Text

TER on Second 10-Yr Interval ISI Program Plan:Fpl,St Lucie Nuclear Plant,Unit 2
	ML20138E635
Person / Time
Site:	Saint Lucie
Issue date:	03/31/1995
From:	Beth Brown, Feige E, Hall K; IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	; NRC (Affiliation Not Assigned)
Shared Package
ML20136C539	List: IR 05000335/1994009; IR 05000335/1996002; L-96-227, Forwards LER 96-S01 Re Tampering W/Key Switches on Hot Shutdown Control Panels; ML20136D791; ML20136D826; ML20136E630; ML20136F193; ML20136F567; ML20136F583; ML20136G294; ML20137D421; ML20137D508; ML20137D737; ML20137D744; ML20138E042; ML20138E053; ML20138E195; ML20138E272; ML20138E355; ML20138E360; ML20138E409; ML20138E415; ML20138E422; ML20138E494; ML20138E500; ML20138E569; ML20138E635; ML20138E692; ML20138E708; ML20138E737; ML20138E766; ML20138E807; ML20138E836; ML20138E843; ML20138E879; ML20138E923; ML20138E937; ML20138F111; ML20138F363; ML20138F370;
References
	CON-FIN-L-2556, FOIA-96-485 INEL-94-0147, INEL-94-147, NUDOCS 9504040254
	Download: ML20138E635 (61)
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INEL-94/0147 l,

March 1995 1

i Idaho National l

Engineering Technical Evaluation Report on the j

Laboratory Second 10-year Interval inservice Inspection Program Plan:

l Florida Power and Light Company, i

St. Lucie Nuclear Plant, Unit 2, Docket Number 50-389 i

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i B. W. Brown 1}

E. J. Feige K. W. Hall i

A. M. Porter l,

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MLockheed l

Idaho Technologies Company

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1 INEL 94/0147 Technical Evaluation Report on the Second 10-year interval inservice inspection Program Plan:

Florida Power and Light Company, St. Lucie Nuclear Plant, Unit 2, Docket Number 50-389 B. W. Brown i

E. J. Feige K. W. Hall A. M. Porter Published March 1995 Idaho National Engineering Laboratory Materials Physics Lockheed Idaho Technologies Company Idaho Falls, Idaho 83415 Prepared for the i

Division of Engineering Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Idaho Operations Office Contract DE-AC07 941013223 FIN No. L2556 (Task Order 20) i

i ABSTRACT

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This report presents the results of the evaluation of the St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval inservice Inspection Program Plan, Revision 0, submitted August 4, 1993, including the requests for relief from the American Society of Mechanical Engineers (ASME) Boiler. and Pressure Vessel Code,Section XI, requirements that the licensee has determined to be impractical. The St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval Inservice Inspectfon Program Plan is evaluated in Section 2 of this report.

The ISI Program Plan is evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability of the examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI-related commitments identified during previous Nuclear Regulatory Commission (NRC) reviews. The requests for relief are evaluated in Section 3 of this report.

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This work was funded under:

U.S. Nuclear Regulatory Commission FIN No. L2556, Task Order 20 Technical Assistance in Support of the NRC Inservice Inspection Program iii

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SUMMARY

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The licensee, Florida Power and Light, has prepared the St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval Inservice Inspection Program Plan, Revision 0, to meet the requirements of the 1989 Edition. The second 10-year j

interval began August 8, 1993.

i The information in the St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval Inservice Inspection Program Plan, Revision 0, submitted August 4, 1993, was reviewed.

Incirc ' in the review were the requests for relief from j

the ASME Code Section XI re..irements that the licensee has determined to be impractical. As a result of this review, a Request for Additional Information (RAI) was prepared describing the information and/or clarification required from the licensee in order to complete the review.

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The licensee responded to the RAI in a submittal dated August 22, 1994; included in this submittal were revisions to Relief Requests 1, 5, 14, and 17.

4 Based on the review of the St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval Inservice Inspection Program Plan, the licensee's responses to the-Nuclear Regulatory Commission's RAI, and the recommendations for granting relief from the inservice inspection (ISI) examinations that cannot be performed to the extent required by Section XI of the ASME Code, no deviations from regulatory requirements or commitments were identified in the St. Lucie l

Nuclear Plant, Unit 2, Second 10-Year Interval Inservice Inspection Program Plan, with the exception of Requests for Relief 14 and 16.

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4 CONTENTS i

ABSTRACT ii

SUMMARY

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INTRODUCTION I

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EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN...........

4 2.1 Documents Evaluated 4

2.2 Compliance with Code Requirements................

4 2.2.1 Compliance with Applicable Code Editions..........

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2.2.2 Acceptability of the Examination Sample 4

2.2.3 Exemption Criteria.....................

5 2.2.4 Augmented Examination Commitments 5

2.3 Conclusions...........................

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EVALUATION OF RELIEF REQUESTS....................

8 3.1 Class 1 Components 8

3.1.1 Reactor Pressure Vessel 8

3.1.1.1 Request for Relief 1, Examination Category B-A, Items 81.11, Bl.12, Bl.21, Bl.22 Bl.30, and B1.40, Pressure Retaining Welds in the Reactor Pressure Vessel, Examination Category B-D, Item B3.90, Full Penetration Nozzle Welds in the Reactor Pressure vessel 8

3.1.1.2 Request for Relief 17, Examination Category B-D, Items 83.90 and B3.100, Examination Scheduling Requirements of Reactor Pressure Vessel Nozzle-to-Vessel Welds and Inner Radius Sections 12 3.1.2 Pressurizer 14 3.1.2.1 Request for Relief 3, Examination Category B-D, Item B3.110, Full Penetration Nozzle-to-Vessel Welds in the Pressurizer 14 3.1.3 Heat Exchangers and Steam Generators (No Relief Requests) 1 v

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l 3.1.4 Piping Pressure Boundary...................

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3.1.4.1 Request for Relief 4 (Part 1 of 2), Examination Category B-J, Items 89.12 and B9.22 Examination of-Class 1 Longitudinal Piping Welds...........-

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3.1.4.2. Request for' Relief 5, Examinatial Categories B-F, Item No. 85.130 and Examination Lategory B-J, Item No. 89.11,. Examination of Class.l. Pressure Retaining Dissimilar Metal Welds 20 j

i 3.1.4.3 Request for Relief 6, Examination Category B-J, Items 89.11, B9.12, and 89.31, Examination of Class 1 Pressure Retaining Welds in Piping 23 i

3.1.4.4 Request for Relief 15, Category B-J, Item B9.11 Examination of Inlet and Outlet Nozzle tc Pipe Transition Welds 26 3.1.5 Pump Pressure Boundary (No Relief Requests) 3.1.6 Valve Pressure Boundary:{No Relief Requests) 3.1.7' General (No Relief Requests) 3.2= Class 2 Components 29-3.2.1 Pressure Vessels......................

29 3.2.1.1 Request for Relief 8, Examination Category C-A, Item C1.10 Examination of Class 2 Shutdown Heat Exchanger Shell Welds..................

29 3.2.1.2 Request for Relief 9 Examination Category C-B, Item C2.21. Examination of Class 2 Steam Generator Nozzle-to-Vessel Welds 30 3.2.2 Piping............................

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3.2.2.1 Request for Relief 4 (Part 2 of 2), Examination Categories C-F-1 and C-F-2, Items C5.12, C5.22, C5.42, C5.52, C5.62, and C5.82, Examination of Class 2 Longitudinal Piping Welds............

32 3.2.2.2 Rn :est for Relief 10, Examination Categories C-F-1 and C-F-2, Items C5.11 and C5.81,' Examination of Class 2 Pressure Welds in Piping 35 j-3.2.3 Pumps ( No Relief Requests) 3.2.4 Valves (No Relief Requests)

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3.2.5 General 37 I

3.2.5.1 Request for Relief 14, IWB-2412 and IWu-2412, Inspection Program B Percentage Requirements, i

IWB-2420 and IWC-2420, Sequence of Component Examinations ' Established During the First Inspection Interval 37 3.2.5.2 Request for Relief 16, Paragrapl. IWA-6620, Preparation of Owner's Reports, Forms NIS-1 and NIS-2, and submittal of 90-day Summary Report.....

43 3.3 Class 3 Components (No Relief Requests) 3.4 Pressure Tests (No Relief Requests) 3.5 General.............................

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1 3.5.1 Ultrasonic Examination Techniques 46 3.5.1.1 Request for Relief 13, Appendix III Requirements Ultrasonic Calibration Blocks.........,...

46 3.5.2 Exempted Components (No Relief Requests) 3.5.3 Other (No Relief Requests) 4.

CONCLUSION 49 5.

REFERENCES 50

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TECHNICAL EVALUATION REPORT ON THE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAN PLAN FLORIDA POWER AND LIGHT CONPANY I

ST. LUCIE NUCLEAR PLANT, UNIT 2 DOCKET NUNBER 50-311 k

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INTRODUCTION Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) (Reference 1) requires that components (including supports) that are classified as American Society of Mechanical Engineers l

(ASME) Boiler and Pressure Yessel Code Class 1, Class 2, and Class 3 meet the l!

requirements, except the design and access provisions and the preservice f

examination requirements, set forth in the ASME Code Section XI, Rules for i

Inservice Inspection of Nuclear Power Plant Components (Reference 2), to the t

extent practical within the limitations of design, geometry, and materials of l

1 construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during successive 120-month inspection intervals shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Nuclear Regulatory Commission (NRC) approval.

The licensee, Florida Power and Light (FPL) Company, has prepared the St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval inservice Inspection Progrer Plan, Revision 0 (Reference 3), to meet the requirements of the 1989 Edition of the Code. Th'e second 10-year interval began August 8,1993 and ends August 8, 2003.

As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief from them, the licensee shall submit information and justification to the NRC to support that determination.

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Pursuant to 10 CFR 50.55a(g)(6), the NRC will evaluate the licensee's determination that Code requirements are impractical to implement.

The NRC may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Alternatively, pursuant to 10 CFR 50.55a(a)(3), the NRC will evaluate the licensee's determination that either (i) the proposed alternatives provide an acceptable level of quality and safety, or (ii) Code compliance would result in hardship or unusual difficulty without a compensating increase in safety.

Proposed alternatives may be used when authorized by the NRC.

The information in the St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval ISI Program Plan, Revision 0, submitted August 4, 1993, was reviewed, including the requests for relief from.he ASME Code Section XI requirements c

that the licensee has determined to be impractical. The review of the ISI Program Plan was performed using the Standard Review Plans of NUREG-0800 (Reference 4), Section 5.2.4, " Reactor Coolant Boundary Inservice Inspections and Testing," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components."

