ML20090K290

Final Technical Evaluation Rept on Response from Cleveland Electric Illuminating Co to Generic Ltr 88-01 Pertaining to Perry Nuclear Power Plant

ML20090K290
Person / Time
Site:	Perry
Issue date:	08/31/1989
From:	Bates R VIKING SYSTEMS INTERNATIONAL
To:	NRC
Shared Package
ML20090B498	List: ML20090K290
References
CON-NRC-03-87-028, CON-NRC-3-87-28 GL-88-01, GL-88-1, NUDOCS 8909150234
Download: ML20090K290 (38)

Text

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ATTACHi:ENT j.

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FINAL i

e i TECHNICAL EVALUATION REPORT ON-RESPONSE FROM CLEVELAND ELECTRIC ILLUMINATING COMPANY --

TO GENERIC LETTER 88-01 PERTAINING 'IO THE PERRY NUCLEAR POWER PLANT l

l Published August, 1989 i

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prepared by Robert C. Bates Armand Lakner

.. Viking Systems International.

2070 Wm. Pitt Way '-

j Pittsburgh, PA Prepared for:

U.S. Nuclear Regulatory Commission-Washington, D._C. 20555 ggg g 1

under Contract No. HRC-03-87-028 Task Order 005 '

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c ABSTRACT This report contains an evaluation of the licensee (Cleveland Electric Illrainating Company) submittal for the Perry Nuclear Power Plant which was submitte d in response to the NRC Generic Letter 88-41 in which Cleveland Electric was requested tos (1) Furnish their current plans relating to piping repiscenent and other saeasures to mitigate IGSCC, inspection, repair, and leakage detection. -(2) Indicate whether they plan to follow the NRC Staff positions, or propose alternative measures.

Cleveland Electric's plans are evaluated in Section 2-of.this report in teras of compliance to NRC Staff positions. Section 3 contains an evaluation of an alternative position concerning a change to the Technical Specification on ISI and concerning exceptions tc the NRC Staff position on leakage detection.

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SUMMARY

The Licensee, Cleveland Electric Illuminating Company, submitted a response to the NRC Generic Letter 88-01. Cleveland Electric's response pertaining to the austenitic stainicas steel piping in the Perry Nuclear Power Plant (a BVR 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) Program.

(3) Their Technical Specifications pertaining to ISI and their plans to ensure that leakage detection will be in conformance with the NRC Staff position. (4) Their plans to notify the NRC of significant flaws identified (or changes in the condition of the welds previously known to be cracked) during inspection.

Cleveland Electric endorse: twelve (two with provisions) of the 13

' NRC Staff positions which are outlined in Generic Letter 88-01. They proposed alternative positions to portions of the NRC Staff pcettions on leakage detection.

Most welds at Perry are IGSCC Category A as a result of design and construction practices that followed NRC Staff guidelines; however, welds in nozzle assemblies contain Inconel alloys and are considered nonresistant to IGSCC. SI treatments are being considered for these welds.

The ISI program proposed for Perry conforms with the NRC Staff position except for two provisions. Many welds have special geometrical contours due to corrosion resistant cladding. For these welds, they propose to supplement the recommended inspection procedures with special procedures developed for the CRC contours. The second provision applies to IGSCC Category D velds. They plan to inspect all of these welds every second outage rather than 50% each refueling outage. Also concerning ISI, Cleveland Electric presented an alternative position to the NRC Staff position requesting a change to the TS on ISI.

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CONTENTS ABSTRACT i-

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SUMMARY

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1. INTRODUCTION 1 2.

EVALUATION OF RESPONSE TO GENERIC 11T1t.K 88-01 2 2.1 Documents Evaluated 3 2.2 Review of Cleveland Electric Illuminating Co.'s 3 Responses to Staff Positions and Implementation of Those P itions 2.3 Review of Classification of Welds, Previous Mitigating 6 Actions, and Previous Inspections 2.3.1 Scope of Oeneric letter 88 01 6

2.3.2 Materials in Piping Systems 6 2.3.3 Materials in Nozzle to Safe.End Welds 8 2.3.4 Summary of IGSCC Classifications, Materials, 9 and Mitigating Treatments 2.3.5 Previous Inspection Programs 9 2.3.6 Evaluation of Previous Mitigating Actions 11 and Inspections and Reccamendations 2.4 C.orrent Plans for Mitigating Actions 13 2.4.1 Summary of Plans 13 2.4.2. Stress Improvement 13 2.4.3 Evaluation of Conformance to Staff Positions and 13 Recommendation 2.5 Plans for Future Inspections 14-2.5.1 Summary of Inspection Schedule 14 2.5.2 Inaccessible Welds 16 2.5.3 Methods and Personnel 16

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2.5.4 Sample Expansion 17 l 2.5.5 Evaluation and Recommendation 17 2.6 Changes in the Technical Specification Concerning ISI 18 2.7 Confirmation of Leak Detection in the Technical Specification 18 2.8 Plans for Notification of the NRC of Flaws 20 2.8.1 Cleveland Electric's Position 20 2.8.2 Evaluation and Recommendation 20

3. ALTERNATIVE POSITIONS AND EXCEPTIONS 20 3.1 Alternative Position Concerning ISI in the Technical Specification 20 3.1.1 NRC Staff Position 20 3.1.2 Cleseland Electric's Position 21 3.1.3 Evaluation and Recommendation 21 3.2 Leakage Detection in the Technical Specification 22 3.2.1 Conformance with Regulatory Guide 1.45 22 3.2.2 Leakage Limits 22 3.2.3 Frequency of Leakage Monitoring 24 3.2.4 Definition of Unidentified leakage

. 24 3.2.5 Operar.ihty of Monitoring Instruments

• 25 3.2.6 Evaluation and Recommendations 26

4. CONCLUSIONS AND RECOMMENDATIONS 28

5. REFERENCES 32-iv

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1. INTRODUCTION s.

