ML20012B671
| ML20012B671 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/06/1990 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20011D112 | List: |
| References | |
| GL-88-01, GL-88-1, TAC-69143, TAC-69144, NUDOCS 9003160088 | |
| Download: ML20012B671 (5) | |
Text
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UNITED STATES tc
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g NUCLEAR REGULATORY COMMISSION 5-8 WASHINGTON. D. C. 2%f4
(....,f' March 6, 1990 Docket Nos. 60 352 l
and 50-353
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Mr. George A. Hunger, Jr.
Director Licensing, MC 5-2A-5 i
Philadelphia Electric Company i
huclear Group Headquarters i
Correspondence Control Desk P.O. Box Nc. 195 l
Wayne, Pennsylvania-19087-0195
Dear Mr. Hunoer:
SUBJECT:
GENERIC LETTER 88-01 (TAC N05, 69143 AND 69144) l
'RE:
LIMERICK GENERATING STATION, UNITS 1 AND 2 i
Your letters of August 2, 1988, AplGL) 88-01, "NRC Position on IGSCC in BWR ril 28, 1989, May 30, 1989 and September 11, 1989 responded to Generic Letter i
Austenitic Stainless Steel Piping." We have completed our review of your i
submittals with the assistance of a contractor, Viking Systems International, i
Our Safety Evaluation and our Contractords Technical Evaluation Report (TER) i are enclosed.
The generic letter requested that you address five specific items and your proposed actions on 13 staff positions. Your responses to the five items is t
acceptable except for the following:
1.
Item 2. requested that you provide the actual list of welds that you l
were going to examine at the last refueling outage. You stated that the GL 88-01 requirements would be integratee' with the regular ISI program and that inspections will be performed at frequencies which will be in conformance with the Staff Positions on Inspection Schedules.
1 This is not specific enough to assess the scope of your program.
l Accordingly, it is requested that you submit your IGSCC inspection plans for staff review at least three months prior to the beginning of each refueling outage.
2.
Item 3 requested that you submit an a plication to amend the Limerick Technical Specifications (TSs) to inc ude a statement in the section on ISI that the Inservice Inspection Program for pising covered by the scope of GL 88-01 will be in conformance with tse staff position I
on schedule, methods and personnel and sample expansion. You and some other BWR licensees took exception to this request. The staff reevaluated this issue and concluded that this requirement needed to l
be in the TSs. As nart of the TS improvement program, surveillance requirement 3.0.5 will be relocated to the Administrative Controls section of the STS. You are requested to submit a TS change to include the statement on the ISI program as initially proposed in your letter of August 2, 1988.
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I 3.
Item 4 requested EWR licensees to amend the TSS to incorporate the staff position on unidentified leakage - specifically, that unidenti-fied leakege be limited to an increase in leakage of 2 gpm over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, that total unidentified leakage be limited to 5 gpm and that leakage be monitored every four hours.
Your letter of August 2 1988 discussed reasons why you concluded the present TS requirements i
were adequate. Most other BWR licensees also took exception to the leakage detection requirements in GL 88-01. The staff reassessed the r
leakage requirements and concluded that, with one exceptiod, they were reasonable and r.ecessary. The staff agreed that monitoring leakage i
every four hours would create an unnecessary administrative hardship.
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The staff position was modified to reouire that leakage be monitored every eight (8) hours.
It is requested that you submit an epplication to revise the Limerick TSs to incorporate the above limits on unidenti-fied leakage.
Your responses on the 13 staff positions are acceptabic except for the following:
1.
As a result of the fuel f ailures in the second fuel cycle of Unit 1 there were many discussions and presentations by your staff on j
proposed improvements to the water chemistry program. These improve-ments go well beyond the "B)lR Water Chemistry Control Program" dated December 11, 1987 referred to on page 4 of your August 2,1988 letter. We assume that the actions and commitments you made in your letter of April 3, 1989 to avoid future CILC related fuel failures at Limerick, Units 1 and 2, supersede the discussion of water chemistry in your August 2,1988 letter. Your proposed actions included improved performance of the condensate filter /dimineralizers, improved i
monitoring methods and instrumentation, minimizing copper in the feedwater, limiting chemica_1 transients and total organic carbon and installation of full-flow, deep-bed demineralizers at the next refueling outages for Units 1 and 2.
