ML17215A651

Forwards Response to 840914 Request for Addl Info Re Inservice Insp Program.Drawings Undergoing General Rev for Incorporation of as-built Field Changes & Clarification

ML17215A651
Person / Time
Site:	Saint Lucie
Issue date:	11/19/1984
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	John Miller Office of Nuclear Reactor Regulation
References
L-84-340, NUDOCS 8411260272
Download: ML17215A651 (25)

Text

I"

'EGULATORNFORNATION OISTRIBUTION STEN (RIDS)

ACCESSION NBR:8411260272" DOC ~ OATEN'4/li/19 NOTARIZED: NO -DOCKE,T' FACIL 50 389 St ~ Lucie Plantg Uni t 2~,F)orida Power L Light Co, 05000389 AUTH S NAME'UTHOR AFFILIATION WILLIAMS>JBH, Florida Power 5 Light Co, REC IP ~ NAME 'ECIPIENT AFF IL'IATION MILLER',RB Operating Reactors Branch 3 SUBJECTS'orwards response to 840914request foraddi info re inservice insp,program. Drawings undergoing general rev for. incorporation of-as-buil.t field "changes 8 clarification,, j DISTRIBUTION CODE; A047D COPIES RECEl)ED!LTR- ENCL SIZE'"

TITLE: OR Submittal! Inservice Inspection/Testing NOTES!. 05000389 OL!04/06'/83I

,. RECIPIENT COPIES RECIPIENT COPIES

'ID CODE/NAME LTTR ENCL' ID CODE/NAME LTTR'NCL<

NRR'RB3 BC 01 7 INTERNAL, ACRS 16 10 10 ADM/LFMB .1 0.

ELD/HDS2 1- 0 NRR/DE/MEB 15 1 1 Ke .1 .

1 NRR/DL/TAPMG 1 R FI 04 1 1 RGN2 1 1 4

EXTERNAL'PDR 03 1 1 NRC PDR 02 1 1 NSIC 05 1 1 NTIS 1 1 TOTAL NUMBER OF COPIES REQUIRED! LTTR 28 ENCL 26'

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FLORIOA POWER 5 LIGHT COMPANY November 19, 1984 L-84-340.

Office of Nuclear Reactor Regulation Attention: Hr. James R. Miller, Chi.ef Operating Reactors Branch .83 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Dear Mr. Hiller Re: St. Lucie Unit 2 Docket No. 50-389 Request for Additional Informati'on Inservice Ins ection'Pr'o ram Florida Power 5 Light has reviewed the NRC letter dated September 34, ]984, which requested additional information concerning the Inservice Inspection Program at St. Lucie Unit 2.

The information requested is attached.

Should you or your staff have any questions on this information, please contact us.

Very truly yours, J. W. Williams, Jr.

Group Vice President Nuclear Energy JWW/PLP/cas cc: J.P. O'Rei lly, Region II Harold F. Reis, Esquire PNS-LI-84-370-2 P84i126027p 84gl19 ADOCK 050ppp89 PEOPLE... SERVING PEOPLE PDR

Page 1 of 17 Response to NRC Questions St ~ Lucie Unit P2 1 ~ Section 3.1 Pa e 3-1 Section 3 ~ 1 states: "During Preservice Inspection, there were cases where components configuration and/or interferences prohibited 100% 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 Inservice Inspection, those Relief Requests are included for information 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 are applicable to the planned inspections (not just included for information)'ESPONSE:

The Relief Requests are intended to be an integral part of the plan and wil1 be modified to reference only those items which are scheduled for examination during the first Inspection Interval.

2. A endices H and I The Inspection Plan Examination Tables included in Appendices H and reference a drawing for each zone. He assume 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.

RESPONSE

The subject drawings are currently undergoing general revision for incorporation of field changes (AS-BUILT) and clarification. These will be incorporated by revision to the ISI plan, due for issue hy April 14, 1985.

Copies of the revised document, including the drawings, will be sent to the NRC at that time.

Page 2 of 17

3. A endices 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 interpretation 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, however, 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. 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 table should clearly indicate which relief request, if any, is appli.cable.

