ML20091L568

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Responds to Generic Ltr 84-11 Re Addl Insp & Leakage Monitoring Requirements Resulting from IGSCC in Large Diameter Recirculation & RHR Sys Piping
ML20091L568
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 06/04/1984
From: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
GL-84-11, NUDOCS 8406080111
Download: ML20091L568 (11)
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Text

{{#Wiki_filter:_ PHILADELPHIA ELECTRIC COMPANY l 2301 MARKET STREET P.O'. BOX 8699 PHILADELPHI A. PA.19101 12151841-4000 June 4, 1984 Docket Nos. 50-277 50-278 Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

Generic Letter 84-11, " Inspections of BWR Stainless Steel Piping"

Dear Mr. Eisenhut:

The subject Generic Letter dated April 19, 1984, requires Philadelphia Electric Company's response for additional inspection and leakage monitoring requirements as a result of intergranular stress corrosion cracking (IGSCC) in large diameter recirculation and residual heat removal systems piping. Actions requitad in accordance with the Generic Letter are as restated below along with our response for Peach Bottom Units 2 and 3. Unit 2 (a) Scope and schedule of planned inspections Rgsponse On March 6, 1984, Philadelphia Electric Company submitted plans for recirculation and residual heat removal (RHR) system piping replacement (S. L. Daltroff, PECo, to J. F. S tolz, USNRC, letter). The outage to perform this work is in progress, having started on April 28, 1984. The scope of the modification is to replace the entire recirculation system, the RHR shutdown cooling piping out to, but not including penetrations, c portion of the RHR head spray piping and the reactor water cleanup (RWCU) penetration and a portion of its piping outside containment with Type 316 (controlled chemistry) stainless steel having low carbon (0.024 max) and nitrogen (0.1% max) content. The RWCU an .MM 8406080111 840604 DR ADOCK 03000 [-

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t*.. . Mr.~Darrell G. Eisenhut June 4, 1984 Page 2 portions of the core spray piping inside containment have previously been replaced with Type 316L stainless steel. The new piping conforms to the guidelines stated in Part III of NUREG-0313, Rev. 1, for corrosion resistant material. Therefore, in accordance with Part IV A of NUREG-0313, Rev. 21, no; augmented inservice inspection beyond the requirements of 10 CPR 50.55a (g), Inservice Inspection Requirements (ISI), will be required subsequent to these piping modifications. Future inspections after performance of baseline UT examinations following modifications will be performed in accordance with the second 120-month ISI program'for Peach Bottom Unit 2. - Unit 3 (a) Scope and schedule.of planned inspections.

Response

The reinspections specified below will be performed during the.next Unit'3 refueling outage currently scheduled to begin March 30, 1985. Recirculation'and RHR system inspections were previously performed during the summer of 1983. Based on results of those inspections, the scope of the reinspections is as follows in accordance with items 2a through 2e of the Generic Letter. Attachments 1 and 2 depict the Unit 3 Recirculation and RHR System. (1)- '20% of non-conforming welds in each pipe size not i . prev ously inspected -Recirculation, System e 12-inch" risers - All non-conforming welds were previously idspected. Therefore, no riser welds will be reinspected during the_next

outage, e'

22-inch manifold'- Two. welds were not' inspected previously. These-two welds, 2-BM-2 and 2-BM-3 will-be inspected'during.the next: outage. 6 s 1 4 - ,2

2 -- MA. Darrell G. Eisenhut June 4, 1984 Page 3 e 28-inch discharge and suction - Eight welds were not inspected previously. The following welds will be inspected during the next outage: 2-AS-9 2-AD-13 2-BS-8 2-BD-16 [ RHR System 4 e~ inch return - Two welds were not inspected -previously. Welds 10-1A-2 and 10-1B-2 are not inspectable due to their configuration and cannot be inspected during the next outage. (2) 20% of.non-conforming welds in each pipe size inspected. previously with no indications: 4 Recirculation System e 12-inch.' risers - Thirty welds previously inspected had no indications. The following welds will be inspected during the next outage: 2-AHK-1 2-BHE 2-AHH-1 2-BHC-1 i AHF-3 2-BHA-3 e- ^22-inch manifold -- Eight welds previously inspected'had.no indications. 4' The following welds will be -inspected during.the.next outage: 2-BM-4' l. 2-AM-S 28-inch disch'arge.and suction _ Twenty-five welds o e ~previously inspected.hadino. I indications. The'following b welds.will be' inspected'during. the nextLoutage: U m. - 4 ,,m 4,_

