ML17309A619
| ML17309A619 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/25/1997 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17264A963 | List: |
| References | |
| GL-97-01, GL-97-1, NUDOCS 9707310152 | |
| Download: ML17309A619 (43) | |
Text
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SUBJECT:
Forwards 120-day response to GL 97-01.
DISTRIBUTION CODE:
A075D COPIES RECEIVED:LTR i ENCL
~
SIZE:(P TITLE: GL-97-0'egraduation-of Control Rod Drive Mechanism
& Other j
NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
CATEGORY 1 REGULATOlINFORMATION DISTRIBUTION TEM (RIDE)
ACCESSION NBR:9707310152 DOC.DATE: 9"1/07/25 NOTARIZED: YES FAC L:50-244 Robert Emmet Gi.nna Nuclear Plant, Unit 1, Rochester G
AU.H.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas a Electric Corp.
RECAP.NAME RECIPIENT AFFILIATION VISSjNG,G.S.
DOCKET 05000244 C
Vessel A
05000244 T
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE I CONTACT THE DOCUMENT CONTROL DESKI ROOM OWFN 5D-5(EXT ~ 415-2083)
TO ELZMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED:
LTTR 11 ENCL 10
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ROCHESTER GASANDELECTR1C CORPORATION ~ 89 FASTAYENUE, ROCHESTER, N. Y Id@f9-0001 ARFA CODE716 54'6-2700 ROBERT C. MECREDY Vice President Nvcleor operations July 25, 1997 U. S. Nuclear Regulatory Commission Document Control Desk Attn:
Guy S. Vissing Project Directorate I-1 Washington, D.
C.
20555
Subject:
Rochester Gas 8 Electric Corporation's
Response
to the Generic Letter 97-01 R.
E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Vissing:
Enclosed is Rochester Gas.R Electric's 120-day response to subject Generic Letter 97-01.
RGEE has been an active participant in the efforts of NEI and others to address the Alloy 600 Primary Water Stress Corrosion Cracking (PWSCC) concern on the Control Rod Drive Mechanism(CRDM) Penetration issue since the issue developed, including being among the first to perform enhanced Generic Letter 88-05 visual inspections.
RGEE continues to support NEI, Owners Groups and others in their efforts to address the CRDM issue.
A significant amount of research and design efforts have been expended by the industry, in order to analyze PWSCC in CRDM penetrations.
These efforts resulted in the safety evaluation presented in WCAP-13565 Rev.
1, and NRC Safety Evaluation Report to NEI on Nov 19,1993, which concluded that the issue does not present an immediate safety concern, as confirmed by NUREG/CR-6245.
Additional clarification and response to NRC c(uestions resulting from the safety evaluation have been addressed in WCAP 14219 Rev.
1, RV Closure Head Penetration Supplemental Assessment of NRC SER Issues, March 1995.
These safety evaluations and WCAPs are applicable to Ginna Station and form the basis for our characterization and prioritization of this issue.
As early as
- 1993, RGEE took pro-active steps in order to develop options for the Ginna Station vessel penetrations based on the work of Dominion Engineering.
This work was updated after the pO three sample plant inspections (one of which contained the same material heat numbers as the Ginna Station vessel)were complete'd and the final report was issued in November 1995.
Based on this
- report, an options matrix was developed for Ginna.
97073iOi52 970725 PDR ADOCK 05000244 P
pon llllllllllllllllllllllllllllllllllllllll
In order to properly evaluate the potential ramifications of this issue on RGsE, we are currently in the process of preparing a
specification for solicitation of bids to perform examinations of the Ginna vessel head during the 1999 refueling outage.
A determination of whether'o, when to, and to what extent to perform inspections will be based on our review of these bids, as well as our -review of ongoing industry experience.
While approaches to predicting probabilities of occurrence may vary between analyses, RGEE believes that the one sample plant inspection which included the exact heat numbers from the Ginna
- vessel, and did not produce indications, provides the best representation for what would be expected at Ginna Station and supports the conclusion that the issue does not present an immediate safety concern.
Very Truly yours,
/kc Enclosure Robert C.
Mec edy Subscribed and sworn/affirmed before me this 25th day of July, 1997 MARIE C. VILLENEUVE Notary Public, State of New York
'onroe County Commission, Expires October 31, 19HZ Notary Public xc:
Mr. Guy S. Vissing Project Directorate I-1 U. S. Nuclear Regulatory=Commission Washington, D. C.
