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| issue date = 12/10/1993
| issue date = 12/10/1993
| title = Responds to RAI Re ISI Program First 10-Year Interval Final Relief Request on Limited Volumetric Exam Coverage
| title = Responds to RAI Re ISI Program First 10-Year Interval Final Relief Request on Limited Volumetric Exam Coverage
| author name = HAGAN J J
| author name = Hagan J
| author affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY
| author affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY
| addressee name =  
| addressee name =  
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:***. __ --Public Service Electric and Gas Company
{{#Wiki_filter:***.
* Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President  
Public Service Electric and Gas Company Joseph J. Hagan                       Public Service Electric and Gas Company   P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations DECl 0 1993 NLR-N93194 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
-Nuclear Operations DECl 0 1993 NLR-N93194 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM FIRST 10-YEAR INTERVAL, FINAL RELIEF REQUESTS SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311 By letter dated September 28, 1992, Public Service Electric & Gas Company (PSE&G) submitted the Final Relief for the first 10-year interval for Salem Unit No. 2. By letter dated October 5, 1993, the NRC requested additional information to support PSE&G's submittal for Salem Unit No. 2 Inservice Inspection Program.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM FIRST 10-YEAR INTERVAL, FINAL RELIEF REQUESTS SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311 By letter dated September 28, 1992, Public Service Electric & Gas Company (PSE&G) submitted the Final Relief for the first 10-year interval for Salem Unit No. 2. By letter dated October 5, 1993, the NRC requested additional information to support PSE&G's submittal for Salem Unit No. 2 Inservice Inspection Program. Attachment 1 contains PSE&G's response to the requests for additional information.
Attachment 1 contains PSE&G's response to the requests for additional information. Attachment 2 contains the revised relief request pages.
Attachment 2 contains the revised relief request pages. Should there be any questions with regard to this submittal, please do not hesitate to contact us. *')')001-''8 t.. ..J .. ll}* .
Should there be any questions with regard to this submittal, please do not hesitate to contact us.
* Document Control Desk NLR-N93194 C Mr. J. c. Stone Licensing Project Manager Mr. c. Marschall Senior Resident Inspector 2 Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Manager IV
                *')')001-''8 t.. ..J .. ll}* .
* New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 DEC 10 1993
 
* NLR-N93194 ATTACHMENT 1 SALEM UNIT NO. 2
Document Control Desk           2
* RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM FIRST 10-YEAR INTERVAL FINAL RELIEF REQUESTS The following is a response to the NRC request for additional information (RAI), dated October 5, 1993. REQUEST A Final Relief Request #1 includes requests for relief due to limited volumetric examination coverage.
* DEC 10 1993 NLR-N93194 C   Mr. J. c. Stone Licensing Project Manager Mr. c. Marschall Senior Resident Inspector Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Manager IV New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
In February, 1990, the licensee requested and received approval for the use of ASME Code Case N-460, which allows a reduction of examination coverage not to exceed 10 percent of the required volume. The licensee has provided a table describing the examination areas for-which relief is requested.
 
Under the table heading "LIMITATION", the licensee gives the percent of volumetric examination area that received volumetric coverage followed by the statement that coverage was obtained in at least one direction.
NLR-N93194 ATTACHMENT 1 SALEM UNIT NO. 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM FIRST 10-YEAR INTERVAL FINAL RELIEF REQUESTS The following is a response to the NRC request for additional information (RAI), dated October 5, 1993.
Based on Code Case N-460, the licensee states that for some of the limited examinations listed in this table, relief would no longer be required.
REQUEST A Final Relief Request #1 includes requests for relief due to limited volumetric examination coverage. In February, 1990, the licensee requested and received approval for the use of ASME Code Case N-460, which allows a reduction of examination coverage not to exceed 10 percent of the required volume.
From the information provided, the extent to which Code required volume coverage being obtained is unclear to the staff; therefore, the examination areas that would not require relief based on Code Case N-460 cannot be determined.
The licensee has provided a table describing the examination areas for-which relief is requested. Under the table heading "LIMITATION", the licensee gives the percent of volumetric examination area that received volumetric coverage followed by the statement that coverage was obtained in at least one direction. Based on Code Case N-460, the licensee states that for some of the limited examinations listed in this table, relief would no longer be required.
Code examination coverage is satisfied when the ultrasonic beam passes through the cross-sectional volume of a specified examination area in two directions for the specified Code examination length. If coverage is obtained in at least one direction, as stated, but coverage in the second direction is not quantified, the Code required coverage obtained is not known, and the basis for the claim that relief may no longer be required is not clear. The staff requests that the licenseer.provide the accumulative examination volume coverage based on; (1) the percent of ,volume coverage obtained by two directional, beam component coverage for scans perpendicular to the weld; (2) the percent of volume coverage obtained for scans performed with the beam component parallel to the weld; and (3) the percent of the total length scanned. RESPONSE A See below NLR-N93194 Attachment 1 REQUEST B *
From the information provided, the extent to which Code required volume coverage being obtained is unclear to the staff; therefore, the examination areas that would not require relief based on Code Case N-460 cannot be determined. Code examination coverage is satisfied when the ultrasonic beam passes through the cross-sectional volume of a specified examination area in two directions for the specified Code examination length. If coverage is obtained in at least one direction, as stated, but coverage in the second direction is not quantified, the Code required coverage obtained is not known, and the basis for the claim that relief may no longer be required is not clear.
* 2 In the table for Final Relief Request #1, it.appears that examination areas 29-STG-1240-IRS and 6-SJ-1241-16 both have duplicate examination areas identified under a separate Sum #. Please clarify the apparent duplication.
The staff requests that the licenseer.provide the accumulative examination volume coverage based on; (1) the percent of ,volume coverage obtained by two directional, beam component coverage for scans perpendicular to the weld; (2) the percent of volume coverage obtained for scans performed with the beam component parallel to the weld; and (3) the percent of the total length scanned.
RESPONSES A AND B The attached final Relief Request #1 has been revised. These revisions include: 1. Only those welds requiring relief when applying Code Case N-460 are included.
RESPONSE A See below
Welds receiving accumulative examination average of 90% or greater when incorporating the NRC guidance in paragraph 2A of the RAI have been deleted. The "Alternative Examination" section has been revised to present PSE&G's position on not performing alternate examinations.
 
: 3. The end of the "Basis for Relief" section has been revised to present the process on how PSE&G identified what belonged on the final relief request list. 4. The Relief Request Table was revised to include the following:
NLR-N93194
: a. Editor.:i,.al corrections were made on the table, including corrections to examination areas 29-STG-1240-IRS and 6-SJ-1241-16 as identified in the RAI. b. The remarks column and basis column have been removed with the pertinent information shown in a "Limitation" column. c. The Alternate Examination column has been removed. There are no alternate examinations.proposed for any of the areas. d. A "% of Accum. Exam. Code Coverage" column is now included.
* 2 REQUEST B In the table for Final Relief Request #1, it.appears that examination areas 29-STG-1240-IRS and 6-SJ-1241-16 both have duplicate examination areas identified under a separate Sum #.
These percentages have been calculated in accordance with the NRC staff request identified above. -------------------------------------------
Please clarify the apparent duplication.
NLR-N93194 Attachment 1 REQUEST C 3 Final Relief Request #2, Alternative Examination, states: "Public Service Electric and Gas examined at least one valve in a valve group (valves of similar design and function) where at least one valve in the group was disassembled for maintenance purposes during the inspection interval.
RESPONSES A AND B The attached final Relief Request #1 has been revised.       These revisions include:
If any valve was found to require corrective action, additional valves in that group would be disassembled and inspected as required by Section XI". It is further stated in the second paragraph under "Alternative Examination", that the aforementioned statement is a guideline.
: 1. Only those welds requiring relief when applying Code Case N-460 are included. Welds receiving accumulative examination average of 90% or greater when incorporating the NRC guidance in paragraph 2A of the RAI have been deleted.
2~  The "Alternative Examination" section has been revised to present PSE&G's position on not performing alternate examinations.
: 3. The end of the "Basis for Relief" section has been revised to present the process on how PSE&G identified what belonged on the final relief request list.
: 4. The Relief Request Table was revised to include the following:
: a. Editor.:i,.al corrections were made on the table, including corrections to examination areas 29-STG-1240-IRS and 6-SJ-1241-16 as identified in the RAI.
: b. The remarks column and basis column have been removed with the pertinent information shown in a "Limitation" column.
: c. The Alternate Examination column has been removed.
There are no alternate examinations.proposed for any of the areas.
: d. A "% of Accum. Exam. Code Coverage" column is now included. These percentages have been calculated in accordance with the NRC staff request identified above.
 
