L-2007-195, Inservice Inspection Plan Fourth Ten-Year Interval Unit 1 Relief Request 1

Inservice Inspection Plan Fourth Ten-Year Interval Unit 1 Relief Request 1

ML073480185
Person / Time
Site:	Saint Lucie
Issue date:	12/07/2007
From:	Johnston G Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2007-195
Download: ML073480185 (5)

Text

0 FPL Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach, FL 34957 December 7, 2007 L-2007-195 10 CFR 50.4 1OCFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re: St. Lucie Unit 1 Docket No. 50-335 Inservice Inspection Plan Fourth Ten-Year Interval Unit 1 Relief Request 1 Pursuant to 10 CFR 50.55a (a)(3)(i), FPL requests to revise the St. Lucie Unit I ISI Program, for Class 1 piping only, through the use of a Risk-Informed Inservice Inspection Program (RI-ISI) as an alternative to the current requirements of Class I examination Categories B-F and B-J as specified in Table IWB-2500-1 of the 2001 Edition with 2003 Addenda of ASME Section XI.The proposedrevision to the ISI program, for Class 1 piping only, is based on the risk-informed process described in Westinghouse Owners Group WCAP-14572, Revision 1-NP-A,"Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report." A similar revision to the third interval ISI program was submitted by letter dated July 30, 2003, as supplemented by letters dated December 4, 2003, and January 28, 2004, and was approved by SER dated March 25, 2004 (TAC No. MC0244). This request for alternative utilizes the identical methodology that was previously approved.Please contact Ken Frehafer at (772) 467-7748 if there are any questions about this submittal.

Very truly yours, Attachment GLJ/KWF 4e~r7 an FPL Group company St. Lucie Unit 1 Docket No. 50-335 Inservice Inspection Plan Fourth Ten-Year Interval Unit I Relief Request 1 L-2007-195 Attachment Page 1 of 4 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety--1. ASME Code Components Affected Class 1 pressure retaining similar and dissimilar metal piping welds B5.40 Pressurizer-NPS 4 or larger, Nozzle-to-Safe End Butt Welds B-F B5.50 Pressurizer-Less than NPS 4, Nozzle-to-Safe End Butt Welds B9.11 Piping- NPS 4 or Larger, Circumferential Welds B9.21 Piping- Less than NPS 4, Circumferential Welds other than PWR high pressure safety injection systems B9.22 Piping- Less than NPS 4, Circumferential Welds of 892 PWR high pressure safety injection systems B9.31 Piping- Branch Pipe Connection Welds, NPS 4 or Larger B9.32 Piping- Branch Pipe Connection Welds, Less than NPS 4 B9.40 Piping- Socket Welds 2. Applicable Code Edition and Addenda Inservice inspections (ISI) are performed on piping to the requirements of the ASME Boiler and Pressure Vessel Code Section Xl, 2001 Edition with 2003 Addenda as required by 10CFR50.55a.

3. Applicable Code Requirement Pursuant to 10 CFR 50.55a (a)(3)(i), FPL requests to revise the St. Lucie Unit 1 ISI Program, for Class 1 piping only, through the use of a Risk-Informed Inservice Inspection Program (RI-ISI) as an alternative to the current requirements of Class 1 examination Categories B-F and B-J as specified in Table IWB-2500-1 of the 2001 Edition with 2003 Addenda of ASME Section XI.

St. Lucie Unit I L-2007-195 Docket No. 50-335 Attachment Inservice Inspection Plan Page 2 of 4 Fourth Ten-Year Interval Unit 1 Relief Request I The proposed revision to the ISI program, for Class 1 piping only, is based on the risk-informed process described in Westinghouse Owners Group WCAP-14572, Revision 1-NP-A, "Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report." A similar revision to the third interval ISI program was submitted by letter dated July 30, 2003, as supplemented by letters dated December 4, 2003, and January 28, 2004, and was approved by SER dated March 25, 2004 (TAC No. MC0244).This request for alternative utilizes the identical methodology that was previously approved.St. Lucie Unit 1 is entering the fourth interval as defined by the Code for Program B. The fourth inspection interval for St. Lucie Unit 1 begins February 11, 2008 and ends February 10, 2018.4. Reason for Request The objective of this submittal is to continue the change to the ISI program plan for Class 1 piping only through the use of a risk-informed inservice inspection (RI-ISI) program for the fourth 10-year interval.

The risk-informed process used in this submittal is described in Westinghouse Owners Group WCAP-14572, Revision 1-NP-A, "Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report." 5. Proposed Alternatives and Basis for Use ASME Section Xl Class 1 Categories B-F and B-J currently contain the requirements for examining (via non-destructive examination (NDE)) Class 1 piping components.

This current program submittal is limited to ASME Class 1 piping, including piping currently exempt from requirements.

The alternative RI-ISI program for piping is described in WCAP-14572, Revision 1-NP-A. FPL will substitute the Class 1 RI-ISI for the ASME Section Xl, Category B-F and B-J examination program on piping. Other non-related portions of the ASME Section Xl Code will be unaffected.

