ML20093A576

Technical Evaluation of Integrity of Pilgrim Nuclear Power Station Unit 1 Reactor Coolant Boundary Piping Sys

ML20093A576
Person / Time
Site:	Pilgrim
Issue date:	08/31/1983
From:	Nagata P EG&G, INC.
To:	Koo W Office of Nuclear Reactor Regulation
Shared Package
ML20093A570	List: ML20093A576
References
CON-FIN-A-6429, RTR-NUREG-0313, RTR-NUREG-313 EGG-FM-6257, TAC-46673, NUDOCS 8407100655
Download: ML20093A576 (47)

Text

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EGG-FM-625.7 August 19c3-l l

TECHNICAL EVALUATION OF INTEGRITY OF THE PILGRIM NUCLEAR POWER STATION UNIT 1 REACTOR COOLANT BOUNDARY PIPING SYSTEM Peter K. Nagata Idaho National Engineering Laboratory Operatt.d by the U.S. Department of Energy 3.- ? '.; f 7f:tT 'n

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This is an informal report intended for use as a preliminary or working document 8407100655 840620 PDR ADOCK 05000293 p

PDR Pre ared for the U,[, NUCLEAR.REGULATORYCOMMISSION y

E G E G ioano Under 00E Contract No. OE-AC07-76ID0lS70

EGG-FM-6257 TECHNICAL EVALUATION OF INTEGRITY OF THE PILGRIM NUCLEAR POWER STATION UNIT 1 REACTOR COOLANT BOUNDARY PIPING SYSTEM i

Published August 1983 Peter K. Nagatu Materials Engineering Branch Materials Sciences Division EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Responsible NRC Individual and Division:

W. H. Koo/ Division of Engineering Docket No.: 50-293

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TAC No.: 46673 Prepared for the U.S. Nuclear Regulatory Commission Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6429

ABSTRACT NUREG-0313, Rev.1, Technical Resort on Material Selection and Processing Guidelines for dWR Coolant Pressure douncary Plaing, is tne NRC starf's reviseo acceptaole metnoas to reouce intergranular stress corrosion cracking in boiling water reactors. The responses to NRC Generic Letter 81-04 of the Boston Edison Company concerning wnetner its Pilgrim Nuclear Power Station Unit 1 meets of NUREG-0313, Rev. I are evaluatea by EG&G Idaho, Inc. in this report. Particular attention was given tne leak cetection systems described in Regulatory Guide 1.45, Reactor Coolant Pressure Boundary Leak Detection Systems, referenced by Parts IV.S. I.a.(1) ano (2) founo on pages I anc o of NUREG-0313, Rev.1.

FOREWORD This report is supplied as part of the Selected Operating Reactor Issues Program being concuctea for the U.S. Nuclear Regulatory Commission, 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, 8&R 20 19 10 11.

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SUMMARY

NUREG-0313, Rev.1, Technical Reoort on Material Selection and Processing Guidelines for 8WR Coolant Pressure 80unoary Fioing, is the NRC staff's reviseo acceptaole metnoos to reouce intergranular stress corrosion cracking in boiling water reactors. The responses to NRC Generic Letter 81-04 of the Boston Edison Company concerning whether its Pilgrim Nuclear Power Station Unit I meets of NUREG-0313, Rev. 1 are evaluated by EG&G Idaho, Inc. in this report. Particular attention was given the leak i

detection systems described in Regulatory Guide 1.45, Reactor Coolant Pressure Boundary Leak Detection Systems, referenced by Parts IV.8.1.a.(1) ano (4) found on pages / ano s of auxts-0313, Rev. 1.

As may be observed in the following table, Pilgrim Nuclear Power

' Station Unit I does not meet any of the parts of NUREG-0313, Rev.1 evaluated in this document.

The following table is a synopsis of the EG&G Idaho, Inc. evaluation of Boston Edison Company's response to NRC Generic Letter 81-04.

i Additional Part of NUREG-0313, Data b

Rev.1 Evaluated Evaluation

• Recuired Discrepancy Section II.

II.C.

Provides alternative to Yes Minor i,

NUREG-0313, Rev. 1 Section III.

Section IV.

i IV.S.

Provides alternative to No Minor NUREG-0313, Rev. 1 IV.S. I. a. ( 1)

Provides alternative to Yes Major NUREG-0313, Rev. 1 IV.S.I.a.(2)

Does not meet NUREG-0313, No Major Rev. I IV.S.I.b.

Provides alternative to No Minor 4

NUREG-0313, Rev. 1 l

IV.B.1.b.(3)

Did not provide data in Yes Minor

+

response to NRC Generic Letter 81-04 i

IV.B.1.b.(4)

Did not provide data in Yes

. Minor i

response to NRC Generic Letter 81-04 iii i

l

Additional Data Part of NUREG-0313, 8

Rev. 1 Evaluated Evaluation Reouired Discrepancy IV.B.2.a.

The comments for Parts IV.S.I.a.(1) and IV.S.I.a (2) apply here.

IV.B.2.b.

Provides alternative to No Minur NUREG-0313, Rev. 1 IV.B.2.b.(6)

Did not provide data in Yes Minor response to NRC Generic Letter 81-04 Section V.

aSee Tables 1 and 3 for additional infonnation.

bSee Tables 1 and 4 for additional information.

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CONTENTS AB ST R AC T..............................................................

11

SUMMARY

111 1

1 1.

I N TR O D UC T ION.....................................................

1 2.

EVALUATION.......................................................

4

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2.1 NUREG-0313, R ev. t Gui de l ines..............................

4 2.2 Olscussion of Tables.......................................

4

'2. 3 Discrepancies..............................................

5 3.

C O NC L US I O N S......................................................

6 4.

R E F ER E NC E S.......................................................

40 TABLES 1.

Review of Licensee's Response to NRC Generic Letter 81-04........

7 2.

Summaries of Evaluation of Licensee's Responses..................

26 3.

Differences between NUREG-0313 Rev. I and Lic Responses.....................,...............ensee's 29 4

Additional Data Requi red of Licensee.............................

37 i

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V

TECHNICAL EVALUATION OF INTEGRITY CF THE PILGRIM NUCLEAR POWER STATION UNIT l' REACTOR COOLANT BOUNDARY PIPING SYSTEM 4

1.

INTRODUCTION Intergranular stress corrosion cracking (IGSCC) of austenitic stainless steel (SS) piping has been observed in boiling water reactors f

(8WRs) since Decemoer 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 Evaluation of Cracking in Austenitic Stainless Steel Piping of Boiling Water Reactors 3 and an implementation document, NUREG-0313, Rev. 0.d After cracking in large-diameter piping was discovered for the first time in the Ouane Arnold BWR in 1978, a new PCSG was formed. The new PCSG in turn issued two 2

reports, NUREG-0531, Investigation and Evaluation of Stress-Corrosion Cracking in Piping of L'ight Water Reactor Plants 4 and NUREG-0313, Rev. 1 Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping.5 NUREG-0313, Rev. 1 is the implementing document of NUREG-0531 and discusses tne augmented inservice inspection (ISI) and leak detection requirements "for plants that cannot comply with the material selection, testing, and processing guidelines" of I

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.1.0 i

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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1 In response to NRC Generic Letter 81-04, Boston Edison Company submitted a letter on July 8, 1981.7 A request for information from tne NRC staff elicited another letter from Boston Edison Comp'any on May 20, 1983.8 EG4G Idano personnel evaluated these responses, and this report provides:

1 1.

A brief summary of the Ifcensee's response to each part of NUREG-0313, i

Rev. 1.

i 2.

A discussion of areas where the licensee does not meet the guidelines or requirements of NUREG-0313, Rev. 1.8 3.

A brief discussion of the licensee's proposed alternatives to NUREG-0313, Rev. 1; however, no determination of acceptability is made on these alternatives.

4.

An identification of all areas where the licensee has not provided sufficient information to judge the licensee's program.

There is an effort underway to revisa NUREG-0313, Rev. I by NRC in 1

lignt 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. I, Sections IV.B.I.(a)(1) and IV.B.I.(a)(2).

I 2.

The acceptability of licensee-proposed augmented inservice inspection (ISI) sampling criteria.

I a.

Part III of NUREG-0313, Rev. I contains guidelines; Part IV contains requirements.

2

i 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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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. I guidelines are found in Parts III and V and the requirements in Parts II and IV of that document. 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 inservice inspection requirements of nonconfonning (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 througn 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 tne licensee'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 cancents below will be used.

Not applicable because the construction permit for this plant o

has been issaed.

Not applicable because the operating license for this plant has o

been issued.

o Not applicable because the plant has been constructed.

4

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 sunnaries 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 I 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.

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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 ilsted in the Conclusions section.

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3.

