ML20153A976

Forwards RAI Re GL 97-01, Degradation of Crdm/Cedm Nozzle & Other Vessel Closure Head Penetrations, Responses for Plant,Unit 2 & Relationship of Responses to TR CE NPSD-1085. Response Requested within 90 Days of Receipt of Ltr

ML20153A976
Person / Time
Site:	Millstone
Issue date:	09/16/1998
From:	Mcdonald D NRC (Affiliation Not Assigned)
To:	Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO.
References
GL-97-01, GL-97-1, NUDOCS 9809220257
Download: ML20153A976 (7)

Text

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l 9 ner ug p t UNITED STATES s j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666 0001 i

%,***** September 16, 1998 Mr. Martin L. Bowling, Jr. f0 Recovery Officer - Technical Services Northeast Nuclear Energy Company clo Ms. Patricia A. Loftus Director- Regulatory Affairs P.O. Box 128 Waterford, CT 06385

SUBJECT:

GENERIC LETTER (GL) 97-01," DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS" RESPONSES FO 'l MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2, AND RELATIONSHIP OF THE RESPONSES TO TOPICAL REPORT NO. CE NPSD-1085

Dear Mr. Bowling:

On April 1,1997, the staff issued Generic Letter (GL) 97.01, " Degradation of CRDM/CEDM

[ Control Rod Drive Mechanism / Control Element Drive Mechanism) Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting, in part, that addressees provide a description of the plans to inspect the vessel head penetration (VHP) nozzles 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 the 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 Combustion Engineering Owners Group (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 ano 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 1 Southern California Edison Company - San Onofre Units 2 and 3 9809220257 990916 F PDR A[ ROCK 05000336 "

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M. L. Bowling Septemt.er 16, 1998 The CEOG submitted its integrated program and Topical Report No. CE NPSD-1085 to the staff on July 25,1997.

By letters dated April 4 and July 30,1997, you provided Northeast Nuclear Energy Company's (NNECO's) 30-day and 120-day responses to the GL. In the July 30,1997, letter, you indicated that NNECO is a member of the CEOG and a participant in the CEOG integrated program that was developed to address the staffs requests in GL 97-01. By letter dated February 12,1998, you provided the information requested by the GL on inspection activities of CEDM nozzle and other vessel head closure penetrations and also indicated that the information in Topical Report No. CE NPSD-1085 is applicable with respect to the assessment of VHP nozzles for the Millstone Nuclear Power Station, Unit No. 2.

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 the staffs inquiries in the form of a request for additionalinformation (RAl). The staff requests a response to this RAI within 90 days of receipt. It should be noted that similar staff requests have been issued to other CEOG member utilities. As was the staffs 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 facility. The staff appreciates the efforts expended with respect to this matter.

Sincerely, Original signed by:

Daniel G. Mcdonald Jr., Senior Project Manager Millstone Project Directorate Division of Reactor Projects - 1/ll Office of Nuclear Reactor Regulation Docket No. 50-336

Enclosure:

Request for Additional Information cc w/ encl: See next page '

DISTRIBUTION:

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OFFICE MSPD:PM m, A MSPD:LA\ h IJ MSPD:D NAME DMcDonddA J LBerry M\ WDean DATE 09/lt98 W^ 09/f/98 09698 OFFICIAL RECORD COPY

i M. L. Bowling The CEOG submitted its integrated program and Topical Report No. CE NPSD-1085 to the staff on July 25,1997.

By letters dated April 4 and July 30,1997, you provided Northeast Nuclear Energy Company's (NNECO's) 30-day and 120-day responses to the GL. In the July 30,1997, letter, you indicated that NNECO is 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. By letter dated February 12,1998, you provided the information requested by the GL on inspection activities of CEDM nozzle and other vessel head closure penetrations and also indicated that the information in Topical Report No. CE NPSD-1085 is applicable with respect to the assessment of VHP nozzles for the Millstone Nuclear Power Station, Unit No. 2.

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 i NPSD-1085. The enclosure to this letter forwards the staff's inquiries in the form of a request for additional information (RAl). The staff requests a response to this RAI within 90 days of receipt. 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 address these inquiries j 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 facility. The staff appreciates the efforts expended with respect to this matter.

Sincerely, Daniel G. Mcdonald Jr., Senior Project Manager Millstone Project Directorate Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket No. 50-336

Enclosure:

Request for Additional Information cc w/ encl: See next page

i i

i* .

l l Reauest for Additional Information Combustion Enaineerina Owners Group (CEQfal l

l Resoonse to Generic Letter (GL) 97-01

, "Deoradation of CEDM Nonle and Other l

Vessel Closure Head Penetrations"

! -j l Tooical Reoort No. CE NPSD-1085. Revision 0 l

l The ABB - Combustion Engineering Corporation's (ABB-CE's) methodology for predicting the susceptibility of vessel head penetration nozzles in the Combustion Engineering Owners Group I

(CEOG) plant designs is provided in Section 2.4 of CE Topical Report No. CE NPSD-1085, which I

was submitted to the staff on July 25,1997. ABB-CE's methodology applies a probabilistic I l inspection timing model (PITM) to predict the probability of having a given Control Element Drive l l Mechanism (CEDM) penetration nonle or in-core instrumentation (ICl) nonle fail in service.

l With respect to the PITM model, the term " failure" does not refer to a compromise of the structuralintegrity of the reactor coolant pressure boundary, but rather that the presence of a q non-throughwall flaw 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 Control Rod Drive Mechanism penetration nonles in ABB-CE l designed plants, and lately has adopted a CEDM penetration nonle 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 l its decision to change the susceptibility model being adopted by the CEOG member utilities.

