ML043240187
| ML043240187 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/16/2004 |
| From: | Archie J South Carolina Electric & Gas Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BL-04-001, RC-04-0185 | |
| Download: ML043240187 (9) | |
Text
A SCANA COMPANY Jeffrey B. Archie Vice President, Nuclear Operations 803.345.4214 November 16, 2004 RC-04-01 85 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Dear Sir/Madam:
Subject:
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)
DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 RESPONSE TO NRC BULLETIN 2004-01 INSPECTION OF ALLOY 82/182/600 MATERIALS USED IN THE FABRICATION OF PRESSURIZER PENETRATIONS AND STEAM SPACE CONNECTIONS AT PRESSURIZED-WATER REACTORS
- 1. Stephen A. Byrne letter to document Control Desk, RC-04-0100, June 11, 2004
Reference:
- 2. Stephen A. Byme letter to document Control Desk, RC-04-0113, July 26, 2004 On May 28, 2004, the U.S. Nuclear Regulatory Commission (NRC) issued NRC Bulletin 2004-01 to request that utilities provide information regarding Alloy 82/182/600 materials used in the fabrication of pressurizer penetrations and steam space piping connections at their plants.
Information was requested related to the materials, the methods of inspection and repair, and individual inspection schedules.
Licensees were requested to provide a response within 60 days of issuance of the bulletin. If a licensee could not provide the information or could not meet the requested completion date, they were required to submit a written response indicating this within 15 days of the date of the bulletin.
South Carolina Electric & Gas Company (SCE&G) determined that all necessary actions to provide the requested information for VCSNS could not be achieved within 60 days; therefore, a letter was submitted on June 11, 2004 (Reference 1) to address the 15-day response action required by the bulletin.
Subsequent to the referenced submittal during a telephone discussion between the VCSNS NRC Project Manager, NRC reviewer, and SCE&G, the NRC directed that SCE&G submit an interim response providing available-VCSNS information in regards to the Bulletin items. This interim response (Reference 2) provided the available inspection information. As noted by the referenced response, SCE&G identified the intent to provide a full response to the bulletin by November 17, 2004.
The attached provides the complete response to the bulletin.
-A(I 0 SCE&G I Virgil C Summer Nuclear Slation
- P.O. Box BB*.Jenkinsville, South (arolina 29065.T (803)345.5209 w.anasona.com
- Document Control Desk Letter O-C-04-1 719 RC-04-01 85 Page 2 of 2 Should you have questions, please call Mr. Ron Clary at (803) 345-4757.
I certify under penalty of perjury that the foregoing is true and correct.
Executed on JeffreyB. Archie
//,/ice President, Nuclear Operations JT/JBA/mb c:
N. 0. Lorick S. A. Byme N. S. Cams T. G. Eppink R. J. White W. D. Travers K. R Cotton NRC Resident Inspector K. M. Sutton NSRC RTS (0-C-04-1719)
File (815.02)
DMS (RC-04-0185)
Document Control Desk Letter Attachment
/
0-C-04-1719 RC-04-01 85 Page 1 of 7 SCE&G (
RESPONSE TO USNRC BUL\\.ETIN 2004-001 FOR V.C. SUMMER NUCLEAR STATION (VCSNS)
Requested Information from Bulletin 2004-001 issued ay 28, 2004:
(1) All subject PWR licensees are requeste provi e the following information within 60 days of the date of this bulletin.
(a) A description of the pressurizer penetrations and steam space piping connections at your plant.
At a minimum, this des ription should include materials of construction (e.g.,
stainless steel pipi and/or weld
- metal, Alloy 600 piping/sleeves, Alloy 821182 weld metal or bu enng, etc.), joint design (e.g., partial penetration welds, full penetration welds, bolted connections, etc.), and, in the case of welded joints, whether or not the weld was stress-relieved prior to being put into service.
Additional information relevant with respect to determining the susceptibility of your plant's pressurizer penetrations and steam space piping connections to PWSCC should also be included.
RESPONSE (1)(a):
The requested information is provided below. The components and relevant information are provided as requested.
The following notes apply:
N/A designates "not applicable."
All units given in table are in inches unless specified otherwise.
All notations of Inconel "x/y" indicate that the connection was first tack welded with Inconel Xx" and then welded with Inconel My."