NLR-N93194                       3 REQUEST C Final Relief Request #2, Alternative Examination, states: "Public Service Electric and Gas examined at least one valve in a valve group (valves of similar design and function) where at least one valve in the group was disassembled for maintenance purposes during the inspection interval. If any valve was found to require corrective action, additional valves in that group would be disassembled and inspected as required by Section XI". It is further stated in the second paragraph under "Alternative Examination", that the aforementioned statement is a guideline.
It is unclear to the staff whether the guideline for the "Alternative Examination" is a statement of examinations performed or a statement of requirement (i.e. will examine at least one valve ..... ). Please clarify the extent of the Code required examinations that were completed during the first 10-year interval.
It is unclear to the staff whether the guideline for the "Alternative Examination" is a statement of examinations performed or a statement of requirement (i.e. will examine at least one valve ..... ). Please clarify the extent of the Code required examinations that were completed during the first 10-year interval.
RESPONSE C In order to more clearly state PSE&G's position, the "Alternative Examination" section of Relief Request #2 has been revised. The revision includes a description of the use of 19S9 Edition of Section XI, Table IWB-2500,.Category B-M-2, item B12.50. REQUEST D *-Included in Final Relief ReqUes( #3*is a to Examination Category B-A, Item Number B1.1, for examination of reactor vessel welds in the beltline region. It appears that the licensee is requesting credit for examination area coverage of Category B-A welds that exceeded the Code requirements, as an alternative examination for relief associated with Examination Category B-B and B-D. The licensee states that for vessel welds in the beltline region, 100 percent examination of all required welds was attempted.
RESPONSE C In order to more clearly state PSE&G's position, the "Alternative Examination" section of Relief Request #2 has been revised. The revision includes a description of the use of 19S9 Edition of Section XI, Table IWB-2500,.Category B-M-2, item B12.50.
Although the licensee maximized coverage on the category B-A examination volume, this does not constitute an alternative examination for other examination categories.
REQUEST D Included in Final Relief ReqUes( #3*is a referenc~ to Examination Category B-A, Item Number B1.1, for examination of reactor vessel welds in the beltline region. It appears that the licensee is requesting credit for examination area coverage of Category B-A welds that exceeded the Code requirements, as an alternative examination for relief associated with Examination Category B-B and B-D. The licensee states that for vessel welds in the beltline region, 100 percent examination of all required welds was attempted.
The licensee should include alternative examinations that are applicable to the examination category and examination areas for which Code required coverage is not obtained.
Although the licensee maximized coverage on the category B-A examination volume, this does not constitute an alternative examination for other examination categories. The licensee should include alternative examinations that are applicable to the examination category and examination areas for which Code required coverage is not obtained. Please provide a revised relief request that addresses any alternative examinations for limitations associated with Examination Categories B-B and B-D.
Please provide a revised relief request that addresses any alternative examinations for limitations associated with Examination Categories B-B and B-D.
 
NLR-N93194 Attachment 1 RESPONSE D See below REQUEST E
NLR-N93194
* 4 Final Relief Request #3 has a table that lists percents of coverage for "Beam Directions," cw, ccw, Up, Down, and Toward RX. Refer to "A" above and provide the percent of examination area coverage obtained.
* 4 RESPONSE D See below REQUEST E Final Relief Request #3 has a table that lists percents of coverage for "Beam Directions," cw, ccw, Up, Down, and Toward RX.
RESPONSES D AND E In order to more clearly state PSE&G's position, Relief Request #3 has been revised. The revision includes a re-write of the "Basis for Relief" section and the "Alternative Examination" section, also revisions to the table listing welds requiring relief were made, which include: a. Adding a "% of Accum. Exam. Code Coverage" column with percent coverage as described previously.
Refer to "A" above and provide the percent of examination area coverage obtained.
: b. Deleting the "Remarks" column and including pertinent information in a " Limitations" column. As an additional point of clarification, PSE&G has not, or proposed to take credit for excess examination coverage obtained in category B-A as an alternative to a relief request for examinations in category B-B , B-D or any other examination category.
RESPONSES D AND E In order to more clearly state PSE&G's position, Relief Request
ATTACHMENT 2 REVISED FINAL RELIEF REQUESTS SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 1 COMPONENT DESCRIPTION:
#3 has been revised. The revision includes a re-write of the "Basis for Relief" section and the "Alternative Examination" section, also revisions to the table listing welds requiring relief were made, which include:
Pressure vessels, components, and piping welds and integrally welded attachments subject to surface and/or volumetric examination listed on the attached table. ASME CODE CLASS: ASME Section XI Class 1, 2 welds. ASME EXAMINATION REQUIREMENTS:
: a. Adding a "% of Accum. Exam. Code Coverage" column with percent coverage as described previously.
In accordance with the examination requirements of Subsection IWB, Table IWB-2500 of examination categories:
: b. Deleting the "Remarks" column and including pertinent information in a " Limitations" column.
B-C, B-D, B-F, B-J and Subsection IWC, Table IWC-2520 examination categories:
As an additional point of clarification, PSE&G has not, or proposed to take credit for excess examination coverage obtained in category B-A as an alternative to a relief request for examinations in category B-B , B-D or any other examination category.
C-A, c-c, C-E-1, c-F and C-G when an examination (surface or volumetric) is performed, essentially 100% of the weld length is required to be inspected.
 
BASIS FOR RELIEF: The ASME Code requires surface and volumetric examination of various Class 1 vessel and piping welds as defined in Paragraph and various Class 2 vessel and piping welds as defined in Paragraph IWC-2500. During the inservice examinations performed at SALEM. NUCLEAR GENERATING STATION UNIT 2 it has been the position of PUBLIC SERVICE ELECTRIC AND GAS COMPANY that examinations which could not be performed completely, (i.e., performed from two (2) directions because of component configuration or restrictions from permanent structures) the examination would be performed to the greatest extent possible and whatever limitation that existed be documented.
ATTACHMENT 2 REVISED FINAL RELIEF REQUESTS
It has also been PUBLIC SERVICE ELECTRIC AND GAS COMPANY'S position that when there was a "removable" structure, (i.e., hanger, support) these items were removed, when practical, providing greater access to the component being examined.
 
The basis for this position.
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1 COMPONENT DESCRIPTION:
is as follows:*
Pressure vessels, components, and piping welds and integrally welded attachments subject to surface and/or volumetric examination listed on the attached table.
The Code of Federal Regulations, 10CFR50, "Domestic Licensing of Production and Utilization Facilities" defines those requirements which must be adhered to by the utility in order to be issued and maintain an operating license. This document states in Paragraph 55a(g) that inservice inspections shall meet the requirements of the ASME Boiler & Pressure Vessel Code. Throughout 10CFR50 numerous references are made allowing performance of these inspections "to the extent practical".
ASME CODE CLASS:
PAGE 1 OF 9 SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 1 Some of the specific paragraphs are: Paragraph 50.55a(g)4 states that throughout the service life of a nuclear power facility components which are classified as ASME Code Class 1, 2 and 3 shall meet the requirements of Section XI of the ASME B&PV Code, "to the extent practical within the limitations of design, geometry and materials of construction of the components".
ASME Section XI Class 1, 2 welds.
Paragraph 50.55a(2)i of this document states that inspection of systems and components is performed "to the maximum extent practical, in accordance with generally recognized codes and standards" i.e., ASME Boiler & Pressure Code. Paragraph 50.55g(l) states that components (including supports) shall meet the requirements of (ASME Code) "to the extent practical".
ASME EXAMINATION REQUIREMENTS:
In accordance with the examination requirements of Subsection IWB, Table IWB-2500 of examination categories: B-C, B-D, B-F, B-J and Subsection IWC, Table IWC-2520 examination categories: C-A, c-c, C-E-1, c-F and C-G when an examination (surface or volumetric) is performed, essentially 100% of the weld length is required to be inspected.
BASIS FOR RELIEF:
The ASME Code requires surface and volumetric examination of various Class 1 vessel and piping welds as defined in Paragraph IWB~2500 and various Class 2 vessel and piping welds as defined in Paragraph IWC-2500.
During the inservice examinations performed at SALEM. NUCLEAR GENERATING STATION UNIT 2 it has been the position of PUBLIC SERVICE ELECTRIC AND GAS COMPANY that examinations which could not be performed completely, (i.e., performed from two (2) directions because of component configuration or restrictions from permanent structures) the examination would be performed to the greatest extent possible and whatever limitation that existed be documented.
It has also been PUBLIC SERVICE ELECTRIC AND GAS COMPANY'S position that when there was a "removable" structure, (i.e., hanger, support) these items were removed, when practical, providing greater access to the component being examined. The basis for this position. is as follows:*
The Code of Federal Regulations, 10CFR50, "Domestic Licensing of Production and Utilization Facilities" defines those requirements which must be adhered to by the utility in order to be issued and maintain an operating license. This document states in Paragraph 55a(g) that inservice inspections shall meet the requirements of the ASME Boiler & Pressure Vessel Code.
Throughout 10CFR50 numerous references are made allowing performance of these inspections "to the extent practical".
PAGE 1 OF 9
 
