ML20138E871
Text
_.
o
~
-b
~"
1 L OCKHE ED M A R TIN Lockideed Idaho Technok,gles Cosepany P. O. Box 1625 Idaho ralls,ID 83415 m Na8onst Eas***ar*w Laborsery October 24,1995 d
Mr. Thomas K. McLellan, Project Officer c/o Document Control Desk Civil Engineering & Geosciences Branch Division of Engineering U.S. Nuclear Regulatory Conunission Washington, DC 20555 4
1 TRANSMITTAL OF THE TECHNICAL LEITER REPORT ON THE SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN, REQUEST FOR RELIEF REGARDING CODE CASE
]
N-532 FOR ST. LUCIE NUCLEAR PLANT, UNITS 1 AND 2 - MTA-44-95
Reference:
NRC Form 189, " Technical Me in Support of the NRC Inservice Inspecuon 1
Program" (JCN-J2229, Technical Work Assignment TWA-B29, NRC TAC No. M93297 and M93298) 1
Dear Mr. Mclellan:
This report completes the INEL review of the subject request for relief for the second 10-year ISI innerval at St. Lucie Nuclear Plant, Units 1 and 2. ~1his request was submitted by Florida Power and Light Company in a letter dated August 11,1995.
This report completes the INEL work under Technical Work Assignment TWA-B29 of NRC JCN-J2229 for NRC TAC Nos. M93297 and M932';8.
Sincerely, M. T. Anderson, Principal Investigator NDE Engmeering Analysis and Applications Enclosure ec:
S. F. Armour, DOE-ID, MS 1219 G. Baschi, NRR, MS 7H15 (w/o Enct)
D. Terno NRR, MS 7H15 (w/o EncI)
Q\\h 300043 j
yam a.g {g.
h$lubl o! O l I
y i
T
~
ATTACHNENT ?
TECHNICAL LETTER REPORT ON THE SECOND 10-YEAR INSERVICE INSPECTION INTERVAL REQUEST FOR APPROVAL TO INPLENENT CODE CASE N-532 FOR ST. LUCIE NUCLEAR PLANT, UNITS 1 AND 2 FLORIDA POWER AM LIGHT CONPANY DOCKET NUNBERS: 50-335 A M 50-389 2
1.0 INTRODUCTION
l j
By letter dated August 11, 1995, Florida Power and Light Company i
submitted a request to implement alternatives contained in Code Case N-532, Alternative Requirements to Repair and Replacement 00cumentation Requirements and Inservice Suanary Report Preparation and Subnission as Required by IWA-4000 and IWA-6000, for St. Lucie Nuclear Plant, Units 1 and 2.
The Idaho National Engineering Laboratory (INEL) staff has evaluated the subject request in the following section.
4 2.0 EVALUATION 1
The Code of record for the St. Lucie Nuclear Plant, Unit 1, second 10-year inservice inspection interval, which began February 11, 1988, is the 1983 Edition through the Summer 1983 Addenda of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI.
The Code of record for the St. Lucie Nuclear Plant, Unit 2, second i
10-year inservice inspection interval, which began August 8, 1993, is the 1989 Edition. The information provided by the licensee in support of the use of the alternatives to Code requirements contained in Code Case N-532 has been evaluated and the basis for disposition is documented below.
Reauest to Imolement Alternatives to Code Recordina and Reportino Reauirements Contained in Code Case N-532 Code Reauirement: Paragraph IWA-6220 requires that the licensee prepare reports using NIS-1, Owner's Report for Inservice Inspections, and NIS-2, 1
s j I' l
- i i
J t-i 4
i'
)
Owner's Report for Repair or Replacements; IWA-6230 requires that these feports be filed with the enforcement and regulatory authorities having j
jurisdiction at the plant site within 90 days of the completion of the l
inservice inspection conducted during each refueling outage.
j-
}
Licensee's Code Relief Reauest: The licensee requested relief from Code-required repair and replacement and inservice summary report documentation and submission requirements.
i h.
