3F1009-05, Response to Request for Additional Information on the Third 10-Year Inservice Inspection Interval Requests for Relief 09-001-II, 09-002-II and 09-003-II

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Response to Request for Additional Information on the Third 10-Year Inservice Inspection Interval Requests for Relief 09-001-II, 09-002-II and 09-003-II
ML093030455
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 10/26/2009
From: Cahill S
Progress Energy Florida
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
3F1009-05, TAC ME0905, TAC ME0906, TAC ME0907
Download: ML093030455 (48)
v • d • e


Text

0Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 50.55a October 26, 2009 3F1009-05 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Response to Request for Additional Information on the Third 10-Year Inservice Inspection Interval Requests for Relief 09-001-11, 09-002-II and 09-003-11 (TAC NO. ME0905, ME0906 and ME0907)

References:

1. CR-3 to NRC letter, dated March 20, 2009, "Crystal River Unit 3 - Third Ten-Year Inservice Inspection (ISI) Interval Relief Requests #09-001-11, #09-002-11 and #09-003-11"
2. CR-3 to NRC letter, dated May 28, 2009, "Crystal River Unit 3 - Third Ten-Year Inservice inspection (ISI) Interval Relief Request #09-003-I, Revision 1"
3. NRC to CR-3 Electronic Mail, dated August 23, 2009, "Request for Additional Information on the Third 10-Year Inservice Inspection Interval Requests for Relief 09-001-11, 09-002-11 and, and 09-003-11 for Florida Power Corporation Crystal River Nuclear Power Plant, Unit 3"

Dear Sir:

Pursuant to 10 CFR 50.55a(g)(5)(iii), Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc., submitted Relief Requests 09-001-11, 09-002-11 and 09-003-11 (References 1 and 2). These relief requests seek approval for limited volumetric examinations performed on ASME Code Class 1 piping and nozzles, ASME Code Class 2 piping and nozzles, and on the ASME Code Class 1 Reactor Pressure Vessel Shell, respectively, during the Crystal River Unit 3 (CR-3) Third Ten-Year Inservice Inspection (ISI) Interval. The Nuclear Regulatory Commission (NRC), by electronic mail dated August 23, 2009, provided a request for additional information (PAl), concerning the Relief Requests (Reference 3). The Enclosure to this letter provides the response to the RAI. No new regulatory commitments are made in this submittal.

If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Superintendent, Licensing and Regulatory Programs at (352) 563-4796.

Sincerely, Stephen J. Cahill Manager, Engineering Crystal River Nuclear Plant SJC/dwh

Enclosure:

Response to Request for Additional Information xc: NRR Project Manager Regional Administrator, NRC Region II Senior Resident Inspector Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 1 of 46 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION The NRC staff has reviewed the information submitted by the licensee, and based on this review, determined the following information is required to complete the evaluation.

2. REQUEST FOR ADDITIONAL INFORMATION 2.1 Request for Relief 09-001-11, Part A, Examination Category B-D, Items B3.110, B3.120, B3.130, and B3.140, Full Penetration Welded Nozzles in Vessels 2.1.1 In Attachment A of Enclosure 1, the licensee has included multiple sketches and tables with volume coverage percentages for different angle beam orientations on steam generator and pressurizer nozzle-to-vessel welds and inner radius sections. However, in many of the sketches, it is unclear which portions, and how much of the ASME Code-Required Volumes have been completed. Please clearly describe or provide drawings showing volume coverage for each of the ultrasonic angles applied. Include dimensions, scanning directions and ultrasonic techniques (longitudinal or shear wave) used. In addition, list the base and weld materials. As applicable, describe NDE equipment (ultrasonic scanning apparatus), details of the listed obstructions (size, shape, proximity to the weld, etc.) to demonstrate accessibility limitations, and discuss whether alternative methods or advanced technologies could be employed to maximize ASME Code coverage.

RESPONSE

B3. 110 PressurizerNozzle-to-Head Welds: B2.2. 1A, B2.2.2A, B2.2.3A and B2.2.4A and B3. 120 PressurizerNozzle Inner Radius: B2.2. 1B, B2.2.2B, B2.2.3B and B2.2.4B The pressurizer upper head material is SA-516 Grade 70 carbon steel and the relief nozzle material is SA-508 Class 1 carbon steel. Welds B2. 2. 1A, B2.2. 2A, and B2.2.3A (Relief Nozzles) have a diameter of 6.875 inches and a wall thickness of 4.750 inches.

Weld B2.2.4A (Spray Nozzle) has a diameter of 7.750 inches and a wall thickness of 4.750 inches.

During the manual ultrasonic examination of these nozzle-to-head welds and nozzle inner radii, less than 90% coverage of the required examination volume was obtained.

The percentage of coverage reported for each weld represents the aggregate coverage from all scans performed on the weld and adjacent base material (pressurizerhead).

The examination coverage was based on the aggregatefrom each scan as follows:

Manual scans of the base material from the head side (Scan directions as labeled 1, 3 and 4 on Figures 1 and 2): 450, 600, and a supplemental 350 shear wave scans perpendicularand parallel to the weld in one axial direction and two circumferential directions and 00 longitudinalwave.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 2 of 46

  • Manual scans of the weld volume from the head side (Scan directions as labeled 1, 3 and 4 on Figures 1 and 2): 450 and 60' shear wave scans perpendicularand parallel to the weld in one axial direction and two circumferential directions and 0° longitudinalwave.

" Manual scans of the weld volume from the nozzle side (Scan direction as labeled 2 on Figures 1 and 2): 350 and 700 shear wave scans perpendicularand parallelto the weld in one axial direction and two circumferential directions.

The actual material,coverage amount, and component configurations are as follows:

B2.2.1A CLAD CARBON STEEL 50% Nozzle-to-Head Welds B2.2.2A CLAD CARBON STEEL 50% Nozzle-to-Head Welds B2.2.3A CLAD CARBON STEEL 50% Nozzle-to-Head Welds B2.2.4A CLAD CARBON STEEL 56% Nozzle-to-Head Welds B2.2.1B CLAD CARBON STEEL 42% Nozzle Inner Radius B2.2.2B CLAD CARBON STEEL 42% Nozzle Inner Radius B2.2.31 CLAD CARBON STEEL 42% Nozzle Inner Radius B2.2.41 CLAD CARBON STEEL 48% Nozzle Inner Radius Manual scans were performed using qualified pulse-echo ultrasonic instruments and hand-held transducers, as specified in the Progress Energy ultrasonic examination procedures.