ANSWER:

The table entries clearly specify which items are to be examined and which are not. In addition, the table clearly indicates which relief request, if any, is applicable.

As stated in Section 6.0, "Inspection Plan Examination Tables", paragraph 6.1.16, "ISI Interval", items to be examined during the interval are designated by a single digit (1, 2, or 3) representing the period in which it will be examined. This column also denotes the applicability of Relief Requests using the notation ",RR" 'ollowed by a number representing the applicable Relief Request.

See the response to Question 81 for additional clarification.

4. A endices H and I A. 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, please indicate how these specific requirements were applied to determine the extent and frequency of examinations included under Categories B-J and C-F. Please illustrate by example for a typical zone, such as Zones 31 and 32, Zones 3 1 and 32 are diffulcult to evaluate with the information given in the tables; for example, pages 3 1-1 and 3 1-2 include the examination areas for the Charging Line to Loop 2B1 and pages 32-1 through 32-3 list the examinatioh areas for the Charging Line to Loop 2A2. Of the total 75 Category B-J welds in the charging system, only 12 are schedule'd for examination-B. Zone No. 70, Combined CS 2A and 2B Inlet Piping from RWST, on pages 70-1 through 70-10 contains 47 circumferential piping welds, but only 8 circumferential piping welds are scheduled for examination. Please explain why the total number of welds to be examined in these systems is less than the 25% required by the Code.

~ ~

Page 3 of 17 uestion 4 (continued)

RESPONSE: Part A Cate or B-F 100% of all category B-F welds were selected to be examined in the first inspection interval.

Cate or B-J Class 1 piping welds classified as B-J in accordance with the table IWB-2500-1, except as exempted by IWB-122(b), made up the group of piping welds which are subject to selection. Class 1 selections were broken down into three categories which included butt welds, sockets welds and branch connections, based on the "Examination Area Decription" column of the Inspection Plant examination tables. The total number of welds of each type within category B-J was determined and then the mmber required to achieve a 25% selection of each type was computed. The welds selected were distributed among the various types (i.e. pipe-to-pipe, pipe-to-tee, pipe-to-elbow, etc. ) using the following criteria: e A. Terminal ends at vessels are scheduled for examination.

r B. Where possible, welds in a particular zone were grouped so that the ones selected were in close physical proximity. This grouping minimizes the time required for insulation removal, examination and weld location and results in reduced personnel radiation exposure. Also, welds selected were distributed among the various, line sizes represented. As a result of the above selected method, some zones will have more than 25% of all non exempt category B-J welds.

4 At tached is a summary breakdown of the total welds of each type of zones including category B-J welds. The number of welds selected in each zone is indicated in parenthesis. Longitudinal seams are not designated in this breakdown; it should be understood that 12" of the long seams that intersect circumferential welds selected for examination, will be examined.

The selection criteria for Category C-F is explained in greater detail in the response to Question 810 of this submittal.

Page 4 of 17 TABLE 1 Butt Welds Branch Welds Socket Welds Zone I! Descri tion Existin Selected Existin Selected Existin Selected Main Coolant 2(a) 0 0 Main Coolant 2(a) l(d)

Main Coolant 1(a) + 4(b) 0 Main Coolant 1(a) 10 Main Coolant 1(a) 1(d)

Main Coolant 1(a) 2(d) 12 Main Coolant 1(a) 0 13 Hain Coolant l(a) 14 Main Coolant l(a) 15 Main Coolant 1(a) 16 Surge Line l(a) + 5(b) 17 thru 20 RC Pumps NA NA NA NA NA NA 21 SI-Loop 2Al 21 8(b) 22 SI-Loop 2A2 '9 3 (b) 23 SI-Loop 2B1 28 4 (b) 24 SI-Loop 2B2 19 4 (b) 25 Press. Spray 10 0 26 Press. Spray Loop 2B1 25 6 (b) 27 Press. Spray Loop 2B2 25 6 (b) 0 28 Shutdown Clg. Loop B 37 7(d) 2(d) 12 0 29 Shutdown Clg. Loop A 34 7(d) 0 10 0 30 Aux. Spray 6(b) 23 20(b) 31 Charging Loop 2B1 0 19 7(b) 32 Charging Loop 2A2 1(b) 42 8(b) 33 2A1 Drain 0 0 34 2A2 Drain 0 0 35 2Bl Drain 1(b) 3 (b) 36 2B2 Drain 0 0 37 Letdown 5 (b) 31 30(b) 38 Relief 20 8(b) 0 340 13(a) + 22 6(d) 157 68 (b)

