ML20140G611

Forwards Corrected Request for Addl Info Re Millstone,Unit 2 Third 10-yr Interval Inservice Insp Program.Correction Due to Administrative Error Including Missing Page

ML20140G611
Person / Time
Site:	Millstone
Issue date:	06/11/1997
From:	Mcdonald D NRC (Affiliation Not Assigned)
To:	Carns N NORTHEAST NUCLEAR ENERGY CO.
References
TAC-M96200, NUDOCS 9706160377
Download: ML20140G611 (8)

Text

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Mr. Neil S. Carns June 11, 1997 Senior Vice President .

and Chief Nuclear Officer I Northeast Nuclear Energy Company c/o Ms. Patricia A. Loftus Director - Regulatory Affairs P.O. Box 128 Waterford, CT 06385

SUBJECT:

CORRECTED REQUEST FOR ADDITIONAL INFORMATION REGARDING MILLSTONE UNIT 2 THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM (TAC NO. M96200)

Dear Mr. Carns:

By letter dated May 15, 1997, we requested additional information (RAI) regarding the Millstone Unit 2 third 10-year interval inservice inspection program. Due to an administrative oversight, the RAI was missing a page and included a duplicate second page.

The RAI has been corrected. Please replace the RAI, as the enclosure to our May 15 letter, with the enclosed revised RAI.

We regret any inconvenience this may have caused.

Sincerely, original signcd by:

Daniel G. Mcdonald, Senior Project Manager Special Projects Office - Licensing Office of Nuclear Reactor Regulation Docket No. 50-336

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Director - Regulatory Affairs P.O. Box 128 Waterford, CT 06385 ,

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SUBJECT:

CORRECTED REQUEST FOR ADDITIONAL INFORMATION REGARDING MILLSTONE l UNIT 2 THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM l

(TAC NO. M96200)

Dear Mr. Carns:

l l

By letter dated May 15, 1997, we requested additional information (RAI) regarding the Millstone Unit 2 third 10-year interval inservice inspection I program. Due to an administrative oversight, the RAI was missing a page and I included a duplicate second page, i

The RAI has been corrected. Please replace the RAI, as the enclosure to our l i May 15 letter, with the enclosed revised RAI.

de regret any in, convenience this may have caused.

Sincerely, i

l 1

Daniel G. Mcdonald, Senior Project Manager Special Projects Office - Licensing Office of Nuclear Reactor Regulation Docket No. 50-336

Enclosure:

As stated l

cc w/ encl: See next page l

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SECOND RE0 VEST FOR ADDITIONAL INFORMATION j THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN MILLSTONE NUCLEAR POWER STATION. UNIT N0. 2 NORTHEAST NUCLEAR ENERGY COMPANY l DOCKET NUMBER 50-336 l

l 1. Scoce/ Status of Review l

The U.S. Nuclear Regulatory Commission (NRC) is responsible for the review and disposition of licensee requests relating to inservice

! inspection (ISI) requirements contained in Title 10 of the Code of l Federal Reaulations (10 CFR), Section 50.55a, and the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code or ASME Code),Section XI. In each request, licensees are required to provide both a regulatory basis (by citing the appropriate section of

10 CFR 50.55a) and a technical discussion supporting the request. This l information is used to establish the context for each evaluation.

l The NRC staff has reviewed the information submitted by Northeast Utilities (NU) in its letters dated July 2 and March 20, 1997, and found l that additional information is required to complete the review.

i l 2. Additional Information Reauired Further information and/or clarification of the March 20, 1997, NU response to the NRC staff's initial request for additional information is needed. Please respond to the following:

2A. In the NU's response regarding the apparent conflict between the ISI program and the Code requirement to examine a percentage of reactor pressure vessel studs each period (Reference Response E.),

NU stated that relief should not be required as they are meeting Code requirements. Sased on the current industry implementation of r Examination Category B-G-1, through the 1989 Edition, the :,taff does l not agree with the licensee's position. The 1989 Edition of the l Code has five items for reactor vessel bolting. NU has not l addressed the volumetric examination, Jtem B6.20, Closure Studs,

inplace, which does not allow deferral. For pressurized water reactors, all studs are typically removed each refueling outage.

i item B6.30 Closure Studs, when removed, inc1udes the note that q deferral is permissible. However, it is understood that deferral of i

the subject examinations is only acceptable when the component disassembly is scheduled at the end of the interval.

