ML18096B018

Forwards Final Inservice Insp long-term Plan First Interval Relief Requests.Requests Address Exams Not Performed or Completed in Entirety During Interval or Not Performed Due to Component Restrictions or ALARA Concerns

ML18096B018
Person / Time
Site:	Salem
Issue date:	09/28/1992
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N92135, NUDOCS 9210060032
Download: ML18096B018 (17)

Text

• Public Service Electric and Gas

• Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations SEP 2 8 1992 NLR-N92135 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

INSERVICE INSPECTION - LONG TERM PLAN FINAL RELIEF REQUESTS - FIRST INTERVAL SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311 In accordance with 10CFR50.55a(g)5, Public Service Electric & Gas Company (PSE&G) hereby submits the final relief requests of the Salem Unit 2 ISI Long Term Plan for the first inspection interval. These relief requests address examinations that were not performed or completed in their entirety during the interval.

The examinations were not performed due to component restrictions, ALARA concerns, or NRC approved changes to subsequent editions of ASME Section XI Boiler and Pressure Vessel Code which deleted certain requirements.

Enclosure 1 contains five final relief requests for the first inspection interval. These relief requests detail which component examinations were not completed and the basis for not performing the examinations.

The component restrictions listed in the final relief requests have been reviewed and appropriate actions taken for submittal of the Salem Unit 2 ISI Long Term Plan for the second inspection interval.

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

Sincerely, Enclosure (1)

\S-

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

9210060032 920928 PDR ADOCK 05000311 G PDR I

__J

• Document Control Desk 2

• SEP 2 8 1992 NLR-N92135 C Mr. J. C. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Mr. Emanuel J. Mossa New Jersey Department of Labor and Industry PO Box 1503, Labor and Industry Building Trenton, NJ 08625

• 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.

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-B, B-D, B-F, B-J and B-K-1 and Subsection IWB, 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 surf ace 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, lOCFRSO, "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 lOCFRSO numerous references are made allowing performance of these inspections "to the extent practical".

• 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(1) 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 already submitted a list of those identified limitations after performing the preservice examination. This relief request is submitted in addition to the original preservice examination list to identify limitations found while performing scheduled examinations for the 1st inspection interval.

ALTERNATIVE EXAMINATION:

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. Below is a listing by Category of all limitations found during the inspection interval and alternate exams performed, if any.

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 acceptance criteria, some of the exams listed below would no longer be considered limitations requiring relief requests.

SUM # CLS CAT ITEM EXAM TYPE LIMITATION 010100 1 8-8 82.1 2-PZR-CIRC-LHA VOL Complete volumetric Close proximity of None Lower head to shell A examination of the code insulation support volume is not obtainable. bracket limits UT performe~ on 80.1 % of effective examination code required volume in at of code required least 1 direction. volume.

010700 1 8-8 82.1 2-PZR-CIRC-8C VOL Complete volumetric Permanently welded None Shell B to Shell c examination of the code insulation supports volume is not obtainable. limits effective UT performed on 93.6% of examination of code code volume examined in at volume.

least 1 direction.

010800 1 8-8 82.1 2-PZR-CIRC-CD VOL Complete volumetric Permanently welded None

• Shell c to Shell D examination of the code insulation supports volume is not obtainable. limits effective UT performed on 95.2% of examination of code code volume examined in at volume.

least 1 direction *.

002700 1 8-c 81.3 29-STG-1240-IRS VOL Complete volumetric Inspection limited None Inlet nozzle IRS examination not obtained. due to permanently welded insulation support.

002800 1 8-c 81.3 2-RPVCH-6446A VOL Complete volumetric Flange configuration None Head to flange examination of the code limits examination of volume is not obtainable. the code required UT performed on 100 % of volume.

code required volume in at least 1 direction.

• 020600 1 8-D 83.2 31-STG-1240-IRS VOL Complete volumetric Close proximity of None Outlet nozzle IRS examination of the code insulation support volume is not obtainable. bracket limits UT performed on 85.0 % o~ effective examination code required volume in at of code required least 1 direction. volume.

