ML18094B423

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SER Concluding That Second 10-yr Interval Inservice Insp Program Plan,W/Addl Info Provided & Relief Requests, Constitutes Basis for Compliance w/10CFR50.55a(g) & Acceptable
ML18094B423
Person / Time
Site: Salem PSEG icon.png
Issue date: 04/17/1990
From:
Office of Nuclear Reactor Regulation
To:
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ML18094B422 List:
References
NUDOCS 9004260038
Download: ML18094B423 (48)
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e UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0. C. 20555 ENCLOSURE 1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE SECOND TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN PUBLIC SERVICE ELECTRIC ANO GAS COMPANY SALEM GENERATING STATION, UNIT 1 DOCKET NO. 50-272

1.0 INTRODUCTION

Technical Specification 4.0.5 for the Salem Generating Station, Unit 1, states that the surveillance requirements for Inservice Inspection and Testing of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, 2, and 3 components shall be applicable as follows:

Inservice Inspection of ASME Code Class l, 2, and 3 components sh'a~l be performed in accordance with Section XI of the ASME Code and applicable Addenda as required by 10 CFR 50.55a(g) 9 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 suppotts) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, 11Rules 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 system pressure tests conducted during the second ten-year interval comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.SSa(b) on the date twelve months prior to the start of the 120-month inspection 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 ASHE Code incorporated by reference in 10 CFR 50.SSa(b) subject to the limitations and modifications listed therein.

Pursuant to 10 CFR 50.SSa(g)(S), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for his facility, information shall be submitted to the Commission in support of that.determination and a request made for relief 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 may impose alternative requirements that are determined to be authorized by law, 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 requirements were imposed.

The Commission may also grant relief by authorizing alternatives to Code requirements, pursuant to 10 CFR 50.55a(a){3){i), if the proposed alternatives will provide an acceptable level of quality and safety.

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PDR ADOCK 05000272 Q

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e e The licensee, Public Service Electric and Gas Company, has prepared the Salem Generating Station, Unit 1. Second Ten-Year Interval Inservice Inspection (ISI)

Program Plan, Revision 0, to meet the requirements of the 1983 Edition, Summer 1983 Addenda of Section XI of the ASME Boiler and Pressure Vessel Code except that the extent of examination for Class 2 piping welds has been determined by ASME Code Case N-408 as approved for use by NRC Regulatory Gui de 1.147. The staff, with technical assistance from its Contractor,: the Idaho National Engineering laboratory ( INEL). has evaluated the Seco:nd Ten-Year I nterva 1 Inservice Inspection Program Plan, Revision 0, the additional information related to the plan, and the requests for relief from certain ASME Code requirements determined to be impractical for Salem Generating Station, Unit l, during the second inspection interval.

2.O EVALUATION The ISI Program Plan has been evaluated for (a) application of the correct Section XI Code edition and addenda, (b) compliance with examination and test requirements of Section XI, (c) acceptability of the examination sample, (d) compliance with prior ISI commitments made-by the licensee, (e) correctness of the application of system or component examination exclusion criteria, and (f) adequate information in support of requests for relief from impractical Section XI Code requirements.

The staff has determined that the licensee's ISl Program Plan reflects compliance with the requirements listed above.

The information provided by the Licensee in support of requests for relief from impractical requirements and proposed alternatives has been evaluated and the bases for granting relief from those requirements are documented in the attached INEL Technical Evaluation Report EGG-MS-8435.

We concur with, and adopt, the findings and recommendations contained in the subject report.

Table 1 presents a summary of the reliefs requested and the status of the requests as determined by the staff.

3. 0 CONCLUSION The staff concludes that the Salem Generating Station, Unit 1, Second Ten-Year Interval Inservice Inspection Program Plan, Revision 0, with the additional information provided and the specific written relief, constitutes the basis for compliance with 10 CFR 50.55a(g) and Technical Specification 4.0.5 and is therefore acceptable.

With respect to the relief granted, the staff has determined, pursuant to 10 CFR 50.5Sa(a)(3){i) that the alternative proposed will provide an acceptable level of quality and safety or, pursuant to 50.55a(g)(6)(i), that the require-ments of the code are impractical and based on the alternative requirements imposed, relief is authorized by law, 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 that could result if the requirements were imposed on the facility.

Attachment:

Table 1, Summa~y of Relief Requests Dated:

Principal Contributor:

!;eorge Johnson

Salem Generating Station, Unit I Page I of 5 1

Relief Request Number (part 2 of 8) 1 (part 2 of 8)

I (part I of 8) 1 (part 3 of 8)

System or Component Exam.

Cat.

Pressurizer 8-f Pressurizer 8-f Class l Piping Pressurizer 8-H Safety Injection System 8-J TABLE 1

SUMMARY

OF RELIEF REQUESTS Item No.

Volume or Area to be Examined 85.40 Nozzle-to-safe end weld 4-PS-1131-29 85.130 Dissimilar metal welds:

4-PR-1100-1 6-PR-1103-1 6-PR-1104 -1 6-PR-1105-1 88.20 lower head-to-support skirt weld 89.ll Class 1 elbow-to-branch connection weld 6-SJ-ll 41-18 Required Method Volumetric and surface Volumetric and surf ace Volumetric and surf ace Licensee Proposed Alternative None.

100%

surf ace examination and volumetric examination to maximum extent practical None.

100%

surface examination and volumetric examination to maximum extent practical

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ATIACHMENT Relief Request Status Granted Granted Withdrawn A based on co*

Case N-460 None.

100%

Granted surf ace examination and volumetric examination to maximum.extent practical (adjacent weld will be examined to increase coverage)

Salem Generating Station, Unit l Page 2 of 5 TABLE l

SUMMARY

OF RELIEF REQUESTS Relief Licensee Request System or Exam.

Item Volume or Area Required Proposed Relief Request Number Comgonent Cat.

No.

to be Examined Method Alternative Status I

RHR Heat C-A Cl. IO Shell-to-flange weld Volumetric 100% surface Granted e (part 4 Exchanger 12-RHRHEX-2 examination and of 8) volumetric examination to maximum extent practical 1

Regen.

C-A Cl. 30 Shell-to-tubesheet welds:

Volumetric None.

Granted (part 4 Heat l-RHE-2 Volumetric of 8)

Exchanger l-RHE-3 examination of l-RHE-11 only welds l-RHE-12 l-RHE-2 and l-RHE-3 to maximum extent practical 1

RHR Heat C-8 C2.21 Nozzle-to-she 11 welds:

Volumetric None.

100%

Granted (part 5 Exchangers 11-RHRHEX-IN and surf ace surf ace of 8) 11-RHRHEX-OUT examination and 12-RHRHE:X-IN volumetric 12-RHRHEX-OUT examination to maximum extent practical

Salem Generating Station, Unit 1 Page 3 of 5 Relief Request System or Exam.

Number

. Com~onent Cat.

1 Class 2 C-C (part 6 Main Steam of 8)

Piping I

Class 2 C-C (part 1 Main Steam of 8)

Valves Item No.

CJ.20 CJ.40 TABLE 1

SUMMARY

OF RELIEF REQUESTS Licen~ee Volume or Area Required Proposed Relief Request to be Examined Method Alternative Status Pipe support Surface None.

Surf ace Granted e 32-MS-2121-2PS-2 and examination of Integrally welded lugs:

pipe support 32-MS-214l-2WPA lugs I 32-MS-2121-2PS-2 through 4.

to maximum 32-MS-2l31-2WPA lugs )

extent practica 1 through 4, 32-MS-2l21-2WPA lugs 1 through 4, 32-MS-2111-2WPA lugs l through 4 Integrally welded

~ Surface None.

Surface Granted supports:

examination to 12-MS-167-VS-lA maximum extent e

12-HS-167-VS-IB practical 13-MS-167-VS-2 13-MS-167-VS-2A 13-MS-167-VS-28 14-MS-167-VS-2 14-MS-l67-VS-2A 14-MS-167-VS-28

Salem Generating Station, Unit I Page 4 of 5 TA8Lf 1

SUMMARY

OF RELIEF REOUESTS Relief Request Number 1

(part 8 of 8) 2 3

System or Component Class 2 Piping Reactor Coolant Pumps Reactor Coolant Pumps Exam.

