ML20203G651
| ML20203G651 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/29/1986 |
| From: | Jaffe D Office of Nuclear Reactor Regulation |
| To: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 8608010351 | |
| Download: ML20203G651 (14) | |
Text
.
July 29, 1986 Distribution T' Docket File.? "
DJaffe Docket No. 50-336
" NRC'PDR' ~ "?
PD#8 Reading BGrimes Mr. John F. Opeka, Senior Vice President FMiraglia OELD Nuclear Engineering and Operations EJordan Northeast Nuclear Energy Company JPartlow P. O. Box 270 NThompson Hartford, Connecticut 06141-0270 Gray File 3.5a I
Dear Mr. Opeka:
We are in the process of reviewing your June 27, 1985 and August 30, 1985 submittals concerning Inservice Inspection (ISI) and Inservice Testing (IST) for Millstone Unit 2.
In order that we may continue our review, we request that you respond to the enclosed questions concerning ISI within 90 days following receipt of this letter.
This request for information affects fewer than 10 respondents; therefore, 0MB clearance is not required under P.L.96-511.
Sincerely, i
/s/
D. H. Jaffe, Project Manager PWR Project Directorate #8 Division of PWR Licensing-B
Enclosure:
Request for Additional Information cc: w/ enclosure See next page PD#8l/
PD#8 h]zer affe:jch Atha ni
/]l-/86 86 86
'/
J 8608010351 860729
~
{DR ADOCK 05000336 PDR
Mr. John F. Opeka Millstone Nuclear Power Station Northeast Nuclear Energy Company Unit No. 2 cc:
Gerald Garfield, Esq.
Mr. Wayne D. Romberg Day, Berry & Howard Superintendent Counselors at Law Millstone Nuclear Power Station City Place P. O. Box 128 Hartford, Connecticut 06103-3499 Waterford, Connecticut 06385 Regional Administrator, Region I Mr. Edward J. Mroczka U.S. Nuclear Regulatory Commission Vice President, Nuclear Operations Office of Executive Director for Northeast Nuclear Energy Company Operations P. O. Box 270 631 Park Avenue Hartford, Connecticut 06141-0270 King of Prussia, Pennsylvania 19406 Mr. Charles Brinkman, Manager Washington Nuclear Operations C-E Power Systems Combustion Engineering, Inc.
7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. Lawrence Bettencourt, First Selectman Town of Waterford Hall of Records - 200 Boston Post Road Waterford, Connecticut 06385 Northeast Utilities Service Company ATTN: Mr. Richard R. Laudenat, Manager Generation Facilities Licensing Post Office Box 270 Hartford, Connecticut 06141-0270 Kevin McCarthy, Director Radiation Control Unit Department of Environmental Protection State Office Building Hartford, Connecticut 06106 Mr. Theodore Rebelowski U.S. NRC P. O. Box 615 Waterford, Connecticut 06385-0615 Office of Policy & Management ATTN: Under Secretary Energy Division 80 Washington Street Hartford, Connecticut 06106
June 3,1986 REQUEST FOR ADDITIONAL INFORMATION Millstone Unit 2 In letters dated June 27,1985,(l) and August 30, 1985,(2) you sitmitted a proposed inservice inspection (ISI) and testing (IST) program and relief requests for the second 10-year inspection interval of Millstone Unit 2.
SAIC will be using the ISI portion of this program, along with the relief requests and other documents (see Attachment 1, Document Review List) to review your requests for relief, weld examination samples, and component exemptions from the requirements of the applicable editions and addenda of Section XI of the ASME Boiler and Pressure Vessel Code.
If there are any documents not referenced that you believe may aid our review, please provide us with copies or reference if previously submitted.
Questions 1 through 11 pertain to the second 10-year inservice inspection interval. One part of Question 4 pertains to the first 10-year inservice inspection interval.
1.
The Millstone 2 Inservice Inspection (ISI) plan does not include isonetric drawings, a listing of welds to be examined, or scheduled examinations. Rather, the plan only includes a listing of Code items and statements indicating Co'de compliance. Code items not in compli-ance are indicated by means of footnotes to an examination table. The information that has been provided is not sufficient to determine the sample of welds selected for examination.
