ML20154C071

Forwards Request for Addl Info Re Facility Preservice Insp Program Transmitted W/Util in Order to Proceed W/ Review.Guidance for Preparation of Requests for Relief from Certain Code Requirements Per 10CFR50.55a(a)(3) Also Encl

ML20154C071
Person / Time
Site:	Limerick
Issue date:	05/10/1988
From:	Clark R Office of Nuclear Reactor Regulation
To:	Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
TAC-66831, NUDOCS 8805180028
Download: ML20154C071 (7)

Text

1 I

6 May 10, 1988 4 1 Docket No.: 50-353  !

Mr. Edward G. Bauer, Jr. I Vice President and General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

Dear Mr. Bauer:

I

SUBJECT:

PRESERVICE INSPECTION PROGRAM (TAC N0. 66831)

RE: LIMERICK GENERATING STATION, UNIT 2 i Your letter dated September 10, 1987 submitted the Preservice Inspection Program for Limerick Unit P. The submittal, however, was not docketed until December 11, 1987. We have completed our initial review and find we need  ;

clarification on several items as discussed in the enclosed request for i additional infomation. Your submittal also stated that a number of items I would be provided later, such as requests #or relief and the applicable P& ids I (as listed on p IX of the Table of Contents to be included in Appendix A). As I discussed in the enclosure, some of this information is needed for us to proceed with our review.

Please advise me of when you expect to provide the information requested.

This request for information is specific to one applicant and thus OMB l clearance is not required under P.L.96-511.

Sincerely, Original signed tiy Richard J. Clark Richard J. Clark, Project Manager Project Directorate I-2 Division of Reactor Projects I/II

Enclosure:

Request for Additional Information cc: See next page DISTPIBUTION Docket File. NRC PDR/LPDR l PDI-2 Reading SVarga/BBoger l WButler M0'Brien RClark/RMartin 0GC-WF l EJordan JPartlow i ACPS (10)

PDI-2/P PDI-2/D '

RClark: WButler offo /88 { / /88 O

8805100028 880510 PDR ADOCK 05000353 0 PDR

=

jf# " %^ UNITED STATES

., o

j-e j

e NUCLEAR REGULATORY COMMISSION WASHING TON, D. C. 20555

%, , , .o May 10, 1988 Docket No.: 50-353 Mr. Edward G. Bauer, Jr.

Vice President and General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

SUBJECT:

PRESERVICE INSPECTION PROGRAM (TAC NO. 66831)

RE: LIMERICK GENERATING STATION, UNIT ?

Your letter dated September 10, 1987 submitted the Preservice Inspection Program for Limerick Unit 2. The submittal, however, was not docketed until December 11, 1987. We have completed our initial review and find we need clarification on several items as discussed in the enclosed request for additional infomation. Your submittal also stated that a number of items would be provided later, such as requests for relief and the applicable P& ids (as listed on p 1X of the Table of Contents to be included in Appendix A). As discussed in the enclosure, some of this information is needed for us to proceed with our review.

Please advise me of when you expect to provide the infomation requested.

This request for information is specific to one applicant and thus OMB clearance is not required under P.L.96-511.

Sincerely, i  ! -

p R ci J. ark, Project Manager oject Directorate I-2 Division of Reactor Projects I/II

Enclosure:

Request for Additional Information cc: See next page

Mr. Edward G. Bauer, Jr Limerick Generating Station Philadelphia Electric Company Units 1 & 2 cc:

Troy B. Conner, Jr., Esquire Mr. Robert Gramm Conner and Wetterhahn Senior Resident inspector 1747 Pennsylvania Ave., N.W. U.S. Nuclear Regulatory Commission Washington, D. C. 20006 P. O. Box 58 Sanatoga', Pennsylvania 19464 Mr. Charles Mengert "7-1 Philadelphia Electri Company Mr. Ted Vilrich 2301 Market Street Manager - Unit 2 Startup Philadelphia, Pennsylvania 19101 Limerick Generating Station P. O. Box A Mr. David Honan N2-1 Sanatoga, Pennsylvania 19464 Philadelphia Electric Company 2301 Market Street Mr. John Doering Philadelphia, Pennsylvania 19101 Superintendent-0perations Limerick Generating Station Mr. Grahm M. Leitch, Vice President P. O. Box A Limerick Generating Station Sanatoga, Pennsylvania 19464 Post Office Box A Sanatoga, Pennsylvania 19464 Thomas Gerusky, Director Bureau of Radiation Protection PA Dept. of Environmental Resources :

