ML19324A910

Revised Final Technical Evaluation Rept on Response from Pse&G to Generic Ltr 88-01 Pertaining to Hope Creek Generating Station

ML19324A910
Person / Time
Site:	Hope Creek
Issue date:	10/31/1989
From:	Bates R VIKING SYSTEMS INTERNATIONAL
To:	NRC
Shared Package
ML19324A911	List: ML19324A910 ML19324C313 ML19324C314
References
CON-NRC-03-87-028, CON-NRC-3-87-28 GL-88-01, GL-88-1, NUDOCS 8910200135
Download: ML19324A910 (40)

Text

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l*s ie REVISED J

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TECHNICAL EVALUATION REPORT ON f

RESPONSE FRON PUBLIC SERVICE ELECTRIC AND GAS COMPANY M GENERIC LETTER 88-41

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PERTAINING M THE HOPE CREEK GENERATING STATION' t

J Published October, 1989 prepared by Robert C. Bates 1

Armand Lakner Viking Systems International 2070 Wm. Pitt Way Pittsburgh, PA FINAL Prepared'for:

U.S. Nuclear Regulatory Consission Washington, D. C. 205.45 under Contract No. NRC-03-87-028 Task Order 005 a

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ABSTRACT This report contains an evaluation of the licensee (Public Service Electric and Gas Company) subsittal for Hope Creek Generating Station which was submitted in response to the NRC Generic latter 88-01 in which Public Service was requested tos (1) Furnish their current plans relating to piping repiscenent and other measures to mitigate IGSCC, inspection, repair, and leakage detection. (2) Indicats whether they plan to follow the NRC Staff positions, or propose alternative measures.'

Public Service's plans are evaluated in Section 2 of this report in terse of compliance to NRC Staff positions. Public Service submitted alternative positions to thoes of the NRC Staff concerning a change e

to the Technical Specification on ISI and concerning leakage L

requirements. These positions are evaluated in Section 3 of this report.

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c SISMARY ne Licensee, Public Service Electric and Gas Company, sehmitted a response to the NEC Generic Letter 88 41. Public Service's respease pertaining to the austenitic stainless steel piping in the Eope Creek Generating Station (a BWR' nuclear power plant) was evaluated in terms (1) Their previous and planned actions to mitigate IGSCC to provide of:

assurance of continued long-term service. (2) Deir Inservice Inspection (3) heir Technical Specifications pertaining to ISI (ISI) Program.

and their plans to ensure that leakage detection will be is conformance with the NRC Staff position. (4) Their plans to motify the NRC of significant flaws identified (or changes in the condition of the welds previously known to be cracked) during inspection.

Public Service endorses twelve of the 13 NRC Staff positions which are outlined in Generic Letter 88-01, but they proposed alternatives to portions of the NRC Staff position on leakage detection.

Hope Creek was designed, fabricated, and constructed per guidance provided in NUREG 0313, Revision 1 so most welds are ICSCC Category Exceptions are in 20 nozzle areas which contain Inconel alloys A welds.

which were described as resistant asterials in NUREG 0313, Revision

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1 but are described as not-resistant materials in NUREG 0313. Revision l

Future plans include implementation of HWC, repair / replacement 2.

as needed, and an ISI program which follows NRC Staff pe itions, on.

schedule, methods and personnel, and sample espansion.

Public Service proposed an alternative to the NEC Staff position concerning a change to the TS on ISI which is evaluated in Section 3 of this report. heir proposal for alternative positions on portions of the requirements for leakage detection are also evaluated in Section 3 of this report.

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ABSTRACT e

11 SthatART 1

1. INTRODUCTION 2

2. EVALUATION OF RESPONSE 'IV GENERIC LETTER 88-01 2

2.1 Document Evaluated 2.2 Review of Public Service's Responses to Staff Positions 3

and Implementation of Those Positions 2.3 Review of Classification of Welds, Previous 5

Mitigating Actions, and Previous Inspections i

l 2.3.1 Summary of IGSCC Classifications and Justification for Classifications 5

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2.3.2 Examples of Materials and Processes 6

i Used for IGSOC Category A Welds 2.3.3 Esamples of Fabrication and Construction Procedures..

7 2.3.4 Supplemental Information on Category G Welds 8

2.3.5 Materials Used in IGSOC Category D and G Welds 10 10 2.3.6 Hydrogen Water Chemistry Tests 10 2.3.7 Previous Inspection Program 2.3.8 Evaluation and Recommendation 12 13 2.4 Current Plans for Mitigating Actions 10 2.4.1 Summary of Plans 2.4.2 Repairs / Replacement.................. 13 l

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13 2.4.3 5ydrogen Water Chemistry...............

2,4.4 Eviniustioc of Conformance to Staff 14 Positt as and Recommendation 14 2.5 Inservice Inspectica Program 14 2.5.1 Summary of Inspection Schedule 17 2.5.2 Inaccessible Welds 17 2.5.3 Methods and Personnel 17 2.5.4 Sample Espansion 18 2.5.5 Evaluation and Recommendations 4

2.6 Chenses in the Technical Specification 18 Concerning ISI i

2.7 Confirmation of Leak Detection 18.

in the Technical Specification 19 2.8 Plans for Notification of the NRC of Flavs 19 2.8.1 Public Service's Position 19 2.8.2 Ersluation and Recommendation 19

3. ALTERNATIVE POSITIONS 3.1 Alternate Position on ISI in the Technical Specification 19 l

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19 3.1.1 Public Service's Position l

20 3.1.2 Evaluation and Recommendation 3.2 Confirmation of Imak Detection 21 in the Technical Specification 3.2.1 Adherence to Regulatory Guide 1.45 21

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21 3.2.2 Imakage Limita l

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3.2.3 Frequency of Leakage Measurements 24 3.2.4 Description of Unidentified Leskage.

25 3.2.5 Operability of Measurement Instruments 26 3.2.6 Evaluation and Recommendations 28 4.. CONCLUSIONS AND RECOPtENDATIONS 30 33

5. REFERENCES l

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1. INTRODUCTION Intergranular stress corrosion cracking (IGSCC) near weldesats in Boiling Water Reactor (BWR) piping has been occurring for almost 20 Substantial efforts in research and developeont have been years.

sponsored by the BWR Owners Group for IGSCC Research, and the results of this program, along with other related work by vendors, consulting firms and confirmatory research sponsored by the NRC, have permitted the developasnt of NRC Staff positions regarding the 10$00 problems.

