ML18101A644

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Safety Evaluation of First ten-year Interval Inservice Insp Program Plan,Final Request for Relief for Salem Plant,Unit 2
ML18101A644
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Site: Salem PSEG icon.png
Issue date: 04/13/1995
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Office of Nuclear Reactor Regulation
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NUDOCS 9504180358
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555--0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE FIRST TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN FINAL REQUESTS FOR RELIEF

1.0 INTRODUCTION

FOR PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION. UNIT 2 DOCKET NUMBER 50-311 The Technical Specifications for Salem Generating Station, Unit 2 state that.

the inservice inspection of the American Society of Mechanical Engineers (ASME) Code Class I, 2, and 3 components shall be performed in accordance with Section XI of the ASM_E Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). Title 10 of the Code of Federal Regulations, Part 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an accept~ble level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Componehts," 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 first ten-year interval and subsequent intervals comply with the requirements in the lates:t* edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable edition of Section XI of the ASME Code for the Salem Nuclear Generating Station, Unit 2, first IO-year inservice inspection (ISI) interval is the 1974 Edition through Summer 1975 Addenda.

The components (including supports) may meet the requirem_ents set forth in subsequent editions and addenda of the ASME Code incorporated by

. referenc~ in 10 CFR 50.S5a(b) subject to the limitations and modifications

  • listed therein and subject to Commission approval.
  • Pursuant to 10 CFR 50.SSa{g){S), if the licensee determines that conformance with an examination requirement of Section XI of the ASHE Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASHE Code requirement. After evaluation of the determination, pursuant to 10 CFR 50.55a{g){6){i), the Conunission may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life, property, or the conunon 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.

In a letter dated September 28, 1992, Public Service Electric and Gas of New Jersey submitted to the NRC its first ten-year interval inservice inspection program p)an final requests for relief for the Salem Nuclear Generating Station, Unit 2. Additional information was provided by the licensee in its letter dated December 10, 1993.

2.0 EVALUATION AND CONCLUSIONS The staff, with technical assistance from its contractor, the Idaho National Engineering Laboratory {INEL), has evaluated the information provided by the licensee in support of its first ten-year interval fnservice inspection program plan final requests for relief for Salem Nuclear Generating Station, Unit 2.

Based on the information submitted, the staff adopts the contractor's conclusions and recommendations presented in the Technical Evaluation Report attached. Requests for Relief Nos. 1, 2, 3, and 5 are granted pursuant to 10 CFR 50.55a{g){6)(i) in that the requirements of the code are impractical.

The alternative proposed in Relief No. 4 is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) in that the required examination would result in a hardship without a compensatory increase in safety. Such relief is authorized by law and will not endanger life, property, or the common defense and security, and is otherwise in the public interest. The granting of relief has been given due consideration to the burden upon the licensee that would result if the requirement were imposed on the facility.

  • Principal Contributor: T. Mclellan Date:

April 13, 1995

Attachment:

Technical Evaluation Report

UNITED STATES.

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TECHNICAL EVALUATION REPORT OF THE FIRST IO-YEAR INTERVAL INSERVICE INSPECTION REQUEST FOR RELIEF FOR I.O INTRODUCTION PUBLIC SERVICE ELECTRIC & GAS OF NEW JERSEY SALEM NUCLEAR GENERATING STATION. UNIT 2.

DOCKET NUMBER:

50-3II The licensee, Public Service Electric & Gas Company. of New Jersey, submitted Final Requests for Relief for the first IO-year ISi interval, which began October I3, I98I, in a letter dated September 28, 1992.

In addition, the licensee submitted their response to an October 5, I993, NRC request for additional information by letter dated December IO, I993.

The Idaho National

  • Engineering Laboratory (INEL) has evaluated the subject requests for relief in the following sections.

2.0 EVALUATION The Code of record for the Salem Nuclear Generating Station~ Unit 2, first IO-year inservice inspection (ISi) interval is the I974 Edition, through Summer I975 Addenda.

The information provided by the licensee in support of the requests for relief from requirements determined to be impractical has been evaluated and the bases for granting relief from those requirements are documented below.

A.

Final Relief Request - #I Final Relief Request #I includes requests for relief from examination requirements of the ASME Code,Section XI, for Class I and 2 welds.

Included in this relief request are examination areas subject to the examination requirements of Subsection IWB, Table IWB-2500 for Examination Categories B-D, B-F, B-J and Subsection IWC-2520, Examination Categories C-A, C-C, C-E-I, C-F and C-G.

