ML082261495

Notification of Inspection (IR 05000445-08-005), and Request for Information

ML082261495
Person / Time
Site:	Comanche Peak
Issue date:	08/13/2008
From:	Russ Bywater Region 4 Engineering Branch 1
To:	Blevins M Luminant Generation Co
References
IR-08-005
Download: ML082261495 (12)

See also: IR 05000445/2008005

Text

UNITE D S TATES

NUC LEAR RE GULATOR Y C OMMIS SI ON

R EG I O N I V

612 EAST LAMAR BLVD , SU ITE 400

AR L IN GTON , TEXAS 7 6 011 - 4125

August 13, 2008

Mike Blevins, Executive Vice President

and Chief Nuclear Officer

Luminant Generation Company LLC

ATTN: Regulatory Affairs

Comanche Peak Steam Electric Station

P.O. Box 1002

Glen Rose, TX 76043

SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION, UNIT 1- NOTIFICATION OF

INSPECTION (NRC INSPECTION REPORT 05000445/2008005) AND

REQUEST FOR INFORMATION

Dear Mr. Blevins:

From September 29 to October 10, 2008, reactor inspectors from the Nuclear Regulatory

Commissions (NRC) Region IV office will perform the baseline inservice inspection at

Comanche Peak Steam Electric Station Unit 1, using NRC Inspection Procedure 71111.08 and

Temporary Instruction 2515/172, "Reactor Coolant System Dissimilar Metal Butt Welds."

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 (Section A of

the enclosure) identified 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. Bob Kidwell 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).

Luminant Generation Company, LLC -2-

In accordance with 10 CFR 2.390 of the NRCs 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 NRCs 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/

Russell L. Bywater, Chief

Engineering Branch 1

Division of Reactor Safety

Dockets: 50-445

Licenses: NPF-87

Enclosure: Request for Information

cc:w/enclosure

Mr. Fred W. Madden, Director

Regulatory Affairs

Luminant Generation Company LLC

P.O. Box 1002

Glen Rose, TX 76043

Timothy P. Matthews, Esq.

Morgan Lewis

1111 Pennsylvania Avenue, NW

Washington, DC 20004

County Judge

P.O. Box 851

Glen Rose, TX 76043

Mr. Richard A. Ratliff, Chief

Bureau of Radiation Control

Texas Department of Health

1100 West 49th Street

Austin, TX 78756-3189

Environmental and Natural

Resources Policy Director

Office of the Governor

P.O. Box 12428

Austin, TX 78711-3189

Luminant Generation Company, LLC -3-

Mr. Brian Almon

Public Utility Commission

William B. Travis Building

P.O. Box 13326

1701 North Congress Avenue

Austin, TX 78701-3326

Ms. Susan M. Jablonski

Office of Permitting, Remediation

and Registration

Texas Commission on

Environmental Quality

MC-122

P.O. Box 13087

Austin, TX 78711-3087

Anthony 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

Luminant Generation Company, LLC -4-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov )

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.gov )

DRS Director (Roy.Caniano@nrc.gov )

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (John.Kramer@nrc.gov)

Resident Inspector (Brian.Tindell@nrc.gov )

Branch Chief, DRP/A (Claude.Johnson@nrc.gov

Senior Project Engineer, DRP/A (Thomas.Farnholtz@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov )

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov )

RITS Coordinator (Marisa.Herrera@nrc.gov )

DRS STA (Dale.Powers@nrc.gov)

Mark Cox, OEDO RIV Coordinator (Mark.Cox@nrc.gov )

ROPreports

CP Site Secretary (Sue.Sanner@nrc.gov )

SUNSI Review Completed: ________ ADAMS: Yes No Initials: ______

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

S:DRS:/REPORTS/CP Request Info ltr.KDC ML

EB1 EB1 C:EB1

KDClatyon MRBloodgood RLBywater

/RA/ /RA/ /RA/

8/11/08 8/11/08 8/13/08

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

INSERVICE INSPECTION DOCUMENT REQUEST

Inspection Dates: September 29, 2008 - October 10, 2008

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

TI 2515/172 "Reactor Coolant System Dissimilar Metal Butt Welds"

