ML20136D672
| ML20136D672 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/13/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20136C539 | List:
|
| References | |
| FOIA-96-485 NUDOCS 9703120457 | |
| Download: ML20136D672 (7) | |
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ATTACHMENT 1 k
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION e
1 0F THE SECOND TEN YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN REQUEST FOR RELIEF REQUESTING THE IMPLEMENTATION OF CODE CASE N-532 i.4
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FLORIDA POWER AND LIGHT COMPANY l
ST. LUCIE NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NUMBERS: 50-335 AND 50-389 i
1.0 INTRODUCTION
The Technical Specifications for Florida Power and Light Company state that i l the inservice inspection of the American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 components shall be performed in accordance with 1
4 Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(g), except where specific written relief has been 1-granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(1).
10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (1) the proposed alternatives g
j would provide an acceptable level of quality and safety or (ii) compliance i
with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of quality and 4
safety.
i Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components
- a (including supports) shall meet the requirements, except the design and access i
provisions and the preservice examination requirements, set forth in the ASME j
Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, i
geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first ten-year interval and subsequent intervals comply i
with the requirements in the latest edition and addenda of Section XI of the j
i ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to q
j the start of the 120-month interval, subject to the limitations and j
modifications listed therein. The applicable edition of Section XI of the r
1 ASME Code for the-St. Lucie Nuclear Plant Unit I second 10-year inservice inspection (ISI) interval is the 1983 Edition through Summer 1983 Addenda and the applicable edition of Section XI of the ASME Code for the St. Lucie Nuclear Plant, Unit 2 second 10-year inservice inspection (ISI) interval is 4
the 1989 Edition. The components (including supports) may meet the i
requirements set forth in subsequent editions and addenda of the ASME Code 4
incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Commission approval.
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Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance I
,1 with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission i
in support of that'oetermination and a request made for relief from the ASME Code requirement. After evaluation of the determination, pursuant to i
10 CFR 50.55a(g)(6)(1), the Commission may grant relief and may impose j
alternative requirements that are determined to be authorized by law, will not 97031204S7 970301 i
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endanger life, property, or the common defense and security, and are otherwise I
in the public i terest, giving due consideration to the burden upon the n
licensee that could result if the requirements were imposed.
In a letter dated August II, 1995, Florida Power and. Light Company submitted to the NRC its second ten-year interval inservice inspection program plan, request for i
relief regarding the implementation of Code Case N-532 Alternate Requirements to Repair and Replacement Documentation Requirenents and inservice Sunnary Report Preparation and Subnission as Required by IWA-4000 and IWA-6000 for St.
I Lucie Nuclear Power and Light Company, Units 1 and 2.
2.0 EVALUATION AND CONCLUSIONS The staff, with technical assistance from its contractor, the Idaho' National Engineering Laboratory (INEL), has evaluated the information provided by the licensee in support of ~its second ten-year interval inservice inspection program plan, request for relief regarding the implementation of Code Case N-532 Alternate Requirements to Repair and Replacement Documentation Requirements and Inservice Suanary Report Preparation and Subnission as Required by IWA-4000 and IWA-6000 for St. Lucie Nuclear Power and Light Company, Units 1 and 2.
1 Based on the information submitted, the staff adopts the contractor's i
conclusions and recommendations presented in the Technical Letter Report attached. The staff has concluded that the licensee's request to implement Code Case N-532, Alternative Requirements to Repair and Replacement e
Documentation Requirements and Inservice Sunnary Report Preparation and Subnission as Required by IWA-4000 and IWA-6000 as an alternative to the Code requirements will provide an acceptable level of quality and safety for St. Lucie Nuclear Plant, Units 1 and 2.
Therefore, the alternative contained in the request for relief is authorized pursuant to 10 CFR 50.55a(a)(3)(1),
provided that all requirements of Code Case N-532 are satisfied. Use of Code Case N-532 is 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.
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t ATTACHNENT 2 TECMICAL LETTER REPORT ON THE SEC" 10-YEAR DKreVICE IMSPECTION INTERVAL t
RE0 DEST FOR A?FaGWAL TO IMPLENENT CODE CASE N-532 fB ST. LUCIE ptEAR PL"~
UNITS 1 A M 2 FLORIDA POWER AL MT COMPANY D0CKET NUMBERS: 50,,; Am 50-389 l
1.0 INTRODUCTION
j By letter dated August 11, 1995, Florida Power and Light Company l
submitted a request to implement alternatives contained in Code Case N-532, Alternative Requirenents to Repair and Replacement Documentation Requirements and Inservice Sumnary Report Preparation and Subnission as Required by IWA-4000 and IWA-6000, for St. Lucie Nuc1 ear Plant, Units 1 and 2.
