ML20057E577

Provides Summary of 930630 Meeting W/Bwr Owners Group Re Update of Work on BWR Vessel Internals & Other Matls Issues

ML20057E577
Person / Time
Issue date:	09/13/1993
From:	Strosnider J Office of Nuclear Reactor Regulation
To:	Wiggins J Office of Nuclear Reactor Regulation
References
NUDOCS 9310120309
Download: ML20057E577 (58)

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v WASHINGTON, D C. 20555-0001 SF.P 13 1993 MEMORANDUM FOR:

James T. Wiggins, Acting Director Division of Engineering FROM:

Jack R. Strosnider, Chief Materials and Chemical Engineering Branch Division of Engineering

SUMMARY

OF MEETING WITH BWR OWNERS GROUP FOR AN UPDATE ON MATERIALS RELATED ISSUES On June 30, 1993, the staff met with members of the BWR Owners Group (BWR0G) for an update of its work on BWR vessel internals and other materials issues.

A list of meeting attendees and a copy of the presentation materials are attached. The BWROG's presentation is briefly summarized below:

BWR Reactor Vessel Internals:

General Electric (GE) presented an update of an on-going proactive analysis of 7 high priority reactor vessel internals and attachments to support its plans for inspection and repair. The analysis will determine the allowable flaw sizes and the crack growth for each selected component for one or more operating cycles.

GE also presented sample evaluations of two irradiated components, the core top guide and shroud. The methodologies of the generic analysis of each component will be documented for use by members of the owners group. A draft report is scheduled to be completed by the end of 1993.

GE updated the staff on the intergranular stress corrosion cracking (IGSCC) found at access hole covers (AHCs) of 14 of 33 plants inspected. Cracking has occurred in the creviced Alloy 600 AHC, the shroud support ledge and Alloy 182 weld metal.

The cracking found in the beltline weld region of a 304 stainless steel shroud was confirmed to be irradiation assisted stress corrosion cracking (IASCC) by the metallurgical examination of a boat sample.

The program to determine the root cause of the core shroud cracking and its generic implication is still underway. The GENE SIL is being revised to recommend inspection of both high and low carbon stainless steel shrouds in the oldest plants (those accumulating 190 on-line months).

The evaluation of the cracking of the core top guide at Oyster Creek is continuing. A boat sample is needed to verify the cracking mechanism.

GE also reported that cracking in a J-groove weld of a control rod drive was recently found in an overseas plant. Some GE BWRs use Alloy 182 at this location.

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J. Wiggins Other Materials Related Issues:

During the meeting BWROG discussed the status of the following materials related issues:

1 (1) Relief from Inspection Requirements Based on Implementing Hydrogen Water Chemistry l

The BWROG had submitted a topical report on hydrogen water chemistry (NEDC-31951P) for NRC review in April 1991.

The staff reviewed this report and issued a request for additional information (RAI) in November 1991.

BWROG stated that its responses to the RAI would be finalized in about a week and that Duane Arnold would be the lead plant to request relief from the requirements for augmented IGSCC inspection in Generic Letter 88-01 as a result of implementing hydrogen water chemistry.

(2) Request for Relief from the Requirements of NUREG-0619 for Examining Feedwater Nozzles The BWROG proposes to prepare a generic request for relief from the requirements of NUREG-0619. The relief request would propose to replace the liquid penetrant test with an ultrasonic test and reduce the frequency of inspections.

BWROG is doing a funding request survey to determine the feasibility of undertaking this task.

The decision on whether to undertake this task will be made by July 2, 1993. The staff recommended that the owners group prepare a generic relief request accompanied by a request from a lead plant.

(3) A Model Inspection Program for BWR Reactor Pressure Vessel Welds The BWROG is considering developing a model alternative inspection i

program for reactor pressure vessel welds. This program would be based on priority ranking of all BWR seam welds, attachments,and internals, the probability and consequences of failure, susceptibility to flaws, safety margins, and experience. The staff stated that if the proposed model is based on the probability and consequence of failure, a separate meeting involving the NRC Research Office and fracture mechanics experts should be held to review the risk-based approach.

(4) A New 3-party Agreement for IGSCC Inspection The purpose of this agreement is to integrate the current 3-party (NRC/BWROG/EPRI) agreement on IGSCC inspection qualification under Generic Letter (GL) 88-01 with the Performance Demonstration Initiative (PDI) program. GL 88-01 requires qualification by a program such as that conducted by EPRI.

