L-2014-169, Inservice Inspection Plan, Fourth Ten-Year Interval Unit 2 Relief Request No. 6, Revision 0

Inservice Inspection Plan, Fourth Ten-Year Interval Unit 2 Relief Request No. 6, Revision 0

ML14203A004
Person / Time
Site:	Saint Lucie
Issue date:	06/30/2014
From:	Katzman E Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-169
Download: ML14203A004 (4)

Text

0 June 30, 2014 FPL.

L-2014-169 10 CFR 50.4 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re: St. Lucie Unit 2 Docket No. 50-3 89 Inservice Inspection Plan Fourth Ten-Year Interval Unit 2 Relief Request No. 6, Revision 0 In accordance with 10 CFR 50.55a(a)(3)(i), Florida Power & Light (FPL) requests relief from the examination requirements for supports and associated attachment hardware as specified in ASME Section XI, IWF-2500. FPL proposes to perform the visual examination of snubbers and associated attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments) per the Snubber Program which is documented in St. Lucie Quality Instructions that invokes the ASME OM Code, Subsection ISTD.

Please contact Ken Frehafer at (772) 467-7748 if there are any questions about this submittal.

Sincerely, Eric S. Katzman Licensing Manager St. Lucie Plant Attachment ESK/KWF Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2014-169 Attachment Page 1 of 3 St. Lucie Unit 2 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 6, REV. 0 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety--

ASME Code Components Affected ASME Code Classes: Code Classes 1, 2 and 3

References:

ASME Section XI, IWF-1220 ASME Section XI, IWF-1300 and Figure IWF-1300-1(f)

ASME Section XI, IWF-2500 and Table IWF-2500-1 ASME OM Code, Subsection ISTD Examination Category: F-A Item Numbers: F1.10, F1.20, F1.30 and F1.40

Description:

Visual Examination of Snubber Attachment Hardware (Pin-to-Pipe and Pin-to-Structure), Excluding Integral Attachments Components: Code Class 1, 2 and 3 Snubbers

2. Applicable Code Edition and Addenda

The Code of record for St. Lucie Unit 2 (PSL-2) is the 2007 Edition with 2008 Addenda of the ASME Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components."

3. Applicable Code Reauirement The examination requirements for supports and associated attachment hardware are specified in ASME Section XI, IWF-2500. Table IWF-2500-1, Examination Category F-A requires that visual VT-3 examinations be performed on Class 1, 2 and 3 piping and component supports.

The examination and testing of snubbers is governed by ASME OM Code, Subsection ISTD as per ASME Section XI, IWF-1220 and 10CFR50.55a(b)(3)(v)(B).

When determining the boundaries for support examinations, IWF-1300(g) states, "All integraland nonintegral connections within the boundary governed by IWF rules and requirements are included."

L-2014-169 Attachment Page 2 of 3 St. Lucie Unit 2 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 6, REV. 0 This verifies that attachment hardware is included in the examination boundary.

The interface boundaries for the examination of snubbers and snubber attachment hardware is further addressed in IWF-1 300(h) which states, "The examination boundary of a support containing a snubber shall not include the connection to the snubber assembly (pins)."

These boundaries are shown graphically in Figure IWF-1 300-1 (f).

4. Reason for Request

PSL-2 is required to perform VT-3 visual examinations on Class 1, 2 and 3 supports, including attachment hardware, per ASME Section Xl. PSL-2 is also required to perform visual examinations and testing on snubber assemblies in accordance with ASME OM Code, Subsection ISTD. When incorporating the criteria of Subsection ISTD into the Snubber Program, FPL included the visual examination of snubber attachment hardware (pin-to-pipe and pin-to-structure) along with the visual examination of the snubber assembly (pin-to-pin). The visual examination criteria of the Snubber Program are nearly identical to those established by ASME Section Xl. Having two nearly identical sets of requirements for the visual examination of snubber attachment hardware would require the performance of redundant examinations and cause unnecessary confusion in the sample selection, data collection and documentation of these examinations.

5. Proposed Alternative and Basis for Use Proposed Alternative Pursuant to 10CFR50.55a(3)(i), FPL proposes to perform the visual examination of snubbers and associated attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments) per the Snubber Program which is documented in St. Lucie Quality Instruction Procedure No. QI-10-PR/PSL-6, "Control, Inspection, and Monitoring of Mechanical and Hydraulic Snubbers,"

which is in accordance with ASME OM Code Subsection ISTD.

The examination of integral attachments will be in accordance with ASME Section X1, Table IWB-2500-1 (Examination Category B-K), Table IWC-2500-1 (Examination Category C-C) and Table IWD-2500-1 (Examination Category D-A).

Basis for Use The examination and testing requirements for snubbers are documented in St.

Lucie Quality Instruction Procedure No. QI-10-PR/PSL-6. This procedure requires an examination frequency that establishes a high level of confidence in the acceptability of the plant's snubbers. This procedure requires the visual examination of snubber attachments, support attachments and attachments to

L-2014-169 Attachment Page 3 of 3 St. Lucie Unit 2 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 6, REV. 0 the supporting foundation, including nuts, bolts, studs, welds, pins spacers and embedments. The visual examination criteria established in Quality Instruction Procedure No. QI-10-PR/PSL-6 meets or exceeds the examination criteria specified in ASME Section XI, Table IWF-2500-1. Performing both the ASME Section XI and Snubber Program examinations would be redundant and would not improve the level of quality and safety in the plant. However, it would increase the occupational radiation exposure and cause the unnecessary repetition of activities.

The examinations on integral attachments that are associated with snubber attachment hardware are not included in the scope of this request for relief. The examination of these items will continue in accordance with ASME Section XI.

6. Duration of Proposed Alternative FPL will implement the alternative requirements during the fourth 10-year Inservice Inspection interval at PSL-2 which began August 8, 2013 and ends August 7, 2023.

7. Precedents The NRC has approved similar requests for alternatives at a number of nuclear facilities, including the following:

- Relief Request No. IR-3-01 was approved for the Millstone Power Station, Unit 3 in a letter from the NRC dated April 6, 2010, ADAMS Accession No. ML100680118.

- Relief Request No. IR-3-03 was approved for the Callaway Energy Center in a letter from the NRC dated March 7, 2006, ADAMS Accession No. ML060580568.

- Relief Request No. RR-111-01 was approved for the V. C. Summer Nuclear Station in a letter from the NRC dated May 10, 2005, ADAMS Accession No. ML051290198.

- Relief Request No.03-002 was approved for the McGuire Nuclear Station, Unit 2 in a letter from the NRC dated November 22, 2004, ADAMS Accession No. ML043080435.

8. Attachments to the Request None