L-02-002, G20100238/EDATS: OEDO-2010-0305 - Ltr. Tom Gurdziel, 2.206 - Firstenergy - Davis-Besse

G20100238/EDATS: OEDO-2010-0305 - Ltr. Tom Gurdziel, 2.206 - Firstenergy - Davis-Besse

ML101120844
Person / Time
Site:	Davis Besse
Issue date:	04/15/2010
From:	Tom Gurdziel - No Known Affiliation
To:	Borchardt R NRC/EDO, Office of Nuclear Reactor Regulation
References
2.206, BL-02-002, EDATS: OEDO-2010-0305, G20100238, OEDO-2010-0305
Download: ML101120844 (40)

Text

EDO Principal Correspondence Control FROM: DUE: 05/21/10. EDO CONTROL: G20100238 DOC DT: 04/15/10 FINAL REPLY:-

Tom Gurdziel Oswego, New York TO:

Borchardt, EDO FOR SIGNATURE OF ** GRN ** CRC NO:

Leeds, NRR DESC: ROUTING:

2.206 - FirstEnergy - Davis-Besse Borchardt (EDATS: OEDO-2010-0305) Virgilio Mallett Ash Mamish Burns/Rothschild DATE: 04/22/10 Satorius, RIII Burns, OGC ASSIGNED TO: CONTACT: Mensah, NRR Scott, OGC NRR Leeds Kotzalas, OEDO SPECIAL INSTRUCTIONS OR REMARKS:

Th~Moi0eE>Oocl L_ k (16 SI-Q00 -0ý

EDATS Number: OEDO-2010-0305 Source: OEDO Generl Inforti o Assigned To: NRR OEDO Due Date: 5/21/2010 11:00 PM Other Assignees: SECY Due Date: NONE

Subject:

2.206 - FirstEnergy - Davis-Besse

Description:

CC Routing: Region]ll; OGC; Tanya.Mensah@nrc.gov; Catherine.Scott@nrc.gov ADAMS Accession Numbers - Incoming: NONE Response/Package: NONE I0te Ifr ai oI Cross Reference Number: G20100238 Staff Initiated: NO Related Task: Recurring Item: NO File Routing: EDATS Agency Lesson Learned: NO OEDO Monthly Report Item: NO IPocs Inomtn I Action Type: 2.206 Review Priority: Medium Sensitivity: None Signature Level: NRR Urgency: NO Approval Level: No Approval Required OEDO Concurrence: NO OCM Concurrence: NO OCA Concurrence: NO Special Instructions:

Iloue n Inomtn I Originator Name: Tom Gurdziel Date of Incoming: 4/15/2010 Originating Organization: Citizens Document Received by OEDO Date: 4/21/2010 Addressee: R. W. Borchardt, EDO Date Response Requested by Originator: NONE Incoming Task Received: Letter Page 1 of I

9 Twin Orchard Drive Oswego, NY 13126 April 15, 2010 Mr. Bill Borchardt, Executive Director for Operations US Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Mr. Bill Borchardt:

This is a 2.206 letter.

Early in 2002 1 started following the events at the FirstEnergy/Davis-Besse plant. I read everything that I could find. And, I mean, all those transcripts of monthly meetings too.

(Some ran to 110 pages, or more. At 20 pages a night, that is 6 night's worth of reading.)

Besides that, I also made telephone calls.

Now, in 2010, I read everything that I can find about FirstEnergy/Davis-Besse.

Here is my observation: the exact same thing happened with the second upper reactor head at FirstEnergy/Davis-Besse that happened with the first. That is, reactor coolant has made its way through cracks (in either the CRDM nozzles or the J-groove weld),

attacking the carbon steel head and ended up on the top surface of the upper reactor head.

One reason for that to happen this time is the present inadequate specification of required (PWR upper head) testing notwithstanding the length of time taken to study the first head failure. Specifically, looking at the top surface of the reactor head does not allow observation of the bottom parts where, apparently, the cracks start. All it does is allow time to pass, (and the plant to operate), until complete through weld/nozzle wall (and head) failure can be identified by reactor coolant residue up there.

I have tried to make this point, (and some others), in a series of e-mail comments I made this week and sent to Jim Heller and Viktoria Mitlyng of Region III.

