ML17156B185
| ML17156B185 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/31/1989 |
| From: | Thadani M Office of Nuclear Reactor Regulation |
| To: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| GL-88-01, GL-88-1, NUDOCS 8906060186 | |
| Download: ML17156B185 (13) | |
Text
May 31, 1989 Docket Nos. 50-387/388 Mr. Harold W. Keiser Senior Vice President-Nuclear Pennsylvania Power and Light Company 2 North Ninth Street A1 1 entown, Pennsy1 vani a 18101
Dear Mr. Keiser:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - RESPONSE TO GENERIC LETTER 88-01 (TAC NOS. 69158/69159)
RE:
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1
AND 2 Our contractor, Viking Systems International, and the staff are reviewing your response to Generic Letter (GL) 88-01 related to the NRC position on intergranular stress corrosion cracking (IGSCC) in BWR austenic stainless steel piping.
Additional information is required to assist the staff in timely completion of our review.
Our general questions/requests are enclosed as Attachment A.
We consider the resolution of our request and completion of our review of your response to GL 88-01 to be of high priority, and request your response within sixty days from the receipt of this letter.
Please forward a copy of your response to our contractor at the following address.
Dr. Armand Lakner, Director Safety II Reliability Viking Systems International 101 Chestnut Street Gaithersburg, MD 10877 If you have any questions please contact me at (301) 492-1427.
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Enclosure:
List of questions/Requests
/s/
Mohan C. Thadani, Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation cc w/enclosure:
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UNITED STATES t NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 May 31, 1989 Docket Nos. 50-387/388 Mr. Harold H. Keiser Senior Vice President-Nuclear Pennsylvania Power and Light Company P North Ninth Street Allentown, Pennsylvania 18101
Dear Mr. Keiser:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - RESPONSE TO GENERIC LETTER 88-01 (TAC NOS. 69158/69159)
RE:
SUSQUEHANNA STEAM ELECTRIC STATION, UINITS I AND 2 Our contractor, Viking Systems International, and the staff are reviewing your response to Generic Letter (GL) 88-01 related to the NRC position on intergranular stress corrosion cracking (IGSCC) in BIIR austenic stainless steel piping.
Additional information is required to assist the staff in timely completion of our review.
Our general questions/requests are enclosed as Attachment A.
Me consider the resolution of our request and completion of our review of your response to GL 88-01 to be of high priority, and request your response within sixty days from the receipt of this letter.
Please forward a copy of your response to our contractor at the following address.
Dr. Armand Lakner, Director Safety It Reliability Viking Systems International 101 Chestnut Street Gaithersburg, MD 20877 If you have any questions please contact me at (301) 492-1427.
Sincer ely,
Enclosure:
List of Questions/Requests cc w/enclosure:
See next page Mohan C. Thadani, Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Mr. Harold W. Keiser Pennsylvania Power 5 Light Company Susquehanna Steam Electric Station Units 1
& 2 CC:
Jay Si lberg, Esq.
Shaw, Pittman, Potts 5 Trowbridge 2300 N Street N.W.
Washington, D.C.
20037 Bryan A. Snapp, Esq.
Assistant Corporate Counsel Pennsylvania Power 5 Light Company 2 North Ninth Street Al 1 entown, Penn sy 1 vani a 18101 Mr. E. A. Heckman Licensing Group Supervisor Pennsylvania Power 5 Light Company
" 2 North Ninth Street Al1entown, Pennsylvania 18101 Mr. S. Barber Resident Inspector U. S. Nuclear Regulatory Commission P.O.
Box 35 Berwick, Pennsylvania l8603-0035 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Resources Commonwealth of Pennsylvania P. 0.
Box 2063 Harrisburg, Pennsylvania 17120 Mr. Jesse C. Tilton, III Allegheny Elec. Coorperative, Inc.
212 Locust Street P.O.
Box 1266 Harrisburg, Pennsy 1 vania 17108-1266 Mr.
W. H. Hirst, Manager Joint Generation Projects Department Atlantic Electric P.O.
Box 1500 1199 Black Horse Pike Pleasantvi lie, New Jersey 08232 Regional Admini s tra tor, Region I U.S. Nuclear Regulatory Commission 475 Al1enda le Road King of Prussia, Pennsylvania 19406
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 thi,s 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 I.
Table 1
Responses to NRC Staff Positions Staff Position Licensee Res onse+
Accept Requests with Alternate
~Aces t Provisions Position Licensee Has/Will~
Applied Consider for in Past Future Use
- 1. Materials
- 2. Processes
- 3. Water Chemistry 4.
- 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 Answer with "yes", "check mark" or "X" in appropriate column for each of the 13 NRC Staff Positions.
List and explain each provision and/or alternate position (or reference original submittal if it contains the listing and explanation).
Use separate page(s) if needed.
++ Answer with "yes" or "no", as appropriate, in each column for each of 13 NRC Staff Positions.
ATTACHMENT A (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."
"An Inservice Inspection Program to be implemented at the next refueling outage for austenitic 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 well as the Inservice Inspection Program provided in most of the licensee submittals were either incomplete or did not provide the background data that is needed to evaluate the ISI Program such as (1) reasons/justification for IGSCC i
classification of welds, (2) methods, personnel qualification, schedules and identities of welds inspected, and (3) results of previous inspections, and/or identities of welds to be inspected during future inspections.
- Thus, the following information is requested:
1.