The technical basis for NRC Staff positions is detailed in Reference 1

1, and further background is provided in Reference 2.

The resul'te of these research and d.evelopment programs prompted the NRC to issue Generic Im*;ter 88-01 (see Reference 3) requesting all licensees of BWR's and holdecs of. construction permits tot p

(1) Purnish their current plans relating to piping repisc went, inspection, repair, and leakage detection.

(2) Indicate whether they:

(a) Plan to follow the staff positions, or (b) Propose alternative measures.

Specifically, Generic Letter 88-01 stated that an acceptable licensee response would include the following itses I

(1) Current plans regarding pipe repiecoment and/or other nessures taken or to be taken to mitigate IGSCC and provide assurance of continued long-term piping integrity and reliability.

(2) An inservice inspection (ISI) program to be implemented at 1

l the next refueling outage for austenitic stainless steel piping.

(3) A change to the Technical Specifications to include a statement l

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n in the section on ISI that the inservice laspectica program t'

for p'iping vill be 'in confomance with the staff positions i

j on schedule, methods and personnel, j

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(4) Confiraation of plans to ensure that the Technical Specification related to leakage detection will be in conformance with the

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Staff position en leak detection.

(5) Plans to notify the NRC, in accordance with 10CFR50.55e(o),

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of any flaws identified that do not meet IVB-3500 criteria of Section II of the ASME Code for continued operation without l:

evaluation, or a change found in the condition of the welds L

pheviouslyknowntobecracked,andanevaluationoftheflaws I

for continued used operation and/or repair plans.

This report contains a technical evaluation of the response which Public Service Electric and Gas Company (called either Public Service or PSEG in this report) submitted in response to the NRC Generic h tter 88-01 pertaining to the Hope Creek Generet'.ng Station (hereafter called Hope Creek).

2. EVALUATIO" 0F RESPONSE 10 GENERIC LE1TER 88-01 This evaluation consisted of a review of the response to NBC Generic Letter 88-01 of January 25, 1988 by Public Service pertaining to Hope Creek:to determine if their performance and plans are in conformance with the NRC Staff positions or if proposed alternatives are acceptable.

Proposed inspection schedules and amendments 'to the Technical Specification were included in the review.

2.1 Documents Evaluated Review was conducted on the information pertaining to Hope Creek 2

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provided by the Licensee in the following documents.

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" Response to Generic Intter 8641, Intergresular Stress Corrosion Cracking, Hope Creek Generating Station, Docket No.

50-354." Public Service Electric and Gas Campany P.O. Bos t

236. Rancocks Bridge, NJ 08039, July 29,1988.

" Response to Request for Additional Inforestion, Generic Letter 88-01, Hope Creek Generating Station Docket No. 54354," Public Service Electric and Gas Company, P.O. Bos 236 Bancocks Bridge, t

NJ 08038, June 2, 1989, e

Hereafter, in this report, these documents will be referred to as Public Service Submittal No. 1 and No. 2, respectively, and collectively as the Public' Service Submittals.

2.2 Review of Public Service's Responses to Staff Positions and Isolamentation of Those Positions.

Generic Letter 88-01. outlines 13 NRC Staff positions pertaining to (1) materials (2) processes, (3) water chemistry, (4) weld overlay (5) partial replacement, (6) stress improvement of cracked weldsents, (7) clamping devices, (8) crack evaluation and repair criteria, (9) inspection methods and personnel, (10) inspection schedules, (11) sample expansion (12) leak detection, and (13) reporting requirements. Generic Intter 8EM)1 states that the licensee should indicate in their submittal whether they endorse these NRC Staff positions or propose alternative positions. The Public Service Submittels contain specific discussions on these items, and their positons are summarized in Table 1.

Note that Public Service indicated acceptance of twelve of the thirteen NRC Staff positions; however they proposed alternate positons (see Section 2.7 of this report) to portions of the 3

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Summary of Public Service's Responses to Staff Positions PSEG "-N111 PSEG Accepts WRC Applied Consider for l

Staff Position Staff Position la Past Puture Use yes(*}

W no

1. Materials yes no(b)

2. Processes yes yes

3. Water Chemistry yes yes yes no ")

yes I

4. Wold Overlay yes yes(b)

5. Partial Replacement yes no

6. Stress Improvement of no(,)

yee Cracked Weldsente yes no ")

yes I

7. Clasping Devices yes

8. Crack Evaluation and no ")

yes I

l Repair Criteria yes f

9. Inspection Method l

and Personnel yes yes yes

10. Inspection Schedule yes no no

11. Sample Expansion yes no yes no(d)

,,(d)

,,(d) i 12.14ak Detection i

13. Reporting Requirements yes no yes (a) Followed NUREG 0313. Revision 1 during design, fabrication, and construction, so most welds are IGSCC Category A welds.

I Exceptions: Non-resistant Inconel (allowed by Revision 1 of l

)

NUREG 0313 but not by Revision 2), so those welds are IGSCC Category G.

i (b) No additional piping replacement or mitigating actions planned unless IGSCC occurs in the future.

(c) No IGSCC has been found at Hope Creek, so no repairs or evaluation has been required. Will be considered for future use if IGSCC occurs.

(d) PSEG accepts some of the requirements of Generic latter 8tM1, but they proposed alternate positions on other requirements.

See text for discussion.

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Note slee that they have not requirements for Isakage Detection.

performed. weld repairs or Crack Evaluation sad Repair Criteria since they have not encountered IGSCC at Hope Creek. They do not f

plan add'itional piping replacement or mitigating actions unless

.they encounter IGSCC in the future.

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2.3 Review of Classification of Welds. Previous Mitimatina Actions, and Previous Inspections 2.3.1 S---- rf of IG W Classifications and 7

lustification for Classifications Public Service Subsittal No. 1 did not provide a listing of welds at Hope Creek that are within the scope of Generic Public Service Submittal No. 1 dose, however.

