ML042940289
| ML042940289 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/11/2004 |
| From: | Matthews W Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 04-614 | |
| Download: ML042940289 (28) | |
Text
I VIRGINIA ELECTRIC AND POWVER COMPANY RICHMOND, VIRGINIA 23261 October 11, 2004 United States Nuclear Regulatory Commission Serial No.04-614 Attention: Document Control Desk NLOS/GDM RO Washington, D.C. 20555 Docket No.
50-280 License No.
DPR-32 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 ASME SECTION Xl INSERVICE INSPECTION PROGRAM PARTIAL EXAMINATION RELIEF REQUESTS Virginia Electric and Power Company (Dominion) performed inservice inspection (ISI) examinations at Surry Power Station Unit 1 for the third ten-year ISI interval to the requirements of the 1989 Edition of ASME Section XI. Certain examinations conducted during the third period of the third interval could only be partially performed due to interferences that prohibited full weld coverage being attained during the examinations.
Pursuant to 10 CFR 50.55a(a)(3) and 10 CFR 50.55a(g)(5), relief is requested from certain requirements of the ASME Section Xl Code associated with examinations where only partial coverage could be obtained. Relief Requests PRT-2 through PRT-06 are included in Attachments 1 through 5, respectively, and provide the bases for this request. The relief requests have been approved by the Station Nuclear Safety and Operating Committee.
If you have any questions or require additional information regarding the attached relief requests, please contact Mr. Gary D. Miller at (804) 273-2771.
Very truly yours, William R. Matthews Senior Vice President - Nuclear Operations Attachments Commitments made in this letter:
None U4
Serial No.04-614 Docket 50-280 Page 2 cc:
U. S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. S. R. Monarque U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8H12 Rockville, MD 20852 Mr. N. P. Garrett NRC Senior Resident Inspector Surry Power Station Mr. R. A. Smith Authorized Nuclear Inspector Surry Power Station
I Relief Request PRT-02 Virginia Electric and Power Company (Dominion)
Surry Power Station Unit 1
Serial No.04-614 Docket 50-280 Virginia Electric & Power Companv Surrv Power Station Unit 1 Third Ten Year Interval Relief Request No. PRT-02 Identification of Components Weld Nos.
H003-1, H003-2 Drawing 11 448-WMKS-0101 Dl Pipe Line No.
30"-SHP-2-601 ASME Class 2
Description Integral Attachments
- 11.
Code Requirement The 1989 Edition of ASME Section Xl Table IWC-2500-1, examination category C-C, item number C3.20, requires a surface examination of 100% of required areas of each welded attachment as defined by Figure IWC-2500-5. Code Case N-460 allows a reduction in coverage only if the reduction is less than 10 percent.
Ill.
Basis for Relief This component support has multiple integrally attached welds as shown in the sketches on pages 3 and 4. One portion consists of two clevis type attachments that were welded to the pipe prior to the installation of two clam shell type pieces that were assembled over the attachments.
The two clam shell pieces were welded together with two longitudinal welds and then attached to the pressure boundary with two circumferential welds. One hundred percent (100%) coverage of the two circumferential welds was obtained. Forty-two percent (42%) of the welds associated with the clevis attachments were accessible and examined resulting in a net total coverage of 75% for the whole component.
The purpose of nondestructive examination (NDE) is to perform inspections without destroying the component. Permanent removal of the exterior protective shell would be required to render all the welds in question accessible for any type of NDE exam, which is contrary to the intent of the code. In fact, more recent editions of Article IWC-1000, such as the 1998 Edition through 2000 Addendum, define "Inaccessible Welds" under IWC-1223 as "Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe."
Thus, these portions of 1
II:
Serial No.04-614 Docket 50-280 welds would be classified as inaccessible by later code editions and would be exempt from the requirements of IWC IV. Alternative Examination This component receives periodic VT-2 examinations in accordance with Category C-H, which should detect any through wall leakage in the inaccessible areas. No alternative NDE methods could provide additional data, and no alternative component may be selected to meet the 100% requirement for pipe integral attachments. Destruction of the component would be necessary to perform 100%
of the code required exam as written in the 1989 ASME Section Xl Code Edition and is contrary to the intent of the Code.
