ML18100B231

Requests Approval to Use Encl Code Case N-508, Rotation of Serviced Snubbers & Pressure Relief Valves for Purposes of Testing, Per 10CFR50.55a,Section (a)(3) & Footnote 6

ML18100B231
Person / Time
Site:	Salem, Hope Creek
Issue date:	07/21/1994
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N94064, NUDOCS 9407290158
Download: ML18100B231 (3)

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' / *, 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 JUL 211994 NLR-N94064 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

ASME CODE CASE N-508 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311 AND 50-354 Public Service Electric and Gas Company (PSE&G) requests approval, per 10CFR.50.55a, Section (a) (3) and footnote 6, to use ASME Code Case N-508 (copy attached) for Salem and Hope Creek Generating Stations. This ASME Section XI Code Case entitled,"Rotation of Serviced Snubbers and Pressure Relief Valves for the Purposes of Testing," was approved by ASME and published on March 11, 1993. The use of this Code Case is not presently referenced in NRC Regulatory Guide 1.147,"Inservice Inspection Code Case Acceptability," Revision 10, dated July 1993.

Code Case N-508 provides an alternative to the current Section XI, Paragraph IWA-7000 requirements to generate a replacement plan when removing snubbers or pressure relief valves for testing. PSE&G's Code Job Package (CJP) is the equivalent of the Section XI replacement plan. As an alternative to this replacement plan (i.e., PSE&G CJP), nine requirements must be met

{Code Case items (a) thru (i)). PSE&G intends to meet all of these requirements.

Code Case item (f) requires a separate mechanism for tracking snubbers and pressure relief valves, which ensures traceability of Inservice Inspection {ISI) and testing records. PSE&G's ISI group utilizes a computer data base program to track the current test results of all snubbers by type, rating and serial number. I' This data base provides specifics identifying a snubbers physical plant location at any point in time. This program has been used by PSE&G for several years and is far more efficient than a CJP for providing test result traceability. A similar independent tracking mechanism will be used by the InserVice Testing (IST) group for relief valves prior to application of Code Case N-508.

These mechanisms will satisfy item (f) of Code Case N-508.

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9407290158 6~866§72 PDR ADOCK PDR p

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• Doument Control Desk 2

~UL211994 NLR-N94064 Each PSE&G CJP requires a significant effort by several PSE&G organizations (Maintenance, Technical, ISI and QA). Generating a separate CJP for each snubber or relief valve removed for testing does not provide improved quality or safety. Code Case N-508, through the elimination of the added work necessary to prepare CJPs, would substantially reduce the resources expended by various station groups, particularly during outages when the requisite testing and possibility of expanded testing exists.

This Code Case does not create any technical or administrative changes that would impact the existing Salem or Hope Creek: ISI Programs, IST Programs, or Technical Specifications. Also, it does not introduce a condition that would compromise existing levels of quality or safety.

PSE&G considers this submittal a Cost Beneficial Licensing Action (CBLA). We have estimated the cost savings as $4k/yr at each

• Salem Unit and $22k/yr at Hope Creek. Savings over the life of the plants is $88k Salem Unit 1, $104k Salem Unit 2 and $704k Hope Creek.

Should you have any questions on this transmittal, please contact us.

c Mr. T. T. Martin, Administrator - Regi

u. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. J. c. Stone, Licensing Project Manager - Salem U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. Marschall (S09)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

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• CASES OF ASME BOILER AND PRESSURE VESSEL CODE

- N-508 Approval Date: March 11, 1993 See Numerical Index for expiration and any reaffirmation dates.

Case N-508 (a) Items being removed and installed shall be of Rotation of Serviced Snubbers and Pressure Relief the same design and construction; Valves for the Purpose of Testing (b) Items being removed shall have no evidence of Section XI, Division 1 failure at the time of removal; (c) Items being rotated shall be removed and installed only by mechanical means; (d) Items being installed shall previo.usly have Inquiry: What alternative rules to those stated in been in service; r.wA-7000 may be used when, for the purpose of (e) Preservice inspections and pressure tests shall testing, snubbers and pressure relief valves are ro-be performed as required by r.wA-7000; tated from stock and installed on components (f) The Owner shall maintain a method of tracking (including piping systems) within the Section XI the items to ensure traceability of inservice inspec-boundary?

• tion and testing records; (g) Use of an NIS-2 form is not required except as provicl~d in (i) below; Reply: It is the opinion of the Committee that, as (h) Testing of removed snubbers and pressure re-an alte111ative to the provisions of IWA-7000 and for lief **alves, including required sample expansions, the purpose of testing, snubbers and relief valves may shall be performed in accordance with the Owner's be rotated from stock and installed on components test program; (including piping systems) within the Section XI (i) Repair or replacement of removed items, when_

boundary provided the -following -requirements are r~quired, shall be performed in accordance with met: IWA-4000 or IWA-7000.

876.1 SUPP. 4 - NC