ML17308A215

First Interval Inservice Insp Program,St Lucie Unit 2, Technical Evaluation Rept

ML17308A215
Person / Time
Site:	Saint Lucie
Issue date:	04/30/1986
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML17216A729	List: ML17216A728 ML17216A730 ML17308A215
References
CON-NRC-03-82-096, CON-NRC-3-82-96 SAIC-86-1627, NUDOCS 8604290225
Download: ML17308A215 (59)

Text

SAI C-86/162 7 TECHNICAL EVALUATION REPORT FIRST INTERVAL INSERYI CE INSPECTION PROGRAM ST.

LUCIE UNIT 2 Submitted to U.S. Nuclear Regulatory Commission Contract No. 03-82-096 Submi tted by Science Applications International Corporation Idaho Falls, Idaho 83402...,..

April 1986 4C ADOCK 05000 SSO42~0aa5

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CONTENTS

'l.

INTRODUCTION.

2.

EVALUATION OF INSERVICE INSPECTION PLAN I

2.1 Introducti on

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2.2 Documents Evaluated 2.3 Summary of Requirements 2.3.1 Code Requirements 2.3.1.1 Class 1 Requirements 2.3.1.2 Class 2 Requir ements 2.3.1.3 Class 3 Requirements 2.3.1.4 Component Supports

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2.4 Compl iance with Requirements.....

2.4.1 Applicable'Code Edition 2.4.2 Code Requirements

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2.4.3 Pres ervi ce,Inspecti on Condi tions 2.5 Conclusions and Recommendations

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5 3.

EVALUATION OF RELIEF REQUESTS 3.1 CLASS 1

COMPONENTS

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3.1.1 3.1.1.1 Reactor Vessel Relief Request No. 1, Pressure-Retaining Melds in Reactor Vessel, Category B-A, Items Bl.ll, Bl.12, Bl.21, B1.22, Bl.30, and B1.40

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8 3.1.1.2 Relief Request No. 2, Full Penetration Melds of Nozzles in Vessels, Category B-D, Items B3.90 and B3.100.................

13 3.1. 2 Pressurizer

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15 3.1.2.1 Relief Request No. 2, Pressure-Retaining Melds in Vessels Other than Reactor Vessels, Category B-B, Item B2.11................

15 3.1.2.2 Relief Request No. 3, Full Penetration Welds of Nozzles in Vessels, Category B-D, Items B3.110 and B3.120................

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s 3.1. 3 Heat Exchangers and Steam Generators 19 3.1.3.1 Relief Request No.

2, Pressure-Retaining Melds in Vessels Other than Reactor Vessels, Category B-B, Items B2.31 and B2.40 3.1.3.2 Relief Request No. 3, Full Penetration Welds of Nozzles in the Steam Generator, Category B

Item B3.130

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21 3.1.4 Piping Pressure Boundary ~....,...

23 3.1.4.1 Relief Request No. 5, Pressure e-Retaining Dissimilar Metal Melds in Reactor Coolant Pump Safe

Ends, Category B-J, Item B9.11, 3.1.4.2 Relief Request No. 6, Pressure Retaining Melds in Piping, Category B-J, Items B9.11, 89.12, and B9.31 3o1.5 Pump Pressure Boundary..

3.1.5.1 Relief Request No. 7, Pump Casings, Category B-L-2, Item B12.20/

23 28 33 sa 3.1.6 Valve Pr essure Boundary 3.1.6.1 Relief Request No. 7, Valve Bodies, Category B-M-2, Item 812.40 36

3. 2 CLASS 3.2.1 3.2.1.1 COMPO NENTS

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Pressure Vessels and Heat Exchangers

'I Relief Request No. 8, Pressure Retaining Welds in Pressure

Vessels, Category C-A, Items Cl.10, Cl.20, and Cl.30

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39 3.2.1.2 Relief Request No. 9, Pressure Retaining Melds in Vessels, Category C-B, Item C2.20.......

41 3.2.2 Plpsng Pressure Boundary...

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43 3.2.2.1 Relief Request No. 10, Pressure Retaining Melds in Piping, Category C-F, Items C5.11, C5.12, C5.21, C5.22, C5.31, and C5.32 3.2.2.2 Relief Request No. 11, Pressure Retaining Welds in Piping Containment Spray System, Category C-F, Items C5.11 and C5.12

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', 3.3 CLASS 3 COMPONENTS (No relief requests)

I 3.4 PRESSURE TESTS (No relief requests) 3.5 GENERAL 1

3.5.1 Relief Request No. 13, Ultrasonic Calibration Blocks........

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3.6 REFERENCES

APPENOIX A:

Requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel

Code, 1980 Edition with Addenda Through Winter 1980

-1 11-

TECHNI CAL EVALUATION REPORT FIRST INTERVAL INSERVICE INSPECTION PROGRAM St. Lucie Unit 2 1.

INTRODUCTION Section 50.55a of 10 CFR Part 50 defines the requirements for the Inservice Inspection (ISI) Program for light-water cooled nuclear power facilities.

Incorporated by reference in this regulation isSection XI of the Boiler and Pressure Vessel Code published by the Pmerican Society of Mechanical Engineers (ASME), which provides the basis for implementing inservi ce inspecti on.*

Two types of inspections are required:

(1) a preservice inspection conducted before comoercial operation to establish a baseline and (2) peri-odic inservice inspections conducted during 10-year inspection intervals that normally start from the date of comnercial operation.

Separate plans for completing preservice inspection and each 10-year inservice inspection must be formulated and submitted to the Nuclear Regulatory Commission (NRC).

The plan for each 10-year interval must be submitted at least six months before the start of the interval.

During the initial 10-year interval, inservice inspection examinations must ccmply with the requirements in the latest edition and addenoa of Section XI incorporated in the regulation on the date 12 months before the date of issuance of the operating license.

The program for the first in-terval for St. Lucie Unit 2 (PSL-2), which began August 8, 1983, has been written to the 1980 Edition with addenda through Minter 1980.

Section 2 of this report evaluates the first interval ISI plan developed by the licensee, Florida Power and Light Company (FPL), for PSL-2 for (a) compliance with this edition of Section XI, (b) compliance with ISI-related commitments identified during the NRC's revie~ before granting an Operating License, (c) acceptability of examination

sample, and (d) exclusion criter ia.

Based on the date PSL-2's construction permit (May 2, 1977) was.

issued, the plant's Class 1

and 2 components (including supports) were to be designed and provided with access to enable performance of inservice examinations and tests.

and to meet the preservice examination requirements of the 1974 Edition of the Code with addenda through Summer 1975 (10 CFR 50.55a(g)(2)).

Paragraph 10'CFR 50.55a(g) recognizes that some requirements of the current edition and addenda of Section XI may not be practical to

• Specific inservice test programs for pumps and valves (IST programs) are being evaluated in other reports.

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implement because of limitations of design,

geometry, and materials of coristruction of components and systems that were designed to the older Code.

The regulation therefore permits exceptions to impractical examination or testing requirements of the current Code to be requested.

Relief from these requirements may be granted, provided the health and safety of the public are not endangered, giving due consideration to the burden placed on the licensee if the requirements were imposed.

Section 3 of this report evalu-ates requests for relief dealing with inservice examinations of ccmponents and with system pressure tests..

The regulation also provides that ISI programs may meet the require-ments of subsequent Section XI editions and addenda, incorporated by reference in the Regulation, subject to approval by the NRC.

Portions of such editions or addenda may be used, provided all related requirements of the respective editions or addenda are met.

These instances are addressed on a case-by-case basis in Section 3 of this report.

Likewise,Section XI provides that certain components and systems may be exempted from volumetric and surface requirements.

In some instances,

however, these exemptions are not acceptable to the NRC or are acceptable only with restrictions.

As appropriate, exemptions are also discussed in Section 3 of this report.

The Preservice Inspection (PSI) program for PSL-2, a 2-loop 800 MWe Combustion Engineering pressurized-water reactor (PWR),

was approved by the, staff.

References 1 through 4 relate to review and approval of the PSI.

The, ISI program for the first 10-year igspection interval (Revision 0) was submitted to the NRC October 6, 1983. (5>

As a result of a prel jminary review of the plan, the staff requested additional information.<<)

The licensee responded to the request for additional iqformation in letters dated October 25, 1984,(")

and November 19, 1984.(8>

In additiqn, the licensee submitted Revision 1 of the ISI program on July 5, 1985. (9>

References 5 and 9 form the primary basis for review of the PSL-2 ISI pro gr am.

Reference 10 summarizes license conditions related to PSL-2 and confirms that there are no unresolved license conditions related to ISI.

~ References ll and 12 describe the stress analysis of PSL-2 and how ISI requirements were revised to comply with examination requirements for highly stressed areas.

, 2.

EVALUATION OF INSERVICE INSPECTION PLAN 2.1 Introducti on The approach being taken in this evaluation is to review the applicable program documents to determine the adequacy of their response to Code requirements and any-license conditions pertinent to ISI activities.

The rest. of this section describes the submittals reviewed, the basic requirements of the effective Code, and the appropriate license conditions.

The results of the review are then described.

Finally, conclusions and recommendations are given.

2. 2 Documents Evaluated A chronology of documents on PSL-2 PSI and ISI is given in Section 1

of this report.

Those documents that impact this ISI program evaluation are (1)

Revisions 0 and 1 of the ISI program, (2) the licensee's response to the staff's request for additional information, (3) portions of the Safety Evaluation Report (SER) and Supplement 3 to the

SER, and (4) to a lesser

extent, the previous submittals on the PSI program.

2.3 Summar of Requirements The requirements on which this review is focused include the following:

(1)

Compliance with Applicable Code Editions.

The Inservice nspection rogram sha be baseo on tne Code editions defined in 10 CFR 50.55a(g)(4) and 10 CFR 50.55a(b).

The licensee for PSL-2 has written the first interval program to the 1980 Edition with addenda through Winter 1980.

These Code requirements are summarized in 2.3.l.below and detailed Code requirements are given in Appendix A.