Therefore, Dominion requests relief from performing the code required surface exam on the inaccessible parts of this integral attachment in accordance with 10 CFR 50.55a(g)(6)(i) since examination in this area is impractical. The VT-2 examination is an acceptable means for detecting through-wall leakage.
2
I Relief Reauest No. PRT-02 11448-WMKS-O0O1D1 H003-1, 2 Permant Pipe Encasement Front View Side View RT0613 3/32 scote 3
II i
Relief Reauest No. PRT-02 11448-WMKS-OlOlDl H003-1, 2 CLEVIS WELDS.
NOT ACCESSIBLEar
/
RT0613 Exploded Side View 4
Serial No.04-614 Docket 50-280 Relief Request PRT-03 Virginia Electric and Power Company (Dominion)
Surry Power Station Unit 1
I Serial No.04-614 Docket 50-280 Virginia Electric & Power Companv Surrv Power Station Unit 1 Third Ten Year Interval Relief Request No. PRT-03 Identification of Component Weld No.
H002-1 Drawing 11448-WMKS-0102D1 Pipe Line No.
30"-SHP-3-601 ASME Class 2
Description Integral Attachments
- 11.
Code Requirement The 1989 Edition of ASME Section Xl Table IWC-2500-1, examination category C-C, item number C3.20 requires a surface examination of 100% of required areas of each welded attachment as defined by Figure IWC-2500-5. Code Case N-460 allows a reduction in coverage only if the reduction is less than 10 percent.
Ill.
Basis for Relief This component support has multiple integrally attached welds as shown in the sketches on page 3. One portion consists of two clevis type attachments that were welded to the pipe prior to the installation of two clam shell type pieces that were assembled over the attachments. The two clam shell pieces were welded together with two longitudinal welds and then attached to the pressure boundary with two circumferential welds, thus rendering the clevis welds totally inaccessible.
One hundred percent (100%) of the examination surface for the circumferential welds was obtained utilizing Magnetic Particle and Liquid Penetrant examination methods. Zero percent (0%) of the welds associated with the clevis attachments were examined resulting in a net total of 89% coverage for the component.
The purpose of nondestructive examination (NDE) is to perform inspections without destroying the component. Permanent removal of the exterior protective shell would be required to render the welds in question accessible for any type of NDE exam, which is contrary to the intent of the code. In fact, more recent editions of Article IWC-1000, such as the 1998 Edition through 2000 Addendum, define "Inaccessible Welds" under IWC-1223 as "Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe." Thus, these welds would be 1
II Serial No.04-614 Docket 50-280 classified as inaccessible by later code editions and would be exempt from the requirements of IWC.
IV. Alternative Examination This component receives periodic VT-2 examinations in accordance with Category C-H, which should detect any through-wall leakage in the inaccessible areas. No alternative NDE methods would provide additional data, and no alternative component may be selected to meet the 100% requirement for pipe integral attachments. Destruction of the component would be required to perform 100% of the code required exam as written in the 1989 ASME Section Xl Code Edition, which is contrary to the intent of the Code.
Therefore, Dominion requests relief from performing the code required surface
-exam on the inaccessible parts of this integral attachment in accordance with 10 CFR 50.55a(g)(6)(i) as examination in this area is impractical.
The VT-2 examination is acceptable for detecting through-wall leakage.
2
.1 114 48-WMKS-0102D1 H002-1 Sue Viw RT0832.
3/32 -scate RT0832 3(32 scale XI cia) 3
Serial No.04-614 Docket 50-280 Relief Request PRT-04 Virginia Electric and Power Company (Dominion)
Surry Power Station Unit 1
I A
Serial No.04-614 Docket 50-280 Virginia Electric & Power Company Surrv Power Station Unit 1 Third Ten Year Interval Relief Request No. PRT-04 Identification of Component Weld Nos.
1-05 and 1-11 Drawing 11448-WMKS-0127J2' Pipe Line No.
6"-RC-1 9-1502 ASME Class 1
Description Circumferential Pipe welds governed by the Risk Informed program
- 11.
Code Requirement These welds are governed by the Risk Informed Inservice Inspection (RI-ISI)
Program that was approved by the NRC for Surry Unit 1 in their letter dated December 16, 1998. The welds are assigned category R-A, item R1.11, and require an ultrasonic examination.
