ML20237B415

Advises That Project Directorate I-1 Requires Addl Info from Addressees Identified in GL 97-01, Degradation of Crdm/Cedm Nozzles & Other Vessel Closure Head Penetrations. Encl Attachments Should Be Forwarded to Licensee Contacts

ML20237B415
Person / Time
Issue date:	08/11/1998
From:	Harold J NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
GL-97-01, GL-97-1, NUDOCS 9808180242
Download: ML20237B415 (35)

Text

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UNITED STATES g

g NUCLEAR REGULATORY COMMISSION

'2 WASHINGTON, D.C. 20666-0001 8

.....,o August 11, 1998 MEMORANDUM TO:

NRR Project Directors THRU:

S. Singh Bajwa, Director g

l]'

Project Directorate 1-1 g

Division of Reactor Projects - 1/11

/

1 FROM:

Jefferey F. Harold, Project Manager 'f 7

M-d Project Directorate 1-1 Division of Reactor Projects - 1/!!

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE GENERIC RESPONSES FROM THE PRESSURIZED-WATER REACTOR (PWR) OWNERS GROUPS TO GENERIC LETTER (GL) 97-01, " DEGRADATION OF CRDM/CEDM NOZZLES AND OTHER VESSEL CLOSURE HEAD PENETRATIONS" On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nozzle and other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration (VHPs) nozzles et their respective PWR designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information requests.

The responses to the GL included generic responses from the respective Pressurized Water Reactor Owners Groups (PWROGs), and a plant specific response for each PWR owned by an NRC licensed utility. On July 25,1997, Babcock & Wilcox Owners Group (B&WOG) submitted Topical Report BAW-2301 to provide the generic response to the GL on behalf ofits member utilities. The corresponding report issued by Combustion Engineering Owners Group (CEOG) was provided in Topical Report CE NPSD-1085, which was submitted on July 25,1997. On July 18,1997, the Westinghouse Owners Group (WOG) submitted two Topical Reports, WCAP-14901 and WCAP-14902, on behalf of its members. WCAP-14901 was submitted on behalf of 1

the WOG members that are applying the Westinghouse Electric Corporation (WEC) probabilistic

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failure model to assess the VHPs at their plants; this WCAP is applicable to the majority of WOG member plants. WCAP-14902 was submitted on beha'. of the WOG members that selected an altemative probabilistic failure model as the basi for assessing the VHPs at their plants. According to the plant-specific response submitted on behalf of the Turkey Point Pl+.nt, 14 of the WOG members are applying the attemative probabilistic failure model for the assessment of the VHPs at their plants.

The staff's method for review of the responses to the GL involves the following approach:

(1) review the generic responses to the GL; (2) review the plant specific responses to the GL and compare the plant-specific responses to the generic response of the appropriate PWR Owners Group; and (3) issue final close-out letters to the PWR utilities. The plant-specific responses to f

the GL were opened under a multi-plant action (MPA).

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AH

.. m W CONTACT: Jefferey F. Harold

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415-1421 9808100242 980811 PDR ISE MISC PDR i

c' I The staff has completed its initial review of the generic responses to GL 97-01. In order to i

complete its review, the staff requires additionalinformation from the addressees identified in GL 97-01. The staff is issuing its requests for additiona! information (RAI) in six attachments.

Each of the attachments contains a propored cover letter und request for additional information.

These RAls are structured with " boiler-plate" questions that are nnplicable to each plant

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participating in a particular PWR Owners Groups integrated progqam (the exception being that the RAI for Ginna is plant-specific); however, should additional plant-specific questions be applicable to a particular plant, the questions are identified as a insert. If applicable, these inserts should be included in the RAI inquiries forwarded to the addressees.

The attachments are as follows: (1) Attachment A for the RAI to member utilities in the B&WOG; (2) Attachment B for the RAI to the member utilities in the CEOG; (3) Attachment C for the RAI to the member utilities in the WOG that have indicated that WCAP-14901, Revision 0, is applicable to their plants; (4) Attachment D for the RAI to the member utilities in the WOG that have indicated that WCAP-14902, Revision 0, is applicable to their plants; (5) Attachment E for the RAI to the member utilities in the WOG that have not indicated whether or not WCAP-14901, Revision 0, or WCAP-14902, Revision 0, is applicable to their plants; and (6) Attachment F for the RAI to Rochester Gas and Electric in regard to the response to GL 97-01 for Ginna (submitted on July 25,1997). TL.e attachments are located in S:\\GL9701.RAI. The staff requests that the attachments be forwarded to the appropriate licensee contacts. The staff requests that the responses to the RAls be submitted from the respective PWR utilities within 90 days of issuance.

Attachments: As stated j

cc w/atts: B. Boger (A) i J. Zwolinski (A)

E. Adensam (A)

DRPE/DRPW PMs i

DRPE/DRPW LAs l

D. Dorman DRPW TA I

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August 11, 1998 The staff has completed its initial review of the generic responses to GL 97-01. In order to complete its review, the staff requires additional information from the addressees identified in GL 97-01. The staff is issuing its requests for additional information (RAl) in six attachments.

Each of the attachments contains a proposed cover letter and request for additional information.

.These RAls are structured with " boiler-plate" questions that are applicable to each plant participating in a pasticular PWR Owners Groups integrated program (the exception being that the RAI for Ginna is plant-specific); however, should additional plant-specific questions be applicable to a particular plant, the questions are identified as a insert. If applicable, these inseris should be included in the RAI inquiries forwarded to the addressees.

The attachments are as follows: (1) Attachment A for the RAI to member utilities in the B&WOG; l

(2) Attachment B for the RAI to the member utilities in the CEOG; (3) Attachment C for the RAI to

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the member utilities in the WOG that have indicated that WCAP-14901, Revision 0, is applicable to their plants; (4) Attachment D for the RAI to the member utilities in the WOG that have indicated that WCAP-14902, Revision 0, is applicable to their plants; (5) Attachment E for the RAI to the member utilities in the WOG that have not indicated whether or not WCAP-14901, Revision 0, or WCAP-14902, Revision 0, is applicable to their plants; and (6) Attachment F for the RAI to Rochester Gas and Electric in regard to the response to GL 97-01 for Ginna (submitted on July 25,1967).. The attachments are located in S:\\GL9701.RAl. The staff

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requests that the attachments be forwarded to the appropriate licensee contacts. The staff l

requests that the responses to the RAls be submitted from the respective PWR utilities within 90 days of issuance.

Attachments: As stated ORIGINAL SIGNED BY:

G. VISSING FOR S. BAJWA AND I

cc w/atts: B. Boger (A)

J. HAROLD J. Zwolinski (A)

E. Adenssm (A)

DRPE/DRPW PMs l

DRPE/DRPW LAs i

D. Dorman l

DRPW TA l

1 i

DISTRIBUTION:

(Contral Puea L

PUBLIC i

PDI-1 R/F l

J. Zwolinski (A)

S. Bajwa S. Little J. Harold -

M. Chaney l'

• See previous for concurrence l

DOCUMENT NAME: G:\\lP2\\lP29701.RAI To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E"

= Copy with attachment / enclosure "N" = No copy 0FFICE-PM:P01 1

,lE LA:P01-1M) l 0:PDI 1 l

TA:DRPE(A)*

l l

NAME JNarold:lc 6 SLitti V SBajus / / 7 DDormen DATE 08/// /98 I I 08/12198 08/// /98 08/11/98 08/ /98 4

l August 11, 1998

-2 The staff has completed its initial review of the generic responses to GL 97-01, in order to complete its review, the staff requires additional information from the addressees ideritified in GL 97-01. The staff is issuing its requests for additional information (RAl) in six affachments.

1 Each of the attachments contains a proposed cover letter and request for additIo' nal information.

I These RAls are structured with " boiler-plate" questions that are applicable to'esch plant participating in a particular PWR Owners Groups integrated program (tjw(exception being that the RAI for Ginna is plant-specific); however, should additional plant-specific questions be applicable to a particular plant, the questions are identified as a insert. If applicable, these i

inserts should be included in the RAI inquiries forwarded to the addressees.

The attachments are as follows: (1) Attachment A for th I to member utilities in the B&WOG; (2) Attachment B for the RAI to the member utilities in t CEOG; (3) Attachment C for the RAI to l

the member utilities in the WOG that have indicated t t WCAP-14901, Revision 0, is applicable l

to their plants; (4) Attachment D for the RAI to the rpdmber utilities in the WOG that have indicated that WCAP-14902, Revision 0, is applica6ie to their plants; (5) Attachment E for the RAI to the member utilities in the WOG that haye not indicated whether or not WCAP-14901, Revision 0, or WCAP-14902, Revision 0, is applicable to their p! ants; and (6) Attachment F for the RAI to Rochester Gas and Electric in rpard to the response to GL 97-01 for Ginna l

(submitted on July 25,1997). The staff r quests that the attachments be forwarded to the l

appropriate licensee contacts. The sta requests that the responses to the RAls be submitted i

from the respective PWR utilities wit n 90 days of issuance.

