ML17228B126

Technical Evaluation Rept on Second 10-Year Interval Insp Program Plan.

ML17228B126
Person / Time
Site:	Saint Lucie
Issue date:	03/31/1995
From:	Beth Brown, Feige E External (Affiliation Not Assigned), IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC (Affiliation Not Assigned)
Shared Package
ML17228B124	List: ML17228B126
References
CON-FIN-L-2556 INEL-94-0147, INEL-94-147, NUDOCS 9505090253
Download: ML17228B126 (57)

Text

INEL-94/0147 Technical Evaluation Report on the Second 10-year Interval lnservice Inspection Program Plan:

Florida Power and Light Company, St. Lucie Nuclear Plant, Unit 2, Docket Number 50-389 B. W. Brown E. J. Feige K. W. Hall A. M. Porter Published March 1995 idaho National Engineering Laboratory Materials Physics Lockheed idaho Technologies Company Idaho Falls, lrlaho 83416 Prepared for the Division of Engineering Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Idaho Operations Office Contract DE-AC07-94ID,1 3223 FIN No. L2556 (Task Order 20) e505090a5S e50504 PDR ADQCK 05000389 PDR

ABSTRACT This report presents the results of the evaluation of the St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval Inservice Inspection Program Plan, Rev'sion 0, submitted August 4, 1993, including the requests for relief from the American Society of Hechanical Engineers (ASHE) Boiler and Pr'essure 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 Inspection 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.

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

SUMMARY

I The licensee, Florida Power and Light, has prepared the St. Lucie Nuclear Plant, Unit 2, Second 10-Year 1'nterval 1'nservice Inspection Program Plan, Revision 0, to meet the requirements of the 1989 Edition. The second 10-year interval began August 8, 1993.

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. Included in the review were the requests for relief from the ASNE Code Section XI requirements 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.

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.

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 ASHE Code, no deviations from regulatory requirements or commitments were identified in the St. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval 1'nservice Inspection Program Plan, with the exception of Requests for Relief 14 and 16.

CONTENTS ABSTRACT S UHHARY o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

1. INTRODUCTION 1

2. EVALUATION OF INSERVICE. INSPECTION PROGRAM PLAN 4 2.1 Documents Evaluated 4 2.2 Compliance with Code Requirements . . . . . . . . . . . . . . . . 4 2.2. 1 Compliance witfi Applicable Code Editions . . . . . . . . . . 4 2.2.2 Acceptability of the Examination Sample . . . . . . . . . . 4 2.2.3 Exemption Criteria . 5 2.2.4 Augmented Examination Commitments, . . . . . . . . . . . . . 5 2~3 Concl us 1 ons 7

~ 4 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

3. 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 Bl.ll, B1.12, 61.21, B1.22, 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 B3.90 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, Examinat'ion Category B-D, Item 63. 110, Full Penetration Nozzle-to-Vessel Welds in the Pressurizer . . . . . . . . . . . . . . . 14

3. 1.3 Heat Exchangers and Steam Generators (No Relief Requests)

3. 1.4 Piping Pressure Boundary . . . . . . ., . . . . . . . . . . . 17

3. 1.4. 1 Request for Relief 4 (Part 1 of 2), -Examination Category B-J, Items B9.12 and B9.22, Examination of Class 1 Longitudinal Piping Welds . . . . . . . . . . . 17 3.1.4.2 Request for Relic'f 5, Examination Categories B-F, Item No. B5. 130 and Examination Category B-J, Item No. B9. 11, Examination of Class 1 Pressure Retaining Dissimilar Metal Welds 20

3. 1.4.3 Request for Relief 6, Examination Category B-J, Items B9.11, B9. 12, and B9.31, Examination of Class 1 Pressure Retaining Welds in Piping . . . . . . 23

3. 1.4.4 Request for Relief 15, Category B-J, Item B9. 11 Examination of Inlet and Outlet Nozzle to 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 Nozzl e-to-Vessel Wel ds 30 3~2~2 Pl ping 32 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 Request 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 3.2.3 Pumps ( No Relief Requests) 3.2.4 Valves (No Relief Requests)

3.2.5. General 37 3.2.5.1 Request for Relief 14, IWB-2412 and IWC-2412, Inspection Program B Percentage Requirements, IWB-2420 and IWC-'2420, Sequence of Component Examinations Established During the First Inspect ion I nterval 37 3.2.5.2 Request for,Relief 16, Paragraph 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 46 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 (Ro Relief Requests)

4. CONCLUSION 49

5. REFERENCES ~ ~ ~ ~ ~ ~ ~ 50

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 50-311

l. 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 (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components (Reference 2), to the extent practical within the limitations of design, geometry, and materials of 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 limitation's 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 Program Plan, Revision 0 (Reference 3), to meet the requirements of the 1989 Edition of the Code. The 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.

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

'onsideration 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 eval,uate 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'rogram Plan, Revision 0, submitted August 4, 1993, was reviewed, including the requests for relief from the ASME Code Section XI requirements 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 letter 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 extent of aug'mented exaa~"..";tions being performed;

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

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

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,'s 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 report. Unless otherwise stated, references to the Code refer to the ASHE Code, Section XI, 1989 Edition. Specific inservice test (IST) programs for pumps and valves are being evaluated in other reports.

2. EVALUATION OF INSERVICE INSPECTION PROGRAN PLAN 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 Com liance with Code Re uirements 2.2. 1 Com liance with A licable 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 I'nkerval ISI Program Plan, Revision 0, to meet the requirements of 1989 Edition.

2.2.2 Acce tabilit of the Examination Sam le Inservice,yolumetric, surface, and visual examinations shall be performed on ASHE Code Class 1, 2, and 3 components and their supports using sampling schedules described in Section XI of the ASHE Code and 10 CFR 50.55a(b). The sample size and weld selectioh have been

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

For Class 2 piping welds, it was recommended 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 Heat 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 recommended that the ISI program include volumetric examination of a sample of thin-wall pipe welds in portions of the subject systems that are otherwi'se excluded from examination.

