ML20206J031
| ML20206J031 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/17/1986 |
| From: | Butler W Office of Nuclear Reactor Regulation |
| To: | Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8606260386 | |
| Download: ML20206J031 (7) | |
Text
. =.
e DISTRIBUTION gD5EEE TTTe7 RMartin:lb Docket No. 50-352
'NRC~PDR ~
N0'Brien LPDR ACRS(?O)
PD#4 Rdg.
BTurovlin RBernero RGallo Mr. Edward G. Bauer, Jr.
Vogler, OELD Vice President and General Counsel Edordan Philadelphia Electric Company BGrimes 2301' Market Street JPartlow Philadelphia, Pennsylvania 19101 NThompson
Dear Mr. Bauer:
SUBJECT:
LIMERICK GENERATING STATION UNIT 1 REQUEST FOR ADDITIONAL INFORMATION ON THE FIRST TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM The staff is reviewing the Inservice Inspection Program for the first ten-year interval of operation of the Limerick Generating Station, Unit 1.
Technical assistance for this effort is being provided by the Idaho National Engineering Laboratory. We request that a timely response be provided to the enclosed 2
request for additional information in order that we may complete our review.
We request that your response be provided within forty-five days of your receipt of this letter.
If you should have further questions concerning this
}
matter please contact the Project Manager, Mr. R. E. Martin, j
Sincerely, l
Original egned by Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing cc: See next page
.i i
, #4 k PD#4/D tin:1b WButler p i
/86 06/
/86 L
pgg62gggggt88yg2 0
at KEG h
[
o UNITED STATES 8'
- ' #^
NUCLEAR REGULATORY COMMISSION h
- E WASHINGTON, D. C. 20555
/
JUN 171986 Docket No. 50-352 Mr. Edward G. Bauer, Jr.
Vice President and General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101
Dear Mr. Bauer:
SUBJECT:
LIMERICK GENERATING STATION UNIT 1 REQUEST FOR ADDITIONAL INFORMATION ON THE FIRST TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM The staff is reviewing the Inservice Inspection Program for the first ten-year interval of operation of the Limerick Generating Station, Unit 1.
Technical l
assistance for this effort is being provided by the Idaho National Engineering Laboratory. We request that a timely response be provided to the enclosed request for additional information in order that we may complete our review.
We request that your response be provided within forty-five days of your receipt of this letter.
If you should have further questions concerning this matter please contact the Project Manager, Mr. R. E. Martin.
Sincerely, Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing cc: See next page
Q Mr. Edward G.- Bauer, Jr Limerick Generating Station l
Philadelphia Electric Company Units 1 & 2 i
cc:
Troy B. Conner, Jr., Esquire Chairman Board of Supervisors of Conner and Wetterhahn Limerick Township 1747 Pennsylvania Ave, N.W.
646 West Ridge Pike Washington, D. C.
20006 Limerick, Pennsylvania 19468 Barry M. Hartman Frank R. Romano, Chairman.
Office of General Counsel Air & Water Pollution Patrol Post Office Box 11775 61 Forest Avenue Harrisburg, Pennsylvania 17108 Ambler, Pennsylvania 19002 Federic M. Wentz Dept. of Environmental Resources l
County Solicitor ATTN: Director, Office Radiologic County of Montgomery Health Courthouse P. O. Box 2063 Norristown, Pennsylvania 19404 Harrisburg, Pennsylvania 17105 Mr. John Franz, Plant Manager Ms. M. Mulligan Limerick Generating Station Limerick Ecology Action Post Office Box A 762 Queen St.
Saratoga, Pennsylvania 19464 Pottstown, Pennsylvania 19464 Mr. Karl Abraham Thomas Gerusky, Director Public Affairs Officer Bureau of Radiation Protection Region I Dept. of Enviromental Resources U.S. Nuclear Regulatory Commission 5th Floor, Fulton Bank Bldg.
