ML20012A991

Technical Evaluation Rept on First 10-Yr Interval Inservice Insp Program Plan:Houston Lighting & Power Co,South Texas Project Electric Generating Station,Unit 1.

ML20012A991
Person / Time
Site:	South Texas
Issue date:	11/30/1989
From:	Beth Brown, Mudlin J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20012A982	List: ML20012A991
References
CON-FIN-D-6022 EGG-MS-5848, NUDOCS 9003130166
Download: ML20012A991 (20)

Text

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^ *' . TECHNICAL EVALUATION REPORT l

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- - TECHNICAL EVALUATION REPORT ON THE FIRST 10-YEAR 4.

idshe 1 INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

Nagoras/  ; HOUSTON LIGHTING AND POWER COMPANY, -

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, gagg g gg UNIT I, DOCKET NUMBER 50 498  :

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Prepared for the

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i TECHNICAL EVALUATION REPORT ON THE FIRST 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN: .

HOUSTON LIGHTING AND POWER COMPANY, i SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNIT 1, DOCKET NUMBER 50-498 ,

B. W. Brown J. D. Mudlin 1

F Published November 1989 }

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Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 i i Prepared for:

l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 under L DOE Contract No. DE-AC07-761001570

' FIN No. 06022 (Project 5) 1

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i ABSTRACT l

This report presents the results of the evaluation of the South Texas  !

Project Electric Generating Station, Unit 1, first 10 year interval

' inservice inspection (ISI) program plans, submitted February 22, 1988, and  ;

- the requests for relief from the American Society of Mechanical Engineers l (ASME) Boiler and Pressure Vessel Code Section XI requirements which the ,

Licensee has determined to be impractical, submitted May 11, 1989. The i South-Texas Project Electric Generating Station, Unit 1, first 10 year interval IS! program plans are evaluated in Section 2 of this report. The i ISI program plans are evaluated for (a) compliance with the appropriate i edition / addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination  ;

exclusion criteria, and (d) compliance with ISI related commitments identified during the Nuclear Regulatory Commission (NRC) review before granting an operating license. The requests for relief are evaluated in Section'3 of this report.

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h This work was funded under:

' U.S. Nuclear Regulatory Commission ,

FIN No. D6022, Project 5

! Operating Reactor Licensing Issues Program, Review of :SI for ASME Code Class 1, 2, an.t 3 Components ii

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SUMMARY

The Licensee, Houston Lighting and Power Company, has prepared the South Texas Project Electric Generating Station, Unit 1, first 10-year interval i I

inservice inspection (ISI) program plans to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that i the extent of examination for Code Class 2 piping welds has been determined  ;

by ASME Code Case N-408 as approved for use by Regulatory Guide 1.147. The i first 10-year interval began August 25, 1988 and-ends August 25, 1998.

The following South Texas Project Electric Generating Station, Unit 1, documents were reviewed: Inservice Inspection Plan For The First Inspection Interval, First 10-Year Interval Long Term Inservice Examination Plan (2 volume set), and the Inservice Inspection Examination of Component  :

Supports. Included in the review were requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical for the first 10-year interval.

t Based on the review of the South Texas Project Electric Generating Station, Unit 1, first 10 year interval ISI program plans and the recommendations for l granting relief from the ISI examination requirements that have been L determined to be impractical, it is concluded that the South Texas Project Electric Generating Station, Unit 1, first 10-year interval ISI program i plans are acceptable and in compliance with 10 CFR 50.55a(g)(4).

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CONTENTS L ABSTRACT ................................................................ ii

SUMMARY

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1. INTRODUCTION ........................................................

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2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN ..................... 3 2.1 Documents Evaluated .............................................. 3 2.2 Compliance with Code Requirements ................................ 3 c

2.2.1 Compliance with Applicable Code Editions . . . . . . . . . . . . . . . . . . . . . 3 2.2.2 Acceptability of the Examination Sample ...................... 4 4

2.2.3 Exclusion Criteria ...........................................

4 2.2.4 Augmented Examination Commitments.............................

