ML032090200

Relief, Relief from ASME Code Requirements Related to the Salem Inservice Inspection Program, Relief Request S1-RR-F01, MB6098

ML032090200
Person / Time
Site:	Salem
Issue date:	07/28/2003
From:	Clifford J NRC/NRR/DLPM/LPD1
To:	Richard Anderson Public Service Enterprise Group
Fretz R, NRR/DLPM, 415-1324
References
TAC MB6098
Download: ML032090200 (10)

Text

July 28, 2003 Mr. Roy A. Anderson President & Chief Nuclear Officer PSEG Nuclear, LLC - X04 Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NO. 1 - RELIEF FROM ASME CODE REQUIREMENTS RELATED TO THE SALEM INSERVICE INSPECTION PROGRAM, RELIEF REQUEST S1-RR-F01, (TAC NO. MB6098)

Dear Mr. Anderson:

By letter dated July 8, 2002, as supplemented on July 10, 2003, PSEG Nuclear, LLC (PSEG) submitted a request for relief (Relief Request S1-RR-F01) from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (the Code),Section XI, requirements for the testing of dynamic restraints (snubbers) at the Salem Nuclear Generating Station (Salem), Unit No. 1. In the July 8, 2002, letter, PSEG requested the continued use of Technical Specification 3/4.7.9, Snubbers, and associated bases, in lieu of ASME Code requirements outlined in Article IWF-5000. Relief was requested for the third 10-year Inservice Inspection (ISI) interval for Salem, Unit No. 1.

The U.S. Nuclear Regulatory Commission (NRC) staff has completed its review of the subject relief request. As documented in the enclosed Safety Evaluation, the staff concludes that the proposed alternative will provide an acceptable level of quality and safety. Therefore, pursuant to Title 10 of the Code of Federal Regulations, Section 50.55a(a)(3)(i), the NRC staff authorizes the proposed alternative for the third 10-year ISI interval for Salem, Unit No. 1.

Sincerely,

/RA/

James W. Clifford, Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-272

Enclosure:

Safety Evaluation cc w/encl: See next page

ML032090200

• See previous concurrence OFFICE PDI-2/PM PDI-2/LA EMEB/SC* OGC* PDI-2/SC NAME RFretz CRaynor KManoly RHoefling/NLO JClifford DATE 7/24/03 7/24/03 07/15/03 07/23/03 7/25/03 PSEG Nuclear LLC Salem Nuclear Generating Station, Unit No. 1 cc:

Mr. Timothy J. OConnor Lower Alloways Creek Township Vice President - Operations c/o Mary O. Henderson, Clerk PSEG Nuclear - X15 Municipal Building, P.O. Box 157 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Dr. Jill Lipoti, Asst. Director Mr. John T. Carlin Radiation Protection Programs Vice President - Engineering NJ Department of Environmental PSEG Nuclear - N10 Protection and Energy P.O. Box 236 CN 415 Hancocks Bridge, NJ 08038 Trenton, NJ 08625-0415 Mr. David F. Garchow Brian Beam Vice President - Projects and Licensing Board of Public Utilities PSEG Nuclear - N28 2 Gateway Center, Tenth Floor P.O. Box 236 Newark, NJ 07102 Hancocks Bridge, NJ 08038 Regional Administrator, Region I Mr. Gabor Salamon U.S. Nuclear Regulatory Commission Manager - Nuclear Safety and Licensing 475 Allendale Road PSEG Nuclear - N21 King of Prussia, PA 19406 P.O. Box 236 Hancocks Bridge, NJ 08038 Senior Resident Inspector Salem Nuclear Generating Station Jeffrie J. Keenan, Esquire U.S. Nuclear Regulatory Commission PSEG Nuclear - N21 Drawer 0509 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Ms. R. A. Kankus Joint Owner Affairs PECO Energy Company Nuclear Group Headquarters KSA1-E 200 Exelon Way Kennett Square, PA 19348

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE TESTING OF DYNAMIC PIPE RESTRAINTS (SNUBBERS)

