ML20009B447
| ML20009B447 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/08/1981 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Pawlicki S Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20009B448 | List: |
| References | |
| NUDOCS 8107160011 | |
| Download: ML20009B447 (2) | |
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IGDRANDUM FOR: Stefan S. Pawlicki Chief Materials Engineering Branch FROM:
A. Schwencer, Chief LBf2, DL
SUBJECT:
PIPE STORAGE PRACTICES AT LIMERICK GENERATING STATION
References:
1.
Memo f.am Carlsc/to Seyfrit, " Request for Transfer of Lead Responsibility to NRR - Pipe Storage Practices at Limerick Generating Station (AITSfF12126H1)" March 31, 1977.
2.
Memo fmm Pawlicki to Kniel. " Limerick Generating Station U
Units Nos. I and 2. Pipe Storage Practices" May 23, 1977.
[c Storage Practices at the Limerick Generating Station",
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Letter to Philadelphb Electric Company from NRR, " Pipe
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July 14, 1977.
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Letter to NRR from Philadelphia Electric Company, Novenber 4,
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Memo fmm Carlson to Reinmuth, " Pipe Storage Practices at Limerick Generating Station". December 5,1977.
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Memo from Seyfrit to Kniel, " Pipe Storage Practices at Limerick Generating Station, Units No. I and 2 February 15, 1978.
The References summarize an open item wncerning the pipe storage practices at Limeric,[c. NRR letter of July 14, 1977. Reference 3 stated that we found the outsid.e storage of carbon steel pipe without end caps unacceptable.
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response the Applicant submitted a letter on November 4.1977. Reference 4 with data to support his practice. However I&E pointed out. Reference 5, that additional data were available which made the storage practice questionable.
We have not responded to the Applicant's letter of Noventer 4.1977 Reference 4 Your support is requested to evaluate the applicant's posi-tion expressed in that let'.er of storing the subject pipe uncapped followed by inspections after cleaning before use. If the practice is still unac-ceptable what needs to be done to qualify the pipe that is already installed or that has been stored uncapped but not installed?
A. Schwencer. Chief Licensing Branch No. 2 Division of Licensing
Enclosure:
As stated
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'e M8NG oF PftUSSI A, PeNNSYLV ANI A 19406 h n gg March 31, 1977 DN 50-352 DN 50-353 MEMORANDIDi FOR:
K. V. Seyfrit, Chief, Reactor Technical Assistance Branch, IE:HQ h0t DT R. T. Carlson, Chief, Reactor Construction and FROK:
Engineering Support Branch, NRC:I ///7 {.4U i
SUBJECT:
REQUEST FOR TRANSFER OF LEAD RESPONSIBILITY TO NRR
- FIPE STORAGE PRACIICES AT LIMERICK GENERATING
$1ATION (AITS#F12126H1)
An amendment to Appendix A, Paragraph 3.5.3, of the Limerick PSAR was submitted.by the Philadelphia Electric Company in October 1975 wherein.
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they stated the use of end caps on' stored pipe was only applicable to austenitic stainless steel pipe. Their purpose in this amendment was e
The to permit outside storage of carbon steel pipe without end caps.
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licensee is of the viev, based on a study performed by Bechtel at the Limerick site, that uncapped storage.of carbon steel pipe is less deleterious than capped storage.
We perfote d an inspection of thfa item in mid-1976 to review the study and its results. At that time, the information was not on-site. The licensee stated the study showed that capped carbon steel pipe accumu-lated water from condensation resulting in greater internal corrosion rates than that experienced with uncapped pipe stored at a slight tilt to permit draining. This matter was considered to be unresolved pend-ing the inspector's review of the study results. As you know, contrary to the licensee's practice, the ca.pped pipe storage technique is generally practiced in the nuclear industry and is advocated by ANSI Standard N45.2.2 which is endorsed by the NRC.
During a recent reinspection of this matter, our inspector reviewed the study results provided by the licensee. He found that controls for the study and the data obtained did not provide a sound basis to support the licensee's conclusion that uncapped pipe storage is desirable. The study involved a limited sample size and there was a lack of correlation of the data. Specifically, M pipe spools were involved with corrosion rate data taken over a 50-meath period. Corrosion rates were determined l
by wall thickosss measurements and " weight loss" coupons. Provisions had not been made to assure ths.t comparative wall thickness measurements -
were made at the same point on the pipe and, as result, the data was scattered (some data indicated increasing wall thickness). The weight loss coupons appeared to have been handled more precisely and they indicatedaboutafactoroftwohigharcorrosionrateinuncagedpipe.
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K. V. Seyfrit The coupon data disclosed the capped pipe exhibited a projected 37 mil wall thickness loss over a two-year period and uncapped pipe a 72 mil loss. This was contrary to the licensee's conclusions which were based
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on the wal) thickness measurements. Also, since some,of this pipe is stored outs Me for up to four years, the pipe wall thickness-loss could encroach on the minimum required wall thickness.
It is also noteworthy that the licensee's program does not require post storage psasurements and evaluation of pipe wall thickness. -
Based on the 15.censee's studies as reported to our inspector, we find that the licensee's current practice of outside storage of carbon steel pipe has not been appropriately justified. Also, our< inspector observed l
that the open pipe storage practice has resulted in contaminants (dirt) g being deposited inside of the pipes. Although the licensee's practice I
is to clean (sand blast) and inspect the pipe internally prior to installa-tion, we are of the view that detrimental contaminants could remain in the piping which may not be removed during the final cleaning / flushing operation prior to start-up.
Our view is that this storage practice has not been demonstrated to prevent deterioration of piping materials in storage and thus appears i
to be contrary to 10 CFR 50, Appendix B, Criterion XIII and ASME B&PV Code,Section III,1971 Edition, Paragraph NA-4460 which are applicable to the Limerick facility. Howevec, NRR's acceptance of the P.4R change permitting outside storage of uncapped safety related carbon steel pipe makes IE enforcement action difficult at best and establishes a generic j
precedent which will be difficult to correct.
l You are therefore requested to consider a transfer 'of lead responsibility l
for resolution of this item to NRR so* hat they can determine if the observed practice is consistent with their requirements and within the 8
intent of their understanding when they accepted the aforementioned PSAR
.imendment.
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Robert T. Carlson, Chief Reactor Construction and Engineering Support Branch cc:
F. A. Dreher, IE:HQ
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