5 2.3 Conclusions ......................................................

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3. EVALUATION OF RELIEF REQUESTS .......................................

3.1 Class 1 Components ............................................... 6 3.1.1 Reactor Pressure Vessel (No relief requests) 6 L 3.1.2 Pressurizer ..................................................

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3.1.2.1 Request for Relief RR-ENG-09, Examination Category B-H, Item B8.20, Pressurizer Support  !

Skirt Weld ............................................... 6  !

3.1.3 Heat Exchangers and Steam Generators (No relief requests) 3.1.4 Piping Pressure Boundary (No relief request;;

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i 3.1.5 Pump Pressure Boundary (No relief requests)

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3.1.6 Valve Pressure Boundary (No relief requests) 3.1.7 General (No relief requests) 3.2 Class 2 Components .............................................. 8 8

3.2.1 Pressure Vessels ............................................

l 3.2.1.1 Request for Relief RR-ENG-08, Examination l Category C-8, Item C2.22, Steam Generator Main Steam Nozzle Inside Radius Section .................. 8 l

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-3.2.2 Piping (No relief requests) 3.2.3 Pumps (No relief requests) 3.2.4 Valves (No relief requestr) j 3.2.5 General (No relief requests) 3.3 Class 3. Components (No relief requests) j 3.4 Pressure Tests (No relief requests) )

i 3.5 General (No relief requests) l

4. CONCLUSION ......................................................... 10

5. REFERENCES ......................................................... 12 I

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TECHNICAL EVALUATION REPORT ON THE I I

FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN:

"; HOUSTON LIGHTING AND POWER COMPANY, i SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNIT 1, l DOCKET NUMBER 50-498 I

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1. INTRODUCTION Throughout the service life of a water cooled nuclear power facility, 10 CFR 50.55a(g)(4) (Reference 1) requires that components (including supports) which are classified as American Society of Mechanical Engineers  ;

i (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except the design and access provisions and the preservice ,

examination requirements, set forth in the ASME Code Section XI, " Rules for Inservice Irspection of Nuclear Power Plant Components," (Reference 2) to the extent practical within the limitations of design, geometry, and -

materials of construction of the components. This section of the

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regulations also requires that inservice examinations of components and system pressure tests conducted during the initial 120-month inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the L date 12 months prior to the date of issuance of the operating license, subject to the limitations and modifications listed therein. The components -

f (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in i 10 CFR 50.55a(b) subject to the limitations and modifications listed therein. The Licensee, Houston Lighting and Power Company, has prepared the l l

Scuth Texas Project Electric Generating Station, Unit I, first 10-year i

interval inservice inspection (ISI) program plans to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examination for Class 2 piping welds has been determined by ASME Code Case N-408 (Reference 3) as approved for use by Regulatory L* Guide 1.147 (Reference 4). The first 10-year interval began August 25, 1988 and ends Augu.it 25, 1998.

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief from them, 1

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the liconi:ee shall submit information and justificati6ns to the Nuclear Regulatory Commission (NRC) to support that Jetermination.

Pursuant to 10 CFR 50.55a(g)(Q, the NRC will evtluate the licensee's determinations under 10 CFR 50.55a(g)(5) that Code requirements are  ;

impractical. The NRC may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life or property or the common defense and security, and are otherwise in-  ;

the public interest, giving due consideration to the burden upon the

. licensee that could result if the requirements were imposed on the facility. ]

The inTorration in the South Texas Project Electric Generating Station, Unit 1. first 10-year interval ISI program plans, submitted February 22. 1988 (References 5, 6, and 7), was reviewed including the  ;

requests for relief from the ASME Code Section XI requirements which the ,

Licensee has determined to be impractical for the first 10 year interval.

The requests for relief wen received in a submittal dated May 11, 1989 ,

(Reference 8). The reviw of the IS! program plans was performed using the l

Standard Review Plans of NUREG-0800 (Reference 9), Section 5.2.4, " Reactor [

Coolant Boundary Inservice Inspections and Testing," and' Section 6.6, ,

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. "hservice Inspection of Class 2 and 3 Components."

