ML20211B534

Forwards RAI Re 2nd 10-yr ISI Interval Relief Requests Re Plant.Info Requested to Be Provided within 60 Days of Receipt of Ltr

ML20211B534
Person / Time
Site:	Hope Creek
Issue date:	08/20/1999
From:	Richard Ennis NRC (Affiliation Not Assigned)
To:	Keiser H Public Service Enterprise Group
References
TAC-MA2026, NUDOCS 9908250026
Download: ML20211B534 (6)

Text

August 20, 1999 )

Mr. H::rold W. K:iser Chi f Nucinr Officer & Pr:sid:nt -

Nucirr Busin:ss Unit Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING SECOND 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUESTS FOR HOPE CREEK GENERATING STATION (TAC NO. MA2026)

Dear Mr. Keiser:

By lettu dated May 11,1998, you submitted the Hope Creek Generating Station inservice inspection program for the second 10-year interval, including requests for relief from the requirements of Section XI of the ASME Code. The NRC's contractor, Idaho National Engineering and Environmental Laboratory (INEEL), is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure. In order to expedite the review process, please send a copy of your response to INEEL, at the following address:

MichaelT. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 We request that the additionalinformation be provided within 60 days of receipt of this letter.

The 60-day response timeframe was discussed with Mr. Charles Manges of your staff on August 5,1999. If circumstances result in the need to revise your response date, or if you have any questions, please contact me at (301) 415-1420.

Sincerely, ORIGINAL SIGNED BY:

Richard B. Ennis, Project Manager, Section 2 9908250026 990820 Project Directorate I PDR ADOCK 05000354 Division of Licensing Project Management C PDR Office of Nuclear Reactor Regulation Docket No. 50-354

(

Enclosure:

Request for AdditionalInformation

} }

cc w/ encl: See next page DISTRIBUTION:

Docket File EAdensam (EGA1) OGC GMeyer, RGN-l PUBLIC JClifford ACRS PDI-2 Reading REnnis TMcLellan SBlack TCiark TSuiiivan N0056 3 e '

OFFICE PDI-2/PM PDI-2/LA d34CI)/SC PDI-2/SJD ,

NAME REnnis:ME TCla Ibhollivan JC r DATE I/II/99- $/T/99 [/ / 7 /99 [/M/99 ,

OFFICIAL RECORD COPY DOCUMENT NAME: G:\PDI-2\ Hope Creek \RAla2026.wpd

r: R l

p cts y t UNITED STATES g j NUCLEAR REGULATORY COMMISSION o WASHINGT,0N D.C. 2006M001

.  % # August 20, 1999 Mr. Harold W. Keiser l Chief Nuclear Officer & President -

Nuclear Business Unit Fubi;c Service Electric & Gas Company i Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING SECOND 10-YEAR  !

1NSERVICE INSPECTION INTERVAL RELIEF REQUESTS FOR HOPE CREEK GENERATING STATION (TAC NO. MA2026)

Dear Mr. Keiser:

i j

By letter dated May 11,1998, you submitted the Hope Creek Generating Station inservice .

Inspection program for the second 10-year interval, including requests for relief from the i requirements of Section XI of the ASME Code. The NRC's contractor, Idaho National Engineering and Environmental Laboratory (INEEL), is reviewing your submittal and has determined that additionalinformation is required to complete the review. The specific infortnation requested is addressed in the enclosure, in order to expedite the review process, please send a copy of your response to INEEL, at the following address: 1 MichaelT. Anderson l INEEL Research Center 2151 North Boulevard '

P.O. Box 1625 ldaho Falls, Idaho 83415-2209 We request that the additionalinformation be provided within 60 days of receipt of this letter.

The 60-day response timeframe was discussed with Mr. Charles Manges of your staff on August 5,1999. If circumstances result in the need to revise your response date, or if you have any questions, please contact me at (301) 415-1420. I Sincerely, d

Richard B. Ennis, Project Manager, Section 2 Project Directorate i Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

