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MONTHYEARML0314900672003-05-29029 May 2003 Relief, Safety Evaluation for Request No. 37 Regarding Radiographic Inspection of Intake Cooling Water System Piping Project stage: Approval 2003-05-29
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Category:Letter
MONTHYEARIR 05000335/20230102024-01-26026 January 2024 NRC Quadrennial Focused Engineering Inspection (FEI) Commercial Grade Dedication Report 05000335/2023010 and 05000389/2023010 L-2024-010, Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)2024-01-25025 January 2024 Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3) IR 05000335/20230042024-01-24024 January 2024 Integrated Inspection Report 05000335/2023004 and 05000389/2023004 L-2024-004, Relief Request (RR) 7, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) Extension of Inspection Interval for Reactor Pressure Vessel Welds from 10 to 20 Years2024-01-18018 January 2024 Relief Request (RR) 7, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) Extension of Inspection Interval for Reactor Pressure Vessel Welds from 10 to 20 Years L-2024-002, Withdrawal of Proposed Alternative to American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code for the Auxiliary Feedwater (AFW) 2C Pump2024-01-0808 January 2024 Withdrawal of Proposed Alternative to American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code for the Auxiliary Feedwater (AFW) 2C Pump L-2023-173, Quality Assurance Topical Report (FPL-1) Revision 30 Update2023-12-15015 December 2023 Quality Assurance Topical Report (FPL-1) Revision 30 Update L-2023-179, Unusual or Important Environmental Event - Turtle Mortality2023-12-14014 December 2023 Unusual or Important Environmental Event - Turtle Mortality L-2023-168, License Amendment Request Supplement to Revision 2 for the Technical Specifications Conversion to NUREG-1432 Revision 52023-12-12012 December 2023 License Amendment Request Supplement to Revision 2 for the Technical Specifications Conversion to NUREG-1432 Revision 5 L-2023-155, Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-06542023-11-28028 November 2023 Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, ML23332A1772023-11-28028 November 2023 Correction to the 2022 Annual Radioactive Effluent Release Report L-2023-162, Response to 50.69 2nd Round of Rals2023-11-21021 November 2023 Response to 50.69 2nd Round of Rals IR 05000335/20230032023-11-0606 November 2023 Integrated Inspection Report 05000335/2023003 and 05000389/2023003 ML23270B8882023-10-23023 October 2023 Regulatory Audit Summary Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structure, Systems, and Components for Nuclear Power Reactors EPID L-2022-LLA-0182 ML23346A1322023-10-0606 October 2023 Communication from C-10 Research & Education Foundation Regarding NextEra Common Emergency Fleet Plan License Amendment Request and Related Documents Subsequently Published ML23275A1102023-10-0202 October 2023 License Amendment Request Revision 2 for the Technical Specifications Conversion to NUREG-1432, Revision 5 L-2023-131, Subsequent License Renewal Application - Second Annual Update2023-09-28028 September 2023 Subsequent License Renewal Application - Second Annual Update L-2023-136, Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2023-09-26026 September 2023 Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors L-2023-122, Corrections to the 2022 Annual Radiological Environmental Operating Report2023-09-20020 September 2023 Corrections to the 2022 Annual Radiological Environmental Operating Report IR 05000335/20233012023-09-20020 September 2023 NRC Operator License Examination Report 05000335/2023301 and 05000389/2023301 L-2023-127, Correction to the 2022 Annual Radioactive Effluent Release Report2023-09-18018 September 2023 Correction to the 2022 Annual Radioactive Effluent Release Report L-2023-113, Correction to the 2020 Annual Radiological Environmental Operating Report2023-09-14014 September 2023 Correction to the 2020 Annual Radiological Environmental Operating Report L-2023-108, Report of 10 CFR 50.59 Plant Changes2023-09-11011 September 2023 Report of 10 CFR 50.59 Plant Changes L-2023-118, Response to Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2023-09-11011 September 2023 Response to Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors L-2023-112, Corrections to the 2021 Annual Radioactive Effluent Release Report2023-09-0606 September 2023 Corrections to the 2021 Annual Radioactive Effluent Release Report L-2023-107, Technical Specification Bases