ML20091D596
| ML20091D596 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/31/1983 |
| From: | Nagata P EG&G, INC. |
| To: | Koo W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20091D599 | List: |
| References | |
| CON-FIN-A-6429, RTR-NUREG-0313, RTR-NUREG-313 EGG-FM-6252, GL-81-04, GL-81-4, TAC-46662, TAC-46663, NUDOCS 8405310368 | |
| Download: ML20091D596 (43) | |
Text
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EGG-FM-6252 July 1983
/
TECHNICAL EVALUATION OF INTEGRITY OF THE EDWIN 1. HATCH NUCLEAR POWER PLANT '
UNITS 1 AND 2 REACTOR COOLANT BOUNDARY
, PIPING SYSTEM i
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Peter K. Nagata
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Idaho National Engineering Laboratory Operated by the U.S. Department of Energy y .. -
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This is an informal report intended for use as a preliminary or working documunt m
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Under 00E Contract No. DE-AC07-76ID01570 pg g g E g Idaho
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l EGG-FM-6252 TECHNICAL EVALUATION OF INTEGRITY OF
, THE EDWIN I. HATCH NUCLEAR POWER PLANT UNITS 1 AND 2 REACTOR COOLANT
, B0UNDARY PIPING SYSTEM Published July 19,83 i
Peter K. Nagata Materials Engineering Branch Materials Sciences Division EG&G Idaho, Inc.
. . Responsible NRC Individual and Division:
W. H. Koo/ Division of Engineering Docket No.: 50-321, -366 TAC No.: 46662 and 46663 L
l l Prepared for the l U.S. Nuclear Regulatory Commission Under DOE Contract No. DE-AC07-761001570 FIN No. A6429 l
l
A85 TRACT
, -NUREG-0313, Rev. 1, Technical Report on Material Selection and Processing Guidelines for swr coolant Pressure soundary Piping. is the NRC l
staff's revised acceptable methods to reduce intergranular stress corrosion J i,
cracking in toiling water reactors. The responses to NRC Generic 1 Letter 81-04 of the Georgia Power Company concerning whether its Edwin I.
Hatch Nuclear Power Plants Units I and 2 meet NUREG-0313. Rev. I are evaluated by EG&G Idaho, Inc. in this report. Particular attention was given the. leak detection systems described in Regulatory Guide 1.45, Reactor Coolant Pressure Boundary Leak Detection Systems, referenced by 4
Parts IV.B.I.a.(1) and (2) found on pages 7 and 8 of NUREG-0313, Rev. 1.
I FOREWORD This report is supplied as part of the Selected Operating Reactor issues Program being conducted 'for the U.S. Nuclear Regulatory Cormnission, Office of Nuclear Reactor Regulation Division* of Licensing, by EG&G Idaho, Inc., Materials Engineering Branch.
The U.S. Nuclear Regulatory Commission funded 'the work under the
- authorization, B&R 20 19 10 11.
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SUMMARY
NUREG-0313, Rev.1, Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure soundary Piping. is the NRC staff's revised acceptacle metnoos to reduce intergranular stress corrosion cracking in boiling water reactors. The responses to NRC Generic Letter 81-04 of the Georgia Power Company concerning whether its Edwin I.
i Hatch Nuclear Pcwer Plants Units 1 and 2 meet NUREG-0313, Rev. I are !
- evaluated by EG4,G Idaho, Inc. in this report. Particular attention was
, given the leak detection systems described in Regulatory Guide 1.45, Reactor Coolant Pressure Boundary Leak Detection Systems, referenced by
- Parts IV.5.1.a.(1) and (z) found on pages / and 8 of NUREG-0313 Rev. 1.
!- As may be observed in the following table, Edwin I. Hatch Units 1 and 2 i do not meet any of the parts of NUREG-0313 Rev.1 evaluated in this document. ,
I The following table is a synopsis of the EGlG Idaho, Inc. evaluation of
, Georgia Power Company's response to NPC Generic Letter 81-04.
- Additional Part of NUREG-0313, Data a
Rev. 1 Evaluated Evaluation Required b Discrepancy Section II. 1 4
II.C. Provides alternative to No Minor NUREG-0313, Rev. 1 Section III. .
Section IV.
IV.B.1. a. ( 1) Provides alternative to Yes Major NUREG-0313, Rev. 1
. IV. 8.1. a. ( 2 ), Does not meet NUREG-0313 Yes Major Rev. 1
- IV.B.I.b. Provides alternative to Yes Minor l NUREG-0313, Rev. 1 IV.8.1.b.(3) Did not provide data in Yes Minor response to NRC Generic
- .
- Letter 81-04 IV.8.1.b.(4) Did not provide data in Yes Minor t
response to NRC Generic Letter 81-04 IV.8.2.a. The comments for Parts IV.8.1.a.(1) and IV.8.1.a.(2) apply here.
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Additional Part of NUREG-0313, Data a
Rev. 1 Evaluated Evaluation Required D Discrepancy IV.8.2.b. Provides alternative to Yes Minor NUREG-0313 Rev. 1 IV.8.2.b.(3) Provides alternative to No Minor NUREG-0313, Rev. 1 IV.8.2.b.(6) Did not provide data in Yes Minor response to NRC Generic Letter 81-04 IV.8.3. Did not provide data in Yes Minor response to NRC Generic Letter 81-04 Section V.
aSee Tabits 1 and 3 for additional infonnation, bSee Tables 1 and 4 for additional infonnation.
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CONTENTS A B S TR AC T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
SUMMARY
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- 1. I N TR O D UC T I O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
- 2. EVALUATION ....................................................... 4
. 2.1 NUREG-0313. Rev. I Guidelines .............................. 4
. 2.2 Discussion of Tables ....................................... '4 2.3 Discrepancies ......................................'........ 5
- 3. C O NC L U S I O N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
- 4. R E F ER E NC E S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 TABLES -
- 1. Review of Licensee's Response to NRC Generic Letter 81-04 ........ 7
- 2. Summaries of Evaluation of Licensee's Responses .................. 25
- 3. Differences between NUREG-0313, Rev. I and Licensee's Responses ........................................................ 28
- 4. Additional Data Required of Licensee ............................. 35 v-
i TECHNICAL EVALUATION OF INTEGRITY OF THE EDWIN I. HATCH NUCLEAR POWER PLANT l
UNITS 1 AND 2 REACTOR COOLANT
- BOUNDARY PIPING SYSTEM l
- 1. INTRODUCTION Intergranular stress corrosion cracking (IGSCC) of austenitic stainless steel (SS) piping has been observed in boiling water reactors (BWRs) since December 1965.I The NRC established a Pipe Crack Study Group (PCSG) in January 1975 to study the problem.2 The PCSG issued two
, documents, NUREG-75/067, Technical Report, Investigation and Evaluaticn of Cracking in Austenitic Stainless Steel Piping of Soiling Water Reactors 3 and an implementation document, NUREG-0313,'Rev. 0.2 After cracking in large-diameter piping was discovered for the first time in the Duane Arnold BWR in 1978, a new PCSG was formed. The new PCSG in turn issued two reports, NUREG-0531, Investigation and Evaluation of Stress-Corrosion Cracking in Piping of Light Water Reactor Plants" and NUREG-0313, Rev. 1, Technical Report on Material Selection and Processing Guidelines for BWR ,
Coolant Pressure Boundary Piping.D NUREG-0313, Rev. 1 is the implementing document of NUREG-0531 and discusses the augmented inservice inspection (ISI) and leak detection requirements "for plants that cannot comply with the material selection, testing, and processing guidelines" of NUREG-0313, Rev. 1.5 NRC Generic Letter 81-04 requested each licensee "to review all ASME Code Class 1 and 2 pressure boundary piping, safe ends, and fitting material, including weld metal to determine if (they) meet the material selection, testing and processing guidelines in" NUREG-0313, Rev. 1.6 The generic letter offered the option of providing a description, schedule, and justification for alternative actions that would reduce the susceptibility of pressure boundary piping and safe ends to intergranular stress corrosion cracking (IGSCC) or increase the probability of early detection of leakage from pipe cracks.
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In response to NRC Generic Letter .81-04, Georgia Power Company (GPC) submitted a letter on June 29, 1981.7 A request for information from the NRC staff elicited another letter from GPC on January 7, 1983.8 EG&G Idaho personnel evaluated these responses, and this report provides:
- 1. A brief sumary of the licensee's response to each part of NUREG-0313 Rev. 1.
