ML20209G672

Forwards Draft Request for Addl Info Re Inservice Insp - Second 10 Yr Interval

ML20209G672
Person / Time
Site:	Hope Creek
Issue date:	07/14/1999
From:	Richard Ennis NRC (Affiliation Not Assigned)
To:	NRC
References
TAC-MA2026, NUDOCS 9907190222
Download: ML20209G672 (6)

Text

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July 14, 1999 i I

i MEMORANDUM TO: Docket File Original signed by: i FROM: Richard B. Ennis, Project Manager, Section 2 Project Directorate l Division of Licensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

HOPE CREEK GENERATING STATION, DRAFT REQUEST FOR ADDITIONAL INFORMATION, INSERVICE INSPECTION - SECOND TEN-YEAR INTERVAL (TAC MA2026) -

The attached draft request for additional information (RAI) was transmitted by facsimile on July 14,1999 to Mr. Charles Manges of Public Service Electric & Gas Company (PSE&G).

Review of the RAI would allow the licensee to determine and agree upon a scheoule to respond >

to the RAl. This memorandum and the attachment do not convey a formal request for information or represent an NRC staff position.

Docket No. 50-354

Attachment:

Draft RAI DISTRIBUTION y \

Docket File \/ l PUBLIC 1 JClifford REnnis TMcLellan OFFICE PDI 2/PM NAME REnnis (  ;

DATE 1/ N /99 OFFICIAL RECORD COPY DOCUMENT BLAME: G:\PDI-2\ Hope Creek \mema2026.wpd 1OO()dO 9907190222 990714 34 DR ADOCK 050

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20565 4001 4 . , , , . *# July 14, 1999 MEMORANDUM TO: Docket File FROM: Richard B. Ennis, Project Manager, Section 2 Prnject Directorate i Division of Ucensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

HOPE CREEK GENERATING STATION, DRAFT REQUEST FOR i ADDITIONAL INFORMATION, INSERVICE INSPECTION - SECOND i

TEN-YEAR INTERVAL (TAC MA2026)

The attached draft request for additional information (RAl) was transmitted by facsimile on July 14,1999 to Mr. Charles Manges of Public Service Electric & Gas Company (PSE&G).

Review of the RAI would allow the licensee to determine and agree upon a schedule to respond to the RAl. This memorandum and the attachment do not convey a formal request for information or represent an NRC staff position.

Docket No. 50-354

Attachment:

Draft RAI

REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION - SECOND TEN-YEAR INTERVAL j HOPE CREEK GENERATING STATION (TAC NO. MA2026) l By letter dated May.11,1998, the licensee, Public Service Electric and Gas Company (PSE&G),

f submitted their second interval 10 year inservice inspection (ISI) program, including requests

for relief from the requirements of the ASME Code,Section XI, for the Hope Creek Generating Station (HCGS). The NRC's contractor, Idaho National Engineering and Environmental Laboratory (INEEL) has reviewed the information provided by the licensee in the subject requests for relief. Based on this review, the following Information is required to complete the evaluation of the subject requests for relief.' The regulatory basis for all of the questions is 10 CFR 50.55a.

1) Request for Relief RR-A3 - In accordance with 10 CFR 50.55a(a)(3)(i) the licensee has proposed the use of IWB-2412(a), IWC-2412(a), and IWD-2412(a) of the 1994 Addenda of ASME Section XI.10 CFR 50.55a(a)(3)(l) requires the applicant to demonstrate that the proposed attemative would provide an acceptable level of quality and safety. In order for this request to be found acceptable, present a discussion that describes how the proposed attemative examination (s) provides an equivalent and acceptable level of quality as compared to the current code requirements.

2) Request for Relief RR-A4 - The licensee has requested relief from the requirements of IWA-5250V(2), concerning leakage at bolted connections. The licensee has proposed to adopt Re requirements of IWA-5250(a)(2) of the 1990 Addenda. The 1990 Addenda requires that if leakage occurs at a bolted connection, one of the bolts shall be removed, VT-3 examined, and evaluated in accordance with IWA-3100. When the removed bolt has evidence of degradation, all remaining botting in the connection shall be removed, VT-3 examined, and evaluated in accordance with IWA 3100.

IWA-3100 invokes the use of subparagraphs IWB-3000, IWC-3000, IWD-3000 for Class 1,2, and 3 pressure retaining components respectively. However, none of these subparagraphs provide an acceptance criteria for VT-3 examinations of bolting.

Therefore, the ability to perform a meaningful evaluation on the bolting without an applicable acceptance criteria is questionable. The INEEL staff believes that a VT-1 visual examination utilizing the acceptance criteria defined in IWB-3000 provides a more appropriate method of examination of the subject bolting than a VT-3 visual examination.- Similar requests for relief have been approved with the condition that a VT-1 visual examination be performed utilizing the acceptance criteria for VT-1 examinations. Additionally, other licensees who have had this type of relief authorized have included a detailed and well defined engineering evaluation of the bolting and the bolted connection when leakage is detected. The evaluation should, at a minimum, considered the following factors: bolting materials, corrosiveness of process fluid

- leaking, leakage location, leakage history at connection or other system components, visual evidence of corrosion at connection (while connection is assembled), and service age of the bolting materials.

l DRAFT ATTACHMENT 3

l In order for the licensee's proposed attemative to be found acceptable, a specific leakage evaluation procedure is necessary. The leakage evaluation procedure should include the appropriate corrective actions to be taken if an evaluation is inconclusive or l identifies bolting degradation at a leaking bolted connection. Discuss the intended l action regarding this Request for Relief.

