ML20246P419

Requests Addl Info Re Util 880808 Response to Generic Ltr 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping. Response Needed within 60 Days of Ltr Receipt

ML20246P419
Person / Time
Site:	Grand Gulf
Issue date:	05/15/1989
From:	Kintner L Office of Nuclear Reactor Regulation
To:	Cottle W SYSTEM ENERGY RESOURCES, INC.
References
GL-88-01, GL-88-1, TAC-69137, NUDOCS 8905220185
Download: ML20246P419 (11)

Text

,

(P, Y.

E. y :.

,..<--y-(,?? ' '.,

May15.j989

[

DISTRIBUTION.

~

1-Mr NRC PDR Local PDR

~,

PD21 r/f SVarga (14E4) 6 Docket No. 50 416' Glainas i.

.Mr. W..T. : Cottle PAnderson

~

EAdensam-Vice President, Nuclear Operations OGC System Energy. Resources',LInc.

Edordan'(MNBB3302)'

. Post Office Box:23054 BGrimes-(9A2).

Jackson, Mississippi 39205 T; McLellan;(9H3).

ACRS(10)

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - GRAND GULF NUCLEAR STATION, (GGNS), UNIT 1-(TAC NO. 69137):

By. letter dated August 8. 1988 System Energy Resources, Inc..; responded to Generic Letter 88 01 entitled "NRC Position on;IGSCC in BWR Austenitic Stainless Steel Piping.." The NRC staff is reviewing this submittal:and. finds that additional information is needed to complete our review. The request for

.. additional'information is attached.

'In' order to support our review schedule, you are requested to'. respond to the attached request within 60 days of your receipt of this letter.-

To. expedite the review process, it is requested that a copy of your response ll to'the attached request be sent. directly to the staff's contractor at the following address:

l Dr. Armand A. Lakner Director, Safety and Reliability Viking Systems International-101 Chesnut Street Gaithersburg, Maryland 20877 The reporting.and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore, 0MB clearance is not required under P. L.

n78;96-511.

G8' Jg Sincerely,

/w*i g}

O L 20 Lester L. Kintner, Senior Project Manager -

' 58 Project Directorate 11 1 y

Division of Reactor Projects I/II on

Attachment:

Request for Additional JG11 Information cc w/ attachment:

See next page r

[GGNSRAI69137]

[9(

0 n.

OK. :LA:

glL

'PR:PM:P DRPR:D

DRPR L.,

NAME-:P

% LKi ner:jfw:EAdensam q..

.....:............:............:.. f.......:............:............:............:...........

DATE25/df89-

5/11/89

5A h/89'

j i:

'Mr. W. T. Cottle

~ System' Energy Resources, Inc.

Grand Gulf Nuclear Station (GGNS) sc:

Mr. T. H. Cloninger Mr. C. R. Hutchinson Vice President, Nuclear Engineering GGNS General Manager and Support System Energy Resources, Inc.

System Energy Resources, Inc.

P. O. Box 756' P. 0. Box 23054 Port Gibson, Mississippi 39150 Jackson, Mississippi.39205 Robert B. McGehee, Esquire The Honorable William J. Guste, Jr.

Wise, Carter, Child, Steen and Attorney General Caraway Department of Justice P. 0.' Box 651-State of Louisiana Jackson, Mississippi 39205 Baton Rouge, Louisiana 70804 Nicholas S. Reynolds, Esquire Office of the Governor' Bishop. Liberman, Cook, Purcell State of Mississipp!

and Reynolds Jackson, Mississippi 39201 1400 L Street, N.W.

Washington, D.C.

20005-3502 Attorney General Gartin Building l

Mr. Ralph T. Lally Jackson, Mississippi 39205

. Manager of Quality Assurance Middle South Utilities System Mr. Jack McMillan, Director Services, Inc.

. Division of Solid Waste Management 639 Loyola Avenue. 3rd Floor Mississippi Department'of Natural New Orleans, Louisiana 70113 Resources

' P. O. Box 10385 Mr. John G. Cesare-

' Jackson, Mississippi 39209 Director, Nuclear Licensing System Energy Resources, Inc.

Alton B. Cobb, M.D.

