ML070790113

Confirmatory Action Letter

ML070790113
Person / Time
Site:	Oconee
Issue date:	03/27/2007
From:	Dyer J E Office of Nuclear Reactor Regulation
To:	Hamilton B H Duke Energy Carolinas, Duke Power Co
Olshan L N, NRR/DORL, 415-1419
References
MRP-139, TAC MD4166, TAC MD4167, NRR-07-022
Download: ML070790113 (6)

Text

March 27, 2007 CAL No. NRR-07-022Mr. Bruce H. HamiltonVice President, Oconee Site Duke Power Company LLC 7800 Rochester Highway Seneca, SC 29672

SUBJECT:

CONFIRMATORY ACTION LETTER - OCONEE NUCLEAR STATION, UNITS 2AND 3 (TAC NOS. MD4166 AND MD4167)

Dear Mr. Hamilton:

This letter confirms commitments by Duke Power Company LLC, d/b/a Duke Energy Carolinas,LLC, regarding Alloy 82/182 butt welds in the pressurizers at the Oconee Nuclear Station, Units

2 and 3.

The discovery, in October 2006, of five circumferential indications in three dissimilar metal (DM)welds on the pressurizer at the Wolf Creek Generating Station (Wolf Creek) raised safetyconcerns based on the size and location of the indications. At Wolf Creek, three indicationswere in the pressurizer surge nozzle-to-safe end weld, and two separate indications were in thesafety and relief nozzle-to-safe end welds. These findings also indicated that significantconcerns might exist with the inspection schedules for addressing the pressurizer weldconcerns issued by the industry-sponsored Materials Reliability Program (MRP), in "PrimarySystem Piping Butt Weld Inspection and Evaluation Guideline (MRP-139)."The Nuclear Regulatory Commission (NRC) is concerned about the pressurizer surge nozzle-to-safe end weld indications, as this is the first time that multiple circumferential primarywater stress-corrosion cracking (PWSCC) indications have been identified in a weld. Thiscondition calls into question the degree of safety margin present in past structural integrityevaluations for flawed DM welds susceptible to PWSCC, since multiple stress-corrosioncracking flaws may grow independently and ultimately grow together, significantly reducing thetime from flaw initiation to leakage or rupture. The size of the relief nozzle-to-safe end flaw isalso of concern, as this flaw has a much larger aspect ratio than those assumed in theestimates used to establish the basis for completing the baseline inspections required by theindustry-sponsored MRP. Larger aspect ratios could result in achieving a critical flaw size andrupture before the onset of detectable leakage. The long-term resolution of this issue is expected to involve changes to the American Society ofMechanical Engineers Boiler and Pressure Vessel Code (ASME Code), and will involvechanges to the NRC regulations in Title 10 of the Code of Federal Regulations (10 CFR),Part 50, Section 50.55a, "Codes and standards." The development of the NRC regulations, whether the rule adopts the ASME Code standards or defines separate requirements, will likelybenefit from additional operating experience, continuing assessments, and analysis beingconducted by the NRC and the MRP.

Until NRC regulations are revised, it is necessary to establish a minimum set of enhancedreactor coolant system (RCS) DM butt weld inspection expectations for nickel-basedAlloy 82/182 pressurizer surge, spray, safety, and relief nozzle butt welds, including safe endwelds, to supplement existing inspection and other requirements of the ASME Code and NRCregulations. In addition, enhanced monitoring of RCS leakage is needed to promptly identifyany through-wall flaws in the pressurizer surge, spray, safety, or relief nozzle DM butt welds orsafe end DM butt welds to prevent additional degradation from occurring. The above actionsprovide reasonable assurance that there is no undue risk to the health and safety of the publicwhile the NRC regulations are revised. The NRC communicated the need for near-term enhancements to the industry through publicmeetings held on November 30, 2006, December 20, 2006, and February 2, 2007. Licenseessubmitted letters voluntarily committing to the enhanced inspection and leakage monitoringrequirements. After teleconferences with specific licensees held between February 12 throughFebruary 23, 2007, the licensees submitted supplemental commitment letters addressing theNRC staff's concerns regarding inspection, compensatory actions, and reporting.In your letter dated January 31, 2007 (Agencywide Documents Access & Management System(ADAMS) Accession Number ML070390049), as supplemented by letter dated February 22, 2007 (ADAMS Accession Number ML070600169), you described actions you will take at the Oconee Nuclear Station, Units 2 and 3, for the pressurizer dissimilar metal butt welds containing Alloy 82/182 material. These commitments address: 1) completion schedules for inspection/mitigation of the welds; 2) RCS leak monitoring frequency, action levels, and actions; and 3) reporting requirements. The NRC staff has reviewed these actions and commitments and agrees the actions andcommitments are appropriate to address the potential of PWSCC of the applicable pressurizer dissimilar metal butt welds containing Alloy 82/182 material with clarification on one of the commitments as indicated in bold below regarding reports to be provided to the NRC.