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1 Some of the specific paragraphs are:
Paragraph 50.55a(g)4 states that throughout the service life of a nuclear power facility components which are classified as ASME Code Class 1, 2 and 3 shall meet the requirements of Section XI of the ASME B&PV Code, "to the extent practical within the limitations of design, geometry and materials of construction of the components".
Paragraph 50.55a(2)i of this document states that inspection of systems and components is performed "to the maximum extent practical, in accordance with generally recognized codes and standards" i.e., ASME Boiler & Pressure Code.
Paragraph 50.55g(l) states that components (including supports) shall meet the requirements of (ASME Code) "to the extent practical".
The ASME Code itself provides allowance for "limited" examinations.
The ASME Code itself provides allowance for "limited" examinations.
The 1986 Edition, Section V, Article 4, Paragraph T-441.3.2.4 states: "Whenever feasible, the scanning of the examination volume shall be carried out from both sides of the weld on the same surface. Where configuration of adjacent parts of the component are such that the scanning from both sides is not feasible, this fact shall be included in the report of the examination".
The 1986 Edition, Section V, Article 4, Paragraph T-441.3.2.4 states:
PUBLIC SERVICE ELECTRIC AND GAS COMPANY has utilized approved technical procedures written in accordance with the applicable Section/Paragraph of the ASME Code in regard to the area/volume to be examined and the specified requirements of the examination for the 1st inspection interval.
"Whenever feasible, the scanning of the examination volume shall be carried out from both sides of the weld on the same surface. Where configuration of adjacent parts of the component are such that the scanning from both sides is not feasible, this fact shall be included in the report of the examination".
Recognizing that because of component design, construction, etc. there are cases when examinations can only be performed "to the greatest extent possible".
PUBLIC SERVICE ELECTRIC AND GAS COMPANY has utilized approved technical procedures written in accordance with the applicable Section/Paragraph of the ASME Code in regard to the area/volume to be examined and the specified requirements of the examination for the 1st inspection interval. Recognizing that because of component design, construction, etc. there are cases when examinations can only be performed "to the greatest extent possible". PUBLIC SERVICE ELECTRIC
PUBLIC SERVICE ELECTRIC & GAS has previously submitted a list of those identified limitations after performing the preservice examination.
& GAS has previously submitted a list of those identified limitations after performing the preservice examination. Subsequently Weld selection for this interval was made to minimize known limitations identified during preservice examination (PSI). For limitations found during the 1st inservice inspection interval, additional, components were scheduled and examined, when possible, to meet the allocation table requirements of ASME Section XI 1974 Edition, Summer 75 Addenda.
Subsequently Weld selection for this interval was made to minimize known limitations identified during preservice examination (PSI). For limitations found during the 1st inservice inspection interval, additional, components were scheduled and examined, when possible, to meet the allocation table requirements of ASME Section XI 1974 Edition, Summer 75 Addenda. PSE&G requested and received approval for use of ASME Code Case N-460 in February, 1990 allowing a reduction of examination coverage not to exceed 10% of the required volume. Utilizing that criteria and the additional guidance found in 2.A of the NRC RAI, dated October 5, 1993 on accumulative examination volume coverage, PSE&G has been able to minimize those components requiring relief. PAGE, 2 OF 9 SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 1 ALTERNATE EXAMINATION:
PSE&G requested and received approval for use of ASME Code Case N-460 in February, 1990 allowing a reduction of examination coverage not to exceed 10% of the required volume. Utilizing that criteria and the additional guidance found in 2.A of the NRC RAI, dated October 5, 1993 on accumulative examination volume coverage, PSE&G has been able to minimize those components requiring relief.
No alternate examinations were performed on the components listed in the attached table for the following reasons: 1. Where appropriate, Section XI had already required surface examinations in addition to volumetric examinations.
PAGE, 2 OF 9
 
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1 ALTERNATE EXAMINATION:
No alternate examinations were performed on the components listed in the attached table for the following reasons:
: 1. Where appropriate, Section XI had already required surface examinations in addition to volumetric examinations.
: 2. Performing surface examinations on areas with limitations were not justified when considering the following:
: 2. Performing surface examinations on areas with limitations were not justified when considering the following:
a) all examination areas received coverage greater than 50% of the required volume. b) The Code has identified the examination area, to be the lower 1/3 of the weld. *performing a surface examination on the outside surface gives no information on the condition of the lower 1/3 of the weld. c) Additional radiation exposure to personnel.
a)   all examination areas received coverage greater than 50% of the required volume.
PAGE* 3 OF 9
b)   The Code has identified the examination area, to be the lower 1/3 of the weld.
              *performing a surface examination on the outside surface gives no information on the condition of the lower 1/3 of the weld.
c)   Additional radiation exposure to personnel.
PAGE* 3 OF 9
 
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1


==SUMMARY==
==SUMMARY==
# 002700 020600 020700 020800 020900 021000 021100 SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 1 COMPONENT ID CODE CODE % OF LIMITATIONS W/DESCRIPTION CAT/ REQ. ACCUM. ITEM EXAM EXAM # CODE cov. 2-RPV-7442 B-C/ VOL. 60% DUE TO THE FLANGE VESSEL TO FLG Bl. 3 CONFIGURATION.
COMPONENT ID     CODE   CODE   % OF     LIMITATIONS
CIRC. WELD 31-STG-1240-B-D/ VOL. 86% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT OUTLET NOZZLE INSULATION SUPPORT. IRS 31-STG-1230-B-D/ VOL. 81% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT OUTLET NOZZLE INSULATION SUPPORT. IRS 31-STG-1220-B-D VOL. 75% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT OUTLET NOZZLE INSULATION SUPPORT. IRS 31-STG-1210-B-D/ VOL. 80% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT OUTLET NOZZLE INSULATION SUPPORT. IRS 29-STG-1240-B-D/ VOL. 84% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT INLET NOZZLE INSULATION SUPPORT. IRS 29-STG-1230-B-D/ VOL. 75% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT INLET NOZZLE **INSULATION SUPPORT. IRS PAGE 4 OF 9
  #    W/DESCRIPTION   CAT/   REQ. ACCUM.
ITEM   EXAM   EXAM
                          #           CODE cov.
002700  2-RPV-7442       B-C/   VOL. 60%     DUE TO THE FLANGE VESSEL TO FLG   Bl. 3                 CONFIGURATION.
CIRC. WELD 020600  31-STG-1240-     B-D/   VOL. 86%     DUE TO THE LOCATION IRS             B3.2                 OF A PERMANENT OUTLET NOZZLE                           INSULATION SUPPORT.
IRS 020700  31-STG-1230-     B-D/   VOL. 81%     DUE TO THE LOCATION IRS             B3.2                   OF A PERMANENT OUTLET NOZZLE                           INSULATION SUPPORT.
IRS 020800  31-STG-1220-     B-D   VOL. 75%     DUE TO THE LOCATION IRS             B3.2                   OF A PERMANENT OUTLET NOZZLE                           INSULATION SUPPORT.
IRS 020900  31-STG-1210-     B-D/   VOL. 80%     DUE TO THE LOCATION IRS             B3.2                   OF A PERMANENT OUTLET NOZZLE                           INSULATION SUPPORT.
IRS 021000  29-STG-1240-     B-D/   VOL. 84%     DUE TO THE LOCATION IRS             B3.2                 OF A PERMANENT INLET NOZZLE                           INSULATION SUPPORT.
IRS 021100  29-STG-1230-     B-D/   VOL. 75%     DUE TO THE LOCATION IRS             B3.2                   OF A PERMANENT INLET NOZZLE                         **INSULATION SUPPORT.
IRS PAGE 4 OF 9
 
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1


==SUMMARY==
==SUMMARY==
# 021200 02i300 050000 051200 052400 070000 *
COMPONENT ID     CODE   CODE   % OF   LIMITATIONS
* SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 1 COMPONENT ID CODE CODE % OF LIMITATIONS W/DESCRIPTION CAT/ REQ. ACCUM. ITEM EXAM EXAM # CODE cov. 29-STG-1220-B-D/ VOL. 66% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT INLET NOZZLE INSULATION SUPPORT. IRS 29-STG-1210-B-D/ VOL. 86% DUE TO THE LOCATION IRS ' B3.2 OF A PERMANENT INLET NOZZLE INSULATION SUPPORT. IRS 6-PR-1205-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4.1 & AND SAFE-END SAFE-END SUR. CONFIGURATION.
  #    W/DESCRIPTION   CAT/   REQ. ACCUM.
ITEM   EXAM   EXAM
                          #           CODE cov.
021200  29-STG-1220-     B-D/   VOL. 66%     DUE TO THE LOCATION IRS             B3.2                 OF A PERMANENT INLET NOZZLE                           INSULATION SUPPORT.
IRS 02i300  29-STG-1210-     B-D/   VOL. 86%     DUE TO THE LOCATION IRS       '
B3.2                 OF A PERMANENT INLET NOZZLE                           INSULATION SUPPORT.
IRS 050000  6-PR-1205-1     B-F/   VOL. 50%     DUE TO THE NOZZLE NOZZLE TO       B4.1   &             AND SAFE-END SAFE-END               SUR.           CONFIGURATION.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
6-PR-1204-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4.1 & AND SAFE-END SAFE-END SUR. CONFIGURATION.
051200  6-PR-1204-1     B-F/   VOL. 50%     DUE TO THE NOZZLE NOZZLE TO       B4.1   &             AND SAFE-END SAFE-END               SUR.           CONFIGURATION.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
6-PR-1203-1 B-F/ VOL. 64% DUE TO THE NOZZLE NOZZLE TO B4.1 & AND SAFE-END SAFE-END SUR. CONFIGURATION.
052400  6-PR-1203-1     B-F/   VOL. 64%     DUE TO THE NOZZLE NOZZLE TO       B4.1   &             AND SAFE-END SAFE-END               SUR.           CONFIGURATION.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
31-RC-1240-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4.1 & CONFIGURATION AND ELBOW SUR. ACOUSTIC PROPERTIES OF THE ELBOW. NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
070000  31-RC-1240-1     B-F/   VOL. 50%     DUE TO THE NOZZLE NOZZLE TO       B4.1   &             CONFIGURATION AND ELBOW                   SUR.           ACOUSTIC PROPERTIES OF THE ELBOW.
PAGE 5 OF 9
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
PAGE 5 OF 9
 
