ML17319B295
| ML17319B295 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/05/1982 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Dolan J INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| References | |
| NUDOCS 8204200508 | |
| Download: ML17319B295 (18) | |
Text
APR 05 )982 Docket Nos.60-316 and 60-316 Mr. JohhnDolan, Vice President Indiana and Michigan Electric Company Post O,fice Box 18 Bowling Green Station New York, New York 10004
Dear Mr. Dolan:
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'~;.@go DISTR IBUTION Docket NRC PDR L PDR NSIC ORB¹1 Rdg DEisenhut OFLD IE ACRS-10 CParrish RCilimberg GJohnson Gray File lie have determined that we need certain adhitiona information to complete our review of your proposed fnservice Inspection Program submitted by your letters which are listed in the enclosure.
He request that you provide the additional information within 30 days after" receipt of this request in order to not delay the review schedule.
The request for information contained in this letter affects fewer than 'Mn respondents; therefore.
OMB clearance,is not required under P.L.96-611.
Sincerely, origlnal siSneL 1V'4 11@~
Steven A. Varga, Chief Operating Reactors Branch
¹1 Division of Licensing
Enclosure:
As stated cc w/enclosure:
See next page 8204200508 820405 PDR ADOCK 05000315 PDR OFFICEI SURNAMES DATE0 ORB ¹1: DL ORB¹1:D RCilimbe g
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NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981~8 960
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Mr. John Dolan Indiana and Michigan Electric Compan mpany
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Mr. Robert W. Jurgensen Chief Nuclear Engineer
'merican Electric Power Service Corporation 2 Broadway New York, New York 10004 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W-Mashington, D. C.
20036 Maude Preston Palenske Memorial Library 500 Market Street St. Joseph, Michigan 49085 M. G. Smith, Jr., Plant Manager Donald C. Cook Nuclear Plant P. 0.
Box 458 Bridgman, Michigan 49106 U. S, Nuclear Regulatory Commission Resident Inspectors Office 720 Red Arrow Highway Stevensville, Michigan 4912?
William J. Scanlon, Esquire 2034 Pauline Boulevard Ann Arbor, Michigan 48103 The Honorable Tom Corcoran United States House of Representatives Mashington, D. C.
20515 James G. Keppler Regional Administrator - Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen El lyn, Illinois 60137
0
ATTACHMENT 1 REQUEST FOR ADDITIONAL INFORMATION INSERV ICE INSPECTION PROGRAM Cook 1 and 2
( IMP) Company submitted the Inservice Inspection (ISI) program pertaining to the non-destructive examination of welds at Cook Unit No.
1 in September 1978 (Attachment 2 of Ref. 2).
This program was for the 40-month period beginning December 23, 1978 (Ref.
1 and 2).
After being informed by NRC staff that NRC had not received this submittal, it was re-transmitted in September 1979 (Ref. 3).
For Cook Unit No. 2, IMP submitted ISI program information pertaining to the non-destructive examination of welds in November 1977 (Attachments A,
B E
C to Ref. 4).
A revision to this information (revised Tables 1 and 2 of Attachment B to Ref. 4), resulting from piping system walkdowns and from review of the program, was submitted in August 1978 (Ref. 5).
Assuming that the above su+nary covers all ISI submittals by IMP on these two units, a preliminary review indicates some substantial gaps in the information necessary to evaluate:
(a)
IMP's requests for relief from the requirements of Section XI (1974 Edition through S-75 addenda) of the ASME Code, and
. (b) exemptions IMP is claiming under the terms of the code.
Accordingly, the following additional information is needed to aid in further review of these items.
Further specific information may be required once a
complete package of relief requests and exemptions has been obtained.
1.
The two pertinent submittals are:
(a) Section B of Attachment 2 of Ref.
2 for Unit 1, and (b) Attachment B to Ref.
4 (as updated by Ref,
- 5) for Unit 2.
These submittals deal with Class 2 piping only (Code Items C2. 1 to C2.6).
For each Class 2 system, Table 1 in these submittals covers compliance with code requirements ana exemptions per Code Para-graph IWC-1220.
(a) Are these lists of exemptions complete and up-to-date?
(b) Regarding exemption C, the NRC does not accept the "chemistry control" provision of the 5-75 addenda as a basis for exempting systems for inspection.
IMP should develop an ISI program for the
C
CHR (containment heat removal) systems that complies with the intent of the S-79 addenda, in which the "chemistry control" provision has been deleted.
