ML17286A530
| ML17286A530 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/28/1990 |
| From: | Eng P Office of Nuclear Reactor Regulation |
| To: | Sorenson G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| Shared Package | |
| ML17286A531 | List: |
| References | |
| GL-88-01, GL-88-1, TAC-69161, NUDOCS 9101030372 | |
| Download: ML17286A530 (6) | |
Text
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Docket No. 50-397 l
UNITEO STATES t
NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 December 28, 1990 gee,km.)
Pi law Mr. G. C. Sorensen, Manager Regulatory Programs Washington Public Power Supply System 3000 George Washington Way P.O.
Box 968 Richland, Washington 99352
Dear Mr. Sorensen:
SUBJECT:
RESPONSE
TO GL 88-01, INTERGRANULAR STRESS CORROSION IN PIPING (TAC NO. 69161)
By letters dated July 26, 1988 (G02-88-164) and July 20, 1989 (G02-89-123), you provided your response to Generic Letter 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping."
We have completed our review of your response.
We find your response acceptable with the following four exceptions:
1.
The Generic Letter requires that technical specifications include a'tatement that the inservice inspection program conforms with the NRC staff positions on inspection schedules, methods and personnel, and sample expansion.
Although the Generic Letter implied uncertainty regarding the improved technical specification program, it is the current staff position that the improved standard technical specifi-cations for BWRs will include the GL 88-01 requirements (except 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 />, as noted below).
You must apply for an amendment as provided in the Generic Letter.
2.
The Generic Letter requires that technical specifications include a requirement to shut down the plant when the rate of unidentified leakage increases by-more than 2 gallons per minute within a 24-hour period.
Your technical specification requirement to shut down when the leakage rate increases by more than 2 gpm within a 4-hour period does not meet the intent of the Generic Letter.
You must apply for an amendment as provided in the Generic Letter.
3.
The Generic Letter requires that the leakage rate should be monitored at 4-hour intervals or less.
After discussions between the staff and several BWR operators, the staff has acknowledged that this may create an unnecessary administrative hardship.
Therefore, leakage rates may be measured every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
We find that recording the leak rate continuously and performing channel checks at 12-hour intervals, as you described, does not meet the intent of the Generic Letter.
You must revise your leak rate monitoring frequency accordingly.
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Mr. G.
C. Sorensen 4.
Table 2 of your July 20, 1989 submittal indicated that Inconel material is used in some Category A weldments.
However, you did not identify the type of Inconel material.
GL 88-01 considers Inconel 82 to be the only commonly used nickel base weld metal to be resistant to IGSCC and the use of Inconel 600 requires evaluation on an individual case basis.
If the Inconel material which you used was not as required in GL 88-01, the category of those affected Category A
weldments would have to be changed and inspection schedules revised.
You must review the weld records and provide revised inspection plans if the use of Inconel materials is not as required in Generic Letter 88-01.
The staff found that your proposed IGSCC inspection and mitigation program will provide reasonable assurance of maintaining the long term structural integrity of austenitic stainless steel piping in WNP-2.
This finding makes it unnecessary for you to resubmit IGSCC inspection plans for each future outage provided that the Inconel materials used meet the requirements in the Generic Letter.
If inspection plans are revised because of the use of non-resistant material, the revised inspection plans should be provided for staff review at least 3 months prior to the beginning of the scheduled outage.
Misinterpretation (by others) of the generic letter requirement regarding NRC approval of flaw evaluations and repairs has occurred.
Therefore, I am reiterating the requirement from the generic letter along with the applicable ASME,Section XI requirement.
It is noted that weld overlay repair is considered a non-Code repair and requires NRC approval.
Generic Letter 88-01, Attachment A, page 6, Staff Position on Reporting Requirements states that:
If any cracks are identified that do not meet the criteria for continued operation without evaluation given in Section XI of the Code, NRC approval of flaw evaluations and/or repairs in accordance with IWB 3640 and IWA 4130 is required before resumption of operation.
ASME Code,Section XI, IWB 3640, Evaluation Procedures and Acceptance Criteria for Austenitic Piping states that:
Piping containing a flaw exceeding the allowable flaw standards of IWB-3514.3 may be evaluated to determine its acceptability for continued service in accordance with the evaluation procedures and acceptance criteria of IWB 3641 or IWB 3642.
The evaluation procedures and acceptance criteria shall be subject to approval of the regulatory authority having jurisdiction at the plant site.
Within 120 days of r eceipt of this letter, provide the information indicated as necessary in items 1 through 4 above, including the applications for changes to your technical specifications.
Mr. G.
C. Sorensen Enclosed is a safety evaluation summarizing the staff review of your response to the Generic Letter.
Also included is the "Technical Evaluation Report on
Response
from Washington Public Power Supply System to Generic Letter 88-01 Pertaining to the Washington Nuclear Plant No. 2."
This report, prepared by Viking Systems International, and dated September
- 1989, was used in our review.
S incere ly, Original signed by Patricia L.
Eng
Enclosure:
Safety Evaluation with attached Technical Evaluation Report cc 'w/enclosure:
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Mr. G. C. Sorensen Washington Public Power Supply System WPPSS Nuclear Project No.
2 (WNP-2) cco Mr. J.
W. Baker WNP-2 Plant Manager Washington Public Power Supply System P.O.
Box 968, MD 927M Richland, Washington 99352 G.
E.
C. Doupe, Esq.
'Washington Public Power Supply System 3000 George Washington Way P. 0.
Box 968
- Richland, Washington 99532 Mr. R. G. Waldo, Chairman Energy Facility Site Evaluation Council Mail Stop PY-ll Olympia, Washington 98504 Mr. Alan G. Hosier, Licensing Manager Washington Public Power Supply System P. 0. Box 968, MD 9568 Richland, Washington 99352 Mr. A. Lee Oxsen, Acting Managing Director for Operations Washington Public Power Supply System P. 0.
Box 968, MD 1023 Richland, Washington 99352 Mr. Gary D. Bouchey, Director Licensing and Assurance Washington Public Power Supply System P. 0.
Box 968, MD 280 Richland, Washington 99352 Regional Administrator, Region V
U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Chairman Benton County Board of Commissioners P. 0.
Box 190
- Prosser, Washington 99350-0190 Mr. R. C. Sorensen U. S. Nuclear Regulatory Commission P. 0.
Box 69 Richland, Washington 99352 Nicholas S. Reynolds, Esq.
Winston 5 Strawn 1400 L Street, N.W.
Washington, D.C.
20005-3502