ML17241A373
| ML17241A373 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 06/17/1999 |
| From: | Stall J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-99-139, NUDOCS 9906230177 | |
| Download: ML17241A373 (17) | |
Text
CATEGORY 1 REGULATORY,INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9906230177 DOC.DATE: 99/06/17 NOTARIZED: NO DOCKET ¹ FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335
~KITH.NAME INSTALL,J.A. AUTHOR AFFILIATION Florida Power & Light Co.
RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)
SUBJECT:
Suppls relief requests 4,11 &, 13 for third ten-year ISI interval with info requested during 990526 telcon.Expedited review is requested by 990730 to avoid negatively impactin outage.
DTSTRIBUTTON CODE: A047D COSTER RE CE TVED: LTR ENCL i STZE: l TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code - GL-89-04 E
NOTES:
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NOTE TO ALL "RZDS" RECZPZENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT LISTS THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OP COPIES REQUIRED: LTTR 13 ENCL 12
Florida Power 5 Light Company. 6351 S. Ocean Drive, Jensen Beach, FL 34957 June 17, 1999 L-99-139 PPlL. 10 CFR 50.55a 10 CFR 50.4 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re: St. Lucie Unit 1 Docket No. 50-335 Third Ten- Year In-Service-Inspection Interval Revised Relief R uests 4 ll and 13 The third ten-year in-service inspection (ISI) interval for St. Lucie Unit 1 began on February 11, 1998. Florida Power & Light Company (FPL) submitted the planned ISI program including the third interval relief requests (R/R) by letter L-98-14 on February 2, 1998. In a telephone conference on May 26, 1999, the NRC project manager for St. Lucie notified FPL that several of the R/R (// 4, 5, 8, 10, 11, 13, and 16) require additional information and therefore were not being approved as submitted. R/R 4, 11, and 13 have the potential to negatively impact the upcoming St. Lucie Unit 1 refueling outage (SL1-16) currently scheduled to begin in September 1999.
The purpose of this letter is to supplement R/R 4, 11, and 13 with the information requested by the NRC. Expedited NRC review is requested by July 30, 1999, to avoid negatively impacting the Unit 1 outage. Please contact us should you require any additional clarifications.
Very truly yours, J. A. Stall Site Vice President St. Lucie Plant Enclosures (3) cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Plant I'906230i77 9906i7 ADOCK 05000335 PDR 8 PDR an FPL Group company
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 1 Page 1 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 4 A. COMPONENT IDENTIFICATION:
Class 1, 2, and 3 Pressure Retaining Bolted Connections at Florida Power and Light's (FPL) St.
Lucie Unit 1.
B. EXAMINATIONREQUIREMENT:
Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition IWA-5250(a)(2) if leakage occurs at a bolted connection, the bolting shall be removed, VT-3 visually examined for corrosion, and evaluated in accordance with IWA-3100.
C. RELIEF REQUESTED:
Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests relief from removing and performing a VT-3 visual examination on bolting when leakage is observed at a bolted connection during a system pressure test. Additionally, when required, FPL proposes to perform a VT-1 visual examination of the affected bolting in lieu of the specified VT-3 examination.
D. BASIS FOR RELIEF'he requirement to remove all bolting from a bolted connection to check for degradation is a burden. This requirement does not take into account the corrosiveness of the fluid, the material of the leaking component, the type and location of the leakage, and the history of material degradation in a similar environment. Additional examinations are performed by system engineers during routine surveillance required by plant Technical Specifications and procedures.
Previous corrective actions are not taken into account. The 1992 and later Editions of ASME Section XI changed the IWA-5250 requirements to allow the removal of the bolt closest to the source of leakage, reducing the number of bolts to be examined.
ASME Code interpretation XI-1-92-01 states that new bolting or bolting that has received a visual examination prior to installation and has not been inservice does not have to be evaluated in accordance with this section. This is recognition by the Code that leakage at this point would be considered a maintenance item, and one in which the requirements of IWA-5250(a)(2) do not apply.
