ML20195H928
| ML20195H928 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/06/1988 |
| From: | Kowalski S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8801200416 | |
| Download: ML20195H928 (4) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.'. BOX 8699 O
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PHILADELPHI A. PA.19101 (2 5) s4 4sor S. J. KOWA LSKI January 6, 1988 vic a.,n a sio a s r on..............
United States. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk
Subject:
USNRC Region I Letter dated December 7, 1987 Re:
Site Inspection of October 12, 1987 to November 15, 1987 Inspection Report No. 50-353/87-14 Limerick Generating Station, Unit 2 File: QUAL 1-2-2 (353/87-14)
Gentlemen:
In response to the subject letter regarding the item identified during the subject inspection of construction activities authorized by NRC Licence No. CPPR-107, we transmit herewith the following:
Attachment I - Response to Appendix A Should you have any questions concerning these items, we would be pleased to discuss them with you.
Sincerely, s'.
JMC/mep Attachment Copy to: United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 9"
R. Gramm, USNRC Resident Inspector
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AI Attachnent I Response to Appendix A Violation As a result of the inspection conducted on October 12, 1987 to Novenber 15, 1987, and in accordance with 10CFR21, Appendix C (Enforcement Policy 1987), the following violation was identified.
10CFR50, Appendix B, Criterion III requires that measures shall be established to assure that regulatory requirenents and the design basis specified in _the IIcense application are correctly translated into specifications and drawings. The Limerick Construction Quality Assurance Program Appendix D-6.2 specifies that Final Safety Analysis Report requirenents will be translated into appropriate engineering specifications, drawings and purchase orders. The Limerick Final Safety Analysis Report Section 3.2.2d states that fleid installed ANSI B31.1 energency diesel generator auxiliary piping will be procured a3 ASME noterial, that welds greater than two Inches diameter will be radiographed and that pneunatic tests will be performed at 1.25 times the design pressure.
Contrary to the above, on Novenber 4,1987, the 26 Inch diameter energency diesel generator air intake piping depicted on isometric dBD-461-2 was installed as non-ASME material, the welds had not been radiographed and pneunatic tests had not been performed on the piping. These supplementary FSAR requirements had not been incorporated in the appilcable piping design and Installation specifications P-300, P-301-2, P-305 or P-323.
This is a Severity Level V Violation (Supplenent !!).
Response
PECo agrees with the violation as stated in the Inspection Report.
FSAR Section 3.2.2d provides the basis for classification of the off-skid portions of the diesel generator auxillary systans which were not originally designed to ASME Section III, Class 3 as Quality Group C equivalent (see Regulatory Guide 1.26) by inposing certain supplementary requirements. These included procuring ASME naterials, examining all pipe welds greater then 2 inches by radiography, and pnctrnatic testing all pipin'; to 1.25 times the design pressure. This section was included in the ?SAR in response to NRC RAI 430.75 during Unit 1 Ilcensing.
. Contrary to these supplementary requirements, ASTM materials were procured for the air intake and exhaust piping, welds on the air intake.(26" JBD-361) and exhaust (24" & 30" XRE-1XH) piping were not radiographed, the air intake piping has not been pneumatically tested, and the pneunatic test pressure used for other off-skid piping was 1.2 in lieu of 1.25 times the design pressure. Although the intake and exhaust piping do not completely meet the supplementary requirements in the FSAR, the adequacy of this piping as installed to perform the Intended design ftnction is confirmed by the following information:
Although the piping is non-ASME, it was installed to meet Seismic Category I requirements and the materials used are essentially equivalent to ASME material since they were procured to ASTM standards (considered identical If supplier holds a Quality System Certificate (QSC)) with Certifle:1 Materials Test Reports (CMTR).
Radiography is typically performed on piping welds to provide additional assurance that the weld performs in a manner equivalent to the base material (piping) being joined. ASME Section III, Class 3 specifies one examination by either RT, MT or PT for circunferent.lal welds, but does not require RT for any pipe sizes.
In fact, ASME Section III, Class 3 piping on Limerick is typically examined by MT or PT only. The original design code (ANSI B31.1) used for this piping also does not require NDE for this service and temperature. The pIptng for the air intake and exhaust lines are rolled and welded pipe.
In general, both ASME Section III, Class 3 and ANSI B31.1 apply a weld joint efficiency factor of 0.8 to single butt welded "longitudinal" and "circunferential" welds that have not been radiographed, thereby, reducing the allowable stress by 20%. The maximtm stress level calculated for the worst case design basis condition for the exhaust piping was 43% of the allowable. The maximtm stress level for the worst case design basis condition for the air intake piping was less than 1% of the allcwable.
Therefore, significant margin still exists even though radiography was not performed.
Welding was performed with procedures quallfled in accordance with ASME Section IX of the Boller and Pressure Vessel Code, as required by Quality Group C.
The lines were pnetmatically tested to mininun of 1.2 times the design pressure which is in accordance with ASME Section III, Class-3 requirements. A minimtm test pressure of 1.25 times is required for hydrostatic testing. Testing was not performed on the air Intake piping since the design pressure is belcw attrospheric (-1 psig).
The engines operate at nominally -7 in H O 2
pressure in this piping. The IIne has performed satisfactorily during diesel generator engine preoperational testing and subsequent operational tests.
Leak tightness has therefore been denonstrated during Initial service testing.
This type test is acceptable per the original design code (ANSI B31.1) for this piping.
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. 1 It can therefore be concluded that the piping is essentially equivalent to Quality Group C.
An FSAR Licensing Doctment Change Notice (LDCN) FS-1239 has been prepared and is being reviewed in accordance with our QA Plan requirements.
This LDCN will correct the description of the supplementary requirements for the off-skid portions of the emergency diesel auxillary systems.
A review of other off-skid portions of the emergency diesel auxiliary systems is being conducted to ensure that all required supplementary FSAR requirements have been met.
A keyword search of the FSAR was performed to find any other places where additional supplementary requirements had been Irroosed. The only others found were also in Section 3.2.
They were for the control rocm HVAC water chillers, the control structure chilled water piping, and the piping between the inboard and outboard contalrvnent isolation valves on the drywell chilled water systan. These items are presently under review to ensure that all the required supplementary requirements have been met. A nere detailed review is being conducted of Section 3.2 and the NRC Questions to further ensure that no additional supplanentary requironents were imposed without being addressed in the design docurents.
To assure this will not occur again, the LDCN fonn is being revised to require that any new ccomitments contained in an LDCN be IIsted, the design docunents which will inplement the new cmmitments be listed, and it be Indicated whether or not the new cmmitments have been incorporated into the appilcable design doctments.
In addition, the revised LDCN form will formally docunent the Bechtel re-review of any PECo ccoments by requiring a Bechtel sign-off. All appropriate personnel will be tralned to the use of the revised LDCN form when it is approved.
The above actions are expected to be fully camleted by March 31, 1988.
WJM/anv/01078805