1 3). Request for Relief RR-B1 - This request for relief is for multiple Class 1 welds of

, various Code examination categories. Included are Code Category B-A, item B1.12 l welds. Provide the staff with the status of the augmented reactor pressure vessel I

examinations required by 10 CFR 50.55a(g)(6)(li)(A), effective September 8,1992, and provide a technical discussion of how the regulation was implemented at HCGS.

Include in the discussion a description of the approach and any specialized techniques or equipment that was used to complete the required augmented examination. Also, provide the percent of the volume examined for each weld.10 CFR

! 50.55a(g)(6)(ii)(A)(2) requires essentially 100% of the volume of each weld to be l examined. Confirm that " essentially 100%" of each Examination Category B1.10 weld I (RPV shell welds) have been examined, or that an altemative has been submitted for staff review pursuant to 10 CFR 50.55a(g)(6)(ii)(A)(5).

4) Request for Relief RR-B1 - The licensee has submitted this request for relief in accordance with 10 CFR 50.55a(a)(3)(ii).10 CFR 50.55a(a)(3)(ii) requires the applicant to demonstrate that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Present a discussion that describes how compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Additionally, present a discussion describing how the proposed attemative examination (s) provides reasonable assurance of structural integrity.

5) Request for Relief RR-B1 -It appears from the request for relief that the limitations associated with the subject welds are primarily due to physical obstructions and geometric configurations of the component surfaces. The licensee stated that these conditions affect the ability to obtain complete Code coverage. The limitations listed in Appendix C of the program are not detailed. Provide detailed descriptions of the limitations associated with the subject welds. Include drawings of weld configurations and physical obstructions associated with the components, as well as other items that may help describe the limitations, if available.

6) Request for Relief RR Code' Case N-547, as written, has not been considered acceptable by the INEEL staff. However, authorization to use Code Case N-547 has been epproved when the following is performed: 1) The licensee replaces the bolting with new material after disassembly, and/or 2) the licensee commits to performing a VT-

= 1 visualinspection on any bolting to be re-used.

L DRAFT ATTACHMENT

l a

The INEEL staff believes that when CRD bolting is replaced with used bolting, a visual examination (VT-1) should be performed to verify that the condition of the CRD bolting is acceptable. Mishandling of the bolting during removal can result in galling of threads, bending and other damage that may reduce the reliability of the bolting. Additionally, when the CRD bolting is being replaced with new bolting, the staff believes that a quality receipt inspection will provide an acceptable verification of the bolting integrity.

. Therefore, in order for this request to be found acceptable, provide a commitment to: 1) replace the bolting with new material, and/or 2) perform a VT-1 visual inspection on any bolting to be re-used.

7) Request for Relief RR-C1 - The licensee has submitted this request for relief in accordance with 10 CFR 50.55a(a)(3)(ii).10 CFR 50.55a(a)(3)(ii) requires the applicant

. to demonstrate that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality ano safety.

Present a discussion that describes why compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Additionally, present a discussion describing how the proposed altemative examination (s) provides reasonable assurance of structural integrity.

8) Request for Relief RR-C1 - It appears from the request for relief that the limitations associated with the subject welds are primarily due to physical obstructions and geometric configurations of the component surfaces. The licensee stated that these conditions affect the ability to obtain complete Code coverage. The limitations listed in

. Appendix C of the program are not detailed. Provide detailed descriptions of the limitations associated with the examination of the subject welds. Include drawings of configurations and physical obstructions associated with the components as well as other items that may help describe the limitations, if available.

9) Request for Relief RR-C3 - The licensee has proposed to conduct the Appendix J testing at the peak calculated containment pressure and will use procedures and techniques capable of detecting and locating through wallleakage in the containment isolation valves (CIV's) and the pipe segments between the CIV's.

. Appendix J, Option A Prescriptive Requirements, requires that three Type A tests be performed at approximately equal intervals during the 10 year ISI interval, with the third test being done while shutdown for the 10-year plant ISI. Option A also requires Type B and C tests be performed during each refueling outage, but in no case at intervals greater than 2 years. This is more frequent than the periodic pressure tests required by ASME Section XI.

Appendix J, Option B-Performance Based Requirements, allows a licensee to perform Type A, B, and C tests at frequencies related to the safety significance and historical performance of the system's isolation capabilities. This could, in effect, allow only one test to be performed during the .10-year ISI interval. However, the staff's position, as MAFT ATTACHMENT

L stated in Regulatory Guide 1.163 Performance-based Containment Leak-Test Program, '

is that the licensee is to establish test intervals of no greater than 60 months for Type C tests because of uncertainties (particularly unquantified leakage rates for test failures, l repetitive / common mode failures, and aging effects) in historical Type C cc.nponent l performance data. While this five-year limit results in an increased time between testing over that required by Section XI (forty months), it is believed that Appendix J tests are

, more appropriate and provide reasonable assurance of the continued operability of l containment penetrations. Therefore, the INEEL staff believes that the test frequencies l associated with Appendix J, Option A (Type A, B or C) or Option B (Type C) Tests are l commensurate with the Code-required pressure test frequencies.

The licensee has not stated the Option (A, or B), or the Type (A, B, or C) that will be l used at HCGS in conjunction with this Code Case. Provide the Appendix J Option, and l

Type of test that will be used. Additionally, provide information stating the examination frequencyif Option B is used.

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1 ATTACHMENT l

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