TOTALS 61(b) +

14(d) =

88 Total

Page 5 of 17 TABLE 2 Zone Line Item Weld Selection Basis No. I.D. No. B-J (la, b or d) 1 114-1 (a) 12 201-258 (a) 1 123-1 (a) 10 205-771 (d) 12 201-258 (.)

1 115-4 (b) 5 115-3 (b) ll 17 115-2 115-1 (b)

(b) 20 401-258-B (a) 115-6 (a) 10 la 401-258-3 (a) 18 1413-771-B (d) 8 121-6 (a) 11 812-771 (d) 13 806-771 (d) 12 la 401-258-A (a) 13 112-6 (a) 14 la 401-258-A (a) 15 124-6 (a) 16 la 301-771 (a) 2 106-751 (b) 4 107-751 (b) 5 RC-108-FW-2 (b) 7 101-751 (b) 8 102-?51 (b) 21 3 RC-151-1-SW-1 (b) 5 SI-148-FW-5 (b) 8 SI-148-FW-4 (b) 9 SI-148-FW-801 (b) 14 148-2-SW-5 (b) 16 148-2-SW-3 (b) 19 SI-516-FW-1 (b) 23 SI-148-FW-1 (b) 22 3 SI-149-FW-4 (b) 16 SI-149-Hf-1 (b) 21 SI-515-FW-2 (b)

Page 6 of 17, TABLE 2 Cont.

Zone Line Item Weld Selection Basis No. I.D. No. B-J (la, b or d) 23 5 SI-150-FW-4 (b) 22 SI-150-FW-1 (b) 27 517-'1-SW-4 (b) 28 517-1-SW-3 (b) 24 5 SI-1.5l-FW-4 (b) 18 SI-151-FW-1 (b) 20 151-1-SW-4 (b) 23 SI-518-FW-1 (b) 25 10 103C-SW-1 (b) These three welds 11 103C-SW-3 (b) are actually Cate~

12 103C-SW-2 (b) B-F and are not counted for B-J.

26 8 RC-109-FW-909 (b),

9 RC-109-FW-908 (b) 18 RC-109-FW-903 (b) 19 109C-SW-2 (b) 25 109A-SW-2 (b) 26 109A-SW-1 (b) 27 9 RC-141-FW-910 (b) 10 RC-141-FW-909 (b) 16 RC-141-FW-906 (b) 17 RC-141-FW-905 (b) 18 RC-141-FW-904 (b) 19 141C-SW-1 (b) 28 1 RC-147-FW-1 (d) 6 147-1-SW-1 (d) 7 147-1-SW-2 (d) 47 SI-378-FW-901 (d)

~9 378-2-SW-2 (d) 51 SI-378-FW-3 (d) 59 SI-191-SW-3 (d) 29 1 SI-190-FW-1 (d)

2. SI-190-FW-901 (d) 18 162-1-SW-5 (d) 20 162-1-SW-3 (d) 31 SI-127-FW-1 (d) 38 127-1-SW-1 (d) 47, SI-378-FW-2 (d)

Page 7 of l7 TABLE 2 Cont.

Zone Line Item Weld Selection Basis No. I.D. No. B-J (la,b or d) 30 2 RC-149-SW-1 (b) 3 CH-146-FW-28 (b) 4 CH-146-FW-27 (b) 5 CH-146-FW-26 (b) 6 CH-146-FW-23 (b) 8 CH-146-SW-21 (b) 9 CH-146-Ft<-20 (b) 10 CH-146-SW-19 (b) ll 12 CH-146- TW-18 CH-146-SW-17 (b)

