L-2024-133, Snubber Program Plan Submittal
| ML24227A633 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/14/2024 |
| From: | Rasmus P Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-2024-133 | |
| Download: ML24227A633 (1) | |
Text
l=PL.
ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE:
St. Lucie Nuclear Plant Unit 2 Docket No. 50-389 Renewed Facility Operating License NPF-16 Snubber Program Plan Submittal L-2024-133 10 CFR 50.55a(g)(4)
August14,2024 Pursuant to 10 CFR 50:55a(g)(4), Florida Power & Light (FPL) is updating its snubber program for the Fifth 10-Year lnservice Testing Interval at the St. Lucie Nuclear Plant, Unit 2 (PSL-2). The Code Edition applicable to PSL-2 for the Fifth Snubber Program lnservice Testing Interval is the American Society of Mechanical Engineers Operation and Maintenance Code (ASME OM Code) 2020 Edition. Paragraph (b)(3)(v) of 10 CFR 50.55a requires Subsection ISTD, "Preservice and lnservice Requirements for Dynamic Restraints (Snubbers) in Water-Cooled Reactor Nuclear Power Plants", of the ASME OM Code to be used for the examination and testing of snubbers.
The Fifth 10-Year Interval for the Snubber Program begins August 8, 2024.
The enclosure to this letter provides the PSL-2 Snubber Program Plan for the Fifth 10-Year Interval. FPL is providing this plan for information only in accordance with 10 CFR 50.55a(f)(7).
NRC approval is not requested. The plan does not include any new commitments.
Should you have any questions regarding this submittal, please contact Mr. Kenneth Mack, Senior Manager, Licensing and Regulatory Compliance, at 561-904-3635.
Sincerely,
Enclosure:
St. Lucie Unit 2 Snubber Testing Program Plan Fifth Ten Year Interval cc:
USNRC Regional Administrator, Region II USNRC Project Manager, St. Lucie Nuclear Plant, Units 1 and 2 USNRC Senior Resident Inspector, St. Lucie Nuclear Plant, Units 1 and 2 Mr. Clark Eldredge, Florida Department of Health Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957
St. Lucie Nuclear Plant, Unit 2 Docket No. 50-389 St. Lucie Plant Unit 2 Snubber Testing Program Plan Fifth 10-Year Interval Beginning August 8, 2024 Ending August 7, 2034 USNRC DOCKET NO. 50-389 OPERATING LICENSE NO. NPF-16 Revision 0 Page 1 of6 L-2024-133 Enclosure
St. Lucie Nuclear Plant, Unit 2 Docket No. 50-389 Effective Revision Description Date 8/8/2024 Updated Snubber Program Plan for Fifth 10-Year Interval Revision Log Prepared Snubber Program Owner, See EC 299900 Milestone 140 Page 2 of 6 Date Approved L-2024-133 Enclosure Date Engineering Manager, See EC 299900 Milestone 199
St. Lucie Nuclear Plant, Unit 2 Docket No. 50-389 SECTION
1.0 INTRODUCTION
TABLE OF CONTENTS 2.0 EXAMINATION, TESTING, AND SERVICE LIFE MONITORING REQUIREMENTS 3.0 EXAMINATION AND TESTING METHODS 4.0 EXAMINATION AND TESTING FREQUENCY 5.0 EXAMINATION, TESTING, AND SERVICE LIFE MONITORING EVALUATION 6.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS 7.0 SCHEDULING 8.0 REPORTS AND RECORDS Page 3 of 6 L-2024-133 Enclosure
St. Lucie Nuclear Plant, Unit 2 Docket No. 50-389
1.0 INTRODUCTION
1.1 Purpose L-2024-133 Enclosure To provide the test plan for maintaining the operational readiness of safety and quality related dynamic restraints (snubbers) whose specific functions are required to ensure the integrity of the reactor coolant pressure boundary or any safety related system as specified in 1.2 below.
1.2 Scope The program meets the requirements of the following subsections of the American Society of Mechanical Engineers (ASME) OM Code 2020 Edition.
Subsection ISTA, "General Requirements" ISTA contains the general requirements directly applicable to inservice examination and testing, including the Owner's Responsibilities and Records and Reports Requirements Subsection ISTD, "Preservice and lnservice Requirements for Dynamic Restraints (Snubbers) in Water-Cooled Reactor Nuclear Power Plants" ISTD establishes requirements for preservice and inservice examination, testing, and service life monitoring of dynamic restraints (snubbers) in water-cooled reactor nuclear power plants.
The snubbers included are those classified as ASME Code Class 1, 2, or 3 and those required to support the systems and components that perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident, or to ensure the integrity of the reactor coolant pressure boundary.
1.3 Discussion In order to ensure the required operability of all safety related and quality related snubbers for the St. Lucie Plant during seismic or other events that may initiate dynamic loads, the examination, testing, and service life monitoring of these snubbers shall be implemented and performed in accordance with the requirements of ER-AA-119, Fleet Snubber Program.
The examination boundaries for the Snubber Program shall include the snubber assembly from pin to pin, inclusive. Integral and nonintegral structural attachments for snubbers, when examined, shall be examined in accordance with the requirements of the current ASME Code Section XI Edition in accordance with ISi Program requirements.
