ML13329A125
| ML13329A125 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/14/2014 |
| From: | Audrey Klett Plant Licensing Branch II |
| To: | Nazar M Florida Power & Light Co |
| Klett A | |
| References | |
| TAC MF1903, TAC MF1904, TAC MF1905, TAC MF1906, TAC MF1907, TAC MF1908 | |
| Download: ML13329A125 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 14, 2014 Mr. Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power & Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4- SAFETY EVALUATION FOR RELIEF REQUEST NO. 12 FOR FOURTH 10-YEAR INSERVICE INSPECTION INTERVALS- SYSTEM LEAKAGE TEST BOUNDARIES OF CLASS 1 COMPONENTS (TAC NOS. MF1903, MF1904, MF1905, MF1906, MF1907, AND MF1908)
Dear Mr. Nazar:
By letter to the U.S. Nuclear Regulatory Commission (NRC or the Commission) dated May 24, 2013, as superseded by letter dated October 9, 2013, Florida Power & Light Company (the licensee) submitted Relief Request No. 12 for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point 3 and 4 ). Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Paragraph 50.55a(a)(3)(ii), the licensee proposed alternatives to the requirements of 10 CFR 50.55a(g)(4) on the basis that complying with the specific requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Specifically, the licensee proposed alternatives to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code), Section XI, Paragraph IWB-5222(b) requirements to fully pressurize piping between the first and second isolation device in order to perform a system leakage test on small bore size vent and drain lines in the reactor coolant system and in the segments of the residual heat removal and safety injection loop piping.
The NRC staff reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that the licensee adequately addressed all regulatory requirements in 10 CFR 50.55a(a)(3)(ii). Accordingly, the NRC staff authorizes Relief Request No. 12 at Turkey Point 3 and 4 for the remainder of the fourth 10-year inservice inspection (lSI) intervals of Turkey Point 3 and 4, which are currently scheduled to end on February 21 and April14, 2014, respectively. The licensee may invoke the provision of the ASME Code, Section XI, paragraph IWA-2430, which allows the licensee to extend the fourth 10-year lSI intervals by 1 year. The licensee may perform the proposed alternative in the 1-year extension periods.
All other ASME Code, Section XI requirements for which the request was not specifically requested and approved remains applicable, including third-party review by the Authorized Nuclear lnservice Inspector.
M. Nazar If you have any questions regarding this issue, please contact the project manager, Ms. Audrey Klett, at (301) 415-0489 or by e-mail at Audrey. Klett@nrc.gov.
Sincerely,
-'//////~~
ssie F. Quichocho, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251
Enclosure:
Safety Evaluation cc w/encl.: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. 12 FOR THE FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251
1.0 INTRODUCTION
By letter dated May 24, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13164A186), as superseded by letter dated October 9, 2013 (ADAMS Accession No. ML13303B561 }, Florida Power & Light Company (the licensee) submitted Relief Request No. 12 (RR 12) to the U.S. Nuclear Regulatory Commission (NRC or the Commission) for review and authorization. The licensee submitted RR 12 for the fourth 10-year inservice inspection (lSI) intervals of the Turkey Point Nuclear Generating Unit Nos. 3 and 4 {Turkey Point 3 and 4 ). Pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR), Part 50, Paragraph 50.55a(a)(3)(ii), the licensee requested authorization to use the proposed alternative to 10 CFR 50.55a(g)(4) because complying with a specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Specifically, the licensee requested to use an alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code), Section XI, Paragraph IWB-5222(b) requirements to fully pressurize piping between the first and second isolation device in order to perform a system leakage test on small bore size vent and drain lines in the reactor coolant system (RCS), segments of the residual heat removal (RHR) piping, and segments of the safety injection loop piping.
By electronic mail dated September 9, 2013 (ADAMS Accession No. ML13282A185), the NRC sent the licensee a request for additional information (RAI) regarding the relief request. By letter dated October 9, 2013, the licensee responded to this request.
