ML110601208

Clarification Question Regarding the Response to RAI 3.1.2.3-01 in Columbia Letter Dated September 21, 2010

ML110601208
Person / Time
Site:	Columbia
Issue date:	02/25/2011
From:	Mostala A Energy Northwest
To:	Cunanan A License Renewal Projects Branch 1
References
Download: ML110601208 (3)

Text

From: Mostala, Abbas A. [AAMOSTALA@energy-northwest.com]

Sent: Friday, February 25, 2011 12:00 PM To: Cunanan, Arthur Cc: Mostala, Abbas A.

Subject:

RE: Clarification Questions regarding the Response to RAI 3.1.2.3-01 in Columbia Letter Dated September 21, 2010 Hello Arthur, For ease of reading the response to your questions, I have copied the questions, followed immediately by the clarifying information. At the end, I have provided supporting information from another RAI response letter. After reviewing this response, please let me know if you or the reviewer would like to discuss the issues in a conference call.

Regards, Abbas

Background:

In the response to RAI 3.1.2.3-01, by letter dated September 21, 2010, the applicant stated that:

However, the Columbia Risk Informed ISI Program does include volumetric examination of selected small-bore locations (3MS(9)-1, 3MS(9)-5, and 3MS(9)-7). As such, Columbia will add ISI to the aging management programs credited for management of SCC for these selected small bore components. See the amendment to the LRA provided in the enclosure to this letter.

In the amended LRA Table 3.1.2-3 (Amendment 11, Page 3.1-114b), the applicant also indicated, under Row Numbers 182 and 183, that the Inservice Inspection Program is credited to manage cracking due to flaw growth and cracking due to SCC, respectively, of CASS (cast austenitic stainless steel) valve bodies < 4 inches exposed to reactor coolant.

The staff notes that ASME Section XI, Division 1, Appendix VIII, Supplement 9 (2001 edition with 2002 and 2003 addenda) indicates that the qualification requirements for ultrasonic examination of cast austenitic piping welds are in the course of preparation.

Clarification Questions:

1. In the ISI program, what is the method of the volumetric examination for the CASS valve bodies < 4 inches? (For example, ultrasonic testing or radiographic testing)

EN Response:

The ISI program includes volumetric examinations of selected small-bore locations.

However, the ISI Program requirements for Row Numbers 182 and 183 are consistent with ASME XI, Table IWB-2500-1, Category B-M-1, Item Number B12.30 that requires a surface examination rather than a volumetric examination.

2. If ultrasonic testing (UT) is performed to inspect the CASS valves < 4 inches, briefly describe the qualification requirements that the applicant uses for the volumetric examination of the CASS valves.

EN Response:

The ASME Section XI, Division 1, Appendix VIII, Supplement 9 (2001 edition with 2002 and 2003 addenda) that indicates the qualification requirements for ultrasonic examination of cast austenitic piping welds are in the course of preparation is not applicable to Row Numbers 182 and 183 because a surface examination is required rather than a volumetric examination.

Supporting information:

Columbia Generating Stations ISI program does not perform volumetric examinations of valves less than 4 inches NPS . If the valve had a body weld it would be examined by surface methods in accordance with Section XI Code Category B-M-1, Item Number B12.30.

Clarifications to the two questions are found in the NRCs RAI 3.1.2.1-X1 on pages 10-11 of Letter dated 8/26/2010 from NRC to ENW (ML102220373) and ENW response (ML103160425) dated 11/11/2010 on pages 26-28.

From NRC letter The staff also noted that the 2001 edition of the ASME Code Section XI with 2002 and 2003 addenda, referenced by GALL AMP XI.M1, "ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD," requires that valve body welds in valves less than normal pipe size (NPS) 4 should be examined using surface examination in accordance with Table IWB-2500-1 (Examination Category B-M-1, Item No. B12.30). The staff finds that the ASME Code Section XI requirement is applicable to the applicant's line item Row No. 134 in LRA Table 3.1.2-3 because the valve bodies are less than 4 inches.

