ML17229A614

Rev 0 to ISI-PSL-1, Third Interval ISI Program for St Lucie Nuclear Power Plant,Unit 1.

ML17229A614
Person / Time
Site:	Saint Lucie
Issue date:	01/12/1998
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17229A612	List: ML17229A611 ML17229A613 ML17229A614 ML17229A615
References
ISI-PSL-1, NUDOCS 9802090248
Download: ML17229A614 (172)

Text

Nuclear Engineering Department Codes and Component Program Group Code Programs Section P.O. Box 14000 700 Universe Blvd.

Juno Beach, Florida 33408 Third Interval Inservice Inspection Program for St. Lucie Nuclear Power Plant Unit 1 St. Lucie Nuclear Power Plant 6501 South Highway A1A Jensen Beach, Florida 34957 Commercial Service Date: December 21, 1976 USNRC Docket Number: 50-335 Document Number: ISI-PSL-1-Program Rev. 0 Prepared by:

ISI Specialist Date: / /9 Reviewed by: Date:

I'NII Accepted by: Date: l -g7 Approved by: Date: g Manager CSI

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Record of Revision Revision Date Reason for Revision No.

. January 12, 1998 Original Issue Third Ten Year Ins ection Pro ram

St. Lucie 1 ISI Program Revision 0 January 12, 1998 List of Effective Pages Pages Date 1 thru 171 January 12, 1998

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Table of Contents Cover Page Record of Revxsxon

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List of Effective Pages Table of Contents List of Figures and Tables Abbreviations Abstract 1.0 Introduction 12

1. 1 ISI Program Development 12 1.1.1 Applicable Documents 12 1.1.2 Other Programs 13 1.1.3 Construction Permit 14 1.1.4 Operating License 14 1.1.5 First Inspection Interval 14 1.1.6 Second Inspection Interval 14 1.1.7 Third Inspection Interval Dates 14 1.2 Applicable Editions and Addenda to Section XI 15 1.3 System Classification 15

1. 3. 1 System Classifications 15 1.3.2 Optional construction 15 1.3.3 Containment Penetrations 16 1.3.4 Piping and Instrumentation Diagrams 16 1.4 Inspection Program 16 1.5 Regulatory Guides 16 1.6 ASME Section XI Code Cases 17 1.7 Branch Technical Position MEB 3-1 19 1.8 Standard Review Plan 6.6 20 1.9 Replacement Steam Generators 20 2.0 Development of the Inspection Plans 20 2.1 Class 1 20 2.1.1 ASME Code Exemptions Employed 20 2.1.2 Component/Piping Examination Basis 21 Category B-A 21 Category B-B 22 Category B-D 23 Category B-E 24 Category B-F 24 Category B-G-1 25 Category B-G-2 26

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1 ISI Program Revision 0 January 12, 1998 Category B-H 26 Category B-J 27 Category B-K . 27 Category B-L-1 28 Category B-L-2 28 Category B-M-1 28 Category B-M-2 28 Category B-N-1 29 Category B-N-2 29 Category B-N-3 29 Category B-0 30 Category B-P 30 Category B-Q ~ ~ 31 Augmented Examinations 31 2.2 Class 2 ~ ~ ~ 32 2.2.1 Components Exempt from Examin ation 32 2.2.2 Component/Piping Examination Basis 32 Category C-A . 32 Category C-B 33 Category C-C 33 Category C-D 34 Category C-F-1 34 Category C-F-2 35 Category C-F-3 35 Category C-F-4 35 Category C-G 36 Category C-H 36 Class 2 Augmented Examinations 37 2.3 Class 3 37 2.3.1 ASME Code Exemptions Employed ~ ~ 37 2.3.2 Component/Piping Examination Basis 37 Category D-A 38 2.3.3 System Pressure Tests 38 2.3.4 Augmented Examinations 39 2.4 Metal Containment ~ ~, ~ 39 2.4. 1 Components Exempt from Examina tion 39 2.4.2 Examination Basis 39 Category E-A 39 Category E-B 40 Category E-C ~ ~ 40 Category E-D ~ ~ 40 Category E-F 40 Category E-G 41 Category E-P 0 ~ 41 2.5 Component Supports ~ ~ 41 2.5.1 ASME Code Exemptions. Employed 41 2.5.2 Support Examination Basis 42 Category F-A 42 Item Numbers 42

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Augmented Examinations 43 2.6 Concrete Containment 43 2.7 Successive Examinations 43 2.7.1 Class 1 43 2.7.2 Class 2 43 2.7.3 Class 3 44 2.7.4 Component Supports 44 2.8 Substitute Examinations 44 3.0 Relief Requests 44 4.0 Evaluation Criteria 45 4.1 Acceptance by Engineering Evaluation 45 4.2 Acceptance by Repair 45 4.3 Acceptance by Replacement 46 4.4 Acceptance by Analytical Evaluation 46 4.5 Component Support Indications 46 4.6 Supplemental Examinations 47 4.7 Additional Examinations 47 4.8 Minimum Thread Engagement Requirements 48 5.0 Program Boundary Drawings 48 6.0 Records o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 50 6.1 General 50 6.2 Nondestructive Examinations 50 6.3 Final Reports 50 6.4 Final Report Format 50 6.5 Inservice Inspection Summary Reports 50 7.0 Repairs, Replacements, and Modifications 53 7.1 Repairs 53 7.2 Replacements on Class 1, 2, 3, and MC Systems 53 7.3 Modifications 54 7.4 Evaluate.on 54 7.5 Access 55 7.6 Determination of Design and Construction Codes 55 7.7 Authorized Nuclear Inservice Inspector 55 8.0 Inservice Inspection Plan and Schedules 55 8.1 Inspection Plan Tables 55 8.2 Ten Year Inspection Plan 56 8.3 Weld Identification 56 9;-0 Nondestructive Examination Procedures ~ ~ 58 10.0 Calibration Blocks 59 11.0 Removal or Addition of Welds and Components 62

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Requests ~ ~ ~ ~ ~ ~ ~ ~ ~ i ~ 1 ~ ~ ~ ~ ~ \ ~ ~ ~ 64 Relief Request No. 1, Use of Code Case N-532 . . . . . . 66 Relief Request No. 2, Use of Code Case N-533 . . . . . . 75 Relief Request No. 3, Use of Code Case N-546 . . . . . . 79 Belief Request No. 4, Alternative Evaluation of Leakage 83 Relief Request No. 5, RPV Weld 209-04 . . . . . . . . . 87 Relief Request No. 6, Alternative Snubber Examinations . 91 Relief Request No. 7, Refueling Water Tank Non-Code Repair h

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 99 Belief Request No. 8, Scheduling of Examinations . . . . 128 Relief No. 9, Reactor Pressure Vessel Nuts . . . 133 Request No. 10, Reactor"Pressure Vessel Bolting . 136 Request'elief Relief Request No. 11, Use of Code Case N-416-1 . . . . 139 Relief Request No. 12, Use of Code Case N-498-1 . . . . 144 Relief Request No. 13, Use of Code Case N-509 . . . . . 149 Belief Request No. 14, Use of Code Case N-521 . . . . . 157 Relief Request No. 15, Use of Code Case N-524 . . . . . 161 Relief Request No. 16, Alternative Piping Weld Examination

~ ~ ~ ~ ~ ~ ~ ~ ~ e ~ ~ ~ ~ * ~ ~ ~ ~ 165 Index ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1 69

St. Lucie 1 ISI Program Revision 0 January 12, 1998 List. of Figures and Tables USNRC Regulatory Guides 16 Applicable Code Cases 17 Table 4.1 Corrective Action ~ ~ ~ ~ ~ ~ ~ ~ 46 Figure 6.1 Inservice Inspection Summary Record 51

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Abbreviations Listed below are the abbreviations utilized in this document:

ANII Authorized Nuclear Inservice Inspector

'OV Air Operated Valve ASME American Society of Mechanical Engineers B&PV Boiler and Pressure Vessel Code CCW Component Cooling Water CRDM Control Rod Drive Mechanism CH Charging System CPS Code Programs Section CV Control Valve CVCS Chemical and Volume Control System ECCS Emergency Core Cooling System ECT Eddy Current Testing (Examination)

ESI Equipment Support and Inspections FPL Florida Power and Light Company FPS Fuel Pool System FW Feedwater System HPSI High Pressure Safety Injection HS High Stress JPN Juno Nuclear Engineering LPSI Low Pressure Safety Injection Lor LS Longitudinal Seam Weld MOV Motor Operated Valve MSIV Main Steam Isolation Valve MS Main Steam System MT Magnetic Particle Testing (Examination)

N/A Not Applicable NDE Nondestructive Examination

St. Lucie 1 ISI Program Revision 0 January 12, 1998 NPS Nominal Pipe Size P&ID Piping and Instrumentation Diagram PSL St. Lucie Nuclear Power Plant PT Liquid Penetrant Testing (Examination)

'A Quality Assurance QC Quality Control PWR Pressurized Water Reactor PZR Pressurizer RCS Reactor Coolant System RCP Reactor Coolant Pump RWT N

Refueling Water Tank RGX Regenerative Heat Exchanger RPV Reactor Pressure Vessel SD Structural Discontinuity SG Steam Generator SGBD Steam Generator Blowdown SI Safety, Injection Thickness of Component, Pipe, etc.

,TE Terminal End UFSAR Updated Final Safety Analysis Report USNRC United States Nuclear Regulatory Commission UT Ultrasonic Testing (Examination)

VT Visual Testing (Examination) 10

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1 ISI Program Revision 0 January 12, 1998 Abstract This document describes the bases for the Third Ten-Year Inservice Inspection Program for St. Lucie Nuclear Power Plant, Unit 1.

This program'as developed and prepared to meet the requirements of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section XI, 1989 edition, for Class 1, 2, and 3 systems, and the 1992 Edition with addenda through 1992 for Class MC and CC systems. It is subject to the limitations and modifications of 10 CFR 50.55a(b)(2), except the design and access provisions and preservice examination requirements.

identifies those components and/or systems and their supports It which are subject to examination and testing.

Where applicable, ASME Code Cases were incorporated.

Alternatives to the Code requirements have been included as relief requests. Areas where Code compliance is not possible are also included as relief requests, along with proposed alternatives. Relief Request No. 10 is for both St. Lucie Units 1 and 2. All other relief requests within this program are for St. Lucie Unit 1.

Additional requirements for augmented examinations are addressed.

10 CFR 50.55a(g) (6) (ii) (A) requires FPL to perform an augmented examination of the Reactor Pressure Vessel., This was performed during the 1997 refuel outage, with the results having been submitted to the Nuclear Regulatory Commission. The examinations covered the reactor vessel shell welds specified in Item No.

B1.10 of examination category B-A, "Pressure Retaining Welds in Reactor Vessels," in Table IWB-2500-1 of subsection IWB of the 1989 Edition of Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code, subject to the conditions specified in g 50.55a(g)(6)(ii)(A)(3) and (4). The examinations are scheduled to be performed again in the year 2007.

St. Lucie 1 ISI Program Revision 0 January 12, 1998 1.0 Introduction 1.1 ISI Program Development This document details the Long-Term Inservice Inspection Program for the Third Ten-Year Inspection Interval for St. Lucie Nuclear Plant (PSL), Unit 1.

1.1.1 Applicable Documents The Inservice Inspection Program for Class 1, Class 2, and Class 3 (or Quality Groups A, B, and C respectively) systems and components and supports, and Class MC and Class CC components and supports, was developed after reviewing the following documents to the extent practical within the limitations of design, geometry, and materials of construction.

10 CFR 50.55a Code of Federal Regulations Sections V and XI of the American Society of Mechanical Engineers (ASME) Code, 1989 Edition Section XI of the American Society of Mechanical Engineers Code, 1992 Edition with Addenda through 1992 United States Nuclear Regulatory Commission (USNRC)

Regulatory Guides

1. 14 Reactor Coolant Pump Flywheel Integrity Revision 1, August 1975 1.26 Quality Group Classifications and standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants, Rev. 2, June 1975 1.65 Materials and Inspections for Reactor Vessel Closure Studs

1. 68 Initial Test Program for Water Cooled Nuclear Power Plants, Rev. 2, Aug. 1978

1. 82 Sump Augmented Exams for ECCS and CSS NRC Information Notice 89-77 NRC Information'Notice 89.-77, Supp. 1 1.83 Inservice Examination of Pressurized Water Reactor Steam Generator Tubes, Revision 1, July 1975 .

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1 ISI Program Revision 0 January 12, 1998 1.85 Materials Code Case Acceptability, ASME Section III, Division 1 1.147 Inservice Inspection Code Case Acceptability ASME Section XI Latest Revision 1.150' Ultrasonic Testing of Reactor Vessel Welds during

'"Preservice arid Inservice Examinations, Rev. 1, February 1983 St. Lucie 1 Final Safety Analysis Report St. Lucie Plant Technical Spec'ifications USNRC Standard Review Plan 6.6, Paragraph I.8, (for Class 2 Augmented Inspections)

Branch Technical Position APCSB 3.1, paragraph B.2.c(4)

NUREG-0800, Section 9.5.4/9.5.8, Essential Class 3 Diesel Systems First and Second Ten year Interval Inspection Plans Branch Technical Position MEB 3-'1, "High Energy Fluid Systems, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment" USNRC Bulletin 88-11, "Pressurizer Surge Line Thermal Stratification" USNRC Bulletin 79-13, "Cracking in Feedwater System Piping" USNRC Information Notice 93-20, "Thermal Fatigue Cracking of Feedwater Piping to Steam Generators," Dated March 24, 1993 1.1.2 'ther Programs The program for Inservice Testing of Class 1, 2, and 3 Pumps and Valves is covered by the St. Lucie Inservice Testing (IST) program which is submitted and approved separately.

The Steam Generator Eddy Current. Testing (ECT) Program is controlled by Plant Technical Specifications.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 The Snubber Program is controlled by Plant Technical Specifications and Relief Request No. 6, Alternative Snubber Examinations (see page 91).

1.1.3 Construction Permit The Construction permit for St. Lucie 1 was issued during July 197'O'; Florida Power and Light Company (FPL) is the Owner of Record.

1.1.4 Operating License The commercial operating license for St. Lucie 1 was issued during March 1976.

1.1.5 First Inspection Interval During the first Inservice Inspection Interval, the first inservice inspection period was conducted in accordance with t

the 1970 Edition with Addenda through Winter 1970 Addenda of the ASME Boiler and Pressure Vessel (B&PV) Code, Section XI.

The second and third periods were conducted in accordance w'th

3. the 1974 Edition with Addenda throu g h Summer 1975 of ASME B&PV Code, Section XI.

The Reactor Pressure Vessel (RPV) examinations were conducted in accordance with the 1977 Edition with Addenda through Summer 1978.

System Pressure tests were conducted in accordance with the 1980 Edition with Addenda through Winter 1981.

The first interval for St. Lucie Unit 1 began on February 11, 1978 and ended on February 10, 1988.

1.1.6 Second Inspection Interval The Second Ten Year Inservice Inspection Interval was conducted in accordance with the 1983 Edition with Addenda through Summer 1983 of Section XI. The second interval ran from February 11, 1988 to February 10, 1998.

1.1.7 Third Inspection Interval Dates The dates of the Third Interval and Periods are as follows:

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1 ISI Program Revision 0 January 12, 1998 3rd Interval 2/11/1998 2/10/2008 1st Period 2/ll/1998 2/10/2001 2nd Period 2/ll/2001 2/10/2004 3rd Period 2/11/2004 2/10/2008 1.2 Applicable Editions and Addenda to Section XI In accordance with 10 CFR 50.55a(b)(2), the Inservice Inspection Requirements for the third inservice inspection interval applicable to Class 1, 2, and 3 components at St.

Lucie 1 are based on the 1989 Edition of ASME Section XI.

For Class MC and Class CC components of Section XI, Division 1, the 1992 Edition with the 1992 Addenda, Sections IWE and IWL will be used. These Editions of ASME Section XI were endorsed by the USNRC twelve months prior to the start of the Third Ten Year Inservice Inspection Interval (February 11, 1997) .

1.3 System Classification 1.3.1 System Classifications The system classification for the Inservice Inspection Program are based on the requirements of 10 CFR 50 and Regulatory Guide 1.26.

Class 1 system boundaries are developed based on 10 CFR 50.2(v), and the St. Lucie Plant Unit 1 Updated Final Safety Analysis Report (UFSAR).

Class 2 and 3 system boundaries are developed based on Regulatory Guide 1.26 and the St. Lucie Plant Unit 1 UFSAR.

Vessels, piping, pumps, and valves were built and installed according to the rules of ASME Section III and USA Standard B31.7 for those systems classified as Class 1, 2, and 3.

FPL has not completed the review of the Class MC components and supports. As this is developed, this information will be included.

1.3.2 Optional construction Optional construction of a component within a system boundary to a classification higher than the minimum class established 15

St. Lucie 1 ISI Program Revision 0 January 12, 1998 in the component design specification may not affect the overall system classification by which the applicable rules of Section XI are determined.

1.3.3 Containment Penetrations Portions of piping penetrating the containment. vessel which ar'e rendu'ired to be constructed to Class 1 or 2 rules for piping and which may differ from the classification of the balance of the piping system, may not affect the overall system classification that determines the applicable rules of Section XI.

1.3.4 Piping and Instrumentation Diagrams Piping and Instrumentation Diagrams (P&IDs) show the specific boundaries for the Class 1, 2, and 3 systems (see Section 5.0).

1.4 Inspection Program Examinations for Class 1, 2, and 3 components are scheduled in accordance with Inservice Inspection Program B (Subarticle IWB-2412 and Table IWB-2412-1). Examinations are scheduled based upon the Second Ten Year Interval Program, to the extent practical.

In order to be consistent in determining percentages, FPL chose to multiply the number of examination areas by the minimum or maximum percentages of Program B and rounding to the nearest whole number. This will be the number FPL uses for determining how many welds/components will be examined each period.

1.5 Regulatory Guides The Regulatory Guides which have been determined to be applicable to St. Lucie for purposes of this Program are listed below:

USNRC Regulatory Guides R.G. Number Description of Regulatory Guide 1.14 Rev. 1 Reactor Coolant Pump Flywheel Integrity ualit Grou Classifications 16

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1 ISI Program Revision 0 January 12, 1998 USNRC Re ulatory Guides R.G. Number Description of Regulatory Guide Materials and Inspections for Reactor Vessel Closure Studs Section XI Code Case Acceptability (See note) 1.150 Rev. 1 UT of RPV Welds During PSI and ISI Note: Revision 11 of Regulator'y Guide 1.147 was'sed during the writing of this program. Later revisions may be used when issued.

1.6 ASME Section XI Code Cases Section XI Code Cases applicable to the ISI Program are shown below. Each of the Code Cases has been approved and listed in USNRC Regulatory Guide 1.147,.or are the subject of a relief request.

Applicable Code Cases Number Description Revised Ultrasonic Examinations for Class 1 N-307-1 Bolting, Table IWB-2500-1, Examination Category B-G-l, When the Examinations are Conducted from the Center-Drilled Hole, Section XI, Division 1 Calibration Block for Angle Beam Ultrasonic N-355 Examination of Large Fittings in Accordance with Appendix III-3410, Section XI, Division 1 N-401-1 Eddy Current Examination, Section XI, Division 1 N-402-1 Eddy Current Calibration Standards, Section XI, Division 1 Alternative Pressure Test Requirement for Welded N-416-1 Repairs orClass Installation of Replacement Items by Welding, 1, 2, and 3, Section XI, Division 1 (Relief Request No. 11)

Qualification Specimen Notch Location for N-457 Ultrasonic Examination of Bolts and Studs, Section XI Division 1

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Applicable Code Cases Number Description N-460 Alternate Examination Coverage for Class 1 and Class 2 Welds, Section XI, Division 1 N-461 'Al'ternate Rules for Piping Calibration Block Thickness, Section XI, Division 1 Evaluation Procedures and Acceptance Criteria for Flaws in Class 1 Ferritic Piping that Exceed the N-463-1 Acceptance Standards of IWB-3514.2, Section XI, Division 1 Alternate Examination Coverage for Cast Austenitic N-481 Pump Casings, Section XI, Division 1 (See Notes at end of Table)

N-489 Alternative Rules for Level III NDE Qualification Examinations, Section XI, Divisions 1, 2, and 3 Alternative Rules for Examination of Class 1, 2, N-491 3, and MC Component Supports of Light,-Water Cooled Power Plants, Section XI, Division 1 Alternate Rules for 10 Year Hydrostatic Pressure N-498-1 Testing for Class 1 and 2 Systems, Section XI, Division 1 (Relief Request No. 12)

N-503 Limited Certification of Nondestructive Examination Personnel Alternative Rules for the Selection and N-509 Examination of Class 1, 2, and 3 Integrally Welded Attachments, Section XI, Division 1 (Relief Rec{uest No. 13)

Alternative Rules for Deferral of Inspections of Nozzle-to-Vessel Welds, Inside Radius Sections, N-521 and Nozzle-to-Safe End Welds of a Pressurized Water Reactor Pressure Vessel, Section XI, Division 1 (Relief Request No. 14)

Alternative Examination Requirements for N-524 Longitudinal Welds in Class 1 and 2 Piping, Section XI, Division 1 (Relief Request No. 15) 18

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January 12, 1998 Applicable Code Cases Number Description Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary N-532 geport Preparation and Submission as Required by IWA-4000 and IWA-6000, Section XI, Division 1 (See Relief Request No. 1)

Alternative Requirements for VT-2 Visual N-533 Examination of Class 1 Insulated 'Pressure-Retaining Bolted Connection, Section XI, Division 1 (See Relief, Request No. 2)

Alternative Requirements for Qualification of VT-2 N-546 Examination Personnel, Section XI, Division 1 (See Relief Request No. 3)

Notes: Code Case N-481 requirements will be modified by Florida Power and Light from Hydrostatic to System Pressure Test to conform with Code Case N-498-1.

When Code Cases are approved for use through a relief request, and are later added to Regulatory Guide 1.147, FPL may continue to use them provided any limitations in the Regulatory Guide are followed.

1.7 Branch Technical Position MEB 3-1 Branch Technical Position MEB 3-1 required FPL to determine where piping failure in fluid systems outside of the containment would have an adverse effect on other components and equipment. FPL completed a detailed engineering analysis of the Residual Heat Removal, Chemical Volume Control, Main Steam, Main Feedwater, Auxiliary Feedwater, and Steam Generator Blowdown systems.

The engineering analysis determined that portions of the Main Steam system needed to be included in the ISI examination schedule. These included those supports and welds to the first support beyond the Class 2 boundary. Appropriate welds and supports will be examined.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 1.8 Standard Review Plan 6.6 FPL will examine selected welds in the Main Steam and Feedwater systems in accordance with the requirements of SRP 6.6.

1.9 Replacement Steam Generators i

• FPL replaced the steam generators during the 1997 refueling outage. The replacement examination areas were baseline examined, and were scheduled for inservice examination for the third interval as per the applicable categories.

2.0 Development of the Inspection Plans Plant controlled isometric and component drawings were used to develop the scope of examinations. During examinations, the ISI Sketches included within the ISI Program will be used to locate each examination item. Plant controlled drawings will be used when additional information is required.

Refer to Document ISI-PSL-1-Plan for a complete listing of welds subject to examination and proposed examination schedule.

2.1 Class 1 2.1.1 ASME Code Exemptions Employed Subarticle IWB-1220 of the 1989 Edition of Section XI lists those piping and components exempt from examination.

There are no class 1 systems exempt from surface or volumetric examination in St. Lucie Unit 1 for reasons other than size.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 2.1.2 Component/Piping Examination Basis Category B-A, Pressure Retaining Welds in the Reactor Pressure Vessel The reactor pressure vessel examinations (including the closure head) are performed to Regulatory Guide 1.150, Rev.','and are augmented by Appendix VII of the 1989 Edition of Section XI.

B1.11 Circumferential Shell Welds B1.12 Longitudinal Shell Welds Examine essentially 100% of the length of circumferential and longitudinal shell welds (does not include shell to flange weld).

B1.21 Circumferential Head Welds B1.22 Meridional Head Welds Examine essentially 100< of the length of circumferential and meridional head welds.

Bl.30 Shell to Flange Weld Examine essentially 100~ of the length of the shell to flange weld.

Note: If partial examinations are conducted from the flange face, the remaining volumetric examinations required to be conducted from the vessel wall may be performed at or near the end of the inspection interval. At least 50~o of the weld shall be examined by the end of the first inspection period, and the remainder by the end of the third inspection period.

B1.40 Head to Flange Weld Examine essentially 1004 of the length of the head to flange weld.

B1.50 Repair Welds Bl.51 Beltline Region There are no repair welds in the beltline region of the Reactor Vessel.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 2.1.2.2 Category B-B, Pressure Retaining welds in vessels other than Reactor Vessels Pressurizer:

B2.10 Shell-to-Head Welds B2.11 Circumferential B2.12 '-"Longitudinal Examine essentially 100~ of the length of both shell-to-head welds and 1 ft. on one intersecting longitudinal weld at each shell-to-head weld.

B2.20 Head Welds B2.21 Circumferential B2.22 Meridional There are no circumferential or meridional head welds on the pressurizer.

Steam Generators (Primary Side):

B2.30 Head Welds B2.31 Circumferential Examine essentially 100% of the length of one circumferential B2.32 Meridional Welds There are no meridional head welds on the steam generators at St. Lucie Unit l.

B2.40 Tubesheet to Head Weld Examine essentially 100< of the length of one weld on one steam generator.

Heat Exchangers (Primary Side) Head:

B2.50 Head Welds B2.51 Circumferential B2.52 Meridional Examine essentially 100< of the length of one weld per head.

Heat Exchangers (Primary Side) Shell:

B2.60 Tubesheet to Head Welds 22

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Examine essentially 100~ of the length of one weld on one heat exchanger.

B2.70 Longitudinal Welds Examine 1 ft.

heat exchanger.

of one weld at each end of the shell on one B2.80 Tubesheet to Shell Welds Examine essentially 1004 of the length of the welds at each end on one heat exchanger.

2 ~ 1.2.3 Category B-D, Full Penetration Welds of Nozzles in Vessels (Inspection Program B)

Reactor Pressure Vessel:

B3.90 Nozzle to Vessel Welds B3.100 Nozzle Inside Radius Section Examine 100% of all nozzles, see Relief Request 1 on page 157.

The reactor pressure vessel examinations are performed to Regulatory Guide 1.150, Rev. 1, and are augmented by Appendix VII of the 1989 Edition of Section XI.

Pressurizer:

B3.110 Nozzle to Vessel Welds B3.120 Nozzle Inside Radius Sections Examine 100< of all nozzles.

Steam Generators:

B3.130 Nozzle to Vessel Welds B3.140 Nozzle Inside Radius Sections Examine 100~ of all nozzles.

Heat, Exchangers:

B3.150 Nozzle to Vessel Welds B3.160 Nozzle Inside Radius Section Examine 1004 of all nozzles.

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.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 2.1.2.4 Category B-E, Pressure Retaining Partial Penetration Welds in Vessels B4.10 Partial Penetration Welds B4.11 Vessel Nozzles B4.12 Control Rod Drive Nozzles B4.13 (

Instrumentation Nozzles Examine 254 of the nozzles each interval.

B4.20 Pressurizer Penetration Welds Examine 1004 of the heater penetration welds each interval.

Examinations shall be performed during conduct of the system leakage test. See relief request. 3 on page 144.

Category B-E examinations are part of the Plant Pressure Test Program.

2.1.2.5 Category B-F, Pressure Retaining Dissimilar Metal Welds Reactor Pressure Vessel:

B5.10 NPS 4 or Larger Nozzle to Safe End Butt Welds B5.20 Less Than NPS 4 Nozzle to Safe End Butt Welds B5.30 Nozzle to Safe End Socket Welds Examine 100< of the welds each interval.

Pressurizer:

B5.40 NPS 4 or Larger Nozzle-to-safe End Butt Welds B5.50 Less Than NPS 4 Nozzle-to Safe End Butt Welds B5.60 Nozzle-to-Safe End Socket Welds Examine 1004 of the welds each interval.

Steam Generator:

B5.70 NPS 4 or Larger Nozzle to Safe End Butt Welds B5.80 Less Than NPS 4 Nozzle to Safe End Butt Welds B5.90 Nozzle to Safe End Socket Welds There are no class 1 steam generator dissimilar metal welds meeting Category B-F criteria.

Heat Exchangers:

B5.100 NPS 4 or Larger Nozzle to Safe End Butt Welds B5.110 Less Than NPS 4 Nozzle to Safe End Butt Welds B5.120 Nozzle to Safe End Socket Welds 24

St. Lucie 1 ISI Program Revision 0 January 12, 1998 There are no class 1 heat exchanger dissimilar metal welds meeting Category B-F criteria.

Piping:

B5.130 NPS 4 or Larger Dissimilar Metal Butt Welds B5.140 Less Than 4 NPS Dissimilar Metal Butt Welds B5. 150 Dissimilar Metal Socket Weld Examine 100< of the dissimilar metal welds in piping.