- 2. A discussion of areas where the licensee does not meet the guidelines or requirements of NUREG-0313, Rev. 1.a
- 3. A brief discussion of the licensee's proposed alternatives to NUREG-0313, Rev.1; however, no determination of ai:ceptability is made
, on these alternatives. -
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- 4. An identification of all areas where the licensee has not provided sufficient information to judge the licensee's program.
1 There is an effort underway to revise NUREG-0313, Rev. I by NRC in light of research on IGSCC and recent instances of IGSCC at Nine Mile Point (March 1982) and Monticello (October 1982). Because of this contemplated revision of NUREG-0313, Rev. 1, the following issues will not be evaluated.
- 1. The licensee'.s proposed Technical Specifications to implement the requirements, with the exception of the leak detection requirements in NUREG-0313, Rev.1, Sections IV.B.l.(a)(1) and IV.B.l.(a)(2).
- 2. The acceptability of licensee-proposed augmented inservice inspection ,
(ISI) sampling criteria.
a.
Part III of NUREG-0313, Rev. I contains guidelines; Part IV contains l
requirements.
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- 3. Credit for past operating experience and inspection results.
- 4. The acceptability of induction heating stress improvement (IHSI), heat sink welding (HSW), and weld overlay as alternates to augmented ISI.
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- 2. EVALUATION 2.1 NUREG-0313, Rev. 1 Guidelines The guidelines and requirements outlined in NUREG-0313, Rev. I form the basis of this evaluation. The NUREG-0313. Rev. 1 guidelines are found in Parts III and V and the requirements in Parts II and IV of that docu'm ent. Part II discusses implementation of material selection, testing, and processing guidelines. Part III summarizes acceptable methods to minimize IGSCC susceptibility with respect to the material selection, testing, and processing guidelines. Part IV deals with leak detection and 3- inservice inspection requirements of nonconforming (i.e., not meeting the guidelines of Part III of NUREG-0313, Rev. 1) piping. Part V discusses general recommendations. ,
2.2 Discussion of Tables Table I has the complete text Parts II through V of NUREG-0313, Rev.1 on the left side so that the reader may be able to refer to it as the topics are discussed. The right side summarizes the licen'see's responses, lists the differences between the licensee's proposed implementation program and NUREG-0313, Rev. 1, and identifies the additional data required
, to evaluate the licensee's response.
Many sections in Parts II through IV of NUREG-0313, Rev. I are not discussed in the right hand column. In these cases, one of the comments below will be used.
o .Not applicable because the construction permit for this plant has been issued.
o Not applicable because the operating license for this plant has '
t>een issued.
o Not applicable because.the plant has been constructed. - ,
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t o The licensee has not furnished data on this topic in his responses to NRC Generic Letter 81-04.
o No comment made because alternative plans were not evaluated.
Table 2 lists the summaries of the licensee's responses to NRC questions on implementation of NUREG-0313, Rev.1 guidelines. Therefore, in Table 2 the reader is able to read all the summaries in one table without having to search Table 1 for all the summaries. The same compilation applies to Tables 3 and 4. Table 3 lists the differences between the licensee's proposed implementation program and that recommended in NUREG-0313, Rev. 1.
Table 4 lists the areas where additional information is required to properly evaluate the licensee's proposed implementation program. All the items in' Tables 2, 3, and 4 are listed in their respective tables in the order they appear in Table 1.
2.3 Discrepancies Any alternate proposal that did not meet a specific guideline or requirement of NUREG-0313, Rev. I was considered a discrepancy. Evaluation of alternate proposals was outside the scope of this task, as indicated in Section 1.of this report. Licensees have submitted definitions of "nonservice sensitive" and augmented ISI proposals that differ from NUREG-0313, Rev. 1.
These differences are considered minor because the NRC staff is considering major modifications to those requirements. An example ,
of a minor discrepancy is the use of the stress rule index (SRI) to choose .
, which welds would be subjected to augmented ISI.
If the alternate proposal to leak detection does not meet the requirements in NUREG-0313, Rev. - 1, it was considered a major discrepancy because NRC is not considering major modifications to those requirements. ;
An example of a major discrepancy is a licensee's not proposing Technical -
Specifications to implement leak detection requirements in NUREG-0313, Rev. 1.
Only major discrepancies are listed in the Conclusions section.
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- 3. CONCLUSIONS Hatch I and 2 have the following major discrepancies.
Part IV.B.I.a.(1) Leak Detection and Monitoring Systems GPC's description of Hatch Plant Units 1 and 2's leak detection methods is not detailed enough to determine whether they meet Section C of Regulatory Guide 1.45. .'
Part IV.B.l.a.(2) Shutdown for Leakage GPC has put the provision for shutdown after a 2-gpm increase in unidentified leakage in 24 h into the Technical Specifications for Hatch 1 and 2. .
GPC has not put the provision for monitoring the sump level at 4-h intervals (or less) into the Hatch 2 Technical Specificatic9s.
There are minor discrepancies as well as the. major ones listed above.
These minor discrepancies are not listed here. However, while the licensee's alternate proposals that have been classified as minor discrepancies might be acceptable under the anticipated revision of NUREG-0313, Rev. 1, it should not be inferred that approval of those alternate proposals'has been given.
The licensee has not supplied sufficient information to evaluate his responses to topics IV.B.I.a.(1) and (2), IV.B.l.b., IV.B.I.b.(3) and (4),
IV.B.2.a. .. IV.8,2.b, IV.B.2.b. (6), and IV.B.3. Table 4 lists the required information for each topic.
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TABLE I. REVIEW OF LICENSEE *5 RESPONSE 10 NpC GENERIC LEliER 81-04 Encerpts from NUREG-0313 Rev. I EG8G Idaho Evaluation--Edwin I. Hatch Nuclear Power Plant Units I and 2 II. IMPLEMENTATION OF MAIERIAL SELECTION. TESTING, AND PRlR U TI M llELINE5 II.A. For plants under review, but for which a A. Not applicable because the construction permit for this construction permit has not been issued, all ASME plant has been issued.
Code Class I, 2, and 3 lines should conforin to the guidelines stated in Part III.
II.B. For plants that have been issued a cohstruction , B. Not applicable because the operating license for this permit but not an operating license, all ASME Code plant has been issued.
Class I, 2, and 3 lines should conform to the guidelines stated in Part III unless it can be demonstrated to the staff that implementing the guidelines of Part Ill would result in undue -
hardship. For cases in which the guidelines of Part III are not compiled with additional measures should be taken for CIass I and 2 lines in accordance with the guidelines stated in Part IV of this document.
II.C. For plants that have been issued an operating C. SIMIARY w license, NRC designated
- Service Sensitive" lines (Part IV. B) should be modified to conform to the Georgia Power Company (GPC) presently has no plans to guidelines stated in Part Ill, to the extent replace nonconforming " service sensitive" pipe that is not practicable. When " Service Sensitive" and other cracked.
Class I and 2 lines do not meet the guidelines of ,
Part III, additional measures should be taken in GPC has provided an alternative to NUREG-0313. Rev. I.
accordance with the guidelines stated in Part IV of this document. Lines that esperience cracking DlFfERENCES during service and require replacement should be replaced with piping that conforms to the NUREG-0313. Rev. I requires that all NRC-designated guidelines stated in Part Ill. " service sensitive
- lines be replaced with corrosion-resistant materials te the extent practical.
' Also, lines that experience cracking should be replaced with corrosion-resistant materials.
GPC has stated that they ". . .cannot justify the indiscriminate replacement of piping that has not showr.
signs of IGSCC in the Hatch plant. The inspection program described above should identify development of IGSCC in the systems involved. Due to this and the high radiation esposure involved in the replacement of the piping, Georgia Power Company does not plan to replace piping that has not
- shown evidence of IGSCC at Plant Hatch. In the event that repairs or replacement of nonconforming material is required, at such time the affected component,will be replaced with conforming material and processed in i
accordance with Section Ill of NUREG-0313, Rev.1."7 ADDITIONAL DATA REQUIRED None, l
'fil. SUMMMtr OF ACCEPTABLE ME THODS 10 MINIMilE LRACK 5175LTPTr8IETTTTHRTEllrAE~5H ECTIOCTES TTiiGTAlio Pil0EEI511lC EIITDEETMs r
lit.A. Selection of Materials A. The licensee has not furnished data on this paragraph In his responses to NRC GenerlC Letter 81-04. See Only those materials described in Paragraphs I comument on Part II.C. above.
and 2 below are acceptable to the NRC for installation in Stat ASME Code Class I, 2, and 3 piping systems. Other materials may b3 used when evaluated and accepted by the NRC.
