ML17229A259
| ML17229A259 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/10/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17229A257 | List: |
| References | |
| NUDOCS 9703130070 | |
| Download: ML17229A259 (4) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION INSERVICE INSPECTION RE VEST FOR RELIEF FOR FLORIDA POWER AND LIGHT COMPANY ST.
LUCI E PI.ANT UNITS 1
AND 2 DOCKET NOS.
50-335 AND 50-389
1.0 INTRODUCTION
The Technical Specifications for St.
Lucie Plant, Unit Nos.
1 and 2, state that the inservice inspection and testing of the American Society of Mechanical Engineers (ASHE) Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASHE Boiler and Pressure Vessel Code and applicable Addenda as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g),
except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).
Section 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the Nuclear Regulatory Commission, if (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4),
ASME Code Class 1,
2, and 3 components (including supports) shall meet the requirements that become effective subsequent to editions specified in 10 CFR 50.55a(g)(2) and (g)(3), except the design and access provisions and the preservice examination requirements, set forth in the ASHE Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components,"
to the extent practical within the limitations of
- design, geometry, and materials of construction of the components.
The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASHE Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.
The 1983 Edition, with Summer 1983 Addenda, of Section XI is the applicable edition of the ASME Code for St, Lucie Unit 1, and the 1989 Edition, with no Addenda, is the applicable edition of the ASME Code for St.
Lucie Unit 2.
This is the Second 10-year Inservice Inspection (ISI) Interval for both units.
ENCLOSURE l
9703l30070 97039.0 PDR ADOCK 05000335 8
2 Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirements.
After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(i),
the Commission may grant relief and may impose alternative requirements that are determined to be authorized by law; will not endanger life, property, or the common defense and security; and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed.
In a letter dated November 27, 1996, the licensee, Florida Power and Light Company (FPL) proposed an alternative examination to the requirements of the ASME Boiler and Pressure
- Code,Section XI.
FPL requested approval for the implementation of the alternative rules of ASME Section XI Code Case N-546, dated August 24, 1995, "Alternative Requirements for gualification of VT-2 Examination Personnel,Section XI, Division I," pursuant to 10 CFR 50.55a(a)(3) for use in the St.
Lucie Unit 1
and 2 10-Year InService Inspection P ograms.
- 2. 0 EVALUATION
- 2. 1 Licensee's Re uest This submittal is requesting approval pursuant to 10 CFR 50.55a(a)(3) for use of Code Case N-546, "Alternative Requirements for gualification of VT-2 Examination Personnel,Section XI, Division I."
- 2. 1. 1 ASME Code,Section XI, RequirementsSection XI, IWA-2300, requires that personnel performing VT-2 and VT-3 visual examinations be qualified in accordance with comparable levels of competency as defined in ANSI N45.2.6.
Additionally, the examination personnel shall have natural or corrected near distance vision acuity, in at least one eye, equivalent to a Snellen fraction of 20/20.
For far vision, personnel shall have natural or corrected far distance visual acuity of 20/30 or equivalent.
- 2. 1.2 Licensee's Code Relief Request The licensee has requested approval to implement alternatives to the Code requirements contained in Code Case N-546, "Alternative Requirement for gualification of VT-2 Examination Personnel,Section XI, Division I," which is not yet approved by the NRC by reference in Regulatory Guide
- 1. 147.
- 2. 1.3 Licensee's Basis for Relief The licensee stated the following basis for relief:
"Use of Code Case N-546 allows experienced plant personnel such as licensed and non-licensed operators, local leak rate test personnel, system engineers, and inspection and nondestructive examination personnel to perform VT-2 visual examinations without having to be
certified to comparable levels of competency defined in ANSI N45.2.6.
The FPL individuals performing the visual examinations will be subject to the conditions provided in Code Case N-546.
"Specifically, if the code case is approved, the examination personnel will have at least forty (40) hours of plant walkdown experience, receive a minimum of four (4) hours of training on Section XI requirements and plant specific procedures for VT-2 visual examinations, and pass the vision test requirements of IWA-2321, 1995 edition.
