ML20132B288
| ML20132B288 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/12/1996 |
| From: | Boulette E BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BECO-#96-105, GL-88-01, GL-88-1, NUDOCS 9612170130 | |
| Download: ML20132B288 (18) | |
Text
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G Soston Edison 10CFR50.55a(a)(3)
Pilgrim Nuclear Power Staton Rocky Hill Road Plymouth, Massachusetts 02360 1
E. T. Boulette, PhD ;
l Senior Vice President- Nuclear
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l December 12, 1996 !
BECo Ltr. #96-105 U.S. Nuclear Regulatory Commission Attention: Document Control Desk ;
l Washington, DC 20555 l
Docket No. 50-293 License No. DPR-35 Pilarim Refuelina Outaae #11 ISI Relief from I
(a) ASME.Section XI Inspections and (b) Generic Letter 88-01 IGSCC Inspections -
i Summarv :
i
- Boston Edison Company (BECo) informed the NRC in BECo Letter No.96-091, dated October l 30,1996, Refueling Outage (RFO) 11 Inservice Inspection (ISI) Plan" , that a plant shutdown l in September 1996 revealed a significant increase in recirculation piping dose rates in the drywell and we were evaluating the RFO#11 ISI inspection schedule to identify the need for relief due to these elevated radiation dose levels. Our evaluation concluded approximately 60 man-rem exposure can be averted by deferring certain drywell ISI examinations to RFO#12 l
and by performing them after the chemical decontamination of the recirculation system, which '
is planned for RFO#12. Therefore, we seek specific relief from RFO#11 ISI requirements.
The scope of the relief request (as specified in section A of this letter) applies to (i) ASME i Section XI inspections related to nozzle-to-reactor pressure vessel welds, (ii) ASME Class I j piping welds, and (iii) Generic Letter 88-01 IGSCC related examinations. Deferral of ASME j Section XI required inspections would be for nine months from the first to the second ISI l period, and IGSCC susceptible weld inspections would be deferred for one cycle (2 years). j The relief request is submitted pursuant to 10 CFR 50.55a(a)(3)(ii) because compliance with ;
the RFO#11 schedule would result in a radiological exposure hardship to NDE examination '
and craft personnel without a compensating increase in the level of quality and safety. Details of the radiological hardship are provided in section B of this letter.
The granting of relief does' not increase the risk to the public health and safety and is necessary to achieve 10 CFR 20 "as-low-as-reasonably-achievable" (ALARA) requirements for examination and craft personnel. Quality and safety considerations are presented in section C of this letter. I
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We request NRC review and approval of our relief requests in time to support RFO#11 which is current!y scheduled for February 1,1997.
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l A. Scope of Relief Reauests:
Relief Reauest #1: (Nozzle-to-Vessel Welds and RadiL l Relief from ASME Code,Section XI, Table IWB-2500-1, Examination Category B-D for full penetration nozzle welds in reactor vessel is requested. This section requires volumetric l examination of all nozzle welds and inside radii (Items B3.90 and B3.100) within each ten-year l interval. As shown in Enclosure A, examinations of N1A, N2A, and N2B nozzle-to-vessel j welds and N1A, N2A, and N2B nozzle-to-vessel inner radii are currently scheduled for !
RFO#11. BECo seeks relief from these RFO#11 examinations to defer them to RFO#12.
Relief Reauest #2:(Pioina Welds).
