BW090095, Submittal of Analytical Evaluation in Accordance with IWC-3125(b)
| ML092930134 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/09/2009 |
| From: | Shahkarami A Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BW090095 | |
| Download: ML092930134 (28) | |
Text
Exelkn.
Braidwood Station www.exeloncorp.com 35100 South Route 53, Suite 84 Nuclear Brac-eville, IL 60407-9619 1 OCFR50.55a October 9, 2009 BW090095 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Unit 1 Facility Operating License No. NPF-72 NRC Docket No. 50-456
Subject:
Submittal of Analytical Evaluation in Accordance with IWC-3125(b)
In accordance with the American Society of Mechanical Engineers (ASME) Code, Section Xl, 2001 Edition through 2003 Addenda, IWC-3125(b), Braidwood Station is submitting the analytical evaluation of indications identified on Braidwood Station, Unit 1 main steam system piping support welded attachments during the spring 2009 (Al R1 4) refuel outage.
During Section Xl surface examinations of Category C-C, Item C3.20 welded attachments, multiple linear indications were discovered in the lug attachments associated with constant support 1 MS07002C. As a result of the indications identified during this initial examination, additional examinations were performed in accordance with IWC-2430(a). During the initial sample expansion, indications were discovered in the lug attachments associated with snubber 1 MS06007S, prompting a second examination sample expansion of the remaining population in accordance with IWC-2430(b). One indication was discovered in a welded attachment on snubber 1 MS08007S under the second sample expansion.
As several of the indications exceeded the applicable acceptance standards of Table IWC-341 0-1, additional engineering evaluation to determine acceptability was required. This evaluation is contained in Attachment 1.
An additional finite element analysis evaluation of the welded attachments associated with snubber 1 MS06007S was performed to determine the normal stresses on the flaw plane of the linear indications, which is contained in Attachment 2. The intent of the finite element analysis is to show that lug stresses in the plane of the flaw are small due to operating loads.
The analytical evaluations provided in the attachments conclude that based on the location and orientation of the indications found and the magnitude and direction of the applied operating loads, these indications will remain stable and will not prevent the lugs from performing their intended function of providing weight support for the main steam riser pipes.
October 9, 2009 U. S. Nuclear Regulatory Commission Page 2 There are no new regulatory commitments contained in this letter.
If you have any questions or require additional information, please contact Mr. David Gullott, Regulatory Assurance Manager, at (815) 417-2800.
Respectfully, Amir Shahkarami Site Vice President Braidwood Station Attachments: 1)
M-1 MS07002C, Evaluation for MT Indications on Shear Lugs Westinghouse NDE Report #A1 R1 4-MT-001
- 2)
Lug Stress Calculation for 1 MS06007S cc:
Regional Administrator - NRC Region III (w/attachments)
NRC Senior Resident Inspector - Braidwood Station Illinois Emergency Management Agency - Division of Nuclear Safety
bcc: Illinois Emergency Management Agency - Division of Nuclear Safety Director - Licensing and Regulatory Affairs Regulatory Assurance Manager - Braidwood Station Manager, Licensing - Braidwood, Byron and LaSalle County Stations Braidwood Nuclear Licensing Administrator Exelon Document Control Desk Licensing Corporate Commitment Management Coordinator Braidwood Commitment Management Coordinator Marshal. David@nrc.gov
ATTACHMENT 1 Braidwood Station, Unit 1 M-1MS07002C, Evaluation for MT Indications on Shear Lugs Westinghouse NDE Report #A1R14-MT-001
Engineering Change Company Name :
EXELON GENERATION CO.,LLC EC Number Status/Date Facility Type/Sub-type:
0000374961 000 CLOSED 04/18/2009 BRW BRAIDWOOD GENERATING STATION EVAL MECH Print Date:
08/10/2009 Page:
1 EC
Title:
Mod Nbr M-IMS07002C, EVAL FOR MT INDICATIONS ON SHEAR LUGS WESTINGHOUSE NDE REPORT #AIR14-MT-001 COMPONENT #1MS-07-SW08 (SHEAR LUGS) 0000374961 KWI: SR KW2:
KW3:
KW4:
KW5:
Master EC Outage WO Required Adv Wk Appvd:
Auto-Advance:
Caveat Outst:
Resp Engr Location N
Y N
Y ALAN Work Group Alert Group:
DER Image Addr Alt Ref.
Priority Department :
08952 F MIKOTTIS Temporary Aprd Reqd Date:
Exp Insvc Date:
Expires On Auto-Asbuild Discipline N
04/07/2009 01/09/2012 N
DER Units E=
unit BRW 01 Outages E=
Unit BRW Description UNIT ONE A1R14 UIscriELtionU U-1 REFUEL OUTAGE #14 Systems FW System BRW MS Meacrintion MAIN STEAM
EngInearing Change PitDt:0/020 Print Date:
08/10/2009 EC Number Status/Date Facility Type/Sub-type:
0000374961 000 CLOSED 04/18/2009 BRW EVAL MECH i11illilill11illilill1iilli1ll11il1illil1lll11lllllliili1lll11ill11illil11lll1i1li
- __3 Page
1 EC
Title:
Mod Nbr M-1MS07002C, EVAL FOR MT INDICATIONS ON SHEAR LUGS WESTINGHOUSE NDE REPORT #AIRI4-MT-001 COMPONENT #1MS-07-SW08 (SHEAR LUGS) 0000374961 KWl: SR KW2:
KW3:
KW4:
KW5:
Master.EC Outage WO Required Adv Wk Appvd:
Auto-Advance:
Caveat Outst:
Resp Engr
- Location, N
Y N
Y ALAN Work Group Alert Group:
DE Image Addr Alt Ref.
Priority Department 08 F MIKOTTIS
- R Temporary Aprd Reqd Date:
Exp Insvc Date:
Expires On.
Auto-Asbuild Discipline N
04/07/2009 01/09/2012.
N" DER 952 030-DAR CONCUR 04/14/2009 BRZRB BELAIR 110-PREPARE EC 04/14/2009 ZONAM MIKOTTIS 120-REVIEW EC 04/14/2009 PWR69 SHAH Independent review of the EC.
200-DISC RVW-M 04/14/2009 DEBOOGX DEBO0 I performed a technical review of the evaluation and judgments and conclusions drawn in it.
