ML20197K193

Forwards RAI Re Utilities Participation in WOG Response to GL 97-01, Degradation of Crdm/Cedm Nozzle & Other Vessel Closure Head Penetrations. Response Requested within 90 Days of Submittal Date

ML20197K193
Person / Time
Site:	Seabrook
Issue date:	12/09/1998
From:	Harrison J NRC (Affiliation Not Assigned)
To:	Feigenbaum T, Harpster T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
References
GL-97-01, GL-97-1, TAC-MA98595, NUDOCS 9812160115
Download: ML20197K193 (8)

Text

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i p h UNITED STATES

&/($3 s* j NUCLEAR REGULATORY COMMISSION  !

WASHINGTON, D.C. 20666 4001

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• • • • • December 9, 1998 Mr. Ted C. Feigenbaum Executive Vice President and Chief Nuclear Officer North Atlantic Energy Service Corporation c/o Mr. Terry L. Harpster P.O. Box 300 Seabrook, NH 03874

SUBJECT:

GENERIC LETTER (GL) 97-01, " DEGRADATION OF CRDM/CEDM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS" RESPONSES FOR SEABROOK STATION, UNIT 1 (TAC M98595) l

Dear Mr. Feigenbaum:

On April 1,1997, the staff issued Generic Letter (GL) 97-01, " Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their respective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information requests. In the discussion section of the GL, the staff stated that " individual licensees may wish to determine their inspection activities based on an integrated industry inspection program. . .," and indicated that it did not object to individual PWR licensees basing - I their inspection activities on an integrated industry inspection program.

As a result, the Westinghouse Owners Group (WOG) determined that it was appropriate for its -

members to develop a cooperative integrated inspection program in response to GL 97-01. f The WOG program is documented in two Topical Reports issued by the Westinghouse Electric l Corporation (WEC), WCAP-14901, Revision 0, " Background and Methodology for Evaluation l of Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group,"

and WCAP-14902, Revision 0, " Background Material for Response to NRC Generic Letter 97-01: Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group."  !

The WOG submitted the integrated programs described in WCAP-14901 and WCAP-14902 to the staff on July 25,1997.

The staff has determined by your letter dated July 30,1997, that you were a member of the WOG and a participant in the WOG integrated program that was developed to address the staff's requests in GL 97-01. In your letter dated July 30,1997, you also indicated that the ,

information in WEC Topical Report WCAP-14901 is applicable with respect to the assessmeni

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of VHP nozzles at Seabrook.

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T. Feigenbaum December 9,1998 The staff has reviewed your responses to GL 97-01, dated May 1,1997, and July 30,1997, and requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG member plants, and to the contents of Topical Report No. WCAP-14901. The enclosure to this letter forwards staff's inquiries in the form of a request for additional information (RAI).

The staff requests a response to the RAI within 90 days of the submittal date. It should be i noted that similar staff requests have been issued to other WOG member utilities. As was the staff's position before, the staff encourages you to addres.= these inquiries in integrated fashion l with the WOG and the Nuclear Energy Institute (NEI); .iowever, the staff also requests that you

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identify any deviations from the WOG's integrated program that may be specific to your j facilities. The staff appreciates the efforts expended with respect to this matter. j Sincerely, Original signed by John Harrison, Project Manager l Project Directorate 1-3 l Division of Reactor Projects - l/II Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION:

"t. Docket Filea C. Cowgill J. Harrison EMCB

'PUBLIC" OGC T. Clark J. Harold ,

Seabrook r/f ACRS J. Zwolinski  !

DOCUMENT NAME: G:\ Harrison \M98595.RAI

'T3 receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure " N" = No copy OFFICE PDI-3/FM l PDI-3/LA , M lt l PDI-//D / f A/ ) l NAME JHarrison M TClark (. jf\ U CTfom// /

DATE Q/ 4 /98 /d/ 4 /98 / /98 W 47 /98 OFFICIAL RECORD COPY

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T. Feigenbaum The staff has reviewed your responses to GL 97-01, dated May 1,1997, and July 30,1997, and requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG member plants, and to the contents of Topical Report No. WCAP-14901. The enclosure to this letter forwards staff's inquiries in the form of a request for additionalinformation (RAl).

