ML20248E740

Forwards Request for Addl Info Re Review of Beaver Valley Power Station Unit 2,second 10-year Interval Inservice Insp Program Plan & Associated Relief Requests

ML20248E740
Person / Time
Site:	Beaver Valley
Issue date:	06/01/1998
From:	Brinkman D NRC (Affiliation Not Assigned)
To:	Cross J DUQUESNE LIGHT CO.
References
TAC-MA0333, TAC-MA333, NUDOCS 9806030432
Download: ML20248E740 (7)

Text

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g June 1, 1998

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I Mr. J. E. Cross

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t. President - Generation Group l Duquesne Light Company l Post Office Box 4 i Shippingport, PA 15077

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING REVIEW OF BEAVER VALLEY POWER STATION, UNIT NO. 2 (BVPS-2), SECOND 10-YEAR INTERVAL INSERVICE INSPECTION (ISI) PROGRAM PLAN AND ASSOCIATED RELIEF REQUESTS (TAC NO. MA0333)

Dear Mr. Cross:

By letter dated December 9,1997, Duquesne Light Company (DLC) submitted the Second 10-Year interval ISI Program Plan and associated relief requests for BVPG-2. 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 comp:ete the review. The additionalinformation is identified in the enclosed RAl. DLC is requested to provide the additionalinformation 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 l Idaho Falls, Idaho 83415-2209 l 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 s I

Division of Reactor Projects - 1/II l Off.ce of Nuclear Reactor Regulation Docket No. 50-412 l

Enclosure:

RAI ,

cc w/ encl: See next page K' \

DISTRIBUTION:

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NAME DBrinkman:rb MIO'Brien RCapra # _

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\***** June 1, 1998 Mr. J. E. Cross -

l.

President- Generation Group Duquesne Light Company Post Offica Box 4 Shippingport, PA 15077 i

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING REVIEW OF BEAVER VALLEY POWER STATION, UNIT NO. 2 (BVPS-2), SECOND 10 YEAR INTERVAL INSERVICE INSPECTION (ISI) PROGRAM PLAN AND ASSOCIATED RELIEF REQUE~,fS (TAC NO. MA0333)

Dear Mr. Cross:

i By letter dated December 9,1997, Duquesne Light Company (DLC) submitted the Second

' 10-Year Interval ISI Program Plan and associated relief requests for BVPS-2. The NRC staff, with assistance from its contractor, Idaho National Engineering and Environmental Laboratory (INEEL), is reviewing and ovaluating the subject program plan and associated relief requests.

L The NRC staff has determined that additionalinformation is required from DLC to complete the review. The additional information is identified in the enclosed RAI.. DLC is requested to provide the additionalinformation 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 j . a copy of the RAI response directly to the NRC's contractor, INEEL, at the following address:

l Mr. Michael T. Anderson  !

INEEL Research Center 2151 North Boulevard l

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,

f. v= -- -

Donald S. Brinkman, Senior Project Manager-Project Directorate 1-2 Division of Reactor Projects - 1/ll Office of Nuclear Reactor Regulation Docket No. 50-412  !

l

Enclosure:

RAI cc w/ encl: See next page l

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

- Jay E. Silberg, Esquire -

Bureau of Radiation Protection Shaw, Pittman, Potts & Trowbridge Pennsylvania Department of 2300 N Street, NW. Environmenhl Resources Washington, DC 20037 ATTN: MchaelP. Murphy Post Omco Box 2063 Director-Safety and Licensing Harrisburg, PA 17120 Department (BV-A)

Duquesne Ught Company Mayor of the Bonough of Beaver Valley Power Station Shippingport PO Box 4 Post Omco 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 Charieston,WVA 25305 Resident inspector Director, Utilities Department U.S. Nuclear Regulatory Commission Public Utilities Commission Post Offee 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-DERR Nuclear Services (BV-A)

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 Vico

)

President, Nuclear Operations Group i and Plant Manager (BV-SOSB-7) 1

REQUEST FOR ADDITIONAL INFORMATION SECOND 10-YEAR INTERVAL INSERVICE INSPECTION (ISI) PROGRAM PLAN AND ASSOCIATED RELIEF REQUESTS BEAVER vat 1 FY POWER STATION. UNIT NO. 2 DOCKET NO. 50-412

1. Scone / 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 l- 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 Section XI of the ASME Code, " Rules for Inservice

! Inspection of Nuclear Power Plant Components," to the extent practical within the limitations I

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 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 an interval, subject to the limitations and modifications listed therein.' The components (including supports) may meet requirements set forth in subsequent 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 licensee, Duquesne i

Light Company, has prepared the Inservice Inspection Ten-YearPlan forthe Second Interval '

at Beaver Valley Power Station Unit 2, Revision 0, to meet the requirements of the 1989 l Edition of the ASME Code,Section XI. The second 10-year interval began November 17, 1997.

The staff has reviewed the available information in the Inservice Inspection Ten-YearPlan for the Second Intervalat Beaver Valley Power Station Unit 2, Revision 0, submitted December 9,1997, and the requests for relief from the ASME Code Section XI requirements.

2. AdditionalInformation Reauired.

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

1. The licensee's submittalincludes an implementation schedule for performance of i

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 i 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 Examination Category.

ENCLOSURE

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2. In accordance with 10 CFR 50.55a(c)(3),10 CFR 50.55a(d)(2), and 10 CFR 50.55a(e)(2),

ASME Code cases may be used as altematives to Code requirements. Code cases that the NRC has approved for use are listed in Regulatory Guide 1.147, inservice inspection Code Case Acceptability, with any additional conditions that the NRC may have imposed.

