ML20204G730
| ML20204G730 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/18/1988 |
| From: | Dromerick A Office of Nuclear Reactor Regulation |
| To: | Fitzpatrick E GENERAL PUBLIC UTILITIES CORP. |
| References | |
| GL-84-01, GL-84-1, GL-84-11, NUDOCS 8810240220 | |
| Download: ML20204G730 (5) | |
Text
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'o UNITED STATES 8"
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NUCLEAR REGULATORY COMMISSION 5
j WASHINGTON D. C. 20655
'+,....,o Ocri s see Docket No. 50-219 Mr. E. E. Fitzpatrick Vice President and Director Oyster Creek Nuclear Generating Station Post Office Box 388 Forked River, New Jersey 08731
Dear Mr. Fitzpatrick:
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION 12 R REFUELING OUTAGE IGSCC INSPECTION PLAN By letters dated February 16, 1988, April 5, 1988, and August 1, 1988, GPU Nuclear Corporation (GPUN) provided infonnation regarding the intergrar.nulas stre.,s corrosion cracking (IGSCC) inspection plan for the Oystar Creek Nuclear Generating Station 12 R refueling outage. This matter was also discussed in meetings held on May 26, 1988 and June 28, 1988. The staff has reviewed this infonnation and the results of our review are discussed below.
GPUN proposed to inspect about 68 IGSCC susceptible welds at the Oyster Creek 12 R refueling outage. The GPUN proposed inspection plan basically followed the guidelines in Generic letter 84-11 with the following exceptions:
(1) The proposed sample size of inspecting the previously inspected welds is about 10% instead of a required minimum of 20%.
(2) The proposed sample expansion is limited to the system where defective welds are found. However, the Generic letter 84-11 requires the initial sample size to be doubled once a defective weld is found in any system.
The staff has not completed its review of the 3 PUN submittal dated August 12, 1988 responding to Generic Letter 88-01 (GL-88-01). The staff will provide its SER addressing the GPUN submittal of August 12, 1988 under separate cover. Generic Letter 88-01 was issued on January 25, 1988, which supersedes Generic Letter 84-11. Generic Letter 88-01 requires that the staff positions on inspection schedules, methods and personnel, and sample expansion included in the subject letter be implemented at the next refueling outage.
In its letter of April 5,1988, GPUN indicated that the 12 R refueling outage was scheduled to start on October 1, 1988. GPUN also stated that there was not suffizient time for the planning and preparation needed to implement Generic Letter 88-01 at 12R outage.
The subject outage is more than nine months away from the date the Generic Letter 88-01 was issued. We consider that GPUN has adequate time to implement the subject generic letter at the upcoming refueling outage and should make every effort to do so. During the meeting held on June 28, 1988, the staff requested GPUN to provide additional infonnation including a comparison of
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Mr. 'E. E. Fitzpatrick,
GPUN's program with Genetic Letter 88-01 to facilitate our review of their proposed inspection plan for 12R.
Based on our review, we conclude that, although the proposed inspection plan for 12R does not completely meet Generic Letter 88-01, it will be acceptable if all the staff coments discussed Delow are incorporated.
Our main concern over GPUN proposed inspection plan is that many Category G welds (155) are not included in the 12R outage inspection.
The proposed plan also shows that, even after 14R outage, 93 Category G welds would still be not inspected. Category G welds are welds that have never been properly inspected for IGSCC. Generic Letter 88-01 requires that all Category G welds be inspected during the upcoming refueling outage. We recognize that because of a tight outage schedule GPUN may not be able to examine all Category G welds in 12R outage. We believe that because of the timing of the generic letter some relief may be justified. However, we consider that, as a minimum, GPUN comit to examine all Category G welds at Oyster Creek no later than the end of 13R 1
outage so that staff will gain assurance that these welds will be inspected in the foreseeable future.
We also do not agree with GPUN positions for the following items; (1) GPUN contends that the Reactor Water Cleanup System (RWCU) piping welds outside the second containnent isolation valves are outside the inspection scope. This is not acceptable because the Generic Letter 88-01 requires the augmented inspections to be applied to all BWR piping made of austenitic stainless steel that is four inches or larger in nominal diameter and contains reactor coolant a a temperature above 200 degree F during power operation regardless of Code classification.
