ML20245D308

Forwards Request for Addl Info to Continue Review of Response to Generic Ltr 88-01, IGSCC Problems in BWR Austenitic Stainless Steel Piping. Response Should Also Be Submitted to Viking Sys Intl at Listed Address

ML20245D308
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/19/1989
From:	Brown S Office of Nuclear Reactor Regulation
To:	Leonard J LONG ISLAND LIGHTING CO.
References
GL-88-01, GL-88-1, TAC-M69157, NUDOCS 8906270054
Download: ML20245D308 (14)

Text

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June 19, 1989:

O O.

Docket No. 50-322 y DIS"RIBUTION w/ enclosure: ,

idDocket111egf SBrown l Mr. . Johh D. Leonard, Jr. NRC PDR & Local-PDR' -CShiraki Vice President-Nuclear Operation PDI-2 Reading . 0GC Long Island Lighting Company SVarga EJordan Shoreham Nuclear Power Station ~BBoger BGrimes P.O. Box 618, North Country Road WButler ACRS (10)

Wading River, NY 11792 'M0'Brien CCheng, DEST ASmith

SUBJECT:

INTERGRANULAR STRESS CORROSION CRACKING (IGSCC) PROBLEMS'IN BWR AUSTENITIC STAINLESS STEEL PIPING (TAC NO. M69157) j RE: SHOREHAM NUCLEAR POWER STATION' 'I The NRC is evaluating LILCo's response to Generic Letter 88-01. Enclosed arei questions that address additional information that is required to complete the review. .A formal response is requested to these questions within sixty dyas of receipt of this request. To expedite the review process, please include in the-distribution of your response, a copy. to the NRC's contractor at the following address:

Dr. Armand A. Lakner, Director Safety & Reliability Viking Systems International 101 Chestnut Street Gaithersburg, MD 20877 Sincerely,

./s/

Stewart W. Brown, Project Manager' Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear' Reactor Regulation t

Enclosure:

As-stated cc w/ enclosure:

See next page-

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Docket No. 50-322 I Mr. John D. Leonard, Jr. 4 Vice President-Nuclear Operation Long Island Lighting Company Shoreham fluclear Power Station 1 P.O. Box 618, North Country Road  ;

Wading River, NY 11792  ;

Dear Mr. Leonard:

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SUBJECT:

INTERGRANULAR STRESS CORROSION CRACKING (IGSCC) PROBLEMS IN BWR AUSTENITIC STAINLESS STEEL PIPING (TAC NO. M69157)

RE: SH0REHAM NUCLEAR POWER STATION j The NRC is evaluating LILCo's response to Generic Letter 88-01. Enclosed are questions that address additional information that is required to complete the ,

review. A formal response is requested to these questicns within sixty days of I receipt of this request. To expedite the review process, please include in the '

distribution of your response, a copy to the NRC's contractor at the following address:

3 Dr. Armand A. Lakner, Director Safety & Reliability Viking Systems International 101 Chestnut Street Gaithersburg, MD 20877 Sincerely, h Mw Stewart W. Brown, Project Manager Project Directorate I-2 Division of Reactor Projects I/II-Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure:

See next page

i O O Mr. John D. Leonard, Jr. Shoreham Nuclear Powtr Station Long Island Lighting Company 1

CC:

Victor A. Staffieri, Esq. Supervisor 4 General Counsel Town of Brookhaven Long Island Lighting Company 205 S. Ocean Ave.

175 East Old County Road Patchogue, New York 11772 Hicksville, New York 11801 l Town Attorney l W. Taylor Reveley, III, Esq. Town of Brookhaven Hunton & Williams 3232, Route 112 )

1 Post Office Box.1535 Medford, NY 11763 I 707 East Main Street  !

Richmond, Virginia 23212 MHB Technical Associates 1723 Hamilton Avenue Mr. Lawrence Britt Suite K i' Shoreham Nuclear Power Station San Jose, California 95125 Post Office Box 618 Wading River, New York 11792 Richard M. Kessel Chairman & Executive Director -

Mr. John Scalice New York State Consumer Protection Plant Manager Board i Shoreham Nuclear Power Station Room 1725 Post Office Box 628 250 Broadway I Wading River, New York 11792 New York, NY 10007 .

