ML112200187

IR 05000483-11-005, on 10/17/2011 - 10/28/2011, Callaway Plant

ML112200187
Person / Time
Site:	Callaway
Issue date:	08/04/2011
From:	Greg Werner NRC/RGN-IV/DRS/PSB-2
To:	Heflin A Union Electric Co
References
IR-11-005
Download: ML112200187 (11)

See also: IR 05000483/2011005

Text

UNITED STATES

NU CLE AR RE G ULAT O RY CO M M I S S I O N

R E GI ON I V

612 EAST LAMAR BLVD , SU ITE 400

AR LIN GTON , TEXAS 76011-4125

August 4, 2011

Mr. Adam C. Heflin, Senior Vice

President and Chief Nuclear Officer

Union Electric Company

P.O. Box 620

Fulton, MO 65251

SUBJECT: CALLAWAY PLANT - NOTIFICATION OF INSPECTION (NRC INSPECTION

REPORT 05000483/2011005) AND REQUEST FOR INFORMATION

Dear Mr. Heflin:

From October 17 to October 28, 2011, reactor inspectors from the Nuclear Regulatory

Commissions (NRC) Region IV office will perform the baseline inservice inspection at your

Callaway Plant, using NRC Inspection Procedure 71111.08, Inservice Inspection Activities.

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), due by September 26, 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. Steve Petzel 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 Dustin Reinert at (817) 860-8244 (dustin.reinert@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

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.

Union Electric Company -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/

Gregory E. Werner, Chief

Plant Support Branch 2

Division of Reactor Safety

Docket: 50-483

License: NPF-30

Enclosure:

Inservice Inspection Document Request

Distribution via ListServ for Callaway Plant

Union Electric Company -3-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

Acting DRP Deputy Director (Jeff.Clark@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

Acting DRS Deputy Director (Robert.Caldwell@nrc.gov)

Senior Resident Inspector (David.Dumbacher@nrc.gov)

Branch Chief, DRP/B (Geoffrey.Miller@nrc.gov)

Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)

Project Engineer, DRP/B (Nestor.Makris@nrc.gov)

CWY Administrative Assistant (Dawn.Yancey@nrc.gov)

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

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

Project Manager (Mohan.Thadani@nrc.gov)

Acting Branch Chief, DRS/TSB (Dale.Powers@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:

RIV/ETA: OEDO (John.McHale@nrc.gov)

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

SUNSI Review Completed: ___Y___ ADAMS: 7 Yes No Initials: __DRR___

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

R:\_REACTORS\_CW\2011\CW2011005-ISI RFI LTR-drr.doc ML112200187

RI:EB1 RI:EB1 C:PSB2

D. Reinert A. Fairbanks G. Werner

/RA/ /RA/ /RA/

08/03/2011 08/03/2011 08/04/2011

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

INSERVICE INSPECTION DOCUMENT REQUEST

Inspection Dates: October 17 through October 28, 2011

Inspection Procedures: IP 71111.08 Inservice Inspection (ISI) Activities

Inspectors: Dustin Reinert, Reactor Inspector (Lead Inspector - ISI)

Abin Fairbanks, 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 Dustin Reinert, by

September 26, 2011, 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 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 planned for Class 1 & 2 systems and

containment, performed as part of your ASME Section XI, risk informed (if

applicable), and augmented inservice inspection programs during the

upcoming outage;

Provide a status summary of the nondestructive examination 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.); and

-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).

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 nondestructive examination 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 nondestructive examination reports

with relevant conditions in the reactor pressure vessel head penetration nozzles

that have been accepted for continued service. The list of nondestructive

examination reports should include a brief description of the structures, systems,

or components where the relevant condition was identified.

d) A list with a brief description (e.g., system, material, pipe size, weld number, and

nondestructive examinations 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 structures, systems, or

components 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 inservice

inspection, welding, and Alloy 600 programs.