Removal of pressure retaining bolting at mechanical connections for VT-3 visual examination and subsequent evaluation in locations where leakage has been identified is not always the most prudent course of action to determine the acceptability of the bolting. This is a task that could easily cause more harm than good. Many bolted connections are studs threaded into a component such as a valve or pump. Removal of these studs can be difficult due to the length of time they have been installed. Large studs, such as those found on the Reactor Coolant Pumps, pose additional problems with removal. Damage to the pump casings can occur if substantial torque is required to remove a stud.
The Code requirement to remove, examine, and evaluate bolting in this situation does not allow the Owner to consider other factors which may indicate the acceptability of mechanical joint bolting. FPL considers this requirement to be unnecessarily prescriptive and restrictive.
Other factors which should be considered when evaluating bolting acceptability when leakage has been identified at a mechanical joint include, but should not be limited to: joint bolting materials, service age of joint bolting materials, location of the leakage, history of leakage at the joint, evidence of corrosion with the joint assembled, and corrosiveness of process fluid.
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 1 Page 2 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 4 ASME Section XI is written to primarily address examinations and testing during periods of plant or system shutdown. No guidance is given to address components that are examined or tested while the plant or system is in service. However, many Code Class 3 and a few Code Class 2 systems are pressure tested, including VT-2 visually examined, utilizing the "inseivice test" requirements of IWA-5000.
Performance of the test while the system is inservice may identify leakage at a bolted connection that, upon evaluation, may conclude that the Joint's structural integrity and pressure retaining ability is not challenged. It would not be prudent to negatively impact a safety system's availability by removing the system from service to address a leak that does not challenge the system's ability to perform its safety function.
In addition, a situation frequently encountered at commercial nuclear plants such as St. Lucie, is the complete replacement of bolting materials (studs, bolts, nuts, washers, etc.) at mechanical joints during plant outages. When the associated system process piping is pressurized during plant start-up, leakage is identified at these Joints. The root cause of this leakage is most often due to thermal expansion of the piping and bolting materials at the joint and subsequent process fluid seepage at the joint gasket. Proper retorquing of the joint bolting, in most cases, stops the leakage. Removal of any of the joint bolting to evaluate for corrosion would be unwarranted in this situation due to new condition of the bolting materials.
Later editions of the Code have realized the problems inherent in removal of all bolting. The wording of the Code has been changed to avoid removing of all bolting to perform an evaluation.
The proposed alternatives are consistent with Code Case N 566-1 that was approved by the Code Committee on February 15, 1999.
E. ALTERNATIVEEXAMINATIONS:
When FPL finds leakage at bolted connections by VT-2 visual examination during system pressure testing, as an alternative to the requirements of IWA 5250(a)(2), either the requirements of (a) or (b) below will be met.
(a). The leakage will be stopped and the bolting and component material will be evaluated for joint integrity as described in (c) below.
(b). If the leakage is not stopped, the Joint will be evaluated in accordance with IWB-3142.4 for joint integrity. This evaluation will include the considerations listed in (c) below. The evaluation will be submitted to the authority having jurisdiction in accordance with IWB-3144.
(c). The evaluation for (a) and (b) above is to determine the susceptibility of the bolting to corrosion and failure. This evaluation will, at a minimum, consider the following factors:
- 1. The number and seivice age of the bolting
- 2. Bolt and component material
- 3. Corrosivcness of process fluid
- 4. Leakage location and system function
- 5. Leakage history at connection or other system components
- 6. Visual evidence of corrosion at connection (while connection is assembled)
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 1 Page 3 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 4 When the pressure test is performed with the system in service or required by the Technical Specifications to be operable, and the bolting is susceptible to corrosion, the evaluation shall address the connection's structural integrity until the next component/system outage of sufficient duration. If the evaluation concludes that the system can perform its safety related function, removal of the bolt closest to the leakage and VT-1 visual examination and evaluation in accordance with IWB-3517 of the bolt will be performed when the system of component is taken out of service for a sufficient duration for accomplishment of the system maintenance activities.
When the removed bolt shows evidence of unacceptable degradation, additional affected bolting shall be removed, VT-1 examined, and evaluated in accordance with IWB-3517, or the affected bolting shall be replaced.
