ML20244D489
| ML20244D489 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/03/1989 |
| From: | Mcbrearty R, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20244D481 | List: |
| References | |
| 50-352-89-07, 50-352-89-7, GL-88-01, GL-88-1, NUDOCS 8904210367 | |
| Download: ML20244D489 (7) | |
See also: IR 05000352/1989007
Text
_ _ _ . - _ _ _ _ _ _ _ - _ _ _ _ _ _
..
..
l-
.
.
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-352/89-07
Docket No.
50-352
License No.
Priority
-
Category
C
Licensee:
Philadelphia Electric Company
P.O. Box 7520
Philadelphia, PA 19101
Facility Name:
Limerick Generating Station, Unit No.1
Inspection At:
Sanatoga, Pennsylvania
Inspection Conducted: March 6 - 10, 1989
Inspector : Naab/
_
4/3/87
Sw'R. A. McBrearty, Reactor Engineer
date
~
Approved by: NMA'DA/4L
M3 /8 9
J. R. 5trosnidef, Chief, Materials & Processes
' date ~
Section, EB, DRS
Inspection Summary:
Inspection on March 6-10, 1989, Report No. 50-352/89-07
Areas Inspected: A routine, unannounced inspection was conducted of the
licensee's inservice inspection activities to ascertain that the activities
were conducted in accordance with applicable ASME Code and regulatory
requirements.
In addition, the licensee's response to Generic Letter 88-01,
regarding inspections for stress corrosion cracking, was inspected.
Results: The inspector concluded, based on the areas inspected, that the
licensee's activities complied with applicable requirements. The licensee's
response to GL 88-01 was timely and addressed the areas required by the
Generic Letter.
I
5
8904210367 890
ADOCK 0
352
pg
Q
n
-
. _ .
__
_
. _ .
_
._.
-,
-
a
.
.
.
. Details
1.0 ' Persons Contacted
Philadelphia Electric Company (PECO)
T. L. Anderson, NDE Level III
!
K. Earle, Maintenance Engineer
(
- K. D. Folta, Quality Assurance Superintendent-
E. Gibson, Quality Support Superintendent
- T. C. Hinkle, Supervising Engineer
J. Hunter, Quality Engineer
- M. Logue, Technical Assistant
- M. T. - McCormick' Jr. , Plant Manager
D. Neff, Licensing Engineer
- N. A. Silvestri, Quality Assurance Auditor
- W. Sokro, Licensing Engineer
- J. W. Spencer, Superintendent - Maintenance /I&C
W. Texter, Staff Engin2er
General' Electric Company (G.E.)
M. A. Heath, NDE Level III
E. Reczek, NDE Level III
U.S. Nuclear Regulatory Commission
- T. J. Kenny, Senior Resident Inspector
- L. L. Scholl, Resident Inspector
2.0 Inservice Inspection Program (73051)
Inservice inspection is mandated'by the ASME B&PV Code,Section XI, and
the code edition applicable to a specific facility is identified by 10 CFR 50.55 a(g) based upon the issue date of its construction permit. .The
Limerick Unit 1 facility is committed to the 1980 edition of Section XI
through the winter 1981 addenda.
Section XI requires that the 40 year
life of each facility be divided into four 10 year inspection intervals
which, in turn, are divided into three equal 40 month periods. The
current refueling outage at Limerick is the second outage of the first 40
month period of the first 10 year inspection interval.
Section XI-identifies the components and welds which must be included in
the facility's ISI program and inspected withir: the 10 year interval. The
Code additionally mandates the minimum and maximum percentage of the program
l
which must be completed during each period of an interval.
l
- _ _ _ _ _ _
.
.
.
'
.
.
.
The licensee uses a computerized ISI data management system called In-Service
Inspection Control (ISIC), to assure compliance with the code requirements.
The system is used to establish examination schedules for outages, periods
and inspection intervals.
Section XI required items are included in the
data base, as are separate entries of items for which augmented examinations
are required by the NRC such as the Generic Letter 88-01 IGSCC program.
Items are tracked separately for each program in which they are entered
and the status of each program can be quickly determined.
In addition
to tracking status of complete and incomplete examinations, the system is
capable of determining the percentage of the program which is completed.
Reports, such as the Section XI summary report, are generated by the
system.
Each component is identified by system description, component
description, code category, required examination method and ND procedure.
The ISIC system was determined to be an excellent tool for complying with
ASME Code and regulatory requirements regarding Section XI and augmented
examination programs.
3.0 Nondestructive Examination Implementing Procedures (73052)
The following procedures were selected for inspection for compliance with
the ASME Code and regulatory requirements and for technical adequacy:
Procedure No. LP-PE-001, Revision 3, " Liquid Penetrant Examination
-
Procedure"
Procedure No MT-PE-001, Revision 1, " Magnetic Particle Examination
=
Procedure:
Procedure No. UT-PE-001, Revision 7, " Automatic Examination of
Similar and Dissimilar Metal Welds in Piping Systems"
Procedure No. UT-PE-001 Supplement 2, Revision 2, " Auto Examination
of Dissimilar Metal Welds and Butter Materials"
Procedure No. ESD-UT-2, Revision 1, " Technique for Determining the
-
Through Wall Dimension of Planer Flaws"
The inspector determined that the aforementioned procedures were in
compliance with the applicable ASME Code and regulatory requirements.
