ML13127A279
| ML13127A279 | |
| Person / Time | |
|---|---|
| Site: | Fermi |
| Issue date: | 04/24/2012 |
| From: | Matthew Mitchell NRC/NRR/DCI |
| To: | Robert Pascarelli Plant Licensing Branch III |
| References | |
| FOIA/PA-2013-0030, TAC ME6765 | |
| Download: ML13127A279 (4) | |
Text
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MEMORANDUM TO:
FROM:
SUBJECT:
Robert J. Pascarelli, Chief Plant Licensing Branch I11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Matthew A. Mitchell, Chief Vessels and Internals Integrity Branch Division of Component Integrity Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR RELIEF FOR FERMI, UNIT 2 REACTOR VESSEL INTERNAL COMPONENTS (TAC NO. ME6765)
By letter dated July, 28, 2011, Detroit Edison (the licensee) submitted its ten year interval inservice inspection (ISI) program plan Relief Request for Fermi, Unit 2. The licensee's submittal proposes to use various Boiling Water Reactor Vessel and Internals Project guidelines as an alternative to certain requirements of Section Xl of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code for ISI of reactor pressure vessel internal components.
The staff requires further information to complete its assessment of the subject relief request. In the attached request for additional information, the staff has listed the outstanding questions.
Docket No.:
50-341
Enclosure:
Request for Additional Information CONTACT: Ganesh S. Cheruvenki, DCI/CVIB (301) 415-2501
,1 Bilt_
ML OFFICE NRR/DCI/CPNB NRR/DCI/CPNB NAME GCheruvenki MMitchell DATE
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/11
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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 PFr-ram-Proiect (BWRVIP) guidelines as an alternative to certain requirements of Section X1 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 the-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 the-VYNPS's relief request.
The staff, requeststhat the..liensee provide inspection requirements.and.inspection frequencies for Fermi;' Unit 2 similar to "those addressed inVYNPS's supplemental'Ietter (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, "Program Implementation Guidelines," for all its BWR units. 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 stafftiequests that thellicensee identify whether there are anywfurnace-sensitized stainless steel vessel attachment.welds associated with theRVI, components inF..ermi, Unit 2. It is requested that the licensee.- provide an r'explanation regarding:the.type of inspection, program and any additional augmented inspection program..that are implemented forany 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, "BWRVIP Updated Jet Pump Beam Inspection and Flaw Evaluation."
BWRVIP-139, "BWR Vessel Internals Project, Steam Dryer Inspection and Flaw Evaluation Guidelines."
- -d Commentp[31]: How far intothe futumre? 'Until..
the end ofthe interval?
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.- Comment [32]: Any BWRvIP guidelin es for L this?.
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ENCLOSURE 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, "BWR 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.
(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, "BWR Vessel Internal Project, BWR Shroud Support Inspection and Flaw Evaluation Guidelines."
However, the staff's final SE for the BWRVIP-38 report IML #?) 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 should include a reference to the-BWRVlPe..25 CoBWRCore Plate Inspection and Flaw Evaluation.Guidelines,"'jkep4 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 regards 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 the-BWRVIP Letter 2010-2437-.w'as dispcsitoGned for these bolit.
(9) According to Section 2.0 of the-BWRVlP-76. :'BWR Core Shroud Inspection and Flaw Evaluation Guidelines4epG4," 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 of thesubmittal dated July 28, 2011.
(10) Identify the welds that werenmade~with l4, 3ee:Allov182 weld electrode in Fermi, Unit.2 RVI components. Since Ally 182 welds are prone.to interoranular stress corrosion crackinql.GSG, the6licensee 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 weldsI
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.-Comment [33]: Explain why you think they need to.,
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..-Comment [14]: Don't the BWRVIP guidelines take into account whether welds are Alloy 182?
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