ML19332C305

Forwards Request for Addl Info Re Rev 1 to First 10-Yr Interval Inservice Insp Program Plan & Associated Relief Requests Submitted by .Response Requested within 45 Days of Receipt of Ltr

ML19332C305
Person / Time
Site:	Beaver Valley
Issue date:	11/20/1989
From:	Tam P Office of Nuclear Reactor Regulation
To:	Sieber J DUQUESNE LIGHT CO.
References
TAC-62873, NUDOCS 8911270129
Download: ML19332C305 (6)

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4 LDocket No. 50-412 Mr. J. D.: Sieber, Vice President Nuclear Group Duquesne Light Company' Post Office Box.4 Shippingport, Pennsylvania 15077

SUBJECT:

BEAVER-VALLEY UNIT 2 REQUEST FOR ADDITIONAL INFORMATION FOR FIRST TEN-YEAR INSERVICE INSPECTION PROGRAM (TAC 62873)

By letter dated August 11 _1989, you provided the NRC with the Beaver Valley Power -Station, Unit 2 First 10-year Interval Inservice Inspection Program Plan, Revision 1, and associated relief requests.

As a result of our continuing review efforts on this issue, we developed additional information needs (see Enclosure).

Please respond to the questions in the enclosure within 45 days of receipt of this letter. We are, of course, available to discuss ~ any of these questions if you need any clarification.

The reporting and/or _recordkeeping requirements contained in this letter affect -fewer than ten respondents; therefore OMB clearance is not required under P.

L.'96-511.

Sincerely,

/s/

Peter 5. Tam, Senior Project Manager Project Directorate I-4 Division of Reactor Projects I/II Office of Nuclear Rector Regulation

Enclosure:

L As stated I'

cc w/ enclosure:

See next page 2Dschet4 File #

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- Duquesne Light Company-Units 1 & 2 CC:

' Jay.E. Silberg,-Esquire f;ureau of Radiation Protection Shaw, Pittman, Potts and Trowbridge Pennsylvania Department of 2300 N Street, N.W.

Environaental Resources Washington, DC 20037

- ATTN:

R. Janati Post Office Box 2063 Kenny Grada Manager Harrisburg, Pennsylvania 17120 Nuclear Safety Duquesne Light Company

- Mayor of the Borrough of P. O. Box 4 Shippingport-Shippingport Pennsylvania 15077 Post Office Box 3 Shippingport, Pennsylvania 15077 John A. Lee, Esquire Ashley C. Schannauer Duquesne Light Company Assistant City Solicitor One Oxford Centre City of Pittsburgh 301 Grant Street 313 City-County Building Pittsburgh, Fennsylvania 15279 Pittsburgh, Pennsylvania 15219

. W.F. Camichael, Comissioner Regional Administrator, Region I Department of Labor.

U.S. Nuclear Regulatory Comission 1800 Washington-Street East-475 Allendale' Road Charleston, West Virginia 25305 King of Prussia Pennsylvania 19406

- John D. Borrows Resident Inspector Director, Utilities Department U.S. Nuclear Regulatory Commission Public. Utilities Comission Post Office Box 181

. 180 East Broad Street Shippingport, Pennsylvania 15077 Columbus,. Ohio-43266-0573 Director, Pennsylvania Emergency Management Agency Post Office Box 3321 Harrisburg, Pennsylvania 17105-3321 L

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,j Enclosure.

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DUQUESNE LIGHT-COMPANY L

BEAVER VALLEY POWER STATION, UNIT 2

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L Reouest for Additional Information - First 10-Year Interval Inservice h

Inspection Proaram Plan I

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1.

Scoce/ Status of Review l-n

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Throughout the service life of a water-cooled nuclear power facility, 10 CFR-50.55a(g)(4)' requires that components (including supports)

L classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the' p

p requirements, except design and access provisions and preservice examination. requirements, set forth in the ASME Code Section XI, " Rules x

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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 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, h

subject to the limitations and modifications listed therein.

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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.

