ML20067D326

Responds to NRC 821101 Request for Addl Info Re Util 811001 Response to Generic Ltr 81-04 Concerning Revision 1 to NUREG-0313.Responses to Items 4,5d & 6d Will Be Submitted No Later than 821215

ML20067D326
Person / Time
Site:	Peach Bottom
Issue date:	12/03/1982
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20067D329	List: ML20067D326 ML20070E193 ML20070E196 ML20070E212
References
RTR-NUREG-0313, RTR-NUREG-313 GL-81-04, GL-81-4, TAC-46671, NUDOCS 8212130211
Download: ML20067D326 (13)

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4 PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A PA.19101 SHIE.LOS L DALTROFF mLtcfm c Pn o citoN December 3, 1982 Docket Nos. 50-277 50-278 Mr. John F. Stolz, Chief Operating Reactors Branch 54 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Stolz:

On October 1, 1981, in a letter to Mr. D. G. Eisenhut, we submitted our response to Generic Letter 81-04. In your letter to Mr. E. G. Bauer, Jr., dated November 1, 1982, after review of our submittal, you requested additional information.

Because of the short time allowed to respond to your requests, we are unable at this time to respond to item 4 and part of items 5d and 6d. However, we will send our response to item 4 and the remainder of items 5d and 6d to you no later than December 15, 1982. Item 2d requests a General Electric Report which is proprietary in nature. This report will be sent under separate cover letter as soon as we receive necessary documentation from General Electric.

Thin letter will restate each of your requests and provide the additional information to all the remaining items.

Request:

1. Nonconforming Nonservice Sensitive Piping Recirculation System Risers and RHR Shutdown Cooling Return Lines (IV.B.2.b of NUREG-0313 Rev. 1) .

8212130211 821203 DR ADOCK 05000277 PDR

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Mr. John F. Stolz, Chief Page 2 In the S. L. Daltroff letter to D. G. Eisenhut dated October 1, 1981, a revised program for mitigating IGSCC dated September 24, 1981 was attached. This program mentioned nonconforming service sensitive welds in the recirculation system risers and the RHR Shutdown Cooling 3eturn Lines. It was inferred by EGEG Idaho personnel that not all the welds in these systems with a Stress Rule Index (SRI) greater than 1.2 would be inspected per NUREG-0313 Rev. 1.

la. What proportion of the total welds in both systems with SRI >l.2 will be inspected at each successive scheduled outage under the proposed program plan?

Response

la. Unit No. 2 All of the following are welds that are nonconforming service sensitive with SRI numbers that are greater or equal to 1.2.

Main Recirculation (RISERS)

Loop A - 3 out of 15 Loop B - 3 out of 15 Total - 6 out of 30 = 20% of welds will be inspected each successive scheduled outage RHR (IN)

Loop A - 3 out of 3 Loop B - 3 out of 3 Total - 6 out of 6 = 100% of welds will be inspected each successive scheduled outage Total (RECIRC & RHR) = 12 out of 36 = 33.3%

Unit No. 3 Same as Unit No. 2 Request:

lb. What proportion of the total welds in both systems will be inspected at each successive scheduled outage under the proposed program plan?

Mr. Jchn F. Stolz, Chiof PcgD 3

Response

lb. Unit No. 2 Main Recirculation (RISERS)

Loop A - 3 out of 19 Loop B - 3 out of 19 Total - 6 out of 38 = 15.79% of welds will be inspected each successive scheduled outage RHR (IN)

Loop A - 3 out of 5 Loop B - 3 out of 5 Total - 6 out of 10 = 60% of welds will be inspected each successive scheduled outage Total (RECIRC & RHR) = 12 out of 48 = 25%

Unit No. 3 Same of Unit No. 2 Request:

2. Induction Heating Stress Improvements (IHSI) for Inhibiting Growth of IGSCC.

In the S. L. Daltroff letter to D. G. Eisenhut dated October 1, 1981, IHSI was mentioned as a means of inhibiting growth of IGSCC (V of NUREG-0313, Rev. 1) .