CONCLUSIONS Boston Edison's Pilgrim auclear Power Station plant n'as the following major discrepancies:

IV.B.I.a.(1) Leak Detection and Monitoring Systems BECO's description of Pilgrim l's leak detection methods indicates they do not meet Section C of Regulatory Guide 1.45.

IV.B.1.a.(2) Leak Detection Requirements BECo has not proposed a requirement for shutdown af ter a 2-gpm increase in unidentified leakage in 24 h into the Technical Specifications for Pilgrim 1.

BECo has not proposed a requirement for monitoring the sump level at 4-h intervals (or less).

BECo does not meet NUREG-0313, Rev.1 in this matter.

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 suoplied sufficient information to evaluate his responses to topic II.C., IV.8.1.a.(1), IV.8.1.b.(3), IV.8.1.b.(4),

IV.8.2.a., and IV.8.2.b.(6).

Table 4 lists the required information for each topic.

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Rf Wife OF LICtIntE'S RESPue5C Id leWC GlutRIC Lillia 81-04 facerpts from deta(fG-0313. Nev. I EG&G Idaho Evaluat tun--Pilgrim souclear Stat tun limit. I II.

lHPitMf mIAlluss OF st4IIRIAL SitFCTiuse. IESIIIeG, Assu PiitflT51mG GuluttimES li.A.

For plants under review, but for weilch a A.

Ilot applicable tecause the constructfun permit f or this construction permit has not been issued, all A5ME plant has been issued.

Code Class I, 2, and 3 lines should conform to the guidelines stated in Part lit.

II.B.

For pleets that have been issued a construction u.

Ilot applicable leecause the operating license for this permit inat not ase operating license, all ASME Code plant has leeen issued.

Class I, 2, and 3 lines should conform to the guidelines stated in Part Ill unless it can be demonstrated to the staf f that iglementing the guidelines of Part fit would result in undue hardship. For cases in which the guidelines of Part til are not coglied with, additional measures should be taken for Class I and 2 lines in accordance with the guidelines stated in Part IV of this document.

N ll.C.

For plants that have been issued an operating C.

SupetAkt license, misc designated *5ervice Sensitive" lines (Part IV. 8) should her audifled to conferin to the Boston Edison Company (8400) is not planning to replace guidelines stated in Part lit, to the eatent nonconf orming " service sensitive

• lines at Pilgrim, but is prac t ic able. hel.en " Service Sensitive" and ottier evaluatteng laduction heatisus stress improveement ased local Class I asui 2 lines do not meet the guidelines of sink welding to reduce the possibility of IGSCC. htLo has Part III, additional measures should be taken in presented an alternative tu seuR(G-oJI), Rev. 1.

accordarece with the guidelines stated in Part IV of this drument. Lines that esperience crackisig OlFFt REIEE S during service and require replacement should be replaced witte piping that Conforms to the IIidt[G-0313, New. I requires Lt.J1 INIC-designated guidelines stated in Part Ill.

nonconforming " service sensitive" lines be replaced ulth corrosion-resistant materials to the entent practical.

Also, lines that emperlesece cracting should be replued with corrosion-resistasit materials.

1. fCo is not planning to replue nunconfusming " service sensitive

• lines. Instead 810u is evaluating induct ion heating stress ig rovement (18151) and heat sink welJing (il5W) to reduce the possibility of lGS8.C.

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AtuilluNAt DAIApfgulR]

1.

Isidkete waikk nonconforming

• service sensitive' piping mill be subjected to 18 51 ased itSW.

7 Supply the specifications f or ts.e 18t51 asal il5W processes proposed to t.eing used.

Ill. 54estARY Of ALCIPIASA E M[Il1005 to MimlMilf CAACK 5NfP it t ifflizisilf R ift' EfITCHeisDf 5TI O Pedff551faC'ColMflES-

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lil.A. Selection of Materials A.

The licensee has not f urnished data on this paregs apse in his responses to autC Generic tetter 81-04. See 0.aly those materials descrisad in Parayapsis I cammment on Part II.C. anove.

and 2 below are acceptable to the IIRC lor installation in Samt A9tf Code Class I, ?, and 3 piping systems. Other materials may be used when evaluated ased accepted or the autC.

Ill.4.3. Corrostose-Nesistant Materials I.

The cdmarats on Ill. A. also apply eiere.

All pipe ased fitting saterial including safe esses, thermal sleeves, and meld e=tal should me of a type and grade that has been desanastrated to be eilghly resistas.t to onygen-assisted stress corrosion in the og as-installed casedilloss. Materials that have been so skmunstrated eseclude ferritic steels.

• huclear Grade" austenttic stainless steels.*

Iypes 304L and 316L aisstenitic stainless steels. Iype U-3 cast stainless steel.

Iypes CF-8 ased (F-ast cast austenitic stataless steel with at least 55 ferrite, lype 308L stelnless steel iseld metal, asad other austenttic stainless steel weld metal with at least W ferrite content. thistabillied wrueght austematic stainless steel without cuestrolled low carbuse has snot t.een 50 demuistrated encept when the piping is in tsie solutlose-annealed cosadition. Ihe esse of suc8:

material (i.e., regular grades sif lypes 304 and 316 stainless steels) should be avoided.

If sucts material is used, the as. installed p6 ping including welJs shemsid see in the solutleue-annealed tandittom. Where regular grades of lypes 304 and 316 are used and melding or heat treatneset is required, special measures, such as thuse ileste lhed in Part lit.L., Praxessiseg of Materials, should be

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taken to essere that IGSCC will not occur.

Sesch measures may include (a) solut ton

.ammeelleg tusseguent to the merldlag or heat treateret and (t) ogle Claddlag GI Saterials to be melded uslag procedures that hawr been deemmestrated to redem e residual stresses and sensittrat een of surf ace saaterials.

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• Inese materials nave centrolled low carten (0.021 eaa) and altrugen (e.it maa) contents and amet all requirements.

lec tuusag archemical property requirements, of ASSE i

spec 6iitatten ior reguler grasses oi lype 304 or j

Jie stainlass steel pipe.

Ill.A.t. Corresten-Resistant Sete Ends and Ineraal 2.

Ine comments un Ill.A.~ also apply here.

Sleeves All unstaellised wrought sesstenttic stataless steel meterials used for safe ends and thermal 1

l sleeves witnant centrolled law carton centents (L-grades and Ibsclear Grade) shoesid be la the seletion-ammeeled conditlen. If as a conseepsence of f abrication welds jelalog these materials are not seletten annealed, i

Eney should te made metaseen cast (or meld to overteld) austenttic stainless steel surfaces (55 eleimum ferrite) er other materials navlag nigh resistance to esygen-assisted stress corresten. Ine je6mt design must te such that j

any hlgn-stress areas la enstabillied wreesent i

austenttic stataless steel witneest controlled les carbon centent, mailcn may became sensitised as a result of tese eseldtag process, is not espused to the reactor coolant.

Issermal sleeve attachments that are welded to tne pressere tomandery east fore crevices weiere impearities may acuanslate should esot te esposed to a tem coolant environment.

til.a. lest6mg of leatersals S.

Isie licensee nas saut furnissed data ese this paragrarse la als responses to NRC Generic tetter 88-04 Fur new lastalletless, tests snuuld be made on all regular grenie stelnless steels to be used in the A5ME Caele Class 1. 2, and 3 pipleeg systees to denunstrate tnat the meterial was properly-

, aumealed and as met saueptiele to R&5CC. lests that nave seen used to detero6ae the suueptiellity of IG5CC laclude Practices A*

auss E" of A51st A-262, "Recummweeded Practices f or l

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thesecting 5mwept ability to latergrasesalar Attus en Steinless Steels

• eens the electrochemical potenticainetic rextivation (Erst) test. The (pR test is not yet auepted my the IIRC. If the EPit test is used, the aceptance criteria applied saast be evaluated and eccepted my the seat on a tase-by-case seests.

• Practsce A--04alic acid etch test for classification of each structures of stainless steels.

" Practice E--Copper-csipper sulf ate-sullisric acid test f or detetting suscepa thility to intergrmeular attack in stainless steels.

III.C. processing of flaterials C.

The licensee has not f aernished data on this par. graph in his responses to telC Generic letter 88-04 See Corrosium-resistant cladding with a duples cuaments on part II.C. above.

microstriscture l51 alalansa ferrite) may be applied to t>e esmas of type 304 or 316 stainless steel pipe for the paarpose of avoiding IG5CC at neldsents. Such cladding, ishkh is intenJed to (a) mintelse the ital on the pipe inner surface.

(b) move the 8842 away f rom the singhly stressed region neat to the attachment neeld, and (c) esolate the weldnent from the environment, may o

be asplied aneder the f ollowing condit ions:

Ill.C.I. for lattial construction, prowlJed that all, of I.

