ML110390699

Notification of Inspection (NRC Inspection Report 05000498-11-003 and Request for Information

ML110390699
Person / Time
Site:	South Texas
Issue date:	02/07/2011
From:	Werner G E NRC/RGN-IV/DRS/PSB-2
To:	Halpin E D South Texas
References
IR-11-003
Download: ML110390699 (14)

See also: IR 05000498/2011003

Text

UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125 February 7, 2011

Mr. Edward D. Halpin President and

Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483

SUBJECT: South Texas Project Unit 1 - NOTIFICATION OF INSPECTION (NRC INSPECTION REPORT 05000498/2011003) AND REQUEST FOR INFORMATION

Dear Mr. Halpin:

From April 4 through 15, 2011, senior operations engineers from the Nuclear Regulatory Commission's (NRC) Region IV office will perform the baseline inservice inspection at South Texas Project Unit 1, using NRC Inspection Procedure 71111.08, "Inservice Inspection Activities." Experience has shown that this inspection is a resource intensive inspection both for

the NRC inspectors and your staff. In order to minimize the impact to your onsite resources and to ensure a productive inspection, we have enclosed a request for documents needed for this inspection. These documents have been divided into two groups. The first group, due by March 23, 2011, (Section A of the enclosure) identifies information to be provided prior to the inspection to ensure that the inspectors are adequately prepared. The second group (Section B of the enclosure) identifies the information the inspectors will need upon arrival at the site. It is important that all of these documents are up-to-date and complete in order to minimize the

number of additional documents requested during the preparation and/or the onsite portions of the inspection.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Mr. Phil Walker of your licensing

organization. Our inspection dates are subject to change based on your updated schedule of outage activities. If there are any questions about this inspection or the material requested, please contact the lead inspector Kelly Clayton at (817) 860-8216 (Kelly.Clayton@nrc.gov) or Gabriel Apger at (817) 276-6508 (Gabriel.Apger@nrc.gov).

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, Control Number 31500011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control number.

STP Nuclear Operating Company - 2 -

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, /RA/

Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety

Docket: 50-498 License: NPF-76

Enclosure: Inservice Inspection Document Request

cc w/enclosure:

Kevin Richards, Senior Vice President and Assistant to CEO STP Nuclear Operating Company South Texas Project P.O. Box 289

Wadsworth, TX 77483

David W. Rencurrel Senior Vice President Units 1 and 2 STP Nuclear Operating Company

South Texas Project P.O. Box 289 Wadsworth, TX 77483

Louis Peter, Plant General Manager

STP Nuclear Operating Company South Texas Project P.O. Box 289 Wadsworth, TX 77483

Tim Powell, Vice President, Engineering STP Nuclear Operating Company

South Texas Project P.O. Box 289 Wadsworth, TX 77483

STP Nuclear Operating Company - 3 -

A. W. Harrison, Manager, Licensing STP Nuclear Operating Company South Texas Project P.O. Box 289

Wadsworth, TX 77483

Charles T. Bowman, General Manager, Oversight STP Nuclear Operating Company South Texas Project

P.O. Box 289 Wadsworth, TX 77483

Marilyn Kistler Senior Staff Specialist, Licensing STP Nuclear Operating Company South Texas Project

P.O. Box 289 Wadsworth, TX 77483

Cheryl Mele City of Austin

Electric Utility Department 721 Barton Springs Road Austin, TX 78704

J. J. Nesrsta/R. K. Temple

Ed Alercon/Kevin Pollo City Public Service P.O. Box 1771 San Antonio, TX 78296

A. H. Gutterman, Esq.. Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004

Richard A. Ratliff, P.E., L.M.P. Radiation Safety Licensing Branch Manager Division for Regulatory Services Texas Department of State Health Mail Code 2385 P.O. Box 149347 Austin, TX 78714-9347

Brian Almon Public Utility Commission of Texas P.O. Box 13326 Austin, TX 78711-3326

STP Nuclear Operating Company - 4 -

Environmental and Natural Resources Policy Director, Office of the Governor P.O. Box 12428 Austin, TX 78711-3189

Mr. Nate McDonald Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street

Bay City, TX 77414

Anthony P. Jones, Chief Boiler Inspector Texas Department of Licensing and Regulation Boiler Division E.O. Thompson State Office Building P.O. Box 12157

Austin, TX 78711

Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality

MC-122 P.O. Box 13087 Austin, TX 78711-3087

Ted Enos

4200 South Hulen, Suite 422 Fort Worth, TX 76109

Kevin Howell/Catherine Callaway/Jim von Suskil NRG Energy, Inc.

