ML20045H165

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Requests Addl Info Re Request That NRC Review & Accept Plant ISI Program Plan,Rev 0 & Associated Requests for Relief from ASME Boiler & Pressure Vessel Code,Section XI
ML20045H165
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 07/12/1993
From: Steven Bloom
Office of Nuclear Reactor Regulation
To: Tira Patterson
OMAHA PUBLIC POWER DISTRICT
References
TAC-M84936, NUDOCS 9307190148
Download: ML20045H165 (7)


Text

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C Docket No. 50-285 July 12, 1993 Mr. Terry-L. Patterson 4

Division Manager - Nuclear Operation Omaha'Public Power District 444 South 16th Street Mall Mail Stop 8E/EP 4 Omaha, Nebraska 68102-2247 i

Dear Mr. Patterson:

S BJECT: THIRD 10-YEAR INTERVAL INSERVICE INSPECTION (ISI) PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF (TAC NO. M84936)

By letter dated November 13, 1992, you requested that the NRC review and accept the Fort Calhoun Station (FCS) ISI Program Plan, Revision 0 and associated requests for relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME) Code,Section XI. To continue our review we request additicnal information from you. The enclosed information questions were discussed by the NRC staff and the Omaha Public Power District staff on June 23, 1993. As discussed during the telecon, we ask that your responses to our request for additional information (RAI) to be submitted within 60 days.

In addition, to expedite the review process, please send a copy of the RAI response to our contractor, INEL, at the following address:

Boyd W. Brown EG&G Idaho, Inc.

INEL Research Center 2151 North Boulevard Post Office Box 1625 Idaho falls, Idaho 83415-2209

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If you have any questions about this nutter, please do not hesitate to call me at (301) 504-1313. This requirement affects fewer than 10 respondents and, therefore, is not subject to Office of Management and Budget review under Public Law 96-511.

Sincerely, ORIGINAL SIGNED BY:

Steven D. Bloom, Project Manager o h O$$ $$$[$$g6 Project Directorate IV-1 Q

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July 12, 1993 1

Docket No. 50-285 Mr. Terry L. Patterson Division Manager - Nuclear Operation Omaha Public Power District 444 South 16th Street Mall Mail Stop BE/EP 4 Omaha, Nebraska 68102-2247 l

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Dear Mr. Patterson:

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SUBJECT:

THIRD 10-YEAR INTERVAL INSERVICE INSPECTION (ISI) PROGRAM PLAN AND l

ASSOCIATED REQUESTS FOR RELIEF (TAC NO. M84936) l By letter dated November 13, 1992, you requested that the NRC review and accept the Fort Calhoun Station (FCS) ISI Program Plan, Revision 0 and associated requests for relief from the American Society of Mechanical 4

Engineers Boiler and Pressure Vessel (ASME) Code,Section XI. To continue our review we request additional information from you. The enclosed information questions were discussed by the NRC' staff and the Omaha Public Power District staff on June 23, 1993.

As discussed during _the telecon, we.ask that your responses to our request for additional information.(RAI) to be submitted i

within 60 days.

In-addition, to expedite the review process, please send a copy of the RAI response to our contractor, INEL, at the following address:

lly Boyd W Brown EG&G Idaho, Inc.

INEL Research Center 2151 North Boulevard Post Office Box 1625 Idaho Falls, Idaho 83415-2209 If you have any questions about this matter, please do not hesitate to call me at (301) 504-1313. This requirement affects fewer than 10 respondents and, therefore, is not subject to Jffice of Management and Budget review under Public Law 96-511.

Sincerely, u

[evh D. Bloom, Project Manager Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation

Enclosure:

i As stated cc w/ enclosure:

See next page

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Mr. Terry L. Patterson Omaha Public Power District Fort Calhoun Station, Unit No. 1 cc:

Harry H. Voigt, Esg.

LeBoeuf, Lamb, Leiby & MacRae

~1875 Connecticut Avenue, NW Washington, D.C.

20009-5728 Mr. Jack Jensen, Chairman Washington County Board of Supervisors Blair, Nebraska 68008 Mr. Raymond P. Mullikin, Resident Inspector U.S. Nuclear Regulatory Commission Post Office Box 309 Fort Calhoun, Nebraska 68023 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations Combustion Engineering, Inc.

12300 Twinbrook Parkway, Suite 330 Rockville, MD 20852 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas. 76011 Harold Borchert, Director Division of Radiological Health Nebraska Department of Health 301 Centennial Mall, South Post Office Box 95007 Lincoln, Nebraska 68509 Mr. James W. Chase, Manager Fort Calhoun Station Post Office Box 399 Fort Calhoun, Nebraska 68023

F ENCLOSURE OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT 1 DOCKET NO. 50-285 Reauest for Additional Information - Third 10-Year Interval Inservice Inspection Proaram Plan 1.

Scope / 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 Boiler and Pressure Vessel (ASME) Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in the 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 the successive 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 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.

The licensee, Omaha Public Power District, has prepared the Fort Calhoun Station, Unit 1, Inservice Inspection (ISI) Program Plan to meet the requirements of the 1989 Edition of Section XI of the ASME Code, except that the selection of Class 1 and Class 2 pressure retaining piping welds is in accordance with the requirements of the 1974 Edition through Summer 1975 Addenda (see question 'B' below)

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief, the licensee shall submit information to the Nuclear Regulatory Commission (NRC) to support that determination.