Ihe comments on Ill.C. also apply here, the piping is solution mweealed af ter claddesag.

III.L.t. For repair welding and anodifIcation to 2.

The comments on Ill.C. also apply here.

6n-plate systisms in operating plants anJ plants unocr constructiose. tihen the repair melding or usedli kation requires replacement of pipe, the replacema:nt pipe should be solutlum-maincaled af ter cladding.

Corrosion-resistant cladding spplied in the

• f teld" (i.e., without senseesent solution anseealing of the pipe) is acceptable only ese that portium sef the pipe tilat has snot been renouved f rum the pipiseg system. Other *fleid*

appikat temis of corrosium-resistant clesding are not accept. hic.

Other processes that have been found by laawaretary tests to min 6stre steesses sens IGSLC in austenitic stainless steel meldnents incluJe tenha Llom heating stress improvement (18158) and heat samt melding (HSW). A lt hungse the ese of these processes as an alternate to euepsented enservice inspection is not yet euerted by the sinc. these processes may be m

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permis56 ele and allt be caus6dered en a case-sy-case basis prowlded acceptasir supptlee data are smaalttcJ to the estC.

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ItSteel8E Is5Pffilen Aans 1th De IECTlan afijn;Iafsta IS (si diids tilhTB4491GfifMIT'df TWMIE45C(14

,I_IMEAIF5ft f(IldETTf 5TietTAIB Pedtf55fertilefuuf 5 IV.A.

For plants amese A5 FEE Code Class I, 2, and 3 A.

the Ikeesee has met furetshed data en th6s paragreesse pressere moundary peping meets the guideltaes of la his respunses to IEBC Generic tetter 65-04 Part III, se emym oted 6eservice inspectius or

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lean detecties reestrements eeyund tasse specified les the le CfA Sas.Ma{g), *leservice Inspecties anaemeraments" and plant lechakal Specificatlees for leanap detect 6ee are necessary.

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458E Code Class I and 2 pressure neuedary p6plog -

8.

54spaper thet dans met aset guide 86aes of Part lit is l

des 6 pated "muecentereleg* and ausL mave OfCe has cless6ited oer6eess pertlens of the additlemal lesereke lespectlee and eure stringset recirculaties systes reacter amater cledeup systee, and letIII l

lesh detectiem resgeiremmets. Ihe degree of system as eencenferming "menserske seasillve*l whereas all augmented laserske lespection of secg piplag these systems stemld be mancesfereleg *sereke sens 6tive"-

l depends es whether the specific *mmacemformeeg" because thC considers the recirculatlan systee as 'serske p6plag runs are classified as " Service sensitive *. Effe has presented an alternatlee to l

5eesittee." Ihe *4erske Sensit 6ve* llees inere einfG.e313, see. I.

and mill me des 6gnated by toe sueC and are defleed as these that have emportenced cracting of a sifffafmCES gener6c esture, er that are coesidered to te

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partkularly sesceptlele to crace6eg becassse of a IWAfG-0313, Aew. I has given esemples of *serske camelaatles of high local stress, material sensit tee

• peplag le Part 15.8 Part IV.S. further states cendet6en, and high sayone centent le the relat swely stagnant, latermittent, er lem-flee that should any 56500 te lemed le a partkestar p6plag run caelant. Currently, for the mantenfesialag ASSE and be censlJered generic by the stC, it esill ne dest,nated as *serske seesitive'. IG5fC has recently been f amed 6e Code Class 3 pip 6ag, ne additlemal laserske the reCirCWIatlee system pipleg and the SIE systems.

laspectlen meyend the Sectlee yl visual t"

esamenet ten is reestred.

Iterefore, teth these systems satee Id be "sereke seesillwe".

Stre has classif 6ed the folleming puertleas of selected

. f aamples of p6p6eg censleered to me 'Serske systems as amacemfereleg "mensereke sensit tee *:

5 eses 6tlee" laclude best are met Iletted to: care I

spray llaes, recirculat ten riser 16aes.*

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Ihe rec 6rculat 6am system circismieresetlal pipe rec 6rculaties bspess itses (or p6pe welds--encluding the massle-to-saf e ends, the eatenstemis/stmas times ao plants where the bypass

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mppass cap melds, and the reser Isees.

Ismes have seen ruansed), centrul red Jrive (CBS) hydresslk retearn 36mes, tselaties condenser 16aes.

7.

Ihe rearter water cleanup system free the resideal recirculetless isolet 16 eses at saf e ends ednere heat ressaval (neel) tie-6n to autheard isolative corwkes are fossed my the melded Enereal sleeve valve 1288-5.

attacammets, and shotssumme heat eschemyr lines.

It creca teg shmeld later be found 6e a particular 3.

Ihe near system fram oest6easd Iselatlose valves p6p6eg rise and camsidered to me gemerk, it allt 5004-294 and 5 to the discharge of re< 6rculatlea me desapeted by the meC as "Sereke Seesttlee.*

leaps A and 8, respectively.a i

All circianferential melds in sumscuselerelag pipe le the

+5sace me 465CC has seen esserved le the dunestic plants and

. rec trcelat ten system are *seroke sensit eve *, Also, the seat s

in v6c= et tese pos56aile high radiat see esposesre to the laspect eve persasassel, terveillassa.e and eeniterleg means system f see teme recirculatten system loups to the outteesaf lselet tee valves are *seroke sensit eve *,

other teiass those song 68 6cd in Sectless IV et this report for rec 6ranslat6 se riser lines will be resssidered me a case-by-case s. asis.

AlyfilghAIA Rf,QIgRfD

.. -... ~....

' E

~

todage esste(t ton and awpeated sawreste laspect sesa e.:eg'sIrassemts Ior *wamtarelay* Ileea saJ *noemensisalag. Serence Sensattee* Ismes are spec eileJ Delaw:

IV.s.t.

• m acenfurataq* times Inst Are hat *5erence~

- 5FailTTee*

I V.S. I.4.

teas setection: The reactor coolant lemmage detection systemas smould a,e operated under tae Techalcal Specificatten ree=trements to enhance gne discovery of a.nlJamtsfled lemage taat may laclede through-mail cracts develuped la ausacantic stalmless stesI piplag.

iv.s.l.a.(I) Ihe ledage detection system provided (1) sasseemi l

shoulJ laclede sefiscaently diverse tema I

detectlen methuds math adequate SECo*s descriplica of reigree l's led detection sensitivity te detect and measure small methods laJicates they du mot meet Sectica C of Aegulatory led s la a steely manner sad to IJentify Calde 1.45.

the ledage sources altale the practicas l imit s.

Acceptable ledage detection and Difffataff5 amaatterlag systems are descriand la Section C. Segulatory Position af the alae subsections of Sectica C of segulatory

. Segulatory Guide 1.45 " Reactor Coolant Guide 1.45 are discussed below.

Pressere Soundary teatage Betectica Systems."

Cl Bite has stated that ledage to the peleary reactor contelament free IJentified sources is y

Particular attention should be given te collected such that upgrading and calthreting those led detection systees that =111 prowlJe peumpt a.

tne flow rates are gitored separately f rugs indication of an lacrease la led.ge rate, unidentified led age, and other equivalent leala9e detecties and b.

the total collectica systians will me revlemed on a munitoreJ. glow rate can be estas.Ilshed and case-hy-case basis.

C.2 It is not clear from the Pilgrie i Final Safety Analysis Report (f 5 Alt) that unidentificil leakage to the prleary restor containment can be collected and the flow rate munitored with an accuracy of I gym or better.

C.3 Ike primary contalement leak detection methods in Pilgrie I consist of the following:

a.

Floor and equilament drale siemps 6

Drywell atenpheric radiatles muettors I) Particulate

2) Gaseous J) llalogen.

c.

Drywell temperature and samaldity recorArs.8 Ihe Pilgrie i primary contalument led detection methods meet Section C.3 of Regulatory Guide 1.45.

C.4 It is not clear whetner provisions have been made in the Pilgr:m i F5As to monitor systems connected so te..THB 8.as sip 6f intersplee lea 6 age.

r C.5 it is not known whether the Pilgrie I primary containment led detection methoJs can detect a ledage rate, or its egativalent, of I p in less than I h.

C.6 Ihe Pilgrie I alrt.orne particulate radioactivity monitoringsystemdoegnotreimainfinactionalwhen subjected to the 55E.

C.7 Indicators acut alarms for the required ledage detection systee are provided in the main control It is not clear frue the Pilgrie I f 5AA roun.

that procedures for converting various indications C

to a c==

ledage equivalent are available to the operators.

It is not knoins whether callaration of the indicators accounts for the needed independent vart ales.

