ML17227A322
| ML17227A322 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/26/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17227A321 | List: |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9203030392 | |
| Download: ML17227A322 (4) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGU ATION RELATED TO THE INSERVICE TESTING PROGRAM RELIEF RE UESTS FLORIDA POWER AND LIGHT COMPANY ST.
LUCIE UNIT 1
DOCKET NO. 50-335
- 1. 0 INTRODUCTION The Code of Federal Regulations, 10 CFR 50.55a(g),
requires that inservice testing (IST) of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable
- addenda, except where specific written relief has been requested by the licensee and granted by the Commission pursuant to Subsections (a)(3)(i), (a)(3)(ii), or (g)(6)(i) of 10 CFR 50.55a.
In requesting relief, the licensee must demonstrate that:
(1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance with certain requirements of the applicable Code edition and addenda is impractical for its facility.
These regulations authorize the Commission to grant relief from ASME Code requirements upon making the necessary findings.
The NRC staff's findings with respect to granting or not granting the relief requested as part of the licensee's IST Program are contained in this Safety Evaluation (SE).
In Florida Power and Light Company's January 3,
1990, submittal, Revision 2 of the St.
Luci e, Unit 1, Inservice Testing (IST) Program was provided.
This revision incorporated NRC guidance contained in Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs."
New relief requests were identified which were submitted for NRC review.
In addition, several relief requests had been included in the program submittal that involve IST requirements not covered by the GL 89-04 positions.
These relief requests had been submitted prior to issuance. of GL 89-04 (April 3, 1989),
and therefore, approved by GL 89-04, Paragraph B.
Two relief requests, VR-6 and VR-9, similar to relief requests submitted in the licensee's August ll, 1987
- revision, were evaluated due to changes made in the basis for relief in the January 3,
1990, submittal.
Evaluations of the new relief requests are provided in the attached Technical Evaluation Report (TER).
The relief request evaluations supersede the interim relief granted in NRC's letter of October 17, 1990.
The IST Program addressed in this SE and TER covers the first 10-year interval which began February 11,
- 1988, and ends February 10, 1998.
The licensee's program is based on the requirements of Section XI of the ASME Code, 1983 Edition through Summer 1983 Addenda.
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2.0 EVALUATION The licensee's requests for relief from the requirements of Section XI have been reviewed by the staff with the assistance of its contractor, EG&G Idaho, Inc.
(EG&G).
The TER is EG&G's evaluation of the relief requests.
The staff has reviewed the TER and concurs with the evaluations and conclusions contained in the TER.
A summary of the status of the pump and valve relief request determinations is presented in Table 1.
The granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternative proposed testing.
The licensee should refer to the TER, Appendix B, for a discussion of anomalies identified during the review.
The licensee should resolve all the items in Appendix B in accordance with the guidance therein, and address these items in a submittal within 1 year of the date of this SE.
As necessary, program or procedural changes covered in Appendix B should be completed within 1 year of the date of this SE, or by the schedule requested in the specific
- anomaly, except for items 6, 9, 12, 13, 14, and 15.
These items are to be addressed within 6 months of the date of this SE, as they were identified for licensee action in the interim relief granted by NRC's letter of October 17, 1990.
3.0 CONCLUSION
Based on the review of the licensee's IST Program relief requests, the staff concludes that the relief requests as evaluated and modified by this SE will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety-related functions.
The staff has determined that granting relief, pursuant to 10 CFR 50.55a(a)(3)(i),
(a)(3)(ii) and (g)(6)(i), is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest.
In making this determination the staff has considered the alternative testing being implemented, compliance resulting in a hardship without a compensating increase in safety, and the impracticality of performing the required testing considering the burden if the requirements were imposed.
The last column of Table 1 identifies the regulation or GL 89-04 guidance under which the requested relief is approved.
During the review of the licensee's IST Program, the staff has identified certain misinterpretations or omissions of 10 CFR 50.55a and Code requirements.
These items are summarized in the TER, Appendix B.
The IST Program relief requests for St. Lucie, Unit 1, provided by submittal dated January 3,
- 1990, are acceptable for implementation provided that the changes and actions described in Appendix B are completed within 1 year (or 6 months for items 6, 9, 12, 13, 14, and
- 15) of receipt of this SE or as requested in the specific anomaly.
Date February 26, 1992 Principal Contributor:
P.
Campbell
DISTRIBUTION LIST FOR SL174794.REL Document Dated:
Docket File..
NRC
& Local PDRs PDII-2 RDG S.
Varga G. Lainas H. Berkow J. Norris D. Hiller OGC P.
Campbell ACRS (10)
H. Sinkule, RII