ML13305A710

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Forwards Request for Addl Info Re Inservice Insp Program for First 10-yr Insp Interval
ML13305A710
Person / Time
Site: San Onofre  
Issue date: 12/12/1984
From: Knighton G
Office of Nuclear Reactor Regulation
To: Baskin K, Holcombe J
San Diego Gas & Electric Co, Southern California Edison Co
References
NUDOCS 8501070390
Download: ML13305A710 (11)


Text

DEC12 1984 Docket Nos.:

50-361 and 50-362 Mr. Kenneth P. Baskin Mr. James C. Holcombe Vice President CgkSort 4w Vice President -

Power Supply Southern Caita Edison Company San Diego Gas & Electric Company 2244 Walnut Grove Avenue 101 Ash Street Post Office Box 800 Post Office Box 1831 Rosemead, California 91770 San Diego, California.92112 Gentlemen:

Subject:

REQUEST FOR ADDITIONAL INFORMATION ABOUT INSERVICE INSPECTION PROGRAM The NRC staff has conducted a review of the San Onofre 2 and 3 Inservice Inspection Program. We find that additional information is needed to complete our review. The specific information needed is given in the enclosure, which was prepared by our contractor, Science Applications, Inc.

We and our contractor are prepared to discuss the resolution of this issue with you at your convenience.

original signed by George W. Knighton George W. Knighton, Chief Licensing Branch No. 3, Division of Licensing

Enclosure:

As stated cc:

See next page D=I=6FRT I ON '~

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ton 12/11/84 12////84 9501070390 841212 PDR ADOCK 05000361 PDR _

San Onofre Mr. Kenneth P. Baskin Vice President Southern California Edison Company 2244 Walnut Grove Avenue P. 0. Box 800 Rosemead, California 91770 Mr. James C. Holcombe Vice President - Power Supply San Diego Gas & Electric Company 101 Ash Street Post Office Box 1831 San Diego, California 92112 Charles R. Kocher, Esq.

Mr. Mark Medford James A. Beoletto, Esq.

Southern California Edison Company Southern California Edison Company 2244 Walnut Grove Avenue 2244 Walnut Grove Avenue P. 0. Box 800 P. 0. Box 800 Rosemead, California 91770 Rosemead, California 91770 Dr. L. Bernath Manager, Nuclear Department Orrick, Herrington & Sutcliffe San Diego Gas & Electric Company ATTN:

David R. Pigott, Esq.

P. 0. Box 1831 600 Montgomery Street San Diego, California 92112 San Francisco, California 94111 Richard J. Wharton, Esq.

University of San Diego School of Alan R. Watts, Esq.

Law Rourke & Woodruff Environmental Law Clinic Suite 1020 San Diego, California 92110 1055 North Main Street Santa Ana, California, 92701 Charles E. McClung, Jr., Esq.

Attorney at Law Mr. V. C. Hall 24012 Calle de la Plaza/Suite 330 Combustion Engineering, Inc.

Laguna Hills, California 92653 1000 Prospect Hill Road Windsor, Connecticut 06095 Region Administrator-Region V/NRC 1450 Maria Lan/Suite 210 Mr. S. McClusky Walnut Creek, California 92672 Bechtel Power Corporation P. 0. Box 60860, Terminal Annex Los Angeles, California 90060 Resident Inspector, San Onofre NPS c/o U. S. NRC Mr. C. B. Brinkman Post Office Box 4329 Combustion Engineering, Inc.

San Clemente, California 92672.

7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. Dennis F. Kirsh U.S. Nuclear Regulatory Commission - Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

ATTACHMENT REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM San Onofre Unit 2 San Onofre Unit 3 Inservice Inspection Section Materials Engineering Branch By letter dated March 3, 1982 (1) from K. P. Baskin (SCE) to F. Miraglia (NRC), the licensee submitted an inservice inspection (ISI) program for the first 10-year inspection interval for San Onofre Unit 2. In a subsequent letter dated July 5, 1983(2) from K. P. Baskin (SCE) to F. Miraglia (NRC),

the licensee submitted an inservice inspection program for the first 10-year inspection interval for San Onofre Unit 3. The staff will be evaluating these programs and the documents referenced in them and other documents (see attached document review list)..The staff will also use this material to review the sample of welds selected for examination and requests for relief from impractical examinations required by Section XI of the ASME Loi Ir and Pressure V.ssel Code.

