ML18153A328

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Forwards RAI Re GL 97-01, Degradation of Crdb/Cedm Nozzle & Other Vessel Closure Head Penetrations. Response Requested within 90 Days of Submittal Date
ML18153A328
Person / Time
Site: Surry, North Anna  Dominion icon.png
Issue date: 09/16/1998
From: Edison G
NRC (Affiliation Not Assigned)
To: Ohanlon J
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
GL-97-01, GL-97-1, TAC-M98577, TAC-M98578, TAC-M98603, TAC-M98604, NUDOCS 9809220148
Download: ML18153A328 (8)


Text

e UNITED STATES e

NUCLEAR REGULATORY COMMISSION

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WASHINGTON, D.C. 20555--0001

} j? _, 2 i!r tCJ /..?-'Ol Mr. J. P. O'Hanlon Senior Vice President

. Virginia Electric and Power Company 5000 Dominion Boulevard Glen Allen, VA 23060 September 16, 1998

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SUBJECT:

GENERIC LETIER (GL) 97-01, "DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS," RESPONSES FOR

. SURRY POWER STATION, UNITS 1 AND 2 (SPS 1 AND 2) AND NORTH ANNA POWER STATION, UNITS 1 AND 2 (NAPS 1 AND 2); (TAC NOS.

M98603, M98604, M98577 AND M98578)

Dear Mr. J. O'Hanlon:

On April 1, 1997, the staff issued Generic Letter (GL) 97-01, "Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information requests. In the discussion section of the GL, the staff stated that "individual licensees may wish to determine their inspection activities based on an integrated industry inspection program...," and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspection program.

As a result, the Westinghouse Owners Group (WOG) determined that it was appropriate for its members to develop a cooperative integrated inspection program in response to GL 97-01.

The WOG program is documented in two Topical Reports issued by the Westinghouse Electric Corporation (WEC), WCAP-14901, Revision 0, "Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group," and WCAP-14902, Revision 0, "Background Material for Response to NRC Generic Letter 97-01:

Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group."

The WOG submitted the integrated programs described in WCAP-14901 and WCAP-14902 to the staff on July 25, 1997.

The staff has determined by letters dated April 28, 1997, and July 25, 1997, that you were a member of the WOG and a participant in the WOG integrated program that was developed to address the staffs requests in GL 97-01. In your letters of April 2_8, 1997, and July 25, 1997,.

you also indicated that the information in WEC Topical Report WCAP-14901 is applicable with respect to the assessment of VHP nozzles at SPS 1 and 2 and NAPS 1 and 2.

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The staff has reviewed your responses to GL 97-01, dated April 28, 1997, and July 25, 1997, and requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG member plants, and to the contents of Topical Report No. WCAP-14901. The enclosure to this letter forwards staffs inquiries in the form of a request for additional information (RAI}.

The staff requests a response to the RAI within 90 days of the submittal date. This submittal date was discussed with Mr. Tom Shaub of your staff on August 26, 1998. Mr. Shaub later indicated that VEPCO will be able to meet this date. It should be noted that similar staff requests have been issued to other WOG member utilities. As was the staffs position before, the staff encourages you to address these inquiries in integrated fashion with the WOG and the Nuclear Energy Institute (NEI}; however, the staff also requests that you identify any deviations from the WOG's integrated program that may be specific to your facilities. The staff appreciates the efforts expended with respect to this matter.

Sincerely, Original Signed by:

N. Kalyanam, Project Manager Project Directorate 11-1 Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION:

a@o_e~e~Fr11~

OGC Public J. Harold ACRS EMCB DOCUMENT NAME: g:\\noanna\\m98577-8.rai NAME NKalyanam DATE 111,;-'198 COPY Sincerely, Original Signed by:

Gordon E. Edison, Senior Project Manager Project Directorate 11-1 Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation L. Plisco, R II J. Zwolinski D:PD 11-1

/98 YES/NO

2 The staff has reviewed your responses to GL 97-01, dated April 28, 1997, and July 25, 1997, and requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG member plants, and to the contents of Topical Report No. WCAP-14901. The enclosure to this letter forwards staffs inquiries in the form of a request for additional information (RAI).

The staff requests a response to the RAI within 90 days of the submittal date. This submittal date was discussed with Mr. Tom Shaub of your staff on August 26, 1998. Mr. Shaub later indicated that VEPCO will be able to meet this date. It should be noted that similar staff requests have been issued to other WOG member utilities. As was the staffs position before, the staff. encourages you to address these inquiries in integrated fashion with the WOG and the Nuclear Energy Institute (NEI); however, the staff also requests that you identify any deviations from the WOG's integrated program that may be specific to your facilities. The staff appreciates the efforts expended with respect to this matter.