Attachmen's: As stated cc w/atts: B. Boger (A)

J. Zwolinski (A)

E. Adensam

)

OriginalSigned by; DRPE/DR PMs G.Vissing acting Dir. PDI-1 DRPE/D W LAs and D.Do n

J. Harold, PM DRP TA i

DISTRIBUTION:

l Central ile PUBLI-l PDI-} R/F l

J. Z)kolinski(A) 6jJajwa Sr. Little J. Harold M. Chaney DOCUMENT NAME: G:\\lP2\\lP29701.RAI To receive a copy of this document, indicato its the box: "C" = Copy without attachmerit/ enclosure "E"

= Copy with attachment / enclosure "N" =,.No copy.

OFFICE PM:PDI 1 G,1.d_

lE LAPDI-M\\l l

DPOI 1 l

TAIDRPE(A},

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NAME JHarold:tec'j'l SLitti V S8ajwa / [ 7 DDormen A({h DATE 08/fi/98 08/ h /98 08/// /9ti 08/lf /98 " '

08/ /98 Official Record Copy I

4 L

1 John (Jane) Doe Utility Address

SUBJECT:

GENERIC LETTER (GL) 97-01, " DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS," RESPONSES FOR PLANT (S)[ FILL IN THE APPLICABLE B&WOG UNIT (S)]

Dear Mr. (Ms.,

Dr. etc.) Doel On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nozzle and other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a descript on d the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staffs information requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish to determine their inspection activities based on an integrated industry inspection program...,"

i and indicated that it did not object to individual PWR licensees basing their inspection activities l

on an integrated industry inspection program.

As a result, the B&WOG determined that it was appropriate for its members to develop a cooperative integrated inspection program in response to GL 97-01. The B&WOG program is documented in Topical Report BAW-2301, " Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations,"which was prepared by Iramatome Technologies, Incorporated (FTI) on behalf of the B&WOG and the following B&WOG member utilities and plants:

General Public Utilities - Three Mile Island Unit 1 Duke Power Company - Oconee Nuclear Station Units 1,2, and 3 Entergy Operations, Inc. - Arkansas Nuclear One Unit 1 Centerior Energy Corp. - Davis Besse Nuclear Plant Florida Power Corporation - Crystal River Unit 3 The B&WOG submitted its integrated program and Topical Report BAW-2301 to the staff on July 25,1997.

The staff has determined by letters dated [fillin the months and days of the 30 day and 120 day responses to GL 97-01), that you were a member of the B&WOG and a participant in the B&WOG integrated program that was developed to address the staffs requests in GL 97-01. In l

your letters of dates [fillin the months and days of the 30 day and 120 day responses to GL i

97-01J, you also indicated that the information in Topical Report BAW-2301 is applicable with respect to the assessment of VHP nozzles at plant (s)[fillin the names of the applicable B&WOG plant (s)].

The staff has reviewed your responses to GL 97-01, dated [fil/In the months and days of the 30 day and 120 day responses to GL 97-01J, and requires further information to complete its review of the responses as they relate to the B&WOG's integrated program for assessing VHP nozzles at B&WOG member plants, and to the contents of Topical Report No. BAW-2301.

Attachment A l

i

Mr. John Doe (

I The enclosure to this letter forwards staff's inquiries in the form of a request for additional information (RAl). The staff requests a response to the RAI within 90 days of the submittal date, it should be noted that similar staff requests have been issued to the other B&WOG member I

utilities. As was the staffs position before, the staff encourages you to address these inquiries in integrated fashion with the B&WOG; however the staff also requests that you identify any t

deviations from the B&WOG's integrated program that may be specific to your facilities. The staff appreciates the erforts expended with respect to this matter.

Sincerely, James Smith (fillyournameJ, Project Manager Project Directorate (fill PD NumberJ Division of Reactor Projects [f1/1In 1/11or//l//VJ Office of Nuclear Reactor Regulation

Enclosure:

Request i er Additional Information cc w/ encl: See next page DISTRIBUTION:

use misc. dist.

add EMCB DOCUMENT NAME:G:\\

To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E"

= Copy with attachment / enclosure "N" = No copy 0FFICE PM:PD lEl LA:PD l

D:PD l

3 L

NAME DATE Official Record Copy

{

Request for Additional information for Utilities Participating in the Babcock and Wilcox Owners Group (B&WOG)

Integrated Response to Generic Letter (GL) 97-01,

" Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations" Applicability of Topical Report Number BAW-2301 to the Plant-Specific Responses to GL 97-01 for Participating Member Utilities and Plants in the B&WOG The methodology developed by Framatome Technology Incorporated (FTI) for predicting the susceptibility of vessel head penetration nozzles in B&WOG plant designs is provided in j

3 Appendix B to the report, " Description of GRDM Nozzle PWSCC inspection and Repair atrategic i

Evaluation Mochl." The GRDM Nozzle PWSCC inspection and Bepair Strategic Evaluation (CIRSE) methodology for crack initiation is dependent on the calculation of a Relative Susceptibility Factor (RSF), which in part is a function of a number of multiplicative adjustment factors (e.g., the material factors, fabrication factors, and water chemistry factors). FTl has assumed that there is little variability in the alloying chemistries and microstructure of the heats used to fabricate the B&W CRDM penetration and thermocouple nozzles, and has therefore set the values for these multiplicative adjustment factors to a value of 1.0. This simplifies the CIRSE crack initiation model to one that is simply based on the applied nozzle stresses and nozzle operating temp + atures. The approach taken does not appear to be consistent with the ranges of data provided in Table 1 of the report, "CRDM Nozzle Heats at B&W-Design Plant," which provides the yield strengths, ultimate tensile strengths, and carbon contents for the B&W CRDM penetration nozzle material heats. The data in Table 1 of the report imply that there may be some variability in the chemistries and microstructure of the Alloy 600 material heats used to

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fabricate the B&W CRDM penetration nozzles.

Topical Report No. BAW-2301 also provides the B&WOG's inspection schedule and scope for VHP nozzles in B&W designed plants. In this section, the B&WOG indicated that the schedule for VHP nozzle inspections was developed based on the susceptibility assessments of the B&W

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CRDM penetration nozzles and thermocouple nozzle heats. The specific results of the CRDM I

penetration nozzle susceptibility rankings for the B&WOG plants were not provided in the report; l

however, the B&WOG has indicated that additionalinspections of the B&W fabricated CRDM l

penetration nozzles have been scheduled for the 1999 refueling outages (RFOs) of the Oconee Nuclear Station Unit 2 (ONS-2) and at Crystal River Unit 3 (CR-3) plants. In addition, FTl has I

also indicated that additional inspections of the thermocouple nozzles at Three Mile Island Unit 1

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(TMI-1) and Oconee Nuclear Station Unit 1 (ONS-1) are tentatively scheduled for the year 2001.

Therefore, with respct to the design of the CIRSE crack initiation and crack growth models, the susceptibility rankings for vessel head penetrations in B&W designed plants, the proposed CRDM nozzle inspections at ONS-2 and CR-3, and the postulated inspections of the instrumentation nozzles at TMI-1 and ONS-1, the staff requests the following information:

1. Provide a description of how the various product forms, material specifications, and heat treatments used to fabricate each CRDM penetration nozzle at the B&WOG member j

utilities are handled in the CIRSE model.

1

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2. Provide any additional information, if available, regarding how the model will be refined to allow the input of plant-specific inspection data into the model's analysis methodology.

Enclosure

s.

2-

3. Describe how FTl's crack initiation and crack growth models for assessing postulated flaws in vessel head penetration nozzles were bench-marked, and a listing and discussion of the standards the models were bench-marked against.

4. Provide the latest CIRSE model susceptibility rankings of B&W designed facilities based on the CIRSE model analysis results compiled from the analyses of the CRDM and instrumentation nozzles at the facilities.

Insert 1 for the RAI to the Duke Power Comnanv for Oconee (ONS) Units 1. 2. and 3

5. Compare the overall susceptibility rankings of the thermocouple nozzles at ONS-1 to that of the plants with the most susceptible ranked CROM penetration nozzles.

Based on this assessment, Indicate whether the thermocouple nozzles at ONS-1 will be inspected during the year 2001 refueling outage. ifit is determined that the thermocouple nozzles will not be Inspected, provide the basis for omitting the inspections of the thermocouple nozzles in the year 2001.

Insert 2 for the RAI to General Public Utilities for Three Mlle Island Unit 1 (TMI-1) 5.

Compare the overall susceptibility rankings of the thermocouple nozzles at TMI-1 to that of the plants with the most susceptible ranked CROM penetration nozzles.

