ML20237B470

Technical Evaluation Rept on First 10-Yr Interval Insp Program Plan:Pse&G,Hope Creek Generating Station,Docket 50-354, Informal Rept

ML20237B470
Person / Time
Site:	Hope Creek
Issue date:	11/30/1987
From:	Beth Brown, Mudlin J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20237B442	List: ML20237B440 ML20237B461 ML20237B470
References
CON-FIN-D-6022 EGG-SD-7829, NUDOCS 8712160287
Download: ML20237B470 (41)

Text

4 EGG-SD-7829 November 1987 P

INFORMAL REPORT 0

/daho National TECHNICAL EVALVATION REPORT ON THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

Engineering PUBLIC SERVICE ELECTRIC & GAS COMPANY, Laboratory HOPE CREEK GENERATING STATION, DOCXET NUMBER 50-354 Managed by the U.S. B. W. Brown Depanment J. D. Mudlin ofEnergy I

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i TECHNICAL EVALUATION REPORT ON THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

PUBLIC SERVICE ELECTRIC & GAS COMPANY, .

HOPE CREEK GENERATING STATION, l

DOCKET NUMBER 50-354 4 I

'B. W. Brown J. D. Mudlin Published November 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 i

Prepared for: l U.S. Nuclear Regulatory Comission Washington, D.C. 20555 under DOE Contract No. DE-AC07-76IDOI570 FIN No. D6022 (Project 5) l lI _ _

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ABSTRACT This report presents the results of the evaluation of the Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0, dated June 1987, including the requests' for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical. The Hope Creek Generating Station Inservice i .

Inspection Program, Long Term Plan, First 10-Year Interval, is evaluated in Section 2 of this report. The Inservice Inspection (ISI) Program Plan is evaluated for (a) compliance with the appropriate edition / addenda of i Section XI, (b) acceptability of examination sample, (c) exclusion criteria,.

and (d) compliance with ISI-related commitments identified during the Nuclear Regulatory Commission (NRC) review before granting an Operating I

License. The requests for relief from the ASME Code requirements which the l

Licensee has determined to be impractical for the first 10-year inspection interval are evaluated in Section 3 of this report.

l l-1 This work was funded under:

U.S. Nuclear Regulatory Commission FIN No. D6022, Project 5 Operating Reactor Licensing Issues Program, Review of ISI for ASME Code Class 1, 2, and 3 Components l

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, SUMMARf The Licensee, Public Service Electric & Gas Company, has prepared the Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0, dated June 1987, to meet the requirements of the 1983 Edition, Summer 1983 Addenda (83S83) of the ASME Code Section XI except that, in lieu of the requirements in 10 CFR 50.55a(b)(2)(iv)(A), the Licensee has incorporated the requirements of ASME Code Case N-408 for

. Class 2 piping welds in Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems. This Code Case has been approved by the Nuclear Regulatory Commission (NRC) as referenced in Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability, ASME Section XI Division 1." The first 10-year interval commenced on the date of commercial operation, December 20, 1986, and ends December 19, 1996.

The information in the Hope Creek Generating Station Inservice Examination Program Submittal, First 10-Year Interval, dated September 1986, was reviewed, including the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical This document described the basis for the Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval. As a result of this review, a Request for Additional Information (RAI) was prepared requesting the complete plan and describing the information and/or j

clarification required from the Licensee in order to complete the review.  !

_ Based on the review of the Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0, j including revised relief requests, submitted as part of the Licensee's l'

response to the NRC's RAI, and the recommendations for granting relief from the ISI examination requirements that have been determined to be impractical, it is concluded that the Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0, is acceptable and in compliance with 10 CFR 50.55a(g)(4).

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CONTENTS ABSTRACT................................................................. 11-

SUMMARY

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INTRODUCTION.......................................................... 1

2. EVALUATION OF INSERVICE' INSPECTION PROGRAM PLAN....................... 4 4 2.1 Documents Evaluated................................................ 4 2.2 Compliance with Code Requirements.................................. 4 2.2.1 Compli ance wi th Appl icabl e Code Edi tions. . . . . . . . . . . . . . . . . . . . . . . 4 2.2.2 Acceptability of the Examination Sample. . . . . . . . . . . . . . . . . . . . . . . . 5 2.2.3 Exclusion Criteria............................................. 5 -

2.2.4 Augmented Examination Commitments.............................. 5 2.3 Conclusions........................................................ 8

3. EVALUATION OF RELIEF REQUESTS......................................... 9

, 3.1 Cl a s s 1 C omp on en t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 i

3.1.1 Reactor Pressure Vessel........................................ 9 3.1.1.1 Request for Relief, Examination Category B-A, Item B1.30, Shell-to-Flange Weld, and Item Bl.40 i He a d - t o - Fl a ng e We l d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . 9

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3.1.1.2 Request for Relief, Examination Cate cry B-A, .

Item B1.11, RPV Circumferential Shel Welds, and - -

Item Bl.12, RPV Longitudinal Shell Welds.................. 10

.l 3.1.1.3 Request for Relief, Examination Category B-A, Item Bl.21, RPV Circumferential Head Welds, and Item Bl .22, RPV Meridional Head Welds . . . . . . . . . . . . . . . . . . . . . 12 3.1.1.4 Request for Relief, Examination Category B-D, Item B3.90, RPV Nozzle-to-Vessel Welds. . . . . . . . . . . . . . . . . . . . 14 3.1.1.5 Request for Relief, Examination Category B-D, Item B3.100, RPV Nozzle Inside Radius Sections............ 16 3.1.1.6 Request for Relief. Examination Category B-G-1, Item B6.40, RPV Fl ange Ligaments . . . . . . . . . . . . . . . . . . . . . . . . . . 18 3.1.1.7 Request for Relief, Examination Category B-H, Item B8.10, RPV Stabilizer Bracket Welds.................. 19

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/ 3.1.2 Pressurizer (Does not apply to BWRs) 3.1.3 Heat Exchangers and Steam Generators (No relief requests) 3.1.4 Piping Pressure Boundary...................................... 20 3.1.4.1 Request for Relief, Examination Category B-J, Item B9.ll, Pressure Retaining Circumferential Welds in Class 1 Piping Systems........................... 20 3.1.4.2 Request for Relief, Examination Category B-J, Item B9.31, Pressure Retaining Branch Connection Welds in Cl ass 1 Pi ping Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 3.1.4.3 Request for Relief, Examination Category B-K-1, Item 810.10, Integrally Welded Attachments to Cl as s 1 Pi pi ng Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 3.1.5 Pump Pressure Boundary (No relief requests) 3.1.6 Valve Pressure Boundary (No relief requests)

