ML19256F424

Forwards 30-day Response to IE Bulletin 79-17,Revision 1, Pipe Cracks in Stagnated Borated Water Sys at PWR Plants. Describes Welds to Be Examined & Welds Selected for Ultrasonic Testing

ML19256F424
Person / Time
Site:	Davis Besse
Issue date:	11/28/1979
From:	Crouse R TOLEDO EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1-106, NUDOCS 7912190127
Download: ML19256F424 (26)

Text

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TOLEDO EDISDN November 28, 1979 Pcm Docket No. 50-346 NE p19) 259 5221 License No. NPF-3 Serial No. 1-106 Mr. James G. Keppler Regional Director, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

This letter is in response to IE Bulletin 79-17, Revision 1, dated October 30, 1979 (Log No. 1-262), as applicable to Davis-Besse Nuclear Power Station Unit No. 1. Attached is Toledo Edison's required 30 day response to Item No. 2(b). Please note that Toledo Edison's response to Item No. I was submitted to you on August 24, 1979 (Serial No. 1-84).

Yours very truly, ff - := -

RPC:1WH Attachment db d/3 162b bo3 DEC 3 197g THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652

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Docket No.: 50-346 License No.: NPF-3 Serial No.: 1-106 November 28, 1979 IMPLEMENTATION OF IE BULLETIN 79-17 WELD INSPECTION FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 PREPARED BY THE TOLEDO EDISON COMPANY 1620 004

TABLE OF CONTENTS Page Number

SUMMARY

. . . . . . . . . . . . . . . . . . . . . . 1 PROGRAM IMPLEMENTATIGN . . . . . . . . . . . . . . 2 PROGRAM GUIDANCE . . . . . . . . . . . . . . . . 3 APPENDIX A - LINE DESCRIPTIONS APPENDIX B - LINE DATA SHEETS WITH WELD SELECTIONS FOR UT EXAMINATION ATTACHMENT 1 - MEETING MINUTES, TEC0/NRC MEETING, SEPTDBER 20, 1979 16 0'0'05

Docket No.: 50-346 License No.: NPF-3 Serial No.: 1-106 November 28, 1979 SUM >iARY This report identifies welds to be examined in compliance with the intent of IE Bulletin 79-17, Revision 1, dated October 30, 1979, at the Davis-Besse Nuclear Power Station Unit 1. A meeting was held with the NRC on September 20, 1979 (see Attachment 1) to develop guidance for implementation of IE Bulletin 79-17. The guidance developed was used to identify the NDE requirements on portions of safety related stainless steel piping systems which contain stagnant oxygenated borated water.

1 1620 606

Docket No.: 50-346 License No.: NPF-3 Serial No.: 1-106 November 28, 1979 PROGRAM IMPLEMENTATION The following systems were determined to be wi;hin the scope of IE Bulletin 79-17:

1. Reactor Coolant

2. Makeup and Purification

3. Emergency Core Cooling

4. Decay Heat Removal

5. Containment Spray

6. Core Flood

7. Spent Fuel Pool Cooling In compliance with the requirements of Paragraph 1 of IE Bulletin 79-17, line descriptions have been written for the portions of safety related stainless steel systems which contain stagnant oxygenated borated water.

The line descriptions are listed in Appendix A - Line Descriptions. In compliance with the intent of Paragraph 2(a), visual examinations will be performed on those welds normally accessible on a monthly basis and the inaccessible ones at each cold shutdown which contain stagnant oxygenated borated water. UT examinations will be performed on twenty welds in thick wall piping which is part of normally accessible portions of systems that contain stagnant oxygenated borated water. This represents a twenty-four percent sample and exceeds the requirement of Paragraph 2(b). The weld selections for UT examination are listed in Appendix B -

Line Data Sheets with Weld Selections for UT examination. Line descrip-tions are listed in Appendix A to identify the inspectable portions of systems in not normally accessible areas of the plant. This list of line descriptions complies with the intent of Paragraph 2(c).

1620 007 2

Docket No.: 50-346 License No.: NFF-3 Serial No.: 1-106 November 28, 1979 PROGRAM GUIDANCE IE Bulletin 79-17 lacked sufficient detail to develop acceptable guidance for the implementation of Paragraphs 1 and 2. A meeting was held with the NRC (see Attachment 1 - Meeting Minutes) to develop acceptable guidelines for identification and examination of safety related stainless steel piping systems which contain stagnant oxygenated borated water.

