L-2009-169, Response to Request for Additional Information, Third Interval Relief Request 32

Response to Request for Additional Information, Third Interval Relief Request 32

ML092090263
Person / Time
Site:	Saint Lucie
Issue date:	07/20/2009
From:	Katzman E Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2009-169
Download: ML092090263 (57)

Text

Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach, FL 34957 July 20, 2009 F=PL L-2009-169 10 CFR 50.4 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re: St. Lucie Unit 1 Docket No. 50-3 35 Response to Request for Additional Information Unit 1 Third Interval Relief Request 32 On February 6, 2009, FPL submitted relief request 32 for the St. Lucie Unit 1 Third ISI Interval.The relief request dealt with the impracticality to meet the code required volume coverage of some piping and vessel welds as required by the ASME Code, 1989 Edition, no addenda, as clarified by Code Case N-460 due to configuration and/or the presence of permanent attachments.

Relief is requested in accordance with 1 OCFR50.55a(g)(5)(iii).

The NRC requested additional information via emails that were subsequently posted in ADAMS as ML091590627 and ML091800277.

The responses to the RAI questions are within Attachment

1. Attachment 2 contains the revised relief request.Sincerely, Eric S. Katzman Licensing Manager St. Lucie Plant Attachments ESK/KWF an FPL Group company St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 1 Page I of 4 2.2 Request for Relief 32, All Examination Cateqories Specific inspection techniques used to examine the subject welds are unclear. The figures included in the licensee's submittal show that various angle beam transducers were used and note the areas applied. However, the wave mode (shear or refracted longitudinal), and actual beam propagation angle, have not been identified.

In addition, materials of construction and thickness of components have not been provided.FPL Response: The wave mode, actual beam propagation angle, materials of construction and thickness of each component has been added to Tables 1 through 7.2.2.1 Summarize the inspections techniques (e.g., 0-degree longitudinal, and/or 30-, 45- and 60-degree shear wave; etc.) for each of the welds included in RR-32.FPL Response: The inspection techniques for each weld have been added to Tables 1 through 7.2.2.2 Clarify, if not specifically noted in the licensee's Table 1[1], whether the examinations listed in the Table were conducted prior to, or after, implementation of ASME Code,Section XI, Appendix VIII requirements.

FPL Response: All examinations identified in Tables 3 (B-J/R-A), 6 (C-F-i), and 7 (C-F-2) were performed utilizing personnel qualified and procedures demonstrated in accordance with the ASME Section XI, Appendix VIII, Supplement 2 or 3 as applicable and the PDI program.[1] Table 1 is not included in this Technical Letter Report (TLR) and can be found in the licensee's submittal dated February 6, 2009.2.2.3 Prior to the requirement to implement ASME Code,Section XI, Appendix VIII, state to what ASME Code inspection requirements were used to examine the subject welds in all the ASME Code,Section XI, Examination Categories listed in RR-32.FPL Response: All examinations identified in Tables 3 (B-J/R-A), 6 (C-F-i), and 7 (C-F-2) were performed utilizing personnel qualified and procedures demonstrated in accordance with the ASME Section XI, Appendix VIII, Supplement 2 or 3 as applicable and the PDI protocol.

St. Lucie Unit 1 L-2009-169 Docket No. 50-335 Attachment 1 Page 2 of 4 2.2.4 State the materials of construction, wall thickness, and schedule (for piping) for each of the components in RR-32. Note any specific features, such as cladding on the inside diameter (ID) of any of the carbon steel components, etc. If not already described, list the system and/or specific component, as applicable, to which each of the subject welds is associated.

FPL Response:

The materials of construction, wall thickness, and schedule (for piping) for each of the components has been added to Tables 1 through 7. Cladding, when present, is identified in the "Materials" column of Tables 1 through 7 and shown on the figures. Each specific component is described in the "ASME Code Component" column.The licensee lists examination coverage for certain welds as 100% from one side (e.g., pipe), and lists varied coverage from the opposite side of the weld. However, if these welds were examined after implementation of ASME Code,Section XI, Appendix VIII requirements, it is unclear how the licensee can credit the full volume (100%) from only one side, as qualifications for detecting flaws on the far-side of austenitic welds has not been demonstrated.

2.2.5 Please clarify the volumetric coverage(s) obtained (and claimed) for all of the subject welds.FPL Response:

The coverage(s) credited has been clarified in Tables 1 through 7 as discussed during the telecon May, 20, 2009 between FPL and the NRC.2.3 Request for Relief 32, ASME Code,Section XI, Examination Category B-J, Items B9.11 and B9.21, Austenitic Stainless Steel Piping Welds In Attachment 2, Page 1 of 45, under Section 3.0, Applicable Code Requirement, of the licensee's letter dated February 6, 2009, a Table is included containing certain ASME Code references and requirements.

However, for certain ASME Code,Section XI, Examination Category B-J welds, the licensee states that a Risk-Informed Inservice Inspection (RI-ISI)program was approved by the NRC on March 25, 2004 (ADAMS ML040850587), for St. Lucie, Unit 1. It is unclear how this affects the current request for relief. A review of the Safety Evaluation for the RI-ISI program notes that the Westinghouse Owners Group Topical Report WCAP-14572, Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report, Revision 1-NP-A, February 1999, was used as a basis for the RI-ISI program. This method invokes ASME Code Case N-577, Risk-Informed Requirements for Class 1, 2, and 3 Piping, Method A,Section XI, Division 1, for revised Examination Categories.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 1 Page 3 of 4 2.3.1 State whether any of the piping welds in RR-32 were examined in accordance with the RI-ISI program, and if so, why these welds have not been designated as Examination Category R-A per ASME Code Case N-577, with specific Item numbers associated with potential degradation mechanisms.

