L-2014-207, Inservice Inspection Plan Third Ten-Year Interval Unit 2 Relief Request No. 16
| ML14203A007 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 06/30/2014 |
| From: | Katzman E Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2014-207 | |
| Download: ML14203A007 (24) | |
Text
June 30, 2014 L-2014-207 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. 16 In accordance with 10 CFR50.55a(g)(5)(iii), inservice inspection impracticality, Florida Power
& Light (FPL) requests relief from the examination coverage requirements of the ASME Code,Section XI, 1998 Edition with Addenda through 2000, as clarified by Code Case N-460, for the subject ASME Code Category C-F-I welds. The basis for the relief request is provided in the Attachment.
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 6501 S. Ocean Drive, Jensen Beach, FL 34957
L-2014-207 Attachment 1 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Relief Request In Accordance with 10 CFR50.55a(g)(5)(iii)
--Inservice Inspection Impracticality--
- 1. ASME Code Component(s) Affected Class 2 pressure retaining welds in piping
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 Xl, 1998 Edition with Addenda through 2000 as amended by 10CFR50.55a, is the code of record for the St. Lucie Unit 2, 3 rd 10-year interval. ASME Section Xl, 1998 Edition with Addenda through 2000 as amended by 10CFR50.55a, was utilized for Appendix VIII.
3. Applicable Code Requirement
Exam Item No. Examination Requirements Cat.
Essentially 100% volumetric and surface examination of C-F-1 C5.11 circumferential welds >3/8" nominal wall thickness for piping
>4" nominal pipe size.
Essentially 100% volumetric and surface examination of C-F-1 C5.21 circumferential welds >1/5" nominal wall thickness for piping
>2" and <4" nominal pipe size.
As defined by ASME Code Case N-460, essentially 100% means more than 90% of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.
- 4. Impracticality of Compliance Due to the configuration of the welds included within this relief request, it is not possible to meet the examination coverage requirements of the ASME Code,Section XI, 1998 Edition with Addenda through 2000, as clarified by Code Case N-460. Relief is requested in accordance with 10 CFR 50.55a(g)(5)(iii). These areas were found during the 3rd 10-year inservice inspection interval.
When a component has conditions, which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site. This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.
When examined, the welds listed within this request did not receive the required code
L-2014-207 Attachment 2 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 volume coverage due to their configuration and/or the presence of permanent attachments. These scanning limitations prohibit essentially 100% ultrasonic examination coverage of the required examination volume.
The Table included in this Relief Request summarize the percent of coverage credited and references specific figures that show the extent of coverage.
Relief is requested from the ASME Boiler and Pressure Vessel Code required volume as identified in Figure IWC-2500-7.
- 5. Burden Caused by Compliance It is not possible to obtain ultrasonic interrogation of greater than 90% of the required examination volume due to interference caused by configuration and/or permanent attachments. Examinations are performed to the maximum extent possible. The Ultrasonic (UT) techniques for each weld were reviewed to determine if additional coverage could be achieved. For the welds listed in the Table, FPL determined that removal of the obstruction was not possible without significant work, increased radiation exposure, and/or damage to the plant. Additional weld preparation by welding or metal removal is a modification of the examination area requiring significant engineering and construction personnel support.
Radiography is impractical due to the amount of work being performed in the areas on a 24-hour basis. This would result in numerous work-related stoppages and increased exposure due to the shutdown of and startup of other work in the areas. The water must be drained from systems where radiography is performed, which increases the radiation dose rates over a much broader area than the weld being examined. There would be significant burden associated with the performance of weld or area modifications or radiography in order to increase the examination coverage.
- 6. Proposed Alternative and Basis for Use Proposed Alternative
- 1) Periodic system pressure tests in accordance with ASME Section XI Category C-H, Table IWC-2500-1.
- 2) Conduct ultrasonic examinations to the maximum extent possible.
- 3) Regular walkdowns by operations personnel and system engineers are performed on Class 2 systems to check for leakage, piping configuration, and/or damage. During outages, system engineers walkdown Class 2 systems inside containment. This walkdown is performed to look for system anomalies that could affect plant performance.