Relief is requested from ASME Section XI, Table IWB-2500-1, Examination Category B-J (ltems B9.10 through 89.40) for pressure retaining welds in pipes, which requires surface and/or volumetric examination of a 25% sample population within each ten-year interval. Category B-F i for dissimilar metal welds requires 100% examination every 10 years. Category B-K-1 integral attachment weld examinations (Item B10.10) are not code-required during the Third and Fourth )
Ten-Year ISI intervals; however, the NRC has required that an augmented 10% sample be examined at Pilgim during the current Third interval. Additionally, most of these piping welds fall under Generic Letter 88-01 (IGSCC) Category A augmented inspection requirements. GL
, 88-01 Category A requirements are coincidentally the same as Category B-J of the code (25%
l every 10 years). !
l BECo has scheduled inspections of a portion of all B-J, B-F and B-K-1 welds during RFO#11 to comply with code and augmented examination requirements. A significant number of piping j
welds and lugs are scheduled for this inspection. BECO seeks relief from a portion of these RFO#11 weld examinations (listed below) by deferring them to RFO#12.
l Pilarim ASME Weld No. Code System GL 88-01 Comments Cateoorv Cateaorv 2R-N1B-10 B-J RECIRC A 2R-N1 B-11 B-J RECIRC A 2R-nib-9BC-1 B-J RECIRC A 2R-N18-14HL2(4) B-K-1 RECIRC N/A I
RPV-N-16A-R-1 B-F RWL N/A 1-A-9 B-J MS N/A l 1-A-7 B-J MS N/A 1-A-8 B-J MS N/A-1-A-8HLi(8) B-K-1 MS N/A 10R-0-12 B-J RHR A H.S?
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- Note: High Stress Welds (H.S.) are also deterred to RFO#12. ASME Section XI, Table IWB-2500-1, Examination Category B.J (item B9.11 thru B9.40) are pressure retaining pipe welds at terminal ends or where the stress level exceeds 2.4Sm or usage factor exceeds 0.4.
The above listed examinations, if deferred from the first to the second period of the Third Ten-l
, year interval, would require relief from two sections of the ASME XI code. Paragraph IWB-l 2420(a) requires that the sequence of examinations be repeated during each interval, j l Additionally, paragraph IWB-2412(a) states (via Table IWB-2412-1) that at least 16% but not ;
more than 34% of the scheduled IS! program examinations for each category must be l completed by the end of the first 40 month inspection period of each interval. Upon approval of !
relief, the Category B-J and B-K-1 e.xaminations will be 12% and 0% at the end of the first l l ' period. '
BECo proposes to complete the above examinations during RFO#12. RFO#12 represents 4 years of operation for the present ISI interval and is nine months into the second inspection
, period. Since this operational period is only slightly longer than the specified inspection period of 3 years, the intent of the code, if not the precise time period, is satisfied. I Relief Reauest #31lGSCC Welds)
Relief from the NRC Generic Letter 88-01 commitment to inspect Category D welds is i requested. This commitment falls within the scope of PNPS Operating License Amendment ;
No. 75, Long Term Program Plan, Schedule B requirements. i GL 88-01 requires examination of all Category D recirculation pipe safe-end welds every two I refueling outages. Six recirculation safe-end welds (5 Category D and one Category A) are !
scheduled for examination during RFO#11. BECo seeks one-time relief from the examination !
of two Category D (N2A and N28) and one Category A (N1A) safe-end weld during RFO#11.'
BECo proposes completing these examinations during RFO#12. However, these welds may be subject to a reduction of Category D weld examination requirements if authorized by the NRC in response to BECo Letter # 94-111, dated October 13,1994, and BWR Owners Group (BWROG) resolution of NRC Safety Evaluation Report (SER) findings conceming BWROG ]
1opical Report NEDC-319151P. 1 The attached isometric drawings (Enclosure C) indicate welds included in the above relief requests.
B . Reason for the Relief Reauests - Radioloalcal ExDosure Hardship Pilgrim is committed to keeping personnel radiation exposure as-low-as-reasonably-achievable (ALARA) to comply with 10 CFR 20.
During our September 1996 outage, containment (drywell) dose-rate data was gathered and used to update our ISI ALARA assessments. This data indicated dose rates in the drywell were significantly higher than expected. We attribute the elevated dose-rates to the use of hydrogen water chemistry (HWC) that we employ to mitigate potential IGSCC in susceptible stainless steel components.
l We reassessed the expected RFO#11 personnel exposure rates based on our September 1996 containment dose rate data. The expected dose-rates for certain ISI examinations are significantly higher than our previous estimate. Hence, proceeding with the examinations 3
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during RFO#11 is inconsistent with ALARA goals and presents a radiological exposure hardship to NDE and craft personnel performing these examinations.
