ML20082U610
| ML20082U610 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/27/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9505050204 | |
| Download: ML20082U610 (3) | |
Text
[h a J s, 10CFR50.55a(3)(1)L I
PECO ENERGY.
= m'3.='.m.,, -
e 965 Chesterbrook Boulevard i
Wayne. PA 19087-5691
. Apr5 27,1995 Docket No. 50-352 50-353 License No. NPF NPF-85 :
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Limerick Generating Station, Units 1 and 2 Inservice Inspection, inservice Testing, and Repair ard Replacement Programs
-l Basis for Continued Use of the 1986 Edition of the
-l
' ASME Section XI Code Requirements l
i Gentlemen.
}
On February 1,1986, Limerick Generating Station (LGS), Unit 1, began commercial operation
}
which marked the beginning of the Unit 1 First Ten-Year interval inservice inspection (ISI),
j inservice Testing (IST), and Repair and Replacement Programs, which were developed to 1
Implement the requirements of Section XI d the American Society d Mechanical Engir,eers j
t (ASME), Boller and Pressure Vessel (B&PV) Code. At the time these prograrn's were i
implemented, the 1900 Edition of the Section XI Code, including Addenda thrcogh the Winter 1981 Addendum, were used to develop the ASME Section XI Programs (i.e.,181, IST, and Repair and Replacement), as required by 10CFR50.55a(g)(4)(i).
]
By letter dated January 24,1992, PECO Energy Company notified the NRC that the LGS,' Unit 1 and Common ISI, IST, and Repair and Replacement Programs had been voluntarRy upgraded to meet the requirements of the latest NRC approved version of the ASME Section XI Code, (i.e.,
1906 Edition, no Addenda). This voluntary upgrade was adopted following the completion of the LGS, Unit 1. Third Refueling Outage, and has been used for the remainder of the First Ten-Year inspection Interval. The voluntary upgrade was initiated to allow LGS, Unit 1, to utRize the same Edition of the ASME Section XI Code as that required for LGS, Unit 2 (i.e,1996 Edition). This alignment of applicable Code Edition was developed to provide a cost effective and uniform set of requirements for both units at LGS, and to preclude any confusion which could result from the use of different requirements for each unit.
The First Ten-Year Inspection Interval for LGS, Unit 1, is scheduled to end on February 1,1996.
However, by letter dated Apr5 6,1995, PECO Energy notified the NRC that the interval would be extended urul March 1,1996, to accommodate the Sixth Refueling Outage schedule. As required by paragraph by 10CFR50.55a(g)(4)(ii) the 1989 Edition of ASME Section XI Code must 4
be used to develop the ASME Section XI Code Programs for LGS, Unit 1 and Common, for the q
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fAprI27,1995 Page 2 Second Ten-Year inspection interval which is scheduled to begin at the end of the Sixth '
Refueling Outage (i.e.,1R06). FulfIllng this requirement wIl force a misalignment of the program j
requirements between the two units at LGS (i.e.,1986 Code for Unit 2,1980 Code for Unit 1).
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Satisfying the regulation wil require the development of a parallel set d implementation
'I documents (e.g., procedures, guidelines, etc.) which wil be used at LGS, Unit 1 for.
j approximately three to four years At that time, the LGS Unit 2 Program wIl also require update
- to meet the requirements of the later code for its second inspection interval. This update wil-j likely realign the two unit's programs to the same code requirements.
-j in order to avoid the inherent and repetitive misalignment of the ASME Section XI Code I
programs, PECO Energy is requesting approval of the following In accordance with 10CFR50.55a(3)(1), PECO Energy proposes an attemative to the rules contained in 10CFR50.55a(g)(4)(li), which require that: " inservice examination of components and system pressure tesis conducted during successive 120-month -
Inspection intervals must comply with the requirements of the latest Edition and
. Addenda of the Code incorporated by reference in paragraph (b) of this section 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed in paragraph (b) of this section." Instead, PECO Energy proposes to begin the Second Ten-Year Inspection interval d LGS, Unit 1 and Common,-
as normally scheduled, using the existing Code requiremeras 0.e., First Interval requirements), as described in the 1986 Edition of Section XI Code, in approximately z
three (3) years following the start of the LGS, Unit 1, Second Ten-Year interval, when '
l LGS, Unit 2, completes its First Ten-Year inspection Interval, both Unit 1 and Unit 2 wil be simultaneously updated to the latest approved Edition and Addenda of the Section XI Code, which wil be the Code requirements in effect 12 months prior to the start of LGS, 1
Unit 2 Second Inspection interval, as required by 10CFR50.55a(g)(4)(ii).
The basis for this proposed altemative contains two (2) main points First, the proposed altomative will provide an acceptable level of quellty and safety. This conclusion is based on a comparison between the requirements of the 1989 Edition of the Section XI Code (i.e., for the Second Ten-Year Interval), and the requirements of the 1986 Edition of the ASME Code (i.e., First Ten-Year ISI Interval requirements). Except for the addition of the mandatory Appendix Vil, few substantial changes have been made. _ Further the use of NRC approved Code Cases and ASME approved Code Cases (via approved relief requests) in conjunction with either version of the ASME Code tends to normalize each j
of the resulting programs. Therefore, there is even less significant difference between a program written to the 1986 Edition of Section XI versus one written to the 1989 Edition, j
when Code Cr.;es are utilzad.
Additionally, the relationship of the inspection interval dates for the two LGS units creates a repeated economic burden for PECO Energy. This burden is caused by the need to develop and maintain two (2) somewhat differens sets of program implementation documents for portions of each unit's Ten-Year ISI interval. As a minimum, the implementation documents must be completely reviewed, twice during i
each inspection interval, to assure that they adequately surgott both unit's updated ISI j
Program requirements. Approximately 325 procedures would need to be reviewed and revised to at least reference the additional (new) Edition / Addenda of the ASME Section i
XI Code applicable to the ISI Program. This ec0006-Je burden is estimated to cost between $285,000 and $300,000 each time a review is required.
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Apr5 27,1995
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Further, the use of two (2) different sets of requirements at the same station could lead to confusion and inefficiencies, which could tend to divert resources and attention from
- the underlying theme cf the ASME Section XI ISI Programs at LGS.
Therefore, we would appreciate the NRC's cooperation by reviewing and approving this request by December 1,1996, in order to facIltate cc - ' ^: wy and commonality in upgrading the LGS, Units 1 and 2, ISI, IST, and Repair and Replacement Programs for the Second-Ton Year -
Inspection Interval.
-l If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, L
40.4 74 G. A. Hunger, Jr. -
Director Licensing cc:
T. T. Martin, Administrator, USNRC, Region I N. S. Perry, USNRC Senior Resident inspector, LGS i
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