In a lette dated June 17,1994 (Reference 5), the NRC requested additional information (RAI) that was required in order to complete the review of the ISI Program Plan.

The requested information was provided by the licensee in an August 22, 1994 submittal (Reference 6). This response included the following:

a. Clarification of the e" tant of augmented examinations being performed;

b. A position on the examinations associated with the steam generator support skirt-to-stay basc;

c. A position with regard to the examination of Class 2 piping welds excluded from examination based on wall thickness; and 2

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d. Revisions to Requests for Relief 1, 5,14, and 17.

The St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval ISI Program Plan, Revision 0, is evaluated in Section 2 of this report. The ISI Program Plan is evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI-related commitments identified during the NRC's previous reviews.

The requests for relief are evaluated in Section 3 of this rerort. Unless otherwise stated, references to the Code refer to the ASME Code,Section XI, 1989 Edition. Specific inservice test (IST) programs for pumps and valves are being evaluated in other reports.

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EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN l

This evaluation consists of a review of the applicable program documents to determine whether or not they are in compliance with the Code requirements and any previous license conditions pertinent to ISI activities. This section describes the submittals reviewed and the results of the review.

2.1 Documents Evaluated Review has been completed on the following information from the licensee:

(a) St. Lucie Nuclear Plant, Unit No. 2, Second 10-Year Interval Inservice Inspection Program Plan, Revision 0, submitted August 4, 1993 (Reference 3).

(b) Response to Request for Additional Information, Second 10-Year Interval Inservice Inspection Program Plan, submitted August 22, 1994 (Reference 6).

2.2 Comoliance with Code Reauirements j

2.2.1 Comoliance with Aeolicable. Code Editions The inservice inspection program plan shall be based on the Code editions defined in 10 CFR 50.55a(g)(4) and 10 CFR 50.55a(b).

Based on the starting date of August 8,1993, the Code applicable to the second interval ISI program is the 1989 Edition. As stated in Section 1 of this report, the licensee has prepared the St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval ISI Program Plan, Revision 0, to meet the requirements of 1989 Edition.

2.2.2 Acceptability of the Examination Samole Inservice volumetric, surface, and visual examinations shall be performed on ASME Code Class 1, 2, and 3 components and their supports using sampling schedules described in Section XI of the ASME Code and 10 CFR 50.55a(b). The sample size and weld selection have been 4

implemented in accordance with the Code and 10 CFR 50.55a(b) and appear to be correct except as noted below.

For Class 2 piping welds, it was recomended in the RAI (Reference 5),

that the licensee augment the Class 2 piping weld examinations of the Residual Heat Removal, Emergency Core Cooling, and Containment Haat Removal Systems by volumetric examination of a sample of welds excluded from selection based on wall thickness.

In the response to the RAI (Reference 6), the licensee took the position that additional examinations are not warranted. The INEL staff maintains that due to the safety significance of the subject systems, it is recomended that the ISI program include volumetric examination of a sample of thin-wall pipe welds in portions of the subject systems that are otherwise excluded from examination.

2.2.3 Exemotion Criteria The criteria used to exempt components from examination shall be consistent with Paragraphs IWB-1220, IWC-1220, IWC-1230, IWD-1220, and-10 CFR 50.55a(b). The exemption criteria have been applied by the licensee in accordance with the Code, as discussed in the ISI Program Plan, and appear to be correct.

2.2.4 Auamented Examination Comitments In addition to the examinations specified in Section XI of the ASME Code, the licensee has comitted to perform the following augmented examinations:

(a) Volu' metric and surface examination of the Reactor Coolant Pm Flywheels in accordance with Regulatory Guide 1.14 (Reference 7);

i (b) Reactor pressure vessel examinations, including the closure head, in accordance with Regulatory Guide 1.150, Rev.1 (Reference 8);

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(c) VT-3 visual examination of the pressurizer surge line for. general mechanical and structural conditions in response to NRC Bulletin 88-11 (Reference 9);

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(d) Per LER 50-389-93-04, FPL committed to perform visual (VT-1) examinations of the Alloy 600 instrumentation nozzles during the second inspection intervai for. evidence of leakage; (e) Feedwater nozzle examinations.per NRC Bulletin.79-13 i

(Reference.10). Continuous enhanced ultrasonic examinations starting at the Feedwater Nozzle ramp and extending out to a j.

distance of one diameter on the elbow will be performed in conjunction with the Code examination schedule; and (f) Augmented examinations, based on Branch Technical Position MEB 3-1, High Energy Fluid Systems, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment, on weids that fa11 within the following criteria:

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Code Category C-F welds beyond the Code class boundary (MSIV) to the first restraint providing at least two degrees of restraint to piping thermal' expansion; 2.

Pipe-to-pipe welds and longitudinal weld seams beyond the Code class boundary (MSIV) to the first restraint providing at least two degrees of restraint to piping thermal expansion; 3.

Welds selected for examination as defined in the 1989 Edition of Section XI; and 4.

Circumferential and intersecting longitudinal welds in high energy fluid system piping between con'.ainment isolation valves (100% volumetric examination).

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2.3 Conclusions

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Based on this review of the St. Lucie Nuclear Plant, Unit'2, Second k

10-Year Interval ISI Program Plan, Revision 0, no deviations from j

regulatory requirements or commitments have been identified (relief i

1 requests are reviewed in the next section). However, for Class 2 piping welds, it is recommended that the licensee augment the examination of 1

the Residual Heat Removal, Emergency Core Cool'-', and Containment Heat Removal Systems by volumetric examination of sample of welds excluded from selection based on wall thickness.

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EVALUATION OF RELIEF REQUESTS 4

The requests for relief from the ASME Code Section XI requirements that the licensee has determined to be impractical for the second 10-year inspection interval are evaluated in the following sections.

3.1 Class 1 Components 3.1.1 Reactor Pressure Vessel i

4 3.1.1.1 Recuest for Relief 1. Examination Cateaory B-A. Items 81.11.

Bl.12. B1.21. Bl.22. 81.30. and 81.40. Pressure-Retainino Welds in the Reactor Pressure Vessel. Examination Cateaory B-0.

Item 83.90. Full Penetration Nozzle Welds in the Reactor Pressure 2

Vessel Code Reauirement: Section XI, Table IWB-2500-1, Examination Category B-A, Items Bl.11 and 81.12 require that essentially 100%

i of all circumferential and longitudinal reactor pressure vessel shell welds be volumetrically examined as defined in Figures IWB-2500-2 and IWB-2500-2. Items B1.21 and B1.22 require that essentially 100% of the accessible length of all reactor pressure vessel circumferential and meridional head welds be volumetrically examined as defined in Figure IWB-2500-3.

Item B1.30 requires that essentially 100% of the reactor pressure vessel shell-to-flange weld be volumetrically examined as defined in Figure IWB-2500-4.

Item Bl.40 requires that esse,tially 100%

of the head-to-flange weld be volumetrically examined as defined in Figure IWB-2500-5.

Examination Category B-D, Item B3.90 requires the examination of all nozzle-to-vessel welds as defined in Figure IWB-2500-7.

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-il ticensee's Code Relief Reauest: The licensee requested relief l

from the Code-required 100% volumetric r. overage of the following f

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welds:

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[Examina,tionArea Co e age' '. Description of_ Limitations 4

i Bottom Head Peel Limited along length of i !

Segment Weld:

weld near flow skirt-lower

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-101-154A 65%

head attachment 101-154B 64%

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101-154C 66%

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101-1540 64%

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101-154E 66%

l4 101-154F 64%

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Lower Shell-to-88%

Limited along length of j

Intermediate Shell weld near the vessel i j Cire. Weld 101-171 surveillance capsules Intermediate Shell 81%

Limited along' length of I

3 Long. Weld 101-124C weld near the vessel I

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Upper Shell 87%

Limited at intersection

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Longitudinal Weld with the adjacent outlet 101-122A nozzle integral extension 4

i Upper Shell-to-Flange 67%

Limited above the weld by F'

Circumferential Weld the flange configuration 101-121 in Outlet Nozzle-to-28%

Shell-side examination is i

Shell Weld 105-121A limited by.the integral i

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Outlet Nozzle-to-28%

Shell-side examination is Shell Weld 103-1218 limited by the integral extension f

Flange to Torus Weld 75%

Limited at intersection of 101-101 flange flex radius, shroud, shroud hold down lug:, and head lifting lugs 4

Dome Weld'102-101 46%

Limited by location of J

shroud and at intersection

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of adjacent Weld 101-101 and shroud 9

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I Licensee's Basis for Reauestino Relief (as stated):

"1. 10 CFR 50.55a(g)(4), recognizes that throughout the service life of a nuclear power facility, components which are classified as ASME Code Class 1 shall meet the requirements, except design and access provisions requirements, set forth in Section XI, to the extent practical within the limitations of design, geometry and materials of construction of the components.

"2. NDE procedures implemented during the St. Lucie Unit 2 RPV examinations required full vee path calibration of the 45' shear wave scans to compensate for limitations encountered in the near surface and those due to geometric shadowing. Those examination volumes which receive other than 90% of the ASME i

Code required coverage are identified within this Request for i

Relief. It should be noted that electronic gating does not result in any examination limitations since the entire instrument screen presentation is monitored during the examinations, video taped, and reviewed independently following the examinations.

" Described below, coupled with the Tables and Figures, details of the examination limitations by weld description.

The accompanying Figures' graphically depict the locations and extents of the limitations with respect to weld metal and associated base material. The Table quantifies the limitations in terms of present code required volume which is effectively covered."

"RPV LOWER HEAD MERIDIONAL WELDS

" Mechanized scanning of the Lower Head Meridional welds 101-154A through F is limited due to interference from the core support lugs and flow skirt. Figure 1.1 is a roll out inside view showing inside surface scan limitations. Figure 1.2 provides a side section view of peel segment welds showing limitations caused by core support lugs and flow skirt support.

Figure 1.3 provides a graphic view of a typical meridional weld showing transverse scan limitations in the area behind the flow skirt."

"RPV CIRCUMFERENTIAL SHELL WELDS

" Examination of the Middle Shell-to-Lower Shell weld 101-171 is limited due to interference from the surveillance specimens.

Figure 1.1 is a roll out view of weld 101-171 depicting areas where parallel examination scans can not be performed.

"The Upper Shell-to-Flange weld 101-121 is examined from the shell side and from the flange seal surface. Beams directed nearly perpendicular to the weld plane from the flange seal

' Figures, tables, and attachments are not included with this evaluation.

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surface compensated for the straight beam and angle beam examination limitations on the flange side of the weld. Due to the flange configuration, no transverse examination scans can be performed on the flange side of the weld.

Figure 1.6 shows the limitations to the shell side path scans.

