ML17215A594

Forwards Request for Addl Info Re Review of Inservice Insp Program.Info Requested within 30 Days of Ltr Receipt

ML17215A594
Person / Time
Site:	Saint Lucie
Issue date:	09/14/1984
From:	John Miller Office of Nuclear Reactor Regulation
To:	Williams J FLORIDA POWER & LIGHT CO.
References
NUDOCS 8410110563
Download: ML17215A594 (20)

Text

Docket No.: 50-389 I

SEP "-4 ]gpss DISTRIBUTION:

Mr. J.

W. Williams, Jr.

Vice President Nuclear Energy Department Florida Power 5 Light Company P. 0.

Box 14000 Juno Beach, Florida 33408 NRC PDR Local PDR ORB83 Reading DEisenhut OELD EJordan JNGrace DSells PKreutzer

ACRS, 10

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION, ST.

LUCIE PLANT, UNIT NO. 2, INSERVICE INSPECTION PROGRAM In the course of its review of the inservice inspection (ISI) program for St.

Lucie Plant, Unit No. 2, the staff has developed a need for additional informa-tion as indicated in the enclosure.

The staff reviewer and our contractor, Science Applications, Inc., are prepared to discuss these issues with you, if you desire.

1 You are requested to respond to this requ'est within 30 days of receipt of this letter or provide a date that you can meet within 15 days of r'eceipt of this letter.

Please contact the Project Manager, D. Sells on (301) 492-9735, if you should desire such a discussion or have any other questions.

This request for additional information affects fewer than ten respondents; therefore, OMB clearance is not required under P'.L.96-511.

Sincerely, OrtgnaI sIgn~5yF

Enclosure:

As stated cc w/enclosure:

See next page OR 3:

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utzer DSt;1 1 s/dn 9/I3 8/4 9/I /84 84iOii0563 8409i PDR ADOCK 05QQ0389

. 'DR James R. Miller, Chief Operating Reactors Branch P3 Division of'icensing B 3:DL RM'lier

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ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM ST.

LUCIE PLANT, UNIT NO.

2 By letter dated October 6, 1983, from R.

E. Uhrig (FPL) to D.

G. Eisenhut (NRC), the licensee submitted a proposed inservice inspection (ISI) program for St.

Lucie Unit 2's first 10-year inspection interval.

The staff will be evaluating this program and the documents referenced in it to review the sample of welds selected for examination and requests for relief from impractical examinations required by the 1980 Edition, Winter 1980 Addenda of Section XI of the ASME Boiler and Pressure Vessel Code.

If there are any additional relief requests or supporting information that needs to be considered, please provide the staff with copies.

If they have been previously furnished to the

NRC, please document by reference.

The following questions address the plan and the specific relief requests.

ISI PROGRAM 1.

Section 3.1 Pa e 3-1 Section

3. 1 states:

"During Preservice Inspection, there were cases where component configuration and/or interferences prohibited 100K coverage of the Code required volume or surface.

In each case where such limitations were encountered, the details were documented in a...

relief request.

Since those same conditions will prevail during

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Inservice Inspection, those relief requests are included for in-formation in this document, in some cases editorially revised to the grammatical tense consistent with Inservice Inspection."

Please confirm that the relief requests included in the ISI plan for the first 10-year interval are intended to be an integral part of the plan and not just included for information.

2.

A endixes H and I The Inspection Plan Examination Tables included in Appendices H and I reference a drawing for each zone.

The staff assumes that the referenced drawings are the inspection isometric drawings which are essential for evaluation of the ISI program.

Please provide copies of the inspection isometric drawings for the 70 zones covered'in Appendices H and I.

3.

A endixes H and I On some items the only entry in the ISI column on the Inspection Plan Examination Tables is a relief request identification.

The interpre-tation of this entry is not clear.

If examination of the item is not a mandatory part of the examination

sample, no relief is required.

If the examination is mandatory and is to be conducted within the limits of the referenced relief request, the ISI column should indicate that an examination is to be conducted.

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Please clarify the meaning of entries in the ISI column.

The final format for table entries should clearly specify which items are to be examined and which are not.

In addition, the t+le should clearly indicate which relief request, if any, is applicable.

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4.

A endices H and I The code requirements for extent and frequency of examination under examination Categories B-J and C-F, Pressure Retaining Welds in Piping, depend on the weld configuration.

In particular, welds in areas of high stress, dissimilar metal welds, welds at terminal ends and branch connections, and welds at structural discontinuities require examination during each interval. If the examination areas are not defined on the inspection isometrics to be provided under 2 above, discuss the methods that were applied to determine the extent and frequency of examinations included under Categories B-J and C-F.

Please illustrate the methods used for a typical zone, such as Zones 31 and 32, since these zones are difficult to evaluate with the information given in the tables.

For example, pages 31-1 and 32-2 include the examination areas for the Charging Line to Loop 2Bl, and pages 32-1 through 32-3 list the I

qxamination areas for the Charging Line to Loop 2A2.

Of the total 76 Category B-J welds in the charging

system, only 12 are scheduled for examination.

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Zone No.

70 combined CS 2A and 2B Inlet Piping from RMST (pages 70-1 through 70-10) and contains 47 circumferential piping welds;

however, only 8 circumferential piping welds are scheduled for examination.

Please explain the reason that the total number of welds to be examined in these systems is less than the 25X required by the Code.

5.

