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Information Request February 13, 2020 Notification of Inspection and Request for Information Comanche Peak Unit 2 NRC Inspection Report 05000446/2020002

ML20045E351
Person / Time
Site:	Comanche Peak
Issue date:	02/13/2020
From:	Isaac Anchondo NRC Region 4
To:
Taylor N
References
IR 2020002
Download: ML20045E351 (7)

See also: IR 05000446/2020002

Text

ML20045E351

PAPERWORK REDUCTION ACT STATEMENT

This letter contains mandatory information collections that are subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)

approved these information collections (approval number 3150-0011). Send comments

regarding this information collection to the Information Services Branch, Office of the Chief

Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,

DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office

of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and

Budget, Washington, DC 20503.

Public Protection Notification

The NRC may not conduct nor sponsor, and a person is not required to respond to, a request

for information or an information collection requirement unless the requesting document

displays a currently valid OMB control number.

Information Request

February 13, 2020

Notification of Inspection and Request for Information

Comanche Peak Unit 2

NRC Inspection Report 05000446/2020002

INSERVICE INSPECTION DOCUMENT REQUEST

Inspection Dates: TBD

Inspector: Isaac Anchondo

A. Information Requested for the In-Office Preparation Week

The following information should be sent to the Region IV office in hard copy or electronic

format or via a secure document management service, in care of Isaac Anchondo, by April

6, 2020, to facilitate the selection of specific items that will be reviewed during the onsite

inspection week. The inspector will select specific items from the information requested

below and then request from your staff additional documents needed during the onsite

inspection week. We ask that the specific items selected from the lists be available and

ready for review on the first day of inspection. Please provide requested documentation

electronically if possible. If requested documents are large and only hard copy formats are

available, please inform the inspector(s), and provide subject documentation during the first

day of the onsite inspection.

If you have any questions regarding this information request, please call the inspector as

soon as possible.

On TBD, a reactor inspector from the Region IV office will perform the baseline inservice

inspection at Comanche Peak, Unit 2, using NRC Inspection Procedure 71111.08,

"Inservice Inspection Activities. Experience has shown that this inspection is a resource

intensive inspection both for the NRC inspector and your staff. The date of this inspection

may change dependent on the outage schedule you provide. In order to minimize the

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impact to your onsite resources and to ensure a productive inspection, we have enclosed a

request for documents needed for this inspection. The information identified on this request

(Section A) is to be provided prior to the inspection to ensure that the inspector(s) are

adequately prepared. The section identified as Documents Upon Request is intended to

provide guidance to the type of information an inspector(s) will be requesting to complete

the inspection following the initial request. It is important that all of these documents are up

to date and complete in order to minimize the number of additional documents requested

during the preparation and/or the onsite portions of the inspection (i.e., condition reports with

attachments).

We have discussed the schedule for these inspection activities with your staff and

understand that our regulatory contact for this inspection will be James Barnette of your

licensing organization. The tentative inspection schedule is as follows:

Preparation week: TBD

Onsite weeks: TBD

Our inspection dates are subject to change based on your updated schedule of outage

activities. If there are any questions about this inspection or the material requested, please

contact Isaac Anchondo at (817) 200-1152. (email: Isaac.Anchndo-Lopez@nrc.gov)

A.1 ISI/Welding Programs and Schedule Information

1. A detailed schedule (including preliminary dates) of:

1.1. Nondestructive examinations planned for ASME Code Class Components

performed as part of your ASME Section XI, risk informed (if applicable), and

augmented inservice inspection programs during the upcoming outage.

1.2. Examinations planned for Alloy 82/182/600 components that are not included in

the Section XI scope (If applicable)

1.3. Examinations planned as part of your boric acid corrosion control program

(Mode 3 walkdowns, bolted connection walkdowns, etc.)

1.4. Welding activities that are scheduled to be completed during the upcoming

outage (ASME Class 1, 2, or 3 structures, systems, or components)

2. A copy of ASME Section XI Code Relief Requests and associated NRC safety

evaluations applicable to the examinations identified above.