The 1974 Edition, Sumner 1975 Addenda is being used for selecting Class 2 pipe welds in systems providing the functions of residual heat removal, emergency core cooling, and containment heat removal.

This is a requirement of 10 CFR 50.55a(b) (2) (iv)(a).

(2)

Acceptablit of the Examination Sampl e.

Inser vice volumetric sur

ace, ana visua examinations sna be performed on ASIDE Code Class 1

and 2 components and their supports using sampling schedules described in Section XI of the ASME Code and 10 CFR 50.55a(b).

Sample size designations are identified as part of the Code requirements given in Appendix A.

(3)

Exclusion Criteria.

The criter ia used to exclude components from examina ion s

a e consistent with IWB-1220, IWC-1220, and 10 CFR 50.55a(b).

(4)

PSI Commitments.

The Inserviie Inspection Program should address Ch i q lifi d t

disci th ISI-related commitments described in the SER and its suppleoents for the preservice examination.

2.3. 1 Code Requirements The following requirements are summarized from the 1980 Edition of Section XI with addenda through Winter 1980.

Nany requirements call for the examination of all areas, while other requirements specify more limited examinations based on criteria such as representative percentage, conponents examined under other categories, material thickness, location relative to other welds or discontinuities, and component function and construction.

For detailed requirements, see Appendix A of this report or the Code itself.

2.3.1.1 Class 1 Requirements.

The following Class 1 components are to be examine in ne ir st, interval in accordance with Table IWB-2500-1:

(1)

Pressure-Retaining Wel ds in Reactor Vessels (2)

Pressure-Retaining Welds in Vessels Other than Reactor Vessels (3)

Full Penetration Welds of Nozzles in Vessels (4)

Pressure-Retaining Partial Penetration Welds in Vessels (5)

Pressure-Retaining Diss imilar Netal Wel ds (6)

Pressure-Retaining Bolting, Greater than 2 in. in Di'ameter (7)

Pressure-Retaining

Bolting, 2 in.

and Less in Diameter (8)

Integral Attachments for Vessels (9)

Pressure-Retaining Welds in Piping (10) Integral Asttachments for Piping,

Pumps, and Valves

'(ll) Pump Casings and.Valve

Bodies, including Pressure-Retaining Welds (12) Interior of Reactor Vessel, including Welded Core Support Structures, Interior Attachments, and Removable Core Support Structur es (13) Pressure-Retaining Welds in Control Rod Housings (14) All Pr essure-Retaining Components - Pressure Tests (15)

Steam Generator Tubing.

2.3.1.2 Class 2 Requirements.

The following&ass 2 components are

. to be examine sn e

>rs sn erval in accordance with Table IWC-2500-1."

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(1) 'Pressure-Retaining Welds in Pressure Vessels (2)

Pressure-Retaining Nozzle Welds in Vessels (3)

Integral Attachments for Vessels,

Piping, Pumps, and Valves (4). Pressure-Retaining Bolting Greater than 2 in. Diameter (5)

Pressure-Retaining Welds in Piping (6)

Pressure-Retaining Welds in Pumps and Valves (7)

All Pressure-Retaining Components - Pressure Tests.

2.3.1.3, Class 3 Requirements.

The following Class 3 reactor-connected and assoc>ated systems are to be examined in the first interval in accordance with IWD-2500-1:

(1)

Systems in Support of Reactor Shutdown Function I

(2)

Systems in Support of Emergency Core Cooling, Containment Heat Removal; Atmosphere Cleanup, and Reactor Residual Heat Removal (3)

Systems in Support of Residual Heat Removal from Spent Fuel Stor age P ool.

2.3.1.4 Component Supports.

The following examination and inspection of component supports are to oe examined in the first interval in accordance with IWF-2500-1:

(1)

Plate and Shell Type Supports (2)

Linear Type Supports (3)

Component Standard Supports.

2.4 Com 1iance wi th Requirements 2.4.1 Applicable Code Edition The initial inservice inspection interval examination program must comply (10 CFR 50.55a(g)(4) (i) ) with the requirements of the latest edition and addenda of Section XI incorporated into 10 CFR 50.55a on the date 12 months before the date of issuance of the operating license, 'ased on an April 6, 1983, operating license for PSL-2, the Code applicable to the first-interval program is the 1980 Edition with Addenda through Winter 1980.

The licensee prepared the first-interval program to the applicable Code.

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2.4. 2 Code Requirements s

The first interval I$ J 'program of record is contained in Revisions 0

and 1 of the ISI program.(~

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The ISI program submitted in the two revisions was reviewed'(exclusive of pump and valve testing) and the following observations were noted:

(a)

Revision 1 of the PSL-2 ISI program was issued to (1) correct minor errors in Revision 0, {2) respond to questions raised in the staff's request for additional information, and (3) redistri-bute weld selection based on the results of a'stress analysis.

(b)

The PSL-2 ISI program has been prepared in accordance with the applicable version of the Code.

(c)

Sample size and weld selection have been implemented in accor-dance with the Code and appear io be correct.

(d)

Exclusion criteria have been applied in accordance with the Code and appear to be correct.

(e)

Examination of the low pressure turbine discs is included in the plan in accordance with the licensee's commitment in Reference 3.

(f)

Examination of Class 1, 2, and 3 component supports in accordance with Subsection IMF has not been completely specified in the ISI program.

The component supports for Class 1, 2, and 3 equipment are listed in Appendix E, but the examination category and schedule have not been completed.

2.4.3 Pres ervi ce Inspecti on Condi tions License condition 2.C.6 required that the licensee submit a revised inservice inspection program for Class 1, 2, and 3 ccmpgnents within six months from the issue date of operating license NPF-16.<1O)

The license

.condition was satisfied when the licensee sohmittad the revised ISI program on October 6, 1983.(5 2e5 Conclusions and Recommendations Based on the preceding evaluation, it is concluded that the St. Lucie Unit 2 ISI program meets the requirements of (1) the Code and (2)

NRC regu-lations, except as summarized below.

Class 1, 2, and 3 component supports have not been specifically

'selected and scheduled for examination in accordance with Subsection IMF.

The sample of supports'o be examined and the schedule for examinations should be specified and the program updated accordingly and resubmitted.

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'I It is also recommended that the licensee continue to assure that the equipment and procedures used to perform the examinations are among the most up-to-date that are commercially available at the time the exami-nations are performed.

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3.

EVALUATION OF RELIEF REOUIS The following.sections evaluate the 12 pending relief requests.

The material included in the paragraphs titled Code Relief Re uest, Proposed Alternative Examination, and Licensee's

'asis or Re uesting e ief is quoted direct y tram the relief request except or minor

~e>corial changes such as removing references to figures and tables not included in this report.

3.1 CLASS 1

COMPONENTS Subsections IWA and IWB of the Code govern the examination of Class 1 piping and components.

Specific requirements are given in Table IW8-2500-1.

3.1.1 Reactor Vessel

3. 1.1.1 Relief Request No. 1, Pressure-Retainin Welds in Reactor Vessel, Cate or B-A, Items 81.1 1, 81.12, 81.21, 81.22, 81.30,-and 81.40 Code Re uirement Bl.ll Circumferential Shell Welds, and 81.12 Lon itudinal ne we as:

Essentially 100% of the weld length of all circumferential and longitudinal shell welds must be volumetrically examined in accor-dance with Figures IWB-2500-1 and -2 during the first inspection interval.

The examinations may be deferred to the end of the inspecti on interval.

81.21 Circumferential Head Welds, and 81.22 Meridional Head e os:

Essentially 100% of the accessible, weld lengths of all head welds must be volumetrically examined in accordance with Figure IWB-2500-3 during the first inspection interval.

The examination of bottom head welds may be delayed to the end of the interval

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81.30 Shell-to-Flan e Weld:

Essentially 100% of the weld length of the shell-to-flange weld must be volumetrically examined in accordance with Figure IWB-2500-4 during the first inspection interval.

The examination of shell-to-flange welds may be performed during the first and third inspection periods in conjunction with the nozzle examinations of

Examination Category 8-0 (Program B).

At least 50% of shell-to-flange welds shall be examined by the end of the first inspection.

period and the remainder by the end of the third inspection period.

If partial examinations are conducted from flange face, the remaining volumetric examinations required to be conducted from vessel wall may be performed at or near the end of each inspection interval.

Bl.40 Head-to-Flan e Weld:

Essentially 100% of the weld length of the head-to-flange weld must be examined by surface and volumetric methods in accordance with Figure IWB-2500-5 during the first inspection interval.

If partial examinations are conducted from flange face, the remaining volumetric examinations required to be conducted from vessel wall may be performed at or near the end of each inspection interval.

Code Relief Re uest Relief from volumetric examination of 100>> of the Code required volume is requested for specified welds in the reactor pressure

vessel, including welds in the lower head, shell beltline

region, and upper head.

Proposed Alternative Examination (a)

Periodic System Leaf>age tests per Category B-P, Table IWB-2500-1;*

(b)

Inservice Hydrostatic test per Category B-P, Table IWB-2500-1;*

(c)

The extent of examination volume achieved ul trasonically and the alternative examinations and test provide assurance of an acceptable level of quality and safety.

Licensee's Basis for Requestin Relief Configuration and permanent attachments prohibit 1005 ultra-sonic examination coverage of the required examination volume.

Additional ultrasonic techniques are employed, where practical, to achieve the Code-required volume (CRV).

• These alternatives proposed by the licensee are already required by the Code.

Limitations to examination coverage were experienced during the mechanized PSI and will prevail during Inservice Inspection of the St. Lucie Plant, Unit 2 reactor pressure vessel (RPV).

The following paragraphs illustrate the types and extent of limitations encountered in attempting to examine the St. Lucie 2 reactor pr ess ur e v ess el.

RPV Lower Head Welds:

No limitations affect the lower head dollar plate weld.

Nechanized scanning of the lower head meridional welds is limited due to interference from the core support lugs and flow skirt.

RPV Circumferential Shell Welds:

The mechanized examination of the lower shell-to-lower head weld is limited due to interfer-ence from the core support lugs and anti-rotation lugs.

Examination of the middle shell-to-lower shell weld is limited due to interference from the surveillance specimens.