C.8 only the particulate and halogen atmospheric radlettua annitors in Pilgrie I can be callbrated or tested during operatloei. lhe other led detection systems cannot be calibrated or tested during operation.8 C.9 The Pilgria l lechnical Specifications include lletting conditleens for identified and esaldentitled leakage.

Pilgrie I does not meet all the requirements of Regulatory Guide 1.45, Section C.

AleillanAt DABA utyUIRED I.

Indicate weiettier provisions have been made in tiee Pilgrim i FSAR to monitor systems casinected to the RLP8 for signs of Intersystes ledage (Subsectl.wi C 4 of Regulatory Guide 1.45).

4

1.

Indicate whether calibratisus of time indicators actounts for 4he neeJed independent veriabIes.

Also, indicate if there are lorocsdures f or converting various ladications to a common ledage eiguivalent available to the operators (Subsection C.7 of Regulatory GulJe 1.45).

3.

Indicate if unidentified ledage in the primary contaisement can be collecte=4 and the flow rate monitored with an accuracy of I gene or better (Subsection C.2 of Regulatory Guide 1.45).

4.

Indicate if the Pilgria 1 pr6 mary containment led detection methods can detect a ledage rate, or its espalvalent, of I gema in less than I A (Sunsection C.5 of Regulatory Golde I.45).

IV.S.I.e.(2) ' Plant shutduun snoesid be initiated for (2) SisetAR T inspection and corrective action when any leasage detection system indicates, within SECo has not proposed a requirement for shutdumn af ter 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 a 2-gpo isscrease in unidentified lemage in 24 h into the in rate of unidentified lem age in escess Technical Specifications for Pilgria I.

of 2 gallons per minute or its equivalent, or mesen the total asaldentified ledage SECo has not proposed a reepairement for monitoring the attalais a rate of 5 gallons per minute or sump level at 4-h latervals (or less).

Its equivalent, whichever occurs first.

For saamp level amanitoring systems with 8(Co ilues not meet statfG-0313, new. I la this matter.

A fined-seasurement interval method, the level seiculd be munitored at 4-hour DIFFER (aces latervals or less.

Nest (G-0313, Rev. I requires that reactor shutdown be 2

f lattiated when there is a 2-gym lacrease in aseidentified led age in 24 h.

For siaap level annitoring systems ulth the flaed-seasurement laterves method, the level should Ise monitored every 4 h or less. IRC Generic tetter 81-04 requires temat the above registrements be incorporated in the plant Technical Specifications.

SECo has hat arapased a requirement for Shs.tduem for a A vna terrar.c ii. useidentified ledage in 24 h la the Pilgr6m I lectualcal Specifications. the muualturing of e

L ledag (8 h).g moselloring systems is i.erformu-l once a shif t ADDIi1041AL DA1 A REQUIRED leone.

j IV.s. l.a. ( J) tholdentified ledage should include all (3) BECo's definition of unidentified ledage for Pilgrim I led age other than:

seets stat (G-0313. Rev. I (FSAH Section 4.10.3).

.-.._7_,.

r i v.s. l.a. ( _l)l a ) temaage into closed systems, such as (a) the comments on IV.B.I.e.(3) also apply hese, pump seal or valve pacting leans that are captured. flow metered, s.J cun.eucted to a sump or callestlag tans, or I V.8. 8.4. l J)(a) teakage into the contalsament (b). Ike comments on IV.B.I.a.(3) also apply siere.

etausphere frue sources that are both specifically located and known either not to laterfere with the operations of unidentified leatage monitoring systems or nut to be free a through-wall crack in the pfpsag within the reactor coolant pressure bounJary.

I V.M. I.D.

Auge:nted laservice inspection; laservice b.

St9904R V inspection of the *munconforming.

Nonservice Sensitive

• lines should be.

RECo has edupted an inspection laterval of 80 months conducted in accordance with the following for all nonconforming "nonservice sensitive" welds.

progras:*

Huwever, B((o has not classified the welds correctly, as mentioned in Paragrapsi IV.S. above.

• Inis progras is largely taken free the requirements of 458t[

5(Co has presented an alternate proposal to immtG-0313, sailer & Pressure vessel Code, Section AI, referenced in the Rev. l.

paragrepsi ib) of 10 LTR be.b5a, " Contes and Standards."

UlfftafilLES 8ItsifG-0313, Rev. I includes requirceents for augmented ISI latervals for "nonservice sensitive

• and

• service sensitive

• pipe. ihe augmented 151 requirements for

" service sensitive" pipe are more stringent than those for "nonservice sensitive" pipe, la Paragraph IV.S. above, the pipe that g(Co considered "nonservice sensitive" was identitled. It was found that same of those pipes--the recirculation system anel the Riot system from the recirculation system to the outboard Isolation valves--should be classified as

• service sensitive" and should be subjected to augmented 151 for

• sertice sensitive

• pipe. SECo did not meet inkf G-0313 Rev. I la this matter.

The pipes that are conslJered "nonservice sensitive" will be subjected tg an augsmented ISI program tiat meets muitfG-0313, Rev.

I."

A0 pill 000At BAIA REQUIAf D i

Hune.

l

(

3c Y'

'Y l

c -

y

' ~

s

/

~..;

j..

s

~

1W.5.l.t.(l) for AME famle Class I campenents and JI) 14 isamments un it.E.I.A. alse 46,1y here,

~

l[M -' '_

p6plag, exh pressure.retalning diss6eller

/

e' t

metal wie sehject to Lerske lespectice

(

reep.ireemets ei Sect see al sneeld me i

. er;,almed at lesst once la no aere thee.

LC 46 eunths (tedb-tn6tes of the 4 6me s

/

prescr6eed le toe A5IE Soller and pressure

{

l.g

- Vessel Code Section all. Seca esamleatlen 2

lJr_

snueld W sede all laternal attacammet melds that are met toercesgh-mail melds het are meleted to af form part of the pressure

?I scandary.

u r

l y., ;

j' f'-

IV.S.I.t.(tl Ime felle=6eg A5fE Code tiess I pipe welds (2) Ime comments on IV.S.I.h. also apply here.

y sie ject te 6.serske sospectlee ream 6 cements et sects e al snould me p

enanimed at leest once in na more than as emotas:

l, e-IV.e.l.6.(2)(a) All melds at terni.at ends

• et pipe (a) Ihe caemmets en IV.s.l.a. aise apply here.

at vessel mennes; l..

• lereimal ends are the estremitles of piplag runs that l

commect to structures campanients (such as sessels, pumps.

salees) er pipe w==rs, eum of whkes acts as rigle restraints er proeldes at least toe degrees of restralet to

.m I

piplag tearmel espanslam.

I V.S. I.t.(2)(t) All melds heeleg a design ceableed (6) the cameents en IV.S.I.h. also apply here.

primary plus secondary stress range of 2.45, or more; IV.S. I.h. (2)(c ) All ucids heeleg a destga cuanslatlee (c) the comments se IV.S.I.D. anse apply here.

fatigue usage facter of 0.4 asr more;

.med I V.8. 8.t. (t)(d) Sei#6clemt addettomal melds moth alp

- (d) the ceanents en IV.s.l.a. also apply here.

y potential for crece6eg to eeke Lee total essual to 755 of the melds la eacn piping systes.

I I V.S. I.b.(J) Ime f alluu6mg A5sE Code Class 2 p6pe (3) SafetAAV

= ends, senject to 6 sereke lespectsee

~~ -

ressu6remrets of Section al. la resliksal affe has met identif 6ed these unseconfeesleg "ausiservice meat remusel systmas, emergency core sees 6tive" p6 pes usikh are to be laspetted per part cael6mg systems, and centalement meat IV.S.I.t.(3) of maf G.0313. Rev. l.

Itate are needed to reisupeal systeams 54matel4 he eedslard a8

.#et maiso ep le. *eGr.&.?.'r ke senslt ige" 4580i CeJe Class ?

least once le me more tha= 80 sioaths:

pipes will ne ir,ected and eshet suspect 6ame precedures will e

be used.

I e

l

.m

-2

Dif ff REleEE S MEG-0313, New. I requires that nonconforming A$ff -

Code Class I and Class 2 piping be suujected to en augmented 151 programs. The augmented 151 program for A58E tode Class I piping differs from that required oss Class 2 p iping. Also, augmented ISI requirements dif fer f or ASML Code Class 2 pipes to oc inspected per Parts IV.S.I b.(J) and IV.B.I.b.(4) of MEG-0313. Rev. l.

SECo has submitted the augmented 151 program for montonforming *nonservice sensitive

• piping, but has not distinguisl.ed between the ASME fode Class I and Class 2 piping, and between ts.e A5ME Code Class 2 pipes which are in be inspected per Parts IV.8.l.b.(3) and IV.8.1.b.(4) of NtatEG-0313. New.1. Therefore, 8ECo's program for A5ME Code Class 2 piping cannot be evalatated.