In addition to the requirements of the Code Case N-546, FPL will develop a procedure to assure that consistent VT-2 visual examinations are performed.
FPL will proceduralize the requirement that an independent review and evaluation of the findings be performed by persons other than those that performed the VT-2 examinations.
FPL will also implement a
program that documents the qualifications, training, and visual acuity of persons selected to perform the VT-2 examinations and will maintain records that all of the requirements in the Code Case and specified herein, are met.
This approach alleviates the need to contract certified VT-2 personnel to perform these examinations and reduces the administrative burden of maintaining a Section XI qualification and certification program for VT-2 examination personnel.
The level of safety and quality will not decrease with the elimination of contract personnel and the use of qualified FPL personnel to determine if leakage is present.
The qualification requirements in Code Case N-546, in conjunction with the additional commitments, are comparable to those qualifications required for VT-2 visual examiner certification."
- 2. 1.4 Licensees'roposed Alternative Examination (as stated):
"FPL will meet the requirements contained in Code Case N-546 and will develop and implement formal procedures so that consistent VT-2 visual examinations are performed.
Leakage evaluations will include an independent review and evaluation of findings by persons other than those that performed the VT-2 exams.
- Finally, FPL will document and maintain records to verify that persons selected are qualified."
- 2. 1.5 Evaluation The Code requires that VT-2 visual examination personnel be qualified to comparable levels of competency as defined in ANSI N45.2.6.
The Code also requires that the examination personnel be qualified for near and far distance vision acuity.
The licensee proposes to implement the alternatives contained in Code Case N-546.
In addition, the licensee will implement formal procedures to ensure consistent VT-2 visual examinations are performed, and that the evaluation of leakage includes an independent review of the findings by persons other than those that performed the VT-2 exams.
FPL will also document and maintain records to verify that persons selected are qualified by meeting the following requirements, as stated by the licensee:
1.
"...at least forty (40) hours of plant walkdown experience, 2.
"...receive a minimum of four (4) hours of training on Section XI requirements and plant specific procedures for VT-2 visual examination,..."
3.
"...pass the vision test requirements of IWA-2321, 1995 Edition."
The qualification requirements in Code Case N-546 are comparable to those qualifications required for VT-2 visual examiner certification.
Licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel typically have a sound working knowledge of plant components and piping layouts.
This knowledge makes them acceptable candidates for performing VT-2 visual examinations.
The licensee is implementing formal procedures to obtain consistent VT-2 visual examination results even with the varied experience levels and potentially different leakage interpretations by employees performing the VT-2 visual examinations.
In addition, the evaluation of leakage will include independent review and evaluation of find'.ngs by persons other than those that performed the VT-2 visual examinations.
Furthermore, the licensee is implementing a program that documents the qualifications, training, and visual acuity of persons selected to perform the VT-2 visual examinations.
Based on a review of Code Case N-546, the staff believes that the alternatives to the Code qualification requirements for examination personnel, in conjunction with the licensee's added provisions, will provide an acceptable level of quality and safety.
Therefore, the licensee's request to implement alternatives contained in Code Case N-546 is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
Use of Code Case N-546 is authorized for the current interval at St. Lucie, Units 1
and 2, until such time as the Code Case is approved by reference in Regulatory Guide
- 1. 147.
At that time, if the licensee intends to continue to implement this Code
- Case, the licensee is to follow all provisions in Code Case N-546 with limitations issued in Regulatory Guide (RG)
- 1. 147, if any.
3.0 CONCLUSION
S The staff evaluated the information provided by the FPL in support of its request for relief.
Based on the information submitted, the alternative for qualification of VT-2 examination personnel contained in the licensee's proposal provides an acceptable level of quality and safety and is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
Florida Power and Light Company's alternative is authorized until such time as the Code Case is published in a future revision of RG 1. 147.
At that time, if the licensee intends to continue to implement this Code
- Case, the licensee is to follow all provisions in Code Case N-546, with limitations issued in RG 1. 147, if any.
Principal Contributor:
L. Wiens Date:
Harch 10, i997