My editorial RAYMOND ALAN SHASHIKANT GUY agree with the comments have been CANCELED APPROVED APPROVED
.APPROVED satisfactorily resolved.
240-ITPR-EPR 04/14/2009 BRZRB BELAIR RAYMOND The Consequence Risk Factors in Attachment 2 of HU-AA-1212 have been reviewed for applicability and all were of LOW or N/A severity level.
Therefore, this EC will be prepared, reviewed,, and approved using existing process reviews.
300-APPROVE EC 04/15/2009 BRWYG GUSTAFSON DAVID 900-ARCHIVE EC 04/18/2009 BRZEF RIORDAN GAIL APPROVED APPROVED CLOSED Units Fa=
IUni BRW 01 Description UNIT ONE Outages Fac BRW unit AIR14
-IDescription AlRl4 U-1 REFUEL OUTAGE #14 Systems E=a System BRW MS Description MAIN STEAM
Engin-ae.rng Change EC Number 0000374961 000 Status/Date CLOSED 04/18/2009 Facility BRW Type/Sub-type:
EVAL MECH 1i11 11l1li 111ili iiillililli1l 1111i1i1l11il 1l11l1l11ll 1111 111i1lliill liii lilli Print Date:
08/10/2009 Page:
2 Affected Equipment List Fa=
Unit OnSy nivig Systm fiLaAA BRW 01 Equipment :
HNGA 06007S Component H05 Equip. Tag:
1MS06007S State:
Reviewed?
Y Inst/Rm:
Name :
MECH SNUBBER SUPPORT FOR LINE MS Minor Rev:
Major Rev:
Rev Trackable:
IMS01AB (32.75)
Y Inc:
N BRW 01 MS Equipment HNGA 07002C Minor Rev:
Component S18
<-Major Rev:
Equip. Tag:
lMS07002C State:
Reviewed?
Y Inst/Rm:
Rev Trackable:
Name :
CONSTANT SUPPORT. FOR LINE lMS01AC (32..75)
Y Inc:
N BRW 01 Equipment PIPA 01AC Component :
P20 Equip. Tag:
1MS01AC State:
Reviewed?
Y Inst/Rm:
Name :. PIPE, 32.75 MS Minor Rev:
Major* Rev:
Rev Trackable:
Y Inc:
N Reference Documents List Tace ISuty yy e
Document BRW DWGC M-914
Title:
COMPONENT LUG AND STANCHION SCHEDULE UNITS 1 & 2 BRW DWGC M-914
Title:
COMPONENT LUG & STANCHION SCHEDULE UNITS 1 & 2 Sheet 36
. BRW DWGC
Title:
HANGER BRW DWGC
Title:
HANGER BRW DWGV
Title:
MAIN STEAM M-1MS07002C M-iMS07002C 1C-MS-18 2
Engineering Change EC Number 0000374961 000 Status/Date CLOSED 04/18/2009.
Facility BRW Type/Sub-type:
EVAL MECH 111III1I1I1III 11I1I1111I111 I1I11I1IIIII1 IIIIII1I1 II1I1III111 III1111I1I11II111111 Print Date:
08/10/2009 Page:
3 BRW DWGV IMS-07
Title:
ISI ISO OF MS LINE INSIDE Planning/Scheduling Infornation CONTAINMENT LOOP 3 Planning Start Planning Event 100-PREP EVAL Cross References Level of Effort:
Thru affte Ref.
AR Sub-Number Number 00901376 MeTcriNItion MT INDICATIONS. IDE NTIFIED DURING ISI EXAM OF 1
Engineering, Ckiage Print Date:
08/10/2009 EC Number Facility Type/Sub-type:
0000374961 000 BRW EVAL MECH Page:
1 Topic EVAL DETAILS Last Updated By ZONAM From Panel
- TIME100 Last Updated Date:
04/15/2009 Text Status UNLOCKED
Document: EC 374961 Rev. 000
Title:
Evaluate the Linear Indications Found on the Shear Lugs for Support #M-1MS07002C (and M-1MS06007S).
Reason for Evaluation /Scope:
Westinghouse NDE Report #A1R14-MT-001 (Ref. 1), inspection of the shear lugs on support lMS07002C (Ref. 2), which is a Safety Related / ASME Class 2 support, identified several linear indications on all 4 of the lugs (9 total indications). Five of these indications (#3, #4, #5, #8 & #9) exceeded the acceptance criteria as delineated in ASME Section XI, 2001 Edition, 2003 Addenda, as described in IR #00901376 (Ref. 5). The indications that exceed the applicable acceptance standards of Table IWC-3410-1 require additional engineering evaluation to determine acceptability.
Per IWC-3121(a) IWC-3122.3, flaws that exceed the acceptance standards of Table IWC-3410-1 are acceptable for continued service without repair/replacement if the results of an analytical evaluation, as described in IWC-3600, meets the acceptance criteria of IWC-3600.
IWC-3600 only provides the analytical methodology for planar flaws. and does not specify acceptance criteria for ferritic components. The flaws identified in these lugs are characterized as laminar flaws.
Constant spring hanger support 1MS07002C is a Safety Related pipe support on line 1MS01AC-32.75", located inside the Unit 1 Containment Building at elevation 398'-67, a seismic category I area of the plant. Support lMS07002C is located on a riser for line MSO0AC-32.75" and provides vertical deadweight support only (i.e. no seismic restraint provided by this support). Line 1MS01AC-32.75" is the first part of the piping system that transports steam from the 1C Steam Generator inside containment to the U1 Turbine outside containment.
