ML20199A144

Safety Evaluation Accepting Relief Request for Delayed Implementation of 10CFR50.55a,until 971231 or Plant Restart, Whichever Occurs First

ML20199A144
Person / Time
Site:	Crystal River
Issue date:	01/09/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20199A142	List: ML20199A138 ML20199A144
References
NUDOCS 9801270129
Download: ML20199A144 (4)

Text

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ng\. UNITED STATES -

j '- NUCLEAR REGULATORY COMMISSION -

WASHINGTON, D.C. EsseMeet A- .....

p SAFETY EVALUATION BY THE NUCLEAR REGULATORY COMMISSION

,RE.lEF REQUEST FROM THE IMPLEMENTATION DE. L THE REPAIR AND REPLACEMENT ACTIVITIES FOR CONTAINMENT I

FLORIDA POWER CORPORATION. ET AL.

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CRYSTAL RIVER. UNIT NO. 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302

1.0 INTRODUCTION

By Federal Register Notice No.154, Volume 61, dated August 8,1996, the U.S. Nuclear '

Regulatory Commission (NRC) amended its regulations to incorporate by reference the 1992 edition with the 1992 addenda of Subsections IWE and IWL of Section XI of the ASME Boiler and Pressare Vessel Code. Subsections lWE and IWL provide the requirements for inservice inspection (ISI) of Class CC (concrete containments), and Class MC (metallic containments) of the light-water cooled power plants.. The effective date for the amended rule was September 9, 1996, and it requires the licensees to incorporate the new requirements into their ISI plans and to complete the first containment inspection within 5 years, that is, by September 9,2001, Since the amended rule Lecame effective on September 9,1996, any repair or replacement activity to be performed for the containments after that date has to be in accordance with the respective requirements of Subsections IWE and IWL. However, a licensee can submit a request for relief for the date of implementation of its containment repair and replacement (R/R) activities with proper justification. The provision for granting relief is incorporated in the regulation.

1 By letter dated August 21,1997, as supplemented October 30,1997, and pursuant to 10 CFR 50.55a(a)(3)(i) and (ii), Florida Power Corporation (FPC or the licensee) submitted a request

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for relief from the immediate implementation of tha r quirements of the ASME Boiler and Pressure Vessel Code,Section XI,1992 edition with the 1992 Addenda,' Articles IWA 4000,

- _lWE-4000, and IWL 4000 of Subsections IWA, IWE, and IWL, related to the containment R/R

~ activities. This evaluation addresses the merits of the relief requests for Crystal River 3.

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2-2.0' BASIS FOR REllEE

The relief request is based on the licensee's justification that immediata compliance with'the :

requirements of the rule for R/R activities would result in unusual difficulty without a

. compensating increase in the level of safety and quality as recognized in the Nucleu J Regulatory Commission (NRC) Information Notice 97-29. ' Some of the reasons, as stated by the licensee, are discussed below.

L 1. Ider,urication of the applicable bouridpries (e.g.. drawing / document development. ,

preparation. and issuance).

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_ in order to ensure taniponents are properly identified as Class MC or Class CC during

, - the maintenance and/or_ modification work process, it will be necessary to classify 1

containment components using Class MC and CC classification criteria. This effort will include the retrieval and review of applicable design'and construction records and plant

, walkdowns.

2. Revision of applicable plant procedures related to maintenance and modification work

, package oreparation To achieve full implementation of the IWEllWL repair and replacement program, the requirements of IWA 4000, IWE-4000, and IWL-4000 must be incorporated into all .

L . plant procedures.

3. Develonment of nondestructive examination and trainina orocedures in coniunction with

. Dersonnel certification to imolement oreservice examination roouirements, f-..