PDI is a program initiated by the utilities to implement the qualification and training requirements of ASME i

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i Section XI, Appendix Vill.

The 3-party agreement and PDI both address these issues with respect to stainless steel piping.

The new coordination plan is being developed so utilities would not have to keep two separate qualifications.

BWROG provided the staff with a copy of the draft proposal of the agreement. The staff recommended that the integrated qualification program would be better served if managed by an independent third party organization. Subsequent to the meeting, the staff performed a preliminary review of the proposed agreement.

The 3

staff informed the owners group that they are not in favor of implementing such an agreement because the staff does not see the

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advantages or the need of such an approach at this time.

The staff would prefer to see a plan from the owners group on how the industry j

will make the transition from the current three-party agreement to the new Appendixes 7 and 8 of Section XI.

During the meeting, the staff stated that, in view of the cracking being found 1

in the penetrations for control rod drive mechanisms (CRDM) in PWRs, the i

potential exists for a similar problem in BWRs.

The BWROG has committed to include the CRDM penetration welds in the reactor vessel internals and attachments program as a component with high susceptibility to cracking.

The staff also shared with the owners group some overseas crack growth i

information.

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l Jack R. Strosnider, Chief Materials and Chemical Engineering Branch Division of Engineering 1

Enclosures:

(1) A List of Meeting Attendees

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i (2) BWROG Agenda and Presentation Materials l

(3) A Draf t Proposal for A New 3-Party Agreement cc:

B. D. Liaw W. T. Russell J. Partlow F. Miraglia R. Dyle, BWROG I

C. L. Tully, BWROG DISTRIBUTION:

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NRC & Local PDRs Docket or Central Files TMurley JWiggins JStrosnider CSerpan MMayfield CHinson OGC

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WKoo RHermann NRC Participants DE:EMCB* b(l/DE:EMCB DE:EMCB*

RHermann JStrosnider WKoo:wk

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Document file: G:\\K00\\BWR-MTG.WHK

• See previous concurrences.

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l J. WigginsSection XI, Appendix VIII.

The 3-party agreement and PDI both address these issues with respect to stainless steel piping.

The new coordination plan is being developed so utilities would not have to keep two separate qualifications.

BWROG provided the staff with a copy of l

the draft proposal of the agreement. The staff recommended that the integrated qualification program would be better served if managed j

by an independent third party organization.

Subsequent to the meeting, the staff performed a preliminary review of the proposed agreement.

The r

staff is not in favor of implementing such an agreement because the staff does not see the advantages or the need of.such an approach at this time.

During the meeting, the staff stated that, in view of the cracking being found in the penetrations for control rod drive mechanisms in PWRs, the potential exists for a similar problem in BWRs. The staff also shared with the owners group some overseas crack growth information.

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Jack R. Strosnider, Chief Materials and Chemical Engineering Branch i

Division of Engineering

Enclosures:

(1) A List of Meeting Attendees (2) BWROG Agenda and Presentation Materials (3) A Draft Proposal for A New 3-Party Agreement cc:

B. D. Liaw W. T. Russell J. Partlow

/

F. Miraglia

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R. Dyle, BWROG' C. L. Tully,/BWROG DISTRIBUTION:

NRC & Local PDRs Docket or Central Files TMurley

JWiggins, JStrosnider CSerpap' MMayffeld i

CHinson l

OGC' WKoo RHermann

'NRC Participants DE EMCB DE:EMCB DE:EMCB WK 69k RHermann JStrosnider o'r /3//93 8 Gi/93

/ /93 Document file: G:\\KOO\\BWR-MTG.WHK y,

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ENCLOSURE 1 f

I LIST OF ATTENDEES AT JUNE 30, 1993 MEETING WITH BWR OWNERS GROUP (BWROG) FOR AN UPDATE 0F MATERIALS RELATED ISSUES t

NAME POSITION / AFFILIATION TELEPHONE NO.

