ML20203F754
| ML20203F754 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/30/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20203D220 | List: |
| References | |
| NUDOCS 9712170457 | |
| Download: ML20203F754 (109) | |
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PREDECISIONAL ENFORCEMENT CONFERENCE OF SOUTHERN CALIFORNIA EDISON COMPANY NUCLEAR REGULATORY COMMISSION REGION IV l
Taken on SEPTEMBER 30,1997 i
?
i Condensed Transcript Prepared By:
Tammie L. Smith, CSR Certined Shorthand Reporter P. O. Box 4601 Fort Worth, Texas 76164-0601 Phone: (817) 625-4940 FAX (817) 625-5684 U
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!amie L. Snith. CSA (817) % -4 M8
PREDF4181celAL [WPONClMENT HEMING * $t?!LSER C.1997 6
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PR0CEED2NG$
1 I'm the Replon Enforrsnent Officer.
2 M. Er3C1KfPs Good efterroon.
2 MA. HOWELL Art flovell. Director 3
l'n tills Hat schof f. Reptonal Administrator. NRC's 3
of Divlelon of heactor $afety.
4 Region TV office.
4 MR. BAREE$t Ian Barnet. Technical s
this af terren ve're hwe to 5
Assistahl. Olvision of Reactor Safety.
conduct en op.it Pre %41stonal Lnforcenent 6
MR. HERMMWs
- Bob Hermann, senior 7
Conference 14 tween the WR0 and Southern California 7
4 vel 63 visor for Material $Clence.
8 Edisoft Coripany to discuse an apprent viciation of 8
MR. DF10CKMN Ken Brockman.
9 WhC requirenente at the company's San Onotre 9
Deputy Director. Division of Reactor Projects.
14 liucler Generating. Unit 2 and 3 reactor 19 MR. FIELD $a Nel Fields. NRR 11 facilities.
11 Project Manager assipi ed to San unofre.
1F The apparent violation involves 12 MR. 79WER$t Dale Powers.
13 the f allwe to inplement actions to preclude 13 Maintenatee Brar.ch. Chler.
' 14 recJrrence of B nottle penettetton cracking on 14 MR. NLNDERSON: Breck Henderson.
l$
Heat W7636, 16 Pttilic Affetts.
16 Defore 100 any further. I'd like 18 MR. RAYS All right. l'h 17 to elic;w the NRC nenbert to introduce themselves 17 Hrolf RaV. Executive Vice President of Couthern 18 and. Hrold, allov vou an opporttrity to introduce le California Edison compenv.
19 Wour folks.
Ib I'll ask the other henbers of our te 1 understand on the phone Ulth us 28 teen hers to go ahead and introduce themselves.
21 today are Dave Nelson from the Office of F1 MN. NUNNI Dwight Nunn,
??
Enfurcenent and J. D. Pilcou fron NRR.
22 Vice President of Engineering and Technical F3 TELEPHONIC RESPONSE: Thank Vou.
P3 Services.
24 Ellis.
24 MR. $HORT Mike SWt. Manager.
P5 MH. SMDDRN l'n Garv Sanborn.
25 Site Technical Services.
7 8
1 MR. $CH00NOVERt Eric Sch00nover.
1 There vill, of course, be no 2
S Wien Deelen Engineer.
2 decintons made during this Conference, but 3
MR. GIBSON: Greg Gibson the 3
aftervrds You vill be inforned of the results.
4 Manager of Conr11ance.
4 T'd like to encotrage Southern Californie Edison 5
MR. SI$f0Si Angel $1stos.
to be candid in providing its perspectives on G
Supervisor. Nuclear Oversight.
these apparsat violations. on their significance.
7 MR. YACXLE4 fon Yackle. Assistant 7
on the circunstances surrounding the apparent 8
Manager of Oserations.
9 violations, on any corrective actions you have 9
MR. H!INf: $leve Hunt. Doninion 9
taken or planned, or any other infornation that 15 Engineering.
10 wou feel bears on this enforcenant decision.
11 MR. MERSCH0FFt. lot n are vou here 11 This la the right tine to talk 12 f # t he nett ing?
12 about your vlevs in terns of application of the 13 MR. WHIffEMORE: Yes. sir.
13 Enforcenent Policy of any errors in the 14 MR. Milf 0N I'n Mike Melton with 14 Inspection Repo't or any inferences in the 15 Artrona Public $nrvice.
15 Insportlen Report that you nav disagree with or 16 MR. WHITTEMORE: John Whittenore.
16 consider to be Inappropriate.
17 Maintenance Dranch.
17 I would like to note that this 10 MR. MERSCHOFFi l'd like to 18 neeting ts open for ptelic observation. I 6 ton't is emphasim the f act as we get started that 19 notice any menters of the pubite here. Dut if P9 conc W this Conference does not nean that the 20 there Vere. I'd point out that it's open for 21 NRC.o M a final determination in this case.
21 observationi not peticipation. It's. In fact, a 22 In fact, this Conference is en 22 neeting between Southern California Edison and the 23 Important part of our deliberettve process in 23 NRC.
24 terns of assuring that all the infornation is in 24 ve would of course answer 25 front of the NE rrior to e decision being nade.
25 truestions following the netting with nenters of f annte L. Snith CSR (0171 WS-4M8
PREDECl$10NAL INF0Kt E NT HEARING * $EPit>mER C. 1997 9
18 1
the public.
I as we kfov at or if there are any avenues that we 2
This heelin0 is telne 2
haven't explored that we feed to put on the table.
3 trafrecrited. ! vould f e'auest any participants to 3
The object is to assure that all 4
Identify thonselves or asstre that their hans tags 4
those issues. that you are given a chance to 5
are visitile to our court reporter who hoperv!!v 5
address anything we think we heard that differs 6
has at least tetts vision to to able to read it.
fron the facts and that we have fully explored all 7
The agenda vill te made part of 7
of the lasues 60 that when we leave this roont if 8
the public record along with the ninutes of this 9
ve disagree, et least we understand where we 9
neeting. Copies of the agenda should have teen 9
disagree.
le na$e evallable.
19
.30 if there kre no questions at 11 Following nu renarks. Gry Santorn 11 this point on the t,asic strs,tture. I'll turn it 12 vill provide sone trief connents on the 12 over to Gary for his remarks on the enforcement 13 linforcenent Policy. And then Art Howell, the 13 process.
14 Director of the Division of henctor Safety. Will 14 M. $MDORN Okay. Thank you.
15 provide some specifics with regard to our 15 tills.
18 understanding and our views of the apparent 1(.
First of all. I'n polno to Just 17 vio!Oflon et this time.
17 triefly cover the purposes of thle Conference w.d 18 The agenda provides for a 18 the NRC's process for naking enforcenent decisions 19 ten ninute recess at the end of -- or a ten-minute 19 and then open it up to any ques.lons you have 28 caucus et the end of the presentation. It's a 20 atout either of those before ve proceed with the 21 useful line for be'h of us.
21 topic todet.
22 I would like to get the NE io 22 MR. NUNN Keep it as af.Jrt as 23 convene in a separate roon. And the ptrpose of 23 pou'd like. Gary.
24 that recess is to quicktv ascertain whether we've R4 MR. SAW10RN Okay. And, in f ac t.
25 heard anything that doesn't conport with the f acts 25 there are some handouts on the table in the front 1
-.. I 11 12 1
of the roon there that explain the process in more 1
But we'd be pleased if you would 2
detall than I'n poing to nov. And I take it from 2
- If you'd just Indicate the Pollev is as it has 3
votr conNents. that you understand the process.
3 teen and nove on.
4 MR. NUNNI ve do.
4 MR. MERSCH0FF Fair enough.
5 MR. SANDORN Okay. vould there 5
MR. $ANDORN Okay.
6 be any tenefit to ne polno through the civil 6
MR. MERSCH0FFt Art.
7 penalty assessment process or how we nake those 7
MR. HovEll Okay. Thank you.
B dacistons?
8 The apparent violation that is the attject of this 9
MR. RAYi No, sir. I don't believe 9
Conference was descrited in oir inspection report le there is.
18 lasued on September the 18th of this year.
11 MR. SANDORN: Okay.
11 In addille.. '+e have the 12 MR. PWI Dut please feel free 12 handouts. Does everybody have a copy of the 13 to -
13 handouts? Okav. That has tf:e apparent violetIon 14 MR. HERSCH0FF vell, no our 14 and the agenda.
15 Ouldance is tf there is a nenber of the pubilc. We 15 In eccordance with our nornal 16 nust 90 through this for completeness.
16 practice, this information, as well as any written 17 MR. RAY: Sure.
17 naterlat that you provide us today, vill be placed 18 MR. MERSCH0FF But if you 18 in the NRC's Pttite Document Roon.
19 understand this process. there's no point --
19 If you believe any of the 28 MR. NW N Stre.
29 information you plan to provide us should be 21 MR. MERSCH0FF But if you a 21 withheld fron the Pttlle Document Roon. vou need 22 MR. RAY: I think in the interest 22 to provide us your basis for withholding and 23 of time ve vould silPulate that we do understand 23 should do so in Urlting. And. additionally. the 24 4t. And there nav te reason for you to have 'o do 24 vrltten transcript of this Enforcenent conference
?$
11 nevertheless.
25 vill be made Ptolicly available, fannte L. Sattn. CSR 1817) 625-4948
PREDEcl$1teiAL ENFolCEMENT HfCIN3 - $EPTEMilER 30. 1997 13 14 1
In telef. the estarent violation 1
And as you are svare. the 2
involved the f ailure to inplenant actions to 2
teunical specifications prevent reactor coolant 3
preclude recurterte of Heat Wr7638 notrie 3
systen pressure toundary leakage owing power 4
penetration cracking, specifically 18 CFR Part 58 4
operations. We accord.ngly consider the recurring 6
Arterdis 3. Criterion ry! requires neaswee to 5
tracking to potentially represent a significant G
established to assure that corditions adverse to 6
- 7 quality are promptly identafled and corrected. In 7
You previous!v provided a position 8
tre esse of signif atant conditions adverse to e
on this natter in a letter dated July 22nd.1997.
9 quality. the nessures shall assure that the cause 9
This letter was included as AttachSent 2 to the 18 of the condillon is determined and corrective if Inspection Rep.rt.
Il actlon taken to preclWe repetition.
11 We hope to receive infornation 12 Contrary to this requirement a 12 during this Conference on the actual links, 13 total of four confitned f ailuress nanely 13 orientation, cause or causes, and corrective 14 through-vall craf king, a $lgniflCant tondtlion 14 actions relative to the not21e cracks that have 15 e3 verse to quelltv. have occurred during 1802 to 15 occurred at San onofre Nuclear c.enerating Station 16 1997 in thtt 2 and Unit 3 reactor coolant systen 16 Unite 2 and 3.
17 Incorel 600 norrie penetrations manuf actured from 17 Additionally, we would like you to 19 Hset WV7638 Ulthout actions being taken to 19 address the basis for your statement in the July 19 preclude recurrette.
19 22nd letter that NIC had agreed that there was no 29 This apparent violation is of 28 safety significance to prinar" "ater stress 21 regulatory concern in that the recurring 21 corrosion cracking, which would justlfy 22 through-vall cratking in the reactor coolant 22 replacenent of not21es.
23 sveten presswe toundary pernits e entinuing 23 At thle time. Mr. Ray. Unless 24 potential for pressure boundary leakage during 24 there's any questions of --
25 power or* rations.
25 MR. MERSCH0FF 1 Just have one 15 16 1
nare thought. As we vent around for the 1
It was trought up that his attendance would be 2
Introductions. I was disappointed to see 2
here. We were told that --
3 Mr. Slagte wasn't here.
3 MR. GIBSONI Yeah. We - we 4
We had hoped that since the safety 4
originally talked with the first date I conf erned 5
assessnent that was done had a key role in this.
5 that he was available. And after that I --
6 that he would he here. In f act. we verlfled that 6
MR. HOWELL I re-confirned with 7
he would 14 available before we agreed to shif ting 7
900 that he would te here.
8 the date of this meeting.
9 MR. MERSCH0FF Well, that's O
MR WUNvi He's had a 9
unfortunate. I would not have agreed to shifting 18 tong-standing trip planned to Europe to celebrate 18 the date had I known he wasn't evallable. But 11 his 38th vedding anniversary.
Il with Mr. $1stos here, we can hopefully accomplish 12 MR. MERSCH0174 I can UMorstand 12 the same purposet and that is. Understanding the 13 that. Was that not known when we --
13 leakage and the intent of the findings in the 14 MR. NUNN1 We *- we --
14 safety assessment.
15 MH. MERSCH0FFs -- roved the 15 MR. RAY: Well, that's our plan.
It meeting?
16 We certainly have a sttastantial part of ci-17 MR NUNils That wasn't av 17 discussion oriented to that, and I hope it vill le understanding that the neeting was contingent on 10 satisfy your - vour interest.
19 his attendance. Maybe that was a 19 MR. MER$CHOFF Okay.
20 hisconnmication.
28 MR. RAY: All right. Thank 900.
g 21 MR. RAY: we understood that 21 Well. I do appreciate the 22 Mr. $1stos. sitting right here. who's responsible 22 scheduling change that was nase. And the reason 23 for the report, had to te here, and to he isi tot 23 was -- unless that - I understood you couldn't be 24 ve did not understand that 1(en Slagte did --
24 here if we didn't change the date.
25 MR. HOWELL We invited hin tvece.
25 I saw that because in av alnost 30 Tanr.:e L. Snith. CSR (0171 625-4940
PHEDECISIOkAL LNFORCLMENT HEA%In $EPILMitLil C.1987 17 13 1
Lars as a licensee, this is f ar and evas the nast i
areas or to be broken into two areas. which !
7 Imortant f.r.fortement Conferer.ca I've ever 2
think of ten. locause they aren't serrated, result 3
attanded.
3 in confusion in the dialog t4 tween the licensee 4
1 think the issues that we'll be 4
and the Agency.
talking about here are profound and transcendent.
First. We accept a absolute G
And perhaps tha host importait reason that i vant G
requirenent for sfritt and liters' compilence with 7
to start with is that I really have no idea what 7
the regulations. And our opinions about their 8
corrective action to take to prevent recurrence of 8
inportance. We don't think are relevant in that 9
this apparent violation.
9 regard.
18 And so vo're here to get 18 And I alnost have connitted to 11 intornation, as wil. And whether 1 take a very.
11 tenory the recent neno fron the conmissioners to IP very nortov interpretation of violation or a broad IP Mr. Callan on the subject of conpliance and 13 and expansive eme. I end up with the sans position 13 safety. And I hope 1 von't violate any of the 14 or anything in between.
14 premises in that hono.
16 ve vill inik about. as Art asked.
1$
But, nevertheless. I think it in 18 why It is we selo what we did about our 18 Inportant for us to talk about strict Allance 17 understanding of the NHC's posillon. And we'll do 17 and nake sure ve have addressed that fully and 18 tti, at sono length and. I hope. suf ficiently.
18 then to talk about. also, what our vlevs are on 19 But I've never been in a position 19 the F.sre Wortant issue of safety and how we view P0 of discussing an issue before where I think the -
P6 our responsibility to maintain safety in the F1 the Agency's record is 50 cleariu contrary to the 21 plant.
22 basis of the violation that, at least, was sent to P2 Doth of then are inportant.
F3 us.
23 They're both linked. But I thit.k ttue discussions P4
$$ let ne begin on that sonber 24 of ten vill get across purposes, and we'll talk 25 note. I'd like our discussion to go into two 25 past each other. When I'n talking about 19 P0 1
conp!!ances you're talking about something that is 1
discussion vill be carried in the niddle.
P transcendent or goes bevond the issue of 2
1 said our opinir.as about the 3
compliance. And then ve reverse roles at sone 3
inportance of various regulatory requirteenta 1 4
point in the discussion. We really don't 4
don't think is inportant in enforcenent space.
effectively connunicate.
But our opinions about the neaning of the 6
So 1*n going to talk in what 1 6
regulations 13. of corse, important in our 7
have to say here about -- in the introduction 7
control.
B about the vlotation and our respnnse to it as we 8
And the reasons why ve have 9
see it now. And then Mike Short will nove into a 9
opinions about what the requirements are. We'll 19 discusslun in which we're not focused on the le give vou. And that's the spirit in which they're il violation or the inspection Report as nuch as we 11 provid.$.
12 are focused on what oua progran tel vnat we have 12 Okay. 7he f act that I an talkinn 13 don?l what our understanding of the Phenonenon is 13 about the apparent violation and the regulatory 14 and to on, 14 aspects don't have to do With that being the F.ve 15 And we won't constrain that 15 inportant tasue. as I've already said. I don't 16 discussion by issu% of whether or not a violation 16 think it is.
17 exists.
17 But it has to do with the fact IS And then at the end I'd like to 18 that I en very insistent upon understanding what 19 cone back and talk about or vlevs of the 19 the = what otr perfornance is in the area of 20 regulatory franPvork Ulthin whlCh this escalated 20 compliance.
21 enforcenent is being considered. sons of the 21 l've been involved in this issue 22 things that Art asked us to talk about.
22 of prinary water stress corrosion cracking 23 So I'll speak at two points, the 23 personally and on behalf of the industry for a 24 beginning and the end. But the bulk of the 24 long tine.
25 discussion and the nost inportant part of the 25 1 think it is inportant for us to I
~
Tannte L. Snith C5R (0171 625-4948 l
. -. ~.,,__ _
PREDEtis10W. ENFOMWI tlCIM SEPTESER O.1997 t1 tt 1
understand exattly what the violation te, 1
respon3IVe, b'It ! " I'll have to dwell on that a 2
primarily where etMlated etiforcement is little bit as I go along.
3 coreldered to that de can insure that there a 3
the Inspect ?on Report. of course.
4 that we take Etion to prevent rectrence.
4 did not contain a Notice of Vloistion on this There's nothing worse, in ny mind.
point. It said it was belne W.thheld pending this 6
than to accept a firse and saw, okay, fines we C
Conference.
7 von't do that agt.6al but not know how to - not "
7 But it did have this statenant in 0
and not take action to not do it ageln.
B st that the apparent violation involved the 9
And I think the Agency rightiv 9
f al!Ure to implenent actions to preclude 18 anpildes the fines when you're not ef fectively 10
- acurrence of cracking in a cordance with the 11 taking cortective actlon to prevent recWr6nce.
Il Tsquitanents of Criterton XVI of Appendix 8.
12 to I'n very, very insistent and focused on the 12 I think that's essentially the 13 hotion that we need to know how to grevent this 13 Sane thing this savs. only just in a slightly 14 ff'on haPrening agalnt if, in f act the AgenCV 14 differ $nt order. This one includes the Idee of 15 susteins a fine.
15 ferJr confitned failures. We'll talk tout that.
18 Okav. I want to address ~ ! vant is as to whether tiare were four or not, but that's e 17 to take a feu ntnutes talking about the apparent 17 ninor point. I think.
18 v.olation which has changed fron what we extracted 18 It does include - I'n glad to see 19 from the Inspectton Report.
It in the apparent violetten statenent here ~ the PC And, franktv. I'n standing here E8 ptrase. 'significant condition adverse to 21 right row trying to think how to deal with that 21 quellin,.' which is an important 1 tion that we P2 change. I - I'm not sure what we're 90100 to 22 vant to have an opportunity to talk about.
F3 talk about is close enough to what is on this 23 As the quotation from Appendl* 8 24 piece of paper here. but I think it it.
24 savs above on that sane pape a there are two PS I think what we'll have t0 say Is P5 par 1s to AppendlX 9. Criterion XVI that seen to be w-23 24 1
Imporiant here. One, thst nessures will be 1
focused - on this notlon of signlficant condition 2
estabi.shed, blah, bbh. blah, for conditions 2
adverse to quality.
3 adverse to quality.
3 ve have, and Palo Verde has, in 4
ve think this is a condition 4
service today a large number of nonles 5
adverse to quellig, and v' ththk we satisfied that nanuf act'Jred out of this heat. Nov. If the 6
requirenent in Criterion XVI.
6 presence of that maternal in the reactor coolant 7
It goes on to saw, then, in the 7
pressure boundary ~ pardon nel I've Got a sore 8
case of significant ronditions adverse to q ality 8
throat here that nakes it a little hard to talk.
9 the nessu e shall usure that the cause of the 9
I hav vind up sucking on a candy here in a n'nute.
18 col,Jition is determined and corrective Etion is 10 If -- If it's the presence of the 11 taken to prevent - excuse ne ~ to preclude 11 naterial in the pressure boundary, the alonificant 12 recurrence, 12 condition adverse to quality. I'n not sure what to 13 And it's that area that is t.'e 13 do because I've got a lot of it in the plants that 14 nost troubling to ne If I can refer you to page 14 are operating today and so does Palo Verde as I 15 16 of the Inspection Report a sinller. I think.
15 Said -- another licensee.
is to what Art just recited " down toward the botton 16 So it nust not be that. I don't 17 of the last bullet at says. recurring through-vall 17 believe it's that, and we'll tell you ubs we don't 18 cracking in a reactor coolant pressure boundary 18 believe it's that issue. It's got to be something 19 which permits -- permits pressure toundarv 19 else that is the significant condition adverse to P0 leakage, a condition prohibited by technical 29 quellt v.
21 specificattma bhlte In luce 1 was considered to 21 And Vet viren ! study the words 02 fully neet a reasonable interpretation of a 22 here, and nany others have, as velt, and focused F3 significant condition adverse to quality.
23 on what exactly is the vloistion and when did we P4 So I really want to focus 24
- When did the vietation occurl it's verv. very F5 attention a at least that's where nv attention is 25 hard to understand. I can't put my finger on 111 I
i fannte !.. Entth. CSR 'IB171 625-4346
PRINC1510kAL fkFORMEW1 WING
- CpfsMER O.1997 25 ts 1
and, therefore.
- 00n't know exactly what to do to 1
St. Lucie or anstede else.
I prevent it.
P You night do it for c4eret tunal 3
We'll continue on that as we 90 3
reliability f ennont N1 not because it stands out 4
elong here.
4 as a significar*
'dition 41 verse to quality MR. MRSCHrFF Palo Verde seeu under Appendix 9.
to have sucresoed in that they didn't have any C
791. HOWELLs Excuse me. Mr. Ray -
7 through vall leakage fron their nor21ts at the 7
M. ERSCHOFF 1~
0 same hebt according to a SWveV ve did tecentiv.
9 M. HOWELLI Yes. We'll need 9
M. RAYS Well - and we'll show to ~ ve'll need to a le you that we have a lot of that materlet compared 10 MR. ERSCHOFF 1 can help focus 11 to others. And it's not tousual that we would 11 this.
12 have leaks and others would V* If you look at it 17 MR.l.3WELLI We'll need to -
13 statistically.
13 MR. MERSCH0FFs Let ne try, and 14 We vill look at 11 on a ~ on a 14 then 900 can add on.
15 statistical basle. If you sinplW say this 15 The condition is acceptirJ of 18 naterial vill f all in this way. $an Onofre vill 16 condition where tech specs will te knowinglV 17 have hare failures of this heat than other plants 17 violated by a through-vall leak. When you have an 18 vould have, such as Talo Verde, tecause we happen 18 Instance a any component in eng application vill is 9 % nws at it.
19 ultinately fall.
te But if you look at how does this el It's a question of what is a 21 heat perforn relative to other heats. there are 21 reasonable judgenent for its lifettne. When a 27 Many other Heats that are ~ perforn - have had 22 situation is arrlVed at where components a like P3 f ar more leaks than this heat has had. And you P3 components in sintler appilcations f all. f all 24 wouncn't pick this one out as the one to go and 24 again, and f all 'igaln within a given period of 25 tenovel nor would Palm Verde. as I say, or the 25 timel it becomes reasonable to presume that the 27 20 t
lifeline for that naterial selection in that 1
could even tell you to turn back there in your 2
application has teen exceeded.
2 Packape, but whV don't you valt until -
3 MR. RAYS Well -
3 MR. ERSCHOF7: I can't valt now.
4 MR. MERSCH0FF That's the lasue.
4 MR. RAY: A!! right. Well, just just hang in there. We'!! Det to it.
5 MR. RAYS ~ if you vill valt, we vill show you. I'n sure fersuasively, that this 6
MR. HOWELLs Okay.
7 naterial is not any different than any other Allov 7
MR. RAY: But. You knov. Ellis.
0 000 natarial that's in service today from that 8
even accepting the proposition the way you stated 9
standpoint.
9
- 11. I don't think the violation is presented in a 18
$o Just tear with me, and I think 10 vav that I can respond to in that manner.
11 ve'll eerenstrate that to to the case. As I say.
11 In other words. I ~ I ~ ! hate 12 ve have had failures of this material because we 12 to tell you how to - how to present ~ how to 13 have this natorial in an abundance compared with 13 vrlte the violations but a but the way the 14 others. But even accepting this -
14 violation is written. I don't think is ~ is 15 MR. HOWELL: Mr. Ray, the only 15 consistent with - with what I hear vcv saying.
18 point ! vanted to nake is you implied that other 16 And 1 - ! vant to saw that If. In 11 bette tad failed more frequently. And I guess we 17 fact. I take the broad view that the ~ that the 18 need to explore that because that is sonevhat 16 violation is problematic as inpiled by this part 19 contrary to the cata that be have.
19 of the discussion down here, that I h6dn't yet 29 MR. RAY: Well, we've cot quite a P0 talked to -- I was poing to point out - that 't il tot of data, and We'll te glad to show you.
And 21 refers to things about no actions belno taken and 72 ve are planning 10.
PP susceptibility demonstrated by perfornance 23 MR. HOWELL: We would like to see 23 history.
24 11.
24 Both of these things we're Oving 25 MR. RAY: Okay. And, in f ac t. I 25 to tPik to you about at Sone length. But at the fannie L. Smith. C5R 19176 625-4Ma
PittNC1810HL ENFOllCIAENT HCING = SEPIEel'R D.1997 Pt 38 1
and of the dev l'n not necenarily going to 14 1
Inferned by (to Agency, a* 11 vere, as to the f
at>le to convince you, since these are matters of 2
significance of this condition.
3 su3cnent in some part.
3 1 referred to page 16 here in the 4
Nov.1*n convinced. and I'll te!!
4 Inspection Report because it does very closely 5
900 that a lot of other people are, as vollt tv.
E parallel what you said. But l'n troubled by that 6
he that as it nav. vou have e responsibility that 6
for reatons we vill discuss liter.
7
- tt.at you have to be convinced, as well. And 7
MR. MER$CHOFF Is there a sneller 8
wou nav not be convinced.
9 version of vow Pv ~
9 Dut if you're not. I would sav 9
MR. RAYa Yes.
18 that we need to work still on what exactly the 18 MR. MERSCHOFFI ~ SCC historvt 11 violation W vhmt should I do in the future to 11 MR. RAY: It's in front of you in 12 pedvent a fi stence of ~ of thlt violation) 12 the binder at the t>ack.
13 As 1 said. !*ll tone back to that 13 MR.. %-
7s Oh good. Ihank 14 at the end, we vill vant to 161k about whether 14 900.
15 this is e significant condition adverse to 1$
MR. RAY: And not to worry. I 15 quellty, as 1 saldt and why it is.
16 don't plan to go through all of those, but I do 17 In f act. ve've got up here. and 17 vant then to be before you.
10 wou've got at the botton of the heterials in front 19 Okav. Nov. I've said that it's 19 of you, e long history that cites all of the it unclear when the violettor ccurred. And I guess te relevant Agency and industr1 dxunentation on this te I Just want to underscore 1.nat vi?.h this slide il particular attaject over line ~ vhat is the 21 here, we t'n even concerned that it's ongoing.
PP significance of this?
22 again. focusing on the issue of significant P3 And 1 yant ta separatt that 23 conditiDn adverse tc quelltv.
P4 tecause 1 think it's an essential part of our 24 Is the significant condition that PS understanding and of our response is to be 25 ve didn't have a that you don't like our progran 31 32 8
that we had in place to nanage this, and we'll 1
What is consloered to be good practice.
2 talk stud it at lanoths or is the condition that But in terns of the progran not -
3 this natorial is present in the pressure botadarv 3
the progran violating NRC requiremente, I just 4
et all and therefore, presents the potential for 4
don't believe that's correct.
cracking and through-vall leakape?
5 while the Inspection Report cover 6
Ow argunent would 14 that there 6
letter has some additional concerns in it that 1 7
are ~ every heat that's true of, and it's no nore 7
- inptv vented to nention here, and it talks about 8
true in this case than other heatel and, in fact, 8
~ and I'n alvava alert to these things - our 9
It's less true.
9 overall response is of concern.
18 Dut l'n trying to sort out, again.
10 1 hope we'll allav some of that 11 What is it exactly that in the crime, as it were, f
11 overall ~ of that concern here todav in telling 12 and when was it connitted. We infer that the 12 vou again what we dog but, nevertheless. I an 13 violation occwred or at least tegen in 1935. And 13 sensitive to the Agency's feeling that we're 14 that's based on our notes taken fron exit units.
14 Sonehow not responding appropriately to safety 15 But I looked through the 15 concerns.
16 Inspection Report in vain to find exactiv when the 16 We talk about repetittve f ailures 17 violation occurred. And, as I said. I hav be in 17 in Individual Heats of Allov boo noz21e 18 violation today, 18 penetrations. I believe the Agency has addressed 13 If ~ If the concern is Ulth our 19 that issue on an industrv-vide or generic bastsi Pe progran. We truly telleve that there tan't a basis PO that ts to say the issue of repetitive f ailures.
21 for escalated enforcenent action, although ve're 21 The question of Individual heats.
F2 certainly ~ there la e basis for discussion.
22 ve'll separate and talk about. And the question 23 ve're swe. And, you know, we're pleased to have 23 of particular susceptibility is also something 24 thall and, in f act, we're pleased to be. vou know.
24 that is extetstvely addressed throughout all of 25 Inforned that we're not exactly conforming with PS that CWrespondence up there.
Tannte L. Smitn. CSR (817) 625-4948
PPEDECISICAL ENFORCECW7 HEARING - SEPTEMBER 30, 1997 33 34 1
And I would - I would assert that 1
MR. MERSCH0FF: And I want to nake 2
at least until this time, the Agency has not 2
sure we tmderstand it. So you don'i. nor have you
/
3 indicated that action need be taken by licensees 3
anticipated a particular noz21e or categories of 4
where soneone judges that there is a particular 4
nozzle to Itak at the end of the cycle --
5 suscept iblit t u.
5 MR. 8tAY: That's right. In --
t 6
Having said that let he tell you 6
MR. MERSCH0FF ~ in this case a
?
What our policy is less there be any doubt. We 7
heat?
8 vill never operate the plan anticipating ang 8
MR. RAY: Durths the cycle, or to 9
specific pressure boundary component 10 leak.
9 be leaking at the end of the er b which !s the 18 MR. MERSCH0FF: That's a very 18 sane thing.
11 interesting statenent.
11 I would saw an exception to that 12 MR. HOWELL It seens 10 be 12 ts ~ and we'll cer'atnly address the data that 13 tsonevhat inconsistent with infnrnatf ' nal was 13 Art just referred to ~ the -- the notion that we 14 proviced during the nanagenent reeting that was 14 Inspect and repair la ne' inconslStent with that 15 held at your request.
15 pollev stateneni. And we'll explain whv.
16 MR. RAY: vell --
16 MR. MERSCH0FF Ihat's good 17 MR. MERSCH0FF By
- specific' do 17 because that's really fundanental there. One 19 vou nean ~
18 could describe the approach we think we see as a 19 MR. RAY: - I stand by the 19 run to f atiure philosophy of the reactor coolant 23 st at enent. I've had people look at it and 28 susten.
21 challenge it fron outside the conpany. I believe 21 MR. RAY: Uh-huh.
22 It's an accurate statenent. And I'n here to telt 22 MR. MERSCH0FFI And at the end of 23 vou that's the pollev anvvav regardless of what 23 this Conference I'd like to know why you don't 24 any, you know. ntscharacterization of it night 24 think you're doing that. And, of course, what Art 25 be.
25 was referring to was the predicted forecast c
35 36 1
f atlures of noz21es inforftation that you gav. US 1
whether the Agency has or has not.
2 at the neeting.
2 But I don't think t*lat's an issue 3
And we presuned forecast 4 3
to be subject to nuch debate. The Agency has 4
f ailures is not consistent with vour state..m ef 4
clearly deternined that all nozzles, as a class.
5 anticipating leaks.
5 do not constitute what I'n referring to here. nor
(
6 MR. WL vell. It is. We 6
do they need to all be replaced.
7 forecast having to plug a given numbee of tubes in 7
Nov. there was a lot of debate 8
the steel generator. We ce #A wt i knov 0
about that, and I was involved in that on behalf 9
which ones or what category.1 uv 24 1kely to 9
of the industry so that I -- I -- I don't feet 18 leak. Sonet tnes we have an inkli. that, vua 18 1 *e I'n disconnected sonehow or l'n up here 11 know the short radius bend tubes are likely to ~
11 representing sonething that I've not had any 12 hora itkely to develop cracks than others, had 12 personal association v6th.
13 sonetines we don't.
13 Ihe question. When this first is Bu the idea that the pcpulatton 14 started over in the left end of that long series 15 of Inconal nozzles can be expected. based on 15 of docunent vas certainig raised as to whether or 16 history - and we'll show you the data again - to 16 not all Inconel penetrations should be subject to 17 develop a certain nunber of leaks ver a period of 17 pronpt replacenent with 600.
18 t tne is not inconsistent with th idea that we la And there was atrong disagreenent 19 don't operate, unless you consider a specific 19 within the Acency over that Issue. I sat in 20 pressure boundary component to be all nozzles.
28 debates in white Fitnt in which there was -- there 21 And - and he've certainly 21 was that disagreenent openly expressed. I 22 considered that. And I believe. vou know. the 22 understand it.
23 answer to that li. In nu Jucgenent, the Agency has 23 MR. MERSCH0FF Do you custder 24 clearly determined -- and I know there's a 24 heats as a valid reans of categorizing noz21es 25 argunent here in the Inspection Report as to 25 differently with regard to their susceptibility to Tennie L. Sntth. CSR (0171 625-4348
PREDECISIOWL ENFORCEMENT GARING - SEPIEMllER 38, 1997 l
[
37 38 corroston?
1 the vapor Space on a pressurtzer. We had nozzles 2
- m. RA): Certelnlv. Yes. If the 2
that weren't cracked there.
3 data allow you to discrtninate a heat as we have 3
ve thought that was a particularly 4
done in the past in different circunstances.
4 ag1ressive environnent for prinary water stress b
that's a perfectiv valid way to do it.
5 corroston cracking due to tM anytronnent in the 6
It turns out, as - as -- and I 6
top of the pressuriter.
<r.d te t elaced then 7
keep teasing you with this ides that ve're going 7
all. I tetter nove on.
8 to show you sone date here in a little bit -- it 8
$o the t *Wat is '..at vs helleve 9
turns out that we have not yet beea able to see 9
ve have and continue to ou J in total 18 that discrtnination.
le compliance with the tech Spt :s. And - and we 11 I realtre you all think that we 11 just feel like ve have to esplain to you why we've 12 can or should. And that's an important part of 12 cone to that conclusion.
13 this neeting. Dut, on the other hand, when I say 13 The last tullet here on this slide 14 I don't know what to do to prevent recurrence, the 14 before I turn it does try und sunnarl2e what I've 15 one thing I can do to prevent recurrence that I do 15 just been savingt which is that that particular 16 not feel I e'nould do, nuht do, or that the Agency 16 heat as we vill show you iron the data, does not 17 has indicated the Industry should do, is replace 17 stand out as particularly susceptible on ang 18 all 000 nor21es.
18 relevant scale.
19 Absent that deternination. I feet 19 I guass one other thino I want to 20 there is no vev to discriminate this particular 29 sav, too, because it grates ne. la ve think we 21 heat or any heat as one that we should go in and 21 vere particularly aggressive in inplenenting this 22 replace. If and when that deternination did 22 generic letter.
23 occur. we would do it.
23 I have yet to find anybody in the 24 Nov let ne olve you a class of 24 Industry that goes to the extent that we do to 25 nozzles whure we did replace then all. That was 25 conduct this inspection. Nov. there are others --
39 48 1
I shm LA '
M said it that way - that goes to 1
everything I can to try to test the proposition 2
a st ort em than we do to implement this.
2 that we've put before you today.
3 And. M. 4 m do it far nore than nost.
3 And -- and I feel confident that 4
ve really look for any early sign 4
ve're responding correctiv and accurately to you.
5 of leakage due to this phenonenon. And I believe 5
And we'll proceed to do that here.