Ill. Basis for Relief Weld 1-05 is a circumferential weld joining a valve and a pipe tee. The material type and outside profile do not allow for ultrasonic examination from the outside, resulting in no coverage of the examination volume in the 2 direction.
Only 14% of the examination volume could be attained in the 2 and 5 direction. For flaws oriented transverse to the welds, in the 7 and 8 scan direction, full coverage was attained. The total average percent coverage obtained is 57%. (See Table 1.)
Ultrasonic shear wave examination was attempted on the tee and valve sides of the weld, and it was apparent that the material for these components is cast stainless steel. At elevated sensitivity levels, an inner diameter roll was not visible on the valve side, and excessive noise resulted on the tee side. The weld material was examined to the maximum extent practical in the 2, 5, 7 & 8 directions. Alternative ultrasonic techniques would not produce additional meaningful data.
Weld 1-11 is a circumferential weld joining a pipe tee and a reducer. The material type and outside profile do not allow for ultrasonic examination from the tee side in the 2 direction resulting in no coverage of the examination volume. From the reducer side, due to curved surface configuration and the weld profile, only 44% of the 1
AI Serial No.04-614 Docket 50-280 examination volume could be examined in the 5 direction.
For flaws oriented transverse to the welds, i.e., the 7 and 8 directions, full coverage was achieved. The total average percent coverage obtained is 61 %. (See Table 1 below.)
Due to material type limitations of the tee (cast stainless) and the component outer diameter contour of the reducer, the examination volume was examined to the maximum extent practicable. Altemative ultrasonic techniques would not produce additional meaningful data.
Table 1 %UT Scan Coverage at 45 degree Angle Beam Direction 2
5 7
8 Total Average 1-05 14 14 100 100 57 1-11 0
44 100 100 61 UT Scan Direction Definitions 2 - axial scan, 180 degrees from isometric flow direction.
5 - axial scan, the same direction as the isometric flow.
7 - circumferential scan, clockwise rotation when viewing in the direction of isometric flow.
8 - circumferential scan, counter-clockwise rotation when viewing in the direction of isometric flow.
Risk Informed Background The welds in question are both part of the RI-ISI Program initially approved on December 16, 1998 under the Westinghouse Owners Group pilot RI-ISI methodology.
The methodology is described in WCAP-14572, Rev.1-NP-A, "Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report (WCAP)."
The welds are part of segment ECC-002, which acts as a conduit for safety injection cooling water from both the high pressure and low pressure safety injection pumps (common piping) to the "B" reactor coolant loop piping cold side. Segment ECC-002 is separated by single check valves from segments: RC-042, classified as High Safety Significant (HSS),
LHI-10, classified as HSS, and HHI-12C, classified as Low Safety Significant (LSS).
The initial quantitative analysis determined segment ECC-002 to be LSS.
However, the expert panel was concerned about the separation from RC-042 by a single check valve (1-SI-82), since segment RC-042 is a 6-inch line that connects with a 27Y/2 inch main loop reactor coolant line. Furthermore, thermal stratification has been experienced with associated high thermal cyclic fatigue within the industry (i.e., Farley plant) in this area in the past. Therefore, the segment was 2
4 Serial No.04-614 Docket 50-280 determined numerically HSS for Surry Unit 1. The expert panel, noting the single check valve boundary, was concerned about valve leakage and the potential for causing the same problem in segment ECC-002 that was considered for RC-042.
As such, the Expert Panel changed the classification to HSS.
The segment ECC-002 failure probability analysis assumed some thermal stratification and determined the large leak (no ISI, no leak detection) failure probability to be 8.295E-4 for 40 years. Per WCAP-14572, Rev.1-NP-A, page 168, PLARGE LEAK > 1 OE-3 to 1 OE-4 per 40 year operating life is required to consider the segment as having a high failure importance and require Region 1 (A) and 1 (B) selections (reference Figure 3.7-1 in WCAP). Based on the failure probability (PLARGE LEAK), the segment could have been classified as Region 2 and only require statistical sampling. Conservatively, the segment was treated as having a high failure importance, and weld 1-05 was designated Region 1 (A) (weld just before the check valve) or mandatory and weld 1-08 was designated a statistical sample or Region 1 (B).