(b) 13 CH-146-FW-16 (b) 14 CH-146-SW-15 (b) 15 CH-146-SW-14 (b) 16 CH-146-SW-13 (b) 17 CH-146-FW-12 (b) 19 CH-146-FW-ll (b) 20 CH-146-SW-8 (b) 21 CH-146-SW-9 (b) 23 CH-146-SW-7 (b) 24 CH-146-FW-6 (b) 25 CH-347-FW-2 (b) 26 CH-347-SW-1 (b) 27 CH-146-SW-5 (b) 28 CH-146-SW-4 (b) 30 CH-146-SW-2 (b) 31 CH-146-FW-1 (b) 31 7 CH-148-SW-7 (b) 12 CH-148-FW-12 (b) 13 CH-148-SW-13 (b) 16 CH-148-SW-16 (b) 17 CH-148-SW-17 (b) 23 RC-150-SW-2 (b) 24 RC-150-SW-3 (b) 32 7 CH-147-SW-43 (b) 9 CH-147-SW-41 (b) 13 CH-147-SW-37 (b) 14 CH-147-SW-36 (b) 15, CH-147-SW-35 (b) 40 CH-147-FW-9 (b) 45 CH-147-SW-5 (b) 46 CH-147-FW-4 (b) 50 RC-148-SW-2 (b)

Page 8 of 17 TABLE 2 Cont.

Zone Line Item Weld Selection Basis No. I.D. No. B-J (la, b or d) 33 34 35 RC-122-FM-1 (b)

RC-122-FW-2 (b)

RC-122-SW-3 (b)

RC-122-SW-4 (b) 36 37 1 RC-142-FW-1 (b) 2 RC-142-SW-2 (b) 3 RC-142-SW-3 (b) 4 RC-142-SW-4 (b) 5 RC-142-FW-5 (b) 6 RC-142-SW-6 (b) 7 RC-142-FW-7 (b) 8 RC-142-SW-8 (b) 9 RC-142-FW-9 (b) 10 RC-142-SW-10 (b) ll RC-142-FW-ll RC-142-SW-12 (b) 12 (b) 13 RC-142-FW-13 (b) 15 RC-142-FW-19 (b) 16 RC-142-FW-18 (b) 19 RC-142-FW-17 (b) 20 CH-145-SW-1 (b) 21 CH-145-SW-2 (b) 22 CH-145-SW-3 (b) 23 CH-145-SW-4 (b) 24 CH-145-SW-5 (b) 25 CH-145-SW-6 (b) 20 CH-145-SW-7 (b) 28 CH-145-FW-8 (b) 29 CH-145-SW-9 (b) 30 CH-145-SW-10 (b) 31 CH-145-SW-11 (b) 32 CH-145-SW-12 (b) 33 CH-145-SW-13 (b) 35 CH-145-SW-15 (b) 36 CH-145-SW-16 (b) 37 CH-145>>SW-17 (b) 38 CH-145-SW-18 (b) 39 CH-145-FW-19 (b) 40 CH-145-FW-20 (b)

Page 9 of 17 TABLE 2 Cont.

Zone Line Item Weld Selection Basis No. I.D. No. B J (la, b or d) 38 4 RC-309-FW-2 (b) 10 101-1-SW-13 (b) 11 RC-101-FW-1 (b) 13 101-1-SW-7 (b) 14 101-1-SW-6 (b) 15 101-1-SV-5 (b) 16 101-1-SH-4 (b) 22 310-1-SW-1 (b)

Page )0 of 17 Res onse to uestion 4 continued RESPONSE: Part B Per the requirements of the 1974 Edition through the Summer 1975 Addenda of Section IX, 25% of the welds requiring examination must be selected.

Criteria in Table IWC-2520, Category C-F exempts* pipe-to-pipe welds from examination requirements if located greater than 3 pipe diameters from rigid restraints, etc. Of t'e 47 circ welds in Zone 70 only 33 are subject to examination per IWC-2520, the remainder are pipe to pipe, 25% of those subject to exam is ~8 hence the eight (8) welds selected for exam.

(*Pipe-to-pipe welds are not, by definition structural discontinuities".

See Footnote 1 under Code Category C-F in the above referenced 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 exam note 3 which states that "surface and visual examinations are required, when disassembled, by USNRC I&E Bulletin 82-02" is referenced. The Code requires 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 B6.307?