Figure 1.6 shows the limitations to the shell side examination and depicts the

,t-coverage obtainable from the seal surface examination. Also shown is the tapered surface where transverse examination is prohibited."

"RPV LONGITUDINAL SHELL WELDS "The 60" examination of weld 101-124C is limited by interference from the surveillance capsules as shown on Figure 1.1.

" Examination of the Upper Shell Vertical welds 101-122A, is limited by interference from the outlet nozzle integral extension as shown on Figure 1.1.

However, the examinations are complemented by the Nozzle-to-Shell weld examinations."

"RPV N0ZZLE TO SHELL WELD "The inlet and outlet Nozzle-to-Shell welds are examined from the shell side and from the nozzle bore. The Nozzle Bore examinations 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.

Limitations to the Inlet Nozzle examinations are shown on Figure 1.7 and limitations to the Outlet nozzle examinations are shown on Figure 1.8."

"RPV CLOSURE HEAD "The closure Head-to-Flange weld 101-101 is examined from one side due to flange.

Figure 1.10 provides the scan path for this weld.

I "The Closure Head Dome weld 102-101 is limited due t'o instrument nozzles, penetrations, and CEDM's, see Figure 1.13.

"The extent of examination volume achieved ultrasonically and the alternate scans performed (see Examination Coverage Table) coupled with the s:/ stem pressure tests provide assurance of an acceptable level of quality and safety."

Licensee's Proposed Alternative Examination (as stated):

"l) Periodic System Pressure tests per Category B-P, Table IWB-2500-1 "2) Inservice Hydrostatic tests per Table IWB-2500-1 11 4

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-l "3) Conduct Mechanized Ultrasonic Examinations to the extent practical.

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"4) 50/70* Bi-modal ultrasonic examination of the inner 25 percent."

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Evaluation: The Code requires that all RPV shell welds and the accessible length of RPV head welds receive essentially 100%

volumetric examination. The scan path sketches show that examinations of the subject welds are limited by physical obstructions that restrict scanning, making it impractical to i

perform the examinat' ions to the extent required by the Code. To j

j obtain complete volumetric coverage, design modifications or 1

j replacement,of the components with those of a design providing for complete coverage would be necessary.

Imposition of this

-requirement would cause a considerable burden on the licensee.

The licensee performed the volumetric examinations to the extent practical. Based on the percent of coverage obtained, in conjunction with the proposed alternatives, it is reasonable to conclude that degradation, if present, would be detected. As a 1

result, reasonable assurance of operational readiness has been provided.

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Conclusions:==

Based on the above, it is concluded that complete

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volumetric examination is impractical to perform. Therefore, pursuant to 10 CFR 50.55s(g)(6)(i), it is recommended that relief i

be granted as requested.

I 3.1.1.2 Raouest for Relief 17. Examination Cateaory B-D. Items 83.90 and i

B3.100. Examination Schedulina Reouirements of Reactor Pressure Vessel Nozzle-to-Vessel Welds and Inner Radius Sections Code Reauirement: Section XI, Table IWB-2500-1, Examination Category B-D, Items B3.90 and B3.100 require that for reactor pressure vessel nozzle welds and inner radius sections, at least 25% but not more than 50% (credited) of the nozzles shall be 12

l examined by the end of the first inspection period and the I

i remainder by the end of the inspection interval.

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Licensee's Code Relief Reauest: The licensee. requested relief l

from the Code requirement to examine at least 25% of the ves'sel-to-nozzle welds during the first examination period, a

Licensee's Basis for Reauestina Relief (as stated):

"During the First 10 Year interval the vessel-to-nozzle and nozzle inner radius sections, that were examined during the first a

period, as identified above, were reexamined during the second period, in conjunction with the automated Reactor Pressure vessel examinations.

"The intent of the ASME Code is to assure the structural integrity of safety related components. This is accomplished by performing nondestructive examination, as required by Table IWB-2500-1, over the extent of a specific inspection interval.

" Performance of the examination requirements in the first and third inspection periods provides an undue cost burden.

Performance of 25% to 50% code examinations requirements, as specified in the Code, by the automated examination technique, cost in excess of $300,000.00 to $400,000.00 dollars more than performance of the entire vessel examinations of $700,000.00.

"FPL, during.the first 10. Year Interval, performed a reexamination of the 25% to 50% code examinations, in conjunction with the remaining vessel examinations, in order to establish an examination interval consistent with the entire Reactor Vessel requirements.

"FPL believes that since these welds will still be examined at 10 year intervals, an acceptable level of quality and safety is assured."

Licensee's Proposed Alternative Examination (as stated)-

" Conduct 100% Nozzle-to-Vessel Examinations during Second

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Examination Period, in conjunction with the remaining Reactor J

Vessel examinations."

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i Evaluation: The Code requires that at least 25% 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.

Imposing this requirement on the licensec results in the requirement to employ a automated 13

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,-.-.-_--r-my <

i.

I I'

s l

examination device two times in one interval.

It has been previously determined that, for Examination Category B-D, l

deferral of the first period examinations is acceptable provided

'that these examinations are completed within the same period in 4

which the preceding examinations were performed, or earlier, so

)

that there is no more than 10 years between examinations.

The proposed alternative schedule for Examination Category B-D, Items 83.90 and 83.100, in the second period of the second 10-j year interval, provides an acceptable level of quality and safety because the required examinations will be completed within the same period in which the preceding examinations were performed.

Therefore, the proposed alternative schedule should be authorized.

i

==

Conclusion:==

The INEL staff has reviewed the licensee's request for relief from Code scheduling requirements.

It is concluded j

that the proposed alternative schedule provides an acceptable I

t level of quality and safety. Therefore, pursuant to

)

10 CFR 50.55a(a)(3)(i), with the provision as noted above, it is recommended that the proposed alternative be authorized.

3.1.2 Pressurizer 3.1.2.1 Reauest for Relief 3. Examination Cateaory B-D. Item B3.110. Full Penetration Nozzle-to-Vessel Welds in the Pressurizer Code Reauirement: Examination Category B-D, Item B3.110 requires 100% volumetric examination of all pressurizer nozzle-to-vessel welds as defined in Figure IWB-2500-7 (as applicable).

Licensee's Code Relief Reauest: The licensee requested relief from the Code-required 100% coverage of the following nozzle-to-vessel welds.

14 1

u 4

Iden tion.

Coveragel(%).

l Description of Limitations Spray Nozzle-70% One Side Proximity of other nozzles to-Upper Head that are directly opposite on j

Weld 103-601 scan line Safety Valve 80% One Side Proximity of other nozzles Nozzle-to-Upper (60* Angle),

that are directly opposite on Head Weld.

95% One Side scan line 108-601-A (45' Angle)

Safety Valve 70% One Side Iroximity of other nozzles Nozzle-to-Upper (60* Angle),

that are directly opposite on 4-Head Weld 85% Sne Side scan line 108-601-8 (45 Angle)

Safety Valve 70% One Side Proximity of other nozzles

' Nozzle-to-Upper (60' Angle),

that are directly opposite on Head Weld 95% One Side scan line 108-601-C (45' Angle)

Safety Valve 80% One Side Proximity of other nozzles Nozzle-to-Upper that are directly opposite on Head Weld scan line 108-601-D Surge Nozzle 60% One Side Proximity of ten Heater Wald 105-651 (60' Angle),

attachments 100% One Side (45' Angle)

Licensee's Basis for Reauestino Relief (as stated):

" Configuration and permanent attachments prohibit 100% ultrasonic examination of the required volume. Additional ultrasonic techniques are employed where practical, to achieve the Code Required Volume.

"N0ZZLE - TOP OF PRESSURIZER "Due to the close proximity of Pressurizer Nozzle orientation, as identified in Figures 1 and 2 attached', the ultrasonic scan distance of 8.0" for 45*, and 12" for 60' can not be accomplished.

" PRESSURIZER SURGE N0ZZLE

" Figure 3 identifies the 60' angle beam scan limitations affecting the examination, due to 10 Pressurizer Heater Penetrations.

"The extent of examination volume achieved ultrasonically and the alternate scans performed (see Examination Coverage Table) coupled

' Figures, tables, and attachments are not included in this report.

15

]

~

A I

with the system pressure tests provide assurance of an acceptable q,

level of quality and safety."

Licensee's Alternative Examination (as stated):

3 ji "1) Periodic System Pressure tests.

"2) Conduct Ultrasonic Examinations to the extent practical."

l Evaluation:

The Code requires that all pressurizer nozzle-to-shell

[

l welds be 100% volumetrically examined. The sketches provided show l

that the subject nozzle welds have limited scan areas.as the result i

I

of physical obstructions (i.e. adjacent nozzles and heater j

attachments). Therefore, it is impractical to examine the i

pressurizer nozzle welds at St.'Lucie to the extent required by the Code. To obtain complete volumetric coverage, design modifications or replacement of the pressurizer with cne of a design providing for i

complete coverage would be required.

Imposition of this requirement would cause a considerable burden on the licensee.

The licensee performed the volumetric examination of the subject pressurizer nozzle welds to the extent practical obtaining one-sided j

j coverages ranging from 60% to 100% coverage.

Based on the. coverage

]

i obtained,'it is reasonable to conclude that degradation, if present, would be detected. As a result, reasonable assurance of structural l

integrity is provided.

l

==

Conclusions:==

Because of scanning limitations, complete volumetric examination of the pressurizer nozzle welds at St. Lucie is impractical to perform. Therefore, pursuant to 10 CFR 50.55a(g)(6)(1), it is recommended that relief be granted as l

requested.

5 i

}

l 16 i

. _. ~... _ - _ _.

f 3

[..

3.1.3 Heat Ei:hanaers and Steam Generators (No relief requests) f 1

3.1.4 Pinina Pressure Boundary j

I 1!

3.1.4.1 Reauest for Relief Number 4 (Part 1 of 21. Examination Cateaory l

B-J. Items B9'.12 and B9.22. Examination of Class 1 Lonaitudinal l

Pinina Welds 1

Code Reauirement: Examination Category B-J,. Item B9.12 requires 100% volumetric and surface examination of Class I longitudinal

.)

piping welds 24 inch NPS. The examination area shall include at least a pipe-diameter length but not more than 12 inches of each longitudinal weld intersecting the circumferential welds required i

to be examined by Examination Categories B-F and B-J.

)

l Item B9.22 requires a 100% surface examination of the l

longitudinal piping welds <4 inch NPS. The examination area j

shall include at least a pipe-diameter length'but not more than I

12 inches of each longitudinal weld intersecting the i

circumferential welds required to be examined by Examination Categories B-F and B-J.

l Licensee's Code Relief Reauest: The licensee requested relief from performing the Code-required surface and/or volumetric examinations of all Class I piping longitudint! welds to the extent required by Code.

