ML17263A120
| ML17263A120 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/27/2017 |
| From: | Shoop U S Plant Licensing Branch II |
| To: | Nazar M NextEra Energy |
| Buckberg P H, NRR/DORL/LPL2-2, 415-1447 | |
| References | |
| CAC MF9827, EPID L-2017-LLR-0044 | |
| Download: ML17263A120 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division Florida Power & Light Company Mail Stop: EX/JB 700 Universe Blvd. Juno Beach, FL 33408 October 27, 2017
SUBJECT:
ST. LUCIE PLANT, UNIT NO. 1 -INSERVICE INSPECTION PLAN FOURTH 10-YEAR INTERVAL RELIEF REQUEST NO. 16 (CAC NO. MF9827; EPID L-2017-LLR-0044)
Dear Mr. Nazar:
By letter dated June 12, 2017 (Agencywide Documents Access and Management System Accession No. ML 17163A365), Florida Power & Light Company (FPL) requested relief from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 2001 Edition through 2003 Addenda, regarding the examination of select Class 1 piping and valves at the St. Lucie Plant, Unit No. 1. Specifically, pursuant to Title 10 of the Code of Federal Regulations Section 50.55a(z)(2), FPL requested to use the proposed alternative in Relief Request No. 16 on the basis that hardship and unusual difficulty exists in establishing a system configuration that will subject all Class 1 components to reactor coolant system pressure during the system pressure test, without a compensating increase in the level of quality and safety. The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that FPL has addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2) and that the proposed alternative to the ASME Code requirement of subjecting all Class 1 components to reactor coolant system pressure during the system pressure test provides reasonable assurance of structural integrity.
Therefore, pursuant to 1 O CFR 50.55a(z)(2), the NRC authorizes the use of Relief Request No. 16 at the St. Lucie Plant, Unit No. 1, for the fourth 10-year inservice inspection interval, which ends on February 10, 2018. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear lnservice Inspector.
M. Nazar If you have any questions, please contact the Project Manager, Perry H. Buckberg, at 301-415-1383 or Perry.Buckberg@nrc.gov.
Docket No. 50-335
Enclosure:
Safety Evaluation cc w/enclosure:
Distribution via Listserv Sincerely, Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. 16 EXAMINATION OF CLASS I PIPING AND VALVES AT ALTERNATIVE PLANT CONDITIONS
1.0 INTRODUCTION
ST. LUCIE PLANT, UNIT NO. 1 FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-335 By letter dated June 12, 2017 (Reference 1), Florida Power & Light Company (FPL, the licensee) submitted Relief Request No. 16 to request relief from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (B&PV Code),Section XI, 2001 Edition through 2003 Addenda, regarding the examination of select Class 1 piping and valves at the St. Lucie Plant, Unit No. 1. Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 O CFR) 50.55a(z)(2), FPL requested the U.S. Nuclear Regulatory Commission (NRG) to review and approve the use of a proposed alternative on the basis that hardship and unusual difficulty exists in establishing a system configuration that will subject all Class 1 components to reactor coolant system (RCS) pressure during the system pressure test, without a compensating increase in the level of quality and safety.
2.0 REGULATORY EVALUATION
Adherence to Section XI of the ASME Code is mandated by 1 O CFR 50.55a(g)(4), which states, in part, that ASME Code Class 1, 2, and 3 components will meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in Section XI of the ASME Code. Section 50.55a(z) of 1 O CFR states that alternatives to the requirements of paragraphs (b) through (h) of 10 CFR 50.55a, or portions thereof, may be used when authorized by the Director, Office of Nuclear Reactor Regulation.
A proposed alternative must be submitted and authorized prior to implementation.
The licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety, or (2) compliance with the specific requirements would result in hardship or unusual difficulty, without a compensating increase in the level of quality and safety. Based on the above, and subject to the following technical evaluation, the NRG staff finds that regulatory authority exists for FPL to request the use of an alternative and the NRG to authorize the proposed alternative.
Enclosure 3.0 TECHNICAL EVALUATION 3.1 ASME Code Components Affected Code Class:
Reference:
Exam Category:
Item Number:
Description:
1 IWB-5220, Table IWB-2500-1 B-P B15.10 Pressure Retaining Components
3.2 Applicable
Code Edition and Addenda The code of record for the St. Lucie Plant, Unit No. 1, is the 2001 Edition through 2003 Addenda of the ASME B&PV Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," as modified by 1 O CFR 50.55a. 3.3 Applicable Code Requirement ASME Code,Section XI, Table IWB-2500-1, "Examination Categories," Examination Category B-P, Item B15.10, requires that a system leakage test be conducted prior to startup following each refueling outage in accordance with the requirements of IWB-5220.
