ML18100B147
| ML18100B147 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 06/13/1994 |
| From: | Stone J Office of Nuclear Reactor Regulation |
| To: | Miltenberger S Public Service Enterprise Group |
| References | |
| TAC-M83316, NUDOCS 9406270039 | |
| Download: ML18100B147 (14) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555--0001 June 13, 1994 Docket No. 50-311 Mr. Steven E. Miltenberger Vice President and Chief Nuclear Officer Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, New Jersey 08038
Dear Mr. Miltenberger:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION, SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN, REV 0, ANO ASSOCIATED REQUESTS FOR RELIEF, SALEM NUCLEAR GENERATING STATION, UNIT 2 (TAC NO. M83316)
The NRR staff is reviewing and evaluating the Second Ten-year Interval Inservice Inspection Program Plan, Rev. 0, and the associated requests for relief from the American Society of.Mechanical Engineers, Boiler & Pressure Vessel Code,Section XI requirements for Salem Nuclear Generating Station, Unit 2. Additional information is required from Public Service Electric and Gas Company in order for the staff to complete its review.
Enclosed is a list of questions that the staff has developed during the course of their review.
To meet the inservice inspection program plan review schedule, the staff requests a response be provided within 60 days of receipt of this letter. In addition, to expedite the review process, please send a copy of the response to NRC's contractor, Idaho National Engineering Laboratory (INEL), at the following address:
I,...~ (*'. :*-, ('\\ l'"-1 t;Y r;.,..:;00~0 Boyd W. Brown EG&G Idaho, Inc.
INEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, Idaho 83415-2209
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9406270039 940613 PDR ADOCK 05000311
- PDR
Mr. Steven June 13, 1994 This requirement affects 9 or fewer respondents and, therefore, is not subject to Office of Management and Budget review under P.L.96-511.
Enclosure:
Request for Additional Information cc w/enclosure:
See next page DISTRIBUTION Docket File NRC & Local PDRs PDI-2 Reading SVarga JCalvo CMiller JStone MO' Brien TMclellan OGC ACRS(IO)
EWenzinger, RGN-I JWhite, RGN-I OFFICE NAME DATE PDI-2/PM JStone:rb fo
[fl/94 Sincerely, Original signed by:
James C. Stone, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Mr. Steven June 13, 1994 This requirement affects 9 or fewer respondents and, therefore, is not subject to Office of Management and Budget review under P.L.96-511.
Enclosure:
Request for Additional lnformat ion cc w/enclosure:
See next page Sincerely,
~c,~
James C. Stone, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Mr. Steven E. Miltenb,,ger Public Service Electric & Gas Company cc:
Mark J. Wetterhahn, Esquire Winston & Strawn*
1400 L Street NW Washington, DC 20005-3502 Richard Fryling, Jr., Esquire Law Department - Tower SE 80 Park Place Newark, NJ 07101 Mr. Calvin A. Vondra General Manager - Salem Operations Salem Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. J. Hagan Vice President - Nuclear Operations Nuclear Department P.O. Box 236 Hancocks Bridge, New Jersey 08038 Mr. Charles S. Marschall, Senior Resident Inspector Salem Generating Station U.S. Nuclear Regulatory Commission Drawer I Hancocks Bridge, NJ 08038 Dr. Jill Lipoti, Asst. Director Radiation Protection Programs NJ Department of Environmental Protection and Energy CN 415 Trenton, NJ 08625-0415 Maryland People's Counsel American Building, 9th Floor 231 East Baltimore Street Baltimore, Maryland 21202 Mr. J. T. Robb, Director Joint Owners Affairs PECO Energy Company 955 Chesterbrook Blvd., 51A-13 Wayne, PA 19087 Mr. S. LaBruna Vice President - Nuclear Engineering Nuclear Department
.P.O. Box 236 Hancocks Bridge, New Jersey 08038 Salem Nuclea'9Generating Station, Units 1 and 2 Richard Hartung Electric Service Evaluation Board of Regulatory Commissioners 2 Gateway Center,-Tenth Floor Newark, NJ 07102; Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Lower Alloways Creek Township c/o Mary 0. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038-Mr. Frank X. Thomson, Jr., Manager Licensing. and Regulation Nuclear Department P.O. Box 236 Hancocks Bridge, NJ 08038 Mr*. David. Wersan Assistant Consumer Advocate Office of Consumer Advocate 1425 Strawberry Square Harris~urg, PA 17120 Ms. P. J. Curham MGR. Joint Generation Department Atlantic Electric Company P.O. Box*1soo 6801 Black Horse Pike Pleasantville, NJ 08232 Carl D. Schaefer External Operations - Nuclear Delmarva Power & Light Company P.O. Box 231 Wilmington, DE 19899 Public Service Commission of Maryland Engineering Division Chief Engineer 6 St. Paul Centre Baltimore, MD 21202-6806
PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION. UNIT 2 DOCKET NUMBER 50-3II ENCLOSURE Request for Additional Information - Second IO-Year Interval Inservice Inspection Program Plan I. Scope/Status of Review Throughout the service life of a water-cooled nuclear power facility, IO CFR 50.55a(g)(4) requires that components (including supports) that are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class I, Class 2, and Class 3 meet the requirements, except design and access provisions and 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. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during successive I20-month inspection intervals comply with the requirements in the latest edition and addenda of the Code incorporated by reference in IO CFR 50.55a(b} on the date I2 months prior to the start of a successive I20-month interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of the Code that are incorporated by reference in IO 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 2, Second IO-Year Interval Inservice Inspection (ISI) Program Plan to meet the requirements of the I986 Edition of Section XI of the ASME Code.