Licensee's Basis for Reauestina Relief (as stated):

"1. Longitudinal welds are fabricated during original manufacturing under controlled shop conditions, which produce higher quality and more uniform residual stress patterns.

j!

"2. Longitudinal piping welds undergo heat treatment in the shop, which enhances the material properties of the weld and reduces the residual stresses created by welding.

"3. For Austenitic stainless steel piping, the intergranular stress corrosion cracking (IGSCC) problem, or for that matter any stress corrosion problem, has not occurred to any 17 zi

i.!

d

significant extent in PWR piping, due to the nonoxygenated environment, nor to carbon steel piping in PWR's.

1 "4. Results of previous weld inspections.through out the industry 3

indicates that longitudinal welds have not been a safety concern, nor has there been any evidence of longitudinal weld i3 defects compromising safety at nuclear power plants.

i 4

"5. Longitudinal welds have not been shown to be susceptible to any particular degradation mechanism.

"6. The only areas of a longitudinal weld which may be considered l.

suspect are-the ends of the weld where it is adjacent to the i

field fabricated circumferential welds. These areas fall l

within the volumetric examination boundaries of the adjacent i

circumferential welds.

t' i

"7. The man-rem exposure and cost associated with the inspection i

of longitudinal welds is dependent on the time it would take to remove / reinstall insulation and interferences, locate the weld, prepare the weld for examination and perform the examination.

"The volumetric and surface examination costs and man-rem for the selected Class 1 and Class 2 longitudinal welds are estimated to cost $34,496, and 25 man-rem for the second inspection interval.

"8. Based on the above arguments, there is little, if any, technical benefit to performing inservice inspections on longitudinal piping welds.

In addition, there are substantial radiatio.xposure and cost considerations 4

associated with ther.,nspections."

Licensee's Alternative Examination (as stated):

"FPL proposes to eliminate the examination requirements for

~

surface examination on Class 1 and 2 longitudinal piping welds j

4 beyond those inspections which are required for the adjacent i

circumferential weld.-

l i

1 "FPL also proposes to enhance the volumetric examinations at the intersection point of circumferential and longitudinal welds by including both transverse and parallel scans within the length of longitudinal weld which falls within the circumferential weld.

examination volume.

l "Circumferential welds with intersecting longitudinal welds will i

be noted to document the extent of the examination.

"The extent of volumetric examinations performed coupled with the system pressure tests provides assurance of an acceptable level i

of quality and safety."

I 18

a l

6 i

Evaluation: The Code requires surface and/or volumetric l,

examination of at least a pipe diameter length but not more than t

l; 12 inches of each longitudinal weld intersecting the i,

circumferential welds required to be examined by Examination Categories'B-F and B-J.

In the response to the NRC's RAI, the 1

licensee stated that the request for relief includes both surface and volumetric examination of the length of longitudinal weld to-l ;.

the extent required by Code. As an alternative, the licensee

{.

proposed to examine a portion of the. required length of each longitudinal weld in conjunction _with the associated j'

circumferential weld..The proposed alternative is based on'the position that longitudinal welds are unlikely to fail; the low probability of failure is attributed to fabrication controls and lack of susceptibility to conditions that lead to failure.

Additional radiation exposures would be incurred by performance l

of the surface examinations. The licensee maintains that the i

potentially critical portion of the longitudinal welds, the I

portion that intersects the circumferential weld, will be j.

examined in conjunction with the circumferential welds.

The licensee's proposed alternative is to enhance the volumetric f

examinations of that length of longitudinal weld that falls j

within the circumferential weld examination volume by performing both transverse and parallel scans. The circumferential welds l

with intersecting longitudinal welds will be noted to document fi the extent of the examination. The extent of surface and l

volumetric examinations performed in conjunction with the

/

associated circumferential welds, coupled with the iystem pressure tests, should provide an acceptable h et c: g ality and sa' fety.

1 4

j

==

Conclusions:==

An acceptable level of quality ard.:dety is j-provided by the licens.ee's proposed alternative. Therefore,

[

pursuant to 10 CFR 50.55a(a)(3)(i), it is recommended that the proposed alternative be authorized.

i l

i-19

. -. -. -.. - - - - _ _.. -. ~.. - -

i 3.1. 4.' 2 Reauest for Relief Number 5. Examination Cateaory B-F. Item l

B5.130. and Examination Cateaory B-J. Item 89.11. Examination of Class 1 Pressure-Retainino Dissimilar Metal Welds Code Reauirement:

Examination Category B-F, Item B5.130 requires 100% volumetric and surface examination for circumferential piping welds of nominal pipe size 4 inch and larger as defined by Figure IWB-2500-8.

t Examination Category B-J, Item B9.11 requires 100% volumetric.and surface examination, as defined by Figure IWB-2500-8, of l

dissimilar metal butt welds of nominal pipe size 4 inch and larger.

Licensee's Code Relief Reauest: The licensee requested relief from the Code-required volumetric coverage for Examination Category B-F, Item B5.130 and Examination Category B-J, Item 89.11 as defined in Figure IWB-2500-8. The welds listed in the table below have limited volumetric coverage due to the weld joint configurations.

I

>h[EN61 nation!Afeai

,ig.

CodeIRequiredCoverage Obtained 2A2 Inlet field weld Safe End to 20% from safe end Pump Weld RC-115-4 0% from pump side 2A2 RCP Inlet shop weld Elbow-to-100% from elbow Safe End Weld RC-Il5-1501-771-A 0% from safe end 2A2 RCP Outlet field weld, Safe 100% from pipe End to Pipe Weld RC-115-701-771 30% from safe end 2B1 RCP Inlet shop weld Elbow-to-100% from elbow Safe End Weld RC-Il5-1501-771-B 0% from safe end 281 RCP Outlet field weld, Safe 100% from elbow i

End to Pipe Wald RC-121-5 0% from safe end 2Al RCP Inlet shop weld Elbow-to-100% from elbow Safe End Weld RC-ll2-1501-771-C 20% from safe end i

20

e 9

Code Re d overage

. Examination Area 2B2 RCP Inlet shop weld Elbow-to-100% from elbow Safe End Weld RC-124-1501-771-D 0% from safe end 2B2 RCP Inlet shop weld Safe End-100% from pipe to-Pipe. Weld RC-124-1301-771 30% from safe end 4

Licensee's Basis for Reauestina Relief (as stated):

" Configuration and permanent attachments prohibit 100% ultrasonic examination coverage of the required examination volume. The attached Table' summarizes the percent of coverage achieved and reference specific Figures included within the request identifying typical configurations.

"Both the pump casing and the safe-end are fabricated from SA-i 351-CF8M material, which is centrifugally cast stainless steel.

This material consists of relatively large grains in columnar structures that are aligned radially."

" INLET "The geometry of the welds varies considerably.

Figure 1 illustrates the inlet safe-end configuration in that the wall thickness of the elbow is 6/10" thicker than the safe-end.

Thus, the elbow-to-safe-end weld tapers down to the safe-end, and within a short distance another taper is caused by the joining of the safe-end to the pump. The configuration of the safe-end weld conditions provide essentially no access limitations on the shop weld from the elbow side, but are significantly more prohibitive from the safe-end side including the surface conditions on the field weld. Most of the 00 surface is not sufficiently flat to permit adequate search unit contact. The taper is often so steep that the ultrasonic beam either changes to an ineffective angle or misses the area of interest entirely.

The transition between weld taper and flat base material is so abrupt that search unit liftoff occurs, causing substantial gaps in the beam coverage."

" OUTLET i

"The outlet safe-end configuration Figure 2 taper; pently upward from the pipe to the safe-end and further into the pump casing which is of an even greater thickness.

The geometric configuration poses no significant access limitation except for the safe-end to pump field weld where beam interrogation is i

possible from one side only."

" SUPPLEMENTARY TECHNIQUE

' Figures, tables and attachments are not included with this evaluation.

21

"FPL has employed a full scala mock-up in lieu of the standard code calibration block. The mock-up was constructed of identical material with a duplication of the construction field weld and a duplication of the shop weld welding parameters considered necessary for this application. (See Figure 3),

"This mock-up is considered invaluable toward the understanding and the qualification of acoustical interfaces that could cause beam scatter, beam redirection, mode conversion and verification of sound beam penetration.

"The mock-up design accommodates a calibration from the carbon steel side to be used for the shop weld and a calibration from the safe-end material to be utilized for field weld examinations.

"The examination technique essentially complies with the provisions of Section XI. The shape and slope of the distance amplitude curve (DAC) is established using side drilled holes while examination sensitivity is established by ID notch (10%)

response.

In both cases, the ultrasonic beam passes through weld metal during calibration.

"The extent of examination volume achieved ultrasonically (see ixamination Coverage Table) coupled with the system pressure tests provide assurance of an acceptable level of quality and s afety. "

Licensee's prooosed Alternative Examination (as stated):

"1) Surface examination per categories B-F and B-J.

?

"2) Ultrasonic examinations will be performed to the maximum extent possible by the employment of a full scale mock-up in lieu of the standard calibration block.

"3) Periodic system pressure tests."

Evaluation: The Code requires 100% volumetric examination coverage of dissimilar metal piping welds. Based on the sketches of the cross sections of the subject welds, it appears that the weld configuration and material acoustic properties make complete volumetric coverage impractical. To obtain complete volumetric coverage, design modifications or replacement of the components with those of a design providing for complete coverage would be necessary.

Imposition of this requirement would cause a considerable burden on the licensee.

22

.~,...-,. -

I

'd i

The licensee performed the volumetric examinations to the maximum extent practical obtaining minimum, one-sided coverages of 20% to l

100%. For several examinations, the licensee obtained 20% and 30% coverages from the second side, increasing overall coverage.

Based on the extent of volumetric coverage achieved and' the Code-required 100% surface examination, it is reasonable to conclude that significant degradation, if present, would have been i

detected.

==

Conclusions:==

The examinations performed provide reasonable assurance of structural integrity, and thus an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(g)(6)(1), it is recommended that relief be granted j

as-requested.

l 3.1.4.3 Reauest for Relief Ns=her 6. Examination Cateaory B-J. Items B9.11. B9.12. and B9.31. Examination of Class 1 Pressure-Retainina Welds in Picina Code Reauirement: Examination Category B-J, Items 89.11 and-89.12, requires 100% volumetric and surface examination for circumferential and longitudinal piping welds of nominal pipe size 4 inch and larger as defined in Figure IWB-2500-8.

Item B9.31 requires 100% volumetric and surface examination of branch pipe connection welds of nominal pipe size 4 inch and larger as defined in Figure IWB-2500-9, -10, or -11, as applicable.

