Text

Technical Evaluation Rept on Response from Sys Energy Resources,Inc to Generic Ltr 88-01 Re Grand Gulf Nuclear Plant
	ML20059N510
Person / Time
Site:	Grand Gulf
Issue date:	08/31/1990
From:	Bates R, Laknew A; VIKING SYSTEMS INTERNATIONAL
To:	; NRC
Shared Package
ML20059N494	List: ML20059N493; ML20059N497; ML20059N510;
References
	CON-NRC-03-87-028, CON-NRC-3-87-28 GL-88-01, GL-88-1, NUDOCS 9010160125
	Download: ML20059N510 (35)
	v • d • e

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ATTACHMENT 4

1 FINAL i

TECHNICAL EVALUATION' REPORT ON RESPONSE FROM SYSTEMS ENERGY RESOURCES, INC.

10 GENERIC LEITER 88-01 PERTAINING TO THE GRAND GULF NUCLEAR PLANT '

Published August, 1989 !

i prepared by l Robert C. Bates i Armand Lakner '

i Viking Systems International '

2070 W. Pitt Way Pittsburgh, PA '

Prepared for:

U.S. Nuclear Regulatory Commission d Washington, D. C. 20555 .

under ,

Contract No. NRC-03-87-028 Task Order 005 l

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ABSTRACT I

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'i This report contains an evaluation of the licensee (Systems Energy I Resources, Inc.) submittal for Grand Gulf Nuclear Station which was '

submitted in response to the NRC Generic Letter 88-01 in which SERI j was requested to (1) Furnish their current plans relating to piping ;

replacement and other measures to mitigate IGS00, inspection, repair, i and leakage detection. (2) Indicate whether they plan to follow the t NRC Staff positions, or propose alternative measures. SERI's plans are evaluated in Section 2 of this report in terms of compliance to NRC Staff positions. Section 3 contains an-evaluation of an alternative '

position concerning a change to the Technical Specification on ISI.

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l SMMARY f

The Licensee, Systems Energy Resources, Inc., submitted a response !

to the NRC Generic Letter 88-01. SERI's response pertaining to the '

austenitic stainless steel piping in the Grand Gulf Nuclear Station -

(a BWR nuclear power plant) was evaluated in terms of: (1) Their !

previous and planned actions to mitigate IGSCC to provide assurance :

of continued long-term service. (2) Their Inservice Inspection (ISI) t Program. (3) Their Technical Specification pertaining to ISI. (4) l Their plans to ensure that leakage detection will conform with the t NRC Staff position. (5) Their plans to notify the NRC of significar.t

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flaws identified (or changes in the condition of the welds previously j known to be cracked) during inspection and evaluation of such flaws, t

SERI stated that they endorse the 13 NRC Staff positions which are outlined in Generic Letter 88-01. However: (a) they applied provisions concerning inspection methods and personnel, (b) they presented a modified approach to crack characterization, (c) their requirements for leakage limits are not as restrictive as the NRC Staff position, and -(d) they proposed an alterrative position on requirements for operability of leakage monitoring instruments. s Most of the welds (117 of a total of 175) at Grand Gulf are IGSCC Category A welds since they eithec contain conforming materials or j

have been solution treated, internally clad, or both. Twenty-four welds were stress improved and are IGSCC Category B welds. Stress-j improvement is being considered for the remaining 34 unmittigated welds. :

1 All welds have been inspected at least once, and no flaws have been found. Plans for future inspections follow guidelines presented in l

Generic Letter 88-01 except for one weld. SERI declined to amend the '

Technical Specification on the IS1 to include a statement that they will conform with the NRC Staff position on inspection, schedules, inspection methods and personnel, and sample expansion. Rather, they ;

proposed to include such a statement in the ISI Program.

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CONTENTS ABSTRACT .......................... i l

SUMHARY .......................... 11

1. INTRODUCTION ....................... 1 !

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2. EVALUATION OF RESPONSE TO GENERIC LETTER 88-01 ..... 2 1

2.1 Documents Evaluated ................. 2 l 2.2 Rev.tew of SERI's Responses to Staff' Positions and Implementation of Those Positions ........ 3 '

2.3 SERI's Classification of Welds , Previous

Mitigating Actions, and Previous Inspections . . . . . - 6 .

2.3.1 Current IGSCC Classifications and Summary of Materials and Mitigating Treatments ..... 6 2.3.2 IGSCC Category A Welds, SHT, and CRC ...... 7

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2.3.3 IGSCC Category B Welds, IHSI Treatments .... 7 e

2.3.4 IGSCC Category C Welds ............. 8 2.3.5 Previous Inspection Programs .......... 9 ;

2.3.6 Evaluation and Recommendations ........ 11 [

2.4 Current Plans for Mitigating Actions ........ 11 2.4.1 Stress Improvement .............. Il f'

2.4.2 Evaluation of Conformance to Staff Positions and Recommendation ......... 12- ;

r 2.5 Plans for Future Inspections ............ 12 !

2.5.1 Summary of Inspection Schedules ...,.... 12 ;

2.5.2 Personnel and Methods ............. 13 iii i i

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2.5.3 Sample Expansion . . . . . . . . . . . . . . . 14 2.5.4 Evaluation and Recommendations . . . . . . . . . 14 I I

2.6 Changes in' the Technical Specification )

Concerning ISI ................... 15 "

i 2.7 Confirmation of Leak Detection in the Technical Specification . . . . . . . . . . . 15 2 1

2.7.1 Conformance with Position 0 of Regulatory Guide 1.45 . . . . . .. . . . . . 15 2.7.2 Plant Shutdown for Excessive Unidentified 14akage . . . . . . . . . . . . . 18 .

2.7.3 Frequency of Leakage Monitoring . . . ... . . . 19 2.7.4 Definition of Unidentified Leakage . . . . . . 19 2.7.5 Requirements for Operability of Monitoring Instruments . . . . . . . . . . . 20 t

2.7.6 Evaluation and Recommendations . . . . . . . . . 22 2.8 Plans for Notification of the NRC of Flaws . . . . . 23 2.8.1 SERI's Position ................ 23 2.8.2 Evaluation and Recommendations .. . .'. . . . . 24

3. ALTERNATIVE POSITIONS AND EXCEPTIONS .. . . . .. . . . . 25 3.1 SERI's Alternate Position Concerning ISI in the Technical Specification . . . . . . . . .. . 25 3.2 Evaluation nnd Recommendation . . . . . . . . . . . . 25 ' '

4. CONCLUSIONS AND RECOM4ENDATIONS .'............ 26 j

5. REFERENCES

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

sponsored by the BWR Owners Group for IGSCC Research, and the results ;

of this program, along with'other related work by vendors, consulting '!