Additional Exam Performed Weld 1-08 received an ultrasonic examination (Category R-A, item R1.1 1) and met coverage requirements with no recordable indications (NRI).
Weld 1-05 was ultrasonically examined with NRI (Category R-A, item R1.11), but attained only 57% coverage. Partial guidance is described in the WCAP on pages 191 and 192.
It was determined from the guidance that weld 1-11 (not part of the initial RI-ISI selection) would be ultrasonically examined (Category R-A, item R1.11) to supplement the 1-05 examination. This weld is just upstream of the 1-05 weld in segment ECC-002. Again, only partial coverage was attained (61% with NRI.) No other selections were deemed necessary.
Final Assessment The RI-ISI program postulates potential damage mechanisms in determining the appropriate examination requirement.
In this case, thermal cycling which eventually causes thermal fatigue failure is the postulated damage mechanism.
Segment RC-042, which is the primary area of concern for this phenomena, was examined (Category R-A, Item R1.11) at welds 1-02 and 1-04 (weld on opposite side of check valve 1-SI-82) with NRI. No evidence of the postulated mechanism was found on the segment.
For the damage mechanism to be present, check valve 1-SI-82 would also need to leak significantly to affect the upstream segment ECC-002.
This valve is a pressure isolation valve (PIV), which is required to meet leakage requirements established by Surry Technical Specification 3.1.C.7.a. These valves are tested for leakage and positive closed position.
3
Serial No.04-614 Docket 50-280 On September 13,1995, within the third interval prior to RI-ISI implementation, weld 1-07 on ECC-002 was examined (Category B-J, item B9.11) with NRI.
The expert panel conservatively required surface (liquid penetrant) examinations on welds 1-05 and 1-08 on ECC-002 and on welds 1-02 and 1-04 on RC-042.
This requirement is in addition to the requirements of R1.1 1, which specifies only ultrasonic examination. The examination identified NRI.
IV. Alternative Examination The examinations performed and the considerations discussed above adequately address the postulated concerns associated with the RI-ISI program and the partial examinations.
Dominion requests relief in accordance with 10 CFR 50.55a(a)(3)(i) for the supplemental examinations discussed above to be considered as an acceptable alternative for completion of this RI-ISI ultrasonic examination requirement.
The RI-ISI program is a "living program." The limitations experienced with the ultrasonic examination will be discussed with the panel at the next update meeting and will be given additional consideration with regard to some of the conservative classifications discussed above.
4
Serial No.04-614 Docket 50-280 Relief Request PRT-05 Virginia Electric and Power Company (Dominion)
Surry Power Station Unit 1
Serial No.04-614 Docket 50-280 Virginia Electric & Power Company Surrv Power Station Unit 1 Third Ten Year Interval Relief Reauest No. PRT-05 I.
Identification of Components Weld No.
Drawing ASME Class ASME Category ASME Item Description Weld No.
Drawing ASME Class ASME Category ASME Item Description 1-07 11448-WMKS-RC-E-2 1
B-B B2.11 Pressurizer Shell to Head Circumferential Weld J
1-15 11448-WMKS-RC-E-2 1
B-B B2.12 Pressurizer Shell to Head Longitudinal Weld II.
Code Requirement The 1989 Edition of ASME Section XI Table IWB-2500-1, examination category B-B, item B2.11, requires volumetric examination of essentially 100% of the circumferential shell to head welds.
Table IWB-2500-1 category B-B, item B2.12, of the 1989 Edition requires volumetric examination of one foot on the longitudinal weld that intersects the selected circumferential shell to head weld.
Ill.
Basis for Relief The pressurizer is covered with an insulation support ring (Figure 1).
The insulation support ring is 6 inches wide at the location where examination interference is encountered for weld 1-07. As seen in Figure 1, this insulation support ring and a power operated relief valve support prevent complete volumetric coverage of both the upper circumferential head weld and the intersecting longitudinal weld 1-15. Total removal of the insulation support ring at the mechanical connection is considered impractical due to high anticipated exposure levels, estimated at 18 man-rem. Partial removal of the support ring 1
Serial No.04-614 Docket 50-280 could allow some increased coverage; however, the actual increase would be very small in relation to the entire weld length. This partial removal is not a viable alternative when considering consequential disturbance of interconnected cross supports and the welded connections to safety and power operation relief valve supports. Any removal of the mechanical connections or forced spreading apart of components would create a risk of misalignment and possible warping of the structure.