Licensee's Code Relief ReauettJ The licensee requested relief from the Code-required volumetric coverage defined in Figures IWB-2500-8 through IWB-2500-11, as applicable, for the Class I welds listed below.

23

,--.,,,m-,,.,,,,-,,

4 N

4 i

Examination; Area.

Coverage"(%)

DescF Ption (5mita j9ns Loop 2A Hot Leg, 100% pipe side Nozzle OD transition Elbow-to-Inlet 30% from nozzle taper i

Nozzle Weld RC-123-side 201-258 8 Hot Leg Branch 100% one side Branch connection Connection Wald only configuration RC-123-205-771 Supplemental 4

Scan limited from nozzle i

Loop 2A2 100% both welds i

Intermediate Cold from pipe side side due to nozzle OD Leg Steam Generator 0% of shop weld transition taper Nozzle-to-Extension from nozzle side (shop weld) and 98% of field Extension-to-Elbow weld from nozzle (field weld) Welds side 4

RC-115-1, RC-115-1 401-258-B l

Loop 2A2 33%

Scan limited to length of j

Intermediate Cold 4" due to pipe support Leg Longitudinal i

Seam Weld RC-115-j 109-722-LS-A RCS Loop A 2A7 RCP 91%

Longitudinal seam to Reactor Vessel obstructed by welded 1

Longitudinal Seam attachment (lugs) on weld i

Weld RC-115-103-722-centerline j

LS-A l

RCS Loop B 2B1 RCP 59%

Longitudinal seam i

to Reactor Vessel obstructed by welded Longitudinal Seam attachment (lug) on weld Weld RC-115-103-722-and bumper attached to A

sleeve at biological shield penetration Loop 2A1 100% from pipe Scan limited from nozzle Intermediate Cold side side due to nozzle 00 Leg Steam Generator 30% from nozzle transition taper

' Nozzle-to-Extension side (shop weld) and Extension-to-Elbow (field weld) Weld RC-112-401-258-A Pipe to Valve V-3227 63% pipe side Limited by pipe-to-valve Weld RC-151-FW-1 0% valve side configuration Valve V-3227 to Pipe 88% pipe side Limited by pipe-to-valve Weld SI-148-FW-5 0% valve side configuration 24

i t

j d

L

. Ption of~

}

Examination: Areal LLCoverage "(%),

Jese tjmita {9 l

Pipe to Valve V-3624 100% pipe side Limited by pipe-to-valve i

Weld SI-148-FW-1 0% valve side configuration Pipe to Valve V-3617 81% pipe side Limited by pipe-to-valve Weld SI-149-FW-4 0% valve side configuration

{

Pipe to Valve V-3614 100% pipe side Limited by pipe-to-valve t

Weld SI-149-FW-1 0% valve side configuration Valve V-3237 to Pipe 100%_ pipe side Limited by pipe-to-valve Weld SI-150-FW-4 0% valve side configuration Valve V-3247 to Pipe 45% pipe side Limited by pipe-to-valve Weld SI-151-FW-4 20% valve side configuration 4

Pipe to Valve V-3644 63% pipe side Limited by pipe-to-valve Weld SI-151-FW-1 0% valve side configuration Valve V-3261 to Pipe 63% pipe side Limited by pipe-to-valve Weld SI-518-FW-1 38% valve side configuration Licensee's Basis for Reauestina Relief (as stated):

" Configuration, permanent attachments and/or structural interferences prohibit 100% ultrasonic examination of the Code-required volume.

Additional ultrasonic techniques are employed where practical to achieve the Code Required Volume. The attached Table summarizes the percent of coverage achieved and references specific Figures that shows the extent of limitations.

"The extent of examination volume achieved ultrasonically and the alternate scans performed (see Examination Coverage Table) coupled I

with the system pressure tests provide assurance of an acceptable level of quality and safety."

Licensee's Alternative Examination: (as stated)

"1) Surface examination per category B-J.

"2) Ultrasonic examinations will be performed to the maximum extent possible.

"3) Periodic system pressure tests."

Evaluation: The Code requires 100% volumetric examination coverage of Class 1 piping welds. Based on the sketches provided, which

' Figures and Tables are not included in this report.

25

.---....-=.-..- - _-

3 1

depict the cross sections of the subject welds, it appears that

~

scanning limitations (weld configurations such as valve-to-pipe weld, welded attachments, etc.).make complete, Code-required volumetric coverage impractical..To obtain complete-volumetric coverage, design a'

modifications or replacement of the. components'with those.of a design providing for complete coverage would be required.

Imposition of this requirement would cause' a considerable burden on the licensee.

The licensee performed the volumetric examinations to the extent practical obtaining limited two-sided coverage and one-sided coverage as noted in the table above. Based on the extent of volumetric coverage attained, and complete examination of other, similar welds, in combination with the Code-required 100% surface examinations, it is reasonable to conclude that significant degradation, if present, would be detected. As a result, reasonable assurance of structural integrity has been provided.

==

Conclusions:==

Complete Code-required volumetric coverage is impractical. An acceptable level of quality and safety is provided by the examinations performed. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), it is recommended that relief be granted &s i

requested.

a

)

3.1.4.4 Reauest for Relief Number 15. Cateaory B-J. Item B9.11. Examination of Inlet and Outlet Nozzle to Pine Transition Welds Code Reauirement: Examination Category B-J, Item B9.11 requires 100%

[

volumetric and surface examination of circumferential piping welds of j

nominal pipe size 4 inch and larger per Figure IWB-2500-8.

Licensee's Code Relief Reauest: The licensee requested relief from the Code-required surface examinations of the following Class 1 piping welds:

i 26

i

\\

Ident cation Weld Description-401-128-A 42" Outlet Nozzle to Extension RC-114-1

'42" Outlet Nozzle Extension to Pipe 4

201-128A 30" Inlet Nozzle to Extension RC-112-6 30" Inlet Nozzle Extension to Elbow 201-128-8 30" Inlet Nozzle to Extension i

RC-121-6 30" Elbow to Inlet Nozzle Extension j

401-128-8 42" Outlet Nozzle to Extension RC-123-1 42" Outlet Nozzle Extension to Pipe 201-128-C 30" Inlet Nozzle to Extension RC-124-6 30" Inlet Nozzle Extension to Elbow 201-128-D 30" Inlet Nozzle to Extension RC-115-6 30" Elbow to Inlet Nozzle Extension Licensee's Basis for Reauestino Relief (as stated):

"1. Performance of the surface examinations on the Reactor Pressure Nozzle to Pipe Transition welds involves excessive costs, manhours and man / rem with little or no compensating increase in the level of quality and safety.

"2. Changes in Section XI Code Required Volume (CRV) has reduced the volumetric portion to the inner one-third of the weld thickness, while still requiring the surface examination on the outside surface.

In most cases this is considered the most efficient and j

less expensive way of examining these welds.

In the case of the Reactor Coolant piping, this is not the case due to the size of the piping, location of the welds (access), man / rem exposure due to the close proximity of the welds in relation to the RPV, the i

cost of insulation removal, erecting scaffolding, and not to j

mention the increased time of the examiner to conduct the surface e'xamination.

"3. FPL has developed an alternate volumetric examination technique to effectively examine the outside surface of the Reactor Vessel Nozzle to Pipe Transition welds from the inside surface of the component in lieu of the surface examination.

"This volumetric examination will accomplish more than the current surface examination previously performed at St. Lucie.

The surface examination used is the Magnetic Particle examination method, which is limited to defects open to, or just below the 27

I

'2 surface. The alternative volumetric (ultrasonic) examination l

method proposed by FPL, will not only examine the surface area, i

4 j

but the entire volume below the surface.

"4. This technique was used successively at FPL's Turkey Point Units 3 and 4,.and during the St. Lucie Unit I and 2 examinations l

l1 during the last inspection interval.

l J

]

"5. FPL has-over 70 years of operating experience with pressurized water reactors, between our four operating plants. These welds i

have been examined starting with the preservice examination and within each inservice inspection interval without identifying any flaws with either the volumetric and/or surface examination technique, on any of our units."

Licensee's Alternative Examination (as stated):

1 i

"1. Conduct a Full Vee (ultrasonic) examination technique to j

[

effectively examine the outside surface of the Reactor Vessel j'

Nozzle Pipe to Transition welds, from the Inside. surface, in lieu i

i of the surface examination as defined'in the proposed attachment j'

to this request.

1 "2. Conduct system pressure test as required by IWB-2500-1.

"3. The extent of examination required and the proposed examination i

technique, coupled with the system pressure tests provides assurance of an acceptable level of quality and safety."

Evaluation: The Code requires 100% volumetric and surface j

examination of circumferential piping welds of nominal pipe size 4 inch and larger. The licensee states that the surface examination of the subject welds involves excessive costs, manhours, and man rem 1

3 with little or no increase in the level of, quality and safety. The

]

i licensee's proposed alternative to the surface examination is a full-

}

vee ultrasonic technique to interrogate the entire volume of the weld i

l from the inside surface of the pipe. This technique has been

-i qualified on a weld mock-up calibration block for the Turkey Point Plants, Unit 3 and 4, which contains implanted cracks. The cracks were demonstrated to be detectable and recordable as allowv by

)

paragraph IWA-2240, " Alternative Examinations", of ASME S u ion XI.

Based on the review of the licensee's proposed alternative, it is concluded that the full-vee ultrasonic examination provides an acceptable level of quality and safety.

28

s-

==

Conclusions:==

An acceptable level of quality and safety will be provided by the licensee's proposed alternative. -Therefore, pursuant to 10 CFR 50.55a(a)(3)(1), it is recommended that the proposed s

alternative be authorized.

i 3.1.5 Pumo Pressure Boundarv (No relief requests) 3.1.6 Valve Pressure Boundary (No relief requests) 3.1.7 General (No relief requests) 3.2 Class 2 Comoonents 3.2.1 Pressure Vessels 3.2.1.1 Reauest -for Relief 8. Examination Cateaory C-A. Item C1.10.

Examination of Class 2 Shutdown Coolina Heat Exchanaer Shell Maldt Code Reauirement: Examination Category C-A, Item C1.10 requires 100% volumetric examination of Class 2 pressure-retaining welds in pressure vessels at gross structural discontinuities as defined in Figure IWC-2500-1.

Licensee's Code Relief Reauest: The licensee requested relief from examination of the Code-required volumes for Shutdown Cooling Heat Exchanger Welds No.1-2701 (flange-to-body) and 1-2702 (body-to-tubesheet) as specified in Figure IWC-2500-1.

Ocensee's Basis for Reauestina Relief (as stated):

" Ultrasonic examination of welds No.1-2701 (flange to Body) and 1-2702 (body to tubesheet) are partially obstructed by inlet and outlet nozzle reinforcing pad. - Approximately 78% of Code Required volunie is achieved.