Item Volume or Area Cat.

No.

to be Examined C-F-1 C5. ll Circumferential welds:

14-RH-2114-18 8-RH-2126-l 6-SJ-2104-4 8-L-l 812.10 Casing welds 8-l-2 812.20 Internal surfaces of casings Required Method Volumetric and surf ace Volumetric VT-3 visual Licensee Proposed Alternative Relief Request Status None.

100%

Granted

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surf ace examination and volumetric examination lo maximum extent practical (also, four additional we l d s w i ll be examined)

Surface and VT-3 visual examinations of the external surface of welds Granted provided that volumetric examination is performed whenever piA is comp 1 ete..,,.

disassembled VT-3 visual Granted examination when pump is disassembled for maintenance

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Salem Generating Station, Unit 1 Page 5 of 5 Relief Request Number 4

5 6

System or Com~onent Residual Heat Removal and Safety Injection Systems Mechanical and Hydraulic Snubbers Class 3 Anchors Exam.

Cat.

C-H 0-8 and F-C TABLE 1

SUMMARY

OF RELIEF REQUESTS Item Volume or Area No.

to be Examined Cl.40 Class 2 RHR piping:

Approx. 4 ft between valves IRH45 and IRH33, and approx. 4 ft between valves IRH46 and IRH24 Class 2 SJ piping:

Approx. 14 ft between valves 11SJ96 and llSJ98, and approx. 14 ft between valves 12SJ96 and 12SJ98 Note:

The functional testing of snubbers is not included in this evaluation.

Functional tests are not within the scope of this document and will be evaluated elsewhere.

02.20 and FJ.30 Integral attachments of anchors:

M-SWPA-006 M-SWPA-012 M-SWPA-013 M-SWPA-025 P-SW-A-WSll P-SW-A-WS13 P-SW-A-WSl5

l. 25 times system pressure VT-3 and
  • VT-4 visual examinations per IWF-2000 VT-3 visual Licensee Proposed Alternative Surface examination and inservice pressure test at nominal.

operating pressure Visual examinations per Salem Technical Specifications

_I I

r Relief Requesl Status Granted e Granted None.

VT-2 Granted visual examination during pressure tests and during visual examinations of adjacent pipe supports

EGG-MS-8435 TECHNICAL EVALUATION REPORT ON THE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

PUBLIC SERVICE ELECTRIC AND GAS COMPANY, SALEM GENERATING STATION, UNIT 1, DOCKET NUMBER 50-272 B. W. Brown J. 0. Mudlin Published November 1989 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls~ Idaho 83415 Prepared for:

U.S. Nuclear Regulatory Commission Washington, D.C.

20555 under DOE Contract No. DE-AC07-76ID01570 FIN No. D6022 (Project 5)

ABSTRACT This report presents the results of the evaluation of the Salem Generating Station, Unit 1, Second 10-Year Interval Inservice Inspection (ISI) Program Plan, Revision 0, submitted in letters dated October 23, 1987 and December 23, 1987, including the requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical.

The Salem Generating Station, Unit 1, Second 10-Year Interval ISI Program Plan is evaluated in Section 2 of this report.

The !SI Program Plan is evaluated for (a) compliance with the appropriate edition/addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with !SI-related commitments identified during the Nuclear Regulatory Commission's (NRC) previous reviews.

The requests for relief are evaluated in Section 3 of this report.

This work was funded under:

U.S. Nuclear Regulatory Commission FIN No. 06022, Project 5 Operating Reactor Licensing Issues Program, Review of ISi for ASME Code Class 1, 2, and 3 Components i i

SUMMARY

The Licensee, Public Service Electric and Gas Company, has prepared the -

Salem Generating Station, Unit 1, Second IO-Year Interval Inservice Inspection (!SI) Program Plan, Revision 0, to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examination for Code Class* 2 piping welds has been determined by ASME Code Case N-408, "Alternative Rules for Examination of Class 2 Piping,Section XI, Division 1." The second 10-year interval began JJnuary 1, 1988 and ends January 1, 1998.

The information in the Salem Generating Station, Unit 1, Second 10-Year Interval IS! Program Plan, Revision 0, was reviewed.

Included in the review were the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical for the second 10-year interval.

As-a result of this review, a request for additional information (RAI) -was prepared describing the information and/or clarification required from the Licensee in order to complete the review.

The Licensee provided the requested information in the submittal dated February 1, 1989.

Based on the review of the Salem Generating Station, Unit 1, Second 10-Year-Interval ISI Program Plan, Revision 0, the Licensee's response to the Nuclear Regulatory Commission's RAI, and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Salem Generating Station, Unit 1, Second 10-Year Interval ISI Program Plan, Revision 0, is acceptable and in compliance with 10 CFR 50.55a(g)(4).

; i

CONTENTS ABSTRACT.......................... * *..... *....... * *...... * * *.. *.. * *....... i ;

SUMMARY

.*.*..*...*.*****************.*.*..* ~ *. * *. * *. * * * * *. * *. * *. * * *. *. * ; i ;

I.

INTRODUCTION a **************************************** ~ *********** o ** o 1

2.

EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN...................... 4 2.1 Documents Evaluated.......................... *..................... 4 2.2 Compliance with Code Requirements................................. 4 2.2.1 Compliance with Applicable Code Editions...................... 4 2.2.2 Acceptability of the Examination Sample....................... 5 2.2.3 Exclusion Criteria *******************************~************ 5 2.2.4 Augmented Examination Commitments............................. 5

2. 3 Cone 1 us ions....................................................

0

  • 6
3.

EVALUATION OF RELIEF REQUESTS........................................ 7

3. I Cl ass I Components................................................ 7 3.1.1 Reactor Pressure Vessel (No relief requests) 3.1.2 Pressurizer...............................................

0 *** 7 3.1.2.1 Request for Relief No. 1 (Part 1 of 8), Examination Category B-H, Item B8.20, Pressurizer Lower Head-to-Support Skirt Weld.....**......................... 7 3.1.3 Heat Exchangers and Steam Generators (No relief requests) 3.1.4 Piping Pressure Boundary...................................... 7 3.1.4.1 Request for Relief No. 1 (Part 2 of 8), Examination Category B-F, Items BS.40 and BS.130, Pressure Retaining Dissimilar Metal Welds.......................... 7 3.1.4.2 Request for Relief No. 1 (Part 3 of 8), Examination Category B-J, Item B9.ll, Class 1 Circumferential Pi ping We 1 ds.............................................. 9 3.1.5 Pump Pressure Boundary....................................... 10 3.1.5.1 Requests for Relief Nos. 2 and 3, Examination Categories B-L-1 and B-L-2, Items 812.10 and Bl2.20, Class 1 Pressure Retaining Welds in Pump Casings and Internal Surfaces of Pump Casings.................... 10 iv

.3.1.6 Valve Pressure Boundary (No relief requests) 3.1.7 General (No relief requests) 3.2 Class 2 Components............................................... 14 3.2.1 Pressure Vessels....................... ;..................... 14 3.2.1.1 Request for Relief No. 1 (Part 4 of 8), Examination Category C-A, Items Cl.10 and Cl.30, Pressure Retaining Welds in Class 2 Pressure Vessels.............. 14 3.2.1.2 Request for Relief No. 1 (Part 5 of 8), Examination Category C-8, Item C2.21, Pressure Retaining Nozzle Welds in Class 2 Vessels................................. 17 3.2.2 Piping ***************************o*************************** 19 3.2.2.1 Request for Relief No. 1 (Part 6 of 8), Examination Category C-C, Item C3.20, Integrally Welded Attachments for Class 2 Piping........................... 19 3.2.2.2 Request for Relief No. 1 (Pa.rt 8 of 8), Examination Category C-F-1, Item CS.11, Class 2 Circumferential Pip i ng Welds............. ". o *

  • 21 3.2.3 Pumps (No relief requests) 3.2.4 Valves.............. o **************************************** 23 3.2.4.1 Request for Relief No. 1 (Part 7 of 8), Examination Category C-C, Item C3.40, Integrally Welded Attachments for Class 2 Valves........................... 23 3.2.5 General (No relief requests) 3.3 Class 3 Components (No relief requests)
3. 4 Pressure Tests................................................... 24
  • 3.4.1 Class 1 System Pressure Tests (No relief requests) 3.4.2 Class 2 System Pressure Tests................................ 24 3.4.2.1 Request for Relief No. 4, Examination Category C-H, Item C7.40, Hydrostatic Pressure Test of Class 2 Piping in the Residual Heat Removal and Safety Injection Systems........................................ 24 3.4.3 Class 3 System Pressure Tests (No relief requests) 3.4.4 General (No relief requests) v

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3:5 General.......................................................... 27 3.5.1 Ultrasonic Examination Techniques (No relief requests) 3.5.2 Exempted Components (No relief requests) 3.5.3 Other........................................................ 27 3.5.3.l Request for Relief No. 5, VT-3 and VT-4 Visual Examinations of Snubbers................................. 27 3.5.3.2 Request for Relief No. 6, Examination Categories 0-8 and F-C, Items 02.20 and F3.30, Class 3 Anchors and Their Associated Integral Attachments.................... 29

4.