' Based on this assessment, Indicate whether the thermocouple nozzles et TMI-1 will be inspected during the year 2001 refueling outage. Ifit is determined that the thermocouple nozzles will not be Inspected, provide the basis for omitting the inspections of the thermocouple nozzles in the year 2001.

6.

Given that the TMI-1 facility experienced an extendedintrusion of thiosulfate ions into the TMI-1 RCS, and since the degradation of Alloy 600 steam generator tubes at TMI-1 has In part been attributed to this event, Justify why the Alloy 600 CRDM penetration nozzles at TMI-1 are not being scheduled for volumetric inspection in the near term.

l i

l

i s.

John (Jane) Doe Utility Address

SUBJECT:

GENERIC LETTER (GL) 97-01, " DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS" RESPONSES FOR PLANT (S)[ FILL IN THE NAMES OF THE APPLICABLE CEOG PLANT (S)] AND THE RELATIONSHIP OF THE RESPONSES TO TOPICAL REPORT NO. CE NPSD-1085

Dear Mr. (Ms.,

Dr. etc.) Doe:

On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nonle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration noules (VHPs) at their resped've pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information requests, in the discussion section of the GL, the staff stated that "individuallicensees may wish to determine their inspection activities based on an integrated industry inspection program...,"

and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspection program.

l As a result, the CEOG determined that it was appropriate for its members to develop a cooperative integrated inspection program in response to GL 97-01. The CEOG program is documented in Topical Report No. CE NPSD 1085, "CEOG Response to NRC Generic Lette, 97-01, Degradation of CEDM Nonle and Other Vessel Closure Head Penetrations," which was j

prepared by ABB Combustion Engineering Nuclear Operations (ABB-CE) on behalf of the CEOG and the following CEOG member utilities and plants:

I Arizona Public Service - Palo Verde Units 1,2, and 3 Baltimore Gas and Electric Company - Calvert Cliffs Units 1 and 2 i

l Consumers Energy-Palisades Entergy Operations, Inc. - Arkansas Nuclear One Unit 2 and Waterford Unit 3 Florida Power and Light Company - St. Lucie Units 1 and 2 Northeast Utilities - Millstone Unit 2 Maine Yankee Atomic Power Company - Maine Yankee Nuclear Plant Omaha Public Power District - Fort Calhoun Unit 1 Southem Califomia Ed: son Company-San Onofre Units 2 and 3 The CEOG submitted its integrated program and Topical Report CE NPSD-1085 to the staff on July 25,1997.

[

The staff has determined by letters dated (fillin the months and days of the 30 day and 120 day responses to GL 97-Off, that you were a member of the CEOG and a participant in the CEOG integrated program that was developed to address the staff's requests in GL 97-01. In your letters of dates [fillin the months and days of the 30 day and 120 day responses to GL 97-01J, you also indicated that the information in Topical Report CE NPSD 1085 is applicable with respect to the assessment of VHP noules at plant (s)[fillin the names of the appilcable CEOG plant (s)J.

Attachment B I

t.

Mr. John Doe 2

The staff has reviewed your responses to GL 97-01, dated [fil/In the months and days of the 30 day and 120 day responses to GL 97-Off, and requires further information to complete its review of the responses as they relate to the CEOG's integrated program for assessing VHP nozzles at CEOG member plants, and to the contents of Topical Report No. CE NPSD-1085.

The enclosure to this letter forwards staffs inquiries in the form of a request for additional information (RAI). The staff requests a response to the RAI within 90 days of the submittal date.

It should be noted that similar staff requests have been issued to other CEOG member utilities.

As was the staffs position before, the staff encourages you to address these inquiries in integrated fashion with the CEOG; however, the staff also requests that you identify any deviations from the CEOG's integrated program that may be specific to your facilities. The staff appreciates the efforts expended with respect to this matter, Sincerely, Jane Smith [fillyourname], Project Manager Project Directorate (fill PD Number]

Division of Reactor Projects [fillIn Vil orllVIV]

Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION:

use misc. dist.

add EMCB l

DOCUMENT NAME:G:\\

To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E"

= Copy with attachment / enclosure

• N" = No copy 0FFICE PM:PD lE LA:PD l ) D:PD l

l l

l L

NAME DATE 08/ /98 Official Record Copy t

\\

I Request for Additional information Regarding Utilities Participating I

in the Combustion Engineering Owners Group (CEOG)

Response to Generic Letter (GL) 97-01

" Degradation of CEDM Nonle and Other l-

. Vessel Closure Head Penetrations"-

Topical Report CE NPSD 1085, Revision 0 Applicability of Topical Report Number CE NPSD-1085 to the l'

Plant-specific Responses to GL 97-01 for Participating Member Utilities and Plants in the CEOG The ABB - Combustion Engineering Corporation's (ABB-CE's) methodology for predicting the susceptibility of vessel head penetration nonles in the CEOG plant designs is provided in Section 2.4 of CE Topical Report No. CE NPSD-1085, which was submitted to the staff in July 25,1997. ABB-CE's methodology applies a probabilistic inspection timing model (PITM) to predict the probability of having a given Contro' Element Drive Mechanism (CEDM) penetration nozzle or in-core instrumentation (ICl) nonle fail in service. With respect to the PITM model, the term " failure" does not refer to a compromise of the structuralintegrity of the reactor coolant pressure boundary, but rather that the presence of a non-throughwall flaw may require attention or repair.

_ Since that time, the etaff has leamed informally that the CEOG has decided to change the i

l methodology for eva.uating the CRDM penetration nonles in ABB-CE designed plants, and lately has adopted a CEDM penetration nonle crack initiation and growth susceptibility model that has been developed by the Dominion Engineering Company. However, the CEOG has not submitted an addendum to its response of July 25,1997, informing the staff of its decision to change the susceptibility model being adopted by the Owners Group member utilities. The staff requests the following information be provided with respect to content of your plant-specific response to GL 97-01, and its relationship to the CEOG integrated program for assessing the potential for CEDM penetration nonles to undergo primary stress corrosion cracking (PWSCC) or intergranular attack (IGA):

1. Designate which crack susceptibility modelis being endorsed for the assessment of CEDM penetration nonles at your plant (s). Indicate how the susceptibility model being endorsed relates to the CEOG's integrated program for assessing the CEDM penetration nonles at ABB-CE designed plants, and whether or not the design of the susceptibility modelis consistent with the contents of Topical Report CE NPSD-1085. If the ABB-CE's PITM modelis being endorsed for the assessment of CEDM penetration nonles at your plant (s), address the items a. - e. that follow. If the Dominion Engineering susceptibility model is being endorsed for the assessment of CEDM penetration nonles at your plant (s), address the items g. - k. that follow.

If the PITM models are beino endorsed for the assessment of vour CEDM penetration nonles-s.

Provide an expanded discussion and additional details describing how the time-to-failure model in the PITM relates to the PITM's time-to-initiation model. In particular, includo an expanded discussion of how the PITM model relates growth of postulated flaws to the time-to-initiation model, and how the two aspects relate to each other and to the probability of failure methodology.

Enclosure I

I b.

Provide the latest PITM susceptibility ranking of CEDM penetration nonles, and if applicable of the vessel head instrumentation nonles at your plant (s) relative to the renkings of those at the other CEOG member plants.

Provide a description of how the PITM model for assessing postulated flaws in c.

yessel head penetration nonles was bench-marked, and list and discuss the l

standards the models were bench-marked against.

j d.

Provide any additional information regarding how the model will be refined to allow the input of plant-specific inspection data into the moders analysis methodology.

Describe how the variability in the product forms, material specifications, and heat e.

treatments used to fabricate each CEDM penetration nonle at the CEOG member utilities are addressed in the PITM model.

If the susceotibilitv model develooed bv Dominion Enaineerina is beino endorsed for the assessment of vour CEDM penetration nonfes:

f.

Provide a description of how the various product forms, material specifications, and heat treatments used to fabricate each CEDM penetration nonle at the CEOG member utilities are handled in the Dominion Engineering susceptibility model.

g.

Provide any additional information, if available, regarding how the model will be refined to allow the input of plant specific inspection data into the model's analysis methodology.

h.

Describe how the Dominion Engineering crack initiation and crack growth models for assessing postulated flaws in vessel head penetration nonles were bench-marked, and a listing and discussion of the standards the models were bench-marked against.

l.