As required by IO CFR 50.55a(g}(5), if the licensee determines that certain Code examination requirements are impractical and requests relief, the licensee shall submit information to the Nuclear Regulatory Commission (NRC} to support that determination.
The staff has reviewed the available information in the Salem Generating Station, Unit 2, Second IO-Year Interval ISI Program Plan, Revision 0, submitted May 4, 1992, and the requests for relief from the ASME Code Section XI requirements that the licensee has determined to be impractical.
- 2.
Additional Information Required Based on the above review, the staff has concluded that the following information and/or clarification is required to complete the review of the ISI Program Plan.
A.
Address the degree of compliance with augmented examinations that have been established by the NRC when added assurance of structural reliability is deemed necessary.
Examples of documents that address augmented examinations are listed below, where (1) and (2) may be applicable based on licensee commitments and (3) is applicable to all utilities.
(1)
Branch Technical Position MEB 3-1, 11High Energy Fluid Systems,
- Protection Against Postulated Piping Failures in Fluid Systems Outside Containment; 11 (2)
Regulatory Guide 1.150, Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations; (3)
New regulations, effective September 8, 1992, were issued regarding augmented examination of reactor vessels.
As a result of these regulations, all licensees must augment their reactor vessel examinations by implementing once, during the inservice inspection interval in effect on September 8, 1992, the examination requirements for reactor vessel shell welds specified in Item Bl.IO of Examination Category B-A of the 1989 Code.
In addition, all previously granted reliefs for Item Bl.IO,
- Examination Category 8-A, for the interval in effect on September 8, 1992, is revoked by the new regulation.
For licensee's with fewer than 40 months remaining in the interval on the effective date, deferral of the augmented examination is permissible with the conditions stated in the regulations.
Please provide the staff with the projected schedule and a technical discussion describing how the regulation will be implemented for these welds at Salem Generating Station, Unit 2, during the second interval. Include in the discussion a description of the intended approach and any specialized techniques or equipment that will be used to complete the required augmented examination.
Discuss these and any other augmented examinations that may have been incorporated in the Salem Generating Stationp Unit i, Second 10-Year Interval Inservice Inspection Program Plan.
B.
In the Class 2 Section XI Summary, Table IWC, Examination Category C-F-1, the Item Descriptions do not correspond with the "Parts Examined", of the 1986 Edition.
As a result, it is unclear if the number of welds reflected in the table are correct. Please provide a revised table with Item Descriptions that correspond to the "Parts Examined" of the 1986 Edition of the Code.
C.
The inservice inspection plan has no longitudinal piping welds identified, yet there are several relief requests identifying longitudinal welds. Discuss the omission of longitudinal piping welds from the program and/or revise the tables to include applicable longitudinal welds.
D.
The licensee has made reference to the use of Code Case N-460 in several relief requests. It appears that the licensee's position is that implementation -0f the Code Case alleviated the need for a relief request submittal as long as the limitations are documented on the examination data sheet and included in the Owner's Summary Report.
This is true when examination coverage is equal to or exceeds 90 percent coverage only.
Please discuss the implementation of Code Case N-460.
