L-2009-035, Third Interval Relief Requests 31 and 32

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Third Interval Relief Requests 31 and 32
ML090430304
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 02/06/2009
From: Katzman E
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2009-035
Download: ML090430304 (56)


Text

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FIPL Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach, FL 34957 February 6, 2009 L-2009-035 10 CFR 50.4 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re:

St. Lucie Unit 1 Docket No. 50-335 Unit 1 Third Interval Relief Requests 31 and 32 Relief request 31 pertains to the impracticality to meet the code required volume coverage of some welds in the reactor vessel as required by the ASME Code, 1989 Edition, no addenda, as clarified by Code Case N-460 due to configuration and/or the presence of permanent attachments. Relief is requested in accordance with 10CFR50.55a(g)(5)(iii).

Relief request 32 pertains to the impracticality to meet the code required volume coverage of some piping and vessel welds as required by the ASME Code, 1989 Edition, no addenda, as clarified by Code Case N-460 due to configuration and/or the presence of permanent attachments. Relief is requested in accordance with 1 OCFR50.55a(g)(5)(iii).

The relief requests are contained in Attachments 1 and 2.

Sincerely, Eric S. Katzman Licensing Manager St. Lucie Plant Attachments ESK/KWF A4ý7 P4,9 an FPL Group company

I-,

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 1 of 10 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 31 Relief Request In Accordance with 10 CFR50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

1.

ASME Code Component(s) Affected Class 1 pressure retaining welds in the reactor pressure vessel (RPV).

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, 1989 Edition, No Addenda.

3.

ADDlicable Code Reuuirement I I I

..... Item No.

Examination Requirements,.,

Cat.

B 1.10 Essentially 100% volumetric examination of all longitudinal B-A B 1.11 and circumferential shell welds (does not include shell to B11.12 flange weld).

B 1.20 Essentially 100% volumetric examination of accessible length B 13.22 of circumferential and meridional head welds.

B 1.22 As defined by 10CFR50.55a(g)(6)(ii)(A)(2) and 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 Reactor Vessel, it is impractical to meet the examination coverage requirements of the ASME Code,Section XI, 1989 Edition, No Addenda, 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 examined, the welds listed within this request did not receive the required code 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.

Described below, coupled with figures, are details of the examination limitations by weld description. The accompanying figures graphically depict the extent of the limitations.

St. Lucie Unit 1 L-2009-035 Docket No. 50-335 2 of 10 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 31 RPV Intermediate Shell-to-Lower Shell Circumferential Weld (9-203)

Examination Category B-A, Item B 1.11 The examination of the Figure IWB-2500-2 A-B-C-D volume is limited due to the surveillance capsule holders. Access to approximately 16.9% of the examination volume is restricted. The remaining examination volume was examined with techniques which have been qualified by demonstration in accordance with Supplements 4 & 6 of the 1995 Edition, 1996 Addenda of the ASME Code Section XI, Appendix VIII, using the Performance Demonstration Initiative Protocol. This weld was examined from both sides of the weld, scanning both parallel and perpendicular. These ultrasonic examinations did not reveal any recordable or reportable flaws in accordance with the ASME Code Section XI, 1989 Edition, No Addenda.

Figure 1 is a roll out view showing the reactor vessel inside surface scan areas (cross hatched) and the locations of limited areas due to the presence of the surveillance capsule holders.

RPV Circumferential Bottom Head-to-Lower Shell Weld (10-203)

Examination Category B-A, Item B 1.21 The examination of the Figure IWB-2500-3 A-B-C-D volume is limited due to the proximity of the Core Barrel Stabilizers and Core Lugs. Access to approximately 29.4%

of the examination volume is restricted. The remaining examination volume was examined with techniques which have been qualified by demonstration in accordance with Supplements 4 & 6 of the 1995 Edition, 1996 Addenda of the ASME Code Section XI, Appendix VIII, using the Performance Demonstration Initiative Protocol. This weld was examined from both sides of the weld, scanning both parallel and perpendicular to the weld. The ultrasonic examination identified three IWB-3510 acceptable indications in accordance with the ASME Code Section XI, 1989 Edition, No Addenda, acceptance criteria.