ASME Code,Section XI, paragraph IWB-5222(a), requires that the pressure retaining boundary during the system leakage test shall correspond to the reactor coolant boundary with all valves in the position required for normal reactor operation startup, with the visual examination extended to include the second closed valve at the boundary extremity.
ASME Code,Section XI, paragraph IWB-5222(b), requires that the pressure retaining boundary during the system leakage test conducted at or near the end of each inspection interval shall extend to all Class 1 pressure retaining components within the system boundary.
ASME Code Case N-798, "Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Vent, Drain, and Test Isolation Devices," states that for portions of Class 1 vent, drain, and test piping between the first and second isolation devices that normally remain closed during plant operation, only the boundaries of IWB-5222(a) shall apply. ASME Code Case N-800, "Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Injection Valves," states that for portions of the Class 1 boundary between the first and second isolation valves in the injection and return path of standby safety systems, the system leakage test may be conducted by pressurization of the Class 1 volume using the Class 2 safety system to pressurize the volume. It further states that such alternative tests shall be performed each inspection interval, and the system leakage test shall be conducted using the pressure associated with the Class 2 system function that provides the highest pressure between the Class 1 isolation valves. 3.4 Reason for Request Pursuant to the provisions of 10 CFR 50.55a(z)(2), FPL requests approval to perform the examination of select Class 1 piping and valves at plant conditions other than those required by the ASME Code. Relief is requested in accordance with 1 O CFR 50.55a(z)(2) on the basis that hardship and unusual difficulty exists in establishing a system configuration that will subject all Class 1 components to RCS pressure during the system pressure test, without a compensating increase in the level of quality and safety. Extending the pressure retaining boundary during system pressure test to all Class 1 pressure retaining components within the system boundary will require a number of temporary system alterations, temporary piping installations, and control logic alterations.
FPL requests approval to perform the examination of selected Class 1 piping and valves at plant conditions other than those required by paragraph IWB-5222(b) by using the alternative boundaries permitted by Code Cases N-798 and N-800 at the end of the interval.
Code Cases N-798 and N-800 have been approved for use by the ASME Code but not incorporated by reference by the NRC; therefore, the licensee is requesting NRC approval to apply these code cases. The Class 1 vents and drains in the RCS are equipped with inboard isolation valves and outboard blind flanges that provide double isolation of the reactor coolant pressure boundary (RCPB). The valves are maintained in the closed position during normal plant operation, and the downstream pipe and blind flange are not normally pressurized.
To perform the ASME Code-required pressure test, it would be necessary to manually open the inboard valves to pressurize the piping and connections.
Pressurization by this method defeats the double isolation and reduces the margin of personnel safety for those performing the test. Furthermore, performing the test with the inboard isolation valves open requires several man-hours to position the valves for the test and restore the valves to their closed positions once the test is completed.
These valves are located in close proximity to the RCS loop piping and thus would require personnel entry into high radiation areas within the containment and a consequent increase in radiation exposure.
Since this test would be performed near the end of an outage when all RCS work has been completed, the time required to open and close these valves would impact the outage schedule.
In addition, the segments pressurized for the test would have to be depressurized at the next refueling outage when the RCS is depressurized in order to relieve the test pressure in the section, adding another action to performing the test. Thus, compliance with this specific ASME Code requirement results in unnecessary hardship pursuant to 10 CFR 50.55a(z)(2), without a compensating increase in the level of quality and safety. Design of some St. Lucie Plant, Unit No. 1, Class 1 process piping requires substantial effort to extend the boundary subject to RCS pressure where check valves or non-redundant components serve as the first system isolation from the RCS. Such configurations may require temporary piping installations such as hard-pipe jumpers and/or other unusual temporary system configurations in order to achieve test pressures at upstream piping and valves. Since the Class 1 system pressure testing is performed in Mode 3, these temporary configurations could conflict with technical specification requirements.
Establishing and restoring such temporary configurations could also result in an unwarranted increase in worker radiation exposure.