Except. for near surface interface noise during Oo and 60o examinations, no limitations affect the parallel and transverse examination of upper shell-to-middle shell weld.

The near su~face volume is examined with 45o full vee-path scans.

The upper shell-to-flange weld is examined from the shell side and *om the flange seal surface.

The Oo and 60o shell side exami-nations are limited due to near surface interface noise;

however, this volume is effectively examinable using the 45 full vee-path beam.-

Beams directed nearly perpendicular to the weld plane from the flange seal surface compensated for the straight beam and angle beam examination limitations on the flange side of the weld.

Due to the flange configuration, rio transverse examination'scans can be performed on the flange side of the weld.

Transverse examinations are also limited 'on th'e shell side of the weld due to near surface interface noise, but the near surface volume is effectively

.examinable with 45o full vee-path scans.

RPV Lon itudinal Shell Welds:

The examinations of the lower shell vert>ca we s -, u, and C are limited due to near surface interface noise.

Those volumes shadowed by the interface noise are effectively examinable with the 45 full vee-path

scans, except for a small area of interference from the cor e barrel anti-rotation lugs.

The examination of weld 101-142C is also limited due to interference of the surveillance capsules.

This volume is effectively examinable by the 45 full vee-path beam.

Transverse examinations are not limited by the lugs of capsules.

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Examination of the middle shell vertical welds is limited by near surface interference noise in the case of Oo and 60o beams;

however, the 45 full vee-path scans obtain full coverage.

The 60o examination of weld 101-124C is further limited by interference from the surveillance capsules.

Examination of the upper shell vertical welds is limited by interference from the inlet nozzle inner radius bend and the outlet nozzle integral extension.

However, the examinations are comple-mented by the nozzle-to-shell weld examinations.

RPV Closure Head Melds:

The RPV closure head flange-to-torus weld examsna son ss smste by instrument nozzle penetrations and control element drive mechamism (CEIN) penetrations.

Examination of the four torus peel segment welds and the torus-to-dome weld is also limited by instrument nozzle and GEOM penetrations in the RPV closure head.

Suosaary:

Limitations.to effective coverag of ASME Code required examination volumes will be experienced during the St.

Lucie 2 RPV inservice examinations.

The limitations are minimized to the maximum extent possible.

Future equipment and technique development may further reduce limitations to subsequent inservice inspecti ons.

The extent of examination achievable is sufficient to assure an adequate level of quality and safety.

Supplementary manual examinations are impractical because of the radiation levels in-volved and would represent a hardship or unusual difficultywithout a compensating increase in the level of quality and safety.

Evaluati on Five ultrasonic scans are conducted on each weld in th RPV and RPV closure head using Oo, 45o, and 60 scan angles with both parallel and transverse configuration for the 45o and 60o angles.

Additional scan angles of 1.5o, 5.7o, and 12.5o are used to scan the flange side of the upper shell-to-flange weld.

By using the multiple scan

angles, the licensee is able to achieve good coverage of the code required volume on the reactor pressure vessel welds.

The lower head dollar plate weld and the six meridional head welds are given 100% coverage on each scan.

Of the 13 welds in the shell region lower head, essentially 100% coverage of the code required volume is achieved with at least one scan angle for all but one circumferential weld.

Approximately 80% coverage of the code required volume is achieved on the lower

shell-to-middle shell weld.

The RPV closure head welds generally are examined with from 50 to 100% coverage of the code required volume.

In addition to ultrasonic testing, the licensee will imple-ment the Code required leakage and hydrostatic testing of the RPV welds, which would provide initial evidence of seepage from a through-wall perforation.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed

above, adherence to the Code requirements is im-practical.

It is further concluded that the proposed examinations will provide necessary assurance of structural reliability during this interval.

Therefore, relief is recommended as requested prov ided (a) the volumetric examinati'ons are performed to the maximum extent practical, and (b) the Code required system pressure tests are performed.

References References 5, 6, 8, and 9.

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~ 3.1.1.2 Relief Re vest No. 2, Full Penetration Welds of Nozzles in Vessels, Categor 8-0 Items B3.90 and B3.100 Code Re uirement The nozzle-to-vessel weld and the nozzle inside radius

section, including adjacent areas of the nozzle and vessel, of all reactor vessel nozzles shall be volumetrically examined in accor-dance with the applicable portion of Figure IMB-2500-7.

At least 255 but not more than 50% (credited) of the nozzles shall be examined by the end of the first inspection period and the remainder by the end of the inspection interval.

If examinations are conducted from inside the component and the nozzle weld is examined by straight beam ultrasonic method from the nozzle bore, the remaining examinations required to be conducted from the shell may be performed at or near the end of each inspection interval.

Code Relief Request Relief from volumetric examination of 100% of the Code required volume is requested for the primary coolant inlet and outlet nozzle on the reactor pressure vessel.

Proposed Alternative Examination (a)

Periodic System Leakage tests per Category B-P, Table IM8-2500-1;*

(b)

Inservice Hydrostatic Test per Category B-P, Table IWB-2500-1;~

(c)

The extent. of examination volume achieved ul tr asoni cally and the alternative 'examinations and tests provide assurance of an acceptable level of quality and safety.

Licensee's Basis for Requestin Relief The inlet and outlet nozzle-to-shell welds are examined from the shell side and from the nozzle bore.

The nozzle bore examina-tions are limited due to near surface interface noise;

however, surface wave examinations are performed on the nozzle inner radius sections.

The shell side transverse examinations of the outlet nozzles are limited due to interference from the nozzle integral extensions.

• These alternatives proposed by the licensee are already required by the Code.

Evaluati on The licensee will examine the primary coolant nozzles on the RPV from hoth the shell side and the bore.

Five ultrasonic scans, which include scan angles of Oo, 45o, and 60o with both parallel and transverse scans at the 45o and 60o angles will be used on the shell side.

Scan angles of 15o and 45o will be used for examina-tions from the bore of the nozzles.

The licensee estimates that 975 of.the code required volume will be examined on the inlet

nozzles, and 92% of the code required volume will be examined on the outlet nozzles using the combined scan results.

In addition, the licensee has indicated that the nozzles will be visually examined during periodic system leakage tests and hydrostatic tests required under Category B-P.

The licensee has attempted to minimize the limitations of volumetric examination of the RPV nozzles by employing a variety of scan angles and by conducting examinations from both the shell side and the bore.

Over 90% coverage of the RPV nozzle code-required volume has been achieved.

Additio'nal manual ultrasonic examination could provide some additional coverage; however, it does not appear to be prudent based on the trade-off between radiation exposure to personnel and increased confidence in the structural integrity of the nozzles.

The ultrasonic examinations combined with the visual exami-nation (which would provide initial evidence of seepage from through-wall perforations) should provide an adequate level of confidence in the structural reliability of the nozzles.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed

above, adherence to the Code requirements is im-practical.

It is further concluded that the proposed examinations will provide necessary assur ance of structural reliability during this interval.

Therefore, relief is recommended as requested provided (a) the volumetric examinations are performed to the maximum extent practical, and (b) the Code required system pressure te'sts are performed.

Referen ces Reference 5, 6, 8, and 9.

14

3.1.2 Pressurizer 3;1.2.1 Relief Request No. 2, Pressure-Retainin Welds in Vessels Other than Reactor

Vessels, Cate ory B-B,.Item B2.11 Code Requirements All circumferential* shell-to-head welds in the pressur izer shall be volumetrically examined in accordance with Figure IWB-2500-1 over essentially 100K of their length during the first inspection interval.

Code Relief Request Relief is requested from 1005 volumetric examination of the pressurizer circumferential lower head-to-shell weld.

Proposed Alternative Examination (1)

Periodic System Leakage tests per Category B-P, Table IWB-2500-1'*

(2)

-Inservice hydrostatic test per Category B-P, Table IWB-2500-1;*

(3)

The extent of examination volume achieved ultrasonically, and the alternative examinations and tests, provide assurance of an acceptable level of quality,and safety.

Licensee's Basis for Requestin Relief Configuration and permanent attachments prohibit 100%

ultrasonic examination coverage of the required examination volume.

Additional ultrasonic techniques are employed, where practical, to achieve the Code-required volume.

In most cases, the interferences affect only a small portion of one examination angle.

In all cases, 100K of the weld root is examined in at least one direction by at least one angle.

• These alternatives proposed by the licensee are already required by the Code.

Evaluation 0

The lower shell-to-head weld on the pressurizer is partially obscured by the support skirt attachment to the pressurizer.

Ap-proximately 80% of the code required volume is covered, including the weld root, with the 60-degree angle scan from the head side of the weld.

For the 60-degree scan from the shell side and the 45-degree scan from both sides, 100% of the code required volume is covered.

The achievable volumetric coverage of the weld is acceptable in conjunction with the proposed hydrostatic and system leakage

tests, which would provide initial evidence of seepage from through-wall per forations..

Conclusions and Recommendations Based on the above evaluation,'t is concluded that for the welds discussed

above, the Code requirements are impractical.

is further concluded that the alternative examination discussed above will provide the necessary added assurance of structural reliability.

Therefore, relief should be granted fr om volumet-rically examining those portions, of the subject weld that are obstructed provided (a) the welds are volumetrically examined to the maximum extent practical, and (b) the Code-required system pressure tests are performed.

References References 5, 6, 8, and 9.

16

3.1.2.2 Relief Request No. 3, Full Penetration fields of Nozzles in Pressur izer;.Cate or B-D, Items B3.110 and 83;120 Code Requirement The nozzle-to-vessel weld and the nozzle inside radius

section, including adjacent areas of the nozzle and vessel, of all pressurizer vessel nozzles shall be volumetrically examined in ac-cordance with the applicable portion of Figur e IHB-2500-7. If examinations are conducted from inside the component and the nozzle weld is examined by straight-beam ultrasonic method from the nozzle bore, the remaining examinations required to be conducted from the shell may be performed at or near the end of each inspection interval.

Code Relief Re uest Relief from volumetric examination of 100% of the Code required volume is requested for, the specified full penetration nozzle welds on the pressurizer vessel.