III.A.I. Corrosion-Resistant Materials 1. The cosaments on Ill.A. also apply here.
All pipe and fitting material f acluding' safe ends, thermal sleeves, and weld metal should be of a type and grade that has been demonstrated to be highly resistant to osygen-assisted stress corrosion.in the as-Installed condition. Materials that have been so demonstrated include ferrit* ' steels.
" Nuclear Grade" austenttic stainless steels.*
Iypes 304L and 316L austenttic stainless -
steels, Type CF-3 cast stainless steel.
Types CF-8 and CF-8M cast austenttic stainless steel with at least 51 ferrite, Type 308L stainless steel weld metal, and other austenttic stainless steel weld metal with at
'least 55 ferrite content. Unstanlitred 03 wrought austenttic stainless steel without controlled low carbon has not been so demonstrated except when the piping is in the solution-annealed condition. The use of sur material (i.e., regular grades of Types 304 and 316 stainless steels) should be evolded. *
- If such material is used, the as-Installed piping including welds should be in the
- solution-annealed condition. Where regular grades of Types 304 and 316 are used and welding or heat treatment is required, special measures, such as those described in '
Part Ill.C. Processing of Materials, should be taken to ensure that IGSCC will not occur.
Such measures may include (a) solution !
annealing subsequent to the welding or heat treatment, and (b) weld cladding of materials to be welded using procedures that have been demonstrated to reduce residual stresses and sensittration of surface materials.
- These materials have controlled low carbon (0.025 max) and nitrogen (0.15 mas) contents and meet all requirements, including mechanlCal property requirements, of ASME specification for regular grades of Type 304 or 316 stainless steel pipe.
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Ill.A.2. Corrosion-Resistant Sara Ends and Thermal 2, The Comments on Ill.A. also apply here.
Sieeves All unstabilized wrought austenttic stainless steel materials used for safe ends and thermal .
sleeves without controlled low carbon contents (L-grades and fluclear Grade) should be in the sobtlan-annealed condition. if as a consequence of f anrication, welds joining these materials are not solution annealed they should be made between cast (or weld, overlald) austenttic stainless steel surfaces
('.I mieless ferrite) or other materials having high resistance to oxygen-assisted" stress .
- corrosion. The joint design must be such that any high-stress areas in unstabilized wrought austenttic stelnless steel without controlled low carbon content, which may become sensitized as a result of the welding process. * '
is not exposed to the reactor coolant.
Thermal sleeve attachments that are welded to the pressure boundary and form crevices where lapurttles may accumulate should not be exposed to a Sim coolant environment.
III.S. Testing of Materials
- 5. The licensee has not furnished data on this paragraph in his responses to IIRC Generic Letter fst-04.
For new installation, tests should be made on all regular grade stainless steels to be used in the ASME Code Class I, 2, and 3 piping sy:tems to e demonstrate that the material was properly .
annealed and is not susceptible to IGSCC. Tests that have been used to determine the -
susceptibility of IGSCC include Practices A*
and E** of ASIM A-262, " Recommended Practices for Detecting Susceptibility to Intergranular Attack in Stainless Steels
- and the electrochemical ,
potentiokinetic reactivation (EPR) test. The EPR test is not yet accepted by the NRC. If the EPit test is used, the acceptance criteria applied must be evaluated and accepted by the llRC on a case-by-case basis.
- Practice A--Osalic acid etch test for ClassiflCatton of etch structures of stainless steels.
- Practice E--Copper-copper sulfate-sulfuric acid test for detecting susceptibility to intergranular attack in stainless steels.
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s Ill.C. processing of Materials C.
- The licensee has not furnished data on this paragraph In his responses to NRC Generic Letter 81-04 See Corrosion-resistant cladding with a duples comments on part II.C. above.
microstructure (51minlawsferrite)maybeapplied l to the ends of Type 304 or 316 stainless steel pipe for the purpose of avoiding IGSCC at weldsents. Such cladding, which is intended to (a) minimise the HAZ on the pipe inner surf ace.
(b) move the HAZ away from the highly stressed region next to the attachment weld, and (c) isolate the weldment from the environment, may be applied under the following conditions:
Ill.C.I. For initial construction, provised that all of I. Not app]! cable because the plant has be?n Constructed.
the piping is solution innealed af ter cleMing.
III.C.2. For repair welding and modificatalon to 2. Not applicable because the plant has been constructed.
in-place systems in operating plants and t
plants under construction. When the repair welding or modification requires replacement of pipe, the replacement pipe should be solution-annealed af ter cladding -
Corrosion-resistant cladding applied in the
'fleld" (i.e., without subsequent solution annealing of the pipe) is acceptable only on that portion of the pipe that has not been removed from the piping system. Other "fleid" applications of corrosion-resistant cladding are not acceptable.
_ Other processes that have been found by o laboratory tests to alnimise stresses and IGSCC in austenttic stainless steel weldments include induction heating stress improvement *
(INSI) and heat sink welding (NSW). Although the use of these processes as an alternate to
- augmented laservice inspection is not yet accepted by the NRC, these processes may be permissible and will be considered on a -
case-by-case basis provided acceptable supportive data are submitted to the NRC.
IV. INSERVICE INSpfCTION AND LEAK DETECTION REQUIREENIS Mlds UTFTMfTNRrWT5iiFORMANCE TO HATERIAL SELECTION. TE5 TING 3FPEMMDELINES IV.A. For plants whose ASME Code Class ], 2, and 3 A.
pressure boundary piping meets the guidelines of The licensee has not furnished data on this paragraph in his responses to NRC Generic Letter 81-04 part III, no augmented inservice inspection or leak detection requirements beyond those specified in the 10 CFR 50.55a(g), " Inservice Inspection Requirements" and plant Technical Specifications i for leakage detection are necessary.
IV.S. ASME Code Class I and 2 pressure boundary piping 8. The licensee has not furnished data on this paragraph that does not meet guidelines of Part Ill is in his responds to NltC Generic Letter SI-04 designated *llonconforming" and must have additional laservice inspection and more stringent t leak detection requirements. The degree of augmented laservice inspection of such piping depends on whether the specific *llonconforming" piping runs are classified as " Service Sensitive.* The " Service Sensitive" Jines were and will be designated by the NltC and.are defined as those that have experienced cracking of a generic nature, or that are considered to be
- particularly susceptible to cracking because of a 4
combination of high local stress, material condition, and high oxygen content in the relatively stagnant, intermittent, or low-flow coolant. Currently, for the nonconforming ASME Code Class 3 piping, no additional inservice Inspection beyond the Section XI visual .
examination is required. i Examples of piping considered to be " Service Sensitive" include but are not limited to: core spray lines, recirculation riser lines
- recirculation bypass lines (or pipe eatensiras/ stub tubes on plants where the bypass lines e ave been removed), control rod drive (CRD) hydrau <lc return lines, isolation condenser lines, rectr< alation inlet lines at *,afe ends where cr%es are formed by the welded thermal sleeve '
""' attachments, and shutdown heat exchager lines. ,
If cracking should later be found in a particular piping run and considered to be generic, it will be designated by the NitC as " Service Sensitive.'
- Since no IGSCC has been observed in the domestic plants and in view of the possible high radiation exposure to the inspection personnel, surveillance and monitoring means i other than those specified in Section IV of this report for ,
recirculation riser lines will be considered on a case-by-case basis.
Leakage detection and augmented inservice inspection requirements for " Nonconforming" lines and *llonconforming, Service Sensitive" lines are specified below:
IV.8.1. " Nonconforming
- Lines That Are Not " Service 5ensitive" a
d
IV.S.I.c. tsak Detsction: The reactor coolant a. The llCensee nas not furnished date on this paragraph leakage detection systems should be in his responses to NRC Ge.wric Letter 81-04, operated under the lechnical Specification requirements to enhance the discovery of unidentified leakage that may include through-wall cracks developed in austenttic stainless steel piping.
IV.S.I a.(l) The leakage detection system provided (1) SteeWuty should include sufficiently diverse leak detection methods with adequate GPC's description of Hatch I and 2's leak detection sensitivity to detect and measure small methods is not detailed enough to determine whether they leaks in a timely manner and.to identify meet Section C of Regulatory Guide 1.45.
the leakage sources within the practical lletts. Acceptable leakage detection and OlFFERENCES monitoring systems are described in Section C. Regulatory Positlow of The nine subsections of Section C of Regulatory Regulatory Guide 1.45, " Reactor Coolant Guide 1.45 are discussed below.
