LR-N05-0240, Inservice Inspection Program Relief Request S2-13-RR-F01
| ML051250366 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/24/2005 |
| From: | Perino C Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N05-0240 | |
| Download: ML051250366 (7) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 APR 2 4 2005 LR N05-0240 NuclearLLC United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-001 INSERVICE INSPECTION PROGRAM RELIEF REQUEST S2-13-RR-FOI SALEM GENERATING STATION UNIT 2 FACILITY OPERATING LICENSE DPR-75 DOCKET NOS. 50-311
Reference:
LR-N05-0168, RELIEF REQUEST S2-13-RR-F01, Snubber Testing and Inspection, dated April 8, 2005.
The reference letter transmitted relief request S2-13-RR-F01, Snubber Testing and Inspection and requested relief from ASME Section Xl, IWF-5300 (a) and (b). On April 22, 2005, as a result of discussion with the NRC staff, it was determined that relief from IWF-5300 (c) is also necessary. Attachment 1 to this letter replaces, in its entirety, the previously submitted relief request.
Should you have any questions regarding this request, please contact Mr. Michael Mosier at 856-339-5434.
Sincerely,~
Chritna nrL Director - Regulatory Assurance
Attachment:
ISI Relief Request S2-13-RR-F01L 4Vz4'~
95-2168 REV. 7/99
Document Control Desk APR 2 4 2005 LR-N05-0240 C
Mr. S. Collins, Administrator-Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission ATTN: Mr. D. Collins, Licensing Project Manager - Hope Creek/Salem Mail Stop 08C2 Washington, DC 20555-0001 USNRC Senior Resident Inspector - Salem (X24)
Mr. K Tosch, Manager IV Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 08625
Document Control Desk Attachment I LR-N05-0240 Relief Request S2-13-RR-F01 Snubber Testing and Inspection Proposed Alternative In Accordance with 10 CFR 50.55a(a)(i)
-- Alternative Provides Acceptable Level of Quality and Safety --
2. Applicable Code Edition and Addenda
1998 Edition, including 2000 Addenda
3. Applicable Code Requirement
Paragraphs IWF-5200(a) and IWF-5300(a) require Preservice and Inservice examinations to be performed in accordance with ASME/ANSI OM, Part 4, using the VT-3 visual examination method described in IWA-2213. Additionally, Paragraphs IWF-5200(b) and IWF-5300(b) require Preservice and Inservice tests to be performed in accordance with ASME/ANSI OM, Part 4. Table IWA-1600-1 specifies use of the 1987 Edition, with OMA-1988 Revision of ASME/ANSI OM, Part 4. Paragraph IWF-5300(c) requires integral and non-integral attachments for snubbers, including lugs, bolting pins and clamps to be visually examined in accordance with ASME Xi Subsection IWF.
The regulation in 10 CFR 50.55a(b)(3)(v) permits the use of Subsection ISTD, titled 'Inservice Testing of Dynamic Restraints (Snubbers) in Light-water Reactor Power Plants,' ASME OM Code, 1995 Edition up to and including the 1998 Edition with the 2000 Addenda, in lieu of the requirements for snubbers in Section Xl, IWF-5200(a) and (b) and IWF-5300(a) and (b), by making appropriate changes to their technical specifications or licensee controlled documents.
Preservice and inservice examinations shall be performed using the VT-3 visual examination method described in IWA-2213.
- 4. Proposed Alternative Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative provides an acceptable level of quality and safety.
PSEG Nuclear LLC (PSEG) requests the use of Plant Systems Technical Specification (TS) 3/4.7.9, Snubbers, and associated bases, as found within the Salem Nuclear Generating Station Unit 2 TS.
Document Control Desk Attachment I LR-N05-0240 Relief Request S2-13-RR-FOI Snubber Testing and Inspection Proposed Alternative In Accordance with 10 CFR 50.55a(a)(i)
- Alternative Provides Acceptable Level of Quality and Safety --
- 5. Basis of Alternative for Providing Acceptable Level of Quality and Safety The Salem Generating Station Unit 2 TS contain specifically developed and approved visual examination and functional testing requirements.
Performance of examinations and testing to the requirements of the TS meet the intent of the ASME Code requirements. However, use of the Technical Specification differs in the areas of examination scheduling, re-examinations and functional testing requirements. Visual examination and testing to the more stringent requirements of the TS will continue to result in an increase in the overall level of Plant quality and safety.
These mechanical and hydraulic snubbers were constructed and installed in accordance with the requirements of the Salem UFSAR. Documentation of fabrication and installation examinations is stored at the plant site. Subsequent to the plant going into operation, these snubbers have been and continue to be visually inspected and functionally tested in accordance with Plant TS.
The NRC reviewed several areas of the ASME OM Code, subsection ISTD, to TS Surveillance Requirement (SR) 4.7.9. Table 1 reflects the comparison performed by the NRC as detailed in the July 28, 2003 Safety Evaluation Report (SER). Based on this, the NRC found that TS 3/4.7.9 provides essentially equivalent visual and functional testing of snubbers when compared to the ASME Code requirements. In addition, the staff found that the qualification and certification program for personnel conducting snubber examinations at Salem (LR-N03-0305, dated July 10, 2003) is equivalent to the ASME Code qualification requirements for VT-3 NDE personnel. This July 28, 2003 SER is also applicable to this Unit 2 request.