Figure 2 is a roll out view showing the reactor vessel inside surface scan areas (cross hatched). Figure 3 provides an illustration of the core barrel stabilizers and core lugs and their locations in the reactor vessel.

RPV Upper Shell Longitudinal Seam Weld at 15 Degrees (1-203B)

Examination Category B-A, Item B 1.12 The examination of the Figure IWB-2500-2 A-B-C-D volume is limited due to the outlet nozzle at zero degrees integral extension. Access to approximately 36.8% of the examination volume is restricted. The remaining examination volume was examined with techniques which have been qualified by demonstration in accordance with Supplements 4 & 6 of the 1995 Edition, 1996 Addenda of the ASME Code Section XI,

St. Lucie Unit 1 L-2009-035 Docket No. 50-335 3 of 10 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 31 Appendix VIII, using the Performance Demonstration Initiative Protocol. This weld was examined from both sides of the weld, scanning both parallel and perpendicular. These ultrasonic examinations did not reveal any recordable or reportable flaws in accordance with the ASME Code Section XI, 1989 Edition, No Addenda.

Figure 4 is a roll out view showing the reactor vessel inside surface scan areas (cross hatched).

RPV Lower Head Peel Segment Welds (204-03-A through F)

Examination Category B-A, Item B 1.22 The examination of the Figure IWB-2500-3 E-F-G-H volume is limited due tothe proximity of the flow baffle. Approximately 46.7% of welds 204-03-B, 204-03-D, 204-03-F and 56.6% of welds 204-03-A,.204-03-C, 204-03-E, the examination volume is restricted due to limited access behind the flow baffle. The remaining examination volume was examined with techniques which have been qualified by demonstration in accordance with Supplements 4 & 6 of the 1995 Edition, 1996 Addenda of the ASME Code Section XI, Appendix VIII, using the Performance Demonstration Initiative Protocol. The welds were examined from both sides of the weld, scanning both parallel and perpendicular to the weld. These ultrasonic examinations did not reveal any recordable or reportable flaws in accordance with the ASME Code Section XI, 1989 Edition, No Addenda.

Figure 5 is a roll out view showing the reactor vessel inside surface scan areas (cross hatched) and the locations of the areas of incomplete weld volume coverage. Figure 3 provides an illustration of a flow baffle.

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 w.elds listed above, it was not possible to remove the obstruction without significant work, increased radiation exposure, and/or damage to the plant.

St. Lucie Unit 1 L-2009-035 Docket No. 50-335 4 of 10 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 31

6.

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) Conduct ultrasonic examinations to the maximum extent possible.

Basis FPL performed inservice examinations of selected welds in accordance with the requirements of 10CFR50.55a, plant technical specifications, and the 1989 Edition, No Addenda, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI. 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.

FPL performed mechanized ultrasonic examinations of the reactor vessel during the November 2008 refueling outage.

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 ultrasonic examinations of the all reactor vessel welds. in accordance with the requirements of 10 CFR 50.55a, plant technical specifications, and the 1995 Edition, No Addenda, of ASME Section XI to the maximum extent possible. The mechanized techniques employed for examination from the RPV inside have been demonstrated in accordance with Supplements 4 & 6 of the 1995 Edition, 1996 Addenda of the ASME Code Section XI, Appendix VIII, using the Performance Demonstration Initiative Protocol.

In addition to the required ultrasonic examination, the interior of the reactor vessel, including welded attachments, received a visual examination in accordance with Table IWB-2500-1, Examination Categories B-N-I, B-N-2 and B-N-3. The visual examinations revealed no indications.

The subject welds were examined in the second interval during the 10-year reactor vessel examination. These examinations did not reveal any reportable flaws during the previous examination.

The extent of examination volume achieved ultrasonically, the alternate scans performed, and the system pressure tests provide assurance of an acceptable level of quality and safety.

St. Lucie Unit I L-2009-035 Docket No. 50-335 5 of 10 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 31

7.

Duration of Proposed Alternative Third Inservice Inspection Interval February 11, 1998 to February 10, 2008

8.