1301 McKinney, Suite 2300 Houston, TX 77010

Peter G. Nemeth Crain, Caton, & James, P.C.

P.O. Box 289 Mail Code: N5005 Wadsworth, TX 77483

Chief, Technological Hazards Branch FEMA Region VI

800 North Loop 288 Federal Regional Center Denton, TX 76201-3698

STP Nuclear Operating Company - 5 -

Chairperson Radiological Assistance Committee FEMA Region VI 800 North Loop 288

Federal Regional Center Denton, TX 76201-3698

C. Kierksey City of Austin

Electric Utility Department 721 Barton Springs Road Austin, TX 78704

STP Nuclear Operating Company - 6 -

Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) Deputy Regional Administrator (Art.Howell@nrc.gov) DRP Director (Kriss.Kennedy@nrc.gov)

DRP Deputy Director (Troy.Pruett@nrc.gov) DRS Director (Anton.Vegel@nrc.gov) DRS Deputy Director (Vacant) Senior Resident Inspector (John.Dixon@nrc.gov) Resident Inspector (Binesh.Tharakan@nrc.gov)

Branch Chief, DRP/A (Wayne.Walker@nrc.gov) Senior Project Engineer, DRP/A (David.Proulx@nrc.gov) STP Administrative Assistant (Lynn.Wright@nrc.gov) Project Engineer, DRP/A (Laura.Micewski@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Public Affairs Officer (Lara.Uselding@nrc.gov) Project Manager (Mohan.Thadani@nrc.gov)

Branch Chief, DRS/TSB (Michael.Hay@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov) Regional Counsel (Karla.Fuller@nrc.gov) Congressional Affairs Officer (Jenny.Weil@nrc.gov) OEMail Resource

OEDO RIV Coordinator (James.Trapp@nrc.gov) DRS/TSB STA (Dale.Powers@nrc.gov)

SUNSI Review Completed: ___Y___ ADAMS: Yes No Initials: ___kdc_ Publicly Available Non-Publicly Available Sensitive Non-Sensitive

SOE:OB SOE:OB C:PSB2 KClayton GApger GWern34

/RA/ /RA//RA/ 1/27/11 2/7/2011 2/7/2011 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

- 1 - Enclosure INSERVICE INSPECTION DOCUMENT REQUEST

Inspection Dates: April 4 through 15, 2011

Inspection Procedures: IP 71111.08 "Inservice Inspection (ISI) Activities"

Inspectors: Kelly Clayton, Sr. Operations Engineer (Lead Inspector) Gabriel Apger, Sr. Operations Engineer

A. Information Requested for the In-Office Preparation Week

The following information should be sent to the Region IV office in hard copy or electronic format (ims.certrec.com preferred), in care of Kelly Clayton, by March 21, 2011, to facilitate the selection of specific items that will be reviewed during the onsite inspection week. The inspectors will select specific items from the information requested below and then request from your staff additional documents needed during the onsite

inspection week (Section B of this enclosure). We ask that the specific items selected from the lists be available and ready for review on the first day of inspection. Please provide requested documentation electronically if possible. If requested documents are large and only hard copy formats are available, please inform the inspector(s), and provide subject documentation during the first day of the onsite inspection. If you have any questions regarding this information request, please call the inspector as soon as possible.