2.1. A list of ASME Code Cases currently being used to include the system and/or

component the Code Case is being applied to.

3. A list of nondestructive examination reports which have identified recordable or

rejectable indications on any ASME Code Class components since the beginning of

the last refueling outage. This should include the previousSection XI pressure test(s)

conducted during start up and any evaluations associated with the results of the

pressure tests.

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4. A list including a brief description (e.g., system, code class, weld category,

nondestructive examination performed) associated with the repair/replacement

activities of any ASME Code Class component since the beginning of the last outage

and/or planned this refueling outage.

5. If reactor vessel weld examinations required by the ASME Code are scheduled to

occur during the upcoming outage, provide a detailed description of the welds to be

examined and the extent of the planned examination. Please also provide reference

numbers for applicable procedures that will be used to conduct these examinations.

6. Copy of any 10 CFR Part 21 reports applicable to structures, systems, or

components within the scope of Section XI of the ASME Code that have been

identified since the beginning of the last refueling outage.

7. A list of any temporary non-code repairs in service (e.g., pinhole leaks).

8. Please provide copies of the most recent self-assessments for the inservice

inspection, welding, and Alloy 600 programs.

9. A copy of (or ready access to) most current revision of the inservice inspection

program manual and plan for the current interval.

10. Copy of NDE procedures for NDE that will be used during the outage.

11. Copy of overarching site procedure for welding.

A.2 Reactor Pressure Vessel Head (If Being Inspected, otherwise N/A)

1. Provide a detailed scope of the planned bare metal visual examinations (e.g., volume

coverage, limitations, etc.) of the vessel upper head penetrations and/or any

nonvisual nondestructive examination of the reactor vessel head including the

examination procedures to be used.

1.1. Provide the records recording the extent of inspection for each penetration

nozzle including documents which resolved interference or masking issues

that confirm that the extent of examination meets 10 CFR

50.55a(g)(6)(ii)(D).

1.2. Provide records that demonstrate that a volumetric or surface leakage path

examination assessment was performed.

2. Copy of current calculations for EDY, and RIY as defined in Code Case N-729-1

that establish the volumetric and visual inspection frequency for the reactor vessel

head and J-groove welds.

A.3 Boric Acid Corrosion Control Program

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1. Copy of the procedures that govern the scope, equipment and implementation of the

inspections required to identify boric acid leakage and the procedures for boric acid

leakage/corrosion evaluation.

2. Please provide a list of leaks (including code class of the components) that have

been identified since the last refueling outage and associated corrective action

documentation. If during the last cycle, the unit was shutdown, please provide

documentation of containment walkdown inspections performed as part of the boric

acid corrosion control program.

A.4 Steam Generator Tube Inspections

1. A detailed schedule of:

• Steam generator tube inspection, data analyses, and repair activities for the

upcoming outage (if occurring).

• Steam generator secondary side inspection activities for the upcoming outage

(if occurring).

2. Copy of SG history documentation given to vendors performing eddy current (ET)

testing of the SGs during the upcoming outage.

3. Copy of SG condition monitoring and operational assessment of previous cycle.

Also include a copy of the following documents as they become available for the

current cycle:

• Degradation assessment

• Condition monitoring assessment

4. Define the planned SG ET scope (e.g., 100 percent of unrepaired tubes with bobbin

probe and 20 percent sample of hot leg expansion transition regions with rotating

probe) and identify the scope expansion criteria, which will be applied.

5. Identify and quantify any SG tube leakage experienced during the previous operating

cycle. Also provide documentation identifying which SG was leaking and corrective

actions completed and planned for this condition.

6. Copy of steam generator eddy current data analyst guidelines and site validated

eddy current technique specification sheets. Additionally, please provide a copy of

EPRI Appendix H, Examination Technique Specification Sheets, qualification

records.

7. Copy of the guidance to be followed if a loose part or foreign material is identified in

the steam generators.

8. Provide past history of the condition and issues pertaining to the secondary side of

the steam generators (including items such as loose parts, fouling, top of tube sheet

condition, crud removal amounts, etc.).