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L The South Texas Project Electric Generating Station, Unit 1, first 10-year interval ISI program plans are evaluated in Section 2 of this report. The l 151 program plans are evaluated for (a) compilance with the apprcpriate l edition / addenda of Saction XI, (b) acceptability of examination sample.

l (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI-related commitments ider.tified during the NRC review before granting an operating license.

The requests for relief are evaluated in Section 3 of this report. Unless otherwise stated, references to the Code refer to the ASME Code,Section XI, 1983 Edition, including Addenda through Summer 1983. Specific inservice test (IST) programs for pumps and valves are being evaluated in other reports.

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2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN i

This evaluation consisted of a review of the applicable program documents to 7 determine whether or not they are in compliance with the Code requirements j and any license conditions pertinent to ISI activities. This section ,

describes the submittals reviewed and the results vi the review.

J 2.1 Documents Evaluated Review has been completed on the following information from the Licensee:

(a) Inservice Inspection Plan For The First Inspection Interval Of The South Texas Project Electric Generating Station - Unit 1, issued February 1988 i t

(Reference 5);

(b) First 10 Year Interval Long-Term Inservice Examination Plan For The South Texas Project Electric Generating Station, Unit 1, (2 volume set) dated February 1988 (Reference 6); .

f (c) Inservice Inspection Examination Of Component Supports Of South Texas Project Electric Generating Station Unit 1, First Inspection Interval, dated February 19, 1988 (Reference 7); and (d) letter, dated May 11, 1989 (Reference 8), Licensee's submittal of the requests for relief for the first 10-year interval. 4 s

2.2 Comoliance with Code Reouireg n u i 2.2.1 Como11ance with Aeolicable Code Editions The inservice inspection program plan shall be based on the Code editions .

defined in 10 CFR 50.55a(g)(4) and 10 CFR 50.55a(b). Based on the -

operating license date of August 21, 1987, the Code applicable to the - ,

! first 10-year interval ISI program is the 1983 Edition with Addenda L

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'through Summer 1983. As stated in Section 1 of this report, the Licensee  ;

has written the South Texas Project Electric Generating Station, Unit 1, first 10-year interval ISI program plans to meet the applicable Code '

requirements except that the extent of examination for Code Class 2 piping welds has been determined by ASME Code Case N 408, " Alternative Rules for i Examination of Class 2 Piping,Section XI, Division 1." Code Case N-408 is referenced 'n NRC Regulatory Guide 1.147 Revision 5, as an NRC approved Code case and, therefore, may be used.  :

2.2.2' Accentab111tv of the Examination Samole Inservice volumetric, surface, and visual examinations shall be performed l

on ASME Code Class 1, 2, and 3 components and their supports using sampling schedules described in Section XI of the ASME Code and {

10 CFR 50.55a(b). Sample size and weld selection have been implemented in accordance with the Code and 10 CFR 50.55a(b) and appear to be correct. l 2.2.3 Exclusion Criteria The criteria used to exclude components from examination shall be '

consistent with Paragraphs IWB-1220, IWC-l'220, IWC-1230, IWD-1220, and 10 CFR 50.55a(b). The exclusion criteria have been applied by the ,

licensee in accordance with the Code as discussed in Section II.E of the First 10-Year Interval Long-Term Inservice Examination Plan for the South Texas Project Electric Generating Station, Unit 1, and appear to be ,

correct.

2.2.4 Auamented Examination Commitments In addition to the requirements as specified in Section XI of the ASME Code and Code Case N 408, the Licensee has committed to meet the inspection requirements contained in the following documents:

2 (a) NUREG-0800, Standard Review Plan 3.6.1, " Plant Design for Protection Against Postulated Piping Failures in Fluid Systems Outside Containment" (Reference 9),; .

