ML17285A467

Forwards Request for Addl Info Re Util 880726 Response to Generic Ltr 88-01.Copy of Response Should Also Be Sent to Viking Sys Intl at Listed Address

ML17285A467
Person / Time
Site:	Columbia
Issue date:	05/16/1989
From:	Samworth R Office of Nuclear Reactor Regulation
To:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
GL-88-01, GL-88-1, TAC-69161, NUDOCS 8905220453
Download: ML17285A467 (16)

Text

~ Docket No. 50-397 Mr. G.

C. Sorensen, Manager Regulatory Programs Washington Public Power Supply System P. 0.

Box 968 3000 George Washington Way Richland, Washington 99352 May 16, 1989

SUBJECT:

GENERIC LETTER 88-01 RESPONSE.

REQUEST FOR ADDITIONAL INFORMATION (TAC NO. 69161)

We have received your response of July 26, 1988 to Generic Letter 88-01 and have initiated our review.

We find that to complete the review we will need the additional information specified in the attachment to this letter.

Please provide the information within sixty days of receipt of this request.

We have contracted with Viking Systems International to review responses to the Generic Letter.

To expedite the review of your response, please send a

copy of your response to the contractor at the same time that you submit it to NRC.

The contractor's address is:

Dr. Armand A. Lakner Director, Safety and Reliability Viking Systems International 101 Chestnut Street Gaithersburg, Maryland 20877 I thank you for your prompt attention to this matter.

S incere ly,

/s/

Robert B. Samworth, Senior Project Manager Project Directorate V

Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated above DISTRIBUTION-------/

g NRC 5 Local PDRs PD 85 Reading MVirgi1io JLee RSamwor th OGC (f/info only)

EJordan BGrimes WNP-2 69161 P

PqoS'/

ywaoo 97 9Fc f

LOG p5 5/15 gP PD5/DRSP RSamworth 5/p /89 DRSP hton

/)0/89

I

~

I RH

~

lO I'

ll f'~)'

affah R Rh fhfJ h

li a

ha

'I 4

I I

~

p,

~ =

h QRR I I I

Fit 4

I all R

I

'Pl RR Rah I ha 1 ~

,h If y I" Rh,

'FIlf,,ill I

RF I

~

I ll I

f)I)

I' Ff 1

4, 4

4 a

l4 4

4 If i 4

Fa I

I I 'Ill,ah fc I

~

'I 'a) )'<)4'lF,j 4

'RI f)

'4 l ll R I I

] )

h r I)

R R

I

~ fl, I!4 li a

I'

~

I i lh) lip M

II I )

~

~,

Ia);.

a

) )

- ar

'll li'I l

'I IFff 4 ~

M I4 yallFR 4',

g "I

Il 4 I IP

)<g j I',

a RR) hll" I R'l 4

~

l'l RF34 a

)

h)II a

Ih R>

th R

"I, ~

FIR h

1 1

hl 1

Fl

'R,lgl, '

~pS RECy, c~

wpo*

O C

0

+**++

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 May 16, 1989 Docket No. 50-397 Mr. G.

C. Sorensen, Manager Regulatory Programs Washington Public Power Supply System P. 0.

Box 968 3000 George Washington Way Richland, Washington 99352

SUBJECT:

GENERIC LETTER 88-01 RESPONSE.

RE(VEST FOR ADDITIONAL INFORMATION (TAC NO. 69161)

We have received your response of July 26, 1988 to Generic Letter 88-01 and have initiated our review.

We find that to complete the review we will need the additional information specified in the attachment to this letter.

Please provide the information within sixty days of receipt of this request.

We have contracted with Yiking Systems International to review responses to the Generic Letter.

To expedite the review of your response, please send a

copy of your response to the contractor at the same time that you submit it to NRC.

The contractor's address is:

Dr. Armand A. Lakner Director, Safety and Reliability Yiking Systems International 101 Chestnut Street Gaithersburg, Maryland 20877 I thank you for your prompt attention to this matter.

