ML20236C718
| ML20236C718 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/08/1989 |
| From: | Paulson W Office of Nuclear Reactor Regulation |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| GL-88-01, GL-88-1, NUDOCS 8903220288 | |
| Download: ML20236C718 (12) | |
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4 March'8, 1989-Docket No. 50'458 Gulf States Utilities Company
' ATTN: Mr. James C. Deddens SeniorVicePresident(RBNG)-
Post Office Box St. Francisville, Louisiana 70775 4
Dear Mr. Deddens:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - GENERIC LETTER 88-01 The NRC staff and its contractor, Viking' Systems International, is reviewing and evaluating Gulf States' Utilities' July 21, 1988 response to Generic. Letter 88-01, NRC Position On IGSCC In BWR Austenitic Stainless Steel Piping. -The-
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staff finds that the additional information11dentified in Attachments A'and B is re' quired to' complete the review._ Please provide your' response.to the Attachments within 60 days of the receipt of this' letter. To expedite the.-
1 review process, please send a copy of your response to the NRC Contractor at' the following address:--
Dr. Armand A. Lakner Director, Safety and Reliability Viking Systems International.
I 101 Chestnut Street-Gaithersburg, Maryland 20877' This request for information was approved by' the Office of_ Management and-Budget under clearance number 3150-0011 whichexpiresDecember.31,fl989.
Sincerely, Walter A. Pauls/s/
09032 g g 990300oSoog4je. -
Project Directorate -~IV
'l on, Project Manager i
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. Division of Reactor Projects - III, IV, V and SpecialLProjects
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- Office of Nuclear Reactor. Regulation Attachments:
1.
Attachment A, Request for Additional Information on Generic Letter 88-01, General Questions / Requests 2.
Attachment B Request for Additional Information on Generic Letter 88-01, Pertaining to River Bend Station, Unit I cc w/ attachments:
See next page H
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March 8, 1989 Docket No. 50-458 Gulf States Utilities Company ATTN: Mr. James C. Deddens Senior Vice President (RBNG)
Post Office Box St. Francisville, Louisiana 70775 4
Dear Mr. Deddens:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - GENERIC LETTER 88-01 The NRC staff and its contractor, Viking Systems International, is reviewing and evaluating Gulf States Utilities' July 21, 1988 response to Generic Letter 88-01, NRC Position On IGSCC In BWR Austenitic Stainless Steel Piping. The staff finds that the additional information icentified in Attachments A and B is required to complete the review.
Please provide your response to the Attachments within 60 days of the receipt of this letter. To expedite the review process, please send a copy of your response to the NRC Contractor at the following address:
Dr. Armand A. Lakner Director, Safety and Reliability Viking Systems International 101 Chestnut Street Gaithersburg, Marylano 20877 This request for information was approved by the Office of Management and Budget under clearance number 3150-0011 which expires December 31, 1989.
Sincerely, b)dL A. a&J Walter A. Paulson, Project Manager Project Directorate - IV Division of Reactor Projects - III, i
IV, Y and Special Projects Office of Nuclear Reactor Regulation Attachments:
1 1.
Attachment A. Request for Additional Information on Generic Letter 88-01, General Questions / Requests 2.
Attachment B, Request for Additional Information on Generic Letter 88-01, Pertaining to River Bend Station, Unit I cc w/ attachments:
See next page i
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Mr. Jame's C. Deddens Gulf States Utilities Company River Bend Nuclear Plant cc:
Troy B. Conner, Jr., Esq.
Mr. J. E. Booker Conner and Wetterhahn Manager-River Bend Oversight 1747 Pennsylvania Avenue, NW P. O. Box 2951 Washington, D.C.
20006 Beaumont, TX 77704 Mr. Les England Mr. William H. Spell, Administrator Director - Nuclear Licensing Nuclear Energy Division Gulf States Utilities Company Office of Environmental Affairs P. O. Box 220 P. 0.' Box 14690 St. Francisville, LA 70775 Baton-Rouge, Louisiana 70898 Richard M. Troy, Jr., Esq.
Assist 6nt Attorney General in Charge Mr. J. David McNeill, III l
State of Louisiana Department of Justice William G. Davis, Esq.