Inspectors: K. Clayton, Senior Reactor Inspector (Lead Inspector - ISI)

M. Bloodgood, Reactor Inspector

A. Information Requested for the In-Office Preparation Week

The following information (Section A of this enclosure) should be sent to the Region IV

office in hard copy or electronic format (ims.certrec.com preferred), in care of K. Clayton,

by September 22, 2008, to facilitate the selection of specific items that will be reviewed

during the onsite inspection week. The inspector 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 day

indicated in this request. *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 (NDEs) planned for Class 1 & 2 systems

and containment, performed as part of your ASME Section XI, Risk

Informed (if applicable), and augmented ISI programs during the

upcoming outage.

Provide a status summary of the NDE 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 (RPVH) 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.)

-1- Enclosure

v) Welding activities that are scheduled to be completed during the

upcoming outage (ASME Class 1, 2, or 3 structures, systems, or

components (SSCs))

b) A copy of ASME Section XI Code Relief Requests and associated NRC Safety

Evaluations applicable to the examinations identified above.

c) A list of NDE reports (ultrasonic, radiography, magnetic particle, dye penetrate,

Visual VT-1, VT-2, and VT-3), which have identified relevant conditions on Code

Class 1 & 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 NDE reports with relevant conditions in the RPVH penetration nozzles

which have been accepted for continued service. The list of NDE reports should

include a brief description of the SSC where the relevant condition was identified.

d) A list with a brief description (e.g., system, material, pipe size, weld number, and

NDE 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) Copy of any 10 CFR Part 21 reports applicable to your SSCs within the scope of

Section XI of the ASME Code that have been identified since the beginning of the

last refueling outage.

g) A list of any temporary non-code repairs in service (e.g., pinhole leaks).

h) Please provide copies of the most recent self assessments for the ISI, Welding,

and Alloy 600 Programs.

A.2 Reactor Pressure Vessel Head (RPVH)

a) Provide the detailed scope of the planned NDE of the reactor vessel head which

identifies the types of NDE 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 planned expansion sample sizes if relevant conditions are identified. (If

applicable)

b) A list of the standards and/or requirements that will be used to evaluate

indications identified during NDE 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).

-2- Enclosure

A.3 Boric Acid Corrosion Control Program (BACCP)

a) Copy of the 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

BACCP.

c) Please provide a copy of the most recent self-assessment performed for the

BACCP.

A.4 Steam Generator Tube (SGT) Inspections

a) A detailed schedule of:

i) SGT inspection, data analyses, and repair activities for the upcoming

outage. (If occurring)

ii) SG secondary side inspection activities for the upcoming outage. (If

occurring)

b) Please provide a copy of your SG ISI 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 TSTF-449, please provide copies of your correspondence with

the NRC regarding deviations from the STS.

d) Copy of SG history documentation given to vendors performing eddy current (ET)

testing of the SGs during the upcoming outage.

e) Copy of SG Eddy Current Data Analyst Guidelines and Site Validated Eddy

Current Technique Specification Sheets (ETSS). Additionally, please provide a

copy of EPRI Appendix H ETSS Qualification Records.

f) Identify and quantify any SGT leakage experienced during the previous operating

cycle. Also provide documentation identifying which SG was leaking and

corrective actions completed or planned for this condition (If applicable).

-3- Enclosure

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 SG

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 SGT 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 Materials Reliability (MRP-139) Program Activities (TI-172)

a) A list of, with verification, that the baseline inspections of all applicable Dissimilar

Metal Butt Welds (DMBWs) have been completed by December 31, 2007.

b) Verification that baseline inspection of hot leg and cold leg temperature DMBWs

have been included in the inspection program and that the schedules for the

baseline inspections are consistent with the baseline schedules in MRP-139.

c) A list and schedule (examination dates) of all DMBW examinations planned for

the upcoming refueling outage. If none are scheduled, then data from previous

examinations should be available for review.

d) A list and schedule for any welding to be performed on DMBWs in the upcoming

outage. If no welding will be performed then records of previous welding on

DMBWs and postweld NDE documentation should be available for review.

e) A list and schedule of any stress improvement (SI) activities planned for the

upcoming refueling outage. If none are scheduled then qualification reports for

any SIs previously performed should be available for review.

f) Documentation and description of how the baseline and inservice inspection

specifications in MRP-139 are satisfied at your facility.