Intergranular stress cortcuien cracking (IGSCC) near veldments in Boiling Water Reactor (BWR) piping has been occurring for almt 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 vith other relcted work by vendors, consulting firms and confirmatory research sponsored by the NRC, have permitted the development of NRC Staff positions regarding the IGSCC problems.

The technical basis for NRC Staff positions is detailed in Referance 1, and further backgrcund is provided in Reference 2. .

.The results of these research and development programs prompted the NRC to issue Generic Letter 88-01 (see Reference 3) requesting all licensees ( f BWR's and holders of construction permits to:

(1) Furnish their current plans relcting to piping replacnent, inspection, repair, and leakage detection.

(2) Indiccte whether they:

(a) Ples, to folloe tae 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 ta':en or to be taken to mitigate IGSCC end provide assurance

' continued long-term piping integrity and reliahf.lity.

(T) An inservice impection (ISI) program to be implemented at ae next refveling outage for austenitic stainless steel piping.

( 3) A change r.o the Technictil Specifications to include a statement 1

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for piping will be in conformance with the staff positions i on schedule, methods and personnel, and sample expansion.

(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 accordance with 10CFR50.55a(o),

of any flaws identified that do not meet IVB-3500 criteria of Section II of the ASME Code for continued operation without evaluation, or a change found in tne condition of the welds previously known to be cracked, and an evaluation of the flaws for continued used operation and/or repair plans.

This report contains a technical evaluation of the response which Cleveland Electric Illuminating Company (called either eleveland Electric or CEI in t'~ a report) submitted in response to the NRC Generic Letter 88-01 ps-* eining to the Perry Nuclear Power Plant (hereaf ter called either Perry or PNPP).

2. EVALUATION OF RESPONSE 'N GENERIC LETTER 88-01 This evaluation consisted of a review of the response to NRC Generic Letter 88-01 of January 25, 1988 by Cleveland Electric pertaining to Perry to deterair.e if their oerformance 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 were included in the review.

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2.1 Documents Evaluated Review was conducted on the information pertaining to Perry provided by the Licensee in the following documents.

(1) " Response to Generic Letter 88-01, Docket No. 50-440, Perry Nuclear Power Plant," PY-CEI/NRR-0894 L. Cleveland Electric Illuminating Company, P.O. Box 97,10 Center Road, Perry, Ohio, 44801, July 29, 1988.

(2) " Perry Nuclear Power Plant, Docket No. 50-440 Generic Letter 88-01, Extension Request and Response Clarification," PY-CEI/NRR-1027 L, Cleveland Electric Illuminating Company, P.O. Box 97,10 Center Road, Perry, Onio, 44601, June 15, 1989.

(3) " Perry Nuclear Power Plant, Docket No. 50-440, (Response to) Request for Additional Information on Generic Letter 88-01 (IGSCC) TAC No. 69152 " PY-CEI/NRR-1044 L. Cleveland Electric Illuminating Company, P.O. Box 97,10 Center Toad, Perry, Ohio, 44801, June 2,1969. N{ 33,lSt3 Hereaf ter, in this report, these documents will be. referred to as the Cle; eland Slectric Submittals No. 1 No. 2, and No. 3, respectively, and collectively as the Cleveland Electric Submittals.

2.2 Review of Cleveland Electric Illuminatina Co.'s Responses to Staff Positions and Implementation of Those Positions.

Generic Letter 88-01 outlines 13 NRC Staff positions pertaining to (1) materials, (2) processes, (3) water chemistry. (4) weld overlay, (5) partial replacement, (6) stress improvement of cracked weldments, (7) clamping devices (8) crach evaluation and repair 3

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criteria, (9) inspection methods and personnel, (10) inspection schedules, (11) sample expansion, (12) leak detection, and (13) reporting requirements. Generic Letter 88-01 states that the licensee should indicate in their submittal whether they endorse these NRC Staff positions or propose alternativo positions.

Cleveland Electric Submittal No. 3 contains a table that presents their position on the 13 NRC Staff positions, and Table 1 of this report was constructed using information from that table.

Note that Cleveland Electric indicated acceptance of twelve of the thirteen NRC Staff positions, although they indicated that they ha"e applied provisions to two of those positions (i.e., that pertain 11g to Inspection Methods and Personnet sad that pertaining to Inspaction Schedules). As discussed in Section 2.5 of this report those provisions are acceptable.

Concerning inspections, although not indicated in Table 1, Cleveland Electric proposed an alternative to the NRC Staff request to amend the Technical Specification on ISI to include a statement that their ISI program will comply with the NRC Staff position on schedules, methods and personnel, and sample expansion. This alternative position is discussed in Section 3.1 of this report.

It may also be noted from Table 1 that Cleveland Electric proposed alterr.stive positions pertaining to portions of the NRC Staff positions concerning leakage detection. These alternative positions are discussed in Section 3.2 of this report.

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Table 1 Sumary of Cleveland Electric's Responses to Staff Positions CEI BasN111 CEI Accepts NRC Applied Consider for Staff Position Staff Position In Past Future Use'

1. Materials yes yes yesI ")

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 cf Cracked Weldsents yes no- yes

7. Clamping Devices yes no yes

8. Crack Evaluation and Repair Criteria yes no yes

9. Inspection Method and Personnel yes(b) y,, ,

10. Inspection Schedule yes(b) ,, y,,_

11. Sample Expansion- yes no yes

12. Leak Detection see (c)~ see (c) see (c)

13. Reporting Requirements yes no yes-(a) Welda in most stainless-steel _ piping is conforms to NRC Staff

-requirements for resistance to IGSCC, but this was achieved b; extensive used of SHT and CRC. Exceptions sre 25 Inconel welds between pressure vessel nozzles and safe-ends. : Stress improvement is being considered for these welds.