I firms and confirmatory research sponsored by the NRC 'have permitted the development of NRC Staff positions r.egarding the IGSCC problems. l The technical basis for NRC Staff positions is detailed in Reference j 1, and further background is provided in Reference 2. ,

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The results of these research and development programs prompted the i

NRC to issue Generic Letter 88-01 (see Reference 3) requesting all licensees of BWR's and holders of construction permits to (1) Furnish their current plans relating to piping replacement, !

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 items:

(1) Current plans regarding pipe replacement and/or other measures 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 the next refueling outage for austenitic stainless steel piping.

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

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l in the section on ISI that the inservice inspection program for. piping will be in conformance with the staff positions on schedule, methods and personnel, and sample expansion. j l

(4) Confirmation of plans to ensure that the Technical Specification related to leakage detection will be in conformance with the Staff position on leak detection. !

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

of any flaws identified that do not meet IWB-3500 criteria f

of Section XI of:the ASME Code for continued operation without

, evaluation, or a change found in the condition of the welds-previously known to be cracked, and an evaluation of the flawe for continued used operation and/or repair plans.

This report contains a technical evaluation of the response which System . .

Energy Resources Inc. (hereafter called SERI) submitted in response to the NRC Generic Letter 88-01 pertaining to the Grand Gulf , Nuclear .

Station (hereafter called either Grand Gulf or GGNS).

2. EVALUATION OF RESPONSE *IO GENERIC LEITER 88-01 This evaluation consisted of a review of the response to NRC Generic Letter 88-01 of January 25, 1988 by SERI pertaining to Grand Gulf-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

r. vere included in the review.

2.1 Documents Evaluated 'i

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Review was conducted on the information pertaining'to Grand Gulf 1

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o provided by the Licensee in the following documents.

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(1) " Grand Gulf Nuclear Station, Unit 1, Docket No. 50-416, -

License No. NPF-29, (Response to) Generic Letter 88-01,"

AECM-88/0153, System Energy Resources, Inc., P.O. Box 23070, Jackson, Mississippi, 39225-3070, &17 M , 1;;7. WM 'Wj

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f (2) " Grand Gulf Nuclear Station Unit 1,_ Docket No. 50-416, License No, NPF-29, (Response to) Request for Additional l Information - Generic Letter 88-01: Position on IGSCC in '

BWR Austenitic Stainless Steel Piping," AECM-89/0130/0153, System Energy Resources, Inc., P.O. Box 23070, Jackson, '

Mississippi, 39225-3070, 4- :_ u.

U7/J jff / N Hereafter, in this report, these documents will be referred to '

as SERI Submittal Nos. I and No. 2, respectively, and collectively -

as the SERI Submittals.

2.2 Review of SERI's Responses to Staff Positions and Implementation of Those Positions.

Generic Letter 88-01 outlines 13 NRC Staff positions pertaining i j

to (1) materials, (2) processes, (3) water chemistry, (4) weld

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overlay, (5) partial replacement,.(6) stress improvement of cracked i

weldments, (7) clamping devices, (8) crack evaluation and repair criteria, (9) inspection methods and personnel, (10) inspection l schedules, (11) sample expansion, (12) leak detection' and_(13) 1

.j reporting requirements. SERI Submittal No. I states that the SERI !

response to Generic Letter 88-01 is based on their understanding and implementation of the thirteen NRC Staff positions pertaining to materials, In addition. Table 1 of SERI Submittal No. 2 contains a table stating their positions on each of these 13, positions. :

Table 1 of this report is based on that table, although'a change- 1 3 -

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i Table 1 Summary of SERI's Responses to Staff Positions i

SERI Accepts SERI HasN111 NRC Staff Applied Consider for l Staff Position Position In Past Future Use 1

1. Materials yes yes yes l

2. Processes yes yes(*) yes(*)

3. Water Chemistry yes , no yes

4. Weld Overlay yes no yes :

5. Partial Replacement yes no yes ,

6. Stress Improvement of Cracked Weldments '

yes no yes

7. Clamping Devices yes no yes j

8. Crack Evaluation and Repair Criteria yes no yes

9. Inspection Method and Personnel yes g) g .

yes. yes

10. Inspection Schedule yes yes yes(c)

11. Sample Expansion yes yes(c) l no.

12. Leak Detection yes(b) ,,, ,,,

13. Reporting Requirements yes no yes 5

(a) SERI has used SHT, IHSI, and CRC. Additional SI treatments are being considered.

(b) Provisions applied. See text for discussion.

(c) Most previous examinations complied with NUREG 0313. Revision

2. The current ISI program has been developed to comply with guidelines presented in Generic.88-01 on schedule, methods and' personnel, and sample expansion.. However, SERI proposed '

modification of ISI Program rather than to amend the Technical Specification to include statements of compliance with NRC Staff position on inspection.

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was made pertaining to their response on previous application of Hydrogen Water Chemistry (HWC) and a few explanatory footnotes have been added. The change and footnotes are based on information contained throughout the SERI Submittals.

Note that SERI endorses all 13 nic Staff positions (although they .

applied provisions which are discussed later in this report), and i they will consider future application of all of these items. Note e

also, that SERI indicated that theyihave already applied several-of these items (those pertaining to materials, processes, inspection f method and personnel, and inspection schedules). There has been no need to apply those pertaining to weld overlay, stress improvement of cracked weldments, clamping devices, crack evaluation ,

and repair criteria, sample expansion, and reporting requirements l because no IGSCC cracking has been detected at Grand Gulf.- :

Concerning HWC, the Table 1 of SERI Submittal No. 2 states that HWC has been applied in the past; however, elsewhere in t, hat document the following statement appears:

"GGNS accepts the staff position on Hvdrogen Water Chemistry as noted in Table 1 and agrees that the control of conductivity I will inhibit the initiation and growth of IGSCC. GGNS monitors

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the reactor water chemistry and controls water purity. There ,

are no plans to implement a Hydrogen Water Chemistry program at this time. Grand Gulf will continue to monitor industry standards with respect to water chemistry cad the potential benefits of implementing a Hydrogen water chemistry progrea."

"As stated in Generic Letter 88-01, a full set of criteria !

has not been developed for the general use of a Hydrogen Water Chemistry Program." i o

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2.3 SERI's Classification of Welds. Previous Mitigating Actions, and Previous Inspections The SERI Submittals both state that 268 welds are covered in the scope of NUREG 0313 Revision 2 and Generic Letter 88-01. However, this number includes longitudinal seam welds khich are outside of the scope of Generic Letter 88-01. When the longitudinal welds are excluded, there are a total of 175 welds at Grand Gulf that are within the scope of Generic Letter 88-01. These welds are contained in four piping systems as listed below.