CONCLUSION.......................................................... 32

5.

REFERENCES........................................... *.............. 34 vi

  • TECHNICAL EVALUATION REPORT ON THE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

PUBLIC SERVICE ELECTRIC AND GAS COMPANY, SALEM GENERATING STATION, UNIT 1, DOCKET NUMBER 50-272

1.

INTRODUCTION Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) (Reference 1) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," (Reference 2)* to the extent practical within the limitations of design, geometry, and materials of construction of the component~: This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during the successive 120-month inspection intervals shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein.

The Licensee, Public Service Electric and Gas Company, has prepared the Salem Generating Station, Unit 1, Second 10-Year Interval Inservice Inspection (ISI) Program Plan, Revision 0, to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examination for Class 2 piping welds has been determined by ASME Code Case N-408, "Alternative Rules for Class 2 Piping 11 (Reference 3). The second 10-year interval began January 1, 1988 and ends January 1, 1998.

As required by 10 CFR S0.55a(g)(S), if the licensee determines that certain Code examination requirements are impractical and requests relief from them, 1

the 1icensee shall submit information and justifications to the Nuclear Regulatory Commission (NRC) to support that determination.

Pursuant to 10 CFR 50.55a(g)(6), the NRC will evaluate the licensee's determinations under 10 CFR 50.55a(g)(5) that Code requirements are impractical.

The NRC may grant relief and may impose alternative requirements that are determined to be authorized by law, 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 requirements were imposed on the facility.

The information in the Salem Generating Station, Unit 1, Second 10-Year Interval ISI Program Plan, Revision 0, submitted by letters dated October 23, 1987 (Reference 4) and December 23, 1987 (Reference 5), was reviewed, including the requests for relief from the ASME Code Section XI requirements which the Licensee has* determfn'ed to be impractical.

The review of the ISI Program Plan was performed using the Standard Review Plans of NUREG-0800 (Reference 6), Section 5.2.4, "Reactor Coolant Boundary Inservice Inspections and Testing,~ and Section 6.6, "Inservice Inspection of Class 2 and 3 Components."

In a letter dated November 9, 1988 (Reference 7), the NRC requested additional information required in order to complete the review of the ISI Program Plan.

The requested information was provided by the Licensee in a letter dated February 1, 1989 (Reference 8).

The Salem Generating Station, Unit 1, Second 10-Year Interval ISI Program Plan is evaluated in Section 2 of this report.

The ISI Program Plan is evaluated for (a) compliance with the appropriate edition/addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with !SI-related commitments identified during the NRC's previous reviews.

The requests for relief are evaluated in Section 3 of this report. Unless otherwise stated, references to the Code refer to the ASME Code,Section XI, 2

1983 Edition including Addenda through Summer 1983.

Specific inservice test (IST) programs for pumps and valves are being evaluated in other reports.

3

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2.

EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN This evaluation consisted of a review of the applicable program documents to determine whether or not they are in compliance with the Code requirements and any previously *identified licensing conditions pertinent to ISI activities. This section describes the Licensee's submittals reviewed and the results of the review.

2.1 Documents Evaluated Review has been completed on the following information from the Licensee:

(a)

(b)

(c) 2.2 Letter, dated October 23, 1987, transmittal of "Inservice Inspection Program Second Ten-Year Interval Salem Generating Station, Unit l;"

Letter, dated December 23, 1987, transmittal of "Inservice Inspection Program Boundary Diagrams" for Salem Generating Station, Unit l; and Letter, dated February 1, 1989, reiponse to the NRC request for additional information.

Comoliance with Code Requirements 2.2.l Compliance with Applicable Code Editions The Inservice Inspection Program Plan shall be based on the Code editions defined in 10 CFR 50.55a(g)(4) and 10 CFR 50.SSa(b).

Based on the starting date of January 1, 1988, the Code applicable to the second 10-year interval is the 1983 Edition with Addenda through Summer 1983.

As stated in Section 1 of this report, the Licensee has prepared the Salem Generating Station, Unit l, Second 10-Year Interval ISI Program Plan, Revision 0, to meet the requirements of the 1983 Edition with Addenda through Summer 1983 of the ASME Code Section XI except that the extent of examination for Code Class 2 piping welds has been determined by ASME Code Case N-408, "Alternative Rules for Examination of Class 2 Piping, 4

SE!"ction XI, Division 1.

11 ASME Code Case N-408 is referenced in Regulatory Guide 1.147, Revision 6 (Reference 9), as an NRC-approved code case and, therefore, may be used.

2.2.2 Acceptability of the Examination Sample Inservice.volumetric, surface, and visual examinations shall be performed on ASME Cride Class 1, 2, and 3 components and their supports using sampling schedules described in Section XI of the-ASME Code and 10 CFR 50.55a{b}.

In response to the NRC request for additional information, the Licensee committed to perform volumetric and surface examinations of 14 Class 2 piping welds in the Containment Spray System which meets the 7.5% requirement of ASME Code Case N-408.

The Licensee also committed to increase the total number of welds to be examined in the RHR system from 10 welds to 15 welds (increased from 5.3% to approximately 8%).

Based on review of the ISi Program"P"lan and the Licensee's commitments, sample size and weld selection have been implemented in accordance with the Code and appear to be correct.

2.2.3 Exclusion Criteria The criteria used to exclude components from examination shall be consistent with Paragraphs IWB-1220, IWC-1220, IWC-1230, IW0-1220, and 10 CFR 50.55a(b).

The exclusion criteria have been applied by the Licensee in accordance with the Code as discussed in the ISI Program Plan and.appear to be correct.

2.2.4 Augmented Examination Commitments In addition to the requirements as specified in Section XI of the ASME Code, the Licensee has committed to perform the following augmented examinations:

(a)

Inservice examinations in accordance with NRC Regulatory Guide 1.150, Revision 1 (Reference 10), "Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examiriations;"

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Ultrasonic and surface examinations of the reactor coolant pump flywheels in accordance with NRC Regulatory Guide 1.14, Revision 1 (Reference 11), "Reactor Coolant Pump Flywheel Integrity; 11 (c}

Ultrasonic examination of selected welds in stagnated portions of systems containing austenitic stainless steel for intergranular stress corrosion cracking; and (d}

Class 1 Bolting:

The Steam Generator primary side manway bolting receives a surface examination when disassembled and a visual examination for evidence of boric acid each refueling outage.

The Reactor Coolant Pump flange bolting receives a visual examination for evidence of boric acid buildup each refueling outage.

2.3 Conclusions Based on the review of the documents listed above, it is concluded that the Salem Generating Station, Unit 1, Second 10-Year Interval ISI Program Plan, Revision 0, is acceptable and in compliance with 10 CFR S0.55a(g)(4).

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3.

EVALUATION OF RELIEF REQUESTS The requests for relief from the ASME Code requirements that the Licensee has determined to be impractical for the second 10-year inspection interval are evaluated in ~he following sections.