SECo has insucsted that the nonconforming "nonservice sensitive

• ASMC Code Class 2 piping augmented 151 Intervals will be that of the "nonservice sensitive" A5ft fode Class I p iping.8 BECo meets NUREG.03I3, Rev. I in this rc9ard.

A00!Il0NAL DATA REqulRED 1.

Identify editch A5ME Code Class 2 pipe will be Inspected per Part IV.B.I.b.(3).

N 2.

Identify the insp*Clion procedures for "nonservice sensitive" A5ME Code Class 2 pipe.

IV.S.I.o.(3)(a) All welds of the terminal ends of (a) Ihe coussents on IV.B.I.b.(3) also apply here.

pipe at vessel nonles, and I V.lf. l.b.13)(b ) At least 105.J the welds selected (b) Ihe casaments on IV.B.I.b.(3) also apply here.

proportionately from the following categories:

IV.S.I.b.(3)(b){l)

Circunferential welds at (1) Ihe cosaments on IV.B.I b.(3) also apply here.

locations ws.ere the stresses under the loadings resulting from any plant coNitions as calcuTated by the sum of Equations (9) and (10) in IIC.3652 eacced 0.8 (1.25n + S );

A IV.B.I.b.(3)(b)(ll)

Welds at terminal ends of (11) The comments on IV.8.1.b.(3) also apply here.

piping, including branch runs; IV.C.I.b.(3)(b)(lii) Dissimilar metal welds; (lli)lne cosaments on IV.B.l.b.(3) also apply here.

IV.8.1.b. ( 3)(o)( lv) Welds at structural (iv) Ihe cosaments on IV.B.I.b.(3) also apply tere.

discontinuitles; and

w._ [

s

. t

' f w

, 'k

\\

A

-Q

\\

[s 3,

i -

s 4.,

'g "4[%g.

g.

s

%Ag-t

' -~ s A,

,j'

'-g s

\\\\%

_ s.

3 gt

'$ IV.B.I.b.(J)th)(v)

Welds that cannot be pres.:srt N, (v) -Jhe comm mts on IV.S.I.b.(3) also al$ y 6.cre. '

1 s

l tested in accordance with 3y c!~?

IWC-bouu.

s 5

-g N

- ' (I lhe welds to be examined shall i

7 be distributed approximately equally among ruses (or portions' of runs) tenet are essentially X

stellar in desigsi, size, systene femetion, and service conditluns.

(

iW.8.1.b.(4)

The following ASME Code Class 7 pipe (4) St###AY welds in systems other than residual xf '

"(

mt remuval systems, emergency core

1. sCo has not idotified those nimeconforming "nonserwhe cooling systems, aa4 contaleasent heat sensitive

• pipas wh!ch are to be inspected per Part x

resmoval systems, weilae are subject to IV.8.1.b.14) of InsifG-0313, Rev. l.

Data are needed to inservice inspection requirements of -

determine wnich

• susaservice sensitive" ASME Cole Class 2 Sectione II, should be, inspected at pipes will be inspeGIed and what inspertion procedures will least once an no moreltnan 80 asonths g

.be used.

I' g, *E DifTIREhCf5

~,

s NtsesG-0]I3. Rev. I requires that noncentos, sing ASME Code Class I and Class 2 piping be,%sbjxted to ass augmented

~

I$I program. The augmented I$I progras for A5ME Cmle Class I piping differs from that reestred on Class 2 piping. Also, angersited ISI requirements differ for A5M[

\\

co Code Class 2 pipes to be inspected per Parts IV.B.I.b.(3) and IV.S.I.b.(4) of allslEG-0313. Rev. 1.

BECo has submitted the augmented ISI program for nonconforming ?nonservice sensitive" piping, but has not x'

distinguished betwean the ASME Code Class 1 and Class 2 piping, and between the ASME Code Class 2 pipes wenich are to be inspected per Parts IV.S.I.b.(3) and IV.8.l.b.(4) of letNtf G-0313. New. I.

therefore. SECo's program for A5ME Code r

Class 2 piping cannot be evaluated because they have not beesi identified.

NEto has Inificated that the nonconforming "nonseYvice sensitive" A9tE Cole Class 2 piping auipmented ISI intervals will be that of the "nonservice sensitive" ASML Code Class I piping.8 SECo meets IIUREG-0313. Rev. I with respect to tne inspection interval.

A&Meill0IIAL DAlA RtqulRLD 1.

Identify whics ASME Coale Class 2 pipe will be inspected per Part IV.8.l.b.(4).

2.

Identify the inspectiose procedures for "nunservice sensitive" A5ME Code Class 2 pipe.

J

IV.B.I.b.(4)(a) All welds at locatloses where the (a) the comsments on IV.8.1.b.(4) also apply here.

Stresses isnder the loadlugs resulting f rom %rmal* and " Upset

• plant conditions including the operettag basis earthquake (OBE) as calculated by the sum of Equations (9) and (10) la 4C-3652 exceed 0.8 (I.25,a S );

A I V. B. I.b. ( 4)(b) All welds at terminal ends of piping, (b) The comments on IV.S.I.b.(4) also apply here.

Including brassch runs; IV.S.I.b.t4)(c) All dissieller metal welds; (c) Ihe comments on IV.S.I.D.(4) also apply here.

IV.S.I.b.(4)(d) Additional welds with high potential (d) The comunents on IV.B.I.b.(4) also apply here.

for cracting at structural discontinuitles* such that the total number of welds selected for esamination equal to 251 of the circueferential welds in each pipisig system.

• Structural discontinuities include pipe weld joints to vessel nonles, valve bodies, pump casings, pipe fittings (sucn as elbows, tees, reducers, flanges, etc., conforming to ANSI Standard B 16.9) and pipe branch connections and to fittings.

IV.B.I.b.(5)

If examination of (1), (2), (3), and (5) Ihe cnsmeents on IV.S.I.b.(l). (2), (3), and (4) also (4) above conducted during the first apply here.

80 months reveal no incidesice of stress corrosion tracLing, the eammination f requency thereaf ter ca's revert to 120 months as prescribed in Section 11 of the ASME Soller and pressure Vessel Code.

I V.S. I.D. ( b)

Sampling plans other than those (6) SleetARY described in (2), (3), and (4) above will be reviewed on a case-by-case SECo has not identified those nonconforming "nonservice basis.

sensitive' pipes which are to be inspected per Part IV.S.I.b.(6) of NLAtEG-0313, Rev. I.

Data are needed to determine which "nonservice sensitive

• ASME Code Class 2 pipes will be luspected asul what inspection procedures will be used.

DIfitRENCES NLREG-0313,licy. I requires that nonconforming ASME Code Class I and Class 2 piping be subjected to an augwented ISI program. ihe duapaented ISI progrno for A5ME Code Class I piping differs true that required on Class 2 pipinj.

SECo has sur;mitted the augmente-d 151 program for noncorforming " service sensitive" piping. but has not distinguished between the ASME Code Class I and Class 2 piping. Therefore, 8ECo's program for ASHC Code Class 2 piping cannot be evaluated because the ASHE Code Class 2 pipinj has not been identified.

SECo has indicated that the nonconfo:ining " service sensitive

• A5ME Code Class 2 piping au nted 151 intervals will be that of the

• service sensitive ASME Code Class I piping. SECo has submitted an alternate plass which meets NtEEC-031), dev. I in the inspection latervals.

ADulflukAt DAIA REQUIRED l.

1.lentify i.hich ASHE Code Class 2 pipe will be inspes.tt ' 6,er Part IV.8.2.b. (b).

2.

Identify the inspectlan procedures for

• service sensitive" A$HE Code Class 2 pipe.

IV.b.t.

" Nonconforming" t lpes that are " Service MME IV.d.i.a.

test Detection: Ihe leatage detection requirisents, described in IV.8.1.a.

The comments made in Parts IV.8.l.a.(l) and a.

above, should be implemented.

IV.8.1.a.(2) apply here.

IV.8.2.0.

Augmented Inservice inspection:

b.

$leMAR V 8ECo has selected portions of piping systems as nonconforming " service sensitive". All the portions so designated by 8Efo are considered nonconforming " service sensitive" by NRC. lkswever. there are some portions of the piping systems designated by BECo as nonconforming "nonservice sensitive" that NRC considers nonconforming

" service sensitive *. These are listed in Paragraph !V.8.

above.

Also, UFCo's priposed augmented 151 interval for the nonconfoilaing " service sensitive" piping does not meet NlREG-Oll3, Rev. l.

DECO has presented an alternative to NtREG-0313. Rev. l.