(b) Provisions applied. See text for discussion.-

(c) CEI proposed alternatives to some portions of WRC Staff position on leakage detection. See text for discussion.

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1 2.3 Review of Ciessification of Welds. Previous Mitigating Actions, and Previous Inspections 2.3.1 Scope of Generic Letter 88-01 Generic Letter 88-01 defines its scope of coverage as follows:

"This Generic Letter applies to all BVR piping made of austenitic stainless steel that is four inches or larger in nominal di tater and contains reactor coolant at a temperature above 200'F regardless of Code classification.

It also applies to reactor vessel attachments and appurtenances such as jet pump instrumentation penetration assemblies and head spray and vent components."

In a Request for Information, Cleveland Electric was specifica11Ly asked, among other things, whether they had excluded any piping (such as the portion of piping in the RWCU that is outboard of the isolation valves) from their reply to Generic Letter 88-01. Cleveland Electric did not respond to that question in their replies to the RAI (Cleveland Electric Submittals Nos. 2 and 3). Thus, it is assumed that the piping discusred in the following sections constitutes all of the piping within the scope of Generic Letter 88-01.

2.3.2' Materials in Piping Systems '

Claveland Electric Submittal No. I states the followingr

"... 'Ihe stainless steel piping at Perry was fabricated, velded, inspected, and controlled as described in Sections 5.2.4 and 5.2.5 of the Perry SER (NUREG) 0887 and its supploments 5 and 7. With the exception of inconel weld 6 _ _ _ _ _ _ _ _ _

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metal, CEI finds no significant difference in material

,' at Perry and the Generic Letter 88-01 requirements for reactor coolant pressure boundary saterials."

Cleveland Electric Submittal No. 2, in elaborating on measures that were taken during construction of the piping systems to provide protectfon from IGSCC, ststen the following:

" Recirculation piping was made resistant to IGSCC by application of corrosion resistant cladding followed ty solution annealing. The recirculation inlet safe-ends and thermal sleeves were replaced with ?l6L austenitit n'. sinless steel material having a no-crevice design."

"The standby liquid control system piping is fabricated from Type 316L stainless steel."

"Other reactor coolant pressure boundary and engineered safety feature piping, except NSSS-supplied systems and the standby liquid control system, is fabricated from Type 304 stainless steel. Individual pipe lengths and fittings have been procured in the solution-annealed condition under ASME Specifications SA-312, SA-376, and SA-403 and are, therefore, not sensitized. Additionally, the following veld methods are employed for all pipe sizes: (a) Weld ' est input is controlled to Itait the material heat flux values to avoid the conditions that cause excessive sensitization. (b) Weld interpass temperatures are limited to a maximum of 350*F, and the weld weave pattern is lit,ited to a maximum of four times the core wire diameter to control the her.t build-up which contributes to excessive aens".tizatior.. (c) Weld procedures also conform to the guidelines of Regulatory 7

i Cuide 1.44, ' Control of the Use of Sensitized Stain ass Steel.'"

2.3.3 Materials in Norrie to Safe-End Welds Cleveland Electric Submittal No. 1 states that twenty-five Inconel 182 welds exist at Perry between the reactor vessel nozzles and safe-ends. These welds have been classified by Cleveland Electric as IGSCC Category D (as noted below, the classifications of most of these were subsequently changed to ICSCC Category G). These welds are idencified as items B5.10 and B5.20 in the Perry ten year ISI Program Plan (Document No. ISI-GEN-T2004 Rev. O, dated January 21, 1987, Section 13-A, pages 51-55, submitted by PY-CEI/NRR-0614 on March 31, 1987)

These welds were reclassified to IGSCC Category G in Cleveland Electric Submittal No. 2. which contains the f:N oving explanation:

" Generic letter 88-01 reflected recent industry concerns with certain Inconel materials used in the welding process. In our original response we therefore determined that the 25 reactor vessel nozzle to :.afe-end welds were fabricated of IGSCC sensitive material due to the use of Inconel 182 in weld preparation (' buttering') of the nozzles and the pipe ends. These 25 welds were classified

'D' (non-resistant material, no stress improvement) in our response to the Generic Letter. In performing our revia 17r the RAI with regard to weld inspection methods and quelifications, we have determined that the categorizat. ion of these reactor vessel nozzle to safe end welda should be ICSCC Category G as defined in Sections 5.2.1 and 5.3.1 of NUEEG 0313 Revision 2. These 8

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welds are listed in the attached tabulation (a preliminary draft of RAI response)."

The tabulation of welds mentioned in the above paragraph was duplicated in Cleveland Electric Submittal No. 3 and is summarized in the following section.

2.3.4 Summary of ICSCC Classifications Materials.

and Mitinating Treatments Cleveland Electric Submittal No. 3, which was submitted in in response to a Request for Additional Information (RAI),

a contains a list of welds that are included in the Perry IGSCC program. They listed a total of 302 welds; however, 154 of those are longitudinal seam welds which are not within the scope of Generic Letter 88-01. A summary of the number of welds, excluding the longitudinal seam welds, their IGSCC classifications, and mitigating treatments is contained in Table 2 of this report.

2.3.5 Previous Inspection Programs Cleveland Electric Submittal No. I does not disclose their previous inspection schedule; however, those inspections are discussed in Cleveland Electric Submittal No. 2 and 3.

Cleveland Electric Subeittal No. 2 states:

"The Perry Unit 1 Preservice Inspection (PSI) program scope of examinations, procedures, and acceptance criteria was based on the requirements of ASME Code, Secti'on'II, 1977 Edition with Addenda through Summer 1978. The extent of examination was determined by the requirements of l

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4 Table 2 r

Sumnary of IGSCC Classifications, Materials, i

I and Mitigating Treatments at Perry No. of Welds No. of Welds With IGSCC No. of With Conform. Indicated Treat.

