ML18094A078

Rev 1 to Technical Evaluation of Integrity of Browns Ferry 1,2 & 3 Reactor Coolant Boundary Piping Sys

ML18094A078
Person / Time
Site:	Browns Ferry
Issue date:	08/30/1983
From:	Nagata P EG&G, INC.
To:	Koo W Office of Nuclear Reactor Regulation
Shared Package
ML18026B092	List: ML18094A078
References
CON-FIN-A-6429, RTR-NUREG-0313, RTR-NUREG-313 EGG-FM-6246, EGG-FM-6246-R01, EGG-FM-6246-R1, GL-81-04, GL-81-4, TAC-46652, TAC-46653, TAC-46654, NUDOCS 8407110154
Download: ML18094A078 (60)

Text

EGG-FM-6246 Revision 1

Augttst 1983 TECHNICAL E'lALUATION OF INTEGRITY OF THE BROitfNS FERRY 1, 2, ANO 3 REACTOR COOLANT BOUNOARY PIPING SYSTEM Peter K. Nagata idaho National Engineering Laboratory Operated by the U.S. Department of Energy

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'hg<rrya This is an informal report intended for use as a preliminary or working document 8407iiOi54 8406i5 PDR ADDCK 00000209 I,

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EGG-FM-6246 Revision 1

TECHNICAL EVALUATION OF INTEGRITY OF THE BROMNS FERRY 1, 2, ANO 3 REACTOR COOLANT BOUNDARY PIPING SYSTEM Published August 1983 Peter K. Nagata Materials Engineering Branch Materials Sciences Division EG5G Idaho, Inc.

Idaho Falls, Idaho 83415 Responsible NRC Individual and Oivision:

M. H. Koo/Oivision of Engineer ing Oocket No.:

50-259,

-260,

-296 TAC No.:

46652, 46653, 46654 Prepared for the U.S. Nuclear Regulatory Commission Under 00E Contract No. OE-AC07-76I001570 F IN No. A6429

ABSTRACT NUREG-0313, Rev.

1, Technical Report on Material Selection and Processin Guidelines for BNR Coolant Pressure Boundar Pipin, is the NRC staff's reviseo acceptaole methods to reduce intergranular stress corrosion cracking in boiling water reactors.

The responses to NRC Generic Letter 81-04 of the Tennessee Yalley Authority concerning whether, its Browns Ferry Nuclear Power Station Units 1, 2, and 3 meet NUREG-0313, Rev.

1 are evaluated by EG&G Idaho, Inc. in this report.

Particular attention was given the leak detection systems described in Regulatory Guide 1.45, Reactor Coolant Pressure Boundar Leak Oetection S stems, referenced by arts

..a.

ana roun on pages an or NUREG-0313, Rev. l.

FOREMORO This report is supplied as part of the Selected Operating Reactor Issues Program being conducted for theiU.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Licensing, by EG&G Idaho, Inc., Materials Engineering Branch.

The U.S. Nuclear Regulatory Commission funded the work under theo authorization, B&R 20 19 10 11.

SUMMARY

HUREG-0313, Rev.

1, Technical Report on Material Selection and Processin Guidelines for BWR Coolant Pressure Boundar Pipin

, is the NRC star7 s revised acceptab e met ods to re uce >ntergranu ar'stress corrosion cracking in boi ling water reactors.

The responses to NRC Generic Letter 81-04 of the Tennessee Valley Authority concerning whether its Browns Ferry Nuclear Power Station Units 1, 2,

and 3 meet NUREG-0313, Rev.

1 are evaluated by EG4G Idaho, Inc. in this report.

Particular attention was given the leak detection systems described in Regulatory Guide 1.45, Reactor Coolant Pressure Boundary Leak Detection Systems, referenced by arts

..a.

an round on pages i ana or NUREG-0313, Rev.

1.

As may be observed in the following table, with the exception of II.C.,

Browns Ferry 1, 2,

and 3 do not meet any of the parts of NUREG-0313, Rev.

1 evaluated in this document.

The following table is a synopsis of the EG5G Idaho, Inc. evaluation of the Tennessee Valley Authority's response to NRC Generic Letter 81-04.

Part of NUREG-0313, Rev.

1 Evaluated Section II.

Eva 1uat ion a Additional Data b

Section III.

Section IV.

Meets NUREG-0313, Rev.

1 No None IV.B.1.a. (1)

Provides alternative to NUREG-0313, Rev.

1 Yes Major IV.B.l.a. (2}

Does not meet NUREG-0313, Ho Rev.

1 Major IV.B.l.b. (1)

Does not meet NUREG-0313, Yes Rev.

1 Minor IV.B.l.b.(2)(a) Does.not meet NUREG-0313, Yes Rev.

1 Minor IV.B.l.b.(2)(b) Provides alternative to NUREG-0313, Rev.

1 IV.B.l.b. (2) (c) Provides alternative to HUREG-0313, Rev.

1 Yes Yes Minor Minor

Part of NUREG-0313, Rev.

1 Evaluated IV.B.l.b.(2)(d)

Evaluation Provides alternative to NUREG-0313, Rev.

1 Additional Oata Required Yes Oiscrepanc Minor IV.B.l.b. (3)

IV.B.l.b.(4)

Ooes not meet NUREG-0313, No Rev.

1 Ooes not meet NUREG-0313, No Rev.

Minor Minor IV.8.2.a.

The comments for Parts IV.B.l.a. (1) and IV.B.l.a.(2) app ly here.

IV.B.2.b.(1)

IV.8.2.b.(2)

IV.B.2.b.(3)

IV.B.Z.b.(4)

IV.S.2.b.(6)

Section V.

Provides alternative to NUREG-0313, Rev.

1 Provides alternative to NUREG-0313, Rev.

1 Provides alternative to NUREG-0313, Rev.

1 Provides alternative to NUREG-0313, Rev.

1 Oid not provide data in response to NRC Generic Letter 81-04 Yes Yes No Yes Yes Minor Minor Minor Minor Minor aSee Tables 1 and 3 for additional information.

See Tables 1 and 4 for additional information.

CONTENTS ABSTRAC T

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11 UOARY...............................................................

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IN TROD UC TION

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1 2

EVALUATION..................................................,....

2.1 NUREG-0313, Rev.

1 Guidelines..............................

4 2.2 Discussion of Tables.......................................

4 2.3 Discrepancies.............................................-

5 3

CONC LUSIONS

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REFERENCES....................

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44 TABLES 1.

Review of Licensee's

Response

to NRC Generic Letter 81-04........

8 2.

Summaries of Evaluation of Licensee's Responses..................

27 3.

Differences between NUREG-0313, Rev.

1 and Licensee's Responses..................,.....................................

32 4.

Additional Data Required of Licensee............'.................

40

TECHNICAL EVALUATION OF INTEGRITY OF THE BROWNS FERRY 1, 2, AND 3 REACTOR COOLANT BOUNQARY PIPING SYSTEM 1.

INTROOUCTION Intergranular stress corrosion cracking

( IGSCC) of austenitic stainless steel (SS) piping has been observed in boiling water reactors (BWRs) since Oecember 1965.

The NRC established a Pipe Crack Study 1

Group (PCSG) in January 1975 to study the problem.

The PCSG issued two documents, NUREG-75/067 Technical Re ort, Investi ation and Evaluation of Crackin in Austenitic Stainless Steel Pipin of Boilin Water Reactors and an implementation

document, NUREG-0313, Rev. 0.

After cracking in large-diameter piping was discovered for the first time in the Duane Arnold BMR in 1978, a new PCSG was formed.

The new PCSG in turn issued two

reports, NUREG-0531,'.Investi ation and Evaluation of Stress-Corrosion Crackin in Pipin of Li ht Mater Reactor Plants and HUREG-0313, Rev.

1, Technical Report on Material Selection and Processin Guidelines for BWR Coolant. Pressure Boundar Pipin.

implementing document of NUREG-0531 inspection

( ISI) and leak detection comply with the material selection, NUREG-0313, Rev.

l.-5 HUREG-0313, Rev.

1 is the and discusses the augmented inservice requirements "for plants that cannot

testing, and processing guidelines" of HRC Generic Letter 81-04 requested each licensee "to review all ASNE Code Class 1

and 2 pressure boundary piping, safe ends, and fitting

material, including weld metal to determine if (they) meet the material selection, testing and processing guidelines in" HUREG-0313, Rev. l.

The generic letter offered the option of providing a description,

schedule, and justification for alternative actions that would reduce the susceptibility of pressure boundary piping and safe ends to intergranular stress corrosion cracking

( IGSCC) or increase the probability of early detection of leakage from pipe cracks.

In response to NRC Generic Letter 81-04, the Tennessee Valley Authority (TVA) submitted a letter on July 2, 1981.

A request for information from the NRC staff elicited another letter from TVA on Oecember 20 1982.

EGEG Idaho personnel evaluated these responses, and 8

this report provides:

l.

A brief summary of the licensee's response to each part of NUREG-0313, Rev. l.

Z.

A discussion of area~

where the licensee does not meet the guidelines or requirements of NUREG-0313, Rev.

3.

A brief discussion of the licensee's proposed alternatives to NUREG-0313, Rev.

1; however, no determination of acceptability is made on these alternatives.

4.

An identification of all areas where the licensee has not provided sufficient information to judge <<he licensee's program.

There is an effort underway to revise NUREG-0313, Rev.

1 by NRC in light of res< rch on IGSCC and recent instances of IGSCC at Nine Mile Point (March 1982',

and Monticello (Oc:ober 1982).

8ecause of the contemplated revision of NUREG-0313, Rev.

1, the following issues will not be evaluated.

1.

The licensee's proposed Technical Specifications to implement the requirements, with the exception of the leak detection requirements in NUREG-0313, Revision 1, Sections IV.B.1(a)( 1) and IV.S. 1.(a)(2).

2.

The accep:ability of licensee-proposed augmented inservice inspection (ISI) sarpling criteria.

3.

Credit for past operating experience and inspection results.

a.

Part III of NURE".-0313, Rev.

1 contains guidelines; Part IV contains requirements.

4.

The acceptability of induction heating stress improvement (IHSI), heat sink welding (HSW), and weld overlay as alternates to augmented ISI.

2.

EVALUATION 2.1 NUREG-0313, Rev.

1 Guidelines The guidelines and requirements outlined in NUREG-0313, Rev.

1 form the basis of this evaluation.

The NUREG-0313, Rev.

1 guidelines are found in Parts III and Y and the requirements in Parts II and IY of that document.

Part II discusses implementation of material selection, testing, and processing guidelines.

Part III summarizes acceptable methods to minimize IGSCC susceptibility with respect to the material selection,

testing, and processing guidelines.

