ML19064B265

Summary of February 28, 2019, Public Meeting with Pacific Gas and Electric Company to Discuss the Proposed Relief Request Concerning Reactor Vessel Internal Visual Examination for the Diablo Canyon Nuclear Power Plant, Units 1 & 2

ML19064B265
Person / Time
Site:	Diablo Canyon
Issue date:	03/14/2019
From:	Balwant Singal Plant Licensing Branch IV
To:	Pacific Gas & Electric Co
Singal B, 301-415-3016
References
EPID L-2019-LRM-0009
Download: ML19064B265 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 14, 2019 LICENSEE: Pacific Gas and Electric Company FACILITY: Diablo Canyon Nuclear Power Plant, Units 1 and 2

SUMMARY

OF FEBRUARY 28, 2019, PRESUBMIITAL TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY TO DISCUSS A PROPOSED RELIEF REQUEST CONCERNING REACTOR VESSEL INTERNAL VISUAL EXAMINATION FOR THE DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 (EPID L-2019-LRM-0009)

On February 28, 2019, a Category 1 public meeting was held by teleconference between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Pacific Gas and Electric Company (PG&E, the licensee). The purpose of the meeting was to discuss a proposed relief request concerning reactor vessel internal visual examination for the Diablo Canyon Nuclear Power Plant, Units 1 and 2 (DCPP). The meeting notice and agenda, dated February 14, 2019, are available in the Agencywide Documents Access and Management System Accession No. ML19045A004. No formal presentation slides were used during the meeting. Enclosed is a list of attendees.

During the meeting, the following information was discussed, which will be included in the proposed relief request:

• Table IWB-2500-1, Examination Category B-N-1, Item B13.10, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code),Section XI, requires a periodic visual VT-3 examination. The ASME Code requires that this examination be performed each inspection period (3~ years) on average after the first inspection interval.

• The proposed relief request is to propose an alternative to the visual VT-3 examination specified by ASME Code,Section XI, for Examination Category B-N-1 for the remainder of the fourth inservice inspection interval under Title 1O of the Code of Federal Regulations paragraph 50.55(a)(z)(1 ), "Acceptable level of quality and safety."

• The licensee stated that the Electric Power Research Institute (EPRI) assessment, documented by Report 3002012966, 1 "Evaluation of Basis for Periodic Visual Examination of Accessible Areas of Reactor Vessel Interior per Examination Category B-N-1of ASME Section XI, Division 1," documents the basis and benefit of the periodic visual VT-3 examination of the reactor 1 The EPRI report may not be publically available. Also, the EPRI report has not been endorsed by the NRC staff.

2 vessel interior specified for ASME Examination Category B-N-1. As determined by a review of the historical evolution of the requirements for Examination Category B-N-1, the purpose of this examination is to detect foreign material and debris in the interior of the reactor vessel. The EPRI report concludes that other industry requirements and guidance are sufficient for the purposes of detecting and removing foreign material and debris in the reactor vessel.

• Foreign material and debris examinations are not directly related to vessel integrity and are routinely performed during refueling outages at DCPP through core plate foreign object search and retrieval, core verification, and other maintenance activities. The practices at DCPP during refueling outages to exclude foreign material and to detect and remove foreign material and debris from the interior of the reactor vessel and fuel assemblies are sufficient to provide an acceptable level of quality and safety in lieu of the ASME Examination Category B-N-1 visual VT-3 examination requirement.

• The licensee further stated that ASME is in the process of approving a code case eliminating the need for the visual VT-3 examination specified by the Code. The licensee believes that the NRC staff has also voted in favor of the code case.

However, a code case has not been published at this time.

• The licensee stated that the proposed alternative meets the requirements of 10 CFR 50.55a(z)(1) and provides an acceptable level of quality and safety.

The NRC staff stated that since the referenced EPRI report used as the basis for justification for the proposed alternative has not been endorsed by the NRC staff, the request needs to address all the qualitative analysis included in the EPRI report on a plant-specific basis, and the submittal has to be a stand-alone document without references to the analysis included in the EPRI report. Any additional supporting analysis performed by the licensee or Westinghouse should also be included in the submittal.

The purpose of the meeting was to exchange technical information and no regulatory decisions were made during the meeting.

The licensee indicated that the request will be submitted to the NRC staff before the end of March 2019, and requested the NRC staff to complete its review by October 1, 2019. The staff indicated that it will try its best to support the licensee's requested date. The staff stated that a high quality submittal that does not require requests for additional information, will assist the staff in meeting the licensee's requested date Public Comments The following comments were made by some of the members of the public on teleconference.