(2) We do rot agree with GPUN's taking credit for examinations performed in 10R outage, because the subject examination was perfonted prior to September 1985 by examiners not being requalified. The credit for 10R examination may be considered if GPUN can show that the examiners had passed the requalificaticn tests on the first try thus indicating they were qualified when they perfonted the testing at the facility.
(3) GPUN, in their submittal dated August 1,1988, proposed to modify the sample expansion for recirculation system safe ends, isolation condenser piping outside second containment isolation valves and RWCU piping inside the second containment isolation valves.
For those piping welds, the proposed sample expansion is limited to the same kind of welds in the i
same system, where the flaws are found.
This is not consistent with the staff position in Generic Letter 88-01, where the required sample expansion is on a weld Category basis irrespective of the systems and pipe weld locations. An alternate sample expansion scheme may be considered on a case basis if adequately justified in terms of the crack severity, safety impact, quality of inspection, IGSCC history ALARA, outage schedule, availability of qualified examiners and other relevant factors.
i Mr. E. E. Fitzpatrick,
Therefore, based on the above, we require that GPUN revise and document their proposed inspection plan for the 12R and subsequent outages in accordance with the comments provided.
Based on ;'our revised inspection plan, we request that GPUN also submit a revised response to Generic Letter 88-01 in order to expedite our review.
The reporting and/or record keeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not needed under P.I.. 96.511.
Sincerely,
$tL-1he iW M 6C Alexandef W. Dromerick, Project Manager Project Directorate 1-4 Division of Reactor Projects 1/II Office of Nuclear Reactor Regulation cc: See next page
t l#.>E. E. Fitzpatrick -
Therefore, based on the above, we require that GPUN revise and document their proposed inspection plan for the 12R and subsequent outages in accordance with the comments provided.
Based on your revised inspection plan, we request that GPUN also submit a revised response to Generic Letter 88-01 in order to expedite our review.
The reporting and/or record keeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not needed under P.L. 96.511.
Sincerely, original signed by Alexander W. Dromerick, Project Manager Project Directorate 1-4 Division of Reactor Projects I/!!
Office of Nuclear Reactor Regulation cc: See next page DISTRIBUTION
.Docke t ET ADromerick NRC & Local PDRs OGC (info. only)
Gray File Edordan, 3302 MNBB SVarga, 14/E/4 DGrimes, 9/A/2 BBoger, 14/A/2 ACRS(10)
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' Mr. 'E. E. Fitzpatrick Oyster Creek Nuclear Oyster Creek Nuclear Generating Station Generating Station CC*
Ernest L. Blake, Jr.
Resident Inspector Shaw, Pittman, Potts and Trowbridge c/o U.S. NRC 2300 N Street, NW Post Office Box 445 Washington, D.C.
20037 Forked River, New Jersey 08731 J.B. Liberman, Esquire Comissioner Bishop, Liberman, Cook, et al.
New Jersey Department of Energy 1155 Avenue of the Americas 101 Comerce Street New York, New York 10036 Newark, New Jersey 07102 Jennifer Moon, Acting Chief Regional Administrator, Region I New Jersey Department of Environmental U.S. Nuclear Regulatory Comission Protection 475 Allendale Road Bureau of Nuclear Engineering King of Prussia, Pennsylvania 19406 CN 415 Trenton, New Jersey 08625 BWR Licensing Manager GPU Nuclear Corporation 1 Upper Pond Road Parsippany, New Jersey 07054 Deputy Attorney General State of New Jersey Departeent of Law and Public Safety 36 West State Street - CN 112 Trenton, New Jersey 08625 Maycr Lacey Township 818 West Lacey Road Fcrked River, New Jersey 08731 Licensing Manager Oyster Creek Nuclear Generating Station Mail Stop:
Site Emergency Bldg.
P. O. Box 388 Forked River, New Jersey 08731
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