Proposed Alternative Examination (1)

Periodic System Leakage tests per Category B-P, Table IM8-2500-1;*

(2)

Inservice Hydrostatic test per Category B-P, Table IWB-2500-1.*

Licensee's Basis for Re uestin Relief Configuration and permanent attachments prohibit 100% ultra-sonic examination coverage of the required examination volume.

Additional uItrasonic techniques are employed, where practical, to achieve the Code required volume.

In all cases, 100~ of each weld root is achieved in one direction by at least one angle.

In most cases, 100K of the required examination volume is achieved in one direction by one angle.

• These alternatives proposed by the licensee are already required by the Code.

17

Evaluation The pressurizer nozzles to be examined include five nozzles and a manway on the top'head and surge line nozzle oh the bottom head.

The five nozzles on the upper head are located in a cluster with from 4 in. to 8 in. clearance between the nozzle flanges.

This nozzle configuration results in mutual interference during nozzle examinations for all scan angles (Oo, 45o, 60o).

As a

result of the interference, coverage is limited to a minimum of 70% of the Code required volume for some scans.

However, 100% of the Code required volume on each nozzle is covered by at least one scan at one angle.

Examination of the surge line nozzle on the pressurizer bottom head is limited by ten heater penetrations which surround the nozzle.

The limitation applies only to the 60-degree scan angle and 100K of the Code required volume is covered by the scan at 45o.

Volumetric coverage of the nozzle welds on the pressurizer includes 100+ of each weld root and 100% of the Code required volume for at least one scan at one angle on each nozzle.

Th'.s extent of volumetric examination, together with the visual examination of the nozzles during pressure tests (which would provide initial evidence of seepage from through-wall perfora.ions) should provide adequate assurance of structural reliability.

Conclusions and Recommendati ons Based on the above evaluation, it is concluded that for the welds discussed

above, adherence to the Code.,requirements is im-practical.

It is further concluded that the proposed examinations will provide necessary assur ance of structural reliability during this interval.

Therefore, relief is recommended as requested provided (a) the volumetric examinations are performed to the maximum extent practical, and (b) the Code required system pressure tests are performed.

Ref er ences References 5, 6, 8, and 9.

18

3.1.3.1 Relief Request No. 2, Pressure-Retainin Welds in Vessels Other Than Reactor Vessels, Cate or B-B; Items 82.31 and 82.40 Code Requirement All circumferential head welds in the primary side of the steam generators shall be volumetrically examined in accordance with Figure IWB-2500-3 over essentially 100% of their length during the first inspection interval.

The tubesheet-to-head weld in the primary side of the steam enerators shall be volumetrically examined in accordance wi th igure IWB-2500-6 over essentially 100% of its length during the first inspection interval.

Code Relief Re uest Relief is requested from 100% volumetric examination of four circumferential head welds on the steam generators.

Proposed Alternative Examination (1)

Periodic System Leakage tests per Category B-P, Table IWB-2500-1;*

(2)

Inservice hydrostatic test per Category B-P, Table IWB-2500-1;*

(3)

The extent of examination volume achieved ul trasoni cally, and the alternative examinations and tests, provide assurance of an acceptable level of quality and safety.

Licensee's Basis for Requestin Relief Configuration and permanent attachments prohibit 100" ultra-sonic examination coverage of the required examination volume.

Additional ultrasonic techniques are employed, where practical, to achieve the Code-required volume.

In most cases, the interferences ll

• These alternatives proposed by the licensee are already required by the Code.

19

affect only a small portion of one examination

angle, In all

cases, 100% of the weld r oot is examined in at least one direction by at least one angle.

Evaluati on The ultrasonic scans of the extension ring-to-head and the extension ring-to-tubesheet weld on each steam generator are obstructed by manways, 1-in. instrument nozzles, and the inlet nozzle.

On the extension ring-to-head welds, at least 92K of the Code required volume is examined from one side and 100% from the opposite side.

On the extension ring-to-tubesheet

weld, 92% of the Code r equired volume is examined using a 60-degree scan angle and 99K of the volume using a 45-degree scan angle.

The achievable volumetric coverage of the weld is acceptable in conjunction with the proposed hydrostatic and system leakage

tests, which would provide initial evidence of seepage from through-wall perforations.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds, discussed

above, the Code requirements are impractical.

It is further concluded that the alternative examination discussed above will provide the necessary added assurance of structural reliability.

Therefore, relief should be granted from volumet-rically examining those portions of the subject welds that are obstructed provided (a) the welds are volumetrically examined to the maximum extent practical as

proposed, and (b) the Code-required system pressure tests are performed, References References 5, 6, 8, and 9.

20

'3-1.3.2 Relief Request No. 3, Full Penetration Melds of Nozzles in the Steam Generator; Cate or B-D, Item B3.130 Code Requirement The nozzle-to-vessel weld, including adjacent areas of the nozzle and vessel, of all steam generator nozzles shall be volumetrically examined in accordance with the applicable portion of Figure IMB-2500-7. If examinations are conducted from inside the component and the nozzle weld is examined by straight-beam ultrasonic method from the nozzle bore, the remaining examinations required to be conducted from the shell may be performed at or near the end of each inspection interval.

Code Relief Request Relief from volumetric examination of 100% of the Code required volume is requested for the specified full penetration nozzle welds on the steam generator.

Proposed Alternative Examinati on (1)

Periodic System Leakage tests per Category B-P, Table IHB-2500=1;"

(2)

Inservice Hydrostatic test per Category B-P, Table IWB-2500-1.*

Licensee's Basis for Requestin Relief Configuration and permanent attachments prohibit 100% ultra-sonic examination coverage of the required examination volume.

Additional ultrasonic techniques are employed, where practical, to achieve the Code required volume.

In all cases, 100" of each weld root is achieved in one direction by at least one angle.

In most cases, 100K of the required examination volume is achieved in cne direction by one angle.

The extent of examination coverage achieved ultrasonically and the alternative examinations and tests provide assurance of an acceptable level of quality and safety.

• These alternatives p."oposed by the licensee are already required by the Code.

21

Evaluation Ultrasonic scans of the primary inlet and outlet nozzle weld attachments to the head on the steam generators are limited by access restrictions.

The steam generator stay base, which is the primary support for the vessel, interferes with the ultrasonic scan equipment so that a portion of the scan cannot be completed.

The restriction only applies to the 60 scan angle and at least 93>> of the weld is covered with the 60 angle beam for all the primary nozzles.

For the 0o and 45o angle scan, 100% of the Code required.

volume is covered for all the primary nozzles on the steam gen er ator s.

The licensee has indicated that the steam generator nozzle-to-vessel welds will be visually examined during system pressure tests as an alternative examination.

~ I' The steam generator nozzle welds are scanned over the entire Code required volume with a Oo and 45 beam angle and only lOX of the Code required volume is not covered with the 60o angle scan.

The visual examination during pressure tests (which would provide initial evidence of seepage from through-wall perforations).

This combination of examinations should be adequate to confirm the structural condition of the nozzle welds.

'LP. ~

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed

above, adherence to the Code requirements is im-practical.

It is further concluded that the proposed examinations will provide necessary assur ance of structural reliability during this interval.

Therefore, relief is recommended as requested provided (a) the volumetric examinations are performed to the maximum extent practical, and (b) the Code required system pressure tests are performed.

References References 5, 6, 8, and 10.

22

6 3.1.4 Piping Pressure Boundary I

I 3.1.4.1 Relief Request No. 5;.Pressure Retainin Dissimilar Metal Welds in.Reactor Coolant-Pump-Safe Ends; Cate ory B-J; Item B9;ll Code Requirements For circumferential welds in pipe of nominal pipe size 4 in.

and greater, surface plus volumetric examinations shall be performed in accordance with Figure IWB-2500-8 over essentially 100% of the weld length during each inspection interval.

The examination shall include the following:

(a)

All terminal ends in each pipe or branch run connected to vessels.

(b)

All terminal ends and joints in each pipe or branch run connected to other components where the stress levels exceed the following limits under loads associated with specific seismic events and operational conditions.

(1) primary plus secondary stress intensity of 2.4Sm for ferritic steel and austenitic steel, and (2) cumulative usage factor U of 0.4.

(c)

All dissimilar metal welds between coabinations of (a) carbon or low alloy steels to high alloy steels, b) carbon or low alloy steels to high nickel alloys, and c) high alloy steels to high nickel alloys.

(d)

Additional piping welds so that the total equals 25>> of the circumferential joints in the reactor coolant piping system.

This does not include welds excluded by IWB-1220.

These addi tion al wel ds may be 1 oca ted in one 1 oop.

For welds in carbon or low alloy steels, only those welds showing reportable preservice tr ansverse indications need be examined for transverse reflectors.

I Code Relief Re uest foal Relief from volumetric examination of 100% of the Code required volume is requested for the dissimilar metal welds on the primary coolant pump suction and discharge nozzle safe ends.

23

t Pr opos ed er nati v e Examin ati on

(

(1)

The ultrasonic examinations will be performed to the maximum extent possible by the employment of a full-scale mockup in lieu of the standard Code calibration block.

The mockup is constructed of identical materials with a duplication of the construction field welds and the duplication of the shop welds 1ch pp d

d yf thi pl (2)

Periodic System Leakage tests per Category B-P, Table IWB-2500-1;*

(3)

Inservice Hydrostatic test per Category B-P, Table IWB-2500-1;*

(4)

Surface (liquid penetrant) examination per Categories 8-F and B-J, Table IWB-2500-1;*

(5)

For those items scheduled for examination, the extent of the examination volume achievable ultrasonically and the alterna-tive tests and examinations provide assurance of an acceptable level of quality and safety.'icensee's Basis for Requestin Relief (1)

Due to the geometric confi guration of the safe-end welds, the required volume, where applicable, will not be 100% examined.

A thorough technical analysis was performed to establish a

supplementary ultrasonic technique or an additional alter-native examination.

A summary of the results of this analysis shows that these welds are examined to the maximum extent practical consistent with their geometric configuration; (2)

The welds scheduled for examination in the first inspection interval, for which relief is requested, were identified in the licensee's submittal.

