ML19347E199
| ML19347E199 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 04/09/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Draper E GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8104240236 | |
| Download: ML19347E199 (7) | |
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UNITED STATES 3%
NUCLEAR REGULATORY COMMISSION j, f ) ^*
j WASHINGTON, D. C. 20555
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APR 9 1981
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f, 'o Docket Nos. 50-458/459 g
Dr. E. Linn Draper, Jr.
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Vice President, Technology E
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Gulf States Utilities Company t
P. O. Box 2951 s
Beaumont, Texas 77704 s
Dear Dr. Draper:
SUBJECT:
GUIDANCE FOR PREPARING PRESERVICE AND INSERVICE INSPECTION PROGRAMS AND RELIEF REQUESTS - RIVER BEND NUCLEAR PLANT, UNITS 1 AND 2 The NRCs Materials Engineering Branch reviews the preservice inspection programs of applicants for operating licenses following the review procedures of Standard Review Plan Sections 5.2.4 and 6.6.
To assist applicants in the preparation of their programs and to expedite this review process, enclosure 1 is provided for your guidance in preparing the program for River Bend, Units 1 and 2.
Your inspection program for Class 1, 2 and 3 components should be in accordance with the revised rules in 10 CFR Part 50, Section 50.55a, paragraph (g).
Accordingly, you should submit the following information:
(1) A preservice inspection plan which is consistent with the required edition of the ASME Code. This inspection plan should include any exceptions you propose to the Code requirements; and (2) An inservice inspection plan submitted within six months of the anticipated i
date for corinercial operation.
}
Your preservice inspection plan will be used by the NRC to support its safety evaluation report findings regarding your compliance with preservice and f
inservice inspection requirements. Our detemination of your compliance will be based on the edition of Section XI of the ASME Code referenced in your FSAR or later editions of Section XI referenced in the FEDERAL REGISTER that you may elect to apply.
Your response should define the applicable edition (s) and subsections of Section XI of the ASME Code.
If any of the examination requirements of the particular edition of Section XI you referenced in the FSAR cannot be met, a request for relief must be submitted. Requests for relief should include adequate technical justification to support your request.
8104240236
c' 1RPR 9 te"1 Dr. E. Linn Draper, Jr. I Should you have questions regarding this guidance, contact Mr. J. Kennedy (301) 492-9545 or our Project Manager.
Sincerely, r
M Robert L. Tedesco, Assistant Director for Licensing Division of Licensing Office of Nuclear Reactor Regulation 2
Enclosure:
Guidance For Preparing Preservices and Inservices Inspection Programs and Relief Requests ces w/ enclosure:
See next page i
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APR 9 W
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i ENCi0SURE GUIDANCE FOR PREPARING PRESERVICE AND INSERVICE INSPECTION PROGRAMS AND RELIEF REQUESTS PURSUANT TO 10 CFR 50.55a(g)
A.
Description of the Preservice/ Inservice Inspection Program This program should cover the requirements set forth in Section 50.55a(b) and (g) of 10 CFR Part 50; the ASE Boiler and Pressure Vessel C, ode,Section XI, Subsections IAW, IWB, IWC and IWD; and Standard Review Plans 5.2.4 and 6.6.
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 Section XI of the ASME Code. By utilizing these guidelines, applicants can significantly reduce the need for requests for additional informa-tion 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 date for the ASME Code and the ar
' ate addenda date.
2.
The periu.,ad interval for which this program is applicable.
3.
Provide the proposed codes and addenda to be used for repairs, modifications, additions or alternations to the facility which might be implemented during this inspection period.
4.
Indicate the components and lines that you have exempted under the rules of Section XI of the ASME Code. A reference to the applicable paragraph of the code that grants the exemption is necessary. The inspection requirements for exempted components should be stated (e.g., visual inspection during a pressure test).
5.
Identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitations of design, geometry, or materials of construction of the components. Provide the information requested in the following section of this appendix for the inspections and pressure tests identified in Item 4 above.
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. C.
Request for Relief from' Certain Inspection and Testing Requirements It has been the staff's experience that many requests for relief from testing requirements submitted by applicants and licensees have not been supported by adequate descriptive and detailed technical infor-mation. This detailed information is necessary to:
(1) document the impracticality of the ASME Code requirements within the limita-tions of design, geometry, and materials of construction of components; and (2) 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 information to permit the staff to make an evaluation of that relief request. The objective of the guidance provided in this section 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 staff's Safety Evaluation Report. The NRC staff believes subsequent requests for additional information and delays in completing the review can be considerably reduced if this information is provided initially in the applicant's submittal.
For each relief request submitted, the following information should be included:
1.
An identification of the component (s) and/or the examination requirements for which relief is requested.
2.
The number of items associated with the requested relief.
3.
The ASME Code class.
4.
An identification of the speci?!c ASME Code requirement that has been determined to be impractical.
5.
The information to support the determination that the requirement is impractical; i.e., state and explain the basis for requesting relief.
6.
An identification of the alternative examinations that are proposed: (a) in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in compliance with the requirements of Section XI.
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3-l 7.
A description and justification cf any changes expected in the overall level of plant safety by performing the proposed alternative examinations in lieu of the examination required by l
l Section XI.
If it is not possible to perform 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 request for relief would apply during the inspection period or interval (i.e., whether the request is to i
defer an examination).
9.
State when the proposed alternative examinations will be implemented and performed.
- 10. State the time period for which the requested relief is needed.
Technical justification or data must be sumitted 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 applicable) or "None" will suffice.
D.
Request for Relief for Radiation Considerations Exposures of test personnel to radiation to accomplish the examina-tions prescribed in Section XI of the ASME Code can be an important factor in determining whether, or under what conditions, an examination must be performed. A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently approved by the NRC staff.
l l
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 experience at operating facilities, of those areas where relief will be necessary and should submit as a minimum, the following i
information with the request for relief:
i 1.
The total estimated man-rem exposure involved in the examination.
2.
The radiation levels at the test area.
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Flushing or shielding capabilities which might reduce radiation levels.
4.
A proposal for alternate inspection techniques.
5.
A discussion of the considerations involved in remote inspections.
6.
Similar welds in redundant systems or similar welds in the same systems which can be inspected.
7.
The results of preservice inspection and any inservice results for the welds for which the relief is being requested.
8.
A discussion for the consequences if the weld which was not examined, did fail.
APR9 1961 Dr. E. Linn Draper, Jr.
Vice President - Technology Gulf States Utilities Company P. O. Box 2951 Beaumont, Texas 77704 cc: Troy B. Corner, Jr., Esq.
Conner, Moore & Corber 1747 Pennsylvania Avenue, N. W.
Washington, D. C.
20006 Mr. J. E. Booker, Safety & Licensing Gulf States Utilities Company P. O. Box 2951 Beaumont, Texas 77704 Stanley Plettman, Esq.
Orgain, Bell & Tucker Beaumont Savings Building Beaumont, Texas 77701 Karin P. Sheldon, Esq.
Sheldon, Harmon & Weiss 1725 I Street, N. W.
Washington, D. C.
20006 William J. Guste, Jr., Esq.
Attorney General State of Louisiana P. O. Box 44005 State Capitol Baton Rouge, Louisiana 70804 l
Richard M. Troy, Jr., Esq.
j Assistant Attorney General in Charge State of Louisiana Department of Justice 234 Loyola Avenue New Orleans, Louisiana 70112 I
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