6 sone of the statistics that we've expertenced is a 6
MR. FIEL.DS: Harold. I did have 7
consequence of that conservative and aggressive 7
one questton.
8 posture that we've taken.
8 MR. RAY: Sure.
9 So, in sunnary. I'll now turn it 9
MR. FIELDS: You brought up, in 10 over to Mike Short. We did not violate le response to Ellis' point about run to failure, the 11 Criterton XVI of Appendix B in this instancel and 11 f act that the stean generatbr tubes are forecasted 12 ve can't. as I've said several times, feel 12 to develop. I believe, either Indications or 13 confident that we know what to do to prevent 13 leaks. Now, obviousiv --
14 recurrence of tha violation, albeit we nav not 14 MR RAY: Cracks.
15 understand the violation.
15 MR. FIELDS -- We understand that 16 I've -- I've sought input fron 16 they are forecasted to develop indications, but 17 everybody in the industry I could find outside the 17 vou don't forecast that you're Colno to develop a 18 Agency on this point to challenge -- excuse ne --
18 through-vall crack in the stean generator tube.
19 to challenge these conclusions, including sone who 19 MR. RAY: No, no, no. If I said 29 vere involved in some of the Ager.cv positions when 29
' cracks.' I didn't nean to. I tried very hard not 21 thev Vere with the Nency.
21 to. I said ~ I nean the leaks. I said 22 And none have succested that we 22
- cracks.* They oo develop cracks. Those are the 23 nake any change in this response. So that doesn't 23 Indications we're talking -
24 nean that it's right s doesr.'t nean that you need 24 MR. FIELDS: Right.
25 to accept it 11 just neans that I've done 25 MR. RAY: -- about. My only point l
l Tannte L. Salth. CSR (017) 625-4948
PREDECISZC AL ED ORCEMEWT HEARING - SEPTEMBER 38. 1997 i
41 42 1
was going to be, when you have a netellurgical 1
NR. HERMANN: I was trying to 2
phenonenon of thIs kind occurrino. vou can projec1 2
understand the atatenent you nade about the 3
fron past experience into the futa and say. I'n 3
nozzles on the top of the pressurizer versus these 4
poing to see nore of this.
4 other nozzles.
5 MR. FIELDS: Exactiv.
S
- 9. CAY: Uh-huh.
6 MR. RAY: Now, the difference 6
HR. HERMANN: So far as I can 7
between leaks here and Indications in stean 7
telt, ttx only difference that you nau have been 8
generator tubes, of course, is inportant. You --
8 talking about would be temperature differences?
9 wou detect the Indications in the stean generator 9
MR. RAY: Well, we n.rd be wrong.
18 tubes and take action to plug thsn before they can 18 okay? We thought there was a difference, also, in 11 develop into cracks.
11 that there are corlosive passes in the top of the 12 In this case ve have not been 12 pressurirtr that aren't present in the reactor 13 nandated. as 't were, or we have not inplenented a 13 coolant systen, itself.
14 NDE progran for these nozzles. I believe, again.
14 And this was early on in -- In the 15 a reasonable reading of the Agency's assessnent is 15 assessnent of this back. I think, before 1990 16 that we don't need to because we can do what we 16 originallv! vasn't it Mike, or when was it?
17 are doing, 17 MR. SHORIl Yes.
18 Nov Vou can buy that or not, but.
18 MR. SCH00NOVER:
'86.
i 19 I nean. the point is that the Agency has said.
19 MR. RAY And so ve didn't really 29 this is occurrinal ve've assessed its this is what 20 understand the phenonenon the uav ve do today. We 21 to do about it. And just as we 90 in v n h ths 21 sinply said the top of the pressurizer is a 22 stean generator tubes and inspect the heck out of 22 different place tenperature-vise and the fact that 23 then, and we expect to find sone with cracks and 23 vou have in there, as I saw. Corrosive passes that 24 plug thent in that same way the data that Art was 24 come out of the reactor coolant systen and which.
25 referring to were developed. That's all.
25 fron a netallurgical standpotnt, nau be causing 41 44 1
cracking of these nozzles.
1 not yet reached it, and the appropriate action was 2
They were the first ones te crack.
2 not necessarily to replace then all and in other 3
and we have replaced the9 all --
3 Instances you have? Where is the dividing point?
4 11R. HERMANN: I'n --
4 MR. RAY: We have not -- at least S
MR. RAY: -- nore than once.
S to ny knowledge -- I have not been involved in the 6
MR. HERMANN I'M hot sure where 6
deternination of a fixed threshold, as you 7
that had cone fron because you're still running 7
suggest. not that there couldn't be o v.
8 very lov oxygen up there. I think. With all the 8
I think the naterial that Mike 9
hydra 2ine you put in your systen and --
9 util present vill allow for discussion of that to le MR. RAYi veil, it's still worse 10 sone greater extent. But rather than have it 11 than it is in the -- In the water section. I 11 float off into the future. let ne just saw that 12 nean. I'n sure vou would agree with ne there.
12 there have been a variety of reasons whv ve've 13 And so my only potnt was going to 13 taken the replacement action that we have.
14 be. do we ever identlfy a class of things and take 14 We've studied this a lot, and 15 action dealing with that class? Well ves, we 15 learned over ttne. And I'll let Mike speak to why 16 did.
16 ve did particular thincs when we did then. And.
17 MR. MERSCH0FF Let ne -- along 17 again, ve vill have a substantial discussion of 18 those lines. Harold -- In '06 and '92, were at 18 this self-criticisn that we engaged in, which I 19 least two instances where you did just that. You 19 think has been very nuch nisunderstood in the 20 took acti' to replace all nozzles in a heat.
20 Inspection Report. And I look forward to 21 And so I presune there is vne 21 discussing that with V!J.100.
22 threshold at which you have taken that act t 9 to 22 But let's first start with sone of 23 replace all the nozzlet vill this presentatica 23 this material. Including what I keep referring 24 attempt to describe what that threshold is, where 24 to. Yeah?
25 in this case presunably vour position is you had 25 MR. SCH00NOVER: Just to clarify Tannte L. Smith CSR (8171 625-4940
PREDECISIONAL ENFORCEENT HEMtING SEPTEMBER O.1997 45 46 1
~ in 1906, the cracking experience did result in 1
in the Inspection Report. I've listed then here.
2 replacenant of that heat which he$ e particularly 2
The only point I wanted to nake on these cases is 3
high vield strength. The 1992 experlence was ~
3 If you consider confernation to be radio-chenical.
4 the cracking was identified in three nozzles in 4
they were not alsaus confirned, and in sone cases 6
the stean space and all four stean space no221es 5
the leak was quite anall so --
6 vere replaced. not from a particular heat.
6 MR. HERMM4: *! guess I don't 7
MR. RAY: Well, that's what !
7 understand the logic in the second bullet. What 8
nean. That was a matter of convenience. I think.
B is a radio-chemical analvsts going to da in terns 9
in that we vere set up to do that.
9 of a prinarW unter stress corrosion cracking other le MR. MERSCH0 fps Location as 18 than - are vou inferring that the boric acid came 11 opposed to -
11 fron sone place else other than the reactor 12 MR. RAY: Correct. Okay.
12 coolant systen?
13 MR. SHORT: Again, nv nane is Mike 13 MR. SHORT: The boric acid that 14 Short. Manager. Site Technical Services. I have 14 was used to detect the presence of the leak was 15 three aspects to the plasentation. The firct one 15 sanpled and assessed radio-chenically for what's 16 speaks to the heat, itself. Then we'll talk a 16 present in the boric acid. What radio nuclides 17 little bit about PWSCC in general and than the 17 vere present --
18 planning for that nrahanten at San Onofre.
18 MR. HERMANN: Rlpht.
19 So first I'll begin with the Heat.
19 MR, SHORT: This was right after 28 Itself. And I'll start with the -- the experience 28 shutdown, so you would nornally expect to see 21 with this heat at San Onofre and then go through 21 short ilved radio nucildes. We found that. All 22 its susceptibility issues a discussion of our 22 ve found were longer-lived radio nucildes. And by 23 replacenent approach, the technical specifications 23 comparing the presence of those nuclides Ulth the 24 and app!! cations of Criterion XVI.
24 content of activity in the reactor coolant systen.
25 There vere four cases identified 25 It Indicated that the boric acid was -- cane fron 47 48 1
a source about four years ago and had decayed --
1 It?
2 MR. HERMANN: Are you trying -
2 MR. SHORT* It's based --
3 MR. SHORT: -- because there was 3
MR. HOWELL For exanple, you have 4
no --
4 pictures here where I would clearly saw that It's 5
MR. HERMANW1 -- to tell us 5
pretty clear that this was leaking. Are there 6
that --
6 other types of Doric acid deposits in which it was 7
MR. RAY: Let no --
7 harder to deternine?
8 MR. HERMMWs - it didn't con 6 8
MR. SHORT: It was not clear in 9
out of the RCS or it did cone out of the RCS?
9 this case. It didn't have the chnracterization of le MR. RAY: All -- we open up the 18 dripping down the side of this -
11 RCS and do work on it often. Sonettnes water 11 MR. RAY: Walt a ninute. Walt a 12 drips onto other conponents, we were trying to 12 nt nut e.
Yes. And we'll show 900 a picture of it 13 deternine whether or not it was leaking fron that 13 in a ninute.
1.0 location or had dripped onto that location fr M 14 MR. SHORT: And then we just want 13 another locatich.
15 to nake the point down here that the leakage 10 MR. HERNMN Sonevhere else.
16 in the last two cases was quite, quite small.
g 17 MR. SHORT There was a spraw-down 17 I'll show you an exanple of tf.at a little bit L
20 Inside contalnnent about fcur years prior to this 18 later.
19 event. It is possible this boric came fron that 19 MR. RAY: One of then wasn't a 29 event. It la ponible the boric acid cane fron 28 failure in the sense that leakage occurred at all.
21 the nozzle. We couldn't deternine. and so we 21 MR. SHORT: In the first case --
22 replaced the no221e.
22 Eric :e erred to this, as well -- we were 23 MR. HOWE 1.La Is that based solely 23 Invt.Wgating a vapor space no221e leak in another 20 on the presence of boric acid in the vicinity, or 24 heat. heat nunber shown here llndicat tncl. That
- 25 did you have sone kind of acreening criteria for 25 investigation took us to all the vapor space Tannie L. Snith. CSR 1817) 625-43 7
PREDECISICAL ENFORCEMENT HEARING - SEPTEPEER 38. 1997 49 58 1
nozzles.
1 for code conpliance.
2 And from the inside of the 2
MR. RAYi vell. I'n not sure of 3
pressurizer. penetrant exansnations were used to 3
the point. We - we found an indication in this 4
identify cracking in a 7638 heat vapor space 4
nozzle. We renoved it, and replaced the nozzle.
nozzle. And as a result of that. We replaced that 5
MR. HERMANW: I think the point is 6
no2214.
6 Sc55-A says you'vd got to operate things in 7
MR. RAY: So ve found a crack due 7
accordance with Section 11. Okay. And if you 8
to NDE. but it had not developed a leak of the C
find a flav fron a surface Indication, you have to 9
violation of the first failure. That nav or naw 9
disposition the flav. And you did that.
It not be what you intended.
10 So to say that you did it -- I 11 MR. SHORT: And this - this is an 11 think the inference of the first sten is that you 12 exanple --
12 found a flav. and it wasn't leakingl and.
13 MR. HE W JINI Well. Baube we ought 13 therefore, you satisfied the CE owners grow 14 not leave that subject too quick, because if you 14 position in terns of corrective actions. You also 15 find an Indication bv. say, a penetrant exan --
15 have to satisfy 5055 A.
16 this is Class 1 piping, essentially -- the ninute 16 MR. RAY: Well. let ne not nahe 17 900 find a penetrant exan. I think you have to 17 any inferences. Let ne be explicit. We think we la characterize what the depth of that Indication is.
18 did satisfy the regulatory requirenents. We only 19 do fisv evaluation and see if you need the flav 19 point it out because it's referred to here as a 28 evaluation rules.
20 confirmed failure.
21 So I think your action at that 21 I don't know if you nean the crack 22 point was you found sonething on the surface.
22 indication to be a confirned failure or not. We 23 900 decided not to do a flaw evaluations you 23
- one of the things we're asked to do in contng 24 decided to do a repair in lieu of a -- In lieu of 24 here is to point out any errors.
25 a flaw evaluation. And I think you needed that 25 MR. MERSCH0FF: And your i
51 52 1
point's --
1 vessel originating from the veld area accunulating 2
MR. RAY:
I-2 r!Ght in this area allowing us to detect the 3
MR. MERSCH0FF -- your point's a 3
leakage.
4 good one. The violation as vrttten is conferned 4
MR. RAY: Wow, has there been any 5
failure i.e., through-vall cracking. Clearly 5
cleantne done of the pipe vall?
6 this is in variance to --
6 MR. MERSCH0FF Dwight, you 7
MR. RAY: That's correct.
7 probabig have your foot on the plug.
8 MR. MERSCH0FF -- to the 8
MR. SANBORN You're altting --
9 ci t at ion.
9 MR. MERSCH0FF I'n not allowed to it MR. RAY: Go ahead.
le sit in that seat.
11 MR. SHORT: You indicated you had 11 MR. RAY: Nice that you knew 12 photographs. Some of those photographs we have 12 exactiv vhat the problen was.
13 with us today. This is the example of one. This 13 MR. SHORT: Harold - Harold asked 14 is an Indication of a nozzle. This hypens to be 14 the question, had there been cleaning? I don't 15 e portion of the insulation. The Insulation has 15 know in this case, although it appears to be 16 been renoved fron the innediate vicinity of the 16 cleaned.
17 nozzle.
17 It is our practice efter - as the 10 This would be the base material. I 18 plant is shut down, we conduct an inspection. We 19 believe. of the RCS loop piping in this case and a 19 do a bare netal Inspection in the vicinity of the 29 small accunulation of boric acid has forned here.
29 nozzle vitu e plug of insulation renoved. We're 21 That lead to the detection of potent tal leakage.
21 going to talk about that in Just a ninute.
22 and this nozzle was replaced.
22 Durinu the -- and then we'll --
23 The leakage path is -- la through 23 ve'11 act on the basis of that inspection. During 24 about a between a 2 and 5 nti cap between the 24 the outage, itself. We take nore insulation avav 25 nozzle and the bore of either the pipe or the 25 fron each nozzle, clean the area around the nozzle Tannte L. Snith. CSR 18171 6 3 -4048
PREDECISIONAL ENFORCEMENT HEARING SEPTEMDER 30. 1997 53 54 1
in the event that there's sone non-relevant 1
affectIng cracking of Allov 600 are shown here.
2 natorial present, such as. van nentioned earlier.
2 Many of then are shown here.
3 boric acid fron another source so that that 3
And we vill point out that none 4
doesn't confuse us on return to service of the 4
nozzles fron this heat renair. th service todav in 5
unit and allows us to see boric acid indication as 5
en area that we consider one of the nost 6
early as possible.
6 aggressive environnents - the pressurizer ~
7 MR. RAY: Eric, do you renercer?
7 happens to be in the water space portion of the 8
MR. SCH00NOVER: Ihis particular B
the pressurizer, and as of the last outage have no 9
picture. I don't believe it was cleaned prior 9
Indications of through-wall cracking.
18 to --
18 I'n going to shov Vou in a 11 MR. SHORT: So this nas be an *as 11 ni nut e --
12 found' "
12 MR. RAYS But 41 ve expected then 13 MR. RAY All I can saw to Vou.
13 to leak, we would replace then.
14 Ellis, la that of tentines I get these things 14 MR. SHORTS Yes.
45 brought into ne looking Ilke that or less so in 1S MR. RAY: And we'll shov Vou in a 16 trying to define whether or not it is or is not an 16 ntnute why we haven't.
17 evidence of a leak.
17 MR. SHORT: I'n going to show you 18 Now, this one is pretty Clearly an 10 sone graphs in just a ntnute. We believe that 19 indication of a leak. But unlike the ones that 19 this heat is behaving in a fashion str.ilar to 20 Art had there, they don't alvavs have these big 20 other Allow C00 heats in service and nozzles in 21 running drips down the side of the pipe.
21 the industry.
22 MR SHORT: I'n up to page 13 in 22 And, consequent 1v. based on the 23 the package. Moving on to our assessment of the 23 Infornation available to us in 1935. We are 24 ausceptibility of this. As you know -- I don't 24 proposing that as the point where the violation 25 think is controversial at all -- the f actors 25 nav have occurred here on that date ~ selecting 55 56 1
that date - that se couldn't predict that this 1
of those or are they actual confitned failures?
2 allov was any nore at risk than *.av other allov 2
MR SHORT: I believe this 3
for cracking and nozzle service in RCS at 3
reflects fattures. Eric?
4 San Onofre.
4 MR. SCH00NOVER: At St. Lucie 1 5
Nov. this is the data that had 5
did find none cracking. I believe, at their ~
6 been referred to earlier. It takes a nonent to 6
Mike, do you renercer that?
7 absorb this chart. Let ne walk you throuan it.
7 MR. MELTON: I don't have the data 8
This is through 199S. So this reflects the state B
in front of ne.
9 of knowledge in 1995.
9 MR. RAY: Don't know. Art.
18 The colors represent varioua heats 18 MR. HOWELL: Okay. If you could 11 in service in the CE fleet of plants. Those 11 just clartfy that a sone point and get bact to us 12 plants are show across this axis. This would be 12 on it.
13 Unit 2. Unit 3. and then other CE Units labeled 13 MR. HERMANN: Is the point of the 14
'A' throwh 'G.
- 14
-- la the point of the slide that tenperature and 15 And then these would be the heats 15 carbide decoration aren't important, and this is a 16 and whether or not they have cracked as a 16 randon statistical occurrence?
17 percentage of the total nunber of heats in service 17 MR. Raft No. We'll -- ve'11 drav 18 at that plant.
18 a conclusion if you'il just bear with us ~
19 MR. HOWELL: Excuse ne, Mike. 18 13 MR. HERMANNt Okay.
29 this crEks or replacenent because --
29 MR. RAY 1 ~ briefly. Please.
21 MR. SHORTt The
'B' ~
21 MR. SCN00NOVER: St. Lucie did 22 MR. HOWELL: For exanple, heat 22 have tuo confitned nozzles cracked, heat 54318, 23 54318. I believe. is the heat that St. Lucie 23 MR. HoutLL: Okay. But thev 24 changed out proactively as % result of sone of 24 changed out about ten, as I recall. So does this 25 vour expertence. Does that reflect the change out 25 bar reflect ten or two? That's the question.
l I
fannie L. Snith. CSR (0171 625-4940
PREDEC1510NAL ENFORCEMENT HEARING - SEPTEMBER 30, 1997 57
$8 i
MR, SCH00NOVER I don't know the 1
MR. HOWElis But, again, it's 2
answer to that.
2 critical that we understand what the data 3
MR. MERSCH0FFs Help ne out for a 3
reprssents.
4. pinute. Blue's can be a little difficult 4
MR. $NORTs Right. So the 5
sonelines to distinguish. Can you point out 5
question is, does this represent all replacenent 6
WX76307 6
activilles --
7 MR. $HORT This row back here 7
MR. HOWElls Or all failures.
8 findicat inal.
8 MR. SHORT: -- versus all cracking 9
MR. BROCKMA)lt Next to the back 9
-- detected cracks.
16 row?
18 MR. RAY: Well, if -- you can 11 MR. HUNTS Next to the back --
11 taire of Course, any one heat out of the pictire.
12 MR. $HORT: Next to the back row.
12 and it doesn't change the picture with respect to 13 MR. MERSCH0FF Okay. Thank you.
13 that heat that we're focused on here.
14 MR RAY: This data was put 14 MR. HOWELLs Well. I'n not sJr0 15 together before ve knew that you vere going to 15 that I believe that because sone of these ntabers 18 land on that one. And so it wasn't an attenpt to 16 are very 109.
17 hide it, but I think it's clear enough.
17 MR. RAY: lihat I neant was you 18 Anyway, we've got tone nore data 18 could just --
1S that Mike's going to look at here -- two nore data 19 MR. HOWELL For exanple. We're 29 sets.
29 talking --
21 MR. SHORT: Unat I've cone in this 21 MR. RAY: -- ontt one of these 22 slide is basically just roll all this data up so 22 heats fron the picture -- just inactne arv one of 23 that all the plants are shown as one population.
23 then doesn't natter -- lan't there.
24 It's the sane data, just shown as one population.
24 MR. HOWELL: Well, for stanple 25 7638 uvuld be here findicating).
25 9315. 1 believe -- or is it 8234 -- now, in that B
59 68 1
heat you had three failures, but they were all in 1
shovn.
2
-- three of the four vere in the last outage so --
2 MR. MERSCH0FFi Okay. And I guess 3
MR. SHORT Uh-huh. They would 3
If this is to show that NX7630 is not an outtler.
4 not be shown on this because this la through '35.
4 it seens like the large nunber with ne failures 5
MR. HOWELL: Right. Dut I nean if 5
vould need to be in this picture sonelev.
6 there is any other sintlar -- I nean, we have to 6
Otherwise. I would tend to conclude 11at every one 7
understand what 'tm data ts. That's nu only 7
on here is clearly an outtler fron the nang that 8
point.
8 have not been replaced. and action Stould be 9
MR. HERMANN: Is this all 9
t aken.
18 Instrunent no221es. or does it include things like 18 MR. SHORT: This does represent a 11 heater penetration sleeves?
11 significant fraction of the heats in service but 12 MR. SCH00NOVER: Only Instrunent 12 not all of then. And we can providt that.
13 nozzles.
13 MR. RAY: Let ne has ten to add. If 14 MP, SHORT: This is Instrunent 14 the Agency concludes that all heats that have 15 noz2les only.
15 suffered arv cracking should be replaced and that 16 MR HERMANN: Okay. De ause this 16 occurs. vou know. I think that's sorething that we 17 just savs '600 nozzles.'
17 can certaint's say, okay, the decision has been 18 MR. MERSCH0FF: And these are all 18 nade.
l 19 the heats in service in the CE donestic fleet?
19 We don't thtnt that decision has 29 MR. SHORT: Where cracking has 20 been nades to ti.e a.ontrarv. But if it is (sic) l 21 been detected, ves -- where fatlures have 21 been nade, it's -- it's sonething that can be 22 occurred.
22 nade. And I've sat for hours and listened to 23 MR. MERSCH0FF: Okay. So --
23 people argue about that, vou know, at white Flint.
24 MR. SHORT: There are sone heats 24 And I know there's a body of 25 there no failures have occurred that are not 25 op'nton that says that's what ough*. to happen.
Tannte L. Sntth CSR 18171 625-4948
)
PREDECISIONAL ENFORCEENT GOING = LEPIEMBER 30, 1997 61 62 1
Fine o not fine, but I ~ ! nean, we can accept
-1 do with this heat.
2=
that and - and go on.
2 MR. HERMANNI The 97-01 was CRDM 3
The problen is we haven't ~ that 3
penetration. I believe.
O deteralnation was not na$e. In fact. a dif ferent 4
MR. RAY: Ws11. let ne say that 5
deternination was nade, I assert. And we can 5
that a there is a poln' nade in the Inspection change oir nInd about that, but ~ bVt I think --
8 Report that disalsses all disEussion of reactor
?
MR. HOWELL We're anxious to hear 7
vessel head penetration. CRDM or otherwise.
8 that, too.
8 Again. We vould take the position 9
MR. RAY Huh? We're ~ vell. I 9
that that's a nev -- sonething new to us because 18
-- I ~ again. I'n speaking now fron personal 18 15ese things have been conbined in our opinion.
11 expertsnce. I think the Agency can change its 11 in the past.
12 nindi and, in fact, there's an inp1l cation in the 12 There -- I've never seen a subject 13 recent 87-91 that nafie we want to make sure there 13 over the years where there is such a videsprea:1 14 lan't sone date out there that should lead us to 14 differing opinions Ulthin the Mency, so I don't 13 change our ntnd.
15 vant to try and speak for anybodv of cpinion.
16 And that's flagged in the ~ in a 16 But there -- I have never Peard 17 recent docunent on this purpose ~ on this 17 anybody argue that the policy position with 18 subject. I nean. But, again, we're not here 18 respect to CEDM no221es is sonehow separable fran 19 trying to defend the proposition that cracking of 19 those on Instrunent nozzles or heater sleeves.
29 these nozzles should be tolerated vou know, above 29 which is what this Inspection Report savs. It's 21 any level at all.
21 the first line I ever heard that.
22 1 -- I take the position that it's 22 MR. HOWELL: We11. It's not the 23 clear that the Agency does accept thet. And the 23 first tine I've heard that. but --
24 only thing we're talking about is what is 24 MR. RAY: Okay. Well, the first 25 described here as the apparent violation having to 25 time I heard it was in this Inspection Report.
63 64 1
Let ne --
1 were not subjected to NDE to deternine whether 2
MR. HOWELL: Because the 2
they contained cracks or not.
3 inspection reginen is different, and there are 3
l@. MERSCH0FF I'd like tc try 4
diff# ences in nu view.
4 and understand fully the point that this graph is 5
MR. RAY: Welt.
5 naking. On the one hand it would seen to ne that 6
phenonenologically? I nean -- I nean, what are --
6 the specific application uitbin a plant of these 7
what are the differences? The CEDM's are 7
heats for the chentstry conottlons that they've 8
certainly note safety significant by any stretch 8
expertenced, the velding approach the stresses 9
of the inagination, 9
induced to put it on the tenperatures. Would tend 18 MR. HERMANN: Yeah.
18 to make plants relativelv unique and that data of 11 MR. RAY: So l'il accept that 11 the hea? applications within a given plant and the 12 difference. I neant, is there a different that 12 failure frequencies ulthin the given plant night 13 would nake these more safety significant than the 13 De nore neaningful than industry-wide data.
14 CEDM penetrations really? I nean. I realize you 14 Or do you feel that the
+
15 can saw the reactor vessel head is what's the --
15 appilcations and the temperettres and the 10 really the issue of concern. And I understand 16 chentstry are close encuch that it's really a 17 that.
17 relatively uniforn population, so knowledge or a 18 MR. MERSCH0FF Let ne --
18 failure at any plant applies to all of then?
19 MR. HOWELL: But just cetting back 19 MR. RAY: We!!. I -- I don't want 28 1o pages 14 and 15. We do need to clarifu vheIher
- 29 to have to choose brtveen those t90. E111s.
21 these are replacenents or failures. We need to 21 because I ~ I think that our posture is that you 22 have 900 clartty that.
22 would e.pect us to be nindful of industry 23 MR. RAY: Yeah. And I would guess 23 experitoce as we discharged our responsibilities 20 that we nav not be able to get that definitivelv 24 here.
25 because there nay be sone that were replNed that 25 Now, if we want to, we can sinply Tennie L. Snith. CSR 18171 625-4948
PREDECISIONAL ENFORCEPENT HEARING
- SEPTEMBER 30, 1997 65 06 1
t: lock out all other data but San Onofre 2 and 3 1
NRC should impose sone different requirenents.
2 and ask the quesiton as to whether or not we had a 2
You know, all of that is fair 3
basis for selecting this heat that is identified 3
gane. And, as I said I've spent a lot of tine in 4
th the apparent violation for replacement.
4 that kind of discussion and happy to have nore.
5 And I would saw to you, no. we The - the question before us, though, here has 6
didn't that way either. But we accept the 6
got to keep tonin0 back to the question of whether 7
responsibt!Itv to look nore broadly, and this is 7
or not this heat should have been :2placed.
O simply an effort to do that.
8 Mike.
9 Now, you can set it aside and saw 9
MR. SCH00NOVER: Back ~ back to 18 that these other differences that Vou refer to 18 these two graphs. The input for these two graphs 11 nake the industry data not appilcable. Again. I 11 was generated fron cracking data that was 12 don't thir,k the Agency has done that and - nor 12 available fron the industry and fron a catalog of 13 havo ve through EPRI. And I should perhaps let 13 all the CEOG Instrunent nozzle Heat infornation.
14 Doninion speak here about their experience in 14 So specifically to 54318. that one 15 regard to these other variablittles.
I'.i occurred prior to the ~ vhen the catalog of 1C They do have an effect. All we're 16 infornation was published in 1991. So I can't 17 trying to focus Ni le. did we have a clear 17 give you a confirnation of that specific one.
18 Indication, or any Indication, that this heat 18 But all of the data that is 19 should have been replaced?
19 graphed here is confirned cracked nozzles, not 28 If not, again. I think we want to 20 replacenent.
21 cone back to the issue of the violation. Nov.
21 MR. HOWELL: I*n not sure 1 22 ve're happy to talk about the fact, gee, this 22 understood that. You're saving that all the data 23 progran lan't going veill you had leaks, and you 23 is. except you're not sure about 543187 24 shouldn't have leaksi navbe we ought to do 24 MR. SCHOONOVER: 54318, we had the 25 sonething differentiv as an Industrui navbe the 25 one crack at San Onofre and two at St. t.ucle. And 4
67 68 1
the one piece that's nissing is the total nunber 1
But I'n assun!ng that there's a failure 2
of 54318 that was originally installed at 2
sonevhere. Uhv ts that itsteo? Is that just an 3
St. Lucie.
3 aberration that occurred?
4 MR. RAY: See, this is expressed 4
MR. SHORT: I'n not certain.
5 as a percentage.
5 MR. FIELDS: Okay.
6 MR. HOWELL: Right. Well, but I'm 6
MR. SHORT: It looks like it 7
assuning the percentage is nore than 12. There's 7
shouldn't have teen Insted there fron av prior 8
nore than 12 total there.
8 definttlon. There are a nunber of heats that are 9
MR. RAY: I'd suggest you let 9
not listed.
18 us ~
18 MR. FIELDS: Okay.
11 MR. HOWELL: Because there were --
11 Mk. SHORT: And that would help --
12 MR. RAY: -- cone tack to you 12 MR. MERSCH0FF: In terns of 13 tonorrov or whenever.
13 understanding this data ~
14 MR. HOWELL: ~ that ~
14 MR. SCH00NOVER: It was in 15 MR. RAY: We think that the data 15 1997 --
tC are relevant to the point we're trying to nake.
16 MR. BARNES: Unit 2.
17 And we would certatnig nake clear to vou the 17 MR. SCH00NOVER: - at Unit 2.
It 10 answer to vow question.
18 Jas K240 that failed.
19 MR. FIELDS: Mike, one nore 19 MR. BROCKMAN: So if you see a 29 question before we get off this slide. You stated 28 little bitty line there. It's probably a 1 tucked 21 that only the heats that you had observed cracking 21 in there or sonething?
22 are listed here.
22 MR. SCH00NOVER: Yeah, that's 1 23 MR. SHORT: Yes, that's correct.
23 and -
24 MR. FIELDS: So when I look at 24 MA. RAYi But you can't tell a 25 Heat K248. It looks like there is no failures.
25 dif ference between the l's and the none's ~
Tannte L. Snttn. CSR 18171 625-4% 8
PREDECISZ0liAL ENFORCEMENT HEARING SEPTEMBER 38. 1997 CS 78 1
MR. FIELDSt Okay.
I characterized as that source. I don't know that 2
MR. RAYS -- Is the point.
2 thev -- I can say they were confirned through, for 3
MR. FIEl.DS: That's fine.
3 exanple, net exaninations. That's not the case.
4 MR. RAVs well, it's not fine.
4 MR. RAYi Again. Ellis, we didn't 5
MR. FIELDS: I just wanted to nahe 5
perceive a need to address why aren't any heats C
sure we were -*
6 that develop cracks replaced "on that basis alone.
7 MR. NUNN: That failed in '95.
7 That's the issue I understand you're asking but 8
This is 's5 date. It actually fa!!ed in '97.
O that's not --
9 MR. RAY: So that's why it's in s
MR. MERSCH0FFi Wo. It's not. As 18 there is because it f ailed in ~ okay, well, it's le I said at the opening, any component in anu 11 another nuance.
11 app!! cation W111 Ultimately fall. And an Inconel 12 MR. MERSCH0FF: In terns of 12 se8 nozzle in service long enough will nost 13 understanding this data, nu nental pictre now le 13 probably develop a crack and fall.
14 these are a few fal!Ures in a vast black Sea of no 14 The concern that we've come to the 15 fallwes. And you need to bring ne closer to 15 table with is that a particular population of 16 reality in terns of the --
16 these nozzles has shown itself to reach its end of 17 MR. SHORT: How big is the sea?
17 service life, 18 MR. MERSCH0FF Yes.
18 And we expect -- would have 19 MR. RAY: Okay. We'll certainly 19 expected a pro-active approach to recognize that 28 do that. That's a good point. And we should have 28 failure for this sub group has been reached -- end 21 been prepared to do that.
21 lifettne reached and replaced -- rather than 22 MR. HERMANN: And all of these are 22 simply waiting for the inevitable failures that 23 confirned to be prinary water stress corrosion 23 vou now know vill occur to occur.
l 20 cracking through all these heatst 24 That's a little different than 25 MR. SHORTI They all vere 25 any single failure industrv-vide being 71 72 1
unaccept able.
I that's where we disagree obviously.
2 MR. RAY: vell. except that when 2
MR. RAY Well --
3 wou say. I want to know how big the sea ts, the 3
MR. MERSCH0FF Are these -
4 Inplication of it is that. Well, navbe there's 4
MR. RAY: -- I would argue. Art.
5 tots and lots and lots of heats out there that 5
that your disagreenent doesn't take into account 8
don't experience any failure at all implying that 6
the fact that we have a large population of that i
7
-- that - to ne anuvag - that the group that 7
heat, which is, in fact. one of the reasons whv.
O ve're looking at here are really all in the group 8
once we get to the discussion of ALARA. vou know.
S that ought to be identified for pro-active 9
I nean, you're talking about a radiation exposure le replacenent. That's a good question, we hope ve 18 to replace all of this naterial that's nore than 11 can answer it.
11 our annual site ractation exposure.
12 MR. HOWELLs That's what we're 12 Nov albeit I know that in all of 13 trying to -
13 this discussion there tan't any nention of thall 16 MR. RAY: I'n -- I'n just telling 14 sooner or later it's polno to have to be taken 15 vou we didn't cone here to address that because I 15 Into consideration.
16 believe to the contrary that it's well understnod.
16 MR. MERSCH0FF Art, are these all 17 and navbe I just bring too nuch baggage to this 17 the heats enployed at San Onofre or, again.
18 discussion, that that lan't so.
18 failures?
19 Uhat I -- what this is trying to 19 MR. RAY: Are there others that l
29 do la to saw we couldn't pick this heat out of the 20 haven't failed in cur population?
21 other heats that we had to consider as one that 21 MR. SCH00NOVER: Yes, there are l
22 stood out as an cuttler.
22 others.
l 23 MR. MERSCH0FF: By industry data?
23 MR. RAY How many? Do you have 24 MR. RAY: Or our own.
24 any idea?
25 MR. HCUELL: vell, snd I guess 25 MR. SCHOONOVER: It's not very Tannte L. Snith. CSR 1817) 625-4948 i
PREDECISIONAL ENFORCEMENT CARING - SEPTEMBER ID.1997 73 74 1
nany. I think about four.
1 service for the Industru versus the time when the 2
MR. MERSCH0FF That helps.
2 Indication was detected -- conputed into hours in 3
MR. RAY: A!! right. We'll answer 3
that power for these -- for the units at the tina 4
that question -
4 the failure occurred would be Indications --
5 MR. HOWELL: Was it - there was 5
MR. RAY: Nov. this is tenperatre 6
four addatlonel in addition to those --
6 pornallred.
7 MR. SCH00NOVER: I believe there 7
MR. SHORT: This is also 8
are four additional heats. The nunbering B
tenperature nornalized for prposes of bringing 9
sequences --
9 hot leg nozzles, for example, onto the sane 18 MR. RAY: We'll provide that.
18 playing field as press wizer nozzles. So ve've 11 additionally.
11 normaltred this data to pressurizer tenperature.
12 MR. fdl0RTs On page 16 I've 12 What we conclude from this is that 13 provided a stattstical analysis of Industry 13 the 7638 performance is very sinstar to the 14 expertence versus the experience Ulth this 14 perfornance in the industry as a whole when We 15 particular heat. The industry experiencs is shown 15 consider all of the use of 7638 and in the 16 lh red. 7630 is shown in blue.
16 industry in general together.
17 This is in -- using a 'Y' bolt 17 In other vords. We don't see fron 18 distribution. Which is a statistical distribution 18 these three charts that 7630 is an outtler by 19 and plotted across 'Y' exts is cunulative to 19 Itself.
20 distribution frequency of Indications of 20 MR HOWELL: Before ve go any 21 cr acking.