4 631 Park Avenue Third and Locust Streets King of Prussia, PA 19806 Harrisburg, Pennsylvania 17120 4
Mr. Gene Kelly Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 47 Sanatoga, Pennsylvania 19464 Governor's Office of State Planning and Development ATTN: Coordinator, Pennsylvania State Clearinghouse P. O. Box 1323 Harrisburg, Pennsylvania 17102 i
N Philadelphia Electric Company Limerick Generating Station 1/2 cc:
Director, Pennsyivania Emergency Angus Love, Esq.
Management Agency 107 East Main Street Basement,. Transportation &
Norristown, Pennsylvania 19402 Safety Building Harrisburg, Pennsylvania 17120 Helen F. Hoyt, Chairman Administrative Judge Robert L. Anthony Atomic Safety & Licensing Board Friends of the Earth U.S. Nuclear Regulatory Commission of the Delaware Valley Washington, D. C.
20555 103 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Dr. Jerry Harbour Administrative Judge Atomic Safety & Licensing Board Kathryn S. Lewis, Esq.
U.S. Nuclear Regulatory Commission Municipal Services Bldg.
Washington, D. C.
20555 15th and JFK Blvd.
Philadelphia, Pennsylvania 19102 Dr. Richard F. Cole Administrative Judge David Wersan, Esq.
Atomic Safety & Licensing Board Assistant Consumer Advocate U.S. Nuclear Regulatory Commission Office of Consumer Advocate Washington, D. C.
20555 1425 Strawberry Square Harrisbcrg, Pennsylvania 17120 Mr. Spence W. Perry, Esq.
Associate General Counsel Federal Emergency Management Agency Room 840 500 C Street, S.W.
Washington, D. C.
20472 Mr. J. T. Robb, NS-1 Philadelphia Electric Company 2301 Market Street Philadelphia, Pennylsvania 19101 Timothy R. S Campbell, Director Departnent of Emergency Services 14 East Biddle Street I
West Chester, Pennsylvania 19380-f
o i
UNITED STATES g
NUCLEAR REGULATORY COMMISSION g
g j
WASHINGTON. D. C. 20555 y
o,,
h,c
....+
4 PHILADELPHIA ELECTRIC CO.
LIMERICK GENERATING STATION, UNIT 1 DOCKET NUMBER 50-352 ENGINEERING BRANCH DIVISION OF BWR LICENSING Request for Additional Information - First 10-Year Interval Inservice Inspection Program
- 1. Scope / Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which are classified as ASME Code Class 1, Class 2, and Class 3 meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components.
This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during the initial 120-month inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the date of g#
issuance of the operatind license, subject to the limitations and m,odifications listed therein.
The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein.
Based on the Operating License date of August 8,1985, the Licensee has prepared the ISI Program in compliance with the requirements of the 1980 Edition, Winter 1981 Addenda (80W81) of ASME Code Section XI except that the extent of examination for the Residual Heat Removal Systems (RHR), Emergency Core Cooling Systems (ECCS), and Containment Heat Removal Systems (CHR) shall be determined by the 1974 Edition, Summer 1975 Addenda (74575) of Section XI of the ASME Code.
The staff has reviewed the available information in Document No. 8031-P-501, Limerick Generating Station Unit 1 First 10-Year Interval Augmented Inservice Inspection Program, through Revision 1,
,and Document No. 8031-P-500, Limerick Generating Station Unit 1 First Year Interval Inservice Inspection Program, through Revision 1, including the associated requests for relief from ASME Code Section XI requirements which the Licensee has determined to be impractical to perform at Limerick Generating Station, Unit 1.
l i
o 1
2
- 2. Staff Evaluation Based on the above review, the staff has concluded that the following information and\\or clarification is required in order to complete the 1
review of the Inservice Inspection Program Plan:
A.
Provide the staff with an itemized listing of the components subject to examinatior. during the first 10 year interval. The l
l requested listing will permit the staff to determine if the extent of ISI examinations meets the applicable Code requirements.
B.