020900 1 8-D 83.2 31-STG-1210-IRS VOL Complete volumetric Close proximity of None Outlet nozzle IRS examination of the code insulation support volume is not obtainable. bracket limits UT performed on 79.0 % of effective examination code required volume in at of code required least 1 direction. volume.

021000 1 8-D 83.2 29-STG-1240-IRS VOL Complete volumetric Close proximity of None Inlet nozzle IRS examination of the code insulation support volume is not obtainable. bracket limits UT performed on 86.0 % of effective examination code required volume in at of code required least 1 direction. volume.

SUM # ITEM EXAM TYPE LIMITATION 021300 1 8-D 83.2 29-STG-1210-IRS VOL complete volumetric Close proximity of -None Inlet nozzle IRS examination of the code insulation support volume is not obtainable. bracket limits UT performed on 82.0 % of effective examination code required volume in at of code required least 1 direction. volume.

020800 1 8-D 83.2 31-STG-1220-IRS VOL Complete volumetric Insulation support None Inner radius examination of the code limits effective volume is not obtainable. examination of code Ut performed on 74.0 % of required volume ..

code required volume in at least 1 direction.

021200 1 8-D 83.2 29-STG-1220-IRS VOL Complete volumetric Insulation support None.

Inner radius examination of the code limits effective volume is not obtainable. examination of code Ut performed on 66.0 % of required volume.

code required volume in at least 1 direction.

050000 1 8-F 84.l 6-PR-1205-1 SUR/ Complete volumetric Nozzle to safe-end None Nozzle to safe-end VOL examination of the code configuration limits volume is not obtainable. examination of code No UT performed in the required volume.

axial direction.

051200 1 8-F 84.1 6-PR-1204-1 SUR/ Complete volumetric Nozzle to safe-end None Nozzle to safe-end VOL examination of the code configuration limits volume is not obtainable. examination of code UT not performed on code required volume.

required volume.

• 052400 1 8-F 84.l 6-PR-1203-1 SUR/ Complete volumetric Nozzle and safe-end None Nozzle to safe-end VOL examination of the code configuration limits volume is not obtainable. examination of code UT performed on 52.5% of volume.

code volume examined in at least 1 direction.

07()000 1 8-F 84.1 31-RC-1240-1 SUR/ Complete volumetric Nozzle to safe-end None Nozzle to elbow VOL examination of the code configuration limits volume is not obtainable. examination of code UT not performed on code required volume.

required volume in the axial direction.

072300 1 8-F 84.1 31-RC-1230-1 SUR/ Complete Volumetric Examination not None Nozzle to Elbow VOL examination not obtained performed due to the no UT performed in the acoustic properties axial direction. of cast elbow and nozzle configuration.

SUM #. CLS CAT ITEM EXAM TYPE LIMITATION BASIS ALT 074600 1 8-F 84.1 31-RC-1220-1 SUR/ Complete volumetric not Examination not None Nozzle to elbow VOL obtained no examination performed due to the performed in the axial acoustic properties direction. of the cast elbow and nozzle configuration.

076800 1 8-F 84.1 31-RC-1210-1 SUR/ Complete volumetric Examination not None Nozzle to elbow VOL examination of the code performed due to the volume is not obtainable. acoustic properties No UT performed in the of the cast elbow and axial direction. nozzle configuration.

080000 1 8-F 84.1 29-RC-1240-5 Elbow to nozzle SUR/

VOL Complete volumetric examination of the code volume is not obtainable.

No UT performed on code required volume in the axial direction.

Acoustic properties of cast elbow as well as nozzle configuration limits effective examination of code required volume.

None

• 081200 1 8-F 84.1 29-RC-1230-5 SUR/ Complete volumetric Acoustic properties None Elbow to nozzle VOL examination of the code of cast elbow as well volume is not.obtainable. as nozzle No UT performed on code configuration limits required volume in the effective examination axial direction. of code required volume.

082200 1 8-F 84.1 29-RC-1220-5 SUR/ Complete volumetric Acoustic properties None Elbow to nozzle VOL examination of the code of cast elbow as well volume is not obtainable. as nozzle

• No UT performed on code configuration limits required volume in the effective examination axial direction. of code required volume.

