ML20138P088

Forwards Supplemental Exam Program Plan & Response to Outstanding Issues in Sser 3,Sections 5.2.4.3 & 6.6.3 Re Preservice Insp.Decision on Acceptability of Encl Requested by 860106

ML20138P088
Person / Time
Site:	Seabrook
Issue date:	12/20/1985
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Noonan V Office of Nuclear Reactor Regulation
Shared Package
ML20138P089	List: ML20138P088 ML20138P096
References
RTR-NUREG-0896, RTR-NUREG-896 SBN-909, NUDOCS 8512240289
Download: ML20138P088 (6)

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n SEABROOK STATION Engineering Office i

y .5l 5' December 20, 1985 Pub 5c Service of New Hampeo Now Hampshire Yonkee Divlelen SBN- 909 T.F. B7.1.2 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. Vincent S. Noonan, Project Director PWR Project Directorate No. 5

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC NUREG-0896, Supplement No. 3, " Safety Evaluation Report, Related to the Operation of Seabrook Station, Units 1 and 2," dated July 1985

. (c) PSNH Letter (SBN-876), "SER Outstanding Issues; Materials Engineering Branch (MtEB) Concerns," J. DeVincentis to G. W. Knighton, dated September 30, 1985

Subject:

Preservice (PSI) and Inservice (ISI) Inspection Program (SER Outstanding Issue No. 4 and Licensing Condition No. 4)

Dear Sir:

In References (b) and (c), further action was identified for both the PSI and ISI Programs. The following discusses the action which has been or will be taken to resolve these issues.

Regarding the PSI Program, please find enclosed Attachment A, which responds to the concerns identified in Sections 5.2.4.3 and 6.6.3 of Reference (b). As indicated in this attachment, also please find enclosed one copy of Seabrook's Supplemental Examir.ation Program Plan (SEPP), dated November 25, 1985. Since our PSI Program activities, temporarily halted due to hot functional testing, are scheduled to be resumed by mid-January 1986, we request a decision regarding the acceptability of the enclosed by January 6, 1986.

In the aforesaid sections of Reference (b), the staff also indicates that the ISI Program has not been submitted to the staff for review. As the staff is aware, the ISI Program uses the results of the PSI Program and uses the applicable ASME Code Editicn and Addenda determined from the date of issuance of the operating license [ Reference 10CFR50.55a (g)(4)(1)]. Therefore, we intend to submit the initial 120-month ISI Program to the staff for review within six months of the receipt of Unit l's operating license.

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If AD - J. KNIGliT (ltr only)

EB (BALLARD)

P.O. Box 300 . Sootyook.NH 03874 . Totephone (603)474 'EICSB ( ROSA)

PSB (GAmfILL)

HSB (BERLINGER)

FOB (DENAROYA)

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United. States Nuclear Regulatory Commission

? Attention :Mr. Vincent S.'Noonan^ Page-2

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e We believe that'the enclosed completes our; response to that portion'of the above' referenced SER Outstanding-Issue involving the above~ referenced SER l sections. : Accordingly, 'we also request' that' the resolution of.-these sections *

e. be reflected'in'the next supplement to'Seabrook: Station's SER.

Very truly yours,

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John DeVincentis, Director Engineering'and Licensing

. Enclosures cc ' Atomic Safety sud Licensing Board Service List s

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C IWilliam S.' Jordan,1 III Donald E. Chick Diane Curran Town Manager Harmon. Weiss & Jordan . Town of Exeter 20001-S. Street, N.W. 10 Front Street

-Suite 1430- Exetar, NH 03833 -

' Washing ton, D.C.. 20009 Brentwood Board of Selectmen .

Robert C. ! Perlis - RED Dalton Road b

0f fice of the Executive Legal Director Brentwood. NH< 03833 U.S. Nuclear Regulatory Commission

' Washington, DC 20555 Richard E. Sullivan, Mayor City Hall Robert A. Backus, Esquire Newburyport, MA 01950 116 Lowell Street P.O.' Box 516 Calvin A. Canney Manc hester, NH . 03105 City Manager City Hall Phill'p Ahrens, Esquire ~ 126 Daniel Street Assistant Attorney General Portsmouth, NH 03801

. Augusta, ME . 04333 Dana Bisbee, Esquire Mr. John ' B. Tanser Assistant' Attorney General Designated Representative of Office of the Attorney General .

the Town of Hampton. 206 State House Annex-5 Morningside Drive Concord, NH 03301 Hampton NH 03842 Anne Verge, Chairperson Roberta C. Pevear Board of Selec tmen Designated Representative of Town Hall the Town of Hampton Falls South Hampton, NH 03827 Drinkwater Road Hampton Falls, NH 03844 Patrick J. McKeon Selectmen's Office 1

Mrs. Sandra Cavutis 10 Central Road Designated Representative of Rye, NH 03870 the Town of Kensington -

RFD 1 Carole F. Kagan, Esquire East Kingston, ini 03827 Atomic Safety and L4 censing Board Panel U.S. Nuclear Regulatory Commission EJo Ann Shotwell, Esquire Washington, DC 20555 Assistant Attorney General

Environmental Protection Bureau Hr. Angt Machiros Department of . the Attorney General Chairman of the Board of Selectmen One Ashburton Place, 19th Floor Town of Neubury Boston, MA 02108' Newbury, MA 01950 Senator Corfon J. Humphrey Town Manager's Office

. U.S. Senate Town Hall - Friend Street Washington, DC 20510 Amesbury HA 01913 (ATTN!- Tom Burack)

Senator Cordon J. Humphrey Diana P. Randelt 1 Pillsbury Street 70 Collins Street Concord, NH 03301 Seabrook, NH 03874 (ATTN: Herb Boynton)

