ML17333A471
| ML17333A471 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/14/1996 |
| From: | John Hickman NRC (Affiliation Not Assigned) |
| To: | Fitzpatrick E AMERICAN ELECTRIC POWER SERVICE CORP. |
| References | |
| TAC-M94871, TAC-M94872, NUDOCS 9606200256 | |
| Download: ML17333A471 (12) | |
Text
June 14, 1996 Mr. E.
E. Fitzpatrick, Vice President Ihdiana Michigan Power Company c/o American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, OH 43215
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE D.C.
COOK NUCLEAR PLANT, UNITS 1
AND 2 THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF (TAC NOS.
M94871 AND M94872)
Dear Mr. Fitzpatrick:
The NRC staff with assistance from its contractor, Idaho National Engineering Laboratory, is reviewing and evaluating your third 10-year interval inservice inspection program plan and the associated requests for relief from the American Society of Mechanical Engineers, Boiler and Pressure Vessel
- Code,Section XI requirements for D.C.
Cook Nuclear Plant, Units 1
and 2, as submitted on January 25, 1996.
We have identified additional information that is required in order to complete our review.
We request that you respond to the enclosed list of questions within 60 days to meet our inservice inspection program plan review schedule.
In addition, to expedite the review process, please send a copy of your response to our contractor at the following address:
Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, Idaho 83415-2209 If you have any questions on these items please contact me at (301) 415-3017.
Sincerely, Original Signed By:
John B. Hickman, Project Manager Project Directorate III-1 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket Nos.
50-315 and 50-316 cc w/encl:
See next page
Enclosure:
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 14, 1996 Mr. E.
E. Fitzpatrick, Vice President Indiana Michigan Power Company c/o American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, OH 43215
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE D;C.
COOK NUCLEAR PLANT, UNITS 1
AND 2 THIRD 10-YEAR INTERVAL INSERVICE.INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF (TAC NOS.
M94871 AND M94872)
Dear Mr. Fitzpatrick:
The NRC staff with assistance from its contractor, Idaho National Engineering Laboratory, is reviewing and evaluating your third 10-year interval inservice inspection program plan and the associated requests for relief from the American Society of Mechanical Engineers, Boiler and Pressure Vessel
- Code,
- Section XI requirements for D.C.
Cook Nuclear Plant, Units 1 and 2, as submitted on January 25, 1996.
We have identified additional information that is required in order to complete our review.
We request that you respond to the enclosed list of questions within 60 days to meet our inservice inspection program plan review schedule.
In addition, to expedite the review process, please send a copy of your response to our contractor at the following address:
Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, Idaho 83415-2209 If you have any questions on these items please contact me at (301) 415-3017.
Sincerely, Docket Nos.
50-315 and 50-316 cc w/encl:
See next page
Enclosure:
As stated ohn B. Hickman, Project Manager Project Directorate III-1 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation
0
Hr.
E.
E. Fitzpatri ck Indiana Michigan Power Company CC:
Regional Administrator.
Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Attorney General Department of Attorney General 525 West Ottawa Street Lansing, Michigan 48913 Township Supervisor Lake Township Hall P.O.
Box 818 Bridgman, Michigan 49166 Al Blind, Plant Manager Donald C. Cook Nuclear Plant 1 Cook Place
- Bridgman, Michi gan 49106 U.S. Nuclear Regulatory Commission Res ident Inspector '
Office 7700 Red Arrow Highway Stevensville, Hichigan 49127 Gerald Charnoff, Esquire
- Shaw, Pittman, Potts and Jrowbridge 2300 N Street, N.
W.
Washington, DC 20037 Mayor, City of Bridgman Post Office Box 366
- Bridgman, Hichi gan 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, Michigan 48909 Drinking Water and Radiological Protection Division Hichigan Department of Environmental guality 3423 Hartin Luther King Jr Blvd P. 0.
Box 30630 Lansing, Hichigan 48909-8130 Donald C.
Cook Nuclear Plant Hr. S. Brewer American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43215 May 1996
W1
RE UEST FOR ADDITIONAL INFORMATION INDIANA HICKIGAN POWER COMPANY DONALD C.