IN ACCORDANCE WITH RELIEF REQUEST S1-RR-F01 PSEG NUCLEAR, LLC SALEM NUCLEAR GENERATING STATION, UNIT NO. 1 DOCKET NO. 50-272

1.0 INTRODUCTION

By letter dated July 8, 2002, as supplemented on July 10, 2003, PSEG Nuclear, LLC (PSEG) submitted a request for relief from the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code (the Code),Section XI, requirements for the testing of dynamic restraints (snubbers) at the Salem Nuclear Generating Station (Salem), Unit No. 1. In the July 8, 2002, letter, PSEG requested the continued use of Technical Specification (TS)

Section 3/4.7.9, Snubbers, and its associated bases, in lieu of ASME Code requirements outlined in Article IWF-5000. The July 10, 2003, letter provided additional information associated with personnel qualifications for snubber testing.

Relief was requested for the third 10-year Inservice Inspection (ISI) interval for Salem, Unit No. 1.

2.0 REGULATORY EVALUATION

The ISI of the ASME Code Class 1, 2, and 3 components is to be performed in accordance with Section XI of the ASME Code and applicable edition and addenda as required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(g), except where specific written relief has been granted by the U.S. Nuclear Regulatory Commission (NRC or Commission) pursuant to 10 CFR 50.55a(g)(6)(i). Pursuant to 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, Director of the Office of Nuclear Reactor Regulation, if the licensee demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection (ISI) of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The Enclosure

regulations require that the ISI of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b),

12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed therein, and subject to the Commissions approval.

3.0 LICENSEES RELIEF REQUEST (As stated)

Component Description ASME Section XI Class 1, 2, and 3 component supports snubbers 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.

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 1996 Addenda, in lieu of the requirements for snubbers in Section XI, 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.

Basis for Relief 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 the continued use of Plant Systems Technical Specification No. 3/4.7.9, Snubbers, and associated bases; as found within the Salem Nuclear Generating Station, Unit 1 Technical Specifications, Appendix 'A' to License No. DPR-70, Amendment No. 243, dated May 25, 2001.

The Salem Nuclear Generating Station, Unit 1 Technical Specifications contain specifically developed and approved visual examination and functional testing requirements.

Performance of examinations and testing to the requirements of the Technical Specification meet the intent of the 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 Technical Specification 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 Technical Specifications.

Additionally, relief has been previously granted to perform the examination and testing in accordance with the plant Technical specifications (Ref. NRC SER/TAC 66932), therefore there is reasonable assurance of continued structural integrity, and an acceptable level of quality and safety will be maintained during the Third Inspection Interval.

Alternate Requirements PSEG Nuclear LLC proposes to continue implementation of the visual examinations and functional testing on Code Class 1, 2 and 3 (and other) snubbers in compliance with the Salem Nuclear Generating Station, Unit 1 Technical Specification 3/4.7.9 and its associated bases.

Applicability This Relief Request is applicable to the following:

Salem, Unit 1 - Third Ten-Year Inservice Inspection

4.0 TECHNICAL EVALUATION

Paragraph (b)(3)(v) of 10 CFR 50.55a states that licensees may use Subsection ISTD, "Inservice Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Power Plants," of the ASME OM Code, 1995 Edition through the latest edition and addenda incorporated by reference in paragraph (b)(3) of 10 CFR 50.55a, in place of the requirements for snubbers in Section XI, IWF-5200(a) and (b) and IWF-5300(a) and (b), by making appropriate changes to their TSs or licensee-controlled documents. Therefore, in reviewing Relief Request S1-RR-F01, the NRC staff compared certain requirements of the ASME OM Code, Subsection ISTD, to TS Surveillance Requirement (SR) 4.7.9, including: (1) snubber sample size, (2) examination requirements, (3) failure evaluation, (4) additional sampling, (5) corrective actions, (6) subsequent examination intervals, and (7) personnel qualifications. A summary of the comparison of the Salem, Unit No. 1, TS SRs and ASME Code (Section XI and OM Code, Subsection ISTD) requirements is provided in the following table:

ASME Code Section XI and/or OM Code (Subsection ISTD) Salem, Unit Nos. 1 and 2, Criteria Requirements TS 3/4.7.9 Requirements Snubber sample ISTD 7.6.1 states that each At least once per 18 months size defined test plan group shall use during shutdown, a representative either a 10% sampling plan; or a sample of 10% of the total of each 37 testing sample plan during type of snubber in use shall be each refueling outage. functionally tested either in place or in a bench test.

