L-2012-344, Inservice Inspection Plan Third Ten-Year Interval Unit 2 Relief Request No. 13, Revision 02
| ML12250A667 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 09/01/2012 |
| From: | Katzman E Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2012-344 | |
| Download: ML12250A667 (42) | |
Text
0FPLo September 1, 2012 L-2012-344 10 CFR 50.4 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re:
St. Lucie Unit 2 Docket No. 50-389 Inservice Inspection Plan Third Ten-Year Interval Unit 2 Relief Request No. 13, Revision 02 On June 11, 2012, Pursuant to 10 CFR 50.55a(a)(3)(ii), Florida Power & Light (FPL) requested relief from the 10 CFR 50.55a(g)(6)(ii)(F)(4) exception to ASME Code Case N-770-1 that essentially 100% coverage be achieved for the baseline required volumetric examinations. On July 13, 2012, the NRC provided an email containing a draft request for additional information (RAI) to the relief request 13 submittal. On August 10, 2012, a telecom was held with NRC reviewers to discuss the RAIs. and the nature of FPL's proposed responses. The Staff's issues were addressed in the attached revision to the relief request.
Please contact Ken Frehafer at (772) 467-7748 if there are any questions about this submittal.
Sincerely, Eric S. Katzman Licensing Manager St. Lucie Plant Attachment ESK/KWF Florida Power & Light Company
ý0 I 6501 S. Ocean Drive, Jensen Beach, FL 34957
L-2012-344 1 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Relief Request In Accordance with 10 CFR50.55a(a)(3)(ii)
--Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety--
- 1.
ASME Code Component(s) Affected Class 1 pressure retaining dissimilar metal piping welds containing Alloy 82/182.
American Society of Mechanical Engineers (ASME) Code Case N-770-1, Table 1, Examination Categories, Inspection Item B - Unmitigated butt weld at cold leg operating temperature.
- 2.
Applicable Code Edition and Addenda
The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1998 Edition with Addenda through 2000 [1] as amended by 1 0CFR50.55a,[21 is the code of record for the St. Lucie Unit 2, 3rd 10-year interval.
10CFR50.55a(g)(6)(ii)(F)(1), effective date August 22, 2011, requires "licensees of existing, operating pressurized water reactors as of July 21, 2011, shall implement the requirements of ASME Code Case N-770-1, subject to the conditions specified in paragraphs (g)(6)(ii)(F)(2) through (g)(6)(ii)(F)(10) of this section, by the first refueling outage after August 22, 2011."
Additionally, 10CFR50.55a(g)(6)(ii)(F)(3) states that the baseline examinations for welds in Code Case N-770-1, Table 1, Inspection Item B, "shall be completed by the end of the next refueling outage after January 20, 2012. Previous examinations of these welds can be credited for baseline examinations if they were performed within the re-inspection period for the weld item in Table 1 using Section X1, Appendix VIII requirements and met the Code required examination volume of essentially 100 percent. Other previous examinations that do not meet these requirements can be used to meet the baseline examination requirement, provided NRC approval of alternative inspection requirements in accordance with paragraphs (a)(3)(i) or (a)(3)(ii) of this section is granted prior to the end of the next refueling outage after January 20, 2012."
L-2012-344 2 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2
- 3.
Applicable Code Requirement
ASME Code Case N-770-1 as Amended by 10CFR50.55a6(g)6)(ii)(F)(4).
CLASS 1 PWR Pressure Retaining Dissimilar Metal Piping and Vessel Nozzle Butt Welds Containing Alloy 82/182 Insp Parts Examined Item Extent and Frequency of Examination Bare metal visual examination once per interval Unmitigated butt weld at Cold Leg Essentially 100% volumetric examination for axial and operating B
circumferential flaws in accordance with the applicable temperature (-2410) requirements of ASME Section Xl, Appendix VIII, every
> 525°F (274°C) and second inspection period not to exceed 7 years. Baseline
< 580'F (304'C) examinations shall be completed by the end of the next refueling outage after January 20, 2012.
As defined by ASME Code Case N-460,j31 essentially 100% means greater than 90% of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.
ASME Section XI, Appendix VIII, Supplement 10, "Qualification Requirements for Dissimilar Metal Piping Welds" is applicable to dissimilar metal welds without cast materials.
ASME Section XI, Appendix VIII, states that the supplement for the examination of cast stainless steel is "in the course of preparation".
- 4.
