ML20247M898

Forwards Request for Addl Info Re 880727 Response to Generic Ltr 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping. Response Should Be Sent to Viking Sys,Intl at Listed Address

ML20247M898
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/24/1989
From:	Fairtile M Office of Nuclear Reactor Regulation
To:	Capstick R VERMONT YANKEE NUCLEAR POWER CORP.
References
GL-88-01, GL-88-1, TAC-69160, NUDOCS 8906050188
Download: ML20247M898 (10)

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May 24,1989 '

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l e = Docket No..50-271 a.

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e Mr. R. ~ W.' Capstick Licensing Engineer .

. Vermont Yankee Nuclear Power corporation-580 Main Street Bolton, Massachusetts 01740-1398

SUBJECT:

-REQUEST FOR ADDITIONAL INFORMATION.(TAC'69160.)

By letter ' dated July 27,1988,.you responded to our Generic Letter 88-01, .

dated January 25, 1988 entitled, "NRC Position.on IGSCC in BWR Austenitic Stainless Steel Piping." Our staff with' assistance from.our contractor, Viking-SystemsiInternational'(VSI) is. reviewing your response for the . Vermont

Yankee Nuclear' Power Station. Additional information, questions enclosed..is

1. required from you in order for the staff to complete its review.

We. request that ycu se'nd a copy of your response' to VSI at the following address:

Dr. Armand A. Lakner Director, Safety.& Reliability Viking Systems. International

. 101 Chestnut Street Gaithersburg, Maryland 20877 Kindly respond within 60 days of. receipt of this , letter..

Sincerely, Original Signed by:

l '. Morton B. Fairtile, Project Manager Project Directorate I-3 Division of Reactor Projects I/II

Enclosure:

As stated cc w/ encl.:

See next page' DISTRIBUTION:190ehetaMg, NRC& Local PDRs, MFairtile, MRushbrook, SVarga, BBoge BGrimes,EJordan,ACRS(10), essman, Dr.Lakner, CYCheng, TMcLellan,

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m .1 Mr. R. W.-.Capstick Vermont. Yankee Nuclear. Power Corporation Vermont Yankee Nuclear Power' Station CC: -

Mr. J. ._ Gary _ Weigand W. P. Murphy, Vice President ~

' President & Chief. Executive Officer and Manager of Operations Vermont Yankee Nuclear Power Corp. Vermont Yankee Nuclear Power Corp.

R.D. 5, Bcx 169 R.D. 5, Box 159 Ferry Road - Ferry Road-Brattleboro, Vermont 05301 .Brattleboro, Vermont _ 05301 Mr. John.DeVincentis, Vice President Mr. George Sterzinger, Commissioner-Yankee Atomic Electric Company Vermont Department of Public Service.

580 Main Street- 120 State Street, 3rd Floor:

Bolton, Massachusetts 01740-1398' Montpelier, Vermont 05602 New England Coalition on Nuclear Public Service Board

Pollution State _of Vermont L

Hill and Dale Farm '120 State Street R.D. 2, Box 223 Montpelier, Vermont 05602 Putney, Vermont 05346 Vermont Public Interest Research Group, Inc. G. Dean Weyman 43 State Street .

Chairman,. Board of Selectman Montpelier, Vermont 05602 Post Office Box 116-Vernon, Vermont 05354

^ William Russell,' Regional Administrator Raymond N. McCandless Region I Office .

Vermont Division of Occupational

- U.S. Nuclear Regulatory Commission 'and Radiological Health 475 Allendale Road Administration Building King of Prussia, Pennsylvania 19406 Montpelier, Vermont 05602 Mr. R. W. Capstick Honorable John J. Easton Vermont Yankee Nuclear Attorney General Power Corporation State of Vermont 580 Main St. 109 State Street Bolton, Massachusetts 01740-1398 Montpelier, Vermont 05602 R. K. Gad III Ropes & Gray Conner & Wetterhahn, P.C.

225 Franklin Street Suite 1050 Boston, Massachusetts 02110 1747 Pennsylvania Avenue, N.W.

Washington, D.C. 20006

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Vermont Yankee Nuclear Power - 2'- Vermont Yankee Nuclear Power Station Corporation-cc:

Diane Curran, Esq. Resident Inspector Harmon, Curran & Tousley U.S. Nuclear Regulatory Comission 2001 S Street, N.W., Suite 430 P.O. Box 176' Washington, D.C. 20009 Vernon, Vermont 05354 David J. Mullett, Esq. John Traficonte, Esq.

