ML17229A266
| ML17229A266 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/13/1997 |
| From: | Stall J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-97-65, NUDOCS 9703190387 | |
| Download: ML17229A266 (9) | |
Text
CATEGORY 1 REGULAT Y INFORI'IATION DISTR IBUTIO SYSTEI l (RIDS )
ACCESSION NBR: 9703190387 DOC. DATE: 97/03/13 NOTARIZED:
NO FACIL: 50-389 St.
Lucie Planti Unit 2I Florida Pou!er 8c Light'Co.
AUTH. NANE AUTHOR AFFILIATION STA(LI J. A.
Florida Poeer h Light Co.
RECIP. NA!T!E RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET kf 05000389
SUBJECT:
Submits info in response to RAI re ISI Plan Second Ten-Yr Interval Relief Request
- 14. providing addi Justification on rescheduling of exams in r elief request.
DISTRIBUTION CODE:
A047D COPIES RECEIVED: LTR ENCL
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SIZE: 4 TITLE:
OR Submittal:
Inservice/Testing/Relief from ASNE Code GL-89-04 E
RECIPIENT ID CODE/NANE PD2-3 L*
MIENSI L.
RES/DET/EIB 1
ACT INTERNAL:
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EXTERNAL: LITCO ANDERSON NRC PDR 1
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!
CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT. 415-2083)
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
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LTTR 14 ENCL 13
Florida Power 5 Light Company.
6501 South Ocean Drive, Jensen Beach, FL34957 PlPE March 13, 1997 L-97-65 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 Inservice-Inspection Plan Second Ten-Year Interval Relief Re uest 14 Su lement By letter dated May 4, 1995, NRC transmitted the safety evaluation approving the Second-Ten-Year Interval Inservice Inspection (ISI) Plan for St. Lucie Unit 2.
Relief request 14 was identified as an open item in that evaluation and was to be resolved by separate correspondence.
Subsequent conference calls with the NRC Project Manager and tlie NRC contractor, INEL, identified the need for FPL to provide additional justification on the rescheduling of examinations in the relief request.
The additional schedule justification was submitted by FPL Letter, L 310A, dated November 20, 1995.
In February 1996, the NRC Project Manager for St. Lucie provided FPL with a telecopy request for additional information based on the review of FPL Letter, L-95-310A.
The requested information is attached.
Please contact us ifthere are any questions about this submittal.
Very truly yours, J. A. Stall Vice President St. Lucie Plant JAS/GRM Attachment cc:
Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant 9703290387 970323, PDR ADOCK 0500038 6
PDR an FPL Group company iiiniiiiIiiiiIuIiiiliiIiiiiiratiiIr~iitii I
St. Lucie Unit 2 Docket No. 50-389 L-97-65 Attachment Page 1
NRC Request 1:
Deferring the reactor pressure vessel (RPV) examinations from the first or second period to the third period was included in Request for Relief 14. How willallowing greater than 10 years between examinations provide an acceptable level of quality and safety?
Provide technical justification on the acceptability of deferral of RPV examinations.
FPL Response 1:
FPL will perform the required RPV examinations during the scheduled March 1999 refueling outage.
This schedule willhave FPL performing the examinations 10 years after the March 1989 outage.
FPL has reviewed the originally submitted schedule to determine the effect of moving the RPV examinations forward one period. By doing this, Program B requirements would be exceeded by having too many examinations scheduled during the second period.
The review showed the pressurizer welds were examined during the first period.
The pressurizer examinations met the maximum requirements of Program B and Code Category B-D for the first period.
Steam Generators A and B (with 12 B-D areas) were scheduled for the second period and the RPV examinations (with 12 B-D areas) for the third period to meet the Program B requirements.
By moving the RPV examinations forward one period, 100% of the Category B-D examinations would be completed by the end of the second period, with no examinations scheduled for the third period. In order to correct this, the steam generator examinations would have to be moved to the third period.
However, steam generator B was already delayed one period.
By delaying it a second period, it would mean 14 to 17 years between examinations.
FPL felt these examinations should not be delayed any further. For steam generator A, FPL can delay one period and still be approximately 10 years between examinations.
This would still result in the second period having more examinations scheduled than allowed by Program B, but is a reasonable alternative that willnot affect the safety and quality of the plant, FPL plans to use the following schedule:
St. Lucie Unit 2 Docket No. 50-389 L-97-65 Attachment Page 2 Component Category B-D Examination Schedule Period Schedule No. of Areas Reactor Pressure Vessel Steam Generator Pressurizer Totals 12 12 12 36 12 12 = 33%
12
+18 = 83%
+6 = 100%
NRC Request 2:
A paragraph has been added to this relief entitled Substitutions, however, the explanation is brief and incomplete.
Provide a thorough explanation of how St. Lucie plans to do substitutions.
Include the process which is used to determine which examinations are to be replaced and which examinations willreplace them.
FPL Response 2:
FPL willschedule substitute welds for examination in accordance with Section XI selection and scheduling requirements.
When substitute welds are selected, they willbe similar in configuration to those originally scheduled, ifpossible.
Terminal end welds and high stress welds willbe selected, ifavailable.
The substituted welds willbe on the same or similar lines as close as possible to the originally scheduled welds.
Substitute welds will be selected only when a significant reduction in overall exposure or costs can be achieved, or the originally scheduled weld is no longer accessible or has been removed from service.
Program B requirements willbe followed.
NRC Request 3:
Examination Category C-A has six new items added during this interval. What are these new items? Why were they not examined in the prior interval? It appears that these new items are to be scheduled in the third period; when were they last examined?
Provide justification for why it is technically prudent to wait until the third period to examine these new items.