A.2 Reactor Pressure Vessel Head

a) Provide the detailed scope of the planned nondestructive examinations of the

reactor vessel head which identifies the types of nondestructive examination

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)

-2- Enclosure

b) A list of the standards and/or requirements that will be used to evaluate

indications identified during nondestructive examination 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

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 Steam Generator Tube Inspections

a) A detailed schedule of:

i) Steam generator tube inspection, data analyses, and repair activities for

the upcoming outage

ii) Steam generator secondary side inspection activities for the upcoming

outage

b) Please provide a copy of your steam generator inservice 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 Technical Specification Task Force Traveler TSTF-449, Steam

Generator Tube Integrity, please provide copies of your correspondence with the

NRC regarding deviations from the standard technical specifications.

d) Copy of steam generator history documentation given to vendors performing

eddy current testing of the steam generators during the upcoming outage.

-3- Enclosure

e) Copy of steam generator eddy current data analyst guidelines and site validated

eddy current technique specification sheets. Additionally, please provide a copy

of EPRI Appendix H, Examination Technique Specification Sheets, qualification

records.

f) Identify and quantify any steam generator tube leakage experienced during the

previous operating cycle. Also provide documentation identifying which steam

generator 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) Provide copies of your most recent self assessments of the steam generator

monitoring, loose parts monitoring, and secondary side water chemistry control

programs.

i) Indicate where the primary, secondary, and resolution analyses are scheduled to

take place.

j) Provide a summary of the scope of the steam generator tube 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 Additional Information Related to all Inservice Inspection Activities

a) A list with a brief description of inservice inspection, 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 example, a list based upon data base searches using

key words related to piping or steam generator tube degradation such as:

inservice inspection, 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:

Inservice inspection (examination, planning)

Containment exams

Reactor pressure vessel head exams

Snubbers and supports

Repair and replacement program

Licensing

Site welding engineer

Boric acid corrosion control program

Steam generator inspection activities (site lead and vendor contact)

-4- Enclosure

B. Information to be Provided Onsite to the Inspector(s) at the Entrance Meeting (October

17, 2011):

B.1 Inservice Inspection / Welding Programs and Schedule Information

a) Updated schedules for inservice inspection/nondestructive examination 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 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 used to fabricate the welds;

vi) Copies of procedure qualification records supporting the weld procedures

from B.1.b.v;

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

records 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 radiographic testing 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); and

xii) Copies of nondestructive examination personnel qualifications (Visual

inspection, penetrant testing, ultrasonic testing, radiographic testing), as

applicable.

-5- Enclosure

c) For the inservice inspection 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 nondestructive examination reports with relevant conditions on Code

Class 1 and 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 inservice inspection

program manual and plan for the current Interval.

f) For the nondestructive examinations selected by the inspectors from section A of

this enclosure, provide a copy of the nondestructive examination procedures

used to perform the examinations (including calibration and flaw

characterization/sizing procedures). For ultrasonic examination procedures

qualified in accordance with ASME 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 nondestructive

examination personnel qualification records.

B.2 Reactor Pressure Vessel Head

a) Provide the nondestructive 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

ii) Reactor pressure vessel head insulation configuration

Note: The drawings listed above should include fabrication drawings for

the nozzle attachment welds as applicable.

c) Copy of nondestructive examination 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).

-6- Enclosure

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 report(s) that demonstrates the detection

capability of the nondestructive examination 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 report(s).

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 Steam Generator Tube Inspections

a) Copies of the Examination Technique Specification Sheets 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 steam generators.

c) Please provide a copy of the eddy current testing procedures used to perform the

steam generator tube 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 steam generator tube 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 steam generator 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 steam generator tube eddy current examination

Inspector Contact Information:

Dustin Reinert Abin Fairbanks

Reactor Inspector Reactor Inspector

817-860-8244 817-860-8158

dustin.reinert@nrc.gov abin.fairbanks@nrc.gov

Mailing Address:

US NRC Region IV

Attn: Dustin Reinert

612 E. Lamar Blvd, Suite 400

Arlington, TX 76011

-8- Enclosure