L-2014-265, License Renewal One-Time Inspection of Class 1 Small Bore Piping Inspection Plan Submittal

License Renewal One-Time Inspection of Class 1 Small Bore Piping Inspection Plan Submittal

ML14261A107
Person / Time
Site:	Saint Lucie
Issue date:	09/03/2014
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-265
Download: ML14261A107 (6)

Text

0 FPL.

September 3, 2014 L-2014-265 10 CFR 54 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555-0001 St. Lucie Unit I Docket No. 50-335 License Renewal One-Time Inspection of Class 1 Small Bore Piping Inspection Plan Submittal

References:

1. Safety Evaluation Report Related to the License Renewal of St. Lucie Nuclear Plant, Units I and 2, NUREG-1779, September 2003.

2. Letter from Joseph Jensen (FPL) to U.S. Nuclear Regulatory Commission (L-2014-059), "License Renewal One-Time Inspection of Class I Small Bore Piping Revised Commitments," March 19, 2014, ADAMS Accession No. 14087A007.

3. Generic Aging Lessons Learned (GALL) Report, NUREG-1801, Rev. 2, December 2010.

Florida Power and Light Company (FPL) has License Renewal (LR) commitments for St. Lucie Units I and 2 to perform a one-time inspection of Class I Small Bore Piping prior to the end of the initial operating license term. For St. Lucie Unit 1 specifically, this inspection was originally addressed by Commitment 7 listed in Appendix D, Table I of Reference 1. The Unit 1 small bore piping inspection requirements were revised in Reference 2, such that this one-time inspection will follow the guidance provided in the Reference 3, Section AMP XI.M35, "One-Time Inspection of ASME Code Class I Small-Bore Piping."

St. Lucie Unit 1 Updated Final Safety Analysis Report (UFSAR), Section 18.1.5, Small Bore Class I Piping Inspection, states that a report describing the details of the one-time inspection plan will be submitted prior to the implementation of the inspection. To comply with UFSAR Section 18.1.5 requirements, the one-time Class I Small Bore Piping Program Inspection Plan is provided herein in the Attachment.

Should you have any questions, please contact Mr. Eric Katzman, Licensing Manager, at 772-467-7734.

( y t*u*y yours, Site Vice President St. Lucie Plant C--

JJ/lrb _ ,O c(

Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2014-265 10 CFR 54 Page 2 of 2

Attachment:

St. Lucie Unit I One-Time ASME Code Class I Small-Bore Piping Inspection Plan (4 pages) cc: USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Plant

L-2014-265 Attachment Page 1 of 4 St. Lucie Unit 1 ASME Code Class 1 Small-Bore Piping One Time Inspection Plan, Revision 0

L-2014-265 Attachment Page 2 of 4 Plan Description This plan augments the requirements in American Society of Mechanical Engineers (ASME) Code,Section XI, 1998 edition with Addenda through 2000, and is applicable to small-bore ASME Code Class 1 piping and systems less than 4 inches nominal pipe size (less than NPS 4) and greater than or equal to NPS 1. The plan includes pipes, fittings, branch connections, and all full and partial penetration (socket) welds. This plan was developed using the Generic Aging Lessons Learned (GALL) Report, NUREG-1801, Rev. 2 XI.M35; One-Time Inspection of ASME Code Class 1 Small-Bore Piping as guidance.

A one-time inspection to detect cracking resulting from thermal and mechanical loading, vibration, or intergranular stress corrosion of full penetration welds will be performed by volumetric examination. A one-time inspection to detect cracking in socket welds will be performed by either volumetric or destructive examination. The number of welds to be examined will be on a sample basis as described in Section 4 of this plan. The sample of welds to be examined will be selected using the risk-informed approach as approved by the NRC for St. Lucie Nuclear Plant, Units No. 1 and 2 -Fourth 10-Year Interval Inservice Inspection Program Plan Relief Request No. 1 (TAC NO.

MD7739)

These inspections will provide additional assurance that either aging of small-bore ASME Code Class 1 piping is not occurring or the aging is insignificant, such that a plant-specific Aging Management Program (AMP) is not warranted. Should evidence of cracking be revealed by the one-time inspection, a periodic inspection plan will be developed and implemented using a plant-specific AMP.

A search of the St. Lucie Corrective Action Program and the ASME Section XI, Repair and Replacement Reports over the operating history of St. Lucie Unit 1 was performed to detennine if any ASME Code Class 1 Small-Bore Piping greater than or equal to NPS 1 and less than NPS 4 had experienced cracking. No instance of cracking of ASME Code Class 1 Small-Bore Piping greater than or equal to NPS 1 and less than NPS 4 was identified.

