ML18101B157
| ML18101B157 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 12/29/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML18101B156 | List: |
| References | |
| NUDOCS 9601030344 | |
| Download: ML18101B157 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST FROM THE IMPLEMENTATION OF CODE CASE N-532 FOR PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM NUCLEAR GENERATING STATION. UNITS I AND 2 I.O INTRODUCTION AND HOPE CREEK GENERATING STATION DOCKET NOS. 50-272. 50-3II. AND 50-354 The Technical Specifications for Salem and Hope Creek 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 for the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by IO CFR 50.SSa{g), except where specific written r~lief has been granted by the Commission pursuant to IO CFR 50.55a(g){6){i). It is stated in IO CFR 50.55a{a){3) that alternatives to the requirements of paragraph {g) may be used, when authorized by the NRC, if {i) the proposed alternatives would provide an acceptable 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 IO CFR 50.55a{g){4), ASME Code Class I, 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 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 first ten-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in IO CFR 50.55a{b) twelve months prior to the start of the I20-month interval, subject to the limitations and modifications listed therein:
{I) Salem, Unit I, second IO-year Inservice Inspection {ISi) interval is the I983 Edition with the Summary I983 Addenda, (2) Salem 2, second IO-year ISi interval is the I986 Edition, and (3) Hope Creek, first IO-year ISi interval is the I983 Edition with the Summary I983 Addenda.
The components {including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in IO CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Commission approval.
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- Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME 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 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, 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 res~lt if the requirements were imposed.
In a letter dated November 3, 1995, Public Service Electric and Gas Company (PSE&G), the licensee, submitted to the NRC a request for relief regarding the implementation of Code Case N-532 Alternate Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000 for Salem and Hope Creek.
Licensee's Code Relief Request:
The licensee requested relief from Code-required repair and replacement and inservice summary report documentation and submission requirements.
Licensee's Basis for Requesting Relief (as stated):
"Code Case N-532 provides an alternative to the current ASME Section XI repair and replacement documentation requirements, and.regulatory reporting requirements related to lnJervice Inspections.
NRC Letter (sic) [Paper]
SECY-94-093 dated April 1, 1994, provides the NRC's recommendation to eliminate the need to submit summary Inservice Inspection (ISi) reports to the NRC following each refueling outage in accordance with ASME Section XI, Article IWA-6000.
The NRC recommended that code reporting requirements per IWA-6000 be modified through its representation on the ASME Code Committee to reduce licensee burden and eliminate the need to submit the ISi summary reports. Consistent with the recommendations in the NRC SECY Letter (sic)
[Paper], it is PSE&G's intent to not submit periodically the Owner's Activity Report identified by Code Case N-532.
The Owner's Activity Report will be completed by PSE&G in accordance with Code Case N-532 and will be available for NRC review upon request."
"The cost effective alternatives afforded by this Code Case have been determined by the ASME to provide an acceptable alternative to existing requirements.
The alternatives provide a substantial reduction in the overall administrative burden each of the PSE&G's plants are required to meet in accordance with the requirements of IWA-6000.
Further, this Code Case does not create any technical changes that would impact the existing ISi programs or the Technical Specifications at either Salem or Hope Creek, and does not introduce a condition that would compromise existing levels of safety or quality."
Licensee's Proposed Alternative Examination Implement Code Case N-532.
- Evaluation:
The use of Form NIS-1, owner's Report For Inservice Inspections, and Form NIS-2, Owner's Report for Repairs or Replacements, and submittal of the 90-day Summary Report are Code requirements. Alternatives contained in Code Case N-532 allow the licensee to submit these records in an abstract format on Form NIS-2A, Repair/Replacement Certification Record, and Form OAR-1, Owner's Activity Report, following the completion of an inspection period.
Based on review of the Code, the staff has determined that re~uirements associated with the documentation of inservice examinations and repairs/replacements and the subsequent submittal of Forms NIS-1 and NIS-2 within 90 days following a refueling outage are administrative only. It is noted that repair and replacement documentation reviews and approvals by the Authorized Nuclear Inspector continue to be required by this Code Case and that the licensee is required to establish a Repair/Replacement Plan in accordance with IWA-6340 of the 1992 Edition of Section XI.
The licensee has implemented Inspection Program B of the Code.
Under this program, examination schedules are satisfied on a per period basis.
Considering the milestones associated with Inspection Program 8, it can be concluded that the submittal of the results of examinations and an abstract of repairs/replacements on a periodic basis is a reasonable alternative.
In addition, the staff believes that the use of forms contained in Code Case N-532, that provide a summary of the status of repairs/replacements and a more detailed status of examinations by period and interval, is an improvement over report forms currently required by the Code.
For example, OAR-I includes the status of examinations credited for a period and percent credited to date, for the interval, by Examination Category.* This type of information provides the regulatory authorities a more comprehensive report on the status of the inservice inspection program.
Considering that the Code recording and reporting criteria satisfy only administrative requirements, the staff believes that use of the alternatives to Code requirements contained in Code Case N-532 will continue to provide an acceptable level of quality and safety for Salem and Hope Creek.
3.0 CONCLUSION
The staff has evaluated the licensee's request to implement alternatives to Code requirements contained in Code Case N-532, Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000.
It has been determined that the alternatives contained in Code Case N-532 are only administrative changes to recording and reporting requirements for repairs/replacements and inservice examinations.
Implementation of the alternatives contained in this Code C~se will continue to provide an acceptable level of quality and safety for Salem and Hope Creek. Therefore, the alternatives contained in this request for relief are approved for use pursuant to 10 CFR 50.55a(a)(3)(i), provided that all requirements of Code Case N-532 are satisfied. Use of Code Case N-532 is authorized until such
- time as the Code Case is published in a future rev1s1on of RG 1.147.
At that time, if the licensee intends to continue to implement this Code Case, the licensee is to follow all provisions in Code Case N-532 with limitations issued in RG 1.147, if any.
Principal Contributor:
L. Olshan Date:
December 29, 1995
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