ML060820513

Donald C. Cook, Units 1 & 2, Relief Request ISIR-19 Regarding Class 1 and 2 Piping Weld Inspection Requirements

ML060820513
Person / Time
Site:	Cook
Issue date:	05/31/2006
From:	Raghavan L NRC/NRR/ADRO/DORL/LPLE
To:	Nazar M K Indiana Michigan Power Co
tam P S, NRR/ADRO/DORL, 415-1451
References
TAC MC8569, TAC MC8570
Download: ML060820513 (10)

Text

May 31, 2006Mr. Mano K. NazarSenior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 (DCCNP-1 ANDDCCNP-2) - RELIEF REQUEST ISIR-19 REGARDING CLASS 1 AND 2 PIPINGWELD INSPECTION REQUIREMENTS (TAC NOS. MC8569 AND MC8570)

Dear Mr. Nazar:

By letter dated September 22, 2005, as supplemented by letter dated December 28, 2005, Indiana Michigan Power Company submitted Relief Request ISIR-19 for DCCNP-1 andDCCNP-2. The relief request relates to certain examination requirements in the AmericanSociety of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, for Class 1 and 2 piping welds during the third 10-year inservice inspection (ISI) interval.The Nuclear Regulatory Commission (NRC) staff has completed its review of Relief RequestISIR-19. Details of the NRC staff's review are set forth in the enclosed safety evaluation.

Accordingly, the NRC staff concludes that your proposed alternative to delay the remainingsecond period Class 1 and Class 2 piping weld inspections while developing a risk-informed ISI program to implement during the third ISI period will provide an acceptable level of quality andsafety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative is authorized for the second period of the third 10-year ISI interval at DCCNP-1 and DCCNP-2. If you haveany questions, please call the Project Manager, Mr. Peter Tam at 301-415-1451.Sincerely,/RA by Fred Lyon for/L. Raghavan, Branch ChiefPlant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-315 and 50-316

Enclosure:

As statedcc w/encl: See next page

ML060820513OFFICENRR/LPL3-1/PMNRR/LPL3-1/LANRR/CNPB/BCOGCNRR/LPL3-1/BC(A)NAMEPTamTHarrisTChan*PMouldingLRaghavan(FLyon for)DATE3/30/063/29/063/21/065/26/065/31/06 ENCLOSURESAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONINSERVICE INSPECTION PROGRAM RELIEF REQUEST ISIR-19DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 (DCCNP-1 AND DCCNP-2)INDIANA MICHIGAN POWER COMPANYDOCKET NOS. 50-315 AND 50-31

61.0 INTRODUCTION

By letter dated September 22, 2005 (Agencywide Document Access and Management System(ADAMS) Accession No. ML052780450), as supplemented by letter dated December 28, 2005 (Accession No. ML060090295), Indiana Michigan Power Company (the licensee) submitted Relief Request ISIR-19 for the DCCNP-1 and DCCNP-2. The relief request relates to certainexamination requirements in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, for Class 1 and 2 piping welds during the third 10-year inservice inspection interval.

2.0REGULATORY EVALUATION

Inservice inspection (ISI) of the ASME Boiler and Pressure Vessel Code (Code) Class 1, 2, and3 components is to be performed in accordance with Section XI of the ASME Code (the applicable edition and addenda) as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). The provision of 10 CFR 50.55a(a)(3) states, in part, that alternatives to the requirements of paragraph (g)may be used, when authorized by the Nuclear Regulatory Commission (NRC), if the licenseedemonstrates that: (i) the proposed alternative would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (includingsupports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection (ISI) of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components.

The regulations require that inservice examination of com ponents and system pressure testsconducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ISI Code of record for the third 10-year ISI interval for DCCNP-1 and DCCNP-2 is the 1989 Edition with no Addenda of the ASME Code,Section XI. The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in10 CFR 50.55a(b), subject to the limitations and modifications listed therein and subject to NRC approval.