Evaluation and Technical Basis

1. Scope of Plan: This plan is a one-time inspection of a sample of ASME Code Class 1 piping less than NPS 4 and greater or equal to NPS 1. This plan includes measures to verify that degradation is not occurring, thereby confirming that there is no need to manage age-related degradation. The one-time inspection plan for ASME Code Class 1 small-bore piping includes locations that are susceptible to cracking. The sample of welds will be selected using the risk-informed approach as approved by the NRC for St. Lucie Nuclear Plant, Unit No. 1 -Fourth 10-Year Interval Inservice Inspection Program Plan Relief Request No. 1 (TAC NOS. MD7739).

All ASME Class 1 pipe segments less than 4-inch NPS and greater than equal to 1-inch NPS have the same Low Safety Significance Risk Ranking and, as such, all welds were given the same level of consideration.

2. Preventive Actions: This plan is a condition monitoring activity independent of methods to mitigate or prevent degradation.

3. ParametersMonitored/Inspected: This inspection is intended to detect potential cracking in ASME Code Class 1 small-bore piping.

L-2014-265 Attachment Page 3 of 4

4. Description of Aging Effects: This one-time inspection is designed to provide assurance that aging of ASME Code Class 1 small-bore piping is not occurring, or that the effects of aging are not significant. The one-time inspection to detect cracking in socket welds will be either a volumetric or destructive examination. The inspection to detect cracking resulting from thermal and mechanical loading, vibration, or intergranular stress corrosion of full penetration welds will be a volumetric examination. Volumetric examination will be performed using demonstrated techniques from the ASME Code that are capable of detecting the aging effects in the examination volume of interest. The inspection will be performed at a sufficient number of locations to ensure an adequate sample. This number, or sample size, is based on susceptibility, accessibility, dose considerations, operating experience, and limiting locations of the total population of ASME Code Class 1 small-bore piping inspections.

The inspection sample size will be at least 3%, up to a maximum of 10 welds, of each weld type, for each operating unit using a methodology to select the most susceptible and risk-significant welds from the risk-informed approach as described above. For socket welds, destructive examination may be performed in lieu of volumetric examinations. Because more information can be obtained from a destructive examination than from nondestructive examination, credit will be taken for each weld destructively examined equivalent to having volumetrically examined two welds.

St. Lucie Unit 1 Weld Type Approx. 3% Sample Size Number (Max 10 Welds Each Type)

" Volumetric OR Destructive Socket 493 15 N/A 5 (NPS-2 and smaller)

Full Penetration 92 3 3 N/A (Greater than NPS-2 and less than NPS-4)

5. Monitoring and Trending: This is a one-time inspection to determine whether cracking in ASMEE Code Class 1 small-bore piping resulting from stress corrosion, cyclical (including thermal, mechanical, and vibration fatigue) loading, or thermal stratification and thenrial turbulence (MRP 146 and MRP 146S) is an issue. Evaluation of the inspection results may indicate the need for additional or periodic examinations (i.e., a plant-specific AMP for Class 1 small-bore piping using volumetric inspection methods consistent with ASME Code,Section XI, Subsection IWB).

6. Acceptance Criteria: If flaws or indications exceed the acceptance criteria of ASME Code,Section XI, Paragraph IWB-3400, they are evaluated in accordance with ASME Code, Section

L-2014-265 Attachment Page 4 of 4 XL, Paragraph IWB-3 131; additional inspections are performed in accordance with ASME Code,Section XI, Paragraph IWB-2430. Evaluation of flaws identified during a volumetric examination of socket welds will be in accordance with IWB-3600.

7. Corrective Actions: The site corrective action program, quality assurance procedures, site review and approval process, and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B. Should evidence of cracking be revealed by the one-time inspection, a periodic inspection will be developed and implemented, using a plant-specific AMP.

8. Confirmation Process: The requirements of 10 CFR Part 50, Appendix B are used to address the confirmation process.

9. Administrative Controls: The requirements of 10 CFR Part 50, Appendix B are used to address the administrative controls.

10. Operating Experience: This one-time inspection plan uses volumetric inspection techniques with demonstrated capability and a proven industry record and/or destructive examinations to detect cracking in piping weld and base material. Currently, an industry proven volumetric technique for detection, sizing and performing analytical evaluation of flaws in socket welds has not been established; therefore, a destructive examination will be performed.