. 3.1.7 General (No relief requests) 3.2 Cl a s s 2 C omp o n e n t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 5 3.2.1 Pressure Vessels.............................................. 25 3.2.1.1 Request for Relief, Examination Category C-8, l Item C2.22, Nozzle Inside Radius Section on the RHR Heat Exchanger.................................... 25 3.2.2 Piping (No relief requests) 3.2.3 Pumps......................................................... 26

_ 3.2.3.1 Request for Relief, Examination Category C-G, i Item C6.10, Pressure Retainin Class 2 Pump Casing We1ds.................g............................. 26 3.2.4 Valves (No relief requests)  ;

3.2.5 General (No relief requests)  !

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3.3 Class 3 Components (No relief requests) 3.4 Pressure Tests (No relief requests) l 3.5 General........................................................... 28 3.5.1 Ultrasonic Examination Techniques (No relief requests) i i.

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t 3.5.2' Exempted Components (No relief requests) l 3.5.3 0ther......................................................... 28 3.5.3.1 Request for Relief, Examination Category F-C, Inservice Visual Examinations of Mechanical

! and Hydraul i c Snubbers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 '

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CONCLUSION........................................................... 30 5.

REFERENCES........................................................... 32

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TECHNICAL EVALUATION REPORT ON THE l

FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

! PUBLIC SERVICE ELECTRIC & GAS COMPANY, HOPE CREEK GENERATING STATION, l DOCKET NUMBER 50-354

1. INTRODUCTION Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) (Reference 1) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 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," (Reference 2) 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 components 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 by reference in 10 CFR 50.55a(b) on the date 12 months prior to the date of 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

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10 CFR 50.55a(b) subject to the limitations and modifications listed therein. The Licensee, Public Service Electric & Gas Company, has prepared the Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0 (Reference 3), to meet the requirements of the 1983 Edition, Summer 1983 Addenda (83S83) of the ASME Code Section XI except that, in lieu of the requirements in 10 CFR 50.55a(b)(2)(iv)(A), the Licensee has incorporated the requirements of ASME Code Case N-408 for Class 2 piping welds in Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems. This Code Case has been approved by the Nuclear Regulatory Commission (NRC) as referenced in Regulatory Guide 1.147, " Inservice 1

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Inspection Code Case Acceptability, ASME Section XI Division 1" (Reference 4). The first 10-year interval comenced on the date of comercial operation, December 20, 1986, and ends December 19, 1996.

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief from them, the licensee shall submit information and justifications to the Nuclear Regulatory Comission (NRC) to support that determination.

Pursuant to 10 CFR 50.55a(g)(6), the NRC will evaluate the licensee's determinations under 10 CFR 50.55a(g)(5) that Code requirements are

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impractical. The NRC may grant relief and may impose alternative I requirements that it determines are authorized by law, will not endanger life or property or the comon defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

As a result of review of the information in the Hope Creek Generating Station Inservice Examination Program Submittal, First 10-Year Interval, '

dated September 1986 (Reference 5), the NRC requested additional information that was required in order to complete the review of the ISI Program Plan in a letter dated March 5,1987 (Reference 6). The requested information was provided by the Licensee in the " Inservice Inspection Program - Reply to NRC Request for Additional Information" dated June 29,1987(Reference 7). In this response, the Licensee submitted the Hope Creek Generating Station .

Inservice Inspection Program, Long Term Plan, First 10-Year Interval, '

Revision 0, dated June 1987.

The'information in the Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0, dated June 1987, was reviewed, including the requests for relief from the ASME Code Section XI requirements which the Licensee has detemined to be impractical. Review was also completed on a letter from the Licensee dated July 31,1987 (Reference 8) regarding supplemental infonnation for the Long Term Plan, Revision 0. The review of the ISI Program Plan was performed using the Standard Review Plans of NUREG-0800 (Reference 9), Section 5.2.4, 2

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" Reactor Coolant Boundary Inservice Inspections and Testing," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components."

As a result of a telephone conversation with the Licensee on August 25, 1987, in a letter dated September 17,1987 (Reference 10), the Licensee: Provided clarification on augmented examination requirements; provided additional information with regards to the ISI examination of the Reactor Pressure Vessel (RPV) flange ligament area; stated that the Reactor Core Isolation Cooling System (RCIC) does not serve an ECCS function; and comitted to perform volumetric examinations on the Scram Discharge Volume Header (SDVH) per the recommendations of NUREG-0803 (Reference 11).

The Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval is evaluated in Section 2 of this report. The ISI Program Plan is evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability of examination sample, (c) exclusion criteria, and (d) compliance with ISI-related comitments identified during the NRC's review before granting an Operating License.

The requests for relief are evaluated in Section 3 of this report. Unless otherwise stated, references tt, the Code refer to the ASME Code,Section XI, 1983 Edition including Addenda through Sumer 1983. Specific inservice test (IST) programs for pumps and valves are being evaluated in other reports. i e

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2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN 1 i

This evaluation consisted of a review of the applicable program documents to determine whether or not they are in compliance with the Code requirements j

and any license conditions pertinent to ISI activities. This section '

describes the submittals reviewed and the results of the review.

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) 2.1 Documents Evaluated Review has been completed on the following information from the Licensee:

(a) Summary report, " Hope Creek Generating Station Inservice Examination 3

Program Submittal, First 10-Year Interval," dated September 1986; l

(b) Licensee's " Reply to NRC Request for Additional Information" with regard to Hope Creek Generating Station ISI Program, dated

! June 29, 1987; (c) " Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval," Revision 0, dated June 1987; (d) Letter, dated July 31, 1987, containing supplemental information for the " Hope Creek Generating Station ISI Program, Long Term Plan, First 10-Year Interval," Revision 0; and

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(e) Letter, dated September 17, 1987, containing clarification on items '

discussed during a telephone conference call on August 25, 1987, 2.2 Como11ance with Code Requirements 2.2.1 Comoliance with Aeolicable Code Editions The Inservice Inspection Program Plan shall be based on the Code editions defined in 10 CFR 50.55a(g)(4) and 10 CFR 50.55a(b). Based on the l operating license date of April 11, 1986, the Code applicable to the first interval ISI program is the 1980 Edition with Addenda through 4

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Winter 1981. However, as permitted by 10 CFR 50.55a(g)(4)(iv), the Licensee has opted to upgrade the program to the 1983 Edition through'the Summer 1983 Addenda, except that, in lieu of the requirements in 10 CFR 50.55a(b)(2)(iv)(A), the Licensee has incorporated the requirements of ASME Code Case N-408 for Class 2 piping welds in the RHR, ECC, and CHR systems. This Code Case has been approved by the NRC as referenced in Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1."

