ML20150D529

Forwards Request for Addl Info Re Third 10-yr Interval Inservice Insp Program Plan.Info Requested within 60 Days of Receipt of Ltr

ML20150D529
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/18/1988
From:	Wang A Office of Nuclear Reactor Regulation
To:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO.
References
TAC-65687, NUDOCS 8803240320
Download: ML20150D529 (7)

Text

.

l Docket No. 50-213

~

MAR 1 S MIS Mr. Edward J. Mroczka Senior Vice President Nuclear Engineering and Operations Connecticut Yankee Atomic Power Company l i

P. O. Box 270 Hartford, Connecticut 06141-0270 l l

SUBJECT:

HADDAM NECK PLAN - REQUEST FOR ADDITIONAL INFORMATION  !

REGARDING INSERVICE INSPECTION PROGRAM PLAN (TAC N0. 65687) l The NRC has reviewed the Haddam Neck Plant Third Ten-Year Interval Inservice Inspection (ISI) Program Plan, as submitted by Connecticut Yankee Atomic Power Company. Based on this review we have determined that additional information  ;

is necessary to complete our review. Enclosed is our request for additional i information. Please submit this information within 60 days of receipt of this letter.

The reporting and/or recordkeeping requirements contained in this letter i affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

If you have any questions or coments, please contact me on (301)-492-1313.

Sincerely, I

Alan B. Wang, Project Manager Project Directorate I-4 Division of Reactor Projects I/II 1 l

Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure:

See next page f!j32jggg ggggg G PDR DISTRIBUTION

• Docket File F OGC-WF NRC & Local PDRs E. Jordan Gray File J. Partlow S. Varga ACRS(10)

8. Boger T. Shedlosky, Resident S. Norris C. Y. Cheng A. Wang G. Johnson LA PDI-4 s

, PM:PDI-4

bd 0

JS H

S 1 03/IS/88

' gAWang/88 03/f) 03 /88

6 .

• Mr. Edward J. Mroczka Connecticut Yankee Atomic Power Company Haddam Neck Plant cc:

Gerald Garfield, Esquire R. M. Kacich, Manager Day, Berry and Howard Generation Facilities Licensing Counselors at Law Northeast Utilities Service Company City Place Post Office Box 270 Hartford, Connecticut 06103-3499 Hartford, Connecticut 06141-0270 W. D. Romberg, Vice President D. O. Nordquist Nuclear Operations Parager of Quality Assurance Northeast Utilities Service Company Northeast Nuclear Energy Company Post Office Box 270 Post Office Box 270 Hartford, Connecticut 06141-0270 Hartford, Connecticut 06141-0270 Kevin McCarthy, Director Regional Administrator Radiation Control Unit Region I Department of Environmental Protection U. S. Nuclear Regulatory Commission State Office Building 475 Allendale Road Hartford, Connecticut 06106 King of Prussia, Pennsylvania 19406 Bradford S. Chase, Under Secretary Roard of Selectmen Energy Division Town Hall Office of Policy and Management Haddam, Connecticut 06103 80 Washington Street Hartford, Connecticut 06106 J. T. Shedlosky, Resident inspector Haddam Neck Plant D. B. Miller, Station Superintendent c/o U. S. Nuclear Regulatory Commission Haddam Neck Plant Post Office Box 116 Connecticut Yankee Atomic Power Company East Haddam Post Office RFD 1, Post Office Box 127E East Haddam, Connecticut 06423 East Hampton, Cor,necticut 06424 G. H. Rouchard, Unit Superintendent Haddam Neck Plant RFD #1 Post Office Box 127E East Hampton, Connecticut 06424 l

6 .

Connecticut Yankee Atomic Power Company Haddam Neck Plant Docket No. 50-213 Reauest for Additional Information Third-Ten-Year interval Inservice inspection Proaram Plan

1. The staff notes that the Licensee is not performino volumetric exami-nation of any of the Class 2 piping welds in the Residual Heat Removal, Chemical and Volume Control, Fioh Pressure Safety Injection, low Pressure Safety injection, and Containment Soray Systems.

Paragraph 10 CFR 50.5Fa(b)(?)(iv) requires that ASME Code Class 2 i 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 exempted from inservice volumet- i ric examination based on Section XI exclusion criteria contained ir j IWC-1220. Later editions and addenda of the Code require volumetric i 1

examination of Class 2 pipino welds greater than or eoual to 3/8-inch nominal wall thickness for piping greater than 4-inch nominal pipe size (NPS). The staff has previously determined that a 7.51 augmented volumetric sample constitutes an acceptable resolution at similar I plants. Verify that volumetric examination will be perforr:ed on at l least a 7.5% sample of the Class 2 piping welds in the RHR, Chemical and Volume Control, High Pressure Safety Injection, low Pressure Safety j Injection, and Contairment Spray Systems.