On the basis of the later submittals, we find your water chemistry 1rogram acceptable, in fact, the actions and evaluations underta(en by your plant chemistry staff following the recent condenser tube leaks in Unit 1 is commendable.
Our contractor did not have the benefit of the discussions and submittals related to the Unit I fuel failurest hence th TERdoesnotfullyreflecttheabovestaffdeterminatIon.eenclosed 2.
You discussed your plans to notify the NRC of any flaws that do not meet IWB-3500 criteria of Section XI of the Code for continued operation and to obtain NPC approval of the disposition for each flaw exceeding the criteria before resuming operation. You made a very good submittal on the indication you found during the second refueling outage in the Limerick, Unit I recirculation riser nozzle to safe end weld, in your submittals on GL 88-01, you did not address your general position on use of weld overlays and clamping devices or long range plans, if any, for stress improvement of welds
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in Unit 1.
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k-Mr. George A. Hunger e 3.
It was not clear whether you plan to inspect the 195 category G welds c"
in the Reactor Water Cleanup System beyond the outer containment isolation valve.
We suggest'a meeting with your staff to resolve the items discussed in this letter end Safety Evaluation.
Sincerely, i
l-Original signed ti)f Richard J. Clark Richard 11. Clark, Project Manager Project Directorate 1-2 Division of Reactor Projects 1/11
, h, Office of Nuclear Reactor Regulation
Enclosures:
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3.
It was not clear whether you plen to inspect the 195 category G welds in the Peactor Water Cleanup System beyond the outer containment it.olation valve.
We suggest e meeting with your staff to resolve the items discussed in this letter and Safety Evaluation.
Sin
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lark. Project Manager reject Di ectorate 1 2 Division of Reactor Projects 1/11 Office of Fuclear Reactor Regulation
Enclosures:
1.
Safety Evaluation 2.
Technical Evaluation Report cc w/ enclosures:
See next page
_ - _._____-_____ _ _ __ __ _--__ _ __ _ _____ _____-__ w
.o Mr. George A. Hunger, Jr.
Limerick Generating Station Philadelphia Electric Company Units 1 & 2 CC:
Troy B. Conner, Jr., Esquire Mr. Thomas Gerusky, Director Conner and Wetterbahn Bureau of Radiation Protection 1747 Pernsylvania Ave., N.W.
PA Dept. of Environmental Resources Weshington, D. C.
20006 P. O. Box 2063 Mr. Red Krich 52A-5 Philadelphia Electric Company Single Point of Contact 955 Chesterbrook Boulevard P. O. Pcx 11880 Wayne, Pennsylvania 19087-5691 Harrisburg, Pennsylvania 17108-1880 Mr. Graham M. Leitch, Vice President Mr. Philip J. Duca Limerick Generating Station Support Manager Post Office Box A Limerick Generating Station Sanatoga, Pennsylvania 19464 P. O. Box A Sanatoga, Pennsylvania 19464 Mr. Marty J. McCormick, Jr.
Plant Manager Hr. Gary Edwards Limerick Generating Station Superintendent-Technical P.O. Box A Limerick Generating Station Senatoga, Pennsylvenia 19464 P. O. Box A Mr. Larry Doerflein O.S. Nuclear Regulatory Comission P.egion I A75 Allendale Road King of Prussia, PA 19406 tir. Thomas Kenny Senior Resident inspector US Nuclear Pegulatory Comission P. O. Box 596 Pottstown, Pennsylvania 19464 Mr. John Doering Project Manager Linerick Generating Station P. O. Box A Sanatoga, Pennsylvania 19464 Mr. Larry Hopkins Superintendent-Operations Limerick Generating Stttion P. O. Box A Sanatoga, Pennsylvania 19464 i
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