ML032650616
| ML032650616 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/26/2003 |
| From: | Richard Laufer NRC/NRR/DLPM/LPD1 |
| To: | Skolds J AmerGen Energy Co |
| Tam P, NRR/DLPM, 415-1451 | |
| References | |
| TAC MB5790, TAC MB5791, TAC MB5792, TAC MB5793 | |
| Download: ML032650616 (10) | |
Text
September 26, 2003 Mr. John L. Skolds Chairman and CEO AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) -
ALTERNATIVES AND RELIEFS CONCERNING THE FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM (TAC NOS. MB5790, MB5791, MB5792, AND MB5793)
Dear Mr. Skolds:
The Nuclear Regulatory Commission (NRC) staff, with technical assistance from its contractor, the Pacific Northwest National Laboratory (PNNL), has reviewed and evaluated the relief requests submitted by AmerGen Energy Company, LLC (the licensee), in its application dated August 1, 2002. The licensee withdrew Relief Request No. OC-02-04 and provided additional information for the remaining relief requests in its letter dated June 23, 2003. The NRC staff found the licensees Relief Request Nos. OC-02-01, OC-02-02, OC-02-03, and OC-02-05 to be acceptable, as discussed below.
The details of the NRC staff's evaluation and conclusions are contained in the enclosed Safety Evaluation, which incorporates the PNNL Technical Letter Report (TLR) as an Attachment. For Relief Request No. OC-02-02, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for the fourth 10-year interval, provided the licensee performs the additional UT as described in the TLR. The NRC staff has concluded that the examination coverage required by the American Society for Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) is impractical for the components for which the licensee has requested relief. The NRC staff has concluded that, provided the licensee performs the additional UT specified in the TLR, there exists reasonable assurance that structural integrity will be maintained. Further, granting relief pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
For Relief Request Nos. OC-02-01 and -03, the licensees proposed alternatives are authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the fourth 10-year interval. The NRC staff has concluded that compliance with the ASME Code requirements would result in a hardship or unusual difficulty without a compensating increase in the level of quality or safety. Furthermore, the licensees proposed alternatives provide reasonable assurance of structural integrity of the subject components. For Relief Request No. OC-02-05, the licensees proposed alternative provides an acceptable level of quality and safety and is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the fourth 10-year interval.
J. L. Skolds This completes the NRC staffs efforts on the licensees application. If you have any questions or need for clarification on the enclosed SE and its attached TLR, please contact the OCNGS Project Manager, Mr. Peter S. Tam, at 301-415-1451.
Sincerely,
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-219
Enclosure:
Safety Evaluation w/attachment cc w/encl: See next page
J. L. Skolds This completes the NRC staffs efforts on the licensees application. If you have any questions or need for clarification on the enclosed SE and its attached TLR, please contact the OCNGS Project Manager, Mr. Peter S. Tam, at 301-415-1451.
Sincerely,
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-219
Enclosure:
Safety Evaluation w/attachment cc w/encl: See next page DISTRIBUTION:
PUBLIC PDI-1 Reading C. Holden R. Laufer ACRS S. Coffin P. Tam T. McLellan G. Georgiev TChan B. Platchek, R-I S. Little G. Hill (2)
OGC J. Jolicouer, EDO ADAMS Accession Number: ML032650616
- SE transmitted by memo of this date.
OFFICE PDI-1:PM PDI-1:LA EMCB:SC*
OGC PDI-1:SC NAME TColburn for PTam SLittle SCoffin RHoefling RLaufer DATE 9/22/03 9/22/03 9/25/03*
9/25/03 9/26/03 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF NOS. OC-02-01, -02, -03, AND -05 AMERGEN ENERGY COMPANY, LLC OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219
1.0 INTRODUCTION
The Nuclear Regulatory Commission (NRC) staff, with assistance from Pacific Northwest National Laboratory (PNNL), has reviewed the Inservice Inspection (ISI) Program Request for Relief Nos. OC-02-01, OC-02-02, OC-02-03, OC-02-04, and OC-02-05 submitted for the fourth 10-year interval for Oyster Creek Nuclear Generating Station (OCNGS) by AmerGen Energy Company, LLC (the licensee) letter dated August 1, 2002. The NRC requested additional information by letter dated April 17, 2003. The licensee provided additional information and withdrew Relief Request No. OC-02-04 in its letter dated June 23, 2003.
2.0 REGULATORY EVALUATION
Inservice inspection of the American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 components is performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (ASME Code) and applicable addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 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, if: (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 regulations require that inservice examination 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) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable Code of record for the fourth 10-year ISI for OCNGS is the 1995 Edition with the 1996 Addenda of the ASME Code,Section XI.
Enclosure
3.0 TECHNICAL EVALUATION
The NRC staff adopts the evaluations and recommendations for authorizing alternatives and granting relief contained in the Technical Letter Report (TLR), included as an Attachment to this Safety Evaluation (SE), prepared by its contractor PNNL. The table at the end of this SE lists each relief request and the status of approval.