To reduce personnel exposure, chemical decontamination of the recirculation system will be necessary. Implementation of chemical decontamination during RFO#11 is not practical because there is not enough-time to evaluate the outage sequence impact, understand industry experience to maximize the effectiveness of decontamination, and plan and execute dose reduction strategies. Accordingly, we will perform chemical decontamination in RFO#12.
The attached Table A provides a breakdown of the original and revised exposure rates associated with each examination for which we are requesting relief. A summary of the combined exposures follows:
RFO#11 estimates for inspections included in Relief Request #1 and 3 = 40.40 Rem RFO#11 estimates for inspections included in Relief Request #2 = 26.38 Rem Total RFO#11 dose estimates = 66.78 Rem If we defer these examinations to RFO#12, we will have time to implement a dose reduction i strategy that includes chemical decontamination of the recirculation system. This strategy should produce significant savings in personnel exposure (see attached Table B) as summarized below:-
RFO#12 dose from Relief Request # 1 and 3 = 1.80 Rem RFO#12 dose from Relief Request # 2 = 4.64 Rem Total RFO#12 dose = 6.44 Rem ,
We estimate _ that granting the requested relief, when combined with chemical decon4mination, will reduce exposure by approximately 60 man-rem. In addition, we are in the process of implementing depleted zinc injection which may provide further dose reduction.
Therefore, we request the above specified ISI relief, which would allow time to implement strategies to mitigate personnel exposure when the deferred examinations are performed.
C. Quality and Safety Considerations in Support of Relief Reauests The following technical considerations support our RFO#11 ISI examination relief requests:
- 1. Justification for Relief Requests # 1 and 3 (a) Mechanics and Operating Experience.
The purpose of the inspection program is to identify flaw indications or conditions that, when evaluated in accordance with the requirements of the Code, will assure _ the component is acceptable for continued service. The N1A, N2A and N2B nozzles were inspected in 1984 (see Enclosure A, ISI N1 and N2 Nozzle Inspection Schedule), and no relevant indications were found.
In 1995 (RFO#10) the reactor vessel shell and beltline welds were inspected in compliance with the NRC's augmented examination requirement for reactor pressure vessels. These welds had been exposed to service induced loads and neutron fluence that was more severe than the nuzzle wcids. The probability of flaw initiation is, therefore, greater in this 4
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region, yet no flaws were discovered during this inspection. Thus, based on the inspection history, there is high confidence these welds are absent of flaws, and these nozzle .
l inspections can be deferred by one cycle.
However, if a flaw of detectable size was assumed to develop in a nozzle shortly after the 1984 inspection and grew at stable growth rates until the next inspection interval (i.e.,
RFO#12), the final flaw size would not compromise the integrity of the nozzle. Maximum stress cycles were assumed together with existing nozzle analyses to confirm stable crack growth is assured. Thus, the structural integrity for all normal, emergency and faulted conditions would be maintained.
In the unlikely event that a flaw propagated through-wall during this time, crack growth is stable, and catastrophic failure would not occur. Therefore, the affected line would not completely sever, and extensive leakage would occur before failure. Any amount of l leakage, however small, would be identified bv the drywell leak detection system in time to take corrective action.
(b) Hydrogen Water Chemistry (HWC).
