ML15264A521
| ML15264A521 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/04/1988 |
| From: | Pastis H Office of Nuclear Reactor Regulation |
| To: | Tucker H DUKE POWER CO. |
| References | |
| TAC-57036, TAC-57037, TAC-57038, NUDOCS 8805100028 | |
| Download: ML15264A521 (12) | |
Text
May 4-1988 Docket Nos. 50-269, 50-270 and 50-287 Mr. H. B. Tucker, Vice President Nuclear Production Department Duke Power Company 422 South Church Street Charlotte, North Carolina 28242
Dear Mr. Tucker:
SUBJECT:
SECOND TEN-YEAR INSERVICE INSPECTION PROGRAM - REQUEST FOR ADDITIONAL INFORMATION (TACS 57036/57037/57038)
Re:
Oconee Nuclear Station, Units 1, 2 and 3 We have been reviewing your second ten-year inservice inspection program for Oconee Units 1, 2 and 3. We have determined, with assistance from our consultant - Science Applications International Corporation - that to complete our review, we need the additional information identified in the enclosure.
We request that you respond to this request for additional information within sixty days of the date of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely, Originial Signed by David Matthews Helen N. Pastis, Project Manager Project Directorate-II-3 Division of Reactor Projects I/Il
Enclosure:
As stated cc w/encl:
See next page DISTRIBUTION NRS POR Local PDR PDIT-3 Reading File S. Varga G. Lainas D. Matthews M. Rood 0-ij 408 H. Pastis PD88 ADOCK OGC-WF E. Jordan 3302 J. Parflow 9A-4 ACRS (10)
Oconee Plant File PD I P I1 MRod
- sw Matthews 06-3/88 0 /
/88 0 /\\ /88
Mr. H. B.
Tucker Oconee Nuclear Station Duke Power Company Units Nos. 1, 2 and 3 cc:
Mr. A. V. Carr, Esq.
Mr. Paul Guill Duke Power Company Duke Power Company P. 0. Box 33189 Post Office Box 33189 422 South Church Street 422 South Church Street Charlotte, North Carolina 28242 Charlotte, North Carolina 28242 J. Michael McGarry, III, Esq.
Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W.
Washington, D.C. 20036 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 525 1700 Rockville Pike Rockville, Maryland 20852 Manager, LIS NUS Corporation 2536 Countryside Boulevard Clearwater, Florida 33515 Senior Resident Inspector U.S.
Nuclear Regulatory Commission Route 2, Box 610 Seneca, South Carolina 29678 Regional Administrator, Region 1I U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323 Mr. Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 Office of Intergovernmental Relations 116 West Jones Street Raleigh, North Carolina 27603 Honorable James M. Phinney County Supervisor of Oconee County Walhalla, South Carolina 29621
ENCLOSURE DUKE POWER COMPANY OCONEE NUCLEAR STATION, UNITS i 2, AND 3 Reauest for Additional Information Second 10-Year Interval Inservice Inspection Relief Requests I. Scope/Status of Review The Oconee Nuclear Station (ONS) Units 1, 2, and 3 Second 10-Year Interval Inservice Inspection (ISI) Program Plan is being evaluated for compliance with 10 CFR 50.55a(g)(4).
Specifically, the ISI Program Plan is being evaluated for (a) compliance with the appropriate edition of Section XI, (b) acceptability of examination sample, (c) exemption criteria, and (d) compliance with ISI-related commitments identified during the NRC's previous Preservice Inspection (PSI) and ISI reviews. The second inspection interval began in April 1984 and ends in April 1994.
The requests for relief for the second 10-year inspection interval are also being evaluated. As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief from them, the licensee shall submit information and technical justifications to the U.S. Nuclear Regulatory Commission (NRC) to support that determination.
II. Additional Information Required Based on review of the ISI plan and requests for relief for the second 10-year interval submitted through December 1987, the staff cannot conclude that the ISI plan for ONS -1, -2, and -3 is in compliance with 10 CFR 50.55a(g)(4). The staff cannot complete review of the ISI plan until the following additional information and/or clarification is submitted:
1
- 1. All three ONS plants would be expected to be very similar in design and configuration because (1) all are 860 MWe pressurized water reactors with the nuclear steam supply system designed by B&W, (2) all have supporting systems designed by the same Architect/Engineer, and (3) all three ONS plants began commercial operation within a 1-1/2 year time span. In addition, the 1980 Edition, Winter 1980 Addenda of Section XI (80E 80W) has been applied to all three plants in developing ISI plans with a common ISI interval.
The ISI examination sample required by the Code for all three units would, therefore, be expected to be very similar in extent and distribution. However, the individual plant ISI plans contain a large number of significant differences in the examination sample and include many cases where Code requirements for extent and distribution are not met.