P. O. Box 23054.

State Health Officer Jackson, Mississippi. 39205 State Board of Health P. O. Box 1700 Mr. C. B. Hogg, Project Manager Jackson, Mississippi 39205 Bechtel Power Corporation P. O. Box 2166 President-Houston, Texas 77252-2166 Claiborne County Board of Supervisors Port Gibson, Mississippi 39150 Mr. H. 0..Christensen Senior Resident Inspector Regional Administrator, Region II U.S. Nuclear Regulatory Commission U. S. Nud ear Regulatory Commission Route 2 Box 399 101 Marietta Street Port Gibson, Mississippi 39150 Suite 2900 Atlanta, Georgia ~ 30323 l

s i

S REQUEST FOR ADDITIONAL INFORMATION ATTACHMENT A Reviews of several licensee submittals responding)to Generic Letter 88-01 (GL 88-01) have shown that most (although not all of the sebmittals 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 l

to each of the licensees.

For those portions 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 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 by providing the following information.

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.

(8) Crack Evaluation and Repair Criteria.

(9) Inspection Method and Personnel.

(10) Inspection Schedules..(11) Sample Expansion.

(12)LeakDetection.

(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 Table 1.

A-1

l

. a l

Table 1 Responses to NRC Staff Positions Licensee Response

• Licensee Has/Will**

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

1. Materials

2. Processes

3. Wetter Chemistry

4. Weld Oveilay

5. Partial Replacement

6. Stress Improvement of Cracked Weldments

'7. Clamping Devices

8. Crack Evaluation an'd Repair Criteria

'9. Inspection Method and. Personnel

10. Inspection Schedules

11. Sample Expansion 1

12. Imak Detection

13. Reporting Requirements 1

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

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

A-2 I

,, ~

1 ATTAC10(ENT A (continued)

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

l l

"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."

The information pertaining to the pipe replacement and other mitigating actions an 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, 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 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 l

l refueling outage. Include (a) dates and results of previous irapections (b) flaw characteristics including orientation 1

(axial or circumferential), maximum length, maximum depth, 1

repairs and/or mitigating treatments applied.

Please supply this information in tabular form using formats such as that illustrated in Tables 2 and 3.

l A-3 l

i l

1

Table 2 History of Welds and Prior Mitigating Actions / Treatments

• Material **

IGSCC Weld Dia.

Casting Treatment ***

Qteg System Number Configuration Inch Fornina. Pipe Weld SHT HSW CRC SI 0.L.

Notes:

List each weld sentrately, using one or mere lines as required.

• • For material: 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 huat 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/or 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).

A4

)

4,,a e

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

Past Future Caten System No.

Inch. Configuration R.O.fI-2 R.O.fI-1 Flaw R.O.fI R.O.f1+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.

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

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

4. Place an "X" 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 Jescribing any repairs made.

I A-5 l

g, s

't ATTACHMENT A (continued)

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 austenitic stainless steel that is four inches or larger in nominal diameter and contains reactor coolant at a temperature above 200'F during power operation regardiens of Code classification. It also applies to reactor vessel attachments and appurtenances nuch 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 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 in detail the method of temperature measurements.

Item 4.WeldsthatAreNotUTInspectable 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 ITT inspections?

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

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

J If not, please list these velds and plans for mitigation / inspection.

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

1

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

I' ; a ~. ' L Y

t ATTACHMENT 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 Intter 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 gpa or its equivalent, or (b) the total unidentified leakage attains a rate of 5 spm 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 4, 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 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 arelcontained in the Technical Specifications. Thus it is requested that this information should be providedeby-each-licensee. For, clarity and completeness, please use a checklist such as that illustrated in Table 4 A-7 4

w___________._____.-._.

l lC '

A.

D'

~ ;

l 1

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:

(q) withia 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 gpe, or (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:

Place "X" or "yes" under appropriate column for each item. Provide description and justification for alternative positions if not alrea3.y provided.

A-8 j

i

n. ; e i

.-; { ' i ATTACHMENT B REQUEST.FOR. ADDITIONAL INFORMATION PERTAINING TO GRAND GULF NUCLEAR STATION

. RESPONSE TO GENERIC-LETTER 88-01

. Item.1.

Inservice Inspection Program For previous inspections, please include information concerning.

inspection methods.. For example, your August 8,1988 submittal indicated that at least some previous inspections were performed per Generic Letter 84-11 and NUREG 0313, Revision 1.

Which previous inspections were included, and which inspections were performed per other methods?

n 1

i L

,