For bolting that is susceptible to corrosion, and when the initial evaluation indicates that the connection cannot conclusively perform its safety function until the next component/system outage of sufficient duration, the bolt dosest to the source of leakage will be removed, receive a VT-1 visual examination, and be evaluated in accordance with IWB-3517. When the removed bolt shows evidence of unacceptable degradation, additional affected bolting shall be removed, VT-1 examined, and evaluated in'accordance with IWB-3517, or the affected bolting shall be replaced.
F. IMPLEMENTATIONSCHEDULE:
Third Inseivice Inspection Interval G. ATTACHMENTS TO THE RELIEF:
None
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 2 Page 1 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 11 A. COMPONENT IDENTIFICATION:
IWA-4000, hydrostatic tests of welded repairs or installation of replacement items by welding is required on Class 1, 2, and 3 systems at PSL-1.
B. CODE REQUIREMENT'ules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition IWA-4700(a) requires a system hydrostatic test be performed in accordance with IWA-5000 after repairs by welding on the pressure retaining boundary.
C. RELIEF REQUESTED'ursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required hydrostatic tests required on welded repairs or installation of replacement items by welding as specified in the 1989 Edition of ASME Section XI.
D. BASIS FOR RELIEF'ydrostatic pressure tests impose significant costs, including potentially increased outage duration, while adding marginal (if any) value to the total repair or replacement quality.
Industry experience has demonstrated that leaks are not being discovered as a result of hydrostatic test pressures propagating a pre-existing flaw through wall. Most leaks are being found when the system is at normal operating pressure. Hydrostatic tests are time consuming, require extensive operator support, and usually mean radiation exposure to personnel. Often additional equipment must be brought in to test a localized repair/replacement, which may involve additional exposure and expense. In many cases, a system hydrostatic test must be conducted over large parts of the system.
Code hydrostatic tests subject the piping system to a small increase in pressure over the nominal operating pressure and is not intended to present a significant challenge to pressure boundary integrity. It is used primarily as a means to enhance leakage detection during the examination of components under pressure, rather than as a measure to determine the structural integrity of components. When normal system pressure is applied, many of the areas where leakage occurs stop leaking.
FPL has compared the system pressure test requirements of the 1992 Edition of Section XI to the requirements of IWA-5000 of the 1989 Edition of Section XI. Based on that review FPL concluded that the 1992 Edition imposes a more uniform set of system pressure test requirements for Code Class 1, 2 and 3 systems. The terminology associated with the system pressure tests requirements for all three Code classes has been clarified and streamlined. The test frequency and test pressure conditions associated with these tests has not been changed. In addition, the post-welded repair NDE requirements of the 1992 Edition of Section III remain the same as the requirements of the 1989 Edition of Section III.
Hydrostatic tests place a burden on the systems, increase radiation exposure and costs, require significant setup time, and add marginal value (if any) to the repair or replacement quality. These tests result in hardships without a compensating increase in the level of quality and safety.
Performing the tests in accordance with the proposed alternative will provide reasonable assurance that flaws will be discovered.
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 2 Page 2 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 11 Use of this Code Case provides an acceptable level of quality and safety by the use of a system leakage test and the additional nondestructive examinations identified below.
ASME Code Case N-416-1 has been included in the draft of the proposed revision to Regulatory Guide 1.147. The requirement to perform a surface examination on the root pass of class 3 welds has been included as part of the acceptance of the Code Case.
This Code Case was approved by the Code Committee as an alternative to the hydrostatic test requirements of IWA-4000 on February 15, 1994.
This is a duplicate Relief Request of RR-19 submitted by FPL letter L-95-296, dated November 7,1995, and approved by NRC letter dated April 29,1996 (TAC NO. M94246) for the Second Ten Year Interval Inservice Inspection Program.
E. ALTERNATIVEEXAMINATIONS:
In lieu of the Code required hydrostatic testing for repairs or installation of replacement items by welding in Class 1, 2, and 3 piping systems, FPL proposes to apply ASME Code Case N-416-1 as alternative rules. Code Case N-416-1 requires:
(a) NDE be performed in accordance with the methods and acceptance criteria of the 1992 Edition of Section III, (b) Visual examinations (VT-2) will be performed in conjunction with a system leakage test using the 1992 Edition of Section XI, in accordance with IWA-5000, at nominal operating pressure and temperature, (c) The use of the Code Case will be documented on the Owner's Data Report Form NIS-2 or equivalent.