So, I am requesting that you order the FirstEnergy/Davis-Besse plant to remain shut down until those 13 comments are satisfactorily addressed.

Along with those e-mail comments, I also sent slides from an August 23, 2002 public meeting between the NRC and NEI and PWR Licensees. On page 12 of 36, under the title of "Status of Future Inspections", it says exactly the same thing:

"Management by visual examination may not be considered sufficient" This guidance was given more than 7 years ago.

EDO -- G20100238

Additionally, I am requesting that you order the FirstEnergy/Davis-Besse plant to remain shut down until "Staff Concerns" listed on slide 14 of 36 are reviewed in light of present day knowledge and satisfactorily addressed.

Additionally, I am requesting that you order the FirstEnergy/Davis-Besse plant to remain shut down until "Requested Information, 30 -Day Response" listed on slides 18 of 36 and 19 of 36 are also reviewed in light of present day knowledge and satisfactorily addressed.

I am also requesting that you order the same shutdown until adequate J-groove weld inspection techniques are clearly specified. (The reference is slide 27 of 36, where it states:

"Ultrasonic inspection of the weld material has not been demonstrated to be effective in detecting flaws in the J-groove weld, therefore, PT or ET is required" The counterbore shown in slide 10 of 36 tells me that the J-groove weld is made with a gap or space between the reactor head and the CRDM nozzle. I request that you order the FirstEnergy/Davis-Besse plant to remain shut down until you are sure that the weld qualification for this weld was made with a similar gap, and passed the test.

I can supply you with the e-mails if you can't get them from Region III.

Thank you, Tom Gurdziel Member, ASME

Public Meeting Between NRC and NEI and PWR Licensees to Discuss Bulletin 2002-02 REGO 0 TwoVWhite Flint North o 11545 Rockville Pike Rockville, Maryland 20852 TIVFN AuaitoriLrn August 23, 2002 9:00 am - 12:15 pm

Agenda Time TQpik Speaker Brian Sheron, NRC 9:00 a - 9:15 a Opening Remarks Alex Marion, NEI 9:15 a - 10:00 a Overview of Bulletin 2002-02 Allen Hiser, NRC 10:00 a - 10:30 a Example of Supplemental Inspections Tim Steingass, NRC 10:30 a - 11:00 a Q & A on 1 st and 2rd Presentations all/public 11:00 a - 11:15 a Break all Overview of Plans for Vessel Head and 11:15 a - 11:30 a Michael Marshall, NRC Nozzle Inspection Regulations 11:30 a - 12:00 p Q & A on 3rd Presentation all/public Brian Sheron, NRC 12:00 p - 12:15 p Closing Remarks Alex Marion, NEI Rockvlle, MD August 23, 2002

Contacts 4 NEI Project Manager oJoe Birmingham, 301-415-2829

- Bulletin 2002-02 Technical Contacts oAllen Hiser, 301-415-1034 oTim Steingass, 301-415-3312

-+ Bulletin 2002-02 Project Managers oMichael Marshall, 301-415-2734 oSteve Bloom, 301-415-1313 Rockville, MD August 23, 2002

NRC Web-Site Information

-+Alloy 600 Cracking (including Circumferential Cracking of CRDM Nozzles) ohttp://www.nrc.gov/reactors/operating/ops-experience/alloy600.html 4 RPV Head Degradation o http://www.nrc. gov/reactors/operating/ops-experience/vessel-head-degradation. html Rockville, MD August 23, 2002

Previous Meetings with NEI and MRP Conceming Cracking, Wastage, or Inspections Date Subject 08/23/2002 Bulletin 2002-02 07/24/2002 Revised MRP Proposed Inspection Plan 05/22/2002 MRP Proposed Inspection Plan, Crack Growth Rate, Probability of Detection, Probabilistic Fracture Mechanics 03/16/2002 Davis Besse Reactor Vessel Head Degradation 02/20/2002 Control Rod Drive Mechanism Vessel Head Penetration Cracking 11/08/2001 Control Rod Drive Mechanism Nozzle Cracking 08/15/2001 Bulletin 2001-01 07/03/2001 Development of Bulletin 2001-01 06/07/2001 Control Rod Drive Mechanism Nozzle Cracking 04/12/2001 Control Rod Drive Mechanism Nozzle Cracking Rockville, MD August 23, 2002

Overview of Bulletin R E G&

2002-02 Z 11

-00;7 ý Presenter:

Allen Hiser, 301-415-1034 0

August 23, 2002

Background on VHP Nozzle

-Cracking &RV Head Deciradation.