The guidance is presented and discussed below:

1. Safety related piping systems made of Type 304 and 316 austenitic stainless steel were reviewed to identify stagnant portions of lines. Non-safety related systems or porticas of systems were exempted from examination requirements.

2. A system or a portion of a system that is nornally operating was exempted from examination requirements.

3. A system or a portion of a system that is full flow tested was exempted from UT examination requirements. Based upon TECo's full flow testing schedule and calculations of flow rates through the affected systems, it was concluded that the full flow tested lines do not contain stagnant oxygenated borated water.

4. Non-water containing lines and lines which contain fluids and/or gases other than oxygenated borated water are not within the scope of IE Bulletin 79-17.

5. UT examination will not be performed on thin wall piping (0.250" or less wall thickness) since UT has not been demon-strated to be repeatable, or even able to confirm an indication in thin wall piping. A statistical UT examination will be performed in accessible portions of systems which contain stagnant oxygenated borated water if the wall thickness is greater than 0.250".

6. Visual examinations will be performed on welds in thin wall riping which contain stagnant oxygenated borated water.

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Docket No.: 50-346 License No.: NPF-3 Serial No.: 1-106 November 28, 1979

7. Welds selections for UT examination were made according to the following guidelines:

. Carbon content greater than 0.05 percent.

. Distribution among line sizes.

. Distribution between horizontal and vertical runs.

The guidance discussed above is considered to meet the intent of compliance with IE Bulletin 79-17, Revision 1, dated October 30, 1979.

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Docket No.: 50-346 License No.: NPF-3 Serial No.: 1-106 November 28, 1979 Appendix A LINE DESCRIPTIONS

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LINE DESCRIPTIONS ACCESSIBLE PORTIONS _OF SYSTEMS WHICH WOULD BE ULTRASONIC TESTED (wall thickness greater than 0.250")

The welds in the lines of the following systems should be ultrasonic tested:

. The welds in the lines of the High Pressure Injection System including the discharge lines from the high pressure injection pumps to the discharge line outermost containment valves, not including the full flow test portion of these lines. There are 92 welds in this portion of the system.

NON-ACCESSIBLE PORTIONS OF SYSTEMS WHICH WOULD BE ULTRASONIC TESTED (wnll thickness greater than 0.250")

The welds in the lines of the following systems should be ultrasonic tested but are inaccessible: ,

. The welds in one train of the High Pressure Injection System including the discharge lines from the discharge line outermost containment valves to the discharge line innermost containment valves. There are 114 welds in this portion of the system.

. The welds in the lines of the Decay Heat Removal System including the discharge lines from the discharge line outermost containment valves to the Core Flood System discharge lines. There are 46 welds in this portion of the system.

. The welds in the lines of the Core Flooding System which include the core flooding tank discharge line from the core flooding tanks to the reactor vessel. There are 50 welds in this portion of the system.

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ACCESSIBLE PORTIONS OF SYSTEMS THAT WILL BE INSPECTED PER ITEM 2(a), UNTIL ITEM 2(b) IS COMPLETE (wall thicknesses of 0.250" or less)

The welds in the lines o! the following systems will be visual and liquid penetrant examined:

. The welds in the Spent Fuel Pool Cooling System discharge line to the spent fuel pool through the Decay Heat Removal System crosstie and including the return line to the spent fuel pool through the " ay Heat Removal System crosstie.

. The welds in the safety related lines of the Spent Fuel Pool Cooling System that include the crosstie between the borated water storage tank svetion line and the spent fuel pool pump suction lines (spent fuel pool makeup line) up to the first isolation valve.

. The welds in the lines of the Decay Heat Removal System which include the reactor coolant normal cooldown lines from the outermost contain6ent valve to the decay heat pump suction lines.

. The welds in the lines of the Decay Heat Removal System which include the decay heat cooler bypass lines.

. The welds in the lines of the crosstie between the Decay Heat Removal System discharge lines.

. The welds in the lines of the crosstie between the Decay Heat Removal System suction line and the Makeup and Purification System suction line.