To perform the evaluation, examination areas have been grouped by the applicable Examination Category. A common "Basis for Relief" and "Alternative Examinati.on" have been developed by the licensee for all examination areas that are part of Final Relief Request #I.

Provided below are the licensee's common "Basis for Relief" and "Alternative Examination",

followed by the subgroups of Final Relief Request #I.

Licensee's Stated Basis for Requesting Relief:

"The ASME Code requires surface and volumetric examination of various Class I vessel and piping welds as defined in Paragraph IWB-2500 and various Class 2 vessel and piping welds as defined in Paragraph IWC-2500.

.. "During the inservice examinations performed at SALEM NUCLEAR GENERATING STATION UNIT 2 it has been the position of PUBLIC SERVICE ELECTRIC AND GAS COMPANY that examinations which could not be performed completely, (i.e., performed from two (2} directions because of component configuration or restrictions from permanent structures} the examination would be performed to the greatest extent possible and whatever limitation t.hat existed be documented.

"It has also been PUBLIC SERVICE ELECTRIC AND GAS COMPANY's position that when there was a "removable" structure, (i.e., hanger, support}

these items were removed, when practical, providing greater access to the component being examined.

The basis for this position is as follows:

'The code of Federal Regulation, 10CFR50, "Domestic Licensing of Production and Utilization Facilities" defines those requirements which must be adhered to by the utility in order to be issued and maintain an operating license. This document states in paragraph 55a(g} that inservice inspections shall meet the requirements of the ASME Boiler & Pressure Vessel Code.

'Throughout 10CFR50 numerous references are made allowing performance of these inspections "to th~ extent practical".'

"Some of the specific paragraphs are:

'Paragraph 50.55a(g}4 states that throughout the service life of a nuclear power facility components which are classified as ASME Code Class 1, 2, and 3 shall meet the requirements of Section XI of the ASME B&PV Code, "to the extent practical within the limitations of design, geometry and materials of construction of the components".

'Paragraph 50.55a(2}i of this docume_nt states that inspection of systems and components is performed "to the maximum extent practical, in accordance with generally recognized codes and standards" i.e., ASME Boiler & Pressure Code.

'Paragraph 50.55g(l} states that components (including supports}

shall meet the requirem~nts of (ASME Code} "to the extent practical".'

"The ASME Code itself provides allowance for 'limited' examinations.

The 1986 Edition,Section V, Article 4, Paragraph T-441.3;2.4 states:

'Whenever feasible, the scanning of the examination volume shall be carried out from both sides of the weld on the same surface.

Where configuration of adjacent parts of the component are such that the scanning from both sides is not feasible, this fact shall be included in

  • the report of the examination'.
  • "PUBLIC SERVICE ELECTRIC AND GAS COMPANY has utilized approved technical
  • procedures written in accordance with the applicable Section/Paragraph of the ASME Code in regard to the area/volume to be examined and the specified requirements of the examination for *the 1st inspection interval. Recognizing that because of component design, Construction, etc. there are cases when examinations can only be performed 'to the greatest extent possible'.

PUBLIC SERVICE ELECTRIC & GAS has previously submitted a 'list of those identified limitations after performing the preservice examination. Subsequently Weld selection for this interval was made to minimize known limitations identified during preservice examination (PSI).

For limitations found during the 1st inservice inspection interval, additional components were scheduled and examined, when possible, to meet the allocation table requirements of ASME Section XI 1974 Edition, Summer 75 Addenda.

"PSE&G requested and received approval for use of ASME Code Case N-460 in February, 1990 allowing a reduction of examination coverage not to exceed 10% of the required volume.

Utilizing that criteria and the additional guidance found in 2.A of the NRC RAI, dated October 5, 1993 on accumulative examination volume coverage, PSE&G has been able to minimize those components requiring relief."

Licensee's Proposed Alternative Examination (as stated):

"No alternate examinations were performed on the components listed in the attached table for the following reasons:

1.

Where appropriate,Section XI had already required surface examinations in addition to volumetric examinations.

2.

Performing surface examinations on areas with limitations were not justified when considering the following:

a) all examination areas received coverage greater than

  • 50% of the required vo i ume.

b)

The Code has identified the examination area, to be the lower 1/3 of the weld.

