ML021010241
| ML021010241 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 04/01/2002 |
| From: | Salamon G Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LRN-02-0115 | |
| Download: ML021010241 (5) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 APR 0 1 2002 PSEG N'uclear LLC LRN-02-0115 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
INSERVICE INSPECTION PROGRAM RELIEF REQUEST SH-RR-WO1 SALEM GENERATING STATION UNITS I AND 2 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSES NPFDPR-70, DPR-75 AND NPF-57 DOCKET NOs. 50-272, 50-311 and 50-354 Pursuant to 10CFR50.55a(a)(3)(i), PSEG Nuclear is submitting Inservice Inspection (ISI) relief request HC-RR-WO1 for NRC approval. Relief is requested from the requirements for welding and brazing procedure qualifications as stated in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, IWA-4000. This request also includes relief for all Procedure Qualification Records (PQR) supporting alternative repair procedures in accordance with ASME, Section Xl, IWA-4500.
PSEG Nuclear LLC (PSEG Nuclear) requests to utilize ASME Code Case N-573, Transfer of Procedure Qualification Records Between Owners,Section XI, Division 1 as an alternative method to qualify welding procedures.
This relief request is intended as an alternate method of qualifying welding procedures at Salem Units 1, Unit 2 and Hope Creek. However, it is desired to use the provisions of this Code Case prior to the October 2002 Salem Unit 1 refueling outage.
The attachment to this letter includes the proposed alternative and supporting justification for the relief. Based on the evaluation contained in the attachment, PSEG Nuclear has concluded that the proposed alternative provides an acceptable level of quality and safety. Accordingly, this proposal satisfies the requirements of 10 CFR 50.55a(a)(3)(i).
Should you have any questions regarding this request, please contact Mr. Howard Berrick at 856-339-1862.
Sin ýerel G. Salamon Manager - Nuclear Safety and Licensing
Attachment:
- 1. ISI Relief Request No. SH-RR-W01
- 2. TABLE 1 - Comparison of ASME Code Case N-573 to PSEG Nuclear Relief Request 95-2168 REV. 7/99
Document Control Desk
-2 LRN-02-0115 APR 0 12002 C
Mr. H. Miller, Administrator Regional Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Fretz Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08B2 11555 Rockville Pike Rockville, MD 20852 Mr. G. Wunder Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08B1 11555 Rockville Pike Rockville, MD 20852 USNRC Senior Resident Inspector - Salem (X24)
USNRC Senior Resident Inspector - Hope Creek (X24)
Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625
PSEG NUCLEAR LLC SALEM GENERATING STATION, UNITS 1 & 2 HOPE CREEK GENERATING STATION ISI RELIEF REQUEST SH-RR-W01 Description Use of ASME Code Case N-573, "Transfer of Procedure Qualification Records Between Owners, Section Xl, Division 1.
ASME Section XI Class ASME Class 1, 2 and 3 Code Requirement ASME, Section Xl, IWA-4440(a), 1995 Edition, 1996 Addenda edition requires that the Owner qualify all welding procedures utilized for ASME Xl repair/replacements.
Basis for Relief Pursuant to 1 OCFR50.55a(a)(3)(i), relief is requested from the requirements for welding and brazing procedure qualifications as stated in ASME, Section Xl, IWA-4440. This request also seeks similar relief for all Procedure Qualification Records (PQRs) that would be required in support of alternative repair procedures in accordance with ASME,Section XI, IWA-4600.
PSEG Nuclear LLC (PSEG Nuclear) requests to utilize ASME Code Case N-573 as an additional alternative method to qualify welding procedures.
Exclusively adhering to the present welding and brazing qualification requirements presents an undue hardship, as considerable utility specific resources are unnecessarily duplicated when qualified procedures from other NRC licensed facilities have already been demonstrated to provide an acceptable level of quality and safety. The requested alternative will not reduce safety or quality but will provide for an alternative means by which to qualify welding procedures.
Similar relief has been granted to a number of utilities, including TXU Electric, Comanche Peak Units 1 and 2 (TAC Nos. MA9406 and MA9407) and Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station (TAC No MA7129).
Alternate Requirements PSEG Nuclear seeks the approval of Code Case N-573, in order to allow the use of other Owners' PQRs that have been developed and controlled under comparable 1 OCFR50 Appendix B program controls. Steps to be taken by PSEG Nuclear to ensure the technical correctness of other Owner's PQRs and to ensure the resulting Welding Procedure Specifications (WPS) produce sound welds are presented in Table 1 of this request. In summary, PSEG Nuclear shall:
- a.
