ML20247E715

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Forwards Request for Addl Info to Enable NRC & Contractor (Viking Sys Intl) to Continue Review of Responses to Generic Ltr 88-01 Re IGSCC in BWR Austenitic Stainless Steel Piping.Response Requested in 60 Days of Ltr Receipt
ML20247E715
Person / Time
Site: Cooper Entergy icon.png
Issue date: 05/17/1989
From: Oconnor P
Office of Nuclear Reactor Regulation
To: Trevors G
NEBRASKA PUBLIC POWER DISTRICT
References
GL-88-01, GL-88-1, TAC-69131, NUDOCS 8905260319
Download: ML20247E715 (11)


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May 17,.1989 e

~ Docket No. :50-298-

. Mr. Gecrge A' .Trevors, Division F Manager - Nuclear Support l Nebraska Public Power District Post Office Box 499 Columbus, Nebraska 68601

Dear Mr. Trevors:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - GENERIC LETTER 88 (TACNO.69131)

The NRC staff.and its contractor, Viking Systems International, are reviewing  ;

and' evaluating Nebraska Public Power District's August 3, and December 19, 1988 responses to Generic Letter 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping. The staff finds that the additional information identified in Attachment A~is. required to complete the review. Please provide your response to the Attachments within 60 days of your the receipt of this letter. To expedite:the review process, please send a copy of your response to the NRC Contractor at the following address:

Dr. Armand A. Lakner Director, Safety and Reliability Viking Sysi ms International i 101 Chestnut Street Gaithersburg, Maryland 20877 The request for information was approved by the Office of Management and Budget under clearance number 3150-0011 which expires December 31, 1989.

Sincerely,

/s/

Paul W. O'Connor, Project Manager Project Directorate - IV-Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Attachment:

Request for Additional Information on Generic Letter 1 88-01, General Questions / Requests  !

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.cc w/ attachment:

See next page j j

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5 E NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 k . . . . .j May 17, 1989 Docket No. 50-298 Mr. George.A. Trevors, Division

. Manager - Nuclear Support Nebraska-Public Power District Post Office Box 499 Columbus, Nebraska 68601

Dear Mr. Trevors:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - GENERIC LETTER 88-01 (TACNO.69131)

The f RC staff and its contractor, Viking Systems International, are reviewing and evaluating Nebraska Public Power District's August 3, and December 19, .

1988 responses to Generic Letter 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping. The staff finds that the additional information identified in Attachment A is required to complete the review. Please provide your response to the Attachments within 60 days of your the receipt of this letter. To expedite the review process, please send a copy of your response to the NRC Centractor at the following address:

Dr. Armand A. Lakner Director, Safety and Reliability Viking Systems International 101 Chestnut Street Gaithersburg, Maryland 20877 The request for information was approved by the Office of Management and Budget under clearance number'3150-0011 which expires December 31, 1989.

Sincerely, W .

Paul W. O'Connor, Project flanager Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Attachment:

Request for Additional '

Information on Generic Letter 88-01, General Questions / Requests cc w/ attachment:

See next page I

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Mr. George A. ;Trevors Nebraska Public Power District Cooper Nuclear Station CC: .

Mr. G. D. Watson, General Counsel Nebraska Public. Power District-P. O. Box 499 Columbus, Nebraska 68601 Cooper Nuclear Station ATTN: Mr. Guy R. Horn, Division Manager of Nuclear Operations P. 0. Box 98.

Brownville, Nebraska .68321 Dennis Grams, Director Nebraska Department of Environmental Control P. O. Box 98922 Lincoln, Nebraska 68509-8922 Mr. Larry Bohlken, Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 218 Brownville, Neb'raska 68321 I

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Mr. Harald Borchart, Director Division of Radiological. Health Department of Health 301 Centennial Mall, South P. O. Box 95007 Lincoln, Nebraska 68509-5007 l

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t ATTACHMENT A GENERAL QUESTIONS / REQUESTS Reviews 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 portions of this at;.achment 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 NRC Staff positions in Generic Letter 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 Veldments. (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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a-Table 1 Responses to NRC Staff Positions a

Licensee Response

  • Licensee Has/Will**

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

1. Materials
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 Perscanel

10. Inspection Schedules '
11. Sample Expansion
12. IAak Detection
13. Report,ing Requirements Answer with "yes", " check mark" or "I" in appropriate column for each of the i

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 Staff Positions.

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ATTACHMENT A (continued)

Item 2. Inservice Inspection Program 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 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."

'Ihe 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 IGSCC l 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 IGSOC 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 l 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 celds to be inspected during past and future refueling outage. Include (a) dates and results of previous inspections, (b) flaw characteristics including orientation (axial or circsaferential), maximum length, maximum depth, repairs and/or mitigating treatments applied.

I 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

  • l Material **

ICSCC Weld Dia. Casting Treatment *** '

Caten System Number Configuration Inch Forging. Pipe Veld SHT HWS CRC SI 0.L.

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Notes:

List each weld separately, using one or more 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 I material type (e.g., Type 316 NG).

      • For trestment 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 overlays that were not standard (per NRC Staff position).

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Table 3 Inspection Schedules Inspected /To Be Inspected /Flavs Found IGSCC Weld Dia. Past Future Caten System No. Inch. Configuration R.O.fI-2 R.O.iI-1 Flav R.O.fI R.O.fI+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.

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(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. I

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. i

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, . l ATTACHMENT A (continued) 1 Item 3. Welds Covered in Licensee Submittal l Generic Intter 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 regardless of Code classification. It also applies j to reactor vessel attachments and appurtenances such as jet pump J instrumentation penetration assemblies and head spray and vent i 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 f of such welds and plans for sitigation 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 UT Inspectable Generic Intter 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 UT inspections?

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

(c) Welds that cannot be UT inspected because of geometrical 3 constraints or other reasons.

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

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

" Confirmation of you plans to ensure that the Technical

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ATTACHMENT A (continued)

Specification related to leakage detection will be in conformance with the staff position on leak detection included in this letter."

1he 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 pystems," 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. 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 /> 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 reqtsested 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

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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

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

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.

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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 ites. Provide description and justification for alternative positions if not already provided.

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