ML17334B043
| ML17334B043 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/02/1987 |
| From: | Youngblood B Office of Nuclear Reactor Regulation |
| To: | Dolan J AMERICAN ELECTRIC POWER SERVICE CORP., INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| References | |
| NUDOCS 8702040154 | |
| Download: ML17334B043 (12) | |
Text
Docket Nos.:
50-315 and 50-316 FEB p g lS87 Mr. John Dolan, Vice President Indiana and Michigan Electric Company c/o American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43216
Dear Mr. Dolan:
In our review of the Indiana and Michigan Electric Company (IMEC) submittal of the second 10-year interval Inservice Inspection Program Plans, Revision 1, dated December 1985 for the Donald C.
Cook Nuclear Plant, Unit Nos 1 and 2, we have identified additional information needed to determine compliance with 10 CFR 50.55a.
The attached questions, relate only to inservice inspection; the review of testing pumps and valves has not progressed to a question stage at this time.
It is requested that IMEC provide the additional information for our review.
If there are any questions on our request, please let us know.
Sincerely,
Enclosure:
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 F'EB 0 2 1987 Docket Nos.:
50-315 and 50-316 Mr. John Dolan, Vice President Indiana and Michigan Electric Company c/o American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43216
Dear Mr. Dolan:
In our review of the Indiana and Michigan Electric Company
( IMEC) submittal of the second 10-year interval Inservice Inspection Program Plans, Revision 1, dated December 1985 for the Donald C.
Cook Nuclear Plant, Unit Nos 1 and 2, we have identified additional inforIIIation needed to determine compliance with 10 CFR 50.55a.
The attached questions relate only to inservice inspection; the review of testing pumps and valves has not progressed to a question stage at this time.
It is requested that IMEC provide the additional information for our review.
If there are any questions on our request, please let us know.
Sincere Iy,
Enclosure:
As stated PWR Project Directorate 4'4 Division of PWR Licensino-A cc w/enclosure:
See next page
Mr. John Dolan Indiana and Michigan Electric Company Donald C.
Cook Nuclear Plant cc:
Mr.
M. P. Alexich Vice President Nuclear Operations American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43215 Attorney General Department of Attorney General 525 West Ottawa Street Lansing, Michigan 48913 Township Supervisor Lake Township Hall Post Office Box 818 Bridgeman, Michigan 49106 W.
G. Smith, Jr., Plant Manager Donald C.
Cook Nuclear Plant Post Office Box 458 Bridgman, Michigan 49106 U.S. Nuclear Regulatory Comiission Resident Inspectors Office 7700 Red Arrow Highway Stevensville, Michigan 49127 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, N.W.
Washington, DC 20037 Mayor, City of Bridgeman Post Office Box 366 Bridgeman, Michigan 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, Michigan 48909 Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3500 N. Logan Street Post Office Box 30035 Lansing, Michigan 48909 The Honorable John E. Grotberg United States House of Representatives Washington, DC 20515 Pegional Administrator, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen El lyn, Illinois 60137 J. Feinstein Anierican Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43216
INDIANA AND MICHIGAN ELECTRIC COMPANY DONALD C.
COOK NUCLFAR POI!ER PLANT UNITS 1
P
~
DOCKET NlWBERS 50-315 AND 50-316 MATERIAIS ENGINEERING SECTION ENGINFERING BRANCH DIVISION OF PHR LICENSING - A Re uest for Additional Information - Second 10-Year Interval Inservice Inspection Proqram Plans 1.
Scope/Status of Review Throuahout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) reauires that components
{including supports) which are classified as ASME Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination reauirements, set forth in ASME Code Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components,"
to the extent practical within the limitations of desiqn,
- qeometry, 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 second 1?0-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 start of the 120-month inspection interval, subiect to the limitations and modifications listed therein.
The components (includina 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) subiect to the limitations and modifications listed therein.