The personnel certification program at CR3, including nondestructive examination and

. . training procedures, currently meets the requirements of the 1983 Edition of ASME Section XI, Summer 1983 Addenda; in accordance with the 1983 Edition of ASME -

Section XI, personnel performing visual VT-3 examinations are certified to ANSI-N45.2.6. Personnel performing other NDE methods are certified in accordance with

l. ' SNT-TC-1 A The 10 CFR 50.55a rule change mandated the implementation of the

, 1992 Edition of ASME Section XI for IWE and IWL which requires that all NDE examiners be certified in accordance with an employer's written practice to ANSI /ASNT CP-189. Compliance with the rule will require that FPC develop a new personnel.

7-certification program to meet the 1992 edition of ASME Section XI for IWE and IWL.

The use of personnel certified to the' current code does not reduce the level of quality or

[ ' safety.-

L 3.0 PROPOSED ALTERNATIVE l =

;The licensee has provided a oescription of the procedures that it will use until full compliance is o

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3-The licensee states that "[WJork related to the containment boundary and its attachments is being reviewed by engineering to determine IWE and IWI. applicability and to conservatively classify comportents as Ciass CC or MC as required.- Examinations prior to and folk, wing - _

repairs or replacements are being performed as required by the 1992 Edition with the 1992 Addenda of Subsections IWE and IWL, with the exception that nondestructive examination (NDE) personnel will be certified to the 1983 Edition of ASME Section XI and qualified to the 11984 Edition of SNT-TC-1A. Adverse conditions identified are being evaluated as part of the corrective action program to ensure design requirements are met."

'The proposed altemate examinations provide the necessary controls to assure the continued abliity of the CR 3 containment structure to perform its intended function. The process of performing altemate examinations discussed above is controlled by procedures at CR-3. The process includes review and approvaj of work requests by angineers and managers in the CR-3 engineering group responsible for ASME code compliance. These individuals are i knowledgeable in the requirements of the ASME code. Based on this, FPC considers these procedures to be effective in ensuring that any repair and replacement work on containment will

' be performed in accordance with requirements of IWE and IWL The proposed altemative, therefore, will provide an acceptab's level of quality and safety for CR-3.

4.0 EVALUATION

- In Information Notice 97-29, the NRC staff informed licensees that their requests for relief should demonstrate that procedures are in place to ensure adequate safety of the containment and proper qual _ity assurance requirements have been implemented. By letter dated October

. 30,1997, . FPC requested that the duration of the relief extend until December 31,1997, or the date of CR-3 restart, whichever occurs first. Until that date. all R/R conducted on Class CC and Class MC components and their integral supports will be F .med as follows.

The process of performing the attemate examinations is controlled by CR-3 procedures, which

= in tum are based on the requirements of Quality Assurance Criteria of Appendix B of 10 CFR Part 50.- Also, the inspection and R/R activities related to the containment post-tensioning -

tendons are govemed by the CR 3 Technical Specification.

The staff consit:lers the attemative program for R/R activities reasonable and acceptable during the period of relief in that it provides assurance of structural integrity and that actions will be

- taken to ensure that design requirements are met.

In order to comply immediately with the rule, the licensee would need to complete several activities, such as retrieval and review applicable design and construction records, modification of plant procedures, and development of training procedures in a time frame that would result in

unusual difficulty without a compensating increase in the leve' of safety and quality. Based on

the above, the staff finds that the licensee's proposed altema 've to implement the requirements of the rule for the containmant repair and replacement (R/R) activities starting

' January 1,1998, or the date of the restart of the Unit, whichever occurs first, to be acceptable.

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3.0 CONCLUSION

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Based on the review of the information provided in the relief request and the response to the staffs request for additional information, the staff finds the temporary use of the current procedure for containment repair and replacement activities, instead of the requirements of the amended 10 CFR 50.55a rule, to be reasonable and acceptable. Also, the staff concludes that immediate compliance with the requirements of the amended rule for containment repair and

. replacement activities during the period September 9,1996 through December 31,1997 (or CR 3 restart whichever occurs first), would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the request for relief dated August 21,1997 (as revised on October 30,1997), to delay implementation of the rule for repair and replacement activities until January 1,1998, is acceptable for authorization pursuant to 10 CFR 50.55a(a)(3)(ii). .

Principal Contributor: H. Ashar, NRR Date: January 9, 1998 4