Resident Inspector Jonathan D. Feinberg, Esq. i Shoreham NPS New York State Department }

U.S. Nuclear Regulatory Comission of Public Service Post Office Box B Three Empire State Plaza Rocky Point, New York 11778 Albany, New York 12223 Regional Administrator, Region I Gerald C. Crotty, Esq.

U.S. Nuclear Regulatory Commission Ben Wiles, Esq.

475 Allendale Road Counsel to the Governor-King of Prussia, Pennsylvania 19406 Executive Chamber  ;

State Capitol .;

Ms. Donna Ross Albany, New York 12224 New York State Energy Office Agency Building 2 Herbert H. Brown, Esq.

Empire State Plaza Lawrence Coe Lanpher, Esq.

Albany, New York 12223 Karla J. Letsche, Esq.

! Kirkpatrick & Lockhart  ;

l. South Lobby - 9th Floor l 1800 M Street, N.W.

Washington, D.C. 20036-5891 ,

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o o 1 Long Island Lighting Company Shoreham(1) i

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cc: )

Dr. Monroe Schneider I North Shore Committee Post Office Box 231 )

Wading River, NY 11792 i Fabian G. Palomino, Esq.

Special Counsel to the Governor l Executive Chamber - State Capitol' j Albany, NY 12224 I Martin Bradley Ashare, Esq. i

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Suffolk County Attorney H. Lee Dennison Building Veteran's Memorial Highway l J

Hauppauge NY 11788 i Robert Abrams, Esq.

Attorney General of the State l of New York I ATTN:- John Corwin, Esq.

New York State Department of Law Consumer Protection Bureau 3 120 Broadway j 3rd Floor New York, NY 10271 ]

Honorable Peter Cohalan i Suffolk County Executive l County Executive / Legislative Building i Veteran's Memorial Highway l Hauppauge, NY 11788 l

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O O ATTACHMENT A )

GENERAL QUESTIONS / REQUESTS j 1

i 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 submittale. Thus, this general list of questions and l requests has been prepared for submission to each of the licensees. For i those portions of this attachment 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 1 certify that you comply with NRC Staff positions in Generic Letter 88-01, '

or identify and justify any deviations taken.

1 Item 1. Position or. NRC Staff Positions l Generic I4tter 88-01 states on page 3:

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" Pursuant to 10 CFR 50.54(f), you, as a BWR operating reactor  !

licensee or construction permit holder, are requested to furnish, i 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 j measures." j

'Ihe staff positions outid.ned in Generic Letter 88-01 includ,e positions on: (1) Materials. (2) Processes. (3) Water Chemistry. (4) Weld j Overlay. (5) Partial Replacement. (6) Stress Improvement of Cracked i Weldments. (7) Clamping Dev;tces. (8) Crack Evaluation and Repair  !

Criteria. (9) Inspection Method and Personnel. (10) Inspection 1 Schedules. (11) Sample Expansion. (12) Leak Detection.- (13)

Reporting Requirements.

Please supply information concerning whether the licensees (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.

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Please supply this information using a table such as that illustrated in the example shown in Table 1.

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Table 1 Responses to NRC Staff Positions l

Licensee Response

• Licensee Has/Will**

Accept Requests {

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

1. Materials

2. Processes

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3. Water Chemistry

4. Weld Overlay 1

5. Partial Replacement

{a

6. Stress Improvement of f Cracked Weldments

7. Clamping Devices

8. Crack Evaluation and I j

Repair Criteria 1 l

9. Inspection Method and Personnel

10. Inspection Schedules

11. Sample Expansion

12. Leak Detection

13. Reporting Requirements Answer with "yes", " check mark" or "X" 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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O O ATTACHMENT A (continued)

Item 2. Inservice Inspection Pronram 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 IGSOC 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."