083300 1 8-F 84.1 29-RC-1210-5 SUR/ Complete volumetric Acoustic properties None Elbow to nozzle VOL examination of the code of cast elbow and volume is not obtainable. nozzle configuration UT not performed on code limits examination of required volume in the the code required axial direction. volume.

030800 1 8-J 84.5 3-CV-1243-4 VOL Complete volumetric Valve configuration None Valve to elbow examination of the code limits examination of volume is not obtainable. the code required UT performed on 100 % of volume.

code required volume in at least 1 direction.

SUM#.. CLS CAT ITEM EXAM TYPE LIMITATION BASIS ALT 034800 1 8-J 84.5 3-CV-1231-2 VOL Complete volumetric Sharp elbow curvature None Valve to elbow examination of the code limits examination of volume is not obtainable. the code required UT performed on 72.8 % of volume.

code required volume in at least 1 direction.

070500 1 8-J 84.5 31-RC-1240-3 VOL Complete volumetric Acoustic properties None Pipe to elbow examination of the code of elbow limits volume is not obtainable. examination of code UT performed on 50 % of required volume.

code required volume in at

-

least 1 direction.

075100 1 8-J 84.5 31-RC-1220-3 VOL Complete volumetric Examination not None Pipe to elbow examination of the code performed due to the volume is not obtainable. acoustic properties 61\ of the code volume of the cast elbow.

will be examined with at least 4 directions.

078200 1 8-J 84.5 31-RC-1210-4 VOL Complete volumetric Acoustic properties SUR Elbow to pipe examination of the code of cast elbow and volume is not obtainable. branch connection UT performed on 50.0 % of configuration limits code required volume in at effective examination least 1 direction. of code required volume.

083200 1 8-J 84.5 29-RC-1210-4 VOL Complete volumetric Acoustic properties None Pipe to elbow examination of the code of cast elbow limits volume is not obtainable. examination of code UT performed on 50.0\ of required volume.

• code required volume in at least 1 direction.

083400 1 8-J 84.5 27.5-RC-1240-1 VOL Complete volumetric Pump configuration None Pump to pipe examination of the code and branch connection volume is not obtainable. limits examination of UT performed on 47.7 % of code required volume.

code required volume in at least 1 direction.

151800 1 8-J 84.5 14-RH-1211-15 VOL Complete volumetric Valve configuration None Valve to pipe examination of the code limits effective volume is not obtainable. examination of code UT performed on 86.2% of volume.

code volume examined in at least 1 direction.

SUM # CLS CAT ITEM EXAM TYPE LIMITATION BASIS ALT 160750 1 8-J 84.5 10-SJ-1241-8 VOL Complete volumetric Penetration sleeve Non~

Elbow to pipe examination of the code limits accessibility volume is not obtainable. and examination of UT performed on 50.0% code code required volume.

required volume in at least 1 direction.

172400 1 8-J 84.5 6-SJ-1241-16 VOL Complete volumetric Valve configuration None Valve to pipe examination of the code limits effective volume is not obtainable. examination of code UT performed on 79.3% of volume.

code volume in at least 4

• directions.

172450 1 8-J 84.5 6-SJ-1241-16 VOL Complete volumetric Valve configuration None Valve to pipe examination of the code limits effective volume is not obtainable. examination of code UT performed on 79.3% of volume.

code volume in at least 1 direction.

174550 1 8-J 84.5 6-SJ-1222-1 VOL Complete volumetric Reducer to valve None Reducer to pipe examination of the code configuration volume is not obtainable. prevents examination No UT performed on code of code required required volume in the volume.

axial direction.

174600 1 8-J 84.5 6-SJ-1222-2 VOL Complete volumetric Valve configuration None Valve to pipe examination of the code limits effective volume is not obtainable. examination of code UT performed on 80.1% of volume.

• code volume in at least 1 direction.