The procedures were approved by the licensee for use at Limerick, and
were determined to be technically adequate for their intended use.
No violations were identified.
'
I
L_____________________________
_
i
_.
_ _ _ _ _ _
. - _
_ _ _ _ _
.__
_ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
.
.
l
'
'
4
l
4.0 Observation of Work in Progress (73753)
The licensee's contractor, the General Electric Company performed ultrasonic
examinations at Limerick to comply with ASME Section XI ISI requirements
and with augmented examination requirements defined by Generic Letter 88-01.
The examinations were performed manually and with the use of the General
Electric Company " Smart UT" automated examination system.
The video tape of the " Smart UT" examination of the following welds was
selected for observation:
Recirculation System
Weld VRR-1RD-1A-N2H, -N2E and -N2K,12" diameter nozzle to safe end
Weld VRR-1RS-18-N1B, 28" diameter nozzle to safe end
l
Core Spray System
Weld DCA-319-1-N5A and -N5B, 12 " diameter nozzle to safe end
-
The recirculation system welds were examined using refracted longitudinal
wave at 45 and 60
The core spray system welds were examined using 45
and 60 shear waves.
A reflector indication was observed in the VRR-1RD-1A-N2H nozzle to safe
end weld and was evaluated as characteristic of IGSCC. The reflector is
located on the nozzle side of the weld in the NiCrFe Alloy 182 butter, is
connected to the ID surface and has an average depth of 18% through wall
over a 7 inch circumferential length. One area, 1/2 inch long, was
determined to have a 29% through wall depth.
That weld is the subject of
NCR #L89070-312 and was discussed at a meeting between the NRC Office of
Nuclear Reactor Regulation and the licensee as discussed in paragraph 6 of
this report.
The tapes of the ultrasonic examinations were of good quality and
permitted the A-scan to be reviewed by evaluation personnel outside
radiation areas and in conjunction with the ultra image display provided
by the " Smart-UT".
In addition to the above, the video tapes of selected underwater remote
visual examinations of rc sctor pressure vessel internals were observed to
assess the quality of the video tapes.
The inspections were documented
by visual inspection reports and the tapes are not the official record of
inspection.
The video tapes related to the visual examinations of the shroud
head / moisture separator and core spray piping and brackets displayed a
0.001 inch diameter wire to demonstrate that a flaw of that minimum size
could be identified by the inspection.
The inspection was performed with
hand held equipment and portions of the tape showed good quality and
- - - - _ _ _ - _ - - _ _ _ _ - _ _ - _ - _ _
_
N
. _ .
_
_
_
_
_ _ _ _ _ _ _ _ _ _ _
-
-
..
.-
.
5
1
clarity, but other portions were of questionable quality in:that focus
was poor as a result of what appeared to be an excessive rate of movement
of the equipment.
Because of the hand held feature of the equipment it
is difficult to maintain proper focus unless the camera is moved at an
'
extremely slow pace.
The inspector determined that the examination personnel were properly
qualified in accordance with the licensee's program.
In addition,
the ultrasonic examination personnel were listed by the latest issue of
the EPRI Registry for IGSCC Detection and Planar Flaw Sizing personnel
qualification. The General Electric Level III individuals were listed as
being qualified to analyze " Smart UT" data.
No violations were identified.
5.0 License Response to Generic Letter (GL) 88-01 (92703)
This Generic Letter applies to all BWR piping made of austenitic stainless
steel that is four inches or larger in nominal diameter and contains reactor
coolant at a temperature above 200 F- during power operation, regardless of
Code classification.
The letter also applies to reactor vessel attachments
and appurtenances such as jet pump instrumentation penetration assemblies
and head spray and vent components.
Licensees were requested to respond
to the GL within 180 days of the receipt of the letter.
The GL provides a
list of specific items which should be included by licensees to constitute
an acceptable response to the GL.
The technical bases for these positions are detailed in NUREG-0313,
Revision 2, " Technical Report on Material Selection and Guidelines for
BWR Coolant Pressure Boundary Piping".
NUREG-0313, Revision 2 describes
the technical bases for the staff positions on materials, processes, and
primary coolant chemistry to minimize and control IGSCC problems.
Inspection
schedules and inspection sample sizes are based on the susceptibility of
weldments to initiation and propagation of IGSCC.
Inspection schedules
l
are comparable to those specified in Section XI of the ASME B&PV Code in
cases where the piping material is IGSCC resistant.
The licensee's response to the GL dated August 2,1988, was reviewed by
,
the inspector to ascertain that applicable systems were identified, welds
'
l
. ere categorized and inspection schedules were established in accordance
w
l
with Table 1 of NUREG-0313, Revision 2.