St. Lucie Unit 2 Docket No. 50-389 L-97-65 Attachment Page 3 FPL Response 3:
The six new items are reinforcement plate welds around the nozzles of the Shutdown Cooling Heat Exchanger.
These pressure retaining nozzle welds are inaccessible from the outside surface.
This note should have been listed under category C-B.
Reinforcement plates were not addressed in the previous Code edition (1980 Edition with Addenda through Winter 1980.) The 1989 Edition added Item Numbers for the associated welds, so there are now six additional listings. FPL did perform surface examinations on two reinforcement plate to pipe welds as a best effort in accordance with the methods of the previous Code Edition. These examinations exceeded the requirements of the previous Code and were performed during the third period of the first interval. By examining them during the third period of the second interval, approximately ten years willelapse between subsequent examinations.
The following three questions refer to Attachment 2 of FPL Letter, L-95-310A.
NRC Request 4:
Response number 3 states that "The RPV studs, nuts and washers were replaced in 1994, so the next scheduled examination is 2004, Third Inspection Interval." The RPV nuts and washers require a sample each period and cannot be examined for credit all at the same time. Only the RPV stud examinations, performed when removed, may be deferred until the end of the interval. Provide the examination schedule for RPV studs, nuts and washers for the second interval ~
FPL Response 4:
The St. Lucie plant currently owns three sets of RPV studs, nuts, and washers.
During each refueling outage, the RPV bolting is removed and replaced with the set in storage.
Since this practice began (1993), FPL has examined every RPV stud, nut, and washer in its inventory according to the requirements of Code Category B-G-1, item numbers B6.30, B6.40, and B6.50 with one exception.
Stud number 44 in St. Lucie Unit 2 has not been removed or examined this interval. Ifstud number 44 cannot be removed during a future outage, it willbe examined in place according to item number B6.20.
Since FPL now moves RPV bolting from one unit to the other, examining the bolting on an expedited schedule was necessary for the first period.
This was done to assure that every bolt was examined during the interval. Having performed these examinations once
St. Lucie Unit 2 Docket No. 50-389 L-97-65 Attachment Page 4 for the interval, FPL felt that examining them a second time during the interval was unnecessary.
FPL willexamine approximately 1/3 of the RPV nuts and washers during each period.
The remaining RPV stud examinations willbe deferred to the end of the interval.
Since it is not possible to plan for every event, unforseen changes in plant scheduling may require FPL to move the stud examinations forward to an earlier outage in the interval.
Ifthis happens, FPL willfollow all Code Category B-G-1 and Program B requirements.
NRC Request 5:
Table 14-11 list Examination Category B-G-1 as in accordance with ASME Section XI.
However, when questioned about the RCP Bolting in Attachment 2, FPL responded that "The intent of FPL is=that the pump selected will be based on pump disassembly for maintenance under B-L-2 or end of inspection interval, whichever comes first... "
Although pumps can be deferred until the end of the interval in accordance with Table IWB-2500-1 Examination Category B-L-2, deferral of the associated bolting is not permissible according to Examination Category B-G-1. Provide the examination schedule for pump bolting for the second interval.
FPL Response 5:
FPL willperform examinations on Category B-G-1 Reactor Coolant pump studs on one pump during the interval. A total of 16 studs willbe examined. Ifthe required number of studs cannot be examined on one pump due to limitations or restrictions, studs on other pumps willbe examined until a total of 16 studs have been completed.
Pump 2A1 - no examination scheduled Pump 2A2 - no examination scheduled Pump 2B1 - 2nd period Pump 2B2 - no examination scheduled NRC Request 6:
When questioned about examination schedules for valve bolting examinations, FPL's response stated that "The intent of FPL is that valves selected shall be based on valve disassembly for maintenance under B-M-2 or end of inspection interval, whichever comes first." Although valves can be deferred until the end of the interval in accordance with Table IWB-2500-1 Examination Category B-M-2, deferral of the associated bolting is not permissible according to Examination Category B-G-2. Provide the examination schedule for valve bolting for the second interval.
St. Lucie Unit 2 Docket No. 50-389 L-97-65 Attachment Page 5 FPL Response 6:
FPL willperform examinations on the B-G-2 bolting of one valve within each group of valves greater than 4 inch nominal pipe size that are of the same size, constructional design (such as globe, gate, or check valves) and manufacturing method, and that perform similar functions in the system.
These examinations willconsist of a VT-3 examination, as described below, of the bolting either in place under tension, or when the connection is disassembled.
If the bolting is removed or replaced, a VT-1 examination will be performed on the existing or new bolting. B-G-2 bolting willbe examined in accordance with Program B requirements.
Proposed B-G-2 Examination Schedule Period Schedule No, of Areas 44 15 14 15 VT-1 examinations require very clean surfaces.
Cleaning the insulation residue, rust, and other foreign material from valve bolting is a time consuming process that involves significant radiation exposure and costs, and is a hardship without a compensating increase in safety. AVT-3 examination on all category B-G-2 bolting would provide a reasonable safety margin instead of the VT-1. The types of flaws found during VT examinations are typically found during the system leakage test performed during plant startup, and are of the type found during VT-3 examinations (loose parts, abnormal corrosion products, wear, etc.)
The personnel who perform these examinations are qualified VT-3 examiners.
In addition, a VT-2 examination is performed on each bolted connection on systems borated for purposes ofcontrolling reactivity. If leakage is detected, FPL is required to remove the bolt closest to the source of leakage and perform a VT-1 examination in accordance with Relief Request ¹ 18.
System engineers perform walkdowns of the entire class one system whenever the plant comes down for refueling.
The scheduled VT-2 examinations and system engineer walkdowns performed during each refueling outage along with VT-3 examinations on all Category B-G-2 bolting performed during the interval will find problems ifthey exist and provide a reasonable level of quality and safety.