Verify that examination areas receiving less than 90 percent coverage are addressed in applicable relief requests.
E.
As noted by the licensee, 10 CFR 50.55a(b)(2)(ii) states that the extent of examinations of Code Class 1 piping welds may be determined by the requirements of IWB-2500 and IWB-2600, Category 8-J of the 1974 Edition through and including the Summer 1975 Addenda (74575) of Section XI.
The selection criteria in the 1986 Edition assure that welds most susceptible to failure are selected. Other utilities have adopted the selection criteria from later Codes for Class 1 piping, recognizing the technical prudence of the improved selection philosophy, and have developed their programs accordingly. Discuss Public Service Electric and Gas Company's position on the use of the 74575 Code for selection of Class 1 piping welds.
The position statement will aid in the review of the program.
F.
The licensee stated that for Class 1 piping welds, the same welds examined during the first interval will be examined during the second interval. Under Relief.Request-A2, "Alternative Examination", the licensee stated that welds have been selected for the second interval, when possible, that do not have associated examination limitations.
In addition, the licensee discussed the implementation of Code Case N-460.
Included in the discussion is the statement, "Where possible, an alternate weld or component in the same examination category and item number will be selected and examined".
Code Case N-460 and the 74S75 do not include a provision for the selection of an alternative weld.
Provide an itemized list of all Class 1 piping welds that required relief from examination during the first interval and the corresponding alternate weld selected for the second 10-year interval when applicable.
From this list, an evaluation of the alternative examination areas will be made.
G.
It was noted during the review of relief requests for Examination Category 8-J welds for the first and second 10-year intervals that all relief requests for Examination Category 8-J have been omitted in the second 10-year program.
Please explain the variance.
H.
Paragraph 10 CFR 50.55a(b}(2}(iv} requires that appropriate ASME Code Class 2 piping welds in the Residual Heat Removal (RHR}, Emergency Core Cooling (ECC}, and Containment Heat Removal (CHR} systems be examined.
Portions of these systems should not be completely omitted from inservice volumetric examination based on Section XI selection criteria (piping wall thickness} specified in Table IWC-2500-1.
It appears that the licensee is committed to performing appropriate examinations for the Containment Heat Removal system (Containment Spray).
It is noted, however, from the review of coded P&IDs, that the Safety Injection System (which is part of the ECC} from the Safety Injection Pumps to the first normally closed valve is excluded from examination. It also appears that within the RHR system, piping is excluded from examination within runs of pipe scheduled for examination.
The licensee should review these systems and select welds (7 1/2 percent} in those portions of lines excluded from examination to ensure that the integrity of the complete flow path of these systems is assured.
Please discuss the review and provide a list of welds selected to augment the program.
I. Request for relief RR-A2 has been developed in a table format.
In the present format, the extent of Code compliance, conclusions of impracticality or hardships, and to what extent quality and safety are assured through alternative examinations or tests cannot be evaluated.
The preferred presentation is provided in Appendix A {Attached}.
The licensee should put an emphasis on the following to support the
~ranting of relief:
(1)
Explain the impracticality of the Code-required examination or test; (2)
Explain for each relief request how adequate assurance of system integrity will be provided or maintained where Code requirements
- are not met; and (3)
Explain how the proposed alternative will provide an acceptable level of quality and safety.
(4)
Provide the percentage of Code required coverage that will be obtained for each examination area for which relief is requested.
For all requests for relief submitted, the licensee should review the submittal and ensure that the required information is included. This information should clearly support a conclusion that such relief will not result in a reduction of integrity and safety of the components/systems.
J.
In Relief Request RR-Bl, the licensee has submitted a generic relief request for ASME Code Class 2 welds.
It should be noted that generic relief requests are unacceptable. Please revise this relief request and resubmit based on the relief request submittal information discussed in part "I" of this Request for Additional Information.
K.
Relief Request RR-AS requests relief from the Code-required volumetric examination of the pump casing weld.
The NRC has approved Code Case N-481 as an alternative to the Code requirement, as referenced in Regulatory Guide 1.147. Discuss the alternative proposed to support the current relief request when alternatives to the Code have been developed under Code Case N-481.
.. L.
Verify that there are no relief requests in addition to those submitted.
If additional relief requests are required, the licensee should submit them for staff review.
The schedule for timely completion of this review requires that the licensee provide, by the requested date, the above requested information and/or clarification with regard to the Salem Generating Station, Unit 2, Second IO-Year Interval Inservice Inspection {ISI) Program Plan.