Detailed Evaluation:
Braidwood Design Engineering and Corporate Engineering (Cantera). reviewed Westinghouse NDE Report #A1R14-MT-001 and sketches for the identified linear indications. From this report, the indications exceeding the acceptance criteria (Ind. #3, #4, #5, #8 & #9) are located in the lug base metal along the weld toe. These indications run parallel to the Weld toe and based on the 00 beam UT examination are running in a plane parallel to the 16" x 4 1/2" surface of the lug. Based on the location and orientation of the indications it is evident that these are not caused by external piping loads, i.e. not service induced. Since this is a vertical riser supported with a riser clamp and shear lugs as can be seen on drawing M-1MS07002C (Ref. 2), the load applied to the clamp / lug is essentially a weight shear load in the pipe axial direction. The stresses decrease from the bearing surface of the lugs to the top (free) surface of the lugs, where more of the indications were found (i.e. the shear approaches "zero" at the top end of the lug just above the weld since this is a free edge). Also any radial stress from the constant support load being eccentrically applied would be compressive as well as going to zero at the top end of lug. The piping pressure stress would tend to put the lug weld and these laminations into compression due the increased rigidity of the lug compared, to the piping wall without the lug. The highest stressed area.of these lugs would be at the bottom end of the lugs, at the lug/clamp interface. The majority of the indications are not located in this area.. These indications are linear and located just above the welds of the lugs to the pipe, in a plane parallel to the pipe axis. This is indicative of a laminar separation caused by the fabrication process of the lug and the weld residual stresses. These lugs are 2 1/2" thick, 4 1/2" wide and 16" long, welded to the pipe with 1 3/8" partial penetration groove welds with 1 3/8" fillet caps along the two. 16" lengths and the top 4 1/2" length of the !ugs (see Ref.s 3 & 4). The welding process for
EC 374961 Rev. 000 Page 2 of 4 these large welds introduces a significant amount of weld shrinkage stress into the lug itself and large residual stresses acting on the lugs can cause laminar separations that result over time into indications similar to those identified. These lugs also may not have been cut in the optimal orientation, which can make them more susceptible to laminar separation. See the following information on lamellar tearing below (under "Additional background information...").
As previously described the applied weight load on the lug is parallel to the plane of the indications, therefore the applied load will not cause the indication to grow in a different direction. Also, the weight load variations between hot and cold positions of the piping are very small and. would not cause a stress range sufficient to initiate fatigue cracking in the lug or the weld. Other operating stresses, i.e. from pressure loads and through7wall. thermal stress gradients due' to heat-up and cool-down of the steam lines, are small and occur infrequently with the start-up and shutdown of the Unit (less than -200 cycles for the life time of the plant) and would not be a cause of fatigue damage to the lug or weld. Since the through wall stress in the lug is insignificant or very small, there is no.
crack driving force that would cause growth or failure of these laminar flaws, i.e. the mode I stress intensity factor along the crack tip is essentially zero.
As previously stated, all the indications that exceed the acceptance criteria are located in the lug base metal itself, just above the welds, and oriented parallel with the welds (see Ref. 1). In the' extreme case (not credible), assume the lugs were to shear off, just above the weld, which would in turn result in a lug that is now only 1 3/8" thick vs. 2 1/2" thick (still 4 V/2" wide by 16" long). This would still be of sufficient size to restrain the load and actually reduce the stresses in the pipe wall since the moment arm from the bearing load point of the clamp to the pipe wall would actually be smaller i.e. reduced integral welded attachment (IWA) stresses. The amount of weld transferring the load from the pipe lugs to the clamp has not decreased. Weld stresses would actually decrease slightly based on the reduced moment arm discussed above, Shear on the lug would not change since the cross sectional area resisting the shear is the same (4.5" x 16" = 72 sq. inches).
The design basis calculation (Ref. 7) that includes these lug qualifications uses MES-EMD-6.2 (Ref. 6) forms for qualification. The evaluation for this configuration uses a LF (load factor) = 0.5, which means half of the total load is applied to a single lug. This is consistent. with MES-EMD-6.2, Section 2.6-IV, which states "For figure type 1-1 and 1-2, only two lugs are assumed to carry load".
Our arrangement is Fig 1-1. Thus, only 2 of the 4 lugs are assumed to be active for evaluations in thistype of lug arrangement.
If the lug were to shear off as described above, the bearing area on the clamp would decrease from
- approximately 4.5" x 2" = 9 sq. inches to 4.5" x 1 3/8" = 6 sq. inches/lug (clamp is 2" thick, Ref. 2).
The load on support 1MS07002C is approximately 50 kips. The 50 kip load is distributed between 2 lugs, which results in an increase in bearing stress On the clamp/lug interface from 25 / 9 -2.8 ksi:
to 25 / 6 = 4.2 ksi, which is very low for bearing stresses. Therefore, even if the lugs sheared off just above the welds, the remaining portions of the lugs would still provide adequate support forithe riser clamp to perform its design function for support 1MS07002C with no increase in IWA stresses on the pipe wall. This was an extreme example and not a credible scenario. It should also be noted that only 1 of the 4 lugs (@ 135 degrees) has any indications over 0.50".
Additional background information provided by Jim Cirilli (Sr. Staff Engr., Kennett Square):
EC 374961 Rev. 000 Page 3 of 4 Based on that weld joint design, the lug thickness and my review of the NDE results from 2000 and this outage, these indications are likely laminar tears related to the original fabrication/construction welding. Lamellar tearing commonly occurs in T-butt and fillet weld joints and is a kind of weld-cracking that forms beneath a weld, generally outside the HAZ.L Per the attached zero degree beam UT inspection report, the plane of these indications is parallel to the surface of the lug. Although lamellar tearing is not service-induced, existing tears can propagate due to service loads until the displacement control residual stresses are sufficiently relieved..
The following are contributors to laminar tearing:
- thick carbon steel plate (4.5" in the case of these lugs), which commonly has preferential grain orientation from the plate rolling operation. The material toughness in the through-thickness direction is typically lower in these steels. The presence of non-metallic inclusions in the steel can also contribute to lamellar tearing.
- weld joint design and large weld size producing high welding residual stresses acting on the through-thickness direction of the plate (i.e., transverse to the plate rolling direction such that the welding stresses want to pull apart the plate material).
The problem can be avoided by selecting base material having adequate ductility in the thickness direction that has been screened by ultrasonic testing for absence of laminations or other internal defects. It can also be managed by paying attention to weld joint details and avoiding massive welds that develop significant shrinkage stresses.