It should be noted that, in response to the NRC request for additional information, the Licensee's letter of February 1, 1989 states that ASME Code Case N-460 is being used as requested in the Licensee's January 26, 1989 letter (Reference 12) and as approved by NRC letter dated February 3, 1989 (Reference 13) and, therefore, that relief is no longer necessary for certain welds originally included in Request for Relief No. 1 because the reduction in coverage is less than 103.

3.1 Class 1 Comoonents 3.1.1 Reactor Pressure Vessel (No relief requests) 3.1.2 Pressurizer 3.1.2.1 Request for Relief No. 1 (Part 1 of 8), Examination Category B-H, Item 88.20. Pressurizer Lower Head-to-Support Skirt Weld NOTE:

This portion of Request for Relief No. 1 was deleted by the Licensee based on ASME Code Case N-460.

3.1.3 Heat Exchangers and Steam Generators (No relief requests) 3.1.4 Piping Pressure Boundary 3.1.4.1 Request for Relief No. 1 (Part 2 of 8), Examination Category B-F. Items BS.40 and BS.130, Pressure Retaining Dissimilar Metal Welds Code Requirement:

Section XI, Table IWB-2500-1, Examination Category B-F, Item BS.40 requires both 100% volumetric and 7

surface examinations of the pressurizer nozzle-to-safe end butt welds of nominal pipe sizes 4 inches and greater as defined by Figure IWB-2500-8.

Examination Category B-F, Item 85.13.0 requires both 1003 volumetric and surface examination of the Class 1 piping dissimilar metal butt welds of nominal pipe sizes 4 inches and greater as defined by Figure IWB-2500-8.

Licensee's Code Relief Request:

Relief is requested from examining 100% of the Code-required volume of the following nozzle-to-safe end welds:

Item Number*

BS.40 BS.130 BS.130 BS.130 BS.130 Weld Number 4-PS-1131-29 4...P..R-1100-1 6-PR-1103-1 6-PR-1104-1 6-PR-llOS-l Licensee's Proposed Alternative Examination:

None.

These welds will receive the complete Code-required surface examinations.

In the Licensee's February 1, 1989 response to the NRC RAI, the Licensee stated that coverage will be maximized on the pressurizer dissimilar metal welds, but only 30 to SO% of the examination area can be volumetrically examined and that volume only on the weld for reflectors perpendicular to the weld.

Licensee's Basis for Requesting Relief:

The Licensee states that complete examination of the Code-required volume is not obtainable but that 100% of the weld length can be scanned from the weld surface.

Due to the nozzle and safe end configurations, scanning from the base material is not possible.

As demonstrated during the first inspection interval, complete surface examination coverage and 0-degree and 4S-degree ultrasonic examinations from the weld surface are obtainable.

8

e e

Evaluation:

The volumetric examination of the subject nozzle-to-safe end welds is impractical to perform to the extent required by the Code because of the configuration of the nozzle and safe end.

The limited Section XI volumetric examination and the complete Code-required surface examination provide reasonable assurance of the continued inservice structural integrity of these welds.

==

Conclusions:==

Based on the above evaluation, it is concluded that the volumetric examination of the subject welds is impractical to perform to the extent required by the Code.

Therefore, it is recommended that relief be granted as requested.

3.1.4.2 Request for Relief No. 1 (Part 3 of 8). Examination Category 8-J, Item 89.11, Clas'S"' l Circumferential Piping Welds Code Requirement:

Section XI, Table IWB-2500-1, Examination Category 8-J, Item 89.11 requires both 100% volumetric and surface examinations of the Class 1 pressure retaining circumferential piping welds of nominal pipe sizes 4 inches and greater as defined by Figure IWB-2500-8.

Licensee's Code Relief Request:

Relief is requested from examining 100% of the Code-required volume of Class 1 elbow-to-branch connection weld 6-SJ-1141-18 in the Safety Injection system.

Licensee's Proposed Alternative Examination:

None.

The weld will receive the complete Code-required surface examination.

The Code-required volumetric examination will be performed to the maximum extent possible. Also, in the Licensee's February 1, 1989 response to the NRC RA!, the Licensee committed to examine an additional adjacent weld (weld 6-SJ-1141-17) on the same line to increase overall coverage of the system.

9

Licensee's Basis for Requesting Relief:

The Licensee states that complete examination of the Code-required volume is not obtainable but that 100% of the weld length can be scanned from the weld surface.

Due to the elbow and branch connection configurations, scanning from the base material is not possible.

As demonstrated during the first inspection interval, complete. surface examination coverage and 0-degree and 45-degree ultrasonic examinations from the weld surface are obtainable.

Evaluation:

The volumetric examination of the subject circumferential pipin.g weld is impractical to perform to the extent required by the Code because of the geometric configuration of the elbow and branch connection.

The limited Section XI volumetric examination, the complete Code-required surface examination of the subJect weld, and the examination of an additional weld (this additional weld is not a terminal end) an the same line provide reasonable assurance of the continued inservice structural integrity of the weld.

It should be noted that nine welds were deleted from this relief request by the Licensee based on ASME Code Case N-460.

==

Conclusions:==

Based on the above evaluation, it is concluded that the volumetric examination of the subject weld is impractical to perform to the extent required by the Code.

Therefore, it is recommended that relief be granted as requested.

3.1.5 Pump Pressure Boundary 3.1.5.1 Requests for Relief Nos. 2 and 3, Examination Categories B-L-1 and B-L-2. Items 812.10 and 812.20. Class 1 Pressure Retaining Welds in Pump Casings and Internal Surfaces of Pump Casings Code Requirement:

Section XI, Table IWB-2500-1, Examination Category B-L-1, Item Bl2.10 requires a 100% volumetric 10

examination of the Class 1 pressure retaining pump casing welds as defined by Figure IW8~2500-16. Examination Category 8-L-2, Item 812.20 requires a 100% visual (VT-3) examination of the internal surfaces of Class 1 pump casings.

The examinations are limited to welds in at least one pump in each group of pumps performing similar functions in the system.

The visual examination of the internal surfaces may be performed on the same pump selected for volumetric examination of the welds.

Licensee's Code Relief Request:

Relief is requested from performing the Code-required visual (VT-3) examination of the internal surfaces of the pump casings of the reactor coolant pumps unless disassembled for maintenance and from performing the Code-required volumetric examination of the pump casing welds.

Licensee's Proposed Alternative Examination:

The Licensee states that a surface examination of the external surface of the weld will be performed.

A VT-3 visual examination will be performed on the external pressure boundary surfaces of the pump casing weld in conjunction with the surface examination performed. Also, a VT-3 visual examination of the internal surfaces will be performed when the pump is disassembled for maintenance.

Licensee's Basis for Requesting Relief:

The Licensee states that, currently, there are no plans for disassembly of any of the reactor coolant pump casings for maintenance.

NRC Safety Evaluation Report dated August 12, 1981 granted relief from the volumetric requirements of the Code Item 85.6 Category B-L-1 such that only surface examination on the external surface of the weld is required to be performed.

As such, PSE&G has been evaluating new techniques for volumetrically examining the pump casing welds.

Such a technique exists using the Miniature Linear Accelerator (MINAC) which was built under an EPRI sponsored program.

This equipment hal been made available to 11

other utilities and currently constitutes the only method available for the volumetric examination of reactor coolant pump casing welds.

This examination has been performed at several sites. The MINAC examination was performed at Ginna in the spring of 1981, at Point Beach, Unit 1, in the fall of 1981, at Turkey Point, Unit 3, early in 1982, and at H. B. Robinson, Unit 2, later in 1982.

No problems with welds were found at any of the sites.

The successful performance of this volumetric examination using the MINAC demonstrates that the method is capable of satisfying ASME Section XI examination requirements.

Based on the following information, however, the Licensee does not plan to use this technique.

The volumetric examination method is radiographic and is performed by placing the MINAC inside the pump casing and pl acing fi.lm on the outside of the pump.

To perform the examination, the pump must be completely disassembled.

This disassembly is far beyond that performed for normal maintenance.

In addition, insulation must be* removed from the exterior of the pump casing.

The performance of the examination has shown that there is a relatively high radiation exposure associated with it. The total exposure associated with insulation removal, disassembly, examination, and reassembly -0f the pump has averaged about 40 man-rem.