2.2.3 Exem tion 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 u mented Examination Commitments In addition to the examinations specified in Section XI of the ASME Code, the licensee has committed to perform the following augmented examinations:

(a) Volumetric and surface examination r'" the Reactor Coolant Pump Flywheels in accordance with Regulatory Guide l. 14 (Reference 7);

(b) Reactor pressure vessel examinations, including the closure head, in accordance with Regulatory Guide 1. 150, Rev. 1 (Reference 8);

e

I (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);

(d) Per LER 50-389-93-04, FPL committed to perform visual (VT-1) examinations of the Alloy 600 instrumentation nozzles during the second insp'ection,interval for evidence of leakage; (e) Feedwater nozzle examinations per NRC Bulletin 79-13 (Reference 10). Continuous enhanced ultrasonic examinations starting at the Feedwater Nozzle ramp and extending out to a 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 HEB 3-1, High Energy Fluid Systems, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment, on welds that fall within the following criteria:

1. Code Category C-F welds beyond the Code class boundary (HSIV) 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 (HSIV) 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 containment isolation valves (100K volumetric examination).

2.3 Conclusions Based on this review of the SC. Lucie Nuclear Plant, Unit 2, Second 10-Year Interval lSI Program Plan, Revision 0, no deviations from regulatory requirements or commitments have been identified (relief requests are reviewed in the next section). However, for Class 2 piping welds, it is recommended that the licensee augment the examination of the Residual Heat Removal, Emergency Core Cooling, and Containment Heat Removal Systems by volumetric examination of a sample of welds excluded from selection based on wall thickness.

3. EVALUATION OF RELIEF REQUESTS The requests for relief from the ASNE Code Section XI requirements that the licensee has determined to be impractical for the second 10-year inspection C

interval are evaluated in the following sections.

3.1 .Class .1 Com onents

3. 1. 1 Reactor Pressure Vessel

3. 1. 1. 1 Re uest for Relief 1 Examination Cate or 8-A Items 81. 11 81.12 81.21 81.22 81.30 and 81.40 Pressure-Retainin Welds in the Reactor Pressure Vessel Examination Cate or B-.D Item 83.90 Full Penetration Nozzle Welds in thh Reactor Pressure Vessel Code Re uirement: Section XI, Table IW8-2500-1, Examination Category B-A, Items 81.11 and 81.12 require that essentially 100%

of all circumferential and longitudinal reactor pressure vessel shell welds be volumetrically examined as defined in Figures IWB-2500-1 and IWB-2500-2. Items 81.21 and 81.22 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 81.30 requires that essentially 100% of the reactor pressure vessel shel,l-to-flange weld be volumetrically examined as defined in Figure IWB-2500-4. Item 81.40 requires that essentially 100%

of the head-to-flange weld be volumetrically examined as defined in Figure IWB-2500-5. Examination Category B-D, Item 83.90 requires the examination of all nozzle-to-vessel welds as defined in Figure IWB-2500-7.

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Licensee's Code Relief Re uest: The licensee requested relief from the Code-required 100% volumetric coverage of the following welds:

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at,i,'o';,"'A'r'ea;:.".,:-",.;,'ottom Head Peel Limited along length of Segment Meld: weld near flow skirt-lower 101-154A 65% head attachment 101-154 B 64%

101-154C 66%

101-154D 64%

101-154 E 66%

101-154F 64/

Lower Shell-to- 88% Limited along length of Intermediate Shell weld near the vessel Circ. Weld 101-171 surveillance ca sules Intermediate Shell 81% Limited along length of Long. Weld 101-124C weld near the vessel surveillance ca sules Upper Shell 87% Limited at intersection Longitudinal Weld with the adjacent outlet 101-122A nozzle inte ral extension Upper Shell-to-Flange 67% Limited above the weld by Circumferential Weld the flange configuration 101-121 Outlet Nozzle-to- 28% Shell-side examination is Shell Weld 105-121A limited by the integral extension Outlet Nozzle-to- 28% Shell-side examination is Shell Weld 103-121B limited by the integral extension Flange to Torus Weld 75% Limited at intersection of 101-101 flange flex radius; shroud, shroud hold down lugs, and head lifting lu s Dome Weld 102-101 46/ Limited'y location of shroud and at intersection of adjacent Meld 101-101 and shroud

i censee's Basi s for Re uestin 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 wave scans to compensate for limitations encountered in 45'hear the near surface and those due to geometric shadowing. Those examination volumes which receive other than 90% of the ASME Code required coverage are identified within this Request for 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'raphically 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

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

10

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 coverage obtainable from the seal surface examinati'on. 'lso shown is the tapered surface where transverse examination's prohibited."

"RPV LONGITUDINAL SHELL WELDS "The 60'xamination 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 NOZZLE 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.

"The Closure Head Dome weld 102-101 is limited due to instrument nozzles, penetrations, and CEDH's, see Figure 1.13.

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

Licensee's Pro osed Alternative Examination (as stated):

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

"3) Conduct Hechanized Ultrasonic Examinations to the extent practical.

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

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 perform the examinations to the extent required by the Code. 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.

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 result, reasonable assurance of operational readiness has been provided.

Conclusions:

Based on the above, it is concluded that complete volumetric examination is impractical to perform. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), it is recommended that relief be granted as requested.

3. 1. 1.2 Re uest for Relief 17 Examination Cate or B-0 Items B3.90 and B3. 100 Examination Schedulin Re uirements of Reactor Pressure Vessel Nozzle-to-Vessel Melds and Inner Radius Sections Code Re uirement: 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 501. (credited) of the nozzles shall be 12

examined by the end of the first inspection period and the remainder by the end of the inspection interval.

Licensee's Code Relief Re uest: The licensee requested relief from the Code requirement to examine at least 25% of the vessel-to-nozzle welds luiing the first examination period.

Licensee's Basis for Re uestin 'elief (as stated):

"During the First 10 Year interval the vessel-to-nozzle and nozzle inner radius sections, that were examined during the first period, as identified above, were reexamined during the second period, in conjunction with the automated Reactor Pressure vessel examinations.

"The intent of the ASHE 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 Pro osed Alternative Examination (as stated):

"Conduct 100% Nozzle-to-Vessel Examinations during Second Examination Period, in conjunction with the remaining Reactor Vessel examinations."

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 licensee results in the requirement to employ a automated 13

examination device two times in one interval. It has been previously determined that, for Examination Category B-D, deferral of the first period examinations is acceptable provided that these examinations are completed within the same period in 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 B3.90 and B3.100, in the second period of the second 10-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.