FPL Response: With the exception of the three welds examined in 2005 (RC-1 09-FW-2003, RC-103-FW-2000, RC-103-FW-2002), the figures in ASME Section XI, 1989 Edition, No Addenda, define the examination volume. For the welds examined in 2005, the required examination volume was extended to include, as a minimum, the lower 1/3 weld volume and base material for a distance of 1/2 inch beyond each weld toe as required by FPL's approved alternative risk informed program (TAC NO. MC0244).All of the piping welds included in Table 3 of this relief request are included in the risk informed population, but not selected for examination.

The applicable code requirement column in Table 3 includes both the ASME Section XI, 1989 Edition, No Addenda examination category and item number and FPL's approved alternative risk informed examination category and item number.2.3.2 State whether new examination volumes, based on risk, have been applied to these welds, and whether the current limited examinations apply to these new inspection volumes.FPL Response: With the exception of the three welds examined in 2005 (RC-1 09-FW-2003, RC-103-FW-2000, RC-103-FW-2002), the figures in ASME Section XI, 1989 Edition, No Addenda, define the examination volume because they were examined prior to the approval of FPL's alternative risk informed program. For the welds examined in 2005, the required examination volume was extended to include, as a minimum, the lower 1/3 weld volume and base material for a distance of 1/2 inch beyond each weld toe as required by FPL's approved alternative risk informed program (TAC NO. MC0244).

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 1 Page 4 of 4 2.3.3 As revised by NRC e-mail dated June 29, 2009 (ADAMS#ML091800277)

Attachment 3 Describe all nondestructive examinations that were performed on the subject welds during the replacement process, including examinations for construction code acceptance and/or pre-service inspection in accordance with ASME Section XI.FPL Response: For welds RC-109-FW-2003, RC-103-FW-2000, and RC-103-FW-2002, examinations performed during the replacement process included in-process and final surface examinations, and final radiography (RT) in accordance with the requirements of the 1992 Edition of ASME Section Il1. The surface and radiographic examinations were not limited. Final RT and surface examinations performed during the installation, of the welds revealed no recordable or reportable flaws in the examination zone or adjacent to any UT limitations.

The acceptable surface and RT results were obtained prior to the preservice UT examinations being performed.

The UT examinations did not reveal any recordable or reportable flaws in the examination zone or adjacent to any limitations in accordance with ASME Code Section XI, 1989 Edition, No Addenda.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 1 of 52 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Relief Request In Accordance with 10 CFR50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

1 .ASME Code Component(s)

Affected Class 1 and 2 pressure retaining welds in vessel and piping 2. Applicable Code Edition and Addenda The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition, No Addenda as amended by 10CFR50.55a, is the code of record for the St. Lucie Unit 1, 3rd 10-year interval.

ASME Section XI, 1995 Edition with Addenda through 1996, as modified by 1 OCFR50.55a, was utilized for Appendix VIII.3. Applicable Code Requirement-Exam 'Item No. Examination Requirements,: C at 1 ."_ _ _ _ _ ..... .... .." ..... .. .. _ ... ..B-B B2.31 Essentially 100% volumetric examination of weld length.B-D B3.130 Essentially 100% volumetric examination of weld length.Essentially 100% volumetric and surface examination of circumferential welds for >4" nominal pipe size.B-J B9.11 On March 25, 2004, FPL received approval (TAC NO.MC0244) to implement an alternative risk informed program that requires essentially 100% volumetric examination for butt welds in class 1 systems. PSI volumetric examination of essentially 100% of piping welds.Essentially 100% surface examination of circumferential welds for <4" nominal pipe size.B-J B9.21 On March 25, 2004, FPL received approval (TAC NO.MC0244) to implement an alternative risk informed program that requires essentially 100% volumetric examination for butt welds in class 1 systems. PSI volumetric examination of essentially 100% of piping welds.C-A C1.30 Essentially 100% volumetric examination of the weld length.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 2 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I Exam ..... ..".. .Cat 'Item No .Exarmination Requirements Cat. I ..it m No." ... ....C-B C2.21 Essentially 100% volumetric and surface examination of nozzle to shell welds Essentially 100% volumetric and surface examination of C-F-1 C5.11 circumferential welds >3/8" nominal wall thickness for piping>4" nominal pipe size.Essentially 100% volumetric and surface examination of C-F-1 C5.21 circumferential welds >1/5" nominal wall thickness for piping>2" and <4" nominal pipe size.Essentially 100% volumetric and surface examination of C-F-2 C5.51 circumferential welds >3/8" nominal wall thickness for piping>4" nominal pipe size.PSI volumetric examination of essentially 100% of piping welds. On March 25, 2004, FPL received approval (TAC NO.R-A R1.11 MC0244) to implement an alternative risk informed program that requires essentially 100% volumetric examination for butt welds in class 1 systems.As defined by ASME Code Case N-460, essentially 100% means more than 90% of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.4. Impracticality of Compliance Due to the configuration of the welds included within this relief request, it is not possible to meet the examination coverage requirements of the ASME Code,Section XI, 1989 Edition, No Addenda, as clarified by Code Case N-460. Relief is requested in accordance with 10 CFR 50.55a(g)(5)(iii).

These areas were found during the 3rd 10-year inservice inspection interval.When a component has conditions, which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site. This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.

When examined, the welds listed within this request did not receive the required code volume coverage due to their configuration and/or the presence of permanent attachments.

These scanning limitations prohibit essentially 100% ultrasonic examination coverage of the required examination volume.The Tables included in this Relief Request summarize the percent of coverage credited and references specific figures that show the extent of coverage.

St. Lucie Unit 1 L-2009-169 Docket No. 50-335 Attachment 2 3 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Relief is requested from the ASME Boiler and Pressure Vessel Code required volume as identified in Figure IWB-2500-3, 7, and 8 and IWC-2500-1, 2, 4 and 7, as applicable.

5. Burden Caused by Compliance It is not possible to obtain ultrasonic interrogation of greater than 90% of the required examination volume due to interference caused by configuration and/or permanent attachments.