Pressure Boundary Leakage Detection Systems." C.I GPC has stated that leakage to the primary reaClor ,
containment from identified sources is collected Particular attention should be given to such that -
upgrading and calibrating those leak detection systems that will provide prompt a. the flow rates are mo t indication of an increase in leakage rate. unidentifiedleakage,gegedseparatelyfrom and Other equivalent leakage detection and the total monitored.gI rate can be established and 6.
collection systees will be reviewed on a case-by-case basis.
C.2 It is not clear from the Hatch 2 TechalCal
. Specifications or Hatch I and 2 Final Safety ro Analysis Reports (FSAR) that unidentifled leakage to the primary reactor contaltunent can be i
collected and the flow rate monitored with an accuracy of I gpo or better.
C.3 The Hatch I leak detection systems consist of the following:
- a. Drywell Floor Drain Sump Flow Measurement i
- b. Drywell Eaulpment Drain Sump
! c. Fission Product Monitoring (I) Gross particulates (2) todine (3) Noble gas activities
- d. Drywell Pressure Measurement
- e. Drywell Temperature Measurement.II j
The Hatch 2 leak detection systems consist of the following:
- a. Drywell Floor Drain Sump Flow Measurement
- b. Drywell Equipment Drain Sump
- c. Fission Product Monitoring (1) Particulates
+ *
(2) Gases
- d. Drywell Pressure and Temperature Measurement
- e. RPV Water Level Monitors
- f. Cooling Water Temperature Of fferential at Inlet and Outlet of Primary Containment Equipment Coolers .
- g. Hydrogen and Oxygen Concentration Monitors.I2 The Hatch I and 2 leak detection methods meet those recosamended in Subsection C.3 of Regulatory Guide 1.45.
C.4 It is not clear whether prowlsions have been made C in the Hatch I and 2 FSARs to monitor systems connected to the RCPS for signs of intersystem leakage.
i C.5 It is not clear from the Hatch I and 2 Technical Specifications whether the systems employed for detecting and monitoring untientified leakage can detect a leakage rate, or its equivalent, of I gpa in less than I h.
C.6 It is not clear whether the Hatch I and 2 airborne particulate radioactivity monitoring systems remain functional when subjected to the SSE.
C.7 Indicators and alarms for the required leakage detection system are provided in the main control room. Procedures for converting various
! indications to a common lea available to the operators.gge equivalent are It is not known whether calibration of the indicators accounts for the needed independent variables.
C.8 it is not known whether the Hatch I and 2 leak detection systems enumerated in References 10
- and 11 can be calibrated or tested durtry operation.
4
C.9 Ihe llatch I and 2 Final Safety Analysis Reports include limiting cond unidentified leakage. gigs for identified and .
GPC has identified the availability of the Hatch I and 2 systems for detecting and monitoring leakage. Two cf four systems in Table 3.2-10, Note C of the Hatch 2 Technical Specifications are always available.9 It cannot be determined from the above whether Hatch I and 2 meet all the requirements of Regulatory Guide 1.45, Section C.
AD0lil0NAL DATA REQUIRED
. 1. Indicate whether prowlsions have been made in the Hatch I and 2 FSAR to monitor systems connected to the RCP8 for signs of intersystem leakage (Subsection C.4 of Regulatory Guide 1.45).
- 2. Indicate whether calibration of the indicators accounts for the needed independent verlebles (Subsection C.7 of Regulatory Guide 1.45).
- 3. Indicate whether unidentified leakage to the A primary reactor containment can be detected with a sensitivity of I gpm in less than I h (Subsection C.5 of Regulatory Guide 1.45).
- 4. Fill out the attached table of information regarding the Hatch I and 2 leak detection and monitoring systems (Subsections C.6 and C.8 of Regulatory Guide,1.45).
- 5. Indicate whether,the unidentified leakage to the primary containment in Hatch I and 2 can be collected and the flowrate monitored with an accuracy of I gpa or better (Subsection C.2 of Regulatory Guide 1.45).
IV.8.1.a.(2) Plant shutdown should be initiated for (2) SupetARY Inspection and corrective action when any leakage detection system indicates, within GPC has put the provision for shutdown after a 2-gpm 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 increase in unidentified leakage in 24 h into the Technical in rate of unidentified leakage in excess Specifications for llatch I and 2.
of 2 gallons per minute or its equivalent, or when the total unidentified leakage GPC has not put the prowlsion for monitorin the sump attains a rate of 5 gallons per minute or level at 4-h intervals (or less) into the Hatch ! Technical Its equivalent, whichever occurs first. Spect'ffcations.
For sump level monitoring systems witte Ilued-measurement interval methoo, tr.e DIFFERENCES level snould be monitored at 4-hour intervals or less. NUREG-0313, Rev. I requires that reactor shutdown be infilated A en there is a 2-gpm increase in unidentified leakage in 24 h. For sump level monitoring systems with the fixed-measurement interval method, the level should be monitored every 4 h or less.
GPC has incorporated the prowlsion for shutdown for a
. 2-gpa increase in unidentified leakage Hatch I and 2 Technical Specifications.gn el g4GPC h into hasthe also incorporated a requirement in the Hatch I Technical Specifications to check and record uniden coolant system leakage sources every 4 h.gfled reactor However, G monitorsthesumplevelevery12horlessforHatch2.gC ADDITIONAL DATA REQUIRED
, , Indicate the monitoring interval of the sump level monitoring system for Hatch 2.
IV.B.I.a.(3) Unidentified leakage should. include all (3) GPC's definition of unidentified leakage for Hatch I leakage other than:
and 2 meets NUREG-0313. Rev.1 (f 5AR Section 5.2.7).
IV.S. I .a. ( 3)(a ) Leakage into closed systems, such as (a) The comments on IV.B.I.a.(3) also apply here.
pump seal or valve packing leaks that are captured, flow metered, and conducted to a sump or collecting tank, or I V. B. I . a. ( 3) (b) Leakage into the containment (b) The connents on IV.B.I.a.(3) also apply here.
atmosphere from sources that are both specifically located and known either not to laterfere with the operations m of unidentitled leakage monitoring un '
systems or not to be tros a through-wall crack in the piping within the reactor coolant pressure boundary.
I V. B. I .b. Augmented laservice Inspection: Inservice b. StMMARY inspection of the " Nonconforming, Isonservice Sensitive" lines should be GPC has committed to selecting ASME Code Class I conducted in accordance with the following "nonservice sensitive" pipes per NLMEG-0313 Rev. I except program:* that the high stress welds will be identlfled in the unit stress report. Also, GPC wants to take credit for pas
- Inspections.
- This progree is largely taken from the requirements of ASME Boller & Pressure Vessel Code,Section II, referenced in the GPC has not supplied suf ficient information to paragraph (b) of 10 CFR 50.554, " Codes and Standards." determine whether Hatch I and 2 meet this part of NUREG-0313. Rev.1.
DIFFERENCES NUREG-0313. Rev. I requires that ASME Code Class 1 "nonservice sensitive" pipes be subjected to an augmented 151 program.
GPC has committed to selecting t'he ASME Code Class I pipes for augmented 151 per IIUREG-0313. Rev.1. However, instead of using the selection method prescribed in IIUREG-0313, Rev.1; GPC plans to use the unit stress report for a selection method. GPC also indicated that the SRI will be used for "nonservice sensitive" welds on Hatch Units 1 and {. Finally, GPC wants to take credit for past inspections. -
ADDITIONAL DATA REQUIRED:
Identify the method (s) to select pipes to be inspected per NUREG-0313. Rev. I requirements.
I V.E . I .b. ( l ) For ASME Code Class I components and (1) The cosaments on IV.O.l.b. also apply here, piping. each pressure-retalning dissimilar metal weld subject to inservice inspection requirements of Section Il should be
. examined at least once in no more than 80 months (two-thirds of the time prescribed in the ASME soller and Pressure Vessel Code Section XI). Such examination should include all internal ittachment welds that are not through-wall welds but
.are welded to or form part of,the pressure boundary. .
IV.S.I.b.(2) The following ASft Code Class I pipe welds (2) The comuments on IV.E.I.b. also apply here.
Subject to inservice inspection rsquirements of Section XI should be examined at least once la no more than
- 80 months:
IV.B.I.b.(2)(a) All welds at terminal ends
- of pipe (a) The comuments on IV.B.I.b. also apply here, at vessel norales;
- Terminal ends are the extremities of piping runs that connect to structures, conqueents (such as vessels, pumps, g valves) or pipe anchors, each of which acts as rigid restraints or provides at least two degrees of restraint to piping themel expansion.
