ML20236A173

Forwards Request for Addl Info Re Util 880810 Response to Generic Ltr 88-01,within 60 Days of Ltr Receipt

ML20236A173
Person / Time
Site:	FitzPatrick
Issue date:	03/08/1989
From:	Labarge D Office of Nuclear Reactor Regulation
To:	Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
GL-88-01, GL-88-1, TAC-69136, NUDOCS 8903160436
Download: ML20236A173 (10)

Text

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'.' - March 8, 1989 i Docket No. 50-333 DISTRIBUTION:

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A pocket 4F11e:.a0GC EAdensam Mr. John C. Brons NRC PDR . EJordan .WKoo.

Executive Vice President, Nuclear Generation Local PDR BGrimes TMcLellan Power Authority of the State of New York PDI-1 R/F ACRS (10) JJohnson, RI l~ 123 Main Street Glainas Gray File RCapra White Plains, New York 10601 BBoger CCheng CVogan LShao

Dear Mr. Brons:

DLaBarge JRichardson

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - GENERIC LETTER 88-01 (TAC 69136)

By letter dated August 10, 1988 (JPN-88-041) you responded.to Generic Letter 88-01 for the FitzPatrick Nuclear Power Plant. Analysis of this response has determined that additional information is necessary in order for the staff and its contractor, Viking Systems International, to complete the review. This information is enclosed as Attachment A.

Since this is a high priority item, we request that a formal response be provided within sixty days of receipt of this letter. In addition, please send a copy of your response to the NRC's contractor at the following address:

Dr. Armand A. Lakner Director, Safety and Reliability Viking Systems International 101 Chestnut Street Gaithersburg, Maryland 20877 Sincerely, l

ORIGINAL SIGNED BY David E. LaBarge, Project Manager Project Directorate I-1 Division of Reactor Projects I/II

Enclosure:

Attachment A

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i Mr. John C. Brons .

James A. FitzPatrick Nuclear 'I i, Power Authority of the State of New York Power Plant cc:

Mr. Gerald C. Goldstein Ms. Donna Ross Assistant General Counsel New York State Energy Office Power Authority of the State 2 Empire State Plaza of New York 16th Floor 10 Columbus Circle Albany, New York 12223 New York, New York 10019 Resident Inspector's Office .

U. S. Nuclear Regulatory Comissitt Regional Adminisi.rator, Region ! .I Post Office Box 136 U.S. Nuclear Regulatory Comission Lycoming, New York 13093 475 Allendale Road ,

King of Prussia, Pennsylvania 19406 Mr. Radford J. Converse Mr. A. Klausman Resident Manager .

Senior Vice President - Appraisal James A. FitzPatrick Nuclear and Compliance Services Power Plant Tower Authority of the State.

Post Office Box 41. of New York Lycoming, New York 13093 10 Columbus Circle New York, New York 10019 '

Mr. J. A. Gray, Jr. Mr. George Wilverding, Manager Director Nuclear Licensing - BWR Nuclear Safety Evaluation Power Authority of the State Power Authority of the State of New York of New York 123 Main Street 123 Main Street White Plains, New York 10601 White Plains, New York 10601 Mr. Robert P. Jones, Supervisor Mr. R. E. Beedle Town of Scriba Vice President Nuclear Support  ;

R. D. #4 Power Authority of the State '

Oswego, New York 13126 of New York 123 Main Street Mr. J. P. Bayne, President White Plains, New York 10601 Power Authority of the State of New York Mr. S. S. Zulla 10 Columbus Circle Vice President Nuclear Engineering New York, New York 10019 Power Authority of the State of New York M:. Richard Patch 123 Main Street Ous11ty Assurance Superintendent White Plains, New York 10601 James A. FitzPatrick Muclear Power Plant Mr. R. Burns Post Office Box 41 Vice President Nuclear Operations Lycoming, New York 13093 Power Aathority of the State of Nfw York ,

Charlie Donaldson, Esquire 123 Main Street Assistant Attorney General White Plains, New York 10601 New York Department of Law 120 Broadway New York, New York 10271

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ATTACHMENT A I

• l GENERAL QUESTIONS / REQUESTS Reviews of saveral licensee submittels has shown that mose (although not all) of the submittals commonly lack certain information that is needed fi, evaluation of the submittals. Thus, this general. list of questions and requests has been prepared for submission to each of the licensees. For those portions of this attachment for which the requested information was supplied (in the detail requested herein)'in the original submittal, the ,

utilities may reference the relevant pages or tables in the original submittal and supply only the requested information that was not provided. However, if the information requested concerning any of the items herein was not provided in the original licensee submittal, an omission of that information from the response to this RAI will be construed as an endorsement of the applicable NRC Staff position.

Item 1. Position on NRC Staff Positions .