A.1 ISI/Welding Programs and Schedule Information

a) A detailed schedule (including preliminary dates) of:

i) Nondestructive examinations planned for Class 1 and 2 systems and containment, performed as part of your ASME,Section XI, risk informed (if applicable), and augmented inservice inspection programs during the

upcoming outage

Provide a status summary of the nondestructive examination inspection activities vs. the required inspection period percentages for this interval by category per ASME,Section XI, IWX-2400. Do not provide separately if other documentation requested contains this information

ii) Reactor pressure vessel head examinations planned for the upcoming outage iii) Examinations planned for Alloy 82/182/600 components that are not included in the Section XI scope (If applicable)

iv) Examinations planned as part of your boric acid corrosion control program (Mode 3 walkdowns, bolted connection walkdowns, etc.)

- 2 - Enclosure v) Welding activities that are scheduled to be completed during the upcoming outage (ASME, Class 1, 2, or 3 structures, systems, or components)

b) Please provide a copy of ASME,Section XI, code relief requests and associated NRC safety evaluations applicable to the examinations identified above.

c) Please provide a list of nondestructive examination reports (ultrasonic, radiography, magnetic particle, dye penetrant, Visual VT-1, VT-2, and VT-3), which have identified relevant conditions on Code Class 1 and 2 systems since

the beginning of the last refueling outage. This should include the previousSection XI pressure test(s) conducted during start up and any evaluations associated with the results of the pressure tests. Also, include in the list the nondestructive examination reports with relevant conditions in the reactor pressure vessel head penetration nozzles that have been accepted for continued service. The list of nondestructive examination reports should include a brief description of the structures, systems, or components where the relevant

condition was identified.

d) Please provide a list with a brief description (e.g., system, material, pipe size, weld number, and nondestructive examinations performed) of the welds in Code Class 1 and 2 systems which have been fabricated due to component

repair/replacement activities since the beginning of the last refueling outage, or are planned to be fabricated this refueling outage.

e) If reactor vessel weld examinations required by the ASME Code are scheduled to occur during the upcoming outage, provide a detailed description of the welds to

be examined and the extent of the planned examination. Please also provide reference numbers for applicable procedures that will be used to conduct these examinations.

f) Please provide a copy of any 10 CFR Part 21 reports applicable to your structures, systems, or components within the scope of Section XI of the ASME Code that have been identified since the beginning of the last refueling outage.

g) Please provide a copy of any temporary noncode repairs in service (e.g., pinhole leaks). h) Please provide copies of the most recent self-assessments for the inservice inspection, welding, and Alloy 600 programs.

A.2 Reactor Pressure Vessel Head

a) Provide the detailed scope of the planned nondestructive examinations of the reactor vessel head which identifies the types of nondestructive examination methods to be used on each specific part of the vessel head to fulfill commitments made in response to NRC Bulletin 2002-02 and NRC Order EA-03-009. Also, include examination scope expansion criteria and

- 3 - Enclosure planned expansion sample sizes if relevant conditions are identified (if applicable).

b) Please provide a list of all standards and/or requirements that will be used to evaluate indications identified during nondestructive examination of the reactor

vessel head (e.g., the specific industry or procedural standards which will be used to evaluate potential leakage and/or flaw indications).

A.3 Boric Acid Corrosion Control Program

a) Please provide a copy of all procedures that govern the scope, equipment and implementation of the inspections required to identify boric acid leakage and the procedures for boric acid leakage/corrosion evaluation.

b) Please provide a list of leaks (including Code class of the components) that have been identified since the last refueling outage and associated corrective action documentation. If during the last cycle, the unit was shutdown, please provide

documentation of containment walkdown inspections performed as part of the boric acid corrosion control program.

c) Please provide a copy of the most recent self-assessment performed for the boric acid corrosion control program.

A.4 Steam Generator Tube (SGT) Inspections

a) Please provide a detailed schedule of:

i) Steam generator tube inspection, data analyses, and repair activities for the upcoming outage (If occurring)

ii) Steam generator secondary side inspection activities for the upcoming outage. (If occurring)

b) Provide a copy of your steam generator inservice inspection program and plan. Please include a copy of the operational assessment from last outage and a copy of the following documents as they become available:

i) Degradation assessment ii) Condition monitoring assessment

c) If you are planning on modifying your Technical Specifications such that they are consistent with Technical Specification Task Force Traveler TSTF-449, "Steam Generator Tube Integrity," please provide copies of your correspondence with the NRC regarding deviations from the standard technical specifications.

d) Provide a copy of steam generator history documentation given to vendors performing eddy current testing of the steam generators during the upcoming outage.

