ML15264A592

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Requests Addl Info Re Second 10-yr Internal Inservice Insp Program Plan & Relief Requests within 45 Days of Ltr Receipt
ML15264A592
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 03/27/1989
From: Hood D
Office of Nuclear Reactor Regulation
To: Tucker H
DUKE POWER CO.
References
TAC-57036, TAC-57037, TAC-57038, NUDOCS 8903300261
Download: ML15264A592 (12)


Text

March 27, 1989 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:

REQUEST FOR ADDITIONAL INFORMATION -

OCONEE UNITS 1, 2, AND 3-SECOND TEN-YEAR INSERVICE INSPECTION PROGRAM (TACS 57036, 57037, 57038)

The NRC, with assistance from its contractor Science Applications International Corporation (SAIC), is reviewing the Second Ten-Year Interval Inservice Inspection Program Plan for the Oconee Nuclear Station, Units 1, 2, and 3. Additional information identified by the enclosure is needed for completion of our review.

We request that you respond to the enclosure within 45 days of receipt of this letter.

We also request that a copy of your reply be forwarded directly to Tory Whitehead of SAIC at P.O. Box 50697, Idaho Falls, Idaho 83450 Contact me at (301) 492-1442 if you have questions or are unable to meet the requested schedule.

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,

/S/

Darl S. Hood, Project Manager Project Directorate 11-3 Division of Reactor Projects -

I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated cc:

See next page DISTRIBUTION:

Docket File D. Matthews 14-H-25q CYCheng 9-H-15 NRC PDR.

M. Rood 14-H-25 Gdohnson 9-H-15 Local PDR D. Hood" 14-H-25 ACRS (10) P-315 PDII-3 Reading OGC 15-B-18 Oconee Plant File S. Varga 14-E-4 E. Jordan MNBB-3302 G. Lainas 14-H-3 B. Grimes 9-A-2 P"IA3 PDII-3 PDII-3 DHood:sl DMatthews 03/3/89 03/73/89 03/A7/89 3903300261 890327 PEIR ADOCK 05000269 1B Oo PaFPDC

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UNITED STATES 0

NUCLEAR REGULATORY COMMISSION 00 C

WASHINGTON, D. C. 20555

+0 March 27, 1989 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:

REQUEST FOR ADDITIONAL INFORMATION - OCONEE UNITS 1, 2, AND 3 SECOND TEN-YEAR INSERVICE INSPECTION PROGRAM (TACS 57036, 57037, 57038)

The NRC, with assistance from its contractor Science Applications International Corporation (SAIC), is reviewing the Second Ten-Year Interval Inservice Inspection Program Plan for the Oconee Nuclear Station, Units 1, 2, and 3. Additional information identified by the enclosure is needed for completion of our review.

We request that you respond to the enclosure within 45 days of receipt of this letter. We also request that a copy of your reply be forwarded directly to Tory Whitehead of SAIC at P.O. Box 50697, Idaho Falls, Idaho 83450 Contact me at (301) 492-1442 if you have questions or are unable to meet the requested schedule.

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, Darl S. Hood, Project Manager Project Directorate 11-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated cc:

See next page

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 Mr. Alan R. Herdt, Chief 1400 L Street, N.W.

Project Branch #3 Washington, D.C. 20005 U.S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Mr. Robert B. Borsum Atlanta, Georgia 30323 Babcock & Wilcox Nuclear Power Generation Division Mr. Tory Whitehead Suite 525 SAIC 1700 Rockville Pike P.O. Box 50697 Rockville, Maryland 20852 Idaho Falls, Idaho 83405 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 II 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 1, 2, AND 3 Reauest for Additional Information Second 10-Year Interval Inservice Inspection Program and Relief Reauests 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 In response to an NRC staff request for additional information dated May 4, 1988,(44) the licensee provided a revised second interval ISI plan on July 5, 1988.(45) Based on a review of the revised plan, the staff cannot conclude that it is in compliance with 10 CFR 50.55a(g)(4).

The staff cannot complete review of the revised ISI plan until the following additional information and/or clarification is submitted:

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1. Appendix A to Revision 5 of the ISI plan lists the examinations to be performed each outage for each Oconee unit. ASME Code Sections IWB-2400, IWC-2400, and IWF-2400 list examination schedule require ments. In order for the staff to verify compliance with examination scheduling requirements, please specify the dates of each planned outage for each Oconee unit.
2. Sections 4.2 and 5.2 of the Oconee ISI plan list Class 1 and 2 piping welds that exceed stress criteria given under Category B-J, Table IWB-2500-1 and Category C-F, Table IWC-2500-1. However, the welds indicated below are listed in Sections 4.2 and 5.2 of the ISI plan but are not scheduled for examination in Appendix A.