The pump casing examination is also not justified from a cost/benefit perspective. The pump disassembly, examination, and reassembly are estimated to cost $750,000.

Based on the preceding factors, the Licensee does not consider it justifiable to disassemble these pumps for the sole purpose of performing these examinations. Therefore, relief is 12

e required from performing the e

visual examination of the pump internal pressure retaining surfaces unless disassembled for maintenance and the volumetric examination of the pump casing weld.

£valuation:

The visual examination is performed to determine

___ whether unanticipated severe degradation of the casing is occurring due to phenomena such as erosion, corrosion, or cracking.

However, previous experience during examination of similar pumps at other plants has not shown any significant

  • degradation of pump casings.

The concept of visual examination of the internal surfaces of the pump casing if the pump is disassembled for.maintenance is acceptable.

The disassembly of the pumps for the sole purpose of inspection is a major effo,~ and, in addition to the possibility of damage to the pumps, could result in personnel receiving excessive radiation exposure.

The Licensee has committed to perform surface and visual (VT-3) examinations of the external surface of the pump casing welds.

With regard to the volumetric examination of the pump casing welds, the Licensee has stated that the volumetric examination will not be performed even if the pumps are disassembled for normal maintenance because the volumetric examination of the pump casing welds requires complete disassembly which is far beyond that required for normal maintenance.

Based on the ALARA considerations, the disassembly of the pumps for the sole purpose of performing the volumetric examination of the pump casing welds is impractical. However, if a pump is completely disassembled such that the weld is exposed and volumetric examination of the weld is possible, the Licensee should perform the volumetric examination.

It should be noted that other Westinghouse plants that have requested this same 13

      • -:~
-:~

relief have committed to perform the Code-required volumetric examination of the pump casing weld if the pump is disassembled for maintenance.

==

Conclusions:==

Based on the above evaluation, it is concluded that the Code requirement is impractical. Therefore, it is recommended that relief be granted provided that:

(a) the Code-required volumetric examination of the pump casing weld is performed whenever the pump is completely disassembled such that the weld is exposed and volumetric examination is possible, and (b) if the pumps have not been disassembled, this fact should be reported by the Licensee in the ISI Summary Report at the end of the interval.

3.1.6 Valve Pressure Boundary (No relief requests) 3.1.7 General (No relief requests) 3.2 Class 2 Components 3.2.l Pressure Vessels 3.2.1.1 Request for Relief No. 1 (Part 4 of 8). Examination Category C-A. Items Cl.10 and Cl.30. Pressure Retaining Welds in Class 2 Pressure Vessels Code Requirement:

Section XI, Table IWC-2500-1, Examination Category C-A, Items Cl.IO requires a 100% volumetric examination of the Class 2 pressure vessel shell circumferential welds as defined by Figure IWC-2500-1.

Item Cl.30 requires a 100% volumetric examination of the Class 2 pressure vessel tubesheet-to-shell welds as defined by Figure IWC-2500-2.

14

Licensee's Code Relief Request:

Relief is requested from performing the Code-required volumetric examination of the following Class 2 pressure vessel welds:

Item Number Weld Number C 1. 3 0 1 -RH E -11 Cl.30 l-RHE-12 Weld Description Regenerative heat exchanger she 11

-to-tubesheet Obstruction or Limitation Permanent restraint and insulation interferences Regenerative heat Permanent restraint exchanger tubesheet interference

-to-shell Also, relief is requested from exam1n1ng 100% of the Code-required volume of the following Class 2 pressure vessel welds (each is approximately 20% examinable):

Item Obstruction Number Weld Number Weld Descrigtion or Limitation Cl.10 12-RHRHE.X-2 RHR heat exchanger Nozzle and flange shell -to-flange configurations Cl.30 l-RHE-2 Regenerative heat 24" of weld exchanger shell inaccessible

-to-tubesheet Cl.30 l-RHE-3 Regenerative heat Support brackets exchanger tubesheet each side of weld

-to-shell Licensee's Prooosed Alternative Examination:

None.

The Licensee states that weld 12-RHRHE.X-2 will receive a complete surface examination in addition to the limited volumetric examination.

The Code-required volumetric examination will be performed to the maximum extent possible.

Licensee's Basis for Requesting Relief:

The Licensee states that complete volumetric examination of the Code volume is not obtainable.

For weld 12-RHRHEX-2, 100% of the weld length can be scanned from the weld surface.

Due to nozzle configuration, scanning is limited and scanning is not possible on the flange side due to flange configuration.

As demonstrated during the 15..

first inspection interval, complete surface examination coverage and 0-degree and 45-degree ultrasonic examinations from the weld surface are obtainable.

For weld l-RHE-2, complete coverage is obtained for approximately 20% of the examination area.

Due to the inaccessibility of 24 inches of the weld, scanning of the complete weld is not possible.

As demonstrated during the first inspection interval, a limited examination of the Code-required volume is obtainable.

For weld l-RHE-3, 100% of the weld length can be scanned from the base material. Scanning on the weld with 0 degree and 45 degree is not possible due to a support bracket extending 1/4 inch to each side of the weld.

As demonstrated during the first inspection interval, com~~lete 45-degree and 60-degree ultrasonic examinations from the base material are obtainable.

For welds 1-RHE-11 and 1-RHE-12, a volumetric examination cannot be performed due to permanent restraint and insulation interferences.

Evaluation:

The volumetric examination of the subject Class 2 pressure vessel welds is impractical to perform to the extent required by the Code because of the described geometric configurations and permanent obstructions.

In the Licensee's February 1, 1989 response to the NRC RAI, the Licensee states that these examination areas will be evaluated to determine where augmented surface examination can be applied to improve coverage. Surface examinations will be performed 6n accessible portions of the welds.

The limited Section XI volumetric examinations and supplemental surface examinations will provide reasonable assurance of the continued inservice structural integrity of these Class 2 pressure vessel welds.

16

It should be noted that Class 2 reactor coolant filter upper head-to-flange weld 1-RCF-l was deleted from the relief request by the Licensee based on ASME Code Case N-4o0.

==

Conclusions:==

Based on the above evaluation, it is concluded that the volumetric examination of the subject Class 2 pressure vessel welds is impractical to perform to the extent required by the Code.

Therefore, it is recommended that relief be granted as requested.

3.2.1.2 Reauest for Relief No. 1 (Part 5 of 8), Examination Category C-8, Item C2.21. Pressure Retaining Nozzle Welds in Class 2 Vessels Code Requirement:

Section XI, Table IWC-2500-1, Examination Category C-8, Item C2.21 requi~es both 100% volumetric and surface examinations of the nozzle-to-shell (or head) welds for nozzles without reinforcing plate in vessels greater than 1/2 inch wall thickness as defined by Figure IWC-2500-4(a) or IWC-2500-4(b).

Licensee's Code Relief Request:

Relief is requested from examining 1003 of the Code-required volume of the following nozzle-to-shell welds in RHR heat exchangers 11 and 12:

Weld Number 11-RHRHEX-IN Weld Descriotion Nozzle-to-shell Obstruction or Limitation Nozzle configuration, permanent support lugs, and adjacent welds 11-RHRHEX-OUT Shell-to-nozzle Nozzle configuration, permanent support lugs, and adjacent welds 12-RHRHEX-IN Nozzle-to-shell Nozzle configuration, adjacent welds, and support interference 12-RHRHEX-OUT Shell-to-nozzle Nozzle configuration, adjacent welds, and support interference 17

The!censee stated in the February ~1989 response to the NRC RA! that previous IS! data and available drawings do not allow computation of the weld volume coverage obtainable.

Measurements will be taken during this IS! interval to allow the percentage of weld volume coverage to be accurately calculated.

Licensee's Proposed Alternative Examination:

None.

These welds will receive the complete Code-required surface examination.

The Code-required volumetric examination will be performed to the maximum extent possible.

Licensee's Basis for Requesting Relief:

The Licensee states that complete volumetric examination of the Code-required volume is not obtainable but that 100% of the weld length can be scanned from the weld surfcn:e.

Due to nozzle configuration, scanning from the nozzle side is not possible.

Due to permanent support lugs, adjacent weld interference, and support interference, scanning is limited from the vessel side.

