ML17201Q477
| ML17201Q477 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, 05000000 |
| Issue date: | 05/22/1989 |
| From: | Ross T, Siegel B Office of Nuclear Reactor Regulation |
| To: | Kovach T COMMONWEALTH EDISON CO. |
| References | |
| GL-88-01, GL-88-1, TAC-69133, TAC-69154, TAC-69155, NUDOCS 8905310228 | |
| Download: ML17201Q477 (15) | |
Text
- UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket Nos.
50-249, 50-254 and 50-265 Mr. Thomc.s J. Kovach Nuclear Licensing Manager Convnonw~alth Edison Company Post Office Box 767 Chicago, Illinois 60690
Dear Mr. Kovach:
May 22, 1989
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) PERTAINING TO CECO's RESPONSE TO GENERIC LETTER 88-01 FOR DRESDEN, UNIT 3 (TAC NO. 69133)
AflD QUAD CITIES, UNITS 1 AND 2 (TAC NOS. 69154 AND 69155)
Based on a pr~liminary review of you~ submittals in response to Generic Letter
- 88-01 for Dr~sden 'Unit 3 cmo Quad Cities Units 1 ii.lid 2, the staff and its contractor, Viking Systf:ms Internatior1a l, havti determined that addit iono l information is net::ded to complete these revi.:ws.
The additional informaticin needed is identified in the Enclosure.
Please note that the Enclosure is common to both Dresd~n and Quad Citie~ except for Attachments A and B which are plant specific.
It is requesttd that this 1nformatior1 be provided within 60 days of the date of this l~tter. If you have any questions regQrd1ng this request or schedule, plt:ase call Byron Siegel at (301) 492-3019 for Drescien and Thi~rry Ross at (301) 492-3016 for Quad Cities.
To expedite the review process, it is requested that a copy of your r~spons~
be sent directly to the staff's 'ontractor at the following address:
Dr. Armand A. Lakner Director, Safety and Reliability Viking Systems International 101 Chestnut Street
.Gaithersburg, MD 20877 We acknowledge that this request for additional information could involve reiterating previously submitted material, but 1n a more convenient form for our contract reviewer.
For the sake of efficiency of review, we request your indulgence.
Please r*eview this request carefully to assure that an requested material has been provided and is in the proper format.
- l( 8905310.228 890522 PDR ADOCK *05000249 P
PNU
May 22, 1989* :.
- Mr. Thom*as J. Kovach
- 2 *-
The reporting and/or recordkeeping requirements _contained in this_ 1ette*r affect fewer than ten respondents; therefore, OMB c1earanc~,is pot.-r.eq*u;red t.i'n.der p.L.96-511.
Enclosures:
As stated cc:
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Thie,rry M.,Ros~,*Pr:oaect Manager Prt?je_ct Directorate-,.JII-2' Division of Reacfor Projects III,
. IV, V. and Specia 1 Projects,
Isl Byron L. Siege 1, Project Manager
- Project Directorate III-2
]ivision of Reactor Projects III.-
IV, V, and Special Proj~cts NRC & Local PDRs MVirgilio PDIII-2 r/f EJordan*
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Mr. Thomas The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Enclosures:
As stated cc:
See next page Sincerely, hi erry
- Ross, Project Manager Project Directorate III-2 Division of Reactor Projects III, IV, V, and Special Projects 1~(4,~ject Manager Project Directorate Ill-2 Division of Reactor Projects III, IV, V, and Special Projects
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- ti
Mr. Thomas J*. Kovach Conunonwealth Edison Company cc:
Michael I. Millert Esq.
