ML19269C080
| ML19269C080 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/10/1979 |
| From: | Pawlicki S Office of Nuclear Reactor Regulation |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7901220326 | |
| Download: ML19269C080 (7) | |
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A p 10 WN Docket Nos. 50-397 MS 05-12 MENORANDUM FOR:
- 5. A. Varga, Chief Light ifater Reactors Branch, No. 4 Division of Project Manage::aent
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S. S. Pawlicki, Chief 9
Materials Engineering Branch Division of Systems Safety gh gh
SUBJECT:
WPPSS MUCLEAR PROJECT W. 2 (BWR-5)
Plant Narse: WNP-2 Suppliers: General Electric; Burns and Roe Licensing Stage: OL Docket Number: 50-397 Responsible Branch and Project Manager: LWPA ; M. D. Lynch Reviewer:
M. L. Soyle Description of Task: Supplemental Q-1 Review Status: Additional Information Required The Materials Integrity Section of the Materials Engineering Branch, Division of Systents Safety has prepared the attached inquiry con-cerning the preservice and inservice inspectica programs for NNP-2.
This inquiry should be included as part of our Round One Questions forwarded to you in our memo of November 20,1978.
The following table, which was developed to keep WMP-2, Grand Gulf and 5tsquehanna apprised of questions comanon to one or both of the other plants, has been amended to mflect the additional inquiry and the deletion of one of the Susquehanna questions.
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o S. A. Varga C0 90rt nUESTIONS WNP-2 Grand Gulf Susquehanna 121.1 121.1 121.1 121.2 121.2 121.2 1 21.3 121.3 121.4 121.5 121.3 121.4 121.6 121.4 121.5 121.7 1 21.6 121.8(Hatch-2) 121.5 121.7
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121.9 121.6 121.10 121.7 121.8 After receipt of an acceptable response to any of the coenon questions, the Materials Engineering Branch will send the response to the LPM's for the other plant (s).
Origi:wl signed by
- s. s. Pnlicki S. S. Pawlicki, Chief Materials Engineering Branch Division of Systems Safety Office of nuclear Reactor Regulation
Enclosure:
As Stated cc w/ enc 1:
R. J. Mattson, DSS H. D. Lynch, DPM B. K. Grimes. 00R C. O. Thanas. DPH D. M. Crutchfield, KRR S. Miner. DPM J. P. Knight, DSS G. B. Georgiev, DSS H. F. Conrad, DSS '
R. A. Hermann, DSS R. M. Gamble, DSS N. L. Boyle, DSS R. J. Rosnak DSS cc w/o enc 1:
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2 121-1 121.0 MATERIALS ENGINEERING BRANCH - MATERIALS INTEGRITY SECTION 121.10 We will require that your inspection program for Class 1, 2 and 3 components be in accordance with the revised rules in 10 CFR Part 50, Section 50.55a, paragraph (g) oublished in the February 12, 1976 issue of the FEDERAL REGISTER.
To evaluate your inspection program, the following minimum information is necessary for our review:
(1) A preservice inspection plan to consist of the applicable ASME Code Edition and the exceptions to the Code requirements.
(2) An inservice inspection plan submitted within six months of anticipated comercial operation.
The preservice inspection plan will be reviewed to support the safety evaluation report finding on compliance with preservice and inservice inspection requirements.
The basis for the deternination will be compliance with:
(1) The Edition of Section XI of the ASME Code stated in your PSAR or later Editions of Section XI referenced in the FEDERAL REGISTER that you may elect to apply.
(2) All augmented examinations established by the Comission when added assurance of structural reliability was deemed necessary. Examples of augmented examination requirements can be found in NRC positions on (a) high energy fluid systems in SRP Section 3.2, (b) turbine disk integrity in SRP Section 10.2.3, and (c) feedwater inlet nozzle inner radii.
Your response should define the applicable Section XI Edition (s) and subsections.
If any examination requirements of the Edition of Section XI in your PSAR can not be met, a relief request including complete technical justification to support your conclusion must be provided.
The inservice inspection plan should be submitted for review within six months of anticipated commercial operation to demonstrate compliance with 10 CFR Part 50, Section 50.55a, paragraph (g). This plan will be evaluated in a safety evaluation report supplement. The objective is to incorporate into the inser/ ice inspection program Section XI requirements in effect six months prior to commercial operation and any augmented examination requirements established by the Comission.
Your response should define all examination requirements that
, 121-2 you determine are not practical within the limitations of design, geometry, and materials of construction of the components.
Attached are detailed guidelines for the preparation and content of the inspection programs and relief requests to be submitted for staff review.
GUIDANCE FOR PREPARING PRESERVICE AND INSERVICE INSPECTION PROGRAMS AND RELIEF REQUEST PURSUANT TO 10 CFR 50.55a(g)
A.
Preservice/ Inservice Inspection Procram Description This program covers the requirements set forth in 10 CFR 50.55a(g) and the ASME Boiler and Pressure Vessel Code Section XI, Sub-sections 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 NRC review.
It also describes the information necessary for " request for relief" of items that cannot be fully inspected to the requirements of ASME Section XI. By utilizing these guidelines, licensees can signifi-cantly reduce the need for having to respond to additional information requests from the NRC staff.
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 that might occur during this inspection 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 that grants the exemption is satisfactory. The inspect-ion 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 material of construction of the components. Provide the information requested in paragraph C for the inspections and pressure tests identified.
C.
Recuest for Relief from Certain Insoection and Testino Recuirements It has been the staff's experience that many requests for relief from testing requirements submitted by licensees have not been supoorted by adequate descriptive and detailed technical information. This detailed
2-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 requests submitted with a justification such as " impractical,"
" inaccessible," or any other categorical basis, require additional infor ation to pemit the staff 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 the NRC staff to make a proper evaluation and to adequately document the basis for granting the relief in the safety evaluation report. The NRC staff believes subsequent requests for additional information and delays in completing the review can be considerably reduced, if this infomation is provided initially in the licensee's submittal.
For each relief request submitted, the following information should be included:
1.
Identification the component (s) and/or the en mination require-ment for which relief is requested.
2.
Number of items associated with the requested relief.
3.
ASME Code class.
4.
Identification of the specific ASME Code requirement that has been detemined to be impractical.
5.
Infomation 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 perfanning the proposed alternative examinations in lieu of the ASME Section XI examination.
If it is not possible to perfom alternate examinations, discuss the impact on the overall level of plant quality and safety.
For inservice inspection provide the following additional information regarding the inspection frequency:
. 8.
State when the relief request would apply during the inspection period or interval; i.e., is the request to defer an examination.
9.
State when the proposed alternative examinations will be imple-mented and performed.
- 10. State the time period for which the requested relief is needed Technical justification or data must be subd.tted to support the relief request. Opinions without substantiation that a change will not affect 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 applic-able) or none will suffice.
D.
Request for Relief for Radiation Considerations Exposures of test personnel to radiation to accomplish the examinations prescribed in ASME Section XI can be an important factor in detemining v:hether or under what condition an examination must be perfomed. A request for relief must be submitted and approved similar to that required for inaccessibility.
We recogni;:e that some of the radiation considerations will only be known at the time of the test. However, the licensee generally is aware, from experience at operating facilities, of those ar'as where relief is necessary and should submit as a minimum the follouing infomation 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.