ML20246M540

Forwards Request for Addl Info Re Generic Ltr 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping

ML20246M540
Person / Time
Site:	Perry
Issue date:	03/15/1989
From:	Colburn T Office of Nuclear Reactor Regulation
To:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
References
GL-88-01, GL-88-1, TAC-69152, NUDOCS 8903270190
Download: ML20246M540 (11)

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. March 15,-1989?

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Docket No'.L50-440

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$.secast DISTRIBUTION:

1 0es d1NRC & Local PDRs PDIII-3 r/f'~' GHolahan MVirgilio PKreutzer JHannon -TColburn- 4

Mr. Alvin Kaplan, Vice Presideri. 0GC-WF1 EJordan.

Nuclear Group. ..

BGrimes' .ACRS(10)

.The Cleveland Electric Illuminating' PDIII-3 Gray .CYCheng Company; .

TMcLellan 10' Center Road:

Perry, Ohio' 44081'- ,

SUBJECT:

GENERIC LETTER 88-01, "NRC POSITION ON IGSCC.IN BWR AUSTENITIC-STAINLESS STEEL' PIPING,"; REQUEST FOR ADDITIONAL INFORMATION

'(TACNO.:69152).

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We:have' received your July 29 -1988 response to the subject Generic Letter. In order for the' staff and our contractor, Viking Systems

' International (VSI) to complete our review, we request the additional information contained in the enclosure to this letter. We request that-

'you. respond within'60 days after receipt of this request and that you forward a copy.of your response.directly to our contractor at the following address:

Dr.-Armand A. Lakner Director, Safety and Reliability Viking' Systems International 101 Chestnut Street-Gaithersburg, MD 20877

.This. request' is cove' red by Office.of Management and Budget Clearance-S Number 3150-0011, which expires December ~31, 1989. The estimated average burden hours is 200. person-hours per owner response,. including assessment of the new recommendations, searching data sources, gathering-o and analyzing.the data, and preparing the required letter.' These esti-mated average burden hours pertain only to these identified response-related matters and do r.ot include the time'for actual implementation of the requested actions. Send comments regarding this burden estimate or any other t.spect of this collection of information, including suggestions for reducing this burden, to the Records and Reports Management Branch,

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I 8903270190 890315 I PDR ADOCK 05000440 l- P PDC o __ _ _

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ifr. Alvin Kaplan Division of Information Support Services, Office of Information Resources Management, U.S. Nuclear Regulatory Connission, Washington, D.C., 20055;.

and to the Paperwork Reduction Project (3150-0011), Office of Management and Budget, Washington, D.C. 20503.

If you have any questions please contact me'at (301) 492-1369.

Sincerely,

/s/

Timothy G. Colburn, Sr. Project Manager Project Directorate III-3 Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information b N0f Office: LA/PDIll-3 PM/PDIII-3 PD/PDIII-3 Surname: PKr'eut'2er TColburn/tg JHannon Date: 5 /g /89 f 3 //f /89 3 // 6 /89 I

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. Mr. Alvin Kaplan .

Perry Nuclear Power Plant

.The Cleveland Electric Unit 1 Illuminating Company I cc: Jay E. Silberg, Esq. Mr. James W. Harris, Director

, Shaw, Pittman, Potts & Trowbridge Division of Power Generation

, 2300 N Street, N.W. Ohio Department of Industrial i

Washington, D.C. 20037 Relations  !

P. O. Box 825 l David E. Burke Columbus, Ohio 43216

! The Cleveland Electric Illuminating Company The Honorable Lawrence Logan P.O. Box 5000 Mayor, Village of Perry Cleveland, Ohio 44101 4203 Harper Street-Perry, Ohio 44081 Resident Inspector's Office U.S. Nuclear Regulatory Comission The Honorable Robert V. Orosz  !

Parmly at Center Road Mayor, Village of North Perry Perry, Ohio 44081 North Perry Village Hall 4778 Lockwood Road ,

Regional Administrator, Region III North Perry Village, Ohio 44081  :

U.S. Nuclear Regulatory Comission 799 Roosevelt Road Attorney General Glen Ellyn, Illinois 60137 Department of Attorney General l 30 East Broad Street Frank P. Weiss, Esq. Columbus, Ohio 43216 Assistant Prosecuting Attorney  !

