ML17209A947
| ML17209A947 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/08/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| References | |
| NUDOCS 8104150407 | |
| Download: ML17209A947 (10) | |
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Docket No.: ~50-389-Sincerely, gr!@md @gned by
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LB¹1 Rdg TERA DEisenhut NRC/PDR BJYoungblood L/PDR VNerses NSIC MRushbrook TIC RTedesco ACRS (16)
'V w RVol1mer Florida Power
& Light Company....,....,T ATTN:
Dr. Robert E. Uhrig, Vice,President DR, 4Q Advanced Systems
& Technolo9y,.,
"""%H t$'d "MPA, P. 0.
Box 529100
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Dear Dr. Uhrfg:
JKennedy
Subject:
Request for Additional Iyformatfoy,jot,the.,gyvfey.of thje..,
St. Lucfe, Unit 2,Preservfce Inspection Pro)rap,.......
I '6 The Materials Engineering BranchDivisionofEngineer)ng.,t'outfne1y, reyfe>vs the preservfce inspection programsof, Ot.applicants, as pat t,,of, the pj.imary, review responsibility for SRP Sections,5,.2,4.and 6.;6,,
Tp assist/appl,fcants, fn the prepara'tfon of these programs,and. to,exKedjte,the review process,, the.attached guidance fs provided for St., Lucfe,Uni,t. 2,for,jnc)rporatfon,fpto. the FSARas...
an MTEB question.
Responses to the enclosed request. should. be submitted by, flag;.,29,1981...,,If,,.
you cannot meet this date, please, fnIfojm usyitfifn seven days,afterreceipt,,...,,
of this letter of the date you,plan,to subijt yourresponses......,
Please contact Mr. Nerses, St.Lucfe,, Unit2 LicensingPro)yet.ganaget;, if..
you desire any dfscussfon or. c't.arfffcat$ onof, tfie enclosed pelves'ted.
Enclosure:
As stated Robert L. Tedesco, Assistant Director for Licensing Division of Licensing
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NRC FORM 318 RO/80) NRCM 0240 OFFICIAL RECORD COPY e USGPO: 1980-0294124
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Dr. Robert E. Uhrig, Vice President Advanced Systems and Technology Florida Power 8 Light Company P. 0.
Box 529100 Miami, Florida 33152 CC:
Harold F. Reis, Esq.
Lowenstein, Newman, Reis,-Axelr'ad 5 Toll 1025 Connecticut
- Avenue, N.
W.
Washington, D.
C.
20036 Norman A. Coll, Esq.
McCarthy, Steel, Hectory 5 Davis 14th Floor, First National Bank Building Miami, Flori da 33131 Mr. Martin H. Hodder 1131 N.
E.
86 Street Miami, Florida 33138 Dr. David L. Hetrick Professor of Nuclear Engineering The University of Arizona Tucson, Arizona 85721
-Or. Frank F. Hooper School of Natural Resources University of Michigan Ann Arbor, Michigan 48104 Resident Inspector St. Lucie Nuclear Power Station c/o U. S. Nuclear Regulatory Commission P. 0.
Box 400 Jensen, Beach, Florida 33457 Edward Luton, Esq.,
Chariman Atomic Safety 5 Licensing US Nuclear Regulatory Commission Washington, DC 20555
e.
I 0 't. Luc'ie, Unit 2 250.0 INSERYICE INSPECTION STATION MATERIALS ENGINEERING BRANCH 250. 1 We require that your inspection program for Class 1,
2 and 3 components be in accordance with the revised rules in 10 CFR Part 50, Section 50.55a,
, paragraph (g).
Accordingly, submit the following information:
(1)
A preservice inspection plan which is consistent with the required edition of the ASME Code.
This inspection plan should include any exceptions you propose to the Code requirements.
(2)
An inservice inspection plan submitted within six months of the anticipated date for commercial operation.
This preservice inspection plan will be required to support the safety evaluation report finding regarding your compliance with preservice and inservice inspection requirements.
Our determination of your compliance will be based on the edition of Section XI of the ASME Code
, referenced in your FSAR or later editions of Section XI referenced in
~ the FEDERAL REGISTER that you may elect to apply.
I ',
Your response to this item should define the applicable edition(s) and subsections of Section XI of the ASME Code.
If any of the examination requirements of the particular edition of Section XI you referenced in the FSAR cannot be met, a request for relief must be submitted, including
,'omplete technical justification to support your request.
Detailed guidelines for the preparation and content of the inspection programs to be submitted for staff review and for relief requests are attached as an Appendix to Section 121.0 of our review questions.
0
APPENDIX TO SECTION,'250.0 GUIDANCE FOR PREPARING PRESERVICE AND INSERVICE INSPECTION PROGRAMS AND RELIEF REQUESTS PURSUANT TO 10 CFR 50.55a(g)
A.