Provide the latest model susceptibility rankings of CEDM penetration nonles in CEOG member plants based on the results of the Dominion Engineering susceptibility model analyses of these CEDM and ICI nonles.

l 1

I Mr. John Doe 2

The staff requests a response to the RAI within 90 days of the submittal date. It should be noted that similar staff requests have been issued to other WOG member utilities. As was the staffs j

position before, the staff encourages you to address these inquiries in integrated fashion with i

l the WOG and the Nuclear Energy Institute (NEI); however, the staff also requests that you identify any deviations from the WOG's integrsted program that may be specific to your facilities.

i l

The staff appreciates the efforts expended with respect to this matter.

u l-Sincerely, James Smith (fillyourname], Project Manager Project Directorate [ fill PD Number]

Division of Reactor Projects [ fillin Vil orllVIV)

Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION:

use misc. dist.

add EMCB DOCUMENT NAME:G:\\

To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E"

= Copy with attachment / enclosure "N" = No copy DFFICE PM:PD lE LA:PD l

D:PD l

l

[

NA"E DATE Official Record Copy l

l John (Jane) Doe Utility Address

SUBJECT:

GENERIC LETTER (GL) 97 01," DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS" RESPONSES FOR PLANT (S)[ FILL IN THE NAMES OF THE APPLICABLE WOG PLANT (S)J

Dear Mr. (Ms.,

Dr. etc.) Doe:

On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM l

. Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that I

addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-u-response within 120 days of issuance containing the technical details to the staffs information s

requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish to determine their inspection activities based on an integrated industry inspection program...,"

and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspection program.

j As a result, the WOG determined that it was appropriate for its members to develop a cooperative integrated inspection program in response to GL 97-01. The WOG program is documented in two Topical Reports issued by the Westinghouse Electric Corporation (WEC),

(

WCAP-14901, Revision 0, " Background and Methodology for Evaluation of Reactor Vessel l

Closure Head Penetration Integrity for the Westinghouse Owners Group," and WCAP-14902, Revision 0, " Background Material for Response to NRC Generic Letter 97-01: Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group."

The WOG submitted the integrated programs described in WCAP-14901 and WCAP-14902 to the staff on July 25,1997.

The staff has determined by letters dated [fillin the months and days of the 30 day and 120 day responses to GL 97-01), that you were a member of the WOG and a participant in the WOG integrated program that was developed to address the staffs requests in GL 97-01. In your letters of dates [fillIn the months and days of the 30 day and 120 day responses to GL 97-01J, you also indicated that the information in WEC Topical Report WCAP-14901 is applicable with respect to the assessment of VHP nozzles at plant (s)[fillin the names of the applicable WOG plant (s)J.

The staff has reviewed your responses to GL 97-01, dated [f/// /n the months and days of the 30 day and 120 day responses to GL 97-01J, and requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG member plants, and to the contents of Topical Report No. WCAP-14901. The

(

enclosure to this letter forwards staffs inquiries in the form of a request for additionalinformation i

(RAI).

j Attachment C i

l

Request for Additional Information Regarding Utilities Participating l

in the Westinghouse Owners Group (WOG)

Response to Generic Letter (GL) 97-01

" Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group" Topical Report No. WCAP-14901, Revision 0 Applicability of Topical Report No. WCAP-14901, Revision 0, to the Plant-specific Responscs to GL 97-01 for Participating Member Utilities and Plants in the WOG l.

Relationship and Applicability of WCAP-14901, Revision 0, to GL 97-01 and the WOG On f pril 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the j

issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staffs information j

requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish j

to determine their inspection activities based on an integrated industry inspection program.,,"

)

and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspection program.

As a result, the WOG determined that it was appropriate for its members to develop a cooperative integrated inspection program in response to GL 97-01. The WOG program is documented in two Topical Reports issued by the Westinghouse Electric Corporation (WEC),

WCAP-14901, Revision 0, " Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group," and WCAP-14902, Revision 0, " Background Material for Response to NRC Generic Letter 97-01: Reactor Vessel closure Head Penetration Integrity for the Westinghouse Owners Group."

The technical content provided in WCAP-14901, Revision 0, is basically the same as that provided in WCAP-14902. The difference with regard to the reports is that WOG member plants subscribing to the content of WCAP-14901 have opted to rank the susceptibility of their vessel head penetrations according to a probabilistic Weibull analysis method that was developed by WEC. In contrast, the WOG member plants subscribing to the content of WCAP-14902, Revision 0, have opted to rank the vessel head penetrations for their facilities according to a probabilistic methodology that was developed by another vendor of choice. The staff has determined by letters dated (fillin the months and days of the 30 day and 120 day responses 1

l to GL 97-01J, that you were a member of the WOG and a participant in the WOG integrated program that was developed to address the staffs requests in GL 97-01. In yourletters dated

[fillIn the months and days of the 30 day and 120 day responses to GL 97-01], you also indicated that the information in WEC Topical Report WCAP-14901 is applicable with respect to the assessment of VHP nozzles at plant (s)(fillin the names of the appilcable WOG plant (s)].

l l

l Enclosure l

-________________.______a

. The staff has reviewed your responses to GL 97-01, dated [ fill /n the months and days of the 30 day and 120 day responses to GL 97-01), and requires further information to complete its i

review of your responses as they relate to the WOG's integrated program for assessing VHP nonles at WOG member plants, and to the contents of Topical Report No. WCAP-14901. The staff requests the following information with respect to the content of your responses to GL 97-01, dated [fillin the months and days of the 30 day and 120 day responses to G'. 97-01],

and to the content of WCAP-14901 as it relates to these responses:

1. In WCAP-14901 WEC did not provide any conclusions as to what the probabilistic failure model would lead the WOG to conclude with respect to the assessment of PWSCC in WEC-designed vessel head penetrations. With respect to the probabilistic susceptibility model (e.g., probabilistic failure model) provided in WCAP-14901:

Provide the susceptibility rankings compiled for the WOG member plants for which a.

WCAP-14901 is applicable, in regard to other WOG member plants to which WCAP-14901 is applicable, include the basis for establishing the ranking of your plant (s) relative to the others, b.

Describe how the probabilistic failure model in WCAP-14901 for assessing postulated flaws in vessel head penetration nonles was bench-marked, and provided a list and discussion of the standards the model was bench-marked against.

Provide additional information regarding how the probabilistic failure models in c.

WCAP-14901 will be refined to allow the input of plant-specific inspection data into the model's analysis methodology.

d.

Describe how the variability in product forms, material specifications, and heat treatments used to fabricate each CRDM penetration nonle at the WOG member utilities are addressed in the probabilistic crack initiation and growth models described or referenced in Topical Report No. WCAP-14901.

2. Table 12 in WCAP-14901 provides a summary of the key tasks in WEC's vessel head penetration nonle assessment program. The table indicates that the Tasks for (1)

Evaluation of PWSCC Mitigation Methods, (2) Crack Growth Data and Testing, and (3)

Crack initiation Characterization Studies have not been completed and are still in progress. In light of the fact that the probabilisti susceptibility models appear to be dependent in part on PWSCC crack initiation and growth estimates, provide your best i

estimate when these tasks will be completed by WEC, and describe how these activities I

relate to and will be used to update the probabilistic susceptibility assessment of VHP nonles at your plant (s).

L_-___

)

i l

3

(

Insert 1 - Acclicable to the RAls to All WOG Atember Plants Endorsina WCAP-14901.

Revision 0. Other Than RAls for Diablo Canvan Units 1 and 2. and Farfev Unit 1 and 2

3. In the NElletters of January 29,1998 (Ref.1), and April 1,1998 (Ref. 2), NEl Indicated that inspection plans have been developed for the VHP nozzles at the Farley Unit 2 plant in the year 2002, and the Diablo Canyon Unit 2 plant in the year 2001, respectively. The staff has noted that although you have endorsed the pmbebilistic susceptibility model described in WCAP-14901, Revision 0, other WOG member licensees have endorsed a probabilistic susceptibility model developed by an attemate vendor of choice. The WOG's proposal to inspect the VHP nozzles at the Farley Unit 2 and Diablo Canyon Unit 2 plants appears to be based on a composite assessment of the VHP nortles at all WOG memberplants. Verify that such a composite ranking assessment has been applied to the evaluation of VHP nozzles at yourplant(s). If composite rankings of the VHP nozzles at WOG memberplants have been obtained from the composite results of the two models, justify why appilcation of the probabilistic susceptibility model described In WCAP-14901, Revision 0, would yleld the same comparable relative rankings of the VHP nozzles foryourplant(s) as would appilcation of the attemate probabilistic susceptibility model used by the WOG memberplants not subscribing to WCAP 14901, Revision 0. Comment on the susceptibility rankings of the VHP nozzles at yourplant(s) relative to the susceptibility rankings of the VHP nozzles at the Farley Unit 2 and Diablo Canyon Ur.,t 2 plants.