Reason for Request
Florida Power and Light is requesting permission to utilize the Ultrasonic examinations performed in accordance with MRP-1 39 [4] during the 2011 (SL2-19) outage to satisfy the baseline examination requirements of 10CFR50.55a(g)(6)(ii)(F)(3). However, the welds listed within this request did not satisfy the required ASME Code Case N-770-1, as amended by 10CFR50.55a(g)(6)(ii)(F)(3), volume coverage due to their configuration.
The scanning limitations prohibited essentially 100% ultrasonic examination coverage of the required examination volume.
10CFR50.55a(g)(6)(ii)(F)(4) provides the following exception to ASME Code Case N-770-1, "the axial examination coverage requirements of -2500(c) may not be considered to be satisfied unless essentially 100 percent coverage is achieved."
Relief is requested from the 10CFR50.55a(g)(6)(ii)(F)(4) exception to ASME Code Case N-770-1 that essentially 100% coverage be achieved for the baseline volumetric examinations.
L-2012-344 3 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2
- 5.
Proposed Alternative and Basis for Use Proposed Alternative
- 1) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1.
- 2) Ultrasonic examinations conducted to the maximum extent possible.
- 3) During refueling outages, system engineers walkdown Class 1 systems inside containment. This walkdown was performed to look for system anomalies that could affect plant performance. These examinations identified no evidence of leakage for these components.
- 4) Bare metal visual examinations of the Inspection Item B welds in accordance with ASME Code Case N-722-1. Those examinations identified no evidence of leakage for these components. The combination of these examinations provides confidence that an acceptable level of quality and safety has been maintained.
Basis FPL's, St. Lucie unit 2 contains a thirty (30) inch I.D. inlet and a thirty (30) inch I.D. outlet weld connected to each of the four (4) reactor coolant pumps (RCPs). Each weld joins mill-clad SA-516, Grade 70 carbon steel pipe with SA-240-304L stainless steel cladding to a SA-351, Grade CF8M cast stainless steel safe end.
All of the welds covered by this relief request are found in cold leg temperature (TooId) regions of the system. This means there is a lower probability of crack initiation, and a slower crack growth rate. These welds are also very highly flaw tolerant, as demonstrated in the MRP-109 report.151 No service-induced flaws have been found in these large diameter pipes, even though most of the plants of interest have been in service for over 25 years. [6,7]
Examinations of the eight (8) reactor coolant pump inlet/outlet dissimilar metal welds were performed during previous intervals utilizing manual conventional ultrasonic techniques in accordance with the requirements of ASME Section XI, Category B-F.
These examinations were performed prior to the requirement to implement ASME Section XI, Appendix VIII, Supplement 10 qualified equipment, procedures, and personnel. No indications were identified during the previous interval examinations.
During the 2011 (SL2-19) outage, examinations were performed of the eight (8) reactor coolant pump inlet/outlet dissimilar metal welds utilizing a manual non-encoded phased array Ultrasonic (UT) technique.
In all cases, examination was performed from the carbon steel side of the weld.
No indications were identified.
The equipment, procedure, and personnel utilized for the performance of the examinations were qualified in accordance with the requirements of ASME Section XI, Appendix VIII, Supplement 10, as implemented through the Performance Demonstration Initiative (PDI) program.
L-2012-344 4 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Because the examination of the RCP inlet/outlet configuration is included in the PDI sample set, a site specific mock-up was not applicable for these weld examinations.
Prior to the issuance of the revised final rule 10CFR50.55a (effective date August 22, 2011) that includes the requirement to implement the requirements of ASME Code Case N-770-1 as amended, the Materials Reliability Program issued "Primary System Piping Butt Weld Inspection and Evaluation Guidelines (MRP-139)" that included mandatory elements per the implementation protocol of the Nuclear Energy Institute (NEI) 03-08 initiative. The guideline provided a strategy to manage degradation of butt welds with alloy 82/182 in primary system piping that are 1" NPS or greater and exposed to temperatures greater than or equal to cold leg temperature. The guideline was structured to categorize weld inspections to acknowledge mitigation, temperature, safety significance of flaw orientation, and inspection capabilities.
The guideline defined examination locations on the piping, examination requirements for various weld categories, and extent of examination for each location. Finally, the guideline provided evaluation procedures to determine acceptance of flaws, justification for mitigation actions, and changing examination categories.
MRP-139 delineated acceptable coverage of the required examination volume to be calculated separately for axial and circumferential flaw orientations using the actual weld configuration and the procedure's essential variables, if needed. Coverage calculations could be made by manual plotting or by using computer-aided design (CAD) or other software that models the procedure's beam angles and scan plans.
" The inspection was considered complete when, using the qualified procedure and personnel, the coverage for both axial and circumferential flaws was greater than 90% of the required examination volume.