20555 U. S. Nuclear Regulatory Commission Region 1
475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector
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9707310152 Attachment 1:
Response
to-Requ'ested Information Items 1.1-1.4
./
Item 1.1 Description of all inspections of CRDM nozzle and other VHP's performed to date of this Generic letter, including the results of these inspections.
1.1.1 RGEE has performed visual examinations of the head area during each refueling outage since 1994, using an "Enhanced 88-05 Criteria".
The results of the visual examinations are transmitted in Enclosure 1.
1.1.2 RGB has also performed a remote underhead visual scoping inspection to determine the condition of the underside of the vessel head.
(Video, 1993) 1.1.3 ISI examination results of the attachment weld as required by section XI of ASME code are contained in Enclosure 2.
I ISI UT/PT inspection results of the bi-metallic welds of the CRDM enetration to the CRD end connection.
1.1.4 p
(Enclosure 3) 1.1.5 No replications have been performed on the Ginna.Head.
1.1.6 No volumetric inspections have been performed at Ginna Station.
- Note, however, that the Ginna Vessel penetrations contain the same heat numbers as one of previously inspected vessel
- heads, NX-4906 and NX-4909.
Item 1.2 If a plan has been developed to periodically inspect the CRDM nozzles and other VHP's.
a.
Provide the schedule for first, and subsequent, inspections of the CRDM nozzle and other VHP's, including the technical basis for this schedule.'.
Provide the scope for the CRDM nozzle and other VHP inspections, including the total number of penetrations(and how many will be inspected),
which:
penetrations have thermal sleeves, which are spares and which are instrument or other penetrations.
1.3 If a plan has not been developed to periodically inspect the CRDM nozzle and other VHP's, provide the analysis that supports why no augmented inspection is necessary.
1.4 In light of the degradation of CRDM nozzle and other VHP's described
- above, provide the analysis that supports the selected course of action as listed in either 1.2 or 1.3,,
above.
In particular, provide a description of all relevant data and/or tests used to develop crack initiation and crack growth models, the methods and data used to validate these
- models, the plant-specific inputs to these
- models, and how these models substantiate the susceptibility evaluation.
Also, if an integrated industry inspection program is being relied on, provide a detailed description of this program.
Ginna Station is a participant in the Westinghouse Owners Group RPV head penetration integrated inspection program.
This integrated program includes volumetric inspection of head penetrations that have been performed to date.
We are continuing to evaluate the results of inspections, both from WOG reactor vessels and other PWR Owners Groups
/
The need and schedule for re-inspection will be based on an evaluation of the inspection results from the Westinghouse Owners Group integrated inspection Program.
The plant performing re-inspections will keep the NRC staff informed of its future re-inspection plans.
Relevant data and or tests used to develop crack initiation and crack growth models are contained in WCAP's 14901 and 14902 submitted by the WOG.
Note that RG&E utilized the Westinghouse model as a confirmatory type analysis.
The strategic plan used-to develop the Ginna options matrix is based on the work performed in conjunction with Dominion Engineering=. Additional information on the strategic plan is contained in enclosure 4.
1 As noted in our cover letter, RGRE is also soliciting bids. for potentially performing an inspection during the 1999 Refueling Outage.
The basis for choosing this date is the Strategic
- Plan, prepared in conjunction with Dominion Engineering, which captures the results of the sample plant inspections performed through 2/13/9S.
It conservatively assumes an indication in one penetration in the sample plant which contained the same heat numbers as the Ginna vessel head CRDM material.
Note that the sample plant which inspected did not discover any indications.
Total scope of inspections, if it is decided to do so for economic reasons, will be defined by bids received.
Current options considered in the Strategic Plan indicate that, if underhead inspections are performed, the cost, differential between selected penetrations, as compared to all genetrations is not significant, but this will be further evaluated as bids become available.
Provide a description of any resin bead intrusion as described in IN 96-11, that have exceeded the current EPRI PWR Water Chemistry Guidelines recommendations for primary water sulfate levels including the following information:
2.1 2.2 2.3 2.4 2.5 Were the intrusions cation, anion or mixed bed?
What were the durations of these intrusions?
Does the plant RCS water chemistry Technical, specifications follow the EPRI guidelines?