234 Loyola Avenue Departnent of Justice New Orleans, Louisiana 70112 Attorney General's Office 7434 Perkins Road Resident Inspector Baton Rouge, Louisiana 70808 1
P. O. Box 1051 St. Francisville, Louisiana 70775 H. Anne Plettinger 3456 Villa Rose Drive Gretchen R. Rothschild-Reinike Baton Rouge, Louisiana 70806 Louisianians for Safe Energy, Inc.
2108 Broadway Street New Orleans, Louisiana 70118-5462 President of West Feliciana Police Jury Regional Administrator, Region IV P. O. Box 1921 U.S. Nuclear Regulatory Commission St. Francisville, Louisiana 70775 Office of Executive Director 6
for Operations Mr. Frank J. Uddo 611 Ryan Plaza Drive, Suite 1000 Uddo & Porter Arlington, Texas 76011 6305 Elysian Fields Avenue l
Suite 400 Philip G. Harris New Orleans, Louisiana 70122 Cajun Electric Power Coop. Inc.
i 10719 Airline Highway P. O. Box 15540 Baton Rouge, LA 70895 1
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~ ATTACHMENT A i."
REQUEST FOR ADDITIONAL INFORMATION ON GENERIC LETTER 88-01 i
GENERAL QUESTIONS / REQUESTS Reviews of several licensee submittals has shown that most (although not all) of the submittals commonly lack certain information that is needed:for i
evaluation of the submittals. Thus, this general list of questions and j
! requests has been prepared for submission.to each of the licensees. For.
those pertions 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.
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Item 1. Position on NRC Staff Positions' Generic IAtter 88-01 states on page 3:
" Pursuant to 10 CFR 50.54(f), you, as m.BWR operating reactor licensee or construction permit holder, are requested to furnish, under oath or affirmation, your current. 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 measures."
'Ihe 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 Weldments. (7) Clamping Devices. (8) Crack Evaluation and Repair Criteria. (9) Inspection Method and Personnel. (10) Inspection l
Schedules. (11) Sample Expansion. (12) Leak Detection. (13) 1 Reporting Requirements.
Please supply infomation concerning whether the licensee: (1) 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, i
exceptions, or provisions that are proposed, j
Please supply this information using a table such as that illustrated in the example shown in Table 1.
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l Table 1 Responses to NRC Staff Positions Licensee Response *-
Licensee'Has/Wille'*
Accept Requests with Alternate Applied Consider for l
Staff Position Accept Provisions Position in Past - Future Use l
- 1. Materials
- 2. Processes
- 3. Water Chemistry
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- 4. Weld Overlay l
- 5. Partial Replacement
- 6. Stress Improvement of Cracked Weldsente 1
- 7. Clamping Devices 1
- 8. Crack Evaluation and Repair Criteria
- 9. Inspection Method and Personnel
- 10. Inspection Schedules
- 11. Sample Expansion
- 12. Leak Detection
- 13. Reporting Requirements l
Answer with "yes", " check mark" or "I" 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).
Item 2. Inservice Inspection Pronram Generic Letter 88-01 requests on page 3:
"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 inteprity 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 2etter that conforms to the staff positions on inspection schedules methods and personnel, and sample expansion included in this letter."
'Ihe 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 I
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or did not provide the background data ths.t is needed to evaluate the ISI Program such as (1) reasons / justification for IGSOC 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.
Thus, the following information is requested:
- 1. A listing of all welds by system, pipe size, configuration (e.g., pipe to albow, 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 saterial 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 ##
ICSCC Weld Dia.
Casting Tr6stment**e
_Categ System Numbyr, Configuration Inch Formina. Pipe Weld SHT INS CRC JI 0.L.
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Notes:
l List each veld, separately, using one or more lines as required.
- For materialt identify as non-conforafng or conforming as appropriate concerning whether it conforms with the NRC Staff l
position on resistant materials. If conforming, identify the material type (e.g., Type 316 NG).
- For treatments list "I" under appropriate column (s) if weld was I
treated using indicated technique, i.e., solution heat treated (SHT), heat sirs welded (HSW). corrosion resistant clad (CRC),
l stress improved (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 ~ inspection was applied using methods and personnel qualified under NRC/EPRI/BWROG coordination plan, and whether treatment was applied within two years of service date. Also add explanation and justification of any overlays that were' not standard (per NRC Staff positf on).
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Table 3 l
Inspection Schedules s
Inspected /To Be Inspected / Flaws Found ICSCC Weld Dia.