Based on the 74575 Section XI exclusion criteria contained in
]
IWC-1220, the Limerick First 10-Year Interval ISI Program, Section 3.1 A.(1) exempts components in the RHR, ECCS, and CHR systems from inservice examinations when both the design pressure and temperature are equal to or less than 275 psig and 200*F,
=
respectively.
10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2 piping welds in the RHR, ECCS, and CHR systems shall be examined.
These systems should not be completely exempted from inservice volumetric examination based on the 74575 Section XI exclusion criteria contained in IWC-1220. The staff points out that later edition and addenda of the Code does not permit the temperature / pressure exclusion for these systems. To satisfy the inspection requirements of General Design Criteria 36, 39, 42, and 45, the inservice inspection program must include volumetric examination of a representative sample of welds in the RHR, ECCS, and CHR systems, C.
Sections 2.5.3(3) and 3.5.3(3) state that ultrasonic examinations a*
of Class 1 and Class,'2 pipe components shall be in accordance with Section XI, IWA-2230 and Appendix III including Supplement 7 s
for welds in austenitic materials. Weld reflectors producing a response greater than 50% of the reference level shall be recorded.
When using either Article 5 of Section V or Appendix III of Section XI for examination of either ferritic or austenitic piping welds, the following should be incorporated into the examination procedure:
1.
Any crack-like indication, regardless of ultrasonic amplitude, discovered during examination of piping welds, heat affected zone or adjacent base metal should be recorded and investigated by a Level II or Level III examiner to the extent necessary to determine the shape, identity, and location of the reflector.
2.
The Owner should evaluate and take corrective action for the disposition of any indication investigated and found to be other than geometrical or metallurgical in nature.
N..
3 4
D.
Provide clarification on Relief Request 2.7.3 for Class 1 circumferential welds <4 inch NPS.
ASME Section XI, Table IWB-2500-1, Examination Category B-J, Item 9.21 requires a 100%
surface examination on the subject welds. The justification for relief (Section 2.7.3.2) states that the examination is restricted as non parallel OD and ID surfaces in certain valve and fitting designs may preclude complete Code coverage of the component base material adjac6nt to the weld when using the same calibration techniques.
This justification is not applicable for I
the Code-required surface examination.
Table 2.0-4 shows the subject weld (RC-131) as receiving both surface and volumetric examinations with relief being requested for the augmented volumetric examinatio,n. Verify that relief is being requested only for the augmented ISI volumetric examination.
E.
Table 3.0-4, Note 4, states that the component / weld numbers listed in the table for relief request 3.7.2 include, but are nst limited to, all piping supports with integral attachment welds and removable pipe clamps that may be included in Examination Category C-C, Item C3.20..This note also states that the integral attachment welds are listed only to demonstrate the generic nature of the relief request.
The Licensee should provide a complete listing of the components for which relief is being requested for the first 10 year interval and include the i
percentage of the Code-required examination that can be completed for each of these components.
F.
During the staff's review of the final Safety Analysis Report for the Limerick Generating Station in 1983 and 1984, the staff determined that the two cast bodies for the feedwater check
- valves HV-41-1F074A ahd B contained shrinkage cracks that could
/ compromise the valves' conformance with GDC-51 if the cracks were to propagate while in service. Such propagation of shrinkage cracks has occurred in the past and has been documented for.
similar valves at other plants. In a letter to the staff dated October 12, 1984, the Utility committed to an augmented inservice inspection program for these feedwater check valves which would include inspection of the entire surface of the valve bodies, both internal and external, by surface or other examination techniques acceptable to the staff.
The staff notes that the Limerick Generating Station Unit 1 first 10 year Augmented Inservice Inspection Program includes the examination requirements of ASME Code Section XI, Examination Category B-M-2, Item No. B12.50, which requires visual examination.
The staff considers this a Code examination rather than an augmented surface examination. The licensee should include the augmented surface examination (either liquid penetrant or magnetic particle) l as per the committment in the October 12, 1984-letter to the staff.
The Licensee should respond to the above staff concerns as soon as possible so that the review of the Inservice Inspection Program Plan can be completed.
l
_. _.