\ Enclosure

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Although later editions of the Code state that deferral is permissible, the NRC Staff has not approved this change. In addition, it has been noted that in later editions of the Code (1995 Edition), the Table for Examination Categorf B-G-1 is incomplete as Note 5 has been eliminated. In later editions of the Code, IWB-2412 Inspection Program B, maintains that the required percentage in each Examination Category shall be completed in accordance with Table IWB-2412-1 with the following exception.

Item (4) states, " examinations dcferred until disassembly of a component for maintenance, repair, or volumetric examination, as allowed by Examination Categories B-G-1, B-G-2, B-L-2, and B-M-2.

If there are less than three items or welds to be examined in an Examination Category, the items or welds may be examined in any two periods, or in any one period if there is only one item or weld, in lieu of the percentage requirements of Table IWB-2412-1."

Considering that all reactor pressure vessel closure head studs are removed each refueling outage (54 studs), NU can perform the required examinations each period. As a result, the basis for deferral of all of the closure head studs until the end of the interval is not supported. For the NRC Staff to find this'part of the NU's program acceptable, NU must schedule a sample of reactor pressure vessel closure studs for examination each period in accordance with Table IWB-2412-1. Provide the action NU proposes to take regarding the scheduling of the reactor pressure vessel closure head studs.

28. In accordance with 10 CFR 50.55a(c)(3), 10 CFR 50.55a(d)(2), and 10 CFR 50.55a(e)(2), ASME Code cases may be used as alternatives to Code requirements. Code cases that the NRC has approved for use are published in Regulatory Guide 1.147, Inservice Inspectfon Code Case Acceptability, with any additional conditions the NRC may have imposed. When used, these Code cases must be implemented in their entirety. ASME approved Code cases awaiting NRC acceptance and subsequent publication in Regulatory Guide 1.147 may be adopted only if the licensee requests, and the NRC authorizes, their use on a case-by-case basis.

Use of Code Cases not published in Regulatory Guide 1.147 may be acceptable when conditions deemed appropriate by the NRC are included; a licensee proposing the use of such alternative (s) must commit to meet these conditions.

NU has submitted a list of Code cases for implementation during the third interval. It is noted that NU requested and received approval for use of certain Code cases in the previous interval and NU requested that these requests remain approved for the third interval. For several of these cases, the use was approved provided that NU satisfy certain conditions. It is necessary that written commitments be provided for these conditions by NU. Therefore, NU I

_ . _ . _ _ _ . _ . . _ _ . _ _ . _ _ _ . . . _ . _ . . . . _ _ . _ _ _ _ _ _ . _ . _ . ~ . _ . _ . .

should review requests for implementing Code cases that have not yet been published in Regulatory Guide 1.147 and submit new requests for the third interval that include commitments for the appropriate conditions; this is necessary for the NRC to find the Code case (s) acceptable for implementation.

2C. It is noted that NU included Nozzle-to-Shell, Examination Category

B-D (NS-1 and NS-4), in Request for Relief RR-89-03. This request does not include a basis for relief for Examination Category B-D.

Is it the intent of NU to include Examination Category B-D in L

Request for Relief RR-89-03? If so, the request should be revised t to reflect this or a separate relief request provided for Examination Category B-D items. Take appropriate hetion regarding this discrepancy.

2D. In Request for Relief RR-89-10, NU has requested relief for' steam

. generator nozzle-to-shell welds. Based on a review of the information provided, it appears that the joint configuration, due to the steam generators' replacement,'is a heavy wall pipe butt weld. Provide a basis for the classification (Examination Category B-D) of the subject welds.

In addition, it appears that the replacement design did not take into account the inspectability requirement of the Code. The weld configuration, a nozzle boss-to-nozzle boss, does not appear to be conducive to ultrasonic examination. Describe the examination i technique for the subject welds. }

Because the volumetric examination provides limited coverage, the licensee should consider a VT-l' visual examination of the subject area of the nozzle interior as an alternative to the limited volumetric examination. The VT-1 visual examination could be performed during steam generator tube inspections. Provide the action NU proposes to take regarding the current relief and examination being proposed for the subject welds.