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1


==SUMMARY==
==SUMMARY==
# 070500 072300 074600 075100 076800 078200 SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 1 COMPONENT ID CODE CODE % OF LIMITATIONS W/DESCRIPTION CAT/ REQ. ACCUM. ITEM EXAM EXAM # CODE cov. 31-RC-1240-3 B-J/ VOL. 79% DUE TO THE ACOUSTIC PIPE TO ELBOW PROPERTIES OF THE ELBOW. 31-RC-1230-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4.1 & CONFIGURATION AND ELBOW SUR. ACOUSTIC PROPERTIES OF THE ELBOW. NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
COMPONENT ID     CODE   CODE   % OF   LIMITATIONS
3*1-RC-1220-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4.1 & CONFIGURATION AND ELBOW SUR. ACOUSTIC PROPERTIES OF THE ELBOW. NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
  #    W/DESCRIPTION   CAT/   REQ. ACCUM.
31-RC-1220-3 B-J/ VOL. 80% DUE TO THE ACOUSTIC PIPE TO ELBOW B4.5 PROPERTIES OF THE ELBOW. 31-RC-1210-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4/1 & CONFIGURATION AND ELBOW SUR. ACOUSTIC PROPERTIES OF THE ELBOW. NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
ITEM   EXAM   EXAM
31-RC-1210-4 B-J/ VOL. 77% DUE TO THE LOCATION ELBOW TO B4.5 OF THE BRANCH PIPE CONNECTION AND ACOUSTIC PROPERTIES OF THE ELBOW. PAGE 6 OF 9
                          #           CODE cov.
070500  31-RC-1240-3     B-J/   VOL. 79%     DUE TO THE ACOUSTIC PIPE TO ELBOW   B4.~                  PROPERTIES OF THE ELBOW.
072300  31-RC-1230-1     B-F/   VOL. 50%     DUE TO THE NOZZLE NOZZLE TO       B4.1   &             CONFIGURATION AND ELBOW                   SUR.           ACOUSTIC PROPERTIES OF THE ELBOW.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
074600  3*1-RC-1220-1   B-F/   VOL. 50%     DUE TO THE NOZZLE NOZZLE TO       B4.1   &             CONFIGURATION AND ELBOW                   SUR.           ACOUSTIC PROPERTIES OF THE ELBOW.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
075100  31-RC-1220-3     B-J/   VOL. 80%     DUE TO THE ACOUSTIC PIPE TO ELBOW   B4.5                 PROPERTIES OF THE ELBOW.
076800  31-RC-1210-1     B-F/   VOL. 50%     DUE TO THE NOZZLE NOZZLE TO       B4/1   &             CONFIGURATION AND ELBOW                   SUR.           ACOUSTIC PROPERTIES OF THE ELBOW.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
078200  31-RC-1210-4     B-J/   VOL. 77%     DUE TO THE LOCATION ELBOW TO         B4.5                 OF THE BRANCH PIPE                                   CONNECTION AND ACOUSTIC PROPERTIES OF THE ELBOW.
PAGE 6 OF 9
 
~- --~~-------
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1


==SUMMARY==
==SUMMARY==
. # 080000 081200 082200 083200 083300
. COMPONENT ID     CODE   CODE   % OF   LIMITATIONS
* SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 1 COMPONENT ID CODE CODE % OF LIMITATIONS W/DESCRIPTION CAT/ REQ. ACCUM. ITEM EXAM EXAM # CODE cov. 29-RC-1240-5 B-F/ VOL. 50% DUE TO THE NOZZLE ELBOW TO B4.1 & CONFIGURATION AND NOZZLE SUR. ACOUSTIC PROPERTIES OF THE ELBOW. NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
        #    W/DESCRIPTION   CAT/   REQ. ACCUM.
29-RC-1230-5 B-F/ VOL. 50% DUE TO THE NOZZLE ELBOW TO B4 .1 & CONFIGURATION AND NOZZLE SUR. ACOUSTIC PROPERTIES OF THE ELBOW. NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
ITEM   EXAM   EXAM
29-RC-1220-5 B-F/ VOL. 50% DUE TO THE NOZZLE ELBOW TO B4.1 & CONFIGURATION AND NOZZLE SUR. ACOUSTIC PROPERTIES OF THE ELBOW. NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
                                #           CODE cov.
29-RC-1210-4 B-J/ VOL. 75% DUE TO THE ACOUSTIC PIPE TO ELBOW B4.5 PROPERTIES OF THE ELBOW. 29-RC-1210-5 B-F/ VOL. 50% DUE TO THE NOZZLE ELBOW TO B4.1 & CONFIGURATION AND NOZZLE SUR. ACOUSTIC PROPERTIES OF THE ELBOW. NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
080000  29-RC-1240-5     B-F/   VOL. 50%     DUE TO THE NOZZLE ELBOW TO         B4.1   &             CONFIGURATION AND NOZZLE                 SUR.           ACOUSTIC PROPERTIES OF THE ELBOW.
PAGE 7 OF 9
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
081200  29-RC-1230-5     B-F/   VOL. 50%     DUE TO THE NOZZLE ELBOW TO         B4 .1   &             CONFIGURATION AND NOZZLE                 SUR.           ACOUSTIC PROPERTIES OF THE ELBOW.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
082200  29-RC-1220-5     B-F/   VOL. 50%     DUE TO THE NOZZLE ELBOW TO         B4.1   &             CONFIGURATION AND NOZZLE                 SUR.           ACOUSTIC PROPERTIES OF THE ELBOW.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
083200  29-RC-1210-4     B-J/   VOL. 75%     DUE TO THE ACOUSTIC PIPE TO ELBOW   B4.5                 PROPERTIES OF THE ELBOW.
083300  29-RC-1210-5     B-F/   VOL. 50%     DUE TO THE NOZZLE ELBOW TO         B4.1   &             CONFIGURATION AND NOZZLE                 SUR.           ACOUSTIC PROPERTIES OF THE ELBOW.
NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.
PAGE 7 OF 9
 
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1


==SUMMARY==
==SUMMARY==
# 083400 160750 172400 174550 179000 275040 275230 360010 360110 SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 1 COMPONENT ID CODE CODE % OF LIMITATIONS W/DESCRIPTION CAT/ REQ. ACCUM. ITEM EXAM EXAM # CODE cov. 27.5-RC-1240-B-J/ VOL. 74% DUE TO THE PUMP 1 B4.5 CONFIGURATION AND PUMP TO PIPE THE PROXIMITY OF A BRANCH CONNECTION.
COMPONENT ID     CODE   CODE % OF     LIMITATIONS
10-SJ-1241-8 B-J/ VOL. 50% DUE TO THE EXISTING ELBOW TO PIPE B4. 5 . PERMANENT PENETRATION SLEEVE. 6-SJ-1241-16 B-J/ VOL. 77% DUE TO THE VALVE VALVE TO PIPE B4.5 CONFIGURATION.
  #    W/DESCRIPTION   CAT/   REQ. ACCUM.
6*-sJ-1222-1 B-J/ VOL. 50% DUE TO THE REDUCER REDUCER TO B4.5 AND VALVE VALVE CONFIGURATION.
ITEM   EXAM EXAM
4-SJ-1282-10 B-J/ VOL. 83% DUE TO A PERMANENT PIPE TO ELBOW B4.5 STRUCTURAL I-BEAM MEMBER. 2-CVCT-2VS-1&2 C-C/ SUR. 89% DUE TO A PERMANENT VESSEL SUPPORT Cl. 3 I-BEAM VESSEL SUPPORT. 2-RCF-1 C-A/ VOL. 50% DUE TO THE WELD AND UPPER HEAD Cl.1 . FLANGE TO FLANGE CONFIGURATION.
                          #           CODE cov.
8-CV-2201-1 VOL. 85% DUE TO THE PROXIMITY VALVE TO PIPE C2.1 OF A PERMANENT PIPE RESTRAINT AND THE VALVE CONFIGURATION.
083400  27.5-RC-1240-   B-J/   VOL. 74%     DUE TO THE PUMP 1               B4.5                   CONFIGURATION AND PUMP TO PIPE                           THE PROXIMITY OF A BRANCH CONNECTION.
8-cv-2210-11 C-F/ VOL. 82% DUE TO THE PROXIMITY PIPE TO TEE C2.1 OF A PERMANENT PIPE RESTRAINT.  
160750  10-SJ-1241-8     B-J/   VOL. 50%     DUE TO THE EXISTING ELBOW TO PIPE   B4. 5 .               PERMANENT PENETRATION SLEEVE.
' PAGE 8 OF 9
172400  6-SJ-1241-16     B-J/   VOL. 77%     DUE TO THE VALVE VALVE TO PIPE   B4.5                   CONFIGURATION.
174550  6*-sJ-1222-1     B-J/   VOL. 50%     DUE TO THE REDUCER REDUCER TO       B4.5                   AND VALVE VALVE                                   CONFIGURATION.
179000  4-SJ-1282-10     B-J/   VOL. 83%     DUE TO A PERMANENT PIPE TO ELBOW   B4.5                   STRUCTURAL I-BEAM MEMBER.
275040  2-CVCT-2VS-1&2   C-C/   SUR. 89%     DUE TO A PERMANENT VESSEL SUPPORT   Cl. 3                 I-BEAM VESSEL SUPPORT.
275230  2-RCF-1         C-A/   VOL. 50%     DUE TO THE WELD AND UPPER HEAD       Cl.1                 . FLANGE TO FLANGE                               CONFIGURATION.
360010  8-CV-2201-1     C~F/    VOL. 85%     DUE TO THE PROXIMITY VALVE TO PIPE   C2.1                   OF A PERMANENT PIPE RESTRAINT AND THE VALVE CONFIGURATION.
360110  8-cv-2210-11     C-F/   VOL. 82%     DUE TO THE PROXIMITY PIPE TO TEE     C2.1                   OF A PERMANENT PIPE RESTRAINT.
PAGE 8 OF 9
 