Generic Letter 88-01 states on page 3: ,

" Pursuant to 10 CFR 50.54(f), you, as a BWR ope' rating reactor licensee or construction permit holder, are requested to furnish, under oath or affirmation, your currept plans relating to piping replacement, inspection, repair, and leakage detection. Your response should indicate whether you intend to follow the staff positions included in this letter, or propose alternative l measures." i The staff positions outlined in Generic Letter 88-01 include positions on: (1) Materials. (2) Processes. (3) Water Chemistry. (4) Weld Overlay. (5) Partial Replacement. (6) Stress Improvement of Cracked  ;

Weldsents. (7) Clamping Devices. (8) Crack Evalus' tion and Repair >

Criteria. (9) Inspection Method and Personnel. (10) Inspection Schedules. (11) Sample Expansion. (12) Leak Detection. (13)

Reporting Requirements.

Please supply information concerning whether the licensee: (1) l endorses these positions, (2) proposes alternate positions, exceptions, or provisions, and (3) is considering or planning to apply them in the future. Please describe any alternate positions, exceptions, or provisions that are proposed.

Please supply this information using a table such as that illustrated in the example shown in Table 1. .

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Table 1 Responses.to NRC Staff Positions Licencee Responsc* Licensee !!as/Wil15#

Accept Requests ,

with Alternate Applied Consider for Staff Position Accept Provisions Posieton in Past Future Use

1. Nhterials

2. Processes *

3. Water Chemistry

4. Weld Overlay

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5. Partial Replacement '

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6. Stress Improvement of

• l Cracked We ldsents  !

7. Clasping Devices i'

8. Crack Evaluation and i Repair Criteria .

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9. Inspection Method and Personnel

10. Inspection Schedules '

11. Saaple Expansion

12. Leak Detection

13. Reporting Requirements Answer with "yes", " check mark" or "X" in appropriate column for each of the 13 NRC Staff Positions. List and explain each provision and/or alternate position (or reference original submittal if it contains the listing and explanation). Use separate page(s) if needed.

• • Answer with "yes" or "no", as appropriate, in each column for each of 13 NRC Staff Positions. -

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ATTACHMENT A (continued)

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Item 2. Inservice Inay etion Program Generic Letter 88-01 requests on page 3t "Your current plans regarding pipe replacement and/or other measures taken or to be taken to mitigate IGSCC and provide assurance of continued long-term integrity and reliability."

"An Inservice Inspection Program to be implemented at the next refueling outage for austenitic stainless steel piping covered under the scope of this letter that conforms to the staff positions on inspection schedules methods and personnel, and sample expansion included in this letter."

he information pertaining to the pipe replacement and other mitigating actions as well as the Inservice Inspection Program provided in most of the licensee submittals were either incomplete or did not provide the background data that is needed to evaluate the ISI Program such as (1) reasoas/ justification for IGSCC classification of welds, (2) methods, personnel qualification, schedules and identities of welds inspected, and (3) results of previous inspections, and/or identities of welds to be inspected during future inspections.

R us, the following information is requested:

1. A listing of all welds by aystem, pipe size, configuration (e.g., pipe to elbow, pipe to valve, etc.), drawing number (piping ISO with weld I.D.), location (i.e., inside or outside ,of containment, etc.), weld I.D. number, and IGSCC classification (i.e. IGSCC Category A, B, C, D, E F and G).

2. Reason / justification for the classification'of each weld,'

using such information as (a) weld history such as heat sink welding (HSW), (b) pipe and weld metal compositions or material .

identities to show either conforming material or non-conforming material. (c) mitigating treatment (s) applied such as solution heat treating (SHT), stress improvement (IHSI or MSIP).

3. Identity of welds to be inspected during past and future refueling outage. Include (a) dates and results of previous inspections, (b) flaw characteristics including orientation (axial or circumferential), maximum length, maximum depth, repairs and/or mitigating treatments applied.

Please supply this information in tabular form using formats such as that illustrated in Tables 2 and 3.

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Table 2 ,

History of Welds and Prior Mitigating Actions / Treatments

• Material **

IGSCC Weld Dia. Casting Treatment ***

h System Number Configuration Inch Formind. Pine Weld Siff HWS CRC S,I,, 0.LT l

Notes: ,

i List each weld separateln using one or more lines as required.

For materials identify as non-conforming or conforming as l appropriate concerning whether it conforms with the NRC Staff position on resistant materials. If conforming, identify the material type (e.g., Type 316 NG).

• • • For treatment: list "X" under appropriate column (s) if weld was i treated using indicated technique, i.e., solution heat treated (SHT), heat sink welded (HSW), corrosion resistant clad (CRC),

stress laproved (SI), or overlayed (0.L.). For SI, add '

explanation of method used, i.e., whether by induction heating or mechanical, whether pre and/or post treatment ir.spection was '

applied using methods and personnel qualified under NRC/EPRI/BWROG j coordination plan, and whether treatment was applied within two years of service date. Also add explanation and justificatica-of any overlays that were not standard (per NRC Staff position).

