ML030590207

Inservice Inspection Program Relief Request HC-RR-A06

ML030590207
Person / Time
Site:	Salem, Hope Creek
Issue date:	02/20/2003
From:	Salamon G Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HC-RR-A06
Download: ML030590207 (3)

Text

PSEG Nuclear LLC P O. Box 236, Hancocks Bndge, New Jersey 08038-0236 FEB20ZOO3 LRN-03-0055 United States Nuclear Regulatory Commission Document Control Desk0 PSEG Washington, DC 20555-001 NuclearLLC INSERVICE INSPECTION PROGRAM RELIEF REQUEST HC-RR-A06 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSES NPF-57 DOCKET NOS. 50-354 Pursuant to 10 CFR 50.55a(a)(3)(i), PSEG Nuclear, LLC requests the use of Code Case N-566-2, CorrectiveAction for Leakage at Bolted Connections,Section XI, Division 1, for the Hope Creek Second Inspection Interval. PSEG Nuclear, LLC proposes to implement the alternative requirements of Code Case N-566-2 when leakage occurs at bolted connections (other than gaseous systems).

The attachment to this letter includes the proposed alternative and supporting justification for the relief. Based on the evaluation contained in the attachment, PSEG Nuclear has concluded that the proposed alternative provides an acceptable level of quality and safety. Accordingly, this proposal satisfies the requirements of 10 CFR 50.55a(a)(3)(i).

This relief request is applicable to PSEG Nuclear LLC Hope Creek Generating Station. PSEG Nuclear requests that the NRC approve this request by April 2003 in order to support Hope Creek refueling outage RFOI 1 scheduled to commence April 12, 2003. Similar relief has been granted for Salem Units 1 and 2 [Docket Numbers 50-272 and 50-311 via approved TAC numbers MB6091 and MB6092, dated November 27, 2002, respectively].

Should you have any questions regarding this request, please contact Mr.

Howard Berrick at 856-339-1862.

y

S ncderWI Manager - Nuclear Safety and Licensing

Attachment:

ISI Relief Request HC-RR-A06 95-2168 REV 7/99

Document Control Desk Attachment I LR-N03-0055 "ReliefRequest HC-RR-A06

1. ASME Code Component(s) Affected Bolted connections for Class 1, 2, & 3 components.

2. Applicable Code Edition and Addenda

The code of record for Hope Creek ISI Program is Section X1 of the ASME Code, 1989 Edition.

3. Applicable Code Requirement

For Hope Creek, sub-paragraph IWA-5250(a)(2) of the 1989 Edition, without Addenda of Section XI requires the removal of all the bolting, performance of VT-3 visual examination of all the bolting, and performance of an evaluation in accordance with IWA-3100 when leakage occurs at bolted connections.

4. Proposed Alternative PSEG Nuclear, LLC proposes to implement the alternative requirements of Code Case N-566-2 when leakage occurs at bolted connections (other than gaseous systems).

5. Basis of Alternative for Providing Acceptable Level of Quality and Safety Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative provides an acceptable level of quality and safety.

PSEG Nuclear, LLC requests the use of Code Case N-566-2, Corrective Action for Leakage at Bolted Connections, Section Xl, Division I for the Hope Creek Second Inspection Interval.

Removal of bolts for VT-3 visual examination is not always the most prudent action when leakage is discovered at a bolted connection. Leakage at bolted connections is typically identified during system leakage tests. For Class 1 systems, this leakage test is conducted prior to plant startup following each refueling outage. This test is perfom ed at full operating pressure (1000 psia) and temperature. When leakage is discovered during this test, the corrective action (i.e. removal of bolts) must be performed with the system at full temperature and pressure, or the plant must be cooled down. The removal of a bolt at full temperature and pressure conditions can be extremely physically demanding due to the adverse heat environment. Cooling down the plant subjects the plant to additional heat up and cool down cycles, and can add 3 4 days to the duration of the refueling outage. Bolted connections associated with pumps and valves are typically studs threaded into the body of the component. Removal of these studs is typically very difficult and time consuming due to length of time they have been installed and are often ProposedAlternative In Accordance with 10 CFR 50.55a(a)(3)(i)

-- Alternative ProvidesAcceptable Level of Quality and Safety --

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Document Control Desk Attachment I LR-N03-0055 Relief Request HC-RR-A06 damaged during the removal process. This difficulty is compounded when the removal must be performed under heat stress conditions.

The requirements of IWA-5250(a)(2) must be applied regardless of the significance of the leakage or the corrosion resistance of the materials used in the bolted connection. Implementation of Code Case N-566-2 permits factors such as the number and service age of the bolts, the bolting materials, the corrosiveness of the system fluid, the leakage location and system function, leakage history at the connection or at other system components, and visual evidence of corrosion at the bolted connection be used to evaluate the need for corrective measures.

Granting the proposed alternative will provide an acceptable level of quality and safety, and will not adversely impact the health and safety of the public.

6. Duration of Proposed Alternative Proposed alternative relief is requested for the duration of the second ten year IS[ interval at Hope Creek. The use of the Code Case is requested until the NRC publishes the Code Case in a future revision of the applicable Regulatory Guide.

7. Precedents Previous relief has been granted for Salem Units I and 2 [Docket Numbers 50-272 and 50-311 via approved TAC numbers MB6091 and MB6092, dated November 27, 2002, respectively].

8. References None.

ProposedAlternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative ProvidesAcceptable Level of Quality and Safety --

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