Conclusion:

The INEL staff has reviewed the licensee's request for relief from Code scheduling requirements. It is concluded that the proposed alternative, schedule provides an acceptable 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.

3.1.2.1 e uest for elief 3 Examination Cate or B-D Item B3.110 Full enetration Nozzle-to-'Vessel Welds in the Pressurizer Code Re uirement: Examination Category B-D, Item B3.110 requires 100X volumetric examination of all pressurizer nozzle-to-vessel welds as defined in Figure IWB-2500-7 (as applicable).

censee's Code Relief Re uest: The licensee requested relief from the Code-required 100X coverage of the following nozzle-to-vessel welds.

14

<.,':,:,'.'Id'en'ti.'fi'c"at'.i o':.".

~Co v'erage4P):;"', g:;';Descriptio'n"'of;-':L'imi'tations-j';-':.

Spray Nozzle- 70% One Side Proximity of other nozzles to-Upper Head that are directly opposite on Weld 103-601 scan line Safety Valve 80% One Side Proximity of other nozzles Nozzle-to-Upper (60'ngle), that are directly opposite on Head Weld 95% One Side scan line.

108-601-'A 45'n le Safety Valve 70% One Side Proximity of other nozzles Nozzle-to-Upper (60'ngle), that are directly opposite on Head Weld 85% One Side scan line 108-601-B 45'n le Safety Valve 70% One Side Proximity of other nozzles Nozzle-to-Upper (60'ngle), that are directly opposite on Head Weld 95% One Side scan line 108-601-C 45'n le 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 Weld 105-651 (60'ngle), attachments 100% One Side 45'n le Licensee's Basis for Re uestin 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.

"NOZZLE - 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'an not be accomplished.

"PRESSURIZER SURGE NOZZLE "Figure 3 identifies the 60'ngle 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

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

15

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

Licensee's Altern'ative Examination (as stated):

"1) Periodic System Pressure tests.

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

Evaluation: The Code requires that all pressurizer nozzle-to-shell welds be 100% volumetrically examined. The sketches provided show that the subject nozzle welds have limited scan areas as the result of physical obstructions (i.e. adjacent nozzles and heater attachments). Therefore, it is impractical to examine the 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 one 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 examination of the subject pressurizer nozzle welds to the. extent practical obtaining one-sided coverages ranging from 60% to 100% coverage. Based on the coverage obtained, it is reasonable to conclude that degradation, if present, would be detected. As a result, reasonable assurance of structural integrity is provided.

==

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)(i), it is recommended that relief be granted as requested.

16,

3. 1.3 Heat Exchan ers and Steam Generators (No relief requests)

3. 1.4 Pi in Pressure Boundar

3. 1.4. 1 Re uest for Relief Number 4 Part 1 of 2 Examination Cate or B-J Items B9. 12 and B9.22 Examination of Class 1 Lon itudinal

~PI i Il 1d Code Re uirement: Examination Category B-J, Item B9. 12 requires 100% volumetric and surface examination of Class 1 longitudinal piping welds M 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 to be examined by Examination Categories B-F and B-J.

Item B9.22 requires a 100% surface examination of the longitudinal piping welds <4 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 to be examined by Examination Categories 8-F and B-J.

Licensee's Code Relief Re uest: The licensee requested relief from performing the Code-required surface and/or volumetric examinations of al-1 Class 1 piping longitudinal welds to the extent required by Code.

Licensee's Basis for Re uestin Relief (as stated):

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

"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

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

"4. Results of previous weld inspections through out the industry 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. Lon~itudinal 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 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 welds. adjacent'ircumferential "7. The man-rem exposure and cost associated with the inspection 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 radiation exposure'and 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.

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

"Circumferential welds with intersecting longitudinal welds will 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 of quality and safety."

18

~ ~ ~"

Evaluation: The Code requires. surface and/or volumetric examination of at least a pipe diameter length but not more than 12 inches of each longitudinal weld intersecting the circumferential welds required to be examined by Examination Categories B-F and B-J. In the response to the NRC's RAI, the licensee stated that the request for relief includes'oth surface and volumetric examination of the length of longitudinal weld to 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 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 of the surface examinations. The licensee maintains that the potentially critical portion of the longitudinal welds, the portion that intersects the circumferential weld, will be examined in conjunction with the circumferential welds.

The licensee's proposed alternative is to enhance the volumetric examinations of that length of longitudinal weld that falls within the circumferential weld examination volume by performing both transverse and parallel scans. The circumferential welds

~

with intersecting longitudinal welds will be noted to document the extent of the examination. The extent of surface and volumetric examinations performed in conjunction with the associated circumferential welds, coupled with the system pressure tests, should provide an acceptable level of quality and safety.

Conclusions:

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

19

@hi l I I ~ Vt)pP'A')),4 ~ \~ ) ~ t'(I' ll I

3. 1.4.2 Re uest for Relief Number 5 Examination Cate or B-F Item B5. 13 and Examination Cate or B-J Item B9. 11 Examination of Class 1 P essure'-Retainin Dissimilar Metal Welds Code Re uirement: Examination Category B-F, Item B5. 130 requires 100/o volumetric and surface examination for circumferential piping welds of nominal pipe size 4 inch and larger as defined by Figure IWB-2500-8.

Examination Category B-J, Item B9.11 requires 100% volumetric and surface examination, as defined by Figure IWB-2500-8, of dissimilar metal butt welds of nominal pipe size 4 inch and larger.

Licensee's Code Relief Re uest: The licensee requested relief from the Code-required volumetric coverage for Examination Category B-F, Item B5.130 and Examination Category B-J, Item B9. 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.

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-115-1501-771-A 0% from safe end 2A2 RCP Outlet field weld, Safe 100% from pipe End to O Meld RC-115-701-771 30% from safe end 2B1 RCP Inlet shop weld Elbow-to- 100% from elbow Safe End Meld RC-115-1501-771-B 0% from safe end 2B1 RCP Outlet field weld, Safe 100% from elbow End to Pi e Meld RC-121-5 0% from safe end 2A1 RCP Inlet shop weld Elbow-to- 100% from elbow Safe End Weld RC-112-1501-771-C 20% from safe end 20

2B2 RCP Inlet shop weld Elbow-to- 100% from elbow Safe End Weld RC-124-1501-771-D 0% from safe ehd 2B2 RCP Inlet shop weld Safe End- 100% from pipe to-Pi e Meld RC-124-1301-771 30% from safe end Licensee's Basis for Re ues'ti'n Relief '(as stated):

"Configuration and permanent attachments prohibit 100% ultrasonic examination coverage of the'required examination volume. The attached Table'ummarizes 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-351-CFSH 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. Host of the OD 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 liftoffoccurs, causing substantial gaps in the beam coverage."