2. 1.2. 6 Category B-G-1, Pressure Retaining Bolting, Greater Than 2 in. in Diameter Reactor Pressure Vessel:

B6.10 Closure Head Nuts B6.20 Closure Studs, in place B6.30 Closure Studs, when removed B6.40 Threads in Flange B6.50 Closure Washers, Bushings Examine 1004 of the bolting each interval.

Pressurizer:

B6.60 Bolts and Studs B6.70 Flange Surface, when connection disassembled B6.80 Nuts, Bushings, and Washers There are no category B-G-1 pressurizer bolting greater than 2 in. in diameter.

Steam Generators:

B6.90 Bolts and Studs B6.100 Flange Surface, when connection disassembled B6.110 Nuts, Bushings, and Washers Examine 100< of the bolting each interval.

Heat Exchangers:

B6.120 Bolts and Studs B6.130 Flange Surface, when connection disassembled B6.140 Nuts, Bushings, and Washers There are no heat exchanger bolting greater than 2 in. in diameter.

Piping:

B6.150 Bolts and Studs B6.160 Flange Surface, when connection disassembled B6.170 Nuts, Bushings, and Washers

St. Lucie 1 ISI Program Revision 0 Zanuary 12, 1998 There are no category B-G-1 piping bolting greater than 2 in.

in diameter.

Pumps:

B6.180 Bolts and Studs B6.190 Flange Surface, when connection disassembled B6.200 Nuts, Bushings, and Washers Examine 100> of the above items in one Reactor Coolant Pump during B-L-2 examinations. If all the bolting in one pump cannot be examined due to an interference, then additional bolting from the other 'pumps may be examined until a number equal to the bolting in one pump has been examined.

Valves:

B6.210 Bolts and Studs B6.220 Flange Surface, when connection disassembled B6.230 Nuts, Bushings, and Washers There are no category B-G-1 valve bolting greater than 2 in.

in diameter.

2.1.2.7 Category B-G-2, Pressure Retaining Bolting, 2 in. and Less in Diameter B7.10 Reactor Vessel Bolts, Studs, and Nuts There are no category B-G-2 Reactor Vessel bolting 2 in. and less in diameter.

Bj. 20 Pressurizer Bolts, Studs, and Nuts B7.30 Steam Generators Bolts, Studs, and Nuts B7.40 Heat Exchangers Bolts, Studs, and Nuts B7.50 Piping Bolts, Studs, and Nuts B7.60 Pumps Bolts, Studs, and Nuts B7.70 Valves Bolts, Studs, and Nuts B7.80 CRD Housings Bolts, Studs, and Nuts For the pressurizer and steam generators, examine 100% of the bolting each interval.

For heat exchangers, piping, pumps, and valves, examinations are limited to components selected for examination under B-B, B-J, B-L-2, and B-M-2.

2.1.2.8 Category B-H, Integral Attachments for Vessels The guidelines of Code Case N-509 will be used in the performance and scheduling of examinations in lieu of the B-H 26

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1 ISI Program Revision 0 January 12, 1998 requirements of the 1989 Edition of Section XI. The Code Case changes the examination requirements and category to B-K.

2.1.2.9 Category B-J, Pressure Retaining Welds in Piping B9. 10 NPS 4 or Larger B9. '-'"Circumferential Welds 12 Longitudinal Welds 11'9.

B9 20

~ Less Than NPS4 B9.21 Circumferential Welds B9.22 Longitudinal Welds B9 30

~ Branch Pipe Connections B9.31 NPS 4 or Larger B9.32 Less Than NPS 4 B9 ~ 40 Socket Welds Examine dissimilar metal pipe welds, terminal ends, high stress terminal ends and joints in each pipe or branch run connected to other components, plus an additional number of piping welds so that 254 of nonexempt circumferential and branch connection pipe welds are examined. Longitudinal pipe welds intersecting any of the selected circumferential welds will be examined. FPL will limit the number of Category B-J piping welds examined to 254 of the total to reduce radiation exposure.

Longitudinal piping welds will be examined in accordance with the requirements of Code Case N-524.

2.1.2.10 Category B-K, Integral Attachments for Class 1 Vessels, Piping, Pumps, and Valves The guidelines of Code Case N-509 and Relief Request 4 (see page 149) will be used in the performance and scheduling of examinations in lieu of the B-H and B-K-1 requirements of the 1989 Edition of Section XI.

FPL will examine 10~ of Class 1 Integral Attachments. Each will receive a surface examination of 100> of required areas of each welded attachment. In the case of multiple components within a system of similar design, function, and service, only one of the integral attachments of only one of the multiple components will be examined. The integral attachments selected for examination shall correspond to those component supports selected by Code Case N-491 and IWF-2510. Examination is also required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, 27

St. Lucie 1 ISI Program Revision 0 January 12, 1998 maintenance, examination, inservice inspection, or testing.

Examinations performed as a result of support deformation cannot be credited under the requirements of inspection program B.

B10.10 Pressure Vessel Integrally Welded Attachments Exami'ne'only one integrally welded attachment of only one of multiple vessels.

B10.20 Piping Integrally Welded Attachments B10.30 Pump Integrally Welded Attachments Examine 10% of the integral attachments.

B10.40 Valve Integrally Welded Attachments There are no B10.40 components at St. Lucie Unit 1 2.1.2.11 Category B-L-1, Pressure Retaining Welds in Pump Casings; and Category B-L-2, Pump Casings B12.10 Pump Casing Welds Code Case N-481 will be utilized as an alternate examination method. The outside surface of one pump will be examined during the inspection interval.

B12.20 Pump Casing Examine the interior surfaces of one of the four Reactor Coolant volumetric Pumps if disassembled examination for maintenance, repair, or 2.1.2.12 Category B-M-1, Pressure Retaining Welds in Valve Bodies; and Category B-M-2, Valve Bodies B12.30 Valve Valve Body Welds, ( NPS 4 B12.40 Body Welds, z NPS 4 There are no B12.30 or B12.40 valve body welds at St. Lucie Unit 1 B12.50 Valve Body, > NPS 4 Examine at least one valve of a group of valves once per interval when disassembled for maintenance, repair, or volumetric examination.

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1 ISI Program 'evision 0 January 12, 1998 Listing of Class 1 Valves by Group Group Valve Number Zone Number Type Size 1-021 CV-3227 1-022 CV-3217 Check 12 Ii 1-023 CV-3237 1-024 CV-3247 1-021 V-3624 1-022 V-3614 Gate 12 II 1-023 V-3634 1-024 V-3644 1-028 MV-3652 1-028 MV-3651 Gate 10ii 1-029 MV-3480 1-029 MV-3481 1-039 V-3124 1-039 V-3114 Check 6 Il 1-040 V-3144 1-040 V-3134 2.1.2.13 Category B-N-1, Interior of Reactor Vessel; Category B-N-2, Integrally Welded Core Support Structures and Interior Attachments to Reactor Vessels; and Category B-N-3, Removable Core Support Structures B13.10 Reactor Vessel Interior (B-N-1)

Examine accessible areas above and below the reactor core made accessible for exam by removal of components during normal refueling, once each inspection period.

B13.20 Interior Attachments Within Beltline Region (B-N-2)

B13.30 Interior Attachments Beyond Beltline Region (B-N-2)

B13.40 Core Support Structure (B-N-2) 29

St. Lucie 1 ISI Program Revision 0 January 12, 1998 St. Lucie Unit 1 is a Pressurized Water Reactor and the item nos. B13.20, B13.30, and B13.40 do not apply (BWR only) .

B13.50 Interior Attachments Within Beltline Region (B-N-2)

Examine interior attachments within the beltline region

'once 'per interval.

B13.60 Interior Attachments Beyond Beltline Region (B-N-2)

Examine interior attachments beyond the beltline region once per interval. These 'examinations may be deferred until the end of the interval.

B13.70 Core Support Structure (B-N-3)

Examine accessible surfaces of core support structures when removed from the vessel, once per interval. These examinations may be deferred until the end of the interval.

2.1.2.14 Category B-O, Pressure Retaining Welds in Control Rod Housings B14.10 Reactor Vessel Welds in CRD Housing Examine 10< of peripheral CRD housings.

2.1.2.15 Category B-P, All Pressure Retaining Components B15.10 Reactor Vessel Pressure Retaining Boundary (Leakage)

B15.11 Reactor Vessel Pressure Retaining Boundary (Hydro)

B15.20 Pressurizer Pressure Retaining Boundary (Leakage)

B15.21 Pressurizer Pressure Retaining Boundary (Hydro)

B15.30 Steam Generator Pressure Retaining Boundary (Leakage)

B15.31 Steam Generator Pressure Retaining Boundary (Hydro)

B15.40 Heat Exchanger Pressure Retaining Boundary (Leakage)

B15.41 Heat Exchanger Pressure Retaining Boundary (Hydro)

B15.50 Piping Pressure Retaining Boundary (Leakage)

B15.51 Piping Pressure Retaining Boundary (Hydro)

B15.60 Pumps Pressure Retaining Boundary (Leakage)

B15.61 Pumps Pressure Retaining Boundary (Hydro)

B15.70 Valves Pressure Retaining Boundary (Leakage)

B15.71 Valves Pressure Retaining Boundary (Hydro)

System pressure tests are conducted on Class 1 systems and components as follows:

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1 ISI Program Revision 0 January 12, 1998 (a) A IWA-5211(a) conducted prior to plant startup following each occurrence where the Class 1 pressure boundary is breached, such as during a refueling outage.

The pressure retaining boundary subject to the leakage test corresponds to the reactor coolant system boundary, as"e'stablished with all valves aligned as required by approved plant operating procedures for startup and normal reactor operation. The VT-2 examination boundary extends to include the second closed valve at the boundary extremity, which may be a check valve opposing reactor coolant system pressure. The test is conducted at system operating temperature and pressure.

(b) A will be performed in accordance with alternate exam techniques of Code Case N-498-1, "Alternative Rules for 10-Year Hydrostatic Pressure Testing for Class 1 and 2 Systems Section XI, Division I

On systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolted connections for visual examination VT-2 (IWA-5240). The examinations may be performed in accordance with the alternative requirements of Code Case N-533 and Relief Request No. 7 (see page 75).

2.1.2.16 Category B-Q, Steam Generator Tubing B16.20 Steam Generator Tubing in U-Tube Design The extent and frequency of examination are governed by plant Technical Specifications. The steam generator tubing surveillance requirements are contained in plant technical specification 3/4.4.5.

2.1.2.17 Augmented Examinations Reactor Coolant Pump Flywheels As required by Regulatory Guide 1.14, an in place ultrasonic examination of higher stress concentration at the bore and keyway areas of each RCP flywheel are examined at approximately 3 year intervals, during the refueling or maintenance shutdown coinciding with the inservice inspection schedule as required by Section XI.

A surface examination of exposed surfaces and complete ultrasonic volumetric examination will be performed at approximately 10 year intervals.

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St: Lucie 1 ISI Program Revision 0 January 12, 1998 2.2 Class 2 2.2.1 Components Exempt from Examination Subarticle IWB-1220 of the 1989 Edition of Section XI lists those piping and components exempt from examination.

Th'e*folI'owing class 2 systems are exempt from surface and volumetric requirements for reasons other than size:

Exemption Component/Piping System Criteria Accumulator Tank 1A1 to valve V-3225 IWC-1221 (e)

Accumulator Tank 1A2 to valve V-3215 IWC-1221 (e)

Accumulator Tank 1B1 to valve V-3235 IWC-1221(e)

Accumulator Tank 1B2 to valve V-3245 IWC-1221(e)

Containment Spray from valve I-MV-07-3A to IWC-1221(f) spray headers inside containment Containment Spray from valve I-MV-07-3B to IWC-1221(f) spray headers inside containment 2.2.2 Component/Piping Examination Basis 2.2.2.1 Category C-A, Pressure Retaining Welds in Pressure Vessels C1.10 Shell Circumferential Welds Examine 100% of welds at gross structural discontinuities.

The examination may be limited to one vessel or distributed among the vessels.

Cl.20 Head Circumferential Welds Examine 100> of head-to-shell welds, limited to one of multiple vessels.

Cl.30 Tubesheet to Shell Welds Examine 100% of tubesheet to shell welds, limited to one of multiple vessels.

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1 ISI Program Revision 0 January 12, 1998 2.2.2.2 Category C-B, Pressure Retaining Nozzle Welds in Vessels C2.10 Nozzles in Vessels s 1/2" Nominal Thickness C2.11 Nozzle to Shell (or Head) Weld There are no C2.10 or C2.11 items.

C2-.20 -"'Nozzles without Reinforcing Plate in Vessels > 1/2" Nominal Thickness.

C2.21 Nozzle to Shell or Head Welds C2.22 Nozzle Inside Radius Section Examine nozzles at terminal ends of piping runs, limited to one of multiple vessels.

C2.30 Nozzles with Reinforcing Plate in Vessels > 1/2" Nominal Thickness.

C2.31 Reinforcing Plate 'Welds to Nozzle and Vessel Examine nozzles at terminal ends of piping runs, limited to one of multiple vessels.

C2.32 Nozzle to Shell (or Head) Welds When Inside of Vessel is Accessible There are no item no. C2.32 components at St. Lucie.

C2.33 Nozzle to Shell (or Head) Welds When Inside of Vessel is Inaccessible Examine telltale hole in reinforcing plates once each period, limited to one of multiple vessels.

2.2.2.3 Category C-C, Integral Attachments for Class 2 Vessels, Piping, Pumps, and Valves The guidelines of Code Case N-509 will be used in the performance and scheduling of examinations in lieu of the C-C requirements of the 1989 Edition of Section XI.

C3.10 Pressure Vessels, Integrally Welded Attachments There are no integrally welded attachments on the pressure vessels C3.20 Piping, Integrally Welded Attachments 33

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Examine 1004 of the required areas of welded attachments, limited to attachments of components examined per C-F-1 and C-F-2. A minimum of 10% of the Integral Attachments will receive a surface examination. In the case of multiple components within a system of similar design, function, and service, only one of the integral attachments of only one of the multiple components will be examined. The integral

'attachments selected for examination shall correspond to those component supports selected by Code Case N-491 and IWF-2510. Examination is also required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, inservice inspection, or testing.

Examinations performed as a result of support deformation will not be credited under the requirements of inspection program B.

C3.30 Pumps, Integrally Welded Attachments There are no Class 2 Pumps with integrally welded attachments C3.40 -Valves, Integrally Welded Attachments There are no Class 2 Valves with integrally welded attachments 2.2.2.4 Category C-D, Pressure Retaining Bolting > 2" in Diameter C4.10 Pressure Vessel Bolts and Studs C4.20 Piping Bolts and Studs C4.30 Pumps Bolts and Studs C4.40 Valve Bolts and Studs There are no Class 2 pressure retaining bolting greater than 2" 2.2.2.5 Category C-F-1, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping C5.10 Piping Welds z 3/8" Nominal Wall Thickness for Piping > NPS 4 C5.11 Circumferential Weld C5. 12 Longitudinal Weld C5.20 Piping Welds > 1/5" Nominal, Wall Thickness for Piping a NPS 2 and s NPS 4 C5.21 Circumferential Weld C5.22 Longitudinal Weld 34

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1 ISI Program Revision 0 January 12, 1998 C5. 30 Socket Welds C5.40 Pipe Branch Connections of Branch Piping a NPS 2 C5.41 Circumferential Weld C5.42 Longitudinal Weld Examine 7.54, or a minimum of 28 piping welds. The welds to be examined shall be distributed among the systems in a ma'nner such that a representative sample of each system and size is selected.

Longitudinal piping welds will be examined in accordance with the requirements of Relief Request 15 (see page 161) and Code Case N-524.

2.2.2.6 Category C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping C5.50 Piping Welds a 3/8" Nominal Wall Thickness for Piping > NPS 4 C5.51 Circumferential Weld C5.52 Longitudinal Weld C5.60 Piping Welds > 1/5" Nominal Wall Thickness for Piping a NPS 2 and s NPS 4 C5.61 Circumferential Weld C5.62 Longitudinal Weld C5.70 Socket Welds C5.80 Pipe Branch Connections of Branch Piping a NPS 2 C5.81 Circumferential Weld C5.82 Longitudinal Weld Examine 7.5%, or a minimum of 28 piping welds. The welds to be examined shall be distributed among the systems in a manner such that a representative sample of each system and size is selected.

Longitudinal piping welds will be examined in accordance with the requirements of Relief Request 15 (see page 161) and Code Case N-524.

2.2.2.7 Category C-F-3 Those welds that are not exempt and not addressed by the requirements of category C-F-1 are counted as part of the selection criteria. These welds have been given the category of C-F-3 and are for counting purposes only. No examinations are required.

2.2.2.8 Category C-F-4 35

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Those welds that are not exempt and not addressed by the requirements of category C-F-2 are counted as part of the selection criteria. These welds have been given the category of C-F-4 and are for counting purposes only. No examinations are required.

2.2.2.9 Category C-G, Pressure Retaining Welds in Pumps and Valves C6.10 Pump Casing Welds C6.20 Valve Body Welds There are no pressure retaining welds in Class 2 pumps and valves 2.2.2.10 Category C-H, All Pressure Retaining Components C7. 10 Pressure Vessel Pressure Retaining Components (IWC-5221 test each Period)

C7.20 Pressure Vessel Pressure Retaining Components (IWC-5222 test each Interval)

C7.30 piping Pressure Retaining Components (IWC-5221 test each Period)

C7.40 piping Pressure Retaining Components (XWC-5222 test each Interval)

C7.50 Pump Pressure Retaining Components (XWC-5221 test each Period)

C7.60 Pump Pressure Retaining Components (IWC-5222 test each Xnterval)

C7.70 Valve Pressure Retaining Components (IWC-5221 test each Period)

C7.80 Valve Pressure Retaining,.Components (IWC-5222 test each Interval)

The pressure retaining components within the class 2 system boundaries are subjected to System Pressure Tests in accordance with XWC-5210 and visually examined (VT-2) per IWA-5240. The tests are conducted as follows:

(a) System Functional Test; (b) A System Pressure test will be performed in accordance with alternate examination techniques of Code Case N-498-1, "Alternative Rules for 10 Year Hydrostatic Pressure Testing for Class 1 and 2 Systems Section XI, Division 1".

On systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolted 36

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1 ISI Program Revision 0 January 12, 1998 connections for visual examination VT-2 (IWA-5240). The examinations may be performed in accordance with the alternative requirements of Code Case N-533.

2.2.2.11 Class 2 Augmented Examinations (a) Welds in those portions of systems addressed in, USNRC Branch Technical Position APCSB 3.1 para. B.2.c(4);

(b) Welds in those portions of systems addressed in SRP 6.6 paragraph I.8; (c) Welds in those portions of the Steam Generator Feedwater nozzle piping as referenced in IE Bulletin 79-13, "Cracking in Feedwater System Piping."

Examinations will be performed each period and continue until an evaluation concludes these examinations are no longer required.

2.3 Class 3 The Class 3 system boundary examination is based upon the requirements of Regulatory Guide 1.26, and ASME Section XI, Table IWD-2500-1.

2.3.1 ASME Code Exemptions Employed Subarticle IWD-1220 of the 1989 Edition of Section XI lists those piping and components exempt from examination.

The following class 3 systems are exempt from the surface and volumetric requirements for reasons other than size:

Radiator lines from the Emergency Diesels to IWD-1220.2 the radiators 2.3.2 Component/Piping Examination Basis The guidelines of Code Case N-509 will be used in the performance and scheduling of examinations in lieu of the D-A, D-B, and D-C requirements of the 1989 Edition of Section XI.

Examine 104 of the integral attachments, 1004 of required areas of each welded attachment. .In the case of multiple components within a system of similar design, function, and service, one of the integral attachments of one of the

. multiple components will be examined. The integral 37

St. Lucie 1 ISX Program Revision 0 January 12, 1998 attachments selected for examination shall correspond to those component supports selected by Code Case N-491 and IWF-2510. Examination is also required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, inservice inspection, or testing.

Examinations performed as a result of support deformation cannot,'b'e credited under the requirements of inspection program B.

2.3.2.1 Category D-A, Integral Attachments for Class 3 Vessels, Piping, Pumps, and Valves D3.10 Pressure Vessels, Integrally Welded Attachments D3.20 Piping, Integrally Welded Attachments Examine 1004 of required areas of welded attachments.

D3.30 Pumps, Integrally Welded Attachments D3. 40 Valves, Integrally Welded Attachments There are no Category D-A class 3 pump or valve integrally welded attachments at St. Lucie Unit 1.

2.3.3 System Pressure Tests Il 2.3.3.1 The pressure retaining components within the boundary of each system are pressure tested and visually examined (VT-2) for leakage during the following tests:

(a) System Inservice Test or (b) System Functional Test will be performed in accordance with alternate examination techniques of Code Case N-498-1, "Alternative Rules for 10 Year Hydrostatic Pressure Testing for Class 1 and 2 Systems Section XI, Division 1".

2.3.3.2 Pressure Test Requirements The boundaries subject to system Pressure tests, Functional tests, Inservice tests, and Hydrostatic tests are shown in the Piping and Xnstrumentation Diagrams (see Section 5.0).

On systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolted 38

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1 ISI Program Revision 0 January 12, 1998 connections for visual examination VT-2 (IWA-5240). The examinations may be performed in accordance with the alternative requirements of Code Case N-533.

2.3.4 Augmented Examinations No augmented

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examinations are required on class 3 components.

2.4 Metal Containment On September 9, 1996, 10CFR50.55a was amended to include sections IWE and IWL of the 1992 Edition with Addenda through 1992 of Section XI. This amendment requires FPL to implement and complete the initial requirements of these sections with five years. FPL is preparing a plan for all the FPL nuclear plants in order to comply. At this time, the listing of components to be examined is incomplete and is not included within this program.

Repair and replacement requirements must meet the 1992 Edition of Section XI with Addenda through 1992. These requirements have been implemented since September 9, 1996.

2.4.1 Components Exempt from Examination

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Subarticle IWE-1220 of the 1992 Edition with Addenda through 1992 of Section XI lists those components'r parts of components exempt from the examination requirements of IWE-2000.

2.4.2 Examination Basis 2.4.2.1 Category E-A, Containment Surfaces El.10 Containment Vessel, Pressure Retaining Boundary E1.11 Accessible Surface Areas General Visual of essentially 100% of the accessible surface area prior to each Type A test E1.12 Accessible Surface Areas Visual (VT-3) of 1004 of accessible surface areas within the last period of the interval E1.20 Vent System, Accessible Surface Areas Visual (VT-3) of 100~ of accessible surface areas within the last period of the interval 39

St. Lucie 1 ISI Program Revision 0 January 12, 1998 2.4.2.2 Category E-"B, Pressure Retaining Welds E3.10 Containment Penetration Welds E3.11 Longitudinal E3.12 Circumferential E3.13 Flued Head and Bellows Seal Circumferential Welds VJ Joined to the Penetration Examine 25% of the total number of welds. Includes only those welds subject to cyclic loads and thermal stress during normal plant operation.

E3.20 Flange Welds (Category C)

Examine 25~ of the total number of welds.

E3.30 Nozzle to Shell Welds (Category D)

Examine 25% of the total number of welds.

2.4.2.3 Category E-C, Containment Surfaces Requiring Augmented Examinations E4.10 Containment Surface Areas E4.11 Visible Surfaces surface areas identified by IWE-1242, 100<

'xamine examination of area for each inspection period until the areas examined remain essentially unchanged for three consecutive inspection periods. Then the area may revert to the original schedule of inspections.

E4.12 Surface Area Grid, Minimum Wall Thickness Location Examine 100% of minimum wall thickness locations during each inspection period, established in accordance with IWE-2500(c)(3) and IWE-2500(c)(4).

2.4.2.4 Category E-D, Seals, Gaskets, and Moisture Barriers E5.10 Seals E5.20 Gaskets E5.30 Moisture Barriers Examine 100% of each item.

2.4.2.5 Category E-F, Pressure Retaining Dissimilar Metal Welds E7.10 Dissimilar Metal Welds 40

Revision 0 January 12, 1998 Examine 504 of the total number of welds. Includes only those welds subject to cyclic loads and thermal stress during normal plant operation. Different welds shall be selected each interval.

2.4.2.6 Category E-G, Pressure Retaining Bolting E8.10 -'olted Connections Examine 100% of each bolted connection.

E8.20 Bolted Connections Bolt torque or, tension test to be performed on bolted connections that have not been disassembled and reassembled during the inspection interval.

2.4.2.7 Category E-P, All Pressure Retaining Components E9.10 Pressure Retaining Boundary Perform system leakage test in accordance with 10CFR50, Appendix J during each repair, modification, or replacement.

E9.20 Containment Bellows Perform 10CFR50,Appendix J, type B test.

E9.30 Airlocks Perform 10CFR50,Appendix J, type B test.

E9.40 Seals and Gaskets Perform 10CFR50,Appendix J, type B test.

2.5 Component Supports Component supports subject to examination are selected in accordance with Code Case N-491.

2.5.1 ASME Code Exemptions Employed Subarticle IWF-1230 of Code Case N-491 lists those piping and components exempt from examination.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 2.5.2 Support Examination Basis To the extent practical, the same supports selected .for examination during the first and second inspection intervals were selected for examination during the third inspection interval.

2.5.2.1'ategory F-A Fl.10 Class 1 Piping Supports Examine 25% of Class 1 piping supports F1.20 Class 2 Piping Supports Examine 154 of Class 2 piping supports F1.30 Class 3 Piping Supports Examine 10% of Class 3 piping supports The total percentage sample shall be comprised of supports from each system (e.g., Main Steam, Feedwater, or RHR), where the individual sample sizes are proportional to the total number of nonexempt supports of each type and function within each system.

F1.40 Supports Other Than Piping Supports Examine the supports of only one of the multiple components within a system of similar design, function, and service.

2.5.2.2 Item Numbers Item numbers will be categorized to identify support types by component support function.

A Single Acting Restraints B Double Acting Restraints C Spring Hangers and Supports D Anchors P Pumps S Snubbers V Vessels and Heat Exchangers W Welded Stanchions Other codes may be used as required.

Several supports hold more than one classified line. These supports are counted only once and if scheduled for 42

Revision 0 January 12, 1998 examination, will cover all of the applicable lines. The support will be counted once for credit.

2.5.2.3 Augmented Examinations No augmented examinations are required on component supports.

2.6 ConcreteContainment St. Lucie Unit 1 has a concrete missile shield surrounding the metal containment. This missile shield does not perform any containment functions and is outside the, scope of Section XI. 'No examinations are required.

The bottom of containment has a metal liner, covered with concrete. The concrete serves only as a protective covering and is outside the scope of Section XI. No examinations are required.

2.7 Successive Examinations 2.7.1 Class 1 When examinations reveal the presence of flaw indications that exceed the acceptance standards and the component is analyzed as acceptable for service by analytical evaluation (see section 4.4), the areas containing the flaw indications will be scheduled for reexamination during the next three inspection periods of inspection program B (IWB-2412 and IWB-2420). Provided the flaw indications remain essentially unchanged over those periods, the component examination schedule will revert to the original schedule of successive inspections.

2.7.2 Class 2 When examinations reveal the presence of flaw indications that exceed the acceptance standards and the component is analyzed as acceptable for service by analytical evaluation (see section 4.4 and IWC-2420), the areas containing the flaw indications will be scheduled for reexamination during the next inspection period of inspection program B (IWC-2412).

Provided the flaw indications remain essentially unchanged over that period; the component examination schedule will revert to the original schedule of successive inspections.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 2.7.3 Class 3 Class 3 components with flaw indications that exceed the acceptance standards and are analyzed as acceptable for continued service by analytical evaluation (see section 4.4) need not be scheduled for reexamination except as required by inspection program B (IWD-2412).

2.7.4 Component Supports When a component support must be subjected to corrective measures in accordance with during the next inspection period. Ifit IWF-3000, will be reexamined additional corrective measures are not required, examinations will revert back to the original schedule.

2.8 Substitute Examinations FPL may substitute unscheduled components for scheduled components. This substitution may be performed when conditions such as limited physical access, high radiation levels, or other situations which necessitate a substitute examination exist. Substituted components will meet the scheduling requirements of Inspection Program B and the appropriate Code category. Specific examinations required by the Code that cannot be completed will be the subject of a relief request.

3.0 Relief Requests During previous Inspection Intervals, there were cases where component configuration and/or interference prevented the code required volume or surface area from being examined. In each case where limitations were encountered, the details were documented in a relief request.

Areas where Code required coverage was not attained will be submitted to the USNRC in the form of a relief request. These areas include:

On Class 1 and 2 weld examinations, relief will be required if (see less than 904 of the Code required coverage was achieved Code Case N-460).

All other components where the Code examination coverage was not attained.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief requests will be reviewed for completeness, technical adequacy, and implementation. Reviewers may be the site ISI Coordinators, the ISI Specialist, NDE personnel, and any other group the relief request may affect.

Relief requests are found starting on page 65.

