ML20244D659

Requests Addl Info Re Response to Generic Ltr 88-01.Response Needed within 60 Days of Receipt of Ltr

ML20244D659
Person / Time
Site:	Clinton
Issue date:	06/12/1989
From:	John Hickman Office of Nuclear Reactor Regulation
To:	Holtzscher D ILLINOIS POWER CO.
References
GL-88-01, GL-88-1, NUDOCS 8906190181
Download: ML20244D659 (11)

Text

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' o UNITED STATES

,.y g' W g./ , NUCLEAR REGULATORY COMMISSION

', 11 : er . WASHINGTON, D. C. 20555 June 12, 1989

' Docket No. 461' Mr.' Dale L. Holtzscher

. . . Acting Manager - Licensing and Safety Clinton' Power Station

, P.O..' Box'678  ;

Mail Code V920 t >

.Clinton, Illinois 61727 a '

Dear Mr. Holtzscher:

(

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - CLINTON POWER STATION RESPONSE ~ i TO GENERIC LETTER 88-01 l The staff is reviewing the Illinois Power Company's response to Generic Letter 88-01. .Our review of this submittal disclosed the need for additional i information as described in the enclosed request for additional information. l

.Please provide your response.to this request within 60 days. In additior...you )

.are requested to provide a copy of your response directly to our review  ;

contractor at the following address:'

Dr. Armand A. Lakner Director, Safety and. Reliability .

Viking Systems International l '

101 Chestnut Street '

Gaithersburg, MD' 20877 The reporting and/or recordkeeping requirements contained in this letter affects. I fewer than ten respondents; therefore, OMB clearance is not. required under

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P.L.96-511..

Please call me at (301) 492-3017 if you have any questions.

i Sincerely,  ;

i I

1 31 is John B. Hickman, Project Manger i 890619'o181shoh61 PDR ADOCK O Project Directorate III-2 l PNV I P Division of Reactor Projects - III, .

IV, V, and Special Projects )

1 Enclosure As stated cc w/ enclosure: i T. McLellan, EMTB/ DEST OFol o

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l- Mr. Dale' L. Holtzscher Clinton Power Station

'4 Illinois Power Company Unit I cc: ---

Mr. D. P. Hall Illinois Department Vice President of Nuclear Safety Clinton Power Station Division of Engineering P. O. Box 678 .

1D35 Outer Park Drive 5th Floor Clinton,' Illinois, 61727 .

Springfield, Illinois 62704 Mr. R. D. Freeman . Mr. Donald Schopfer

- Manager-Nuclear Station Engineering Dept. Project Manager Clinton Power Station Sargent & Lundy Engineers

.P. O. Box 678 55 East Monroe Street Clinton, Illinois 61727 Chicago, Illinois 60603 Sheldon Zabel, Esquire Schiff, Hardin & Waite 7200 Sears Tower 233 Wacker Drive Chicago, Illinois 60606 Resident Inspector U. $. Nuclear Regulatory Commission RRf3, Box 229 A Clinton Illinois 61727 Mr. L. Larson Project Manager General Electric Company 175 Curtner Avenue, N/C 395 San Jose, California 95125 Regional Administrator, Region III 799 Roosevelt Road, Bldg. f4 Glen Ellyn, Illinois 60137 Chairman of DeWitt County c/o County Clerk's Office DeWitt County Courthouse Clinton, Illinois 61727

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i ATTACHMENT A GENERAL' QUESTIONS / REQUESTS Reviewsofseveralifcenseesubmittalshasshownthatmost(althoughnotall) of the submittals commonly lack certain information that is needed for evaluation of the submittals. Thus, this general list of questions and requests has been prepared for submission to each of the licensees. For those attachment for which the requested information was supplied in the (portions detail of this requested herein) in the original submittal, the utilities may reference the relevant pages or tables in the original submittal and supply only the' requested information that was not provided. Please certify that you comply with the staff positions in GL-88-01 or identify.and justify any deviations taken.