From ENW response Columbia has no small bore CASS Class 1 valves with either a manufacturing weld or a repair weld in the valve body. All small bore CASS Class 1 valve bodies (and bonnets) at Columbia are cast as one piece. The bodies and bonnets are bolted together. Consequently, there is no surface inspection of these valves in the Columbia lSI program.

From: Cunanan, Arthur [1]

Sent: Thursday, February 17, 2011 5:18 AM To: Mostala, Abbas A.

Subject:

FW: Clarification Questions regarding the Response to RAI 3.1.2.3-01 in Columbia Letter Dated September 21, 2010

Abbas, Could you please clarify this question below? You can respond via e-mail and I can place the e-mail in ADAMS. If you prefer a conference call, we can also accommodate.

Sincerely, Arthur Cunanan Project Manager NRR/DLR/RPB1 O-11H08

301-415-3897 arthur.cunanan@nrc.gov From: Min, Seung Sent: Thursday, February 17, 2011 8:12 AM To: Cunanan, Arthur Cc: Dias, Antonio

Subject:

RE: Clarification Questions regarding the Response to RAI 3.1.2.3-01 in Columbia Letter Dated September 21, 2010 Good Morning, Arthur, As we discussed, attached are the clarification questions regarding Columbia responses to RAI 3.1.2.3-01.

As we talked, please, communicate with the applicant on this topic and let us know the applicants response.

If you have any question, please, let me know, too.

Thanks, Seung Min

Background:

In the response to RAI 3.1.2.3-01, by letter dated September 21, 2010, the applicant stated that:

However, the Columbia Risk Informed ISI Program does include volumetric examination of selected small-bore locations (3MS(9)-1, 3MS(9)-5, and 3MS(9)-7). As such, Columbia will add ISI to the aging management programs credited for management of SCC for these selected small bore components. See the amendment to the LRA provided in the enclosure to this letter.

In the amended LRA Table 3.1.2-3 (Amendment 11, Page 3.1-114b), the applicant also indicated, under Row Numbers 182 and 183, that the Inservice Inspection Program is credited to manage cracking due to flaw growth and cracking due to SCC, respectively, of CASS (cast austenitic stainless steel) valve bodies < 4 inches expose to reactor coolant.

The staff notes that ASME Section XI, Division 1, Appendix VIII, Supplement 9 (2001 edition with 2002 and 2003 addenda) indicates that the qualification requirements for ultrasonic examination of cast austenitic piping welds are in the course of preparation.

Clarification Questions:

1. In the ISI program, what is the method of the volumetric examination for the CASS valve bodies < 4 inches? (For example, ultrasonic testing or radiographic testing)

2. If ultrasonic testing (UT) is performed to inspect the CASS valves < 4 inches, briefly describe the qualification requirements that the applicant uses for the volumetric examination of the CASS valves.

From: Min, Seung Sent: Thursday, February 17, 2011 7:24 AM To: Dias, Antonio

Subject:

FW: Clarification Questions regarding the Response to RAI 3.1.2.3-01 in Columbia Letter Dated September 21, 2010 Good Morning. Dias, Recently, Columbia submitted its response to Small Bore Piping Program RAIs.

Related review identified a need for clarification questions regarding the AMR items under our review.

Dr. Trillo and I prepared for a few clarification questions related to the Columbia response to RAI 3.1.2.3-01.

These are not formal RAIs and based on the discussion with PM, we are planning to communicate with the applicant by emails.

I will also talk with you about these questions sometime today.

If you have any question or comment, please, let me know.

Thanks, Seung Min

Background:

In the response to RAI 3.1.2.3-01, by letter dated September 21, 2010, the applicant stated that:

However, the Columbia Risk Informed ISI Program does include volumetric examination of selected small-bore locations (3MS(9)-1, 3MS(9)-5, and 3MS(9)-7). As such, Columbia will add ISI to the aging management programs credited for management of SCC for these selected small bore components. See the amendment to the LRA provided in the enclosure to this letter.