4.0 Evaluation Criteria Florida Power and Light will perform non-destructive examinations using visual, surface (Penetrant and Magnetic Particle), and volumetric (Ultrasonic, Radiography, and Eddy Current) techniques. Other NDE techniques may be utilized when required.

During inservice inspections, NDE indications are evaluated against the acceptance standards of ASME Section XI. Components with indications that do not exceed the acceptance criteria will be considered acceptable for continued service. Additional examinations are not required.

Examinations that reveal indications exceeding the acceptance standards will be made acceptable by. an engineering evaluation, repair, replacement, or an analytical evaluation.

4.1 Acceptance by Engineering Evaluation Examinations that reveal indications exceeding the acceptance standards may be submitted to Nuclear Engineering for evaluation and disposition as follows:.

A. Indications determined to be acceptableby the FPL design and/or manufacturer's specifications shall be acceptable for continued service provided they meet the minimum requirements of the construction code.

B. Indications determined to be surface anomalies (e.g fabrication marks, scratches, surface abrasion, material roughness, or other conditions) are acceptable for continued service. They may be removed by light flapping and/or grinding (surface preparation) without violating the design minimum wall thickness.

4.2 Acceptance by Repair Components whose volumetric or surface examination reveals indications exceeding the acceptance criteria shall be unacceptable for continued service until repaired. Repairs are further covered by section 7.0.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 4.3 Acceptance by Replacement As an alternative to repairing the component, the portion of the component containing the indication may be replaced.

Replacements are further covered by section 7.0.

'4.4 Acceptance by Analytical Evaluation Components whose volumetric or surface examination reveals indications exceeding the acceptance criteria are acceptable for continued service without repair or replacement analytical evaluation meets the acceptance criteria of IWB-if an 3600.

4.5 Component Support Indications As 'an alternative to repair or replacement, if an evaluation is conducted on a component support in accordance with IWF-3122.3 and the support is analyzed and/or tested to the extent necessary to substantiate its integrity for its intended service, then corrective action and additional examinations are not required (but may be performed) . When component supports must be subjected to corrective measures in accordance with IWF-3000, additional examinations will be performed. See Code Case N-491.

Table 4.1 lists areas which FPL considers to be maintenance.

If parts are replaced, baseline examinations will be conducted as appropriate.

Table 4.1 Corrective Action Condition Corrective Action Re-exam Damaged, missing, Replace with new cotter No corroded or loose pin or retainer or tighten cotter pins and as necessary retainers Mild rust/corrosion on Clean and lubricate with No spherical bearings graphite Gross rust/corrosion Replace spherical bearing 'Yes on spherical bearing and restake Mild rust/corrosion on Clean and reinspect for Yes hanger/support further degradation, re aint su ort 46

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1 ISI Program Revision 0 January 12, 1998 Condition Corrective Action Re-exam Paint on tags, Remove paint with solvent No indicators etc.

Foreign material, Clean load pin with scotch No corrosion on load pin brite pad or equivalent, wipe clean and apply a light film of machine oil Spherical bearing is Reseat spherical bearing Yes loose or dislodged and restake Misalignment of loosen pipe clamp & Yes hanger/support realign in accordance with original drawing Standard nut, used as lock nut shall have at No a lock nut, does not least 50% thread have full thread engagement engagement Replace as necessary Yes Spherical bearing is Lubricate and work bearing No frozen until loose Replace as necessary Yes FPL will consider as acceptable paint spatter found on close tolerance machined or sliding surfaces as long as it has been determined that its presence does not interfere with the function of the support.

4.6 Supplemental Examinations Volumetric, visual, or surface examinations that detect indications requiring evaluation may be supplemented by other examination methods and techniques to determine the character of the indication.

4.7 Additional Examinations Additional examinations that are required in accordance with IWB-2430, IWC-2430, IWE-2430, and IWF-2430 will be performed before the end of the refueling outage.

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St. Lucie 1 XSI Program Revision 0 January 12,- 1998 4.8 Minimum Thread Engagement Requirements St. Lucie Nuclear Engineering has reviewed the Code requirements applicable to thread engagement for safety related bolted connections. FPL Discipline Standard STD-C-011, "Acceptance Criteria for As-Built Safety Related Piping and Pipe Supports," and Specification SPEC-M-004, "Maintenance Bolting Specification for St. Lucie Units 1 and 2 and Turkey Point Units 3 and 4" will be used as guidance for determining whether thread engagement is adequate.

Bolting that does not meet this criteria shall be unacceptable for continued use until an engineering evaluation has been completed and approval for continued use is obtained or the bolting has been repaired or replaced.

5.0 Program Boundary Drawings The code required boundaries for all Class 1, 2, and 3 systems are denoted by a boxed-in letter (A, B, and C respectively) on Piping and Instrument Diagrams (P&IDs). The following list shows those P&IDs applicable to the St. Lucie ZSI Program.

Drawing Sheet P&ZD Title Number Number 8770-G-078 110A Reactor Coolant System 110B 8770-G-078 111A Reactor Coolant Pump 1A1 8770-G-078 111B Reactor Coolant Pump 1A2 8770-G-078 111C Reactor Coolant Pump 1Bl 8770-G-078 111D Reactor Coolant Pump 1B2 8770-G-078 120A Chemical and Volume Control System 120B 8770-G-078 121A Chemical and Volume Control System 121B 8770-G-078 130A Safety Injection System 130B 8770-G-078 131A Safety Injection System 131B 8770-G-078 140 Fuel Pool S stem a

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Drawing Sheet PAID Title Number Number 8770-G-079 Main Steam 8770-G-080 3 Feedwater and Condensate Systems 4

8770-G-082 Circulating and Intake Cooling Water System 8770-G-082 Intake Cooling Water Lube Water System 8770-G-083 1A Component Cooling System 1B 8770-G-083 Component Coolin System 8770-G-086 Miscellaneous Systems 8770-G-088 Containment Spray and Refueling Water Systems 8770-G-096 1A Emergency Diesel Generator System, Diesel Engine 1A1 8770-G-096 1B Emergency Diesel Generator System, Diesel Engine lA2 8770-G-096 Emergency Diesel Generator System, Air Start Package lA 8770-G-096 2A Emergency Diesel Generator System, Diesel Engine 1B1 8770-G-096 2B Emergency Diesel Generator System, Diesel En ine 1B2 8770-G-096 2C Emergency Diesel Generator System, 49

St. Lucie 1 ISX Program Revision 0 January 12, 1998 6.0 Records 6.1 General Records of Inservice Xnspection Program, Plans, outage schedules, calibration standards, examination and test procedures, results of activities, final reports, certifications, and corrective actions will be, developed and maintained in accordance with IWA-6000.

6.2 Nondestructive Examinations Completed NDE examination data packages shall be submitted to the ISX Specialist following completion of the inservice examination activity.

6.3 Final Reports Final reports will be generated for the following activities:

a. .Nondestructive examination activities performed on Class 1, 2, and 3 systems, components and their supports

b. Nondestructive examination activities performed on Class MC systems

c. Snubber examinations and tests

d. System, pressure tests

e. Eddy current examinations

f. Repairs and replacements 6.4 Final Report Format Final reports shall contain, as a minimum, the information required in the NIS-1 or OAR-1 (Code Case N-532), as applicable.

6.5 Inservice Inspection Summary Reports Ninety days following the end of the outage (defined by FPL as "breaker closed" ), FPL shall forward a Summary Report NIS-1 and NIS-2 of ISI activities and Repair and Replacements to the Nuclear Regulatory Commission in accordance with IWA-6220; or 50 0

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1 ISI Program Revision 0 January 12, 1998 FPL shall submit an Owners Activity Report (OAR-1) of ISI activities to the Nuclear Regulatory Commission in accordance with Code Case N-532 following the end of the inspection period; and Th'e'NIS-BB report will be submitted to the NRC.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 DATE: 02/11/98 (A) ST ~ LUCIE NUCLEAR PLANT UNIT 1 (D) PAGE: 1 INSERVICE INSPECTION SUHMARY REPORT THIRD INTERVAL, FIRST PERIOD, FIRST OUTAGE (1997)

CLASS 1 ALL STATUS COMPOHENTS (E) (C)

N I 0 ZONE NUMBER  : 1-001 (F) ASME S ONGT SEC. XI T RSEH

SUMMARY

EXAMINATION AREA CATGY EXAM A E I 0 E REHARKS NUMBER IDEHTIFICATION ' ~ ~

ITEH NO METHOD PROCEDURE T C G M R **CALIBRATIONBLOCK**

(G) 000060 204-02 (I) (L) B-A UT 0 HDE 5.4 C X- 2/98 - DATE AHD REMARKS ON COMPLETED (H) DOLLAR PLATE WELD (J) (M) B1.21 UT 45 NDE 5.4 (P) X- EXAM UT 45T NDE 5.4 X- (S)

UT 60 NDE 5.4 X-UT 60T NDE 5.4 X- ** UT-1, UT-4 **

(N) (0) (R)

(A) Date the inspection plan table was printed (C) Specific outage and classification of system (D) Page number of the table (E) System description (F) Unit Zone number (G) System /

(H) Summary number of the ISI sketch record (I) Component or weld identification (J) Component or weld description (L) ASME Code category (M) ASME Code item number (N) NDE methods (0) Procedure number (P) Shows status of examination X Scheduled C Completed A Augmented P Partial B Baseline E Expanded Scope Examination No Status (Other codes may be used as necessary)

(Q) Types of indications found (R) Ultrasonic calibration block (S) Remarks on examinations performed during this outage Figure 6.1 Inservice Inspection Summary Record 52

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1 ISI Program Revision 0 January 12, 1998 7.0 Repairs, Replacements, and Modifications The requirements of the 1989 Edition of Section XI and the Repair and Replacement Program for St. Lucie Nuclear Power Plant, shall be met for Class 1, 2, and 3 piping and components.

The requirements of the 1992 Edition with Addenda through 1992 of Section XI and the Repair and Replacement Program for St. Lucie Nuclear Power Plant, shall be met for Class MC components.

7.1 Repairs on Class 1, 2, and 3 Systems 7.1.1 Code'epairs are performed in accordance with approved procedures or instructions in accordance with IWA-4000.

7.1.2 Repair operations shall be performed in accordance with a program delineating essential requirements of the complete repair cycle and shall include the following:

a. The non-destructive method that revealed the flaw and a description of the flaw;

b. the flaw removal method, method of measurement of the cavity created by removing the flaw, and dimensional requirements for reference points during and after the repair;

c. weld procedures and postweld heat. treatment, if applicable, and the nondestructive examination methods to be used after the repair;

d. the repair programs shall be subject to review by the enforcement and regulatory authorities having jurisdiction at the plant site.

7.1.3 After repairs by welding on the pressure retaining boundary, a system pressure test shall be performed in accordance with IWA-5000 (when required by IWA-4700).

7.1.4 The repaired area shall be reexamined to establish a new preservice record. The examination shall include the method that detected the flaw.

7.2 Replacements on Class 1, 2, 3, and MC Systems 7.2.1 Replacements are performed using approved procedures or instructions in accordance with IWA-7000. The Program for replacements shall include the following:

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St. Lucie 1 ISI Program Revision 0 January 12, 1998

a. The applicable Edition and Addenda of Section XI;

b. a description of the items being replaced and the Codes to which they were constructed;

c. a description o f the work to be per formed; d;'he 'Code Edition, Addenda and Code Cases applicable to materials, design manufacture, and installation;

e. any special requirements pertaining to materials, welding, heat treatment, and nondestructive examination requirements;

f. the test and acceptance criteria to be used to verify the acceptability of the replacement;

g. the documentation required by IWA-7500;

h. the application of the ASME Code Symbol Stamp in accordance with IWA-7300.

7.2.2 Replacements that involve substitution of materials, dimensional changes, process changes, deviations to specifications or changes to design codes require engineering approval.

7.2.3 Procedures for the installation of renewal, spare, and replacement parts shall be in accordance with IWA-4100.

7.2.4 Prior to the systems return to service, a preservice examination shall be made in accordance with IWB-2200, IWC-2200, IWD-2200, or IWF-2200, as applicable, for the component and part replaced.

7.3 Modifications The performance of modifications is controlled in accordance with applicable procedures.

7.4 Evaluation When equipment cannot be restored to design configuration, equipment substitutions are needed, or conditional use is necessary, and plant modifications are deemed inappropriate for various reasons, the necessary engineering evaluations shall be documented.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 7.5 Access Adequate access and clearances for examination and tests shall be considered by Nuclear Engineering as part of the processing of design or arrangement changes of system components in accordance with applicable procedures.

7.6 Determination of Design and Construction Codes 7.6. 1 Components, parts, and piping shall be procured to the requirements of the original Construction Code of the component or system. Later editions and addenda of the Construction Code may be used provided they are in accordance with IWA-7210.

7.6.2 The design and analysis of piping, components and supports shall meet the design code of record as identified in the FSAR or design specification.

7.6. 3 Welding activities shall meet the requirements of the original construction code. Alternatively, Nuclear Engineering may specify that the use of a later edition of the construction code, or Section III, as identified in the welding control manual.

Later editions and addenda may be used provided that 'they have been endorsed by the USNRC and are incorporated in 10 CFR 50.55a(g).

7.7 Authorized Nuclear Inservice Inspector The services of an Authorized Inspection Agency shall be used when making repairs. FPL shall notify the Authorized Nuclear Inservice Inspector (ANII) prior to starting the repair, replacement, or modification, and keep the inspector informed of the progress of the work so necessary inspections may be performed.

8.0 Inservice Inspection Plan and Schedules 8.1 Inspection Plan Tables The Inservice Inspection Plan Tables for inservice examinations of the major components of Florida Power and Light, will be in a format similar to the table found on page 57. The inspection plan has been divided into zones.

ISI Sketches locate welds and other examination areas for each zone.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 8.2 Ten Year Inspection Plan The Ten Year Inspection Plan provides the following information (see figure 8.2):

Program Summary Number Each weld or component is assigned a unique summary number. These are for administrative controI'nd are subject to change. This provides a method for accessing multiple data bases relating to each weld or component.

Code Category The Code category from tables IWB-2500-1, IWC-2500-1, 'IWD-2500-1, or IWF-2500-1, as applicable.

Item Number The Code item number from applicable IWX-2500-1 table, of the ASME Boiler and Pressure Vessel Code, Section XI.

Component Identification The component or weld identification number. This number appears on the applicable ISI sketch.

Component Description A brief description of the component or the parts being joined.

Code Exam Method The examination method(s) suggested for each component or weld, if applicable.

ISI Interval The numbers 1, 2, 3, or 4 signify which ten-year interval. The current inspection interval relating to this table is number 3 (see Figure). An "X" will be placed in the scheduled outage in which it will be examined or an "A", "B", "C" "E" or "P" to show when the examination took place and the type of exam performed. Other letter codes may be used as needed.

Instructions Identifies specific examination notes.

8.3 Weld Identification Welds and other components that are subject to examination and have not been identified by plant drawings have been assigned identification numbers for tracking purposes.

When new longitudinal seam welds are identified, they reference the intersecting circumferential weld.

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1 ISI Program Revision 0 January 12, 1998 DATE: 02/11/98 (A) ST. LUCIE NUCLEAR PLANT UNIT 1 (D) PAGE: 1 TEH-YEAR IHSERVICE INSPECTION PLAH CLASS 1 COMPONENTS (C)

INSPECTION INTERVAL PLAN STATUS (E) I FIRST SECOND THIRD I ZONE NUMBER: 1-001 (F) ASME PERIOD PERIOD PERIOD

'TEM I I SEC ~ XI

SUMMARY

EXAMINATIOH AREA CATGY HDE ------OUTAGE-. I INSTRUCTIONS

'NUMBER IDENTIFICATION NO METH 1 2 3 1 2 3 1 2 3 **CALIBRATIOHBLOCK~*

(G) 000060 204-02 (I) (L) 8-A SUR 3 - - - - C (P)

(H) DOLLAR PLATE MELD (J) (M) B1.21 VOL (H)

• • (0) **

(0)

(A) Date the inspection plan table was printed (C) Classification of system (D) Page number of the table (E) System description (F) Unit Zone number (G) ISI sketch no.

(H) Summary number of the record (I) Component or weld identification (J) Component or weld description (L) ASME Code category (M) ASME Code item number (N) NDE method(s)

(0) Shows when an item was examined or is scheduled to be examined. Intervals can be shown separately.

A Augmented B Baseline C Completed E Expanded Scope P Partial 0 Other X Scheduled No Status (Other Codes may be used as needed)

(P) Specific instructions for this component (Q) Ultrasonic calibration block Figure 8.2 Inspection Plan Table Format 57

St. Lucie 1 ISI Program Revision 0 January 12, 1998 9.0 Nondestructive Examination Procedures The following is a list of the standard NDE procedures used for ISI activities. The specific revision used during an activity will be listed on the applicable NDE data sheet. Other NDE procedures may be used as required, providing they have been approved for use by the ANII.

Procedure Title No.

NDE 1. 3 Eddy Current Examinations of Non Ferro-magnetic Tubing with Multi Frequency Techniques MIZ-18/MIZ-30 NDE 2.2 Magnetic Particle Examination NDE 3.3 Liquid Penetrant Examination Solvent Removable Visible Dye Technique NDE 4. 1 Visual Examination VT-1 for Welds/Boltin /Bushings/Washers NDE 4. 2 Visual Examination VT-2 Conducted During System Pressure Tests NDE 4.3 Visual Examination VT-3 NDE 4.4 Steam Generator Secondary Side Visual Examination NDE 5.1 Ultrasonic Examination of Pressure Vessel Welds NDE 5.2 Ultrasonic Examination of Ferritic Piping Welds NDE 5. 4 Ultrasonic Examination of Austenitic Piping Welds and c 2" Thick Vessels and Piping Dissimilar Metal Welds NDE 5.7 Ultrasonic Examination of Reactor Pressure Vessel Studs and Reactor Coolant Pump Studs NDE 5. 8 Ultrasonic Examination of Bolting Material for Crackin NDE 5. 10 Ultrasonic Examination of Nuts Two Inches in Diameter or Greater NDE 5. 12 Manual Ultrasonic Examination of Reactor Vessel Flange to Shell Welds and Stud Hole Threads NDE 5.13 Ultrasonic Examination of Nozzle Inner Radius Areas NDE 5. 15 Ultrasonic Examination of Reactor Coolant Pump Fl wheels 58

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1 ISI Program Revision 0 January 12, 1998 Procedure Title No.

NDE 5. 16 Ultrasonic Examination Technique for the Evaluation of Cracking in Steam. Generator Feedwater Piping NDE 5..18 .Ultrasonic Thickness Measurement NDE 5. 19 Ultrasonic Examination of Socket welds in the Pressurizer Auxiliary Spray Line PTN-3/4 NDE 5.20 Ultrasonic Flaw Sizing NDE 5.21 In-Place Surface Examination Technique of Reactor Coolant Pump Flywheels Using Ultrasonics NDE 5.22 Ultrasonic Examination of Small Bore Nozzle Penetrations and Inconel Weld Material Build-up Areas 10.0 Calibration Blocks Calibration blocks are maintained and controlled at the St. Lucie

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St. Lucie Calibration Blocks Cal. Material Size Application Block Number UT-1 SA-533 GR. B RPV Upper Shell UT-2 SA-533 GR. B 9 II RPV UT-3A SA-533 GR. B 7 II RPV UT-4 SA-533 GR. B 5 II RPV UT-4A SA-533 CL. 1, GR. B 5 II PZR UT-5 SA-533 CL. 1, GR. B 3 II 3" RC Piping UT-6 SA-516 GR. 70 W/304L 3 5 II RC Piping CLAD UT-7 'SA-516 GR. 70 CLAD 3 II UT-7A SA-516 GR. 70 UNCLAD 3 II 59

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Cal. Material Size Application Block Number UT-8 SA-533 GR. B 7 II RPV Flange Li ament UT-9 SA-533 GR. B RPV Inlet Nozzle UT-10 SA-533 GR. B RPV Outlet Nozzle UT-11 SA-533 GR. B Obsolete/Not Used UT-12 SA-533 GR. B Obsolete/Not Used UT-13 SA-533 GR.B Obsolete/Not Used UT-14 SA-533 GR.B Obsolete/Not Used UT-15 SA-516 GR. 70 W/304L Training Only, Replaced by ROLL BOND/316 UT-59 UT-16 SA-351 CFSM 1. 25 12.75" Diameter SA-106 GR. B Safe Ends UT-17 SA-182,TP316 1. 25II 6" Diameter Safe SA-533 CL 1 A Ends UT-18 SA-182 TP316 SA-533 CL 1 A

l. 25" 5" Diameter Safe Ends UT-19 SA-182 TP316 625 4 5/8" Diameter SA-533 CL 1 A Safe Ends UT-20 SA-540 B-24 Obsolete/Not Used UT-21 SA-540 B-23 Obsolete/Not Used UT-22 SA-182 TP304 5.56 O. D. RPV INCONEL 600 Instrument Nozzle UT-23 SA-351 CFSM 1. 312II 12.75" Diameter Pressurizer Surge Nozzle Safe End UT-24 No Block Identified with this Number UT-25 SA-533 GR.B 5 lt Flat Steam Generator CL. II UT-26 No Block Identified with this Number 60

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1 ISI Program Revision 0 January 12, 1998 Cal. Material Size Application Block Number UT-27 SA-533 GR.B 7 II Flat/Clad Steam Generator Primary Head UT-28A SA-533 GR.B CL1 4 II Clad UT-29 SA-516 GR.70 18" Diameter Feedwater UT-30 No Block Identified with this E

Number UT-31 SA-516 GR.70 1.625" Flat Block UT-32 SA-533 GR.B 2 II Stay Cylinder UT-33 SA-182 TP316 Letdown 6 Drain SA-533 CL1 7/8" Nozzle Safe End UT-34 SA-182 TP316 4 5 II Spray Nozzle SA-533 CL1 9 3 II Safe End UT-35 SA-376 (SA-312) 1.34" 12" Sch. 160 UT-36 No Block Identified with this Number UT-37 TP304 1. 125 10.75" O.D. Not Used UT-38 SA-312 TP304 . 719" 6" Sch. 160 Piping UT-39 SA-3 12 TP3 04 . 531" 4" Sch. 160 Pipin UT-40 SA-312 TP316 . 531" 20" Sch. 80 Pipin UT-41 A-106 GR.B 1 ~ 031 20" Sch. 80 Piping UT-42 A-106 GR.B 1.50 20" Sch. 120 Piping UT-43 A-106 GR.B 938 18" Sch. 80 Piping UT-44 A-515 GR 70 2 II 35.5" Diameter 61

St.- Lucie 1 ISI Program Revision 0 h

January 12, 1998 Cal. Material Size Application Block Number UT-45 A-155/515 GR.65 1.250" 34" Diameter UT-46 A-106 GR.B 1.125" 10" Sch. 160 UT-47 A-106 GR.B .594" 10sr Sch. 80 UT-48 A-106 GR. B .906" 8" Sch. 160 UT-49 A-519 511 UT-50 A-182 TP304 1.56 12" Sch. 160 UT-51 No Block Identified with this Number UT-52 No Block Identified with this Number UT-53 No Block Identified with this Number UT-54 A-312 TP304 .562" 6" Sch. 120 UT-55 No Block Identified with this Number UT-56 A-516-79B GR.70 1.15" 1" + Clad Flat Plate UT-57 No Block Identified with this Number UT-58 SA-540 GR.B23 4.75" RCP Stud UT-59 A-351 CF8M Reactor Coolant Pump Safe End Block 11.0 Removal or Addition of Welds and Components The 1989 Edition of Section XI does not address the steps to be taken when additions or deletions to the program are necessary.

The following may be used for selection and scheduling of examinations for the new welds (taken from the 1992 Edition of Section Xt with Addenda through 1994, IWB-2412(b), IWC-2412(b),

IWD-2412(b), IWF-2412(c)):

When items or welds are added during the first period of the interval, at least 25> of the examinations required by the applicable examination category and item number, for the added items or welds shall be performed during each of the second and third periods of that interval. Alternatively, 62

St. Lucie 1 ISI Program Revision 0 January 12, 1998 if deferral of the examinations is permitted for the examination category and item number, the second period examinations may be deferred to the third period and at least 50% of the examinations required by the applicable examination category and item'umber for the added items or welds shall be performed during the third period.

2 ~ When iC'ems or welds are added during the second period of the interval, at least 25% of the examinations required by the applicable examination category and item number for the added items or welds shall be, performed during the third period of that. interval.

3. When items or welds are added during the third period of the interval, examinations shall be scheduled in accordance with IWB-2412(a) for successive intervals.

4 ~ New components and welds, deleted welds may be summarized in the NIS-1 or OAR-1 submittal.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Requests 64

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Description Status Request Use of Code Case N-532 Submitted Use of Code Case N-533 Submitted 3 Use of Code Case N-546 Submitted Use of Code Case N-566 Submitted RPV Weld 209-04 Submitted Alternative Snubber Submitted Examinations Refueling Water Tank Non-Code Submitted Repair Scheduling of Examinations Submitted Reactor Pressure Vessel Nuts Submitted 10 Reactor Pressure Vessel Studs Submitted Use of Code Case N-416-1 Submitted 12 Use of Code Case N-498-1 Submitted 13 Use of Code Case N-509 Submitted 14 Use of Code Case N-521 Submitted 15 Use of Code Case N-524 Submitted 16 Alternative Piping Weld Submitted Examination 65

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Request No. 1, Use of Code Case N-532 Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required IWA-6000 reporting requirements as specified in the 1989 Edition of ASME Section XI.

'I. Identifi'cation*

NIS-1 and NIS-2 reports to be submitted at the end of each refueling outage.

II. Code Requirement:

ASME Section XI, 1989 Edition Article IWA-6000, Records and Reports The Owner shall prepare records of the examinations, tests, replacements, and repairs ... prepare Preservice and Xnservice inspection Summary Reports for Class 1 and 2 pressure retaining components and their supports ... Inservice inspection summary reports shall be prepared at the completion of each inspection conducted during a refueling outage ... examinations, tests, replacements, and repairs conducted since the preceding summary report shall be included ... summary reports shall contain an Owners Report for Inservice Inspections, Form NIS-1, and Owners Report for Repair and Replacement, Form NIS-2 ... the Owner shall...within 90 days of the completion of the inservice inspection conducted during a refueling outage, file inservice inspection summary reports with the enforcement and regulatory authorities having jurisdiction at the plant site.

III. Relief Requested:

Relief is being requested from preparing the NXS-1 and NIS-2 forms for reporting the results of inservice inspection activities after each outage as prescribed by Section XI. FPL will utilize the alternative requirements in ASME Code Case N-532, Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 IV. Basis for Relief The documentation required by IWA-6000 includes the NIS-1 and NIS-2 forms. These forms give a summary of the status of the examinations. They include what components and piping systems were examined. They do not require the inclusion of Class 3 components or the new IWE and IWL'xaminations.

The information included on the NIS-1 is verified by the ANII, and reviewed by several other groups. These may include QA auditors and the USNRC. By submitting the NIS-1 to the regulatory agencies having jurisdiction at the plant, it the same information is being reviewed one more time by personnel means who have little or no knowledge of plant specifics.

The NIS-2 report on repairs and replacements lists the 'components where work has been performed. Again, the ANII reviews and verifies each report. Some of these reports are reviewed by USNRC inspectors during refuel outages. Sending these reports to the regulatory agencies does not provide any detail about the repair or replacement.

V.~ Alternative Documentation:

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FPL will prepare

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OAR-1 and NIS-2A forms in accordance with the requirements of Code Case N-532.

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The forms will be submitted after the end of the period.

For Table 1 of the Code Case, FPL will provide the required information. On those Code Categories that are covered by requirements other than Section XI (i.e. Code Category B-Q for steam generator tubes), a note will be placed in the table explaining the details.

For Table 2, items with flaws or relevant conditions that required evaluation for continued service in accordance with the following will be included:

IWB-3132. 4, Acceptance by Analyti cal Eval uati on, IWB-3142. 4, Acceptance by Anal yti cal Eval ua ti on, IWC-3122.4, Acceptance by Evaluati on IWC-3132. 4, Acceptance by Eval uati on IWD-3000, Acceptance Standards (the rules of IWB-3000 will be used)

IWE-3122.4, Acceptance by Evaluation (92A92 Code)

IWF-3112.3, Acceptance by Evaluation or Test IWL-3122. 4, Acceptance by Eval ua ti on or Test (92A92 Code) 67

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Flaws meeting the intent of the above sections will be included.

This will preclude the evaluation of geometric and acceptable indications from appearing on the report.

For Table 3, Repairs, Replacements, or Corrective Measures that were required for continued service since the previous OAR-1 Form (or NIS-1 form)

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was written will be included.

VI. Justification of Relief:

Code Case N-532 is an alternative to the documentation requirements of IWA-6000 of Section XI. Use of this alternative reduces the documentation required to be gathered and submitted each outage. Submittals are reduced to once at the end of the period. The forms in the Code Case enhance the type of information being submitted, being more specific in the number of examinations performed and what types of problems were encountered. FPL will use this Code Case to replace the NIS-1 and NIS-2 reports.

