L-93-190, Forwards Relief Request 13, Repair Requirements for Class 2 Tank for Temporary non-code Repair to Unit 1 RWT Botton for Approval.Rev 1 to SE JPN-PSL-SENP-93-035, Evaluation of Inventory Loss from RWT, St Lucie,Unit 1 Also Encl
| ML17228A235 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/30/1993 |
| From: | Sager D FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17228A236 | List: |
| References | |
| L-93-190, NUDOCS 9308060325 | |
| Download: ML17228A235 (8) | |
Text
DOCKET 05000335
SUBJECT:
Forwards Relief Request 13, "Repair Requirements for Class 2
Tank" for temporary non-code repair to Unit 1 RWT botton for approval.Rev 1 to.SE JPN-PSL-SENP-93-035, "Evaluation of Inventory Loss from RWT," St Lucie,Unit 1 also encl.
DISTRIBUTION CODE:
A047D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code NOTES:
ACCEI ERAT DOCUMENT DISTRIBUTIONSYSTEM REGULRT INFORMATION DISTRIBUTION'STEM (RIDE)
ACCESSION NBR:9308060325 DOC.DATE: 93/07/30 NOTARIZED:
NO FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power
& Light Co.
AUTH.NAME AUTHOR AFFILIATION SAGER,D.A.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT. AFFILIATION Document Control Branch (Document Control Desk)
RECIPIENT ID CODE/NAME PD2-2 LA NORRIS F J INTERNAL: ACRS NRR/DE/EMEB NUDOCS-ABSTRACT OGC/HDS3 RES/DSIR/EIB EXTERNAL: EG&G BROWNFB NRC PDR COPIES LTTR ENCL 0
2 2
6 6
1 1
1 1
1 0
1 1
1 1
1 1
RECIPIENT ID CODE/NAME PD2-2 PD AEOD/DSP/ROAB NRR/EMCB 0C~j)g EG FILE Ol EG&G RANSOME,C NSIC COPIES LTTR ENCL 1
1 1
1 1
1 1
0 1
1 1
1 1
1 NOTE TO ALL"RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL 19
I 0
'~K 0
P.O. Box 1 8, Ft. Pierce, FL 34954-0128 July 30, 1993 L-93-190 10 CFR 50.4 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.
C.
20555 RE:
St. Lucie Unit 1 Docket No. 50-335 In-Service-Inspection Plan Second Ten-Year Interval Relief Re uest 13 Re air Re uirements for Class 2 Tank Pursuant to 10
~ CFR 50.55a(a)
(3) and 50.55a(g) (5) (iii), Florida Power and Light Company (FPL) requests approval of relief request 13 "Repair Requirements for a Class 2 Tank" for a temporary non-code repair to the Unit 1 refueling water tank bottom.
FPL determined that an ASME Section XI Code repair is not practical in that the affected tank has a Technical Specification required water volume.
In addition, a plant shutdown and cooldown with unnecessary cycling of facility systems and components would be required to perform a code repair of the tank bottom.
The proposed alternatives provide an acceptable level of quality and safety, and that compliance with the specified requirements would result in hardship or unusual difficultywithout a compensating increase in the level of quality an'd safety.
Attachment 1 is Relief Request 13.
Attachment 2 is a copy of the FPL Safety Evaluation (JPN-PSL-SENP-93-035, Revision 1) "Evaluation of Inventory Loss from the Refueling Water Tank."
Please contact us if there are any questions about this submittal.
Very truly yours,
~r <5'~
D. A. Sager Vice President St. Lucie Plant DAS/GRM/kw Attachments (2) cc:
Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant DAS/PSL N962-93 0 5O O ~ ~
an FPL Group company, Q308060325 930730 PDR ADOCK 05000335 P
I
St. Lucie Unit 1 Docket No. 50-335 In-Service-Inspection Plan Second Ten-Year Interval Relief Re uest 13 - Re air Re uirements for Class 2 Tank ATTACHMENT 1
SECOND INSPECTION INTERVAL ST. LUCIE UNIT 1 RELIEI= REQUEST NUMBER 13 A.
COMPONENT IDENTIFICATION:
Class:
Quality Group B Class 2
Identification of components:
Refueling Water Tank Description of components:
Above Ground Storage Tank B.
EXAMINATIONREQUIREMENTS:
Examination Category C-H C-H Exam Item Number C7.10 C7.20 Exam Method Visual VT-2 Visual VT-2 Examination Requirement Pressure Retaining Boundary each inspection period Pressure Retaining Boundary at or near the end of the inspection interval C.
RELIEF REQUESTED:
Relief is requested from the Repair and/or Replacement requirements of the ASME Boiler and Pressure Vessel
- Code,Section XI, 1983 Edition through the Summer 1983
- Addenda, Articles IWA/IWC-4000 and IWA/IWC-7000 respectively.
D. BASIS FOR RELIEF:
Florida Power and Light Company (FPL) has determined, based on the justification stated
- below, that the shutdown of the operating unit would be impractical for the sole purpose of making an ASME Code repair/replacement, and provide a undue hardship on
- FPL, without a
compensating increase in the quality 'or safety of the plant for the following reasons:
1 ~
2 ~
3.
FPL has determined that a code repair/replacement is not practical in that a plant shutdown and cooldown with unnecessary cycling of the facility systems and components would be required to perform a
code repair/replacement to the tank bottom.
In addition, the 500,000 gallons of borated water in the storage tank must be emptied into the refueling canal or temporary tankage during the repair/replacement.
Review of industry data indicates that tanks with comparable leaks do not fail catastrophically.
Leakage through the RWT bottom plate will not adversely affect the overall structural integrity of the RWT since it is not relied upon to transfer any design basis loads to the ring wall foundation.
~ 0 SECOND INSIECTION INTERVAL ST. LUCIE UNIT 1 RELIEF REQUEST NUMBER 13 4 ~
Carbon steel structures or components are not located directly beneath the RWT or adjacent to it, the potential for carbon steel corrosion due to borated water is not applicable.
E.
ALTERNATIVE EXAMINATIONS OR TESTS:
In lieu of the Code repair, FPL proposes the following:
1 ~
A remote visual (VT-3) examination utilizing a
submersible dev'ice was performed prior to the temporary repair.
2 ~
3.
4 ~
The temporary repair is an epoxy sealant coating with an aluminum backing plate.
This temporary repair has been determined to be compatible with the tank materials and system fluids.
Continued monitoring of the RWT level by Operations and Chemistry.
Any step increase in inventory loss (e.g.,
a 1
gpm increase) will be evaluated for makeup capability and continued operability of the RWT.
F.
IMPLEMENTATION SCHEDULE:
This temporary repair to the tank bottom/liner is considered by FPL to be an intermediate measure.
The RWT will be repaired in accordance with the ASME Code requirements during the Fall 1994 refueling outage.
St. Lucie Unit 1 Docket No. 50-335 In-Service-Inspection Plan Second Ten-Year Interval Relief Re uest 13 - Re air Re uirements for Class 2 Tank ATTACHMENT 2