ML20212N302
| ML20212N302 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/27/1986 |
| From: | Oconnor P Office of Nuclear Reactor Regulation |
| To: | Schnell D UNION ELECTRIC CO. |
| References | |
| NUDOCS 8608280176 | |
| Download: ML20212N302 (7) | |
Text
Docket No.
50-483 Mr. Donald F. Schnell Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, Missouri 63166
Dear Mr. Schnell:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RELATED TO TH.E FIRST TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN FOR CALLAWAY NUCLEAR POWER PLANT The staff is continuing its review of your submittals dated July 16, 1985.
To permit us to centinue our review on our current schedule; we require the infonnation requested in Enclosurn 1 to this letter be provided, a
Please provide the requested information within 45 days of your receipt of this letter.
Sincerely, 1
Paul W. O'Connor, Project Manager PWR Project Directorate #4 Division of PWR Licensing-A inclosure: As stated cc: See next page i
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r Mr. D. F. Schnell Callaway Plant Union Electric Company Unit No. 1 cc:
Mr. Nicholas A. Petrick Lewis C. Green, Esq.
Executive Director - SNUPPS Green, Hennings & Henry 5 Choke Cherry Road Attorney for Joint Intervenors Rockville, Maryland 20850 314 N. Broadway, Suite 1830 St. Louis, Missouri 65251 Gerald Charnoff, Esq.
Thomas A. Baxter, Esq.
Ms. Marjorie Reilly Shaw, Pittman, Potts & Trowbridge Energy Chairnen of the League of 1800 M Street, N. W.
Women Voters of Univ. City, M0 Washington, D. C.
20036 7065 Pershing Avenue University City, Missouri 63130 Mr. J. E. Birk Assistant to the General Counsel Mr. Donald Bollinger, Member 4
Union Electric Company Missourians for Safe Energy Post Office Box 149 6267 Delmar Boulevard St. Louis, Missouri 63166 University City, Missouri 63130 l
i U. S. Nuclear Regulatory Commission Mr. Dan I. Bolef, President f
Resident Inspectors Office Kay Drey, Representative RR#1 Board of Directors Coalition i
Steedman, Missouri 65077 for the Environment St. Louis Region Mr. Donald W. Capone, Manager 6267 Delmar Boulevard Nuclear Engineering University City, Missouri 63130 Union Electric Company Post Office Box 149 St. Louis, Missouri 63166 Chris R. Rogers, P.E.
Manager - Electric Department 301 W. High t
Post Office Box 360 Jefferson City, Missouri 6,5102 Regional Administrator U. S. NRC, Region III i
i 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Ronald A. Kucera, Deputy Director Department of Natural Resources P. O. Box 176 Jefferson City, Missouri 65102 i
r Mr. Glenn L. Koester Vice President - Nuclear l
Kansas Gas and Electric Company 201 North Market Street Post Office Box 2C8 1
Wichita, Kansas 67201
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ENCLOSURE 1 UNION ELECTRIC COMPANY CALLAWAY NL' CLEAR POWER PLANT DOCKET NUMBER 50-483 ENCINEERING BRANCH DIVISION OF PWR LICENSING - A Request for Additional Information - First Interval Inservice Inspect *.on Program 1.
Scope / Status of Review t.
10 CFR 50.55a(g)(4) requires that throughout the service life of a water-cooled nuclear power facility, 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 i
extent practical within the limitations of design, geometry, and materials of construction of the components.
This section of the
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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 i
listed therein. The components (including supports) may meet requirements ret 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 therein.
Based on the Operating License date of October 18, 1984, the Licensee has prepared the ISI Program in compliance with the requirements of the 1980 Edition, Winter 1981 Addenda (1980k81) of.ASME Code Section XI except that the extent and frequency of examination for Quality Group B (Class 2)
Piping (Table IWC-2500-1, Category C-F) will be in accordance with the requirements of paragraph IWC-1220, Table IWC-2520 Category C-F and C-G, and paragraph IWC-2411 of Section XI 1974 Edition, Summer 1975 Addenda.
The staff has reviewed the available information in the Callaway Inservice Inspection Program Plan submitted July 16, 1985.
Requests for relief from ASME Code Section XI requirements which the Licensee has determined to be impractical to perform at Callaway have not been submitted.
2.
Staff Evaluation 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:
A.
ASME Code Section XI paragraph IWF-2510, " Supports Selected for Examination", states that component supports selected for 1
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examination shall be the supports of those components that are required to be examined under IWB, IWC, IWD, and IWE during the f
I first inspection interval, and for multiple components within a system of similar design, function, and service, the supports of i
only one of the multiple components are required to be examined.
i In the ISI program Plan for component supports (NES document-I No. 83A1003 Rev.2), the support assemblies are divided as (1) i Equipment support assemblies, and (2) Piping support assemblies.
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Demonstrate that the selection of piping support assemblies for i
examination meets or exceeds the Code requirements.
i' B.
Paragraph 10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2 piping welds in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems shall Thesc syste's should not be completely exempted be examined.
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i from inservice volunetric examination based on Section XI exclusion criteria contained in IWC-1220.
The inservice inspection program for the Containment Cooling System (NES document No. 83A098d) must inc.lude volumetric examination of a j
representative sample of welds.
Justify why this system has been j
completely exempted from inservice volumetric examination.
C.