TL inservice testing: (IST) portion of the program is not being reviewed as part of this evaluation. If there are any cnaonel relier requests or supporting information that shouic be considered, provide the staff with copies. If they have been previously furnished to the NRC, document by reference.

The folloing questions address the. plans ana inE specific relieT requests.

The questions relate to both plans except where specifically noted.

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1. SONGS-3 Plan, Page 1, Statement of Position There are advantages in having identical plans based on the same edition of the Code for ISI.

The ISI plan for SONGS-3 acknowledges that the utility should be using the 1980 Edition including Addenda through Winter 1980 since the full power license date for SONGS-3 is September 16, 1983. Therefore, in the case of the SONGS-2 and SONGS-3 plans, the staff considers the appropriate edition of the Code to be used is the 1980 Edition with Addenda through Winter 1980. The reasons for this selection are:

1.

10 CFR 50.55a(g)(4)(i) requires that this edition of the Code be applied to SONGS-3.

2. 10 CFR 50.55a(g) permits more recent editions of the Code to be used.

No provisions are included for using older versions of the Code; i.e., the 1980 Edition q,.the Code could be applied to SO;CGS-2 withv'in the scope of 10 CFR 50.55a, whereas 10 CFF, 50.55a contains no provisions for applying the 1977 Edition of

-the Code to SONGS-3.

3. The staff has determined that a common ISI interval start date for essentially identical units at a plant site is acceptable.

In these cases, the startup date was established as the date midway between the license dates.

The applicable edition of Section XI was then determined by 10 CFR 50.55a(g)(4) using

-3 the joint combined startup date. Using this approach for SONGS-2 and SONGS-3, the joint startup date would be March 1983, and the effective edition of the Code would be the 1980 Edition with Addenda through Winter of 1980.

Based on the above, both the SONGS-2 and SONGS-3 ISI plans should be revised to the 1980 Edition of the Code with Addenda through Winter of 1980. As a minimum, 10 CFR 50.55a(g)(4) requires that the IS plan for SONGS-3 comply with the 1980 Edition of the Code with Addenda through Winter of 1980 based on a full-power license date of September 16, 1983(3). Therefore revised ISI plan(s) for SONGS-2 and SONGS-3 should be submitted.

2. Section 4.0 ISI Program Description, Page 7 This section provides a broad overall description of the ISI program and summarizes the Code requirements.

The Code provides examination require mnpts fcr Class 1, Class 2. and Class 3 ecL Tmen-,ts: how.'ev'-.

it is th responsibility of the plant owner to designate equipment classifications.

The San Onofre ISI plans do not address the methods used to specify system boundaries except to state that the scope of the plan is "generally similar" to the preservice examination.

Provide a ciscussion of the basic philosophy used by SCE to establish system boundaries and equipment classifications.

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3. Section 4.2 -

Vessel, Piping and Support Examinations Section 4.2 states that zone drawings, plans and examination data sheets are available to provide qualified examiners with all information necessary to perform the required inspections. In order to determine the acceptabi lity of the sample of welds selected for examination, provide copies of the isometric drawings and data sheets for the reactor coolant pressure boundary and Class 2 components and piping. The material supplied should be sufficiently complete to permit evaluation of the sampling for all Class 1 and 2 systems, including the ECC, RHR and CHR systems and to determine the exemptions used based on IWB-1220 and IWC-1220.

4. Section 4.2 - Vessel, Piping and Support Examinations, Austenitic Materials, Page 8 This section states that volumetric examination of pump casings and valvc i-cnstrutce of austenitic st 1inlEs steel are no schedul E

not be performed unless a suitable examination method is identified during the interval.

The inspection program summary tables given in the plan also indicate that these welds will not be examined. The Minac system developeC by EP'I nas Dern used successfully to radiograpn pump casing welos.

this method been evaluated for examinatioon of pump casing and valve bo&

welds? If the volumetric examinations of pump and valve casing welds ar, not to be conducted, a relief request addressing this area should be subl mitted with a technical justification.

-5 Items B12.10 and B12.30 for pump casing welds and valve body welds under category B-L-1 also require surface examination. Are the surface examina tions required by the Code to be conducted?

5. Sections 1.0 - 8.0 and Appendix A Sections 1.0 through 8.0 describe the San Onofre ISI plan and Appendix.A provides tabular summaries of examinations to be conducted. This material provides an overall description of what is to be done. However, no examina tion procedures were referenced that would allow the staff to determine that suitable procedures are being used to detect service-induced flaws. Will the same procedures used for preservice examinations be used for ISI?

