ML20141K353

Forwards Second RAI Re Plant,Unit 2 Third 10-yr Interval ISI Program Plan & Associated Requests for Relief.Response Requested to Be Provided within 60 Days from Receipt of RAI

ML20141K353
Person / Time
Site:	Millstone
Issue date:	05/15/1997
From:	Mcdonald D NRC (Affiliation Not Assigned)
To:	Carns N, Loftus P NORTHEAST NUCLEAR ENERGY CO.
References
TAC-M96200, NUDOCS 9705290027
Download: ML20141K353 (9)

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20665 4 001

\*****p8 May 15, 1997 Mr. Neil S. Carns Senior Vice President #rgyp and Chief Nuclear Officer 1

Northeast Nuclear Energy Company c/o Ms. Patricia A. Loftus Director - Regulatory Affairs P.O. Box 128 Waterford, CT 06385

SUBJECT:

SECOND REQUEST FOR ADDITIONAL INFORMATION REGARDING THE MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2, THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF (TAC N0. M96200)

Dear Mr. Carns:

By letter dated July 2, 1996, Northeast Utilities (NU) provided its third 10-year interval inservice inspection program plan and associated requests for relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, requirements for the Millstone Nuclear Power Station, Unit No. 2. The NRC staff, with assistance from its contractor, Idaho National Engineering and Environmental Laboratory (INEEL), is evaluating the submittal.

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A request for additional information (RAI) was issued on January 21, 1997, and NU responded to the RAI by letter dated March 20, 1997. Enclosed is a second l RAI. The information is required in order for the NRC staff to complete its review. We request that a response be provided within 60 days from receipt of this RAI to be consistent with the NRC staff's inservice inspection program plan review schedule. In addition, to expedite the review process, please send a copy of your response to NRC's contractor, INEEL, at the following address:

Michael T. Anderson

, INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209

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Mr. N. S. Carns May 15, 1997 If you have any questions relating to this RAI, please contact me at (301) 415-1408.

Sincerely, origimi signed by: )

Daniel G. Mcdonald, Sr. Project Manager Special Projects Office - Licensing l Office of Nuclear Reactor Regulation Docket No. 50-336

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION:

Docket File . '

PUBLIC SP0-L Reading SP0 Reading i PMcKee LBerry DMcDonald TMcC1ellan GBagchi OGC ACRS JDurr, RI DOCUMENT NAME: G:\ MCDONALD \M962002.RAI To nctive a copy of this document, Indicate in the boa: "C' = Copy without attachment / enclosure "E*

• Copy with attachment / enclosure "N* = No copy 0FFICE SPO-L:PM o l sm SP0-L:LA n r! C/ SPO-L:DD l l l NAME DMcDonaYd //Rd@ LBerry V(lo PMcKee DATE 05/ /%97

• 05/l S/97 05/p6/97 0FFICIAL RECORD COPY l

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4 Mr. N. S. Carns 1 If you have any questions relating to this RAI, please contact me at (301) 415-1408.

Sincerely, E i Daniel G. Mcdonald, Sr. Project Manager Special Projects Office - Licensing Office of Nuclear Reactor Regulation l Docket No. 50-336

Enclosure:

Request for Additional Information cc w/ encl: See next page

Northeast Nuclear Energy Company Millstone Nuclear Power Station

. Unit 2 CC:

Lillian M. Cuoco, Esquire Mr. F. C. Rothen Senior Nuclear Counsel Vice President - Nuclear Work Services Northeast Utilities Service Company Northeast Nuclear Energy Company P. O. Box 270 P. O. Box 128 Hartford,-CT 06141-0270 Waterford, CT 06385 Mr. John Buckingham Ernest C. Hadley, Esquire Department of Public Utility Control 1040 B Main Street Electric Unit P.O. Box 549 10 Liberty Square West Wareham, MA 02576 New Br.itain, CT 06051 Mr. D. M. Goebel Mr. Kevin T. A. McCarthy, Director Vice President - Nuclear Oversight Monitoring and Radiation Division Northeast Nuclear Energy Company Department of Environmental Protection P. O. Box 128 79 Elm Street Waterford, CT 06385 Hartford, CT 06106-5127 Mr. M. L. Bowling, Jr.

