ML20151V195

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Forwards Request for Addl Info Re GL 97-01, Degradation of Crdm/Cedm Nozzle & Other Vessel Closure Head Penetration. Response Requested within 90 Days of Date of Ltr
ML20151V195
Person / Time
Site: Waterford 
Issue date: 09/10/1998
From: Chandu Patel
NRC (Affiliation Not Assigned)
To: Dugger C
ENTERGY OPERATIONS, INC.
References
GL-97-01, GL-97-1, TAC-M98610, NUDOCS 9809140149
Download: ML20151V195 (6)


Text

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4 UNITED STATES M2 g

j NUCLEAR REGULATORY COMMISSION o

2 WASHINGTON, D.C. 20666-0001 Y.....,o September 10, 1998 i

Mr. Charles M. Dugger Vice President Operations Entergy Operations, Inc.

P. O. Box B Killona, LA 70066

SUBJECT:

GENERIC LETTER (GL) 97-01," DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS" RESPONSES FOR WATERFORD STEAM ELECTRIC STATION, UNIT 3 AND THE RELATIONSHIP OF THE RESPONSES TO TOPICAL REPORT NO. CE j

NPSD-1085 (TAC NO. M98610)

Dear Mr. Dugger:

On April 1,1997, the staff issued GL 97-01," Degradation of CRDM/CEDM Nozzle and Other 2

Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish to determine their inspection activities based on an integrated industry inspection program.

.., and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspection program.

As a result, the CEOG determined that it was appropriate for its members to develop a cooperative integrated inspection program in response to GL 97-01. The CEOG program is documented in Topical Report No. CE NPSD-1085, "CEOG Response to NRC Generic Letter 97-01, Degradation of CEDM Nozzle and Other Vessel Closure Head Penetrations," which was prepared by ABB Combustion Engineering Nuclear Operations (ABB-CE) on behalf of the CEOG and the following CEOG member utilities and plants:

Arizona Public Service - Palo Verde, Units 1,2, and 3 Baltimore Gas and Electric Company - Calvert Cliffs, Units 1 and 2 Consumers Energy - Palisades Entergy Operations, Inc. - Arkansas Nuclear One, Unit 2 and Waterford Unit 3 Florida Power and Light Company - St. Lucie, Units 1 and 2 Northeast Utilities - Millstone, Unit 2 Maine Yankee Atomic Power Company - Maine Yankee Nuclear Plant Omaha Public Power District - Fort Calhoun, Unit i Southern Califomia Edison Company - San Onofre Units,2 and 3 The CEOG submitted its integrated program and Topical Report CE NPSD-1085 to the staff on

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July 25,1997.

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2 The staff has determined by your letters dated April 30 and July 28,1997, that you were a member of the CEOG and a participant in the CEOG integrated program that was developed to address the staff's requests in GL 97-01. In your above mentioned letters, you also indicated

' that the information in Topical Report CE NPSD-1085 is applicable with respect to the assessment of VHP nozzles at Waterford Steam Electric Station, Unit 3.

The staff has reviewed your responses to GL 97-01, and requires further information to complete its review of the responses as they relate to the CEOG's integrated program for assessing VHP nozzles at CEOG member plants, and to the contents of Topical Report No. CE NPSD-1085. The enclosure to this letter forwards staff's inquiries in the form of a request for additional information (RAI). The staff requests a response to the RAI within 90 days from the date of this letter. It should be noted that similar staff requests have been issued to other -

CEOG member utilities. As was the staff's position before, the staff encourages you to

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address these inquiries in integrated fashion with the CEOG; however, the staff also requests 4 that you identify any deviations from the CEOG's integrated program that may be specific to your facilities. The staff appreciates the efforts expended with respect to this matter.

' Sincerely, ORIGINAL SIGNED BY:

Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects ill/IV

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Office of Nuclear Reactor Regulation Docket No. 50-382

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Enclosure:

As stated.

cc w/ encl: See next page DISTRIBUTION Docket File '

PUBLIC PD4-1 r/f C. Patel

-J.Hannon C.Hawes T. Gwynn, RIV E. Adensam (EGA1)

ACRS Document Name: WAT98610.LTR s)

D/h-1 OFC PM/PD4,1 LA/PD4-1 NAME CPaIe vw CHaweb,lHannon DATE 4/ $ /98 T/M /98

/[U/98 COPY-h/NO YES/NO YES/NO OFFICIAL RECORD COPY

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2 The staff has determined by your letters dated April 30 and July 28,1997, that you were a member of the CEOG and a participant in the CEOG integrated program that was developed to address the staff's requests in GL 97-01. In your above mentioned letters, you also indicated that the information in Topical Report CE NPSD-1085 is applicable with respect to the assessment of VHP nozzles at Waterford Steam Electric Station, Unit 3.

The staff has reviewed your responses to GL 97-01, and requires further iniormation to complete its review of the responses as they relate to the CEOG's integrated program for assessing VHP nozzles at CEOG member plants, and to the contents of Topical Report No. CE NPSD-1085. The enclosure to this letter forwards staff's inquiries in the form of a request for additional information (RAl). The staff requests a response to the RAI within 90 days from the date of this letter. It should be r,oted that similar staff requests have been issued to other CEOG member utilities. As was the staff's position before, the staff encourages you to address these inquiries in integrated fashion with the CEOG; however, the staff also requests that you identify any deviations from the CEOG's integrated program that may be specific to your facilities. The staff appreciates the efforts expended with respect to this matter.

Sincerely, aku ffh j

Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosure:

As stated j

cc w/ encl: See next page

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Mr. Charles M. Dugger Entergy Operations, Inc.