"OUTLET "The outlet safe-end conf~ .~"ation Figure 2 tapers gently 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

'possible from one side only."

"SUPPLEHENTARY TECHNI(UE Figures, tables and attachments are not included with this evaluation.

21

~ ~ '-'~ ~ i w ~ < ~ ~ ~ ~ ~ r ~ w>>% ~ ~ ~. i ~ w ~ ~sl ~ ~ - ~ V",v', ~ ~

"FPL has employed a full scale 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 of the shop weld welding parameters considered a'uplication necessary for this application. (See Figure 3)

"This mock-up is considered invaluable toward the understanding and the qualification of acoustica3 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 Examination Coverage Table) coupled with the system pressure tests provide assurance of an acceptable level of quality and safety."

Licensee's Pro osed Alternative Examination (as stated):

"I) 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

The licensee performed the volumetric examinations to the maximum extent practical obtaining minimum, one-sided coverages of 20% to 100%. For several examinations, the licensee obtained .20% and 30% coverages from the second'ide, 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 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)(i), it is recommended that relief be granted as requested.

3. 1.4.3 Re vest for Relief Number 6 Examination Cate or B-J Items B9. 11 B9. 12 and B9.31 Examination of Class 1 Pressure-Retainin Welds in Pi in Code Re uirement: Examination Category B-J, Items B9. 11 and B9. 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.

Lice'=~o.'s Code Relief Re uest: 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 1 welds listed below.

23

.v .): t w%r ... > 9 qy:r

,;:Vj~:Exami'nat'i on',"Area~/~!:.'

'N::.':'..'. <<(8,':>:"":,;>~gy:: '~k

i at i ons . '.. transition 'oop 2A Hot Leg, 100% pipe side Nozzle OD Elbow-to-Inlet 30% from nozzle taper Nozzle Weld RC-123- . side 201-258 B Hot Leg Branch 100% one side Branch connection Connection Weld only configuration RC-123-205-771 Su lemental Loop 2A2 100% both welds Scan limited from nozzle 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 RC-115-1, RC-115-401-258-B Loop 2A2 33% Scan limited to length of Intermediate Cold 4" due to pipe support Leg Longitudinal Seam Weld RC-115-109-722-LS-A RCS Loop A 2A2 RCP 91% Longitudinal seam to Reactor Vessel obstructed by welded Longitudinal Seam attachment (lugs) on weld Weld RC-115-103-722- centerline LS-A RCS Loop B 2B1 RCP 59% Longitudinal 'seam 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 enetration Loop 2A1 100% from pipe Scan limited from nozzle Intermediate Cold side side due to nozzle OD Leg Steam Generator 30% from nozzle transition taper Nozzle-to-Extension side (shop weld) and Extension-to-Elbow (field weld) Meld 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 confi uration Valve V-3227 to Pipe , 88% pipe side Limited by pipe-to-valve Weld SI-148-FW-5 0% valve side confi uration 24 <','>>>> <h&,j <<: Qjg'.(aP(>>>>>><$ .>>>>< g<>>>>y: ", ' < ~>>"" g-,;5<,,:,E>>xa'm'ina<ti on:.Ar e>>a-,'.;.',":;:,;:.:.'..! ~,"".:,'::::::.,::-':.:;"".:,:.':,":L'.imit'at i ons'~:;:~"::.""'imited Pipe to Valve V-3624 100% pipe side by pipe-to-valve Weld SI-148-FW-1 0% valve side confi uration Pipe to Valve V-3617 81% pipe side Limited by pipe-to-valve Weld SI-149-FW-4 0% valve side confi uration Pipe to Valve V-3614 100% pipe side Limited by pipe-to-valve Weld SI-149-FW-1 0% valve side confi uration Valve V-3237 to Pipe 100% pipe side Limited by pipe-to- valve Weld SI-150-FW-4 0% valve side confi uration Valve V-3247 to Pipe 45% pipe side Limited by pipe-to-valve Weld SI-151-FW-4 20% valve side confi uration Pipe to Valve V-3644 63% pipe side Limited by pipe-to-valve Weld SI-151-FW-1 0% valve side confi uration Valve V-3261 to Pipe 63% pipe side Limited by pipe-to-valve Weld SI-518-FW-1 38% valve side confi uration Licensee's Basis for Re uestin 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'ummarizes 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 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 'igures and Tables are not included in this report. 25 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 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 1-icensee 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 as requested.

3.1.4.4 Re uest for Relief Number 15 Cate or 8-J Item 89.11 Examination of Inlet and Outlet Nozzle to Pi e Transition Welds Code Re uirement: Examination Category B-J, Item B9.11 requires 100%

volumetric and surface examination of circumferential piping welds of nominal pipe size 4 inch and larger per Figure IWB-2500-8.

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

26

401-128-A 42" Outlet Nozzle to Extension RC-114-1 42" Outlet Nozzle Extension to Pi e 201-128A 30'nlet Nozzle to Extension RC-112-6 30" Inlet Nozzle Extension to Elbow 201-128-B 30" Inlet Nozzle to Extension RC-121-6 30" Elbow to Inlet Nozzle .Extension 401-128-B 42" Outlet Nozzle to Extension RC-123-1 42" Outlet Nozzle Extension to Pi e 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 Re uestin Relief (as stated):

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.

II 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 less expensive way of examning 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 cost of insulation removal, erecting scaffolding, and not to mention the increased time of the examiner to conduct the surface examination.

II 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 Hagnetic Particle examination method, which is limited to defects open to, or just below the

surface. The alternative volumetric (ultrasonic) examination method proposed by FPL, will not only examine the surface area, 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 during the last inspection interval.

"5. FPL has over 70 years of operating expirience with pressurized water reactors, between our four op~rating plants. These welds 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. Conduct a Full Vee (ultrasonic) examination technique to effectively examine the outside surface of the Reactor Vessel Nozzle Pipe to Transition welds, from the Inside surface, in lieu of the surface examination as defined in the proposed attachment to this request.