2a. Please provide a copy of the process specifications for the IHSI technique to be used on Peach Bottom 2&3 nonconforming piping.

Response

2a. We expect to authorize General Electric Company to begin preparation of specifications for IHSI treatment approximately December 15, 1982. These specifications will be forwarded to the NRC after they are reviewed and approved by Philadelphia Electric Company.

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.' Mr. John F. Stolz, Chiof Pcg3 4 Request:

2b. Please provide data and literature proving the efficacy of the particular IHSI technique to be used on Peach Bottom 2 & 3.

Response

2b. Data and literature for proving the efficacy of the IHSI technique to be used at Peach Bottom is contained in the following reports:

1. General Electric Report No. NEDE-25394, Class III, July, 1981, titled " Induction Heating Stress Improvement for Stainless Steel Piping." (See Response 2d.)

2. EPRI Report No. NP-81-4-LD, Project Til3-5, Research Report, March, 1981 titled " Residual Stress Improvement by Means of Induction Heating." This report is attached.

3. EPRI Report No. NP-2527-LD, Project Til3-1, Final Report, August, 1982 titled " Induction Heating Stress Improvement, Implementation Planning, and Field Procedure Development."

This report is attached.

Request:

I 2c. Please provide a schedule of application of IHSI to Peach Bottom 2&3.

Response

2c. IH5I treatment is planned to be performed on welds in the nonisolatable portions of the Recirculation suction piping (Loops A and B) and the RHR shutdown cooling suction piping up to the first motor operated isolation valve in each line during the 1983 Unit 3 refueling outage. A decision on the scope of IHSI treatment of Unit 2 welds will be made at a later date.

Mr. John F. Stolz, Chief Page 5 Request:

2d. Please provide a copy of the General Electric Topical Report alluded to in the Daltroff-to-Eisenhut letter.

Response

2d. The General Electric Report, NEDE-25394, Induction Heating Stress Improvement for Stainless Steel Piping is proprietary in nature and will be provided to you under separate cover letter as soon as we receive necessary documentation from General Electric. We expect to be able to send this material no later than December 15, 1982.

Request:

3. Augmented Inservice Inspection (ISI) of Nonconforming Pipe Welds.

In the attachment to the S. L. Daltroff letter to D. G.

Eisenhut dated October 1, 1981, the augmented ISI program for nonconforming service sensitive pipe welds with a Stress Rule Index (SRI) equal to or greater than 1.2 was mentioned. Welds with SRI >1.2 would be examined during three consecutive refuel outages, then once every other scheduled refueling outage, then once every 80 months. Credit would "be taken for examination performed to date."

For the pipe welds for which the above description is valid, provide the schedule of examinations to date (IV.B.2.b of NUREG-0313, Rev. 1) .

)

Mr. John F. Stolz, Chief Page 6 Response 3 UNIT 2 Interval (Year Inspected) 18 Month 36 Month 80 Month Reactor Recirc 2-AHJ-2 '80 '82 0 0 0 0 0 Loop A 2-AHJ-3 '80 '82 0 0 0 0 0 2-AHJ-4 '82 0 0 0 0 0 0 Reactor Recirc 2-BHA-2 '80 '82 0 0 0 0 0 Loop B 2-BHA-3 '82 0 0 0 0 0 0 2-BHA-4 '82 0 0 0 0 0 0 RHR Shutdown 10-0-1 '76 '78 '80 '82 0 0 0 Cooling Suction 10-0-2 '76 '78 '80 '82 0 0 0 10-0-4 '76 '78 '80 '82 0 0 0 10-0-6 '76 '78 '80 '82 0 0 0 10-0-7 '76 '78 '80 '82 0 0 0 RHR Shutdown 10-IA-8 '78 '80 '82 0 0 0 0 Cooling Return 10-IA-9 '78 '80 '82 0 0 0 0 Loop A 10-IA-ll '76 '78 '80 '82 0 0 0 RHR Shutdown 10-IB-8 '75 '82 0 -- -- - -

