ML20245B995

Forwards Request for Addl Info Re 880725 Response to Generic Ltr 88-01.Response Requested within 60 Days of Ltr Date

ML20245B995
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	04/18/1989
From:	Pulsifer R Office of Nuclear Reactor Regulation
To:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
GL-88-01, GL-88-1, TAC-69127, NUDOCS 8904260427
Download: ML20245B995 (13)

Text

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April 18e 1989 a

Mr. Kenneth W. Berry Director, Nuclear Licensing Consumers Power Company 1945 West Parnell Road Jackson, Michigan. 49201

SUBJECT:

BIG ROCK P0 INT PLANT RESPONSE ON GENERIC LETTER 88-01 (TAC 69127)

The Materials Engineering Branch, Division of Engineering and Systems Technology, with assistance from its contractor, Viking Systems International (VSI) is reviewing and evaluating your submittal dated July 25, 1988 in response to Generic Letter 88-01 for Big Rock Plant. Additional information is required in order for the staff to complete the review.

Please respond to this request within 60 days of receipt of this RAI. To help expedite the review process please send a copy of your response to our contractor at the following address:

Dr. Armand A. Lakner Director, Safety and Reliability Viking Systems International 101 Chestnut Street Gaithersburg, Maryland 20877 Sincerely, CMntf tig??Obl Robert M. Pulsifer, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V t

& Special Projects l

Enclosure:

Attachment A cc: See next page DISTRIBUTION.

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f April 18, 1989 l l

Mr. Kenneth W. Berry Director, Nuclear Licensing Consu;ners Power Company 1945 West Parnell Road Jackson, Michigan 49201

SUBJECT:

BIG ROCK POINT PLANT RESPONSE ON I GENERIC LETTER 88-01 (TAC 69127)

The Materials Engineering Branch, Division of Engineering and Systems j Technology, with assistance from its contractor, Viking Systems International j (VSI) is reviewing and evaluating your submittal dated July 25, 1988 in response '

to Generic Letter 88-01 for Big Rock Plant. Additional information is required in order for the staff to complete the review.

Please respond to this request within 60 days of receipt of this RAI. To help expedite the review process please send a copy of your response to our contractor at the following address:

Dr. Annand A. Lakner Director, Safety and Reliability Viking Systems International 101 Chestnut Street Gaithersburg, Maryland 20877 Sincerely,

~Cthhi#t# S/

Robert M. Pulsifer, Project Manager Project Directorate 111-1 Division of Reactor Projects - III, IV, V

& Special Projects

Enclosure:

Attachment A cc: See next page DISTRIBUTION Central File NRC PDR Local PDR DRSP R/F RPulsifer PShuttleworth i

11h k PM:PD3-1:DRSP ( PD3-1:DRSP Nnn/ mIB LA:PD31:DRSP PShuttleworth g( RPulsiferg'O CCheng 4/3 /89 a/J /89 /89 4/(1/89

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UNITED STATES

[(p i NUCLEAR REGULATORY COMMISSION 5 WASHINGTON, D. C. 20656 l

% ,/ April 18, 1989

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Mr. Kenneth W. Berry Director, Nuclear Licensing '

Consumers Power Company 1945 West Parnell Road Jackson, Michigan 49201

SUBJECT:

BIG ROCK POINT PLANT RESPONSE ON GENERIC LETTER 88-01 (TAC 69127)

The Materials Engineering Branch, Division of Engineering and Systems Technology, with assistance from its contractor, Viking Systems International (VSI) is reviewing and evaluating your submittal dated July 25, 1988 in response to Generic Letter 88-01 for Big Rock Plant. Additional information is reouired in order for the staff to complete the review.

Please respond to this reouest within 60 days of receipt of this RAI. To help expedite the review process please send a copy of your response to our contractor at the following address:

Dr. Amand A. Lakner Director, Safety and Reliability Viking Systems International 101 Chestnut Street Gaithersburg, Maryland 20877 Sincerely,

, / . f/? l

" Ro et .'Pulsjfer, Project Manager Project Directorate 111-1 Division of Reactor Projects - III, IV, V

& Special Projects

Enclosure:

Attachment A cc: See next page

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' Mr. Kenneth W. - Berry o  : Consumers Power Company Big Rock Point Plant CC:

L-Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan .49201 Mr. Thomas W. E1 ward Plant Manager Big Rock Point Plant 10269 U.S. 31 North Charlevoix, Michigan 49720 Mr.' Bud Heeres County Commissioner 303 Sheridan Charlevoix, Michigan 49720'

, 0ffice of the Governor Room 1_- Capitol Building Lansing, Michigan- 48913 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn,.Illinnis 60137 Nuclear Facilities and Environmental Monitoring Sectinn Office Division of Radiological Health P. O. Box 30035 Lansing, Michigan 48909 U.S. Nuclear Regulatory Commission Resident Insnector Office Big Rock Point Plant 10253 U.S.'31 North Charlevoix, Michigan 49720

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 attachment for which the requested information was supplied in (portions the detailof this 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.

