ML17056A059

Forwards Request for Addl Info Re Util 880722 Response to Generic Ltr 88-01 Covering Pipe Replacement & Other Measures to Mitigate Igscc.Response Requested within 60 Days

ML17056A059
Person / Time
Site:	Nine Mile Point
Issue date:	06/16/1989
From:	Slosson M Office of Nuclear Reactor Regulation
To:	Burkhardt L NIAGARA MOHAWK POWER CORP.
References
GL-88-01, GL-88-1, TAC-69147, TAC-69148, NUDOCS 8906220158
Download: ML17056A059 (22)

Text

June 16, 1989 Docket Nos. 50-220 and 50-410 Hr. Lawrence Bur khardt III Executive Vice President, Nuclear Operation Niagara Mohawk Power Corporation 301 Plainfield Road

Syracuse, New York 13212 DISTRIBUTION, NRC 8 Local PDRs PDI-1 Rdg SVarga BBoger CVogan RCapra OGC EJordan BGr imes ACRS (10)

JJohnson HSlos son

SUBJECT:

NINE MILE POINT UNIT NOS.

1 AND 2, GENERIC LETTER 88-01 RESPONSE-REgUEST FOR ADDITIONAL INFORMATION (TAC NOS.

69147 AND 69148)

By letters dated July 22, 1988 Niagara Mohawk Power Corporation responded to Generic Letter 88-01 for Nine Mile Point Unit Nos.

1 and 2.

The staff is currently reviewing your responses.

However, additional information is required to assist in our review.

Therefore, you are requested to complete the enclosed request for additional information for each unit within 60 days.

In addition to sending your response to the NRC, we request that you send a copy to our contractor at the following address:

Dr. Armand A. Lakner, Director Safety and Reliability Viking Systems Internation 101 Chestnut Street Gaithersburg, Maryland 20877 S incere ly, Original signed by 890622015S S90626 t

PDR ADOCK 05000220 P

PDC

Enclosure:

As stated cc w/enclosure:

See attached list

)GL88-01 ADD INFO 69147 5 69148]

Harylee H. Slosson, Project Manager Project Directorate I-1 Division of Reactor Projects I/II NAME :CVogan

HSlosson bah:

DATE:6/'i(/89:6/

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Mr. Lawrence Bur k t III

'Niagara Mohawk Pow r Corporation Nine H Point 1/2 CC:

Mr. Troy B. Conner, Jr., Esquire Conner

& Wetterhahn Suite 1050 1747 Pennsylvania

Avenue, N.W.

Washington, DC 20006 Mr. Kim Dahlberg Unit I Station Superintendent Nine Mile Point fluclear Station Post Office Box 32

Lycoming, New York 13093 Hr. Frank R. Church, Supervisor Town of Scriba R. D. P2

Oswego, New York 13126 Mr. Richard Abbott Unit 2 Station Superintendent Nine Mile Point Nuclear Station Post Office Box 32

Lycoming, New York 13093

.Mr. James L. Willis General Supt.-Nuclear Generation Niagara Mohawk Power Corporation Nine Hile Point Nuclear Station Post Office Box 32

Lycoming, New York 13093 Charlie Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Resident Inspector U. S. Nuclear Regulatory Comnission Post Office Box 126

Lycoming, New York 13093 Mr. Paul D. Eddy State of New Yor k Department of Public Ser vice Power Division, System Operations 3 Empire State Plaza

Albany, New York 12223 Mr. Gary D'. Wilson, Esquire Niagara Mohawk Power Corporation 300 Erie Boulevard West

Syracuse, New York 13202 Mr. Peter E. Francisco, Licensing Niagara Mohawk Power Corporation 301 Plainfield Road

Syracuse, New York 13212 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. Richard Goldsmith Syracuse University College of Law E. I. White Halle Campus

Syracuse, New York 12223 Ms. Donna Ross New York State Energy Office 2 Empire State Plaza 16th Floor

Albany, New York 12223 Mr. Richard M. Kessel Chair and Executive Director State Consumer Protection Board 99 Washington Avenue

Albany, New York 12210

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ATTACHMENT A GENERAL QUESTIONS/REQUESTS Reviews of several licensee submittals has shown that most (although not all) of the submittals commonly lack certain information that is needed for evaluation of the submittals.