3.0TECHNICAL EVALUATION

3.1Components for Which Relief is RequestedThe licensee's request for relief is applicable to ASME Section XI, Class 1 and 2 piping welds, specifically, Category B-F, B-J, C-F-1 and C-F-2 piping welds scheduled to be inspected during the second period of the third 10-year ISI interval.3.2Code RequirementsThe 1989 Edition of the ASME Code,Section XI, requires that a minimum percentage ofexaminations in each category of welds be completed during each successive inspection period and inspection interval in accordance with Tables IWB-2412-1 and IWC-2412-1. For the second period of the third inspection interval, the minimum examination requirement is 50 percent.3.3Relief RequestedIn accordance with 10 CFR 50.55a(a)(3)(i), the licensee requested relief from the Table IWB-2412-1 and Table IWC-2412-1 requirements for meeting the minimum examination percentages associated with ASME Code Categories B-F, B-J, C-F-1, and C-F-2 piping welds during the second inspection period of the third 10-year ISI interval.3.4Licensee's Proposed AlternativeThe licensee is currently developing a risk-informed ISI (RI-ISI) program in accordance withcode case N-716, "Alternative Piping Classification and Examination Requirements Based Upon Risk-Informed and Safety-Based Insights." This RI-ISI program is expected to result in a substantial reduction in the required number of piping weld examinations. The RI-ISI program will be developed and submitted by July 31, 2006. Upon approval of the RI-ISI programsubmittal, the examinations required by the RI-ISI program will be scheduled to occur over theremainder of the outages in the third 10-year inspection interval such that 66 percent of the High Safety Significant RI-ISI population requiring examination will be examined by the end ofthe third 10-year inspection interval.Licensee commitments made under NRC Bulletin 2004-01, "Inspection of Alloy 82/182/600Materials Used in the Fabrication of Pressurizer Penetration and Steam Space Piping Connections at Pressurized-Water Reactors" are not impacted by this request.3.5Licensee's BasisInformation Notice 98-44, "Ten-Year Inservice Inspection (ISI) Program Update for Licenseesthat intend to Implement Risk-Informed ISI of Piping," indicates that the NRC will considerauthorizing a delay of up to 2 years in the implementation of a 10-year ISI program, for piping only, to allow licensees to develop and obtain approval for a RI-ISI program using NRC-approved topical reports. DCCNP-1 and DCCNP-2 are currently in the second inspection period of the third 10-year ISIinterval. The second inspection period ends January 31, 2007, for DCCNP-1 and September 30, 2006, for DCCNP-2. The third inspection interval for both units ends February 28, 2010. Only one refueling outage remains for each unit to complete the second period examination requirements. To meet the second period examination requirements ofTables IWB-2412-1 and IWC-2412-1 for piping welds would require a significant number of examinations to be performed that may not be necessary based on a RI-ISI program. Table 1Unit 1 Weld Examination SummaryASME CategoryASMEItem NumberTotal number ofexaminations to beperformed during thethird inspectionintervalExaminationPercentageCompletedB-FB5.10 1 80B-FB5.40633 B-FB5.70825B-JB9.119831B-JB9.12450 B-JB9.215939 B-JB9.31333 B-JB9.32757 B-JB9.4012832C-F-1C5.113053C-F-1C5.213023 C-F-1C5.30520C-F-2C5.513327 1 For ASME Item Number B5.10 - the reactor vessel nozzle safe end examinations may be performed coincidentwith the vessel nozzle examinations required by Examination Category B-D.Table 2 Unit 2 Weld Examination SummaryASME CategoryASME Item NumberTotal number ofexaminations to beperformed during thethird inspectionintervalExaminationPercentageCompletedB-FB5.10 1 80B-FB5.40634 B-FB5.70825B-JB9.1110033B-JB9.12850 B-JB9.216832 B-JB9.31333 B-JB9.32757 B-JB9.4012242C-F-1C5.112580 2C-F-1C5.2110C-F-1C5.213135 C-F-1C5.30540C-F-2C5.513135 1 For ASME Item Number B5.10 - the reactor vessel nozzle safe end examinations may beperformed coincident with the vessel nozzle examinations required by Examination Category B-D.2In accordance with Table IWC-2412-1, Inspection Program B, the maximum examinations thatcan be credited for the second period is 67 percent. 3.6NRC Staff EvaluationThe NRC staff has reviewed the information concerning the ISI program request for relief andthe proposed alternative submitted by the licensee in letters referenced above for the second period of the third 10-year ISI program at DCCNP-1 and DCCNP-2. The Code requires that atleast 50 percent of the welds in each category be examined during the second period.

