ML20215A249

Responds to Util Submitting Rev 2,updating 850108 & 0522 Submittals,To 10-yr Inservice Insp Program Plans. Requests Addl Info as Identified in Encl within 60 Days to Complete Review

ML20215A249
Person / Time
Site:	Catawba
Issue date:	06/08/1987
From:	Jabbour K Office of Nuclear Reactor Regulation
To:	Tucker H DUKE POWER CO.
References
NUDOCS 8706160576
Download: ML20215A249 (9)

Text

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Docket Mos.: 50-413 and 50-414 0 8 JUN pp Mr. H. B. Tucker, Vice President Nuclear Production Department Duke Power Company 422 South : Church Street Charlotte, North Carolina 28242

Subject:

Request for Additional Information Regarding the First Ten-Year Inservice Inspection Program Plans - Catawba Nuclear Station Units 1 and 2 By letter dated August 18, 1986, you submitted Revision 2 to the ten-year Inservice Inspection Program Plans. This revision updated your earlier submittals dated January 8 and May 22, 1985.

The staff with the technical assistance from the Idaho National Engineering Laboratory has reviewed your submittals and finds that additional information, identified in the enclosure, is needed for completion of its review.

Your response to the enclosure is requested within 60 days from the date of this letter. Please contact me at (301) 492-7367 if you have questions regarding the enclosure or are unable to meet the requested response date.

Silcerely, 1 bi Kahtan N. Jabbour, Project Manager Project Directorate II-3 Division of Reactor Projects I/II

Enclosure:

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. Duke Power Company Catawba Nuclear Station cc:

A.V. Carr, Esq. North Carolina Electric Membership Duke Power Company Corp.

422 South Church Street 3400 Sumner Boulevard Charlotte, North Carolina 28242 P.O. Box.27306 J. Michael McGarry, III, Esq.

Bishop. Liberman, Cook, Purcell Saluda River Electric Cooperative, and Reynolds . Inc.

1200 Seventeenth Street, N.W. P.O. Box 929 Washington,-D. C. 20036. Laurens, South Carolina 29360 North Carolina MPA-1 Senior Resident Inspector Suite 600 Route 2, Box 179N 3100 Smoketree Ct. York, South Carolina 29745 P.O. Box 29513 Raleigh, North Carolina 27626-0513 Regional Administrator, Region II U.S. Nuclear Regulatory Connission, L.L. Williams- 101 Marietta Street, NW, Suite 2900 Area Manager, Mid-South Area Atlanta, Georgia 30323 ESSD Projects Westinghouse Electric Corp.

- MNC West Tower - Bay 239 P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 County Manager of York County York County Courthouse Karen E. Long

= York South Carolina P.9745 Assistant Attorney General N.C. Department of Justice Richard P. Wilson, Esq. P.O. Box 629

. Assistant Attorney General Raleigh, North Carolina 27602 S.C.- Attorney General's Office P.O. Box 11549 Spence Perry, Esquire Columbia, South Carolina 29211 General Counsel

Federal Emergency Management Agency Piedmont Municipal Power Agency Room 840 100 Memorial Drive 500 C Street Greer, South Carolina 29651 Washington, D. C. 20472 f Mr. Michael Hirsch

! Federal Emergency Management Agency i ' Office of the General Counsel Room 840

500 C Street, S.W.

j Washington, D. C. 20472 i Brian P. Cassidy, Regional Counsel l Federal Emergency Management Agency, j Region I J. W. McCormach P0CH Boston, Massachusetts 02109 L

ENCLOSURE DUKE POWER COMPANY CATAWBA NUCLEAR STATION UNITS 1 AND 2 DOCKET NUMBERS 50-413 AND 50-414 INSERVICE INSPECTION ASSESSMENT SECTION MATERIALS ENGINEERING BRANCH Reouest for Additional Information - First 10-Year Interval Inservice Insoection prodram Plan

1. Scoce/ 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 Cit.ss 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 therein. The Licensee, Duke Power Company, has prepared the Inservice Inspection (ISI) Program Plans to meet the requirements of the 1980 Edition, Winter 1981 Addenda (80W81) of the ASME Code Section XI except that the extent and frequency of examination for Code Class 2 piping welds in Residual Heat Removal (RHR) Systems, Emergency Core Cooling (ECC) Systems, and Containment Heat Removal (CHR) Systems has been determined by the 1974 Edition through Summer 1975 Addenda (74S75).