Request for AdditionalInformation oc w/ encl: See next page b

l. Hope Creek Generating Station

i. cc:-

l Jeffrie J. Keenan, Esquire Manager -Joint Generation Nuclear Business Unit - N21' Atlantic Energy P.O. Box 236 6801 Black Horse Pike nancocks Bridge, NJ 08038 Egg Harbor Twp., NJ 08234-4130 Hope Creek Resident Inspector Richard Hartung U.S. Nuclear Regulatory Commission Electric Service Evaluation Drawer 0509 Board of Regulatory Commissioners Hancocks Bridge, NJ 08038 2 Gatewa Center, Tenth Floor Mr. Louis Storz Sr. Vice President - Nuclear Operations Lower Alloways Creek Township Nuclear Department c/o Mary O. Henderson, Clerk P.O. Box 236 Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 General Manager - Hope Creek Operations Mr. Elbert Simpson Hope Creek Generating Station Senior Vice President-P.O. Box 236 Nuclear Engineering Hancocks Bridge, NJ 08038 Nuclear Department P.O. Box 236 Director - Licensing Regulation & Fuels Hancocks Bridge, NJ 08038 Nuclear Business Unit - N21 i P.O. Box 236 Hancocks Bridge, NJ 08038 -

Regional Administrator, Region i I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Dr. Jill Lipoti, Asst. Director Radiation Protection Programs NJ Department of Environmental Protection and Energy CN 415 Trenton, NJ 08625-0415 L.

p l'

REQUEST FOR ADDITIONAL INFORMATION SECOND 10-YEAR ISI INTERVAL RELIEF REQUESTS FOR I

HOPE CREEK GENERATING STATION 1 By letter dated May 11,1998, Public Service Electric and Gas Con pany (licensee or PSE&G) submitted the Hope Creek Generating Station (HCGS) inservice inspection (ISI) program for the second 10-year interval, including requests for relief from the requirements of Section XI of the American Society of Mechanical Engineers ASME Code. The NRC's contractor, Idaho National Engineering and Environmental Laboratory (INEEL) is reviewing 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 Rollef 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 LWD 2412(a) of the 1994 Addenda of ASME Section XI. Title 10 of the Code of Federal Reoulations, Section 50.55a(a)(3)(i) requires the applicant to demonstrate that the proposed alternative 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 alternative 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-5250(a)(2), concerning leakage at bolted connections.L The licensee has proposed to adopt the requirements of IWA-5250(a)(2) of the 1990 Addenda. The 1990 Addenda l requires that if leakage occurs at a bolted connection, one of the bolts shall be removed,~ i VT-3 examined, and evaluated in accordance with IWA-3100. When the removed bolt has evidence of degradation, all remaining bolting in the connection shall be removed, VT-3 examined, and evaluated in accordance with IWA-3100, lWA-3100 invokes the use of subparagraphs IWB-3000, lWC-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 lWB-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 conr,ection when leakage is detected. The evaluation should, at a minimum, considered the following factors: bolting materials, corrosiveness of process fluid L,

ENCLOSURE

f

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 botting materials.

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 identifies bolting degradation at a leaking bolted connection. Discuss the intended action regarding this request for relief.

3) Request for Relief RR-B1 - This request for relief is for multiple Class 1 welds of various code examination categories, lacluded are Code Category B-A, item B1.12 welds. Provide the staff with the status t:f the augmented reactor pressure vessel (RPV) examinations required by 10 CFR 50.55a(g)(6)(ii)(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 were 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 examined. Confirm that " essentially 100%" of each Examination Category B1.10 weld (RPV shell welds) have been examined, or that an attemative has been submitted for staff review pursuant to 10 CFR 50.55a(g)(6)(ii)(A)(5).

4) Request for Relief RR Code Case N-547, as written, has not been considered acceptable by the staff. However, authorization to use Code Case N-547 has been approved 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 visual inspection on any botting to be re-used.

The staff believes that when CRD botting 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 bo' ting 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 I any bolting to be re used.

5) : Request for Relief RR-C3 - The licensee has proposed to conduct the Appendix J testing at the peak calculatcd 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.

l l

t I

I i

. - p 3-9 Appendix J, Option A-Prescriptive Requirements, requires that three Type A tests be performed at approximately equal intervals during the 10-year ISI intental, with the third test being done while shut down for the 10-year plant ISI. Option A also requires Type i 3 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 4 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, repetitive / common mode failures, and aging effects) in historical Type C component performance data. While this 5-year limit results in an increased time between testing over that required by Section XI (40 months), it is believed that Appendix J tests are  !

more appropriate and provide reasonable assurance of the continued operability of containment penetrations. Therefore, the staff believes that the test frequencies 3 associated with Appendix J, Option A (Type A, B, or C)'or Option B (Type C) Tests are j commensurate with the Code-required pressure test frequencies, j The licensee has not stated the Option (A or B), or the Type (A, B, or C) that will be used at HCGS in conjunction with this Code Case. Provide the Appendix J Option and '

type of test that will be used. Additionally, provide information stating the examination frequency if Option B is used.

t LL.m.-