Control Program Periodic Report of Bases Changes TS 6.8.4.j.42023-09-0606 September 2023 Technical Specification Bases Control Program Periodic Report of Bases Changes TS 6.8.4.j.4 ML23219A0042023-09-0101 September 2023 Transmittal Letter - Safety Evaluation Related to the SLRA of St. Lucie Plant, Units 1and 2, Revision 1 L-2023-114, Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update2023-08-17017 August 2023 Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update L-2023-098, and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22023-08-0707 August 2023 and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 IR 05000335/20230022023-08-0707 August 2023 Integrated Inspection Report 05000335/2023002 and 05000389/2023002 L-2023-105, Preparation and Scheduling of Operator Licensing Examinations2023-08-0303 August 2023 Preparation and Scheduling of Operator Licensing Examinations ML23201A0872023-08-0303 August 2023 Audit Plan in Support of Review of License Amendment ML23212B2652023-07-27027 July 2023 Operator Licensing Written Examination Approval 05000335/2023301 and 05000389/2023301 L-2023-099, Pump Relief Request 10 (PR-10), One-Time Request for an Alternative to the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code for the Auxiliary Feedwater (AFW) 2C Pump2023-07-26026 July 2023 Pump Relief Request 10 (PR-10), One-Time Request for an Alternative to the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code for the Auxiliary Feedwater (AFW) 2C Pump L-2023-102, Relief Request PSL2-15-RR-01, Proposed Alternative to ASME Section XI Code Examination Requirements for Reactor Vessel Bottom Area and Piping in Covered Trenches2023-07-26026 July 2023 Relief Request PSL2-15-RR-01, Proposed Alternative to ASME Section XI Code Examination Requirements for Reactor Vessel Bottom Area and Piping in Covered Trenches ML23200A1232023-07-21021 July 2023 Transmittal Letter for the St. Lucie SLRA Review L-2023-097, Subsequent License Renewal Application Revision 1 - Supplement 62023-07-13013 July 2023 Subsequent License Renewal Application Revision 1 - Supplement 6 L-2023-076, In-Service Inspection Program Owner'S Activity Report (OAR-1)2023-07-11011 July 2023 In-Service Inspection Program Owner'S Activity Report (OAR-1) ML23184A0352023-06-30030 June 2023 Notification of St. Lucie Units 1 & 2 Focused Engineering Inspection (FEI) 05000335/2023010 and 05000389/2023010 and Initial Information Request L-2023-087, Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452)2023-06-29029 June 2023 Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452) IR 05000335/20234032023-06-29029 June 2023 Security Inspection Report 05000335/2023403 and 05000389/2023403 IR 05000335/20234022023-06-20020 June 2023 Security Baseline Inspection Report 05000335/2023402 and 05000389/2023402 L-2023-082, Subsequent License Renewal Application Revision 1, Supplement 52023-06-14014 June 2023 Subsequent License Renewal Application Revision 1, Supplement 5 L-2023-074, Addendum to 2021 Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation Ctsfsi) Financial Assurance Update2023-06-0202 June 2023 Addendum to 2021 Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation Ctsfsi) Financial Assurance Update L-2023-071, NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 29 and Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses (FPL-2) Revision 11, Annual Submittal2023-05-22022 May 2023 NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 29 and Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses (FPL-2) Revision 11, Annual Submittal IR 05000335/20234012023-05-16016 May 2023 Cyber Security Inspection Report 05000335/2023401 and 05000389/2023401 (Cover Letter) IR 05000335/20230012023-05-0909 May 2023 Integrated Inspection Report 05000335/2023001 and 05000389/2023001 ML23109A1132023-04-30030 April 2023 SLRA Change Schedule Letter L-2023-059, Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 4 Supplemental Response2023-04-21021 April 2023 Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 4 Supplemental Response ML23097A1642023-04-17017 April 2023 Summary of March 23, 2023, Meeting with Florida Power and Light on St. Lucie and Turkey Point Improved Technical Specifications Conversion License Amendment Requests L-2023-055, 2022 Annual Environmental Operating Report2023-04-12012 April 2023 2022 Annual Environmental Operating Report 2024-01-08
[Table view] Category:Safety Evaluation