Attachment:
Appendix A
Appendix A INSERVICE INSPECTION:
GUIDANCE FOR PREPARING REQUESTS FOR RELIEF FROM CERTAIN CODE REQUIREMENTS PURSUANT TO 10 CFR 50.SSaCqlCSl The guidance in this Appendix is intended to illustrate the type and extent of information that is necessary in a "request for relief" submittal for those items that cannot be fully inspected to the requirements of ASME Code Section XI.
A.
Description of Requests for Relief The i nservi ce inspection program should contain requests for r_e Hef. that identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitations of design, geometry, radiation considerations, or materials of construction of the components.
Each request for relief should provide the information identified in the following sections of this Appendix for the inspections and pressure tests considered impractical.
B.
Request for Relief From Certain Inspection and Testing Requirements Many requests for relief from inservice inspection requirements submitted by licensees have not been supported by adequate descriptive and detailed technical information. This detailed information is necessary to:
(1) document the impracticality of the ASME Code requirements because of the limitations of design, geometry, and mat~rials of construction of components; and (2) determine whether the use of alternatives will provide an acceptable level of quality and safety.
Relief requests submitted with a justification such as "impractical",
"inaccessible", or any other categorical basis, require additional information to permit an evaluation of that relief request.
The objective of the guidance provided in this section is to illustrate the extent of the information required to make a proper evaluation and to adequately document the basis for the granting of relief in the Safety Evaluation Report.
Re~uests for additional information and delay~ in completing the review can be considerably reduced if this information is provided in the licensee's initial submittal.
Each relief request should contain adequate information to act as a "stand alone" document and should include the following:
- 1.
The ASME Code Class, Examination Category, and Item Number(s) or the specific Code paragraph number from which relief is being requested.
- 2.
ASME Code Section XI examination or test requirements for the weld(s) and/or component(s) for which relief is being requested.
- 3.
The number of items associated with the requested relief.
' 4.
Identification of the specific ASME Code requirement that has been determined to be impractical.
- 5.
An itemized list of the specific welds(s) and/or component(s) for which relief is requested.
- 6.
An estimate of the percentage of the Code-required examination that can be completed for each of the individual welds(s) and/or component(s) requiring relief.
- 7.
Information to support the determination th~t the requirement is impractical; i.e., state and explain the basis for requesting relief.
If the Code-required examination cannot be performed because of a limitation or obstruction, describe or provide drawings showing the specific limitation or obstruction.
- 8.
Identification of the alternative examinations that are proposed:
(a) in lieu of the requirements of Section XI; or (b) to supplement partial Section XI examinations performed.
- 9.
A discussion of the failure consequences of the weld(s) and/or component(s) that would not receive the Code required examination.
Discuss any changes expected in the overall level of plant safety by performing the proposed alternative examination in li~u of the examination required by Section XI.
If it is not possible to perform alternative examinations, discuss the impact on the overall level of plant quality and safety.
- 10. State when the proposed alternative examinations will be impl~mented and performed.
- 11. State when the request for relief would apply during the inspection period or interval (i.e., whether the request is to defer an examination).
- 12. State the time period for which the requested relief is needed.
Technical justification or data must be submitted to support the relief request. Stating without substantiation that a change will not affect the quality level is unsatisfactory (i.e., because a licensee does not agree with a Code requirement is not considered justification for the granting of relief). If the relief is requested for inaccessibility, a detailed description or drawing that depicts the inaccessibility must accompany the request.
C.
Request for Relief for Radiation Considerations Radiation exposures of test personnel to accomplish the examinations prescribed in ASME Code Section XI can be an important factor in determining whether, or under what conditions, an examination must be
I performed. A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently approved by the NRC staff.
Some of the radiation considerations will only be known at the time of the test. However, from experience at operating facilities, the licensee generally is aware of those areas where relief will be necessary and should submit as a minimum (in addition to the previous general requirements in Section B) the following additional information regarding the request for relief:
- 1.
The total estimated man-rem exposure involved in the examination.
- 2.
The radiation levels at the test area.
- 3.
Flushing or shielding capabilities that might reduce radiation levels.
- 4.
A discussion of the considerations involved in remote inspections.
- 5.
The results of any previous inservice inspections regarding ALARA for the welds for which the relief is being requested.
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