Comment 1 Mr. Marvin Lewis indicated that Framatome has developed an Angle Beam Ultrasonic Probe technique (no details provided), and suggested that the licensee should be asked to use this technique instead of eliminating the visual VT-3 examination required by the ASME Code. The NRC staff indicated that the examination technique, suggested by Mr. Lewis, qualifies as volumetric examination and cannot be considered as a replacement for visual VT-3

3 examination. However, this comment does not apply to the topic of discussion. Mr. Lewis stated that he disagreed with the NRC staff and did not ask for any further clarification Comment 2 Ms. Linda Seeley was concerned about NRC staff authorizing fewer inspections instead of asking for more. The NRC stated that the purpose of the call is to exchange technical information. At this time no regulatory decision is being made by the NRC and no official submittal has been made by the licensee. The NRC staff further stated that they will review the request when submitted and will make its decision based on the information and justification provided by the licensee in its application. The decision will be based on maintaining an acceptable level of quality and safety as required by the regulation at 10CFR 50.55a(z)(1 ).

Additionally, the NRC staff discussed that they are not obligated to approve the request if it does not satisfy the requirements of the regulations.

Ms. Seeley asked if the NRC staff has ever denied such requests. The staff replied that the NRC has denied relief request in the past. Ms. Seeley further asked if the staff has ever denied any such request for DCPP. The staff stated that they can answer this question only after review of plant records. Ms. Seeley did not have any further questions.

Comment 3 Ms. Donna Gilmore asked the NRC staff to explain the reason for performing the visual VT-3 examinations. The NRC staff stated that the purpose is to identify any loose parts or foreign materials inside the reactor vessel. Ms. Gilmore asked what will be the consequences if any foreign materials go undetected. The NRC staff stated that most of the time there will not be any significant consequences, and that the foreign materials are likely to be detected and removed during the following refueling outage. In a worst case scenario, the foreign materials may result in some fuel cladding damage resulting in fuel leak. However, cladding is only one of the three barriers and there should be no dose consequence to the public.

No Public Meeting Feedback forms were received.

Please direct any inquiries to me at 301-415-3016 or via e-mail at Balwant.Singal@nrc.gov.

~i-~,\,\;~

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosure:

List of Attendees cc: Listserv

LIST OF ATIENDEES FEBRUARY 28, 2019, PRESUBMITIAL TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY TO DISCUSS A PROPOSED RELIEF REQUEST CONCERNING REACTOR VESSEL INTERNAL VISUAL EXAMINATION DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 NAME ORGANIZATION David Alley NRC 1 (NRR)2 David Dijamco NRC (NRR)

Simon Sheng NRC (NRR)

Mark Yoo NRC (NRR)

Balwant Singal NRR (NRR)

David Gonzalez PG&E 3 James Hill PG&E Michael Richardson PG&E Rama Thatipamala PG&E Robert Grizzi EPRl 4 Chris Joffe EPRI Gary Stevens EPRI Markus Burkardt Dominion Engineering5 Glenn White Dominion Engineering Donna Gilmore Member of the Public Marvin Lewis Member of the Public Linda Seeley Member of the Public 1 U.S. Nuclear Regulatory Commission (NRC) 2 Office of Nuclear Reactor Regulation (NRR) 3 Pacific Gas and Electric Company (PG&E) 4 Electric Power Research Institute (EPRI) 5 Representing PG&E Enclosure

SUMMARY

OF FEBRUARY 28, 2019, PRESUBMITIAL TELECONFERENCE MEETING WITH PACIFIC GAS AND ELECTRIC COMPANY TO DISCUSS A PROPOSED RELIEF REQUEST CONCERNING REACTOR VESSEL INTERNAL VISUAL EXAMINATION FOR THE DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 (EPID L-2019-LRM-0009) DATED MARCH 14, 2019 DISTRIBUTION:

PUBLIC PM File Copy RidsACRS_MailCTR Resource RidsNrrDorl Resource RidsNrrDorlLpl4 Resource RidsNrrLAPBlechman Resource RidsNrrPMDiabloCanyon Resource RidsRgn4MailCenter Resource RidsNrrDmlrMvib Resource DDijamco, NRR SSheng, NRR MYoo, NRR JLarsen, RIV MMcCoppin, OEDO RIV ADAMS A ccess1on Nos.: M eetmg Not1ce:

. ML19045A004 S ummary: ML190648265 *via

. e-ma1*1 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LAit NRR/DORL/LPL4/LA NAME BSingal KZeleznock PBlechman DATE 03/11/19 03/08/19 03/01/19 OFFICE NRR/DLPM/MVIB/BC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME DAIiey RPascarelli BSingal DATE 03/05/19 03/14/19 03/14/19 OFFICIAL RECORD COPY .