Part IV deals with leak detection and inservice inspection requirements of nonconforming (i.e., not meeting the guidelines of Part III of NUREG-0313, Rev.

1) piping.

Part V discusses general recommendations.

2.2 Oiscussion of Tables Table 1 has the complete text Parts II through V of NUREG-0313, Rev.

1 on the left side so that the reader may be able to refer to it as the topics are discussed.

The

. ight side summarizes the licensee's responses, lists the differences between the licensee's proposed implementation program and NUREG-0313,

Rev, 1,

and identifies the additional data required to evaluate the licensee's response.

iMany sections in Parts II through IV of NUREG-0313, Rev.

1 are not discussed in the right hand column.

In these cases, one of the comments below will be used.

o Not applicable because the construction permit for this plant has been issued.

o Not applicable because the operating license for this plant has been issued.

o Not applicable because the plant has been constructed.

o The licensee has not furnished data on this topic in his responses to NRC Generic Letter 81-04.

o No comment made because alternative plans were not evaluated.

Table 2 lists the summaries of the licensee's responses to NRC questions on implementation of NUREG-0313, Rev.

1 guidelines.

Therefore, in Table 2 the reader is able to read all the summaries in one table without having to search Table 1 for all the summaries.

The same compilation applies to Tables 3 and 4.

Table 3 lists the differences between the licensee's proposed implementation program and that recommended in NUREG-0313, Rev. l.

Table 4 lists the areas where additional information is required to properly evaluate the licensee's proposed implementation program.

All the items in Tables 2, 3, and 4 are listed in their respective tables in the order they appear in Table l.

2.3 Discrepancies Any alternate proposal that did not meet a specific guideline or requirement of NUREG-0313, Rev.

1 was considered a discrepancy.

Evaluation of alternate proposals was outside the scope of this task, as indicated in

~

Section 1 of this report.

Licensees have submitted definitions of "nonservice sensitive" and augmented ISI proposals that. differ from NUREG-0313, Rev.

1.

These differences are considered minor because the NRC staff is considering major modifications to those requirements.

An example of a minor discrepancy is the use of the stress rule index (SRI) to choose which welds would be subjected to augmented ISI.

If the alternate proposal to leak detection does not meet the requirements in NUREG-0313, Rev.

1, it was considered a major discrepancy because NRC is not considering major modifications to those requirements.

An example of a major discrepancy is a licensee's not proposing Technical Specifications to implement leak detection requirements in HUREG-0313, Rev. l.

Only major discrepancies are listed in the Conclusions section.

3.

CONCLUSIONS Browns Ferry 1, 2 and 3 have the following major discrepancies:

IV.B.l.a.(1)

Leak Oetection and Monitoring Systems TVA's description of the Browns Ferry 1, 2, and 3 leak detection methods is not detailed enough to determine if they meet those suggested in Section C of Regulatory Guide 1.45.

IV.B.l.a.(2)

Leak Detection Requirements TVA has not proposed a requirement for shutdown after a 2-gpm increase in unidentified leakage in 24 h into the Technical Specifications for Browns Ferry 1, 2, and 3.

TYA has not proposed a requirement for monitoring the sump level at 4-h intervals (or less).

There are minor discrepancies as well as the major ones listed above.

These minor discrepancies are not listed here.

However, while the licensee's alternate proposals that have been classified as minor discrepancies might be acceptable under the anticipated revision of NUREG-0313, Rev.

1, it should not be inferred that approval of those alternate proposals has been given.

The licensee has not supplied sufficient information to evaluate his responses to topics IV.B.l.a.( 1); IV.B.l.b.( 1); IV.B.l.b.(2)(a), (b), (c),

and (d);

and IV.B.2.b.( 1), (2), (4) and (6).

Table 4 lists the required information for each topic.

7

fAULE 1.

REVIEH OF LICENSEE S RESPONSE lo NRC GENERIC LLI IBt 81-04 Excer t,s froEn NUREG-0313~Rev.

1 II.

IHPLEHENIA~ ION OF HAIERIAI. SELECf ION TESTING At(0 RUiHK'fm'MlijEllNE II.A.

For plants under review, but for which a conslruction permit has not been issued, all ASHE Code Class I, 2, and 3 lines should conform to Lhc guidelines stalcEI in Part III.

II.B.

for plants that have been issued a construction permit but not an operating license, all ASHE Code Class I, 2, and 3 lines should conform to the guidelines staLed in Part ill unless lt can be demonstrated to the staif that lnTpleTnentlng the guidelines ot Perl III would result in undue hardship.

Fur cases in which the guidelines of Part ill are not conplied with, additional measures stEould be taken for Class 1 and 2 lines in accorda>>ce <<Ith LIEe guidelines stated In Part IV of this document.

EGIIG Idalio Eaaloalloa

-OIIGUIIS FEOIIT I 2

AUU 3 A.

Not applicable because the cons ruction permits for these plants have been Issued.

D.

Not applicable because the operating licenses for these plants have already been Issued.

11.C.

For plants that have been issued an operating

license, NNC designated "Siarvice Sensitive" lines (Part IV. 3) SIEuuld be Enudlfied Lo conform to the guidelines stated in Part Ill, to the extent pracLicaule.

Mhen "Service Sensitive" and other Class I and 2 lines do not EnccL the guidelines of Part Ill. additional measures should be taken In accordance with tne guidelines stat.ed in Part IV of this docuTnc>>t.

Lines that experience cracking during service and require replacuaent should be replaced with pipi>>g tITat conforms to the guidelines stated in Part Ill.

C.

SUHHARY TVA has replaced some "service sensitive" li>>es with conforming materials.

TVA also has contingency plans to replace other "service sensitive" lines.

TVA meets the requirements of NIIIEG-0313, Rev.

1 regarding replaceTncnt material for nonconforming piping.

OII FERENCES fherc are no differences betwcc>>

IVA's proposals a>>d NUREG-0313, Rev.

1 requirements on replacement material for nonconforming piping.i However, there Is not sufficient Eletail In Reference 7 to fully evaluate fVA's compliance.

Al)UITIOUAL OATA REIAUIIIEO Ide>>tify all nonce>>forming "service sensitive" piping and LIEe replacmnent plans pertaining to then.

III.

SMIARY OF ACCFPTAULE HEINOUS TO IIINIHILE CRACK

'2 SUbCLPIIBILlfY--HAILRIALSELECf ION ICSIING ANU h<Gt'.EHINb ~ulDEt fAH I II.A.

Sel<<etio>> of Halcrials O>>ly those Enaterials described in Parts I a>>d 2

belOw are aCCeptaule LO lhe NRC fur inStallaLIO>>

i>> BUR ARE Code Class 1, 2, and 3 piping I systcEns.

Other materials nEay bc>>scd when evaluated a>>EI acci'pled loy lhc IU(C.

A.

The lice>>see has not furnished data on this paragraplE i>> Iois r<<spo>>ses to NRC Generic Lialter 81-04.

I II.A.1.

Corrosion-Resistant Haterlals All pipe and fitting material including safe

ends, thermal sleeves, and weld metal should be of a type and grade that has been d<<monstrated to be highly resistant to oxygen-assisted stress corrosion in the as-installed condition.

Haterlals that have been so demonstrated include ferritic sLeels, "tiuclear Grade" austenitlc stainless steels,~

Types 304L and 316L austenitic stainless

steels, fype CF-3 cast stainless steel, lypes CF-8 and CF-8H cast austenitlc stainless st<<el with at leasL 5X ferrite. I'ype 308L stainless steel weld metal, and other aust<<nitic stainless steel weld metal with at least bl ferrite content.

Unstabilized wrought austeniLic stainless steel without controlled luw carbon has uot been so dmrenstrated except when the piping is in the solution-anneale<l condition.

Ihe use of such material

( l.e., r<<gular grad<<s of Types 304 and 316 stainless steels) should be avoided.

if such material is used, the as-installed piping including welds should be in the solution-annealed condition.

Mhere regular grades of Types 304 and 316 are used and welding or heat treatment is required, special

measures, such as those described in Part III.C, Processing of Haterials, should be taken to ensure that IGSCC will not occur.

Such measures may include (a) solution annealing subsequent to the fielding or heat treatment, and (b) weld cladding of materials to be welded using procedures that have been demonstrated to reduce residual stresses and sensitization uf surface materials.

Ihe couments on I II.A. also apply here.

'uese materials hav<< controlled low carbon (0.02', max) and nitrogen (O.iy nmx) contents and me<<L all requirements, including mechanical property r<<quirenmnts, of ASHE sp<<cification for regular grades of lype 304 or 3lb stainless steel pipe.

I II.A.2.

Corrosion-Hesistant Safe Ends and Thermal Qeuves 2.

The ceuxents on III.A. also apply here.

Al I unstabi I ized wrought aust<<nitic stainless steel materials us<<d for safe ends and thermal sleeves without controlled low carbon contents (L-grades and Huclear Grado) should be in the solution-annealed condit.ion.

If as a

consequence of fabricaLion, welds joining t>>ese materials are noi. sulution an>>ealed, they s>>ould be made between cast (or weld overlaid) austu>>itic stainless steel surfaces (5X minimum ferrite) or other materials havi>>g high ruSistance to oxygen-assisted stress corrosion.

Ihe joint design must be such that any >>Ig>>-stress areas In unstabilized wrought austenitic stainless steel without Controlled low carbon contents which may become sensii,Ized as a result of the welding process's

>>ot exposed to the reactor coolant lhermal sleeve attachments that are welded to the pressure boundary and form crevices where impuriLies may accumulate should not be exposed to a BMII coolant environment.

For new installation, tests should be made on all regular grade stainless. steels to be used In the ASHE Code Class I ~ 2, and 3 piping systems to di~enstrate that the material was properly a>>>>ealed and Is not susceptible to IGSCC.

Iests that have been used to determine the susceptibiliLy of IGSCC include Practices A'nd E" of AS1H A-262, "Recomnended Practices for Detecting Susceptibility to lntergranular Attack in Stainless Steels" and the electrochemical pote>>tiokinel.ic reactivation (EPR) test.

Ihe EPR tosL is not yet accepted by the IIRC. If the EPR test is uSed, t>>e acceptance criteria applied must bo evaluated and accepted by the IIILC on a case-by-case basis.

B.

lhe licensee has not furnished data on this paragraph In his responses to INC Generic Letter 81-04

'Practice A--Oxalic acid etch teSL for Classification of etch structures of stainless steels

~

"Practice E-- Copper-copper sulfate-sulfuric acid test for detucLIng susceptibility Lo Intergranular attack in stainless steels.

