ML20235U602
| ML20235U602 | |
| Person / Time | |
|---|---|
| Site: | Seabrook, 05000000 |
| Issue date: | 06/17/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20235T530 | List:
|
| References | |
| FOIA-87-51 NUDOCS 8707220530 | |
| Download: ML20235U602 (13) | |
Text
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D-ATTACHMENT 2
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APPENDIX _
.s PUBLIC SERVICE CO. OF NEW HAMPSHIRE 5
SEABROOK NUCLEAR POWER STATION UNIT 1
.Q.Q DOCKET NUMBER 50-443 l
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SAFETY EVALUAT!0N REPORT SUPPLEMENT PRESERVICE INSPECTION REL!EF REQUEST EVALUAi!ON 1,
INTR 000CT!0N This section was prepared with the technical assistance of DOE contractors from the Idaho National Engineering Laboratory.
For nuclear power facilities whose construction permit was issued on or after July 1, 1974, 10 CFR 50.55a(g)(3)irements set forth inspecifies that compon l
shall meet the preservice examination requ editions and addenda of Section XI of the ASME Boiler and Pressure
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Vessel code applied to the construction of the particular component, f}
The provisions of 10 CFR 50.55a(g)(3) also state that < components (including supports) may meet the 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 i
I listed therein.
. N.
In a submittal dated May 28, 1986, the Applicant requested relief from ASME Code Section XI requirements which he has determined to be 4HHt-IM practical'. These relief requests were supported by information pursuant to 10 CFR 50.55afa)(3). Therefore, the staff evaluation consisted of reviewing th4s submittal to the requirements of the applicable Code edition and addenda and determining if relief from the Code requirements M
- justified.
A i
!!. TECHNICAL REVIEW CONSIDERATIONS A.
The construction permit for Seabrook Nuclear Power Station, Unit 1, was issued on July 7,1976.
In accordance with 10 CFR 50.55a( )(3), components (including. supports), which are classified as $ME Code Class 1 and 2, have been designed and provided with access to enable the performance of required-preservice examinations.
B.
Verification of as-built structural integrity of the primary pressure boundary is not dependent on the Section XI preservice examination. The applicable construction codes to which the primary pressure boundary was fabricated contain examination and testing requirements which by themselves provide the necessary assurance that ths pressure boundary components are capable of performing safely under all operating conditions reviewed in the FSAR and described in the plant design specification. As a part of these examinations, all of the primary pressure boundary full penetration welds were volumetrically examined (radiographer) and the system was subjected to hydrostatic pressure tests.
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C.
The intent of a preservice examination is to establish a reference or baseline prior to the initial operation of the facility. The results of subsequent inservice examination can than be compared with the original condition to determine whethers channes have occurred.
Iftheinserviceinspectionresultsshowf no change from the original condition, no action is required.
In i
the case where baseline data are not available, all flaws must be t6ated as new flaws and evaluated accordingly.
Section XI of tu ASME Code contains acceptance standards which may be used as the easts for evaluating the acceptability of such flaws.
4 D.
Other benefits of the preservice examination include providing r4dandant or alternative volumetric examination of the primary pres 4ure boundary using a test method different from that employed during the component fabrication.
Successful performance of the preservice examination also demonstrates that the welds so examined are capable of subsequent inservice examination using a similar test method.
In the case of Seabrook Nuclear Power Station Unit 1, a large portion of the preservice examination required by the ASME Code was performed. Failure to perform a 100% preservice examination of the welds (dantified below will not sientficantly affect the assurance of the initial structural integrity.
E.
In some instances where the required preservice examinations were not performed to the full extent specified by the applicable ASME Code, the staff may require that these examinations or supplemental examinations be conducted as a part of the inservice inspection program.
Requiring supplemental examinations to be performed at this time would result in hardships or unusual difficulties without a compensating increase in the level of quality or safety. The performance of supplemental examinations, such as surface examinations, in areas where volumetric examination is difficult will be more meaningful after a period of operation. Acceptable preoperational integrity has already been established by similar ASME Code Section !!! fabrication examinations.
In cases where parts of the required exam'3ation areas cannot be effectively examined because of a combina on of component design or current examination technique limitatia 1, the development of new or improved examination techniques will continue to
>e monitored. As improvements in these areas are achieved, the staff will require that these new techniques be made a part of the inservice examination requirements for the components or welds which received a limited preservice examination.
Several of the preservice inspection relief requesta involve limitations to the examination of the required volume of a specific weld. The inservice inspection (151) program is based on the examination of a representative sample of welds to detect
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generic service-induced degradat' ion.