As demonstrated during the first inspection interval, complete surface examination coverage and 0-degree and 45-degree ultrasonic examinations from the weld surface are obtainable.

Evaluation:

As the Licensee has stated, the volumetric examination of the subject RHR heat exchanger nozzle-to-shell welds is impractical to perform to the extent required by the Code because of the nozzle configuration, permanent support lugs, adjacent weld interferences, and support interferences.

The limited Section XI volumetric examinations and complete Section XI surface examinations will provide reasonable assurance of the continued inservice structural integrity of these welds.

18

r Con~sions: Based on the above eva~tion, it is concluded that the volumetric examination of the subject nozzle-to-shell welds is impractical to perform to the extent required by the Code.

Therefore, it is recommended that relief be granted as requested.

3.2.2 Piping 3.2.2.1 Request for Relief No. 1 (Part 6 of 8), Examination Category C-C. Item C3.20. Integrally Welded Attachments for Class 2 Pieing Code Requirement:

Section XI, Table IWC-2500-1, Examination Category C-C, Item C3.20 requires a 100% surface examination of the Class 2 piping integrally welded attachments as defined by Figure IWC-2500-5.

Licensee's Code Relief Request:

Relief is requested from performing the Code-required surface examination of the following integrally welded lugs on Main Steam piping:

32-MS-2141-2WPA lugs 1 through 4 32-MS-2131-2WPA lugs 1 through 4 32-MS-2121-2WPA lugs 1 through 4 32-MS-2111-2WPA lugs 1 through 4 Also, relief is requested from examining 100% of the Code-required surface of pipe support 32-MS-2121-2PS-2.

Licensee's Proposed Alternative Examination:

None.

The Code-required surface examination of pipe support 32-MS-2121-2PS-2 will be performed to the maximum extent possible.

Licensee's Basis for Requesting Relief:

The Licensee states that complete surface examination coverage is not attainable for pipe support 32-MS-2121-2PS-2 due to welded lugs.

As 19

  • .i demonstrated during the first inspection interval, approximately 20% of the examination area is accessible for exalJlination.

For the integrally welded lugs listed above, surface examination coverage is not obtainable as they are located within the containment wall penetration and are inaccessible.

Evaluation:

The drawing included in the Licensee's relief request shows that the subject integrally welded lugs on the Main Steam piping are within the containment wall penetrations and are inaccessible for surface examination.

Therefore, the Code-required surface examination of these lugs is impractical to perform.

The surface examination of pipe support 32-MS-2121-2PS-2 is impractical to perform to the extent required by the Code because of welded lugs which limit examination.

The limited Section XI surface examination will provide reasonable assurance of the continued inservice structural integrity of the subject pipe support.

In the Licensee's February 1, 1989 response to the NRC RAI, the Licensee stated that substitute examination areas are not available. Magnetic particle (MT) examination is the recommended examination and has been accomplished during the first ISI interval on the subject ferritic support.

Since MT examinations inherently require more space to perform, each area will be carefully analyzed by the Licensee to determine if augmented liquid penetrant examinations can be performed on the support to minimize the limitations and maximize coverage.

==

Conclusions:==

Based on the above evaluation, it is concluded that surface examination of the subject integrally welded piping lugs is impractical to perform and the surface examination of the subject pipe support is impractical to 20:

f.

~

3.2.2.2 e

e perform to the extent required by the Code.

Therefore, it is recommended that relief be granted as requested.

Request for Relief No. 1 (Part 8 of 8). Examination Category C-F-1. Item CS.11. Class 2 Circumferential Piping Welds Code Requirement:

ASME Code Case N-408, Examination Category C-F-1, Item CS.11 requires both 100% volumetric and surface examinations of circumferential piping welds 3/8 inch or greater nominal wall thickness for austenitic stainless steel or high alloy piping greater than 4 inches nominal pipe size as defined by Figure IWC-2500-7 of Section XI.

Licensee's Code Relief Request:

Relief is requested from examining 100% of the Code-reqti1red volume of the following Class 2 circumferential piping welds:

Weld Number 14-RH-2114-18 8-RH-2126-1 6-SJ-2104-4 Weld Description Flange-to-pump Pump-to-valve Safe end-to-nozzle Licensee's Proposed Alternative Examination:

None.

These welds will receive the complete Code-required surface examination.

The Code-required volumetric examination of the subject welds will be performed to the maximum extent possible.

Licensee's Basis for Requesting Relief:

The Licensee states that 100% of the weld length can be scanned from the weld surface. Scanning from the base material is not possible due to geometric configurations and permanent obstructions.

As demonstrated during the first inspection interval, complete surface examination coverage and 0-degree and 45-degree ultrasonic examinations from the weld surface are obtainable.

21

e e

Evaluation:

The volumetric examination of the subject welds is impractical to perform to the extent required by the Code because of flange, pump, valve, and nozzle configurations, adjacent weld interference, and sockolet interference.

In the Licensee's Febtuary 1, 1989 response to the NRC RAI, the Licensee stated that the limited coverage examination areas in this Examination Category are terminal ands of systems and, therefore, substitutions cannot be made since all terminal ends must be selected. The best possible examination coverage will be obtained to ensure the integrity of the system. Additional welds on the affected lines have been selected for examination to improve overall coverage of the systems (welds 14-RH-2114-14, 8-RH-2126-2, and 6-SJ-2104-2).

The limited Section XI volumet1"ic examinations and complete Section XI surface examinations of the subject welds and the examinations of the additional three piping welds will provide reasonable assurance of the continued inservice structural integrity of these welds.

It should be noted that Class 2 reducer-to-nozzle weld 14-BF-2141-16 was deleted from this relief request by the Licensee based on ASME Code Case N-460.

==

Conclusions:==

Based on the above evaluation, it is concluded that the volumetric examination of the subject welds is impractical to perform to the extent required by the Code.

Therefore, it is recommended that relief be granted as requested.

3.2.3 Pumps (No relief requests) 22

3:2.4 Valves 3.2.4.l Request for Relief No. 1 (Part 7 of 8), Examination Category C-C, Item C3.40, Integrally Welded Attachments for Class 2 Valves Code Requirement:

Section XI, Table IWC-2500-1, Examination Category C-C, Item C3.40 requires a 100% surface examination of the Class 2 valve integrally welded attachments as defined by Figure IWC-2500-5.

Licensee's Code Relief Request:

Relief is requested from examining 100% of the Code-required surface of the following Class 2 valve supports in the Main Steam system:

Weld Number 12-MS-167-VS-lA 12-MS-167-VS-18 13-MS-167-VS-2 13-MS-167-VS-2A 13-MS-167-VS-28 14-MS-167-VS-2 14-MS-167-VS-2A 14-MS-167-VS-28 9bstruction or Limitation Adjacent lugs and support structure Adjacent l ug Adjacent lug Adjacent lugs and support structure Valve support lug Adj a cent lug Valve support lug Valve support lug Licensee's Proposed Alternative Examination:

None.

The Code-required surface examination will be performed to the maximum extent possible.

Licensee's Basis for Requesting Relief:

Due to support structure and support lug interferences, complete surface examination cannot be obtained.

As demonstrated during the first inspection interval, only a limited examination of the Code area is obtainable.

Evaluation:

The surface examination of these valve supports is impractical to perform to the extent required by the Code because of the support structure and support lug interferences.

The limited Section XI surface examination will 23

e e

provide reasonable assurance of the continued inservice structural integrity of these welds.

In the Licensee's February 1, 1989 response to the NRC RAI, the Licensee stated that substitute examination areas are not available. Magnetic particle examinations are the recommended examination and have been accomplished during the first ISI interval on these ferritic lugs and supports. Since MT examinations inherently require more space to perform, each area is being carefully analyzed by the Licensee to determine if augmented liquid penetrant examinations can be performed to minimize the limitations and maximize coverage.

==

Conclusions:==

Based on the above evaluation, it is concluded that the surface examination of the subject valve supports is impractical to perform to the ~extent required by the Code.

Therefore, it is recommended that relief be granted as requested.

