ML20212L215

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Forwards Request for Addl Info Re 860716 Inservice Insp Program.Response Requested by 870301
ML20212L215
Person / Time
Site: River Bend Entergy icon.png
Issue date: 01/21/1987
From: Stern S
Office of Nuclear Reactor Regulation
To: Deddens J
GULF STATES UTILITIES CO.
References
NUDOCS 8701290372
Download: ML20212L215 (9)


Text

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January 21, 1987 DISTRIBUTION

,DocketF11e Pleech Docket No. 50-458 NRC PDR M0'Brien LPDR ACRS(10)

PD#4 Rdg. BTurovlin RBernero Mr. James C. Deddens Dewey,0GC Senior Vice President, (RBNG) EJordan Gulf States Utilities BGrimes P. O. Box 220 JPartlow St. Francisville, LA 70775 NThompson ATTN: Nuclear Licensing SStern

Dear Mr. Deddens:

SUBJECT:

INFORMATION REQUEST - INSERVICE INSPECTION PROGRAM The staff is currently reviewing the River Bend Station Inservice Inspection Program which you submitted by letter dated July 16, 1986. In the course of its review, the staff has identified additional information which will be required to complete our review. This information is contained on pages 2 through 6 of the enclosure.

Please provide your response to this information request by March 1, 1987 so that the staff may complete a timely review of your Inservice Inspection Program.

For further information or amplification of this request, please contact me.

Sincerely,

/s/

Stephen M. Stern, Project Manager BWR Project Directorate No. 4 Division of BWR Licensing

Enclosure:

As stated cc w/ enclosure:

See next page PD#4/PM PDh4/D SStern:lb WButler v\

l /20/87 ( /3\/87 8701290372 870121 PDR ADOCK 05000458 PDR G

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j/ ""'%,7, 3' i UNITED STATES NUCLEAR REGULATORY COMMISSION h,,  ! j WASHINGTON, D. C. 20555

%, * . . . * / January 21, 1987 Docket No. 50-458 Mr. James C. Deddens SeniorVicePresident,(RBNG)

Gulf States Utilities P. O. Box 220 St. Francisville, LA 70775 ATTN: Nuclear Licensing

Dear Mr. Deddens:

SUBJECT:

INFORMATION REQUEST - INSERVICE INSPECTION PROGRAM The staff is currently reviewing the River Bend Station Inservice Inspection Program which you submitted by letter dated July 16, 1986. In the course of its review, the staff has identified additional information which will be required to complete our review. This informatiot is contained on pages 2 through 6 of the enclosure.

Please provide your response to this information request by March 1, 1987 so that the staff may complete a timely review of your Inservice Inspection Program.

For further information or amplification of this request, please contact me.

Sincerely, I .

l *

V

$t phen M. Stern, Project Manager BWR Project Directorate No. 4 Division of BWR Licensing

Enclosure:

As stated cc w/ enclosure:

See next page t

Mr. James C. Deddens Gulf States Utilities Company River Bend Nuclear Plant cc:

Troy B. Conner, Jr., Esq. Mr. J. E. Booker Conner and Wetterhahn Manager-River Bend Oversight 1747 Pennsylvania Avenue, NW P. O. Box 2951 Washington, D.C. 20006 Beaumont, TX 77704 Mr. Edward Grant Director - Nuclear Licensing Mr. William H. Spell, Administrator Gulf States Utilities Company Nuclear Energy Division P. O. Box 2951 Office of Environmental Affairs Beaumont, Texas 77704 P. O. Box 14690 Baton Rouge, Louisiana 70898 Richard M. Troy, Jr., Esq.

Assistant Attorney General in Charge Mr. J. David McNeill, III State of Louisiana Department of Justice William G. Davis, Esq.

234 Loyola Avenue Department of Justice New Orleans, Louisiana 70112 Attorney General's Office 7434 Perkins Road Resident Inspector Baton Rouge, Louisiana 70808 P. O. Box 1051 St. Francisville, Louisiana 70775 H. Anne Plettinger 3456 Villa Rose Drive Gretchen R. Rothschild Baton Rouge, Louisiana 70806 Louisianians for Safe Energy, Inc.

