ML063340273

Relief Request to Synchronize Inservice Inspection Intervals

ML063340273
Person / Time
Site:	Salem
Issue date:	12/26/2006
From:	Stewart Bailey NRC/NRR/ADRO/DORL/LPLI-2
To:	Levis W Public Service Enterprise Group
Bailey S N,NRR/DLPM,415-1321
References
TAC MC8847
Download: ML063340273 (5)

Text

December 26, 2006 Mr. William Levis Senior Vice President & Chief Nuclear Officer PSEG Nuclear LLC - N09 Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NO. 1 - RELIEF REQUEST TO SYNCHRONIZE INSERVICE INSPECTION INTERVALS (TAC NO. MC8847)

Dear Mr. Levis:

The purpose of this letter is to document the Nuclear Regulatory Commission (NRC) staffs review of the subject application.

By letter dated October 31, 2005, PSEG Nuclear LLC (PSEG, or the licensee) requested relief, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Paragraphs 50.55a(a)(3)(i) and (ii), from the requirements of 10 CFR 50.55a(g)(4)(ii) and Section XI, Subparagraph IWA-2430(d), of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code), for the Salem Nuclear Generating Station (Salem), Unit No. 1. In particular, the licensee requested relief related to the edition and addenda of the ASME Code used for the inservice inspection (ISI) program. Paragraph 10 CFR 50.55a(g)(4)(ii) requires, in part, that the examinations and pressure tests of the ISI program be performed to the latest edition and addenda of the ASME Code incorporated into 10 CFR 55.55a one year before the start of the 10-year ISI interval.Section XI of the ASME Code, Paragraph IWA-2432, requires each inspection interval to consist of a 10-year duration, except as modified by IWA-2430(d).

Subparagraph IWA-2430(d) permits the inspection interval to be extended or decreased by as much as one year, provided that the successive intervals are not altered by more than one year from the original pattern of intervals. The licensee proposed to extend the Salem Unit No. 1 third 10-year ISI interval in order to synchronize the start dates, and thus the utilized ASME Code edition and addenda, for the fourth 10-year ISI interval for both Salem units.

On August 28, 2006, the NRC e-mailed the licensee the enclosed draft requests for additional information. As stated in the initial application, the ISI intervals for both Salem units had already been extended for plant shutdowns and to correspond to refueling outages, as permitted by the ASME Code. The NRC staff was initially unable to determine the length of time that was being requested beyond the extensions allowed by IWA-2430(d) and why the increased interval would still provide an assurance of safety. During subsequent conference calls, the licensee confirmed that the proposed interval extension would be greater than one year.

The NRC staff notes that the licensee performs inspections based on a risk-informed ISI program, which reduces the number of piping inspections performed during the interval. Also, while PSEG indicated that there would be no reduction in the number of inspections, it

W. Levis appeared to the NRC staff that there would be a reduction in the inspection frequency, and the application had not provided a technical justification for further extending the surveillance interval beyond the extensions allowed by IWA-2430(d).

By letter dated October 27, 2006, the licensee withdrew the request, stating that a revised request may be submitted at a later date.

This completes the NRC staffs work under TAC No. MC8847. If you have any questions, please contact me at (301) 415-1321 or snb@nrc.gov.

Sincerely,

/RA/

Stewart N. Bailey, Senior Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-272

Enclosure:

As stated cc w/encls: See next page

Salem Nuclear Generating Station, Unit No. 1 cc:

Mr. Dennis Winchester Township Clerk Vice President - Nuclear Assessment Lower Alloways Creek Township PSEG Nuclear Municipal Building, P.O. Box 157 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. Paul Bauldauf, P.E., Asst. Director Mr. Thomas P. Joyce Radiation Protection Programs Site Vice President - Salem NJ Department of Environmental PSEG Nuclear Protection and Energy P.O. Box 236 CN 415 Hancocks Bridge, NJ 08038 Trenton, NJ 08625-0415 Mr. George H. Gellrich Mr. Brian Beam Plant Support Manager Board of Public Utilities PSEG Nuclear 2 Gateway Center, Tenth Floor P.O. Box 236 Newark, NJ 07102 Hancocks Bridge, NJ 08038 Regional Administrator, Region I Mr. Carl J. Fricker U.S. Nuclear Regulatory Commission Plant Manager - Salem 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 Mr. James Mallon U.S. Nuclear Regulatory Commission Manager - Licensing Drawer 0509 200 Exelon Way, KSA 3-E Hancocks Bridge, NJ 08038 Kennett Square, PA 19348 Mr. Steven Mannon Manager - Regulatory Assurance P.O. Box 236 Hancocks Bridge, NJ 08038 Jeffrie J. Keenan, Esquire PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038

DRAFT REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST TO SYNCHRONIZE INSERVICE INSPECTION INTERVALS SALEM NUCLEAR GENERATING STATION, UNIT NO. 1 PSEG NUCLEAR LLC

1) The first paragraph under the heading "Basis for Relief" discussed the Salem Unit 1 ten year ISI interval schedule. The licensee stated that for the second 10-year ISI interval "This interval excluded 36 Months and 10 Days (April 7, 1995 - April 17, 1998) for extended shutdown..." The licensee needs to verify if this time period was included or excluded. Similar wording is used to discuss the Salem Unit 2 interval schedule. The licensee needs to verify and document if the time periods for extended shutdown are included or excluded IWA-2430(e) and what time periods are extended or decreased to coincide with refueling outages in accordance with IWA-2430(d).

2) The licensee states that for Unit 1 the first interval included 7 months and 16 days to coincide with the end of a refueling outage. For the second interval it appears that the licensee also extended the interval by and additional 2 months and 13 days to coincide with the end of a refueling outage. At this point Unit 1 intervals have been extended by approximately 10 months to coincide with a refueling outage. The current Code of record for Unit 1 is the 1998 Edition through the 2000 Addenda. IWA-2430(d)(1) states, "Each inspection interval my be reduced or extended by as much as one year.

Adjustments shall not cause successive intervals to be altered by more than one year from the original pattern of intervals." Therefore, the licensees illustrations and basis need to be adjusted since there are only approximately two months remaining of the one year allowed adjustment to the original pattern of intervals for Unit 1 (not including extended outages). The licensee needs to clearly identify for Units 1 and 2 what adjustments have been made to the intervals.

3) The licensee states that Salem Unit 1 is scheduled to conclude its third 10-year ISI interval on May 19, 2011 and Unit 2 is scheduled to conclude its third 10-year ISI interval on November 23, 2013. Using the remaining adjustments the staff finds the Unit 1 and 2 intervals are still separated by approximately one year and four months. The licensee needs to provide a technical justification or alternative to reconcile the one year and four months that the Unit 1 and Unit 2 intervals are out of synch. For similar relief requests the staff has only approved reductions in intervals.

ENCLOSURE

ML063340273 OFFICE LPL1-2/PM LPL1-2/LA CPNB/BC LPL1-2/BC NAME SBailey CRaynor TChan HChernoff DATE 12/22/06 12/22/06 12/12/06 12/26/06