i

2. Section 2.2.2(C), "Piping Examination Requirements," of the ISI Program Plan describes the extent of examination for Category C-F welds of each Class 2 system, based on system, pipe size, and multiple stream concepts. It appears that, by the method used for determining the extent of examination, the number of welds scheduled for examination by the Licensee is less than the minimum number to be in compliance with the Code. It is the staff's position that the Code requirement is a minimum and that licensee; should not hesitate to exceed the minimum requirements. The following table lists examples of the Licensee scheduling a smaller number of welds for examination than the minimum Code requirement:

Average Number Number of Welds Number Pipe of Welds Req'd by of Welds Item # System / Streams Diameter Per Stre.gm Code (25%) Scheduled C5.11 RHR / A & B 8 inches 20.5 5.125 5 (suction)

C5.ll RHR / A & B 8 inches 29.5 7.375 7 (suction)

C5.ll RHR/ Single 8 inches 18 4.5 4 stream (discharge)

C5.ll CVC / A & B 6 inches 9 2.25 2 C5.11 HPSI / A & B 6 inches 17 4.25 4 C5.11 LPSI / A & B 10 inch 12.5 3.125 3 Additional welds should be scheduled, for cases like the examples above, in order to be at least in compliance with the minimum examination samples required by the Code.

3. Provide isometric and/or component drawings showing the welds, components, and supports which Section XI of the ASME Code requires be examined.

4. 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 isometric drawings requested above, is necessary to permit the staff to determine if the extent of ISI examinations meets the applicable Code requirements.

5. Provide a list of the ultrasonic calibration standards being used during the third 10-year interval ISI at the Haddam Neck Plant.

__. = -_

s This list should include the calibration standard identifications, material specifications, and sizes. I I

5. Provide a list of the nondestructive examination procedures that are being used during the third inspection interval. l

7. Revision 4 of Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," dated September 1985, is referenced in Section 1.1 of the ISI Program Plan. Verify that Revision 5 of Regulatory Guide 1.147, dated August 1986, will be referenced instead as some Code Cases endorsed by the NRC in the previous revision have either been deleted from l the list of acceptable Code Cases or are no longer endorsed by the NRC.

8. Section 2.1.2(0), "Reactor Coolant Pressure Boundary Piping," of the

{

ISI Program Plan states that: " ...some examinations are limited due I to geometric configuration or accessibility. . . .Generall y, these limitations exist at all fitting-to-fitting welds such as elbow-to-tee, elbow-to-valve, reducer-to-valve, etc., where geometry and sometimes surface conditions preclude ultrasonic coupling or access for the required scan length. The limitations exist to a lesser degree at pipe-to-fitting welds, where examination can only be fully performed from the pipe side, the fitting geometry limiting l or even precluding examination from the opposite side. No effort l has been made to identify individual welds in the ten-year plan where such restrictions exist. Welds having such restrictions will be examined to the extent practical."

If examinations are precluded due to limitations or obstructions, submit a request for relief from the Section XI requirements which includes: identification of the specific welds, a detailed description of the limitations or obstructions, a detailed technical justification for not performing the Code-required examination, and an estimate of the percentage of the Code-required examination that can be completed for each of the subject welds. Thejustification

- 4 for relief should include increasing the examination sample to make I up for portions not examined. l l

9. Relief Request No. 3-1: Based on the sketch attached to the relief j request, it appears that the ventilation shroud assembly on the Reactor Pressure Vessel could be removed to allow access for insulation removal and partial examination of the closure head peel segment-to-disc circumferential weld. Provide an estimate of the percentage of the Code-required examination that can be performed if the ventilation shroud assembly can be and is removed.

10. Relief Request No. 3 3 states: "In 1984, the Steam Generator No. 4 bottom head-to-tubesheet weld was ultrasonically examined. It was discovered that the calibration block and bottom head materials were different. An attempt was made to compensate for acoustic differences by measuring attenuation and adjusting instrument gain.

This attempt was unsuccessful; the gain required for equivalent sensitivity yielded inconsistent and unreliable data. The examination was void due to the incorrect calibration standard and inherent difficulties when examining cast materials.

In 1986, the Steam Generator No. 4 bottom head-to-tubesheet weld was ultrasonically examined using an automated ultrasonic system. Due to physical limitations of ti,e four steam generator support lugs,  ;

28 percent of the required vf.:me cannot be examined."

Discuss the calibration standard and procedure being used for the automated ultrasonic examination of the steam generator tubesheet-to-head weld.

11. In Relief Request Nos. 3-5 and 3-12, relief is requested from performing the Code-required volumetric examination because of the geometric configurations of the Class 1 nozzle inner radius sections on the pressurizer and the Class 1 and Class 2 nozzle inner radius sections on the steam generators.

. 1 a ..

l If relief from examining the nozzle inner radius sections is to be considered, sufficient technical justification must be provided.

What attempts have been made to obtain construction drawings, to select transducers, and to perform the Code-required volumetric examination of the nozzle inner radius sections? If the full Code-required volumetric examination cannot be completed, describe a "best-effort" volumetric examination that could be performed.

l l

I

, - - - - - , ,. __ _ - .__n--. -.--g-