ML20245C967

Requests Addl Info on Response to Generic Ltr 88-01 on IGSCC in Matls.Response Should Be Provided within 60 Days of Receipt of Ltr

ML20245C967
Person / Time
Site:	Peach Bottom
Issue date:	06/16/1989
From:	Martin R Office of Nuclear Reactor Regulation
To:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
GL-88-01, GL-88-1, NUDOCS 8906260346
Download: ML20245C967 (12)

Text

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- June 16, 1989

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Ddeket Nos. 50-277/278 DISTRIBUTION w/ enclosure:

6 RMartin Mr. George A. Hunger, Jr. NRC PDR & Local PDR RClark Director-Licensing PDI-2 Reading- OGC Philadelphia Electric Company SVarga EJordan Correspondence Control Desk -

BBoger BGrimes P. O. Box 7520 WButler ACRS (10)

Philadelphia, Pennsylvania 18101 M0'Brien TMcLellan

Dear Mr. Hunger:

SUBacCT: REQUEST FOR ADDITIONAL INFORMATION ON RESPONSE TO GENERIC LETTER

'88-01 ON IGSCC IN MATERIALS RE: PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 The staff's Materials Engineering' Branch, with assistance from its contractor, Viking Systems International, is reviewing and evaluating PECo's submittal in response to Generic Letter 88-01 for' the Peach Bottom Atomic Power Station.

Additional information, as identified in the enclosure, is rauested in order for the staff to complete its review. We request that a response be provided within sixty days of receipt of this letter and that a copy of the response also be forwarded to the staff's contractor at the following address:

Dr. Armand A. Lakner Director, Safety and Reliability Viking Systems International 101 Chestnut Street Gaithersburg, Maryland 20877 Sincerely,

/s/

Robert E. Martin, Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated 1

cc w/ enclosure:

See next page

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[GAHUNGER] O/

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8906260346 DR 890616 ADOCK 05000277 PNU

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1, f"/ *'% UNITED STATES 0 #'t, h j NUCLEAR REGULATORY COMMISSION

• WASHINGTON, D. C. 20555

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June 16, 1989 s., ...../ j i

Docket Nos. 50-277/278 Mr. George A. Hunger, Jr.. l Director-Licensing Philadelphia Electric Company 3 Correspondence Control Desk P. O. Box 7520 Philadelphia, Pennsylvania 18101

Dear Mr. Hunger:

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SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON RESPONSE TO GENERIC LETTER 88-01 ON IGSCC IN MATERIALS RE: PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 Thestaff'sMaieNalsEngineeringBranch,withassistancefromitscontractor,  !

Viking Systems International, is reviewing and evaluating PEco's submittal in '

response to Generic Letter 88-01 for the Peach Bottom Atomic Power Station.

Additional information, as identified in the enclosure, is requested in order q for the staff to complete.its review. We request that a response be provided-  ;

within sixty days of receipt of this letter and that a copy of the response j also be forwarded to the staff's contractor at the following address:

]

Dr. Armand A. Lakner l Director, Safety and Reliab;lity I Viking Systems International 101 Chestnut Street Gaithersburg, Maryland 20877 j Sincerely, I 4

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/( / _j7fA w jRobfrtE. Martin,ProjectManager 1 Project Directorate I Division of Reactor Projects I/II ,

Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure:

See next page l

L----_-_--------------------- - - - - - - -

. Mr. George A. Hunger, Jr. Peach Bottom Atomic Power Station, Philadelphia Electric Company Units 2 and 3 I

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Troy B. Conner, Jr. , Esq. Single Point of Contact 1747 Pennsylvania Avenue, N.W. P. O. Box 11830 Washington, D.C. 20006- Harrisburg, Pennsylvania 17108-1880 Philadelphia Electric Company Mr. Thomas M. Gerusky, Director ATTN: Mr. D. M. Smith, Vice President Bureau of Radiation Protection Peach Bottom Atomic Power Station Pennsylvania Department of Route 1, Box 208 Environmental Resources Delta, Pennsylvania 17314 P. O. Box 2063 Harrisburg, Pennsylvania 17120 H. Chris Schwemm Vice President, Production Mr. Albert R. Steel, Chairman l Atlantic Electric Board of Supervisors P.O. Box 1500 Peach Bottom Township 1199 Black Horse Pike R. D. #1 1 Pleasantville, New Jersey 08232 Delta, Pennsylvania 17314 i Resident Inspector Delmarva Power and Light Company j

.U.S. Nuclear Regulatory Commission c/o Jack Urban.