Weld 1-07, the circumferential head weld, was examined for 100% of the weld length. Examination coverage of the required examination volume was limited due to the position of hardware that supports the safety valves. Table 1 shows the percent volume that was examined by each scan direction.
All areas were examined to the maximum extent practical for flaws oriented in the circumferential and axial directions.
The average total examination coverage of all scan directions is 38.3%.
Examination of weld 1-15 was examined to the maximum extent possible but was limited by the power operated valve support. Table 2 shows the percent volume achieved for each scan direction. All areas were examined to the maximum extent practical for flaws oriented in the circumferential and axial directions.
The average total examination coverage of all scan directions is 30.5%.
IV. Alternative Examination No additional ultrasonic examination techniques, such as extended beam, or alternative nondestructive examination methods would provide meaningful additional data on this cladded material for the examination volume not attained. It is proposed that the percentage coverage obtained be considered as meeting the Code requirements in accordance with 10 CFR 50.55a(a)(3)(ii) since any effort to achieve greater coverage is considered a hardship due to the risk of component damage and excessive personnel dose exposure without a compensating level of quality and safety.
In an NRC letter dated August 30, 1995, similar relief was granted for the Surry Unit 2 Third Interval (Relief Request SR-011) under the same ASME Section Xl 1989 Edition.
2
r'IPING-
?OA WE LD I'S BE14IN~D SuPpoRIT WtLDE.D (TY?).
.INSULATION..5LJPO&T 1SO (FOR STUJDYr OF INTERFF-RE!JCE3 WITH I'$I NOE' OF FRESSURI'ZER
-WELDS Ir 7.4 -15)
Firwre. I~
PIRE $URIZER INSULATION.
SUPPORT 3
I 11448-WMKS-RC-E-2 1-07 (Hatched oreas represent no examination coveroge)
-J INSTRU1CuTAT' h022LE Foxre 2 Weld 1-07 Scan Detai RT550113.:
11448-WMKS-RC-E-2 1-15 Pressurizer, Long Sean Weld
.(Hatched c'eas represent no examination coverage) 4tJM 3_ a.._ M
- n S.k ~.
ls, 5 72 C-.h*4t S = LK i-iAg I --* s II aMr
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s I C 54, M. -'
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'1 -1 I tS l 4Z. S ks 1.
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W36 3 11 -1 "t
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. Figure 3 Weld 1-15 Scan Delail RT5506 4
Serial No.04-614 Docket 50-280 Table 1 Weld 1-07, % Volume by Scan Direction SCAN ANGLE, SCAN SCAN AREA
% EXAMINED degrees DIRECTION 0
0 Weld and Base 68 Metal 45 2
Weld and Base 82 Metal 60 2
Weld and Base 20 Metal 45 5
Weld and Base 15 Metal 60 5
Weld and Base 20 Metal 45 7
Weld and Base 35 Metal 60 7
Weld and Base 35 Metal 45 8
Weld and Base 35 Metal 60 8
Weld and Base 35 Metal Average Percent Examined for Weld 1-07:
38.3%
5
Serial No.04-614 Docket 50-280 Table 2 Weld 1-15, % Volume by Scan Direction SCAN ANGLE, SCAN SCAN AREA
% EXAMINED degrees DIRECTION 0
0 Weld and Base 10 Metal 45 2
Weld and Base 57 Metal 60 2
Weld and Base 75 Metal 45 5
Weld and Base 36 Metal 60 5
Weld and Base 57 Metal 45 7
Weld and Base 10 Metal 60 7
Weld and Base 10 Metal 45 8
Weld and Base 10 Metal 60 8
Weld and Base 10
_ _Metal Average Percent Examined for Weld 1-15:
30.5%
UT Scan Direction Definitions 2 - axial scan, 180 degrees from isometric flow direction.
5 - axial scan, the same direction as the isometric flow.
7 - circumferential scan, clockwise rotation when viewing in the direction of isometric flow.
8 - circumferential scan, counter-clockwise rotation when viewing in the direction of isometric flow.
