ML19263B516
| ML19263B516 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/10/1979 |
| From: | Parr O Office of Nuclear Reactor Regulation |
| To: | Delgeorge L COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 7901180339 | |
| Download: ML19263B516 (5) | |
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UNITED STATES
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1 JAN 101979 Docket flos. 50-373 and 50-374 fir. Louis 0. DelGeorge fluclear Licensing Administrator Boiling Water Reactors Commonwealth Edison Company Post Office Box 767 Chicage, Illinois 60690
Dear Mr. DelGeorge:
SUBJECT:
COMt4ENTS Ott PROPOSEC PRESERVICE IflSPECTION AtiD TEST PLANS FOR LA SALLE COUNTY STATIONS, UNIT N05. 1 & 2 In your letter of December 8,1978, you requested our comments on your proposed preservice inspection and test plan for your La Salle County Station by January 19, 1979.
In addition, you indicated that the intent of the proposed plan is to provide an overview. A final sutwittal will be provided at a later date.
In discussing the plan with you by telephone on January 3,1979, we indicated that our review of the plan would be divided into two areas:
(1) mechanical engineering, and (2) materials engineering. We stated that due to manpower problems the mechanical engineering area could not be reviewed until you submit your final report.
We should note, though, that in our letter of December 7,1977, we provided guidance relating to the mechanical engineering area.
Nith respect to the materials area, our comments are discussed below.
Sufficient information was not submitted to demonstrate that the examinations were impractical to conduct with regards to code requirements.
Also, there was insufficient information to justify the proposed alternate examination procedure to provide adequate safety protection against failure of the component.
For example, in Section 7, regarding relief requests No. -01 and -04: the specific location of each weld should be described; the number of welds in each category, involved and not involved in the request, should be indicated; the extent to which the welds can be examined by code requirement should be documented; and justification for the adequacy of the alternate examination procedure should be included in the request.
Furthermore, regarding relief request Nos. -02 and -03: the mere selection of a later code addition
-for the sake of convenience or the fact you need relief only is not justification for the adoption of an alternate method of examination.
7901180 339
o e
Mr. Louis 0. DelGeorge JAN 10 1979 In addition to our specific comments regarding the materials area, the enclosure to this letter provides additional guidance to you for the preparation of your preservice and inservice inspection programs and relief requests pursuant to 10 CFR Section 50.55a(g).
Please contact us if you desire further discursions or clarifications relative to cur comments or guidance.
Sincerely, D.k lan u. Parr, Chief Light Uater Reactors Branch ilo. 3 Division of Project Management
Enclosure:
As Stated cc w/ enclosure:
Mr. Byron Lee, Jr.
Vice President Commonwealth Edison Company P. O. Box 767 Chicago, Illinois 60690 Richard E. Powell, Esq.
Isham, Lincoln & Beale One First flational Plaza Suite 2400 Chicago, Illinois 60690 Dean Hansell, Esq.
Assistant Attorney General State of Illinois 188 West Randolph Street Suite 2315 Chicago, Illinois 60601
~
ENCLOSURE GUIDANCE FOR PREPAP TION _0I,PRESERVICE AND INSERVICE INSPECTION PROGRAM Herein is our guidance for the preparation of preservice and inservice inspection programs and the request from relief of code requirement pursuant to 10 CFR Section 50.55a(g).
A.
Preservic_efInservice Inspection Program Description This program covers the requirements set forth in 10 CFR 50.55a(g) and the ASME Boiler and Pressure Vessel Code Section XI. Subsections IWA, IWB, IWC and IWD.
The guidance provided in this enclosure is intended to illustrate the type and extent of information that should be provided for our review.
It also describes the information necessary for " request for relief" of items which cannot be fully inspected to the requirements of ASME Section XI.
By utilizing these guidelines, licensees can significantly reduce the need for having to respond to additional information requests from us.
B.
Contents of the Submittal The information listed below should be included in the submittal:
1.
For each facility, include the applicable ASME B & P V Code date and appropriate addendum date.
2.
The period and interval for which this program is applicable.
3.
Include the proposed codes and addenda to be used for repairs, modifications, additions or alternations to the facility which might eccur during this inspectiori period.
4.
Identify the examinations that you have exempted under the rules of ASME Section XI. A reference to the applicable paragraph of the code which grants the exemption is satisfactory. The inspection requirements for exempt components should be shown; i.e., visual inspection during a pressure test.
5.
Identify the inspection and pressure testing requirements of the applicable Section XI requirements that are deemed impractical because of the limitations of design, geometry and materials of construction of the components.
Provide the information requested in paragraph C below for the inspections and pressure tests identified.
2 C.
Request for Relief from Certain Testing Requirements It has been our experience that many requests for relief from testing requirements submitted by licensees have not been supported by adequate descriptive and detailed technical information. This detailed information is necessary to document the impracticality of the ASME Code requirements within the limitations of design, geometry and materials of construction of components and to determine whether the use of alternatives will provide an acceptable level of quality and safety.
Relief request that are submitted with a justification such as
" impractical," " inaccessible," or any other categorical basis, require additional information to permit us to make an evaluation of that relief request.
The objective of the guidance set forth below is to illustrate the extent of the information that is required by us to make a proper evaluatior, and to adequately document the basis for granting the relief in the safety evaluation report. We believe, i f this information is provided in the licensee's submittal, subsequent requests for additional infcrmation and delays in completing the review can be reduced considerably.
For each relief request submitted, the followins formation should be included:
(1)
Identification of the component (s) and/or the examination.
(2) Number of items associated with the requested relief.
(3) ASME Code class.
(4)
Identification of the specific ASME Code requirement ~ that has been determined to be impractical.
(5)
Informatior to support the determination that the requirement is impractical, i.e., state and explain the basis for requesting relief.
(6)
Identification of the alternative examinations that are proposed in lieu of Section XI requirements or to supplement partially performed Section XI examinations.
(7) Description and justification of any changes expected in the overall level of plant safety by performing the proposed alternative examinations in lieu of the ASME Section XI
.. examination.
If it is not possible to perform examinations, discurs the impact on the overall level of plant quality and safety.
For inservice inspection provide the following additional information regarding the inspection frequency:
(1) State when the relief request would apply during the inspection period or interval; i.e.,
is the request to defer an examination.
(2) State when the proposed alternative examinations will be implemented and performed.
(3)
State the time period for which the requested relief is needed.
Technical justi fication or data must be submitted to support the relief request.
Opinions without substantiation that a change will not af fect 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.
D.
Request for Relief for Radiation Considerations Exposures of test personnel to radiation to accomplish the examinations prescribea in ASME Section XI can be an important factor in determining whether or under what condition an examination must be performed. A request for relief must be submitte6 and approved similar to that required for inaccessibility.
We recognize that some of the radiation considerations will only be known at the time of the test.
However, the licensee generally is aware, from conditions noted during previous refuelings, of those areas where relief is necessary and should submit as a minimum the following information with the request for relief:
(1) Total estimated man-rem exposure involved in the examination.
(2) Radiation levels at the test area.
(3) Flushing or shielding capabilities which might reduce radiation levels.
(4) Alternate inspection techniques proposed.
(5) Remote inspections considerations.
(6) Redundant systems or similar welds which can be inspected.
(7) Preservice and any inservice results of welds involved.
(8) Consequences if the weld failed.