MONTHYEARML23219A0032023-09-0101 September 2023 SLRA SER Rev 1 ML23200A1462023-07-21021 July 2023 Safety Evaluation Related to the SLRA of St. Lucie Plant, Units 1 and 2 ML22255A1022022-09-21021 September 2022 Authorization and Safety Evaluation for Alternative Relief Request No. 10 - Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety ML22038A1872022-02-0909 February 2022 Authorization and Safety Evaluation for Relief Request No. 19 (RR19) - the Use of an Alternative to ASME Code Case N-729-6 for Replacement Reactor Vessel Closure Head Penetration Nozzle 85 ML21342A2092022-01-14014 January 2022 Issuance of Amendment Nos. 252 and 207 to Allow Risk-Informed Completion Times (RICT) for the 120-Volt Alternating Current (AC) Instrument Bus Requirements ML21236A1312021-09-30030 September 2021 Authorization of RR 15 Regarding Extension of ASME Requirements Related to Reactor Pressure Vessel Weld Examinations from 10 to 20 Years ML21022A2192021-02-26026 February 2021 Issuance of Amendment No. 206 to Replace the Current Time-Limited Reactor Coolant System Pressure/Temperature Limit Curves and LTOP Setpoints with Curves and Setpoints That Will Remain Effective for 55 Effective Full Power Years ML21027A2262021-02-17017 February 2021 Approval of Alternative to ASME Code, Section XI to Use an Alternative Inservice Inspection Schedule for the Reaction Vessel Closure Head Bolting ML20329A4022021-02-0303 February 2021 Approval of Alternative to Use ASME Code Case N-513-4 for Alternative Repair of Intake Cooling Water System ML20259A2982020-11-18018 November 2020 Issuance of Amendment No. 205 Regarding Modification of the Reactor Coolant Pump Flywheel Inspection Program ML20237F2572020-10-30030 October 2020 Issuance of Amendment Nos. 251 and 204 Regarding Adoption of Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6 Development of Emergency Action Levels for Non-Passive Reactors ML20099A3482020-06-25025 June 2020 Safety Evaluation for Relief Request for Fifth Ten-Year Inservice Inspection (ISI) Interval - Alternative Risk-Informed Inservice Inspection Program for Class 1 and 2 Piping Welds ML20023B3782020-02-19019 February 2020 Safety Evaluation for Relief Request RR-16, Alternate Repair of 2B Boric Acid Makeup Pump Revision for the Fourth 10-Year Inservice Inspection Interval ML20015A1232020-02-0606 February 2020 Proposed Alternative to Use Encoded Phased Array Ultrasonic Examination Techniques ML19266A0722020-01-27027 January 2020 Issuance of Amendment Nos. 250 and 202 Regarding Technical Specification Changes to Allow the Performance of Selected Emergency Diesel Generator Surveillance Requirements During Power Operation ML19254B5332019-09-30030 September 2019 Safety Evaluation for Relief Request RR#15, Revision 0, Regarding Limited Piping Examinations ML19148A7442019-07-31031 July 2019 Issuance of Amendment Nos. 161, 249, 200, 287, and 281 to Add Technical Specification Limiting Condition for Operation 3.0.6 ML19203A1662019-07-26026 July 2019 Issuance of Exigent Amendment No. 248 Technical Specification 3/4.8.1 Change to Allow for a One-Time Extension of the Allowed Outage Time for One Emergency Diesel Generator ML19115A2812019-05-31031 May 2019 Safety Evaluation for Relief Request No. 6 for the Fifth 10 Year Inservice Inspection Interval ML19058A4922019-04-23023 April 2019 Issuance of Amendment 198 Regarding Technical Specification Changes to Reduce the Number of Control Element Assemblies ML18274A2242018-11-0202 November 2018 Issuance of Amendment Nos. 246 and 197 Regarding Technical Specifications Site Area Map ML18256A0982018-10-30030 October 2018 Safety Evaluation for Relief Request No.5 for the Fifth 10-Year Inservice Inspection Interval ML18129A1492018-07-0909 July 2018 Issuance of Amendments Regarding Technical Specification Changes Related to the Auxiliary Feedwater System (CAC Nos. MG0237 and MG0238; EPID L-2017-LLA-0296) ML18106B1212018-04-25025 April 2018 Proposed Alternative to Use Encoded Phased Array Ultrasonic Examination Techniques ML18046A7122018-03-26026 March 2018 Issuance of Amendments Regarding the Unusual Event Fire Related Emergency Action Level Scheme ML18018A0332018-01-26026 January 2018 Safety Evaluation of Relief Requests for the Fifth 10-Year Inservice Testing Program (EPID L-2017-LLR-0113; L-2017-LLR-0017, L-2017-LLR-0018, L-2017-LLR-0119, L-2017-LLR-0120, L-2017-LLR-0121, and L-2017-LLR-0122) ML17334A9362018-01-0404 January 2018 Relief from the Requirements of the ASME Code Regarding Relief Request No. 17, Revision 0, for the Fourth 10-Year Inservice Inspection Interval (CAC No. MF9826; EPID L-2017-LLR-0043) ML17341A4422018-01-0404 January 2018 Relief from the Requirements of the ASME