The Licensee, Indiana and Michiaan Electric Company, has prepared the Donald C,
Cook Nuclear Power Plant Units 1 and 2 Second 10-Year Interval ISI Program Plans, Revision 1, to meet the requirements of the 1983 Edition, Summer 1983 Addenda (83S83) of the ASME Code Section XI except that the selection and allocation of Code Class 1 and Code Class 2 piping welds has been determined by the 1974 Editioh throuqh Summer 1975 Addenda (74S75).
The staff has reviewed the available information in Volumes 1 and 2 of the Donald C.
Cook Nuclear Power Plant Units 1 and
? Second 10-Year 1
'Interval Tnservice Inspection Proaram Plans, Revision 1, dated December 1985.
2.
Additional Information Re uired Based on the above review, the staff has concluded that the followina information and/or clarification is required in order to complete the review of the Inservice Inspection Proaram Plans:
A.
Units 1 and 2:
Paraaraph 10 CFR 50.55a(b)(2)(iv} requires that ASIDE Code Class 2 piping welds in the Residual Heat Removal (RHR),
Emerqency 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 IMC-1220.
The staff has previously determined that a 7.5% auqmented volumetric sample constitutes an acceptable resolution at similar plants.
The ISI Proaram Plans for the Containment Sprav System should be revised to include volumetric examination of a representative samole o< welds.
B.
Units 1 and 2:
With regard to limitations due to metalluraical properties of cast stainless steel
~SA351 Grade CAUSA>, the staff has continued to monitor the development oF improved examination techniques.
Significant improvements have been achieved in the ability to examine cast stainless steel and, accordingly, the staf'f's requiring that utilities perform the Code-required examinations bv incorporatina these improved techniques as part of the inservice examination procedures.
Proper calibration standards and equipment should be obtained for development of a oualified ultrasonic testina (UT> technique and procedure f'r D.C.
Cook Nuclear Power Plant Units 1 and 2.
Discuss the inservice examination procedures for the ultrasonic examination of the Primary Coolant Svstem and, in particular, the improved examination techniques and procedures which will be incorporated to increase the level of compliance with the Code examination requirements of this pipina.
C'.
Units 1 and 2:
Provide the staff with the Boundary Diagrams which define the ASME Code Class 1, Class 2, and Class 3 boundaries for the systems in the O.C.
Cook Nuclear Power Plant Units I and 2
Second 10-Year Interval ISI Program Plans.
0.
Units I and 2:
As required by 10 CFR 50.55a{g)(5), if the licensee determines that certain code examination requirements are imnractical and relief is requested, the licensee shall submit information to the Commission to support that determination.
In the following sections of each ISI Program Plan, the Licensee has made incorrect assumptions with regard to requests for relief'rom the AS8F.
Code requirements which the Licensee has determined to be impractical:
1.)
Section 3.5, "Code Relief", states:
"A number of welds cannot be examined due to inaccessibility or component configuration.
Code relief for these areas was granted by the USNRC during the first interval.
Since accessibility or configuration ~or these welds has not changed, and where Code examination requirements are the
- same, continued Code relief can be assumed for the second interval."
?.)
Section 3.6, "System Pressure Tests", states:
"The same code reliefs which were granted by NRC letters dated ilune 28 and August 13, 1985 for Unit I are also necessary for both units during the second inspection interval.
Unless advised otherwise, we consider these code relic< re uests granted for the second inspection interval."
These requests for relief are not automatically granted for the second 10-year i.nspection interval.
A complete submittal of the requests for relief'ust be submitted for each 10-year inspection interval for the staff to review the relief requests against the updated Code requirements.
Furthermore, the staff monitors the development of new or improved examination techniques.
As improvements in these areas are achieved and implemented in the 3
industry, the staff requires that these techniques be incorporated in subsequent inspection interval ISI program olan examination requirements.
The Licensee should provide a formal submittal of requests for relief including supporting technical.iustifications.
Each request for relief should be a "stand-alone" document (i.e.
all of the suoporting information should be included as part of the relief request).