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1


==SUMMARY==
==SUMMARY==
# 380050 384630 500810 502410 503340 573383
COMPONENT ID     CODE   CODE   % OF   LIMITATIONS
* SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 1 COMPONENT ID CODE CODE % OF LIMITATIONS W/DESCRIPTION CAT/ REQ. ACCUM. ITEM EXAM EXAM  
  #    W/DESCRIPTION   CAT/   REQ. ACCUM.
# CODE cov. 34-MS-2241-C-E-1/ SUR. 25% DUE TO THE PROXIMITY 2PS-1&2 C2.5 OF THE PERMANENTLY INSTALLED PIPE SUPPORT. 6-MS-2231-4 C-G/ VOL. 89% DUE TO THE VALVE PIPE TO VALVE C2.1 CONFIGURATION.
ITEM   EXAM   EXAM
6-PR-2203-2 C-F/ VOL. 60% DUE TO THE PROXIMITY ELBOW TO PIPE C2.1 OF A PERMANENTLY INSTALLED PIPE SUPPORT. 8*-RH-2273-1 C-F/ VOL. 50% DUE TO THE VALVE TEE TO VALVE C2.1 AND TEE CONFIGURATION.
                          #           CODE cov.
8-RH-2216-4 C-F/ VOL. 50% DUE TO THE FLANGE FLANGE TO C2.1 CONFIGURATION.
380050  34-MS-2241-     C-E-1/ SUR. 25%     DUE TO THE PROXIMITY 2PS-1&2         C2.5                 OF THE PERMANENTLY INSTALLED PIPE SUPPORT.
VALVE 12-SJ-2252-38 C-E-1/ SUR. 71% DUE TO PROXIMITY PIPE SUPPORT C2.5 OF A PERMANENTLY INSTALLED PIPE SUPPORT. PAGE 9 OF 9 ---------------------------
384630  6-MS-2231-4     C-G/   VOL. 89%     DUE TO THE VALVE PIPE TO VALVE   C2.1                 CONFIGURATION.
s9EM UNIT 2 -lST INSPECTIO.NTERVAL FINAL RELIEF REQUEST -# 2 COMPONENT DESCRIPTION:
500810  6-PR-2203-2     C-F/   VOL. 60%     DUE TO THE PROXIMITY ELBOW TO PIPE   C2.1                 OF A PERMANENTLY INSTALLED PIPE SUPPORT.
Pressure Retaining Valves listed below ASME CODE CLASS: ASME Section XI, Class 1 Valves ASME EXAMINATION REQUIREMENTS:
502410  8*-RH-2273-1     C-F/   VOL. 50%     DUE TO THE VALVE TEE TO VALVE     C2.1                 AND TEE CONFIGURATION.
Relief is being requested from the visual (VT) examination requirements of Table IWB-2500 Examination category B-M-2 Item No. B6.7. BASIS FOR RELIEF: The disassembly of functional valves during the first ten year inspection interval for the sole purpose of performing a visual examination of the internals would have increased the likelihood for component failure in the future and was contrary to good maintenance practices.
503340  8-RH-2216-4     C-F/   VOL. 50%     DUE TO THE FLANGE FLANGE TO       C2.1                 CONFIGURATION.
Considering the uncertainty of the benefit involved with this examination, it is difficult to justify the additional radiation exposure that would be incurred as a result of the disassembly, examination and reassembly these valves. For example, estimates from radiation surveys performed on and around valve 2RH1 indicate that the total job dose that would be received in disassembling, examining and reassembling this valve be in excess of 4 man-rem. Public Service Electric & Gas feels implementation of this examination is impractical for valves not scheduled for disassembly because of preventive or corrective maintenance.
VALVE 573383  12-SJ-2252-38   C-E-1/ SUR. 71%     DUE TO T~E PROXIMITY PIPE SUPPORT     C2.5                 OF A PERMANENTLY INSTALLED PIPE SUPPORT.
In the 1989 and later editions of Section XI, this examination is only required to be performed on valves scheduled for disassembly for maintenance purposes.
PAGE 9 OF 9
 
s9EM UNIT 2 - lST INSPECTIO.NTERVAL FINAL RELIEF REQUEST - # 2 COMPONENT DESCRIPTION:
Pressure Retaining Valves listed below ASME CODE CLASS:
ASME Section XI, Class 1 Valves ASME EXAMINATION REQUIREMENTS:
Relief is being requested from the visual (VT) examination requirements of Table IWB-2500 Examination category B-M-2 Item No.
B6.7.
BASIS FOR RELIEF:
The disassembly of functional valves during the first ten year inspection interval for the sole purpose of performing a visual examination of the internals would have increased the likelihood for component failure in the future and was contrary to good maintenance practices. Considering the uncertainty of the benefit involved with this examination, it is difficult to justify the additional radiation exposure that would be incurred as a result of the disassembly, examination and reassembly these valves. For example, estimates from radiation surveys performed on and around valve 2RH1 indicate that the total job dose that would be received in disassembling, examining and reassembling this valve be in excess of 4 man-rem. Public Service Electric & Gas feels implementation of this examination is impractical for valves not scheduled for disassembly because of preventive or corrective maintenance. In the 1989 and later editions of Section XI, this examination is only required to be performed on valves scheduled for disassembly for maintenance purposes.
ALTERNATIVE EXAMINATION:
ALTERNATIVE EXAMINATION:
As required by the 1989 edition of Section XI, table IWB-2500 Category B-M-2, Item Bl2.50 examinations were performed when the valve was disassembled for maintenance, repair, or volumetric examination.
As required by the 1989 edition of Section XI, table IWB-2500 Category B-M-2, Item Bl2.50 examinations were performed when the valve was disassembled for maintenance, repair, or volumetric examination.
Also in accordance with the 1989 Edition IWB-2430 (a) when examinations reveal flaws or relevant conditions that exceed the acceptance standards, examinations were extended to include additional valves. Utilizing the above requirements, the following valves, listed by group were .never disassembled during the first inspection interval and therefore, the internals were not visually examined.
Also in accordance with the 1989 Edition IWB-2430 (a) when examinations reveal flaws or relevant conditions that exceed the acceptance standards, examinations were extended to include additional valves.
Valve Valve Valve Valve Group Group Group Group 2RH1 2RH26 21SJ49 21SJ54 2RH2 22SJ49 22SJ54 23SJ54 24SJ54 PAGE 1 OF 1
Utilizing the above requirements, the following valves, listed by group were .never disassembled during the first inspection interval and therefore, the internals were not visually examined.
*
Valve           Valve           Valve           Valve Group           Group           Group           Group 2RH1             2RH26           21SJ49           21SJ54 2RH2                             22SJ49           22SJ54 23SJ54 24SJ54 PAGE 1 OF 1
* SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 3 COMPONENT DESCRIPTION:
 