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. i q.. o IE Bulletin No. 79-17, " Pipe Cracks in Stagnant Borated Water j (b)

Systems at PWR Plants" (Reference 10);

l (c) South Texas Project, FSAR Section 5.3.3.7 requires a VT 3 visual j examination of the interior surfaces of the Reactor Pressure Vessel  :

closure head in accordance with the examination frequency i requirements of Examination Category B N 1; j i

(d) Regulatory Guide 1.14. Revision 1, " Reactor Coolant Pump Flywheel l Integrity" (Reference 11);

(e) Regulatory Guide 1.65, Revision 0, " Materials and Inspection for ,

Reactor Vau,el Closure Studs" (Reference 12); and ,

(f) Regulatory Guide 1.150, Revision 1 " Ultrasonic Testing of Reactor Pressure Vessel Welds During Preservice and Inservice Examinations" (Reference 13).

These inspection requirements are being met as outlined in Sections !!I.D and III.E of the First 10 Year Interval Long Term Inservice Examination  :

Plan For The South Texas Project Electric Generating Station, 'Mit 1.

2.3 Conclusions Based on the review of the documents listed above, it is concluded that the ,

South Texas Project Electric Generating Station, Unit 1, first 10 year interval ISI program plans, as submitted February 22, 1988, are acceptable and in compliance with 10 CFR 50.55a(g)(4).

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3. EVALUATION OF RELIEF REQUESTS li i

l The requests for relief frt"n the ASME Code requirements that the Licensee j

- has determined to be impractical for the first 10-year. inspection interval l are evaluated in the following sections.

3.1 Class 1 Comoonents  :

3.1.1 Reactor Pressure Vessel (No relief requests)  !

3.1.2 Pressurizer l

- . _ _ _ . _ 3.1.2.1 Raouest for Relief RR.ENG 09. Examination Cateoory B-H. }

Item B8.20. Pressurizer Suncort Skirt Weld Code Reauirement: Section XI, Table IWB-2500 1, Examination j Category B H, Item B8.20 requires 100% of the weld length of ,

Pressurizer integrally welded attachments to be surface or ,

volumetrically examined, as applicable, as defined by i i

Figures IWB-2500-13, -14, or -15.

licensee's Code Relief Regi11: Relief is recuested from ,

examining 100% of the Code rcquired surface of Pressurizer  ;

support skirt to-lower head Weld IR111NPZ101A, as defined by  ;

Figure IWB-2500-13 in Section XI of the Code.  !

f U censee's Proposed Alternative Examination: In lieu of a l magnetic particle (MT) examination of the inside surface (surface area C-D in Figure IWB-2500-13) of the skirt attachment weld, the Licensee will perform an ultrasonic (UT) examination from the outside surfaces of the attachment weld [

and adjacent base materials. An MT examination will be conducted on the exterior surfaces of the attachment weld and adjacent base materials (surface area A-B) in accordance with  !

Code requirements. ,

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Licensee's Basis for Recuestino Relief: Surface area C-D is j inaccessible for surface examination. Access'to this area is  :

restricted by the pressurizer heaters which are located j approximately 13 inches from the inside surface of the support  !

skirt.

The Licensee reports that the proposed alternative examination l provides coverage of the interior surfaces that would have been examined by the internal MT examination. Furthermore, this UT i examination provides coverage of the attachment weld and -

portions of adjacent base material volumes not obtainable by MT examination. ,

Evaluation: Based on the design of the support skirt attachment, the surface examination of the subject weld is impractical to perform to the extent required by the Code. A significant percentage (surface area A B) of the Code-required surface examination can and will be performed. The remainder of the weld (surface area C D) is inaccessible for surface examination.-

o The proposed alternative UT examination provides a level of i assurance of structural integrity that is equivalent, if not superior, to that obtainable ?;4 Rn MT examination performed on the interior surfaces of the 4Ltachment weld.

Conclusions:

Based on the above evaluation, it is concluded that the Code-required examination is impractical to perform to the extent required by the Code and that the limited Section XI surface examination, in conjunction with the Licensee's proposed alternative UT examination, meets or exceeds the intent of the Code. Therefore, it is recommended that relief be granted as reqQested.