In the event that the welds
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identified in the PSI relief requests are required to be examined j
assin, the possibility of augmented inservice inspection will be evaluated during review of the Applicant's initial 10-year ISI An augmented program may include increasing the extent program.
and/or frequency of examination of accessible welds.
gig. EVALUATION OF ret!EF REQUESTS The Applicant requested relief from specific preservice inspection requirements in a submittal dated May 28, 1986.
These relief requests were supported by information pursuant to 10 CFR 50.55a(s)(3). Based on the information submitted by the Applicant and the staff's review of the design, geometry, and materials of construction of the components, certain preservice inspection requirements of the ASME Boiler and Pressure Vessel Code,Section XI have been determined to be impractical to perform. The Applicant has demonstrated that either (1) the proposed c1ternative would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements of this section would result in hardships or unusual difficulties without a compensating increase in the level of quality and safety.
Thorsfore, pursuant to 10 CFR 50.55a(a)(3), conclusions that these preservice requirements are impractical are justified as follows.
Unless otherwise stated, references to the Code refer to the ASME Code,Section XI,1977 Edition including Addenda through Sumer 1978.
A.,
Relief Recuest PR-1. Examination Catecory B-A. Reactor Pressure Vessel 1 elds, and Examinatif# Catenory B-D. Reactor Pressure Vessel (ottle FJ11 Penetration Welds Code Requirement: Section XI, Table IWB-2500-1. Examination Category 5 A, Items Bl.11, 81.12, Bl.21, B1.22, and 81.30, and Examination Category B-D, Item B3.90 require a 100% volumetric examination of the RPV shell, head, shell-to flange, and norrie to-vessel welds.
C3de Relief Reauest:
Relief is requested from performing 100% of tse Code and/or Regulatory Guide 1.150-required volumetric examination on the 4 shell welds, 8 head welds,1 shell-to-flange weld and 8 nozzle-to-vessel welds (21 welds total) listed in Table 1 of Relief Request PR-1.
ReasonferRelief: Geometric configuration and permanent obstructions prohibit 100% volumetric examination of the Code-required volume of the subject welds.
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5taff Eva' uation: The staff has reviewed the 4.olfcant's May 28, 1986 submittal including the attached Table and Figures.
In the attached Table 1, the Applicant identified the individuel welds with respect to the percentage of the ASME Code Section XI required examination completed, the percentage of the Regulatory Guide 1.150 required examination completed, and provided a
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description of the obstructions'(ference, etc.) encountered.e., nor:1e ob geometry, control rod drive, inter
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during these examinations. The Figures, included in Relief Request PR-1 showed.the subject welds with respect to the obstructions encountered. The Applicant reported that all of the i
subject welds received the ASME Code Section !!! volumetric and surface examinations during fabrication as well as the construction hydrostatic test.
On the basis of this review, the staff has concluded that a significant percentage of the Code-required examination has been performed and that the reactor vessel would have to be redesigned in order to complete the remainder. Therefore, the staff concludes that the limited Section XI and Regulatory Guide 1.150 volumetric examinations in conjunction with the Section !!!
fabrication examinations and hydrostatic tests provide an acceptable level of preservice structural integrity and that compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
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Reliof Recuest PR 2. Pressurizer and Stoam Generator Welds.
3.
Exem nati on Catecory B-B. Pressuro Rota nine Welds in Vessels.
and Exam nation Ca';enory B-D. Fur Pene'; ration Welcs on Norzles in vessels Code Requirement:
Section XI, Table IW8 2500-1 Examination Category e-5, Items 52.11 and B2.40, and Examination Category 8 D, items 83.30, B3.40, and 83.50 all require a 100% volumetric examination for PSI.
Cide Relief Roauest:
Relief is requested from performing 100% of tie Code-requ' red volumetric examination on the 3 pressurizer j
circumferential shell-ta-head welds, 4 steam gaaerator tubesheet-to-head welds, 6 pressurizer norrie-tevessel welds, 1 pressurizer nozzle inside radius section, and 8 steam senerator nozzle-to vessel welds (22 items total) identified in Ta61e 1 of Relief Request PR-2.
Reason for. Relief: The Applicent reports that geometric configuratWn and permanent obstructions (i.e. vessel penetrations and steam generator supports) prohibit performance of a 1005 volumetric examination of each of the subject welds.