Performing a surface examination on the outside surface gives no information on the condition of the lower 1/3 of the weld.

c) Additional radiation exposure to personnel."

Al.

Final Relief Request - #1. Examination Category B-C. Item Bl.3, Reactor Pressure Vessel to Flange Circumferential Weld Code Requirement:

Table IWB-2500, Examination Category B-C, Item Bl.3 requires volumetric examination of 100% of the length of each circumferential weld selected for examination during the

. interval.

.. Licensee's Code Relief Request:

The licensee requested relief from the Code-required 100% volumetric examination coverage for Weld 2-RPV-7442.

Licensee's Basis for Requesting Relief:

(See Part A aboye.)

Licensee's Proposed Alternative Examination:

(See Part A above.)

Evaluation:

The Code requires that the subject weld be 100%

volumetrically examined during the inspection interval.

Due to the flange configuration, complete volumetric examination coverage is impractical~ To obtain complete volumetric coverage, design modifications or replacement of the component with one of a design providing for complete coverage would be required.

Imposition of this requirement would cause a considerable burden on the licensee.

The licensee performed the examination to the extent practical, resulting in 60% examination coverage.

Based on the significant percent of coverage obtained, it is reasrinable to conclude that degradation, if present, would be detected.

As a result, reasonable assurance of operational readiness has been confirmed. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), it is recommended that relief be granted as requested.

A2.

Final Relief Request - #1. Examination Category B-D. Item B3.2.

Steam Generator Inlet and Outlet Nozzle Inner Radius Sections Code Requirement:

Table IWB-2500, Examination Category B-D, Item B3.2 requires 100% volumetric examination of the steam generator nozzle inner radius sections.

Licensee's Code.Relief Request:

The licensee requested relief from the Code-required 100% volumetric examination coverage for the steam generator nozzle inner radius sections listed below.

It was stated that in all cases examination coverage was limited by the location of a permanent insulation support.

Percentage of Code Component ID & Description Cove~age Obtained 31-STG-1240-IRS, Outlet Nozzle Inner Radius Section 86%

31-STG-1230-IRS, Outlet Nozzle Inner Radius Section 81%

31-STG'-1220-IRS, Outlet Nozzle Inner Radius Section 75%

31-STG-1210-IRS, Outlet Nozzle Inner Radius Section 80%.

29-STG-1240-IRS, Inlet Nozzle Inner Radius Section

  • 84%

29-STG-1230-IRS, Inlet Nozzle Inner Radius Section 75%

29-STG-1220-IRS, Inlet Nozzle Inner Radius Section 66%

29-STG-1210-IRS, Inlet Nozzle Inner Radius Section 86%

Li~ensee's Basis for Requesting Relief: (See Part A above.)

Licensee's Proposed Alternative Examination:

(See Part A above.)

Evaluation:

The Code requires that the subject nozzle inner radius sections be 100% volumetrically examined during the inspection interval.

Due to the l,ocation of permanent insulation supports, complete Code examination coverage of the subject examination areas is impractical.

To obtain complete volumetric coverage, design modifications of the permanent insulation supports would be required.

Imposition of this requirement would cause a considerable burden on the licensee.

The licensee performed the examinations to the extent practical, resulting in coverages from 66 to 86%.

Based on the significant percentage of coverage obtained, it is reasonable to conclude that degradation, if present, would be detected.

As a result, reasonable assurance of operational readiness has been confirmed, Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), it is recommended that relief be granted as requested.

A3.

Final Relief Request - #1. Examination CategorY B-F. Item B4.1.

Class 1 Pressure Vessel Nozzle-to-Safe Ends Code Requirement: Table IWB-2500, Examination Category B-F~

Item 83.2 requires a 100% volumetric and surface examination of nozzle-to-safe end welds.

Licensee's Code Relief Request:

Relief is requested fromthe Code-required 100% volumetric coverage of the following Class 1 nozzle-to-safe end welds:

Component ID & Description 6-PR-1205-1, Nozzle-to-Safe End 6-PR-1204-1, Nozzle-to-Safe End 6-PR-1203-1, Nozzle-to-Safe End 31-RC-1240-1, Nozzle-to-Elbow 31-RC-1230-1, Nozzle-to-Elbow Percent of Code Coverage.

