ML17222A258
| ML17222A258 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/20/1988 |
| From: | Tourigny E Office of Nuclear Reactor Regulation |
| To: | Conway W FLORIDA POWER & LIGHT CO. |
| References | |
| TAC-66198, NUDOCS 8805270166 | |
| Download: ML17222A258 (12) | |
Text
Docket No. 50-335 May 20, 1988 Hr.
W. F.
Conway Senior Vice President-Nuclear Florida'Power and Light Company P.O.
Box 14000 Juno Beach, Florida 33408
Dear Hr. Conway:
SUBJECT:
ST.
LUCIE UNIT I - RE(VEST FOR ADDITIONAL INFORf<ATION-SECOND 10-YEAR INSERVICE INSPECTION PROGRAM (TAC NO. 66198)
In conducting our review of your September 2,
1987 submittal relating to the above subject at the St. Lucie Plant, Unit No. I, we have determined that we wi 11 need additional information identified in the enclosure to continue our review.
In order for us to maintain our review schedule, your response is requested within 45 days of the date of this letter.
If 'you cannot provide a full response within the requested time, please provide your full response schedule within 30 days of the date of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than 10 respondents; therefore, OHB clearance is not required under P.L.96-511.
Please contact me at (301) 492-1474 if you have any questions concerning this letter.
S incere ly, II
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E.
G. Tourigny, Project f<anager Project Directorate II-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/enclosure:
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+~ 0 c," 4r~ Cy 0O IVl Cy +o ~0 ++*++ UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 May 20, 1988 Docket No. 50-335 Mr. Il. F. Conway Senior Vice President-Nuclear Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408
Dear Mr. Conway:
SUBJECT:
ST.
LUCIE UNIT 1 - RE(VEST FOR ADDITIONAL INFORMATION-SECOND 10-YEAR INSERVICE INSPECTION PROGRAM (TAC NO. 66198)
In conducting our review of your SepterIber 2,
1987 submittal relating to the above subject at the St. Lucie Plant, Unit No. I, we have determined that we wi 11 need additional information identified in the enclosure to continue our review.
In order for us to maintain our review schedule, your response is requested within 45 days of the date of this letter.
If you cannot provide a full response within the requested time, please provide your full response schedule within 30, days of the date of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than 10 respondents; therefore, OMB clearance is not required under P.L.96-511.
Please contact me at (301) 492-1474 if you have any questions concerning this letter.
Sincerely,
Enclosure:
As stated E.
G. Tourigny Pro't Manager Project Direc rate I-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation cc w/enclosure:
See next page
Mr.
W. F.
Conway Florida Power
& Light Company St. Lucie Plant CC Mr. Jack Shreve Office of the Public Counsel Room 4, Holland Building Tallahassee, Florida 32304 Resident Inspector c/o U.S.
NRC 7585 S.
Hwy A1A Jensen Beach, Florida 34957 State Planning
& Development Clearinghouse Office of Planning
& Budget Executive Office of the Governor The Capitol Building Ta 1 lahassee, Florida 32301 Harold F. Reis, Esq.
Newman
& Holtzinger 1615 L Street, N.W.
Washington, DC 20036 John T. Butler, Esq.
- Steel, Hector and Davis 4000 Southeast Financial Center
- Miami, F1 or ida 33131-2398 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301 Mr. Weldon B. Lewis, County Administrator St. Lucie County 2300 Virginia Avenue, Room 104 Fort Pierce, Florida 33450 Mr. Charles B. Brinkman, Manager Washington - Nuclear Operations Combustion Engineering, Inc.
7910 Woodmont Avenue
- Bethesda, Maryland 20814 Jacob Daniel Nash Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.
Tallahassee, Florida 32399-0700 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323
ENCLOSURE FLORIDA POWER AND LIGHT COMPANY ST.
LUCIE PLANT, UNIT 1
DOCKET NUMBER 50-335 Re uest f'r Additional Information - Second 10-Year Interval Inservice Ins ection Pro ram Pla 1.
Sco e Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class I, Class 2,
and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in the ASME Code Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components,"
to the extent practical within the limitations of design,
- geometry, and materials of construction of the components.
This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during successive 120-month inspection intervals shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.
The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein.
