ML18094A458

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Safety Evaluation Supporting Request to Utilize Code Cases N-448,N-449 & N-356 & Form NR-1 to Document Repairs & Replacements Performed Under Provisions of ASME Section XI
ML18094A458
Person / Time
Site: Salem, Hope Creek, 05000000
Issue date: 05/16/1989
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML18094A457 List:
References
NUDOCS 8906010041
Download: ML18094A458 (4)


Text

UNITED STATES A

CLEAR REGULATORY COMMISSIOr\\19' WASHINGTON, D. C. 20555 SJl.FETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF FROM REGULATORY REQUIREMENT PUBLIC SERVICE ELECTRIC & GAS COMPANY HOPE CREEK GENERATING STATION SALEM GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-354, 272, AND 311

1.0 INTRODUCTION

The Technical Specifications for the Hope Creek Generating Station and the Salem Generating Station Units 1 and 2, state that the surveillance requirements for inservice inspection and testing of ASME Code Class 1, 2, and 3 components shall be applicable as follows:

Inservice Inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel 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 10 CFR. 50.55a(g)(6)(i).

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 preservice examination requirements, set forth in ASME Code,Section XI, "Rules for Inservice Inspection 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 systems pressure tests conducted during the first ten-year interval shall 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) on the date twelve months prior to the date of issuance of the operating license, 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.

Pursuant to 10 CFR 50.55a{g)(5), if _the licensee determines that conformance to an examination requirement of Section XI of the ASME Code is not practical for his facility, information is submitted to the Conlllission in support of the determination and a request made for relief 9906010041 890516

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~bR ADOCK 05000272 Q

PDC from the ASME Code requirement. After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and impose alternative requirements as it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirement were '

imposed.

The Public Service Electric and Gas Company, the licensee, prepared the Hope Creek Generating Station and the Salem Generating Station, Unit No.

1, ISI Program, First Ten-Year Interval to the requirements of Section XI, ASME Code, 1983 Edition, including Summer 1983 Addenda.

The ISI Program, First Ten-Year Interval for the Salem Generating Station, Unit No. 2, was prepared to the requirements of Section XI, ASME Code, 1974 Edition, including Summer 1975 Addenda.

In letter dated July 21, 1988, the licensee informed the Commission that Code Case N-389 would be used to permit repairs and replacements to be made at Salem Generating Station, Unit No. 2, to the rules of Section XI, ASME Code, 1983 Edition, including Summer 1983 Addenda.

Code Case N-389 permits the licensee to select a later approved Section XI Edition and Addenda of the ASME Code when making repairs, replacements, or modifications than those specified in the ISI Program.

The use of Code Case N-389 permits the licensee to make repairs, replacements 9 or modifications at Hope Creek Generating Station, and Salem Generating Station, Unit 1 and 2, to the requirements of Section XI, 1983 Edition, including Summer 1983 Addenda.

The ISI Program at Salem Generating Station, Unit 2, will continue to meet the requirements of Section XI, ASME Code, 1974 Edition, including Summer 1975 Addenda.

In addition, the licensee requested Commission approval to use Code Case N-448, "Qualification of VT-2 and VT-3 Visual Examination Personnel,"

N-449, "Qualification of VT-4 Visual Examination Personnel," and N-356, "Certification Period for Level III NDE Personnel" for the qualification of examination personnel.

In addition, the licensee requested relief from the ASME Code,Section XI, 1983 Edition, including Summer 1983 Addenda, requirement to use Form NIS-2 Owner's Report for Repairs and Replacements.

Form NR-1 Report of Repair-Modification or Installation of Replacement(s) to Nuclear Components and Systems in Nuclear Power Plants, national Board of Boiler and Pressure Vessel Inspectors (National Board)

"NR 11 Certification of Authorization, required by New Jersey state law, would be used in lieu of Form NIS-2.

2.0 EVALUATION Relief Request NLR-N87232-1 Commission approval was requested for the use of Code Cases N-448, "Qualification of VT-2 and VT-3 Visual Examination Personnel," M-449, "Qualification of VT-4 Visual Examination Personnel," and N-356, "Certification Period for Level III NDE Personnel."

"., Code Case N-389, "Alternative Rules for Repairs, Replacements, or Modifications," has been approved by the Commission and provides for the use of approved ASME Code,Section XI, Editions and Addenda, subsequent to that specified in the Owner's Inservice Inspection Program.

The licensee informed the Commission that the rules for component repair and replacement of the 1983 Edition, including Summer 1983 Addenda of the ASME Code,Section XI, would be used at the Salem Generating Station, Unit 2.

The preservice and inservice inspection programs will continue to meet the requirements of the 1974 Edition, including Summer 1975 Addenda of Section XI of the ASME Code.

Code Cases N-448, N-449 and N-356 are in the process of being approved by the Commission.

Approval is expected to be completed by July 30, 1989.

The staff concludes from its review of the information submitted by the licensee in letter dated July 21, 1988, the Code Cases N-448, N-449, and N-356 are acceptable and may be used as requested for the qualification of examination personnel at the Hope Creek Generating Station and the Salem Generating Station, Unit 1 and 2.

Relief Request NLR-N87232-2 The licensee requested relief from the requirement of paragraph IWA-7520{a){8) of Section XI, 1983 Edition, including the Summer 1983 Addenda, requiring the Form NIS-2, Owner's Report for Repairs or Replacements, be completed and maintained by the Owner.

The licensee posses a National Board of Boiler and Pressure Vessel Inspectors {National Board) "NR" Certificate of Authorization, which is required by New Jersey state law.

In accordance with the provisions of the National Board Inspection Code and the New Jersey state law, repairs and replacements performed under the NR Certificate of Authorization must meet the requirements of Section XI of the ASME Code, and be documented on the National Board Form NR-1.

The licensee requested relief from the ASME Code Section XI requirement to use the NIS-2 form and proposed as an alternative the use of the National Board NR-1 form to document repairs or replacements.

As justification of this request, the licensee stated generation of both forms would be a duplication of effort, and create the potential for inconsistencies in reporting.

Both forms require certification of similar information.

In addition, when the forms are completed, Form NIS-2 would be maintained by the Owner, while Form NR-1 would be submitted to the National board and to the State of New Jersey, and maintained by the Owner.

We conclude from our review that relief from the requirements of paragraph IWA-7520{a){8) of Section XI, 1983 Edition, including Sununer 1983 Addenda, requiring the use of Form NIS-2, is granted for Hope Creek

I

" Generating Station and Salem Generating Station, Unit 1 and 2.

In lieu of Form NIS-2, the National Board form NR-1 may be used at those facilities to document repairs or replacements as required by this edition of the ASME Code.

However, we recommend that the licensee submit an inquiry to the Section XI ASME Committee to determine an acceptable alternative to the requirement of paragraph IWA-7520(a)(8).

3. 0 CONCLUSION We conclude from our evaluation of information submitted in letter dated July 21, 1988, that Code Cases N-448, N-449 and N-356 are approved for use and that Form NR-1 may be used to document repairs and replacements at the Hope Creek Generating Station and Salem Generating Station, Units 1 and 2.

Information required for Form NR-1 is essentially identical to the information required in the ASME Code approved Form NIS-2.