. Mr. J Darreil l3.. Eisenhut June 4, 1984 Page 4 w 2-AS-5 2-BS-6 2-AD-17 2-BD-15 2-BS-4 RHR, System e 20-inch suction - Ten welds were previously inspected with no indications. The following welds will be inspected during the next outage: 10-0-3 10-0-12 e 24-inch return - Nineteen welds were previously inspected with no indications. The following welds will be inspected during the next outage: 10-1A-7 10-1B-4 t 10-1A-10 10-1B-ll )- (3) All unrepaired cracked welds All welds with crack indications were weld overlay repaired during the Summer 1983-outage. Therefore, since'there are no known'unrepaired weld locations 'with indications, this-item is not applicable. (4) Inspection of all weld overlays where circumferential cracks longer than 10% of circumference were measured. All crack indications in the 12-inch risers were axial =in configuration. All crack indications in ~ it 'the RHR system were circumferential in configu' ration'with indications' greater than 10%:of the circumference.- Therefore, the following welds will be inspected;during theinext outage: 10-0-5 10-0-6 0-7 j 10-0-10 10-1-15 1 l

(5)

LWelds previously treated by Induction Heating Stress Improvement (IHSI) that had not been UT. acceptance Jtested.. l F' 1 "?: .l s

s t .I; M'r. Darrell G. Eisenhut ~ June 4, 1984 Page 5 A. total of-ninety-one welds in the recirculation and RHR systems were IHSI treated and all of these welds have had_ post ~ treatment UT inspections . performed.. Therefore, no IHSI treated welds will be reinspected during the next outage. x. -(6) If;during the reinspections to be performed as indicated above, new cracks or significant growth of old cracks are. detected, as defined in the generic letter, the scope of inspections will be expanded for the size of the pipe in which cracks were found in accordance with I.E. Bulletin 83-02. Unit'2 (b). Availability and qualification of examiners. Response' Southwest'Research Institute is under contract by

Philadelphia Electric Company to perform the UT inspections as part of Peach Bottom Unit 2 Inservice Inspections.

Southwest-Research Institute personnel are available on an as-needed basis. As discussed in Philadelphia Electric Company's response to.I.E. Bulletin 83-02, S._ L..Daltroff' . (PECo) to Dr. T. E.-Murley (NRC), " Supplement to Peach ~ Bottom Unit 2 Response to I.E. Bulletin No. 83-02", dated October. 19,.1983, Southwest Research Institute validated their UT detection capability in accordance with the requirements-of Action-Item 1 of I.E. Bulletin 83-02 at the EPRI NDE Center on April 14 and 15,'1983. Unit 3 -(b)-. Availability _and qualification of examiners. l l Response Southwest Research Institute'is under contract by

Philadelphia Electric Company to perform the UT inspections as'part of' Peach
Bottom Unit 3 Inservice Inspections.

Southwest Research' Institute personnel are available on an as-needed basis.- As discussed in Philadelphia Electric ' Company's' response to I. E. Bulletin 83-02,'S. L.-Daltroff- '(PECo)- to Dr.ST. E. - Murley - (NRC), " Peach Bottom Unit 3 o 0: . Response to:I.E.' Bulletin No. 83-02", dated August 9, 1983,- J s_ Southwest'Research-Institute validated their UT detection m,

capability in accordance'with the requirements of' Action Item'l of I.E. Bulletin: 83-02 at'the EPRI NDE Center on 3

-AprilM14 and'15,"1983. J ~ m

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u-2%. i cf PMr..Darrell"G7 Eisenhut June 4, 1984 Page 6 l jgnit_2o '(c) Description.of any special surveillance measures, in effect or proposed, for~ primary system leak detection, beyond those 7, measures already required by your Technical Specifications. Response'- Philadelphia Electric Company, to assure the safe operation of. Peach Bottom Unit 2 and to provide for the detection of small primary system leakage, has implemented an additional surveillance. measure for primary system leak detection. This system consists of moisture detection devices placed on -five weldolet to pipe welds not examined due to configuration and.two valve to penetration welds unexaminable due to configuatrion. In addition, five additional welds were instrumented with Moisture Detection Devices. These welds were discovered to contain circumferential indications during UT examination, but these indications were determined to be acceptable for full power operation until the current-outage, which began on April 28, 1984. This system is described in detail in Attachment G, " Identification of Placement of Leak Detection Devices and' Monitoring of These Devices to Assure. Safe Operation of i Plant", of the October 19, 1983, letter response, S. L. Daltroff (PECo) - to Dr. T. E. Murley (NRC), " Supplement to Peach Bottom Unit 2 Response to I.E. Bulletin No. 83-02." In addition,.as discussed in Philadelphia Electric Company's letter response of September 15, 198 3, J. S. Kemper (PECo) to Dr. T. E. Murley - (NRC), " Peach Bottom Unit 2 Response-to I.E. Bulletin No. 83-02", Philadelphia Electric. Company will - report all moisture. detection system problemsLand alarms unrelated to actual leakage on a 30-day basis. This-moisture detection system is used for the detection of-small primary system leakage. A decision as-to the extent of the use of moisture detection devices following the Unit 2 pipe replacement has not yet' been made.. The need for such devices is currently,being studied. Unit 3 (c). Descript(on of any special surveillance measures,~in effect or' proposed, for primary system' leak detection, beyond'those - measures already. required by your Technical Specifications. . Response Philadelphia Electric Company, to assure the safe operation- ~ of Peach Bottom Unit 3 and to provide for1thefdetection of: s

