L-2014-277, Inservice Inspection Plan, RAI Reply - Third Ten-Year Interval Unit 2 Relief Request No. 17

Inservice Inspection Plan, RAI Reply - Third Ten-Year Interval Unit 2 Relief Request No. 17

ML14253A182
Person / Time
Site:	Saint Lucie
Issue date:	08/28/2014
From:	Catron S Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-277
Download: ML14253A182 (4)

Text

0 August 28, 2014 FPIL' L-2014-277 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. 50-389 Inservice Inspection Plan RAI Reply - Third Ten-Year Interval Unit 2 Relief Request No. 17

References:

1. FPL Letter L-2014-277 dated June 30, 2014, "Third Ten-Year Interval Unit 2 Relief Request No. 17," ADAMS Accession Number ML14203A047.

2. NRC Request for Additional Information, ADAMS Accession Number ML14231A289.

In Reference 1, Florida Power & Light (FPL) requested relief from the examination requirements of the ASME Code,Section XI, 1998 Edition with Addenda through 2000, as clarified by Code Case N-460, for the subject ASME Code Category B-A welds. In Reference 2, the NRC forwarded a request for additional information (RAI) pertaining to the relief request. The FPL response to the RAIs is provided in the attachment to this letter.

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

Sincerely, Steven Catron Licensing Manager St. Lucie Plant Attachment SC/KWF cc: USNRC Regional Administrator, Region I1 USNRC Senior Resident Inspector, St. Lucie Units I and 2 Florida Power & Light Company Q4" -

6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2014-277 Attachment 1 of 3 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 17, REVISION 0 REQUEST FOR ADDITIONAL INFORMATION (RAI)

ON THE THIRD TEN YEAR 10-YEAR INSERVICE INSPECTION INTERVAL REQUEST FOR RELIEF 17, REVISON 0 FLORIDA POWER AND LIGHT ST LUCIE. UNIT 2 DOCKET NUMBER: 50-389 TAC No. MF4339 By letter dated June 30, 2014, (Agencywide Documents Access and Management System (ADAMS) Accession Number MI1 14203A047), the licensee, Florida Power and Light, submitted Request for Relief (RR) 17, Revision 0 from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, Rules for Inservice Inspection of Nuclear Power Plant Components for St Lucie, Unit 2 (PSL-2). The request for relief applies to the third 10-year inservice inspection (ISI) interval, in which the licensee adopted the 1998 Edition through the 2000 Addenda of ASME Code Section XI as the code of record.

In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee has submitted the subject request for relief for limited examinations in multiple ASME Code Examination Categories. The ASME Code requires that 100 percent of the examination volumes, or surface area., described in Table IWB-2500 be performed during each interval.

10 CFR 50.55a(g)(5)(iii) states that when licensees determine that conformance with ASME Code requirements is impractical at their facility, they shall submit information to support this determination. The NRC will evaluate such requests based on impracticality, and may impose alternatives, giving due consideration to public safety and the burden imposed on the licensee.

The NRC staff has reviewed the information submitted by the licensee, and based on this review, determined the following information is required to complete the evaluation.

RAIs Regarding Request for Relief 17 from ASME Code, Section Xl. Examination Category B-A, Items B1.10, B1.11, B1.12, B1.20, B1.21, and B1.22 Pressure Retaining Welds in Vessels in Reactor Vessels, PSL-2 RAI 1 It appears that only the percentage of the interferences was provided for each examination and the volumetric coverage was provided in the CAD drawings. Provide the volumetric coverage obtained for each weld examination in a table to insure that all of the volumetric examination coverages were listed in Request for Relief No. 17, Revision 0.

FPL Response - The volumetric coverage obtained is provided in the column titled "Applicable Code Requirement and Weld Volume Coverage Obtained" in the table below.

L-2014-277 Attachment 2 of 3 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 17, REVISION 0 RAI 2 Fully clarify the wave modality and insonification angles used for all ultrasonic examinations. It appears they were 45 Degrees Shear, 45 degrees and 70 degrees Longitudinal scans based on Figure 1 of the licensee's submittal.

FPL Response- The wave modality (L-Longitudinal, S-Shear) and insonification angles (45, 70) used for the ultrasonic examinations is provided in the column titled "Angle(s)/Wave Mode" in the table below.

L-2014-277 Attachment 3 of 3 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST #17 FPL RESPONSE TO RAI Category B-A Angle(s)/Wave ASME Code Component Component ID Applicable Code Requirement and Mode Impracticality of Compliance Weld Volume Coverage Obtained Inner Outer I 15% T 85% T RPV Intermediate Shell- Exam Category B-A Inservice examination limited to-Lower Shell 101-171 Item No. 31. 11 45L 45L due to six surveillance capsule Circumferential Weld 83% volume coverage 45S holders.

RPV Circumferential Bottm Hed-toLowe201141Item Exam Category No. B1.21B-A 45L 45L Inservice examination limited Inevcexmatolitd Bottom Head-to-Lower 201-141 70L 45S due to the proximity of the core Shell Weld 71% volume coverage barrel stabilizers and core lugs.

RPV Upper Shell Exam Category B-A Inservice examination limited Longitudinal Seam Weld 101-122A Item No. 31.12 45L 45L duervice outlet nozzle at zero at 15 Degrees 63% volume coverage degrees integral extension Exam Category B-A Inservice examination limited RPV Lower Head Peel 101-154-ACE Item No. B1.22 45L 45L due to the proximity of the flow Segment Welds 54% 70L 45S baffle.

______________________ ~53% volume coverage_______________

Exam Category B-A Inservice examination limited RPV Lower Head Peel 101-154-BDF Item No. B1.22 45L 45L dnervice examition limited Segment Welds 101-154-BDFcov e 70L 4 due to the proximity of the flow

____________________ 43% volume coverage 7Lbaffle &core lug.