Examinations are performed to the maximum extent possible.

The Ultrasonic (UT) techniques for each weld were reviewed to determine if additional coverage could be achieved.

For the welds listed in the attached Tables, FPL determined that removal of the obstruction was not possible without significant work, increased radiation exposure, and/or damage to the plant. Additional weld preparation by welding or metal removal is a modification of the examination area requiring significant engineering and construction personnel support. Increased radiation exposure and cost would be incurred in order to perform these modifications.

Radiography is impractical due to the amount of work being performed in the areas on a 24-hour basis. This would result in numerous work-related stoppages and increased exposure due to the shutdown of and startup of other work in the areas. The water must be drained from systems where radiography is performed, which increases the radiation dose rates over a much broader area than the weld being examined.

There would be significant burden associated with the performance of weld or area modifications or radiography in order to increase the examination coverage.6. Proposed Alternative and Basis for Use Proposed Alternative

1) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1.

2) Conduct ultrasonic examinations to the maximum extent possible.3) Regular walkdowns by operations personnel and system engineers are performed on Class 2 systems to check for leakage, piping configuration, and/or damage. During outages, system engineers walkdown Class 1 and 2 systems inside containment.

This walkdown is performed to look for system anomalies that could affect plant performance.

Basis When a component has conditions which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site. This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.

St. Lucie Unit 1 L-2009-169 Docket No. 50-335 Attachment 2 4 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 It is not possible to obtain ultrasonic interrogation of greater than 90% of the required examination volume due to interference caused by configuration and/or permanent attachments.

Configuration, permanent attachments and/or structural interferences prohibit 100% ultrasonic examination of Code required volume. Additional ultrasonic techniques are employed where practical to achieve the code-required volume. The attached Tables provide the percent of coverage credited and references specific figures that illustrate the extent of coverage for each weld. The thickness and material is identified for each item within the Tables. The angles, Ultrasonic wave modes (Shear-S or Longitudinal-L) that were employed for examination, and impracticality of compliance are listed for each weld. Arrows and lines on the figures illustrate the UT transducer beam direction and extent of the area examined.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, Class 2, and Class 3 must meet the requirements set forth in the ASME Code to the extent practical within the limitations of design, geometry and materials of construction of the components.

FPL performed the examinations to the extent possible.

Operations personnel and system engineers perform walk downs of every system on a periodic basis looking for leakage or other abnormal conditions.

The extent of examination volumes achieved via surface and/or volumetric examinations, combined with the system pressure tests and system walkdowns, provide assurance of an acceptable level of quality and safety.Category B-B (Table 1)The figures in ASME Section XI, 1989 Edition, No Addenda, define the examination volume. The examinations were performed in accordance with ASME Section XI, 1989 Edition, No Addenda, Appendix I. The coverage credited identified in Table 1 is based upon the requirements of ASME Section XI, Appendix I.The UT techniques for each weld were reviewed to determine if additional coverage could be achieved.

FPL's procedure requires the examiner to make an attempt to achieve complete coverage by using alternative techniques such as using a smaller wedge thus reducing the distance from the exit point to the front of the wedge, changing angles or reducing the search unit element size. Any alternative equipment is required to be in compliance with the limits specified in the procedure.

Alternate techniques were investigated at the time of discovery.

The coverage obtained was the maximum practical.

The volumetric examinations of the items listed in Table 1 did not reveal any recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations in accordance with the ASME Code Section XI, 1989 Edition, No Addenda.

St. Lucie Unit 1 L-2009-169 Docket No. 50-335 Attachment 2 5 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Category B-D (Table 2)The figures in ASME Section XI, 1989 Edition, No Addenda, define the examination volume. The examinations were performed in accordance with ASME Section XI, 1989 Edition, No Addenda, Appendix I. The coverage credited identified in Table 2 is based upon the requirements of ASME Section XI, Appendix I.The UT techniques for each weld were reviewed to determine if additional coverage could be achieved.

FPL's procedure requires the examiner to make an attempt to achieve complete coverage by using alternative techniques such as using a smaller wedge thus reducing the distance from the exit point to the front of the wedge, changing angles or reducing the search unit element size. Any alternative equipment is required to be in compliance with the limits specified in the procedure.

Alternate techniques were investigated at the time of discovery.

The coverage obtained was the maximum practical.

The volumetric examinations of the items listed in Table 2 did not reveal any recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations in accordance with the ASME Code Section XI, 1989 Edition, No Addenda.Category B-J (Table 3)Category B-J items, with the exception of weld RC-1 15-FW-3-500E, were examined in accordance with ASME Section XI, Appendix VIII, 1995 Edition with Addenda through 1996 as modified by 10CFR50.55a.

Appendix VIII, UT examinations were performed utilizing personnel qualified and procedures demonstrated in accordance with the Performance Demonstration Initiative (PDI) program. Weld RC-115-FW-3-500E (cast material) was examined in accordance with ASME Section XI, 1989 Edition, No Addenda, Appendix I.With the exception of the three welds examined in 2005 (RC-109-FW-2003, RC-103-FW-2000, RC-103-FW-2002), the figures in ASME Section XI, 1989 Edition, No Addenda, define the examination volume. For the welds examined in 2005, the required examination volume was extended to include, as a minimum, the lower 1/3 weld volume and base material for a distance of 1/2 inch beyond each weld toe as required by FPL's approved alternative risk informed program (TAC NO. MC0244).The preservice UT examinations of the three welds in 2005 (RC-1 09-FW-2003, RC-1 03-FW-2000, RC-103-FW-2002) were performed to satisfy the requirements of ASME Section XI, 1989 Edition, No Addenda, Paragraph IWB-2200.

One of the welds (RC-109-FW-2003), does not require volumetric examination by the 1989 Edition, No Addenda, of ASME Section XI. However, this weld is included in FPL's approved alternative risk informed program (TAC NO. MC0244) Class 1 population.