2.2.2 Acceptability of the Examination Samole Inservice volumetric, surface, and visual examinations shall be performed on ASME' Code Class 1, 2, and 3 components and their. supports using sampling schedules described in Section XI of the ASME Code and 10 CFR 50.55a(b). With the addition of the welds in the SDVH, per the commitment in the September 17, 1987 submittal, the sample size and weld selection have been implemented in accordance with the Regulations and tis Code and appear to be correct.

2.2.3 Exclusion Criteria The criteria used to exclude components from examination shall be consistent with Paragraphs IWB-1220, IWC-1220, and IWD-1220, and 10 CFR 50.55a(b). The exclusion criteria have been applied by the Licensee in accordance with the Code as discussed in Sections 2.1.1, -

2.2.1, and 2.3.1, "ASME Code Exemptions", of the Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0, and appear to be correct.

2.2.4 Auomented Examination Commitments The Licensee has stated in the ISI Program Plan that the following augmented examinations are being implemented during the first 10-year inspection interval:

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, (a) Inservice examinations will be performed in accordance with Regulatory Guide 1.150, " Ultrasonic Testing of Reactor Vessel Welds during Preservice and Inservice Examinations," Revision 1, (Reference 12),AlternateMethod.

i l (b) Feedwater Check Valve: To meet the requirements of General Design l'

Criteria 51, the Licensee has committed to perform augmented surface examinations on two 24-inch check valves (1-AE-HV-F074A and F0748).

These examinations will include inspection of both the internal and external surfaces. Additionally, the accessible valve body internal and external pressure retaining surfaces will be visually examined for evidence of surface cracks whenever these valves are disassembled for corrective maintenance.

(c) Augmented examinations will be performed in accordance with NUREG-0619 "BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking" (Reference 13). The Licensee will perform an ultrasonic examination of all feedwater nozzle safe ends, bores, and inside blend radii by the end of the second refueling outage and every second refueling cycle thereafter. Visual inspection of the sparger flow holes and welds in the sparger anns and sparger tees will be performed every four refueling cycles. Liquid penetrant examinations will be performed on the inside surfaces of one nozzle following removal and grinding of the sparger, and on the accessible ,

_ portions of the remaining nozzles once every nine refueling cycles or

• once every 135 startup/ shutdown cycles, whichever occurs first.

(d) The Scram Discharge Volume Header piping will receive volumetric examinations per the recommendations of NUREG-0803, " Generic Safety Evaluation Report Regarding Integrity of BWR Scram System Piping" (Reference 11). In the Licensee's letter dated September 17, 1987, the Licensee committed to perfonn augmented volumetric and surface examinations on 12 Class 2 welds on the Scram Discharge Volume Headers.

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4 (e) The Licensee has committed to an augmented examination of 10% of the selected critical welds in the Class 3 Main Steam System Lines and Cross-over piping.

(f) As a result of NRC Inspection and Enforcement Bulletin 80-13 (Reference 14), the Core Spray sparger will receive a visual (VT-1) examination when the Reactor Pressure Vessel (RPV) internal surface examinations are performed at the first refueling outage and approximately every 3 years thereafter.

(g) Visual (VT-1) examinations will be performed on the jet pump sensing lines when the RPV internal surface examinations are performed at the l first refueling outage and approximately every 3 years thereafter.

(h) Visual (VT-1) examinations will be performed on the steam dryer support brackets when the RPV internal surface examinations are performed at the first refueling outage and approximately every 3 years thereafter.

(i) Due to a negative slope on the RCIC turbine steam supply line, baseline thickness measurements were taken on selected pipe elbows.

These ultrasonic thickness measurements will be repeated after ten years of operation.

The Licensee has complied with the requirements of NUREG-0313, " Technical '

Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping" (Reference 15), prior to licensing, by reduction of austenitic piping where possible, application of solution heat treating and corrosion resistant cladding mitigation techniques, and the use of "L" grade austenitic materials. Therefore, the Licensee reports that an augmented examination program to NUREG-0313 is not applicable.

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2.3 Conclusions Based on the review of the documents listed above, it is concluded that the

-Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0, is acceptable and in compliance with h 10 CFR 50.55a(g)(4).

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3. EVALUATION OF RELIEF REQUESTS The requests for relief from the ASME Code requirements which the Licensee has determined to be impractical for the first 10-year inspection interval

- are evaluated in the following sections.

3.1 Class 1 Components i

3.1.1 Reactor Pressure Vessel 3.1.1.1 Reauest for Relief. Examination Cateaory B-A. Item Bl .30.

Shell-to-Flance Weld. and Item B1.40. Head-to-Flance Weld '

Code Requirement: Section XI, Table IWB-2500-1, Examination

, Category B-A, Item B1.30 requires 100% volumetric examination of the Reactor Pressure Vessel (RPV) shell-to-flange weld as defined by Figure IWB-2500-4. Item Bl.40 requires both 100%

volumetric and surface examinations of the RPV head-to-flange weld as defined by Figure IWB-2500-5.

Licensee's Code Relief Recuest: Relief is requested from examining 100% of the Code-required volume of shell-to-flange weld RPVI-W3 and closure head-to-flange weld _RPVl-W20.

Licensee's Prooosed Alternative Examination: None. The Code-required volumetric examination will be performed to the maximum extent practical.

Licensee's Basis for Reauestina Relief: Shell-to-Flange Weld:

l The flange configuration prohibits scanning from the flange l side of the weld. Thermocouple pads limit scanning from the shell side of the weld in two regions. The Licensee reports I that approximately 97% of the weld length is accessible for r

scanning, and that approximately 92% of the Code-required volume will be examined with at least one angle-beam component.

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Head-to-Flange Weld: The flange configuration prohibits j scanning from the flange side of the weld. The Licensee I reports that 100% of the weld length is accessible for scanning, and that approximately 88% of the Code-required 1

volume will be examined with at least one angle-beam component.