Supplemental Evaluation for Linear Indications Found on the Shear Lugs for Snubber Support
- M-1MS06007S (Ref. 9):
As a result of the indications found on the lugs of support 1MS07002C it was necessary to expand the population. Shear lugs (4 of 8) on seismic restraint IMS06007S were inspected (Ref. 8). This restraint is on a vertical riser section of line #1MS01AB-32 3/4". The indications on these lugs are.
very similar in nature to those from support 1MS07002C. The lugs for this support are slightl larger than those of 1MS07002C (16" x 5" x 2 1/22" with 1 1/22" welds vs. 16" x 4 1/22" x 2 1/2/2" with 1 3/8" welds), but the same configuration and material. However, 1MS06007S is a snubber-type restraint, and is only subjected to seismic/dynamic type loads, which have not occurred on this support. This further supports the previous discussion that these types of indications are not "load induced". There are actually 8 lugs (4 ontop & 4 on the bottom of the clamp) on 1MS06007S since this type of restraint has a +/- loading applied due to seismic. However, the applied load on any individual lug is always in the same direction. All of the previous discussions for 1MS07002C are basically applicableto the linear indications found in the shear lugs for 1MS06007S. Seismic loads.
on this snubber are on the order of 55,000 lbs per drawing M-1MS06007S Sheet 1 (Ref. 9). Seismic stresses at the lug location are small (less-than 1 i,000 psi for equation 9B per Ref. 10 base report, less than 4000 psi per revision 8D). These shear lugs were also originally evaluated assuming only 2 of 4 lugs (in each direction) take the entire load (Ref. 7).
Conclusion / Findings:
Based on the above evaluation, the indications identified in Ref.s 1 & 8 are acceptable and the lugs.
will provide their intended design functions for restraints 1MS07002C & 1MS06007S. Based on
EC 374961 Rev. 000 Page 4 of 4 the location and orientation of the indications and on the magnitude and direction of the applied operating loads, these indications will remain stable and will not prevent the lug from performing its intended function of providing weight support for this MS riser pipe for 1MS07002C (and seismic restraint for 1MS06007S). Furthermore the design basis qualification for the lugs requires only 2 of the 4 lugs to satisfy design criteria and the material of the lug above the top of the weld (i.e.,
radially out from the pipe surface) is not required for functionality or to satisfy design stress limits.
Note also that these conclusions are also applicable to the lugs on the sister supports on the 1A, 1B, 1Cand 1D MS lines off the generators (subsystems 1MS05, 1MS06, 1MS07 and 1MS08) when reviewing similar lug. anomalies.
References:
- 1. Westinghouse NDE Report #A1R14-MT-001 for 1MS-07-SW08 (shear lugs for Support
- M-1MS07002C). See Attached PDF file.
- 2. Drawing #M-1MS07002C, Sheets 1 & 2, Rev. J.
- 3. Drawing #M-914, Sheet 1, Rev. L, "Component Lug & Stanchion Schedule".
- 4. Drawing:#M-914, Sheet 36, Rev. D, "Component Lug & Stanchion Schedule".
- 5. IR #00901376, "MT Indications Identified During ISI Exam of 1MS-07-SW08", dated 04/01/2009.
- 6. Sargent & Lundy Standard MES-EMD-6.2, Rev. B, "Evaluation of Welded Attachments'.'.
- 7. Calculation #055269, Rev. 008 (up to Addendum "E"), "Piping Stress Report for Subsystem 1MS07".
- 8. Westinghouse NDE Report #A1R14-MT-003 for lMS-05 (shear lugs for Support #M-1MS06007S). See Attached PDF file.
- 9. Drawing #M-1MS06007S, Sheets 1 & 2, Rev. F.
- 10. Calculation #055270, Rev. 008 (up to Addendum "D"), "Piping Stress Report for Subsystem 1MS06".
PDF file of Ref. 1:
ScanOO.PDF PDF file of Ref. 8:
ScanOOl.PDF
Cc Exelkn.
Nuclear Date: 4-2-09 To: Brendan Casey / Tom Green From: Jay Miller
Subject:
Evaluation of Surface indications from WesDyne report AIR14-MT-001 There were two indications on the lug located at 45' - indications located in the lug base material at the weld toe.
Indication #1: Linear indication 0.25" long Indication #2: Linear indication 0.20" long There were six indications on the lug at 1350 - indications #3, 4, 5, 7 and 8 are located in the lug base material at the weld toe, indication #6 is located in the weld.
Indication #3: Linear indication 1.5" long Indication #4: Linear indication 2.3" long Indication #5: Linear indication 1.6" long Indication #6: Linear indication 0.25" long Indication #7: Linear indication 0.25" long Indication #8: Linear indication 0.50" long There was one indications on the lug located at 315' - indications located in the lug base material at the weld toe.
Indication #9: Linear indication 0.45" long The lugs are an ASME Section XI 2001 Edition, 2003 Addenda code category C-C, Welded Attachments for Vessels, Piping, Pumps, and Valves, item number C3.20 with acceptance criteria specified in paragraph IWC-3512.
IWC-3512, Standards for Examination Category C-C, Welded Attachments for Vessels*
Piping, Pumps, and Valves, states in paragraph IWC-3512.1, Allowable Linear Flaws, (a) The size of an allowable flaw within the boundary of the examination surfaces in Fig. IWC-2500-5 shall not exceed the allowable flaw standards of this Article for the applicable supported pressure retaining component to which the attachment is welded.
Line number IMSO7AC-32.75" is the pressure retaining component and is an ASMIE Section XI 2001 Edition, 2003 Addenda, Category C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping, item number C5.51 with acceptance criteria specified in paragraph IWC-3514.
IWC-3514, Standards for Examination Category C-F-1, Pressure Retaining Welds in A ustenitic Stainless Steel or High Alloy Piping, and C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping, states, "'These standards are in the course of preparation. The standards of IWB-3514 may be applied."
Exelon.
Nuclear
,VB-3514, Standards for Examination Category B-F, Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles, and Examination Category B-J, Pressure Retaining Welds in Piping, states in paragraph IWB-3514.1 Allowable Planar Flaws (a) The size of allowable planar flaws within the boundary of the examination surfaces and volumes delineated in Figs. IWB-2500-8 through lWB-2500-11 shall be in accordance with the standards of IWB-3514.2, IWB-3514.3, and IWB-3514.4, as applicable.
IWB-3514.2 Allowable Flaw Standards for Ferritic Piping, (b) Where flaws on the outer surface of piping as detected by the surface examination method during an inservice examination exceed the allowable standards of IWB-3514.7,'
the indications may be examined by the volumetric method. The acceptance of these flaws shall be governed by the allowable flaw standards for the volumetric examination method in Table IWB-3514-1.
Paragraph IWB-3514.7, Allowable Linear Flaw Standards for Ferritic Piping, (a) The size of an allowable linear flaw within the boundaries of the examination' surfaces in Figs. IWB-2500-8 through IWB-2500-11 shall not exceed the limits specified in Table IWB-3514-4.
