ML20214K069
| ML20214K069 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/14/1986 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Butler W Office of Nuclear Reactor Regulation |
| References | |
| CON-#386-415 OL, NUDOCS 8608180023 | |
| Download: ML20214K069 (7) | |
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PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 AUG 141986 msi s4i-4so2 V IC E-PR E SI D E NT sseeemannene ano massances Mr. Walter R. Butler, Director Docket No.:
50-352
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BWR Project Directorate No. 4 Division of BWR Licensing
Subject:
Limerick Generating Station Unit 1 First 10-Year Interval Inservice Inspection Program Request for Additional Information
Reference:
Letter, W. R. Butler (NRC) to E. G. Bauer, Jr. (PECo),
dated June 17, 1986
Attachment:
Request for Additional Information LGS-1 First 10-Year Interval ISI Program Files:
GOVT 1-1 (NRC)
GEN 5-1 (P-500)
Dear Mr. Butler:
e The reference letter forwarded requests for additional information concerning the Inservice and Augmented Inservice Inspection Programs for the first 10-year interval of operation of the Limerick Generating Station Unit 1.
The attachment to this letter provides either the requested information or a date when the information will be completed and forwarded to the NRC Staff.
Should additional information be required in the interim, please do not hesitate to contact us.
Sincerely, s
h O
DLS/pdO7318601 Copy to:
See Attached Service List
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cc: Troy B. Conner, Jr., Esq.
Benjamin M. Vogler, Esq.
Mr. Frank R. Romano Mr. Robert L. Anthony Ms. Maureen Mulligan Charles W. Elliot, Esq.
Barry M. Hartman, Esq.
Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus R. Love, Esq.
David Wersan, Esq.
Robert J. Sugarman, Esq.
Katt.ryn S. Lewis, Esq.
Spence W. Perry, Esq.
Jay M. Gutierrez, Esq.
Atomic Safety & Licensing Appeal Board Atomic Safety S Licensing Board Panel Docket & Service Section Mr. E. M. Kelly Mr. Timothy R. S. Canpbell s
ATTACFNENT Request for Additional Information LGS-1 First 10-Year Interval ISI Program The following is provided in support of the NRC Staff's review of the Unit 1 First 10-Year Interval Inservice Inspection Program (ISI Program), Specification 8031-P-500, and the Unit 1 First 10-Year Interval Augnented Inservice Inspection Program (Augnented ISI Program), Specification 8031-P-501. The staff's requests for additional information are restated below followed by our response.
Request A.
Provide the staff with an itemized listing of the conponents subject to examination during the first 10-year Interval. The requested ilsting will permit the staff to determine if the extent of ISI examinations meets the applicable Code requirements.
Response to A.
The determination that the extent of the planned ISI examinations meets the applicable ASME Section XI Code requirements should be based on the Tables and referenced Notes included in the ISI Program. As always, additional examinations may be required in accordance with ASME Section XI, IWB,C,D,F-2430.
To facilitate the staff's review, an itemized listing of the c mponents selected for examination during the first 10-year Interval, presently in the course of preparation, will be provided on or before January 31, 1987.
Request B.
Based on the 74S75 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 sys4 ems from inservice examinations when both the design pressure and temperature are equal to or less than 275 psig and 200F, l
respectively.
10CFR50.55aCbX2Xiv) 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 volunetric examination based on the 74S75 Section XI exclusion criteria contained in IWC-1220. The staff points out j
that later edition and addenda of the Code does not permit the i
temperature / pressure exclusion for these systems. To satisfy the l
inspection requirements of General Design Criteria 36, 39, 42, and 45, the inservice Inspection program must include volunetric examination of a representative sample of welds in the RHR, ECCS, and CHR systems.
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ATTACtf4ENT Reque t for Addition 1 InfonnatIon LGS-1 First 10-Year Interval ISI Program Response to B.
Sections 1.4 and 3.1.A of the ISI Program, meet the regulatory requirements of 10CFR50.55aCbX2XIv) in that the inspections required per GDC 36, 39, 42 and 45 will be perfonned using voltsnetric, surface and/or visual examination techniques as applicable.
10CFR50.55a(bX2Xiv) requires that AstE Code Class 2 pressure retaining piping welds in RHR, ECCS and CHR systems shall be examined and that the extent of the welds selected for examination shall be in accordance with IWC-1220, IWC-2520 and IWC-2411 of the 74/S75 edition of ASME Section XI.