1. Reactor Circulation system.

2. Reactor Recirculation to Reactor Vater Cleanup system connections.

3. Reactor Recirculation to Residual Heat Removal system connections, i

4. Reactor Presnure Vessel Nozzle connections to safe ends and safe end connections to safe end extensions / pressure l

seals. I Previous actions applied by SERI include application of solution j

heat treating (SHT), induction heating stress improvement (IHSI), i corrosion resistant cladding (CRC), and inspections. These. actions and the current classifications of welds are' discussed in the i following sections. '

I 2.3.1 Current IGSCC Classifications and Summarr of '

Materials and Mittaatina Treatments A table that identifies the welds in the IGSCC program at Grand Gulf is contained in SERI Submittal No. 2. It also 6

provides the following information for each of those welds:

the IGSCC category in which it is classified, materials, and mitigating treatments that have been applied. That table, which'11sts both-the welds within the scope of Generic Letter 88-01 and associated longitudinal seas welds, is not reproduced in this report, but the information (excluding the longitudinal welds)~is summarized in Table 2 of this report to show the number of welds of each IGSCC Category, the number.'of welds containing conforming material-(per guidelines presented in NUREG 0313 -Revision 2), and the number of welds that were treated with SHT, CRC, and/or IHSI, 2.3.2 IGSCC Category A Welds.-SHT and' CRC Most of the welds contain non-resistant material, either.

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in total or in pert. There are six exceptions, and these -

welds are classified as IGSCC Category A since'they contain conforming material (per guidelines provided by.NUREG 0313, Revision 2). Sixty-five welds are classifed as IGSCC A because they were solution heat treated.

.Another 46 welds are classified as IGSCC Category A because they were internally clad'with corrosion resistant cladding (eight of these:were solution heat treated after cladding). Some-of these welde join non-resistant materials to resistant-materials,'and CRC was app 11edito the non-n sistant side' L of the welds.

In all, there are 117 IGSCC Category A-welds.

2.3.3 IGSCC Category B Welds. IHSI Treatments Note, from Table 2, that twenty-four welds were treated with Induction Heating Stress Improvement (IHSI) in 1985. These welds were treated within two years of operation and no flaws were found during pre-treatment and post-treatment ;

inspections, so as:shown in Table 2, they are classified 7

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-Summary of IGSCC Classifications. Materials, and Mitigating Treatments at Grand Gulf No. with ' Number of Welds with IGSCC Number Conforming ,

Caten, of Welds Indicated Treatment Material SHT- CRC SHT+ CRC IHSI-A 117 6 65 38 8 0 B 24' 0 ,0 0 0 24 C 0 0 - -

D 34 0 'O O O O E ;

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175 6. 65 38 8 24.

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o as IGSCC Category B welds. The identities-of these welds, i

although not shown in Table 2, are contained in SERI Submittal No. 2 l D

2.3.4 IGSCC Catenory / Welds f

Twenty-seven nozzle to safe-end welds,:5 welds in safe-end-to safe-end-extensions, and 2 safe-endoto penetration seal welds contain Inconel 182 butter in the welds. To date, these welds have not received any mitigating treatments, .

and since this material is. considered'to be non-resistant I to IGSCC (per guidelines in Generic Letter 88-01 and NUREG 0313 Revision 2), these 34 nozzle welds are, classified as 1 i

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i IGSCC. Category D welds. <

i 2.3.5. Previous Inspection Programs Northern States Submittal No. 2 contains a list of the inspections' performed during a maintenance outage in October, 1985 and during Refueling Outage Nos. 1,.2, and 3 (09/86 - ,

12/86, 11/87-01/88, and 03/89-04/89, respectively). These examinations, -which 'were conducted per .NUREG 0313 Revision I 2, are summarized in Table 3 and'in the following paragraphs. .i LICSCC Category A welds: ' All 117 welds were inspected , t during the maintenance' outage and' Refueling Outage No. '

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1. In addition, 17-of these velds were re-examined during-Refueling Outage No. 3..

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-t IGSCC Category B welds: As previously indicated, the. .

24 IGS00 Category.B welds that.were treated with IHSI-i i vere given both~ pre-treatment and post-treatment i inspections. It is presumed"that these inspections were y

-performed during the maintenance outage, but the M:rth;;;. 15 bE/ ~ -

Semees Submittals do not actually say so. -At-any rate,: l

, all 24 IGSCC welds were. inspected during the maintenance outage. Eight'of these welds were re-examined during

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l Refueling Outage-No. '1: and again' during Refuelin8 Outage No. 2. An additional six IGSCC Category B welds were <

i re-examined during Refueling Outage No. 3.

IGSCC Category D welds: All'34 of these welds were 1

, c inspe'ted:durin8 Refueling Outage No. 1. One of'these '

l was re-examined during Refueling Outage No. 2 and again during Refueling Outage No. 3. Eighteen of the IGSCC Category D welds were re-examined during Refueling Outage-

'No.-3. '

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Table 3 ;

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Summary.of Inspection: Schedules for Grand Gulf. -

I No. Inspected / Scheduled y During Indicated R.O.

IGSCC No. in Past Future Required by-Caten. Caten. jg g g 03 g 0_5_ g O_7,08 g 10 Generic Letter 88-01 ,

A 117 48 69 0 17~ 0 16 0 'O 18 0 17 25%.every 10 years- (at -

least 12% in 6 years). !

0 10 -0 0 ' 3 ' 0 :7 50% every310 years (at

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B 24' 24 '8' 8 6 least 25% in 6 years)'

C 0 - - -

.- - .- - All within the next 2- '

refueling-cycles, then all every 10 years (at' '

least 50%_in 6 years)

D- 34 0 34 1 19 16 34 0 33 0'33 0 A11'every 2 refueling- !

cycles E O - .- : -- --

- - - 50% nexti refueling cycle, then all every 4 2 refueling cycles F 0 -

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A11'every refueling !

-outage G 0 - - -- - - - - -- -

All'next refueling tv cycle Notes: M0 indicates maintainance outage, r

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Dates for Refueling Outages are'(NA indicates not available):

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R.O.(- Date R.O.#i Date R.O.# Date H0 10/85 04 10/90 08 08/97 01 09/86-12/86 05 03/92 09 02/98 1 02 11/87-01/88 06 09/93 10- NA 03 03/89-04/89 07 '

03/95 10 1

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-2.3.6 Evaluation and Recommendations. 1

,4 Of the 175 welds at Grand Gulf that are within the scope ;

of Generic Letter 88-01, 117 are IGSCC Category A welds since they are either composed of conforming materials, solution hea'.

t treated, or internally clad (CRC).

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g, An additional 24 welds have been treated with IHSI.= Since the compositions / mitigating treatments of these welds! conform with guidelines provided in Generic Letter 88-01, it is !

recommended that the IGSCC classifications'should be, accepted. l Ihe. remaining 34 welds are contained in nozzle assemblies ;

and contain non-resistant materials.- Since these' velds have' ,

been inspected, they are correctly classified as IGSCC ,

Category D welds..

e 2.4 Current Plans-for Hitimating Actions.