COOK NUCLEAR PLANT UNITS 1
AND 2 DOCKET NUMBERS 50-315 AND 50-316 Re uest for Additional Information RAI
- Third 10-Year Interval Inservice Ins ection ISI Pro ram Plan 1.
Sco e 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) that are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2,
and Class 3 meet the requirements, except design and access provisions and 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 successive 120-month inspection intervals 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 start of a successive 120-month interval, subject to the limitations and modifications listed therein.
The components (including supports) may meet requirements set forth in subsequent editions and addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Nuclear Regulatory Commission (NRC) approval.
The licensee, Indiana Michigan Power
- Company, prepared the Donald C.
Cook Nuclear Plank, Units 1
and 2, Third Ten Year Inservice Inspection
- Plan, Revision 0, to meet the requirements of the 1989 Edition of the ASME Code Section XI, except that the extent of examination for Class 1, Examination Category B-J, has been determined by the requirements of the 1974 Edition through Summer 1975 Addenda (74S75) as permitted by 10 CFR 50.55a(b).
The third 10-year interval begins July 1, 1996.
As required by 10 CFR 50.55(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief, the licensee shall submit information to the NRC to support that determination.
The staff has reviewed the available information in the Donald C.
Cook Nuclear Plank, Units 1 and 2, Third Ten Year Inservice Inspection Plan, Revision 0, submitted January 25, 1996.
2.
Additional Information Re uired Based on the above review, the staff has concluded that the following information and/or clarification is required to complete the review of the ISI Program.
A.
Section I.A. references Code Cases N-491-1, N-498-1, N-509, N-521, and N-524.
These Code Cases have not been approved for use by reference in Regulatory Guide 1. 147.
Therefore, to use these code
B.
C.
D.
E.
F.
G.
- cases, requests for relief are required.
For use as a guide when preparing requests for relief, attached is Appendix A, "Inservice Inspection:
Guidance for Preparing Requests for Relief from Certain Code Requirements Pursuant to 10 CFR 50.55a(g)(5)."
Section II.E states:
"A number of welds cannot be examined due to inaccessibility or component configuration.
Code relief is requested for the third interval.
Details of the Code Relief are contained in Appendix E."
Appendix E does not exist in the January 25,
- 1996, submittal.
Provide the necessary request(s) for relief for the welds that cannot be examined, this interval, due to inaccessibility or component configuration as required by 10 CFR 50.55a(g)(5)(iv).
Many exams listed in the schedule of examinations contained in the long-term plan do not appear to follow the code successive examination requirements.
The code requires the sequence of examinations established during the first inspection interval shall be repeated during each successive inspection interval, to the extent practical.
- However, many items seem to be scheduled for examination in the third interval without regard to when they were examined in previous intervals.
The third 10-year schedule results in as many as 20-years between examinations.
Provide a detailed technical position explaining how Donald C.
Cook Nuclear Plant, Units 1 and 2, meet the Code successive examination requirements.
The schedule of examinations, included in the long-term plan, contains no Class 3 pressure
- tests, Appendix D, Pages D-34 and D-35 (Units 1
and 2, respectively) states:
"Class 3 pressure-retaining components will have pressure test scheduled by IMP, as maintenance requirements and plant technical specifications dictate."
Do the technical specifications dictate a 10-year system hydrostatic test or periodic system leakage tests?
If not, how will the licensee ensure that Section XI pressure test requirements are met?
It appears that the scheduling of Unit 2, Examination Category B-D does not meet the code percentage requirements of IWB-2412.
Was this an oversight?
If not, provide a request for relief justifying this deviation from code requirements.
Included with the submittal of the Donald C.
Cook Nuclear Plant,
. Units 1 and 2, Third Ten Year Inservice Inspection Plan was several requests for relief for Units 1 and 2.
The requested date for these reliefs is associated with the second interval.
- However, some of these reliefs state that they are for the third interval.
Furthermore, reliefs are mentioned in the third interval program but not included in the plan.
Based on the conflicting information presented, it is unclear as to which interval the reliefs apply.
Provide clarification as to what interval each of the reliefs is requested.
Provide a listing of the code cases being used at Donald C. Cook, Units 1 and 2, that are included in Regulatory Guide 1. 147, Inservice Inspection Code Case Acceptability ASHE Section XI Division l.