Descri tion of the Preservice/Inservice Ins ection Pro ram This program should cover the requirements set forth in Section 50.55a(b) and (g') of 10 CFR Part 50; the ASME Boiler and Pressure Vessel Code,Section XI, Subsections IAW, IWB, IWC and IWD; and Standard Review Plans 5.2.4 and 6.6.
The guidance provided in this enclosure is intended to illustrate the type and extent of information that should be provided for NRC review.
It also describes the information necessary for "request for relief" of items that cannot be fully inspected to the requirements of Section XI of the ASME Code.
By utilizing these. guidelines, applicants can significantly reduce the need for requests for additional informa-tion from the NRC staff.
B.
Contents of the Submittal The information listed below should be included in the submittal:
1.
For each facility, include the applicable date for the ASME Code and the appropriate addenda date.
2.
- Fhe period and interval for which this program is applicable.
3.
Provide the proposed codes and addenda to be used for repairs, modifications, additions or alternations to the facility which might be implemented during this inspection period.
4.
Indicate the components and lines that you have exempted under the rules of Section XI of the ASME Code.
A reference to the applicable paragraph of the code that grants the exemption is necessary.
The inspection requirements for exempted components should be stated (e.g., visual inspection during a pressure test).
5.
Identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitations of design, geometry, or materials of construction of the components.
Provide the information requested in the following section of this appendix for the inspections and pressure tests identified in Item 4 above.
C.
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f df It has been the staff's experience that many requests for relief from testing requirements submitted by applicants and licensees have not been supported by adequate descriptive and detailed technical infor-mation.
This detailed information is necessary to:
(1) document the impracticality of the ASNE Code requirements within the limita-tions of design,
- geometry, and materials of construction of components; and (2) determine whether the use of alternatives will provide an acceptable level of quality and safety.
Relief requests submitted with a justification such as "impractical,"
"inaccessible,"
or any other categorical
- basis, require additional information to permit the staff to make an evaluation of that relief request.
The objective of the guidance provided in this section is to illustrate the extent of the information that is required by the NRC staff to make a proper evaluation and to adequately document the basis for granting the relief in the staff's Safety Evaluation Report.
The NRC staff believes subsequent requests for additional information and delays
.in completing the review can be considerably reduced if this information is provided initially in the applicant's submittal.
For each relief request submitted, the following information should be included:
l.
An identification of the component(s) and/or the examination requirements for which relief is requested.
2.
The number of items associated with the requested relief.
3.
The ASME Code class.
4.
An identification of the specific ASHE Code requirement that has been determined to be impractical.
5.
The information to support the determination that the requirement is impractical; i.e., state and explain the basis for requesti.ng relief.
6.
An identification of the alternative examinations that are proposed:
(a) in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in compliance with the requirements of Section XI.
7.
A description and justification of any changes expected in the overall level of plant safety by performing the proposed alternative examinations in lieu of the examination required by Section XI. If it is not possible to perform alternate examinations, discuss the impact on the overall level of plant quality and safety.
For inservice inspection, provide the following additional information regarding the inspection frequency:
8.
State when the request for relief would apply during the inspection period or interval (i.e., whether the request is to
'defer an examination).
9.
State when the proposed alternative examinations will be implemented and performed.
10.
State the time period for which the requested relief is needed.
Technical justification or data must be sumitted to support the relief request.
Opinions without substantiation that a change will not affect the quality level are unsatisfactory.
If the relief is requested for inaccessibility, a detailed description or drawing which depicts the inaccessibility must accompany the request.
A relief request is not required for tests prescribed in Section XI that do not apply,to your facility.
A statement of "N/A" (not applicable) or "None" will suffice.
0.
Re uest for Relief for Radiation Considerations Exposures of test personnel to radiation to accomplish the examina-tions prescribed in Section XI of the ASME Code can be an important factor in determining whether, or under what conditions, an examination must be performed.
A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently approved by the NRC staff.
Me recognize that some of the radiation considerations will only be known at the time of the test.
However, the licensee generally is
- aware, from experience at operating facilities, of those areas where relief will be necessary and should submit as a minimum, the following information with the request for relief:
1.
The total estimated man-rem exposure involved in the examination.
2.
The radiation levels at the test area.
3.
Flushing or shielding capabilities which might reduce radiation 1 evel s.
4.
A proposal for alternate inspection techniques.
5.
A discussion of the considerations involved in remote inspections.
6.
Similar welds in redundant systems or similar welds in the same systems which can be inspected.
7.
The results of preservice inspection and any inservice results for the welds for which the relief is being requested.
8.
A discussion for the consequences if the weld which was not
- examined, did fail.
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