ML042040394

Request for Relief 03-004, Minimum Percentage Requirements for Second Period of the Second Inservice Inspection Interval

ML042040394
Person / Time
Site:	Catawba
Issue date:	07/20/2004
From:	Stephanie Coffin NRC/NRR/DLPM/LPD2
To:	Jamil D Duke Energy Corp
Peters S, NRR/DLPM, 415-1842
References
TAC MC0272
Download: ML042040394 (9)

Text

July 20, 2004 Mr. D. M. Jamil Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, South Carolina 29745

SUBJECT:

CATAWBA NUCLEAR STATION, UNIT 2 RE: REQUEST FOR RELIEF 03-004, RELIEF FROM MINIMUM PERCENTAGE REQUIREMENTS FOR SECOND PERIOD OF THE SECOND INSERVICE INSPECTION INTERVAL (TAC NO. MC0272)

Dear Mr. Jamil:

By letter dated August 8, 2003, Duke Energy Corporation, the licensee for Catawba Nuclear Station (Catawba), Unit 2, submitted a request for relief, Relief Request No.03-004, from the requirements of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, 1989 Edition with no addenda, Table IWB-2412-1, Unit 2. Specifically, the licensee requested relief associated with minimum percentage requirements for Inservice Inspection (ISI) Category B-F, Pressure Retaining Dissimilar Metal Weld, for the Second ISI Period which concluded on August 19, 2003, of the Second ISI Interval which will conclude on August 19, 2006.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided for this relief request. The enclosed Safety Evaluation contains the NRC staffs evaluation and conclusions. Based on the information provided in the relief request, the NRC staff concludes that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the proposed alternative is authorized pursuant to Title 10 of the Code of Federal Regulations Section 50.55a(a)(3)(ii) for the Second ISI Interval at Catawba, Unit 2.

Sincerely,

/RA/

Stephanie M. Coffin, Acting Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-414

Enclosure:

As stated cc w/encl: See next page

Mr. D. M. Jamil Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, South Carolina 29745

SUBJECT:

CATAWBA NUCLEAR STATION, UNIT 2 RE: REQUEST FOR RELIEF 03-004, RELIEF FROM MINIMUM PERCENTAGE REQUIREMENTS FOR SECOND PERIOD OF THE SECOND INSERVICE INSPECTION INTERVAL (TAC NO. MC0272)

Dear Mr. Jamil:

By letter dated August 8, 2003, Duke Energy Corporation, the licensee for Catawba Nuclear Station (Catawba), Unit 2, submitted a request for relief, Relief Request No.03-004, from the requirements of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, 1989 Edition with no addenda, Table IWB-2412-1, Unit 2. Specifically, the licensee requested relief associated with minimum percentage requirements for Inservice Inspection (ISI) Category B-F, Pressure Retaining Dissimilar Metal Weld, for the Second ISI Period which concluded on August 19, 2003, of the Second ISI Interval which will conclude on August 19, 2006.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided for this relief request. The enclosed Safety Evaluation contains the NRC staffs evaluation and conclusions. Based on the information provided in the relief request, the NRC staff concludes that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the proposed alternative is authorized pursuant to Title 10 of the Code of Federal Regulations Section 50.55a(a)(3)(ii) for the Second ISI Interval at Catawba, Unit 2.

Sincerely,

/RA/

Stephanie M. Coffin, Acting Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-414

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION: See next page ADAMS Acession No: ML042040394 *No Major Changes to SE NRR-028 OFFICE PDII-1/GE PDII-1/PM PDII-1/LA (A) EMCB/SC* OGC PDII-1/SC (A)

NAME ZCruz SPeters DClarke TLChan AFernandez SCoffin DATE 06/17/04 06/16/04 06/30/04 05/17/04 07/12/04 7/20/04 OFFICIAL AGENCY RECORD

DISTRIBUTION FOR CATAWBA NUCLEAR STATION, UNIT 2 RE: REQUEST FOR RELIEF 03-004, RELIEF FROM MINIMUM PERCENTAGE REQUIREMENTS FOR SECOND PERIOD OF THE SECOND INSERVICE INSPECTION INTERVAL (TAC NO. MC0272)

DISTRIBUTION:

PUBLIC PDII-1 R/F RidsNrrDlpmLpdii (EHackett)

RidsNrrDlpmLpdii-1 (SCoffin)

DClarke RidsNrrPMSPeters RidsOgcRp GHill (2 Copies)

RidsAcrsAcnwMailCenter RidsRgn2MailCenter (VMcCree)

RidsNrrDlpmDpr TJKim ZCruz-Perez

Catawba Nuclear Station cc:

Lee Keller, Manager North Carolina Electric Membership Corp.