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ATTACHMENT A SBN- 909 Response to SSER-3 PSI Concerns SER Sections 5.2.4.3 and 6.6.3

). Item l'- Ultrasonic Examination of Cast Stainless Steel RCPB FittingJ Issue FSAR Table 5.2-2, " Material Specifications Class 1 Primary Components," shows the use of cast stainless steel (SA-351, Gr CF8A) fittings.. Paragraph 2.2, Table 2.2, in the PSI program for examination of the Reactor Coolant System (Document 80A8983) discusses exceptions from the ASME Code-required ultrasonic examination of cast austenitic stainless steel fitting and component welds in the-primary piping systems. Table 2.2 states that the wrought pipe-to-cast elbow or cast pump stainless steel welds will be examined with a one-side, 1/2-voe ultrasonic examination from the pipe side, and the cast side may not be examined because of metallurgical constraints (large grain structure that produces a high' degree of scatter and attenuation of ultrasound). This table also states.that the cast elbow-to-cast pump wolds will not receive an ultrasonic examination because of these constraints.

A one-side, 1/2-voo examination does not meet the code requirements. The

. staff recognizes that the ultrasonic examination of cast stainlass stool fittings and components may be difficult. However, a PSI with the best available instrumentation with straight beam and angle beam techniques should be attempted and documented on all welds in accordance with Section XI requirements. A technical justification is required if the examination is performed from the pipe side only.

In Table 2.4, which lists reference calibration standards, only SA-376, Gr 304N calibration blocks have been identified. The program tables indicate that the cast stainless stool fittings to pipe wolds will bo examined with these wrought stainless steel calibration standards. Calibration blocks for fitting to nozzle safe end welds are to be identified "later." Calibration blocks should be available for each type of material (i.e., ferritic, cast or wrought) that is representative of both sides of the wold. The applicant

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'should describe the measures that were taken (i.e. , using the best available refracted longitudinal waves transducers) to determine that a meaningful ultrasonic examination cottd not be performed from the cast side of those welds. Copios of the ultrasonic testing procedures for the primary piping welds should be provided for staff review.

Response

We will ultrasonically examino those welds and document the examination results as part of the DOP PSI Program.

In support of this ultrasonic examination:

o Cast stainless stoel material has boon acquired and fabricated into a calibration block, o A UT procedure to examino wolds to cast stainless stool fittings and components is being developed and is expected to be issued by the end of December. This procedure will be mado available for staff review out of our Dothesda Licensing office.

k ATTACHMENT A S8N-909 Response to SSER-3 PSI Concerns

-SFR Sections 5.2.4.3 and 6.6,3 (continued)

F Item 2 - Visual Examination procedure 80A647AM Issue

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Visual Examination Procedure 80A6474 states that "at least one member of a visual examination team shall be certified to at least Level II and shall have possed his/ hor visual acuity examination in accordance with the minimum quallfication requirements of Nuclear Energy Services (NES) Document 80A9069 (latest. revision)." The applic nt should clarify the above, since ASME Code,Section XI, Paragraph IWA-2300 requires that all nondostructivo examination personnel for all methods be certified to at least Level I and be examined by qualified persor.nel to ensure the required near-distance visual acuity. In addition, personnel qualified for Vf-2, VT-3 and VT-4 shall receive a visual examination to ensure far-distance acuity. Visual oxaminations must be conducted annually.

Response

Paragraph 4 of the subject procedurc will be revised to road as follows:

Visual examination personnel shall be certified in accordance with the latest revision of NES Document No. 00A9067 At least one member of a visual-examination team shall be certified to at least Lovel II in accordance with the latest revision of NES Documuet 80A9069.

MItem is common to both SER sections referenced.

[ tem 3 - Ultrasonic Examination of Cortain Class 2 pipinq Wolds Issu3 10CFR50.55(o)(2)(iv) requires that ASMC Codo, Class 2 piping welds in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC) and Containment Heat Removal (CHR) Systems shall be examined. The staff review of the PSI program shows extensive numbers of surface-only examinations for Class 2 piping wolds in the safety injection, chemical and volumo control, and Containment Spray Systems. Those systems should not be completely exempted from preservice volumotric examination based on Section XI exclusion criteria contained in Paragraph IWC-1220. To satisfy the inspection requirements of GDC 36, 39, 42 and 45, the PSI program must include volumotric examination of a representative samplo of wolds in the RHR, ECC and CHR Systems. The PSI program should be revised to include a volumotric examination of a representative sample of the wolds in those systems.

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' ATTACHMENT A - SBN-909 =

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Il Response to SSER-3 PSI Concerns b '

-SEN Sections 5.2.4.3 and 6.6.3 ' *

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Item 1 -) Continued-4: .

. Response

, (In' lieu of rew'i' sing' the. BOP-PSI programi we have developed a supplemental 5  ; examination' program. .This program is in our " Supplemental Examination Program

Plan," dated November 25, 1985, .provided herewith.

,-- In general l terms this' SEPP:

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[l, (1):'provides:a general text which relates to the overal1' examination: '

1 requirements for individual piping systems and system-specified-

.g examinations; " - i

-(2) : provides procedures for performance and documentation of the examinations-e s; and

, (3) discusses the requirements which form the bases for the development of f

^ the plan and the technical scope of examinations to satisfy these requirements.-

!It'should be noted that Code Case N-40s was used as guidance in selecting welds to be UT examined for.those portions of Reactor Makeup Water.(RMW),

Safety Injection (SI), Containment Building Spray (CBS) and Chemical and r

Volume Control (CVC) which'are nocessary for'RHR, ECC and CHR i  !

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