Table IWB-3514-4, Allowable LinearFlaw, states for Surface Examination Method, PT or MT, Inservice Examination for a nominal wall thickness of 1.344" utilizing linear interpolation, the allowable flaw length cannot exceed 0.42".
Indication Evaluation (evaluated as separate flaws):
Indications #1, 2, 6 and 7 lengths are less than 0.42" and are acceptable.
Indications #3, 4, 5, 8 and 9 lengths exceed 0.42" Per IWA-3400, Linear Flaws Detected by Surface or Volumetric Examinations, (a) Linear flaws detected by surface (PT/MT) or volumetric (RT) examination methods shall be considered single linear surface flaws provided the separation distance between flaws is equal to or less than the dimension S, where S is determined as shown in Fig.
The indications discovered during this examination are represented by figure (c) aligned linear flaws, and the total indication length is determined by applying the longest length and verifying the S dimension (length between the flaws) is less than or equal to the longest dimension. In this case indications 3 and 4 must be combined and equal an aggregate length of 4.5".
Indication Evaluation (applying the requirements of IWA-3400):
All indications except #3 and 4 have an S dimension greater than the longes.t length of the adjacent flaw. The S dimension for indications #3 and 4 is 0.65" and the longest length is
- 4 at 2.3". Therefore these indications are combined for an aggregate length of 4.5".
ExelOn.
Nuclear Additionally, a straight beam 0' Ultrasonic examination was performed from the face of the lug located at 1350 to determine how far the indications extended into the base material. The straight beam UT identified a length of 12.5" long by 1.1" wide adjacent to indications #3 and #4 and a depth of 1.2" from the lug face.
In conclusion indications #3, 4, 5, 8 and 9 are rejectable, Issue report 00901376 has been generated to capture the evaluation and disposition of all the indications.
Jay Nkilldr - NDE Level III
/
WESTINGHOUSE NUCLEAR SERVICES Westinghouse SURFACE EXAMINATION DATA Report No. AIR14-MT-O01 Page 1 of 3
PLANT BRAIDWOOD UNIT' 1
DWG/SKETCH 1 MS -07 SYST/COMP MAIN STEAM PROCEDURE EXE-ISI-70 Rev 3 EXAMINER P6AL-...
5A DATE 3/31/09 COMPONENT 1MS SW08 Paul Blecha P/T TYPE, BATCH NUMBER M/T CLEANER EQUIPMENT Y-6 YOKE 1239 TYPE OF CURRENT AC PENETRANT N
SURFACE THERMOMETER 105222 DEVELOPER A
EXAM MEDIUM YELLOW #2 - Batch 08H030 REMOVER LIGHT METER 105248 LIGHT METER WHITE-LIGHT R BLACK-LIGHT CHECK TIME
__CHECK TIME 13:31 (> 100 fc)
SURFACE T MOMETER Component consists of 4 lugs spaced 900 apart @
450,1350, 2250, 3150 IDENT.
RESULTS TEMP.
NUMBER NI NRI RI REMARKS OF i____
00 pipe azimuth was established at the intradose of the elbow, below the lugs There is a plate welded to the bottom of each lug > 90% coverage obtained (see limitation in Rpt.OOBRI-MT-01 9)
SWO8 91 Lug @ 450 X
Indications 1 & 2 are located in the lug base material at the weld toe Ind # 1 = Linear.25" Ig Ind # 2 = Curvilinear.2" Ig Lug @ 1350 X
Indications 3, 4, 5, 6, 7& 8 - Indications 3,4,5,7,8 are located in the lug base
_______material at the weld toe. Ind #6 is in the weld Ind # 3 Linear 1.5" Ig These two indications are separated by.65",therefore by the Ind # _=_Liear
-g rules of IWA-3400, their lengths and separation are combined Ind #4 = Linear 2.3" Ig to total 4.5' overall length.
Ind #5 =Linear 1.6"lg Ind # 6 = Linear.25". Ig Located in a grindout on the weld metal Ind # 7 = Linear.25" Ig
- Ind
- 8 =Linear 0.5" Ig Lug @ 2250 X
No reportable indications were observed Lug @ 3150 X
Indication 9 is located in the lug base material at the weld toe Ind #9 = Linear.45" Ig WESOYNE REVIEW) I ATE ANN REV IEW)I DATE
.XELON LEVEL III REVIEW I DATE
-a q
0.
I I
Q Westinghouse WESTINGHOUSE NUCLEAR SERVICES INDICATION SKETCH SHEET A1R14-MT-001 PAGE 2 of 3 PLANT BRAID WOOD UNIT 1
DWG/SKETCH 1 MS-07 EXE-ISI-70 Rev 3 SYST/COMP, Main Steam PROCEDURE EXAMINER
.Paul Blecha DATE 3/31/09 RELATED TO:
VT PROVIDE GENERAL INFORMATION TO DESCRIBE APPROXIMATE SIZE, LOCATION AND TYPE OF LIMITATION.
IDENT. NO.
I MS-07-SWO8 ICURVILINEAR 2-L9 l@ Top c9 Lug located nowr wald LUG FACE 135 To e Lug m I rvllfIln # 3 AV' LINEAR 1.5" Lg on Skis of Lug ocated a weld toe
- 06.
-1.2 din from faoe of lug 2Z3 LINEAR 2.3-Lg on Side of Lug located a weld toe 4.6
-1.2" dn from faoe of ag Pipe V" established at lower elbow intac&ose Lugs Typ 4P.s5 4lszs35*
I I
LINEAR 1.i' Lg on Side of Lug Iocated @ weld toe
/
-1.2' dn from faoe of lug 1 4" 90 0
180 90 l_I_* 1 rJ it I
.41 ANM REVIEW I DATE EXELON LEVEL III REVIEW I DATE 1
(
Westinghouse WESTINGHOUSE NUCLEAR SERVICES INDICATION SKETCH SHEET A1R14-MT-001 PAGE 3 of 3 PLANT BRAID WOOD UNIT 1
DWGISKETCH 1MS-07 EXE-ISI-70 Rev 3 SYST /COMP.
EXAMINER Main Steam PROCEDURE DATE 3/31/09 DATE Paul Blecha RELATED TO:
VT PROVIDE GENERAL INFORMATION TO DESCRIBE APPROXIMATE SIZE. LOCATION AND TYPE OF LIMITATION.