- I V'.B. I .O. (2)(b) All welds having a design combined (b) The comuments on IV.B.I.b. also apply here.
Primary plus secondary stress range of 2.45, or more; IV.B.I.b.(2)(c) All welds having a design cumulative (c) The casaments on IV.B.I.b. also apply here.
f atigue usage f actor of 0.4 or more; and I V.5.1.b. (2)(d) Sufficient additional welds with high (d) The Comuments on IV.S.I.b. also apply here.
potential for cracking to make the total equal to 2'J of the welds in each piping system.
I V.S.1.b. ( 3) The following ASME Code Class 2 pipe (3) Sl# MARY welds, subject to inservice inspection requirements of Section XI, in residual GPC has not identified those nonconforming "nonservice heat removal systems, emergency core sensitive ^ pipes *shich are to be inspected per part cooling systems, and contairment heat IV.B.I.b.(3) of NUREG-0313 Rev. 1. Data are neaded to removal systems should be examined at determine whtCh "r.onservlCe sensitive" ASME Code Class 2 ',
least once in no more than 80 months: pipes will be inspected and what inspection procedures will be used.
f
l
- l. *
, DIFFERENCES NUREG-0313. Rev. I requires that nonconforming ASME Code Class 1 and Class 2 piping be subfected to an augmented ISI program. The augmented ISI program for ASME Code Class 1 piping differs from that required on Class 2 p iping. Also, augmented ISI requirements differ for ASME Code Class 2 pipes to be inspected per Parts IV.S.I.b.(3) and IV.B.I b.(4) of NUREG-0313. Rev. l.
GPC has subeltted the augmented ISI progree for nonconforming "nonservice sensitive' piping, but has not distinguished between the ASME Code Class ! and Class 2
. piping, and between the ASME Code Class 2 pipes which are to be inspected per Parts IV.B.I.b.(3) and IV.B.I.b.(4) of NUREG-0313. Rev. I. Therefore GPC's program for ASE Code Class 2 piping cannot be evaluated.
AD0lil0NAL DATA REQUIRED ,
Identify which ASM Code Class 2 pipe will bc inspected per Part IV.S.I.b.(3) and which inspection procedures will, be used.
IV.B.I.b.(3)(a) All welds of the terminal ends of (a) The comments on IV.B.I.b.(3) also apply here.
Pipe at vessel nozzles, and IV.S.I.b.(3)(b) At least 10s of the welds selected (b) The comments on IV.B.I.b.(3) also apply here.
proportionately from the following categories:
m IV.B.I.b.(3)(b)(1) Circumferential welds at (1) The comments osi IV.B.I.b.(3) also apply here.
%s locations where the stresses under the loadings resulting '
from Janplant conditions as calculated by the sum of Equations (g) and (10) in IIC-3652 enceed 0.5 (1.25n + $4 );
IV.S.I b.(3)(b)(ll) Welds at terminal ends of (11) The comments on IV.B.I.b.(3) also apply here.
piping, including branch runs; IV.B.I.b.(3)(b)(lit) Olsstellar metal welds; (Ill)The comments on IV.S.I b.(3) also apply here.
IV.B.I.b.(3)(b)(lv) Welds at structural (iv) The comments on IV.B.I.b.(3) also apply here.
discontinuitles; and
" IV.S.I.b.(3)(b)(v) Welds that cannot be pressure (v) The comments on IV.B.I.b.(3) also apply here.
tested in accore nce with IWC-5000.
4
The welds to be examined shall be distributed approximately equally among runs (or portions of runs) that are essentially stellar in design, sire, system function, and service conditions.
I V.B . I .b. (4 ) The following ASME Code Class 2 pipe (4)~St# MARY welds in systems other than residual heat removal systems, emergency core GPC has not identified those nonconforming "nonservice coollag systems, and containment heat sensitive
- pipes which are to be inspected per Part removal systems, which.are subject to IV.B.I.b.(4) of NUREG-0313, Rev.1. Data are needed to inservice inspection requirements of determine which "nonservice sensitive" ASE Code Class 2 Section XI, should be Inspected at pipes will be inspected and what inspection procedures will least once in no more than 80 months: be used.
DIFFERENCES NUREG-0313. Rev. I requires that nonconforming ASE Code Class I and Class 2 piping be subjected to an augmented ISI program. The augmented 15.1 program for ASE Code .
Class I piping differs from that required on Class 2 p iping. Also, augmented ISI requirements differ for ASE Code Class 2 pipes to be inspected per Parts IV.B.I.b.(3) and IV.B.I.b.(4) of R] REG-0313 Rev.1. ,
GPC has submitted the augmented ISI program for H nonconforming "nzservice sensitive
- piping, but has not 0' distinguished between the ASME Code Class I and Class 2 piping, and between the ASME Code Class 2 pipes which are to be inspected per Futs IV.B.I.b.(3) and IV.B.I.b.(4) of i.
NUREG-0313. Rev.1. Therefore, GPC's program for ASME Code Class 2 piping cannot be evaluated.
ADDITIONAL DATA REQUIRE 0 Identify which ASME Code Class 2 pipe will lee inspected per Part IV.B.I.b.(4) and which inspection procedures will be used.
IV.B.I.b.(4)(a) All welds at locations where the (a) The coments on IV.B.I.b.(4) also apply here.
stresses under the loadings resulting free
- Normal
- and " Upset" plant conditions including the operating a
basis earthquake (OBE) as calculated
- t. by the sum of Equations (9) and (10)
- . In NC-3652 exceed 0.8 (1,.2Sh + SA );
- 6 j IV.S.I.b.(4)(b) All welds at terminal ends of piping. (b)' The comments on IV.B.I.b.(4) also apply here. '
including branch runs; IV.B.I.b.(4)(c) All dissiellar metal welds; (c) The coments on IV.B.I b.(4) also apply here.
i 5
3 IV.B.I.b.(4)(d) Additional welds with high potential (d) The comuments on IV.I.l.b.(4) also apply here.
for cracking at structural discontinulties* such that the total.
number of welds selected for examination equal to 251 of the circumferential welds is each piping system.
- Structural discontinuities include pipe weld joints to vessel non les, valve bodies. pump casings, pipe fittings (such as elbows, tees, reducers, flanges, etc.. sonforming to ANSI Standard B 16.g) and pipe branch connections and fittings.
IV.B.I b.(5) If esamination of (1) (2). (3), and (5) The comuments on IV.B.I.b. also apply here.
(4) above conducted during the first -
80 months reveal no incidence of stress corrosion cracking, the esamination frequency thereaf ter can revert to 120 months as prescribed in Section II of the ASE Boller and Pressure vessel Code.
IV.B.I.b. (6) - Sampling plans other than those (6) The consusts on IV.B.I.b. also apply here.
described in (2) (3), and (4) above will be reviewed on a case-by-case basis.
IV.B.2. " Nonconforming" Lines That are " Service i 5ensitive' I
' 5 IV.B.2.a. Leak Detection: The leatage detection a. The cosaments made in Parts IV.B.I.a.(1) and requirements, described in IV.I.l.a. IV.B.I.a.(2)applyhere, a above, should be laplemented.
IV.B.2.b. Augnented Inservice Inspection: b. $99WtV GPC has committed to s.nlecting ASME Code Class 1
- service sensitive
- pipes per NUREG-0313. Rev. I except that t h high stress welds will be identified in the unit stress report. Also. GpC wants to take credit for past inspections.
GpC has provided an alternative to NUREG-0313, Rev.1.
OlFFERENCES NUREG-0313. Rev. I requires that ASE Code Class I
= service sensitive
- pipes be subjected to an augmented ISI program as outlined in Part IV.B.2.b.
1 9
. - . = . . . - -.
GPC has comaltted to selecting the ASME Code Class I pipes for augmented ISI per huREG-0313. Rev.1. However, instead of using the selection method prescribed in huREG-0313. Rev.1. GPC plans to use the unit stress report for a selection method. GPC also indicated that the SRI will be used for " service sensitive" welds on Hatch Units I and 2. Fina inspections.}ly, GPC wants to take credit for past ADolTIONAL DATA REQUIRED Identify the methods (s) to select pipes to be inspected Per huREG-0313, Rev. I requirements.