If >90% coverage for circumferential or axial flaws was not attained then the following independent actions were required:
- If greater than 90% coverage for circumferential flaws could not be met (using qualified personnel and procedures), then specific actions described within the document were required.
- If greater than 90% coverage for axial flaws could not be met, but greater than 90%
coverage was obtained for circumferential flaws (using qualified personnel and procedures), then the examination for axial flaws would be completed to achieve the maximum coverage possible with limitations noted in the examination report.
The UT techniques proposed for each weld were reviewed to determine the amount of examination coverage that could be achieved.
Extensive surface conditioning was performed to obtain the maximum amount of coverage. As a result, essentially 100% of the susceptible material in all 8 welds was examined for circumferential flaws.
However, due to the weld taper and no access for examination from the cast CF8M safe-end side of the welds, limited examination volume coverage was noted for axial flaws.
L-2012-344 5 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Therefore, FPL satisfied the examination volume coverage requirements identified in MRP-139.
The amount of coverage credited was determined in accordance with the qualified examination procedure utilizing field obtained contours. The qualified procedure provides the following for the determination of examination volume coverage:
For axial beam directions (circumferential flaws), coverage of the examination volume is based on the a minimum ID impingement angle of 40 to 50 degrees.
The sound beam was directed essentially perpendicular to the weld axis utilizing a raster scan pattern that provided a minimum of 50% overlap of the transmitting element in the indexing direction.
Procedurally, if the weld crown cannot be conditioned to an acceptable level, coverage of the non-cast or accessible portion of the examination volume can be claimed from the base material, without scanning on top of the weld provided the procedurally defined angles cover the required examination volume. Scanning was performed from the carbon steel side only.
For circumferential beam directions (axial flaws), coverage of the examination volume is based upon ID impingement angles between 45 and 60 degrees. The sound beam was directed essentially parallel to the weld axis in both the clockwise and counter-clockwise directions utilizing a raster scan pattern that provided a minimum of 50% overlap of the transmitting element in the indexing direction. Additionally, the search unit was physically skewed into the weld centerline at angles between 0 and 30 degrees for both the clockwise and counterclockwise scan directions. Scanning was performed from the carbon steel side only.
Procedurally, coverage could be claimed up to the weld centerline from the non-cast side provided the center point of the ultrasonic beam was capable of intersecting this area.
Qualification for the UT examination of the cast material is "in the course of preparation."
No coverage is claimed in the cast material for the MRP-139 or ASME Code Case N-770-1 exam volume in Table 1, since access for scanning was not available from the cast side of the weld, and the qualified procedure specifically excludes cast materials in the coverage calculation. However, as shown in the figures, the theoretical beam path extends into the cast material for the examinations performed from the carbon steel side of the weld. While the coverage is not included in the Table, UT examinations conducted using Appendix VIII qualified procedures also provide reasonable assurance for the detection of flaws on the cast side of dissimilar metal welds, even though there is presently no standardized process to qualify them.
For the MRP-139 axial and circumferential flaw examination volume coverage achieved, the calculation includes the carbon steel base material and susceptible material. For the ASME Code Case N-770-1 axial and circumferential flaw examination volume coverage achieved, the calculation includes the volume identified in Figure 1 of the code case which, in the case of St. Lucie unit 2, includes cast stainless steel.
L-2012-344 6 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Table 1 provides the percent of coverage credited for MRP-1 39, Code Case N-770-1 (as described above), and references specific figures that illustrate the extent of coverage for each weld. The angles, ultrasonic wave modes (Shear-S or Longitudinal-L) that were employed for the manual non-encoded phased array examinations, and limitations encountered are listed for each weld.
Arrows and lines on the figures illustrate the phased array search unit beam direction and extent of the area examined.
The examination volume coverage for MRP-139 included the susceptible material and carbon steel base material. As shown in Table 1, essentially 100% of the examination volume coverage for the safety significant circumferential flaw in the susceptible material and carbon steel base material was achieved during the MRP-139 examinations. In all cases, the ID surface of the susceptible material was interrogated for circumferential flaws with the ultrasonic beam based upon ID impingement angles between 40 to 50 degrees. A small amount of the upper portion of the coverage box for welds RC-1 15-701-771 (Figure 4b) and RC-121-1501-771-B (Figure 5b) was not interrogated for circumferential flaws with the ultrasonic beam due to the weld taper. Additionally, portions of the carbon steel base material examination volume were not interrogated for circumferential flaws with the ultrasonic beam for a circumferential distance of 6.80" for weld RC-121-901-771 (Figure 6c) and 5.70" for weld RC-124-1301-771 (Figure 8c) due to the proximity of the spray nozzles.