- 4 - Enclosure

e) Provide a copy of steam generator Eddy Current Data Analyst Guidelines and Site Validated Eddy Current Technique Specification Sheets. Additionally, please provide a copy of EPRI Appendix H Examination Technique Specification Sheets Qualification Records.

f) Identify and quantify any steam generator tube leakage experienced during the previous operating cycle. Also provide documentation identifying which steam generator was leaking and corrective actions completed or planned for this condition (If applicable).

g) Provide past history of the condition and issues pertaining to the secondary side of the steam generators (including items such as loose parts, fouling, top of tube sheet condition, crud removal amounts, etc.)

h) Please provide copies of your most recent self assessments of the steam generator monitoring, loose parts monitoring, and secondary side water

chemistry control programs.

i) Please also indicate where the primary, secondary, and resolution analyses are scheduled to take place.

j) Please provide a summary of the scope of the steam generator tube examinations, including examination methods such as Bobbin, Rotating Pancake, or Plus Point, and the percentage of tubes to be examined. Do not provide these documents separately if already included in other information requested. A.5 Additional information related to all inservice inspection activities

a) A list with a brief description of inservice inspection, boric acid corrosion control program, and steam generator tube inspection related issues (e.g., condition

reports) entered into your corrective action program since the beginning of the last refueling outage (for Unit 2). For example, a list based upon data base searches using key words related to piping or steam generator tube degradation such as: inservice inspection, ASME Code,Section XI, NDE, cracks, wear, thinning, leakage, rust, corrosion, boric acid, or errors in piping/steam generator

tube examinations.

b) Please provide names and phone numbers for the following program leads:

Inservice inspection contacts (examination, planning) Containment exams Reactor pressure vessel head exams

Snubbers and supports Repair and replacement program manager Licensing contact Site welding engineer

- 5 - Enclosure Boric acid corrosion control program Steam generator inspection activities (site lead and vendor contact)

B. Information to be provided onsite to the inspector(s) at the entrance meeting (April 4, 2011):

B.1 Inservice Inspection / Welding Programs and Schedule Information

a) Updated schedules for inservice inspection/nondestructive examination activities, including steam generator tube inspections, planned welding activities, and

schedule showing contingency repair plans, if available.

b) For ASME, Code Class 1 and 2 welds selected by the inspector from the lists provided from section A of this enclosure, please provide copies of the following documentation for each subject weld:

i) Weld data sheet (traveler)

ii) Weld configuration and system location

iii) Applicable Code Edition and Addenda for weldment

iv) Applicable Code Edition and Addenda for welding procedures

v) Applicable weld procedures used to fabricate the welds

vi) Copies of procedure qualification records supporting the weld procedures from B.1.b.v

vii) Copies of mechanical test reports identified in the procedure qualification records above

viii) Copies of the nonconformance reports for the selected welds (If applicable)

ix) Radiographs of the selected welds and access to equipment to allow viewing radiographs (If radiographic testing was performed)

x) Copies of the preservice examination records for the selected welds.

xi) Copies of welder performance qualifications records applicable to the selected welds, including documentation that welder maintained proficiency in the applicable welding processes specified in the weld procedures (at least 6 months prior to the date of subject work)

xii) Copies of nondestructive examination personnel qualifications (Visual inspection, penetrant testing, ultrasonic testing, radiographic testing), as applicable

- 6 - Enclosure c) For the inservice inspection related corrective action issues selected by the inspectors from section A of this enclosure, provide a copy of the corrective actions and supporting documentation.

d) For the nondestructive examination reports with relevant conditions on Code Class 1 and 2 systems selected by the inspectors from Section A above, provide a copy of the examination records, examiner qualification records, and associated corrective action documents.