Staff Evolustion: The staff has reviewed the Applicant's
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submitta', inc' uding Table 1 identifying the items for which relief is being requested. This Table includes the component or weld identification, the Code Item Number, the examination angle and technique being used, the configuration of the item, and the percent of the Code-required volume that was completed. The staff notes that each item received at least 741 of the Code-required volumetric examination for PSI.
In addition, the i
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t Applicant t'eports that all of the subject welds received the ASME Code Section !!! volumetric and surface examination during fabrication as well as the construction hydrostatic test. The inservice system leakage tests will be performed per the Code Section XI requirements during each refueling outage.
On the basis of this review, the staff has concluded that a significant percentage of the Code-required examination has been perfomed and that these components would have to be redesigned in order to complete the remainder.
Therefore, the staff concludes that the limited section XI volumetric examinations and the Section !!! fabrication examinations, along with the j
hydrostatic test, provide an acceptable level of preservice 1
structural integrity and that compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
C.
Relief Re nuest' PR-3. Examination Cotocory B-J. Reactor Coolant Pume Discatraa Nortle-ta-Pinine We' ds (4 welds)
Code Requirement:
Section XI, Table 11tB-2500-1, Examination Category g-J Item No. 39.11 requires a 100% surface and volumetric examination for PSI on pressure retaining welds in Class 1 piping of 4 inch nominal pipe size and greater.
Code Relinf Renuest:
Relief is esquested from performing the Code-requ' red preservice volumetric examination on the 4 Reactor Coolant Pump discharge nozzle-to-piping welds listed in Table 1 i
of relief request PR-6.
Reason for Recuest:
Due to the construction configuration of these welds, i'; is not possible to verify complete coverage of the Code-required volume.
Each weld consists of a cast stainless steel pump casing ($A-351, CF8A) welded to a wrought stainless pipe f 5A-376, TP-304N).
In order to provide a satisfactory tranattien taper between the pump and piping, the pipe side was overlaid with weld material.
staff Evaluatios: The staff has reviewed the Applicant's May Eg,1986 sunnittal including the attached dimensional drawing of the pump to-pipe weld with the weld overlay.
During the April 15, 1986 seabrook plant site visit, the staff also had the opportunity to see the subject welds and discuss the difficulties of examination.
The Applicant reported that these welds were scanned using a 41' refracted longitudinal (RL) wave from both sides of the weld and that due to the taper of the pump nozzle the resulting angle in the material was sesentially O' relative to the 1.0. surface when usinn the 41' RL fixture on I
the pump side. This was confirmed dur ng the examination by the l
presence of a strong backwall signal. The Applicant also
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reported that the pipe side of each weld was scanned using a e
45' shear wave.
Due to the metallurgical structure of the
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weid overlay on the pipe and the effect this type of material
' typically has on shear waves combined with the existence of a wold materis1/ base satorial interface parallel to the I.D., the angle of the shear wave in the material and resultant coverage could not be determined.
Both sides of the welds were completely scanned wi,th.0* longitudinal beams.
In addition to the above, the subject welds received the ASME Code Section !!! volumetric and surface examinations during fabrication, as well as the construction hydrostatic test. The inservice system leakage tests will be performed per ths/ M BactionX}requirementsduringeachrefuelingoutage.
Based on the above review, the staff has concluded that the section !!! fabrication examinations, supplemented by the section XI surface examination and the limited Section XI volumstric examination, is equivalent to the required preservice examination and therefore provides an acceptable level of quality and safety.
The staff will continue to monitor the development of new or improved examination techniques. As improvements in these areas are achieved, the staff will require that these new techniques be made a part of the inservice examination requirements for the components or welds which received a limited preservice examination.
D.
Relinf Recuest PR-4. Examination Category B-J. Class 1 pressure ReSa' nine %ldn in pipine, and Examination Csteoory 5-F. Pressure Re3atnien i ss' milar Meta' We'da Code Recuiremen4:
Section X1, Table IWB-2500-1, Examination Category 5-J, 14em Nos. 89.11 and 89.31, and Examination Category B-F, Items No. 85.10 and 85.30 all require a 100% surface and volumetric examination for P5!.
Code Re'inf Roauest:
Relief is requested from performing the
~preserv' ce vo' umetric examination of the inaccessible portions of the it reactor coolant loop piping circumferential welds (Item No. 59.11), 9 branch connection welds in the reactor coolant loop piping (Item No. 89.31),1 reactor pressure vessel nozzle-to-safe end weld (Item No. B5.10), and 8 steam generator nottle to-safe and welds (! tem No. 85.30) listed in Table 1 of pt-4 (37 welds total).