The 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 IGSOC 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 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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. Table 2 ,

History of Welds and Prior Mitigating Actions / Treatments

• I Material **

IGSCC Weld Dia. Casting Treatment *** j Caten System Number Configuration Inch Foraina. Pipe Weld SHT HWS CRC jg[ 0.L. i

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Notes:

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

• • For materfs1: identify as non-conforming or conforming as appropriate concerning whether it conforms with the NRC Staff 1 position on resistant materials. If conforming, identify the f material type (e.g., Type 316 NG). j 1

• • • For treatment: list "X" 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 l years of service date. Also add explanation and justification i of any overlays that were not standard (per NRC Staff position). 1 l

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. Table 3 )

Inspection Schedules Inspected /To Be Inspected / Flaws Found ICSCC Weld Dia. Past Future Caten System No. Inch. Configuration R.O.dX-2 R.O.fX-1 Flaw R.O.fX R.O.fX+1

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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 l qualified under NRC/EPRI/BWROG coordination plan as i upgraded in September,1985. j 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 b tter 88-01,

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

3. List each weld within the scope of Generic Letter 88-01.

4. Place an "X" 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 (altial or circumferential), the dimensions (maximum length and depth), and describing any repairs made.

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O- O ATTACHMENT A (continued)

Ites 3. Welds covered in Licensee Submittal Generic Intter 88-01 (on page 2) states:

"This Generic 14tter applies to all BWR piping ande of sustenitic 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 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 excluded, pleaue list identity of such welds and plans for mitigation and inspections in Tables 2 and 3 or provide alternative proposal. If ICSCC 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.

Ites 4. Welds that Are Not UT Inspectable Generic Letter 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 fort (a) All welds that are inaccessible for ITT ir.spections?

(b) All welds that are only partis 11y accessible for Iff inspections?

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

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

Item 5. Leakene Detection Generic I4tter 88-01 states on page 3: .

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

O O ATtACIMENT A (continued)

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

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The staff position is outlined on pages 5 and 6 of Generic Letter i 88-01 and include the followiag items:

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

3. Leakage should be monitored (or determined from flow measurements if flow is continuously monitored) at approximately f four hour intervals or less. ,

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4. Unidentified leakage should ir.clude all leakage other than i (a) leakage into closed systems, or l j

i (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 /> i or immediately initiate an orderly shutdown.

Although most licensee submittels 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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Table 4 Licensee Positions on Leakage Detection i 1

Already TS will be Alternate Contained Changed Position i Position in TS to Include Proposed l 1

1. Conforms with Position C of a Regulatory Guide 1.45 1

2. Plant shutdown should be I 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 /> l or less, an increase is 1 indicated in the rate of  !

unidentified leakage in excess of 2 gpm, or ,

(b) the total unidentified leakage attains a rate of 5 sps.

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 i with monitoring systems, or not from throughwall crack.

5. Provisions for shutdown within 24  ;

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

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. ATTACSGDIT B REQUEST FOR ADDITIONAL INFORMATION PERTAINING 10 SHOREHAM, UNIT 1 Ites 1. Inservice Inspection and Mitimatian Treatments In responding to Item 2 of Attachment A:

I (a) Please note that the tables listing of~ welds in the IGSOC ,,

ISI plan which were previously submitted do not contain=

piping or weld compositions. Please include these.in your reply.

(b) Please supply justification for the IGSCC Category B classifiestions applied to welds that were treated with IHSI in terms of the dates of application of the IHSI treatmente (recalling that the treatements must be applied within two years of operation to be classisifed as IGSCC Category B) and the limited number (17) of post-IHSI inspections (recalling that all IHSI-treated welds must -

be inspected to be classified as IGSCC Category B unless

~ the treatments were applied prior to operation).

l (c) Please note that specific refueling outages when welds are to be inspected were not included in the submittal. Nor were plans included for IGSCC Category B welds after the first refueling outage.

(d) Please justify the "not applicable" assignments to welds containing Inconel, noting that all Inconal alloys are I specifically covered in Generic Intter 88-01 and that only - '

Inconel 82 is considered resistant. Also please include I

page B - 1 i i

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O O ATTAC} MENT B (continued) i inspection plans for these welds.

Item 2. Uninspectable Welds In responding to Item 4 of Attachment A, recall that expected UT i inspectability of several welds was less than 100%. In particular expected per cent ITT coverage for some of the welds was about 65%

of less. Please list plans, other that UT inspection of these welds or provide justification for limiting the inspections to UT.

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