Obtained 50%

. 50%

64%

50%

. 50%

Examination Coverage Limited By:

Nozzle & safe end configuration Nozzle & safe end configuration Nozzle & safe end configuration Nozzle configuration & acoustic properties Nozzle configuration & acoustic properties Percent of Code Coverage Component ID & Description Obtained Examination Coverage Limited By:

31-RC-1220-1, Nozzle-to-Elbow 50%

Nozzle configuration & acoustic properties 31-RC-1210-1, Nozzle-to-Elbow 50%

Nozzle configuration & acoustic properties 29-RC-1240-5, Elbow-to-Nozzle 50%

Nozzle configuration & acoustic properties 29-RC-1230-5, Elbow-to-Nozzle 50%

Nozzle configuration & acoustic properties 29-RC-1220-5, Elbow-to-Nozzle 50%

Nozzle configuration & acoustic properties 29-RC-1210-5, Elbow-to-Nozzle 50%

Nozzle configuration & acoustic properties Licensee's Basis for Reguesting Relief:

(See Part A above.)

Licensee's Proposed Alternative Examination:

(See Part A above.)

Evaluation:

The Code requires that the subject nozzle-to-safe end welds receive a 100% volumetric and surface examination.

The licensee stated that 100% of the surface examinations were performed.

  • However, due to the nozzle-to-safe end configuration, complete volumetric Code coverage is impractical.

To obtain complete volumetric coverage, design modifications or replacement of the nozzle-to-safe end with one of a design providing for complete coverage would be required.

The licensee performed the volumetric examinations to the extent practical, resulting in coverages from 50 to 64%.

Based on the significant percent of coverage obtained and the surface examination, it is reasonable to conclude that significant degradation, if present, would be detected.

As a result, reasonable assurance of operational readiness has been confirmed. Therefore, pursuant to 10 CFR S0.55a(g)(6)(i), it is recommende*d that relief be granted as requested.

. A4.

Final Relief Reguest - #1. Examination Category B-J, Item B4.5.

Circumferential Pipe Welds Code Reguirement:

Table.IWB-2500, Examination Category B-J, Item B4.5 requires 100% volumetric examination of Class 1 pressure-retaining piping circumferential welds and one foot sections of adjoining longitudinal welds.

.. Licensee's Code Relief Request:

Relief is requested from 100%

volumetric coverage of the following examination areas:

Component ID & Description 31-RC-1240-3, Pipe-to-Elbow 31-RC-12~0-3, Pipe-to-Elbow 31-RC-1210-4, Elbow-to-Pipe 29-RC-1210-4, Pipe-to-Elbow 27.5-RC-1240-1, Pump-to-Pipe IO-SJ-1241-8, Elbow-to-Pipe 6-SJ-1241-16, Valve-to-Pipe 6-SJ-1222-1, Reducer-to-Valve Percent of Code Coverage Obtained 79%

80%

77%

75%

74%

50%

77%

.50%

Examination Coverage Limited By:

Elbow Acoustic Properties Elbow Acoustic Properties Location of Branch Connection and Elbow Acoustic Properties Elbow Acoustic Properties Pump Configuration and Proximity of Branch Connection Existing Permanent Penetration Sleeve Valve Configuration Reducer and Valve Configuration 4-SJ-1282-10, 83%

Permanent Structural I-Beam Member Pipe-to-Elbow Licensee's Basis for Requesting Relief:

{See Part A above.)

Licensee's Proposed Alternative Examination:

{See. Part A above.)

Evaluation:

The Code requires that the subject Class I piping welds receive 100% volumetric examination.

Due to limitations described in the above table, complete volumetric Code coverage is impractical.

To obtain complete Code-required volumetric coverage, design modifications and/or replacement of components with components fabricated of materials compatible with ultrasonic examination would be required.

Imposition of this requirement would cause a considerable burden on the licensee.

ihe licensee performed the volumetric examinations to the extent practical, which resulted in ~xamination coverages from 50 to 83%.

Based on the significant percent of coverage obtained, it is reasonable to conclude that degradation, if present, would be detected.

As a result, reasonable assurance of operational readiness has been confirmed~ Therefore, pursuant to 10 CFR 50.55a{g){6){i}, it is recommended that relief be granted as requested.

AS.

Final Relief Request - #I, Examination Category C-A, Item Cl.I.

Upper Head to Flange Weld Code Requirement: Table IWC-2520; Examination Category C-A, It~m c1-.1 requires volu~etric examination of at least 20% of each circumferential weld, uniformly distributed among three areas around the vessel circumference.