Corrosion-resista>>t cladding with a duplex microstructuro (5X minimum ferrite) may be applied tu the e>>ds of Iypu 304 or 3IG stainless steel pipe for the purpose of avoiding IGSCC at weldme>>ts Such claddi>>g, which Is l>>tended to (a) mi>>imlze the IIA2 o>> the p Ipe Inner surface, (u) muVe Lhe INl a>>ay I'rOm Lhu highly StreSSed rcgio>> >>oxt to the attacliau.'>>t weld, a>>d (c) isolate Lhe weldmu>>L from the e>>viroeme>>t, may bu applied unde!

tho followl>>g co>>dition'st C.

Ihe licensee has not furnished data on this paragraph In his responses to INC Generic LeLter 81-04.

See comxents on Part II.C. above.

Ill.t;.I. Fur Initial construction, provided thaL all of ttse piping is solution annealed after cladding.

Ill.t'..2.

For repair wc.ldlng and modification to In-place systems In operating plants and plants under construction.

Ithcn the repatr fielding or modification requires replacement of pipe, ttse replacmaent pipe should be solution-asu>caicd after cladding.

Corrosion-resistant cladding applied In the "field" (i.ePH Mltttout subsequent solution annealing of the pipe) is acceptable only on ttsat portion of thc pipe that has not been removed from the piping system.

Other "field" applications of corrosion-resistant cladding are not acceptable.

Other processes that have been found by laboratory tests to minimize stresses and IGSCC In austeniLic sLalnless steel weldmcnts ioclude inductlun heating stress improvement (IttSI) and heat Sink weldiog (IIStt).

Although the use of these processes as an alternate to augsEsented inserv ice Inspection Is not yet accepted by ttse ttRC, ttsese processes may be permissible and will be considered on a case-by-case bas is provided acceptable supportive data are subsnitted to the NIC.

IV.

INSEAVICE INSPECTIOtt AIID LEAK OEIECTION REOUIAEIIEttTS FGRS~sTMARFTIIMEGRE~MOIIFORH'AillETo HHAE~IAL ELECIIIGHWESTIIIG Allll PAUCTSYIIII GUIIIELIHES IV.A.

For plants whose ASIIE Code Class I, 2, and 3

pressure boundary piping meets ttte guidelines of Part III, no augmented inservice Inspection or leak dctecllon requirements beyond those SPecified in the !0 CFR 50.55a(g),

"lnservice Inspection Itcquirencots" and plant Technical Specifications for leakage detection are necessary.

i.

The cosmtcnts on III.C. also apply here.

2.

The comssents on III.C. also apply here.

A.

The licensee has not furnished data on this paragraph in his responses to NRC Generic Letter 81-04.

IY.B.

AS>IE Code Class I aod 2 pr~ssure boundary piping ttsat does not meet guide) ines of Part I I I Is designated "ttuncunfonning" aod must tsave additional l>>service inspection and more stringent leak detection requirements.

Ttte degree of auIgssscnted inservice Inspection of such piping depends oo wtsettEer tnc specific "ttooconforming" piping runs are classified as "Service Seos I tive."

Ine "Service Sens illve" lines were and will be designated by tne ttttC and are deflssed as thuse that have ezpericssced cracking of a gcsseric nature, ur ttsal are considered Lo be S.

The licensee has not furnished data on this paragraph In his responses to ttRC Generic Letter 81-04.

particularly susceptible to cracking because of a corn>>i>>ation of high local stress, material co>>dition, and high oxygen content In the relatively stag>>an'.,

Intermittent, or low-flow coolant.

Cu"renLly, Iur thc >>o>>conf>>rmlng ASHE Code Class 3 piping, no additional Inservic" Inspection beyo>>d thu beetle>>

Xi vlsURI examination is required.

fxamples of piping considered to be "Service Sensitive" include but are noL limited to:

core spray lines, recirculation riser lines,~

recirculation bypass lines (ur pipe extensions/stub tubes on planLs ~here the bypass lines have been removed), control rod drive (CRD) hydraulic return lines, isolation condenser

lines, recirrulatlon i>>let lines at safe ends where crevices are formed by the welded thermal sleeve attaclvxents, and shutdown heat exchanger lines.

If cracking should later be found In a particular pipi>>g run and considered to be generic, it will be designated by the IdIC as "Service Sensitive."

Si>>ce no IGSCC has been observed In the domestic plants and in view of t>>e possible high radiation exposure to the inspection personnel, surveillance and monitoring means other than those specified in Section IV of this report for recirculatio>> riser lines will be considered on a case-Dy-case basis.

p Leakage detection a>>d augmented inservice inspection requlreme>>ts for "Nv>>conforming" lines and "Nu>>conforming, Service Se>>sitive" lines are specified below:

IV.B.I.

"Nu>>conforming" Lines That Are Not "Service Ye7iatLive 1.

fhe cou3aents on IV.B. also apply here.

IV.U.I.a.

Leak Oetection:

The reactor coolant leakage detection systems should be operated under the Tech>>Ical Specification requlremeni,s to enhance the discovery of unidentified leakage that may include through-wal I cracks developed In austenitic stainless steel piping.

a.

The coaments on IV.B. also apply here.

IV.B.).a.(l) lhe )eakage detection system provided should Include sufficiently diverse leak detection methods with adequate sensitivity to detect and measure small leaks In a timely manner and to identify the leakage sources within the practical 1 imits.

Acceptable leakage detection and monitoring systems are described In Section C, Regulatory Position of Regulatory Guide ).45, "Reactor Coolant Pressure Boundary Leakage Oetection Systems'articular attention shou)d be given to upgrading and calibrating those leak detection systems that will provide prompt indication of an increase in leakage rate.

Other equivalent leakage detection and collection systems will be reviewed on a case-by-case basis.

() )

Seg)ART TYA's description of tne Browns Ferry 1, 2, and 3 leak detection methods is not detailed enough to determine if they meet those suggested In Section C of Regulatory Guide 1.45.

OIFFEREHCES The nine subsections of Section C of Regulatory Guide 1.45 are discussed belo~.

C.i TVA has stated that leakage to the primary reactor containment from identified sources is collected Such that the flow rates are monitored separately from unidentified leakage,>

and b.

the total floe rate can be established and mon)tored.w C.2 It Is not clear from the Browns Ferry 1, 2, and 3

Final Safety Analysis Report (FSAR) (Section 4.)0.3) that unidentified leakage to the primary reactor containment can be collected and the flow rate monitored with an accuracy of 1 gpm or better.

C.3 The Browns Ferry 1, 2, and 3 )eak detection systems consist of the following.

a.

Hanual or automatic discharge flow Integrat ion b.

Sump fill timer c.

Sump pumpout timer d.

Drywei 1 continuous air monitor.B The leak detection systems described above are not sufficiently detailed to assess whether the requisite number of )eak deteCtion methods as recmuaended In Regulatory Guide 1.45 are present in the drywells.

C.4 lt Is not clear whether provisions have been made In the Browns Ferry ), 2, and 3 FSAR to monitor systems connected to the RCPB for signs of intersystem leakage.

C.5 There are no Indications that the leakage detection systems described in Subsection C. 3 above are adequate to detect a leakage rate, or its equivalent, of 1 gpm ln less than 1 h.

C.6 The Browns Ferry 1, 2, and 3 drywell continuous air radioactivity monitoring system does not remain functional when subjected to the SSE.

C.l Indicators and alarms for the required leakage detection system are provided in the main control room.

Procedures for converting various indications to a coiuaon leakage equivalent are available to the operators.

It is not known whether calibration of the indicators accounts for the needed independent variables.

C.B 1'he manual or automatic discharge flow integrater and the drywell continuous air monitor can be.

calibrated or tested during operation.

The sump fill timer and sump pumpout timer cannot be calibrated or tested during operation.u C.g The Browns Ferry 1, 2, and 3 FSAR include limiting conditions for Identified and unidentified leakage.

TVA has Identified the Browns Ferry 1, 2, and 3 systems for detecting and monitoring leakage.

Either the sump or air uvnitoring system ls always available.g It cannot be determined from the above whether Drowns Ferry I, 2, and 3 meet Regulatory Guide 1.45, Section C.

NlDITIORAL DATA RE VIREO I.

Indicate whether provisions have been made in the Drowns Ferry I, 2, and 3 FSAR to monitor systems connected to the RCPB fur signs of Intersystem leakage (Subsection C.4 of Regulatory Guide 1.45).

2.

Indicate whether calibration of the indicators accounts for the needed Independent variables (Subsection C.7 of Regulatory Guide 1.45).

3.

TYA should indicate whether the Drowns Ferry I, 2, and 3 leak detection system includes an alrbon>e particulate radioactivity monitoring system and an airborne gaseous radioactivity monitoring system (Subsection C.3 of Regulatory Guide 1.45).

4; Please indicate whether unidentified leakage to the primary reactor cnntainamnt can be collected and the flow rate monitored with an accuracy of 1

gpm or better (Subsecl.ion C.2 of Regulatory Guide 1.45).

5.

Indicate whether the leakage detection systems are adequate to detect a leakage rate, or its equivalent, of 1

gpm In less than 1 h (Subsection C.5 of Regulatory Guide 1.45).

IY.B.I.a.(z)

Plant shutdown should be initiated for inspection and corrective action when any leakage deteci.ion system indicates, within a 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 in rate of unidentified leakage In excess of 2 gallons per minute or Its equivalent, or when the total unldeutifled leakage attains a rate of 5 gallons per minute or its equivalent, whichever occurs first.

For sump level monitoring systems with fixed-measurement interval method, the level shuuld be monitored at 4-hour intervals or less.

(2)

SNNAR Y TVA has not proposed a requirement for shutdown after a 2-gpm increase in unidentified leakage ln 24 h Into the Technical Specifications for Browns Ferry I, 2, and 3.

TYA has not proposed a requirement for monitoring the sump level at 4-h intervals (or less).

OIFFEREHCES HUREG-0313, Rev.

I requires that reactor shutdown be initiated when there is a 2-gpm Increase in unidentified leakage In 24 h.

For senp level monitoring systems with the fixed-measurement interval method, the level should be monitored every 4 h or less.

INC Generic Letter 81-04 requires that the above requirements be incorporated ln the plant Technical Specifications.

TYA has not incorporated the provision for shutdown for a 2-gpm Increase In unidentified leakage In 24 h in the Drowns Ferry I, 2, and 3 Technical Specifications.~

Also, It Is not known whether TVA monitors the sump level every 4 h.

ADDlTIOHALDATA RE UlRED Indicate the monitoring interval of the sump level monitoring system.

IV.B.I.a.(3)

Unidentified leakage should include all leakage other than:

IY.B.l.a.(3)(a)

Leakage Into closed systems, such as pump seal or valve packing leaks that are captured, flow metered, and conducted to a sump or collecting tank, or (3)

(a)

Ho cmnxent made because alternative plans were not evaluated.

TYA meets HNIEG-0313, Rev.