The staff requests that the following information be provided with respect to the content of your plant-specific response to GL 97-01, and its relationship to the CEOG integrated program for i assessing the potential for CEDM penetration nonles to undergo primary stress corrosion cracking (PWSCC) or intergranular attack (IGA): j Designate which crack susceptibility modelis being endorsed for the assessment of CEDM penetration nonles at your plant. Indicate how the susceptibility model being endorsed relates to the CEOG's integrated program for assessing the CEDM penetration nonles at ABB-CE designed plants, and whether or not the design of the susceptibility model is consistent with the contents of Topical Report No. CE NPSD-1085. If the ABB-CE's PITM modelis being endorsed for the assessment of CEDM penetration nonles at your plant, address the items a. - e;that follow, if the Dominion Engineering susceptibility modelis being endorsed for the assessment of CEDM penetration nonles et your plant, address the items f. - 1. that follow.

I l

Enclosure

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. ._ . . . ~ . . . -. - . - - . -. . - - ..

l l*

2-l l' If the PITM models are beino endorsed for the assessment of vour CEDM oenetration nozzles:

I

a. Provide an expanded discussion and additional details describing how the time-to-failure l model in the PITM relates to the PITM's time-to-initiation model. In particular, include an i

expanded discussion of how the PITM model relates growth of postulated flaws to the time-l 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, the vessel head instrumentation nozzles at your plant relative to the rankings of those at the other CEOG member plants.

c. Provide a description of how the PITM model for assessing postulated flaws in vessel head l penetration nozzles was benchmarked, and list and discuss the standards the models were l benchmarked against.

d. Provide any additionalinformation 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, 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 Dominion Enoineerino is beino endorsed for the assessment of your CEDM oenetration nozzles:

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 benchmarked, and provide a listing and discussion of the standards the models were benchmarked against.

l. Provide the latest model susceptibility rankin0s of CEDM penetration nozzles in CEOG member plants based on the results of the Dominion Engineering susceptibility model analyses of these CEDM and ICI nozzles.

Millstine Nucle:r Power St:t!on Unit 2 cc:

Lillian M. Cuoco, Esquire Mr. F. C. Rothen l Senior Nuclear Counsel- Vice President- Work Services  !

Northeast Utilities Service Company Northeast Utilities Service Company .

P. O. Box 270 P. O. Box 128 Hartford, CT 06141-0270 Waterford, CT 06385 Mr. John Buckingham Emest C. Hadley, Esquire Department of Public Utility Control 1040 B Main Street ,

Electric Unit P.O. Box 549 '

10 Liberty Square West Wareham, MA 02576 New Britain, CT 06051 1 Mr. John F. Streeter Mr. Kevin T. A. McCarthy, Director Recovery Officer - Nuclear Oversight Monitoring and Radiation Division Northeast Utilities Service Ccmpany 1 Department of Environmental Protection . P. O. Box 128 1 79 Elm Street Waterford, CT 06385 Hartford, CT 06106-5127 <

Mr. David B. Amerine Regional Administrator, Region i Vice President - Human Services U.S. Nuclear Regulatory Commission Northeast Utilities Service Company

.. 475 Allendale Road P, O. Box 128 King of Prussia, PA 19406 Waterford, CT 06385 First Selectmen Mr. Allan Johanson, Assistant Director Town of Waterford Office of Policy and Management Hall of Records ~ Policy Development and Planning l 200 Boston Post Road . Division Waterford, CT 06385 450 Capitol Avenue - MS# 52ERN l P. O. Box 341441  !

Mr. Wayne D. Lanning, Director . Hartford, CT 06134-1441 Millstone Inspections 4 Office of the Regional Administrator Mr. M. H. Brothers 475 Allendale Road Vice President - Operations King of Prussia, PA 19406-1415 Northeast Nuclear Energy Company P.O. Box 128 Charles Brinkman, Manager Waterford, CT 06385 Washington Nuclear Operations ABB Combustion Engineering Mr. J. A. Price 12300 Twinbrook Pkwy, Suite 330 Director - Unit 2 Rockville, MD 20852 Northeast Nuclear Energy Company P.O. Box 128

. Senior Resident inspector Waterford, CT 06385 Millstone Nuclear Power Station clo U.S. Nuclear Regulatory Commission P.O. Box 513 Niantic, CT 06357

Millst:ne Nucle:r Pcwer StLiion Unit 2 cc: l Mr. B. D. Kenyon (Acting) - Attomey Nicholas J. Scobbo, Jr.

Chief Nucler Officer- Millstone Ferriter, Scobbo, Caruso, Rodophele, PC ,

Northeast Nuclear Energy Company 1 Beacon Street,11th Floor P.O. Box 128 Boston, MA 02108  !

Waterford, CT 06385 Mr. J. P. McElwain l Citizens Regulatory Commission Recovery Officer- Millstone Unit 2 i ATTN: Ms. Susan Perry Luxton Northeast Nuclear Energy Company l 180 Great Neck Road P. O. Box 128 Waterford, CT 06385 Waterford, Connecticut 06385 Deborah Katz, President Citizens Awareness Network

)

i P. O. Box 83 Shelbume Falls, MA 03170 l 1

The Honorable Terry Concannon Co-Chair. i Nuclear Energy Advisory Council )

Room 4035 i Legislative Office Building I Capitol Avenue l

Hartford, CT 06106  ;

Mr. Evan W. Woollacott  !

Co-Chair )

Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, CT 06070 Little Harbor Consultants, Inc.

Millstone - ITPOP Project Office

]

P. O. Box 0630 1 Niantic, CT 06357-0630 l Mr. Daniel L. Cuny Project Director Parsons Power Group Inc.

2675 Morgantown Road '

Reading, PA 19607