The staff has reviewed the available information in the fort Calhoun Station, Unit 1, Inservice Inspection Program Plan for the 1993-2003 Interval, submitted November 13, 1992.

2.

Mditional Information 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 Plan:

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A.

Fort Calhoun Station, Unit 1, Inservice Inspection Program Plan for the 1993-2003 Interval, Paragraph 1.2.2, states that the specific components to be examined for each class shall be identified in the fort Calhoun Station, Unit 1, Ten-Year Inservice Examination Plan by title and/or number.

Please provide a complete copy of the subject Ten-Year Inservice Examination Plan for staff review.

B.

Paragraph 1.3.3 of the Fort Calhoun Station, Unit 1, Inservice Inspection Program Plan for the 1993-2003 Interval states that:

" Selection of Class 1 and Class 2 pressure retaining piping welds for examination shall be in accordance with the requirements of the 1974 Edition of Section XI, Summer of 1975 Addenda."

10 CFR 50.55a(b)(2)(ii) permits the use of the 1974 Edition, Summer 1975 Addenda, for the selection of Code Class 1 Examination Category B-J welds if the facility's application for a construction permit was docketed prior to July 1, 1978. However, this option is not allowed by the regulations for Code Class 2 piping welds when the Code of record is the 1989 Edition.

Please provide further clarification regarding the acceptability of using the 1974 Edition, Summer 1975 Addenda for the selection of Code Class 2 piping welds.

C.

Provide the staff with the Boundary Diagrams that define.the ASME Code Class 1, Class 2, and Class 3 boundaries for the systems in the Fort Calhoun Station, Unit 1, Third 10-Year Interval ISI Program Plan.

Color coded Boundary Diagrams are preferred if available.

D.

Provide isometric and/or component drawings showing the Code Class 1 and Class 2 piping welds, components, and supports that Section XI of the ASME Code requires to be examined during the third 10-year inspection interval.

E.

If the information is not included in the fort Calhoun Station, Unit 1, Ten-Year Inservice Examination Plan, as identified in paragraph 'A' above, provide the staff with an itemized listing of the components subject to examination during the third 10-year interval. The requested listing, along with the requested isometric / component drawings, will permit the staff to determine if the extent of ISI examinations meets the applicable Code requirements.

F.

Provide a list of the ultrasonic calibration standards being used during the third 10-year interval ISI at Fort Calhoun Station, Unit 1.

The list should include the calibration standard identifications, material specifications and sizes.

G.

Augmented examinations have been established by the NRC when added assurance of structural reliability is deemed necessary.

Examples of documents that address augmented examinations are:

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Branch Technical Position MEB 3-1, High Energy fluid Systems, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment; 2.

Regulatory Guide 1.14, Reactor Coolant Pump Flywheel Integrity; and 3.

Regulatory Guide 1.150, Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations.

Address the degree of compliance with these and any other augmented examinations that may have been incorporated in the fort Calhoun Station, Unit 1, Third 10-Year Interval Inservice Inspection Program Plan.

H.

Effective September 8, 1992, new regulations were issued regarding the augmented examination of reactor vessels. As a result of these regulations, all licensees must augment their reactor vessel examinations by implementing once, as part of the inservice inspection interval in effect on September 8, 1992, the examination requirements for reactor vessel shell welds specified in Item Bl.10 of Examination Category B-A.

In addition, all previously granted relief for Item Bl.10, Examination Category B-A for the interval in effect on September 8,1992, are revoked by the new regulation.

For-licensees with fewer than 40 months remaining in the interval on the effective date (e.g., Fort Calhoun Station, Unit 1), deferral of the augmented examination is permissible with the conditions stated in the regulations.

Please provide the staff with the projected schedule and a technical discussion describing how the regulations will be implemented for these welds during the third 10-year interval.

Include in the discussion a d scription of the intended approach and any specialized techniques or equipment that will be used to complete the required augmented examination.

I.

Paragraph 10 CFR 50.55a(b)(2)(iv) states 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 excluded from inservice volumetric examination based on wall thickness. The staff has previously determined that a 7.5% augmented volumetric examination sample constitutes an acceptable resolution at similar plants.

Confirm that these systems, or portions of these systems, are not being excluded from volumetric examination. Also, please provide a summary table containing the total number of welds and the type of Code-required examinationn being performed in the RHR, ECC, and CHR systems. The requested table will permit the staff to determine if the extent of ISI examinations meets the applicable j

requirements.

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The Fort Calhoun Station, Unit 1, Inservice Inspection Program Plan for the 1993-2003 Interval contains four Appendices:

Appendix 1A - Exceptions to Compliance with Subsection IWA Appendix IB - Exceptions to Compliance with Table IWB-2500-1 Appendix IB - Exceptions to Compliance with Table IWC-2500-1 Appendix 1B - Exceptions to Compliance with Table IWD-2500-1 These Appendices contain brief discussions of areas where the licensee has taken exception to Code Section XI requirements. As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical, the licensee should request relief and submit information to the NRC to support that determination.

Each request for relief should contain adequate information to act as a " stand alone" document.

If relief is required, the licensee should submit the requests at this time for staff review.

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).

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