ML14135A291
| ML14135A291 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 06/02/2014 |
| From: | John Lamb Plant Licensing Branch 1 |
| To: | Joyce T Public Service Enterprise Group |
| Lamb J, NRR/DORL/LPLI-2 | |
| References | |
| TAC MF3898, TAC MF3899 | |
| Download: ML14135A291 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001
.!une 2, 2014 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236, N09 Hancocks Bridge, NJ 08038
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2- REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR RELIEF SC-14R-140 FROM AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI REQUIREMENTS REGARDING THE REACTOR VESSEL HEAD FLANGE SEAL LEAK DETECTION PIPING (TAC NOS. MF3898 AND MF3899)
Dear Mr. Joyce:
By letter dated April 8, 2014, 1 Public Service Enterprise Group Nuclear LLC (PSEG or the licensee) requested relief from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, for pressure testing the reactor vessel head flange seal leak detection piping at Salem Nuclear Generating Station, Units 1 and 2 (Salem 1 and 2), for the duration of the fourth 10-year inservice inspection (lSI) interval.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) 50.55a(a)(3)(ii),
the licensee requested to use an alternative on the basis that complying with the system leakage test that is required by the ASME Code,Section XI, Table IWB-25001-1, Examination Category B-P; and Table IWC-2500-1, Examination Category C-H would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The U.S. Nuclear Regulatory Commission staff has reviewed the submittal by PSEG and has determined that additional information is needed as set forth in the enclosure.
On May 7, 2014, the draft questions were sent to Mr. Paul Duke of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On May 13, 2014, a conference call was held to clarify the questions. Mr. Duke indicated that PSEG will submit a response within 30 days of the date of this letter.
1 Agencywide Documents and Access Management System (ADAMS) Accession No. ML14098A308.
T.Joyce If you have any questions, please contact me at (301) 415-31 00 or via e-mail at John. Lamb@ nrc.gov.
G. Lam{~ager t Licensing Branch 1-2 Di ision of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311
Enclosure:
Request for Additional Information cc w/encl: Distribution via ListServ
REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR RELIEF SC-14R-140 FROM AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI REQUIREMENTS REGARDING THE REACTOR VESSEL HEAD FLANGE SEAL LEAK DETECTION PIPING SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-272 AND 50-311 By letter dated April 8, 2014, 1 Public Service Enterprise Group Nuclear LLC (PSEG or the licensee) requested relief from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, for pressure testing the reactor vessel head flange seal leak detection piping at Salem Nuclear Generating Station, Units 1 and 2 (Salem 1 and 2), for the duration of the fourth 10-year inservice inspection (lSI) interval.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) 50.55a(a)(3)(ii),
the licensee requested to use an alternative on the basis that complying with the system leakage test that is required by the ASME Code,Section XI, Table IWB-25001-1, Examination Category B-P; and Table IWC-2500-1, Examination Category C-H would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the submittal by PSEG and has determined that additional information is needed as set forth below.
REQUEST FOR ADDITIONAL INFORMATION
- 1. Provide a detailed diagram of the reactor pressure vessel (RPV) head flange seal leak-off lines. Clearly identify and discuss the boundary between the ASME Code Class 1 and Class 2 piping.
- 2. Is any part(s) of the Class 1 and Class 2 RPV flange leak-off piping insulated and inaccessible for the ASME Code required VT-2 visual examination? If yes, discuss how the licensee will perform the VT-2 visual examination of the insulated and inaccessible part(s) of the subject piping.
1 Agencywide Documents and Access Management System (ADAMS) Accession No. ML14098A308.
Enclosure
- 3. The NRC staff notes that in Section 5, Attachment 1 of RFA SC-14R-140, the licensee stated, in part, "In lieu of the requirements of IWB-5222(b) and IWC-5220, a VT-2 visual examination of the Class 1 and Class 2 accessible portions of the leak detection system piping will be performed while the system is subjected to the static pressure from the head of water when the reactor cavity is filled to its normal refueling water level for at least four hours. . .. "
The ASME Code requirement for Class 1 piping in IWB-2500, Table IWB-2500-1, Examination Category B-P, states that the system leakage test shall be conducted in accordance with IWB-5220 and the associated VT-2 visual examination according to IWA-5240, each refueling outage. The system leakage testing requirement in IWB-5220 consists of two subparagraphs, IWB-5221 pressure requirement and IWB-5222 boundary requirement. The pressure requirement in IWB-5221 consists of two subparagraphs, IWB-5221 (a) and IWB-5221 (b). The boundary requirement in IWB-5222 consists of two subparagraphs, IWB-5222(a) and IWB-5222(b).
It appears that the licensee is only requesting relief from the boundary requirement of IWB-5222(b) during system leakage testing performed at or near the end of each inspection interval for Class 1 segment of the subject piping.
- a. Discuss whether the licensee is also asking relief from IWB-5221 (a), IWB-5221 (b), and IWB-5222(a) in addition to IWB-5222(b).
- b. Has the licensee performed the system leakage test of Class 1 segment of the subject piping in accordance with IWB-5220, each refueling outage? If no, discuss whether the licensee is asking relief from the system leakage testing requirements of IWB-5221 (a), IWB-5221 (b), and IWB-5222(a) for each refueling outage.
The ASME Code requirement for Class 2 piping in IWC-2500, Table IWC-2500-1, Examination Category C-H, states that the system leakage testing shall be conducted in accordance with IWC-5220 and the associated VT -2 visual examination according to IWA-5240, each inspection period. The system leakage testing requirement in IWC-5220 consists of two requirements, the IWC-5221 pressure requirement and the IWC-5222 boundary requirement. The boundary requirement in IWC-5222 consists of two subparagraphs, IWC-5222(a) and IWC-5222(b).
It is not clear to the NRC staff from which subparagraph(s) the licensee is asking relief for Class 2 segment of the subject piping.
- c. In light of IWC-5221, IWC-5222(a), and IWC-5222(b), discuss specific subparagraph(s) of IWC-5220 for which the relief was requested.
3 -
- 4. For justifications that the structural integrity and leak tightness of the Class 1 and Class 2 RPV flange leak-off lines will be reasonably ensured without compliance with the ASME Code system leakage testing requirements, discuss whether there has been any plant-specific, fleet, and industry operating experience regarding potential degradation of the subject lines due to known degradation mechanisms that would lead to leakage.
- 5. Discuss leakage detection capabilities at the plant, or any measure(s) that would be taken, to monitor and identify leakage in an unlikely event of a through wall leak in the RPV flange seal leak-off lines concurrent with leak or failure of the RPV flange 0-ring seal during normal operation.
- 6. The licensee in the last paragraph of Section 4, Attachment 1 of RFA SC-14R-140 stated, in part, "The configuration of the leak-off line also precludes pressurizing the line externally with the head installed. . .. The time and radiation exposure associated with removing and reinstalling the closure head, replacing the outer 0-ring and re-cleaning of the vessel flange mating surface prior to head installation would be an undue hardship.
For the above mentioned hardship on the basis of radiation exposure, provide an estimate for roentgen equivalent man exposure with consideration of an as low as reasonably achievable, if the licensee performs the ASME Code required system leakage test with the vessel head installed.
Enclosure
- .. ML14135A291 *via email OFFICE LPL 1-2/PM LPL 1-2/LA ESGB/BC LPL 1-2/BC LPL 1-2/PM NAME Jlamb A Baxter GKulesa* MKhanna Jlamb DATE 05/27/2014 05/21/2014 05/07/2014 06/02/2014 06/02/2014