A commitment to such a program, with any necessary relief requests for reasons other than chemistry control, should be provided in response to this inquiry.
(c) In Table 1, the "remarks" column for a number of welds identifies apparent restrictions in access.
Do these restrictions prevent meeting the code requirement of examining 100i of the weld (categories C-F and C-G)? If so, these instances require code relief and belong more ap-propriately in Table 2.
For each such weld, IMP should estimate the percent of the weld area that cannot be examined and propose an alter-native inspection method, if practical.
(d) The "remarks" column of Table 1 also identifies a number of welds as saddle-to-pipe welds whose inspection is considered augmented because the welds are not structural.
Please justify why these welds are not Code category C-E-1 for which a surface examination, rather than the proposed visual examination, is required.
2.
Table 2, in the two submittals listed in Item 1 above, deals with relief from the requirements of the code.
(a)
In these tables and in supporting legends discussed below, the termin-ology should be changed from "exemption" to "code relief".
Exemptions are covered by paragraphs IWB-1220 and IWC-1220, while these tables deal with relief from code requirements.
(b) Table 2 is useful in identifying individual welds that IMP believes cannot or should not be inspected in accordance to requirements of Tables IWC-2520 and IWC-2600 of the code.
However, it does not present the total story on required code relief for various Class 2 piping
For each Class 2 system in which at least some welds require code relief, a
summary should be prepared with the following information:
(1) Identity and number of welds whose examination is required to meet the total intent of the
- Code, but whose examination is impractical.
2.(b)
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(Cont):
(2) -For which of the above welds an alternative examination method is proposed.
(3) Other comparable welds, if any, in that system or in comparable systems that will be examined in lieu of the impractical, Code-required welds.
(4)
A quantitative estimate of how close these measures will come to meeting the total intent of the Code for each system.
3.
The generic exceptions
( 1-9) claimed in Table 2 are described in Figure C-3 of the two submittals.
Please answer the following questions only for those exceptions that are, being claimed.
(a) D-1 is insufficient clearance for volumetric or surface inspection.
Please explain criteria and/or method in making this determination.
Are these welds totally inaccessible, as distinguished from partially accessible welds discussed in Item 1(c) above?
(b) EX-2 is insufficient clearance for volumetric inspection, but sufficient clearance for surface inspection.
Please respond as for (a) above.
(c) EX-3 is due to physical inaccessibility (height, location).
If height is invoked, please specify what methods were considered for reaching such welds.
Based on current indust;y safety standards, show why each of these methods was rejected.
(d) EX-5 is due to radiation in excess of 1000 mrem/hr.
Provide the basis for selecting this value.
Whenever high radiation is invoked, an esti-mate should be made of the man-rem exposure that would result from the code-required examination.
Also a discussion of possible methods (flush-ing, shielding, etc.) to be used in reducing this exposure should be given.
(e)
EN-7 is from hydrostatic inspection because of an open line.
The particular circumstances should be explained on a case-by-case basis.
Also explain the parenthetical phrase under EX-7: "(Only exemption code ever used for an exempt line)."
(f) EX-8 is from volumetric inspection due to insufficient wall thickness (less than 5/16 in.)..
Explain the basis for selecting this wall thickness value.
Ql 1
(g) EX-9 is surface inspection used in lieu of volumetric inspection due to partial penetration welds.
Provide criteria for this exception.
(h)
EX-4 and EX-6 are for "medium energy fluid" and "piping break criteria",
both per MEB 3-1 of Standard Review Plan.
Please provide justifica-tion for using MEB-1 to prove these examinations impractical.
4.
Item E on page A-2 of these submittals indicates that inspection of Class 2
pressure
- vessels, pumps, and valves will be in accordance with the approp-riate examination category of Table IWC-2520 in S-75 addenda.
Are there any relief requests for these Code items?
5.
The above submittals include no information on either Class 1 or Class 3
systems.
Are there any relief requests for these classes?
6.
Under the change in Regulation 10 CFR 50.55a effective November 1,
1979 the ISI program, when finally approved, will cover the last 80 months of the current 10-year inspection interval, i.e.,
from December 23, 1978 to August 23, 1985 for Unit 1.
For Unit 2, it will cover the entire 10-year interval from the start of commercial operation.
(a)
Does this result in any changes IMP wishes to make in the relief requests?
Does IMP require other ISI relief?