NRC Generic Letter 88-01 requires inat all nozzle safe-end welds made of non-lGSCC resistant materials be inspected evtaf 2 refueling outages. These welds are defined as
" Category D"in GL 88-01. The Pilgrim reactor vessel Category D nozzle safe-ends have material which is susceptible to intergranular stress corrosion attack; however, Pilgrim has employed Hydrogen Water Chemistry (HWC) since 1989. Hydrogen injection provides j protection against IGSCC development and will arrest crack growth. l l
The N2A and N2B nozzles, currently scheduled for inspection during RFO#11, were previously inspected in 1993 after the HWC system had been operating for four years. No evidence of IGSCC was found during this inspection. Therefore, deferral of the nozzle safe-end inspection for one additional cycle is technically justifiable. Should a nozzle safe-end IGSCC related flaw develop and propagate through-wall during this time, any leakage would be identified by the drywell leak detection system in time for corrective action to be taken.
PNPS requests a deferral of three safe-end weld inspections based on the technical reasons specified above and the fact that HWC was in operation during cycles 9,10, and
implemented during cycle 12 reducing potential crack growth that might occur without HWC. Pilgrim employs HWC and practices reactor coolant chemistry techniques that ,
mitigate IGSCC. In addition, past inspections of the subject components have identified no j indications, and crack propagation rates are sufficiently. slow to minimize the risk of I component failure prior to the proposed RFO#12 examinations. Therefore, granting a deferral of the specified examinations to RFO#12 to reduce personnel radiation exposure
' does not represent a increase in risk to the public health and safety.
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l Based on the known fracture toughness of the nozzle-to-vessel welds and the mitigating actions taken to arrest crack growth in IGSCC susceptible welds, a one cycle deferral of the l inspections will not affect the integrity of the vessel nozzles or the capability of the nozzles to l perform their intended function; therefore, such deferral will not decrease the level of quality or j safety of the affected components.
- 2. Justification for Relief Request #2 only: Operating Experience.
l The impact of deferring the selected pipe weld inspections for one additional cycle is inconsequential based on operating history and the lack of indications found during previous inspections. We have requested relief for fourteen welds. Nine of the listed welds were l replaced in 1984 with IGSCC-resistant materials and have experienced five operating cycles
! since replacement. Four welds have been in service for ten operating cycies and are in their third inspection interval. One was replaced in 1987 and has seen four operating cycles. All the welds were previously inspected at least once, (and in some instances more than once) after having experienced a significant number of operating transients. Thus, a one cycle deferral of
- the inspections will not affect the integrity of the welds or the capability of the system to
! perform its intended function and, therefore, such deferral will not decrease the level of quality or safety of the affected components.
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D. Commitments:
This letter contains the following commitments:
- 1. Implementation of a dose reduction strategy (chemical decontamination) during RFO#12 prior to performing the deferred inspections.
- 2. Inspections of deferred nozzle-to-vesselwelds and radii during RFO#12.
i 3. Inspection of deferred piping welds during RFO#12.
- 4. Inspection of deferred GL 88-01 Category D recirculation safe-end welds during RFO#12 or reduced inspections of Category D welds if authorized by the NRC in l accordance with BECo letter No.94-111, dated October 13,1994.
! Should you wish further information on this request, please contact Walter Lobo at (508)
- j. 830-7940.
E. T. Boulette, PhD WGUdmc/rfoisir3 Attachments:
Table A: Dose Estimates for Relief Requests.
l Table B: Dose Savings due to Dose Reduction Strategies.
Enclosure A: Pilgrim ISI N1 and N2 Nozzle Inspection Schedule.
- Enclosure B
- Pilgrim Hydrogen Water Chemistry.
Enclosure C: Isometric Drawings (ISil10-1 A, ISil1-1SHT 1,1S1154-1, ISil54-4, & ISil2RA) 4 6
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Project Manager Division of Reactor Projects - 1/Il Mail Stop: 14D1 U. S. Nuclear Regulatory Commission 1 White Flint North f 11555 Rockville Pike i Rockville, MD 20852 U.S. Nuclear Regulatory Commission !