Due to the guidance included in the Appendix VIII qualified procedure for single sided access configurations, the MRP-139 axial flaw examination volume coverage did not satisfy the essentially 100% requirement. In all cases, the ID surface of the susceptible material for the examination volume that could be credited for axial flaws was interrogated with the ultrasonic beam. Additionally, the attached sketches illustrate that the theoretical beam path extends past the centerline covering the remainder of the susceptible material and into the cast material for the examinations based upon ID impingement angles between 45 and 60 degrees.
As identified in MRP-109 [5], the axial flaw(s) that could result from a primary water stress corrosion cracking (PWSCC) mechanism in the susceptible alloy 82/182 butt weld are not safety significant.
The axial critical flaw length for an RCP inlet and outlet alloy 82/182 butt weld is 38.2" (MRP-1 09 Table 5-2) which exceeds the width of the St. Lucie Unit 2 RCP inlet and outlet alloy 82/182 butt weld material width of 1.75"-2.5". Therefore a critical axial flaw in an RCP inlet or outlet alloy 82/182 butt resulting from a PWSCC mechanism is not credible and improving the exam axial flaw examination volume coverage would not result in an increase in safety.
During the St. Lucie Unit 2 2011 refueling outage, examination volume coverage for the RCP inlet and outlet welds was extensively improved by grinding and contouring to meet the ASME Section Xl, Appendix VIII, Supplement 10 qualified procedure scanning requirements for the search units. Further contouring is limited by design minimum wall calculations for the piping. To obtain acceptable surface contour conditions for axial flaw examinations, weld build up of the DM weld, additional contouring, and a Construction Code RT examination would be required.
This additional effort to improve axial flaw
L-2012-344 7 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 coverage would be a hardship that would not result in an increase of health and safety to the public.
As stated above, the initiation or growth of a safety significant flaw in a cold leg alloy 82/182 DM butt weld is extremely unlikely. However, as an added measure of safety, the industry imposed an NEI-03-08 "needed" requirement, to improve their RCS leak detection capability in part due to the concern with PWSCC.
St. Lucie Unit 2 has adopted the standardized approach to measuring RCS leak rate in WCAP-16423 [8] and has proceduralized the action levels in WCAP-16456J 91 The enhanced leak rate monitoring and detection procedure monitors specific values of unidentified leakage, seven day rolling average, and baseline means. Action levels are initiated as low as when the unidentified leak rate exceeds 0.1 gpm.
The enhanced leak detection capability provides an increased level of safety that if a flaw were to grow through wall, although unlikely, that is would be detected prior to it growing to a safety significant size.
Therefore, examination coverage meeting the MRP-139 volume, which includes essentially 100% of the susceptible material for the safety significant circumferential flaw and a significant percentage of the susceptible material for the non safety significant axial flaw (Attachment 1) combined with the periodic system pressure tests and outage system walk downs, provides an acceptable level of qualify and safety for identifying degradation from PWSCC prior to a safety significant flaw developing.
- 6.
Duration of Proposed Alternative This relief request is applicable to the St. Lucie unit 2 Third Inservice Inspection Interval which began August 8, 2003 and ends August 7, 2013.
- 7.
References
- 1. ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components,"
1998 Edition with Addenda through 2000.
- 2. Nuclear Regulatory Commission Federal Register part II, Vol. 76, No. 119, effective date August 22, 2011, 10 CFR part 50 Industry Codes and Standards; Amended Requirements; Final Rule.
- 3. ASME Section XI, Division 1, Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1."
- 4. Material Reliability Program: Primary System Piping Butt Weld Inspection and Evaluation Guideline (MRP-139, Revision 1), EPRI, Palo Alto, CA: 2008. 1015009.
- 5. Material Reliability Program, Alloy 82/182 Pipe Butt Weld Safety Assessment for US PWR Plant Designs (MRP-109): Westinghouse and CE Design Plants, EPRI, Palo Alto, CA: 2005. 1009804.
L-2012-344 8 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2
- 6. "Changing Frequency of Inspections for PWSCC Susceptible Welds at Cold Leg Temperatures", in Proceedings of 2011 ASME Pressure Vessels and Piping Conference, July 17-21, 2011, Baltimore, Maryland, USA.
- 7. "Technical Basis for a Flaw tolerance Option for Code Case N-770-1 for Large Diameter Cold Leg Piping to Main Coolant Pump Welds, with Obstructions", in Proceedings of 2010 ASME Pressure Vessels and Piping Division Conference, July 2010, Bellevue, WA, USA.