The Crystal River Unit 3 (CR-3) Inservice Inspection Plan allows the use of Code Case N-460, which requires greater than 90% volumetric coverage of examination volume A-B-C-D-E-F-G-H-J (Figure 3). Therefore, the available coverage will not meet the acceptance criteria of this Code Case. The area not examined for the pressurizer nozzle-to-head welds are shown in Figure 4.

There were no recordable indications found during the inspection of the nozzle-to-head welds or nozzle innerradii.

The pressurizernozzle-to-vessel head welds and the pressurizer nozzle inner radii are accessible only from the head side, based on the nozzle curvature. The scanning surface of the nozzle is perpendicularto the head surface, which prohibits the ultrasonic wave entering the Code required examination volume at an angle that will integrate the weld volume for in-service flaws. In order to scan all of the required volume for this weld, the relief nozzles would have to be redesigned to allow scanning from both sides of the weld, which is impractical.

Radiography, as an alternative, is not feasible because access is not available for film placement. IWB-2500, Table IWB-2500-1, Examination Category B-P System Leakage Tests and VT-2 visual examinations performed each refueling outage provide adequate assurance of pressure boundary integrity. No alternative examinations or advanced

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 3 of 46 technologies were considered capable of maximizing ASME code coverage further for the weld during the current inspection interval.

Welds B2.2.2A and B2.2.2B have an obstruction in the examination area from a welded lifting lug (Figures 5 and 6). The exam was limited for 13 inches radially for a limitation of 25% of the Code Required Volume. Combined with the total examination limitations, due to geometry and physical restriction,the total examination of Code Required Volume was approximately 50% and 42%, respectively.

Welds B2.2.1, 2.2.2, 2.2.3 (A&B)

Parallel Scans (3,4)

UPPER (

2 Perpendicular Scans (1,2)

  • _Weld Nozzle Inner Radius Area Figure 1 Relief Nozzles

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 4 of 46 Nozzle Bore Weld B2.2.4(A&B)

Perpendicular Scans (1,2)

Parallel Scans (3A4) 3; Id 1 Head Figure 2 Spray Nozzle

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 5 of 46 NOZZLE B3.110 Pressurizer Nozzle-to-Head Welds B2.2.1A, B2.2.2A, B2.2.3A and B2.2.4A B3.120 Pressurizer Nozzle Inside Radius B2.2.1B, B22.21B, B2.2.3B and B2.2.4B WELD i~

I / A I /

HEAD

/

jl I

/

IF Figure 3 Weld Examination Volume

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 6 of 46 Figure 4 B3. 110, PRESSURIZER NOZZLE-To-HEAD WELDS B2.2. 1A, B2.2.2A, B2.2.3A, B2.2.4A Area not examined is the Cross Hatched area.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 7 of 46 Welds B2.2.2A & B2.2.2B Figure 5 Figure 6

U. S. Nuclear Regulatory Commission Enclosure 3F1 009-05 Page 8 of 46 B3.130 Steam GeneratorNozzle-to-Head Welds: B3.2. I and B3.2.4 These welds are the steam generatorinlet nozzle-to-head welds (upper head) for each Once-Through Steam Generator(OTSG) RCSG-1A and RCSG-1B. There is one inlet nozzle per OTSG. The steam generator upper head material is SA-508 64 Class 1 carbon steel and the inlet nozzle material is SA-533 Grade B carbon steel. Welds B3.2.1 and B3.2.4 have a diameter of 179.54 inches and a wall thickness of 9.00 inches.

During the ultrasonic examination of these welds, less than 90% coverage of the required examination volume was obtained. The percentage of coverage reported for each weld represents the aggregate coverage from all scans performed on the weld and adjacent base material (steam generator upper head). The examination coverage was based on the aggregatefrom each scan as follows:

  • Manual scans of the weld volume from the steam generatorhead side: 350, 45°, and 600 shear wave scans perpendicularand parallel to the weld in one axial direction and two circumferential directions and 0° longitudinal wave.

The actual material,coverage amount, and component configurations are as follows:

B3.2.1 CLAD CARBON STEEL 46% Steam Generator Nozzle To Head Weld B3.2.4 CLAD CARBON STEEL 46% Steam Generator Nozzle To Head Weld Manual scans were performed using qualified pulse-echo ultrasonic instruments and hand-held transducers, as specified in the Progress Energy ultrasonic examination procedures.

The CR-3 Inservice Inspection Plan allows the use of Code Case N-460, which requires greater than 90% volumetric coverage of examination volume A-B-C-D-E-F-G-H-I.

Therefore, the available coverage will not meet the acceptance criteria of this Code Case. The area not examined for the steam generatorinlet nozzle-to-head welds are shown in Figure 7.

There were no recordable indicationsfound during the inspection of these welds.

The steam generator nozzle-to-vessel head welds are accessible only from the head side, based on the designed nozzle configuration. The proximity of the nozzle radius prevented examination coverage from the nozzle side. In order to scan all of the required volume for these welds, the inlet nozzle would have to be redesigned to allow scanning from both sides of the weld, which is impractical.

Radiography, as an alternative, is not feasible because access is not readily available for film placement and the background radiationfrom the steam generatorupper tube sheet would severely impact the quality of the radiograph. IWB-2500, Table IWB-2500-1, Examination Category B-P System Leakage Tests and VT-2 visual examinations performed each refueling outage provide adequate assurance of pressure boundary integrity. No alternative examinations or advanced technologies were considered capable of maximizing ASME code coverage further for the weld during the current

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 9 of 46 inspection interval.

B3. 130 Steam GeneratorNozzle-to-Head Welds: B3.2.2, B3.2.3, B3.2.5 and B3.2.6 These welds are the steam generatoroutlet nozzle-to-head welds (lower head) for each OTSG, RCSG-1A and RCSG-1B. There are two welds per OTSG. The steam generatorlower head material is SA-508 64, Class 1 carbon steel and the outlet nozzle materialis SA-533 Grade B carbon steel.

During the ultrasonic examination of this weld, less than 90% coverage of the required examination volume was obtained. The percentage of coverage reported for each weld represents the aggregate coverage from all scans performed on the weld and adjacent base material (steam generatorlower head). The examination coverage was based on the aggregate from each scan as follows:

  • Manual scans of the weld volume from the steam generatorhead side: 45° and 60° shear wave scans perpendicularand parallel to the weld in one axial direction and two circumferential directions and 0° longitudinalwave.

The actual material, coverage amount, and component configurationsare as follows:

B3.2.2 CLAD CARBON STEEL 63% Steam Generator Nozzle-to-Head Weld B3.2.3 CLAD CARBON STEEL 50% Steam Generator Nozzle-to-Head Weld B3.2.5 CLAD CARBON STEEL 63% Steam Generator Nozzle-to-Head Weld B3.2.6 CLAD CARBON STEEL 49% Steam Generator Nozzle-to-Head Weld Manual scans were performed using qualified pulse-echo ultrasonic instruments and hand-held transducers, as specified in the Progress Energy ultrasonic examination procedures.