(3)

The supplementary examination technique and the weld volume coverage achieved during preservice inspection were given in the licensee's submittal.

The same

.echniques and volume will prevail for inservice inspection.

Evaluati on The St. Lucie 2 plant contains four primary coolant circulation

pumps, and the inlet and outlet nozzle on each pump is attached to the piping with a safe end.

The pump casing and safe end are

• These alternatives proposed by the licensee are already requ',red by the Code.

fabricated from SA 351-CFSM material which is a centrifugally cast stainless steel.

This material is characterized by relatively large grains in a columnar structure that is aligned radially.

The iping connected to the safe end is SA-516 Gr. 70 carbon steel with 04 stainless steel roll-bonded cladding on the interior.

The pump outlet is a straight pipe with a wall thickness of 2.8 in.

The pipe is attached by a shop weld to the safe end which has a wall thickness of 3.2 in.

The safe end is in turn attached to the pump nozzle by a field weld.

The wall thickness of the pump nozzle is thicker than the safe end.

The overall joint to be examined is a section, which increases gradually in cross section from the pipe to the pump nozzle and includes two welds.

The pump inlet piping is an elbow attached to the pump suction nozzle through a safe end.

Although the elbow is fabricated from the same material as the piping, its wall thickness is 3.6 in.

ccmpared to 2.8 in. for straight pipe.

Correspondingly, the inlet piping joint varies in cross section from 3.6 in. at the elbow down to 3.2 in. thickness at the same end and back up to a thickness greater than 3.6 in. at the pump inlet nozzle.

The elbow to safe-end weld is a shop weld and the safe-end to pump weld is a

field weld.

~

~

As a result of the joint configuration, ultrasonic examination of the pump nozzle safe-end welds is difficult.

The outlet nozzle welds can be examined to save extent except from the pump side of the safe-end to pump nozzle field weld.

Access limitations essen-tially prohibit the examination.

Examination of the inlet nozzle safe-end welds is nach more limited.

Complete examination from the elbow side of the elbow to safe-end shop weld can be completed;

however, the surface contours of the welds severely limit examina-tion of the safe-end side of both the'elbow-to-safe-end and shop weld and the safe-end-to-pump nozzle field weld.

Examination of the pump side of the pump nozzle-to-safe end weld is severely limited due to access limitations.

The weld materials, geometrical configuration of the safe-end

joints, and ihe limited access coabine to make detailed inspection of the safe-end welds on the RCP pumps difficult.

The licensee has constructed a full-scale mockup of the weld c'onfiguration on the pump outlet for use in evaluating examination methods.

The mockup is constructed with materials identical to the plant installation and the welding parameters were duplicated to the extent practical.

Flaws, including side-drilled holes and a notch, have been machined into the mockup.

The mockup has been used to develop examination procedures, calibrate

methods, and evaluate equipment.

Several search units were evaluated and a model was selected to achieve maximum useful results.

The search unit was contoured to enhance beam focus.

Several procedures and calibration methods were evaluated on the mockup using the equipment and search unit selected.

As a result, 25

optimum procedures and calibration methods were selected for use on the plant.

The expected examination coverage of the pump safe-end welds is shown in Table 1.

This coverage was achieved in the PSI.

The outlet nozzles receive the most complete coverage primarily because the examination surface is more uniform.

Both inlet and outlet

~

nozzles receive 100% coverage from the piping side and partial coverage from the safe-end side for the carbon steel to stainless steel shop weld.

The stainless steel to stainless steel field welds between the safe end and the pump nozzle receive substantially less cover age.

TABLE 1

~Com anent Elbow to Safe End (Shop Weld) ow iae ave n

sac Safe End to Pump (Field Weld) are na iae ump >>oe A-1 Inlet A-2 Inlet B-l Inlet B-2 Inlet 100

~

20 100 0

100 0

100 0

30 20 10 10 30 0

0 0

Pipe to Safe End (Shop Meld)

Safe End to Pump (Field Meld)

A-1 Outlet A-2 Outlet B-1 Outl et B-2 Outlet lpe 1

e 100 100 100 100 ave n

5>

e 100 30 100 30 a e na iae ump

>ae 100 50 100 50 The licensee has made a reasonable effort to provide for volumetric examination of the pump safe-end welds.

Complete cover-age of the Code required volume is not achievable with existing equipment; however, the licensee has optimized application of existing equipment for safe-end examination.

The construction of a full-scale mockup played an important role in optimizing current ultrasonic examination methods.

The mockup serves an even more important purpose in. providing a reference for interpretation of examination resul ts.

Although the overall coverage of the Code required volume is less than desirable on the pump safe-end nozzle welds, the coverage should be acceptable in view of the improved interpretation of the limited data which is achieved through use of a full-scale mockup.

In addition, the required surface examinations and visual 26

examinations during pressure tests (which would provide initial evidence of seepage from through-wall perforations) should provide additional information to confirm the structural adequacy of the system.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed

above, adherence to the Code requirements is im-practical.

It is further concluded that the proposed examinations will provide necessary assurance of structural reliability during this interval.

Therefore, relief is recommended as requested provided (a) the volumetric examinations are performed to the maximum

'extent practical, and (b) the Code required system pressure tests are performed.

References References 5 and 10.

3.1.4.2 Relief Request No. 6, Pressure Retainin Welds in Pipin, g

~

Categor B-J,.Items B9.11; 89.12; and B9.31 Code Requirements

'or circumferential (B9.1 1) and branch pipe connection (B9.31) welds in pipe of nominal pipe s ize 4 in.

and greater, surface plus volumetric examinations shall be performed in accordance with Figures IWB-2500-8, -9, -10, and -l,l over essentially 100% of the weld length during each inspection interval.

The examination shall include the following:

(a)

All terminal ends in each pipe or b~anch run connected to vessel s.

J (b)

All terminal ends and joints in each pipe or branch run connected to other components where the stress levels exceed

.the following limits under loads associated with specific seismic events and operational conditions.

(1) primary plus secondary stress intensity of 2.4Sm for ferritic steel and austenitic steel, and (2) cumulative usage factor U of 0.4.

(c)

All dissimilar metal welds between coabinations of (a) carbon or low alloy steels to high alloy steels, b

carbon or low alloy steels to high nickel alloys, and c

high alloy steels to high nickel alloys.

(d)

Additional piping welds so that the total equals 25K of the circumferential joints or branch connection welds in the reactor coolant piping system.

This does not include welds excluded by IWB-1220.

These additional welds may be located in one loop.

For longitudinal (B9.12) welds in pipe of nominal pipe size 4 in. and greater, surface plus volumetric examinations shall be performed in accordance with Figure IWB-2500-8 for at least a

pipe-diameter length, but not more than 12 in., of each longi-tudinal weld intersecting the circumferential welds required to be examined.

For. welds in carbon or low alloy steels, only those welds showing reportable preservice transverse indications need be examined for transv er se ref 1 ector s.

28

Code Relief Re uest 0

Relief is requested from volumetrically examining 1005 of the requ.ired volumes of certain Class 1 pipe welds (circumferential,

'branch connection, and longitudinal) in piping greater than 4 in.

diameter.

Specific welds, covered by this relief request and scheduled to be examined during this interval, are identified in Table 2.

Proposed Alternative Examination

.(1)

Periodic system leakage tests per Category B-P, Table IWB-2500-1 *

(2)

Inservice hydrostatic test per Category B-P, Table IMB-2500-1;*

(3)

Surface examination per Category 8-J, Table IMB-2500-1;*

(4)

For those items selected for examination, the extent of exami-nation volume achieved ultrasonically, and the alternative examinations and tests, provide assurance of an acceptable level of quality and safety.

Licensee's Basis for Requestin Relief Configur ation, permanent attachments',

and/or structural inter-ferences prohibit 100% ultrasonic examination coverage of the required examination volume.

Additiona'1 ultrasonic techniques are

employed, where practical, to achieve the Code required volume.

Evaluation The licensee has r equested relief from 100% coverage of the Code required volume on 22 Class 1 piping welds.

Seventeen of the welds are circumferential piping joiqts, three are branch connec-

tions, and two are longitudinal seam welds in piping.

The two major reasons for requesting relief are limited physical access for inspection equipment and joint configurations, which limit search unit contact with the surface.

Partial volumetric examinations are to be conducted on all the welds for which relief is requested, and at least 50% of the Code required volume is covered on all the

• These alternatives proposed by the licensee are already required by the Code.

29

1 t

Table 2.

MELDS SCHEDULED FOR EXANINATION Area Zone Code Item Description Average Coverage

.%. cRva,b Limitati on s 6.7 B9.11 B9.11 Loop 2A.Hot Leg:

~ Elbow to inlet nozzle

.extension

'Inlet nozzle extension to nozzle 99%

65%

100%

CRV from pipe side limited from nozzle side due to OD taper 7.10 B9.31 Shutdown cool ing nozzle branch connection 50%

100%

CRV from one side only - access res tricti ons 8.17 B9.11 89.11 Loop 2A, Intermediate Cold Leg:

~ SG nozzle to extension

~ Extension to elbow 50%

99>>

100%

CRV from pipe side limited from nozzle side due to OD taper 9.3 B9.12 Pipe Seam Meld 91.5%

Access limited by welded attachment lugs 11.3 B9.12 Pi pe Seam Weld 60%

Access limited by welded lug attach-ment and penetra-tion housing 12.1 Loop 2A, Intermediate Cold Leg:

89.11

~ SG nozzle to extension B9.11

~ Extension to elbow 50%

99>>

100%

CRV from elbow side limited from nozzle side by OD taper 21.3 B9.11 Pipe to Valve (V-3227) 85%

Limited by config-urationn 21.5 B9.11 Valve to Pipe 92%

Limited by config-ur ation 21.8 89.11 Pipe to Elbow 96%

Limited by lift-off at toes of weld

~"

30

Table 2

(continued) l a

l Area Code Zone Item Oescri tion Average Coverage t Ciiy a Limitations 21.33 B9.11 Pi pe to Valve (V-3624) 50%

100%

CRV from one side only due to configuration 22.5 B9.11 Valve (Y-3217) to Pipe 58%

100%

CRV from one side only due to confi gurati on 22.16 B9.11 Pipe to Valve (V-3614) 23.5 B9.11 Yalve (Y-3237) to Pipe 23.22 B9.11 Pipe to Valve (V-3634) 24.5 B9.11 Valve (V-3247) to Pipe 24.18 89.11 Pipe to Valve (V-3644) 28.2 B9.31 Sweepolet to, Pi pe 28.33 B9.31 Pipe to Tee 28.42 B9.11 Elbow to Pi pe 50%

50%

50%

50%

50%

50%

86.5%

83.5%

100%

CRY from one sioe only due to confi gurati on 100%

CRV from one side only due to confi gurati on 100%

CRV from one side only due to configuration 100>>

CRV from one side only due to confi gurati on 100%

CRV from one side only due to confi guration 100%

CRV from one side only due to confi gurati on Limited by tee geometry Limited by trans-ducer lift-offat toes of weld a.

