ML20248D356
| ML20248D356 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/28/1998 |
| From: | Kugler A NRC (Affiliation Not Assigned) |
| To: | Gipson D DETROIT EDISON CO. |
| References | |
| TAC-MA1570, NUDOCS 9806020402 | |
| Download: ML20248D356 (4) | |
Text
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Mr. Douglis R.' Gipson May 28, 1998 Senior Vice President Nuclear Generation Detroit Edison Company 6400 North Dixie Highway Newport, Michigan 48166 l
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED REQUESTS FOR RELIEF FOR THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION (ISI) NONDESTRUCTIVE EXAMINATION (NDE) PROGRAM AT FERMI 2 (TAC NO. MA1570)
Dear Mr. Gipson:
By a letter dated April 16,1998 (NRC-98-0060), the Detroit Edison Company (DECO) requested NRC approval of 10 requests for relief related to the ISI NDE Program. DECO also requested that the NRC complete its review and approval by July 10,1998, to support a refueling outage scheduled to start in August 1998. Based on discussions with the NRC, DECO verbally changed the requested date to July 15,1998, for Requests for Relief RR-A17 and A19-A22 and to July 31,1998, for Requests for Relief A1, A16, A18, A23, and A24.
I Additional information, as discussed in the enclosure, is requested in order for the staff to complete its review. NRC requests that DECO respond by June 19,1998, for Requests for Relief RR-A17 and A19-A22 and July 10,1998, for Requests for Relief A1, A16, A18, A23, and A24. In order to expedite the review process, please send a copy of the your response to the NRC's contractor, Idaho National Engineering and Environmental Laboratory (INEEL), at the following address:
MichaelT. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 i
Idaho Falls, Idaho 83415-2209 If you should have any questions regarding this request, please contact me at 301-415-2828.
Sincerely, ORIGINAL SIGNED BY Andrew J. Kugler, Project Manager Project Directorate ill-1 9006020402 990528 Division of Reactor Projects - Ill/IV DR ADOCK 05 31 Office of Nuclear Reactor Regulation Docket No. 50-341
Enclosure:
As stated
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'sg Mr. Douglas R. Gipson Fermi 2 Detroit Edison Company cc:
John Flynn, Esquire Senior Attorney Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. O. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 U.S. Nuclear Regulatory Commission Resident inspector's Office 6450 W. Dixie Highway Newport, Michigan 48166 l
Monroe County Emergency Management Division t
'J33 South Raisinville Monroe, Michigan 48161 l
Regional Administrator, Region lli l
U.S. Nuclear Regulatory Commission 801 Warrenville Road l
Lisle, Illinois 60532-4351 l
Norman K. Peterson Director, Nuclear Licensing Detroit Edison Company Fermi 2 - 280 TAC 6400 North Dixie Highway i
Newport, Michigan 48166 August 1997
REQUEST FOR ADDITIONAL INFORMATION PROPOSED REQUESTS FOR RELIEF FOR THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION (ISI)
NONDESTRUCTIVE EXAMINATION (NDE) PROGRAM AT FERMI 2 Scone / Status of Review Throughout the service life of a water-cooled nuclear power facility,10 CFR 50.55a(g)(4) l requires that components (including supports) that are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in the 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 successive 120-month inspection intervals 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 start of the interval, subject to tbs limitations and modifications listed therein. The components (including supports) may meet examination requirements set forth in s'ubsequent editions and addenda of the 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 staff has reviewed the information provided by the licensee in the April 16,1998, submittal.
The applicable edition of the Code for the Fermi 2 first 10-year ISI interval is the 1980 Edition through Winter 1981 Addenda of ASME Section XI.
Questions 1.
To ensure that the requests for relief are evaluated in accordance with the appropriate criteria, each request should be reviewed to determine if the appropriate paragraph of the regulations has been cited, as discussed below. Also verify that the regulatory basis has been adequately supported.
l The regulations provide that a licensee may propose an attemative to CFR or Code requirements in accordance with 10 CFR 50.55a(s)(3)(i) or 10 CFR 50.55a(a)(3)(ii).
Under 10 CFR 50.55a(a)(3)(i), the proposed attemative must be shown to provide an acceptable level of quality and safety, i.e., essentially, be equivalent to the original requirer,1ent in terms of quality and safety. Under 10 CFR 50.55a(s)(3)(ii), the licensee must show that compliance with the original requirement results in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Examples of hardship and/or unusual difficulty include, but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examination, and ENCLOSURE I
- development of sophisticated tooling that would result in only minimal increases in examination coverage.
A licensee may also submit a request for relief from ASME requirements. In accordance with 10 CFR 50.55a(g)(5)(iii), if a licensee determines that conformance with certain Code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in 10 CFR 50.4, information to support that determination.
When a licensee determines that an inservice inspection requirement is impractical, e.g., the system would have to be redesigned, or a component would have to be replaced to enable inspection, the licensee should cite 10 CFR 50.55a(g)(5)(iii). The NRC may, giving due consideration to the burden placed on the licensee, impose an alternative examination requirement. Based on its review of the licensee's submittal, the staff has concluded that approprkte paragraphs of 10 CFR 50.55a(a)(3) have not been referenced in all cases. The licensee must provide the appropriate paragraph of the regulations for Requests for Relief RR-A1, A18, A22, and A23.
2.
In Request for Relief RR-A1, there is a B1.11 weld that could not be examined to the extent required by the regulations. Pursuant to 10 CFR 50.55a(g)(6)(ii)(A)(2), licensees shall augment their reactor vessel examination by implementing once, as part of the inservice inspection interval in effect on September 8,1992, the examination -
requirements for reactor vessel shell welds specified in item B1.10 of Exarhination Category B-A. Licensees unable to completely satisfy the requirements for the augmented reactor vessel examinations shall submit information to the Commission to support the determination and shall propose an alternative [ pursuant to 10 CFR 50.55a(g)(6)(ii)(A)(5)] to the examination requirements that would provide an acceptable level of quality and safety. Provide the staff with the status of the augmented reactor pressure vessel examinations required by 10 CFR 50.55a(g)(6)(ii)(A). In addition, provide a list of all B1.11 and B1.12 welds that have been inspected and include the coverage achieved for each of those welds.
3.
For the totally inaccessible welds listed in Request for Relief RR-A1, provide a discussion of how reasonable assurance of the structural integrity will be maintained without the performance of any attemative examination.
4.
For Requests for Relief RR-A16 and A17, referencing only Code Cases N-416-1 and i
N-498-1 does not provide an acceptable basis for the staff to authorize an attemative.
Provide a regulatory basis for each of the subject requests; e.g., attemative examination l
or hardship.
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5.
For Request for Relief RR-A20, identify the item Number (s) for which relief is requested.
6.
For Requests for Relief RR-A21 and RR-A22, cost cannot be considered a burden.
Therefore, the basis provided is not adequate, and the burden associated with the removal of clamps must be Justified. What radiation exposure is expected? For RR-A21, do any of the subject attachments require volumetric examination? For Weld (s) PSFW-E41-3172-625A-65D in RR-A22, relief cannot be granted based on the coverage given ("significant limitation possible"). Provide an estimate of the coverage that can be completed and the reasons why the coverage cannot be completed.
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