3.2.5 General (No relief requests) 3.3 Class 3 Components (No relief requests) 3.4 Pressure Tests 3.4.1 Class 1 System Pressure Tests (No relief requests) 3.4.2 Class 2 System Pressure Tests 3.4.2.1 Request for Relief No. 4, Examination Category C-H, Item C7.40, Hydrostatic Pressure Test of Class 2 Piping in the Residual Heat Removal and Safety Injection Systems Code Requirement:

Section XI, Table IWC-2500-1, Examination Category C-H, Item C7.40 requires that the hydrostatic pressure 24

I, e

e tests of IWA-5000 and IWC-5000 be performed at 1.25 times system pressure.

Licensee's Code Relief Request:

Relief is requested from performing the hydrostatic pressure tests at 1.25 times system pressure as required by the Code for the following Class 2 3/4-inch lines in the Residual Heat Removal (RHR) and Safety Injection (SJ) systems:

Required Design Test Alternative Class 2 Piging Pressure Pressure Test Pressure Approx. 4 ft of RHR piping 450 psi 565 psi 80 to 90 psi between valves 1RH45 and 1RH33 Approx. 4 ft of RHR piping 600 psi 750 psi 80 to 90 psi between valves 1RH46 and 1RH24 Approx. 14 ft of SJ piping 450 psi 565 psi 80 to 90 psi between valves 11SJ96 and 11SJ98

)

Approx. 14 ft of SJ piping 450 psi 565 psi 80 to 90 psi between valves 12SJ96 and 12SJ98 Licensee's ProQosed Alternative Examination:

The Licensee proposes to conduct surface examinations of the welds and a test at nominal operating pressure for the subject lines.

Licensee's Basis for Requesting Relief:

The Licensee states that the subject Class 2 portions of the RHR and SJ systems cannot b~ tested at the required hydrostatic test pressure.

Pressurization at hydrostatic pressure would require cutting open the pressure boundary and rewelding when the test is completed, which use resources of man-hours, material, and radiation exposure.

Expending these resources is not justified when an acceptable level of safety can be achieved by performing the surface examination and inservice pressure tests proposed in the alternative examination.

These lines cannot be pressurized to the required hydrostatic pressure due to:

25

e (a)

Lines from the demineralized water system are welded to one side of the test boundary.

(b)

A check valve with a welded bonnet forms the other side of the test boundary.

(c)

There is no test connection within the test boundary.

The Licensee requests that these portions of RHR and SJ piping be pressurized to the nominal operating pressure of the demineralized water system (80 to 90 psi).

Evaluation:

The Licensee stated the following in the February 1, 1989 response to the NRC RAI:

"Relief Request No. 4 was submitted because of piping configuration restraints.

The lines are 314-inch Class 2 piping but with check valves preventing flow to the system isolation valves from the demineralized water system used to make up and flush the RHR ~Tstem.

All the piping is welded with welded capped check valves.

Without breaching the system to remove the check valve internals or the demineralized water system upstream of the isolation valves, testing of this piping would not be obtainable. A hydrostatic pressure test at 151 to 770 psig was performed on the portions of the system on the RHR side of the check valves as specified and required by ASHE Section XI."

The subject piping cannot be pressurized to the Code-required test pressure without extensive temporary modifications as shown in the sketches included in the Licensee's relief request. Therefore, the Code-required hydrostatic pressure test is impractical to perform.

The subject portions of piping are short and represent a small portion of the system hydrostatic tests. The Licensee's proposed alternative examination will provide reasonable assurance of the continued inservice structural integrity of the piping.

==

Conclusions:==

Based on the above evaluation, it is concluded that the Code-required hydrostatic pressure test of the subject piping is impractical to perform.

Therefore, it is recommended that relief be granted as requested.

26

3:4.3 Class 3.stem Pressure Tests (No rel ie,,.equests) 3.4.4 General (No relief requests) 3.5 General 3.5.1 Ultrasonic Examination Techniques (No relief requests) 3.5.2 Exemoted Components (No relief requests) 3.5.3 Other 3.5.3.l Request for Relief No. 5. VT-3 and VT-4 Visual Examinations of Snubbers Code Requirement:

Section XI~Article IWF-2000 requires 100%

VT-3 and VT-4 visual examinations of mechanical and hydraulic snubbers.

Licensee's Code Relief Request:

Reli~f is requested from performing the inservice VT-3 and VT-4 visual examinations to the requirements of the Code.

Licensee's Proposed Alternative Examination:

The Licensee states that vi sua 1 exami nat i ans wi 11 be performed on Code Class 1, 2, and 3 (and other) snubbers in compliance with Salem Generating Station Technical Specification 3/4.7.5 and its associated bases.

Licensee's Basis for Requesting Relief:

The Licensee states that performance of examinations to the requirements of the Technical Specification meet some of the Code requirements.

However, this approach differs in the areas of examination scheduling and reexamination requirements.

27

l e

  • e These mechanical and hydraulic snubbers were constructed and installed in accordance with the requirements of the Salem FSAR.

Documentation of fabrication and installation examinations is stored at the plant site. Subsequent to the plant going into operation, these have been and will continue to be visually inspected in accordance with Plant Technical Specifications.

Evaluation:

In the Licensee's February 1, 1989 response to the NRC RA!, the Licensee states that performance of the examinations to the requirements of the Technical

  • Specifications meets or exceeds all the requirements of the Code.

As an example, the Code specifies that examinations will be scheduled per the inspection period established.

The Technical Specification requires that visual examinations be performed on all snubbers ever'f 18 months +/-25% based on zero inoperable snubbers. Thus, inspections are performed more frequently* and usually twice as often as specified in the Code.

Visual inspections shall verify (1) that there are no visible indications of damage or impaired operability, (2) that attachments to the foundation or supporting structure are secure, and (3) that in those locations where snubber movement can be manually induced without disconnection of the snubber, that the snubber has freedom-of movement and is not frozen up.

The Licensee summarizes that compliance with the Salem, Unit 1, Technical Specification results in an increase in the overall level of plant quality and safety since the examination requirements meet or exceed Code requirements and since the inspections are performed on a more frequent basis than that specified by the Code.

Paragraph IWF-2520 states that alternative methods of examination meeting the requirements of IWA-2240 may be used.

Paragraph IWA-2240, RAlternative Examinations,R states that alternative examinations methods, a combination of methods, or newly developed techniques may be substituted for the methods 28

specified in Division 1 of Section XI, provided the Inspector is satisfied that the results are demonstrated to be equivalent or superior to those of the specified method.

Use of the Technical Specification for examination of snubbers meets or exceeds the Code requirements and, therefore, in accordance with IWA-2240, is an acceptable alternative.

==

Conclusions:==

Based on the above evaluation, it is concluded that the proposed alternative examination meets or exceeds the Code requirement and, thus, provides reasonable assurance of the continued inservice structural integrity of the snubbers.

Therefore, it is recommended that relief be granted as requested.

NOTE:

This Request for Relier also requests relief from the functional testing requirements of IWF-5000 for snubbers.

The functional testing of snubbers is not included in this evaluation.

Functional tests are not within the scope of this document and will be evaluated elsewhere.

3.5.3.2 Request for Relief No. 6, Examination Categories 0-8 and F-C.

Items 02.20 and F3.30, Class 3 Anchors and Their Associated Integral Attachments Code Requirement:

Section XI, Table IWD-2500-1, Examination Category 0-8, Item 02.20 requires a 100% visual (VT-3) examination of the integral attachments of component supports and restraints as defined by Figure IW0-2500-1.

Table IWF-2500-1, Examination Category F-C, Item F3.30 requires a 100% visual (VT-3) examination of the weld and mechanical connections at intermediate joints in multiconnected integral and nonintegral supports as defined by Figure IWF-1300-1 and to the extent required by Articles IWF-1300 and IWF-2510.

29

l licensee's Code Relief Request:

Relief is requested from performing the Code-required visual (VT-3) examinations of the following Class 3 anchors and their associated integral attachments:

M-SWPA-006 M-SWPA-012 M-SWPA-013 M-SWPA-025 P-SW-A-WSll P-SW-A-WS13 P-SW-A-WS15 P-SW-A-WS16 A-SW-A-WSOS A-SW-A-WS06 A-SW-A-WS07 A-SW-A-WSOS licensee's Proposed Alternative Examination:

None.