- 8. WCAP-16423-NP, Rev. 0, "Pressurized Water Reactor Owners Group Standard Process and Methods for Calculating RCS Leak Rate for Pressurized Water Reactors,"
Westinghouse Electric Co., September 2006.
- 9. WCAP-16456-NP, Rev. 0, "Pressurized Water Reactor Owners Group Standard RCS Leakage Action Levels and Response Guidelines for Pressurized Water Reactors,"
Westinghouse Electric Co., September 2006.
L-2012-344 9 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Table 1 MRP-1 3 9 [1j N-770-1 VI Noz Insp Volume Volume Angle/
Comments/
Component ID Location Size Item Coverage Coverage Wave Fig.
Limitations Cat Axial Circ Axial Circ Mode Flaw Flaw Flaw Flaw RCP 2A1 Inlet la RC-112-1501-771-C Elbow(CS) to Safe-end (Cast 30 B
69%
100%
50%
73%
25-70L lb Cast SS, Weld SS)35-65S C
Taper RCP 2A1 Outlet Safe-end 25-70L 2a Cast SS, Weld RC-l 12-1066-771 (Cast SS) to Pipe(CS) 30 B
66%
100%
49%
74%
2b Taper 2c RCP 2A2 Inlet 25-70L 3a Cast SS, Weld RC-1 15-1501-771-A Elbow(CS) to Safe-end (Cast 30 B
64%
100%
52%
82%
35-65S 3b SS) 3c RCP 2A2 Outlet 25-70L 4a Cast SS, Weld RC-1 15-701-771 Safe-end (Cast SS) to Pipe 30 B
68%
97%
49%
71%
4b (CS) 4c RCP 2B1 Inlet 25-70L 5a Cast SS, Weld RC-121-1501-771-B Elbow (CS) to Safe-end (Cast 30 B
66%
99%
52%
78%
S5b Taper SS)35-65S 5c RCP 2B1 Outlet 25-70L 6a Cast SS, Weld RC-121-901-771 Safe-end (Cast SS) to Pipe 30 B
64%
99.4%
51%
77.9%
35-65S thru Taper, Spray (CS) 6q Nozzle RCP 2B2 Inlet 25-70L 7a, Cast SS, Weld RC-124-1501-771-D Elbow (CS) to Safe-end (Cast 30 B
67%
100%
49%
72%
7b, Taper SS)35-65S 7c RCP 2B2 Outlet 25-70L 8a Cast SS, Weld RC-124-1301-771 Safe-end (Cast SS) to Pipe 30 B
66%
99.1%
50%
77%
35-65S thru Taper, Spray (CS) 8g Nozzle 1 -_LPr h=
,RA1VP_1 X-1 vinl nnr I
t rirrI tmfotroInfinl flutl l=J IXminnfinn vih ImI rHrwarn a nrhiaxiorl the% r-nlr "
finn inrl, I
ial fha I
nJrhnn KIM,=
cfaal base material and susceptible material.
Note 2-For the ASME Code Case N-770-1 axial and circumferential flaw examination volume coverage achieved, the calculation includes the volume identified in Figure 1 of the code case.
L-2012-344 10 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 0.25 -jý MRP-139 Inspection Examination Volume (1.98 sq. in.)
Cast SST Inspection Examination Volume
(.73 sq. in.)
ASME Section XI Inspection Examination Volume (Cast SST + MRP-139)
(2.71 sq. in.)
Figure la 2A1 RCP Inlet (RC-1 12-1501-771-C)
L-2012-344 11 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Axial Scans (Circumferential Flaws) 100% Coveraqe -MRP-139 Exam Volume 73% Coverage-ASME Exam Volume ((2.71-.73)/2.71" 100)
(Cast SS exam volume excluded)
Figure lb 2A1 RCP Inlet (RC-1 12-1501-771-C)
L-2012-344 12 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 MRP-139 Inspection Examination Volume Limitation (per EPRI-DMW-PA-1 exam volume can be claimed up to weld centerline) (.62 sq. in.)
Circ Scans (Axial Flaws) 69% Coverage-MRP-139 Volume ((1.98-.62)/1.98*100) 50% Coverage-ASME Exam Volume (2.71-.62-.73)/2.71-100)
(cast SS exam volume excluded; exams not conducted on weld due to taper)
Figure 1c 2A1 RCP Inlet (RC-1 12-1501-771-C)
L-2012-344 13 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 ASE ecio X Ispcto DM Weldiý Cast SST CS Pipe (2.642 sq. in.)
(.8s.i.
ASMEi Section XInspectiono Examination Volume (Cast SST + MRP-139)
(2.42 sq. in.)