Region I f l 475 Allendale Road i King of Prussia, PA 19406 ;
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Senior Resident inspector Pilgrim Nuclear Power Station t I
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TABLE A: RFO#11 DOSE ESTIMATES ASSOCIATED WITH RELIEF REQUESTS Dose Estimate for Relief Reauests #1 and 3 (N1 A. N2A and N2B nozzle-to-vessel. inner radii and safe end weld examinations)
Nozzle Oriainal Dose Estimate New Dose Estimate increase e
N1A 6.60 13.20 6.60 ,
N2A 4.32 13.60 9.30 !
N2B 4.32 13.60 9.30 Total Est. Rem 15.24 Rem 40.40 Rem 25.2 Rem Dose Estimate for Relief Reauest #2 ,
e B/_elci Oriainal Dose Estimate New Dose Estimate increase :
Rem Rem Rem 2R-N1B-10 0.82 2.05 1.23 2R-N1B-11 0.82 2.05 1.23 .
2R-N1B-9BC-1 0.82 2.05 1.23 l 2R-N18-14HL2(4) 0.82 2.05 1.23 RPV-N-16A-R-1 1.58 1.90 0.32 1-A-7 0.27 1.00 0.73 l l 1-A-8 0.27 1.00 0.73 l l 1-A-9 0.32 1.28 0.96 1-A-8HLi(8) 0.27 1.00 0.73 1 10R-0-12 1.60 2.40 0.80 1 l 10R-0-6 1.60 2.40 0.80 10R-0-7 1.60 2.40 0.80 10R-0-8 1.60 2.40 0.80 10R-0-9 1.60 2.40 0.80 Total Est. Rem 13.99 Rem 26.38 Rem 12.39 Rem Total New Dose Estimate for Relief Request #1,2 and 3 = 40.40+26.38 = 66.78 Rem Total Increase in Dose for Relief Request #1,2 and 3 = 25.20+12.39 = 37.59 Rem I
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TABLE B. RFO#12 DOSE ESTIMATES ASSOCIATED WITH RELIEF REQUESTS Dose Estimate for Relief Reauests #1 and 3 (N1A. N2A and N2B nozzle-to-vessel. inner radii and safe end weld examinations)
Nozzle New Dose Estimate Dose Estimate Followina !
Rem Decon* !
8 El l N1A 13.20 .566 N2A l 13.60 .616 '
N2B 13.60 .616 j 1
Total Est. Rem 40.40 Rem 1.80 Rem )
Dose Estimate for Relief Reauest #2 l
Weld New Dose Estimate Dose Estimate Followina I Rem Decon* 1 Rem 2R-N1B-10 2.05 0.255 2R-N18-11 2.05 0.255 2R-N1B-9BC-1 2.05 0.255 2R-N1B-14HL2(4) 2.05 0.255 RPV-N-16A-R-1 1.90 1.540 1-A-7 1.00 0.125 1-A-8 1.00 0.125 1-A-9 1.28 0.160 1 A-8HL1(8) 1.00 0.125 10R-0-12 2.40 0.300 1 I
10R-0-6 2.40 0.300 10R-0-7 2.40 0.300 10R-0-8 2.40 0.300 10R-0-9 2.40 0.300 Total Est. Rem 26.38 Rem 4.640 Rem l
The above estimate is based on a dose reduction factor of 8.0.