179000 1 8-J 84.5 4-SJ-1282-10 VOL Complete volumetric Structural member None Pipe to elbow examination of the code limits effective volume is not obtainable. examination of code UT performed on 82.5% of volume.

code volume in at least 1 direction.

161900 1 8-K-l 84.9 10-SJ-1231-5PS VOL Complete volumetric Penetration SUR Penetration to pipe examination of the code configuration limits volume is not obtainable. examination of code UT performed on 91.1% of required volume.

code volume examined in at least 1 direction.

SUM I CLS CAT ITEM EXAM TYPE LIMITATION 275210 2 C-A Cl. l 2-LHEX-l VOL Complete volumetric Flange configuration Hone.

Flange to shell examination of the code and the close volume is not obtainable. proximity of 4" UT performed on 82.4% of sensing lines limits code volume in at least 1 the effective direction. examination of code volume.

275230 2 C-A Cl .1 2-RCF-1 VOL Complete volumetric Adjacent flanges and None Upper head to flange examination of the code supports limits volume is not obtainable. effective examination UT performed on 50.0 % of of code required code required volume in at volume.

least 1 direction.

275040 2 C-C Cl. 3 2-CVCT-2VS-1&2 SUR Complete surface Inacceeibilty of weld None.

Vessel support examination of the code limits the effective volume is not obtainable. examination of code PT performed on 62.0% of volume.

code volume. 6" of weld not inspected.

380050 2 C-E-1 C2.5 34-MS-2241-2PS-1&2 SUR Complete surface Adjacent pipe support None Pipe support examination of the code limits effective volume is not obtainable. examination of code 50 % of the code required required volume.

inspected.

573383 2 C-E-1 C2.5 12-SJ-2252-38PS-1&2 SUR Complete surface Piping orientation None Pipe support examination of the code limits examination of volume is not obtainable. code required volume.

All but 8" of weld on each lug inspected.

360010 2 C-F C2 .1 e-cv-2201-1 VOL Complete volumetric Pipe restraint and None.

Valve to pipe examination of the code valve configuration volume is not obtainable. limits examination of UT performed on 69.7 % of code required volume.

code required volume in at least 1 direction.

360110 2 c-F c2 .1 e-cv-2201-11 VOL Complete volumetric Pipe restraint limits None Pipe to tee examination of the code examination of code volume is not obtainable. required volume.

UT performed on 69.7 % of code required volume in at least 1 direction.

SUM #

500810 CLS 2

• CAT C-F ITEM C2.1 EXAM 6-PR-2203-2 Elbow to pipe TYPE VOL

• LIMITATION Complete volumetric examination of the code volume is not obtainable.

BASIS Close proximity of permanent pipe support limits

• Non~*

UT performed on 55.9 % of examination of the code required volume in at code required volume.

least 1 direction.

502410 2 C-F C2.1 8-RH-2273-1 VOL Complete volumetric Tee to valve None Tee to reducer examination of the code configuration limits volume is not obtainable. examination of code No UT performed on code required volume.

required volume in the axial direction.

503340 2 C-F C2.l 8-RH-2216-4 VOL Complete volumetric Flange to valve SUR .,

Flange to valve examination of the code configuration limits volume is not obtainable. examination of code No UT performed on code required volume.

required volume in the axial direction.

330930 2 C-G C2.1 14-BF-2211-2 VOL Complete volumetric Whip restraint and 4" None Pipe to elbow examination of the code branch connection volume is not obtainable. limits examination of UT performed on 81.3% of code required volume.

code required volume in at least 1 direction.

380040 2 C-G C2.3 34-MS-2241-2/8-MS-2241 VOL Complete volumetric Flange configuration SUR 8" branch connection examination of the code and the close volume is not obtainable. proximity of 4" UT performed on 82.4% of sensing lines limits

• code volume in at least 1 the effective direction. examination of code volume.

380050 2 C-G C2.l 34-MS-2241-3 VOL Complete volumetric Valve configuration None Pipe to valve examination of the code and branch connection volume is not obtainable. limits examination of UT performed on 83.8 % of code required volume.

code required volume in at least 1 direction.