Identify any RCS chemistry excursions, that exceed the plant administrative limits for the following species:
Identify and conductivity excursions which may be indicative of resin intrusions.
Provide technical assessment of each excursion and any follow-up actions.
Provide an assessment of the potential for any of these intrusions to result in a significant increase in the probability for IGA of VHP's and any associated plan for inspections.
Ginna Station has reviewed the plant historical records to determine if any incident of resin ingress similar to those which occurred in 1980 and 1981 at Jose Cabrera (Zorita) plant has occurred at Ginna.
This data search is structured to identify all resin intrusion events into the primary coolant system with a magnitude greater than 1 ft.'30 liters).
The threshold of 1.
ft.'as chosen as a conservative lower bound since it represents less than 15% of the estimated volume of resin released into the reactor coolant system during the two events at Jose Cabrera.
A review of existing records performed by plant chemistry personnel showed no occurrence at Ginna Station.
For the period of plant operation prior to the routine analysis for sulfate in reactor coolant, the data search was based on a review of the plant's reactor coolant chemistry records relative to specific conductance of the reactor coolant.
'An elevation of a 28 micro S/cm increment in specific conductance was the value used as an indicator of cation resin ingress equivalent to a volume of 1 ft'outine analysis for sulfate in reactor coolant was performed monthly for plant operation from 1992 to June 1996 and weekly since July 1996.
Had either specific conductance or sulfate increases indicated resin ingress to the magnitude of the threshold quantity identified above, additional data evaluation would have been conducted to look for a corresponding depression in pH or elevation in lithium as corroborating information of the incident.
In the case of the use of sulfate data as the indicator, specific conductance would also have been included as confirmatory data had a significant in-leakage event been identified.
It is unnecessary to review plant records for boron, chlorides',
fluorides and oxygen because these species are not viewed as valid indicators of cation resin ingress and degradation within the primary coolant system of a PWR.
Borate, chloride and fluoride anions could be associated with the anion portion of mixed bed resin (cation plus anion);
however, if mixed bed resin leakage to the RCS occurred, the cation portion of the resin would contain the sulfate indicator described above.
Detectable oxygen in reactor coolant, during power operation with appropriate hydrogen overpressure on the volume control tank and specified residual dissolved hydrogen in the reactor coolant, could not occur and, therefore,. could not be associated with resin in-leakage.
Ginna Station has followed the EPRI PWR Primary Water Chemistry Guidelines since July 96 and has implemented revisions when issued.
The following exception to the EPRI guidelines exist at Ginna:
Regular analysis for calcium and aluminum have not been performed.
The magnesium analysis has been done regularly and the other two omitted when no magnesium is found in the primary coolant.
h:Ngw gl
Enclosure I Enhanced 88-05 Results
- 1994, 1995, 1996
Examination Summary Record EIN Site Ginna Work Order ¹ N/A Summary Sheet ¹ RRC01 N96003*
Time:
1012 Comments Informational - Information given to AI Butcavage of Engineering - ¹96GV028 - 4/6/96
,plicable Code:
(
N/A System:
RX Vessel Head escription:
Area Assoc. with CRDM Insulation Inspection ID:
CRDM Examination For:
ISICI MISIPCI Non-Scheduleda E/CO RRMCI Fossil/HydroCI GasO SoSCI Other Exam Type VT Additional Comments:
Pictures given to A Butcavage - This inspection did not rev I any problems with boric acid leakage or
'~lid-up - All areas were clean and did not appear to any different than the 1995 inspection. This was a
.>ited scope exam due to the insulation and shrouds.
E Summarized By IIIH I
NAZI Signature Date F
Paul A Lewis
'o= C Reviewed By IIIQ II0 NAOS Signature Frank A. Klepacki
/
Date
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'isual Examination ofEquipment and Components Work Order ¹ N/A Summary Sheet ¹ N96003 Sheet ¹ 96GV028 Ginna Procedure VT-105 Rev.
0 PDR N/A Date:
4/6/96 Applicable Code:
N/A System ID:
Descrjptjon Area Assoc. With CRDM Insulation Inspection RX Vessel Head Time:
osoo ID Control Rod Drive Mechanism N/A N/A ISO Drawing ¹:
Location:
I'xamination For:
ISIO MISIPO Non-ScheduledH E/C Cl RRMCI Fossil/Hydro CI GasQ SoSCI Other Light Meter MFG:
GE-214 Serial No.
