ML063340284

RAI Inservice Inspection Program Relief Request (TAC Nos. MD1052 and MD1053)

ML063340284
Person / Time
Site:	Salem
Issue date:	12/20/2006
From:	Stewart Bailey NRC/NRR/ADRO/DORL/LPLB
To:	Levis W Public Service Enterprise Group
Bailey S N,NRR/DLPM,415-1321
References
TAC MD1052, TAC MD1053
Download: ML063340284 (7)

Text

December 20, 2006 Mr. William Levis Senior Vice President & Chief Nuclear Officer PSEG Nuclear LLC - X09 Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NO. 2, REQUEST FOR ADDITIONAL INFORMATION RE: INSERVICE INSPECTION PROGRAM RELIEF REQUESTS (TAC NOS. MD1052 AND MD1053)

Dear Mr. Levis:

On March 21, 2006, PSEG Nuclear LLC (PSEG), the licensee for the Salem Nuclear Generating Station, Unit No. 2, requested relief from certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, for the inservice inspection (ISI) of Class 1 and Class 2 components. PSEG stated that it had conducted examinations as part of the second ten-year interval ISI program to the extent practical; however, coverage for certain weld examinations was less than required by the ASME Code. The Nuclear Regulatory Commission (NRC) staff has determined that responses to the questions in the enclosure to this letter are necessary in order for the staff to complete its review. The enclosure was sent via e-mail to PSEG on October 19, 2006, to see whether the questions were understandable, whether the regulatory bases were clear, and whether the information was already docketed. PSEG indicated that no clarifications were needed. Please provide a response to the enclosed questions within 30 days of the date of this letter in order to allow the NRC staff to complete a timely review of the relief requests. This request was discussed with Mr. James Mallon of your staff on December 12, 2006. If you have questions about this request, please contact me at (301) 415-1321.

Sincerely,

/RA/

Stewart N. Bailey, Senior Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-311

Enclosure:

Request for Additional Information cc w/encl: See next page

ML063340284 OFFICE LPL1-2/PM LPL1-2/LA DE/CPNB/BC LPL1-2/BC NAME SBailey CRaynor TChan* HChernoff DATE 12/15/06 12/15/06 8/24/06, 9/25/06 12/20/06

• by memo Salem Nuclear Generating Station, Unit No. 2 cc:

Mr. Dennis Winchester Township Clerk Vice President - Nuclear Assessment Lower Alloways Creek Township PSEG Nuclear Municipal Building, P.O. Box 157 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. Paul Bauldauf, P.E., Asst. Director Mr. Thomas P. Joyce Radiation Protection Programs Site Vice President - Salem NJ Department of Environmental PSEG Nuclear Protection and Energy P.O. Box 236 CN 415 Hancocks Bridge, NJ 08038 Trenton, NJ 08625-0415 Mr. George H. Gellrich Mr. Brian Beam Plant Support Manager Board of Public Utilities PSEG Nuclear 2 Gateway Center, Tenth Floor P.O. Box 236 Newark, NJ 07102 Hancocks Bridge, NJ 08038 Regional Administrator, Region I Mr. Carl J. Fricker U.S. Nuclear Regulatory Commission Plant Manager - Salem 475 Allendale Road PSEG Nuclear - N21 King of Prussia, PA 19406 P.O. Box 236 Hancocks Bridge, NJ 08038 Senior Resident Inspector Salem Nuclear Generating Station Mr. James Mallon U.S. Nuclear Regulatory Commission Manager - Licensing Drawer 0509 200 Exelon Way, KSA 3-E Hancocks Bridge, NJ 08038 Kennett Square, PA 19348 Mr. Steven Mannon Manager - Regulatory Assurance P.O. Box 236 Hancocks Bridge, NJ 08038 Jeffrie J. Keenan, Esquire PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038