When preparing requests for relief, the staff suggests that the Licensee follow the attached Appendix A, "Inservice Inspection:
Guidance for Preparing Requests for Relief from Certain Code Requirements Pursuant to 10 CFR 50.55a(g)(5>".
Units I and 2:
For the relief requests listed in Section 3.5, "Code Relief," on pages 12 and 13 of the ISI Program Plans, the Licensee should provide the specific weld identification numbers for which relief is requested.
Also, these relief requests should be included in the formal submittal of requests for relief required in item D above, The Licensee should provide the above requested information and/or clarifications as soon as possible so that the review of the D.C.
Cook Nuclear Power Plant Units I and 2 Second 10-Year Interval Inservice Inspection Program Plans can be completed.
APPENDIX A INSERVICE INSPECTION:
GUIDANCE FOR PREPARING REQUESTS FOR RELIEF FROID CERTAIN CODE REQUIREMENTS PURSUANT TO 10 CFR 50.55a(g)(5)
A.
Descri tion of Re uests for Relief The guidance in this enclosure is intended to illustrate the type and extent of information that is necessary for "request for relief" of items that cannot be fully inspected to the requirements of Section XI of the ASYiE Code.
The inservice inspecticn program should identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitation of
- design, geometry, radiation considerations or materials of construction of the components.
The request for relief should provide the information requested in the followina section of this appendix for the inspections and pressure tests identified above.
B.
Re uest for Relief From Certain Inspection and Testino Requirements Many requests for relief from testing requirements submitted by licensees have not been supported by adequate descriptive and detailed technical information.
This detailed information is necessary to:
(I) document the impracticality of the ASNE Code requirements within 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 reouests 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 that is required to make a proper evaluation and to adequately document the basis for granting the relief in the Safety Evaluation Report.
Subsequent requests for additional
information and delays in completing th'e review can be considerably reduced if this information is provided initially in the licensee's submittal.
For each relief request submitted, the following information should be included:
1.
State when the request for relief would apply during the inspection period or interval (i.e., whether the request is to defer an examination.)
P.
State the time period for which the requested relief is needed.
3.
An itemized list of the specific component(s) and the examination requirement for which relief is requested.
4.
The number of items associated with the requested relief.
5.
The ASME Code Class, Examination Category, and Item Number(s).
6.
An identification of the specific ASIDE Code requirement that has been determined to be impractical.
7.
The information to support the determination that the requirement is impractical; i.e., state and explain the basis for reouesting relief. If the Code reouired examination cannot he performed because of a limitation or obstruction, describe or provide drawings showing the specific limitation or obstruction, and provide an estimate of'he percentage of the Code required examination that can be completed on the individual components requiring relief.
8.
An identification of the alternative examinations that are proposed:
(a> in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in compliance with the requirements of Section XI.
'9.
State when the proposed alternative examinations will be implemented and performed.
10.
A description and,iustification of 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 alternate examinations, discuss the impact on the overall level of plant quality and safety.
Technical.iustification or data must be submitted to support the relief request.
Opinions without substantiation that a chanoe will not affect the quality level are unsatisfactory.
If the relic< is requested for inaccessibility, a detailed description or drawing which depicts the inaccessibility must accompany the request.
A relief request is not required for tests prescribed in Section XI that do not apply to your facility.
A statement of "0/ A" (not applicable> or "none" will suffice.
C.
Re uest for Relief'or Radiation Considerations Exposures of test personnel to radiation to accomplish the examinations prescribed in Section XJ of the ASME Code can he'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, the following information with 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 which might reduce radiation levels.
4.
A proposal for alternate inspection technique's.
5.
A discussion of the considerations involved in remote inspections.
6.
Similar welds in redundant systems or similar welds in the same systems which can be inspected.
7.
The results of preservice inspection and any inservice results for the welds for which the relief is beino reauested.
A.
A discussion of the failure consequences o~ the we1d which would not receive the Code required examination.