The focus of the IGSCC mitigation program at Limerick has been to
p
minimize the amount of susceptible piping originally placed in the
plant. With only three exceptions, which are identified in the response,
the materials used in the Limerick facility are resistant due to their
chemical composition. Additionally, all of the longitudinal seam welds
in the resistant piping have been solution heat treated.
__-_____
_ _ _ - _ - - - - - _ _
h
.,
..
c.
.
,
.
6
The PECO water chemistry control requirements, detailed in BWR Chemistry
4
Control Program, Revision 0 dated December II, 1937, are in accordance
I
with the BWR Owners' Group and EPRI Water Chemistry Guidelines, existing
General Electric Chemistry recommendations and INPO recommendations.
'
<
Additional IGSCC mitigation measures taken by the licensee include
inspections and leakage detection.
The inspector determined that the licensee's response to the GL was
timely and addressed the five areas listed by the. letter, and further,
that the licensee has committed to comply with the NRC Staff positions as
' delineated in Generic Letter 88-01.
No violations were identified.
6.0 Engineering Support of Licensee Inservice Inspection Activities (73051).
The Nuclear Engineering Department (NED) provides support to inservice
inspection activities at.the site with regard to ISI findings which are.
determined to be rejectable per applicable acceptance criteria or require.
further evaluation to determine.their acceptability. Those items are.
reported by a Site Notification ISI Form and nonconformance report (NCR)
which is tracked.using the Quality Assurance Tracking and Trending System
(QATTS).
The NCR is submitted by the initiator to Nuclear Quality Assurance Quality
Support (NQAQS) where a sequential number is assigned, logged and entered
in the tracking system. The need for root cause analysis and trending is
also determined based upon the nature of the nonconformance.
Nuclear Engineering is responsible for providing a disposition and corrective
action and has the option to delegate the responsibility to site Maintenance
Engineering if the site group has the expertise to perform the function.
The Engineering disposition is subject to review and approval by NQA as is
the performance of corrective work.
The engineering department, in addition to providing a disposition and
corrective action, is responsible for determining whether a safety evalua-
tion is required or whether an existing safety evaluation is 'affected by
the disposition.
Upon completion of corrective action NQA verifies that required actions
are acceptable and closecut of the NCR is accomplished by the appropriate
NQA signature. A list of open NCRs is generated periodically and reviewed
by appropriate levels of management to assure that start up from an outage
is not accomplished with plant systems inoperable because of open NCRs.
Administrative Guide 15 requires NQA signature indicating that open items
are properly closed prior to initiating a reactor mode change.
!
i_____________________ . _ _ _ _
_
]
_
p,
~
}
]
o s
.-
)
.- +
>
,
.
.
,
NCR #L89070-312 which documents the ultrasonic indication detected in RPV
nozzle to safe end weld number VRR-1RD-1A-2NH was selected for inspection
to ascertain that the licensee's program for processing NCRs was followed.
!
The NCR was prepared by site maintenance engineering which provided three
corrective action options for the reported condition.
Nuclear engineering
was requested to recommend and approve one of the options for implementation.
At the. time of this inspection NED had not documented its option selection.
_
The item was the subject of an NRR/ licensee meeting at Rockville, Maryland
scheduled to be held on March 15, 1989. The licensee proposed using an
electronic system to monitor the condition of the weld during plant operation.
That NCR remained open pending documentation of the selected corrective
action, completion of the action and NQA sign off following verification
that the corrective action was completed.
No violations were identified.
7.0 Quality Assurance Involvement in Inservice Inspection Activities (73051)
Licensee audit No. LA89001 of General Electric Company and licensee inservice
inspection activities was selected for inspection to ascertain that the
audit included. appropriate vendor activities, and that it was performed in
accordance with the licensee's program.
The audit included a review of
NDE Procedures and~the observation of twenty (20) weld examinations.
It
performed at the Limerick Generating Station, Unit 1 and at the Valley
Forge NDE Service Branch by the licensee's Nuclear Quality Assurance group
'
from January 24, 1989 through February 17, 1989.
The procedure review was performed to ascertain compliance with
applicable ASME Code requirements and the observations were made to
assess activity compliance with the applicable procedure.
The licensee's auditor concluded that the Limerick Unit 1 ISI Program meets
ASME code requirements and is being effectively implemented.
Based on his
independent review of NDE procedures and observation of weld examinations
the NRC inspector agreed with the auditor's conclusion.
No. violations were identified.
8.0 Exit Meeting
The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on March 10, 1989.
The inspector
summarized the scope and findings of the inspection.
At'no time during the inspection was written material provided by the
inspector to the licensee.
The licensee did not indicate that proprietary
information was involved within the scope of this inspection.
8
__._.__.
________..______m
. _ _ _ _ _ _ _ - _ _ _ _
. _ . . _ . . . _ _ .