ML20212M304
| ML20212M304 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 03/05/1987 |
| From: | Wagner D Office of Nuclear Reactor Regulation |
| To: | Corbin McNeil Public Service Enterprise Group |
| References | |
| NUDOCS 8703110355 | |
| Download: ML20212M304 (9) | |
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DIS W 80 TION:.
-Nocket No. 50-354.
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. Docket No. 50-354-MRC PDR 5
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BWO-3 r/f EAdensam Mf; Corbin A. McNelli, Jr.
DWagner LVice President - Nuclear EHy' ton
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Public' Service Electric & Gas Company,
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P.O. Box 236 Attorney,00t
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Dear Mr. McNeill:
EJordan ACRS (10)
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Subject:
' Hope Creek - Request for Additi6nal Infomation f
p In your letter dated October 10,'1986, ycu submitted for our,hsiew the Hops n
Creek Inservice Inspection Program for thy first 10-year inteivfl. Inservice Inspection Boundary Diagrams were submitterin your letter dated Cecember'11,
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1986.
'j-We and our consultants. Idaho National En31neering Labcratory, havn reviewed the available infomation in these submittals. Based on f1is review, the infomation/ clarification in the enclosed request for additional'information f
is required in order. to complete our review.c We request that this infomation
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be submitted no later than 60 days from the date of this letter.
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Please contact us if you have any questions concoming this request.
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Sincerely,'
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s David H. Esgner, Project Manager t-
,i BWR Project Diructorate No. 3 Division of BWR Ucensing
Enclosure:
9 As stated cc: 'See next page.
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- Pictard Fryling,i1r., Escuire P.O. Box 1401 Associate General Solicitor Dover, Delasare 19903 Public Service Electric'& Gas Company
- P.O. Box 570 'r5E Ms. Rebecca Green Fewark, New Jersey 07101' New Jersey Bureau of Radiation-Protection Pesident Inspecto'r 380 Scotch Road U.S. Nuclear Regulatory Commission Trenton, New Jersey 086?8 P.O. Fox Pal l
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F0PE CREEK GENERATING-STATION DOCKET NUMBER 50-354 l
i t-Request for Additional Information - First 10-Year Interval Inservice Insoection Program Plan i
- Scope / Status of Review Throughout the service life of a water-cooled nuclear power facility,.10 CFR -
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. 50.55a(g)(4) requires that components (including supports) which are classified as ASME Code Class"1,, Class 2, and_ Class 3 meet the requirements, except desian-
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. and access provisions and preservice examination requirements, set forth in ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Dower Plant Compon-ents," to the extent practical within the limitations.of design, geometry, and materials of construction'of the components. This section of the regulations also requires that inservice examinations of compon;nts and system pressure tests-conducted during the initial -120-month, inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorporated g
. by. reference in 10~CFR.50.55a(b) on the date 12 monthsjprior to the date of l'
issuance of the operating license, subject to the limitations and modifications
-listed therein. The components (including supports) may meet requirements set forth_in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed m
therein. Public Service Electric and Gas ~ Company has prepared the ISI Program-
' Plan to meet the requirements of the 1983 Edition, Summer 1983 Addenda (83S83) of the ASME code ~Section XI except that the extent and frequency of examination for Code Class 2 piping welds in Residual Heat Removal (RHR) Systems, Emergency Core Cooling (ECC) Systems, Containment Heat Removal (CHR) Systems, and Non-ECC Sys.tems has been determined by ASME_ Code Case N-408.
As required by 10 CFR 50.55a(g)(5), if PSEAG determines that certain code examin-ation requirements are impractic' l and relief is requested, PSE&G shall submit a
information to the NRC to support that determination.
3 The staff has reviewed the available information in the Hope Creek Generating Station First 10-Year Interval Inservice Inspection Program Plan, dated September 1986,'and the requests for relief from the ASME Code Section XI requirements which PSE8G has determined to be impractical.
Additional Information Required Based on this review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the Inservice U
Inspection Program Plan:
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. A.
Provide the staff with isometric and/or cogonent drawings showing the welds, components, and supports which are required to be examined by Section XI cf the ASME Code.
B.
Provide the staf f with a list of systems receiving ISI examination and define the acronyms used.
C.
Provide the staff with a list of specific exemptions applied to each system (by Code Class) being examined during the first 10-year interval inservice inspection.