Reason $r Recuest: Geometric configuration, permanent obstruct ons, and structural interferences prohibit 1005 of the Code-required volumutric examination on the subject welds.
Stcff Evolustion: The staff has reviewed the Applicant's submitta' of Relief Request PR-4, including the attached Table 1 which identifies the individual welds with respect to the percentage of the ASME Code section XI required volumetric
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examination completed and the examination technique being used.
(Ses Section 5.2.4.3 of this Supplement for a discussion of the ultrasonic examination techniques used for the examination of the statica11y cast stainless steel fittings.)
The Applicant also reports that complete examinations which met the requirements of ASME Section XI were performed on welds of similar configuration using the same inspection techniques, equipment, and procedures as those partially inspected or uninspected welds. Since tha partially inspected er uninspected welds will see the same operating and environmental conditions as the inspected welds, / reasonable assurance of the structural intecrity of the welds for which relief is requested has been attained. Also, all of the subject welds received the ASME Code Section !!! volumetric and surface examination during fabrication as well as the construction hydrostatic test.
Ested on the above review, the staff has concluded that the Section !!! fabrication examinations, supplemented by the Section XI surface examination and the limited section XI provides an acceptable level of volumetric examination preservice structural btegrity and that compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
E.
An11ef Raouest pR-5. Examination Chtegories B L-2 and B-M-2m C' ass 1 Peo Casinos and Velve Botf as code Requirement: Section XI, Table IWB-2500-1, Examination Categories B-L-2 and B-M-2, Item Nos. 812.20 and B12.40, requires i
a visual (VT-1) examination of valve bodies exceeding 4 inch nominal p4pe size (NPS) and of pump casings.
Code Re11of Roouest: For the reactor coolant pump casings and 33 injection, and residual heat removal pressurizer, safety Valys bod' es ' n the reactor coolaat systems, relief is requested from disassembly of an operable valve or pump to perform a preservice visual (VT-1) examination.
Reason for Relief: The Applicant reports the following: The requirement to disassemble an operable valve or pump oor the sole purpose of performing a visual examination of the internal pressure rotatning boundary is impractical and not commensurate i
to the increased assurance of safety achieved by the inspection.
Class 1 valves and pumps are installed in their respective systems and all active valves completed functional testing in accordance with ASME section XI Article IW. To disassemble i
these items would provide a very small potential for increasing i
plant safety margins with a disproportionate impact on 1
expenditures of plant manpower and resources. In addition, the Applicant has reported that the manufacturer's test data will be used is lieu of the preservice visual examination. This includes c-g fa,,',* D..y i
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documentation of examinations performed during fabrication and installation of the subject valves. The examinations performed may include volumetric, surface, and visual examinations, as required by. ASME Section !!, Material Specifications for Ferrous and Nonferrous Materials, and ASME Section !!!, Construction and Installation Requirements.
These valves and pumps have been found acceptable by the manufacturer, the ASME Authorized Nuclear Inspector, and New Hampshire Yankee's Quality Assurance.
l Staff Rynluation:
The staff has reviewed the Applicant's submitla', ine' uding Table 1 identifying the items for which 4
relief is being requested, and determined that disassembly of pumps and valves at this time, for the sole purpose of performing preservice visual examination using qualified personnal, would result in hardships or unusual difficulties without a compensating increase in the level of quality and safety. The staff has concluded that the construction code examinations and.
tests exceed the requirements for visual examination and, therefore, are an acceptable alternative to the section XI preservice visual examination.
F.
Relief Recuest PR-6. Examination Catonery C-A. Pressure Retainine We' ds < n P
- essure Vesse' s. and Examination Catenory C-B. Pressure Re aind na torr' e Welds d n vessels Code Recuiremen4:
Section XI, Table IWC-2500-1 Examination Category C-A, hems C1.10, C1.20, and C1.30 requires a 1005 volumetric examination on Class 2 pressure vessel welds.
Section XI, Table IWC-2500-1, Examination Cate' gory C-8, Item C2.20 requires a 1005 surface and volumetric examination on Class 2 nostles in vessels over 1/2 inch in nominal thickness.
Code Re'ief Rocuest: Relief is requested from performing the preserv' ce vo' umetric examination of the inaccessible portion of the 12 vessel shell circumferential welds, 2 vessel head circumferential welds,1 vessel tubenheet-to-shell weld, and 7 vessel nottle welds (22 welds total) listed in Table 1 of Relief Request PR-6. These welds are located in the Steam Generators and the Residual Heat Removal and Letdown Heat Exchangers.