Figure 2a 2A1 Outlet (RC-112-1066-771)
L-2012-344 14 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Axial Scans (Circumferential Flaws) 100% Coverage - MRP-139 Exam Volume 74% Coverage - ASME Exam Volume ((2.42 - 0.64)y2.42 *100)
(cast SS exam volume excluded)
Figure 2b 2A1 Outlet (RC-1 12-1066-771)
L-2012-344 15 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 MRP-139 Inspection Examination Volume Limitation (per EPRI-DMW-PA-1 exam volume can be claimed up to weld centerline) (0.60 sq. in.)
Circumferential Scans (Axial Flaws) 66% Coverage - MRP-139 Exam Volume ((1.78-0.60)/1.78
- 100) 49% Coveraqe - ASME Exam Volume ((2.42-0.64-0.60)12.42
- 100)
(cast SS exam volume excluded, exams not conducted on weld due to taper)
Figure 2c 2A1 Outlet (RC-112-1066-771)
L-2012-344 16 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 CS Elbow DM Cast SST Weld Safe End MRP-139 Inspection Examination Volume (2.65 sq. in.)
Cast SST Inspection Examination Volume
(.60sq. in.)
ASME Section XI Inspection Examination Volume (Cast SST + MRP-139)
(3.25 sq. in.)
Figure 3a 2A2 Inlet (RC-115-1501-771 -A)
L-2012-344 17 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Axial Scans (Circumferential Flaws) 100% Coverage -MRP-139 Exam Volume 82% Coveraqe-ASME Exam Volume ((3.25-.60)/3.25*100)
(Cast SS exam volume excluded)
Figure 3b 2A2 Inlet (RC-115-1501-771 -A)
L-2012-344 18 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 MRP-139 Inspection Examination Volume Limitatior (per EPRI-DMW-PA-1 exam volume can be claimed up to weld centerline) (. 96 sq. in.)
Circ Scans (Axial Flaws) 64% Coveraqe-MRP-139 Volume ((2.65-.96)/2.65*100) 52% Coverage-ASME Exam Volume (3.25-.96-.60)/3.25*100)
(cast SS exam volume excluded; exams not conducted on weld due to taper)
Figure 3c 2A2 Inlet (RC-115-1501-771-A)
L-2012-344 19 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 0.25 L~0.25 DM CS Cast SST Safe End Weld I l I /
/ t
/ /
I I Pipe Cast SST Inspection Examination Volume
(.61 sq. in.)
MRP-139 Inspection Examination Volume (1.63 sq. in.)
Examination Volume (Cast SST + MRP-1 39)
(2.24 sq. in.)
Figure 4a 2A2 Outlet (RC-115-701-771)
L-2012-344 20 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 MRP-139 Inspection Examination_,ý-
Volume Limitation (.048 sq. in.) -
j
~//
t/
Axial Scans (Circumferential Flaws) 97% Coverage -MRP-1 39 Exam Volume ((1.63-.048)/1.63*100) 71% Coverage-ASME Exam Volume ((2.29-.048-.61)/2.29*100)
(Cast SS exam volume excluded)
Figure 4b 2A2 Outlet (RC-115-701-771)
L-2012-344 21 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 MRP-139 Inspection Examination Volume Limitation-(per EPRI-DMW-PA-1 Rev. 1; exam volume can be claimed up to weld centerline)
(.53 sq. in.)
Circ Scans (Axial Flaws) 68% Coverage-MRP-1 39 Volume ((1.63-.53)/1.63*100) 49% Coverage-ASME Exam Volume (2.24-.53-.61)/2.24*100)
(cast SS exam volume excluded; exams not conducted on weld due to taper)
Figure 4c 2A2 Outlet (RC-115-701-771)
L-2012-344 22 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Oý25 MRP-139 Inspection Examination Volume (1.94 sq. in.)
Cast SST Inspection Examination Volume
(.53 sq. in.)
ASME Section XI Inspection Examination Volume (Cast SST + MRP-139)
(2.47 sq. in.)
Figure 5a 2B1 Inlet (RC-121-1501-771-B)
L-2012-344 23 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2
\\MRP-139 Inspection Examination Volume Limitation
(.01 sq. in.)