All notations of SS 309/308 indicate that the connection was welded with stainless steel 308, 308L, 309, or 309L or some combination
Document Control Desk Letter Attachment O-C-04-1 719 RC-04-01 85 Page 2 of 7 i::V. C. Summer Unit i Pressurizer Penetrations -_____
- iStress, Susceptible Penetration Mteras Joint Design Reliee
?
Yes No Nozzle: Low Alloy Steel Forging Yes Inconel Not SA-508 Class 2a, Inconel 182 N/A (cladding wetted buttering, SS 309/308 cladding buttering)
Weld Nozzle to Safe-end: Inconel Full penetration No No 82/182 butt weld woIoetted t
Safe-end: SS ASME SA-182, NANASaNles Grade 316L Forging N/A NtA Stanless Thermal Sleeve: ASME SA-213 No Grade TP-304 SS Seamless N/A N/A Stainless 4" Spray Nozzle Tubing (qty-1)
Yes 450, 0.12 bevel Thermal Sleeve to Safe-End Weld:
groove partial No Inconef 82 penetration butt weld 450 around Liner: ASME SA-213 Grade TP-NA/ASaNles 304 SS Seamless Tubing N/A NA SaNSeel
- 300,
.12 flletYes Liner to safe end Weld: Inconel 82 3°, 0.12 fillet No Liner to cladding Weld: SS 0.12 x 0.31 fillet Nl 309/308 weld all around No Steel filler Yes No 6" Safety Nozzle: Low Alloy Steel Forging Yes Inconel Not a
qty SA-508 Class 2a, SS 309/308 N/A (cladding wetted oze (qty cladding, Inconel 182 buttering buttering)
Weld Nozzle to Safe-end: Inconel Full penetration No Inone Not 82/182 butt weld woIoetted t
Safe-end: SS ASME SA-182, N/A NA Stainles Grade 316L Forging NANAStaneel Liner: ASME SA-213 Grade TP-No 304 SS Seamless Tubing NIA NA Steel
Document Control Desk Letter Attachment 0-C-04-1719 RC-04-01 85 Page 3 of 7 l;!~'~
V. xC.Summer Unit 1 Pressurizer Penetrations-.
-: i --
Pentrtin atrils--Stress
~Susceptible'
~
laten Jo-9
.44
.Relieved?
to PWSCC?
- 300,
.12 flletYes Liner to safe end Weld: Inconel 82 3w0, 0.12 fillet No Liner to cladding Weld: SS 0.12 x 0.31 fillet No 309/308 weld all around No Stainless
________Steel filler Yes No Nozzle: Low Alloy Steel Forging (claddin Inconel Not SA-508 Class 2a, SS 309/308 N/A and wetted cladding, Inconel 182 buttering buttering)
Weld Nozzle to Safe-end: Inconel Full penetration No 82/182 butt weld No wetted Safeend SSASMESA-82,No 6" Relief Nozzle Sae 5 ASME SA-182, N/A N/A Stainless (qty. 1)
Gae36Fogn_____Steel Liner: ASME SA-213 Grade TP-No 304 SS Seamless Tubing N/ANA Stainless Liner to safe end Weld: Inconel 82 30, 0.12 fillet sNo Liner to cladding Weld: SFA SS 0.12 x 0.31 fillet No 309/308 weld all around No Stainless Heater: SS: SA-213, Grade TP 316 N/A N/A Stainless tubing
_Steel Heater Adaptor: SS SA-1 82, Grade NA/ASaNles F316 Forging N/A N/A NstDee Adapter to Heater Element Weld:
0.19 fillet weld all No Heater SS 309/308 around No Stainless PenetrtionsSteel filler (qty. 78)
Heater Well to Adapter Weld: SS 0.19 fillet weld all No 78)38arud oStainless 309/08 aoundSteel filler 0.19 radius partial Stainless Heater Well to Lower Head penetration JwSteel filler Cladding Weld: SS 309/308 groove butt weld No weld all around
Document Control Desk Letter Attachment 0-C-04-1719 RC-04-01 85 Page 4 of 7 V. C. Summer Unit 1 Pressurizer Penetrations-h',
, -I-
..t
- aPeneratitn M
ia Joint JDesign SusceptibeR Re61ieved?~ to' WSCC?
