NG-88-3593, Requests Approval to Defer Insp of Piping Susceptible to IGSCC Until Cycle 10/11 Due to Welds in RWCU Not Previously Examined,Per Generic Ltr 88-01

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Requests Approval to Defer Insp of Piping Susceptible to IGSCC Until Cycle 10/11 Due to Welds in RWCU Not Previously Examined,Per Generic Ltr 88-01
ML20195B982
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 10/21/1988
From: Rothert W
IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To: Murley T
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
References
GL-88-01, GL-88-1, NG-88-3593, NUDOCS 8811020280
Download: ML20195B982 (2)


Text

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i Iowa Electric Light and Power Company l October 21, 1988 l

NG-88-3593 l

l Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn: Do'cument Control Desk Mail Station P1-137 Washington, D.C. 20555 Sohjoct: Duane Arnold Energy Center Docket No: 50-331 Op. License DPR-49 NRC Generic Letter 88-01 Inspection Schedule Guidelines

Reference:

Letter from W. Rothert (Iowa Electric) to T. Murley (NRC) dated July 27, 1988 (NG-88-0973)

File: A-107, A-286a, B-31c, SpF-118

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Dear Or. Murley:

In the referenced letter, we submitted our' plans'for inspection of piping susceptible to Intergranular Stress Corrosion Cracking (IGSCC) at the Duane Arnold Energy Center (DAEC). A subsequent review of these inspection plans identified additional welds which must be included in our inspection program to meet the guidelines set forth in NRC Generic letter 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping."

The additional welds are located in the isolable, non-safety-related portion of the Reactor Water Cleanup (RWCU) system and have not been previously examined in accordance with the guidelines set forth in Generic letter 88-01.

Eighty-two of these welds art of IGSCC Cetagory G and ten are of IGSCC Catagnry A. Per Generic Letter 88-01, all of these welds should be inspected during our current (Cycle 9/10) refueling outage. Due to the discovery of these additional welds just prior to beginning our current refueling outage, we request to defer inspection of these welds until the Cycle 10/11 refueling outage because of significant difficulties associated with planning and performing the inspections. This matter was discussed with members of your staff in a telephone conversation held on October 4, 1988.

We estimate that the n3cessary planning, weld preparation, labor support (i.e., scaffolding and insulation installation and removal) and actual weld inspections would require approximately 5,000 man-hours to complete. The addit unal inspections would result in an estimated 120 man-rem of exposure to personnel at the DAEC. If all welds were inspected this outage, the additional inspections would extend the current refueling outage an estimated 6 weeks and the associated exposure would cause the outage exposure budget to be exceeded by approximately 27%.

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Dr. Thomas E. Murley October 21, 1988 Page Two By deferring these inspections until the Cycle 10/11 refueling outage, we would have sufficient time to adequately plan and support the inspections while keeping exposures as low as reasonably achievable (ALARA). Items such as procurement and use of readily removable insulation and the use of temporary shielding could be considered as means to minimize long-term as well as short-term personnel exposures. We estimate that, given the additional time to prepare to perform the inspections, we could reduce the exposure by 40 man-rem (33Y,) during not only the initial inspections, but also for the recurring inspections required by Generic letter 88-01.

As a means of further reducing long-term personnel exposures and costs associated with these inspections, we are considering replacement of the RWCU piping with IGSCC resistant material. Should we decide to pursue this alternative, we will inform you via an Integrated Plan update prior to the next refueling outage.

Should you have any additional questions or concerns regarding this submittal, please contact this office.

Very truly yours,

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.g William C. Ro Manager, Nuclear Division NKP/WCR/go ca: N. Peterson R. McGaughy L. Root L. Liu J. R. Hall (NRC-NRR)

A Bert Davis (NRC-RIII)

, NRC Resident Office Commitment Control No. 880033, 880284 I

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