ML20217B013

Forwards Request for Addl Info Re Review of Beaver Valley Power Station,Unit 1,third 10-year Interval Inservice Insp Program Plan & Associated Relief Requests

ML20217B013
Person / Time
Site:	Beaver Valley
Issue date:	04/16/1998
From:	Brinkman D NRC (Affiliation Not Assigned)
To:	Cross J DUQUESNE LIGHT CO.
References
TAC-M99673, NUDOCS 9804220388
Download: ML20217B013 (6)

Text

April 16, 1998 Mr. J. E. Cross President - Generation Group Duquesne Light Company Post Office Box 4 Shippingport, PA 15077

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING REVIEW OF BEAVER VALLEY POWER STATION, UNIT NO.1 (BVPS-1), THIRD 10-YEAR INTERVAL INSERVICE INSPECTION (ISI) PROGRAM PLAN AND ASSOCIATED RELIEF REQUESTS (TAC NO. M99673)

Dear Mr. Cross:

By letter dated September 17,1997, Duquesne Light Company (DLC) submitted the third 10-year interval 181 program plan and associated relief requests for BVPS-1. The NRC staff, with assistance from its contractor, Idaho National Engineering and Environmental Laboratory (INEEL), is reviewing and evaluating the subject program plan and associated relief requests.

The NRC staff has determined that additionalinformation is required from DLC to complete the eview. The additional information is identified in the enclosed RAl. DLC is requested to provide he additional information by May 29,1998, if possible, but in any event within 60 days of receipt of this letter, so that the NRC staff may complete its review within a timely manner. In order to expedite the review process, please send a copy of the RAI response directly to the NRC's contractor, INEEL, at the following address:

Mr. Michael T. Anderson INEEL Research Center 2151 North Boulevard P. O. Box 1625 Idaho Falls, Idaho 83415-2209 Should you have any questions on this matter, please contact me at (301) 415-1409.

Sincerely,

/S/

Donald S. Brinkman, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - t/11 Office of Nuclear Reactor Regulation l

Docket No. 50-334 i i

Enclosure:

Request for Additional j infonnadon p

- ' "" ' g'" pg ,,"" ,p [/Q l l

~ ;,,L cc wienci: See next page m c i DISTRIBUTION: .,t )3 .

Docket File JZwolinski DBrinkman . MEvans, RGN 1 PUBLIC RCapra ,OGC TMcLellan PD1-2 Reading MO'Brien ACRS GBagchi OFFICE PDI-2/PM A // PDIM-PDI-2/D G NAME DBrinkmanN MI RCapra &

DATE '/ /If/98 h//bO8 4 / 16 / 9 8 OFFICIAL RECORD COPY ' _' DOCUMENT NAME: BVM99673.RAI 9804220388 980416 .

PDR ADOCK 05000334 l I

G PDR J

e nouq k UNITED STATES j

v s NUCLEAR REGULATORY COMMISSION g WASHINGTON, D.C. 206E4001 g*****j e April 16, 1998 Mr. J. E. Cross President - Generation Group Duquesne Light Company Post Office Box 4 Shippingport, PA 15077

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAl) REGARDING REVIEW OF BEAVER VALLEY POWER STATION, UNIT NO.1 (BVPS-1), THIRD 10 YEAR INTERVAL INSERVICE INSPECTION (ISI) PROGRAM PLAN AND ASSOCIATED RELIEF REQUESTS (TAC NO.- M99673)

Dear Mr. Cross:

By letter dated September 17,1997, Duquesne Light Company (DLC) submitted the third 10-year j intervalISI program plan and associated relief requests for BVPS-1. The NRC staff, with assistance from its contractor, Idaho National Engineering and Environmental Laboratory l (INEEL), is reviewing and evaluating the subject program plan and associated relief requests.

The NRC staff has determined that additionalinformation is required from DLC to complete the review. The additionalinformation is identified in the enclosed RAl. DLC is requested to provide the additional information by May 29,1998, if possible, but in any event within 60 days of receipt of this letter, so that the NRC staff may complete ite review within a timely manner. In order to expedite the review process, please send a copy of the RAI response directly to the NRC's contractor, INEEL, at the following address:

Mr. Michael T. Anderson INEEL Research Center 2151 North Boulevard i P. O. Box 1625 '

Idaho Falls, Idaho 83415-2209 Should you have any questions on this matter, please contact me at (301) 415-1409.