Tubing: SS ASME SA-213, Grade N/A N/A Stainless TP 316 Tubing NANAStaneel Coupling: SS ASME SA-182, N/AN/A Stainless Grade F316 Forging NANAStaneel Level &
0.19 radius partial Stainless Temperature Pipe to Lower Head Assy.
penetration J-Steel filler Instrumentation Cladding Weld: SS 309/308 and 0.12 efillet weld all around Partial No Pipe penetration J-N Stainless Pie oCopin Wl: Sgroove butt weld No Steel filler 3091308 and fillet weld all around No Forging: Low Alloy Steel Forging N/AN/rSeeow SA-508 Class 2a NA NIA Stail sw Steel Clad Manway (qty. 1) Insert: SS, ASME 21-240, Type NNA N/A Stle 304. Plate NANAStaneel No Cover: MN-MO St. Plate - SA-533 N/A NIA Carbon Gr. A Cl.1 Steel, not I wetted (b)
A description of the inspection program for Alloy 821182/600 pressurizer penetrations and steam space piping connections that has been implemented at your plant. The description should include when the inspections were performed; the areas, penetrations and steam space piping connections inspected; the extent (percentage) of coverage achieved for each location which was inspected; the inspection methods used; the process used to resolve any inspection findings; the quality of the documentation of the inspections (e.g., written report, video record, photographs); and, the basis for concluding that your plant satisfies applicable regulatory requirements related to the integrity of pressurizer penetrations and steam space piping connections.
If leaking pressurizer penetrations or steam space piping connections were found, indicate what followup NDE was performed to characterize flaws in the leaking penetrations.
Document Control Desk Letter Attachment O-C-04-1 719 RC-04-01 85 Page 5 of 7 RESPONSE (1)(b):
The inspection program implemented at VCSNS consists of the following entities:
- 1. ASME Section Xl ISI examinations have been conducted, including those volumetric, surface, and visual examinations addressed via the ASME Code. The ASME Code ISI volumetric and surface examinations conducted, for the components addressed in the referenced bulletin, are as follows with exceptions or limitations to coverage noted:
COMPONENT A' PRESS. SAFETY A' PRESS. SAFETY A' PRESS. SAFETY A' PRESS. SAFETY B' PRESS. SAFETY B' PRESS. SAFETY B' PRESS. SAFETY B' PRESS. SAFETY C' PRESS. SAFETY C' PRESS. SAFETY C' PRESS. SAFETY C' PRESS. SAFETY PRESS. RELIEF PRESS. RELIEF PRESS. RELIEF PRESS. RELIEF PRESS. SPRAY PRESS. SPRAY PRESS. SPRAY PRESS. SPRAY PRESS. SPRAY PRESS. SPRAY PRESS. SPRAY WELD ID 4501-1 DM 4501-1DM 4501-1DM 4501-1 DM 4501 -12DM 4501-12DM 4501-12DM 4501-12DM 4501 -23DM 4501 -23DM 4501-23DM 4501 -23DM 4502-1DM 4502-1DM 4502-1DM 4502-1 DM 4503-46DM 4503-46DM 4503-46DM 4503-46DM 4503-46DM 4503-46DM 4503-46DM RFO RF 6 RF 6 RF 8 RF 8 RF 6 RF 6 RF 8 RF 8 RF 6 RF 6 RF 8 RF 8 RF 2 RF 2 RF 8 RF 8 RF 2 RF 2 RF 5 RF 5 RF 8 RF1 I RF1 I METHOD PT UT PT UT PT UT PT UT PT UT PT UT PT UT PT UT PT UT PT UT PT PT UT RESULTS NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI NRI EXAM. COVERAGE 100% one sided exam 100% one sided exam 100% one sided exam 100% one sided exam 100% one sided exam 100% one sided exam 100% one sided exam 100% one sided exam 100% one sided exam 100% one sided exam 90.38% one sided exam RF-2-Spring 1984, RF-5-Spring 1990, RF-6-Fall 1991, RF-8-Fall 1994, RF-11-Spring 1999 NRI-No Recordable Indications In addition to the volumetric and surface examinations addressed above, the VCSNS conducts the VT-2 examinations addressed by ASME Section XI each outage.