A review of the ISI Program Table 3.0-3 and the ISI PSID's will verify that'the RHR, ECCS and CHR systems have not been completely exempted from inservice inspections and that volunetric examinations will be performed on a representative sample of welds in these systems.
Request C.
Sections 2.5.3(3) and 3.5.3(3) state that ultrasonic examinations of Class 1 and Class 2 pipe components shall be in accordance with Section XI, IWA-2230 and Appendix III including Supplement 7 for wolds 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 affect'ed 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.
Resoonse to C:
The items in C.1 and C.2, above, are consistent with the practices established during the Unit 1 preservice inspection and will be carried through as inservice inspection requirements. The ISI Program, Sections 2.2.3(4), 2.5.3(3) and 3.5.3(3), applicable to the volunetric examination of either ferritic or austenitic safe end and piping welds, will be revised to require:
ATTACl+1FNT Request for Additional Information LGS-1 First 10-Year Interval ISI Program 1.
Any indication detected in the weld, heat affected zone or adjacent base metal not readily attributable to geometry will be recorded regardless of ultrasonic amplitude and investigated by a Level II or Level III examiner to the extent necessary to detennine the shape, identity and location of the indication.
2.
PECo will d!sposition and take the appropriate corrective action for any indication investigated and evaluated to be other than geometrical or metallurgical in nature.
The above revision to the ISI Program will be provided on or before January 31, 1987.
Request D.
Provide clarification on Relief Request 2.7.3 for class I circunferential 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 ccmponent base material adjacent to the weld when using the same calibration techniques. This justification is not appitcable for i,
the Code-required surface examination. Table 2.0-4 shows the subject weld (RC-131) as receiving both surface and volunetric examinations with relief being requested for the augmented volunetric examination. Verify that relief is being requested only for the augmented ISI volunetric examination.
Response to D.
A review of the ISI Program, Section 2.7.3.3 and Table 2.0-4 will verify that Relief Request 2.7.3 is applicable only to the Ilmited portion of the augmented ISI volunetric examination and that this examination will be performed to the maximun extent possible. A complete Code required surface examination is achievable and will also be perfonned.
For further clarification, requests for relief that are applicable to augnented ISI requirements will be deleted frcm the ISI Program and included in the Augmented ISI Program. The revision to both the ISI and Augmented ISI Programs will be provided on or before January 31, 1987.
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ATTACFNENT Request for Additionni Information LGS-1 First 10-Year Interval ISI Program Request E.
Table 3.0-4, Note 4, states that the component / weld nunbers listed in the table for relief request 3.7.2 include, but are not Ilmited to, all piping supports with integral attachment welds and. removable pipe clanps 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 ccmponents for which relief is being requested for the first 10-year Interval and include the percentage of the Code-required examination that can be ccmpleted for each 'of these ccmponents.
Response to E.
fable 3.0-4 and Note 4 of the ISI Program will be revised to identify those piping integral attachnent welds for which relief is requested. Pursuant to ReIIef Request 3.7.2, relief is only requested for the obstructed portion of the weld. The Code required examination will be performed to the maximtm extent possible. Although Table 3.0-4 provides a percentage of completion of the Code required examination, these are only estimates based on PSI experience. The exact percentage of completion cannot be detennined until the examinations are performed during che ISI.
Any changes to a request for relief will be made in accordance with 10CFR50.55a(gX5Xiv). The revisions to Table 3.0-4 and Note 4 will be provided on or before January 31, 1987.
Request 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 and B contained shrinkage cracks that could ccmpromise 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 doctmented for similar valves at other plants.
In a letter to the staff dated October 12, 1984, the Utility conmitted 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._
r ATTACl-NENT Request for Additional Information LGS-1 First 10-Year Interval ISI Program Inservice Inspection Program includes the examination requirements of the 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 exanination. The IIcensee should include the augnented surface examination (either liquid penetrant or magnetic particle) as per the conmitment in the October 12, 1984 letter the to staff.
Response to F.
Section 3.5 of the Augnented ISI Program wl!1 be revised to include surface examinations (either magnetic particle or liquid penetrant) of both the Internal and external valve body surfaces of feedwater check valves HV-41-1F074A and B.
The augmented inspections will be performed during the first refueling outage.
Subsequent inspections will be in accordance with the ISI Program. The revision to Section 3.5 will be provided on or before January 31, 1987.
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