William H. Koo Sr. Materials Engineer (301)504-2706 NRC/NRR/DE/EMCB Allen Hiser Materials Engineer (301)492-3988 NRC/RES/DE/MEB James A Davis Materials Engineer (301)504-2713 NRC/NRR/DE/EMC8 James T. Wiggins Director-Degsignate/NRR/DE (301)504-2722 Robert Hermann Sect. Chief /NRR/DE/EMCB (301)504-2768 Martin Hum Materials Engr./NRR/DE/EMCB (301)504-2730 John T. Lindberg Proj. Engr./ Penna Power Light (717)S42-3875 Les England Chairman /BWROG/GSU (504)381-4145 Robin Dyle SNC/BWROG Matls's Issue Comm.

/ chairman (205)877-7121 Mark Richter Sr. NDE Engr./Balto. Gas & Elec.

/PDI (401)787-5510 Ken Huffman PDI Prog. Managr./EPRI (704)S47-6055 Marty Sime SNC/ Hatch Project (205)877-7473 Julien Abramovici GPU Nuclear (201)316-7058 Har Mehta GE (408)925-5029 Vijay M Nilekani PECO (215)640-6460 Theresa Meisenheimer Bechtel/Serch (301)417-8818 James J. Raleigh STS Inc.

(301)652-2500 Donald S. Brinkman Sr. Proj. Mngr./NRR/PDI-1 (301)504-1409 Michael Kirk Sr. Proj. Mgr.-NUMARC (202)872-1280 d

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d AGENDA MATERIALS ISSUES UPDATE MEETING JUNE 30,1993 INTRODUCTION L. ENGLAND /R. DYLE (BWROG)

B. HERMANN (NRC)

UPDATE ON INTERNALS M. HERRERA (GE)

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ACCESS HOLE COVERS SHROUD TOP GUIDE CRD STUB TUBES MISCELLANEOUS DYLE j

NUREG-0619 RPV WELD EXAMS

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NEW 3-PARTY AGREEMENT (BWROGINRC/PDl)

HYDROGEN WATER CHEMISTRY INSPECTION RELIEF g ggg PENDING SIL ON INSTRUMENT <~ gw wi6cG5 NOZZLE CRACKING POST-MAINTENANCE HYDRO TESTING ADDITIONAL ITEMS ALL l

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t IMPROVED WATER CHEMISTRY INSPECTION RELIEE i

o OBJECTIVE:

t ESTABLISH GL 88-01 INSPECTION FREQUENCY TAKING i

CREDIT FOR HWC BENEFITS o

BACKGROUND:

BWROG HAS SUBMITTED TOPICAL REPORT FOR NRC REVIEW NRC HAS ISSUED REQUEST FOR ADDITIONAL INFORMATION o

STATUS:

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BWROG RESPONSES TO NRC RFI HAVE BEEN DRAFTED AND ARE UNDERGOING FINAL REVIEW ONE PLANT HAS SUBMITTED REllEF REQUEST TO NRC FOR REVIEW o

ACTIONS:

BWROG TO SUBMIT RESPONSES TO RFI I

BWROG/NRC TO ESTABLISH REVIEW SCHEDULE 3

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NUREG-0619 FEEDWATER NOZZLE EXAMS o

OBJECTIVE:

DEVELOP FOR NRC REVIEW A GENERIC RELIEF REQUEST FROM THE FEEDWATER NOZZLE REQUIREMENTS OF NUREG-0619 l

o BACKGROUND:

GPC (HATCH) HAS SUBMITTED RELIEF REQUEST TO NRC RELIEF REQUEST WOULD ELIMINATE PT AND REDUCE CURRENT FREQUENCY OF UT RELIEF REQUF.u s BASES ON CAPABILITY OF UT TO

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I DETECT CRITICAL FLAW SIZE NRC REQUESTED THAT BWROG PREPARE GENERIC i

RELIEF REQUEST o

STATUS:

BWROG HAS ISSUED FUNDING REQUEST IN RESPONSE BWROG DECISION ON WHETHER TO UNDERTAKE THIS TASK WILL BE MADE BY JULY 2 o

ACTIONS:

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BWROG TO COMMUNICATE DECISION TO NRC BWROGINRC TO DEVELOP SCHEDULE FOR SUBMITTAL AND REVIEW f

RPV WELD EXAMS o

OBJECTIVE:

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T8" DEVELOP A MODEL INSPECTION PROGRAM FOR BWR RPV WELDS 1

o BACKGROUND:

NRC REQUIRES INSPECTIONS OF " ESSENTIALLY 100%"

OF VESSEL SHELL WELDS I

OTHER AREAS SUCH AS ATTACHMENT WELDS, MAY HAVE HIGHER PRIORITY FOR INSPECTION j

o STATUS:

