ML20094G393
| ML20094G393 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/07/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| OL, NUDOCS 8408130296 | |
| Download: ML20094G393 (7) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101
' JOHN S. KEMPER AUG 0 71984 m.......,
1NGONatRtNG AND RESE ARCM Mr. A. Schwencer, Chief Licensirig Branch No. 2 Division of Licensing U. S. Nuclear Regulatory Conmission Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Information for Materials Engineering Branch (MTEB)
Regarding SER Confirmatory Issue #12 - Preservico Inspection (PSI) Program
REFERENCES:
- 1) Telecon between M. Hun /C. Y. Cheng (NRC/MTEB) and D. Schnidt (PECo), 7/20/84
- 2) Letter, d. S. Kemper (PECo) to A. Schwencer (NRC),
dated 7/17/84 ATTACHMENTS:
- 1) Limerick Unit 1 PSI Relief Request No. 19, Rev. 1
- 2) Limerick Unit 1 PSI Relief Request No. 20, Rev. 1
- 3) History of Welds in Relief Requests 19 and 20 FILE:
GOVT 1-1 (NRC)
Dear Mr. Schwencer:
/
As discussed in the reference (1) telecon, attachments 1 and 2 provide revisions to Relief Requests 19 and 20.
The Limerick Unit I rollef requests were originally transmitted by reference (2).
Attachnent 3 ' provides additional information to supplement these revised relief requests.
Sincerely, b
'b RRH/ cam 08028405
' Attachments cc: See Attached Service List 8408130296 840807 gDRADOCK 05000352 O
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l I;
cc: Judge Lawrence Brenner (w/o enclosure)
Judge Richard F. Cole (w/o enclosure)
Troy B. Conner, Jr., Esq.
(w/o enclosure)
Ann P. Hodgdon, Esq.
(w/o enclosure)
Mr. Frank R. Romano (w/o enclosure)
Mr. Robert L. Anthony (w/o enclosure)
Charles W. E71iot, Esq.
(w/o enclosure)
Zori G. Ferkin, Esq.
(w/o enclosure)
Mr. Thomas Gerusky (w/o enclosure)
Director, Per.na. Emergency (w/o enclosure)
Management Agency Angus R. Love, Esq.
(w/o enclosure)
David Wersan, Esq.
(w/o enclosure)
Robert J. Sugarman, Esq.
(w/o enclosure)
Spence W. Perry, Esq.
(w/o enclosure)
Jay M.'Gutierrez, Esq.
(w/o enclosure)
Atomic Safety & Licensing (w/o enclosure)
Appeal. Board Atomic Safety & Licensing (w/o enclosure)
Board Panel Docket & Service Section (w/o enclosure)
Martha W. Bush, Esq.
(w/o enclosure)
Mr. James Wiggins (w/o enclosure)
Mr. Timothy R. S. Campbell (w/o enclosure)
Ms. Phyllis Zitzer (w/o enclosure)
Judge Peter A. Morris (w/o enclosure)
m i
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' Attachment 1 6
3_
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. Limerick' Generating Station, Unit 1 Preservice Inspection Relief Request ASE BSPV Code,-Section XI jl9. -Class"1 Pressure Retaining Welds in Piping
- Code Item No. B4. 5, category B-d.
' Code"Reaulrament:
Those pipe longitudinal and circunferential pressure -
retaining welds included In Code _ Category B--J of Table
- IWB-2500 shall be volunetrically examined per Item B4.5 of Table IWB-2600.
Indications shall'be. evaluated using the acceptance standards for examination evaluation specified in
. subarticle IWB-3100 of. the 1974 Edition of Section XI, including Addenda through Surmer 1975.
-Re1lef Request:
Relief Is' requested to use the acceptance standards specified.
In the 1980 Edition of. ASE Section XI, including Addenda through Winter 1981 (anticipated code edition to be used for ISI examination), In lieu of the 1974 Edition of ASE Section XI, including Addenda through Surmer 1975. This
-relief is requested for the evaluation of seven (7).
longitudinal; welds, identified as RRA-027LD Max./ Min.,
RRA-028LU Max./ Min., RRA-037LD Max., RRA-038LU Max.,
RHB-005LD Max. and ~. one (1) circunferential weld identified as'FWB-028. These welds are included in the Cu manent
~
Sunnary Table.
Justification for Granting Relief The factors considered in the use-as-is disposition of weld flaw Indications are as follows:
1.
Use of the 1980 Edition of ASE Section XI, including Addenda through Winter 1981, for determining acceptance criteria for preservice examinations is appropriate and in conpliance with 10CFR50 requirements. The 1980 Edition of ASE Section XI uses recently developed piping weld acceptance criteria based on fracture mechanics.' These acceptance. criteria reflect current technology for ASME Section XI appilcations which did not exist in the 1974 Edition, Sunner 1975 Addenda.
This technology acknowledges that service induced flaw.
growth results from planar as opposed to laminar oriented flaws. It requires the use of a flaw sizing evaluation technique, recording of flaw sizes above a given size, and subsequent exaninations to check for possible growth or the origination of new service induced flaws.