The licensee requested to use the proposed alternative for Turkey Point 3 and 4 until the end of the fourth 10-year lSI intervals. The Turkey Point 3 fourth 10-year lSI interval is scheduled to end on February 21, 2014, and the Turkey Point 4 fourth 10-year lSI interval is scheduled to end on April14, 2014. However, the licensee may invoke the provision of the ASME Code, Section XI, Paragraph IWA-2430, which allows the licensee to extend the fourth 10-year lSI intervals by 1 year. Extending the fourth 10-year lSI intervals would be necessary because the licensee extended previous refueling outages to install power uprate modifications.
Enclosure
2.0 REGULATORY EVALUATION
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code, Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. Pursuant to 10 CFR 50.55a(g)(4)(i) and 10 CFR 50.55a(g)(4)(ii), inservice examination of components and system pressure tests conducted during the first 10-year inspection interval and subsequent 10-year inspection intervals must comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed therein.
Pursuant to 10 CFR 50.55(a)(3)(ii), alternatives to the requirements of 10 CFR 50.55a(g) may be used when authorized by the Director of the NRC Office of Nuclear Reactor Regulation if compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Based on its analysis of the regulatory requirements, the NRC staff finds that the regulatory authority exists to authorize the licensee's proposed alternative on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff reviewed and evaluated the licensee's request pursuant to 10 CFR 50.55a(a)(3)(ii).
The code of record for the Turkey Point 3 and 4 fourth 10-year lSI intervals is the 1998 Edition with Addenda through 2000 of the ASME Code, Section XI.
3.0 TECHNICAL EVALUATION
3.1 Licensee's Proposed Alternative The components for which the licensee is seeking proposed alternatives are listed in Table 1 of the licensee's letter dated October 9, 2013, and are listed in the attachment to this safety evaluation.
The code of record for the Turkey Point 3 and 4 fourth 10-Year lSI intervals is the ASME Code, Section XI, 1998 Edition through the 2000 Addenda. The Turkey Point 3 fourth 10-year lSI interval began on February 22, 2004, and is scheduled to end on February 21, 2014. The Turkey Point 4 fourth 10-year lSI interval began on April 15, 2004, and is scheduled to end on April 14, 2014. Because of the extended refueling outages for the power uprate plant modifications, the licensee stated that it may invoke the provision of ASME Code, Section XI, Paragraph IWA-2430( d)1. This paragraph allows the licensee to extend the fourth 10-year lSI interval by 1-year to complete the required ISis during the refueling outages for Cycle 27 of Turkey Point 3 and Cycle 28 of Turkey Point 4, respectively, and to credit those inspections and examinations to the fourth 10-year lSI intervals.
ASME Code, Section XI, Table IWB-2500-1, Section IWB-5200, "System Test Requirements,"
Subsection IWB-5222, "Boundaries," Paragraph (b), requires that "[t]he 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."
The licensee proposed an alternative to this requirement that uses leakage testing. The licensee proposed that the Class 1 system boundary be maintained in a normal operational alignment during leakage tests for the items identified within Table 1 of its letter dated October 9, 2013, constituting exceptions to the Code-required boundary of IWB 5222(b). The VT-2 visual examination will extend to the Class 1 pressure retaining components within the system boundary during the performance of each system leakage test required by Table IWB-2500-1 examination category B-P. The licensee stated that the items within Table 1 of its letter dated October 9, 2013, will be visually examined for evidence of leakage during system leakage testing without being pressurized.
The licensee's basis for requesting the proposed alternative consisted of the following. The ASME Code required leakage test would be performed in Mode 3 at the normal operating temperature and pressure. However, 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 doing so, the design requirement for two primary coolant pressure boundary isolation devices would be violated.
Additionally, opening of these valves introduces the potential risk for spills and personnel contamination. For configurations where blind flanges or caps are installed as isolation devices, opening of the inboard valve introduces the possibility of a personnel safety hazard if a flange or cap fails in the presence of inspection personnel. In addition, the licensee performs a VT-2 visual examination on these piping segments through the entire length as part of the Class 1 system inspection at the conclusion of each refueling outage. This leakage test does not specifically pressurize past the first isolation valve. This leakage test is also considered successful when no external or visible leakage is identified. Because this type of test assures that the combined first and second isolation devices are effective in maintaining the reactor coolant pressure boundary at normal operating temperature and pressure, the increase in safety achieved from the code required leakage test (IWB-5222(b)) is not commensurate with the hardship of performing such code required leakage testing.