L-2014-207 Attachment 3 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Basis The attached Table provides the percent of coverage credited and references specific figures that illustrate the extent of coverage for each weld. The examination figures of ASME Section XI, 1998 Edition with Addenda through 2000, define the examination volume required. The thickness and material is identified for each item within the Table.
The angles, Ultrasonic wave modes (Shear-S or Longitudinal-L) that were employed for examination, and impracticality of compliance is listed for each weld. Arrows and lines on the figures illustrate the UT transducer beam direction and extent of the area examined.
10 CFR 50.55a(g)(4) recognizes that throughout the service life of a nuclear power facility, components which are classified as ASME Code Class 1, Class 2, and Class 3 must meet the requirements set forth in the ASME Code to the extent practical within the limitations of design, geometry and materials of construction of the components.
FPL performed the examinations to the extent possible. Operations personnel and system engineers perform walk downs of every system on a periodic basis looking for leakage or other abnormal conditions. The extent of examination volumes achieved via surface and/or volumetric examinations, combined with the system pressure tests and system walkdowns, provide assurance of an acceptable level of quality and safety.
The UT examinations were performed utilizing personnel qualified and procedures demonstrated in accordance with ASME Section Xl, Appendix VIII, Supplement 2, 1998 Edition with Addenda through 2000 and the Performance Demonstration Initiative (PDI) program.
The UT techniques for each weld were reviewed to determine if additional coverage could be achieved. FPL's procedures require the examiner to make an attempt to achieve complete coverage by using alternative techniques such as using a smaller wedge thus reducing the distance from the exit point to the front of the wedge, changing angles or reducing the search unit element size. Any alternative equipment is required to be in compliance with the limits specified in the qualified procedure. Alternate techniques were investigated at the time of discovery.
The coverage credited is limited when access can only be obtained from one side. No coverage is claimed past the centerline in the coverage credited in the Table since access for scanning was not available from that side of the weld and the Performance Demonstration Qualification Summary (PDQS) for the qualified procedure, PDI-UT-2, states that "the austenitic single side qualification documented on this summary demonstrates application of best available technology, but do not meet the requirements of 10CFR 50.55a(b)(2)(xvi)(B)." It should be noted that UT was performed through the weld to the maximum possible of the Code examination volume and, as shown in the figures, the theoretical beam path extends into the far side for the examinations performed. While the coverage is not included in the Table, the techniques employed for the single sided examinations provided for a best effort examination. The coverage obtained was the maximum practical. Therefore, the UT examinations conducted using
L-2014-207 Attachment 4 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 the Appendix VIII, Supplement 2, qualified procedure provide reasonable assurance for the detection of flaws on the far side of welds where the ultrasonic beam has been transmitted even though not presently qualified.
For weld SI-409-FW-2003, installed in 2011, examinations performed during the replacement process included in-process and final surface examinations, and final radiography (RT) in accordance with the requirements of ASME Section II1. The surface and radiographic examinations were not limited. Final RT and surface examinations performed during the installation of the weld revealed no recordable or reportable flaws in the examination zone or adjacent to any UT limitations. The acceptable surface and RT results were obtained prior to the preservice UT examination being performed. The preservice UT examination did not reveal any recordable or reportable flaws in the examination zone.
Surface examinations were performed of all the items listed were not limited. In all cases, 100 percent of the Code required surface area was examined.
The surface and volumetric examinations of all the items listed did not reveal any recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations.
- 7. 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 ended August 7, 2013.
- 8. References 10CFR50.55a ASME Section Xl, "Rules For Inservice Inspection of Nuclear Power Plant Components,"
1998 Edition with Addenda through 2000 ASME Section XI, Division 1, Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds, Section Xl, Division 1,"
L-2014-207 Attachment 5 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Category C-F-1 Component ID" ear Applicable Code Angle(s)/
ASME.Code Component ;.Diameter-Schedule Of Requirement and Wave Fig. Impracticality-of Compliance
_ _ _Material Exam Coverage Credited Mode Exam Category C-F-1 SI-179-FW-1 Item No. C5.21 45S Inservice examination limited Valve to Pipe (3-160) 2006 Fig. IWC-2500-7(a) 60S 1 to single side access due to Stainless Steel 70S valve configuration.
