L-2008-014, Inservice Inspection Plan, Third Ten-Year Interval Unit 1 Relief Request 30

Inservice Inspection Plan, Third Ten-Year Interval Unit 1 Relief Request 30

ML080380330
Person / Time
Site:	Saint Lucie
Issue date:	02/04/2008
From:	Johnston G Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2008-014
Download: ML080380330 (14)

Text

Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach, FL 34957 0 February 4, 2008 L-2008-014 F=PL 10 CFR 50.4 10CFR 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 Third Ten-Year Interval Unit 1 Relief Request 30 Pursuant to 10CFR 50.55a (a)(3)(i), Florida Power and Light Company (FPL) requests approval to implement an alternative to the requirements of Appendix VIII, Supplement 2, as referenced by Supplement 3, within ASME Section XI, 1995 Edition with the 1996 Addenda as required by 10CFR50.55a by providing alternative qualification requirements for UT of ferritic RCS welds from the ID.

The automated ultrasonic techniques to be utilized for the examinations of the Reactor Coolant piping from the ID will have been qualified by demonstration in accordance with the requirements of Appendix VIII, Supplement 3, of the 1995 Edition with Addenda through 1996 of ASME Section XI and proposed alternatives by the Performance Demonstration Initiative (PDI). The use of techniques qualified from the inside surface provides assurance that the Reactor Coolant piping welds have remained free of service related flaws thus enhancing quality and ensuring plant safety and reliability.

Please contact Ken Frehafer at (772) 467-7748 if there are any questions about this submittal.

Very

• ly yours, Gardon L. Johnston Site Vice President St. Lucie Plant Attachment GLJ/KWF an FPL Group company

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 1 of 13 Third Inservice Inspection Interval Relief Request Number 30 Proposed Alternative In Accordance with 10 CFR 50.55a (a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety--

"Alternative Qualification Requirements for UT of Ferritic RCS Welds from the ID"

1. ASME Code Component(s) Affected Class 1 Reactor Coolant System (RCS) welds subject to Ultrasonic (UT) examination from the inside surface (ID).

2. Applicable Code Edition and Addenda

The code of record for the St. Lucie Unit 1 third 10-year inservice inspection interval is the 1989 Edition, no Addenda, of the American Society of Mechanical Engineers (ASME) Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components." 10CFR50.55a requires that "Licensees implementing the 1989 Edition and earlier Editions and Addenda of IWA-2232 of Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code must implement the 1995 Edition with the 1996 Addenda of Appendix VIII and the Supplements to Appendix VIII of Section Xl, Division 1, of the ASME Boiler and Pressure Vessel Code."

3. Applicable Code Requirement

Pursuant to 10CFR 50.55a (a)(3)(i), Florida Power and Light Company (FPL) requests approval to implement an'alternative to the requirements of Appendix VIII, Supplement 2, as referenced by Supplement 3, within ASME Section XI, 1995 Edition with the1996 Addenda as required by 10CFR50.55a.

Exam ItmExaminationiDsrpii Cat. No. ~

B-J B9. 11 Essentially 100% volumetric examination of the pressure (R-A) (R1.11) retaining welds in piping in accordance with Figure IWB-2500-8 Code Case N-524 & Risk Informed Program, Essentially 100%

B-J B9.12 volumetric examination required for those portions of the welds (R-A) within the examination boundaries of the intersecting circumferential welds

4. Reason for Request

UT examinations are performed from the inside surface of the RPV outlet nozzle-to-extension and extension-to-pipe and inlet nozzle-to extension and extension-to-elbow welds in accordance with the requirements of 10CFR50.55a, plant

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 2 of 13 Third Inservice Inspection Interval Relief Request Number 30 Technical Specifications, and the 1989 Edition, no Addenda of the ASME Section XI Code. 10CFR50.55a requires the UT equipment, procedures, and personnel to be qualified by performance demonstration in accordance with Appendix VIII of the 1995 Edition with the 1996 Addenda of ASME Section Xl Code. Appendix VIII, Supplement 2, as referenced by Supplement 3, paragraph 2.0 requires that the inside surface be concealed. This is not possible for demonstrations performed from the ID. The 2002 Addenda of ASME Section XI provided additional guidance for the conduct of demonstration activities when performed from the ID. However, 10CFR50.55a specifically prohibits the use of Appendix VIII and the Supplements to Appendix VIII and Article 1-3000 of Section XI of the ASME BPV Code, 2002 Addenda through the latest Edition and Addenda.

