ML14172A149
| ML14172A149 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 06/20/2014 |
| From: | Farideh Saba Division of Operating Reactor Licensing |
| To: | Frehafer K Florida Power & Light Co |
| References | |
| MF3470 | |
| Download: ML14172A149 (5) | |
Text
NRR-PMDAPEm Resource From: Saba, Farideh Sent: Friday, June 20, 2014 11:02 AM To: ken.frehafer@fpl.com; Lewis, Atanya (Atanya.Lewis@fpl.com)
Cc: eric.katzman@fpl.com
Subject:
RAIs for St. Lucie 2 (MF3470)
Attachments: St Lucie 2 RAIs for TS Change for Snubber Relocation (MF3470) Revised June - 2014 .docx Importance: High
- Ken, Please see attached RAIs regarding proposed changes to the snubber surveillance requirements for St. Lucie Unit 2. Draft RAIs were discussed with you on June 19. No clarification, except one typographical error, was needed. As we agreed during this call, please response to these RAIs by July 21. 2014.
- Thanks, Farideh Farideh E. Saba, P.E.
Senior Project Manager NRC/ADRO/NRR/DORL 301-415-1447 Mail Stop O-8G9A Farideh.Saba@NRC.GOV 1
Hearing Identifier: NRR_PMDA Email Number: 1394 Mail Envelope Properties (Farideh.Saba@nrc.gov20140620110200)
Subject:
RAIs for St. Lucie 2 (MF3470)
Sent Date: 6/20/2014 11:02:16 AM Received Date: 6/20/2014 11:02:00 AM From: Saba, Farideh Created By: Farideh.Saba@nrc.gov Recipients:
"eric.katzman@fpl.com" <eric.katzman@fpl.com>
Tracking Status: None "ken.frehafer@fpl.com" <ken.frehafer@fpl.com>
Tracking Status: None "Lewis, Atanya (Atanya.Lewis@fpl.com)" <Atanya.Lewis@fpl.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 531 6/20/2014 11:02:00 AM St Lucie 2 RAIs for TS Change for Snubber Relocation (MF3470) Revised June - 2014 .docx 33810 Options Priority: High Return Notification: No Reply Requested: Yes Sensitivity: Normal Expiration Date:
Recipients Received:
REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT REQUEST CHANGES TO SNUBBER SURVEILLANCE REQUIREMENTS FLORIDA POWER AND LIGHT COMPANY (FPL)
ST. LUCIE UNIT 2 DOCKET NO. 50-389 (TAC No. MF3470)
By letter dated January 30, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14049A284), Florida Power and Light (FPL or the licensee) submitted a license amendment request (LAR) for St. Lucie Unit 2. The proposed amendment would revise the Technical Specification (TS) requirements for snubbers to conform to planned revisions to the inservice inspection (ISI) program.
The Nuclear Regulatory Commission (NRC) staff has reviewed the information the licensee provided that supports the proposed LAR and have the following request for additional information (RAI).
RAI 1 , Description and Assessment, Section 2.0, Detailed Description, Page 1, states that St. Lucie Unit 2 third 10-year ISI interval ending date was August 7, 2013. The snubber surveillance program is being removed from the ISI program under the ASME Section XI inspection requirements to comply with the ASME OM Code, Subsection ISTD requirements.
Allowing for a 1 year extension to the existing interval for the snubber program transition, in accordance with ASME OM Code, Subsection ISTA-3120(d), the fourth 10-year interval for snubbers at St. Lucie Unit 2 will begin on August 8, 2014. Currently, snubber testing and examination are performed in accordance with the requirements of TS 3/4.7.9 and St. Lucie Unit 2 third 10-Year ISI Interval Program submitted in letter L-2003-189, dated August 6, 2003 and will continue until August 7, 2014.
(a) FPL letter L-2003-189, dated 6, 2003, regarding third 10-year ISI interval at St. Lucie Unit 2 states that St. Lucie Unit 2 third 10-year ISI program is based on ASME Section XI 1998 Edition with Addenda through 2000. Please verify and confirm that for the snubber program for the third 10-year interval is also based on ASME Section XI, 1998 Edition with Addenda through 2000.