"The extent of examination volume achieved ultrasonically coupled with the system pressure leakage tests provide assurance of an acceptable level of quality and safety."

29

t O

Licensee's Proposed Alternative Examination (as stated):

"l) Conduct examinations to the extent practical per IWC-2500-1 j

"2) Perform System Pressure Test as required by IWC-2500-1" Evaluation: The Code requires that the subject welds receive a i

100% volumetric examination. However, due to the flange-to-body and body-to-tubesheet weld configurations, complete volumetric Code coverage is impractical. To obtain complete volumetric coverage, design modifications or replacement of the components i

with those of a design providing for complete coverage would be required.

]

The licensee performed the volumetric examinations to the extent practical, resulting in approximately 78% Code coverage.

Based on the significant percent of coverage obtained, it is reasonable to conclude that degradation, if present, would have been J

detected. Thus, reasonable assurance of operational readiness has been provided.

==

Conclusions:==

Complete, Code-required volumetric examination is 4

impractical due to the weld configurations. However, the significant coverage achieved provides information on the component structural integrity, and thereby reasonable assurance of operational readiness. Therefore, pursuant to 10 CFR 50.55a(g)(6)(1), it is recommended that relief be granted as requested.

3.2.1.2 Reauest for Relief 9. Examination Cateoory C-B. Item C2.21.

Examination of Class 2 Steam Generator Nozzle-to-Vessel Welds Code Reauirement:

Examination Category C-B, Item C2.21 requires 100% surface and volumetric examination of Class 2 pressure-retaining nozzle welds without reinforcing plates in vessels greater than 1/2 inch wall thickness as defined in Figure IWC-2500-4(b).

30 l

ti V

i Licensee's Code Relief Reauest: The licensee requested relief

)

from volumetric examination of the Code-required volumes for the following welds.

~

Description j.

Examination' Area'_

. Coverage (%))

(jgj,j9ns d

i Steam Nozzle to 100% one side Examination limited by Head Weld configuration to one side No. SG-2A-105-201 L

Feedwater Nozzle 100% due to full Examination limited by to Shell Weld vee (one sided) configuration and welded l

No. SG-2A-111-221 98% one sided attachment i

j Licensee's Basis for Reauestina Relief (as stated):

1

" Configuration and permanent attachments prohibit 100% ultrasonic examination of Code required volume. Additional ultrasonic techniques are employed where practical to achieve the Code Required Volume. TheattachedTablesummarizesthepercentof coverage achieved and references the specific Figure within the 4

relief providing the extent of the limitations.

"The extent of examination volume achieved ultrasonically and i

alternate scans performed (see Examination Coverage Table)

{

coupled with the system pressure tests provide assurance of an acceptable level of quality and safety."

i l

Licensee's Alternative Examination (as stated):

i j

"l) Periodic System Pressure tests per IWC-2500-1 l

"2) Perform to the extent practical the volumetric and surface j.

examinations as required by IWC-2500-1."

l Evaluation: The Code requires that the subject welds receive a j~

1,00% surface and volumetric examination.

It appears that the Feedwater nozzle-to-shell weld coverage is essentially 10 % not requiring relief. For the nozzle-to-head weld, due to l

configuration complete volumetric Code coverage is impractical.

To obtain complete volumetric coverage, design modifications or l

' Figures, tables, and attachments are not included in this report.

31 l

replacement of the nozzle-to-head weld with one of a design providing for complete coverage would be required.

The licensee performed the volumetric examinations to the extent practical.

Based on the significant percent of volumetric coverage obtained and 'the surface examination, it is reasonable to conclude that degradation, if present, would have been detected. Therefore, reasonable assurance of operational readiness has been provided.

==

Conclusions:==

Compliance with the Code-required volumetric coverage is impractical for the Main Steam nozzle-to-head weld due to the weld configuration.

However, the significant extent of examination coverage achieved provides reasonable assurance of operational readiness.

Therefore, pursuant to 10 CFR 50.55a(g)(6)(1), it is recommended that relief be granted i

for the Main Steam nozzle-to-head weld as requested.

In the case of the Feedwater nozzle-to-shell weld, relief is not required.

l 3.2.2 Pinino 3.2.2.1 Reauest for Relief 4 (Part 2 of 2). Examination Cateoories C-F-1 and C-F-2. Items C5.12. C5.22. C5.42. C5.52. C5.62. and C5.82.

Examination of Class 2 Lonoitudinal Pioino Welds Code Reauirement: Examination Categories C-F-1 and C-F-2, Items C5.12, C5.22, C5.52, and C5.62 require 100% volumetric and surface examination of Class 2 longitudinal piping welds for 2.5T from the intersection with the applicable circumferential weld.

Items C5.42 and C5.82 require 100% surface examination'of the longitudinal piping welds for 2.5T from the intersection with the applicable circumferential weld.

Licensee's Code Relief Reauest:

The licensee requested relief from the Code-required surface and volumetric examinations for Class 2 longitudinal piping welds for 2.5T from the intersection with the applicable circumferential weld.

32

j i

c Licensee's Basis for Reauestino Relief (as stated):

i "1. Longitudinal welds are fabricated during original manufacturing under_ controlled shop conditions, which produce higher quality and more uniform residual stress patterns.

l "2. Longitudinal piping welds undergo heat treatment in the shop, which enhances the material properties of the weld and

- reduces the residual stresses created by welding.

"3. For Austenitic stainless steel piping, the intergranular stress corrosion cracking (IGSCC) problem, or for that matter any stress corrosion problem, has not occurred to any significant extent in PWR piping, due to the nonoxygenated environment, nor to carbon steel piping in PWR's L

"4. Results of previous weld inspections through out the industry i

indicates that longitudinal welds have not been a safety concern, nor has there been any evidence of longitudinal weld defects compromising safety at nuclear power plants.

"5. Longitudinal welds have not been shown to be susceptible to q.

any particular degradation mechanism.

"6. The only areas of a longitudinal weld which may be considered suspect are the ends of the weld where it is adjacent to the field fabricated circumferential welds.

These areas fall within the volumetric examination boundaries of the adjacent circumferential welds.

"7. The man-rem exposure and cost associated with the inspection of longitudinal welds is dependent on the time it would take i

to remove / reinstall insulation and interferences, locate the weld, prepare the weld for examination and perform the examination.

i 1

"The volumetric and surface examination costs and man-rem for the selected Class 1 and Class 2 longitudinal welds are estimated to cost $34,496, and 25 man-rem for the second 1

inspection interval.

I "8

Based on the above arguments, there is little, if any, technical benefit to performing inservice inspections on longitudinal piping welds.

In addition, there are substantial radiation exposure a.d cost considerations associated with these inspections."

Licensee's Alternative Examination (as stated):

"FPL proposes to eliminate the examination requirements for surface examination on Class 1 and 2 longitudinal piping welds beyond those inspections which are required for the adjacent circumferential weld.

l 33 l

. - -. - ~ -

p

't

]}

i j

"FPL-also proposes to enhance the volumetric examinations at the j

intersection point of circumferential and imgitudinal welds by including both transverse and parallel scans within the length of 1

longitudinal weld which falls within the circumferential weld l

examination volume.

l 1

i i

"Circumferential welds with intersecting longitudinal welds will 3

.be noted to document the extent of the examination.

1 J

"The. extent of volumetric examinations performed coupled with the i

j system pressure tests provides assurance of an acceptable level of quality and safety."

j i

4 Evaluation:

The Code requires surface and/or volumetric l

examination, as' applicable, of the longitudinal piping welds for i

.2.5T from the. intersection with the_ applicable circumferential l

weld.

In the response to the NRC's RAI, the licensee clarified j

that the request for relief included' both surface and volumetric 1

examination of the length of longitudinal weld required by Code.

1 As an alternative, the licensee proposed to examine a portion of each longitudinal weld in conjunction with the associated a

circumferential weld. The proposed alternative is based on the j

position that longitudinal welds are unlikely to fail; the low l

probability of failure is attributed to fabrication. controls and

[

lack of susceptibility to conditions that lead to failure.

l Additional radiatten exposures would be incurred by performance j

of the surface examinations. The licensee states that the potentially critical portions of the longitudinal welds (the

}

portions that intersect the circumferential welds) will be examined in conjunction with the circumferential welds.

4 The licensee's proposed alternative to the surface and/or volumetric examination of the longitudinal welds to the extent 1

j required by the Code is to perform a surface examination and enhanced volumetric examination that includes both transverse and j

parallel scans for the length of longitudinal weld that falls i

within the circumferential weld examination volume. The j

circumferential welds with intersecting longitudinal welds will i

be noted to document the extent of the examination.

The extent of surface and volumetric examinations performed, coupled with j

34

y i

j the system pressure tests, should provide an acceptable level of quality and safety.

a t

i Conclusioni: An acceptable level of quality and safety is provided by the licensee's proposed alternative.

Therefore, g

pursuant to 10 CFR 50.55a(a)(3)(1), it is recommended that the proposed alternative be authorized.

J 3.2.2.2 Reauest for Relief 10. Examination Cateaories C-F-1 and C-F-2.

,r l-Itame C5.11. 5.12. and C5.81. Examination of Class 2 Pressure-l Retainina Welds in Pioina l"

Code Reauirement:' Examination Category C-F-1, Items C5.Il and

[

C5.12 require 100% surface and volumetric examination of Class 2 j

piping welds equal to or greater than 3/8 inch wall thickness in j

piping greater than 4 inch nominal pipe size.

j Examination Category C-F-2, Item C5.81 requires 100% surface examination of pipe branch connections of branch piping equal to 3

or greater than 2 inch nominal pipe size.

Licensee's-Code Relief Reauest: The licensee requested relief l

from the surface and volumetric examination requirements of the Code for the following welds.

4 5

i FEaminatihn'Afear Coverage-(%)

Description' of L'imit' tions

~

a Pipe Longitudinal Examination limited by Seam Welds welded attachment MS-1-FW-1-LS 93% PT MS-33-FW-1-LS 84% UT Pipe to Valve 37% pipe and Limited due to pipe-to-(V-3144) Weld No.

valve sides valve configuration SI-146-FW-2 Valve (V-3144) to 65% pipe Limited due to pipe-to-Pipe Weld No. SI-

side, valve configuration' Il0-FW-1 57% valve side 35

-.. -. - -. -. ~..

-~ - -..

j I

Examination' Area Coverage (%)

Description of Limitations l

~

l Pipe to Elbow Weld 80% CRV 4" of total circumference No. SI-110-8-SW-1 achieved missed due to I-beam of s

top Valve (V-3654) to 40% Pipe Limited due to pipe-to-I 4

Pipe Weld No. SI-

side, valve configuration i

213-FW-2 20% Valve Side j.

