ML17333A563

Responds to 960614 RAI Re Third Ten Year Inservice Insp Interval Program Plan & Associated Requests for Relief

ML17333A563
Person / Time
Site:	Cook
Issue date:	09/10/1996
From:	Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:0969AW, AEP:NRC:969AW, TAC-M94871, TAC-M94872, NUDOCS 9609180259
Download: ML17333A563 (11)

Text

REGULATO INFORMATION DISTRIBUTIONTEM (RIDE)

ACCESSION NBR:9609180259 DOC.DATE: 96/09/10 NOTARIZED:

NO FACIL:50-315 Donald C.

Cook Nuclear Power Plant, Unit 1,

Indiana, M

~50-3.'.ig Donald C.

Cook Nuclear Power Plant, Unit 2, Indiana M

AUTH.NAME.'UTHOR AFFILIATION FITZPATRICK,E.E American Electric Power Co., Inc.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

DOCKET 05000315 05000316

SUBJECT:

Responds to 960614 RAI re third ten year inservice insp interval program plan 6 associated requests for relief.

DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submi,ttal: Inservice/Testing/Relief from ASME Code GL-89-04 NOTES:

RECIPIENT ID CODE/NAME PD3-1 LA HICKMAN,J INTERNAL: AEOD/SPD/RAB NRR/DE/ECGB NRR/DE/EMEB OGC/HDS2 RES/DSIR/EIB EXTERNAL: LITCO ANDERSON

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1 RECIPIENT ID CODE/NAME PD3-1 PD LE CglgZE 01 NRR DE EMCB NUDOCS-ABSTRACT RES/DET/EMMEB NOAC COPIES LTTR ENCL 1

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1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT. 415"2083)

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LTTR 15 ENCL 14,

Indiana Michigan Power Company P.O. Box 16631 Coiumbus, OH 43216

/NJNSlNA NICNlCAN PWM September 10, 1996 AEP:NRC:0969AW Docket Nos.:

50-315 50-316 U.

S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.

C.

20555 Gentlemen:

Donald C.

Cook Nuclear Plant Units 1 and 2

THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM AND ASSOCIATED REQUESTS FOR RELIEF (TAC NOS.

M94871 AND M94872)

REQUEST FOR ADDITIONALINFORMATION This letter responds to your June 14, 1996, request for additional information regarding the third 10 year inservice inspection interval program plan and associated relief requests.

The requested information is contained in Attachment 1 to this letter.

Attachment 2 contains a

summary of weld examinations where the third 10 year interval exam schedule does not agree with the first 10 year interval.

Vice President jmb Attachments A. A. Blind A. B. Beach NFEM Section Chief NRC Resident Inspector J.

R. Padgett CC:

7QQQgg 9'609i80259 9609i0 PDR ADQCK 050003i5

, 8 PDR A%7

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ATTACHMENT 1 TO AEP:NRC:0969AM REQUEST FOR ADDITIONALINFORMATION REGARDING THE DONALD 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)

Attachment 1 to AEP:NRC:0969AM Page 1

The Cook Nuclear Plant units 1

and 2 third 10 year inservice inspection interval began on July 1, 1996.

In accordance with 10CFR50.55(a),

relief requests for examinations and inspections that cannot be conducted in accordance with the adopted edition of ASME Section XI must be demonstrated to the satisfaction of the NRC within 12 months after the start of the new inspection interval.

Code relief requests for Cook Nuclear Plant, units 1

and 2 for examinations of components that could not be performed in accordance with ASME Section XI were submitted to the NRC in January 1996, in submittal AEP:NRC:0969AJ.

Also provided with the required third 10 year interval code relief requests was a copy of the long term plan for the.inservice inspection (ISI) program for each unit to facilitate the review of the code relief requests.

In a letter dated June 14,

1996, the NRC's reviewer (INEL) concluded that additional information was required based on the review of the ISI program.

The purpose of this submittal is to provide the requested information.

The following lists each question as stated in the NRC correspondence dated June 14, 1996, (italicized) followed by our response.

Question A

Section I.l references Code Cases N-491-1, N-498-1, N-509, N-521, and N-524.

The code cases have not been approved for use by reference in Regulatory Guide Nl.147.

Therefore, to use these code

cases, requests for relief are required.

For use as a guide when preparing request for relief, attached is Appendix A, "Inservice Inspection:

Guidance for preparing requests for relief from certain code requirements pursuant to 10CFR50.55(g) (5)."

Answer A 10CFR50.55 in footnote 6 references that the code cases listed in Regulatory Guide 1.147, Inservice Inspection Code Case Applicability, ASME Section XI can be used by reference in the long term plan without prior NRC approval.