BWROG CONSIDERING DEVELOPING A MODEL ALTERNATIVE INSPECTION PROGRAM BASED ON:

PRIORITY RANKING OF ALL BWR SEAM WELDS, ATTACHMENTS AND INTERNALS l

PROBABILITY AND CONSEQUENCE OF FAILURE SUSCEPTIBILITY TO FLAWS INHERENT SAFETY MARGINS INDUSTRY FAILURE EXPERIENCE o

ACTIONS:

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OBTAIN FEEDBACK FROM NRC ON WHETHER THEY WOULD CONSIDER REVIEWING THE BWROG MODEL PROGRAM i

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RPV WELD EXAMS o

PROPOSED MODEL ALTERNATIVE INSPECTION PROGRAM:

INSPECTION PRIORITY RANKING TECHNICAL BASES FOR INSPECTION SCOPE AND FREQUENCY GENERIC COST / BENEFIT ANALYSIS FOR CURRENT REQUIREMENTS VS. ALTERNATIVE PROGRAM SPREADSHEET FORMAT LISTING ALL BWR SEAM WELDS, ATTACHMENTS AND INTERNALS TO ADDRESS PRIORITY RANKING, EXAMINATION METHOD AND EXAMINATION FREQUENCY BWROG ll&R COMMITTEE RANKING OF INTERNALS lNSPECTION AND REPAIR PRIORITIES TO BE lNCORPORATED IN PROGRAM

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D NEW 3-PARTY AGREEMENT P

o OBJECTIVE:

INTEGRATE CURRENT 3-PARTY AGREEMENT (NRC/BWROGIEPRI) ON IGSCC WITH PDI e

o BACKGROUND:

GL 88-01 STAFF POSITION REQUIRES QUALIFICATION BY A PROGRAM SUCH AS THAT CONDUCTED AT EPRI 3-PARTY AGREEMENT AND PDI BOTH ADDRESS STAINLESS STEEL PIPING NEW COORDINATION PLAN BEING DEVELOPED SO UTILITIES WOULD NOT HAVE TO MAINTAIN TWO SEPARATE QUALIFICATIONS 1

o STATUS:

BWROG HAS APPROVED PROPOSED PDIINTEGRATION PLAN o

ACTIONS:

NRC TO CONSIDER NEED FOR EITHER NEW INTEGRATION PLAN OR GL 88-01 REVISION

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- Access hole cover

- Shroud

- Top guide

'I Future plans

BWROG COIAlAITTEE ACTIVITIES INTERNALS INSPECTION & REPAIR 0

PROACTIVE ANALYSES DOCUMENT GENERIC ANALYSIS METHODOLOGIES (AND BOUNDING ANALYSES WHERE POSSIBLE) FOR HIGH PRIORITY INTERNALS AND ATTACHMENTS:

CORE SPRAY INTERNAL PIPING CORE SPRAY T-BOX TOP GUIDE SHROUD SHROUD SUPPORT SHROUD SUPPORT ATTACHMENT CORE DELTA-P/SLC PENETRATION ACCESS HOLE COVER (DONE)

ANALYSES ARE STILL IN PROGRESS, WITH DRAFT RESULTS SCHEDULED FOR END OF YEAR

Proactive Analysis 1

Determination of allowable flaw sizes prior to inspection May provide justification for continued operation Allows for contingency (repair / replacement / analysis) option preparation Reduces likelihood that small indications disrupt or. extend outage

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Proactive Analysis Approach Critical flaw size Allowable flaw size Crack growth for one cycle or more Flaw acceptance for continued operation l

Methodology for Prediction of Allowable Flaw Size in Irradiated Stainless Steel BWR Internals Applied to highly irradiated stainless steel BWR internals Top guide Core shroud Essential Steps Load determination Finite element modelling Stress analysis Stress intensity factor distribution determination Fracture toughness properties Critical flaw size calculation Allowable flaw size calculation

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Core top guide and core shroud Selection of fracture toughness based on fluence Fracture toughness decreases with fluence Fracture toughness (KIC) decrease shows

" saturation" behavior at high fluences l

KIC of 50 Ksih bounds l

Data obtained from specimen irradiated up to 6 x 10*'n/cm 1

Top Guide Evaluation BWR/2 used as example Finite element modeling used to evaluate in-plane membrane and out-of-plane bending stress.