1 ln this matter (FSAR Section 4. 10.3).

The comnents on IV.B.).a.(3) also apply here.

iv.B.l.a.(3)(b)

Leakage into the containment atmosphere from sources that are both specifically located and known either not to Interfere with the operations of unidentified leakage monitoring systems ur not to be from a through-wall crack in the piping within the reactor coolant pressure boundary.

(b)

The coxments on IV.G.l.a.(3) also apply here.

IV.B.).b.

Auginentcu lnservice inspection:

Inservice inspect!on of the "Nonconfonaing, Nouservice Sensitive" lines should be conducted in accordance with the following progr@an*

b.

The coaw.'nts on IV.B.l.b.(l) also apply here.

'luis progrma is largely taken from the requirements of ASHE Boiler L Pressure Vessel Code, Section Xl, referenced in the part (b) of IO CFR 50.55a, "Codes and Standards."

IV.B.l.b.(l) For ASHE Code Class I coayonents and piping, each pressure-retaining dissimilar metal weld subject to Inservice inspection requirements of Section XI should be examined at least once in no more than 80 months (two-thirds of the time prescribed in the ASHE Boiler and Pressure Vessel Code Section XI).

Such examination should include all internal attacinaent welds that are not through-wall welds but are welded to or form part of the pressure boundary.

(1)

SIZIISlRY TVA takes exception to the Inspection requirements for the 28-in. dimneter recirculation outlet. nozzle safe end welds and 20-ln. diameter residual heat removal (RUR) supply line Isolation valve welds.

For the former, TVA has detenalned that Stress Rule Index (SRI) values are below

).2, the SRI value below ~hich no IGSCC has been found.

The latter are considered haaune to IGSCC.

Also, TVA has classified the above ASHE Code Class 1 pipe cmaponents as "nonservice sensitive".

They should be classified as "service sensitive" because NRC now considers these piping systems as "service sensitive."

TVA has not supplied enough data to determine if the ferrite content of the 20-In. RIN valves is to the level where IGSCC Is minimized.

In not classifying the above pipes as "service sensitive",

TVA does not meet NUREG-03)3, Rcv. l.

0 IFFERENCES NUREG-03)3, Rev.

1 requires that "nonservlce sensitive" and "service sensitive" pipes be subject to an augmented ISI progr@a.

Selection aietliods for "nonservice sensitive" and "service sensitive" pipes to be exon)ncd are found In Part IV.B.).b. and IV.B.2.b. of NUREG-0313, Rev.

1, respectively.

For the 28-In. diameter recirculation outlet nozzle safe end wclds, TVA p)ans to use the SRI as a means of determining which welds should be smap)ed.

Research at, General Electric Indicates that for welds with SRI

<< 1.2, IGSCC does not occur.

Since the recirculation outlet nozzle safe end welds have SRI << 1.2, I'VA has concluded that they need not bc subjected tu augmented ISI.

NUREG-0313, Rev.

I requires that all ASHE Code Class I coaponeuts be subjected to augavzntcd ISI.I

For the 20-In. diameter RIB stainless valve welds, the valve bodies are SA-35)

CFDH.

These are stainless steel castings and probably contain delta ferrite.

This would exclude them from augmented ISI if the delta ferrite content were above five percent.

Delta ferrite readings have not been taken on these castings;

however, TVA Indicates that they will be taken and documented at the next refueling outage for each unit.

81NEG-03)3, Rev.

I Indicates that if a cast stainless steel has a delta ferrite of five percent'r

more, then that material is considered corrosion-resistai>t.

Also, TVA has c)asslfled the 28-In. diameter recirculation outlet nozzle safe end we)ds and 20-ln.

diva@ter RIII supp'ly

) Ings Isolation valve we)ds as "nonservice sensitive".'hese.pipe cenponents are classified as "service sensitive" by RUREG-0313, Rev. I and should meet Part IV.8.2.b. of HUBEG-0313, Rev. l.

ADDITIDtlALDATA RE UIRED The ferrite content of the 20-ln.

RHR valve bodies must be documented.

IV.D.I.b.(2)

Ihe following ASHE Code Class I pipe welds subject to inservice inspection requirements of Section Xl sliou)d be examined at least once in no more than 80 months LV.8.I.b.(2)(a)

All welds at terminal ends'f pipe at vessel nozzles; "ierminal ends are the extremities of piping runs that connect to structures, components (such as vessels,

pumps, valves) or pipe ancnurs, each of which acts as rigid restraints or provides at least two degrees of restraint to piping therma) expansion.

(a)

SINHARY TVA takes exception to requiring inspection on the recirculation outlet nozzle pipe welds because the largest SRI value for those terminal ends Is ).ll.

Also, TVA has classified the abovementloned ASHE Code Class I piping components as "nonservice sensitive".

They should be "service sensitive" because Id)C now considers these piping systems as "service sensitive".

ln not classifying the above piping components as "service sensitive" TVA does not meet IIUREG-03)3, Rev. l.

TVA has also not supplied enough data to determine the SRI value below which no IGSCC Is expected to occur.

DIFFERENCES TVA does not plan to Inspect the recirculation outlet nozzle pipe welds per the 80-month schedule HlNEG-0313, Rev.

I because no IGSCC has been found In pipes with SRI < ).2 and the SRI value for these we)ds is 1.11.

TherefOre,

'IVA plans to Inspect the welds per the 120-month ASHE schedu)e.f

TVA has also classified these piping components as "nonservlce sensitive".

They should be classified as "service sensitive" and meet Part IV.B.2.b. of KDREG-0313, Rev. l.

ADDITIONAL DATA RE IREO Calculated SRI values can vary depending on who made the calculations.

Indicate whether SR I values were calculated for the above pipes by any other consultant.

Identify the effect of low temperature sensitization on welds with SRI values close to 1.20 (e.g., I.ll).

lv.U.l.b.(2)(b)

All welds having a design cexbined primary plus secondary stress range of 2.4S, or more; (b)

SINI4IIRY TVA takes exception to the requirements In Parts IV.B.I.b.(2)(b) and IV.B.I.b.(2)(c) because these requirements are based on an Edition and Addenda to the ASHE Code ~rltten after the one on which the Bruwns Ferry I, 2, and 3 ISI requirements are based.

Instead, TVA proposes to use the SRI as a means of selecting pipes to be Inspected per the augmented ISI program.

However, 1VA has not supp)led data on the SRI values for these ASHE Code Class I

pipes.

DIFFERENCES Parts IV.B.l.b.(2)(b) and IV.B.l.b.(2)(c) require testing for those welds exceeding certain values of primary plus secondary stress range and cumulative fatigue usage factors.

These quantities do not exist for Browns Ferry I, 2,

and 3 because the Code to which they were built did not r~quire calculation of these quantities.

Instead, TVA proposes to use the SRI to determine which pipe welds are most susceptible to IGSCC.~

ADDITIONALDATA RE IREO IV.B.l.b.(2)(c)

All welds having a design cumulative fatigue usage factor of 0.4 ur more; and identify the SRI value below which no auyxented ISI wi I I be perforxjed.

(c)

SWeWV TVA takes exception to the requlrexents In Parts IV.B.l.b.(2)(b) and IV.B.l.b.(2)'c) because these requirements are based on an Edition aid Addenda to the ASHE Code written after the one on which the Drowns Ferry I, 2, and 3 ISI requlrenmnts are based.

Instead, TVA proposes to use the SRI as a means of selecting pipes to be inspected per the auyxented ISI progra~.

However, TVA has not supplied data on the SRI values for these ASHE Code Class I

p ipes.

IV.B.l.b.(2)(d)

Sufficient additional welds with high potential for cracking to make the total equal to 251 of the welds In each piping systex.

0 IFF ERERCES Parts IV.B.l.b.(2)(b) and IV.B.l.b.(2)(c) require testing for those welds exceeding certain values of primary plus secondary stress range and cumulative fatigue usage factors.

These quantities do not exist for Browns Ferry I, 2, and 3 because the Code to which they were built did not require calculation of these quantities.

Instead, TVA proposes to use the SRI to determine which pipe welds are most susceptible to IGSCC.~

AOOITIOIIAL OATA RE IREO Identify the SRI value below which no augmented ISI wl I I be performed.

(d)

SIISllllY TVA takes exception to the inspection requirements for the 28-In. diameter recirculation piping, 22-In. dimneter recirculation piping manifold, 24-In. diameter RIG supply

lines, and 20-ln. diameter RIM supply lines.

TVA plans to use SRI to select the welds to be Inspected.

TVA does not comply with the method by which pipes are to be selected for augmented ISI and the Inspection Interval.

Also, TVA has classified the 28-ln. diameter recirculation piping and 22-ln. diameter recirculation piping manifold as "nonservlce sensitive".

These ASHE Code Class 1 pipes should be "service sensitive" because BRC now considers these piping systems as "service sensitive".

By not classifying the above piping components as "service sensitive",

TVA does not meet IIUREG-0313, kev. I.

TYA has also not supplied sufficient data to fully characterize the augmented ISI program for the above piping.

0 IFFEREHCES NUREG-0313, Rev.

1 requires that In addition to tho welds ln Parts IV.B.l.b.(2)(a), (b), and (c) that "sufficlent additional Melds with high potential for cracking (be added) to make the total equal to 25K of the welds In each plplng system."

TVA will use SRI to select th'e welds to be Inspected and will not Inspect the pipes at the BO-month interval required by Part IV.B.I.b. of IIUREG-0313. Rev. I.

Also, If the number of welds having SRI values 1.2 or greater exceeds 25K of the total welds, then only 25K of the total welds will be Inspected.

Finally, HNEG-0313, Rev.

I considers the 28-in.

dia<<<eter recirculation piping and the 20-in. dia<<<eter recirculation piping manifold as service sensitive" piping.

TVA has classified them as "nonservice sensitive" piping.T IV.B.l.b.(3)

The following ASIDE Code Class 2 pipe WeldS, SuujeCt tO inSerVICe InSpeCtlOn requirements of Section XI, in each residual heat re<nova! syste<as, emergency core cooling systems, and containment heat re<<<oval systems should be examined at least once ln no more than 80 months:

The additional data required Inclu<le:

I.

Proportion of welds described by Parts IV.B.l.b.(2)(a)-(d) that have SRI values equal to or greater than 1.2.

2.

Whether the 28-In. diameter recirculation piping and 20-in. dla<aeter recirculation piping manifold have been reclassified as "service sensitive" piping.

(3)

SUHHARV TYAsill not inspect the ASIIE Code Class 2 stainless steel piping because they are exempt from the 1975 ASIIE Section XI ISI requirements.

TVA does not meet HNEG-0313, Rev. I In this matter.