Examination ISTD 6.1 states that snubber TS 4.7.9.b requires that visual requirements visual examinations shall identify inspections shall verify that there physical damage, leakage, are: (1) no visible indications of corrosion, or degradation. Also, damage or impaired operability; ISTD 7.1 and 7.2 state that (2) attachments to supporting operational readiness tests shall structure secure; and (3) where verify activation, release rate, and possible, freedom of movement is breakaway force or drag force checked to ensure the snubber is shall be verified by either an not frozen up. TSs 4.7.9.c, in-place or bench test. IWA-2213 4.7.9.d, 4.7.9.e requires in-place also provides requirements for or bench tests to verify activation, VT-3 examinations of snubbers. 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 snubber does not meet functional to determine the root cause for testing acceptance criteria in TS the failure in accordance with 4.7.9.d and 4.7.9.e, the cause will ISTD 7.7. 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.

Additional sampling Additional snubbers are to be TS 4.7.9.c requires an additional tested based on the number of 10% of the type of snubber that failures in accordance with ISTD failed functional testing be tested.

7.10.

Corrective actions ISTD 7.8 states that unacceptable TS LCO 3/4.7.9 requires that snubbers shall be adjusted, inoperable snubbers would be repaired, modified, or replaced. adjusted, repaired, modified, or replaced before operability can be restored.

ASME Code Section XI and/or OM Code (Subsection ISTD) Salem, Unit Nos. 1 and 2, Criteria Requirements TS 3/4.7.9 Requirements Subsequent ISTD 6.5.2 provides guidance for TS Table 4.7-3 provides a examination examination intervals. Intervals snubber visual inspection interval intervals are to be based on Table based on the number of ISTD 6.5.2-1. unacceptable snubbers discovered. Requirements similar to Table ISTD 6.5.2-1.

Personnel IWA-2310 states that PSEG letter dated July 10, 2003, qualifications nondestructive examination (NDE) states that its qualification and personnel shall be qualified in certification program for NDE accordance with ANSI/ASNT personnel satisfies the CP-189. IWA-2317 provides requirements of ASNT CP-189 alternative qualifications for VT-3 (1991 edition) and supplemental examination personnel requirements of IWA-2300.

4.1 Snubber Sample Size Salem TS SR 4.7.9 requires that a representative sample of 10% of the total of each type of snubber in use shall be functionally tested, either in place or in a bench test, at least once per 18 months, during shutdown. These tests are normally performed during refueling outages.

The ASME OM Code requires either a 10% testing sampling plan or a 37 testing sample plan.

The Salem TS sample size would, therefore, be comparable to the 10% sample testing requirements of the ASME OM Code. As a result, the number of snubbers tested during the 18-month period is essentially equivalent to the ASME OM Code requirements.

4.2 Examination Requirements TS 4.7.9.b requires that visual inspections shall verify that: (1) there are no visible indications of damage or impaired operability; (2) attachments to the supporting structure secure; and (3) where possible, freedom of movement is checked to ensure the snubber is not frozen up.

TSs 4.7.9.c, 4.7.9.d, and 4.7.9.e require in-place or bench tests to verify activation, snubber bleed or release rate, and maximum drag force for mechanical snubbers. These requirements are similar to snubber visual examination requirements of ASME OM Code Subsections ISTD 6.1, ISTD 7.1, and ISTD 7.2. Additionally, in PSEGs letter dated July 10, 2003, the licensee states that its VT-3 type visual examinations include verification of: clearances, settings, and physical displacement; loose or missing parts; debris; corrosion; wear; erosion; and loss of integrity at bolted or welded connections. The licensees snubber examinations provided in its TSs are similar to the VT-3 examination requirements of ASME Code, IWA-2213.