Cooling Return 10-ID-9 '77 '82 0 -- -- - -

Loop B 10-ID-ll '82 0 0 -- -- - -

UNIT 3 Reactor 2-AHJ-2 '81 '83 0 0 0 0 0 Recirc 2-AHJ-3 '83 0 0 0 0 0 0 Loop A 2-AHJ-4 '75 '83 0 0 0 0 0 Reactor 2-BHA-2 '82 '83 0 0 0 0 0 Recirc 2-BHA-3 '81 '83 0 0 0 0 0 Loop B 2-BHA-4 '81 '83 0 0 0 0 0 10-0-1 '78 '79 '81 0 0 0 0 10-0-2 '78 '79 '81 0 0 0 0 RHR Shutdown 10-0-4 0 0 0 0 0 0 0 Cooling Suction 10-0-6 '77 '79 '81 0 0 0 0 10-0-7 '77 '79 '81 0 0 0 0 RHR Shutdown 10-IB-8 '78 '79 '81 0 0 0 0 Cooling Return 10-IB-9 '77 '79 '81 0 0 0 0 Loop B 10-IB-11 '77 '79 '81 0 0 0 0 RHR Shutdown 10-IA-8 '79 '83 0 -- -- - -

Cooling Return 10-IA-9 '83 0 0 -- -- - -

Loop A 10-IA-ll '77 '83 0 -- -- - -

-- Indicates No inspection required 0 Indicates to be inspected during future outages

Mr. John F. Stolz, Chief Page 7 Request:

4. Unidentified Leakage Monitoring (IV.B.1 of NUREG-0313, Rev.

1) .

4a. Identify the methods to detect and monitor unidentified leakage in the pressure boundary piping of your BWR.

Some of these methods are enumerated in Regulatory Guide 1.45, Paragraph B.

Response

4a. To be answered under separate cover letter not later than December 15, 1982.

Request:

4b. Please fill out the attached table of information regarding the systems identified in the above paragraph.

Response

4b. Same as response 4a, above.

Request:

5. Augmented ISI of Nonconforming Service Sensitive Pipe Sa. Please identify the methods for augmented ISI of the nonconforming service sensitive pipe (IV.B.3 of NUREG-0313 Rev. 1) .

Response

Sa. Article 5 of Section V (T-535. lb) of the ASME boiler pressure vessel code, requires a beam angle in the range of 40 degrees to 75 degrees inclusive with respect to the perpendicular to the entry surface. In the past, PECo has performed two beam angle inspections, one at 45 degrees and another at 60 degrees.

Request:

Sb. Provide a copy of the specifications for the augmented ISI method of methods (IV.B.3 of NUREG-0313 Rev. 1) .

Response

Sb. Attached, find a copy of Southwest Research Institute Procedure No. SWRI-NDT-600-3 for the Manual Ultrasonic Examination of Pressure Piping Welds. This procedure is used for the examination of all subject welds.

--. . -_ = . ._ .

Mr. John F. Stolz, Chief Page 8 l l

Request:

Sc. Identify each of the augmented ISI methods used and the training and certification levels the individuals using those methods received. (IV.B.3 of NUREG-0313 Rev. 1) .

Indicate if cracked specimens are used in your training.

Response

Sc. The augmented ISI methods are as noted in Response Sa above. The training & certification levels of individuals performing augmented ISI methods are as follows:

Level I: Qualified to perform certain set-ups, calibration, tests and record data according to written instructions. Level I shall implement written NDT instructions under the guidance of a certified NDT Level II or III, but never individually evaluate or accept results of an NDT examination.