DIFFEREHCES HUREG-0313, Rev. I requires that a certain proportion of ASIIE Code Class 2 pipe welds be inspected.

TVA's position is that all of the AQlE Code Class 2

stainless steel piping systems are exempt from the inservlce inspection requirements of the 1975 Section Xl because the control of che<<<lstry of the contained fluid which Is Intended to mlnlmlze corrosive effects, particularly stress corrosion, Is verified by periodic sampling and test.

!herefore, they do not perform any aug<<<outed Inservlce Inspections on Class 2 stainless piping.~

AUD IT IOHAL DATA REI)UIRED Hone.

IV.U.l.b.(3)(a)

IV.O.l.b.(3)(b)

All welds of the terminal ends of pipe at vessel

nozzles, and At least IUX of tne welds selected proper tionately from the following categories:

(a)

The co<<<<<cuts on IV.B.I.b.(3) also apply here.

(b)

The co<u<<ents on IV.O.l.b.(3) also apply here.

II

IV.B.I.b. (3)(b}(I)

Circumferential welds at locations where the stresses under the loadings resulting from ~an plant conditions as calculated by the sum uf Equations (9) and (10) in NC-3652 exceed 0.8 (1.2Sh

> SA);

(I) the ceoaents on IV.B.l.b.(3) also apply here.

IV.B.l.b.(3)(b)(ii)

Melds at terminal ends of piping,,

including branch runs; (ii)

The couments on IV.B.l.b.(3) also apply here.

IV.U.I.b. (3) (b) (Ill) Oiss imilar metal welds;

( I II) The contents on IV.B.I.b. (3) also apply here.

IV.B.l.b.(3)(b)(iv)

Melds at structural discontinuities; and IV.B.l.b.(3)(b)(v)

Melds that cannot be pressure tested in accordance with IMC-5000.

The welds to be examined shall be distributed approximately equally among runs (or portions of runs) that are essentially similar in design, size, system function, and service conditions.

(iv)

The ceuuents on IV.B.l.b.(3) also apply here.

(v)

The comaents on IV.B.l.b.(3) also apply here.

IV.B.l.b.(4)

The following ASHE Code Class 2

pipe welds in systems other than residual heat removal systems, emergency core cooling systems, and containment heat removal systems, which are subject to Inservice Inspection requirements of Section XI, should oe inspected at leasL once In no more than 80 mouths:

(L)

LIHHAIIY TVA will not Inspect the ASHE Code Class 2 stainless steel piping because they are exempt from the 1975 ASHE Section Xl ISI requirements.

TVA does not meet NUAEG-0313, Aev.

1 in this matter.

OIFFENENCES NUI<EG-0313, Nev.

1 requires that a certain proporLion of ASHE Code Class 2 pipe welds be inspected.

TVA's position is that all of the ASHE Code Class 2

stainless steel piping systems are exempt from the Inservice Inspection of the 1975 Section XI because the control of chemistry of the contained fluid which is Intended to minimize corrosive effects, particularly stress corrosion, Is verified by periodic sampling and teaL.

Therefore, they will qot perform any augmented Inservice Inspections on ASHE Code.~

None.

IV.U.l.b.(4)(a)

IV.B.l.b.(4)(b)

All welds at locations where the stresses under the loadings resulting from "Normal" and "Upset" plant conditions Including the operating basis earthquake (OUE) as calculated by the sum of Equations

9) and

( 10) In NC-3652 exceed 0.8 1.25h i SA);

All welds at terminal ends of piping, including branch runs; (a)

The ceoxents on IV.B.l.b.(4) also apply here.

(b) ihe comments on IV.B-l.b.(4) also apply here.

IV.U.I.b. (4) (c)

All dissimilar metal welds; (c)

The comuents on IV.B.l.b.(4) also apply here.

IV.B. I.b. (4) (d)

Additional welds with high po tent Ia 1 for cracking at structural discontinuities* such that the total number uf welds selected for examination equal to 25X of the circumferential welds in each piping system.

(d)

The comnents on IV.B.l.b.(4) also apply here.

'Structural discontinuities include pipe weld Joints to vessel

nozzles, valve bodies, pump casings, pipe fittings

{such as elbows,

tees, reducers, flanges, etc., conforming to ANSI Standard 8 )6.9) and pipe branch connections and flttings.

IV.B.I.b.{5)

IV.U.I.b.(6)

If examination of (I), (2), (3),

and (4) above conducted during the first 80 months reveal no incidence of stress corrosion cracking, the examination frequency thereafter can revert to 120 months as prescribed in Section Xl of the ASIDE Boiler and Pressure Vessel Code.

Sampling plans other than those described in (2), (3),

and (4) above will be reviewed on a case-by-case basis.

(5)

The licensee has not furnished data on this paragraph in his responses to NRC Generic l.etter BI-04.

(6)

The comnents on IV.B.l.b.(l), (2), (3), and (4) also apply here.

IV.U.2.

Nonconforming" Linus Ihat are "Service Sensitive" I V.U.2.a.

Leak Uetect ion:

Inu leakage detection requirmxents, described in IV.U.l.a above, should be implemented.

IV.B.2.b.

Augmented lnserv ice inspection:

IV.B.2.b.(I)

IV.8.2.b.(2) lhe welds and adjoining areas of bypass piping of the discharge valves in the main recirculation

loops, and of the austen)tie

'tainless steel reactor core spray piping up to and including the second isolation valve, should be examined at each reactor refueling outage or at other scheduled plant ou tages.

Successive examination need not be closer than 6 months, If outages occur more frequently than 6 months.

This requirement applies to all welds In all bypass lines ~nether the 4-inch valve is kept open or closed during operation.

In the event these examinations f)nd the piping free of unacceptable Indications for three successive Inspections, the examination u<ay be extended to each 36-month period (plus or minus by as much as 12 months) coincident with a refueling outage.

In these

cases, the successive examination may be limited tu all welds In one bypass pipe run and one reactor core spray piping run.

If unacceptable flaw indications are

detected, the remaining piping runs in each group should be examined.

ln the event these 36-month period examinat tons reveal no unacceptable indications for three successive inspections, U<e welds and adjoining areas of these piping runs should be examined as described In IV.B.).b()) for dissimilar metal welds and in IV.B.).b(2) for other welds.

lhe d)ssl<<<i)ar metal Molds and adjoin)n<l areas of other ASHE Code Class

)

Service Sens Itive" piping should be exa<<<ined at each reactor refueling outage or at other scheduled plant outages.

() )

Sag)ART TVA takes exception to the Inspection period for the 4-in. diameter recirculation lines.

TVA has not supp) led SRI values for the ASHE Code Class I piping component in question.

Also,< the 12-in. diameter stainless steel core spray piping has been replaced with carbon steel on Drowns Ferry 2 and 3 and ls exempt from HNEG-313, Rev.

1.

The corresponding piping In Drowns Ferry 1 will be inspected at every outage until It Is replaced.

TVA meets RNEG-0313, Rev.

1 In this matter.

DIFFEREHCES HUREG-0313, Rev.

1 requires that recirculation loop discharge valve bypass piping welds and adjoining areas and the reactor core spray bypass piping be subject to an augmented 1SI program.

TVA has removed the 4-In. diameter recirculation bypass

)ines.

TVA feels that the remaining portions of the bypass lines Mill have low SRI values because the pipe reaction loads have been eliminated.

TVA plans to inspect the stuhs at 60 t 12 month Interva)s.>

ADDITIOIIALDATA RE UIRED Identify the SRI values for the 4-In. diameter recirculation bypass line stubs.

(2)

SISHARY TVA takes exception to the inspection period requirements In IINEG-0313, Rev. I for the dissimilar metal Molds at the 12-in. diameter recirculation inlet nozzle safe ends.

TVA wants to modify the Inspection requirements for these ASHE Code Class I pipes.

TVA has not supplied sufficient data on the au<j<<<outed ISI prugra<a to fully characterize it.

Successive examinations need not be closer than 6 months, if outages occur more frequently than 6 months.

Such examination should include all internal attachments that are not through-wall welds but are welded to or form part of the pressure boundary.

OIFFERENCES NUREG-0313, Rev.

1 requires that the dissimilar metal welds at the 12-ln. dianx.ter recirculation Inlet nozzle safe ends be subject to an augmented ISI program.

TVA has had SRI values calculated for the 12-in. diameter recirculation inlet nozzle safe ends.

Since these SAI values are less than 1.2 and no IGSCC has been observed for welds with SRI values less than 1.2, TVA does not plan to perform the augmented ISI on the abovementioned welds.T ADOITIONAL OATA RE UIREO l.

IVA's proposed ISI schedule for the 12-in.

diameter recirculation Inlet nozzle safe ends.

2.

Identify the Individual Sill values for the safe end welds.

3.

Ilas a second calculation by another contractor of SRI for the abovementioned welds been madel The welds and adjoining areas of other ASNE Code Class 1 "Service Sensitive" piping should be examined using the sampling plan described in IV.B,I.b(2) except that the frequency of such examinations should be at each reactor refueling outage or at other scheduled plant outages.

Successive examinations need not be closer than 6 months, if outages occur more frequently than 6 months,

{3)

SUIVQR V TVA has classified the 12-In. recirculation riser lines and the 6-ln. reactor water cleanup sweepolet as "nonservice sensitive".

They should be classified as "service sensitive" because IIIC now considers these piping systems as "service sensitive".

Also, 1VA has proposed alternate augmented ISI plans for the 6-in. diameter reactor water cleanup and 6-In. diameter head spray lines.

These alternate augmented ISI plans differ from NUREG-0313, Rev. l.

TVA does not meet NUREG-0313, Rev.

1 in these matters.

DIFFERENCES NUREG-0313, Rev.

I has classified recirculation riser lines and and reactor ~ater cleanup sweepolets as "service sensitive" ASHE Code Class I piping.

TVA has taken exception to this and has proposed that they be classified as 'nonservlce sensitive".

1he proposed "nonservice sensitive" classification for the 12-in. recirculation riser

>ines ls based on recent augmented ISI examinations during which no Indications of IGSCC were found.

The proposed "nonservice sensitive" classification for the 6-in. reactor water cleanup sweepolets was based on the sweepolets being welded to the 20-in. AIII supply line which Is also classified by TVA as "nonservlce sensitive".

HUREG-0313, Rev.

I requires that "service sensitive" piping be subjected to an augmented ISI program.

TVA has proposed an alternative ISI program for the 6-ln. diaamter reactor water cleanup and the 6-In. dianmter head spray lines.

The TVA ISI plan for the reactor water cleanup Is

"...eacli refueling cycle until lt Is replaced "

The TVA ISI plan for the head spray lines is 60 months.)

ADDITIOIIALDATA RE UIRED Hone.