Catenery Welds Material CRC SHT A 121 6 51 64 4

B 0 - - -

! C 0 - - -

D 2 - -

E O - -

F 0 - - -

i G 26 0 0 0 i

< '.otal 148 6 51- 64 i

ASME Code,Section II, 1974 Edition with Addenda through Summer 1975."

l Ir addressing the 25 nozzle to safe-end welds, Cleveland E'.ectric Submittal No. 2 states:

"These welds have been previously inspected per ASME Code criteria. Of 25 reactor vessel nozzle safe-end welds, 22 were examined during preservice inspection .

using automated ultrasonic equipment. ... The other 3 welds were manually examined. There were no reportable

-ITT indications."

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1 More specific information concerning previous inspections at Perry is contained in Cleveland Electric Submittal No.

3 which provides a list of inspection dates for all welds.

Included are both preservice inspection dates and inspections during Refueling Outage No. 1. This information is eussarized in Table 3 and in the following paragraphs.

IGSCC Cateaory A Welds: All 121 of these welds were given preservice inspections. Six of these were conducted in 1983, seven were conducted in 1984, and the remaining 108 were conducted in 1985. ,

ICSCC Catenory D Welds: These two welds which are located at the jet pump instrument nozzle safe end to penetration seal were both inspected during Refueling Outage No.

1. Methods and Personnel were in conformance with guidelines provided in NUREG_0313. Revision 2.

ICSCC Category G Weldst'All 25 of these welds received preservice inspections in 1984. -Cleveland Electric elected to classify these welds as IGSCC Category G despite those inspections because Methods and Personr.41 utilized in those inspections ware not in conformance with guidelines provided.in NUREG 0313. Revision 2.

As noted later this action has no effect on the long tera examination schedules.

- 2.3.6 Evaluation of Previous Mitimatina Actions and Inspections and Recommendations '

Cleveland Electric has followed-the guidelines of NUREG 0313

-Revision 2 in the construction of--the piping systems at Perry _

with the result that all welds in piping are IGSCC Category A welds. In addition, Cleveland Electric followed previously 1

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l Table 3

'o Summary af Inspection Schedules for Perry No. Inspected / Scheduled (*)

Durina Indicated Outage IGSCC No in Past ,,

Future Required by Categ Caten 83 84 85 RF1 RF2 RF3 RF4 RF5 RF6 Generic Letter 88-01 A 121 6 7 108 3 24 7 8 8 7 25% every 10 years (at least 12% in 6 years)

B 0 - - - - - - - - - 50% every 10 years (at least 25% in 6 years)

C 0 - - - - - - - -

All within.the next 2 refueling cycles, then all every 10 years (at 50 % in 6 years)

D 2 (see note b) 2 (see note c) All every 2 refueling cycles

. E O - - - - - - - - - 50% next refueling

' cycle, then all every 2 refueling cycles F 0 - - - - - - - - - All every refueling outage G 25 0 0 25 0 25 (see note c) All next refueling cycle (a) The 1983, 1984, and 1985 inapections were preservice inspections.

Refueling Outage (RF) No. 1 occurred in the Spring, 1989. Perry is on an 18 month fuel cycle, but the acr al dates of future refueling outages were not provided.

(b) IGSCC Category D welds may have received preservice inspections, but this was not disclosed in the Cleveland Electric Submittals.

(c) IGSCC Category G welds will be reclaecified as IGSCC Category'D following inspections during Refueling Outage No. 2 (assuming no flaws are found). SI may be applied to IGSCC Category D and IGSCC Category G welds. Inspection schedules after Refueling Outat,e No. 2 vill follow the NRC Staff guidelines for the IGSCC classification (s) that are applicable at that time.

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accepted practices for 27 nozzle welds in the use of Inconel

,- alloys. However, these welds are not considered to be resistant to IGSCC. Cleveland Electric conservatively elected to classify most of these as IGSCC Category G even though they received preservice inspections. Acceptance of Cleveland Electric's classification of the velds at Perry is recommended.

2.4 Current Plans for Mitigating Actions 2.4.1 Summary of Plans Cleveland Electric has no specific plans for future mitigating actions except for possible application of stress improvement to non-resistant velds as discussed below.

2.4.2 Stress Improvement Stress improvement treatments of nozzle to safe-end welds are under consideration, concerning which Cleveland Electric Submittal No. 2 states:

" Perry is still evaluating mechanical stress improvement (SI) on these nozzles for the second refueling, which would place the subject welds in Category C (nonresistant materials, stress improvement after 2 years of operation) if satisfactorily completed and inspected."

2.4.3 Evaluation of Conformance to Staff Positions and Recommendation Stress improvement is being considered for the 25 non-resistant welds (i.e., the nozzle to safe-end welds) 13

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1 and all other welds within the scope of Generic Letter 88-01 are already IGSCC Category A welds. In addition, as discussed in the Section 2.5 of this report, inspection plans comply with NRC Staff guidelines, hus, acceptance of Cleveland Electric's plans is recommended.

2.5 Plans for Future Inspections 2.5.1 Summary of Inspection Schedule Cleveland Electric Submittal No. 1 states that the requirew nts for IGSCC Gstegory A welds will be incorporated into the ISI Program plan, and that plan will reflect commitments to Generic Letter 88-01. In addition Cleveland Electric Submittal No. I states that an augmented inspection program will be instituted for the 25 nozzle to safe-end welds that will comply with Generic Letter 88-01.