Waterford 3 cc:

Administrator Regional Administrator, Region IV Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drive, Suite 1000 Baton Rouge, LA 70884-2135 Arlington,TX 76011 Vice President, Operations Resident inspector /Waterford NPS Support Post Office Box 822 Entergy Operations, Inc.

Killona, LA 70066 P. O. Box 31995 Jackson, MS 39286 Parish President Council St. Charles Parish Director P. O. Box 302 Nuclear Safety & Regulatory Affairs Hahnville, LA 70057 Entergy Operations, Inc.

P.O.BoxB Executive Vice-President Killona, LA 70066 and Chief Operating Officer Entergy Operations, Inc.

Wise, Carter, Child & Caraway P. O. Box 31995 i

P. O. Box 651 Jackson, MS 39286-1995 Jackson, MS 39205 Chairman General Manager Plant Operations Louisiana Public Serv!ce Commission Entergy Operations, Inc.

One American Place, Suite 1630 P. O. Box B Baton Rouge, LA 70825-1697 Killona, LA 70066 Licensing Manager Entergy Operations, Inc.

P. O. Box B Killona, LA 70066 Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005-3502

s.

Request for Additional Information Regarding Utilities Participating in the Combustion Engineering Owners Group (CFOG)

Response to Generic Letter (GL) 97-01

" Degradation of CEDM Nozzle and Other Vessel Closure Head Penetrations"-

Topical Report CE NPSD-1085, Revision 0 Applicabil;ty of Topical Report Number CE NPSD-1085 to the Plant-specific Responses to GL 97-01 for Participating Member Utilities and Plants in the CEOG The ABB - Combustion Engineering Corporation's (ABB-CE's) methociology for predicting the susceptibility of vessel head penetration nozzles in the CEOG plant designs is provided in Section 2.4 of CE Topical Report No. CE NPSD-1085, which was submitted to the staff in July 25,1997. ABB-CE's methodology applies a probabilistic inspection timing model (PITM) to predict the probability of having a given Control Element Drive Mechanism (CEDM) penetration nozzle or in-core instrumentation (ICl) nozzle fail in service. With respect to the PITM model, the term " failure" does not refer to a compromise of the structural integrity of the reactor coolant pressure boundary, but rather tnat the presence of a non-throughwall flew may require attention or repair.

Since that time, the staff has leamed informally that the CEOG has decided to change the methodology for evaluating the CRDM penetration nozzles in ABB-CE designed plants, and lately has adopted a CEDM penetration nozzle crack initiation and growth susceptibility model that has been developed by the Dominion Engineering Company. However, the CEOG has not submitted an addendum to its response of July 25,1997, informing the staff of its decision to change the susceptibility model being adopted by the Owners Group member utilities. The staff requests the following information be provided with respect to content of your plant-specific response to GL 97-01, and its relationship to the CEOG integrated program for assessing the potential for CEDM penetration nozzles to undergo primary stress corrosion cracking (PWSCC) or intergranular attack (IGA):

1.

Designate which crack susceptibility model is being endorsed for the assessment of CEDM penetration nozzles at your plant (s). Indicate how the susceptibility model being endorsed relates to the CEOG's integrated program for assessing the CEDM penetration nozzles at ABB-CE designed plants, and whether or not the design of the susceptibility modells consistent with the contents of Topical Report CE NPSD-1085. If the ABB-CE's PITM modelis being endorsed for the assessment of CEDM penetration nozzles at your plant (s), address the items a. -

e. that follow. If the Dominion Engineering susceptibility modelis being endorsed for the assessment of CEDM penetration nozzles at your plant (s),

address the items g. - k. that follow.

If the PJIM models are beina endorsed for the assessment of your CEDM oenetration nozzles:

ENCLOSURE

2 Provide an expanded discussion and additional details describing how a.

the time-to-failure model in the PITM relates to the PITM's time-to-initiation model. In particular, include an expanded discussion of how the PITM model relates growth of postulated flaws to the time-to-initiation model, and how the two aspects relate to each other and to the probability of failure methodology.

b.

Provide the latest PITM susceptibility ranking of CEDM penetration nozzles, and if applicable of the vessel head instramentation nozzles at your plant (s) relative to the rankings of those at the other CEOG member plants.

Provide a description of how the PITM model for assessing postulated i

c.

flaws in vessel head penetration nozzles was bench-marked, and list and

)

discuss the standards the models were bench-marked against.

d.

Provide any additional information regarding how the model will be refined to allow the input of plant-specific inspection data into the model's analysis methodology.

e.

Describe how the variability in the product forms, material specifications, l

and heat treatments used to fabricate each CEDM penetration nozzle at the CEOG member utilities are addressed in the PITM model.

If the susceotibility model develooed by Dominien Enoineerina is beina endorsed l

for the assessment of your CEDM oenetration nnnies:

2 f.

Provide a description of how the various product forms, material specifications, and heat treatments used to fabricate each CEDM penetration nozzle at the CEOG member utilities are handled in the Dominion Engineering susceptibility model.

g.

Provide any additional information, if available, regarding how the model will be refined to allow the input of plant-specific inspection data into the model's analysis methodology.

h.

Describe how the Dominion Engineering crack initiation and crack growth models for assessing postulated flaws in vessel head penetration nozzles were bench-marked, and a listing and discussion of the standards the models were bench-marked against.

1.

Provide the latest model susceptibility rankings of CEDM penetration nozzles in CEOG member plants based on the results of the Dominion

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Engineering susceptibility model analyses of these CEDM and ICI nozzles.

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