ML20247E277

Requests Addl Info Re IGSCC Problems in BWR Austenitic Stainless Steel Piping,Per Generic Ltr 88-01.Response Should Be Provided within 60 Days

ML20247E277
Person / Time
Site:	Hope Creek
Issue date:	03/24/1989
From:	Shiraki C Office of Nuclear Reactor Regulation
To:	Miltenberger S Public Service Enterprise Group
References
GL-88-01, GL-88-1, NUDOCS 8904030016
Download: ML20247E277 (11)

Text

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March 24, 1989 Docket No. 50-354 _ DISTRIBUTION: w/ encl [.

!Docteti11ea' NRC PDR/LPDR PDI-2 Reading Glainas/BRoger Mr. Steven E. Miltenberger M0'Brien CShiraki/SBrown Vice President and Chief Nuclear OGC EJordar.

Officer .

BGrimes ACRS (10)

Public Service Electric & Gas Company CCheng, DEST Post Office Box 236 Hancocks Bridge, New Jersey 08038

SUBJECT:

INTERGRANULAR STRESS CORROSION CRACKING (IGSCC) PROBLEMS IN BWR AUSTENITIC STAINLESS STEEL PIPING Re: HOPE CREEK GENERATING STATION The.NRC is evaluating Hope Creek Generating Station's response to Generic Letter 88-01. Enclosed are questions that address additional information that is required to complete the review. A formal response is requested to these questions within sixty days of receipt of this request. To expedite the review process, please include in the distribution of your response, a copy to the NRC's contractor at the following address:

1 l Dr. Armand A. Lakner, Director Safety & Reliability Viking Systets International 101 Chestnut Street Gaithersburg, MD 20877 Sincerely, Clyde Shiraki, Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure: .

See next page

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% , ,', , , # March 24, 1989 Docket No. 50-354 Mr. Steven E. Miltenberger Vice President and Chief Nuclear Officer Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, New Jersey 08038

SUBJECT:

INTERGRANULAR STRESS CORROSION CRACKING (IGSCC) PROBLEMS IN BWR AUSTENITIC STAINLESS STEEL PIPING Re: HOPE CREEK GENERATING STATION The NRC is evaluating Hope Creek Generating Station's response to Generic Letter 88-01. Enclosed are questions that address additional information that is required to complete the review. A formal response is requested to these questions within sixty days of receipt of this reouest. To expedite the review process, please include in the distribution of your response, a copy to the NRC's contractor at the following address:

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

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Clyde Shiraki, Project Manager  !

Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure:

See next page 1

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Mr. Steven E. Miltenberger Hope Creek Generating Station Public Service Electric & Gas Co.

cc:

M. J. Wetterhahn, Esquire Conner & Wetterbahn Suite 1050 1747 Pennsylvania Avenue Washington, D.C. 20006 R. Fryling, Jr., Esquire Law Department - Tower SE 80 Park Place Newark, New Jersey 07101 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 241 Hancc:ks Bridge, New Jersey 08038 l Mr. S. LaBruna Vice President - Nuclear Operations Nuclear Department P.O. Box 236 Hancocks Bridge, New Jersey CP038 Mr. J. J. Hagan General Manager - Hope Creek Operations Hope Creek Generating Station P.O. Box 236 Hancocks Bridge, New Jersey 08038 Mr. B. A. Preston, Manager Licensing and Regulation Nuclear Department P.O. Box 236 Hancocks Bridge, New Jersey 08038  !

l l Regional Administrator, Region I l U.S. Nuclear Regulatory Commission i

475 Allendale Road King of Prussia, Pennsylvania 19406 l Mr. David M. Scott, Chief Bureau of Nuclear Engineering Division of Environmental Quality Department of Environmental Protection State of New Jersey CN 411 Trenton, New Jersey 08625 l

________m______ _ _ _ _ _ _ _ _ _ _ _ _

ATTACHMENT A GENERAL QUESTIONS / REQUESTS Reviews of several licensee submittals has shown that most (although not all) of the submittals consonly 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 portions of this attachment for which the requested information was I supplied (in the detail requested herein) in the original submittal, the '

utilities may reference the relevant pages or tables in the original subeittal and supply only the requested 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 Intter 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 oash 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 IAtter 88-01 include positions on: (1) Haterials. (2) Processes. (3) Water Chemistry. (4) Weld Overlay. (5) Partial Replacement. (6) Stress Improvement of Cracked Weldsents. (7) Clamping Devices. (8) Crack Evaluation and Repair Criteria. (9) Inspection Method and 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 l \

Responses to NRC Staff Positions Licensee Response

• Licensee Has/Will** '

Accept Requests with Alternate Applied Consider for j Staff Position Accept Provisions Position in Past Future Use l l

1. Materials l l

2. Processes

3. Water Chemistry

4. Weld Overlay

5. Partial Replacement

6. Stress Improvement of Cracked Weldsents

7. Clamping Devices

8. Crack Evaluation and Repair Criteria

9. Inspection Method and Personnel

10. Inspection Schedules

11. Sample Expansion '

12. Leak Detection

13. Reporting Requirements

• Answer with "yes", " check mark" or "X" in appropriate column for each of the 13 NEC 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 A (continued)

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

"Your current plans regarding pipe replacement and/or other )

measures taken or to be taken to mitigate ICSCC 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 as well as the Inservice Inspection Program provided in most of the licensee sabaittals 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 albow, 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 I 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 (Str), 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 (exial or circumferential), maximum length, maximum dept.h, 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 Weld Dia. Casting Treatment ***

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

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1 Notes:

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

• • For materiait 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/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 overlaya that were not standard (per NRC Staff position).

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Table 3 Inspection Schedules Inspected /To Be Inspected / Flows Found IGSCC Weld Dia. Past Future Cater System No. Inch. Configuration R.O.fI-2 R.O.fI-1 Flaw R.O.f1 R.O f!+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 1

(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 14tter 88-01.

2. Replace R.0.# (X-2. 1-1, I, I+1) with actual refueling outage l numbers. Indicate dates inspections were/will be performed. I

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

4. Place an "K" 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 "fisw" if a fisw indication was found. Attach a statement for each flawed weld giving the orientation (axial or circumferential), the dimensions (maximum i length and depth), and describing any repairs made.

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.- l ATTACHMDff A (cantinued)

Item 3. Welds Covered in Licensee Submittal Generic Letter 88-41 (on page 2) states:

"This Generic 1Atter applies to all BWR piping made of austenitic j stainless steel that is four inches or larger in nominal diameter ]

and contains reactor coolant et 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 escluded from the licensee submittal (for example, welds in the RWCU outboard cf 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 IGSOC 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. Welds that Are'Not W Inspectable Generic Intter 88-01 (in Table 1) states: " Welds that are not trf 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 (s) All welds that are inaccessible for UT 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.

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

Item 5. Leakene Detection Generic !atter 88-01 states on page 3:

" Confirmation of you plans to ensure that the Technical 4

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ATTAOMElff A (continued) l Specification related to leakage dete tion 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. IAakage 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 leakage attains a rate of 5 spa or equivalent.

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

A. Un% ratified 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 c droughwall crack.

5. For plaats operating with any ICSCC Category D, E, F, or G welds, at least one of the leakne measurement. instruments associated with each surp chn11 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 rar!to ted that this information should be provided by each lieragra, For clarity and completeness, please use a checklist such a tb 4t illustrated in Table A.

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Table 4 Licensee Positions on Imakage 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 whens (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 gpm, 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) 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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