In addition, considering the limited nature of NDE requirements for Class 3 components, FPL proposes to perform additional surface examinations on the root (pass) layer of butt and socket welds of the pressure retaining boundary of Class 3 when the surface examination method is used in accordance with the 1992 Edition of Section III. For those Class 3 welds receiving radiography in lieu of a surface examination in accordance with Section III, no additional surface examination of the root layer will be performed.
F. IMPLEMENTATIONSCHEDULE:
Code Case N-416-1 will be implemented during the Third 10-year Inservice Inspection interval. If this Code case is published in a future revision of Regulatory Guide 1.147, and FPL intends to continue implementation of this Code Case, limitations issued in the Regulatory Guide will be implemented.
G. ATTACHMENTS TO THE RELIEF'ode Case N-416-1
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 2 Page 3 t St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 11 CASE N416-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: February 15, 1994 See Numeric Index for expiration and any reaffirmation dates.
Alternative Pressure Test Requirement for Welded Repairs or Installation of Replacement Items by Welding, Class 1, 2 and 3,Section XI, Division 1 Inquiry: What alternative pressure test may be performed in lieu of the hydrostatic pressure test required by para. IWA-4000 for welded repairs or installation of replacement items by welding'?
Reply: It is the opinion of the Committee that in lieu of performing the hydrostatic pressure test required by para. IWA-4000 for welded repairs or installation of replacement items by welding, a system leakage test may be used provided the following requirements are met.
(a) NDE shall be performed in accordance with the methods and acceptance criteria of the applicable Subsection of the 1992 Edition of Section III.
(b) Prior to or immediately upon return to service, a visual examination (VT-2) shall be performed in conjunction with a system leakage test, using the 1992 Edition of Section XI, in accordance with para.
IWA-5000, at nominal operating pressure and temperature.
(c) Use of this Case shall be documented on an NIS-2 Form.
If the previous version of this case were used to defer a Class 2 hydrostatic test, the deferred test may be eliminated when the requirements of this revision are met.
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 3 Page 1 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13 A. COMPONENT IDENTIFICATION'lass 1, 2, and 3 integral attachments on piping and components at PSL-1.
B. CODE REQUIREMENT'ules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition Code Category B-H Surface examinations shall be performed on essentially 100% of the length of the attachment weld Code Category B-K-1 No examinations required Code Category C-C Surface examinations shall be performed on essentially 100% of the length of the attachment weld on attachments whose base material design thickness is 3/4" or greater Code Category D-A, D-B, D-C Visual (VT-3) examinations shall be performed on essentially 100% of the length of the attachment weld C. RELIEF REQUESTED:
Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the code required surface and visual examination of integral attachments as specified in the 1989 Edition of ASME Section XI.
D. BASIS FOR RELIEF'he preparation for and performance of the Section XI required examinations involve excessive cost, man-hours, and approximately one Man-REM per outage with little or no compensating increase in the level of quality or safety. FPL has not had any failure of integral attachment welds at the St. Lucie plants.
Use of this alternative reduces the need for the building of scaffold and removal of insulation from the Reactor Coolant, Safety Injection, Residual Heat Removal, and other Class 1, 2, and 3 piping systems.
There is no requirement for the examination of Class 1 integral attachments for the 3rd interval.
Code Case N-509 requires FPL to examine at least 10% of piping attachments and one integral attachment. on one of multiple vessels of similar design, function and service. Additional scaffolding may be built and insulation removed, but careful scheduling of examinations in conjunction with piping weld and other support examinations will minimize this work and exposure. There will be an increase in weld cleaning and preparation time. The additional preparation increases overall radiation exposure and the possibility of personnel contamination.
The Code Case will increase the amount of examinations FPL would be required to perform.