Approximately 70 welds for Unit 1 and 44 welds for Unit 2 would need to be examined during the remaining outage of the second period.NRC Information Notice (IN) 98-44, "Ten-Year Inservice Inspection (ISI) Program Update forLicensees that Intend to Implement Risk-Informed ISI of Piping," states that for licensees whointend to implement a RI-ISI program for piping and following the guidance provided in IN 98-44, the NRC staff will consider authorizing a delay of up to 2 years in implementation of the ISI program for piping only. The second period for DCCNP-1 will end January 31, 2007, andDCCNP-2 will end its second period on September 30, 2006. The third 10-year ISI interval forboth units will end on February 28, 2007. The licensee intends to use the methodology in CodeCase N-716 for both units' RI-ISI program. However, the NRC staff has not yet approved CodeCase N-716. The Grand Gulf Nuclear Station is scheduled as the pilot plant for a RI-ISI program using Code Case N-716, and the NRC staff will make its determination regarding N-716 following its review of Grand Gulf's application to use the methodology. The Cook licensee committed in its December 28, 2005, letter to submit its RI-ISI program for NRC approval by July 31, 2006. Typically, RI-ISI programs result in a significant reduction in the required number of piping weldexaminations. Although the licensee will be performing examinations on fewer locations, thelocations selected will be based on knowledge of potential degradation mechanisms and theuse of effective examination requirements for the potential degradation mechanism at locationsthat have been determined to be highly safety significant. Examination of the reduced number of Class 1 and Class 2 piping welds would be performed over the outages in the third period of the third 10-year inspection interval, such that a minimum of 66 percent of the RI-ISI examinations would be completed. The licensee's proposed RI-ISI program will be reviewed bythe NRC and will require NRC approval prior to implementation. If the NRC staff does notapprove the DCCNP-1 and DCCNP-2 RI-ISI program by 6 months prior to the first outage of thethird period, the licensee will be required to complete the remaining ASME Code-required pipingexaminations during the third period at each unit.The goal of piping ISI is to detect precursors to possible future piping failure. By examiningcertain piping welds once every ten years, the licensee is monitoring to determine whether any degradation is occurring. Based on the number of required examinations performed during the current interval, the NRC staff believes that any significant active degradation would have beendetected. Furthermore, the NRC staff believes a two-year delay of the requested percentage ofpipe examinations would not provide sufficient time for specific degradation mechanisms to progress to failure. Therefore, the NRC staff concludes that the licensee's proposed alternativeprovides an acceptable level of quality and safety.

4.0CONCLUSION

Based on the above evaluation, the NRC staff concludes that the licensee's proposedalternative to delay the remaining second period Class 1 and Class 2 piping weld inspections while developing a RI-ISI program to implement during the third period will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative is authorized* for the second period of the third 10-year ISI interval at DCCNP-1 and DCCNP-2. All other ASME Code Section XI requirements for which relief wasnot specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.Principal Contributor: A. Keim Date: May 31, 2006-------------------------------- *This authorization was verbally conveyed to the licensee on March 23, 2006, per the guidance in Office of NuclearReactor Regulation Office Instruction LIC-102, Rev. 1, "Relief Request" and documented in an e-mail, P. Tam to the licensee, dated March 23, 2006 (ADAMS Accession No. ML060820421).

Donald C. Cook Nuclear Plant, Units 1 and 2 cc:Regional Administrator, Region IIIU.S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210Lisle, IL 60532-4352Attorney GeneralDepartment of Attorney General 525 West Ottawa Street Lansing, MI 48913Township SupervisorLake Township Hall

P.O. Box 818 Bridgman, MI 49106U.S. Nuclear Regulatory CommissionResident Inspector's Office 7700 Red Arrow Highway Stevensville, MI 49127James M. Petro, Jr., EsquireIndiana Michigan Power Company One Cook Place Bridgman, MI 49106Mayor, City of Bridgman P.O. Box 366 Bridgman, MI 49106Special Assistant to the GovernorRoom 1 - State Capitol Lansing, MI 48909Mr. John A. ZwolinskiSafety Assurance Director Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106Michigan Department of Environmental Quality Waste and Hazardous Materials Div.

Hazardous Waste & Radiological Protection Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P. O. Box 30241 Lansing, MI 48909-7741Lawrence J. Weber, Plant ManagerIndiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106Mr. Joseph N. Jensen, Site Vice President Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106