Basis for Use The St. Lucie Unit 1 ISI program for the examination of Class,1 piping welds is in accordance with a risk-informed process submitted July 30, 2003. NRC approved this request on December 23, 2003 (TAC No. MC0244). In the original submittal, FPL committed to review and adjust the risk ranking of piping segments as a minimum on an ASME period basis. Most U.S. nuclear power plants have now implemented similar risk-informed inservice inspection programs, with similar review and update commitments.

As a result, a task force was formed by the Nuclear Energy Institute (NEI) to formulate consistent guidance for maintaining these programs.

The task force included representatives from reactor operating companies, ASME committees, EPRI, and Westinghouse.

The result of this effort is document NEI 04-05, "Living Program Guidance To Maintain Risk-Informed Inservice Inspection Programs For Nuclear Plant Piping Systems", published April, 2004.While not specifically approved by the NRC, the NRC staff reviewed the document as it was being developed and provided comments.

St. Lucie Unit 1 L-2007-195 Docket No. 50-335 Attachment Inservice Inspection Plan Page 3 of 4 Fourth Ten-Year Interval Unit I Relief Request 1 In accordance with the guidance provided by NEI 04-05, a periodic evaluation and update was performed in conjunction with the end of the Third ISI Inspection Interval at St. Lucie Unit 1. The updated program resulting from this review is the subject of this request.In accordance with the guidance provided by NEI 04-05, Table 1 identifies the number of welds added to and deleted from the originally approved RI-ISI program. One weld was deleted due to a configuration change: an elbow welded to a pipe was replaced with a bent pipe, eliminating the pipe-to-elbow weld. Changes in weld count per Category are attributable to a change in definition of Category B-F in the 2001 Edition with 2003 Addenda.A new Change in Risk Evaluation was performed, and the risk from the revised risk-informed ISI program continues to remain constant when compared to the last deterministic Section XI inspection program.6. Duration of Proposed Alternative FPL will implement the alternative requirements during the fourth 10-year Inservice Inspection interval at St. Lucie Unit 1.7. Precedents St. Lucie Unit 1 submitted, by letter dated July 30, 2003, as supplemented by letters dated December 4, 2003, and January 28, 2004, relief request #19, "Risk Informed Inservice Inspection Program" for implementation during the third inspection period of the third 10-year inspection interval.

The request was approved by SER dated March 25, 2004 (TAC No. MC0244). This request for alternative utilizes the identical methodology that was previously approved.8. Tables Table 1 -"STRUCTURAL ELEMENT SELECTION RESULTS AND COMPARISON TO ORIGINAL PROGRAM AND PREVIOUS RI-ISI PROGRAM."

St. Lucie Unit 1 Docket No. 50-335 Inservice Inspection Plan Fourth Ten-Year Interval Unit 1 Relief Request 1 L-2007-195 Attachment Page 4 of 4 Table I STRUCTURAL ELEMENT SELECTION RESULTS AND COMPARISON TO ORIGINAL PROGRAM AND PREVIOUS RI-ISI PROGRAM Number of High ASME Xl Safety Significant ASME Examination Methods Third Interval Approved Fourth Interval Segments Code Weld Count' (Volumetric (Vol) and RI-151 2 RI-IS1 2 (No. of HSS in Degradation Category Surface (Sur))Aug. Program I Mechanism(s)

Class (original Total No. of 1989 SES Number SES Number of Segments in Aug. Basis)1 Butt Socket Vol & Sur Sur Only Matrix of Exam Matrix Exam Program) Region Locations Region Locations B-F 1 3 0 0 3 CH 0 Thermal Fatigue 1 00 -0 B-J 13 157 0 22 B-F1 21 0 12 9 4 1 Thermal Fatigue, volumetric volumetric RC 11 (0/0) Thermal Transients, 1 1,2 1,2 Vibration Fatigue B-J 156 17 33 18 20 22 volumetric volumetric B-F 1 6 0 6 0 SI 0 Thermal Fatigue 1 0 0 B-J 285 15 69 22 B-F 1 30 0 18 12 4 NDE 1 NDE TOTAL 11 (0/0) CL. 1 B-J 454 189 102 62 20 NDE 22 NDE TOTAL 484 189 120 74 24 NDE 2 23 NDE 2 Summary: Original ASME Section XI selected a total of 120 non-destructive exams (surface only exams not included).

The Third Interval RI-ISI program selected a total of 24 non-destructive exams, and the Fourth Interval RI-ISI program selects a total of 23 non-destructive exams.Notes: 'The ASME Code Category and weld count is based on the 1989 Edition of the ASME Section XI Code, which was the basis forthe Program when RI-ISI was originally developed.

In the 2001 Edition with 2003 addenda, Category B-F pertains only to vessel dissimilar metal welds.2 System pressure test requirements and VT-2 visual examinations shall continue to be performed in ASME Class 1 systems.