5. Proposed Alternative and Basis for Use Proposed Alternative:

Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested to implement the alternative paragraphs in Attachment 1 to the requirements of ASME Section XI, Appendix VIII, Supplement 2, as referenced by Supplement 3, of the 1995 Edition with the 1996 Addenda.

Basis for Use:

St. Lucie Unit 1 reactor coolant piping consists of nominal 42 inch ID, 3 3/16 inch minimum thick, hot leg piping and 30 inch ID, 3 inch minimum thick, cold leg elbows attached to the RPV nozzle safe-ends which are fabricated from carbon steel mill cladded with stainless steel. Examinations are performed from the inside surface of the piping.

The examinations of these welds are performed in conjunction with the 10-year RPV examinations from the inside surface using automated Ultrasonic examination techniques qualified in accordance with ASME Section XI, Appendix VIII, Supplement 3. The qualification requirements provided in ASME Section Xl, Supplement 2, as referenced by Supplement 3, do not provide allowances for demonstrations performed from the inside surface of the piping.

Prior to the issuance of the 2002 Addenda of ASME Section XI, the Performance Demonstration Initiative (PDI) administered demonstrations activities for ID examinations in accordance with Supplement 3 as modified by the PDI instructions. The PDI worked with the ASME Code to provide clarification of the intent of Section XI when demonstrations and examinations of carbon steel piping welds were to be performed from the ID. The result was the 2002 Addenda of ASME Section XI which provided additional guidance for the conduct of demonstration activities when performed from the ID. However, 10CFR50.55a specifically prohibits the use of Appendix VIII and the Supplements to Appendix VIII and Article 1-3000 of Section XI of the ASME BPV Code, 2002 Addenda

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 3 of 13 Third Inservice Inspection Interval Relief Request Number 30 through the latest Edition and Addenda. FPL's contractor, AREVA, qualified by demonstration from the ID, in accordance with PDI's implementation of Supplement 3, which is consistent with the requirements described in the 2002 Addenda of ASME Section Xl, Appendix VIII.

The automated ultrasonic techniques to be utilized for the examinations of the Reactor Coolant piping from the ID will have been qualified by demonstration in accordance with the requirements of Appendix VIII, Supplement 3, of the 1995 Edition with Addenda through 1996 of ASME Section XI and proposed alternatives by the Performance Demonstration Initiative (PDI). The use of techniques qualified from the inside surface provides assurance that the Reactor Coolant piping welds have remained free of service related flaws thus enhancing quality and ensuring plant safety and reliability.

6. Duration of Proposed Alternative FPL will implement the proposed alternative UT examinations from the inside surface of the RPV outlet nozzle-to-extension and extension-to-pipe and inlet nozzle-to extension and extension-to-elbow welds during the St. Lucie Unit 1 third 10-year Inservice Inspection interval.

7. Attachments to Relief Request 30 Attachment 1-Comparison of ASME Section XI, 1995 Edition with Addenda through 1996 and FPL alternatives

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 4 of 13 Third Inservice Inspection Interval Relief Request Number 30 "1u

,U *I"I::LC*I MI:* r_.W*UIMr_~-lNI:E Ia Qualificationtest specimens shall meet the requirements listed herein, unless a set of specimens is designed to accommodate specific limitations stated in the scope of the examination procedure (e.g., pipe size, access limitations). The same specimens may be used to demonstrate both detection and sizing qualification.

1.1 General. 1.1 General No Change The specimen set shall conform to the following Applicable to ferritic piping welds examined requirements. from either the inside (I.D.) or outside (O.D.) surface. The applicable qualification criteria shall be satisfied separately. The specimen set shall conform to the following requirements.

(a) Specimens shall have sufficient volume to No Change No Change minimize spurious reflections that may interfere with the interpretation process.

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 5 of 13 Third Inservice Inspection Interval Relief Request Number 30 (13) I ne specimen set snaii consist OT at least Tour (0) i ne specimen set snaii consist oT at specimens having different nominal pipe diameters least four specimens having different and thicknesses. The set shall include pipe nominal pipe diameters and thicknesses.

specimens not thicker than 0.1 in. more than the The set shall include pipe specimens not minimum thickness, nor thinner than 1.0 in. less than thicker than 0.1 in. (2.5 mm) more than the the maximum thickness for which the examination minimum thickness, nor thinner than 1.0 in.

