ML061570228

Evaluation of Response to GL 2004-01

ML061570228
Person / Time
Site:	Saint Lucie
Issue date:	06/09/2006
From:	Moroney B Plant Licensing Branch III-2
To:	Stall J Florida Power & Light Co
Moroney B, NRR/DORL, 415-3974
References
GL-04-001, TAC MC4846
Download: ML061570228 (5)

Text

June 9, 2006Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

ST. LUCIE PLANT, UNIT NO. 2 - EVALUATION OF RESPONSE TO GENERICLETTER 2004-01 (TAC NO. MC4846)

Dear Mr. Stall:

On August 30, 2004, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter(GL) 2004-01, "Requirements for Steam Generator Tube Inspections." The purpose of GL 2004-01 was to obtain information that would enable the NRC staff to determine whetherlicensees' steam generator (SG) tube inspection programs comply with the existing tube inspection requirements in the plant Technical Specifications (TSs) in conjunction with Appendix B to Title 10 of the Code of Federal Regulations (10 CFR) Part 50. By letter dated October 29, 2004, Florida Power and Light Company, et al. (the licensee),submitted a response to GL 2004-01 for St. Lucie Unit 2. In the response, the licensee indicated that the SG tube inspection practices at St. Lucie 2 were in compliance with the TSs,in conjunction with Criteria IX, XI and XVI of 10 CFR Part 50, Appendix B. However, the licensee also indicated it would submit a license amendment request, consistent with the GL, to ensure that future inspections would remain in compliance. The license amendment request was subsequently submitted on November 8, 2004, and was approved by the NRC staff onApril 11, 2006. As discussed in the enclosed evaluation, the NRC staff concludes that the licensee hasadequately addressed the issues identified in GL 2004-01 for St. Lucie Unit 2.If you have any questions, please call me at (301) 415-3974.

Sincerely,/RA/Brendan T. Moroney, Project ManagerPlant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-389

Enclosure:

Evaluation cc w/encl: See next page

ML061570228NRR-106OFFICELPL2-2/PMLPL2-2/LACSGB/BCLPL2-2/BC NAMEBMoroneyBClaytonTBloomer (Acting)by memo datedMMarshall(DPickett for)DATE6/7/06 6/7/0605/05/2006 6/9/06 EnclosureEVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRESPONSE TO NRC GENERIC LETTER 2004-01FLORIDA POWER AND LIGHT COMPANY, ET AL.ST. LUCIE PLANT, UNIT NO. 2DOCKET NO. 50-389On August 30, 2004, the Nuclear Regulatory Commission (NRC) issued Generic Letter(GL) 2004-01, "Requirements for Steam Generator Tube Inspections." The purpose of GL 2004-01 was to obtain information that would enable the NRC staff to determine whetherlicensees' steam generator (SG) tube inspection programs comply with the existing tube inspection requirements in the plant Technical Specifications (TSs) in conjunction with Appendix B to Title 10 of the Code of Federal Regulations (10 CFR) Part 50. Licensees who concluded that their SG tube inspections have not been or are not beingperformed consistent with the NRC's position on the requirements in the TSs, in conjunctionwith Appendix B of 10 CFR Part 50, were requested to submit a safety assessment. As part of this safety assessment, licensees were to address whether their safety bases for limiting inspections within the tubesheet constitutes a change to the "method of evaluation" for establishing the structural and leakage integrity of the tube-to-tubesheet joint.By letter dated October 29, 2004 (Agencywide Documents Access and Management System(ADAMS) Accession Number ML043070353), Florida Power and Light Company, et al. (the licensee), submitted a response to GL 2004-01 for St. Lucie Unit 2. In the response, the licensee indicated that the tube inspection practices at St. Lucie 2 were in compliance with the TSs, in conjunction with Criteria IX, XI and XVI of 10 CFR Part 50, Appendix B.This statement was based, in part, on a conclusion that there was no potential for degradationto occur below the region within the tubesheet that was inspected with a rotating probe (i.e., theportion of the tube below the top 8 inches of the tubesheet). This conclusion was based ondegradation in the tubesheet region being limited to a few tubes with all of the indicationslocated within the top 2 inches of the tubesheet.Given these inspection findings, the NRC staff could not conclude that the licensee's pastinspection practices were consistent with the staff's position outlined in GL 2004-01, since the staff is unaware of any technical justification that would indicate tube degradation within the tubesheet would only occur near the top of the tubesheet. However, in its GL 2004-01 response, the licensee also indicated it would be submitting a license amendment request, consistent with the GL, to ensure that future inspections would remain in compliance with the TSs, in conjunction with 10 CFR Part 50, Appendix B. This decision was based on a preliminary degradation assessment that indicated there was a potential for degradation tooccur in the tubesheet region below the region historically inspected with a rotating probe. Thepotential for degradation to occur deeper in the tubesheet was based on recent inspectionresults in SGs of similar design. This license amendment request was subsequently submitted on November 8, 2004, and wasapproved by the NRC staff on April 11, 2006 (ML060790352). Based on the licenseamendment, the NRC staff concludes that the licensee's inspection practices at St. Lucie Unit 2are consistent with the NRC staff's position outlined in GL 2004-01. As a result, the NRC staffconcludes that the licensee has adequately addressed the issues identified in GL 2004-01.Principal Contributors: Paul Klein Matthew Yoder Mr. J. A. StallST. LUCIE PLANTFlorida Power and Light Company cc:Mr. William E. Webster Vice President, Nuclear Operations Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Senior Resident Inspector St. Lucie Plant U.S. Nuclear Regulatory Commission P.O. Box 6090 Jensen Beach, Florida 34957 Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 M. S. Ross, Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

Marjan Mashhadi, Senior Attorney Florida Power & Light Company 801 Pennsylvania Avenue, NW.

Suite 220 Washington, DC 20004Mr. Douglas Anderson County Administrator St. Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982

Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741Mr. Gordon L. Johnston Acting Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000Mr. Christopher R. CostanzoActing Plant General Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957Mr. Terry PattersonLicensing Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957Mark Warner, Vice PresidentNuclear Operations Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420Mr. Rajiv S. KundalkarVice President - Nuclear Engineering Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420Mr. J. KammelRadiological Emergency Planning Administrator Department of Public Safety 6000 Southeast Tower Drive Stuart, Florida 34997Mr. Bill ParksActing Operations Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000