50% volume coverage Exam Category C-F-1 S1-137-1-SW-1 Item No. C5.21 45S Inservice examination limited to Pipe to Flange (3-160) 2006 Fig. IWC-2500-7(a) 60S 2 single side access due to flange Stainless Steel 70S configuration.
50%
Exam Category C-F-1 SI-1 79-20-SW-8 Item No. C5.21 45S Inservice examination limited to Flange to Pipe (3-1 60) 2006 Fig. IWC-2500-7(a) 60S 2 single side access due to flange Stainless Steel 70S configuration.
50%
Exam Category C-F-1 Inservice examination limited to SI-381-FW-1 Item No. C5.21 45S single side access due to flange Pipe to Flange (3-160) 2006 Fig. IWC-2500-7(a) 60S 3 configuration. Examination from Stainless Steel 70S pipe side limited due to adjacent 45% 1" line.
Exam Category C-F-1 SI-213-FW-1 Item No. C5.11 60S Inservice examination limited Pipe to Valve (6"- 20) 2006 Fig. IWC-2500-7(a) 70S 4 to single side access due to Stainless Steel 70L valve configuration.
________________________________________50% Lvlecniuain
L-2014-207 Attachment 6 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Category C-F-1 Component DID Year Applicable Code 2. Angle(s) .
ASMEDCode Comonent Diameter-Schedule Obf ReqUirement and Wave Fig. Impracticality of Compliance Material Exam Coverage Credited Mode Exam Category C-F-1 45S SI-146-FW-2 Item No. C5.11 Inservice examination limited Pipe to Valve (6"-160) 2006 Fig. IWC-2500-7(a) 60S 5 to single side access due to Stainless Steel 70L valve configuration.
50%7L Exam Category C-F-1 45S SI-110-FW-1 Item No. C5.11 60S Inservice examination limited Valve to Pipe (6"-160) 2006 Fig. IWC-2500-7(a) 70S 5 to single side access due to Stainless Steel 70L valve configuration.
Exam Category C-F-1 45S SI- 13-FW-6 Item No. C5.11 60S Inservice examination limited Pipe to Penetration (6"-160) 2006 Fig. IWC-2500-7(a) 70S 6 due to penetration configuration.
Stainless Steel 70% 70% 45L 45L Exam Category C-F-1 Sii1SW6Item No. C5.21 45S SIPp t T-160)2-SW-6 Ig. NWC52 a 45S Inservice examination from tee Pipe to Tee (W-160) 2006 Fig. IWC-2500-7(a) 60S 9 side limited due to radius.
70S 74%
Exam Category C-F-1 Sl-211-FW-2 Item No. C5.21 45S Inservice examination limited Valve to Pipe (3-160) 2007 Fig. IWC-2500-7(a) 60S 1 to single side access due to Stainless Steel 70S valve configuration..
50%
Exam Category C-F-1 SI-213-FW-2 Item No. C5.11 Inservice examination limited Valve to Pipe (6"-120) 2007 Fig. IWC-2500-7(a) 70S 4 to single side access due to Stainless Steel valve configuration.
50%
L-2014-207 Attachment 7 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0
.Category C-F-1 Component ID Year Applicable Code Angle(s)/
ASME Code Component Diameter-Schedule Of Requirement and Wave Fig. Impracticality of Compliance Material Exam Coverage Credited Mode Exam Category C-F-1 SI-110-FW-10 Item No. C5.11 45S Pipe to Penetration (6"-160) StailessStee IWC-2500-7(a) 2007 Fig. 60S 70Ldue 7 dnseviceexamiation limited to penetration configuration.
Stainless Steel 70L 79%
Exam Category C-F-1 SI-208-FW-1 Item No. C5.21 45S Inservice examination limited Pipe to Valve (3"-160) 2009 Fig. IWC-2500-7(a) 60S 1 to single side access due to Stainless Steel 70S valve configuration..
50%
Exam Category C-F-1 SI-208-FW-2 Item No. C5.21 45S llnservice examination limited Valve to Pipe (3-160) 2009 Fig. IWC-2500-7(a) 60S 1 to single side access due to Stainless Steel 70S valve configuration.
