ML16341D971

Forwards Request for Addl Info Re First 10-yr Interval Inservice Insp Program,Based on Review of 850222 Submittal. Response Requested by 870106 in Order to Complete Evaluation Prior to First Refueling Outage

ML16341D971
Person / Time
Site:	Diablo Canyon
Issue date:	11/12/1986
From:	Schierling H Office of Nuclear Reactor Regulation
To:	Shiffer J PACIFIC GAS & ELECTRIC CO.
References
NUDOCS 8611180026
Download: ML16341D971 (14)

Text

November 12, 1986 Docket No. 50-323 Mr. J.

D. Shiffer, Vice President Nuclear Power Generation c/o Nuclear Power Generation, Licensing Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106 DISTRIBUTION NRC PDR Local PDR PD¹3 Rdg.

OGC E. Jordan E. Sullivan G. Johnson S.

Lee B. Grimes N. Thompson J. Partlow H. Schierling C.

Vo an ACRS l 10)

M. Mendonca P. Narbut J. Burdoin

SUBJECT:

DIABLO CANYON NUCLEAR POWER PLANT, UNIT 2 - ISI PROGRAM Your letter of February 22, 1985 (DCL 86-076) submitted the Inservice Inspection

( ISI) Program Plan for Diablo Canyon Unit 2.

Based on our review of your submittal we have determined that additional information is required for us to complete our evaluation of your program for the first ten-year interval.

The required information is identified in the enclosure.

In order for us to complete our evaluation, including your requests for relief, prior to the Unit 2 first refueling outage, we request that you provide the information no later than January 6,

1987.

Sincerely,

Enclosure:

As stated cc:

See next page Hans Schierling, Senior Project Manager Project Directorate ¹3 Division of PWR Licensing-A PD¹3 CVogan 11/gr/86 PD¹3 HSchier'lsng:mak ll/to/86 P

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Mr. J.

D. Shiffer Pacific Gas and Electric Company Diablo Canyon CC:

Philip A. Crane, Jr.,

Esq.

Pacific Gas E Electric Company Post Office Box 7442, San Francisco, California 94120 Mr. Malcolm H. Furbush Vice President

- General Counsel Pacific Gas 5 Electric Company Post Office Box 7442 San Francisco, California 94120 Janice E. Kerr, Esq.

California Public Utilities Commission 350 McAllister Street San Francisco, California 94102 Mr. Frederick Eissler, President Scenic Shoreline Preservation Conference, Inc.

4623 More Mesa Drive Santa Barbara, California 93105 Ms. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, California 93401 Mr. Gordon A. Silver Ms. Sandra A. Silver 1760 Alisal Street San'Luis Obispo, California 93401 Harry M. Willis, Esq.

Seymour 8 Willis 601 California Street, Suite 2100 San Francisco, California 94108 Mr. Richard Hubbard MHB Technical Associates Suite K

1725 Hamilton Avenue San Jose, California 95125 Arthur C. Gehr, Esq.

Snell 5 Wilmer 3100 Valley Center Phoenix, Arizona 85073 NRC Resident Inspector/Diablo Canyon Nuclear Power Plant c/o U.S. Nuclear Regulatory Commission P. 0.

Box 369 Avila Beach, California 93424 Ms.

Raye Fleming 1920 Mattie Road Shell Beach, California 93440 Joel

Reynolds, Esq.

John R. Phillips, Esq.

Center for Law in the Public Interest 10951 West Pico Boulevard Third Floor Los Angeles, California 90064 Mr. Dick Blankenburg Editor A Co-Publisher South County Publishing Company P. 0.

Box 460 Arroyo Grande, California 93420 Bruce Norton, Esq.

Norton, Burke, Berry 8 French, P.C.

202 E. Osborn Road P. 0.

Box 10569 Phoenix, Arizona 85064 Mr.

W.

C. Gangloff Westinghouse Electric Corporation P. 0.

Box 355 Pittsburgh, Pennsylvania 15230 David F. Fleischaker, Esq.

P. 0.

Box 1178 Oklahoma City, Oklahoma 73101 Managing Editor San Luis Obispo County Telegram Tribune 1321 Johnson Avenue P. 0.

Box 112 San Luis Obispo, California 93406

Pacific Gas 5 Electric Company Diab1 o Canyon CC:

Dr. R.

