ML20247G550
| ML20247G550 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick, 05000000 |
| Issue date: | 07/21/1989 |
| From: | Kowalski S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1344 GL-89-08, GL-89-8, NUDOCS 8907280105 | |
| Download: ML20247G550 (6) | |
Text
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10 CPR 50.54(f) f ;,
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-PHILADELPHIA ELECTRIC COMPANY 23o1 MARKET STREET P.O. BOX 8699 PHILADELPHIA A. PA.15 HOI
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(215) 841-4502 S. J. KOWALSKI VICE PRESIDENT i
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July 21, 1989 Docket Nos. 50-277 l
50-278 50-352 50-353 License Nos. DPR-44 DPR-56 NPF-39 NPF-84 i
.U.S.
Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 1
SUBJECT:
Peach Bottom Atomic Power Station Units 2 and 3 Limerick Generating Station Units 1 and 2 Generic Letter 89-08, " Erosion / Corrosion - Induced
. Pipe Wall Thinning"
' Gentlemen:
J NRC Generic Letter (GL) 89-08, " Erosion / Corrosion - Induced j
Pipe Wall Thinning," dated May 2, 1989, required Philadelphia l
Electric Company (PECo) to submit a response, as specified in 10 CFR l
50.54(f), providing assurances that a program, consisting of systematic measures to ensure that erosion / corrosion does not lead to degradation of single phase and two phase high-energy carbon steel systemu has been or will be implemented at our nuclear stations.
GL 89-08 also directed that our response should include information on whether or not we have implemented or intend to implement a long-term erosion / corrosion monitoring program that provides assurances that procedures or administrative controls are
.in place to assure that'the Nuclear Utility Management and Resources Council (NUMARC) program or other equally effective program is Aool 8907280105 890721 PDR ADOCK 05000277 I
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i'Docum5nt.ControlEDesk July 21, 1989 i
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Q Implementedandthestructuralintegrityofallhigh.energycarbbn 1
-steel systems is' maintained.
Our' response,:provided in-the attachment, gives otir'
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assurance,that a program, composed'of procedures, assures long-term
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implementation of erosion / corrosion monitoring of appropriate piping I
.and components. ~Furthermore,-program enhancements, described in the atthched response, will be accomplished in a timely manner.
If you-have any questions, or require additional information, please contact us.
l very truly yours,
-Attachment
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cc:
, W. T< Russell', Administrator, Region I, USNRC
'P. Johnson, USNRC Senior Resident Inspector, PBAPS T.
T; J.. Kenny, USNRC Senior Resident Inspector, LGS T..,E. Magette, State of-Maryland J.. Urban,'Delmarva Power R. A. Burricelli,-Public Service' Electric'& Gas H. C. Schwemm,. Atlantic Electric-T. M. Gerusky, Commonwealth of-Pennsylvania
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A COMMONWEALTH OF PENNSYLVANIA :
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. CHESTER COUNTY S. J..Kowalski, being first' duly sworn, deposes and says:
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l That.he is Vice' President-~of Philadelphia Electric Company; i
the Applicant herein; that he has read the foregoing response to Generic. Letter 89-08, and knows the contents thereof; and that the
- statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
A' t
Vice President l
Subscribed and sworn to N
before nie this1I day of 2
- 1989.
,/LYTkEh/sd]Ye ll &nbs Notary Public NOTARIAL SEAL CATHERINE A MENDEL Notary Public Media Boro. Delaware Co.'
My Commiss!on Expires Sept 4,1989 1
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I ATTACHMENT l
PEACH BO'1"POM ATOMIC POWER STATION, UNITS 2 AND 3 LIMERICK GENERATING STATION, UNITS 1 AND 2 RESPONSE TO NRC GENERIC LETTER 89-08
" EROSION / CORROSION - INDUCED PIPE WALL THINNING" l
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RESPONSE
The Philadelphia Electric Company does have an j
established long-term erosion / corrosion monitoring a
program for Limerick Generating Station (LGS), Units 1 j
and 2, and for Peach Bottom Atomic Power Station I
(PBAPS), Units 2 and 3.