The CR-3 Inservice Inspection Plan allows the use of Code Case N-460, which requires greater than 90% volumetric coverage of examination volume A-B-C-D-E-F-G-H-I (Figure 9). Therefore, the available coverage will not meet the acceptance criteriaof this Code Case.

There were no recordableindicationsfound during the inspection of these welds.

These welds are obstructed by the OTSG support skirt (Figures 9 and 10), which is welded to the OTSG 3600. In order to scan all of the required volume for this weld, the outlet nozzle would have to be redesigned to allow scanning from both sides of the weld, which is impractical.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 10 of 46 Radiography as an alternative is not feasible because access is not readily available for film placement and the background radiationfrom the steam generator upper tube sheet would severely impact the quality of the radiograph. IWB-2500, Table IWB-2500-1, Examination Category B-P System Leakage Tests and VT-2 visual examinations performed each refueling outage provide adequate assurance of pressure boundary integrity. No alternative examinations or advanced technologies were considered capable of maximizing ASME code coverage further for the weld during the current inspection interval.

B3.140 Steam Generator Nozzle Inside Radius Welds: B3.2. 1.1, B3.2.2. 1, B3.2.3. 1, B3.2.4. 1, B3.2.5.1 and B3.2.6.1 The limitations discussed in the nozzle-to-shell welds are also applicable to the nozzle innerradius examinations. During the ultrasonic examination of this weld, less than 90%

coverage of the required examination volume was obtained. The percentage of coverage reported for each weld represents the aggregate coverage from all scans performed on the weld and adjacent base material (OTSG head). The examination coverage was based on the aggregatefrom each scan as follows:

" Manual scans of the base material from the head side: 450 and 600 shear wave scans perpendicular and parallel to the weld in one axial direction and two circumferentialdirections and 00 longitudinalwave.

  • Manual scans of the weld volume from the head side: 450 and 600 shear wave scans perpendicularand parallel to the weld in one axial direction and two circumferential directions and 0' longitudinalwave.

The actualmaterial, coverage amount, and component configurationsare as follows:

B3.2.1.1 CLAD CARBON 61% Nozzle Inner Radius STEEL B3.2.2.1 CLAD CARBON 48% Nozzle Inner Radius STEEL B3.2.3.1 CLAD CARBON 43% Nozzle Inner Radius STEEL B3.2.4.1 CLAD CARBON 61% Nozzle Inner Radius STEEL B3.2.5.1 CLAD CARBON 48% Nozzle Inner Radius STEEL B3.2.6.1 CLAD CARBON 43% Nozzle Inner Radius STEEL Manual scans were performed using qualified pulse-echo ultrasonic instruments and hand-held transducers, as specified in the Progress Energy ultrasonic examination procedures.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 11 of 46 The CR-3 Inservice Inspection Plan allows the use of Code Case N-460, which requires greater than 90% volumetric coverage of examination volume M-N-O-P (Figures 7, 8 and 9). Therefore, the available coverage will not meet the acceptance criteria of this Code Case.

There were no recordable indications found during the inspection of these nozzle inner radii.

The steam generatornozzle inside radii are accessible only from the head side, based on the designed nozzle configuration. The proximity of the nozzle outer radius prevented examination coverage from the nozzle side. In order to scan all of the required volume for this weld, the OTSG nozzles would have to be redesigned to allow scanning from both sides of the weld, which is impractical.

Radiography, as an alternative, is not feasible because access is not available for film placement. IWB-2500, Table IWB-2500-1, Examination Category B-P System Leakage Tests and VT-2 visual examinations performed each refueling outage provide adequate assurance of pressure boundary integrity. No alternative examinations or advanced technologies were considered capable of maximizing ASME code coverage further for the weld during the current inspection interval.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 12 of 46 Nozzle Bore Steam Generator Inlet Nozzle Welds B3.2-1 and B3.2.1.1 B3.2.4 and B3.2.4.1 Area Not Examined 45 D

Weld~

E. -_ *60 Figure 7

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 13 of 46 Steam Generator Inlet Nozzle Inner Radius Examinations Welds B3.2.1.1 and B3.2.4.1 Area 46 Weld Figure 8 The area not examined is at the upper section of the box outlined by M-N-O-P.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 14 of 46 Steam Generator Outlet Nozzle B3.130 Welds B3.2.2 83.2.3 B3.2.5 B3.2.6 B3.140 Welds 83.2.2.1 B3.2.3.1 B3.2.5.1 B3.2.6.1 OTSG Lower OTSG Support Skirt Head

& 60o -C Area Not Examined

/

/,

/

7 Area Not Examined OTSG Outlet Nozzle Figure 9

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 15 of 46 OTSG Support Skirt Figure 10 The above figure details a side view of the nozzle, Steam Generatorand Support Skirt configuration. The Support Skirt wraps around the Steam Generator entirely with an opening for the Outlet Nozzle. The limitation is only on the upper portion of the nozzle as shown in gray.

Welds B3.2.2, B3.2.3, B3.2.5, B3.2.6 Welds B3.2.2.1, B3.2.3.1, B3.2.5.1, B3.2.6.1 2.2 Request for Relief 09-001-11, Part B, Examination Category B-J, Items B9.21, Pressure Retaininq Circumferential Welds in Piping Less than 4 NPS, and Part D, Examination Category R-A, Item R1.20, Risk Informed Piping Examinations The licensee has not provided sufficient information to support the bases for impracticality for each of the Examination Category B-J and R-A piping welds in RR 09-

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 16 of 46 001-11. Only general statements regarding geometries and access restrictions are provided, such as the following:

The ultrasonic examination of the above pipe welds was limited in coverage due to component configuration and/or immovable physical barriers. It is not possible to perform the ultrasonic examination from both sides of the weld since one side of the weld was not suitable for scanning based on the scanning surface angle of the component.

2.2.1 Provide further information to support the basis for each limited Examination Category B-J and R-A weld, and therefore, demonstrate impracticality. This information should include detailed descriptions with sufficient explanation for the clarification. It may refer to the enclosed lay-out or cross-sectional drawings/sketches to enable the staff to fully understand the causes of ultrasonic scan limitations and their impact on examination volume coverage.

2.2.2 Describe the ultrasonic techniques (shear wave and angles, and refracted L-wave and angles) applied to maximize coverage when examining from a single side of these welds.

2.2.3 In addition to the bases for impracticality, state whether any outside diameter surface feature, such as weld crown, diametrical weld shrinkage, or surface roughness conditions caused limited volumetric coverage during the subject piping weld examinations. Discuss the efforts that were used to correct these conditions.