Regulatory Compliance P.O. Box 27306 Duke Energy Corporation Raleigh, North Carolina 27611 4800 Concord Road York, South Carolina 29745 Senior Resident Inspector U.S. Nuclear Regulatory Commission Lisa F. Vaughn 4830 Concord Road Duke Energy Corporation York, South Carolina 29745 Mail Code - PB05E 422 South Church Street Henry Porter, Assistant Director P.O. Box 1244 Division of Waste Management Charlotte, North Carolina 28201-1244 Bureau of Land and Waste Management Dept. of Health and Environmental Control Anne Cottingham, Esquire 2600 Bull Street Winston and Strawn Columbia, South Carolina 29201-1708 1400 L Street, NW Washington, DC 20005 Mr. R.L. Gill, Jr., Manager Nuclear Regulatory Issues North Carolina Municipal Power and Industry Affairs Agency Number 1 Duke Energy Corporation 1427 Meadowwood Boulevard 526 South Church Street P.O. Box 29513 Mail Stop EC05P Raleigh, North Carolina 27626 Charlotte, North Carolina 28202 County Manager of York County Saluda River Electric York County Courthouse P.O. Box 929 York, South Carolina 29745 Laurens, South Carolina 29360 Piedmont Municipal Power Agency Mr. Peter R. Harden, IV, Vice President 121 Village Drive Customer Relations and Sales Greer, South Carolina 29651 Westinghouse Electric Company 6000 Fairview Road Karen E. Long 12th Floor Assistant Attorney General Charlotte, North Carolina 28210 North Carolina Department of Justice P.O. Box 629 Mary Olson Raleigh, North Carolina 27602 Director of the Southeast Office Nuclear Information and Resource Service NCEM REP Program Manager 729 Haywood Road, 1-A 4713 Mail Service Center P.O. Box 7586 Raleigh, North Carolina 27699-4713 Asheville, North Carolina 28802 ENCLOSURE

Catawba Nuclear Station cc:

Mr. T. Richard Puryear Owners Group (NCEMC)

Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Richard M. Fry, Director Division of Radiation Protection NC Dept. of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721 Henry Barron Group Vice President, Nuclear Generation and Chief Nuclear Officer P.O. Box 1006-EC07H Charlotte, NC 28201-1006

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF NUMBER 03-004 RELIEF FROM MINIMUM PERCENTAGE REQUIREMENTS FOR SECOND PERIOD OF THE SECOND INSERVICE INSPECTION INTERVAL CATAWBA NUCLEAR STATION, UNIT 2 DUKE ENERGY CORPORATION DOCKET NUMBER: 50-414

1.0 INTRODUCTION

By letter dated August 8, 2003, Duke Energy Corporation, the licensee for Catawba Nuclear Station (Catawba), Unit 2, submitted a request for relief, Relief Request No.03-004, from the requirements of the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code),Section XI, 1989 Edition with no addenda, Table IWB-2412-1, Unit 2.

Specifically, the licensee requested relief associated with minimum percentage requirements for Inservice Inspection (ISI) Category B-F, Pressure Retaining Dissimilar Metal Weld, for the Second ISI Period which concluded on August 19, 2003, of the Second ISI Interval which concludes on August 19, 2006.

2.0 REGULATORY EVALUATION

The ISI of the ASME Code Class 1, 2, and 3 components shall be performed in accordance with Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, of the ASME Code and applicable edition and addenda as required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). Section 50.55a(a)(3) states in part that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the licensee demonstrates that: (i) the proposed alternatives 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 (including supports) 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 components and system pressure tests ENCLOSURE

conducted 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 Catawba, Unit 2, Second 10-year ISI interval, which concludes on August 19, 2006, is the 1989 Edition. The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Commission approval.