6
Serial No.04-614 Docket 50-280 Relief Request PRT-06 Virginia Electric and Power Company (Dominion)
Surry Power Station Unit 1
tV Serial No.04-614 Docket 50-280 Virginia Electric & Power Company Surrv Power Station Unit I Third Ten Year Interval Relief Request No. PRT-06 Identification of Component Weld No.
1-AO1 Drawing 1 1448-WMKS-RH-E-1A ASME Class 2
Description Circumferential Head Weld
- 11.
Code Requirement The 1989 Edition of ASME Section Xl Table IWC-2500-1, examination category C-A, item C1.20 requires essentially 100% volumetric examination of the weld length.
Ill.
Basis for Relief This code requirement for the Residual Heat Removal (RHR) heat exchanger circumferential head weld was divided into thirds of the 360 degree circumference and distributed between "A" and "B" heat exchangers as in the previous interval.
Fifty-eight percent (58%) coverage of the 0" datum point to 44" on "A" was obtained. One hundred percent (100%) coverage of 44" to 88" was obtained on "B" heat exchanger and 91% of the 88" datum to 0" on "A" was covered. Thus, the total percent coverage for the circumference of the RHR heat exchanger head weld is 83%.
The limitation in examination was created by the concrete support and inlet nozzle shown on page 3. The figures on page 4 show the exact location of interference for weld 1-01 on the "A" heat exchanger. A 45-degree angle beam was used, and partial percentages per scan are shown in the following table.
1
Serial No.04-614 Docket 50-280
%UT Scan Coverage at 45 degree Angle Beam Direction 2
5 7
8 0" to 44" 34%
48%
58%
58%
88" to 132" 91%
l 91%
91%
91%
UT Scan Direction Definitions 2 - axial scan, 180 degrees from isometric flow direction.
5 - axial scan, the same direction as the isometric flow.
7 - circumferential scan, clockwise rotation when viewing in the direction of isometric flow.
8 - circumferential scan, counter-clockwise rotation when viewing in the direction of isometric flow.
An extended beam path 1.5 MHz at a 45-degree angle was used to achieve the maximum possible coverage. Additional scans using different angles, additional beam paths or alternative techniques will not improve quality or quantity of examination.
No recordable indications were noted on any of the areas examined. The portions of the weld not examined are virtually inaccessible, and it would be impractical to attempt to remove any portion of the concrete support to allow full examination.
IV.
Alternative Examination Dominion proposes that the examinations already completed at the reduced coverage of 83% for this category C-A, item C1.20 weld are acceptable for meeting the code requirements in accordance with 10 CFR 50.55a(g)(6)(i). The code requirement in this application is impractical because of the concrete support and connecting pipe interference making the particular weld areas inaccessible.
Any through-wall leakage on this component would likely be detected during the periodic VT-2 exam that is performed on this component under Category C-H.
Similar relief was previously granted by the NRC in letter dated April 14, 1994 for the previous interval.
2
Relief Reauest No. PRT-06 11448-WMKS-RH-E-1A
.1-A01 SIDE VIEW.
TOP VIEW RT6013 1/8 scale 3
Rellef Request No. PRT-06 11448-WMKS-RH-E-IA I-AO]
WELD EXAMINED rMM 98 TO 13t CO-DATLUH Z SIDC HA7CHCD MICAA IS AREA NOT XMINCD IN 2A7 L 8 SCANS AMA HOT CXAIMIND CAN NT DE RCAO9C DCCAUS Or CNCRETC SUPvMr C13L A4D ADJACrHT PIPING 9K OF THC CX 4NATIM VtJJC CXAlNICO kT6013
.l448-WMKS-RH-E-lA 1-AOl CX041INATIN rR D EATLI To 44' WELD I-AM~
48'
~
- 4.
VC-LD l-A02
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C
=
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==
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HATDCD ARA IS AREA NOT CXMINECD IN 2;5,7 L C SCANS ARtA N1T'[C!XAlICD CAN NOT'BE RCACffD ECAUSE Or CONCR£T7 SUPPORT.C(XUNN AND ADJACCNT PIPING 5O% Or 7ffE EXAMINATIJN VtLUME ENAMINED.
RT6032 4