Cleveland Electric Submittal No. 3 contains a detailed list (on a weld-by-weld basis) of inspection plans for welds within the IGSCC program, n ese plans are summarized in Table 3 (along with the summary of past inspections that were discussed previously) and in the following paragraphs. Table 3 also contains summaries of the inspection requirements for each IGSCC category as delineated in Generic Letter 88-01.

ICSCC Category A Welds: Fifty-seven of the 121 IGSCC Category A welds are scheduled for inspection during the inspection period (Refueling Outage Nos. I through 6). This represents 47% of the welds which is considerably in excess of the 25% required by Generic letter 88-01.

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1 ICSCC Catenary D and IGSCC Category G Velds: All of

, these non-resistant velds will be inspected during the second refueling outage. 'Ihereaf ter, the IGSCC Category G welds vill be reclassified as ICSCC Category D, and all IGSCC Category D welds will be reviewed for Stress Improvement (SI) treatments. If SI treatmenta are not applicd, Clevelaad Electtic plans to inspect all of these selds every second refueling outage. Note that this is a deviation from NRC Staff guidelines as delineated in peregraph 5.3.2.4 of NUREG 0313 Revision 2 which suggests that half of the IGSCC Category D welds should be inspected during each refueling outage. This deviation constitutes the provision applied to inspection schedules that was noted in Section 2.2 and Table 1 of this report.

Cleveland Electric Submittal No. 3 contains the folio.iing statement of that provision: j "PNPP has 25 reactor vessel nozzle to safe-end velds which are presently categorized as 'C', and subsequently scheduled for ultrasonic examination during the second refueling outage (tentatively scheduled for the fall of 1990). Fallowing the RF2 scheduled examinations, if IGSCC has not occurred if SI has not been applied, the nozzle safe-end welds will be reclassified as category

'D'. Any Cat dory 'D' welds would be scheduled for in-service inspections in accordance with NUREG 0313 revision 2 with an Exception of the recommendation to perform the examinations on half of the nor.zles every refueling outage. PNPP proposes to examine 100% of the category 'D' welds every other refueling outage with no mid-term examinations unless the areas are made accessible due to other work related activities occurring

during the refueling outage."

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1 Cleveland Electric Submittal No. 2 contains the following

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information pertaining to inspection plans of nozzle velds.

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"Regarding the inspection interval for non-resistant asterial without stress improvement, the recossmendation is to perform inspections every 2 refue. ling cycles once a determination is made that no IGSCC indications are present. The Perry Nuclear Power Plant is _till a ' young' plact, having finir.hed only one fuel cycle after initial testing. Prior to plant operation, the Perry safe-end welds could not have been subject to IGSCC conditions, and therefore were acceptable from an IGSCC standpoint.

Therefore, the first inspection of the subject welds can be scheduled for the second refueling outage, consistent with our original dscision to perfora these inspections at that time."

" Discussions with our NSSS vendor indicated that IGSCC of Inconel 182 material typically does not occur until after at least six years of operation. Recent experience has shown that the earliest any limited occurrence of IGSCC has been found is after completion of the initial two fuel cycles."

2.5.2 Inaccessible Welds No inaccessible welds are listed in the Clevelar.d Electric Submittal No. 1 for Perry.

2.5.3 Methods and Personnel .

Recall frem Section 2.2 and Table 1 of this report that Cleveland Electric endora.as the NRC Staff position pertaining to methods and personnel, although they applied a provision.

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Specifically, Cleveland Electric Submittal No. 3 states:

"Each veld vill receive a basic Section II examination.

Velds containing corrosion resistant cladding (CRC) vill receive an augmented exaaination developed specifically to examine the unique veld configurations. Velds without CRC will receive an augmented IGSCC examination."

"The exception applies to the examination techniques used on velds which have the CRC application. As noted in the Staff Position on Materials, welds with CRC are considered resistant to IGSCC, and this unique CRC weld configuration makes the application of an IGSCC examination method ineffective. Therefore, a specialized ultrasonic examination technique was developed by the pre-service NDE vendor, h e technique was demonstrated at the EPRI NDE Center in Charlotte, North Carolina.

The procedure was reviewed and approved by the Site ANII and reviewed by the Region III NDE Inspector prior to utilization."

2.5.4 Sample Expansion The Cleveland Electric Submittals did not contain descriptions of plans for sample expancton; however, Cleveland Electric did indicate that their endorsement of the NRC Staff position would be incorporated into the. Inservice Inspection program for Perry.

2.5.5 Evaluation and Recommendatim Cleveland Electric' position concerning inspection schedules comply with the NRC Staff position with the minor provision that IGSCC Category D welds will all be inspected every two

.---,-en~.. .e- m,-n,.-~

[ -

i refueling outages (rather than half each refueling outage).

This is an acceptable provision. Their position concerning inspection methods and personnel complies with the NFC Staf f position with the provision that improved inspection techniques have been developed and and will be applied to the inspection of welds that have been clad (CRC). This is an acceptable provision. Their position pertaining to sample expansion complies with the KRC Staf f position. Thus, acceptance of Cleveland Electric's positions pertaining to inspection schedules, methods and personnel, and sample expansion is recommended.

2.6 Changes in the Technical Specification Concerning ISI Cleveland Electric proposed an alternative position to the KRC Staff position concerning a change to the Technical Specification to include a statement that their ISI program vill comply with

! the NRC Staff position on inspection schedules, methods and personnel, and sample expansion. This alternative position is dis:ussed in Section 3 of this report.

2.7 Confirmation of Leak Detection in the Technical Specification Table 4 of this report provides a summary of Cleveland Electric's position on requirements for leakage detectiot that are delineated j in Generic Letter 88-01. Note that Cleveland Electric indicates conformance with a portion of the requirements. However, since

• they also proposed alternative positions on a portion of the leakage requiruments, discussion of the entire subject of leakage detection is deferred in this rsport to Section 3, " Alternative Positions and Exceptions."