Letter 88-01.

contain descriptions of the materials and processes that l

were used at Hope Creek which were used to assign IGSCC l

classifications.

During design, f abrication, and construction of Hope Creek, Public Service followed the guidance contained in NUREG-0313, l

As a result, most welds (exceptions are discussed I

Revision 1.

in Section 2.3.5) were either constructed with corrosion l

resistant materials, solution treated, or clad with corrosion resistant cladding and are, therefore, IGSCC Category A welds.

Specifically, with the exceptions discussed in Section 2.3.5 the materials used are as follows:

(1) Types 304L and 316L stainless steel.

(2) Types 304 and 316 stainless steel - solution heat treated after shop welding.

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l (3) Carbon and low alloy steels.

, (4) Corrosion Resistant Cladding (CBC) and 55 ferrite weld filler metal and casting on field welds and heat af fected nones.

2.3.2 h==cles of Materials and Prc-:rrr :-

Used for IG E Cateaort A Welds Public Service Submittel No. I also contains several esemples of action that was taken to minimise the possibility of ICSCC which are quoted below "The reactor pressure vessel (RPV) aossie safe-ends and estensions were replaced with corrosion resistaat materialn and the thermal sleeves were redesigned to eliminate crevices."

" CRC was applied to field weld connections of Type 304 stainless steel piping in the recirculation system cad all shop welds were furnace solution heat treated before installation."

"To minimise the number of stagnant lines, the recirculation system bypass line and control rod drive return line were eliminated."

"The stainless steel piping in the core spray (CS) and residual heat removal (RHR) systems (the low-pressure coolant injection line and RPY head spray line) was replaced with impact, tested carbon steel piping from the RPV to the outboard containannt isolation valve."

"The RHR shutdown cooling suction and return lines have 6

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Type 304L stainless steel transities pieces between the recirculation line connections and the tapact-tested

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carbon steel pipe that estende to the outboard containment isolation valve."

Regarding solution heat treating used for piping at Hope Creek, Public Service stated that solution heat treatments were performs.1 in accordance with accepted procedures and specification as required by NUREG 0313. Revision 2.

2.3,3 h = 91es of Fabrication and Construction Procedures lPublicServiceSubmittalNo.1containsseveralexamples of fabrication techniques and construction procedures that were used to minimise the possibility of IGSCC which are quoted belows

" Welding heat input was restricted to 110,000 Joules per inch maximus', and interpass temperature to 350'F.

High heat welding processes, such as block welding and electroslag wel m g, were not permitted."

"All weld filler metal and castings were required by specification to have e minimum of 5% ferrite."

"Whenever any wrought austenitic stainless steel was heated to temperatures over 800'F, by means other than welding or thermal cutting, the material was again solution heat treated."

" Exposure to contaminants capcble of causing stress corrosion cracking of stainless steel components was avoided by carefully controlling all cleaning and processing matericts that' contact the stainises steel 7

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"Special care was esercised to ensure removal of surface contaminants prior to any heating operations."

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" Water quality for cleaning, rinsing, flushing and testing was controlled and monitored."

" Suitable packaging aad protection were provided for i

components to maintain cleanliness during shipping and storage."

2.3.4*Suoniemental Information on Catemore A Welds Since a list of welds was not included in Publia Service Submittal No. 1, such a list was requested in the RAI (Request for Additional Information). The reply to that request e

(Public Service Submittal No. 2) contains a list of all welds l

that are within the scope of Generic Letter 88-01 plus a list of the saan welds in the associated piping. This list shows the weld identification number, system (including the line number), pipe size, configuration, materials (weld metal l

and associated base metals), mitigating treatments, and i

inspection pie.ns for each veld.

Although the list of welds in Public Service Submittal No.

2 is not reproduced in this report, a summary of the IGSCC Category A welds is shown in Table 2 of this report which shows the number of IGSCC Category A welds by system 'line number, and diameter. Note that the total number of welds l

I-classified as IGSCC Category A is 152. An examination of the material data and the list of mitigating treetsents contained in Public Service Submittal No. 2 revested that the welds classified as IGSCC Category A are correctly 8

Table 2 Summary of Inspection Schedules for

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1G800 cate8 cry A Wolds at Hope Creek No. Scheduled for Inspection Dia.

No. of Durian Indicated Refuel. Outame*

Srstes Line Number __

h Welds Zagg,331Jgig M M M h

Recire 1-BB-2tfVCA-011 28 14 1

1 0

Rectre 1-58 4VCA-011 4

2 Recirc 1-BB-28VCA-012 28 14 3

2 5

0 Recire 1-B b 4VCA-012 4

2 Recire 1-BB-28VCA-013 28

'12 1

3 1

1 2

8 Recire 1-BB-22VCA413 22 8

2 1

3 0

Recirc 1-Bb 4VCA-013 4

2 I

Recire i-Bb12VCA-013F 12 25 2

3 5

Recire 1-RB-28VCA-014 28,.

12 1

1 1

3 Recirc 1-BB-22VCA-014 22 8

1 1

3 5

0 Recirc 1-B5-4VCA-014 4

2

-Rectre 1-Bb 28VCA-014A 12 25 3

1 2

6 RHR 1-L12LDA421 12 2

2 2

RHR 1-W 20CCA-114 20 10 1

1 2

4 RNR 1-L 12CCA-114 12 10 3

3 2

8 RWCU 1-W 4CCA-011 4

2 2

2 RWCU 1-BG-4CCA-012 4

2 2

2 152 11 11 3

9 15 5

54 Totals 7% 7% 2% 6% 10% 3%

36%

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l Notes:

a. Generic Intter 88-01 requires 25% of IGSCC Category A Welds to be inspected every 10 years (at least 12% is six years).

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b. Explanation of abbreviations: Recire - Reactor Recirculation, I-(.'

RHR - Residual Heat Removal, RWCU - Reactor Water Cleanup.

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b classified inasumch as each of those welds wass (1) constructed of resistant asterials, per NUREG 0313. Revisies 2 and Generic Letter 88-01 (2) solution treated folieving weldings and/or (3) clad (with CRC) following welding.