RESPONSE

Volumetric and surface examinations shall he conducted in accordance with Code Item No. B.6.30 in the 3rd inspection period. This was inadvertantly omitted from the 'plan due to" clerical error. The inspection plan will be corrected in the general revision to be issued by April 1, 1985.

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 114-1 will be inspected in the first period on page 1-3 and not at all on page 6-1. Please clarify.

RESPONSE

The ultrasonic examination of the subject welds is conducted from the nozzle bore, utilizing remote mechanized techniques. The surface examinations are conducted from the O.D. This accounts for the welds being included in both the RPV Zone (1) and the piping Zones (6, 7, 9, 11, 13, and 15).

There is an apparent error for all 6 welds in all zones above. In summary, all 6 welds are considered terminal ends per Category B-J criteria and will be scheduled for examination. This will be documented in the general revision to the ISI Plan, to be issued April 1, 1985.

Page 11 of 17

7. A endix H Pa es 9-1 ll-l 13-1 and 15-1 On pages 9-1, 11-1, 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. Relief Request 5 addresses Category B-J. We assume that Code Category B-J should also be designated on pages 9-1, 11-1, 13-1 and 15-1.

RESPONSE

The .Code Category designations and Relief Request applicability are correct as listed on pages 9-1, 11-1, 13-1 and 15-1. The error exists in the Relief Request itself, which should also address Code Category B-J, which is the category of the Reactor Coolant pump-to-safe end weld. Relief Request f/5 will be revised to address both code Category B-F and B-J, since both categories are represented in this particular weld configuration.

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 Hetal Welds, but no examination is scheduled. Please explain why these Category B-F welds will not be examined.

RESPONSE

These examinations were inadvertantly omitted and had already been identified for correction in the aforementioned Plan Revision. Item 30.1 will be examined in the 3rd period, item 33.1a will be examined in the 1st period.

Hany 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 examinati.on is scheduled, but many areas for which no exam is scheduled do not reference this note. Please clarify the use and meaning of the note "No exam required".

RESPONSE

Table IWC-2500-1, Examinat ion Category C-F, "Pressure Retaining Jelds in 3

Piping", Note (1) (d) required the examination of "additional welds at STRUCTURAL DISCONTINUITIES. .". ~ Structural discontinuities are defined in Note (1) (f); the definition does not include pipe-to-pipe welds. Please, observe that, in each case where the note "No exam required" is invoked, the description of the joint in the "Examination Area Description" column is "Pipe-to-Pipe".

Please refer to paragraph 6.1.3 of the plan for addition information.

Per the requirements of the 1974 Edition through the Summer 1975 Addenda of Section XI, 25% of the HELDS REQUIRINC EXAMlNATION must be selected. Criteria in Table IWC-2520, Category C-F exempts pipe-to-pipe welds from examination requirements if located )3 pipe diameters from rigid restraints, etc.

The pipe-to-pipe welds are included on the isometric drawings and in the Inspection Plan sheets to provide details of the entire piping systems only. Tn making our 25% sample allocation they were not counted due to the above definition. The note "No Exam Required" is therefore applicable to only these pipe-to-pipe welds.

Page 12 of 17 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 the'se systems shall be determined by the requirements of paragraph IWC-1120, Table IWC-2520, Categories C-F and C-G, and paragraph IWC-2411 in the 1974 Edition, through Summer 1975 Adenda 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 the specific provisions of IWC-1220 that were used for each system.

RESPONSE

A. SYSTEMS DENOTED ABOVE ARE CATEGORIZED BY ZONE NUMBER AS FOLLOWS:

RHR Zones 49-52, 75-78 ECCS Zones 43-48, 57-62 CS Zones 70, 79, 80 Zones 73 and 74 provide suction to the pumps involved in each of the three systems above.

A B. The piping system welds selected f or examination were determined by applying the criteria extablished in the 1974 Edition through Summer 1975 Addenda of Section IX of the ASME Code. The specific criteria employed as as fol lows:

1 ~ IWC-1220 Exem ted Com onents The following components may be exempted f rom the examination requirements of IWC-2520:

d. Components connections, piping, and associated valves, and vessels (and their supports ), that are 4 in nominal pipe size and smaller.