The programs assure that the structural integrity of high-energy single-phase and two phase carbon steel systems is maintained.
The Limerick Generating Station Erosion / Corrosion Program is described in Specification P-508, " Nuclear Engineering Department Specification for Limerick j
Generating Station Units 1 and 2 - Program for Monitoring Pipe for Wall Thinning due to Erosion / Corrosion."
This specification is in place and being implemented.
It provides criteria for the following:
o Identifying the single phase and two phase lines to be included in the program.
o Selecting the single-phase and two phase inspection locations.
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Determining the frequency of inspections.
o o
Determining appropriate acceptance criteria.
o Calculating the estimated remaining life of pipe and fittings.
o Determining the method of_ inspections.
o Determining necessary corrective actions.
I Furthermore, the LGS specification includes Appendices which:
o identify the single phase and two phase lines included in the program, i
identify pipe and fittings to be inspected, o
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PECo Response'.tof89-08 Attachment
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Page 2 Lo provide a five-cycle inspection schedule, and o
provide acceptance criteria.
I The-Peach Bottom' Atomic Power Station-Erosion / Corrosion-Program-is described in the
" Maintenance' Department Program for Peach Bottom Atomic Power. Station Units 2 and'3 - Inspection of-Piping Subject to Erosion / Corrosion."
This program is' in place and is being implemented.. The,PBAPS program provides~information similar to:what is.provided in the appendices of the LGS Specification; however, it does not provide the detailed engineering. criteria j
which is contained.in the LGS Specification._ In order to provideouniformity in. the programs at both' LGS and-
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PBAPS, the PBAPS' program is^being revised and will.be reissued as Specification M-721, " Nuclear Engineering Department Specification for Peach Bottom Atohtic Power Station Units-2 and.3 - Program;for Monitoring Pipe' l
for Wall Thinning:due to Erosion / Corrosion."' This' Specification will be issued for use by August 31, 1990, which is approximately four months prior to the 4
next PBAPS Unit 2 refueling outage.
A common inspection procedure is used at LGS and'PBAPS T
for;the ultrasonic'(UT) detection of erosion / corrosion in piping systems. ;This procedure'is NDE-SP-3, "NDE Services Special Procedure for the Ultrasonic Detection?cf Erosion / Corrosion.in Piping Systems."
It provides' criteria for the following:.
o Marking pipe and fittings to be inspected.
o Performing UT inspections.
o Documenting inspection results.
Inspections are performed using calibrated equipment and qualified and trained personnel.
. Baseline inspections of pipe and fittings in single-
.phaca flow locations have been performed.at LGS Units 1 and 2 and PBAPS Units 2 and 3.
Baseline inspections i
and several follow-up inspections of pipe and tittings J
in many two phase flow locations have been performed at LGS Unit 1 and PBAPS Unita 2 and 3.
Baseline inspections of some two-phase flow locations are m
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PECo. Response to 89-08 Attachment Page 3
-scheduled to be performed at LGS Unit.2 prior to-commercial operation.
i In addition to having established.long-term 4
eros' ion / corrosion monitoring programs at each of our
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nuclear. units, we have used upgraded material when replacing pipe.and fittings and have improved water chemistry to reduce erosion and corrosion rates.
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CONCLUSION:
- The Philadelphia Electric Company is implementing long-term erosion / corrosion monitoring programs at its Peach Bottom Atomic Station-and' Limerick Generating ~
1 Station.
These programs provide assurance that administrative' controls are in place to assure that the NUMARC program is implemented and that the j
structural integrity of high energy piping systems is I
maintained in accordance with the intent of NUREG-l 1344, " Erosion / Corrosion-Induced Pipe Wall Thinning in l
U.S. Nuclear Power Plants."
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