L170 Illumination:
) 8o Ft./CDS Gray Card: 1/32" Direct gx 1/64u Remote Q Surface Condition:
Visual Equipment/Aids:
Flashlight, Camera Ljmjtatjons Porthoies (3) 12" diameter access As Assembled, Insulated Lo Location:
N/A Wo Location:
N/A
'OC L
LOC W
LOC U/D IND R/L SIZE D/L REMARKS This inspection was performed by following the guidelines to enhance 88-05 criteria.
No Boric Acid Deposits.
Looking in west port access hole'- a small existing tool mark puncture in insulation dome.
Southeast port access hole - no recordable indications.
Northeast ort access hole - unavailable due to cavit activities.
'i
)dd. Documentation: Hand SketchE3 PotarotdCI Dtgttat PhotoQ Video TapeQ Other PART A
~
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rnponent ID:
~<etch or Photo:
Control Rod Drive Mechanism Visual Examination ofEquipment and Components Sheet ¹ 96GV028'omments:
Photographs and information have been provided to the cognizant individual Al Butcavage.
14 photographs are with Al Butcavage - EWR 10028 File.
Disposition: Accept CI Reject 0 Informational Qx Information given to A Butcavage of engineering Examiner Level III CI II H I0 Signature
~IIIchael D. Canny
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Examiner Level IIIQ II Q IH Signature Chris G. Northington
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Paul A. Lewis Date Signature Date l I.'I6 PART B
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" %%/$3/j. ly RX VESSEL HEAD ENHANCEMENT TO 88-05 CRITERIA ENHANCEMENT OUTLINE 1
0 2.0 In accordance with NRC recommendation's the scope of this outline is to provide enhancements to NRC Generic Letter 88-05 requirements which are addressed by Station procedure A1407.
These guidelines are being provided to ME&IS 'for on time application for use in performing a visual examination of the area associated with the Control Rod Drive Mechanism penetrations on the Ginna Station RX Vessel.
The intent of the enhanced requirements is to provide direction on visual examination of the Reactor Vessel Head in the area of the Control Rod Drive Penetrations.
3.0 The visual examination of the head area is intended to reveal any larcae deposits of Boric Acid Crystals which may have formed on the vessel head.
4.0 5 ~ 0 Note that due to previously addressed NCR's, on the Conoseals of the
- head, trace deposits of Boric Acid may be found scattered throughout the head area.
The examination should be a visual exam above the existing insulation with documented results stating the existence or absence of large Boric Acid Deposits.
1 The insulation which is in place above the vessel head is the original insulation installed during plant construction.
Note that this asbestos insulation is believed to be in a "Friable" condition and therefore would not be capable of restraining the normal plant operating pressure associated with the RCS.
Therefore any leakage through a CRDM penetration would present itself in the form of Boric Acid deposits above the insulation.
Reporting 1.0 Accumulations which are larger than trace amount or display a natural build up of Boric Acid deposit that could indicate potential leak paths initiating from the CRDM penetrations shall be noted.
2.0 3.0 Appropriate action shall be initiated by
- NES, ME&IS And Station personnel to investigate the source of the boric acid build up.
Depending on the item 2 investigation results, appropriate corrective action should be initiat'ed to address the identified concern.
4.0., If large deposits are identified, the amount of Boric Acid and its location shall be reported using an appropriate process.
Da~ to be included in the report should include as a minimum the following information:
I A.
Location of the Boric Acid deposit could be established using the Center line of the ves'sel head and the existing 0 through 360 degree markings on the vessel head to locate the Boric Acid deposit angle relative to the 0
degree position.
Note that the markings are on the vessel head flange in the area of the flange bolt holes.
B.
In lieu of number 1,
or in addition to number 1,
the location of the Boric Acid deposit could be identified by an existing numbering system used by ME&IS for bi-metallic weld inspections on the CRDM penetrations.
C.
Any additional information on the specific source of the Boric Acid Deposit should be included.
Disposition Action Plan If it is determined that additional reporting of a Boric Acid deposit is required, appropri'ate corrective action will be a
function of the source of the Boric Acid.
Prepared By:
Mecha 'cal En 'neer Reviewed By:
chanica Engine Approved By:
Manager Mechanxca Engineering y:Vrdea ect.pie
Enclosure 2
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