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SERI does not plan either additional piping replacement or.the implementation of hydrogen water treatment. However, stress improvement is being considered for the 34 IGSCC Category D welds as discussed below.

2.4.1 Stress Improvement l'

The locations and geometrical configurations of-:all'34 IGSCC Category D welds at Grand Gulf have: beenL evaluated;and found to be acceptable for stress improvement treatments,'and SERI is currently assessing the plant outage schedules for possible implementation of such treatments. The SERI'Submittals state that any future actions to-implement: stress. improvement L for the IGSCC Category welds will "be'in compliance. wich Generic Letter 88-01 or other NRC approved programs.

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,2,4.2 Evaluation of Conformance-to Staff Positions l and Recommendation ,

1 Acceptance of SERI's plan.for future mitigating actions at- l Grand Gulf is recommended for,the following reasons: (1) l Extensive mitigating actions,'which follow the guidelines of Generic Letter 88-01, have already been applied with the ,

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. result'that a11'except 34 welds (all contained in nozzle 1 assemblies)Lare classified as'either IGSCC Category A or IGSCC Category B.- (2) Additional' stress improvement !

treatments are under consideration-for the'34 unmitigated

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(IGSCC Category D) welds. (3)-As' discussed in the Section ]

2.3.5 and Section 2.5,,an inspection program'that conforms- I with Generic Letter 88-01'(with the exception of planned inspections for one. weld) hasib een institut'ed and will be ,i continued. . l l

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2.5 Plans for Future Inspections ~

2.5.1' Summary of Inspection Schedules -

J The current Inservice Inspection Program,(ISI Program) for Grand: Gulf is in compliance with previous commitments,made- !

to NUREG 0313, Revision'1 and Generic Letter 84-11. SERI-Submittal No. 1 states that the ISI Program for Grand Gulf will be modified to incorporate the requirements'of Generic !

Letter 88-01 prior to the next refueling' outage'(scheduled for early 1989). SERI. Submittal No. 2 contains a similar F statement. In addition Table 3 of:that SERI S'ubmittal No.

2 contains future inspection schedules-(as' currently planned). q on a weld-by-weld basis-(along with the previous inspection schedules discussed-in Section'2.3.'5) for Grand Gulf. 'Ihose schedules extend through 1998_(Refueling Outages Nos. 4 4

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through 10). Of course, these schedules!are subject to change as explained in the following statement,. quoted from SERI '

Submittal No. 2.

"The schedules for future examination provided in Table I 3 are subject to change to facilitate actions such as. 1 SI or outage schedules and durations. Any changes wills !

be in compliance with the NRC staff positions as discussed. 1 by this submittal." I i

A summary of the' inspection' schedules is contained in Table 3 of this report. In this summary, the number of welds of I each of the various IGSCC categories that are scheduled for inspection during Refueling Outages 4 ~ through110. (1990 through-1998) are' compared with inspection-requirements.. delineated in Generic Letter.88-01. As previously discussed-(Section 2.3.5) this table also summarizes past' inspection schedules, b

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Note-that the planned inspections comply with the NR'C Staff position on inspection schedules (requirements presented '

in Generic Letter 88-01) with the exception of Lone..IGSCC

' Category D weld (Weld No. XN9-B, a safe;end to penetration seal weld). This weld ~is-. scheduled for inspection;during L Refueling Outages Nos. 4 and 5, but it is not-.' scheduled for inspection during any'of the subsequent inspections' scheduled- '

.through 1998. The reason (s) for this was'not provided. i

! 2.5.2 Personnel and Methods The SERI Submittals state that the detailed inspection '

procedure, equipment, and personnel for Grand Gulf utilize the NRC/EPRI/BWROG Coordination Plan. Procedures for detection and sizing of IGSCC.are reviewed-against the EPRI-module to ensure that the necessary parameters are included.

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5 In addition,_the EPRI-Performance Documentation Summary (PDS):

is used to' verify'that examinations are being conducted in -

r the same. manner coincident with the parameters:used in the practical portion of personnel qualification.-

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The current EPRI training'and qualification programs utilize -

weld samples that'contain:IGSCC;_ however, no suchi samples "

are available:for welds with CRC (corrosion resistant ,

cladding)'or with Inconel butter such as contained in some of the welds at Grand Gulf.: l Additional training is being-.

.provided to personne1'for1 inspection of such welds,;and it' is believed that this training will be sufficient to provide

. viable _ inspections of<the, welds at Grand Gulf that contain~

CRC or buttered-layers.

2.5.3 Sample Expansion i

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Both-SERI Submittals. state that sample expansion aq Grand Gulf will comply with the NRC Staff position as_ detailed

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in Generic Letter 88-01, f4 i

2.5.4 Evaluation and Recommendations ,

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'SERI's position concerning in'spections follow the NRC Staff position _on schedules, methods and personnel, and~ sample l expansion as delineated in Generic Letter 88-01 and NUREG '

0313, Revision 2 with two exceptions: (1) They applied 2 provisions to their endorsement'of.the NRC Staff position onmethodsandpersonnelwhihh'areactuallyacceptable l additions which will. permit-the inspections;of welds with i

CRD or-buttered 11ayers. (2).One IGSCC Category D' weld, which i should be scheduled'for; inspection every .second refueling U outage, is not scheduled:duringLRefueling Outages Nos. 6 i through 10. Thus, acceptance of SERI's position on inspection a

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. Table 4 .

Licensee Positions on Leakage Detection Already TS will be- Alternate Contained . Changed _ Position i Position in TS to Include Proposed-

1. Conforms with Position C_of yes(*) - -

Regulatory Guide l.45 l 9

2. Plant shutdown should be initiated when: .

(a) within any period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months yes(*) - -

or less, an increase is-

-indicated in the rate of ,

unidentified leakage in--

excess of 2 gpm, or-i (b) the-total unidentified, leakage yes(*) - --

attains a rate of 5 gpm.

3. Leakage monitored at! four hour yes(*) -

intervals or less. $

4. Unidentified leakage includes all' ~ yes(a) ,

except:

(a) leakage into closed-systems. .t:

or -

(b) leakage into the containment- yes(*) - :-

atmosphere from sources that .

t are located, do not= interfere . :

with monitoring systems, or not from throughwall crack'.

i

5. Provisions for shutdown within 24 - - yes(a) hours due to inoperable measurement-l instruments in plants with' Category D, E, F,'or G welds.- '

l 1

i l

(a) See text for comments.