In the amended LRA Table 3.1.2-3 (Amendment 11, Page 3.1-114b), the applicant also indicated, under Row Numbers 182 and 183, that the Inservice Inspection Program is credited to manage cracking due to flaw growth and cracking due to SCC, respectively, of CASS (cast austenitic stainless steel) valve bodies < 4 inches expose to reactor coolant.

The staff notes that ASME Section XI, Division 1, Appendix VIII, Supplement 9 (2001 edition with 2002 and 2003 addenda) indicates that the qualification requirements for ultrasonic examination of cast austenitic piping welds are in the course of preparation.

Clarification Questions:

3. In the ISI program, what is the method of the volumetric examination for the CASS valve bodies < 4 inches? (For example, ultrasonic testing or radiographic testing)

4. If ultrasonic testing (UT) is performed to inspect the CASS valves < 4 inches, briefly describe the qualification requirements that the applicant uses for the volumetric examination of the CASS valves.

From: Elizabeth Trillo [2]

Sent: Wednesday, February 16, 2011 6:38 PM To: Min, Seung Cc: Todd Mintz

Subject:

RE: Clarification Questions regarding the Response to RAI 3.1.2.3-01 in Columbia Letter Dated September 21, 2010

Seung, I agree. The question is regarding ultrasonic or radiograph.

Regards, Elizabeth Trillo Senior Research Engineer Environmental Performance of Materials Southwest Research Institute 6220 Culebra Road San Antonio, TX 78238 Tel: 210-522-4210 Fax: 210-522-5122 From: Min, Seung [3]

Sent: Wednesday, February 16, 2011 1:13 PM To: 'Elizabeth Trillo' Cc: Todd Mintz

Subject:

RE: Clarification Questions regarding the Response to RAI 3.1.2.3-01 in Columbia Letter Dated September 21, 2010 Hello, Elizabeth, Did you have a chance to review the clarification questions?

Thanks, Seung Min From: Min, Seung Sent: Tuesday, February 15, 2011 5:21 PM To: 'Elizabeth Trillo' Cc: Todd Mintz

Subject:

Clarification Questions regarding the Response to RAI 3.1.2.3-01 in Columbia Letter Dated September 21, 2010 Elizabeth, As we discussed, here are the draft clarification questions.

Please, review the attached questions and let me know your comments.

Thanks, Seung Min

Background:

In the response to RAI 3.1.2.3-01, by letter dated September 21, 2010, the applicant stated that:

However, the Columbia Risk Informed ISI Program does include volumetric examination of selected small-bore locations (3MS(9)-1, 3MS(9)-5, and 3MS(9)-7). As such, Columbia will add ISI to the aging management programs credited for management of SCC for these selected small bore components. See the amendment to the LRA provided in the enclosure to this letter.

In the amended LRA Table 3.1.2-3 (Amendment 11, Page 3.1-114b), the applicant also indicated, under Row Numbers 182 and 183, that the Inservice Inspection Program is credited to manage cracking due to flaw growth and cracking due to SCC, respectively, of CASS (cast austenitic stainless steel) valve bodies < 4 inches expose to reactor coolant.

The staff notes that ASME Section XI, Division 1, Appendix VIII, Supplement 9 (2001 edition with 2002 and 2003 addenda) indicates that the qualification requirements for ultrasonic examination of cast austenitic piping welds are in the course of preparation.

Clarification Questions:

5. In the ISI program, what is the method of the volumetric examination for the CASS valve bodies < 4 inches? (For example, ultrasonic testing or radiographic testing)

6. If ultrasonic testing (UT) is performed to inspect the CASS valves < 4 inches, briefly describe the qualification requirements that the applicant uses for the volumetric examination of the CASS valves.