IV.B.2.b.(1) The welds and adjoining areas of (1) The comments on IV.B.2.b. also apply here.
bypass piping of the discharge valves in the main recirculation loops, and-of the austenitic stainless steel reactor core spray piping up to and including the second isolation valve, should be examined at each reactor -
refueling outage or at other scheduled plant outages. Successive examination need not be closer than 6 months, if outages occur more frequently than 6 months. This requirement applies to all welds in all bypass lines whether the 4-lach g valve is kept open or closed during _
c operation.
In the event these examinations find the piping free of unacceptable e Indications for three successive inspections, the examination may be .
extended to each 36-month period (plus or minus by as much as 12 months) coincident with a refueling outage. In these cases.
- the successive examination may be llelted to all welds in one bypass pipe run and one reactor core spray piping run. If unacceptable flaw
' indications are detected, the remaining piping runs in each group should be examined.
In the event these 36-month period examinations reveal no unacceptable
'. Indications for three successive inspections, the welds and adjoining areas of these piping runs should be examined as described in IV.B.I.b(1) for dissimilar metal welds and in IV.B.I.b(2) for other welds.
4 o
. )
I IV.S.2.0.(2) ine dissieller metal welds and (2) The Comuments on IV.S.2.b. also apply here.
l adjoinlog areas of other ASME Code
! Class I
- Service Sensitive
- piping should be examined at each reactor refueling outage or at other scheduled plant outages. Sv:cessive examinations need not be closer than 6 months, if outages occur amore
, frequently than 6 months. Such i
examination should include all faternal attachments thgt are flot through-wall welds but are welded to 1
or f orm part of 1'.e pressure boundary.
IV.S.2.b.(3) The welds and adjoining areas of (3) 5tsetARY other ASME Code Class I
- Service Sensitive' piping should be examlaed GPC has classified the recirculation riser piping as using the sanpling plan described in "nonservice sensitive" and will perform the augmented ISI IV.B.1.b(2) except that the f requency per the schedule requirements for "nonservice sensitive" of such examinations should be at piping. ~
t each reactor refueling outage or at F
other scheduled plant outages. GPC has cosmiltted to inspecting SOE of the Successive examinations need not be recirculation inlet norrle thermal sleeve attachment closer than 6 months, if outages (RINTSA) welds at each outage and plans to take credit for occur more frequently than 6 months. past inspections. GPC has provided an alternative to NUREG-0313. Rev.1.
DIFFEpENCES N
" NUREG-0313, Rev I reeutres that all " service sensitive' piping be inspected per an augnented ISI program. Recirculation riser pipes are considered " service sensitive."
GPC has classified the rectrCulatiot' riser piping as l "nonservice sensitive" and will perform the augmented ISI on
' the schedule requirements for "nonservice sensitive" piping. "Nonservice sensitive
- piping has less stringent reeutrements than " service sensitive" piping on the proportion of tge piping to be inspected and the frequency of Inspections.
Hatch I and 2 each have "A" and '8" loop recirculation inlet noriles. Due to the stellar configuration of the "A" and "B" loops, only one of the loops will be examined during each examination interval. However, if unacceptable flaw Indications are detected in one of the RINTSA welds for a given loop, then the other loop will be inspected. Also, GPC piens to take credit for past inspections on the RINISA welds.'
ADDITIDNAL DATA RER! IRED None.
IV.E.2.b.(4) The adjoining areas of Internal (4) The comments on IV.B.2.b. also apply here, attachment welds in recirculation inlet lines at safe ends where crevices are formed by the welded thermal sleeve attachment should be examined at each reactor refueling outage or at other scheduled plant outages. Successive examinations need not be closer than 6 months, if outages occur more frequently than 6 months.
I V. B.2.b. ( 5) In the event the examinations .
(5) The cosaments on IV.B.2.b. also apply here.
described in (2), (3) and (4) above find tw piping free of unacceptable indications for three successive inspections, the examination may be .
entended to each 36-month period (plus or minus by as much as 12 months) coinciding with a refueling outage.
In the event these 36-month period emeelnations reveal no unacceptable indications for three successive inspections, the frequency of examination may revert in 80-month periods (two-thirds the time N prescribed in the ASE Code Section II).
I V.B .2.b. (6) The area, entent, and frequency of (6) SteeWtf emaelnation of the augmented ,
inservice inspection for ASME Code GPC has submitted tte acenented ISI program fc:-
Class 2 " Service Sensitive" lines nonconforming
- service sensitive' piping, but has not will be determined on a case-by-case distinguished between the ASME Code Class I and Class 2 basis. piping. Thtrefore, GPC's program for ASM1 Code Class 2 piping cannot be evaluated without more data.
DIFFERENCES MUREG-0313. Rev. I requires that nonconforming ASME Code Class I and Class 2 piping be subjected to an augmented ISI program. The augmented ISI program for ASME Code Class 1 piping differs from that required on Class 2 piping.
GPC has not identified those nonconforming "servlCe sensitive" pipes which are to be inspected per Part IV.B.2.b.(6) of NUREG-0313, Rev.1.
Data are needed to determine which " service sensitive" ASME Code Class 2 pipes will be inspected and what inspection procedures will be used.
. _ _ . ._ . . _ _ . . . - .~
a ADDITIONAL DATA REQUIRE 0
- 1. Identify which ASE Code Class 2 pipe utll be inspected per Part IV.8.2.b.(6).
- 2. Identify the inspection procedures for " service ,
sensitive" ASelE Code Class 2 pipe.
IV.S.3. Nondestructive Esamination (NDE) Requirements 3, 5tpetutf The method of esamination and volume of material GPC has not supplied a copy of the NDE procedur:s nor to be anamined, the allouasle indication -
given a reference to where a copy of the NOE procedures can standards, and emanination procedures should be obtained. Therefore. GPC's NDE procedures cannot be .
comply with the requirements set forth in the evaluated.
, applicable Edition and Addenda of the ASE Code.
Section II, specified in Paragraph (g). '
OlFFERENCES
- " Inservice Inspection Requirements." of 10 CFR j 50.55a " Codes and Standards." NUREG-0313. Rev. I requires that the NOE procedures meet the applicable Edition and Addenda of the 45NE Code.
In same cases, the code examination procedures Section II, specified in Paragraph (g). " Inservice may not be effective for detecting or evaluating Inspection Requirements" of 10 CFR Part 50.55a. " Codes and IGSCC and other ultrasonic (MT) procedures or Standards." I&E Bulletins 82-03 and 43-02 lepose further advanced nondestructive examination techniques requirements on the NOE procedures. To deterulne whether may be required to detect and evaluate stress the NDE procedures meet the above requirements, lutC corrosion cracking in austenttic stainless steel personnel neea a copy of the specifications for the IIDE i piping, leproved UT procedures have been procedures currently in use at Hatch I and 2 to inspect for developed by certain organlaations. These IG5CC in nonconf:rsing piping.
leproved UT detection and evaluation procedures that have been or can be demonstrated to the IIRC SpC has Indicated those proc to be effective in detecting IG5CC should be for imC I&E personnel to inspect fes are on flie at Match y; used in the laservice inspection.
Recommendations for the development and eventual A00lT10NAL DATA BEQUIRED laplementation of these leproved techniques are included in Part V. 1. A copy of the specifications for the NOE procedures currently used at Hatch I and 2 to inspect for IGSCC in nonconforulag piping.
- 2. Indicate if the above procedures meet I&E Bulletins 82-03 and 83-02.
V. GEIERAL REColeENDATIONS V. The licensee has not furnished data on this paragraph in his responses to NRC Generic Letter 81-04.
The neasures outlined in Part III of this document provide for positive actions that are consistent with current technology. The laplementation of these actions ,
should markedly reduce the susceptittlity of stataless steel piping to stress corrosion cracking in Bluts. It is recugnized that additional means could be used to
. Ilmit the estent of stress corrosion cracting of SWR pressure boundary piping materials and to leprove the overall system lategrity. These include plant design
, and operational procedure considerations to reduce g system esposure to potentially aggressive environment.
. leproved material selection, special f abrication and melding techniques, and provisions for volumetric inspection capability la the design of weld joints. The s use of such means to limit IG5CC or to leprove plant system lategrity will be revleued on a case-by-case l Dails.
p TA8LE FOR QUESTION ON LEAK DETECTION SYSTEMS Control Earthquake Room Iestable Has the Time Required for Wnich Indication During System Been Leak Rate to Achieve Function for Alarms Documentation Normal
- System Incorporated? Sensitivity Sensitivity is Assured and Indicators Reference Operation?
v 1
L
e Td8LE2 SUMMARIES OF EVALUATION OF LICENSEE'S RESPONSES II.C Material Selection, Testing, and Processing Guicalines for BWRs with an Operating License Georgia Power Company (GPC) presently has r.o plans to replace nonconforming " service sensitive" pipe that is not cracked.