The percentages represent the arithmetic average of all scans.

b.

CRY - Code required volume.

SG

- steam generator.

31

~

0 welds.

The required surface examinations and visual examinations during pressure tests (which would provide initial evidence of seepage from through-wall perforations) in conjunction with the partial,.volumetric examinations will confirm the structural adequacy of the system.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed

above, adherence to the Code requirements is imprac-tical. It is further concluded that the proposed examinations will pr ovide necessary assurance of structural reliability during this interval.

Therefore, relief is recommended as requested provided (a) the volumetric examinations are performed to the maximum

, extent practical, and (b) the Code-required surface examinations and system pressure tests are performed.

Refer en ces References 5, 6, 8, and 9.

32

~ 3-1.5 Pump Pressure Boundary I

3.1.5.1 Relief Request No; 7,=

Pump Casin s, Cate or B-L-2, Item B12.20 Code Requirements A visual examination of the internal surfaces (VT-3) must be performed on at least one pump in each group of pumps performing similar functions in the system.

The visual examination may be performed on the same pump selected for volumetric examination of the welds.

Code Relief Request Relief is requested from visual examination of the internal surfaces of a reactor coolant pump.

Proposed Alternative Examination (1)

Periodic volumetr ic (RT) examination of the reactor coolant pump casing scroll welds per Table IWB-2500-1, Category B-L-2, Note l.+

(2)

Periodic system leakage test per Category B-P, Table IWB-2500-1;*

'E (3)

Inservice hydrostatic test per Category B-P, Table IWB-2500-1;*

(4)

Perform the required YT-3 examinations in accordance with the sampling criteria of Table IMB-2500-1, Category B-L-2, Note 1, in the event the components are disassembled for maintenance or repair (5)

The alternative tests and examinations provide assurance of acceptable quality and safety.

• These alternatives proposed by the licensee are already required by the Code.

33

Disassembly of the reactor coolant pumps for the sole purpose of performing a visual (VT-3) examination is not practical.

The reactor.

coolant pumps are int>ended, by design, to remain assembled throughout their service. lives.

The process of disassembling these components will result;in considerable exposure of personnel to radiation and significantly increase the risk of component damage or failure without providing a compensating increase in the level of quality and safety.

Evaluation Disassembly of the reactor coolant pumps to the extent required for examination under Category B-L-2 is a major maintenance effort.

Inspection of a pump on a similar plant required nearly 6000 manhours and r esul ted in nearly 50 manrem exposure.

In addi-tion, the pump inspection activity generated a large volume of radioactive was te.

The visual inspection of the pump internal surfaces is intended to detect erosion, corrosion, and surface cracking.

The structural reliability of reactor coolant pump casings in service has been

good, and no significant'egradation has been detected.

Accordingly, the large expenditure of effort to disassemble and inspect the pump is not practical in view of the reliability of primary coolant pump casings.

Visual examination of the pump internal surfaces would not produce an increase in plant safety commensurate with the cost of conducting the examinations.

The Code required examinations of the pump casing 'welds, along with visual examination. for leakage dur ing system pressure tests under Category B-P and periodic testing in accordance with IMP, will provide an adequate level'f safety.

The licensee has agreed to conduct the required inspections if a pump is disassembled for maintenance.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the examinations discussed

above, adherence to the Code requirements is impractical. It is.further concluded that the proposed examinations will provide necessary assurance of structur al reliability during this interval.

Therefore, relief is recommended as requested provided (a) volumetric examination of the pump casing welds is con-ducted in accordance with Category B-L-l,

0 (b) visual examination of the pump casing for leakage is conducted in conjunction with system leakage and hydro-static tests under Category B-P, (c) periodic inservi'ce testing of the pumps is conducted in accordance with IHP, and (d) the required visual examinations are conducted under Category B-L-2.if a reactor coolant pump is disassembled for maintenance.

- References References 5 and 10.

',3.1.6 Valve Pressure Boundary 3.1.6.1 Relief*Request No. 7; Valve Bodies, Cate or B-N-2;.Item.B12.40 Code Requirement A visual (VT-3).examination of the internal surfaces must be performed on at least one valve in each group of valves exceeding 4 in. nominal pipe size which are of the same constructional

design, such as globe, gate, or check valves and manufacturing

method, and that are performing similar functions in the system such as contain-ment isolation and system overpressure protection.

The visual examination may be performed on the same valve selected for volumetric examination of valve body welds.

Code Relief Request Relief is requested from visual examination of the internal surfaces of Class 1 valves in piping greater than 4 in. nominal pipe size (see Table 3).

/

Zone Item ape Tabl e 3.

VALVE INTERNAL SURfACES Component 21.4 21.20 21.24 22.4 22.17 22.22 23.4 23.23 23.33 24.4 24.19 24.24 28.24 28.36 28.52 29.30 29.41 V-3227 V-3528 V-3624 V-3217 V-3614 V-3259 V-3237 V-3634 V-3260 V-3247 V-3644 V-3261 V-3652 V-3651 V-3645 V-3480 V-3481 Check Check Gate Check Gate Check Check Gate Check Check Gate Check Gate Gate Gate Gate Gate 36

Proposed Al ernative Examination (1)

Periodic inservice testing per subarticles IWV-3400 and/or IWB-3520 (valves);*

(2)

Periodic system leakage test per Category B-P, Table IWB-2500-1 *

(3)

Inservice hydrostatic test per Category B-P, Table IWB-2500-1' (4)

Perform the required VT-3 examinations in accordance with the sampling criteria of Table IWB-2500-1, Category B-N-2, Note 3, in the event the components are disassembled for maintenance or repair; (5)

The alternative tests and examinations provide assurance of acceptable quality and safety.

Licensee's Basis for Requestin Relief DisasseInbly of these items (listed in Table 3) for the sole purpose of performing a VT-3 visual examination is not practical.

The valves all have seal-welded bonnets.

The process of dis-assembling these cunponents will result in considerable exposure of personnel to radiation and significantly increase the risc of com-ponent damage or failure without providing a compensating increase in the level of quality and safety.

4 Evaluation Disassembly of large valves to the degree necessary to examine the internal pressure-retaining surfaces is a major effort, which may involve large personnel exposures.

To do this disassembly solely to perform a visual examination of the internal body is impracti ca 1.

The licensee has committed to the concept of visual exami-nation if the valve is disassembled for maintenance.

The visual examination specified is to determine whether anticipated severe degradation of the body is occurring due to phenomena such as erosion or corrosion.

• These alternatives proposed by the licensee are already required by the Code.

37

The visual examinations for leakage during system pressure tests under Category B-P and periodic testing in accordance with IWV as proposed by the licensee provide an adequate level of safety.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the examinations discussed

above, adherence to the Code requirements is impractical. It is further concluded that the proposed examinations will provide necessary assurance of structural reliability dur ing this interval.

Therefore, relief is recommended as requested provided

{a) periodic inservice testing of the valves is conducted in

'.accordance with IMV, (b) visual examination of the valves for leakage is conducted

- in conjunction with system leakage and hydrostatic tests under Category B-P, and (c) the required visual examinations are conducted under Category B-N-2 if a valve is disassembled for maintenance.

References References 5 and 9.

3. 2 CLASS 2 COMPONENTS SUbsections IMA and IWC of the Code govern the examination of Class 2 piping and components.

Specific requirements are given in Table I WC-2500-1.

3.2.1 Pressure Vessels and Heat Exchangers 3.2.1.1 Relief Request No. 8, Pressure Retainin Welds in Pressure

Vessels, Cate or C-A, Items Cl.10, Cl;20, and Cl;30 Code Requirement Shell circumferential welds at gross structural discontinuities, (Cl.10), head circumferential welds (C1.20),

and tubesheet-to-shell welds (Cl.30) in Class 2 pressure vessels must be volumetrically examined in accordance with Figure IMC-2500-1 or IMC-2500-2 over essentially 100% of the weld length.

Gross structural discontinuity is defined in N8-3213.2.

Examples are junctions between shells of different thicknesses, cylindrical shell-to-conical shell junctions, and shell (or head)-

to-flange welds and head-to-shell welds.

In the case of multiple vessels of similar design, size, and service (such as steam gen-

erators, heat exchangers) the required examinations may be limited to one vessel or distributed among the vessels.

Code Relief Request Relief is requested

• om volumetric examination of 100% of the

'ode required volume for six welds on steam generator 2A, and two girth welds on shutdown cooling heat exchanger 2A.

Proposed Alternative Examination (1)

Inservice hydrostatic test per Category C-H, Table IWC-2500-1*

(2)

The extent of examination volume achieved ultrasonically, and the alternative examinations and tests, provide assurance of an acceptable level of quality and safety.

• This alternative proposed by the licensee is already required by the Code.

39

Licensee's Basis for Re uestin Relief Configuration, permanent attachments, and/or structural interferences prohibit 100% ultrasonic examination coverage of the required volume.

Additional ultrasonic techniques are employed, where practical, to achieve the Code required volume.

In all

cases, ultrasonic examination covers 100% of the weld root.

In most cases, 1004 of the required volume is achieved by at least one angle from at least one side.