Pipe to Valve 40% pipe Limited due to pipe-to-(V-3654) Weld No.

side valve configuration SI-213-FW-1 20% valve side Licensee's Basis for Reauestino Relief (as stated):

n

" Ultrasonic and surface examination partially obstructed by 1

welded attachments.

"The extent of examination volume achieved ultrasonically and the alternate scans performed coupled with the system pressure tests l

provide assurance of an acceptable level of quality and safety."

i j

Licensee's Proposed Alternative Examination (as stated):

}

"1) Periodic System Pressure tests "2) Perform. volumetric and surface examination to the extent j

practical" Evaluation:

The Code requires that the subject welds receive a I

100% surface and volumetric examination.

However, due to the 2

l weld configurations and restrictions imposed by attachments, complete Code coverage is impractical.

To obtain complete

{

surface and. volumetric coverage, design modifications or

{

replacement of components with those of a design providing for I

complete coverage would be required.

1

==

Conclusions:==

Compliance with the Code requirements is impractical due to the weld configurations and obstructions. The

]

licensee--has performed the subject examinations to the extent practical.

Based on the coverage achieved, information is j

provided with respect to component structural integrity.

This l

information in combination with similar piping weld examinations j

36

9

)

provides reasonable assurance of operational readiness.

j Therefore, pursuant to 10 CFR 50.55a(g)(6)(1), it is recommended that relief be granted as requested.

t i

l 3.2.3 Pumos (No relief requests) l

?

l 3.2.4 Valves (No relief requests) 2 l

3.2.5 General 4

3.2.5.1 Reouest for Relief 14. IWB-2412 and IWC-2412. Insoection Proaram B Percentaae Reauirements. IWB-2420 and IWC-2420.

l Seouence of Comoonent Examinations Established Durino the First i

Inspection Interval i

Code Reauirement:

IWB-2412 and IWC-2412 specify the h

minimum / maximum percentage of examinations that may be p'erformed in a given period.

IWB-2420 and IWC-2420 require that the i

sequence of component examinations established during the first inspection interval be repeated during each successive inspection interval, to the extent practical.

Licensee's Code Relief Reauest:

The licensee requested relief j

from the successive inspection scheduling established during the first inspection interval for the following examination areas:

i c'ategory

)Ikem: 1xaminannireaDescriphon y,

B-D' B3.90 RPV Nozzle - Vessel Weld B3.100 RPV Nozzle Inside Radius B3.110 Pressurizer Nozzle - Vessel Weld B3.120 Pressurizer Nozzle Inside Radius B3.130 Steam-Generator Nozzle - Vessel Weld l

B3.140 Steam Generator Nozzle Inside Radius

'See Relief Request 17 for the evaluation of Examination Category B-D Items B3.90.and B3.100..

37

4 1

\\

Conclusion:

The licensee's proposed rescheduling of examinations

)'

for the second interval results in noncompliance with the successive examination re virements as well as with the percentages of examinations to be performed each inspection period.

Therefore, it is recommended that relief be denied.

i 42

i 3.2.5.2 Reauest for Relief 16. Paraoraoh IWA-6620. Preparation of Owner's Reoorts. Forms NIS-1 and NIS-2. and Submittal of 90-day Suman Reoort 4

j Code Reauirement:

Paragraph IWA-6220 requires that the licensee prepare NIS-1, kner's Report for Inservice Inspections, and NIS-2, kner's Report for Repair or Replacements, and file these reports with the enforcement and regulatory authorities having I

jurisdiction at the plant site within 90 days of the completion of the inservice inspection conducted during each refueling outage.

i i

Licensee's Code Relief Reauest: The licensee requested relief i

from :

i 1.

Preparation of the kner's Report for Inservice Inspection, I

Form NIS-1.

3 2.

Preparation of the kner's Report for Repair or Replacement, Form NIS-2.

4 3.

Submittal of the sumary report within 90 days following completion of the inservice inspection conducted during each l

refueling outage.

i Licensee's Basis for Reauestino Relief (as stated):

i

" Florida Power and Light Company (FPL) feels that the summary report required by IWA-6000 does not contain the information necessary to assure compliance with Code requirements, and therefore does not provide a compensating increase in the quility and/or safety of the St. Lucie operating plant.

"The sumary report does not furnish evidence of compliance with i

ASME Boiler and Pressure Vessel Code,Section XI, Inspection Prograni B, percentage requirements as mandated by IWB-2412, i

IWC-2412, and IWD-2412.

" Class 3 components are excluded from the sumary report submittal.

"Both a Final Report and Sumary Report must be prepared, reviewed, and approved in order to comply with sub-article's IWA-6220 and IWA-6310 respectively.

]

43

j~~~

j i4

.~

"The preparation, review, approval and certification of each 2'

record and report, within the time frame of 90 days following i

completion of each refueling outage, increases substantially the

)

i costs associated with inservice inspection activities, and puts an unreasonable time constraint on FPL without a increase in j

<[

assurance of Code compliance."

)

]

Licensee's Proposed Alternative (as stated):

{

j "As an alternate to the requirements of IWA-6000, Florida Power and Light Company proposes the following:

l l

"1) REPAIR / REPLACEMENT PLAN

'i Repair /Replac ment plans shall meet the requirements of IWA-4140 (1902 Edition), to the extent required, for all Code 1

l Classes.

i Each Repair / Replacement Plan shall be given a unique j

identification number.

The unique identification number may j

be the number of the document utilized for the repair and/or replacement as required by FPL procedures or instructions.

4 1

(i.e., NCR, CNR, PCM, MEP, CW0, PWO, etc. ).

3 i

All other requirements of IWA-4000 (1989 Edition) which are applicable to the repair or replacement shall be met.

"2) REPAIR REPLACEMENT CERTIFICATION RECORD As an alternate to the NIS-2 Report, following completion of repair or replacement FPL shall prepare and certify the Repair / Replacement Plan Certification Record, Form NIS-2A, attached l

The completed Form NIS-2A shall become part of the i

Repair / Replacement Plan and shall be maintained in accordance i

with IWA-6300.

l FPL shall maintain an index and update regularly the status of the index of all' Repair / Replacement Plans for all Code 3

i Cl asses.-

The index shall identify the unique identification number and interval and period during which the repair or replacement was completed.

i The index shall be maintained in accordance with IWA-6300, i

and be made available upon request for review by the enforcement and regulatory authorities having jurisdiction at i

the plant site.

L J

' figures, tables, and attechments are not included in this report.

j 44

b

.c 5.ilb *o.

y 1

"3)

SUMMARY

REPORT l

A Summary Report shall be prepared and submitted to the regulatory and enforcement authorities having jurisdiction at i

the plant site within 120 days following the end of the Inspection Period as identified in Program'8.

The Summary Report shall include examinations, tests, repa. irs and replacements results for all ASME Class items which have been completed since the previously submitted Summary Report.

The Summary Report shall contain the following:

r Summary Report Cover Sheet, Form NIS-1A, attached.

a.

b.

Abstract of examination and tests information, Form NIS-1B, attached.

Listing of examinations, Form IC, that were not c.

performed to the extent identified by the inspection plan for the inspection period, and when or if they are planned for a later date. Additionally,'any alternate examination (IWA-2240), from those identified within the inspection plan, were performed.

d.

A listing of all flaws that require analytical evaluation, Form NIS-ID, attached.

Abstract of all Code Classes of repairs and e.

replacements Form NIS-28, which were required due to an item (s) having exceeded'an. acceptance criteria for IWX-3000."

i Evaluation: The use of the NIS-1 and NIS-2 report forms and submittal of the 90-day Summary Report are Code requirements.

Their consistent industry-wide use establishes a uniform reporting methodology for evaluating Code compliance for inservice examinations and the extent of repairs and replacements for regulatory purposes.

Because burdens associated with the subject administrative requirements of the Code are not considered a primary factor when considering relevance to safety, the licensee should present administrative change proposals to the applicable Code committee as deemed appropriate.

I

==

Conclusion:==

Based on the above evaluation, it is recommended

)

that relief be denied.

45

c

[

3.3 Class 3 Comnonents (No relief requests) j i

3.4 Pressure Tests (No relief requests) i J

3.5 General i

3.5.1 Ultrasonic Examination Techniaues 3.5.1.1 Reauest for Relief 13. Anoendix III Reauirements. Ultrasonic

)

l Calibration Blocks J

Code Reauirement: ASME Section XI, Appendix III, III-3400 requires-the calibration blocks to be made from pipe of the same 1

nominal diameter and nominal wall thickness (pipe schedule) as the pipe to be examined.

III-3411 requires that the calibration block be fabricated from j

one of the materials specified for the piping being joined by the i

weld.

Licensee's Code Relief Reauest: The licensee requested relief from the ASME Code, Appendix III, requirements for use of a 1

calibration block of the same nominal diameter and wall thickness, or pipe schedule, and for fabrication of the calibration block from one of the same materiris as the piping being joined for calibration blocks UT-4A and UT45.

Licensee's Basis for Reauestino Relief (as stated):

"1. UT-4A Primary Coolant Piping, Hot Leg SA-533 Grade A is comparable to SA-516 Grade 70 (piping material), as provided by ASME Section XI, Appendix III, Article III-3411 (c).

]

1 "2. UT-45 Main Steam Piping Welds 1

The subject piping welds are of two sizes:

"a) 34" diameter, 1.250" wall l

46 i

4 h

4

)

4 "b) 36.625" diameter, 1.234" wall. The requirements of i

ASME code are such that two blocks, one.of each diameter would be required.

i i

"c)

The wall thickness is essentially the same, therefore there is little or no change in the sensitivity.

a l

"d)

The small difference in diameter is not ultrasonically noticeable i

"3. The proposed calibration blocks have been in use since the plant was built, their continued use would tend to provide j

consistent results."

Licensee's Pronosed Alternative Examination (as stated):

}

" Perform the Code required examinations using the proposed

}-

calibration blocks as defined above."

i l

Evaluation:

The Code requires that calibration blocks be of the 4

same diameter, thickness, and material as the area to be

)

examined. The licensee procured the subject piping calibration blocks at the time the plant was built and has used them during previous inservice inspection intervals.

In accordance with III-1100(d), the licensee may use calibration block designs

?

demonstrated, to the satisfaction of the inspector,- to be' equivalent or superior to the requirements specified, as provided-j by IWA-2240.

Based on a review of the calibration block l

specifications, it appears that an acceptable degree of I

equivalence exists.

Therefore, continued use of these blocks should be allowed, provided it is demonstrated to the Inspector that these calibration blocks provide an acceptable level of examination sensitivity.

The licensee proposed continued use of Calibration Blocks UT-4A anc UT-45 as an alternative to calibration-blocks in compliance with the Code.