Licensee's Code Relief Request:

The licensee requested relief from the Code-required coverage of the Reactor Coolant Filter upper head-to-flange Weld 2-RCF-1.

Licensee's Basis for Requesting Relief:

(See Part A above.)

Licensee's Proposed Alternative Examination:

(See Part A above.)

Evaluation:

The Code requires that at least 20% of each circumferential weld, uniformly distributed among three areas around the vessel circumference, be volumetrically examined.

Due to the weld and flange configuration, complete volumetric coverage is impractical.

To obtain complete volumetric coverage, design modifications or replacement of the components with those of a design providing for complete coverage would be required.

Imposition of this requirement would cause a considerable burden on the licensee.

The licensee performed the volumetric examinations to the extent practical, resulting in 50% coverage of the Code-required examination volume.

Based on the significant percent of coverage obtained, it is reasonable to conclude that degradation, if present, would be detected.

As a result, reasonable assurance of operational readiness has been

recommended that relief be granted as requested.

A6.

Final Relief Reguest - #1. Examination Category C-C. Item Cl.3.

Class 2 Pressure Vessel Integrally-welded Vessel Supports Code Requirement: Table IWC-2520, Examination Category C-C, Item Cl.3 requires 100% surface examination of integrally welded support attachments to Class 2 pressure vessels.

Licensee's Code Relief Request:

The licensee requested relief from the Code-required 100% surface examination of the Chemical and Volume Control Tank, vessel support 2-CVCT-2VS-1&2.

Licensee's Stated Basis for Requesting Relief: *csee Part A above.)

Licensee's Stated Proposed Alternative Examination:

(See Part A *bove.)

Evaluation:

The Code requires 100% surface examination of integrally welded support attachments to Class 2 pressure vessels.

Due to a permanent I-beam vessel support on the Chemical and Volu~e Control Tank~ the Code-required 100% surface examination of-the subject weld is impractical.

To perform a complete surface examination, design modifications would be required.

Imposition of this requirement would cause a considerable burden on the licensee.

The licensee performed the surface examination to the extent practical, resulting i~ 89% coverage.

Based on the significant percentage of coverage obtained, it is reasonable to conclude that degradation, if present, would be detected.

As a result, reasonable assurance of operational readiness has been confirmed. Therefore, pursuant to 10 CFR 50.55a{g){6){i), it is recommended that relief be granted as requested.

A7.

Final Relief Request - #1. Examination Cateaorv C-E-1. Item C2.5.

Class 2 Piping Integrally Welded Supports Code Requirement: Table IWC-2520, Examination Category C-E-1, Item C2.5 requires a 100% surface examination of the weld, base metal, and integral attachment to Class 2 piping for a distance of two support thicknesses.

Licensee's Code Relief Request:

The licensee requested relief from the Code-required 100% surface examinations for integrally welded pipe supports 34-MS-2241-2PS~l&2 and 12-SJ-2252-38.

Licensee's Stated Basis for Requesting Relief: 1See Part A above.)

Licensee's Stated Proposed Alternative Examination:

{See Part A above.)

Evaluation:

The Code requires 100% surface examination of Class 2 integrally welded piping support welds; base metal, and the integral attachment for a distance of two support thicknesses.

Due to the proximity of permanently installed pipe supports, the Code-required surface examination coverage is impractical.

To obtain complete surface examination coverage, design modifications would be required.

Imposition of this requirement would cause a considerable burden on the licensee.

The licensee performed the Code-required surface examination to the extent practical, resulting in 25% coverage for examination area 34-MS-2241-2PS-1&2 and 71% for examination area 12-SJ-2252-38.

Based on the significant percent of coverage obtained, it is reasonable to conclude that degradation, if present, would be detected.

As a result, reasonable assurance of operational readiness has been confirmed.

Therefore, pursuant to 10 CFR 50.55a{g){6){i), it is recommended that relief be granted as requested.

AB.

Final Relief Request - #1, Examination Category C-F, Item C2.l Class 2 Piping Welds Code Requirement:

Table IWC-2520, Examination Category C-F, Item C2.l requires a 100% volumetric examination of Class 2 circumferential butt welds in pressure retaining piping that circulates r.eactor coolant.