Reason for Relief: Geometric configuration and permanent obstruct' one prohibit the performance of a 1005 volumetric examination of each of the subject welds.
Stafd Evnluation: The staff has reviewed the Applicant's submitta', including Table 1 identifying the items for which reltof is being requested. Thia Table includes the weld.
identification, the Code Item Number, the examination angle and technique being used, the configuration of the weld, and the percentage of the Code-required volumetric examination that was
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completed. The staff notes that on all welds, with exception of the outlet nozzle inner radius area, a significant portion of the Code-required volumetric examination was completed.'
In addition, the Applicant reports that all of the subject welds received the ASME Code section III volumetric and surface examination during fabrication as well as the construction hydrostatic test.
Based on the above, the staff has concluded that a significant percentage of the Code-required examination has been performed and that these components would have to be redesigned in order to complete the remainder.
Therefore, the staff concludes that the limited section XI volumetric examinations and the Section !!!
fabrication examinations, along with the hydrostatic test, provide an acceptable level of preservice structural integrity and that compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
4 G.
Reliof Renuest PR-7. Examination Catenory C-8. RHR Heat Exchanner Nott' s We' ds Code Requirement: Section XI Table IWC-2500-1, Examination Category C-B, Item No. C2.20 requires a 100% surface and volumetric examination on nozzles in vessels ever 1/2 inch in nominal thickness.
Code ge'inf Recuest:
Relief is requested from performing the preserytco ultrasonic examination of the nozzle-to-vesse ; welds on the tube side waterbox of the RHR Heat Exchanger (2 heat
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exchangers - I nozzles each).
Reason for Re' ief: Table IWC-2500-1 Examination Category C-B, requires a vo' umetric examination of nozzle welds in vessels whose thickness exceeds 1/2 inch nominal. The Applicant states that, in the case of the Seabrook RHR Heat Exchangers, the weld g40metries for the inlet and outlet nozzlea do not have a configuration which can be examined with ultrasonic techniques.
Therefore the preservice volumetric examination requirement will be fulfilled by the construction radiography and ultrasonic examination techniques will be developed such that maximum coverage will be achieved at the first refueling outage.
The Applicant reported that the subject welds received the ASME Code Section III volumetric and surface examinations during fabrication as well as the construction hydrostatic test.
Staff Evn1catd er : The staff has reviewed the Applicant's submitta' Lnc' uting Figure i showing the configuration of the RHR -
Heat Exchanger nozzle-to-ahell welds. The staff d= st ;= ha> C"CbdLd that these welds have a configuration which ----' "
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ith ultrasonic techniques. However, the ff considers the A$ME Code section !!! volumetric a_
ace examinations along
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with the construction hydrostatic test adequate to assure the preservice structural integrity, provided that the ultrasonic examinations are completed at the first refueling outage.
Compliance with the specific requirements of section XI, et this time, would result in hardships or unusual difficulties without a
'i compensating increase in the level of quality and safety.
H.
Relief ReaJest pR-8. Examination Catonery C-F. Pressure Retainina Welds in t ie Containment Eu' Edino 5 Dray Pininn code Reeviremen1:
Section XI, Table IWC-2500-1. Examination Category C-F. I"em No. C5.20 requires a 1005 surface and volumetric examination on Class 2 piping welds over 1/2 inch nominal wall thickness.
Code Relief Roouest: Relief is requested from performing the preservice vo'umetric and surface examinations on the Containment l
Building Spray Headers beyond the last downstream valve.
Reason for Relief:
1.
The subject lines are normally empty and are required to function only in the unlikely event of a major loss of coolant accident or a main steam line break.
2.
The subjset lines are not exposed to fluctuating stresses, so that propagation of cracks due to defects in the pipe is unlikely.
3.
Spray piping welds are examined by radiography during fabrication, so that large defects that could cause catastrophic failure dur ng system operation would be detected and repaired during fabrication and installation of the piping.
4.
This piping contains hundreds of open norrles so that splits or cracks which do not directly cause catastrophic failure would not have a marked effect on the function of the system.
5.
System pressure is low, so that pressure stresses in the piping would be unlikely to cause failure in the presence of small defects.
staff Evolt stion: The staff has reviewed the above information and conc' ut ed that this relief request is acceptable for PS!
based on ASME Nuclear Code Case N-408, " Alternative Rules for Examination of Class 2 Piping", which exempts CHR system piping of any size beyond the last shutoff valve in open ended portions of piping that do not contain water during normal plant operating conditions. In addition, the preservice structural integrity has been demonstrated by the ASME Code Section III volumetric examinations performed during fabrication.