2.3.5 $ terials Used in IGSCC Catemorr D and C Welds Table 3 of this report shows twenty areas that contain nickel-based alloys according to Public Service Submittal These alloys are considered by the NRC Staff to be No. 1.

non-resistant asterials (per NUREG 0313, Revisten 2), although previously (por NUREC 0313, Revision 1) these s11eys were At the time Public lconsideredtobecorrosionresistant.

Service Submittal No. I was submitted, no inspections had been performed on any of these velds, so they were classified as IGSCC Category G welds. Subsequently, during the second aidcycle outage which occurred prior to the submittal of Public Service Submittal No. 2, sixteen of the 20 IGSCC Category G welds were inspected (see Section 2.3.7) and reclassified as IGSCC Category D welde.

2.3.6 Hydromen Water Chemistry Tests Tests were developed to study the effects of hydrogen The tests have not yet bass completed, but initisi injection.

testing has proven successful.

2.3.7 Previous Inspection Promrams Public Service Submittal No. 2 indicates previous outages as follows:

1st. Refueling Outage - 02/12/88 to 04/15/89 2nd. Midcycle Outage - 02/18/89 to 03/06/89 10 9

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Table 3 Nicket Based Alloys in Rope Creek (IGSCC Category G Welds)

Material Noszie Finer /5kfe-and/Can Description _

Butter Svetese Nos.

Suction N1A, N1B Nossle/ Safe-end ENICrFe-3 ERNiCr-3/ENicrFe-3 Recire.

Discharge N2A, N2B Nozzle / Safe-end ENICrFe-3 ERNiCr-3/ENiCrFe-3 N2C, N2D N2E, N2F H2G, N2H N2J N2K Core Spray NSA, NSB Nozzle / Safe-end ENICrFe-3 RNicr-3/ENiCrFe-3 55-166 (Safe-end) and Safe-end N5A, N55 Safe-end/ Safe-end ENiCrFe-3 SS-166 (Safe-end)

Estension Welds and Safe-end b

Head Spray N16A Nozzle / Flange ENiCrFe-3 ERNiCr-3/ENiCrFe-3 1

JPI N8A, N88 Nozzle / Safe-Ends ENicrFe-3 ERNiCr-3/ENiCrFe-3 1

l CRDA N9 Nossie/ Cap & Cap ENicrFe-3 S5-166(Cap) 1

• Abbreviations:

Recirculation Recire.

Jet Fump Instrumntation JFI Control Rod Drive Return CRDR e

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Sisce it is not likely that the First Isiseling Outage would isst for fourteen months and overlap the midcycle outage, the

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completion date listed for the First Refueling Ontage is Hereafter is this report, it will be assumed probably in error.

that that date should be listed as 04/15/88 rather that 04/15/89. Based on that assumption Public Service Submittal No. I was submitted after the First Refueling Outage but prior to the Second Midcycle Outage, and Public Service Submittal No. 2 was submitted after completion of both outages.

No previous inspections are reported in Public Service Submittel

,No. 1 except for a statement that previous inspections were

' conducted in accordance with the NDE Coordination Plan implemented at the EPRI NDE Center in Charlotte, North Carolina.

However, Public Service Submittal No. 2 lists a total of 11 IGSCC Category A welds and 16 IGSCC Category G welds were f

inspected during two outages. No flaws were found. Thus, in Public Service Submittal No. 2, sixteen of the 20 non-resistant welds are classified as IGSCC Category D welds, and 4 are classified as IGSCC Category G.

t 2.3.8 Evaluation and Recommendation Public Service applied materials and processes recommended by NUREG 0313 Revision 1 in the design, fabrication, and l-construction of Hope Creek with the result that most welds are IGSCC Category A welds. Exceptions are several nozzle areas which contain non-resistant nickel-based materials and are classified as IGSCC Category D and G welds. The Public Service Submittels provided excellent descriptions of materials sad processes and a complete list of welds (including eitigating treatments and previous inspections) that justify their IGSCC classifications. Acceptance of Public Service's IGSCC Classifications is, therefore, recommended.

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C, 2.4 Current Ptaan for Nitimatina Actions 2.4.1 '--- ev cf P1===

Public Service has no specific plans for future aitigating actions except for the introduction of Hydrogas Vater Treatment. Action will be taken, however, in tbs event of discovery of IGSCC during future inspections. These items are discussed in greater detail below.

2.4.2 Roomirs/Renlacement iIn the event that IGSCC is discovered during subsequent linserviceinspections.PublicServicewillutilisethelatest industry accepted techniques cassensurate with NRC Staff recessendations given in Generic Intter 88-01 and NUREG 0313, Revision 2 to accomplish the repairs and/or replacements.

2.4.3 Hydromen Water Chemistry As mentioned in Section 2.3.6 of this report, tests were developed to study the effects of hydrogen injection, and initial tests were successful. At the ties that Public Service Submittal No. I was submitted, long-ters usage was still under investigations however, Public Service Submittal No. 2 states:

"With the issuance of Ansadsent 23 for HCGS, the NRC approved the use of a permanent hydrogen water chemistry (HWC) system. installation is scheduled during the second refueling outage (presently scheduled from September - November 1989). At this time, PSE&G will not request any changes in the Inspection Schedules specified in the Generic Iatter as a result of the use 13 l

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f 2.4.4 Evaluation of Confe a ce to Staff Positions

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and Recommendstico I

Since extensive mitigating actions have already been applied -

at Hope Creek, Hydrogen Water Chemistry should further reduce l

the possibility of IGSOC at Hope Creek, and plass will be redirected to repair or replace piping that develops IGS00, Public Service's current plan.concerning mitigating treatments are reasonable. Acceptance of that plea is, therefore,

.', recommended.