The staff requests a response to the RAI within 90 days of the submittat date. It should be noted that similar staff requests have been issued to other WOG member utilities. As was the

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l staff's position before, the staff encourages you to address these inquiries in integrated fashion with the WOG and the Nuclear Energy Institute (NEI); however, the staff also requests that you identify any deviations from the WOG's integrated program that may be specific to your facilities. The staff appreciates the efforts expended with respect to this matter.

l Sincerely, 8A John Harrison, Project Manager Project Directorate I-3 Division of Reactor Projects - l/II Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosure:

Request fcr Additional Information cc w/ encl: See next page

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,-. 3-T. Feigenbaum North Atlantic Energy Sen.' ice Corporation Seabrook Station, Unit No.1 cc:

Lillian M. Cuoco, Esq. Mr. Peter LaPorte, Director Senior Nuclear Counsel ATTN: James Muckerheide Northeast Utilities Service Company Massachusetts Emergency Management P.O. Box 270 Agency Hartford, CT 06141-0270 400 Worcester Road P.O. Box 1496 Mr. Peter Brann Framingham, MA 01701-0317 Assistant Attorney General State House, Station #6 Jeffrey Howard, Attorney General Augusta, ME 04333 G. Dana Bisbee, Deputy Attorney General Resident inspector 33 Capitol Street U.S. Nuclear Regulatory Commission Concord, NH 03301 Seabrook Nuclear Power Station P.O. Box 1149 Mr. Woodbury Fogg, Director Seabrook, NH 03874 New Hampshire Office of Emergency Management Jane Spector State Office Park South Federal Energy Regulatory Commission 107 Pleasant Street 825 North Capital Street, N.E. Concord, NH 03301 Room 8105 Washington, DC 20426 Mr. Roy E. Hickok Nuclear Training Manager Town of Exeter Seabrook Station 10 Front Street North Atlantic Energy Service Corp.

Exeter, NH 03823 P.O. Box 300 Seabrook, NH 03874 Regional Administrator, Region i U.S. Nuclear Regulatory Commission Mr. Terry L. Harpster 475 Allendale Road Director of Licensing Services King of Prussia, PA 19406 Seabrook Station North At. antic Energy Service Corp.

Office of the Attorney General P.O. Box 300 One Ashburton Place Seabrook, NH 03874 20th Floor Boston, MA 02108 Mr. W. A. DiProfio Station Director Board of Selectmen Seabrook Station Town of Amesbury North Atlantic Energy Service Corporation Town Hall P.O. Box 300 Amesbury, MA 01913 Seabrook, NH 03874 Mr. Dan McElhinney Federal Emergency Management Agency Region i J.W. McCormack P.O. &

Courthouse Building, Room 401 Boston, MA 02109

. - . - - - ~ = - _ , - - - - - - - - - - - . - - - - - - - - - - - - - - - - - - - .

, Mr. Frank W. Getman, Jr.

' 20 International Drive Suite 301 Portsmouth, NH 03801 6809 Mr. B. D. Kenyon President - Nuclear Group Northeast Utilities Service Group P.O. Box 128 Waterford, CT 06385 Mr. David E. Carriere Director, Production Services Canal Electric Company 2421 Cranberry Highway Wareham, MA 02571

REQUEST FOR ADDITIONAL INFORMATION REGARDING UTILITIES PARTICIPATING IN THE WESTINGHOUSE OWNERS GROUP (WOG)

RESPONSE TO GENERIC LETTER (GL) 97-01

" BACKGROUND AND METHODOLOGY FOR EVALUATION )

OF REACTOR VESSEL CLOSURE HEAD PENETRATION INTEGRITY FOR THE WESTINGHOUSE OWNERS GROUP" TOPICAL REPORT NO. WCAP-14901. REVISION 0 i APPLICABILITY OF TOPICAL REPORT NO. WCAP-14901. REVISION 0.  !

TO THE PLANT-SPECIFIC RESPONSES TO GL 97-01 FOR PARTICIPATING l MEMBER UTILITIES AND PLANTS IN THE WOG l Relationshio and Acolicability of WCAP-14901. Revision O. to GL 97-01 and the WOG On April 1,1997, the staff issued Generic Letter (GL) 97-01, ' Degradation of CRDM/CEDM Nozzle and Other Vessel Closure Head Penetrations," to the industry requesting in part that addressees provide a description of the plans to inspect the vessel head penetration nozzles (VHPs) at their re'spective pressurized water reactor (PWR) designed plants. With respect to the issuance of the GL, the staff required the addressees to submit an initial response within 30 days of issuance informing the staff of the intent to comply with requested information and a follow-up response within 120 days of issuance containing the technical details to the staff's information requests. In the discussion section of the GL, the staff stated that " individual licensees may wish to determine their inspection activities based on an integrated industry inspection program. . .," and indicated that it did not object to individual PWR licensees basing their inspection activities on an integrated industry inspection program.

As a result, the WOG determined that it was appropriate for its members to develop a cooperative integrated inspection program in response to GL 97-01. The WOG program is documented in two Topical Reports issued by the Westinghouse Electric Corporation (WEC),

WCAP-14901, Revision 0, ' Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group," and WCAP-14902, Revision 0, ' Background Material for Response to NRC Generic Letter 97-01: Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group."

