ML20042D244

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Safety Evaluation Accepting Licensee Response to Generic Ltr 88-01
ML20042D244
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 01/02/1990
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20042D162 List:
References
GL-88-01, GL-88-1, NUDOCS 9001080114
Download: ML20042D244 (4)


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ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EVALUATION OF NRC GENERIC LETTER 88-01 RESPONSE Cleveland Illuminating Company Perry Nuclear Power Plant DOCKET NOS. 50-440

1.0 INTRODUCTION

Cleveland Illuminating Company, the licensee, submitted its response to NRC Generic Letter (GL) 88-01, "NRC Position on IGSCC in 8WR Austenitic Stainless Steel Piping" for Perry Nuclear Station by letter dated July 29,1988, and additional information as requested by the staff was provided by letters dated June 15,1989 and July 31, 1989. GL-88-01 requested Licensees and construction permit holders to resolve the IGSCC issue for BWR piping made of austenitic-stainless steel that is 4 inches or larger in nominal diameter and contains reactor coolant at a temperature above 200 degrees Fahrenheit during power operation regard 1p s 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 IGGSC and provide assurance of continued long term integrity and reliability.

2.

TheInserviceInspection(ISI)Programtobeimplementedatthenext refueling outage for austenitic stainless steel piping covered under the scope of GL-88-01 that conforms to the the staff positions on inspection schedules, 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 by 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 L

SpecificationenclosedinGL-88-01).

It is recognized that the Inservice Inspection and Testing sections may be removed from the Technical Specifications Improvement programs.

In this case, this requirement shall remain with the ISI section when it is included in an alternative document.

4.

The confirmation of your plans to ensure that the Technical S>ecifications related to leakage detection will be in conformance with tie staff positions on leak detection included in GL-88-01.

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The plans to notify the NRC in accordance with 10 CFR 50.55a(g) of any flaws identified that do not reet IWB-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 for continued operation and/or your repair plans.

2.0 DISCUSSION The licensee's response to NRC GL-88-01 has been reviewed by the staff with theassistanceofitscontractor,VikingSystemsInternational(VSI). The attached Technical Evaluation Report is VSI's evaluation of the licensee's response to NRC GL-88-01. The staff has reviewed the TER and concurs with the t

evaluations, conclusions, and recommendations contained in the TER, with the exception of the frequency to monitor leakage. The licensee proposed to monitor leakage every eight hours instead of every four hours as required by GL-88-01. However, the statf has re-evaluated the frequency of leakage monitoring after discussions with several BWR operators and concluded that monitoring every four hours creates an unnecessary administrative hardship to the plant operators. Thus, RCS leakage measurements may be taken very eight hours instead of every four hours as required in GL-88-01.

In the review of the licensee's GL 48-01 submittal, the staff has found the following positions to be unacceptable:

The licensee's position not to amend the Technical Specification (TS) to include a statement on ISI as required by GL-88-01.

The licensee's position not to amend the TS to include limiting the increase in leakage to 2 gpm over a 24 period as required by GL-88-01.

The licensee's position not to accept operability of monitoring instruments requirements outlined in GL-88-01.

For discussion of these items see section 3.0, attachment 1.

3.0 CONCLUSION

Based on the review of the licensee's NRC GL-88-01 response the staff concludes that the response as evaluated is acceptable with the exception of

'the licensee's positions as identified above.

The licensee is requested to submit a TS change that would require an ISI statement per GL-88-01 and the I

staff's GL-88-01 positions with regard to leak detection with the exception l

that frequency of leakage monitoring may be every eight hours instead of every four hours as required in GL-88-01.

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3-The staff also concludes that the proposed IGSCC inspection and mitigation program will provide reasonable assurance of maintaining the long-term structure 1 integrity of austenitic stainless steel piping at the Perry Nuclear

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SALP INPUT FACILITY NAME: Perry Nuclear Power Plant

SUMMARY

REVIEW:

Safety Evaluation (SE) of the licensee's program to resolve the 1GSCC in Generic Letter 88-01 for BWR piping made of austenitic stainless steel that is 4 inches or larger in nominal diameter and contains reactor coolant at a temperature above 200 degrees Fahrenheit during power operation regardless of code classification. The licensee was required to address the following:

1.

The current plans regarding pipe replacement and/or other measures taken to mitigate IGGSC and provide assurance of continued long term integrity and reliability.

2.

The Inservice Inspection (ISI) Program to be implemented at the next refueling outage for austenitic stainless steel piping covered under the scope of GL-88-01 that conforms to the the staff positions on inspection schedules, 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 by the scope of this letter will be in staff positions on schedule methods and personnel, and sample expancion included in GL-BS-01 (See model BWR Standard Technical SpecificationenclosedinGL-88-01).

It is recognized that the Inservice Inspection and Testing sections may be removed from the Technical Specifications Improvement programs.

In this case, this requirement shall reniain with the 151 section when it is included in an alternative document.

4 The confirmation of your plans to ensure that the Technical Specifications related to leakage detection will be in conformance with the staff positions on leak detection included in GL-88-01.

5.

The plans to notify the NRC in accordance with 10 CFR 50.55a(g) of any flaws identified that do not meet IWB-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 for continued operation and/or your repair plans.

NARRATIVE DISCUSSION OF LICENSEE PERFORMANCE-FUNCTION AREA ENGINEERING AND TECHNICAL SUPPORT:

The licensee's responses were submitted according to a schedule consistent with that requested by the staff in GL-88-01.

The licensee was response and has implemented twelve of thirteen items in GL-88-01.

However, the licensee did not add a statement to the TS on leakage monitoring and to include a statement in the TS on ISI as required per GL-88-01.