105 Main Street .

Radiological Health Program Lake County Administration Center Ohio Department of Health Painesville, Ohio 44077 1224 Kinnear Road Columbus, Ohio 43212 Hs. Sue Hiatt OCRE Interim Representative Ohio Environmental Protection ,

8275 Munson Agency Mentor, Ohio 44060 361 East Broad Street Columbus, Ohio 43266-0558 Terry J. Lodge, Esq.

618 N. Michigan Street Mr. Phillip S. Haskell, Chairman Suite 105 Perry Township Board of Trustees Toledo, Ohio 43624 Box 65 4171 Main Street John G. Cardinal, Esq. Perry, Ohio 44081 Prosecuting Attorney Ashtabula County Courthouse State of Ohio Jefferson, Ohio 44047 Public Utilities Comission 180 East Broad Street Robert A. Newkirk Columbus, Ohio 43266-0573 Cleveland Electric Illuminating Company Michael D. Lyster Perry Nuclear Power Plant Cleveland Electric P. O. Box 97 E-210 Illuminating Company Perry, Ohio 44081 Perry Nuclear Power Plant P. O. Box 97 SB306 Perry, Ohio 44081

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. ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION GENERAL QUESTIONS / REQUESTS Reviews of several licensee submittels 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 portiens of this attachment for which the requested information was supplied (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 req'uested information that was not provided. However, if the information requested concerning any of the items herein was not provided in the original licensee submittal, an omission of that information from the response to this RAI will be construed as an endorsement of the applicable NRC Staff position.

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 Weldments. (7) Clamping Devices.  ;

Criteria. (9) Inspection Method and(8) Crack Evaluation and Repair Personnel. (10) Inspection Schedules. (11) Sample Expansion. (12) Leak Detection. (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 or 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 that illustrated in the example shown in Table 1.

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. Table 1 Responses to NRC staff Positions ,

Licensee Response

• Licensee Has/Will**

Accept Requests

, with Alternate Applied Consider for Staff Position- Accept Provisions Position in Past Future Use

1. Nbterials

2. Processes

3. Water Chemistry

4. Weld Overlay

5. Partial Replacement

6. Stress Improvement of

• Cracked Weldments

7. Clamping Devices .

8. Crack Evaluation and -

Repair Criteria .

9. Inspection Method and Personnel

10. Inspection Schedules

11. Sawple Expansion

12. Leak Detection

13. Reporting Requirements l

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Answer with "yes", " check markt' or "X" in appropriate column for each of the (

13 NRC Staff Positions. List and explain each provision and/or alternate j 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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Item 2.: Inservice Insoection Proaram Generic Letter 88-01 requests on page 3: i j

i t, "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

• under the scope of this letter that conforms to the staff positions on inspection schedules methods and personnel, and sample expansion included in this letter."

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'Ihe information pertaining to the pipe replacement and other $

mitigating actions as well as the Inservice Inspection Progrant 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 identitias of welds inspected, and (3) results of previous inspections, e,ad/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., IGSCC 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 velding (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 outa inspections, (ge. Include b) flaw (a) dates and characteristics results of including previous orientation ,

3 (axial or circumferential), maximum length, maximum depth, repairs and/or mit! rating treatments applied.

j Please supply this information in tabular fdra 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 Weld Dia. Casting Treatment ***

Caten System Number Configuration Inch Foraina. Pipe Weld SNT HWS CRC JI,O.L.

Notes:

l 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 "I" under appropriate column (s) if weld was treated using indicated technique, i.e., solution heat treated (SNT) heat sink welded (HSW), corrosion resistant clad (CRC),

stress improved (SI), or overlayed (0.L.). For SI, add explanation of method ured, 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 treatmeht 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 Inepected/To Be Inspected / Flaws Found l

ICSCC Weld Dia. Past Future 1 Cates System No. Inch. Configuration R.O.fX-2 R.O.fX-1 Flaw R.O.f1 R.O.fX+1 Instructions:

1. Under the heading, " Inspected /To BE Inspected," use as many column.s 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 (I-2, I-1, I, I+1) with actual refueling outage numbers. Indicate dates inspections were/will be performed.

3. Liat each weld within the scope of Gcneric 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.

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-Item 3. Welds Covered in Licensee Submittal j Generic Intter 88-01 (on page 2) states:

i "This Generic IAtter 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 had head spray and vent components."

Vere any welds that fall within this defined scope excluded frow 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 sitigation 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 describs in detail the method of temperature measurements.

Item 4. Welds that Are Not UT Inspectable Generic Letter 88-01 (in Table 1) states: " Welds that are not Ur 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 fors (a) All welds that are inaccessible for UT inspections?

(b) All welds that are only partially accessible for UT inspections? a (c) Welds that cannot be UT inspected because of geometrical constraints or other reasons. -

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

Item 5.14akane Detection

• Generic Intter 88-01 ccates on page 3: .

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" Confirmation of you plans to ensure that the Technfcal '

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b 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 Leakage 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 spa or its equivalent, or (b) the total unidentified leskage 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. 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 Category 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 /> i or immediately initiate an orderly shutdown.

Although a,ost licensee submittals describe the intention of meeting some or all of these requirements or offer siternative 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 l

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

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Table 4 Licensee Positions on Leakage 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 d l

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 spa, or i (b) the total unidentified leakage attains a rate of 5 spm.

3. Leakage' monitored at four hour

• intervals or 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 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: i Place "I" or "yes" under appropriate column for each item.

and justificatica for alternative positions if not already provided. Provide description  !

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