ML050100222
| ML050100222 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 01/19/2005 |
| From: | Marshall M NRC/NRR/DLPM/LPD2 |
| To: | Stall J Florida Power & Light Co |
| Moroney B, NRR/DLPM, 415-3974 | |
| References | |
| TAC MC3826 | |
| Download: ML050100222 (7) | |
Text
January 19, 2005 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 NUCLEAR PLANT, UNIT 2 SAFETY EVALUATION FOR RELIEF REQUEST NO. 8 REGARDING RADIOGRAPHIC INSPECTION OF INTAKE COOLING WATER SYSTEM PIPING (TAC NO. MC3826)
Dear Mr. Stall:
By a letter dated July 14, 2004, Florida Power and Light Company (FPL, the licensee) submitted Relief Request No. 8 (RR-8) for St. Lucie, Unit 2. FPL requested relief from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, 1998 Edition through Addenda 2000,Section XI, Article IWD-4000, Paragraph IWD-4421, which requires radiographic examination of sections of the Intake Cooling Water System piping following weld repair. FPL proposed an alternative inspection of the repair welds that is equivalent to that imposed on the pipe welds during the construction period.
Pursuant to Title 10 of the Code Federal Regulations Section 50.55a(a)(3)(i), the U.S. Nuclear Regulatory Commission staff finds the licensees proposed alternative provides an acceptable level of quality and safety. Therefore, RR-8 is authorized for the duration of the third Inservice Inspection Interval, which began August 8, 2003, and ends August 7, 2013. The staff's evaluation and conclusions are contained in the enclosed safety evaluation.
If there are any questions, please contact Brendan Moroney at (301) 415-3974.
Sincerely,
/RA/
Michael L. Marshall, Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-389
Enclosure:
Safety Evaluation cc w/enclosure: See next page
ML050100222 NRR-028 OFFICE PM:PDII-2 LA:PDII-2 SC:EMCB-B OGC SC:PDII-2 NAME BMoroney BClayton TChan by memo dated MZobler MMarshall DATE 01/ 11 /05 01/ 11 /05 12/ 23 /04 01/ 17 /05 01/ 19 /05 Mr. J. A. Stall ST. LUCIE PLANT Florida Power and Light Company cc:
Senior Resident Inspector St. Lucie Plant U.S. Nuclear Regulatory Commission P.O. Box 6090 Jensen Beach, Florida 34957 Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 M. S. Ross, Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Marjan Mashhadi, Senior Attorney Florida Power & Light Company 801 Pennsylvania Avenue, NW.
Suite 220 Washington, DC 20004 Mr. Douglas Anderson County Administrator St. Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982 Mr. William A. Passetti, Chief 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 Mr. G. L. Johnston Plant General Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957 Mr. Terry Patterson Licensing Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957 David Moore, Vice President Nuclear Operations Support Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. J. Kammel Radiological Emergency Planning Administrator Department of Public Safety 6000 Southeast Tower Drive Stuart, Florida 34997
ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION INSERVICE INSPECTION PROGRAM RELIEF REQUEST NO. 8 FLORIDA POWER AND LIGHT COMPANY SAINT LUCIE PLANT, UNIT NO. 2 DOCKET NO. 50-389
1.0 INTRODUCTION
By a letter dated July 14, 2004, Florida Power and Light Company (FPL, the licensee) submitted Relief Request (RR) No. 8 (RR-8) for St. Lucie Unit 2, requesting relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code (Code),Section XI, 1998 Edition through 2000 Addenda, Article IWD-4000, Paragraph IWD-4421. The ASME Code requires radiographic examination of sections of the Intake Cooling Water (ICW) System piping following weld repair. The same RR was submitted as RR-37 for the St. Lucie, Unit 2 second 10-year Inservice Inspection (ISI) interval in letters to the U.S. Nuclear Regulatory Commission (NRC) dated May 1, and May 4, 2003. The NRC approved RR-37 by letter dated May 29, 2003. RR-8 requested that the relief remain valid for the duration of the third ISI interval. For the third ISI interval, the Code of Record is ASME, Section Xl, 1998 Edition through the 2000 Addenda.
Pursuant to Title 10 of the Code Federal Regulations (10 CFR) Section 50.55a(a)(3)(i), the licensee has proposed an alternative inspection of the repair welds that is equivalent to the inspection performed on the pipe welds during the construction period. The proposed alternative, therefore, provides an equivalent level of quality and safety. 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.
2.0 REGULATORY EVALUATION
In accordance with 10 CFR 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, or (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), ISI of nuclear power plant components shall be performed in accordance with the requirements of the ASME Code,Section XI, except where specific written relief has been granted by the NRC pursuant to 10 CFR 50.55a(g)(6)(i).