Based on the start date of February 11, 1988 for the second 10-year interval, the Inservice Inspection (ISI) Program Plan has been prepared to meet the requirements of the 1983 Edition, Summer 1983 Addenda (83S83) of the ASME Code Section XI. In addition, Code Case N-408, "Alternative Rules for Examination of Class 2 Piping Section XI, Division 1," is incorporated as applicable.
As required by 10 CFR 50.55a(g)(5), if the licensee determines that
certain Code examination requirements are impractical and relief is requested, the licensee shall submit information to the Nuclear Regulatory Commission (NRC) to support that determination.
The staff has reviewed the available information in the St. Lucie Plant, Unit 1, Second 10-Year Interval ISI Program Plan, Revision 0, submitted September 2,
- 1987, and the requests for relief from the ASHE Code Section XI requirements which the Licensee has determined to be impractical.
2.
Additional Information Clarification Re uired Hased on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the ISI Program Plan:
A.
Provide isometric and/or component drawings showing the welds, components, and supports which the ASHE Code requires to be examined during the second 10-year interval.
B.
Section 5.0, "Submittal Summary," of the ISI Program Plan states:
"The Second Ten Year Inservice inspection Plan Tables are being prepared for the components and piping systems which are subject to examination per the requirements of ASIDE Section Xl."
In order to continue the review, the staff requests an itemized listing of the components subject to examination during the second 10-year interval.
The requested listing, along with the isometric drawings, will permit the staff to determine if the extent of ISI examinations meets the applicable Code requirements.
C.
Provide a list of the ultrasonic calibration standards being used during the second 10-year interval ISI at St. Lucie, Unit 1.
This
list should include the calibration standard identifications, material specifications, and sizes.
D.
Provide a list of the nondestructive examination procedures that are being used during the second inspection interval.
E.
Section 3.0, "Relief Requests,"
of the ISI Program Plan states:
"... During the First Ten Year Inspection Interval, there were cases where component configuration and/or interferences prohibited 1002'overage of the Code required volume or surfaces.
In each
- case, where such limitations were encountered, the details are documented in a Relief Request.
Since those same conditions will prevail during this Inservice Inspection Interval, those Relief Requests are included that will be utilized in the Second ISI Interval..."
The relief requests submitted for the second 10-year interval should be specific only to the examinations being performed during the second interval.
The following are "examples" of relief requests which do not appear to reflect Section XI requirements for the second 10-year interval only:
RR-1:
RR-2:
RR-3:
Examination Category B-A, Pressure Retaining Welds in the Reactor Pressure Vessel; Examination Category B-A, Reactor Pressure Vessel Closure Head; and Examination Category B-B, Pressure Retaining Welds in Vessels other than Reactor Vessels.
Revise the above relief requests, and any others which do not reflect the specific examination requirements for the second 10-year interval, to reference only those items which are scheduled during the second 10-year interval.
F.
All Relief Requests:
Provide an estimate of the percentage of the Code-required examination that can be completed for each of the specific examinations for which relief is requested for the second 10-year interval.
If the Code required examination for a specific weld cannot be completed to the extent required by the Code, consideration should be given to meeting the intent of the Code by performing examinations on adjacent similar weldments (e.g. reactor vessel beltline region welds, reactor vessel head meridional welds, etc.).
G.
Relief Request Nos. I, 2, 3, 4, 5, 6, 7, and 9:
These relief requests list attachments (e.g. drawings,
- sketches, tables) that accompany the relief requests.
These attachments are missing from the package that was submitted for review and are required in order to continue the review.
H.
Relief Request No. 2:
Relief is requested from performing both the Code-required surface and volumetric examinations on the reactor pressure vessel closure head-to-flange weld and on the closure head meridional welds.
The "Basis for Relief" provided with the request for relief shows no justification for not performing the Code-required surface examination on the closure head-to-flange weld.
Provide information as to why the surface examination of the closure head-to-flange weld cannot be performed to the extent required by the Code.
Also discuss the impact of removing the closure head insulation ring in order to perform the Code-required surface and volumetric examinations on the closure head meridional welds, or the possibility of performing additional examinations on adjacent meridional welds in order to meet the intent'of the Code.
I.
Relief Request No. 6:
Relief is requested from the ASIDE Code-required surface examination of the reactor pressure vessel nozzle-to-pipe transition welds.