Class 1 1PSL-10 2PSL-10 3PSL-10 1PSL-11 2PSL-11 3PSL-11 1PDB1-11 2PDB2-10 1PDB2-11 Class 2 1-01A-MS13A-C 2-01A-4.1-21A-A 3-53B-34-06 1-01A-2-4BA 2-O1A-4.1-21A-C 3-538-34-07 1-01A-2-13BA 2-01A-15-10-E 3-53B-34-08 1-01A-2-13BD 2-O1A-15-10-F 1-01A-2-31BE 2-01A-2MS20A-E 1-01A-MS717B-C 1-03-3-36BA 1-538-6.1-21KA 1-53B-6.2-26KC Also, the following Unit 2, Class 2 piping welds are not listed under Section 5.2 as exceeding.stress criteria of Category C-F, but are indicated as such in the Comments column of the Appendix A outage lists:

2-01A-4-MS21A-A 2-01A-MS21A-C 2-O1A-15-MSB-10-E 2-01A-2-MSB-10-F Please resolve the inconsistencies concerning the Class 1 and 2 piping welds which exceed stress criteria in the Code.

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3.

Refer to: ISI Plan, Volume 1, Sections 4.1, 5.1, and 6.1 - Examination Categories and Requirements.

The below listed examination Item numbers are not scheduled for examination in the outage lists, Appendix A, but are included in the ISI program in Section 4.1, 5.1, and 6.1 (i.e., they are not denoted by "none" in the Comments column).

84.11 02.50 B7.50 03.20 01.20 03.30 01.40 D3.50 01.50 03.60 D1.60 Please resolve the inconsistency for the above item numbers.

4. Based on a review of the examination listings provided in Appendix A of the ISI plan, it is apparent that there are several omissions and/or departures from Code requirements in the plan. The licensee is requested to review the following examinations for Code compliance:

(a) Item B2.15, primary side shell circumferential welds on letdown heat exchangers. Examinations performed at Unit 1 and 2, but no examination scheduled in Appendix A for Unit 3.

(b) Items B3.150 and 83.160, nozzle-to-vessel welds and inside radius sections. Six nozzles scheduled for inspection in Appendix A on letdown heat exchangers on Unit 1, but only four nozzles scheduled on Units 2 and 3. In addition, all examinations on Unit 3 are deferred until Outage 14.

(c) Item B5.50, Class 1 piping dissimilar metal butt welds. Two welds (2-53A-10-10A and 2-PHB-17) on Unit 2 are not scheduled for surface examination as required.

(d) Item B9.11, Class 1 piping welds 4 inches and greater in diameter. The following welds are not scheduled for surface examination as required by Code:

1-53A-2.3-43L 3-53A-15.1-44 3-53A-16-01 3

(e) Item B9.21, Class 1 piping welds less than 4 inches in diameter.

Unit 2 pressurizer spray piping terminal end 2PSP-1 is not scheduled for examination as required.

(f) Item 813.30, visual examination of core support structure. No examinations scheduled in Appendix A for Unit 3.

(g) Items B15.10 through 815.71 Class 1 system pressure tests. No hydro static tests (IWB-5222) scheduled at Unit 3. Also, no examinations scheduled under Item B15.70 or B15.71 at any of the three units.

(h) Item C5.21, Class 2 piping welds greater than 1/2-inch nominal wall thickness. Weld 3-03A-97-8A is not scheduled for surface examination as required by Code.

(i) Items C7.10 through C7.41, Class 2 pressure tests. No hydrostatic tests (IWC-5222) scheduled for Unit 3. Also, no examinations scheduled under Items C7.40 or C7.41 at any of the three units.

(j) Items D1.10, 02.10, and 03.10, Class 3 pressure tests. No hydro static tests (IWD-5223) scheduled for Unit 3.

5. Numerous requests for relief from the requirements of IWA-4440, hydro static testing of weld repairs to the pressure retaining boundary, have been submitted by letters dated June 27, 1986,(30) December 3, 1986,(32)

March 2, 1987,(34) March 5, 1987,(35) April 7, 1987,(36) April 9, 1987,(37) September 25, 1987,(38) October 29, 1987,(39) March 7, 1988(40,41) (two letters), and March 15, 1988(42). The following questions relate to the above submitted relief requests:

(a) Relief requests from hydrostatic testing of repair welds to the Low Pressure Service Water System were submitted by letters dated March 5, 1987, and October 29, 1987. No drawings of this system have been provided in the ISI plan. To facilitate review of these relief requests, please provide flow diagrams which detail the impracticality of performing the required hydrostatic tests. Please also indicate the design pressure of the marbo (?) plug mentioned in the relief 4

request for repair welds associated with Valve ILPSW-6. Is the Low Pressure Service Water System scheduled for hydrostatic testing as part of the 10-year ISI program?

