ML17241A346

Forwards Revised Relief Request 22 to Clarify Several Areas of Relief.Nrc Action Is Requested to Be Complete by Aug 1999 to Support Planning for Spring 2000 Unit 2 Refueling Outage

ML17241A346
Person / Time
Site:	Saint Lucie
Issue date:	05/24/1999
From:	Stall J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-99-118, NUDOCS 9906020148
Download: ML17241A346 (6)

Text

REGULAT i INFORMATION DISTRIBUTION YSTEM (RIDS)

ACQ~SSION NBR:9906020148 DOC.DATE: 99/05/24 NOTARIZED: NO DOCKET ¹

'rACXL 50-389 St. Lucie Plant, Unit 2, Florida Power 6 Light Co. 05000389 AbZH.NAME AUTHOR AFFILIATION STALL,J.A. Florida Power 8 Light Co.

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

SUBJECT:

Forwards revised Relief Request 22 to clarify several areas of relief.NRC action is requested to be complete by Aug 1999 C to support planning for Spring 2000 Unit 2 refueling outage.

DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR ENCL SIZE TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code - GL-89-04 NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LPD2-2 LA 1 1 LPD2-2 PD 1 1 0 GLEAVES,W 1 1 INTERNAL: ACRS NRR/DE/EMEB <<NUDOCS-ABSTRACT OGC/RP 0 RES/DET/EIB RES/DET/EMMEB 1 EXTERNAL: LITCO ANDERSON 1 1 NOAC NRC PDR 1 1 D

'E NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION CONTACT LISTS THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL 12

I Florida Power & Light Company, 6351 S. Ocean Drive, Jensen Beach, FL 34957 May 24, 1999 L-99-118 II=PL 10 CFR 50.4 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 St. Lucie Unit 2 Docket No. 50-389 In-Service-Inspection Plan Second Ten- Year Interval Revised Relief R uest 22 Based on discussions between Florida Power & Light Company (FPL) and the NRC staff on April 19, 1999, FPL was requested to revise Relief Request 22 to clarify several areas of the relief.

Attachment 1 is the revised relief request.

Pursuant to 10 CFR 50.55a, (Footnote 6) and 10 CFR 50.55a (a)(3), FPL submitted Relief Request 22 by FPL letter L-99-40 on February 18, 1999. Relief Request 22 incorporates Code .,

Case N-622, Ultrasonic Examination ofRPV and Piping and Bolts and Studs, Section XT, Division 1, in lieu of the requirements of Appendix I, Article I 2000. The Code Case will be used for the performance of the required volumetric examinations of Class 1 comporient welds as specified in Table IWB-2500-1 Category B-A and B-D of the 1989 Edition of ASME'Section XI. FPL has determined, pursuant to 10 CFR 50.55a (a)(3) that the proposed alternatives would provide an acceptable level of quality and safety, and that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. ASME approved Code Case N-622 for use on December 11, 1998. A copy of ASME Code Case N-622 was included with our original submittal.

NRC action is requested to be complete by August 1999 to support planning for the Spring 2000 Unit 2 refueling outage (SL2-12). Please contact us if there are any questions about this submittal.

Very truly yours, J. A. Stall Vice President St. Lucie Plant JASIGRM Attachment cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant 990S020X4S Ve0524 PDR ADQCK 05000389 8 PDR anFPLGroup company t-j.-

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St. Lucie Unit 2 Docket No. 50-389 L-99-118 Attachment Page 1 St. Lucie Unit 2 SECOND INSPECTION INTERVAL RELIEF RE UEST NUMI)ER 22 A. COMPONENT IDENTIFICATIO¹ Class: 1 Reactor Pressure Vessel Pressure-retaining welds in vessels examined at St. Lucie Unit 2.

B. EXAMINATIONREQUIREMENT:

Rules for In-Service Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition

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,Exam 'tem,,no'.,.;,':

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'::::,'Examination'Requir'e'ments':

.':::Cat a B-A B1.10 Essentially 100% volumetric examination of longitudinal and B1.11 circumferential shell welds (does not include shell to flange weld)

B1.12 In accordance with A ndix I, Article I-2000.

B-A B1.20 Essentially 100% volumetric examination of accessible length of B1.21 circumferential and meridional head welds in accordance with Appendix B1.22 I, Article I-2000.

B-A B1.30 Essentially 100% volumetric examination of the shell to flange weld in accordance with A ndix I, Article I-2000.

B-A B1.40 Essentially 100% volumetric and surface examination of head to flange weld in accordance with A ndix I, Article I-2000.

B-D .

B3.90 Essentially 100% volumetric examination of nozzle-to-vessel welds in accordance with Appendix I, Article I-2000.

B3.100 Nozzle inner radius areas.

ASME Code Case N460: Alternative Examination Coverage for Class 1 and Class 2 Welds C. RELIEF REQUESTED:

Pursuant to 10 CFR 50.55a (a)(3)(i), FPL requests to use the alternative requirements of Code Case N-622, Chapters A.2, A.3, B-1000 through B-5000 inclusive and Supplements 1, 4, 5A, 6, 7 and 13, in lieu of the requirements of Appendix I, Article I 2000 for the performance of the required volumetric examinations of Class 1 component welds as specified in Table IWB-2500-1 Category B-A and B-D of the 1989 Edition of ASME Section XI. These examinations willbe performed during the second inspection interval.

D. BASIS FOR RELIEF:

FPL is currently required to perform in-service examinations of selected welds in accordance with the requirements of 10 CFR 50.55a, plant Technical Specifications, and the 1989 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components. This Code edition invokes the examination requirements of Appendix I, Article I-2000 that essentially prescribes 20 year old

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St. Lucie Unit 2 Docket No. 50-389 L-99-118 Attachment Page 2 St. Lucie Unit 2 SECOND INSPECTION INTERVAL RELIEF RE UEST NUMI)ER 22 examination methodology. This examination methodology is typically "qualified" by calibration on side drilled holes in a calibration block fabricated from similar material.

Later Code editions and Code Case N-622 describe a performance demonstration based examination methodology that has been proven to be superior to the current requirements. These demonstrations have been conducted using full sized vessel specimens that contain fatigue cracks replicating the actual conditions that could be encountered.

We believe the use of Code Case N-622, which delineates this newer demonstrated examination methodology, will provide added assurance that the reactor vessel welds have remained free of service related fiaws thus enhancing quality and ensuring plant safety and reliability. This will be particularly evident in the important under-clad region where the performance demonstrations have resulted in examination technique enhancements that transcend Code requirements.

Furthermore, examinations performed using these newer techniques will allow us to achieve greater coverage of the Code required volume, thereby eliminating or substantially reducing areas of reduced coverage described in the previously approved Relief Request No. 1. The implementation of the methodology of Code Case N-622 is also expected to reduce on-vessel examination time by as much as 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, which translates to significant cost savings and reduced personnel radiation exposure.

E. ALTERNATIVEEXAMINATIONS:

1) Perform examinations in accordance with Code Case N-622.

2) Conduct mechanized ultrasonic examinations to the maximum extent to achieve essentially 100% of the Code required volume of all welds using Performance Demonstration Initiative (PDI) qualified procedures and personnel.

3) Perform periodic system pressure tests per Category B-P, Table IWB-2500-1.

F. IMPLEMENTATIONSCHEDULE:

Second In-Service Inspection Interval G. ATTACHMENTSTO THE RELIEF:

Code Case N-622 H. ADDITIONALINFORMATION:

Code Case N-622 contains a typographical error in the first line of B-3130 (a). The reference is given as [B-2100(d)]; the correct reference should be totB-2100(e)].

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