ML112580356

Request for Additional Information - Fermi 2 - Request for Relief - Use of BWRVIP Guidelines in Lieu of Specific ASME Code Requirements - TAC ME6765

ML112580356
Person / Time
Site:	Fermi
Issue date:	09/12/2011
From:	Mahesh Chawla Plant Licensing Branch III
To:	Hassoun A Detroit Edison
Mahesh Chawla, LPL3-1, 415-8371
References
TAC ME6765
Download: ML112580356 (2)

Text

From: Chawla, Mahesh Sent: Monday, September 12, 2011 5:12 PM To: Alan I Hassoun Cc: Cheruvenki, Ganesh; Mitchell, Matthew; Pascarelli, Robert; Lingam, Siva; Boyle, Patrick

Subject:

Request for Additional Information - Fermi 2 - Request for Relief - Use of BWRVIP Guidelines in Lieu of Specific ASME Code Requirements -

ME6765 By letter dated July 28, 2011 (ADAMS Accession No. ML112101480), Detroit Edison Company (the licensee) submitted above relief request for Fermi 2. In order to proceed with the review of this request, the NRC staff is requesting following additional information. Please arrange a teleconference with the NRC staff to discuss this information:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO RELIEF REQUEST RR-A39 FERMI, UNIT 2 REACTOR VESSEL INTERNAL COMPONENTS DOCKET NOS. 50-341 By letter dated July 28, 2011, Detroit Edison (the licensee) submitted Relief Request RR-A-39 for Fermi, Unit 2. The licensee proposed to use Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines as an alternative to certain requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for in-service inspection (ISI) of reactor vessel internal (RVI) components. The staff has reviewed the information the licensee provided that supports the proposed relief request and has the following questions:

(1) In a letter dated October 1, 2003, Entergy Nuclear Operations Inc. (Entergy), the licensee of Vermont Yankee Nuclear Power Station (VYNPS), submitted a similar relief request in which the licensee proposed to implement the BWRVIP guidelines in lieu of ASME Section XI requirements for the VYNPS=s RVI components. In a supplemental letter dated January 22, 2004, (ADAMS-Accession Number ML040690734), Entergy submitted details of the inspections for the RVI components that are consistent with the BWRVIP inspection guidelines. The staff, in its safety evaluation (SE) dated September 19, 2005, approved VYNPS=s relief request.

The staff requests that the licensee provide inspection requirements and inspection frequencies applicable for the third ISI interval for Fermi, Unit 2 similar to those addressed in VYNPS=s supplemental letter (ADAMS-Accession Number ML040690734).

(2) The staff requests that the licensee make a commitment that it will implement the requirements specified in the BWRVIP-94 report, AProgram Implementation Guidelines,@ for Fermi, Unit 2. Specifically, the BWRVIP-94 report states that where guidance in existing BWRVIP documents has been supplemented or revised by subsequent correspondence approved by the BWRVIP Executive Committee, the most current approved guidance will be implemented. A similar commitment was made by Entergy for VYNPS in its relief request dated October 1, 2003 (ADAMS-Accession Number ML032810440).

(3) The staff requests that the licensee identify whether there are any furnace-sensitized stainless steel vessel attachment welds associated with the RVI components in Fermi, Unit 2. It is requested that the licensee provide an explanation regarding the type of inspection program and any additional augmented inspection program that are implemented for any existing furnace-sensitized stainless steel attachment welds in Fermi, Unit 2.

(4) The staff requests that the licensee include the following BWRVIP reports in Section 5.0 of the submittal dated July 28, 2011.

BWRVIP-138, ABWRVIP Updated Jet Pump Beam Inspection and Flaw Evaluation.@

BWRVIP-139, BWR Vessel Internals Project, Steam Dryer Inspection and Flaw Evaluation Guidelines.

BWRVIP-183, BWR Vessel Internals Project, Top Guide Grid Beam Inspection and Flaw Evaluation Guidelines.

(5) The staff requests that the licensee confirm whether NUREG-0619, ABWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking,@ will be used for the inspection of feedwater sparger tee welds and feedwater sparger piping brackets. If not, provide alternative methods for inspecting these components.

(6) In Table 1 of Enclosure 1 of the submittal dated July 28, 2011, the licensee did not provide inspection criteria for the shroud support leg weld (H12) which requires inspection per the requirements specified in the staff=s SE for the BWRVIP-38 report, ABWR Vessel Internal Project, BWR Shroud Support Inspection and Flaw Evaluation Guidelines.@ However, the staff=s final SE for the BWRVIP-38 report (ML #003735498) indicates that when inspection tooling and methodologies are developed that allow the welds in the lower plenum to be accessible, the guidelines will state that the licensee will inspect these welds with the appropriate NDE methods in order to establish a baseline for these welds. Consistent with these requirements, the staff, therefore, requests that the licensee revise Table 1 of Enclosure 1 of the submittal dated July 28, 2011, to include a commitment that the shroud support leg weld H12 will be inspected when the inspection tooling and methodologies permit such an inspection.

(7) The staff requests that the licensee shall include a reference to BWRVIP-25, "BWR Core Plate Inspection and Flaw Evaluation Guidelines, in the row designated as ASME item B13.10 in Table 1 of Enclosure 1 of the submittal dated July 28, 2011.

(8) On pages 11 and 12 of Enclosure 3 of the submittal dated July 28, 2011, the licensee stated that per the BWRVIP analyses performed in 2003 and 2006, no inspections were performed on core plate rim bolts since refueling outage (RF08). With regard to this issue, the staff requests that the licensee provide a brief summary of the justification that was used for not performing the inspections and explain how the deviation was dispositioned for these bolts as required by BWRVIP Letter 2010-243. .

(9) According to Section 2.0 of BWRVIP-76, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines, core shroud welds shall be inspected every 6 years when the enhanced visual test (EVT-1) method is used for one-sided weld inspections, and shall be inspected every 10 years when the subject welds are examined with the ultrasonic test (UT) method. The inspection frequency for the core shroud welds (H1 through H7) as indicated in Table 1 of Enclosure 1 of the submittal dated July 28, 2011, is not consistent with the aforementioned requirement.

Therefore, the staff requests that the licensee revise the inspection frequency requirement for the subject welds in Table 1 of Enclosure 1 of the July 28, 2011 submittal. Inspection criteria for H8 and H9 welds should be specified in Table 1 of Enclosure 1 of the submittal dated July 28, 2011.

(10) Identify the welds that were made with Alloy182 weld electrode in Fermi, Unit 2 RVI components. Since Alloy 182 welds are prone to intergranular stress corrosion cracking, the licensee is requested to provide the history of inspections and the results of these inspections of these welds, and subsequent examination criteria if cracking was found in these welds.