Item 1. Position on NRC Staff Positions Generic Letter 88-01 states on page 3:

" Pursuant to 10 CFR 50.54(f), you, as a 8WR operating reactor licensee or construction permit holder, are requested to furnish, under oath or affirmation, your current plans relating to piping replacement, inspection, repair, and leakage detection. Your response should indicate whether you intend to follow the staff positions included in this letter, or propose alternative measures."

The staff positions outlined in Generic Letter 88-02 include positions on: (1) Materials. (2) Processes. (3) Water Chemistry. (4) Weld Overlay. (5)PartialReplacement. (6 Stress Improvement of Cracked Weldments. ( ) Clamping Devices. (8)) Crack Evaluation and Repair Criteria. (9 Inspection Method and Personnel. (10) Inspection Schedules. ( 1) Sample Expansion. (12) Leak Detection. (13)

Reporting Requirements.

Please supply information concerning whether the licensee: (1) endorses these positions, (2) proposes alternate positions, exceptions,orprovisions,and(3)isconsideringorplanningto apply them in the future. Please describe any alternate positions, exceptions, or provisions that are proposed.

Please supply this information using a table such as the illustrated in the example shown in Table 1.

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. . c Table 1 .

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Responses to NRC Staff Positions Licensee Response

• Licensee Hss/Will**

Accept Requesta -

with Alternate Applied Consider for

' Staff Fosition Accept Provisions Position in Past Future Use

1. Materials

2. Processes *

3. Water Dienistry *

4. Veld Overlay

5. Pertial Replacement

6. Stress Improvement of Cracked Weldments

7. Clamping Devices B. Crack Evaluation and Repair Criteria

.9. Inspection Method and Personnel

10. Inspection Schedules

11. Sample Expansion 12.14ak Detection .

13. Reporting Requirements Answer with "yes", " check mark" or "I" in appropriate column for each of the 13 NRC Staff Positions. List and explain each provision and/or alternate position (or reference original submittal if it contains the listing and explanation). Use separate page(s) if needed.

• • Answer with "yes" or "no", as appropriate, in each column for each of 13 NRC Staff Positions.

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• ATTACHMENT '(continued)

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Item 2. Inservice Insoection Proaram -

Generic Letter 88-01 requests on page 3:

"Your current plans regarding pipe repiscament and/or other measures taken or to be taken to mitigate IGSOC and provide 1 assurance.of continued long-term integrity and reliability."

"An Inservice Inspection Program to be implemented at the next refueling outage for austenitic stainless steel piping covered i; under the scope of this letter that conforme to the staff positions on inspection schedules methods and personnel, and sample expansion included in this letter."

The infomation' pertaining to the pipe replacement and other mitigating actions as well as the Inservice Inspection Program provided in most of the licensee submittals were either incomplete or did not provide the background' data that is needed to evaluate the ISI Program such as-(1) reasons / justification for IGSCC classification of welds (2) methods, personnel qualification, schedules and identities of welds inspected, and (3) results of previous inspections, and/or identities of welds to be inspected during future inspections.

Thus, the following information is requested:

1. A listing of all welds by system, pipe size, configuratina

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(e.g., pipe to elbow, pipe to valve, etc.), drawing number (piping ISO with weld I.D.), location (i.e., inside or outside of containment, etc.), weld I.D. number, and 1GSCC classification (i.e., IGSOC Category A, B, C, D, E, F and C).

2. Reason / justification for the classification of each weld, using such information as (a) weld history such as heat sink ,

welding (HSW), (b) pipe and weld metal compositions or material identities to show either conforming material or non-conforming material. (c) mitigating treatment (s) applied such as solution heat treating'(SHT), stress improvement (IHSI or MSIP).

3. Identity of welds to be inspected during past and future refueling outage. Include (a) dates and results of previous inspections, (b) flaw characteristics including orientation *

(axial or circumferential), maximum length, maximum depth, repairs and/or mitigating treatments applied. -

Please supply this information in tabular form using formats such .

as that illustrated in Tables 2 and 3.

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Table 2 -

History of-Welds and Prior Mitigating Actions / Treatments

• Ma'terial**

IGSCC Weld Dia. Casting Treatment ***

Cater System Number Configuration Inch Formina. Pipe Weld SHT HWS CRC E O.L.