Sidley and Austin One First National Plaza Chicagot Illinois 60603 Mr. J. Eenigenburg Plant Superintendent Dresden Nuclear Power Station Rural Route #1 Morrist Illinois 60450 U. S. Nuclear Regulatory Conunission Resident Inspectors Office Dresden Station Rural Route #1 Morrist Illinois 60450 Chairman Board of Supervisors of Grundy County Grundy County Courthouse Morrist Illinois 60450 Regional Administrator Nuclear Regulatory Conunission, Region III 799 Roosevelt Road, Bldg. #4 Glen Ellynt Illinois 60137 Mr. Michael E. Parker, Chief Division of Engineering Illinois Department of Nuclear Safety 1035 Outer Park Drive, 5th Floor Springfield, Illinois 62704 Dresden Nucledr Power Station Units 2 and 3
Mr. Thomas J. Kovach Conunonwealth Edison Company cc:
Mr. Stephen E. Shelton Vice President Iowa-Illinois Gas and Electric Company P. O. Box 4350 Davenport, Iowa 52808 Michael I. Miller, Esq.
Sidley and Austin One First National Plaza Chicago, Illinois 60603 Mr. Richard Bax Station Manager Quad Cities Nuclear Power Station 22710 206th Avenue North Cordova, Illinois 61242 Resident Inspector U. S. Nuclear Regulatory Commission 22712 206th Avenue North Cordova, Illinois 61242 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.
Rock Island, Illinois 61201 Mr. Michael E. Parker, Chief Division of Engineering Illinois Department of Nuclear Safety 1035 Outer Park Drive, Springfield, Illinois 62704 Regional Administrator, Region III U. S. Nuclear Regulatory Conunission 799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137 Quad Cities Nuclear Power Station Units 1 and 2
ENCLOSURE GENERAL QUESTIONS/REQUESTS Rev;ews of several licensee submittals has shown that most (although not all) of the submittals corrrnonly lack certa;n information that is needed for evaluation of the subrnittals. 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 ut11itits may reference the relevant pages or tables in the original submittal and supply only the requested information th~t was not provided. Please certify that you comply: with the*
staff positions in GL;..sa;..01 or identify *and justify any deviations taken.
Item 1.
P~sition 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 88-02 include positions on:
(1) i:aterials. (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 concern1ng whether the licensee: (1) endorses these positions, (2) proposes alternate positions, exceptions, or provisions, and {3J is considering or planning to apply them in the future. Please describe any alternate positions, exceptions, or provisions that are proposed.
Please supply this fnformatfo~ using a table such as the illustrated ir1 the example shown in Tab.le J.
J.
- 2.
- 3.
- 4.
- s.
- 6.
- 7.
- 8.
- 9.
- 10.
11.*
- 12.
- 13.
Table l Responses to NRC Staff Positions Licensee Response*
Accept Requests vi th Alternate Staff Position Accept Provisions Position Materials Processes Water Otemistry Weld Overl_ay Partial Replacement Stress Improvement of Cracked Weldments Clamping Devices Crack Evaluation and Repair Criteria Inspection Method and Personnel Inspection Schedules Sample Expansion Leak Detection Reporting Requirements Licensee Has/Will**
Applied Consider for in Past Future Use Answer rith "yes", "checlc 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.
2
Item 2. Inservice Inspection Program 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 mf~igating 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 classification of welds, (2) methods, personnel qualification, schedules and identities of welds inspected, and (3) results of previous inspections, and/or identities of velds to be inspected during future inspections.
Thus, the following information is requested:
- 1. A listing of ell 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 conformiJ18 material or non-conforming material, (c) mitigating treatment(s) applied such as solution heat treating (SHT), stress improvement (IHSI or MSIP).
- 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.
3
Table 2 History of Welds and Prior Mitigating Actions/Treatments*
Material**
Casting Treatment***
Categ System Number Configuration Inch Forging, Pipe Weld
~ID§ £8.£ g 2.:.h Notes:
List each veld separateb,-usirig one or more lines as requirt:d.
- For material: identify es 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 was treated using indicated techni-que, i.e., solution heat treated
- (SHT), heat sink velded (HSW), corrosion resistant clad (CRC),
stress improved (SI), or overleyed (O.L.). For SI, add explanation of method used, i.e., whether 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, end whether treatment was applied within two years of service date. Also add explanation and justification of any overlays that were not standard (per NRC Staff position) *
. : t' 4
Table 3 Inspection Schedules*
Inspected/To Be Inspected/Flaws Found IGSCC Weld Dia.