Based on the above, extension of the boundary subjected to RCS pressure during system leakage tests to include all Class 1 pressure retaining components within the system boundary represents a hardship and unusual difficulty that does not provide a compensating increase in the level of quality and safety provided by the examination.
The following is specific information pertaining to the various pipe segments identified in Tables 1 and 2 of the licensee's submittal for which relief has been requested.
Table 1 contains piping for the RCS vent and drain, which references ASME Code Case N-798. Table 2 contains the hot leg shutdown cooling suction and hot leg injection for trains A and B, which reference ASME Code Case N-800. Small Bore Class 1 RCS Vent and Drain Lines Relief is requested from pressurizing piping between the first and second isolation device on small size vent and drain lines. There are 10 Class 1 vent or drain lines in the RCS identified in Table 1 of the licensee's submittal ranging in diameter from 3/4 of an inch to 2 inches. Eight of these consist of an inboard isolation valve and a blind flange in series. Two 3/4-inch segments consist of two valves in series. The piping segments provide the design-required double isolation barrier for the RCPB. The ASME Code-required leakage test would be performed in Mode 3 at the normal operating pressure of 2,250 pounds per square inch absolute (psia) and at a nominal temperature of 532 degrees Fahrenheit
(°F). Leakage testing of these piping segments at nominal operating pressure in Mode 3 would require the opening of the inboard isolation valve at the normal operating RCS temperature and pressure conditions.
In so doing, the design requirement for two primary RCPB isolation devices would be violated.
Additionally, opening these valves introduces the potential risk for spills and personnel contamination, and there is no way to depressurize the eight blind flanges at the completion of the examination.
Small Bore Class 1 Safety Injection/Shutdown Cooling Fill, Vent, and Drain Lines There are 28 vent and drain lines in the Class 1 portion of the safety injection system, diameter 3/4 of an inch or 1 inch. In addition, there are four 1-inch diameter safety injection tank (SIT) fill lines, four 3/4 of an inch diameter pressure transmitter root lines, and four 2-inch diameter high pressure safety injection (HPSI) header lines within the Class 1 portion of the safety injection system directly connected to the RCS, isolated by the 12-inch loop check valves. These lines are all statically pressurized during normal operation and are monitored for leakage by SIT pressure and level indications.
These lines are visually examined both during the RCS system leakage test as Class 1 boundary lines and during the HPSI system functional pressure test conducted at HPSI pump discharge pressure in accordance with the requirement of paragraph IWA-5212(e) to examine systems at their highest operating pressure.
These components are identified in Table 2 of the licensee's submittal.
Larger Bore Class 1 Safety Injection and Shutdown Cooling Piping Segments Hot Leg Shutdown Cooling Suction There are two 10-inch diameter hot leg shutdown cooling suction lines, one from each hot leg, identified in Table 2 of the licensee's submittal.
These piping segments consist of short segments of piping between the two shutdown cooling suction valves on each train of the system. These valves are interlocked at a required setpoint below 350 pounds per square inch gauage (psig) and administratively controlled to be closed at a pressure not to exceed 275 psia to avoid over-pressurization of the shutdown cooling system. The interlock prevents manual opening of the valves from the control room with RCS pressure above the setpoint.
The piping segment is VT-2 inspected through the entire length as part of the Class 1 system inspection at the conclusion of each refueling outage, as well as when the shutdown cooling system is placed in service, in accordance with IWA-5212(e).
The proposed system pressure test will not specifically pressurize past the first isolation valve for this inspection.
It is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. No external or visible leakage will be allowed for the test to be acceptable.
This test will provide assurance that the combined first and second isolation valves are effective in maintaining the RCPB at normal operating temperature and pressure.
HPSl/Low Pressure Safety Injection (LPSI) Loop Header and SIT Discharge Piping These large bore piping segments identified in Table 2 of the licensee's submittal provide the flow path for SIT discharge into the RCS, high pressure and low pressure safety injection, and shutdown cooling return to the RCS. The primary isolation devices are the 12-inch loop check valves oriented to flow into the RCS. The piping segments provide the design-required double isolation barrier for the RCPB. These lines are all statically pressurized during normal operation and are monitored for leakage by SIT pressure and level indications.
These lines are visually examined both during the RCS system leakage test as Class 1 boundary lines and during the HPSI system functional pressure test conducted at HPSI pump discharge pressure, in accordance with the requirement of paragraph IWA-5212(e), to examine systems at their highest operating pressure.