50%
Exam Category C-F-1 SI-1 80-FW-2 Item No. C5.21 45S Inservice examination limited Pipe to Valve (3"-160) 2011 Fig. IWC-2500-7(a) 60S 1 to single side access due to Stainless Steel 70S valve configuration.
50%
Exam Category C-F-1 SI-181-FW-14 Item No. C5.21 45S Inservice examination limited Pipe to Valve (3"-160) 2011 Fig. IWC-2500-7(a) 60S 1 to single side access due to Stainless Steel 70S valve configuration.
50%
Exam Category C-F-1 SI-382-FW-1 Item No. C5.21 45S Inservice examination limited to Elbow to Flange (3-160) 2011 Fig. IWC-2500-7(a) 60S 8 single side access due to flange Stainless Steel 70S configuration.
1_ 50%
L-2014-207 Attachment 8 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Category C-F-1 Component ID Year Applicable Code Angle(s)/
ASME Code Component Diameter-Schedule -Of Requirement and Wave Fig. Impracticality of Compliance Material Exam Coverage Credited Mode Exam Category C-F-1 SI-180-1-SW-1 Item No. C5.21 45S Inservice examination from tee Pipe to Tee (3"-160) 2011 Fig. IWC-2500-7(a) 60S side limited due to radius.
Stainless Steel 70S 74%
Exam Category C-F-1 SI-213-1-SW-11 Item No. C5.21 45S Inservice examination from tee Tee to Pipe (3"-160) 2011 Fig. IWC-2500-7(a) 60S side limited due to radius.
Stainless Steel 70S 74%
Exam Category C-F-1 SI-220-1-SW-8 Item No. C5.21 45S Inservice examination from tee Pipe to Tee (3"-160) 2011 Fig. IWC-2500-7(a) 60S side limited due to radius.
Stainless Steel 70S 74%
Exam Category C-F-1 SI-1 03-FW-1 Item No. C5.11 45S Inservice examination limited Valve to Pipe (12"-160) 2011 Fig. IWC-2500-7(a) 60S 10 to single side access due to Stainless Steel 60L valve configuration.
50%
Exam Category C-F-1 45S SI-111-FW-9 Item No. C5.11 60S Inservice examination limited to Pipe to Penetration (6"-160) 2011 Fig. IWC-2500-7(a) 70S 11 single side access due to Stainless Steel 60L penetration configuration.
Exam Category C-F-1 SI-111-FW-10 Item No. C5.11 45S Inservice examination limited Pipe to Valve (6"-160) 2011 Fig. IWC-2500-7(a) 60S 12 to single side access due to Stainless Steel 60L valve configuration.
__ 50%
L-2014-207 Attachment 9 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Category C-F-1
,f en .Component]ID ':Year Applicable Code, Angle(s)/
W:' Fig Im ratialt' : ' Compliance ASME Code Component Diameter-Schedule ! Of Requirement and Wave Fig. Impracticalityof Compliance Material !Exam Coverage Credited Mode Exam Category C-F-1 SI-409-FW-2003 Item No. C5.11 45S Preservice examination limited Valve to Pipe (6"-160) 2011 Fig. IWC-2500-7(a) 60S 13 to single side access due to Stainless Steel 60L valve configuration.
50%
Exam Category C-F-1 SI-101-FW-2 Item No. C5.11 45S Inservice examination limited Pipe to Valve (12"-160) 2012 Fig. IWC-2500-7(a) 60S 10 to single side access due to Stainless Steel 60L valve configuration.
50%
Exam Category C-F-1 SI-112-FW-6 Item No. C5.11 45S Inservice examination limited to Pipe to Penetration (6"-160) 2012 Fig. IWC-2500-7(a) 60S 14 single side access due to Stainless Steel 60L penetration configuration.
50% 1_1
L-2014-207 Attachment 10 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 CL 70 45 60 VALVE PIPE SINGLE SIDED EXAMINATION DUE TO VALVE CONFIGURATION EXAMINED 50% OF CRV.