procedure is applicable. It shall include the minimum (25 mm) less than the maximum thickness and maximum pipe diameters and thicknesses for for which the examination procedure is which the examination procedure is applicable. If the applicable. It shall include the minimum, procedure is applicable to pipe diameters of 24 in. within NPS 1/2, and maximum pipe (610 mm) or larger, the specimen set must include at diameter for which the examination least one specimen 24 in. (610 mm) or larger in procedure is applicable. If the procedure is diameter but need not include the maximum applicable to pipe O.D. of 24 in. (610 mm) diameter. or larger, the specimen set must include at least one specimen 24 in. O.D. (610 mm) or larger but need not include the maximum diameter (c) The specimen set shall include examples of the (c)Taking into consideration the accessible No Change following fabrication condition: scanning surface, the O.D. or I.D. specimen (1) unground weld reinforcement (crowns); set shall include applicable examples of the following fabrication conditions:

(1)unground weld reinforcement (crowns);

(2) wide crowns, such that the total crown width is 1 No Change No Change 1/2 to 2 times the nominal pipe wall thickness;

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 6 of 13 Third Inservice Inspection Interval Relief Request Number 30 ASME SectionX1, 1995 withAdenda through 1096 FLPooe Alenav 10CFRSO. 55a ch~ange (Supplement 2 with Sy ppposen Alternative r, reggirem en (3) geometric conditions that normally require (3)geometric conditions that normally No Change discrimination from flaws (e.g., counterbore, weld require discrimination from flaws (e.g.

root conditions such as excessive I.D. counterbore, weld root conditions such as reinforcement); excessive 1.D. reinforcement for O. D.

scans, or O.D. reinforcement for I.D. scans, as applicable);

(4) typical limited scanning surface conditions (e.g., (4)typical limited scanning surface No Change diametrical shrink, single-side access due to safe conditions (e.g. diametrical shrink, single-ends or fittings). side access due to safe ends or fittings, clad surfaces, or counterbore within the scanning area, as applicable).

(d) All flaws in the specimen set shall be cracks. No Change No Change (1) Mechanical fatigue cracks and thermal fatigue cracks shall be used. At least 75% of the sample set defects shall be mechanically or thermally induced fatigue cracks.

(2) At least 50% of the cracks shall be coincident with No Change No Change fabricated conditions described in (c) above.

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 7 of 13 Third Inservice Inspection Interval Relief Request Number 30

~AS E~Scti~~Xff9~5wit~Addnd~ hrouh I 96wFPL Proposed Alternative ~g

__(up leient 2 with Si~p Jement_3 inserted) ,- --- requiiremen~t~

1.2 Detection Specimens. The specimen set shall No Change No Change include detection specimens that meet the following requirements.

(a) Specimens shall be divided into grading units.

Each grading unit shall include at least 3 in. (76 mm) of weld length. If a grading unit is designed to be unflawed, at least 1 in. (25 mm) of unflawed material shall exist on either side of the grading unit. The segment of weld length used in one grading unit shall not be used in another grading unit. Grading units need not be uniformly spaced around the pipe specimen.

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 8 of 13 Third Inservice Inspection Interval Relief Request Number 30 NO unange NO unange

.i flF PERFC est ritera KNo. of U111ts Crft

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16. 12 < 3,2 17 12 is18 13 "K7' 19 13 38 20 40. el

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 9 of 13 Third Inservice Inspection Interval Relief Request Number 30 (b) Detection sets shall be selected from Table (L4tLJtL*LIULI bUl eIJUI I IbumIlI qudilIIlLIUI 1

VIIIS2-1. The number of unflawed grading units shall shall be selected from Table VIII-S2-1. The be at least twice the number of flawed grading units. number of unflawed grading units shall be at least twice the number of flawed grading units. For initial procedure qualification, detection sets shall include the equivalent of three personnel qualification sets. To qualify new values of essential variables, at least one personnel qualification set is required.

(c) Flawed grading units shall meet the following No Change No Change criteria for flaw depth, orientation, and type.

(1) A minimum of 1/3 of the flaws, rounded to the next higher whole number, shall have depths between 5% and 30% of the nominal pipe wall thickness. At least 1/3 of the flaws, rounded to the next higher whole number, shall have depths greater than 30% of the nominal pipe wall thickness.

(2) At least one and a maximum of 10% of the flaws, No Change No Change rounded to the next higher whole number, shall be oriented axially. The remainder of the flaws shall be oriented circumferentially.

(3) Service-induced flaws shall be included when No Change No Change available.

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 10 of 13 Third Inservice Inspection Interval Relief Request Number 30 1.S bizing bpecimens. I ne specimen set snaii 1.j stizing bpecimens. i ne specimen set iNJo .nange contain sizing specimens that meet the following shall contain sizing specimens that meet requirements. the following requirements.

