ML20245H642

Forwards Request for Addl Info Re Util Response to Generic Ltr 88-01.Reply Must Be Received within 60 Days of Ltr Date

ML20245H642
Person / Time
Site:	LaSalle
Issue date:	05/01/1989
From:	Shemanski P Office of Nuclear Reactor Regulation
To:	Kovach T COMMONWEALTH EDISON CO.
References
GL-88-01, GL-88-1, TAC-69141, TAC-69142, NUDOCS 8905030460
Download: ML20245H642 (11)

Text

'1 bek6T F2m f* C'%c

[k y(

UNITED STATES p,

NUCLEAR REGULATORY COMMISSION rn 1j WASHINGTON, D. C. 20S55 k*...+,/

May 1, 1989 Docket ilos.: 50-373 and 50-374 Mr. Thomas J. Kovach Nuclear Licensing Manager Coirs.cnwealth Edison Company Post Office Box 767 Chicago, Illinois 60690

SUBJECT:

LASALLE COUNTY STATION UNITS 1 AFD 2, GENERIC LETTER 88-01 RESPCilSE, REQUEST FOR ADDIT 10ftAL INFORMATION (TAC NOS. 69141 1

AliD 69142) i The Nterials Engineering Branch (EMT!!), Division of Engineering and Systems j

Technology, with assistence from its contractor, Viking Systems International q

(VSI) is reviewing and evaluating licensee submittals it. response to Generic l

Letter 88-01.

Addition 61 information is required from Ceco in order for the staff to complete the review. Thit is a hig:. priority item, and we request that e formal response to the attached questions be provided by CECO within 60 days of receipt of this letter.

In addition, to expedite the review process, please send a copy of CECO's response to NRC's contractor VSI at the following address:

j Dr. Armand A. Lakner Director, Safety and Reliability Viking Systerns International 101 Chestnut Street Gaithersburg, MD 20877 The reporting and/or recordkeeping requirements ennthinea in this letter affect fewer thun ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely,

'b Paul C. Shemanski, Project Manager e905030460 890501 Ned WecWate M PDR ADOCK 0500037:3 Division of Reactor Projects Ill -

P PDC IV, V and Special Projects

Enclosure:

As statea f

\\

cc:

See next page i

I

Docke.t Nos.:

50-373 and 50-374

' Mr. ' Thomas J. Kovach Nuclear Licensing Manager l

Commonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690

SUBJECT:

LASALLE COUNTY STATION UNITS 1 AND 2, GENERIC LETTER 88-01 RESPONSE, REQ' EST FOR ADDITIONAL INFORMATION (TAC NOS. 69141 J

AND69142)

The Materials Engineering Branch (ENTB), Division of Engineering and Systems Technology, with assistance from its contractor, Viking Systems International (VSI) is reviewing and evaluating licensee submittals in response to Generic Letter 88-01.

Additional information is required from CECO in order for the staff to complete the review. This is a high priority item, and we request that a formal response to the attached questions be provided by CECO within 60 days of receipt of this letter.

In addition, to expedite the review process, please send a copy of CECO's response to NRC's contractor VSI at the following address:

Dr. Armand A. Lakner Director, Safety and Reliability Viking Systems International 101 Chestnut Street Gaithersburg, MD 20877 The reporting and/or recordkeeping requirements conta "d in this letter affect fewer than ten respondents; therefore, OMB clearance n not required under P.L.96-511.

Sincerely, 05 Paul C. Shemanski, Project Manager Project Directorate III-2 Division of Reactor Projects III -

IV, Y and Special Projects

Enclosure:

l As stated cc:

See next page DISTRIBUTION Docket file OGC NRC & Local PDRs EJordan GHolahan BGrimes MVirgilio ACRS (10)

LLuther PShemanski PDIII-2 r/f Plant file THeLellan SBajwa f f.

fT. f0K PDIII-2 PDIII-2 PDIII-2 LLuther.

PShemanski DMuller 4/ M /89 5/ / /89 5'/ / /89

Mr. Thomas J. Kovach LaSelle County Nuclear Power Station Commonwealth Edison Company Units 1 & 2 cc:

Phillip P. Steptoe, Esquire John W. McCaffrey Sidley and Austin Chief, Public Utilities Division One First National Plaza SOIC Chicago, Illinois 60603 100 West Randolph Street Chicago, Illinois 60601 Assistant Attorney General 100 West Randolph Street r

Suite 12 i

Chicago, Illinois 60601 Resident Inspector /LaSalle, NPS U.S. Nuclear Regulatory Commission Rural Route No. 1 P. O. Box 224 i

Marseilles, Illinois 61341 j

Chairman LaSalle County Board of Supervisors LaSalle County Courthouse i

Ottawa Illinois 61350 Attorney General 500 South 2nd Street 1

Springfield, Illinois 62701 Chairman Illinois Commerce Commission Leland Building 527 East Capitol Avenue Springfield, Illinois 62706 Mr. Michael C. Parker, Chief Division of Engineering Illinois Departmont of Nuclear Safety 1035 Outer Park Drive, 5th Floor Springfield, Illinois 62704 Regional Administrator, Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road, Bldg. f4 Glen Ellyn, Illinois 60137 l

l

l ATTACHMENT A GENERAL QUESTIONS / REQUESTS I

Review of several licensee submittals has shown that most (although not all) 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 l

attachment for which the requested information was supplied (portions of this in the detail 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 BWR 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 88-01 include positions on:

(1) Materials.