In all cases, the missed volume is minimal, amounting to 6X in the worst case.

Evaluation Relief is requested from 100>> coverage of the Code required volume for six Class 2 welds on steam generator 2A.

Not less than 94% of the code required volume is covered on each of the welds and 100% of the weld root is covered in all cases.

For five of the six

welds, 1005 of the volume is covered from one side.

Relief is also requested from 100% coverage of the Code required volume for two girth welds on shutdown cooling heat exchanger 2A.

The welds are partially obstructed by reinforcing pads for the inlet and outlet. nozzles.

Approximately 78K coverage of the Code required volume was achieved on each weld.

Essentially 100% of the six welds on the steam generator are examined volumetrically, and nearly 80% of the Code required volume is examined on the shutdown cooling heat exchange~.

The extent o, coverage achieved volumetrically in combination with the proposed Code requir ed system pressure tests should assure an adequate level of safety.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed

above, adherence to the Code requirements is imprac-tical. It is further concluded that the proposed examinations will provide necessary assurance of structural reliability during this interval.

Therefore, relief is recommended as requested provided (a) the volumetric examinations are performed to the maximum extent practical, and (b) the Code-required system pressure tests are performed.

Ref erences References 5 and 9.

40

0

~

,3.2.1.2 Relief Re uest No. 9, Pressure Retainin Nozzle Welds in Vessels, Categor C-B,'. Item C2.20 Code Requirement The nozzle-to-shell (or head) welds of all nozzles in vessels over 1/2 in. nominal thickness at terminal ends of piping runs shall be surface and volumetrically examined in accordance with Figure IWC-2500-4 during each inspection interval.

Terminal ends are the extremities of piping runs that. connect to vessels.

Only those piping runs selected for examination under Category C-F are included.

Code Relief Re uest Relic'f is requested from volumetrically examining 100% of the required volumes of the following four nozzle-to-vessel wel ds:

. Steam gener ator nozzle-to-head weld

- Steam generator feedwater nozzle-to-head weld

~ Shutdown cooling heat exchanger nozzle-to-vessel weld

~ Shutdown cooling heat exchanger outlet nozzle-to-vessel weld.

Proposed Alternative Examination (1)

Inservice hydrostatic test per Category C-H, Table IWC-2500-1*

(2)

The extent of examination coverage achieved ultrasonically, and the alternative examinations and tests, provide assurance of an acceptable level of quality and safety.

Licensee's Basis for Re uestin Relief (1)

The shutdown cooling heat exchanger nozzle welds are totally inaccessible to both RT and UT methods of exam',nation, due to welded pads placed over the welds.

(2)

For other nozzles, configuration, permanent attachments, and/or structural interferences prohibit 1004 ultrasonic examination

• This alternative proposed by the licensee is already required by the Code.

coverage o

the required volume; however, t volume missed is minimal, amounting to 2X in the worst case and affecting one examination angle only.

Additional ultrasonic techniques are

employed, where practical, to achieve the Code r equired volume.

Evaluation

,y~

The two steam generator nozzles can b'e examined from one side only.

Volumetric examinations are conducted with 60-degree and 45-degree UT beams and. essentially 100% of the CRV is covered with both angles from one side only on both welds. 'nly 2X of the CRV is missed on the 60% scan for one weld.

The extent of volumetric examination achieved in combination with the required surface examination and hydrostatic tests should provide an adequate level of safety for the steam generator nozzle welds.

The two shutdown cooling heat exchanger hozzle welds are completely covered by a reinforcing pad welded to the nozzle and the shell.

Neither UT or RT volumetric examination nor surface examination of the nozzle-to-vessel weld is possible for the existing, configuration.

Surface examination of the pad-to-nozzle and pad-to-shell weld could provide a measure of increased confi-dence in the structural reliability of'he nozzle and should be implemented.

Surface examination of ihe pad welds in coohination with the required hydrostatic tests, which would provide initial evidence of seepage from through-wall perforations, will provide an adequate level of quality and safety.

J Conclusions and Recommendations I

I g

.'.i ~

Based on the above evaluation, it is concluded that for the welds discussed

above, adherence to the Code requirements is imprac-tical. It is further:concluded that the proposed examinations wi11 provide necessary assurance of structural reliability during this interval.

Therefore, relief is recommended as requested provided (a) the volumetric examinations are performed to the maximum extent practical, (b) the Code-required surface and system pressure tests are performed on the steam generator

nozzles, and (c) surface examinations of the pad-to-nozzle and pad-to-shell weld are conducted on the shutdown cooling heat exchanger.

Refer en ces Refer ences 5, 6, 8, and 9.

42

', 3.2.2 Piping Pressure Boundary 3.2.2.1 Relief Re uest No; 10; Pressure Retainin Welds in P ipin,

Categor AC-F; Items C5.ll, C5;12; C5.21; C5.22,.C5.31 and C5.32 Code Re uirements One hundred percent of each circumferential weld over 1/2 in.

nominal wall thickness shall be surface and volumetrically examined in accordance with Figure IWC-2500-7 during each inspection inter-val.

Circumferential welds less than or equal to 1/2 in. wall thickness shall receive a surface examination in accordance with IWC-2500-7.

(a) all welds at locations where the stresses under the loadings resulting from Normal and Upset plant conditions as calculated by the sum of Equations 9 and 10 in NC-3652 exceed the speci-fied values; (b) all welds at terminal ends (see (e) below) or piping or branch runs; (c) all dissimilar metal welds; (d) additional welds, at structural discontinuities (see (f) below) such that the total number of welds selected for exami-nation includes the following percentages of circumferential piping welds:

1.

none of the welds exempted by IWC-1220; 2.

none of the welds in residual heat removal and emergency core cooling systems; 3.

10% of the main steam system welds 8 in. nominal pipe size and smaller; 4.

25K of the welds in all other systems.

(e) terminal ends are the extremities of piping runs that connect

~ to structures, components (such as vessels,

pumps, and valves) or pipe anchors, each of which act as rigid restraints or provide at least two degrees of restraint to piping thermal expansion; (f) structural discontinuities include pipe weld joints to vessel nozzles, valve bodies, pump casings, pipe fittings (such as, elbows, tees, r educers, and flanges conforming to ANSI Standard B16.9),

and pipe branch connections and fittings; 43

0 Longitudinal welds over 1/2 in. nominal wall thickness shall be surface and volumetrically examined in accordance with Figur e

.IWC-2500-7, and longitudinal welds less than or equal to 1/2 in.

wall thickness and longitudinal welds in branch connections shall be surface examined (2.5 t at the intersecting circumferential weld) during each inspection interval.

The surfaces of 100% of each circumferential weld in branch connections shall be examined

.in accordance with Figure IWC-2500-9 during each inspection interval.

Code Relief Request Relief is requested from 100% Code required examination for four circumferential pipe-to-valve welds and four longitudinal seam wel ds.

Proposed Alternative Examination (1)

Inservice hydrostatic tests per Category C-H, Table INC-2500-1*

(2)

The extent 'of surface coverage achieved or the volume achieved ultrasonically, and the alternative examinations and tests, provide assurance of an acceptable level of quality and safety.

Licensee's Basis for Requestin Relief (1)

Configuration, permanent attachments, and/or structural inter-ferences prohibit 100% ultrasonic exanination coverage of the required examination volume.

Additional ultrasonic techniques are employed, where practical, to achieve the Code required volume.

(2)

Configuration, permanent attachments, and/or structural inter-.

ferences prohibit 100% coverage of the required examination sur face.

• This alternative proposed by the licensee is already required by the Code.

Evaluation Relief is requested from 100% examination of four pipe-to-valve welds.

Surface examination of one of the welds is limited by weld attached lugs;

however, 944 of the surface is covered.

Two of the four pipe-to-valve welds for which relief is requested can be volumetrically examined from one side only.

The coverage of the Code required volume is 100K for one weld and 97% of the other.

The fourth valve is examined over 77K of the Code required volume, 56K from the pipe side, and 21% from the valve side.

The four longitudinal welds for which relief is requested are on the Nain Steam Lines A and B outside the containment.

The scan is limited to a minimum of 83K of the Code required volume by welded saddle attachments on the pipe in all four cases.

The examination coverage achieved appear s reasonable in view of the access and configuration.

The partial examinations in conjunction with the proposed system pressure tests (which would provide initial evidence of seepage from through-wall perforations) should provide adequate assurance of structural integrity.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed

above, adherence to the Code requirements is imprac-tical., It is further concluded that the proposed examinations will provide necessary assurance of structural reliability during this interval.

Therefore, r elief is recommended as requested provided (a) the volumetric and surface examinations are performed to the maximum extent practical and (b) the Code-required system pressure tests are performed.

References References 5 and 9.

.3.2.2.2 Relief Request No. 11, Pressure Retainin

. Welds in Pipin Con-tainment ray S stem, Cate or.C-F, Items C5.ll and C5.12 Code Re uirements The surfaces of 100% of each circumferential weld 1/2 in. or less nominal wall thickness shall be examined in accordance with Figure IWC-2500-7 during each inspection interval.

The welds selected for. examination shall include (a) all welds at locations where the stresses under the loadings resulting from Normal and Upset plant conditions as calculated by the sum of Equations 9 and 10 in NC-3652 exceed the speci-fied values; (b) all welds at terminal ends (see (e) below) or piping or branch runs;

{c) all dissimilar metal welds;

{d) additional welds, at structural discontinuities (see (f) below) such that the total number of welds selected for exami-nation includes the following percentages of circumferential pi ping welds:

1.

none of the welds exempted by IWC-1220; 2.

none of the welds in residual heat removal and emergency core cooling systems; 3.

10% of the main steam system welds 8 in. nominal pipe size and smaller; 4.

25%, of the welds in all other systems.

(e) terminal ends are the extremities of piping runs that connect to structures, components (such as vessels,

pumps, and valves) or pipe anchors, each of which act as rigid restraints or provide at least two degrees of restraint to piping thermal expansion; (f) structural discontinuities include pipe weld joints to vessel

nozzles, valve bodies, pump casings, pi pe fittings (such as, elbows, tees,

reducers, and flanges conforming to ANSI S andard 816.9),

and pipe branch connections and fittings; Longitudinal welds 1/2 in. or less nominal wall thickness shall be surface examined in accordance with Figure IWC-2500-7 (2.5 t at the intersecting circumferential weld) during each inspection interval.