The current requirement is to submit the NIS-1 and NIS-2 summary reports to the enforcement and regulatory authorities having jurisdiction at the plant site within 90 days of the end of the outage. The NIS-1 report gives a summary of the types of examinations performed and the results. The NIS-2 reports give details on Repairs and Replacements. Code Case N-532 allows the 0

use of the OAR-1 form and three tables of examination information and the NIS-2A forms as replacements.

By using this Code Case, FPL will reduce the amount of information to be submitted, but will provide more specific information about the status of examinations. This will reduce the amount of time and costs involved in collection of the data, and provide more specific information to the enforcement and regulatory agencies having jurisdiction at the plant site.

Code Case N-532 requires specific Program B information to be submitted. The preparation of the Code required documentation involves excessive cost and man-hours. The information provided with the NIS-1 and NIS-2 forms does not provide any supporting evidence of the status of examinations performed.

Code Case N-532 was approved for use by ASME on December 12, 1994, as an alternative to the Code required documentation of IWA-6000. Use of this Code Case provides an acceptable level of quality and safety by the use of alternate documentation that enhances the process of determining requirements of Section XI.

if FPL has met the 68

St. Lucie 1 ISI Program Revision 0 January 12, 1998 VII. Implementation Schedule:

FPL will implement ASME Code Case N-532 during the St. Lucie 1 third 10-year inservice inspection interval. If this Code case is published in a future revision of Regulatory Guide 1.147, and FPL intends to continue implementation, limitations issued in the Regulatory Guide will be implemented.

VIII. Attachments:

Code Case N-532 IX. Status:

Submitted 69

St. Lucie 1 XSI Program Revision 0 January 12, 1998 CASE N-532 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: December 12, 1994 See Numeric Index for expiration and any reaffirmation dates.

Alternative Requirements to Repair and Replacement Documentation

.Requir'ementsand Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000'ection XI, Division 1 Inquiry: What alternatives may be used to the requirements of IWA-4910(d) and XWA-6210(e) for completion of Form NIS-2 following repair or replacement, and IWA-6210(c) and (d), IWA-6220, IWA-6230(b), (c), and (d), and IWA-6240(b) for preparation and submittal of the inservice summary report and Form NIS-1?

Reply: It is the opinion of the Committee that as an alternative to the requirements of IWA-4910(d), IWA-6210(c), (d), and (e)g IWA-6220, IWA-6230(b), (c), and (d), and IWA-6240)b), the following provisions may be used. This Case shall be utilized at least until the end of the inspection period in which it was invoked.

1.0 CERTXFICATXON OF THE REPAIR OR REPLACEMENT (a) The Owner's Repair/Replacement Program shall identify use of this Case.

(b) A Repair/Replacement Plan shall be prepared in accordance with IWA-4140', and shall be given a unique identification number.

(c) Upon completion of all required activities as associated with the Repair/Replacement Plan, the Owner shall prepare a REPAIR/REPLACEMENT CERTIFICATION RECORD, FORM NXS-2A.

(d) Form NIS-2A shall be presented to the Inspector for certification.

(e) The completed Form NIS-2A shall be maintained by the Owner.

The Owner shall maintain an index of Repair/Replacement Plans in accordance with IWA-6340. The index shall identify the identification number required by (b) above and the inspection interval and period during which each repair or replacement was completed.

'All references to IWA-4000 and IWA-6000 used in this Case refer to the 1992 Edition.

70

St. Lucie 1 ISI Program Revision 0 January 12, 1998 2.0 OWNER'S ACTIVITY REPORT PREPARATION AND SUBMITTAL An OWNER'S ACTIVITY REPORT FORM OAR-1 shall be prepared and certified upon completion of each refueling outage. Each Form OAR-1 prepared during an inspection period shall be submitted following the end of the inspection period. Each Fo'rm OAR-' shall contain the following:

(a) Abstract of applicable examinations and tests with the information and format of Table l.

(b) A listing of item(s) with flaws or relevant conditions that required evaluation to determine acceptability for continued service, whether or not the flaw or relevant condition was discovered during a scheduled examination or test. The listing shall provide the information in the format of Table 2.

(c) Abstract for repairs, replacements and corrective measures performed, which were required due to an item containing a flaw or relevant condition that exceeded IWB-3000, IWC-3000, IWD-3000, IWE-3000, IWF-3000, or IWL-3000 acceptance criteria; even though the discovery of the flaw or relevant condition that necessitated the repair, replacement or corrective measure, may not have resulted from an examination or test required by this Division. If acceptance criteria for a particular item is not specified in this Division, the provisions of IWA-3100(b) shall be used to determine which repairs, replacements, and corrective measures are required to be included in the abstract. The abstract shall provide the, information in the format of Table 3.

71

St. Lucie 1 ISI Program Revision 0 January 12, 1998 FORM NIS-2A REPAIR/REPLACEMENT CERTIFICATION RECORD OWNERS CERTIFICATE OF CONFORMANCE I certify the represent by Repair/Replacement Plan repair or replacement Number conforms to the requirements of Section XI.

Type Code Symbol Stamp Certificate of Authorization Ho. Expiration Date Owner of Owners Designee, Title CERTIFICATE OF INSERVICE INSPECTION I, the undersigned, holding a valid conmission issued by the National Board of Boiler and Pressure Vessel Inspectors and the State or Province of and employed by of have inspected the items described in Repair/Replacement Plan number during the period to , and state that to the best of my knowledge and belief, the Owner has performed all the activities described in the Repair/Replacement Plan in accordance with the requirements of Section XI.

By signing this certificate neither the Inspector nor his employer makes any warranty, expressed or implied, concerning the activities described in the Repair/Replacement Plan. Furthermore, neither the inspector nor his employer shall be liable in any manner for any personal injury or property damage or loss of any kind arising from or connected with this inspection.

Conmissions Inspectors Signature Rational Board, State, Province, and Endorsements Date 72

St. Lucie 1 ISI Program Revision 0 January 12, 1998 FORM OAR-1 OWNERS ACTIVITY REPORT Report Number Owner (Name and Address of Owner)

Plant (Name and Address of Plant)

Unit No. Comnercial Service Date Refueling Outage No.

(If applicable)

Current Inspection Interval (1st, 2nd, 3rd, 4th, other)

Current Inspection Period (1st, 2nd, 3rd)

Edition and Addenda of Section XI applicable to the inspection plan Date and Revision of inspection plan Edition and Addenda of Section XI applicable to repairs and replacements, if different than the inspection plan CERTIFICATE OF CONFORMANCE I certify that the statements made in the Owners Activity Report are correct, and that the examinations, tests, repairs, replacements, evaluations, and corrective measures represented by this report conform to the requirements of Section XI.

Certificate of Authorization No. Expiration Date (If applicable)

Signed Date Owner or Owners Designee, Title CERTIFICATE OF INSERVICE INSPECTION I, the undersigned, holding a valid comnission issued by the National Board of Boiler and Pressure Vessel Inspectors and the State or Province of and employed by of have inspected the items described in this Owners Activity Report, during the period to , and state that to the best of my knowledge and belief, the Owner has performed all activities represented by this report in accordance with the requirements of Section XI.

By signing this certificate neither the Inspector nor his employer makes any warranty, expressed or implied, concerning the examinations, tests, repairs, replacements, evaluations, and corrective measures described in this report. Furthermore, neither the inspector nor his employer shall be liable in any manner for any personal injury or property damage or loss of any kind arising from or connected with this inspection.

Comaissions Inspectors Signature National Board, State, Province, and Endorsements 73

St. Lucie 1 ISI Program Revision 0 January 12, 1998 TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS Total Total Total Total Examinations Examinations Examinations Examinations Credited (X) to Examination Required for Credited for Credited (X) Date for the Category the Interval this Period for the Period Interval Remarks TABLE 2 ITEMS WITH FLAWS OR RELEVANT CONDITIONS THAT REQUIRED EVALUATION FOR CONTINUED SERVICE Flaw Flaw or Relevant Condition Found Examination I tern I tern Characterization During Scheduled Section XI Category Number Description (IWA-330D) Examination or Test (Yes or No)

TABLE 3 I

ABSTRACT OF RE PA RS I REPLACEMENTS / OR CORRECT VE MEASURES I REQUIRED FOR CONTINUED SERVICE Flaw or Relevant Condition Found Repair, During Scheduled Replacement, Section XI Repair/

Code or Corrective I tern Description Examination or Date Replacement Class Heasure Description of Mork Test (Yes or No) Complete Plan Number 74

St. Lucie

~

~

1 ISI Program Revision 0 January 12, 1998

-Relief Request No. 2, Use of Code Case N-533 Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required IWA-5242 VT-2 examination requirements for bolted connections as specified in the 1989 Edition of ASME Section XI.

I. Component Identification:

Bolted connections on class 1, 2, and 3 systems borated for the purpose of controlling reactivity.

II. Code Requirement:

ASME Section XI, 1989 Edition Article IWA-5242(a) For systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolted connection for, visual examination VT-2.

III. Relief Requested:

Relief is being requested from performing VT-2 examinations on bolted connections on systems borated for controlling reactivity during system pressure tests as prescribed by Section XI, Article IWA-5242(a). FPL will utilize the alternative requirements of ASME Code Case N-533, Alternative Requirements for VT-2 Visual Examination of Class 1 Insulated Pressure Retaining Bolted Connections, Section XI, Division 1.

IV. Basis for Relief:

The ambient conditions during the installation of insulation after VT-2 examinations at normal operating pressure and temperature (NOP/NOT) require heat stress work restrictions.

Containment entries at NOP/NOT are physically demanding on personnel due to the adverse heat environment. Stay times for personnel in many areas are less than one hour and would require multiple containment entries to complete the examination activities. Ambient temperatures range from 95 to 110 degrees F.

Personnel should not be exposed to such an adverse work environment unnecessarily without a compensating increase in the level of quality and safety. Performing the VT-2 visual examination using Code Case N-533 will accomplish the 75

St. Lucie 1 ISI Program Revision 0 January 12, 1998 examinations and the insulation installation while maintaining personnel safety and examination quality at an appropriate level.

Historical data indicate that personnel contaminations increase with increasing environmental temperatures due to the profuse sweating caused by the elevated temperatures. Reinstalling contaminated insulating material under adverse conditions (i.e.,

to piping that is at 2250 psia and greater than 500 degrees F).

would negatively impact total personnel contaminations and expose personnel to unnecessary safety risk. Additionally, increased dose would be accumulated due to reduced examination efficiency as a result of the necessity to wear special protective equipment (e.g., ice vest).

The removal of scaffolding from containment would be through the reactor containment building personnel hatch rather than the equipment hatch since the plant is in Mode 4 with the equipment hatch secured. This will place added physical and heat stress limitations on the personnel involved.

V. Alternate Examinations:

FPL will examine bolted connections on systems borated for the purpose of controlling reactivity in accordance with. the requirements of Code Case N-533. This Code Case was written specifically for Class 1 systems. However, FPL requests to apply it to Class 1, 2, and 3 systems.

Each refueling outage, FPL will remove the insulation from the bolted connections and perform a VT-2 visual examination in accordance with paragraph .(b) of the Code Case on Class 1 systems. '.For Class 2 and 3 systems, this same examination will be performed once each period. The connections are not required to be pressurized during the examination and any evidence of leakage will be evaluated in accordance with IWA-5250.

In addition to the requirements of paragraph (a) of the Code Case, the system pressure test and VT-2 examination with the insulation install'ed on bolted joints at normal operating pressure and temperature will include a 4-hour hold time and will be completed prior to returning the unit to service.

VI. Justification for Relief:

Code Case N-533 was approved for use by ASME on March 14, 1995, as an alternative to the Code requirements of IWA-5242(a). 'he Code Case was written when it was recognized that personnel 76

St. Lucie 1 ISI Program Revision 0 January 12, 1998 safety during the conduct of the UT-2 examinations would be compromised, and that examination of bolted connections during plant shutdown would accomplish the desired results. In addition, evaluation and repairs could be performed without the need to bring the plant to a cold shutdown condition.

Use of this Code Case provides an acceptable level of quality and safety by the use of an alternate method of performing VT-2 examinations. This Code Case meets the intent of Section XI requirements by requiring FPL to examine bolted connections for evidence of leakage and bolt degradation.

VII. Implementation Schedule:

FPL will implement ASME Code Case N-533 during the St. Lucie 1 third 10-year inservice inspection interval. If this Code case is published in a future revision of Regulatory Guide 1.147, and FPL intends to continue implementation, limitations issued in the Regulatory Guide will be implemented.

VIII. Attachments Code Case N-533 IX. Status:

Submitted.

St. Lucie 1 ISI Program Revision 0 January 12, 1998 CASE N-533 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: March 14,1995 See Numerical Index for expiration and any reaffirmation dates.

Case N-533 Alternative Requirements for VT-2 Visual Examination of Class 1 Insulated Pressure Retaining Bolted Connections, Section XI, Division 1 be used in lieu of Inquiry: What alternative requirements may from those of IWA-5242(a) to remove insulation Class 1 pressure-retaining bolted connections to perform a VT-2 visual examination?

Reply:

to the It requirements of IWA-5242(a) to remove as an alternative is the opinion of the Committee that,insulation from Class 1 pressure-retaining bolted connections to perform a VT-2 visual examination, the following requirements shall be met.

(a) A system pressure test and VT-2 visual examination shall be performed each refueling outage without removal of insulation.

(b) Each refueling outage the insulation shall be removed from the bolted connection, and a VT-2 visual examination shall be performed. The connection is not required to be pressurized. Any evidence of leakage shall be evaluated in accordance with IWA-5250.

78

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Request No. 3, Use of Code Case N-546 Pursuant to 10 .CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required IWA-2300 requirements for the qualification of VT-2 examination personnel as specified in the 1989 Edition of ASME Section XI.

I. Identification:

Certification of VT-2 visual examiners II. Code Requirement:

ASME Section XI, 1989 Edition Article IWA-2300 Qualifications of Nondestructive Examination Personnel Article IWA-2310 Personnel performing nondestructive examination (NDE) shall be qualified and certified using a written practice prepared in accordance with SNT-TC-1A and the requirements of this Division.

III. Relief Requested:

Relief is being requested from certifying VT-2 examination personnel as prescribed Section XI, Article IWA-2300. FPL will utilize the method by of certification prescribed by ASME Code Case N-546, Alternative Requirements for Qualification of VT-2 Examination Personnel, Section XI, Division 1.

IV. Basis for Relief:

Code Case N-546 is an alternative to the qualification requirements of IWA-2300 for VT-2 visual examination personnel.

This alternative enables St. Lucie to utilize plant operators to perform VT-2 leak examinations during routine system pressure test walkdowns, reducing the burden of costly contractor NDE personnel. The proposed alternative qualification requirements will provide a reasonable assurance that personnel used for the examinations will have sufficient training. Thus an acceptable level of quality and safety will be achieved and public health and safety will not be endangered by allowing the proposed alternative qualification in lieu of the Code requirement.

79

Revision 0 January 12, 1998 j

Use of Code Case N-546 allows experienced plant personnel such as licensed, and non-licensed operators, local leak rate test personnel, system engineers, and inspection and nondestructive examination personnel to perform VT-2 visual examinations without having to be certified to comparable levels of competency defined in ANSI N45.2.6. The FPL individuals performing the visual examinations will be subject to the conditions provided in Code Case N'-546;'"

This approach alleviates the need to contract certified VT-2 personnel to perform these examinations and reduces the administrative burden of maintaining a Section XI qualification and certification program for VT-2 examination personnel. The level of safety and quality will not decrease with the elimination of contract personnel and the use of qualified FPL personnel to determine if leakage is present. The qualification requirements in Code Case N-546, in conjunction with the additional commitments, are comparable to those qualifications required for VT-2 visual examiner certification.

V. Alternative:

FPL will use Code Case N-546 in lieu of the requirements of Article IWA-2300 for the qualification of VT-2 examiners.

A program has been developed and formal procedures implemented so that consistent VT-2 visual examinations are performed. Leakage evaluations will include an independent review and evaluation of findings by persons other than those that performed the VT-2 examinations. Finally, FPL will document and maintain records to verify that persons selected are qualified.

Examination personnel will have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of plant walkdown experience, receive a minimum of four hours of training on Section XI requirements and plant specific procedures for VT-2 visual examinations, and pass the vision test requirements of IWA-2321, 1995 edition. In addition to the requirements of the Code Case N-546, FPL has developed a procedure to assure consistent VT-2 visual examinations are performed. FPL will proceduralize the requirement that an independent review and evaluation of the findings be performed by persons other than those that performed the VT-2 examinations. FPL will also implement a program that documents the qualifications, training, and visual acuity of persons selected to perform the VT-2 examinations and will maintain records that all of the requirements in the code case and specified herein, are met.

80

St. Lucie 1 ISI Program Revision 0 January 12, 1998 VI. Justification for Relief:

FPL plant operators have many hours of training in the proper functioning of the plant and its components. They are already trained to report any abnormal conditions that may affect the plant. Leakage is one condition that is reported. By providing the additional training and allowing the plant operators to perform'he VT-2 examinations, FPL will reduce costs and radiation exposure by having fewer people performing examinations in the same areas. In addition, the training required for operators may enhance the VT-2 examination as they are more familiar with the plant components than most temporary contractors.

Code Case N-546 was approved for use by ASME on August 24, 1995.

VII. Implementation Schedule:

FPL will implement ASME Code Case N-546 during the St. Lucie 1 third 10-year inservice inspection interval. If this Code case is published in a future revision of Regulatory Guide 1.147, and FPL intends to continue implementation, limitations issued in the Regulatory Guide will be implemented.

VIII. Attachments:

Code Case N-546.

IX. Status:.

Submitted.

81

St. Lucie 1 ISI Program Revision 0 January 12, 1998 CASE N-546 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: August 24, 1995 See Numerical Index for expiration and any reaffirmation dates.

Case N-546 Alternative Requirements for Qualification of VT-2 Examination Personnel, Section XI, Division 1 Inquiry: What alternative to the requirements of IWA-2300 may be used for qualification of VT-2 visual examination personnel?

Reply: It is the opinion of the Committee that VT2 visual examination personnel need not be qualified nor certified to comparable levels of competence in accordance with the referenced standard (i.e., ANSI N45.2.6, ASNT SNT-TC-lA, or ASNT CP-189) provided the examination personnel are qualified in accordance with the following requirements.

(a) At least 40 hrs plant walkdown experience, such as that gained by licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel.

(b) At least 4 hrs of training on Section XI requirements and plant specific procedures for VT-2 visual examination.

(c) Vision test requirements of IWA-2321, 1995 Edition.

82

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Request No. 4, Alternative Evaluation of Leakage Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required IWA-5250(a)(2) requirements for bolted connections when leakage is detected as specified in the 1989 Edition of ASME Section XI.

I. Component Identification:

St. Lucie Unit 1 Class 1, 2, and.3 Pressure Retaining Bolted Connections Corrective measures for leakage at bolted connections.

II. Examination Requirements:

Rules for Inservice Inspection of Nuclear Power Plant Components, Section XI, 1989 Edition IWA-5250(a)(2) bolting shall if leakage occurs at a bolted connection, the be removed, VT-3 visually examined for corrosion, and evaluated in accordance with IWA-3100.

III. Relief Requested:

Florida Power and Light requests relief from removing and performing a VT-3 visual examination on bolting when leakage is observed at a bolted connection during a system pressure test.

The alternative requirements of ASME Code Case N-566 with additional evaluation requirements will be used.

IV. Basis for Relief:

The requirement to remove all bolting from a bolted connection to check for degradation is a burden. This requirement does not take into account the corrosiveness of the fluid, the material of the leaking component, the type and location of the leakage, and the history of material degradation in a similar environment.

Additional examinations are performed by system engineers during routine surveillance required by plant Technical Specifications and procedures. Previous corrective actions are not taken into account. The 1992 and later Editions of ASME Section XI changed the IWA-5250 requirements to allow the removal of the bolt 83

St. Lucie 1 ISI Program Revision 0 January 12, 1998 closest to the source of leakage, reducing the number of bolts to be examined.

ASME Code interpretation XI-1-92-01 states that new bolting or bolting that has received a visual examination prior to installation and has not been inservice does not have to evaluated in accordance with this section. This is recognition by the" Code that leakage at this point would be considered a maintenance item, and one in which the requirements of IWA-5250(a)(2) do not apply.

V. Alternative Examinations:

When FPL finds leakage at bolted connections by VT-2 visual examination during system pressure testing, an evaluation will be performed to determine the susceptibility of the bolting to corrosion and assess the potential for failure. The following criteria may be considered, as applicable, but not limited to, when evaluating the acceptability of the bolting:

1. Service age of the bolting

2. Bolt and component material

3. Corrosiveness of process fluid

4. Leakage location and system function

5. Leakage history at connection or other system components

6. Visual evidence of corrosion at connection (while connection is assembled)

When the pressure test is performed with the system in service or required by the Technical Specifications to be operable, and the bolting is susceptible to corrosion, the evaluation shall address the connections structural integrity until the next component/system outage of sufficient duration. If the evaluation concludes that the system can perform its safety related function, removal of the bolt closest to the leakage and VT-3 visual examination of the bolt will be performed when the system of component is taken out of service for a sufficient duration for accomplishment of the system maintenance activities.

For bolting that is susceptible to corrosion, and when the initial evaluation indicates that the connection cannot conclusively perform its safety function until the next component/system outage of sufficient duration, the bolt closest to the source of leakage will be removed, receive a VT-3 visual examination, and be evaluated in accordance with IWA-3100(a).

84

St. Lucie 1 ISI Program Revision 0 January 12, 1998 VI. Justification for Relief:

Removal of pressure retaining bolting at mechanical connections for VT-3 visual examination and subsequent evaluation in locations where leakage has been identified is not always the most prudent course of action to determine the acceptability of the bolting. This is a task that could easily cause more harm than good. 'Many bolted connections are studs threaded into a component, such as valves and pumps. Removal of these studs can be difficult due to the length of time they have been installed.

Large studs, such as those found on the Reactor Coolant Pumps, pose additional problems with removal. Damage to the pump casings can occur stud.

if too much torque is required to remove a The Code requirement to remove, examine, and evaluate bolting in this situation does not allow the Owner to consider other factors which may indicate the acceptability of mechanical joint bolting.

FPL considers this requirement to by unnecessarily prescriptive and restrictive.

Other factors which should be considered when evaluating bolting acceptability when leakage has been identified at a mechanical joint include, but should not be limited to: joint bolting materials, service age of joint bolting materials, location of the leakage, history of leakage at the joint, evidence of corrosion with the joint assembled, and corrosiveness of process fluid.

ASME Section XI is written to primarily address examinations and testing during periods of plant or system shutdown. No guidance is given to address components that are examined or tested while the plant or system is in service. However, many Code Class 3 and a few Code Class 2 systems are pressure tested, including VT-2 visually examined, utilizing the "inservice test" requirements of IWA-5000.

Performance of the test while the system is inservice may identify leakage at a bolted connection that, upon evaluation, may conclude that the joints structural integrity and pressure retaining ability is not challenged. It would not be prudent to negatively impact a safety systems availability by removing the system from service to address a leak that does not challenge the systems ability to perform its safety function.

In addition, a situation frequently encountered at commercial nuclear plants such as St. Lucie, is the complete replacement of bolting materials (studs, bolts, nuts, washers, etc.) At mechanical joints during plant outages. When the associated

St. Lucie 1 ISI Program Revision 0 January 12, 1998 system process piping is pressurized during plant start-up, leakage is identified at these joints. The root cause of this leakage is most often due to thermal expansion of the piping and bolting materials at the joint and subsequent process fluid seepage at the joint gasket. Proper retorquing of the joint bolting, in most cases, stops the leakage. Removal of any of the joint bolting to evaluate for corrosion would be unwarranted in this situation due to new condition of the bolting materials.

ASME Later editions of the Code have realized the problems inherent in removal of all bolting. The wording of the Code has been changed to avoid removing of all bolting to perform an evaluation.

VII. Implementation Schedule:

FPL will implement the alternative during the St. Lucie 1 third 10-year inservice inspection interval.

VIII. Attachments:

None IX. Status:

Submitted.

86

St. Lucie 1 ISI Program Revision, 0 January 12, 1998 Relief Request No. 5, RPV Weld 209-04 Pursuant to 10 CFR 50.55a(a)(3)(ii), FPL requests an alternative to the Code Category B-A required examinations as specified in the 1989 Edition of ASME Section XI.

I. Identification Class 1 Reactor Pressure Vessel (RPV) Weld 209-04 II. Code Requirement 1989 Edition of Section XI Code Category B-A, Pressure Retaining Welds in Reactor Vessel Item No. B1.21, Circumferential Head Weld Examination Method Volumetric Examination Area Entire volume of weld plus 1/2 T of base metal from the toe of the weld, essentially 100~ of the weld length.

III. Relief Requested Relief is being requested from performing the volumetric examination on RPV weld 209-04 as required by Code Category B-A.

IV. Basis for Relief Weld 209-04 is located under the RPV head shroud, has Control Rod Drive (CRD) mechanisms penetrating it, and is generally inaccessible for volumetric examination. The shroud is welded and bolted to the RPV head in several areas. Removal and replacement of the shroud would be time consuming, involve high radiation exposure, could create an airborne contamination hazard, and possibly cause harm to the RPV head.

Remote or manual examination of the weld from the outside surface is impractical. The shroud, which extends below the weld, would interfere with robotic equipment and manual examinations from the bottom side. On and above the weld are the CRDs, which limit the examination from the other direction. Performing Radiography is impractical due to the high radiation and limited access.

CRDs penetrate the weld, further limiting the amount of weld that could be shot. Performing Ultrasonic examination from the 87

St. Lucie 1 ISI Program Revision 0 January 12, 1998 inside surface is impractical due to the interference of the CRDs and the high radiation.

During previous inservice examinations, it was shown that examination of the weld is impractical. The only method of examination that was able to produce credible results was the VT-2 during pressure tests.

C V. Alternative Examination FPL will perform a visual VT-3 examination on the accessible outside surface areas of the weld once during the interval. The areas will include those between the CRDs, to the extent practical. During system leakage tests, this weld is required to have a visual VT-2 performed to check for leakage.

VI. Justification for Relief Performing the examinations would require FPL to remove the shroud from the RPV head. This would involve a great deal of radiation exposure, cutting of critical RPV equipment, and restoration o'f that same equipment. The possibility of harming the RPV would increase due to the work to remove the shroud and associated components.

Volumetric examination of. the weld from the outside surface is limited due to the shroud and CRDs. At best, that less than 54 of the weld could be examined.

it is estimated Volumetric examination of the weld from the inside surface is impractical. Remote examination equipment would need to be developed and qualified in order to perform these examinations.

The CRDs on the insi'de of the RPV head would interfere with the operation of any remote equipment as the CRDs go through and around the weld. Robotic examination would be very limited at best due to the CRDs interference and their penetrating the weld.

FPL has performed a system leakage test on this weld every outage. No leakage has ever been noted. Industry experience with the St. Lucie vintage of reactor has not shown any specific or generic problems with this weld.

The failure of the weld is small. The weld is outside the beltline region and receives minimal exposure to the neutron flux (which embrittles the metal) .

88

St., Lucie 1 ISI Program Revision 0 January 12, 1998 Having FPL remove the shroud .to gain access to a small percentage of the weld would be a hardship without a compensating increase in safety. Removing the shroud would also increase the possibility of damage to the RPV head.

VII. Implementation Schedule Third Inservice Inspection Interval VIII. Attachments Sketch showing approximate locations of shroud and CRDs.

IX. Status Submitted.

89

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Attachment Shroud Weld 209-04 Weld 209-04 Limitations 90

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Request No. 6, Alternative Snubber Examinations Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the requirements of OM-4 for the examination of snubbers as specified in the 1989 Edition of ASME Section XI.

I. Xdentification

/ Mp St. Lucie Unit 1 ASME Section XI, 1989 Edition IWF-5000 Inservice Test Requirements ASME Class 1, 2 and 3 Snubbers XI. Examination Requirements Rules for Inservice Inspection of Nuclear Power Plant Components, 1989 Edition IWF-5300 Inservice Examination and Tests (a) Inservice examinations shall be performed in accordance with the first Addenda to ASME/ANSI OM-1987, Part 4 (published in 1988), using the VT-3 visual examination method described in IWA-2213.

(b) Inservice tests shall be performed in accordance with the first Addenda to ASME/ANSI OM-1987, Part 4 (published in 1988) .

III. Relief Requested Relief is requested from the requirements of ASME/ANSI OM-1987, Part 4 (OM Part 4).

XV. Basis for Relief The first addenda to ASME/ANSI OM-1987 contains a visual examination, schedule which was recommended for removal from Plant Technical Specifications by Generic Letter 90-09, "Alternative requirements for snubber visual inspection intervals and corrective actions", dated" December lip 1990 This generic letter was issued to reduce the burden placed upon utilities by 91

St. Lucie 1 ISI Program Revision 0 January 12, 1998 the then overly restrictive visual examination schedule.

