ML030590216

Inservice Inspection Program Relief Request HC-RR-A02

ML030590216
Person / Time
Site:	Salem, Hope Creek
Issue date:	02/20/2003
From:	Salamon G Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LRN-030054
Download: ML030590216 (4)

Text

PSEG Nuclear LLC P 0 Box 236, Hancocks Bridge, New Jersey 08038-0236 FEB 2 0 2003 LRN-03-0054 United States Nuclear Regulatory Commission Document Control Desk0 o PSE PsE" Washington, DC 20555-001 NuclearLLC INSERVICE INSPECTION PROGRAM RELIEF REQUEST HC-RR-A02 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSES NPF-57 DOCKET NOS. 50-354 Pursuant to 10 CFR 50.55a(a)(3)(i), PSEG Nuclear, LLC requests relief to incorporate the alternate examination requirements of ASME Code Case N-598, Alternative Requirements to Required Percentagesof Examinations,Section XI Division ', to determine the required percentage of examinations each inspection period for Class 1, 2, and 3 components and associated component supports at Hope Creek.

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).

This relief request is applicable to PSEG Nuclear LLC Hope Creek Generating Station. PSEG Nuclear requests that the NRC approve this request by April 2003 in order to support Hope Creek refueling outage RFO1E1 scheduled to commence April 12, 2003. Similar relief has been granted for Salem Units I and 2 [Docket Numbers 50-272 and 50-311 via approved TAC numbers MB6086 and MB6087, respectively, dated October 4, 2002].

Should you have any questions regarding this request, please contact Mr.

Howard Berrick at 856-339-1862.

G. Salamon Manager - Nuclear Safety and Licensing

Attachment:

ISI Relief Request HC-RR-A02 AOV-7 95-2168 REV 7/99

Documept Control Desk LR-N03-0054 C Mr. H. Miller, Administrator Regional Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission ATTN: Mr. G. Wunder Licensing Project Manager - Hope Creek Mail Stop 08C2 Washington, DC 20555-001 USNRC Senior Resident Inspector - Hope Creek (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625 Page 2 of 4

Document Control Desk Attachment 1 LR-N03-0054 Relief Request HC-RR-A02

1. ASME Code Component(s) Affected ASME Section X1 Class 1, 2, 3 component and their component supports.

2. Applicable Code Edition and Addenda

The code of record for Hope Creek ISI Program is Section Xl of the ASME Code, 1989 Edition.

3. Applicable Code Requirement

For Hope Creek, ASME Xl 1986 Edition subparagraphs IWB-2412, IWC 2412, IWD-2412, IWF-2410; and Tables IWB IWB-2412-1, IWC-2412-1, IWD 2412-1 and Table -2410-2 of Code Case N-491-1 require approximately one third of the Code examinations be performed each inspection period and that 100 percent of the examinations be completed each inspection interval.

4. Proposed Alternative PSEG Nuclear, LLC proposes to fully implement the alternative requirements of Code Case N-598 for Class 1, 2, and 3 components, and their associated Component Supports.

5. Basis of Alternative for Providing Acceptable Level of Quality and Safety 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 requests relief to incorporate the alternate examination requirements of ASME Code Case N-598, titled 'Alternative Requirements to Required Percentages of Examinations, Section Xl Division 1V, to determine the required percentage of examinations each inspection period for Class 1, 2, and 3 components and associated component supports at Hope Creek.

Although Code Case N-598 also addresses Class MC components, relief is not being requested for scheduling of Class MC components in this Request for Alternative.

The ASME Code tables referenced above were originally established such that approximately one third of the non-deferred examinations would be performed each period. Over the past 20 years, it has become increasingly more difficult to meet these percentages. The emergence of longer fuel cycles increases the likelihood that one of the periods will only have one refueling outage in it. In addition, efforts to shorten refueling outages have limited the amount of time available to perform examinations. These factors have made it difficult to complete the Code required percentages of examinations in the allotted time.

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

-- Alternative Provides Acceptable Level of Quality and Safety --

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Document Control Desk Attachment I ILR-N03-0054 Relief Request HC-RR-A02 Code Case N-598 was developed to address this issue. It expands the range of examination completion percentages to allow examinations to be distributed more evenly between outages. This minimizes the need to schedule an excessive number of examinations during one outage just to meet the percentages required by ASME,Section XI, Tables IWB-2412-1, IWC-2412-1, IWD-2412-1, and IWF-2410-2 (-2410-2). In addition, Code Case N-598 allows for a more uniform distribution between outages that is more conducive to performing quality examinations.

During the development cf Code Case N-598, two additional factors were considered when evaluating the impact of the Code Case on plant safety.

The first was that the existing tables allow up to 50 percent of the examinations to be performed in the second and third periods, but only 34 percent can be performed in the first period. Therefore, the Inspection Plan B schedule is biased towards delaying examinations until the end of the interval.

The more flexible percentages stated in Code Case N-598 allow for more examinations to be performed earlier in the interval. This should improve safety because any problems, should they exist, would be detected earlier in the interval.

The second factor that was considered when developing Code Case N-598 was that some minimum amount of examinations should be required in each period. To address this consideration, the Code Case, including Note (1), is structured such that examinations will be required during all three periods.

Due to the factors documented above, PSEG Nuclear, LLC considers that the alternative criteria of Code Case N-598 provide an acceptable, or improved, level of quality and safety during the Second Ten-Year Inspection Interval at Hope Creek Granting the proposed alternative will provide an acceptable level of quality and safety, and will not adversely impact the health and safety of the public.

6. Duration of Proposed Alternative Proposed alternative relief is requested for the duration of the second ten year ISI interval at Hope Creek. The use of the Code Case is requested until the NRC publishes the Code Case in a future revision of the applicable Regulatory Guide.

7. Precedents Previous relief has been granted for Salem Units 1 and 2 [Docket Numbers 50-272 and 50-311 via approved TAC numbers MB6086 and MB6087, respectively, dated October 4, 2002].

8. References None Proposed Alternative In Accorddnce with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

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