Paragraph IWC-1220(d), " Exempted Components", of the ASME Code Section XI 1974 Edition, Summer 1975 Addenda, states that I
component connections, piping, and associated valves, and vessels j
(and their supports), that are 4 in, nominal pipe size and j
smaller may be exempted from the examination requirements of i
In the ISI Program Plan for the Chemical and Volume 1
Control System (NES document No. 83A0983), piping 442-8C8-12" and j
444-BC8-10" are listed as exempt per IWC-1220(d) S '75 Addenda and treated as vessels with 3 in, connections, and section 2.1,
" Exemptions and Exceptions", states " Letdown delay lines d
442-BC8-12" and 444-8CB-10", with inlet and outlet lines of 3 in.-
j and 1 in. NPS, respectively, are considered exempt because the i
i failure of the 10 in and 12 in. lines are of no greater i
consequences than the failure of the 1 in, and 3 in. lines, which j
are exempt per Section XI."
The Licensee may not arbitrarily l
1 rename a pipe as a vessel.
If the Licensee has determined the
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ASME Code requirements for examination of these two lines to be impractical to perform, a request for relief from the ASME Code Section XI requirements should be submitted for staff review.
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0.
10 CFR 50.55a(g)(5) requires that if the licensee determines that certain code examination requirements are impractical and relief i
is requested, the licensee shall submit information to the staff j
to support that determination. The Licensee should submit a j
complete list of requests for relief from ASME Code Section XI i
requirements which the Licensee has determined ta be impractical i
to perform at Callaway. When preparing requests for relief, the t
staff suggests that the Licensee follow the attached Appendix A, l
" Guidance for Preparing Requests for Relief from Certain Code i
Requirements Pursuant to 10 CFR 50.55a(a)(3)".
i The Licensee should provide the above requested information and/or j
clarifications as soon as possible so that the review of the Inservice j
Inspection Program Plan can be completed.
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e APPENDIX A GUIDANCE FOR PREPARING REQUESTS FOR RELIEF FROM CERTAIN CODE REQUIREMENTS PURSUANT TO 10 CFR 50.55a(a)(3)
A.
Description of Requests for Relief The guidance in this enclosure is intended to illustrate the type and extent of information that is necessary for " request for relief" of items that cannot be fully inspected to the requirements of Section XI of the ASME Code.
The preservice/ inservice inspection program should identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitation of design, geometry, radiation considerations or materials of construction of the components.
The request for relief should provide the information requested in the following secticn of this appendix for the inspections and pressure tests identified above.
B.
Reauest for Relief From Certain Inspection and Testina Reauirements Many requests for relief from testing requirements submitted by licensees have not been supported by adequate descriptive and detailed technical information. This detailed information is necessary to: (1) document the impracticality of the ASME Code requirements within the limitations of design, 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 request submitted with a justification such as " impractical",
" inaccessible", or any other categorical basis, require additional information to permit an evaluation of that relief request.
The objective of the guidance provided in tiis section is to illustrate the extent of the information that is required to make a proper evaluation and to adequately document the basis for granting the relief in the Safety Evaluation Report.
Subsequent requests for additional information and delays in completing the review can be considerably reduced if this information is provided initially in the licensee's submittal.
For each relief request submitted, the following information should be included:
1.
An identification of the component (s) and the examination requirement for which relief is requested.
2.
The number of items associated with the requested relief.
3.
The ASME Code class.
4.
An identification of the specific ASME Code requirement that has been determined to be impractical.
5.
The information to support the determination that the requirement is impractical; i.e., state and explain the basis for requesting 1
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relief.
If the Code required examination cannot be performed i
because of a limitation or obstruction, describe or provide drawings showing the specific limitation or obstruction, and provide an 4
j estimate of the percentage of the Code required examination that can be completed on the individual components requiring relief.
6.
An identification of the alternative examinations that are proposed:
(1) in lieu of the requirements of Section XI; or (b) to supplement j
examinations performed partially in compliance with the requirements of Section XI.
7.
A description of the ASME Code Section III fabrication examinations k
that were completed and documented during construction for the
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specific components listed in the relief requests.
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8.
A description and justification of any changes expected in the i
overall level of plant safety by performing the proposed alternative j
examination in lieu of the examination required by Section XI.
If it is not possible to perform alternate examinations, discuss the j
impact on the overall level of plant quality and safety.
For inservice inspection, provide the following additional information l
regarding the inspection frequency:
1 1.
State when the request for relief would apply during the inspection 1
period or interval (i.e., whether the request is to defer an j
examination.)
2.
State when the proposed alternative examinations will be implemented
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and performed.
3.
State the time period for which the requested relief is needed.
Technical justification or data must be submitted to support the relief request.
Opinions without substantiation that a change will not affect j
the quality level are unsatisfactory.
If the relief is requested for j
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" will suffice.
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C.
Reouest for Relief for Radiation Considerations 4
j" Exposures of test personnel to radiation to accomplish the examinations i
prescribed in Section XI of the ASME Code can be an important factor in-determining whether, or under what conditions, an examination must be i
performed. A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently
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approved by the NRC staff.
4 Some of the radiation considerations will only be known at the time of the test.
However, from experience at operating facilities, the licensee generally is aware of those areas where relief will be necessary and should submit as a minimum, the following information with the request for relief:
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The total estimated man-rem exposure involved in the examination.
2.
The radiation levels at the test area.
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3.
Flusning or shielding capabilities which might reduce radiation levels.
4.
A proposal for alternate inspection techniques, j
5.
A discussion of the considerations involved in remote inspections.
i 6.
Similar welds in redundant systems or similar welds in the same j
systems which can be insp'ected.
1 7.
The results of preservice inspection and any inservice results for the welds for which the relief is being requested.
8.
A discussion of the failure consequences of the weld which would not i
j receive the Code required examination.
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