Attachment:
Appendix A, Inservice Inspection Guidance
~~~AiA INSERVICE INSPECTION: GUIDANCE FOR PREPARING REQUESTS FOR RELIEF FROM CERTAIN CODE REQUIREMENTS PURSUANT TO 10 CFR 50.55a(g)(5)
The guidance in this Appendix is intended to illustrate the type and extent of information that is necessary in a "request for relief" submittal for those items that cannot be fully inspected to the requirements of ASME Code Section XI.
1 A.
D ri in fR f rRIif The inservice inspection program should contain requests for relief that identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitations of design, geometry, radiation considerations, or materials of construction of the components.
Each request for relief should provide the information identified in the following sections of this Appendix for the inspections and pressure tests considered impractical.
B.
R u
f rReli fFrom erainln e
i n ndT sin Re uiremens Many requests for relief from inservice inspection requirements submitted by licensees have not been supported by adequate descriptive and detailed technical information. This detailed information is necessary to:
(1) document the impracticality of the ASME Code requirements because of the limitations of design, geometry, and materials of construction of components; and (2) determine whether the use of alternatives will provide an acceptable level of quality and safety.
Relief requests submitted with a justification such as "impractical",
"inaccessible", or any other categorical basis, require additional information to permit an evaluation of that relief request.
The objective of the guidance provided in this section is to illustrate the extent of the information required to make a proper evaluation and to adequately document the basis for the granting of relief in the Safety Evaluation Report.
Requests for additional information and delays in completing the review can be considerably reduced if this information is provided in the licensee's initial submittal.
Each relief request should contain adequate information to act as a "stand a/one" document and should include the following:
f
The ASME Code Class, Examination Category, and Item Number(s) or the specific Code paragraph number from which relief is being requested.
ASME Code Section XI examination or test requirements for the weld(s) and/or component(s) for which relief is being requested.
The number of items associated with the requested relief.
Identification of the specific ASME Code requirement that has been determined to be impractical.
An itemized list of the specific welds(s) and/or component(s) for which relief is requested.
An estimate of the percentage of the Code-required examination that can be completed for each of the individual welds(s) and/or component(s) requiring relief.
Information to support the determination that the requirement is impractical; i,e., state and explain the basis for requesting relief. If the Code-required examination cannot be performed because of a limitation or obstruction, describe or provide drawings showing the specific limitation or obstruction.
Identification of the alternative examinations that are proposed:
(a) in lieu of the requirements of Section XI; or (b) to supplement partial Section Xf examinations performed.
A discussion of the failure consequences of the weld(s) and/or component(s) that would not receive the Code required examination.
Discuss any changes expected in the overall level of plant safety by performing the proposed alternative examination in lieu of the examination required by Section XI. If it is not possible to perform alternative examinations, discuss the impact on the overall level of plant quality and safety.
State when the proposed alternative examinations will be implemented and performed.
State when the request for relief would apply during the inspection period or interval (i.e., whether the request is to defer an examination).
S 12.
State the time period for which the requested relief is needed.
\\
Technical justification or data must be submitted to support the relief request.
Stating without substantiation that a change will not affect the quality level is unsatisfactory (i.e., because a licensee does not agree with a Code requirement is not considered Justification for the granting of relief). If the relief is requested for inaccessibility, a detailed description or drawing that depicts the inaccessibility must accompany the request.
G.
R f Rlieffr i in r
i n Radiation exposures of test personnel to accomplish the examinations prescribed in ASME Code Section XI can be an important factor in determining whether, or under what conditions, an examination must be performed.
A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently approved by the NRC staff.
Some of the radiation considerations will only be known at the time of the test.
However, from experience at operating facilities, the licensee generally is aware of those areas where relief will be necessary and should submit as a minimum (in addition to the previous general requirements in Section B) the following additional information regarding the request for relief:
1.
The total estimated man-rem exposure involved in the examination.
2.
The radiation levels at the test area, 3.
Flushing or shielding capabilities that might reduce radiation levels.
4.
A discussion of the considerations involved in remote inspections.
5.
The results of any previous inservice inspections regarding ALARAfor the welds for which the relief is being requested.