Licensee's Code Relief Request:

The licensee requested relief from the Code-required 100% volumetric coverage of following Class 2 pipe welds:

Component ID & Description 6-PR-2203-2, Elbow-to-Pipe 8-RH-2273-1, Tee-to-Valve 8-RH-2216-4, Flange-to-Valve 8-CV-2201~1, Valve-to-Pipe Percent of Code Coverage Obtained Examination Coverage Limited By:

60%

Proximity of Permanently Installed Pipe Support 50%

Valve a'!_d Tee Configuration 50%

Flange Configuration 85%

Proximity of Permanent Pipe Restraint and Valve Configuration 8-CV-2210-11, Pipe-to-Tee 82%

Proximity of Permanent Pipe Restraint Licensee's Stated Basis for Requesting Relief:

(See Part A above.)

Licensee's Stated Proposed Alternative Examination:

(See Part A above.)

Evaluation:

The Code requires that the subject piping welds receive 100% volumetric examination.

Due to the limitations described in the table above, the Code-required 100% volumetric coverage is impractical.

To obtain completed volumetric coverage, design modifications and/or replacement of the component with one of a design providing for complete coverage would be required.

Imposition of this requirement would cause a considerable burden on the licensee.

The licensee performed the volumetric examinations to the extent practical, resulting in coverages from 50 to 60%.

Based on the significant percent of coverage obtained, it is reasonable to conclude that degradation, if present, would be detected.

As a result, reasonable assurance of operational readiness has been confirmed.

Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), it is recommended that relief be granted as requested.

11 -

A9.

Final Relief Request - #1, Examination Category C-G. Item C2.1. Class 2 Piping Welds Code Requirement:

Table IWC-2520, Examination Category C-G, Item C2.1 requires 100% volumetric examination of Class 2 circumfetential butt welds in pressure retaining piping that circulates other than reactor coolant.

Licensee's Code Relief Request:

Relief is requested from the Code-required 100% volumetric coverage of circumferential piping butt Weld 6-MS-2231-4 (Pipe-to-Valve).

Licensee's Basis for Requesting Relief:

(See Part A above.)

Licensee's Proposed Alternative Examination:

(See Part A above.)

Evaluation:

The Code requires that the subject piping weld receive a 100% volumetric examination.

Due to the pipe-to-valve configuration, complete volumetric coverage is impractical.

To obtain complete volumetric coverage, design modifications or replacement of the component with one of a design providing for complete coverage would be required.

Imposition of this requirement would cause a considerable burden on the licensee.

The licensee performed the volumetric examination to the extent practical, resulting in 89% coverage.

Based on the significant percent of volumetric examination coverage that was obtained, it is reasonable to conclude that degradation, if present, would be detected.

As a result, reasonable assurance of operational readiness has been confirmed. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), it is recommended that relief be granted as requested.

. B.

Final Relief Request - #2, Examination Category B-M-2. Item B6.7, Class 1 Valve Body Internal Surfaces Code Requirement:

Table IWB-2500, Examination Category B-M-2, Item B6.7 requires a visual examination of Class 1 valve body internal pressure boundary surfaces for valves exceeding 4 inch nominal pipe size. This* is limited to one valve in each group of valv~s of the same type (i.e. globe, gate, or check valve),

manufacturing method, and manufacturer.that performs similar functions in the system.

Licensee's Code-Relief Request:

The licensee req~ested relief from the first IO-year visual examination requirements for Class 1 pressure retaining valves.

Licensee's Stated Basis for Requesting Relief:

"The disassembly of functional valves during the first ten year inspection interval for the sole purpose of performing a visual

I* examination of the internals would have increased the likelihood for component failure in the future*and was contrary to good maintenance practices. Considering the uncertainty of the benefit involved with this examination, it is difficult to justify the additional radiation exposure that would be incurred as a result of the disassembly, examination and reassembly of these valves.

For example, estimates from radiation s4rveys performed on and around valve 2RH1 indicated that the total job dose that would be received in disassembling, examining and reassembling this valve be in excess of 4 man-rem.

Public Service Electric & Gas feels implementation of this examination is impractical for valves not scheduled for disassembly because of preventive or corrective maintenance.

In the 1989 and later editions of Section XI, this examination is only required to be performed on valves scheduled for disassembly for maintenance purposes."

Licensee's Proposed Alternative Examination (as stated):

"As required by the 1989 edition of Section XI, table IWB-2500 Category B-M-2, Item 812.50 examinations*were performed when the valve was disassembled for maintenance, repair, or volumetric examination.

Also in accordance with the 1989 Edition IWB-2430 (a) when examinations reveal or relevant conditions that exceed the acceptance standards, examinations were extended to include additional valves.