, - NT - ,n

.ws.

T i

Table 4 Licensee Positions on Leakage Detection (a)

Already TS vill be Alternate Contained Changed Position Position in TS to Include Proposed

1. Conforms with Position C of yes - -

Regulatory Guide 1.45

2. Plant shutdown should be initiated when:

(a) vithin any period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - -

yes or less, an increase is indicated in the rate of unidentified leakage in excess of 2 gpa, or (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 - -

except:

(a) leakage into closed systems, or (b) leakage into the containment atmosphere from sources that are located, do not interfere with monitoring systems, or not from throughwall crack.

5. Provistoas for shutdown within 24 - -

yes hours due to inoperable measurement instruments in plants with Category D, E, F, or G welds.

(a) See text for discussions concerning alternate proposals sad other comments.

_ _ _ _ _ _ _ _ _ - _ - . - - - - - - - - - - - - - - - - - - - ^ ' - ' ' ' ' ^ ' ^ ' ^ ^ ' ~ ~ ~ ^ ^ ^ ' ~ ~ ~ ^~

f  :

4 e

2.8 Plans for Notification of the NRC of Flaws Generic Letter 88-01 requests the following:

"In accordance with 10CFR50.55(o), your plans to notify the NRC of any flaws identified that do not meet IVB-3500 criteria of Section II of the Code for continued operation withvut evaluation, or a change found in condition of the veldc previously known to be cracked, and your evaluation of the flaws for continued operation and/or your repair plans."

2.8.1 Cleveland Electric's Position The Cleveland Electric Submittal No. I states:

"CEI confirms that such notificatica vill be provided."

2.8.2 Evaluation acd Recoe.mendation Cleveland Electric's plans for reporting of flaws complies with the NRC Staf f position, so it is recoamended that the plans for reporting of flaws should be accepted.

3. ALTERNATIVE POSITIONS AND EICEPTIONS 3.1 Alternative Position Concerning ISI .. the Technical Specification 3.1.1 NRC Staff Position Generic Letter 88-01 requires each licensee to change their Technical Specifications to include a statement in the section on ISI that the Inservice Inspection Program for piping

P i

covered by the scope of that letter will be in conformance

i. with the NRC Staff position on schedule, methods and personnel, and sample expansion.

3.1.2 Cleveland Electric's Position Cleveland Electric Sutoittal No. I states:

"CEI plans to incorporst- *ese changes in the ISI program."

"The commitment for performing ISI related examination is presently documented in both the PNPP 10-year Inservice Inspection Plan in addition to Sections 3.4.8 and 4.0.5 of the plant Technical Specifications. The examination requirements pertaining to the IGSCC Category A and D material of the Generic Letter will be incorpore*.ed into the ISI Program Plan ... rather than adding a get.~ic statement to the Technical Specifications. This alternative method of documenting specific commitments to the Generic Letter recommendations vill properly control the activities conducted under the ISI program at PNPP."

3.1.3 Evaluation and Recommendation Generic Letter 88-01 discloses that the in ervice Inspection and Testing Sections may be removed from the Technical i

Specifications (TS) and included in the ISI Program in the future. Despite this consideration, the NRC Staff specifically included a requirement in Generic Letter 88-01 to change the TS to include a statement that the ISI l

program vill conform with the NRC Staff position on l inspection. Thus rejection of the Cleveland Electric position l

l I

a is recommended, and the Technical Specification for Perry should be changed to include the required statement on ISI.

3.2 Leakage Detection in the Technical Specification-3.2.1 Conformance with Regulatory Guide 1.45 Generic letter 88-01 states:

4akage detection systems should be in conformance with Position C of Regulatory Guide 1.45 ' Reactor Coolant Pressure Boundary Leakage detection Systems,' or as otherwise previously approved by the NRC."

Cleveland Electric Submittal No. 3 states that the Perry Technical Specification in'conformance with this provision as previously reviewed and approved by the NRC, 3.2.2 Leakane Liaits Generic Letter 88-01 states

" Plant shutdown should be initiated for inspection and corrective action when, within any pcriod of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or lesa, any leakage detection system indicates an increase in rate of unidentified leakage in ezras of 2 spe or its equivalent, or when the total unidentified

. leakage attains a rate of 5 spe or equivalent, whichever occurs first." '

Note from Table 4 that the Perry Technical Specification contains requirements that conform with the NRC Staff position concerning the 5 gpa total unidentified leakage. However, 4

Cleveland Electric Submittal No. 3 contains the following a statement:

c "The Perry Plant is already restricted to 5 gpa leakage from unidentified sources by the Technical Specifications.

This limit is shown to be quite conservative by USAR Section 5.2.5.5 which identifies that this 5 spa leakage rate is a small fraction of the calculated flow from a critical crack in a primary system pipe. Should a leak develop for whatever reason, this current limit is considered sufficient to allow for plant shutdown to investigate. PNPP has just completed its first refueling outage, and the PNPP reactor coolant pressure boundary had no evidence of cracking from either preservice examirations or from inservice examinations performed during the refuel outage. Industry experience has shown that IGSCC cracking is not yet a safety concern for a plant such as PNPP, at least thrs go the end of the second feel cycle. ... Stress improvement is still under consideration for velds currently not considered resistant to IGSCC. Should CEI elect to apply Stress Improvement techniques to these velds during the second refuel outage, then all welds at PNPP wou'.d t.: considered resistant to IGSCC. If Stress Improvement is not chosen to be performed on the subject welds during upcoming refueling outages, CEI would consider the nadition of the NRC recommended Technical Specification requirement associated with service sensitive IGS(X: materials that imposes a shutdown if leakage rates increase 2 gpu over

, a 24-hour period. Again, CEI intends to consider this l Technical Specification change in conjunction with evaluation of Stress Improvement. As a minimum, however, this requirement would have to allow for reestablishing background rates of leakage during plant startups."

