ML17202U801

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SER Accepting Licensee 880729 Response to Generic Ltr 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping, W/Stated Exceptions.Licensee Requested to Submit Tech Spec Change to Require Inservice Insp Statement
ML17202U801
Person / Time
Site: Dresden Constellation icon.png
Issue date: 08/23/1990
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17202U800 List:
References
GL-88-01, GL-88-1, NUDOCS 9008290178
Download: ML17202U801 (3)


Text

. l UNITED STATES NUCLEAR ~EGULATORY COMMISSION WASHINGTON, D. C. 20555 ENCLOSURE 2

  • SAFETY EVALUATION BY THE.OFFICE OF NUCLEAR REACTOR REGULATION REVIEW OF RESPONSE TO NRC GENERIC LETTER 88-01 COMMONWEALTH EDISON COMPANY DRESDEN *NUCLEAR POWER STATION, UNIT 2

'DOCKET NO. 50-237 L 0 INTRODUCTION Conunonwea 1th Edi son Company, the 1 i cens*ee, *submitted its response to NRC Generic*

  • and add iti ona 1 information as. requested by the* staff was prov ide.d by letters dated October 5, 1988, December 21, 1988, and March 1, 1989:

GL 88-01 requested licensees and construction permit holders.to resolve the* Intergranul,ar Stress Corrosion Cracking (IGSCC) issue for* BWR. piP.ing made of austenitic stainless

-steel that is four inches* or larger.in* nominal diameter* and contains reactor coolant at a temperature above 200 degrees Fahrenheit during poweroperation'._

  • regardless of Gode classification. The licensee was requested to address

. the_Jollow.ing:

1.

The.current plans regarding pipe replacement and/or other measures taken to mit'igate

  • IGSCC and provide assurance of continued long.:term integrity *
  • and re 1 iabil ity.
2.

The !~service Inspection (iSI) Program t6 be implemented at t~e next r~fueling outage for austenitic stainless steel piping covered under the scope of this letter that conformsto the staff positions on inspection schedules,* methods and personnel, and.sample expansion included in *.

GL 88-01.

3.. Th~ Technical Specification (TS) change to include a statement i~ the section on ISI that the ISI Program.for piping ~ov~red by the scope of this
  • letter will be in staff p~sitions on schedule,. methods. and personnel, and

~ample expansion included in GL 88~01 (see model BWR Standard Technical

  • Specification enclosed in GL 88-01}~ It is recognized**that the Inservice
  • Inspection and Testing sections may be removed from the Technical Specifications Improvement programs.

In this case, this requirement

.shall remain with the ISI section when it is *included in an alternative

  • document.
4.

The confirmation o*f your plans to ensure that the TS related to leakage detection will be ib conformance with.th~ staff positions on leak detection included in GL 88-01.

  • 5.

The plans to notify the NRC in accordance with 10 CFR 50.55a(g) of any flaws identified that do not meet IWB-3500 criteria of Section XI of the

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. Code for continued operat~on without evaluation, or a change found in the conditii:>n of the welds previously known to be cracked and your evaluati.on

~f the flaws for continued operation and/or your repair plans.

2.0 DISCUSSION

  • The licensee's response to NRC GL 88-01 has been reviewed by the staff with the assistance of its contractor, Viking Systems International (VSI).

The _

attached Technical Evaluation Report~ (TERs) are VSI's evaluation of the licensee's response to NRC GL 88-01.,The staff has reviewed the TER~ and concurs with the evaluatioris,. conclusions, and recommendations contained in

_the TER with the exception as discussed.below with regards to litensee's positions IGSCC classifications of castings. In the review of.the li~ensee's

  • GL.88-01 submittal, the staff has found th~ foilowing positions to*be
  • unacceptable:
1.

The.lice~see's positi6n on a 50% reduciiori*of the inspection schedule based on hydrogen water treat!'lent.

2.

The ljcensee's posjtion not to *amend the TS to include a statement on ISI as r.equired in GL 88-01.

3.-

-Th~ l.icensee's position to average the unidentified leak.rate over a*

. *24~ho~r period~

4. *.The licen~ee*'s position concerning *the operability requirements of the leakage monitoring *instrume~~s outlined in GL 88-01.

For a.detail~d discussion of these item~, see S~ctioris 2.0 and 3.0 ~f the TER *

.*The above identified item*s with. regards to TS amendments have been approved

the exception tha.t unidentified l~akage may be monitored every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

  • instead of every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required i~ GL 88-01.

The staff has re.;.evaluated the. frequency of leakage* monitoring. 'After discuss ions with severa 1 BWR

  • operators the staff concluded that monitoring every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> creates an unnecessary administrative hardship to the plant operators. Thus, Reactor Coolant System (RCS) leakage measurements may be taken every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> instead
  • of every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required. i_n GL 88-01.

The licensee needs to address the Reactoi ~ater Clean-up (RWCU) piping outboard of the isolation valves. If ~he piping-is within the scope of GL 88-01, the Jicens~e wi-11 need to list the.identify of the we,lds, and -plans.

  • for mitigation and inspections or proviqe alterna_tive proposals.
  • 3.0 CON CL US ION Based on the review of the licensee's NR~ Gl 88-01 response, the staff conclude~ that the response, as evaluated, is acceptable with th~ exception of the licensee's positions as identified above.

The licensee *is requested to submit a _TS change that wot.ild require an ISI statement and leakage

  • requirements as required in GL 88-01 with the exception that leakage may be monitored every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> instead of.every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required in GL 88-01.

Since, the licensee's request to reduce the inspection schedule by 50% has been denied at this time, the licensee must submit future IGSCC inspection plans based o~ the requirements in GL 88-01.

The staff also concludes that the proposed IGSCC inspection and mHigation program will provide reasonable assurance of maintaining the _long-term structural integrity of austenitic stainless steel piping in.the Dresden Nuclear Power Station, Unit 2.

  • Principal Contributors~ W. Koo T. McLel lan Dated:

August 23, 1990

...