ML20239A052
| ML20239A052 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 09/02/1998 |
| From: | John Hickman NRC (Affiliation Not Assigned) |
| To: | Kingsley O COMMONWEALTH EDISON CO. |
| References | |
| GL-97-01, GL-97-1, TAC-M98547, TAC-M98548, TAC-M98549, TAC-M98550, NUDOCS 9809080107 | |
| Download: ML20239A052 (8) | |
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NUCLEAR REGULATORY COMMISSION bx*****j WASHINGTON, D.C. 20056 4001 September 2, 1998 Mr. Oliver D. Kingsley, President Nuclear Generation Oroup Commonwealth Edison Company Executive Towers West lll 1400 Opus Place, Suite 500 Downers Grove, IL 60515
SUBJECT:
GENERIC LETTER (GL) 97-01, " DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS," RESPONSES FOR BRAIDWOOD UNITS 1 AND 2, AND BYRON UNITS 1 AND 2 (TAC NOS. M98547, M98548, M98549, M98550)
Dear Mr. Kingsley:
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 " 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 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 29,1997, 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 of April 29,1997, and July 30,1997, you also indicated that the information in WEC Topical Report WCAP-14902 is applicable with respect to the assessment of VHP nozzles at Braidwood Units 1 and 2, and Byron Units 1 and 2.
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O. D. Kingsley 2
The staff has reviewed your responses to GL 97-01, dated April 29,1997, and July 30,1997, 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 No. WCAP-14902. The enclosure to this letter forwards staff's inquiries in the form of a request for additional information (RAI).
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 that may be specific to your facilities. The staff appreciates the efforts expended with respect to this matter.
Sincerely, I
John B. Hickman, Project Manager Project Directorate lil-2 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455, STN 50-456 and STN 50-457
Enclosure:
Request for Additional information cc w/ encl: See next page l
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's O. D. Kingsley 2
Septeraber 2,1998 The staff has reviewed your responses to GL 97-01, dated April 29,1997, and July 30,1997, 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 No. WCAP-14902.' The~ enclosure to this letter forwards staffs inquiries in the form of a request for additionalinformation (RAI).
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 that may be specific to your facilities. The staff appreciates the efforts expended with respect to this matter.
Sincerely, ORIG. SIGNED BY John B. Hickman, Project Manager Project Directorate 111-2 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455, STN 50-456 and STN 50-457
Enclosure:
Request for Additional Information cc w/ encl: See next page DISTRIBUTION:
Docket File PUBLIC PDill-2 r/f (2)
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Ms. C. Sue Hauser, Project Manager George L Edgar Westinghouse Electric Corporation Morgan, Lewis and Bochius Energy Systems Business Unit
'1800 M Street, N.W.
Post Office Box 355 Washington, DC 20036 Pittsburgh, Pennsylvania 15230 Attomey General Joseph Gallo 500 S. Second Street Gallo & Ross Springfield, Illinois 62701 1250 Eye St., N.W., Suite 302 Washington, DC 20005 lilinois Department of Nuclear Safety Office of Nuclear Facility Safety Michael 1. Miller, Esquire 1035 Outer Park Drive Sidley and Austin Springfield, Illinois 62704 One First National Plaza Chicago, lilinois 60603 Commonwealth Edison Company Byron Station Manager Howard A. Leamer 4450 N. Gerrnan Church Road Environmentallaw and Policy Byron, Illinois 61010 9794 Center of the Midwest 35 East Wacker Dr., Suite 1300 Commonwealth Edison Company Chicago, Illinois 60601 Site Vice President-Byron 4450 N. German Church Road U.S. Nuclear Regulatory Commission Byron, Illinois 61010-9794 Byron Resident inspectors Office 4448 N. German Church Road U.S. Nuclear Regulatory Commission Byron, Illinois 61010-9750 Braidwood Resident inspectors Office RR 1, Box 79 Regional Administrator, Region ill Braceville, Illinois 60407 U.S. Nuclear Regulatory Commission 801 Warrenville Road Mr. Ron Stephens Lisle, Illinois 60532-4351 lilinois Emergency Services and Disaster Agency Ms. Lorraine Creek 110 E. Adams Street RR 1, Box 182 Springfield, Illinois 62706 Manteno, Illinois 60950 Chairman Chairman, Ogle County Board Will County Board of Supervisors Post Office Box 357 Will County Board Courthouse Oregon, Illinois 61061 Joliet, Illinois 60434 Mrs. Phillip B. Johnson Commonwealth Edison Company 1907 Stratford Lane Braidwood Station Manager Rockford,lilinois 61107 RR 1, Box 84 ~
Braceville, Illinois 60407 I
O. Kingsley Commonwealth Edison Company Byron /Braidwood Stations Ms. Bridget Little Rorem Ms. Irene Johnson, Licensing Director Appleseed Coordinator Nuclear Regulatory Services 117 N. Linden Street Commonwealth Edison Company Essex, Illinois 60935 Executive Towers West til 1400 Opus Place, Suite 500 Document Control Desk-Licensing Downers Grove,IL 60515 Commonwealth Edison Company 1400 Opus Place, Suite 400 Commonwealth Edison Company Downers Grove, Illinois 60515 Reg. Assurance Supervisor-Braidwood RR 1, Box 79 Commonwealth Edison Company Braceville, Illinois 60407 Site Vice President-Braidwood RR 1, Box 84 Commonwealth Edison Company Braceville,IL 60407 Reg. Assurance Supervisor-Byron 4450 N. German Church Road Mr. David Helwig Byron, Illinois 61010-9794 Senior Vice President Commonwealth Edison Company Mr. Michael J. Wallace Executive Towers West til Senior Vice President i