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

"3. The extent of examination required and the proposed examination technique, coupled with the system pressure tests provides assurance of an acceptabl'e level of quality and safety."

Evaluation: The Code requires 100% volumetric and surface 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 with little or no increase in the level of quality and safety. The licensee's proposed alternative to the surface examination is a full-vee ultrasonic technique to interrogate the entire volume of the weld from the inside surface of the pipe. This technique has been 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 allowed by paragraph IWA-2240, "Alternative Examinations", of ASNE Section 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

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)(i), it is recommended that the proposed alternative be authorized.

3. 1.5 Pum Pressure Boundar (No relief requests) 3.1.6 Valve Pressure Boundar (No relief requests)

3. 1.7 General (No relief requests) 3.2 Class 2 Com onents 3.2.1 Pressure Vessels 3.2. 1. 1 Re uest for Relief 8 Examination Cate or C-A Item C1.10 Examination of Class 2 Shutdown Coolin Heat Exchan er Shell Welds Code Re uirement: Examination Category C-A, Item Cl.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 Re vest: 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.

Licensee's Basis for Re uestin 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 volume 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

Licensee's Pro osed Alternative Examinatio (as stated):

"1) Conduct examinations to the extent practical per IWC-2500-1 "2) Perform System Pressure Test as required by IWC-2500-1" Evaluation: 'The Code requires that the subject welds receive a 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 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 detected. Thus, reasonable assurance of operational readiness has been provided.

Conclusions:

Complete, Code-required volumetric examination is 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)(i), it is recommended that relief be granted as requested.

3.2.1.2 Re uest for Relief 9 Examination Cate or C-8 Item C2.21 Examination of Class 2 Steam Generator Nozzle-to-Vessel Welds Code Re uirement: 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 I/2 inch wall thickness as defined in Figure IWC-2500-4(b).

30

icensee's Code Relief Re uest: The licensee requested relief from volumetric examination of the Code-required volumes for the following welds.

~',j~Examinat;i,onPA're'a~;:;,';

Steam Nozzle to 100% one side Examination limited by Head Weld configuration to one side No. SG-2A-105-201 Feedwater Nozzle 100% due to full Examination limited by to Shell Weld vee (one sided) configuration and welded No. SG-2A-111-221 98% one sided attachment Licensee's Basis for Re uestin Relief (as stated):

"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. The attached Table summarizes the percent of coverage achieved and references the specific Figure within the relief providing the extent of the limitations.

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

Licensee's Alternative Examination (as stated):

"1) Periodic System Pressure tests per IWC-2500-1 "2) Perform to the extent practical the volumetric and surface examinations as required by IWC-2500-1."

Evaluation: The Code requires that the subject welds receive a 100% surface and volumetric examination. It appears that the Feedwater nozzle-to-shell weld co~,.".ge is essentially 100%, not requiring relief. For the nozzle-to-head weld, due to configuration complete volumetric Code coverage is impractical.

To obtain complete volumetric coverage, design modifications or

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

31

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 Hain 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)(i),'it is recommended that relief be granted for the Hain Steam nozzle-to-head weld as requested. In the case of the Feedwater nozzle-to-shell weld, relief is not required.

3.2.2 ~Pi in 3.2.2.1 Re vest for Relief 4 Part 2 of 2 Examination Cate pries C-F-I and C-F-2 Items C5. 12 C5.22 C5.42 C5.52 C5.62 and C5.82 Examination of Class 2 Lon itudinal Pi in Melds Code Re uirement: Examination Categories C-F-I 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 Re uest: 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

Licensee's Basis for Re uestin 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.

"2. Longitudinal piping welds undergo heat treatment in the shop, which enhances the material properties of the weld and reduces 'he 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 "4. Results of previous weld inspections through out the industry 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 any particular degradation mechanism.

"6. The only ar eas 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 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 I 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 technical benefit to performing inservice inspections on any, longitudinal piping welds. In addition, there are substance;.~i radiation exposure and cost considerations associated with these inspections."

Licensee's Alternative xamination (as stated):

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

33

"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.

"Circumferential welds with intersecting longitudinal welds will 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 of quality and safety."

Evaluation: The Code requires surface and/or volumetric examination, as applicable, of the longitudinal piping welds for 2.5T from the intersection with the applicable circumferential weld. In the response to the NRC's RAI, the licensee clarified that the request for relief included both surface and volumetric examination of the length of longitudinal weld required by Code.

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

The licensee's proposed alternative to the surface and/or volumetric examination of the longitudinal welds to the extent required by the Code is to perform a surface examination and enhanced volumetric examination that includes both transverse and parallel scans for the length of longitudinal weld that falls within the circumferential weld examination volume. The circumferential welds with intersecting longitudinal welds will be noted to document the extent of the examination. The extent of surface and volumetric examinations performed, coupled with 34

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

Conclusions:

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

3.2.2.2 Re uest for Relief 0 Examination Cate pries C-F-1 and C-F-2 Items C5. 11 5. 12 and C5.81 Examination of Class 2 Pressure-Retainin Welds in Pi in Code Re uirement: Examination Category C-F-1, Items C5. 11 and C5. 12 require 100% surface and volumetric examination of Class 2 piping welds equal to or greater than 3/8 inch wall thickness in piping greater than 4 inch nominal pipe size.

Examination Category C-F-2, Item C5.81 requires 100% surface examination of pipe branch connections of branch piping equal to or greater than 2 inch nominal pipe size.

Licensee's Code Relief Re uest: The licensee requested relief from the surface and volumetric examination requirements of the Code for the following welds.

P.P:; Pg<'.)v;.~. @<<<<+ P<'<<(< hg><<<<<vs<

<< < <<< (KO Q)<o< x'g..<>

< '""~¹j"~gk~%'Ã<~~)%T ""'k WN '>..":

/

':)De'seri"ti on',"of::"";Limit at i ons a < <<;

,~;-:,.:h':Examinati ori':Area~@~>.;"'"::;Cover'a" e;> ~

Pipe Longitudinal Examination limited by Seam Melds welded attachment NS-I-FW-I-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-FM-2 Valve (V-3144) to 65% pipe Limited due to pipe-to-Pipe Meld No. SI- side, valve configuration 110-FW-1 57% valve side 35

..4)$ Exa'min at,1 on".':"'Ar.ea;-,'-'..";:.';."'!Cov'er.,ad( % 5,'

:':Oe's'cr;:i 'ti.on'-o'>::,Limi tati o'ns Pipe to Elbow Weld 80% CRV 4" of total circumference No. SI-110-8-SW-1 achieved missed due to I-beam of to Valve (V-3654) to 40% Pipe Limited due to pipe-to-Pipe Weld No. SE- side, valve configuration 213-FW-2 20% Valve Side 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 Re uestin Relief (as stated):

"Ultrasonic and sui face examination partially obstructed by welded attachments.

