ML20237E036

Forwards Request for Addl Info Re GL 97-01, Degradation of Crdm/Cedm Nozzle & Other Vessel Closure Head Penetrations

ML20237E036
Person / Time
Site:	Beaver Valley
Issue date:	08/24/1998
From:	Brinkman D NRC (Affiliation Not Assigned)
To:	Cross J DUQUESNE LIGHT CO.
References
GL-97-01, GL-97-1, TAC-M98545, TAC-M98546, NUDOCS 9808280194
Download: ML20237E036 (8)

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\*****,/ August 24, 1998 Mr. J. E. Cross President - Generation Group Duquesne Light Company

- Post Office Box 4 Shippingport, PA _15077

SUBJECT:

GENERIC LETTER (GL) 97-01, " DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS," RESPONSES FOR BEAVER VALLEY POWER STATION, UNIT NOS.1 AND 2 (TAC NOS. M98545 AND M98546)

Dear Mr. Cross:

On April 1,1997,' the staff issued Generic Letter (GL) 97-O1, " Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that adoressees 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 state'.I that "individuallicem,ees 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 result, the Westinghouse Owners Group (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 j

Reactor Vessel Closure Head Penetration Integrity for the Westinghouse owners Group," and l WCAP-14902, Revision 0, " Background Material for Response to NRC Generic Letter 97-01: I 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 April 30,1997, and July 30,1997, that you were a 1 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 April 20,1997, and July 30,1997,

- you also indicated that the information in WEC Topical Report WCAP-14901 is applicable with

respect to the assessment of VHP nozzles at Beaver Valley Power Station, Unit Nos.1 and 2.

The staff has reviewed your responses to GL 97-01, dated April 30,1997, and July 30,1997, and requires faither 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 staff's inquiries in the form of a request for additional information (RAl).

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9808290194 990624 NM Wi OM3 MPY PDR. ADOCK 05000334 P PDR t 0 ,

J. Cross The staff requests a response to the RAI within 90 days of the receipt of this letter, it should be noted that similar staff requests have been issued to other WOG member utilities. As was t't staffs position before, the staff encourcges you to address these inquiries in integrated fasli!:,n with the WOG and the Nuclear Energy institute; 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, original signed by l Donald S. Brinkman, S.enior Project Manager Project Directorate 1-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

RAI 4

cc w/ encl: See next page DISTRIBUTION:

Docket File PUBLIC PDI-2 ReadingF JZwolinski RCapra MO'Brien DBrinkman OGC ACRS MEvans, RGNI EMCB JHarold OFFICE PDI-2/PM A // PDI-2/LA1 PDI-2/D NAME DBrinkman MhBrieh J RCapra RE DATE P /ty/98 h th98 9 f24/98 OFFICIAL RECORD COPY DOCUMENT NAME: A:\bvm98545.LTR l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ a

J. Cross The staff requests a response to the RAI within 90 days of the receipt of this letter. It should be >

noted that similar staff requests have been issued to other WOG member utilities. As was the staff's position before, the staff encourages you to address these inquiries in integrated fashion with the WOG and the Nuclear Energy Institute; 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, d a ld. O n Donald S. Brinkman, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412 l l

Enclosurc: RAI cc w/ encl: See next page

l

J. Cross The staff requests a response to the RAI within 90 days of the receipt of this letter. It should be noted that similar staff requests have been issued to other WOG member utilities. As was the staff's position before, the staff encourages you to address these inquiries in integrated fashion with the WOG and the Nuclear Energy Institute; however, the staff also requests that you identify I

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, original signed by Donald S. Brinkman, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - t/II Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

\

Enclosure:

RAI cc w/ encl: See next page DISTRIBUTION:

Docket File PUBLIC PDI-2 Readingaf JZwolinski RCaora MO'Brien DBrinkman OGC ACRS MEvans, RGNI EMCB JHarold OFFICE PDI-2/PM A // PDl-2/LA/1 PDI-2/D NAME DBrinkman MhENeb RCapra RD

,DATE P /v//96 h /h98 9/$/98 I

( OFFICIAL RECORD COPY I l DOCUMENT NAME: A:\bvm98545.LTR

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I u___ - _ - - - - - - - - - -

i J. E. Cross Beaver Valley Power Station, Units 1 & 2 I

Duquesne Ught Company cc:

i Jay E. Silberg, Esquire Bureau of Radiation Protection Shaw, Pittman, Potts & Trowbridge Pennsylvania Department of 2300 N Street, NW. Environmental Resources Washington, DC 20037 ATTN: Michael P. Murphy {

