ML060250649

RAI Concerning Response to GL 2004-01, Requirements for Steam Generator Tube Inspections.

ML060250649
Person / Time
Site:	San Onofre
Issue date:	01/18/2006
From:	Kalyanam N Plant Licensing Branch III-2
To:	Rosenblum R Southern California Edison Co
Kalynanam N, NRR/DLPM,415-1480
References
GL-04-001, TAC MC4849
Download: ML060250649 (5)

Text

January 18, 2006Mr. Richard M. RosenblumChief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION (SONGS), UNIT 2 -REQUEST FOR ADDITIONAL INFORMATION CONCERNING RESPONSE TO GENERIC LETTER 2004-01, "REQUIREMENTS FOR STEAM GENERATOR TUBE INSPECTIONS" (TAC NO. MC4849)

Dear Mr. Rosenblum:

On August 30, 2004, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter(GL) 2004-01, "Requirements For Steam Generator Tube Inspections." The purpose of GL 2004-01 was to obtain information that would enable the NRC staff to determine whetherlicensees' steam generator tube inspection programs comply with the existing tube inspection requirements (the plant technical specifications in conjunction with Appendix B to Part 50 of Title 10 of the Code of Federal Regulations

).By letter dated October 26, 2004 (Agencywide Documents Access and Management System(ADAMS) Accession Number ML043020250), as supplemented by letter dated November 23, 2005 (ADAMS Accession Number ML053320210), Southern California Edison (SCE), the licensee for SONGS, submitted the response to GL 2004-01. The NRC Staff has reviewed the SCE response to GL 2004-01 for SONGS, Unit 2, anddetermined that additional information is needed in order for the NRC staff to complete areview. The NRC staff requests that you forward the enclosed questions to the licensee.If you have any questions, please me at (301) 415-1480.Sincerely,/RA/N. Kalyanam, Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-361

Enclosure:

Request for Additional Information cc w/encl: See next page Mr. Richard M. RosenblumJanuary 18, 2006Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION (SONGS), UNIT 2 -REQUEST FOR ADDITIONAL INFORMATION CONCERNING RESPONSE TO GENERIC LETTER 2004-01, "REQUIREMENTS FOR STEAM GENERATOR TUBE INSPECTIONS" (TAC NO. MC4849)

Dear Mr. Rosenblum:

On August 30, 2004, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter(GL) 2004-01, "Requirements For Steam Generator Tube Inspections." The purpose of GL 2004-01 was to obtain information that would enable the NRC staff to determine whetherlicensees' steam generator tube inspection programs comply with the existing tube inspection requirements (the plant technical specifications in conjunction with Appendix B to Part 50 of Title 10 of the Code of Federal Regulations

).By letter dated October 26, 2004 (Agencywide Documents Access and Management System(ADAMS) Accession Number ML043020250), as supplemented by letter dated November 23, 2005 (ADAMS Accession Number ML053320210), Southern California Edison (SCE), the licensee for SONGS, submitted the response to GL 2004-01. The NRC Staff has reviewed the SCE response to GL 2004-01 for SONGS, Unit 2, anddetermined that additional information is needed in order for the NRC staff to complete areview. The NRC staff requests that you forward the enclosed questions to the licensee.If you have any questions, please me at (301) 415-1480.Sincerely,/RA/N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-361

Enclosure:

Request for Additional Information cc w/encl: See next pageDISTRIBUTIONPUBLICLPLIV r/fRidsNrrDorl (CHaney/CHolden)RidsNrrDorlLplg (DTerao)RidsNrrPMNKalyanamRidsNrrLALFeizollahiAHiserRidsAcrsAcnwMailCenterRidsOgcRpRidsRgn4MailCenter (TPruett)RidsNrrDorlDpr PKlein MYoder ACCESSION NO: MLOFFICENRR/LPL4/PMNRR/LPL4/LANRR/LPL4/BCNAMENKalyanamLFeizollahiDTeraoDATE1/10/061/10/061/18/06OFFICIAL RECORD COPYDOCUMENT NAME: E:\Filenet\ML060250649.wpd REQUEST FOR ADDITIONAL INFORMATIONRELATED TO SOUTHERN CALIFORNIA EDISONSAN ONOFRE NUCLEAR GENERATING STATION, UNIT 2, GL-2004-01 RESPONSEDOCKET NO. 50-361On August 30, 2004, the Nuclear Regulatory Commission (NRC) issued Generic Letter(GL) 2004-01, "Requirements For Steam Generator Tube Inspections." The purpose of GL 2004-01 was to obtain information that would enable the NRC staff to determine whetherlicensees' steam generator (SG) tube inspection programs comply with the existing tube inspection requirements (the plant technical specifications in conjunction with Appendix B to Part 50 of Title 10 of the Code of Federal Regulations