2.2.4 Confirm that ASME Code-Required surface examinations were completed for the subject welds, as applicable.

RESPONSE

R1.20 CircumferentialPipe Welds, B4.5. 108.17 (RI-ISI):

The ultrasonic examination of the above pipe weld was limited in coverage due to component configuration, elbow-to-valve (Figure 11). It is not possible to perform the ultrasonic examination from both sides of the weld since the valve prohibits scanning from the down-stream side of the weld based on the scanning surface angle of the component. Additionally, the intrados of the elbow restricts scanning from approximately 1.5 inches through 4.5 inches circumferentially; therefore, the welds only received a single sided examination resulting in less than 90% coverage of the required examination volume, with an actual 50% coverage for the subject weld. The examination coverage was based on the aggregate from manual scans of the pipe side:

450 and 700 shear wave scans perpendicular and parallel to the weld in one axial direction and two circumferentialdirections.

A single sided examination for a stainless steel weld can only be credited for 50% of the Code Required Volume. [10 CFR 50.55a(b)(2)(xv)(A)(2): Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds or dissimilar metal welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 17 of 46 opposite side of the weld. Dissimilar metal weld qualifications must be demonstrated from the austenitic side of the weld and may be used to perform examinations from either side of the weld.]

Manual scans were performed using qualified pulse-echo ultrasonic instruments and hand-held transducers, as specified in the Progress Energy ultrasonic examination procedures.

The Non-Destructive Examination (NDE) techniques and procedures used incorporate examination techniques qualified under Appendix VIII of the ASME Section XI Code by the Performance Demonstration Initiative (PDI) for examination of the pipe welds. The entire volume of these welds was interrogated ultrasonically; however, the qualified technique is only qualified to detect flaws on the examination side of the weld. No indicationswere identified for these examinations.

Therefore, since the welds only received a single-sided examination, the resulting code coverage credit in less than 90% coverage of the required examination volume. The limitations were not due to excessive weld crown, diametricalweld shrinkage, or surface roughness conditions. A surface examination was not required for this weld as described in Code Case N-578, Risked Informed ISI.

Weld B4.5.108.17 (RI-ISI)

Valve Al 40 .9Lo .93 1,'46s',.

Figure 11 Retraction for B9.21 CircumferentialPipe Welds As part of the initialRequest for Relief, CR-3 submitted the welds in Category B-J, B9.21 for relief from the ASME Section XI requirements. The Code relief request was only for the volumetric examinations, which were performed to satisfy a CR-3 augmented program, and not ASME Section XI Code requirements.

ASME Section X1, 1989 Edition, Category B-J, Item B9.21, only requires a surface examination for those components. Additionally, 10 CFR 50.55a(g)(4)(iii) states that, "Licensees may, but are not required to, perform the surface examinations of High Pressure Safety Injection Systems specified in Table IWB-2500-1, Examination Category B-J, Item Numbers B9.20, B9.21, and B9.22."

The CR-3 Third Interval ISI Program, Section 6.2.2 for Augmented Programs,included the discussion for B-J, B9.21 welds.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 18 of 46 6.2.2 Volumetric Examination of Class 1 Piping, ASME Examination Category B-J, < 4 inches NPS Ž> 2 inches NPS in HPI system The 1989 edition of ASME Code, Section X1 for Category B-J, requires only surface examination on Class 1 piping welds less than 4 inches NPS. Class 2 HPI piping _ 2 inches NPS and _54 inches NPS receive both a surface and volumetric examination. FPC recognizes the importance of conducting volumetric examinations on austenitic stainless steel piping in PWR High Pressure Injection Systems.

Therefore, volumetric examination, in addition to the Code Required surface examination, will be performed on all Class I HPI system welds selected for examination under Category B-J.

The request for relief from the ASME Code requirements (B9.21, Less than 4 inches NPS CircumferentialPipe Welds) is retractedfor the following welds: B4. 5.62, B4. 5.71.3, B4.5.71.4, B4.5.79.4, B4.5.79.5, B4.5.84.2, B4.5.84.4, B4.5.151, and B4.5.165.

The Code Required surface examination was performed for the above welds. No recordable indicationswere noted.

2.3 Request for Relief 09-001-11, Part C, Examination Category B-M-1, Item B12.40, Valve Body Welds NPS 4 or Larger 2.3.1 The licensee has not provided sufficient information to enable the staff to determine whether the subject valve body weld is inaccessible for volumetric examination. The licensee stated that the ultrasonic examination of the DHV-3 valve body weld would require disassembly of the valve to access the weld, however the drawings submitted in Attachment A of Enclosure 1 do not adequately display this weld, nor fully show access limitations. In addition, the provided drawings are unclear and difficult to read. Please submit clear diagrams/sketches of the valve and location of the subject weld, showing access restrictions that make disassembly of the valve necessary for volumetric examination.

RESPONSE

The B-M-1 weld for valve DHV-3 is a limited single sided examination that is also inaccessible for volumetric examination without valve disassembly. Figure 12 shows the canopy-to-valve body configuration and weld without the yoke in place. The valve actuator support i.e., yoke, encompass the entire DHV-3 canopy-to-valve body weld (Figures 12 and 14). The valve actuatoris seal welded to a mechanical clamp which is attached to the valve body (Figures 13 and 14). The examination of the B-M-1 after the yoke is removed would still result in a request for relief from the Code requirements since the examination of the weld is a single sided examination and the Code Required Volume coverage would be less than 90%.

DHV-3 is the first valve downstream of the reactoron the decay heat removal line and is in a high radiation area even when the reactor is de-fueled. This is the only B-M-1 category weld at CR-3. Removal of the yoke would involve extensive man-hours to

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 19 of 46 remove the yoke and its welded clamp, inspect the canopy weld, reinstall the yoke and re-weld the yoke to the clamp. The estimated time spent on the valve for removal, inspection, re-installation and post-maintenance testing is 100 man-hours, which would result in a total radiationexposure of IOR.

The B-M-1 weld only received a single sided examination during the pre-service examination resulting in 75% calculated coverage, which is less than 90% coverage of the required examination volume. The examination coverage was based on the aggregate from manual scans on the canopy side: 450 and 700 shear wave scans perpendicular and parallel to the weld in one axial direction and two circumferential directions. The ultrasonicexamination of the valve body weld for DHV-3 was limited in coverage due to component configuration, canopy-to-valve. It is not possible to perform the ultrasonic examination from both sides of the weld since the cast stainless valve material and the scanning surface angle are not conducive to scanning from the valve body side of the component.