References 10CFR50.55a ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, No Addenda ASME Section XI, Division 1, Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1" ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components," 1995 Edition, 1996 Addenda

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 6 of 10 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 31 18C.,

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St. Lucie Unit 1 L-2009-035 Docket No. 50-335 7 of 10 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 31 1-03 wi. "

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St. Lucie Unit 1 Docket No. 50-335 L-2009-035 8 of 10 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 31

-SURVEILLANC HULDER CElRE BARR~EL STABILIZER-WELD 10-203 1ý9 FLOW BATFLE Figure 3-Weld 10-203

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 9 of 10 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 31 B

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St. Lucie Unit 1 Docket No. 50-335 L-2009-035 1 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 Relief Request In Accordance with 10 CFR50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

1.

ASME Code Component(s) Affected Class 1 and 2 pressure retaining welds in vessel and 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 XI, 1989 Edition, No Addenda.

3.

Applicable Code Requirement

Exarr-iNo Cat,.

Item o Examination Requirements B-B B2.31 Essentially 100% volumetric examination of weld length.

B-D B3.130 Essentially 100% volumetric examination of weld length.

Essentially 100% volumetric and surface examination of circumferential welds for >4" nominal pipe size. On March 25, 2004, FPL received approval (TAC NO. MC0244) to implement an alternative risk informed program that requires essentially 100%

volumetric examination for butt welds in class I systems. PSI volumetric examination of essentially 100% of piping welds.

Essentially 100% surface examination of circumferential welds for

<4" nominal pipe size. On March 25, 2004, FPL received approval B-J B9.21 (TAC NO. MC0244) to implement an alternative risk informed program that requires essentially 100% volumetric examination for butt welds in class I systems. PSI volumetric examination of essentially 100% of piping welds.

CI.10 C-A CJ.30 Essentially 100% volumetric examination of the weld length.

C-B C2.21 Essentially 100% volumetric and surface examination of nozzle to sheel welds Essentially 100% volumetric and surface examination of C-F-I C5.11 circumferential welds >3/8" nominal wall thickness for piping >4" nominal pipe size.

St. Lucie Unit 1 L-2009-035 Docket No. 50-335 2 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 Exa Item No.

Examination Reqiuirements Cat.

Essentially 100% volumetric and surface examination of C-F-I C5.21 circumferential welds >1/5" nominal wall thickness for piping >2" and <4" nominal pipe size.

Essentially 100% volumetric and surface examination of C-F-2 C5.51 circumferential welds >3/8" nominal wall thickness for piping >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 impractical to meet the examination coverage requirements of the ASME Code,Section XI, 1989 Edition, No Addenda, 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 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.

Table 1 summarizes the percent of coverage achieved and references specific figures that show the extent of coverage. Arrows and lines on the figures illustrate the UT transducer beam direction and extent of the area examined.

Relief is requested from the ASME Boiler and Pressure Vessel Code required volume as identified in Figure IWB-2500-3, 7, and 8 and IWC-2500-1, 2, 4 and 7, as applicable.

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 Table 1, it was not possible to remove the obstruction without significant work, increased radiation exposure, and/or damage to the plant. Additional weld preparation by

St. Lucie Unit 1 L-2009-035 Docket No. 50-335 3 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 welding or metal removal is a modification of the examination area requiring significant engineering and construction personnel support. Increased radiation exposure and cost would be incurred in order to perform these modifications.

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

2) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1.
3) Conduct ultrasonic examinations to the maximum extent possible.
4) 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 1 and 2 systems inside containment. This walkdown is performed to look for system anomalies that could affect plant performance.

Basis FPL performed inservice examinations of selected welds in accordance with the requirements of 10CFR50.55a, plant technical specifications, and the 1989 Edition, No Addenda, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI. 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.

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.

Configuration, permanent attachments and/or structural interferences prohibit 100% ultrasonic examination of Code required volume. Additional ultrasonic techniques are employed where practical to achieve the code-required volume. The Table I summarizes the percent of coverage achieved and references specific figures that show the extent of coverage. Arrows and lines on the figures illustrate the UT transducer beam direction and extent of the area examined.