).By letter dated October 26, 2004 (Agencywide Documents Access and Management System(ADAMS) Accession Number ML043020250), as supplemented by letter dated November 23, 2005 (ADAMS Accession Number ML053320210), Southern California Edison, the licensee for San Onofre Nuclear Generating Station, Unit No. 2, submitted a response toGL 2004-01. The NRC staff has reviewed these letters and has determined that additionalinformation is needed in order for the NRC staff to complete a review. The NRC staff requeststhat the licensee respond to the following:In its response to GL 2004-01, the licensee indicated the following concerning inspections ofthe parent tube behind (i.e., adjacent to) the nickel band portion of Combustion Engineering Alloy 690 tungsten inert gas welded sleeves: (1) the inspections adjacent to the nickel band are limited; (2) completion of the ongoing evaluation and technical basis development is expected within the next year; (3) this issue is being tracked within their corrective action program; and (4) flaws in the parent tube adjacent to the nickel band are not safety significant.Given that it is not clear whether inspection techniques are capable of finding the forms ofdegradation that could be occurring in the parent tube adjacent to the nickel band and thelicensee is relying on a safety assessment indicating that inspections in this region are not needed to ensure structural and leakage integrity, it would appear that a license amendment is required consistent with the NRC staff position outlined in GL 2004-01.With respect to the qualification of a technique for inspecting the parent tube adjacent to thenickel band, the NRC staff notes that existing analysis is based on electro-discharged machined(EDM) notches with adjustments to account for differences between cracks and EDM notches. As discussed in Regulatory Issue Summary 2000-22, "Issues Stemming from NRC StaffReview of Recent Difficulties Experienced in Maintaining Steam Generator Tube Integrity," the NRC staff position is that technique qualifications based on EDM notched specimens do notprovide an adequate basis for evaluating the technique capability since EDM notchedspecimens produce much larger amplitude signals and have better signal-to-noise levels.

EDM notches may also produce different signal response characteristics. As a result of the above, we request the licensee discuss their plans (and schedule) forsubmitting an amendment demonstrating that structural and leakage integrity of the joint are ensured without inspecting the parent tube behind (i.e., adjacent to) the nickel band region. Alternatively, the licensee could either (1) demonstrate that the techniques they are using arecapable of finding the forms of degradation that could be in the parent tube behind the nickelband region, or (2) commit to remove all sleeves with a nickel band from service.

November 2005San Onofre Nuclear Generating Station Units 2 and 3 cc:Mr. Daniel P. Breig Southern California Edison Company San Onofre Nuclear Generating Station

P. O. Box 128 San Clemente, CA 92674-0128Mr. Douglas K. Porter, EsquireSouthern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770Mr. David Spath, ChiefDivision of Drinking Water and Environmental Management P. O. Box 942732 Sacramento, CA 94234-7320Chairman, Board of SupervisorsCounty of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101Eileen M. Teichert, Esq.Supervising Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522Mr. Gary L. Nolff Power Projects/Contracts Manager Riverside Public Utilities 2911 Adams Street Riverside, CA 92504Regional Administrator, Region IVU.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064Mr. Michael OlsonSan Diego Gas & Electric Company P.O. Box 1831 San Diego, CA 92112-4150Mr. Ed Bailey, ChiefRadiologic Health Branch State Department of Health Services Post Office Box 997414 (MS7610)

Sacramento, CA 95899-7414Resident Inspector/San Onofre NPS c/o U.S. Nuclear Regulatory Commission Post Office Box 4329 San Clemente, CA 92674Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672Mr. James T. Reilly Southern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92674-0128Mr. James D. Boyd, CommissionerCalifornia Energy Commission 1516 Ninth Street (MS 31)

Sacramento, CA 95814Mr. Ray Waldo, Vice PresidentSouthern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92764-0128Mr. Brian KatzSouthern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92764-0128Mr. Steve HsuDepartment of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899Mr. A. Edward SchererSouthern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92674-0128