I Total Estimated Exposure for RFO#12 = 1.80 + 4.64 = 6.44 Rem Total Estimated Savings for Relief Request #1,2 and 3 = 66.78 - 6.44 = 60.34 Rem l
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PILGRIM ISI N1 & N2 N0ZZLE INSPECTION SCHEDULE '*~ ~
YEAR l l l 1 RF0 6 7 8 9 to 11 12 13 14 15 16 17 16 19 20 2nd 10 Year Interval 3rd 10 Year Interval 4th 10 Year Interval NIA N2G NIB NIA N2C NIB N2G ROZZ1e t.o N2A N21, N2D N2A N2B N2N N2B N2K N2E N2B ^ N2E N2K Vessel Weld N2C N2P N2F N2J N23 (code item B3.90) m Z
O NIA N2G NIB NIA N2C NIB N2G {
a o nogg}e {nner N2A N211 N2D N2A N2D N211 m N2B N2K N2E N2B A N2E N2K C N2r :o radius exam N2C N2J i
l N2P N2J A
(code item B3.100) >
- I 4 NIB N2A NIB N2Al NIB N2A NIB N2A Safe end Nec N2B Nec maj Nec N2B N2c Nan NIA N2D N2G N2D N2G N2D N2G N2D N2G WCldS ~ ' ~
N2E N2il N2K N211 N2K N211 N28 N211 N2P N2K N2P N2K N2P N2K N2F N2K (GL88-01 & N2J N2J [NIAl N2J N2J code item B5.10) l i
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ygia 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 O
I ENCLOSUREB l Pilarim Hydroaen Water Chemistry l
The current inspection schedule requirements for reactor recirculation piping category "D" welds in accordance with NUREG 0313 are 100% every two cycles. This schedule allows for some potential crack growth bounded by NUREG 0313. However, no credit is taken for HWC, which is recognized as a mitigator of stress corrosion cracking in stainless steel at an Electrochemical Corrosion Potential (ECP) of < -230mV.
- it is also recognized HWC is more effective if reactor water conductivity is maintained far below 0.3 S/cm.
PNPS requests a deferral of three safe-end weld inspections based on both the mechanical i
l reasons (Relief Request #1 justifications) and the fact that HWC was implemented in cycles 9, 10 and 11. HWC will continue to be implemented in cycle 12 to reduce the potential crack growth that otherwise might occur without HWC. An estimate of that reduced crack growth is
! based on the BWRVIP crack growth model as submitted to the staff in BWRVIP-14, " Evaluation l of Crack Growth in BWR Stainless Steel RPV internals".
HWC was started at PNPS in 1989 during cycle 8. The following table summarizes chemistry
! conditions in the reactor recirculation piping since 1991:
t l Table 1 Cycle % HWC Availability Avg. Reactor Water Cond ( S/cm)
! 9 ~56% '10 10 ~75% 3.15 11 -85% -0.13
% HWC Availability is defined as:
l Hours ECP < -230 mV Hours service temp > 2007 The reactor water conductivity was averaged from monthly time-weighted averages. To add some conservatism, a 0.2 S/cm conductivity was assumed along with an ECP of -230 mV. In actuality, reactor water conductivity was much less and ECP, on average, was generally in the range of -400 to -500 mV. This simplifies the discussion when utilizing information in BWRVIP-
- 14. The following table summarizes the relative crack growth at 0.2 S/cm and approximates i the reduction in crack growth at varying ECPs and HWC availability:
Table 2 ECP 200 -230 -360 500 l (mV) (NWC Condition) 4 Crack Growth 4.5 X 10 9 X 10~7 6 X 10~7 3.5 X 10~7 (Inches /Hr)
Crack Growth Reduction @ 100% -
5X 7.5X 13X Availability Crack Growth Reduction 50% Availability -
2.5X 3.75X 6.5X 11
If a worst case condition is assumed (ECP is at -230 mV for 50% of the time and conductivity at 0.2 S/cm) then a crack growth reduction of - 2.5 times is realized under HWC conditions as compared to normal water chemistry (NWC) conditions. As can be seen from the above table, much higher crack growth reductions are realized if HWC availability is higher and ECP is maintained less then -230 mV. This has been the trend at PNPS. Since cracks have not yet been observed in the safe-end welds of concern, the current practices should serve to continue to mitigate potential cracking.
Based on these chemistry mitigating actions taken to arrest crack growth in IGSCC susceptible .
welds, a one cycle deferral of the inspections will not affect the integrity of the vessel nozzles or the capability of the nozzles to perform their intended function; therefore, such deferral will not decrease the level of quality or the safety function of the affected components.
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t ENCLOSURE C lsometric Drawings (ISil10-1 A, ISili-1SHT 1, ISil54-1, ISil54-4, & ISil2RA) l l
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