FPL's alternative risk informed program only requires volumetric examinations of welds. The risk informed program does not provide guidance for preservice examinations.

Therefore, FPL performed a preservice UT examination of weld RC-109-FW-2003.

St. Lucie Unit 1 L-2009-169 Docket No. 50-335 Attachment 2 6 of 52 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 All of the piping welds included in Table 3 of this relief request are included in the risk informed population, but not selected for examination.

The applicable code requirement column in Table 3 includes both the ASME Section XI, 1989 Edition, No Addenda examination category and item number and FPL's approved alternative risk informed examination category and item number.The Ultrasonic Testing (UT) techniques for each weld were reviewed to determine if additional coverage could be achieved.

FPL's procedure requires the examiner to make an attempt to achieve complete coverage by using alternative techniques such as using a smaller wedge thus reducing the distance from the exit point to the front of the wedge, changing angles or reducing the search unit element size. Any alternative equipment is required to be in compliance with the limits specified in the qualified procedure.

Alternate techniques were investigated at the time of discovery.

In cases where austenitic materials were examined in accordance with Appendix VIII, the coverage credited identified in Table 3 is limited when access can only be obtained from one side. It should be noted that UT was performed through the maximum possible of the Code examination volume; however, the PDI Appendix VIII procedure used is not qualified for the detection of flaws on the far side of the single sided access examinations of austenitic piping welds. The techniques employed for the single sided examinations provided for a best effort examination.

The coverage obtained was the maximum practical.

For Weld RC-1 15-FW-3-500E (cast material) examined in accordance with ASME Section XI, 1989 Edition, No Addenda, Appendix III, the coverage credited identified in Table 3 is limited because access can only be obtained from one side. Appendix III, Paragraph 111-4420 requires "the examination shall be performed using sufficiently long examination beam path coverage of the required examination volume in two-beam path directions." The coverage credited identified in Table 3 for weld RC-1 15-FW-3-500E is based upon the requirements of Appendix Ill, Paragraphs 111-4420 and 111-4430.Because the inservice examinations of the welds included in this relief request were performed prior to the approval of FPL's alternative risk informed program for Class 1 piping, surface examinations were performed as required by ASME Section XI, 1989 Edition, No Addenda. In all cases the surface examinations were not limited and 100 percent of the Code required surface area was examined.

St. Lucie Unit 1 L-2009-169 Docket No. 50-335 Attachment 2 7 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 For welds RC-109-FW-2003, RC-103-FW-2000, and RC-103-FW-2002, examinations performed during the replacement process included in-process and final surface examinations, and final radiography (RT) in accordance with the requirements of the 1992 Edition of ASME Section II1. As allowed by IWB-2200, the ASME Section III final surface examination was used to satisfy the preservice surface examination requirement.

The surface and radiographic examinations were not limited. Final installation RT and surface examinations of the welds revealed no recordable or reportable flaws in the examination zone or adjacent to any UT limitations.

The acceptable surface and RT results were obtained prior to the preservice UT examinations being performed.

The preservice UT examinations did not reveal any recordable or reportable flaws in the examination zone or adjacent to any limitations in accordance with ASME Code Section XI, 1989 Edition, No Addenda.The inservice surface examinations of the items listed in Table 3 did not reveal any recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations in accordance with the ASME Code Section XI, 1989 Edition, No Addenda.The inservice UT examinations of the items listed in Table 3 did not reveal any recordable or reportable flaws in the examination zone or adjacent to any limitations in accordance with ASME Code Section XI, 1989 Edition, No Addenda.Categories C-A and C-B (Tables 4 and 5)The figures in ASME Section XI, 1989 Edition, No Addenda, define the examination volume. The examinations were performed in accordance with ASME Section XI, 1989 Edition, No Addenda, Appendix I. Appendix I, Paragraph 1-2200, directs that the examination of vessels less than or equal to 2 inches thick be performed in accordance with Appendix Ill. Appendix Ill, Paragraph 111-4420 requires "the examination shall be performed using sufficiently long examination beam path coverage of the required examination volume in two-beam path directions." The coverage credited identified in Tables 4 and 5 is based upon the requirements of Appendix Ill, Paragraph 111-4420 and 111-4430 The UT was performed utilizing personnel qualified and procedures demonstrated in accordance with the PDI program. The PDI generic procedure for ferritic piping welds has been qualified for the detection and length sizing of circumferentially oriented flaw indications where single or dual side access is available and the detection of axially oriented flaws where dual side access is available or if the flaw indications are located on the near side of a single side access configuration.

In all cases, only one side of the weld was accessible for examination.

The UT techniques for each weld were reviewed to determine if additional coverage could be achieved.

FPL's procedure requires the examiner to make an attempt to achieve complete coverage by using alternative techniques such as using a smaller wedge thus reducing the distance from the exit point to the front of the wedge, changing angles or reducing the search unit element size. Any alternative equipment is required to be in compliance with the limits specified in the procedure.

Alternate techniques were St. Lucie Unit 1 L-2009-169 Docket No. 50-335 Attachment 2 8 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 investigated at the time of discovery.

The coverage obtained was the maximum practical.

The volumetric examinations of the items listed in Tables 4 and 5 did not reveal any recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations in accordance with the ASME Code Section XI, 1989 Edition, No Addenda.Categories C-F-1 and C-F-2 (Tables 6 and 7)Category C-F-1 and C-F-2 items were examined in accordance with ASME Section XI, Appendix VIII, Supplements 2 and 3, 1995 Edition with Addenda through 1996.Appendix VIII, Supplement 2 and 3 UT examinations were performed utilizing personnel qualified and procedures demonstrated in accordance with the PDI program.The examination figures of ASME Section XI, 1989 Edition, No Addenda, define the examination volume required.The UT techniques for each weld were reviewed to determine if additional coverage could be achieved.

