TXX-9917, Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES

Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES

ML20216D534
Person / Time
Site:	Comanche Peak
Issue date:	07/26/1999
From:	Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0612 TXX-99172, NUDOCS 9907300015
Download: ML20216D534 (5)

Text

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b-M F ""l Log # TXX-99172

- = File # 10010.1 905.2 7UELECTRIC Ref. # 10CFR50.55a

%% July 26,1999 Senior Mce P>esident

& PrincipalNuclear Oficer U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 SUPPLEMENT INFORMATION TO NUREG-0612 REF: 1) TXU Electric' letter logged TXX-3659 from H. C. Schmidt to the NRC dated June 3,1983

2) TXU Electric letter logged TXX-4226 from H. C. Schmidt to the NRC dated July 12,1984 1

3) NRC letter to TXU Electric dated November 27,1984, " Acceptability of l CPSES Compliance with the Control of Heavy Loads Guidelines of NUREG-0612"

. TXU Electric wishes to provide information regarding the Augmented inservice laspection (AISI) '

Plan, which requires periodic inspection of the Reactor Vessel Head and Internals Lifting Devices at CPSES. These li. Ng devices, referred to as lift rigs, are non ASME Code Class items and are therefore not under the jurisdiction of ASME Sect;.)n XI or the CPSES ASME Section XI Inservice inspection (ISI) Plan. The governing documents identified in the AISI Plan are ANSI N14.6 - 1978, NUREG 0612, and Reference 2.

Via Reference 1 and 2, TU Electric identified section 6 of WCAP-10156 rev.1 for testing of these lift rigs.~ Paragraph 6.5 of WCAP-10156 rev.1 recommends "that a periodic j nondestructive surface examination of critical welds and/or parts be performed once every ten I years as part of an inservice inspection outage."

9907300015 990726" PDR ADOCK 05000445 i G PDR

'. TXU Electric was formerly TU Electric. A license amendment request (LAR 99-003) was submitted per TXX-99122, dated May 14,1999, to revise the company name contained in the CPSES operating licenses.

COMANCHE PEAK Si!.AM ElICTRIC STATION 300009 eo. % = m x .1m., mm.m L

TXX-99172 Page 2 of 4 In an NRC letter dated November 27,1984 on the subject of " Acceptability of CPSES l Compliance with the Control of Heavy Loads Guidelines of NUREG-0612", it is stated that "[T]he I proposed alternate for this type of testing, which was recommended in WCAP-10156, rev.1 is i acceptable.".

The AISI Plan was developed using the critical part and weld list from the WCAP and examination roelhods that matched the original construction / fabrication examinations. As with the ISI examinations of ASME Code Class 1,2 and 3 components, the fabrication examination methods are not always the most meaningful or practical methods for performance after component assembly and initial plant operation. In addition to complications due to j contaminated surfaces, painted surfaces and surface accessibility, later nondestructive l' examination techniques and methods have been developed since the assignment of the AISI examination methods. Moreover, there are critical items that are involved with the overall lifting system that are not integral to the lift rigs themselves and were not included in the WCAP critical part and weld list Therefore, a comprehensive review of the lift rig system was performed in preparation for the end of interval 10 year ISI examination outage. A summary of the changes resulting from this {

review are described below. The actual changes will be made to the AISI Plan examination tables. These changes provide an inspection scheme that maintains compliance with the goveming documents, is more appropriate for the given application, is more consistent to the ASME Section XI ISI program applied to Code Class 1,2 and 3 components and maintains or increases the level of quality and safety intended during the 1983 and 1984 AISI Plan development.

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1). Add the following items to the AISI Plan:

Rem Examination Method Reactor Vessel Head Lifting Lug Surface

-integral attachment area Reactor Vesse! Head Lifting Lug Visual

- base material area Load Cell Pins Volumetric Lower Internals Connecting / Lifting Pins Volumetric Justificction: l Adding nondestructive examination requirements where none previously existed increases the level of quality and safety of the overalllifting system a

TXX-99172 Page 3 of 4 2). Change the examination method for all pins and screws listed from the current Liquid Penetrant or Magnetic Particle method to the Volumetric examination method.

Justification:

Volumetric examinations provide a more thorough interrogation of the subject parts which provides an increased level of quality and safety than surface examinations. It is also more practical to perform volumetric examinations which can be accomplished without full or partial disassembly of the part therefore maintaining component integrity.

3). Change the examination method for all welds listed from the current specific Liquid Penetrant or Magnetic Particle method to the more general Surface examination method (which also allows eddy current examination to be performed as a surface examination).

Justification:

Using the " surface examination" terminology in lieu of requiring either a specific " liquid penetrant" or a cpecific " magnetic particle" examinatim maintains the existing level of quality and safety, it is also more practical to base the assignment of examination types, which are considered interchangeable and use the saine acceptance criteria, on part configuration, accessibility, contamination levels and the minimization of rad waste.

4). Change the examination method for all base material areas of legs, lugs, plates and blocks listed from the current Liquid Penetrant or Magnetic Particle method to the Visual examination method.