Mr. James Linville P. O. Box 2063 l U.S. Nuclear Regulatory Comission Harrisburg, Pennsylvania 17120 Region I 475 Allendale Road Governor's.0ffice of State King of Prussia, PA 19406 Planning and Development ATTN: Coordinator, Pennsylvania Mr. Thomas Kenny State Clearinghouse Senior Resident Inspector P. O. Box 1323 US Nuclear Regulatory Commission Harrisburg, Pennsylvania 17102 P. J. Box 47 Saaatoga, Pennsylvania 19464 Mr. Philip J. Duca ,

Superintendent-Technical  !

Mr. Joseph V. Gallagher Limerick Generating Station  !

Vice President, Nuclear Services P. O. Box A  !

Philadelphia Electric Corapany Sanatoga, Pennsylvania 19464 l 2301 Market Street i Philadelphia, Pennsylvania 19101 Mr. John S. Kemper Senior Vice President-Nuclear Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

REQUEST FOR ADDITIONAL INFORMATION PRESERVICE INSPECTION PROGRAM PLAN LIMERICK GENERATING STATION, UNIT 2 DOCKET NO. 50-353

1. Scope / Status of Review General Design Criteria 32, 36, 39, 42, and 45, in Appendix A of 10 CFR Part 50 require, in part, that Code Class 1, 2, and 3 components be designed to permit periodic examination and testing of important areas and features to assess their structural and leak-tight integrit:. The design of these components must incorporate provisions for acce n for inservice examinations, as required by Subarticle IWA-1500 of Section XI of the ASME Code. 10 CFR 50.55a(g) defines the detailed requirements for the preservice and inservice programs for light water-cooled nuclear power facility components. Based upon the construction permit date of June 19, 1974, components (including supports) which are classified as ASME Coda Class 1 and 2 shall meet the preservice examination requirements set forth in editions and addenda of Section XI of the ASME Code in effect 6 months prior to the date of issuance of the construction permit. The coraponents (including suppnrts) may meet the requirements set forth in subsequent editions of this Code and Addenda which are incorporated by reference in paragraph (b) of 10 CFR 50.55a, subject to the limitations and modifications listed therein. The Preservice Inspection (PSI) Program Plan ITs been prepared to meet the requirements of the 1980 Editinn, Winter 1981 Addenda (80481) of the ASME Code Section XI except that the extent of examination for Code Class 2 piping welds in i Residual Heat Removal (RHR) Systems, Emergency Core Cooling (ECC) '

Systems, and Containment Heat Removal (CHR) Systems has been determined by the 1974 Edition through Sumer 1975 Addenda (74S75).

As required by 10 CFR 50.55a(a)(3), if the appl ant deter: nines that certain Code examination requirements are imprac.ical and relief is requested, the applicant shall submit information to the Nuclear 1 Regulatory Comission (NRC) to support that determination, i

The staff has reviewed the available information in the Limerick Generating Station, Unit ?, PSI Program, through Revision 1, submitted September 10, 1987.

2. Additional information/ Clarification Required Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the PSI Program Plan:

A. Provide the staff with two documents listed in Section 1.3 of the PSI Program Plan. The requested documents are er, titled "Preservice Inspection of the ASME Code _ Class 1 Reactor Pressure Vessel" (document 8031-M2468-LATER), and "Preservice Inspection ASME Code Class 1, 2, and 3 Nuclear Piping Systems" (document 8031-P-505).

These doc >ments are reported to identify the specific details as to how the various requirements and commitments made in the Inspection Program are to be met. These documents, if they contain an itemized listing of the welds / components subject to examination along with drawings, will permit the staff to determine if the extent of PSI examinations meets the applicable Ccde Section XI and augmented examination requirements.

B. Section 1.8, "Classification of Components," of the PSI' Program references color-coded P&ID boundary diagrams identifying ASME Code 1 Class 1, ?, 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 l missing from the package that was submitted for review and are l required in order to continue the review.  !