2.5 Inservice Inspection Fronram 2.5.1 S = ry of fnsoection Schedule Dates of ths various outages (during which inspection have been or will be performed) are:

L 1st Refueling Outage 02/12/88 - 04/15/88 2nd Midcycle Outage 02/18/89-03/06/89 s

2nd Refueling Outage 09/16/89 - 10/31/89 1

3rd Refueling Outage 01/26/91 - 03/11/91 4th Refueling Outage 10/31/92 - 12/14/92 l

5th Refueling Outage 11/05/94 - 12/19/94 6th Refueling Outage 11/02/96 - 12/16/M Public Service Submittal No. 1 contains the following information pertaining to inspection plans for Hope Creeks g

(1) ICSCC Catemory A welds: The schedule for inspection i*

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l will follow the temparable previstema of Secties II of the ASME Boiler and Pressere Vesset Code 1983 Edities through the Summer of 1983 Addeada, and include additional inspections which assare that 255 of the welde susceptible to 10000 v111 be asemised i

overy 10 years.

(2) JftSOC Catemorr G velds: All stekel-base alley welds f

i (which as discussed earlier are classified as 10:00 Category 0 welds) will be inspected daring the nest i

i refueling outase, scheduled for toptember, 1989, 6

after which they will bn reclassified as 10500 Category D.

Dotatied inspections. schedules, contained in Publie Service Submittal No. 2, confirm that inspections ochedulee have t

been designed that are in keeping with the above statements and the reguirements of Generic Letter 88-01. This may be j

verified by an esamination of Table 2 (which summarises the ochedules for IGS00 Category A welds) and similar summary of schedules for ICS00 Category D and G welds abova in

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Table 4.

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Note that the schedule for IGS00 Category D welde differs slightly from NRC Staff guidelines (i.e., 100X overy second refueling outage rather than 505 every refueling outage).

Public Service Submittal No. 2 contains the following explanation.

I "The Rope Creek esamination schedule for Category D weldsents differs slightly from the NBC Staff Recommendation on Inspectica Schedules as stated in NURE00313, Revision 2. Section 5.3.2.4.1he Staff

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recommended that approzinstely half of the 10 SCC 15

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I Cate ery D weldments be esamined every refueling outase.

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• tocause of the cast associated with mobilisation, preparation and performance of, these asaniastions PSEsG l

will perform 1005 et the esaminations of the 100CC

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oueceptible weldsente during overy other gefseling j

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Table d Summary of Inspection Schedules for i

IGSCC Category D and G Wolds at lope Creek t

Number Scheduled for Inspection (s) j IGSCC No. of Durina Indicated Ou*==

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16 16 16 16 G(b) 4 4

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I (a) Generic htter 88-01 requires all 10000 Cetagety D welds i

to be inspected every two refueling estages ( M e x h outage) f and for all IGdCC Category G welds to be inspected during the nest refuelir.g outage.

l (b) IGSCC Category G welds will be reclassified to Category D fo11 ewing the inspections scheduled for the 2nd. Refueling l

Outase, assuming no cracks are found.

i 16 p

4

,-c a

-.,e n.,,,_.--,..,

_,,,,.,,e, n,, _., - -

f l

t t

i 2.5.2 Inaccespible Welds 1

No inaccessible welds are listed is hblic Servise Submittal No. 1 for Nope Creek. In reopense to the RAI cancersias l

inaccessible welda, Public Service Submittal No. 2 states i

that all welds e: hor than IG900 Category A are fully l

accessible and will be inspected as discussed la the previous section.

2.5.3 MethMe and Personnel I

Public Service Submittal No I states that all future I

', inspections will be conducted in accordance with the NDE Coordination Plan implemented at the EPt1 NDE Canter in Charlotte, North Carolina, i

i 2.$.A '--ale Eneamaton Sample Expansion et Hope Creek will comform with the NRC Staff position. Specifically, Public Serview Sobetttal No. 1 statest "Should one or more IG500 Categories A, B, or C welds ashibitias'IGSCC be found by a sample inspection during the 10 year ISI interval, an addittomal enople of the

[

welds in that category will be inspected, approsiastely equal in number and service history to the origins 1 sample. 'this additional sample will be stallar in distribution (according to pipe siae, system and location) to the original sample, unless it le determined that there is a technical reason to select a different distribution. If any welds in the espanded sample exhibit

+

ICSCC, all welds in that category will be ins?ected."

I f

i i

g7

-. - _, _ _ _ _. -. _ _ _ _ _. _. - - _.. - -. _ _ _,. _ _ _. ~ _ _ _. _. ~.. - - _

2.5.5 Evaluation sqd Recommandations he only deviation from the NBC Staff posities conceratag taspection schedules is the stoor one concerning IGSCC Category D welds (i.e., inspect 1005 of these welds every second refueling outage rather than 501 each refueling outage). his plan is reasonable and adequetely cospites with the inspection requirements. Plans for methods and personnel av for semple espansion comply with the NRC Staff positions. Taus, acceptance of Public Service's ISI (Inservice Inspection) Progras is recommended.

2.6 Channes in the Tehaical Specification Concernina 18I Public Service presented an alternative position of that of the NRC Staff which requires a change to the Technical Specification stating that the Inservice Inspection Program vill be la conformance with the staff positions on schedule, methods and personnel, and sample espansion. h is alternative position is discussed in Section 3 of this report.

2.7 Confirmatier 3 M Detection in the i-Technical Ssecificatica l

Public Service presented an alternative positions to portions of l

that of the NRC Staff position concerning leakage requi:ements in the Technical Specification. Bus, discussion of leakage L

L detection is deferred to Section 3 of this report.

l 18

o l

j 2.5 PU -- for Natificatieu of the E of Flave

~

2.3.1 Publie Service's Posities i

Public Service endorses and will comply with the NRC Staff position en reporting of flaws. Specifically, Public Service i

Submittal No. 1 states the followings i

I "PSE&G will notify the NRC of fiev evolusticas and/or repaire for cracks that de not aset Secties IWS-3500 criteria for continued operatios er any change found

)

in the condition of welds previously knows to have IG800.

In addition, timely recanaandations made by the NRC for aample espansion based upon this motificaties will be considered.