. The welds in the safety related lines of the refueling canal drain lines which do not penetrate containment.

. The welds in the safety related lines of the crosstie between the Decay Heat Removal System discharge line and the Makeup and Purification System and the Spent Fuel Pool Purification System.

. The welds in the lines of the Decay Heat Removal System from the decay heat removal pumps to the discharge line outermost containment valves, not including the full flow test portions of these lines.

. The welds in the bypass line from the Decay Heat Removal System full flow test return lines.

. The welds in the lines of the Decay Heat Removal System including the suction lines from the containment emergency sump outermost containment valves to the Decay Heat Removal pumps, not including the full flow test portion of these lines.

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NON-ACCESSIBLE PORTIONS OF SYSTEMS THAT WILL BE INSPECTED PER ITEM 2(a), UNTIL ITEM 2(b) IS COMPLETE (wall thicknesses of 0.250" or less)

The welds in the lines of the following systems will be visual and liquid penetrant examined but are inaccessible:

. The welds in the safety related portion of the refueling canal drain line which penetrates containment.

. The welds in the lines of the Reactor Coolant System which include the safety related lines of the pressurizer quench tank discharge. ,

. The welds in the lines of the Decay Heat Removal System which include the normal cooldown from the innermost containment valves to the outermost containment valves.

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FULL FLOW TESTED LINES The welds in the lines of the following systems will be exempted from examination because these lines are subject to full flow testing:

. The welds in the lines of the Containment Spray System which include the suction lines from the Decay Heat Removal System suction lines to the containment spray pumps, and the discharge lines from the containment spray pumps to the full flow test return lines.

. The welds in the lines of the Decay Heat Removal System which include the suction lines from the borated water storage tank to the decay heat pumps, and the discharge lines from the decay heat pumps up to and including the safety related portion of the full flow test return lines.

. The welds in the lines of the High Pressure Injection System which include the suction lines from the Decay Heat Removal System suction lines to the high pressure injection pumps, and the discharge lines from the high pressure injection pumps to the full flow test return lines.

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PORTIONS OF SYSTEMS WHICH ARE NORMALLY OPERATING The welds in the lines of the following systems will be exempted from examination because these lines are in portions of systems which are normally operating:

. The welds in the safety related lines of the Makeup and Purifi-cation System which include the reactor coolant letdown from the reactor coolant pump suction to the letdown coolers.

. The welds in the safety re?ated lines of the Makeup and Purifi-cation System which include the reactor coolant letdown lines that penetrate containment.

. The welds in the safety related lines of the Makeup and Purifi-cation System which include the reactor coolant makeup lines that penetrate containment.

. The welds in the lines of the Reactor Coolant System from the reactor vessel to the steam generators.

. The welds in the Lines of the Reactor Coolant System from the steam generators to the reactor coolant pumps.

. The welds in the lines of the Reactor Coolant System from the reactor coolant pumps to the reactor vessel.

. The welds in the lines of the Reactor Coolant System which include the pressurizer surge line.

. .The welds in the lines of the Reactor Coolant System from the pressurizer to the pressurizer relief valves. NOTE: These lines do not operate in the true sense. However, they are in

. a system which is oxygen seas .ged.

. The welds in the lines of the Reactor Coolant System which include the pressurizer spray lines.

. The welds in the lines of the Reactor Coolant System which include the pressurizer control lines from the pressurizer to the first isolation valve.

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Docket No.: 50-346 License No.: NPF-3 Serial No.: 1-106 November 28, 1979 APPENDIX B LINE DATA SHEETS WITH WELD SELECTIONS FOR UT EXAMINATIONS ACCESSIBLE PIPING WELDS FOR IE BULLETIN 79-17 NONDESTRUCTIVE EXAMINATION DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 162Cr016

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Docket No.: 50-346 License No.: NPF-3 Serial No.: 1-106 November 28, 1979 ATTAC.IMENT 1 MEETING MINTES, TECo/NRC MEETING SEPTEMBER 20, 1979 3 pages 1620 025

. TECo -- Telecopy to Garner, NRC, October 17, 1979 Date: September 20, 1979 Location: ,

NRC (Bethesda, Maryland)

Attendance: TECo HAFA B&W NRC T. Hart H. H. Askvith J. Uhl E. Brown C. Daft L. Sage W. Collins R. Herman A. Toboda

Purpose:

To discuss and Clarify TECo's Philosophy of Testing Under Inspection and Enforcement Bulletin 79-17 Minutes:

f Mr. Collins of the NRC opened the meeting by introducing all the partici-pants. TECo's consultant then asked the NRC participants the following information questions:

a. How many UT defects were found on TMI-1 and confirmed by other NDE methods?