The adjoining areas of internal attachment welds in recirculation inlet lines at safe ends where crevices are formed by the welded thermal sleeve attachments should be examined at each reactor refueling outage or at other scheduled plant outages.

Successive examinations need not be closer than 6 months, if outages occur more frequently than 6 months.

In the event the examinations described in (2), (3) and (4) above find the piping free of unacceptable Indications for three successive inspections, the examination may be extended to each 36-month period (pius or minus by as much as 12 months) coinciding with a refueling outage.

In the event these 36-month period exmuinatlons reveal no unacceptable indications for three successive inspections, the frequency of examination may revert to 80-month periods (two-thirds the time prescribed in the ASME Code Section XI).

(4)

SUNIARY TVA has suggested an alternative plan for the selection,

sampling, and inspection Interval for recirculation Inlet lines at safe ends which are ASHE Code Class I pipes.

TVA has not supplied sufficient data on the alternative inspection pian to fully characterize It.

DIFFEREHCES HUREG-0313, Rev, I requires that "service sensitive" piping be subJected to an augmented ISI progr@a.

TVA has offered an alternative ISI plan.

Instead of inspecting all

crevices, TVA will select a number of crevices sufficient to represent 25% of the crevices and Inspcc) these selected crevices at intervals of 60 + 12 months.

ADDITIONALDATA RE UIREO l.

Identify the SRI values of the above crevices.

2.

Mhen were the crevices last InspectedT 3.

Please provide a copy of the inspection technique(s) specifications.

(5)

The licensee has not furnislied data on this paragraph in his responses to HRC Generic Letter 81-04.

IV.B.Z.b.(b)

Ihe area, extent, and frequency hf examination of the auynented Inservlce inspection for ASHE Code Class 2 "Service Sensitive'ines will be determined on a case-by-case basis.

(6)

SIX4HARV TVA wIII not Inspect the ASHE Code Class 2 stainless steel piping because they are exempt from the 1915 ASHE Section XI ISI requirements.

TVA does not meet NUREG-0313, Rev.

1 in this matter.

DIFFERENCES NUREG-0313, Rev. I requires that a certain proportion uf ASHE Code Class 2 pipe Melds be inspected.

TVA's position ls that all of the ASHE Code Class 2

stainless steel piping systems are exeapt from the inservlce inspection of the 1975 Section XI because the control of chemistry of the contained fluid which Is intended to minimize corrosive effects, particularly stress corrosion, Is verified by periodic sampling and test.

Therefore, they do not perform any augmented inservlce Inspections on Class 2 stainless piping.'DDITIONAL DATA RE UIRED None.

IV.B.3~

Nondestructive Examination NDE Re ulrements The method of examination and volume of material to ue examined, the allowable indication standards, and examination procedures should cearly with the requlrenents set forth ln the applicable Edition and Addenda of the ASHE Code, Section Xl, specified In Part (g), "Inservlce inspection Requlreuents," of 10 CFR 50.55a, "Codes and Standards."

(3) lhe licensee has not furnished data on this paragraph ln his responses to KRC Generic Letter 81-04.

ln smxe cases, the code examination procedures may not be effective for detecting or evaluating IGSCC and other ultrasonic (UT) procedures or advanced nondestructive examination techniques may be required to detect and evaluate stress corrosion cracking ln austenltic stainless steel piping.

Improved UI procedures have been developed by certain organizations.

These Improved UT detection and evaluation procedures that have been or can be dmnonstrated to the ISC to be effective in detecting IGSCC should be used in the Inservlcu inspection.

Recoumendatlons for the development and eventual implwu.ntatlon of these Improved techniques are Included in Part V.

V.

GEIIERAL RECUIIIIEIIUAIIOIIS The measures oui..lned In part III of thi document provide for positive acti".).'. I!wt are consistent <<Ith current technology.

The Impleamntatlon of these actions should markedly reduce the susceptibility of stainless

.'.i.el piping Io stress corrosion cracking in IIWRs.

It is recognized that additional means could be used to limit the extent of stress corrosion cracking of IIWR pressure boundary piping materials and to Improve the overall system Integrity.

These include plant design and operational procedure considerations to reduce system exposure to potentially aggressive environment, impruved iaaterlai selection, special fabrication and melding techniques, and provisions for volumetric inspection capabi) lty in the design of weld joints.

The use of such means:to limit ICSCC or to improve plant system integrity IIII be reviored on a case-by-case baSiS.

V.

The licensee has not furnished data on this paragrai>h ln his responses to NRC Generic Letter 8)-04.

~

TABLE 2 SUMMARIES OF EVALUATION OF LICENSEE'S RESPONSES II.C Material Selection,

Testing, and Processing Guidelines for BWRs with an Operating License TVA has replaced some "service sensitive" lines with conforming materials.

TVA also has contingency plans to replace other "service sensitive" lines.

TVA meets the requirements of NUREG-0313, Rev.

1 regarding replacement material for nonconforming piping.

IV.B.l.a.(1)

Leak Oetection Methods TVA's description of the Browns Ferry 1, 2, and 3 leak detection methods is not detailed enough to determine if they meet those suggested in Section C of Regulatory Guide 1.45.

IV.B.l.a.(2)

Shutdown for Leakage TVA has not proposed a requirement for shutdown after a 2-gpm increase in unidentified leakage in 24 h into the Technical Specifications for Browns Ferry 1,

2, and 3.

TVA has not proposed a requirement for monitoring the sump level at 4-h intervals (or less).

IV.B.l.b.( 1)

Augmented ISI for "Nonservice Sensitive" Piping TVA takes exception to the inspection requirements for the 28-in.

diameter recirculation outlet nozzle safe end welds and 20-in.

diameter residual heat removal (RHR) supply line isolation valve welds.

For the former, TVA has determined that Stress Rule Index (SRI) values are below 1.2, the SRI value below which no IGSCC has 28

been found.

The latter are considered immune to IGSCC.

Also, TVA nas classified the above ASME Code Class 1 pipe components as "nonservice sensitive".

They should be classified.

as "service sensitive" because NRC now considers these piping systems as "service sensitive".

TVA has not supplied enough data to determine if the ferrite content of the 20-in.

RHR valves is to the level where. IGSCC is minimized.

In not classifying the above pipes as "service sensitive",

TVA does not meet NUREG-0313, Rev. l.

IV.B.l.b.(2)(a)

Augmented ISI for ASME Code Class 1 Pipe Melds at Terminal Ends of Pipe at Vessel Nozzles TVA takes exception to requiring inspection on the.recirculation outlet nozzle pipe welds because the largest SRI value for those terminal ends is 1.11.

Also, TVA has classified the*abovementioned ASME Co~e Class 1 piping comoonents as "nonservice sensitive".

They should ae "service sensitive" because NRC now considers these piping systems as "service'ensitive".

In not ciassifying the above piping components as "service sensitive" TVA does not meet NUREG-0313, Rev.

1.

TVA has also not supplied enough data to determine the SRI value below which no IGSCC is expected to occur.

IV.B.l.b.(2)(b)

Augmented ISI for ASME Code Class 1 Pipe Melds Having a

Oesign Combined Primary Plus Secondary Stress Range of 2.4S or More TYA takes exception to the r equirements in Parts IV.B.l.b.(2)(b) and IV.B.l.b.(2)(c) because these requirements are based on an Edition and Addenda to the ASME Code written after the one on which the Browns Ferry 1, 2,

and 3 ISI requirements are based.

Instead, TYA 29

proposes to use the SRI as a means of selecting pipes to be inspected per the augmented ISI program.

However, TVA has not supplied data on the SRI values for these ASNE Code Class 1 pipes.

IV.B.l.b.(2)(c)

Augmented ISI for ASNE Code Class 1 Pipe Melds Having a

Design Cumulative Fatigue Usage Factor of 0.4 or Nore TYA takes exception to the requirements in Parts IV.B.l.b.(2)(b) and IY.B.l.b.(2)(c) because these requirements are based on an Edition and Addenda to the ASNE Code written after the one on which the Browns Ferry 1, 2, and 3 ISI requirements are based.

Instead, TYA proposes to use the SRI as a means of selecting pipes to be inspected per the augmented ISI program.

However, TVA has not supplied data on the SRI values for these ASME Code Class 1 pipes.

IV.B.l.b.(2)(d)

Augmented ISI for ASME Code Class 1 Pipe Melds with High Potential for Cracking TYA takes exception to the inspection requirements for the 28-in.

diameter recirculation piping, 22-i'. diameter recirculation piping manifold, 24-in. diameter RHR supply lines, and 20-in. diameter RHR supply lines.

TVA plans to use SRI to select the welds to be inspected.

TVA does not meet the method by which pipes are to be selected for augmented ISI and the inspection interval.

Also, TVA has classified the 28-in. diameter recirculation piping and 22-in.

diameter recirculation piping manifold as "nonservice sensitive" because NRC now considers these piping systems as "service sensitive".

These ASNE Code Class 1 pipes should be "service sensitive" because NRC now considers these piping systems as "service sensitive".

By not classifying the above piping components as "service sensitive",

TVA does not meet ilUREG-0313, Rev.

1.

TVA has also not supplied sufficient data to fully characterize the augmented ISI program or the above piping.

30

IV.B.l.b.(3)

Augmented ISI For ASHE Code Class 2 Pipe fields TVA will not inspect the ASHE Code Class 2 stainless steel piping because tney are exempt from the 1975 ASHE Section XI ISI requirements.

TVA does not meet NUREG-0313, Rev.

1 in this matter.

IV.B.l.b.(4)

Augmented ISI for ASME Code Class 2 Pipe Melds TVA will not inspect the ASME Code Class 2 stainless steel piping because they are exempt from the 1975 ASHE Section XI ISI requirements.

TVA does not meet NUREG-0313, Rev.

1 in this matter.

IV.B.2.b;(1)

Augmented ISI for Welds and Adjoining Areas of Bypass Piping of the Discharge Valves in the Hain Recirculation Loops and Reactor Core Spray Piping TVA takes exception to the inspection period for the 4-in. diameter recirculation lines.

TVA has not supplied SRI values for the ASHE Code Class 1 piping component in question.

Also, the 12-in; diameter stainless steel core spray piping has been r eplaced witn carbon steel on Browns Ferry 2 and. 3 and is exempt from NUREG-313, Rev.

1.

The corresponding piping in Browns Ferry 1

will be inspected at every outage until it is replaced.

TVA meets NUREG-0313, Rev.

1 in this matter.

IV.B.2.b.(2)

Augmented ISI for Dissimilar Metal Melds and Adjoining Areas of Other ASHE Code Class 1 "Service Sensitive" Piping TVA takes exception to the inspection period requirements in NUREG-0313, Rev.

1 for the dissimilar metal welds at the 12-in'iameter recirculation inlet nozzle safe ends.