1 Evaluation: The Licensee's submittal has been reviewed, o

including the figures showing the weld design with the limitations to examination and the tables estimating the examination volume coverage. Based on the vessel design, a  ;

significant percentage of the Code-required examination will be l performed. The Reactor Pressure Vessel would have to be l I

redesigned and prefabricated in order to complete the remainder.

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examination of the subject welds, along with the Code-required pressure test, ensures an acceptable level of inservice structural integrity l 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. Therefore, it is recommended that relief be granted as requested.

3.1.1.2 Recuest for Relief. Examination Cateaory B-A. Item 81.11. RPV Circumferential Shell Welds, and item B1.12. RPV Longitudinal Shell Welds Code Requirement: Section XI, Table IWB-2500-1, Examination Category B A, Items 81.11 and Bl.12 require a 100% volumetric examination of the RPV circumferential and longitudinal snell welds as defined by Figures IWB-2500-1 and IWB-2500-2, respectively.

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Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume of the following RPV  !

welds: l Circumferential Shell Welds )

Weld No.  % lenath Accessible % Coveraae '

RPVl-W4 90% 93%

RPVI-WS 62% 53%

RPVI-W6 43% 53%

RPVI-W7 100% 98%

RPV1-W8 87% 91%

Longitudinal Shell Welds Weld No.  % lenath Accessible % Coveraae RPVI-Wil-1 100% 98% >

RPVI-Wil-2 100% 98%

RPVI-Wil-3 100% 98%

RPVI-W12 100% 98%

RPV1-W12-2 96% 97%

RPVI-W12-3 100% 98%

RPVI-W13-1 100% 79%

' RPVI-W13-2 68% 64%

RPVI-W13-3 100% 98%

RPVI-W14-1 100% 98% <

RPVI-W14-2 100% 98%

RPVI-W14-3 96% 94%

RPVI-W15-1 93% 81%

RPVI-W15-2 100% 98%

RPVI-W15-3 100% 98%

Licensee's Prooosed Alternative Examination: None. The Code-required volumetric examination will be performed to the maximum extent practical.

Licensee's Basis for Reauestina Relief: The design of the RPV includes nozzles, welded insulation pads, support skirt attachments, and other geometric constraints that prevent a 100% ultrasonic examination of the subject RPV Welds.

. i In response to Regulatory Guide 1.150, the Licensee has stated that there is a 2% volumetric limitation as a result of  !.

interface noise at the sound beam entry at the outside vessel surface. For eleven of the twenty subject welds this is the only examination limitation.

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, Evaluation: The Licensee's submittal has been reviewed, including the roll-out drawing of the RPV :;howing the location  !

of the nozzles'and other restrictions with respect.to the subject welds and the table with the estimated volume coverage for.each examination angle. Based on the vessel. design, a l significant' percentage of the Code-required volumetric examination will be performed. The Reactor Pressure Vessel would have to be redesigned and prefabricated in order to l complete the remainder.

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Conclusions:

Based on the above evaluation, it is concluded i that the limited Section XI volumetric examination of the subject welds, along with the Code-required pressure test, ensures an acceptable level of inservice 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. Therefore, it is recommended tha't relief be granted as requested.

3.1.1.3 Reauest for Relief. Examination Cateaory B-A. Item Bl.21. RPV Circumferential Head Welds. and Item Bl.22. RPV Meridional Head  ;

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Code Requirement: Section XI, Table IWB-2500-1, Examination Category B-A, Items B1.21 and 81.22 require a 100% volumetric examination of the RPV circumferential and meridional head welds as defined by Figure IWB-2500-3.

Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume of the following RPV head welds:

Lower Head Dome Circumferential Weld Weld No.  % Lenath Accessible  % Coveraae RPV1-W9 100% 98%

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. Lower Head. Meridional Weld's Weld No.  % lenath Accessible % Coveraae i RPVI-W16-1 82% 65% '

RPVI-W16 82%- 64%

RPVI-W16-3 82%- 65%

RPVI-W16-4 82% 65%

RPVI W16-5: 82% 66%

RPVl-W16-6 82% 66%

RPVI-W16-7 '82%' 66%

RPVI-W16 82% 66%

Closure Head Dome Circumferential Weld- I Weld No;  % Lenath Accessible. % Coveraae '

RPVI-W22 100% 98%

Lower Head Merid' ional Welds-Weld No.  % Lenath Accessible  % Coverace-RPVl-24A 100% 98%.  !

RPVI-248 100% 98%

• RPVI-24C 100% 98% i l

RPVI-24D -100% 98%

RPVI-24E 100% 98%

, RPVI-24F 100% 98%

RPVI-24G 100% 98%

RPVI-24H 100% 98%

Licensee's Prooosed Alternative Examination: None. The Code-required volumetric examination will be performed to the maximum extent practical.

Licensee's Basis for Reauestino Relief: The design of the RPV lower head support skirt attachment limits scanning in one location on each of the lower head meridional welds and the +

proximity of the control rod drive mechanisms limits scanning from below the lower head dome circumferential weld but does not significantly impact coverage.

The only restriction for the eight closure head meridional welds and the dome circumferential weld is the 2% volumetric limitation, with regards to Regulatory Guide 1.150, as a result of interface noise at the sound beam entry at the outside l surface of the vessel head.

l i

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13 I 1

I I

e l

l

, Evaluation: The Licensee's submittal has been reviewed, including the roll-out drawing of the RPV lower head showing the location of the support skirt with respect to the subject welds and the table with the estimated volume coverage for each examination' angle. Based on the vessel design, a significant percentage of the Code-required volumetric examination will be performed. The Reactor Pressure Vessel would have to be redesigned and prefabricated in order to complete the remainder.

Conclusions:

Based on the above evaluation, it is concluded that.the limited Section XI volumetric examination of the subject welds, along with the Code-required pressure test, ensures an acceptable level of inservice 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. Therefore, it is recommended that relief be granted as.

requested.

3.1.1.4 Reauest for Relief. Examination Cateaory B-D. Item B3.90. RPV Nozzle-to-Vessel Welds l Code Raouirement: Section XI, Table IWB-2500-1, Examination .

, Category B-D, Item B3.90 requires a 100% volumetric examination '

of the RPV nozzle-to-vessel welds as defined by Figure IWB-2500-7.

Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required volume of the following RPV nozzle-to-vessel welds (34 total):

RPV Nozzle-to-Vessel Welds Nozzle-  % Lenath Accessible % Coveraae RPVI-NIA 97% 89%  !