Limiting conditions evaluated - Limiting seismic Two Models used to estimate stress in beams.

Full model for in-plane stress Box model for out-of-plane bending stress 4

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Applied Loads Weight Pressure drop across top guide Fuel impact due to seismic event Fuel impact load Consider flexibility between fuel and top guide upper beams

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cracked plate e

Critical flaw size defined when applied K equals fracture toughness

• Allowable flaw size determined from critical flaw size and application of safety factor

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Weld residual stress considered in crack growth evaluation.

• Throughwall crack in shroud does not impair intended function.

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ALLOY 182 FIELD EXPERIENCE NOZZLE WELD INSPECTION RESULTS 110 %

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Access Hole Cover (AHC) IGSCC AHC IGSCC discovered at 14 plant of 33 plants inspected

- Through-thickness cracking observed at several plants in both thin and thick. covers

- Most plants experienced cracking following 8.5 to 12 on-line service years

. Cracking (circumferential and radial) has occurred in creviced Alloy 600 access hole cover, shroud support ledge and in Alloy 182 weld material No apparent coolant conductivity dependence Presence of Alloy 182 weld metal appears to dominate response m

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Fewer older plants were included in inspected population.

KSH 5/21/93

l Access Hole Cover Update - Alloy 182 Crack Growth Rate Recent overseas test data shows significantly higher growth rates for low conductivity water (0.1 pS/cm).

Maximum rates approximately 10-4 in/hr with significant data scatter 1.2 inches over 18 month cycle (12,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />) - well in excess of field observation Inconsistency with field suggests key differences between actual service and test.

Plant field experience and on-line CAV's data consistent with 2x10-5 in/hr growth rates 0.24 inch over 18 month cycles Crack growth rate of 2x10-5 in/hr continues to be reasonable for e

average crack growth determination

a Access Hole Cover Update - Alloy 182 Crack Growth Rate e

inconsistency of new data and field experience may be explained by:

Load controlled versus displacement controlled test specimens Key role of plasticity Crack branching at higher K values Possible added impurities in new data Weld residual stress governs crack growth in access hole cover e

weld regions Displacement controlled data more appropriate i

. _ _ = -, - - -,. - - -. - - - -. - - - - - - -. -

4

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Access Hole Cover Update Current GE SIL recommends:

Inspection for radial cracking at next outage if not yet done Inspect for circumferential cracks:

(i) once every three years, or (ii) every outage if on 2 year cycle.

Some revision expected to address:

+

non-creviced Alloy 182 welds

+

more recent crack growth data

+

consideration for extended operating cycles n

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Core ShroudSCCUpdate e First incident occurred in beltline weld region of a 304 SS shroud

- Foundin 1990 after-190 oryline months l

Initial indications discovered during in-vessel visual inspection

- Circumferentialindications on inside surface (~.2in. deep)

- One area of axialindications on outside surface Enhanced UTin 1992 sho wed cracks as deep as ~0.6 in.

- Circumferential crack increase seen Completed Metallography confirmed IASCC mechanism

- Fluence ~8x1020 nyt> threshold

+ Grainboundaryimpuritysegregation/distributiontypicalofIASCC

+ No apparent weldsensitization present Crack growth appears driven by oxide wedging stress

+

- IASCC now confirmed to apply to Type 304L shrouds i

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l Crack growth analysis performed 1

Continued operation approved and plant operating i

GENE SIL being revised to recommend inspection of both high l

e and low carbon stainless steel shrouds in oldest plants (after ~

190 on-line months)

Development of automated UT equipment planned by GE Program to better understand cause of cracking and generic implications still underway High toughness based on actual sample J-R Curve 1

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Core Top Guide SCC Update zirs: crac< incication observec visua y in1991 Two adcitional cracks found during IVVI in 992 Cracks (3/4 to 1-5/8 in. deep) initiatec in uncreviced, high neutron fluence regions at bottom of grid beams

- Crevices at beam intersections not examinec by UT 21 21 3reliminary fluence estimate is ~3.5x10 n/cm IASCC is most likely cause GE initial analysis showed adec uate structural marcin

- Sufficient margin still expected for next fuel dycle Boat sample rec uired to verify mechanism and precict actual li"e Proactive IVVl/UT inspection recommendec (SIL 554) i Verify margins and minimize potential reaair costs

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~11/2in. cracks

• High radiation at bottom of beams (IASCC) beam

(.18cmi

• Notches atbottom ofbeam M20492.23

SCC Test Results on Irradiated Annealed Type 304 Stainless Steel seserieretuscct%lascci Lewsdross dasseeld

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Top Guide SCC Update Discussions on-going concerning alternatives regarding cracked top guide.