FPL's procedures require the examiner to make an attempt to achieve complete coverage by using alternative techniques such as using a smaller wedge thus reducing the distance from the exit point to the front of the wedge, changing angles or reducing the search unit element size. Any alternative equipment is required to be in compliance with the limits specified in the qualified procedure.

Alternate techniques were investigated at the time of discovery.

In cases where austenitic materials were examined, the coverage credited in Table 6 is limited when access can only be obtained from one side. It should be noted that UT was performed through the maximum possible of the Code examination volume; however, the PDI Appendix VIII procedure used is not qualified for the detection of flaws on the far side of the single sided access examinations of austenitic piping welds. The techniques employed for the single sided examinations provided for a best effort examination.

The coverage obtained was the maximum practical.

Surface examinations were performed of all the items listed in Tables 6 and 7 and were not limited. In all cases, 100 percent of the Code required surface area was examined.The surface and volumetric examinations of all the items listed in Tables 6 and 7 did not reveal any recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations in accordance with the ASME Code Section XI, 1989 Edition, No Addenda.

St. Lucie Unit 1 L-2009-169 Docket No. 50-335 Attachment 2 9 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 7. Duration ,of Proposed Alternative Third Inservice Inspection Interval February 11, 1998 to February 10, 2008 8. References 10CFR50.55a ASME Section III, "Rules For Construction of Nuclear Power Plant Components," 1992 Edition, No Addenda ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, No Addenda ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components," Appendix VIII, 1995 Edition with Addenda through 1996.ASME Section XI, Division 1, Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1" ASME Section V, "Nondestructive Examination," 1989 Edition, No Addenda NRC SER Dated March 25, 2005, "St. Lucie Nuclear Plant, Unit No. 1-Relief Request No. 19 Regarding Risk-Informed Inservice Inspection Program (TAC NO. MC0244)

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 10 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 1 C9ategory B-B Component ID Year~ Applicable Code 'Angle(s)/

ASME Code Component Thickness Of i Requirement and Wave Fig. Impracticality of Compliance iMaterial Exam Coverage-Cre-dite'd Mode 1-SGA-W4 Exam Category B-B OL Head to Stay Cylinder, 7" Item No. B2.31 30S Inservice examination limited Steam Generator 1A Carbon Steel .2005 Fig. IWB 2500-3 45S 1,2 along length of weld due to one Primary Side with Stainless 60S side configuration.

Steel Clad 58% volume coverage St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 11 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I Table 2 Category-B-D Component ID Year Applicabe Code WAngle(s)/,Component Thickness Of Requirement and Wave Fig. Impracticality of Commpiance Material, Exam Coverage ,Credited Mode 1-SGB-W5 Exam Category B-D 0L Inlet Nozzle to Shell Steam 6" Item No. B3.130 30S Inservice examination limited Generator 1 B Primary Side Carbon Steel 2001 Fig. IWB 2500-7(c) 1,3 along length of weld due to one with Stainless 60S side configuration.

Steel Clad 85% volume coverage 1-SGA-W5 Exam Category B-D OL Inlet Nozzle to Shell Steam 6" Item No. B3.130 30S Inservice examination limited Generator 1A Primary Side Carbon Steel 2005 Fig. IWB 2500-7(c) 1,3 along length of weld due to one with Stainless

.60S side configuration.

Steel Clad 85% volume coverage St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 12 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I Table 3 Categor. B.J/R-A -___... _ _meetID-Component ID~ Year Ap'plicable.

Code~ Angle(s)/ASME Code Component Diame;terSchedule Of Requirement and Wave Impracticality of Compliance Malterial.

Exam ~Coverag6 Credited~

Mode ____________

Exam Category B-J/R-A 45S Inservice examination limited by SI-112-1-SW-5 Item No. B9.11/R1.11 60S configuration.

Examination Tee to Pipe (61'-160) 1999 Fig. IWB-2500-8 45L 4 complete of the pipe side and Stainless Steel 60L access is limited from tee side in 81.5% volume coverage area of radius.Exam Category B-J/R-A 45S Inservice examination limited by SI-112-1-SW-6 Item No. B9.11/R1.11 60S configuration.

Examination Reducer to Tee (6"-160) 1999 Fig. IWB-2500-8 45L 5 complete of the reducer side Stainless Steel 60L and access is limited from tee 81.5% volume coverage side in area of radius.Exam Category B-J/R-A Inservice examination limited by Item No. 19.11 /R1.11 configuration.

Examination SI-148-2-SW-4 Fig. IWB-2500-8 60S complete of the pipe side and Pipe to Tee (6"-160) 1999 6 access is not available for Stainless Steel 45L examination from tee side due to 50% volume coverage 60L weld crown and tee configuration.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 13 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 3 Category .B-J/R-A Component ID Year Apcable Code,, Angle(s)/ASME Code Component Diameter-Schedle Of Requiremenf and- -Wave Fig. Impracticality of Compliance S Material <Exam, .Mode.Exam Category B-J/R-A Inservice examination limited by Item Catego. 139. /R1. 1configuration.

Examination is SI-148-FW-5 FigN.IB-2500-8 45S complete of the elbow side and Elbow to Valve (12"-160) 1999 45L 7 access is not available from Stainless Steel 50L valve side due to taper.50% volume coverage Scanning was performed across weld from elbow side.Inservice examination limited by Exam Category B-J/R-A configuration.

Examination is RC-151-FW-1 I Fig. IWB-2500-8 45S complete of the elbow side and Valve to Elbow (12"-160) 1999 45S 8 access is not available from Stainless Steel 45L valve side due to taper.50% volume coverage Scanning was performed across weld from elbow side.Inservice examination limited by Exam Category B-J/R-A configuration.