+ First cracking of CRDM nozzles identified in France in 1991 - axial cracking

+ Industry analyses - axial cracking not a safety concern; circumferential cracking unlikely

+ NRC issued Generic Letter 97-01

+ Spring 2001 Outages -- Circumferential flaws detected (boric acid deposits)

" Oconee Units 2 & 3 - 2 nozzles 1650 through-wall cracks

" Chronology of circumferential cracks o Axial cracks in J-groove welds or HAZ allow leakage into annular region o Leakage to vessel head OD may be restricted by interference fit of nozzles o Circumferential cracks initiate on OD and grow in aggressive environment RocWi1e, MD August 23, 2002

Background on VHP Nozzle Cracking & RPV Head Degradation

+ NRC issued Bulletin 2001-01 (August 2001) -inspections for circumferential cracks

• Spring 2002 Outages - vessel head degradation identified at Davis-Besse

+ NRC issued Bulletin 2002-01 (March 2002) - no head degradation at other plants

+ NRC issued Bulletin 2002-02 (August 9, 2002) -

inspections to prevent leakage Rockville, MD August 23, 2002

Typical Reactor Vessel Head.

-Oconee Unit 1 (Babcock & Wilcox)

I I I ICR DM Thermocouple Vessel ea Source:

Rockville, MD August 23, 2002

Schematic View of B&W Design CRDM Nozzle Area SA-12

• ERNiCr-3F34 SB-167 UNS N06600 (A*lly82)

(Alloy600) Outr Surfac of RPV Head

\ *4P"'* RPV Head r F(SA-533 Gr. B Cl. 1)

/miabd

,1 .Inner Surface of RPV Head oureSteel Ce-3ing) ly ý J-Groove Weld Source:

Rockville, MD August 23, 2002

Past Inspections I 1* Lr Most RecentIrnspection, .,

Plants, Date.' , . Summary ofCracked or Leaking CRDMNozzles, Mate' ethod& S Crcufrentia ,!, Number

.' Leaking Cracked Nozzle'Cracks' R~epaired Oconee 1 11/2000 Qualified Visual - 100% 1* 1* 0 1 Oconee 3 02/2001 Qualified Visual - 100% 9 9 3 9 ANO-1 03/2001 Qualified Visual - 100% 1 1 0 1 Oconee 2 04/2001 Qualified Visual - 100% 4 4 1 4 Robinson 04/2001 Qualified Visual - 100% 0 0 0 0 North Anna 1 09/2001 Qualified Visual - 100%** 0 8 0 0 Crystal River 3*** 10/2001 Qualified Visual - 100%** 1 1 1 1 TMI-1 10/2001 Qualified Visual - 100% 5* 8* 0 6 Surry 1 10/2001 Qualified Visual - 100%** (4) 10 0 6 North Anna 2 10/2001 Qualified Visual - 100%** 3 3 0 3 Surry 2 11/2001 Qualified Visual - 100%** 0 0 0 0 Oconee 3 11/2001 Qual. Visual - 100% (UT of 100%) 5 7 1 7 D. C. Cook 2 1/2002 Qual. Visual, ECT, UT - 100% 0 0 0 0 Millstone 2 *** 2/2002 UT Examination - 100% 0 3 0 3 Davis-Besse 2/2002 UT Examination - 100% 3 5 1 3 (5)

Oconee 1 3/2002 Qualified Visual - 100% 1 2 0 2 Rockville, MD August 23, 2002

Status of Future Inspections Management by visual examination may not be considered sufficient

" Visual examination inspectability

" Hypotheses contained in the Davis-Besse root cause report is probable

• Technical specification limit of "no pressure boundary leakage" Need further information to support visual examinations alone

" On-going MRP activities

• Support not sufficiently mature at this time

• Addtional technical understanding about wastage (corrosion) rates

• Agreement on technical basis for predictive models for crack growth in.

welds

" Cracking is becoming more prevalent as plants age Rockville, MD August 23, 2002