Confirm crack mechanism Establish material properties Fracture toughness Yield strength, etc Confirm structural integrity

CRD J-Groove Weld Crack Recent observation of cracking in J-groove weld in overseas plant Some GE BWR's use Alloy 182 at this location.

Cracking in stub tubes occurred in two plants Cracking in furnace sensitized stainless steel stub tubes -

not weld Furnace sensitized stub tube unique to these plants, Visual inspections have been performed with no cracking seen.

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Future Plans Complete evaluation of remaining high priority internal components issue draft document by end of 1993 Evaluate Oyster Creek Top guide crack further

3.

DRAFTi t.

PROPOSAL FOR INTEGRATION OF THE NRC/EPRI/BWROG COORDINATION PLAN WITH THE APPENDIX VIII PERFORMANCE DEMONSTRATION INITIATIVE (PDI) PROGRAM

! Backgroun&

l The purpose of this plan (referred to as the "Integratio,n Plan") is to integrate the NRC/EPRI/BWROG Coordination Plan with the Appendix VIII Performance Demonstration Initiative (PDI) program. The PDI is a group of participating utilities responsible for implementing ASME Section XI, Appendix VIII. This plan allows BWR owner's ultrasonic testing personnel to simultaneously comply with the requirements of: NRC Generic I.etter 88-01: NUREG 0313; ASME Section XI, Appendix VIII; and generic provisions of 10 CFR 50 regulations. This plan replaces the NRC/EPRl/BWROG Coordination Plan.

In the implementation of this plan several underlying assumptions are made, including the following:

(

0 The BWROG, PDI, and EPRI recognizes NRC's regulatory responsibilities.

O NRC recognizes BWROG, PDI, and EPRI continuing efforts to improve the quality of ultrasonic (UT) examinations performed on BWR stainless steel piping systems. This should result in significant improvements in UT technology used in the detection and sizing of intergranular stress corrosion cracking in BWR stainless steel piping.

i 0 The principal benefit for integration of the " Coordination Plan" with the PDI program is to minimize potentially duplicative qualification requirements, while continuing to address the inspection needs for BWR stainless steel piping subject to IGSCC.

O Under the Integration Plan, all parties recognize that each BWR owner is responsible for compliance with: the training and qualification requirements of NRC Generic I2tter 88-01 and NUREG 0313; the UT personnel training and qualification requirements of ASME Section XI Appendix VII; and the performance demonstration requirements of ASME Section XI, Appendix VIII.

I O The owner fulfills the above responsibilities via implementation of the " written practice" required per ASME Section XI, IWA-2300. Alternately, the owner may review and adopt the written program of an inspection service organization.

0 This Integration Plan is applicable only to the qualification of personnel performing IGSCC flaw detection and sizing on BWR stainless steel piping systems.

D RAFT Integration Plan, Rev. Od Page 2 of 5 i

II. Integration Plan Responsibilities This section defines the responsibilities of the various parties to assure effective implementation of the Integration Plan.

A. Owners' responsibilities include:

1. Development of a " written practice" which addresses the qualification and training requirements from ASME Section XI, Appendices VII and VIII; NRC Generic Letter 88-01; and NUREG 0313. This " practice" shall detail the owner's plan for the qualification of UT personnel performing IGSCC flaw detection and sizing.

This plan should be comparable to the existing " Coordination Plan" requirements.

2. Implementation of the above written practice. If the written practice allows several training and qualification options, then each option must be clearly defined and implemented. Alternately, the owner may review and adopt the written program of an inspection service organization.

Note: The owner has the option to use training, qualification, and performance demonstration services from qualified sources other than the EPRI NDE Center.