21 further. I guess just so it's citar to ne. all 22 So this vould be either visual 22 this data was developed when? This graph the --
23 Indications or non-destructive indicm ions of 23 this --
24 cracking across the vertical axis. As a percent 24 MR. SHORTS The -- the developnent 25
- percentage of the total nunber of noz21es in 25 of the data is current. We've just done this. We 75 76 1
did not develop the data in this fashion prior to 1
20-sonething thousand or whatever it is.
2 the issue being raised. So we acknowledge that.
2 MR. SHORT: In these papers right j
3 In or judgment we were aware of 3
here. there are three separate points --
4 this data, had this data and had applied judonent 4
MR. HERMANN Or whatever it is.
5 to it, that 7630 was behaving Ilke the rest of the 5
MR. SHORT: -- plotted at that 6
Industry. What vo've sinply done is validated 6
number of hours, yes.
(
7 that Judanent through a statistical process.
7 MR. HERMANN It's three points 0
That's the point.
B laying in the lino at about the sane time.
9 MR. BARNES: Is there a reason.
9 MR. SCH00NOVER: Right. It's le Mike, that restricted this recent review to '95 18 actually a coincidence.
11 date?
11 MR. HERMANE: And then -- then 12 MR. RAY: No. We've got '97 data 12 one, five or six times longer than that -- one 13 right here.
13 failure for that heat?
14 MR. SHORT: I can show you '97 14 dR. SHORT: Out in here?
15 date, as well.
15 MR. HERMANN: Yes.
I 16 MR. RAY: Why don't you get it 16 MR. SHORT: Yes.
17 up. I was just going to ask hin to show the '97 17 MR. SCHOONOVER: The times for le dat a.
18 these faltures have been corrected to 653 19 MR. HERMANW: Are there three 19 degrees, So sone of the failures occurred in the 20 failures E at are around 18.000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> and then one 20 hot legs, and their tines have been reduced for 21 failure at a 100,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for this heatt or is 21 Plotting to account for that temperature 22 there only two failures around 18.000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />?
22 correction.
23 MR. SHORT: We're talking about 23 MR. HERMANN No. But I guess 24 7630 and -
24 unat I'n sort of driving at. It looks like there 25 MR. HERMANN: 7630 for 25 nas be two little populations heren era sort of Tannte L. Salth. CSR 1817) 625-4940
PREDECIS20ML ENF0iEEENT HEARDIG - SEPTEMEER 38. 1997 77 70 1
laving around the 18. and ora laying around the C8 1
be the outage when It's detected.
2 nasbe where teetween ~
2 MR. POWERG. So there would be ~
3 MR. RAY: Why don't we put the '97 3
MR. RAY: I think that's a good 4
data up there just so we're looking at all the 4
point.
5 dat a.
Again, we think the question of when the 5
MR. POWERS: - pretty broad air 6
vloistion occurred as important. It's inportant 6
bands on the data points then".
7 to the Enforcenent Policy. for exanple. But we're 7
MR. SHORT: There is. And as you 8
nindful that we need to keep lookinJ at this.
O collect nore data, the data vill begin to go less 8
This adds now the '97 data.
9 around it - around the forecasted line. The fact 18 MR SHORT: This adds the 18 that these lines are reasonably consistent with 11 experience through 1997. and adds nore data up in 11 the '95 data. I think just supports the relative 12 this r1givn out in the 188,fe8 hows rance.
12 value of the technique.
13 The slopes of these lines do not 13 MR. RAY: Dut let ne nake the 14 change significt!ntiv between '95 and '97.
14 point that It'., as true of the blue as it is of 15 MR. RAY: No. But the enount of 1!
the red that the line is associated with the time 16 data fron which the line to '95 es drcan is, as 16 of detection. And the only thing ve're trying to 17 pointed out, nora linited ~
17 discuss here or address here is whether this heat 18 MR. SHORT: Yes.
18 is in outtler. We're not trying to say, and 10 MR. RAY: ~ vea have in '97.
13 therefore, anything else.
30 MR. POWER $1 How do you calculate 28 MR. MERSQiOFF And how is it 21 the service line for failure? Is that just the 21 bomded? It's plain that the slope is the 22 outage that you --
22 steepest that the heat of concern indicating the 23 MR. SHORT ' Yes, we assune that 23 rate at which these failures ocetr as a function 24 the indication of leakage or the Indication of a 24 of EFPH is the greatest. What is the bounding 25 crack occurs at the line of detection. Which would 25 paranater?
79 08 1
MR. RAY vell, let ne answer it 1
particular heat.
2 this uava There is no bounding paraneter. These 2
ve haven't gotten to the point of 3
data, olven that you're only looking at one heat 3
selecting nozzles to replace, going forward, but 4
separated here -- the blue line is only one heat 4
ve're *1aarly colno to do that, not for any reason 5
the red is all the others -- would suggest to you 5
associated with what we're discussing here todavl 6
that a replacenent progran ought to address 7638 6
but for the reason that we can't afford to have 7
as suguested.
7 these leaks develop unexpectedly.
8 Nov. the point is, you could take 8
And, you know. I would expect you 9
sone other heat that would navbe have a steeper 9
ouvs to be concerned about. aren't you guys --
18 curve than the blue ctrve had when you go through 18 aren't Vou. Vou know, creating a lot of radiation 11 this sane analysis herc. So es to whether with 11 exposure here to try and avoid having to shut the 12 the '97 data in hand or even based on the '95 12 plant down and drain down and fix these leaks and 13 data unich the point. I think, is well nade, that 13 is that really necessary and that kind of thing.
14 there is a few nuncer of points in the '95 cata.
14 I nean. I would take another 15 whether or not it would lead you 15 because that's driven entirely by the destro to 16 - to pick ninety -- given th t you decided that you 16 evold forced outages. But we're searching for 17 couldn't stand, and that certainly is our 17 sone way to priortil2e replacement of no221es, and 18 conclusion, continuing leakage of these darn 18 900'11 see us replacing no221es going forward -
19 - things to replace then -- whether the data vould 19 absolutelv -- and that's the reason. It's an 28 lead you to replace this heat or nott I can't 28 ec E nte reason.
' 21 answer you right now.
21 MR. MERSCH0FF I was --
22 But this is a vehicle for trying 22 MR. RAY: I think it's also the 23 to make that dectston. And it nav ttrn out to be 23 focus of these ~ the evaluation you were talking 24 that, in fact, this heat is the one that you veutd 24 about - Ken Slagte not being here to discuss --
25 plcit to replace if you vere poing to do it on a 25 was how can we learn fron our experten;.e and avoid Tannte L. Snith. CSR (8171 625-4048 l
l
PREDECI$20NM. ENFORCEENT CARING - SEPTDIBER 30. 1937 81 82 1
the impact on plant operatica of a forced outage.
1 than 'X.'
2 MR. MERSCH0FFs I was just 2
MR. HERMANN: What you're saving.
3 stunbling over your note at the botton of this 3
vou really didn't address what Ellis vas. I think.
4 graph that states that NX7628 data 15 completely 4
askinp earlier about the slope of the curves?
5 bounded. Indicating there la not a significant 5
It's just within the statistical bound.
6 statistical difference.
6 MR. SH3RT: The slope of those two 7
I just didn't understand that 7
lines -- the industry line versus 7630 line are 8
statenent. Dounded by what?
8 verv very slin. From a statistical analysis 9
MR. NUNNs Let ne a if you look 9
standpoint. these two ~ the heat at 7630 is 18 at the red lines, the hourglass shaped lines -
18 behaving very nuch like the industry, the 11 MR. RAYi Bounded by the red 11 difference in those slopes are very small.
12 lines.
12 MR. NUNN: That's just saving in 13 MR. NUNN: -- that 's the 99 13 different words What the footnote at the botton of 14 percent confidence lines. All of the 7630 daia 14 the page la trying to say.
15 lies within that -
15 MR. FIELDSI One thing I note when 16 MR.11ER$CHOFF: Oh. I see.
16 I look at these graphs is that you've nornallred 17 MR. NUNN: ~ vhich says that 17 everything, when in reality fron a safety IB statlatically, at a 99 percent confidence level.
18 standpoint. ths absolute values are inportant.
19 900 can't tell (f.e difference between a population 19 If you have a thousand nozzles of 29 of 7630 and the renalnder -- than all the other 20 one heat and you have a failure rate of one 21 nor21es. That's what that note says.
21 percent, that's nore safety significant than if 22 MR RAY: I'n sorry. I 22 900 have le noz21es of another heat with the sane 23 nisundert.tood what
- bounded' neans. I thought you 23 failure rate. How do you address that?
24 neant bounded in the sense of, you won't let 11 24 MR. RAY: Well. Walt, valt. You 25 rencin in service if it has a history any worse 25 use the word at the end. *fallure rate.' Nov. I B3 84 1
thought for a second 90' going to saw with 1
know, when 1 start seeing statistical data that's 2
nunber of failures -- absowts nunber of failures.
2 nornalized on a Y-bolt clot and I start looking at 3
things liite this. I guess questions cone into nu 3
The only way that we can talk j
4 about falltre rate is -- is on sone basis that 4
nind about statistical Independence. nunber of 5
takes into account how nany of these things we 5
samples and heat.
6 have in service. That's the only way that rate 6
Things get very complicated when 7
nakes ang - nakes any sense.
7 vou really start to do a good stallstical analysts 8
So navbe I don't understand your B
vith data. So I guest, so far as the statistical 9
question. But the point is. I think it cones back 9
presentation of this I guess we'd really like le to what Ellis was saving before, well, see Uhlz.
18 probably to get sone more infornation on it.
11 supposing you guys have just an inordinate amount 11 Maybe ve ought to have one of the 12 of this - these bunch of heats that tend to crack 12 statisticlaas at our place take a look at it, 13 like this.
13 MR. RAY: We'd be More than 14 You know, you Quvs got all of 14 pleased to do that. But let ne bring you back to 15 these things, and other people only have one or 15 the violation which ve're here talking about.
16 two of then. How do you account for that fren a 16 We're not really trying to 17 safety standpoint?
17 persuade you about sta;lstical netallursv. We're IB vell. the -- and, in fact, if you 18 here to talk about whether or not we had cause and 19 look at this picture here, you would tend to think 19 failed to respond to information that would have 29 that navbe that's the casel vouldn't you?
29 and should have caused us to replace this 21 Actually, we're the first two colunns.
'A' is 21 nat erial.
22 another plant, as you see. But we've had more of 22 Much of it is still in service in 23 this expertence than others have had. That's a 23 the plant. That's what I'n here to talk about.
24 true statenent.
24 MR. BARNES: One final question.
25 MR. HERMANN: But I guess, you 25 Mike. Did you. In this analysis, look at hot leg Tannte L. Snith. CSR 18171 625-4948
. PHEDECISIONAL ENFORCEENT HEARING = SEPTESER 30, 1997 BS 86 1
f ailure as a separate population?-
1 And, therefore. I think it% hard 2
MR. SiORT No. We lumped - I 2
to say what Mike just said, which is that we have 3
should back up. We have lunped hot leg no721es 3
note fattures than anybody else. Belteve ne. We 4
with pressurtter nozzles ~
4 have gone out there with a nitroscope in looking 5
MR. 6ARNES: Well. I understand 5
for leaks, and at least av associates tell ne that 6
that the nornaltration --
C thev don't do that.
7
R. SHORT: ~ Included then ~
7 So nang. Many of the laaks that we 8
put then 1ogether ia terns of IhIs oraph.
8 have found and fixed would not - are not 9
MR. BARNES: Well. I was just 9
self-revealing ~ are not - vould not be 18 curious whether you had took a look at the hot les le self-revealing at the line trev vere detected or 11 fat ture population of the CE fleet. C W t you 11 for sone ccnaldeaable tine thereafter - naube 12 have a significantly disparate of failures in the 12 ever.
13 hot legs conpared to other plants?
13 Sone of this stuff is very ting 14 MR. SHORT: Through 1995. we 14 weepage. So I don't vant to leave that statenent 15 telleve the answer to that question is no.
15 just the vag Mike made it.
10 Through 1997. Unit 3 is expertencing a higher 16 164. HERMANN: Have you fomd that 17 percentage of hot leg nor21e failures than the 17 visual inspections in the CE owners group progran.
18 rest of the CE fleet.
18 Which are like the code Vf *1 exaninations is ~
19 MR. BARNES: Thank you.
19
!91. NUNN Ask that question 28 MR. RAY Well, valt a ntnute.
29 again.
'21 I've got to stop you there for a second. I would 21 MR. HERMANN: Are you following.
22 nalntain. Ian, that other plants do not conduct 22 Ilke. VI-l type exaninations?
T3 the sane inspection that we do. Your experience 23 MR. NUNN: No. We're doing 24 nau be different than that twit that's ng 24 sonething substantially better than VT 1.
We have 25 experience.
25 a dedicated tean of fotr individuals that look at l
87 88 1
each nortle.
1 this is navbe putting nore enphasis on this than 2
MR. HERMA:.N Uh-hub.
2 is appropriate at this nonent in time -- I just 3
MR. NUNN: We have renoved all the 3
vanted to say that by compartno our data with G
insulation around it. We've cleaned all the 4
'other plants. I believe in fairness you need to S
insulation around It. We not only evpect it when 5
take into account how rigorously now we're 8
the unit cones down --
6 conducting these inspections.
7 HR. RAY We -- N take the 7
We didn't alsaus in the past, but 8
hangers off. also, now.
B nov ve have been. And I think it has surfaced a 9
MR. NUNNI We -- We not only 0
tot nore data, particularly in this outage than 18 Inspect it when the unit cones down! We inspect it 16 others have vet to report. We vouldn't have 11 two or three times when we're bringing the Unit 11 reported 11 etther.
12 back up for leaks when It's repressurertzed. It 12 MR. LIORT: I'n going to wrap up 13 is much nore extensive than ang VT to ever 13 this particular discussion on page 27.
14 ytsua11ze.
14 The Inspection Report does 15 MR. HERMANN: I said VT-1.
15 reference sone work done in 1932. Where samples 10 MR. NUNN: Or VT-1.
16 fron this heat were obtained. And the inspector 17 MH. HERMANN I was just trVing to 17 concluded that there was sone evidence of a 18 conn up -- the VT-l's the k!nd of put vcur nose up 18 greater susceptibility of this heat from that root 10 - against the part, kind of a visual exanination.
19 cause evaluation.
25 which is what I think folks are supposed to be 29 We vent back and reviewed that 21 doing.
21 root cause evaluation and concluded that -- Well.
23 MR. VACKLE: We definitely put our 22 the conclusions of the root cause evaluatton are 23 nose up against it. And then when there's any 23 shown here, and tasically that this heat 24 suspect. We take setpes.
24 represent 8d no greater risk of failure than ang J
. 25 ~
MR. RAY: ! nean. I realize that 25 other heat was the overall conclusion reached ond tannie L. Sntth. CSR 1917) 625-4348
PREDECISIONAL EWF051 CEMENT HEARING - SEPTEMBER C.1997 83 90 1
that the statistical analysis that I've just gone 1
talked about for years having large grains and 2
through supports that judgment in our opinion.
2 tots of grain boundary carbides.
3 This is a case where we have 3
And there are poorer 4
reached a different conclusion than was reached in 4
nicrostructures that have Intergranular carbides.
S the Inspection Report.
5 And we have had the banding, the carbide bands 6
MR. RAY: Do you want to ask 6
ve've clearly seeh that before on sone of the 7
Doninion to -
7 Calvert cliffs to heater sleeves, for exanple.
8 MR. SHO3T: Steve Hunt fron 8
which were exantned.
9 Doninton is present. Do you have anything you 9
And looking at the alcrographs, wo 18 vant to offer here in addition to what I've said?
le can't really see anything different in this that 11 MR. HUNT: lio. I think the crack 11 really stands out to saw that the naterial should 12 that gov've seen is certainly consistent with what 12 be particularly poor.
13 ve. at an industry, have been talking about for 13 It's clearly nore susceptible than 14 the last - for the last 18 years.
14 sone of the other heats that you have. But it 1$
And I see nothing in the 15 doesn't stand out as being out of line at all with 16 statistical information that vot, ve provided that 16 the overall Industry experience.
17
- that vould change ev conclusion.
17 MR. HERMANN: So vou're saving 18 MR. RAY: Well, how about this 18 nicrostructure is not significant?
19 point here - right on this point Steve? I 19 MR. HUNT: I'n saving the 29 thought navbe you had sonething.
29 nicrostructure nav be a contributing factor, but 21 MR. HUNT: On the carbides?
21 It's within the spectrun of all the other 22 MR. SHORT: Yes.
22 variables that we look at. There vill be the 23 MR. HUNT: ve've seen -- there is 23 strength of the naterial, the cold working of the 24 a spectrun of naterials fron good nicrostructure 24 inside surface and the nicrostructure of the -- 9f 25 to poor nicrostructure. Good alcrostructure we've 25 the naterial and, obviousiv, the water thentstry 91 92 1
conditions and the tenperatures.
1 adjustnent in operating temperatures several years 2
But putting all thow together.
2 ago.
3 this material seems to be within the range of 3
MR HERMANN: What's the relative 4
typical expected behavior of the natorial. This 4
lines for the -- that their heats and material 5
nay be a little more susceptible due to noterials 5
have seen so far? 50.000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. 30.000. 10.0007 6
factors than sone other naterials which nau be 6
MR. SCH00NOVER: 68. 65.800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />.
7 nore susceptibla because of high strength. But 7
MR. HERMANN: but sone of th9 8
putting the two together, it's cleariv vithin the 8
numbers we're seeing inre for the lines of the 9
range of accepted or expnted behavior.
9 fatture. vet theirs have failed less than yours 16 MR. HERMANN: Dio sonebody say to for the sane heat?
11 this heated naterial was in Palo Verde? Is the 11 MR. SHORT: They have not had a 12 operating tines and tenperatures at Palo Verde 12 heat failure -- a failure of this heat.
13 significantly different?
13 MR. HERMANN where they have the 14 MR SHOR1 On a -
14 nozzles mant'factured the sane vag?
IS MR. RAY: A Ilttle bit. It's --
15 MR. SHORT: The question is, were 16 It's a little high.
1G they manufactured at the same tine?
17 MR. SHORT: On a 17 MR. RAY: The sane way.
18 temperature-adjusted basis Palo Verde and 18 MR. HERMANN: The saw way.
19 San Onofre are verv sins tar in terns of operating.
19 MR. SHORTS The sane way? As far 29 MR. HERMANN: What's the actual -
29 as we know, they were manufactured in the sane 21 Palo Vcrde's a little biggert runs a little 21 fashion.
22 hot ter?
22 MR. HERMANN: The sane design.
23 MR. SHORT: Palo Verde initially 23 MR. SHORT: Yes.
+
e 24 ran hotter. It currently runs slightly hotter.
24 MR. FIELDS: Are they exanined at 25 uut nuth cloaer to San Onofre now. They nace an 25 the sane level of detall for ninute causes?
Tannie L. Salth. CSR 48171 625-4340
PREDECIS!0NAL ENFORCEMENT HEARING - SEPIEMBER 38. 1997 93 94 1
MR. RAY: I don't think we ought 1
based on the average of all the nozzle 2
to of tak to that. Let 's 90. Mike. We're Going to 2
replacenents that have teen dona on site.
3 run out of airplane ting here.
3 including pressurizer repales and hot les repairs.
4 MR. SHORT: To sunnar;2e the 4
MR. BARNES: Is your current a 5
replacement approch used for Allow G80, in 5
MR. SCH00NOVER: To date -
6 particular, this heat, we concluded that there F
MR. BARNES: 1xcuse ne. Eric. Is 7
wasn't a reliable nethod to predict that this heat 7
vour current process Etually a renote 9
would fall.
8 autonatic approach nout 9
Lacking that nethod. Dasically.
9 MR. SHORT No. It's a Manual 10 Harold's tonnent about all nozzles would f equire 18 approach.
11 replacenent. Harold rentioned the ALARA 11 MR. BARNES: You actually use 12 inplications of this to replace this heat would 12 n aualt 13 - have required near19 $8 personren, about what we 13 MR. SHORT: Yes. Correct?
14 Incurred on site in 1904.
14 MR. SCH00NOVER: Not on the 15 MR. HERMANN: Is that based on 15 pressurtzer ~ on the pressuriter It's til 18 doing a manual velding or based on doin0 an 16 automatic.
17 autonated velding manual?
17 MR. SHORT: Speaking off - veah.
10 MR. SHORT: The questlon is. Is 18 vou're right. I'n thinking hot teo, and you're 19 that based on nanual velding?
19 talking pressurizer. We'll take the pressurl2er 28 MR. HERMANNi Or autonated.
20 first. and. Eric. vou answer. Then answer for the 31 MR. SHORT: It's based on nanual 21 hot leg.
22 velding from the exterior nozzle approach.
22 MR SCHOONOVER: All the velding 23 MR. HERMANN: Why Can't that be 23 is autonallC on the pressurl2er.
24 done renotelv?
24 MR. BARNES: That's what I 25 MR. SCH00NOVER: Actually, it's 25 thought.
95 96 1
MR SHORT: And for the hot teos?
1 On the next page I've got sone 2
MR. HERMANN: And why wouldn't you 2
sites from the basis of the tech specs. The 3
use the sane autonated welding on the hot leg?
3 inportant points fron those sites are that tech 4
MR. RAY: We're going to talk 4
specs consider joints to be those not only 3
about the Aston M the hot leg nozzle here in a 5
associated vlth bolted connections. but also C
ninut e.
We think our design is better. And I 6
velding, and that during plar.t operatlun joints 7
assune it's also not susceptible to automatic 7
nav leak.
8 Welding.
8 And the purpose of the technical 9
But there is a different design.
9 specificallon is es shown here lindicatinal. And.
la I know the - we -- haven't --
18 obviousiv. If you do detect a leak in service that 11 MR. HERMANN I'n just tryin0 to 11 vou're required to shut down pronptiv.
12 get a hand on the ALARA nunbers. It's a ble deal 12 MR. HERMANN: What's the 13 If you do it manually versus renote autonated.
13 difference between a pressure boundary leak and a 14 MR. SHORT: And then the last 14 non-pressure boundary leak in your definitions?
15 point to nake on this allde is, la ve telleved 15 MR. RAY: A non-pressure boundary 1S that our approach of visual Inspection is en'6 rely 16 leak. I don't understand your question about a 17 consistent with that of the industry and Ulthin 17 non-pressure boundary leak.
10 the expectations that vou*ve connunI ated.
18 MR. HEPMANN: Leakage eround 19 Technical specificatlons are an 19 bolted connecttons, so far as code rules go. are 10 issua. so va vant to just work our vag through 28 not -- are the - the pressure boundary of a 21 those if we could. This la e reiteration of the 21 bolted connection is the bolts, not the gaskets.
E2 - polley that Harold stated earlier and how the LCO 22 MR. RAY: Yeah. Okay. From that 23 and the tech specs operates at San Onofre, we 23 standpolnt, then. I don't know that we can answer 24 have. I think. virtually standard tech spets in 24 the question the was -- the was you put it. But.
25 the case of RCS operational leakage.
25 obviousiv. there is a difference between a gasket Tamte L. Snith. CSR (0171 625-434n
PREDECISIONAL ENFORCTMENT HEARING - SEPfDtBER 30, 1997 97 90 1
leak and a through-vall leak.
I agree that - and I think that's what the previous 2
And let ne hasten to add that 2
statement savs in terns of not anticipating a 3
there is no way that a crack through the vall --
3 leak. But would you agree the plant should not 4
through the pipe vall of the reactor coolant 4
enter an operating cycle with the anticipation 5
systen would t:e evaluated in the sane nanner as 5
that a presswa boundary leak Will occur that vill 6
What we're talking about here now. So let's not 6
not be able to be'identifled until the subsequent 7
even have anybody toss that up as a red herring.
7 shut down?
8 All - the tuilW point here that 8
MR. RAY: Yes. Without exception.
9 ve're trying to nake is that sometines we becone O
Mindful of the f act that we do have a record here.
10 prisoners of the idea that the tech specs if I want to be clear when I said. 'Wes, without 11 absolutelv. positively do not contenplate any 11 except ion. '
12 leakage of jointe and that anything that nav lead 12 Again. I'n thinking in the context 13 to a leakage of a Joint nust te prevented.
13 of a conponent that - a spectfic component that 14 Ihat's just not true. And that's 14 ve would replace. 1 -- I exclude all no221es as 15 the only point we're trying to nake. We're not 15 forning a class of components taken together 16 trying to justify anything. We're just trying to 16 because, as you know. We and. I believe, the 17 address a fairly narrov issue that sonetimes 17 Industry do anticipate that sone leakage due to 18 arises in the context of whether we have en 18 this phenonenon sonevhere nas occur during an 19 absolute obligation to insure that at no ttne 19 operating cucts.
29 there is the possibility of leakage through a 28 And the only vag I could preclude 21 reactor coolant systen.
21 that with a greater degree of certainty than we 22 Inst's not the case. And we think 22 have todav is to replace then all. And I don't 23 that that underlies the NRC's approach to this 23 nean to erect that as sone of -- vou know.
24 problen in general, but that's for later.
24 inpossible crean. I*n just saving we are not in a 25 MR. MERSCH0FFi Well, would 900 25 node in which we understand that to be required.
99 180 1
and that is, replacenent of all no221es.
1 MR. MERSCH0FF What line is 2
To the extent that we don't 2
L.
3 replace all the no221es and va have this naterial 3
MR. RAY: Well, it's whatever --
4 in service, sonevhere it is likely that a leak 4
no this is nore -- I told you this is the nost 5
vill develop prior to the end of an operating 5
inportant Enforcenent Conference I've ever been 6
cycle, but not in any area that we can predict as 6
at. 50 don't worry about that.
7 a sub set of all no221es.
7 It's just it - it vill have a O
MR. HERMANN: I guess navbe I*d 8
substantial part of the discussion. I knov 41 9
ilke to get a little clartfication on one issue.
9 vill be of a lot of Interest to you. You nav find 18 though. You keep talking about NRC's acceptance 18 sone of it controverstal. And so I just -- If you 11 of positions with regard to pressurt2er instrunent 11 give ne a chance to discuss that after the break 12 no221es. okay?
12 navbe is the right line, 13 I believe there was a (eport that 13 MR. HERMNN: Okay.
14 was in the owners gr7Ups that was discussed at 14 MR. SHORT4 With respect to 15 neettnas and the rest of it. I don't believe 15 Crtterion XVI. I think all of this is a repeat of 16 there was ever a safety evaluation written.
16 what we've covered already.
17 I don't believe the owners group 17 MR. RAYa There's a light switch I
10 paid for a safety evaluation to be written. And I la on the --
19 think the NRC navbe hasn't addressed it with 19 MR. SHORT: I turned it of f first.
20 regard to instrunent nozzles and explicitiv -- are 29 MR. MERSCHOFF: We're in a 72-hour 21 vou going to get into it later?
21 LCO now.
22 MR. RAY: Yes, sir. And it's 22 MR. RAY: Slightly dinner light it 1
23 going to probably run us right up to the line when 23 locks like, l
24 ve've got to run out of here and catch a plane 24 MR. S! ORT: But stt!! legible.
i 25 to -
25 MR HOWELL Excuse ne. Mike.
Tannte L. snith. CSR 18171 625-4348 I
i
PREDECI510hAL ENFORCEMENT HEARING - SEPTEMDER 30. 1997 I
181 182 1
Before you 90 any further, are you going to 1
be have a rest serious problem from the standpoint 2
explain the, statistical anaissis you just did 2
of the reliable operation of the plant associated 3
relative to this plot that you gave us?
3 with these nozzles.
4 MR. $HORT: I c an i f you v. sh.
4 And 1*n trying to flgtre out hov 5
MR. HOWELLt Yes, because I'm not S
nuch replacenent to undertake for purposes of 8
sure what the differences are. This clearly shows 8
inc.' easing the rallability of plant operation. So 7
- ter fraction of leakage, and I don't know. I 7
e tot of analysis, and, again, part of it belno 8
don't know what the relationship is, but this is 8
th.6 -- th* t celf-critical analysis. I've been on 9
based on virtually what you just told ne.
9
-- very dornatic about the f act that we've got to 18 MR. $HORT Ihey're very sintlar.
18 stop this fron occurring.
11 The differencs is that is limited to hot leg 11 So that leads to a lot of ~ of 12 noz21e f ailures only, tenperature normalized. And 12 Infornation and discussion which is geared around.
13
-- and through 1995. We developed a profile based 13 oWW how nucht how sooni What are we villing to 14 on the Industry experience and then applied those 14 do to put an end to this problen fron a 15 profiles to the two units and forecasted based on 15 rettability standpoint.
18 those profiles what the expected future behav:or 16 MR. SHORT The tasues were 17 of the two units vould be.
17 different with respect to that neettna and this 18 This analysts was ocns in July of 18 neeting, so I chose e different type of 19 this vefir to try and understand how the Units were 19 presentation as to the details.
29 tracking with Industry experience. It's another 2d At that meeting toe issue, as 1 21 Way of doing it. It's besically the sane 21 UMerstood it, was the perfornance of our Inconen 22 technique. just applied in a little different 22 nanagement progran versus at what point was the 23 fashion. And I think the conclustons are very 23 progran deviating fron expectations.
24 sintlar to what we reached here.
24 And the point we made back at that 25 MR. PM i Let ne be clear. Art.
25 neeting was that through 1995's outages, the 183 184 1
progran was performno as expected, conststent 1
ve acted on the basis of all available 2
with industry expertence. In 1997 ou Unit 3 ve 2
informat ion.
3 saw a deviation and reacted appropriately in our 3
MR. HOWELL: Okay. We still have 4
judanent.
4
.the outstanding questton about exposure and hov 5
So that was a different issue, 5
nuch could be realized --
6 That wasn't 7C30, per ne but rather what progran 6
MR. SHORT: Yes.
7 vent wrong. So I was attenpting to address that 7
MR. HOWELL ~ if you were to use 8
lasue in that presentation.
B the other velding -
9 In this presentation I'n focused 9
MR. SHORT: Renate versus nanual.
le on 7638 so I use the sane techniques but a 18 MH. FIELDSt Mike, you have a lot 11 slightiv different presentation because I thought 11 of Information here presented for nornalized 12 the tasue was different.
12 curves and evarvthing.
13 Okay. Again, on Criterton XVI.
13 You also stated that this was 14 this repeats what we've previousiv Indicated that 14 prepared for this Enforcement Conference. What 15 vith respect to the corrected actton avects of 15 vere your thought processes -- What did you use as i
16 Criterlen XVI, those were done. Those are under 16 vour judgnent to come up with a decision in lieu 17 dispute and that we did perforn augnented 17 of the fact you didn't have all of this analysis 1B Inspections in accordance utth the goldance that 10 present ?
19 900 lasued to the industry.
19 MR. SHORT: I'm going to go 29 And this is a repeat of vnai we've 20 through that. Mel. That's - the next discussion 21 covered already. as well. In that we didn't 21 15 briefly just sone background on PWSCC. And 22 predict that out of a class 7638 was behaving any 22 then I was going to walk you through the prograns.
23 differently than anything else ad responded in 23 thenselves.
24 that fashion.
24 MR. RAY: Bastcal19. We'll take 25 And the botton line is we believe 25 vou in line through how we responded to this Tannte L. Snith. CSR 1817) C25-4940
PREDECISICAL ENFORCEMENT HICING - SEPTEMBER C.1997 185 126 1
problen.
1 As the crack progresses down the nozzle and 2
MR. $H0kT This is sintlar. I 2
reaches the point where the no221e is no longer 1
believe, to a slide I provided back in the August 3
affected by the velding process, the stresses drop 4
netting. this p s e 23. It just shows a cartoon of 4
to very small values and the longer propagate the the typical reactor coolant SVsten and where Allow 5
track rapidly.
t 600 penetration cracking has been observed, as 6
Ahd. again, the cracks = once 7
Well as the pleMr that are involved.
7 thev progress beyond the heat affected Zone of the 6
This M taken from an EPRI report.
O velding. the Wel'ing-of fected Zone of the nor21e 9
So this is generally available Information. On 9
is very slow.
18 the next page, page P4 We've alre&dy shown you 18 There is a concern that the cracks 11 the typical of an Allov 000 nozzle.
11 night not be axial, that they nav be 12 Unless there are questions. I'll 12 circunferential. Circunferential cracking has 13 nove on to the next silde. Page 25 talks about 13 been observed in foreign reactor plants. notably 14 where the cracking occurs in instrunent nozzles.
14 EDF. And this is because of an Installation 15 It is a result of stresses that build up fron -
15 difference between nozzles used there and nozzles 16 that result from the velding process.
16 used in the CE fleet.
17 The veld is located here 17 The nozzles at EDF in sone cases 18 t lndicat ingl. As the veld cools, it shrtr.ksi and 18 vere hard rolled in place creating a change in the 19 it draws the edge of this nozzle ootvard creating 19 stress field where the roll transition occurs.
29 residual stresses.
28 And that lead to stresses that could propagate 21 And the cracking that results fron 21 circunferentist cracking.
22 those stresses is extal in nature. And that's 22 The cracks in the EDF experience 23 tecause the stresses from this shrthitage procets 23 vere shallow. did not extend through the vall but 24
- reatly exceed any axial stresses present.
24 vere definitely circunferential. However, we 25 The cracks are short in length.
25 don't use this processi and. therefore, we don't f
167 188 1
think our nor21es are subjected to circunferential 1
can go back over the record on that.
2 cracking.
2 MR. RAYS My judgment is we're 3
You had asked for data regarding 3
going to need to sunnarize and give that to you.
4 crack lengths. We can sunnartre that for you to 4
also, because in preparing for the neeting I 5
sone extent today. I'll let Steve do that.
5 wasn't Indicated vo*J wanted those pieces of data.
6 MR. HUNT: Yeah. The crack 6
But we can get then to you.
7 lengths that we've seen expertnentally in the 7
MR. HOWELL Okay. Stre.
O field are around ~ for nozzles that do not 90 in 8
MR. RAY: I'll say the key thing 9
at an angle, the cracks are sonevnere in 'he order 9
here Mike already covered. Which is the stress 10 of five-eighths to the three-quarters of an inch le fleid, changes very, very rapidly as you go down 11 long.
11 the instrunent nozzle away from the point of 12 They've been Inspected at a number 12 attachnent in the veld.
13 of plants over a ten-year period of tine. The 13 And, therefore, the propapation of 14 only lo%'er crach are cracks in nozzles.olch 14 the crack is not the same as it would be in a ~
if h ve had an oblique angle, and there's sone 15 in a pressure vall that is stressed by the 16 ovallt'.' to the no:zle vall.
16 Internal pressure ~
17 Dut. prsnar119 on thle tvpe uf 17
- 12. HOWELL: RIsht rIsht.
18 instrunent nozzle ~ lt's particular with a hot 18 MR. RAY: ~ as the primars 19 teo -- they tend to be short on the order of 19 vehicle for -
29 five-eighthe to seven-etghths of an inch.
29 MR. HOWELL: And all we want to do 21 MR. HOWELL: This is not 21 is Independentiv verify that your actual data is 22 San Onofre data ve're talking about here. What 22 consistent utth what vou're predicting.
23 are you --
23 HR. RAY: Well, we've -- ve've --
24 MR. HUNT: San Onofre has 24 I'll tell you, there is linited data fron 25 performed several inspections. And let's see if I 25 ourselves insufficient to satisfy us that what fannte L. Sntth. CSR (8171 62S-4340
)
PREDECISIONAL ENFORCEMENT HENtDIG SEPTEMBER 30, 1997 189 118 1
ve're looking 41. We think, is what the industry 1
I'll start - I von't spend a lot 2
as a whole has been dealing with, 2
of tlne on this slide, but, basically. this covers 3-So it's not gotno to be exhaustive
-3 in sunnary vbat each of the following slides 4
perhaps, we'll Walt and see. I'll forewarn you 4
discusses.
S that we don't have as auch data as we have 5
To begin with, the repair approach C
experience with having detected cracks.
6 ve've chosen ~
7 MR. SHORft I'd like to sunnartre 7
MR. RAY: Mike, everv tine you put 8
this ser: tion of the presentation in the following 8
e s!!de up there it cuts off the top. So you 9
vav. At SONGS Allov 688 la present in these 9
either need to ste; back and ~ there you go.
18 locatlans lladicatingt.
18 MR. SHORT: That was deliberate.
11 11 was originally selected for the 11 I was trying to nake sure the botton was showing.
12 reason I show tere. It was installed, as was true 12 MR. nAY: Yeah. I understand that.