The staff has reviewed the available information in the Catawba Nuclear 1

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Station Units 1 and 2 First 10-Year Interval Inservice Inspection-3-

' Program P1ans, through Revision 2, submitted August 18, 1986.

2. Additional Information Reouired 1

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 Plans:

A..

Provide the staff with isometric and/or component drawings showing the welds, components, and supports which are required to be examined by Section XIfof the ASME Code.

B.

With regards.to limitations due to metallurgical properties of cast stainless steel -(SA351 Grade CF8A), the staff has continued to monitor the development of new or improved examination techniques.

~As improvements in these areas are achieved, the staff is' requiring that these new techniques be made part of the ISI examination procedures. Discuss the ISI examination procedures for the ultrasonic examination of the Catawba Nuclear Station Units 1 and 2 Primary Coolant System and, in particular, the improved examination techniques and procedures which will be incorporated to increase

. the level of compliance with the Code examination requirements.

C. Code Cases N-356 and N-427 are not referenced in Regulatory Guide 1.147, Revision 5, as NRC-approved code cases. Therefore, these code cases, as referenced in Section 1.2 of the ISI Program Plans, should not be used. Regulatory Guide 1.147, Revision 5, Paragraph C.4, states " Code Cases that are not on the approved list of this guide (Paragraph C.1) or other regulatory guides, or for which authorization by the Commission has not been granted, are not acceptable on a generic basis". The 1.icensee 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.

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D. As required by 10 CFR 50.55a(g)(5), if the licensee determines that 0

.certain. code examination requirements are impractical and relief is requested, the licensee shall submit information to the NRC to support that determination. The Licensee should provide a formal submittal of requests for relief including supporting technical justifications. Each request for relief should be a " stand-alone" document (i.e. all of the supporting information should be included as part of the relief request). When preparing requests for relief, the staff suggests that the Licensee follow the attached Appendix A, " Inservice Inspection: Guidance for Preparing Requests for Relief from Certain C' ode Requirements Pursuant to 10 CFR 50.55a(g)(5)".

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, APPENDIX A INSERVICE INSPECTION: GUIDANCE FOR PREPARING REQUESTS FOR RELIEF FROM CERTAIN CODE REQUIREMENTS PURSUANT TO 10 CFR 50.55a(g)(5)

A. Descriotion of Reauests 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 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 deslgn, geometry, radiation considerations or materials of construction of the components. The request for relief should provide the information requested in the following section of this appendix for the inspections and pressure tests identified above.

B. Reouest for Relief From Certain Insoection and Testino Reouirements Many requests for relief from testing requirements su~mitted o 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 requests 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 this 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 4

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g. submittal.

For each relief request submitted, the following information should be included:

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1. State'when the request for relief would apply during the inspection period or interval (i.e., whether the request is to defer an examination.)

2. State the time period for which the requested relief is needed.

3. An itemized list of the specific component (s) and the examination requirement for which relief is requested.

4. The number of. items associated.with the rec;uested relief.

5. The ASME Code Class, Examination Category, and Item Number (sf.

6. An identification of the specific ASME Code requirement that has been determined to be impractical.

7. The information to support the determination that the requirement is impractical; i.e., state'and explain the basis for requesting relief. If the Code required examination cannot be performed because of a limitation or obstruction, describe or provide drawings showing the specific limitation or obstruction, and provide an estimate of the percentage of the Code required examination that can be completed on the individual components requiring relief.

8. An identification 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 with the requirements of Section XI.

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9. State when the proposed. alternative examinations will be implemented and performed.

10. - A description and justification of any changes expe'cted in the

~ overall level .of plant safety by performing the proposed alternative examination 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.

Technical justification or data must be submitted 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" will suffice.

C. Reauest for Relief for Radiation Considerations Exposures of test personnel to radiation to accomplish the examinations prescribed in Section XI of the ASME Code can be an important factor in determining whether, or under what conditions, an examination must be performed. A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently

approved by the NRC staff.

.1 Some of the radiation considerations will only be known at the time of l -the test. However, from experience at operating facilities, the l licensee generally is aware of those areas where relief will be i necessary and should submit as a minimum, the following information with

[ the request'for relief:

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1. The total estimated man-rem exposure involved in the examination.

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,_ 2. .The radiation levels at the test area.

3. Flushing or shielding capabilities which might reduce radiation levels.

4. A proposal for alternate inspection techniques.

5. A discussion of the considerations involved in remote inspections.

6. Similar welds in redundant systems or similar welds in the same systems which can be inspected.

7. - The results of preservice inspection anc 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 receive the Code required examination.

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