ML031630973

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Inservice Inspection Program Relief Request HC-RR-A10
ML031630973
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 06/05/2003
From: Salamon G
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LRN-03-0172
Download: ML031630973 (4)


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 JUN 5 2003 LRN-03-0172 A"3 PSEG" United States Nuclear Regulatory Commission 0

PuclearLC Document Control Desk Washington, DC 20555-001 INSERVICE INSPECTION PROGRAM RELIEF REQUEST HC-RR-AIO HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 Pursuant to 10 CFR 50.55a(a)(3)(i), PSEG Nuclear, LLC (PSEG Nuclear) is submitting relief request HC-RR-Al0 for NRC approval of a proposed alternative conceming performance demonstration methods for ultrasonic examination systems for Hope Creek Generating Station. Specifically, this proposed altemative concerns depth-sizing capability of dissimilar metal piping welds.

ASME Section Xl 1995 Edition 1996 Addenda Appendix VIII Supplement 10, Sizing Acceptance Criteria, section 3.2 (b) requires a root mean square (RMS) error of less than or equal to 0.125" for depth sizing capability. PSEG Nuclear has been informed that qualification of examination procedures, automated ultrasonic acquisition exam equipment, and personnel for depth sizing to the Supplement 10 procedures were not capable of achieving qualification to an overall error less than or equal to a 0.125" RMS.

Further review by the PDI Technical Working Group has determined that an error of up to 0.154" RMS should be considered acceptable for fracture mechanics calculations utilizing depth-sizing measurements obtained with the Supplement 10 procedure.

PSEG Nuclear requests that the NRC approve this request by August 2003 to support Hope Creek dissimilar weld piping inservice inspections.

Should you have any questions regarding this request, please contact Mr. Howard Berrick at 856-339-1862.

Manager - Nuclear Safety and Licensing

Attachment:

1. ISI Relief Request No. HC-RR-AI0 MW4 96-216 REV. 7/99

JUN 5 2003 Document Control Desk LR-N03-0172 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. R. Ennis Licensing Project Manager - Hope Greek Mail Stop 08B1 Washington, DC 20555-001 USNRC Senior Resident Inspector - Hope Creek (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. 0. Box 415 Trenton, NJ 08625

Document Control Desk LR-N03-0172 Page 1 ASME Code Component(s) Affected Dissimilar metal piping welds subject to examination using procedures, personnel and equipment qualified to ASME XI, Appendix Vil, Supplement 10 criteria.

Applicable Code Edition and Addenda

ASME Section Xl, 1989 Edition, is the code of record for PSEG Nuclear Hope Creek Nuclear Generating Station's Second Ten-Year Inservice Inspection (ISI) Program Interval.

Applicable Code Requirements ASME Section Xl 1995 Edition 1996 Addenda Appendix VIII Supplement 10, Sizing Acceptance Criteria 3.2(b) requires qualification of examination procedures, automated ultrasonic acquisition exam equipment, and personnel for depth sizing when the overall root mean square (RMS) error of the depth measurements, as compared to the true depth, be less than or equal to 0.125 inches.

PSEG Nuclear has been informed by their ISI Non-destructive Examination (NDE) vendor that their procedures, personnel and equipment were unable to qualify to an overall error of less than or equal to a 0.125" RMS for flaw depth sizing. The vendor achieved an overall error less than or equal to a 0.154" RMS for flaw depth sizing.

The vendor satisfactorily qualified procedures, personnel and equipment for the detection and length sizing in accordance with the Performance Demonstration Initiative's (PDI) implementation of Supplement 10.

Proposed Alternative and Basis for Use Pursuant to 1 OCFR50.55(a)(3)(i), PSEG Nuclear requests relief to use the following altemative requirement for implementation of Appendix VIII, Supplement 10 Sizing Acceptance Criteria 3.2(b) requirements. These requirements have been qualified through the PDI Program.

At the time of this submittal only two vendors have recorded RMS data. The two vendors each achieved similar RMS errors for depth sizing (0.154" and 0.155"). This would indicate the systems being qualified through PDI are the "best technologies" available at this time.

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

- Altemative Provides Acceptable Level of Quality and Safety -

Document Control Desk LR-N03-0172 Page 2 While the procedure's depth sizing capability was evaluated, the overall performance did not satisfy the acceptance criteria specified in Supplement 10, which requires an overall error less than or equal to a 0.125" RMS. The PDI Technical Working Group determined that the actual performance achieved of a RMS error of 0.154" should be considered for fracture mechanics calculations when utilizing the depth-sizing measurements obtained with the vendors Supplement 10 procedure.

PSEG Nuclear proposes, for the purposes of evaluation, to add the difference (0.029 in.)

between the vendors achieved RMS value (0.154") and the Code value (0.125") to the determined size depth when performing fracture mechanics calculations.

Duration of Proposed Alternative The requested duration of the proposed relief requ_.;st alternative is until October 31, 2004. f after that time, the Code required 0.125" RMS value is still not achievable, PSEG Nuclear will re-apply for relief. The requested 18-month duration will allow industry vendors to explore and enhance technology towards reaching the Code goal of 0.125" RMS.

Precedents None References Letter from M.P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, dated December 13, 2002 Letter from M.P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulation Commission, dated February 14, 2003 Letter from Carl Latiolais (EPRI NDE Center-PDI Qualification Project Manager) to Wayne Denlinger, PSEG Nuclear LLC, dated March 18, 2003.

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

- Altemative Provides Acceptable Level of Quality and Safety -

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