Letter Sequence Other |
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MONTHYEARML0232204442003-01-0202 January 2003
Environmental Assessment & Finding of No Significant Impact Related to License Amendment Request to Change Appendix B
Project stage: Other
ML0302201332003-01-21021 January 2003
Technical Specifications, Revision to Appendix B
Project stage: Other
ML0228103322003-01-21021 January 2003
Issuance of Amendments Revision to Appendix B Environmental Protection Plan (Non-Radiological).
Project stage: Approval
ML0302204032003-01-29029 January 2003
Memo to File, Code Interpretation
Project stage: Other
2003-01-21
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Category:Memoranda
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K. Hsueh Memo Site Visit Summary Regarding the Prairie Island ISFSI License Renewal
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CFR 50 Appendix E Evacuation Time Estimate Study
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Notice of Closed Pre-Application Meeting NSPM Staff to Discuss Proposed Physical Security Plan Changes That Will Be Submitted for NRC Review and Approval Via License Amendment Request
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Notice of Pre-Application Meeting with Licensee for Prairie Island Nuclear Generating Plant, Units 1 and 2 to Discuss Spent Fuel Pool Criticality and Extended Power Uprate
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Review of Revision 29 to the Updated Safety Analysis Report (Tac No. MD5651 and MD5652)
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Draft Regulatory Guide for Comment
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Memo Transmitting Prairie Island Nuclear Generating Plant: Report on Results of Staff Audit of Corrective Actions to Address Generic Letter 2004-02
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ML0421003322004-06-30030 June 2004
Close-out of Tacs Relating to the Review of 35-day Letters Submitted in Response to the April 29, 2003, Orders Revising the Design Basis and Security Guard Force Training Enhancements and Physical Fitness Requirements
2023-07-11
[Table view] |
Text
January 29, 2003 MEMORANDUM TO: File FROM: John G. Lamb, Project Manager, Section 1 /RA/
Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 - CODE INTERPRETATION (TAC NO. MB6836)
During the course of a Region III inspection at Prairie Island Nuclear Generating Plant (PINGP),
the Nuclear Regulatory Commission (NRC) staff determined that the licensee found weld indications during PINGP Unit 2 2002 Refueling Outage (RFO) on 22 steam generator (SG) head-to-tubesheet welds, and the scope was not expanded to 21 SG head-to-tubesheet welds.
The licensee performed an operability recommendation for 21 SG. During a conference call with the licensee to discuss the PINGP Unit 1 SG tube inspections, which was held on November 25, 2002, the NRC staff requested that the licensee submit an Operability Recommendation for 21 SGs. Gene Eckholdt of the Nuclear Management Company, LLC (the licensee), e-mailed me Operability Recommendation OPR000360 on December 2, 2002.
Region III staff held a conference call with the licensee on December 2, 2002, to discuss Operability Recommendation OPR000360. Based on questions from the Region III staff, the licensee revised its Operability Recommendation OPR000360. Shannon Hanson of the licensees staff e-mailed me Operability Recommendation OPR000360 Revision 1, on December 4, 2002. The licensee determined that 21 SG is operable, but nonconforming in accordance with Generic Letter 91-18.
A conference call was held between the NRC staff and the licensee on December 4, 2002, to discuss Operability Recommendation OPR000360 Revision 1. Attached is the list of attendees on the conference call. The NRC staff asked the licensee if it used Performance Demonstration Initiative (PDI) in its examination of the 22 SG head-to-tubesheet welds. The licensee stated it did not use PDI in its examination of the 22 SG head-to-tubesheet welds because it was not required by the American Society of Mechanical Engineers Code (Code).
The NRC asked questions regarding flaw characterization. The licensee stated that the 14 flaws discovered during the 2002 RFO were casting flaws in the base metal. The licensee also stated that all the ultrasonic thickness indications were acceptable by Code or fracture analysis in accordance with WCAP-14166. The licensee stated it would send in the analysis dispositioning the indications by the end of January 2003. The NRC staff asked if the licensee used the critical flaw methodology or a stress intensity factor; the licensee stated it would verify which methodology was used. In addition, the licensee stated it is seeking a Code interpretation, because it believes that when performing successive examinations, the expansion criteria does not apply. The NRC staff stated it would look into this matter further internally.
In the view of the Piping Integrity & Nondestructive Examination (NDE) Section of the Materials
& Chemical Engineering Branch (EMCB) of the Division of Engineering of the Office of Nuclear Reactor Regulation, the sample expansion and additional inspection requirements of IWB-2430(a) and (b) apply, even when conducting successive examinations per IWB-2420(b).
The purpose of the successive exams is to ensure that the assumptions made in the analysis, which allowed leaving a flaw in service, remain valid. However, if new flaws are found while conducting the successive exams, then those flaws must be appropriately dispositioned, because they may or may not be related to the original flaw left in service, and the provisions of IWB-2430(a) and (b) followed.
However, Code Case (CC) N-586 provides alternate requirements to IWB-2430(a), which based on the licensees determination that these "new" flaws were fabrication-related indications, may not have required additional exams. Although the NRC staff has not approved the use of CC-N-586 via Regulatory Guide 1.147, had the licensee proposed to use the CC, the NRC staff would likely have approved its use, with conditions.
EMCB notes that the draft task interface agreement does not indicate what the inspection results were for SG 12 and SG 21 for the 1998 and 2000 RFOs, respectively. However, if those exam results are "clean," then from a practical viewpoint, if CC-N586 was invoked, it is possible for the licensee to have determined that sample expansion or additional exams were not required.
Because the licensee called these flaws "new flaws, a technical noncompliance with implementation of the Code requirement occurred, but the safety significance is low. Had the licensee associated these "new" flaws as "old" flaws, but in a different (but justifiably similar) location based on new NDE methods or characterization uncertainties, or implemented CC-N-586, it is possible noncompliance could have been avoided. Regardless of how the Code dispositions the inquiry, NRC is not bound by the interpretation.
Region III submitted a request for technical assistance using Task Interface Agreement (TIA) 2003-01 for the application of ASME Code Section XI, IWB-2430 requirements associated with scope of volumetric weld expansion at PINGP. Region III submitted TIA 2003-01 by letter dated January 17, 2003. The NRC staff will respond to the code interpretation via TIA 2003-01.
Docket No. 50-306
Attachment:
List of Attendees for December 4, 2002, Conference Call
ML030220403 *Previously Concurred OFFICE PDIII-1/PM PDIII-1/LA EMCB/SC* PDIII-1/SC NAME JLamb RBouling TChan LRaghavan DATE 01/28/03 01/28/03 01/03/03 01/29/03 LIST OF ATTENDEES FOR CONFERENCE CALL HELD DECEMBER 4, 2002 NAME ORGANIZATION John G. Lamb NRC L. Raghavan NRC Pat Patniak NRC Raul Hernandez NRC Mel Holmberg NRC Randy Womack NMC Gene Eckholdt NMC Shannon Hanson NMC Jerry Wren NMC Jack Leveille NMC ATTACHMENT
