ML20238F310

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Forwards Request for Addl Info Re Responses to GL 97-01 to Complete Review of Responses as They Relate to WOG Integrated Program for Assessing Vhp Nozzles at WOG Members Plants & to Contents of Topical Rept WCAP-14901
ML20238F310
Person / Time
Site: Millstone Dominion icon.png
Issue date: 08/27/1998
From: Andersen J
NRC (Affiliation Not Assigned)
To: Bowling M, Loftus P
NORTHEAST NUCLEAR ENERGY CO.
References
GL-97-01, GL-97-1, TAC-M98576, NUDOCS 9809030261
Download: ML20238F310 (8)


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WASHINGTON, D.C. 3000H001 August 27, 1998 Mr. Martin L. Bowling, Jr.

Recovery Officer - Technical Services Northeast Nuclear Energy Company clo Ms. Patricia A. Loftus Director-Regulatory Affairs P. O. Box 128 Waterford, Connecticut 06385

SUBJECT:

MILLSTONE NUCLEAR POWER STATION, UNIT 3 - GENERIC LETTER 97-01,

" DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS"(TAC M98576)

I

Dear Mr. Bowling:

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

[ Control Rod Drive Mechanism / Control Element Drive Mechanism] Nozzle and Other Vessel l

Closure Head Penetrations," to the industry requesting, in part, that addressees provide a i

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 the 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 " individual licensees 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 Repor1s issued by the Westinghouse Electric.

Corporation (WEC), WCAP-14901, Revision 0, " Background and Methodology for Evaluation of

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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 your letters dated April 28 and July 28,1997, that you are 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, you also indicated that the infor(nation in WEC Topical Report WCAP-14901 is applicable with respect to the assessment of VHP nozzles at Millstone Unit 3.

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M. L. Bowling, Jr. August 27, 1998 The staff has reviewed your 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 nonles at WOG member plants, and to the contents of Topical Report WCAP-14001. The enclosure to this letter forwards the staff's inquiries in the form of a request for additionalinformation (RAI).

l The staff requests a response to the RAI within 90 days of the date of this letter. 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; however, the staff also requests that you identify any deviations from the WOG's integrated program th9 may be specific to your 1

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

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Sincerely, Original signed by:

James W. Andersen, Project Manager Millstone Project Directorate i

Division of Reactor Projects - 1/Il l

Office of Nuclear Reactor Regulation Docket No. 50-423

Enclosure:

Request for Additional Information l

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M. L. Bowling, Jr. The staff has reviewed your 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 WCAP-14901. The enclosure to this letter forwards the staffs inquiries in the form of a request for additionalinformation (RAl).

The staff requests a response to the RAI within 90 days of the date of this letter, it should be noted that similar staff requests have been issued to other WOG member utilities. As was the E

staffs 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,

[

m s W. Andersen, Project Manager illstone Project Directorate Division of Reactor Projects -l/II Office of Nuclear Reactor Regulation Docket No. 50-423

Enclosure:

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

1

4 Reauest for AdditionalInformation Recardino Utilitic Particioatina in the Westinghouse Owners Grouc (WOG)

Resoonse to Generic Letter (GL) 97-01 "Backaround and Methodoloov for Evaluation of Reactor Vessel Closure Head Penetration Intearity for the Westinghouse Owners Grouo" Tooical Reoort WCAP-14901. Revision 0

]

1. Relationship and Applicability of WCAP-14901, Revision 0, to GL 97-01 and the WOG On Apri: 1,1997, the staff issued GL 97-01, " Degradation of CRDM/CEDM [ Control Rod Drive Mechanism / Control Element Drive Mechanism) 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 the 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 " individual licensees 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 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 28 and July 28,1997, 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, you also indicated that the information in WEC Topical Report WCAP-14901 is applicable with respect to the assessment of VHP nozzles at Millstone Unit 3.

Enclosure

0 The staff has reviewed your responses to GL 97-01 dated April 28 and July 28,1997, 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 WCAP-14901. The staff requests the following information with i

respect to the content of your responses to GL 97-01 dated April 28 and July 28,1997, and to the content of WCAP-14901 as it relates to these responses.

. 2. 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 water stress-corrosion cracking (PWSCC) in WEC-designed vessel head penetrations. With respect to the probabilistic susceptibility model (e.g., probabilistic failure model) provided in l

WCAP-14901:

I

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 plant relative to the others.
b. Describe how the probabilistic failure model in WCAP-14901 for assessing postulated flaws in vessel head penetration nozzles was benchmarked, and provided a list and

- discussion of the standards the model was benchmarked against.

c. Provide additional information 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 CRDM penetration nozzle at the WOG member utilities are addressed in the probabilistic crack initiation and growth models described or referenced in Topical Report WCAP-14901.
3. 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) l 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 j

be used to update the probabilistic susceptibility assessment of VHP noules at your plant.

