L-2017-159, Response to Request for Additional Information Regarding Inservice Inspection Plan, Fifth Ten-Year Interval Unit 1 Relief Request No. 3, Revision 0

Response to Request for Additional Information Regarding Inservice Inspection Plan, Fifth Ten-Year Interval Unit 1 Relief Request No. 3, Revision 0

ML17256A176
Person / Time
Site:	Saint Lucie
Issue date:	09/13/2017
From:	Synder M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2017-159
Download: ML17256A176 (3)

Text

SEP 1 3 2017 L-2017-159 10 CPR 50.4 10 CPR 50. 55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re: St. Lucie Unit 1 Docket No. 50-335 Inservice Inspection Plan Fifth Ten-Year Interval Unit 1 Relief Request No. 3. Revision 0

References:

1. PPL Letter L-2017-033 dated February 16, 2017, Inservice Inspection Plan Fifth Ten-Year Interval Unit 1 ReliefRequest No.3, Revision 0, ADAMS Accession ML17047A283

2. 2017/08/15 NRR E-mail Capture - Request for Additional Information - St. Lucie Relief Request #3 - ICW 30" pipe defect removal (1viF9288), ADAMS Accession ML17228A005 Per reference 1, Florida Power & Light (FPL), requested relief from the requirements of ASME Code,Section XI, Subsection IWA-4000 for defect removal prior to repair, since compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. In Reference 2 the NRC provided a request for additional information (RAI) for the submittal. This attachment to this letter provides FPL's response to the RAI. .

Please contact Ken Frehafer at (772) 467-77 48 if there are any questions about this submittal.

Licensing Manager St. Lucie Plant Attachment MJS/K\V'F cc: USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Units 1 and 2 Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2017-159 Attachment Page 1 of 2 REQUEST FOR ADDITIONAL INFORMATION ST LUCIE NUCLEAR PLANT, UNIT 1 DOCKET NO. 50-335 RELIEF REQUEST NUMBER 3, REVISION 0 PROPOSED ALTERNATIVE REQUIREMENTS FOR THE REPAIR OF INTAKE COOLING SYSTEM PIPING CACs MF9288 By letter dated February 16, 2017, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17047A283), Florida Power & Light (the licensee) requested the U. S.

Nuclear Regulatory Commission (NRC) to authorize an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) regarding the repair of Intake Cooling Water (ICW) System piping at St. Lucie Unit 1 for the fifth 10-year inservice inspection interval (lSI). The current request is identified as Relief Request No. 3, Revision 0.

By letter dated August 5, 2013 (ADAMS Accession No. ML13220A029) the licensee submitted Relief Request No. 7, Revision 0, as an alternative to ASME Code regarding the repair of ICW system piping during the fourth 10-year lSI interval at St. Lucie Unit 1. The licensee provided supplemental information in a letter dated August 30, 2013 (ADAMS Accession No. ML13283A011), and an E-mail dated November 22, 2013 (ADAMS Accession No. ML13329A594).

The NRC issued the safety evaluation for the fourth 10-year lSI interval Relief Request No. 7, Revision 0 on January 30, 2014 (ADAMS No. ML14013A304).

The NRC staff notes that the fourth 10-year lSI Relief Request No. 7, Revision 0 and the current fifth 10-year lSI Relief Request No. 3, Revision 0 appear to be identical except for the interval identified, Code Edition and Addenda, and the reference to two additional repairs performed on 1-30"-CW-29. Attachment 2 of the August 5, 2013, request letter provided calculations, including minimum wall thickness, for various sized plate repairs.

Please provide verification that Attachment 2 of the August 5, 2013, letter referenced above is applicable to the current requested alternative. If the information in Attachment 2 is not applicable to Relief Request No. 3, Revision 0, please supplement the current request with updated calculations.

Similarly, please provide verification that the fourth 10-year lSI Relief Request No. 7, Revision 0 supplemental information provided in the August 30, 2013, letter and the November 22, 2013, email, as referenced above, is applicable to the current requested alternative. If the 2013 information is not applicable to Relief Request No. 3, Revision 0, please provide like supplemental information that is applicable to the current request.

L-2017-159 Attachment Page 2 of 2 Florida Power and Light Response to Request for Additional Information (ML17228A005):

1. Please provide verification that Attachment 2 of the August 5, 2013, letter referenced above is applicable to the current requested alternative. If the information in Attachment 2 is not applicable to Relief Request No. 3, Revision 0, please supplement the current request with updated calculations.

FPL Response: Attachment 2 of the August 5, 2013 letter (ADAMS Accession No. ML13220A029) which submitted Relief Request No. 7, Revision 0, as an alternative to ASME Code regarding the repair of ICW system piping during the fourth 1 0-year lSI interval at St. Lucie Unit 1 is applicable to the current Relief Request No. 3, Revision 0 for the St. Lucie Unit 1 fifth 10-year inservice inspection interval (lSI).

2. Similarly, please provide verification that the fourth 10-year ISI Relief Request No. 7, Revision 0 supplemental information provided in the August 30, 2013, letter and the November 22, 2013, email, as referenced above, is applicable to the current requested alternative. If the 2013 information is not applicable to Relief Request No. 3, Revision 0, please provide like supplemental information that is applicable to the current request.

FPL Response: The supplemental information in the letter dated August 30, 2013 (ADAMS Accession No. ML13283A011) and the E-mail dated November 22, 2013 (ADAMS Accession No. ML13329A594) in support of Relief Request No. 7, Revision 0, as an alternative to ASME Code regarding the repair of ICW system piping during the fourth 10-year lSI interval at St.

Lucie Unit 1 are applicable to the current Relief Request No. 3, Revision 0 for the St. Lucie Unit 1 fifth 10-year inservice inspection interval (lSI) for the currently installed repairs. Future repairs will continue to use the same design with equivalent materials/coatings.