Post Office Box 2063 l Director-Safety and Ucensing Harrisburg, PA 17120 Department (BV-A)

]

1 Duquesne Ught Company Mayor of the Borough of Beaver Valley Power Station Shippingport )

PO Box 4 Post Office Box 3 Shippingport, PA 15077 Shippingport, PA 15077 Commissioner RoyM. Smith Regional Administrator, Region i I West Virginia Department of Labor U.S. Nuclear Regulatory Commission Building 3, Room 319 475 Allendale Road Capitol Complex King of Prussia, PA 19406 Charleston, WVA 25305 j Resident inspector  ;

Director, Utilities Department U.S. Nuclear Regulatory Commission {

Public Utilities Commission Post Office Box 298 l 180 East Broad Street Shippingport, PA 15077 Columbus, OH 43266-0573 Director, Pennsylvania Emergency Duquesne Ught Company Management Agency Beaver Valley Power Station Post Office Box 3321 PO Box 4 Harrisburg, PA 17105-3321 Shippingport, PA 15077 ATTN: S. C. Jain, Senior Vice President Ohio EPA-DERR Nuclear Services (BV-A)

ATTN: Zack A. Clayton Post Office Box 1049 Mr. J. A. Huitz, Manager Columbus, OH 43266-0149 Projects & Support Services First Energy Dr. Judith Johnsrud 76 South Main Street National Energy Committee Akron, OH 44308 Sierra Club 433 Oriando Avenue State College, PA 16803 Duquesne Ught Company

, Beaver Valley Power Station PO Box 4 Shippingport, PA 15077 ATTN: R. D. Brandt, Division Vice President, Nuclear Operations and Plant Manager (BV-SOSB-7) l

1 Request for Additional Information Regarding Utilities Participating in the Westinghouse Owners Group (WOG)

Responses to Generic Letter (GL) 97-01 and

" Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group" i Topical Report No. WCAP-14901, Revision 0 I

i Applicability of Topical Report No. WCAP-14901, Revision 0, to the Plant-specific Responses to GL 97-01 for Participating Member Utilities and Plants in the WOG I

1. Relationship and Applicabihty of WCAP-14901, Revision 0, 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 Vesssi 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 tneir 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 on an integrated industry inspection program.

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As a result, the Westinghouse Owners Group (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 April 30,1997, and July 30,1997, 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 April 30,1997, and July 30,1997, you also indicated that the information in WEC Topical Report WCAP-14901 is applicabie with respect to the assessment of VHP nozzles at Beaver Valley Power Station, Unit Nos.1 and 2.

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Enclosure b __

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The staff has reviewed your responses to GL 97-01, dated April 30,1997, and July 30,1997, i 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 staff requests the following information with respect to the content of your responses to GL 97-01, dated April 30,1997, and July 30,1997, and to the content of WCAP-14901 as it relates to these responses:

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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 primary l water stress corrosion cracking (PWSCC) in WEC-designed vessel head penetrations. j With respect to the proba'oilistic susceptibility model (e.g., probabilistic failure model) provided in WCAP-14901:  !

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a. 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 plants relative to the others.

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

c. Provide additionalinformation regarding how the probabilistic failure models in 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 control rod drive mechanism (CRDM) penetration nozzle at the WCG member utilities are addressed in the probabilistic crack initiation and growth models described or referenced in Topical Report No WCAP-14901.

2. Table 1-2 in WCAP-14901 provides a summary of the key tasks in WEC's vessel head penetration 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 still in 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 plants.

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3. In the Nuclear Energy Institute (NEI) letters of January 29,1998 (Ref.1), and April 1, (

1998 (Ref. 2), NE! 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 hure andorsed a probabilistic susceptibility model developed by an altemate 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 noules at all WOG member plants. Verify that such a composite I ranking assessment has been applied to the evaluation of VHP nonles at your plants. If }

composite rankings of the VHP noules at WOG member plants have been obtained from I 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 plants as would application of the attemate 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 plants relative to the susceptibility rankings of the VHP nonles 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 t 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 Regula"

SUBJECT:

Generic Letter 97-01, ' Degradation of CRDM/CEDM Nonles and Other Vessel Closure Head Penetrations.' "

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