Examination is S1-148-FW-1 Fig. IWB-2500-8 45S complete of the pipe side and Valve to Pipe (12"-160) 1999 9 access is not available from Stainless Steel 45L valve side due to taper.50% volume coverage Scanning was performed across weld from pipe side.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 14 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I Table 3 Category B-J/R-A I Component ID Year AplcbeCd Angle(§)I ASME Code Component Diameter-Schedule OQf Requirementa:

and Wave ,Fig. Impracticality ofCornpliance, Material ~Exam:. Cover ,age Credited WMde-, Exam Category B-J/R-A Inservice examination limited by 1FW-3-00EIexam C y/R1. 1configuration.

Examination Pump (Cast) to Safe-end RC-115-FW-3-500E Item No. B9.11/R1.11 complete from the safe-end side (Cast) (30-3.5")

2002 Fig. IWB-2500-8 45L 10 and no access from pump side Cast Stainless Steel due to pump configuration.

50% volume coverage Circumferential scan not limited.PSI examination limited by Exam Category B-J/R-A configuration.

Examination RC-109-FW-2003 Item No. B9.21/R1.11 45S complete of the pipe side Valve to Pipe (3-160) 2005 Fig. IWB-2500-8 60S 11 including best effort examination Stainless Steel 70S of valve side through weld 50% volume coverage material.

No access for scanning of the valve side due to weld crown and taper.PSI examination limited by Exam Category B-J/R-A configuration.

Examination RC-103-FW-2000 Item No. B9.11/R1.11 complete of the nozzle side and Tee to Nozzle (4"-160) 2005 Fig. IWB-2500-8 60S 12 scanning limited from the tee side in area of radius. Best effort 84.5% volume coverage examination of tee side in area of radius performed through weld material.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 15 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 3 U ,CategoryB-J/R-A<

Component ID. Ya Applicable Code AngIe(s)/ASME Code Component Diameter-Schedule, Of Requiremnt nand ~ Wave Fig. I mpracticality of Compliance Mateial. Exam Coverage CreditedMoe i.PSI examination limited by Exam Category B-J/R-A configuration.

Examination RC-103-FW-2002 Item No. B9.11/R1.11 45S complete of the pipe side and Tee to Pipe (4"-160) 2005 Fig. IWB-2500-8 60S 13 scanning limited from the tee Stainlessside in area of radius. Best effort 84.5% volume coverage examination of tee side in area of radius performed through weld material.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 16 of 52 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 4-~Category C-A~.Component ID Applicable Codea Angle(s)!ASME Code Component Thicknessf Requirement nd Wave, Fig. -Impracticality of Material Y Exam -Coverage Credited, 'Mode Inservice examination limited by 2-2701 Exam Category C-A weld crown, taper, and flange Flange to Shell, 1.4" Item No. C1.10 45S configuration.

Axial scan from Shutdown Cooling Heat Carbon Steel with 2004 Fig. IWC 2500-1 60S 14 the shell side only.Exchanger Stainless Steel Clad Circumferential scan limited by 36% volume coverage weld crown, taper, and flange configuration.

Inservice examination limited by 2-2702 Exam Category C-A weld crown and tubesheet Body to Tubesheet, 1.4" Item No. Cl.30 configuration.

Axial scan from Shutdown Cooling Heat Carbon Steel with 2004 Fig. IWC 2500-2 60S 15 the body side only.Exchanger Stainless Steel Clad Circumferential scan limited by 40% volume coverage weld crown and tubesheet I I_ configuration.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 17 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 5 Category C-BiU- nt' -".Component ID Year .Applicable Code Angle(s)/,Fig.

Impract.c.lity.of.Complian.e ASME d oO- Requirement and Wave'Material Exam Coverage (Credited Mode Exam Category C-B Inservice examination limited to Outlet Nozzle to Vessel, 2-2742-1 Item No. C2.21 one sided access due to nozzle Shutdown Cooling Heat 1.4" 2004 Fig. IWC 2500-4(b) 45S 16 configuration.

Axial scan from Exchuwnge Carbon Steel with 60S the shell side only.Exchanger Stainless Steel Clad 50% volume coverage Circumferential scan limited by weld taper.Exam Category C-B Inservice examination limited to 2-2741-1 Item No. C2.21 one sided access due to nozzle Shutdown Cooling Heat 1.4" 2004 Fig. IWC 2500-4(b) 45S 16 configuration.

Axial scan from Echuwnge Carbon Steel with 260S the shell side only.Exchanger Stainless Steel Clad 50% volume coverage Circumferential scan limited by weld taper.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 18 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 6-Category C-F-i%) Component'ID Year ."Applicable C~ode> Agle(s)/ASMECodeComponent

Diameter-shedule

Of -Requirrn and;Y jWave' Fig. Impracticality of Compliance Material

Exkam Coverage 0 edited> ~1Mo Inservice examination limited by Exam Category C-F-1 configuration.

Examination SI-213-1-SW-2 Item No. C5.1 1 45S complete of the reducer side Sl-23-1-W-2 temNo. 5.1145Sand best effort examination of Tee to Reducer (6"-120) 2001 Fig. IWC-2500-7(a) 70S 17 teesi erformed athou wl StailessStee 70Ltee side performed through weld Stainless Steel 70L material.

No access for scanning 50% volume coverage from tee side due to weld crown, taper, and tee configuration.

Inservice examination limited by configuration.

Examination Exam Category C-F-1 complete of the pipe side and SI-21 0-FW-5 Item No. C5.21 45S best effort examination of valve Pipe to Valve (4"-80) 2001 Fig. IWC-2500-7(a) 70S 18 side performed through weld Stainless Steel 70L material.

No access for scanning 50% volume coverage from valve side due to weld crown, taper, and valve configuration.

Inservice examination limited by Exam Category C-F-1 configuration.

Examination SI-129-FW-1 Item No. C5.11 45S complete of the pipe side and best effort examination of valve Valve to Pipe (6"-160) 2002 Fig. IWC-2500-7(a) 60S 19 si erformed athrou we StailessStee 60Lside performed through weld Sie Steele coveraLe material.

