ML18040A737

Responds to Generic Ltr 84-11, Insp of BWR Stainless Steel Piping. Induction Heating Stress Improvement & Ultrasonic Testing or Radiography Will Be Performed on Unit 1 Welds During First Refueling Outage

ML18040A737
Person / Time
Site:	Susquehanna
Issue date:	06/01/1984
From:	Curtis N PENNSYLVANIA POWER & LIGHT CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
References
RTR-NUREG-0313, RTR-NUREG-313 GL-84-11, IEB-83-02, IEB-83-03, IEB-83-2, IEB-83-3, PLA-2210, NUDOCS 8406060262
Download: ML18040A737 (5)

Text

REGULATORY 1NFOHMAT ION D JSTRISUTION

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SYSTFM (RIDS)

ACCE,SSIOhr NUH:8406060262 DOC ~ DATE: 84/06/01 NOTARIZED: YFS DOCKET FACIL'50-387 Susquehanna Steam El ec trio Stat ion Uni t 1~ Pennsyl va 05~00 387 50-388 Susauer anna Steam Electric Station~ Unit 2< Pennsylva 0003K AUTH'AhiE A VTHuR AF F ILIAT ION CUHT IS ~ N,i ~ Pennsy varuni a Power I L i gh t Co ~

1 REC IP ~ NAME RECIP IE.NT AFFILIATION SCHbENCEHr A~ Licensing Branch 2

SUBJECT:

Responds to Generic Ltr 84-11'Insp of Bl>R stainless steel piping." Induction neating stress improvement K ultr asonic testing or radiography will be performed on Unit 1 welds during first refueling outage.

DISTRIBUTION CODE: A001S COPIES RECEIVFD:LTH ENC SIZF.:

TITLE: OR Submittal: General Di str ibuti on NOTES: 1cy NESS/FCAF/PM'PDR 2cys ~

05000387 1cy NMSS/FCAF/P~. LVDR 2cys. 05000388 RECIPIENT COPIES RECIPIENT COPIES IO CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL NRR LB2 BC 01 INTERNAL; ELO/HDS4 NRR/DE/HTEB NRH/DL DIR NRR/DL/ORAB NR~R t~FTB NHR/DS I/RAB

~REG F 04 RGN1 EXTERNAL: ACRS 09 I PDR 03 NHC PDH 02 NSIC 05 NTIS NOTES:

TOTAL NUMBER OF COPIES icEUUIRED: LTTR 29 ENCL 7

Pennsylvania Power 8 Light Company Two North Ninth Street ~ Allentown, PA 18101 ~ 215 I 770.5151 Norman W. Curtis Vice President-Engineering 4 Construction-Nuclear 215/770-7501 JUN 0 l 8g Director of Nuclear Reactor Regulation Attention: Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO GENERIC LETTER 84-11 ER 100450 FILE 841-9 Docket Nos. 50<<387 PLA-2210 50-388

Dear Mr. Schwencer:

The following is in response to Generic Letter 84-11, "Inspections of BWR Stainless Steel Piping". The response is in two parts addressing both Unit 1 and Unit 2.

Part I- Sus uehanna SES Unit 1 Res onse

1. During the first refueling outage, scheduled for March 1985, Pennsylvania Power & Light Company will perform induction heating stress improvement (IHSI) on 136 welds which are considered non-conforming prior to IHSI treatment. These welds will include nine one inch branch line welds where IHSI is feasible. Also during the first refueling outage and after IHSI has been performed the non-conforming/conforming service sensitive welds will receive augmented inspections to the extent defined in NUREG 0313.

These welds will be either UT tested or radiographed using the Miniature Linear Accelerator-(MINAC). Since IHSI will be performed on these welds, future augmented inspection requirements of NUREG 0313 no longer apply.

Future inspections on these welds will be in accordance with the Inservice Inspection Program of Section XI of the ASME Boiler and Pressure Vessel Code.

2. The examiners will be available per contractural requirements and will be qualified as follows:

a. All level 2 and level 3 UT examiners performing UT examinations on the IGSCC susceptible welds will have demonstrated competence in accordance with IEB 83-02 as a prerequisite to performing these examinations at Susquehanna SES and level 1 examiners will demonstrate field performance capability.