11 Licensee's Basis for Reauestina Relief (as stated):
l' "This Code Case was approved by the Code Committee on December 12, 1994, as an alternative to the requirements of IWA-4910(d).
IWA-6210(c),(d),
and (e), IWA-6220, IWA-6230(b), (c), and (d), and IWA-6240(b). -Use of'
!a this alternative reduces the significant burden for preparation and i
submittal of approximately 100-200 NIS-2 forms following repairs or replacement of components and for the preparation and submittal of the 2
inservice inspection summary report and Form NIS-1 after each refueling outage.
4
'i i
"By use of this code case, all inspections and tests completed each
] 'j -
refueling outage would be listed on the abstract and attached to an Owner Activity Report (Form OAR-1). -All 0AR-1 Forms would be submitted
- l
~q following the end of the inspection period."
p i
Licensee's Pronosed Alternative Examination Implement Code Case N-532.
i 1
Evaluation: The use of Form NIS-1, Owner's Report for Inservice i
Inspections, and Form NIS-2, Owner's Report for Repairs or Replacements, j
i4 i
and ' submittal of the 90-day Summary Report are Code requirements.
li Alternatives contained in Code Case N-532 allow the licensee to submit these records in an abstract format on Form NIS-2A, Repair / Replacement l
Certification Record, and Form OAR-1, Owner's Activity Report, fo11owing l'
the completion of an inspection period.
lr Based on review of the Code, the INEL staff has determined that
,[l requirements associated with the documentation of inservice examinations jl and repairs / replacements and the subsequent submittal of Forms NIS-1 and j
i j
s j
2 i
[
I
-j 1
f,
+
NIS-2 within 90 days following a refueling outage are administrative
'only.
It is noted that repair and replacement documentation reviews and approvals by the Authorized Nuclear Inspector continue to be required by this Code Case and that the licensee is required to establish a Repair / Replacement Plan in accordance with IWA-6340 of the 1992 Edition of Section XI.
The licensee has implemented Inspection Program 8 of the Code. Under this program, examination schedules are satisfied on a per period basis.
Considering the milestones associated with Inspection Progras 8, it can be concluded that the submittal of the results of examinations and an j
abstract of repairs / replacements on a periodic basis is a reasonable alternative.
In addition, the INEL staff believes that the use of forms l
contained in Code Case N-532, that provide a summary of the status of repairs / replacements and a more detailed status of examinations by period and interval, is an improvement over report forms currently required by the Code. For example, AOR-1 includes the status of examinations credited for a period and percent credited to date, for the interval, by-Examination Category. This type of information provides the regulatory authorities a more comprehensive report on the status of the inservice inspection program.
1 Considering that the Code recording and reporting criteria satisfy only administrative requirements, the INEL staff believes that use of the alternatives to Code requirements contained in Code Case N-532 will continue to provide an acceptable level of quality and safety for St. Lucie Nuclear Plant, Units 1 and 2.
3.0 CONCLUSION
The INEL staff has evaluated the licensee's request to implement i
alternatives to Code requirements contained in Code Case N-532, i
f Alternative Requirements to Repair and Replacement Documentation i
Requirements and Inservice Sunnary Report Freparation and Submission as i
Required by IWA-4000 and IWA-6000.
It has been determined that the 3
1 e
alternatives contained in Code Case N-532 ars only administrative changes to recording and reporting requirements for repairs / replacements and
)
inservice examinations.
Implementation of the alternatives contained in this Code Case will continue to provide an acceptable level of qua ity and safety for St. Lucie Nuclear Plant, Units 1 and 2.
Therefore, it is recommended that the alternatives contained in this request for relief be j
approved for use pursuant to 10 CFR 50.55a(a)(3)(i), provided that all requirements of Code Case N-532 are satisfied. Use of Code Case N-532 should be authorized until such time as the Code Case is published in a future revision of Regulatory Guide 1.147. At that time, if the licensee intends to continue to implement this Code Case, the licensee is to follow all provisions in Code Case N-532 with limitations issued in Regulatory Guide 1.147, if any.
4
)