This alternative should provide an acceptable level of quality and safety provided that these calibration blocks can be demonstrated to provide equivalent acoustic properties.

47

l i

==

Conclusions:==

An acceptable level of quality and safety will be provided by the licensee's proposed alternative calibration blocks, if it is demonstrated to the Authorized Inspector-to j

provide an acceptable level of examination sensitivity.

Therefore, pursuant to 10 CFR 50.55a(a)(3)(1), it is recommended that the proposed alternative be authorized.

3.5.2 Exemoted Comoonents (No relief requests) i 3.5.3 Other (No relief requests) i i

s I

I i

48

d 4.

CONCLUSION Pursuant to 10 CFR 50.55a(g)(6)(i), it has been determined that certain inservice examinations cannot be performed to the extent required by Section XI of the ASME Code.

Therefore, it is recommended that for Requests for Relief 1, 3,.5, 6, 8, 9, and 10 relief be granted as requested. The granting of relief will not endanger life, property, or the common defense and security and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Pursuant to 10 CFR 50.55a(a)(3)(i), it is concluded that for Requests for Relief 4 (Parts 1 and 2), 13, 15, and 17 (with the condition stated in the evaluation), the licensee's proposed alternative provides an acceptable level of quality and safety in lieu of the Code-required examination and it is recommended that relief be authorized.

For Requests for Relief 14 and 16, it is concluded that the licensee has not provided sufficient information to support the determination that the Code requirement is impractical and that requiring the licensee to comply with the Code requirement would not result in hardship.

(Requests for Relief 2, 7,11, and 12 were not resubmitted as they are not required for the second 10-year interval.)

Based on the review of the St. Lucie Nuclear Plant, Unit 2 Second 10-Year Interval Inservice Inspection Program Plan, Revision 0, the 11censee's response to the NRC's request for additional information, and the recommendations for granting relief from the ISI examinations that cannot be i

performed to the extent required by Section XI of the ASME Code, no deviations from regulatory requirements or commitments were identified, except for Requests for Relief 14 and 16.

49

47 4.

5.

REFERENCES 1.

Code _of federal Regulations, Title 10, Part 50.

2.

American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Division 1; 1989 Edition 3.

St. Lucie Nuclear Plant, Unit 2 Second 10-Year Interval Inservice Inspection Prograe Plan, Revision 0, dated August 4, 1993.

4.

NUREG-0800, Standard Review Plan for the Review of Safety Analysis i

Reports for Nuclear Power Plants, Section 5.2.4, " Reactor Coolant i

Boundary Inservice Inspection and Testing," and Section 6.6, " Inservice Inspection of Class 2 and 3 Components," July 1981.

5. Letter dated June 17, 1994, J. A. Norris (NRC) to J. H. Goldberg (FPL),

containing NRC Request for Additional Information.

6. Letter. dated August 22, 1994, D. A. Sager (FPL) to Document Control Desk (NRC) containing response to June 17, 1994, Request for Additional Information.

7. NRC Regu3atory Guide 1.14, Reactor Coolant Pump Flywheel Integrity, August 1975.

8. NRC Regulatory Guide 1.150, Reactor Pressure Vessel Beltline Weld Examinatfons, Rev. 1, February 1983.

9. IE Bul1etin 82-02, Degradation of Threaded Fasteners in the Reactor Coolant Pressure Boundary of PWR Plants, June 2, 1982.

10. NRC Regulatory Guide 1.65, Naterial and Inspections for Reactor Vessel Closure Studs, October'1973.

i l

l i

j 50

- ~

.e,

4 gg.:.v225 u s NuctE Aa REcutAroRv Commiss eE s g,p,.

Y:~ofE2$

BIBLIOGRAPHIC DATA SHEET

~~

Isee +structions on ene reverses 2 TiicE ANo susim E INEL-94/0147 Technical Evaluation Report on the Second 10-Year Interval Inservice Inspection Program Plan:

1 oats RE,0 7,visis E:

Florida Power and Light Company wo r-j t,

St. Lucie Nuclear Plant, Unit 2 March 1995 Docket Number 50-389

( P N oR cRANT Nuveta FIN-L2556 (Task-20)

5. AUTHORIEl

6. TYPE OP REPORT i

Technical U.W. Brown, E.J. Feige, K.W. Hall, A.M. Porter

7. eE Rioo Cov E R e o,,a.,

- o,,,

s.

F A NIZA TION - N AM E AND AOD R ELS ist 4ac. ever.or cer. mea. Onsre er messoa. V.14.reer mesi,detery C.

. mis aiasdamp sepee es rearrareer. eso or Lockheed Idaho Technologies Company i

Idaho Falls, Idaho 83415-2209 9.

O RGANIZATION - N AM E AND ADOR E55 ist mac, ever 3 w as ses.e. etcearnerser. sewnse sac o*=,ea. onsce er mensa, ut messer men aeory Cow Materials and Chemical Engineering Branch Office of Nuclear Regulatory Comission i

i U.S. Nuclear Regulatory Comission

)

Washington, D.C.

20555 4

10. SUPPLEMENTARY NOTES ll, ABSTRACT (200 wome er mas This report presents the results of the evaluation of the St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval Inservice Inspection (ISI) Program Plan, Revision 0, submitted January 5, 1994, including the requests for relief from the American i

Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI requirements that the licensee has determined to be impractical.

The St. Lucie j

Nuclear Plant, Unit 2, Second 10-Year Interval Inservice Inspection (ISI) Program Plan, Revision 0, is evaluated in Section 2 of this report.

The ISI Program Plan is evaluated for (a) compliance with the appropriate edition / addenda of Section XI, (b) acceptability of examination sample, (c) correctness of the application of system or component examination exclusion criteria, and (d) compliance with ISI-related comitments identified during previous Nuclear Regulatory Comission reviews.

The requests for relief are evaluated in Section 3 of this report.

1 1

i

12. K E Y WOROS/DESCR!PTQR 5 tost misser er enaeus ense een esser ensemenses en sessmay ene eveen.s

3. awasLasiu f

1iaT&w4 %T Unlimited 14 $4CURI T Y CLA15l S eGA T K,,N I roen 9apre Unclassified tinn neeens Unclassified

15. NUMBER OF PAGES

16. PRICE f

NaC pomu 3Js (3een

7 _

t ST. LUCIE NUCLEAR PLANT, UNIT 2 Page 1 of 3 Second 10-Year 151 Interval TABLE 1 SUNNARY OF RELIEF REQUESTS Reitef Rollef Request Systen or.

> Exas.

Itse :

. ~

Required -

Requeet Number Campenent~

Category No,-

.VoluesorAreatobeExaminedf

.-Method Licenese Proposed Altemative Status RR-1 Reactor B-A Bl.11 Lower Shell to Intermediate Shell Volumetric

1) Periodic System Pressure Granted Pressure Vessel Circ eferential Weld 101-171 tests per category B-P, i

Table IWB-2500-1 Bl.12 Shell Longitudinal Welds 101-124C, 101-122A

2) Inservice Hydrostatic tests per Table IWB-2500-1 Bl.21 Dome Weld 102-101

3) Conduct Mechantred B1.22 Bottem Head Peel segments Ultrasonic Examinations to 101-154A, 101-1548, 101-154C, the extent practteal.

101-1540, 101-154E, 101-154F

4) 50/70* Bt-modal ultrasonte Bl.30 Upper Shell-to-Flange Weld 101-121 examination of the Inner 25 percent Bl.40 Flange-to-Torus Weld 101-101 B-0 B3.90 Nozzle to Shell Welds 105-121a, 103-121B RR-3 Pressurtzer B-0 B3.110 Nozzle-to-Vessel Welds 103-601, Volumetric

1) Periodic System Pressure Granted 108-601-A, 108-601-B, 108-601-C, tests.

108-601-0, 105-651

2) Conduct UT Exams the extent practical.

RR-4 Class 1 Piping B-J B9.12 Longitudinal Seam Welds Volumetric Examine longitudinal weld only Authortred (Part 1)

Systems 89.22 and/or at intersection of Surface circumferential weld RR-4 Class 2 Piping C-F-1 C5.12, Longitudinal Seam Welds Volmetric Examine longitudinal weld only Authorized (Part 2)

Systems Welds C5.22, and/or at intersection of C5.42 Surface circumferential weld C-F-2 C5.52 C5.62 C5.82 m

m.

<s 1

ST, LUCIE NUCLEAR PLANT, UNIT 2 Second 10-Year ISI Interval Page 2 of 3 TABLE I SUfmARY OF RELIEF REQUESTS Relief Request Systen or-

. Exam ?

Item -

Relief Regaired' naquest Number Camponent:

Category;

, No.

Volume or Area to be Exeetned ?

- Method Licensee Preposed AlternetIve Status RR-5 Class 1 Reactor B-J B9.11 Piping Dissimliar Metal Welds Surface and

1) 100% surface exam Granted Coolant System B-F B5.130 RC-115-4. RC-115-1501-771-A, Volumetric RC-115-701-771, RC-115-1501-771-B,

2) UT exam to the RC-121-5. RC-112-1501-771-C.

maximum extent possible.

RC-124-1501-771-D, RC-124-1301-771,

3) Periodic system pressure tests.

RR-6 Class 1 Piping B-J 89.11 Piping Walds RC-123-201-258 Volumetric

1) 100% surface exam Granted Systems RC-115-1, RC-115-401-258-B, and Surface RC-112-401-258-A RC-151-FV-1

2) UT exam to the maximum 51-148-FW-5. 51-148-FW-1 SI-149-FW-4 SI-149-FW-1 extent possible.

SI-150-FW-4, SI-151-FV-4

3) Periodic system pressure

$1-151-FW-1, 51-518-FW-1 tests.

B9.12 RC-115-109-722-LS-A.

RC-115-103-722-LS-A, RC-115-103-722-A, B9.31 RC-123-205-771 RR-8 Shutdown C-A C1.10 Flange to Body Veld (1-2701)

Volumetric

1) UT exam to the maximum Granted Cooling Heat Body to Tubesheet Weld (1-2702)

Exchanger extent practical

2) System pressure test RR-9 Steam Generator C-B C2.21 Steam Nozzle to Head Weld Surface and

1) System pressure test Granted (SG-2A-105-201)

Volumetric

2) Perform to the extent

Feedwater Mozzle to Shell Veld practical the volumetric

Relief Not (SG-2A-111-221) and surface exams Required

ST. LUCIE NUCLEAR PLANT, UNIT 2 Second 10-Year ISI Interval Page 3 of 3 TABLE 1 SUMARY OF RELIEF REQUESTS Relief Relief Request Systen or..

.a Exas c

Itasi Required-a=9==t.

aima r rwt!

ML20138E635

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ML20138E635

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