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

Licensee's Pro osed Alternative Examination (as stated):

"1) Periodic System Pressure tests "2) Perform volumetric and surface examination to the extent practical" Evaluation: The Code requires that the subject welds receive a 100% surface and volumetric examination. However, due to the 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 complete coverage would be required.

==

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 provided with respect to component structural integrity. This information in combination with similar piping weld examinations 36

provides reasonable assurance of operational readiness.

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

3.2.3 ~Pum s (No relief requests) 3.2.4 Valves (No relief requests) 3.2.3 General

~ m 3.2.5.1 Re uest for Relief 14 IWB-2412 and IWC-2412 Ins ection Pro ram 8 Percenta e Re uirements IWB-2420 and IWC-2420 Se uence of Com onent Examinations Established Durin the Pirst Ins ection Interval Code Re uirement: IWB-2412 and IWC-2412 specify the minimum/maximum percentage of examinations that may be performed in a given period. IWB-2420 and IWC-2420 require that the sequence of component examinations established during the first inspection interval be repeated during each successive ins'I)ection interval, to the extent practical.

Licensee's Code Relief Re uest: The licensee requested re'li'ef from the successive. inspection scheduling established during the first inspection interval for the following examination areas:

i-.;C';ategor'y'>f,,",.',I',teem'.',:.".'.", Examinat;i o'n'I'A'r'eaI',Dess'crIi pt:;i on%.,:-'.'!:;::;=,,": j:,'-'";";':,",~"-",,

8-D'3.90 RPV Nozzle - Vessel Weld B3.100 RPV Nozzle Inside Radius 83.110 Pressurizer Nozzle - Vessel Weld 83.120 Pressurizer Nozzle Inside Radius 83.130 Steam Generator Nozzle - Vessel Weld ~

83.140 Steam Generator Nozzle Inside Radius l

'See Relief Request 17 for the evaluation of Examination Category B-D Items 83.90 and 83.100.

37

"o ~ k' << '~ "~: '"< " i" '.;

'j '.'-:'"::.'.:;:.'-.,-"."".-'"'..:.,

Examination'";Area'-Description':i':-'." .jc; j<<"~'...>>'

B-B 82.11 Pressurizer Shell - Head Welds 82.12 Pressurizer Long Welds 82.31 Steam Generator Circ. Head Welds 82.32 Steam Generator Meridional Welds 82.40 Steam Generator Tubesheet - Head Welds 8-F 85.40 Pressurizer Nozzle - Safe End 8-G-1 86.50 RPV Thread in Flan e 8-G-2 87.20 Pressurizer Bolts, Studs, Nuts 87.30 Steam Generator Bolts, Studs, Nuts 87.50 Pressurizer Bolts, Studs, Nuts 8-H 88.20 Pressurizer Integral Attachments 88.30 Steam Generator Inte ral Attachments 8-J 89.11 Circumferential Pipe Welds Steam Generator:

C-A C1.10 Shell Circumferential Welds C1.20 Head Circumferential Welds C1.30 Tubesheet to Shell Welds Steam Generator:

C-8 C2.21 Nozzle to Shell (or Head) Welds C2.22 Nozzle Inner Radius Section Licensee's Basis for Re uestin Relief (as stated):

"The primary purpose of this request for relief is to optimize the Code required vessel examinations by reducing costs and radiation exposure associated with these examinations.

"1. Vessels are unique in that several Examination Categories and Item numbers are associated with each vessel. In order to fully attain the goals stated above, the entire examination activity must be performed at the same time.

"Examples of significant costs and reduction in radiation exposure that may be realized from this approach are; na Table IWB-2500-1, Examination Cateyvry B-D requires the conduct of two of the six reactor pressure vessel nozzles in the first period of an inspection interval to meet the 25% to 50% requirement of'footnote (20).

The cost associated with these examinations exceeds

$ 400,000.00 for the nondestructive examinations activity. This cost does not take into consideration the support required to make the vessel ready for the examinations, such as (equipment handling, maintenance 38

crews, HP support, and planning), just to mention a few.

The total cost of performing the entire reactor Pressure Vessel NDE examination activity, including the two nozzles addressed above, and extending the examinations to essentially 100/. of all weld, as required by the regulation change is $ 1,000,000.00 plus support. The performance of two nozzle examinations in the first period, and the remainder in the third period places an economic hardship on FPL of an additional $ 400,000.00.

In addition to the above, the reactor vessel shell to flange weld, and the reactor vessel nozzle safe ends are also included in the mechanized examination activity.

lib Insulation removal associated with vessels are of such a size and shape that the removal of selected pieces for the purpose of a specific examination area, usually requires a substantial amount of additional insulation to be removed, If not all insulation on the vessel. Adhering to the sequence of examination established for the first interval would require FPL to remove and reinstall the same insulation on these vessels no less than two or three times over an inspection interval. The sequence of insulation removal and reinstallation is also true of installing and removing scaffolding.

FPL estimates that altering the sequence of examinations on the steam generators to one generator will save in excess of $ 100,000.00 and a reduction in radiation exposure by approximately 15 manrem.

"2. The sequence of component examinations established during the first inspection interval should be altered for the following

'easons:

Na FPL believes that with the exception of those examinations identified within Table IWX-2500-1, that specifically address examinations required in specific periods, the intent of the Code is to examine essentially the same items that were examined during the initial/previous inspection interval, to the extent practical. This is further confirmed by the exceptions allowed in Tables IWX-2412-1 of inspection Program B.

Il b Section XI allows examinations within a specific period to exceed 10 years by as much as 3 years in the first and third period, and 4 years in the second period. The Code also allows each period to be 39

adjusted by as much as I year to coincide with a refueling outage. .This extension could in an extreme case allow examinations to be performed as much as 15 years following the initial examination.

