ML063340284

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

ML063340284
Person / Time
Site:	Salem
Issue date:	12/20/2006
From:	Bailey S N 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, 2006Mr. William LevisSenior 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 FORADDITIONAL 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 NuclearGenerating 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 ManagerPlant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-311

Enclosure:

Request for Additional Informationcc w/encl: See next page

ML063340284OFFICELPL1-2/PMLPL1-2/LADE/CPNB/BCLPL1-2/BCNAMESBaileyCRaynorTChan*HChernoff DATE12/15/0612/15/068/24/06, 9/25/0612/20/06* by memo Salem Nuclear Generating Station, Unit No. 2 cc:

Mr. Dennis WinchesterVice President - Nuclear Assessment PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038Mr. Thomas P. JoyceSite Vice President - Salem PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038Mr. George H. GellrichPlant Support Manager PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038Mr. Carl J. FrickerPlant Manager - Salem PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038Mr. James MallonManager - Licensing 200 Exelon Way, KSA 3-E Kennett Square, PA 19348Mr. Steven MannonManager - Regulatory Assurance P.O. Box 236 Hancocks Bridge, NJ 08038Jeffrie J. Keenan, EsquirePSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038Township ClerkLower Alloways Creek Township Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038Mr. Paul Bauldauf, P.E., Asst. DirectorRadiation Protection Programs NJ Department of Environmental Protection and Energy

CN 415 Trenton, NJ 08625-0415Mr. Brian BeamBoard of Public Utilities 2 Gateway Center, Tenth Floor Newark, NJ 07102Regional Administrator, Region IU.S. Nuclear Regulatory Commission

475 Allendale Road King of Prussia, PA 19406Senior Resident InspectorSalem Nuclear Generating Station U.S. Nuclear Regulatory Commission Drawer 0509 Hancocks Bridge, NJ 08038 REQUEST FOR ADDITIONAL INFORMATIONREQUESTS FOR RELIEF REGARDING EXAMINATION COVERAGESECOND TEN-YEAR INSERVICE INSPECTION INTERVAL SALEM NUCLEAR GENERATING STATION, UNIT NO. 2DOCKET NO. 50-311On March 21, 2006, PSEG Nuclear LLC (PSEG), the licensee for the Salem NuclearGenerating 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:

1.1Request for Relief S2-I2-RR-B01, Part B, Examination Category B-B, PressureRetaining Welds in Vessels Other than Reactor Vessels1.1(a)For weld 2-PZR-CIRC DUH, the information submitted by the licensee is not sufficient todemonstrate 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.1.2Request for Relief S2-I2-RR-B01, Part C, Examination Category B-D, Full PenetrationWelds of Nozzles in Vessels1.2(a)For certain nozzle welds, information submitted by the licensee is not sufficient todemonstrate 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-IRS29-STG-1230-IRS29-STG-1240-IRS29-STG-1220-IRS31-STG-1240-IRS29-STG-12R10-IRS 31-STG-1230-IRS31-STG-12R10-IRS1.2(b)From the licensee's submittal, it appears that all welds considered in Category B-Dunderwent 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 1.3Request for Relief S2-I2-RR-B01, Part D, Examination Category B-J and B-F, PressureRetaining Welds in Piping and Pressure Retaining Dissimilar Metal Welds in VesselNozzles1.3(a)In the licensee's submittal, Table 1 of Relief Request S2-I2-RR-B01 contains a listing ofmultiple 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 weldbecause: 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 itemnumbers 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 todemonstrate 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-F6-PR-1205-129-RC-1210-531-RC-1220-16-PR-1203-131-RC-1240-131-RC-1210-1 4-PR-1200-131-RC-1230-1Examination Category B-J10-SJ-1221-2131-RC-1220-431-RC-1220-4LU-I2-CV-1275-44 8-SJ-1262-104-PS-1231-2031-RC-1220-4LU-O 8-SJ-1245-127.5-RC-1230-13-CV-1231-14 8-SJ-1241-186-RH-1231-162-CV-1275-43 1.4Request 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 CategoryB-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:

2.1Request of Relief S2-I2-RR-C01, Part C, Examination Category C-F-1 and C-F-2,Pressure Retaining Piping Wleds2.1(a)In the licensee's submittal, Table 1 of Relief Request S2-I2-RR-C01 contains a listing ofmultiple 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 wasperformed 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 haslisted 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 todemonstrate 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-2227-512-PR-2201-114-RH-2212-114-RH-2224-112-RH-2252-383-CV-2255-93-CV-2256-63-CV-2255-12 14-BF-2211-230-MS-2211-934-MS-2241-36-MS-2211-13 2.2Request for Relief Part D, Examination Category C-C, Integral Attachments for Vessels,Piping, Pumps and Valves2.2(a)For certain component attachment and support welds, information submitted by thelicensee 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-1214-BF-2231-17PS14-BF-2231-18PS34-MS-2241-242PL 12-RH-2252-38PS-1&212-RH-2252-38PS-3 32-MS-2231-1PS-232-MS-2221-1PS-2 32-MS-2211-1PS-232-MS-2211-2PL-1 thru 3 12-RH-2252-5PL-1 thru 614-BF-2221-3PL-1 thru 8