ML20195F009
| ML20195F009 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/08/1999 |
| From: | Terry C, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-99130, NUDOCS 9906140163 | |
| Download: ML20195F009 (6) | |
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- TXX-99130 File
- 10010.1, 905.2 (clo) i.
Ref.
- 10CFR50.55(a)(3)(i) l 7UELECTRIC 100FR50.55(g)(5)(iii)
C. Lance'Ibrry Senior Mce President
& PrincipalNuclear ODicer Jung 8,1gg9 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
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DOCKET NOS. 50-445 AND 50-446 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING UNIT 1 AND UNIT 2 INSERVICE INSPECTION PROGRAM RELIEF REQUESTS E-1 AND L-1 REF: 1) TXU Electric Letter, logged TXX-98041, from C. L. Teny, dated February 20,1998.
Gentlemen:
On February 20,1998, TXU Electric submitted Unit 1 and Unit 2 Relief Requests E-1 and L-1 (Reference 1). On May 17,1999, and May 28,1999, the NRC staff (D. Jaffe et al.) and TXU Electric (D. Buschbaum et al.) participated in a phone conference call to discuss open issues related to the subject relief requests. In the May 17,1999, phone conference call TXU Electric agreed to provided a written response to the requests for additional information (RAI)
Identified during the phone conference calls. TXU Electric's response to the RAI is Attached.
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9906140163 990600 PDR ADOCK 05000445 G
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COMANCHE PEAK SILAM ELECTRIC STATION i
P.O. Box 1002 Glen Rose. Texas 76043-1002
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g-TXX-99130 Page 2 of 2 If you have any questions please contact Ben Mays at (254) 897-6816 or Carl Corbin'at
-(254)897-0121.
j This communication contains no new licensing basis commitments regarding Comanche Peak Steam Electric Station Units 1 and 2.
Sincerely, l
C. L. Terry i
By:
N D. R. Woodlan Docket Licensing Manager CBC/cbc Attachment c-E. W. Merschoff, Region IV J. l. Tapia, Region IV D. H. Jaffe, NRR Resident inspectors, CPSES G. Bynog, TDLR J. C. Hair, ANil
r Attachment'to TXX-99130 l
Page 1 of 4 CPSES Response to the NRC RAl's regarding Units 1 and 2 Relief Requests E-1 and L-1 NRC RAI 1.
It is presently unclear how the owner-defined visual examinations will be qualified. IWA-2210 specifies Illumination and resolution requirements for Code visual examinations. These requirements no longer apply to the 1998 Code for Subsection IWE. Further,10 CFR 50.55a(b)(x)(B) mandates qualification of the remote visual examination procedure, if used, to extend the maximum direct examination distance and reduce the minimum illumination requirements specified in Table IWA-22101. However, this j
relaxation does not eliminate the requirement to qualify these remote l
visual examinations. Provide plant-specific Information that qualify the l
remote visual examinations as required by the Regulations TXU Electric Response:
Containment visual examinations will be performed in accordance with procedures written specifically for the Containment ISI Program. That is, the l
examination attributes are containment specific as are the containment examiner qualification requirements which are based on containment specific expenence, i
training and examination. However, the containment visual examination procedure qualification requirements for lighting and resolution are similar to, and developed from, the procedures used for VT-1 and VT-3 examinations of ASME Code Class 1,2 and 3 components. As such containment visual examination procedures will be demonstrated to the ANil for capability to detect the flaws and degradation levels defined within the procedures. In applications where remote visual examination systems are to be used those systems will be demonstrated to have a resolution capability at least equivalent to that attainable by direct visual examination.
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Attachm,ent*to TXX-99130 Page 2 of 4 CPSES Response to the NRC RAl's regarding Units 1 and 2 Rollef Requests E-1 and L-1 NRC RAI 2.
lWA-2210 also specifies illumination and resolution requirements for i
Subsection lWL visual examinations. While 10 CFR 50.55a(b)(x)(B) mandates a qualification of the remote visual examination procedure for Subsection IWE, if used, the INEEL staff believes it to be technically prudent to perform this same type of procedure qualification for Subsection lWL remote visual examinations. One method may be to use the guidelines established in ACI 349.3R-96, Evaluation of Existing Nuclear Safety-Related Concrete Structures. This document provides acceptance criteria for concrete structures and, by default establishes the minimum detectable flaw size for direct and remote visual examination procedure qualification. The second-tier acceptance criteria has been found acceptable for use at other plants. The licensee may establish acceptance criteria for evaluating concrete containments and qualify the remote visual examination procedure accordingly. Provide plant-specific information that is used to qualify the remote visual examination procedure for the concrete containment i
TXU Electric Response:
The same type of procedure qualification used for Subsection IWE remote visual examinations, as discussed in TXU response to NRC RAI 1 above,' will also be used for Subsection IWL remote visual examinations of concrete containments.