Sincerely, M .b Donald S. Brinkman, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket No. 50-334 l t

Enclosure:

Request for Additional Information cc w/ encl: See next page

J. E. Cross Beaver Valley Power Station, Units 1 & 2 Duquesne Ught Company cc:

Jay E. Silberg, Esquire Burosu of Radiation Protection Shaw, Pittman, Potts & Trowbridge Pennsylvania Department of 2300 N Street, NW. Environmental Resources Washington, DC 20037 ATTN: M:chael P. Murphy Post Office Scx 2063 Director-Safety and Ucensing Harrisburg, PA 17120 Department (BV-A)

Duquesne Ught Company Mayor of the Borrough of Beaver Valley Power Station Shippingport PO Box 4 Post Office Box 3 Shippingport, PA 15077 Shippingport, PA 15077 Commissioner Roy M. Smith Regional Administrator, Region I West Virginia Department of Labor U.S. Nuclear Regulatory Commission Building 3, Room 31g 475 Allendale Road Capitol Complex King of Prussia, PA 19406 Charleston, WVA 25305 Resident inspector Director, Utilities Department U.S. Nuclear Regulatory Commission Public Utilities Commission Post Office Box 2g8 180 East Broad Street Shippingport, PA 15077 Columbus, OH 43266-0573 Director, Pennsylvania Emergency Duquesne Ught Company Management Agency Beaver Valley Power Station Post Office Box 3321 PO Box 4 Harrisburg, PA 17105-3321 Shippingport, PA 15077 ATTN: S. C. Jain, Vice President Ohio EPA-DEP.R Nuclear Services (BV-A) l ATTN: Zack A. Clayton Post Office Box 104g Columbus, OH 43266-014g Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Duquesne Ught Company Beaver Valley Power Station PO Box 4 Shippingport, PA 15077 ATTN: R. L. Grand, Division Vice President, Nuclear Operations Group and Plant Manager (BV-SOSB-7)

REQUEST FOR ADDITIONAL INFORMATION THIRD 10-YEAR INTERVAL INSERVICE INSPECTION (ISI) PROGRAM PLAN AND ASSOCIATED RELIEF REQUESTS l BEAVER VALLEY POWER STATION. UNIT NO.1 DOCKET NO. 50-33/

1. Scooe/ 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) that are classified as American Society of Mechanical l Engineers (ASME) Boiler and Pressure Vessel Code Class 1 Class 2, and Class 3 meet the l requirements, except design and access provisions and preservice examination requirements,  !

I set forth in Section XI of the ASME Code, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of l construction of the components. This section of the regulations also requires that inservice l examinations of components and system pressure tests conducted during the successive 120-month inspection intervals comply with the requirements in the latest edition and addenda of I i the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of an interval, subject to the limitations and modifications listed therein. The components l (including supports) may meet requirements set forth in subsequent editions and addenda of the l l

Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Nuclear Regulatory Commission (NRC) approval. The l licensee Duquesne Light Company (DLC), has prepared the Inservice inspection 10-Year Plan l

for the Third Interval at Beaver Valley Power Station Unit 1, Revision 0, to meet the requirements of the 1989 Edition of the ASME Boiler and Pressure Vessel Code,Section XI.

The staff has reviewed the Inservice inspection Ten-Year Pian for the Third Interval at Beaver Valley Power Station Unit 1, Revision 0, submitted September 17,1997, and the requests for relief from ASME Code Section XI requirements.

2. Additional Information Reauired Based on the above review, the staff has concluded that additional information and/or clarificatbn is required to complete the review of the ISI Program Plan.

A. The licensee's Program submittal includes an implementation schedule for performance i of examinations as required by IWA-2420(b). To determine compliance with Tables IWB-2412-1, IWC 2412-1, and IWD-2412-1, it is necessary to know the total number of components eligible for examination as well as the total number of components to be examined. Provide an examination summary that includes each examination category, the total number of components in each category, and the total number of examinations to be performed in periods 1,2 and 3 for each category.

B. Provide a list of all ultrasonic calibration blocks to be used during the third 10-year interval, including identifications, material specifications, and sizes. Also, provide a list of all procedures that will be used in the implementation of the ISI Program Plan, including the procedure identification (e.g. number), title, and a general description of the components to which it applies.

1 l

e 2-C. lWB-1220, IWC-1220, and IWD 1220 of ASME Section XI, provide rules for exemption from examination of certain Class 1,2 and 3 components. Appendix F, gives nonmandatory guidance for inspection plan development. F-2500(b) states that l Inspection plans should include the specific exemptions applied to each system covered l by Section XI. To complete the review of the Beaver Valley Power Station, Unit 1, l Program Plan, provide the specific exemption criteria applied to each exempt system.