4.3 Failure evaluation The ASME OM Code requires that a root cause evaluation be performed. The root cause evaluation shall review information related to other unacceptable snubbers and determine whether other snubbers of similar design would require further examination. Salem TS 4.7.9.c

states that if a snubber does not meet functional testing acceptance 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. Therefore, the NRC staff considers Salems TS requirements to be equivalent to the ASME OM Code requirements.

4.4 Additional Sampling ASME OM Code, Subsection ISTD 7.9.2 states that the additional sample size must be at least one-half the size of the initial sample size of the defined test plan group of snubbers. That is, for a 10% sample program, an additional 5% of the same type of snubber in the overall population would need to be tested. If additional snubbers are required to be tested due to the failure of a snubber to meet acceptance criteria, the Salem TSs require that an additional 10%

of the type of snubber that had failed be tested. Therefore, the NRC staff finds the additional sampling to be acceptable 4.5 Corrective Actions ASME OM Code, Subsection ISTD 7.8 states that unacceptable snubbers shall be adjusted, repaired, modified, or replaced. Salem TS LCO 3/4.7.9 would require that inoperable snubbers be similarly adjusted, repaired, modified, or replaced prior to restoring system operability.

Consequently, the corrective actions associated with the discovery of unacceptable snubbers at Salem are acceptable.

4.6 Subsequent Examination Intervals ASME OM Code, Subsection ISTD 6.5.2 provides guidance for examination intervals. This subsection states that intervals are to be based on Table ISTD 6.5.2-1. TS Table 4.7-3 provides a snubber visual inspection interval based on the number of unacceptable snubbers discovered. The requirements of TS Table 4.7-2 are equivalent to ASME OM Code, Table ISTD 6.5.2-1. Therefore, the NRC staff finds this acceptable.

4.7 Personnel Qualifications In its letter dated July 10, 2003, PSEG stated that NDE personnel assigned to conduct snubber visual examinations are, as a minimum, certified Level I, VT 1-3 in accordance with the licensees qualification and certification program for NDE personnel. PSEG further stated its NDE qualification and certification program satisfies the requirements of: (1) American Society for Nondestructive Testing (ASNT) Recommended Practice No. SNT-TC-1A (1980, 1984, and 1992 Edition), "Personnel Qualification and Certification in Nondestructive Testing;" (2) ASNT CP-189 -1991, "ASNT Standard for Qualification and Certification of Nondestructive Testing Personnel;" and (3) supplemental requirements of the ASME Code,Section XI (1995 Edition, 1996 Addenda), Subsection IWA-2300. The qualification and certification program for personnel conducting snubber examinations at Salem are equivalent to the minimum ASME Code qualification requirements for VT-3 NDE personnel. Therefore, the NRC staff finds the licensees qualification program acceptable.

5.0 CONCLUSION

Salem TSs define examination requirements, initial sample size, failure evaluation, additional sampling, corrective actions, subsequent examination intervals, and personnel qualifications that are similar to those provided by the ASME Code (Section XI and OM Code, Section ISTD).

Therefore, because the limiting conditions for operation and SRs defined in Salem TS 3/4.7.9 provide essentially equivalent visual and functional testing of snubbers when compared to ASME Code requirements, the NRC staff finds the alternative program, as provided in the Salem, Unit No. 1, TSs, to be acceptable. Therefore, based on its review, the NRC staff finds that the proposed alternative described in PSEGs letter dated July 8, 2002, as supplemented on July 10, 2003, provides an acceptable level of quality and safety. Therefore, use of Salem Unit No. 1, TS 3/4.7.9 for the testing of dynamic restraints (snubbers) in lieu of ASME Code requirements is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the third 10-year ISI interval at Salem, Unit No. 1.

Principal Contributor: R. Fretz Date: July 28, 2003