13 in all CE units, without stress relief, and like 13 MR. SHORT: I von't *- all right.
14 ether uses of Allow C88. ratably in the stean 14 The first key losue is how do you repair one of 15 generator tubing. these nozzles have proven to be 15 these? As I've shown you earlier the cracking 18 susceptible to this danage mechanisn.
16 originates in this portion.
17 This is the situation as of 1935.
17 And we've chosen a repair 18 in terns of total nozzles found with cracking and 18 technique that allows us to nove the veld ~ the 19 vtaat San Onofre's portion of that has bsen up to 19 pressure boundary veld - to the outside of either 28 that point in time. and, again, a sunnary of how 20 the vessel or the hot leg, as you can see here.
21 ve see our response to this issue, as well.
21
- ils happens to be a detall of the 22 Now, what I'd like to do is get to 22 vessel repair v...a a weld bulld-up to create a pad 23 Mel's question about our progran. So this next 23 which then the pressure boundary veld is nade to.
24 disrvas:On is how we applied this paterial and 24 11 leaves in place the flaw itself and the inner 25 Dullt a progran.
25 J-groove veld.
111 112 1
The reason it does that is, one.
I s:isver on the conduct of this proress -- to what 2
it doesn't require entry into the vessel. In the 2
extent is it renotes to what extent is 11 3
case of the pressurizer, the vapor space nozzles.
3 non-renote?
4 vou can hav" access to then from the ID ~ fron 4
Most of the line and effort is in 5
the inside.
6 setting up the drilling naterials to det!! the old 6
And we did not use this technique 6
no221e out, cleaning the area. and then setting up 7
originally for the pressurtter. We actually 7
to do -
- to install the new no2210.
8 ground Jul the 'J' veld and replaced it. But in 8
So I belteve that the najority of 0
the lover part of the pressurizer where the water 9
this exposure is unrelated to the veldine process, 18 space no221es are and the hot legs, themselves, 18 ltself. The degradation is abandoned in place, 11 accessing to do ID welding is ~ is not 11 which does represent a concern about exposing the 12 practical.
12 base naterial of the pressurizer or of the hat 13 So. consequently, this technique 13 leg. Which is an allow steel or carbon steel.
14 was developed as a vag of overconing that. It's 14 It's not clad in the bore, so the 15 now in connan use Ulthin the CE fleet. It also 15 bore area is exposed to boric acid as a result of 18 deals ulth foreign natertal issues.
16 this repair technique. It was originally --
17 If you vere to bore out this inner 17 because of that fact, it was originally considered 18 veld and have no Way of entering the loop to 18 to be an interin repair, short-ilved in nature.
10 renove any chips, you're relytng on renote chipped 19 requiring renoval and inspection of that bore 29
" chip-catching, debris-catching techniques. And 29 periodically at some point in the future.
21 those are known to break down under these kind of 21 vhat has occurred since 1993. IS 22 circunst ances. So that was an important 22 analytically it's been quallfled - quallfted by 23 consideration in developing this.
23 Inspection at another plant. What our plans are.
24 And then, as noted this is our 24 now that we've used this repatr a nunber of lines 25 experience with personren. And we ove you an 25 and intend to use it in the future, is to verify Tannte L. Snith. CSR 88171 625-4M8
PRh 7,ISI0llAL EtWORCEONT HEMtING - SEPTEMBER 38, 1997 i
113 114 1
that the analytical nodeling and the inspections 1
thnse no221es were dellied out? They're not just 2
at other plants are bounded by our own experience 2
a circunference -- you cut the end of it of f and 3
or bound our own expertence.
3 go in vnth circunferential cut and renove it?
4 So we vill te conducting a 4
Decause I thought that was part of the reason thew S
nonttoring progran of this bore area during the 5
vanted to do this.
6 CVcle 10 refueling outage, which is the next 6
M. SHORT: The technique of 7
refueling outage.
7 renoving the no221c?
8 MR. HOVELLi So at San Onofre the B
MR. HERfWIN: Yeah, y
9 first line you used this technique was in '937 Is 9
MR. SHORTS I nav have misspoken.
18 that --
18 I*n not cxactly sure how it's renoved.
11 MR. SH0;T: I think that's 11 MR. HERMAlait I can't believw nev 12 corrvct. hight. Er et 12 nicht driti that.
13 MR. SCH00NOVER: Yes.
13 MR. SCH00lRVER: I %1leve it's 14 161. SHORT:
'93.
Originally 11 14 bored.
IS was done by a contractor, and we now **
15 MR. SHORY: Boredt 16 MR. SCH00NOVERt vell --
16 MR. SCH00NOVEPs Bored out.
17 MR. SHORT
- have the aol'Ilv to 17 MR. SHORTt I next want to nove on 19 do it ourselves.
18 to inspection capabilities. Herold nentioned 19 MR. SCHOCYER: Actualtv. the 19 this. This is sunething that we belteve ve net a
.NI first time was in Unit 2 in the pressur42er. but 29 standard for in the Ind9stry.
21 that was only an interin repair. That was 21 I have three photographs here, and 22 replaced with a 'ull no221e in '93.
The first 22 I want to walk you through. The first one shows 23 tlne it was installed and kept in place was in 23 an instrunent connected to a no221e Which then 24
'93.
24 the background is the pressurl2er vessel shelf.
25 MR. HERMANN Did you actu911g say 25 We'vo cut a vindow in the 4
l 115 116 1
insulatton. Nornally, the Insulation butts right 1
learned in 1937. Was that the c.lanp could obstruct 2
up against the no221e assenbly, itself. We've 2
a hypothetical leak. So we decidec to now -- fron 3
actually cut Windows in all of our insulation to 3
this polnt forward. We take thet.e clanps out of 4
allov 'nspection of that joint interface to the 4
the way so that we can 60 an effective inspection 5
vessel or to the 1000 and allow inspection.
5 of that interface.
6 therefore, of that interfac' at tenperature in 6
And that's done on the way down to 7
Mode 3. 4 0019e down at the..iginning of an outaan 7
an outage. It's not done on the vay up. So in 8
and on the vag bacs up.
8 sunnary. the bare metal inspection --
9 We then Install insulating cover 9
MR. HOWELL: Just to te clear in 18 over this vindcv. So that's essentially an 10 the caso of Unit 21 did this clanp obstruct --
11 inNect ton port that's been added. This was done 11 MR, SHORT: It's possible this 12 in 1933, 12 clanp obstructed the early indications of leakage.
13 There's a little differe.it vtev of 13 so ve. In essence, are in the process of trying to 14 the sane type of opening. It's actual' y the sane 14 learn fron that expertence, we postulated that 15 no221e Just a dt f ferent angle on it. And inside 15 and took corrective action in accordance with --
16 90u can barely nake out a clanp. The next picture 16 MR. RAY: Again, let Pe say. Art.
~
shows the clanp. Itself, on a sinitar no221e.
17 I's doing this even thocGh it cost inne and noney 10 It would have to be a 01fferent 18 and runs the risks that you're not going to get 19 no221e but this picture illustrates what "ne clamp 19 the doggone clamp back and all that kind of 29 looks like. It lies under the insulation. And as 20 stuff.
21 vou can see. It's possible for that clanp to 21 In order to insure that 've don't 22 Interfere with the observation of a verv snall 22 develop a forced outage due to a nelf-revealing 23 accunulation of borte acid.,
23 leak later on. We want to find these things early.
24 Through 1997, we lef t these clanps 24 I don't think anybody uho hasn't 25 in place. We did not renove then. What we 25 had our expertence would ever do that. And I l
Tannie L. Smith. CSR tB171 625-4948 l
PREDERISIONAL ENFORCEMENT HENtING - SEPTEMBER 38, 1397 sr 117 118 1
wouldn't have. So we're ~ ve're talking about 1
the pressurizer. For exanple -
2 Inspection date here whic'. 900 know, we've 2
MR. RAY: That's why I'n doing 1
sinply. out of self-defense put in place. - But 3
this is because the, doggone things do reveal 4
It's quita far beyond what we use1 to do.
4 1henne1ves, hopefully.
5 MR. SHORT Wlthout the use of Ihe 5
MR. HOWELL R1pht. risht.
8 windows, without the use of bare netal techniques.
6 191. $NORT: Tws.
7 nany of otr leaks 90014 tiot have been detected.
7 MR. RAY: At inconvenient lines.
8 They are undetectable without these techniques.
8 MR. SHORT: Yes.
9 If the Insuletion is left in 9
MR. RAY: $$ ~
10 place, no vindow is put -- if no Window is 18 MR. HOWE 1.L
- Right, il provided, you will not see these leaks. They do 11 MR. RAY: ~ that's why we started 12 not alcan, tupleetly. So they're not ~ they're
- 12 cutting all these little vindows and taking the
'3 not observable generally, in that fashion. You 13 brackets off and all that kind of thing.
14 have to get to the bre metal to see these.
14 MR. SHORT: This is an example of 15 I put a couple of examples here.
15
-- sinitar to one I showed at the very beginning 16' These are sinitar to the photos that we showed you 18 of the presentation. This is the loop piping 17 a nonent ago. Here's a ~ clearly. With bare 17 here. This is a portion of the insulation that's 18 net.<1. Util can 3ee leakage here.
10 been a this piece has been renoved to allov 19 With insulation in place this leak 19 increased access to this nozzle.
28 vould not be dete.ted because it wasn't stear.ing.
28 Here's the no221e interface to the 21 This is a very snall lea *. It Just accur.uiated 21 loop. This cap. I nentioned eer!!ar is anvvhere 22 enough boric acid where it's clear --
22 fron 2 to S nits in clearance. And a snall anount 23 MR. HOWELL: Nov vou have had 23 of white-Ish nsterial had accunulated there.
24 sone that have stearEd. right?
24 MR. HERMANN: You're tciling ne 23 MR. $HORT: We hive had -- notably 25
'his one on the left is sone',hing that cane fron L.,
119 128 1
spittire in fron sonevhere else Ltd not a veep out 1
be --
2 of there ve sus the one on the right being, what 2
MR. HERMANNI No. That one over 3
I'll call, a little bigger -- a snall -- I'll 3
there with -
4 charactertre the one on the right as a small leak 4
MR. SHORT: This vould not ce 5
and the one on the lef t as navbe a veep.
5 characterized as fron another source.
8
- 19. RAY: We were guilty of 8
MR. RAY: valt. Hold on a second.
7 vishful thinking on the left.
7 MR. HERMAWN The one on the left.
8 MR $HORT: This is a case 8
MR. RAY: I think he was asking us 8
where we thought --
9 before why did we do what we did in terns of te MR. RAY: We were wrong.
18 radio-chenical ~
11 MR. SHORT: We didn't think this 11 MR. HERMANN: Yeah.
1 12 was leakage. We thought this white na'ertal 12 MR. RAY: -- t est ing. And I said 13 wasn't boric acid and wasn't an st.dtcation of RCS 13 because there are places in there where there is 14 activity. We thought it was --
14 boric acid crystals, and sono of it has run down 15 tIR. HERMANN: That. I'll buv. You 15 on things like tuts due to a spray 1oun of the 16 didn't know what 11 van.
16 containment and different things that have 17 MR. SHORT: We thought it was 17 happened.
18 residual --
10 So I defend the use of
-13 MR. HERMANN: You didn't --
19 redlo-chenical analysis. In this particular case 20 MR. RAY: What?
29 here it was a nistake to accept that as a basis 21 MR. HERMANN: That's reasonable.
21 for it not being a leak.
22 But. I nea,1. I don't think -- the story you said 22 MR. $HORT: This was not thought
-- 23 earlier is that it dunped fron sonevhere else 23 to be boric acid from another source. I don't 24 arut --
24 vant to nislead you aoout that. Th's was thought 25 MR. SHORT: Well, this vould not 25 to be not boric acida rather. this was thought to Tannie L. Smith. CSR 1817) 625 4948
PREDECISIONAL ENFORCEMENT HEMLING - SEPTEMBER 30, 1997 121 122 1
be cleaning natt.rlat left over from cleaning 1
MR. HERMANN: Okav.
2 dwing the outage of 'ble area.
2 MR. RAY: I'n not going to defend 3
And 11 was chenically -- 11 was 3
It. I'n just telling Vou what we were doing.
4 radio-chenically analv2ed. And the conclusion 4
MR. HERMANNs Okay. I thought you 5
was, it wasn't fron the reactor coolant systen.
5 were trying to nake point with it that --
6 And that conclusion has been validated 6
MN. RAY: No. No. I was trying 7
Independentiv based on -- soltiv on 7
to nake the point that sometines we nislead 8
r6310-chenistry.
O curselves. I think --
9 MR. HERMANN: Okay. But I thought 9
MR. HERMAM: Okay.
18 vhat you said on the one we were talking about 18 MR. RAY: -- In an effort to try 11 earlier that 11 was four years old.
11 and nake sure we're not cutting these things out 12 HR. YACKLE: We -- ve learned that 12 unnecessarliv. I nean, it's not a snali deal to 13 when you shut the nuclear power plant down --
13 renove these nozzles and put in new ones.
14 within the first several dacs of the shutdown --
14 MR. SHORT* Okay. As vs. again.
15 short lived todine and other Isotopea are readily 15 go through the industry experience and its 18 available and can lead you to the conclusion -*
16 approaches, this is a 9unnary of what we've 17 MR. HERMANN: Yeah, I know that.
17 already Covered.
18 MR. YACKLE: And in this case here 39 I will nention a nav point located 19 vou're looking at a photograph were the -- It's at 19 here that we have -- through prenaturely 29 the end of the outage. and we've refilled the RCS pe preventative 19 replacing - replacing before the 21 fron the RWST, and what we had in tNre was not --
21 cracking had begun, put ourselves in a position of 22 ve learfied we can't do this type of assessnent 22 having to do replacenents again in the case of a 23 late in the outage. We just --
23 pressurl2er.
24 MR. RAY: I'n not going to rely on 24 MR. BARNES: What do vou neon by 25 this angnore.
25 that. Mike?
123 124 1
MR. HOWELL: Yes. I guess I 1
ntnute. Art. This la not an issue with regard to 2
don't --
2 690.
I 3
MR. SHORT: We've -- we have -- we 3
MR. HOWELL: Right.
4 have preventatively replaced nozzles in the 4
MR. RAY: I nean, we're not saving I
5 pressurizer prior to the identified presence of 5
that if we put in a 600. We think it's going to 6
cracking.
6 crack, as well, and so we shouldn't put in a 630 f
7 MR. BARNES: Uh-huh.
7 in sone circunstances for that reason, 8
MR. SHORT And we found ourselves 8
MR. HOWELL:
Right. I just 9
replacing that sane nozzle again because the 9
vanted to be clear on that point.
18 replacenent cracked.
10 MR. RAY: Yeah.
Il MR. HERMANN: What did you do put 11 MR. HOWELL: Yeah.
12 in thernally-treated 600 the first line?
12 MR, SHORT: Welt. We've used 690 1
13 MR, SHORT: We were conpelled by 13 and 6 -- and f)11 in naterlat conpatible utth 14 the state of the industry at the line to use 14 690.
15 Inconel 600.
15 MR. RAY: And we're not saving.
16 MR. HERMANN: Thernally-treated 16 therefore, that preventative replacenent is 17 600?
17 sonething we vould not do -- to the contrarv.
18 MR. SHORT: Thernally-treated.
18 I've just said several times it's sonething we 19 MR. HERMANN: Right. The nicro --
19 would do So I think this point can nislead.
29 MR. RAY: Ihts is --
29 MR. BARNES: The systen varrants 21 MR. HERMANN: That's another 21 that where your records Indicated a correlation 22
$0lnt.
22 with the velds but led to having to pull the f
23 MR. RAY: This is not --
23 second ones off.
24 MR. HOWELL: Yeah, It's --
24 MR. SHORT: I'n sorry?
25 MR. RAY: This is not -- vast a 25 MR. RAYS He's talking about where l
Tannie L. Snith. CSR 80171 625-4%e i
i
.m
_m F'RE0CIS? DIAL ENFORCEMENT CARING - SEPTEMBER 13. 1997 125 126 1
ve used Allov 000 veld material. I think. Was -
1 pressurizer nor21e leakage and a hot les noz2le 2
MR. BARNES: There was a couple of 2
leak in Unit 2.
The plan was based on three 3
failures or cracking or whatever was ideattfled 3
prentses. We've covered the absolute prediction 4
related to the veldnent.
4 prenise alreadv.
5 MR. SHORT: Yes.
5 We indicate back in 1993 trat to G
MR. RAY: Exact iv.
6 the best of our knowledge, pernanent repairs night 7
MR. SHORT Yes.
7 not have been available. What we were installing 8
MR. RAY: Right.
8 had a potentially tenporary nature to it.
9 MR. SHORT: That's an exa:ple S
And lastly that this was an issue 10 where -
18 of non-significance from a safety perspective.
11 MR. BARNE*
Are these the sane 11 Out of that plan several reconner.Jations arose.
12 Ones we're talking about?
12 We've talked about tone of these already. One is 13 -
MR SHORT: That's one of the 13
-- for exanple, is to nodify the insulation, and 14 examples we're talking about.
14 ve've done that in responoe to this plan.
15 MR. BARNES: Okay. Thank you.
15 On the next page. the plan took 16 MR $HORT: we vent ahead with a 16 each location where A11ov 600 was used, assigned a 17 replacenent even though the replacement did not 17 relative susceptibility to the nozzles in that 18 take advantage of the best naterials. Ar.d that 18 location nade a reconnendation. And then I've 19 replacenent had to be replaced again.
19 Indicated how that reconnendation was O
Okay. Nov. I want to talk about 29 disposittoned.
21 planning. In response to all this information.
- 1 The plan provided reconnendations 22 plans were assenbled. I want to begin with the 22 to nanagenent for nanagenent to act on. This 23
'93 plan otherwise known as revisixt zero of the 23 vould represent nanagenent's actions based on that 24 Allow C00 plan.
24 plan.
25 The experience to date had been 25 MR. HOWELL: Just so I'n clear.
I 127 128 1
are you asserting that one of the reconnendations 1
was updated just prior to the '95 refuelings.
2 was n:t to have sone proacttve nozzle replacenent 2
In sunnary. the plan called for 3
based on susceptiblittu ranking?
3 the following actions. And the Inplementation of l
4 MR. SHORTS The plan did call for 4
the plan had the following results in '95: In l
5 consider rep 1Eenent of hot leg noz2les ~ In a 5
Unit 2 there were no leaks identifled no acttons 6
sense this is a proactive replacenent -- and the 6
were taken of a repair nattre. And then 1ktet 3.
j 7
vater space notries in the pressurizer. Both of 7
as you can see, these conditions were identified 8
those reconnendations were acted on in the 8
and acted on.
9 following vav. Both of then were considered and 9
The inportant point on this slide 18 deferred.
le la what conclusions were rehched after the '95 11 MR. BROCKMAN: So deferred through 11 refueling a first of all that the plan was 12
'97 --
12 managing the cracking of noz21es.
i 13 MR, SHORT:
'97.
13 Secondly, and that our expertence i
14 MR. BROCKMAN: -- neans as of 14 was consistent with that of the industry. And.
15 today. they're sit 11 deferred?
15 third. Up to this point we had been using 16 MR. SHORTa They're no longer 16 contractors to do these repairs. It was 17 deferred as of today. But as of the '97 17 considered inportant to develop that technology i
18 refuelinos. thev ~
18 in-house.
19 MR. HOWELL: And what was the 19 But we want to nake the point that O
basis for deferral.
20 that wasn't a pre-condition to replacenent 21 MR. SHORT: I'll go through that.
21 activities. We believe we've been nisunderstood 22 MR. HOWELL: Okay.
22 on this point.
23 MR. SHORT: In '95 the plan was 23 Nov. With respect to '97 -- and M
updated. This is the revision one to the plan 24 this would be planning the refuelings that I
25 that to referred to in the Inspection Report. It 25 occurred in '97 for both units -- we elected to l
Tannte L. Snith. CSR (01D 625-4940
PkEDECISIcelAL ENFORCEMENT HEARlWG - SEPfDIBL18 38.1997 129 138 1
continue with the plan as put together in 1995.
1 MR. RAY: ~ alone? We all 2
We did consider the 2
understand thatt 3
reconnendations that had been made earlier to 3
MR. HovELLs Right.
4 conduct a prt/ active replacement. ParticularlW as 4
MR. SHORT: This is the global --
5 a neans of having an efficient outage.
5 MR. BROCKMAN Uh-huh. Uh-huh.
6 MR HOWELL: I'n getting confused.
6 MR. Sn0RT: These are the reasons 7
Mike. The water spaces nozzles that were 7
that were used to reach the con a lh support of 8
reconnended to be replaced in '95, and deferred 8
the conclusion that was reached. These reasons 9
through '978 when you got to '95. how did you 9
vere tae sans reasons used in 1995, 18 disposition those? I guess I dlM't hear you.
18 That's how I wanted to get to 11 MR. SHORT We elected to not it answering your quLstion, Art. Sorry it took ne so 12 execute that reconnendation.
12 long to get to it.
13 MR. HOWElls On the basis of 13 Now, this is the planning for the 14 What?
14 1997 refueling. The Unit 2 refueling in 1997. We 15 MR. SHORT: On the basis of --
15 did have a leak arise durina return service of the 16 vell, basically, it's the sane reasons as I'n 16 Unit.
17 going to show here.
17 As a result of that leak.
18 MR. HOWELL: Okay.
18 nanagenent requested the safety engineering 19 MR. SHORT: So although we 19 assessment that's referred to in the Inspection 29 considered pro-active replacement, we deternined 28 Report. That arcse a that request arose 21 that it wasn't ~
21 following the Unit 2 outage. I'll get to that in 22 MR.RMs Can I renand evervbudy 22 just a nonent.
23 that we're not talking about beat WX7630 here --
23 I've provided this infornation to 24 MR. $HORT: Yes.
24 Sunnarize overall ow ecertence with A11ov 600 25 MR. HOWELL: Yes.
25 and I've shown the 700 eNience at the botton.
131 132 1
So this reflects the total nunber of nozzles in 1
Angel Sistos, who's here today.
2 service per unit, the cracking experience through 2
The purpose they were given was 3
'95 and where it occurred, updated through 1997, 3
use hindsight and identify lessons for future 4
where it occurred, and whether it was confirned or 4
Inprovenent of our progran. It's inportant to 5
not as through-vall leakage as noted by the 5
note th" the report doesn't attenot to assess the 6
dIattnc1 Ion betveen 1he nunbers versus the nunbers 6
prudence
.( the past decleIons, rather. It Is how 7
in the paragraphs. And then the 7630 experience 7
can we improve on those decisions and 8
is shown at the botton.
8 nethodologies.
9 If I could. I'd like to talk about 9
The report nade three 18 the safety engineering assessnent.
le reconnendat ions. The first one is to provide an 11 MR. RAY: This is the -
11 alternate neans of addressing nozzle leakage fron 12 MR. SHORT: Mad ~
12 Welding repair, and this la a nechanical seal 13 MR. RAY: -- nissing Ken Slagte 13 assenbly. We've sutellted that, and we are 14 piece.
14 valling staff approval to use this alternate 15 MR. SHORT: -- this a this was 15 neans.
16 requested by management in response to the Unit 2 16 It reconnended that we renove any 17 pressurtzer water space leak that occurred during 17 obstructions in the event those could hide early 18 restart of the Unit.
10 Indications of leakage. That reconnendation was 19 The heat involved is other than 19 completed and used in the Unit 3 outage. We've 29 7638. And we're bringing this up because it was 29 talked about this already.
21 pointed out in the Inspec'lon Report as relevant 21 And, lastig. It reconnended that 22 to the issue.
22 after each refueling we reassess our situation.
23 Our Isutlear Oversight 73 nake changes as appropriate and :iove forward.
24 Organization, which is headed by Ken Slagle.
24 That recnnendation was alreadv :n place and 25 put together a tean. The tean es lead Du 25 connitted to in our overall nuclear organization Tannte L. Snith. CSR (8171 625-4343
PREDECI510NAL ENFORCEENT HEARING - SEPTEMBER 39. 1997-133 134 1
business plan. And it's in progress as we speak 1
$o that's basically what they were 2
with a completion date of the et.1 of October.
2 assigned to dol not critique the deelstons made.
3 I nake note of what it doesn't 3
but rather tell us how the decisions could have 4
reconnend. It does not reconnend pro-active 4
been nade differently.
5 replacenent of Watea space or hot leg nozzle.
5 And the first nissed opportunity G
replacenent. ' Jid consider these, but it did.
8 Identified was the presence of obstructions 7
not reconnend that this occur.
7 Interfering with the possible ovidence of 8
Again, based on factors that are 8
leakage. We've already covered the response to 9
virtually identical to the factors that we used in 9
that. We've nodified the progran to address le 1937, and again in 1995, to reach the sane 18 that.
11 conclusions. The report --
11 There were two additional alssed 12
- m. HOWELL: Are you going to talk 12 opportunilles discussed.
13 - about vow Incone1 strategic plan?
13 MR. HovELL1 Excuse ne.
14 MR. SHORTS Only very briefly at 14 MR. SHORT: Yes.
1$
the ver'J end.
15 MR. HOWELLt we know of the Unit 2 16 The report covers three nissed 16 example that occurred in. What. March. April of 17 opportunttles, and we Nant to nate sure that it's 17
'977 Have there been any others that were nissed 18 - understood bhat we nernt by that. First. We're 18 through your inspection progrant 19 going to define what a nissed opportunity was for 19 MR. SHORT: Through th6 presence 29. purposes of this report.
28 of obstructions? Not -- not that I know of.
21 A nissed oppot tunity is a place in 21 MR. HOWELL Not through
- 2 line dere a discussion is made. And if you nov 22 obstructions. Just nissed that where re-aaalvses 23 look ba <lth hindsight at that decision. could a 23
- reanalysis you concluded that the leaks 24 different decistor. have been made and with the 24 exister' for sone line.
25 result of that. change the Inpact on the outage.
25 CD'JRT REPORTER: I'n sorry. I'n 135 136 1
having a hard line hearing.
I gas a very real neaning here, as well, which is 2
MR. HOWELL: I'n sorry.
2 the opportunity to expend resources to avoid an 3
COURT REPORTER: That's okau.
3 inpact on revenue. or the output of the plant.
'4 MR. HOWELL: That the leaks 4 'which translates into revenue.
5 existed for sone line.
5 And I havs a high notivation to S
MR $HORT: We had the experience 6
try to find cases where we've, through whatever
(
7 where radio-chemistry told us that we weren't 7
reason, not applied the resources that we night B
seeing the leak in July of this year -- excuse ne 0
aave owe, had an inpact on the productivity of 9
-- Jma of thle year on Unit 3 on the return to 9
the plant, le service.
18 And so that's entirely the context 11 That penetration was then ahown 11 in which this work was being done because I was 13 definitively to be leaking about a nonth later.
12 very exercised over the fact that we had had these 13 So we're vondering if there was a leak present in 13 inpacts on the outage on the return to service of i
14 June and the radio-chenistry jus' wasn't sensitive 14 the plant.
15 enough to discriminate that the leak was present.
15 That's not the oniv neaning that, 16 MR. RAY: That's nu opinion.
16 nissed opportunttles can happen. In fact, in this 17 MR. $HORTs That's a po;stble 17 environnent that we're engaged in now. It usually 19 other case, not confirned.
18 has a quite dif ferent neaning -- In e'tforcenent 19 MR. NUW The ciher tDing there 19 space, for example.
l 20 that Mike skipped over, we also added additional 29 But that's not at all the thing I
(.
21 Inspections during the start-up operation as a 21 was looking for in insisting on this analysis to 22 result of that safety issue that previousiv 22 be done.
l 23 been -
23 MR. SHORT: On page 42. the first 24 MR. RAY: Let ne at this polet 24 of the second two ntssed opportunilles is 25 insert. Missed opportunity. fron nu standpoint.
25 discussed. And this refers to the change -- the Tannte L. Snith. CSR 18171 625-4940 l
PREDECISIONAL ENFORCEMDIT HEARING
- SEPTEMDER 38, 1997 137 138 1
proposal to pro-actively replace in 1997 that was 1
MR. SHORT: And the second Kid 2
originally proposed in 1933 -- to inspect and 2
last of this group of Missed opportunities 3
replace, visually exantne for stans of leakage and 3
discussed in the report is on tilde 43. Again.
4 respond accordingly.
4 t t's a sinitar type of assessnent. And the ve recognize that that was a response is as you see here. ve've gone through 6
ntssed opportunatu 'n the context of the 6
this already.
7 terninology used in this report and the responses.
7 vhat it enounts to it, this is --
8 vet we agree that that certainly was the case --
O ves, nanacenent did assess and conclude that 9
that based on the f actor 6 present et the line, be 9
pro-active replacenent wasn't likelv.
18 hade a dif ferent dectslon than hthdsight vovid 18 MR. MERSCel0FF I guess I'n a 11 lead US to believe.
11 little confused about this. I thought that 12 MR. SISTOS: Let he clartfu that 12 engineertha had reconnended this pro-active 13 11 was just spectfic to that nass that failed in 13 replacement, and the group charged with 14 March of this year, ve wie not really looking at 14 deternining whether this fat ture was avoidable or 15 other heats or -- It was just that specific 15 not on review had endorsed that.
16 f at ture that we had seen in March.
16 MR. SISTOS No. Actually. It was 17 MR. HOWELL: vas this one of the 17 the same engineering lean that had put the 18 onet ist would have been replaced in 200S?
18 orlDtnal reconnendation together that changed the 19 MR. $1STOS: Yeah.
19 technical reconnendation later on, on revision 29 MR. SHORT This was a water space 20 one.
21 nozzle 5.opned in 'P1 for replacennnt in '95.
21 So it was basically the sane group 22 MR. HOWELL: But you did look at 22 of people, the engineers that had prepared the 23 hot leg nozzle replacener.t.
23 orlotnal report in 90022. ref zero that later 24 MR. $1STOSi se also lo^ked at hot 24 changed their technical decision or reconnendation 25 leg nozzles.
25 to not pro-actively replace then.
139 142 v
i So it was basically, the technical 1
of the persons involved in that.
2 realn of the engineers, tnd av nanagement concur 2
Basically. It was the Information 3
with that.
3 that Indicated that the -- the -- there was no 4
MR. DROCKMAN: So to nake stre I 4
real need to go wholesale replacement of nozzles.
S understand, all the engineers were -- not all --
S No one -- that the -- there was not a --
6 but the engineering tcan, basically. that was in 6
predictive nodels had not been developed that 7
charge of putting together the original 7
could tell you specifically which nozzle to 8
reconnendation to go with the pro-active progran B
replace.
9 was the sane ones that was part of the outage 9
MR. FIELDS: vell, want a ntnute.
18 planning.
18 You said that voir ntssed opportunity nunber two 11 The scope planning said, no, wo 11 was relative to one nozzle.
12 really don't want to do that now. They basicalls 12 Ifi. SISTOS: Yes.
13 reversed their reconnendation.
13 MR. FIELDS: So just now you said 14 MR. SIJTOS: Yes. Yes, based on 14 a wholesale nozzle replacenent, but your oniv --
15 Information that they had now available, thev 15 MR. SISTOS: Yes.
16 bellent that the process of nanao.no this type of 16 MR. FIELDS: -- nissed opportunity 17 cracks was acceptable with a very aggressive 17 was to replace the one nozzle that first --
16 Inspection progran and then detect then verv. very 18 MR. SISTOS: Yeah. In -- back --
19 early and then fix then.
19 back In 1993. they had reconnended to replace the 29 MR. FIELDS: What was the new 20 vater space nozzles --
21 Information? What was the new infornation that 21 MR. FIELDS: Uh-huh.
22 nade then change their nind.
22 MR. SISTOS: -- In '05.
And then 23 MR. SISTOS: The Inforfiation **Lat 23 when '95 came around. the same technical tean 24 they had seen in the CE owners groups, ve have 24 decided that that was not necessary after all.
25 people that were very active. Tor Nkle was one 25 MR. BROCKMAN: So for the outage Tannie L. Snith CSR 1817) 62S 4940
=.
_~
l PREDECISIONAL EN80RCEMENT MEARING - SEPTEMBER 38, 1997 141 142 1
planning group. then. they subnitted a new 1
MR. YACKLE:
'95.
Consideration 2
reconne# ton that the management tean would have 2
was again put into replacenent of noz21es. Again.
3 pone on. or that part of the nettings that 90 ont 3
a technical assessnent was made and a decision was 4
I'n just trying to get -
4 nade to defer it once again.
5 MR. YACKLEi Yeah.
5 MR. BROCKMAN Nov. Probably the 6
MR. BROCKMAN: ~ the dynanics 6
the point I Want to make sure I understand is the 7
that vent along with this.
7 technical reconnendation that cane fron that point 8
MR. VACKLE: The advantage I have 8
at this tine was now not to do it, or was the 9
la that I was there.
9 technical reconnendation again to do it th '95 and 18 MR. BROCKMAN: I was hoping 18 then the nanagerial decision ulth all the other 11 someone was.
11 things that have to get considered into that?
12 MR. YACKLE: In 1933, the 12 MR. YACKLE Yeah, good. The --
11 reconnendations by the engineerin3 tean vou've 13 the -- In '95, the avail -- what we had -- the -
14 seen was to do the replacenent activatles that was 14 the infornation had changed in shape conpared to 15 technically assessed by a revlev forun.
15
'93.
10 And the conclusion of that 16 ve now had the external repair 17 assessnent was to defer the replatenent, although 17 technique available to us. However there is -
18 the engineering -- period. The engineering tean.
18 there was alvavs the concept or the thought that 19 - however, knew that Inconet nozzles were cracking.
19 this had not been videly adopted in the industry.
29 MR. BROCKMAN Okay.
28 MR. BR0CKMAN: Okay, okay.
21 MR. YACKLE: They never let go of 21 MR. YACKLE: For exanple, if 22 the concept that ultinately in line we're going to 22 soneone had cene along and said. let's replace all 23 be needing to replace these noz21es. :t's the 23 the nozzles in '95 the engineering tean would 24 next line around.
24 have said no. That -- and the cor.aern there was.
E MR. BROCKMAN: This is '95 now?
25 although analytically the boric acid had been s
143 144 1
established. We vanted to see sone tine pass on 1
started into the development of what we tern the 2
one of these hot leg nozzles such that we could go 2
'In-house repatr technique' where what we vented 3
in and look at it to confirm the corrosion 3
to do was put together a repair nethodoloog that 4
analysis of that nozzle. We did not want to rush 4
ve could do it in-house rather than pay a lot of S
Into this.
5 noney to a vendor.
6 MR. PROCKMAN: In the inner 6
And that was ultimately developed 7
space --
7 by the end of '96, with that capability. But we 8
MR. YACKLE: In the inner space.
8 did not inplement it for the Cycle 9 outage.
9 correct.
9 MR. RAY: And I was there also.
18 MR. HERMANN: You're talking about 18 and I was the nanagenent referred to. at least in 11 the accelerated currosion testing was done by CE.
11 part here.
12 MR. VACKLE: Yes. So that was a 12 One of the things that nakes this 13 aspect of the decision along with the other 13 conversation so difficult for us is that so nuch 14 aspects that Mike has mentioned. Which is the lov 14 of what we were talking about had to do with 15 safety sicnificance. the ALARA. and the fact that 15 strictly plant reliability decisions. trade-of fs.
16 M couldn't predict what noz21es wer*v going to be 16 how nuch to invest in trying to naks "e that we 17 falling in the future.
17 veren't put into a forced outage ain m not et 18 You could only rank then by a la all related to whether or not there was a 13 relative susceptibility. So you take those 19 potential safety problen.
29 thoughts and make a decision in '95, are we goino 28 Nov. I nean. I just have to say 21 to go out and replace a set of nozzles in -- In 21 that and nove on. I realize this discussion is 22 that outage? The dectslon was no.
22 entirelv in terns of whether it was a safetu 23 At the end of that outage. Which 23 problen. But unfortunately, nuch of the language 20 van what Mike's talking about here, we re-thought 24 that we use in terns of whether to reconnend to do 25 it again. And we ~ and we -- that's when we 25 something or not reconnend to do sonething and Tannie L. Snith. CSR (8171 625-0 48
r_._ -___ - __
pHECC151C~AL INFORCEMENT COING SErfLMDER !] 1997 145 146 N
1 whether nanagement did (v did not think it was the 1
M. RAYI $o a still geens a
?
line to Pove aliend and do til is, in f att. 9 eared F
MR DROCKMN o
3 r*jt to what otr relative judgment van about either 3
little bit to me ** and I'n not sure a one cf the 4
compliance or Safety, but hai to do with er.ttrely 4
terns that consistentiv lt Med in that report is the question of reliability.
e pro active replEenent program.