B. Ferguson Siera Club - Santa Lucia Chapter Rocky Canyon Star Route Creston, California 93432 Mr. Leland M. Gustafson, Manager Federal Relations Pacific Gas 5 Electric Company 1726 M Street, N.W.

Suite 1100 Washington, DC 20036-4502 Regional Administrator, Region V

U.S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Michael J. Strumwasser, Esq.

Special Counsel to the Attorney General State of California 3580 Wilshire Boulevard, Suite 800 Los Angeles, California 90010 Mr.

Tom Harris Sacramento Bee 21st and 0 Streets Sacramento, California 95814 Mr. K. Daniel Nix California Energy Commission 1516 9th Street, MS 18 Sacramento, California 95814 Lewis Shollenberger, Esq.

US Nuclear Regulatory Commission Region V

1450 Maria Lane Suite 210 Walnut Creek, California 94596 Mrs. Jacquelyn Wheeler 2455 Leona Street San Luis Obispo, California 93400 Mr. Thomas Devine Government Accountability Project Institute for Policy Studies 1901 gue Street, NW Washington, DC 20009 Chairman San Luis Obispo County Board of Supervisors Room 220 County Courthouse Annex San Luis Obispo, California 93401 Director Energy Facilities Siting Division Enerqy Resources Conservation and Development Commission 1516 9th Street Sacramento, California 95814 President California Public Utilities Commission California State Building 350 McAllister Street San Francisco, California 94102 Mr. Joseph

0. Ward, Chief Radiological Health Branch State Department of Health Services 714 P Street, Office Building 0'8 Sacramento, California 95814 Ms. Nancy Cul ver 192 Luneta Street San Luis Obispo, California 93401 Ms. Laurie McDermott, Coordinator Consumers Organized for Defense of Environmental Safety 731 Pacific Street, Suite 42 San Luis Obispo, California 93401

ENCLOSURE REOUEST FOR ADDITIONAL INFORMATION RELATED TO FIRST TEN-.YEAR INTERVAL INSERVICE INSPECTION (ISI)

PROGRAM PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT, UNIT 2 DOCKET NO. 50-323 I.

SCOPE AND STATUS OF REVIEW Throughout the service life'of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which are classified as ASME Code Class 1, Class 2, and Class 3 meet the requirements, except the design and access previsions and the preservice examination requirements, set forth in ASME Code Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components,"

to the extent practical within the limitations of design,

geometry, and materials of construction of the components.

This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during the initial 120-month inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the date of issuance of. the operating license, subject to the limitations and modifications listed therein.

The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein.

The licensee has prepared the ISI Program to meet the requirements of the 1977 Edition, Summer 1978 Addenda (77S78) of the ASME Code Section XI except that for Code Class 1 and Code Class 2 pipe welds, the extent and frequency of examination has been determined by the 1974 Edition through Summer 1975 Addenda (74S75).

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain code examination requirements are impractical and relief is requested, the licensee shall submit information and justifications to"the staff to support that determination.

The staff has reviewed the information in the Diablo Canyon Nuclear Power Plant, Unit 2 First 10-Year Interval Inservice Inspection Program Plan, submitted by letter dated February 22, 1985 (DCL 85-076) including requests for relief from the ASME Code Section XI requirements which the licensee has determined to be impractical to perform.

ADDITIONAL INFORMATION REQUESTED Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the evaluation of the Inservice Inspection (ISI) Program Plan:

2.

Paragraph 10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2 piping welds in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC),

and Containment Heat Removal (CHR) systems shall be examined.

These systems should not be completely exempted from inservice volumetric examination based on Section XI exclusion criteria contained in IWC-1220.

The ISI Program Plan for the Containment Spray System should be revised to include volumetric examination of a representative sample of welds.

Provide the staff with a reference list of NDE examination procedures to be used for ISI.

3.

4.

5.

6.

7.

8.

With regards to limitations due to metallurgical properties of cast stainless steel (SA351 Grade CFSA), the staff has continued to monitor the development of new or improved examination techniques.

As improvements in these areas are achieved, the staff is requiring th'at these new techniques be made part of the ISI examination procedures.

Discuss the ISI examination procedures for the ultrasonic examination of the Diablo Canyon Unit 2 Primary Coolant System and, in particular, the improved examination techniques which may have been incorporated.

