ML18101A346
| ML18101A346 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 11/18/1994 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N94163, NUDOCS 9411300084 | |
| Download: ML18101A346 (4) | |
Text
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Joseph J. Hagan
,,A Public Service Electric and Gas Company Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations NOV 18 1994 NLR-N94163 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Gentlemen:
ASME CODE CASE N416-1 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 272, 50-311, 50-354 Public Service Electric and Gas Company (PSE&G) requests approval, per 10CFR50.55a, Section (a)(3) and footnote 6, to use ASME Code Case N416-1 (copy attached) for Salem and Hope Creek Generating Stations.
This ASME Section XI Code Case entitled, "Alternate Pressure Tes.t Requirement for Welded Repairs or Installation of Replacement Items by Welding, Class 1, 2, and 3, 11 was approved by ASME and published on February 15, 1994.
The use of this Code Case is not presently referenced in NRC Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability," Revision 10, dated July 1993.
Code Case N416-1 provides an alternative to the current Section XI, Paragraph IWA.:..4000 hydrostatic pressure test requirements for welded repairs or installation of replacement items by welding. In lieu of performing the hydrostatic pressure test required by Paragraph IWA-4000, a system leakage test may be used. In order to apply Code Case N416-1, t~.ree (3) requirements must be met:
(a)
NDE shall be performed in accordance with the methods and acceptance criteria of the applicable Subsection of the 1992 Edition of Section III, (b)
Prior to or immediately upon return to service, a visual examination (VT-2) shall be performed in conjunction with a system leakage test, using the 1992 Edition of Section XI, in accordance with para.
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___ -operati-ng-pressure-ana--tempe-rature, (c)
Use of this case shall be documented on an NIS-2 Form.
of these requirements.
In addition to
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~n' Code Case N416-1, PSE&G shall perform~
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Q ADOCK osooo272 PSE&G intends to meet all the requirements specified PDR
Docµment Control Desk NLR-N94163 NOV 18 1994 2
a surface examination of the root (pass) layer for Class III butt welds in accordance with ND-5222.
Code Case N416-1 states that if the previous version of this Code Case was used to defer a Class 2 hydrostatic test, the deferred test may be eliminated when the requirements of this revision are met. Upon approval of this application for Code Case N416-1, PSE&G intends to apply this statement to its Class 2 hydrostatic tests that were deferred using the previous version of this Code Case.
The NDE that is required to be performed by this Code Case does represent a change in the NOE acceptance criteria that is presently employed.
This Code Case does not create any technical or administrative changes that would impact the existing ISI Programs, IST Programs, or Technical Specifications at either Salem or Hope Creek and does not introduce a condition that would compromise existing levels of safety and quality.
Numerous benefits are gained by use of this Code Case.
Among all three units, approximately 100 to 150 hydrostatic tests are conducted annually. It is estimated that approximately 20 person-days time is expended for set-up, testing, disassembly, and system restoration for the "average" hydrostatic test.
In addition, approximately five to six days are expended for the conduct of each typical hydrostatic test.
Significant labor is expended, which results is very little or no added safety benefit, and generally, these tests are performed during refueling outages, often as critical path activities.
By not having to conduct the additional efforts associated with testing lineup, test system disassembly, and system restoration, the system availability for operation is accelerated, and overall job labor and person-rem exposure is reduced.
The use of Code Case N416-1, through the elimination of the added work, substantially reduces resource and time demands placed upon station organizations and contributes to ALARA practices.
PSE&G notes that a similar application of Code Case N416-1 has been approved by the NRC for the Commonwealth Edison Company in an SER dated May 25, 1994.
PSE&G also requests-tnaf-the--subject relief request be prioritized as a Cost Beneficial Licensing Action. The proposed relief request modifies a requirement that provides little or no safety benefit, yet will require significant resources to implement.
We have estimated the cost savings as $184K/yr for each unit. Savings over the life of the plants is $4M for Salem Unit 1, $4.SM for Salem Unit 2, and $5.9M for Hope Creek.
Document Control Desk NLR'-N94163 3
NOV 181994 Approval of this application for Code Case N416-1 is requested by March 31, 1995 for the twelfth refueling outage for Salem unit 1, which is scheduled for April of 1995.
Work associated with the Steam Generator (S/G) Feed Water nozzles would presently require performing a hydrostatic test.
The test boundary for this test would encompass the S/G's proper, portions of feedwater, mainsteam and generator blowdown piping, all of which are non-isolable from the Steam Generators.
Due to the extreme complexity of this test, it has been estimated that the cost for performing the tests will be $SOK per S/G.
Expedient approval of this application for Code Case N416-1 would provide a large cost savings and eliminate critical path work, from which there is no added safety benefit, from the Salem Unit 1 outage.
Should you have any questions on this transmittal, please contact us.
Sincerely,
~
Document Control Desk NLR-N94163 Attachment (1) 4 C
Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 NOV 18 1994 Mr. D. Moran, Licensing Project Manager -
Hope Creek U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. L. Olshan, Licensing Project Manager -
Salem
- u. s. Nuclear Regulatory Commission One White Flint North' 11555 Rockville Pike Rockville, MD 20852 Mr. R. summers (S05)
USNRC Senior Resident Inspector -
Hope Creek Mr. c. Marschall (S05)
USNRC Senior Resident Inspector -
Salem Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Bureau of Nuclear Engineering CN415 Trenton, NJ 08625