A single sided examination for a stainless steel weld can only be credited for 50% of the Code Required Volume. [10 CFR 50.55a(b)(2)(xv)(A)(2): Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds or dissimilarmetal welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld.]

Manual scans were performed during the pre-service examinations using qualified pulse-echo ultrasonic instruments and hand-held transducers, as specified in the Progress Energy ultrasonic examination procedures.

The Non-Destructive Examination (NDE) techniques and procedures used incorporate examination techniques qualified under Appendix VIII of the ASME Section XI Code by the Performance Demonstration Initiative (PDI) for examination of the pipe welds. The entire volume of this weld was interrogated ultrasonically; however, the qualified technique is only qualified to detect flaws on the examination side of the weld. No indications were identified for these examinations. The limitations were not due to excessive weld crown, diametricalweld shrinkage or surface roughness conditions.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 20 of 46 Cut-away view of the canopy on top of DHV-3 Canopy to valve body weld

-dALV DOODY Figure 12 This figure shows the canopy to valve body configuration without the yoke in place.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 21 of 46 Cut-away view of the canopy on top of DHV-3 with the yoke installed Figure 13

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 22 of 46 Cut-away view of the yoke clamp assembly Valve Actuator Support (Yoke)

Valve Body Weld Figure 14 This detail shows the where the clamp is welded to the yoke of DHV-3

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 23 of 46 Photographof DHV-3 configuration

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 24 of 46 2.4 Request for Relief 09-002-11, Parts A and B, Examination Cate-gory C-A and C-B, Items C1.10 and C2.21, Pressure Retaining Welds in Pressure Vessels and Nozzle-to-Shell Welds 2.4.1 The coverage sketches included in the licensee's submittal do not contain dimensions and are not adequate to demonstrate impracticality for the subject volumetric examinations. Please clearly describe ASME Code Required Volumes and areas of completed coverage (including dimensions) that for clarification refers to the cross-sectional sketches. Summarize scanning directions and techniques used. In addition, list the base and weld materials, if not already provided. As applicable, describe NDE equipment (ultrasonic scanning apparatus), details of the listed obstructions (size, shape, proximity to the weld, etc.) to demonstrate accessibility limitations, and discuss whether alternative methods or advanced technologies could be employed to maximize ASME Code coverage.

2.4.2 The description associated with Examination Categories C-A and C-B list the component type (shell-to-flange weld, nozzle-to-shell weld), however, it is not clear what the actual components are, or what systems are involved. Please state the component(s) for the subject welds and to what system these components are assigned.

2.4.3 Also, identify whether 100 percent of the ASME Code Required surface examinations were completed, as applicable, and if any indications were detected.

RESPONSE

C1. 10 Shell to Flange Weld, Summary Number C1. 1.5:

The Decay Heat Cooler DHHE-1A is part of the Decay Heat Removal System. The examination was performed from the shell side of the heat exchanger. The base and weld materialis stainless steel, SA-240, TP 304 with a nominal thickness of 1.25 inches.

The flange is also SA-240, TP-304 stainless steel. The examination limitation is solely based on the configuration of the weld joint, shell-to-flange (Figure 15 for general location of C1. 1.5) with a total coverage amount of 42.5% (Figure 16 for coverage plot).

The examination can only be conducted from the shell side with perpendicular and parallelscans.

Manual scans were performed using qualified pulse-echo ultrasonic instruments and hand-held transducers, as specified in the Progress Energy ultrasonic examination procedures.

The NDE techniques and procedures used incorporate examination techniques qualified in accordancewith the ASME Section X1 Code for examination of vessel welds less than 2 inches. The qualified technique is only qualified to detect flaws on the examination side of the weld.

Ultrasonic examination of the subject weld was limited in coverage due to component configuration and/or immovable physical barriers. It is not possible to perform a 100 percent ultrasonic examination from both sides of the weld since one side of the weld was not suitable for scanning based on the scanning surface angle of the component (flange). A single-sided examination for a stainless steel weld can only be credited for

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 25 of 46 50% of the Code Required Volume, as detailed in 10 CFR 50.55a(b)(2)(xv)(A)(2),

(Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds or dissimilarmetal welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld.). No indications were identified for this examination and a surface examination is not requiredfor this category/item number.

Therefore, since the welds only received a single-sided examination, the resulting code coverage credit in less than 90% coverage of the required examination volume. The limitations were not due to excessive weld crown, diametricalweld shrinkage, or surface roughness conditions.

Radiography as an alternative is not feasible because access is not available for film placement. IWC-2500, Table IWC-2500-1, Examination Category C-H System Leakage Tests and VT-2 visual examinationsperformed each inspection period provide adequate assurance of pressure boundary integrity. No alternative examinations or advanced technologies were considered capable of maximizing ASME code coverage further for the weld during the current inspection interval.

The surface examination was completed and no recordableindications were noted.

C2.21 Nozzle to Shell Weld, Summary Number C 1.2.3: DHHE-1A Inlet The NDE techniques and procedures used incorporateexamination techniques qualified in accordance with the ASME Section X1 Code for examination of vessel welds less than 2 inches. The entire volume of this weld (Figure 15 for weld location) was interrogated ultrasonically; however, the qualified technique is only qualified to detect flaws on the examination side of the weld. No indicationswere identified for these examinations.

Manual scans were performed using qualified pulse-echo ultrasonic instruments and hand-held transducers, as specified in the Progress Energy ultrasonic examination procedures.

The NDE techniques and procedures used incorporateexamination techniques qualified in accordance with the ASME Section XI Code for examination of vessel welds less than 2 inches. The qualified technique is only qualified to detect flaws on the examination side of the weld.

A single-sided examination for a stainless steel weld can only be credited for 50% of the Code Required Volume, as detailed in 10 CFR 50.55a(b)(2)(xv)(A)(2) (Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds or dissimilarmetal welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld.).

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 26 of 46 Radiography as an alternative is not feasible because access is not available for film placement. IWC-2500, Table IWC-2500-1, Examination Category C-H System Leakage Tests and VT-2 visual examinations performed each inspection period provide adequate assurance of pressure boundary integrity. No alternative examinations or advanced technologies were considered capable of maximizing ASME code coverage further for the weld during the current inspection interval.

Ultrasonic examination of the subject weld was limited in coverage due to component configuration and/or immovable physical barriers. It is not possible to perform a 100 percent ultrasonic examination from both sides of the weld since scanning was performed on the shell side only (Figure 17). The scanning surface of the pipe is perpendicularto the shell surface which prohibits the ultrasonic wave entering the Code required examination volume at an angle that will integrate the weld volume for in-service flaws. Therefore, since the welds only received a single-sided examination, the resulting code coverage credit is less than 90% coverage of the required examination volume. The limitations were not due to excessive weld crown, diametrical weld shrinkage, or surface roughness conditions.