Notes:

List each weld separately -using one or more lines as required.

For meterials identify as non-conforming or conforming as appropriate concerning whether it conforms with the NRC Staff position on resistant materials. If conforming, identify the material type (e.g., Type 316 NG).

• • • For treatment: list "I" under appropriate column (s) if weld was treated using indicated technique, i.e., solution heat treated (SHT), heat sink welded (HSW), corrosion resistant clad (CRC),

stress improved (SI), or overlayed (0.L.). For SI, add explanation of method used, i.e., whether by induction heating.

or mechanical, whether pre and/cr post treatment inspection was applied using methods and personnel qualified under NRC/EPRI/BWROG~

coordination plan, and whether treatment was applied within two years of service date, Also add explanation and justification of any overlays that were not standard (per NRC Staff position). ,

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. Table 3 Inspection Schedules

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l Inspected /To Be Inspected / Flaws Found i ICSCC Weld Dia. Past Future Qgg System No. Inch. Configuration R.O.fX-2 R.O.fI-1 Flav R.O.fI R.O.fX+1 W

Instructions:

1. Under the heading, " Inspected /To BE Inspected," use as many cplumns as required to describe the following:- ,

(a) All previous inspections that were conducted (per NUREG

• 0313. Revision 2, page 5.2) using methods and personnel qualified under NRC/EPRI/BWROG coordination plan as

. upgraded in September, 1985.

plus

- (b) A sufficient number of' future inspections to demonstrate that the schedules will follow the NRC Staff positions as given in Table 1 in Generic Letter 88-01.

2. Replace R.O.# (I-2, I-1, I, I+1) with actual refueling outage numbers. Indicate dates inspections were/will be performed. .

3. List each veld within the scope of Generic Letter 88-01.

4. Place an "I" or other appropriate symbol under the appropriate column for each refueling outage for which that weld was inspected I. or will be inspected. .

5.' Indicate with "yes" under column marked " flaw" if a flaw indication was found. Attach a statement for each flawed weld giving the orientation (axial or circumferential), the dimensions (maximum length and depth), and describing any repairs made.

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$7, . .

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. ATTACHMENT (continued)

Item 3. Welds Cov3 red in Licensee Submitt,aJ1, Generic latter 88-01 (on page 2) states:

"This Generic Letter applies to all BWR piping made of sustenitic stainless steel that is four inches or larger in nominal diameter and contains reactor coolant at a temperature above 200*F during -

power operation regardless of Code classification. It also' applies to reactor vessel attachments and appurtenances such as jet pump instrumentation penetration assemblies and head spray and vent components."

Were any welds that fall within this defined scope excluded from

• the licensee submittal (for example, welds in the RWCU outboard of-the 1 solation valves)? If previously excluded, please list identity of such welds and plans for mitigation and inspections in Tables-2 and 3 or provide alternative proposal. If IGSCC susceptible welds were excluded from the licensee submittal based on temperature .

considerations please identify the welds and describe in' detail the method of temperature measurements.

4 Item 4. Welds that Are Not UT Inspectabis Generic Letter 88-01 (in Table 1) states: " Welds that are not UT ,

'inspectable should be replaced, " sleeved", or local leak detection applied.- RT examination or visual inspection for leakage may also be considered."

Does the licensee submittal include discussions and plans for: -

(a) All welds that are inaccessible for UT inspections? ,

(b) All welds that are only partially accessible for W inspections?

(c) Welds that cannot be UT inspected because of geometrical constraints or other reasons.

If not, please list these welds c.sd plans for mitigation / inspection.

Item 5. Leakane Detection Generic Intter 88-01 states on page 3: .

" Confirmation of you plans to ensure that the Technical A-6

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• ATTACIMENT '(continued)

Specification related to leakage detection will be in conformance'

with the staff position on leak detection included in 'this letter."