The Licensee has proposed the use of state-of-the-art ultrasonic techniques to examine the outside surface of the reactor pressure vessel nozzle-to-pipe transition
- welds, from the I.D. surface, in lieu of the Code-required surface examination.
The Licensee reports that the ultrasonic examination will investigate the outside surface of the welds in two directions circumferentially and in two directions axially covering 100K of the weld plus one inch of the base material on each side.
The examination sensitivity will be established using 2X of thickness notches.
The proposal could be considered acceptable provided that the Licensee meets the following conditions:
(I)
The remote volumetric examination includes the entire weld volume and heat affected zone instead of only the inner one-third of the weld as required by the Code.
(2)
The ultrasonic testing instrumentation and procedure are demonstrated to be capable of detecting O.D. surface-connected
- defects, in the circumferential orientation, in a laboratory test block.
The defects should be cracks and not machined notches.
Provide a discussion of the above conditions
~
J.
Relief Request No. 9:
Relief is requested from performing surface examinations on all pressure retaining piping welds in the Containment Spray System with I/2 inch or less nominal wall thicknesses.
Based on review of Appendix B, "Class 2 Examination Summary Tables,"
and Relief Request No. 9, it appears that the 5
Containment Spray System has been completely exempted from any ISI examinations during the second 10-year interval.
Paragraph 10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2 piping welds in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC),
and Containment Heat Removal (CHR) systems shall be examined.
These systems should not be completely exempted from inservice volumetric examination based on Section XI exclusion criteria contained in IWC-1220.
Later editions and addenda of the Code, and Code Case N-408 which has been implemented by St. Lucie Unit 1, require volumetric and surface examination of Class 2 piping welds greater than or equal to 3/8-inch nominal wall thickness for piping greater than 4-inch nominal pipe size (NPS).
Based on Code Case N-408, piping and other components of any size beyond the last shutoff valve in open ended portions of systems that do not contain water during normal plant operating conditions are exempt from the volumetric and surface examination requirements of IWC-2500.
Discuss the method that the Class 2 piping welds in the containment spray systems meets the 7.5% volumetric and surface examination requirement of Code Case N-408.
K.
Relief Request No. 12:
This is a generic relief request without a listing of specific components for which relief is requested.
The regulations do not provide for granting generic relief requests.
Therefore, the staff requests the following information:
(I) List the specific Class I and Class 2 welds for which relief is being requesting during the second 10-year interval; (2)
For each of the subject welds, provide a description of the obstructions of limitations encountered during the course of the examination(s);
and
-(3)
Provide an estimate of the percentage of the Code-requ,ired examination(s) that can be performed for each of the welds listed.
L.
Appendix A, "Class 1 Examination Summary Tables," in the ISI Program Plan does not include any pressure retaining dissimilar metal nozzle welds (Examination Category 8-F) on the reactor pressure vessel for examination during the second 10-year interval.
Confirm that there are no reactor vessel nozzle-to-safe end welds that would require examination during the second 10-year interval at St. Lucie, Unit 1.
M.
Provide clarifications on the following items with regard to the "Class 2 Examination Summary Tables,"
Examination Category C-F-l, in Appendix 8 of the ISI Program Plan:
(1)
Define Code Item Numbers C5.43 and C5.44 of Examination Category C-F-1 as listed on pages 4, 5, and 6 of the Table.
(2)
Define the exemption used for excluding the
(3)
Based on review of the Summary Table for C-F-1 welds, it appears that the SD-CLG, LPSI, and C.S.
systems have been completely exempted from ISI examinations during the second 10-year interval based on the above exemption.
Verify that these
- systems, and any other
- systems, have not been completely exempted from ISI examinations during the second 10-year interval.
Paragraph 10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2
piping welds in the
These systems should not be completely exempted from inservice volumetric examination based on Section XI exclusion criteria contained in IWC-1220.
(See paragraph I. above for further information.)
N.
The ISI Program Plan states that the extent and frequency of testing for mechanical and hydraulic snubbers shall be governed by the Plant Technical Specifications.
Provide a brief narrative on the examination of component supports that explains the basis of the program.
Provide an estimate of the sample size versus the entire population, separated by Code class.
The schedule for timely completion of this review requires that the Licensee provide, by the requested
- date, the above requested information and/or clarifications with regard to the St. Lucie Plant, Unit 1, Second 10-Year Interval ISI Program, Revision 0.