Code Relief Re vest Relief from surface examination of 64 welds in the open-ended portion of the containment spray system is requested.

Proposed Alternative Examination (1)

At least once every five years, the piping is tested by performing an air or smoke flow test through each spray header to demonstrate an open flow path.

(Ref:

ASNE Section XI, IMC-5222(d) )*

(2)

In the event that the Containment Spray System is operated or in the case of a significant seismic event, FP&L will re-evaluate this relief request to determine if additional non-destructive examinations are warranted.

Licensee's Basis for Requestin Relief (1)

The Containment Spray System piping is not required to operate during normal system operation.

I (2)

Following 'initial inspection and testing, the Containment Spray piping downstream of the second isolation valve outside containment is subject to no pressure transients and no temp-eratur e transients other than ambient Containment Building/

Auxiliary Building pressure and temperature; thus, there is no mechanism for failure.

(3)

ASNE Section XI, Table IMC-2500-'1, Category C-H, Note 1, exempts open-ended portions of systems for VT-2 tests.

Evaluati on The ASNE Code Committee has addressed the subject of open-ended portions of systems in Code Case N-408 (approved by ASNE, July 12, 1984) where the following question is answered:

• This alternative proposed by the licensee is already required by the Code.

47

Inquiry:

Reply:

~

~

When determining the components subject to examination and establishing the examination requirements for Class 2

piping under Section XI, what alternative exemptions to those stated in IWC-1220 and what alternative examination requirements'o those stated in IWC-2500, Category C-F, may be used2 Paragraph (a)(6) of the reply exempts piping and other components of any size beyond the last shutoff valve in open-ended portions of systems (or portions of systems) of RHR, ECC, and CHR systems that do not contain water during normal plant operating conditions from the volu-metric and surface examination requirements of IWC-2500.

Code Case N-408 has been referenced in Regulatory Guide 1.147, Revision 4, dated September 1985.

Therefore, Code Case N-408 is acceptable for use in current or updated inservice inspection programs.

- This regulatory position provides an exclusion from volumetric or surface examination for ASMf Code Class 2 piping and other components of any size beyond the last shutoff valve in open-ended portions of systems that do not contain water during normal plant operating conditions.

The open-ended portion of the containment spray system for which relief is requested is Class 2 piping which does not contain water during normal plant operation.

Accordingly, relief from volumetric and surface examination of the open-ended portion of the containment spray system downstream of the second isolation valve is acceptable.

A key requirement of the Code case is that the exempted piping does not contain water during normal operation.

While the contain-ment spray piping would not normally contain water during plant operation, leaks in the isolation valves could result in water entering the piping.

The air and smoke flow tests proposed by the licensee should be observed.

If those tests are not sufficient <<

determine whether water is present, other appropriate tests should be conducted every five years to determine that water is not con-tained in the open-ended containment. spray pi ping.

Detection of the presence of water in the containment spray piping should be reported to the staff for further evaluation.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the welds discussed

above, adherence to the Code requirements is impractical.

It is further concluded that the proposed examina-tions will provide necessary assurance of structural reliability during this interval.

Therefore, relief is recommended as requested provided 48

(a) the Code required air or smoke flow tests through each header are conducted every five years, and (b) confirmation that water resulting from valve leakage or other causes is not contained in the exempted piping is obtained every five years.

The detection of water during testing,'he operation of the

system, or a seismic event should be reported to the staff for further evaluation.

References References 5 and 9.

3.3 CLASS 3 COMPONENTS No relief requests.

3.4 PRESSURE TESTS No r elief requests.

49

3.5 GENERAL

~ \\

3.5.1 Relief Request No; 13, Ultrasonic Calibration Blocks Code Requirement Calibration blocks for ASME Code Section XI examinations are required to meet Section XI, Appendix III, or Section V require-

ments, as specified in Section XI, IWA-2232.

tg

I. -

1

~ r r3 Code Relief Request Relief is requested for:

(1)

Use of a flat, SA-533 Grade A, calibration block for examination of SA-516 Grade 70, 42-in. diameter primary coolant pi ping hot legs.

(2)

Use of a flat calibration block for examination of 36-in.

diameter primary coolant piping cold legs.

(3)

Use of a 34-in. diameter calibration block for examination of 36.25-in. diameter main steam piping welds.

(4)

Use of r eactor vessel calibration blocks with the 3/4 T straight beam calibration hole, closer to the end of the block than allowed by the ASME Code,Section V, Article 4.

Pro osed Alternative Examination r

Not appli cable.

Licensee's Basis for Re uestin Relief (1)

Cal ibration Bl ock:

UT-4A r

r r4 I,CI Application:

Primary Coolant Piping Hot Legs Code Oeviation:

(a)

The block is flat.

ASME Section XI Appendix III requires the same nominal diameter.

(b)

The block is. SA-533 Gr ade A,'here ASME'Section XI, Appendix III requires the same material as one of the items being joined.

50

Justi fication:

(a)

Article 5 of ASME Section V allows flat blocks for items

~

~

~

~

eater than 20-in. diameter, as does Article 4 of ASME ection V.

(b)

FPQ.-PNS staff determined that SA-533 Grade A is comparable.to SA-516 Grade 70 (piping material),

as provided by ASME Section XI, Appendix III, Section III-3411(c).

(2)

Calibration Bl ock:

UT-6 Applications:

Primary Coolant Piping, Cold Legs Code Deviation:

The block is flat; ASNE Section XI, Appendix III requires the same nominal diameter.

Justifi cation:

(a)

The block material is identical to the coolant piping material; therefore, it is preferred over a curved block of a different material.

(b)

Article 5 of ASNE Section V allows flat blocks for items greater than 20-in. diameter, as does Article 4 of ASME Section V.

(c)

With a half Vee-examination technique, curvature is not a

major source of error.

Sound path calibration is used with full-scale plotting of indications.

(3)

Cal ibrati on Block:

UT-45 P

Appl ication:

Main St'earn Piping Welds Code Deviation:

The subject piping welds are of two sizes:

(a) 34-in. diameter, 1.250 in. wall (b) 36.625-in. diameter, 1.234>>in. wall (two welds only).

The requirements of ASME Section XI Appendix III are such that two blocks, one of each diameter, would be required.

FPQ -PNS staff opts to use one block (34-in. x 1.250-in.)

to examine both pipe sizes.

tustification:

'a)

The wall thickness is essentially the same, therefor e so is the sensitivity.

(b)

The small difference in diameters is not ultrasonically-noticable.

By permitting flat blocks for applications over 20 in.,

ASME Section V, Articles 4 and 5 recognize this.

51

~ s

~

~

(c)

The smaller diameter of the two was chosen since it would yield a slightly more sensitive examination on the larger diameter pipe.

(4)

Calibration Block:

UT-4, UT-5 Appl ication(s):

Reactor Pressure Yessel Code Deviation:

The 3/4 T straight beam hole is too close (UT-4, l-l/4 in.; UT-5, 3/4 in.) to the end of the block.

This satisfies the requirements of the Code to which they were fabri cated.

Justification:

The blocks posed no problem during examination calibration, therefore, they were used as-is.

A pending Code case addresses this subject and will allow alternative con-figurations provided the same results are achieved and/or the placement of the reflector does not interfere with the calibration.

Evaluation

/

Technical evaluation of the proposed calibration blocks prior to the preservice examination indicated that examination effective-ness would not be reduced by use of the proposed calibration blocks.

An important feature of the overall ISI program is that the preservice inspection serves as a baseline by which inservice examination results are evaluated.

Accordingly, it is'ppropriate to use methods during inservice inspection which are consistent with preservice inspection methods provided the preservice methods were technical ly acceptable.

Conclusions and Recommendations Based on the above evaluation, it is concluded that for the methods discussed

above, adherence to the Code requirements is impractical.

It is further concluded that the pr oposed methods will pr ovide necessary assurance of structural reliability during this interval.

Therefore, relief is recommended as requested.

Ref erences References 5 and 9.

52

3.6 REFERENCES

2.

3.

4.

5.

6.

7.

8.

9.

. 10.

Safety Evaluation Report related to the operation of St. Lucie Plant, Unit No. 2, NUREG-0843, U.S.

Nuclear Regulatory Commission, October 1981.

R.

E. Uhrig, (FPL) to D; G. Eisenhut (NRC), L-82-491, November 10, 1982; Relief requests on St. Lucie 2 PSI.

R.

E. Uhrig (FPL) to D.

G. Eisenhut (NRC), L-83-17, January 14, 1983; Commitment to perform ISI of low pressure turbine aiscs.

Safety Evaluation Report related to the operation of St. Lucie Plant, Unit No. 2, NUREG-0843, Supplement No. 3, U.S.

Nuclear Regulatory Commission, April 1983.

R. E. Uhrig (FPL) to D.

G. Eisenhut (NRC), L-83-510, October 6, 1983; ISI Program Volumes I and II attached.

J.

R. Miller (NRC) to J.

W. Williams, Jr.

(FPL), September 14, 1984; Request for additional information.

J.

M. Williams, Jr.

(FPL) to J.

R. Miller (NRC), L-84-287, October 25, 1984; Preliminary response to the request for additional information.

J.

W. Williams, Jr.

(FPL) to J.

R. Niller (NRC), L-84-340, November 19, 1984;

Response

to the request for additional information.

J.

W. Williams, Jr.

(FPL) to E. J.

Butcher (NRC), L-85-259, July 5, 1985; Revision 1 of ISI Program.

J.

W. Milliams, Jr.,(FPL) to D.

G. Eisenhut (NRC), L-84-333, November 20, 1984; Resolution of license conditions.

11.

EP0-84-0903, FPL Letter, Nay ll, 1984; Stress analysis.

12.

L-CE-10432, C-E Letter, June ll, 1984; Stress analysis.

53