REQUEST FOR ADDITIONAL INFORMATION REQUESTS FOR RELIEF REGARDING EXAMINATION COVERAGE SECOND TEN-YEAR INSERVICE INSPECTION INTERVAL SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 DOCKET NO. 50-311 On March 21, 2006, PSEG Nuclear LLC (PSEG), the licensee for the Salem Nuclear Generating Station (Salem), Unit No. 2, requested relief from certain requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),

Section XI, for the inservice inspection (ISI) of Class 1 and Class 2 components. PSEG stated that it had conducted examinations as part of the Second Ten-Year Interval ISI Program to the extent practical; however, coverage for certain weld examinations was less than required by the Code. The Nuclear Regulatory Commission (NRC) staff has determined that responses to the following questions are necessary in order for the staff to complete its review:

Questions on Relief Request S2-I2-RR-B01:

1.1 Request for Relief S2-I2-RR-B01, Part B, Examination Category B-B, Pressure Retaining Welds in Vessels Other than Reactor Vessels 1.1(a) For weld 2-PZR-CIRC DUH, the information submitted by the licensee is not sufficient to demonstrate impracticality. Please submit further information in the form of drawings, sketches and/or descriptions to support the determination that the inspection of this weld is limited and impractical.

1.2 Request for Relief S2-I2-RR-B01, Part C, Examination Category B-D, Full Penetration Welds of Nozzles in Vessels 1.2(a) For certain nozzle welds, information submitted by the licensee is not sufficient to demonstrate impracticality. Please submit further information in the form of drawings, sketches and/or descriptions to support this evaluation for the following components, as identified by licensee identification numbers shown below.

31-STG-1220-IRS 29-STG-1230-IRS 29-STG-1240-IRS 29-STG-1220-IRS 31-STG-1240-IRS 29-STG-12R10-IRS 31-STG-1230-IRS 31-STG-12R10-IRS 1.2(b) From the licensees submittal, it appears that all welds considered in Category B-D underwent a pressure test, with the exception of 29-RCN-12R10 and 29-RCN-1230.

Please clarify whether a pressure test was performed on these welds, and the results of the pressure test.

Enclosure

1.3 Request for Relief S2-I2-RR-B01, Part D, Examination Category B-J and B-F, Pressure Retaining Welds in Piping and Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles 1.3(a) In the licensees submittal, Table 1 of Relief Request S2-I2-RR-B01 contains a listing of multiple limited examinations for Class 1 piping and nozzle welds that have occurred during the second 10-year interval. The table lists ASME Code examination categories for each piping and nozzle weld prior to (B-F and B-J), and after (R-A), implementation of a risk-informed inservice inspection (RI-ISI) program. It is unclear whether the piping and nozzle weld examinations were performed under a conventional ASME Code program, or under the new RI-ISI program.

It is important to understand which program was used to examine each piping weld because: a) under a conventional ASME Code Section XI program, which requires a substantial population of applicable Category B-F and B-J welds to be examined, requests for relief for limited examinations based on impracticality may be submitted per Title 10 of the Code of Federal Regulations (10 CFR), Paragraph 50.55a(g)(5)(iii),

whereas, b) under a RI-ISI program, which is an existing alternative to ASME Code requirements approved by the NRC for Salem Unit No. 2, there is no method for evaluating a request for relief under 10 CFR 50.55a(g)(5)(iii).

1.3(b) According to Table 1, Examination Category B-F and B-J, the post ISI ASME item numbers are listed as R1.19-2, R1.20-4, or R1.20-6. According to Code Case N-577 or N-578, as applicable, for implementation of RI-ISI programs at Salem Unit No. 2, these item numbers do not appear in Table 1, Examination Category R-A. Please provide the correct designations.

1.3(c) For certain piping welds, information submitted by the licensee is not sufficient to demonstrate impracticality. Please submit further information in the form of drawings, sketches and/or descriptions to support this evaluation for the following components, as identified by licensee identification numbers listed below.