Code Tables IWB-2412-1, IWC-2412-1, and IWD-2500-1, and Paragraph IWF-2410 deYine requirements for the percentage of examinations that can be completed for each of the three periods.during the inspection interval. Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1 show the required extent and frequency of examination for each Item Number; Table IWB-2500-1 also indicates whether deferral of the exami-nation (s) to the end cf the 10-year interval is permissible. We cannot determine the method of compliance with these Code requirements from the available information.
i l
1
Please include the following infomation in the Millstone 2 ISI plan to enable determination of compliance with the Code requirements:
i (a) Provide an ISI plan section giving specific details of the ISI examinations that are specific to Millstone 2.
For each exami-nation item number, provide the following information on each component to be examined: the examination method used, the total number and/or length of welds in the component, the number and/or length of welds included in the examination sample for the second interval, the number and/or length of welds to be examined each inspection period, and the reference system isometric drawings and pipe and instrument drawings.
(b) Provide a section which gives the methodology used to select the weld examination sample for each component in the second interval (i.e., multiple train concept, etc.).
(c)
In Reference 1, impractical examinations are included as foot-notes or qualifications incorporated into the text. The staff will not review impractical examinations based on footnotes and qualifications incorporated into the text. You should clearly define each impractical requirement with a relief request.
Provide an ISI plan section for relief requests which includes the information illustrated in Attachment 2.
This section should include the relief requests provided in the Reference 2 letter and those items not in compliance with the Code as footnoted in the 9xamination tables or. as noted in the text of Reference 1.
1 (d) Provide a section which lists all Class 1, 2, and 3 Code allowed exemptions that are applied to Millstone 2.
When an exemption from a code other than the code of record is used, give the Code edition (i.e., Class 1 and 2 piping weld exemptions from 1974 S75 Edition).
2 I
i 2.
The Millstone 2 ISI plan states that when examining inaccessible piping welds, they will be examined to the extent practical, and when no meaningful examination can be performed, relief will be requested.
In addition, your Reference 2 relief requests titled, " accessibility relief request" and " component support restriction relief request" stated that some pipe welds could not be examined in accordance with the Code. Review of these issues will not be perforined on a generic basis.
Identification of the specific weld and details of the inter-ference should be provided as part of the plant-specific justification for requesting relief. Please provide, based on PSI and first-interval ISI examinations, a revised submittal with the specific welds requiring relief identified.
3.
Please provide the following information concerning Class 1 components contained in Notes 1 and 2, Section 3, of the ISI plan:
(a) Provide drawings and/or sketches showing reactor vessel welds SC-1 and SC-2.
Include enough detail to determine the access limitations.
(b)
Are welds SC-1 and SC-2 both located in the beltline region, as defined in Table IWB-2500-1, Category B-A, Note l?
4.
Note 3, Section 3 of the ISI plan, concerns reactor vessel nozzle-to-shell welds. This note states that nozzles'NS-2, NS-4, and NS-6 are inaccessible for voltmetric examination. Please provide the following information concerning the reactor vessel-to-shell welds:
1 (a)
Please provide drawings and sketches of nozzles NS-2, NS-4, and NS-6.
Include enough detail to illustrate the nozzle volumetric examination-inaccessibility problem.
l 3
(b) Note 3 states that the lower 50% of the subject nozzles are inaccessible; consequently, an alternative examination will be perforined consisting of a visual examination for signs of structural distress. Considering the nozzle inaccessibility, please describe what kind of visual examination "for signs of structural distress" is thus possible.
(c) Reference 3 withdrew an identical relief request for the first inspection interval and stated that the " nozzle-to-vessel welds N-2, N-4, ard N-6 will be examined." Please explain the reason required examinations could be perfonned during the first ISI interval but not the second.
5.
Certain Class 1 items listed in Section 3 of Reference 1 have Note 4 applied to them. Note 4 states that "there are no items of this category at Millstone Unit 2".
For example, Note 4 is applied to pump internal surfaces and valve body internal surfaces, Categories B-L-2 and B-M-2.
Since these components:must exist at Millstone 2, please address these examination categories.
6.