Technical Specification Amendment g 151 & g 146, incorporated the requirements of Generic Letter 90-09 and removed the restrictive visual examination requirement from the St. Lucie Plant Technical Specifications. The visual examination table in OM Part 4 would return the plant to what was present in the Plant Technical Specifications prior to the issuance and incorporation of Generic Letter"'0-09'."

The initial sample for functional testing is the same in OM-4 as the Technical Specifications (10~). The sample expansion required by OM-4 would result in less snubbers being tested but would significantly increase the engineering man-hours required to 'identify the sample expansion. Plant Technical Specification requires a 10% sample expansion (based on design type population) without the extensive engineering man-hours required by OM-4.

St. Lucie currently performs functional testing during refueling outages, including any sample expansion requirements. OM-4 imposes requirements that could extend the off-load window which would extend the refueling outage with no increase in the level of quality or safety.

A single functional test failure which is identified in OM-4 as generic or application induced failure would require the entire group of snubbers to be replaced or modified. Once all the units were replaced, OM-4 requires a shutdown after 2 months and before 12 months to perform inspection/testing. This would result in hardship for material replacement, extended outages, forced shutdowns, radiation exposure and extensive costs and man-hours without an increase in the level of quality or safety.

V. Alternative Examinations Florida Power & Light St. Lucie Plant will perform functional testing in accordance with Plant Technical Specifications. Base sample shall be 10 ~, 104 sample expansion based on design type population, and the following will be considered:

1) Snubbers immediately adjacent to those found unacceptable;

2) Snubbers from the same system having similar operating conditions, such as temperature, humidity, vibration and radiation.

Visual examinations will be conducted in accordance with Plant Technical Specifications 4.7.10 "Surveillance Requirements I'for snubbers]". Xn addition, snubbers with conditions that could impact their function will be evaluated for continued operation.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 VI. Justification for Relief Performing snubber testing per the requirements of OM-4 is counter to NRC Generic Letter 90-09. St. Lucie Plant technical specifications have been changed to reflect the generic letter.

To use the requirements of OM-4 would require a license amendment.

VII. Implementation Schedule FPL will implement this alternative during the St. Lucie 1 third 10-year inservice inspection interval.

VIII. Status Submitted.

IX. Attachments Technical Specification requirements 93

St. Lucie 1 ISI Program Revision 0 January 12, 1998 St. Lucie 1 Technical Specification for Snubbers PLANT SYSTEMS 3I4.7.10 SNUBBERS 3.7.10 All safety related snubbers shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4. (MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES).

ACTION:

With one or more safety related snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status or declare the supported system inoperable and follow the appropriate ACTION statement for that system.

SU 4.7.10 Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program.

a. Ins ection T es As used in this specification, "type of snubber" shall means snubbers of the same design and manufacturer, irrespective of capacity.

b. Visual Ins ections Snubbers are categorized as inaccessible or accessible during reactor operation.

Each of these categories (inaccessible or accessible) may be inspected independently according to the schedule determined by Table 4.7-3. The visual inspection interval for each category of snubber shall be determined based upon the criteria provided in Table 4.7-3 and the first inspection interval determined using this criteria shall be based upon the previous inspection interval as established by the requirements in effect before Amendment.

c. Visual Ins ection Acce tance Criteria Visual inspections shall verify that (1) the snubber has no visible indications of damage or impaired OPERABILITY, (2) attachments to the foundation or supporting structure are functional, and (3) fasteners for the attachment of the snubber to the 94

St. Lucie 1 IS? Program Revision 0 January 12, .1998 component and to the snubber anchorage are functional. Snubbers which appear inoperable as a result of visual inspections shall be classified as unacceptable and may be reclassified acceptable for the purpose of establishing the next visual inspection interval, provided that (i) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type that may be generically susceptible; and (ii) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per specifications 4.7.10.e and 4.7.10.f, as applicable. AII snubbers found connected to an inoperable common hydraulic fluid reservoir shall be counted as unacceptable for determining the next inspection interval. A review and evaluation shall be performed and documented to justify continued operation with an unacceptable snubber. If continued operation cannot be justified, the snubber shall be declared inoperable and the ACTION requirements shall be met.

TABLE 4.7-3 SNUBBER VISUALINSPECTION INTERVAL NUMBER OF UNACCEPTABLE SNUBBERS Population Column A Column B Column C or Category Extend Interval Repeat Interval Reduce Interval (Notes 1 and 2) (Notes 3 and 6) (Notes 4 and 6) (Notes 5 and 6) 80 100 150 200 13 300 12 25 400 18 500 12 24 48 750 20 40 78 1000 or greater 29 56 109 Note 1: The next visual inspection interval for a snubber population or category size shall be determined based upon the previous inspection interval and the number of unacceptable snubbers found during that interval. Snubbers may be categorized, based upon their accessibility during power operation, as accessible or inaccessible. These categories 95

St. Lucie 1 ISI Program Revision 0 January 12, 1998 may be examined separately or jointly. However, the licensee must make and document that decision before any inspection and shall use that decision as the basis upon which to determine the next inspection interval for that category.

Note 2: Interpolation between population or category sizes and the number of unacceptable

,snubbers is permissible. Use next lower integer for the value of the limit for Columns A, B, or C if that integer includes a fractional value of unacceptable snubbers as determined by interpolation.

Note 3: If the number of unacceptable snubbers is equal to or less than the number in Column A, the next inspection interval may be twice the previous interval but not greater than 48 months.

Note 4: If the number of unacceptable snubbers is equal to or less than the number in Column B but greater than the number in Column A, the next inspection interval shall be the same as the previous interval.

Note 5: If the number of unacceptable snubbers is equal to greater than the number in Column C, the next inspection interval shall be two-thirds of the previous interval. However, if the number of unacceptable snubbers is less than the number in Column C but greater than the number in Column B, the next interval shall be reduced proportionally by interpolation, that is, the previous interval shall be reduced by a factor that is one-third of the ratio of the difference between the number of unacceptable snubbers found during the previous interval and the number of Column B to the difference in the numbers in Columns B and C.

Note 6: The provisions of Specification 4.0.2 are applicable for all inspection intervals up to and including 48 months.

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1 ISI Program Revision 0 January 10, 1998

d. Functional Tests At least once per 18 months during shutdown, a representative sample (10% of the safety related snubbers) shall be functionally tested either in place or in a bench test.

For each snubber that does not meet the functional test acceptance criteria of Specification 4.7.10.e or 4.7.10.f, an additional 10% of that type of snubber shall be functionally tested. Functional test shall continue until no additional snubbers are found inoperable or all safety related snubbers have been tested.

The representative sample selected for functional testing shall include the various configurations, operating environments and the range of size and capability of snubbers.

Snubbers identified as "Especially Difficultto Remove" or in "High Exposure Zones During Shutdown" shall also be included in the representative sample.* Safety related hydraulic snubber listings and safety related mechanical snubber listings may be used jointly or separately as the basis for the sampling plan.

In addition to the regular sample, snubbers which failed the previous functional test shall be retested during the next test period. If a spare snubber has been installed (if it is repaired and installed in another position) and the spare snubber shall be retested. Test results of these snubbers shall not result in additional functional testing due to failure.

Permanent or other exemptions from the functional testing for individual snubbers in these categories may be granted by the Commission only ifjustifiable basis for exemption is presented and/or snubber life destructive testing was performed to qualify snubber operability for all design conditions at either the completion of their fabrication or at a subsequent date.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 If any snubber selected for functional testing either fails to lockup or fails to move, i.e.,

frozen in place, the cause will be evaluated and if caused by manufacturer or design deficiency, all snubbers of the same design subject to the same defect shall be functionally tested. This testing requirement shall be independent of the requirements stated above for snubbers not meeting the functional test acceptance criteria.

e. H draulic Snubbers Functional Test Acce tance Criteria The hydraulic snubber functional test shall verify that

1. Activation (restraining action) is achieved within the specified range of velocity or acceleration in both tension and compression.

2.

Snubber bleed, or release rate, where required, is within the specified range in compression or tension.

f. Mechanical Snubbers Functional Test Acce tance Criteria The mechanical snubber functional test shall verify that:

1. The force that initiates free movement of the snubber rod in'either tension or compression is less than the specified maximum drag force.

2. Activation (restraining action) is achieved in both tension and compression.

g. Snubber Service Life Monitorin A record of the service life of each snubber, the date at which the designated service life commences and the installation and maintenance records on which the designed service life is based shall be maintained as required by Specification 6.10.2.1.

Concurrent with the first inservice visual inspection and at least once per 18 months thereafter, the installation and maintenance records for each safety related snubber shall be reviewed to verify that the indicated service life has not been exceeded or will not be exceeded by more than 10% prior to the next scheduled snubber service life review. If the indicated service life will be exceeded by more than 10% prior to the next scheduled snubber service life review, the snubber service life shall be reevaluated or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review. The results of the reevaluation may be used to justify a change to the service life of the snubber., This reevaluation, replacement or reconditioning shall be indicated in the records.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Request No. 7, Refueling Water Tank Non-Code Repair Pursuant to 10 CFR 50.55a(a)(3)(ii), FPL requests an alternative to the Code required repair of the Refueling Water Tank as specified in the 1989 Edition of ASME Section XI.

I. Identification Class: Quality Group B Class 2 Identification of components: Refuel Water Tank

Description:

Above Ground Storage Tank II. Code Requirements Examination Item Exam Examination Requirement Category Number Method C-H C7.10 Visual Pressure Retaining Boundary VT-2 each inspection period C-H C7.20 Visual Pressure Retaining Boundary VT-2 at or near the end of the inspection interval III. Relief Requested Relief is requested from the Repair and/or Replacement requirements of the ASME Boiler and Pressure Vessel Code, Section XI, 1983 Edition through the Summer 1983 Addenda, Articles IWA/IWC-4000 and IWA/IWC-7000 and IWA/IWB 3000 respectively.

IV. Basis for Relief During the second interval, in-service inspection (ISI) Relief Request 13, FPL letter (L-93-190) dated July 30, 1993, requested approval of a temporary non-Code repair for the RWT bottom until the next Unit 1 refueling outage. The Unit 1 Refueling Water Tank (RWT) is an ASME Class 2 structure. Relief Request 13 was approved by NRC letter dated October 21, 1993. During the Fall 1994 refueling outage it was determined that a Code repair of the RWT bottom was not practical and on November 16, 1994, FPL requested approval of an alternative non-Code repair to correct through wall leakage and corrosion of the Unit 1 RWT bottom. On November 25, 1994, NRC approved the addition of a reinforced vinyl ester liner to the bottom of the RWT until the St. Lucie 99

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Unit 1 steam generator replacement outage. As part of the approval, the NRC requested FPL to complete ongoing laboratory testing and in-situ inspections to confirm the ultimate capabilities of the lining.

FPL completed the evaluation of the reinforced vinyl ester liner and requested its approval as a permanent replacement of the RWT bottom. This approval was received on Ma7 27, 1997. The enclosed engineering evaluation (attachment 1) justifies the reinforced vinyl ester liner as an acceptable alternative to the original bottom design for the third inservice inspection interval and, with the proposed augmented inspection program, provides a level of quality and safety equivalent to the original design.

V. Alternative Examinations or Tests:

In lieu of an ASME Section XI Code repair and/or replacement, FPL proposes to perform the following:

1. Beginning with the SLl-17 refueling outage (the second outage following the Steam Generator Replacement outage), and during every third subsequent refueling outage (i.e., approximately every 4-1/2 years), a full examination of the RWT liner will be performed. For these examinations, the RWT will be completely drained, and examiners will enter the tank to perform a hands-on examination. These examinations will be similar to the examination performed during the Spring 1996 refueling outage (SL1-14). The liner will be examined for acceptability of the following properties:

Hardness Delamination Adhesion Peeling Flaking Undercutting Blistering Cracking Discoloration Checking Holidays Pinholes

2. Beginning with the SL1-15 outage (the Steam Generator Replacement outage), and during every refueling outage for which a full examination of the RWT liner is not scheduled, a remote visual examination of the liner will be performed.

These remote examinations may be performed with the use of a diver or a remotely operated submersible vehicle equipped with a camera. During these examinations, the liner will be visually examined for:

Peeling Flaking 100

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1 ISI Program Revision 0 January 12, 1998 Undercutting -Blistering Cracking Should any RWT liner examinations indicate unacceptable results, or if there are any documented occurrences of leakage through the RWT bottom, the examination schedule (and types of examinations required) shall be revised as follows:

a full hands-on examination shall be performed during the first refueling outage following the unacceptable examination results or documented leakage and during every third refueling outage thereafter for the remainder of the third ten-year XSI interval.

See Table 1 in Attachment 1 for summary of proposed augmented examinations.

3. Inspection of Caulking Material The conditions at the bottom of the RWT shall be examined on an annual basis to verify that the corrective measures implemented (i.e., the caulking material between the RWT bottom and the concrete ring wall) continue to pre'vent ingress of standing or rain water beneath the RWT.

VX. Justification of Relief:

See attachment.

VII. Implementation Schedule:

This alternative repair will remain in place through the third ten year inservice inspection interval.

VXII., Attachments:

St. Lucie Unit 1, Refueling Water Tank, Request for Alternative Tank Bottom Design IX. Status:

Submitted.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 ST ~ LUCIE UNIT 1 REFUELING WATER TANK REQUEST FOR ALTERNATIVE TANK BOTTOM DESIGN 1.0 ZURRQGE The purpose of this submittal is:

a ~ To demonstrate that the liner material'presently installed on the St. Lucie Unit 1 Refueling Water Tank bottom reflects an alternative design which provides acceptable levels of quality and safety which are equivalent to those provided by the original Code of record.

b. To request approval of the installed liner material as an alternative design to be used on the tank bottom for the remaining duration of the tank life.

c ~ To establish the augmented inspection schedule (and types of inspections) proposed for verification that the RWT liner will continue to perform its required functions.

2 0 The refueling water tank (RWT) is an above ground storage tank which provides a source of primary grade water for refueling, reactor coolant makeup, reactivity control during plant operations, and accident conditions (Reference 9.1, Sections 3.1.2.2, 3.1.2.8, and 3.5.4). The RWT is a Quality Group B, ASME Class 2 structure, and was designed and erected in accordance with ANSI B96.1-1967 (Reference 9.2). The RWT provides the Technical Specification required minimum volume of 401,800 gallons of borated water, which ensures that 371,800 gallons are available for injection for emergency core cooling. The RWT boron concentration is maintained at a minimum value of 1720 ppm to ensure an adequate shutdown margin with the reactor in cold shutdown with all Control Element Assemblies withdrawn (Reference 9.1, Section 3.1.2.8, and Reference 9.3, Section 6.3.2.2.1) 3 0 Relief is requested from the Repair and/or Replacement requirements of the ASME Boiler and Pressure Vessel Code, Section XI, 1983 Edition through the Summer 1983 Addenda, Articles IWA/IWC-4000 and IWA/IWC-7000 and IWA/IWB-3000, 102

St. Lucie 1 ISI Program Revision 0 January 12, 1998 respectively. In particular, Florida Power and Light Company (FPL) proposes to leave the installed fiberglass-reinforced vinyl ester liner in place on the Unit 1 RWT bottom, and to consider this installation as an alternative design equivalent to a Code repair or replacement of the RWT bottom.

In support of this request, FPL proposes an augmented inspection program for the bottom liner installation.

4 '

4.1 a steady loss of RWT inventory was observed for several weeks in June and July of 1993. The rate of the loss measured at that time was approximately 2 gpm. In July, 1993, an acoustic emissions (AE) analysis was performed using externally mounted equipment and a transducer mounted on a mini-rover submarine. From this analysis, a single leak approximately 3/16 inch in diameter was located in an area on the RWT bottom near the east side of the tank.

a review of Generic Letter No. 90-05 (Reference 9.4) was performed to determine the basis for allowing non-Code repairs to Code class components. It was determined that any non-Code repair to Class 1 or 2 piping must be performed in accordance with an engineered specification which would provide a boundary that would be of equal structural strength as the original design basis of the component. Code Relief Request No. 13 was prepared and submitted to the NRC (Reference 9.5) requesting NRC approval for a. non-Code repair involving the use of an epoxy coating to adhere an aluminum plate to the tank bottom. In the relief request, FPL committed to providing a Code acceptable repair during the Fall 1994 refueling outage. The NRC, in accordance with 10 CFR 50.55a(g)(6)(i), granted the requested relief and accepted the temporary repair until the Fall 1994 refueling outage, at which time the RWT bottom plate was required to be repaired or replaced in accordance with the provisions of the ASME Code (Reference 9.6). The non-Code repair was implemented using a 1/8 inch thick, 3 inch diameter piece of aluminum plate and Duromar SAR-UW epoxy. Additional AE testing confirmed that, there was no further leakage from the identified location (Reference 9.7).

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 4.3 Engineering documents were prepared to support the implementation of a permanent Code repair during the Fall 1994 Unit 1 refueling outage. This repair, as designed, involved:

a0 Removal of the section of the bottom plate which contained the identified leak, and which had been temporarily repaired in 1993 using aluminum plate and Duromar SAR-UW epoxy.

b. Addition of a new 1/4" aluminum filler plate, with bearing material as necessary to provide uniform support for the new plate section.

c. Sealing of the filler plate to the existing bottom plate by the use of Belzona 1111 epoxy sealant.

d. Welding of a new 1/4" aluminum plate section to the existing bottom plate to cover the opening left by the removal of the temporarily repaired plate.

When the bottom p late section was removed from *the RWT bottom during the Fall 1994 outage, visual inspection revealed corrosion on the exterior surface; scattered pitting (hemispherical in shape) and.patches of a loosely adherent white corrosion product (likely aluminum oxide) were found.

The depths of the ten deepest pits ranged from 0..065 inches to 0.225 inches, with an average depth of 0.107 inches. Most of the surface displayed a dark gray color, indicating a passive state prior to removal; however, several of the pits were shiny and silver in color, indicating a state of active corrosion prior to removal. Portions of the surface were free of any evidence of corrosive attack. The previously repaired hole was seen to have originated from the plate's exterior surface; this was deduced from the sloping profile of the hole. These findings are documented in the root cause analysis performed by FPL's Component Support and Inspection (CSI) Group (Reference 9.8).

During the installation of the new plate section, difficulties were experienced in completing the Code repair.

The wall thinning of the base material, coupled with conditions associated with welding inside the contaminated environment, led to localized defects. This resulted in an inability to qualify the welds; for this reason, the Code repair could not be implemented.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 4 '

As an alternative to the Code repair, a fiberglass reinforced vinyl ester liner (Protecto-Line 800 system, manufactured by Dudick, Inc.) was applied to the inside surface of the RWT

.bottom. The liner system is a 1/8" (approximate) thick coating"consisting of a prime coat, a troweled base coat with a layer of fiberglass roving, and a top coat. Prior to application, the aluminum surfaces to receive the liner were sandblasted to obtain the specified surface profile. The surface was inspected to ensure proper preparation for the application of the coating. The 'liner was applied over the entire tank bottom, and extended approximately 24 inches up the tank wall. The liner was visually inspected to verify proper installation. The installation of this liner system was performed during the Fall 1994 Unit 1 refueling outage in accordance with PC/M 128-194 (Reference 9.9). Personnel training, surface preparation, liner installation, and visual inspections were performed under the direction of FPL Nuclear Engineering s Coatings Specialist. .The RWT was placed in service immediately following the installation and inspection of the liner material; the liner system has satisfactorily performed its required functions since its installation.

The liner installation is considered an alternative non-Code repair. For this reason, FPL submitted Relief Request No.

13A to the NRC for approval of the use of this liner (Reference 9.10). In a telephone conversation on November 16, 1994, the NRC provided verbal approval for the installation of this liner in the RWT. By NRC letter (Reference 9.11), which also transmitted a Safety Evaluation Report, the NRC granted relief to install and use the

.Protecto-Line 800 system, stating that it would provide an acceptable level of quality and safety. In this letter, the NRC stated that, at the time of the Steam Generator Replacement outage, the RWT bottom will be replaced or repaired in accordance with the ASME Code. Additionally, the NRC stated that FPL has committed to the following:

a ~ Visual examination of the lining during each refueling outage.

b. Continued monitoring of the RWT for indications of leakage.

c ~ Completion of ongoing laboratory testing to confirm the ultimate capabilities of the lining.

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 5 '

5.1 FPL's CSI Group performed an evaluation of the as-found condition of the 14 inch square section of plate removed from the 'RWT'bottom, and of the soil samples taken from the area beneath the removed plate, in order to determine the failure mechanism of the RWT bottom (Reference 9.8). The following tests were performed as part of this analysis:

a~ Resistivity tests on soil samples

b. Determination of chemicals in soil samples c ~ Evaluation of DC potential measurements conducted on the RWT.

The very low chloride, nitrate, and sulfate anion levels, along with the near neutral pH values and high electrical resistivity values found, indicate that the soil beneath the RWT is non-corrosive. No detectable levels of oil were found in the soil samples.

The tank-to-soil corrosion potentials measured around the tank rim were more positive than documented potentials for aluminum alloys in simulated sea water. This result indicated that the exterior surfaces of the floor plates were in an active state of corrosion. The recorded values likely resulted from a galvanic couple between the floor plates and the copper ground grid, which would have rendered the plates susceptible to corrosive attack; this, however, would have required a more conductive electrolyte than the specified sand-oil cushion. Visual inspection of the interface between the tank floor and the concrete ring wall revealed the absence of a joint sealing compound.

The conclusion of the root cause evaluation was that the failure mechanism of the RWT was galvanic corrosion (resulting from a galvanic couple between the exterior surface of the RWT aluminum alloy floor and the surrounding copper ground grid) which was manifested as pitting type attack. The root cause of the failure was determined to be the absence of a seal between the tank bottom plates and the concrete ring wall, which permitted the periodic ingress of water into the sand/oil cushion layer beneath the tank. This water likely contained dissolved salts which had been formerly deposited on the tank walls and the surrounding earth. As this water permeated the sand layer beneath the tank, it rendered the soil more conductive, thus increasing 106

St. Lucie 1 ISI Program Revision 0 January 12, 1998 the susceptibility of the exterior of the tank floor plates to corrosive galvanic attack.

5.2 The root cause evaluation (Reference 9.8) included a recommendation for installation of a joint sealing compound between the tank bottom plates and the concrete ring wall to prevent further ingress of water. This installation has been performed via a controlled Work Order. The caulking material used was Chem Caulk 900. Additionally, the area around the RWT has been regraded to prevent standing water from rising to a level above the top of the ring wall foundation (Reference 9.12). Elimination of water from the sand layer beneath the tank will arrest further galvanic corrosion by eliminating the conductive electrolyte in contact with the tank floor and the ground grid. Further corrosion due to the presence of salts in the sand layer will be minimal further water ingress is prevented.

if As stated in Section 4.4, in approving Relief Request No.

13A, the NRC stated that FPL had committed to performing visual examinations of the liner material during each refueling outage. The Spring 1996 refueling outage was the first scheduled outage after the installation of the liner.

The commitment for the examinations would have been satisfied by performing a remote visual inspection (e.g., utilizing a diver or a remotely operated submersible vehicle equipped with a camera). However, 'it was decided to completely drain the RWT and perform a complete hands-on inspection of the liner for the following reasons a ~ To evaluate more completely the performance of the installed liner.

b. To obtain sufficient data to support the request for approval of the liner as a permanent repair to the tank bottom.

Prior to the Spring 1996 Unit 1 refueling outage, a safety evaluation was prepared to provide the following information (Reference 9.13):

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St. Lucie 1 ISI Program Revision 0 January 12, 1998 Procedures and acceptance criteria for the inspection of the vinyl ester liner installed on the RWT bottom.

b. Contingencies for minor repairs to be performed if acceptance criteria for the inspections were not met.

the c ~ a 10CFR50.59 evaluation demonstrating that the above activities do not constitute an unreviewed safety question or require a change to the Technical

" 'pec'ifications.

On May 18, 1996, during the Spring 1996 Unit 1 refueling outage (SL1-14), an inspection of the bottom liner of the RWT was performed. The liner was inspected for acceptability of the following properties:

a ~ Hardness

b. Delamination C~ Adhesion

d. Peeling

e. Flaking

f. Undercutting g Blistering

h. Cracking I ~ Checking Discoloration

k. Holidays

l. Pinholes The inspections performed on the RWT liner were non-destructive in nature. The majority of the inspections were visual only. Some of the inspections (i.e., hardness, undercutting) involved the application of pressure with the edge or point of a knife or paint scraper; this did not result in any cutting of the liner surface. The inspections for Delamination and adhesion involved physical sounding, in which the liner surface was struck with a hammer. The liner was only struck hard enough to enable the inspector to listen to the sound made; the force applied was insufficient to cause any damage / to the liner.

The installed liner was found to be acceptable. The liner met the acceptance criteria for all of the properties listed above, and showed no signs of degradation which could affect its ability to perform its required functions. There were two minor conditions found which warranted additional investigation, as noted below:

a ~ At one location, a small hole (diameter approximately 1/32 inch) was found. Upon excavation, the hole was found to be less than 1/16 inch deep, and did not 108

St. Lucie 1 ISI Program Revision 0 January 12, 1998 penetrate through the topcoat layer. No path was found for water from the RWT to penetrate through the liner material. Therefore, the condition was considered to be an installation anomaly, and was not classified as a pinhole. For these reasons, the as-found condition was determined to be acceptable. The excavated area was sanded, cleaned with an alcohol wipe, and filled in with

'"'uromar SAR-UW. This repair left the total coating thickness in the area of the anomaly equivalent to that of the remainder of the liner.

b. At one location, a small amount of duct tape was found to have been left on the RWT wall and covered by the Protecto-Line topcoat. The tape was completely covered by the liner material, and was completely restrained by the liner from becoming dislodged. The duct tape had originally been placed on the wall for temporary attachment of shielding materials. The tape was removed by cutting the liner with a knife, removing the liner material from above the tape, and removing the tape.

Additional liner material was removed to accommodate the installation of a vortex suppressor (Reference 9.14).

The liner material near the cut line was sanded and wiped with alcohol; the surface of the newly exposed aluminum was prepared in accordance with SSPC-SP-11.

Duromar SAR-UW epoxy was then placed with a 1" (minimum) overlap on both the liner and the aluminum to provide a seal at the cut line.

The complete report of the results of the liner inspection, including the additional investigations described above, is documented in Reference 9.15.

6.2 As discussed in Section 5.2, a caulking compound has been installed between the RWT bottom and the concrete ring wall foundation to prevent further ingress of water. This caulking installation is required to be inspected on an annual basis to verify that the corrective measures continue to prevent ingress of standing or rain water beneath the RWT.

The first required inspection was performed on August 26, 1996. Visual inspection was performed at the interfaces between (a) the base of the RWT and the asphalt and (b) between the asphalt and the concrete RWT foundation. These inspections revealed minor defects in the caulk layers.

These defects consisted of pitting (small holes, less than 1/16" diameter) and minor separation (approximately 1/32" 109

St. Lucie 1 ISI Program Revision 0 January 12, 1998 wide) between the caulk and the adjacent surfaces. The extent of the defects was not sufficiently large to have created a potential for ingress of substantial amounts of water beneath the RWT. However, in order to prevent future problems in this area, the caulk at the interfaces (a) between the base of the RWT and the asphalt and (b) between the asphalt and the concrete RWT foundation was repaired as necessary'. This installation was re-inspected on September 12, 1996, and was determined to be satisfactory for the prevention of ingress of standing or rain water beneath the RWT. The complete report of the inspection and re-inspection is documented in Attachment 12.5 of Reference 9.16.

6.3 Dudick, Inc., has published test values for the following physical properties of the Protecto-Line 800 liner system (Reference 9.9):

Adhesion strength Ability to bridge holes up to 0.5" in diameter Specific gravity Ability to accommodate "oil canning" Effects of radiation exposure on tensile bond test results Resistance to 5,000 ppm boron concentration Compressive strength Coefficient of thermal expansion Taber abrasion Flame spread Water vapor transmission Electrical resistance Discussion of these properties, including any laboratory testing performed to confirm the capabilities of this liner material with regard to its use in the Unit 1 RWT, is provided in the following paragraphs.

(a)

Two sets of adhesion strength tests were performed at FPLs CSI laboratory in West Palm Beach, Florida, on January 3 and 30, 1995. Adhesion tests were performed in accordance with ASTM D4541-93. Test samples were prepared by applying Dudick Protecto-Line 800 (using the same batches as were applied to the RWT bottom) to aluminum plates of the same material as specified for the RWT. The coating was applied in individual layers (primer, basecoat, mat, topcoat) which were exposed at different strips along the test plate. Loading fixtures were 110

St. Lucie 1 ISI Program Revision 0 January 12, 1998 attached to the surface of the liner test samples using an epoxy adhesive. The portable tester used was an Elcometer Model No. 106 (0-2,000 psi). The pulling force was applied through the Elcometer testing apparatus to the loading fixture until failure occurred. Special care was taken to turn the wrench in a plane parallel to the substrate to avoid the application of shear loads or other eccentric loads. The fail'ure loads (in psi) and nature of failure were also recorded.

a total of 32 loading fixtures were tested for pull-off strength. The summary of these tests is as follows:

Date of System Number Average Pull-Off Test Component of Tests Strength 1/3/95 Primer 500 psi 1/30/95 Primer 233 psi 1/3/95 Mat 400 psi 1/30/95 Mat 200 psi 1/3/95 Base Coat 500 psi 1/3 0/95 Base Coat 550 psi 1/3/95 Top Coat 600 psi

.1/30/95 Top Coat 620 psi All of the failures of the test specimens were a result of failure of the glue attaching the test fixtures to the sample panel. No adhesion or cohesion failures of the coating were observed.