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3.1.3 Heat Exchancers and Steam Generatori (No relief requests) 3.1.4 Pinina Pressure Boundary (Noreliefrequests) 3.1.5 Pi=a Pressure Boundarv (No relief requests) 3.1.6 Valve Pressure Boundarv (No relief requests) 3.1.7 General (No relief requests) 3.2 [ lass 2 Comoonents 3.2.1 Pressure Vessels

_ 3.2.1.1 Recuest for Relief RR-ENG 08. Examination Cateoory C-B.

Item C2.22. Steam Generator Main Steam Nozzle Inside Radigt.

Section Code Reauirement: Section XI, Table IWC-2500-1, Examination Category C-B, Item C2.22 requires a 100% volumetric examination of Class 2 vessel nozzle inside radius sections as dafined by ll Figure IWC-2500-4.

f Licensee's Code Relief Reouest: Relief is requested from performing 100% of the Code-required volumetric examination of the inside radius sections of the Steam Generator main steam nozzles.

l licensee's Procosed Alternative Examination: None licensee's Basis for Reauestina Relief: The subject Steam Generator main steam nozzles are fabricated as a one-piece forging containing a set of seven holes bored parallel to the nozzle centerline. A flow restrictor is installed in each of

. ,these holes.

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. o g? . i The Licensee reports that, since the ligaments between the.  ;

I holes distribute the stresses throughout the nozzle forging, there is no high-stress, inside radius section for this main j steam nozzle design. Therefore, the Section XI nozzle inside l radius section examination requirements are not applicable to l the subject main steam nozzles. i Evaluation: The main steam nozzle was designed with an ,

internal multiple hole type flow restrictor. This design does not use a radiused nozzle as described in Figure IWC-2500-4, but instead has several individual inner radii corresponding to  !

l each hole. Therefore, the Code-required volumetric examination j of the nozzle inner radius section is impractical to perform. l 1

Conclusions:

Based on the above evaluation, it is concluded that the Code required examination is impractical to perform.

Therefore, it is recommended that relief be granted as i requested, i 3.2.2 Pioina (No relief requests) 3.2.3 f.umD.1 (No relief requests) 3.2.4 Valves (No relief requests) 3.2.5 General (No relief requests) ,

, 3.3 Class 3 Comoonents (No relief requests) 3.4 Pressure Tests (No relief requests) '

3.5 General (No relief requests) ,

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4. CONCLUSION l Pursuant to 10 CFR 50.55a(g)(6), it has been determined that certain  :

Section XI required inservice examinations are impractical to perform. In  ;

all cases, the Licensee has demonstrated that specific Section XI [

requirements are impractical.

This technical evaluation report has not identified any practical method by -

which the Licensee can meet all the specific inservice inspection  ;

requirements of Section XI of the ASME Code for the existing South Texas Project Electric Generating Station, Unit 1, facility. Requiring compliance with all the exact Section XI required inspections would require redesign of j components such as the Pressurizer support skirt and the Steam Generator -}

main steam nozzles. Replacement components would need to be obtained, j installed, and a baseline examination performed. Even after the redesign efforts, complete compliance with the Section XI examination requirements

! may not be achieved. Pursuant to 10 CFR 50.55a(g)(6), relief is allowed .

! from these requirements which are impractical to uplement if granting the l relief will not endanger life or property or the commen defense and security  ;

and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed ,

on the facility. Therefore, it is concluded that the public interest is not served by imposing certain provisions of Section XI of the ASME Code that have been determined to be impractical, i

The development of new or improved examination techniques should continue to be monitored. As improvements in these areas are achieved, the Licensee should incorporate these techniques in the ISI program plan examination ,

requirements.

Based on the review of the South Texas Project Electric Generating Station, Unit 1, first 10-year interval inservice inspection program plans, as submitted February 22, 1988, and the recommendations for granting relief from the ISI examination requirements that have been determined to be 10

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1 impractical. it is concluded that the South Texas Project Electric j

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Generating Station, Unit 1, first 10 year interval inservice inspection program plans, as submitted February 22, 1988, are acceptable 'and in l t

. compliance with 10 CFR 50.55a(g)(4). l' i

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5. REFERENCES ;f

1. Code of Federal Regulations, Volume 10, Part 50. j

2. American Society of Mechanical Engineers Boiler and Pressure Vessel  :

Code,Section XI, Division 1, 1983 Edition through Summer 1983 Addenda.