Insen 2 - AnnIIcable to the RAI for the Diablo Canvon Nuclear Plant. Units 1 and 2

3. In the NElletters of January 29,1998 (Ref.1), and April 1,1998 (Ref. 2), NEI Indicated that inspection plans have been developed for the VHP nozzles at the Farley Unit 2 plant in the year 2002, and the Diablo Canyon Ualt 2 plant in the year 2001, respectively. The staff has noted that although you have endorsed the probabilistic susceptibility model described in WCAP-14901, Revision 0, other WOG memberlicensees have endorsed a probabilistic susceptibility model developed by an attemate vendor of choice. The WOG's proposal to inspect the VHP nozzles at the Faricy Unit 2 and Diablo Canyon Unit 2 plants appears to be based on a composite assessment of the VHP nozzles at all WOG memberplants. Verify that such a composite ranking assessment has been applied to the evaluation of VHP nozzles atyourplants. If composite rankings of the VHP nozzles at WOG memberplants have been obtained from the composite

\\

results of the two models, justify why appilcation of the probabilistic susceptibility model describedin WCAP-14901, Revision 0, wouldyleId the same comparable relative rankings for the VHP nozzles at the Diablo Canyon Unit 1 and Unit 2 plants as would appilcation of the attemate probabilistic susceptibility model used by the l

?

WOG memberplants not subscribing to WCAP-14901, Revision 0. Comment on the susceptibility rankings of the VHP nozzles at the Diablo Canyon Unit 1 and Unit 2 plants relative to the susceptibility rankings of the VHP nozzles at other WOG memberplants.

1 4

Insert 3 - Anal! cable to the RAI for the J.M Farlev Nuclear Plant. Units 1 and 2

3. In the NElletters of January 29,1998 (Ref.1), and April 1,1998 (Ref. 2), NEl Indicated that inspection plans have been developed for the VHP nozzles at the Farley Unit 2 plant in the year 2002, and La e Diablo Canyon Unit 2 plant in the year 2001, respectively. The staff has noted that although you have endorsed the

'probabilistic susceptibility model describedin WCAP-14901, Revision 0, other WOG member licensees have endorsed a probabilistic susceptibility model developed by an alternate vendor of choice. The WOG's proposal to inspect the VHP nozzles at the Farley Unit 2 andDiablo Canyon Unit 2 plants appears to be based on a composite assessment of the VHP nozzles at all WOG memberplants. Verify that such a composite ranking assessment has been applied to the evaluation of VHP nozzles atyourplants. If composite rankings of the VHP nozzles at WOG memberplants have been obtained from the composite results of the two moaels, justify why application of the probabilistic susceptibility model describedin WCAP-14901, Revision 0, would yleid the same comparable relative rankings for the VHP nozzles at the Farley Unit 1 and Unit 2 plants as would appilcation of the alternate probabilistic susceptiblilty model used by the WOG memberplants not subscribing to WCAP 14901, Revision 0. Comment on the susceptibility rankings of the VHP nozzles at the Farley Unit 1 and Unit 2 plants reistive to the susceptibility rankings of the VHP nozzles at other WOG member plants.

BEFERENCES

1. January 19,1998 - Letter from David J. Modeen, Director of Engineering, Nuclear Generation Division, Nuclear Energy Institute, to Mr. G.C. Lainas, Acting Director, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (Untitled).

2. April 1,1995 - Letter from David J. Modeen, Director of Engineering, Nuclear Generation Division, Nuclear Energy Institute, to Mr. G.C. Lainas, Acting Director, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission,

SUBJECT:

Generic Letter 97-01, ' Degradation of Control Rod Drive Mechanism Nozzle and Other Vessel Head Penetrations.' "

L

John (Jane) Doe Utility Address

SUBJECT:

GENERIC LETTER (GL) 97-01, " DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS" RESPONSES FOR PLANT (S)[ FILL IN THE NAMES OF THE APPLICABLE WOG PLANT (S)]

Dear Mr. (Ms.,

Dr. etc.) Doe:

On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish to determine their inspection activities based on an integrated industry inspection program...,"

and indicaterl that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspection program.

' As a result, the WOG determined that it was appropriate for its members to develop a cooperative integrated inspec%n program in response to GL 97-01. The WOG program is documented in two Topical Reports issued by the Westinghouse Electric Corporation (WEC),

WCAP-14901, Revision 0, " Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group," and WCAP-14902, Revision 0, " Background Material for Response to NRC Generic Letter 97-01: Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group."

The WOG submitted the integrated programs described in WCAP-14901 and WCAP-14902 to the staff on July 25,1997.

The staff has determined by letters dated [fillin the months and days of the 30 day and 120 day responses to GL 97-Off, that you were a member of the WOG and a participant in the WOG integrated program that was developed to address the staff's requests in GL 97-01. In your letters of dated (fillin the months and days of the 30 day and 120 day responses to GL 97-Off, you also indicated that the information in WEC Topical Report WCAP-14902 is applicable with respect to the assessment of VHP nozzles at plant (s)[fillin the names of the applicable WOG plant (s)];.

The staff has reviewed your responses to GL 97-01, dated [ fill /n the months and days of the l

30 day and 120 day responses to GL 97-01), and requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG member plants, and to the contents of Topical Report No. WCAP-14902. The enclosure to this letter forwards staff's inquiries in the foan of a request for additional information (RAl).

Attachment D l'

Mr. John Doe 2

The staff requests a response to the RAI within 90 days of the submittal date it should be noted that similar staff requests have been issued to other WOG member utilities. As was the staffs position before, the staff encourages you to address these inquiries in integrated fashion with the WOG and the Nuclear Energy Institute (NEI); however, the staff also requests that you identify any deviations from the WOG's integrated program that may be specific to your facilities.

The staff appreciates the efforts expended with respect to this matter.

Sincerely, Jane Smith (fillyourname], Project Manager Project Directorate (fill PD Number]

Division of Reactor Projects [ fillin Vil orllVIV]

Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION:

use misc. dist, add EMCB DOCUMENT NAME:G:\\

To r::ceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E"

= Copy with attachment / enclosure "N" = No copy DFFICE PM:PD lE LA:PD l

0 PD l

l l__

NAME DATE Official Record Copy i

j Request for Additional Information Regarding Utilities Participating in the Westinghouse Owners Group (WOG) Response to Generic Letter (GL) 97-01 Topical Report No. WCAP-14902, Revision 0

" Background Material for Response to NRC Generic Letter 97-01 1

Reactor Vessel Closure Head Penetration integrity I

for the Westinghouse Owners Group" Applicability of Topical Report No. WCAP-14902, Revision 0, to the Plant-specific Responses to GL 97-01 for Participating Member Utilities and Plants in the WOG j

l 1.

Relationship and Acolicability of WCAP-14902. Revision O. to GL 97-01 and the WOG On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nozzle and other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit n initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish to determine their inspection activities based on an integrated industry inspection program...,"

and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspection program.

)

As a resu't, the WOG determined that it was appropriate for its members to develop a cooperative integrated inspection program in response to GL 97-01. The WOG program is i

documented in two Topical Reports issued by the Westinghouse Electric Corporation (WEC),

l WCAP-14901, Revision 0, " Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration integrity for the Westinghouse Owners Group," and WCAP-14902,

)

Revision 0, " Background Material for Response to NRC Generic Letter 97-01: Reactor Vessel Closure Head Penetration integrity for the Westinghouse Owners Group."

The technical content provided in WCAP-14902, Revision 0, is basically the same as that provided in WCAP-14901, Revision O. The difference with regard to the reports is that WOG member plants subscribing to the content of WCAP-14901 have opted to rank the susceptibility of their vessel head penetrations according to a probabilistic Weibull analysis method that was developed by WEC. In contrast, the WOG member plants subscribing to the content of WCAP-14902, Revision 0, have opted to rank the vessel head penetrations for their facilities according to a probabilistic methodology that was developed by another vendor of choice. The staff has determined by letters dated [fillin the months and days of the 30 day and 120 day rsponses to GL 97-01J, that you were a member of the WOG and a participant in the WOG integrated program that was developed to address the staff's requests in GL 97-01. In your letters dated (fillin the months and days of the 30 day and 120 day responses to GL 97-01],

you also indicated that the information in WEC Topical Report WCAP-14901 is applicable with respect to the assessment of VHP nozzles at' plant (s)[fillin the names of the applicable WOG plant (s)].

Enclosure

l

! The staff has reviewed your responses to GL 97-01, dated /fil!In the months and days of the 30 day and 120 day responses to GL 97-OfJ, and requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG inember plants, and to the contents of Topical Report No. WCAP-14902, Revision O. The staff requests that the following information be submitted with respect to the content of your responses to GL 97-01, dated (fillin the months and days of the 30 day and 120 day responses to GL 97-01J, and to the content of WCAP-14902, Revision 0, as it relates to these responses:

1

1. WEC and the WOG did not provide a description of the crack initiation and growth susceptibility model used for the assessment oi WEC vessel head penetration (VHP) nozzles in plants endorsing WCAP-14902, Revision O. Provide a description of the crack initiation and growth susceptibility model used for assessment of the VHP nozzles at your plant (s).