It is already.a requirement of 10CFR50 that~the first ISI examination for Limerick Unit 1 has to be performed to a Section XI Code Edition that uses
. pipe weld acceptance criteria based on fracture mechanics.
r Attachment 1 s
Limerick Generating Station, Unit 1 Preservice Inspection Relief Request
- 4SE BSPV Code,Section XI 2.
All indications, which produced a response greater than 20% of reference level during the preservice examinations, were investigated to determine their extent, shape, identity and location. The indications were characterized and considered to be unacceptable per the evaluation standards of ASME Section XI,1974 Edition including Addenda through Smmer 1975; however, these indications are acceptable per the evaluation standards of ASE Section XI, 1980 Edition including Addenda through Winter 1981. The indications were characterized as either subsurface or nultiple planar flaws per Article IWA-3000 of the 1980 Edition of ASME Sc; tion XI.
Flaw aspect ratios were developed and evaluated using the acceptance criteria specified in Article IWB-3000 of the 1980 Edition.
3.
Welds were previously examined by radiography and evaluated as required by ASME Section III and all were found to be acceptable. The shop fabricated piping subassenbiles have satisfied all ASME Section III requirements as signified by signoff of Form NPP-1 and application of the ASE Section III Code NPT Stamp.
Based on the above, it was concluded that there were no safety or plant reliability concerns and the subject welds were accepted for use-as-is.
The welds included in this relief request will receive successive Inservice inspections in accordance with subsubarticle IWB-2420 of ASME Section XI, 1980 Edition including Addenda through Winter 1981, which is the anticipated code edition for the inservice inspection (ISI) program. This requires nure frequent inspection than would normally be required for welds without Indications.
g RRH/pdO8068402
' Limerick Generating Station, Unit 1 Preservice Inspection Relief Request ASM BSPV Code,Section XI 20.
Class 2 Pressure Retalning Welds l'1 Piping Code Item No. C2.1, Categories C-F Ond C-G Code Requirement:
Those pipe longitudinal and circunferential pressure retaining welds included in Code Categories C-F and C-G of Table IWC-2520 shall be volunetrically examined per Item C2.1 of Table IWC-2600.
Indications shall be evaluated using the acceptance standards for examination evaluation specified in subarticle IWC-3000 of the 1974 Edition of Section XI, including Addenda through Sumier 1975.
Relief Request:
Relief is requested to use the acceptance standards specified in the 1980 Edition of ASME Section XI, including Addenda through Winter 1981 (anticipated code edition to be used for ISI examination), in lieu of the 1974 Edition of ASE Section XI, including Addenda through Sunner 1975. This relief is requested for the evaluation of four (4) welds, Identified as RHB-194, HP-117, RDA-019, and RDB-011.
These welds are included in the Component Sunnary Table.
Justification for Granting Relief The factors considered in the use-as-Is disposition of weld i
flaw Indications are as follows:
1.
Use of the 1960 Edition of ASE Section XI, including Mdenda through Winter 1981, for determining acceptance criteria for preservice examinations is appropriate and in conpliance with 10CFR50 requirements. The 1980 Edition of ASE Section XI uses recently developed piping weld acceptanc.e criteria based on fracture mechanics. These acceptance criteria reflect current technology for ASME Section XI appilcations which did not exist in the 1974 Edition, Sunmer 1975 Addenda.
This technology acknowledges that service induced flaw growth results from planar as opposed to laminar oriented flaws. It requires the use of a flaw sizing evaluation technique, recording of flew sizes above a given size, and subsequent examinations to check for possibic growth or the origination of new service Induced flaws.
It is already a requirement of 10CFR50 that the first ISI examination for Limerick Unit I has to be performed to a Section XI Code Edition that uses pipe weld acceptance criteria based on fracture mechanics.
)
m-E Limerick Generating Station, Unit 1 Preservice<Insnection Relief Request
- 4SE BSPV Code,Section XI 2.
All indications, which produced a response greater than 20%'of-reference level during the preservice -
exarninations, were investigated to determine their extent, shape,-identity and location. The indications were characterized and considered to be unacceptable per the evaluation standards of ASPE Section XI,1974 Edition. including Addenda through Swmer 1975; however, these Indications-are acceptable per the evaluation standards of ASE Section XI, 1980 Edition including Addenda through Winter 1981. The indications were characterized as either subsurface or multiple planar flaws per Article IWA-3000 of the 1980 Edition of ASME Section-XI.= Flaw aspect ratios were developed and evaluated using the acceptance criteria specified in Article IWC-3000 of the 1980 Edition.
3.
Welds were previously examined by radiography and evaluated as. required by ASE Section III and all were found to be' acceptable. The shop fabricated piping subassenblies have-satisfied all ASE Section III requirements as signifled by signoff of Form PSP-1 and appilcation of the ASE Section III Code iPT Stanp.
Based on the above, it was concluded that there were no safety or plant reliability concerns and the subject welds
.were accepted for use-as-is.
The welds included in this' relief request will receive successive inservice' inspections in accordance%31th subsebartIcle-IWC-2420 of ASE SectIon XI, 1986 EdI. tion
' including Addenda through Winter 1981, which Ip the anticipated code edition for the Ir* service inspection (ISI)-
program. This requires more frequent inspection than would-normally be ' equired for welds without Indications.
r RRH/pdO8068403
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