%< s 4 - ,

l 1 3.2.3 Frequency of Leakage Monitoring Generic Letter 88-01 states:

"For sump level monitoring systems with fixed-measurement-interval methods, the level should be monitored at approximately 4-hour intervals or less."

Cleveland Electric Submittal No. 3 states the following:

"This recommendation is not applicable to PHPP. ...

Leakage into the dryvell floor drain susp (unidentified leakage) at PNPP is continuously monitored by instrumentation which records the rate of fill of the sump and provides an alarm in the control room as leakage approaches Technical Specification limits. This leakage flow rate is also monitored by control room operators every shift-(approximately every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) in order to ensure meeting the Technical Specification 12-hour surveillance requirement. If the alarm is activated / Tech Spec limits are approached, close monitoring of this flow rate is initiated as a result of cdainistrative controls."

3.2.4 Definition of Unidentified Leakage Generic Lett'er 88-01 states:

" 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 i into the containment atsosphere from sources that are l both specifically located and known either not to l

l 4

l l

interfere with the operations of unidentified leakage monitoring systems or not to be from a throughwall crack in the piping within the reactor coolant pressure boundary."

As indicated in Table 4, the Perry Technical Specification conforms vith this position.

3.2.5 Operability of MonitorinR Instruments Generic Letter 88-01 states:

"For plants operating with any IGSCC Category D, E F, or G velds, at least one of the leakage measurement instruments associated with each sump shall be operable, and the outage time for inoperable instruments shall be limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or inmediately initiate an orderly shutdown."

As indicated in Table 4, Cleveland Electric proposed an alternative position on this item. Specifically, Cleveland Electric Submittal No. 3 states:

"As discussed ... above, IGSOC cracking is not yet a safety concern for PNPP at least through the end of the second fuel cycle, and Stress Improvement is still under consideration for Laplementation on Category D, E, F or G welds. If CEI elects to apply Stress Improvement to these velds, then no Category D, E. F or G welds would exist and this recommendation would clearly not apply.

Even if Stress Improvement is not performed on these velds, PRPP's design includes the use of apper dryvell cooler condensate flow rate monitors which eliminate the need tc implement this reconsendation at PNPP. These

R ,

condensate flow rate monitors have the capability .s identify leaks with an accuracy of 1 gpa within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and since reactor coolant leakage f.'. ashes to steam at the atmospheric pressure in the drywell free space, these drywell cooler condensate flov monitors perform essentially the same function as the floor drain sump flow rate ocasurements (with a correction for steam condensed on other equipment). PNPP Technical Specifications have always allowed a 30-day out-of-service Action Statement for floor drain sump inoperability based-on the assumption that the other leak detection systems would provide adequate indication; this assumption was made a requirement through a recent Technical Specification amendment that required that. the dryvell cooler condensate flow monitor be operable if the f'.oor drain instrumentation was not. If both systems are inoperable, a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shutdown is imposed by Technical Specifications. Therefore, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> out-of-service Action Statement for loss of floor drain instrumentation is not necessary at PNPP."

3.2.6 Evaluation and Recommendations Cleveland Electric's positions concerning compliance with Regulatory Guide 1.45, limits on the total unidentified leakage 't 5 gps, and description (or definition) of unidentified leakage comply with NRC Staff guidelines. Thus, aces, tance of these positions is recommended.

Concerning the requirement for~ limiting the increase of the unidentified leakage to 2 gpa over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, Cleveland Electric's proposal is not acceptable. The NRC Staff, in the development of this proposal concluded that limiting the total unidentified leakage to 5 gpa (without imposing 1

! 26

. m M

a restriction of the rate of increase of unidentified leakage) is not sufficiently conservative. Furthermore, this requirement was included in Generic Letter 88-01 even though the NRC Staff realized that all welds at some plants would be ICSCC Categories A, B, and C. Thus, rejection of Cleveland Electric's position on this ites is recommended. It is further recommended that Cleveland Electric should amend the Perry Technical Specification to equire a maximum rate of increase of unidentified leakage as delineated in ,eneric r Letter 88-01 and quoted in Section 3.2.2 of this report.

Concerning requirements foi frequency of leakage measurement:

Even though Perry continuously monitors the unidentified leakage, the recording of this rate by control room operators every eight hours is inadequate. It is recommended, therefore, that the Technical Specification should be amended to require that operators record the unidentified leakage approrisately every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or less, as required iy Generic Letter 88-01.

Cleveland Electric's position pertaining to requirements for operability of measurements instruments is not acceptable.

The alternative methods of leakage measurement available at Perry provide accuracy of I sps within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This is inadequate to measure an increase of unidentified leakage in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period of 2 spa. Thus, Cleveland Electric should either modify the Perry Technical Specification or proceed with actions to apply mitigating actions to eliminate the 27 IGSCC Category D and G welds.

7

- w -_ . . . _

m ,

4. CONCLUSIONS AND RECOMMENDATIONS t.

Concerning the thirteen NRC Staff positions as delineated in Generic Letter 8S-01: Cleveland Electric endorses twelve of the thirteen KRC Staff positions (i.e., those pertaining to materials, processes, veter chemistry, weld overlay, partial replacement, stress improvement of crscked weldments, clamping devices, crack evaluatior and repair criteria, inspection methods and personnel, inspection schedule, sample expansion, and reporting requirements), although they presented provisions to the items on inspection schedules and on methods and personnel. They presented exceptions to one of the positions (i.e.,

that pertaining to leakage detection).

