ML20236N248

Provides Clarification to Licensee ,Submitted to Satisfy Conditions of 1992 NRC SE Which Granted Conditional Relief Applicable to Second ISI Interval.No Addl Relief Is Being Requested

ML20236N248
Person / Time
Site:	Crane
Issue date:	07/09/1998
From:	Langenbach J GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1920-98-20358, NUDOCS 9807150062
Download: ML20236N248 (3)

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GPU Nuclear,Inc.

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Route 441 South NUCLEAR Post Office Box 480 Middletown, PA 17057-0480 Tel 717 944-7621 1920-98-20358 July 09,1998 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Wastnngton, DC 20555

Subject:

Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 Inservice Inspection (ISI) - Clarification of GPU Nuclear Submittal Regarding Semi-Elliptical Circumferential Reactor Vessel Nozzle-To-Pipe Weld Flaws In response to the NRC's June 1,1998 request for additional information (Reference 7),

the purpose of this letter is to clarify the GPU Nuclear letter dated December 19,1997 (Reference 6) which was submitted to satisfy the conditions of a 1992 NRC Safety Evaluation which granted conditional relief applicable to the second ISI Interval. No additional reliefis being requested.

Included with the April 19,1991 GPU Nuclear submittal ofInservice Inspection Plans and Schedules for the second ten year interval (Reference 1), as Relief Request No.1 (RR-01), was a request for relief from the Section XI Cc,de requirements to perform external surface examinations of the reactor vessel nozzle-to-piping welds connected to the Core Flood and the Reactor Coolant System hot leg and cold leg piping. GPU Nuclear requested relief to accept an alternative examination of the outer

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diameter (OD) surface from the inner diameter (ID) using an ultrasonic technique using a remote manipulator. The basis for requesting relief was the substantial dose savings through use of the alternate technique compared with an estimate of 87 person-rem to perform the examinations in

, accordance with the Code. GPU Nuclear provided additional information in a letter dated December 12,1991 (Reference 2) and conditional relief was granted by the NRC in a Safety Evaluation dated October 8,1992 (Reference 3).

The NRC's Safety Evaluation (Reference 3) stated that relief was granted with the conditions stated in an attached Technical Evaluation Report (TER) by Idaho National Engineering Laboratory (EGG-O MS-10169) dated May 1992 as follows.

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"The proposed alternative of a volumetric inspection from the ID is acceptable provided the Licensee meets the following conditions:

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(1) The remote volumetric examination includes the entire weld volume and heat affected zone r

instead of only the inner one-third of the weld.

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PDR ADOCK 05000289?

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o / Page 2 'of 3 (2) The Ultrasonic testing instrumentation and procedures are demonstrated to be capable of detecting OD surface connected defects, in the circumferential orientation, in a laboratory test block. The defects should be cracks and not ma'chined notches."

The TER acknowledged the GPU Nuclear commitments as stated in our December 12,1991 letter (Reference 2) to: (1) examine the full weld volume and adjacent base metal %" on each side of the l;

weld, and (2) qualify the contractor, Babcock and Wilcox Nuclear Services (BWNS) technique.

I Since this relief request was common to the B&W plants, GPU Nuclear pursued qualification of the contractor technique through the Babcock and Willcox Owners Group (BWOG). Following a demonstration of the technique in Lynchburg, VA on August i 1,1993 for Donald Naujock of NRR, several meetings to discuss NRC comments, and submittals by the BWOG, NRC approval was provided in a March 21,1996 letter to the NDE Committee Chairman, Gene Navratil (Reference 4).

Reference 4 provided the NRC's Safety Evaluation approving the proposed ultrasonic examination from the ID of the nozzles as an acceptable alternative to penetrant testing (PT) surface examination of the OD to satisfy the Code requirement based on their review of the BWOG Topical Report (TR) which was approved as BAW-2228P-A, Rev 1. In approving the proposed technique, the NRC's safety evaluation states that each licensee which references the TR as the basis for relief must l

confirm the p! ant-specific applicability by demonstrating that: 1) the input stresses under L

normal / upset and emergency / faulted conditions shown in the tables I to 4 of the TR for its plant are i

the result of using the bounding transient in the analysis, and (2) the material in its inlet, outlet, and l

core flood nozzles is either A508 Class 2 carbon steel or SA 336 (316) stainless steel.

GPU Nuclear has confirmed that: 1) the analysis approved by the NRC in Reference 4 considers the bounding normal / upset condition transients and emergency / faulted condition transients from the

.TMI-l plant specific analysis, and 2) the materials used for the analysis of nozzles in Reference 4 l

were found to be the same materials used for TMI-l nozzles. The TMI-l Reactor Vessel inlet and outlet nozzles are ASTM A508 class 2, the Core flood nozzles are ASTM A508 class 2, and the Core flood safe end is SA336 F8M. ASTM-A-508 Class 2 is low alloy steel and SA-336-F8M is Type 316 stainless steel. Therefore, based on our review of TMI-l design documentation, GPU Nuclear concludes that BAW 2228P-A, Revision 1 is applicable to TMI-l and the NRC's condition for granting relief (confirmation that the ultrasonic testing instrumentation and procedures are capable of detecting OD surface connected defects in the circumferential orientation) has been satisfied.

Sincerely,

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James W. Langenbach j

Vice President and Director, TMI 1.

MRK cc: Administrator, NRC Region I TMI Senior NRC Resident inspector TMl Senior NRC Project Manager 95052

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lEFERENCES:

1. GPU Nuclear Letter to NRC, Broughton to NRC, " Inservice Inspection (ISI) Second Ten

. Year Interval-Plans and Schedules," dated April 19,1991.

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2. GPU Nuclear Letter to NRC, Broughton to NRC, " Response to NRC Request for i

. Additional Information Regarding the Second Ten Year Inservice Inspection (ISI) Interval,"

dated December 12,1991.

3. NRC Letter to GPU Nuclear, Stolz to Broughton, "Three Mile Island Unit 1 - Safety -

Evaluation on Second 10-Year Inservice Inspection Program Plan (TAC No. M80197),"

dated October 8,1992.

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4. NRC Letter to the B&W Owners Group NDE Committee Chairman, Sheron to Navratil, l

" Acceptance for Referencing of Topical Repoit BAW-2228P, Revision 1,-' Fracture l

Mechanics Assessment of Postulated Outer Surface, Semi-Elliptical Circumferential RV Nozzle-To-Pipe Weld Flaws,'" dated March 21,1996.

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5. B&W Nuclear Technologies Topical Report, BAW-2228P-A, Revision 1

" Fracture Mechanics Assessment of Postulated Outer Surface, Semi-Elliptical Circumferential RV Nozzle-to-Pipe Weld Flaws," dated September 1996.

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'6.

GPU Nuclear Letter to NRC, Langenbach to NRC, " Request for Relief Regarding Semi-Elliptical Circumferential [ Flaws in] Reactor Vessel Nozzle-To-Pipe Welds," dated '

December 19,1997.

7. NRC Letter to GPU Nuclear, Colburn to Langenbach, "Three Mile Island Nuclear Station, L

. Unit 1 (TMI-1)- Second 10-Year Interval Inservice Inspection Program Plan and Associated. Requests for Relief-Request for Additional Information (TAC No. MA0437),

dated June 1,1998.

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