Reference 2 included a relief request from the examination require-ments of the reactor coolant pump casing welds. However, Note 7 of Section 3, Reference 1 states that 'a relief request was granted from inservice volumetric examination of the reactor coolant pump casing welds." Please note that any previously approved relief requests for the first ISI interval are not automatically approved for the second ISI interval because of the updating requirements of 10 CFR 50.55a (g)(4)(ii).
If this issue has not been approved for the second ISI interval, please revise Note 7 accordingly.
7.
With regard to Category IWF, Component Supports, please provide the following information:
4
l-l (a) Your " snubber inspection" relief request of Reference 2 states that the testing inspection requirements ' contained in the Unit Technical Specification equal or exceed those in the Code. Your technical basis compares only the technical specification visual examination requirements to the visual examination (VT-4) requirements of the Code. Please provide an evaluation of the technical specification snubber testing requirements as compared to the snubber testing requirements contained in Article IWF-5000 of the Code.
(b)
In Reference 1 Section 6, you state that for Class 1 and 2 com-ponent supports, 25% of the total number of supports. on piping that is required to be examined each interval will be examined.
For Class 3 supports, you repeat IWF-2510(b) which requires *that for multiple components within a system of similar design, function, and service, the supports of only one of the multiple components are required to be examined.
You have provided a percentage of Class 1 and 2 supports to be examined.
In order for the staff to evaluate the visual examination program for component supports, the licensee should indicate the approximate number of ASME Class 1, 2, and 3 supports included in the totals for each examination category. Also provide a description of the methodology used to determine the total number of Code Class 1, 2, and 3 supports.
8.
Certain Class 2 items listed in Section 4 of Reference 1 have Note 2 applied to them. Note 2 states that "there are no items of this category at Millstone Unit 2."
Note 2 is applied to Steam Generator Class 2 nozzle welds in vessels, item number C2.20. However, item number C2.21, steam generator nozzle-to-shell weld, is shown as being examined.
(a) Please address the apparent conflict between item numbers C2.20 and C2.21 for the steam generator.
5
(b) Please explain why the Class 2 steam generator nozzles, item number C2.22, nozzle inside radius section is not shown as being examined.
9.
Please pmvide the following information regarding the shutdown heat exchanger nozzles with wall thickness over 1/2 inch:
(a) For item number C2.20, what is meant by the notation in the method column, " volumetric (surface)"?
(b) For item number C2.22, what is meant by the notation in the com-pliance column, "not applicable"?
(c) Any variations from compliance with the Code requirements for the shutdown heat exchangers should be addressed in the ISI plan in accordance with 10 CFR 50.55a(g)(5)(iii).
- 10. Please provide the following information concerning ISI Plan Section 9, System Pressure Tests:
(a) Table 8C0-5000 gives only one leakage test pressure and one hydrostatic test pressure for all Class 1 piping and components.
Are there any Class 1 components or piping with design pressures or safety relief valve settings such that the resulting pressure tests would differ from that shown in Table BCD-5000?
- -.'~ -
4 (b) Table BCD-5000 does not identify the given test pressure for Class 2 and 3 piping and components as being either the leakage i
test or hydrostatic test pressure.
Please provide the test pressures.for both leakage-andihydrostatic tests of all classes of components.
6 Tw-
_ _ _ ~,., _,,..
,,. ~ -.. _.. - _... -,,..,. - _ -,,.. ~.., - _.,,. -
(c) General remarks regarding possible variations in pressure test boundaries from that required by the Code were made in ISI Plan Section 9.
Any deviations from Code requirements should be addressed in accordance with 10 CFR 50.55a(g)(5)(iii).
- 11. In Reference 2, your " Calibration Block Relief Request" proposed alternative examination states that, "All future ultrasonic exami-nations of the reactor coolant system welds,.in the 30" and 42" piping, will be examined utilizing procedures specific to Millstone Unit 2.
These ultrasonic examination procedures will specify the use of UT-15 calibration block and have concurrence of the ANII Agency."
IWA-2240 states that alternative examination methods, a combination of methods, or newly developed techniques may be substituted for those methods specified in IWA-2200, provided the Inspector is satisfied that the results are denor.strated to be equivalent or superior to those of the specified method. Has the use of calibration block UT-15, speci-fled in Reference 2, been demonstrated to the ANII to be equivalent or superior to the specified method?
i References t
1.