Level II: Qualified to set up and calibrate equipment and to interpret and evaluate results with respect to applicable codes, standards, and specifications. He shall be able to report NDT investigations.

Level III: Qualified to evaluate examination results in terms of codes, standards and specifications.

Training & Experience Levels Training (Hours)

Level I Level II With 2 years completion of Engineering, or Science study at a university, college, or

technical school 24 40 i

High School Grad / Equivalent 40 40 1

Work Time Experience (Months)

All education levels listed above 3 months 9 months i Level III: Certified in accordance with Paragraph 6.3.1 of l ASNT-TC-1A (1975)

Cracked specimens are employed by PECo, and by its vendor contractor Southwest Research Institute in training of NDT personnel.

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Mr. John F. Stolz, Chief Pcg3 9 Request:

5d. Identify the proportion of the nonconforming service sensitive pipe that is being inspected (IV.B.2.b of NUREG-0313 Rev. 1).

Response

5d. The portion of the nonconforming service. sensitive piping mentioned in paragraph IV B.2.b. (1) of NUREG-0313, Rev. 1 has been modified and requires no further investigation. The modifications-included the removal and capping of the recirculation bypass piping, and the replacement of 304 stainless steel core spray piping with that of conforming material (316 L stainless steel).

As mentioned in the opening paragraph of this letter, the remainder of this response will be forwarded at a later date.

Request:

5e. Identify the inspection interval of each system of the partially nonconforming service sensitive pipe (IV .B . 2. b of NUREG-0313 Rev. 1) .

Response

Se. Our piping has been designated as either' conforming and non-conforming service sensitive, whose inspection program / interval is as noted in our October 1, 1981 response. We have not classified any welds as partially non-conforming.

Request:

Sf. Identify the Stress Rule Index Numbers for the welded joints in the partially nonconforming service sensitive pipe (IV.B.l.b (6) of NUREG-0313 Rev. 1) .

Response

Sf. As noted in Response Sc above, we have classified our welds as conforming and non-conforming service sensitive. The SRI values using threshold of 1.2 (greater, equal to, or less than) are noted at top of our tables. Again, we have not classified any welds as partially non-conforming.

6. Augmented ISI of Nonconforming Nonservice Sensitive Piping.

Request:

6a. Please identify the methods of augmented ISI of the piping (IV.B.3 of NUREG-0313 Rev. 1) .

Response

6a. We use the same methods as described in Response 5a above.

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Mr. John F. Stolz, Chief Page 10 Request:

6b. Please provide a copy of the specifications for the e

augmented ISI method or methods (IV.B.3 of NUREG-0313 Rev. 1) .

Response

6b. We use the same procedure as attached and referenced in Response 5b above.

Request:

i 6c. Identify each of.the augmented ISI methods used and the training and certification levels the individuals using those methods received. Indicate if cracked specimens are used in your training (IV.B.3 of NUREG-0313 Rev. 1) .

Response

6c. We use the same methods, training and certification levels as described in Response Sc.

Request:

6d. Identify the proportion of the piping that is being inspected (IV.B.2.b of NUREG-0313 Rev. 1) .

Response

6d. See Response 5d above.

Request:

4 6e. Identify the Stress Rule Index Numbers for the welded j joints in the piping (IV.B . l . b ( 6 ) of NUREG-0313 Rev. 1) .