2E. For Request for Relief RR-89-17, NU has proposed an alternative to the Code-required removal of insulation on borated systems for VT-2 visual examinations during pressure tests. This alternative is similar to Code Case N-533. However, NU has proposed the following alternative for Class 2 borated systems. "Each inspection period Borated Class 2 system connections shall be VT-2, visually excmined at zero or static pressure with insulation removed."

The purpose of a VT-2 visual examination.is to look for evidence of leakage and, if leakage has occurred, to take corrective action.

Because certain Class 2 systems are relied on for the safe shutdown of a plant (i.e., provide emergency shutdown features), it is technically prudent to monitor the bolted connection integrity of these systems similar to Class I systems. -The NRC Staff has determined that because hydrostatic pressure test requirements can >

be satisfied by pressure tests performed at normal operating l

pressure and because the subject VT-2 test can be performed during refueling outages by looking for evidence of leakage, the subject insulation removal is not pressure test frequency. dependent.

Therefore, the requirement for insulation removal should be the same for both Class 1 and 2 borated systems and NU should commit to the removal of insulation and VT-2 visual examination of bolted connections in Class 1 and 2 systems borated for controlling reactivity each refueling outage. Confirm that insulation removal will be performed for both Class 1 and 2 borated systems each refueling outage.

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, Northeast Nuclear Energy Ccmpany Millstone Nuclear Power Station l Unit 2 l

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Lillian M. Cuoco, Esquire Mr. F. C. Rothen Senior Nuclear Counsel Vice President - Nuclear Work Services l Northeast Utilities Service Company Northeast Nuclear Energy Company P. O. Box 270 P. O. Box 128 Hartford, CT 06141-0270 Waterford, CT 06385 Mr. John Buckingham Ernest C. Hadley, Esquire Department of Public Utility Control 1040 B Main Street i Electric Unit P.O. Box 549 10 Liberty Square West Wareham, MA 02576 New Britain, CT 06051 Mr. D. M. Goebel Mr. Kevin T. A. McCarthy, Director Vice President - Nuclear Oversight Monitoring and Radiation Division Northeast Nucletr Energy Company Department of Environmental Protection P. O. Box 128 79 Elm Street Waterford, CT Oti385 Hartford, CT 06106-5127 Mr. M. L. Bowling, Jr.

Regional Administrator, Region I Millstone Unit No. 2 Nuclear U.S. Nuclear Regulatory Commission Recovery Officer 475 Allendale Road Northeast Nuclear Energy Company King of Prussia, PA 19406 P. O. Box 128 Waterford, CT 06385 l First Selectmen Town of Waterford Mr. J. K. Thayer Hall of Records Recovery Officer - Nuclear Engineering 200 Boston Post Road and Support Waterford, CT 06385 Northeast Nuclear Energy Company P. O. Box 128 Mr. Wayne D. Lanning Waterford, CT 06385 Deputy Director of Inspections Special Projects Office Mr. B. D. Kenyon l 475 Allendale Road President and Chief l King of Prussia, PA 19406-1415 Executive Officer l Northeast Nuclear Energy Company l Charles Brinkman, Manager P. O. Box 128 Washington Nuclear Operations Waterford, Connecticut 06385 ABB Combustion Engineering 12300 Twinbrook Pkwy, Suite 330 Mr. Allan Johanson, Assistant Director Rockville, MD 20852 Office of Policy and Management Policy Development and Planning Senior Resident Inspector Division Millstone Nuclear Power Station 450 Capitol Avenue - MS# 52ERN l c/o U.S. Nuclear Power Station P. O. Box 341441 Hartford, CT 06134-1441 P.O. Box 513 Niantic, CT 06357 I

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Northeast Nuclear Energy Company Millstone Nuclear Power Station Unit 2 cc:

Citizens Regulatory Commission ATTN: Ms. Susan Perry Luxton 180 Great Neck Road Waterford, Connecticut 06385 Deborah Katz, President Citizens Awareness Network P. O. Box 83 i Shelburne Falls, MA 03170 The Honorable Terry Concannon Co-Chair Nuclear Energy Advisory Council Room 4035 Legislative Office Building Capitol Avenue Hartford, Connecticut 06106 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, Connecticut 06070 Little Harbor Consultants, Inc.

Millstone - ITPOP Project Office P. O. Box 0630 Niantic, Connecticut 06357-0630