RPVI-NIB 90% 82%

RPV1-N2A 100% 91%

14

l (continued)

RPV Nozzle-to-Vessel Welds Nozzle  % lenath Accessible  % Comolete RPVI-N2B 100% 91%

RPVI-N2C 100% 79%

RPVI N20' 100% 79%

RPVI-N2E 100% 91%

RPVI-N2F 100% 91%

RPVI-N2G 100% 91%

1' RPVI-N2H 100% 79%

l RPVI-N2J 100% 79% l RPVI-N2K 100% 91%

RPVl-N3A 100% 84% t l

l RPVI-N38- 100% 84%

RPVI-N3C- 100% 84%

! RPV1-N3D 100% 84%

RPVI-N4A 100% 83%

RPV1-N48 86% 71%

-RPVI-N4C 79% 66%

RPVI-N4D 86% 71%

'RPVI-N4E 100% 83%  ;

RPVI-N4F 79% 66% '

l , RPVI-NSA 100% 86%

RPV1-NSB L 100% 86%

RPVI-N6A 100% 90%

RPVI-N6B 100% 90%

RPVI-N7 100% 93%

RPV1-N8A 100% 92%

i RPVI-N8B 100% 92%

! RPVI-N9 100% 92%

RPVI-N17A 100% 89%

RPVI-N178 100% 89%

l RPVI-N17C 100% 89%

RPV1 N170 100% 89% .-

Licensee's Prooosed Alternative Examination: None. The -

Code-required volumetric examination will be performed to the maximum extent practical.

Licensee's Basis for Reauestina Relief: The Licensee reports

, that the design configuration of the subject RPV nozzles and/or other geometric constraints (i.e. welded insulation pads, bioshield door sliding rail assemblies, proximity of adjacent nozzles, thermocouple brackets, etc.) limit effective examination of the full Code-required volume.

15

__- _ _ = _ _ _ _ - -

In response to Regulatory Guide 1.150, the Licensee states that there is also a 2% volumetric limitation as a result of interface noise at the sound beam entry at the outside vessel surface.

Evaluation: The Licensee's submittal has been reviewed, including figures showing the configurations of the subject l nozzles with respect to the limitations to examination and the table with the estimated volume coverage for each examination angle for each of the subject welds. Based on the nozzle and/or vessel design, a significant percentage'of the Code-required volumetric examination will be performed. The components would have to be redesigned and prefabricated in -

, order to complete the remainder.

Conclusions:

Based on the above evaluation, it is concluded that' the limited Section XI volumetric examination of the subject welds, along with the Code-required pressure test, ensures an acceptable level of inservice 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. Therefore, it is recommended that relief be granted as requested. -

I 3.1.1.5 Reauest for Relief. Examination Cateaory B-D. Item B3.100. RPV

)

Nozzle Inside Radius Sections j

~

Code Requirement: Section XI, Table IWB-2500-1, Examination Category 8-0, Item B3.100 requires-a 100% volumetric examination of the RPV nozzle inside radius sections as defined by Figure IWB-2500-7.

16

~

I i__1__________ _r l_ _ ___o - )

Licensee's Code Relief Reauest: Relief is requested from i examining 100% of the Code-required volume of the following RPV nozzle inside radius sections:

RPV Nozzle Inside Radius Sections Nozzle

% Coverace l RPVI-NIAIR 86%

{

RPVI-NIBIR 86%

RPVI-N4CIR 89%

j RPVI-N4 FIR 89%

i l

Licensee's Prooosed Alternative Examination: None. The Code-required volumetric examination will be performed to the maximum extent practical.

Licensee's Basis for Reauestina Relief: The examination of  !

l nozzle inside radius sections NIAIR and N1BIR is limited as the (

nozzle configuration interferes with scanning on the nozzle  !

boss and prohibits a meaningful interrogation of the bore portion of the inside radius section.

The examination of nozzle inside radius sections N4CIR and N4 FIR is limited due to the proximity of the N11 nozzles.

Evaluation: The Licensee's submittal has been reviewed, '

including figures showing the configurations of the subject nozzle inner radii with respect to the limitations to '

examination and the table with the estinated volume coverage for each examination angle for each of the subject nozzle inner radii. Based on the nozzle design, a significant percentage of the Code-required volumetric examination will be performed.

The nozzles and/or vessel (in the case of adjacent nozzle interference) would have to be redesigned and prefabricated in order to complete the remainder.

4

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examination of the 17 i~

l i

_~__ _ _ _ _ _ _ -1~- - - . - - . - - - - - -

1

~

4 subject nozzle inside radius sections, along with the Code-required pressure test, ensures an acceptable level of -

inservice 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. Therefore, it is recommended that relief be granted as requested.

3.1.1.6 Reauest for Relief. Examination Cateaory B-G-1. Item B6.40 RPV F1anae Liaaments Code Requirement: Section XI, Table IWB-2500-1, Examination Category B-G-1, Item B6.40 requires a 100% volumetric examination of the RPV flange ligaments as defined by Figure

- 4 IWB-2500-12.

Licensee's Code Relief Recuest: Relief is requested from examining -100% of the Code-required volume of the RPV flange ligaments.

Licensee's Proposed Alternative Examination: None. The Code-required volumetric examination will be performed to the maximum extent practical.

Licensee's Basis for Reauestina Relief: The Licensee states -

that due to an abrupt transition at the seal surface cladding, scanning for complete coverage of the ligament area cannot be performed.

Evaluation: Review has been completed on the information presented in the Licensee's relief request submittal and the sketches provided in the submittal dated September 17, 1987.

The sketches show the examination area coverage and the scan area limitations of the RPV flange ligament. A significant percentage of the Code-required examination will be performed 18

,s .

on each stud hole ligament area, and the remainder of the examination will be limited by the lip of the flange seal surface. This examination limitation, and the percent of examination that can be completed, is consistent with limitations reported by other plants of similar design.

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examination of the RPV flange ligaments, along with the Code-required pressure test, ensures an acceptable level of inservice structural integrity I 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. Therefore, it is recommended that relief be granted as requested.

3.1.1.7 Reauest for Relief. Examination Cateoory B-H. Item B8.10. RPV Stabilizer Bracket Welds Code Requirement: Section XI, Table IWB-2500-1, Examination Category B-H, Item B8.10 requires a 100% surface or volumetric examination, as applicable, of the RPV stabilizer bracket welds as defined by Figures IWB-2500-13, -14, and -15.