J. F. Opeka (NU) to E. J. Butcher (NRC) ISI Second Interval Program, June 27,1985.
2.
J. F. Opeka (NU) to E. J. Butcher (NRC) ISI Second Interval Program Supplemental Relief Request Information August 30, 1985.
3.
W. G. Counsil (NRC) to R. A. Clark (NRC.,
l
,ponse to Request for Additional Information, April 14, 1982.
7
--.-.--.. 2...-
=
REVIEW DOCUMENT RECORD ATTACHMENT 1.
Unit (s )
Millstone Unit 2 ID Nbmber and Date Author - Recipient Type Subject Matter Misc.
8/72 Sub.
Final Safety Analysis Report 7/18/75 Sub.
Final Safety Analysis Report. Amendment 39 5/28/76 Switzer (NNEC).to G. Lear (NRC)
Ltr.
-~
11/22/76 Lear (NRC) to Switzer (NNEC)'
~
Ltr.
10/26/78 Counsil (NNEC) to Reid (NRC)
Ltr.
Proposed Revisions to Technical Specifications 1/25/79 Counsil (NNEC) to Reid (NRC)
Ltr.
Inservice Inspection and Testing Program 1/31/79 Coudsil (NNEC) to Reid (NRC)
Ltr.
5/11/79 Reid (NRC) to Counsil (NNEC)
Ltr.
6/7/79 Reid (NRC) to Counsil (NNEC)
Ltr.
.2, i.
6/25/79 Counsil (NNRC) to Reid.(NRC)*
Ltr.
Inservice Inspection and Testing Program 2/26/82 Clark (NRC) to Coun'sil.(NNEC)
Sub.
Request for Additional Information 4/14/82 Counsil (NNEC) to Clark (NRC)
Sub.
Additional Information ISI and Testing Program 6
9/28/82 Johnston (NRC) to Lainas,(NRC) itemo Transmitting SER to Licensee.
5/4/84 Counsil (NNEC) to Miller (NRC)
Sub.
Reactir' Coolant Pump Relief Request 2/22/85 Counsil (NNEC) to Miller (NRC)
'Ltr.
Requesting 'use of Code Case N-416 6/27/85 Opeka (NNEC) to Butcher (NRC)
'Sub.
Second Interval ISI Program 8/30/85 Opeka (NNEC) to Butcher (NRC) iSub.
Second Interval Relief Requests r
i
7 ATTACHMENT 2 Millstone Unit 2
., ~.
Ejitt.05UR_E GUIDANCE FOR PREPARING PRESERVICE AND INSERVICE INSPECTION PROGRAMS AND REl.IEF REQUESTS PURSUANT TO 10 CFR 50.55a(g)
A.
Descriotion of the Preservice/ Inservice Insoection Procram This program should cover the requirenents set forth in Section 50.55a(b) i and (g) of 10 CFR Part 50; the ASME Boiler and Pressure Yessel Code,Section XI, '
Subsections IAW, IWB, IWC and IWD; and ' Standard Review Plans 5.2.4.and 6.6.
The guidance provided in this enclosure is intended to illustrata the type and extent of infonnation that should be provided for NRC review. It also describes' the information necessary for " request for relief" of items that cannot be fully inspected to the requirements of Section XI of the ASME Code. Sy uttilling these guidelines, applicants can significantly reduce the need for requests for additional informa-tion from the NRC staff.
i B.
Contents of the Submittal The information listed below should be included in the submittal:
j
.s 1.
For each facility, include the applicable date for the ASMI Code and the appropriate addenda, data.
2.
The period and interval for which this program is applicable.
3.
Provide the proposed codes and addenda to be used for repairs',
redifications, additions or alternations to the facility which might be implemented during this inspection period.
4.
Indicata the components and lines that you have exempted under the rules of Section XI of the ASME Code. A reference to the applicable paragraph of the code that grants the exemption is nece:sary. The i
inspection requirements for exempted components should be stated.
(e.g., visual inspection du, ring a pressure test).
S.
Identify the inspection and pressure testing requirements of the applicable portion of Section II that are deemed impractical because of the limitations of design, geometry, or materials of construction of the components. Provide the information riquestad in the following section of this appendix for the inspections and pressure tests identified in Item 4 above.