Dudick has published test. data (Attachment 12.11 to Reference

.9.16) indicating that the tensile bond strengths of the Protecto-Line 800 liner components are as follows:

a. Base coat (adhesion to primed aluminum): 750 psi

b. Top coat (adhesion to total system): 1050 psi During the testing, the glue bonding the loading fixtures to the liner generally failed before the above loads could be applied. Therefore, it was not possible to confirm the adhesion values published by Dudick. However, some of the 111

St. Lucie 1 ISI Program Revision 0 January 12, 1998 individual tests performed exceeded the published values. It may be concluded that higher adhesion values could have been obtained if a stronger glue had been available. The test values obtained are sufficient to ensure that the coating will not suffer adhesion or cohesion failure. Therefore, the values obtained during the testing indicate that the Dudick Protecto-Line, 800 system has sufficient adhesion and cohesion strength"to perform its intended functions as a liner for the St. Lucie Unit 1 RWT.

The complete reports of these tests are documented in Attachments 12.6 and 12.7 of Reference 9.16.

II (b)

Three sample plates were tested at FPLs CSI laboratory in West Palm Beach, Florida, on January 3 and 30, 1995.

Tests were performed to evaluate the ability of the liner material to span over holes of 1", 2", and 3" diameters.

Holes of these sizes were drilled in the test plates, and then covered with tape, prior to application of the liner material. After the liner material had cured, the tape was removed from the underside of the cured liner material; this left holes in the plates over which the liner spanned. This set-up replicates the hypothetical situation in which the aluminum plate deteriorates after the application of the liner.

Loads were applied to the liner material spanning the holes to simulate the loads which would result from water pressure at the bottom of the RWT. The table below lists the loads applied to the liner for each hole size, and the margin of safety with regard to postulated loading conditions (i.e.,

the liner would have to carry iD RWT) .

~

the ratio between the test loading applied and the load which at the bottom of the Hole Size Test Load In-Situ Margin of Applied Load

• Safety 140 lbs 13 lbs 2 II 150 lbs 53 lbs 2.8 3 It 220 lbs 119 lbs 1.8 112

St. Lucie 1 ISI Program Revision 0 January 12, 1998

• The water pressure at the bottom of the RWT is 16.9 psi (Reference 9.17). Therefore, the in-situ load to be carried by the liner spanning over a postulated hole is equal to 16.9 psi multiplied by the area of the hole.

For each hole size tested, the loads that were applied during laboratory testing did not cause failure (either by stru'ctural'ailure or by adhesion/cohesion failure) of the test sample. No deflection'or visual signs of distress of the liner material was observed. Therefore, the actual margin of safety of the liner material is higher than the values determined above.

The conclusion reached from this test is that the Dudick Protecto-Line 800 system liner material, in its application in the St. Lucie Unit 1 Refueling Water Tank, can span over holes up to 3 inches in diameter with a satisfactory margin of safety.

The complete report of these tests is documented in Attachment 12.8 of Reference 9.16.

(c) a sample of the Dudick Protecto-Line 800 liner material was applied to a removable plastic medium and allowed to cure.

When curing was complete, the liner system was removed from the medium. a sample was then cut from this material, and the dimensions and weight were'easured and recorded. These measurements were taken at FPLs CSI laboratory in West Palm Beach, Florida, on January 3, 1995.

From the measurements taken, the volume of the sample was determined to be 2861 mm, while the weight was measured as 4.86 grams. From this, the specific gravity of the liner sample was determined to be 1.7 (greater than that of water in the RWT). As a confirmatory test, a sample of liner material was placed into a beaker of tap water. Several different orientations were used (i.e., the sample was placed onto the surface of the water with the flat surface horizontal as well as vertical). Each time the sample was placed into the water, it sank immediately to the bottom of the beaker. This confirms the claim of Dudick, Inc., that the specific gravity of the Protecto-Line 800 liner is greater than that of water.

This result confirms the original conclusion (Reference 9.9) that, loose, ifitany liner material installed in the RWT were to come would remain on the bottom of the tank and not be 113

St. Lucie 1 ISI Program Revision 0 January 12, 1998 drawn into suction penetrations (as stated in Reference 9.9, the fluid velocities in the vicinity of the penetration are very low and insufficient to draw any significant debris off the bottom of the tank).

The complete report of these tests is documented Reference 9.16.

(d)

In Letter No. JPN-CSI-95-045 (Reference 9.18), documentation was provided of the observation of "oil canning" of the bottom plates of the RWT after the application and curing of the Dudick Protecto-Line 800 system. This "oil canning" was caused by the weight of personnel walking on the tank bottom which had distended upward when the weight of the water normally stored in the tank had been removed. The effect was observed to be applied cyclically (i.e., downward deflection when an individual stood on a floor panel, with the panel returning to its original position when the weight of the individual was removed. This "oil canning" was observed to be of a magnitude approximating 3 to 4 inches. No cracking, disbondment, or other signs of distress in the liner were observed as a result of this occurrence. Similar observations (both of the extent of "oil canning" and of the absence of distress in the liner) were made during the inspection of the RWT liner on May 18, 1996. Therefore, is concluded that the Protecto-Line 800 liner will not be it adversely affected by the "oil canning" effect resulting from the cyclic removal and addition of loads on the RWT bottom plates (i.e., the draining and filling of the tank).

(e)

An aluminum test panel coated with the Dudick Protecto-Line 800 system was submitted to SteriGenics, Inc., who subjected this test panel to an exposure of 107,100,000 Rads (Attachments 12.11 and 12.14 of Reference 9.16). This is greater than the projected total dose to the RWT bottom, which is e'stimated to be 35,000 Rem overall or 350,000 Rem at hot spots (Reference 9.19). The irradiated panel was then provided to Dudick, who performed adhesion tests in accordance with ASTM D4541. The results of this testing were identical to previous tests, thus verifying that the radiation exposure had no effect on the tensile bond strength of the liner material (Attachment 12.11 of Reference 9.16).

After testing, the test panel was returned to FPL.

114

St. Lucie 1 ISI Program Revision 0 January 12, 1998 The FPL Coatings Specialist performed confirmatory adhesion testing in accordance with ASTM D4541-93 on the irradiated sample received from Dudick (Reference 9.20). All of the failures of the test specimens were a result of failure of the glue attaching the test fixtures to the'sample panel; in each case, the applied load at failure was between 500 and 750 psi. No adhesion or cohesion failures of the coating wer'e obser'ved. 'he values obtained during the testing indicate that the Dudick Protecto-Line 800 system maintains sufficient adhesion and cohesion strength to perform its intended functions as a liner for the St. Lucie Unit 1 RWT.

Dudick, Inc., recommends the Protecto-Line 800 fiberglass reinforced vinyl ester l'incr system for applications involving concentrated acid spills, acid neutralization, and caustic handling areas. General-purpose polyester resins reinforced with fiberglass have good chemical resistance, except to alkalies; however, materials in this class which are based on bisphenol are more resistant to alkalies (Reference 9.21, page 23-61). General-purpose polyesters have good to excellent chemical resistance to 10% solutions of hydrochloric, sulfuric, nitric, and acetic acids (Reference 9.21, Table 23-9). Also, polyesters have excellent resistance to mineral acids such as boric acid (Reference 9.21, Table 23-11).

Even at 5,000 ppm, the concentration of boric acid in water is very dilute (much less than 10<). Therefore, from the industry data and historical information referenced in the paragraph above, the Protecto-Line 800 liner material will adequately resist a boron concentration of 5,000 ppm.

Makeup to the RWT is supplied via a blended flow of reactor makeup water from the Primary Water Tank and boric acid (approximately 3% concentration) from the Boric Acid Makeup Tanks (Reference 9.22). This combination yields the Technical Specification required RWT concentration of 1720 ppm boron (approximately 1% boric, acid) . This is much less than the 10% concentration evaluated above. Therefore, the Protecto-Line 800 liner material will adequately resist the boron concentration present in the RWT.

Visual inspection performed on May. 18, 1996 (Reference 9.15) indicated no changes in the physical attributes of .the installed liner; this is a primary indication of chemical resistance.

115

St. Lucie 1 ISI Program Revision 0 January 12, 1998 (g)

The water pressure at the bottom of the RWT is 16.9 psi (Reference 9.17). Because of this low uniform load to be carried, and the absence of concentrated loads on the RWT bottom, it was concluded that compressive strength is not. a critical property for the liner material. However, subs'equent'ests were performed to verify that the liner material can withstand, with an adequate safety margin, the uniform compressive loads to which it will be subjected in the RWT.

Two samples of Dudick Protecto-Line 800 material were subjected to compression testing in FPLs Research and Evaluation laboratory in West Palm Beach, Florida, on August 28, 1996. The compression loads were applied with a Tinius Olsen 5000 pound universal testing machine. The complete report of this testing is documented in Attachment 12.13 of Reference 9.16.

The samples were placed in the testing machine between parallel plates. a thin piece of rubber blanket was placed on top of the sample to smooth out any irregularities. The sample was compressed in 1,000 pound increments at a rate of approximately 1,000 pounds per minute. At each increment, the sample was removed and visually examined for signs of failure.

The first sample tested measured 1.1" by 1.117", with an area of 1.23 in'. The maximum compressive load applied to this sample was 5030 pounds, which resulted in a compressive stress of 5030/1.23, or 4090 psi. The second sample tested measured 1.124" by 1.126", with an area of 1.27 in . The maximum compressive load applied to this sample was 5021 pounds, which resulted in a compressive stress of 5021/1.27, or 3950 psi. Neither test sample showed any signs of failure at the maximum load. Therefore, the margin of safety for the liner material with regard to compressive strength is at least 3950/16.9, or 234. The test values obtained indicate that the Dudick Protecto-Line 800 system has sufficient compressive strength to perform its intended function as a liner for the St. Lucie Unit 1 RWT.

(h)

From information published by Dudick, Inc., the coefficient of expansion for the Protecto-Line 800 system is 12-15 x 10 (Attachment 4.4 of Reference 9.9). The 'nch/inch/'F coefficient of thermal expansion for aluminum is 12.8 x 10 116

St. Lucie 1 ISI Program Revision 0 January 12, 1998 inch/inch/'F (Reference 9.23, p. 19-46). The values of the coefficient of thermal expansion for the two materials are approximately equal.

The assumed minimum temperature of the water in the RWT is 55'F (Reference 9.3, Table 6.3-6). The design temperature of the water in the RWT is 125'F (Reference 9.3, Table 6.3-2).

Because'f this limited temperature range, the coefficient of thermal expansion is not a critical property. Over a 50 foot length (the diameter of the RWT), a strip of aluminum subjected to a 70'F temperature increase would increase in length by only (12.8 x 10 in/in/'F) x (50x12 in) x (70'F), or approximately 1/2 inch. Even a major variance in the coefficient of expansion of the liner material would not result in a large differential expansion between the liner and the aluminum; therefore, the value of the coefficient of thermal expansion does not need to be verified.

Water vapor transmission (WVT) is a measure of the rate at which water vapor can be, transmitted through a coating. This property is generally used as a guide in the selection of coatings (i.e., paint) which are normally applied to a dry film thickness (DFT) of 10-20 mils and which would be more susceptible to blistering. The value of WVT published by Dudick for the Protecto-Line 800 system (0.0017 perm. in.) is very low. Because of the high DFT (125 mils or greater) of the liner system, and the low WVT rate, the Protecto-Line 800 system is not susceptible to osmotic blistering. Therefore, the water vapor transmission rate does not need to be verified.

Because of the nature of this application of the liner material (i.e., underwater on the non-traffic-bearing interior surfaces of the non-structural bottom plates of a water storage tank), verification of the properties of Taber abrasion, flame spread, and electrical resistance is not required.

6.4 Samples of the materials used in the application of the Protecto-Line 800 system (primer, coating, filler, hardener, and fiberglass roving) were sent to Professional Service Industries (Pittsburgh Testing Lab Division) for chemical analysis. The intent of this analysis was to confirm the 117

St. Lucie 1 ISI Program Revision 0 January 12, 1998 composition of the liner materials, and to determine whether the amounts of impurities in the materials are within the limits specified in FPL Administrative Procedure 0010507 (Reference 9.24) for materials used in the primary system.

To analyze the composition of the liner materials, infrared spectroscopic analysis was performed on samples of the basecoat"'and the filler material. The spectrum of the basecoat material appeared to represent a mixture of materials from which typical vinyl esters are formed. The spectrum of the filler material was determ'ined to be similar

,to several siliceous materials. From this analysis, it concluded that the chemical composition of the two samples was agreed with the description published by Dudick, except that the basecoat sample did not contain silica. This conclusion was as expected; although the purchase requisition describes the basecoat as being a "vinyl ester resin with graded silica", the silica is a separate filler which is added at the time of application, and would not have been present in the basecoat material analyzed. Therefore, the results of this analysis confirm that the liner material is in conformance with the published description.

Tests were also performed to determine the concentration of halogens (chloride, fluoride, bromide, and iodide), sulfur, and metals (mercury. lead, copper, zinc, tin, cadmium, and phosphorus) present in the liner materials. These impurities are as identified in Reference 9.24. The testing was performed using recognized-ASTM and EPA standards and inductively coupled plasma spectroscopy. This testing indicated that the levels of all impurities (except for chloride and sulfur) in each of the liner components were within the acceptable limits. The levels of chloride and sulfur were above the acceptable limits. These results were obtained from the testing of the individual component elements of the Protecto-Line system. When these components are mixed together to form the applied liner, the reactions between the elements change the final chemical composition of the liner. For this reason, the levels of impurities in the component elements are not necessarily indicative of the levels to be found in the final system; the chemical reactions could cause the concentrations of the free elements to be reduced. Since the levels of impurities (except chloride and sulfur) in each of the liner components were within the acceptable limits, it was concluded that the levels of these impurities in the liner are acceptable.

Further investigation of total chloride and sulfur levels was required. The complete report of the chemical analysis 118

St. Lucie 1 ISI Program Revision 0 January 12, 1998 performed by Professional Service Industries (Pittsburgh Testing Lab Division) is documented in Reference 9.25.

Additional tests were performed on a sample of the cured Protecto-Line 800 system liner to determine total chloride, total sulfur, and leachable chloride. This testing was performed at the FPL Central Testing Laboratory in West Palm Beach on August 28 and 29, 1996. a sample of the liner was burned in a Parr Oxygen Combustion Bomb. The bomb washings were then analyzed for chloride and sulfate by ion chromatography (EPA Method 300.0). The test results indicated that the total sulfur content of the cured liner material was 87 ppm, which is within the acceptable limit of 100 ppm. Total chloride was determined to be 460 ppm, which is above the specified limit of 100 ppm.

For the vinyl ester liner, the total chloride is not an appropriate measure of the amount. of chloride that can come into contact with the primary system. In compounds of this nature, the majority of the chloride is bound within the matrix of the cured liner material; the only chloride that can come into contact with the primary system is that which can leach out of the cured chemical compound. For this reason, an additional test was performed to determine the amount of leachable chloride in the liner material. For this test, a sample of the cured liner was leached in ionized water and boiled for one hour. After cooling, the water was analyzed by ion .chromatography. This test indicated that the concentration of leachable chloride in the cured liner material is 83 ppm; this is within the acceptable limit of 100 ppm. The use of leachable chlorides as an indicator is an accepted practice within the nuclear coatings industry.

The complete report of the testing performed at FPL's Central Testing Laboratory is documented in Reference 9.26.

The results of the chemical tests performed by Professional Testing Industries and FPLs Central Testing Laboratory indicate that the Dudick Protecto-Line 800 liner is composed of the materials specified by Dudick, Inc., and that the levels of impurities in the material are within the acceptable limits as specified in Reference 9.24.

7~0 7~1 The RWT was designed in accordance with ANSI B96.1, "Welded Aluminum Alloy Field Erected Storage Tanks". The main base 119

St. Lucie 1 ISI Program Revision 0 January 12, 1998 plates are 0.25 inches thick, and are welded to a 0.375 inch thick annular base plate. The tank is supported on an by 2 wide reinforced concrete ring wall foundation.

8.5'igh The RWT base is anchored to the ring wall foundation with 45 two-inch diameter ASTM A36 carbon steel anchor bolts.

(References 9.27 and 9.28)

The'WT bottom plates are continuously supported by structural fill material. There is a 6" thick sand and oil cushion placed on approximately 8 feet of Class I fill compacted to 95% of maximum dry density; underlying this is Class I fill compacted to 984 of maximum dry density (Reference 9.22). The tank shell is supported directly by the concrete ring wall and does not depend on the bottom plate for structural support. Per ANSI B96.1, the flat bottom of the tank is not subject to specific design rules for calculating minimum thickness and allowable stresses are not given for the tank bottom. The function of the bottom plate is to provide a barrier between the tank fluid and the underlying fill material'. The bottom plate does not transfer loads to the shell or the annular base plate and ring wall foundation. Pressure stress loads are carried by the beneath the tank bottom. Therefore, the tank bottom may be fill considered a liner.

During the various repairs made to the RWT bottom, the support conditions of the bottom plate have not been changed from the original design.

7.2 As discussed in Section 6.3, FPL has performed confirmatory testing to verify the manufacturer's published information concerning the physical properties of the Dudick Protecto-Line 800 system. These test results provide the necessary confirmation of the ability of the Dudick system to perform its intended functions as a liner for the St. Lucie Unit 1 RWT.

As discussed in Section 6..4, FPL has performed chemical testing to confirm the composition of the liner materials.

The results of this testing indicate that the Protecto-Line 800 liner system is composed of the materials specified by Dudick, Inc., and does not exceed the acceptable limits for impurities as specified by FPL Administrative Procedures for materials in contact with the primary system.

120

St. Lucie 1 ISI Program Revision 0 January 12, 1998 The fiberglass-reinforced vinyl ester liner was installed during the Fall 1994 refueling outage. During the Spring 1996 refueling outage, the RWT was drained and a full hands-on visual inspection of the liner was performed. As discussed in Section 6.1, the liner met the acceptance criteria for all properties evaluated during this inspection, and showed no signs of degradation which could affect its abi'lity to perform its required functions.

As discussed in Section 5.0, FPL has performed a root cause analysis of the tank bottom corrosion mechanism. The failure mechanism was determined to be galvanic corrosion resulting from a galvanic couple between the exterior surface of the RWT floor and the surrounding copper ground grid. The root cause of the failure was determined to be the absence of a seal between the tank bottom plates and the concrete ring wall, which permitted the periodic ingress of water beneath the tank. Corrective action has been taken to eliminate this root cause by installing a joint sealing compound between the tank bottom plates and the ring wall. Additionally, the area around the RWT has been regraded to prevent standing water from rising to a level above the top of the ring wall foundation. By preventing further ingress of water beneath the RWT, further corrosion of the tank bottom due to the presence of salts in the sand layer will be minimal.

For the reasons discussed above, the Dudick Protecto-Line 800 system has been determined to be an appropriate material to be used as a liner for the aluminum RWT. Visual inspections

-have indicated no degradation of the material since installation. Since the tank bottom does not transfer loads to the shell or to the annular base plate and ring wall foundation, it is considered a liner (i.e., a barrier between the tank fluid and the underlying fill material) in accordance with ANSI B96.1 (the design Code of record).

Therefore, the installed Dudick Protecto-Line 800 liner is considered an alternative design which is equivalent to the design originally installed per the Code of record (ANSI B9'6.1), and will provide an acceptable level of quality and safety.

The liner material extends approximately 24 inches up the tank wall, which is a structural, load carrying element of the tank. As indicated in Section 6.3(d), the liner has exhibited the ability to accommodate approximately 3 to 4 inches of deflection on the tank bottom. This exceeds any bending deflection which will be experienced in the lowest 2 feet of the tank wall under postulated loading conditions.

Therefore, loads causing stresses and accompanying 121

St. Lucie 1 ISI Program Revision 0 January 12, 1998 deformations in the RWT wall will not result in loss of adhesion of the liner material to either the tank wall or the bottom.

The installed Protecto-Line 800 liner system meets quality standards commensurate with the importance of the safety function to be performed (i.e., acting as a liner to retain the'ater'"in the RWT), as indicated by the following:

a4 The liner was installed in accordance with Reference 9.9, which is a safety-related Engineering Package.

b. The liner material has been subjected to physical and chemical tests (as discussed in Sections 6.3 and 6.4) to confirm its ability to perform its intended functions as a liner for the RWT.

c ~ FPL is proposing an augmented inspection program to provide ongoing verification that the liner will continue to adequately perform its intended functions.

8 '

8.1 Florida Power and Light proposes to use the installed fiberglass-reinforced vinyl ester liner (Dudick Protecto-Line 800 system) in place on the Unit 1 Refueling Water Tank (RWT) bottom as a permanent alternative design, and also proposes to continue to use the RWT to meet its required Technical Specification functions.

The Unit 1 Updated Final Safety Analysis Report. (FSAR)

(Reference 9.3), Section 6.3.2.2.1, states that the NRC has approved the liner "as an alternative non-Code repai'r until the steam generator refueling outage, at which time a Code repair shall be made". An FSAR Change Package (FCP) has been prepared to delete the requirement to perform a Code repair at the time of the steam generator replacement outage.

Upon NRC approval of the use of the liner as a permanent installation, the Updated FSAR will be updated to incorporate this FCP.

8.2 The following inspections will be performed during the period beginning with the Steam Generator Replacement outage and for the subsequent ten years (i.e., through the third ten-year ISI interval, which ends on February 11, 2008).

122

St. Lucie 1 ISI Program Revision 0 January 12, 1998

a. Beginning with the SL1-17 refueling outage (the second outage following the Steam Generator Replacement outage), and during every third subsequent refueling outage (i.e., approximately every 4-1/2 years), a full inspection of the RWT liner will be performed. For these inspections, the RWT will be completely drained; inspectors will enter the tank to perform a hands-on inspection. These inspections will be similar to the inspection performed during the Spring 1996 refueling outage (SL1-14). The liner will be inspected for acceptability of the following properties:

Hardness Delamination Adhesion Peeling Flaking Undercutting Blistering Cracking Checking

'iscoloration Holidays Pinholes

b. Beginning with the SL1-15 outage (the Steam Generator Replacement outage), and during every refueling outage for which a full inspection of the RWT liner is not scheduled, a remote visual inspection of the liner will be performed.

These remote inspections may be performed with the use of a diver or a remotely operated submersible vehicle equipped with a camera. During these inspections, the liner will be visually examined for:

Peeling Flaking Undercutting Blistering Cracking The proposed inspection schedule outlined above is applicable through the end of the third ten-year ISI interval. a separate submittal will be made to the NRC regarding a proposed inspection schedule for the period beginning with the fourth ten-year ISI interval (which begins on February 12, 2008). The proposed inspection schedule for the fourth ten-year ISI interval will be based on the results of inspections performed up to the time of the submittal.

123

St; Lucie 1 ISI Program Revision 0 January 12, 1998 Should any RWT liner inspections indicate unacceptable results, or if there are any documented occurrences of leakage through the RWT bottom, the inspection schedule (and types of inspections required) shall be revised as follows: a full hands-on inspection shall be performed during the first refueling outage following the unacceptable inspection results or documented leakage and during'very third refu'cling"outage thereafter for the remainder of the third ten-year ISI interval.

See Table 1 for summary of proposed augmented inspectiohs.

8.3 The conditions at the bottom of the RWT shall be inspected on an annual basis to verify that the corrective measures implemented (i.e., the caulking material between the RWT bottom and the concrete ring wall) continue to prevent ingress of standing or rain water beneath the RWT (Reference

9. 17) .

9 0 9.1 St. Lucie Unit 1 Technical Specifications, through Amendment 14.

9.2 ANSI B96.1-1967, "Welded Aluminum Alloy Field Erected Storage Tanks".

9.3 St. Lucie Unit 1 Updated Final Safety Analysis Report, through Amendment 142.

9.4 Generic Letter No. 90-05, "Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 Piping", dated June 15, 1990.

9.5 FPL Letter L-93-190 from D. a. Sager to U. S. Nuclear Regulatory Commission, dated July 30, 1993 9.6 U. S. Nuclear Regulatory Commission letter from Herbert N.

Berkow to Mr. J. H. Goldberg, dated October 21, 1993 9.7 Letter No. ESI-NDE-93-172, from C. M. Redding/S. M.

Alberico to A. G. Menocal, "Final Report of the Refueling Water Tank, St. Lucie Unit. 1, August 1993", prepared by Florida Power & Light Company, Nuclear Engineering, ESI, dated August 13, 1993.

124

St. Lucie 1 ISI Program Revision 0 January 12, 1998 9.8 Letter MET-94-227 from Mark Joseph (FPL Component Support and Inspection Group) to Dan Denver (FPL Nuclear Engineering), dated January 19, 1995.

9.9 PC/M No. 128-194, "Addition of a Reinforced Vinyl Ester Liner to the Bottom of the Refueling Water Tank", Revision 1~

9. 10 FPL Letter L-94-291 from D. a. Sager to U. S. Nuclear Regulatory Commission, dated November 16, 1994.

9.11 Letter from Mohan C. Thadani (NRR) to Mr. J. H. Goldberg (FPL), "Proposed Alternative to the ASME Code for Replacement of the Refueling Water Tank Bottom at St. Lucie Unit No. 1 (TAC No. M90762)", dated November 25, 1994

9. 12 Nonconformance Report (NCR) No. 1-741, dated January 22, 1993.

9.13 Safety Evaluation No. JPN-PSL-SECP-96-053, "Inspection Procedures and Repair Contingencies for the Refueling Water Tank Bottom Liner", Revision 0.

9. 14 PC/M No.96-085, "Refueling Water Tank Vortex Suppressor",

Revision 0.

9.15 Letter JPN-SPSL-96-0245 from D. J. Denver (FPL Nuclear Engineering) to H. L. Fagley (FPL Projects Maintenance Support), dated May 23, 1996 9.16 Safety Evaluation No. JPN-PSL-SECS-96-082, "Refueling Water Tank Alternative Bottom Design", Revision 0.

9. 17 St. Lucie Action Report (STAR) No. 1-94110485, dated November 21, 1994.

9. 18 Letter JPN-CSI-95-045 from G. S. Dolderer (JPN/CSI) to K.

H. Greene (JPN/PEG), dated February 3, 1995.

9. 19 Letter No. BK 493-021 from Ray McCullers (St. Lucie Health Physics) to Garth Dolderer (JPN/JB), dated September 22, 1993.

9.20 Letter JPN-CSI-96-113 from G. S. Dolderer (ENG/CSI) to K.

H. Greene (ENG/PSL), dated September 12, 1996.

~~i~,

copyright Fifth Edition, McGraw-Hill 1973.

1 E Book Company, e 125

St. Lucie 1 ISI Program Revision 0 January 12, 1998 9.22 Safety Evaluation No. JPN-PSL-SENP-93-035, "Evaluation of Inventory Loss from the Refueling Water Tank", Revision 2.

9.23 1968.

9.24 'FPL Administrative Procedure No. 0010507, "Control of Chemicals and Materials for the Maintenance of Plant Systems", Revision 9.

9.25 Professional Service Industries,'nc., Test Report for Protecto-Line 800 Material for Florida Power & Light Co.,

Project No. 831-5T084-1, dated March 6, 1995.

9.26 Florida Power and Light Central Laboratory Report of Analysis (Sample Identification: Dudick Protecto-Line 800; FPL Lab WITS ID: W-96-81), dated September 4, 1996.

9.27 Drawing No. 8770-4510, "Refueling Water Tank Bottom Details", Revision 4.

9.28 Drawing No. 8770-G-671, "Component Cooling Pumps Foundations Masonry", Revision 8.

126

St. Lucie 1 ISI Program Revision 0 January 12, 1998 TABLE 1 ST ~ LUCIE UNIT 1 -REFUELING WATER TANK PROPOSED SCHEDULE OF EXAMINATION FOR THE THIRD 10 YEAR INSERVZCE INSPECTION INTERVAL OUTAGE REMOTE VISUAL FULL HANDS-ON EXAMINATION EXAMINATION SL1-16 SL1-17 X SL1-18 SL1-19 SL1-20 X SL1-21 Note:

Should any RWT liner examinations indicate unacceptable results, or if there are any documented occurrences of leakage through the RWT bottom, the examination schedule (and types of inspections required) shall be revised as follows: a full hands-.on examination shall be performed during the first refueling outage following the unacceptable examination results or documented leakage and during every third refueling outage thereafter for the remainder of the third ten-year ZSI interval.

127

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Request No. 8, Scheduling of Examinations Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required IWB-2400 and IWC-2400 requirements for the scheduling of examinations as specified in the 1989 Edition of ASME Section XI.