Licensee's Code Relief Reauest: Relief is requested from 1

examining 100% of the Code-required surface area of the RPV l

)

stabilizer bracket welds.

)

Licensee's Proposed Alternative Examination: None. The

~

Code-required surface examination will be performed to the maximum extent practical.

19 i

1 l

. . _ _ _ - _ .____--___________----_a

1 Licensee's Basis for Reauestino Relief: Complete surface examination coverage is not possible on RPV stabilizer brackets 1, 5, 6, 7, and 8 due to interference from permanent insulation support brackets. The Licensee reports that these brackets will receive the Code-required surface examination on three of the four sides.

Evaluation: Based on the reported obstructions, the surface examination of the subject RPV stabilizer brackets, to the i extent required by the Code, is impractical. A significant portion of the Code-required examination will be completed.

Conclusions:

Based on the above evaluation, it is concluded that the' limited Section XI surface examination of the RPV

, stabilizer bracket welds will ensure an acceptable level of inservice 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. Therefore, it is recommended that relief be granted as requested.

3.1.2 Pressurizer (Does not apply to BWRs) 3.1.3 Heat Exchancers and Steam Generators (No relief requests) 3.1.4 Pioina Pressure Boundarv l

3.1.4.1 Reauest for Relief. Examination Cateaory B-J. Item B9.11.

Pressure Retainino Circumferential Welds in Class 1 Pioina Systems Code Requirement: Section XI, Table IWB-2500-1, Examination Category B J, Item B9.11 requires both 100% surface and 20 i

... .-m L - _ _ - - - - - - - - , - - - - - - - - - - - - - - - - _ _ _ _ . - - - - A

volumetric examinations of pressure retaining circumferential welds in Class 1 piping 4 inch and larger nominal pipe size as defined by Figure IWB-2500-8.

Licensee's Code Relief Reouest: . Relief is requested from examining 100% of the Code-required volum of the following l Class I circumferential welds:

Weld Number Weld Configuration  % Examinable- l

1-AB-8DBA-0318-2 Pipe-to-Flange 75%

l-BB-4VCA-012-1 Branch-to-Pipe 75%

i 1-BB-28VCA-013-2 Pipe-to-Valve 50%

1-BB-4VCA-013-1 Branch-to-Cap 75%

l-BC-20CCA-Il4-1 Tee-to-Pipe 50%

l-BG-4CCA-Oll-01 Weldolet-to-Pipe 50%

l-BG-4CCA-012-1 Weldolet-to-Pipe 66%

Licensee's Prooosed Alternative Examination:' None. The Code-required volumetric examination will be' performed to the

. maximum extent practical.

Licensee's Basis for Reauestino Relief: Becav;e of the ,

configuration of these welds (i.e. pipe-to-flange, branch I

. connection-to-pipe, pipe-to-valve, tee-to-pipe, etc.), complete volumetric examination of the Code-required volume is not obtainable.

~

Evaluation: The Licensee's ' submittal has been reviewed, and it has been determined that, based on the weld design, a significant percentage of the Code-required volumetric examination will be performed. It is noted that complete l examinations which meet the requirements of ASME Code Section XI will be performed on welds of similar configuration

, using the same inspection techniques, equipment, and procedures as these partially inspected welds. Since these welds will see l the same operating and environmental conditions as the inspected welds, a reasonable assurance of the structural integrity of the welds for which relief is requested will be attained. 4 21

-_ - - _ _ . - . _ _ - - . _ - - - - _ - " " ~ ~ ~

l ' n. ,

I e

+

Conclusions:

Based on the above evaluatien, it is concluded

~ that the limited Section XI volumetric examination of the subject welds, along with the Code-required surface examination and pressure test, ensures an acceptable level of inservice 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. Therefore, it is recommended that relief be granted as requested.

3.1.4.2 Reauest for Relief. Examination Cateaory B-J. Item B9.31.

pressure Retainino Branch Connection Welds in Class 1 Pioina -

Systems Code Requirement: Section XI, Table IWB-2500-1, Examination Category B-J, Item B9.31 requires both 100% surface and volumetric examinations of pressure retaining branch connection welds in Class 1 piping systems 4 inch and larger nominal pipe size as defined by Figures IWB-2500-9, -10, and -11.

Licensee's Code Relief Reouest: Relief is requested from examining 100% of the Code-required volume of branch connection welds 1-BB-2BVCA-012-9BC3 and 1-BB-2BVCA-013-1BC1. .

I Licensee's Proposed Alternative Examination: None. The i

Code-required volumetric examination will be performed to the maximum extent practical.

Licensee's Basis for Reouestina Relief: The Licensee reports (

that because of the configuration of the subject branch connections, volumetric coverage using O' weld and 45' transverse scans is not obtainable.

22 L __ - _ __-_ - -

Evaluation: Based on branch connection design, the complete Code-required volumetric examination cannot be performed.

However, the Licensee can and will perform a Code-required 60'-

examination from the pipe side of the branch connection on Weld No. 1-BB-28VCA-012-9BC3 and a Code-required 45' examination ,

from the pipe side of the branch connection on Weld No.

1-BB-28VCA-013-1BC1. The Code-required surface examination will be performed.  ;

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI voluanetric examination of the sub.iect walds, along with the Code-required surface examination and pressure test, ensures an acceptable level of inservice 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. Therefore, it is recommended that relief be granted as requested.

3.1.4.3 Recuest for Relief. Examination Catecory B-K-1. Item B10.10. l Intecrally Welded Attachments to Class 1 Pioino Systems Code Requirement: Section XI, Table IWB-2500-1, Examination .

Category B-K-1, Item B10.10 requires a 100% volumetric or '

surface examination of Class I piping integrally welded attachments. The examination shall be as defined by Figures IWB-2500-13, -14, and -15.

~

Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required surface area on Class 1 piping integrally welded attachment No. 1-BB-2DBA-192A-IPSI.

1 23 f

- _ _ - . - - _ _ . _ _ _ _ . . _ . - - _ . o

Licensee's Pronosed Alternative Examination: None.- The Code-required surface examination will be performed to the j maximum extent practical.

l Licensee's Basis for Reauestina Relief: The Licensee reports that complete surface examination coverage is not obtainable as the integral attachment cannot be examined on the upstream side due to interference from an expansion joint.