4 And we can't altentangle that verv 6
M. RAY: Yes.
7 esilly 6ttting fere nov. It looks like we're 7
M. BROCKMNI And that never 8
141ng " you know, naking Up exhanations for 8
Stens to Det defined "
9 things that ought to te self evident on their 9
MR. RAY: Yeah.
If f a' s.
18 MR. BWNJte - as to what - If 11 Dut that's. In f act. What all of 11 there's any thoughts as to what was poing on and 12 thtt discussion had to do with. this report that 12 neant by that as to a pro-active "
13 Mika't t alking about. at I've 6ald already, was 13 MR. RAYS Okay.
14 precipitated entitelv by the notion that we sinply 14 MR. DROCKMNI " progran heat 15 have to nake sure that we don't flad ourselves 15 location, what'o r. I'd te host Interested.
16 into a forced outage condition if it's at all 16 MR. YACKLE: Yes. In that s eport 17 avoidable.
17 th6 tern ' pro-active replacement' can be 18 1s there any way t'pt we can in 19 Interpreted in two vaus. One.18 that we were at 19 the future evold petting into thlt situation 19 that ilne interested in the concept of PC ageln? And that *t what all of this discusslo) and PS pro-attively going af ter nortles. That was never il analVsts had to do with. No time altne the weg
?!
not a consideration.
N did we think we were Jittuting or creattag a 22 MR. BROCKMANt Ok ay.
r3 record that we would sit here and Olscuts in 23 MR. YACKLE: The other is that at P4 Safety or chrollance trace.
24 times vou'11 - Vou'll " wou'll read a tentence P5 MR. DROCKMAN A point that --
PS and be confused by the word ' pro active
- tecause w
147 149 1
1 ve were eroud t.f the vsy we were pe r 1ctively 1
What have Vou.
?
001h0 af tSr the nortles in terns of otr 2
So a to no there was never ang 3
a r,apec t ion.
3 Population or indicator that would lead us to be 4
ve were pro actively putting the 4
rocusing on a spectfic set C nozzles.
3 pl'A us in. We were pro nulvely looking real 5
MR. HERMANN: Was it thought that U
hard on doing the isotopic assesanent and to on.
6 ortelnallv vou vere trying to pick out --
And to that in time ~ that vcid got tus in front 7
MR. YACALE: Except - except for 8
of pro-actively doing our inspections. So it -
B pressurtrer is hot. We know that. That's our ~
9 the definition ~ the word is a misused word.
9 that's our hit,n susceptibility area. Hot leg 16 18 P9. DROCKMA'l Welt. Vou can also 10 next, cold leg la last.
l 11 9et it to the polnt where you think it's saving 11 MR. MERSCH0FFi The assessment 12 there'u something Systenic. vou know, some 12 that was done concluded that the reason the 13 criterla that they're uutng 100, which causes a 13 prt-active approach was abandoned was to ltatt the 14 tot of that.
14 outage duration and cost exposure, thus continue W
I was just wondering were there 1$
vith an inspect and replace strategy.
16 any Innlances like that as part of it where we've 16 18 that accurate? You Seen to be 17 got sona systente criteria that we're wantIng used 17 telling ne scrathing dif ferent.
18 to identify. which are those particular nozzles vs 18 MR. RAY No. No. I'll say It 's 19 vant to place our priorttles on?
19 acetrate.
PS MR. YACKLE: Good. We never got P6 MR. MERSCH0FFt So the envineers
?!
to that point, we were, prior to Cycle 9.
21 that decided to abandon the reconnendation for
- 2 considering establishing a populatton that we 22 pro-active, abandoned it based on the cost. Is P3 would go after. It was Just in the thinking 23 that -
24 phase, tot we never Oct to the point where we vent 24 MR. $1STOS I think it was the -
P5 fceward with that an't then identtfled no 21es and 25 MR. RAY: No, no. All l'n trVing fannie L. Snith. CSR (817) 0?S-4%e l
PREDEClllDEAL CNFORCLENT CARING * $EPfteER 30. 1997 1
149 158 3
to say is thev vere reflecting, perhaps. What thev 1
continue to r4 place ** Inspect and replus. did 2
heard fron N. Wr.lch was that the investment in 2
engineering anticipate that that Would result in 3
nortle feplacenent which Would extend the outage.
3 leakst 4
extend the cost extend the ra$lation exposure "
4 MR. $!$10$t well. I don't think in order to reduce the potential that we vpyld so. I think. based on the correspond " or the experience sons Irtiact on the outsee, this was a literature that se've read. the NCR's. the 1.ER's 3
7 huge nistak6 that I made.
7
- there Was no prewtictive nodel or an acetate 8
Not that I could have necessartiv 8
predictive model had been developed.
s f agured out Which ones to replace tut that the t
And even our ansessnent lean tack if f erlacement progran Was something that We vleved le in March and April of this year. We still 11 as no! 14100 justified or not having justified 11 confirmed that as f ar as we Ynny, that We didn't 12 liself for all the reasons that have teen 12 have a predictive rodel that could saw that 13 descrited here.
13 particular nozzle is going to leak before any 14 which noz21es are you poing to 14 other nottle.
15 replate? In it really polne to be sufficient to 15 MR. MERSCH0F8: Okay. Su as far it avoid a forced outage due to leakapet I wasn't 18 as the assessnent's concerned. vou didn't feel 17 persuaded of it that we Were properly applying the 17 there Was any sub group of nozzles.
10 resources that were evallable to ve in order to 18 MR. YACKLE: Th&t 's a that's ~
le svold What ttrned out to be. You know, a 19 MR. MERSCH0FFs = other than all D
eignificant inpact on ourselves.
20 the nor21es, that would be expected to lenkt 21 Nov. that Was Av WicW. And I 21 MR. $1STDS: t rac t ly.
22 would expect that to be under4tt,M by the folks 22 MR. MERSCHOFFI vhat about the 23 Who were interacting with he over What to do here.
RJ engineerst That's What the assessnent was for.
24 MR. MER$CHOFPs well, let no ask.
24 MR. 31STOS I think - Well. I 25 when engineering decided, then, to reconnend to 25 thlbk fon can saw something for the engineers.
151 152 1
MR. MERSCH0FFs But what did 1
predictive nadel they could never say, okay.
2 engineering think? navte Dwight's the one to ask 2
replace these ten first, and it Will buy vuu sone 3
about that. Did --
3 additional anount.
4 MR. NUNW: vell. actually both the 4
It was alvavs. It's better to plan 5
assessnent and the engineers Work for ne -
5 the outage. Which la sort of a trutsn a plan the MR. MERSCHOFFI Are the sane.
Work for the outage, be set up for it, and 00 in 7
HR. NUNNt " but I think, from av 7
and do it and be reactive.
8 perspective having to ask for the report. that the B
However. If Wou look at the - our 9
engineers were in '93 and '95, and certainly in 9
-- our f ailures up until 1997. We alvaus 10
'97, in the position of saving, yes, it's a good 18 Identified these at the beginning of the outage.
11 Ides to replace these act21es because they're 11 And 11 didn't hue any impact on the Uc.
of 12 poing to crack.
12 identifying, other than take out the ear..
13 ve can rank then in these broad 13 presswirer history for a ntnute.
14 categories. And We Will tell Wou which specific 14 MR. MERSCH0 fps The ~
15 ones to do in those categories, based probably on 15 MR. Ni l'n talking about once 16
-the location. In other Words, if they're on the 16 We instituted the inspection progran in '95. that 17 tetton of the Ipop replace then Otring terueling 17 Worked. That didn't extend the outage. '97 did 18 outages When they're drained and other Itnes.
10 because We learned sonething.
19 Dut there was no - never was it 19 MR. RAY: Yeah, but the inference 20 pushed to the point of a that is a there ~ thev 20 that you can drav fron all of that is that We Were 21 4091d h3 nit that there is no predictive nodel and la satisfied with leakage developing curing the 22 all they could do ves - le put it in these broa6 22 operation of the plant as long as We could fix 11 23 categories of where Wou should replace.
23 without extending the outage. That's the logical 24 And stven the nunber of noZ21em 24 conclusion We can draw fron that.
25 that Were subject to replacenent. Without a 25 That's onts true insofar as tie fa9nte L. $nith. C$R 8817) 625-4949
PREDECISICAL EWOHCEMENT HEARIN3. $EPTEMBER ID.1997 153 154 1
inpact on the outage is concerned, the potential 1
they would have reflected in ~ as %anapenent's 2
for impact on the optage is concerned. That is 2
view, because it was.
3 twt true with regard to anything that we could 3
But thle - vou now, that ~ that 4
have dA to precipoe the leakage from the 4
bests for the discussion and decision was driven standpoint of compliancel that is to saV.
5 from the standpoint of can 1 Justify doing this 6
predicting 11 and precluding 11 not only because 6
vork in terns of tte likelihood that it will evold 7
it night intact the outage if we didn't find it at 7
a leek occurring? And I never Could cone to the 9
the leginning of the outage, but we've been 8
conclusion thtt I could do that. So what 1 --
9 finding it et the teginning of the outape.
9 MR. MER$Cil0FF So what l'n 16 But in terns of can you replace 18 hearing is that engineering did hot conclude that 11 these nor21es here, this grow. and thereby 11 there was a category of nozzles by location or tiv 12 algnificantly reduce the likelihood of a leair 12 heat or by other f actor that would be expected to 13 occurring during the next operating cyclel we had 13 leak before the end of the operating cycle. In it no basis to do that.
14 that -
1$
And nv concern alvavs vas, all 15 MR. DROCKMMI Except for the 16 fIsht. vou want to go off and spend a nlllion 16 three great big nacroscopic pressurarer. then hot 17 bucks. and you want to have this nuth radiation 17 leg. then cold leg.
18 exposure, anc vou want to take up this noch time 18 MR. NUNNI No. They just ranked 19 in the outag to replace these nozzlest let's talk 19 then on susceptibility on that basis.
29 about what the basis is upon which we would do 28 MR. HERMANNI They were just 21 that.
21 ranking then on ~
22 And I never got persuMed to the 22 MR. RAYi Let these guys answer 23 point where ! vas at least villing to saw that 1 23 down there on -
24 felt we had a Justifiable rationale for doing 24 MR. MERSCH0FFs la that 25 that. And as f ar as l'n concerned, that's what 25 consistent ~
l iss 156 1
MR. YACKLE: that is consistent.
1 they're not very accrate.
2 Ves.
2 MR. RAY: But ! -. I ~ ! Just 3
MR. MERSCH0rPt And what about 3
haven't been persuaded by them. And. of course.
4 from the assessment. Mr. $4stos? !s that 4
our biggest focus of attention and the reason why 5
consistent with what you think?
5 1 think we know something about this phenonenology 6
MR. 5I5T0$# Yes. As Narold 6
is not only the experience we're discussing here 7
nentioned before. I think that was basically to 7
today, but we've teen very nuch engaged in this 8
ntninire this exposure of having to find these 8
question of CEDM head failure.
9 leaks late in the outage. And, obylousiv. so it 9
We are connitted to do an 10 was ~ our intent was to t.e able to assess if we 18 inspection coning up. But we have aponlred over 11 can prevent that at all costs or -- not at all 11 that long and hard. I shouldn't take line on ' hat 12 Losta - but a reasonable ~ If it were a 12 nov.
13 reasonable basis to be able to predle'.Mch 13 But at the end of the day. I,ou 14 nozzles could be ~ could te replaced.
14 know. I was as frustrated over the fallwe of our 15 And we could not cone up with 15 prograns that Mike has described to vou in prior 16 anything, including our assessnent. We basically 16 years as anybody here in that I didn't want to 17 vent back and reviewed work that had teen done 17 have to cord.nue to rely on that.
18 before by the previous engineering teens and 18 So I really put a lot of presswe 19 concluded that the predictive podele are not vet it on these gWs to cone up with some conclusion.
29 available. And, therefore, we cannot reconnend a PS sone insight. sone discoverv. Sone basis upon 21 predictive or a selectal number of nozzles to be 21 which we could avoid this Is in the future, which 22 replaced.
22 is in the report that I think Mike needs to finish k,
23 MH. HOWELL: predictive nodels are 23 talking about if he hasn't already.
24 floating out' there, right?
24 MR. MERSCH0FFs One more 25 MR. SI$f0$6 Yeah, they are. But 25 questich So if I look at your report, i
fannte L. Snitn. CSR 18174 C25-4M8
PRENCISIONAL CNPDHLEMENT CAR!n + $EPTEMUEA U.1997 157
!!.0 1
Mr. $1stos, you have a chart of opttons with pro's CE owners group progran as a starting point.
2 and can's. And the con's listed ftr continuing 2
There were a bunch of flav 3
visual inspection is, nap have adverse regulatory 3
evaluations in that wort. Incre were a bmch of 4
consegances.
4 rankings in that work, there were a tunch of 5
MR. $1STO$1 Yeah. We a things on susceptibility Inden in that wk - all 8
MR. MENSCHOFFt what does that 6
the things you basically say1 hat you really don't 7
neant 7
think are good predictive tools, okset 8
M. $13f05: Yeah. Well, 8
You sav 900 can't pick the heat.
9 t,asically, our tean recognited that the NE has 8
but yet that's the base issue a pot you where you 14 alvaus the prerogative of revleving licensees' 18 are for the inspections =
il decisions at any time. And we understood that.
11 MR. NUNN 0% 1 thirA vou -
12 Dut we believe, based on the 12 MR. HERMANN ~ in terns of the 11 Information that we had seen - in f act, even the 13 crack growth and in terns of the rest of it.
14 NE letters and reports on this topic ~ that 14 MR. RAYI valt, velt. I don't 1$
this was a verv ~ had very low regulatory t$
understad the basis for 'he 1%pections. vs 16 significance. It had a very lov safety 16 inspect then all.
17 significance.
17 MR. HERMANN
- 11. What l'n IB But we identitled all potential 18 saving, the idea of visual inspations as belho an 19 aspects, you know. for our decision-naking 19 acceptable way to look at these notries okavt 28 process. So that was basically what - what in 28 And 'het whole owners group had a whole thing on
- 1 neant by a by that statenant.
21 Justification based on crack growth ~
P2 MR. HER'tANN The only confusion 22 MR. RAYS Yeah, right.
P3
- ! puess I still have a little confusion nov 23 MR. HERMANNI *- leakage and til 74 14cause the basis of the visual Inspection progran P4 the rest -
25 to stat with for these nozzles started from the P5 MR. RAY: Correct. Uh-huh, 159 169 1
MR. HERMANN " of the stuf f.
1 are at a point of nutual understanding. I von't
?
MR. RAY: tm-huh.
2 use the word 'agreenent
- pr 'appr;vst' or ang 3
MR. HERMANX4 Dut it seems like 3
other thing about how to manage this problen or 4
there is certainly sono question as ~ at least 4
this phenonenon.
E the predictive parts of that prc3ran ~ of you 5
Although the thing is not finally 6
thinking they're valid.
G put to ted. I believe it's clsarly teen agreed 7
You know. Whether we agree or 7
upon. And, again. I - I'n not telling you things 6
don't agree, is not inportant. And 1 night even 8
that tonehow regurgitated fron the past.
9 agree with you, to tell VA.he truth. But on the 9
But I've sat in meetings at which 18 other hand, it seems like kind of a alred bag.
18 ve concluded that the visual inspection that 11 You know, puu're trying to get out of the thing 11 vou're referring to is, in fact, the proser.
IP because of vorrying about forced outages. but yet 12 adequate, and cor@! lent means for dealink with 13 vou can't flouro out how to do it because you 13 primary Water stress corrosion cracking on Incuiel 14 don't like the predictive tools. Dat that's the 14 nozzles no natter whether they're this big or this 15 basis of your inspection programs.
1!
ble landicatinal.
16 MR. RAYa
!~
16 MR. HERMANN: And --
17 M. Hk W Ns It's sort of a 17 MR. RAYI And that's what we're la MR. RAYa It's ~ lt's the last 18 doing. Nov. We are going to go and do NDE on our 19 part there about it being the basis. I think 11 19 hen:!s for the CEDM nozzles coning up. And the 23
- 15. In f act. the inability of the predictive tools 29 reasons for doing that, you krov, again, we've had 21 to te reelled won that is the basle of our 21 a long discussion about. Dasically, the 22 inspection program, not the contrary, 22 Connission has said, we really think it's 23 Dut with that nuance, with that 23 Important for you to do this. So we've said.
?4 dif ference in v;tv. I ~ 1 puess I do believe that 24 okay. We'll go do it. And we are.
P$
the lodust7 and the NT as I will explain next.
25 And I'm saVing to you that if f arnie L. Snith. CSR 18171625 4Me
PRE!CEI$10NAL ENF0FQKNT HEARING $[PTEMBER G 1937 181 1CP 1
Iberi are things atout what we're doing with these i
looked at all nozzlest f
norfles that you don't approve of and 900 think we f
M. SHORis All nort!69, 3
M. WHITTEMt Every linet 3
ought to 60 differently. ef ter we once have a 4
M. CM 4 Yes.
4 discussion atout it and understand it. ve'll go 5
M. YEKLt Yes.
5 of f and do 1 hat. too.
6 MR. YE KLE: What ! -
S M. FIELD $s Although, only in the 7
MR. WHlifl M s What's the scope 7
last outspe did they renovo the restratet.
8 M. YEKLtl Yes.
B of your inspection progran nov covered to tW3?
9 M. $HORTI
'93. on the Insulation 9
Mas that evolvedt it vindows have t+en in service. The restraints, the if MR. $HORin The scope has not 11 clav8 le 14111 3. 1997, oniv.
11 chanced.
ftR. WHIfffMORE: Okay.
If MR. WHIffEM: It was alvavs 13 MR. NUNils Dut that was in only 13 tu Jit 14 VerV few cases where that clanp was a 14 M. $HORis It was alvaVs 15 M. $HORTl The clav is only used 1$
complete.
16 in a handful of nozzles. It's not in videspread is MR. WHIffE M I Dkav.
17 MR. $HORTI The difference is the II US8' 18 1 was asked earlier to talk atout 10 nunter of inspections. But, otherwise, the 19 our plans fron this point forward. The next two it scope's the same.
PS elides deal with that. And these vould wrap up ny 28 MR. WH! Tit m s Oh.
21 part of this presentation.
F1 MR. YEKLE And the nunter of PP M. MER$CHOFF# Let the record R2 people involved in the inspection.
P3 Show there was a sigh of relief.
F3 M. $P')RT: Nunter of people 24 involved has increased as well. Overall..
P4 M. RAY 1 told you il vould te PS 10hg 1*cause this is the nost inportant part.1 P5 MR. WHIffE M : You've 41vavs 163 164 1
- think, 1
contingency for the hot leg.
2 MR. LHORis I have given 2
And then, as Harold mentioned, for 3
presentations nuch longer than this before, so 3
the hea1 nozzles associated with the control rods I
4 this is fine.
4 and the in core instrumentation. We have Unit 3 l
5 The first point to make it. With scheduled, based on 11.4 CE owners group ef fort.
6 respect to the hot Isos we are planning to 6
for Cycle 10. That would te a volunetric 7
conduct repairs dwing the nid cycles for both 7
exanination -- renote tooling. eddy current type j
8 Units and in the refueling.
O of exanination.
9 The precise distribution of those 9
And we're considering actually le repairs is undergoing review right now because le doing Unit 2. as well. Both units would be 11 vo're assessing the implications of repair on the 11 scheduled during the CVcle 10 outage.
12 outage of safety, 12 We 'ntend to have this resolved 13 Dwing a and-cycle and ald loop.
13 and docketed by the and of Octoter a? We've 14 wh. h is vnat you're required to do to Dain access 14 previously connitted. 50 that will give you a bit 15 to the hot les notries. that represents sone risk 15 of a visuallration as to where we plan to go in 14 of outage-related risk. And we're balancing that 18 the future.
17 with the tenefits of vasting until the refueling.
17 l've inc!Uded for your tenefit on 18 So those a the precise 18 page 45 a short discussion of the nochanical 19 distribution of repairs renatne under review. We 19 nottle Seal assenb!v. It 's here for your benefit j
R8 do hope to te able to use -- depending on 26 and interest. It wasn't a critical part of the i
21 agreenent by the staf f -- the nechanical seal 21 present ation.
l 22 ass.inbly for the pressurarer water space.
22 So if there's io further P3 And in the event that we can't 23 questions, the next part of the presentation vould i
P4 gain access to a nozzle because we can't uncover 24 be Harold.
PS lt for purposes of repair, it would te a PS MR. MER$CHOFF And I would j
l f annte L. Sntth, cSR (8171 625-4948
._ ~.
PRIDECll10kAL ENFoHCMNT HE"1NE SEPTEMBLA U.1997 I
tc5 It4 1
geopose a ten minute break to ps off the record i
13 look dif ferent than nine?
j and reconvene.i 4.s.
ut ou on. rean, ori e
M. uY, i w i m v i.cause 3
nine is atsolVtti, date-starsied ts a certified 3
4 MR. kays well. I have e pla's at 4
at*0lutel, correct tory stoned off by the NRC and
$ipe o' clock, which ways to ne I f eet to 90 ant' 5
to on, so I telieve I've got the copy I should 6
get a dif forent pit.ne, t.o dwing the tonk 1%
8 have.
7 90 do that.
7 in an, case. In this ~ Under the 8
M. ItR9CHOFFI Okay. vh, don't 0
heading 'llcensee evoluttlon of Generic 9
ve 90 off the recerd nov, and we'll try to 9
CorWJnicallons.' there's a discussion, and il le reconvene at 4195.
18 discusses other aspects of our response to this, il 19reak in proceeditios fron 11 But ny point is that l'n a rs're it 3M p.h. Until 4:10 p.n.1 12 not presenting nuch of this information here for 13 M. RAY: l'n Harold Ray 13 the first time. And to l'n Mindful of that, and I 14 aostn. Southern Californie Edison. Executive 14 dan't want to belabor it.
15 Vite President.
Il But there is a stata..ht here with 14 Let ne t*0ln with what I hope 16 which I have to 16ke exception. 11 appears in it*
17 isn't too much of a digression, but I do have note 17 niddle of the first paragraph. It says the le
- I nais connent tefore ~ but I want to 10 majorit, of the evaluations ~ referring to the 19 tasderscore a point here.
19 evaluations that we have provlued earlier ~
P8 In the Inspectlen Report on page P0 pertain to degradation issues related to reactor y
vessel components: therefore, the inspector el
- 13. In talking about generic connmtratione, which 4
72 l'n atout to do, there's a discussion of our prior y
't Matricted review of the evaluations of 23 connunicellons abDut that. And it looks like is brornation Notice 9010 in the combuellon F4 this ~
29 et<0lneering technical bulletin BS*.8 pressurtter F5 MR. MER$CH0rFs why does your page 25 eit*er sleeve leakaos.
167 108 1
1 just want to saw that I do 1
significance of the crack ralstive to reactor 2
telleve, as we'll show here, that we should not coolant systen integrity. I believe, are all 3
exclude the conslGeration that has been given to 3
connon. Yes.
4 reactor vessel head penetrations o' ~ nade of 4
MR. HERMNN I'd agree with you 5
Allow f.00 the primary water stress corrosion 5
to the point of sone of the propagation nachanten 8
cracking. the cause, the progression the safety 6
to l'n not very sT e.
I think there's enough 7
significance ~ til of those things are the same 7
dif ferences in design fron like, the inside of 8
and are of ten referred to jointly.
8 the sleeves end. like, things like happened at 9
Nov. I think My next slide here is 9
Buges where you could potentiall, end up with circ 18 one on the computer here. Is that slide 477 le cracks.
Il MR. SHOR74 Yes.
11 But there is 4 difference between 12 MR. HERMNW Go over that one it the instronent nozzles and - and the sleeves.
13 nore line. You're basically equating the 13 MR. RAYS Yes. I agree with you.
14 Instrument nortles to the head penetrettons?
14 as well.
15 MR. RAY: l'n not, other than the 15 MR HERMANN Fron a safet, 16 vag I described it. Which te that the ~ the 16 perspective, sure.
17 prinary veter stress corrosion crarking 17 MR. SCH00NOVER: ve - We don't 18 netellT9ical pnenonenoni that 1s to say, reitdual 18 have any sleeves at $an Onofre ~ no a no thernal 19. stresses in the presence of, the reactor coolant it sleeves.
O systen at tenperature. develop cracks in the areas PB MR. HERMANN: vell, but l'n saying 21 that are ~ as Mike explained then ~ very sintlar 21 that ~
P2 in terns of what precipitates this crett.
22 MR. RAYi No, no. I understi.ad f3 The propapallon of the track as a 23 his point. and I agree ulth it. I just. On the 24 longitudinal crack which then enters a region of 24 other hand. do not believe that we should 25 lover stress levels in arrested and the 25 disregard entirely the ~ the large amount of Tannte L. Snith. CSR t017) G7 4948
. ~. - -,
PIEDKISIONAL ENFDEDENT HICM + LEPTEMut:A O. 1997 109
!?8 I
infernation that trists on this.
1 betteve the NE and the industry have concluded e
In f act. I have to tell you. as 2
that pt: nary veter stress corros on cracking has 3
1've sito t4 fore, I cone to this decision proress 3
nov safe's significance for <ecisolv the reasons 4
that !*ve been ensaped in here over the wears with 4
that we've said and that inspect and repair to an 5
e lot of bwgage that is associated with all of 5
acceptable - not the only acces table ~ but an 8
that industry and NE vork that I telleve is 6
acceptable response to this prpllen.
7 artil:able.
7 We telleve that what we were doing a
well. In the fegulatory e
9ere tounded by the NT assesstents a and by the e
environment we telleve now, narrowing back down to 9
vev. vo're not presenting here todav due to the to Nx7638, that primary water stress corrosion 16 - tength of this discussion ever though we're il cracking was proceelv identified and corrected by 11 invited to oc so by the letter announcing this 12 replectne the norrless that is to sav, that 12 Predecisional conference to talk about safety 13 le Cnl 58. Appendia B. Critetton ry! response was 13 significance.
14 to replace with Allov Gor to prevsnt recurrence 14 the safets significance that we 15 and suonented inspections were perforned in 15 would provide in response it, a proposed escalated 18 accordance with the generic letter and thformation 16 enforcement would basically say that the nost "
17 notice.
17 the only significant safett inpact of not 18 We believe that we could not have 1B replacing the norries is tae pocket or the safety 19 predicted, as we've said tefore, norries which 19 consequences associated with taking a forced 28 would develop this crack based on the hest alone.
28 outage, not the fellwe Of the ner21e.
21 And therefore. short of replacing all of the 21 That is to say, any tine that you 22 notries, could not have taken action to prevent 22 experience a forced outase, you go down to nid 23 the f ailures that we're talking about.
23 loop. vou open up the reactor coolant systen, you 24 Nov. I'll get into the area with 24 work on these things. 90u put it all back 25 sono trepidation in here of controversy. We l
25 together, and you cont back to power.
t 171 172 1
As we til know, that increases the 1
(f at back in 19%. the staf f identtfled this as a 2
level of core damage frequency having to do that.
2
- as an energin3 issue, the prinary water stress 3
And tV avoiding doing that, one has sono tenefit 3
corrosion cracking of Allov 600 in components 4
to safety certainly. But that is the safety 4
other than stean generator telne.
5 inpact, not the potential f alltre of these 5
tbntinuing, the staff deternined 6
norries.
6 that the safety tignificance of the cracking was 7
Okay. Nov. I'n poing to give. !
7 109 tecause the c*acks were axial, had a 109 8
think, six exanples here. As I said tefore, et O
provth rate, were in a natorial with extrenelv 9
the end i vill refer you to what we've provided to 9
high flav tolerance.
le you a long series of dialogue tetween the industry 18 Thise f actors also denonstrate 11 and the NT having to do with this phenonenon.
11 that any Cracking 40uld result in a detectable 12 put let no tegth with a f airly 12 leak before a penetration broke.
13 recent NRC petition denial. January 1735, that is 13 Now, again, this doesn't nean that 14 quite a bit on point. We believe. This was in 14 there's not a violation here that we're talking 15 January of '95 the Director. Office of Nuclear 15 about. But it is relevant in natar.at to the 16 Reactor Regulation denied a petition filed on 16 question of safety a gnificance, which, as I said 17 tehalf of Greenpeace International to shut down 17 before, is crucial it the -- to the apparent 18 plants based on this phenonenon.
18 violation anuvay, the way it's stated.
19 Nov. as I said tefore, telleve ne.
19 And going on and talking about 28 there is an enornous body of debate and discussion
?$
this inspection. It says this would result in 21 over this very subject. Dut here in ~ at this 21 deposition of boric acid crystals on the vessel 22 point in tine a tunnary was given that extends 22 head - talking about t he vessel In this case a i
PJ over this and the following two papes.
23 or surrounding area that would te detected dtring 24 l'n not going to read it all. But 24 surveillance walkdowns.
25 the dental basically states that - it recites 25 Consequent!U. the concerns ratted
! annie L. Smith. CSR 4817) 625-4Me
PRLDECISIOKAL DIFDELEW1 C:3ING SEP1EMER C 1997 173 174 1
by the Petitioner do het raise any Innediate 1
altogether. the only point l'n trying to nake is f
safety corcerns. And I can't underscore erosph 2
- la this - ls - is there reason to telleve 3
the fact that l'n not standing here savire to you 3
that the NE views this as sonething other than a 4
that. therefore, it is fine and okay that cracklr4 4
significant condition Mverse to suelliv? And why occw and that you don't need to try and prevent 5
do they do thatt 11.
l'n Just trylhe to explain that 7
vhat l'n trying to sov 18 that tre 7
her e.
8 level of concern that we should assottate with the 8
M. E RSCHOFF The thesis at the 9
tie &d to absolutely, positively preclude any 9
beginning of these erenples is that the Industry 15 crkk!ng fron occtering has been steject to if and the NE have conclD3ed that inspect ahd repair 11 Uldespread discussion and flhdings. I believe.
11 is an acceptable response. And to do 900 12 that are televant fron the NFIC.
12 Interpret that to nean that running the reatter 13 M. HovELLs the only thing 1 13 coolant systen to failure is an appropriate 14 would point out there. Mr. Ray. le that the 14 responset 15 results of acknowledgment in that Director's 1$
M. RAYS No.
18 decision that a number of Ihe eracka 9001d not 16 S. ERSCHOFFs How **
17 involve (f4 reactor pressure boundary, 17 M. RAYS How do you recot*lle 10 MR. RAY: Yes, of course, because 18 those two *-
19 they occurred Ulthin or lower down.
19 M. ER$tFW s Yes.
?$
M. HOWELLs in the contert of P8 M. RAYS 1 puess it would require 21 ansvering to the Petitioner's corgern, so 900 have 21 some discussion about what one neans or intends by PF to look at all of that. That's av o*19 point.
22
- running to f ailure.' what does f allwe F3 M. RAYt ! " 1 ~ 1 underst and.
73 representt P4 and 1 accept your point. 1 vould nake the same P4 I would say that trere in P5 point back to 900. which is that 1 believe. taken P5 unambiguously the posillot, established here that 175 176 1
the anall leakaos associated with this phenonenon 1
Judenent that we could accept that violation and 2
does not represent failure of the reactor coolant i
still deny the apparent vloistion here.
3 evuten.
3 And those two thlres are not 4
Nov. I nean, I can only tell you 4
inconsist ent. DVt that has to do sonevhat with 5
vhat - what I and nany other people conclude fron 5
the Way this violation is franed. As I try to 6
reading these voth I happen to believe then.
6 understand what your real concerns are, however a 7
100. But I don't believe that falture can be 7
and I en trying to do that a l'n not 80 sure.
O epiled here without being given sona definition.
8 And, again. tills. I haven't 9
And this - this pertains ~ ve 9
applied the test that I've had to apply to this le didn't cone here today Io talt about the 18 taause we had the neetIng scheduled and 1 hen 11 - nalntenance rule aspect of this thing, lie vill 11 re-scheduled for today, which is, do I know how to 12 address that. Dut that wasn't the purpose of the 12 prevent a recurrence of this violation?
13 Enforcenent Conference, and so l'n not here to 13 1 vill apply that sane thing to 14 talk about whether this leakage represents a 14 the response to the nalntenance rule violation.
15 f ailure towards the natntenance ruling.
15
- 1. of course. read it tecause It's buried in this 16 M. ERSCHOF7 Il vould help to 16 sane Inspection Report. But I haven't forned an 17 know if you intend to deny that violation or if 17 opinion about it. But I do see the connection 18 900 recognare that that's an appropriate 18 very strongly.
13 application of the maritenance rule.
19 vell, nu - again. I don't want 29 ff you haven't vet artIved at that P8 900 to ntsthierpret what l'n saying here to be 21 dactsion. obviousiv, vou can't. But it bears on 21 nore than what l'n saving. 1 Just want to be sure
??
What we're discussing today.
22 that you're familiar with the ~ at least forn the 23 M. RAY: It very nuch tears on 23 background for av belief, and others of us. that P4 - what ue're discussing today on this point P4 this did not represent a significant condition 25 speelfically. I would saw to you that it's eu 25 adverse to quality for the reasons that are given tannie L. Smith. CSR 18171 625-4948
PREDECISIOkAL LNP0liCETWT CARING = $Erf!)mER 30, 1937 p
177 179 1
in the Inspection Report for 1114tng a 1
81R. RAY: I'n truths to be very 2
significabt condition nWerse to quality.
2 upfront with you and saw that I think they thould 3
And that is for the reason that 3
be blended together. And the guy who signed the 4
recurring through wall leakage in the reactor 4
letter worked very extensively with us in 5
coolant systen pressure toA1arv fully neets the 5
revleving this thing.
reasonable interpretation of signiricant condition 6
$6. I nean. I ~ I'n trying verv.
7 61 verse to outlity.
7 very hard to hake sure that we understand all 9
1 don't see how one con feed this 9
eldes of this. And I'n saving to you. Wes.
9 Director's decision and - and recsiclle that with 9
Indeed. I am taking a response that was based on 18
~ vith the statenent that ! Just read.
If reactor vessel head penetration cracking.
11 MR. HERM/m i ! wrote that 11 And I'n trying to tell you how I 12 Dif ector's deelston. And nautse sone of this in 12 see 11 as app!lcable to this. Now, this isn't 13 setting a little out of contert tecause sone of 13 just in retrospect tecause having been involved 14 the things that are early in front of that were 14 in that very debate over the line of Interest. It 15 background on tv>v the problen was identified.
15 was av judonent that - that what I'n looking at 1$
That thing that's up there right 16 here is, in fact, applicable to the Instrument 17 now looks like the confusion ~ If I recall the 17 penetrotion nozzles.
le 2.206, was probably related to CRDM's not in the 18 In other words, the question. IS 19 troad contert of prinary water cracking.
19 11 okay to anticipate that sonevh9re there's 90lns 23
! think we put some stuff in front to to be a leak, but it's okav because the leak is a 21 of the thing on the prinary water cracking, the 21 result of Pv$CCl It's limited; and we can detect 22 fact that that got identified to the Comission 22 it by inspection ~ is that conclusion. which is 23 as an energing issue. Dut this is sort of 23 explicitly stated here, and I'n stre you nust 24 blending together in the voy this is coming out 24 still agree with ~ applicable to these instrument 25 here.
25 nozzles? Absolutelv I think it is.
179
!!40 1
MR. HERMANW: But navbe sonevhat i
the same thing here.
2 from the safety perspective. vou know, we're 2
I just don't think it's right for 3
setting on to ~ If we get to the 97 91 space.
3 us to be in this discucslon out of the -- What for 4
which is the CRDM resolution, okay. I'n to inspect 4
he is out of the clear blue 6ky ~ in an 5
a sample of CRDM's?
5 enforcenent reeting. Okay. So that's the 6
MR. RAY Yes.
6 Director's decision.
7 MR. HERMANN: The thing that's 7
Going on here recentiv to SECY 8
behind all the owners group positions are the 8
87 063 ~ perhaps you wrote that, as well.
9 predictive nodels that you don't like for picking 9
MR. HERMANNI I didn't vrlie that.
18 out whether or not You ought to remove the heated 16 f6t. RAY: Okay. I don't nean to 11 naterla!. That's the basis of why things are 11 preach to the people who arous that ~ wrote 12 okavl it's the basis of the economic decielon 12 that. The point is that this is entitled.
13
- r. ode ls,
13
- Generic Letters Degradation of Control Rod 14 MR. RAY: vell. I mean, each of us 14 Drive.' Again. I've hade ny speech there. I 15 trings with us cur own perceptions. I would saw 15 von't make it again.