1400 Opus Place, Suite 900 Commonwealth Edison Company
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Downers Grove,IL 60515 Executive Towers West lll 1
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Mr. Gene H. Stanley Downers Grove, IL 60515 PWR's Vice President Commonwealth Edison Company Executive Towers West lli 1400 Opus Place, Suite 900 Downers Grove,IL 60515 Mr. Steve Perry BWR's Vice President Commonwealth Edison Company Executive Towers West lll 1400 Opus Place, Suite 900 Downers Grove, IL 60515 Mr. Dennis Farrar Regulatory Services Manager Commonwealth Edison Company Executive Towers West lil 1400 Opus Place, Suite 500 Downers Grove,IL 60515 i
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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 Reactor Vessel Closure Head Penetration integrity 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 l.
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 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...,"
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-14902, Revision 0, is basically the same as that I
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 April 29,1997, 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 staffs requests in GL 97-01. In your letters dated April 29,1997, and July 30,1997, you also indicated that the information in WEC Topical Report WCAP-14901 is applicable with respect to the l
assessment of VHP nozzles at Braidwood Units 1 and 2 and Byron Units 1 and 2.
ENCLOSURE 1
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. The staff has reviewed your responses to GL 97-01, dated April 29,1997, and July 30,1997, 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 No. WCAP-14902, Revision 0. The staff requests that the following information be submitted with respect to the content of your responses to GL 97-01, dated April 29,1997, and July 30,1997, and to the content of WCAP-14902, Revision 0, as it relates to these responses:
1.
WEC and the WOG did not provide a description of the crack initiation and growth susceptibility model used for the assessment of WEC vessel head penetration (VHP) nozzles in plants endorsing WCAP-14902, Revision 0. 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:
a.
Provide the susceptibility ranking of your plant (s) as compiled from the crack initiation and growth analysis of the VHP nozzles for your plant (s) to that compiled for 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 used for the assessment of the VHP nozzles at your plant (s) was bench-marked, and provide a list and discussion of the standards the model was bench-marked against.
c.
Provide additional information regarding how the probabilistic failure (crack initiation and growth) models for the assessment of VHP nozzles at your plant (s) 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 No. WCAP-14902, Revision 0.
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 PWSCC Mitigation Methods, (2) Crack Growth
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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 i
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
~.s.
3-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 NEl letters of January 29,1998 (Ref.1), and April 1,1998 (Ref. 2), NEl l
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 decided to apply an altamate probabilistic susceptibility model to the assessment of the VHP nozzles at your plant (s), other WOG member licensees, including the Southem Nuclear i
Operating Company and the Pacific Gas and Electric Company, the respective l
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 the CRDM penetration nozzles at Fariey Unit 2 and Diablo Canyon Unit 2 appears to be based l-on an composite assessment of the VHP noules at all WOG member plants.
Verify that such a composite ranking assessment has been applied to the l
evaluation of VHP noules at your plant (s). If composite rankings of the VHP noules at WOG member plants have been obtained from the composite results of the two models, justify why application of the attemate probabilistic susceptibility model being for the assessment of VHP nozzles at your plant (s) would yield the l
same comparable relative rankings as would application of the probabilistic l-susceptibility model used by the WOG member plants subscribing to the contents of l
WCAP-14901, Revision 0. Comment on the susceptibility rankings of the VHP l
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 i
l 1.
January 19,1998 - Letter from David J. Modoen, Director of Engineering, Nuclear l
Generation Division, Nuclear Energy institute, to Mr. G.C. Laines, Acting Director, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (Untitled).
l 2.
April 1,1998 - 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,
SUBJECT:
Generic Letter 97-01, ' Degradation of Control Rod Drive Mechanism Nozzle i
and Other Vessel Head Penetrations.' "
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