For example, under Code Item number B1.11, circumferential shell welds in the reactor vessel, four welds are listed for ONS-1 in Appendix A, but none are scheduled for examination in Appendix B, three welds are scheduled for ONS-2, and one weld is scheduled for ONS-3. One belt line region weld is listed in Appendix A for ONS-1 but is not scheduled for examination in Appendix B. ONS-2 includes a beltline region weld scheduled for examination. The one weld scheduled for ONS-3 is not a beltline region weld as required by the Code. Under Code Item number 82.60, tube sheet-to-shell welds in heat exchangers, two of four welds listed are scheduled for ONS-1, no welds are listed or scheduled for ONS-2, and one weld is scheduled for ONS-3. Under Code Item number B3.150, nozzle-to-vessel welds in heat exchangers, one of four welds listed is scheduled for ONS-1, no welds are identi fied for ONS-2, and four welds are scheduled for ONS-3. Under Code Item number B4.12, partial penetration welds for control rod drive nozzles, some examinations are scheduled for Units 1 and 2 (although it is not clear that 25% of the nozzles are scheduled as required by the Code), but no examinations are scheduled for Unit 3.
The examination samples for component supports as required under Subsection IWF for the three plants are also inconsistent and are much smaller than typically required to meet Code requirements. The samples are tabulated below for comparison.
2
Component Support Examinations Class 1 Class 2 Class 3 ONS-1 62 117 0
ONS-2 0
0 0
ONS-3 32 57 73 The number and magnitude of differences in the examination samples indicate either significant design differences between the three plants or significant differences in methodology used to develop the ISI plans for each plant.
Please provide a discussion of the methodology used to develop the ISI plan for each plant and each examination category which clearly demonstrates that the plants meet all Code and regulatory requirements. The drawings, lists of exami nations, and schedules included in the plans should illustrate application of the methodology for staff review. For example, the plan should indicate the total plant population by Code Item number and the number of examinations of the item that will be conducted.
The plan need not have specific examinations scheduled, but the plan should show the distribution of examinations by period. If all three units are identical, please state. If the units are identical, you may provide the requested information for the least conservative plan in lieu of providing the information for all three units.
- 2. Drawings ISI-OCN-"
"-001 through ISI-CN-"_"-016 supplied with the plan for each unit are acceptable drawings for use in ISI plans.
These drawings provide a convenient source of information on the distribution and extent of the examination sample and are used by the staff to evaluate the acceptability of the sample, including consideration of multiple trains and components performing similar functions. However, these drawings cover only a portion of the Class 1 components. For example, the drawings provided do not include all Class 1 systems such as High Pressure Injection System and Low Pressure Injection Systems, and do not include any Class 2 systems.
Please provide appropriate engineering drawings for ONS-1, -2, and
-3 which will permit the staff to review the ISI plans for each unit and permit evaluation of the examination sample for all non-exempt components.
3
- 3. The ONS-1 ISI plan has been submitted in the format outlined in the IS11 Plan Table of Contents. Appendix A.is a listing of examinations by Code item number. Appendix B contains the same listing of examinations along with a schedule by outage for the examination.
Examinations are scheduled in Appendix B for outages 8, 9, and 10, but many components which the Code requires to be examined are not scheduled for an outage. For example, no reactor vessel circum ferential shell welds (B1.11) or longitudinal welds are scheduled for examination. How will the Code-required examinations for Code items not scheduled in Appendix B for ONS-1 be achieved?
- 4. In addition to providing the basis for the extent of the examination sample, the ASME Code provides guidelines for implementing the inspections during each 10-year interval.
ASME Code Sections IWB 2400, IWC-2400, and IWF-2400 list examination schedule requirements.
However, review of the ISI plans indicate that these requirements may not be included. Please provide an overall narrative description of the method used to meet the requirements of Sections IWB-2412, IWB 2420, IWC-2412, IWC-2420, and IWF-2420 for each examination category.
- 5. Refer to: Volume 1, Section 1.0--Applicable editions and addenda of ASME Boiler and Pressure Vessel Code,Section XI (Rev. 1, Page 1, C/6550025):
Section 1.0 contains the statement:
"Examinations of Class 3 components included in examination Category D-B will be selected in accordance with Table IWD-2500-1 of the 1980 Edition of ASME Section XI, as allowed by paragraph 50.55a(g)(4)(iv) of 10 CFR 50."
Paragraph 50.55a(g)(4)(iv) permits updating to more recent versions of the Code. The 1980 Edition of ASME Section XI with Addenda through Winter 1980 (80E80W) has been selected as the applicable version of the Code for ONS-1, -2, -3. Selecting the 1980 Edition without addenda is not consistent with paragraph 50.55a(g)(4)(iv).