The surface examination was completed and no recordableindications were noted.

General Location of Weld C1. 1.5 and C1.2.3 INLET NOZZLE TO SHELL I

I rf-I i--- SHELL TO FLANGE I II DECAY HEAT COOLER (DHHE-1A)

Figure 15

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 27 of 46 Cross-Sectional View of Weld C1. 1.5 Weld C1.1.5, DHHE-1A (Decay Heat Cooler)

A < 45° 60°

-4 Direction of Scan Figure 16

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 28 of 46 Cross-SectionalView of Weld C1. 2.3 Direction of Scan Figure 17

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 29 of 46 2.5 Request for Relief 09-002-11, Part C, Examination Category C-F-i, Items C5.11, C5.21, and Augmented 7.1, Pressure Retaining Circumferential Welds in Austenitic Stainless Steel of High Alloy Piping. and Part D. Examination Cateory C-F-2, Items C5.51, Pressure Retaining Circumferential Welds in Carbon or Low Alloy Steel The licensee has not provided sufficient information to support the bases for impracticality for each of the Examination Category C-F-1 and C-F-2 piping welds in RR 09-002-11. Only general statements regarding geometries and access restrictions are provided, such as the following:

The ultrasonic examination of the above pipe welds was limited in coverage due to component configuration and/or immovable physical barriers. It is not possible to perform the ultrasonic examination from both sides of the weld since one side of the weld was not suitable for scanning based on the scanning surface angle of the component.

2.5.1 Provide further information to support the basis for each limited Examination Category C-F-1 and C-F-2 weld, and therefore, demonstrate impracticality. This information should include detailed descriptions (with sufficient explanation which may refer to the lay-out or cross-sectional drawings/sketches) to enable the staff to fully understand the causes of ultrasonic scan limitations and their impact on examination volume coverage.

2.5.2 Describe the ultrasonic techniques (shear wave and angles, and refracted L-wave and angles) applied to maximize coverage when examining from a single side of these welds.

2.5.3 In addition to the bases for impracticality, state whether any outside diameter surface feature, such as weld crown, diametrical weld shrinkage, or surface roughness conditions caused limited volumetric coverage during the subject piping weld examinations. Discuss the efforts that were used to correct these conditions.

2.5.4 Confirm that ASME Code Required surface examinations were completed for the subject welds, as applicable.

RESPONSE

Category C-F-I, Item C5. 11 and C5.21 Pressure Retaining Circumferential Welds in Austenitic Stainless Steel of High Alloy Piping and Examination Category C-F-2, Item C5.51, Pressure Retaining Circumferential Welds in Carbon or Low Alloy Steel For the remainderof the C-F-i, Items C5. 11 and C5.21, and Examination Category C-F-2, Item C5.51, the ultrasonic examinations were limited in coverage due to component configuration, (valve-to-elbow, valve-to-pipe, flange-to-pipe, flange-to-reducer, or tee-to-pipe). It is not possible to perform the ultrasonicexamination from both sides of the weld since the configuration, scanning surface angle, or materialproperties,prohibitscanning from the appurtenanceside of the weld.

Tee and valve materialis cast stainless steel which is not suitable for scanning and the inspection techniques are not qualified in accordance with Appendix VIII. The examination coverage was based on the aggregate from manual scans of the pipe or

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 30 of 46 elbow side: 45° and 700 shear wave scans perpendicularand parallel to the weld in one axial direction and two circumferential directions. For welds with a nominal thickness less than 0.500 inches, a 700 refracted longitudinal wave transducerwas used to detect flaws parallelto the weld. Therefore, the welds only received a single-sided examination resulting in code coverage credit less than 90% coverage of the required examination volume. The actual coverage was 50% for single sided components (Figures 18, 19 and 20).

Regarding Examination Category C-F-2, Item C5.51, the ultrasonic examinations were limited in coverage due to component configuration, (Sweep-o-let to Flange). The welds were examined from both sides using the minimum and maximum scanning angles. The configuration limits access of the transducer for scanning. The examination coverage was based on the aggregate from manual scans of both sides: 450 and 70° shear wave scans perpendicular and parallel to the weld in two axial directions and two circumferentialdirections.

Manual scans were performed using qualified pulse-echo ultrasonic instruments and hand-held transducers, as specified in the Progress Energy ultrasonic examination procedures.

The NDE techniques and procedures used incorporate examination techniques qualified under Appendix VIII of the ASME Section X1 Code by the PDI for examination of the pipe welds. The Code Required Volume of these welds was interrogatedultrasonicallyto the extent possible. No indicationswere identified for these examinations.

The limitations were not due to excessive weld crown, diametrical weld shrinkage, or surface roughness conditions.

CR-3 invoked Code Case N-663, Alternative Requirements for Classes I and 2 Surface Examinations, for the Third Ten-Year Inspection Interval. The surface examinations are not requiredfor Item Number C5. 11 and C5.21, as describedin Code Case N-663.

Weld C2.1.1060

(

L 45' 70*

eL r3 0 L')

Figure 18

U. S. Nuclear Regulatory Commission Enclosure 3F17009-05 Page 31 of 46 Weld C2.1.507 Cb 70*

Area Not Credited for Coverage Figure 19 Weld C2.1.1084 Valve Figure 20 The majority of the C-F-i welds do not have a specific Code Required Volume (CRV) sketch. The CRV sketch were not a Code requirement and therefore were not mandatory. The following sketches are typical for the reported configurations (Figures 21 and 22).

Typical Coverage Plot for Pipe-to-Valve, Flange-to-Pipe,and Tee-to-Pipe

'14ý Pipe/Elbow/Reducer * -'*,* -- 1* __ Valve/Tee (Not to Scale)

Area Not Credited Figure 21

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 32 of 46 Typical Profile for C-F-2, C5.51 Welds C2.1.118, C2.1.221, and C2.1.290 (Sweep-o-let-to-Flange)

SwLk.3A- o- L-r-FLA&3 L.:

tL

&"EA liq L.

iaL~ Lit 4Th9 .1SIN 7A V," IRZ AfELA MJOT L"EIWSO 1.1S .04o'M,t1 liJt! ,'74L .13, .1n RAEd.jrý,iTS eADOFILE TAC,4j (Q_

Figure 22 Relief Request Retraction: AUG7.1 and C-F-1 Pressure Retaining Circumferential Welds in Austenitic Stainless Steel of Hiah Alloy Pinina (Pre-serviceExaminations)

As part of the initial Request for Relief, CR-3 submitted the welds in Category C-F-I, Item C5.21, and Augmented 7.1 for relief from the ASME Section X1 requirements.

