ML20063E213
| ML20063E213 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/02/1982 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8207130348 | |
| Download: ML20063E213 (5) | |
Text
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GPU Nuclear g
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P.O. Box 388 Forked River. New Jersey 08731 609-693-6000 Writer's Direct Dial Number:
July 2, 1982 Mr. Dennis M. Crutchfield Operating Reactors Branch #5 Division of Licensing U.S. Nucicar Regulatory Commission Washington, D.C.
20555
Dear Mr. Crutchfield:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inservice Inspection Additional Information
Reference:
(1) Letter, D.M. Crutchfield, NRC, to P.B. Fiedler, GPUN, dated April 26, 1982 As required by your correspondence of April 26, 1982 (Reference 1 above),
we are providing you with the additional information required.
Should you have any questions, please contact Mr. Michael Laggart, Supervisor Oyster Creek Licensing, at (609) 971-4643.
Very truly yours,
$d Peter'B. Fiedler Vice President and Director Oyster Creek PBF:BH:1se Attachment cc:
Mr. Ronald C. Haynes, Administrator
/
Region I U.S. Nuclear Regulatory Commission
[-Qy7 631 Park Avenue i
King of Prussia, PA 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 Dr. D. A. Outlaw Science Applications, Inc.
1710 Goodridge Drive McLean, Virginia 22102 8207130340 820702 PDR ADOCK 05000219 G
PDR GPU Nuclear is a part of the General Pubhc Utihties System
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RESPONSE TO NRC REQUEST FOR INFORMATION INSERVICE INSPECTION REVIEW Responses to NRC request for additional information in NRC letter (D. M. Crutchfield) to Oyster Creek (P. B. Fiedler) dated April 26, 1982, are given below.
The request for information is repeated below with each response.
(Numbering corresponds with your requests.)
1.
1.
Category B-G-1 and B-G-2 Items (pgs 3A-2, 4, 5, Ref. 2)
The extent of examinations proposed for pressure retaining bolting follows 1974 Code requirements.
Note 5 requests relief from the pertinent provisions of the 1974 Code.
Please clarify where relief from code requirements is necessary.
Response: Oyster Creek will perform all B-G-1 and B-G-2 examinations in accordance with the requirements of Section XI 1974 edition through Summer 1975 Addend a.
No request for relief will be required.
2.
Notes 6, 7, 9 and 10 (pgs 3A-9,10, Re f. 2)
These notes request relief from various provisions of the 1974 Code and instead, propose to perform the examinations as specified in later codes (1977 Code) up to and including the Summer 1978 Addenda (3).
Consideration should be given to updating to the Summer 1978 Addenda for the method of examination on each of the items for which relief has been requsted.
In these cases, relief would not be required.
Response (Note 6): Oyster Creek will perform volumetric examination as required by the 1974 edition, " Category B-H, Integral attachments for Vessels."
Consideration will be given to updating our program to a later code af ter the next refueling outage.
Response (Note 7): Vessel and Closure Head cladding inspection was eliminated in the Summer 1976 Addenda and all subsequent Editions and Addenda of the Code because (1) the cladding is not a pressure retaining component and is; therefore, not within the jurisdiction of the ASME Boiler and Pressure Vessel Code, and (2) the Vessel Interior examination (Item No. Bl.15, Examination Ca tegory B-N-1) assesses the general condition of the vessel cladding. Relief from Examination Ca tegory B-I-1 is therefore requested. Consideration will be given to updating our program to a later code af ter the next refueling outage.
Response (Note 9):
Oyster Creek's request for relief on Category B-O Welds (Pressure Retaining Welds in Control Rod Drive Housings) is based upon the fact J
that the component configuration is not condusive to volumetric examination as recognized by later editions of the code.
Consideration will be given to updating our program to a later code af ter the next refueling outage.
Response (Note 10):
The support attachments shall be volumetrically examined to the maximum extent possible in accordance with the 1974 Code.
l II.
1.
Category C-D, Pg 3B-1, Reference 2 Note 2 of page 3B-2 requests relief from the 1974 Code requirement to examine all Class 2 bolting 1-inch-diameter and greater, citing that the Summer 1978 Addenda, Category C-D specification is for bolting which is
greater than 2-inches-diameter.
Consideration should be given to updating to the Summer 1978 Addends for examination requirements.
In this case, relief would not be required.