) Evaluation: Based on the design of the integrally welded  !

attachment, and as reported during the preservice inspection surface examination request for relief, a significant i percentage of the Code-required surface examination will be 3 performed. It is also noted that the complete examination which meets the requirements of Section XI will be performed on welds of similar configuration using the same inspection techniques, equipment, and procedures as in this partial inspection. Therefore, a reasonable assurance of the structural integrity of the weld for which relief is requested will'be attained.

I

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI surface examination of this weld, q in conjunction with the complete examination of similar - J configuration welds, ensures an acceptable level of inservice -

structural integrity and that compliance with the specific l requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, it is recommended that relief be granted as requested.

3.1.5 Pumo Pressure Boundarv (No relief requests) j l

3.1.6 Valve Pressure Boundarv (No relief requests) 24

.~o  : .~

m___mm_ ._ _ _ _

. 3.1.7 General (No relief requests) 3.2 Class 2 Comoonents 3.2.1 Pressure Vessels 3.2.1.1 Reauest for Relief. Examination Cateaory C-B. Item C2.22.

Nozzle inside Radius Section on the RHR Heat Exchanaer Code Requirement: Section XI, Table IWC-2500-1, Examination Category C-8, Item B2.22 requires a 100% volumetric examination of nozzle inside radius sections on Class 2 vessels with nominal wall thickness greater than 1/2 inch as defined by Figure IWC-2500-4.

Licensee's Code Relief Recuest: Relief is requested from examining 100% of the Code-required volume of the RHR Heat Exchanger 'A' Nozzle RHXIR2 inside radius section.

Licensee's Prooosed Alternative Examination: None. The Code-required volumetric examination will be performed to the maximum extent practical.

Licensee's Basis for Reauestina Relief: The Licensee reports .

that, due to the configuration of the N4 nozzle, complete inner -

radius coverage cannot be obtained.

Evaluation: The Licensee's submittal has been reviewed, including the description of the areas of the inner radius that cannot be examined. Approximately 21% of the volume will receive the Code-required examination. The nozzle and/or heat ,

exchanger vessel would have to be redesigned and prefabricated  !

! in order to complete the remainder.

l I

l 25 I

L

Conclusions:

Based on the above evaluation, it is concluded that the limited Section XI volumetric examination of the RHR l

heat exchanger nozzle inside radius sections ensures an acceptable icvel of inservice 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.

Therefore, it is recommended that relief be granted as requested.

3.2.2 P.ioing (No relief requests) 3.2.3 Pumps 3.2.3.1 Recuest for Relief. Examination Cateaory C-G. Item C6.10.

Pressure Retainino Class 2 Pumo Casino Welds Code Requirement: Section XI, Table IWC-2500-1. Examination Category C-G, Item C6.10 requires a 100% surface examination of pressure retaining Class 2 pump casing welds as defined by Figure IWC-2500-8.

)

I Licensee's Code Relief Reauest: Relief is requested from examining 100% of the Code-required surface of the following pressure retaining Class 2 pump casing welds:

Core Sorav Pumo "D" CSP-W1 CSP-W2 CSP-W5

~

Residual Heat Removal Pumo "D" RHP-W1 RHP-W2 RHP-W3 Licensee's Procosed Alternative Examination: Nore. The

Code-required surface examination will be performed to the I maximum extent practical.

26 I

1 Licensee's Basis for Reouestino Relief: The Licensee states that welds CSP-W1 and RHP-W1 are completely inacces:ible due to the pump lower sections being within concrete pump pedestals.

Welds CSP-W2, RHP-W2, and RHP-W3 can only receive limited

)

surface examinations due to portions of the welds being located '

within the concrete pedestal encasements.

Weld CSP-W5 is made inaccessible for surface examination by

{

flange bolts. However, the Licensee reports that the '

Code-required surface examination.will be performed when the flange is disassembled.

l Evaluation: Based on the design of the pumps and the pump support pedestals, these components would have to be redesigned and prefabricated in order to complete the remainder of the Code-required examination without disassembly.

Conclusions:

Based on the'above evaluation, it is concluded that the limited Section XI surface examination ensures an acceptable level of inservice 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. -

Therefore, it is recommended that relief be granted as requested.

3.2.4 Valves (No relief requests) 3.2.5 General (Noreliefrequests) 3.3 Class 3 Comoonents (No relief requests) 27 D _- __ _ o

n

. 3. '4 Pressure Tests (No relief requests) 3.5. General 3.5.I' Ultrasonic Examination Techniaues (No relief requests) 3.5.2 .Exemoted Comoonents (No relief requests) 3.5.3 Q1hgr 3.5.3.1 Reauest for Relief. Examination Cateaory F-C. Inservice Visual Examination of Mechanical and Hydraulic Snubbers Code Requirement: Section XI, Table IWF-2500-1, Examination

, Category F-C, Item numbers B3.10 through B3.50 require visual examinations (VT-3 and VT-4) of hydraulic and mechanical type snubbers. These examinations are to be performed once per inspection interval on those snubbers selected in accordance with IWF-2510.

Licensee's Code Relief Reauest: The Licensee requests relief from performing the inservice VT-3 and VT-4 visual examinations and inservice (functional) testing to the requirements of the Code. .

Licensee's Proposed Alternative Examination: Visual examinations and functional testing will be performed on Code Class 1, 2, and 3 (and other) snubbers in compliance with Hope Creek Generating Station Technical Specification 3/4.7.5 and its associated bases.

Licensee's Basis for Reauestino Relief: The Licensee reports that performance of examinations and testing to the requirements of the Technical Specification meet some of the 1 28 i

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Code requirements. However, this approach differs in the areas of examination scheduling, re-examinations, and functional testing requirements. The Licensee also states that testing to the . Technical Specification results in an increase in the overall level of plant quality and safety.

The first visual' examination of all safety-related snubbers and compensating struts ~ is presently-scheduled to be performed at least 4 months after but within 10 months of the date of commercial . operation. Functional testing will commence at the

! first refueling shutdown in accordance with the provisions and requirements of the Technical Specification.

/

I Evaluation: The Licensee's submittal has been reviewed and it is noted that, per IWA-2240, " Alternative Examinations,"

alternative examination methods, a combination of methods, or newly developed techniques may be substituted for the methods specified in Division 1 of Section XI, provided the inspector l ,

{

is satisfied that the results are demonstrated to be equivalent I or superior to those of the specified method.