e) A copy of (or ready access to) most current revision of the inservice inspection program manual and plan for the current Interval.

f) For the nondestructive examinations selected by the inspectors from section A of this enclosure, provide a copy of the nondestructive examination procedures used to perform the examinations (including calibration and flaw characterization/sizing procedures). For ultrasonic examination procedures qualified in accordance with ASME, Code,Section XI, Appendix VIII, provide

documentation supporting the procedure qualification (e.g., the EPRI performance demonstration qualification summary sheets). Also, include qualification documentation of the specific equipment to be used (e.g., ultrasonic unit, cables, and transducers including serial numbers) and nondestructive examination personnel qualification records.

B.2 Reactor Pressure Vessel Head

a) Provide the nondestructive personnel qualification records for the examiners who will perform examinations of the reactor pressure vessel head.

b) Provide drawings showing the following: (If a visual examination is planned for the upcoming refueling outage)

i) Reactor pressure vessel head and control rod drive mechanism nozzle configurations

ii) Reactor pressure vessel head insulation configuration

The drawings listed above should include fabrication drawings for the nozzle

attachment welds as applicable.

c) Provide a copy of nondestructive examination reports from the last reactor pressure vessel head examination.

d) Provide a copy of the evaluation or calculation demonstrating that the scope of the visual examination of the upper head will meet the 95 percent minimum

coverage required by NRC Order EA-03-009 (If a visual examination is planned for the upcoming refueling outage).

- 7 - Enclosure e) Provide a copy of the procedures that will be used to identify the source of any boric acid deposits identified on the reactor pressure vessel head. If no explicit procedures exist which govern this activity, provide a description of the process to be followed including personnel responsibilities and expectations.

f) Provide a copy of the updated calculation of effective degradation years for the reactor pressure vessel head susceptibility ranking.

g) Provide copy of the vendor qualification report(s) that demonstrates the detection capability of the nondestructive examination equipment used for the reactor

pressure vessel head examinations. Also, identify any changes in equipment configurations used for the reactor pressure vessel head examinations which differ from that used in the vendor qualification report(s).

B.3 Boric Acid Corrosion Control Program

a) Provide boric acid walkdown inspection results, an updated list of boric acid leaks identified so far this outage, associated corrective action documentation, and overall status of planned boric acid inspections.

b) Provide any engineering evaluations completed for boric acid leaks identified since the end of the last refueling outage. Please include a status of corrective

actions to repair and/or clean these boric acid leaks. Please identify specifically which known leaks, if any, have remained in service or will remain in service as active leaks.

B.4 Steam Generator Tube Inspections

a) Provide copies of the Examination Technique Specification Sheets and associated justification for any revisions.

b) Provide a copy of the guidance to be followed if a loose part or foreign material is identified in the SGs.

c) Provide a copy of the eddy current testing procedures used to perform the steam generator tube inspections (specifically calibration and flaw characterization/sizing procedures, etc.). Also include documentation for the

specific equipment to be used.

d) Provide copies of your responses to NRC and industry operating experience communications such as Generic Letters, Information Notices, etc. (as applicable to steam generator tube inspections) Do not provide these documents separately if already included in other information requested such as the degradation assessment. e) Provide a list of corrective action documents generated by the vendor and/or site with respect to steam generator inspection activities.

- 8 - Enclosure B.5 Codes and Standards

a) Provide ready access to (i.e., copies provided to the inspector(s) for use during the inspection at the onsite inspection location, or room number and location where available):

i) Applicable Editions of the ASME Code (Sections V, IX, and XI) for the inservice inspection program and the repair/replacement program.

ii) EPRI and industry standards referenced in the procedures used to perform the steam generator tube eddy current examination.

Inspector Contact Information:

Kelly Clayton Gabriel Apger Senior Operations Engineer Senior Operations Engineer

817-860-8216 817-276-6508 Kelly.Clayton@nrc.gov (Gabriel.Apger@nrc.gov) Mailing Address: US NRC Region IV

Attn: Kelly Clayton 612 E. Lamar Blvd, Suite 400 Arlington, TX 76011