The licensee cited the following precedent: "H.B. Robinson Steam Electric Plant Unit No. 2, Relief Request 4 for the Fifth 10-Year Interval lnservice Inspection Program Plan (TAC No. ME8255)" (ADAMS Accession No. ML12181A126).
3.2 NRC Staff's Evaluation The ASME Code, Section XI requires that the pressure retaining boundary be extended to all Class 1 pressure-retaining components within the system boundary during the system leakage test conducted at or near the end of each inspection interval. The subject piping segments provide the design-required double isolation barrier for the reactor coolant pressure boundary.
The Code-required leakage test would be performed in Mode 3 while the components are at normal operating pressure and temperature.
The subject piping is seamless schedule 160, A-376, type 316 stainless steel. In response to the NRC staff's RAI, the licensee stated that a review of the lSI reports and corrective action program database indicate that there is no history of degradation, such as fatigue or stress corrosion cracking, of the subject lines.
RCS Vent. Drain. Test. and Fill Lines In response to the NRC staff's RAI, the licensee stated that pressurizing the subject vent and drain lines to the required pressure would result in an estimated radiological dose of 280 milli-roentgen equivalent man (mrem) for Turkey Point 3 and 344 mrem for Turkey Point 4.
Based on as low as reasonably achievable considerations, as well as the potential risk for spills and personnel contamination, and personnel safety hazard if a flange or cap fails in the presence of inspection personnel, the NRC staff finds that performing the ASME Code required pressure test on the subject lines would present a hardship.
The licensee requested to use an alternative to fully pressurizing piping between the first and second isolation device on small bore size vent, drain, test, and fill lines in the RCS, which range in size from 0.5 to 2 inches. The configurations are either two small isolation valves in series, a valve and blind flange, or a valve and cap. In certain configurations, the piping between the two isolation boundaries will tee to a third valve that is also the second isolation boundary. These lines are not pressurized during normal service except as the result of leakage of the upstream valve. If the upstream valve does not leak during service, then the subject lines would not be pressurized and would only be subjected to low usage service conditions where degradation is not expected. If the upstream valve did leak during service, then the subject lines would be pressurized, and the VT-2 visual examination at the end of each refueling outage would provide reasonable assurance of structural integrity and leak tightness.
The NRC staff finds that based on the materials of construction, low usage service conditions, and the VT-2 visual examination of the segments conducted at the end of each refueling cycle, there is reasonable assurance of structural integrity and leak tightness of the subject piping.
14-inch RHR Motor Operated Valves (MOV) Segment In response to the NRC staff's RAI, the licensee stated that pressurizing the segment between the RHR inlet MOVs 750 and 751 would require that MOV-3/4-750 be bypassed by installing a pipe jumper. This pipe jumper would experience RCS pressure and temperature conditions.
Risks associated with using a pipe jumper include the possibility of overpressurizing the RHR system should the RHR Inlet valves MOV-3-751 or MOV-4-751 fail. Additionally, if a leak develops at the pipe jumper, it could result in an unisolable RCS leak, and testing and supporting personnel would be at risk from the leakage being at RCS conditions. The NRC staff finds that modification of the existing configuration to permit the required pressure testing and the risks associated with performing the ASME Code required pressure test on the subject lines would present a hardship.
The licensee stated that this segment of pipe experiences pressures equivalent to reactor cavity static head and up to 450 pounds per square inch gauge during normal RHR operation.
Although this 14-inch diameter segment is isolated from the RCS, it is possible that the segment of pipe between MOV-3/4-750 and MOV-3/4-751 can become pressurized from minor leak-by past the first isolation valve during normal plant operations. The NRC staff finds that because the subject segment is pressurized to RHR system pressure for a significant period of time during a refueling outage, the VT-2 visual examination at the end of each refueling outage provides reasonable assurance of structural integrity and leak tightness.