(

B. The BWROG responsibilities include:

1. Overseeing Integration Plan activities through BWR owners' membership in PDI.

2. Interface with BWR owners and regulatory authorities on issues pertaining to BVG piping integrity and plant safety.

C. The PDI responsibilities include:

1. Providing a performance demonstration function for qualifying ultrasonic examination procedures, equipment and personnel. By an agreement between the PDI Steering Committee and EPR1, the PDI Program is administered by the EPRI NDE Center in Charlotte, N.C.

l

2. Controlling and overseeing the PDI Program.

3. By mutual agreement with the BWROG, provide performance demonstration functions specifically addressing the IGSCC inspection requirements for BWR owners and their inspection service organization.

I

DRAFT Integration Plan, Rev. Od Page 3 of 5 D. EPRI's responsibilities include:

1. By agreement with the PDI, the EPRI NDE Center will administer performance i

demonstration tests to candidate IGSCC UT inspectors / operators. These tests will be performed in accordance with Appendix VIII and PDI test protocol.

2. Providing ultrasonic inspection training and qualification programs at its NDE Center in Charlotte, NC. Specifically, these programs address UT Operator Training for the Detection of IGSCC; and UT Operator Training for Planar Flaw Sizing.

3. The EPRI NDE Center will administer the training programs for IGSCC flaw detection and sizing on a periodic or as-needed basis. The NDE Center will provide training literature, instructional lectures, facilities and test sample sets prerequisite to effective implementation of the program. Training materials will be made available to owners and their inspection service organizations to facilitate training in their respective facilities.

E. NRC's responsibilities include:

I

1. Review of selected activities and documents pertaining to the Integration Plan.

III. Elements of the Integration Plan This section details the program attributes and requirements for the Integration Plan.

i A. Owners Written Practice - The " owner's written practice' required per ASME Section XI, IWA-2300 shall also address specific traming and qualification requirements for IGSCC flaw detection and sizing.

1. Altemately, the written practice may allow the owner to review and adopt the written program of an inspection service organization.

2. The owner should develop the written practice requirements specific to the owner's IGSCC examination personnel needs. For exampic, the qualification and training requirements for an owner utilizing only in-house UT personnel may vary significantly from an owner using an inspection service organization.

i i

D RAFT Integration Plan, Rev. Od Page 4 of 5

3. The written practice should specify the requirements for qualification and training. Qualification should be based on any combination of the following elements:

a. Training / Retraining

b. Testing / Retesting

c. Documented continued satisfactory performance.

d. Appendix VII requalification.

e. UT procedure requalification.

B. Training

1. The owner or inspection service organization fulfill their training requirements by any of the following:

a. Completing the IGSCC training programs available through the EPRI NDE Center.

b. Completing "in-house" IGSCC training conducted to formal, documented training plans comparable to existing IGSCC qualification training.

c. Use of an NDE training service organization approved by the owner or inspection service organization. Such training shall be performed to formal,

(

documented training plans comparable to existing IGSCC qualification training.

C. Qualification / Performance Demonstrations

1. Qualification is ultimately achieved by satisfactori!y completing performance demonstration testing.

2. Qualification tests may be completed in conjunction with piping examination performance demonstrations OR as an individual IGSCC qualification.

3. The performance demonstration tests should be performed in conjunction with Appendix VIII qualification testing through the PDI program. EPRI NDE Center will administer the performance demonstration tests in accordance wititthe PDI test protocol.

4. Performance demonstrations may be conducted "in-house" or through the use of an outside agency / qualification service organization. This qualification method must be clearly specified in the written practice. It is recommended that the "PDI Qualification Guidelines for ASME Section XI Appendix VIII Performance Demonstrations" be used for guidance to establish such requirements.

I i

i

DRAFT Integration Plan, Rev. Od Page 5 of 5 D. Documentation

1. The owner's written practice will specify the requirements for training and qualification records.

2. As a minimum, the documentation shall include:

a. Qualification Records required per ASME Section XI, Article VII-5000.

b. Record of Qualification required per ASME Section XI, Article VIII-5000.

E. Implementation

1. This Coordination Plan will become effective six months after the last date of signature below, and will remain in force until the plan is terminated by any of the undersigned organizations upon thirty (30) days written notice to the other organization.

2. Changes or modifications in this Integration Plan as may be requested by any of the parties must be approved by the other parties.

t Prepared by:

s/b Date: /2/64

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/2.////1 L Approved by:

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b Date:

PDI Chairman

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Date: 3 N

BWROG Representative ~

y Date:

Electric Power Research Institute Date:

U.S. Nuclear Regulatory Commission

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