16 to vou that the self-!!niting charrter of these 18 I do, in fact, apply nuth of the 17 defects is the basis for the inspection.
17 philosophy and principles to what, to ne. Is 1B
! riean, each of us can have ott 18 clearly a lesser safety slentficance in the 18 own colnlons about that. The point is that the 19 reactor instrunent nozzles.
29 stif f told us. In nestings that I attended that 28 The WRC staff reviewed the safety 21 this was not poing to te acceptable as a long tern 21 significance of cracking that occurred as well as 22 fix. The industry Sald. okav.
22 the repair and replacement activilles at the 23 And I specifically - af ter a lot 23 affected factlltles and deternineo that cracking 24 of badgering fron av colleagVes - Said, okPV. US 24 was not of innedlate safett, significance because 25 vill do it at San Onofre. And I'n villing to do 25 the cracks were axial, had a low growth rate ~
c fannte L. Sattn. CSR 18171 625-
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PREDhCIS13AL EWORCEENT HLARIWS
- SfPTEMBER 38, 1997 181 182 1
this is the inportant stuff --
1 dDogone heads becarJse you only insp0Cl a sample 2
MR. DOWELL And --
2 around the edge.
3 MR. RAY: - and were in a 3
So I think that that's kind of a 4
natorial with a high flag tolerance.
4
~ ! don't know what I want to call it. It's a 5
MR. 60VELL: And detection is also 5
statenent that I would hesitate to nake. but it's.
import ant. And 1 think we have to point out that 6
nevertheless, been ne$el and that, in fact. Is the 7 - vot progran ~
7 NRC's position here. And l'n now in sort of a 9
MR. RAY: The detection occurs, B
generic space. J'n no longer talking about 9
Art.
9 inf7838, but it applies to that.
18 MR. HOWELLs Yes. But pour 18 okav. Example 3. this is 97-01 11 program Ans nissed leaks. 60. I nean. 900 have to 11 that we Just nade mention of. I view this as 12 take that into account.
12 saving, well. navbe we need to be sure that there 43 MR. RAYS 11011. If I'n here 13 lan't circunferentist tracking that could lead to 14 because our progran has missed leaks and that's 14 ths ejection of one of these things.
15 the basis of the enforcenanti vou know. I'll te 15 1 think that's the sans reason why 16 glad to try and fespond to that.
18 the staff has presswod the industry to conduct an 17 MR. HOWELLI No, no. no. But l'n 17 NDE on the head, as well. But, again. We hear the 18 talking about in the context of thlt statement le sane reasoning given. which I strongly support.
It her e.
1 nean, it acknowledges that the leake vill 19 and the notion that cracking would result in 26 te detected visually.
29 detectable leakage and the opportunity to take 21 MR. RAY: Well. let ne say -
21 corrective action before a penetration would 22 MR. HOWELLI And that doesn't 22 fall.
23 happen in every case. That's nv point.
23 Why do I keep pointing to thall 24 MR. RAY That's right. Md il 24 not because it justifies everything we've done.
25 especially doesn't happen in every case on thet.e 25 l'n trying to focus on the rationale which savs. I 183 104 1
belluve tfe rationale which would say, this is 1
MR. HOWELL: No. But you're 2
unaccepted, this violates the tech spect.
2 bringing this up. So l'n pointing out the context 3
No. I don't Ibink 11 does. At 3
in which the ~
Q least it's not nu opinion that it does. And -
4 MR. RAY: I'll stipulate to that.
5 and I think we're entitled to look to guidance 5
MR. HOUELL: Okay.
fron the Connission and connents like l'n 6
MR. RAYS I happen to telleve that 7
referring to nov.
7 the inspectton program of the nor21es --
9 And I realite these are taken out 9
Instrunent no221es = is a whole lot nore 9
of context. I hope they're not. When placed into 9
effective than the inspection progran that they're le context lead to any different conclusions but.
16 referring to in the CEDM's.
11 necessartiv. I'm not able to bring document after 11 MR. HOWELL: And that nav be the 12 document in here. I've tried to identify then 12 case.
13 all.
13 MR. MER$CHOFPs Is one of the 14 MR. HOWELL: The only point I want 14 thenes that you're drawing along with these 15 to nake Is. It is all predicated on an effective 15 exanples that no innediate safety significance 16 inspection progran ~ all of that 18.
16 equates to not a significant condition adverse to 17 MR. RAY: That's fine. And.
17 quellty?
18 ageln. If our ~ if the problen that we're 18 MR. MY: Yes.
19 discussing here as a natter of compilance is that 19 MR. MERSCHCF7: I would ergue that EJ our inspection progran is ineffective. I would be 26 they're not equivalent. A signtficant condition 21 pleased to discuss that.
21 adverse to quality is substantially lover in its 22 I nean. I'll -- 1*d have to cone 22 nagnitude or threshold than an innedtate safety 23 back another time. But if that's the problen.
23 concern.
24 ve'll talk about inspection. That wasn't the 24 MR. RAY I understand that that 25 issue that has been raised with us.
25 difference exists. Thank you for pointing it i
Tannte L. Snith. CSR (817) 625-4948
Pl@EC151CM. ENF0EEMENT HEARINE - SEPTIMER 38. 1997 185 186 1
out. I was going to point it out,100. Ekst I do I
through-wall crxting in a rextor coolant systen 2
nake that connectlE 2
in all of these cases. So, you know. I think 3
I think that licensees have to 3
pou've got to sev. Well. this cracking is 4
look to whatever sources of information thev 4
different than that cratking soneiov. And I beg 5
have. If. In fEt, the Connission is trytne to
~ veah. I think it is. It's nore safety 8
seg. all of this is true and okay, and we stand 6
significant by at*least an ordinate nagnitude.
7 tehlnd ill ah-hah there's dif ferent words over
?
I said I only had six examples.
B here in Jiterlon XVI.
8 Maybe these are getting too tedious to l'!! veed 9
Notite they are, as you say, not 9
nut. I don't mean to beat a dead horse. This 18 innediate safety concern, but significant 10 letter stecifically we Resented previousiv 11 conditions adverse to quelltv. And I don't mean 11 referred to, but not included for the reason !
12 to try and be cute here.
12 cited on page 13 because 11 deals with CRDM'st 13 The point 18. though. I ththk the 13 and, therefore, wasn't considered.
14 fair reading of all of this information Would be 14 But, again, it repeats this same 15 that the cordition that we were dealing with in 15 notion that a failure to penetrattun is unlikelv.
16 these infrunent nonles was not a significant 16 The flev vould leak. And the fact that it leaks 17 condition adverse to qualliv.
17 nakes it detectable. And that's an acceptable way 18 And. Ellis. I only say that the 18 for dealing with it.
19 rationale elven for this being a slenificant 19 l'n going back fWther in line now PS condit ton adverse to quality is given in the 25 t o 90 18. I Won't even bother to read that. It's 21 Inspection Report, itself. Which is recurring 21 there for ve%
22 through-vall cracking fully meets the reasonable 22 MR. HOWELLs I Was just going to 23 Interpretellon of a significant condition adverse 23 point out on that one that that sane information 24 to qualtty.
24 notice also points out this is an energing issue.
25 vell, we're talking about 25 and there's not nuch known about this phenonenon.
187 188 1
MR. RAY: That's right. And, like 1
ve would all of a sudden, in nw judanent, face a 2
I said before, l'n happy to change what we do as 2
circunstance in which we find ourselves.
3 long as we discuss it and everybody sava ve need 3
MR. MERSCH0 fps The top of this 4
to change because we've decided this tan't good 4
tinellne is WRC7 5
enough, and it appites to the whole industry.
5 MR. RAY: Red, I believe is ~
6 Okay. And finally. May 12th of 6
Greg, why don't you explain it.
7
'93. again, the same story ~ 109 safety 7
MR. GIBSON: Yeah. The red are 9
significance. Low safety significance, veo.
8 things which are assocle'.ed with the NRC that are 9
having the Word 'significant
- 1s in that one.
9 either issued or published or they were itens le Okay. Now we'll vrap up here if Which the NRC participated in, like. NRC 11 because we ~ We still have a couple of steps in 11 inspections.
12 the aoenda to take. I've re'erenced the linellne 12 The blue's are Just the CE 13 that we've given vou. I've put it over here on 13 Informat ion. Down at the botton is the actual --
14 the Well, not for any ressor. Other than to, you 14 I believe they're the Inconel -
15 know. Just be able to point at tonething.
15 MR. SCH00NOVER: Blue's are 16 It has a algtwo of Industry and 16 thdustry.
17 NRC documents. We did not orepare this just to 17 MR. GIBSON: - Industry.
18 cone in here to this Enforcement Conference, this 18 MR. $CHOONOVER: Blue's are 19 history is very veti established of long 19 Industry.
20 standing. It's been a sjbject of a lot of debatel 20 MR. GIDSON: Right. Blue's.i.
21 and, therefore, we just simply reach bxk and grab 21 Industry on the top.
22 onto it and point that out.
22 MR. RAY: It's for your reference.
I 23 And it's hard for ne to 23 but I thought it would be incomplete if we didn't
\\f 24 understand. given the volune, the magnitude of 24 present it.
l 25 discussion that has occurred on this subject that 25 MR. RAY: It's such a long l
l
~
fannie L. Snith. CSR 18171 G25-4 %8 L
m.
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PREDECI$10NAL ENNICDENT HEARING
- SEPTDEER 38. 1997 189 198 1
history. I was just flateergested when it became 1
la one.
2 en issue of enforcement.
2 It's the second sentence that 3
- m. GIBSON: Ytah. This la to 3
talks about significant conditions acverse to 4
respond to the iten in the Inspection Report.
4 quellty and the need to nake sure that you 5
page 18. second bullet which. 900 know. We hadn't 5
preclude repetiticri, and that's what I'n focusing provided a con, ehensive listing of what exactiv 6
on.
v 7
the dialogue had been on this.
7 MR. HERMANW1 One of the things 8
And to sono degree 11 referred 8
that's in here I trJess I do have to nake total l
9 back to the July 22nd letter, which ! vrote and 9
exception to ~ the fitst Iten that's in here is te 18 it was trying to connunicate in th&t letter that 18 1994 NHC $ER nine alle point. It's furnace 11 11 asspeared the NRC had agreed thle was of lov 11 sensitized Inco a fWnace sensitired stainless 12 Safety significance.
12 Steel safe in the DVR environnent. And what 13 And the industry, through these 13 that's got to do with prinary veter cracking.
14 other aspects. had agreed --
14 other inan it probably was involved in it. I dut't 15 MR RAY: ' Agreed' isn't a word 15 know.
18 that I want to use.
16 MR. RAYS $ounds like it has 17 M. GIB50 lit Okay.
17 nothinp to do with it, but let ne ask -
18 MR. HOWEl.La Welt. I believe the 18 MR. IrJNN: I think it's becatse il 19 word in vow letter was no safetti significance 19 has to do with tracking in the reactor coolait 20 30 -
20 pressure boundary. Do you thinkt 21 MR. RAfs I don't know. It nay 21 MR. RAYS I don't knov ~
22 have been. I - we try not to ever use that word 22 MR. GIBSON: The N ~ NCR f.lates P3 either. But I believe in what I said originally.
23 in part, the licensee, af ter reviewing several 24 which is the first sentence of Criterion XVI does 24 alternatives, selected to repair any CRD 25 addrene conditions adverse to quelliv. And this 25 penetration which leaked or showed evidenct of 191 132 1
previous leakage by rolling the CRD housing to the 1
It's a response to a nanaged issue where we 2
vessel ~ reactor vessel lover head, seal the 2
understand the cause and develop an acceptable 3
leakage path.
3 response to that.
4 We find the repair nethod 4
MR. HERMANW: It's clso the --
5 acceptable for the following reasons, and it vent 5
MR. HOWELLs It seened to be G
Nt to discuss those.
6 related.
7 MR. RAY: Yeah, I think -
7 MR. HERMANNI It's also the O
MR. HERMANNt Short tern ~ but B
quest 100 of an industry response that's en the 9
nmber one it's not prinary veter cracking.
9 dncket right now in the BWR owners group. okay.
le Number two. It's a short - it was intended to be 18 which is probably ~ ! don't know how it's going 11 a short temporary repair.
11 to cone out.
12 MR GIBi @
't vis for 4 --
12 MR. RAY: You know. I feel like 13 the --
13 I've been taken to the wood stad here becatse I 14 MR. RAY: Yeah. obi 14 don't understand the inportance and the high
~
15 MR. HERMANW: Okay.
1$
significance of natntaintne the integrity of the 16 MR. GIBSON: - the leak before 16 of reactor coolant pressure boundary.
17 break philoLophy is the basis for en acceptable 17 And, frank 1V. I th'nk that's 18 Intergranular stress corrosion cracking -
10 unfair. And ~ and all I'n trying to do is to 10 MR. HERMANN: Right.
19 focus on that in ~ in some of this, not to 29 MR. GIBSON: ~ Inspection repair 29 address the questton of necessarily Allow Geo P1 no221e proaran.
21 cratkino and vhether inspection vas an adequate 22 MR. HERMANN Yeah. I knog vhat it 22 response to it. Okay.
23 says.
23 MR. MERSCH0FF Let ne ~ vhlte 24 MR. HUNT: I suggested thev put it 24 vou're collecttno your thoughts here -- reolster FS In. Bob. And tha reason was that it's a engine.
25 one point, and that it. I understand the point Tannte L. Snith. CSR (8173 SP5-4340
m
_______-__m.
PRFGISICAL ENF0leCEMCET HECING - SEPTEMBEll 30, 1997 193 194 1
wou're making relative to a significant condition 1
MR. HERMANils I think the words 2
Myerse to quattiv a-et least I think I do.
2
- potential long torn concern
- are in the stef f 3
And the exanples that vou've Olven 3
conclusions of nost of those -- lh sone of those 4
where lov safety significance is attributed to 4
docunents, too.
5 these or teleted conditions are good and 5
And that's an issue that I itnov Interesting examples that need to te revleved.
6 has teen brought fo the industry's attehtlon 7
But I absolutely disagree with 7
before the attention of NE! and the rest of it.
8 equating treediate safety concern with a 8
So the staff didn't say they had so safety concern t
significant condition adverse to quelltv. There 9
regarding primary water stress corrssion cracking.
If con be e 660nificant condition that does not 18 said it was not an innediate safety problen. Said 11 elevate to the point of inmediate safety concern.
11 11 was lov safety significance. but had hever cone 12 MR. RAYi I'll accept that.
12 to the conclusion that it wasn't a safety problen.
13 MR. MERSCH0FFs And I wanted you 13 MR. RAYS ! -- and I'!! agree Ulth 14 to understand that.
14 that, as well.
15 MR. RAY All right. And I think 15 MR. HERMANllt A potential safety IC that's - how, on reflection. I agree with you.
16 problem.
17 MR. HERMANiil I think the other 17 MR. RAY: I said eirly on that 18 thing --
18 I've been witness to an enornous enount of diverse 19 MR. RAYi I think the thing **
19 opinion within the staff on this issue.
28 excuse ne just a second. I think the thing that 20 My oniv objection -- I have no 21 was of nore significance to ne in nuch of what 1 21 objection to the a to sone policy belho taken a 22 was presenting was the notion that we nust not 22 position taken by the NRC that's different than 23 ellow. es '
- Mt prevent and preclude ang 23 unat we happen to think was acceptable up until 24 leakage from the reactor coolant pressure 24 nov. MW only obsaction is for this to be a natter 25 boundary.
25 of enforcenent action.
105 196 1
50 ve think that the 1
ones were talked about.
2 nonconfornance is conpletely nistaken here, 2
MR. RAY: We tried to.
3 repetitious, things we have said already.
3 MR. MERSCH0FF And we're as 4
The last thing I guess I will say 4
Interested as you are in assuring that the record 5
is you inviteo us 'o -- as nornally is the case -
5 is correct and veicone subnittal.
6 to identify any errors in the Inspection Report.
6 MR. RAYS I ~ I know that.
7 There are a fevi If not errors, there are itens of 7
Okay. We apologize to everyone 8
clarification, that we don't think is necessary to B
for the long presentation. As I said, this, to 9
raise and discuss here with you. We vill subalt 9
ne. Is an extraordinarily inportant natter. And to then on the record.
10 wou've been very kind to give us the opportunttu 11 They have arisen in the careful 11 to present a conplete story.
12 review that we have naie of the Inspection Report.
12 MR. MERSCH0FFs As I said in the 13 sone of then Just have to do with nunbers that 13 beginning, the agenda called for a ten-ninute 14
- ott,
- Se corrected for the record. Some of 14 caucus. I intend to do that. I would encourage 15 them t.
.o do with things a little nore 15 vou to do the sane.
16 substanttv.. And I guess we'll do that by the end 16 It's extremely important that the 17 of the week.
17 Infornation conveyed back and forth in a neeting 18 MR. MERSCH0FF: 10 the ertent that 18 such as this be accurate. And this is a good 18 they bear on the decision we're naking now.,t's 13 opportunity to assure that there wasn't anything 29 inportant that we get then -
20 anyone heard on either side of the table that 21 MR. RAY: Of course.
21 wasn't precise.
22 MR. MERSCH0rF: -- promptiv. And 22 MR. RAY: Would you like us to
(
23 I would hope the substantive ones would have teen 23 review the transcript for that reason?
24 tos'.ned on in our dtscussIon.
24 MR. MFJ<SCHOFF: The transcript 25 MR. NUNN: All of the significance 25 vill be *Me public. You'll Det a copy. And I I
fannte t.. Snith. CSR 18171 625-4 M O
_ -. _. - _ -. ~-- -
- - -. - ~ _ _.. -.. - -
~. - -. - - - - -.
PREDECI$10 lim. IMDRCEENT HEARING
- SEPTLMDER 38. 1937 197 198 1
would encowage you, if you see anything in it 1
think that was nMe for which I. at the line.
2 that you would went to amplify or correct. to do 2
didn't have the context.
3 t hat.
3 11 vus stated that we said there 4
M. RMs We vill.
4 was no safety significance to prinary water stress MR. MEE CH0rF Are there ang corrosion cracking. I'd Just like to read the 6
questions that need to be brought up right now?
6 entire phrase.
7 If not. ve're of f the record.
7 Because the NRC and industry 0
ICaucus was taken at thlt 8
agreed there was no safety significance to primary 9
time in the proceedings at 9
veter stress corrosion cracking which would 15 4:45 p.m. until 4:$5 p.n.1 18 justily replacenent of the nozzles. Edison 11 MR. MERSCH0FFI ve have conpleted 11 concluded that, and then it Does on.
12 our caucus. We believe we understand the points 12 So it's only in the context of 13 900 nado and the issues you brought up and have no 13 Justifying replacenent of the noz2les that that it questions fron this side of the table.
14 statement was nade.
15 Let ne ask Dave and J. D. ~
15 1 still don't think it's a good 16 anything fron your endt 16 statenent to make because it's subject to such 17 TELEPHONIC REf.00NSE None here.
17 differing interpretations about what is meant by 18 Ellis. Thanks.
18 It. $o I've tried to stick with the issues that 19 MR. MERSCH0FFI Okay. Mr. Ray.
19 pertain to the appilcation of Criterion XVI. Which 28 1'll give you an opportunity to raise any points 28 is close to that statement but not preciselv the 21 or nake any closing statenents you with to nake at 21 sane.
22 thle point.
22 AnVvav, that's all that we can 23 MR. RAYS I've probably worn out 23 come up with. We vill be providing information 24 nu volcome by nov. Ihtt I was advised by ng 24 that you have asked for fron us by. I'n told, the 25 colleagues to pu' Into context one statenent 1 25 end of the day Thursday by f ax having to do with 199 200 t
the data sets that we have showed 900, answering i
subject to further review ar.J f.av be revised prior 2
questions about those.
2 to any resulting enforcenent action and that 4
3 And we vill provide the letter 3
statenents or expressions of opinion hade by NRC 4
Indicating clarifications that we would with to 4
enployees at this Conference, or the lack thereof.
5 see in the Inspection Report, itself, by Fridag.
5 are not intended to represent final Agency 6
MR. HovELt.a And Personren. I 6
positions or deterninations.
7 think.
7 And with that this conference is 8
closed. Thank 900.
question of whether we think the 48 personren to 9
MR. RAY: Thank you.
10 replace this heat maternal is representative of 18 IProceedingt. concluded 11 what we would really project based on how we 11 at 5:00 p.m. CDT) 12 expect to do the work.
12 13 MR. MERSCMPs Well, thank you.
13 14 First of all. I want to thank you 14 15 for the considerable effort that you obviously t$
15 vent through to provide this volume of 16 17 Information, both clearly and conciselv - ind 1 17 19 hean it when I say conciselv. considering the 18 19 anomt of information that 900 had to go through.
19 20 ve vill use that information.
29 21 constder it in arriving at a dectslon and inforn 21 22 vou both in vrillns and by telephone when the 22 23 decision is nMe.
23 24 l'd like to renind you that the 24 25. apparent vlotation discussed at this Conference is 6
fannte L. $nith. CQt 1817) 625-4948
. _ -.. ---. - ~..
PNEDECISIONAL ENFORCEMENT HE#tDIG * $EPTEMBER C,1997 i
ett i
1
$ FATE OF TEXAS I
i 2
COUNf1r OF f ARRMT I 3
4
- 1. f amie L. $nith. Certified Stathand Reporter in and for the State of Texas. heret>v certify that the foregolh0 pages conteln 4 FUl1.
l 7
true and accurate tranectlption of the proceedtres 8
SS teisen etenuaragelcelly tiv no et the tihe an$
}
9 plate lhdicated.
18 11 WITNESS M h"D thle the 7th day of Octoter.
I 12 A.D.
1997.
i 13 14 15 16 hih hetfb'$1N Expire son 12i 1B is P8 F1 22 F3 CERT C k
'ORTER 24 Port War
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Enclosure.5 l
l 1
PRliDECISIONAL ENFORCEMENT CONFERENCE AGENDA
- __._. ~.
1 PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA CONFERENCE WITH SOUTHERN CAllFORNIA EDISON CO SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 SEPTEMBER 30,1997 NRC REGION IV, ARLINGTON, TEXAS 1.
INTRODUCTIONS / OPENING REMARKS REGIONAL ADMINISTRATOR l
2.
ENFORCEMENT PROCESS ENFORCEMENT OFFICER 3.
APPARENT VIOLATIONS & REGULATORY CONCERNS DIRECTOR, DRS
'l 4.
LICENSEE PRESENTATION -
i 5.
BREAK (10-MINUTE NRC CAUCUS IF NECESSARY) 6.
RESUMPTION OF CONFERENCE 7.
CLOSING REMARKS LICENSEE 8.
CLOSING REMARKS REGIONAL ADMINISTRATOR t*
w w
> ^ + -
vw s
w a-wm-we-
+-r-
ENCLOSURE 6 APPARENT VIOLATION
APPARENT VIOLATION
- PREDECISIONAL ENFORCEMENT CONFERENCE SOUTHERN CALIFORNIA EDISON COMPANY SEPTEMBER 30,1997 NOTE:
THE APPARENT VIOLATIONS DISCUSSED AT THIS PREDECISIONAL ENFORCEMENT CONFERENCE ARE SUBJECT TO FURTHER REVIEW AND MAY BE REVISED PRIOR TO ANY RESULTING ENFORCEMENT ACTION.
i
APPARENT VIOLATION A.
Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, " Measures shall be established tu assure that conditions adverse to quality, such as f ailures, malfunctions, deficiencies, deviations, defective material and equfpment, and nonconformances are promptly identified and corrected, in the case of significant i
conditions adverse to quality, the measures shall assure that the cause of the condition is determined, i corrective actio.i taken to preclude repetition...."
Contrary to the above, a total of four confirmed f ailures (i.e., through wall cracking),
a significant condition adverse to quality, have occurred during 19921997 in Units 2 and 3 reactor coolant system Inconel 600 nozzle penetrations manufactured from Heat NX7030, without actions being taken to preclude recurrence.
NOTE:
THE APPARENT VIOLATIONS DISCUSSED AT THIS PREDECISIONAL ENFORCEMENT CONFERENCE ARE SUBJECT TO FURTHER REVIEW AND MAY BE REVISED PRIOR TO ANY RESULTING ENFORCEMENT ACTION.
ENCLOSURE 7
}
LICENSEE LETTER OCTOBER 31,1997 l
!32" n
"' - ~ "'""~"
Aa llHkDN INilR% AlloN AL Gegen
- October 31,1997 Mr. Arthur T. Howell lil Director, Division of Reactor Safety U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064
Dear Mr. Howell:
Subject:
Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station, Units 2 and 3
Reference:
Meeting, NRC Predecisional Enforcement Conference, dated September 30,1997 At the referenced meeting, Southern California Edison (SCE) agreed to provide a copy of SCE's Alloy 600 Program Plan 90022," Susceptibility of Reactor Coolant System i
Alloy 600 Nozzles to Primary Water Stress Corrosion Cracking and Replacement Program," by October 31,1997. The Alloy 600 program plan update is attached.
If you have any further questions, please contact me.
I Sincerely, bs !R u Y
I
Attachment:
as stated cc:
Document Control Desk K E. Perkins, Director, Walnut Creek Field Office, NRC Region IV M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 2 and 3 R O.Ikn 128.
San Clemente. CA 92t>744)128 7144(4 1480 l
1as 714.%8-1440 I
SOUTHERN CALIFORNIA EDISON SAN ONOFRE NUCLEAR GENERATING STATION Units 2 and 3 October 31,1997 Document 90022 Revision 2 Quality Class III Susceptibility of Reactor Coolant System Alloy 600 Nozzles To Primary Water Stress Corrosion Cracking and Replacement Program Plan O k br D/sih7 Responsible Engineer Date GhavG%
akin Supervisor Date l0 l Vl Mar /ager, S.T.S.
Date '
(For revision block, see page 1) hhMt+f y 3 C/)//
j
Docuntent 90022 Revision 2 Record of Revisions f
P N
Rev.
Date Description /Affected Pages 0
9/9/93 Reference Documentation. Initialissue 1
1/11/95 Reference Documentation. Full document revision: Incorporates Cycle 7 refueling outage experience, CEDM no7zle strategic plan, Alloy 690 material ordering information, stuck PZR heater evaluatloa, and nozzle repair corrosion evaluation. Adds Attachments 2. 3, and 4. Changes Attachment I to ' Tables".
2 10/31/97 Reference Documentation. Full document revision: incorporates Cycle 8 and 9 refueling outage experience. Adds spxadsheet and drawings detailing Alloy 600 component locations. Provides detailed plan for each Alloy 600 component location.
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Document 90022 Revision 2-i t
Table of Contents SECTION PAGE i
1.0 I n t rod uc ti on........................................................... 2 i
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Di scu s s i on............................................................ 3
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2.1 M echanics o f PWSCC............................................. 3 2.2 Pressurizer Instmment Nozzles...................................... 4 2.3 RCS Piping Instmment Nozzles..................................... 5 2.4 Steam Generator instrument Nozzles................................. 5 2.5 Pressurizer Heater Sleeves.......................................... 5
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2.6 Control Element Drive Mechanism /Incore Instrument Nozzles............. 6 i
4 2.7 S afe ty Significance............................................... 8 3.0 SONGS Inconel Inspection Program........................................ 8 3.1 Inspec tion Proced ure.............................................. 9 3.2 Inspec tion Frequency.............................................. 9 4.0 Repair Techn iques...................................................... 10 4.1 Half nozzle repair................................................ 10 4.2 Mechanical Nozzle Seal Assembly................................... I 1 4.3 Non Destmetive Examination Inspections............................. I 1 5.0 l listorical S u m mary...... -............................................ 12 6.0 Cu rren t Plan........................................................... 13 6.1 Pressurizer Instrument Nozzles..................................... 14 6.2 RCS Piping instrument Nozzles.................................... 14 6.3 Steam Generator Instrument Nozzles................................ 14 6.4 Pressurizer Heater Sleeves......................................... 14
- 6.5 Control Element Drive Mechanism /Incore Instmment Nozzles............ 15 7.0 R e fe re nce s........................................................,.. 1 6 -
8.0
- Attachments 8.1 Ta ble 1.............................'........................... 1 7 8.2
- Ta ble 2........................................................ 1 8 8.3 ; - Fi g u re s.........................................................- 1 9 6
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Document 90022 Revision 2 1.0 Introduction nis program plan describes the current level of understanding of Primary Water Stress Corrosion Cracking (PWSCC) in Reactor Coolant System (RCS) Alloy 600 components and the implications of this industry problem to San Onofre Nuclear Generatir.g Station (SONGS). Thi :
plan provides for an effective program management strategy, including inspection timing, scopt, and repair options and planning, to maintain nuclear safety and plant reliability. The plan identifies all Alloy 600 pressure boundary components and details the appropriate inspection and/or repair activities for each location.
Alloy 600 was selected as the preferred material for Reactor Coolant Systems (RCS) penetration applications due to its corrosion resistance and thermal expansion characteristics. Penetrations in the RCS are required for instrumentation, venting, heater insertion in the Pressurizer, and Control Element insertion through the reactor head.
Industry experience has shown Alloy 600 to be susceptible to Primary Water Stress Corrosion Cracking (PWSCC). Industry PWSCC experience was first reported in Steam Genemtor tubes, despite lower operating temperatures than the pressurizer. Steam Generator tubes will not be discussed further in this document; they are addressed in the Steam Generator Strategic Management Plan. Pressurizer instrument and heater penetrations were the next to experience leakage due to PWSCC. PWSCC in Alloy 600 instmment nozzles in RCS piping has recently experienced increased failure rates. Experience has demonstrated that all Alloy 600 components are susceptible to PWSCC and that an aggressive inspection and repair program is required to properly address this issue.
An aggressive Alloy 600 penetration repair plan has been implemented for the RCS piping instrument nozzles. These repairs are scheduled for completion prior to the start of Cycle 10.
This document will be reviewed and updated at least once during each fuel cycle. The review will incorporate lessons learned, site specific experience, and data which becomes available from the industry and research related Alloy 600 materials. Any sepairs required due to identification of evidence ofleakage, proactive repairs, and future planned repair activity will also be updated dur!ng this review.
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Document 90022 Revision 2 2.0 Discussion 2,1 Mechanics of PWSCC Root cause evaluations of failed Alloy 600 nozzles throughout the industry have revealed the presence ofintergranular cracks caused by Stress Corrosion Cracking (SCC). SCC requires three components to be present in order to occur, these are high tensile stresses (residual and/or applied), a harsh environment, and a susceptible material. For Alloy 600, i
a hanh environment contributing to SCC is pure water (Iow Chlorides Oxygen, Fluorides, caustics, etc.) at high temperatures, the environment found in the primary cooling system of pressurized water reactors, hence the name PWSCC.
We installation of RCS penetration nozzles results in high residual circumferentially oriented tensile stresses. De Alloy 600 nozzle, or sleeve, is attehed to the piping or i
pressure vessel inside diameter with a J groove partial penetration attachment weld (see Attachmem 8.3, Figure 1). Durinp, installation, as the weld cools to ambient temperatures, the weld material contracts and deforms the alloy 600 material sadially.
He result is high residual circumferential tensile stress in the vicinity of the attachment weld. We residual stresses resulting from weld contraction can exceed the yield strength of the material. Yield strength is discussed in more detail below. Operating pressure also produces stress in the material. For cylindrical penetrations such as the Alloy 600 components, the magnitude of the hoop stress la the circumferential direction is twice the magnitude oflongitudinal stress due to operating pressure %cse stresses are well below the yleid strength of the material and are considerably lower than residual stresses i
resulting from the attachment weld. Since the primary stresses are oriented circumferentially, cracking within the stress field will be in the axial direction.
%c yield strength of the Alloy 600 material is another factor which contributes to PWSCC susceptibility. A material's ability to retain stresses without plastic deformation is quantified by the yield strength. In some cases, residual stirsses resulting from the attachment weld can be higher than the yleid strength oithe material, increasing the susceptibility to PWSCC. Originally there was a perception that a threshold yield strength existed, at ~40 ksi, below which Alloy 600 would not be susceptible to PWSCC.
Industry experience, both at SONOS and ot' er utilities, has demonstrated that all Alloy 600 material, regardless of yield strength, is susceptible to PWSCC High yield strength material can retain more residual stress than low yleid strength material, resulting in faster crack initiation and propagation.
Iloth field experience and laboratory tests have confirmed that the primary factors contributing to PWSCC in Alloy 600 include temperature and stress. The effect of temperature on time to cracking due to PWSCC can be described by an Arrhenius type relationship, which predicts a two fold increase in time to crack initiation for each 18'F 3
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Document 90022 Revision 2 s
decrease in temperature." Empirical data on stress shows that time to cracking due to PWSCC varies inversely with residual stress raised to the fourth power %e known mformation relating to temperature and stresses can be used to make an initial determination of PWSCC susceptibility. Other factors that contribute to PWSCC are less tangible. Rese factors include the material fabrication and installation process, material irregularities, the depth of cold work present in the material, the annealing temperature and subsequent heat treatment, and microstructural characteristics including carbon content, carbide distribution, and grain size.
Of the less tangible factors contributing to PWSCC susceptibility, cold work is perhaps the most critical and well documented. It is generally accepted that a cold work layer on the inside diameter of an Alloy 600 penetration will accelerate the initiation of PWSCC."
This cold work layer is characterized by a microstructure that has few intergranular carbides, resulting in initiation locations for the corrosion mechanism. His type of surface typically results from the machining piocess of the Alloy 600 bar stock material (SB 166). Depending on the machining process employed, the cold work layer will vary in depth making some nozzles more susceptible than others. Although the depth of the cold work layer can be controlled when machining new, replacement nozzles, the extent of cold work in existing nozzles is not quantifiable. We amount of cold work present in material fabricated from Alloy 600 drawn tube, or pine, material (SB 167), is genera!!y less than that found in machiled bar stock. He drawn tube form was used for pressurizer heaters and incore instrumentation nozzles in the reactor head, while the forged bar was used for all other Alloy 600 applications.
Rese factors may significantly affect the initiation and propagation of flaws due to PWSCC. Current modeling techniques do not quantitatively account for all of the factors discussed above, and therefore cannot accurately predict leakage due to PWSCC in a particular nozzle location.
2.2 Pressurizer Instrument Nozzles he occurrence of through wall cracking in Alloy 600 penetrations due to PWSCC was first discovered in Pressurizer applications, where typical operating temperatures are approximately 650'F. His is consistent with research data showing that PWSCC is accelerated when high temperature is coupled with the less tangible contributors discussed above.
SONGS 2 & 3 pr> ssurizers are both designed with a total of seven instrument nozzles; four vapor space nozzles in the upper hud, one water space nozzle in the lower shell and two water space nozzles in th iower had. Reference 7.3 identifies a condition in which SCC susceptibility increases as a result of contaminant accumulation in vapor space interface locations. Additionally, hydrogen in a vapor environment has been shown ta be 4
Document 90022 Revision 2 a contributor to SCC. Rese two environmental effects are not present in the lower pressurizer instrument nozzles nor any of the other RCS nozzles (hydrogen is present but not in a gaseous form). Consequently, vapor space nozzles were expectui to develop leakage Orst. This expectation was conDrmed as the majority of early PWSCr experience in the U.S. industry was in the vapor space region of the pressuri & - rsus the water space regions of the remainder of the RCS, liowever, since the tema.atme effect is considered a dominant factor, pressurizer vapor and water space nozzles (both operate at a temperature of-650 F) are the locations with the highest susceptibility to PWSCC.
. 2.3 RCS Piping Instrument Nozzles Recent industry experience, particularly at SONGS in the Unit 3 Cycle 9 refueling outage, has included a higher than expected number ofleaking RCS piping instrument nozzles.
Each unit at SONGS has 32 hot leg instrument nozzles (service temperature is 508 F) and 12 cold leg nozzles (service temperature is 554*F). Rese nozzles are used for measurement of temperature, differential pressure, sampling, and spares. The hot leg nozzles are installed at the 145',190', and il35' orientations with respect ta the 12 o' clock position. The cold leg nozzles (three per loop) are installed at 12 o' clock and 145* To date, one hot leg nozzle at Unit 2, ten hot leg nozzles at Unit 3, and one cold leg nozzle at Unit 3 have been replaced due to identification of evidence ofleakage.
Although leakage was not confirmed for each case, for purposes of this plan all replaced nozzles are assumed to have been leaking.
2A Steam Generator Instrument Nozzles Here are four pressure instrument tap nozzles on each Steam Generator. These nozzles are installed in the Steam Generator in the cold side of the lower head in a similar configuration to the RCS piping nozzles. Since the outlet temperature of the Steam Generator is lower (553'F), the susceptibility to PWSCC is low for these nozzies. Since they are installed in a pressure vessel, a weld pad build up would be required to perform the half nozzle repair.