Safety Injection Loops High Head Check Valves 3-874NB, 4-874NB, and Upstream Piping Segments In response to the NRC staff's RAI, the licensee stated that in order to pressurize the safety injection loop high head check valves and upstream piping lines, the high head check valve needs to be temporarily modified by removing its internals. This modification would create a configuration where only one isolation valve will be available to prevent overpressurizing the high head safety injection system. At the completion of this evolution, the affected pipe segment would need to be depressurized in order to restore the affected check valve to its original configuration. Another option would be to bypass one of the high head check valves by installing a pipe jumper. However, the pipe jumper would experience RCS pressure and temperature conditions. If a leak develops at the pipe jumper, it could result in an unisolable RCS leak, and testing and supporting personnel would be at risk from the leakage being at RCS conditions. The NRC staff finds that modification of the existing configuration to permit the required pressure testing and the risks associated with performing the ASME Code required pressure test on the subject lines would present a hardship.
In response to the NRC staff's RAI concerning whether it is possible to pressurize these lines to a pressure associated with operation of the high head safety injection pump, the licensee stated that performance of the safety injection system full flow test during a refueling outage when the reactor head is removed and the reactor cavity is flooded results in pressurization of the subject lines. A VT-2 visual examination of the subject piping is then performed while a safety injection pump is running. The NRC staff finds that because the subject segment is pressurized during the safety injection system full flow test during a refueling outage and a VT -2 visual examination is performed, there is reasonable assurance of structural integrity and leak tightness.
Based on the above analysis, the NRC staff finds that the licensee demonstrated that complying with the specified requirement would result in a hardship or unusual difficulty. The NRC staff also finds that the licensee's proposed alternative will provide reasonable assurance of structural integrity and leak tightness of the subject components for the time period of the proposed alternative. The NRC staff therefore finds that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
4.0 CONCLUSION
As set forth in the aforementioned evaluation, the NRC staff determines that the licensee's proposed alternative - Relief Request No. 12 - provides reasonable assurance of structural integrity and leak tightness of the subject components, and 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(a)(3)(ii) and therefore authorizes use of the proposed alternative for the remainder of the fourth 10-year lSI interval of Turkey Point 3, which will end on February 21, 2014, and of Turkey Point 4, which will end on April14, 2014. The licensee may invoke the provision of the ASME Code, Section XI, Paragraph IWA-2430, which allows the licensee to extend the fourth 10-year lSI intervals by 1 year.
All other ASME Code, Section XI, requirements for which relief was not specifically requested and authorized herein by the NRC staff remain applicable, including the third party review by the Authorized Nuclear lnservice Inspector.
Attachment:
Affected Pressure Retaining Components Principal Contributor: Jay Wallace Date: January 14, 2014
Turkey Point 3 Affected Class 1 Pressure Retaining Components Code Plj)e Pipe Approx Exam Affected L1ne or Component 0raW1ng No Boundary Excepbon(s)