"Utilizing the above requirements, the following valves, listed by group were never disassembled during the first inspection interval and therefore, the internals were not visually examined."

Valve Valve Valve Group Group Group 2RH1 2RH26 21SJ49 2RH2 22SJ49 Valve Group 21SJ54 22SJ54 23SJ54 24SJ54 Evaluation:

The visual examination requirement for internal surfaces of valves requires the disassembly of the valve. This disassembly is a major effort and requires many manhours from skilled maintenance and inspection personnel and may cause excessive radiation exposure. Therefore, the Code requirement is considered impractical.

The visual examination is performed to determine if un~nticipated degradation of the casing is occurring due to phenomena such as erosion, corrosion, or cracking.

Later editions and addenda of the ASME Code (after 1988) have eliminated disassembly of valves for the sole purpose of examining the internal surfaces.

The later Code states that the internal surface visual examination requirement is only applicable to valves that are disassembled for reasons such as maintenance, repair, or volumetric examination. Therefore, the concept of

.e visual examination of the valve internal surfaces only if the valve is disassembled for maintenance is acceptable.

The licensee's program for the examination of valve body internal surfaces will provide assurance of the continued inservice strtictural integrity. Therefore, pursuant to 10 CFR 50.55a{g){6){i), it is recommended that relief be granted as requested..

C.

Final Relief Request - #3, Examination Categories B-D. Item Bl.4.

Nozzle-to-Vessel Welds and Inner Radius Sections Code Requirement:

Category B-D, Item Bl.4 requires a 100%

volumetric examination of primary nozzle-to-vessel welds and nozzle inside radius sections.

Licensee's Code Relief Request:

The licensee requested relief from the Code-required 100% volumetric examination for the following reactor pressure vessel, nozzle-to-vessel welds:

Component ID &

Percent of Code Description Coverage Obtained Examination Coverage Limited By:

29-RCN-1240, Outlet Nozzle at 22 degrees 50%

Integral Extension and Geometric 29-RCN-1230, Outlet nozzle at 158 degrees 29-RCN-1220, Outlet Nozzle at 203 degrees 50%

50%

Shadowing Integral Extension Shadowing Integral Extension Shadowing and Geometric and Geometric 29-RCN-1210, Outlet nozzle at 338 Degrees Licensee's Stated Basis 50%

Integral Extension and Geometric Shadowing for Requesting Relief:

11Due to the geometry of the reactor vessel, 100% of the Code required coverage of all the applicable welds cannot be obtain~d. These examinations are performed from the inside diameter utilizing automated UT equipment.

No examinations ca~ be performed from the outside diameter surface, due to the design of the building structure

. surrounding the reactor vessel making access impossible.

11 Licensee's Proposed Alternative Examination (as stated):

"There are no alternative examinations proposed for these examinations."

Evaluation:

The Code requires that the subject weld~ receive 100%

volumetric examination.

Complete volumetric coverage is impractical due to the integral extension and to geometric shadowing when examinations are performed from the inside surface.

No examinations*are performed from the outside surface due inaccessibility, the result of the building structure surrounding the examination area.

To obtain complete volumetric coverage,

'. des~gn modifications or replacement of the component with one of a design providing for complete coverage would be required.

Imposition of this requirement would cause a considerable burden on the licensee.

The licensee performed the volumetric examinations to the extent practical, ~esulting in 50% coverage of each examination area..

Based on the significant percent of volumetric examination coverage obtained, it is reasonable to conclude that degradation, if present, would be detected.

As a result, reasonable assurance of operational readiness has been confirmed. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), it is recommended that relief be granted as requested.

D.

Final Relief Request - #4, Examination Category B-l-1, Item Bl.13, Interior Clad Surfaces of Reactor Vessels and Examination Category B-1-2, Items B2.9 and B3.8, Interior Clad Surfaces Of Vessels Other Than Reactor Vessels Code Requirement:

Examination Category B-1-1, Item Bl.13, requires a visual and a surface or volumetric examination of vessel cladding in the reactor pressure vessel closure head (at least six areas, 36 square inch patches) and Examination Category B-1-2, Items B2.9 and B3.8 require a visual examination of vessel cladding in the primary side of vessels other than the reactor vessel (at least one area, 36 square inch patch).