380780 2 C-G C2.1 34-MS-2211-3 VOL Complete volumetric Valve configuration None

• Pipe to valve examination of the code limits effective volume is not obtainable. examination of code UT performed on 82.3 % of required volume.

code required volume in at least 1 direction.

SUM l.

384545 CLS 2

• CAT C-G

. ITEM C2.1 EXAM 6-MS-2211-16A Pipe to valve TYPE VOL

• LIMITATION Complete volumetric examination of the code volume is not obtainable.

BASIS Valve configuration limits effective examination of code

• ALT None*

Ut performed on 72.a % of required volume.

code required volume in at least 1 direction.

384548 2 C-G c2.1 6-MS-2211-168 VOL Complete volumetric Valve configuration None Valve to pipe examination of the code limits effective volume is not obtainable. examination of code Ut performed on 73.a % of required volume.

code required volume in at least 1 direction.

384630 2 C-G C2.1 6-MS-2231-4 VOL Complete volumetric Valve configuration None

• Pipe to valve examination of the code and limits the volume is not obtainable. effective examination UT performed on 77.6% of of code required code volume in at least 1 volume.

direction.

384683 2 C-G C2.1 6-MS-2231-9A VOL Complete volumetric Flange configuration None Pipe to valve examination of the code limits effective volume is not obtainable. examination of code UT performed*on ea.a% of required volume.

code required volume in at least 1 direction.

384685 2 C-G C2.1 6-MS-2231-98 VOL Complete volumetric Valve configuration None Pipe to valve examination of the code limits effective volume is not obtainable. examination of code UT performed on ea.a % of required volume.

• code required volume in at least 1 direction.

• *

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

Pressure Retaining Valves 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 uncertainy 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 later editions of Section XI, this examination is only required to be performed on valves scheduled for disassembly for maintenance purposes.

ALTERNATIVE EXAMINATION:

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 examined was found to require corrective action, additional valves in that group would be disassembled and inspected as required by Section XI.

Utilizing the above guidelines, the following valves listed by group were never disassembled during the first inspection interval and therefore, the internals were not visually examined. A similar relief request has been submitted for the second ten year interval per later editions of the Code *

• Valve Group 2RH1 2RH2 Valve Group 2RH26 Valve Group 21SJ49 22SJ49 Valve Group 21SJ54 22SJ54

--- - - - - -- - - --

• *

• SAL.EM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 3 COMPONENT DESCRIPTION:

Reactor Pressure Vessel and Nozzles 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 Categories B-A, B-B and B-D, Item No. 's Bl.1, Bl.2 and Bl.4, respectively.

BASIS FOR RELIEF:

Due to the geometry of the reactor vessel and the proximity of some of the vessel penetrations, code required coverage of all

• the applicable welds cannot be obtained utilizing automated UT equipment.

ALTERNATIVE EXAMINATION:

Ultrasonic examinations were performed on as much of the weld geometry that could be examined. For vessel welds in the beltline region (Categ. B-A), Public Service Electric & Gas attempted to perform a 100% examination of all the required vessel welds which exceeds the Code requirement to examine 10% of all circumferential welds and 5% of all longitudinal welds.

Attached is a listing of those welds where the Code required volume could not be examined due to geometry and interferences .

• *

• REF. EXAM WELD NUMBER/ BEAM  %

1. CAT. EXAM AREA DIR. COVER REMARKS 001900 B-B 2-RPV-3443 cw 4.79% EXAMINATION LIMITED i LOWER HEAD DISK ccw 4.79% DUE TO PROXIMTY OF TO PEEL SEGMENT UP 3.66% INSTRUMENTATION TUBES 002900 B-D CIRC. WELD 29-RCN-1240 DOWN cw 4.80%

25.60% LIMITED DUE TO e*

OUTLET NOZZLE ccw 25.60% INTEGRAL EXTENSION AND

@ 22-DEG TOWARD RX 96.66% GEOMETRIC SHADOWING 003200 B-D 29-RCN-1230 cw 25.60% LIMITED DUE TO OUTLET NOZZLE ccw 25.60% INTEGRAL EXTENSION AND