2.5 Pressurizer Heater Sleeves SONGS 2 & 3 pressurizers are both designed with 30 heater sleeves in addition to the seven instrument nozzles discussed above. The heater sleeves are fabricated from the drawn tube form (SB 167) of Alloy 600 and as a result, heater sleeves are considered less susceptible to PWSCC than instrument nozzles in the piessurizer. CE performed a susceptibility study of heater sleeves at all CE plants. This study ranked SONGS' heater sleeves in the " low susceptibility" caugory based on material yield strength and the machining process prior to and following installation."
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Document 90022 i
Revision 2 There have been three occurrences of leakage from heater sleeves due to PWSCC in the U.S.t Calvert Cliffs, Unit 1 (two found leaking in 1994), Calvert Cliffs, Unit 2 (20 found leaking in 1989), and Arkansas Nuclear One, Unit 2 (one found leaking in 1987). All three of these incidents involved additional contributing factors. In the case of Calvert Cliffs, Units I and 2, root cause evaluations concluded that pre weld teaming performed on the heater sleeves substantially cold worked the inner surface of the sleeves, increasing the yield strength and contributing to PWSCC initiation. One of the sleeves at Calvert
~ Cliffs. Unit I had both circumferet.tial and axial crack orientations due to the forcible removal of a stuck reamer, which imposed axial residual stresses. At Arkansas Nuclear One, Unit 2, the failure was attributed to stresses and cold work in the sleeve imposed by a failed heater, which had swelled due to wettir.g of the heater internals.
When heaters fail electrically, a breach of the heater sheath can occur allowing water to come into contact with the heater internals. When wetted, the magnesium oxide (MgO) insulation material will react with water, producing magnesium hydroxide, which can expand to 152% of its dry volume." This can cause swelling of the heater and possibly rupture the heater sheath. If this swelling occurs near, or vittiin, the Alloy 600 heater
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sleeve, the potential exists for cold wori:ing and cracking of the sleeve. Due to the tight clearance between the outside diameter of the heater and the inside diameter of the sleeve
(.015 to.032 inches), even minor swelling in this regica can cause cold work and introduce additional tensile stress in the heater sleeve. In addition, removing a failed heater can cold work the inside surface of the sleeve if attempts are made to pull the swelled portion of the heater through the sleeve. Cold work on the inner surface will reduce the time to initiation of PWSCC.
Attempts to remove three electrically failed pressurizer heaters at SONGS, Unit 3 have been unsuccessful. Because a pulling force greater than that allowed by the Pressurizer Instruction Manual (20 lbs.)" was exerted, there was a concern that the heaters swelled and the removal attempts may have cold worked the inside surface of the sleeves. A "go-no go" gauge was used during the Unit 3 Cycle 8 refueling outage to verify that swelling of the heater sheath had not occurred in the area just above the heater sleeve, indicating -
that the heaters may be stuck in the support plates.
Five additional heaters have failed electrically at Unit 3. Removal of all eight failed heaters is scheduled for the Cycle 9 mid-cycle outage. All heater sleeves with stuck or difficult to remove heaters will be eddy current tested to ensure that crack initiation has not resulted from cold work done on the inside surface of the sleeve.
2.6 CEDM and ICI Nozzles in the Reactor Head SONGS 2 & 3 each have 91 Control Element Drive Mechanism (CEDM) nozzles and 10 In-Core Instrumentation (ICl) nozzles. The yield strengths of the CEDM and ICI nozzles 6
Docuinent 90022 Revision 2 vary between 35 and 60 ksi. T..ese nozzles differ from the penetrations discussed above in that they are much larger in diameter and they are installed with a 0.000 to 0.003 inch interference fit. They are installed in the reactor head, which is a hemispherical vessel This installation configuration results in another factor which contributes to PWSCC susceptibility, the " hillside angle" at which the nozzle is installed in the reactor head.
Hillside angles increase from the central nozzles to the periphery nozzles. The ICI nozzles are located on the periphery of the reactor head, thus they have the steepest hillside angles. As the hillside angle increases, the length of the attachment weld also increases. He attachment weld for reactor head nozzles follows the path of a three dimensional curve, resulting in uneven residual stresses, which "ovalize" the Alloy 600 penetration.
To date, SONGS has not experienced any leakage due to PWSCC of Control Element Drive hiechanism (CEDht) or Incore instrument (ICI) nozzles. The potential for such an occurrence, however, has become an issue since cracking of CEDh1 nozzles was first discovered in a French PWR in September,1991. The NRC issued Generic Letter 97-01 in April of 1997" to raise the U.S. industry's awareness of the NRC concems and encourage inspections of reactor head penetrations for PWSCC. The Combustion Engineering Owners Group (CEOG) developed a generic response to Generic Letter 97-01" which describes the CEOG integrated inspection plan and provides a detailed explanation of the CEOG timing model. We integrated inspection program includes the ICI inspections at Palisades, the 100% inspection at hiillstone, and the planned 100%
inspection at SONGS 3. Rese three plants are ranked highest by the CE timing model.
Although not ranked high with respect to CE plants, SCE plans to perform a 100%
inspection of SONGS 2. His would provide additional data for the CE integrated inspection plan, the US industry and provide condition assessment information for all reactor head penetrations at SONGS. The CE integrated inspection plan also credits the reactor head vent cddy current exam at Calvert Cliffs, Unit 2.
The following inspections have been performed in the United States:
DC Cook 2 inspected 71 of 78 CRDh1 nozzles and one nozzle revealed 3 axial indications. The deepest crack was weld repaired after a subsequent inspection.
Oconee 2 inspected all of their CRDh1 housings and only one nozzle had axial indications (21 surface flaws identified of no measurable depth). These flaws were accepted as is.
Point Beach 1 inspected 49 nozzles and found no indications.
North Anna 1 inspected periphery nozzles in the highest stress regions and found no indications.
Palisades inspected ICI nozzles on the periphery of the reactor head and found no indications.
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Document 90022 Revision 2 hiillstone 2 performed a 100% inspection and found one shallow cluster of short
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axial flaws in one penetration. Dese flaws were subsequently removed with a mechanical buffing process.
As additional inspections are performed and more information becomes available, the results will be incorporated into this plan.
2.7 Safety Significance The safety significance of PWSCC has been addressed by both the NRC and the U.S.
nuclear industry. He location with the highest safety significance in which Alloy 600 penetrations are in service is the CEDM nozzles, due to the possibility of a control rod ejection associated with catastrophic failure of a CEDht nozzle. CE performed a safety evaluation of this possibility" which concluded that this issue does not constitute an immediate safety concem. The B&W and Westinghouse owners groups' safety evaluations came to similar conclusions. These safety evaluations were submitted to the Nuclear Regulatory Commission (NRC). An it. dependent assessment of control rod drive mechanism (CRDht) nozzle cracking was performed for the NRC which also reached the conclusion that CRDhi nozzle cracking is not a short-term safety issue.*
All evaluations of the stress field in Alloy 600 penetrations attached with a partial penetration attacionent weld to date have predicted primarily circumferential stresses. A circumferential sicess field will result in a crack orientation which is axial.
Reference 7.4 contains a technical assessment of safety concems related to pressurizer heater sleeves. Fracture mechanics studies performed by BG&E have shown that the potential for PWSCC does not pose a significant threat to the structural integrity of the pressurizer. Sudden axial rupture due to plastic tearing would not be expected to occur.
Additionally, the potential for circumferential cracking leading to catastrophic failure of a heater sleeve from a guillotine break is not considered a credible failure mode.
Independent evaluation by CE supports this canclusion.
Reference 7.1 discusses circumferential cracking in pressurizer heater sleeves and instrument nozzles. Catastrophic failure from a guillotine break is judged not to be a credible failure mode. This analysis also applies to instrument nozzles in the RCS piping and Steam Generators.
3.0 SONGS InconelInspection Program
~In order to perform bare metal inspection. '.round each nozzle, the RCS piping insulation has been modified. During the Cycle 7 refueling outage insulation plugs were fabricated which are easily removed for inspection purposes. The insulation on the bottom head of the pressurizer 8
Document 90022 Revision 2 around the heater penetrations and the lower level nozzles is removable, and is removed each refueling outage to perform inspections.
The reactor head is inspected during refueling operations, during the time it is on the reactor head stand. The insulation on the periphery of the reactor head is removed, however the central portions are not, primarily due to the restricted accessibility and ALARA concerns related to the central nozzles. The central nozzles are observed with the insulation in place. The removable portion exposes 24 CEDM nozzles and all 10 ICI nozzles for bare metal visual inspections.
These 34 periphery nozzles have the highest hillside angles. Extemal visual inspections are not required when eddy current examinations are performed on the inside suJace of the reactor head penetrations.
3.1 Inspection Procedure SO23 V-8.16 " Reactor Coolant System Inconel Nozzle Inspection"'" controls and documents the inspections of Alloy 600 penetrations. The following requirements have been implemented for the Unit 3 Cycle 9 refueling outage and future Inconel inspections.
A minimum of two qualified inspectors, familiar vth the nozzle locations, installation configuration, and the types ofindications resulting from PWSCC (extremely small leakrates) inspect each nozzle. All obstructions impairing direct observation of the crevice between the Alloy 600 penetratica and the piping or vessel are removed, with the exception of the central nozzles on the reactor head.
Acceptance criteria were established and incorporated into the inspection procedure to identify a potential nozzle leak. Any brown, mst-type stains on a nozzle or the base metal, or the accumulation of boric acid and/or corrosion products are indicative of a potential nozzle leak. An additional criterion is the presence oflocalized carbon steel degradation of the annular region adjacent to the nozzle. Should any of these observations be made during the inspection, an evaluation of the deposits is performed by Chemistry to assc* in the determination of whether the leakage is from the RCS, and approximately when it initiated. Any discrepancies found during the inspection are documented with photographs and a description is provided in the procedure. An evaluation is performg determine if repair activities are required. Caution is taken when using radio-isotopic analysis results, particularly during or after a significant boration or dilution of the RCS. The completed inspection procedure is filed with Corporate Docum% Management following the refueling outage.
Inspection FrequIncy 3.2 A complete inspection of every Alloy 600 penetration and completion of the inspection procedure is performed at least once each refueling outage. Similar inspections are also performed at the beginning of any Mode 5 outage. Additional inspections are performed 9
Document 90022 Revision 2 after the RCS pressurization during startup, ensuring that there is no pressure boundary leakage upon entering power operations, as required by the Technical Specifications 7.i2 4.0 Repair Techniques Three repair techniques have been used or are planned for use at SONGS The pressurizer steam space nozzles have all been replaced with Alloy 690 nozzles, installed with an internal J-groove weld in accordance with the original design. Pressurizer water space and RCS piping nozzles can be repaired with the half nozzle technique, or they can have a Mechanical Nozzle Seal Assembly (MNSA) installation.
To adequately prepare for nozzle replacement activities SCE has purchased SB-166 Alloy 690 material manufactured to an optimized material specification,7 8 Forged bar stock may also be obtained from the CEOG and machined to replace any pressurizer or RCS nozzles, or a heater sleeve should leakage occur. He CEOG material should be used only in an emergent situation.
4.1 Half Nozzle Repair Technique ne half nozzle repair technique has been used for all hot leg repairs and on three nozzle locations in the pressurizers (two vapor space nozzles were temporarily repaired with this technique, one v Sr space nozzle has this repair configuration in service), his repair option does not regaire entry into the pipNa or vessel to perform the work, significantly reducing the dose required to complete repair activities. The original nozzle is cut off outside the piping or vessel and a temporary plug is installed deep in the nozzle to prevent foreign material from entering the RCS. The outer portion of the nozzle is then machined out by drilling. He inner portion of the nozzle is abandoned in place and a new Alloy 690 " half nozzle"is installed and welded to the piping or vessel outside diameter. This new exterior weld meets ASME Code Section XI requirements and is ctmeturally qualified for the life of the plant.
However, there is a small gap left between the original nozzle and the new Alloy 690 half nozzle. This gap allows borated reactor coolant to be in direct contact with the low alloy carbon steel parent material in the piping or vessel. Borated water in contact with carbon steci hu the potential of developing corrosion. To address the corrosion concerns of the hot leg nozzle repair, B&W Nuclear Technologies has performed an analysis of the carbon steel exposed to RCS in the 1/16 inch gap between the Alloy 600 and 690 nozzles.
His analysis determined an expected corrosion rate of 0.0017 inches per year for stagnant conditions and 0.0036 inches per year under non-stagnant conditions in the pressurizer. These corrosion rates were evaluated for the remaining plant life, including a license extensics to 2023, and were considered acceptable. An inspection of a repaired location will be performed to verify that the calculated corrosion rates are conservative. This inspection will be performed during the Unit 2 Cycle 9 mid-cycle outage. The half nozzle repair technique 4
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Document 90022 Revision 2 will continue to be used unless corrosion rates are found to be significantly higher than expected.
4.2 Mechanical Nozzle Seal Assembly (MNSA)
CE l as provided MNSA's designed for temperature measurement nozzles in the RCS hot leg piping and the water space nozzles in the pressurizer. Dese locations were chosen since the water space pressurizer nozzles are the most susceptible to PWSCC (highest operating temperature) and there are spare temperature nozzles installed on the bottom of the hot legs which would force a core off load in order to perform a half nozzle repair.
The MNSA design can be installed with water in the system, however the RCS should be depressurized prior " installation for personnel safety. The MNS A can be installed in approximately two shifts, reducing the time required to repair a leaking nozzle.
Installation is accomplished by drilling and tapping four shallow holes in the piping or vessel parent material around the leaking nozzle. A grafoil seal is compressed against the nozzle to piping or vessel crevice and the assembly is retained by the threads in the piping or vessel. The pressure boundary is essentially moved from the original attachment weld to the grafoil seal on the outside diameter of the piping or vessel. Concurrence from the NRC is being sought prior to installation of the MNSA design during the Units 2 & 3 Cycle 9 mid-cycle outages. After initial discussions with the NRC, they requested that a code relief request be submitted to address all outstanding issues associated with this design. Pending NRC approval, SCE plans to install the MNS A on the pressurizer water space nozzles as well as any nozzle locations found to be leaking which are not planned for replacement during the Cycle 9 mid-cycle outages. After installation, visuat inspection of the MNSA each n: fueling outage is required in accordance wi'h SO23-V-8.16 and the MNS A grafoil seal and attachment threads would be added to the ten year in service inspection program.
4.3 Non Destructive Examination Inspections Mock ups of the pressurizer and hot leg instrument nozzles and the pressurizer heaters are being fabricated to improve eddy current testing ability for these penetrations. Any penetration identified as leaking should be eddy current tested to confirm the length and orientation of the flaw. His testing should be perfonned during the repair process. To date pressurizer flaws have been characterized using penetrant test (PT), eddy current (EC), and ultrasonic (UT) techniques.
Eddy current test mock ups for the CEDM nozzles in the reactor head have been fabricated and used to qualify eddy current testing equipment. Westinghouse, Framatome and CE have all successfully qualified their eddy current equipment on these mock ups in accordance with EPRI standards and guidelines.
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5.0 SONGS PWSCC Historical Summary De first through wall instrument nozzle leak at SONGS occurred in 1986 when a; pressurizer steam space nozzle was discovered to be leaking.- A root cause evaluation
- was performed which idendfied that the source of the leak was intergranular cracking caused by PWSCC. De es 'uation concluded that the high yield strength of the material
_(heat 54318) made it highly susceptible to PWSCC. All of the remaining penetrations--
fabricated from heat 54318 were scheduled for replacement. There were two Unit 3 4
i steam space nozzles, one Unit 3 lower shell nozzle and one Unit 2 lower shell nozzle made from this heat. - Replacement activities were completed in 1988 using Alloy 600 material that was thought to have good characteristics with respect to resistance to PWSCC.
De next nozzle leak was found in 1992 during the Unit 3 Cycle 6 refueling outage in one of the steam space nozzles which was replaced in 1987 as a result of the first nozzle leak.
During repair activities inside the pressurizer, cracking was identified in two additional nozzles by PT exams. It was decided to replace all four steam space nozzles with Alloy 690 nozzles, however the weld material used was similar in composition to Alloy 600, since the Alloy 690. weld material had not yet been accepted by the code.
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- During a forced outage of Unit 2 in 1992, two steam space nozzles were found to be leaking. A half nozzle repair was installed on both of these nozzles. In 1993, during the Unit 2 Cycle 7 refueling outage, all four steam space nozzles were replaced with Alloy n
.690 nozzles using weld material similar in composition to Alloy 690. The first evidence.
L
- ofleakage from a hot leg nozzle (2PD'm978 1) was found during this 1993 refueling outage. This nozzle was sepaired using the half nozzle technique.
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In 1995 during the Unit 3 Cycle 8 refueling outage, two hot leg nozzles and one -
3:
i pressurizer steam space nozzle were found with evidence ofleakage. During repair
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= act!'.ities in the pressurizer, defects were identified in the weld material of two of the four steam space nozzles. All four steam space nozzles were replaced with Alloy 690 nozzles using weld material similar in composition to Alloy 690. The two hot leg nozzles were repaired using the half nozzle technique.
During the return to service of Unit 2 after the Cycle 9 refueling outage in 1997, the pressurizer lower shell nozzle (2'III0101) was found to be leaking. His nozzic had been proactively replaced in 1987 as a result of the first nozzle leak in 1986. This nozzle was -
repaired using the half nozzle repair technique in 1997 with a weld pad build up on the exteriorof the pressurizer using Alloy 690 material.-
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Document 90022 Revision 2 f
A self assessment team reviewed SONGS PWSCC experience as of the Unit 2 Cycle 9 refueling outage. The team recommendation was to enhance the inspection procedure and re-evaluate replacement recommendations after the Unit 3 Cycle 9 refueling outage.* Document 90022, Revision 2 provides the results of this re-evaluation.
At the beginning of the Unit 3 Cycle 9 outage, five nozzles (four hot leg and one cold leg) were identified for repair. As the unit was being retumed to service, four additional hot leg nozzles were identified for repair. Of the nine nozzles repaired during this outage, five had enough boric acid residue to obtain a relevant sample. Results of radio-isotopic analysis were not consistent with expected results at the end of the refueling outage due to the large volume of water exchanged between the refueling water storage tanks and the RCS during refueling operations.
Until the Cyc!e 9 refueling outages, it was expected that PWSCC could be effectively managed with a rigorous inspection program at the beginning of each refueling outage.
The assumption was that all PWSCC that had propagated through wall could be identified E
early in the outage, allowing time to implement repair utivities without impacting the outage schedule. His strategy also minimized radiation exposure associated with nozzle repair activities. He Unit 2 pressurizer lower shell nozzle leak was not identified during the initial inspection. This location had been bored to a slightly larger diameter during the replacement of the nozzle in 1987. This condition required the installation of shims between the nozzle and the bore with a bolted clamp assembly around the nozzle to hold the shims in place. There is a possibility that, had the clamp assembly been removed, early indications of the leak might have been identified during the initial walkdown.
Enhancements to the inspection process were implemented during the Unit 3 Cycle 9 refueling outage, including the removal of all shim clamp assemblies on Alloy 600 penetrations. Despite these efforts, the recent Unit 3 experience proved that thorough inspections at the beginning of an outage will not guarantee that tnere will be no new pressure boundary leakage developed during startup operations. In order to eliminate delays in return to service due to PWSCC in RCS nozzles, a more aggressive strategy is required than has been previously implemented. This new strategy includes preventive repair or non destructive examination of all Alloy 600 components. A mock up of RCS piping nozzles was fabricated to assist in training construction personnel, minimizing the time required to complete repair activities and radiation exposure. Additionally, shielding has been designed to lower the radiation exposure and ALARA concems associated with nozzle repairs.
6.0 Current Plan
%c following sections discuss planned repair activities for the Units 2 & 3 Cycle 9 mid-cycle outages and recommended inspection and repair activities for future outages.
13
Document 90022 Revision 2 i
6.1
- PressutIzer Instrument Nozzles All of the steam space nozzles at both units have been replaced with Alloy 690 nozzles and comparable weld meterial. Rese nozzles are inspected on a refueling outage interval. Removal of the shim clamps installed on these nozzles is not required since indications ofleakage will be rust stains from condensed vapor running down the side of the pressurizer. Indications of very minute lee.kage evidenced by boric acid residue will not be present on vapor space ne'hs.
The Unit 2 lower shell nozzle has been repaired with the half nozzle technique. Plans are in place to install MNSA's on the remaining water space nozzles during the Cycle 9 mid-cycle outages. Here are five remaining Alloy 600 water space nozzles in the pressurizers, the lower shell nozzle at Unit 3 and both lower head nozzles in both units.
5.2 RCS Piping Instrument Nozzles All RCS piping instrument cozzles are scheduled for half nozzle repairs during both the Cycle 9 mid-cycle outages and the Cycle 10 refueling outage. The scope of repair activities for the mid-cycle outages will be limited to those which are accessible while maintaining a level of 26 inches in the hot leg. All upper 45* nozzles in the hot legs and all cold leg nozzles will be available and scheduled for repair. The remaining RCS piping instrument nozzles at the 90 and 135' orientations will be repaired during the Cycle 10 core off-load window. Any nozzle locations identified with evidence ofleakage during the mid-cycle outages that are not scheduled for repair will have a MNS A installed.
6.3 Steam Generator Instrument Nozzles he susceptibility of steam generator nozzles is considered to be low since they operate at cold leg temperatures. To be prepared for identification of evidence ofleakage during an inconel inspection, MNSA's designed for these nozzles are being purchased and contingency FCN's prepared for their installation.
6.4
. Pressurizer Heater Sleeves Although the pressurizer heater sleeves were fabricated from drawn tube, reducing the amount of cold work present in these penetrations, they are still susceptible. Visual inspections are performed during each refueling outage. If a heater fails and becomes stuck within the sleeve, it may impose abnormal stresses and introduce a cold worked surface on the inside diameter of the sleeve. All sleeves with stuck heaters will have the intemals of the heater removed during the next available work window to reduce further 14
Document 90022 Revision 2 damage to the sleeve until the heater can bc amoved from the pressurizer. When a stuck heater is removed from a heater sleeve, the inside surface of the sleeve will be tested for flaws with eddy current equipment in the areas adjacent to the J-groove partial penetration attachment weld. SCE will monitor the performance of heater sleeves within the industry and use available information to determine when additional mitigation or -
inspection activities are appropriate, 65 Control Element Drive Mechanism / Incore Instrument Nozzles The CEDM and ICI nozzles are visually inspected each refueling outage with insulation removed to the extent possible. The exception to this is during outages when non destructive examinations (eddy current with additional UT and PT as appropriate) are performed on the inside of the nozzles in the areas adjacent to the J-groove partial penetration attachment weld. These exams can be performed with remotely controlled robotic equipment staged underneath the reactor head. Units 2 & 3 are scheduled for 100% inspections in the Cycle 10 refueling outages.
M U
15
Document 90022 Revision 2
7.0 REFERENCES
7.1
" Evaluation of Pressurizer Penetrations and Evaluation of Corrosion After Unidentified Leakage Develops", CEOG Task 700, January 1992.
7.2
" SONGS 3 Pressurizer Level Instrument Nozzle Leakage", RCE 92-019, June 1992.
7.3 Material Technology Institute," Guidelines For Control of Stress-Corrosion Cracking of Nickel-Bearing Stainless Steels and Nickel-Base Alloys", Manual No.1, Columbus, Oli,1978.
7.4
" Evaluation of Pressurizer Heater Sleeve Susceptibility to Primary Water Stress Corrosion Cracking", GOG GN 393-P, November 1989.
7.5
" Failure /.nalysis of ANO-2 Ruptured Pressurizer licater and Cracked Sleeve", CE-NSPD-406, July,1987.
7.6
" Instruction Manual Pressurizer, San Onofre Unit 2", SO23-919-68 Rev.1, April,1977.
7.7 "NRC Generic Letter 97-01: Degradation of Control Rod Drive Mechanism Nozzle and Other Vessel Closure IIead Penetrations" April 1,1997.
7.8 "GOG Response to NRC Generic Letter 97-01 Degradation of GM' Nozzle and Other i'assel Closure IIead Penetrations", CEOG Tas k 992, CE NPSD-1085, July i.97.
7.9
" Safety Evaluation of the Potential For s nd Consequence of Reactor Vessel liead Penetration Alloy 600 ID Initiated Nozzle Cracking", GOG Task 744, CEN-607, May 1993.
7.10
" Assessment of Pressurized Water Reactor Control Rod Drive Mechanism Nozzle Cracking",
NUREG/CR-6245, October 1994.
7.11
" Reactor Coolant System inconel Nozzle Inspection", SO23-V-8.16, June 7,1993.
7.12
" Unit 2 Operating License & Technical Sp cifications", LCO 3.4.13.a.
7.13
" Material Sr ification for Alloy 690 Bar Stock", SO23-411-56, Rev. O May 31,1996.
7.14 "RCS Ho. Leg Pressure Tap Nozzle", M-DSC 279, July 29,1993.
7.15
" Corrosion Evaluation for Base Metal Exposure within RCS Nozzles",1814-AA008-M001, Revision 1, B & W NuclearTechnologies Docurnent identifier 51-1235153-00, March 15,1995.
7.16
" Assessment of the Inconel-600 Nozzle inspection & Replacement Program and Decision Process Leading to the March,1997 Nozzle Failure in Unit 2", SEA 97-002, April 9,1997.
16
U Document 90022 Revision 2.1 Table 1 17
UNIT 2 ALLOY 600/690 NOZZLES PRESSURIZER Procedure ID Equipment ID PC No.
IIeat No.
Nominal size (in.)
Drawing No.
IIistory 20 S2-1201-407-13 NX 4411 1.062 x 6 86 SO23-919-16; DCNs 2 & 4 MI 316 SO23-919-46 21 P 1201-407-13 NX 4411 1.062 x 6.86 SO23-919-16; DCNs 2 & 4 ML-315 SO23-919-46 22 2TE0101 407-07 54318 1.315 x 13.625 SO23-919-16; DCNs 3 & 7 1987-Preventative replacement with A600 material K 248 SO23-919-46; DCNs 1 & 4 Original A600 material heat had high susceptibility Alloy 690 to cracking. C.Chiu letter to JT Reilly,1 I,05/86.
MO 87032254000. FCN S3098M.
1997 - Replaced nozzle with Alloy 690 ifalf nozzle, weld pad and exteriorj-groove weld. NCR 970300092: MO 97030334 23 S2-1201-407-10 NX 4411 1.062 x 7.86 SO23-919-16. DCNs 2,5 & 6 1992-Boric acid indications found Temporary ML-313 B
Alloy 690 SO23-919-46; DCN 2 replacement with A690. from outside, weld pad.
NCR 920300153, NCR 920300154. MO 93012200000. FCN F4420M.
1993-Replaced nozzle per original uesign with Alloy 690 nozzle and I-52 weld m sterial.
24 S2-1201-407-10 NX 4411 1.062 x 7.86 SO23-919-16 DCNs 2 & 6 1993-Replaced nozzle per original design with M1 311 C
Alloy 690 SO23-919-46; DCN 2 Alloy 690 nozzle and I-52 weld material.
25 S2-1201-407-10 NX 7630 1.062 x 7.86 SO23-919-16, DCNs 2,5 & 6 1992-Crack indications found. Temporary MI 314 D
Alloy 690 S023-919-46; DCN 2 replacement with A690, from outside, weld pad.
NCR 920300153, NCR 920300154. MO 93012200000. FCN F4420M.
1993-Replaced nozzle per original design with Alloy 690 nozzle and I-52 weld material.
26 S2-1201-407-10 NX4411 1.062 x 7.86 SO23-919-16 DCNs 1,2 & 6 1993-Replaced nozzle per original design with ML-312 A
Alloy 690 SO23-919-46; DCN 2 Alloy 690 nozzle and I-52 weld material.
Table 1, page I
UNIT 2 ALLOY 600/690 NOZZLES Procedure ID Equipment ID PC No.
Heat No-Nominal size (in.)
Drawing No.
IIistory RCS PIPING: E099 HOT LEG (#1) 13 2PITT0978-4 506-11 NX 7630 0.993 x 8.875 S O 23-923-5,13, 15 16 2PDT0978-1 506A-NX 7630 -
0.993 x 8.875 SO23-923-5, DCN 1; 1993-Replaced with A690. Replaced from outside, 1I repheed by SO23-923-13. DCN 2; weld pad. NCR 930600133; MO 93061906000; Alkrj690 SO23-923-15 MO 93%I876000. FCN F8375M.
18 2PDIV978-2 506-11 NX7630 0.993 x 8.875 S O 23-923-5. 13,15 21 2PDT0978-3 506-11 NX7630 0.993 x 8.875 S O 23-923-5, 13,15 20 S2-1201-506-14 NX7630 1.050 x 8.875 S O23-923-5,13,15 M1 023 12 2TE0112-3 509-05 9294 0.993 x 8375 S O 23-923-5, 15,19 14 2TE0112-4 509-05 9294 0.993 x 8375 S O 23-923-5, 15,19 15 2TE011IX-1 509-05 9294 0.993 x 8375 S O23-923-5,15,19 17 2TE0112-2 509-05 9294 0.993 x 8375 S O 23-923-5,15, 19 19 2TE0112-1 509-05 9294 0.993 x 8375 S O 23-923-5, 15, 19 22 2TW0138A 717 NX 9915.
0.993 x 8375 S O23-923 4 9,70 23 2TWO138B 717-02 NX 9915 0.993 x 8375 S O 23-923 4 9,70 t
24 2Th0138C 717-02 NX 9915 0.993 x 8375 SO23-923 4 9,70
.l 25 2TW0138D 717-02 NX 9915 0.993 x 8375 SO23-923 49,70 26 2TWOI38E 717-02 NX 9915 0.993 x 8375 SO23-923 49,70 I
27 ZrWOI38F 717-02 NX 9915 0.993 x 8375 S O 23-923-69,70 RCS PIPING: Eb88 IIOT LEG (#2) 11 2PDT-0979-3 506-11 NX 7630 0 993 x 8.875 S O23-923-5, 13, 15 14 2PDT-0979-4 506-11 NX 7630 0.993 x 8.875 S O23-923-5, 13,15 15 2PDT-0979-2 506-11
- NX 7630 0.993 x 8.875 S O 23-923-5,13,15 Table 1, page 2 i
UNIT 2 ALLOY 600/690 NOZZLES Procedure ID Equipment ID PC No.
Ileat No.
Nominal size (in.)
Drawing No.
IIistory 17 2PITT-0979-1 506-11 NX 7630 0.993 x 8.875 S O 23-923-5.13,15 18 S2-1201-506-14 NX 7630 1.050 x 8.875 S O 23-923-5,13,15 MI 065 10
'ITE-0122-2 509-05 7617-4 0.993 x 8375 S O 23-923-5. 15, 19 12 2TE-0122-1 509-05 7617-4 0.993 x 8375 S O23-923-5,15.19 13 2TE-0121X2 509-05 7617-4 0.993 x 8375 S O 23-923-5.15,19 16 2TE-0122-3 50945 7617-4 0.993 x 8375 S023-923-5.15,19 19 2TE-0122-4 509-05 7617-4 0.993 x 8375 S O 23-923-5. 15. 19 20 2TW-0139A 71742 NX 9915 0.993 x 8375 S O23-923 4 9,70 21 2TW-0139B 717-02 NX 9915 0.993 x 8375 SO23-923 4 9.70 22 2TW-0139C 717-02 NX 9915 0.993 x 8375 S O23-923-69,70 23 2TW-0139D 717-02 NX 9915 -
0.993 x 8375 3023-92349,70 24 2TW-0139E 717-02 NX 9915 0.993 x 8375 SO23-92.3 59,70 25 2TW-0139F 717-02 NX 9915 0.993 x 8375 SO23-923-69,70 RCS PIPING: P001 COLD LEG (504-01) 15-P001-Rx 2TE-9178-3 509-05 7760-4 0.993 x 8375 SO 23-923-6,16 16-P001-Rx 2TE-0111YI 509-05 7617-4 0.993 x 8375 SO23-923-6,16 17-P001-Rx 2TE-9178-1 509-05 7617 4 0.993 x 8375 SO23-923 4.16 RCS PIPING: P002 COLD LEG (505-04)
I l-P002-Rx 2TE-9179-2 509-05 7760-6 0.993 x 8375 SO23-923-7.16 12-P002-Rx 2TE-0121Y2 509-05 776 %
0.993 x 8375 S O 23-923-7,16 13-P002.Rx 2TE-9179-4 509-05 7760 4 0.993 x 8375 SO23-923-7.16 Table 1, page 3
UNIT 2 ALLOY 600/690 NOZZLES Procedure ID F2;uipment ID PC No.
IIeat No.
Nominal size (in.)
Drawing No.
IIistory RCS PIPING: P903 COLD LEG (505-01) 13-P003-Rx 2TE-9178-2 509-05 7760-4 0.993 x 8375 S O23-923-7.16 14-P003-Rx 2TE4115-2 509-05 7760-4 0.993 x 8375 SO 23-923-7.16 15-P003-Rx 2TE-9178-4 509-05 7760-4 0.993 x 8375 SO23-923-7.16 RCS PIPING: P004 COLD LEG (504-04) 13 -P004-Rx 2TE-9179-1 509-05 7617-4 0993 x 8375 S O 23-923-6,16 14 -P004-Rx 2TE-0125-1 509-05 7617-4 0.993 x 8375 SO23-923-6.16 15 -P004-Rx 2TE-9179-3 509-05 7617-4 0.993 x 8375 S O 23-923-6.16 STEAM GENERATOR PDT Nozzles E088 23 2PDT0979-1 110-11 NX 6296-2 1.019 x 9 %;
S O23-915-14.36,40.139 1.050 x 6 24 2PDT0979-2 110-11 NX 6296-4 1.019 x 9 %;
SO23-915-14.36.40.139 1.050 x 6 25 2PDT0979-3 110-11 NX 6296-6 1.019 x 9 %;
S O 23-915-14.36,40,139 1.050 x 6 26 2PDT0979-4 110-11 NX 6296-7 1.019 x 9 %;
SO23-915-14.36,40.I39 1.050 x 6 E089 23 2PIR0978-1 110-11 NX 6296-1 1.019 x 9 %;
SO23-915-14.35,39.139 1.050 x 6 24 2PDT0978-2 110-11 NX 6296-3 1.019 x 9 %;
5023-915-14.35,39.139 1.050 x 6 25 2PDTD978-3 110-11 NX 6296-5, 1.019 x 9 %;
S O23-915-14.35.39.139 1.050 x 6 26 2PUT0978-4 110-11 NX 6296-8 1.019 x 9 %;
SO23-915-14.35.39.139 1.050 x 6 Table 1, page 4
UNrr 2 ALLOY 600/690 NOZZLES PRESSURIZER IIEATER SLEEVES Location PC No.
IIeat No.
NominalSize (in.)
Drawing No.*s Iristory A1 420-19 NX 4886 1.660 x 14 '!s SO23-919-1,2. M. 33,46. 85 A2 420-19 NX 4886 1.660 x 14'/s S O23-919-1.2.30.33.46.85 A3 420-19 NX 4886 1.660 x 14 '!:
SO23-919-1,2.30.33,46,85 A4 420-19 NX 4886 1.660 x 14 '/s SO23-919-1.2.30.33.46.85 B1 420-19 NX 4886 1.660 x !4 '/s SO 23-919-I.2.30,33,46.85 B2 420-19 NX 4886 1.660 x 14 '/s S O 23-919-1,2.30,33,46,85 C1 420-19 NX 4886 1.660 x 14 '/s S O23-919-1.2.30.33.46,85 C2 420-19 NX 4886 1.660 x 14 '/s SO 23-919-l.2.30.33.46.85 C3 420-19 NX 4886 1.660 x 14 '/s SO23-919-1,2.30.33.46,85 C4 420-19 NX 4886 1.660 x 14 /s SO23-919-1.2.30.33.46,85 5
D1 420-20 NX 4886 1.660 x 15 SO23-919-1.2.30.33.4 i.85 D2 420-20 NX 4886 1.660 x 15 S O 23-919-1.2.30,33,46.85 D3 420-20 NX 4886 1.660 x 15 SO23-919-1. 2. 30,33,46. b.,
D4 420-20 NX 4886 1.660 x 15 SO23-919-1,2.30,33,46,85 El 420-21 NX 48S6 1.660 x 15 '/s SO 23-919-1,2.30,33.46,85 E2 420-21 NX 4886 1.660 x 15 '/s SO 23-919-1,2.30,33,46.85 F1 420-21 NX 4886 1.660 x 15 '/s S O23-919-1.2.30.33.46.85 F2 420-21 NX 4886 1.660 x 15 '/s S O23-919-1,2.30.33.46,85 F3 420-21 NX 4886 1.660 x 15 '/s S O23-919-1.2.30,33,46.85 F4 420-21 NX 4886 1.660 x 15 'is SO23-919-1,2.30,33.46,85 G1 420-22 NX 48d6 1.660 x 16 '/4 S O 23-919-1.2.30.33,46.85 l
l Table 1. page 5
4 L
UNrr2 ALwY60lM690 NOZZLES 4
1
'G2 t-420 22 i NX 4886 -
1.660 x 16 '/4 S O 23-919-1,2.30,33,46,85-G3~
420-22 NX 4886 -
-1.660'x If '/4 S O 23-919-1.2.30,33,46,85 l
i 8
G4 420-22 NX 4886 1.660 x 16 /41 SO23-919-1,2,30.33,46,85 i '
HI
~20 NX 4886 l 1.660 x 16 '/4 SO23-919-1,2,30.33.46,85 H2' 420-23:
NX 4886
' l.660 x 16 '/4 SO23-919-1.2,30.33,46,85 j)
- H3 420-23 NX 4886 1.660 x 16 '/4 SO 23-919-1.2.30,33,46.85 H4 420 NX 4886:
1.660 x 16 '/4 SO23-919 1,2.30,33,46.85 J13 420 NX 4886,
- 1.660 x 18 '/s.