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- Attachment't3 TXX-99130 P ge 3 of 4 CPSES Response to the NRC RAl's regarding Units 1 and 2 Rollef Requests E-1 and L-1 NRC RAI 3.
The IWE-2500(b) requirement to examine paint or coatings prior to removal has been eliminated from the 1998 Edition. Alternatives to this requirement have been found acceptable when adequate provisions exist, in either the licensee's Containment inspection, Repair / replacement, Nuclear Coatings, or ISI Programs, to examine the base metal for surface l
anomalies that may Indicate underlying conditions that could challenge the structural Integrity of containment. The examinations should bo performed prior to re-application of the coating and should invoke detailed visual l
l examinations, e.g., VT-1 or VT-3, if necessary. In addition, the base metal examination should be performed by qualified Inspection personnel. The licensee has not currently provided information addressing the visual examination prior to paint or coating application. Provide plant-specific
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information that nuld ensure that the metal surface to be coated will be examined by qualified personnel prior to paint or coating application.
TXU Electric Response:
The CPSES ISI, Containment ISI, Repair / Replacement and Containment Coatings Programs are all administered by engineering personnel within the organization of one manager. These program engineers are cognizant of each others area of responsibility. In addition to this organizational and physical proximity, procedural provisions are in place to require notificat'.n to the appropriate responsible engineer when one program is potentially affected by the actions or results of another. In areas important to containment integrity, 1
coatings program procedural requirements ensure that coating deficiencies identified on the containment liner are brought to the attention of the Subsection IWE Responsible Individual (Containment ISI Engineer). Prior to final disposition of the coatings deficiency by the Coatings Program Engineer, the Containment ISI Engineer has the opportunity to establish visual examination hold points for any point in the coating removal and reapplication piocess. These procedural ties ensure that base metal conditions that could challenge the structural integrity of the containment are examined by properly qualified personnel.
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Attachrgent'to TXX-99130 Page 4 of 4 l
CPS,ES Response to the NRC RAl's regarding Units 1 and 2 Relief Requests E-1 and L-1 NRC RAI 4.
In your letter of February 20,1998, you indicate that the changes in the requirements of IWE-3511.3 (1998) and IWE 3512.3 (1992), entitled
" Ultrasonic Examination," are insignificant. However, IWE-3511.3 (1998) removes the applicability of this paragraph to the metallic liners of Class CC pressure retaining components. If you plan to use 10% material loss criterion (as established in lWE-3512.3 of the 1992 Edition of the Code) for the Comanche Peak metallic liners, please say so. If not, describe when and how would you document the material loss and perform the supplemental examination (as required by IWE-3200) of the liner, and the associated acceptance criteria that will be used. Please refer to NRC Information Notice 97-10, Liner Plat Corrosion in Concrete Containments," for relevant information.
TXU Electric Response:
The rewording of the Code paragraphs from IWE-3512.3 (1992)" containment vessels" to IWE-3511.3 (1998)" Class MC pressure retaining components" does not change the applicability. However, as stated in the NRC Rulemaking (61FR41312, dated August 8,1996)" Metallic shell and penetration liners which are pressure retaining components and their integral attachments must meet the inservice inspection, repair and replacement requirements applicable to components which are classified as ASME Code Class MC" Therefore, for Examination Category E-C, Containment Surfaces Requiring Augmented Examination, ultrasonic examinations of metallic liners of Class CC pressure retaining components that detect material loss in a local area exceeding 10% of the nominal wall thickness, or material loss in a local area projected to exceed 10% of the nominal wall thickness prior to the next examination, shall be accepted 'uy engineering evaluation or corrected by repair / replacement activities. Supplemental examinations shall be performed 1
when specified as a result of the engineering evaluation.
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