Sincerely, L

p N. Kalyanam, Project Manager Project Directorate II-:-1 Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/encl: See next page Sincerely, LGordon E. Edison, Senior P;~~ct Manager V

  • Project Directorate 11-1 Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation

e Virginia Electric & Power Company Mr. J. Jeffrey Lunsford County Administrator, Louisa County P.O. Box 160 Louisa, Virginia 23093 Michael W. Maupin, Esq.

Hunton and Williams Riverfront Plaza, East Tower 951 E. Byrd Street Richmond, Virginia 23219 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation P.O. Box 1197 Richmond, Virginia 23209 Old Dominion Electric Cooperative 4201 Dominion Boulevard Glen Allen, Virginia 23060 J. H. McCarthy, Manager Nuclear Licensing and Operations Support Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, Virginia 23060 Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Senior Resident Inspector North Anna Power Station U.S. Nuclear Regulatory Commission 1024 Haley Drive Mineral, Virginia 23117 Senior Resident Inspector Surry Power Station, US Nuclear Regulatory Commission 5850 Hog Island Road Surry, Virginia 23883 Robert B. Strobe, M.D., M.P.H.

State Health Commissioner Office of the Commissioner Virginia Department of Health P.O. Box 2448 Richmond, Virginia 23218 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 W. R. Matthews Site Vice President North Anna Power Station Virginia Electric and Power Company P.O. Box 402 Mineral, Virginia 23117 J.P. O'Hanlon Senior Vice President - Nuclear Virginia Electric and Power Co.

Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, Virginia 23060 Mr. Eugene S. Grecheck Site Vice President Surry Power Station Virginia Electric and Power Company 5570 Hog Island Road Surry, Virginia 23883 Chairman Board of Supervisors of Surry County Surry County Courthouse Surry; Virginia 23683 Mr. R. C. Haag U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303

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  • 2 The staff has reviewed your responses to GL 97-01, dated April 28, 1997, and July 25, 1997, and requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG member plants, and to the contents of Topical Report No. WCAP-14901. The enclosure to this letter forwards staff's inquiries in the form of a request for additional information (RAI).

The staff requests a response to the RAI within 90 days of the submittal date. This submittal date was discussed with Mr. Tom Shaub of you*r staff on August 26, 1998. Mr. Shaub later indicated that VEPCO will be able to meet this date. It should be noted that similar staff requests have been issued to other WOG member utilities: As was the staffs position before, the staff encourages you to address these inquiries in integrated fashion with the WOG and the Nuclear Energy Institute (NEI); however, the staff also requests that you identify any deviations from the WOG's integrated program that may be specific to your facilities. The staff appreciates the efforts expended with respect to this matter.

Sincerely, Original Signed by:

N. Kalyanam, Project Manager

. Project Directorate 11-1 Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION:

Docket File OGC Public J. Harold ACRS EMCB DOCUMENT NAME: g:\\noanna\\m98577-8.rai NAME NKalyanam DATE 1 tt':)198 COPY Sincerely, Original Signed by:

Gordon E. Edison, Senior Project Manager Project Directorate 11-1 Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation L. Plisco, R II J. Zwolinski.

D:PD 11-1

/98 YES/NO

e Reguest for Additional Information Regarding Utilities Participating in the Westinghouse Owners Gro~p (WOG)

Response to Generic Letter (GL) 97-01 I

"Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration Integrity for the Westinghous~ Owners Group" Topical Report No. WCAP-14901, Revision O Applicability of Topical Report No. WCAP-14901, Revision 0, to the Plant-specific Responses to GL 97-01 for Participating Member Utilities and Plants in the WOG I.

Relationship and Applicability of WCAP-14901, Revision 0, to GL 97-01 and the WOG I

On April 1, 1997, the staff issued Generic Letter (GL) 97-01, "Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an in'itial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information requests. In the discussion section of the GL, the staff stated that "individual licensees may wish to determine their inspection activities based on an integrated industry inspection program...," and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspection program.

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As a result, the WOG determined that it was appropriate for its members to ~evelop a cooperative integrated inspection program in response to GL 97-01. The WOG program is documented in two Topical Reports issued by the Westinghouse Electric Corpbration (WEC),

WCAP-14901, Revision 0, "Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group,",and WCAP-14902, Revision 0, "Background Material for Response to NRC Generic Letter 97-b1: Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group." \\

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The technical content provided in WCAP-14901, Revision 0, is basically the s1ame as that provided in WCAP-14902. The difference with regard to the reports is that W0G member plants subscribing to the content of WCAP-14901 have opted to rank the suscJ,ptibility of their I

vessel head penetrations according to a probabilistic Weibull analysis method tl~at was developed by WEC. In contrast, the WOG member plants subscribing to the content of WCAP-14902, Revision 0, have opted to rank the vessel head penetrations for their fadlities according to a probabilistic methodology that was developed by another vendor of choice. \\The s~aff has*

determined by letters dated April 28, 1997, and July 25, 1997, that you were a member of the WOG and a participant in the WOG integrated program that was developed to ad~ress the I

staff's requests in GL 97-01. In your letters dated April 28, 1997, and July 25, 199*~. you also indicated that the information in WEC Topical Report WCAP-14901 is applicable with respect to the assessment of VHP nozzles at Surry Power Station, Units 1 and 2, and North Ari,:,a Power Station, Units 1 and 2.