C. Section 3.1(A) of the PSI Program indicates that Class 2 piping welds in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems may be exempted  !

from examinations based on the temperature / pressure exclusions  !

contained in IWC-1220. i l

Paragraph 10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2  !

piping welds in the RHR, ECC, and CHR systems be examined; these systems should not be completely exempted from inservice volumetric examination based on Section XI exclusion criteria contained in IWC-1220. Later editions and addenda of the Code do not permit the temperature / pressure exclusion for these systems, and require i volumetric examination of welds in piping with greater than or equal to 3/8-inch nominal wall thickness and greater that 4-inch nominal pipe size (NPS). The staff has previously determined that a 7.5%

augmented volumetric sample constitutes an acceptable resolution at similar plants. Verify that these systems will not be completely exempted from examinations based on the exclusion criteria contained in IWC-1220, and that volumetric examination will be perfonned on a representative sample of the Class 2 piping welds in these systems.

D. Sections 2.4 (reactor pressure vessel), 2.7 (Class 1 piping), 2.9 (Class 1 pumps), 3.4 (Class 2 pressure vessels), 3.7 (Class 2 piping),

and 3.10 (Class 2 pumps) of the PSI Program all state that relief requests will be submitted "Later." Identify when all requests for relief from ASME Code Section XI PSI requirements will be submittr.d for staff review.

D. When preparing requests for relief, the staff suggests that the Applicant follow the attached Appendix A, "Preservice Inspection:

Guidance for Preparing Requests for Relief from Certain Code Requirements Pursuant to 10 CFR 50.55a(a)(3)."

APPENDIX A PRESERVICE INSPECTION: GUIDANCE FOR PREPARING REQUESTS FOR RELIEF FROM CERTAIN CODE REQUIREMENTS PURSUANT TO 10 CFR 50.55a(a)(3)

A. Description of Requests for Relief The guidance in this enclosure is intended to illustrate the type and extent of information that is necessary for "request for relief" for items that cannot be fully inspected to the requirements of Section XI of the ASME Code. The preservice inspectien program should identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitations of design, geometry or materials of construction of the components. The request for relief should provide the information requested in the following section of this appendix for the inspections and pressure tests identified above.

B. Request for Relief From Certain Inspection and Testing Requirements Many requests for relief from inspection and testing reauirements submitted by Applicants have not been supported by adequate descriptive dnd detailed technical information. This detailed information is necessary to: (1) document the impracticality of the ASME Code reauirements within the limit:tions of design, geometry and materials of construction of components; and (2) determine whether the use of alternatives will provide an acceptable level of quality and safety.

Relief requests submitted with a justification such as "impractical,"

"inaccessible," or any other categorical basis, require additional information to permit an evaluation of that relief request. The objective of the guidance provided in this section is to illustrate the extent of the information that is required to make a proper evaluation and to adequately document the basis for granting the relief in the Safety Evaluation Report. Subsequent requests for additional information and delays in completing the review can be considerably reduced if this information is provi<ied initially in the Applicant's submittal.

Each relief request should be submitted as a "stand alone" document with the following information included:

1. The ASME Code Class, Examination Category, and Item Number (s).

2.Section XI examination or test requirements for the component (s) for which relief is being requested.

3. The number of items associated with the requested relief.

4. Identification of the specific ASME Code requirement that has been determined to be impractical.

L 2-

5. An Itemized list of the specific component (s) for which relief is requested.  ;

6. An estimate of the percentage of the Code-required examination that can be completed for each of the individual components requiring relief.

l

7. Information to support the determination that the requirement is impractical; i.e., state and explain the basis for requesting relief.

If the Code-required examination cannot be performed because of a limitation or obstruction, describe or provide drawings showing the specific limitation or obstruction.

8. A identification of the alternative examinations that are proposed:

(a) in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in compliance with the requirements 1 of Section XI. I

9. A description and justification of any changes expected in the overall level of plant safety by performing the proposed alternative I

examination in lieu of the examination required by Section XI. If it is not possible to perform alternate examinations, discust the ,

impact on the overall level of plant quality and safety. l

10. A description of the ASME Code Section III fabrication examinations that were completed and documented during construction for the specific components listed in the 'elief requests.

Technical justification or data musc be submitted to support the relief request. Opinions without substantiation that a change will not affect the quality level are unsatisfactory. If the relief is requested for  !

inaccessibility, a detailed description or drawing which depicts the inaccessibility must accompany the request.

i