ML17216A447
| ML17216A447 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/14/1986 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Barry D AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML17216A448 | List: |
| References | |
| NUDOCS 8603200233 | |
| Download: ML17216A447 (8) | |
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o NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 IHAR 14 tS88 D. marshall Barry, Ph.D.
74 Eliot Avenue West Newton, t~iassachusetts 02165
Dear Dr. Barry:
Your letter of January 26, 1986 to Chairman Palladino has been referred to my office for response.
In your letter you express a concern about the basis for the extension date of the first 10 year inspection interval at St. Lucie 1.
You state that you were alarmed that such extension is based upon the date of commercial service.
You also expressed your belief that the staff acted "with remarkable haste" on the amended extension request vis-a-vis the original request.
In addition you request a list of nuclear plants that have requested or received a change in their ASNE Code inspection schedules or requirements and a "full and complete copy" of all internal staff memorandum on the issue of "financial vs safety considerations."
Your concerns and requests are addressed below.
The plant Technical Specifications and 10 CFR 50.55a(g)(4) form the regulatory bases that define the requirements for inservice inspection.
Section XI of
'he ASME Boiler and Pressure Vessel Code (the Code) is incorporated by reference to the extent specified by 10 CFR 50.55a(b).
This regulation is unique in requiring updating of Code inspection requirements throughout the service life of a facility.
The regulation has specific provisions for granting relief from impractical Code requirements, imposing alternative requirements, and requiring the licensee to follow an augmented inservice inspection program for systems and components for which the Commission deems that added assurance of structural reliability is necessary.
Therefore, the licensee is required to comply with the provisions of specified Code editions unless a written approval of relief is obtained from the NRC.
Inservice inspections are normally performed during a 10-year inspection interval that is subdivided into three 40-month inspection periods.
Section XI of the code establishes minimum and maximum percentages of examinations that must be performed in each inspection period, e.g.,
Table IWB-2412-1.
Thus, prescribed examinations for the inspection intervals are required to be distributed over each of the periods for the service lifetime of the power plant.
Licensees normally perform certain categories of examinations during each refueling outage.
(All ASt<E Code citations reference the 1980 Edition.)
Section XI paragraph IWA-2400(b) requires the following:
"The inspection interval shall be determined by calendar years following placement of the power unit into commercial service.'"
Footnote 2 references the regulations of the Federal Energy Regulatory Commission (18 CFR Part 101, paragraph 9.D. of "Electric Plant Instructions" ) to define commercial service.
Section XI, paragraph IWA-2400(c) of the Code states "Each inspection interval may be decreased or extended (but not cumulatively) by as much as 1
year.
For power units that are out of service continuously for 6 months or more, the inspection interval during which the outage occurred may be extended for a period equivalent to the outage."
8603200233 8603i4 PDR ADOCK 05000335 8
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With regard to the St. Lucie 1 request for an extension to its first 10-year interval, the Safety Evaluation of November 20, 1985 was an implementation of the regulations described above.
Section XI of the ASME Code as referenced in 10 CFR Part 50 and paragraph IWA-2400(c) permits the extension for a period equivalent to the unscheduled outage.
The technical basis for this conclusion as it relates to your specific comments and requests is as follows:
Your conclusion is correct that the inspection interval starts from the date of commercial service, which is defined by the Code, as noted above.
Section XI of the Code defines requirements for the examination of a sample of welds and components to be inspected periodically to detect significant service-induced degradation if present.
The implicit assumption of the requirements of ASME Section XI is that significant service-induced degradation will not occur during the period before commercial service.
2.
The technical bases for the extensi'on of the inspection interval are the same.
The implicit assumption is that significant service-induced degradation will not occur during a period when a power unit is out of service continuously for 6 months or more.
The decrease or extension of each inspection interval as discussed in paragraph IWA-2400(c) allows scheduling inservice inspections during refueling outages.
The number and extent of examinations required by the regulations must be completed regardless of the decrease or extension of the interval.
The initial request for extension of the inspection interval at St. Lucie 1 covered the period of time needed to reach the next refueling outage scheduled for June, 1987.
The St. Lucie Unit 1 inspection interval originally was to expire on December 21, 1986.
The licensee was in the third 40-month inspection period at the time of the initial request for extension.
for ASME Code Class 1 components,Section XI Table IWB-2412-1 requires that a minimum of 50K and a maximum of 67K of the examinations be performed by the beginning of the third inspection period.
The Code permits the deferral of certain inspections, such as the reactor vessel examination, until the end of the inspection interval.
Subsequently, the licensee recognized that there was no absolute assurance that the refueling outage would occur on such a precise schedule and, therefore, decided to change the request to cover the entire period of the unscheduled outage.
This request was not received and documented until shortly before the approval of the extension.
The NRC does not have a specific list of plants that have been granted changes in their ASME Code inspection schedules or requirements because virtually all plants have requested relief from Code requirements.
The record of NRC decisions concerning the extension of an inspection interval and granting of other reliefs from the Code are in individual plant docket files that are available in the Public Document Room.
Plants that have been out of service continuously for 6 months or more during any given.
inspection interval are likely to have had thei r inspection interval extended in accordance with IWA-2400(c).
The documents provided in my response of January 6, 1986 were those requested in your earlier correspondence.
These are 'the only "internal" staff memoranda that have been identified to date.
Sincer ely, cc:
See next page Qrlglnal Siped hg H.R.Canton g Harold R. Denton, Director Office of Nuclear Reactor Regulation PBD08 RPy~zer g /gj /86 P
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Distribution:
Docket File NRC 5 L PDRs w/cy of incoming EDO ¹001406 EDO Rdg HDenton/DEisenhut PBD¹8 Rdg (W/cy of incoming)
OELD SECY 86-121 VStello PPAS (EDO ¹1406) w/cy of incoming AThadani/EFantom DSells w/cy of incoming PKreutzer PBD¹8 Green Ticket File JNGrace
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 EDO PRINCIPAL CORRESPONDENCE CONTROL FROM:
D.
MARSHALL BARRY NEST
- NEWTON, MASSACHUSETTS TO CHAIRMAN PALLADINO FOR SIGNATURE OF:
DUE:
02/~J 86-
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Da d3/ u co/ b 0
~ P~W'86 GRFEN EDCI CONTROL: 001406 DOC DT: 01/26/86 F INAt REPLY:
SECY NO: 86-121 DENTON DESC:
REQUEST FOR INFO RE SAFETY OF FPLL S ST ~
LUCIE PLANT 13ATE: 02/07/86 ASSIGNED TCI:
NRR CONTACT:
13ENT N
ROUTING:
GRACE GCLINNINGHAM SPECIAL INSTRUCTIONS OR REMARKS:
REF.
02/,10/86 ACTION:,
DPLB-MIRAGLIA NRR ROUTING:
DENTON/EISENHUT PPAS MOSSBURG/TOMS
OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER:
ACTION OFFICE:
AUTHOR AFFILIATION:
LETTER DATE:
SUBJECT:
ACTION:,
CRC-86-0121 EDO LOGGING DATE: Feb 6 86 D.M.,Barry, MASSACHUSETTS Jan 26 86 FILE CODE:
IDLER-5 St. Lucie Followup ltr to Comm's response to his 12-5
& 9, 1986 ltrs concerning the safety of the FPGL Co's St. Lucie Plant Appropriate DISTRIBUTION:
SPECIAL HANDLING: None NOTES'ATE DUE:
SIGNATURE:
AFFILIATION:
DATE SIGNED:
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