(b) A relief request from hydrostatic testing of repair welds associated with Feedwater System Valves IFDW-207 and IFDW-209 was submitted October 29, 1987. These valves cannot be located on the Feedwater System flow diagrams provided in Appendix B to the ISI plan. Please provide flow diagrams which detail the impracticality of performing the required hydrostatic test.

(c) The following questions relate to relief requests submitted as attachments to a letter dated September 25, 1987:

(1) With regard to the request for relief from hydrostatic testing of repair welds associated with Feedwater System Valve 1FDW-329, the subject valve cannot be located on the Feedwater System flow diagrams provided as Appendix B to the ISI plan. Please provide flow diagrams detailing the impracticality of performing the required hydrostatic test. Please also discuss the possibility of performing volumetric or surface examination on the subject repair weld areas.

(2) With regard to the request for relief from hydrostatic testing of repair welds associated with Spent Fuel Cooling System Valve 1SF-65, the subject valve cannot be located on the Spent Fuel Cooling System flow diagram provided as Appendix B to the ISI plan. Please provide flow diagrams detailing the impracticality of performing the required hydrostatic test. Please also discuss the possibility of performing volumetric or surface examination on the subject repair weld areas.

(3) With regard to the request for relief from hydrostatic testing of repair weld areas associated with Reactor Building Spray System Valve 1BS-14, flow diagram OFD-103A-1.1, Rev. 1 provided in Appendix B to the ISI plan shows a removable spool piece 5

downstream of Valve 1BS-14. Please discuss the possibility of using a blind flange at this point to perform the required hydrostatic test. Please also discuss the possibility of performing volumetric or surface examination on the subject repair weld areas.

(4) With regard to the request for relief from hydrostatic testing of repair welds associated with Low Pressure Injection System Valve 2LP-45, a system functional test using a blind flange has been proposed as an alternative to the required hydrostatic test.

Please discuss the possibility of performing the required hydro static test while the blind flange is installed. Please also discuss the possibility of performing a volumetric or surface examination on the subject repair weld areas.

(d) Request for relief No. 88-01 from hydrostatic testing of repair welds associated with Low Pressure Injection System Valves 2LP-131, 2LP-132, and 2LP-133 was submitted on March 7, 1988. These valves cannot be located on the Low Pressure Injection System flow diagrams provided as Appendix B to the ISI plan. Please provide flow diagrams detailing the impracticality of performing the required hydrostatic test.

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0 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.

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16. H. B. Tucker (DPC) to H. R. Denton (NRC), January 23, 1986; relief request from interval start date.
17. H. B. Tucker (DPC) to H. R. Denton (NRC), January 31, 1986; relief request related to snubbers.
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.
27. W. 0. Parker, Jr. (DPC) to H. R. Denton (NRC),

January 7, 1981; alternate NDE methods.

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 J. F. Stolz (NRC), June 27, 1986; relief request from hydrostatic testing of Auxiliary Steam Check Valve 1AS-39.
31. H. B. Tucker (DPC) to H. R. Denton (NRC), September 19, 1986; hydrostatic tests applicable to second interval.
32. H. B. Tucker (DPC) to H. R. Denton (NRC), December 3, 1986; relief request main steam power operated valve 2MS-84.
33. H. B. Tucker (DPC) to H. R. Denton (NRC), February 9, 1987; relief request reactor coolant pump.

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34. H. B. Tucker (DPC) to NRC, March 2, 1987; relief request main steam check valves.
35. H. B. Tucker (DPC) to NRC, March 5, 1987; relief request low pressure service water valve.
36. H. B. Tucker (DPC) to NRC, April 7, 1987; relief request penetration room ventilation system (Unit 3) and purification demineralizer (Unit 3).
37. H. B. Tucker (DPC) to NRC, April 9, 1987; relief request penetration room ventilation system (Units 1 and 2).
38. H. B. Tucker (DPC) to NRC, September 25, 1987; transmits six 2nd-interval relief requests.
39. H. B. Tucker (DPC) to NRCC, October 29, 1987; transmits-five 2nd-interval relief requests from hydrostatic testing of repairs, Unit 1.
40. H. B. Tucker (DPC) to NRC, March 7, 1988; relief request from hydrostatic testing low pressure injection modification welds, Unit 2.
41. H. B. Tucker (DPC) to NRC, March 7, 1988; relief request from hydrostatic testing main steam modification welds, Unit 2.
42. H. B. Tucker (DPC) to NRC, March 15, 1988; relief request from hydrostatic testing feedwater modification welds, Unit 2.
43. H. B. Tucker (DPC) to NRC, March 16, 1988; relief request from 100%

examination of reactor coolant pump, Unit 2.

44. NRC to DPC, May 4, 1988; request for additional information on second interval inservice inspection program.
45. H. B. Tucker (DPC) to NRC, July 5, 1988; response to May 5, 1988 request for additional information, Revision 5 to ISI Plan attached.

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