For Category AUG 7.1, the Code reliefrequest was only for the volumetric examinations, which were performed to satisfy a CR-3 augmented program and not ASME Section XI Code requirements. The request relief from the ASME Code requirements (AUG7.1) is retracted for the following welds: C2.1.190, C2.1.192A, C2.1.605, C2.1.625, and X121.020.

A portion of the welds listed for the C-F-i, Item C5.21 were part of the High Pressure Injection System plant modification installed during the Third Ten-Year Interval. The welds were inspected prior to being placed in-service; however, they are not components selected for subsequent in-service examination and are not credited for meeting the C-F-1 percentage examining 7.5% of the component population for the

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 33 of 46 interval. Therefore, request for relief from the ASME Code requirements (Item C5.21) is retracted for the following welds: C2.1.2136, C2.1.2137, C2.1.2162, C2.1.2164, C2.1.2169, C2.1.2173, C2.1.2174, C2.1.2175, C2.1.2176, C2.1.2199, C2.1.2200, C2.1.2202, C2. 1.2238, and C2.1.2240.

The Code required examinations for the above welds were performed for pre-service; no recordable indicationswere noted.

Relief Request Retraction: Category C-F-I, Item C5.21, Pressure Retaining Circumferential Welds in Austenitic Stainless Steel of High Alloy Piping Code coverage for weld C2.1.1070 was reported in error as having Code Coverage less than 90%. A review of the documentation indicated that the Code Coverage was 96.63%. The configuration is a pipe to pipe with a 1.0" diameter vent line limiting a portion of the scanning area. The Code coverage sketch was incorrectly calculated which resulted reporting the coverage as 86.5%.

Relief Request Retraction: Category C-F-2, Item C5.51, Pressure Retaining Circumferential Welds in FerriticSteel Piping Code coverage for welds C2.1.121 and C2. 1.8 were reported in error as having Code Coverage less than 90%. A review of the documentation indicated that the Code Coverage was 98.6% and 100%, respectively. The configuration is a pipe to valve and per 10 CFR 50.55a(b)(2)(xv)(A)(2), full coverage credit may be claimed from a single side for ferritic welds where examination from both sides is not possible.

2.6 Request for Relief 09-003-11, Part A, Examination Category B-A, Items B1.11 and B1.12, Reactor Pressure Vessel (RPV) Circumferential and Longitudinal Shell Welds 2.6.1 In Attachment A and B of Enclosure 3, the licensee has included multiple sketches and tables with volumetric coverage percentages at different angle beam orientations and arrangements. However, the sketches included are of poor quality and generally unclear, and do not adequately demonstrate impracticality and volumetric coverage(s) achieved. Please clearly explain the limiting conditions and completed percentages of the ASME Code volumes examined. Include in your response the ultrasonic angles applied and include dimensions and scanning directions. Please submit and refer to the cross-sectional drawings, if needed for providing the above clarification. Also, discuss whether alternative methods or advanced technologies could be employed to maximize ASME Code coverage.

2.6.2 Please report whether any indications were detected for the third ten-year IS[

examination for the RPV nozzle belt intermediate shell Weld (B13.2.3).

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 34 of 46

RESPONSE

Reactor Pressure Vessel Weld Lay-Out FLANGE

{U K U(j UPPER NOZZLE BELT

- 01.23.1A Ia INLE & OUTLE

-r W02 81I.1,4 LOWER NOZZLE BELT UPPER SHELL

" W08' B1.1.5 LOV1JER SHELL LOWER KMFD -

I WELD WIO - NO COVERAGE DUE TO OBSTRUCTIONS WITH CORE LUGS ANO) FLOW STABILIZERS Figure 23

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 35 of 46 Component B 1. 2.1, Reactor Pressure Vessel Lower Shell-to- Transition Piece Weld Weld B1.2.1 (Figures 23 and 24 for weld location) was scanned using 450 and 700 longitudinalwaves for the inner 15% and 450 longitudinaland shear waves for the outer 85% of the weld volume in two parallel and two perpendicular directions to the weld.

The total coverage of the Code Required Volume was 46% and was calculated using an aggregate of all scans.

The weld is limited by flow stabilizers and core positioninglugs (Figures 24 through 28 for positioning of the core lugs and stabilizers in relation to the weld). The scan limitation is a physical limitation which would also impact alternative methods or advanced technologies. Radiography as an alternative is not feasible because access is not available for film placement. No alternative examinations or advanced technologies were considered capable of maximizing ASME code coverage further for the weld during the current inspection interval.

Complete redesign would be needed to provide enough clearance so the welds could be examined. Such a re-design is impracticalfor an installedreactorvessel.

-l jCore Positioning Lugs W eld B1.2.1 - .-- '. i Incore Instrumentation Figure 24

U. S. Nuclear Regulatory Commission Enclosure 3F 1009-05 Page 36 of 46 CMi LUG Scanning from the fllOw stabilizer side.

FLoo STAIJIR-,, I - Weld 81 21 CTos-setional view Figure 25 Weld B1.2.1 Plan View (looking down)

Flow Stabilizer Scanning Scanning was performed between the Core Lugs and the flow stabilizers. The cross hatched area ore Lug (typ.)

shows only the area scanned.

(typ)

Figure 26

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 37 of 46 (Scanning from the I

-Weld B1.2.1 FLOW STABUZER -..

Figure 27 Weld B1.2.1 Plan View (looking down)

Area Scanned (12 Locations)

Scanning from the Core Lug Side Scanning was performed between the core lugs. The cross hatched area shows only the areas scanned.

Figure 28

U. S. Nuclear Regulatory Commission Enclosure 3F 1009-05 Page 38 of 46 Component B 1.2.2, Reactor Vessel Transition Piece to Bottom Head Weld Weld B1.2.2 (Figures23 and 29 for weld location) is the reactor vessel transition-piece-to-lower-head-weld. The weld is limited by flow stabilizers and incore instrumentation nozzles (Figure 29). Radiographyas an alternative is not feasible because access is not available for film placement. No alternative examinations or advanced technologies were consideredcapable of maximizing ASME code coverage further for the weld during the current inspection interval.

Consideration was given to examining the weld from the vessel outside diameter.

Access to the weld from the vessel exterior presents Safety and ALARA hazards.

Access to the weld to perform the inspection from the outside using a Manual Contact Ultrasonic method would require concrete removal in the cavity and to suspend an inspection team between the exterior of the vessel and inside the shield wall by harnesses.

Core Positioning Lugs

-- ..--t-".-,,

---'- -.. -. i

'17.