IDENT. NO.
IMS-07-SWO8 LINEAR -25* Lg located in a grind-out in the weld material LUG FACE 135 Pipe "0" established at lower elbow intradose Indicaton # 9 LINEAR.45" Lg located on Top of lug Q weld toe in the lug material LUG FACE 315 0
1 10 270 Lugs Typ 4 Pts Q
.45.135.225,315 UNEAR.25" l.g ocaled @ weld Ito in the lug material UNEAR.5* Lq bcated @ weld toe In the lug nmteral I I
180 90 WESOYNE REVIEW I DATE 4~- 4,447 ANII REVIEW I DATE EXELON LEVEL III REVIEW I DATE.
I
-. Iv-,
- /-
'N OWestinghouse Calibration Data Sheet Plant / Unit Company Comp / System Procedure No.
Rev /Chng. No.
Cal. Block No.
Cal. BlockTemp.
Thermometer S/N:
Size NIA I Ref.
Blo c:
S 10ý3583*
BRAIDWOOD EXELON Main Steam ER-AA-335-045 1/0 CB-01-241 79OF 105222
- ch.
N/A rJ Ferrtic rBAustenitic.
Data Sheet #
AIR14UT-020 Page 1
of 3
Cal. Checks Time Initial Calib.
11:27 Initial Calib. Date 3131109 Intermediate 13:45 Intermediate N/A Final Calib.
15:10 Final Calib. Date 3131/09 Couplant Type:
Ultragel II Batch:
02225 1 step 2_Step Search Unit #1 Manufacture:
Krautkramer Serial No.:
57461 3744 No. of Elements:
2 Size:
2(11x2)
Shape: Rectangle Freq.
2 MHz Style:
MSEB2 Exam Angle:
0° Mode:
L Measured Angle:
N/A Wedge Style:
NVA Search Unit Cable Each Major CRT Div.
.50 Dp Cal. Direction:
N/AlAxial rN_/A Circ.
Nw Both Scan Area:
I.
to Weld rw.
to Weld
[Nj Code Category:
N/A Code Item:
N/A Recordable Exam Access Indications Exam Yes No Geom Type:
Length:
RG-174 Examination Area / Weld 6!
No. of Con.:
0 1 MS-07-S W08 (L us)
N/A N/A N/A N/A N/A:
Remarks.! Reason for Incomplete Scan(s)
COMPONENT TEMP: 91 *F
' As Found" Surface Condition (Slightly Rough).-
Scan to map extent of plate segregate/lamination on Lug @ 1350.
3rd Interval eSearch Unit #2 Manufacture.
Serial No.:
No. of Eleme ts:
Size:
_Shape:
Freq.
Style:
Exam Angle:
Mode:
Measured Angle:
Wedge Style:
Search U it Cable N/A Type:
Length:
No. o on.:
Instrument Se ngs Make I Model:
Serial No.:
Probe Delay:
Range M'tI Cal I Vel:
Pulser:
Damping:
Reject.
PRF:
Freq:____r Filter:
Mode:
Rectify:
Voltage:
Pulse Width:
Reference Sensitivity (Sens.)
Axial:
Circ:
SDH Sensitivity:
Display Delay:
Instrument Settings Make I Model:
GE-Krautkrarner /USN 60SW Serial No.:
104389 Probe Delay: 9.6181 Range:
5.0 M'tl Cal /I Veh:
.2342 Pulser. Square Damping:
500 Reject:
0%
PRF:
Auto High Freq:
2 MHz Filter:
Fixed Mode:
Dual On Rectify:
Fultwave Voltage:
450 Pulse Width:
250 ns Reference Sensitivity (Sensw)
Axial:
40.5 dB Circ:
N/A SDH Sensitivity:
NIA Display Delay:
0 Examiners "
N/A Reviewers:.
Level Iii Date 3/31109 Level N/A Date N/A Further Evaluation Required? Fx1Yes nNo W~SOYNERFU1eWJ flATh 4~
I 1A WEi EAI EW D
4102- /0-9 EXELOWLE~~Y C RE~OA T E~Q%
~
q ~3 ~ 5 Fof EXELOIfLEV4 W REVIgN I DATE J
A, /ý C >
I
- Westinghouse Plant / Unit BRAIDWOOD Company EXELON.
Comp i System Main Steam Procedure No.
EXE-PDI-UT-Rev / Chng. No.
2/0 Cal. Block No.
CB-01-241 Cal. Block Temp.
79OF Thermometer S/N:
105222 Size N/A Sch.
NIA Ref. Block.,
rT]
103583
.3 "T"
- ermtic
,ustenitic Data Sheet #
AlR14UT-020 Page 2
of 3
Cal. Checks Time Initial Calib.
11:25 Initial Calib. Date 3/31/09 Intermediate 13:19 Intermediate N/A Final Calib.
15:09 Final Calib. Date 3/31/09 Couplant Type:
Ultragel I1 Batch:
02225 IýlAY Each Major CRT Div.=
36 DP Cal. Direction:
N/A Axial N/A Circ. r Both Search Unit #1 Manufacture:
Krautkramer Serial No.:
OOYMBB No. of Elements:
1 Size:
.375 Shape:
Round Freq.
2.25 MHz Style:
COMP-G Exam Angle:
450 Mode:
-Shear Measured Angle:
450 Wedge Style:
Non-Integral
-Search Unit Cable Scan-Area:
d CII Code Category.
Code Item:
N/A Type:
Length:
RG-174 Examination Area I 6'
No. of Con.:
0 SSearch Unit #2 Manufacture Serial No.:
No. of Eleme ts:
Size:
Shape:
Freq.
Style:
Exam Angle:
Mode:_____
Measured Angle:
Wedge Style:
Search U it Cable N/A Type:
Length:
No. o, on.:
Make IModel:
Serial No.:
Probe Delay:
Range:
M'tU Cal / /el:
Pulser:
Damping:
Reject:
PRF:.
Freq:
Filter:
Mode:
Rectify:
Voltage:
Pulse Width:
Reference Sensitivity (Sens.)
Axial:
Circ:
SDH Sensitivity:
Display Delay:
1 MS-07-SWO8 (Lugs)
Remarks / Reason for Incomplete Scan(s)
COMPONENT TEMP: 91 "F
"As Found" Surface Condition (Slightly Rough)
Scan to establish MT indications orientation and aid in classification of laminar.