D. Augmented examinations have been established by the NRC when added assurance of structural reliability is deemed necessary. Examples of documents that address l augmented examinations are:

(1) Branch Technical Position MEB 3-1. High Energy Fluid Systems, Protection l A0ainst Postulated Piping Failures in Fluid Systems Outside Containment; i

(2) Regulatory Guide 1.150, Ultrasonic Testing of Reactor Vessel Wolds During l

Preservice and inservice Examinations; Address the degree of compliance with these documents and any other augmented examinations that may have been incorporated in the third 10-year interval ISI Program Plan.

E. Provide the staff with the status of the augmented reactor pressure vessel examinations required by 10 CFR 50.55a(g)(6)(ii)(A), effective September 8,1992,' and a technical discussion describing how the regulation was/will be implemented at Beaver Valley Power Station Unit 1. Include in the discussion a description of the approach and any specialized techniques or equipment that was/will be used to complete the required augmented examination. Also, provide the percent of the volume examined for each l weld. It is required by 10 CFR 50.55a(g)(6)(ii)(A)(2) that essentially 100% of the volume j of each weld be examined. Confirm that " essentially 100W of each Examination Category 81.10 weld (RPV shell welds) has been examined, or that an attemative has t;een submitted for staff review.

F. In Request for Relief No. I-TYP-3 APP-l-1, Revision 0, the licensee seeks relief from Appendix 1, Paragraph 12300, which requires ultrasonic inspection of bolts and studs to be conducted in accordance with Appendix VI.

The licensee states in their Altemative Qualification that "DLC personnel will be qualified using the PDI Performance Demonstration initiative Program and DLC written practice QSP2.11 which meets the requirements of Section XI, Appendix Vil(1989 Edition)." This request for relief is specifically written for the Class 1 (Category B-G-1) and Class 2 (Category C D) bolts and studs. Is it the intent of DLC to use the PDI qualifx:ation of the UT personnel for all UT applications or for bolting only? Considering that implementation of Appendix Vill is imminent, describe DLC's plans regarding the implementation of l Appendix Vill.

t

' Note: Plants with greater than 40 memhs tc.aining in the interval on the effective date of the rule were required to pg rform the augmented examination in that interval.

I. l

' I

, G. In Request for Relief No.1-TYP-3-C6,101, Revision 0, the licensee seeks relief from l performing the surface examinations on the Recirculating Spray Pump Casing Welds RS-l P-2A(28)-C 10 through 27 and the Safety injection (SI) Pump Casing Wolds SI-P-1 A(18)-

l C-1 through 20 as required by ASME XI, item C6.10.

l l

The licensee states that "All of the welds listed above are located below floor level in the pump aump and are therefore inaccessible. See attached drawings." It appears from the drawings submitted that Welds C-18, C 19 and C-20 on the 81 pump (s), and Wold C 10 l on the Recirculation pump (s) may be above floor level. However, it also appears from the I

drawing that other obstacles may limit the accessibility of these welds. Provide additional information concoming the accessibility of these welds.

The licensee also states that " Access to these welds require removal of the pump casings from the sump. This evolution risks damage to the pump, in order to examine components that have a proven reliability record throughout the industry." Are these pump casings designed to be removed for normal maintenance, repair, and inspections?

Also, provide additional information concoming the risk of damage to the pump that could occurif the pump is removed.

H. In Request for Relief /Altemative Examination No.1-TYP-3-UT-1, Revision O, the licensee has proposed, as an attemative to the 1989 Edition of ASME XI, to use ultrasonic examination procedures meeting the requirements of the PDI Program Description, Revision 1, for volumetric UT examination of austenitic piping welds, ferritic piping welds, and bolting.

Identify the specific requirements of the 1989 Edition of ASME XI that will not be met if ultrasonic examination procedures meeting the requirements of the PDi Program Description, Revision 1, are used.

I. Request for Relief /Altemative Examination No.1-TYP-3-N-521, Revision 0, proposes an attemative schedule for reactor pressure vessel nozzle examinations. Code Class N-521, Altemative Rules for Deferral of Inspections of Nozzle-to-Vessel Welds, inside Radius Sections, and Nozzle to-Safe End Wolds of a Pressurized Water Reactor Vessel, states that examination of RPV nozzles, IR sections, and nozzle-to-safe end wolds may be deferred provided a) no inservice repairs or replacements by welding have ever been performed on any of the subject areas b) none of the subject areac contain identified flaws or relevant conditions that currently require successive inspections in accordance with IWB-2420(b), and c) the unit is not in the first interval. An additional requirement imposed by the NRC is that all subject areas be scheduled for examination such that the new Jequence of examinations will not exceed 10 years between examinations. Confirm that all of the above conditions will be met.

J. Verify that there are no requests for relief in addition to those submitted, if additional

! requests for relief are required, the licensee should submit them for staff review.