2.8.2 Evaluation and Recommendation i

)

Public Service's plans for reporting of fisys complies with the NRC Staff position, so it is recommended that the plane l

for reporting of flaws should be accepted.

i l

3. ALTERNiTIVE POSITIONS i

3.1 Alternate Domition on ISI in the TWieal Snecification 8

3.1.1 Public Service's Position Public Service declined to initiate t.he requested change in the Technical Specification conc 6rair.g ISI. Rather they proposed thac the information pertaining to the Inservice i

Inspection Program should be contained in the ISI Program Long Term Plan (ISI LTP), and that such a change would be 19

.--.-,,_,_._..,...~,_..., _..._.._._,-_ ___

._____._______,-___________m-

O i

I tecluded is the oest revistaa of that plan. Bessens for j

this alternative approach are se felleus (geoted from the j

Nblic Service Submittal):

t I

"If an 1st was submitted and approved by the NBC staff, the taformation would eventually be relocated ta the f

ISI L.W as a result of the Technical specificaties f

improvesest effort and therefore incluetos la the j

Technical Specifications for the near ters to unneccesary l

and unproductive."

r

]

"The ISI LW will be revised regardicos of the outcome of the Technical specification improvement effort and f

l thus the caemitmente contained in this transmittal wt11 already be incorporated into the appropriate relocaties document."

t i

"he fact that this transmittal containe commitments I

which satisfy the intent of the various staff positione identified in the generic letter and NUKEG 0313 Revision 2 is aufficient to assure compliance."

3.1.2 Evaluation and Recommendation The NRC Staff, in formulating Generic latter SS41, recognised

)

that Inservice Inspection and Testing Sections may be removed from the Techair.a1 Specifications la the future in line with Even the Technical Specificatione Improvement programs.

so, the NRC Staff requires that this change be made at this time. In addition, including a statement in the ISI Plan would not carry the same weight as including a statement in the Technical Specifications. Thus, rejecties of the Public Service position is recommended, and Public Service should aske the requested change in the TS en IMI.

20 i

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4 g

• 1,

3 3.2 Confirmation of f- ' betecties in N TechnicallSmacif(ggtina 1

Table 5 of this report was constructed frem inferentien supplied i

Note that in a sta11er table in Public Service Submittal No. 3.

l the Hope Creek Technical Specification es laskage detection cesferas i

with some portions of the NRC Staff posities en leakage detectf en, Additieast but alternate positions are proposed for other pertions.

discuestem to provided below.

i 3.2.1 Adherence to Romulatorv_ Cuide 1.45 f

.* Public Service Submittal No.1 etates they have censitted to follow Regulatory Guide 1.45 Revision 0 dated May,1973 j

for Hope Crook leakago with the certata clarifications or Does aime f

esceptions to the nine items under Position C.

items (which are described in Public Service Submittal No.

l 1 but not reproduced here) were previously reviewed and l

approved by the NRC Staff (

Reference:

" Safety Reatuation 1

i l

Report," SER - NUREG-1048).

(

l t

3.2.2 '2 6-se 1.inits t

i

)

b Generic latter r'equires that plant obst deva should be f

initiated for corrective action wheat (a) withis any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> f

period say leakage detection systes indicates an increase of unidentified leakage in escoes of 2 spa, or (b) the total 1

I umidentified leakage attains a rate of 5 spa or equivalent.

l i

Public Service Submittal No. I contains the following j

l statements t

l

" Regulatory Guide 1.45 does not specify leakage rate t

limits nor actions which should result if such limits 4

i l

21 L

l l

, _.... _. ~... _, _

.~

l i

Table S 1.icensee Posittens on taekage Detection j

1 I

Already 11 will be Alternate Contained Ghtaged Peetties r

Position in TB te Easlude Presemed 4

1. Conforms with Poettion C of yes Regulatory Guide 1.45

2. Plant shutdown should be initiated when:

se se yes (a) within any period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> er less, an increase to indicated in the rate of unidentified leakage in escoes of 2 aps, er,

(b) the total snidentified leakage yas 1

attains a rate of 5 spe.

l se so yes j

3. lankage sosttored at four hour

(

intervale or lose.

i

4. Unidentified leakage includes all I

I except i

i (a) leakage into elooed systees, yes j

or

(

I l

(b) leakage into the contalement yes atseephere from eeurces that are located, de not interfere with monitorias systone, or not free throushwall crack.

5. Provisione for shutdeva within 24 yes j

hours due to inoperable measurement instruments in plants with Category e

D E. P, or G welds.

i Note See test for descriptions of alternate posittens and discussione i

on other items.

22 9

l l

e.re escoeded, deferring lastead to the Technical j

Technical Specifisetten 3/4.3.2 specifies j

' Specifications.

l annimum leakage rete limits and corrective esticas required when these limits are escoeded. Oerrently there La no requirement for corrective action nor plant shutdown f

if unidentified leakage increases by ever 2 spa per 24 l

l Rather. the corrective acties only addresses f

hours.

unidentified leakage in oncese of 5 spa er any identified l

RCPS leakage. Newever, the drywell floor drain eusp l

monitoring systes deeis alors when unidentified leakage l

increases by more than 1 gys. 1his alars functies to an entension of Regulatory Guide 1.45 Posities C.2 and l

b refore, PSE&C (Public Service) believes that adequate alors indications esist and the current Techstest f

C.S.

I l

Specification requirements and corrective actions assere l

prompt detection of and response to RCPS leakage."

t l

[

N folieving additional comments are contained in Public Service Submittal No'. 2:

I "Alars indication of leakage increase greater than 1 l

sps Per hour is provided through the Drywell Sump Isak l

Rate Monitor (a Class 1R microprocessor) in the Radiation l

Monitoring System (RMS). N past four hours of flov l

rate data is available to the operater at either the j

niereprocessor or the RMS computer ceasele for trending l

purpenes if an alare occurs. Prompt operator response l

assures that unidentified leakage will not exceed 5 sys."

"If reactor coolant 'systes unidentified leakage rate l

is greater than 5 syn, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> the leakage rate aust be reduced to within 5 sps or withis the nort 12 l

bours the plant most be la Cold Shutdown per Technical l

Specification 3.4.3.2, Acties (b). N $ sps Technical 1*

23 l

i l

S o

Specificaties maximum criteria for unidentified leakage

~ to established to allow time for corrective acties before the preset. barrier aeste be significantly compromised eince 5 spe represents only a oesti fracties of the r

calculated flow fras a critical creek in a primary system pipe (reference: Updated Final Safety Analysis Report

)

)

(UFSAR), Figure 5.2.-12."

i 3.2.3 Freeuenev of Le-6-me Mnamur-nt i

l Generic Istter SS 41 requires that leakage abould be monitored for determined from flow asseurements if flow is aestiasously i~

' sonitored) at approximately four hour intervals or less.