JE. Nh. Darrell G. Eisenhut June 4, 1984 Page 7 small primary system' leakage, has implemented an additional surveillance measure. This system consists of moisture detection devices placed on three welds in the RWCU system .that -were not examined. In addition, all fifteen welds repaired during the 1983-refuel outage, five weldolet to pipe welds not examined due to configuration, ten welds not examined because they were in high radiation areas and two isolatable welds, one each in both the "A" and "B" residual heat removal return penetration. These moisture detectors are part of a system operated as stated in Attachment III to the May. 23,_1983, letter, S. L. Daltroff (PECo) to D. G. Eisenhut per' letter response of September 15, 1983, J. S. Kemper (PECo) to D r. T. E. Mu rley - (NRC), " Peach Bottom Unit 2 Response to I.E. Bulletin No. 83-02. This system is further described in detail in the'previously mentioned Attachment G to " Supplement to Peach Bottom Unit 2 response to I.E. Bulletin No. 83-02", dated October 19, 1983. Any - problems and. alarms in the Unit 3 moisture detection system-unrelated to= actual leakage will be reported on a 30-day basis. After the planned inspections, as described above during the next outage on Unit 3, the locations of the existing moisture detection devices will be re-evaluated and adjusted as necessary. Unit 2 _ (d) JResults of the Bulletin inspections not previously submitted ,to the NRC..

Response

Philadelphia. Electric' Company's letter response of February 21,.1984, S. L. Daltroff (PECo) to Dr. T. E. Murley -(NRC), ' " Supplement IV to Peach Bottom Unit 2 Response to I.E. Bulletin-No.'83-02",,' completed Philadelphia Electric . Company's Unit.2: response to the NRC pertaining to I.E. Bulletin No. 83-02. - Unit 3' (d) Results of:thel Bulletin' inspections not previously submitted ~ 1 to.the NRC. 1 Response; i Philadelphia. Electric Company's letter response of August 30,11983,. S. E Daltroff - (PECo) to.Dr. T. E. Murley (NRC), " Supplement;II to Peach Botton Unit 3 Response to I.E. LBulletin No. 83-02", completed Philadelphia Electric v r

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'Mr. Darrell G. Eisenhut June 4, 1984 Page 8 Company's Peach Bottom Unit 3 response to the NRC pertaining to'I.E.. Bulletin No. 83-02. Unit-2 (e) Remedial measure, if any, to be taken when cracks are discovered.- E88Eonse As described in response to item (a) above, piping susceptible to IGSCC is being replaced during the current outage. Unit'3 (e) -Remedial measures, if any, to be taken when cracks are discovered: gesponse As stated in response to (a), if new cracks or significant growth of old cracks are found, the scope of inspections will be expanded in accordance with I.E. Bulletin 83-02. Any new crack indications will be evaluated and analyzed for further operation and/or repaired as required on a case-by-case basis. Crack evaluations will be performed in ..accordance with section IWB 3600 of Section XI of the ASME -Boiler'and Pressure Vessel Code. Very truly yours, 0 / / cc:. A. R. Blough, Site Inspector [ Y

p COMMONWEALTH OF PENNSYLVANIA :

ss. COUNTY OF PHILADELPHIA S. L'. Daltroff, being first duly sworn, deposes and says: Taat he is vice President of Philadelphia Electric Companyt that he has read the foregoing response to Generic Letter 84-11 and knows the' contents thereof; and that the statements and matters set forth the rein are true and correct to the best of his knowledge, information and belief. ~ ) // ) ,Eli W-__ ___f, _c,d Subscribed and sworn to-VL before me this Y day %v&-,,'l9?Y of idisse__.c_WY -f Notary Public PATRICIA A. JONES Notary Public, F.iita., Pnila. Co. My Commiss6on Empires Oct.13,1986

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