For Request for Relief No. OC-02-02, regarding examination area requirements of reactor vessel support skirt weld 1-569, the NRC staff determined that the inaccessibility of the subject welds makes the Code-required examinations impractical to perform. For complete examination coverage of the welds, redesign and modification of the subject components would be an unnecessary burden on the licensee. Furthermore, the licensees proposed alternatives provide reasonable assurance of structural integrity of the subject components, provided the licensee performs a best-effort ultrasonic examination of the inside weld of the reactor vessel support skirt from the outside of the skirt as described in the PNNL TLR.
For Request for Relief Nos. OC-02-1, regarding surface examination requirements for circumferential welds, and OC-02-03, regarding hydrostatic tests for Class 3 pressure retaining components, the NRC staff determined that compliance with the Code requirements would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Furthermore, the licensees proposed alternatives contained in the subject reliefs provide reasonable assurance of structural integrity of the subject components in the licensees requests for relief.
For Request for Relief No. OC-02-05, regarding training of ultrasonic examination personnel, the NRC staff determined that the licensees proposed alternative to use 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of hands-on training in accordance with 10 CFR 50.55a(b)(2)(xiv) in lieu of the Code requirements provides reasonable assurance of quality of safety.
4.0 CONCLUSION
The NRC staff concludes that for Relief Request No. OC-02-02, the examination coverage requirements imposed by the ASME Code are impractical for the components listed by the licensee. Furthermore, reasonable assurance of the structural integrity of the subject components has been provided by the examinations that are being performed, provided the licensee performs a best-effort ultrasonic examination of the inside weld of the reactor vessel support skirt from the outside of skirt weld. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for the fourth 10-year interval provided the licensee performs the additional ultrasonic examination as noted above and described in the TLR. All other requirements of the ASME Code,Section III and XI for which relief has not been specifically requested, remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector. Granting relief pursuant to 10 CFR 50.55a(g)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
The NRC staff concludes that for Relief Request Nos. OC-02-1 and OC-02-03, compliance with the Code requirements would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Furthermore, the licensees proposed alternative provides reasonable assurance of structural integrity of the subject components. Therefore, the licensees proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the fourth 10-year ISI interval. All other requirements of the ASME Code,Section III and XI for which relief has not been specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
The NRC staff concludes that for Relief Request No. OC-02-05, the licensees proposed alternative provides an acceptable level of quality and safety. Therefore, the licensees proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the fourth 10-year interval. All other requirements of the ASME Code, Sections III and XI, for which relief has not been specifically requested remain applicable, including third party-review by the Authorized Nuclear Inservice Inspector.
Principal Contributors: T. McLellan G. Georgiev T. Colburn Date: September 26, 2003
OYSTER CREEK GENERATING STATION Page 1 of 1 Fourth 10-Year ISI Interval TABLE 1
SUMMARY
OF RELIEF REQUESTS Relief Request Number TLR RR Sec.
System or Component Exam.
Category Item No.
Volume or Area to be Examined Required Method Licensee Proposed Alternative Relief Request Disposition OC-02-1 3.1 Piping Welds B-J C-F-1 B9.10 C5.10 Inner one-third volume and entire outside surface area of selected piping welds Volumetric and Surface Discontinue surface examinations Authorized 10 CFR 50.55a(a)(3)(ii)
OC-02-02 3.2 RPV support skirt attachment weld B-K B10.10 100% length of inner and outer surfaces for integral attachment Weld 1-569 Surface Perform outer surface examination and VT-3 of inner surface Granted, with provision 10 CFR 50.55a(g)(6)(i)
OC-02-03 3.3 All Class 3 pressure retaining components D-B D2.20 D2.40 D2.60 D2.80 A hydrostatic test for all pressure vessels, piping, pumps and valves in each system once per interval VT-2 Visual Use Code Case N-498-4 with hold times imposed Authorized 10 CFR 50.55a(a)(3)(ii)
OC-02-04 3.4 Metal containment bolted connections E-G E8.10 E8.20 A visual examination of all bolted connections, including bolts, studs, nuts, bushings, and washers. A torque or tension test of connections not disassembled during interval VT-1 Visual and Torque or Tension Test Use Examination Category E-A General Visual requirements Withdrawn by licensee OC-02-05 3.5 Various All All Appendix VII, VII-4240 requires 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> annual training for ultrasonic personnel Ultrasonic Testing Use 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of hands-on training in accordance with 10 CFR 50.55a(b)(2)(xiv)
Authorized 10 CFR 50.55a(a)(3)(i)
Oyster Creek Nuclear Generating Station cc:
Chief Operating Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President - Nuclear Services AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Site Vice President - Oyster Creek Generating Station AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Vice President - Mid-Atlantic Operations AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 John E. Matthews, Esquire Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Operations Support AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 H. J. Miller Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 Director Licensing AmerGen Energy Company, LLC Nuclear Group Headquarters P.O. Box 160 Kennett Square, PA 19348 Manager Licensing - Oyster Creek and Three Mile Island AmerGen Energy Company, LLC Nuclear Group Headquarters Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Oyster Creek Generating Station Plant Manager AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Regulatory Assurance Manager Oyster Creek AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731
Oyster Creek Nuclear Generating Station cc:
Vice President, General Counsel and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA 19101 J. Rogge, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Correspondence Control Desk AmerGen Energy Company, LLC 200 Exelon Way, KSA 1-N-1 Kennett Square, PA 19348