Leakage testing at RCS pressure would require a pressure source to be connected at each segment location by way of temporary piping connections and/or unusual temporary system configurations, which would challenge both the header check valves in the auxiliary building and the loop check closure at the RCS connection.
In so doing, the design requirement for two primary RCPB isolation devices would be violated. For test locations located overhead and away from normal personnel access areas, ladders or scaffolding would have to be installed to provide access to the piping segment and to open the valve. This process would lead to the occupational dose associated with leakage testing of these lines. These lines are located in areas involving occupational radiation exposure, and leakage testing of these lines would increase occupational radiation dose. Restoration of temporary configurations to normal operating conditions would be hazardous to personnel, lead to excess occupational dose, and unnecessarily extend the outage, without a commensurate increase in the quality and safety of the system. Dose estimates were performed with input from the site health physics 'as low as reasonably achievable' coordinator.
The estimates were prepared by identifying tasks, personnel resources, and times based on existing site processes and then utilizing survey maps to quantify the estimated dose. The subject under 2-inch nominal piping is located in high radiation areas of the plant. Performing these tests involves cycling open normally closed valves and then restoring to normal configuration.
Pressure trapped between the primary isolation valve and blind flange during each test must be discharged upon completion of tests. Maintenance support would be necessary to remove the blind flange and reinstall with new gaskets at each location.
Dose estimates for opening (normally closed) small bore valves located on under 2-inch nominal piping and performing additional tests and then restoring the system following the tests is approximately 3.985 person-roentgen equivalent man (rem). Dose estimates for performing additional testing for Class 1 safety injection piping is approximately 0.846 person-rem.
These tests involve connecting an external pump at four locations and pressurizing these segments to 2250 psia. Such pressurization may over-pressure the adjoining system. This activity represents a significant personnel safety hazard. This piping can be tested concurrently with ASME Code,Section XI pressure tests of Class 2 and 3 piping performed at the highest pressure the system is exposed to during normal operating conditions. Piping equal to and greater than a 2-inch diameter is applicable to the risk-informed program implemented at the St Lucie Plant. There have been no failures identified on the stated piping under the risk-informed program. The bolted connections of Class 1 piping associated with this relief are walked down each refueling outage to find any evidence of leakage. A review was performed for site and external operating experience (OE) pertaining to the subject piping using the site's inservice inspection (ISi) repair and replacement records and the fleet condition reporting system. Plant-Specific OE The St. Lucie Plant, Units No. 1 and 2, have not experienced any issues with stress corrosion cracking or fatigue in socket or butt welds in piping associated with Tables 1 and 2 of the licensee's submittal.
Facilities contacted for the OE for Tables 1 and 2 indicated they had not experienced any significant issues from similar piping configurations.
Table 1 piping configurations are relatively short segments of piping. The highest stress levels associated with Table 1 piping configurations are located on the upstream side of the valves on the pressurized portion of the piping system. The failure of welded connections located on the downstream (non-pressurized) side of these valves is highly unlikely.
The Table 1 piping would be leak-tested as stated in ASME Code Case N-798. The Table 2 piping would be leak-tested as stated in Code Case N-800. 3.5 Proposed Alternative FPL will conduct the required end of interval system pressure tests as prescribed by Table IWB-2500-1, Examination Category 8-P, boundary exceptions, as noted in Tables 1 and 2 of the licensee's submittal.
Those portions of the systems that are statically pressurized during normal operation will be visually examined both during the RCS system leakage test as Class 1 boundary lines and during the HPSI system functional pressure test conducted at HPSI pump discharge pressure.
3.6 Basis
for Use The objective of the required visual examination at normal operating conditions is to detect evidence of leakage and thereby verify the integrity of the RCS pressure boundary.
FPL believes the same evidence of leakage can be identified by visual examination of all portions of the Class 1 systems at their own normal operating pressures, without subjecting the standby systems and secondary boundaries to unusual alignments and excess pressure.
Therefore, FPL concludes that the proposed alternative provides reasonable assurance of system integrity and an acceptable level of quality and safety comparable to an exam performed at normal operating conditions.