Planar Flaw Tip Calibration No Planar Flaws Detected Instrument Settings Make / Model:
GE-Krautkramer / USN 60SW Serial No.:
104389 Probe Delay:i 6.1222 Range:
5.0 M'tl Cal / Vel:
.1326 Pulser:
Square Damping:
500 Reject:
0%
PRF:
Auto High Freq:
2.25 MHZ Filter:.
Fixed Mode:, Dual Off Rectify:
Fulfwave Voltage:
450 Pulse Width:
220 ns Reference Sensitivity (Sens.)
Axial:
33.4 Circ:
N/A SDH Sensitivity:
N/A Display Delay:
0 3rd Interval Examiners:
- Level III Date 3/31/09 Uldfael McKa~g N/A Level N/A.
Date N/A Further Evaluation Required? 1 Yes
[X1No Reviewers:
WESOYNE 'P iz I DATE 4
~~
-4 EXELON Leif IW
- ý~
6
-T
!?EW DA IANU REVIEW I DATE
- Westinghouse WESTINGHOUSE NUCLEAR SERVICES INDICATION SKETCH SHEET OD UNIT 1
DWG/SKETCH AlR14UT-020 PAGE 3 of 3
.(
PLANT BRAIDWO 1 MS-07 SYST./COMP.
EXAMINER Main Steam M. McKaig PROCEDURE ER-AA-335-.045 R1 3/31/09 DATE RELATED TO:
UT X
PT MT VT PROVIDE GENERAL INFORMATION TO DESCRIBE APPROXIMATE SIZE, LOCATION AND TYPE OF LIMITATION.
IDENT. NO.
IMS-07-SW08 LUG @ 135° Top of Lug 0"
.15" Zero examination indicates a reflector at approximately 1.2" from the surface.
This indication is continuous as noted in the sketch. Amplitude varies but equals and exceeds the back-wall in some places.
The back-wall signal is never reduced to baseline.
Extent of the indication is determined by mapping the signal to baseline noise level.
Bounding rectangle =1.1" x 12.5" = 13.75 sq in.
Exekrn.
Nuclear Date: 4-7-09 To: Brendan Casey / Tom Green From: Jay Miller
Subject:
Evaluation of Surface indications from WesDyne report A 1R 14-MT-003*
No indications were identified on lug PG7.
There was one indication on the lug PG5 - indications located in the lug base material near. the weld toe.
- Indication #1:.Linear indication 0.10" long There was one indication on the lug PG6 - indications located in the lug base material near the weld toe.
- Indication #2: Linear indication 15" long There were eight indications on the lugPG8-indications #3, 4, 5, 6, 7, 8, 9 and 10 are located in the lug base material at the weld toe.
- Indication #3: Linear indication 0.10" long
- Indication #4: Linear indication 0.25" long
- Indication #5: Linear indication 0.20" long
- Indication #6: Linear indication 2.9" long
- Indication #7: Linear indication 1.3" long
- Indication #8: Linear indication 0.10" long
- Indication #9: Linear indication 1.0" long Indication #10: Linear indication 1.7" long Per ASME Section XI 2001 Edition, 2003 Addenda and the ISI Program requirements as defined by requirements for expansion an inservice inspection is required during A1R14 on the four lugs identified in this IR.
The lugs are an ASME Section XI code category C-C, Item number C3.20 with acceptance criteria specified in paragraph IWC-3512.
IWC-3512, states in paragraph IWC-3512.1, Allowable Linear Flaws, (a) The size of an allowable flaw within the boundary of the examination surfaces in Fig. IWC-2500-5 shall not exceed the allowable flaw standards of this Article for the applicable supported pressure retaining component to which the attachment is welded.
Line number 1MS07AB-32.75 is the pressure retaining component and is an ASME Category C-F-2, Item numberC5.51 with acceptance criteria specified in paragraph IWC-3514.
IWC-3514 states, these standards are in the course of preparation. The standards of IWB-3514 may be applied.
IWB-3514 states in paragraph IWB-3514.1 Allowable Planar Flaws (a) The size of allowable planar flaws within the boundary of the examination surfaces and
Exelon.
Nuclear volumes delineated in Figs. IWB-2500-8 through IWB-2500-11 shall be in accordance with the standards of IWB-3514.
IWB-3514.2 Allowable Flaw Standards for Ferritic Piping, (b) Where flaws on the outer surface of piping as detected by the surface examination method during an inservice examination exceed the allowable standards of IWB-3514.7, the indications may be examined by the volumetric method. The acceptance of these flaws shall be governed by the allowable flaw standards for the volumetric examination method in Table IWB-3514-1.
Paragraph IWB-3514.7, Allowable Linear Flaw Standards for Ferritic Piping, (a) The size of an allowable linear flaw within the boundaries of the examination surfaces in Figs. IWB-2500-8 through IWB-2500-1 1 shall not exceed the limits specified in Table IWB-.
3514-4.
Table IWB-3514-4, Allowable Linear Flaw, states for Surface Examination Method, PT or MT, Inservice Examination for a nominal wall thickness of 1.344 utilizing linear interpolation, the allowable flaw length cannot exceed 0.42.
Indication Evaluation (evaluated as separate flaws):
Indications #1, 3, 4, 5. and 8 indications lengths are less than 0.42 and are acceptable.
Indications #2, 6, 7, 9 and 10 indication lengths exceed.0.42 and are unacceptable.
Per IWA-3400, Linear Flaws Detected by Surface or Volumetric Examinations, (a) Linear flaws detected by surface (PT/MT) or volumetric (RT) examination methods shall be considered single linear surface flaws provided the separation distance between flaws is equal to or less than the dimension S, where S is determined as shown in Fig. IWA-3400-1.
The indications discovered during this examination are represented by figure (c) aligned linear flaws, and the total indication length is determined by applying the longest length and verifying the S dimension (length between the flaws) is less than or equal to the longest dimension.
Indication Evaluation (applving the requirements of IWA-3400):
Indications #3, #4, #5 and #7 have an S dimension less than the longest length of the adjacent flaw #6 (2.9"). The aggregate length of these combined indications = 6.6".
Based on indications #3, 4, 5, 6, and 7 being combined with an aggregate length of 6.6",
Indications #8, #9 and #10 have an S dimension less than the longest length of this flaw length.