A listing of all welds by system, pipe size, configuration (e.g.,
pipe to elbow, pipe to valve, etc.),
drawing number (piping ISO with weld I.D.), location (i.e., inside or outside of containment, etc.),
weld I.D. number, and IGSCC classification (i.e.,
IGSCC Category A, B, C, D, E, F and G).
- 2. Reason/justification for the classification of each weld, using such information as (a) weld history such as heat sink welding (HSW), (b) pipe and weld metal compositions or material identities to show either conforming material or non-conforming material, (c) mitigating treatment(s) applied such as solution heat treating (SHT), stress improvement (IHSI or HSIP).
- 3. Identity of welds to be inspected during past and future refueling outage.
Include (a) dates and results of previous inspections, (b) flaw characteristics including orientation (axial or circumferential),
maximum length, maximum depth, repairs and/or mitigating treatments applied.
Please supply this information in tabular form using formats such as that illustrated in Tables 2 and 3.
A-3
Table 2 History of Welds and Prior Hitigating Actions/Treatments+
Material++
Casting Treatment+~
Notes:
List each weld se gretel
, using one or more lines as required.
For material: identify as non-conforming 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 (HSM), corrosion resistant clad (CRC),
stress improved (SI), or overlayed (O.L.).
For SI, add explanation of method used, i.e., vhether by induction heating or mechanical, whether pre and/or post treatment inspection was applied using methods and personnel qualified under NRC/EPRI/BWROG coordination plan, and whether treatment was applied vithin two years of service date.
Also add explanation and justification of any overlays that were not standard (per NRC Staff position).
Table 3 Inspection Schedules Ins ected/To Be Ins ected/Flaws Found IGSCC Weld Dia.
Past Future Instructions:
- l. Under the heading, "Inspected/To BE Inspected,"
use as many columns as required to describe the following:
(a) All previous inspections that were conducted (per NUREG 0313, Revision 2, page 5.2) using methods and personnel qualified under NRC/EPRI/BWROG coordination plan as upgraded in September, 1985.
Jlus (b)
A sufficient number of future inspections to demonstrate that the schedules will follow 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) vith actual refueling outage numbers.
Indicate dates inspections vere/vill be performed.
- 3. List each veld vithin 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 weld was inspected or vill be inspected.
- 5. Indicate vith "yes" under column marked "flaw" if a flaw indication vas found.
Attach a statement for each flaved weld giving the orientation (axial or circumferential),
the dimensions (maximum length and depth),
and describing any repairs made.
ATZACHMENT A (continued)
Item 3. Welds Covered in Licensee Submittal Generic Letter 88-01 (on page
- 2) states:
"This Generic Letter applies to all BWR piping made of austenitic stainless steel that is four inches or larger in nominal 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 jet pump instrumentation penetration assemblies and head spray and vent components."
Were any velds that fall vithin this defined scope excluded from the licensee submittal (for example, welds in the RWCU outboard of the isolation valves)7 If previously excluded, please list identity of such velds and plans for mitigation and inspections in Tables 2 and 3 or provide alternative proposal. If IGSCC susceptible welds vere excluded from the licensee submittal based on temperature considerations please identify the welds and describe in detail the method of temperature measurements.
Item 4. Welds that Are Not UT Ins ectable Generic Letter 88-01 (in Table 1) states:
"Welds 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) All velds that are inaccessible for UT inspections7 (b) All velds that are only partially accessible for UT inspections?
(c) Welds that cannot be UT inspected because of geometrical constraints or other reasons.
If not, please list these welds and plans for mitigation/inspection.
Item 5. Leaka e Detection Generic Letter 88-01 states on page 3:
"Confirmation of you plans to ensure that the Technical
ATTACHMENT A (continued)
Specification related to leakage detection will be in conformance with 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 following items:
- 1. Leakage detection should be in conformance with 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 corrective action when:
(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 gpm or equivalent.
- 3. Leakage should be monitored (or determined from flow 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 with operations of monitoring systems or not to be from a throughwall crack.
- 5. For plants operating with any IGSCC Category D, E, F, or G
welds, at least one of the leakage measurement instruments associated with 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 shutdown.
Although most licensee submittals describe the intention of meeting some or all of these requirements or offer alternative measures, it is not always clear whether 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.
Table 4 Licensee Positions on Leakage Detection Position Already TS will be Alternate Contained Changed Position 1n TS to Inc1ode
~Pro osed
- 1. Conforms with Position C of Regulatory Guide 1.45
- 2. Plant shutdown should be initiated when:
(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 with monitoring systems, or not from throughwall crack.
- 5. Provisions for shutdown within 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 welds.
Instructions:
Place "X" or "yes" under appropriate column for each item.
Provide description and justification for alternative positions if not air'eady provided.
A - 8
ATTACHMENT B REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO SUSQUEHANNA, UNITS 1 AND 2 Item 1. Inservice Ins ection and Miti atin Treatments In responding to Item 1 of Attachment A, please note that the following information pertaining to Crack Characterization and Repair Criteria is needed:
(a) The reason(s) why an equation is used for non-IHSI treated welds that gives about 20X lower crack growth rate than that used for IHSI treated welds.
(b) The reason(s) why a linear distribution for residual stress is assumed for non-IHSI welds for which t <
1 inch.
(c) The residual stress distribution that is used for IHSI treated welds.
Item 2. Inservice Ins ection and Miti atin Treatments In responding to Item 2 of Attachment A:
(a) Please include the welds that contain Inconel 182 and Inconel 600.
(b) Please include information pertaining to post-IHSI inspections, including which welds were inspected, methods and personnel, and results.
page B 1