2. In WCAP-14902, Revision 0, WEC did not provide any conclusions as to what the probabilistic failure model would lead the WOG to conclude with respect to the assessment of PWSCC in WEC-designed vessel head penetration (VHP) nozzles. With respect to the probabilistic susceptibility model (e.g., probabilistic failure model) provided in WCAP-14902, Revision 0:

Provide the susceptibility ranking of your plant (s) as compiled from the crack a.

1 initiation and growth analysis of the VHP nozzles for your plant (s) to that compiled for i

the other WOG member plants for which WCAP-14902, Revision 0, is applicable.

Include the basis for establishing the ranking of your plant (s) relative to the others.

b.

Describe how the probabilistic failure (crack initiation and growth) model in used for the assessment of the VHP nozzles at your plant (s) was bench-marked, and pro, vide a list and discussion of the standards the model was bench marked against, i

Provide additional information regarding how the probsbilistic failure (crack initiation c.

and growth) models for the assessment of VHP nozzios at your plant (s) will be retined to allow the input of plant-specific inspection data into the model's analysis methodology.

d.

Describe how the variability in product forms, material specifications, and heat treatments used to fabricate each CRDM penetration nozzle at the WOG member utilities are addressed in the probabilistic crack initiation and growth models described or referenced in Topical Report No. WCAP-14902, Revision O.

3. Table 1-2 in WCAP-14902, Revision 0, provides a summary of the key tasks in WEC's vessel head penetration nozzle assessment program. The tables indicate that the tasks for (1) Evaluation of FWSCC Mitigation Methods, (2) Crack Growth Data and Testing, and (3) Crack initiation Characterization Studies have not been completed and are stillin progress. In light of the fact that the probabilistic susceptibility models appear to be dependent in part on PWSCC crack 16ation and growth estimates, provide your best estimate when these tasks will be completed by WEC, and describe how these activities relate to and will be used to update the probabilistic susceptibility assessment of VHP nozzles at your plant (s).

4. In the NEllaters of January 29,1998 (Ref.1), and April 1,1998 (Ref. 2), NEl indicated that inspection plans have been developed for the VHP nozzles at the Farley Unit 2 plant in the year 2002, and the Diablo Canyon Unit 2 plant in the year 2001, respectively. The i

3 staff has noted that although you have decided to apply an altemate probabilistic susceptibility model to the assessment of the VHP nozzles at your plant (s), other WOG member licensees, including the Southem Nuclear Operating Company and the Pacific Gas and Electric Company, the respective licensees for the Farley units and the Diablo Canyon units, have selected to apply the susceptibility model described in WCAP-14901, Revision 0, to the assessment of VHP nonles at their plants, The WOG's proposal to inspect the CRDM penetration nozzles at Farley Unit 2 and Diablo Canyon Unit 2 appears to be based on an composite assessment of the VHP nozzles at all WOG member plants.

Verify that such a composite ranking assessment has been applied to the evaluation of VHP nozzles at your plant (s), if composite rankings of the VHP ncules at WOG member plants have been obtained from the composite results of the two models, justify why application of the altemate probabilistic susceptibility model being for the assessment of of VHP nonles at your plant (s) would yield the same comparable relative rankings as would application of the probabilistic susceptibility model used by the WOG member plants subscribing to the contents of WCAP-14901, Revision O. Comment on the susceptibility rankings of the VHP nozzles at your plant (s) relative to the susceptibility rankings of the VHP nozzles at the Farley Unit 2 and Diablo Canyon Unit 2 plants.

REFERENCES

1. January 19,1998 - Letter from David J. Modeen, Director of Engineering, Nuclear Generation Division, Nuclear Energy institute, to Mr. G.C. Lainas, Acting Director, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (Untitled).

2. April 1,1995 - Letter from David J. Modeen, Director of Engineering, Nuclear Generation Division, Nuclear Energy Institute, to Mr. G.C. Lainas, Acting Director, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission,

SUBJECT:

Generic Letter 97-01, ' Degradation of Control Rod Drive Mechanism Nozzle and Other Vessel Head Penetrations.' "

i John (Jane) Doe Utility Address

SUBJECT:

GENERIC LETTER (GL) 97-01, " DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS" RESPONSES FOR PLANT (S)[ FILL IN THE NAMES OF THE APPLICABLE WOG PLANT (S)] AND THE WESTINGHOUSE OWNERS GROUP INTEGRATED PROGRAM FOR ASSESSMENT OF WESTINGHOUSE DESIGNED VESSEL HEAD PENETRATION NOZZLES

Dear Mr. (Ms.,

Dr. etc.) Doe:

On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nonle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration noules (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staffs information requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish to detemline their inspection activities based on an integrated industry inspection program.,,"

and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated indudry inspection program.

As a result, the WOG determined that it was appropriate for its members to develop a cooperative integrated inspection program in response to GL 97-01. The WOG program is documented in two Topical Reports issued by the Westinghouse Electric Corporation (WEC),

WCAP-14901, Revision 0, " Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group," and WCAP-14902, Revision 0, " Background Material for Response to NRC Generic Letter 97-01: Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group."

The WOG submitted the integrated programs described in WCAP-14901, Revision 0, and WCAP-14902, Revision 0, to the staff on July 25,1997. The staff has reviewed your responses

. to GL 97-01, dated (fillin the inonths and days of the 30 day and 120 day responses to GL 97-01], and determined by your responses that you were a member of the WOG and a participant in the WOG integrated program that was developed to address degradation in Westinghouse designed vessel head penetration (VHP) nonles, and the staffs requests in GL 97-01. However, the staff could not determine after reviewing your responses which of the two Westinghouse Generic Topical Submittals, WCAP-14901, Revision 0, or WCAP-14902, Revision 0, is being endorsed for the assessment of the VHP nonles at your plant (s).

The staff requires further information to complete its review of your responses as they relate to l

l the WOG's integrated program for assessing VHP noules at WOG member plants. The i

enclosure to this letter forwards staffs inquiries in the form of a request for additional information (RAI). The staff requests a response to the RAI within 90 days of the submittal date. It should be noted that similar staff requests have been issued to other WOG member utilities. As was l

Attachment E O__-______-_____-

2-the staffs position before, the staff encourages you to address these inquiries in integrated fashion with the WOG and the Nuclear Energy Institute (NEI); however, the staff also requests that you identify any deviations from the WOG's integrated program that may be specific to your facilities. The staff appreciates the efforts expended with respect to this matter.

Sincerely, James Smith [fillyour name], Project Manager Project Directorate (fill PD Number]

Division of Reactor Projects [f///In Filor//FIVJ Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION:

use misc. dist.

add EMCB DOCUMENT NAME:G:\\

To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E"

= Copy with attachment / enclosure "N" = No copy 0FFICE PM:PD lE LA:PD l

D:PD l

l

[_

NAME DATE Official Record Copy l

l

I

. Request for Additional Information Regarding Utilities Participating in the Westinghouse Owners Group (WOG) Response to Generic Letter (GL) 97-01 Applicability of the WOG integrated Program for Assessing Vessel Head ~ )netration (VHP) Nozzles in Westinghouse Designed Nuclear Plants to the Plant-specific Responses to GL 97-01 for Participating Member Utilities and Plants in the WOG l.

Relationship and Applicability of WCAP-14902, Revision 0, to GL 97-01 and the WOG 1

i On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to subn,it an initial response within 30 days j

of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information l

requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish j

1 to determine their inspection activities based on an integrated industry inspection program..,"

and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspe : tion program.

)

{

As a result, the WOG determined that it was appropriate fr its members to develop a l-cooperative integrated inspection program in response to GL 97-01. The WOG program is p

documented in two Topical Reports issued by the Westinghouse Electric Corporation (WEC),

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WCAP-14901, Revision 0, " Background and Methodology for Evaluation of Reactor Vessel i

Closure Head Penetration Integrity for the Westinghouse Owners Group," and WCAP-14902, Revision 0, " Background Material for Response to NRC Generic Letter 97-01: Reactor Vessel Closure Head Penetration integrity for the Westinghouse Owners Group."

The technical content provided in WCAP-14902, Revision 0, is basically the same as that provided in WCAP-14901, Revision 0. The difference with regard to the reports is that WOG member plants subscribing to the content of WCAP-14901 have opted to rank the susceptibility of their VHP nozzles according to a probabilistic Weibull analysis method that was developed by WEC. In contrast, the WOG member plants subscribing to the content of WCAP-14902, Revision 0, have opted to rank the VHP nozzles for their facilities according to a probabilistic methodology that was developed by another vendor of choice. The staff has determined by letters dated [fillin the inonths end days of the 30 day and 120 day responses to GL 97-01],

that you were a member of the WOG and a participant in the WOG integrated program that was developed to address degradation in Westinghouse designed VHP nozzles, and the staff's requests in GL 97-01. However, the staff could not determine after reviewing your responses which of the two Westinghouse Generic Topical Submittals, WCAP-14901, Revision 0, or i

WCAP-14902, Revision 0, is being endorsed for the assessment of the VHP nozzles at your plant (s).