Peach Bottom Atomic Power Station General Manager, Fuel Supply P.O. Box 399 800 King Street Delta, Pennsylvania 17314 P. O. Box 231 ,

Wilmington, DE 19899 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Mr. Tom Magette 475 Allendale Road Power Plant Research Program King of Prussb, Pennsylvania 19406 Department of Natural Resources j B-3 '

Mr. Bryan W. Griman Tawes State Office Building Manager - External Affairs- Annapolis, Maryland 21401 Public Service Electric & Gas Company P. O. Box 235, N28 Hancocks Bridge, New Jersey 08038 Mr. Roland Fletcher Department of Environment 201 West Preston Street Baltimore, Maryland 21201

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l ATTACHMENT A GENERAL QUESTIONS / REQUESTS i

i Reviewsofseverallicenseesubmittalshasshownthatmost-(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 ]4 requested herein) in the original submittal, the utilities may reference the 1 relevant pages or tables in the original submittal and supply only the requested I 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.

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

" Pursuant to 10 CFR 50.54(f), you, as a BWR operating L reactor-licensee or construction permit holder, are i requested to furnish, under oath or affirmation, your current plans relatibg 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) Partial Replacement. .(6)StressImpr.?vementofCracked Weldments. (7)ClampingDevices. (8) Crack Evaluation and Repair Criteria. (9)InspectionMethodandPersonnel. (10) Inspection Schedules. (11)SampleExpansion. (12) Leak Detection. (13)

Reporting Requirements.

Please supply information concerning whether the licensee: (1) endorses these positions, (2) proposes alternate positions, 1 exceptions, or provisions, and (3) is considering or planning to -i apply them in the future. Please describe any alteru te 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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Table 1' i 1

Responses to NRC Staff Positions

(

- I Licensee Response

• Licensee !!as/Will**

Accept Requests with . Alternate Applied Consider for Staff Position Accept Provisions Position in Past Future Use {

1. Materials *

2. Processes

3. Water Chemistry 1

4. Weld Overlay

5. Partial Replacement I

6. Stress Improvement of Cracked Weldsents

7. Clamping Devices 1

8. Crack Evaluation and Repair Criteria

9. Inspection Method and Personnel

10. Inspection Schedules l 11. Sample Expansion

12. Leak Detection

13. Reporting Requirements '

l Answer with "yes", " check mark" or "I" in appropriate column for each of the 13 NRC Staff Positions. List and explain dach provision and/or alternate position (or reference original submittal-if it contains th6 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 A (continued)

Item 2. Inservice Insocction Proaram Generic Intter 88-01 requests on page 3: ,

"Your current plans regarding pipe replacement and/or other measures taken or to be taken to mitigate IGSCC and provide 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 4nder the scope of this~ letter that conforms to the staff ~

psitions on inspection schedules methods and personnel, and

, sample expansion included in this letter."

The information 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 i 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, perswnel qualification,  ;

i schedules and identities of welds inspected, and (3) results of i previous inspections, and/or identities of welds to be inspected during future inspections.

Thus, the following information is request'ed:

1. A listing of all welds by system, pipe size, configuration (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 IGSCC classification (i.e.. IGSCC Category A, B, C, D E, F and G).

2. Reason /justificat$onfortheclassificationofeachweld,$

using such inforu tion as (a) weld history such as heat sink welding (HSW), (b) pipe and weld metal compositions or asterial ~

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 cf welds to be inspected during past and future i 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

• Material **

• IGSCC Veld Dia.. Casting Treatment ***

Caten System Number . Configuration Inch Fornina. Pipe Weld SHT HWS CRC JI,O.L.

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Notes:

List each weld separately, using one cr.nore lines as required.

• • For material: identify as non-conforming or conforming as e !

appropriate concerning whether it conforms with the NRC Staff position on resistant materials. If conforming, identify the material t'ype (e.g., Type 316 NG).