Class O.ameter Schedule Length Calego<y Dram ltne below PZR safety A376 TP316 Valve 3-545 remains closed to avo*d 5613-M-3041 valve RV-3-551 A (plpe p.e¢11 1 314 .n SMLS Sch 160 1 II S-P pressurwng downstream Class 1 p.pe Sh 2 between 3-545 and 3-545A) p.ec11 and valve 3-545A Ora1n ltne below PZR safety Valve 3-546 remamt. closed to avoid valve RV-3-5518 (pipe p.ec11 A376 TP316 5613-M-3041 1 314 Ill 2fl S-P pressunzing downstream Class 1 ptpe between 3-546 and 3-546A SMLS Sen 160 Sh 2 poece and valves 3-546A and 3-585 and 3-585)
Dram line below PRZ safety A376 TP316 5613-M-3().41 Valve 3-547 rema~r~s closed to avo1d valve RV-3*551C (Pipe pieu 1 314*n ~ 1n 6-P pressunztog downstream Class 1 p.pe SMLSSch 160 Sh 2 between 3-547and 3-547A) poece and valve 3-547A A376 TP316 RCS lOOP ontermediate lOOP 2*n SMLSSch 160
- s:l n Valve 3-506A rema.ns closed to avoid
'A' dralfl valve, hqtlld waste 5613-M-3041 1 6-P pressuriZing downstream Class 1 dtSPOsal p.p<ng, and leak-off Sh 1 A376 TP316 P*Ptng and valves 3-5068 and 3-542 valve 314 in. 28ft SMLSSch 160 RCS lOop inletmediate loop Valve 3-515A remains dosed to avoid A376 TP316 5613-M-3041
- a* dram valve and I!Qtltd 1 2in SMlSSch 160
,:1 It B*P Sh 1 pressurtzlng downstream Class 1 waste dt$p0$al PJPIOQ PiPing and valve 3-5156 RCS lOop intetmedoate loop Valve 3-505A remalfiS clOsed to avo1d A376 TP316 5613-M-3041
- c* dram valve and I!Qtlld 1 21<'
SMLS Sch 160
- 1 It B-P Sh 1 pressunzmg downstream Class 1 waste dtSPOSBI p<p~ng Plptng and valve 3-5058 Valve 3-300A rema<ns closed to avoid RCP 'A' seal in)ectJon dratn A376TP316 5613-M-3047 l 1ft B-P pressurizing downstream pipe piece valve and blind flange 314 '" SMLS Sch 160 Sh3 and flange Valve 3-300C rematns closed to avoid RCP 'A' seal water bypass A376 TP316 o613*M*3047
~ 314'" < 1 It B-P pressunztng downstream ptpe pteee vent valve and t>lrnd flange SMLS Sch 160 Sh.3 and flange Code Ptpe Pipe Approx Exam Affected Ltne or Component Draw.ng No Boundary Exception( s)
Class D<ameter Schedule Length Calego<y Valve 3-3000 remams clOsed to avotd RCP 'B' seatlnjectlOil drain A376 TP316 5613-M-3047 1 314 In
- 1ft B-P presSUfiZtog downstream p1pe plece valve and cap SMLSSch 160 Sh 3 and cap Valve 3-300f remains clOsed to avO<d RCP'S'sealwarer~s A376 TP316 5613-M-3047 1 314 '" ' 1 ft 8-P pressurtZ>ng downstream pipe p!ece Vent valve and blind flange SMLS Sch. 160 Sh 3 and flange Valve 3-3000 remains clOsed to avoid RCP *c* sealtnlect*on dram A376 TP316
~1ft 6-P 5613-M-3047 pressunzing downstream pipe Piece valve and cap 314 '" SMLS Sch 160 Sh 3 and cap Valve 3-300J remains clOsed to avo.'(!
RCP *c* seal water bypass 1 3/4 If\
A376 TP316 1 ft B.P 5613-M-3047 pressunz*ng downstream p*pe p<eee Vent valve and obnd flange. SMLS Sch. 160 Sh 3 and flange A376 TP316 2in 139 It Valve CV-3-311 rem111ns clOSed to SMLSSch 160 Aux~.ary spray hne vent valve 5613-M-3047 avotd pressunzmg downstream ptptng 1 B-P and upstream pcp.ng Sh 2 up to check valve 3-313 and vent p1pe A376 TP316 314tn ~ 1 It and vent valve 3-120J SMLS Sch 160 Residual heat removal motor- 1 14 tn A376 TP316 SMLSSch 140 I 26ft Valve MOV-3-750 to remain clOsed to operated valve MOV-3-750 and common suct1on PIP'"9 i 1 3/4 '" 1!2 '"
I A376 TP316 1 SMLS Scl'l 160 3ft B-P 5613-M-3050 Sh1 avoid pressunng downstream piptng and valves, MOV-3-751 3-7508. 3-750C and 3-7500 Downstream ptplflg of CV 3108 1 3m l A376 TP316 SMlS Sch 160 i 45 fl 6-P 5613-M-3047 Sh 2 Valve CV-3-3108 to rematn clOsed to avO<d pressuriZing downstream p1p 1ng up to check va!ve 3-3128 i i 1 Attachment
Code Prpe Pipe Approx Exam Affected ltne or COI'IlpO<lent Drawing No Boundary Exceptton( s)
Class D*ameter Schedule Length Category A376 TP316 Check valves 3-674A and 3-6748 to