1659 Glenmore Avenue Baton Rouge, Louisiana 70775 President of West Feliciana Police Jury Regional Administrator, Region IV P. O. Box 1921 U.S. Nuclear Regulatory Commission St. Francisville, Louisiana 70775 Office of Executive Director for Operations Mr. Frank J. Uddo 611 Ryan Plaza Drive, Suite 1000 Uddo & Porter Arlington, Texas 76011 6305 Elysian Fields Avenue Suite 400 Philip G. Harris New Orleans, Louisiana 70122 Cajun Electric Power Coop. Inc.

10719 Airline Highway P. O. Box 15540 Baton Rouge, LA 70895 l

Enclosure GULF STATES UTILITIES COMPANY RIVER BEND STATION UNIT 1 DOCKET NUMBER 50-458 ENGINEERING BRANCH DIVISION OF BWR LICENSING Recuest for Additional Information - First 10-Year Interval Inservice Inspection program plan

1. Scope / Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which are classified as ASME Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during the initial 120-month inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the date of issuance of the operating license, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed r

therein. The Licensee, Gulf States Utilities Company, has prepared the l

ISI Program Plan to meet the requirements of the 1980 Edition, Winter 1981 Addenda (80W81) of the ASME Coda Section XI except that the extent and frequency of examination for Code Class 2 piping welds in Residual i

Heat Removal (RHR) Systems and Emergency Core Cooling (ECC) Systems has been determined by the 1974 Edition through Summer 1975 Addenda (74S75).

, As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain code examination requirements are impractical and relief is l

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t requested, the licensen shall submit information to the NRC to support that determination.

The staff has reviewed the available information in the River Bend

, Station Unit 1 First 10-Year Interval Inservice Inspection Program Plan, Revision 1, submitted July 16, 1986 and the requests for relief from the ASME Cod.e Section XI requirements which the Licensee has determined to be impractical. *

2. Additional Information Required Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the
review of the Inservice Inspection Program Plan

j A. Code Cases N-322 and N-334 are not referenced in Regulatory Guide 1.147 as NRC approved code cases. Therefore, these code cases, as referenced in Section 3.3 of the ISI Program Plan, should not be used. Regulatory Guide 1.147, Paragraph C.4, states " Code

{ Cases that are not on the approved list of this guide (paragraph C.1) or other requlatory guides, or for which authorization by the Commission has not been granted, are not i acceptable on a generic basis". The Licensee should provide justification for the use of these code cases or submit requests

for relief, along with technical justifications, as to why the Code-required Section XI requirements are impractical.

< B. In the relief requests, the following statement is typical of a partial reason for requesting relief: "The weld has been volumetrically examined by radiography and hydrostatically tested, found acceptable in accordance with ASME Section !!!, Class 1 requirements."Section III fabrication examinations can only be used to ensure the initial structural integrity for PSI and are not intended to be used to supplement ISI examinations for the detection of inservice degradation. All of the 19 relief requests should be revised to delete this statement as justification for requesting relief.

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gi .e C. Relief Request RR0001: Provide a listing of the percentage of the Code-required volumetric examination that can be performed on welds 2, 3, and 4 on Sketch 1.

D. Relief Request RR0002: Seven (7) sketches are referenced but only Sketches 1, 2, and 3 are included with the relief request. The welds for which relief is requested are listed for Part A of the relief request but not for Part B. The Licensee should provide this missing information so that the review can be completed. Also verify that the Code-required examinations will be completed on the 3

accessible portions of the subject welds.

E. Relief Requests RR0004, RR0005, and RR0007: List the approximate percentage of the Code-required surface examination that will be performed on the subject welds. The " Code Requirement" section of RR0005 should delete all reference to preservice and include only the requirements for inservice examinations.

F. Relief Request RR0008: Part A states that "due to component configuration, examination can only be parformed by UT using the V and 1/2 technique." Part B states that "due to overlay conditions, a meaningful UT examination can not be performed."

From the attached sketches, the staff notes that a significant portion of the Code-required volumetric examination can be completed from one side of the subject welds. List the approximate percentage of the Code-required volumetric examination that will be performed on each of the subject welds.