Examination Category B-F 6-PR-1205-1 29-RC-1210-5 31-RC-1220-1 6-PR-1203-1 31-RC-1240-1 31-RC-1210-1 4-PR-1200-1 31-RC-1230-1 Examination Category B-J 10-SJ-1221-21 31-RC-1220-4 31-RC-1220-4LU-I 2-CV-1275-44 8-SJ-1262-10 4-PS-1231-20 31-RC-1220-4LU-O 8-SJ-1245-1 27.5-RC-1230-1 3-CV-1231-14 8-SJ-1241-18 6-RH-1231-16 2-CV-1275-43

1.4 Request for Relief Part E, Examination Category B-G-1, Pressure Retaining Bolting, Greater than 2 Inches in Diameter.

1.4(a) Relief is being requested for certain examination requirements for Examination Category B-G-1, Pressure Retaining Bolting Greater than 2 Inches in Diameter. However, there are no B-G-1 items listed in Table 1. Please add the appropriate Category B-G-1 items to Table 1, and include sufficient information to demonstrate impracticality, or revise the request appropriately.

Questions on Relief Request S2-I2-RR-C01:

2.1 Request of Relief S2-I2-RR-C01, Part C, Examination Category C-F-1 and C-F-2, Pressure Retaining Piping Wleds 2.1(a) In the licensees submittal, Table 1 of Relief Request S2-I2-RR-C01 contains a listing of multiple limited examinations for Class 2 piping welds that have occurred during the second 10-year interval. The table lists ASME Code examination categories for each piping weld prior to (C-F-1 and C-F-2), and after (R-A), implementation of an RI-ISI program. It is unclear whether the piping weld examinations were performed under a conventional ASME Code program, or under the new RI-ISI program.

It is important to understand which type of program each piping weld examination was performed under, because: a) under a conventional ASME Code Section XI program, which requires a substantial population of applicable Category C-F-1 and C-F-2 welds to be examined, requests for relief for limited examinations based on impracticality may be submitted per 10 CFR 50.55a(g)(5)(iii), whereas, b) under a RI-ISI program, which is an existing alternative to ASME Code requirements approved by the NRC for Salem Unit No. 2, there is no method for evaluating a request for relief under 10 CFR 50.55a(g)(5)(iii).

2.1(b) For the component identified as 8-CS-2227-5, a valve-to-pipe weld, the licensee has listed this as ASME Examination Category C-F-1, Item A-E<3/8. This item number does not correspond with Table IWC-2500-1 in the 1986 Edition of the ASME Code. Please confirm that this weld is required to be examined by requirements of ASME Code, Table IWC-2500-1, Examination Category C-F-1. If so, please list the correct item designation for this weld.

2.1(c) For certain piping welds, information submitted by the licensee is not sufficient to demonstrate impracticality. Please submit further information in the form of drawings, sketches and/or descriptions to support this evaluation for the following components, as identified by the licensee identification numbers below.

8-CS-2227-5 12-PR-2201-1 14-RH-2212-1 14-RH-2224-1 12-RH-2252-38 3-CV-2255-9 3-CV-2256-6 3-CV-2255-12 14-BF-2211-2 30-MS-2211-9 34-MS-2241-3 6-MS-2211-13

2.2 Request for Relief Part D, Examination Category C-C, Integral Attachments for Vessels, Piping, Pumps and Valves 2.2(a) For certain component attachment and support welds, information submitted by the licensee is not sufficient to demonstrate impracticality. Please submit further information in the form of drawings, sketches and/or descriptions to support this evaluation for the following components, as identified by the licensee identification numbers below.

14-BF-2211-Trunnions 11PL-11 & 11-PI-12 14-BF-2231-17PS 14-BF-2231-18PS 34-MS-2241-242PL 12-RH-2252-38PS-1&2 12-RH-2252-38PS-3 32-MS-2231-1PS-2 32-MS-2221-1PS-2 32-MS-2211-1PS-2 32-MS-2211-2PL-1 thru 3 12-RH-2252-5PL-1 thru 6 14-BF-2221-3PL-1 thru 8