TVA wants to modify the inspection requirements for these ASHE Code Class 1 pipes.

TYA has not supplied sufficient data on the augmented ISI program to fully characterize 'it.

IV.B.2.b.(3)

Augmented ISI for Welds and Adjoining Areas of Other ASME Code Class 1 "Service Sensitive" Piping TVA has classified the 12-in. recirculation riser lines and the 6-in. reactor water cleanup sweepolet as "nonservice sensitive".

They should be classified as "service sensitive" because NRC considers these piping systems as "service sensitive".

Also, TVA has proposed alternate augmented ISI plans for the 6-in. diameter reactor water cleanup and 6-in. diameter head spray lines.

These alternate augmented ISI, plans differ from NUREG-0313, Rev.

1.

TVA does not meet NUREG-0313, Rev.

1 in these matters.

IV.B.2.b.(4)

Augmented ISI for Internal Attachment Weld Crevices in Recirculation Inlet Lines at Safe Ends TVA has suggested an alternative plan for the selection,

sampling, and inspection interval for recirculation inlet lines at safe ends which are ASME Code Class 1 pipes.

TVA has not supolied sufficient data on the alternative inspection plan to fully charac erize it.

IV.B.2.b.(6)

Augmented ISI for ASME Code Class 2 Pipe Welds TVA will not inspect the ASME Code Class 2 stainless steel piping because they are exempt from the 1975 ASME Section XI ISI requirements.

TVA does not meet NUREG-0313, Rev.

1 in this matter.

32

TABLE 3 OIFFERENCES BETWEEiV NUREG-0313, REV.

1 AND LICENSEE'S RESPONSES II.C Material Selection,

Testing, and Processing Guidelines for BWRs with an Operating License There are no differences between TVA's proposals and NUREG-0313, Rev.

1 requirements on replacement material for nonconforming piping.

However, there is not sufficient detail in Reference 7

7 to fully evaluate TVA's compliance.

IV.B.l.a.(1)

Leak Oetection Methods NUREG-0313, Rev.

1 requires that leak detection and monitoring methods meet with Section C of Regulatory Guide 1.45.

The nine subsections of Section C are discussed below.

C. 1 TVA has stated tnat leakage to the primary reactor containment from identified sources is collected such that a.

the flow rates "re monitored separately from unidentified le'kage, and b.

the total flow rate can be established and monitored. 9 C.2 It is not clear from the Browns Ferry 1, 2, and 3 Final Safety Analysis Repo. t (FSAR) (Section 4.10.3) that unidentified leakage to the primary reactor containment can be collected and the flow rate monitored with an accuracy of 1

gpm or'better.

C.3 The Browns Ferry 1, 2, and 3 leak detection systems consist of the following.

33

a.

Manual or automatic discharge flow integration b.

Sump fill timer c.

Sump pumpout timer Orywel 1 continuous air monitor.

The leak detection systems described above are not sufficiently detailed to assess whether the requisite number of leak detection methods as recommended in Regulatory Guide 1.45 are present in the drywells.

C.4 It is not clear whether provisions have been made in the Browns 'Ferry 1, 2, and 3 FSAR to monitor systems connected to the RCPB for signs of intersystem leakage.

C.5 There are no indications that the leakage detection systems described in Subsection C.3 above are adequate to detect a

leakage rate, or its equivalent, of 1

gpm in less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

C.6 The Browns Ferry 1, 2, and 3 drywell continuous air radioactivity monitoring system does not remain functional when subjected to the SSE.

C.7 Indicators and alarms for the required leakage detection system are provided in the main control room.

Procedures for converting various indications to a common leakage equivalent are available to the operators.

It is not known whether calibration of the indicators accounts for the needed independent variables.

C.B The manual or automatic discharae flow-integrater and the drywell continuous air monitor can be calibrated or tested

~ during operation.

The sump fill timer and sump pumpout timer cannot be calib~ated or tested during operation.

C.g The Browns Ferry 1, 2, and 3 FSAR include limiting conditions for identified and unidentified leakage.

TVA has,identified the Browns Ferry 1, 2, and 3 systems for detecting and monitoring leakage.

Either the sump or air monitoring system is always available.

It cannot be determined from the above whether Browns Ferry 1, 2, and 3 meet Regulatory Guide 1.45, Section C.

IY.B.l.a.(2)

Shutdown for Leakage NUREG-0313, Rev.

1 requires that reactor shutdown be initiated when there is a 2-gpm increase in unid.ntified leakage in 24 h.

For sump level monitoring systems with the fixed-measurement interval method, the level should be monitored every 4 n or less.

NRC Generic 'Letter 81-04 requires that the above requirements be incorporated in the plant Technical Specifications.

TVA has not incorporated the provision for shutdown for a 2-gpm increase in unidentified leakage in 24 h in the Browns Ferry 1, 2,

and 3 Technical Specifications.

Also, it is not known whether TVA monitors the sump level every 4 h.

IV.B.l.b.(1)

Augmented ISI for "Nonservice Sensitive" Piping NUREG-0313, Rev.

1 requires that "nonservice sensitive" and "service sensitive" pipes be subject to an augmented ISI program.

Selection methods for "nonservice sensitive" and "service sensitive" pipes to be examined are found in Part IV.B.l.b. and IV.B.2.b. of NUREG-0313, Rev.

1, respectively.

35

For the 28-in. diameter recirculation outlet nozzle safe end

welds, TVA plans to use the SRI as a means of determining which welds should be sampled.

Research at General E'lectric indicates that for welds with SRI < 1.2, IGSCC does not occur.

Since the recirculation outlet nozzle safe end welds have SRI < 1.2, TVA has concluded that they need not be subjected to augmented ISI.

NUREG-0313, Rev.

1 requires that all ASME Code Class 1 components be subjected to augmented ISI.

For the 20-in. diameter RHR stainless valve welds, the valve bodies are SA-351 CFBM.

These are stainless steel castings and probably contain delta ferrite.

This would exclude them from augmented ISI if the delta ferrite content were above five percent.

Oelta ferrite readings have not been taken on these castings;

however, TV~ indicates that they will be taken and documented at the next refueling outage for each unit.

NUREG-0313, Rev.

1 indicates that if a cast stainless steel has a

delta ferrite of five percent or more, then that material is considered corrosion-resistant.

Also, TVA has classified the 28-in. diameter recirculation outlet nozzle safe end welds and 20-in. diameter RHR supply lines isolation valve welds as "nonservice sensitive".

These pipe

~

7 components are classified as "service sensitive" by NUREG-0313, Rev.

1 and should meet Part IV.B.2.b. of NUREG-0313, Rev.

1.

IV.B.l.b.(2)(a)

Augmented ISI for ASME Code Class 1 Pipe Welds at Terminal

'Ends of Pipe at Vessel Nozzles TVA does not plan to inspect the recirculation outlet nozzle pipe welds per tne 80-month schedule NUREG-0313, Rev.

1 because no IGSCC has been found in pipes with SRI < 1.2 and the SRI value for these welds is 1.11.

Therefore, TVA plans to inspect the welds per the 120-month ASME schedule 36

TVA has also classified these piping components as "nonservice sensitive".

They should be classified as "service sensitive" and meet Part IV.B.2.b. of iiUREG-0313, Rev. l.

IV.B.l.b.(2)(b)

Augmented

!SI for ASME Code Class 1 Pipe Welds Having a

Oesign Combined Primary Plus Secondary Stress Range of 2.4S or More m

Parts IY.B.l.b.(2)(b) and IY.B.l.b.(2)(c) require testing for those welds exceeding certain values of primary plus secondary stress range and cumulative fatigue usage factors.

These quantities do not exist for Browns Ferry 1, 2, and 3 because the Code to which they were built did not require calculation of these quantities.

Instead, TVA proposes to use the SRI to determine which pipe welds are most susceptible to IGSCC.

IV.B.l.b.(2)(c)

Augmented ISI fcr ASME Code Class 1 Pipe Welds Having a

Oesign Cumulative Fatigue Usage Factor of 0.4 or Mor e Parts IV.B.l.b.(2)(b) and IV.B.l.b.(2)(c) require testing for those welds exceeding certain values of primary plus secondary stress range and cumuIat.ve fatigue usage factors.

These quantities do not exisi. for Browns Ferry 1, 2, and 3 because the Code to which they were built did not require calculation of these quantities.

Instead, TVA proposes to use the SRI to determine which pipe welds are most susceptible to IGSCC.

IV.B.l.b.(2)(d)

Augmented ISI for ASME Code Class 1 Pipe Welds with High Potential for Cracking NUREG-0313, Rev.

1 requires that in addition to the welds in Parts IV.B.l.b.(2)(a), (b),

and (c) that "sufficient additional welds with high potential for cracking (be added) to make the total equal to 25K of the welds in each piping system."

37

TVA will use SRI to select the welds to be inspected and will not inspect the pipes at the 80-month interval required by Part IV.B.l.b. of NUREG-0313, Rev.

1.

Also, if the number of welds having SRI values 1.2 or greater exceeds 25K of the total welds, then only 25K of the total welds will be inspected.

Finally, NUREG-0313, Rev.

1 considers the 28-in. diameter recirculation piping and the 20-in. diameter recirculation piping manifold as "service sensitive" piping.

TYA has classified them as "nonservice sensitive" piping.

IV.B.l.b.(3}

Augmented ISI for ASME Code Class 2 Pipe Melds NUREG-0313, Rev.

1 requires that a certain proportion of ASNE Code Class 2 pipe welds be inspected.

TVA's position is that all of the ASNE Code Class 2 stainless steel piping systems are exempt from the inservice inspection requirements of the 1975 Section XI because the control of chemistry of the contained fluid which is intended to minimize corrosive effects, particularly stress corrosion, is verified by periodic sampling and test.

Therefore, they do not perform any augmented inservice inspections on Class 2 stainless piping.

IY.B.l.b.(4)

Augmented ISI for ASNE Code Class 2 Pipe Welds NUREG-0313, Rev.

1 requires that a certain proportion of ASNE Code Class 2 pipe welds be inspected.

TVA's position i" that all of the ASt<E Code Class 2 stainless steel piping systems are exempt from the inservice inspection of the 1975 Section XI because the control of chemistry of the contained fluid which is intended to minimize corrosive effects, 38

particularl>> stress corrosion, is verified by periodic sampling and test.

Therefore, they will not perform any augmented inservice inspections on ASME Code.

IY.B.2.b.(l)

Augmented ISI for Welds and Adjoining Areas of Bypass Piping of the Oischarge Valves in the Main Recirculation Loops and Reactor Core Spray Piping NUREG-0313, Rev.

1 requires that recirculation loop discharge valve bypass piping welds and adjoining areas and the reactor core spray bypass piping be subject to an augmented ISI program.