Enclosure

1

)

I The staff requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG member plants. The staff requests the following information with respect to the content of your responses to GL 97-01, dated [fillin the months and days of the 30 day and 120 day responses to GL 97-01], and to the WOG's integrated program for assessing VHP nozzles at WOG member plants:

1. Indicate which Westinghouse Topical Report, WCAP-14901, Revision 0, or

}

WCAP-14902, Revision 0, is being endorsed for the assessment of VHP nozzles at your plant (s), and which crack initiation and growth susceptibility model is being used for the I

assessment of the VHP nozzles at your plant (s).

i

2. Provide the following information if Topical Repori WCAP-14901 Revision 0, is being i

endorsed for the VHP nozzles at your plant (s); otherwise skip to information Rsquest 3.

In WCAP-14901, Revision 0, WEC did not provide any conclusions as to what the a.

probabilistic failure model would lead the WOG to conclude with respect to the assessment of PWSCC in WEC-designed vessel head penetrations. With respect to the probabilistic susceptibBity model (e.g., probabilistic failure model) provided in WCAP-14901:

(1)

Provide the susceptibility rankings compiled for the WOG member plants for which WCAP-14901 is applicable. In regard to other WOG member plants to which WCAP-14901 is applicable, include the basis for establishing the ranking of your plant (s) relative to the others.

l (2)

Describe how the probabilistic failure model in WCAP-14901 for assessing postulated flaws in vessel head penetration nozzles was bench-marked, and provided a list and discussion of the standards the model was bench-marked against.

(3)

Provide additionalinformation regarding how the probabilistic failure models in l

WCAP-14901 will be refined to allow the input of plant-specific i

inspection data into the model's analysis methodology.

(4)

Describe how the variability in product forms, material specifications, and heat treatments used to fabricate each CRDM penetration nozzle at the WOG member utilities are addressed in the probabilistic crack initiation and growth l

models described or referenced in Topical Report No. WCAN4901.

b.

Table 12 in WCAP-14901 provides a summary of the key tasks in WEC's VHP nozzle assessment program. The table indicates that the tasks for (1) Evaluation of PWSCC Mitigation Methods, (2) Crack Growth Data and Testing, and (3) Crack initiation Characterization Studies have not been completed and are stillin progress.

In light of the fact that the probabilistic susceptibility models appear to be dependent in part on PWSCC crack initiation and growth estimates, provide your best estimate when these tasks will be completed by WEC, and describe how these activities relate to and will be used to update the probabilistic susceptibility assessment of VHP nozzles at your plant (s).

1 I

3-In the NEl letters of January 29,1998 (Ref.1), and April 1,1998 (Ref. 2), NEl c.

indicated that inspection plans have been developed for the VHP nonles at the Farley Unit 2 plant in the year 2002, and the Diablo Canyon Unit 2 plant in the year 2001, respectively. The staff has noted that although you have endorsed the probabilistic susceptibility model described in WCAP-14901, Revision 0, other WOG member licensees have endorsed a probabilistic susceptibility model developed by an attemate vendor of choice. The WOG's proposal to inspect the VHP nonles at the Farley Unit 2 and Diablo Canyon Unit 2 plants appears to be based on a composite assessment of the VHP nonles at all WOG member plants. Verify that such a composite ranking assessment has been applied to the evaluation of VHP nonles at your plant (s). If composite rankings of the VHP nonles at WOG member plants have been obtained from the composite results of the two models, justify why application of the probabilistic susceptibility model described in WCAP-14901, Revision 0, would yield the same comparable relative rankings of the VHP nonles for your plant (s) as would application of the altemate probabilistic susceptibility model used by the WOG member plants not subscribing to WCAP-14901, Revision O. Comment on the susceptibility rankings of the VHP nonles at your plant (s) relative to the susceptibility rankings of the VHP nonles at the Farley Unit 2 and Diablo Canyon Unit 2 plants.

3.

Provide the following information only if Topical Report WCAP-14902, Revision 0, is being endorsed for the VHP nonles at your plant (s).

WEC and the WOG did not provide a description of the crack initiation and growth a.

susceptibility model used for the assessment of WEC vessel head penetration (VHP) l nonles in plants endorsing WCAP-14902, Revision O. Provide a description of the crack initiation and growth susceptibility model used for assessment of the VHP nonles at your plant (s).

b.

In WCAP-14902, Revision 0, WEC did not provide any conclusions as to what the probabilistic failure model would lead the WOG to conclude with respect to the assessment of PWSCC in WEC-designed vessel head penetration (VHP) nonles.

With respect to the probabilistic susceptibility model(e.g., probabilistic failure model) referenced in WCAP-14902:

(1)

Provide the susceptibility ranking of your plant (s) as compiled from the crack initiation and growth analysis of the VHP nonles for your plant (s) to that compiled for the other WOG member plants for which WCAP-14902, Revision 0, is applicable.

(2)

Describe how the probabilistic failure (crack initiation and growth) model in I

used for the assessment of the VHP nonles at your plant (s) was bench-l marked, and provide a list and discussion of the standards the model was bench-marked against.

(3)

Provide additional information regarding how the probabilistic failure (crack j

initiation and growth) models for the assessment of VHP nonles at your I

plant (s) will be refined to allow the input of plant specific inspection data into the model's analysis methodology.

i

f 4

(4)

Describe how the variability in product forms, material specifications, and heat treatments used to fabricate each CRDM penetration nozzle at the WOG member utilities are addressed in the probabilistic crack initiation and growth models described or referenced in Topicci Report No. WCAP-14902, Revision O.

Table 1-2 in WCAP-14902. Revision 0, provides a summary of the key tasks in c.

WEC's VHP nozzle assessment program. The tables indicate that the Tasks for (1)

Evaluation of PWSCC M;tigation Methods, (2) Crack Growth Data and Testing, and (3) Crack initiation Characterization Studies have not been completed and are stillin progress. In light of the fact that the probabilistic susceptibility models appear to be dependent in part on PWSCC crack initiation and growth estimates, provide your l

best estimate when these tasks will be completed by WEC, and describe how these activities relate to and will be used to update the probabilistic susceptibility assessment of VHP nozzles at your plant (s).

i d.

In the NEl letters of January 29,1998 (Ref.1), and April 1,1998 (Ref. 2), NEl indicated that inspection plans have been developed for the VHP nozzles at the -

Farley Unit 2 plant in the year 2002, and the Diablo Canyon Unit 2 plant in the year 2001, respectively. The staff has noted that although you have decided to apply an altemate probabilistic susceptibility model to the assessment of the VHP nozzles at your plant (s), other WOG member licensees, including the Southem Nuclear Operating Company and the Pacific Gas and Electric Company, the respective licensees for the Farley units and the Diablo Canyon units, have selected to apply the susceptibility model described in WCAP-14901, Revision 0, to the assessment of VHP nozzles at their plants. The WOG's proposal to inspect VHP at Farley Unit 2 and Diablo Canyon Unit 2 appears to be based on an composite assessment of the VHP nozzles at all WOG member plants. Verify that such a composite ranking assessment has been applied to the evaluation of VHP nozzles at your plant (s). If composite rankings of the VHP nozzles at WOG member plants have been obtained from the composite results of the two models, justify why application of the altemate probabilistic susceptibility model being for the assessment of of VHP nozzles at your plant (s) would yield the same comparable relative rankings as would application of the probabilistic susceptibility model used by the WOG member plants subscribing to the contents of WCAP-14901, Revision O. Comment on the susceptibility rankings of the VHP nozzles at your plant (s) relative to the susceptibility rankings of the VHP nozzles at the Farley Unit 2 and Diablo Canyon Unit 2 plants.

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l l

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l REFERENCES I

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1. January 19,1998 - Letter from David J. Modeen, Director of Engineering, Nuclear Generation Division, Nuclear Energy Institute, to Mr. G.C. Lainas, Acting Director, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (Untitled).

2. April 1,1995 - Letter from David J. Modeen, Director of Engineering, Nuclear Generation Division, Nuclear Energy Institute, to Mr. G.C. Lainas, Acting Director, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission,

SUBJECT:

Generic Letter 97-01, ' Degradation of Control Rod Drive Mechanism Nozzle and Other Vessel Head Penetrations.' "

I i

s John (Jane) Doe Utility Address

SUBJECT:

GENERIC LETTER (GL) 97-01, " DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS" REGARDING THE ROCHESTER GAS AND ELECTRIC CORPORATION REGPONSES TO GL 97-01 FOR THE GINNA NUCLEAR PLANT

Dear Mr. (Ms.,

Dr. etc.) Doe:

On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days ofissuance containing the technical details to the staff's information requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish to determine their inspection activities based on an integrated industry inspection program...,"

and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspection program.