For Class 2 systems, the Code requires a surface examination of integral attachments whose base material design thickness is 3/4" or greater. Code Case N-509 requires a surface examination of 10% of the population. Implementing the Code Case would result in a decrease in the building of scaffold, removal and replacement of insulation. By careful scheduling of
St. Lucid Unit 1 Docket No. 50-335 L-99-139 Enclosure 3 Page 2 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13 examinations in conjunction with piping weld and support examinations, work, costs, and exposure would be reduced.
For Class 3 systems, the Code requires a VT-3 of integral attachments, with only one of multiple components of similar design, function, and service being examined. Code Case N-509 requires a VT-1 examination of 10% of the population. This would result in a decrease in the building of scaffold, removal and replacement of insulation. Again, by careful scheduling of examinations in conjunction with piping weld and support examinations, work, costs, and exposure would be reduced.
This Code Case was approved by the Code Committee as an alternative to the examination requirements on integral attachment welds of Code Categories B-K-1, C-C, D-A, D-B, and D-C.
Code Case N-509 was approved for use by ASME on November 25, 1992.
This is a duplicate of the request for use submitted by FPL letter L-96-303, dated December 17,1996, and approved by NRC letter dated February 5, 1997 (TAC NO M97521) for the Second Ten Year Interval Inservice Inspection Program.
Use of this Code Case provides an acceptable level of quality and safety by the use of a system leakage test and additional nondestructive examinations.
E. ALTERNATIVE EXAMINATIONS'PL will examine a minimum of 10% of integral attachments distributed among all non-exempt Class 1, 2, and 3 piping pumps and valves in accordance with the requirements of Code Case N-509. By using this Code Case, FPL will reduce the amount of scaffold, insulation removal, and minimize radiation exposure. While it is recognized that some additional radiation exposure will be accumulated in the performance of Class 1 integral attachments, the overall effect of the complying with the Code Case will be a reduction in total accumulated dose and costs.
Code Case N-509 requires the selection of component supports to be in accordance with the 1989 Edition of Section XI with addenda through 1990. FPL will select component supports in accordance with the requirements of Code Case N-491, Alternative Rules for Examination of Class 1, 2, 3, and MC Component Supports of Light-Water Cooled Power Plants,Section XI, Division 1" which was approved for use by ASME on March 14, 1991, and approved for use by the USNRC in Regulatoty Guide 1.147, Rev. 11, dated October 1994.
F. IMPLEMENTATION SCHEDULE'ode Case N-509 will be implemented during the Third 10-year Inservice Inspection interval. If this Code case is published in a future revision of Regulatory Guide 1.147, and FPL intends to continue implementation of this Code Case, limitations issued in the Regulatory Guide will be implemented.
G. ATTACHMENTS TO THE RELIEF'ode Case N-509
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 3 Page 3 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13 CASE N-509 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: November 25, 1992 See Numeric Index for expiration and any reaffirmation dates.
Alternative Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Welded AttachmentsSection XI, Division 1 Inquiry: What alternative requirements to those of IWB, IWC, and IWD may be used to select and examine integrally welded attachments?
Reply: It is the opinion of the Committee that the following rules may be used to select and examine integrally welded attachments:
(a) This Case is limited to Examination Categories B-H, B-K-1, C-C, D-A, D-B, and D-C.
(b) Class 1, 2, and 3 component supports shall be selected for examination in accordance with IWF of the 1989 Edition with the 1990 Addenda.
(c) Except for the selection of component supports for examination, all references to Section XI within this Case shall be from the edition and addenda specified in the Owner's Inservice Inspection Program.
1.0 SCOPE These requirements apply to examination and sample selection of Class 1, 2, and 3 integrally welded attachments of vessels, piping, pumps, and valves listed in Table 2500-1 as follows:
(a) Table 2500-1, Examination Category B-K shall be used for Class 1 integrally welded attachments in Examination Categories B-H and B-K-1 of IWB.
(b) Table 2500-1, Examination Category C-C shall be used for Class 2 integrally welded attachments in Examination Category C-C of IWC.
(c) Table 2500-1, Examination Category D-A shall be used for Class 3 integrally welded attachments in Examination Categories D-A, D-B, and D-C of IWD.