Because several code cases the Cook Nuclear Plant desires to use during the third 10 year interval are not listed in Regulatory Guide 1.147, code relief requests will be submitted to the NRC by October 31,

1996, and the long term plan will be revised accordingly.

Question B

A number of welds cannot be examined due to inaccessibility or component configuration.

Code relief is requested for the third interval.

~ Details of code relief requests are contained in Appendix E.

Appendix E does not exist in the January 25,

1996, submittal.

Provide the necessary requests for the relief for the welds that cannot 'e

examined, this

interval, due to inaccessibility or component configuration as required by 10CFR50.55a (g) (5) (iv).

Attachment 1 to AEP:NRC:0969AW Page 2

Answer B

Appendix E was a courtesy copy of the long term plan.

The code relief requests were inadvertently left out of the copy provided to the NRC.

The contents of this appendix,

however, are identical to the code relief requests we provided to the NRC in our letter AEP:NRC'0969AJ.

Question C

Many exams listed in the schedule of examinations contained in the long term plan do not appear to follow code successive examination requirements.

The code requires the sequence of examinations established during t'e first inspection interval shall be repeated during each successive inspection

interval, to the extent practical.

However, many items seems to be scheduled for examination in the third interval without regard to when they were examined in the previous intervals.

Provide a detailed technical position explaining how Donald C. Cook Nuclear Plant, Units l and 2, meets the Code successive examination requirements.

Answer C

ASME Section XI in paragraph IWB-2420, states that "sequence of component examinations established during the first interval shall be repeated during each successive inspection interval to the extent practical."

Many changes were made to the sequence of component examinations;

however, successive examination requirements were met to the extent practical.

These changes were necessary to maximize examination coverage and reduce radiation exposure while meeting the requirements of successive examination to the extent practical.

We believe that we meet the intent of the phrase "to the extent practical" where there are significant radiation exposure savings or improvement in examination coverages.

In inspection of piping, code changes between the first 10 year inspection interval and the third 10 year interval have required revisions to the allocations due to reclassification of systems (high pressure safety injection lines).

In some

cases, weld examinations which were performed during the first interval were not performed in the second interval due to differences in the edition of the code adopted during those intervals.

To meet the ASME Section XI code requirements and Table IWX-2412, adjustments were necessary to balance the percentage of examination between periods.

Attachment 2 lists these sorted by class and summary number in addition to the reason the change was made.

In the case of vessel examinations, the proposed use of code cases that defer examinations to the end of the interval (RPV nozzle to shell welds and nozzle inside radius examinations) and reductions in examination of some welds account for a majority of the differences.

Attachment 1 to AEP:NRC:0969AW Page 3

Question D

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 willhave 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 syst'm pressure testP If not, how will the licensee ensure that Section XI pressure test requirements are met7 Answer D

The 10 year ISI system hydrostatic tests for class 3 components are conducted in accordance with technical specification 4.0.5, which requires conformance to ASME Section XI.

The required system pressure tests for class 3 components are performed in accordance with ASME Section XI and Code Case N-498-1 as indicated in the third 10 year interval long term plan for units 1 and 2.

We have been granted approval from the NRC in another request to use this code case at Cook Nuclear Plant as an alternative to hydrostatic testing.

A code relief request to use Code Case N-498-1 for the third 10 year interval will be provided by October 31,

1996, as discussed in Answer A.

Question E

It appears that'he scheduling of Unit 2, Examination Category B-D does not meet the code percentage requirements of IVA-2412.

Vas this an oversight? Ifnot, provide a request for relief justifying this deviation from code requirements.

Answer E

The schedule for the ASME Section XI, Table IWB-2500, B-D welds for both units is consistent with code case N-521.

We intend to use guidance provided in this code case for the units 1 and 2 reactor pressure vessel nozzle to shell welds and inside radius geometries.

Request for approval to use this code case will be submitted as a

relief request by October 31,

1996, as described in Answer A.

The B-D welds for the unit 2 pressurizer are all scheduled in the first inspection period, which is not in compliance with Table IWB-2412.

We will adjust the schedule of these welds for the third 10 year interval to agree with the schedule of the second 10, year interval and the long term plan will be revised accordingly.

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4 Attachment 1 to AEP:NRC:0969AW Page 4

Question F

Included with the submittal of the Donald C.

Cook Nuclear PLant, Units l and 2, Third Ten Year Inservice Inspection Plan was several requests for Units l and 2.

The requested date for these reliefs is associ ated with the second interval.

