ML15113A364
| ML15113A364 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/13/1997 |
| From: | Hoffman S NRC (Affiliation Not Assigned) |
| To: | Mccollum W DUKE POWER CO. |
| References | |
| TAC-M99092, TAC-M99093, TAC-M99094, TAC-M99143, NUDOCS 9708180160 | |
| Download: ML15113A364 (7) | |
Text
UNITED STATES 0
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 13, 1997 Mr. William R. McCollum, Jr.
Vice President, Oconee Site Duke Power Company P. 0. Box 1439 Seneca, South Carolina 27679
SUBJECT:
LICENSE RENEWAL INSPECTION PROGRAM EXAMPLE FOR OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 (TAC NOS. M99092, M99093, M99094, AND M99143)
Dear Mr. McCollum:
By letter dated May 19, 1997, Duke Power Company (Duke) submitted an example of the level of detail proposed for a license renewal application to describe a new inspection program. Duke indicated that it intends to use this example as a model for creating descriptions of other new inspections that are required to be included in an application. Nuclear Regulatory Commission (NRC) staff review and comment was requested regarding the approach for describing a new inspection and the level of detail provided.
The Enclosure contains the staff comments requested on the example.
The NRC staff's review focused on the format and content to determine if an application, following the form of the example, would contain sufficient information for the staff to begin its technical review. A comprehensive review to determine the completeness or technical adequacy of the example was not performed. However, during its review, the staff identified a number of technical questions that are included in the Enclosure.
These questions are being provided to illustrate the type of information and level of detail expected in future submittals to help minimize the number of staff questions needed when a review of a complete submittal is performed.
9708180160 970813 PDR ADOCK 05000269 G
PR 1111111 111111 1 1 1 1 111 Ill
W. McCollum
-2 The enclosed comments should be considered by Duke when.preparing descriptions of new inspection programs for staff review.
Sincerely, Stephen T. Hoffman, Sr. Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270 and 50-287
Enclosure:
As Stated cc w/encl: See next page R. L. Gill, Duke Power
HARD COPY PUBLIC PDLR R/F DLaBarge, 0-14H25 OEDO RIV Coordinator, 0-17G21 E-MAIL:
S. Collins/F. Miraglia (SJC1/FJM)
R. Zimmerman (RPZ)
M. Slossom (MMS)
S. Weiss (SHW)
S. Hoffman (STH)
S. Meador (SAM)
R. Wessman (RHW)
J. Strosnider (JRS2)
S. Droggitis (SCD)
S. Peterson (SRP)
G. Lainas (GCL)
B. Morris (BMM)
J. Moore (JEM)
G. Mizuno (GSM)
G. Holahan.(GMH)
B. Sheron (BWS)
M. Mayfield (MEM2)
A. Murphy (AJM1)
H. Brammer (HLB)
L. Shao (LCS1)
G. Bagchi (GXB1)
R. Johnson (REJ)
H. Berkow (HNB)
S. Shaeffer (SMS)
PDLR Staff
Oconee Nuclear Station Units 1, 2, and 3 cc:
Mr. Paul R. Newton Mr. Ed Burchfield Duke Power Company, PB05E 422 South Church Street Comp Charlotte, North Carolina 28242-0001 Oconee Nuclear Site P. 0. Box 1439 J. Michael McGarry, III, Esquire Seneca, South Carolina 29679 Winston and Strawn 1400 L Street, NW.
Ms. Karen E. Long Washington, DC 20005 Assistant Attorney General North Carolina Department of Mr. Robert B. Borsum Justice Framatome Technologies P. 0. Box 629 Suite 525 1700 Rockville Pike Rockville, Maryland 20852 Mr. G. A. Copp Licensing - ECO50 Manager, LIS Duke Power Company NUS Corporation 526 South Church Street 2650 McCormick Drive, 3rd Floor Charlotte, North Carolina 28242-0001 Clearwater, Florida 34619-1035 Richard Fry, Director Senior Resident Inspector Division of Radiation Protection U.S. Nuclear Regulatory Commission North Carolina Department of Route 2, Box 610 Environment, Health, and Seneca. South Carolina 29678 Natural Resources P. 0. Box 27687 Regional Administrator, Region II Raleigh, North Carolina 27611-7687 U. S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, S.W., Suite 23T85 Atlanta, Georgia 30303 Max Batavia, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 County Supervisor of Oconee County Walhalla, South Carolina 29621 Ms
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NRC STAFF COMMENTS ON THE DUKE EXAMPLE OF A NEW INSPECTION PROGRAM Following are NRC staff comments on the Duke topic paper and license renewal application new inspection example that were submitted by Duke's letter dated May 19, 1997. Duke requested that the staff review the submittals to determine if the concept used for describing a new inspection is acceptable.