2.1 Licensees Evaluation 2.1.1 Applicable ASME Code Components: ICW ASME Class 3 lined carbon steel piping and components Request Submittals: FPL letter L-2003-116, dated May 1, 2003, and supplemented by letter L-2003-118, dated May 4, 2003.
NRC Approval Letter: NRC letter dated May 29, 2003;
Subject:
St. Lucie Nuclear Plant, Unit 2 - Safety Evaluation for Relief Request No. 37 Regarding Radiographic Inspection of Intake Cooling Water System Piping (TAC No. MB8732).
2.1.2 Changes to the Applicable ASME Code Section ASME B&PV Code Section Xl, 1989 Edition, no addendum, was applicable for the second inspection interval. Article IWA-4000, paragraph IWA-4120(a) states:
"(a) Repairs shall be performed in accordance with the Owner's 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....
For the third ISI interval, the Code of Record is ASME Section Xl 1998 Edition through the 2000 Addenda. Paragraph IWA-4421 of ASME Section Xl, 1998 Edition through the 2000 Addenda has replaced Paragraph IWA-4120(a) of ASME B&PV Code Section Xl, 1989 Edition, no addendum, and Paragraph IWA-4421 states:
"(a) Welding, brazing, defect removal and installation activities shall be performed in accordance with the Owner's Requirements and the Construction Code of the component or system, except as provided in (b) and (c) below.
(b) Later Editions and Addenda of the Construction Code or a later different Construction Code, either in its entirety or portions thereof, and Code Cases may be used....
The licensee states that the above referenced sections of ASME Section XI, 1989 Edition and the 1998 Edition of ASME Section XI through the 2000 Addenda contain the same requirements and, therefore, there are no Code changes that have an effect on this request.
2.1.3 Component Aging Factors The examination and repair of the ICW piping are within the scope of the ICW System Inspection Program which is one of the aging management programs described in the St. Lucie Updated Final Safety Analysis Report. The ICW piping program is one of many programs that were described in the St. Lucies License Renewal Application. The purpose of the ICW inspection program is to manage the aging effects of loss of material due to various corrosion mechanisms affecting the ICW piping. Applicable aging factors are addressed in the ICW piping program; therefore, aging factors do not have an effect on the basis for the Code relief request for which re-approval is being sought.
2.1.4 Changes in Technology for Inspecting or Testing the Affected ASME Code Component(s)
The RR does not address limitations with inspection or testing and this item is not applicable.
Therefore, changes in technology do not affect the basis for the previous request.
2.1.5 Confirmation of Renewed Applicability Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested from ASME Section III, which requires radiography of lined carbon steel ICW piping base metal repair welds when repair welds are greater than 10-square inches in area and circumferential butt welds in the piping were not examined by radiography.
In accordance with the proposed alternative, repair welds in St. Lucie Unit 2 ICW Class 3 lined carbon steel 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. The alternative inspection requirements provide an acceptable level of quality and safety.
The licensee states that, based on the information provided in the previous 10 CFR 50.55a request, information contained within the NRC approval documents, and information provided above, the circumstances and basis continue to be applicable to the proposed request.
2.1.6 Duration of Re-Approved 10 CFR 50.55a Request The RR is to remain valid for the remainder of the third ISI interval.
2.2 Staff Evaluation By a letter dated July 14, 2004, FPL submitted RR-8 for St. Lucie Unit 2, requesting relief from the ASME Code,Section XI, 1998 Edition through 2000 Addenda, Article IWD-4000, Paragraph IWD-4421. The ASME Code requires radiographic examination of sections of the ICW System piping following weld repair. The same RR was submitted as RR-37 for the St. Lucie Unit 2 second 10-year ISI interval in letters to the NRC dated May 1 and May 4, 2003. The NRC approved RR-37 by letter dated May 29, 2003. RR-8 requested that the relief remain valid for the duration of the third ISI interval. For the third ISI interval, the Code of Record is ASME Section Xl 1998 Edition through the 2000 Addenda.
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, provides reasonable assurance of 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 toward 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 repair examination of the components in the St. Lucie Unit 2 ICW system to be acceptable.
3.0 CONCLUSION
Based on the information provided in the licensees submittals, the NRC staff has determined that the proposed alternative in RR-8, as described above, provides an acceptable level of quality and safety and, therefore, is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the duration of the St. Lucie Unit 2 third 10-year inspection interval, which began August 8, 2003, and ends August 7, 2013. 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.
Principal Contributor: G. Georgiev Date: January 19, 2005