Reactor Pressure Vessel and Nozzles listed on the attached list ASME CODE CLASS: ASME Section XI, Class 1 Vessel ASME EXAMINATION REQUIREMENTS:
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 3 COMPONENT DESCRIPTION:
Relief is being requested from the ultrasonic (UT) examination requirements of Table IWB-2500 Examination Category B-D, Item Bl.4. BASIS FOR RELIEF: Due to the geometry of the reactor vessel, 100% of the Code required coverage of all the applicable welds cannot be obtained.
Reactor Pressure Vessel and Nozzles listed on the attached list ASME CODE CLASS:
These examinations are performed from the inside diameter utilizing automated UT equipment.
ASME Section XI, Class 1 Vessel ASME EXAMINATION REQUIREMENTS:
No examinations can be performed from the outside diameter surface, Due to the design of the building structure surrounding the reactor vessel making access impossible.
Relief is being requested from the ultrasonic (UT) examination requirements of Table IWB-2500 Examination Category B-D, Item Bl.4.
BASIS FOR RELIEF:
Due to the geometry of the reactor vessel, 100% of the Code required coverage of all the applicable welds cannot be obtained.
These examinations are performed from the inside diameter utilizing automated UT equipment. No examinations can be performed from the outside diameter surface, Due to the design of the building structure surrounding the reactor vessel making access impossible.
ALTERNATIVE EXAMINATION:
ALTERNATIVE EXAMINATION:
There are no alternative examinations proposed for these examinations  
There are no alternative examinations proposed for these examinations ..
.. PAGE 1 OF 2
PAGE 1 OF 2
 
SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 3


==SUMMARY==
==SUMMARY==
# 002900 003200 003300 003600 *
COMPONENT ID     CODE   CODE   % OF   LIMITATIONS
* SALEM UNIT 2 -lST INSPECTION INTERVAL FINAL RELIEF REQUEST -# 3 COMPONENT ID CODE CODE % OF LIMITATIONS W/DESCRIPTION CAT/ REQ. ACCUM. ITEM EXAM EXAM # CODE cov. 29-RCN-1240 B-D/ VOL. 50% DUE TO THE INTEGRAL OUTLET NOZZLE Bl.4 EXTENSION AND @ 22-DEG. GEOMETRIC SHADOWING.
  #    W/DESCRIPTION   CAT/   REQ. ACCUM.
29-RCN-1230 B-D/ VOL. 50% DUE TO THE INTEGRAL OUTLET NOZZLE Bl.4 EXTENSION AND @ 158-DEG. GEOMETRIC SHADOWING.
ITEM   EXAM   EXAM
20-RCN-1230 B-D/ VOL. 50% DUE TO THE INTEGRAL OUTLET NOZZLE Bl.4 EXTENSION AND @ 203-DEG. GEOMETRIC SHADOWING.
                          #           CODE cov.
29-RCN-1230 B-D VOL. 50% DUE TO THE INTEGRAL OUTLET NOZZLE Bl.4 EXTENSION AND @ 338-DEG. GEOMETRIC SHADOWING.
002900  29-RCN-1240     B-D/   VOL. 50%     DUE TO THE INTEGRAL OUTLET NOZZLE   Bl.4                 EXTENSION AND
        @ 22-DEG.                             GEOMETRIC SHADOWING.
003200  29-RCN-1230     B-D/   VOL. 50%     DUE TO THE INTEGRAL OUTLET NOZZLE   Bl.4                 EXTENSION AND
        @ 158-DEG.                             GEOMETRIC SHADOWING.
003300  20-RCN-1230     B-D/   VOL. 50%     DUE TO THE INTEGRAL OUTLET NOZZLE   Bl.4                 EXTENSION AND
        @ 203-DEG.                             GEOMETRIC SHADOWING.
003600  29-RCN-1230     B-D   VOL. 50%     DUE TO THE INTEGRAL OUTLET NOZZLE   Bl.4                 EXTENSION AND
        @ 338-DEG.                             GEOMETRIC SHADOWING.
PAGE 2 OF 2}}
PAGE 2 OF 2}}

Latest revision as of 05:04, 3 February 2020

Responds to RAI Re ISI Program First 10-Year Interval Final Relief Request on Limited Volumetric Exam Coverage
ML18100A776
Person / Time
Site: Salem PSEG icon.png
Issue date: 12/10/1993
From: Hagan J
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N93194, NUDOCS 9312280127
Download: ML18100A776 (19)
v • d • e


Text

      • .

Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations DECl 0 1993 NLR-N93194 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM FIRST 10-YEAR INTERVAL, FINAL RELIEF REQUESTS SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311 By letter dated September 28, 1992, Public Service Electric & Gas Company (PSE&G) submitted the Final Relief for the first 10-year interval for Salem Unit No. 2. By letter dated October 5, 1993, the NRC requested additional information to support PSE&G's submittal for Salem Unit No. 2 Inservice Inspection Program.

Attachment 1 contains PSE&G's response to the requests for additional information. Attachment 2 contains the revised relief request pages.

Should there be any questions with regard to this submittal, please do not hesitate to contact us.

  • ')')001-8 t.. ..J .. ll}* .

Document Control Desk 2

  • DEC 10 1993 NLR-N93194 C Mr. J. c. Stone Licensing Project Manager Mr. c. Marschall Senior Resident Inspector Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Manager IV New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

NLR-N93194 ATTACHMENT 1 SALEM UNIT NO. 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM FIRST 10-YEAR INTERVAL FINAL RELIEF REQUESTS The following is a response to the NRC request for additional information (RAI), dated October 5, 1993.

REQUEST A Final Relief Request #1 includes requests for relief due to limited volumetric examination coverage. In February, 1990, the licensee requested and received approval for the use of ASME Code Case N-460, which allows a reduction of examination coverage not to exceed 10 percent of the required volume.

The licensee has provided a table describing the examination areas for-which relief is requested. Under the table heading "LIMITATION", the licensee gives the percent of volumetric examination area that received volumetric coverage followed by the statement that coverage was obtained in at least one direction. Based on Code Case N-460, the licensee states that for some of the limited examinations listed in this table, relief would no longer be required.

From the information provided, the extent to which Code required volume coverage being obtained is unclear to the staff; therefore, the examination areas that would not require relief based on Code Case N-460 cannot be determined. Code examination coverage is satisfied when the ultrasonic beam passes through the cross-sectional volume of a specified examination area in two directions for the specified Code examination length. If coverage is obtained in at least one direction, as stated, but coverage in the second direction is not quantified, the Code required coverage obtained is not known, and the basis for the claim that relief may no longer be required is not clear.

The staff requests that the licenseer.provide the accumulative examination volume coverage based on; (1) the percent of ,volume coverage obtained by two directional, beam component coverage for scans perpendicular to the weld; (2) the percent of volume coverage obtained for scans performed with the beam component parallel to the weld; and (3) the percent of the total length scanned.

RESPONSE A See below

NLR-N93194

  • 2 REQUEST B In the table for Final Relief Request #1, it.appears that examination areas 29-STG-1240-IRS and 6-SJ-1241-16 both have duplicate examination areas identified under a separate Sum #.

Please clarify the apparent duplication.

RESPONSES A AND B The attached final Relief Request #1 has been revised. These revisions include:

1. Only those welds requiring relief when applying Code Case N-460 are included. Welds receiving accumulative examination average of 90% or greater when incorporating the NRC guidance in paragraph 2A of the RAI have been deleted.

2~ The "Alternative Examination" section has been revised to present PSE&G's position on not performing alternate examinations.

3. The end of the "Basis for Relief" section has been revised to present the process on how PSE&G identified what belonged on the final relief request list.
4. The Relief Request Table was revised to include the following:
a. Editor.:i,.al corrections were made on the table, including corrections to examination areas 29-STG-1240-IRS and 6-SJ-1241-16 as identified in the RAI.
b. The remarks column and basis column have been removed with the pertinent information shown in a "Limitation" column.
c. The Alternate Examination column has been removed.

There are no alternate examinations.proposed for any of the areas.

d. A "% of Accum. Exam. Code Coverage" column is now included. These percentages have been calculated in accordance with the NRC staff request identified above.

NLR-N93194 3 REQUEST C Final Relief Request #2, Alternative Examination, states: "Public Service Electric and Gas examined at least one valve in a valve group (valves of similar design and function) where at least one valve in the group was disassembled for maintenance purposes during the inspection interval. If any valve was found to require corrective action, additional valves in that group would be disassembled and inspected as required by Section XI". It is further stated in the second paragraph under "Alternative Examination", that the aforementioned statement is a guideline.

It is unclear to the staff whether the guideline for the "Alternative Examination" is a statement of examinations performed or a statement of requirement (i.e. will examine at least one valve ..... ). Please clarify the extent of the Code required examinations that were completed during the first 10-year interval.

RESPONSE C In order to more clearly state PSE&G's position, the "Alternative Examination" section of Relief Request #2 has been revised. The revision includes a description of the use of 19S9 Edition of Section XI, Table IWB-2500,.Category B-M-2, item B12.50.

REQUEST D Included in Final Relief ReqUes( #3*is a referenc~ to Examination Category B-A, Item Number B1.1, for examination of reactor vessel welds in the beltline region. It appears that the licensee is requesting credit for examination area coverage of Category B-A welds that exceeded the Code requirements, as an alternative examination for relief associated with Examination Category B-B and B-D. The licensee states that for vessel welds in the beltline region, 100 percent examination of all required welds was attempted.

Although the licensee maximized coverage on the category B-A examination volume, this does not constitute an alternative examination for other examination categories. The licensee should include alternative examinations that are applicable to the examination category and examination areas for which Code required coverage is not obtained. Please provide a revised relief request that addresses any alternative examinations for limitations associated with Examination Categories B-B and B-D.