(a) The minimum number of flaws shall be ten. (a)The minimum number of flaws shall be ten. For initial procedure qualification, sizing sets shall include the equivalent of three personnel qualification sets. To qualify new values of essential variables at least one personnel qualification set is required.

(b) Flaws in length sizing sample sets shall meet the No Change No Change requirements of para 1.2(c)(1), when given in conjunction with a detection test. When the length sizing test is administered independently, the flaw depth requirements do not apply.

(c) Flaws in the depth sizing sample set shall be No Change No Change distributed as follows:

Flaxro Depth Minlimumif (14 Wall ckness) Number ofFlw 5-30%200%

The remaining flaws shall be in any of the above categories.

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment

.Page 11 of 13 Third Inservice Inspection Interval Relief Request Number 30 Z.U ;UNUU; I UI- I"1-UIVMANL;I Z.u LUUNUUL I Ur r-'-UIKMANUL.

DEMONSTRATIONS DEMONSTRATIONS The specimen inside surface and identification shall When scanning from the O.D., the be concealed from the candidate. All examinations specimen inside surface and identification shall be completed prior to grading the results and shall be concealed from the candidate.

presenting the results to the candidate. Divulgence of When scanning from the I.D., flaw location particular specimen results or candidate viewing of and specimen identification shall be unmasked specimens after the performance obscured to maintain a "blind test". All demonstration is prohibited. examinations shall be completed prior to grading the results and presenting the results to the candidate. Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited.

2.1 Detection Test. Flawed and unflawed grading No change No Change units shall be randomly mixed.

2.2 Length and Depth Sizing Test 2.2Length and Depth Sizing Test No Change (a) For the length sizing test, the regions of each (a)Each reported flaw in the detection test specimen containing a flaw to be sized shall be shall be length sized. When only length identified to the candidate. The candidate shall sizing is being tested, the regions of each determine the length of the flaw in each region. specimen containing a flaw to be sized may be identified to the candidate. The candidate shall determine the length of the flaw in each region.

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 12 of 13 Third Inservice Inspection Interval Relief Request Number 30 (b) For the depth sizing test, 80% of the flaws shall (U) IIie uUpmi sizirgy test [fay DUe peirmur[ieu be sized at a specific location on the surface of the in conjunction with or separate from the specimen identified to the candidate. For the detection test. When only depth sizing is remaining flaws, the regions of each specimen being tested, the regions of each specimen containing a flaw to be sized shall be identified to the containing a flaw to be sized may be candidate. The candidate shall determine the identified to the candidate. The candidate maximum depth of the flaw in each region. shall determine the maximum depth of the flaw in each region.

3.0 ACCEPTANCE CRITERIA 3.OACCEPTANCE CRITERIA No Change 3.1 Detection Acceptance Criteria. Examination 3.1 Detection Acceptance procedures, (a)Personnel demonstration shall meet the equipment, and personnel are qualified for detection requirements of Table VIII-S2-1 for both when the results of the performance demonstration detection and false calls.

satisfy the acceptance criteria of Table VIIIS2-1 for (b)Procedure qualifications shall both detection and false calls. demonstrate detectability of each flaw within the scope of the procedure.

Successful personnel demonstrations may be combined to satisfy the requirements for procedure qualification.

3.2 Sizing Acceptance Criteria. Examination No Change No Change procedures, equipment, and personnel are qualified for sizing if the results of the performance demonstration satisfy the following criteria:

(a) The RMS error of the flaw lengths estimated by ultrasonics, as compared with the true lengths, shall not exceed 0.75 in. (19 mm);

St. Lucie Unit 1 L-2008-014 Docket No. 50-335 Attachment Page 13 of 13 Third Inservice Inspection Interval Relief Request Number 30 ASME Secation 1995 withrAdendathrough 19966 1' cheng FPL Pooe lentv (Supplement 2with Suplement 3 inserted) ICrequirement~a (b) The RMS error of the flaw depths estimated by No Change No Change ultrasonics, as compared with the true depths, shall not exceed 0.125 in. (3.2 mm).

SUPPLEMENT 3 - QUALIFICATION No Change No Change REQUIREMENTS FOR FERRITIC PIPING WELDS Qualification of examination procedures, equipment, and personnel for ferritic pipe examination shall be accomplished by satisfying the requirements of Supplement 2, except that the sample material shall be ferritic and 75% of the sample set defects shall be mechanically or thermally induced fatigue cracks. In addition, the set shall include pipe specimens not thicker than 0.1 in. (2.5 mm) more than the minimum thickness, nor thinner than 1.0 in. (25 mm) less than the maximum thickness for which the examination procedure is applicable.