G 16 1

. ~ . ;

1 1

1

l' is recommended except.for Weld No IN9-B. That weld should J either be scheduled for: mitigating treatment or inspected every second refueling. outage as recommended'by Generic Letter: I 88-01 for-IGSOC Category weld. ,

1 2.6_ChanRes in the Technical Specification' Concerninn ISI SERI proposed an alternative positi6n to the NRC Staff position '

,concerning a change to the Technical Specification. This 4 alternative position is; discussed.in Section 3 of this report. "!

l O

2.7 Confirmation of Leak Detection-in the Technical Specification d 4

Table'4 in this report, which was constructed from a similar table-in SERI Submittal No. 2, summarizes the.SERI positions on leakage detectiva. Notes pertaining to that table and comments lfrom SERI~ !

Submittal No. I concerning leakage detection are contained in the following sections. An alternative position-isl proposed for one.

aspect of the NRC Staff position (i.e., that" pertaining to operability of monitoring instruments). Normally.. discussion of

.this item would be contained in Section<3 of this-report,> '

" Alternative. Positions and Exceptions," but SERI indicated that their positions on the other aspects of-leakage detection are in conformance with the NRC Staff positions. Thus, discussions ofl 4 1

all of SERI!s positions on leakage detection is contained in this 1 I

section.rather than Section 3. l

)

1 2.7.1 Conformance with Position C of Regulatory Guide 1.45 o 1

l Note,'from Table 4, that SERI stated that the Technical.

(

Spe~cifications on leakage detection is in conformance with 4

15 1

1 1

+

m __ _ , _. __

.w ,

't i Regulatory Guide 1.45,'with-the following explanatory notes:

"The GGNS leakage detection systems conform with Position C of Regniatory Guide 1.45, except for regulatory

. positions'la, 6 and 7. Position la requires that flow rates of identified leak ~ sources be monitored separately. i from unidentified sources. Part of position 6 requires that:the leakage detection ~ systems.be qualified for seismic events which do not require plant shutdown. The exceptions:to these two positions.have been accepted 4 by the NRC and are noted in UFSAR Appendix' g, 3 4 ,. ;

~'Conformance!with Regulatory Guides'."

"The exception to position 7, which requires that '

indicators and alarms for each leakage detection system: y be provided in the main control room, is that-the GGNS drywell equipment drain sump level indication ~is located.

.in the. Auxiliary Building instead of the Main Control Room. A'10CFR50.59' Safety Evaluation ~hasLbeen performed for this exception and a change to the GGNS UFSAR has I[

r been submitted to the NRC in the FSAR update."'

SERI Submittal No. I contains similar comments which are-t quoted below, i

, 'lThe- GGNS leakage detection syste.is for Grand Gulf: are l- in conformance with Position C of ?egulatory Guide 1.45, with the exception-of Regulatory Positions la,j6, and-

7. The exceptions to Positions la and 6 have been accepted by the NRC and are noted in UFSAR' Appendix 3A,

'Conformance with NRC Regulatory Guides' (page 3A/1.45-1). The exception'to Regulatory Position 7 is that the drywell equipment drain sump level indication is located' -i in the Auxiliary building. A 10CFR50.59l safety evaluation; i

. 17 a

s l

. .' '. 4 i l

-)

has been performed for this exception to Position 7, and a change to the Grand Gulf UFSAR that'will reflect !

[ this exception is~ being submitted to the NRC in the current update."

-l 2.7.2 Plant SNdown~ for Excessive Unidentiified Leakane Generic Letter 88-01 ' states the following i

" Plant shutdown should be initiated for inspection and- i corrective action when, within any period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or less, any leakage detection system indicates an; increase in rate of unidentified leakage in excess;of i

, 2 gpm or Its equivalent, or when the total unidentified-leakage attains a rate of.5 spe or' equivalent, whichever-occurs first."'- -

In addressing this requirement, SERI Submittal No. 2 states that the Technical Specificat:fon for Grand Gulf contains these requirements;'however'the~ specific wording in the Technical Specification is provided in SERI Submittal-No.

2 as follows: .

1, "GGNS Technical Specification 3.4.3.2. requires the plant to identify the leakage. source ~within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be'in hot shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and cold shutdown witliin the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with a' reactor coolant system '

unidentified leakage increase greater than 2 gpm within i

any 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months period. This Technical Specification also, states that with greater than.5 gpm unidentified leakage, '

the leakage rate is to be reduced to within the-limit I within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in at least hot shutdown within' the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and cold shutdown within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ."

l 18 l

1 . _ _ . . .. - -

.et '

.t.;

j Note that the Grand Gulf Technical Specification which requirea' shutdown when the increase in unidentified leakage i exceeds 2 gpm or when the total leakage exceeds 5 gpa over a four hour ~ period (rather than a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period) is:lest,.

q restrictive than the-requirements outlined in Generic Letter 88-01.

2.7.3 Frecuency of Leakage Monitorihn' i

. Generic Letter 88-01-states the following: '

"For sump level monitoring systems with F

fixed-measurement-interval methods,' the level should

. be monitored at approximately.'4-hour intervalsL or:less." .i 1

In addressing this requirement,;SERI Submittal No. I states-that the Technical Specification ~ for Grand Gulf: requires 4

the following:

" Sump monitoring systems and level are monitored at least once per-4 hours."

2.7.4 Definition of Unidentified Leakane Generic Letter 88-01 states the following

-i

" Unidentified ' leakage should' include all--leakage other than: (a) leakage into closed systems, such as pump seal or valve packing leaks that are captured, flow metered, and conducted to a sump or collection tank, or (b) leakage into the containment atmosphere from: sources that are both specifically located and known either not to I

interfere with-the operations of unidentified leakage 19 ~l 1

'l -

t . . . .. - . . - . - - - - .

. 3. : .-

1 1

monitoring systems-or not.to be from a throughwall crack in the piping within the. reactor coolant pressure; boundary."

g In. addressing this requirement, SERI Submittal No..l' states that the Technical Specification requires the'following:- -.

l "GGNS considers identified leakage as (REF: GGNS Technical .

Specification 1.18): (a) I,eakage into collec' tion systems,.

such as pump seal or valve packing leaks, that'.is captured ,

I and conducted to a. sump or collecting tank, or (b) leakage ~ ,

i

, into.the drywell atmosphere from sources that'are both ?

specifically located and known either not to interfere-with the operation of the-leakage detection systems or

~

not to'be pressure boundary 1hakage."

" Unidentified leakage is.all leakage.which is not-identified leakage. Valve packing leaks are mo,nitored by equipment drain sump level rather th'an ihdividually

~

flow metered. This.is considered byjSERI asian acceptable method for identifying valve packing. leakage as~not'being a breach of the reactor coolant pressure b5undary.'.'

,.. y 2.7.5 Reauirements-for Operability of Monitorina Instruments

-1 Generic Letter 88-01 states the following "For plants operating with any IGSCC Category D, E, F, i

or G welds, at least one of:the leakage measurement-4

' instruments-associated with each sunp shall be operable, and the outage time for inoperable instruments shall be limited to.24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or immediately initiate an orderly 1

. shutdown" 1 i 20

i 1

In addressing this requirement, SERI-Submittal'No.'l states:.

