L-2014-344, Inservice Inspection Plan, RAI Reply - Fourth Ten-Year Interval Relief Request No. 6, Revision 0
| ML14335A317 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/11/2014 |
| From: | Katzman E Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2014-344, TAC MF4336 | |
| Download: ML14335A317 (6) | |
Text
0 November 11, 2014 FPL.
L-2014-344 10 CFR 50.4 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re:
St. Lucie Unit 2 Docket No. 50-389 Inservice Inspection Plan RAI Reply - Fourth Ten-Year Interval Unit 2 Relief Request No. 6, Revision 0 References
- 1. FPL Letter L-2014-169 dated June 30, 2013, "Inservice Inspection Plan Fourth Ten-Year Interval Unit 2 Relief Request No. 6, Revision 0," ADAMS Accession No. ML14203A004
- 2. NRR E-mail Capture - "Draft RAIs for St. Lucie Unit Relief Request No. 6," ADAMS Accession No. ML14267A533 In accordance with Reference 1, Florida Power & Light (FPL) requested relief from the examination requirements for snubber supports and associated attachment hardware as specified in ASME Section XI, IWF-2500. In Reference 2, the NRC forwarded a request for additional information (RAI) on the relief request. The attachment to this letter provides FPL's response to the RAI.
Please contact Ken Frehafer at (772) 467-7748 if there are any questions about this submittal.
Sincerely, Eric S. Katzman Licensing Manager St. Lucie Plant Attachment ESK/KWF cc:
NRC Region II Administrator NRC Site Resident Inspector ggqk Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957
L-2014-344 Attachment Page I of 5 FPL RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)
FLORIDA POWER AND LIGHT, ST. LUCIE UNIT 2, RELIEF REQUEST 6, REVISION 0, FOURTH TEN YEAR 10-YEAR INTERVAL DOCKET NUMBER: 50-389 (TAC NO. MF4336)
RAI 1
In submitted relief request, two different ASME Codes are being used (a) ASME OM Code for snubbers (pin-to-pin), and (b) ASME Boiler & Vessel Code,Section XI for snubber associated attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments). Verify that ASME OM Code 2004 Edition with 2005 and 2006 Addenda, and ASME Section XI 2007 Edition with 2008 Addenda will be used.
FPL Response; Yes, the ASME OM Code 2004 Edition with 2005 and 2006 Addenda will be used from pin to pin inclusively and ASME Section XI 2007 Edition with 2008 Addenda will be used from pin to structure and pin to piping (associated attachment hardware).
RAI 2
For most plants, snubber (pin-to-pin) inservice examination and snubber associated attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments) examinations are implemented by separate programs. Explain in details how two different programs (1) snubbers (pin-to-pin) and (2) snubber associated attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments), examinations will be maintained and implemented under one program, as proposed.
FPL Response; FPL is proposing that a single program, the St. Lucie snubber program, maintain the schedule of the examination of snubbers and the associated attachment hardware. The practice at St.
Lucie has been to perform a VT-3 examination of the snubber and associated attachment hardware over the past several cutages. Currently, the maximum inspection interval for snubber visual examinations is 48 months. However, as a result of St. Lucie unit 2's 18 month fuel cycles, all snubbers are examined every 36 months. The balance of the support assembly falling under the jurisdiction of ASME Section XI will be examined concurrently with scheduled snubber examinations. Attributes required by both IWF and ISTD are included on the examination data sheets. Drawings associated with the complete support assembly are provided for each examination. Examinations are performed by VT-3 certified personnel.
Findings identified during examinations that fail to meet specified criteria from IWF and ISTD are entered into the corrective action program. Findings associated with the snubber from pin to pin inclusively are evaluated in accordance with ASME OM Code. Findings between the pin to structure and the pin to pipe are evaluated in accordance with ASME Section XI IWF. FPL will review the snubber program procedure OSP-73.01 and incorporate changes necessary to ensure compliance with ASME Section XI, IWA & IWF requirements.
L-2014-344 Attachment Page 2 of 5
RAI 3
In Relief Request RR-6, Section 4, "Reason for Request," it states that "PSL-2 is required to perform VT-3 visual examination on Class 1, 2, and 3 supports, including attachment hardware, per ASME Section XI. PSL-2 is also required to perform visual examinations and testing on snubber assemblies in accordance with ASME OM Code, Subsection ISTD. When incorporating the criteria of Subsection ISTD into the Snubber Program, FPL included the visual examination of snubber attachment hardware (pin-to-pipe and pin-to-structure) along with the visual examination of the snubber assembly (pin-to-pin). The visual examination criteria of the Snubber Program are nearly identical to those established by ASME Section Xl. Having two identical sets of requirements for visual examination of snubber attachment hardware would require the performance of redundant examination and cause unnecessary confusion in the sample section, data collection and documentation of these examinations."
Explain how the proposed visual examination criteria of the snubber program (ASME OM Code, Subsection ISTD) are identical to the VT-3 visual examination per IWA-2213 (IWA-2213(a) thru IWA-2213(g)) of ASME Section Xl, Edition 2007 with 2008 Addenda.
FPL Response:
As a result of administrative changes, QI-10-PR/PSL-6 has been replaced by OSP 73.01. The relief request was referring to the examination criteria that was previously included in QI-1 0-PR/PSL-6 and has been included in the St. Lucie snubber program procedure OSP 73.01.
Attributes for examinations required by ASME Section Xl and the OM Code are included in the procedure. FPL will review the snubber program procedure OSP-73.01 and incorporate changes necessary to ensure compliance with ASME Section Xl, IWA & IWF requirements.