Code Relief Request No. 3 for the Fifth 10-Year Inservice Inspection Interval (CAC No. MF9288; EPID L-2017-LLR-0003) ML17257A0152017-10-31031 October 2017 Issuance of Amendments Regarding Technical Specification Changes Related to the Reactor Protection System and Limiting Condition for Operation 3.0.5 ML17263A1202017-10-27027 October 2017 Inservice Inspection Plan Fourth 10-Year Interval Relief Request No. 16 (CAC No. MF9827; EPID L-2017-LLR-0044) ML17248A3792017-10-23023 October 2017 Issuance of Amendments to Revise the Renewed Facility Operating Licenses Fire Protection License Conditions (CAC Nos. MF9681 and MF9682; EPID L-2017-LLA-0230) ML17235A5652017-10-0505 October 2017 Issuance of Amendments Regarding Technical Specification Changes Related to Component Cyclic or Transient Limits ML17219A1742017-08-31031 August 2017 Relief from the Requirements of the ASME Code Regarding Relief Request 12 for the Fourth 10-Year Inservice Inspection Interval ML17195A2912017-08-14014 August 2017 Issuance of Amendments Regarding Relocation of Radiation Monitor Requirements from Technical Specifications to Licensee-Controlled Documents ML17132A1672017-07-10010 July 2017 Inservice Inspection Plan Fourth 10 Year Interval Relief Request No. 13 ML17110A2702017-05-10010 May 2017 Inservice Inspection Plan Fourth 10-year Interval Relief Request No. 14 Rev 0 - ML17027A0782017-04-0707 April 2017 Issuance of Amendments Regarding Technical Specifications for Inservice Testing Programs (CAC Nos. MF8202 Through MF8209) ML17038A2252017-03-29029 March 2017 Issuance of Amendment No. 188 Regarding Emergency Diesel Generator Day Tank Volume ML16330A1182016-12-15015 December 2016 NextEra Fleet - Safety Evaluation for Proposed Alternative to the American Society of Mechanical Engineers Operation and Maintenance Code by Adoption of Approved Code Case OMN-20, Inservice Test Frequency (CAC Nos. MF8195 Through MF8201) ML16251A1282016-12-0505 December 2016 Issuance of Amendments to Update Appendix B to the Renewed Facility Operating License to Incorporate the 2016 Biological Opinion ML16292A7612016-11-0202 November 2016 Inservice Inspection Plan Fourth 10 Year Interval Relief Request No. 11 ML16166A4242016-10-0505 October 2016 St. Lucie Plant, Unit Nos. 1 and 2 - Issuance of Amendments Regarding the Use of a New Computer Code to Model the Containment Vacuum Analyses ML16183A1382016-09-19019 September 2016 Issuance of Amendments Regarding Technical Specification Change to Eliminate the Moderator Temperature Coefficient Surveillance Test at the End of Cycle ML16210A3742016-08-30030 August 2016 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-422, Revision 2 ML16103A3972016-07-28028 July 2016 Issuance of Amendments Regarding Removal of Technical Specification for Cleaning Fuel Oil Storage Tank Sediment and Relocating Procedures to Licensee Controlled Documents ML16167A4732016-07-0505 July 2016 Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 ML16139A5882016-05-27027 May 2016 Inservice Inspection Plan Fourth 10-Year Interval Relief Request No. 10, Revision 0 ML16124A3832016-05-25025 May 2016 St. Lucie Plant, Unit No. 1 - Issuance of Amendment Regarding Changes to the Snubber Surveillance Requirements (CAC No. MF6490) ML16063A1212016-04-19019 April 2016 Redacted - Issuance of Amendment Regarding License Amendment Request for the Transitioning to Areva Fuel ML15344A3462016-03-31031 March 2016 Issuance of Amendments Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with Title 10 of the Code of Federal Regulations Section 50.48(c) (CAC Nos. MF1373 & MF1374) 2023-09-01
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Text
May 29, 2003 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
SAINT LUCIE NUCLEAR PLANT, UNIT 2 - SAFETY EVALUATION FOR RELIEF REQUEST NO. 37 REGARDING RADIOGRAPHIC INSPECTION OF INTAKE COOLING WATER SYSTEM PIPING (TAC NO. MB8732)
Dear Mr. Stall:
By a letter dated May 1, 2003, as supplemented in a letter dated May 4, 2003, Florida Power and Light Company, et al. (the licensee) submitted Relief Request 37 for Saint Lucie Unit 2, requesting relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (Code), 1989 Edition,Section XI, Article IWD-4000, Paragraph IWD-4100, which would require radiographic examination of sections of the Intake Cooling Water System piping following weld repair. Pursuant to Title 10 of the Code Federal Regulation (10 CFR)
Section 50.55a(a)(3)(i), the licensee proposed an alternative inspection in accordance with the Code,Section XI, 2001 Edition, paragraph IWA-4520(a)(1).