Provide a reference for the procedures to be used for ISI and copies of the ultrasonic testing procedure for the reactor vessel and the piping welds.

6. Appendix A, Ten (10) Year Inservice Insoection Prooram Summar'. Pac: _

No examinations for beltline region welds under category B1.51 "Repair Welds" are scheduled. The staff assumes that the beltline region welds are covered un~v categories B1.10, 81.11 and B1.12 for shell welds.

Confirm that beltline region welds are not scheduled for examination under category B1.51 because material (base metal) weld repairs ex ceeding 10% nominal of the vessel wall were not required.

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7. Appendix A, Ten (10) Year Inservice Inspection Program Summary, Pages 8, 10, 11, 12, 19, etc.

The notation "See Comments" is used on the summary tabulations when apparently reference to a request for relief is the intent. On page 19, for example, less than 25% of the category B-J welds are scheduled for examination, and the note "See Comment" appears in the examination amount column. It is not clear which comment or which relief request applies.

Revise the summary tabulations to reference the appropriate request for relief.

8.

Relief Request No. B-1, Steam Generators, Pressurizer Nozzle-to-shell Welds, Category B-D Relief Request No. B-4, Piping Branch Connections, Category B-J Relief Request No.

C-1, Steam Generators, Secondary Side Nozzle to-shell Weld, Category C-B Relief is requested to examine specific welds from the piping side only in all of the above relief requests. For each of the configurations for which relief is requested, provide an estimate of the percentage of the Code required volume which will be examined.

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9. Relief Request No. B-5, Integrally Welded Atachments, Category B-K-1 Relief Request No. B-6, Class 1 Piping Greater than 1" Nominal Size Class 2 Piping Greater than 4" Nominal Size Relief Request No. C-2, Class 2 Bolting The specific relief requested is not-clear and may not be needed if the ISI plans for SONGS-2 and SONGS-3 are updated to the 1980 Code. These relief requests should be re-evaluated.
10.

Relief Request No. B-7, Pressure Retaining Welds in All Class 1 and Class 2 Piping, Categories B-F,B-J,C-F Relief Request No. B-7 requests relief from the 1/3 volumetric-plus-surface examination with alternative full volumetric examination for applicable F-F.

B-J and C-F welds. The Relief Request, however, does not provide any specific information on the areas for which relief is requested.

Designate the specific welds in categories B-F, B-J and C-F for which volumetric and surface examination will not be conducted in accordancJ with Code requirements:

Also, describe the reason that examination of the Code required volumetric and surface examination is impractical for these areas. If full volumetric examination is to be substituted for partial volumetric and surface examination, state the welds which will be subjected to full volumetric examinations.

References (1)

K. E. Baskin to F. Miraglia, Inservice Inspection and Testing Program for San Onofre Unit 2, March 3, 1982.

(2) SCE to NRC, Inservice Inspection and Testing Program for San Onofre Unit 3, July 5, 1983.

(3) NRC to K. E. Baskin, Amendment No. 8 to Facility Operating License NPF-15 SONGS-3, September 16, 1983.

Southern Californi; Edison -

SCE EVIEW DOCUMENT RECORD Unit(s)

San Onofre Units 2 & 3 Sub 06 & 22 ID nw-mber and Date Author - Peciuient T pe Subject Matter 9111/80 Kroke (Consult.) to SCE Do'.

Preservice Inspection Program Plan -

SONGS-2 and -3 5/10/84 13/6/80 Baskin (SCE) tc Miraglia (NRC Subm.

Responses to NRC Questions; Revised FSAR Sections 5/10/84 1e 1120/81 Baskin (SCE)'r Miraglia (NRC S"bm.

Responses to Open Items and Questions 5/10/84 313/82 Baskin (SCE) to Miraglia (NRC:

Inservice Inspection and Testing Program for SONGS-2 616/82 Baskin (SCE) to Miroinlia (NRC Subm.

Revision 1 to SONGS-2 ISI 5/10/84 715/83 SCE to NRC Subm.

Inservice Inspection and Testing Program Plan, SONGS-3 3/12/84 1W/31/8 Medford (SCE) to Kniahton (NRC)

Inservice Testing Plan Rev. 1. Rev. 6. and Contents page 3/12/84 917/82 Eisenhut (NRC) to Dietch SCE S

n. Amendment No. 7 to Facility Operating License NFP-1O. SONGS-2 __

916/83 NRC to Baskin (SCE)

_Amendment No. 8 to Facility Operating License NFP-15.

SONGS-3