Visual inspections in accordance with TS SR 4.7.9.b shall verify (1) that there are no visible indications of damage or impaired OPERABILITY, (2) attachments to the foundation or supporting structure are secure, and (3) in those locations where snubber movement can be manually induced without disconnecting the snubber, that the snubber has freedom of movement and is not frozen up. The applicable visual inspection guidelines do not differentiate between integral and non-integral attachments. This provides an acceptable level of quality and safety.
il Document Control Desk Attachment I LR-N05-0240 Relief Request S2-13-RR-FOI Snubber Testing and Inspection Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
- Alternative Provides Acceptable Level of Quality and Safety --
6. Duration of Proposed Alternative
This Request, upon approval, will be applicable for the third 10-year interval at Salem Nuclear Generating Station Unit 2 that began on November 23, 2003.
7. Precedents
Relief has been previously granted for Salem Unit 1 to perform the examination and testing in accordance with the plant TS (NRC letter dated July 28, 2003, TAC NO.MB6098). Also, relief has been granted for McGuire Nuclear Station, Unit 2 to perform the examination and testing in accordance with selected licensee commitment (SLC) 16.9.15 (NRC letter dated November 22, 2004, TAC NO.MC2384).
Document Control Desk LR-N05-0240 Attachment I Relief Request S2-13.RR-FOI Snubber Testing and Inspection Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
- Alternative Provides Acceptable Level of Quality and Safety --
Table I Criteria ASME Code Section Xl and/or Salem, Unit Nos. I and 2, O0! Code (Subsection ISTD)
TS 3/4.7.9 Requirements Requirements Snubber sample ISTD 7.6.1 states that each defined test At least once per 18 months size plan group shall use either a 10%
during shutdown, a sampling plan; or a "37 testing sample representative sample of 10%
plan" during each refueling outage.
of the total of each type of snubber in use shall be functionally tested either in place or in a bench test.
Examination ISTM 6.1 states that snubber visual TS 4.7.9.b requires that visual requirements examinations shall identify physical inspections shall verify that damage, leakage, corrosion, or there are: (1) no visible degradation. Also, ISTD 7.1 and 7.2 indications of damage or state that operational readiness tests impaired operability; (2) shall verify activation, release rate, and attachments to the supporting breakaway force or drag force shall be structure are secure; and (3) verified by either an in-place or bench where possible, freedom of test. IWA-2213 also provides movement is checked to requirements for VT-3 examinations of ensure the snubber is not snubbers.
frozen up. TSs 4.7.9.c, 4.7.9.d, 4.7.9.e requires in-place or bench tests to verify activation, snubber bleed or release rate, and maximum drag force for mechanical snubbers.
Failure evaluation Snubbers not meeting test TS 4.7.9.c states that if a requirements shall be evaluated to snubber does not meet determine the root cause for the failure functional testing acceptance in accordance with ISTD 7.7.
criteria in TS 4.7.9.d and 4.7.9.e, the cause will be evaluated. If the failure is caused by the manufacturer or design deficiency, all snubbers of the same design, subject to the same defect, shall be functionally tested.
Document Control Desk LR-N05-0240 Attachment I Relief Request S2-13-RR-FOI Snubber Testing and Inspection Proposed Alternative In Accordance with 10 CFR 50.55a(a)(i)
-- Alternative Provides Acceptable Level of Quality and Safety --
Table I (cont'd)
Criteria ASME Code Section Xl and/or Salem, Unit Nos. 1 and 2, OM Code (Subsection ISTD)
TS 314.7.9 Requirements Requirements Additional sampling Additional snubbers are to be tested TS 4.7.9.c requires that an based on the number of failures in additional 10% of the type of accordance with ISTD 7.10.
snubber that failed functional testing be tested.
Corrective actions ISTD 7.8 states that unacceptable TS LCO 3/4.7.9 requires that snubbers shall be adjusted, repaired, inoperable snubbers would be modified, or replaced.
adjusted, repaired, modified, or replaced before operability can be restored.
Subsequent ISTD 6.5.2 provides guidance for TS Table 4.7-3 provides a examination examination intervals. Intervals are to snubber visual inspection intervals.
be based on Table ISTD 6.5.2-1.
interval based on the number of unacceptable snubbers discovered. Requirements are similar to Table ISTD 6.5.2-1.
Personnel IWA-231 0 states that nondestructive Qualification and certification qualifications examination (NDE) personnel shall be program for PSEG's NDE qualified in accordance with personnel satisfies the ANSI/ASNT CP-189. IWA-2317 requirements of ASNT CP-provides alternative qualifications for 189 (1991 edition) and VT-3 examination personnel.
supplemental requirements of IWA-2300. (REF: PSEG letter dated July 10, 2003 to NRC)