GPC has provided an alternative to NUREG-0313, Rev.1.
IV.B.l.a.(1) Leak Detection and Monitoring Systems
.GPC's description of Hatch 1 and 2's leak detection methods is not detailed enough to determine whether they meet Section C of Regulatory Guide 1.45.
IV.B.l.a.(2) Leak Detection Requirements GPC has out the provision for shutdown af ter a 2-gpm increase in unidentified leakage in 24 h into the Technical Specifications for Hatch l'and 2.
GPC has not put the provision for monitoring the sump level at 4-h intervals (or less) into the Hatch 2 Technical Specifications.
IV.8.1.b. Augmented ISI of Nonconforming "Nonservice Sensitive" Pipe GPC has conmiitted to selecting ASME Code Class 1 "nonservice sensitive" pipes per NUREG-0313, Rev. 1 except that the high stress welds will be identified in the unit stress report. Also, GPC wants to take credit for past inspections.
1-ll l:
?
25 i
___._ j l . - _ _ . . _ _ - . _ . . _ . . . . _ -
. - . . ~
1 GPC has not supplied sufficient information to determine whether Hatch I and 2 meet this part of NUREG-0313, Rev.1.
IV.B.1.b.(3) Augmented ISI of Nonconforming "Nonservice Sensitive" ASME Code Class 2 Pipe
, GPC has not identified those nonconforming "nonservice sensitive" pipes which are to be inspected per Part IV.B.I.b.(3) of NUREG-0313, Rev. 1. Data are needed to determine which "nonservice sensitive" ASME Code Class 2 pipes will be inspected and what inspection procedures will be used.
IV.B.I.b.(4) Augmented ISI of Nonconforming "Nonservice Sensitive" ASME Code Class 2 Pipe .
GPC has not identified those nonconforming "'aa** ce sensitive" pipes which are to be inspected per Par' ,4) of NUREG-0313, Rev. 1. Data are needed to determi- nonservice sensitive" ASME Code Class 2 pipes will be , and what inspection procedures will be used.
IV.B.2.b. Augmented ISI of Nonconforming " Service Sensitive" Pipe GPC has committed to selecting ASME Code Class 1 " service sensitive" pipes per NUREG-0313, Rev.1 except that the high stress welds will be identifi'ed in the unit stress report. Also, GPC wants to take credit for past inspections.
GPC has provided an alternative to NUREG-0313, Rev.1.
IV.B.2.b.(3) Welds and Adjoining Areas of ASME Code Class 1 " Service Sensitive" Piping GPC has classified the recirculation riser piping as "nonservice sensitive" and will perform the augmented ISI per the schedule l
i requirements for "nonservice sensitive" piping.
l 26
GPC has conmitted to inspecting 50% of the recirculation inlet ,
nozzle thermal sleeve attachment (RINTSA) welds at each outage and i plans to take credit for past inspections. GPC has provided an alternative to NUREG-0313, Rev.1.
IV.B.2.b.(6) Augmented ISI of Nonconforming " Service Sensitive" ASME Code Class 2 Pipe GPC has submitted the augmented ISI program for nonconfoming
" service sensitive" piping, but has not distinguished between the I, ASME Code Class 1 and Class 2 piping. Therefore, GPC's program for ASME Code Class 2 piping cannot be evaiusted without more data.
)'
IV.B.3. Nondestructive Examination (NDE) Requirements GPC has not supplied a copy of the NDE' procedures nor given a reference to where a copy.of the NDE procedures can be obtained.
Therefore, GPC's NDE procedures cannot be evaluated.
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? 27
- V
. ~.. . . . .
- .. =
TABLE-3
, DIFFERENCES BETWEEN NUREG-0313, REV. 1 AND LICENSEE'S RESPONSES
. II.C Material Selection, Testing, and Processing Guidelines for BWRs with '
an Operating License 4
~
NUREG-0313. Rev. I requires that all NRC-designated " service sensitive" lines be replaced with corrosion-resistant materials to the extent practical. Also, lines that experience cracking should be replaced with corrosion-resistant materials.
4 GPC has stated that they ". . .cannot jystify the indiscriminate replacement of piping that has not shown signs of IGSCC in the Hatch olant. The inspection program described above should identify development of IGSCC in the systems involved. Due to this and the high radiation exposure involved in the replacunent ,,
of the piping, Georgia Power Company does not plan to replace piping that has not shown evidence of IGSCC at Plant Hatch. In the event that repairs or replacement of nonconforming material is required, at such time the affected O wponent will be replaced with confonning material and processed in accordance with
- Section III of NUREG-0313, Rev.1."7 IV.B. l . a. ( 1 ) Leak' Detection and Monitoring Systems The nine subsections of Section C of Regulatory Guide 1.45 are discussed below.
C.1 GPC has stated that leakage to the primary reactor -
containment from identified sources is collected such that
- a. the flow rates are monitored separately from unidentified leakage,10,H and 28
- b. the total flow rate can be established and monitored.10,11 C.2 It is not clear from the Hatch 2 Technical Specifications or Hatch I and 2 Final Safety Analysis Reports (FSAR) that unidentified leakage to the primary reactor containment can be collected and the flow rate monitored with an accuracy of 1 gpm or better.
C.3 The Hatch I leak detection systems consist of the following:
- a. Drywell Floor Drain Sump Flow Measurement
- b. Drywell Equipment Drain Sump
- c. Fission Product Monitoring (1) Gross particulates (2) Iodine (3) Noble gas activities
- d. Drywell Pressure Measurement
, ,e . , 0ry" ell Temperature Measurement.II The Hatch 2 leak detection systems consist of the following:
- a. Drywell Floor Drain Sump Flow Measurement
- b. Drywell Equipment Drain Sump
- c. Fission Product Monitoring -
29
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1 (1) Particulates (2) Gases
- d. Drywell Pressure and Temperature Measurement '
- e. RPV Water Level Monitors
- f. Cooling Water Temperature Differential at Inlet and Outlet of Primary Containment Equipment Coolers 9 Hydrogen and Oxygen Concentration Monitors.12 The Hatch 1 and 2 leak detect. ion g4ethods meet those recommended in Subsection C.3 of Regulatory Guide 1.45.
C.4 It is not clear whether provisions have been made in the Hatch I and 2 FSARs to monitor systems connected to the RCPB for signs of intersystem leakage.
C.5 It is not clear from the Hatch I and 2 Technical Specifications whether the systems employed for detecting and monitoring unidentified leakage can detect a leakage rate, or its equivalent, of I gpm in less than I h.
C.6 Itis not clear whether the Hatch I and 2 airborne particulate radioactivity monitoring systems remain functional when subjected to the SSE.
C.7 Indicators and alarms for the required leakage detection system are provided in the main control room. Procedures for converting various indications to a common leakage equivalent are available to the operators.10 It is not known whether calibration of the indicators accounts for the needed independent variables.
30
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C.8 It is not known whether the Hatch 1 and 2 leak detection :
systems enumerated in References 10 and 11 can be calibrated or tested during operation.
C.9 The Hatch I and 2 Final Safety Analysis Reports include limiting conditions for identified and unidentified leakage.10,11 GPC has identified the availability of the Hatch 1 and 2 systems for detecting and monitoring leakage. Two of four systems in Table 3.2-10, Note C of the Hatch 2 Technical Specifications are always available.9 It cannot be deterinined from the above whether Hatch 1 and 2 meet all the requirements of Regulatory Guide 1.45, Section C.
IV.B. I .a.(2) Leak Detection Requirements NUREG-0313, Rev. I requires that reactor shutdown be initiated when there is a 2-gpm increase in unidentified leakage in 24 h.
For sump level monitoring systems with the fixed-measurement interval method, the level should be monitored every 4 h or less.
- GPC has incorporated the provision for shutdown for a 2-gpm I increase in unidentified-leakage in 24 h into the Hatch I and 2 Technical Specifications.9'I3 GPC has also incorporated a requirement in the Hatch 1 Technical Specifications to check and record unidentified reactor coolant system leakage sources every 4 h.12 However, GPC monitors the sump level every 12 h or less for Hatch 2.9
- IV.8.1.b. Augmented ISI of Nonconforming "Nonservice Sensitive" Pipe NUREG-0313. Rev. I requires that ASME code class 1 "nonservice i sensitive" pipes be subjected to an augmented ISI program.
(- .