\
2 '" SMLSSch 160 222ft I
, remain closed to aVOid diSassembly or l
Safety lnteet>on check valves other temporary configurations 561~M-3062 I
3-674A, 3-874Band 1 B-P requtfed to adl~eVe test pressures at upstream pipmg 314 tn A376 TP316 I :s 1 ft Sh 1 upstream p!ping and valves MOV 866A and B. 3-941C and 0, and 3-SMLS Sch 160 '
957 Vatve 3-566 remains closed to Pressunzer Spray 1111e draJn A376 TP316 5613-M-3041 1 314 tn ~1 ft B-P avoid pressuriZing downstream valve and cap SMLSSch 160 Sh. 2 pipe p.ece and cap Vatve 3-569 remains closed to Pressunzer Spray l111e dram A376 TP316 561~M-3041 1 314 1n. ~~ ft B-P 8\IOid pressunzing downstream valve and cap SMLSSch 160 Sn 2 pipe piece and cap Vatve 3-201A rema*ns closed to Regenerative Heat Exchanger A376 TP316 561~-3047 1 314 *n ~ 11! B-P av04d pressunztng downstream outlet dralll hne and cap SMlSSch 160 Sh 1 pipe pteee and cap Turkey Point 4 Affected Class 1 Pressure Retaining Components COde Prpe Plpe Approx Affected lme or Component ~xam CategOtj Draw*ng No Boundary ExceptJon(s)
Class Dtameter Schedule Length Vallie 4-545 remal!'ls closed to Dra111 line below PZR safety A376 TP316 5614-M-3041 avoid pressulizmg downstream vatve RV-4-551A (ptpe piece 1 314'" s 1 It 8-P SMLSSch 160 Sh2 Class 1 pipe piece and valve 4-betWeen 4-545 and 4-545A}
545A Dram line below PZR safety Vallie 4-546 remams closed to valve RV-4-551 B (ptpe pteee A376 TP316 5614-M-3041 avoid pressunzmg downstream 1 314 tn ~2ft B*P betWeen 4-546, 4-546A al'd SMLS Sch 160 Sh2 Class 1 pipe piece and valves 4-4-585) 546A and 4-585 Vallie 4-547 remams closed to Dram 1111e below PRZ safety A376 TP316 5614-M-3041 avoid pressurizmg downstream valve RV-4-551C (ptpe ptece 1 314 rn < 1 It B-P SMLS Sch 160 Sh 2 Class 1 pipe piece and valve 4-betWeen 4-547and 4-547A) 547A A376 TP316 RCS loop intermecltate loop 2m 1ft Valve 4-508A remains closed to SMLS Sch 160
'A' drain valve. liquid waste 5614-M-3041 avoid pressur!l.ing downstream 1 B-P disposal pipmg, and leak-off Sh1 Class 1 ll{ptng and valves 4-5088 A376 TP316 valve 314in 28ft and 4*542 SMLS Sch. 160 RCS loop intermedtate loop Vallie 4-515A remains closed to A376 TP316 5614-M-3041
'B" drain valve and liquid 1 2111 1ft B-P a\!Oid pressunz1ng downstream SMLS Sch. 160 Sit 1 waste disposal p~ptng Class 1 p.ping and valve 4-5158 RCS loop rntermedtate loop Valve 4-505A remains closed to A376 TP316 5614-M-3041
- c* dra*n valve and liquid 1 2m SMLS Sch 160
- 11! BP Sh 1 a\!Oid pressurrzing downstream waste drsposal piping Class 1 pipmg and valve 4*5058 Valve 4-300A remains cl01led to RCP 'A' seal tn,ecbon dratn A376 TP316 5614-M-3047 1
314 "' s1ft B-P avoid pressuriZing downstream val\le and blind ftange SMLS Sch 160 Sh. 3 I p1pe piece and llarige
Code Pope Pipe Apptox Afft!cted l *11e or Component l=xamCaleg(}<'1 DraWing No Boun<lal"1 Exceptlon{s)
Class O;arl1eter Schedule Length Valve 4-300C rematns closed to RCP *A* seal water bypass A376 TP316 5614*M<3047 1 31411' 1 It B-P avoid pressurizing downstream vent valve and bhn<l flange SMLS Sch 160 Sh 3 pipe piece and flange Valve 4-3000 remams closed to RCP 'B" seal injeclion drain A376 TP316 5614-M-3047 1 31411'1 -;1ft 8*P avoid preswnzlng dO'Mistream valve and cap SMLS Sch 160 Sh 3 pipe piece and cap Valve 4-300F ramams closed to RCP *a* seal water bypass A376 TP316 5614.M-3047 1 314111 1ft B-P avoid preswnztng dOWlistream Vent valve and bhnd flange SMLS Sch 160 Sh 3 ptpe pteCe and flange ValVe 4-3000 remains closed to RCP 'C' seal injeC!IOn dram A376 TP316 5614-M-3047 1 3l4ll'l 1 It 8-P avoid pressurwng downstream valve aoo cap SMLS Sch 160 Sh 3 pipe ptece and cap Valve 4-300J remains closed to RCP *c* seal water bypass 1 314 in.