Justification:

The subject parts are typically large, painted and contaminated. The removal of lead based paint for the performance of liquid penetrant or magnetic particle examination creates personnel safety, ALARA and rad waste concems. The attachment of these parts are by welds, pins or screws which are examined by surface or volumetric examinations as applicable. The nondestructive examination method applied to ASME Code Class 1 component supports (i.e.,

reactor vessel, steam generator and reactor coolant pump supports) of similar configuration and purpose is the visual method. Performing visual examination on these parts in conjunction with l the rest of the examinations performed maintains the overall level of quality and safety of the

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lifting system intended during the AISI Plan development.

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- TXX-99172 Page 4 of 4 5). Change the acceptance criteria and personnel qualification requirements from the currently identified ASME Sections ill and V construction / fabrication Codes to the ASME Section XI Inservice Inspection Code.

Justification:

Using the procedures and personnel that are performing the ASME Section XI ISI on Code l Class 1,2 and 3 components for examination of the lifting system, is more practical than it is to have a separate set of procedures and personnel. Using the ASME Section XI Code requirements provides consistency in examination methodology and maintains the overall level I of quality and cafety of the lifting system intended during tne AISI Plan development. )

This communication contains no new licensing basis commitments regarding CPSES Units 1 and 2. Should you have any questions, please contact Mr. Obald Bhatty at (254) 897-5839.

Sincerely,

$, S C. L. Terry By: M ~

Roger D. Walker Regulatory Affairs Aanager OAB/oab Enclosures 1) TXX-3659

2) TXX-4226 cc: Mr. E. W. Merschoff, Region IV Mr. D. H. Jaffe, NRR Mr. J. I. Tapia, Region IV Resident inspectors, CPSES

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Enclosure 1 and 2 to TXX- 99172 l l

1 1

h.

• TEXAS UTILITIES SERVICES INC.

m n nn u s m o:n in u. m u s w m m m u. Log # TXX-3659 File # 10010 June 8, 1983 Director of Nuclear Reactor Regulation Attention: Mr. B. J. Youngblood, Chief -

Licensing Branch No. 1 -

Division of Licer. sing U. S. Nuclear Regulatory Comission Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION DOCKET NOS. 50-445 and 50-446 FINAL RESPONSE TO NUREG-0612

Dear Mr. Youngblood:

Enclosed are forty (40) copies of our final response to NUREG-0612,

" Control of Heavy Loads at Nuclear Power Plants".

If you have questions, please call.

Sincerely, l

Nh/i H. C. Schmidt RWH: tis Enclosures l

ap &l 7(,, i[3pp

j v, l

Log # TXX-4226 TEXAS UTILITIES GENERATING COMPANY Fi1e # 10010 l MKYWAY TOWER

• 400 NE >RTH OLIVE NTHEET. L,ts, set

• DALLAm, TEXAm 73208 '

July 12, 1984 I l

Mr. B. J. Youngblood, Chief i Licensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission l Washington, D.C. 20555 1

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION DOCKET NOS. 50-445 AND 50-446 RESPONSE TO B. J. YOUNGBLOOD LETTER TO M. D. SPENCE DATED MAY 17, 1984,

" Technical Evaluation Report Regarding Control of Heavy Loads in Accordance  ;

with NUPEG-0612 at CPSES"

Dear Mr. Youngbl* 1:

As directed by your May 17, 1984 letter, a conference call was held June 18, 1984 with the NRC to resolve the open items associated with handling of heavy loads at CPSES. Resolution was reached concerning these items  :

and is documented by the following:

Section Resolution

'2.2.1 The safety injection pump hoist has been removed at CPSES, therefore this section is closed. l 2.3.1 1) Safe load areas are defined in CPSES plant procedures and operators craining so that, to the extent practical, heavy loads are not carried over or near irradiated fuel or safe shutdown equipment.

2) Safe load area sketches are provided in the ,

appropriate plant procedures.

3) Electrical interlocks are utilized on the Fuel Building Overhead Crane and are discussed in the appropriate plant procedures.

4) The signalmen and crane opefitors at CPSES have been trained to use hand signals. These signals are discussed in the appropriate plant procedures.

2.3.2 Closed A DIVINION Of TEKAs L7tLET8Es ELECTNCC COMI*ANY j j

Q*

t 2.3.3 Closed 2.3.4 1) Reactor vessel head and reactor internal lifting rigs meet the intent of ANSI 14.6-1978 and NUREG-0612 for design, fabrication, assembly and operation. Refer to Section 6 of the enclosed WCAP-10156, Rev. 1.

2) A detailed, analysis of an alternate load verification, tasting, and stress design factor is included in Attachment 8 of WCAP-10156, Rev. 1.

2.3.5 The unit of hoist speed used for calculating the dynamic load in the formula (load X 0.005 X hoist speed + max, static load) is feet / minute. l 2.3.6 Closed 2.3.7 The CPSES Final Response to NUREG-0612 was submitted to the NRC by letter TXX-3659 dated June 8, 1983.

1) All loads in Table A-4 of this report which are less than 2150 pounds are not considered heavy loads, therefore no action is taken with those items. j 2.4.1 Not applicable to CPSES.

I 2.4.2 Closed 2.4.3 Closed If you have questions, please call.

Sincerely, H. C. Schmidt RWH/grr Enclosure cc - Mr. John J. Stefano Mr. Pete Hearn Mr. Amarjit Singh