Sincere ly, Robert B. Samworth, Senior Project Manager Project Directorate V

Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated above

~

I 1

fi'

~ ~

~

~

2 hTTACHMENT h GENERAL QUESTIONS/REQUESTS Reviews of several licensee submittals has shown that most (although not all) of the submittals comoonly 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 BVR 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) Vater 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.

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 l.

Table 1

Responses to NRC Staff Positions Staff Position

1. Materials

2. Processes Licensee Res hccept vith

'Aces t Provieioos onse+

Licensee Has Vill++

Requests hltcrnatc hpplied Consider for Position in Past Future Use

3. Vatcr 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 Ansver 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 ifit contains the listing and explanation)

~

Use separate page(s) if needed.

<<>> hnsver with "yes" or "no", as appropriate, in each column for each of 13 NRC Staff Positions.

h - 2

~ 4 hTThCHMENT 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 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 veil as the Inservice Inspection Program provided in most of the licensee submittals vere 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 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.

&us, the following information is requested:

~I

1. h listing of all velds by system, pipe sixe, configuration (e.g.,

pipe to elbow, pipe to valve, etc.),

drawing number (piping ISO with veld I.D.), location (i.e., inside or outside of containment, etc.), 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 as heat sink velding (E%), (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),

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.

h-3

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

Material++

IGSCC Veld Dia.

Casting Treatment+++

Notes:

List each veld se aratel

, using one or more lines as required.

For material: identify as non-conforming or conforming as appropriate concerning whether 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 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 two years of service date.

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

Table 3 Inspection Schedules Ins cted To Be Ins cted Flavs Found IGSCC Veld

Dia, Past Future I*.~..\\-.. -

"..i..\\

Instructions:

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

use as <<any columns as required to describe the following:

(a) h11 previous inspections that vere 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.

plus (b) h 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 vhich that veld vas inspected or vill be inspected.

'5. Indicate vith "yes" under column marked "flaw" 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.

hTZhCHMENT h (continued)

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

"'Ibis 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 aa jet pump instrumentation penetration assemblies and head spray and vent components."

Were any welds that fall within this defined scope excluded from the licensee submittal (for example, welds in the RMCU outboard of the isolation valves)? If previously excluded, please list identity of such welds and plans for mitigation and inspections in Tables 2 and 3 or provide alternative proposal. If IGSCC susceptible welds were 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 hre Not UT Ins ectable Generic Letter 88-0l (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) h11 welds that are inaccessible for UT inspections?

(b) h11 welds that, are only partially accessible for UT inspections?

(c) Welds that, cannot be UT inspected because of geometrical constraints or other reasons.

Xf not, please list these welds 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

hTl'hQMENT 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 following items:

1. Leakage detection should be in conformance vith Position C

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

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

(a) vithin 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 vith operations of monitoring systems or not to be from a throughvall crack.

5. For plants operating vith any IGSCC Category D, E, F, or G velds, at least one of the leakage measureiint 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 shutdown.

hlthough most licensee submittals describe the intention of meeting some or all of these requirements or offer alternative measures, it is not always 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.

h-7

Table 4 Licensee Positions on Leakage Detection Position I. Conforms vith Position C of Regulatory Guide 1.45

2. Plant shutdown should be initiated Men:

hlready TS will be hlternate Contained Changed Position ln TS to Include

~Pro oned (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 throughva11 crack.

5. Provisions for shutdown 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 fields.

Instructions:

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

Provide description and Justification for alternative positions if not already provided.

h - 8

hTThQBKNT B REQUEST FOR hDDITIONhL INFORMATION PERThINING TO WhSHINGTON NUCLEhR PLhNT NO. 2 Item 1. Staff Position on Crack Evaluation and Re air Criteria In responding to Item 1 of httachment h:

(a) Please note that the WNP-2 Submittal states that the Supply System vill use hSME Section XI Section IWB-3600 of the 1986 Edition of hSME Boiler and Pressure Vessel Code for methods and criteria for crack evaluation and repair.

Hovever, Generic Letter 88-0I also states that this must be supplemented vith a method for determining the crack growth rate.

Please indicate whether you endorse the method suggested in Generic Letter 88-01 or propose an alternative method.

page B 1

'C N

~