Bulletin 2002-02 Susceptibility Ranking~f 70 60 50 4-D 0 40 CU 30 20 10 0

0 5 10 15 20 25 EDY (estimated to 9/1/02)

Rockville, MD August 23, 2002

Staff Concems

+ Understanding about wastage (corrosion) rates and wastage phenomena

+ Predictive models for crack growth in welds

+ Cracking is .becoming more prevalent as plants age

+ Occurrence of through-wall or through-weld cracks during operation

+ Capability to identify through-wall or through-weld cracks by leakage detection _

Rockvlle, MD August 23, 2002

Proactive Actions Needed To Address Issues

" Industry needs to provide adequate technical justification to reduce necessary reliance on supplemental non-visual examinations "New heads with Inconel 690 tubes will have to follow the same inspection criteria as heads with Inconel 600 until industry provides technical basis for changes Rockville, MD August 23, 2002

Requested Information

+ Issued August 9, 2002 - "Reactor Pressure Vessel Head and Vessel Head Penetration Nozzle Inspection Programs"

• Informs PWRs of NRC concerns with visual examinations

+ Asks PRRs to provide information about planned inspections

" Plans to supplement inspections

• Justification for reliance on visual examinations

+ Categorization based on effective degradation years (EDY)

+ Provides example of supplemental inspection Rockville, MD August 23, 2002

Requested Information 30-Day Response (qb For Plants that plan to supplement their RPV head and VHP inspection programs with non-visual NDE methods:

+ Methods and Frequencies Qualification Requirements

" Method

" Personnel

+ EDY

+ Acceptance criteria

+ Scope and Coverage Rockville, MID August 23, 2002

Requested Information 30-Day Response (at.For plants that do not plan to supplement their RPV head and VHP inspection programs with non-visual NDE methods:

+ Discussion of Technical Basis for Concluding that Unacceptable Vessel HeadWastage Will not Occur Between Inspection Cycles

" Provide Data to Demonstrate Understanding Wastage Phenomena

" Provide Data to Demonstrate Understanding Wastage Rates

" Applicability of Data to Plant Rokvl1e, MD August 23, 2002

Requested Information 30-Day Response (a* For plants that do not plan to supplement their RPV head and VHIP inspection programs with non-visual NDE methods:

+ Discussion on How Reliability and Effectiveness of the Inspections Method Was Demonstrated

+ Discussion on How the Six Concerns Have Been Addressed Rockville, MD August 23, 2002

Requested Info ation 30-Day Post Inspection Res nse CLARIFICATION: Staff intent is a one-time submittal after next inspection of vessel head and nozzle penetrations.

Inspection Scope and Results

• location, size, extent, and nature of any degradation NDE Used

" method, number, type, and frequency of transducers or transducer packages,

" essential variables, equipment,

" procedure and personnel qualification requirements Rockville, MD August 23, 2002

Requested Information 30-Day Post Inspection Resonse

+ Criteria used to determine whether an indication, "shadow," or "backwall CWA anomaly" is acceptable or rejectable

+ Corrective actions taken and the root cause determinations for any degradation found.

Rockville, MD August 23, 2002

Example of Supplemental Inspections C:2 4'

Presenter:

0 Timothy Steingass, 301-415-3312 15 August 23, 2002

Example of Supplemental Inspecions.

AHigh Susceptibility Plants

( > 12 EDY) -- 33 plants o UT of nozzle base metal every RFO o Surface examination (eddy current or PT) every RFO o Bare metal visual every RFO AModerate Susceptibility Plants

( > 8 EDY& <12 EDY) - 15 plants o UT of nozzle base metal at RFO after next RFO and then every other RFO o Surface examination (eddy current or PT) at RFO after next RFO and then every other RFO o Bare metal visual at next RFO and then every other RFO ALow Susceptibility Plants

( < 8 EDY) - - 21 plants o UT of nozzle base metal within 5 years and then at least once every 5 years o Surface examination (eddy current or PT) within 5 years and then at least once every 5 years o Bare metal visual within 3 years and then at least once every 5 years Rockville, MD August 23, 2002

Example of Supplemental Inspections AExample of Supplemental inspections is not the definitive answer to testing - other approaches may be technically sound AAnother Supplemental NDE approach may be warranted based on a particular licensee's configuration, geometry and method of construction AThe licensee is responsible to provide their technical basis for their Supplemental NDE approach Rockville, MD August 23, 2002

Bare Metal Visuals ABare Metal Visuals (BMV) detect through wall leakage after the leakage has begun.