(
s...
IV-61
,.,er,.
y,,_
_s
t 4
Millstone Unit 2
)
C.
Recuest for Relief frem'certain insoection and Testine Rwiuirements It has been the staff's experience that many requests for relief from testing requirements submitted by applicants and licensees have not been supported by adequate descriptive and. detailed technical infor-mation. This detailed inforration is necessary to: (1) document the impracticality of the ASME Code requirements within the limita-tions of dasign, geometry, and materials of construction of components; and (2) determine whether the use of alternatives will provide an
- acceptable level of quality and safety.
Relief requests :;ubmitted with a justification such as "ingractical,"
"inacces' ible." or any other categorical basis, require additional s
infonnation td permit the staff to make an evaluation of that relief request. The objective of the guidance provided in this section is to
~
illustrate the extent of the infonnation that is required by the NRC staff to make a proper evaluation and to adequately document 2
the oasis ror granting the relief in the staff's Safety Evaluation Report. The NRC staff believes subsequent requests for additional information and delays in completing the review can be considerably reduced if this information is provided initially in the applicant's submittal.
For each relief request submitted, the following infonnation should be included:
?-
-)
- 1. An identification of the component (s) and/or the examination Z-@"
, requirements for which relief is requested.
~~
~
7~~
The number of items as'ociated with the requested relief.
2.
s
~
~ '
3.
The ASME Code class.
4.
An identification of the specific ASME Code requirement that has been detennined to be impractical.
5.
The information to support the detensination that the' requirement '
is impractical; 1,.e., state and explain the basis for requesting relief.
I t
6.
Ariidentification of the alternative examinations'that are proposed: (a) in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in compliance I
with the requirements of Section XI.
s,,
I lV-62 l
(
1 3
Hi11 stone Unit 2 4
f'-
' 7. A description and justification of any changes expected in the I
~ ~
overall level of plant safety by performing the proposed alternative examinations in lieu of the examination required by Section XI. If it is not possible to perform alternate examinations, discuss the impact, on the overall level of plant quality and safety.
For inservice inspection, provide the following additional infornation
, regarding the inspection frequency:
8.
State when the request i'or relfei' would apply during the inspection period or interval (i.e., whether the request is to defer an examination).
g.
State when the proposed alternative examinations will be implemented and performed.
- 10. State the time period for which the requested relief is needed.
Technical justification or data must be sumitted to support the relief request. Opinions without substantiation that a change will not affect the quality level are unsatisfactory. If the relief is requested for inaccessibility, a detailed description or drawing which depicts the inaccessibility must accompany the request. A relief request is not required for tests prescribed in Section XI that do not apply to your facility. A statement of "N/A" (not applicable)or"None"willsuffice.
D.
Recuest for Relief for Radiation Considerations Exposures of test personnel tn radiation to accomplish W examina-tions prescribed in Section XI cf the ASME Code can be an important factor in detaminir.g whether, or under what conditiens, sn examination must be performed. A request for relief must-be submil:ted by the licensee in the manner described above for inaccersibility and must be subsequ. ntly approved by the NRC staff.
~
We recognize that some of the radiation considerations will only be known at the time of the test. However, the licensee generally is aware,.from experience at operating facilities, of those areas where relief will be necessary and should submit as a minina, the following information with the request for relief:
- 1. The total estimated man-rem exposure involved in the examination.
2.
The radiation levels at the test area.
t v-6T n
-,,w.n n.,.
w
,__n.._., _ _ _
_,_,___,..,.,__y n.
~ ' **
(
~
4 Millstone Unit 2
,e 3.
Flushing or shielding capabilities which might reduce radiation levels.
4.
A proposal for alternate ' inspection techniques.
- 5..'I discussion of the considerations involved in remote inspections.
6.
Similar welds ir redundant systhms or similar welds in the same systems which can be inspected.
- 7. The results of pr2 service inspedtion and any inservice results for the welds for which the relief is being requested. -
-~
- 8. ' A discussion for the consequences if the weld whii:h was'not examined, did fail.
O e
e 9
4
., r-k 4
0 O
G O
e e
e N
e w
IV-M
~
a