ML110910327

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Verbal Authorization, Request for Relief from Code Case N-722 Visual Examination of the Reactor Vessel Hot-Leg Nozzle-to-Safe-End Dissimilar Metal Welds, 4th 10-Year Inservice Inspection Interval
ML110910327
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 04/05/2011
From: Lynnea Wilkins
Plant Licensing Branch IV
To: Markley M
Plant Licensing Branch IV
References
TAC ME4541
Download: ML110910327 (5)


Text

April 5, 2011 MEMORANDUM TO: Docket File FROM: Lynnea Wilkins, Project Manager /RA/

Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

FORT CALHOUN STATION, UNIT NO. 1 -

SUMMARY

OF CONFERENCE CALL ON MARCH 30, 2011, RE: VERBAL AUTHORIZATION OF RELIEF REQUEST RR-12 FROM CODE CASE N-722 VISUAL EXAMINATION (VE) OF THE REACTOR VESSEL HOT LEG NOZZLE TO SAFE END DISSIMILAR METAL WELDS (TAC NO. ME4541)

By letter dated August 16, 2010, as supplemented by letters dated January 14 and March 4, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102300679, ML110200205, and ML110670226, respectively), Omaha Public Power District (OPPD, the licensee), requested approval by the U.S. Nuclear Regulatory Commission (NRC) of Relief Request Number RR-12, Request for Relief from Code Case N-722 Visual Examination (VE) of the Reactor Vessel Hot Leg Nozzle to Safe End Dissimilar Metal Welds, for Fort Calhoun Station, Unit 1 (FCS). Pursuant to paragraph 50.55a(a)(3)(i) of Title 10 of the Code of Federal Regulations (10 CFR), OPPD requested NRC approval of an alternative to the visual examination requirements of American Society of Mechanical Engineers (ASME) Code,Section XI, Code Case N-722, Additional Examinations for PWR Pressure Retaining Welds in Class 1 Components Fabricated With Alloy 600/82/182 Materials,Section XI, Division 1.

The licensee requested relief from the 10 CFR 50.55a(g)(6)(ii)(E) requirement to perform a bare metal visual inspection of reactor pressure vessel outlet nozzle to safe end dissimilar metal welds in accordance with ASME Code Case N-722. OPPD requested this relief for the spring 2011 and fall 2012 refueling outages at FCS. The NRC staff found that analyses submitted by the licensee may not support the full 51 calendar months requested under RR-12.

However, the analysis does support relief during the spring 2011 refueling outage for one operating cycle.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the Code requirements. Therefore, in accordance with 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes the licensees proposed alternative, RR-12 at FCS for the spring 2011 refueling outage, as discussed during a conference call with the licensee on March 30, 2011. A summary of the verbal authorization is enclosed.

The NRC staff will proceed with completion of the written safety evaluation for RR-12. The staff may ask additional clarification questions to complete its written safety evaluation, if necessary.

The written safety evaluation should be issued within 150 days in accordance with the Office of Nuclear Reactor Regulation office instructions.

NRC

Participants:

M. Markley, NRR/DORL/LPL4, Branch Chief T. Lupold, NRR/DCI/CPNB, Branch Chief J. Collins, NRR/DCI/CPNB, Senior Materials Engineer B. Singal, NRR/DORL/LPL4, Project Manager L. Wilkins, NRR/DORL/LPL4, Project Manager Licensee

Participants:

J. Herman, Division Manager - Nuclear Engineering B. Hansher, Supervisor - Nuclear Licensing B. Lisowyj, Project Manager - Materials J. Brandeau, Project Manager - Nuclear Projects M. Edwards, Nuclear Licensing Engineer Docket No. 50-285

Enclosure:

As stated

ML110910327 *via email dated OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DCI/CPNB/BC NRR/LPL4/BC NRR/LPL4/PM MMarkley (BSingal NAME LWilkins JBurkhardt TLupold* for) LWilkins DATE 4/1/11 4/1/11 3/31/11 4/1/11 4/5/11

SUMMARY

OF CONFERENCE CALL ON MARCH 30, 2011 VERBAL AUTHORIZATION FROM ASME CODE CASE N-722 VISUAL EXAMINATION OF THE REACTOR VESSEL HOT LEG NOZZLE TO SAFE END DISSIMILAR METAL WELDS OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT 1 DOCKET NO. 50-285 By letter dated August 16, 2010, as supplemented by letters dated January 14 and March 4, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102300679, ML110200205, and ML110670226, respectively), Omaha Public Power District (OPPD, the licensee), requested relief (RR-12) from the 10 CFR 50.55a(g)(6)(ii)(E) requirement to perform a bare metal visual inspection of reactor pressure vessel outlet nozzle to safe end dissimilar metal welds in accordance with ASME Code Case N-722.