Axial Scans (Circumferential Flaws) 99%Coveraae -MRP-139 Exam Volume ((1.94-.01)/1.94*100) 78% Coveraae-ASME Exam Volume ((2.47-.53-.01)/2.47*100)
(Cast SS exam volume excluded)
Figure 5b 2B1 Inlet (RC-121-1501-771-B)
L-2012-344 24 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 MRP-139 Inspection Examination Volume Limitation (per EPRI-DMW-PA-1 exam volume can be claimed up to weld centerline) (.65 sq. in-)
Circ Scans (Axial Flaws) 66% Coveraae-MRP-139 Volume ((1.94-.65)/1.94*100) 52% Coveraae-ASME Exam Volume( 2. 4 7-.65-.5 3 )/2.7 1*100)
(cast SS exam volume excluded: exams not conducted on weld due to taper)
Figure 5c 2B1 Inlet (RC-121-1501-771-B)
L-2012-344 25 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 0.25
/
Cast SST Inspection Examination Volume
(.54 sq. in.)
MRP-139 Inspection Examination Volume (1.97 sq. in.)
Examination Volume (Cast SST + MRP-1 39)
(2.51 sq. in.)
Figure 6a 2B1 Outlet (RC-121-901-771)
L-2012-344 26 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 All four contours allow the transducer to be scanned over part of the weld: thus impingement of the MRP examination volume with beam angles between 40 and 50 degrees is practical with no limitation.
Adal Scans (Circumferential Flaws) 99.4% Coverage-MRP-139 Exam Volume (see detailed evaluation) 77,9% Coverage-ASME Exam Volume 4 2.51-.542.51'1 00-(1 00-994 ))
(cast SS exam volume excluded)
MRP-1 39 examination volume coverage over total OD circumference with no obsturctions=91.5"M1.97 sq in.=180.3 cu. in.
% of total MRP-139 examination volume outside of obstmucted areas= 180.3/191.5*100=94.2%
% M RP-1 39 exam iantion volume coveraje around Spray Nozzle = 4.95*2=9.9 cu in: 9.9/191 -51 00=5.2%
% MRP-139 examination volume coverage in obsturoted area =5.2%
Total % Examination Coverage of MRP-139 Examination Volume=94% 5.2%=99.4%
Figure 6b 2B1 Outlet (RC-121-901-771)
L-2012-344 27 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 (0
j a-e~ialul PuJ3 ajeS PaS ssaluI0~ S0D/PAA aUlpa~U03 PPaM (A
0 r
0 0
=
-i Spray Nozzle
/
/
Figure 6c 2B1 Outlet (RC-121-901-771)
L-2012-344 28 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Axial Scan Line (Circumferential Flaws) Cross-Section @ Position A & Position E 100% Coverage-MRP-139 Exam Volume ((1.97 sq. in./1.97 sq. in.)*100) 78% Coverage-ASME Exam Volume ((1.97 sq. in./2.51 sq. in.)*100)
Figure 6d 2B1 Outlet (RC-121-901-771)
L-2012-344 29 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2
-1.82 Spray Nozzle Obstruction
-1.66 sq. in.
Axial Scan Line (Circumferential Flaws) Cross-Section @ Position B & Position D 84% Coverage-MRP-139 Exam Volume ((1.66 sq. in./1.97 sq. in.)*100) 66% Coverage-ASME Exam Volume ((1.66 sq. in./2.51 sq. in.)*100)
Figure 6e 2B1 Outlet (RC-121-901-771)
L-2012-344 30 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 1.65 ---1 1 Spray Nozzle Obstruction 1.49 sq. in.
i X
Axial Scan Line (Circumferential Flaws) Cross-Section @ Position C 76% Coverage-MRP-1 39 Exam Volume ((1.49 sq. in./1.97 sq. in.)*1 00) 59% Coverage-ASME Exam Volume ((1.49 sq. in./2.51 sq. in.)*1 00)
Figure 6f 2B1 Outlet (RC-121-901-771)
L-2012-344 31 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2
-MRP-139 Inspection Examination Volume Limitation (per EPRI-DMW-PA-1 exam volume can be claimed up to weld centerline) (.70 sq. in.)
Circ Scans (Axial Flaws) 64% Coverage-MRP-139 Volume ((1. 9 7 -.70)/1. 9 7 *100) 51% Coveraqe-ASME Exam Volume( 2 51-.54 -.7 0)/2.51* 100)
(cast SS exam volume excluded; exams not conducted on weld due to taper)
Figure 6g 2B1 Outlet (RC-121-901-771)
L-2012-344 32 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 rARP-139 Inspection Ex amination Volume (1.66 sq. in.)
ASM E Section XI Inspection Exarrination Volurne (Cast SST + MRP-139g (229 sq. in.)
Figure 7a 2B2 Inlet (RC-124-1501-771-D)
L-2012-344 33 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Axial Scans (Circumferential Flaws) 100% Coveraae -MRP-139 Exam Volume 72% Coverage-ASME Exam Volume(( 2.29-. 6 3 )/2.2 9 *100)
(Cast SS exam volume excluded)
Figure 7b 2B2 Inlet (RC-124-1501-771-D)
L-2012-344 34 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 N1 M RP-1 39 Inspection Examination Volume Limitatik (per EPRI-DMW-PA-1 exam volume can be claim to weld centerline) (.54 sq. in.)