(b) The licensee is proposing to adopt ASME OM Code Subsection ISTD for the snubber program for the fourth 10-year ISI interval. Therefore, the one year extension of the snubber program from the end date of August 7, 2013 to August 7, 2014 for the third 10-year ISI interval cannot be based on the ASME OM Code, Subsection ISTA-3120(d). Please provide the appropriate reasoning and section from the ASME Section XI for extension for third 10-year ISI interval for snubber.
Enclosure
(c) Please confirm that the one year extension for the third 10 year ISI interval is only for snubber program.
RAI 2
In Section 3.0, Technical Evaluation, the second paragraph states that As noted in Regulatory Issue Summary (RIS) 2010-006, the licensees have the option to control the ASME Code-required ISI and testing of snubbers through their TS or other licensee-control documents. For plants using their TS to govern ISI and testing of snubbers, 10 CFR 50.55a(g)(5)(ii) requires that if a revised ISI program for a facility conflicts with the TS, the licensee shall apply to the Commission for amendment of the TS to conform the TS to the revised program. Therefore, when performing 120-month program updates in accordance with 10 CFR 50.55a(g)(4),
licensees must submit any required amendments to ensure their TS remain consistent with the new code of record or NRC-approved alternative used in lieu of the Code requirements.
RIS 2010-06 also states that The TS, TRM, or other licensee-controlled documents, governing the snubber ISI and testing program, do not eliminate the 10 CFR50.55a requirements to update the program at 120-month intervals, in accordance with 10 CFR 50.55a(g)(4), or to request and receive NRC authorization for alternatives to the Code requirements, when appropriate.
(a) The licensee is requested to provide details about the action taken for the snubber program at St. Lucie Unit 2 in response to RIS-2010-006 and Enforcement Guidance Memorandum (EGM) 2010-01.
(b) The licensee is requested to provide detailed evaluation and compatibility of snubber examination and testing requirements of the TS 3/4.7.9, and the Code of Record for the third 10-year ISI interval snubber program (Code of Record for the third 10-year ISI interval at Turkey Point 3 & 4St. Lucie Units 1 and 2 is ASME Section XI, IWF-5000, 1998 Edition with 2000 Addenda).
RAI 3
Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c)(3), Surveillance Requirements, states that, Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The proposed amendment would delete the specific requirements for demonstrating snubber operability, currently in surveillance requirement (SR) 4.7.9. A reference to SR 4.7.9, Snubber Test Program would be added in place of the specific requirements. The proposed changes do not provide sufficient detail necessary to adequately demonstrate snubber operability. Please reference 10 CFR 50.36(c)(3) as part of the basis for this TS change.
Formatted: Widow/Orphan control, Keep with next
RAI 4
Attachments 2 and 3, TS marked up Sections TS 4.7.9 and TS 6.8.4.p (a) Please explain the meaning of snubber life destructive testing, in TS SR 4.7.9.a.
(b) TS Administrative Control Section 6.8.4.p, Snubber Testing Program (1) It would be more appropriate if the referenced regulation 10 CFR 50.55a(b)(3)(v)(B) in Sections 3 and 4 of TS 6.8.4.p are changed to 10 CFR 50.55a(b)(3)(v). This may eliminate the need for TS changes should this section be changed in the future.
Please advise if you agree.
(2) Please change the wordings in TS 6.8.4.p, item 4, from limitations and modifications to conditions to match with the wordings in the current 10 CFR 50.55a.
RAI 5
(a) On Page 8 of 11, third row and third column (Justification for Change) for TS SR 4.7.9.f, NRC staff believes that the referenced TS SR 4.7.9.g should be changed to TS SR 4.7.9.f.
RAI 6 , St. Lucie Plant, Snubber Testing Program (a) This snubber program does not specify that this is for St. Lucie Unit 1 or Unit 2. The cover sheet only states St. Lucie. Please clarify that this snubber program is for St. Lucie Unit 1 or Unit 2 or both.
(b) The snubber program does not specify the fourth 10-year ISI interval.
(c) The snubber program does not specify the start and end date for the fourth 10-year ISI interval.