OPPD requested this relief for the spring 2011 and fall 2012 refueling outages (RFO) at Fort Calhoun Station, Unit 1 (FCS). OPPD stated that a best effort visual examination performed during each RFO coupled with favorable inspection data from the 2003, 2008, and 2009 weld examinations, use of zinc addition, and a supporting deterministic crack growth analysis would provide an acceptable level of quality and safety in lieu of the required bare metal visual examination.

The bare metal visual examination requirements for dissimilar metal butt welds provide defense-in-depth non-destructive examination. Plant-specific analysis can be used to provide a basis for inspection relief if the bare metal visual inspection presents a significant hardship on a licensee.

In 2010, the NRC and industry groups worked on the development of MRP-287, Materials Reliability Program: Primary Water Stress Corrosion Cracking (PWSCC) Flaw Evaluation Guidance, to develop an acceptable standard methodology for deterministic flaw analysis.

While the report was not complete by the time of the issuance of OPPDs relief request, OPPD did use the report to support its basis for this relief request. The staff reviewed OPPDs deterministic assessment as well as supporting inspection results, zinc mitigation and best effort visual examination alternative for authorization of RR-12.

By letter dated January 14, 2011, OPPD provided information on the hardship involved with performing the required bare metal visual examination, additional details on zinc addition, several references for the flaw evaluation, and clarification on previous examination data. As the hot-leg dissimilar metal welds are in sandboxes, the NRC staff concluded that OPPD had a sufficient basis for hardship. However, the staff found insufficient time available to evaluate the effectiveness and credit the zinc benefit for stress-corrosion cracking to support this relief request. Additionally, the staff concluded that OPPDs plant-specific stress analysis used the incorrect safe-end length in the model, which is a critical part of the flaw evaluation. The NRC Enclosure

staff then reviewed OPPDs stress analysis without the effect of a safe end and used OPPDs methodology to develop a new flaw analysis. The staff found this analysis may not support the full 51 calendar months requested under RR-12. However, the analysis does support relief during the spring 2011 RFO for one operating cycle.

In order to validate OPPDs flaw analysis and support relief through to the spring 2014 RFO, the NRC staff would need OPPD to use the as-build dimensions, in accordance with Item 1, Geometry and Materials, of Section 3.6, Attributes of an Acceptable Residual Stress Analysis, of MRP-287 to develop a robust flaw analysis under RR-12. Completion of this analysis would be expected to go beyond the upcoming spring 2011 refueling outage at FCS.

However, since the NRC staffs review of OPPDs current analysis shows reasonable assurance of leak tightness for the reactor pressure vessel outlet nozzle to safe end dissimilar metal welds until the fall 2012 RFO, the staff finds sufficient basis to authorize RR-12 for the spring 2011 RFO.

Therefore, given the hardship of the location of both reactor pressure vessel outlet nozzle to safe end dissimilar metal welds being in sandboxes, OPPDs best effort visual inspection during the spring 2011 RFO, and the flaw analysis performed to date, the NRC staff concludes that OPPD has provided sufficient technical basis to find that compliance with the current requirements of 10 CFR 50.55a(g)(6)(ii)(E) for a bare metal visual examination of the reactor pressure vessel outlet nozzle to safe end dissimilar metal welds at FCS during the spring 2011 RFO would cause an unnecessary hardship or unusual difficulty on the licensee without a compensating increase in the level of quality and safety.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the Codes requirements. Therefore, in accordance with 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes the licensees proposed alternative, RR-12 as supplemented by letters dated January 14 and March 4, 2011, at FCS for the spring 2011 RFO for one operating cycle.

The NRC staff asked if the licensee intended to supplement the existing application in order for the staff to complete its review. The licensee stated that it does not plan to supplement the existing application and will address the NRC staffs concerns in new application for the fall 2012 RFO.

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.