I. Identification Tables IWB-2412-1 and IWC-2412-1 of ASME Section XI, 1989 Edition II. Code Requirement ASME Section XI, 1989 Edition Table IWB-2412-1 Inspection Inspection Period, Minimum Maximum Interval Calendar Years of Examinations Examinations Plant Service Completed, Credited,

[Note (1) 23 16 34 3rd 27 50 67 30 100 100 Note: Except as noted in Table IWB-2500-1, B1.30 Table IWC-2412-1 Inspection Inspection Period, Minimum Maximum Interval Calendar Years of Examinations Examinations Plant Service Completed, Credited, 23 16 34 3rd 27 50 67 30 100 100 IWB-2420 Successive Inspections IWC-2420 Successive Inspections 128

St. Lucie 1 ISI Program Revision 0 January 12, 1998 IWF-2420 Successive Inspections (a) The sequence of component examinations established during the first inspection interval shall be repeated during each successive inspection interval, to the extent practical.

Category B-J, NOTE (2) The initially selected welds shall be reexamined during each inspection interval.

III. Relief Requested Florida Power and Light requests an alternative to repeating the sequence of examinations established during the first interval, allow an alternative to the requirements contained within Tables IWB-2412-1 and IWC-2412-1, and to substitute like examination areas on the same or similar lines when radiation dose accumulation can be significantly lowered.

IV. Basis for Relief H

Florida Power and Light performed examinations on Class 1 systems during the first Period of the First Interval in accordance with the 1970 Edition with Addenda through Winter 1970 of Section XI.

During the second and third periods, examinations were performed in accordance with the 1974 Edition with Addenda through Summer 1975 on all Code classes (pro-rated for the Interval). With this schedule, the sequence of examinations was not established for about one-half of the areas until the second interval.

Modifying the sequence of examinations reduces the need for personnel to prepare and examine components in essentially the same area several times. The radiation exposure, time, and manpower required to perform these tasks can be significantly reduced by changing the sequence of examinations. St. Lucie has not had any problems with piping and components, so modifying the ISI schedule would have no effect on the safe operation of the plant.

St. Lucie has now gone through several outages with a form of this altered scheduling criteria. The second interval inservice inspection plan was scheduled with this philosophy to the extent practical within the guidelines of 83S83 Edition of Section XI.

A 40o to 45+ dose reduction has been achieved from previous outages. This is approximately 10 to 15 man-rem of exposure per outage.

Rescheduling ISI activities has lowered radiation exposure, manpower, and costs associated with the preparation, examination, 129

St. Lucie 1 ISI Program Revision 0 January 12, 1998 and recovery of the selected areas. This also reduced radiation exposure to other workers in the areas by eliminating barriers caused by scaffold and removed insulation, decreasing the amount of time required to perform a task.

While it is desirable to have examination schedules move forward in the interval (less than 10 years between successive exams),

the wording"of the Code's Program B makes this difficult. A review of Program B requirements shows that it is weighted towards moving examinations towards the end of the interval, increasing the amount of time between successive examinations (opposite from NRC desires). The maximum examinations allowed for credit during the 1st period is 344. If the minimum examinations were performed during the 1st period (164) and the maximum examined during the 2nd (674), then 51% of the interval exams could be performed during the 2nd period. This same thought process can be applied to the 3rd period. When a sample size in a category is small, Inspection Program B requires a larger number of examinations to be scheduled later in the interval. Since St. Lucie ISI examinations were originally scheduled one-third each period, it is not possible to move examination schedules forward without scheduling others later in the interval.

Program B allows up to 504 of the 10 year examinations to be performed during the 2nd or 3rd periods. Allowing this same latitude during the 1st period would enable FPL to perform examinations with a more efficient schedule, reduce radiation exposure and costs, and meet NRC desires to have the time frame between successive examinations not exceed 10 years. Most of the rescheduled weld examinations would be performed with less than 10 years between successive examinations.

For Class 2 and Class 3 systems, all piping welds and components selected for examination will be performed in the same or an earlier period as the previous interval. Class 1 systems will have examination schedules altered to achieve radiation exposure and cost reductions.

FPL realizes that the objective of the Code selection method is to examine components in all parts of the plant and to repeat those examinations on a regular basis to determine if occurring. This philosophy was used when the selection and changes are scheduling of Class 1 components was performed.

Grouping of examinations was performed to eliminate duplicate scaffold to the extent practical. These groupings mostly involve the areas around the Reactor Coolant System (RCS) loops.

However, lines from other loops and systems that pass through the 130

St. Lucie 1 ISI Program Revision 0 January 12, 1998 scheduled loop area will be included for examination at that time. This means that welds from all four RCS loops are examined during each period. Examination areas are grouped together outside the biological shield, but no distinction was made as to the loop involved. These outside areas have been scheduled on all four loops during all three periods on the same schedule as the previous interval to the extent practical. Additionally, there were'a'reas where grouping of examinations produced no advantages. These areas are scattered throughout the containment and were scheduled the same as the second interval.

V. Alternate Requirements FPL proposes to use an alternative to the IWB-2412-1 and IWC-2412-1 tables. The table proposed is:

Inspection Inspection Period, Minimum Maximum Interval Calendar Years of Examinations Examinations Plant Service Completed, Credited, 23 16 50 3rd 27 50 75 30 100 100 Notes: Except as noted in Table IWB-2500-1, B1.30.

A minimum of 16% of the required examinations will be performed during the second period.

A table similar to this is currently being incorporated into the latest edition of the Code, with a Code Case being written to allow this scheduling philosophy to be used for all Editions of Section XI.

The sequence of examinations established during the previous inspection interval will be repeated to the extent practical, but may be modified in a manner which reduces scaffold, insulation, and radiation exposure.

Florida Power and Light will schedule the same areas for examination that were performed during the Second Interval to the extent practical. The sequence of examinations established during the second interval will be followed to the extent practical, but will be altered to reduce radiation exposure and expense, and allow the examination, preparation of areas, and the recovery process to be minimized. Substitute welds may be 131

St. Lucie 1 ISI Program Revision 0 January 12'998 selected. When welds are substituted, they will be similar in configuration to those originally scheduled, and on the same or similar line, if possible. The number of examinations performed will meet or exceed the minimum number required by each category.

The number of welds and components examined will meet the percentage requirements as shown in the table above.

VI. Implementation Schedule FPL will implement this alternative to the Code during the St. Lucie 1 third 10-year inservice inspection interval.

VXI. Justification for Relief Since FPL began performing ISI examinations, the rules for radiation exposure, safety, and the selection and scheduling of ISI examination areas have changed significantly. The changes were enacted to provide additional safety to personnel working at the plants and to enhance the safety to the general public.

10CFR20.1101(b) mandates FPL to reduce radiation exposure to as low as reasonably achievable. Procedures and engineering controls based upon sound radiation protection principles are being used to the extent practicable. In order to meet this and other new regulations, FPL must reevaluate every aspect of every job at St. Lucie. Revising the XSX schedule will allow FPL to minimize the amount of work being performed in radiation areas, meet safety and ALARA requirements, and scheduling.

still meet Section XI VIII. Attachments None IX. Status Submitted 132

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Request No. 9, Reactor Pressure Vessel Nuts Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the requirements to the Code required surface examinations of the reactor pressure vessel closure head nuts as specified in Table IWB-2500-1 of the 1989 Edition of ASME Section XI.

'I. Identifi'cation Class 1 Reactor Pressure Vessel Nuts II. Code Requirement 1989 Edition of Section XI Code Category B-G-1, Pressure Retaining Bolting, Greater Than 2" in Diameter Item No. B6.10, Reactor Vessel Nuts Examination Method Surface Examination Area Entire surface of nuts III. Relief Requested r Relief is being requested from performing the surface examination on the RPV closure head nuts as required by Code Category B-G-l.

IV. Basis for Relief The Reactor Pressure Vessel Closure Head Nut configuration is such that only the outside surface is readily accessible for surface examination. The threaded area on the inside of the nuts is very difficult to adequately clean for both liquid penetrant and magnetic particle examination. The cleaning and preparation of the nuts for surface preparation could result in additional damage. Pooling of penetrant and magnetic particle material at the bottom of the nut (which must be placed on its side for examination) could mean additional cleaning time for proper examination of this area. This additional examination may further damage the nuts due to handling.

The 1989 Edition of Section XI does not provide acceptance

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for Code Category B-G-1 surface flaws found during the

'riteria examinations.

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~ FPL has used engineering evaluations on every 133

St. Lucie 1 ISI Program Revision 0 January 12, 1998 indication noted in order to determine whether a nut is acceptable for continued service. This results in more costs and handling (with the possibility of more damage) of the nuts as the engineers determine whether an indication is acceptable.

V. Alternative Examinations FPL will perform a visual VT-1 on the RPV Closure Head Nuts. The IWB-3517 acceptance criteria of the 1989 Edition of Section XI will be used for evaluation of indications.

VI. Justification for the Granting of Relief Beginning in the 1989 Addenda of ASME Section XI, the examination requirement for RPV Closure Head Nuts was changed from surface to visual VT-l. In addition, the acceptance standards of adopted, which is the same standard as for Code Category IWB-3517'ere B-G-2 bolting. A review of later Codes and Addenda shows this examination technique and acceptance standard has not changed.

Conditions that require corrective measures prior to placing the RPV Closure head Nuts back in service include corrosion, damaged threads, or deformation. Surface examinations are qualified for the detection of linear indications, and surface examination acceptance criteria mention only rejectable linear flaw lengths.

The 1989 Code does not provide any acceptance criteria for linear indications found during surface examination of RPV Closure head Nuts, as they were in the course of preparation.

By using the IWB-3517 acceptance criteria, FPL would have definite rules that could be followed for evaluation of indications found during examinations. The indications would be compared against published standards.

Footnote 3 of IWB-3517 clearly states that only relevant conditions must be evaluated. This would preclude scratches, fabrication marks, roughness, etc. from being recorded (except as a general condition). These types of indications are often seen during surface examination, and may be considered non-relevant, which requires the areas in question to be cleaned and re-examined.

Because the VT-1 visual examination acceptance criteria include the requirement for evaluation of crack-like indications and other relevant conditions requiring corrective action, such as deformed or sheared threads, localized corrosion, deformation of part, and other degradation mechanisms, it can be concluded that 134

St. Lucie 1 ISI Program Revision 0 January 12, 1998 the VT-1 visual examination provides a more comprehensive assessment of the. condition of the closure head nut than a surface examination. By performing a visual VT-1 examination of the RPV Closure Head Nuts, an acceptable level of quality and safety is provided.

-VII. "Implementation FPL will implement the alternative to the Code required examination on the RPV nuts during the St. Lucie 1 third 10-year inservice inspection interval.

VIII. Attachments None.

IX. Status Submitted 135

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Request No. 10, Reactor Pressure Vessel Bolting Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the requirements to the Code required schedule of examinations of the reactor pressure vessel closure head bolting as specified in Table IWB-2500-1 of the 1989 Edition of ASME Section XI. This relief 2;""

request affects the RPV bolting of both St. Lucie Units 1 and NOTE: THIS RELIEF COVERS BOTH ST ~ LUCIE 1 AND 2'.

Component Identification:

St. Lucie Units 1 and 2 Class 1 Reactor Pressure Vessel Bolting II. Code Requirement:

1989 Edition of Section XI Code Category B-G-1, Pressure Retaining Bolting, Greater Than 2" in Diameter Xtem No. B6 ~ 10 I Reactor Vessel Closure Head Nuts Item No. B6. 20, Reactor Vessel Closure Studs, in place Item No. B6.30, Reactor Vessel Closure Studs, when removed Xtem No. B6.40, Reactor Vessel Threads in Flange Xtem No. B6.50, Reactor Vessel Closure Washers, Bushings Successive examinations of the bolting will be the same as for the 1st interval, with studs allowed to be deferred to the end of the interval, if removed.

III. Relief Requested:

Relief is being requested from performing successive examinations on the RPV closure head bolting as required by IWB-2420.

IV. Basis for Relief:

St. Lucie currently has three complete sets of RPV bolting.

During refuel outages, the RPV bolting is removed, cleaned, and placed into storage. The bolting in storage is then placed in service. During the next refuel outage on the opposite unit, this same work is performed, with the bolting that had'previously 136

St. Lucie 1 ISI Program Revision 0 January 12, 1998 been in one unit, being placed into service in the sister unit.

This swapping of the bolting has resulted in examinations being performed in one unit now being credited for the other.

The two St. Lucie units have ISI intervals approximately 5 years apart. With the RPV bolting moving from one unit to the other, this requires FPL to perform examinations on three complete sets

'of bolting i'nstead of two. In addition, the bolting groups have been mixed on one occasion due to an unremovable stud (which has since been removed and placed with its original group).

FPL performed examinations of all three sets of RPV bolting in 1994, except on the one stud. This was done to preclude missing any examinations due to the swapping of bolting from one unit to the other.

V. Alternative Examination and Schedule FPL will perform the required examinations during the second period for unit 1 and at the same time, perform the same examinations for unit 2, which will be in the late second or third period. Examinations will be performed on all three sets of bolting, and will be in accordance with Code category B-G-1 requirements and applicable relief requests. The bolting will then be placed on a 10 schedule for examination.

VI. Justification for the Granting of Relief:

Footnote (5) of Code Category B-G-1, which applies to all Code Item numbers, states deferral of examinations is permissible except when the detected leakage of borated water requires a visual VT-1 in accordance with IWA-5250(a)(2). IWB-2420(a) states "The sequence of examinations established during the first inspection interval shall be repeated during each successive inspection interval, to the extent practical." Earlier and later editions of Section XI allow deferral of examinations of B-G-1 bolting. This wording shows that the examination of RPV bolting was considered to be important, but that they can all be performed at the same time. FPL has been required to examine 1/3 of the bolting each period only because earlier editions of Section XI required have dropped this it for the first interval. Later editions schedule requirement as being unnecessary.

Simplifying the examination schedule for the three sets of RPV studs will ensure that FPL meets the intent of ASME Section XI, which is to examine all bolting for flaws. No RPV bolting will be installed for use that has not been examined at least once 137

St. Lucie 1 ISI Program Revision 0 January 12, 1998 during the interval. FPL will perform the examinations during the second period (the equivalent third period of St. Lucie Unit 2). This will mean the scheduled examinations for one third of the bolting will be accelerated.

VII. Implementation Schedule FPL will implement the alternative to the Code required schedule of examinations on the RPV bolting during the St. Lucie unit 1 third 10-year inservice inspection interval, and the St. Lucie unit 2 second interval.

VIII. Attachments None.

IX. Status Submitted 138

St. Lucie

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1 ISI Program Revision 0 January 12, 1998 Relief Request No. 11, Use of Code Case N-416-1 Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required hydrostatic tests required after repairs or replacements as specified in the 1989 Edition of ASME Section XI.

I. System/Component(s) for Which Relief is Requested:

ASME Section XI, 1989 Edition IWA-4000, hydrostatic tests of welded repairs or installation of replacement items by welding is required on Class 1, 2, and 3 systems.

II. Code Requirement:

IWA-4700(a) requires a system hydrostatic test be performed in accordance with IWA-5000 after repairs by welding on the pressure retaining boundary.

III. Relief

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~

Requested:

FPL requests relief from performing hydrostatic tests on welded repairs or installation replacement items by welding.

IV. Basis for Relief:

Hydrostatic pressure tests impose significant costs, including potentially increased outage duration, while adding marginal (if any) value to the total repair or replacement quality.

Industry experience has demonstrated that leaks are not being discovered as a result of hydrostatic test pressures propagating a pre-existing flaw through wall. Most leaks are being found when the system is at normal operating pressure. Hydrostatic tests are time consuming, require extensive operator support, and usually mean radiation exposure to personnel. Often additional equipment must be brought in to test a localized repair/replacement, which may involve additional exposure and expense. In many cases, a system hydrostatic test must be conducted over large parts of the system.

Code hydrostatic tests subject the piping system to a small increase in pressure over the nominal operating pressure and is

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not intended to present a significant challenge to pressure

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139

St. Lucie 1 ISI'rogram Revision 0 January 12, 1998 boundary integrity. It is used primarily as a means to enhance leakage detection during the examination of components under pressure, rather than as a measure to determine the structural integrity of components. When'normal system pressure is applied, many of the areas where leakage occurs stop leaking.

FPL has compared the system pressure test requirements of the 1992 Editionof Section XI to the requirements of IWA-5000 of the 1989 Edition of Section XI. Based on that review FPL concluded that the 1992 Edition imposes a more uniform set of system pressure test requirements for Code Class 1, 2 and 3 systems.

The terminology associated with the system pressure tests requirements for all three Code classes has been clarified and streamlined. The test frequency and test pressure conditions associated with these tests has not been changed. In addition, the post-welded repair NDE requirements of the 1992 Edition of Section III remain the same as the requirements of the 1989 Edition of Section III.

Hydrostatic tests place a burden on the systems, increase radiation exposure and costs, require significant setup time, and add marginal value (if any) to the repair or replacement quality.

These tests result in hardships without a compensating increase in the level of quality and safety. Performing the tests in accordance with the proposed alternative will provide reasonable assurance that flaws will be discovered.

Use of this Code Case provides an acceptable level of quality and safety by the use of a system leakage test and the additional nondestructive examinations identified above.

V. Alternate Examinations:

In lieu of the Code required hydrostatic testing for repairs or installation of replacement items by welding in Class 1, 2, and 3 piping systems, FPL proposes to apply ASME Code Case N-416-1 as alternative rules. Code Case N-416-1 requires:

(a) NDE be performed in accordance with the methods and acceptance criteria of the 1992 Edition of Section III, (b) Visual examinations (VT-2) will be performed in conjunction with a system leakage test using the 1992 Edition of Section XI, in accordance with IWA-5000,at nominal operating pressure, (c) the use of the Code Case will be documented on the Owner's Data Report Form NIS-2 or equivalent.

140

't. ~ Lucie

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1 ISI Program Revision January 12, 1998 0

FPL will implement the requirements of the Code Case, with the following two proposed exceptions:

1. FPL will perform VT-2 visual examination (in conjunction with a system leakage test) using the requirements of the 1989 Edition of Section XI, instead of the 1992 Edition specified by Code Case N-416-1. The VT-2 requirements

'pecified in the 1989 Edition are the latest approved by the USNRC and has proven effective in maintaining leak tight integrity of the pressure boundary. Maintaining a separate VT-2 program using the 1992 Edition is a hardship without an increase in safety or quality.

2. In addition, considering the limited nature of NDE requirements for Class 3 components, FPL proposes to perform additional surface examinations on the root pass layer of butt and socket welds on the pressure-retaining boundary of Class 3 components exceeding 2" nominal pipe size only when those pressure retaining welds are required to have a surface examination in accordance with the 1992 Edition of Section III. For those Class 3 welds receiving radiography in lieu of a surface examination in accordance with Section XXX, no additional surface examination of the root layer will be performed.

VI. Justification for the Relief:

ASME Code Case N-416-1 has been included in the draft of the proposed revision to Regulatory Guide 1.147. The requirement to perform a surface examination on the root pass of class 3 welds has been included as part of the acceptance of the Code Case.

This Code Case was approved by the Code Committee as an alternative to the hydrostatic test requirements of IWA-4000 on February 15, 1994.

VII. Implementation Schedule:

Code Case N-416-1 will be implemented during the Third 10-year Inservice Inspection interval. If this Code case is published in a future revision of Regulatory Guide 1.147, and FPL intends to continue implementation of this Code Case, limitations issued in the Regulatory Guide will be implemented.

141

St. Lucie 1 ISI Program Revision 0 January 12, 1998 VIII.

Attachment:

Code Case N-416-1 IX. Status:

Submitted.

142

St. Lucie

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1 ISI Program Revision 0 January 12, 1998 CASE N-416-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: February 15, 1994 See Numeric Index for expiration and any reaffirmation dates.

Alternative Pressure Test Requirement for Welded Repairs or

'Install'ation'f Replacement Items by Welding, Class 1, 2 and 3, Section XI, Division 1 Inquiry: What alternative pressure test may be performed in lieu of the hydrostatic pressure test required by para. IWA-4000 for welded repairs or installation of replacement items by welding?

Reply: It is the opinion of the Committee that in lieu of performing the hydrostatic pressure test required by para.

IWA-4000 for welded repairs or installation of replacement items by welding, a system leakage test may be used provided the following requirements are met.

(a) NDE shall be performed in accordance with the methods and acceptance criteria of the applicable Subsection of the 1992 Edition of Section III.

(b) Prior to or immediately upon return to service, a visual examination (VT-2) shall be performed in conjunction with a system leakage test, using the 1992 Edition of Section XI, in accordance with para. IWA-5000, at nominal operating pressure and temperature.

(c) Use of this Case shall be documented on an NIS-2 Form.

If the previous version of this case were used to defer a Class hydrostatic test, the deferred test may be eliminated when the 2

requirements of this revision are met.

143

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Request No. 12, Use of Code Case N-498-1 Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required hydrostatic tests once each interval as specified in the 1989 Edition of ASME Section XI.

'I. System/Component(s) for Which Relief is Requested:

Class 1, 2, and 3 systems and components.,

II. Code Requirement:

ASME Section XI, 1989 Edition Code Category B-P, C-H, D-A, D-B, and D-C System hydrostatic tests will be performed once per interval III. Code Requirement from Which Relief is Requested:

Relief is being requested from performing the hydrostatic tests once each interval required by Code Categories B-P, C Hg D Ag D-B, and D-C.

IV. Basis for Relief:

Hydrostatic tests do not significantly challenge the systems.

They have been primarily used to enhance leakage. When leaks are detected, they have been at mechanical connections. The plant writes work orders for corrections, but usually when pressure is reduced to nominal, leaks at, mechanical connections have stopped.

This type of additional work for leakage that was not required to be corrected has increased radiation exposure and costs.

V. Alternate Examinations:

FPL will perform a system leakage test on Class 1 systems and system pressure tests on Class 2 and 3 systems once each interval in accordance with the alternatives of ASME Code Case N-498-1.

This Code Case is an alternative to 10 year hydrostatic tests required by the 1989 Edition of Section XI for Class 1, 2, and 3 systems. Use of this alternative reduces the need for special system alignments and temporary system alteration to conduct hydrostatic tests.

144

St. Lucie 1 ISI Program Revision 0 January 12, 1998 VI. Justification for Relief:

In order to perform hydrostatic tests, special system alignments and temporary system alterations are required. Temporary system alterations include removal of check valve internals, installation of temporary jumpers, and in some instances, the blanking off of pressure relief devices. The preparation for and performance of the 10-year system hydrostatic tests involve excessive cost, man-hours, and man-REM with little or no compensating increase in the level of quality or safety.

Code Case N-498-1 was approved for use.by the ASME on May 11, 1994.

VII. Implementation Schedule:

FPL will implement ASME Code Case N-498-1 during the St. Lucie 1 third 10-year inservice inspection interval. If this Code case is published in a future revision of Regulatory Guide 1.147, and FPL intends to continue implementation of this Code Case, limitations issued in the Regulatory Guide will be implemented.

VIII.

Attachment:

Code Case N-498-1 IX. Status:

Submitted.

145

St. Lucie 1 ISI Program Revision 0 January 12, 1998 CASE'N-498-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: May See Numerical Index ll, 1994 for expiration and any reaffirmation dates.

Case N-498-1 Alternative Rules for 10-Year System Hydrostatic Testing for Class 1, 2, and 3 Systems, Section XI, Division 1 Inquiry: What alternative rules may be used in lieu of those required by Section XI, Division 1, Table IWB-2500-1, Category B-P, Table IWC-2500-1, Category C-H, and Table IWD-2500-1, Categories D-A, D-B, and D-C, as applicable, for the 10-year system hydrostatic test?

Reply:

(a) It is the opinion of the Committee that as an alternative to the 10-year system hydrostatic test required by Table IWB-2500-1, Category B-P, the following rules shall be used.

(1) A system leakage test (IWB-5221) shall be conducted at or near the end of each inspection interval, prior to reactor startup.

(2) The boundary subject to test pressurization during the system leakage test shall extend to all Class 1 pressure retaining components within the system boundary.

(3) Prior to performing the VT-2 visual examination, the system shall be pressurized to nominal operating pressure for at le'ast 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for non-insulated systems. The system shall be maintained at nominal operating pressure during performance of the VT-2 visual examination.

(4) Test temperatures and pressures shall not exceed limiting conditions for the hydrostatic test curve as contained in the plant Technical Specifications.

(5) The VT-2 visual examination shall include all components within the boundary identified in (a)(2) above.

(6) Test instrumentation requirements of IWA-5260 are not applicable.

(b) It is the opinion of the Committee that, as an alternative to the 10-year system hydrostatic test required by Table IWC-2500-1, Category C-H, the following rules shall be used.

146

St. Lucie 1 ISI Program Revision 0 January 12, 1998 (1) A system pressure test shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection interval of Inspection Program B.

(2) The boundary subject to test pressurization during the system pressure test shall extend to all Class 2 components included in those portions of systems required to operate or support the safety" system function up to and including the first normally closed valve, including a safety or relief valve, or valve capable of automatic closure when the safety function is required.

(3) Prior to performing the VT-2 visu'al examination, the system shall be pressurized to nominal oper'ating pressure for a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for non-insulated systems. The system shall be maintained at nominal operating pressure during performance of the VT-2 visual examination.

(4) The VT-2 visual examination shall include all components within the boundary identified in (b)(2) above.

(5) Test instrumentation requirements of IHA-5260 are not applicable.

(c) It is the opinion of the Committee that, as an alternative to the 10-year system hydrostatic test required by Table IWD-2500-1, Categories D-A, D-B, or D-C (D-B for the 1989 Edition with the 1991 and subsequent Addenda), as applicable, the following rules shall be used.

(1) A system pressure test shall be conducted at or near the end of each inspection interval or during the same inspection period of each inspection interval of Inspection Program B.

(2) The boundary subject to test pressurization during the system pressure test shall extend to all Class 3 components included in those portions of systems required to operate or support the safety system function up to and including the first normally closed valve, including a safety or relief valve, or valve capable of automatic closure when the safety function is required.

(3) Prior to performing the VT-2 visual examination, the system shall be pressurized to nominal operating pressure for at. least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated systems and 10 minutes for non-insulated systems. The system shall be maintained at nominal operating pressure during performance of the VT-2 visual examination.

147

St. Lucie 1 ISI Program'evision 0 January 12, 1998 (4) The VT-2 visual examination shall include all components within the boundary identified in (c)(2) above.

(5) Test instrumentation requirements of IWA-5260 are not applicable.

148

St. Lucie

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1 ISI Program Revision 0 January 12, 1998 Relief Request No. 13, Use of Code Case N-509 Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required examination of integral attachments as specified in the 1989 Edition of ASME Section XI.

'I. System/0'omponent(s) for Which Relief is Requested:

Class 1, 2, and 3 integral attachments on piping and components.

II. Code Requirement:

I ASME Section XI, 1989 Edition Code Category B-H Surface examinations shall be performed on essentially 1004 of the length of the attachment weld Code Category B-K-1 No examinations required Code Category C-C Surface examinations shall be performed on essentially 1004 of the length of the attachment weld on attachments whose base material design thickness is 3/4" or greater Code Category D-A, D-B, D-C Visual (VT-3) examinations shall be performed on essentially 1004 of the length of the attachment weld III. Relief Requested:

Relief is being requested from performing the surface and visual examinations as prescribed by Section XI.

IV. Basis for Relief:

Use of this alternative reduces the need for the building of scaffold and removal of insulation from the Reactor Coolant, Safety Injection, Residual Heat Removal, and other Class 1, 2, and 3 piping systems.

There is no requirement for the examination of Class 1 integral attachments for the 3rd interval. Code Case N-509 requires FPL to examine at least 104 of piping attachments and one integral 149

St. Lucie 1 ISI Program Revision 0 January 12, 1998

,attachment on one of multiple vessels of similar design, function and service. Additional scaffolding may be built and insulation removed, but careful scheduling of examinations in conjunction with piping weld and other support examinations will minimize this work and exposure. There will be an increase in weld cleaning and preparation time. The additional preparation increases overall radiation exposure and the possibility of personnel contamination. The Code Case will increase the amount of examinations FPL would be required to perform.

For Class 2 systems, the Code requires a surface examination of integral attachments whose base material design thickness is 3/4" or greater. Code Case N-509 requires a surface examination of 10'f the population. Implementing the Code Case would result in a decrease in the building of scaffold, removal and replacement of insulation. By careful scheduling of examinations in conjunction with piping weld and support examinations, work, costs, and exposure would be reduced.

For Class 3 systems, the Code requires a VT-3 of integral attachments, with only one of multiple components of similar design, function, and service being examined. Code Case N-509 requires a VT-1 examination of 10% of the population. This would result in a decrease in the building of scaffold, removal and replacement of insulation. Again, by careful scheduling of examinations in conjunction with piping weld and support examinations, work, costs, and exposure would be reduced.

This Code Case was approved by the Code Committee as an alternative to the examination requirements on integral attachment welds of Code Categories B-K-1, C-C, D-A, D-B, and D-C.