A endix H

Pa e 1-4 On page 1-4, Item 46 identifies the reactor vessel closure studs as a line item.

No ISI examination is specified, but examination note 3 states "surface and visual examinations are required, when disassembled, by USNRC I8E Bulletin 82-02."

The Code requi.res volumetric examination of the closure studs in addition to surface examination.

Is volumetric examination of the closure studs to be conducted in accordance with item B6.20 or B6.30?

Examination areas 114-1 and 123-1, Reactor Vessel Nozzle Extension-to-Pipe, are included on page 1-3 for Zone 1 and on pages 6-1 and 7-1 for Zones 6 and 7, respectively, and different inspection frequencies are specified; i.e., Item 114-3, will be inspected in the first period on page 1-3 and not at all on page 6-1.

Please clarify the discrepancy.

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7.

A endix H

Pa es 9-1 ll-l 13-1 and 15-1 On pages 9-1, ll-l, 13-1, and 15-1 of Appendix H, the safe end-to-pipe weld (Line Item No.

2 on all pages) is identified as Code Category B-F and reference is made to Relief Request No. 5, which addresses Category B-J.

The staff assumes that Code Category B-J should also be designated on pages 9-1, ll-l, 13-1 and 15-1.

Clarify this difference.

8.

A endix H

Pa es 30-1 and 33-1 On page 30-1, Line Item No. 1, and on page 33-1, Line Item No. la are included in Code Category B-F, Pressure Retaining Dissimilar Metal fields, but no examination is scheduled.

Please explain the reason that these Category B-F welds will not be examined.

9.

~Adi* I Many of the examination tables for zone numbers 42 through 80 contain the note "No exam required" (for example, see pages 42-1 and 43-8).

The use and meaning of this note are not clear.

The note is referenced for some areas where no examination is scheduled, but many areas for which no examination is scheduled do not reference this note.

Please clarify the use and meaning of the note "No exam required."

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10. ~Adi t

l The requirements for ISI specified in 10 CFR 50.55a include the requirement that appropriate Class 2 pipe welds in Residual Heat Removal (RHR) systems, Emergency Core Cooling (ECC) systems, and Containment Heat Removal (CHR) systems be examined.

The extent of examination for these systems shall be determined by the requirements of paragraph IWC-1220, Table IWC-2520, Categories C-F and C-G, and paragraph IWC-2411 in the 1974 Edition, through Summer 1975 Addenda of Section XI of the ASME Code.

The St.

Lucie 2 ISI plan acknowledges this requirement, but the piping to which this requirement applies is not specifically identified.

Discuss the procedure used for determining the piping system welds selected for examination.

Identify'he specific provisions of IWC-1220 that were used for each system.

Relief Requests 1.

Relief Re uest No.

1 -

a e 3-'7 (a)

Relief is requested from lOOX volumetric inspection of the lower shell to middle shell weld (101-171) in the reactor pressure ves-sel beltline region.

Inspection of 83K of this weld is achieved using ultrasonic scans at several angles.

Complete inspection cannot be achieved due to interference from surveillance speci-mens.

Would removal of the surveillance specimens allow a more complete inspection of the weld?

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(b)

One-hundred percent of the CRV (code-required volume) is effectively

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examined based on the combined results of UT scans at several angles for 13 of the welds listed in Table 3. 1 under Relief Request No.

1.

Why are the welds included under the relief request if 100K of the CRV was examined?

(c)

The request for relief for examination of the RPV closure head is not clear.

The table on pages 3-20 to 3-23 sum-marizes the incomplete examinations for the preservice inspection of the RPV closure head.

Is relief being requested during the first 10-year interval ISI for all the examinations which had less than 10(C coverage of the CRV during the preservice inspection?

The relief request for the RPV closure head should be in a more descriptive format; i.e.,

narrative discussion with summary tables that clearly state the examinations to be conducted and the impractical requirement.

2.

Relief Re uest No.

2 -

a e 3-47 The Preservice Inspection tables included in the relief request do not clearly indicate the extent of examinations to be conducted.

Please summarize the extent of examination to be conducted and clearly state the relief requested.

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3.

Relief Re uest No.

3 -

a es 3-57 and 3-61 In the table summarizing the incomplete examinations for which relief is requested, the volumetric examination coverage for the 60-degree angle scan is not clear.

The comment under Items 3.10, 3.11, 3.12, 4.10, 4.11, and 4.12 indicates that 13K of the CRV is missed on the 60-degree angle

scan, but 93K CRV is reported for the 60-degree transverse scan coverage.

Please clarify this apparent discrepancy.

4.

Relief Re uest No.

6 Relief is requested from lOOX volumetric inspection of 50 pressure retaining welds under Category B-J.

In the technical justification, confirm that the code required surface examinations will be conducted for all the welds which cannot be examined volumetrically.

5.

Relief Re uest No.

9 Relief is requested from volumetric inspection of the nozzle-to-shell weld on the shutdown cooling heat exchanger (Items 55.3 and 55.6, pages

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3-188 and 3-189) since the weld is inaccessible due to the installation of a weld pad (Fig. 2.9-2, page 3-191).

As an alternative, will a surface examination be conducted on the. pad-to-nozzle weld and the pad-to-shell weld?

Reference 1.

R.

E. Uhrig to 0.

G. Eisenhut, Inservice. Inspection Program for St.

Lucie 2, Volumes I and II.

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