ML20244D489

Insp Rept 50-352/89-07 on 890306-10.No Violations Noted. Major Areas Inspected:Inservice Insp Activities to Ascertain Activities Conducted Per Applicable ASME Code & Regulatory Requirements & Licensee Response to Generic Ltr 88-01

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: ML20244D478 ML20244D489
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

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-352/89-07

Docket No. 50-352

License No. NPF-39 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.

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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.

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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:

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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"

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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. '

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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

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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

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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

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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

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the inspector to ascertain that applicable systems were identified, welds

l .were categorized and inspection schedules were established in accordance

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.

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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

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< 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.

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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.

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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.

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