1.1 Exemption Criteria (a) The exemption criteria provided in IWB-1220, IWC-1220, and IWD-1 220 may be applied to Class 1, 2; and 3 components respectively, with integrally welded attachments, required to be examined in accordance with Table 2500-1.
(b) Class 1, 2, and 3 integrally welded attachment examinations performed as a result of component support deformation cannot be credited under the requirements of IWB-2411 or IWB-2412, IWC-2411 or IWC-2412, and IWD-2411 or IWD-2412, respectively.
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 3 Page 4 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13 1.2 Inspection Schedule Class 1, 2, or 3 integrally welded attachments selected for examination by sample selection criteria in accordance with Table 2500-1, Examination Categories B-K, C-C, and D-A, shall meet the requirements of IWB-2411 or IWB-2412, IWC-2411 or IWC-2412, or IWD-2411 or IWD-2412, respectively.
1.3 Additional and Successive Examinations (a) Class 1, 2, and 3 additional and successive examination requirements of IWB-2430 and IWB-2420 for Class 1, IWC-2430 and IWC-2420 for Class 2 and 3 as applicable, shall be applied to integrally welded attachments whose examinations reveal flaws or relevant conditions that exceed the acceptance standards of IWB-3000, IWC-3000, and IWD-3000, respectively.
(b) When integrally welded attachments are examined as a result of identified component support deformation and the results of these examinations exceed the applicable acceptance standards listed above, additional or successive examinations shall be performed when determined necessary based on an evaluation by the Owner.
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 3 Page 5 St. Lucje Ufiit1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13 TABLE 2500-I EXAMINATIONCATEGORIES EXAMINATIONCATEGORY B-K, INTEGRAL A1IACHMENTS FOR CLASS 1 VESSELS, PIPING, PUMPS, AND VALVES Examination Item Requir cmental Examination Acceptance Extent of Frequency of No. Parts Fig. No. Method Standard Examination~ Examination Examined'Pressure B10.10 Vesseh IWB-2500-1 3, Surface IWB4516 100% of required areas of each Each identified occurrence and each Integrally Wekled -14, and-15 welded attachment inspection interval' Attachments B10.20 Piping IWB-2500-1 3, Surface IWBM16 100% of required areas of each Ea'ch klentified occurrence and each Integrally Welded -14, and -15 welded attachment inspection Attachments interval'ach
'00%
B10.30 Pumps IWB-2500-1 3, Surface IWB4516 of required areas of each klentified occurrence and Each Integrally Welded -14, and-15 welded attachment inspection Attachments interval'ach B10.40 Valves IWB-2500-1 3, Surface IWB4516 100% of required areas of each kfentified occurrence and each
'I Integrally Welded -14, arid -15 welded attachment inspection Attachments interval'OTES:
(1) Examination is limited to those integrally welded attachments that meet the following conditions:
(a) the attachment is on the outskte surface of the pressure retaining component, (b) the attachment provides component support as defined in NF-1110; and (c) the attachment weld joins the attachment either directly to the surface of the component or to an integrally cast or forged attachment to the component.
(2) The extent of the examination includes essentially 100% of the length of the attachment weld at each attachment subject to examination.
(3) Selected samples of integrally welded attachments shall be examined each inspection Interval.
(4) In the case of multiple vesseh of similar design, function and service, only one integrally welded attachment of only one of the multiple vesseh shall be selected for examination.
(5) For piping, pumps, and valves, a sample of 10% of the welded attachments associated with the component supports selected for examination under the 1990 Addenda, IWF-2510 shall be examined.
(6) Examination is required whenever component support member deformation (e.g., broken, bent, or pulled out parts) h identified during operation, refueling, maintenance, examination, hservice Inspection, or testing.
(7) For the configuration shown in Fig. IWB-2500-1 4, a volumetric examination of volume A-B-C-D from side (B-C) of the circumferential welds may be performed in lieu of the surface examination of surfaces A-D and B-C.