I i

Public Service Submittai No.1 costalas the fellowing statements "50G8 utilises a Claea 1E microprocessor based systes j

i to calculate the unidentified leakage collected in the drywell floor drais cump. As as taput to this systes, f

l the sump level is asseured via a differential pressure transmitter which provides a signal to sa analog to

[

digital converter, which converts this signal to a bit l

etsivalent. Because the sump ceafiguraties and f

tramositter span is provided to the processer, it j

calculates gallons per bit values. De radiation l

l processer in the Class 15 Radiation Monitoring Systes f

(RMS) uses the information to caleviate a flow rate on 4

l the basis of bit changes and the time elapsed since the previous bit change. h is information is continually l

displayed at the RMS panel er via data link to the f

operatore console. Upon sensing a 5 spa leak rate or j

an increase in leakage of I spo per hour, within 1 minute.

l the processor initiates an alars."

24 i

I I

--.--e.

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,,.-_,,.,_m,,._,,_,__,.n_mw_

___--.._.-_.,_,,._-w____,_,__m

-__e_,__-.

l i

D e following addittomal comments are castained La Public i

Service Subsittal No. 2:

l

" Technical Specification 4.4.2.7.1.b requires the drywell floor drain susp flow rate (unidentified Seekage) and j

equipment drain sump flow rate (identified leakage) to la addition, be moeitered at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

l the flow rete calculaties to performed by the Drywell l

Susp 14ak Rate Monitor (a Class it microprocessor) is I

the RMS every time the sump level abanges by approstaately i

0.16 inches (1.5 gallene) la unidentified leakage er i

4.9 gallone is identified 1st,kage) rather than at fined i

time intervale. h is method assures that en slots occurs i

within 1 minute of the unidentified flow escoeding 5 l

I sps or the identified flow escoeding 15 spm."

l r

3 3.2.4 Oneeristion of tinidentified 14akene i

l Casorie latter 36-01 states that unidentified leakage should include all leakage other thans (a) leakage into closed f

systems, and (b) leakage into the containment atmosphere from sources that are both specifically located and known eitbar set to interfere with operations of moattoring ersteme l

or not to be from a throushumil crack.

l Public Service Submittal No.1 costoias the following statements

" Identified leakage from pumpe, valve stem packings and the reacter vessel head seal are discharged to the l

equipment drata susp and semitored during plant operation.

I Unidentified leakage is that porties of the total leakage not identified above and collected ta the floor drain j

Unidentified leakage includes any allevance for susp.

25 I

l

\\

leakage that does not compromise barrier integrity and

. is not identifiable."

l L

l, he following additional statement is contained is Public i

Service Submittal No. 2:

B

" Technical Specification Section 1.17 defines Identified i

imakage es ' Leakage into collecties systems, such as I

pump seal er valve packing leeks, that is captured and conducted to e sump or collection taaks' rather thaa l

tato closed systems. h is leakage is cellected is the-equipment drain susp and monitored as described..."

l (notes decription referred to is in Secties 3.2.3).

i 3.2.5 Onorability of Messir-t Instrumssta Generic latter 66-01 statec that for plaats operating with l

any 10S00 category D E. F, or 0 welds, at least one of the i

1eakage measuroeset'instrumente associated with each susp shall be operable, and the outage time for inoperable i

tastruments shall be limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or famediately i

initiate as orderly shutdown.

Public Service Submittal No. 1 states that Sepe Creek l

Technical Specification 3/4.4.3 identifies the operability and corrective action requirseests for the five leakage Corrective action is required as follows:

detection systems.

"If only four of these five systems are operable.

continued operation is permitted for up to 30 days provided grab samples of the containment atmosphere are obtained: however, the drywell fleer and agaipment drain If either of sump sonitoring afstem must be operable.

these two sump sonitoring systems are taoperable (or 1

26 f

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,,..-a,,.,

av-..,_n p

--- e

I

)

less than three other systems are inoperable or inoperability continues for more than 30 days) plant

~

shutdown is required within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

l Public Service Submittal No. 2 contains the following j

additional statement pertaining to requirements for operability of esasurement instruments:

"In accordance with the Action Statement of Technical Specification 3.4.3.1, when the drywell floor or equipment drain sump monitoring system becomes inoperable, the I

plant suet be in Hot Shutdown within the neat 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

In addition to the drywell floor drain sump monitoring l

systee and the drywell equipment drain sump monitoring i

systes, four additional methods of measuring reactor coolont systes leakage include:

- drywell atsosphere gaseous radioactivity monitoring systee.

- drywell air cooler condensate flow rate monitoring

systee,

- drywell pressure monitoring systes,

- drywell temperature monitoring system.

Inoperability of any of these four systems requires obtaining daily grab asepless however, operability must be restored within 30 days or a plan shutdown is required."

The actual wording of Technical Specification 3.4.3.1 is 27 I

l l

o as follows:

' "he following reactor coolant system leakage detection systems shall be operable:

a. The drywell atmosphere gaseous radioactivity monitoring systes, 1

I

h. The t'rywell floor and equipment drain susp j

monitor.'ns systes,

c. The drywell air cooler condensate flow rate sonitoring systes,

d. The drywell pressure monitoring system, and

e. The drywell temperature monitoring system".

" ACTION: With only four of the above required leakage detection systems OPEllABLE, operation any continue for j

up to 30 days provided grab anspies of the containment I

atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> wher. the required drywell atmosphere gaseous radioactivity monitoring system, the drywell pressure wonitoring system, the drywell temperature monitoring system and/or the drywell air cooler condensate flow rate monitoring system is inoperable: othervice, be in at least H(TT SHttfDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in i

COLD SKITfDOWN within the following 24' hours."

3.2.6 Evaluation and Recessmendations The following evaluation and recommendations are made concerning leakage detection at Hope Creek.

28

J e

y, (1) Regarding Conformance with Position C of Reguistory

~

Cuide 1.45: Public Service states that with certain clarifications (previously approved by the NBC Staff) they are in conformance. Thus, acceptance of this portion of their position on leakage detection is recommended.