Verify that the source Owner has certified, by signing the PQR, that testing was performed in accordance with ASME Section IX.
Page I of 2 LRN-02-0115
PSEG NUCLEAR LLC SALEM GENERATING STATION, UNITS I & 2 HOPE CREEK GENERATING STATION ISI RELIEF REQUEST SH-RR-W01
- b.
Verify that the providing source Owner, (utility) has certified in writing that the procedure qualification was conducted in accordance with a Quality Assurance Program that satisfies the requirements of IWA-1400, (e.g., 10CFR50 Appendix B).
- c.
Be responsible for obtaining any additional supporting information needed for WPS development.
- d.
Document, on each resulting WPS, the parameters applicable to welding. Each WPS shall be supported by all necessary PQR's.
- e.
Accept responsibility for the PQR and document said acceptance by signature approval of each WPS that references the PQR.
- f.
Demonstrate technical competence in application of the received PQR by completing a performance qualification test using the parameters of a resulting WPS.
- g.
Accept and use a PQR only when it is received directly from the Owner that certified the PQR (source Owner).
- h.
Document the use of Code Case N-573 within the repair/replacement plan where the implementing welding procedure(s) have been qualified through this alternative qualification method. This is a departure from the stated conditions within Code Case N-573. This is necessary, however, since ASME NIS-2 forms are not utilized at Salem Unit 1, Salem Unit 2 or Hope Creek. Instead ASME NIS-2A forms are employed in accordance with ASME Code Case N-523, previously approved for use at PSEG Nuclear.
Applicable Time Period Approval for the use of this alternative, as provided by the Code Case, is requested to support the Salem Unit 1 fall outage in October of 2002, and subsequent Salem Unit 1 &2 and Hope Creek outages.
Page 2 of 2 Attachment I LRN-02-0115
PSEG NUCLEAR LLC SALEM GENERATING STATION, UNITS 1 and 2 & HOPE CREEK GENERATING STATION 151 RELIEF REQUEST SH-RR-WOI TABLE I Comparison of ASMVE Code Case N-573 Requirements to PSEG Nuclear Relief Request Code Case N-573 It is the opinion of the Committee that as an alternative to the welding and brazing procedure qualification requirements of IWA-4000, a procedure qualification record (PQR) qualified by one Owner may be used by another Owner. When this alternative is used. the followina requirements shall be met:
PSEG Relief Request PSEG Nuclear will meet the following requirements in using Code Case N-573:
1 (a) The Owner that performed the procedure qualification test shall certify, by
- a. PSEG Nuclear shall verify that the source Owner has certified, by signing signing the PQR, that testing was performed in accordance with Section IX.
the PQR, that testing was performed in accordance with Section IX.
(b) The Owner that performed the procedure qualification test shall certify, in
- b. PSEG Nuclear shall verify that the source Owner has certified in writing 2
writing, that the procedure qualification was conducted in accordance with a that the procedure qualification was conducted in accordance with a Quality Quality Assurance Program that satisfies the requirements of IWA-1400.
Assurance Program that satisfies the requirements of IWA-1400.
(c) The Owner accepting the completed PQR shall accept responsibility for
- c. PSEG Nuclear shall be responsible for obtaining any additional 3
obtaining any additional supporting information needed for WPS supporting information needed for WPS development.
development (d) The Owner accepting the completed PQR shall document, on each
- d. PSEG Nuclear shall document, on each resulting WPS, the parameters 4
resulting WPS, the parameters applicable to welding. Each WPS shall be applicable to welding. Each WPS shall be supported by all necessary supported by all necessary PQR's.
PQR's.
(e) The Owner accepting the completed PQR shall accept responsibility for
the PQR. Acceptance shall be documented by the Owner's approval of each document said acceptance by signature approval of each WPS that WPS that references the PQR.
references the PQR.
(0 The Owner accepting the completed PQR shall demonstrate technical
- f. PSEG Nuclear shall demonstrate technical competence in application of 6
competence in application of the received PQR by completing a performance the received PQR by completing a performance qualification test using the qualification test using the parameters of a resulting WPS.
parameters of a resulting WPS.
7 (g) The Owner may accept and use a PQR only when it is received directly
- g. PSEG Nuclear shall accept and use a PQR only when it is received from the Owner that certified the PQR.
directly from the Owner that certified the PQR (source Owner).
(h) Use of this Case shall be shown on the NIS2 form h'Document the use of Code Case N-573 within the repair/replacement 8
documenting welding plan where the implementing welding procedure(s) have been qualified or brazing.
through this alternative qualification method.
Page 1 of I Code Case N-573 LRN-02-0115