) ~
St. Lucie Unit 1 Docket No. 50-335 L 99-139 Enclosure 3 Page 6 St. Lucle Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13 TABLE 2500-1 (CONT'D)
EXAMINATIONCATEGORIES EXAMINATIONCATEGORY C-C, INTEGRALATTACHMENTS FOR CLASS 2 VESSELS, PIPING, PUMPS, AND VALVES Examination Item Requirementsl Examination Acceptance Extent of Frequency of No. Parts Fig. No. Method Standard Examination~ Examination'ach Examined'ressure C3.10 Vessels Surface IWC3512 100% of required areas of each identified occurrence and each Integrally Welded welded attachment inspection Attachments interval'ach C3.20 Piping IWC-2500$ Surface IWC4512 100% of required areas of each identified occurrence and each Integrally (welded welded attachment inspection Attachments Interval'ach C3.30 Pumps IWC-25004 Surface IWC4512 100% of required areas of each identified occurrence and each Integrally Wekled welded attachinent inspection interval Attachments Valves IWC-2500-5 Surface IWC4512 100% of required areas of each Each kfentified occurrence and each Integrally t Welded welded attachment inspection Attachments interval'OTES:
(1) Examination is limited to those integrally welded attachments that meet the following conditions:
(a) the attachment is on the outside surface of the pressure retaining component; (b) the attachment provides component support as defined in NF-1110; and (c) The attachment weld joins the attachment either directly to the surface of the component or to an integrally cast or forged attachment to the component.
(2) The extent of the examination includes essentially 100% of the length of the attachment weld at each attachment subject to examination.
(3) Selected samples of integrally welded attachments shall be examined each inspection interval.
(4) In the case of multiple vessels of similar design, function and service, only one integrally welded attachment of only one of the mumple vessels shall be selected for examination.
(5) For piping, pumps, and valves, a sample of 10% of the welded attachments associated with the component supports selected for examination under the 1990 Addenda, IWF-%10 shall be examined.
(6) Examination is required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, inservice inspection, or testing.
St. Lucie Unit 1 Docket No. 50-335 L-99-139 Enclosure 3 Page 7 St. Lucje Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 13 TABLE 2500-1 (CONT'D)
EXAMINATIONCATEGORIES EXAMINATIONCATEGORY D-A, INTEGRALATTACHMENTS FOR CLASS 3 VESSELS, PIPING, PUMPS, AND VALVES Examination Item Requirements Examination Acceptance Extent of Frequency of No. Parts Fig. No Method Standard Examination Examination" Examined'ressure DLIO Vessels IWD-2500-1 Visual, VT-1 100% of required areas of each Each identiTied occurrence and each Integrally Wekled welded attachment inspection intenral Attachments D1.20 Piping Integrally Welded IWD-WOO-1 Visual, VT-1 100% of required areas of each Each klentified occurrence and each Attachments welded attachment Inspection intenral D1.30 Pumps Integrally Welded IWD-2500-1 Visual, VT-1 100% of required areas of each Each identified occurrence and each Attachments welded attachment inspection interval D1.40 Valves integrally Welded IWD-MOO-1 Visual, VT-1 100% of required areas of each Each identified occurrence and each Attachments welded attachment inspection interval NOTES:
(1) Examination Is limited to those integrally welded attachments that meet the following conditions:
(a) the attachment Is on the outside surface of the pressure retaining component; (b) the attachment provides component support as defined in NF-1 110; and (c) the attachment weld joins the attachment either directly to the surface of the component or to an integrally cast or forged attachment to the component.
(2) The extent of the exam indudes essentially 100% of the length of the attachment weld at each attachment subject to exam.
(3) Selected samples of integrally welded attachments shall be examined each inspection interval. All integrally welded attachments selected for examination shall be subject to corrosion, as determined by the Owner, such as the integrally welded attachments of the Service Water or Emergency Service Water systems. In the case of multiple vessels of similar design, function and service, the integrally welded attachments of only one of the multiple vessels shall be selected for examination. For integrally welded attachments of piping, pumps, and valves a 10% sample shall be selected for examination. This percentage sample shall be proportional to the total number of nonexempt integrally welded attachments connected to the piping, pumps, and valves, located within each system subject to these examinations.
(4) Examination Is required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, Inservice Inspection, or testing.