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• • • For treatment: list "I" under appropriate column (s) if weld was I treated using indicated technique, i.e., solution heat treatej (SHT), heat sink welded (HSW), corrosion resistant clad (CRC)., 1 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/or post treatment inspection was  !

applied using methods and personnel qualified under NRC/EPRI/BWROG i coordination plan, and whether treatment was applied within two years of service date. Also add explanation and justification i of any overlays that were not standard (per NRC Staff position).

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Table 3 Inspection Schedules Inspected /To Be Inspected / Flaws Found IGSCC Weld Dia. Past Future Caten System No. Inch. Configuration R.O.#I-2 R.O.fX-1 Flaw R.O.fI R.O.fX+1 Instructions: '

1. Under the heading, " Inspected /To BE Inspected " use as many column 6 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 I4tter 88-01.

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2. Replace R.O.f (I-2, X-1, I, X+1) with act'ual 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 approp tate column for each refueling outage for which that vald was inspected 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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. q A1TACHMENT A (continueo)

Item 3. Welds Covered in Licensee Submittal Generic IAtter 88-01 (on page ?) states:

I "This Generic Letter applies to all BWR piping made of austenitic i stainless steel that is four inches or larger in nominal dieseter -

and contains reactor coolant at a temperature above 200'F during power operation regardless of Code classification. It also applies l 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 -

l the licensee submittal (for example, welds-in the RWCU outboard of the isolation. 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 ir. detail the  !

method of temperature measurements. -

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

inspectable should be replaced, " sleeved", or local leak detection l 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?

l (b) All welds that are only partially accessible for UT  !

inspections? l I

(c) Welds that cannot be 16 inspected because of geometrical '

constraints or other reasons. -

1 If not, please list these welds and plans for mitigation / inspection.

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

" Confirmation of you pi'nns to ensure that the Technical ' ' I A-6 I -

F l ATfAODENT A (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:

1. Leakage detection should be in conformance with Position C of Regulatory Guide 1.45 " Reactor Coolant Pressure Boundary ,

Imakage Detection Systems " or as otherwise approved by the NRC.

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

(a) 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 gym or its equivalent, or (b) the total unidentified leakege at.tains a rate of 5 gym l or equivalent.

l 3. Imakage should be monitored (or determined from flow measurements if flow is continuously monitored) at approximately l four hour intervals or less. ,

e;

4. Unidentified leakage should include all leakage other than

(a) leakage 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 IGSCC tategory D, E, F, or G 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 immedia,tely initiate an orderly shutdown.

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

! it is not always cle r whether these requirements are contained in

' the Technical Specifications. Thus it is. requested that.this information' shod 1d be provided.by each licensee. For clarity and-completeness, please use a' checklist such as that illustrated in l

Table 4.. .

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Table 4 '

Licensee Positions on Leakage Detection .

Already TS will be Alternate

. Contained Changed Position-Position is TS " to Include- Proposed

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1. Conforms with Position C cf Regulatory Guide 1.45 1

2. Plant shutdown should 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

' indicated in the rate of unidentified leakage in excess of 2 spm, or (b) the total unidentified leakage

' attains a rate of 5 gps.

3. Leakage monitored at four hour -

intervals er less.

4. Unidentified leakage includes all .

except:

(a) leakage into closed systems, or '

(b) leakage into the containment atmosphere from sources that are located, do not interfere sdth 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.

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Instructions:

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

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ATTACHMENT B 1

l REQUEST FOR ADDITIONAL INPDkMATION PERTAINING 'IO PEACH BOTTOM, UNITS 2 AND 3 '

i Item 1. Inservice Inspection and Mitigatina Treatments i i

In reeponding to Item 2 of Attachment As )

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(a) Please note that the tables listing of welds in the IGSCC ISI plan which were previously submitted (with the original l 1

submittal) excluded six nozzles from each unit (i.e., N8, 1 N9, N10, Nil, N12, and N16 in each unit). These nozzles should be added to the tables. I (b) Mitigating treatments and inspection plans for each weld i j

i should be added to those tables. j i

l (c) Please provide clarification of the word " generally" used -l in the description of inspection methods. Since exceptions {

are implied, please describe those' exceptions and alternate plans. l Item 2. Uninspectable Welds '

1 In responding to Item 4 of Attachment A, please also provide the reasons why the RWCU welds outside of containment are considered j uninspectable. I page B - 1

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