Licensee's Code Relief Request:

The licensee requested relief from visual and surface examinations of the reactor pressure vessel closure head clad surfaces and the visual examination of clad surfaces in the steam generators and pressurizer.

Licensee's Stated Basis for Requesting Relief:

"The requirement to perform these examinations has been deleted in later approved editions of ASME Section XI.. In addition, the radiation dose required to complete these inspections is in conflict with the station's ALARA guidelines. Visual and surface examinations were completed on two (2) of the six (6) required Reactor Pressure Vessel closure head cladding patches (Cat. B-I-1, Item Bl.13) in the first inspection period with no reportable indications noted.

"The cladding patch on the pressurizer (Cat. B-I-2, Item B2.9) was not examined during the inspection interval.

"Two (2) of the required eight (8) visual examinations on the steam generator cladding patches (Cat. B-1-2, Item B3.9) were completed in the first inspection period with no reportable indications noted."

Licensee's Proposed Alternative Examination:

None

f

  • . Evaluation:

The licensee requested relief from completing examinations of interior clad surfaces, citing the deletion of the Code requirements from later editions of the Code.

In addition,

  • the radiation dose required to complete these inspections is in conflict with the stations's ALARA guideline.

The license~ completed the Code-required visual and surface examinations on twn of six clad areas required for the reactor closure head during the first period.

Two of eight clad areas on the steam generator primary side were completed during the first period.

No reportable indications were recorded.

No clad surfaces were examined in the pressurizer.

The licensee performed part of the Code-required examination of interior:

clad surfaces during the first period of the interval.

In Code editions subsequent to the Code in affect for the Salem Nuclear Generating Station, Unit 2, the subject examination requirement was deleted.

In consideration that later Editions of the Code no longer require this examination and the licensee's position to maintain radiation levels as low as reasonably achievable, it can be conclud__ed that imposing the remaining Code required examinations on the licensee would result in a hardship without a compensating increase in safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii}, it is recommended that relief be authorized as requested.

E.

Final Relief Request - #5, Examination Category C-E-2. Item C2.6 and IWD-2600 CC), Component Supports For Piping Code Requirement:

Category C-E-2, Item C2.6 and IWD-2600 (C) require visual examination of component supports.

Licensee's Code Relief Request:

The licensee requested relief from visual examination of the following supports due to inaccessibility:

2C-21-FWH-018 2A-CCH-054 2A-CCH-079.

2A-SWG-317 2C-24-FWH-024 2A-CCS-064 2A-CCH-080

"Some of the supports scheduled for examination during the inspection interval could not be examined due to their accessibility. These supports cannot be examined because they are either encased within.

  • concrete or encapsulated by guard pipe.

In our submittal for Salem Unit 2, 2nd Ten Year Inspection Interval, Public Service Electric & Gas has requested the use of ASME Code Case N-491 which exempts these types of components from examination."

Licensee's Prooosed Alternative Examination: None Evaluation:

The licensee states that the subject supports are inaccessible for visual examination as they are either encased in concrete or encapsulated by guard pipes.

As a result, the Code-required visual examinations are impractical. It is noted that later approved Editions of the Code have recognized the impracticality of examining supports and support members that are encased in concrete or are encapsulated by guard pipes by providing a provision for exemption.

To comply with Code requirements for examination of the subject supports at Salem Nuclear Generating Station, Unit 2, design modifications would be required in order to satisfy the Code required visual examinations.

Imposition of this requirement on the licensee would cause a burden.

Therefore, pursuant to 10 CFR 50.55a(g)(6)(i}, it is recommended that.

relief be granted as requested.

3.0 CONCLUSION

The INEL staff has reviewed the licensee's submittal and responses to request for additional information and concludes that, pursuant to 10 CFR 50.55a(g)(6)(i), some of the requirements of the Code are impractical for the Salem Generating Station, Unit 2 facility. Therefore, it is recommended that relief be granted for Final Relief Requests 1, 2, 3, and 5 and the alternative requirements imposed, as stated. For Relief Request 4, it is determined. that compliance with Code requirements would result in a hardship without a compensating increase in the level of quality and safety.

Therefore*, pursuant.to 10 CFR 50.55a(a)(3)(ii), it is recommended that the proposed alternative be authorized.

Such relief is authorized by law and will not endanger life, property, or the common defense and security, and is otherwise in the public interest. The granting of relief has been recommended giving due consideration to the burden upon the licensee that would result if the requirement were imposed on the facility.

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