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, . 1 Table 3 Inspection Schedules

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Inspected /To Be IneDected/Fisws Found IGSCC ' Weld Dia. Past _ Future Caten System No. Inch. Configuration R.O.#X-2 R.O.fX-1 Flaw R.O.#X R.O.#X+1 l

Instructions: ,

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1. Under the heading, " Inspected /To BE Ins.pected," use as many columns i as required to describe the following: '

(a)Allpreviousinspectionsthatwereconducted(perhUREG 0313, Revision 2, page 5.2) using methods and personnel i qualified under NRC/EPRI/BWROG coordination plan as upgraded in September, 1985.

plus (b) A sufficient number of future inspections to demonstrate that the schedules will follow the NRC Staff positions as given in Table 1 in Generic Letter 88-01. i

2. Replace R.O.f (I-2. I-1, I, X+1) with actual refueling outage numbers. Indicate dates inspections were/will be performed.

3. List each weld within the scope of Generic Letter 88-01.

4. Place an "I" or other appropriate symbol under the appropriate column for each refueling outage for which that weld was inspected or will be inspected. -

5. Indicate with "yes" under column marked " flaw" if a flaw indication was found. Attach a statement for each flawed weld giving the orientation (exial or circuaferentisi), the dimensions (maximum length and depth), and describing any repairs made.

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ATTACHMENT A (contiriued)

Item 3. Welds Covered in Licensee Submittel Generte Letter 88-01 (on page 2) states:

"This Generic Letter applies to all BWR piping made of austenitic stainless steel that is four inches or larger in nominal diameter and contains reactor coolant at a temperature above 200'F during power operation regardless of Code classification. It also applies to reactor vessel attachments and appurtenances such as jet pump instrumentation penetration assemblies and head spray and vent components."

Were any welds i; hat fall within this defined scope excluded from thr: licensee submittal (for example, welds in the RWCU outboard of the isolation valves)? If previously excluded, please list identity of such welds and plans for mitigation and inspections in Tables 2 and 3 or provide alternative proposal. If IGSCC susceptible welds were excluded from the licensee submittal based on temperature considerations please identify the welds and describe in detail the '

method of temperature measurements.

Item 4. Welds that Are Not ITT Inspectable Generic Letter 88-01 (in Table 1) states: "WeldsthatarenotUT$

inspectable should be replaced, " sleeved", or local leak detection applied. RT examination or visual inspection for leakage may also be considered."

Does the licensee submittal include discus,sions and plans fors (a) A11' welds that are inaccessible for ITT inspections?

(b) All wolds that are only partially accessible for UT inspections?

(c) Welds that cannot be UT inspected because of geometrical constraints or other reasons.

If not, please list these welds snd plans for mitigation / inspection.

Item 5.14akane Detection [

Generic Intter 88-01 states on page 3:

" Confirmation of you plans to ensure that the Technical A-6 .

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i ATTAC10ENT A (continued)

Specificati6n related to leakage detection will be in conformance with the staff position on leak detection included in this letter."

ine start ponttion 19 otittinad on psges 5 er.d 5 of Canaric Letter 88-01 and include the following itenst.

1. Lankage detection should be in conformance with Position C of Regulatory Guide 1.45 " Reactor Coolant Pressure Boundary Leakage Detection Systems," or as otherwise approved by the NRC.

2. Plant shutdown should be initiated for corrective action when (a) within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period any leakage detection systes indicates an increase of unidentified leakage in excess of 2 spa or its equivalent, or (b) the total unidentified leakage attains a rate of 5 spe or equivalent.

3. IAakage should be Bonitored (or determined from flow measurements if flow is continuously monitored) at approximately four hour intervals or less.

4. Unidentified leakage should include all leakage other than (a) leakage into closed systems, or i

(b) leakage into the containment atmosphere from sources that are both specifically located and known eithere not to interfere with operations of monitoring systems or not to be from a throughwall crack.

5. For plants operating with any IGSCC Category D. E F, or G welds, at least one of the leakage measurement instruments associated with each ausp shall be operable, and the outage time for inoperable instruments shall be limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or immediately initiate an orderly shutdown.

Although most licensee submittals describe the intention of meeting some or all of these requirements or offer alternative measures, it is not always clear whether these requirements are contained in the Technical Specifications. Thus it is requested that this l

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information should be provided by each licensee. For clarity and i completeness, please use a checklist such as that illustrated in Table 4 o

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_ _ _ _ _ _ _ _ _ . _ . _ _ - - - - - - - - - - - - - - - - - - - - - - - - '^

Table 4.

Licensee F 'tions on Leakage Detection Already TS will be AAternate Contained Changed Position Position in TS ,

to Include Proposed

-1. Conforms with Position C of Regulatory Guide 1.45

2. Plant shutdown should be

• initiated whens (a) within any. period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ,

or less, an increase is indicated in the rate of unidentified leakage in excess of 2 spe, or (b) the total unidentified leakage attains a rate of 5 spa.

3. Leakage monitored at four hour intervals or less.

4.. Unidentified leakage includes all except:

(a) leakage into closed systems, or (b) leakage into the containment '

atmosphere from sources that are located, do not interfere -

with monitoring systems, or not from throughwall crack.

3. Provisions for shutdown within 24 -

hours due to in' operable measurement instruments in plants with Category j D, E, F, or G welds.

Instructions:

Place "I" or "yes" under appropriate column for each ites. Provide description and justification for alternative positions.if not already provided.

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