DifffMENCES NtWEG-0313, Rev. I requires that nonconforming "ser

.e sensitive" pipe welds be subject to an augmented ISl*

program. Selection methods for pipe weldt and inspection Intervals to be selected are found les Part IV.B.2.b. of NIMEG-0313. Rev. l.

8ECo has designated ti.e following portions of selected systems as noesconforming

• service seissitive*:

1.

"the core spray lines betweesa the first valve f rom the reaci4.r vessel and the outboard isolation valve.

2.

lhe recirculatlun system risers.

3.

The recirculation system bypass stubs and caps.

4.

The recirculation system inlets and safe ends.

5.

The shutdown heat enchanger (Rest) lines from the recircul valves.""dtlon loops to the outboard Isolation lhe above list meets NLREG-0313. Rev.1. However some portions of selected systems that were labeled nusiconforming "nonservice sensitive" by SECo are considered nonconforming

" service sensitive" by aftC. Ihese are listed in Farag-aph IV.S. d ove. Therefore, SfCo's IIst of nonconfonsing "see : Ice sensitive" pipe meets NUREG-0313 Jei

1. tut is not exhaustive.

8ECo has adapted the 1914 Edition. Sommier 1975 Addenda m

of A5ME Section Il for the selection and inspection Interval of circumferential pipe welds in Class I and 2 systems.

SECo will reduce the inspection laterval from 120 to 80 months for the inspection of these welds 8 BECo's alternative to NUHfG-0313. Rev. I does not meet NUNEG-0313 Rev. 1.

ADull10N#1 DATA REqulRED None.

IV.6.2.b.(1)

Ihe welds and adjoining areas of ypass piping of the discharge valves in the main recirculation loops, and of the an.stenttic stainless steel reactor core spray piping up to and including the second isolation valve, should be emainined at each reactor refueling outage or at other scheduled plant outages. Successive examination need not be closer than 6 months, if out.sges ocu r more frequently tenan 6 months. This requieement' applies to all welds in all t,ypass lines whether the 4. loch valve is kept open or closed during operation.

In the event these examinations iind the piping free of unacceptable indications for three successive inspectioses, the esamination anay be entended to each 36-month period (plus or minus by as much as 12 months) coincident with a refueling outage. in these cases, tie successive examination may be limited 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 De esamined.

In tne event these J6-month period esasinations reveal no unacceptable indications for three successive inspections, the welds and adjoining areas of these piping runs should be eaamined as described in IV.B.I.b(1) f or dissimilar metal welds and in IV.8.1.bl2) for other welds.

I V. B.2.n. ( 2)

The alssimilar metal welds and (2) The licensee has not furnished data un this paragraph adjoining areas of other ASME Code in his responses to NRC Generic letter 81-04.

N Class I " Service Sensitive" piping N

should be examined it each reactor refueling outage or at other scheduled plant outages. Successive esaminations need n61 he closer than 6 months, if outages occur more frequently than 6 months. Such examination should include all laternal attacaments that are not through-wall welds but are welded to nr fore part of the pressure boundary.

IV.B.2.0.(J)

Ine welds and adjoining areas of (3) The consments on IV.B.2.b. also apply here.

Other ASME Code Class 1 " Service Sensitive" piping should he examined using the sampling plan described in IV.8.8.b(2) except that the f requency of such examinattuns should be at each reactor refueling outage or at other scheduled plant uutages.

Successive caaminations need not be closer than 6 months, if outages uccur more frequently than 6 months.

IV.8.2.b (4)

Ihe adjoining areas of internal (4) the comuments on IV.8.2.b. also apply here.

attacssment welds in rectrculation inlet lines at safe ends where crevices are formed by the welded theemal sleeve attactment should be esamined at each reactor refueling outage or at other scheduled plant outages. Successive examinat forts need not be closer than 6 months, if outages occur more frequently than 6 annths.

iv.B.2.0.(5)

In the event the esaminations (5) Ihe comments on IV.B.2.0 also apply here.

described in (2), (3) and (4) above find the piping f ree of unacceptable indications for three successive inspections, the examination may be entended to each 36-month period (2 monthsplus or minus by as much as refueling) outage. coinciding with a 1

In the event these 36-month period esaminations reveal no unacceptable indicalions for three successive to inspections, the f requency of

'd esamination may revert to 80-month periods (two-thirds the time prescribed in the A5ME Code Section II).

I V. 8.2.b. ( b)

Ihe area, entent, and frequency of (6) StMtARY cuaminallon of the augmented luservice inspection for A5MC Code Class 2 " Serv 6ce Sensitive" lines BECo has not Identified those nonconforming "nonservice will ne determined on a case-by-case sensitive" pipes which are to be inspected per part IV.8.2.b.(b) of NUREG.0313. Rev l.

Data are needed to casts.

determine which " service sensitive" ASME Code Class 2 pipes will be inspected and what inspection procedures will be used.

DIFf fidNCES NURIG-0313. Rev. I requires that nonconforming ASME Code Class I and Class 2 piping be subjected to an auymrnted 3

ISI program. the augmented 151 program for A5M[* Code Class I piping dif fers from that requised on Class 2 piping.

SECo has subesitted the augum!nted ISI program for nonconforming

• service sensitive" piping, but has not distinguished between the ASMC Coe8e Class I and Class 2 piping. Therefore, BECo's program for ASME fode Class 2 piping cannot be evaluated neithout more data.

~

i.

Elfo has laulicated that the nossCunionalspj "servlCe sensitive" ASME Code Class 2 piping augmented ISI intervals will be that of the " service sensitive

• ASML Code Class I piping. BECo has submitted an alternate plan to IIUWEG-Oll3 R ev. 1.

ADull10NAL DAIA REQUIRED l.

Identify which A5ME Code Class 2 pipe will be inspected per Part IV.S.2.b.(6).

2.

Identify taie inspection procedures for " service sensitive" ASME Code Class 2 pipe.

1 (. H. 3.

fenndestew tIve Enamination (feuE) Nequirements 3.

The lice.asee has not furnished data oss this para.jrapse la he methoJ of esamination and vol ane of material his responses to NEC Generic Letter 61-04.

to be esmalned, the allowable indication standa.ds, and examinattua procedures should comply utta the requirements set forth in tne applicable Edition and Addenda of the ASME Code.

Section XI. specified in Paragrapa (g).

"ineervice Inspection Requirements." of 10 CFR yw

$(..a. "Unles and 5tandards."

in sue cases. the code examination procedures may not be ef fective for detecting or evaluating 4G500 and utner ultrasonic (UI) procedures or advanced nondestructive examinatton tectuelques may De required in detect and evaluate stress corrusion creceang in austenttic stainless steel piping. Improved Uf procedures have been developed by certain organisations. Ihese improved UI detection and evaluation procedures -

tt:41 have been or can ne desmanstrated to the 40tC to be effective in detecting IGSCC should be used in the laservice inspectiosa.

NecuuseenJations for the development and eventual lawlcmentation of these improved tectualques are included in Part V.

a 4

e

V.

GEhtNAL litLt1MhD4IlONS V.

lhe licensee has not furnished data on this paragraph in his responies to NRC Generic tetter 88-04.

ihe measures outlined in part Ill of this document provide for positive actions that are consistent with current technology. The implementation of these actions should marsedi.v reduce the susceptibility of stainless steel piping to stress corrosion cracking in SWRs. It

- is recoysited that additional means could be used to limit the extent of stress corrosion cracking of BWR pressure boundary piping materials and to leprove the overall system lategrity. lhese include plant design and operational procedure considerations to reduce system exposure to potentially aggressive envirosament, improved material selection, special f abrication and welding techniques, and provistuns for volumetric inspection capability in the design of weld joints. Ihe use of such means to limit IGSCC or to improve plant system integrity will be reviewed on a case-by-case 04s15.

~us

TABLE 2 SUMMARIES OF EVALUATION OF LICENSEE'S RESPONSES II.C. Material Selection, Testing, and Processing Guidelines for BWRs with an Operating License Boston Edison Company (BECo) is not planning to replace nonconforming " service sensitive" lines at Pilgrim, but is evaluating induction heating stress improvement and heat sink weiding to reduce the possibility of IGSCC. BECo has presented an alternative to NUREG-0313, Rev. 1.

IV.8.

Service Sensitive Pipe BECo has classified various portions of the recirculation system reactor water cleanup system, and RHR system as nonconforming "nonservice sensitive"; whereas all these systems should be nonconforming " service sensitive" because NRC considers the recirculation system as " service sensitive". BECo has presented an alternative to NUREG-0313, Rev. 1.

IV.S.I.a.(1) Leak Detection and Monitoring Systems BECo's description of Pilgrim l's leak detection methods indicates they do no; meet Section C of Regulatory Guide 1.45.