However some of these reliefs state they are for the third intervaL.

Furthermore, reliefs are menti oned in the third interval program but not included in t'e 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.

Answer F All relief requests submitted in this package are for the third 10 year interval.

Question G

Provide a listing of the code cases being used at the Donald C.

Cook Nuclear Plant, Units l and 2, that are included in Regulatory Guide L.L47, Inservi ce Inspection Code Case Acceptability ASME Section XI Division l.

Answer G

Code Case N-481 has been approved for use in Regulatory Guide 1.147 and will be used in the third 10 year interval.

As stated in Answer A, relief requests will be submitted by October 31,

1996, for code cases that have not been accepted in Regulatory Guide 1.147 that we intend to use during third 10 year inspection interval.

ATTACHMENT 2 TO AEP:NRC:0969AW

SUMMARY

OF WELD EXAMINATIONS

~

'4 Attachment 2 to AEP:NRC:0969AW A

Page 1

Suumary of wold oxmninations <<hozo schoduling of third interval oxams does not agroo with tho first interval Wold I.D Remarks Unit 1 Class 1

022200 024400 1-RC-1-14N 1"RC-2-12F Perform 1st interval, rescheduled 3rd Alignod w/ associated longitudinal weld schedule Class 2

300010 300210 300480 300490 STH-11-05 STH-12-HSN-IRS RHE-I"13 RHE-1-16 Aligned w/ STH-11-04 exam Aligned w/ STH-12HSN nozzle exam Shifted from 2nd period to 3rd to distribution.

Shifted from 2nd period to 3rd to distribution.

balance balance 300500 300510 300680 300690 301600 302600 304290 307320 310930 311170 311560 312060 313000 314210 314410 315240 RHE-1-13 RHE-1-13 1-CVCT-1 1-CVCT-2 1-SI-3-09S 1-SI-21-09S 1-SI-70" 11F 1-RH-8-18F 1"FW-10-17S 1-FW-11-13S 1-FW-13-09S 1-FW-17-07S 1-FW-31-01S 1"HS-10-07S 1-HS-11-13S 1-HS-190-02S Shifted from 2nd period to 3rd to balance distribution Shifted from 1st period to 3zd to balance distribution.

Shifted from 1st period to 3rd to balance distribution Shifted from 2nd period to 3rd to balance distribution Perform 1st interval, rescheduled 3rd Perform 1st interval, zoschoduled 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval, rescheduled 3rd Shifted from 2nd period to 3rd to balance distribution Perform 1st interval, rescheduled 3rd Perform 1st intorval, rescheduled 3rd Shifted fzom 2nd period to 3rd to balanco distribution Perform 1st interval. rescheduled 3rd Perform 1st interval, reschedulod 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval, rescheduled 3rd Unit 2 Class 1

045100 2-RC-31-11 Perform 1st intorval, rescheduled 3rd

4 Attachment 2 to AEP:NRC:0969AW Page 2

048400 050800 054700 055100 055200 055400 055500 058200 065700 072100 2-RC-32-08 2-RC-33-02 2-RC-34-03 2-RC-34-04 2-RC-34"05 2-RC-'34-06 2-RC-34-07 2-RC-34-29 2-RC-514-02 2"RC-515-25 Perform 1st interval, rescheduled 3rd Perfozm 1st interval, rescheduled 3rd Shifted from 1st period to 3rd to distribution Shifted from 1st period to 3rd to distribution balance balance Shifted from 1st period to 3rd to balance distzibut ion Shifted from 1st period to 3rd to balance distribution Shifted from 1st period to 3rd to balance distribution Perform 1st intervaled rescheduled 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval, rescheduled 3rd Class 2

300260 300700 300840 300850 310020 310370 310720 310800 310950 312490 318710 319530 320130 320510 321690 322370 STH-23-08 E-RHRHEX-IN 2-BIT-A 2-BIT-B 2-SI-7-028 2"SI-7-36S 2-SI-8-30S 2-SI-8-37S 2-SI-9-09S 2-SI-77-05S 2-FW-72-12S-PL1 and 2

2-FW-76-05F 2-FW-80-03S 2-FW-89-04S 2-HS-94-15S 2-HS-193-01F I

Perform Perform 1st intervaled 1st interval, rescheduled 3rd rescheduled 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval., rescheduled 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval, rescheduled 3rd Perform 1st interval, rescheduled 3rd Shifted from 2nd period to 3rd to balanco distribution Shifted from 2nd period to 3rd to balance distribution Shifted from 2nd period to 3rd to balance distribution Perform 1st interval, rescheduled 3rd