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensees proposed alternative and has concluded that it provides an acceptable level of quality and safety.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative is authorized for the remainder of the second 10-year Inservice Inspection interval at Saint Lucie Unit 2, which ends on August 7, 2003.
Further details on the bases for the NRC staffs conclusions are contained in the enclosed safety evaluation. If you have any questions regarding this issue, please feel free to contact Brendan Moroney at (301) 415-3974.
Sincerely,
/RA/
Allen G. Howe, Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-389
Enclosure:
Safety Evaluation cc: See next page
ML031490067 *By Memo OFFICE PDII-2/PM PDII-2/PM PDII-2/LA OGC EMCB/SC PDII-2/SC NAME EBrown BMoroney BClayton RHoefling NLO TChan* AHowe DATE 05/23/03 05/23/03 5/23/03 05/28/03 5/22/03 5/29/03 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION INSERVICE INSPECTION PROGRAM RELIEF REQUEST NO. 37 FLORIDA POWER AND LIGHT COMPANY, ET AL.
SAINT LUCIE NUCLEAR PLANT, UNIT 2 DOCKET NO. 50-389
1.0 INTRODUCTION
By a letter dated May 1, 2003, as supplemented in a letter dated May 4, 2003, Florida Power and Light Company, et al. (FPL, the licensee) submitted Relief Request (RR) 37 for Saint Lucie (St. Lucie) Unit 2, requesting relief from the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel (B&PV) Code (Code), 1989 Edition,Section XI, Article IWD-4000, Paragraph IWD-4100. The ASME Code requires radiographic examination of sections of the Intake Cooling Water (ICW) System piping following weld repair.
Pursuant to Title 10 of the Code Federal Regulation (10 CFR) Section 50.55a(a)(3)(i), the licensee has proposed an alternative inspection in accordance with the Code,Section XI, 2001 Edition, paragraph IWA-4520(a)(1). Specifically, the proposed alternative will allow the licensee to perform a final surface examination in lieu of a radiographic examination, regardless of the surface area of the weld repair, for Class 3 lined steel piping in the ICW System. When the repair does not penetrate through the piping, the repair excavation area will receive a surface examination prior to welding. Where the repair penetrates through the piping, the root pass of the repair weld will receive a surface examination consistent with the guidance contained in Regulatory Guide 1.147 and ASME Code Case N-416-1.
2.0 REGULATORY EVALUATION
In accordance with 10 CFR Section 50.55a(a)(3), alternatives to the requirements of 10 CFR 50.55a(g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety, and (ii) compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
In accordance with 10 CFR 50.55a(g), inservice inspection of nuclear power plant components shall be performed in accordance with the requirements of ASME Code,Section XI, except where specific written relief has been granted by the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.55a(g)(6)(i).
The Code of record for the second interval for Saint Lucie Unit 2 is the ASME Code,Section XI, 1989 Edition, no addenda.
Enclosure
3.0 TECHNICAL EVALUATION
In the submittal, as supplemented, the licensee requests relief from the requirements of ASME Code,Section III, paragraph ND-4130 to perform radiography on Class 3 piping base metal repairs when the repair area exceeds 10 square inches (in2) of area. FPL requested authorization of this relief to support placing ICW piping in service in order to allow for the refueling outage electrical train swap. The relief was required because repairs were attempted on the ICW piping to repair two previously identified temporary non-code repairs. However, FPL identified an increase in the scope of repair after evaluating field data. FPL completed the final repair area excavations and due to the proximity of some of the additional repairs, the repair preparation and excavation activities resulted in some repair areas exceeding 10 in2.