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Relisf Renunst pR-9. Examination Catonery C-F. pressure Retaininn g,
Class 2 Pis' na and Pining Branch Connection Welds Code Reauiremen<;:
Section XI. Table IWC-2500-1, Examination Category C-Flc e;em Nos. C5.21 and C5.22 require a 100% surfacexa 0
and volumetr welds over 1/2 inch nominal wall thickness, Item No. C5.31 requing a 1005 surface examination on pressure retaining pipe branch connection welds.
C bde Relief Ren aest:
Relief is requested from performing 100% of tse preservice code-required volumetric examination on Item Nos.
C5.21 and C5.22 welds (2 welds) listed in Table 1 of Relief Request PR-9.
Relief it also requested from performing 1005 of the FSAR Augmented Examination comitment (volumetric examination) on the 7 branch connection welds (! tem No. C5.31) listed in Table 1 of Relief Roguest FR-9. The Applicant reports that the Code-required surface examination was completed on these welds.
Reason for Reauest: Geometric configuration, permanent obstructions and/or structural interferences, prohibit 100%
1 examination coverage of the Code-required volume on 2 welds and 100% examination coverage of the FSAR Augmented Examination volume on 7 welds listed in Table 1 of Relief Request PR-9.
Staff Evoltatd or: The staff has reviewed the Applicant's submitta
'nc'ucing Table 1 which identifies the welds for which reltsf is being requested, the Code Item Number, the examination angle and technique being used, the configuration of the weld, and the percentage of the Code or FSAR Augmented Examination required volume that was examined.
In addition, the Applicant reported that the subject welds received the ASME Code Section !!! volumetric examination during fabrication and the l
construction hydrostatic test.
Based on the above, the staff concludes that a significant i
percentage of the Code or FSAR Augmented Examination-required volumetric examination has been performed and that these I
components would have to be redesigned in order to complete the remainder. Therefore, the staff concludes that the limited preservice volumetric examinations and the Section !!!
fabrication examinations, along with the hydrostatic test, provide an acceptable level of preservice structural integrity and that compliance with the specifte requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
, '.h.
.IV. CONCLU5!0NS
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Sased on the foregoing, pursuant to 10 CFR 50.55a(a)(3), the staff has determined that certann section XI required preservice examinations
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are impractical. The Applicant has demonstrated that either (i) the proposed alternatives would provide an ecceptable level of quality and safety or (ii) compliance with the requirements would result in hardships or unusual difficulties without a compensating increase in j
the level of quality and safety.
The staff technical evaluation has not identified any practical method by which the existing loabrook Nuclear power Station, Unit 1 can meet i
all the specific preservice inspection requirements of Section XI of the ASME Code. Requiring compliance with all the exact section XI required inspections wou.d delay the startup of the plant in order to redesign a significant number of plant systems, obtain sufficient install the new components and repeat the replacement components, f these components.Examplesofcomponents preservice examination o that would require redesign to meet the specific preservice examination provisions are: the reactor pressure vessel, the reactor coolant pump discharge nozzle, and a number of the piping and component support systems.
Even after the redesign efforts, complete compliance with the preservice examination requirements probably could not be achieved. However, the as-built structural integrity *of the existing primary pressure boundary has already been established by the construction code fabrication examinations.
Based on the staff review and evaluation, it is concluded that the public interest is not served by imposing certain provisions of i
section XI of the ASME Code that have been determined to be impractical. Pursuant to 10 CFR 50.55a(a)(3), relief is allowed from these requirements which are impractical to implement.
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ATTACHMENT 3 SALP REPORT l
l Plant: Stabrook Unit I Licensee:
Public Service Company of Docket No.: 50-443 New Hampshire Reviewers:
G. Johnson, Sam Lee Licensing Activity:
PSI SSER EVALUATION CRITERIA RATING REMARKS 1.
Management Involvement NA and Control in Assuring i
Quality j
l 2.
Approach to Resolution 2
The applicant's submittals were I
to Technical Issues from well prepared and exhibited an l
a Safety Standpoint effort to comply with the j
regulations.
i 3.
Responsiveness to NRC 1
Responded in minimum time to Initiatives NRC initiatives.
4.
Enforcement History NA 5.
Reporting and Analysis NA of Reportable Events 6.
Staffing 2
The applicant's submittals indicated that staffing has been adequate.
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