Regional Administrator, Region I Millstone Unit No. 2 Nuclear U.S. Nuclear Regulatory Commission Recovery Officer i 475 Allendale Road Northeast Nuclear Energy Company King of Prussia, PA 19406 P. O. Box 128 a Waterford, CT 06385 First Selectmen Town of Waterford Mr. J. K. Thayer Hall of Records Recovery Officer - Nuclear Engineering 200 Boston Post Road and Support Waterford, CT 06385 Northeast Nuclear Energy Company ,

P. O. Box 128 )

Mr. Wayne D. Lanning Waterford, CT 06385 Deputy Director of Inspections Special Projects Office Mr. B. D. Kenyon ,

475 Allendale Road President and Chief i King'of Prussia, PA 19406-1415 Executive Officer j Northeast Nuclear Energy Company Charles Brinkman, Manager P. O. Box 128 Washington Nuclear Operations Waterford, Connecticut 06385 ABB Combustion Engineering 12300 Twinbrook Pkwy, Suite 330 Mr. Allan Johanson, Assistant Director Rockville, MD 20852 Office of Policy and Management Policy Development and Planning Senior Resident Inspector Division Millstone Nuclear Power Station 450 Capitol Avenue - MS# 52ERN c/o U.S. Nuclear Power Station P. O. Box 341441 P.O. Box 513 Hartford, CT 06134-1441 Niantic, CT 06357 j i

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Northeast Nuclear Energy Company Millstone Nuclear Power Station Unit 2 CC: I Citizens Regulatory Commission ATTN: Ms. Susan Perry Luxton 180 Great Neck Road i Waterford, Connecticut 06385 Deborah Katz, President Citizens Awareness Network P. O. Box 83 Shelburne Falls, MA 03170 The Honorable Terry Concannon Co-Chair-Nuclear Energy Advisory Council l Room 4035-Legislative Office Building Capitol Avenue Hartford, Connecticut 06106 Mr. Evan W. Woollacott ,

Co-Chair '

Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, Connecticut 06070 Little Harbor Consultants, Inc.

Millstone - ITPOP Project Office P. O. Box 0630 Niantic, Connecticut 06357-0630 e

'. SECOND RE0 VEST FOR ADDITIONAL INFORMATION THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN MILLSTONE NUCLEAR POWER STATION. UNIT NO. 2 NORTHEAST NUCLEAR ENERGY COMPANY DOCKET NUMBER 50-336

1. Scoce/ Status of Review The U.S. Nuclear Regulatory Commission (NRC) is responsible for the review and disposition of licensee requests relating to inservice inspection (ISI) requirements contained in Title 10 of the Code of Federal Reaulations (10 CFR), Section 50.55a, and the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code or ASME Code),Section XI. In each request, licensees are required to provide both a regulatory basis (by citing the appropriate section of 10 CFR 50.55a) and a technical discussion supporting the request. This information is used to establish the context for each evaluation.

The NRC staff has reviewed the information submitted by Northeast Utilities (NU) in its letters dated July 2 and March 20, 1997, and found that additional information is required to complete the review.

2. Additional Information Reauired Further information and/or clarification of the March 20, 1997, NU response to the NRC staff's initial request for additional.information is needed. Please respond to the following:

2A. In the NU's response regarding the apparent conflict between the ISI program and the Code requirement to examine a percentage of reactor pressure vessel studs each period (Reference Response E.),

NU stated that relief should not be required as they are meeting Code requirements. Based on the current industry implementation of Examination Category B-G-1, through the 1989 Edition, the staff does not agree with the licensee's position. The 1989 Edition of the Code has five items for reactor vessel bolting. NU has not addressed the volumetric examination, Item B6.20, Closure Studs, inplace, which does not allow deferral. For pressurized water reactors, all studs are typically removed each refueling outage.

Item B6.30 Closure Studs, when removed, includes the note that deferral is permissible. However, it is understood that deferral of the subject examinations is only acceptable when the component disassembly.is scheduled at the end of the interval.

Although'later editions of the Code state that deferral is permissible, the NRC Staff has not approved this change. In addition, it has been noted that in later editions of the Ccde Enclosure

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'N n incomplete as Note 5 has been eliminated.. In later editions of the I

Code, IWB-2412 Inspection Program B, maintains that the required

i percentage in each Examination Category shall be completed in i

accordance with Table IWB-241.2-1 with the following exception. l

! Item (4) states, " examinations deferred until disassembly of a i'

component for maintenance, repair, or volumetric' examination, as allowed by Examination Categories B-G-1, B-G-2, B-L-2, and B-M-2.

If there are less than three' items or welds to be examined in an

, Examination Category, the items or welds may be' examined in any two i periods, or in any one period if there is only~one item or weld, in j lieu of the percentage requirements of Table IWB-2412-1."