Past Future Categ System ~
Inch. Configuration R.O.#X-2 R.O.#X-1 ~
R.0.#X R.0.#X+l Instructions: *
- 1. Under the heading, "Inspected/To BE Inspected," use as many columns as required to describe the following: * *
(a) All previous inspections that vere conducted {per NURF.G 0313, Revision 2, page 5.2) using methods and personnel qualified under NRC/EPRI/BWROG coordination plan as upgraded in September, 1985.
plus (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.0.# (X-2, X-1, X, X+l) with actual refueling outage numbers. Indicate dates inspections were/will be performed.
- 3. List each weld 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 weld vas inspected or will be inspected.
S. Indicate with "yes" under column marked "flaw" if a flaw indication was found.
Attach a statement for each~ flawed weld giving the orientation (axial or circumferential), the dimensions {maximum length and depth), and describing any repairs made.
5
Item 3. Welds Covered in Licensee Submittal Generic Letter 88-01 (on page 2) states:
"lbis 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 tempeTature 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 within this defiped.scope excluded from the licensee submittal (for example, velds in the RWCU outboard of the isolation valves)? 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 velds vere excluded from the licensee submittal based on temperature considerations please identify the welds a~d describe in detail the method of temperature measurements.
Item 4. Welds that Are Not trr Inspectable Generic Letter 88-01 (in Table 1) states: "Welds that are not trr 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 trr inspections?
(b) All velds that are only partially accessible for trr inspections?
(c) Welds that cannot be trl' inspected because of geometrical constraints or other reasons.
- If not, please list these velds and plans for mitigation/inspection.
Item 5. Leakage Detection Generic Letter 88-01 states on page 3:
"Confirmation of you plans to ensure that the Technical 6
Specification related to leakage detection vill be in conformance with the staff position on leak detection included in this letter."
'Ille staff position is outlined on pages S and 6 of Generic Letter 88-01 and include the folloving item&:
- 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 vben:
(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 ~ys~em indicates an increase of unidentified leak.&ge.in ez~ess
- of 2 gpm or its equivalent, or (b) the total unidentified leakage attains a rate of S gpm or equivalent.
- 3. Leakage should be monitored (or determined from flov measurements if flov 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.
S. 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 offe~ alternative measures, it is not always clear whether these requirements are contained in the Technical Specifications. 'Illus 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.
7
Table 4 Licensee Positions on Leakage Detection Position
- l. Conforms vith Position C of Regulatory Guide*l.4S
- 2. Plant shutdown shouid 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.
- S. Provisions for shutdown within 24.
hours due to inoperable measurement instruments in plants vith Category D, E, F, or G velds.
Instructions:
Already Contained in TS TS vill*be Changed to Include 0
Alternate Position Proposed Place "X" or "yes" under appropriate column for-each item. Provide description and justification for alternative positions if not already provided.
8
A TI'ACHMENT A REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO DRESDEN STATION, UNIT 3 Item 1. Leakage Detection In responding to Item S of the Enclosure please provide the following information: The licensee submittal ( on page 7) refers to other methods of leakage measurements (stating ~at."Sump operability is defined by the shtion as the ability to mea~ure
- reacto~ coolant leakage rather than strictly depending on the operability of a leakage measurement instrument), but no description of the methods or accuracy of these methods vas provided. Please supply this information
- A - 1
ATI'ACHMENT B REQUEST FOR ADDITIONAL INFORMATION PERTAINING "ro QUAD CITIES, UNITS 1 AND 2 Item 1. Leakage Detection In responding to Item S of the Enclosure please also provide the
- f olloving information:
I!l reference to Quad Cities, Unit 1, the Commonwealth Edison Submittal
- states (on page 19):
"Sump operability is defined.by the station as the ability to measure reactor coolant leakage rather than strictly depending on the operability of a leakage measurement instrument."
A similar statement appears on page 23 of the Commonwealth Edison Submittal 1n reference to Quad Cities, U~t 2.
Please describe the alternate method(s) for meas~rt.ng leakage that are inf erred in that statement.
8-1