The Licensee states that VT-2 visual examinat"ions will be performed during the pressure tests required by IW0-5000 and VT-3 visual examinations required on adjacent pipe supports by Article IWF will be performed.

licensee's Basis for Requesting Relief:

The licensee states that the integral attachments associated with the anchors identified on the list attached to the relief request are buried within wall sleeves making them totally inaccessible for visual examination.

The structural integrity of the lines associated with these attachments will be verified during VT-2 visual examinations during pressure tests required by IWD-5000 and VT-3 visual examinations required on adjacent pipe supports by Article IWF.

Evaluation:

The Code-required VT-3 visual examination of these anchors and their associated integral attachments is impractical to perform because the components are buried within wall sleeves and inaccessible for examination.

Complete VT-3 examinations which meet the requirements of ASME Code Section XI will be performed on anchors and integral attachments of similar configuration. Since these uninspected component supports will see the same operating and environmental conditions as the inspected component supports, a 30

v

'~.

realable assurance of the structur~ integrity which relief is requested will be achieved.

of those for

==

Conclusions:==

It is concluded that the Code-required VT-3 visual examination of the subject anchors and associated integral attachments is impractical to perform.

Therefore, it is recommended that relief be granted as requested.

  • o 31
)
4.

CONCLUSION Pursuant to 10 CFR 50.55a(g)(6), it has been determined that certain Section XI required inservice examinations are impractical to perform.

In these cases, the Licensee has demonstrated that specific Section XI requirements are impractical.

However, it should be noted that Relief Request No. 5 requests relief from the functional testing requirements of IWF-5000 for snubbers.

The functional testing of snubbers is not included in this evaluatirin.

Functional tests are not within the)COpe of this document and will be evaluated elsewhere.

This technical evaluation has not identified any practical method by which the Licensee can meet all the specific inservice inspection requirements of Section XI of the ASME Code for the existing Salem Generating Station, Unit 1, facility.

Requiring compliance with all the exact Section XI required inspections would require redesigrf~f a significant number of plant systems, sufficient replacement components to be obtained, installation of the new components, and a baseline examination of these components.

Even after the redesign efforts, complete compliance with the Section XI examination requirements probably could not be achieved.

Therefore, it is concluded that the public interest is not served by imposing certain provisions of Section XI of the ASME Code that have been determined to be impractical.

Pursuant to 10 CFR 50.55a(g)(6), relief is allowed from these requirements which are impractical to implement if granting the relief 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 development of new or improved examination techniques should continue to be monitored.

As improvements in these areas are achieved, the Licensee should incorporate these techniques in the ISI program plan examination requirements.

Based on the review of the Salem Generation Station, Unit 1, Second 10-Year Interval Inservice Inspection Program Plan, Revision 0, the Licensee's 32

tj, Q--

i.

-~

t,.

4 '

response to the fc,s Request for Additional recommendations for granting relief from the that have been determined to be impractical, e

Information, and the ISI examination requirements it is concluded that the Salem Generating Station, Unit 1, Second 10-Year Interval Inservice Inspection Program Plan, Revision 0, is acceptable and in compliance with 10 CFR 50.55a(g)(4).

33

{*

')

5.

REFERENCES

1.

Code of Federal Regulations, Volume 10, Part 50.

2.

American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Division 1, 1983 Edition through Summer 1983 Addenda.

3. American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Code Cases - Nuclear Components, 1986 Edition.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.

Letter, dated October 23, 1987, C. A. McNeill, Jr. [Public Service Electric and Gas Company (PSE&G)] to NRC, transmittal containing the Salem Generating Station, Unit 1, Second 10-Year Interval Inservice Inspection Program Plan, Revision 0.

Letter, dated December 23, 1987, C. A. McNeill, Jr. (PSE&G) to NRC, transmittal of inservice inspection program plan boundary diagrams for Salem Generating Station, Unit 1.

NUREG-0800, Standard Review Plans, Section 5.2.4, "Reactor Coolant Boundary Inservice Inspection and Testing," and Section 6.6, "Inservice Inspection of Class 2 and 3 Components," July 1981.

Letter, dated November 9, 1988, J. C. Stone (NRC) to S. E. Miltenberger (PSE&G), "Request for Additional Information - Inservice Inspection Program" regarding Salem Generating Station, Unit 1.

Letter, dated February 1, 1989, S. E. Miltenberger (PSE&G) to NRC, "Response to Request for Additional Information - Inservice Inspection Program - Salem Generating Station - Unit No. 1 - Docket No. 50-272."

NRC Regulatory Guide 1.147, "Inservi ce Inspection Code Case Acceptability, ASME Section XI, Division l," Revision 6, May 1988.

NRC Regulatory Guide 1.150, "Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations," Revision 1, February 1983.

NRC Regulatory Guide 1.14, "Reactor Coolant Pump Flywheel Integrity,"

Revision 1, August 1975.

Letter, dated January 26, 1989, S. E. Miltenberger (PSE&G) to NRC, "ASME Section XI Code Case Application - Code Case N-460 - Salem Generating Station - Unit No. 1 - Docket No. 50-272."

Letter, dated February 3, 1989, J. C. Stone (NRC) to S. E. Miltenberger (PSE&G), "Approval to Use ASME Code Case N-460" regarding Salem Generating Station, Unit 1.

34

" ( '

I U.S. lllUCU*A REOUl.A-Y COMMISSION 8

JOGRAPHIC CATA SHEET

2. TITi.E AINO s1.1ar1r1.s Technical Evaluation Report on the Second 10-Year Interval Inservice Inspection Program Plan:

Public Service Electric and Gas Company, Salem Generating Station, Unit 1, Docket Number 50-272

5. AUTHOAISJ B.W. Brown, J.C. Hudlin

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IA-*~ -'lltC...... 'IOI.. 5-.. "'"'**

..a Aomttau"' ~wmmn. 1f ~.I EGG-MS-8435 Nove-n;ber 1

198~~

~ FiN OR Qi'l.:.NT '<U"1BS:il FIN-06022 (Proj. 5)

6. TYPE OF RE?Oi'IT Technical
8. ?ER FORMING ORG..:.NIZATIOl\\l - NAME.l.NO.i.OORESS Ill.YRC.11-- Onuwn. OH*uor!l..,;on. IJ.$. Nucl.. t: R_,.,i.ro.., Comm1a1on, *nd mMiftf.OO,.u:dconrr~'o' i::i:.**'*

~-*lldtNIJiltf-1 EG&G Idaho, Inc.

P. 0. Box 1625 Idaho Falls, ID 83415-2209

9. SPONSORING ORG..i.NIZ.ollTION - NAME ANO AOORESS llfNllC, t'f,_ *~**ao.. **. ""'*rrcmr.-itHNRCOn.iuoll, OflicurR119-. tJ.£ NucJNr!l-i.tMY Co"'"'-*

Materials and Chemical Engineering Branch Office of Nuclear Reactor Regulation U.S.

N~clear Regulatory Commission Washington, D.C.

20555 TO. SUPPLEMENTARY NOTES

11. ASSTRACi r2ao wona °' _,

This report presents the results of the evaluation of the Salem Generating Station, Unit 1, Second 10-Year Interval Inservice Inspection (ISI) Program Plan, Revision 0, submitted in letters dated October 23, 1987 and December 23, 1987, including the requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical.

The Salem Generating Station, Unit 1, Second 10-Year Interval ISi Program Plan is evaluated in Section 2 of this report. The.ISi Program Plan is evaluated for (a) compliance with the appropriate edition/addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of

~ystem or component examination exclusion criteria, and (d) compliance with

!SI-related commitments identified during the Nuclear Regulatory Commission's (NRC) previous reviews.

The requests for relief are evaluated in Section 3 of this report.

12. <cY WOROSiOESCi'l~PTQRS IL11t-aro"'*** "'".. 11,....,_'".,, 1ou11~~..... -.oon.;

IJ. '""'"'l."'811.iTY ST.:.rcMENT Unlimited Unclassified I rl't1t tiJf!HlrTI Unclassified*

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.'IRC PORM 335 12-891

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