31
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l GPC has comitted to selecting the ASME code Class 1 pipes for augmented ISI per NUREG-0313, Rev. 1. However, instead of using the selection method prescribed in NUREG-0313, Rev.1; GPC plans to use the unit stress report for a selection method. GPC also indicated that the SRI will be used for "nonservice sensitive" welds on Hatch Units 1 and 2. Finally, GPC wants to take credit for past inspections.7 IV.B.I.b.(3) Augmented ISI of Nonconforming "Nonservice Sensitive" ASME -
Code Class 2 Pipe NUREG-0313, Rev. I requires that nonconforming ASME Code Class 1 and Class 2 piping be subjected to an augmented ISI program. The augmented ISI program for ASME Code Class,1 piping differs from that required on Class 2 piping. Also, augmented ISI requirements ;
differ for ASME Code Class 2 pipes to be inspected per Parts IV.B.I.b.(3) and IV.B.I.b.(4) of NUREG-0313. Rev.1.
GPC has submitted the augmented ISI program for nonconforming "nonservice sensitive" piping, but has not distinguished between the ASME Code Class 1 and Class 2 piping, and between the ASME Code Class 2 pipes which are to be inspected per Parts -
IV.B.l.b.(3) and IV.8.1.b.(4) of NUREG-0313, Rev. 1. Therefore, GPC's pr.ogram fcr ASME Code Class 2 piping cannot be evaluated.
IV.B.I.b.(4) Augmented ISI for ASME Code Class 1 Pipe Welds with High Potential for Cracking NUREG-0313, Rev. I requires that nonconforming ASME Code Class 1 and Class 2 piping be subjected to an augmented ISI program. The augmented ISI program for ASME Code Class 1 piping differs from that required on Class 2 piping. Also, augmented ISI requirements differ for ASME Code Class 2 pipes to be inspected per Parts IV.B.I.b.(3) and IV.B.I.b.(4) of NUREG-0313, Rev.1.
l 1
32
GPC has submitted the augmented ISI program for nonconforming "nonservice sensitive" piping, but has not distinguished between the ASME Code Class I and Class 2 piping, and between the ASME Code Class 2 pipes which are to be inspected per Parts IV.B.l.b.(3) and IV.8.1.b.(4) of NUREG-0313, Rev. 1. Therefore, GPC's program for ASME Code Class 2 piping cannot be evaluated.
IV.B.2.b. Augmented ISI of Nonconforming " Service Sensitive" Pipe NUREG-0313, Rev. I requires that ASME Code Class 1 " service sensitive" pipes be subjected to an augmented ISI program as outlined in Part IV.8.2.b.
1 GPC has committed to selecting the JUDEE Code Class 1 pipes for augmented ISI per NUREG-0313, Rev.1. However, instead of using the selection method prescribed in NUREG-0313, Rev.1, GPC plans ,
to use the unit stress report for a selection method. GPC also indicated that the SRI will be used for " service sensitive" welds on Hatch Units 1 and 2. Finally, GPC wants to take credit for past inspections.7 IV.B.2.b.(3) Welds and Adjoining Areas of ASME Code Class 1 " Service Sensitive" Piping NURgG-031,3,Rev.Irequiresthatall"servicesensitive"pipingbe inspected per an augmented ISI program. Recirculation riser pipes are considered " service sensitive."
GPC has classified the recirculation riser piping as "nonservice sensitive" and will perform the augmented ISI on the schedule requirements for "nonservice sensitive" piping. " Nonservice sensitive" piping has less stringent requirements than " service sensitive" piping on the proportion of the piping to be inspected and the frequency of inspections.7 Hatch 1 and 2 each have "A" and "B" loop recirculation inlet nozzles. Due to the similar configuration of the "A" and "B" 33
., ,.. , . -y. .,...- , . , - . , , - - . - - , , . -y
loops, only one .of the loops will be examined during each examination interval. However, if unacceptable flaw indications are detected in one of the RINTSA welds for a given loop, then the other loop will be inspecteu. Also, GPC plans to take credit for past inspections on the RINTSA welds.7 IV.B.2.b.(6) Augmented ISI of Nonconforming " Service Sensitive" ASME Code Class 2 Pipe NUREG-0313, Rev. I requires that nonconforming ASME Code Class 1
- and Class 2 piping be subjected to an augmented ISI program. The augmented ISI program for ASME Code Class 1 piping differs from that required on Class 2 piping.
3 GPC has not identified those nonconfoming " service sensitive" pipes which are to be inspected per Part IV.B.2.b.(6) of NUREG-0313, Rev. 1.
Data are needed to detemine which " service sensitive" ASME Code Class 2 pipes will be inspected and what inspection procedures will be used.
IV.8.3. Nondestructive Examination (NDE) Requirements NUREG-0313, Rev. I requires that the NDE procedures meet the applicabh Edition and Addenda of the ASME Code,Section XI, specified in Paragraph (g), " Inservice Inspection Requirements" of 10 CFR Part 50.55a, " Codes and Standards." I&E Bulletins 82-03 and 83-02 impose further requirements on the NDE procedures. To determine whether the NDE procedures meet the above requirements, NRC personnel need a copy of the specifications for the NDE procedures currently in use at Hatch I and 2 to inspect for IGSCC in nonconforming piping.
GPC has indicated those procedures are on file at Hatch for NRC I&E personnel to inspect.8 34 4
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TABLE 4 ADDITIONAL DATA REQUIRED OF LICENSEE II.C Material Selection, Testing, and Processing Guidelines for BWRs with an Operating License None.
IV.B.1.a.(1) Leak Detection and Monitoring Systems
- 1. Indicate whether provisions have been made in the Hatch I and 2 FSAR to monitor systems connected to the RCPB for signs of intersystem leakage (Subsection C.4 of Regulatory Guide 1.45).
- 2. Indicate whether calibration of the indicators accounts for the needed independent variables (Subsection C.7 of Regulatory Guide 1.45).
- 3. Indicate whether unidentified leakage to the primary reactor containment can be detected with a sensitivity of I gpm in less than I h (Subsection C.5 of Regulatory Guide 1.45).
- 4. Fill out the attached table of information regarding the
.. Hatch I and 2 leak detection and monitoring systems (Subsections C.6 and C.8 of Regulatory Guide 1.45).
- 5. Indicate whether the unidentified leakage to the primary containment in Hatch I and 2 can be collected and the flow rate monitored with an accuracy of 1 gpm or better (Subsection C.2 of Regulatory Guide 1.45).
35 L
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- 2. Identify the inspection procedures for " service sensitive" ASME Code Class 2 pipe.
IV.8.3. Nondestructive Examination (NDE) Requirements
- 1. A copy of the specifications for the fl0E procedures currently used at Hatch I and 2 to inspect for IGSCC in nonconforming piping.
- . 2. Indicate if the above procedures meet I&E Bulletins 82-03 and 83-02.
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in en u.s. Noctsan acGut4TOnv COMam8stON e
"GG-FM-6252 BIBLIOGRAPHIC DATA SHEET 4 TlTLE AND SUBTITLE 2.(L,. ,e,,,ep TECHNICAL EVALUATION OF INTEGRITY OF THE HATCH I & 2 REACTOR COOLANT BOUNDARY PIPING SYSTEM 3. RECIPIENT'S ACCESSION NO.
i 7 AUTHORISI 5. DATE REPORT COMPLETED P. K. Nagata July I " *" 1983
- 9. PE r*ORMsNG ORGANIZATION NAME AND MAILING ADDRESS Itachter Iw Coars DATE REPORT ISSUED amoes tw July lvena
- 1983 EG&G Idaho, Inc. ,,t,,,,,,,
Idaho Falls, ID 83415
- 8. / Leave meal
- 12. SPONSORING ORGANIZATION NAME AND MAIUNG ADORESS isacewar le Coart Division of Licensing Office of Nuclear Reactor Regulation it, pin uo.
U.S. Nuclear Regulatory Commission Washington, DC 20555 A6429 t3. TYPE OF REPORT assioo covgaso tsacesive aserst 15 SUPPLEMENTARY NOTES 14 fu ane oratet 16 ABSTR ACT 000 woras or east i
, 17 EEY WORDS AND DOCUMENT ANALYSIS 17e DESCRIPTORS 17tk IDENTIFIERS /OPEN-ENDE D TERMS IS AV AILASILITY STATEMENT 19 SE CURITY CL ASS tra,s reoorri 2t NO OF PAGES Unclassified yn] jmj gg 20. SEcualTY CL ASS IT*,s seers 22 P9sCE Unclassified s ac reau us in .',