Thus, this general list of questions and requests has been prepared for submission to each of the licensees.

For those portions of this attachment for which the requested information was supplied (in the detail requested herein) in the original submittal, the utilities may reference the relevant pages or tables in the original submittal and supply only the requested information that was not provided.

Please certify that you comply with NRC Staff positions in Generic Letter 88-01, or identify and justify any deviations taken.

Item 1. Position on NRC Staff Positions Generic Letter 88-01 states on page 3:

"Pursuant to 10 CFR 50.54(f), you, as a BWR operating reactor licensee or construction permit holder, are requested to furnish, under oath or affirmation, your current plans relating to piping replacement, inspection, repair, and leakage detection.

Your response should indicate whether you intend to follow the staff positions included in this letter, or propose alternative measures."

The staff positions outlined in Generic Letter 88-01 include positions on: (1) Materials.

(2) Processes.

(3) Water Chemistry.

(4) Weld Overlay. (5) Partial Replacement.

(6) Stress Improvement of Cracked Weldments.

(7) Clamping Devices.

(8) Crack Evaluation and Repair Criteria.

(9) Inspection Method and Personnel.

(10) Inspection Schedules.

(11) Sample Expansion.

(12) Leak Detection.

(13)

Reporting Requirements.

Please supply information concerning whether the licensee:

(1) endorses these positions, (2) proposes alternate positions, exceptions, or provisions, and (3) is considering or planning to apply them in the future.

Please describe any alternate positions, exceptions, or provisions that are proposed.

Please supply this information using a table such as that illustrated in the example shown in Table 1.

Table 1

Responses to NRC Staff Positions Staff Position

1. Materials

2. Processes Licensee Res nse+

hccept Requests vith hlternate

~aces t Provisions Position Licensee Has Vill++

hpplied Consider for in Past Future Use

3. Water Chemistry

4. Veld Overlay

5. Partial Replacement

6. Stress Improvement of Cracked Veldments

7. Clamping Devices

8. Crack Evaluation and Repair Criteria

9. Inspection Method and Personnel

10. Inspection Schedules 11.

Sample Expansion

12. Leak Detection

13. Reporting Requirements hnsver vt.th "yes" ~ "check mark" or "I" in appropriate column for each of the 13 NRC Staff Positions.

List and explain each provision and/or alternate position (or reference original submittal ifit contains the listing and explanation)

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Use separate page(s) if needed.

~ hnswer with "yes" or "no", as appropriate, in each column for each of 13 NRC Staff Positions.

h - 2

hTZhCHMENT h (continued)

Item 2. Inservice Ins ection Pro ram Generic Letter 88-01 requests on page 3:

"Your current plans regarding pipe replacement and/or other measures taken or to be taken to mitigate IGSCC and provide assurance of continued long-term integrity and reliability."

"hn Inservice Inspection Program to be implemented at the next refueling outage for auetenitic stainless steel piping covered under the scope of this letter that conforms to the staff

,positions on inspection schedules methods and personnel, and sample expansion included in this letter."

The information pertaining to the pipe replacement and other mitigating actions as vali as the Inservice Inspection Program provided in most of the licensee submittals vere either incomplete or did not provide the background date that is needed to evaluate the ISI Program such as (1) reasons/justification for IGSCC classification of velds, (2) methods, personnel qualification, schedules and identities of velds inspected, and (3) results of previous inspections, and/or identities of velds to be inspected during future inspections.

Thus, the folloving information is requested:

I. h listing of all velds by system, pipe size, configuration (e.g., pipe to elbov, pipe to valve, et@.), draving number (piping ISO vith veld I.D.), location (i.e., inside or outside of containment, ctc.), veld I.D. number, and IGSCC classification (i.e.,

IGSCC Category h, B, C, D, E, F and G).