(2) Regarding Leskase Limits: they endorse the requirement for plant shut down when the total unidentified leakage exceeds 5 sps, but chey do not endorse the requirement for plant shutdown when the rate of increase of unidentified leakage exceeds i

l 2 spa since an alare occurs when that lenkage rate exceeds 1 sps. Although Public Service stated that this alors w'ould assure prompt detection, response, and corrective actions, these actions were not l

specified or described. Thus, it is reconsended i

that Public Service's position regarding plant shutdown when the rate of increase of unidentified leakage exceeds 2 sps should be rejected and that such a requirement should be added to the Technical

{

i Specification.

(3) Regarding Requirements for Operability of Measurement Instruments: The statements in the Public Service Submittals are ecceptable. However, the actual wording in the Technical Specification is confusing I

and open to interpretation that differs from that given in the Public Service Submittals. It is rocossended, therefore, that the wording in the Technical Specification should be changed and stated as given in the Public Service Submittals (as quoted in Section 3.2.5 of this report).

29

r l

e e

e

+

. (4) The remaining aspects of Public Service's position concerning frequency of lankage esasurements and l

the description of unidentified leakage are acceptable.

4. CONCLUSIONS AND REC 000GDfDATIONS Public Service included discussions which specifically addressed the the thirteen NRC Staff positions in their submittal. Doy indicated that they endorse all twelve of the NRC Staff positions,' but they presented, alternative proposals to portions of the NRC Staff positions i

on leakage detection requirements.

Public Service followed,NUREG 0313, Revision 1 during the design, fabrication, and constructions of Hope Creek so that most welds that i

are covered by the scope of Generic Letter 88-01 are ICSOC Category l

l A welds because they: (a) contain corrosion resistant esterials (b)

[

have been solution treated, or (c) were clad with corrosion resistant f

cladding. Esceptions were in 20 nozzle areas which contain non-resistant Inconel alloys. Welds in these areas are classified as IGSOC 9

Category G welds.

i Future sitigating actions planned for Hope Creek include the following:

l (1) Piping replacement or veld repair (following procedures recommended j

in Generic Letter 88-01 and NUREG 0313. Revision 2) will be used in the event of the discovery of IGSOC during future inservice inspections.

l (2) Hydrogen Water Chemistry (HWC) will be implemented.

l l

Inspwetions at Hope Creek have been performed on 16 or the 20 l

non-resistant welds and on some of the IGSOC Category A welds. Dose i

were performed in accordance with the Coordination Plan implemented l

st the EPRI NDE Center at Charlotte, North Carolina. B ey stated that future inservice inspections would also be performed by methods and 30 l

\\

e-l l

personnel approved by the NRC in Generic !stter S M 1 and W ERG 0313 Revision 2.

They further stated that schedules, esople espansion.

i and crock characterisation and repair criteria would follow Ntc Staff positions. In addition. Public Service submitted detailed inspection j

l echedules for several future refueling outages. These schedules confire j

that Public Services plans conform with the NRC Staff position.

Public Service declined to change the Technical Specification on ISI.

Rather they proposed including statements in the ISI Long Tore Plan that schedules, methods and personnel, and sample espansion vill comply j

with the requirements of Generic Letter 88-01. H is alternative plan would not carry the same weight as a change to the Technical l

Specifications, and reasons presented by Public Service for this j

i alternative position have already been rejected by the NRC Staff in formulating Generic Letter 88-01.

Regarding leakage detection: Public Service presented several clarifications to Position C of Regulatory Guide 1.45 which were i

t previously approved by the NRC. heir pocitions concerning frequency j

1 of leakage measurements, requirements when the total unidentified j

leakage exceeds 5 spe, and description of unidentified leakage are

)

acceptable. On the other hand, they declined to accept requirements I

pertaining to an increase in unidentified leakage of 2 spe, stating that an alare occurs when unidentified leakage increases by more than 1 sps and that current Technical Specification requirements and corrective action (which was not delinesced) are adequate. Hope Creek contains five leakage monitoring systems.

Currently, the Technical Specifications require plant shutdown if either the drywell floor and equipment drain sump monitoring systems are inoperable. On the other i

hand, operation for up to 30 days is allowed if one of the other systems l

I is inoperable, providing that grab samples of the containment atmosphere are obtained.

As a result of this technical evaluation, the following reconeondations are madet 31 t

,-,,~~-,,,-,,nn,e--n--.-,w w,--n~--

P o

1.

Acceptance of Public Service's Plans for Mitigating IGSOC at j

Hope Creek.

1 2

Acceptance of Public Service's Inservice Inspection Program

{

for Hope Creek..

i 3.

Rejection of Public Service's position concerning a change to the Technical Specifiestion on ISI. Public Service should amend their Technical Specification to include the required statement concerning ISI.

A.

Rejection of Public Service's positten concerning requirements f6r plant shutdown when an increase of unidentified leakage of 2 spe occurs. Publ,1c Service should amend their Technical l

Specification to include a statement that requires plant l

ahutdown when, 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, any leakage detection systes indicates an increase of unidentified l

1eakage in excess 2 spa.

l 5.

Public Service should aley amend their Technical Specification i

i to clarify requirements pertaining operability of osasursent instruments as discussed in Section 3.2.6 of this report.

6.

Acceptance of the other aspects of Public Service's position i

pertaining to leakage requirements.

l 7.

Acceptance of the remaining portions of the Public Service Submittal.

32

e-o*.

~*

t

)

5. REFERENCES 1.

" Technical report on Material Selection and Procesetag Guidelines for BWR Coolant Pressure Boundary Piping," WUREG 0313, Revision

2. U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, January,~1988.

2.

" Investigation and tvaluation of Stress Corrosion Cracking in Piping i

of Light Water Reactor Plants," NURBG 0531, U. S. Nuclear Regulatory Commission, February, 1979.

l r

3 "NRC Position on 10803 in BWR Austenttic Stainless Steel Piping,"

Generic 14tter 88-01, U.S. Nuclear Regulatory Commieston, January 25, 1988.

I i

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f i

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l l

t I

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