After discussions with ASME Code experts, FPL concluded that radiography would be required on any identified repair areas that exceeded 10 in2 unless relief from the ASME Code requirements was obtained.
3.1 RELIEF REQUEST NO. 37 3.1.1 Component Identification (as stated)
All St. Lucie 2 Intake Cooling Water (ICW) ASME Class 3 piping and components: such as shown on FPL Drawing 2998-G-082 Sheet 2, Revision 48, "Flow Diagram Circulating & Intake Cooling Water System 3.1.2 Code Requirements for which Relief is Requested ASME B&PV Code, 1989 edition,Section XI, Article IWD-4000, "Repair Procedures," Paragraph IWD-4100, "Scope," states: The rules of IWA-4000 apply.
Article IWA-4000, "Repair Procedures," Paragraph, IWA-4120, "Rules and Requirements" states:
(a) Repairs shall be performed in accordance with the Owners Design Specification and the original Construction Code of the component or system. Later Editions and Addenda of the Construction Code or of Section III, either in their entirety or portions thereof, and Code Cases may be used...
ASME B&PV Code, 1980 edition,Section III, Subsection ND, Paragraph ND-4130 "Repair of Material" states:
Material originally accepted on delivery in which defects exceeding the limits of ND-2500 are known or discovered during the process of fabrication or installation is unacceptable. The material may be used provided the condition is corrected in accordance with the requirements of ND-2500 for the applicable product form, except: (1) the limitation on the depth of the weld repair does not apply; and (2) the time of examination of the weld repairs to weld edge preparation shall be in
accordance with ND-5120. However, radiography is not required for welded repairs in material used in components provided that the welded joints in these materials are not required to be radiographed, the extent of the welded repair does not exceed 10 sq in. (6540 mm2) of the surface area, and the magnetic particle or liquid penetrant examination of the repair is made as required by ND 2539.4.
3.1.3 Licensees Proposed Alternative to Code and Basis for Relief (as stated)
The proposed alternative is to inspect weld repairs to base metal in Class 3 piping systems in accordance with ASME B&PV Code,Section XI, 2001 edition, paragraph IWA-4520(a)(1) which states:
Welding or brazing areas and welded joints made for installation of items shall be examined in accordance with the Construction Code identified in the Repair/Replacement Plan with the following exceptions:
Base metal repairs on Class 3 items are not required to be volumetrically examined when the Construction Code does not require that full penetration butt welds in the same location be volumetrically examined.
In accordance with the proposed alternative, repair welds in Class 3 piping will receive a final surface examination but not radiographic examination, regardless of the surface area of the weld repair. Additionally, when the repair does not penetrate through the piping, the repair excavation area will receive a surface examination prior to welding.
Also, where the repair penetrates through the piping, the root pass of the repair weld will receive a surface examination when required to comply with the conditions of Regulatory Guide 1.147 and Code Case N-416-1 (Reference 1). All of the class 3 piping welds at the St. Lucie Unit 2 plant received a final surface examination during construction; the welds were not radiographed. The final surface examination was in accordance with the governing Construction Code requirements. The proposed alternative results in repair welds receiving a degree of examination equivalent to that imposed on pipe welds during the construction period.
The requirement for imposing radiography on weld repairs with surface area greater than 10 in2 is a common requirement from base material specifications. The requirement is to insure that the final product meets uniform expected properties. The material manufacturer works to a set of specific requirements, not knowing the exact use of the product, fabricating material for stock and subsequent delivery to end users.
The requirement for radiography on weld repairs with surface area greater than 10 in2 is appropriate for a material manufacturer. Once an item is installed, it exists in a specific environment and the universal nature of stock products is inappropriate. Accordingly, the controls to insure uniformity are no longer appropriate or meaningful after installation.
The proposed alternative will be employed starting with the current St. Lucie Unit 2 outage.
In conclusion, the proposal to examine piping base metal weld repairs in a manner equivalent to examination of circumferential butt welds in the piping is an alternative to the requirement to radiograph base metal repairs that have a surface area greater than 10 in2 in piping that is not subject to radiographic examination. The alternate provides a degree of quality and safety equivalent to the Construction Code requirements, and has been approved by the ASME Code.
