ML19324C314
| ML19324C314 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 11/08/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19324A911 | List: |
| References | |
| GL-88-01, GL-88-1, NUDOCS 8911160116 | |
| Download: ML19324C314 (2) | |
Text
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j SAFETY EVAt.UATION BY TPF 0FFICE Or NUCLEAR REACTOR REGULATION EVALUATION OF NRC GENERIC LETTER 88-01 Resp 0NSE pilCLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION DOCKET NO. 50-354 1.0 !NTRODUCTION
.Public Service Electric and Gas Comoany (PSE&G), the licensee submitted its response to NPC Generic letter 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Pipino" for Hope Creek Generatino Station by letter dated July 29, 1988.
Additional information as requested by the staff was provided by letter dated June ?, 1989. Generic Letter 88-01 requested Licensees and construction permit holders to resolve the IGSCC issues for BWR piping made of austenitic stainless steel that is 4 inches or laraer in nominal diameter and contains reactor coolant at a temoerature above POO degrees Fahrenheit durihg oower operation regardless of Code classification.
The licensee was requested to address the following:
1.
The current plans regarding pipe replacement and/or other measures taken to mitigate IGSCC and provide assurance of continued long tern integrity and reliability.
P.
The Inservice Inspection (ISI) Program to te implemented at the next re-fueling outage on IST that the ISI program for pipina covered by scope of GL-88-01 will be in conformance with sta'f positions on schedule, methods and personnel, and sample expansion included in GL-88-01.
3.
The Technical Specification change to include a statement in the section on ISI that the ISI Program for piping covered bv the scope of this letter will be in staff positions on schedule, methods and personnel, and sample expansion included in GL-88-01 (See model BWR Standard Technical Specification enclosed in GL-88-01).
It is recoanized that the Inservice inspection and Testina sections may be removed from the Technical Specifications improvement procrams.
In this case, this reouirement shall remain with the ISI section when it is included in an alternative document.
1 4
The conformation of your olans to ensure that the Technical Specification related to leakaae detection will be in conformance with the staff position on leek (4etection included in GL-88-01.,
5.
The plans to notify the NRC in accordance with 10 CFR 50.55a(a) of any flaws identified that do not meet illR-3500 criteria of Section XI of the Code for continued operation without evaluation, or a change found in the condition of the welds previously known to be cracked, and your evaluation of the flaws j
for continued operation and/or your repair plans.
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2.0 DISCOSSION
The licensee's response to NRC GL-88-01 has been reviewed by the staff with the assistence of its contractor, Viking Systems International (VSI). The attached Technical Evaluation Reports (TER) is VCI's evaluation of the licensee's response to NRC GL-83-01. The NRC staff concurs with the evaluation, conclusions, and recommendations contained in the TER.
In the response to NRC GL-88-01 the licensee accepted twelve of the thirteen NDC positions and proposed an alternative position to a portion of the requirements for leakace detection.
The licensee proposed alternative position for leakage detection is not acceptable because it does not meet the guidelines in GL 88-01. The proposed leakage detection in the Technical Specification does not incorporate the unidentified leakage limit of ?
gpm increase in a 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period or less and requires leakage monitoring of once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> rather than once approximately every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Furthermore, the action statement pertaining to the inoperability period of the leakace detection systems in TS 3.4.3.1 is not consistert with the licensee's interoretation which should be revised to clearly indicate that the inoperable period for the sump monitorino system is limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The licensee also proposed to imple-ment the piping ISI requirement in other plant documents rather than the TS. The proposed alternative is not acceptable because the requirements implemented in the other plant documents would not be as enforceable as that in the TS.
Furthermore, this item of piping 151 recuirement was approved to be included in the TS by the Committee to Review Generic Requirements (RGR) as part of GL-88-01.
In addition, the subject reouirement will be included in the Improved Standard Technical Specification for BWR plants.
See section 3.0 of the TER for discussion of these 1Tems.
After discussions with several BWD cperators the staff concluded that monitorinq leakage every four hours creates an unnecessary administrative hardship to the plant operators. Thus, PCS leakage measurements may be taken every eight hours instead of every four hcurs as required in GL-P8-01.
3.0 CONCLUSION
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Based on the review of the licensee's NRC GL-88-01 response, the staff concludes that the licensee's response is acceptable with the exception of the licensee's positions coacerning the leak detection and pipino ISI program as discussed in TER Section 3.0.
The licensee is requested to submit a TS change that would incorporate a statement requiring the performance of the 151 rrocran for pioing as identified in GL-88-01, and the leak detection requirements in conformance with the staff positions in GL-88-01 or the staff's option of monitorino the leakage every eight hours. The staH also concludes that the proposed IGSCC inspection and mitigation pro-gram will provide reasonable assurance of main-taining the long-term structural integrity of austenitic stainless steel piping in the Hope Creek Generating Station. PWR Nuclear power Plant.
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