TVA has removed the 4-in. diameter recirculation bypass lines.

TVA feels that the remaining portions of the bypass lines will have low SRI values because the pipe reaction loads have been eliminated.

TVA plans to inspect the stubs at 60 + 12 month intervals.

IY.B.2.b.(2)

Augmented ISI for Oissimilar Metal fields and Adjoining Areas of Other ASME Code Class 1 "Service Sensitive" Piping NUREG-0313, Rev.

1 requires that the dissimilar metal welds at the 12-in. diameter recirculation inlet nozzle safe ends be suoject to an augmented ISI program.

TVA has had SRI values calculate-for the 12-in. diameter recirculation inlet nozzle safe ends.

'ince these SRI values are less than 1.2 and no IGSCC has been observed for welds with SR I values less than

1. 2, TYA does not plan to perform the augmented ISI on the abovementioned welds.

IV.B.2.b.(3)

Augmented ISI for Melds and Adjoining Areas of Other ASME Code Class 1 "Service Sensitive" Piping.

NUREG-0313, Rev.

1 has classified recirculation riser lines and and reactor water cleanup sweepolets as "service sensitive'SME Code Class 1 piping.

TVA has taken exception to this and has proposed that they be classified as "nonservice sensitive".

Tne proposed "nonservice sensitive" classification for the 12-in.

recirculation riser lines is based on recent augmented IS 39

I

examinations during which no indications of IGSCC were found.

The proposed "nonservice sensitive" classification for the 6-in.

reactor water cleanup sweepolets was based on the sweepolets being welded to the 20-in.

RHR supply line which is also classified by TVA as "nonservice sensitive".

NUREG-0313, Rev.

1 requires that "service sensitive" piping be subjected to an augmented ISI program.

TVA has proposed an alternative ISI program for the 6-in. diameter reactor water cleanup and the 6-in. diameter head spray lines.

The TVA ISI plan for the reactor water cleanup is ".

.each refueling cycle until it is replaced."

The TVA ISI plan for the head spray lines is 60 months.

IV.B.2.b.(4)

Augmented ISI for Internal Attachment Meld Crevices in Recirculation Inlet Lines at Safe Ends HUREG-0313, Rev.

1 requires that "service sensitive" piping be subjected to an augmented ISI program.

TVA has offered an alternative ISI plan.

Instead of inspecting all crevices, TVA will select a number "of crevices sufficient to represent 25K of the crevices and inspect these selected crevices at intervals of 60 + 12 months.

IV.8.2.b.(6)

Augmented ISI for ASME Code Class 2 Pipe Welds NUREG-0313, Rev.

1 requires that a certain proportion of ASME Code Class 2 pipe welds be inspected.

TVA's position is that all of the ASIDE Code Class 2 stainless steel piping systems are exempt from the inservice inspection of the 1975 Section XI because the control of chemistry of the contained fluid which is intended to minimize corrosive effects, particularly stress corrosion, is verified by periodic sampling and test.

Therefore, they do not perform any augmented inservice inspections on Class 2 stainless piping.

40

TABLE 4 AOOITIONAL OATA RE(VIREO OF LICENSEE I I.C Material Selection,

Testing, and Processing Guidelines for BWRs with an Operating License Identify all nonconforming "service sensitive" piping and the replacement plans pertaining to them.

IV.B.l.a.(1)

Leak Oetection Methods l.

Indicate whether provisions have been made in the Browns Ferry 1, 2, and 3 FSAR to monitor systems connected to the RCPB for signs of intersystem leakage (Subsection C.4 of Regulatory Guide 1.45).

2.

Indicate whether calibration of the indicators accounts for the needed independent variables (Subsection C.7 of Regulatory Guide 1.45).

3.

TVA should indicate whether the Browns Ferry 1, 2, and 3

leak detection system includes an airborne par ticulate radioactivity monitoring system and an airborne gaseous radioactivity monitoring system (Subsection C.3 of Regulatory Guide 1.45).

4.

Please indicate whether unidentified leakage to the primary reactor containment can be collected and the flow rate monitored with an accuracy of 1

gpm or better (Subsection C.2 of Regulatory Guide 1.45).

5.

Indicate whether the leakage detection systems are adequate to detect a leakage rate, or its equivalent, of 1

gpm in less than 1

h (Subsection C.S of Regulatory Guide 1.45).

IV.B.l.a. (2)

Shutdown for Leakage Indicate the monitoring interval of the sump level monitoring system.

IV.B.l.b.(1)

Augmented ISI for "Nonservice Sensitive" Piping The ferrite content of the 20-in.

RHR valve bodies must be documented.

IV.B.l.b.(2)(a)

Augmented ISI for ASME Code Class 1 Pipe Melds at Terminal Ends of Pipe at Vessel Nozzles Calculated SRI values can vary depending on wno made the calculations.

Indicate whether SRI values were calculated for the above pipes by any other consultant.

Identify the effect of low temperature sensitization on welds with SRI values close to 1.20 (e.g.,

1.11).

IV.B.I.b.(2)(b)

Augmented ISI for ASME Code Class 1 Pipe Welds Having a

Oesign Combined Primary Plus Secondary Stress Range of 2.4S or More Identify the SRI value below which no augmented ISI will be per formed.

IV.B.l.b.(2)(c)

Augmented ISI for ASME Code Class 1 Pipe Welds Having a

Oesign Cumulative Fatigue Usage Factor of 0.4 or More Identify the SRI value below which no augmented ISI will be performed.

IV.P.l.b.(2)(d)

Augmented ISI for ASME Code Class 1 Pipe Melds with High Potential for Cracking The additional data r equired include:

1.

Proportion of welds described by Parts IV.B.l.b.(2)(a)-(d) that have SRI values equal to or greater than 1.2.

2.

Whether the 28-in. diameter recirculation piping ard 20-in.

diameter recirculation piping manifold have been reclassified as "service sensitive" piping.

IV.B.l.b.(3)

Augmented ISI for ASME Code Class 2 Pipe Welds None.

IV.B.l.b.(4)

Augmented ISI for ASME Code Class 2 Pipe Welds None.

IV.8.2.b.(1)

Augmented ISI for Welds and Adjoining Areas of Bypass Piping of the Discharge Values in the Main Recirculat on Loops and Reactor Core Spray Piping Identify the SRI values for the 4-in. diameter recirculat'on bypass line s tubs.

IV..8.2.b.(2)

Augmented ISI for Dissimilar Metal Welds and Adjoining Areas of Other ASME Code Class 1 "Service Sensitive" Piping 1.

TVA's proposed ISI schedule for the 12-in. diameter recirculation inlet nozzle safe ends.

2.

Identify the individual SRI values for the safe end fields.

3.

Has a second calculation by another contractor of SRI for the abovementioned welds been made?

IV.B.2.b.(3)

Augmented ISI for Welds and Adjoining Areas of Other ASME Code Class 1 "Service Sensitive" Piping None.

IV.8.2.b.(4)

Augmented ISI for Internal Attachment Weld Crevices in Recirculation Inlet Lines at Safe Ends Identify the SRI values of the above crevices.

2.

When were the crevices last inspected7 3.

Please provide a copy of the inspection technique(s) specifications.

IV.B.2.b.(6)

Augmented ISI for ASME Code Class 2 Pipe Welds None.

2.

4.

REFERENCES E. 0.

Eason et al.,

The Cost Effectiveness of Countermeasures to Inter ranular Stress Corrosion Crackin in BNR Pipin EPRI NP-1703, e ruary, p.

U.S. Nuclear Regulatory Commission, Technical Re ort on Material Selection and Processin Guidelines for BWR oo ant ressure Boundary in,

i eponu n -

u y 3.

U.S. Nuclear Regulatory Commission, Technical Repor t, Investi ation and Evaluation of Crackin in Austenitic Stainless Steel Pioin of Bo> in Mater Reactor

ants, USNR Report NURc, -ib

, October 975.

4.

U.S. Nuclear Regulatory Commission, Investi ation and Evaluation of Stress-Corrosion Crackin in Pipin of Li ht Mater Reactor Plants, eport NU e ruary 5.

U.S. Nuclear Regulatory Commission, Technical Report on Material Selection and Processin Guidelines for BWR oo ant ressure oundary in, i

epone i -, ev.,

uu y 6.

0. G. E,isenhut letter to all BMR licensees (except Humboldt Bay and La Crosse),

"Implementation of NUREG-0313, Rev.

1, Technical Report on Material Selection and Processin Guidelines for BNR oo ant Pressure oun ar

~p>n t eneric ask enersc Letter ebruary 7.

L. M. Mills to H. R. Oenton letter, July 2, 1981 (NRC Accession No.:

8107130220).

8.

L. M. Hills to H. R. Oenton letter, December 26, 1982 (NRC Accession No.:

None given).

9.

Browns Ferry 1, 2, and 3 Final Safety Analysis Report, Section 4.10.

U.S. NUCLEAR REGULATORY COMMISSION B(BLIOGRAPHIC DATA SHEET 4 TITLE ANO SUBTITLE Technical Evaluation of Integrity of the BroII7ns Ferry 1, 2,

and 3 Reactor Coolant Boundary Piping System RFPORT NUMBER lAsstgnea oy DDCl EGG-Fil-6246

2. ILeeire olenkl

3. RECIPIENT'S ACCESSION NO.

7. AUTHOR(SI P.

K. Nagata

9. PERFORMING ORGANIZATIONNAME ANO MAILINGAOORESS fInclude Zlp Codel

5. GATE REPORT CCMPI.ETEO MONTH Au Us GATE REPORT ISSUEO 1083 EG8G Idaho, Inc.

Idaho Falls, IO 83415

12. SPONSORING ORGANIZATION NAME ANO MAILINGAOORESS llnclude Zlp Codel Oivision of Licensin Office of Nuc ear Reactor Re ulation U.S. Nuclear Regu atory Commission Washington, OC 20555 August lg83

6. ILeeire otenkl

8. ILeeee ota kl I'J. PROJECT/TASKIWQRK UNITNO.

'I I, FIN NO.

A6429

13. TYPc OF REPORT eERIoo cQYEREQ llnclusiee detesl

15. SUPPLEMENTARY NOTES 14, (Leere otenkl

16. ABSTRACT l200 words or tessl 17 KEY WORDS ANO OQCUMENT ANAI.YSIS 17a. OESCRIPTQRS

'I 7b. IOENTIFIERSI'OPEN ENOEO TERMS

18. AVAILABILITYSTATEMENT Unlimited N4C FORM 335 Sii est

19. SECURI TY CLA'SS /in I coortl Unclassified

20. SECURI TY CLASS t-in s oeFel

'nclas 'fi 21 NQ OF PAGcS 22 oRICE

e a

a, (~

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