D.
Provide line lists for each system including system identification, Code class, NPS and schedule, piping material specification, and maximum operating temperature and pressure.
E.
Provide examination tables, for each system, which give the details for performance of the examinations. The following is a list of typical information to be included in these tables:
1.
identification of system, preferably in system-by-system order; 2.
Code classification; 3.
Code examination category and item number; 4.
individual components and welds, supports and snubbers, or pumps and valves for examination; 5..
reference to drawings to aid locating the weld, component, support, snubber, pump, or valve; 6.
examination method; 7.
calibration blocks; 8.
procedure references; I
9.
schedules for examination; and 10.
reference to Code requirements that are not being satisfied by the examinations and identification of substitute examinations.
F.
Provide summary tables showing, for each system, the Code classification; Code examination category and item number; types of components examined; examination to be performed; and the total number of welds, components, or supports covered for each item number. Note that this information could be put in tables similar to Tables IWB-2500-1 or IWC-2500-1 and is intended to be a sumary of the information in the tables in item E above.
L. G.
Provide the staff with a reference list of NDE' examination procedures tc be
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used-for ISI including identifications, titles _and general descriptions of the components for.which each procedure is applicable.
H.
Provide the staff with a reference list of calibration blocks including identifications, material specifications, and sizes.-
I.. Discuss any auomented examinations that will be performed during the first 10-year inspection interval.
J.
In Section 1.2.3 of the ISI Prooram, PSE&G states:
In accordance'with Federal. Register 48FR5532, Article IWE. of ASME Section XI has not.been adopted by the NRC. PSE&G has not incorporated the requirements of Article IWE into Hope Creek Inservice Examination Program." As stated in 10 CFP Part 50, Appendix J, " Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors", one of the conditions of all operating licenses for water-cooled power reactors, as specified in 10 CFR 50.54(c),
is that primary reactor containments shall meet the containment leakage-test requirements set fcrth in Appendix J.
PSE8G should describe bow the requirements of Appendix J are being incorporated.
c K.
Relief cannot be granted as requested _in Relief Request I because it is a generic relief request. The regulations do not provide for granting generic relief requests. The staff notes that PSE&G has submitted the Hope Creek Generating Station, Unit 1, Preservice Examination Limitations Final Report as part of Relief Request 1.
The staff's relief request evaluations for the preservice inspection are often based on the fabrication examinations meeting the Code requirements and, therefore, may not be applicable for the first 10-year inservice inspection interval. The staff continues to monitor the development of new or improved examination techniques.-
As improvements in these areas are achieved, the staff will require that i
these techniques be incorporated in the next inspection interval ISI program plan examination requirements. PSE8G should separate Relief Request 1 into several relief requests, i.e. separated first by Examination Category and second by reason for requesting relief, and list the specific welds for I-which relief is being reques.ted for the first 10-year inspection interval.
PSE&G should provide a formal submittal of requests for relief including supporting technical justifications. Each request 'or relief should be a
" stand-alone" document (i.e. all of the supporting infonnation should be included as part of the relief request). When preparing requests for relief, the staff suggests that PSE8G follow the attached Appendix A " Inservice Inspection: Guidance for Preparing Requests for Relief from Certain Code Requirements Pursuant to 10 CFR 50.55a(g)(5)".
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1 APPENDIX A INSERVICE INSPECTION:
GUIDANCE FOR PREPARING REQUESTS FOR RELIEF FROM CERTAIN. CODE REQUIREMENTS PURSUANT TO 10 CFR 50.55a(g)(5)
A.
Description-of Requests for Relief-The guidance in this enclosure is intended to illustrate the type and extent of information that is necessary for " request for relief" of items that cannot be fully inspected to the requirements of Section XI of the ASME Code.
The inservice inspection program should identify the inspection and pressure testing requirements of the applicable portion of Section XI-that are deemed. impractical because of the limitation of design, geometry, radiation considerations or materials of construction of the components.
The request for relief should provide the information requested in the following section of this appendix for the inspections and pressure tests identified above.
B.
Request-for Relief From Certain Inspection and Testing Requirements Many requests for relief from testing requirements submitted by licensee's have not been supported by adequate descriptive and detailed technical
- information.
This detailed information is necessary to:
(1) document the impracticality of the ASME Code requirements within the limitations of design, geometry and materials of construction of components; and (2) determine whether the use of alternatives will provide an acceptable level of quality and safety.