NLR-N93194

  • 4 RESPONSE D See below REQUEST E Final Relief Request #3 has a table that lists percents of coverage for "Beam Directions," cw, ccw, Up, Down, and Toward RX.

Refer to "A" above and provide the percent of examination area coverage obtained.

RESPONSES D AND E In order to more clearly state PSE&G's position, Relief Request

  1. 3 has been revised. The revision includes a re-write of the "Basis for Relief" section and the "Alternative Examination" section, also revisions to the table listing welds requiring relief were made, which include:
a. Adding a "% of Accum. Exam. Code Coverage" column with percent coverage as described previously.
b. Deleting the "Remarks" column and including pertinent information in a " Limitations" column.

As an additional point of clarification, PSE&G has not, or proposed to take credit for excess examination coverage obtained in category B-A as an alternative to a relief request for examinations in category B-B , B-D or any other examination category.

ATTACHMENT 2 REVISED FINAL RELIEF REQUESTS

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1 COMPONENT DESCRIPTION:

Pressure vessels, components, and piping welds and integrally welded attachments subject to surface and/or volumetric examination listed on the attached table.

ASME CODE CLASS:

ASME Section XI Class 1, 2 welds.

ASME EXAMINATION REQUIREMENTS:

In accordance with the examination requirements of Subsection IWB, Table IWB-2500 of examination categories: B-C, B-D, B-F, B-J and Subsection IWC, Table IWC-2520 examination categories: C-A, c-c, C-E-1, c-F and C-G when an examination (surface or volumetric) is performed, essentially 100% of the weld length is required to be inspected.

BASIS FOR RELIEF:

The ASME Code requires surface and volumetric examination of various Class 1 vessel and piping welds as defined in Paragraph IWB~2500 and various Class 2 vessel and piping welds as defined in Paragraph IWC-2500.

During the inservice examinations performed at SALEM. NUCLEAR GENERATING STATION UNIT 2 it has been the position of PUBLIC SERVICE ELECTRIC AND GAS COMPANY that examinations which could not be performed completely, (i.e., performed from two (2) directions because of component configuration or restrictions from permanent structures) the examination would be performed to the greatest extent possible and whatever limitation that existed be documented.

It has also been PUBLIC SERVICE ELECTRIC AND GAS COMPANY'S position that when there was a "removable" structure, (i.e., hanger, support) these items were removed, when practical, providing greater access to the component being examined. The basis for this position. is as follows:*

The Code of Federal Regulations, 10CFR50, "Domestic Licensing of Production and Utilization Facilities" defines those requirements which must be adhered to by the utility in order to be issued and maintain an operating license. This document states in Paragraph 55a(g) that inservice inspections shall meet the requirements of the ASME Boiler & Pressure Vessel Code.

Throughout 10CFR50 numerous references are made allowing performance of these inspections "to the extent practical".

PAGE 1 OF 9

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1 Some of the specific paragraphs are:

Paragraph 50.55a(g)4 states that throughout the service life of a nuclear power facility components which are classified as ASME Code Class 1, 2 and 3 shall meet the requirements of Section XI of the ASME B&PV Code, "to the extent practical within the limitations of design, geometry and materials of construction of the components".

Paragraph 50.55a(2)i of this document states that inspection of systems and components is performed "to the maximum extent practical, in accordance with generally recognized codes and standards" i.e., ASME Boiler & Pressure Code.

Paragraph 50.55g(l) states that components (including supports) shall meet the requirements of (ASME Code) "to the extent practical".

The ASME Code itself provides allowance for "limited" examinations.

The 1986 Edition,Section V, Article 4, Paragraph T-441.3.2.4 states:

"Whenever feasible, the scanning of the examination volume shall be carried out from both sides of the weld on the same surface. Where configuration of adjacent parts of the component are such that the scanning from both sides is not feasible, this fact shall be included in the report of the examination".

PUBLIC SERVICE ELECTRIC AND GAS COMPANY has utilized approved technical procedures written in accordance with the applicable Section/Paragraph of the ASME Code in regard to the area/volume to be examined and the specified requirements of the examination for the 1st inspection interval. Recognizing that because of component design, construction, etc. there are cases when examinations can only be performed "to the greatest extent possible". PUBLIC SERVICE ELECTRIC

& GAS has previously submitted a list of those identified limitations after performing the preservice examination. Subsequently Weld selection for this interval was made to minimize known limitations identified during preservice examination (PSI). For limitations found during the 1st inservice inspection interval, additional, components were scheduled and examined, when possible, to meet the allocation table requirements of ASME Section XI 1974 Edition, Summer 75 Addenda.

PSE&G requested and received approval for use of ASME Code Case N-460 in February, 1990 allowing a reduction of examination coverage not to exceed 10% of the required volume. Utilizing that criteria and the additional guidance found in 2.A of the NRC RAI, dated October 5, 1993 on accumulative examination volume coverage, PSE&G has been able to minimize those components requiring relief.

PAGE, 2 OF 9

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1 ALTERNATE EXAMINATION:

No alternate examinations were performed on the components listed in the attached table for the following reasons:

1. Where appropriate,Section XI had already required surface examinations in addition to volumetric examinations.
2. Performing surface examinations on areas with limitations were not justified when considering the following:

a) all examination areas received coverage greater than 50% of the required volume.

b) The Code has identified the examination area, to be the lower 1/3 of the weld.

  • performing a surface examination on the outside surface gives no information on the condition of the lower 1/3 of the weld.

c) Additional radiation exposure to personnel.

PAGE* 3 OF 9

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1

SUMMARY

COMPONENT ID CODE CODE  % OF LIMITATIONS

  1. W/DESCRIPTION CAT/ REQ. ACCUM.

ITEM EXAM EXAM

  1. CODE cov.

002700 2-RPV-7442 B-C/ VOL. 60% DUE TO THE FLANGE VESSEL TO FLG Bl. 3 CONFIGURATION.

CIRC. WELD 020600 31-STG-1240- B-D/ VOL. 86% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT OUTLET NOZZLE INSULATION SUPPORT.

IRS 020700 31-STG-1230- B-D/ VOL. 81% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT OUTLET NOZZLE INSULATION SUPPORT.

IRS 020800 31-STG-1220- B-D VOL. 75% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT OUTLET NOZZLE INSULATION SUPPORT.

IRS 020900 31-STG-1210- B-D/ VOL. 80% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT OUTLET NOZZLE INSULATION SUPPORT.

IRS 021000 29-STG-1240- B-D/ VOL. 84% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT INLET NOZZLE INSULATION SUPPORT.

IRS 021100 29-STG-1230- B-D/ VOL. 75% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT INLET NOZZLE **INSULATION SUPPORT.

IRS PAGE 4 OF 9

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1

SUMMARY

COMPONENT ID CODE CODE  % OF LIMITATIONS

  1. W/DESCRIPTION CAT/ REQ. ACCUM.

ITEM EXAM EXAM

  1. CODE cov.

021200 29-STG-1220- B-D/ VOL. 66% DUE TO THE LOCATION IRS B3.2 OF A PERMANENT INLET NOZZLE INSULATION SUPPORT.

IRS 02i300 29-STG-1210- B-D/ VOL. 86% DUE TO THE LOCATION IRS '

B3.2 OF A PERMANENT INLET NOZZLE INSULATION SUPPORT.

IRS 050000 6-PR-1205-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4.1 & AND SAFE-END SAFE-END SUR. CONFIGURATION.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

051200 6-PR-1204-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4.1 & AND SAFE-END SAFE-END SUR. CONFIGURATION.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

052400 6-PR-1203-1 B-F/ VOL. 64% DUE TO THE NOZZLE NOZZLE TO B4.1 & AND SAFE-END SAFE-END SUR. CONFIGURATION.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

070000 31-RC-1240-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4.1 & CONFIGURATION AND ELBOW SUR. ACOUSTIC PROPERTIES OF THE ELBOW.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

PAGE 5 OF 9

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1

SUMMARY

COMPONENT ID CODE CODE  % OF LIMITATIONS

  1. W/DESCRIPTION CAT/ REQ. ACCUM.

ITEM EXAM EXAM

  1. CODE cov.

070500 31-RC-1240-3 B-J/ VOL. 79% DUE TO THE ACOUSTIC PIPE TO ELBOW B4.~ PROPERTIES OF THE ELBOW.

072300 31-RC-1230-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4.1 & CONFIGURATION AND ELBOW SUR. ACOUSTIC PROPERTIES OF THE ELBOW.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

074600 3*1-RC-1220-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4.1 & CONFIGURATION AND ELBOW SUR. ACOUSTIC PROPERTIES OF THE ELBOW.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

075100 31-RC-1220-3 B-J/ VOL. 80% DUE TO THE ACOUSTIC PIPE TO ELBOW B4.5 PROPERTIES OF THE ELBOW.