Although the staff's intent was not to perform a technical review of the submittals, a number of technical questions were identified and are included for consideration.
Format and Content
- 1.
When a previously approved report is to be incorporated by reference into an application, Section 4.2.2 of NEI 95-10, Revision 0, discusses the need to verify that the plant is bound by the scope, assumptions, limitations, and conclusions addressed in the report and the staff's associated safety evaluation (SE). The Oconee application should discuss how the Oconee flow meter section is bound by the evaluation contained in BAW-2243, "Demonstration of the Management of Aging Effects for the Reactor Coolant System Piping."
Sufficient details are not provided for the staff to make a finding that the safety evaluation issued for BAW 2243 is applicable and that a one time volumetric inspection is acceptable.
- 2.
Because the topic paper will not be part of the application, applicable background information should be incorporated into the application to facilitate the staff's understanding of the purpose and scope of the new inspection.
- 3.
Section 4.3 of NEI 95-10, Revision 0, describes the elements of a license renewal. inspection program. Duke's proposed inspection example indicates that part of the information will be provided in the future.
However, because Duke proposes this example to be the model for other new inspections, consider a format that discusses each of the elements identified in Section 4.3, indicating, if applicable, that the information will be provided in the future.
- 4.
The Purpose section should identify the specific aging effect for which the one-time inspection is being performed.
- 5.
The last paragraph of the example states that Duke will submit within 12 months after the issuance of a renewed operating license for Oconee, or as included in the Oconee Inservice Inspection Plan for the Fourth Interval, whichever is later, a complete description of the proposed augmented inspection for license renewal of the Alloy 82/182 clad flow Enclosure
-2 meter section of the hot leg. The submittal will also include the additional information to be specified later. This information needs to be provided in the application.
Technical Comments
- 1.
The SE for BAW-2243 specifically references the 1989 edition of the ASME Code (except for Class MC and Class CC which are required to use the 1992 edition and the 1992 addenda) and any use of an alternate edition of the Code at the time of inspection needs to be justified with a 10 CFR 50.59 evaluation or other staff approved justification. The application should describe the inspection program, consistent with the requirements for volumetric inspections under the 1989 edition of the ASME Code,Section XI. or provide a specific reference to the section of this Code (e.g., reference the subsections under ASME,Section XI, Appendix VII, that describe the different applicable portions for a UT demonstration, and the different subsections under Appendix VII for UT qualification). The application should adequately describe the intended program such that the staff will be able to make a finding that there is reasonable assurance that primary water stress corrosion cracking will not occur at Oconee during years 40 to 60.
- 2.
The applicant plans to perform the one-time inspection of Alloy 82/182 clad flow meter section of one hot leg during the first or second period of the fourth interval which is an indication that the inspection will be performed prior to year 34 of the current operating term. The SE for BAW-2243 states that the inspection should be performed "near the end of the current licensing term."
To meet this SE action, the applicant should schedule the volumetric exam during the last two periods of the fourth interval.
- 3.
The SE for BAW-2243 specifies use of the 1989 edition of the ASME Code.
The application should either commit to the 1989 edition of the ASME Code or, alternately, provide justification for any deviations from this referenced code edition.
- 4.
The application states that "...there is no indication that the potential cracking is a concern during the current 40 year operating license."
The topic paper states that "Alloy 82/182 cladding may have some susceptibility to primary water stress corrosion cracking..." The apparent contradictory statements should be revised.
W. McCollum
- 2 The enclosed comments should be considered by Duke when preparing descriptions of new inspection programs for staff review.
Sincerely, Original signed by:
Stephen T. Hoffman, Sr. Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270 and 50-287
Enclosure:
As Stated cc w/encl:
See next page R. L. Gill, Duke Power DISTRIBUTION:
See attached DOCUMENT NAME: A:\\DUK99092.LTR (S.
Hoffman/LLM.Disk)
To receive a copy of this document, indicate in the box: "C" = Copy without attachmentlenclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE SPM:PDLR E-41 dSC: PDLR D:PDLR
, L NAME SHoffman:av P. T. Ky CGrimes (S)
DATE 08/I2797 08/)3/97 08/i 97 OFFICIAL RECORD COPY