The technical content provided in WCAP-14901, Revision 0, is basically the same as that provided in WCAP-14902. The difference with regard to the reports is that WOG member plants subscribing to the content of WCAP-14901 have opted to rank the susceptibility of their vessel head penetrations according to a probabilistic Weibull analysis method that was developed by WEC. In contrast, the WOG member plants subscribing to the content of WCAP-14902, Revision 0, have opted to rank the vessel head penetrations for their facilities according to a probabilistic methodology that was developed by another vendor of choice. The staff has determined by your letter dated July 30,1997, that you were a member of the WOG and a participant in the WOG integrated program that was developed to address the staff's requests in GL 97-01. In your letter dated July 30,1997, you also indicated that the information in WEC Topical Report WCAP-14901 is applicable with respect to the assessment of VHP nozzles at Seabrook.

Enclosure

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0 The staff has reviewed your responses to GL 97-01. dated May 1,1997, and July 30,1997, and requires further information to complete its review of your responses as they relate to the WOG's integrated program for assessing VHP nozzles at WOG member plants, and to the contents of Topical Report No. WCAP-14901. The staff requests the following information with respect to the content of your responses to GL 97-01, dated May 1,1997, and July 30, 1997, and to the content of WCAP-14901 as it relates to these responses:

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1. In WCAP-14901 WEC did not provide any conclusions as to what the probabilistic failure model would lead the WOG to conclude with respect to the assessment of primary water stress-corrosion cracking (PWSCC) in WEC-designed vessel head penetrations. With respect to the probabilistic j susceptibility model (e.g., probabilistic failure model) provided in WCAP-14901:

a. Provide the susceptibility rankings compiled for the WOG member plants for which WCAP-14901 is applicable, in regard to other WOG member 1 plants to which WCAP-14901 is applicable, include the basis for establishing the ranking of your plant relative to the others. i

b. Describe how the probabilistic failure model in WCAP-14901 for assessing postulated flaws in vessel head penetration nozzles was bench-marked, and provided a list and discussion of the standards the model was bench-marked against.

c. Provide additionalinformation regarding how the probabilistic failure models in WCAP-14901 will be refined to allow the input of plant--specific inspection data into the model's analysis methodology.

d. Describe how the variability in product forms, material specifications, and heat treatments used to fabricate each CRDM penetration nozzle at the WOG member utilities are addressed in the probabilistic crack initiation and growth models described or referenced in Topical Report No.

WCAP-14901,

2. Table 1-2 in WCAP-14901 provides a summary of the key tasks in WEC's vessel head penetration nozzle assessment program. The table indicates that the Tasks for (1) Evaluation of PWSCC Mitigation Methods, (2) Crack Growth Data and Testing, and (3) Crack initiation Characterization Studies have not been completed and are still in progress. In light of the fact that the probabilistic susceptibility models appear to be dependent in part on PWSCC crack initiation and growth estimates, provide your best estimate of when these tasks will be completed by WEC, and describe how these activities relate to and will be used to update the probabilistic susceptibility assessment of VHP nozzles at your plant.

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, 3. In the NEl letters of January 29,1998, (Ref.1), and April 1,1998, (Ref. 2), NEl indicated that inspection plans have been developed for the VHP nozzles at the Farley Unit 2 plant in the year 2002, and the Diablo Canyon Unit 2 plant in the year 2001, respectively. The staff has noted that although you have endorsed the probabilistic susceptibility model described in WCAP-14901, Revision 0, other WOG member licensees have endorsed a probabilistic susceptibility model developed by an attemate vendor of choice. The WOG's proposal to inspect the VHP nozzles at the Farley Unit 2 and Diablo Canyon Unit 2 plants appears to be based on a composite assessment of the VHP nozzles at all WOG member plants. Verify that such a composite ranking assessment has been applied to the evaluation of VHP nozzles at your plant. If composite rankings of the VHP nozzles at WOG member plants have been obtained from the composite results of the two models, justify why application of the probabilistic susceptibility model described in WCAP-14901, Revision 0, would yield the same comparable relative rankings of the VHP nozzles for your plant as would application of the alternate probabilistic susceptibility model used by the WOG member plants not subscribing to WCAP-14901, Revision 0.

Comment on the susceptibility rankings of the VHP nozzles at your plant relative to the susceptibility rankings of the VHP nozzles at the Farley Unit 2 and Diablo Canyon Unit 2 plants.

REFERENCES

1. January 19,1998 - Letter from David J. Modeen, Director of Engineering, Nuclear Generation Division, Nuclear Energy institute, to Mr. G. C. Lainas, Acting Director, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (Untitled).

2. April 1,1995 - Letter from David J. Modeen, Director of Engineering, Nuclear Generation Division, Nucisar Energy Institute, to Mr. G. C. Lainas, Acting Director, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, "

SUBJECT:

Generic Letter 97-01, ' Degradation of Control Rod Drive Mechanism Nozzle and Other Vessel Head Penetrations.' '

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