840bOb02b2 05 000387 pDR ADQCK pDR Q

Page 2 SSES PLA-2210 JUN 0 1 1984 ER 100450 File 841-9 Mr. A. Schwencer

b. All level 2 and level 3 radiographic examiners using the MINAC will demonstrate competence in accordance with the intent of IEB 83-02 and level 1 examiners will demonstrate field performance capability when the equipment has been qualified to the intent of IEB 83-02.

3. Pennsylvania Power & Light Company is not planning any special surveillance measures for primary system leak detection beyond those measures already required in the Technical Specifications. The following is Pennsylvania Power & Light Company's position on Attachment 1, "Leak Detection and Leakage Limits", of Generic Letter 84-11.

a. The leak detection system at Susquehanna SES is sufficiently sensitive to detect and measure small leaks in a timely manner and to identify the leakage sources within practical limits.

b. Since induction heating stress improvement has been used on Unit 2 and will be used on Unit 1 (see paragraph 1.) susceptible welds, the requirement to shutdown the unit immediately when the unidentified leakage is in excess of 2 gpm in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period is overly restrictive.

c. The requirement for the outage time for inoperable leakage measurement instruments is overly restrictive. These instruments should be allowed to be inoperable up to 7 days provided that at least one leakage measurement instrument system is operable. This time period is consistent with other technical specifications for equipment out of service.

d. The unidentified leakage at Susquehanna SES is as defined in'art D to Attachment 1 of the Generic Letter.

e. Visual examination (VT-2) for leakage of the reactor coolant piping should be required in accordance with the time interval as stated in the ASME Boiler and Pressure Vessel Code and not each time the containment is deinerted. Requiring a visual examination each time the containment is deinerted puts an unnecessary strain on manpower,

.increases radiation exposure, and extends outage time with very little .

benefit.

4. The initial NDE inspection of piping susceptible to IGSCC is scheduled for the first refueling outage. The Susquehanna units were not required to perform inspections under IE Bulletins 82-03, 83-02 or the August 26, 1983 order.

5. The remedial measures to be taken if cracks are discovered in future inspections will be consistent with Attachment 2 of Generic Letter 84-11 or other measures acceptable to the NRC at that time.

Page 3 SSES PLA-2210 JUg 0 1 f984 ER 100450 File 841-9 Mr. A. Schwencer Part II Sus uehanna SES Unit 2 Res onse

1. During Unit 2 construction, IHSI was performed on non-conforming welds.

Some additional welds (20 large pipe welds and 9 small pipe welds) will receive IHSI and those welds which are subject to the augmented inspection requirements of NUREG 0313 will be post-IHSI examined where feasible.

These tasks will be completed prior to startup following the first refueling outage on Unit 2 and are currently scheduled for completion prior to Unit 2 commercial operation. The initial inspection of piping will be during the first refueling outage scheduled for late 1986. For those welds which have been treated with IHSI, the requirements for augmented inspection per NUREG 0313 are not applicable. These welds will be inspected in accordance with the Inservice Inspection Program of Section XI of the ASME Boiler and Pressure Vessel Code.

2. See Part I above.

3. See Part I above.

4. See Part I above.

5. See Part I above.

If you have any questions or concerns, please contact us.

N. W. Curtis Vice President-Engineering & Construction-Nuclear cc: R. L. Perch NRC

AFF IDAVIT COMMONWEALTH OF PENNSYLVANIA)

SS COUNTY OF LEHIGH )

I, NORMAN W. CURTIS, being duly sworn according to law, state that I am Vice President, Engineering 6 Construction-Nuclear of Pennsylvania Power 6 Light Company and that the facts set forth on the attached response by Applicants to Generic Letter 84-11 are true and correct to the best of my knowledge, information and belief.

Norman W. Curtis Vice President, Engineering 6 Construction-Nuclear Sworn to and suby+ibed befor me this 1~ day of Q ..., 1984.

Notary Public MARTHA C. BAt f0, flotap P.uiic Allentown, Lehlgh County, Pa.

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