L-2014-344 Attachment Page 3 of 5
RAI 4
In Section 5, "Proposed Alternative," FPL proposes to perform the visual examination of snubbers and associated attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments) per the Snubber Program, which is documented in St. Lucie Instruction Procedure No. QI-10-PR/PSL-6.
Please explain in detail (by referencing applicable Sections of the ASME OM Code and ASME Section XI for VT-3) how St. Lucie Unit 2 Instruction Procedure No. QI-1 O-PR/PSL-6, which is proposed to perform the visual examination of snubbers and associated attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments), meets all the VT-3 requirements of ASME Section XI.
FPL response; As a result of administrative changes, QI-10-PR/PSL-6 has been replaced by OSP-73.01 for snubber inspections. Section 9.1 of OSP-73.01states the following for inspection boundary:
9.1 Visual Examinations "The examination boundary for snubbers shall be from the building structure up to and including the attachment to the piping system. When the support is connected to existing steel the building structure is defined as the attachment point to the existing steel.
OSP-73.01 Attachment 2 for mechanical snubbers and Attachment 4 for hydraulic snubbers contain the following instructions pertaining to the balance of the support outside of the pin to pin connections for the snubbers.
GENERAL INSTRUCTIONS: Perform a VT-3 examination of the support assembly from the building structure up to and including the pipe attachment. When the support is connected to existing steel the building structure is defined as the attachment point to the existing steel.
SUPPORT STRUCTURE:
Observe the general condition of the support structure components. Record any anomalies which may suggest degradation or loss of integrity.
Check the condition (corrosion, etc.), tightness and integrity of threaded fasteners, cotter pins and other connecting parts, including attachments to intervening elements. Observe welds for evidence of cracks.
Check the integrity of associated embedment plates, including evidence of spalling.
Check piping/component insulation in the vicinity of snubber attachments for evidence of movement.
Note any other reasons for concern with the integrity of the support structure.
FPL will review the snubber program procedure OSP-73.01 and incorporate changes necessary to ensure compliance with ASME Section XI, IWA & IWF requirements.
L-2014-344 Attachment Page 4 of 5
RAI 5
In a FPL Technical Specification amendment request submittal dated June 30, 2014 (ADAMS Accession No. ML14049A284), Attachment 5, "Proposed Snubber Program Plan," Section 4.2 of "Examination and Testing Frequency," states that Code Case OMN-13, which allows the extension of visual examination interval (up to 10 years), will be implemented for snubber inspection. This means that snubber attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments) will also be inspected on extended frequency of 10 years.
ASME Section Xl, Table IWF-2500-1, requires 15% of Class 1, 15% of Class 2, 10% of Class 3, and 100% of the supports (other than piping supports) over a 10-year interval. Please respond to the following:
(1) ASME OM Code Case OMN-13 allows extension of the snubber visual examination to once every 10 years, and can be implemented after the requirements of ISTD-4251 and ISTD-4252 have been satisfied and the previous examination per Table ISTD 4252-1 was performed satisfactory at a maximum interval of two fuel cycles.
After implementing Code Case OMN-1 3, please explain and elaborate on how the proposed visual examination of snubber (pin-to-pin) and snubber associated attachment hardware (pin-to-pipe and pin-to-structure) extended up to 10 years, can be aligned with the 10-year ISI interval of the support attachments (containing the snubber) for inspection.
FPL Response; Currently, St. Lucie Unit 2 does not satisfy the conditions required to extend the examination frequency to the 10 year maximum allowable. Currently, 100% of the examinations which include the snubber and associated attachment hardware are repeated every 3 years. If OMN-13 is implemented and the program inspection interval is increased to the 10 year maximum allowable, the complete support assembly would be examined every 10 years. Therefore, a larger population of examinations is performed of snubbers and their associated attachment hardware that required by ASME Section Xl, Table IWF-2500-1. FPL does not intend to align the snubber program interval with the 10 Year ISI interval. A new relief request will be required at the end of the 10 Year ISI interval in August 2023.
(2) While using OMN-1 3 for snubbers during the extended interval of 10 years, if the number of unacceptable snubbers (pin-to-pin) exceeds the ISTD-4252-1 limits (these unacceptable snubbers can be found during non-inspection activities such as walkdowns or any other events i.e. water hammer, etc.), what action will be taken and how will these findings align with the supports and attachments inspection.
FPL Response; Changes to the inspection schedule required by ISTD-4252-1 will result in the same change in schedule for the balance of the support assembly. Findings falling under the jurisdiction of the ASME OM Code have an impact on the inspection interval per ISTD-4252-1.
Findings outside the pin to pin boundary will be evaluated for in accordance with ASME Section Xl and would not be considered a failure when Table ISTD-4252-1 is applied.
L-2014-344 Attachment Page 5 of 5
RAI 6
IWF-2430(a) states, in part, that component supports examinations performed in accordance with Table IWF-2500-1 that reveal flaws or relevant conditions exceeding the acceptance standards of IWF-3400, and that require corrective measures, shall be extended, during the current outage, to include the component supports immediately adjacent to flawed supports.
Please explain how this situation (to include supports adjacent to flawed supports) will be considered, while using the proposed relief request to perform the visual examination of snubbers (pin-to-pin) and associated attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments). (Note: The adjacent flawed supports could be with or without a snubber)
FPL Response; Pin to pin findings will be evaluated in accordance with ASME OM Code requirements and will not be subject to IWF requirements for evaluation and expansion. Findings identified from pin to structure and pin to piping system will be evaluated in accordance with IWF and corrective measures taken (including scope expansion if applicable) during the same refueling outage.