All adjustments to examination schedules proposed by FPL, with the exception of the attached Tables, are well within the 10 to 15 years discussed above.

The St.'ucie Unit 2 plant is currently starting the second inspection interval, therefore, early

. adjustment in the schedule is crucial in order to minimize the length of time between successive examinations, while still providing adequate assurance of structural integrity over the remaining 30 year period.

All examinations on the primary side were performed on both steam generators during the first inspection interval, and were distributed between the 1st. and 3rd. periods. Adjusting the schedule to perform all successive examination in the 3rd. period of the second interval, and on one steam generator will not in any way degrade the structural integrity of the vessel.

No examinations were conducted on the secondary side of steam generator 2B during the first inspection interval. All'econdary side examinations were performed on steam generator 2A, and were distributed evenly between the 1st., 2nd., and 3rd. inspection periods. Adjusting the schedule to perform all successive examinations in the 3rd. period of the second interval, and on steam generator 2A will not in any way degrade the structural integrity of the steam generator . By performing all examinations on S/G 2A, successive examinations will be building on the initial examinations already conducted during the first inspection interval.

Previous NDE examination results performed on these components have not identified any indications that exceeded the acceptance criteria of Section XI, or warrant consideration of not adjusting the sequence of the examinati-'.. scheduled.

Cost of performing selected examinations on the same component, within each period in order to satisfy the percentage requirements of Section XI is an economic hardship, without a substantial compensating increase in the quality or safety of the unit. "

40

icensee's Pro osed Alternativ xaminat'as stated):

"FPL proposes to reschedule examinations for the Reactor Pressure Vessel, Steam Generator and Pressurizer, such that all major examinations are performed at one time within a specified inspection period.

"FPL proposes the following schedule:

"Reactor Pressure Vessel - All required examinations will be performed in the 2nd. period, in conjunction with the 10-year automated examination activity.

"Reactor Pressure Vessel Closure Head - All required examinations will be performed in the First period, which will provide an additional gauge of the condition of the Unit 2 Reactor Vessel.

"Steam Generator (primary and secondary sides) - all required examinations will performed in the 3rd. Period, and with the exception of those areas requiring examination on both generator, performed on steam generato} 2A.

"Pressurizer - All required examinations will be performed in the 1st. Period.

"The readjusted schedule proposed and the system pressure test will provide continued assurance of an acceptable level of quality and safety.

"If during the inspection interval, an opportunity arises that would allow examinations to be performed on those items referenced in the attached Tables, earlier that the proposed schedule, FPL will make an attempt to examine those items."

Evaluation: The licensee has proposed rescheduling examinations to reduce the duplication of effort, radiation exposure, and costs for the second 10-year interval. In the review of the request for relief, the following were noted:

The Code defines three inspection periods for each 10-year interval and specifies when deferral K examinations is permissible. By performing, examinations in accordance with the Code, a level of confidence for the integrity of piping and components is maintained throughout the interval. When implementing Table IWB-2412-1, Inspection Program B, the 10-year interval is divided into periods of 3, 4, and 3 years, respectively. The dur ation of each period in itself should 41

provide adequate scheduling flexibility for examinations while still maintaining the successive scheduling requirements of the Code. The proposed rescheduling of examinations results in noncompliance with the percent of examinations required to be performed each period.

~ In the response to the RAI, the licensee stated that it is not possible or practical to predict that examinations will be repeated on a schedule that will not exceed ten years. In some cases it is possible for the duration between successive examinations to exceed 10 years, based on the performance of the examinations within the margin of the periods and adjustments to the interval, which may be decreased or extended by as much as one year. The Code scheduling philosophy, however, is based on a 10-year inspection interval, which implies that the examinations are performed each 10 years. When reestablishing examination area schedules, to conclude that the intent of the Code permits a duration between successive examinations of up to fifteen years is unacceptable.

~

The licensee's argument that successive examinations are a burden is not supported by the industry.

Examination Category B-F examinations may be performed. in conjunction with vessel nozzle examinations required by Examination Category B-D. Therefore, relief is not required from the scheduling requirements for Examination Category B-F.

==

Conclusion:==

The licensee's proposed rescheduling of examinations for the second interval results in noncompliance with the successive examination requirements as well as with the percentages of examinations to be performed each inspection period. Therefore, it is recommended that relief be denied.

42

3.2.5.2 Re uest for Relief 16 Para ra h IWA-6620 Pre aration of Owner's R orts Forms NIS-1 and NIS-2 and Submittal of 90-da Summar

~Re ert Code Re uirement: Paragraph IWA-622Q requires that the .licensee prepare NIS-1, Owner's Report for Inser vice Inspections, and NIS-2, Owner's Report for Repair or Replacements, and file these'eports with the enforcement and regulatory authorities having jurisdiction at the plant site within 90 days of the completion of the inservice inspection conducted during each refueling outage.

Licensee's Code Relief Re uest: The licensee requested relief from:

1. Preparation of the Owner's Report for Inservice Inspection, Form NIS-1.

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

3. Submittal of the summary report within 90 days following completion of the inservice inspection conducted during each refueling outage.

Licensee's Basis for Re uestin Relief (as stated):

"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 quality and/or safety of the St. Lucie operating plant.

, "The summary report "..s not furnish evidence of compliance with ASME Boiler and Pressure Vessel Code,Section XI, Inspection Program B, percentage requirements as mandated by IWB-2412, IWC-2412, and IWD-2412.

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

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

43

"The preparation, review, approval and certification of each record and report, within the time frame of 90 days following completion of each refueling outage, increases substantially the costs associated with inservice inspection activities, and puts an unreasonable time constraint on FPL without a increase in assurance of Code compliance."

Licensee's Pro osed Alternative (as stated):

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

"I) REPAIR/REPLACEMENT PLAN Repair/Replacement plans shall meet the requirements of IWA-4140 (1992 Edition), to,the extent required, for all Code Classes.

Each Repair/Replacement Plan shall be given a unique identification number. The unique identification number may be the number of the document utilized for the repair and/or replacement as required by FPL procedures or instructions.

(i.e., NCR, CNR, PCM, HEP, CWO, PWO, etc.,).

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 repait or replacement FPL shall prepare and certify the Repair/Replacement Plan Certification Record, Form NIS-2A, attached'.

The completed Form NIS-2A shall become part of the Repair/Replacement Plan and shall be maintained in accordance with IWA-6300.

