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> From: Phoenix_Firebird_One [mailto:firebird.one@alum.mit.edu]

> Sent: June 29, 2002 9:03 AM

> To: DBRVH_LTBL@yahoogroups.com

> Subject: [DBRVH_LTBL] NRC Response to Paul Blanch (posted in our files

> section also)

>

> UNITED STATES

> NUCLEAR REGULATORY COMMISSION

> WASHINGTON, D.C. 20555-0001

>

> June 19, 2002

>

> Mr. Paul M. Blanch

> 135 Hyde Rd.

> West Hartford, CT 06117

> Dear Mr. Blanch:

>

> Thank you for your E-mail correspondence to the Nuclear Regulatory

> Commission (NRC) dated May 9, 2002. Your letter indicated that you

> had reviewed the recently issued NRC augmented inspection team (AIT)

> report and the Davis-Besse root cause analysis (RCA) report. From

> these documents and comments made during the public meeting of May

> 7, 2002, you detailed six questions in your e-mail message and

> requested these be considered as formal questions from the meeting.

> Your questions have been evaluated by the staff and the responses to

> your specific concerns as they relate to Davis-Besse, are discussed

> below:

>

> Question 1 :

> According to the RCA and the AIT, the cracking on Nozzle #3 was only

> axial. If this is true, then why did this nozzle fall over. In order

> to do this, it had to have circumferential cracking? Am I missing

> something? I think one of the enclosed photos clearly shows the

> circumferential crack around the II J" weld .

>

> Response 1 :

> The cracking in Nozzle #3 at Davis-Besse was only axially-oriented

> according to the non- destructive examinations performed by the

> licensee. The nozzle "fell over" during the repair process when the

> nozzle was machined to a location above the J-groove weld and the

> nozzle lost the support of the J-groove weld. None of the

> photographs available to the NRC staff support the presence of a

> circumferential crack in Nozzle #3.

>

> Question 2:

> If the control rod drive mechanism had not fallen over, was Davis-

> Besse planning to clean the head, or as in the past, restart with a

> significant boron remaining on the vessel head?

>

> Response 2:

> Although the licensee for Davis-Besse did not have a regulatory

> commitment to clean the reactor pressure vessel (RPV) head, the

> licensee had stated a plan to clean the head during

> the most recent refueling outage to facilitate visual examination of

> the head at the next refueling outage. The RPV head cleaning was a

> contingency in case the planned new replacement head was not

> available at the next refueling outage.

>

> Question 3:

> The AIT and the RCA are consistent in the discussions about

> circumferential cracking. That is, the circumferential crack

> initiates from the outside diameter (OD) to the inside diameter. If

> this is the case, then how is it that circumferential cracking is

> considered primary water stress- corrosion cracking (PWSSC)? Can I

> assume that the circumferential cracking is the result of axial

> cracking?

>

> Response 3:

> Circumferential cracking initiated from the OD of the nozzle has

> been identified at plants both above and below the J-groove weld.

> For cracks initiated below the J-groove weld, the environment for

> these cracks is strictly primary water, and hence PWSCC is the

> mechanism of interest. For OD cracking above the J-groove weld, the

> water that initially fills the annulus between the nozzle and the

> reactor pressure vessel head comes from through-wall axial cracking

> and it has a composition similar to that of the primary water. As

> additional leakage occurs, the composition of the water in the

> annulus should become more concentrated due to the evaporation of

> the water itself. The description of this mechanism as PWSCC is

> intended to highlight that the source is primary water as opposed to

> secondary or raw water.

>

> Question 4:

> During the meeting there were many discussions about axial crack

> growth rate, but I did not hear any discussions about

> circumferential crack growth rates. It is my assumption that the

> circumferential cracks present the greater risk from possible rod

> ejection accidents than the axial cracks.

>

> Response 4:

> In general, circumferential cracks do present the greater safety

> risk from possible rod ejection events. For the conditions

> identified at Davis-Besse, the safety implications of the RPV head

> wastage outweighed those of the circumferential cracking identified.

> Because the licensee's root cause summary report attributes the RPV

> head degradation to boric acid leakage from

> axial through-wall cracking, the focus of the May 7, 2002, public

> meeting was the growth rate of the axially oriented cracking in

> Nozzle #3.

>

> Question 5:

> Is it possible that a through wall axial crack may occur and remain

> visually undetected due to a tight interference fit at the top of

> the head and then cause undetected circumferential cracking during

> an operating cycle?

>

> Response 5:

> The possibility of initiation of a circumferential crack from an

> undetected axial through-wall crack is a concern that the NRC has

> addressed in Bulletin 2001-01. Specifically, the Bulletin describes

> a "qualified visual examination" which includes a demonstration of a

> leak path from the annulus between the nozzle and the reactor

> pressure vessel head spanning from the J-groove weld to the outside

> surface of the reactor pressure vessel head. If a licensee cannot

> conclude that a leak path exists for any particular nozzle at a high

> susceptibility plant, then Bulletin 2001-01 would indicate the need

> to perform volumetric examination capable of detecting OD-initiated

> circumferential cracking. In addition, a circumferential crack that

> develops during an operating cycle would not be expected to have

> sufficient growth during that cycle to raise a safety concern.

>

> Question 6:

> The following statement is made on page #3 of the NRC AIT

> report: "The cracks in these five nozzles initiated from the outside

> diameter of the nozzle near the J-groove weld." Again, a crack

> initiating from the OD does not appear to be PWSCC unless the crack

> was below the J-groove weld.

>

> Response 6:

> The OD-initiated cracks in four of the five nozzles described on

> page 3 of the AIT report are located on the nozzle below the J-

> groove weld, and hence, in this case, the cracking is due to PWSCC.

> The OD circumferential crack in Nozzle #2 is above the weld, and as

> described in Response 3, the conditions for this crack are not true

> PWSCC, but primary water is the source of the environment.

>

> In conclusion, I would like to thank you for your correspondence and

> sincerely hope this has answered your questions. The NRC is closely

> monitoring the Davis-Besse issue and that the rules and regulations

> that provide for safe operation of nuclear power plants are

> followed, and thus public health and safety is maintained.

>

> Sincerely,

> Anthony J. Mendiola, Chief,

> Section 2   Project Directorate III

> Division of Licensing Project Management

> Office of Nuclear Reactor Regulation

> __



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