IV.8.1.a.(2) Leak Detection Requirements i

BECo has not proposed a requirement for shutdown after a 2-gpm increase in unidentified leakage in 24 h into the Technical Specificatiens for Pilgrim 1.

BECo has not proposed a requirement for monitoring the sump level at 4-h intervals (or less).

26

l BECo does not meet NUREG-0313, Rev.1 in this matter.

IV.B.I.b.

Augmented ISI of Nonconforming "Nonservice Sen'sitive" Pipe BECo has adopted an inspection interval of 80 months for all nonconforming "nonservice sensitive" welds. However, BECo has not classified the welds correctly, as mentioneo in Paragraph IV.B.

6 above.

BECo has presented an alternate proposal to NUREG-0313, Rev.1.

IV.8.1.b.(3) Augmented ISI of Nonconforming "Nonservice Sensitive" ASME Code Class 2 Pipe BECo has not identified those nonconforming "nonservice sensitive" pipes which are to be inspected per Part IV.8.1.b.(3) of NU7EG-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.8.1.b.(4) Augmented ISI of Nonconforming "Nonservice Sensitive ASME Code Class 2 Pipe BECo has not identified those nonconforming "nonservice sensitive" pipes which are to be inspected per Part IV.B.I b.(4) 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.8.1.b.(6) Alternative Augmented ISI Sampling Plans BECo has not identified those nonconforming "nonservice sensitive" pipes which are to be inspected per Part IV.8.1.b.(3) of NUREG-031.1:

Rev. 1.

Data are needed to determine which "nonservice sensitive" ASME Code Class 2 pipes will be inspected and what inspection procedures will be usad.

i 27 4

s, w,

mm-g n-,,

e

t dugmentedISIofNonconforming"ServiceSensitive" Pipe IV.8.2.0.

BECo has selected portions of piping systems as nonconforming

" service sensitive". All the portions so designated by BECo are considered nonconforming " service sensitive" by NRC. However, there are some portions of the piping systems designated by BECo as nonconforming "nonservice sensitive" that NRC considers nonconforming " service sensitive". Th'ese are listed in Paragraph IV.8. above.

Also, 8ECo's proposed augmented ISI interval for the nonconforming

" service sensitive" piping does not meet NUREG-0313, Rev.1.

BECo has presented an alternative to NUREG-0313,.Rev.1.

IV.B.2.b.(6) Augmented ISI of Nonconforming " Service Sensitive" ASME Code Class 2 Pipe 8ECo has not identifiet those nonconforming "nonservice sensitive" pipes which are to be inspected per Part IV.8.2.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.

28

TABLE 3 DIFFERENCES BETWEEN NUREG-0313, REV. l '

AND LICENSEE'S RESPONSES II.C. Material Selection, Testing, and Processing Guidelines for BWRs with an Operating License NUREG-0313, Rev. I requires that NRC-designated nonconforming

" 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.

BECo is not planning to replace nonconfonning " service sensitive" lines.

Instead, BECo is evaluating induction heating stress improvement (IHSI) and heat sink welding (HSW) to reduce the possibility of IGSCC.

IV.8.

" Service Sensitive" Pipe NUREG-0313, Rev. I has given examples of " service sensitive" piping in Part IV.B.

Part IV.8. further states that should any IGSCC be found in a particular piping run and be considered generic by the NRC, it will be designated as " service sensitive".

IGSCC has recently been found in the recirculation system piping and the RHR systems. Therefore, both those systems should be

" service sensitive".

BECo has classified the following portions of selected systems as nonconforming "nonservice sensitive":

1.

The recirculation system circumferential pipe welds--excluding the nozzle-to-safe ends, the bypass cap welds, and the riser lines.

29

)

i 2.

The reactor water cleanup system from the residual heat removal (RHR) tie-in to outboard isolation valve 1201-5.

3.

The RHR system from outboard isolation valves 1001-29A and 8 to the discharge of recirculation loops A and B, respectively.0 All circumferential welds in nonconforming pipe in the recirculation system are " service sensitive". Also, the RHR system from the recirculation system loops to the outboard isolation valves are " service sensitive".

IV.B.I.a.(1) Leak Detection and Monitoring Systems The nine subsections of Section C of Regulatory Guide 1.45 are discussed below.

C.1 BECo 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,9 and b.

the total flow rate can be established and monitored.'

C.2 It is not clear from the Pilgrim i Final Safety Analysis Report (FSAR) that unidentified leakaga to the primary reactor containment can be collected and the flow rate monitored with an accuracy of I gpm or better.

C.3 The primary containment leak detection methods in Pilgrim 1 consist of the following:

a.

Floor and equipment drain sumps b.

Drywell atmospheric radiation monitors 30

\\

1)

Particulate 2)

Gaseous 3)

Halogen.

Drywell temperature and humidity recorders.8 c.

The Pilgrim 1 primary containment leak detection methods meet Section C.3 of Regulatory Guide 1.45.

C.4 It is not clear whether provisions have been made in the Pilgrim 1 FSAR to monitor systems connected to the RCPB for signs of intersystem leakage.

C.5 It is not known whether the Pilgrim 1 primary containment leak detection methods can detect a leakage rate, or its equivalent, of I gpm in less than 1 h.

C.6 The Pilgrim 1 airborne particulate radioactivity monitoring system does not renain functional when subjected to the SSE.8 C.7 Indicators and alarms for the required leakage detection system are provided in the main control room.

It is not clear from the Pilgrim 1 FSAR that procedures for converting various indications to a common leakage equivalent are available to the operators.

)

l It is not known wnether calibration of the indicators accounts for the needed independent variables.

C.8 Only the particulate and halogen atmospheric radiation monitors in Pilgrim 1 can be calibrated or tested during operation. The other leak detection systems cannot be calibrated or tested during operation.8 l

4 31

C.9 The Pilgrim 1 Technical Specifications include limiting conditions for identified and unidentified leakage.

Pilgrim 1 does not 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.

NRC Generic Letter 81-04 requires that the above requirements be incorporated in the plant Technical Specifications.

BECo has not proposed a requirement for shutdown for a 2-gpm increase in unidentified leakage in 24 h in the Pilgrim 1 Technical Specifications. The monitoring of leakage monitoring systems is performed once a shift (8 h).O IV.B.I.b.

Augmented ISI of Nonconforming "Nonservice Sensitive" Pipe NUREG-0313, Rev.1 includes requirements for augmented ISI intervals for "nonservice sensitive" and " service sensitive" pipe. The augmented ISI requirements for " service sensitive" pipe are more stringent than those for "nonservice sensitive" pipe.

In Paragraph IV.B. above, the pipe that BECo considered "nonservice sensitive" was identified.

It was found that some of those pipes--the recirculation system and the RHR system from the recirculation system to the outboard isolation valves--should be classified as " service sensitive" and should be subjected to augmented ISI for " service sensitive" pipe. BECo did not meet NUREG-0313, Rev. 1 in this matter.

The pipes that are considered "nonservice sensitive" will be subjected to an augmented ISI program that meets NUREG-0313, Rev. 1.8 32

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.l.b.(3) and IV.B.1.b.(4) of NUfsEG-0313, Rev.1.

BECo 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.1.b.(3) and IV.B.l.b.(4) of NUREG-0313, Rev. 1.

Therefore, BECo's program for ASME Code Class 2 piping cannot be evaluated.

BECo has indicated that the nonconforming "nonservice sensitive" ASME Code Class 2 piping augmented ISI intervals will be that of the "nonservice sensitive" ASME Code Class 1 piping.8 BEco meets NUREG-0313, Rev. 1 in this regard.

IV.B. l.b. (4) Augmented ISI for ASME Code Class 1 Pipe Welds with High Potential for Cracking NUREG-0313, Rev. I requires that nonconfonning 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 I

that required on Class 2 piping. Also, augmented ISI requirements differ for ASME Code Class 2 pipes to be inspected per Parts IV.B.1.b.(3) and IV.8.1.b. (4) of NUREG-0313, Rev. 1.

BECo 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 33

IV.B.1.b.(3) and IV.8.1.b.(4) of NUREG-0313, Rev. 1.

Therefore, BECo's program for ASME Code Class 2 piping cannot be evaluated because they have not been identified.

BECO has indicated that the nonconforming "nonservice sensitive" ASME Code Class 2 piping augmenteo ISI intervals will be that of the "nonservice sensitive" ASME Code Class 1 piping.8 BECo meets NUREG-0313, Rev. I with respect to the inspection interval.

IV.8.1.b.(6) Alternative Augmented ISI Sampling Plans NUREG-0313, Rev. I requires that nonconforming ASME Code Class 1 and Class 2 piping be subjected to an augnented ISI program. The augmented ISI program for ASME Code Class 1 piping differs from that required on Class 2 piping.