Relief request submitted with a justification such as " impractical",
" inaccessible", or any other categorical basis, require additional information to permit an evaluation of that relief request.
The objective of the guidance provided in this section is to illustrate the extent of the information that is required to make a proper evaluation and to adequately document the basis for granting the relief in the Safety Evaluation Report.
Subsequent requests for additional information and delays in completing the review can be considerably reduced if this information is provided initially in the licensee's submittal.
For each relief request submitted, the following information should be included:
1.
State when the request for relief would apply during the inspection period or interval (i.e., whether the request is to defer an i
examination.)
2.
State the time period for which the requested relief is needed.
3.
An itemized list of the specific component (s) and the examination requirement for which relief is requested.
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The number of items associated with the requeste'd relief.
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The. ASME Code Class, Examination Category, and Item Number.
6.
An identification of the specific ASME Code requirement that has been determined to be impractical.
7.
The information to support the-determination thAt the' requirement is impractical; i.e., state and explain the basis for requesting relief.
If the Code required examination cannot be performed because of a limitation or obstruction, describe or provide drawings -
showing the specific limitation or obstruction, and provide an estimate of the percentage of the Code required examination that can be completed on the individual components requiring relief.
8.
An identification of the alternative examinations that are proposed:
(a) in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in compliance with the requirements of Section XI.
9.
State when the proposed alternative examinations will be implemented and performed.
- 10. A description and justification of any changes expected in the overall level of plant safety by perfoming the proposed alternative examination in lieu of the examination required by Section XI.
If it is not possible to perform alternate examinations, discuss the impact on the overall level of plant quality and safety.
Technical. justification or data must be submitted to support the relief request.
Opinions without substantiation that a change will not affect the quality level are unsatisfactory.
If the relief is requested for inaccessibility a detailed description or drawing which depicts the 1
inaccessibility must accompany the request. A relief request is not required for tests prescribed in Section XI that do not apply to your facility.
A statement of "N/A" (not applicable) or "none" will suffice.
C.
Request for Relief for Radiation Considerations Exposures of personnel to radiation to accomplish the examinations prescribed in Section XI of the ASME Code can be an important factor in determining whether, or under what conditions, an examination must be performed. A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently approved by the NRC staff.
Some of the radiation considerations will only be known at the time of the test.
However, from experience at operating facilities, the licensee generally is aware of those areas where relief will be necessary and should submit as a minimum, the following information with the request for relief:
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. 1.
The-total estimated man-rem exposure involved in the examination.
2.
The radiation levels at the test area.
3.
Flushing or shielding capabilities which might reduce radiation levels.
4.
A proposal for alternate inspection techniques.
5.
A discussion of the considerations involved in remote inspections.
6.
Similar welds in redundant systems or similar welds in the same systems which can be inspected.
7.
The results of preservice inspection and any inservice results for the welds for which the relief is being requested.
8.
A discussion of the failure consequences of the weld which would not receive the Code required examination.
l
TYPICAL RELIEF REQUEST I.
CLASS 1 COMPONENTS A.
Reactor Vessel' 1,
(Reli9t Request No.) Nozzle-to-Safe End Welds, Catecary B-F, Item B5.10 Code Requirement All nozzle-to-safe end butt welds in nominal pipe size 4 in, or greater in the reactor vessel shall be surface and volumetrically examined in accordance with Figure IWB-2500-8 during each inspection interval.
The examinations may be performed coincident with the vessel nozzle examinations required by Category B-D.
Dissimilar metal welds between combinations of (a) carbon or low alloy steels to high alloy steels, (b) carbon or low alloy steels to high nickel alloys, and (c) high alloy steel to high nickel alloys are included.
Code Relief Request Relief is requested from surface examinations of circumferential welds for the two core flood nozzle-to-safe end welds (Nos.01-025 and 01-026).
Proposed Alternative Examination Both core flood nozzle-to-safe end welds would be 100%
volumatrically examined coincident with the vessel nozzle examinations from the versal ID.
Licensee's Basis for Requestino Relief Access for a surface examination would require removal of the canal seal plate, shielding bricks, shielding supports in the nozzle areas, and insulation removal.
This would require approximately 300 manhours.of work in a 700-1000 mR/hr area.
.