2.1 Systems/Components For Which Relief Is Requested ASME Section XI Code Class 1 Examination Category B-F, Pressure Retaining Dissimilar Metal Welds ID Number Item Number Configuration 2SGA-INLET-SE B05.070.001 SG2A Nozzle to Safe End 2SGA-OUTLET-SE B05.070.002 SG2A Nozzle to Safe End 2SGD-INLET-SE B05.070.007 SG2D Nozzle to Safe End 2SGD-OUTLET-SE B05.070.008 SG2D Nozzle to Safe End 2NC9-02 B05.130.002 SG2A Safe End to Pipe 2NC9-03 B05.130.003 SG2A Safe End to Pipe 2NC15-02 B05.130.014 SG2D Safe End to Pipe 2NC15-03 B05.130.015 SG2D Safe End to Pipe 2.2 Code Requirements ASME Section XI, 1989 Edition with no addenda, Table IWB-2412-1 sets the minimum percentage requirements for Inspection Category B-F, Pressure Retaining Dissimilar Metal Welds for the second inspection period.

2.3 Proposed Alternative Examinations for weld identification numbers 2SGA-INLET-SE, 2SGA-OUTLET-SE, 2SGD-INLET-SE, 2SGD-OUTLET-SE, 2NC9-02, 2NC9-03, 2NC15-02, and 2NC15-03 will be re-performed during the next refueling outage, end of cycle 13 (EOC 13), with an ASME Code acceptable radiographic volumetric examination because no effective ultrasonic technique is available to examine the cast stainless steel reactor coolant system piping elbows.

3.0 TECHNICAL EVALUATION

3.1 Licensee Basis For Relief The licensee examined eight Inspection Category B-F Dissimilar Metal ISI Item Numbers during EOC 12 with a procedure that failed to meet the qualification requirements of ASME Section XI, Appendix III, III-2200 (b) 1989 Edition. The invalid procedure was discovered after completion of the refueling outage (EOC 12). As a result, the examinations were invalid and could not be credited toward the Second Inspection Period percentages. Since EOC 12 was the last outage in the second inspection period, these examinations could not be re-performed by the end of the second inspection period date of August 19, 2003, to meet the second inspection period minimum requirements.

These examinations cannot be physically completed to obtain the minimum percentage before the period expires without bringing the unit back off line and subjecting the unit to unnecessary cycling of systems and components. There are no previous indications in these particular welds and there are no industry problems with welds at these locations.

3.2 Staff Evaluation The second period-required inspections on eight category B-F dissimilar metal welds were performed using an ultrasonic technique during EOC 12. Subsequent to EOC 12, the licensee discovered the inspection procedure did not meet the qualification requirements of Paragraph III-2200(b) of ASME Code Section XI, Appendix III, 1989 Edition, thereby invalidating the examinations that had been performed. Table IWB-2412-1 of ASME Code Section XI, 1989 Edition, establishes period inspection requirements for each ISI interval. The licensees second period of the second ISI interval ended on August 19, 2003. The licensee is requesting relief from the second period inspection requirements. Reinspection of these eight welds will be performed at the next outage, EOC 13, with a qualified radiographic technique.

Paragraph IWB-2412(b) of ASME Code Section XI, 1989 Edition, allows for the inspection period to be extended by as much as one year to enable an inspection to coincide with a plant outage, within the limitations of IWA-2430(d). However, the next Catawba, Unit 2 refueling outage (EOC 13) will occur in the Fall of 2004, which is two months beyond the one year extension period.

In order for the licensee to comply with the second period inspection requirements of ASME Code,Section XI, 1989 Edition, a mid-cycle outage would be required. The licensee has had no previous indications in these particular welds, and there are no industry problems with welds at these locations. Performing a mid-cycle outage would subject Catawba, Unit 2 with a cooldown and heatup cycle that would impose additional stress on the facility and additional inspections due to the evolution, resulting in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

4.0 CONCLUSION

Based on the above evaluation and pursuant to 10 CFR 50,55a(a)(3)(ii), the NRC staff has determined the ASME Code second period inspection requirement for the eight category B-F dissimilar metal welds to be completed by August 19, 2003, would result in hardship or unusual

difficulty without a compensating increase in the level of quality and safety. Therefore, Relief Request 03-004 is authorized for Catawba, Unit 2. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: J. Collins Date: July 20, 2004