NRC Answer: There have been 38 indications found by UT examina-tions plus 8 leaking welds at TMI-1. Of the 38 indications, none have yet been confirmed by other NDE methods.

b. Have the 38 welds in question been mapped out in regard to their location in the piping systems?

NRC Answer: This has not been done at the current time.

c. Of the 38 indications, have any been found in 316 S.S. material?

NRC Answer: To the best of their knowledge, none have been found

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in 316 S.S. material.

After the above discussion, TECo/ Consultant personnel at the meeting, presented the NRC with a plan, including color coded P&ID's showing which lines should be tested and by what NDE method. The following

~

is a recap df what was presented to the NRC:

a. UT examination should not be performed on thin wall piping,

.250 inch or less, since UT has not yet been demonstrated to be repeatable, or even able to confirm an indication of thin wall piping. The NRC agreed with the above statement and stated that : : ecting is being scheduled with Electric Power Research Institute (EPRI) in late October, 1979, .o develop a procedure for UT examination'of thin wall piping.

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b. Lines which receive full flow testing are not considered stagnant lines, and should be exempted from the requirement of 79-17. The NRC agreed, based upon TECo's full flow testing modes, that those lines should be exempted at the present time.

c. TECo and the consultant presented arguments to the NRC stating why welds in 316 S.S. material should be exempted frem examina-tion under 79-17. It was brought out in the meeting that, although 304 S.S. and 316 S.S. materials have the same carbon content of 0.08 percent maximum, it has not yet been proven that 316 S.S. material is as susceptible to stress corrosion cracking as 304 S.S. material. It was generally agreed by all parties, that examinations should be concentrated on the welds in 304 S.S. material, but that TECo should do some sampling of

.- 316 S.S. material.

Mr. Collins of the NRC stated that he intends to amend 79-17 in the following. areas (after clearance through his management):

a. Grant relief to the utilities from the 90-day response require-ment as stated in 79-17. At this point, TECo asked, "Why can't the inspections under 79-17 coincide with the March refueling outage planned by TECo. This would mean that credit could be taken, by TECo, for the inspections that will be performed per 79-17 as part of the weld inspection ISI program.

By following this approach, TECo would not have to perform duplicate weld inspections. Mr. Collins stated that he sees no problem with this approach, but, until his management approves the changes to 79-17, he cannot give TECo a blanket approval.

b. Mr. Collins also vtated that the guidelines for selecting welds to be inspected per 79-17 should be based upon the following:

. carbon content greater than 0.05 percent

. distribution among line sizes s -

. the systems importance to safety

. distribute the sampling between vertical and horizontal runs The question then was asked of the NRC, "Have you looked at other parameters such as stress levels, vibration, operating modes, etc.?" Another question asked of the NRC, "If stress corrosion cracking is the problem, then why were no indica-tions found on the core flood lines which are stagnant?" This was left as an open item.

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..' '. ' 3 Mr. Taboda was asked, "When is .he change to 10 CFR 50.55a, adopting the Summer 1978 Addenda to ASME Section XI, coming out?" Mr. Toboda answered that the change is in printing at the current time, and be expects the change to be published in the Federal Register in about two weeks.

Mr. Toboda stated that TECo can use their current ISI program for the upcoming outage.

The follcwing are the action items that were agreed upon during the meeting by NRC/TECo/HAFA:

. TECo is to look at the chemical additions to their systems (HaOH).

. HAFA will call Burns & Roe and find out which lines in TMI-I are 316 S.S. material.

. Supply the NRC the weld count on exempted systems, full flow test systems, 316 S.S. material systems, systems that are designated as stagnant, and should be inspected per 79-17.

Minutes Taken By Thomas W. Hart

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