The snubber program described in ER-AA-119 adheres to the requirements of Subsections ISTA and ISTD of the ASME OM Code 2020 Edition as required by 1 OCFR50.55a(b)(3)(v)(B).
2.0 EXAMINATION, TESTING, AND SERVICE LIFE MONITORING REQUIREMENTS 2.1 Visual examination, functional testing, and service life monitoring requirements shall be performed to the extent specified within ER-AA-119 and in accordance with ER-AA-119-1000, Snubber Program Procedure, or site specific procedures.
2.2 Snubbers are grouped into Defined Test Plan Groups (DTPGs) in accordance with ISTD-5250. Each DTPG will be tested using the 10% sample plan per ISTD-5300. Snubbers attached to the Steam Generators or Reactor Coolant Pumps will be included as separate DTPGs in accordance with ISTD-5253.
Page 4 of 6
St. Lucie Nuclear Plant, Unit 2 Docket No. 50-389 L-2024-133 Enclosure 2.3 The service life of all snubbers shall be monitored in accordance with ISTD-6000.
Snubbers will be evaluated, replaced, or reconditioned in accordance with ER-AA-119 and ISTD-6200 to ensure that the service life is not exceeded before the next scheduled system or plant outage. The replacement or reconditioning of snubbers shall be documented and records retained in accordance with ISTD-9500.
3.0 EXAMINATION AND TESTING METHODS 3.1 Visual examinations shall be performed by individuals qualified in accordance with St.
Lucie Plant or vendor procedures. These examinations are conducted to ensure the mechanical and structural condition of the snubber support locations and to observe conditions that could affect functional effectiveness. Visual examinations and functional testing shall be performed to verify the requirements specified within ER-AA-119 are met in accordance with Subsection ISTD.
4.0 EXAMINATION AND TESTING FREQUENCY 4.1 Visual examination and functional testing shall be performed at the frequency specified within ER-AA-119, ISTD-4252, and ISTD-5240. Snubbers are categorized as one population, regardless of accessibility during reactor operation, for visual examinations according to the schedule determined by Table ISTD 4252-1, Visual Examination Table.
Functional testing is performed each refueling outage.
4.2 Code Case OMN-13, which allows the extension of the visual examination interval, has been implemented for snubber inspections scheduled during this interval. Code Case OMN-13 is approved for use in Regulatory Guide 1.192 (December 2021 ).
4.3 A preservice visual examination shall be performed whenever a snubber is removed and reinstalled for any reason. This includes temporary removal of a snubber where no maintenance, repair, or replacement has been performed prior to reinstallation.
4.4 An inservice visual examination shall be performed prior to removal of a snubber from service for any reason. This includes temporary removal of a snubber where no maintenance, repair, or replacement has been performed prior to reinstallation.
4.5 Functional testing requirements for new installations or spares shall be equal to or more stringent than those specified within Attachment 2 of ER-AA-119-1000.
5.0 EXAMINATION, TESTING, AND SERVICE LIFE MONITORING EVALUATION 5.1 Snubbers that do not appear to conform to the visual examination acceptance requirements of ER-AA-119 shall be reported for evaluation and appropriate corrective action.
5.2 Snubbers that do not appear to conform to the visual examination acceptance requirements but are later confirmed as operable through functional testing may be declared operable for the purpose of establishing the next visual inspection interval, provided the unacceptable condition did not affect the operational readiness of the snubber location in question.
5.3 Snubbers that do not meet the functional testing acceptance criteria of ER-AA-119 shall be evaluated to determine the cause of the failure and appropriate corrective action shall be taken.
Page 5 of 6
St. Lucie Nuclear Plant, Unit 2 Docket No. 50-389 L-2024-133 Enclosure 5.4 The service life or a snubber will be evaluated once each fuel cycle using manufacturer's input and contemporary information gained through consideration of the snubber service conditions and inservice functional test results. Service life monitoring program requirements are included in ER-AA-119.
6.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS 6.1 Repairs, replacements, and modifications performed on snubbers under this program shall conform, as applicable, to the requirements specified within the current ASME Code,Section XI Edition.
7.0 SCHEDULING 7.1 Schedules for snubber visual examinations, functional testing, and service life replacements will be established, tracked, and maintained in accordance with ER-AA-119 and Subsection ISTD of the ASME OM Code by the Snubber Program Owner.
7.2 A controlled listing of snubbers included in this program is maintained and controlled within the NAMS Equipment Database and ER-AA-119-1000 (Snubber Program Procedure).
7.3 The Snubber Program Owner shall identify and track expanded or additional testing and/or examinations as required by ER-AA-119 and Subsection ISTD of the ASME OM Code.
8.0 REPORTS AND RECORDS 8.1 Reports and records for the visual examinations and functional testing shall be maintained for all snubbers included within the snubber program in accordance with Ql-17-PSL-1, Quality Assurance Records.
8.2 Applicable records and reports, as required for repair and replacements, shall be maintained.
8.3 In accordance with ISTD-9500, records of the service life of all snubbers listed in this program, including the current service life and initial installation date at current locations, and associated installation and maintenance records, shall also be maintained in accordance with Ql-17-PSL-1 and ER-AA-19.
Page 6 of6