2. Reason/Justification for the classification of each veld, using such information as (a) veld history such ae heat sink velding (HSW), (b) pipe and veld metal compositions or material identities to shov either conforming material or non-conforming material, (c) mitigating treatment(s) applied such as solution heat treating (SHT), stress improvement (IHSI or MSIP).

3. Identity of velds to be inspected during past and future refueling outage.

Include (a) dates and results of previous inspections,-(b) flav characteristics including orientation (axial or circumferential),

mhximum length, maximum depth, repairs and/or mitigating treatments applied.

Please supply this information in tabular form using formats'such

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as that illustrated in Tables 2 and 3.

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Table 2 History of Welds and Prior Mitigating hctions/Treatments+

Material~

IGSCC Weld Dia.

Casting Treatment~

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Notes:

List each veld se aratel

, using one or more lines as required.

For material: identify as nonmonforming or conforming as appropriate concerning vhether it conforms vith the NRC Staff position on resistant materials.

If conforming, identify the material type (e.g.,

Type 316 NG).

~ For treatment: list "X" under appropriate column(s) if veld vas treated using indicated technique, i.e., solution heat treated (SHT), heat sink velded (HSW), corrosion resistant clad (CRC) ~

stress improved (SI), or overlayed (O.L.) ~

For SI,'add explanation of method used, i.e., whether by induction heating or mechanical, whether pre and/or post treatment inspection vas applied using methods and personnel qualified under NRC/EPRI/BWROG coordination plan, and whether treatment vas applied vithin tvo years of service date.

hlso add explanation and Justification of any overlays that vere not standard (per NRC Staff position).

Table 3 Inspection Schedules Ins cted To Be Ins cted Flavs Found IGSCC Weld Dia.

Past Future a'"'nstructions:

l. Under the heading, "Inspected/To BE Inspected,"

use as many coluans as required to describe the folloving:

(a) hll previous inspections that vere conducted (per NUREG 0313, Revision 2, page 5.2) using methods and personnel qualified under NRC/EPRI/BMROG coordination plan as upgraded in September>

1985.

~lus (b) h sufficient number of future inspections to demonstrate that the schedules villfollov the NRC Staff positions as given in Table 1 in Generic Letter 88-01.

2. Replace R.O.f (X-2, X-l, X, X+1) with actual refueling outage numbers.

Indicate dates inspections vere/vill be performed.

3. List, each veld within the scope of Generic Letter 88-01.

4. Place an "X" or other appropriate symbol under the appropriate column for each refueling outage for which that, veld vas inspected or vill be inspected.

5. Indicate vith "yes" under column marked "flav" if a flav indication vas found.

httach a statement for each flawed veld giving the orientation (axial or circumferential); the dimensions (maximum length and.depth),

and describing any repairs made.

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hTThCHMENT h (continued)

Item 3. Velds Covered in Licensee Submittal Generic Letter 88-01 (on page 2) states:

"This Generic Letter applies to all BVR piping made of austenitic stainless steel that is four inches or larger in noaLnal diameter and contains reactor coolant at a temperature above 200'F during power operation regardless of Code classification. It also applies to reactor vessel attachments and appurtenances such as 5et pump instrumentation penetration assemblies and head spray and vent components."

Vere any fields that fall within this defined scope excluded from the licensee submittal (for example, zelda in the RRX outboard of the isolation valves)? If previously excluded, please list identity of such fields and plans for mitigation and inspections in Tables 2 and 3 or provide alternative proposal. If IGSCC susceptible fields vere excluded from the licensee submittal based on temperature considerations please identify the velds and describe in detail the method of temperature measurements.

Item 4. Velds that hre Not UT Ins ctable Generic Letter 88-01 (in Table 1) states:

"Velds that are not UT inspectable should be replaced, "sleeved", or local leak detection applied.

RT examination or visual inspection for leakage may also be considered."

Does the licensee submittal include discussions and plans for:

(a) hll +aids that are inaccessible for UT inspections?

(b) hll fields that are only partially accessible for UT inspections?