1 "GGNS Technical Specifi, cation.3.4.3.1 requires that three systems capable of detecting leakage in the drywell be operable (drywell atmosphere particulate radioactivity, drywell and equipment drain' sump level and flow, drywell air coolers condensate flow rate or drywell atmosphere-gaseous radioactivity)._ These systems have sufficient-diversity in detecting reactor coolant pressure boundary- J 1eakage. With one of the three systems of TS 3.4.3.1' inoperable operation may continue for 30 days. With two of the three systems of TS 3.4.3.1 inoperable GGNS ;

must be in hot shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and cold shutdown '

within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ." i SERI's position is that a 30 day inoperable allowance for . <

the drywell and equipment drain sump level and flow monitoring-l 1s acceptable. Justification for_this position is, based on the capabilities of the monitoring equipment as described above and the following additional reasons: (1):A pressure above the normally indicated values will indicate the presence of-a leak within the drywell.- (2) A drywell ambient- '

. temperature rise will indicate the presence of reactor coolant >

or steam leakage. A temperature rise in the drywell'is l~ detected ~by monitoring the drywell temperature at various elevations, inlet and outlet air to the coolers and by the j drywell. chilled water temperature increase'between inlet I and outlet to the coolers. (3)' Detection of small. leaks-has been shown to provide an early warning to prevent gross reactor coolant pressure boundary-failure: small-leaks.(5 gpa_or less) are detected by temperature and pressure changes, ,

drain pump activities and increased air borne radioactivity in the drywell . (4) Experimental evidence has shown that-l-

for unidentified leakage somewhat greater than 5;gpm, the 21 s

~ 4 r ,,s , - - - - w --

7.o b 'o j

. j probability is small that. the crack or imperfection would .j

. grow rapidly. (5) Grand Gulf has only,a~small number of.

IGSCC Category D welds and no welds'of Categories E, F, or l G.

2.7.6 Evaluation and Recommendations j 1

Since the NRC has already ' acceptied SERI's- exception pertaining' f j to Regulatory Positions..la and 6 of the Regulatory Guide,s r 0 continued acceptance of that position 1is recommended. SERI's' '

j exception pertaining to Regulatory, Position 7 refers to a- -!

'10CFR50.59 safety evaluation which was recently performed and a change of the GGNS UFSAR which was recently proposed j to the NRC. Tentative acceptance.of.this item.is recommended .q pendingthereviewofthatsubmissionlby.theNRCStaff. .*

Concerning leakage limits, the Grand Gulf Technical Specification requires shutdown;when the increase in unidentified leakage ~ exceeds 2.gpm or when the total leakage 1

- exceeds .5 gpm over a four hour period '(rather than a '24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months '

period as required- by Generic. IAtter ,88-01). Thus, the SERI' position is less restrictive than the.NRC Staff position,.

so (1) rejection of the SERI position on' leakage limits'is

[

recommended, and (2) the 4-hour time period in'the Grand l Gulf Technical Specification should be changed to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months j l

as stated in Generic Letter.88-01. 1 NRC Inspection Report No. 50-416/87-19 also containsia' 2 discussion of requirements for shutdown for. inoperable leakage.

measurement instruments in which it is noted that wording of.the Grand Gulf Technical Specification would permit continued operation of Lthe plarit for 30 days with an inoperable sump leakage detection system.- The licensee had previously issued a memo requesting that their training 22 e6* ns . s e , , - ,w, - ~ r , .-

}l _

emphasize,that upon loss of sump monitoring capability they- ]

should go to hot shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In. addition, '

SERI issued a Technical Specification Position Statement that the continued operation for 30' days should' apply only )

to loss of particulate or gaseous radioactivity monitoring I and not for sump monitoring. It is' recommended that further I action should be taken to change'in the Technical- 1 Specification to comply with the NRC Staff position pertaining to inoperable sump monitoring, instruments'as delineated;in [

Generic Letter 88-01. < ~

[

2.8 Plans for Notification'of the NRC of Flaws 2.8.1 SERI's-Position SERI Submittal No. 1 states the following:

l i i

i "GGNS accepts the staff position on reporting of cracked J weldments. In the event GGNS:1dentifies IGSCC flaws

'{

exceeding the acceptance criteria of IWB-3500, the NRC '

shallbenotifiedasrequired:bfGenericLetter88-01.

If continued operation-is permissible' based on evaluations l- performed in accordance with IWB-3640 or repairs'made .

l .in accordance with IWA-4130, NRC. approval will.be obtained .i

. prior to resumption of operation."

}l i

In addition, SERI Submittal:No.o1 states that flawedipipe and weld overlay repair. design will be' performed in accordance fi 1

with the criteria' presented in NUREG 0313, Revision 2 with js

.the following additions ~and clarifications as given below: , !

l

1. " Representative butt weld residual stress distributions given in industry literature will be-23 t

l i.

r 1, .

i l

used for pipe diameters < 12" diameter." '

l J

2. " Crack tip stress intensity will be determined as:

l Ky=Kyg + KIR: '

I I. ;

where KIA is K due to applied loads ~and.KIR is K ;

due.to residual stress."

3. "A fatigue crack growth correlation representative j!

of actual plant conditions will be used for the '

[ prediction of fatigue crack. growth."

4

4. " Predicted IGSCC and fatigue crack growth depths will be combined per the methodology in ASME (1986!

Edition), Section,XI, Appendix C."

Similar' descriptions are provided in SERI. Submittal,No. 2.

2.8.2 Evaluation and Recommendations SERI's position on reporting of flaws is in conformance with t the NRC Staff guidelines.as delineated in' Generic Letter

, 88-01; thus, acceptance of.that position is recommended.

Concerning flaw. evaluation, the proposed expression for K 1 y -j to account for residual stress is an acceptable practice. l Use of an expression for-fatigue crack growth that-is' -!

representative of actual plant conditions 1s also an acceptable practice, but the specific expression that'SERI v proposes to use was not disclosed so it cannot be evaluated.