J8 1l St. Lucie Unit 1 L-2009-035 Docket No. 50-335 4 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST. NUMBER 32 For examinations performed prior to the expedited implementation of Appendix VIII, Supplements 2 and 3 (May 22, 2000) and examinations of welds adjoining cast material, the ultrasonic testing (UT) techniques for each weld were reviewed to determine if additional coverage could have been achieved. FPL's procedures require the examiner to consider whether additional coverage is necessary and practical. Those alternate techniques were investigated at the time of discovery. The alternate techniques considered were extending the calibration distance and/or using additional beam angles or modes. This has often provided the additional coverage needed to avoid relief. Using additional UT techniques on the weld examination areas in this relief request would have provided little or no additional coverage. The coverage obtained was the maximum practical.

For examinations performed after the 10 CFR 50.55a required expedited implementation of Appendix VII, supplements 2 and 3 (May 22, 2000), the ultrasonic testing (UT) was performed utilizing personnel qualified and procedures demonstrated in accordance with the Performance Demonstration Initiative (PDI) program. In the cases where austenitic materials were examined (Code Category B-J and C-F-1), the credited volumetric examination of the weld required volume (WRV) is limited when access can only be obtained from one side. It shouldbe noted that the volumetric examination was performed through 100% of the Code WRV; however, the PDI Appendix VIII procedure used is not qualified for the detection of flaws on the far side of the single sided access examinations of austenitic piping welds. The techniques employed for the single sided examinations provided for a best effort examination. The coverage obtained was the maximum practical.

The required surface examinations were performed and were not limited. In all cases, 100 percent of the code required surface area was examined. These surface and volumetric examinations did not reveal any-recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations in-accordance with the ASME Code Section XI, 1989 Edition, No Addenda.

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. Surface and volumetric examinations performed, along with the required system pressure tests, provide reasonable assurance of an acceptable level of quality and safety.

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.

The extent of examination volume achieved ultrasonically, combined with the system pressure tests and system walkdowns, provide assurance of an acceptable level of quality and safety.

7.

Duration of Proposed Alternative Third Inservice Inspection Interval February 11, 1998 to February 10, 2008

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 5 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32

8.

References 10CFR50.55a ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, No Addenda ASME Section XI, Division 1, Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1"

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 6 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 Category B-B omponer f

pApplicibtleode ReqUirement of

~ASME Code Component

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~Exam

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Exam Category B-B Item No. B2.31 Inservice examination limited along Steam Generator Primary Head 1-SGA-W4 2005 Fig. IWB 2500-3 1,2 length of weld due to one side to58%

volume coverage configuration.

Exam Category B-D Exam Category B-D Item No. B33.130 Inservice examination limited along Inlet Nozzle to Shell, Steam

[SGA-W5 2001 Fig. IWB 2500-7(c) 1,3 length of weld due to one side Generator lB Primary Side configuration.

85% volume coverage Exam Category B-D Item No. B3.130 Inservice examination limited along Inlet Nozzle to Shell, Steam lGAW205 Fig. IWB 2500-7(c) 13lnt fwl u ooesd Generator 1A Primary Side

  • cniuain 85% volume coverage cniuain

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 7 of 45 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32

Category B-J

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SI-112-1-SW-5 Tee to Pipe (6"-160)

Reducer to Tee 51-112-1-SW-6 (6"-160)

SI-148-2-SW-4 Pipe to Tee

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SI-148-F W-5 Elbow to Valve SI-14-W (12"-160)

Applicable Code Requirement,,gmrciclt

,and Coverage Obtained,,

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Exam Category B-J Item No. B9.11 Inservice examination performed Fig. IWB-2500-8 prior to expedited implementation of 4

Appendix VIII. Examination 100% From Pipe Side complete from pipe side and limited 63% From Tee Side from tee side in area of radius.

Exam Category B-J Item No. 89.11 Inservice examination performed Fig. IWB-2500-8 prior to expedited implementation of 5

Appendix VIII. Examination 100% From Reducer Side complete from reducer side and 63% From Tee Side limited from tee side in area of radius.