The staff has reviewed your responses to GL 97-01, dated [f//lin the months and days of the 30 day and 120 day responses to GL 97-Off, and has determined that you did not indicate if you were a member of any of the PWR Owners Groups or participating in any of the " Integrated Assessment Programs" developed by these Owners Groups for assessment of the vessel head penetration nozzles in the designs of their member PWR facilities. The staff requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at the Ginna Nuclear Plant (GNP). The enclosure to this letter forwards staff's inquiries in the form of a request for additional information (RAl). The staff requests a response to the RAI within 90 days of the submittal date. It should be noted that similar staff requests have been issued to the other PWR utilities. As was the staff's position before, the staff encourages you to address these inquiries in integrated fashion with the particular PWR Owners Group that you are a member of and with the Nuclear Energy Institute (NEI); however, the staff also requests that you identify any deviations from the Owners Group's integrated program that may be specific to your plant. The staff appreciates the efforts expended with respect to this matter.

Sincerely, James Smith (fillyour name), Project Manager Project Directorate (fill PD Number]

Division of Reactor Projects [fillin VIIorllVIV]

Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ encl: See next page Attachment F i

T John (J:n ) Doe Utility Address SULUECT: GENERIC LETTER (GL) 97-01, " DEGRADATION OF CRDnVCEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS" REGARDING THE ROCHESTER GAS AND ELECTRIC CORPORATION RESPONSES TO GL 97-01 FOR THE GINNA NUCLEAR PLANT l

Dear Mr. (Ms.,

Dr. etc.) Doe:

On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days ofissuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staffs information requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish to determine their inspection activities based on an integrated industry inspection program..,"

l and indicated that it did not object to individual PWR licensees basing their inspection activities i

on an integrated industry inspection program.

The staff has reviewed your responses to GL 97-01, dated [fi/Iln the months and days of the 30 day and 120 day responses to GL 97-01), and has determined that you did not indicate if you were a member of any of the PWR Owners Groups or participating in any of the " Integrated l

Assessment Programs" develop d by these Owners Groups for assessment of the vessel head penetration nozzles in the designs of their member PWR facilities. The staff requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at the Ginna Nuclear Plant (GNP). The enclosure to this letter forwards staff's inquiries in the form of a request for additionalinformation (RAI). The staff requests a response to the RAI within 90 days of the submittal date. It should be noted that similar staff requests have been issued to the other PWR utilities. As was the staffs position before, the staff encourages you to address these inquiries in integrated fashion with the particular PWR Owners Group that you are a member of and with the Nuclear Energy institute (NEI); however, the staff also requests that you identify any deviations from the Owners Group's integrated program that may be specific to your plant. The staff appreciates the efforts expended with respect to this matter.

Sincerely, James Smith (fillyour name], Project Manager Project Directorate [ fill PD Number]

Division of Reactor Projects [fillin Vil orllVIV]

Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION:

use misc. dist.

add EMCB DOCUMENT NAME:GA To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E"

= Copy with attachment / enclosure "N" = No copy 0FFICE PM:PDI 1 lE LA:PDI 1 l

D PDI 1 l

l

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NAME

$Little SBajwe f.

DATE 08/ /98 08/ /98 08/ /98 08/ /98 08/ /98 Official Record Copy

s Request for Additional Information Regarding the Rochester Gas and Electric Corporation (RGE) Responses to Generic Letter (GL) 97-01 for the Ginna Nuclear Plant i

1.

Relationship of the RGE Letters of May 1: 1997. and Julv 25.1997. to GL 97-01 On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM i

l Nonle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nonles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information requests. In the discussion section of the GL, the staff stated that "individuallicensees may wish

)

to determine their inspection activities based on an integrated industry inspection program...,"

and indicated that it did not object to individual PWR licensees basing their inspection activities j

on an integrated industry inspection program.

The staff has determined that RGE submitted its 30 day and 120 day responses to GL 97-01 on May 1,1997, and July 25,1997, respectively. In the letter of July 25,1997, RGE indicated that RGE has been an " active participant"in the industry's efforts to address primary stress corrosion

{

cracking (PWSCC) in vessel head penetration (VHP) noules fabricated from inconel 600 (Alloy 600). In this letter, RGE implied that it believed that the conclusions stated in Westinghouse Electric Corporation (WEC) Topical Report No. WCAP-13565, Revision 1, and the staff's safety svaluation of November 19,1993, were still valid, and that therefore, RGE did not believe the issue to be an immediate safety concem. However, in the letter of July 25,1997, RGE also indicated that it had developed an options matrix for the VHP nonles in the Ginna design. RGE stated that this options matrix was based on engineering work of the Dominion Engineering Corporation. Based on this work, RGE indicated that it was currently soliciting bids to perform examination of the Ginna vessel head during the 1999 refueling outage for the plant. However, RGE also indicated that the decision to inspect the VHP nonles at the Ginna Nuclear Station would be dependent on its review of the bids, as well as its review of ongoing industry experience with respect to this issue. In the letter of July 25,1997, RGE also indicated that inspections were performed of the VHP nonles at similar plants whose VHP noules were fabricated from identical material heats as y ere the VHP nonles in the Ginna reactor design, and that with respect to these inspections, which did not reveal any flaw indications, the inspection results provide "the best representation for what would be expected at Ginna Stat:on,"

and " support the conclusion that the issue does not present an immediate safety issue.

The staff has reviewed the RGE responses of May 1,1997, and July 25,1997, and has determined that additional information is needed to close out its efforts with respect to the responses to GL 97-01 for the Ginna plant. The staff's requests are provided in the items listed on the following page:

f M sure l

a s

2-Indicate whether RGE is participating in the latest industry integrated program developed 1.

for the assessment of VHP nozzles in domestic PWR designed reactors. If so, please provide the following information with respect to the industry's integrated program for assessing PWSCC in domestic PWR VHP nonles:

a.

Identify all PWR Owners Groups that RGE is a member of.

b.

Indicate whether RGE is participating in the latest integrated programs developed by these Owners Groups for assessing PWSCC in PWR VHP nozzles, and if so, whether or not any of the following topical reports are applicable to the assessment of VHP noules in the Ginna rascior design:

. Topical Report BAW-2031, developed for member utilities and plants in the Babcock & Wilcox Owners Group (B&WOG)

. Topical Report CE NPSD-1085, developed for member utilities and plants in the Combustion Engineering Owners Group (CEOG)

. Topical Report WCAP-14901, Revision 0, and/or WCAP-14902, Revision 0, developed for member utilities and plants in the Westinghouse Owners Group (WOG)

If any of the topical reports listed in Item 1.b. above are applicable to the assessment c.

of VHP nozzles in the Ginna reactor design, provide a description of the probabilistic susceptibility model being endorsed to assess the VHP nozzles in the Ginna reactor design. Include the following information with respect to the description of the susceptibility model:

(1)

Provide the model's relative susceptibility ranking for the VHP nonles in the Ginna reactor design to the rankings compiled by other utilities applying the model to the assessment of the VHP nozzles in their plant designs. In addition, if one of the Westinghouse Topical Reports is applicable to the assessment of the VHP nozzles in the Ginna reactor design, compare the susceptibility ranking of VHP nonles in the Ginna reactor design to that of WOG member plants applying the other model to the assessment of the VHP nozzles at their plants. Include the basis for establishing the ranking of you plant relative to the others. Justify why the crack initiation and growth susceptibility model used for your VHP nozzles is considered to yield as reasonable a ranking as would application of the other probabilistic failure I

model being used be WOG member utilities. Provide a composite susceptibility ranking of all WOG member plants and any conclusions which may be drawn from such a ranking with respect to the assessment of PWSCC i

in the Ginna VHP nozzles relative to those in other WOG member designs.

L (2)

Describe how the probabilistic susceptibility model used for the assessment of the VHP nozzles in the Ginna design was bench-marked, and provide a list and discussion of the standards the model was bench-marked against.

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s 5

I 3

f (3) Provide additional information regarding how the pdabilistic susceptibility model being used for the assessment of the VHP nonles in the Ginna design will be refined to allow the input of plant-specific inspection data into the model's analysis methodology.

(4) Describe how the variability in product forms, material specifications, and heat treatments used to fabricate each VHP nonle in the Ginna reactor design is addressed in the probabilistic susceptibility model being used for the assessment of these nonles.

2. Indicate whether any final conclusion has been made to commence with the volumetric examinations of the VHP nonles at the Ginna Nuclear Station in 1999. If the decision has been made not to commence with the examinations of the VHP nonles in the Ginna design, justify why RGE considers it to be safe to operate the Ginna plant without performing volumetric examinations of the Ginna VHP nonles.

3. Identify all other plants where volumetric examinations were performed on the VHP nonles in the reactor design. Include a more in-depth summary of the inspection results at the other plants which RGE considers to be applicable to the evaluation of VHP noules at Ginna, and identify the heats of materials for the Ginna VHP nonles which are considered to be bounded by the examination results at these plants.

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