(c) Velds that cannot be lE inspected because of geometrical constraints or other reasons.

If not, please list these fields and plans for mitigation/inspection.

Item 5. Leaks e Detection Generic Letter 88-01 states on page 3:

"Confirmation of you plans to ensure that the Technical h - 6

hTThCHMENT h (continued)

Specification related to leakage detection vill be in conformance vith the staff position on leak detection included in this letter."

The staff position is outlined on pages 5 and 6 of Generic Letter 88-01 and include the folloving items:

I. Leakage detection should be in conformance vith Position C

of Regulatory Guide 1.45 "Reactor Coolant Pressure Boundary Leakage Detection Systems," or as otherwise approved by the NRC.

2. Plant shutdown should be initiated for correctire action vhen:

(a) within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period any leakage detection system indicates an increase of unidentified leakage in excess of 2 gpm or its equivalent, or (b) the total unidentified leakage attains a rate of 5 gpa or equivalent.

3. Leakage should be monitored (or determined from flov measurements if flow is continuously'monitored) at approximately four hour intervals or less.

4. Unidentified leakage should include all leakage other than (a) leakage into closed systems, or (b) leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere vith operations of monitoring systems or not to be from a throughwall crack.

5. For plants operating vith any IGSCC Category D, E, F, or G welds, at least one of the leakage measurement instruments associated vith each sump shall be operable, and the outage time for inoperable instruments shall be limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or immediately initiate an orderly shutdovn.

hlthough most licensee submittals describe the intention of meeting some or all of these requirements or offer alternative measures,.

it is not alvays clear vhether these requirements are contained in the Technical Specifications.

Thus it is requested that this information should be provided by each licensee.

For clarity and completeness, please use a checklist such as that illustrated in Table 4.

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Table 4 Licensee Positions on Leakage Detection Position

1. Conforms vith Position C of Regulatory Guide 1.45

2. Plant shutdown should be initiated when:

hlready TS vill be hlternate Contained Changed Position dn TS to Include

~Pro need (a) within any period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less, an increase is indicated in the rate of unidentified leakage in excess of 2 gpm, or (b) the total unidentified leakage

.attains a rate of 5 gpm.

3. Leakage monitored at four hour intervals or less.

4. Unidentified leakage includes all except:

(a) leakage into closed systems, or (b) leakage into the containment atmosphere from sources that are located, do not interfere vith monitoring systems, or not from throughvall crack.

5. Provisions for shutdovn vithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to inoperable measurement instruments in plants with Category D, E, F, or G velds.

Instructions:

Place "X" or "yes" under appropriate column for each item.

Provide description and 5ustification for alternative positions. if not already provided.

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ATTACHMENT B REQUEST FOR ADDITIONAL INFORMATION PERTAINING K) NINE MILE POINT, UNITS 1 AND 2 Item 1. Inservice Ins ection and Miti atin Treatments In responding to Item 2 of Attachment A:

(a) Please note that according to Generic Letter 88-01 the existence of Hydrogen Water Treatment may justify reductions in frequency of inspections of IGSCC Category B, C, D, and E weldments (providing that it is operational and judged effective by the NRC Staff), but HWC does not constitute a basis for classification of welds as IGSCC Category A when they would otherwise be classified as IGSCC Category D.

Thus, the welds that were classified as IGSCC Category A on the basis of HWC should be reclassified as IGSCC Category D and scheduled for inspections accordingly.

(b) Please note that both Generic Letter 88-01 and NUREG 0313, Revision 2 specifically state that welds containing crevices are considered non-resistant to IGSCC (and should therefore be included in the Inservice Inspection plan, classified as IGSCC Category G, and scheduled for inspection during the refueling outage).

Thus, please include the welds in Unit 2 that contain crevices even though these welds were judged to be outside of the scope of Generic Letter 88-01.

Item 2. Leaka e Detection in the Technica1 S ecification In responding to Item 2 of Attachment A, please provide clarification of the word "practical" used in the description of compliance with the requirements for leakage detection in the Technical Specification'or Unit 2.

page B 1

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