Provide the staff with isometric and/or component drawings showing the

welds, components, and supports which are required to be examined by Section XI of the ASME Code.

Provide the staff with the boundary diagrams which define the ASME Code Class I, Class 2, and Class 3 boundaries for the systems being examined in the Diablo Canyon Unit 2 First 10-Year Interval ISI Program Plan.

Provide the staff with a list of specific exemptions applied to each system (by Code Class) being examined during the First 10-Year Interval inservice inspection for Diablo Canyon Uni't 2.

Provide line lists for each s stem including system identification, code

class, NPS and sche u e, pspsng material specification, and maximum operating temperature and pressure.

The information and,iustifications for the relief requests included in the Diablo Canyon Unit 2 ISI Program Plan are inadequate for the staff to determine whether or not relief is justified.

In order for the staff to determine if relief from the Code-required examinations/pressure tests is justified, the relief requests should be revised to include the specific components

and, as a minimum, include the following information:

~

~

I)

(a)

List the specific ASME Code Section XI requirements for the components for which relief is being requested.

(b)

State the number of items associated with the relief request.

(c)

Identify the individual welds, components, or supports for which relief is being requested, and for each weld, component, or support listed, state the reason why the Code-required examination cannot be completed.

(d) If the Section XI Code-required examination cannot be performed for ISI because of a limitation or obstruction, provide a detailed written description of the specific limitation or obstruction and/or drawings or sketches showing the specific limitation or obstruction.

(e)

Provide an estimate of the percentage of the Code-required examination(s) that can be completed on each of the welds, components, or supports for which relief is requested.

(f) If an alternative examination/test is proposed, describe the specific examination/test (see paragraph 12 below) and the extent of that examination/test, and state when the proposed alternative examination/test will be implemented and performed.

If it is not possible to perform alternate examination/test, discuss the impact on the overall level of plant quality and safety.

The relief requests contained in the Diablo Canyon Unit 2 ISI Program Plan have been reviewed by the staff and found to be inadequate with respect to the above information. If the relief requests are generic or do not contain adequate information for the staff to determine if relief is justified, relief will be denied.

9.

For Request for Relief NDE-006 and any other requests for relief that list radiation levels as a reason for request, discuss the following ALARA concerns:

(a) radiation levels at the test area; (b) total estimated man-rem exposure involved in the examination/test; (c) consideration of shielding capabilities which might reduce the radiation level; and (d) consideration for remote inspections.

10.

For Requests for Relief NDE-001, NDE-003, NDE-004a, NDE-004b, and NDE-006, provide an estimate of the percentage of the Code-required examination(s) that can be completed on the welds for which relief is requested.

Drawings showing limitations or obstructions may be provided for relief requests (i.e., rollout drawings of the Reactor Pressure Vessel) to assist in justification for relief.

C

4 11.

It is not evident as to why relief is being requested in Request for Relief NDE-007 since the proposed alternative examination is the same as the Section XI Code-required examination.

Provide clarification on this request for relief.

12.

Paragraph IWA-2240, "Alternative Examinations", of the ASME Code Section XI states, "Alternative examination methods, a combination of methods, or newly developed techniques may be substituted for the methods specified in this Division, provided the Inspector is satisfied that the results are demonstrated to be equivalent or superior to those of the.specified method."

In most of the requests for relief in the Diablo Canyon Unit 2 ISI Program Plan, a Code-required examination is listed as an alternative examination.

A Code-required examination is not considered an alternate examination.

13.

There is a typographical error in Request for Relief NDE-005.

Under the

heading, "Code Requirements", it states that the NDE Exemption Criteria established by IWC-1220 1974 Edition, Summer 1975 Addenda is to be uti lized to develop the Diablo Canyon Unit 1 Code Class 2 pipe weld ISI Program as indicated by 10 CFR 50.55a(b)P77iv)(B).

Under the heading, "Alternate Criteria", Request for Relief NDE-005 states that the Class 2 Exemption Criteria established by IWC-1220 1977 Edition, Summer 1978 Addenda will be utilized to develop the Diablo Canyon Unit 2 Code Class 2 pipe weld ISI Program.

The reference to Unit 1 sho~ud be changed to Unit 2.

The above requested information and/or clarification should be provided as soon as possible so that the review of the Inservice Inspection Program Plan can be completed before the Unit 2 first refueling outage.

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