- ,1.2.2"Weld Incore Instrumentation Figure 29 Component B 1.2.3. Reactor Pressure Vessel Nozzle Belt Intermediate Weld Weld B1.2.3 (Figure 23 for weld location) was scanned using 450 and 700 longitudinal waves for the inner 15% and 450 longitudinal and shear waves for the outer 85% of the weld volume (Figure 30) in two parallel and two perpendicular directions. The total coverage was calculated using an aggregate of all scans. Refer to Figures 30, 31 and 32 for cross-sectional view and plan views of axial and circumferential scan coverages.

During the Third Ten-Year Interval examination, a total of 90 percent of the weld was examined. The remainingten percent was not accessible due to scanning interferences

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 39 of 46 with the inlet nozzle openings and the outlet nozzle boss extensions (Figures31, 32, 35, 36, and 37 for representation of nozzle boss limitations). The scan limitation is a physical limitation which would also impact alternative methods or advanced technologies. Radiography as an alternative is not feasible because access is not available for film placement. No alternative examinations or advanced technologies were considered capable of maximizing ASME code coverage further for the weld during the current inspection interval.

There were no recordable indications noted for weld B1.2.3. The circumferential scan was limited by the nozzle configuration for the circumferential scan only.

Complete redesign and replacement of the nozzles would be needed to provide enough clearance so the welds could be examined. Such a re-design or replacement is impracticalfor an installed reactorvessel.

Weld B1.2.3 Cross-sectional Vievv RPV OD RPV ID

'U Outer 05%

  • 1 T

Figure 30

U. S. Nuclear Regulatory Commission Enclosure 3FY1009-05 Page 40 of 46 Weld B1.2.3 Plan View of Coverage Figure 31 Axial scan coverage is detailed above

U. S. Nuclear Regulatory Commission Enclosure 3FY1009-05 Page 41 of 46 Figure 32 View looking down.

Solid areas are the limited scan areas. The limitations are due to nozzle outlets and nozzle bosses. For additionalnozzle boss configuration details refer to Figures 35, 36 and 37.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 42 of 46 Comoonents B1. 1.5 and B1. 1.6, RPV Long Seam The RPV Long Seam Welds, Welds BI. 1.5 and B1. 1.6, on the lower shell section are limited by the geometry of the Core PositioningLugs (Figures33 and 34). Welds B1.1.5 and B1. 1.6 were scanned using 450 and 70° longitudinal waves for the inner 15% and 450 longitudinal and shear waves for the outer 85% of the weld volume in two parallel and two perpendiculardirections. The total coverage of the Code Required Volume was 88.1% and was calculated using an aggregate of all scans. The scan limitation is a physical limitation which would also impact alternative methods or advanced technologies. Radiography as an alternative is not feasible because access is not available for film placement. No alternative examinations or advanced technologies were considered capable of maximizing ASME code coverage further for the weld during the current inspection interval. The core positioning lugs are approximately 24 inches long.

Complete redesign and replacement of the core positioning lugs would be needed to provide enough clearance so the welds could be examined. Such a re-design or replacement is impracticalfor an installedreactorvessel.

Reactor Vessel Roll-out 90° 0o 180*

Area Not Scanned Core Positioning Lugs Figure 33 The scan limitaitons are detailed by the solid areas shown above. The cross hatched areasrepresent the total scan area for the subject welds.

U. S. Nuclear Regulatory Commission Enclosure 3F17009-05 Page 43 of 46 Outer 85%

Area Not Scanned /

Inner 15%

- VVeld Atea L

I I Welds B 1 5and B 11 6 Plan'Viev4 (looking doorn) i Core Posivoning Lugs Figure 34 Solid color representsthe limited scan area 2.7 Request for Relief 09-003-11, Part B, Examination Category B-D, Item B3.90, RPV Nozzle-to-Vessel Welds 2.7.1 In Attachment B of Enclosure 3, the licensee has included several sketches and tables with volumetric coverage percentages at different angle beam orientations. However, the sketches included are of poor quality and generally unclear, and do not adequately demonstrate impracticality and volumetric coverage(s) achieved. Please clearly describe volume coverage for each of the ultrasonic angles applied, and include dimensions, materials for the base metal and weld, and scanning directions. Please submit and refer to the cross-sectional drawings, if needed for providing the above clarification. Also, discuss whether alternative methods or advanced technologies could be employed to maximize ASME Code coverage.

RESPONSE

Components B 1.4. 7A and B 1.4.8A. Reactor Pressure Vessel Outlet Nozzle to Shell Welds The Reactor Pressure Vessel Outlet Nozzle to Shell Welds, B 1.4.7A and B 1.4.8A, are limited by the geometry of the nozzles for the inner 15% examination from the inside diameter of the Reactor Pressure Vessel, only. The nozzle base metal and welds are carbon steel. The nozzles also have a stainless steel cladding on the inside diameter.

The outer 85% of the Code required volume was examined 100% from the bore of the nozzle. Welds B1.4.7A and B1.4.8A were scanned using 45° and 70° longitudinalwaves for the inner 15% and 150 longitudinaland 45°shearwaves for the outer 85% of the weld volume. The welds were examined in two radialand two circumferentialdirections. The total coverage of the Code Required Volume was 69.8% and was calculated using an aggregateof all scans.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 44 of 46 The boss extension limits the circumferential scan coverage (Figures 35, 36 and 37, bottom). However, 100% of the required weld volume and adjacent base material has received two axial angle beam scans from the nozzle bore. The scan limitation is a physical limitation which would also impact alternative methods or advanced technologies. Radiography as an alternative is not feasible because access is not available for film placement. No alternative examinations or advanced technologies were considered capable of maximizing ASME code coverage further for the weld during the current inspection interval.

Complete redesign of the nozzles would be needed to provide enough clearance so the welds could be examined. Such a re-design is impracticalfor an installedreactorvessel.

Design Detail of the Outlet Nozzles Figure 35 The nozzle boss is labeled as "E"above.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 45 of 46 Welds 81 .4.7A and 91.48A Plan View (90°/270°)

Outer 85% Inner 15%

Welds B134.7A and 81.418A Plan View (90°/270°)

Outer 85% 15%

Figure 36 The top view shows the weld coverage area, as detailed by cross hatch. The bottom view shows the area not covered due to the scanning limitation, caused by nozzle boss extension.

U. S. Nuclear Regulatory Commission Enclosure 3F1009-05 Page 46 of 46

(

Welds B1.4.7A and B1.4.8A I

Plan View (0°/180°)

Inner 15%

Outer 85%

Scanning Limitation Welds B1.4.7A and B1.4.8A Plan View (0°/1 80)

Inner 15%

Area Not Covered Figure 37 The top view shows the weld coverage area, as detailed by cross hatch. The bottom view shows the area not covered due to the scanning limitation, caused by nozzle boss extension.

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