The use of the Technical Specification for the examination of snubbers is equivalent to the Code requirements and,-therefore, in accordance with IWA-2240, is an acceptable alternative.

NOTE: Functional tests are not within the scope of this '

document and will be evaluated. elsewhere. Therefore.

the section of this relief reauest involvino functional testino of snubbers is not included in this evaluation.

1

- l

Conclusions:

Based on the above evaluation, it is concluded that the proposed alternative examination is equivalent to the Code requirement and, thus, ensures an acceptable level of

inservice structural integrity. Therefore, it is recommended

{

that relief be granted for the visual examination only.  ;

i

^

l 29 l

L

- , , , , ~ , _ ,_m

l

4. CONCLUSION Pursuant to 10 CFR 50.55a(g)(6), it has been determined that certain Section XI required inservice examinations are impractical. In all cases the Licensee has demonstrated that either the proposed alternatives would provide an acceptable level of quality and safety or that compliance with the requirements would result in hardships or unusual difficulties without a compensating increase in the level of quality and safety.

This technical evaluation has not identified any practical method by which the existing Hope Creek Generating Station can meet all the specific inservice inspection requirements of Section XI of the ASME Code. Requiring compliance with all the exact Section XI required inspections would require redesign of a significant number of plant systems, sufficient replacement

, components to be obtained, installation of the new components, and a

. baseline examination of these components. Examples of components that would require redesign to meet the specific inservice examination provisions are:

the Reactor Pressure Vessel, RHR Heat Exchanger, Core Spray and RHR Pumps, and a number of the piping and component support systems. Even after the redesign efforts, complete compliance with the Section XI examination requirements probably could not be achieved. Therefore, it is concluded that the public interest is not served by imposing certain provisions of Section XI of the ASME Code that have been determined to be impractical.

)

Pursuant to 10 CFR 50.55a(g)(6), relief is allowed from these requirements -

{

which are impractical to implement. .

l t

The development of new or improved examination techniques will continue to j be monitored. As improvements in these areas are achieved, the NRC may require that these techniques be incorporated in the next inspection l interval ISI program plan examination requirements.

)

Based on the review of the Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0, the Licensee's response to the NRC's Request for Additional Information, and the recommendations for granting relief from the ISI examination requirements 1

30 I

=_ _ _ _ _ _ _ l

/ '

that have been determined to be impractical, it is concluded that the Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0, is acceptable and in compliance with 10 CFR 50.55a(g)(4).

l O

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i 31

________-___-m__-__m___.

5. REFERENCES

1. Code of Federal Regulations, Volume 10, Part 50,

2. American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Division 1:

1983 Edition through Summer 1983 Addenda

3. Hope Creek Generating Station Inservice Inspection Program, Long Term Plan, First 10-Year Interval, Revision 0, dated June 1987.

4. Regulatory Guide 1.147, Revision 5, " Inservice Inspection Code Case Acceptability, ASME Section XI Division 1," dated August 1986.

5. Hope Creek Generating Station Inservice Examination Program Submittal, First 10-Year Interval, dated September 1986.

i

6. Letter, dated March S,1987, D.H. Wagner (NRC) to C.A. McNeill [Public Service Electric & Gas Company (PSE&G)], " Request for Additional Information on First 10-Year Interval Inspection Program."

J

7. Letter, dated Julie 29, 1987, C.A. McNeill (PSE&G) to Document Control Desk (NRC), " Inservice Inspection Program - Reply to NRC Request for Additional Information."

8. Letter, dated July 31, 1987, C.A. McNeill (PSE&G) to Document Control Desk (NRC), " Inservice Inspection Program - Supplemental Information -

Hope Creek Generating Station."

9. NUREG-0800, Standard Review Plans, Section 5.2.4, " Reactor Coolant Boundary Inservice Inspection and Testing," and Section 6.6, " Inservice Inspectian of Class 2 and 3 Components," July 1981.

32 O _ ___ - _ _ __ _L

~

~

10. Letter,. dated September 17, 1987, C.A. McNeill (PSE&G) to Document Control Desk (NRC), " Response to Questions on Inservice Inspection Program, Long Term Plan, for Hope Creek Generating Station."

11. NUREG 0803, " Generic Safety Evaluation Report Regarding Integrity of BWR Scram System Piping," August 1981, i -

12. . Regulatory Guide 1.150, " Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations," Revision 1, dated February 1983.

13. NUREG-0619, "BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking," dated November 1980.

14.

NRC Inspection and Enforcement Bulletin 80-13, " Cracking in Core Spray Spargers," dated May 12, 1980.

15.

NUREG-0313, " Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping," Revision 1, dated July 1980.

O en O

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g,*o.m n uarua neeuwo.,Co .o. . .s o-, w . . - ., noc v., .

%*"/7 SISUOGRAPHK: DATA SHEET EGG-SD-7829 S.E t.sst.WCT o. t ..v..s.

• • TEclin E Evaluation Report on the First 10-Year "'"'

Interval Inservice Inspection Program Plan:

Public Service Electric & Gas Company, Hope Creek Generating Station, Docket Number 50-482 , ,,,, ,,,, ,,,,,,,,,,,

,,o., ,

. .or ....

November I 1987 B.W. Brown, J.D. Mudlin *"""

November I 1987

. n .. .. o.s... w o. .... . ...s,. .. . , e. - . ,es,,

EG&G Idaho, Inc. . ,.o.. .. .. ...

P. O. Box 1625 ..,

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Idaho Falls, ID 83415-2209 .

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Materials Engineering Branch Technical Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission .aaoocomo - -- l Washington, D.C. 20555 l i

.. .u s. u . oru tJ .$fT..CTfM as.se,.y w This report presents the results of the evaluation of the Hope Creek Generating Station First 10-Year Interval Inservice Inspection ISI Program Plan through Revision 3, submitted August 11, 1987, including the(requ)ests for relief from the ASME Code Section XI requirements which the Licensee has determined to be )

impractical. The Hope Creek Generating Station First 10-Year Interval ISI Program l Plan-is evaluated in Section 2 of this report. The ISI Program Plan is evaluated for (a) compliance with the appropriate edition of Section XI, (b) acceptability of examination _ sample, (c) exclusion criteria, and (d) compliance with ISI related commitments identified during the NRC's review before granting an Operating License.

The requests for relief from the ASME Code requirements which the Licensee has *

. determined to be impractical for the first 10-year inspection interval are evaluated .

in Section 3 of this report.

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