No access for scanning 50% volume coverage from valve side due to valve taper, and valve configuration.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 19 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 6 Category C-F-1-.Component ID " Year .Applicable Code, Angle(s)/ASME Code 'Component ,Diameter-Schedule Of Requirement and Wave Fig. Impracticality of Compliance Material Exam CoverageCredited 0Mde Inservice examination limited by Exam Category C-F-1 configuration.

Examination SI-1 13-FW-9 Item No. C5.11 45S complete of the pipe side and SI-i 3-F-9 Iem o. C.1 145Sbest effort examination of valve Pipe to Valve (6"-160) 2002 Fig. IWC-2500-7(a) 60S 20 si erformed athrou we StailessStee 60Lside performed through weld Stainless Steel 60L 50% volume coverage material.

No access for scanning from valve side due to valve taper, and valve configuration.

Inservice examination limited by Exam Category C-F-1 configuration.

Examination Sl-212-FW-1A Item No. C5.11 45S complete of the pipe side and SI-212- W-1 Itm N. C51 145Sbest effort examination of tee Tee to Pipe (6"-160) 2002 Fig. IWC-2500-7(a) 60S 21 si efformed athrou wel StailessStee 60Lside performed through weld Stainless Steel 60L material.

No access for 50% volume coverage scanning from tee side due to taper, and tee configuration.

Inservice examination limited by Exam Category C-F-1 configuration.

Examination SI-212-FW-1 Item No. C5.11 45S complete of the pipe side and best effort examination of valve Pipe to Valve (6"-160) 2002 Fig. IWC-2500-7(a) 60S 22 si erformedathrou we StailessStee 60Lside performed through weld Sie Steele coverage material.

No access for scanning 50% volume coverage from valve side due to valve taper, and valve configuration.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 20 of 52 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 6 Category C-F-i 4 Component ID Year Appliable Code Angle(s)/ASME Code Component Diameter-Schedule Of <Requirement and Wavye Fig. Impracticality of Compliance Material?

Exam, CoverageCredited -Mode'Inservice examination limited by Exam Category C-F-1 configuration.

Examination complete of the pipe side and SI-i105-FW-1 Item No. C5.11 4Sbest effort examination of valve Valve to Pipe (6"-160) 2002 Fig. IWC-2500-7(a) 60S 23 si erformed athrou we Stainless Steel 60Lside performed through weld 50% volume coveragematerial.

No access for scanning from valve side due to valve taper, and valve configuration.

Inservice examination limited by configuration.

Examination Exam Category C-F-1 complete of the pipe side and SI-213-FW-2 Item No. C5.11 45S best effort examination of limited Valve to Pipe (6"-120) 2004 Fig. IWC-2500-7(a) 60S 24 amount of valve side performed Stainless Steel 60L through weld material.

No 50% volume coverage access for scanning from valve side due to weld crown, valve taper, and valve configuration.

Inservice examination limited by configuration.

Examination Exam Category C-F-1 complete of the pipe side and SI-21 0-FW-4 Item No. C5.21 4Sbest effort examination of limited Valve to Pipe (4"-80) 2004 Fig. IWC-2500-7(a) 70S 25 amount of valve side performed Stainless Steel through weld material.

No 50% volume coverage access for scanning from valve side due to weld crown, valve taper, and valve configuration.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 21 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 6 4 Category C-F-I ComponentD:

YD-ear Applicable Code Angle(s)/.

ASME Code Component Diameter-SIchdule Of Requirement and, Wave) Fig: Impracticality of Compliance Material 4~>Exam C 4 ove&rage Credited Mode: ___________

Inservice examination limited by configuration.

Examination Exam Category C-F-1 complete of the pipe side and SI-209-FW-2 Item No. C5.21 45S best effort examination of limited Valve to Pipe (3"-160) 2007 Fig. IWC-2500-7(a) 60S 26 amount of valve side performed Stainless Steel 70S through weld material.

No 50% volume coverage access for scanning from valve side due to valve taper and valve configuration.

Inservice examination limited by Exam Category C-F-1 configuration.

Examination SI-21 0-FW-8 Item No. C5.21 45S complete of the reducer side Reducer to Tee (4"-80) 2007 Fig. IWC-2500-7(a) 60S 27 and limited of the tee side in Stainless Steel 70S area of radius. Best effort examination of tee side in area 77% volume coverage of radius performed through weld material.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 22 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 6 Component, ID Year A~pplicabl'e Code Angle(s)!

K ASME Code Component Diameter-Schedule KOf RequiIrement ad Wave, Fig. Impracticality of Compliance viMateria .Exam-. Coverage Credited Mode, Inservice examination limited by configuration.

Examination limited of the elbow side in area Exam Category C-F-1 of intrados.

Examination limited SI-211-11-SW-2 Item No. C5.21 45S of the pipe side in area of Pipe to. Elbow (3"-160) 2007 Fig. IWC-2500-7(a) 60S 28 welded vent line. Best effort Stainless Steel 70S examination from pipe side in 68% volume coverage area of elbow intrados and from elbow side in area of welded vent line performed through weld material.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 23 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Table 7 Category C-F-2 Component.

ID Year ýApplicable Code Angle(s)/?

ASME Code Component Diameter-Scheduled Of. Requiremeri°nd.

Wave Fig Impracticalty of Compliance Material Exam Coverage-Credited -- Mode Inservice examination limited by Exam Category C-F-2 configuration.

Examination from MS-i-i-SW-18 Item No. C5.51 45S the pipe side not limited and no Weldolet to Pipe (8"-160) 2002 Fig. IWC-2500-7(a) 60S 29 access for scanning from Carbon Steel 70S' weldolet side due to weld crown Cro Steele covere and taper. Coverage credited of 75% volume coverage weldolet side from pipe side through weld material.

