ML18019A507
| ML18019A507 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/26/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18019A506 | List: |
| References | |
| NUDOCS 8601020368 | |
| Download: ML18019A507 (3) | |
Text
CAROLINA POWER AND LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 Docket No. 50-400 Back round Information Article IMF of the ASME Section XI, provides requirements for the inspection of ASME Code Class 1, 2, and 3 and MC component supports required to be constructed in accordance with Subsection NF of ASME Section III.
Paragraph IMF-2200 of Section XI, 1980 Edition including Addenda through Minter 1981, requires that all examinations of component supports listed in Table IMF-2500-2 be performed completely once as a preservice examination.
In addition, all examinations shall be performed following the initiation of hot functional testing (HFT).
The ASNE Code requires visual examination of component supports to determine the operability of the component or to determine the general mechanical and structural condition of supports, such as the presence of loose parts, debris, or abnorm'al corrosion products, wear, erosion',
corrosion, and the loss of integrity at bolted or welded connections.
A licant's Re uest In a letter dated November 5, 1985, the applicant requested plant specific approval to use final construction inspection records that document an in-spection prior to HFT for certain component sup~orts in lieu of the required preservice inspection after HFT.
The applicant s position is that a pre-service inspection is not required for component supports where the design and operating temperature of the process fluid is less than or equal to 200'F.
However, the applicant proposes to use final construction inspection records that document an inspection done prior to HFT.
The applicant concludes that this alternate provides an acceptable level of quality and safety on the basis that the final construction inspection is equivalent to a preservice inspection and that HFT does not alter the condition of supports on low tem-perature systems.
In general, supports covered by the applicant's request are in systems such as emergency service water, component cooling, and con-tainment spray; however, the applicant proposes to apply this request to all supports that meet the 200'F criteria irrespective of their system designation.
Staff Evaluation Paragraph IMF-1230 entitled "Supports Exempt From Examination and Test," of ASNE Section XI is identified as "In the course of preparation."
Paragraph IMF-2510(a) states that the component supports selected for examination shall be the supports of those components that are required to be examined under paragraphs IWB, IMC, and IMD during the first inspection interval.
Although certain ASME Class 2 component supports may be excluded from visual examina-tion, the 1980 Edition of ASME Section XI and the regulations require the 86010203bB 851226 PDR ADQCK 05000000 9
Cp visual insPection of some components and their su~ports where the temperature of the process fluid is less than or equal to 200 F.
Final construction and installation verification inspections to a great extent duplicate the inspection requirements of Article IWF.
The examination method for all component supports covered by Article IWF is visual inspections con-ducted to determine the general mechanical and structural condition of the sup-port, the operability of the component or device, the confirmation of functional
- adequacy, or the verification of the settings or freedom of motion.
Consider-ing the scope of Article IWF, some of the required preservice inspections, such as verification of pipe hanger settings or freedom of motion, should be per-formed after hot functional testing or initial criticality.
The applicant proposes to use documentation from final construction inspections, that were conducted prior to HFT, as an alternative program for all component supports where the design and operating temperature of the process fluid is less than or equal to 200'F in lieu of the required IQF component support preservice inspections.
The staff has concluded that the alternative program proposed by the applicant is acceptable provided that the following conditions are met:
(1)
The applicant has defined the specific visual inspections required by Table IWF-2500-2, including component supports with process fluids less than or equal to 200'F, and the applicant can identify the specific documentation that shows that construction inspections were performed on these components.
(2)
All visual inspections that require system function or minimum operating conditions are performed after these conditions are
- achieved, and I
(3)
The records and reports of the alternative program are documented in a manner consistent with Article IWA-6000.
The basis for the staff's conclusion is that the alternative
- program, including the conditions described
- above, and the visual examinations that will be per-formed during hot functional testing, pre-operational
- testing, and system functional verification, will exceed the requirements of the Section XI pre-service visual examination of component supports.
Therefore, the applicant's proposed alternative program described in the letter dated November 5, 1985, with the conditions described
- above, meet the requirements of 10 CFR 50.55a(a)(3)(i) and will provide an acceptable level of quality and safety.
ATTACHMENT 2 SALP REPORT PLANT:
Shearon Harris Unit 1 DOCKET NO.:
50-400 LICENSEE:
Carolina Power 8 Light Company REVIEWER:
M.
Hum LICENSING ACTIVITY:
PSI PROGRAM REVIEW EVALUATION CRITERIA 1.
Management Involvement and Control in Assuring Quality 2.
Approach to Resolution of Technical Issues from a Safety Standpoint 3.
Responsiveness to NRC Initiatives 4.
Enforcement History 5.
Reporting and Analysis of Reportable Events 6.
Staffing RATING 2
N/A N/A N/A REMARKS