Circ Scans (Axial Flaws 67% Coverage-MlRP-1 39 Volume ((1.66-.54)111.66*100) 49% Coveraae-ASME Exam Volume (2.29-.54-.63)V2.29 t 100)
(cast SS exam volume excluded; exams not conducted on weld due to taper)
Figure 7c 262 Inlet (RC-124-1501-771-D)
L-2012-344 35 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 0.25 SDM We'd f
Cast SST L
i t
CS Pipe I
I I
I i I
I p
j I
I t
2 ---
Cast SST Inspection Examination Volume MRP-139 Inspection (0.64 sq. in.)
Examination Volume ASME Section X1 Inspection (1.98 sq. in.)
Examination Volume (Cast SST + MRP-139)
(2.62 sq. in.)
Figure 8a 2B2 Outlet (RC-124-1301-771)
L-2012-344 36 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 All four contours allow the transducer to be scanned over part of the weld; thus impingement of the MRP examination volume with beam 1
angles between 40- and 50-degrees is practical with no limitation.
Axial Scans (Circumferential Flaws) 99.1% Coverage - MRP-139 Exam Volume (see detailed evaluation) 77% Coveraqe - ASME Exam Volume ((2.62 - 0.64)/2.62 *100 - (100 - 99.1))
(cast SS exam volume excluded)
MRP-1 39 examination volume coverage over total OD circumference with no obstructions = 90.4"
- 1.98 sq. in. = 179 cu in
% of total MRP-139 examination volume outside of obstructed areas = 179/189.3
- 100 = 94.6%
% MRP-139 examination volume coverage around Spray Nozzle = 4.25
- 2 = 8.5 cu in; 8.51189.3
- 100 = 4.5%
% MRP-139 examination volume coverage in obstructed areas = 4.5%
Total % Examination Coverage of MRP-139 Examination Volume = 94.6% + 4.5% = 99.1%
Figure 8b 2B2 Outlet (RC-124-1301-771)
L-2012-344 37 of 41 St. Luc!
THIRD INSPECI RELIEF REQUEST NUI C,
- L 6
0- 0 e Unit 2 ION INTERVAL MBER 13, REVISION 2 mc
-(A 3c 0 10t I
0 les-O0 C,)
0 (A
(0 w
0
'C 0
I.
~0 o
to
\\
0 Figure 8c 2B2 Outlet (RC-124-1301-771)
Spray Nozzle
L-2012-344 38 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Spray Nozzle Obstruction Axial Scan Line (Circumferential Flaws) Cross-Section @ Position A & Position E 100% Coverage - MRP-139 Exam Volume ((1.98 sq. in./1.98 sq. in.)
- 100) 76% Coverage - ASME Section Xl Exam Volume ((1.98 sq. in. / 2.62 sq. in.)
- 100)
Figure 8d 2B2 Outlet (RC-124-1301-771)
L-2012-344 39 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Spray Nozzle Obstruction PF*
0 Axial Scan Line (Circumferential Flaws) Cross-Section @ Position B & Position D 90% Coverage - MRP-139 Exam Volume ((1.78 sq. in.1l.98 sq. in.)
- 100) 68% Coverage - ASME Section Xl Exam Volume ((1.78 sq. in. / 2.62 sq. in.)
- 100)
Figure 8e 2B2 Outlet (RC-124-1301-771)
L-2012-344 40 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 Spray Nozzle Obstruction Axial Scan Line (Circumferential Flaws) Cross-Section @ Position C 80% Coverage - MRP-139 Exam Volume ((1.59 sq. in./1.98 sq. in.)
- 100) 61% Coverage -ASME Section Xl Exam Volume ((1.59 sq. in./2.62 sq. in.)
- 100)
Figure 8f 2B2 Outlet (RC-124-1301-771)
L-2012-344 41 of 41 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 2 MRP-139 Insoection Examination Volume Limitation (per 1
EPRI-DMW-PA-1 exam volume can be claimed up to weld centerline)(0.68 sq. in.)
Circumferential Scans (Axial Flaws) 66% Coverage - MRP-139 Exam Volume ((1.98-0.68)/1.98
- 100) 50% Coveraqe -ASME Exam Volume ((2.62-0.64-0.68)/2.62
- 100)
(cast SS exam volume excluded, assumes only partial scans on weld)
Figure 8g 2B2 Outlet (RC-124-1301-771)