S O23-919-1,2,30,33,46,85-
'J2.
420-24 NX 4886 1.660 x 18 '/s SO23-919-1.2.30,33,46,85 i
2 Note: There are two 2" x 18 '/s" nozzles in the warehouse, mat. code 027-70964
[
i 4
9 Table 1, page 6
- i
L
^-
UNrr2 Anov60W690 Nozzlzs :
u CEDM NOZZLES -
/
CEDM Nonle No ~
Heat No.'.
E Code No. -
' Yield Strength Cadma AnnealTemperature Tangent Angle -
1,
- A6777 C4441 ~35000 0.04 1625F -
0~
l 1
.. e
' 2:
A6777 '
- C4441-1 35000'
' O.04 1625F 7.73 3
. A6785 C-6441 56000 0.065 -
1625F
~ 7.73
-.4
' A6777 -
C4441-1 35000' O.04 1625F 10.97 4
j.
i
- 5 ~'
, A4542 '
C4441-2 52000
'O.05 1625F 10.97 r
7 6-A5980 C.6441-3
.39000 0.06 1625F 10.97 j
7 A6926 C4441-4 52000 0.068 1625F 10.97'
- 8 A58.t9 C44414 59000 0.054 1625F 15.61 19 -
A5980-C4441-3 39000 0.06 1625F 15.61 10 A5980-C4441-3 39000 0.06 1625F 15.61 o
1I A5849 C4441-6 59000 0.054 1625F 15.61 1
12 A5980 C4441-3 39000 0.06 1625F 17.50 13 A5980 C4441-3 39000 0.06 '
1625F 17.50
- .. r 14 A5980 C4441-3 39000 0.06
-1625F 17.50 v
15 A5980 C4441-3
'39000 0.06 1625F-17.50 l'
16 A6926-C4441-4
- 52000 0.068 1625F.
17.50 I
17 A6926 C-6441-4' 52000 0.068 1625F 17.50 q
18 A6926 C-6441 52000 0.068 1625F 17.50 i
19 A6926 C4441-4 52000 0.068 1625F 17.50 20
.A6777-C-6441-1 35000 0.04 1625F 22.36 t
21
'A6777 C4441-1 35000 0.04 '
1625F 2236 4
Table 1, page 7 a
w a
v
'm
- m. g m
-m v
v e-w
.,v-51 w-v.
4 e
-w
UNIT 2 ALI8Y 600/690 NOZZLES 1
CEDM Nozzle Na IIcat No.
Code No.
Yield Strength Carbon AnnealTemperature Tangent Angle l
22 A6777 C-6441-1 35000 0.04 1625F 22.36 23 A6777 C-6441-1 35000 0.04 1625F 22.36 1
l 24 EO1088 C-6449-4 39000 0.083 NOT AVAIL 23.80 j
25 EO1088 C-6449-4 39000 0.033 NOTAVAIL 23.80 26 EO1547 C-6449-1 49000 0.078 NOTAVAIL 23.80 27 EO1547 C-6449-1 49000 0.078 NOT AVAIL 23.80 28 EO1090 C-6449-6 38500 0.063 NOTAVAIL 25.17 29 EO1547 C-6449-1 49000 0.078 NOT AVAIL 25.17 30 A09321 C-6449-5 48000 0.06 NOTAVAIL 25.17 31 E01547 C-6449-1 49000 0.078 NOTAVAIL 25.17 32 EO1547 C-6449-1 49000 0.078 NOTAVAIL 25.17 33 A09321 C-6449-5 48000 0.06 NOT AVAIL 25.17 34 EO1547 C-6449-1 49000 0.078 NOT AVAIL 25.17 35 EO1547 C-6449-1 49000 0.078 NOT AVAIL 25.17 36 EO1547 C-6449-1 49000 0.078 NOT AVAIL 29.01 37 EO1547 C-6449-1 49000 0.078 NOT AVAIL 29.01 38 EO1547
'6449-1 49000 0.078 NOT AVAIL 29.01 39 EO1547 C-6449-1 49000 0.078 NOTAVAll 29.01
[
40 EO1547 C-6449-1 49000 0.078 NOT AVAIL 29.0i f
f 41 EOl429 C-6449-9 39000 0.072 NOT AVAIL 29.01 42 EO3045 M4119-4 37500 0.075 NOT AVAIL 29.01 43 R1948 C-6449-10 45000 0.063 NOT AVAIL 29.01 Table 1, page 8
UNIT 2 ALLOY 600/690 NOZZLES GnM Nozzle No.
IIest No.
Code No.
Yield Strength Carbon Annest Ternperature Tangent Angle 44 E01429 C4449-9 30000 0.072 NOT AVAIL 32.55 45 E01547 C.6449-1 49000 0.078 NOT AVAIL 32.55 46 EO1547 C4449-1 49000 0.078 NOTAVAIL 32.55 47 EOl429 C-6449-9 39000 0.072 NM AVAIL 32.55 48 EOl144 C.6449-8 47000 0.07 NOTAVAIL 33.68 49 EOl144 C-6449-8
. 47000 0.07 NOTAVAIL 33.6S 50 EOll44 C4449-8 47000 0.07 NOTAVAIL 33.68 51 EO1547 C4449-1 49000 0.078 NOT AVAIL 33.68 52 EOl142 C-6449-7 54000 0.08 NOTAVAIL 33.68 53 EO1142 C4449-7 54000 0.08 NOT AVAIL 33.68 54 EOl142 C4449-7 54000 0.08 NOT AVAIL 33.68 55 EO1547 C4449-1 49000 0.078 NOT AVAIL 33.68 56 EO1547 C-6449-1 49000 0.078 NOTAVAIL 34.80 57
' EO1547 C4449-1 49000 0.073 NOTAVAIL 34.80 58 EO1547 C4449-1 49000 0.078 NOT AVAIL 34.80 l
59 E01547 C-6449-1 49000 0.078 NOTAVAlL 34.80 60 EO1547 C-6449-1 49000 0.078 NOT AVAIL 36.98 61 E01547 C4449-1 49000 0.078 NOTAVAIL 36.98 62 EO1547 C-6449-1 49000 0.078 NOT AVAIL 36.98 63 EO1547 C-6449-1 49000 0.078 NOT AVAIL 36.98 64 EO1547 C4449-1 49000 0.078 NOT AVAIL 36.98 65 EO1547 C-6449-1 49000 0.078 NOTAVAIL 36.98 Table 1, page 9
w
. ~
.A 4
y
. UNIT 2 Auny 600Edo NOZZLES -
m CEDM Nonle No.-
Heat No.'
Code No.
Yield Strength Carbon AnnealTenperatum Tangent Angle -
- 66 '-
1 ; E01547 -
C-6449-1 49000 0.078 NOTAVAIL 36.98-
- 67 '
EO1547 '
C-6449-1 49000 0.078-
. NOT AVAIL :
36.98 1-68 EO1547 C-6449-1.
49000 0.078 NOT AVAIL' 42.27-69 EO1429
- C-6449 39000 0.072
- NOT AVAIL
- 42.27.
70-E01547 :
C-6449-1 49000 0.078 NOTAVAIL
' 42.27 171 EO1429 C-6449-9' 39000 0.072 NOTAVAIL
- 42.27 72 EOl364 C-6449-2 52000-0.08 NOTAVAIL
' 42.27' J
f 73 EOl364 C-6449-2
'52000 0.08 NOTAVAIL 42.27 -
t j
74
' EOl429
' C-6449-9
-39000 0.072 NOTAVAIL
- 42.27
' 75 EO1429
. C-6449-9 39000 0.072 NOTAVAIL 42.27 76'
- EO1419
' C.6449-9 39000 0.072 NOT AVAIL 42.27-3 77 EOl429 C-6449-9 39000-0.072 NOTAVAIL 42.27 t
78 EO1429
- C-6449-9 39000 0.072 NOT AVAIL '
- 42.27 79
' EO1547
' C-6449-1 49000 0.078 '
NOTAVAIL
- 42.27 1-80 EOl364 '
C-6449-2 52000 0.08 NOTAVAIL 4331 81 E01547
' C-6449-1 49000 0.078 NOT AVAIL -
4331 82 EO1547 -
' C-6449-1 49000 0.078 NOTAVAIL 4331-l' 83 EO1547 C-6449 49000 0.078 NOTAVAIL 4331 l
84 EOI177 C-6449-3 36000 0.088 NOTAVAIL 4331 85 EO1547
' C-6449-1 49000 0.078 NOT AVAIL-
- 4331 86 E01364 C-6449-2 52000
-0.08 NOT AVAIL '
' 4331-87 EO1547
- C-6449-1 49000 0.078
'NOT AVAIL 4331 l
Table 1, page 10
[
-Y'y
'-a-qf g '*
3*iT'W Y
if "as--
f'#
B f
'W
M
'FTT
+M W 31u
--C
"lF.P-g'
- %-w w^"
W Nukre 7-1
'T--
a v
UNIT 2 Aumy600490Norim,
i L-CEDM Nozzle No.'
- Heat No.
Code No. '
Yiekt Strength Carten AnnealTensperasure Tangent Angle.
i
'88
- EO1547 C-6449-1 49000 0.078 -
NOTAVAIL 49.55 89^
EOl749 M-4119 '43000 ;
' O 07 NOTAVAIL
" 49.55.
90 -
- EO1547 C-6449-1 49000 0.078 -
NOTAVAIL 49.55
- s; 91 EO1547 -
C-6449-1 49000 0.078
. NOT AVAIL f49.55 J.
4 t
s i :i
- [
c ICI NOZZLES l
h 11CI Nozzle No.
Heat No-
. Code No.
YickiStrength Carbon AnnealTensperature Tangest Angle
- t
? -
92 NX 2718
- C-6406 38000 0.07.
' NOT AVAIL
~55.06 '
- i 93 NX 2718 -
C-6406-1
'38000 0.07 NOTAVAIL l 55.06 -
94 NX 2718 C-6406-1
.38000 0.07 NOT AVAIL'
' 55.06 95 NX 2718 C-6406-1 38000 0.07 NOT AVAIL
'55.06 96 NX 2718 C-6406-1
'38000 0.07 NOTAVAIL
'55.06 l
97 NX 2718 C-6406-1 38000-0.07-NOT AVAIL.
55.06 i
1 98 NX 2718
- C-6406-1.
38000 0.07 NOTAVAIL 55.06 99
.NX 2718 -
C-6406-1 38000 0.07-NOTAVAIL 55.06 100 NX 2718 -
C-6406-1 38000
' O.07 NOTAVAIL
$5.06
. 101 NX 2718 C-6406-1.
. i 38000 0.07 NOT AVAIL '
55.06 h
4
- t i
l i
Table 1, page 11 l
f 4
.a.
Document 90022 Revision 2.2 Table 2 18
UNTT3 Au.ov600K>90Nozzus Pressurizer Procedure ID Equipment ID PC-No.
Ileat No.
Nominal size (in.)
Drawing No.
IIistory 20 S3-1201-407-13 NX 7630 1.062 x 1.86 SO23-919-77; l
MI 316 83 DCN's 1,2,4 21 S3-1201-407-13 NX 7630 1.062 x 6.86 SO23-919-77; MI 315 83 DCN's 1,2,4 22 3TE0101 407-07 54318 1.315 x 13.625 5023-919-77;83;103 1988-Preventive replacement with A600 material.
K248 Ileat 54318 had high.nsceptibility to PWSCC 23 S3-1201-407-10B 54318 1.062 x 8.25 SO23-919-77;83,103 1987-Preventive replacement with A600 material.
M1-312 94758 Ileat 54318 had high susceptibility to PWSCC.
A690 */A600 1992-Evidence of leakage found, nozzle replaced.
filter 1995-Preventive replacement of A600 weld material.
A690 24 S3-1201-407-10C 54318 1.068 x 8.25 S O23-919-77;83,103 1986-Evidence ofleakage found, nozzle replaced ML-314 NX 0571 from ID per original design. NCR 3-1482 A690 */A600 1992-PT exam identified cracks, nozzle replaced filler 1995-Preventive. replacement of A600 weld material A690 25 S3-1201-407-10D 54318 1.101 x 8.25 S O 23-919-77;83,103 1987-Preventive replacement with A600 material MI 313 94758 IIcat 54318 had high susceptibility to PWSCC-A690 */A600 1992-Preventive replacement of nozzle.3 of 4 steam filler space nozzles found to be cracked.
A690 1995-Evidence of leakage found, nozzle replaced.
26 S3-1201-407-10A NX 7630 1.066 x 8.25 SO 23-919-77;83,103 1992-PT exam identified cracks, nozzle replaced.
M1 311 A690 */A600 1995-PT exam ioentified crack in weld material, filler replaced nozzle.
A690 Table 2, page 1
_____.---_-,_____.----.---_-.--___--,.s
.,m,.
y
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.m-,._
4
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4 4
.c a
u.
1 i
J UNrr3 Anov60lW90Nozzus 3
I 1
Procedum ID" Equipenent ID.
PC-No.
.. Heat No.
Nonunal size (in.)
Drawing No.
Hissory
[
f RCS PIPING: E809 HOT LEG (#1)
. I8 3PDT0978-1 506-11
- NX 7630 0.993 x 8 '/s SO23-923-29,71,73 1997-Half nozzle repair -
. Alloy 690 16 '
3PDT0978-2..
506-11 NX 7630 0.993 x 8 '/s S O 23-923-29,71,73 13 3PDT0978-3 506-11 NX 7630 0.993 x 8 '/s SO23-923-29,71,73 i
Lt 21-3PDT0978-4 506-11
- NX 7630 0.993 x 8 '/s S O23-923-29.71,73
.i
- 20 S3-1201.
506-14 '
NX 7630 -
1.050 x 8 '/s S O 23-923-29,71,73 MI 023 12 37E0112-2 509-05 9294 0.993 x 8 8/s SO23-923-29.73,80 k
i
'14 3TE0112-1
.509-05 9294 0.993 x 8 8/s S O 23-923-29,73,80 l
)
15 3TE0111X-1 509-05 9294 0.993 x 8 '/s S O23-923-29,73,80 l
17 3TE0112-3 509-05 9294 0.993 x 8 '/s S O 23-923-29,73,80 '
19 3TE0112 509-05 7760 4 0.993 x 8 '/s S O 23-923-29,73,80 l
t 22 3TW0138A 717-02.-
NX 99:5 0.993 x 8 '/s S O23-923-69,70 1997-Halfnozzleplugr pair
[
Alloy 690 I
23 31W0138B 717-02 NX 9915 0.993 x 8 '/s SO23-92349,70 l
24 3TW0138C -
717-02 ~
NX 9915 0.993 x 8 '/s SO23-92349,70 i
l 25 3TW0138D 717-02 NX 9915 0.993 x 8 '/s S O23-923-69,70
{J 26 3TW0138E 717-02 NX 9915 0.993 x 8 '/s SO23-923-69,70 1997-Half nozzle plug repeir ~
l
{
Alloy 690
}
i-27 3TWO138F 717-02 NX 9915 '
O.993 x 8 '/s S O23-923-69,70 i
i j
j Table 2, page 2 Lo
(
e...
j l
I UNIT 3 ALLOY 600Nr00Nozz1J3 Procedure ID E wiyuereID PC-No.
IIcar No.
Nominal size (m.)
Drawing No.
HStcry RCS PIPING: E088 IIOT LEG (f2) 14 3PDT-0979-1 506-11 NX 7630 0.993 x 5 SO 23-923-29.71.73 1997-Ilalf nozzle repair Alloy 690 11 3PDT-0979-2 506-11 NX 7630 0.993 x 5 FJ-923-29. 71. 73 1997-Ilalf nozzle repair Alloy 690 15 3PDT-0979-3 506-11 NX 7630 0.993 x 5 S O 23-923-29.71.73 1997-IIalf nozzle repair Alloy 690 17 3PDT-0979-4 506-1?
NX 7630 0.993 x 5 50 23-923-29.71.73 199.tllalf nozzle repair Alloy 690 1S S3-1201-506-14 NX 7630 1.050 x 5 5 023-923-29.71.73 ML-065 16 3TE-0122-2 50945B 9294 0.993 x 8 'Is SO 23-923-29.73.
1997-IIaff nozzle repair Alloy 690 80 DCN #3 19 3TE-0122-1 509-05A 9294 0.993 x 8 'is SO23-923-29.73.80 19c5-ilalf nozzle repair Alloy 690 13 3TE-0121X2 50905E 9294 0.993 x 8 '/s SO23-923-29. 73. 8 J 195'7-IIIIf nozzle repair Alloy 690 10 3TE-0122-3 509-05 9294 0.993 x 8 'Is SO 23-923-29,73.80 12 3TE-0122-4 5094)5 9294 0.993 x 8 '/s S O 23-923-29.73.80 20 3TW-0139A 717-02 K 259 0.993 x 8 '/s 5023-92349.70 21 3TW-0139B j 717-02 K 259 0.993 x 8 '/s SO23-923-69.7C 22 3N-0139C 7i7-02 K 259 0.993 x 8 '/s S O 23-923-69.70 23 3TW-0139D 717-02 NX 9915 0.993 x 8 '/s SO23-92349.70 24 3TW-0139E 717-02 K 259 0 993 x 8 '/s SO23-923-69.70 2';
3TW-0139F 717-02 K 259 0.993 x 8 '/s SO23-92349.70 Table 2. page 3
UNTr3 ALLOY 60GYr>0 NOZZLES Procedure ID Equipment ID PC No.
Heat No.
Nominal size (in.)
Drawing No.
History
~
RCS PIPING: P001 COLD LEG (504-01) s 15 3TE-9178-1 509-05 9294 0.993 x 8 '/s S O23-923-30.72.80 16 3TE-011IYI 509 @
9291 0.993 x 8 '/s S 0 23-923-30.72.80 17 3TE-9178-3 50945 9294 0.993 x 8 'is 5023-923-30.72.80 RCS PIPING: P002 COLD LEG (505-04) 1E 3TE-9179-4 509 4 9294 0.993 x 8 '/s SO23-923-31.72.80 12 3TE-0121Y2 509-05 9294 0.993 x 8 'is S O23-923-31.72.80 1997. Half nozzle repa:r A690 13 3TE-9179-2 509 4 9294 0.993 x 8 '/s 5023-923-31.72.80 RCS PIPING: P903 COLD LEG (505-01) 13 3TE-9178-4 509 4 9294-0.993 x 8 '/s S O23-9 & 31.72.80 14 3TE-0115-2 509-05 9294 0.993 x 8 '/s 5023-923-31.72.80 15 3TE-9173-2 509-05 9294 0.993 x 8 '!:
SO23-923-31.72.80 RCS PIPING: P904 COLD LEG (504-04) 13 3TE-9179-3 509 2 9294 0.993 x 8 '/s S O23-923-30,72.80 14 3TE-0125-1 5'9-05 9294 0.993 x 8 '/s S O 23-923-30.72.80 15 3TE-9179-1 509 4 9294 0.993 x 8 'Is S O 23-923-30.72.80 STEAM GENERATOR PDT Nozzles E088 23 3PDT0979-1 I10-11 NX 3703 G-3 1.019 x 9 %;
S O 23-915-41,138.139 1.050 x 6 24 3PI7IV979-2 I10-11 NX 3703 G-7 1.019 x 9 %:
5023-915-42.133.139 1.050 x 6 Table 2, page 4
1 UMrr3 h ~88598Nors:1x Procedme ID' Eqaipmes ID PC-No. '
Heat No. '
Nouimal size (ia.)
Drawiag No.
Hiseory
.25 3PDT0979-3 110 NX 3703 G-5 S O 23-915-42.138.139 1.019 x 9 %:
1.050 x 6
.26 3P!7T09794 110-11:
NX 3703 G-1 1.019 x 9 %:-
S O 23-915 4 2,138.139 1.050 x 6
..23 2PDTU978-1 110 11 NX 3703 G-2 1.019 x 9 %: -
S O 23-915 4 1. 138,139 E089-1.050 x 6 i
24 3PI7ID978-2 110 NX 3703 G4 1.019 x 9 %
S O23-915 4 1,138.139 I 050 x 6
-25 3PUT0978-3 I10-l'1 NX 3703 G-6 ID19x 9 %:
S O 23-915 4 1,138. 139 1.050 x 6 26 3PUIV978-4 110-11
' NX 3703 G-8 1.015 x 9 %:
S O 23-915 4 1.138.139
[
- F 1.050 x 6 e
i,
. i i.
I 1
I
[
i i
A 1
i t
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t t
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Table 2, page 5 -
1 1
~...._:._....,__.. ~..
2
UsTr3 Anov 600490NozzzJs PRESSURIZER HEATER SLEEVES Ixcation PC-No IIcar No.
Nozzle Size, inches Drawing No.
liistory AI 420-19 NX 7545 1.660 x 14 'is 5023-919-74.77 A2 420-19 NX 7545 1.660 x 14 '/s 50 23-919-74.77 A3 420-19 NX 7545 1.660 x 14 '/s S023-919-74.77 A4 420-19 NX 7545 1.C60 x 14'/s 5023-919-74.77 B1 420-19 NX 4836 1.660 x 14 '/s SO23-919-74.77 B2 420-19 NX 7545 1.660 x 14'/s 5023-919-74.77 C1 420-19 NX 7545 1.660 x 14 '/s 5023-919-74.77 C2 420-19 NX 7545 1.660 x 14 '/s S O23-919-74.77 C3 420-19 NX 4836 1.660 x 14 '/s 5023-919-74.77 C4 420-19 NX 7545 1.660 x 14 '/s S O 23-919-74.77 D1 420-20 NX 4886 1.660 x 15 S O 23-919-74.77 D2 4?0-20 NX 4886 1.660 x 15 SO23-919-74.77 D3 420-20 NX 4886 1.660 x 15 SO 23-919-74.77 D4 420-20 NX 4886 1.660x15 SO23-919-74.77 El 420-21 NX 7545 1.660 x 15 'Is S O23-919-74.77 E2 420-21 NX 4886 1.660 x 15 '/s SO23-919-74.77 F1 420-21 NX 7545 1.660 x 15 'Is S023 919-74.77 F2 420-21 NX 7545 1.660 x 15 '/s S O 23-919-74.77 F3 420-21 NX 7545 1.660 x 15 '/s SO23-919-74.77 F4 420-21 NX 7545 1.660 x 15 '/s SO',-919-74.77 Table 2, page 6
LSTr3 Anay60GM60 Nozztts G1 420-22 NX 4886 1.660 x 16 '/4 SO23-919-74 77 G2 420-22 NX 4886 1.660 x 16 '/4 S023-919-74.77 G3 420-22 NX 4886 1.660 x 16 '/4 S O 23-919-74,77 G4 420-22 NX 4886 1.660 x 16 '/4 5023-919-74,77 III-420-23 NX 4836 1.660 x 16 '/4 S O23-919-74,77' 112 420-23 NX 4886 1.660 x 16 '/4 SO23-919-74,77 113 420-23 NX 4886 1.660 x 16 '/4 S O 23-919-74,77 H4 420-23 NX 4886 1.660 x 16 '/4 S 023-919-74,77 JI 420-24 NX 4886 1.660 x 18 '/s S O23-919-74,77 J2 420-24 NX 7545 1.660 x 18 '/s SO23-919-74,77
)
i l
Note: There are :wo 2" x 18 '/s" nozzles in the.h mat. code 027-70964.
l l
i 1
i Table 2, page 7 i
i
. UNrT3 Aum 600MGNorn n f
r I-CEDM NOZZLES CEN Heat No.
- Code No.
Yieki Strength Carbon AnnealTemperature Tangest Angle Nonle No.
t L
j 1
A6785 C4441-7 56000 0.065 1625F 41R 0
{
2' A6926' C-6441 39500 0.063 1625F 4HR 7.73 3-A6926 C4441 39500 0.068 1625F 4HR 7.73 i
j
.A6926 C-6441 39500 0.068 1625F 4HR 10.97
)
i
-4
[
5 A6926 C4441-4 39kl0 0.068 1625F 4HR 10.97 t
E j:
-6 A6926 '
C4441-4 39500 0.068 1625F 4HR 10.97 t
i 7
A6926 '
C4441-4 39500 0.068 1625F 4HR 10.97 h
l 8
A5849 -
C-64414 59000 0.054-1625F 4HR 15.61
}
t-J
{-
9 A5849 C44414 59000 0.054 1625F 4HR 15.61 L
l l'
10 A5980' C4441-3 39000 0.06 1625F 4HR 15.61 I
l.
t j,
11 A5980 C4441-3 39000 0.06 1625F 4HR 15.61
{
t f
i 12 A6926 C-6441-4.
39500 0.068 1625F 4HR 17.50 i
i I'
13 A6926 C-6441-4 39500 0.068 1625F 4HR 17.50 i
f 14 A6926 C4441-4 39500 0.068 1625F 4HR 17.50 1
t 15
'A5811 C.6441-5 44500 0.06 1625F 4HR 17.50 l
t 16 A5811 C4441-5 44500 0.06 1625F 4HR 17.50 l
[
17 -
A5811 C4441-5 44500 0.06 1625F 4HR 17.50 l
t 18 A6926 C4441-4 39500 0.068 1625F 4HR 17.50 l
19 A581I C4441-5 44500 0.06 1625F 4HR 17.50 20 A6h.3 C-6441-7 56000 0.065 1625F 4HR 22.36 1
Table 2, page 8
{
i t
I i
UNrr3 Anov600490NozzIrs CEDM
}{ eat No.
Code No.
Yield Strength Carta AnnealTempera:ure Tangent Angle Nozzle No.
21 A6785 C4441-7 56000 0.065 1625F 411R 22.36 22 A6777 C4441-1 35000 0.04 1625F 411R 22.36 23 A6777 C4441-1 35000 0.04 1625F 411R 22.36 24 EO3189 C4848-3 55000 0.084 NOT AVAIL 23.80 25 EO3189 C4848-3 55000 0.084 NOT AVAIL 23.80 26 EO3189 C4848-3 55000 0.084 NOTAVAIL 23.S0 27 EO3189 C4848-3
.55000 0.084 NOT AVAIL 23.80 28 EO3189 C4848-3 55000 0.084 NOTAVAIL 25.17 N
EO3189 C4848-3 55000 0.084 NOT AVAIL 25.17 30 EO3189 C4848-3 55000 0.084 NOT AVAIL 25.17 31 EO3189 C4848-3 55000 0.084 NOTAVAIL 25.17 32 EO3189 C4848-3 55000 0.084 NOTAVAIL 25.17 33 EO3189 C4848-3 55000 0.084 NOTAVAIL 25.17 34 AO9965 C4848-5 44000 0.081 NOTAVAIL 25.17 35 AO9965 C4848-5 44000 0.081 NOTAVAIL 25.17 36 EO3189 C-6848-3 55000 0.084 NOTAVAIL 29.01 37 EO3189 C-6848-3 55000 0.084 NOTAVAIL 29.01 38 EO3189 C4848-3 55000 l
0.084 NOT AVAIL 29.01 39 EO3189 C4848-3 55000 0.084 NOT AVAIL 29.01 40 EO3189 C-6848-3 55000 0.084 NOT AVAIL 29.01 41 EO3189 C4848-3 55000 0.084 NOTAVAIL 29.01 Table 2, page 9
l U.NTr3 Aum60GY390Nemiss CEDM IIcat No.
Code No.
Yieki Strength Ca: hon Anne 21 Temperature Tangent Angle Nonne No.
42 EO3189 C4848-3 55000 0.084 NOTAVAIL 29.01 j
43 EO3189 C4848-3 55000 0.084 NOT AVAIL 29.01 44 EO3189 C4848-3 55000 0.034 NM AVAIL 32.55 45 EO3189 C4848-3 55000 0.08:
NOT AVAIL 32.55 46 EO3189 C4848-3 55000 0.084 NOT AVAIL 32.55 47 EO3189 C-6848-3 55000 0.084 NM AVAIL 32.55 48 EO3045 C4848-1
$2000 0.075 NOT AVAIL 33.68 49 EO3O?5 C4843-1 52000 0.075 NOT AVAIL 33.68 50 EO3045 C4848-1 52000 0.075 NOT AVAIL 33.68 5I EO3045 C4848-1 52000 0.075 NOT AVAIL 33.68 52 EO3045 C4848-1 52000 0.075 NOT AVAIL 33.68 53 EO3045 C4848-1 52000 0.075 NOT AVAIL 33.68 54 EO3045 C4843-1 52000 0.075 NOT AVAIL 33.68 55 EO3045 C4848-1 52000 0.075 NOT AVAIL 33.68 I
56 R1948 C4848-2 42500 0.062 NOT AVAIL 34.80 l
57 R1948 C4848-2 42500 0.062 NOTAVAIL 34.80 58 R1948 C4848-2 42500 0.062 NOT AVAIL 34.S0 59 R1948 C4848-2
'42500 0.062 NOT AVAIL 34.80 60 EO3045 C4848-1 52000 0.075 NOT AVAIL 36.98 61 EO3045 C4848-1 52000 0.075 NOTAVAIL 36.98 62 EO3045 C4848-1 52000 0.075 NOT AVAIL 36.98 Table 2, page 10
I USTr3 Anov 6CM90 NOZZLFS y
IIcat No.
Code No.
Yield Strength Carbon Ane:alTempera:ure Tangent Angle 63 EO3045 C4848-1 52000 0.075 NOTAVAIL 36.98 64 EO3Gt5 C4848-1 52000 0.075 NOTAVAIL 36.98 65 E03045 C-6848-1 52000 0.075 NOTAVAIL 36.98 66 EO3045 C4848-1 52000 0.075 NOTAVAIL 36.98 67 EO3045 C4848-1 520W 0.075 NOT AVAIL 36.98 6R EO3189 C-6848-3 55000 0.084 NOT AVAIL 42.27 69 EO3189 C-6848-3 55000 0.084 NOTAVAIL 42.27 70 EO3189 C4848-3 55000 0.084 NOT AVAIL 42.27 71 EO3189 C4848-3 55000 0.084 NOTAVAIL 42.27 72 EO3189 C-6848-3 55000 0.084 NOTAVAIL 42.27 73 EO3189 C-6848-3 55000 0.084 NOTAVAIL 42.27 74 EO3189 C4848-3 55000 0.084 NOTAVAIL 42.27 75 EO3189 C4848-3 55000 0.084 NOTAVAIL 42.27 1
76 EO3189 C4848-3 S5000 0.084 NOTAVAIL 42.27 77 EO3189 C4848-3 55000 0.084 NOTAVAIL 42.27 78 EO3189 C4848-3 55000 0.084 NOT AVAIL 42.27 79 EO3189 C4848-3 55000 0.084 NOT AVAIL 42.27 80 EO3189 C4848-3 55000 0.084 NOT AVAIL 4331 81 EO3189 C4848-3 55000 0.084 NOT AVAIL 4331 82 EO3189 C-6848-3 55000 0.084 NOTAVAIL 4331 83 EO3189 C-6848-3 55000 0.084 NOT AVAIL 4331 l
i Table 2, page 11
UNIT 3 Au,0Y 600Mi90 Nom rs CEDM Nozzk No.-
IIcat No.
Code No.
Yield Strength Carbon AnnealTemperature Tangent Angle 84 EO3189 C4848-3 55000 0.084 NOT AVAIL 4331 I
85 EO3189 C4848-3 55000 0.084 NOT AVAIL 4331 86 EO1547 C4848-4 35000 0.088 NOTAVAIL 4331 87 E01547 C4848-4 35000 0.088 NOTAVAIL 4331 88 EO3189 C4848-3 55000 0.084 NOT AVAIL 49.55 89 EO3189 C4848-3 55000 0.084 NOT AVAIL 49.55 90 EO3189 C4848-3 55000 0.084 NOT AVAIL 49.55 91 EO3189 C4848-3 55000 0.084 NOT AVAIL 49.55 ICI NOZZLES ICI Nozzk lleat No.
Code No.
Yield Strength Carbon Anneal 7emperature Tangent Angle No.
92 NX 8006G C4857-1 40500 0.06 NOT AVAIL 55.06 93 NX 8006G C4857-1 40500 0.06 NOT AVAIL 55.06 94 NX 8006G C4857-1 40500 0.06 NOTAVAIL 55.06 95 NX 8006G C4857-1 40500 0.06 NOTAVAIL 55.06 96 NX 8006G C4857-1 40500 0.06 NOTAVAIL 55.06 97 NX 8006G C4857-1 40500 0.06 NOT AVAIL 55.06 98 NX 8006G C4857-1 40500 0.06 NOT AVAIL 55.06 99 NX 8006G C4857-1
'40500 0.06 NOT AVAIL 55.06 100 NX 8006G C-6857-1 40500 0.06 NOTAVAIL 55.06 101 NX 8006G C4857-1 40500 0.06 NOTAVAIL 55.06 Table 2, page 12
Document 90022 Revision 2.3 Figures t
19
I TYPICAL ALLOY 600 PENETRATION INSTALLATION CONFIGURATION I
-t 5
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i j
k N~.
i PIPING OR VESSEL PARENT MATERIAL i
I CLADDING I
i 2" ;l
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1 l
SUSCEPTIBLE CRACK AR i
1 ii g
J-GROOVE i
WELD 90022 Figure 1
LOCATION POZZLE 10 OATENATERIAL HEAT l0.
n,.4.,
t
,,, n,
= Sn ",
g, n'm m-s sT5sucru53 201ulee9 3m.. >.-3 v.3c n,4 7.-4
- 3 rem LOCATION N0ZZLE 10 DATEAATERIAL HEAT 70.
3PU' 49 FS-l
( ?/9 7 hE 7( j$ )
&Llof $90 gqf gg 3N, -et ?S. t hs 7839 53120 % 001 m,
...- 3 mi nw
,,,-4 3 Te4 8 344 (7/9? N89919)
ALLC'T $90 3 to-g 1 Saa ha 99 5 9 Ste4 t sac Ws 9919 3 FHI 33D hs 99 9 9 3 W t 3at
( 4/9, Ma tt il)
Adov 696 3 rw4 t 3er us 99 tl h
Sig.g t t e s t
$294 3 t[-g 113 1 9294 Sit-4 612 3 bl94 a f f-S t 12-3 9294 311-4113-4 77f f-4
>-i n t * -e n
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s LOCATION N0ZZLE 1D DATE/ MATERIAL HEAT PC.
m-e, ru er$4 pee ta m-e n s-s one c' eyut009
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LOCATION tOZZLE 10 DATEA%TERIAL HEAT l0.
d m,m n-,
(vier ~,n3e) uto, e9.
gf ([g 3PDT -O '9-2
( F/97 hs 7430 )
ALLQV $99 S3120lut002 3Pov
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( 7/96 kr 7634)
ALLov Std 3 fm-4 5 3sa a 2S9 3M t 39.
A 259 Sfw e s 39C a 239 3 r*4 t 39o hI $91$
3'*-4 8 39C a 2Se 3 fe 41395' s 250 af t-e t t e si
( 4/s r 9294) aLLov ele 3tt-g t 3 3-t (7/33 3294) attov ges 3f t -et!2-2 (4/97 9294)
ALov tee af t-4t !2-3 9794 3 t1-4123-4 9794
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