(b) Has consideration been given to combining the ISI programs for the two units in order to simplify the review and approval process?
REFERENCES:
1.
Tillinghast
( IMP) to Rusche (NRC), August 2, 1976.
2.
Hunter
( IMP) to Denton (NgC), AEP:
NRC: 00070, September 22, 1978.
3.
Hunter
( IMP) to Denton (NRC),
AEP:
NRC: 000708, September 11, 1979.
4.
Tillinghast
( IMP) to Case (NRC), November 18, 1977.
5.
Tillinghast
( IMP) to Denton (NRC),
AEP:
NRC: 00062, August 25, 1978.
3/18/82
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'4 DISTRIBUTION
. Docket Files
'RC PDR Local PDR ORB 1 File D. Eisenhut OELD I8E (1)
R. Cil imberg C. Parri sh P.
Kapo D.
DiIann'AR 16 1982 Docket Nos. 50-315 and 50-315 Hr. John Dolan, Vice President Indiana and Hichigan Electric Company Post Office Box 18 Bowling Green Station Hew York, Hew York 10004 00 R
Dear fir. Dolan:
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We have completed our preliminary review of your letter dated January 8, 1981.
Hay 26, 1981, December 23.
1981 (2 letters) and January ll, 1982, on THI Action Items; II.F,1.4 Containment Pressure Honitor, II.F.1.5 Containment Water Level Honitor and II.F.1.6 Containment Hydrogen Monitor for the D.
C'.
Cook Plant Unit Hos.
1 81 2.
We 'f4nd that in order to complete our, review we need the information identified in the enc'losure to this letter.
Please respond within 30 days of the receipt of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OHB clearance is not required under P.L.96-511.
Sincerely,
Enclosure:
As stated Steven A. Yarga, Chief Operating Reactors Branch No.
1 Division of Licensing cc:
See next page OFFICE/
SURNAMF.$
oAva.II ORB 1
RCilimberg/
3/(6/82
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'<I-OFFICIAL RECORD C.OPY USGPO: 1981~990
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Mr. John Dolan Indiana and Michigan Electric Company CC:
Mr. Robert W. Jurgensen Chief Nuclear Engineer American Electric Power Service Corporation 2 Broadway New York, New York 10004 Geral d Charnoff, Esquir e Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D. C.
20036 Maude Preston Palenske Memorial Library 500 Market Street St. Joseph, Michigan 49085 W. G. Smith, Jr., Plant Manager Donald C. Cook Nuclear Plant P. 0. Box 458 Bridgman, Michigan 49106 U. S. Nuclear Regulatory Commission Resident Inspectors Office 770 Red Arrow Highway Stevensville, Michigan 49127 William J. Scanlon, Esquire 2034 Pauline Boulevard Ann Arbor, Michigan 48103 The Honorable Tom Corcoran United States House of Representatives Washington, D. C.
20515 James G. Keppler Regional Administrator - Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
ENCLOSURE 1
QUESTIONS ON NUREG-0737 ITENS II.F.1.4 Containment Pressure Nonitor II.F.1.5 Containment Water Level Monitor II.F.1.6 Containment Hydrogen Nonitor gl. In the submittals received to date you have not indicated that you plan to take exception to any of the requirements of NUREG-0737.
Are you planning any exceptions of which we are not aware?
Al.
g2. (II.F.1.4)
What is the accuracy* of your pressure monitorl State this for both the indicator and the recorder.
g3. (II.F.1.4)
What is the time response** of your pressure monitored State this for both the indicator and the recorder.
g4. (II.F.1.5)
What is the accuracy* of your w'ater level monitor?
State this for both the wide range instrument and the narrow range instrument.
A4.
g5. (II.F.1.6)
Where are the hydrogen sample ports placed?
g6 (II.F.1.6)
Is there any obstruction which would prevent hydrogen from the core from reaching the hydrogen sample ports reasonably quicklyl A6.
g7. (II.F.1.6)
What is the accuracy* of your hydrogen monitor7 A7.
State the accuracy of the readout in the control room, which is a combination of the transmitter accuracy. thr readout device accuracy.
and the accuracy of all components in between.
State what parameter you are quoting for accuracy (i.e. la, 2a. 90K confidence, etc).
State the accuracy as a percentage of full scale.
- State the time response of the readout in the control room, which is a combination of the transmitter time response, the readout time response, and the time response of all components in between.
State what parameter you are quoting for time response (i.e. v. 905 response, etc.).
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