076800 31-RC-1210-1 B-F/ VOL. 50% DUE TO THE NOZZLE NOZZLE TO B4/1 & CONFIGURATION AND ELBOW SUR. ACOUSTIC PROPERTIES OF THE ELBOW.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

078200 31-RC-1210-4 B-J/ VOL. 77% DUE TO THE LOCATION ELBOW TO B4.5 OF THE BRANCH PIPE CONNECTION AND ACOUSTIC PROPERTIES OF THE ELBOW.

PAGE 6 OF 9

~- --~~-------

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1

SUMMARY

. COMPONENT ID CODE CODE  % OF LIMITATIONS

  1. W/DESCRIPTION CAT/ REQ. ACCUM.

ITEM EXAM EXAM

  1. CODE cov.

080000 29-RC-1240-5 B-F/ VOL. 50% DUE TO THE NOZZLE ELBOW TO B4.1 & CONFIGURATION AND NOZZLE SUR. ACOUSTIC PROPERTIES OF THE ELBOW.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

081200 29-RC-1230-5 B-F/ VOL. 50% DUE TO THE NOZZLE ELBOW TO B4 .1 & CONFIGURATION AND NOZZLE SUR. ACOUSTIC PROPERTIES OF THE ELBOW.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

082200 29-RC-1220-5 B-F/ VOL. 50% DUE TO THE NOZZLE ELBOW TO B4.1 & CONFIGURATION AND NOZZLE SUR. ACOUSTIC PROPERTIES OF THE ELBOW.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

083200 29-RC-1210-4 B-J/ VOL. 75% DUE TO THE ACOUSTIC PIPE TO ELBOW B4.5 PROPERTIES OF THE ELBOW.

083300 29-RC-1210-5 B-F/ VOL. 50% DUE TO THE NOZZLE ELBOW TO B4.1 & CONFIGURATION AND NOZZLE SUR. ACOUSTIC PROPERTIES OF THE ELBOW.

NOTE: 100% OF THE SURFACE EXAM WAS PERFORMED.

PAGE 7 OF 9

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1

SUMMARY

COMPONENT ID CODE CODE  % OF LIMITATIONS

  1. W/DESCRIPTION CAT/ REQ. ACCUM.

ITEM EXAM EXAM

  1. CODE cov.

083400 27.5-RC-1240- B-J/ VOL. 74% DUE TO THE PUMP 1 B4.5 CONFIGURATION AND PUMP TO PIPE THE PROXIMITY OF A BRANCH CONNECTION.

160750 10-SJ-1241-8 B-J/ VOL. 50% DUE TO THE EXISTING ELBOW TO PIPE B4. 5 . PERMANENT PENETRATION SLEEVE.

172400 6-SJ-1241-16 B-J/ VOL. 77% DUE TO THE VALVE VALVE TO PIPE B4.5 CONFIGURATION.

174550 6*-sJ-1222-1 B-J/ VOL. 50% DUE TO THE REDUCER REDUCER TO B4.5 AND VALVE VALVE CONFIGURATION.

179000 4-SJ-1282-10 B-J/ VOL. 83% DUE TO A PERMANENT PIPE TO ELBOW B4.5 STRUCTURAL I-BEAM MEMBER.

275040 2-CVCT-2VS-1&2 C-C/ SUR. 89% DUE TO A PERMANENT VESSEL SUPPORT Cl. 3 I-BEAM VESSEL SUPPORT.

275230 2-RCF-1 C-A/ VOL. 50% DUE TO THE WELD AND UPPER HEAD Cl.1 . FLANGE TO FLANGE CONFIGURATION.

360010 8-CV-2201-1 C~F/ VOL. 85% DUE TO THE PROXIMITY VALVE TO PIPE C2.1 OF A PERMANENT PIPE RESTRAINT AND THE VALVE CONFIGURATION.

360110 8-cv-2210-11 C-F/ VOL. 82% DUE TO THE PROXIMITY PIPE TO TEE C2.1 OF A PERMANENT PIPE RESTRAINT.

PAGE 8 OF 9

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 1

SUMMARY

COMPONENT ID CODE CODE  % OF LIMITATIONS

  1. W/DESCRIPTION CAT/ REQ. ACCUM.

ITEM EXAM EXAM

  1. CODE cov.

380050 34-MS-2241- C-E-1/ SUR. 25% DUE TO THE PROXIMITY 2PS-1&2 C2.5 OF THE PERMANENTLY INSTALLED PIPE SUPPORT.

384630 6-MS-2231-4 C-G/ VOL. 89% DUE TO THE VALVE PIPE TO VALVE C2.1 CONFIGURATION.

500810 6-PR-2203-2 C-F/ VOL. 60% DUE TO THE PROXIMITY ELBOW TO PIPE C2.1 OF A PERMANENTLY INSTALLED PIPE SUPPORT.

502410 8*-RH-2273-1 C-F/ VOL. 50% DUE TO THE VALVE TEE TO VALVE C2.1 AND TEE CONFIGURATION.

503340 8-RH-2216-4 C-F/ VOL. 50% DUE TO THE FLANGE FLANGE TO C2.1 CONFIGURATION.

VALVE 573383 12-SJ-2252-38 C-E-1/ SUR. 71% DUE TO T~E PROXIMITY PIPE SUPPORT C2.5 OF A PERMANENTLY INSTALLED PIPE SUPPORT.

PAGE 9 OF 9

s9EM UNIT 2 - lST INSPECTIO.NTERVAL FINAL RELIEF REQUEST - # 2 COMPONENT DESCRIPTION:

Pressure Retaining Valves listed below ASME CODE CLASS:

ASME Section XI, Class 1 Valves ASME EXAMINATION REQUIREMENTS:

Relief is being requested from the visual (VT) examination requirements of Table IWB-2500 Examination category B-M-2 Item No.

B6.7.

BASIS FOR RELIEF:

The disassembly of functional valves during the first ten year inspection interval for the sole purpose of performing a visual examination of the internals would have increased the likelihood for component failure in the future and was contrary to good maintenance practices. Considering the uncertainty of the benefit involved with this examination, it is difficult to justify the additional radiation exposure that would be incurred as a result of the disassembly, examination and reassembly these valves. For example, estimates from radiation surveys performed on and around valve 2RH1 indicate that the total job dose that would be received in disassembling, examining and reassembling this valve be in excess of 4 man-rem. Public Service Electric & Gas feels implementation of this examination is impractical for valves not scheduled for disassembly because of preventive or corrective maintenance. In the 1989 and later editions of Section XI, this examination is only required to be performed on valves scheduled for disassembly for maintenance purposes.

ALTERNATIVE EXAMINATION:

As required by the 1989 edition of Section XI, table IWB-2500 Category B-M-2, Item Bl2.50 examinations were performed when the valve was disassembled for maintenance, repair, or volumetric examination.

Also in accordance with the 1989 Edition IWB-2430 (a) when examinations reveal flaws or relevant conditions that exceed the acceptance standards, examinations were extended to include additional valves.

Utilizing the above requirements, the following valves, listed by group were .never disassembled during the first inspection interval and therefore, the internals were not visually examined.

Valve Valve Valve Valve Group Group Group Group 2RH1 2RH26 21SJ49 21SJ54 2RH2 22SJ49 22SJ54 23SJ54 24SJ54 PAGE 1 OF 1

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 3 COMPONENT DESCRIPTION:

Reactor Pressure Vessel and Nozzles listed on the attached list ASME CODE CLASS:

ASME Section XI, Class 1 Vessel ASME EXAMINATION REQUIREMENTS:

Relief is being requested from the ultrasonic (UT) examination requirements of Table IWB-2500 Examination Category B-D, Item Bl.4.

BASIS FOR RELIEF:

Due to the geometry of the reactor vessel, 100% of the Code required coverage of all the applicable welds cannot be obtained.

These examinations are performed from the inside diameter utilizing automated UT equipment. No examinations can be performed from the outside diameter surface, Due to the design of the building structure surrounding the reactor vessel making access impossible.

ALTERNATIVE EXAMINATION:

There are no alternative examinations proposed for these examinations ..

PAGE 1 OF 2

SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 3

SUMMARY

COMPONENT ID CODE CODE  % OF LIMITATIONS

  1. W/DESCRIPTION CAT/ REQ. ACCUM.

ITEM EXAM EXAM

  1. CODE cov.

002900 29-RCN-1240 B-D/ VOL. 50% DUE TO THE INTEGRAL OUTLET NOZZLE Bl.4 EXTENSION AND

@ 22-DEG. GEOMETRIC SHADOWING.

003200 29-RCN-1230 B-D/ VOL. 50% DUE TO THE INTEGRAL OUTLET NOZZLE Bl.4 EXTENSION AND

@ 158-DEG. GEOMETRIC SHADOWING.

003300 20-RCN-1230 B-D/ VOL. 50% DUE TO THE INTEGRAL OUTLET NOZZLE Bl.4 EXTENSION AND

@ 203-DEG. GEOMETRIC SHADOWING.

003600 29-RCN-1230 B-D VOL. 50% DUE TO THE INTEGRAL OUTLET NOZZLE Bl.4 EXTENSION AND

@ 338-DEG. GEOMETRIC SHADOWING.

PAGE 2 OF 2

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