-4- Enclosure

A.6 Additional information related to all ISI activities

a) A list with a brief description of ISI, BACCP, and SGT inspection related issues

(e.g., condition reports) entered into your corrective action program since the

beginning of the last refueling outage (for Unit 1). For example, a list based upon

data base searches using key words related to piping or SG tube degradation

such as: ISI, ASME Code,Section XI, NDE, cracks, wear, thinning, leakage, rust,

corrosion, boric acid, or errors in piping/SGT examinations.

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

ISI contacts (Examination, planning)

Containment Exams

RPVH Exams

Snubbers and Supports

Repair and Replacement Program Manager

Licensing Contact

Site Welding Engineer

Boric Acid Corrosion Control Program

SG Inspection Activities (site lead and vendor contact)

B. Information to be provided onsite to the inspector(s) at the entrance meeting

(September 29, 2008):

B.1 ISI / Welding Programs and Schedule Information

a) Updated schedules for ISI/NDE activities, including SGT 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 (WPS) used to fabricate the welds

vi) Copies of procedure qualification records (PQRs) supporting the WPS

from B.1.b.v

vii) Copies of mechanical test reports identified in the PQRs 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 RT was performed)

-5- Enclosure

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 WPS (at

least six months prior to the date of subject work)

xii) Copies of NDE personnel qualifications (VT, PT, UT, RT), as applicable

c) For the ISI related corrective action issues selected by the inspector(s) from

section A of this enclosure, provide a copy of the corrective actions and

supporting documentation.

d) For the NDE reports with relevant conditions on Code Class 1 & 2 systems

selected by the inspector 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 ISI Program Manual

and Plan for the current Interval.

f) For the NDEs selected by the inspector from section A of this enclosure, provide

copy of the NDE 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 NDE

personnel qualification records.

B.2 Reactor Pressure Vessel Head (RPVH)

a) Provide the NDE personnel qualification records for the examiners who will

perform examinations of the RPVH.

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

the upcoming refueling outage)

i) RPVH and CRDM nozzle configurations

ii) RPVH insulation configuration

The drawings listed above should include fabrication drawings for the nozzle attachment

welds as applicable.

c) Copy of NDE reports from the last RPVH examination.

d) Copy of evaluation or calculation demonstrating that the scope of the visual

examination of the upper head will meet the 95% minimum coverage required by

-6- Enclosure

NRC Order EA-03-009 (If a visual examination is planned for the upcoming

refueling outage).

e) Provide a copy of the procedures that will be used to identify the source of any

boric acid deposits identified on the RPVH. 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 (EDY)

for the RPVH susceptibility ranking.

g) Provide copy of the vendor qualification report(s) that demonstrates the detection

capability of the NDE equipment used for the RPVH examinations. Also, identify

any changes in equipment configurations used for the RPVH examinations which

differ from that used in the vendor qualification report(s).

B.3 Boric Acid Corrosion Control Program (BACCP)

a) Please 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) Please 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 (SGT) Inspections

a) Copies of the Examination Technique Specification Sheets (ETSS) and

associated justification for any revisions.

b) Copy of the guidance to be followed if a loose part or foreign material is identified

in the SGs.

c) Please provide a copy of the ET procedures used to perform the SGT

inspections (specifically calibration and flaw characterization/sizing procedures,

etc.). Also include documentation for the specific equipment to be used.

d) Please provide copies of your responses to NRC and industry operating

experience communications such as Generic Letters, Information Notices, etc.

(as applicable to SGT inspections) *Do not provide these documents separately if

already included in other information requested such as the degradation

assessment.

e) List of corrective action documents generated by the vendor and/or site with

respect to SG inspection activities.

-7- Enclosure

B.5 Codes and Standards

a) 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 SGT eddy current examination.

Inspector Contact Information:

Kelly Clayton

Senior Reactor Inspector

817-860-8216

Kelly.Clayton@nrc.gov

Mailing Address:

US NRC Region IV

Attn: K. Clayton

612 E. Lamar Blvd., Suite 400

Arlington, TX 76011

-8- Enclosure