Document Control Desk Letter Attachment 0-C-04-1719 RC-04-01 85 Page 6 of 7
- 2. Bare Metal Visual (BMV) Examinations, as addressed in MRP Letter 2003-039 and as directed by MRP Letter 2004-05, were performed on the Pressurizer Safety, Pressurizer Relief, and Pressurizer Spray lines during our Fall 2003 refueling outage. These visual inspections encompassed 100% of the weld and surrounding areas.
The above listed examinations are documented in appropriate written reports, which are archived as station records. The examinations have not revealed any discontinuities or flaws that have required evaluation, analysis, repair or replacement. There have been no leaks detected via the above examinations therefore there has been no basis to perform follow-up examinations. SCE&G has completed the required Code examinations as well as BMV's of the dissimilar metal butt welds, addressed by this bulletin, that we are currently knowledgeable of and have not identified any pressure boundary leakage.
(c)
A description of the Alloy 8211821600 pressurizer penetration and steam space piping connection inspection program that will be implemented at your plant during the next and subsequent refueling outages.
The description should include the areas, penetrations and steam space piping connections to be inspected; the extent (percentage) of coverage to be achieved for each location; inspection methods to be used; qualification standards for the inspection methods and personnel; the process used to resolve any inspection indications; the inspection documentation to be generated; and the basis for concluding that your plant will satisfy applicable regulatory requirements related to the structural and leakage integrity of pressurizer penetrations and steam space piping connections.
If leaking pressurizer penetrations or steam space piping connections are found, indicate what follow-up NDE will be performed to characterize flaws in the leaking penetrations.
Provide your plans for expansion of the scope of NDE to be performed if circumferential flaws are found in any portion of the leaking pressurizer penetrations or steam space piping connections.
RESPONSE (1)(c):
Bare Metal Visual (BMV) Examinations, as addressed in MRP Letter 2003-039 and as directed by MRP Letter 2004-05, will be performed on the Pressurizer Safety, Pressurizer Relief, and Pressurizer Spray lines during our Spring 2005 refueling outage (RF-15).
These visual inspections will encompass 100% of the weld and surrounding areas. VCSNS intends to profile these locations in RF-15.
Any indications identified via these BMV inspections will be addressed through the VCSNS corrective action program.
Should these BMV inspections reveal the potential for leakage at a penetration, VCSNS will conduct surface examinations as well as analysis of the residue to confirm the source of the leakage.
It is expected that the nozzle configurations for these weldments will not lend themselves to the performance of a fully qualified Appendix Vil volumetric examination. However, If leakage is confirmed VSCNS will conduct volumetric examination using a qualified Appendix Vill process to the extent possible and/or a best effort volumetric using ultrasonic in combination with
Document Control Desk Letter Attachment 0-C-04-1719 RC-04-01 85 Page 7of7 radiography to characterize the indication.
Scope expansion will be performed to the requirements of the ASME Code.
Although it is highly unlikely, based on the current knowledge of PWSCC cracking in this type weldment, that a circumferential flaw would be identified, VCSNS would expand the examination scope to all Alloy 600/82/182 butt welds having like design and operating parameters. As a minimum the future inspections and all associated activities will meet or exceed those required by the ASME Code or other regulation in effect at the time, to the extent possible using the technology available at the time.
(d) In light of the information discussed in this bulletin and your understanding of the relevance of recent industry operating experience to your facility, explain why the inspection program identified in your response to item (1)(c) above is adequate for the purpose of maintaining the integrity of your facility's RCPB and for meeting all applicable regulatory requirements which pertain to your facility.
RESPONSE (1)(d):
The inspection results provided in the response to item (1 )(b) gives assurance that the welds in question are currently structurally sound.
Additionally, the pressurizer heater sleeves at VCSNS are stainless steel and are not susceptible the type of corrosion mechanism discussed in the bulletin.
The EPRI MRP is currently developing inspection and evaluation guidance for all Alloy 600 butt weld locations in the primary system. VCSNS will evaluate recommendations and guidance from EPRI and various other industry groups for applicability to our welds. We will determine the extent of and optimum examination methodologies from this information and employ it as appropriate to assure continued integrity of these primary system butt welds. In the interim VCSNS will continue to perform BMV inspection, of the weldments addressed via this bulletin, each outage.
Performance of these BMV inspections as well as future compliance with industry initiatives and all codes and regulations will provide continued confidence that the integrity of the reactor coolant pressure boundary at VCSNS is preserved.