AOnce leakage has been identified, supplemental nondestructive examinations (NDE) are performed ABMV can be challenging to complete. Through-wall leakage may not detected in part due to access restrictions o There may be field impediments to overcome ASupplemental NDE may be necessary to assure that long term leakage does not go undetected to prevent head wastage 7 ...

Rockville, MD August 23, 2002

Bare Metal Visuals ABMV are beneficial because access limitations or surface conditions may prevent complete coverage of the J-groove weld ATherefore, it is reasonable to continue performing BMV as part of the inspection plan APerforming supplemental NDE is consistent with Inservice Inspection Programs and ASME to monitor Class 1, 2 and 3 components Rockvle, MD August 23, 2002

UItrason ic Testing AUltrasonic testing effectively detects flaws in the CRDM tube base material, both the IDand OD AIf flaws are detected, their location, orientation and size must be characterized AUltrasonic inspections detect CRDM base metal flaws prior to leakage onset AUltrasonic inspection of the weld material has not been demonstrated to be effective in detecting flaws in the J-groove weld, therefore, PT or ET is required Rockville, MD August 23, 2002

Eddy Current or Dye Penetrant Testing AThe Eddy Current or PT examination acts as assurance that no unacceptable flaws exist in the CRDM nozzle or J-groove weld area AET or PT examination provide assurance that J-groove weld flaws will be detected AET or PT examinations detect cracks prior to any loose parts issues developing in the lower portion of the CRDM tube Rockile, MD August 23, 2002

Frequency of Examinations AThe working industry with MRP and EPRI have been diligently to expand NDE capabilities and effectiveness AMRP have also provided a proposed inspection plan that we have used as basis with modifications for the suggested frequencies in the Bulletin-Aincreased testing frequency as EDY increase is consistent with the ASME Code approach of successive inspections if flaws are identified.

AThe testing frequencies will be assessed by the staff after a sicinificant amount of field data can iustifv chanaes I.,T Rockville, MD August 23, 2002

CONCLUSIONS ADetection and characterization of unacceptable flaws cannot be accomplished with inspections based on BMV alone ASupplemental NDE and BMV synergistically increase the effectiveness of each method AThis approach is consistent with the methodology used in Inservice Inspection Programs and ASME to monitor components for service related failures Rockville, MD August 23, 2002

CONCLUSIONS ATesting frequencies can be evaluated after sufficient data exists to warrant change AThe example supplemental inspection in the bulletin is not definitive

• Other NDE techniques that are effective when used in conjunction with each other should be discussed and technically justified by the licensee Rockville, MD August 23, 2002

Overview of Plans for Vessel Head and Nozzle

'44ýx, Inspection Regulations SPresenter:

Michael Marshall, 301-415-2734 "A"

• Auaust 23. 2002

.... us 23 2002t..

Main Aspects of NRC Plans

" Issue Bulletin - Request Information on Supplemental z Inspections and Justification for Current Inspection Practice

" Additional Regulatory Action IfWarranted

" Request Changes to ASME Section XI - Address Deficiencies in Inspection Requirements

" Inspection Methods

" Acceptance Criteria

" Revise 10CFR55.55a -Revised Inspection Requirements 7*...7 Rcckville, MD August 23, 2002

Other Aspects of NRC Plans Near-Term

" Formally Review MRP Proposed Inspection Plan

• Waiting for Complete Submittal

" NRC has not found proposed plan acceptable "

• Formally Review MRP Crack Growth Rate Report

" Received Report This Week Long-Term

" Review Planned Changes to ASME Code Requirements

• Develop Alternate Inspection Plan/Requirements Based on Current State of Uncertainty m.......

Rockville, MD August23, 2002

Flow Chart of NRC Plans RockviAle, MD August 23, 2002

Proactive Actions Needed To Address Issues

" Industry needs to provide adequate technical justification to reduce necessary reliance on supplemental non-visual examinations "New heads with Inconel 690 tubes will have to follow the same inspection criteria as head with Inconel 600 until industry provides technical basis for changes Rockville, MD August 23, 2002