ML20151W261

Forwards Responses &/Or Schedules for Submittals in Response to NRC 880510 Request for Addl Info Re Preservice Insp Exam Plan

ML20151W261
Person / Time
Site:	Limerick
Issue date:	08/15/1988
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Murley T NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
Shared Package
ML20151W267	List: ML20151W261 ML20151W270 ML20151W274 ML20151W278 ML20151W283 ML20151W297 ML20151W302 ML20151W306 ML20151W310 ML20151W318 ML20151W321 ML20151W327 ML20151W331 ML20151W335 ML20151W339 ML20151W345 ML20151W350 ML20151W355 ML20151W359 ML20151W375
References
NUDOCS 8808240009
Download: ML20151W261 (6)

Text

i-PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A, PA.19101 (215)841 4500 SENIOR Vic RES D NT NUCLEAR August 15, 1988 Mr. T. E. Murley, Director Docket No. 50-353 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Ccmmission Attn: Docunent Control Desk Mall Station P1-137 Washington, DC 20555 -

Subject:

Limerick Gon'erating Station Unit 2 Preservice Inspection Program

Reference:

Request for Additional Information, R. J. Clark to E. G. Bauer, Jr., dated May 10, 1988

Enclosure:

Specification 8031-P-505 Nuclear Piping Systems PSI Examination Plan

Dear Mr. Murley:

Attached are responses and/or schedules for r.ubmittals in response to the referenced request for additional Information. If additional Information is required, please do not hesitate to contact us.

S ircerely, Tbf 8808240009 880815 PDR ADOCK 0D000353 G PNV f.

DLS/pdO8018803 Ih s

Attachnent 7 l 0 Enclosure A61

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$h Copy to: Addressee -

gj,6 g,5 R. J. Clark, LGS Project Manager W. T. Russell, Region I Administrator R. A. Granm, LGS Unit 2 Senior Resident inspector i

. ATTACH 4ENT Response to Request for Additional Information Limerick Generating Station Unit 2, Docket No. 50-353

-Preservice Inspection Program, Specification 8031-P-504 i

The following restates each request and follows with the Philadelphia Electric Company response for Limerick Generating Station Unit 2.

A. Request -

1 Provide the staff with two doctsnents listed in Section 1.3 of the PSI Program Plan. The requested doctments are entitled "Preservice Inspection of the ASPE Code Class 1 Reactor Pressure Vessel" (doctsnent 8031-M-246B-LATER), and "Preservice Inspection ASPE Code Class 1, 2, and 3 Nuclear Piping Systems" (docunent 8031-P-505). These doctsnents are reported to Identify the specific detalls as to how the various requirements and conmitments made in the Inspection Program are to be met. These doctments, if they contain an itemized listing of the welds / components subject to examinatton along with drawings, will permit the staff to determine if the extent of PSI examinations meets the appilcable Code Section XI and augmented examination requirements.

Response -

The Limerick Generating Station Unit 2 Reactor Pressure Vessel Preservice Inspection Examination Plan, Specification 8031-M-246B-227, tables and drawings are currently being revised based on our review of the preservice examination results. The final as-build examination plan will be provided in October 1988.

The Nuclear Piping Systems Preservice inspection Examination Plan, Specification 8031-P-505, is provided herewith as the Enclosure.

These doctments contain Itanized ilstings of the welds /ccmponents subject to examination in accordance with the current design and as-built verifications ccrpleted to date.

B. Request -

Section 1.8, "Classification of Components," of the PSI Program references color-coded PSID boundary diagrams identifying ASME Code Class 1, 2, and 3 piping systems as being included in Appendix A. These boundary diagrams identify the areas where the requirements of ASME Section XI apply In their entirety. These attachments are missing frcyn the package that was submitted for review and are required in order to continue the review.

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.- ' Response -

The ASME Section XI Boundary PCID's identifying Class 1, 2 and 3 systems are currently being revised to be unit specific similar to the design PSID's and QAD's. The Unit 2 ASME Section XI Boundary P&lD's will be provided as Appendix A to the Limerick Generating Station Unit 2 Preservice Inspection Program, Specification 8031-P-504, in Decenbor,1988. In the Interim, the color coded PSID's provided as Appendix A to the Limerick Generating Station Unit 1 Inservice Inspection Progrern, Specification 8031-P-500, may be used. The Unit 1 PSID's were provided with Rev. 1 of Specification 8031-P-500 on October 23, 1985, via letter from J. S. Kerrper to W. R. Butler. The Unit 1 P&lDs also show Unit 2 Information, and although not in a color-coded fonnat, the designs are similar and the programs for the two units are based on the same ASME Code year. Therefore, the diagrams should provide sufficient information to begin the review.

C. Request -  ;

Section 3.1CA) of the PSI Program Indicates that Class 2 piping r welds in the Residual Heat Retroval (RHR), Emargency Core Cooling (ECC), and Containment Heat Removal (CHR) systems may be exerrpted 1 from examinations based on the temperature / pressure exclusions '

contained in IWC-1220. E Paragraph 10CFR50.55aCbX2Xiv) requires that ASME Code Class 2 piping welds in the RHR, ECC, and CHR systems be examined; thcse systems should not be canpletely exempted fran Inservice voltrnetric examination based on Section XI exclusion criteria i

! contained in IWC-1220. Later editions and addenda of the Code do not permit the temperature / pressure exclusion for these systems,

and require voltsnetric examination of welds in piping with greater  !

than or equal to 3/8-inch nominal wall thickness and greater than 4-inch ncminal pipe size (NPS'). The staff has previously deterTnined that a 7.5% augmented volumetric sarrple constitutes an ,

acceptable resolution at similar plants. Verify that these systems will not be camletely exempted fran examinations based on the exclusion criteria contained in IWC-1220, and that t

voltrnetric examination will be performed on a representative sanple of the Class 2 piping welds In these systems.

Response -

I Sections 1.4 and 3.1(A) of the Preservice inspectior Progran Indicate that sane Class 2 piping welds in the Residual Heat Renoval (PJiP3, Emergency Core Coollng (ECC) and Contairment Heat Rmoval (CHR) systems may be exempted fran examinations based on the temperature / pressure exclusions contained in IWC-1220.

j Voltrmtric and surface examinations of RHR, ECC and CHR system

welds will be performed on a representative sarmle of the Class 2

piping welds in these systerrs. Scrne portions of these systems j will be exempted, hcwever, these portions of the systems will 1

receive visual examinations as required by ASM'i Section Xi and J

10CFR50. 55aCbX2X lv).

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D .* ' Request -

Sections 2.4 (reactor pressure vessel), 9.7 (Class 1 piping), 2.9 (Class 1 puros), 3.4 (Class 2 pressure vessels), 3.7 (Class 2 piping), and 3.10 (Class 2 puros) of the PSI Progran all state that reIIef requests will be sutenitted "Later". Identify when all requests for relief fran ASME Code Section XI PSI requirements will be submitted for staff review.

Response -

The request for relief from ASME Code Sect lon XI PSI reaut ranents are currently being prepared based on our review of the preservice examination results. They wl11 be subnitted in January 1989 as part of the as-build Unit 2 Preservice Inspection Progran, Specification 8031-P-504.

E. Request -

When preparing requests for relief, the staff suggested that the Applicant follow the attached Appendix A, "Preservice Inspection: Guidance for Preparing Requests for Relief from Certain Code Requirenents Pursuant to 10CFR50.55a(e)(3)".

Response -

Philadelphia Electric Conpany will follow the guidance provided in preparation of the requests for relief.

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