! Response:

6e. Non Conforming, Nonservice Sensitive Welds (SRI Greater or Equal to 1.2)

Units 2 & 3 i

i Weld SRI Value i

Reactor Recirculation Loop A 2-AS-2 1.279 2-AS-3 1.659 2-AS-4 1.619 2-AS-7 1.427 2-AS-10 1.40 2-AS-ll 1.379 2-AD-14 1.284 2-AD-15 1.301 2-AD-18 1.623 Loop B 2-BS-3 1.326 2-BS-4 1.307 2-BS-6 1.260 2-BS-9 1.258 2-BS-10 1.262

s Mr. John F. Stolz, Chief Page 11 Weld SRI Value RHR Shutdown Cooling Suction 10-0-10 1.891 10-0-15 1.706 RHR Shutdown Cooling Return 10-IA-4 1.790 Loop A 10-IA-5 1.225 10-IA-6 1.227 RHR Shutdown Cooling Return 10-IB-4 1.790 Loop B 10-IB-5 1.225 10-IB-6 1.227 Request:

6f. Identify the proposed inspection interval for each system of piping (IV.B.l.b of NUREG-0313 Rev. 1) .

Response

6f. Non Conforming, Nonservice Sensitive Welds (SRI greater or equal to 1.2)

Unit 2 Weld Interval 80 Month Interval (Year Inspected)

Reactor Recirculation Loop A 2-AS-2 '80 2-AS-3 0 2-AS-4 '80 2-AS-7 0 2-AS-10 0 2-AS-ll 0 2-AD-14 0 2-AD-15 0 2-AD-18 0 Loop B 2-BS-3 0 2-BS-4 0 2-BS-6 '75 2-BS-9 0 2-BS-10 0 RHR Shutdown Cooling Suction 10-0-10 0 10-0-15 '77

H Mr. John F. Stolz, Chief Page 12 RHR Shutdown Cooling Return 10-IA-4 0 Loop A 10-IA-5 0 10-IA-6 0 Cooling Return 10-IB-4 '75 Loop B 10-IB-5 0 10-IB-6 0 Unit 3 Reactor Recirculation Loop A 2-AS-2 '83 2-AS-3 '83 2-AS-4 '83 2-AS-7 '75 2-AS-10 '83 2-AS-ll '83 2-AD-14 0 2-AD-15 '75 2-AD-18 0 Loop B 2-BS-3 '83 2-BS-4 '83 2-BS-6 '83 2-BS-9 '83 2-BS-10 '83 RHR Shutdown Cooling Suction 10-0-10 '83 10-0-15 '83 RHR Shutdown Cooling Return 10-IA-4 '83 Loop A 10-IA-5 '83 10-IA-6 '83 Cooling Return 10-IB-4 '83 Loop B 10-IB-5 '83 10-IB-6 '83 (Note: 0-Indicates to be inspected during future outages.)

Request:

7. Coolant Leakage (IV .B . l .b (2) of NUREG-0313 Rev. 1) NUREG-0313 Rev. 1 requires that:

Plant shutdown should be initiated for inspection and corrective action when any leakage detection system indicates, within a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less, an increase

T Mr. John F. Stolz, Chief Page 13 in rate of unidentified leakage in excess of 2 gallons per minute or its equivalent, or when the total unidentified leakage attains a rate of 5 gallons per minute or its equivalent, whichever occurs first. For sump level monitoring systems with fixed-measurement interval method, the level should be monitored at 4-hour intervals or less.

Please provide technical justification for not including this in your Technical Specifications. This justification should include data or operating experience.

Response

7. The licensee has been meeting or exceeding the intent of Section IV.B.l.b (2) of NUREG-0313 Rev. 1. Peach Bottom Technical Specification 3.6.C together with Peach Bottom surveillance tests already meet the intent of all of the above requirements. Some of these requirements were imposed by DRO Bulletin 74-10B dated January 24, 1975.

The licensee plans to incorporate a revision to the Technical Specification that reflects the model Technical Specification identified above, to the extent applicable to the Peach Bottom design. The revision will be submitted in the next technical specification amendment application initiated, excluding reload amendments and those of an emergency nature.

Should you have any questions, or require additional information, please do not hesitate to contact us.

Very truly yours,

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Attachments (

cc: R. A. Blough, Site Inspector EG&G Idaho, Inc.

P. O. Box 1625 Idaho Falls, Idaho 83415 l Attn: Mr. Wayne Roberts

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