G. Relief Request RR0009: A visual examination (VT-1) is listed as the Code-required examination in the relief request. According to ASME Section XI, Table IWB-2500-1, Examination Category B-L-2, Item B12.20 and Examination Category B-M-2, Item B12.40, the Code-required examination is a VT-3 visual examination. This correction should be made to the relief request. Also this relief request states that: "Should the pumps or valves be required to be l

disassembled for other plant reasons, the required Inservice Visual 3 _, ,___ , _ _ _ _

Examinations will be considered." If these pumps or valves are disassembled, they should be required to receive the Code-required VT-3 examination.

H. Relief Request RR0010:

1.) The relief request lists Class 2 components but does not list the Class 3 components for which relief is requested. The Licensee should revise the relief request to also include the Class 3 components. c 2.) It is not clear if all of the subject welds are either encased in concrete or underwater, or if they are open ended systems and respective portions of systems that are open ended.

Verify that these welds are completely inaccessiole for the Code-required examination.

I. Relief Request RR0011: For parts A and B of the relief request, the Code Item No. listed is C2.20. Be specific as to the Code Item No. for which relief is being requested (i.e. C2.21, nozzle to vessel weld, or C2.22, nozzle inside radius section). Based on staff review, it is concluded that for Part A relief may only be required for Item C2.22, and Part B may only require relief for Item C2.21. Identify the Code-required examinations for which relief is being requested. The Licensee should also state the approximate percentage of the Code-required examination that can be completed for each component.

i For Part C of the relief request, list the percentage of the Code-required. volumetric examination that can be performed for each component.

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. J. Relief Request RR00120: The Code Section states that " Inservice I

j inspection were performed in accordance with ASME Section XI 1974

! Edition through and including Winter 1981 Addenda." This should be changed to read " Inservice inspection will be performed in 1

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accordance with ASME Section XI 1980 Edition through and including Winter 1981 Addenda."

K. Relief Request RR0012E: A volumetric examination is listed as the Code-required examination in the relief request. ASME Section XI, Table IW8-2500-1,- Examination Category B-A, Item 81.40, requires both a surface and volumetric examination. The Licensee should revise the relief request Code-requirement to include the surface examination and verify that the Code-required surface examination will be completed in addition to the limited volumetric examination.

L. Relief Requests RR0013 and RR0014: State the percentage of the Code-required examination that can and will be completed for each component listed in these relief requests. Also, in Relief Request RR0014, state the Item Number that corresponds to each component listed (i.e. Item 89.11, Item 89.12, Item 89.31, or Item 89.32).

M. Relief Request RR0015: The "Information to Support the Request for Relief" section states that during the preservice baseline examination (s) each respective weld was v-notch, low-stress, stamped with measurements of the indication (s) location (s) taken from the origin of v-notch in either the clockwise or counter clockwise direction by the examiner. Provide further clarification and identify the Code-requirement for which relief is being requested.

General Comment: Some of the above items describe typical observations and inconsistencies and are not intended to indicate a complete staff review. From this information, it is suggested that the Licensee review the relief request submittal for these types of inconsistencies and make i.he necessary coi.ections. The following is a listing of typical findings during review of the relief requests:

1.) The Licensee should state the percentage of the Code-required examination that can be completed on each component for which relief is being requested.

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o 2.) The Licensee should use a specific Code Item Number instead of a

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general Code Item Number (e.g. Item C2.21 or Item C2.22 should be used instead of Item C2.20).

3.) In several relief requests, under the " Code" section, it is stated that " Inservice inspections were performed in accordance with....". This should be changed to " Inservice inspections will be performed in accordance with...".

Under the " Reason Why Relief Should be Granted" section,Section III fabrication examinations have been listed as justification for requesting relief. The Section III fabrication examinations can only be used to ensure the initial structural integrity for PSI and are not intended to be used to supplement ISI examinations for the detection of inservice degradation.

All of these " remnants" of PSI relief requests that are included in the ISI relief requests should be deleted.

The Licensee should provide the above requested information and/or clarifications as soon as possible so that the review of the Inservice Inspection Program Plan can be completed.

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