The' staff position is outlined on pages 5 and 6 of Generic Letter 88-01 and include the following items:

o 1. Laakage detection should be in conformance with Position C

of Regulatory Guide 1.45 " Reactor Coolant Pressure Boundary Leakage Detection Systems," or as otherwise approved by the NRC.

D

2. Plant shutdown should be initiated for corrective action when:

(s)' within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period any leakage detection system indicates an increase of unidentified leakage in excess

-of.2 spa or its equivalent, or (b) the total unidentified leakage attains a rate of 5 gym or equivalent.

3. Leakage should be monitored (or determined from flow measurements if flow is continuously monitored) at approximately.

four hour intervals or less. .

4.11 unidentified leakage should include all leakage other than (a) le'akage into closed systems, or (b) leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with operations of monitoring systems or not to be from a throughwall crack.

'5. For plants operating with any ICSCC Category D, E, F, or.C welds, at least one of the leakage measurement instruments associated with each sump shall'be operable, and the outage time for inoperable instruments shall be limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

• or immediately initiate an orderly shutdown.

Although most licensee submittals describe the intention of meeting some or all of these requirements or offer alternative measures, ,

it is not always clear whether these requirements are contained in the Technical Specifications. Thus it is requested that this information should be provided by each licensee. For clarity and "

completeness, please use a' checklist such as that illustrated in Table 4.

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Table 4 Licensee Positions on hakage Detection ,

Already TS will be Alternate Contained Changed Position Position in TS to Include Proposed i

1. Conforms with Position C of

[ Regulatory Guide 1.45 -

2. Plant shutdown abould be initiated when: .

(a) within any period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ,

or less, an increase is .

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indicated in the rate of unidentified leaksga in excess of 2 spa, or (b) the total unidentified leakage attains a rate of 5 sps.

3. Leakage monitored at four hour intervals or less.

4. Unidentified leakage includes all except:

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(a) leakage into closed systems, or (b) leakage into the containment atmosphere from sources that are located, do not interfere '

with monitoring systems, or not from throughwall crack.

5. Provisions for shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to inoperable measurement instruments in plants with Category D, E F, or G welds.

Instructions: -

Place "I" or "yes" under appropriate column for each ites. Provide description and justification for alternative positions if not already provided.

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• -p PP D !) Dock 3t.No. 2'50-461?

. June"12, 1989

.w, ' ;s ,

$.4 6.. ' ]'Mr.'

ActingDale'll.

Manager- Joltzscher.

Licensing' and Safety-Clinton Power Station,

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P.O.' Box 678

' Mail Code V920 '

Clinton,-Illinois 6'1727J J 1. <" 1

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1 '

Dear Mr. Holtzscher:

' ~

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - CLINTON POWER STATION RESPONSE

^TO GEWERIC LETTER 88-01 The staff;is~ reviewing the. Illinois Power Company's response to Generic Letter

.88-01.' Our review of this submittal disclosed the'need for additional-information as-described'in the enclosed request for additional information. ,

<Please'prov_ide your response to this request within 60 days. LIn addition, you

' are reque'sted to provide a. copy of your response directly to our review contractor at:the following address:

L Dr. Armand A. Lakner-Director, SafetyLa',.! Reliability a Viking- Systems International 101 Chestnut Street' E Gaithersburg, MD 20877

'The reporting and/or recordkeeping requirements contained in this letter affects

-fewer than ten respondents; therefore, OMB clearance is not required under

~

-P.L.96-511.

~.Please: call'me at (301)~ 492-3017 -if you have any questions.

-Sincerely, John B. Hickman, Project Manger Project Directorate III-2 Division of Reactor Projects - III, IV, V, and Special Projects

Enclosure:

. As stated' Lcc w/ enclosure: T. McLellan, EMTB/ DEST DISTRIBUTION-Docket file OGC NRC & Local PDRs Edordan GHolahan. BGrimes MVirgilio ACRS(10)

LLuther JHickman PDIII-2 r/f Plant file SBajwa f.[.

PDIII-2 ,

III-2 PDIII-2 i

- Liler.f.THPN d/lficl

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LLuthe . JHickman'

' 03/// /89 '3/@/89 y/12/89

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