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

(Ref. 2), NEl indicated that inspection plans have been developed for the VHP nozzles at l

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 alternate vendor of choice. The WOG's proposal to inspect the VHP nozzles at the Farley Unit 2 and Diablo i

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o

' Canyon Unit 2 plants appears to be based on a composite assessment of the VHP nonles t

at all WOG member plants. Verify that such a composite ranking assessment has been l

applied to the evaluation of VHP nozzles at your plant. 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 as would application of the alternate probabilistic susceptibility model used by the WOG member plants not subscribing to WCAP-14901, Revision 0. Comment i

l on the susceptibility rankings of the VHP nozzles at your plant relative to the susceptibility l

rankings of the VHP nozzles at the Farley Unit 2 and Diablo Canyon Unit 2 plants.

REFERENCES l

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.' "

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Millst:n3 Nucirr Powir St: tion Unit 3 cc:

The Honorable Terry Concannon Citizens Regulatory Commission Nuclear Energy Advisory Council ATTN: Ms. Susan Perry Luxton Room 4035 180 Great Neck Road Legislative Office Building Waterford, CT 06385 Capitol Avenue Hartford, CT 06106

-l Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road i

Simsbury, CT 06070 l

Mr. John W. Beck, President l

Little Harbor Consultants, Inc.

Millstone -ITPOP Project Office P.O. Box 0630 Niantic, CT 06357-0630 Mr. B. D. Kenyon (Acting)

Chief Nuclear Officer-Millstone Northeast Nuclear Energy Company I

P.O. Box 128 -

Waterford, CT 06385 Mr. Daniel L Curry-l Project Director Parsons Power Group Inc.

2675 Morgantown Road Reading, PA 19607 j

Mr. P. D. Hinnenkamp Director-Unit 3 Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385 Senior Resident inspector Millstone Nuclear Power Station i

c/o U.S. Nuclear Regulatory Commission P. O. Box 513 Niantic, CT 06357 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale

' Electric Company P.O. Box 426 Ludlow, MA 01056 Attomey Nicholas J. Scobbo, Jr.

l-Ferriter, Scobbo, Caruso, Rodophele, PC 1 Beacon Street,11th Floor Boston, MA 02108

Millst:na Nucl2rr Powir Sittion Unit 3 cc:

Lillian M. Cuoco, Esquire Joseph R. Egan, Esquire Senior Nuclear Counsel Egan & Associates, P.C.

Northeast Utilities Service Company 2300 N Street, NW i

P. O. Box 270 -

Washington, DC 20037 Hartford, CT 06141-0270 Mr. F. C. Rothen Mr. Kevin T. A. McCarthy, Director Vice President - Work Services Monitoring and Radiation Division Northeast Utilities Service Company Department of Environmental Protection P. O. Box 128 79 Elm Street Waterford, CT 06385 Hartford, CT 06106-5127 Emest C. Hadley, Esquire Regional Administrator, Region i 1040 B Main Street U.S. Nuclear Regulatory Commission P.O. Box 549 475 Allendale Road West Wareham, MA 02576 King of Prussia, PA 19406 Mr. John Buckingham' First Selectmen Department of Public Utility _ Control Town of Waterford Electric Unit Hall of Records 10 Liberty Square 200 Boston Post Road New Britain, CT 06051 Waterford, CT 06385 Mr. James S. Robinson, Manager Mr. Wayne D. Lanning Nuclear Investments and Administration Deputy Director of Inspections New England Power Company Special Projects Office 25 Research Drive 475 Allendale Road Westborough, MA 01582 King of Prussia, PA 19406-1415 Mr. John Streeter Mr. M. H. Brothers Recovery Officer - Nuclear Oversight Vice President-Millstone Unit 3 Northeast Utilities Service Company Northeast Nuclear Energy Company P. O. Box 128 P.O. Box 128 Waterford, CT 06385 l

Waterford, CT 06385 Deborah Katz, President Mr. M. R. Scully, Executive Director Citizens Awareness Network Connecticut Municipal Electric P.O. Box 83 Energy Cooperative Shelbume Falls, MA 03170 30 Stott Avenue

- Norwich, CT 06360 Mr. Allan Johanson, Assistant Director Office of Policy and Management l-Mr. David Amerine Policy Development and Planning Vice President - Human Services Division Northeast Utilities Service Company 450 Capitol Avenue - MS# 52ERN

- P. O. Box 128 P. O. Box 341441 Waterford, CT 06385 -

Hartford, CT 06134-1441 l