- 3. 7 Duration of Proposed Alternative The licensee stated that this relief request is applicable to the fourth 10-year ISi interval, which began February 11, 2008, and will conclude February 10, 2018. An interval extension is being utilized to complete the fourth 10-year ISi interval as allowed by IWA-2430(c)(1
). The fifth ISi interval will start on February 10, 2018. Credit for these examinations will only be applied to the fourth ISi interval. 4.0 NRC Staff Evaluation The ASME Code requires that all Class 1 components within the pressure retaining boundary undergo a pressure boundary leakage test after each refueling outage prior to plant startup. FPL proposed the use of ASME Code Cases N-798 and N-800 to perform the tests at different plant conditions than those required in ASME Section XI, Table IWB-2500-1, Category B-P, Item B15.10. FPL submitted this request in accordance with 10 CFR 50.55a(z)(2) and requests relief from these requirements.
4.1 Small
Bore Class 1 RCS Vent and Drain Lines FPL requested relief from paragraph IWB-5222(b) of the ASME Code,Section XI, for small bore Class 1 RCS vent and drain lines identified in Table 1 of its submittal, which are located between the first and the second vent, drain, and test isolation devices that remain closed during plant operation.
Paragraph IWB-5222(b) requires the pressurization of piping between the first and second isolation device on small size vent and drain lines. In order to pressurize the piping, the inboard isolation valves have to be manually opened at normal operating RCS pressure and temperature conditions.
FPL stated that when these valves are opened, the double isolation design requirements for two primary RCPB isolation devices are violated, a potential risk for spills and personnel contamination is presented, and it would eliminate a way to depressurize the line segments following the completion of the exam until the next refueling outage. Neither St. Lucie Plant, Units 1 or 2, has any OE where socket or butt welds showed signs of stress corrosion cracking or fatigue in the piping associated with Table 1. FPL proposed to use the boundaries specified in ASME Code Case N-798, which permits the boundaries of IWA-5222(a) to apply, in lieu of paragraph IWB-5222(b) of ASME Code,Section XI. This means that under ASME Code Case N-798, the system leakage test of the affected piping can be performed without satisfying IWB-5222(b), as long as IWB-5222(a) is satisfied.
The NRC staff finds this method of examination acceptable.
The NRC staff concludes, based on the preceding discussion, that the Mode 3 normal operating RCS pressure and temperature system leakage test requirement listed in paragraph IWB-5222(b) for the RCS Class 1 vent and drain lines identified in Table 1 of the licensee's submittal would result in hardship and unusual difficulty.
This hardship and unusual difficulty presented offers no compensating increase in the level of quality and safety for the St. Lucie Plant, Unit No. 1, normal operation.
Therefore, the NRC staff accepts excluding the small bore Class 1 RCS vent and drain line segments from the required system leakage test pressure of ASME Code Case N-798 based on undue hardship, without a corresponding increase in quality and safety. 4.2 Small Bore Class 1 Safety Injection/Shutdown Cooling Fill. Vent. and Drain Lines FPL requested relief from paragraph IWB-5222(b) of the ASME Code,Section XI, for small bore Class 1 safety injection vent and drain lines identified in Table 2 of the its submittal, which are located in the safety injection system. These pipe lines are statically pressurized during normal operations and are monitored for leakage by SIT pressure and level indications.
Neither St. Lucie Plant, Units 1 or 2, has any OE where socket or butt welds showed signs of stress corrosion cracking or fatigue in the piping listed in Table 2. FPL proposed to use the boundaries specified in ASME Code Case N-800 for the piping listed in Table 2, which permits the system leakage test to be conducted by pressurization of the Class 1 volume using the Class 2 safety system to pressurize the volume. Such alternative tests shall be performed each inspection interval.
The system leakage test shall be conducted using the pressure associated with the Class 2 system function that provides the highest pressure between the Class 1 isolation valves. FPL stated that it visually examines these lines during the RCS system leakage test and during the HPSI functional pressure test conducted at HPSI pump discharge pressure in accordance with the requirement of paragraph IWA-5212(e) of the ASME Code,Section XI, to examine systems at their highest operating temperature.
The NRC staff concludes, based on the preceding discussion, that the vent and drain lines listed in Table 2 of the licensee's submittal are visually examined and continuously monitored for leakage during normal operations to ensure any indication of leakage is detected.
In addition, the examinations are performed under the pressure conditions required by the ASME Code requirements, which provide an added method of leakage detection and judging structural integrity.
In order to perform the required tests, the hardship and unusual difficulty presented offers no compensating increase in the level of quality and safety for the St. Lucie Plant, Unit No. 1, normal operation.