Exam Category B-J Inservice examination performed Item No. B39.11 prior to expedited implementation of Fig. IWB-2500-8 Appendix VIII. Examination 100% From Pipe Side complete from pipe side and limited 0% From Tee Side from tee side by weld crown and tee configuration.

Exam Category B-1 Inservice examination performed Item No. 139.11 prior to expedited implementation of Fig. IWB-2500-8 Appendix VIII. Examination is 0 Fcomplete from elbow side and limited 100% From Elbow Side from valve side due to weld crown 0% From Valve Side and taper.

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 8 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 Category 84-J

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Imprdcticalityof Complihhce Exam Category B-J Inservice examination performed Item No. 139.11 prior to expedited implementation of Valve to Elbow RC-151-FW-1 1999 Fig. IWB-2500-8 Appendix VIII. Examination is (12"-160) 100% From Elbow Side complete from elbow side and limited from valve side due to weld crown 0% From Valve Side adtpr and taper.

Exam Category 134 Inservice examination performed Item No. B9.11 prior to expedited implementation of SI-148-FW-1 Fig. IWB-2500-8 Appendix VIII. Examination is Valve to Pipe (12"-160) 1999 100% From Pipe Side complete from elbow side and limited 100% From Vave Side from valve side due to weld crown 0% From Valve Side adtpr and taper.

Exam Category B-J Item No. B9.11 Inservice examination limited by Pump (Cast) to Safe-end (Cast)

RC-1 15-FW-3-500E Fig. IWB-2500-8 configuration, examination complete (30"-3.5")

100% From Safe end Side of safe-end side and no access from 0% From Pump Side pump side due to configuration.

Exam Category B-J PSI examination performed with Item No. B9.21 Appendix VIII demonstrated RC-109-FW-2003 Fig. IWB-2500-8 procedure. Examination complete Valve to Pipe (3"-160) 2005 11 from pipe side including best effort 100% From Pipe Side examination of valve side through 0% From Valve Side weld material. No access from valve side due to weld crown and taper.

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 9 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 Category B-J ASMECodeC jjl ornpnentYear AtpplicableCode oiCempiance

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SExamt PSI examination performed with Exam Category B-J Appendix VIII demonstrated Item No. B9.11 procedure. Examination complete RC-103-FW-2000 Fig. IWB-2500-8 from nozzle side and limited from tee (4"- 160) side in area of radius. Best effort 100% From Nozzle'Side examination of tee side in area of 69% From Tee Side radius performed through weld material.

PSI examination performed with Exam Category B-J Appendix VIII demonstrated Item No. B9.11 procedure. Examination complete RC-103-FW-2002 Fig. IWB-2500-8 from pipe side and limited from tee Tee to Pipe (4"- 160) 2005 13 side in area of radius. Best effort 100% From Pipe Side examination of tee side in area of 69% From Tee Side radius performed through weld material.

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 10 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 Year ASME Code Coiimponent iFi g.mponent ID Of lAppl....lefCode Fig. I InpracticalityofCompliance Exam and Coverage Obtained-Exam Category C-A Item No. C.10 Fig. IWC 2500-1 Inservice examination limited by Flange to Shell 2-2701 2004 14 weld crown, taper, and flange 32% From Shell Side configuration.

0% From Flange Side Exam Category C-A Item No. C1.30 Fig. IWC 2500-2 Inservice examination limited by Body to Tubesheet 2-2702 2004 15 weld crown and tubesheet 38% From Body Side configuration.

0% From Tubesheet Side

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 11 of 45 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 Category C-13 Year AplcbeCdReurmn ASME Code Component omponent 1 Of Applicabl ompcticality of Compliance iExam cndpCoverage Obtained Exam Category C-B Item No. C2.21 Fig. IWC 2500-4(b)

Inservice examination limited by Outlet Nozzle to Vessel 2-2742-1 2004 10%Fo hl ie16nozecfiuao.

100% rom hellSidenozzle configuration.

0% From Nozzle Side Exam Category C-B Item No. C2.21 Fig. IWC 2500-4(b)

Inservice examination limited by Inlet Nozzle to Vessel 2-2741-1 2004 16 100% From Shell Side nozzle configuration.

0% From Nozzle Side

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 12 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 Category C-F-1 Year A

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kirpractiality of Complianic Exam' an Inservice examination performed with Exam Category C-F-I Appendix VIII demonstrated Item No. C5.11 procedure. Examination complete SI-213-1-SW-2 Fig. IWC-2500-7(a) from reducer side and best effort Tee to Reducer (6"- 120) 2001 17 examination of tee side performed 100% From Reducer Side through weld material. No access 0% From Tee Side from tee side due to weld crown, taper, and tee configuration.

Inservice examination performed with Exam Category C-F-I Appendix VIII demonstrated Item No. C5.21 procedure. Examination complete SI-210-FW-5 2001 Fig. IWC-2500-7(a) 18 from pipe side and best effort Pipe to Valve 2001818 (4"-80) examination of valve side performed 100% From Pipe Side through weld material. No access 0% From Valve Side from valve side due to weld crown, taper, and valve configuration.

Inservice examination performed with Exam Category C-F-1 Appendix VIII demonstrated Item No. C5.11 procedure. Examination complete Valve to Pipe SI-129-FW-1 2002 Fig. IWC-2500-7(a) 19 from pipe side and best effort (6"-160) examination of valve side performed 100% From Pipe Side through weld material. No access 0% From Valve Side from valve side due to valve taper, and valve configuration.

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 13 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 Category C-F-I

~Year A6i.bl CoeRqurmn ASME Code Component Componentfir Fig.

Impracticality of omphace:,.

and Covrage Obttained c.m,-

e-

~ ~Examý Inservice examination performed with Exam Category C-F-I Appendix VIII demonstrated Item No. C5.11 procedure. Examination complete Pipe to Valve S I 13-FW-9 2002 Fig. IWC-2500-7(a) 20 from pipe side and best effort (6"- 160) examination of valve side performed 100% From Pipe Side through weld material. No access 0% From Valve Side from valve side due to valve taper, and valve configuration.

Inservice examination limited by Exam Category C-F-I configuration, examination performed Item No. C5.11 with Appendix VIII demonstrated SI-212-FW-IA Fig. IWC-2500-7(a) 21 procedure, examination complete of (6"-162002 pipe side and best effort examination 100% From Pipe Side of tee side performed through weld 0% From Tee Side material. No access from tee side due to taper, and tee configuration.

Inservice examination performed with Exam Category C-F-I Appendix VIII demonstrated Item No. C5.11 procedure. Examination complete SI-212-FW-1 2002 Fig. IWC-2500-7(a) 22 from pipe side and best effort Pipe to Valve 2002 22)

(6"- 160) examination of valve side performed 100% From Pipe Side through weld material. No access 0% From Valve Side from valve side due to valve taper, and valve configuration.

St. Lucie Unit I Docket No. 50-335 L-2009-035 14 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 Category C-F-i

~Year plcbeCdeRqirmn ASME Code Componenf*

! Component ID Of applCaberagdeObqienen Exam aidoegebtnd Exam Category C-F-1 Item No. C5.11 Valve to Pipe SI-105-FW-1 2002 Fig. IWC-2500-7(a)

(6"-160) 100% From Pipe Side 0% From Valve Side Exam Category C-F-1 Item No. C5.1I Valve to Pipe SI-213-FW-2 2004 Fig. IWC-2500-7(a)

(6"-120) 100% From Pipe Side 0% From Valve Side Exam Category C-F-I Item No. C5.21 Valve to Pipe SI-210-FW-4 2004 Fig. IWC-2500-7(a)

(4"-80) 100% From Pipe Side 0% From Valve Side

>Impiracticality of Compliance Inservice examination performed with Appendix VIII demonstrated procedure. Examination complete from pipe side and best effort examination of valve side performed through weld material. No access from valve side due to valve taper, and valve configuration.

Inservice examination performed with Appendix VIII demonstrated procedure. Examination complete from pipe side and best effort examination of limited amount of valve side performed through weld material. No access from valve side due to weld crown, valve taper, and valve configuration.

Inservice examination performed with Appendix VIII demonstrated procedure. Examination complete from pipe side and best effort examination of limited amount of valve side performed through weld material. No access from valve side due to weld crown, valve taper, and valve configuration.

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 15 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32

,Category C~i Exam Category C-F-1I Appendix VIII demonstrated Item No. C5.21 procedure. Examination complete SI-209-FW-2 Ffrom pipe side and best effort Valve to Pipe (3"-160) 2007 26 examination of limited amount of 100% Frmipvalve side performed through weld 100% From Pipe Side material. No access from valve side due to valve taper and valve configuration.

Inservice examination performed with Exam Category C-F-1 Appendix VIII demonstrated Item No. C5.21 procedure. Examination complete SI-210-FW-8 Fig. IWC-2500-7(a) from reducer side and limited from Reducer to Tee (4"-80) 2007 27 tee side in area of radius. Best effort 100% From Reducer Side examination of tee side in area of 54% From Tee Side radius performed through weld material.

Inservice examination performed with Exam Category C-F-1 Appendix VIII demonstrated Item No. C5.21 procedure. Examination complete Item No11-F C5 from elbow side and access limited Pipe to Elbow (3"-160) 2007 Fig. IWC-2500-7(a) 28 from pipe side in area of welded vent 100%0 FroEbline and elbow intrados. Best effort examination from pipe side in area of 60% From Pipe Side welded vent line and elbow intrados performed through weld material.

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 16 of 45 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 ECategory C-F-2 Ad Appicbl CdeReuirenent ASECd omponent>

CompnntI Of ppil figK imp~racticality of Compliance

~a~~and Coveraige Obtained~

Inservice examination performed with Exam Category C-F-2 Appendix VIII demonstrated Item No. C5.51 procedure. Examination complete MS-1-1-SW-18 Fig. IWC-2500-7(a) 29 from pipe side and no access from Weldolet to Pipe (8"-160) 2002 weldolet side due to weld crown and 100% From Weldolet Side taper. Examination coverage of 50% From Pipe Side weldolet side claimed from pipe side through weld material.

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 17 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32

,Weld 5

\\-

Steam Generator Support Steam Generator Primary Side Figure 1

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 18 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 300 4 (6')-

"/D I

3,5* -~

I stay Cyai~er SA 08 CL 3 Primary Hcad SA 509 CL 3

/

9 1-SGA-W4 Figure 2

St. Lucie Unit I Docket No. 50-335 L-2009-035 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 r-3O11(15*)

\\-r---;45* (17')-

00& 604 A

lileý Nozzle SA 508 CL 3 I

I I

C I-SGA-W5/1-SGB.W5 Figure 3

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 20 of 45 St. Lucie Unit 1 THIfRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 SI-112-1-SW-5 (TYPICAL)

CENTERLINE TEE FLOW b.

NOT TO SCALE X Limited exam area due to radius SI-112-1-SW-5 Figure 4

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 21 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 SI-112-1-SW-6 (TYPICAL)

CENTERLINE TEE REDUCER FLOW 6,

NOT TO SCALE Limited exam tire*

due to raidius SI-i 12-1-SW-6 Figure 5

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 22 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 S I-i 48-2-SW-4 (1YPICAL)

TEE CENTERUNE :1 PIPE FLOW

,NoY1 i~SCALfE SI-148-2-SW-4 Figure 6

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 23 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32

,SIl-I AS-FW-5 (TYPICAL)

CEr4TPLII.E V-3227 ELBaW FLOW NOT TO SCALE SI-148-FW-5 Figure 7

  • St. Lucie Unit 1 Docket No. 50-335 L-2009-035 24 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 RC-151l-FW-1 (TYPICALj CENTERLII-V-3227 ELBOW FLOW HOT TO SCALE RC-151-FW-1 Figure 8

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 25 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 SI-I 48-W-1 (rYPIOAL)

CENTEF*ME V-3fi4 PIPE 4

0 FLOW NOT TO SCALE SI-148-FW-1 Figure 9

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 26 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 RC-t I5-M-3-500F( typical)

CENTERLIN E PUMP

//

"SAFE END I

-~-

rLOW NOT TO SCALE RC-115-FW-3-500E Figure 10

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 27 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 RC.-I 09-FW-24H03 (TYPIGALj CENTEPAME V-1 219 PIPE FLOW HOT TO SCA.LE RC-109-FW-2003 Figure 11

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 28 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 RC-103-FW-2000 (TYPICAL)

View @ 180 Degrees Tee Nozzle 9$

Degrees

- Flow NOT TO SCALE

'9 RC-103-FW-2000 Figure 12

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 29 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 RC-103-FW-2002 (TYPICAL)

View @ 180 Degrees Pipe Tee I

270 Degrees Flow NOT TO SCALE RC-103-FW-2002 Figure 13

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 30 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 2-2701 (typical)

CENTERLINE FLANGE KOT TO SCALE 2-2701 Figure 14

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 31 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 2-2702(typical)

TUBESHEET NOT TO SCALE 2-2702 Figure 15

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 32 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 2-2742-1(typical) 2-2741-1(typical)

CENTERLINE I

I I

NOZZLE NOT TO SCALE 2-2742-1/2-2741-2 Figure 16

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 33 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 5 1-213-1 -SW-.2 (r'PI CAL)

CENTERLINE IRED4JCER 4$ ---

FL13W NOT TO SCALE SI-213-1-SW-2 Figure 17

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 34 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 S1-21O-F.W-6 (TYPICAL)

CEWTlEPLIW

a. -~ -

PiPE 1(

FLa*iV NOT TO SCALE SI-210-FW-5 Figure 18

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 35 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 So124Wl(TYPIICAL PO-:ýE V-3S15 FLOW NOT TO SCALE SI-129-FW-1 Figure 19

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 36 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 S1-113-FW-9 (TYPICAL)

Centerline V-3114 4,l FLOW NOT TO SCALE SI-113-FW-9 Figure 20

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 37 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 S 17212 14-A (TYR I CAL0 C3E NTE1jR I NE TEE FLOW Otbi TO, $j*4~ALE-,

SI-212-FW-1A Figure 21

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 38 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 SIl-212-FW-I (TYPICAL)

CENTERLINE I

Il:

I!

PIPE V-3656:

FLOW U.

NOT TO. SCALEr SI-212-FW-1 Figure 22

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 39 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 SI-1 05-FW-1 (TYPICAL)

CENTERLINE V-3656 PIPE L

FLOW NOT TO SCALE SI-105-FW-1 Figure 23

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 40 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 SI-213-FW (TYPICAL)

CENTERLINE V-3654 PIPE-NOT TO SCALE FLOW SI-213-FW-2 Figure 24

St. Lucie Unit I Docket No. 50-335 L-2009-035 41 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 S 1-21 0-FW-4 (TYPICAL),

CENTERLINE V-3653 PIPE 4

FLOW NOT TO SCALE, SI-210-FW-4 Figure 25

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 42 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 SI-209-FW-2 (TYPICAL)

I CENTERLINE V'1405' PIPE 4

FLOW NOT TO SCALE, SI-209-FW-2 Figure 26

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 43 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 U-21,0-FW-8.(TYPICAL)

CENTERLINE REDUCER FLOW

ý I

-I. I

_10 NOTTO SCALE X

Limited exam area, due to radius Limited exam area due to radius SI-210-FW-8 Figure 27

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 44 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 WELDED VENT LINE S1-211-1 -SW-2 (TYPICAL)

CENTERLINE

!ELBOW PIPE

FLOW, NOT TOSCALE

'6' FROM ZRP 6:5"FROM:.

ZRP A"-

INTRADOS (

OF ELBOW 110-5 FROM ZRP XTi RADOS OF 17

ELBOW ZRP 4, FROM ZRP SI-21 1-1 1-SW-2 Figure 28

St. Lucie Unit 1 Docket No. 50-335 L-2009-035 45 of 45 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32 MS-i-i-SW-i 84TYPICA CENTERLINE

)LET I

I,,

Jr m

WELDC 2--

di

~-

F>IPE l

FLOW I,-

NOT TO SCALE MS-I-I-SW-18 Figure 29