@ 158-DEG TOWARD RX 96.66% GEOMETRIC SHADOWING 003300 B-D 29-RCN-1230 cw 25.60% LIMITED DUE TO OUTLET NOZZLE ccw 25.60% INTEGRAL EXTENSION AND

@ 203-DEG TOWARD RX 96.66% GEOMETRIC SHADOWING 003600 B-D 29-RCN-1230 cw 25.60% LIMITED DUE TO OUTLET NOZZLE ccw 25.60% INTEGRAL EXTENSION AND

@ 338-DEG TOWARD RX 96.66% GEOMETRIC SHADOWING

• *

• SALEM UNIT 2 - lST INSPECTION INTERVAL FINAL RELIEF REQUEST - # 4 COMPONENT DESCRIPTION:

Interior Clad surfaces of Class 1 Vessels ASME CODE CLASS:

ASME Section XI, Class 1 Vessels ASME EXAMINATION REQUIREMENTS:

Relief is being requested from the visual and surface, or volumetric examinations in Examination Category B-I-1 Item No.

Bl.13 and the visual examination examinations required by Table IWB-2500 Examination Category B-I-2 Item No.'s B2.9 and B3.8 as required by ASME Section XI 1974 Edition, Summer '75' Addenda, Table IWB-2500.

BASIS FOR RELIEF:

The requirement to perform these examinations has been deleted in later editions of ASME Section XI. In addition, the radiation

• dose required to complete these inspections is in conflict with the station's ALARA guidelines. Visual and surface examinations were completed on two (2) of the six (6) required Reactor Pressure Vessel closure head cladding patches (Cat. B-I-1, Item Bl.13) in the first inspection period with no reportable indications noted.

The cladding patch on the pressurizer (Cat. B-I-2, Item B2.9) was not examined during the inspection interval.

Two (2) of the required eight (8) visual examinations on the steam generator cladding patches (Cat. B-I-2, Item B3.9) were completed in the first inspection period with no reportable indications noted.

ALTERNATIVE EXAMINATION:

There are no alternative examinations proposed for these examinations *

.. * *

• SALEM UNIT 2 - lST INSPECTION INTERVAL COMPONENT DESCRIPTION:

FINAL RELIEF REQUEST - # 5 Support Components for Piping, Pumps and Valves ASME CODE CLASS:

ASME Section XI, Class 2 and 3 Supports ASME EXAMINATION REQUIREMENTS:

Relief is being requested from the visual examinations required by ASME Section XI 1974 Edition, Summer 1 75' Addenda, Table IWC-2520 Examination Category C-E-2, Item No C2.6 and IWD-2600 (c).

BASIS FOR RELIEF:

Some of the supports scheduled for examination during the inspection interval could not be examined due to their accessibility. These supports cannot be examined because they are either encased within concrete or encapsulated by guardpipe.

In our submittal for Salem Unit 2, 2nd Ten Year Inspection

• Interval, Public Service Electric & Gas has requested the use of ASME Code Case N-491 which exempts these types of components from examination.

ALTERNATIVE EXAMINATION:

There are no alternative examinations proposed for these examinations at this time. Below is a listing of those component supports which could not be examined during the 1st inspection interval.

2C-21-FWH-018 2A-CCH-054 2A-CCH-079 2A-SWG-317 2C-24-FWH-024 2A-CCS-064 2A-CCH-080 2A-SWG-318 2C-MSH-207 2A-CCG-065 2A-CCA-088 2A-SWG-319 2A-CCH-030 2A-CCA-066 2A-CCG-101 2A-SWG-320 2A-CCA-031 2A-CCH-067 2A-CCG-102 2A-SWG-321 2A-CCG-032 2A-CCS-073 2A-CCS-104 2A-SWG-322 2A-CCG-033 2A-CCG-074 2A-CCS-126 2A-SWG-323 2A-CCS-034 2A-CCG-075. 2P-CCA-367 2A-SWG-324 2A-CCA-052 2A-CCA-076 2P-CCA-368

• 2A-CCG-053 2A-CCH-077 2F-SFCG-007