3. American Society of Mechanical Engineers Boiler and Pressure Vessel '

Code,. Code Cases - Nuclear Components, 1986 Edition.

4. USNRC Regulatory Guide 1.147, " Inservice Inspection Code Case  !

Acceptability, ASME Section XI Division 1," Revision 5, August 1986.

5. Inservice Inspection Plan for the First Inspection Interval of the South '

Texas Project Electric Generating Station Unit 1, issued February 1988.

6. First 10-Year Interval Long Term Inservice Examination Plan for the ,

South Texas Project Electric Generating Station, Unit 1, (2 volume set) dated February 1988. .

7. Inservice Inspection Examination of Component Supports of South Texas Project Electric Generating Station - Unit 1, First Inspection Interval,- '

dated February 19, 1988.

8. Letter, dated May ll, 1989, M. A. McBurnett (Houston Lighting and Power Company (HL&PC)] to NRC, submitting the ISI relief requests applicable for the first 10-year inspection interval. B

9. NUREG-0800, Standard Review Plans, Section 3.6.1, " Plant Design for Protection Against Postulated Piping Failures in Fluid Systems Outside Containment, Section 5.2.4, " Reactor Coolant Boundary inservice Inspection and Testing," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components," July 1981.

10. IE Bulletin No. 79-17, " Pipe Cracks in Stagnant Borated Water Systems at PWR Plants," Revision 1, October 29, 1979.

11. USNRC Regulatory Guide 1.14. " Reactor Coolant Pump Flywheel Integrity,"

Revision 1, August 1975.

12. USNRC Regulatory Guide 1.65, " Materials and Inspections for Reactor Vessel Closure Studs," Revision 0, October 1983,

13. USNRC Regulatory Guide 1.150, " Ultrasonic Testing of Reactor Vessel '

Welds During Preservice and Inservice Examinations," Revision 1.

February 1983.

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' #W e BIBUOGMAPHIC DATA SHEET j o . .,wn..~ ..u-. , ,

ot a .~o s.:t EGG MS-8548

• Technical Evaluation Report on the First 10-Year .

)

Interval Inservice Inspection Program Plan: cars.incer .. sus-to

.aov- -

Houston Lighting and Power Company, November ; 198h*=

South Texas Project Electric Generating Station, Unit 1, Docket Number 50-498 43 ~ oa caast wvrea FIN-06022 (Proj. 5) ,

s.awT cens, s tvas c, asecar  ;

Technical  !

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B.W. Brown, J.D. Mudlin uno *ooaiss ,,...c.- c, .. .w.a . -

agegagga,uizitios s EG&G Idaho, Inc. 3 J

P. O. Box 1625 )

Idaho Falls, ID 83415-2209

<,,..c. a . .., .-..c e. .o - .va , c e saoggcamzation . sacs ano aocaass Materials and Chemical Engineering Branch Office of Nuclear Reactor Regulation j U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .

10. suaPLiw(NTAmy Notts i t. ASsTa ACT use m ., ,

L l This report presents the results of the evaluation of the South Texas Project f i Electric Generating Station, Unit 1, first 10-Year interval inservice inspection l (ISI) program plans, submitted February 22, 1988, and the requests for relief from i the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code i Section XI requirements which the Licensee has determined to be impractical, submitted May ll, 1989. The South Texas Project Electric Generating Station, Unit 1, first 10-Year interval ISI program plans are evaluated in Section 2 of this .

I report. The ISI program plans are evaluated for (a) compliance with the appropriate '

edition / addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion l

criteria, and (d) compliance with ISI-related commitments identified during the Nuclear Regulatory Commission (NRC) review before granting an operating license.

The requests for relief are evaluated in Section 3 of this report. ,

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