Special Assistant Attorney General Chief Safety Unit Vermont Depart. of Public Service Office of the Attorney General 120 State Street . One Ashburton Place, 19th Floor Montpelier, VT 05602 Boston,.MA 02108 Jay Gutierrez Geoffrey M. Huntington, Esquire Regional Counsel Office of the Attorney General USNRC, Region I . Environmental Protection Bureau 475 Allendale Road State House Annex King of Prussia, PA 19406 25 Capitol Street Concord, NH 03301-6397 G. Dana.Bisbee, Esq. Charles Bechhoefer, Esq.

Office of the Attorney General Administrative Judge Environmental Protection Bureau Atomic Safety and Licensing Board State House Annex U.S. Nuclear Regulatory Comission 25 Capitol Street Washington, DC 20555 Concord, NH 03301-6397 Dr. James H. Carpenter Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 Mr.. Gustave A. Linenberger, Jr. Adjudicatory File (2).

Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel Docket U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, D.C. 20555

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ATTACHMENT A GENERAL QUESTIONS / REQUESTS Reviews of several licensee submittals has shown that most (although not all) of,the submittals connonly lack certain information that is needed for evaluation of the submittals. Thus, this general list of questions and requests has been For those prepared..for submission to each of the licensees.attachmentforwhichtherequestedin in the detail requested herein) in the original submittal, the utilitias 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 88-02 include positions on: (1) Materials. (2) Processes. (3) Water Chemistry. (4) Weld Overlay. (5) Partial Replacement. (6)StressImprovementofCracked Weldments. )ClampingDevices. (8) Crack Evaluation and Repair Criteria. ( Inspection Method and Personnel. (10) Inspection Schedules. 1) Sample Expansion. (12) Leak Detection. (13)

Reporting Requirements.

Please supply information concerning whether the licensee: (1) endorsesthesepositions,(2)proposesalternatepositions, exceptions,orprovisions,and(3)is'consideringorplanningto 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.

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Table 1 ,

Responses to NRC Staff Positions Licensee Response

• Licensee Eas/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 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 neyded,

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

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ATTAODIDIT- A (continued)

Ites 2. Inservice Inspection Pronras Generic 14tter 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-ters integrity and reliability."'

"An Inservice Inspection Program to be implemented at the next refueling outage for avstenitic stainless steel piping covered under the scope of.this letter that conforms to the staff.

positions on inspection schedules methods and personnel, and sample expcssion included in-this letter."

The information pertaining to the pipe replacement and other mitigating actions as well as the Inservice Inspection Progras 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 systes, 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 ICSCC 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 refueling outage. Include (a) dates and results of previous inspections,'(b) flaw characteristics including orientation (arial or circumferential), maximus length, maximum depth, 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 TreatmentM* ,

Caten Systes Number Configuration Inch Formina. Pine Weld SHT NWS CR_C_ g 0.L. I Notes:

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

• • ' For asterials identify as non-conforming or conforming as appropriate concerning whether it conforms with the NRC Staff posttion on resistant asterials. 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 overlays th,at were not standard (per NRC Staff position).

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Table 3 Inspection Schedules Inspected /To Be Inspected / Flaws Found IGSCC Weld Dia. Past Future Q.tt e_g System No, Inch._ Confinuratior. R.O.fI-2 R.O.fI-1 Flaw R.O.JI R.O.f1+1 I

Instructions:

1. Under the heading, " Inspected /To BE Inspected," use as many columns as required to describe the followings (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 IAtter 88-01.

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

3. List each weld within the scope of Generic IAtter 88-41.

4. Piece an "I" or other appropriate symbol under the appropriate column for each refueling outage for which that veld 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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ATTACHMENT A (continued)

Item 3. Velde Covered in Licensee Submittal Generic 1Atter 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 dieseter l 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 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 escluded, 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 deceribe in detail the method of temperature measurements.

Ites 4. Velds that Are Not trT Inspectable Generic !atter 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 fors (a) All welds that are inaccessible for trT inspections?

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

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

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

Ites 5. Imakene Detection Generic Intter 88-01 states on page 3:

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

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ATTACitENT A (continued) l Specification related to leakage detection will be in conformance with the staff position on leak detection included in this letter." ];

i The staff position is outlined on pages 5 and 6 of Generic Intter 88-01 and include the following items {

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1. Leakage detection should be in conformance with Position C J 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 systea indicates an increase of unidentified leakage in excess { i of 2 sps or its equivalent, or (b) the total unidentified leakage attains a rate of 5 spa or equivalent.

3. Imakage 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 leskage 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 throughws11 crack.

5. For plants operating with any ICSCC 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 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

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'h 4 Table 4 l Licensee Poiitions on Imakage Detection 1

Already TS will be Alternate Contained Changed Position l 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 i 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) leakage into the containment atmosphere from sources that are located, do not interfere with monitoring systema, 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: '

Pisce "I" or "yes" under appropriate column for each ites. Provide description and justification for alternative positions if not already provided.

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