ML20155G607

Forwards Response to Request for Addl Info on Inservice Insp Program for Second 10-yr Interval (Topical Rept PGE-1049). Rev to Rept Scheduled for Submittal by 881130

ML20155G607
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/07/1988
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-63974, NUDOCS 8810170246
Download: ML20155G607 (4)

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-- ammumm PortlandGeneralLloctricCompany

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r David W. Cockfield Vice President, Nuclear I l

October 7, 1988 Trojan Nuclear Plant Dockot 50-344 License NPF-1 U.S. Nuclear Regulatory Commission 1 ATTH: Docutt.ont Control Desk Washington DC 205S5

Dear Sir:

Request for Additional Information - Inservice Inspection Program

_ Second Ten-Year Interval. Trojan Nuclear Plant (TAC No. 63974) l By letter dated August 15, 1988, the Nuclear Regulatory Cornmission (NRC) l requested additional information from Portland General Electric Company l (PGE) to aid in evaluating PCE's Inservico Inspection (ISI) Program for the i

Second 10-Year Interval (PCE Topical Report PGE-1049). The requested l Information is attached.

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An extensive revision to PCE-1049 has been initiated. The responson to the NRC's requests refer extensively to the information in the proposed revision. Submittal of the revislan to the NRC is scheduled for November 30, 1988.

Sincerely.

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tttachment c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T. Dixon Stato of Oregon DepartN nt of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant 8810170246 881007 PDR G

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s Trojan Nuclear Plant Document Control !1sk Docket 50-344 Attachment License NPF-1 October 7, 1988 Page 1 of 3 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION ON SECOND 10-YEAR INSERVICE INSPECTION PROGRAM

1. NRC Request;

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Paragraph 10 CFR 50.55a(b)(2)(iv) requires that ASME Codo Class 2 piping wolds in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems shall be examined. These systems should not be completely exempted from inservico volumotric examination based on Section XI exclusion criteria contained in iWC-1220. 7 Based on the 74S75 Section XI exclusion criteria contained in IWC-1220(a), the Trojan Nuclear Plant Second 10-Year Interval ISI i program, Section 4.2.1 exempts components in the RHR, ECC, and CHR systems (i.e. , Safoty Injection System, Chemical and Volume control System) from inservice examinations when both the design pressure and temperature are eqval to or less than 275 psig and 200'F, respectively. To satisfy the inspection requirements of General Design Criteria 36, 39, 42, and 45, the inservice inspection program must include volumetrie examination of a representative sample of welds in the RHR, ECC, and CHR systems. The staff points out that later editions and addenda of the Code do not permit the temperature / pressure exclusion for these systems. Verify that the ,

[ temperature /prossure exclusion will not be used and that the ISI Program Plan will be revised to include examinations for these systems, as applicable.

Item (4) on Pago 31 of the ISI Program Plan exempts all Class 2 piping in the containment Spray System based on the 74375 Section XI exclusion critoria contained in IWC-1220(b). The staff has previously determined that a 7.5*. augmented volumetric samplo constitutes an acceptablo resolution at similar plants. Verify that .

l volumetric examination will be performed on at least a 7.5% sample of the Class 2 piping wolds in the Containment Spray System.

1 PCE Responso:

Section 6 of Revision 1 to the second 10-Year ISI Program, identifies welds selected for examination. Trojan has elected to examine a representative sample of wolds in the RHR, ECC, and CHR systems. .

About 21 percent of the subject wolds will be examined during the I' next 10-year interval.

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O Trojan Nuclear Plant Document Control Deck

. Docket 50-344 Attachment Licenso NPF-1 October 7, 1988 Page 2 of 3

2. NRC Request:

Provide the staff with the Boundary Diagrams which define the ASME Code Class 1, Class 2, and class 3 boundaries for the systems in the Trojan Nucicar Plant Second 10-Year Interval ISI Program Plan.

PCE Response:

Revision 1 of the second 10-year ISI Program will contain a set of boundary drawings. Theso drawings are identical to those in the applicable section of the Finst Safety Analysis Report (FSAR) for each system.

3. NRC Request:

Provido the staff with an itemized listing of the components subject to examinat*on during tho second 10-year interval. The requested listing will permit the staff to determine if the extent of ISI examinations meets the applicable Code requirements.

PCE Response:

Section 9 of Revision 1 of the second 10-year ISI Program will contain an itemized listing of components subject to inspection.

4. NRC Request:

Provido isometric and/or component drawings showing the wolds, components, and supports which Section XI of the ASME Code requires be examined.

PCE_ Response:

The administration of the ISI Program is performed by means of a computerized data baso. This program also provides isometric drawings. The subject isometries are currently being revised and prograrned into this data base for use during the 1989 outage. The isometrics will bo provided with the November 30, 1988 submittal of Revision 1 of the second 10-year ISI Program.

5. NRC Request:

Provido a list of the ultrasonic calibration standards being used during the second 10-year interval ISI at Trojan Nuclear Plant. This list should include the calibration standard identifications, material specifications, and sizes.

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Trojan Nuc1 car Plant Documen Control Desk

. Docket 50-344 Attachmert

. License NPF-1 October 7, 1988 Pago 3 of 3 PGE Response:

Section 13 of Revision 1 of the second 10-Year ISI Program will ,

contain a listing of nondestructivo examination calibration standards l

. currently availablo at Trojan.

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6. NRC Requests Relief Request No. 3.3.2 With regard to the bottom head nozzle  :

inner radius sections on the steam generators, relief is requested  !

from performing the code-required volumetric examination because of  ;

the as-east condition of the outer surface and the clad inner surface  ;

of the bottom head. If relief from examining the nozzio inner radius sections is to be considered, sufficient technical justification must  :

be provided. What attempts havn been made to obtain construction

!, drawings, to select transducers, and to perform the Codo-required I i volumotric examination of the nozzle inner radius sections? If the full Code-required volumetric examination cannot be completed, I

describe a "best-effort" volumetric examination that could be '

performed.

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PGE Response:  ;

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Relief Request No. 3.3.2, has been revised and will be resubmitt ed in Section 10 of Revision 1 of the second 10-Year ISI Program. '

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7. NRC Request: i 4 Relief Roquest No. 4.3.6 Discuss what efforts have been made to  !

l perform the Codo-required volumetric examination of the east I j resonerativo heat exchanger circumferential shell welds. Has a  ;

j refracted longitudinal wavo ultrasonic examination been attempted? I

! PCE Response: t l

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J Relief Request No. 4.3.6 has been revised and will be resubmitted in I i

l Section 10 of Revision 1 of the 10-year ISI Program. The revised d

relief request identifies the excessive personnel exposure potential  !

and ultrasonic limitations experienced which preclude any meaningful j i results. It is concluded that code requirements are impractical, and j l alternativo examination techniques to achieve creditable results on l welds of this nature have not yet been developed.  !

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i 3 TDW/SAB/TRR/me/2577W(03).1088 l