ML19350D371
| ML19350D371 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/08/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Koester G KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8104150338 | |
| Download: ML19350D371 (7) | |
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I UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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o APR 8 1981 Docket No.:
STN 50-482 4
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Mr. Glenn L. Koester Vice President - Nuclear
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I y~1 Kansas Gas and Electric 2-1 201 N. Market Street J APR J g IS8
\\, 4%*mQ g,g/g 8 P. O. Box 208 Wichita, Kansas 76201
Dear Mr. Koester:
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Subject:
Request for Additional Information for the Review o Wolf Creek Plant, Unit 1 - Preservice Inspection Program The Materials Engineering Branch, Division of Engineering, routinely reviews the preservice inspection programs of OL applicants as part of the primary review responsibility for SRP Sections 5.2.4 and 6.6.
To assist applicants in the preparation of these programs and to expedite the review process, the attached guidance is provided for the Wolf Creek Plant, Unit 1 for incorporation into the FSAR as an FUEB question.
Responses to the enclosed request should be submitted by September 1,1981.
Please inform us within seven days after receipt of this letter of the date you plan to submit your responses.
Please contact Mr. Dromerick, Licensing Project Manager, if you desire any discussion or clarification of the enclosed request.
Sincerely, d "A-i Robert L. Tedesco, Assistant Director for Licensing i
I Division of Licensing
Enclosure:
As stated l
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Mr. Glenn L. Koester Vice President - Nuclear Kansas Gas and Electric Company 201 North Market Street P. O. Box 208 Wichita, Kansas 67201 cc: Mr. Nicholas A. Petrick Ms. Wanda Christy Executive Director, SNUPPS 515 N. 1st Street 5 Choke Cherry Road Bulington, Kansas 66839 Rockville, Maryland 20750 Floyd Mathews, Esq.
Mr. Jay Silberg, Esquire Birch, Horton, Bittner & Monroe Shaw, Pittman, Potts & Trowbridge 1140 Conecticut Avenue. N. W.
1800 M Street, N. W.
Washington, D. C.
20036 Washington, D. C.
20036 Kansas for Sensible Energy Mr. Donald T. McPhee P. O. Box 3192 Vice President - Production Wichita, Kansas 67201 Kansas City Power and Light Company 1330 Baltimore Avenue Francis Blaufuse P. O. Box 679 Westphalia, Kansas 66093 Kansas City, Missouri 64101 Ms. Mary Ellen Salva Route 1, Box 56 Burlington, Kansas 66839 Mr. L. F. Drbi Missouri-Kansas Section:
American Nuclear Society 15114 Navaho Olathe, Kansas 66062 Ms. Treva Hearne, Assistant General Counsel Public Service Commission P. O. Box 360 Jefferson City, Missouri 65102 Mr. Tom Vandel Resident Inspector / Wolf Creek NPS c/o USNRC P. O. Box 1407 Emporia, Kansas 66801 Mr. Michael C. Kenner Wolf Creek Project Director State Corporation Commission State of Kansas Fourth Floor, State Office Bldg.
Topeka, Kansas 66612
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ATTACHMENT 1 250.0 MATERIALS ENGINEERING BRANCH 250.1 We 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). Accordingly, submit the following information:
(1) A preservice inspection plan which is consistent with the required edition of tne ASME Code. This inspection plan should include any exceptions you propose to the Code requirements.
(2) An inservice inspection olan submitted within six months of the anticipated date for commercial operatior..
This preservice inspection plan will be required to support the safety evaluation report finding regarding your compliance with preservice and inservice inspection requirements. Our determination 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 to this item 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, including complete technical justification to support your request.
Detailed guidelines for the preparation and content of the inspection programs to be submitted for staff review and for relief requests are attached as an Appendix to Section 121.0 of our review questions.
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APPENDIX TO SECTION 250.0 GUIDANCE FCR PREPARING PRESERVICE AND INSERVICE INSPECTION PROGRAMS AND RELIEF REQUESTS PURSUANT TO 10 CFR 50.55a(9)
A.
Description of the Preservice/ Inservice Inspection Procram This program should cover the requirements set forth in Section 50.55a(b) and (g) of 10 CFR Part 50; the ASME Boiler and Pressure Vessel Code,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 appropriate addenda date.
2.
The period and 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 mignt 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 cf the components.
Provide the information requested in the follow 1 J section of this appendix for the inspections and pressure tests t ientified in Item 4 above.
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C.
Reouest for Relief from Certain Inspection and Testino Reouirements 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 tecnnical 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 tne 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 infomation 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 t< amination 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 specific ASME Code requirement that has been detemined to be impractical.
i 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 perfomed partially in compliance with the requirements of Section XI.
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A description and justification of any changes expected in the overall level of plant safety by performing the proposed alternative examinations in lieu of the examination required by 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 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 excmina-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.
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 facMities, of those areas where relief will be necessary and should submit as a minimum, the followjng information with the request for relief:
1.
The total estimated man-rem exposure involved in the examinatio'n.
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 ti:e consequences if the weld which was not examined, did fail.
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