The NRC staff finds this method of examination to be acceptable and finds reasonable assurance that structural integrity will be maintained.
4.3 Larger
Bore Class 1 Safety Injection and Shutdown Cooling Piping Segments FPL requested relief from paragraph IWB-5222(b) of the ASME Code,Section XI, for large bore Class 1 safety injection and shutdown cooling piping segments identified in Table 2 of the licensee's submittal.
FPL states that these components will continue their normal operating configurations and will not be pressurized to RCS system pressure during the system leakage test, but will be examined at full operating pressures equivalent to their safety functions.
4.3.1 Hot Leg Shutdown Cooling Suction The hot leg shutdown cooling section is located between two shutdown cooling suction valves on each train of the system. FPL stated there is a required interlock administratively controlled to be closed, at a pressure not to exceed 275 psia, as a protection from over-pressurization of the shutdown cooling system. FPL stated that this piping is VT-2 inspected through the entire length and that no external or visible leakage is acceptable.
FPL stated that these specific test parameters provide assurance that the first and second isolation valves are effective in maintaining the RCPB at normal operating temperature.
The NRC concludes, based on the preceding discussion, that the VT-2 examinations of the hot leg shutdown cooling suction line segments will provide reasonable assurance of structural integrity.
The addition of overriding administrative set points creates unusual difficulty and requires violating organizational controls, without an increase in the level of quality and safety of these piping segments.
The lack of pressurizing past the first isolation valve is not necessary to determine whether the piping segment is fit to withstand its normal service conditions safely and reliably throughout its predicted lifetime.
Therefore, the NRC staff accepts excluding hot leg shutdown cooling suction line segments from the required system leakage test pressure.
4.3.2 HPSl/LPSI Loop Header and SIT Discharge Piping FPL stated that the HPSl/LPSI and SIT discharge lines are all statically pressurized during normal operation and are monitored for leakage by SIT pressure and level indications.
In addition, FPL states the lines are visually examined both during the RCS system leakage test and the HPSI system functional pressure test. In order to perform the required leakage test, the design requirements would be violated due to temporary installations.
The NRC staff concludes, based on the preceding discussion, that monitoring for leakage by SIT pressure and level indications and a visual examination during the HPSI system functional pressure test would provide reasonable assurance of the HPSl/LPSI and SIT discharge line segment's structural integrity.
Overriding the design requirements for boundary isolation and the installation of temporary designs would create unnecessary hardship and unusual difficulty, with no compensating increase in the level of quality and safety gained on these piping segments, which are not designed to operate at RCS pressure.
Therefore, the NRC staff accepts excluding the HPSl/LPSI and SIT discharge lines from the required system leakage test pressure.
5.0 CONCLUSION
As set forth above, the NRC staff determines that complying with the specified requirement would result in hardship or unusual difficulty, without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2).
Therefore, the NRC staff approves the use of Relief Request No. 16 at the St. Lucie Plant, Unit No. 1, for the fourth ISi interval, which began on February 11, 2008, and will end on February 10, 2018. FPL is utilizing an interval extension to complete the fourth ISi interval, which is allowed by paragraph IWA-2430(c)(1).
All other requirements of ASME Code,Section XI, for which relief has not been specifically requested and approved in this relief request remain applicable, including third party review by the Authorized Nuclear lnservice Inspector.
6.0 REFERENCES
1 Snyder, Michael J, Florida Power & Light Company, letter to U.S. Nuclear Regulatory Commission, "St. Lucie Unit 1, Docket No. 50-335, lnservice Inspection Plan, sdRenewed Facility Operating License Nos. DPR-67 and NPF-16, Fourth Ten-Year Interval Unit 1 Relief Request No. 16 Revision O," June 12, 2017 (ADAMS Accession No. ML 17163A365).
Principal Contributor:
Diane Render Date: October 27, 2017 M. Nazar
SUBJECT:
ST. LUCIE PLANT, UNIT NO. 1 -INSERVICE INSPECTION PLAN FOURTH 10-YEAR INTERVAL RELIEF REQUEST NO. 16 (CAC NO. MF9827; EPID L-2017-LLR-0044)
DATED OCTOBER 27, 2017 DISTRIBUTION:
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DORL/LPL2-2/BC NAME PBuckberg BClayton DAiiey UShoop (LRonewicz for) DATE 09/28/2017 09/21/2017 09/02/2017 10/27/2017 OFFICIAL RECORD COPY