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!- Considering that all reactor pressure vessel closure head studs are

removed each refueling outage (54 studs), NU can perform the j required examinations each period. As a result, the basis for

deferral of all of the closure head studs until the end of the i interval is not supported. For the NRC Staff to find this part of

. the NU's program acceptable, NU must schedule a sample of reactor  !

i pressure vessel closure studs for examination each period in 1

accordance with Table IWB-2412-1. Provide the action NU proposes to

{ take regarding the scheduling of the reactor pressure vessel closure

head studs.

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28. In accordance with 10 CFr. 50.55a(c)(3), 10 CFR 50.55a(d)(2), and 10 CFR 50.55a(e)(2), ASM2 Code cases may be used as alternatives to Code requirements. Code cases that the NRC has approved for use are published in Regulatory Guide 1.147, Inservice Inspection-Code Case Acceptabfif ty, with any additional conditions the NRC may have imposed. When used, these Code cases must be implemented in their entirety. ASME approved Code cases awaiting NRC acceptance and subsequent publication in Regulatory Guide 1.147 may be adopted only if the licensee requests, and the NRC authorizes, their use on a case-by-case basis.

1 Use of Code Cases not published in Regulatory Guide 1.147 may be acceptable when conditions deemed appropriate by the NRC are included; a licensee proposing the use of such alternative (s) must commit to meet these conditions.

NU has submitted a list of Code cases for implementation during the third interval. It is noted that NU requested and received approval for use of certain Code cases in the previous interval and NU requested that these requests remain approved for the third  ;

interval. For several of these cases, the use was approved provided that NU satisfy certain conditions. It is necessary that written commitments be provided for these conditions by NU. Therefore, NU should review requests for , implementing Code cases that have not yet

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(1995 Edition), the Table for Examination Category B-G-1 is incomplete as Note 5 has been eliminated. In later editions of the 4 Code, IWB-2412 Inspection Program B, maintains that the required 3 percentage in each Examination Category shall be completed in accordance with Table IWB-2412-1 with the following exception.

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Item (4) states, " examinations deferred until disassembly of a I component for maintenance, repair, or volumetric examination, as

, allowed by Examination Categories B-G-1, B-G-2, B-L-2, and B-M-2. l j

If there are less than three items or welds to be examined in an Examination Category, the items or welds may be examined in any two 1 periods, or in any one period if there is only one item or weld, in  !

. lieu of the percentage requirements of Table IWB-2412-1." 1 i

Considering that all reactor pressure vessel closure head studs are  !

!. removed ea@ refueling outage (54 studs), NU can perform the required examinations each period. As a result, the basis for ,

deferral of all of the closure head studs until the end of the  :

I interval is not supported. For the NRC Staff to find this part of l

! the NU's program acceptable, NU must schedule a sample of reactor l pressure vessel closure studs for examination each period in l accordance with Table IWB-2412-1. Provide the action NU proposes to 4

take regarding the scheduling of the reactor pressure vessel closure j head studs.

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28. In accordance with 10 CFR 50.55a(c)(3), 10 CFR 50.55a(d)(2), and '

l 10 CFR 50.55a(e)(2), ASME Code cases may be used as alternatives to i Code requirements. Code cases that the NRC has approved for use are (

, published in Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, with any additional conditions the NRC may have  !

! imposed. When used, these Code cases must be implemented in their l l entirety. ASME approved Code cases awaiting NRC acceptance and i

' subsequent publication in Regulatory Guide 1.147 may be adopted only

if the licensee requests, and the NRC authorizes, their use on a case-by-case basis. ,

Use of Code Cases not published in Regulatory Guide 1.147 may be .

j acceptable when conditions deemed appropriate by the NRC are

included; a licensee proposing the use of such alternative (s) must i . commit to meet these conditions.

hU has submitted a list of Code cases for implementation during the third interval. It is noted that NU requested and received approval l fcr use of certain Code cases in the previous interval and NU  !

requested that these requests remain approved for the third  ;

interval. For several of these cases, the use was approved provided  !

that NU satisfy certain conditions. It is necessary that written i 4

commitments be provided for these conditions by NU. Therefore, NV 1 should review requests for implementing Code cases that have not yet 4

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refueling outages by looking for evidence of leakage, the subject insulation removal is not pressure test frequency dependent.

Therefore, the requirement for insulation removal should be the same for both Class 1 and 2 borated systems and NU should commit to the removal of insulation and VT-2 visual examination of bolted connections in Class 1 and 2 systems borated for controlling reactivity each refueling outage. Confirm that insulation removal will be performed for both Class 1 and 2 borated systems each refueling outage.

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