-23, 2010, 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,

"Inservice Inspection Activities," and TI 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. Barnet 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 Wayne Sifre at (817) 860-8193 (wayne.sifre@nrc.gov) or Matthew

Young at (817) 276-6545 (matt.young@nrc.gov).

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

Luminant Generation Company LLC -2-

requirements were approved by the Office of Management and Budget, Control

Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control

number.

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/

Gregory E. Werner, Chief

Plant Support Branch 2

Division of Reactor Safety

Docket: 50-445

License: NPF-87

Enclosure:

Inservice Inspection Document Request

Mike Blevins, Chief Operating Officer

Luminant Generation Company LLC

Comanche Peak Steam Electric Station

P.O. Box 1002

Glen Rose, TX 76043

Mr. Fred W. Madden, Director

Oversight and 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

Luminant Generation Company LLC -3-

Mr. Richard A. Ratliff, Chief

Bureau of Radiation Control

Texas Department of Health

P.O. Box 149347, Mail Code 2835

Austin, TX 78714-9347

Environmental and Natural

Resources Policy Director

Office of the Governor

P.O. Box 12428

Austin, TX 78711-3189

Honorable Walter Maynard

County Judge

P.O. Box 851

Glen Rose, TX 76043

Mr. Brian Almon

Public Utility Commission

William B. Travis Building

P.O. Box 13326

Austin, TX 78711-3326

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

Chief, Technological Hazards

Branch

FEMA Region VI

800 North Loop 288

Federal Regional Center

Denton, TX 76209

Luminant Generation Company LLC -4-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Chuck.Casto@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 (Wayne.Walker.nrc.gov)

Senior Project Engineer, DRP/A (David.Proulx@nrc.gov)

CP Administrative Assistant (Sue.Sanner@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Balwant.Singal@nrc.gov)

Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEMail Resource

Inspection Reports/MidCycle and EOC Letters to the following:

ROPreports

Only inspection reports to the following:

DRS/TSB STA (Dale.Powers@nrc.gov)

OEDO RIV Coordinator (Leigh.Trocine@nrc.gov)

SUNSI Review Completed: __Y__ ADAMS: 7 Yes No Initials: ____

7 Publicly Available Non-Publicly Available Sensitive 7 Non-Sensitive

R:\REACTORS\CP U1 ISI RFI 2010 - WCS.

SRI:EB1 C:PSB2

W. Sifre G. Werner

/RA/ /RA/

2/18/10 2/24/10

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

INSERVICE INSPECTION DOCUMENT REQUEST

Inspection Dates: April 5-9 and April 19-23, 2010

Inspection Procedures: IP 71111.08 "Inservice Inspection (ISI) Activities"

TI 2515/172 "Reactor Coolant System Dissimilar Metal Butt Welds"

Inspectors: Wayne Sifre, Senior Reactor Inspector (Lead Inspector - ISI)

Matthew Young, 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 Wayne Sifre, by March 22, 2010,

to facilitate the selection of specific items that will be reviewed during the onsite

inspection week. The inspectors 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 inspectors, and

provide subject documentation during the first day of the onsite inspection. If you have

any questions regarding this information request, please call the inspectors 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 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 tests 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 reactor pressure vessel head

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 noncode 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

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

-2- Enclosure

industry or procedural standards which will be used to evaluate potential leakage

and/or flaw indications).

A.3 Boric Acid Corrosion Control Program

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

Boric Acid Corrosion Control Program.

c) Please provide a copy of the most recent self-assessment performed for the

Boric Acid Corrosion Control Program.

A.4 Materials 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, 2009.

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 activities planned for the

upcoming refueling outage. If none are scheduled, then have qualification

reports for any stress improvements previously performed.

f) Documentation and description of how the baseline and ISI specifications in

MRP-139 are satisfied at your facility.

g) A list of weld locations controlled by MRP-139 which includes the MRP-139 weld

category, pre-mitigation volumetric examination date, type of mitigation or stress

improvement, post mitigation volumetric examination date, and plans for future

MRP-139 required examinations.

-3- Enclosure

A.6 Additional information related to all ISI activities

a) A list with a brief description of ISI, Boric Acid Corrosion Control Program, and

steam generator tube 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 steam generator tube degradation such as: ISI,

ASME Code,Section XI, NDE, cracks, wear, thinning, leakage, rust, corrosion,

boric acid, or errors in piping/steam generator tube examinations.

b) Please provide names and phone numbers for the following program leads:

ISI contacts (Examination, planning)

Containment Exams

Reactor Pressure Vessel Head Exams

Snubbers and Supports

Repair and Replacement Program Manager

Licensing Contact

Site Welding Engineer

Boric Acid Corrosion Control Program

B. Information to be provided onsite to the inspectors at the entrance meeting (April 5,

2010):

B.1 ISI/Welding Programs and Schedule Information

a) Updated schedules for ISI/NDE activities, including steam generator tube

inspections, planned welding activities, and schedule showing contingency repair

plans, if available.

b) For ASME Code Class 1 and 2 welds selected by the inspectors 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 welding procedures used to fabricate the welds

vi) Copies of procedure qualification records supporting the welding

procedures from B.1.b.v

vii) Copies of mechanical test reports identified in the procedure qualification

records above

-4- Enclosure

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 welding processes specified in the weld

procedures (at least 6 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 inspectors 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 inspectors 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 activities selected by the inspectors 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

a) Provide the NDE personnel qualification records for the examiners who will

perform examinations of the reactor pressure vessel head.

b) Provide drawings showing the following (if a visual examination is planned for the

upcoming refueling outage):

i) Reactor pressure vessel head and control rod drive mechanism nozzle

configurations

-5- Enclosure

ii) Reactor pressure vessel head 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 reactor pressure vessel head examination.

d) Copy of evaluation or calculation demonstrating that the scope of the visual

examination of the upper head will meet the 95 percent 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 reactor pressure vessel head. 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 for the

reactor pressure vessel head susceptibility ranking.

g) Provide copy of the vendor qualification reports that demonstrates the detection

capability of the NDE equipment used for the reactor pressure vessel head

examinations. Also, identify any changes in equipment configurations used for

the reactor pressure vessel head examinations which differ from that used in the

vendor qualification reports.

B.3 Boric Acid Corrosion Control Program

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 Codes and Standards

a) Ready access to (i.e., copies provided to the inspectors 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 ISI

program and the repair/replacement program

ii) EPRI and industry standards referenced in the procedures used to

perform the steam generator tube eddy current examination

-6- Enclosure

Inspector Contact Information:

Wayne Sifre Matthew Young

Senior Reactor Inspector Reactor Inspector

817-860-8193 817-276-6545

wayne.sifre@nrc.gov matt.young@nrc.gov

Mailing Address:

US NRC Region IV

Attn: Wayne Sifre

612 E. Lamar Blvd, Suite 400

Arlington, TX 76011

-7- Enclosure