2. IWC-2411 Nondestructive Examination (a) Inservice examinations may be performed during normal system operation or during plant outages.

(b) The examinations required by IWC-2520 shall be divided among the number of components of the same size and geometry in each of the multiple streams of a system which perform the same (or redundant) functions, such that the total examinations completed over the system's service lifetime will be equivalent

'f to having performed 100% of the required examinations in one of the multiple streams the system. Systems or portions of systems with a single stream shall he examined such that 100%

of the required examinations of, completed over the system's service lifetime.

the components will be

Page 13 of 17 Res onse to uestion f/10 (continued)

(c) The required examinations for systems with multiple streams shall be distributed among the total number of components and streams by the application of the following procedure:

(1) Determine the number of areas subj ect to examination (Table IWC-2520) for all components (of the same size and geometry) in one of the multiple streams of the system.

(Where the multiple streams have an'nequal number of areas subject to examination, use the average.)

(2) Assign an approximately equal number of the required examination areas among the respective components in each of the multiple streams of the system.

(3) Select different components (or areas of components) to be examined in each of the multiple streams of the system.

(d) If the number of areas subject to examination in a specific category is less than the number of streams, at least one such area shall be examined.

(e) The required examinations assigned to the components in each stream of the system shall be completed by the end of the service lifetime, but divided among the number of inspection intervals (e.g., four intervals for 40-year design service lifetime) in accordance with the following rules:

(1) Distribute, to the extent practicable, the required number of examinations uniformly among the number of inspection intervals.

(2) Perform at least part of the required examinations by the expiration of one-third, two-thirds, and the end of each inspection interval, where the number of required examinations are distributed in accordance with IWC24 10(e) ( 1) ~

(3) Perform at least one examination in each stream of a system during each inspection interval. Select a different component among the multiple streams during each inspection interval (4) To the extent practicable, select periods for the required examination such that the intervals between examinations for specific examination category will not exceed the inspection interval (i.e., 10 years).

3 ~ Table IWC-2520: Code Category C-F The attached, Table 3, denotes by zone number, systems, and multiple streams the welds subject to examination per the above noted criteria. Systems having multiple streams and performing the same function have been combined and the applicable selection criteria of IWC-2411 has been taken into account as well as Table IWC-2520 selection requirements. 1

1

~ (s Page 14 of 17 TABLE 3 System Function Zone lI C-F Welds C-F Welds Selected Subject to Exam for exam 6 divided PT PT/UT between applicable zones PT PT/UT LPSI 43 56 63 (Multiple Stream) 44 58 70 14 17 LPSI 45 0 10 (Multiple Stream) 46 0 6 47 0 2 48 0 13 RHR 49 29 0 (Multiple Stream) 50 28 0 RHR 51 24 0 (Multiple Stream) 52 22 0 LPSI 57 7 (Multiple Stream) 58 8 59 8 60 11 HPSI 61 12 (Multiple Stream) 62 10 Cont. Spray Inlet 70 33 (Multiple Stream)

Combined CS, LPSI 73 66 0 Suction 74 73 0 )8 RHR 75 31 (Multiple Stream) 76 29 77 27 78 36 Cont ~ Spray 79 18 (Multiple Stream) 80 20

ir Page 15 of 17 Response to NRC Questions St. Lucie Unit 2 Relief Re uests

1. Relief Re uest No. 1 Pa e 3-7 (a) Relief is requested from 100% volumetric inspection of the lower shell to middle shell weld (101-171) in the reactor pressure vessel beltline region. Inspection of 83% of this weld is achieved using ultrasonic scans at several angles. Complete inspection cannot be achieved due to interference from surveillance specimens. Would removal of the surveillance specimens allow more complete inspection of the weld?

(b) One-hunderd percent of the CRV (code-required volume) is effectively examined based on the combined results of UT scans at several angles for 14 of the welds listed in Table 3 ' under Relief Request No. 1 ~ Why are the welds included under the relief request if 100% of the CRV was examined?