Please clarify the requirements that will be used for examination of Class 3, Category D-B components.
4
- 6. The.ISI Plan does not state that the 1974 Edition, Summer 1975 Addenda of the Code is being used for Class 2 piping welds in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems as required by 10 CFR 50.55a(b)(2)(iv). The licensee has indicated (Ref. 26) that:
"this requirement was met by using the W80 requirements for Category C-F (except for Note 1(d)(2)) and assuring that all S75 requirements are also met."
The methodology applied by the licensee is not clear and should be discussed in greater detail.
The plan should identify the welds selected to satisfy the requirements of 10 CFR 50.55a(b)(2)(iv).
- 7. Refer to: Volume 1, Section 1.2--Code Cases applicable to the ASME Boiler and Pressure Vessel Code,Section XI (Rev. 1, Page 1, C/46550025):
Please verify that Section 1.2 contains a complete list of Code cases applicable to ONS-1, -2, -3 second ISI interval.
- 8. Refer to: Volume 1, Section 2.1.2 (Rev. 0, Page 1, C/6550025):
Paragraph IWC-1220(b) permits exemption of components of systems or portions of systems that are not required to operate above a pressure of 275 psig (1900 kPa) or above a temperature of 200OF except RHR and ECC systems. Since the exception for RHR and ECC systems is not specifically stated in Section 2.1.2, please confirm that no portions of RHR or ECC systems have been exempted from examination based on the temperature and pressure criteria of paragraph IWC-1220(b).
5
- 9. Refer to: Volume 1, Section 2.2--Examination Boundaries (Rev. 0, Page 1, C/6550025):
The copies of the ONS-1,2,3 ISI program plan provided to the staff for review are uncontrolled copies which do not contain color-coded copies of the flow diagram defining examination boundaries. Two important objectives of the staff's review are to evaluate the acceptability of the examination sample and the application of exemption criteria.
Information on the examination boundaries is essential to completing our review. Therefore, provide a copy of the ISI plan with color coded flow diagrams. As an alternative, legible color slides of these diagrams will be acceptable. Also provide a narrative descrip tion of methodology used to establish system boundaries, including a discussion of how the exemption criteria listed in Section 2.1 were applied on each system, subsystem component, or zone exempted from inspection.
- 10. Refer to: Volume 1, Section 4.1--Examination Categories and Requirements (Rev. 1, Page 1, C/6550025):
(a) The "comments" column in the table used for this section contains several entries that state "none". Does a "none" entry indicate that none of these items are present in any of the three plants?
(b) Why are the following items not included in the table?
55.40, 85.41, and 85.42 - Heat Exchanger nozzle-to-safe end dissimilar metal welds B6.120, B6.130, and 86.140 - Heat Exchanger Bolting larger than 2 inches B7.40 - Heat Exchager Bolting less than 2 inches 815.40 and B15.41 - Heat Exchanger Pressure Boundary 6
- 11. Refer to: Volume 1, Section 4.2--Weld Selection for Inservice Inspection (Rev. 1, Page 7, C/6550025):
Section 4.2.1 contains a listing of Class 1 welds which exceed the stress criteria in Table IWB-2500-1 for ONS-1. Sections 4.2.2 and 4.2.3 were intended to contain similar information for Units 2 and 3 which was to be supplied "at a later date". This material has not been received by the staff. Please provide revisions for Sections 4.2.2 and 4.2.3 which list welds that exceed the stress criteria in IWB-2500 for ONS-2 and ONS-3.
- 12. Refer to: Volume 1, Section 5.2--Weld Selection for Inservice Inspection (Rev. 1, Page 3, C/6550025):
Section 5.2 contains a list of welds which exceed the stress criteria given in Table IWC-2500-1 of the Code. Since all the weld numbers included in the list begin with 1-, we assume that these welds are for ONS-1 in accordance with Section 8.1.2.1. Please provide appropriate revisions for Section 5.2 that list the welds which exceed the stress criteria of Table IWC-2500-1 for all three plants.
- 13. The staff is using the submittals listed in Attachment 1 to review the Second Interval ISI Plan and relief requests for ONS-1, -2, and
-3. Please confirm that these submittals contain the most current version of all ISI documents related to the second interval ISI plan or provide copies of the current documents.
7
ATTACHMENT 1 REFERENCES
- 1. NRC to W. 0. Parker, Jr. (DPC), November 7, 1980; Safety Evaluation Report on the Inservice Inspection program at Oconee Units 1, 2 and 3.