Response
Dyster Creek will volumetrically examine bolting one inch and greater as requited by the 1974 edition of the code. Consideration will be given to updating the program af ter the next refueling outage.
II I. 1.
R1, Pg 3C-2, Reference 2 Relief is requested from the 1974 Code requirements to volumetrically examine integrally welded supports in Class 1 systems.
This request is based on a more up-to-date code specification for Category B-K-1 welds which allows volumetric or surface examinations as applicable.
Consideration should be given to updating to the Summer 1978 Addenda.
Re sponse:
Same response as Note 10, previous page.
2.
R2, Pg 3C-2, Reference 2 Relief is requested from examining Class 1 and Class 2 component connections, piping, and associated valves and vessels that are 3/8-inch nominal wall thickness or less.
The basis for relief is that volumetric examination of thin-walled pipe does not produce reliable results.
Please justify your position that no method of volumetric examination is reliable for thin-walled pipe. What consideration has been given to performing radiographic examinations of the welds subject to this request?
Re sp onse:
Oyster Creek's _ISI program will be revised to volumetrically examine thin walled piping as required by the code. All butt welds will be examined to the maximum extent practical contingent on design, configuration and material res trictions.
3.
R3, Pg 3C-3, Re ference 2 Re ference 4 committed to deleting this request for relief from your ISI Pro gram. What action has been taken to revise your program on this item?
Response
All Class 1 circumferential welds have been included in our examination percentages for the ISI program.
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l 4.
R4, Pg 3C-3, Re ference 2 Please clarify your request for relief from code requirements for " Class 2 components of systems or portions of systems that are required to operate above a pressure of 275 psig or temperature of 2000F except for limited periods...".
Response
Oyster Creek will examine Class 2 components in accordance with code requirements and will exempt components only as permitted by IWC-1220.
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5.
RS Pg 3C-3, Reference 2 This request for relief concerns Class 2 systems or portions of systems that during normal plant operating conditions are not required to operate or perform a system function but remain flooded under static conditions at or near their normal operating pressures. This request pertains specifically to nondestructive examination of the isolation condenser.
In Reference 4, you committed to nondestructive examination of isolation condenser piping greater than 4-inch NPS.
What action has been taken to include these examinations in your program?
Response
An augmented inspection program has been instituted which incorporates volumetric examination of welds equivalent to one complete stream (29 welds).
6.
R7, Pg 3C-4, Reference 2 Relief is requested from volumetric examination of branch pipe-to-pipe welded joints that are Class 1 and greater than 6-inches-diameter, or Class 2.
The basis for relief is that the physical design of branch connections does not permit meaningful volumetric examination, that this f act has been recog-nized by the 1977 Code, and the requirement for volumetric examination of branch connections has been dropped form the Code. The 1977 Code (Summer 1978 Addenda) requires the volumetric and surface examination of Class 1 branch pipe connection welds greater than 2-inch nominal pipe size.
The most recent version seems to have more stringent requirements, please clarify your position.
Also, please explain why radiography was rejected as a method for volumetric examination of branch connections.
For Class 2 pipe branch connections, have you considered updating to the Summer 1978 Addenda for examination require-ments?
Response: Oyster Creek will examine branch pipe-to-pipe welded joints in accordance with the requirements of the 1974 Code. Consideration will be given to updating our program to a later code af ter the next refueling outage.
GENERAL -- Responses to Previous NRC Requests for Additional Information(5) 7.
I Your responsel41 to NRC Requestt3) No. 7 is as follows:
"0yster Creek commits to define the extent and method of examination for all Class 1 and l
Class 2 categories as identified in Appendices 3A and 3B(2) by April 1981.
j These changes are part of the current revisions in-process. The revised i
program will be submitted to NRC."
l What action has been taken to issue a revised ISI Program for Oyster Creek?
l Please confirm that all commitments made in your responses to the previous l
RAI will be incorporated in the revised ISI Program. Also, please submit your revised ISI Program document as soon as possible, preferably within 60 days.
Response: A revised ISI program has been approved and implementation began in April, 1981.
This program incorporated all responses to previous RAI's.
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8.
Under the change in regulation 10 CFR 50.55a effective November 1,1979, your ISI program, when finally approved, will cover your current 10-year inspection interval (December 8,1979 to December 7,1989). Does this result in any changes you wish to make in your relief requests? Do you require other ISI relie f?
Response: All requests for relief for this inspection interval have been l
submitted.
If any further relief is required, it will be done via separate c orre spondence.
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