ML17229A144

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Requests Approval to Incorporate Code Case N-533, Alternative Requirements for VT-2 Visual Exam of Class 1 Insulated Pressure-Retaining Bolted Connections,Section XI, Div 1, for Use in Unit 2 10-Yr ISI Program
ML17229A144
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 11/19/1996
From: Stall J
FLORIDA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-96-304, NUDOCS 9611270167
Download: ML17229A144 (4)


Text

CATEGORY 1 REGULA'1l INFORMATION DISTRIBUTIOYSTEM (RIDE) i.

ACCESSION NBR:9611270167 DOC.DATE: 96/11/19 NOTARIZED: NO DOCKET I FACIL:50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION STALL,J.A. Florida Power a Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Requests approval to incorporate Code Case N-533, "Alternative Requirements for VT-2 Visual Exam of Class 1 Insulated Pressure-Retaining Bolted Connections,Section XI, Div 1," for use in Unit 2 10-Yr ISI program.

DISTRIBUTION CODE: A047D TITLE: OR COPIES RECEIVED:LTR Submittal: Inservice/Testing/Relief from 4 ENCL I ASME Code SIZE:

3 GL-89-04 NOTES: E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 LA 1 1 PD2-3 PD 1 1 WIENS,L. 1 1 INTERNAL: ACRS 1 1 AEOD/SPD/RAB 1 1 "CEN 1 1 NRR/DE/EMEB 1 1 CS=XBSTRACT 1 1 OGC/HDS3 1 0 RES/DET/EIB 1 1 RES/DET/EMMEB 1 1 EXTERNAL: LITCO ANDERSON 1 1 NOAC 1 1 NRC PDR 1 1 D

0 U

E NOTE TO ALL MRIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 I

TOTAL NUMBER OF COPIES REQUIRED: LTTR 14 ENCL 13

Florida Power & Light Company, P.O. Box128, Fort Pierce, FL34854-0128 November 19, 1996 L-96-304 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 2 Docket No. 50-389 In-Service-Inspection (ISI) Plan Second Ten- Year Interval ASME Code Case N-533 - Re uest for Use Pursuant to 10 CFR 50.55a, (Footnote 6) and 10 CFR 50.55a(a)(3), Florida Power and Light Company (FPL) requests approval to incorporate Code Case N-533, Alternative Requirements for I

VT-2 Visual Examination of Class Insulated Pressure-Retaining Bolted Connections,Section XI, Division I, for use in the St. Lucie Unit 2 Ten Year In Service Inspection Program. Code Case N-533 was approved for use by ASME on March 14, 1995.

Code Case N-533 is an alternative to the requirements of IWA-5242(a) of the 1989 Edition of the ASME Code which requires insulation removal from Class 1 pressure-retaining bolted connections to perform VT-2 visual examinations. IWA-5242(a) requires insulation to be removed from pressure-retaining bolted connections for visual examination VT-2 in systems borated for the purpose of controlling reactivity. FPL requested interim relief in ISI Relief Request 19 which was submitted by letter (L-95-104) dated April 3, 1995 and granted by NRC letter dated June 21, 1995. In part, the basis for Interim Relief 19 was to provide time to reduce the burden of the required examinations through the ASME Code process. ASME Code Committee endorsement of this Code Case accomplishes part of this burden reduction for Class 1 bolted connections.

The ambient conditions during the installation of insulation after VT-2 examinations at normal operating pressure and temperature (NOP/NOT) require heat stress work restrictions.

Containment entries at NOP/NOT are physically demanding on personnel due to the adverse heat stress environment. Stay times for personnel in many areas are less than one (1) hour and would require multiple containment entries to complete the examination activities. Ambient temperatures range from 95 to 110 degrees F. Personnel should not be exposed to such an adverse work environment unnecessarily without a compensating increase in the level of quality and safety.

Performing the VT-2 visual examination using Code Case N-533 will accomplish the inspections and the insulation installation while maintaining personnel safety and inspection quality at an appropriate level.

Historical data indicate that personnel contaminations increase with increasing environmental temperatures due to the profuse sweating caused by adverse environmental conditions.

Reinstalling contaminated insulating materials under these adverse conditions (i.e., to piping that 9hiii9

'ir6ii270ih7 PDR ADQCK 8 'DR 05000389 an FPL Group company

St. Lucie Unit 2 Docket No. 50-389 L-96-304 Page 2 is at 2250 psia and greater than 500 degrees F) would negatively impact total personnel contaminations and expose personnel to unnecessary safety risk. Additionally, increased dose would be accumulated due to reduced examination efficiency as a result of the necessity to wear special protective equipment (e,g., ice vest).

Furthermore, the removal of scaffolding used for this examination from containment would be through the reactor containment building personnel hatch rather than the equipment hatch since the plant is in Mode 4 with the equipment hatch secured. This will place added physical and heat stress limitations on the personnel involved.

A system pressure test with insulation installed on bolted joints at NOP/NOT with a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> hold time will be completed prior to returning the unit to service. This test and examination philosophy is consistent with the Inservice Inspection (ISI) Plan which was in place during the first ISI interval. These examinations, in conjunction with routine monitoring of reactor coolant system (RCS) leakage, will provide adequate assurance of RCS integrity. The personnel hazard imposed by the examination of hot, uninsulated components and subsequent insulation re-installation is not commensurate with the marginal contribution to safety. A copy of the Code Case is attached for your information.

Code Case approval is requested to support its use in the upcoming St. Lucie Unit 2 refueling outage (SL2-10) scheduled to begin April 15, 1997. Please contact us if there are any questions about this submittal.

Very truly yours, J. A. Stall Vice President St. Lucie Plant JAS/GRM Attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant

Meet oee t asefvfs sa. tsea 5w Numetfast Msw fItNerphytfee NxfHlyJeealehgfgr) gycyg.,

~ lMQ hlterssative Rcqtdnacats ht VF-3 Visual Eaaaissettea of aaee I Isswslated ~eere-J4csLtelng 50804 C0Es~e Secre Xt, Dbhloe i leyden: %hat alsensative ceqdtcsncnI may be used in ILcu of those of WA-N42(a) to retnove insulation petfam a VT.2 visual exataineioo2 an

~ lt is che opinion of the Conm'ittee char, as alternate to the requirements of ISA-$242(a) bolted connections co perform a VT-2 visual omni.

nathn, the following retpuremcnts shall bo met.

(o) h system prescore tesc and VT-2 visual eaam-hatba shaH be perfortned each reeling outage without retnoval of insula5on-(b) Each roSeling outage cbo insulation shaH bo removed from tho bolted cottnecrion, and a VT-2 vis-ual examinadoa shaQ be performed. The connection ooc xopllrcd to bo prccsurised Any evidence of lealsage shall be evaluated in accordance with PEA.

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