- 2. R. W. Reid (NRC) to W. 0. Parker, Jr. (DPC), January 16, 1981; safety evaluation of replacement hydrostatic test relief request.
- 3. P. C. Wagner (NRC) to W. 0. Parker, Jr. (DPC), April 8, 1982; safety evaluation of relief requests.
- 4. P. C. Wagner (NRC) to W. 0. Parker, Jr. (DPC), May 17, 1982; Revised evaluation of one relief request.
- 5. J. F. Stolz (NRC) to H. B. Tucker (DPC), February 14, 1984; evaluation of relief requests.
- 6. J. F. Stolz (NRC) to H. B. Tucker (DPC), February 7, 1985; evaluation of relief requests.
- 7. H. B. Tucker (DPC) to H. R. Denton (NRC), September 25, 1984; Oconee Unit 1 Inservice Inspection Program.
- 8. H. B. Tucker (DPC) to H. R. Denton (NRC), March 5, 1985; Oconee Unit 2 Inservice Inspection Program.
- 9. H. B. Tucker (DPC) to H. R. Denton (NRC), May 1, 1985; Oconee Unit 3 Inservice Inspection Program.
- 10. H. B. Tucker (DPC) to H. R. Denton (NRC), September 13, 1984; submits five 2nd-interval relief requests.
- 11. H. B. Tucker (DPC) to H. R. Denton (NRC), November 16, 1984; relief request from hydrostatic testing of system modifications.
- 12. H. B. Tucker (DPC) to H. R. Denton (NRC), December 11, 1984; relief request from hydrostatic testing of system modifications.
- 13. H. B. Tucker (DPC) to H. R. Denton (NRC), November 12, 1985; relief request from hydrostatic testing requirements.
- 14. H. B. Tucker (DPC) to H. R. Denton (NRC), November 22, 1985; relief request from hydrostatic testing requirements.
- 15. H. B. Tucker (DPC) to H. R. Denton (NRC), January 10, 1986; relief request from hydrostatic testing requirements.
I
- 16. H. B. Tucker (DPC) to H. R. Denton (NRC), January 23, 1986; relief request from interval start date.
- 18. H. B. Tucker (DPC) to H. R. Denton (NRC), April 18, 1986; relief request from hydrostatic testing requirements.
- 19. H. B. Tucker (DPC) to H. R. Denton (NRC), May 15, 1986; relief request from hydrostatic testing requirements.
- 20. H. B. Tucker (DPC) to H. R. Denton (NRC), November 18, 1985; withdraws relief request submitted November 16, 1984.
- 21. H. Nicolaras (NRC) to H. B. Tucker (DPC), November 7, 1984; approval of common interval start date.
- 22. H. B. Tucker (DPC) to H. R. Denton (NRC), December 2, 1983; request for common interval start date.
- 23. NRC to DPC, July 22, 1985; request for additional information on the Inservice Inspection program.
- 24. H. B. Tucker (DPC) to H. R. Denton (NRC), October 8, 1985; response to request for additional information.
- 25. H. B. Tucker (DPC) to H. R. Denton (NRC), October 23, 1985; transmits omitted attachments to October 8, 1985 letter.
- 26. H. B. Tucker (DPC) to J. F. Stolz (NRC), August 28, 1986; response to several staff concerns regarding inservice inspection.
- 28. W. 0. Parker, Jr. (DPC) to H. R. Denton (NRC), January 13, 1981; relief request main feedwater system check valves.
- 29. H. B. Tucker (DPC) to H. R. Denton (NRC), February 15, 1982; transmittal of B&W report on high pressure injection/makeup safe-end task force.
- 30. H. B. Tucker (DPC)-to H. R. Denton (NRC), September 9, 1986; hydrostatic tests applicable to second interval.
- 31. H. B. Tucker (DPC) to H. R. Denton (NRC), December 3, 1986; relief request main steam power operated valve 2MS-84.
- 32. H. B. Tucker (DPC) to H. R. Denton (NRC), February 9, 1987; relief request reactor coolant pump.
- 33. H. B. Tucker (DPC) to NRC, March 2, 1987; relief request main steam check valves.
2
- 34. H. B. Tucker (DPC) to NRC, March 5, 1987; relief request low pressure service water valve.
- 35. H. B. Tucker (DPC) to NRC, April 7, 1987; relief request penetration room ventilation system (Unit 3) and purification demineralizer (Unit 3).
- 36. H. B. Tucker (DPC) to NRC, April 9, 1987; relief request penetration room ventilation system (Units 1 and 2).
- 37. H. B. Tucker (DPC) to NRC, September 25, 1987; transmits six 2nd-interval relief requests.
3