SI-179-FW-1, Sl-211 -FW-2, SI-208-FW-1, SI-208-FW-2, SI-180-FW-2, SI-181-FW-14 Figure 1
L-2014-207 Attachment 11 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2 1 0 1 2 I I I I CL 70 45 60 FLANGE PIPE SINGLE SIDE EXAMINATION DUE TO FLANGE SI-137-1-SW-1, S1-179-20-SW-8 Figure 2
L-2014-207 Attachment 12 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2 1 0 1 2 I I I I FLOW CL SI-381-FW-1 60 FLANGE PIPE SINGLE SIDE EXAMINATION DUE TO FLANGE LIMITATION PIPE SIDE DUE TO ADJACENT 1" LINE OBSTRUCTED FOR 1.1" OF THE TOTAL 11" LENGTH PIPE SIDE SI-381-FW-1 Figure 3
L-2014-207 Attachment 13 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2 1 0 1 2 II I I CL 60 45 70 PIPE VALVE SINGLE SIDED EXAMINATION EXAMINED 50% OF THE CRV SI-213-FW-1, SI-213-FW-2 Figure 4
L-2014-207 Attachment 14 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2I 1I 0I 1I 2 CL PIPE VALVE SINGLE SIDED EXAMINATION DUE TO VALVE CONFIGURATION EXAMINED 50% OF THE CRV SI-1 46-FW-2, SI-11 0-FW-1, SI-409-FW-2003 Figure 5
L-2014-207 Attachment 15 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2 1 0 1 2 FLOW CL 45 70 45 45 PIPE PEN LIMITED EXAMINATION DUE TO PENETRATION CONFIGURATION SI-113-FW-6 Figure 6
L-2014-207 Attachment 16 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2I ,I 1 ,I 0 1Ir 2 FLOW CL PEN EXAMINATION LIMITED DUE TO PENETRATION CONFIGURATION SI-110-FW- 10 Figure 7
L-2014-207 Attachment 17 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2I 1I 0I 1I 2 FLOW CL SI-382-FW-1 70 FLANGE ELBOW SINGLE SIDED EXAMINATION DUE TO FLANGE CONFIGURATION EXAMINED 50% OF THE CRV.
SI-382-FW-1 Figure 8
L-2014-207 Attachment 18 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Limited to 1 side due to radius Limited to 1 side due to radius Weld total length =1 1. 6" total length limited due to radius.
2 1 0 12 CL 60 45 70 PIPE TEE mo /M EXAMINATION LIMITED DUE TO TEE INTRADOSE (2)
EXAMINED 74% OF THE CRV.
SI-1 80-1-SW-1, SI-213-1-SW-11, Sl-220-1 -SW-8, SI-1i10-1-SW-6 Figure 9
L-2014-207 Attachment 19 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2 1 0 1 2 CL 60 VALVE SINGLE SIDED EXAMINATION DUE TO VALVE CONFIGURATION EXAMINED 50% OF THE CRV.
SI-103-FW-1, SI-101-FW-2 Figure 10
L-2014-207 Attachment 20 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2 SI 1 0I 1 2, CL 60 45 6070 PIPE PEN SINGLE SIDED EXAMINATION DUE TO PENETRATION CONFIGURATION EXAMINED 50% OF THE CRV.
SI-1 11-FW-9 Figure 11
L-2014-207 Attachment 21 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2I 1I 0I 1I 2 CL 60 VALVE PIPE SINGLE SIDED EXAMINATION DUE TO VALVE CONFIGURATION EXAMINED 50% OF THE CRV.
SI-111-FW-10 Figure 12
L-2014-207 Attachment 22 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2I 1I 0 1I 2 CL 60 45 60 I
VALVE PIPE SINGLE SIDED EXAMINATION DUE TO VALVE CONFIGURATION EXAMINED 50% OF THE CRV.
SI-409-FW-2003 Figure 13
L-2014-207 Attachment 23 of 23 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 2I ,I 1 ,I, 0 1 2 CL 60 SINGLE SIDED EXAMINATION DUE TO PENETRATION CONFIGURATION EXAMINED 50% OF THE CRV.
SI-1 12-FW-6 Figure 14