(c) It is not clear what relief is requested for examination of the RPV closure head. The table on pages 3-20 to 3-23 summarizes the incomplete examinations for the preservice inspection of the RPV closure head. Are we to assume that relief is requested during the first 10~ear interval ISI for all the examinations which had less than 100% 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 relief required.

RESPONSE

(a) No. The surveillance specimen brackets are permanently attached to the vessel ID wall and are not removable.

(b) IWA-2232, "Ultrasonic Examination", subparagraph (a). required that examination of. the RPV welds be examined in accordance with Article 4 of ASME B & PV Code, Seciton V. Under Subarticle T-440, "Examination", the requirement is 100% coverage of the WELD VOLUME with both a nominal 45',

and 60 beam angle. The adjacent base metal in the examination volume must be completely scanned by two angle beams, but need not be scanned by both angle beams in both directions'or weld metal, then, if complete coverage of the weld metal is not achieved by both the 45'nd 60'eams, the 100% requirement is not met. Where "Combined" is 100%, this indicated that all of the material was interrogated by some beam angle from one direction or the other, and is not intended to suggest that the code requirement has been totally achieved. It is, rather, included as information in support of the Basis for Relief.

0 Page 16 of 17 Res onse to uestion f!1 (continued)

( c) Table IWB-2500-1, Category B-A, requires the examinat ion of the accessible length of all circumferential and meridional welds in the closure head during the first inspection interval. Note (2) in that table states "Includes essentially 100% of the weld length" While the requirement as stated in the table and the footnote seem to contradict one another, FP&L's conservative approach deemed it appropriate to request relief in areas of known limitations. Since the First Interval requirements for coverage are the same as they were for Preservice, the same limitations prevail. The Relief request is accurate as written, and stands as-is for the first Interval. It will be revised as appropriate in the Second Interval Plan submittal, when only one each circumferential and meridional weld are to be examined. The extent of examination is 100% less the volume which cannot be achieved due to scan limitations, as summarized in Relief Request 7/1. The relief requested is for that volume which cannot be achieved due to the summarized scan limitations.

2. Relief Re uest No. 2 a e 3-27 The Pre service 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 requi.red.

RESPONSE

Table IWB-2500-1, Category B-B, required the examination of all circumferential welds in the steam generator and pressurized heads during the First Inspection Interval. Note (4) states: "Includes essentially 100% of the weld". Since the examination requirement is the same as for Preservice Inspection, the same limitations will prevail. The examinations schedules are shown in the Zone 3, 4, and 5 tables in Appendix I. The extent of examination is 100% less the volume which cannot be achieved due to scan limitations, as summarized in Relief Request No. 2. The relief requested is for that volume"which cannot be achieved due to the summarized scan limitations.

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, under this relief request, the volumetric examination coverage for the 60'ngle s can is no t clear ~

The comment under -Items 3 10, 3 11, 3 12, 4.10, 4.11, and 4.12 indicated that

~ ~

13% of the CRV is missed on the 60 angle scan, but 93% CRV is reported for the 60-degree 1 scan coverage. Please clarify this apparent discrepancy.

RESPONSE

Your observation is correct in that the comments and the reported coverage are discrepant. The comment will be revised, in each case, to read 5%, 7%, 7%, 5%,

7%, and 7% for 3.10 through 4.12, respectively.

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4. Relief Re uest No. 6 Relief 'is requested from 100% volumetric inspection of 50 pressure retaining welds under Category B-J. Category B-J also required surface examination.

Please confirm that surface examinations will be conducted for all the welds which cannot be examined volumetrically.

RESPONSE

Confirmed. Please note that for those welds scheduled for examination, both surface and volmetric are listed in the appropriate examination tables of Appendix I.

Relief Re uest No. 9 Relief is requested from volumetric inspection of the nozzle"to-shell weld on the shutdown cooling heat exchanger (Item 55.3 and 53.6, pages 3-188 and 3-189) since the weld is inaccessible due to the installation of a welded pad (Fig. 2.9-2, page 3.191). As an alternative, would you commit to examining the pad-to-nozzle weld and the pad-to-shell weld by surface examination methods?

RESPONSE

Yes. The Zone 55 and 56 Tables and Relief Request /I9 will be revised accordingly in the aforementioned Plant revision.