Thus, rejection of SERI's position on the expression for

. -l fatigue crack growth is recommended. Acceptance of other l l

aspects of SERI's position on flaw evaluation is recommended. .

since it complies with the NRC~ Staff position. '1 24 I

1

.1 . i 1 e

.g'

3. ALTERNATIVE POSITIONS AND EXCEPTIONS

~

3.1._SERI's Alternate Position Concernina'ISI~ !

in the Technical Specification SERI's position'is not to modify the_ Technical Specification to' specifically delineate conformance.concerning inservice inspection

.(ISI). . Instead, SERI-proposed-to revise the ISI Program for Gulf 1 States to incorporate the commitments.to inservice inspections.- i

.The reasons for this position are~ quoted below from the'SERI f

Submittal.:

i

" Improvements in Technical Specifications by placing some._

actions in' administratively controlled programs-is a goal at GGNS (Grand Gulf) In keeping with'this effort, SERI considers- '

the appropriate location for commitments:regarding conformance .

to staff positions on: schedule, methods and; personnel, Land i L sample expansion.to be the.ISI program'for GGNS. Thg ISI program is a formal program that'is reviewed by theLNRC and -

currently ~ controls other commitments that. augment'ASME Section XI Inservice Examinations." '

1 3.2 Evaluation and Recommendation- '

~

Generic Letter 88-01 states that 'the NRC Staff recognized that-the Inservice Inspection and Testing sections may be removed from the Technical- Specifications -in the future in ~11ne with the Technical Specifications Improvement programs. and that in tthe event of that occurrence,.the requirement shalliremain in the ISI section when it is included in an alternative document.

l Nevertheless, the NRC-Staff, at this time, specifically, rejected-the approach to include a statement of compliance with the inspection requirements in the ISI program and: adopted the [t requirement - that such a statement should be included in the -

. 25 e

I i l

0-1 i

Technical Specifications on ISI. Thus', rejection of SERI's-position I is recommended, and it is further recommended that SERI should amend'the Grand Gulf Technical Specification on ISI in accordance i with directions provided in_ Generic Letter 88-01.;

4 L

1 i

L -

L .4. C9NCLUSIONS AND RECOMMENDATIONS '

L

-SERI. stated that they endorse all 13 ofithe NRC Staff. positions"

-pertaining to materials, processes,. water chemistry, weld overlay,

partial replacement, stress improvement of cracked weldments,' clamping devices, crack evaluation and repair criteria, inspection: methods and personnel, inspection schedule, sample expansion,-leak detection,"and I reporting requirements as outlined.in Generic Letter 88-01. .However, they applied provisions to the NRC Staff position concerning-inspection y

methodsandpersonnel,andtheyprojosedan'alternativepositionto a portion of the NRC Staff position on leakage detection.

t.

Most of the welds within the scope of Generic _Lettsr 88-01 (117 outs of a total;of 175) at Grand Gulf are IGSCC Category A< welds. . Thesci

-. welds are so classified because they. either contain conforming !

materials, have been solution treated,-.have been internally clad with corrosion resistant' cladding, or have been solution, treated following.

internal cladding. In addition,'24 welds were stress improved.using. -

L the-induction heating stress improvement process within two ye'rs.of a L

commercial-operation. These 24 welds ~are classified as IGSCC Category '

B.

Additional stress improvement treatments are being considered for the remaining 34 welds which are contained in nozzle assemblies, contain non-resistant material, and are classified as IGSCC Category'D.

All welds within the scope of Generic Letter 88-01 have been inspected at least once.

No flaws have been detected. Plans for future inspection schedules conform with the NRC Staff positions except for i one IGSCC Category D-welds which is scheduled for inspection during e -

26 -

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+ . _ . - - , . - - . .- , , . .n.. ,.w

. a..

. f. .;

o.

1

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each of the next two refueling outages and not' scheduled during the -l l five subsequent refueling' outages. It should be inspected every second; l

refueling outage.. SERI's position on inspection' methods and personnel.

I~

.]

include supplemental provisions to facilitate inspection of internally l clad and buttered welds. .Otherwise they will; follow guidelines previded )

in Generic. Letter 88-01. Plans for. sample expansion and reporting- ';f of flaws are patterned after the NRC Staff position.

.j i

SERI's plans concerning flaw cheracterization follow the NRC Staff position with the following provisionsi(1) 'Ihey intend.to incorporate' ,

a favorable stress: distribution 11n SI-treated welds in calculating- a, stress intensity. (2) They intend-to use aniempression for) fatigue crack growth that is. representative of actual' plant conditions, but -

they.did not disclose the' expression'or the-approach to be-used in i

determining that expression. The first of these is. acceptable engineering practice, but the second of these'cannot-be evaluated since .

the expression for fatigue crack growth was 'not given..

i SERI declined to change the Technical ~ Specification on ISI to include a statement that the inservice inspection program'for. piping will be in conformance with the NRC Staff positions onfachedule, methods and personnel. Rather, they proposed an alternative position that such a statement would be incorporated into the; Inservice Inspection Program.

Such an alternative approach.was:specifically considered and rejected L by the NRC Staff in the development ofLthe position: stated-in Generic Letter-88-01.

-l Currently, the Technical Specification'for Grand Gulf pertaining to leakage detection complies with Position C ~of- Regulatory Guide 1.45, with the exception of Regulatory Provisions la, 6,~and 7. They have previously obtained NRC approval for the exceptions to Regulatory Provisions la and 6. In presenting justification for their exception

'to Regulatory Provision 7, SERI referred to a'10CFR50.59 safety- q evaluation and a proposed change in the Grand' Gulf'UFS 'R which has 1

27 t !

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, c ., _ . u. , ,

' I

.q

<l .

been submitted to the'NRC. "I The Grand Gulf, Technical Specification is currentlyLin conformance-with guidelines presented in Generic Letter 88-01 for frequency of )

leakage monitoring and t.he definition of unidentified leakage; however, .

their limits on an-increase of unidentified llenkage and on total:

unidentified leakage are based on a ~ 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months period'rather than a 24' hour l period'as required by_. Generic.;;Thus,?their-leakage limits are ,

less restrictive than that; specified by' the' WRC Staff. .

t

, .t F

SERI declined to change their.TechnicaliSpecification(to the NRC Staff !

' position'concerning-plant shut down for inoperable sump leakage 1 -

monitoring. Atthe'presenttimethelTechnical-Specificadion. permits operationLfor up to 30-days,_although plant training' emphasizes lthat' '

j plant _ shut.down'should occur _within'12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months _ m .

As a result of this technical evaluation, the following recotonendationsL i

, are-made.

4 I-

.o (1)AcceptanceofSERI'sclassification'of<weldsintolthe-various

.IGSCC Categories. In:. addition,-' acceptance'of'SERI's plans ;

l'or. mitigating IGSCC is recommended 'since. past actions and: ;,

planned actions conform with the guidelines providsd'in Generic m

Letter 88-01.

(2) Acceptance of SERI's position concerning inspecti6n. plans: i including schedules, methods and personnel,jsample\ expansion' is recommended except for' inspections' planned!forione IGSCC '

1 Category D, weld'(Weld'No. XN9-B).~ :The inspection: schedule-j i

l for this weld should follow guidelines provided in Generic' p

l.' Letter 88-01 similar to'the' schedules' planed for the other.

-IGSCC Category D welds at Grand Gulf. 4 l

(3)' Rejection of SERI's position concerning the undisclosed -

l l

]

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l

.. , .- . .-, . .v. ..