When used, these Code cases must be implemented in their entirety. The licensee may adopt an approved Code case by notifying the NRC in writing. Published Code cases awaiting approval and subsequent listing in Regulatory Guide 1.147 may be adopted only if the licensee requests, and the NRC authorizes, their use on a case-by-case basis. The licensee has provided a list of Code cases that will be used du ing the Unit 2 second-10 year interval. Two of the Codes cases listed, N-416-1, and N-4g8-1, reference NRC approval letters dated 12/71g4 and 1/12/g5, respectively. These Code cases were approved for use during the Unit 1 second 10-year interval and the Unit 2 first 10-year interval. When inservice inspection programs are updated and submitted for a new .

interval, requests for relief that were approved for previous intervals, including requests for use of Code cases not approved in Regulatory Guide 1.147, must be resubmitted for evaluation. Provide an appropriate request for relief to use Code Cases N-416-1 and N-4g8-1 for the Unit 2 second 10 year interval.

3. Provide a list of all ultrasonic calibration blocks to be used during the second 10-year interval; including calibration block identification, material specifications, and sizes. Also, provide's list of all ultrasonic examination 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.

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

5. ' Augmented examinations havr been established by the NRC when added assurance of structural reliability is deeme.1 necessary. Examples of documents that address augmented examinations a<e:

. (1) Branch Technical Position MEB 3-1, High Energy Fluid Systems, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment; (2) Regal,e. tory Guide 1.150, Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations.

Address the degree of compliance with these documents and any other augmented examinations that may have been incorporated in the second 10-year ISl Program Plan. -

- 6. ' Request for Relief No. 2-TYP-2-B3.110-1, Revision O. The licensee seeks relief from the t

requirements of Table IWB-2500-1, Category B-D, item No. B3.110 for Welds 2RCS* PRE 21-N-10, -11, -12, -13, and -14. Table 1 in the relief request provides examination coverage percentages for these welds, Do the examination percentages listed in Table 1 represent the actual first 10-year interval examination coverages for these welds? It appears that relief was not requested for these examinations during the

- first interval. Discuss the status of the first interval examinations and clarify the coverage estimates.

7. Request for Relief No. 2-TYP-2-APP-l-1, Revision 0. The licensee seeks relief from Appendix 1, Paragraph I-2300, which requires that ultrasonic inspection of bolts and studs be conducted in accordance with Appendix VI.

The licensee stated in "Altemative Qualification" that "DLC personnel will be qualified using the PDI Performance Demonstration Initiative Program and DLC written practice QSP 2.11 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) bolts and studs.

' However, it should be noted that implementation of Appendix Vill is imminent for ultrasonic examination systems. Is it the intent of DLC to use the PDI qualific; tion for all UT applications or for bolting only? Discuss DLC's plans regarding the implementation of Appendix Vill ,

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8. Request for Relief No. 2-TYP-2-C6.10-1, Revision 0. The licensee seeks relief from . ,

performing the surface examinations on the Recirculating Spray Pump Casing Welds as '

required by ASME XI, item C6.10. 4

i The licensee stated that " Access to these welds requires disassembly of the pump casing I for those welds located in the floor sleeve; disassembly and removal from the sump for  ;

the lower casing section; removal of welded gusset plates for welds 9,10,17 and 18. '

This evolution risks damage to the pump, il order to examine plant components that have a proven reliability record throughout the industry." Are these pump casings designed to be removed for normal maintenance, repair, and inspections? Provide additional information concerning the risk of damage to the pump if the casing is removed.  ;

it appears from the weld numbers provided and the referenced drawing that the licensee l Is seeking relief for only a portion of the welds. The licensee states in the "Altemative '

Examination" portion of the request for relief that a complete examination is performed on eleven other casing welds. Provide the " Weld Number" and "Examinable Amount" for the L other eleven casing welds.

l Using the referenced drawing,10080 ISI-E-2M, it is difficult to locate Welds 2RSS*P21A- l C-21 and C-24 (circumferential welds). However, Weids 2RSS*P21A-1.-21 and L-24 (longitudinal welds) are identified. To evaluate this request for relief, it is necessary to obtain the correct identity for the subject welds. Verify that all welds requiring relief are identified.

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9. Request for Relief /Altemative Examination No. 2-TYP-2-UT-1, Revision 0. The licensee l

has proposed 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 as an attemative to the 1989 Edition of ASME XI.

t identify the specific requirements of the 1989 Edition of ASMti XI that will not be met if

- ultrasonic examination procedures meeting the requiremords of the PDI Program i

Description, Revision 1 are used. Also, provide a copy of PDI Program Description, l- Revision 1 as referenced in the request for relief.

j. J. Request for Relief /Altemative Examination No. 2-TYP-2-N-521, Revision 0, proposes an i

attemative schedule for reactor pressure vessel noule examinations. Code Case N-521, l Altemative Rules for Doktral of Inspections of Nonle-to-Vessel Welds, Inside Radius l Sections, and Nonle-to-Safe End Welds of a Pressurized WaterReactor Vessel, states j that examination of RPV nonles, IR sections, and nonle-to-safe end welds 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 areas contain identified flaws or relevant conditions that currently require successive inspections in accordance I 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 l

l. time lapse between examinations will not exceed 10 years, except ts adjusted by IWA-  !

2430(a). Confirm that all of these conditions will be met.

K. 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.

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