The I+.ho National Engineering Laboratory (INEL) staff has evaluated the subject request in the following section.
2.0 EVALUATION 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 10-year inservice inspection interval, which began August 8, 1993, is the i
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.
3 Reauest to Imolement Alternatives to Code Recordina and Reoortina i
Reauirements Contained in Code Case N-532 Code Raouirement: Paragraph IWA-6220 requires that the licensee prepare reports using NIS-1, Owner's Report for Inservice Inspections, and NIS-2, O
Qwner's Report for Repair or Replacements; IWA-6230 requires that these reports be filed with the enforcement and regulatory authorities having I
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jurisdiction at the plant site within 90 days of the completion of the inservice inspection conducted during each refueling outage.
Licensee's Code Relief Reauest: The licensee requested relief from Code-required repai.r and replacement and inservice summary report documentation and submission requirements.
Licensee's Basis for Reauestino Relief (as stated):
"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 this alternative reduces the significant burden for preparation and submittal of approximately 100-200 NIS-2 forms following repairs or replacement of components and for the preparation and submittal of the inservice inspection summary report and Form NIS-1 after each refueling outage.
"By use of this code case, all inspections and tests completed each 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 following the end of the inspection period."
Licensee's Proposed Alternative Examination Implement Code Case N-532.
Evaluation: The use of Form NIS-1, Owner's Report for Inservice Inspections, and Form NIS-2, Owner's Report for Repairs or Replacements, j
and submittal of the 90-day Summary Report are Code requirements.
Alternatives contained in Code Case N-532 allow the licensee to submit these records in an abstract format on Form NIS-2A, Repair / Replacement Certification Record, and Form CAR-1, Owner's Activity Report, following the completion of an inspection period.
Based on review of the Code, the INEL staff has determined that requirements associated with the documentation of inservice examinations and repairs / replacements and the subsequent submittal of Forms NIS-1 and NIS-2 within 90 days following a refueling outage are administrative only.
It is noted that repair and replacement documentation reviews and
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3 appiovals 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 Inspectiois Program S of the Code. Under j
this program, examination schedules are satisfied on a per period basis.
Considering the milestones associated with Inspection Program B, it can j
be concluded that the submittal of the results of examinations and an abstract of repairs / replacements on a periodic basis is a reasonable i
alternative.
In addition, the INEL staff believes that the use of forms
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J 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
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and interval, is an improvement over report forms currently required by i
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 j
inspection program.
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Considering that the Code recording and reporting criteria satisfy only administrative requirement:, 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
I The INEL staff has evaluated the licensee's request to implement alternatives to Code requirements contained in Code Case N-532, Alternative Requirenents to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000.
It has been determined that the alternatives contained in Code Case N-532 are only administrative changes to recording and reporting requirements for repairs / replacements and i
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inservice examinations.
Implementation of the alternatives contained in-l~
this Code Case will continue to proside an acceptable level of quality l
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 i
approved for use pursuant to 10 CFR 50.55a(a)(3)(i), provided tritt all i
requirements of Code Case N-532 are satisfied. Use of Code Case N-532
,,!i 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 iIcensee 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.
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O ATTACHMENT 3 SALP INPUT LICENSEE:
Florida Power and Light Company FACILITYl St. Lucie Nuclear Power Plant, Units 1 and 2 DOCKET N0s.:
50-335 and 50-389 TAC Nos.:
M93297 and M93293
't LICENSING ACTIVITY: Review of the Second Ten-Year. Interval Inservice Inspection Program Request for Relief Regarding the Implementation of Code Case N-532 for St. Lucie Nuclear Power Plant, Units 1 and 2 SufMARY OF ACTIVITY: The staff, with technical assistance from its contractor, the Idaho National Engineering Laboratory (INEL), has reviewed and evaluated the information provided by Florida Power and Light Company in its letter dated August 11, 1995, related to the second ten-year interval inservice inspection program plan request for relief regarding the implementation of Code Case N-532 for the St. Lucie Nuclear Plant, Units 1 and 2.
NARRATIVE DISCUSSION OF LICENSEE PERFOR"fMCE FUNCTION AREA -
7 ENGINEERING AND TECHNICAL SUPPORT: The licensee's Engineering and Technical Staff provided adequate technical information regarding its second ten-year interval inservice inspection program plan request for relief regarding the implementation of Code case N-532 for St. Lucie Nuclear Plant, Units 1 and 2.
The staff was able to authorize the alternative contained in the licensee's request for relief as requested based on the information provided by the licensee's etaff.
REVIEWER:
T.K. McLellan, 415-2716 DATE:
10/13/95
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