• Report to the NRC, within 60 days of unit restart, details of the inspectionresults of any unmitigated weld examinations and any corrective or mitigative actions taken on the pressurizer surge, spray, safety, or relief nozzle or safe end welds containing Alloy 82/182 material.This clarification was discussed with and agreed upon by your staff during a telephonediscussion on March 22, 2007, between Graham Davenport, Regulatory Compliance Manager, and Michele Evans, Director-Division of Component Integrity.Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, you are required to: 1)Notify me immediately if your understanding differs from that set forth above;2)Notify me if for any reason you cannot complete the actions and commitments within the specified schedule and advise me in writing of your modified schedule in advance of the change; and3)Notify me in writing when you have completed the actions and commitments addressed in this Confirmatory Action Letter.Issuance of this Confirmatory Action Letter does not preclude issuance of an order formalizingthe above commitments or requiring other actions on the part of the licensee; nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action Letter may result in enforcement action.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter andyour response will be made available electronically for public inspection in the NRC PublicDocument Room or from the NRC's ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should notinclude any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.Sincerely,/RA/J. E. Dyer, Director Office of Nuclear Reactor RegulationDocket Nos. 50-270, 50-287License Nos. DPR-47, DPR-55cc: See next page

ML070790113 OFFICECPNBDCILPL2-1/PMLPL2-1/LALPL2-1/BCTECH EDDIRS/TANAMETLupoldESullivanLOlshanMO'Brien/OL forEMarinosHChangRPascarelliDATE3/23/073/23/073/22/073/22 /073/26/07 2/28/073/26/07 OFFICECPNB/BCDRP/D RGN 2DORL/DDCI/DAD:DESNRR/DNAME TChan/

GG forCCasto/per emailChristensenCHaney JL forMEvansJgrobe/PH forJDyerDATE 3/26/073/23/073/26/073/26/073/27/073/27/07 Oconee Nuclear Station, Units 1, 2, and 3 cc:

Mr. Bruce H. HamiltonVice President, Oconee Site Duke Power Company LLC 7800 Rochester Highway Seneca, SC 29672Ms. Lisa F. VaughnAssociate General Counsel and Managing Attorney Duke Energy Carolinas, LLC 526 South Church Street - EC07H Charlotte, North Carolina 28202Manager, LISNUS Corporation 2650 McCormick Dr., 3rd Floor Clearwater, FL 34619-1035Senior Resident InspectorU.S. Nuclear Regulatory Commission 7812B Rochester Highway Seneca, SC 29672Mr. Henry Porter, DirectorDivision of Radioactive Waste Management Bureau of Land and Waste Management Dept. of Health and Env. Control 2600 Bull St.

Columbia, SC 29201-1708Mr. Michael A. SchoppmanFramatome ANP 1911 North Ft. Myer Dr.

Suite 705 Rosslyn, VA 22209Mr. B. G. DavenportRegulatory Compliance Manager Oconee Nuclear Site Duke Energy Corporation ON03RC 7800 Rochester Highway Seneca, SC 29672Mr. Leonard G. GreenAssistant Attorney General NC Department of Justice P.O. Box 629 Raleigh, NC 27602Mr. R. L. Gill, Jr.Manager - Nuclear Regulatory Issues and Industry Affairs Duke Power Company LLC 526 S. Church St.

Mail Stop EC05P Charlotte, NC 28202Division of Radiation ProtectionNC Dept of Environment, Health, & Natural

Resources 3825 Barrett Dr.

Raleigh, NC 27609-7721Mr. Peter R. Harden, IVVP-Customer Relations and Sales Westinghouse Electric Company 6000 Fairview Road 12th Floor Charlotte, NC 28210Mr. Henry BarronGroup Vice President, Nuclear Generation and Chief Nuclear Officer P.O. Box 1006-EC07H Charlotte, NC 28201-1006Mr. Charles BrinkmanDirector, Washington Operations Westinghouse Electric Company 12300 Twinbrook Parkway, Suite 330 Rockville, MD 20852Ms. Kathryn B. NolanSenior Counsel Duke Energy Carolinas, LLC 526 South Church Street - EC07H Charlotte, NC 28202