St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 24 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Weid 5\- Steam Generator Support Steam Generator Primary Side Figure 1 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 25 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 4 30' (1-'6 60'(2-)A/ D/3.Y ---#7-I Stay Cylizxkr SA508 CL 3 Pharv Rl~d SA 509 CL 3///B L C 1-SGA-W4 Figure 2 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 26 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I.,.- 30 (05't 459 (171 Do & 60°lanet Nozzic SA 508 CL 3'PziAay HCLad SA 509 CL 3 3 I l B 1 -SGA-W5/1 -SGB-W5 Figure 3 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 27 of 52 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 SI-li 2-1 7.SW-5 (TYPICAL)CENTERLINE TEE FLOW NOT TOSCALE> :Limited exam area.'due to radius SI- 112-1-SW-5 Figure 4 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 28 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 SI-1 12-1-SW-6 (TYPICAL)CENTERRUNE TEE REDUCER FLOW NOT TO'SCALE` K Limited exam area due to radius S1- 112-1-SW-6 Figure 5 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 29 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 S 1-14i8-2-S'W-4 (TYPICAL)CENTELIAN1E TEE PRPE PLOW NOT1 TO S3CALE SI-148-2-SW-4 Figure 6 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 30 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Ii 148-FW-5 j -YPICA1).CEIKTMRLINE V-3227 ELBO.W 4 FILOW NOT TO SCALE SI-148-FW-5 Figure 7 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 31 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 RC-151-FW-1 (TYPICAL)CEtNTrELIhNE V-3227 ELBOWY.FLO4W NOT TO SCALE RC-151-FW-1 Figure 8 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 32 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 SV148-P*1 (TYPI(AL)PIPE V-3624 4 FLOW NOT TO SCALE SI-148-FW-1 Figure 9 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 33 of 52 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 RC-~115-F1'-3.-50OE(typical)

C*ENTERLINE I 8AFE END//-FLOW 0 NOT TO SCALE RC-1 15-FW-3-500E Figure 10 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 34 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 RC-1I 09-FW-2003 (TYPICAL)OENTERUNE v-1 249 PIPE FLOW NOT TO SCALE RC-1 09-FW-2003 Figure 11 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 35 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 RC-103-FW-2000 (TYPICAL)View @ 180 Degrees Tee Nozzle 2$Degrees-Flow NOT TO SCALE RC-103-FW-2000 Figure 12 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 36 of 52 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 RC-103-FW-2002 (TYPICAL)View @ 180 Degrees Pipe Tee%I Degrees a -Flow NOT TO SCALE RC-1 03-FW-2002 Figure 13 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 37 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 2-2701 (typical)CENTERLIKE FLANGE NOT TO SCALE 2-2701 Figure 14 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 38 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 2-2702(typical)

TUBESHEET NOT TO SCALE 2-2702 Figure 15 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 39 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 2-2742-1(typical) 2-2741-1(typical)

CENTERLINE I I I NOZZLE NOT TO SCALE 2-2742-1/2-2741-2 Figure 16 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 40 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 CENTEIRLIK4E REDUICER 41- FLOW NOT TO SCALE SI-213-1-SW-2 Figure 17 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 41 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 Sl-,2 I O-FW-65 (-TYPICAL)

CENfTI'LNE r -PIPE FLOW NOT TO 5CALE SI-21 0-FW-5 Figure 18 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 42 of 52 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 So-929-FW-1L (TY'PIC~AL?.

CENIaEALINKE FLOW NOT TO SCALE SI-1 29-FW-1 Figure 19 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 43 of 52 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I SI-113-FW-9 (TYPICAL)Centerline V-3114 I * --................

FLOW -NOT TO SCALE SI-1 13-FW-9 Figure 20 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 44 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I Slll-212'ý-FW-*

A- (Th'PIOAL)

CE CT NLINTE RV TEE FULW NOT) TO- SO-ALE'SI-212-FW-IA Figure 21 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 45 of 52 St. Lucie Unit I THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I SI721 2-F:W-1 (TYPICAL)CENTERLINE rf PIPE-V-3656 FLOW NOT TO -SCALE SI-212-FW-1 Figure 22 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 46 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 S1-105-7FW-1 (TYPICAL)CENTERLINE V-3656 FLOW NOT TO SCALE SI-1 05-FW-1 Figure 23 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 47 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 SI-21 3ý-FW-2 (TYPICAL)-

CENTERLINE V-3654 PIPE FLOW*1 NOTTO SCALE SI-213-FW-2 Figure 24 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 48 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I SI-21 Oý-FW-4 (TYPICAL)CENTERLINE V-3653 PIPEFLOW NOTTO SCCALE SI-21 0-FW-4 Figure 25 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 49 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I sYF209-FW-2 (TPICAL)CENTERLINE V-3405 PIPE 4 FLOW MMN=MMw=4=wMNwpr"ý NOT TO SCALE SI-209-FW-2 Figure 26 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 50 of 52 r St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1 1-2b O-FW-8,(TYPICAN I CENTERILINE REDUCER FLOW'I NOT TO SCALE Limited 6xam area due to radius Linfitedrexamr area,-due to Fa dius.SI-21 0-FW-8 Figure 27 ID St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 51 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION I WELDED VENT LINE SI-21 1-11!-SW-2 (TYPICAL):'

CENTERLINE, PIPE ELBOW FLOW b NOT TOSCALE 6 FROM ZRP 6;5 FROM ZRP!NTkADos (OF ELBOW 10.5" FROM XTRADOS OF ELBOW-ZRP 4" FROM ZRP SI-211-11-SW-2 Figure 28 St. Lucie Unit 1 Docket No. 50-335 L-2009-169 Attachment 2 52 of 52 St. Lucie Unit 1 THIRD INSPECTION INTERVAL RELIEF REQUEST NUMBER 32, REVISION 1.MS-i -i-Sw-i 8 CAL)CENTERLINE WELDOLET PIPE;-,FLOW ftr N OT TO SCALE MS-1-1-SW-18 Figure 29