ML042860412

RAI Regarding Requests for Relaxation from Inspection Requirements of Order EA-03-009

ML042860412
Person / Time
Site:	Saint Lucie
Issue date:	10/12/2004
From:	Moroney B NRC/NRR/DLPM/LPD2
To:	Stall J Florida Power & Light Co
Moroney B, NRR/DLPM, 415-3974
References
Download: ML042860412 (6)

Text

October 12, 2004 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:

ST. LUCIE PLANT, UNIT 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUESTS FOR RELAXATION FROM INSPECTION REQUIREMENTS OF ORDER EA-03-009

Dear Mr. Stall:

By letter dated May 6, 2004, Florida Power and Light Company submitted two requests for relaxation from the inspection requirements of the U.S. Nuclear Regulatory Commission (NRC)

Order EA-03-009, for St. Lucie Unit 2. The NRC staff has reviewed the submittal and finds that a response to the enclosed request for additional information is needed before we can complete the review.

This request was discussed with your staff on October 7, 2004, and Mr. George Madden indicated that a response would be provided by October 29, 2004. If you have any questions, please feel free to contact me at 301-415-3974.

Sincerely,

/RA by JArroyo for/

Brendan T. Moroney, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No.: 50-389

Enclosure:

As stated cc w/encl: See next page

Mr. J. A. Stall ST. LUCIE PLANT Florida Power and Light Company cc:

Senior Resident Inspector Mr. G. L. Johnston 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 Mr. Terry Patterson Division of Emergency Preparedness Licensing Manager Department of Community Affairs St. Lucie Nuclear Plant 2740 Centerview Drive 6351 South Ocean Drive Tallahassee, Florida 32399-2100 Jensen Beach, Florida 34957 M. S. Ross, Managing Attorney David Moore, Vice President Florida Power & Light Company Nuclear Operations Support P.O. Box 14000 Florida Power and Light Company Juno Beach, FL 33408-0420 P.O. Box 14000 Juno Beach, FL 33408-0420 Marjan Mashhadi, Senior Attorney Florida Power & Light Company Mr. Rajiv S. Kundalkar 801 Pennsylvania Avenue, NW. Vice President - Nuclear Engineering Suite 220 Florida Power & Light Company Washington, DC 20004 P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Douglas Anderson County Administrator Mr. J. Kammel St. Lucie County Radiological Emergency 2300 Virginia Avenue Planning Administrator Fort Pierce, Florida 34982 Department of Public Safety 6000 Southeast Tower Drive Mr. William A. Passetti, Chief Stuart, Florida 34997 Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Mr. William Jefferson, Jr.

Site Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000

ML042860412 NRR-088 OFFICE PDII-2/PE PDII-2/PM PDII-2/LA EMCB/SC PDII-2/SC NAME JArroyo JArroyo for BClayton TChan MMarshall BMoroney DATE 10/12/2004 10/12/2004 10/12/2004 10/12/2004 10/12/2004 REQUEST FOR ADDITIONAL INFORMATION FLORIDA POWER AND LIGHT COMPANY ST. LUCIE NUCLEAR POWER PLANT, UNIT 2 DOCKET NUMBER 50-389 The following questions relate to Relaxation Request No. 3 (Florida Power and Light (FPL) letter L-2004-095 dated May 6, 2003)

1. The proposed alternative invokes a supplemental examination by nonvisual nondestructive examination on nozzles with less than 0.50 inch ultrasonic coverage below the J-groove weld. Since the First Revised Order EA-03-009 requires examinations to 1-inch below the J-groove weld provided the stress level at below 1 inch is less than 20 ksi, please justify use of the 0.50-inch criterion, which will limit the supplemental examinations to only 18 nozzles.

2. The proposed alternative was mainly based on a flaw tolerance analysis as documented in WCAP-16038-P, which was completed in March 2003. There has been an inspection since, during which axial cracks were found in two nozzles. The submittal references a previous letter (Ref. 3, FPL Letter L-2003-129) which documented the findings. However, there is no analysis or discussion assessing the impact of the findings on the flaw tolerance analysis. The inspection findings appear to call into question the validity of the flaw tolerance analysis.

a. Please provide your failure analysis regarding the cracks, including a sketch of the flaw found on nozzle 18.

b. Have the findings been used to update the flaw tolerance analysis in WCAP-16038?

c. Are the results and conclusions in WCAP-16038 still valid? Provide technical bases, including the growth rate calculated from the cracks, to substantiate your conclusions.

3. The requested duration for the relaxation includes the next two refueling outages (SL2-15 and SL2-16). If the Nuclear Regulatory Commission (NRC) staff determines that the relaxation request is acceptable, approval may be granted for two refueling outages, subject to a condition such as the following:

If there are significant adverse findings during the inspection in the SL2-15 outage, the NRC staff, at its discretion, may rescind or modify approval of the relaxation for the SL2-16 outage inspection.

Please indicate your acceptance of this condition or propose alternative wording.

4. Granting of relaxation will also be subject to the following condition, which was included in the previous relaxation for the SL2-14 outage:

If the NRC staff finds that the crack growth formula in industry report MRP-55 is unacceptable, the licensee shall revise its analysis that justifies relaxation of the Order within 30 days after the NRC informs the licensee of an NRC-approved crack growth formula. If the licensees revised analysis shows that the crack growth acceptance criteria are exceeded prior to the end of the current operating cycle, this relaxation is rescinded and the licensee shall, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, submit to the NRC written justification for continued operation. If the revised analysis shows that the crack growth acceptance criteria are exceeded during the subsequent operating cycle, the licensee shall, within 30 days, submit the revised analysis for NRC review. If the revised analysis shows that the crack growth acceptance criteria are not exceeded during either the current operating cycle or the subsequent operating cycle, the licensee shall, within 30 days, submit a letter to the NRC confirming that its analysis has been revised.

Please indicate your continued acceptance of this condition.