V. Alternate Examinations:

FPL will examine a minimum of 104 of each Code Cl'ass of integral attachment in accordance with the requirements of Code Case N-509. By using this Code Case, FPL will reduce the amount of scaffold, insulation removal, and minimize radiation exposure.

While it is recognized that some additional radiation exposure will be accumulated in the performance of Class 1 integral attachments, the overall effect of the complying with the Code Case will be a reduction in total accumulated dose and costs.

Code Case N-509 requires the selection of component supports to be in accordance with the 1989 Edition of Section XI with addenda through 1990. FPL will select component supports in accordance with the requirements of Code Case N-491, "Alternative Rules for 150 0

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Examination of Class 1, 2, 3, and MC Component Supports of Light-Water Cooled Power Plants, Section XI, Division 1" which was approved for use by ASME on March 14, 1991, and approved for use by the USNRC in Regulatory Guide 1.147, Rev. 11, dated October 1994.

VI. Justification for Relief Use of this Code Case provides an acceptable level of quality and safety by the use of a system leakage test and additional nondestructive examinations.

The preparation for and performance of the Section XI required examinations involve excessive cost, man-hours, and approximately one Man-REM per outage with little or no compensating increase in the level of quality or safety. FPL has not had any failure of integral attachment welds at the St. Lucie plants.

Code Case N-509 was approved for use by ASME on November 25, 1992.

VII. Implementation Schedule:

FPL will implement ASME Code Case N-509 during the St. Lucie 1 third 10-year inservice inspection interval. If this Code case is published in a future revision of Regulatory Guide 1.147, and FPL intends to continue implementation of this Code Case, limitations issued in the Regulatory Guide will be impl'emented.

VIII.

Attachment:

Code Case N-509 IX. Status:

Submitted.

151

St. Lucie 1 XSX Program Revision 0 January 12, 1998 CASE N-509 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: November 25, 1992 See Numeric Index for expiration and any reaffirmation dates.

Case N-509 Alternative Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Welded Attachments Section XI, Division 1 Inquiry: What alternative requirements to those of IWB, IWC, and IWD may be used to select and examine integrally welded attachments?

Reply:

rules It is the opinion of the Committee that the following may be used to select and examine integrally welded attachments:

(a) This Case is limited to Examination Categories B-H, B-K-1, C-C, D-A, D-B, and D-C.

(b) Class 1, 2, and 3 component supports shall be selected for examination in accordance with IWF of the 1989 Edition with the 1990 Addenda.

(c) Except for the selection of component supports for examination, all references to Section XI within this Case shall be from th'e edition and addenda specified in the Owner's Inservice Inspection Program.

1.0 SCOPE These requirements apply to examination and sample selection of Class 1, 2, and 3 integrally welded attachments of vessels, piping, pumps, and valves listed in Table 2500-1 as follows:

(a) Table 2500-1, Examination Category B-K shall be used for Class 1 integrally welded attachments in Examination Categories B-H and B-K-1 of IWB.

(b) Table 2500-1, Examination Category C-C shall be used for Class 2 integrally welded attachments in Examination Category C-C of IWC.

(c) Table 2500-1, Examination Category D-A shall be used for Class 3 integrally welded attachments in Examination Categories D-A, D-B, and D-C of IWD.

152

St. Lucie 1 ISI Program Revision 0 January 12, 1998 1.1 Exemption Criteria (a) The exemption criteria provided in IWB-1220, IWC-1220, and IWD-1220 may be applied to Class 1, 2, and 3 components respectively, with integrally welded attachments, required to be examined in accordance with Table 2500-1.

(b) Class 1,', result performed as a and 3 integrally of welded attachment examinations component support deformation cannot be credited under the requirements of IWB-2411 or IWB-2412, IWC-2411 or IWC-2412, and IWD-2411 or IWD-2412, respectively.

1.2 Inspection Schedule Class 1, 2, or 3 integrally welded attachments selected for examination by sample selection criteria in accordance with Table 2500-1, Examination Categories B-K, C-C, and D-A, shall meet the requirements of IWB-2411 or IWB-2412, IWC-2411 or IWC-2412, or IWD-2411 or IWD-2412, respectively.

1.3 Additional and Successive Examinations (a) Class 1, 2, and 3 additional and successive examination requirements of IWB-2430 and IWB-2420 for Class 1, IWC-2430 and IWC-2420 for Class 2 and 3 as applicable, shall be applied to integrally welded attachments whose examinations reveal flaws or relevant conditions that exceed the acceptance standards of IWB-3000, IWC-3000, and IWD-3000, respectively.

(b) When integrally welded attachments are examined as a result of identified component support deformation and the results of these examinations exceed the applicable acceptance standards listed above, additional or successive examinations shall be performed when determined necess'ary based on an evaluation by the Owner.

153

St. Lucie 1 ISI Program Revision 0 January 12, 1998 TABLE 2500-1 EXAMINATION CATEGORIES EXAMINATION CATEGORY B-K, INTEGRAL A11ACHMENTS FOR CLASS 1 VESSELS, PIPING, PUMPS, AND VALVES Frequency of Item Examined'xamination Requirements/ Examination Acceptance Extent of Examination~

No. Parts Fig. No. Method Standard Examination" 810.10 Pressure Vessels IW8-2500-13, Surface IWB-3516 100% of required areas Each identified occurrence Integrally Welded -14, and -15 of each welded and each inspection Attachments attachment interval'10.20 Piping IW8-2500-13, Surface IWB-3516 100% of required areas Each identified occurrence Integrally Welded -14, and -15 of each welded and each inspection Attachments attachment interval'10.30 Pumps IW8-2500-13, Surface IWB-3516 100% of required areas Each identified occurrence Integrally Welded -14, and -15 of each welded and Each inspection Attachments attachment interval~

810.40 Valves IW8-2500-13, Surface IWB-3516 100% of required areas Each i'dentified occurrence Integrally Welded -14, and -15 of each welded and each inspection Attachments attachment interval'OTES:

(1) Examination is limited to those integrally welded attachments that meet the following conditions:

(a) the attachment is on the outside surface of the pressure retaining component, (b) the attachment provides component support as defined in NF-1110; and (c) the attachment weld joins the attachment either directly to the surface of the component or to an integrally cast or forged attachment to the component.

(2) The extent of the examination includes essentially 100% of the length of the attachment weld at each attachment subject to examination.

(3) Selected samples of integrally welded attachments shall be examined each inspection interval.

(4) In the case of multiple vessels of similar design, function and service, only one integrally welded attachment of on-y one of the multiple vessels shall be selected for examination.

(5) For piping, pumps, and valves, a sample of 10% of the welded attachments associated with the component supports selected for examination under the 1990 Addenda, IWF-2510 shall be examined.

(6) Examination is required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, inservice inspection, or testing.

(7) For the configuration shown in Fig. IW8-2500-14, a volumetric examination of volume A-8-C-D from side (8-C) of the circumferential welds may be performed in lieu of the surface examination of surfaces A-D and B-C.

154

St. Lucie 1 ISI Program Revision 0 January 12, 1998 TABLE 2500-1 (continued)

EXAMINATION CATEGORIES EXAMINATION CATEGORY C-C, INTEGRAL ATTACHMENTS FOR CLASS 2 VESSELS, PIPING, PUMPS, AND,VALVES Examination Item Requirements/ Examination Acceptance No. Parts Examined'ig. No. Method Standard Extent of Examination~~ Frequency of Examination C3.10 Pressure Vessels IWC-2500-5 Surface IWC-3512 100% of required areas Each identified occurrence Integrally Welded of each and each Attachments welded attachment inspection.'nterval'3.20 Piping IWC-2500-5 Surface IWC-3512 100% of required areas Each identified occurrence Integrally Nwelded of each and each inspection Attachments welded attachment interval~

C3.30 Pumps IWC-2500-5 Surface IWC-3512 100% of required areas Each identified occurrence Integrally Welded of each and each inspection Attachments welded attachment interval~

C3.40 Valves IWC"2500-5 Surface IWC-3512 100% of required areas Each identified occurrence Integrally X of each and each inspection Welded Attachments welded attachment interval~

NOTES:

(1) Examination is limited to those integrally welded attachments that meet the following conditions:

(a) the attachment is on the outside surface of the pressure retaining component; (b) the attachment provides component support as defined in NF-1110; and (c) The attachment weld joins the attachment either directly to the surface of the component or to an integrally cast or forged attachment to the component.

(2) The extent of the examination includes essentially 100% of the length of the attachment weld at each attachment subject to examination.

(3) Selected samples of integrally welded attachments shall be examined each inspection interval.

(4) In the case of multiple vessels of similar design, function and service, only one integrally welded attachment of only one of the multiple vessels shall be selected for examination.

(5) For piping, pumps, and valves, a sample of 10% of the welded attachments associated with the component supports selected for examination under the 1990 Addenda, (WF-2510 shall be examined.

(6) Examination is required whenever component support member deformation (e. g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, inservice inspection, or testing.

155

St. Lucie 1 ISI Program Revision 0 January 12, 1998 TABLE 2500-1 (CONTINUED)

EXAMINATION CATEGORIES EXAMINATION CATEGORY D-A, INTEGRAL ATTACBKNTS FOR CLASS 3 VESSELS, PIPING, PUMPS, AND VALVES Examination Item Requirements Examination Acceptance Extent of No. Parts Fig. No Method Standard Examination~ 3 Frequency of Examination~'ach Examined'ressure Dl.lo Vessels IWD-2500-1 Visual, IWD-3000 100% of required areas identified occurrence Integrally Welded VT-1 of each welded and each inspection Attachments attachment interval D1.20 Piping Integrally IWD-2500-1 Visual, IWD-3000 100% of required areas Each identified occurrence Welded Attachments VT-1 of each welded and each inspection attachment interval D1.30 Pumps Integrally IWD-2500-1 Visual, IWD-3000 100% of required areas Each identified occurrence Welded Attachments VT-1 of each welded and each inspection attachment interval D1.40 Valves Integrally IWD-2500-1 Visual, IWD-3000 100% of required areas Each identified occurrence Welded Attachments VT-1 of each welded and each inspection attachment interval NOTES:

(1) Examination is limited to those integrally welded attachments that meet the following conditions:

(a) the attachment is on the outside surface of the pressure retaining component; (b) the attachment provides component support as defined in NF-1110; and (c) the attachment weld joins the attachment either directly to the surface of the component or to an integrally cast or forged attachment to the component.

(2) The extent of the exam includes essentially 100% of the length of the attachment weld at each attachment subject to exam.

(3) Selected samples of integrally welded attachments shall be examined each inspection interval. All integrally welded attachments selected for examination shall be subject to corrosion, as determined by the Owner, such as the integrally welded attachments of the Service. Water or Emergency Service Water systems. In the case of multiple vessels of similar design, function and service, the integrally welded attachments of only one of the multiple vessels shall be selected for examination.

For integrally welded attachments of piping, pumps, and valves a 10% sample shall be selected for examination. This percentage sample shall be proportional to the total number of nonexempt integrally welded attachments connected to the piping, pumps, and valves, located within each system subject to these examinations.

(4)Examination is required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, inservice inspection, or testing.

156

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Relief Request No. 14, Use of Code Case N-521 Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required examination schedule of Reactor Pressure Vessel nozzles as specified in the 1989 Edition of ASME Section XI.

'I I.

4 System/Component(s) for Which Relief is Requested:

Category B-D Item Nos. B3.90 and B3.100 Reactor Pressure Vessel Nozzle-to-Vessel Welds Reactor Pressure Vessel Inside Radius Section II. Code Requirement:

Section XI, 1989 Edition Code Category B-D, deferral of examinations to the end of the outage is not permissible for RPV nozzle inside radius sections Code Category B-D, deferral of examinations to the end of the outage is permissible for RPV nozzle-to-vessel welds, but at least 254 but not more than 504 (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.

III. Relief Requested:

FPL proposes to perform all RPV inside radius section and nozzle-to-vessel weld examinations during the 10-year ISI, scheduled for 2006.

IV. Basis for Relief:

During the May 1996 outage for St. Lucie Unit 1, 100% of the Reactor Pressure Vessel welds were examined (categories B-A, B-D, and B-F). The examinations consisted of using the Enhanced Data Acquisition System from Southwest Research Institute (SwRI),

which captures essentially 1004 of the Ultrasonic signal for processing. Several of the SwRI personnel had qualified for certification with this equipment through an internal SwRI program and through the Electric Power Research Institute Nondestructive Examination Center for Appendix VIII. Every recorded indication was evaluated to determine its nature. No 157

".St. Lucie 1 XSX Program Revision 0 January 12, 1998 reportable indications were found on the nozzles or any other welds. This was the third Xnservice Inspection of these nozzles and inside radius sections.

Performing the RPV nozzle examinations during the first period is a hardship on FPL. The Code would require two of the six (334) nozzles to be examined. The examinations require substantial preparation. of, the refuel cavity and RPV in order to be performed. To examine the inside radius sections in accordance with Code requirements, the core barrel would need to be removed.

Leaving the Core Barrel in place would limit the inside radius section examination area to about. half.

Significant costs are associated with the performance of the examination. Critical path time is increased. The estimated time for removal/replacement of the core barrel is two days.

Moving the core barrel increases the risk of its damage. The performance of the examinations would take about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> critical path time at $ 75,000/hr = $ 3,600,000 Estimated cost of additional personnel = $ 20,000 Estimated cost of examinations = $ 400,000 Total cost of inside radius examinations = $ 4,020,000 St. Lucie Unit 1 does not have any Category B-F Safe-end welds.

The nozzles and piping are both carbon steel, with cladding.

V. Alternate Examinations:

FPL will perform the Code required volumetric examinations on the RPV nozzle inside radius sections and the nozzle to vessel welds in accordance with the rules of Code Case N-521. The examinations will be performed approximately ten years after the previous examinations, within the guidelines of IWA-2430.

VX. Justification for Relief:

FPL's last examination of the inside radius sections occurred in May 1996. By performing the RPV nozzle examinations during the 2006 outage, FPL will meet the intent of the Code to examine the same component every 10 years. By using this alternative schedule of examinations, FPL will be within the Code requirements.

The same types of examination will be 'performed during the 2006 outage as would be performed during the first period. There will 158

\

St. Lucie 1 ISI Program Revision 0 January 12, 1998 be 10 years between examinations, the same amount of time that is allowed by Code.

By performing the examinations at a later date, no additional safety concerns exist, as only 10 years will have elapsed since the .last examination.

The Code Case. is restricted to those PWR Vessels that have never had any repairs or replacements performed on any of the Nozzle-.

to-Vessel Welds, Inside Radius Sections, and Nozzle-to-Safe End welds. In addition, there are no successive examinations (IWB-2420(b)) required on any of these welds or areas. St. Lucie Unit 1 RPV meets both of these requirements, allowing the use of the Code Case.

Code Case N-521, "Alternative rules for Deferral of Inspection of Nozzle-to-Vessel Welds, Inside Radius Sections, and Nozzle-to-Safe End welds of a Pressurized Water reactor (PWR) Vessel, Section XI, Division 1," is an alternative to the Code required schedule. This Code Case was approved for use by the ASME on August 9, 1993.

VII. Implementation Schedule:

This alternative schedule will be implemented during the Third 10-Year Interval. The schedule for the examinations is currently during the 2006 outage.

VIII. Attachments:

Code Case N-521.

IX. Status:

Submitted.

159

St. Lucie 1 ISI Program Revision 0 January 12, 1998 CASE N-521 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: August 9, 1993 See Numerical Index for expiration and any reaffirmation dates Case N-521 Alternative Rules for Deferral of Inspections of Nozzle-to-Vessel Welds, Inside Radius Sections, and Nozzle-to-Safe End Welds of a Pressurized Water Reactor Pressure Vessel, Section XI, Division 1 Inquiry: What alternative rules may be used in lieu of Table IWB-2500-1, Examination Category B-D, "Full Penetration Welded Nozzles in Vessels Inspection Program B" and Examination Category BF, "Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles," Section XI, Division 1, to allow deferral of inspections of Nozzle-to-Vessel Welds, Inside Radius Sections, and Nozzle-to-Safe Ends Welds of a PWR vessel?

Reply: It is the opinion of the Committee that, as an alternative to the existing requirements, inspections of Nozzle-to-Vessel Welds, Inside Radius Sections, and Nozzle-to-Safe End Welds of a PWR vessel may be deferred to the end of the inspection interval if the following conditions are met for the reactor vessel in question:

(a) No inservice repairs or replacements by welding have ever been performed on any of the Nozzle-to-Vessel Welds, Inside Radius Sections, or Nozzle-to-Safe End Welds.

(b) None of the Nozzle-to-Vessel Welds, Inside Radius Sections, or Nozzle-to-Safe End Welds contains identified flaws or relevant conditions that currently require successive inspections in accordance with IWB-2420(b).

(c) The unit is not in the first inspection interval.

160

St. Lucie

~

~

1 ISI Program Revision 0 January 12, 1998 Relief Request No. 15, Use of Code Case N-524 Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required examinations of piping longitudinal welds as specified in the 1989 Edition of ASME Section XI.

I. System/Component(s) for Which Relief is Requested:

Class 1 and 2 piping system longitudinal seam welds II.. Code Requirement:

ASME Section XI, 1989 Edition Code Category B-J, Item nos. B9.12 and B9.22 Volumetric and/or surface examinations shall be performed on at least one pipe diameter length but not more than one foot of each longitudinal weld intersecting the circumferential welds required to be examined by Examination Categories B-J.

Code Category C-F-1, Item nos. C5.12, C5.22, and C5.42 Volumetric and/or surface examinations shall be performed on 2.5t

~

of each longitudinal weld at the intersecting circumferential

~ ~

weld ~

Code Category C-F-2, Item nos. C5.52, C5.62, and C5.82 Volumetric and/or surface examinations shall be performed on 2.5t of each longitudinal weld at the intersecting circumferential weld.

III. Relief Requested:

IV. Basis for Relief:

The current requirement for Class 1 systems is to examine longitudinal welds for a distance of one pipe diameter but not more than 12 inches from the intersecting circumferential weld.

Often, additional scaffolding must be built and additional insulation removed to accomplish this examination. Much of the reactor coolant system piping is carbon steel with cladding.

This material requires increased weld cleaning and preparation time. The additional preparation increases the overall radiation exposure and the potential for personnel contaminations.

161

St. Lucie 1 ISI Program Revision 0 January 12, 1998 For Class 2 systems, the requirement is to examine the longitudinal welds for a distance of two and one-half times the material thickness from the intersecting circumferential weld.

Essentially the same preparation requirements and radiation concerns discussed above for Class 1 applications apply to Class 2 p1plng The preservice examination and initial inservice examinations have provided assurance of the structural integrity of the longitudinal welds during the service life of the plant to date.

Based on results of these inservice inspections, St. Lucie Unit 1 has not experienced degradation that would warrant continued examination beyond the intersection area or volume bounded by, this Code Case. In addition, experience in the United States has shown ASME Code longitudinal welds have not experienced degradation warranting continued examination beyond the boundaries required to meet the circumferential weld examination requirements. No significant loading conditions or known material degradation mechanisms have become evident to date which specifically relate to longitudinal seam welds in nuclear plant piping.

V. Alternate Examinations:

FPL will examine those areas of Class 1 and 2 longitudinal welds within the boundaries of the intersecting circumferential weld in accordance with the requirements of Code Case N-524.

This Code Case is an alternative to the examination requirements of the longitudinal welds presently required by ASME Section XI for Class 1 and 2 piping welds. Use of this alternative reduces the need for the building of scaffold and removal of insulation for the Reactor Coolant, Safety Injection, Residual Heat Removal, and other Class 1 and 2 piping systems. Use of this Code Case provides an acceptable level of quality and safety by the use of a system leakage test and the additional nondestructive examinations identified above.

This Code Case was approved by the Code Committee as an alternative to the examination requirements on Longitudinal seam welds of Code Categories B-F, B-J, C-F-1, and C-F-2. It was approved for use by ASME on August 9, 1993.

VI. Justification of Relief:

Longitudinal welds are not produced in the field or fabrication shops as is the case of a circumferential weld. Longitudinal 162

St. Lucie 1 ISI Program Revision 0 January 12, 1998 piping welds for Class.l and 2 applications were made by the piping manufacturer under controlled conditions that produce higher quality welds and more uniform residual stress patterns.

These welds were examined by the appropriate ASTM or ASME specifications. The manufacturing controls specified by the appropriate ASTM or ASME specifications provide assurance of the structural integrity of the longitudinal welds at the time the piping. is manufactured.

Code Case N-524, "Alternative Examination Requirements for Longitudinal Welds in Class 1 and 2 Piping Section XI, Division 1," is an alternative to the Code required schedule. This Code Case was approved for use by, the ASME on August 9, 1993.

VII. Implementation Schedule:

FPL will implement ASME Code Case N-524 during the St. Lucie 1 third 10-year inservice inspection interval. If this Code case is published in a future revision of Regulatory Guide 1.147, and FPL intends to continue implementation of this Code Case, limitations issued in the Regulatory Guide will be implemented.

VIII.

Attachment:

Code Case N-524 IX. Status:

Submitted.

163

St. Lucie 1 ISI Program Revision 0 January 12, 1998 CASE N-524 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: August 9, 1993 See Numerical Index for expiration and any reaffirmation dates.

Case N-524 Alternative Examination Requirements for Longitudinal Welds in Class 1 and 2 Piping Section XI, Division 1 Inquiry: What alternative requirements may be applied to the surface and volumetric examination of longitudinal piping welds specified in Table IWB-2500-1,. Examination Category B-J, Table IWC-2500-1, Examination Categories C-F-1 and C-F-2 (Examination Category C-F prior to Winter 1983 Addenda), and Table IWC-2520, Examination Category C-G (1974 Edition, Summer 1975 Addenda)?

Reply: It is the opinion of the Committee that the following shall apply:

(a) When only a surface examination is required, examination of longitudinal piping welds is not required beyond those portions of the welds within the examination boundaries of intersecting circumferential welds.

(b) When both surface and .volumetric examinations are required, examination of longitudinal piping welds is not required beyond those portions of the welds within the examination boundaries of intersecting circumferential welds provided the following requirements are met.

(1) Where longitudinal welds are specified and locations are known, examination requirements shall be met for both transverse and parallel flaws at the intersection of the welds and for that length of longitudinal weld within the circumferential weld examination volume; (2) Where longitudinal welds are specified but locations are unknown, or the existence of longitudinal welds is uncertain, the examination requirements shall be met for both transverse and parallel flaws within the entire examination volume of intersecting circumferential welds.

164

".'t. Lucie 1 ISI Program .Revision 0 January 12, 1998 Relief Request No. 16, Alternative Piping Weld Examination Pursuant to 10 CFR 50.55a(a)(3)(i), FPL requests an alternative to the Code required IWB-2400 and IWC-2400 requirements for the scheduling of examinations as specified in the 1989 Edition of ASME Section XI. To perform the examinations as required by Section XI would result in a hardship without a compensating increase in..safety.

I. System/Component(s) for Which Relief is Requested:

Class 1 piping system circumferential and longitudinal seam welds II. Code Requirement:

ASME Section XI, 1989 Edition Category B-J Item No. B9.11 Circumferential Weld, NPS 4 or larger Item No. B9.12 Longitudinal Weld, NPS 4 or larger The examinations shall cover essentially 100% of the weld length.

Volumetric and surface examination methods are required. The area subject to examination is identified in Figure IWB-2500-8.

III. Relief Requested:

Relief is requested from performing the Code required surface examinations utilizing surface examination methods at the Main Reactor Coolant piping welds located near the RPV nozzles (see attachment for listing of welds).

IV. Basis for Relief:

Performance of these examinations on the Reactor Pressure Nozzle to pipe transition weld involves excessive costs, man-hours and man/rem with little or no compensating increase in the level of quality and safety.

Section XI requires a volumetric examination of the inner one-third of the wall thickness, and a surface examination of the outside surface. In most cases, this is the most efficient and least expensive way of examining welds. In the case of the Main Reactor Coolant piping near the RPV, the size of the piping, location of the welds, high radiation dose rates, insulation 165

St. Lucie 1 ISI Program Revision 0 January 12, 1998 removal, and erecting scaffolding is very time consuming, increasing the amount of radiation dose accumulated.

Florida Power and Light Company has determined that performing the examinations as required by Code is difficult with high radiation dose without an increase in safety or quality.

~ ~

V. Alternative Examination:

FPL will conduct volumetric examinations from the inside surface of the Reactor Pressure Vessel during the Mechanized ultrasonic examinations of the nozzles. The first and second pipe welds, along with the associated longitudinal seam welds will be fully examined volumetrically from the inside surface. The outside surface of the welds will be examined volumetrically, both axially and circumferentially.

VI. Justification for the Granting of Relief:

An ultrasonic examination of the affected welds (see attachment) has been performed successfully during the previous interval.

The material of the welds is a carbon steel, and poses no unusual difficulties for ultrasonic The proposed examination.

examination technique, along with the system pressure tests, provide assurance of an acceptable level of 0

quality and safety. To gain access to the outside of the welds in order to perform the surface examinations is difficult, time consuming, and radiation intensive.

System pressure tests as required by the St. Lucie Inservice Pressure Test Program and Section XI, have been performed. No leakage has been detected. These examinations will continue as required.

VII. Implementation Schedule:

FPL will implement this relief during the St. Lucie 1 third inservice inspection interval.

VIII. Attachments:

Listing of affected welds.

166

St. Lucie 1 ISI Program Revision 0 January 12, 1998 IX. Status Submitted 167

St. Lucie 1 ISI Program Revision 0 January 12, 1998 Attachment for Relief Request No. 16 Listing of affected welds.

Zone 1-006, Loop A Hot Leg 2 05-.07-A, RPV Outlet Nozzle to Extension RC-114-FW-1-500G Extension to Pipe RC-114-500G-LSA Longitudinal Weld RC-114-500G-LSB Longitudinal Weld Zone 1-007, Loop B Hot Leg 205-07-B RPV Outlet Nozzle to Extension RC-123-FW-1-500A Extension to Pipe RC-123-500A-LSA Longitudinal Weld RC-123-500A-LSB Longitudinal Weld Zone 1-009, Loop lA2 Cold Leg 205-03-D RPV Inlet Nozzle to Extension RC-115-FW-1-500J Elbow to Extension RC-115-4-504-LSA Longitudinal Weld RC-115-4-504-LSB Longitudinal Weld Zone 1-011, Loop 1Bl Cold Leg 205-03-A RPV Inlet Nozzle to Extension RC-121-FW-1-500C Elbow to Extension RC-121-2-504-LSA Longitudinal. Weld RC-121-2-504-LSB Longitudinal Weld Zone 1-013, Loop 1A1 Cold Leg 205-03-C RPV Inlet Nozzle to Extension RC-112-FW-1-500M Elbow to Extension RC-112-1-504-LSA Longitudinal Weld RC-112-1-504-LSB Longitudinal Weld Zone 1-015, Loop 1B2 Cold Leg 205-03-B RPV Inlet Nozzle to Extension RC-124-FW-1-500F Elbow to Extension RC-124-3-504-LSA Longitudinal Weld RC-124-3-504-LSB Longitudinal Weld 168

St. Lucie ISI Program Revision 0 January 12, 1998 Index ANII (58)

ASME Code Cases (27, 35, 36, 38, 41, 46, 50, 51)

N-307-1 (17)

N-355 (17)

N 416 1,(17'5~ 139'57)

N-460 (18)

N-461 (18)

N-481 (18, 28)

N-489 (18)

N-491 (18, 38)

N-498 (31)

N 498 1 (18'44'46)

N-509 (37, 149, 152)

N-524 (161, 164)

N-532 (66, 70)

N 533 (75 g 78)

N-546 (79, 82)

Augmented Examinations Class 1 (31)

Class 2 (37)

Class 3 (39)

Component Supports (43)

Branch Technical Position (13)

Calibration Blocks (59)

Category (32)

B-A (21)

B-B (22)

B-D (23)

B-E (24)

B-F (24)

B-G-1 (25)

B-G-2 (26)

B-H (26)

B-J (27)

B-K (27) r B-L-1 (28)

B-L-2 (28)

B-M-1 (28)

B-M-2 (28)

B-N-1 (29)

B-N-2 (29)

B-0 (30)

B-Q (31)

C-B (33)

C-C (33)

C-D (34) 169

St. Lucie ISI Program Revision 0 January 12, 1998 C-F-1 (34)

C-F-2 (35)

C-F-3 (35)

C-F-4 (35)

C-G (36)

C-H (36)

D-A (37)

D-.B. (37,)..

D-C (37)

Code of Federal Regulations (15) 10 CFR 50.55a (12) 10 CFR 50.55a(b)(2)

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(ll, 15)

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St. Lucie ISI Program Revision 0 January 12, 1998 1 147 (13'7) 1 ~ 150 (13, 17, 21, 23)

1. 26 (12, 15) 1.65 (12, 17) 1.68 (12) 1.82 (12) 1.83 (12)

Section. XI, (.3.1) snubber (42, 50, 65, 91)

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