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. (7)ClampingDevices. (8) Crack Evaluation and Repair Criteria. (9)InspectionMethodandPersonnel. (10) Inspection Schedules. (11) Sample Expansion. (12) Leak Detection. (13)

Reporting Requirements.

Please supply information concerning whether the licensee: (1) j 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, j l Please supply this information using a table such as the illustrated j in the example shown in Table 1.

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I Table 1 Respenses to NRC Staff Positions Licensee Response

• Licensee Has/Will**

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

1. Materials I i

2. Processes ]

3. Water Chemistry

4. Weld Overlay

3. 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

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 needed.

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

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. i ATTACHMFET A (continued)

Item 2. Inservice Inspection Pronras, Generic Intter 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."

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

positions on inspection schedules methods and personnel, and I sample expansion included in this letter."

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The information pertaining to the pipe replacement and other j mitigating actions as well as the Inservice Inspection Program s provided in most of the licensee submittals were either incomplete or did not provide the background data that is needed to evaluate l the ISI Program such as (1) reasons / justification for IGSCC ]

classification of welds, (2) methods, personnel qualification, 1 schedules and identities of welds inspected, and (3) resulta of {

previous inspections, and/or identities of welds to be inspected j during future inspections. j 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 ICSCC classification (i.e., ICSCC 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 (axial or circumferential), maximum 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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f Table 2 History of Welds and Prior Mitigating Actions / Treatments * ,

Material ** 1 IGSCC Weld .

Dia. Casting ' Treatment ***

9t.eg Systes Number Configuration Inch Formina. Pipe Weld SHT JWJ.E gg g 0.L7

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Notes: )

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

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• • For materials 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 f 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 /F1sws Found_

ICSCC Wald Dia. *as t Future h Sratem No. Jnch. Configuration R.O.fX-2 t.0.fX-1 h R.O.fX R.O.fX+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 Latter 8841.

2. Replace R.O.i (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 Intter 8841.

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 " yea" under column marked " flaw" if a fisw indication was found. Attach a statement for each flawed weld giving the orientation (axial or circumferential), the dimensions (maximus length and depth), and describing any repairs made.

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• i ATTAQMENT A (continued)

Ites 3. Welds Covered in Licensee Submittal f

Generic Intter 88-01 (on page 2) states:

"This Generic !atter applies to all BWR piping made of austenitic stainless steel that is four inches or larger in nominal diameter and contains rasctor coolant at a tempos *ture above 200*F during power operation regardless of Code classification. It also applies to reactor vessel attachments and appurtenances auch as jet pump instrumentation penetration assemblies and head spray and went components."

I 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 i 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. 1 Item 4. Welds that Are'Not UT Inspectable Generic !stter 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 Eff inspections?

(b) All welds that are only partially accessible 'or ITT 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. l Item 5. tankene Detection Generic Intter 88-01 states on page 3:

" Confirmation of you plans to ensure that the Technical

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ATTACHNDIT A (continued)

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

The staff position is outlined on pages 5 and 6 of Generic latter 88-01 and include the following items:

1. leakage detection should be in conformance with Position C of Regulatory Guide I A5 " Reactor Coolant Pressure Boundary Leakage Detection Systems," or as otherwise approved by the NRC.

2. Plant shutdown should be initiated for corrective action whens (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 l of 2 spe 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 tise 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 l information should be provided by each licensee. For clarity and I completeness, please use a checklist such as that illustrated in )

Table 4 '

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Table 4 Licensee Positions on Leakage Detection i

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

3. Leakage monitored at four hour intervals or lains.

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 yith 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 velds. - i Instructions:

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

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ATTACHMENT B REQUEST WR ADDITIONAL INEDRMATION PERTAINING 10 BIG ROCK POINT PLANT Item 1. Inservice Inspection Program In responding to Item 2 of Attachment A (concerning inservice inspection), please note that a repetition of the reference to the November 13, 1987 Inservice Inspection Program which was given in the original submittal will not satisfy this request for information.

Item 2. plans for Inaccessible Welds In responding to Item 4 of Attachment A (concerning welds that are not UT inspectable) please also supply the following information:

pertaining to inaccessible welds:

(a) Descriptions of plans to ensure that welds that are accessible only from the reactor vessel interior will not develop IGSCC during the 10 year ISI cycle since inspections are planned only at the end of that cycle.

Item 3. Leakene Detection In responding to Item 5 of* Attachment A (concerning leakage detection), please note that a repetition of the reference to the NUREG-0828, " Integrated Plant Safety Assessment", Section 4.16. Topic V-5, dated may,1984 which was referenced in the original submittal vill not satisfy this request for information.

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