Past Future
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9_teg System No.
Inch. Configuration R.O.fI-2 R.O.fI-1 Flav R.O.fI R.O.fI+1 e
1 Instructions
- 1. Under the heading, " Inspected /To BE Ins.pected," use as many columns k
j as required to describe the following:
(a) All previous inspections that were conducted (per NUREG 0313, Revision 2, page 5.2) using methods and personnel
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qualified under NRC/EPRI/BVROG' coordination plan as upgraded in September,1985.
plus (b) A sufficient number of future inspections-to demonstrate
- hat the schedules will follow the NRC Staff positions as given in Table 1 in Generic Intter 88-01.
- 2. Replace R.O.f (I-2, I-1. I,1+1) with actual refueling outage numbers. Indicate dates inspections were/will be performed.
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- 3. List each weld within the scope of Generic IAtter 88-01.
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- 4. Place an "I" or other appropriate symbol'under the appropriate column for each refueling outage for which that weld was inspected
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or will be inspected.
- 5. Indicate with "yes" under column marked " flaw" if a flaw indication l
was found.
Attach a statement for each flawed weld giving the orientation (axial or circumferential), the dimensions (maximum i
length and depth), and describing any repairs made.
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e ATTACHMENT A (continued)
Item 3. Welds Covered in Licensee Submittal Generic 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 l
instrumentation penetration assemblies and head spray and vent components."
Vere any welds that fall within this definbd scope excluded from the 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 cr 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 W Inspectable
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Generic Letter 88-01 (in Table 1) states: " Welds that are not UT 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 discussions and plans for:
(a) All welds that are inaccessible for Iff inspections?
(b) All welds that are only partially sccessible for ITT i
inspections?
(c) Welds th'at cannot be LTT inspected because of geometrical constraints or other reasons.
If not, please list these welds and plan's for mitigation / inspection.
Item 5. Leskene Detection Generic latter 88-01 states on page 3:
" Confirmation of you plans to ensure that the Technical A-6 1
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T ATTACHMENT A (continued)
Specification related to leakage detection will be in conformance with the staff position on leak detection included in this letter."
h e staff position is outlined on pages 5 and 6 of Generic Letter 88-01 and include the following items:
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- 1. Leakage detection should be in conformance with Position C of Regulatory Guide 1.45 " Reactor Coolant Pressure Boundary l
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 system indicates an increase of unidentified leakage in excess of 2 gpm or its equivalent, or (b) the total unidentified leakage attains a rate of 5 spa or equivalent.
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- 3. Leakage should be monitored (or determined from flow l
measurements if floe is continuously monitored) at approximately four hour intervals or less.
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- 4. Unidentified leakage should include all leakage other than (a) leakage into closed systems, or (b) leakage into the containment atmosphere from sources that are both specifically located and known either 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 sump 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 immedi,ately 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, h us it is requested that this information should be provided by each licensee. For clarity and completeness, please use a checklist such as that illustrated in Table 4.
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s Table 4 Licensee Positions on laakage, Detection Already TS will be-Alternate 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 when:
i (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 frei sources that are located, ou not interfere with monitoring systems, or not from throughwall crack.
- 5. Provisions for shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to inoperable measurement instruments in plants with Category D, E, F, or G welds.
Instructions:
Place "X" or "yes" under appropriate column for each ites. Provide description and justification for alternative positions if not already provided.
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t ATTACHMENT B REQUEST FDR ADDITIONAL INFORMATION i
ON GENERIC LETTER 88-01
- PERTAINING TO RIVER BEND STATION, UNIT 1 Item 1. Change to the Technical Specification Renarding ISI J
Generic Letter 88-01 on page 3 states:
J "A change to the Technical Specification to include a statement in the section on ISI that the Inservice Inspection Program for Piping covered by the scope of this letter will be in conformance with the staff positions on schedule, methods and personnel, and sample expar.sion" The Gulf States Submittal states that a change is not required since Gulf States utilizes the RBS ISI Plan, approved by the NRC. It is l
not clear, however, whether the TS contains statements in conformance with the NRC Staff position. Thus, the following information is requested:
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(s) A copy of the portion of the TS containing statements of conformance to the NRC Staff position on ISI, if such -
statements exist, or (b) Appropriate changes to the TS if it does not currently contain statements of conformanc,e to the NRC Staff position on ISI.
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