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Indicate where the primary, secondary, and resolution analyses are scheduled to

take place.

A.5 Additional Information Related to all Inservice Inspection Activities

1. A list with a brief description of inservice inspection, and boric acid corrosion control

program related issues (e.g., PVAR) entered into your corrective action program

since the beginning of the last refueling outage. For example, a list based upon data

base searches using key words related to piping such as: inservice inspection,

ASME Code,Section XI, NDE, cracks, wear, thinning, leakage, rust, corrosion, boric

acid, or errors in piping examinations.

2. Provide training (e.g. Scaffolding, Fall Protection, FME, Confined Space) if they are

required for the activities described in A.1 through A.3.

3. Please provide names and phone numbers for the following program leads:

Inservice inspection (examination, planning)

Containment exams

Reactor pressure vessel head exams

Snubbers and supports

Repair and replacement program

Licensing

Site welding engineer

Boric acid corrosion control program

Steam generator inspection activities (site lead and vendor contact)

DOCUMENTS UPON REQUEST

Inservice Inspection / Welding Programs and Schedule Information

1. Updated schedules for inservice inspection/nondestructive examination activities,

including planned welding activities, and schedule showing contingency repair

plans, if available.

2. For ASME Code Class welds selected by the inspector please provide copies of the

following documentation (as applicable) for each subject weld:

• Weld data sheet (traveler).

• Weld configuration and system location.

• Applicable welding procedures used to fabricate the welds.

• Copies of procedure qualification records (PQRs).

• Welders performance qualification records (WPQ).

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• Nonconformance reports for the selected welds (If applicable).

• Radiographs of the selected welds and access to equipment to allow

viewing radiographs (if radiographic testing was performed).

• Preservice and inservice examination records for the selected welds.

• Readily accessible copies of nondestructive examination personnel

qualifications records for reviewing.

3. For ultrasonic examination procedures qualified in accordance with ASME Code,

Section XI, Appendix VIII, provide documentation supporting the procedure

qualification (e.g. the EPRI performance demonstration qualification summary sheets).

Also, include qualification documentation of the specific equipment to be used (e.g.,

ultrasonic unit, cables, and transducers including serial numbers) and nondestructive

examination personnel qualification records.

Reactor Pressure Vessel Head (If Being Inspected, otherwise N/A)

1. Nondestructive personnel qualification records for the examiners who will perform

examinations of the reactor pressure vessel head replacement. (If applicable)

2. Drawings showing the following:

• Reactor pressure vessel head and control rod drive mechanism nozzle

configurations

• Reactor pressure vessel head insulation configuration

Note: The drawings listed above should include fabrication drawings for the nozzle

attachment welds as applicable.

Boric Acid Corrosion Control Program

1. Boric acid walk down inspection results, an updated list of boric acid leaks identified so

far this outage, associated corrective action documentation, and overall status of

planned boric acid inspections.

2. List of boric acid evaluation and corrective action documents associated with the

leakage.

Steam Generator Tube Inspections

1. Examination Technique Specification Sheets and associated justification for any

revisions.

2. Copy of the eddy current testing procedures used to perform the steam generator

tube inspections (specifically calibration and flaw characterization/sizing procedures,

etc.).

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3. SG tube repair procedures and acceptance criteria

4. Procedures with guidance/instructions for identifying (e.g. physically locating the

tubes that require plugging) and plugging SG tubes.

5. List of corrective action documents generated by the vendor and/or site with respect

to steam generator inspection activities.

Codes and Standards

1. Ready access to (i.e., copies provided to the inspector(s) for use during the inspection

at the onsite inspection location, or room number and location where available):

• Applicable Editions of the ASME Code (Sections V, IX, and XI) for the

inservice inspection program and the repair/replacement program.

2. Copy of the performance demonstration initiative (PDI) generic procedures with the

latest applicable revisions that support site qualified ultrasonic examinations of piping

welds and components (e.g., PDI-UT-1, PDI-UT-2, PDI-UT-3, PDI-UT-10, etc.).

3. Boric Acid Corrosion Guidebook Revision 1 - EPRI Technical Report 1000975.