A376 TP316
\1ft 8-P 5614-M-3047 avoid pteSSuftZII'Ig downstream Vent valve and bltnd flange SMLS Sell 160 Sh 3 p!pe piece and flange Valve CV-4-311 ren;ams closed to Ptptng dO'Mistream of CV A376 TP316 5614-M-3047 1 21f'l 142 It S-P avoid pressunzll'!g dO'Mistream 311 SMLS Sell. 160 Sh 2 ptping up to check valve 4-313 A376 TP316 44 It Valve MOV-4-750 to remain closed 14 '" SMLS Sell 140 Residual heat removal motor. 1 5614 .M<3050 to avotd pressunng downstream operated valve MOV-4-750 and common suction p.ping 1
314111.
112 111 1 In A376 TP316 SMLS Sch 160 .
I 10ft I
B-P I Sl'l 1
I ptptng and valves. MOV-4-751 4-750A. 4-7508, 4-750C and 4-150o 15614-M-J04? Valve CV-4-3108 to remain closed Piptng downstream of CV 3108 1 3*n A376 TP316 SMLS Sell !60 48ft B-P Sh 2
j1 to avotd pressunztng downstream PIPI09 up to check valve 4-3128 1
Code Ptpe Pipe Api)(OX Affected L 111e or Component Class Length Exam Categofl Draw1ng No Boundary Excepoon(s)
D111r11eter Schedule i
A376 TP316 Check valves 4-874A and 4 8748 2111 140ft to rema111 closed to avoid SMLS Sch 160 Safety lnJectiOtl check valves disassembly or other temporal"1
! 15814M3062 4-87 4A. 4-8748 and 1 8-P configurations required to achteve upstream p1pll'\g 314 *n ISh., test pteSSures at upstteam pip111g I
\ A376 TP316 ., 3ft and valves MOV-4-866A and B. 4-I 1111 I
SMLS Sell 160 941C and 0, and 4-957 Pressunzer Spray kne dratn valve and cap 1
l 314tn A376 TP316 SMLS Sch 160 i
i I
s1ft 1 B-P 5814-M-3041 Sn 2 Valve 4*56a rematns closed to avoid pressurizing downstream ptpe pteee and cap Valve 4-569 remams closed to Pressunzer Spray fine drain valve and cap 1
l 314 '"
A376 TP316 SMLS Sch 160 I
- 1 II I 8-P 5614-M-3041 sn 2 avotd pressuriztng downstream ptpe ptece and cap l Valve 4-201A ren;ains closed Regenerative Heat ExChanger outlet dratn hne and flange 1
314 '"
A376 TP316 SMLS Sch 160 s 1ft.
1 8-P 15614M3047 I
Sh. 1 to avoid p~essunzmg downstream pipe pieCe and
!lange
M. Nazar If you have any questions regarding this issue, please contact the project manager, Ms. Audrey Klett, at (301) 415-0489 or by e-mail at Audrey. Klett@nrc.gov.
Sincerely,
/RAJ Jessie F. Quichocho, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251
Enclosure:
Safety Evaluation cc w/encl.: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL2-2 R/F RidsNrrDorllpl2-2 RidsNrrLABCiayton RidsAcrsAcnw_MaiiCTR RidsRgn2MaiiCenter JWallace, NRR RidsNrrDeEsgb BRini, EDO RidsNrrPMTurkeyPoint ADAMS Access1on No.: ML13329A125 *B5y e-ma1"I OFFICE LPLII-2/PM LPLII-2/LA ESGB/BC* LPLII-2/BC NAME AKiett BCiayton GKulesa JQuichocho DATE 01/10/14 01/09/14 12/13/13 01/14/14 OFFICIAL RECORD COPY