Design and construction at Perry was patterned after ERC Staff guidelines with the result that most velds (121 out of a total of 148) are IGSCC Category A welds. Fifty one of the IGSOC Category A welds were solution heat treated, sixty-four were clad with corrosion resistant cladding, and six were constructed with corrosion resistant materials. Twenty-seven welds in nozzle assemblies contain non-resistant Inconel alloys. Two of these were inspected during the first refueling outage and are classified as IGSCC Category D.

Preservice inspections were performed on the other non-resistant welds, but they are classified as IGSCC Category G welds. Specific plans for future mitigating actions have not been formulated; however, stress improvement treacaents are being considered for the 27 welds that are classified as IGSCC Categories D and G.

An inservice inspection program (ISI) has been developed for Perry which complies with the requirements of Generic Letter 88-01 (with certain provisions) pertaining to schedule, methods and personnel.

• and sample expansion. One provision pertains to inspection schedules for IGSCC Category D and G velds. As required by Generic Letter 88-01, all of the IGSCC Category G velds will be inspected during the next refueling outage (and then reclassified as IGSOC Category D,

.,W 6 - -

1 O

I assuming no flaws are found). Also following requirements of Generic Letter 88-01, all ICSOC Category D welds will be inspected every two refueling outages outages, but these inspections are planned for every second outage rathtr than 50% each refueling outage as suggested by NUREG 0313 Revision 2.

The second provision pertains to IGSOC Category A welds that have been clad with corrosion resistant cladding. Inspections of these welds, as with other welds, vill follow KRC Staff guidelines for methods and personnel, but they will be supplemented vith special tecLaiques developed for the CRC weld configuration that was demonstrated at the EPRI NDE Center at Charlotte, NC, approved by the Site ANII, and reviewed by the Region III KDE inspector.

Cleveland Electric declined to change the Technical Specification on ISI. Rather they proposed to include such a statement in the Inservice Inspection Program. Such action was specifically rejected in Generic Letter 88-01.

Cleveland Electric proposed alternative positions to portions of the NRC Staff position pertaining to leakage detection. The Perry Technical Specification requires plant shutdown (as required by Generic Letter 8B-01) when the unidentified leakage exceeds 5 gps. They consider this requirement is sufficiently conservative that there is no need to require plant shutdown when the rate of increase reaches 2 gpa in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period or less, particularly since they may apply SI treatments to the remaining 27 noncomforming welds. They stated that l they vill consider instituting such a requirement in the event that SI treatments are not applied. This position is in contraat to the NRC Staff position that imposes the 2 gpm limit on the rate of increase of unidentified leakage on all BVR plants regardless of the ICSCC Classifications of the welds.

Leakage at Perry is continuously monitored rather than monitored with 6

1

?

fixed-measurement-interval nethods. They require control room operators f; to record the leakage rate once per shif t (approximately c ce every eight hours rather than approximately every four hours, or less, as required by Generic Letter 88-01).

i

. Finally, Cleveland Electric proposed that the requirements for operability of monitoring instruments outlined in Generic Letter B8-01 for plants operating with ICSCC Category D, E, F, or G velds should not apply to Perry. Reasons given ares (a) IGSCC is not currently a safety concern and vill not be until at least the end of the second fuel cycle, and (b) the 27 velds at Perry that are classified in those categories may be Stress Improved and reclassified to IGSCC Category C during the next refueling outage (Refueling Outage No. 2), and (c) alternative methods for measuring leakage are available which are required by the Technical Specification to be operative in the event of outage of sump monitors. However, the alternative methods for measuring leakage do not have equivalent accuracy.

As a result of this technical evaluation, tha following recommendations are made.

(1) Acceptance of Cleveland Electric's IGSCC classifications of welds and plans for mitigating IGSCC at Perry.

(2) Acceptance of Cleveland Electric's inspection plans, including the provision concerning inspection schedules and the provision concerning meihods and personnel.

(3) Rejection of Cleveland Electric's position concerning changes to the Technical Specification on ISI. Cleveland Electric should add the required statement to the Technical Specification on ISI.

(4) Acceptance of Cleveland Electric's positions on the portions

/_ ns of leakage detection pertaining to conformance with Regulatory Guide 1.45, the limit on the total unidentified leakage, and definition (description) of unidentified leakage.

(5) Rejection of the exception pertaining to plant shut down due to an increase in the rate of unidentified leakage. Cleveland Electric should amend the Perry Technical Specification to require, as directed in Generic Letter 88-01, that plant shutdown should be initiated for inspection and corrective action when, within any period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less, any leakage detection system indicates an increase in rate of unidentified leakage in excess of 2 gpa or its equivalent.

(6) Although Perry utilizes continuous monitoring of leakage, Cleveland Electric should amend the Perry Technical Specification to require control room operators to record the leakage rate at approximately 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> intervals, or less, rather than the currently required 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval.

(7) Rejection of the exception pertaining to plant shut down due to inoperable monitoring instruments. Cleveland Electric should either apply mitigating treatments (per guidelines provided in NUREG 0313 Revisioa 2 and Generic Letter 88-01) to eliminate non-resistant ICSCC classifications or they should amend the Perry Technical Specification on leakage detection to require operability of monitoring instruments per guidelines provided in' Generic luer 88-01.

(8) Acceptance of the remaining portions of the Cleveland Electric Submittals pertaining to Perry.

. 1

)

5. REFERENCES I'

1. " Technical report on Katerial Selection and Processing Guidelines for BVR Coolant Pressure Boundary Piping," KUREG 0313. Revision 2, U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation January, 1988.

2. " Investigation and Evaluation of Stress-Corrosion Cracking in Piping of Light Water Reactor Plants," NUREG 0531, U. S. Nuclear Regulatory Commission, February, 1979.

3. "NRC Position on IGSCC in BVR Austenitic Stainless Steel Piping,"

Generic Letter 88-01, U.S. Nuclear Regulatory Commission, January 25, 1988.

32