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Enclosure

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2 The staff has reviewed your responses to GL 97-01, dated April 28, 1997, and July 25, 1997, and requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG member plants, and to the contents of Topical Report No. WCAP-14901. The staff requests the following information with respect to the content of your responses to.GL 97-01, dated April 28, 1997, and July 25, 1997, and to the content of WCAP-14901 as it relates to these responses:

1.

In WCAP-14901 WEC did not provide any conclusions as to what the probabilistic failure model would lead the WOG to conclude with respect to the assessment of primary water stress corrosion cracks (PWSCC) in WEC-designed vessel head penetrations. With respect to the probabilistic susceptibility model (e.g., probabilistic failure model) provide9 in WCAP-14901:

2.
3.
a.

Provide the susceptibility rankings compiled for the WOG member plants for which WCAP-14901 is applicable. In regard to other WOG member plants to which WCAP-14901 is applicable, include the basis for establishing t~e ranking of your plants relative to the others.

b.

Describe how the probabilistic failure model in WCAP-14901 for assessing postulated flaws in vessel head penetration nozzles was bench-marked, and provided a list and discussion of the standards the model was bench-marked against.

c.

Provide additional information regarding how the probabilistic failure models in WCAP-14901 will be refined to allow the input of plant-specific inspection data into the model's analysis methodology.

d.

Describe how the variability in product forms, material specifications, and heat treatments used to fabricate each CROM penetration nozzle at the WOG member utilities are addressed in the probabilistic crack initiation and growth models described or referenced in Topical Report No. WCAP-14901.

Table 1-2 in WCAP-14901 provides a summary of the key tasks in WEC's vessel head penetration nozzle assessment program. The table indicates that the Tasks for (1) Evaluation of PWSCC Mitigation Methods, (2) Crack Growth Data and Testing, and (3) Crack Initiation Characterization Studies have not been completed and are still in progress. In light of the fact that the probabilistic susceptibility models appear to be dependent in part on PWSCC crack initiation and growth estimates, provide your best estimate when these tasks will be completed by WEC, and describe how these activities relate to and will be used to update the probabilistic susceptibility assessment of VHP nozzles at your plants.

In the NEI letters of January 29, 1998 (Ref. 1 ), and April 1, 1998 (Ref. 2), NEI indicated that inspection plans have been developed for the VHP nozzles at the Farley Unit 2 plant in the year 2002, and the Diablo Canyon Unit 2 plant in the

3 year 2001, respectively. The staff has noted that although you have endorsed the probabilistic susceptibility model described in WCAP-14901, Revision 0, other WOG member licensees have endorsed a probabilistic susceptibility model developed by an alternate vendor of choice. The WOG's proposal to inspect the VHP nozzles at the Farley Unit 2 and Diablo Canyon Unit 2 plants appears to be based on a composite assessment of the VHP nozzles at all WOG member plants. Verify that such a composite ranking assessment has been applied to the evaluation of VHP nozzles at your plants. If composite rankings of the VHP nozzles at WOG member plants have been obtained from the composite results of the two models, justify why application of the probabilistic susceptibility model described in WCAP-14901, Revision 0, would yield the same comparable relative rankings of the VHP nozzles for your plants as would application of the alternate probabilistic susceptibility model used by the WOG member plants not subscribing to WCAP-14901, Revision 0. Comment on the susceptibility rankings of the VHP nozzles at your plants relative to the susceptibility rankings of the VHP nozzles at the Farley Unit 2 and Diablo Canyon Unit 2 plants.

REFERENCES

1.

January 19, 1998 - Letter from David J. Modeen, Director of Engineering, Nuclear Generation Division, Nuclear Energy Institute, to Mr. G.C. Lainas, Acting Director, Di~ision of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (Untitled).

2.

April 1, 1995 - Letter from David J. Modeen, Director of Engineering, Nuclear Generation Division, Nuclear Energy Institute, to Mr. G.C. Lainas, Acting Director, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, "

SUBJECT:

Generic Letter 97-01, 'Degradation of Control Rod Drive Mechanism Nozzle and Other Vessel Head Penetrations.' "