SECo has submitted the augmented ISI program for nonconforming

" service sensitive" piping, but has not distinguished between the ASME Code Class 1 and Class 2 piping. Therefore, BECo's program for ASME Code Class 2 piping cannot be evaluated because the ASME Code Class 2 piping has not been identified.

BECo has indicated that the nonconforming " service sensitive" ASME Code Class 2 piping augmented ISI intervals will be that of the "s' rvice sensitive" ASME Code Class 1 piping. BECo has submitted e

an alternate plan which meets NUREG-0313, Rev.1 in the inspection intervals.

IV.8.2.b.

Augmented ISI of Nonconforming " Service Sensitive" Pipe NUREG-0313, Rev. I requires that nonconforming " service sensitive" pipe welds be subject to an augmented ISI program. Selection methods for pipe welds and inspection intervals to be selectea are

. found in Part IV.B.2.b. of NUREG-0313, Rev.1.

BECo has designated the following portions of selecteo systems as nonconforming " service sensitive":

34 4

~

i 1.

"The core spray lines between the first valve from the l

reactor vessel and the outboard isolation valve.

l 2.

The recirculation system risers.

3.

The recirculation system bypass stubs and caps.

4 The recirculation system inlets and safe ends.

5.

The shutdown heat exchanger (RHR) lines from the recirculation loops to the outboard isolation valves."O The above list meets NUREG-0313, Rev.1. However, some portions of selected systems that were labeled nonconforming "nonservice sensitive" by BECo are considered nonconforming " service sensitive" by NRC. These are listed in Paragraph IV.8. above.

Therefore, BECo's list of nonconforming " service sensitive" pipe meets NUREG-0313, Rev. 1, but is not exhaustive.

BECo has adopted the 1974 Edition, Summer 1975 Addenda of ASME Section XI for the selection and inspection interval of circumferential pipe welds in Class 1 and 2 systems. BECo will reduce the inspection interval from 120 to 80 months for the inspection of these welds.O BEco's alternative to NUREG-0313, Rev. I does not meet NUREG-0313, Rev. 1.

IV.B.2.b.(6) Augmented ISI of Nonconforming " Service Sensitive" ASME Code Class 2 Pipe l

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.

35 r =

BECo has submitted the augmented ISI program for nonconforming

" service sensitive" piping, but has not distinguished between the ASME Code Class 1 and Class 2 piping. Therefore', BECo's program for ASME Code Class 2 piping cannot be evaluated without more data.

SECo has indicated that the nonconfonning " service sensitive" ASME Code Class 2 piping augmented ISI intervals will be that of the

" service sensitive" ASME Code Class 1 piping. BLCo has submitted an alternate plan to NUREG-0313, Rev. 1.

9 36

~

TABLE 4 ADDITIONAL DATA REQUIRED OF LICENSEE II.C. Material Selection, Testing, and Processing Guidelines for BWRs with an Operating License 1.

Indicate which nonconforming " service sensitive" piping will be subjected to IHSI and HSW.

2.

Supply the specifications for the IHSI and HSW processes proposed to being used.

IV.8.

Service Sensitive Pipe None.

IV.8.1.a.(1) Leak Detection and Monitoring Systems 1.

Indicate whether provisions have been made in the Pilgrim i 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. Also, indicate if there are procedures for converting various indications to a common leakage equivalent available to the operators (Subsection C.7 of Regulatory Guide 1.45).

3.

Indicate if unidentified leakage to the primary containment can be collected and the flow rate monitored with an accuracy of I gpm or better (Subsection C.2 of Regulatory Guide 1.45).

37

4.'

Indicate if the Pilgrim 1 primary containment leak detection methods can aetect a leakage rate, or its equivalent, of I gpm in less than I h (Subsection C.5 of Regulatory Guide 1.45).

IV.B.I.a.(2) Leak Detection Requirements None.

IV.B.I.b.

Augmented ISI of Nonconforming "Nonservice Sensitive" Pipe None.

IV.8.1.b.(3) Augmented ISI for ASME Code Class 1 Pipe Welds Having a Design Cumulative Fatigue Usage Factor of 0.4 or More 1.

Identify which ASME Code Class 2 pipe will be inspected per Part IV.B.I.b.(3).

2.

Identify the inspection procedures for "nonservice sensitive" ASME Code Class 2 pipe.

IV.B.I.b.(4) Augmented ISI of Nonconforming "Nonservice Sensitive" ASME Code Class 2 Pipe 1.

Identify which ASME Code Class 2 pipe will be inspected per Part IV.B.I.b.(4).

2.

Identify the inspection procedures for "nonservice sensitive" ASME Code Class 2 pipe.

IV.B.l.b.(6) Alternative Augmented ISI Sampling Plans 1.

Identify which ASME Code Class 2 pipe will be inspected per Part IV.B.2.b.(6).

.+

38

2.

Identify the inspection procedures for " service sensitive" ASME Code Class 2 pipe.

IV.B.2.b.

Augmented ISI of Nonconforming " Service Sensitive" Pipe None.

IV.8.2.b.(6) Augmented ISI of Nonconforming " Service Sensitive" ASME Code Class 2 Pipe 1.

Identify which ASME Code Class 2 pipe will be inspected per Part IV.8.2.b.(6).

2.

Identify the inspection procedures for " service sensitive" ASME Code Class 2 pipe.

39

4 REFERENCES 1.

E. O. Eason et al., The Cost Effectiveness of Countermeasures to Intergranular Stress Corrosion Cracking in BWR Pioing, EPRI NP-1703, recruary 1981, p. A-04 2.

U.S. Nuclear Regulatory Commission, Technical Reoort on Material Selection and Processing Guidelines for SWR Coolant Pressure Boundary Piping, USNRG Report NUREG-0313, Ju ly 19//.

3.

U.S. Nuclear Regulatory Commission, Technical Report, Investigation and Evaluation of Cracking in Austenttic Stainless 5 teel Pioing of Boiling Water Reactor Plants, 05NRC Report NUREG-75/co7, Octooer 1975.

4 U.S. Nuclear Regulatory Commission, Investigation and Evaluation of Stress-Corrosion Cracking in Pioing of Lignt water Reactor Plants, USl4RC Report NUREG-0531, Feoruary 19/9.

5.

U.S. Nuclear Regulatory Commission, Technical Report on Material Selection and Processing Guioelines for 8WR Coolant Pressure Boundary Piping, 05NRG Report NUREG-0313 Rey.

1, Ju ly 1980.

t 6.

D. G. Eisenhut letter to all BWR licensees (except Humboldt Bay and La Crosse), " Implementation of NUREG-0313, Rev.1, Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Bounoary Piping (Generic Task A-42)," Generic Letter 81-04, Feoruary 26, 1981.

7.

A. V. Morisi to D. G. Eisenhut letter, July 8,1981 (NRC Accession No.: 8107140669).

8.

W. D. Harrington to D. B. Vassallo letter, May 20,1983 (NRC Accession No.: Not available).

9.

Pilgrim Nuclear Power Station, Unit 1 Final Safety Analysis Report.

10. Pilgrim Nuclear Power Station, Unit i Technical Specifications.

i 40

I

),",c aOaM 335 v.s. Nuctsan ReautATOnv commission Bl8LIOGRAPHIC DATA SHEET EGG-EA-6257

• EnMOD'EvUuation of Integrity of the Pilgrim Nuclear

~'""#

Power Station Unit 1 Reactor Coolant Boundary Piping System 3,,c,,,ENT S ACCES$iCN NO.

7 AUTHORiSJ l

5. DATE REPORT COMPLETED MONTM l YEAR Peter K. Nacata August 1983 9 PERFORMING ORGANIZATION NAME ANO MAILING ACORESS Itacium 2,a Comes OATE REPORT ISSUEO MONTH lVEAR August 1983 l

EG&G Idaho, Inc.

Idaho Falls, ID 83415 8.ft,,,,

{

8. (Leave cimal

12. SPONSORING ORlANIZATION NAME ANO MAILING ACORESS (inctuar tea Coast Division of Licensing Office of _ Nuclear Reactor Regulation

~

ii. pis w, U.S. Nuclear Regulatory Conraission Washington, DC 20555 A6429

13. TYPE OF REPORT pg niOO CQv E dE D (factusive casest

15. SUPPLEMENTARY NOTES 14 Ites,e armes

16. ASSTR ACT /200 woros or ressi

17. KEY WOROS ANO OOCUMENT ANALYSIS 17a. OESCRIPTORS 17b. sOENTIFIERS/CPEN ENDED TERMS

18. AV AILA81LITY STATEMENT 19 SECualTV CLASS <W s recorri 21 NO OF PaGES Unclassified Unlimited I

20 Uncla'7v c'fied I:: s"alCE cua 2 55 ' m >= a a' >

ssi NRC 80RM 33S ett ett l

_