The aggregate length of these combined flaws = 14".
Under the requirements of IWA-3400, indications #3, 4, 5, 6, 7, 8, 9 and 10 are Un ceptable.
Jay Millet - NDE Level III
/
WESTINGHOUSE NUCLEAR SERVICES Westinghouse SURFACE EXAMINATION DATA Report No. AIR14-MT-003 Page 1 of 4
PLANT BRAIDWOOD UNIT 1
DWGISKETCH 1 MS -05 SYSTICOMP MAIN STEAM PROCEDURE EXE-ISI-70 Rev 3 EXAMINE DATE 4/6/09.
COMPONENT, 1 MS PGO5 to PG08 aul Be-chaý o~'/Jseh Sert LvII PIT TYPE, BATCH NUMBER MIT CLEANER EQUIPMENT Y-6 YOKE 1239 TYPE OF CURRENT AC PENETRANT SURFACE THERMOMETER 105222 DEVELOPER A
EXAM MEDIUM YELLOW #2 - Batch 08H030 REMOVER.
LIGHT METER 105248 LIGHT METER WHITE-LIGHT R BLACK-LIGHT, CHECK TIMEJM CHECK TIME 14:09 (> 100 fc)
SURFACE TI MOMETER "
I__..___IIIIiI__
IDENT.
RESULTS-TEMP.
NUMBER NI NRI RI REMARKS
.F Limited exam area at clamp> 90% Coverage Achieved.
PG05 X
Indication 1 is located in the lug base material at the weld toe.
63 Ind 1 =Linear.100" Ig PG06 X
Indication 2 is located in the lug base material at the weld toe.
63 Ind 2 =Linear 15" Ig PG07 X
No Reportable Indications
.63 PGO8 X
Indications 3, 4, 5, 6, 7, 8, 9 and 10 are located in the lug base material at 63 the weld toe.
Ind 3 =Linear.100" Ig Ind 4 = Linear.25" Ig.
Ind 5.= Linear.20" Ig Ind 6 =Linear 2.90" Ig Ind 7.= Linear 1.30" g Ind 8 =Linear.100' Ig Ind 9 =Linear 1.00"lg Ind 10 = Linear 1.70".1g WESDYNE REVIEW I DATE ANII REVIEW I DATE EXELON LEVEL III REEW I TE
efWesfinghouse WESTINGHOUSE NUCLEAR SERVICES INDICATION SKETCH SHEET Al R1 4-MT-003 PAGE 2 of 4 PLANT BRAIDWOOD UNIT 1
DWGISKETCH 1 MS-05 SYST./COMP.
Main Steam PROCEDURE EXE-ISI-70 Rev 3 EXAMINER PBleh J.S
- DATE, P. Blecha, J. Serth 4/6/09 RELATED TO:
VT IDENT. NO.
IMS-05-PG-6 PROVIDE GENERAL INFORMATION TO DESCRIBE APPROXIMATE SIZE, LOCATION AND TYPE OF LIMITATION.
Exam Area Limitation is due to clamp proximity and is essentially, t~h 1/2"area beyond the end of the wel fli s.5 LUG FACE PG-6 15.0" Lug Dimension = 16" X 5.1" 16" + 16" + 5.1" 37.1 linear" Total linear inches not examined equals 1.0" (.5" ea. side) 1." 37. 1=.0269 or 3%
97% Coverage Achieved Linear Ind. (#2) 16.0 Lg at too of weld
.9" from face of lug WESOYNE REVIEW~
f DA~
~
ANN1 REVIEW DATE EXELON LEVEL III REVIEW I DATEI
- o
B Westinghouse WESTINGHOUSE NUCLEAR SERVICES INDICATION SKETCH SHEET 00D UNIT 1 DWGISKETCH Al R 1 4-MT-003 PAGE 3 of 4 PLANT BRAIDWO(
1 MS-05 sYST./COMP.
Main Steam PROCEDURE EXE-ISI-70 Rev 3 EXAMINER Plcha, & Ser DATE P. Blecha, J. Serth 4/6/09 RELATED TO:
VT PROVIDE GENERAL INFORMATION TO DESCRIBE APPROXIMATE SIZE, LOCATION AND TYPE OF LIMITATION, IDENT. NO.
IMS-05-PG-5 Exam Area Limitation is due to clamp proximity and is essentially UIe WA" area beyond the end of the welT
."ITE LUG FACE PG-5
,5 Lug Dimension = 16" x 5.1" 16" + 16" + 5.1"= 37.1 linear" Total linear inches not examined equals 1.0" (.5" ea. side) 1"/37.1" =.0269 or 3%
97% Coverage Achieved Linear Ind. (#1).10" Lg diagonally oriented near the weld toe
.8" from face of lug
- 1
.25'Tr WESDYNE REVIEW I DATE ANNl REVIEW I DATE EXLNLVLIIRVE ATE
~
Westinghouse WESTINGHOUSE NUCLEAR SERVICES INDICATION SKETCH SHEET UNIT 1
DWG/SKETCH A1R14-MT-003 PAGE 4 of 4 PLANT BRAIDWO(
1 MS-05 SYST./COMP.
EXAMINER Main Steam PROCEDURE EXE-ISI-70 Rev 3 P. Bcha J-.~ Serth DATE P. Blecha, J. Serth 4/6/09 RELATED TO:
VT PROVIDE GENERAL INFORMATION TO DESCRIBE APPROXIMATE SIZE, LOCATION AND TYPE OF LIMITATION.
Exam Area Limitation is due to clamp proximity and is essentially the Y." area beyond the end of the weld Linear Indications 3&4 T
Combined for total length of.40" Linear Indications 5&6 Combined for total length of 3.4' IDENT. NO.
IMS-05-PG-8 Indications are located adjacent to the weld toe approximately.90" from face of the lug.
Linear Indication #7
- 1. 3" Lg Linear Indications 8&9 Combined for total length of 1.2' Linear Indication #10 1.7" Lg Lug Dimension = 16" x 6.1" 16" + 16" + 5.1" = 37.1 linear" Total linear inches not examined equals 1.0' (.5" ea. side) 1"/37.1" =,.0269 or 3%
97% Coverage Achieved W.ES.YNE REVIEW I DATE ANN REVIEWt DATE EXELON LEVEL III REVIEWI DATE Q
o,
I I-I