FPL shall maintain an index and update regularly the status of the index of all Repair/Replacement Plans for all Code Classes. The index shall identify the unique identification number and interval and period during which the repair or replacement was completed.

The index shall be maintained in accordance with IWA-6300, and be made available upon request for review by the enforcement and regulatory authorities having jurisdiction at the plant site.

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

44

"3)

SUMMARY

REPORT A Summary Report shall be prepared and submitted to the regulatory and enforcement authorities having jurisdiction at the plant site within 120 days following the end of the Inspection Period as identified in Program B.

l The Summary Report shall include examinations, tests, repairs and replacements results'for all ASME Class items which have been completed since the pi eviously submitted Summary Report.

The Summary Report shall contain the following:

Summary Report Cover Sheet, Form NIS-IA, attached.

b. Abstract of examination and tests information, Form HIS-IB, attached.

C. Listing of examinations, Form IC, that were not performed to the extent identified by the inspection plan for the inspection period, and when or are planned for a later date. Additionally, any if they 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.

e. Abstract of all Code Classes of repairs and replacements Form NIS-2B, which were required due to an item(s) having exceeded an acceptance criteria for IWX-3000."

Evaluation: The use of the NIS-I 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.

Conclusion:

Based on the above evaluation, it is recommended that relief be denied.

45

3.3 Class 3 Com onents (No relief requests) 3.4 Pressure Tests (No relief requests) 3.5 General 3.5. 1 Ultrasonic Examination Techni ues 3.5. 1. 1 Re uest for Relief 13 A endix III Re uirements Ultrasonic Calibration Blocks Code Re uirement: ASME Section XI, Appendix III, III-3400 requires the calibration blocks to be made from pipe of the same nominal diameter and nominal wall thickness (pipe schedule) as the pipe to be examined.

III-3411 requires that the calibration block be fabricated from one of the materials specified for the piping being joined by the weld.

Licensee's Code Relief Re uest: The licensee requested relief from the ASME Code, Appendix III, requirements for use of a 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 materials as the piping being joined for calibration blocks UT-4A and UT45.

Licensee's Basis for Re uestin Relief (as stated):

"I. 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).

"2. UT-45 Main Steam Piping Welds The subject piping welds are of two sizes:

"a) 34" diameter, 1.250" wall 46

"b) 36.625" diameter, 1.234" wall. The requirements of ASME code are such that two blocks, one of each diameter would be required.

"c) The wall thickness is essentially the same, therefore there is little or no change in'he sensitivity.

"d) ~ The small difference in diameter is not ultrasonically noticeable.

"3. The proposed calibration blocks have been in u'se since the plant was built, their continued use would tend to provide consistent results."

Licensee's Pro osed Alternative Examination (as stated):

"Perform the Code required examinations using the proposed calibration blocks as defined above."

Evaluation: The Code requires that calibration blocks be of the 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 by IWA-2240. Based on a review of the calibration block specifications, it appears that an acceptable degree of 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 and 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.

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 provide an acceptable level of examination sensitivity.

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

3.5.2 Exem ted Com onents (No relief requests) 3.5.3 Other (Ne relief requests)

4. CONCLUSION Pursuant to 10 CFR 50,55a(g)(6)(i), it has been determined that certain inser vice examinations cannot be performed to the extent required by Section XI of the ASIDE 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, ll, 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 licensee's response to the NRC's request for additional information, and the recommendations for granting relief from the ISI examinations that cannot be performed to the extent required by Section XI of the ASNE Code, no deviations from regulatory requirements or commitments were identified, except for Requests for Relief 14 and 16.

49

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 IO-Year Interval Inservice Inspection Program Plan, Revision 0, dated August 4, 1993.

4. NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, Section 5.2.4, "Reactor Coolant 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 Regulatory Guide 1. 14, Reactor Coolant Pump Flywheel Integrity, August 1975.

8. NRC Regulatory Guide 1. 150, Reactor Pressure Vessel Beltline h'eld Examinations, Rev. 1, February 1983.

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

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

50

NRC FCALI 335 U.S. i'IUCLEAR REGULATORY COMMISSION 2 2&i IAsssoneo Isv IIAc. Aoo vol.. svoo.. Aev..

VRCM ~ '10", ~ no Aoornovm rsvmoers, ir env.I 2201, '202 BIBLIOGRAPHIC DATA SHEET ISttinrrllrcrionr on rht roventi 2, TITLE AiVO SUBTITLE INEL-94/0147 Technical Evaluation Report on the Second 10-Year Interval Inservice Inspection Program Plan: 3 OATo REPORT PUBLISHE Florida Power and Light Company MPre Tsi St. Lucie Nuclear Plant, Unit 2 March 1995 Docket Number 50-389 4, FIN OR GRAiVT iVUSIBER FIN-L2556 (Task-20)

5. AUTHOR(S) 6. TYPE OF REPORT Technical B.W. Brown, E.J. Fe'ige, K.W. Hall, A.M. Porter 7. PERIOD COVERED rsncrvsr~

Pars'.

PERFORMING ORGANIZATION NAME AND ADDRESS lllllRC Providrpivision. PlliceorRtyhw. MS lrvclterprtvltsory Commrssronendmesimtasdrrssislconsrtcror Proaot nanr assr mtrrint ardrncl Lockheed Idaho Technologies Company Idaho Falls, Idaho 83415-2209

9. SpONSORING ORGANIZATION NAME AND ADDRESS illlrRC, rypr -Sanr es tooer"iilconrreclor. provide HRC Oivnion, prrrcr or Action, M* reverter Retvsesorv Commrsvon.

ard mtilinpeddrtrLl Materials and Chemical Engineering Branch Office of Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 IO. SUPPLEMENTARY NOTES

11. ABSTRACT r200worm or Nssl 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 Society of Mechanical Engineers 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 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 commitments identified during previous Nuclear Regulatory Commission reviews. The requests for relief are evaluated in Section 3 of this report.

12. KEY WORDSIDESCRIPTORS iLin ~rds or phmsts rhrs willtssisr nsterchrnin locerint mr noon I IS. AVAILASILITVSTATSMSNT Unlimited

14. SSCUAI TV CLASSIFSCATSPre IThis Petri Unclassified I This Reposes Unclassified

15. NUMBER OF PAGES 16, PRICE rcAC FOAM 23S I249I