ML17241A452

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Withdraws Relief Request 16 & Suppl Relief Request 15 with Info Requested During 990526 Telephone Conference Re ISI Insp Plan,Third 10-yr Interval
ML17241A452
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 08/31/1999
From: Stall J
FLORIDA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-99-188, NUDOCS 9909080095
Download: ML17241A452 (7)


Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9909080095 DOC.DATE: 99/08/31 NOTARIZED: NO DOCKET ¹ FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power k Light Co. 05000335 AUTH.NAME + AUTHOR AFFILIATION STALL,J.A. Florida Power &. Light Co.

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

SUBJECT:

Withdraws rel'f request990526 info requested during 16 5: suppl relief request 15 with telephone conference re ISI insp plan, third ten-year interval.

DISTRIBUTION CODE: A047D COPIES RECEIVED: LTR I ENCL I SIZE:

TITl E: OR Submittal: Inservice/Testing/Relief from ASME Code NOTES: E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LPD2-2 LA 1 1 GLEAVES,W 1 1 0 1NTERNAL: ACRS 1 1 FILE CENTER Ol 1 1 NUDOCS-ABSTRACT 1 1 OGC/RP 1 0 RES/DET/ERAB 1 1 RES/DET/MEB 1 1 EXTERNAL: LITCO ANDERSON 1 1 NOAC 1 1 NRC PDR 1 1 D

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'E NOTE TO ALL "RIDS" 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 TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL 10

Florida Power & Light Company,6351 S. Ocean Drive, Jensen Beach, FL34957 August 31, 1999 L-99-188 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 Third Ten- Year Interval Revised Relief R uests 5 and 16 The third ten-year in-service inspection (ISI) interval for St. Lucie Unit 1 began on February 11, 1998. Florida Power & Light Company (FPL) submitted the planned ISI program including the third interval relief requests (R/R) by letter L-98-14 on February 2, 1998. In a telephone conference on May 26, 1999, the NRC project manager for St. Lucie notified FPL that several of the R/Rs (¹ 4, 5, 8, 10, 11, 13, and 16) require additional information and therefore'were not being approved as submitted.

The purpose of this letter is to withdraw R/R 16 and supplement R/R 5 with the information requested by the NRC. Unit 1 R/R 5 is similar to Unit 2 R/R 23, which was approved by the NRC on July 29, 1999. Please contact us should you require any additional clarifications.

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

9909080095" 0500 PDR ADQCK 500033 PDR an FPL Group company

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St. Lucie Unit 1 Docket No. 50-335 L-99-188 Attachment Page 1 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 5 A. COMPONENT IDENTIFICATION:

Class: 1 Reactor Pressure Vessel (RPV)

Class 1 pressure retaining welds in the reactor vessel at Florida Power and Light's (FPL) St.

Lucie Unit 1.

EXAMINATIONREQUIREMENT:

Rules for In-Service-Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition Exam Item no. Examination Requirements Cat.

B-A B1.20 Essentially 100% volumetric examination of accessible length of B1.21 circumferential head welds C. RELIEF REQUESTED:

Pursuant to 10 CFR 50.55a (g)(5)(iii), FPL requests relief from the required volumetric examination of RPV head weld 209-04 as specified in Table IWB-2500-1 Category B-A of the 1989 Edition of ASME Section XI.

D. BASIS FOR RELIEF'eld 209-04 is located under the RPV head shroud, has permanent obstructions due to the control element drive mechanisms (CEDM) penetrating it, and is generally inaccessible from the outside and inside surfaces of the RPV head. The shroud is welded and bolted to the RPV head in several areas. Removal and replacement of the shroud would be time consuming, involve high radiation exposure, could create an airborne contamination hazard, and potentially cause harm to the RPV head. Alternative surface examinations can not be utilized for the same reasons.

The performance of a weld examination from the outside surface is impractical. The shroud, which is located below the weld (see attachment), would interfere with access for manual ultrasonic examinations and robotic equipment from the flange side. CEDMs that are located through and above the weld, limit access for manual examinations and robotic equipment from the other direction. Performing radiography is also impractical due to the high radiation levels and limited access. The CEDMs that penetrate the weld further limit the amount of weld that could be radiographed. Performance of an ultrasonic examination from the inside surface is also impractical due to the interference of the CEDMs and the high radiation levels.

Performing the examinations would require FPL to remove the shroud from the RPV head. This would involve a great deal of radiation exposure, cutting shroud components, disassembly of RPV instrumentation, and restoration of that same equipment. The possibility of harming the head would increase due to the work involved in removing the shroud and it's associated components.

St. Lucie Unit 1 Docket No. 50-335 L-99-188 Attachment Page 2 i St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 5 FPL has performed a system leakage test on this weld every outage. No leakage has ever been noted. Industry experience with the St. Lucie vintage of reactor has not shown any specific or generic problems with this weld.

Having FPL remove the shroud to gain access to a small percentage of the weld would be a hardship without a compensating increase in safety. Removing the shroud would also increase the possibility of damage to the RPV head.

This is a duplicate of PSL-2 Relief Request RR-23 submitted by FPL letter L-99-55, dated March 16,1999 and granted by NRC SER dated July 29,1999.

E. ALTERNATIVEEXAMINATIONS:

Periodic system pressure tests per Category B-P, Table IWB-2500-1 F. IMPLEMENTATIONSCHEDULE:

Third In-Service-Inspection Interval ATTACHMENTS TO THE RELIEF:

RPV head drawing showing general arrangement

St. Lucie Unit 1 Docket No. 50-335 1

L-99-188 Attachment Page 3 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 5 RPV Head General Arrangement Shroud Veld 209-04

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