Based on the start date of November 17, 1987 for the first 10-year interval, the Inservice

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Inspection (ISI) Program Plan has been prepared to meet the requirements b

of the 1983 Edition, Summer 1983 Addenda (83S83) of the ASME Code Section XI except.that the extent of examination for Code Class 2 piping welds has been determined by ASME Code Case N-400, " Alternative Rules for Examination of Class 2 Piping." Code Case N-408 has been approved for use by the NRC by reference in Regulatory Guide 1.147.

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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 to the Nuclear j

Regulatory Commission (NRC) to support that determination.

The staff has reviewed the available information in the Beaver Valley l

Power Station, Unit 2, First 10-Year Interval Inservice Inspection J"

Program Plan, Revision 1, submitted August 11, 1989, and the requests for relief from the ASME Code Section XI-requirements which the Licensee j

has determined to be impractical.

2.

Additional Information/ Clarification Reauired Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the ISI Program and relief requests:

A.

Provide isometric drawings showing the piping welds and supports that Section XI_of the ASME Code requires to be examined during the first 10-year interval. These drawings, along with the weld listing.

providedlin the August 11, 1989 submittal, will permit the staff to determine if the extent of ISI examinations meets the applicable Code. requirements.-

B. ' 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.

From the information submitted in the August 11, 1989 submittal, the staff has not identified any CHR welds receiving ISI examinations during the first 10-year inspection interval.

Verify that the CHR system has not been completely exempted from ISI examinations and that a representative sample of

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- welds in this system will-receive examination during the first U

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10-year inspection. interval.

C.

Relief Request's BV2-83.40-1 and BV2-88.20-1:

Both of these requests -

for relief reference attached drawings, which are blank pages indicating' Westinghouse proprietary drawings. The August 11, 1989 cover: letter states-that these two drawings will be transmitted to the NRC-.under a separate cover letter. These drawings are required in order for the staff to evaluate the relief requests and determine

-if an impracticality ellsts..

4 D.

Relief Request BV2-B3.120-1 (Pressurizer Nozzle Inside Radius d

Sections) and Relief Request BV2-B3.14'0-1 (Steam Generator Nozzle j

L Inside Radius Sections): The Licensee has requested total' relief 1

from volumetric examination of the Class 1 Pressurizer and Steam i

Generator nozzle inside radius sections. Although the Licensee may

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not-have confidence in this examination for determining-the j

condition of the subject components, it has not supplied enough j

information'to establish that the Code-required volumetric examination is i_mpractical to perform.

If relief is.to be l

considered, sufficient technical justification demonstrating impracticality must be provided. -What attempts have been made to' q

obtain construction drawings, select transducers, and! perform the Code-required volumetric examination of the nozzle inner radius sections? If the full Code-required volumetric examination cannot j

be completed, describe a "best effort" volumetric examination that j

could be performed.

4 E.

Relief Request BV2-C1.10-3 (Recirculation Spray Pump - Shell j

Circumferential Welds) and Relief Request BV2-C6.10-1 (Recirettlation J

Spray Pump - Pump Casing Welds):

Please provide clarification with regard to why welds 2RSS-P21A-W-5, -9,

-10, -17, -18, and -19, in Relief Request BV2-C1.10-3, are considered by the Licensee to be f

Class 2 vessel welds requiring volumetric examination, while welds 2RSS-P21A-W-11, -12, -13, -15, -16, -21, -23, -24, and -25, in j

Relief Request BV2-C6.10-1, are considered by the Licensee to be Class 2 pump casing welds requiring surface examination.

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Relief Request'BV2-B9.31-1: Examination Category B-J, item B9.31, 3) requires both 100% surface and volumetric examinations of Class 1 branch connection welds NPS 4-inch or larger.

Confirm the. relief is

,p being requested for a partial volumetric examination only and that the Code-required surface examination will be performed.

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. G. ' Relief Request BV2-C3.30-1:. Provide an estimate of the percentage

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of theLCode-required surface examination that can and will be

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performed on the subject charging pump iritegrally welded attachments 1

during the first 10-year inspection interval.

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. The: schedule ~ for timely completion of this, review requires that the Licensee provide, by the requested date, the above requested information and/or clarifications with regard to the Beaver' Valley Power Station, j

Unit 2, First 10-Year Inservice Inspection Program Plan, Revision 1.

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Principal contributors:

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. George Johnson, with contractual assistance from Boyd Brown, INEL j

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