(2) Processes.

(3) Water Chemistry.

(4) Weld Overlay.

(5) Partial Replacement.

(6 Stress Improvement of Cracked (8))CrackEvaluationandRepair Weldments.

(7)ClampingDevices.

Criteria.

(9)InspectionMethodandPersonnel.

(10) Ins Schedules.

(11)SampleExpansion.

(12) Leak Detection. pection (13)

Reporting Requirements.

Please supply information concerning whether the licensee:

(1) endorses these positions, (2) proposes alternate positions, exceptions, or provisions, and (3) is considering er planning to 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.

A-1

Table 1

~

Responses to NRC Staff Positions Licensee response

• Licensee Has/Will**

Accept Reg'uests with

. Alternate. Applied Consider for Staff Position Accept Provi'sions' Position in Past Future Use

1. Materials

2. Processes

3. Water Chemistry

4. Weld Overlay

5. Partial Replacement

6. Stress Improvement of Cracked Weldments

7. Clamping Devices

8. (sack Evaluation and i+.gair Criteria

9. Inspection Method and Personnel

10. Inspection Schedules

11. Sample Expansion

12. Leak 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 l

Staff Positions.

I l

l A-2

~

ATTACHMENT A (continued)

Item 2. Inservice Inspection Pronram Generic Letter 88-01 requests on page 3:

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

"An Inservice Inspection Program to be implemented at the next refueling outage for sustenitic stainless steel piping covered under the scope of this letter that conforms-to the staff positions on inspection schedules set, hods and personnel, and sample expansion included in this letter."

l 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 or did not provide the background data that is needed to evaluate the ISI Program such as (1) reasons / justification for IGSOC classification of welds, (2) methods, personnel qualification, schedules and identities of welds inspected, and (3) results of 3

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, 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., IGSOC Category A, B, C, D, E F and G).

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 i

(axial or circumferential), maximum len8th, maximum depth, repairs and/or mitigating treatments applied.

l Please nepply this information in tabular form using formats such-e as that illustrated in Tables 2 and 3.

A-3 T

L_________.____

~

\\

l Table 2 History of Welds and Prior Nutigating Actions / Treatments

• 1 1

Nbterial**.

IGSCC Veld Dia.

Casting Treatment ***

~

Caten Syste;m Number Configuration Inch Forainn. Pipe Weld SHT HWS CRC j(( 0.L.

l Notes:

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

For materials 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 "X" under appropriate column (s) if weld was treated using indicated technique, i.e., solution heat treated (SHT), heat sink welded (HSV), corrosion resistant clad (CRC),

i l

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 coordination plan, and whether treatment was applied within two i

years of service date. Also add explanation and justification of any overlays that were not standard (per NRC Staff position).

l e

e e

G A-4

1-Table 3 Inspection Schedules Inspected /To Be Inspected / Flaws Found IGSCC Weld Dia.

Past Future Caten System No.

Inch. Configuration R.O.fX-2 R.O.fX-1 Flaw R.O.fX R.O.fX+1 Instructions:

1. Under the heading, " Inspected /To BE Inspected," use as many columns 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.

rius (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 Eetter 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 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.

e A-5 d

0

I ATTACHMENT A (continued) i 1

Item 3. Welds Covered in Licensee Submittal Generic Letter 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 I

power operation regardless of Code classification. It also applie's

)

to reactor vessel attachments and appurtenances such as jet pump instrumentation penetration assemblies and head spray and vent j

components,."

Wereanywidsthatfallwithinthisdefinedscopeexcludedfrom$

)

the licensee submittal (for example, welds in the RWCU outboard of I

the isolation valves)? If previously excluded, please list identity

{

of such welds and plans for mitigation and inspections in Tables j

2 and 3 or provide alternative proposal. If IGSCC susceptible welds 4

were excluded from the licensee submittal based on temperature i

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

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

inspectable should be replaced, " sleeved", or local leak detection j

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 a'ecessible for UT inspections?

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

If not, please list these velds and plans for mitig'ation/ inspection.

I Item 5. Jeakake Detection l

Generic IAtter 88-01 states on page 3:.

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

l ATTACHMENT A (contir.ued)

Specification related to leakage detection will be in conformance 1

t 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:

i

1. Leakage detection should be in conformance with Position C of Regulatory Guide 1.45 " Reactor Coolant Pressure Boundary Leakage Detection Systems," or as ot'herwise 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 j

indicates an increase of unid'entified leakage in excess of 2 spe or its equivalent, or (b) the total unidentified leakage attains a rate of 5 gym l

or equivalent.

j j

3.14akage should be monitored (or determined from flow measurements if flow is continuously monitored) at approximately four hour intervals or less.

i

4. Unidentified leakage should include all leakage other than f

(a) leakage into closed systems, or 1

(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 Category D, E, F, or G welds, at lenst 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.

j j

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 A-7

1 j

e r

Table 4 Licensee Positions on Leakage Detection Already TS will be Alternate

. Contained Changed Position Position in TS to Include Proposed

1. Conforms with Position C of Regulatory Guide 1.45

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 4

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

3. Leakage monitored at four hour intervals or less.

~

4. Unidentified leakage includes all except:

(a) leakage into closed systems, or (b) leaksge into the containment atmosphere from sources that i

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 "X" or "yes" under appropriate column for each item.

and justification for alternative positions if not already provided. Provide description A-8 9

a

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _