ML12114A058

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Third Ten-Year Interval Unit 2 Relief Request No. 13
ML12114A058
Person / Time
Site: Saint Lucie 
Issue date: 04/12/2012
From: Katzman E
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2012-166
Download: ML12114A058 (19)


Text

FPL.

Florida Power & Light Company, 6501 South Ocean Drive, Jensen Beach, FL 34957 April 12, 2012 L-2012-166 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 Pursuant to 10 CFR 50.55a(a)(3)(ii), Florida Power & Light (FPL) requests relief 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 and future required volumetric examinations. The details and justification for this request are provided in the attachment to this letter.

FPL requests approval of this relief request to support the upcoming Unit 2 SL2-20 Spring /

Summer 2012 refueling outage 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/K WF 4041 P a)L an FPL Group company

L-2012-166 1 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 Relief Request In Accordance with 10 CFR50.55a(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 10CFR50.55a,[21 is the code of record for the St. Lucie Unit 2, 3 rd 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-2012-166 2 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0

3.

Applicable Code Requirement

ASME Code Case N-770-1 as Amended by 10CFR50.55a(g)(6)(ii)(F)(4)

CLASS 1 PWR Pressure Retaining Dissimilar Metal Piping and Vessel Nozzle Butt Welds Containing Alloy 82/182 Insp Extent and Frequency of Examination Part Exained Item 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 XI, 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 I

I refueling outage after January 20, 2012.

As defined by ASME Code Case N-460,1 31 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 Xl, Appendix VIII, Supplement 10, "Qualification Requirements for Dissimilar Metal Piping Welds" is applicable to dissimilar metal welds without cast materials.

ASME Section Xl, 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 and future required volumetric examinations.

L-2012-166 3 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0

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.
3) During refueling outages, system engineers walkdown Class 1 systems inside containment. This walkdown is performed to look for system anomalies that could affect plant performance.
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.
5) Coverage results which are less than those obtained in earlier inspections, as shown in Table 1, will be compiled and provided to the NRC, in the form of a revision of the relief request. Such a request will be prepared as soon as the coverage issue is identified, so relief can be obtained in a timely basis.

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 (TcoId) 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. 5 1 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]

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. 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.

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

L-2012-166 4 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 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.

Therefore, FPL satisfied the examination volume coverage requirements identified in MRP-139.

The amount of coverage that could be credited was determined in accordance with the qualified examination procedure utilizing field obtained contours. Qualification for the UT examination of the cast material is "in the course of preparation." No coverage is claimed

L-2012-166 5 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 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.

Table 1 provides the percent of coverage credited for MRP-139, 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 carbon steel base material and susceptible material. As shown in Table 1, essentially 100% of the examination volume coverage for the safety significant circumferential flaw in the carbon steel base material and susceptible material was achieved during the MRP-139 examinations.

However, the MRP-139 axial flaw examination volume coverage did not satisfy the essentially 100% requirement. 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-109 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 XI, 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 coverage would be a hardship that would not result in an increase of health and safety to the public.

L-2012-166 6 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 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-16456.J91 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 it 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.

7.

Duration of Proposed Alternative Third Inservice Inspection Interval

8.

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 Xl, 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.
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

L-2012-166 7 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 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-2012-166 8 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 Table 1 MRP-13911I N-770-1121 Nozz Insp.

Volume Volume Angle/

Component ID Location Size Item Coverage Coverage Wave Fig.

Comments/Limitation Cat.

Axial Circ Axial Circ Mode Flaw Flaw Flaw Flaw RCP 2A1 Inlet 25-70L RC-112-1501-771-C Elbow(CS) to Safe-end 30 B

69%

100%

50%

73%

35-65S 1

Cast SS, Weld Taper (Cast SS)

I I

RC-12-1066-771 RCP 2A1 Outlet Safe-end 30 B

66%

100%

49%

74%

25-70L 2

Cast SS, Weld Taper RC-112-1066-771 (Cast SS) to Pipe(CS)35-65S 2

_CastSS,_WeldTaper RCP 2A2 Inlet 25-70L RC-115-1501-771-A Elbow(CS) to Safe-end 30 B

64%

100%

52%

82%

35-65S 3

Cast SS, Weld Taper (Cast SS)

RCP 2A2 Outlet 25-70L RC-115-701-771 Safe-end (Cast SS) to 30 B

68%

97%

49%

71%

35-65S 4

Cast SS, Weld Taper Pipe (CS)

RCP 2B1 Inlet 25-70L RC-121-1501-771-B Elbow (CS) to Safe-end 30 B

66%

99%

52%

78%

35-65S 5

Cast SS, Weld Taper (Cast SS)

RCP 2B1 Outlet 25-70L Cast SS, Weld Taper, Spray RC-121-901-771 Safe-end (Cast SS) to 30 B

64%

99.4%

51%

77.9%

35-65S 6,7 Nozzle Pipe (CS)

RCP 2B2 Inlet 25-70L RC-124-1501-771-D Elbow (CS) to Safe-end 30 B

67%

100%

49%

72%

35-65S 8

Cast SS, Weld Taper (Cast SS)

RCP 2B2 Outlet 25-70L 9,

Cast SS, Weld Taper, Spray RC-124-1301-771 Safe-end (Cast SS) to 30 B

66%

99.1%

50%

77%

35-65S 10 Nozzle Pipe (CS)

I I

I I

I Note 1-For the MRP-139 axial and circumferential flaw examination volume coverage achieved, the calculation includes the carbon steel 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-2012-166 9 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 0.25j Ii DIM Cast SST Weld Safe End Cs Elbow MRP-139 Inspection' Examination Volume (1.98 sq. in.)

Cast SST Inspection Examnation Volume

(.73 sq in.)

ASME Section XI Inspection Examination Volume (Cast SST. MRIP.139) 12.71 sq. in.)

Axial Scans (Circumferential Flaws) 100% Coveraqe -MRP-139 Exam Volume 73% Coverage-ASME Exam Volume ((2.71-.73)12.71" 100)

(Cast SS exam volume excluded)

- MRP-139 Inspection Examnmation Volume Limitation (per EPRI-OMW-PA-1 exam volume can be daimed up to weld centetline) (.62 sq. in.)

Circ Scans (Axial Flaws) 69% Coverage-MRP-139 Volume ((1.98-.62)1198" 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 1 2A1 RCP Inlet (RC-112-1501-771-C)

L-2012-166 10 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 Cast SST CS Pipe I

Cast SST Inspection Examination Volume (0.64 sq. In.)

ASME Section )a Inspection Examination Volume (Cast SST. MRP-139)

(2-42 sq. in.)

LMRP-139Inspection Examination Volume (1.78 sq. In.)

MRP-139 Inspection Examination Volume Limitation (per -j EPRF4aW-PA-1 exam volume can be claimed up to weld centerfine) (0.60 sq. in.)

//,

All four contours allow the transducer to be scanned over part of the weld: thus kpieremeant of the URP eusminaton volume with beam angles between 40- and 50-degrees Is practical with no limitalion.

Axial Scans (Circumferential Flaws) 100% Coverage - MRP-139 Exam Volume 74% Coverage - ASME Exam Volume (C2 0.64)f2.42 *100)

(cast SS exam volume excluded)

Circumferential Scans (Axial Flaws) 66% Coverage. MRP-139 Exam Volume ((1.78.0.60)l1.78 100) 49% Coverueo - ASME Exam Volume ((2.42.0.64-0.60112A2

  • 1001 (cast SS exam volume excluded. exams not conducted en weld due to taper)

Figure 2 2A1 Outlet (RC-1 12-1066-771)

L-2012-166 11 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 0.25 -"j --

"'i---*--.m *

\\

-Cast SST Inspection Examination Volume (2.65 sq. in.)

Examination Volume

(.60sq. in.)

ASME Section XI Inspection Exam inalion Volume (Cast SST + MRP-139)

(3.25 sq. in.)

I'-11-W7 380-151-057

,2 -7(r TRL 26*

-70' TRL S.°65 TR.Sq_ 36°-W6 TRS

  • W R

-._ MRP-139 Inspection Examination Volume Limitatior Axial Scans (Circumferential Flaws)

(per EPRI-DMW-PA-1 exam volume can be claimed up 100% Coverage -MRP-1 39 Exam Volume to word centertineI(.96 sq. in.)

821% Coveraqe-ASM E Exam Volume ((3.25-.60)13.25"100)

(Cast SS exam volume excluded)

Circ Scans (Axial Flaws) 64% Coveraoe-MRP-139 Volum e ((2.65-.96)/2.65*100) 52% Coverage-ASME Exam Volume (3.25-96-60)/13.25°100)

(cast SS exam volume excluded; exams not conducted on weld due to taper)

Figure 3 Ca-t S ST l

8M CS Sale End Vlbd Pipe RA

L-2012-166 12 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 UI!P-1 lispec~t Dcamlmflm"-ý#

ollme Unnalhot (fasq. hb Aoial Scans (Orcumlerenial Flaws) 07% Coveraoe-MRP-130 Exam\\,blume ((1.63-f48y1.63'100) 71% Coverame-ASME ExamnVolume ((2.29-D48-A01y229arl0)

(Cas SS eam Iolume excluded)

MRP-139 hspection EBarinaton \\olurre Limitadon-t (per EPRDMWP*PA1I exm votume can be daimed up to weld centeriine)(.63 sq. in.)

Circ Scans (Axial Flaws) 08% Coverage-MRP-139 Volume ((1.83-;53Y1.63Q1100) 40% C overage-ASME Exam Volume (2-24-.53-.01)Q2.247100)

(castSS exam volume excluded; exams notconducted on wueld duetotaper)

Figure 4 2A2 Outlet (RC-115-701-771)

L-2012-166 13 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 EDM Cast SST

,Weld, Safe End CS Elbow MRP-139 Inspection Cast SST Inspection Examination Volume (1.94 sq. in.)

Examination Volume

(.53sq. in.)

SASME Section X) Inspection Examination Volume (Cast SST

(2 47 sq in.)

36" l

- --- 1 j360-11511O57 26-70 TRL 263.70, TL 135"-66" TR.

'.35-o65-TR

.MRP-139 Inspection Examination Volume Limitation

(.01 sq. in.)

Axial Scans (Circumferential Flaws) 99% Coveraae -MRP-139 Exam Volume ((1.94-.01)11.94'100) 78% Coveraoe-ASME Exam Volume ((2.47-.53-.01112.47*100)

(Cast S5 exam volume excluded)

- 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% Coveraoe-MRP-139 Volume ((1.94-.65)/1.94*100) 52.% Coverace-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 5 281 Inlet (RC-121-1501-771-B)

L-2012-166 14 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 0.25 0.25 CastSST DM CS Weld //

Pipe MRP-139 Inspection Examination Volume (1.97 sq. in.)

ASME Section XI Inspe Examination Volume (Cast SST + MRP-1 39)

(2.51 sq. in.)

AtI 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.

Mdal Scans (Circumferential Flaws) 99.4% Coverage-MRP. 139 ExamVolume (see detailed evaluation) 77.9% Coversge-ASME Exam Volume((

2. 54.2.5110 -(t 0-99 4))

(cast SS exam volume excluded)

MRP-139 examination volume coverage over total OD circumference with no obsturctions=91.5"°1.97 sq.

in.=180.3 cu. it.

% of total MRP-139 examination volume outside of obstructed areas= 180.3Y191.5'100=94.2%

% MIRP-1 39 examiantion volume covetaqe around Spray Nozzle = 4.952=9.9 cu in: 9.9.191.51 00=5.2%

% MRP-139 e aminaion volume coverage is obsturcted arsa =5.2%

Total % Examination Coverage of MRP-139 Examination Volume=94% 5 2%=99 4%

MRP.13 InsoPection Earrsnation Volume Limklaron (per EPR -DMW-PA-1 exam volume can be claimed up to weld centerdne) (.70 sq. in )

Circ Scans (Axial Flaws) 64% Coverage.MIRP-139 Volume(l.-

9 7-.70)il.97"100) 51% Coveraqe-ASME Exam Volume(2.51-.5 4-.

7 0Y2.51'100)

(cast SS exam volume excluded: exams not conducted on weld due to taper)

Figure 6 2B1 Outlet (RC-121-901-771)

L-2012-166 15 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 Figure 7 2B1 Outlet (RC-121-901-771)

L-2012-166 16 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 0.25 0

D t DM 1 Weld Cast SST C S Safe End Elbow MRP-139Inspection Cast MS Insection Examination Volume (1.66 sq. in Examination Volume

.ASME Section XInspection Eiamnation Volume (Cast SST - r.IRP-139)

(229 sq. in-)

6 -151-057 M8-1161 -057 i360-151-057 5 -70w TRL 25-70 TRL i25*-70' TRL 5

35°,65° TRS I35-65° TRS

-/

'2.

skew t1 Z

"'x MRP-139 Inspection Examination Volume Limitatit (per EPRI-DMW-PA-1 exam volume can be claim Axial Scans (Circumferential Flaws) to weld centerline) (.54 sq. mi) 100%Coveraoe -MRP-139 Exam Volume Circ Scans (Ax ial Flaws 72% Coverage-ASME Exam Volume(( 2 29-.63)/2.29"100) 67% Coverage-FRP-1 39 Volume ((1.66-.54)/1.66"100)

(Cast SS exam volume excluded) 49% Coveraoe-ASME Exam Volume (2.29-.54-.63.'2.29 100)

(cast SS exam volume excduded: exams not conducted on weld due to taper)

Figure 8 2B2 Inlet (RC-124-1501-771-D)

L-2012-166 17 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 521 OM W;. d Cast SST cs Pipe Cst SST inspectlon Examination Volume (0.64 S4. in.)

ASME Section X1 Inspection Examination Volume (Cast SST MRP-139)

(20.6 q.

qi.)

SMRP-139 Inapecion Examination Volume (1.98 sq. In.)

360-151-057 360-151-057 25-701 TRIL 1

25' - 70' TRL 359 65' TRS 3

-65. TRS I--,

t~i;......

2 C?

.11, 112t All four contours allow the transduMr to be scanned over part of the weld; thus impingement of the MRP examination volume with beam angles between 40- and 50-dge6s -IS practical With no limitation.

Axial Scs.s (CincumferentIat Flaw.)

99.1% Coverage

  • MRP-139 Exam Volume (see detailed evaluation) 77% Coverawe - ASME Exam Volume ((2.62 - 0.64)12.62 "100 - (100 - 99.11))

(cast SS oxam volume excluded)

MRP-139 examination volume coverage over total Of circumference with no obstructions = 90.4' 1.98 sq. in. = 179 c

% of total MRP-139 examination volume outside of obstructed areas = 1791189.3' 100 = 94.6%

% MRP-139 examination volume coverage around Spray Nozzle = 4.25

  • 2 = 8.5 cu in: 8.5/189.3 100 = 4.5%

% MRP-139 examination volume coveraoe in obstructed areas = 4.5%

Total % Examination Coverage of MRP-1 39 Examination Volume = 94.6% + 4.5% = 99.1%

MRP-139 Irnoe*tion Examination Volume Limitation (per EPRI-OMW-PA-1 easm volume can be Mimed up to wield cenftodlne)(0,68 sq. In.)

1~~-*'

4 1

C-Circumferential Scans (Axial Flawnl 66% Coverage - MRP-139 Exam Volume (f1.500d.68)Jt.08 10) 50% Coveraae - ASME Exam Volume (12.62-0.640.68)2M62

  • 1001 tcast S5 exam volume excluded, assumes only partial Scans on Weld)

Figure 9 2B2 Outlet (RC-124-1301-771)

L-2012-166 18 of 18 St. Lucie Unit 2 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13, REVISION 0 I

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Figure 10 2B2 Outlet (RC-124-1301-771)