, , : t; ' '

, jw. a i

.d

/W ;;

expression for fatigue crack growth to be.used for flaw. [

! characterization. SERI should'either utilize the expression b

recommended in Generic' Letter 88-01'or inform the NRC Staff of the specific expression to he'used and receive NRC Staff I approval.-

1

+

i 4 '

E (4) Rejection of SERI's position concerning an amendement'to the' Technical Specification on ISI. SERI should amend the Grand '

Gulf Technical Specification on'ISI to include a statement l

'that.the ISI program'will conform with the NRC Staff position onschedule,methodsand-personnel 1andsampleexpansionlas delineated in Generic Letter 88-01. . , , ;

i (5) Tentative acceptance.of the: portion of SERI's position on leaktige requirements concerning' conformance with Reguintory j Guide 1.45, pending NRC Staff review'of the SERI submittal. . l described in.Section 2.7.1 of;this report.

_.- 1 (6) Acceptance of the following poitions~of'SERI's position on'-

-leakage requirements: -(a), Frequency of 1Ankage measurements. -

(b)Their. definition (descripcion)Lof'unidentifled' add identified' leakage.

15 41 (7)' Rejection of SERI's position concerning requirements.An' tho- , )

l Technical' Specification for limits .on' an increase'in ths ' 5 unidentified leakage and the total unidentified'leENnge. iSERI:

u should change the Grand' Gulf Technical: Specification to require ;

plant shutdown when, within any period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or less (rather than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months as presently! stated in the Grand Gulf-Technical Specification), any leakage detection system indicates

'an increase in rate.of unideatified leakage in excess'of 2- -)

gpm or its equivalent, or when the total unidentifiedileakage l

[

4 attains a rate of 5 8Pm or equivalent, whichever occurs first.

_ q

i. 29 l

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.y ; . *'

5 :: , . ',

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ln a fJ 1mQfD c yx t r e' ,

if N (/lcle.f6! @9 ' ! M' '

.;1 g;g 4

.r; ' % :D i *

-j I 2 '

y

'.(8) Rejection of SERI's gonitionlon operability lof leakage 4 monitoring instruments.. .SERI.should' amend the Crand Gulf-

~

Technical Specification to req'uire operability of leakage instruments as stated in Item 3,{page 6'of Generic Letter 88 '. ,

!01, 9:' ,

4

~

(9) Acceptance of: the: remaining port 19 ns of the SERI Submittal. - +

\.

u .. ,

.5. REFERENCES- ,

i c

l

1. '"Techni:a1 report on Naterial Selection and Processing Guidelines 4 for BWR Coolant Pressure . Boundary Piping," NUREG 0313,. Revision 2, U.S. Nuclear Regulatory Commission,,0ffice'of-NuclearfReactor.-

Regulation, January,'1988.

9 12.

. " Investigation and Evaluntion of Stress-Corrosion Cracking;in' Piping

'of Light' Water' Reactor Plants,";NUREG 0531,lU.'S. Nuclear Regulatory 1

' Commission, February, 1979. ,

3. .

"NRC Position on~ IGSCC in BWR -Austenitic: Stainless Steel Piping,"

Generic Letter 88-01, U.S.,Nucicar Regulatory Commission ; January- '

25,-1988.

'i t (I l

h-1 l <C j

'I ll ,

s lI

[

t!j r; ,

30 ;

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

m. . J. l '

o ENCLOSURE ~2~ 4

.y , >

, o g ,

MODEL BWR_ TECHNICAL SPECIFICATIONS

, ' REACTOR. COOLANT SYSTEM-OPERATIONAL LEAKAGE t

. LIMITING CONDITION FOR OPERATION

~

U: 4 3.4.3.2 ' Reactor coolant' system leakage shall be limited to:

a.- No PRESSURE BOUNDARY LEAKAGE. i

b. S 9pm' UNIDENTIFIED LEAKAGE.

i

c. : 25 gpm total leakage averaged over any _24-hour period. 1 1

1

d. ~ 1--gpm leakage from any reactor coolant' system pressure isolation q valve:specif.ied in Table 3.4.3.2-1. ;

(e. 2 gpm increase'in UNIDENTIFIED LEAKAGE within anyl24-hour period.).

' APPLICABILITY: OPERATIONAL CONDITIONS 1;'2 and 3. '

! ACTION:

L 8

.a. With any PRESSURE BOUNDARY. LEAKAGE, be in' at least'. HOT.. SHUTDOWN L !

within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ~ and in COLD SHUTDOWN:within' the next' 24' hours. i

b. With any reactor coolant systemleakage greater than the limits in b and/or c, above reduce the leakage rate to within the limits !

within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or,be in at?least: HOT SHUTDOWN WITHIN THE NEXT; 12 ,

hours and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . 1

c. .

With any reactor coolant system pressure': isolation valve leakage greater than_the.above/ limit, isolate'the high pressure portion of the.affected system from theflow pressure portion within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least two closed manuel or deactivated ,

automatic valves, or be in at least _ HOT SHUTDOWN'within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within~the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

H m ,

d. With any reactor coolant system leakage greater than the limit in i

. e above, identity the source of leakage within 4'huurssor be in at '

letst' HOT SHUTDOWN within-the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and'in COLO; SHUTDOWN within the following 24. hours.)

SURVEILLANCE REQUIREMENTS u

-4.4.3.2.1 The reactor coolant -system leakage shall be demonstrated to be within each of the above limits by:- '

a. Monitoring the primary cont'ainment. atmospheric particulate (and/or gaseou ) radioactivity at least once per (4 or 12 as applicable to tant) hours, l- b. Monitoring.the prinary containment sump flow rate at least once l per eight (8) hours, 1,

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q. REACTOR C0OLANT SYSTEM-

_ SURVEILLANCE REQUIREMENT 5L(Continued)

L c. . Monitoring ~ the primary containment air coolers condensate' flow-

~

.j rate at <1 east once per (4 or.12 as applicable to plant) hours, and I a

d. Monitoring the reactor vessel head flange leak. detection system- I

, at least once.per 24;hoursk 4.4.3.2.2 Each reactor coolant system pressure -isolation valve specified '

in Table 3.4.3.2-1:shall be demonstrated OPERABLE pursuant lto Specification 4.0.5, except'that. in'11eu ofr any-leakage testing required by Specification 4.0.5, Leach valve. shall,be-' demonstrated OPERABLE by verifying leakage to be '

L within~its' limit:

-a. .At least once per'18 months.-

b.. Prior;to entering HOT SNUTDOWN whenever the, plant has been_in COLD SHUTDOWN for: 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or. more and iflieskagei testing has not ,

.been performed in theLprevious 9 months. o ,

c. Prior,to returning the valve to' service following maintenance, repair or replacement work on'the valve. ;7

d. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following valve actuationLdue to automatic or l manual action or flow-through the valve.'

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