3.1.4 Duration of Proposed Alternative (as stated)
The proposed alternative will be applicable to any base metal repairs in St. Lucie, Unit 2 ICW Class 3 lined carbon steel piping for the remainder of the second interval for Unit 2.
3.1.5 Evaluation The licensee proposed an alternate examination that results in repair welds receiving a degree of examination equivalent to that imposed on pipe welds during the construction period.
Specifically, the repair welds in Class 3 piping will receive a final surface examination but not radiographic examination, regardless of the surface area of the weld repair. Additionally, when the repair does not penetrate through the piping, the repair excavation area will receive a surface examination prior to welding. Also, where the repair penetrates through the piping, the root pass of the repair weld will receive a surface examination. All of the Class 3 piping welds at the St. Lucie Unit 2 plant had received a final surface examination during construction and were not radiographed. Therefore, the final surface examination was in accordance with the governing Construction Code requirements. The proposed alternative results in repair welds receiving a degree of examination equivalent to that imposed on pipe welds during the construction period.
Under the proposed alternative the ICW repair welds would receive an examination equivalent to that imposed on pipe welds during the construction phase of the plant. Therefore, the proposed alternative examination would detect unacceptable weld defects prior to placing the ICW piping in service and, thus, ensure the structural integrity of the ICW piping. The staff has determined that the proposed alternative examination for the subject ICW piping system provides an acceptable alternative to the requirements of ASME Code Section III, paragraph ND-4130. Requiring examinations in excess of those required to be performed on the welds made during the construction phase would provide little value towards ensuring the structural integrity of the ICW piping because the proposed alternative examinations would detect unacceptable defects in the repair welds prior to placing the piping in service. Based upon review of the information provided by the licensee, the staff finds the proposed examinations of the components in the St. Lucie Unit 2 ICW system to be acceptable.
4.0 CONCLUSION
Based on the information provided in the licensees submittals, the NRC staff has determined that the proposed alternative in RR 37, as described above, provides an acceptable level of quality and safety and, therefore, they are authorized pursuant to 10 CFR 50.55a(a)(3)(i) at St. Lucie 2 for the duration of the second 10-year inspection interval which ends August 7, 2003. This authorization is limited to those components described in Section 3.1.1
above. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this safety evaluation remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
5.0 REFERENCES
- 1) ASME Boiler and Pressure Vessel Code, Code Case N-416-1, "Alternative Pressure Test Requirements for Welded Repairs or Installation of Replacement Items by Welding, Class 1, 2, and 3,Section XI, Div. 1" as accepted by Regulatory Guide 1.147.
- 2) ASME Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 2001 Edition.
- 3) ASME B&PV Code,Section III, Subsection ND, "Nuclear Plant -Components - Class 3 Components," 1980 Edition (in accordance with the provisions of the Repair/Replacement Program).
Principal Contributor: George Georgiev, NRR Date: May 29, 2003
Mr. J. A. Stall ST. LUCIE PLANT Florida Power and Light Company cc:
Senior Resident Inspector Mr. R. E. Rose St. Lucie Plant Plant General Manager U.S. Nuclear Regulatory Commission St. Lucie Nuclear Plant P.O. Box 6090 6351 South Ocean Drive Jensen Beach, Florida 34957 Jensen Beach, Florida 34957 Craig Fugate, Director Licensing Manager Division of Emergency Preparedness St. Lucie Nuclear Plant Department of Community Affairs 6351 South Ocean Drive 2740 Centerview Drive Jensen Beach, Florida 34957 Tallahassee, Florida 32399-2100 Vice President, Nuclear Operations Support M. S. Ross, Attorney Florida Power & Light Company Florida Power & Light Company P.O. Box 14000 P.O. Box 14000 Juno Beach, FL 33408-0420 Juno Beach, FL 33408-0420 Mr. Rajiv S. Kundalkar Mr. Douglas Anderson Vice President - Nuclear Engineering County Administrator Florida Power & Light Company St. Lucie County P.O. Box 14000 2300 Virginia Avenue Juno Beach, FL 33408-0420 Fort Pierce, Florida 34982 Mr. J. Kammel Mr. William A. Passetti, Chief Radiological Emergency Department of Health Planning Administrator Bureau of Radiation Control Department of Public Safety 2020 Capital Circle, SE, Bin #C21 6000 SE. Tower Drive Tallahassee, Florida 32399-1741 Stuart, Florida 34997 Site Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957