ML071110003

Fourth 10-year Internal ISI Requests for Relief RR 4-1, RR 4-2, RR 4-3 (Revision 1), RR 4-4, RR 4-6, and RR 4-7 (TAC Nos. 2404, MD2405, MD2406, MD2407, MD2409, and MD2410)

ML071110003
Person / Time
Site:	Palisades
Issue date:	05/18/2007
From:	Raghavan L NRC/NRR/ADRO/DORL/LPLIII-1
To:	Balduzzi M Entergy Nuclear Operations
Poole Justin
References
TAC MD2404, TAC MD2405, TAC MD2406, TAC MD2407, TAC MD2409, TAC MD2410
Download: ML071110003 (26)

Text

May 18, 2007 Mr. Michael Balduzzi Sr. Vice President, Regional Operations NE Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PALISADES NUCLEAR PLANT - FOURTH 10-YEAR INTERNAL INSERVICE INSPECTION PROGRAM PLAN REQUESTS FOR RELIEF RR 4-1, RR 4-2, RR 4-3 (REVISION 1), RR 4-4, RR 4-6, AND RR 4-7 (TAC NOS. MD2404, MD2405, MD2406, MD2407, MD2409, AND MD2410)

Dear Mr. Balduzzi:

By a letter dated June 12, 2006 (Agencywide Documents Access and Management System (ADAMS), Accession No. ML061710216), Nuclear Management Company, LLC (the licensee, at the time of the submittal), submitted Relief Request (RR) Nos. RR 4-1, RR 4-2, RR 4-3, RR 4-4, RR 4-6, and RR 4-7 for the fourth 10-year Inservice Inspection Interval. Entergy Nuclear Operations, Inc. has since become the current licensee, following the license transfer that occurred on April 11, 2007. The licensee submitted additional information in a letter dated February 12, 2007 (ADAMS Accession No. ML070440187), and by email on March 28, 2007 (ADAMS Accession No. ML070870606). In its February 12, 2007, letter, the licensee withdrew RR 4-4, and revised RR 4-3. Pursuant to Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.55a(a)(3)(ii), relief is requested by RR 4-1, RR 4-2, RR 4-6, and RR 4-7 to implement examination on the accessible volumes as identified, in lieu of the 100 percent volumetric requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested by RR 4-3 (Revision 1) because examination on the accessible volumes as identified, in lieu of the 100 percent volumetric requirements, would require modification or replacement, and therefore are impractical. The letter dated June 12, 2006, also submitted RR 4-5, RR 4-8, RR 4-9, RR 4-10, RR 4-11, and RR 4-12. These requests, along with the withdrawal of RR 4-4, are being handled by other correspondences.

The U.S. Nuclear Regulatory Commission (NRC) staff evaluation for the above relief requests for the fourth 10-year inservice inspection (ISI) program which began December 13, 2006, is as follows:

For RR 4-1, the NRC staff determined that examination of 100 percent of all accessible meridional welds will meet the ASME Code requirements and therefore, relief is not required for reactor pressure vessel lower head meridional welds 1-113A, 1-113B, 1-113C, 1-113D, 1-113E and 1-113F.

For RR 4-2, 4-3 (Revision 1), RR 4-6, and RR 4-7, the NRC staff determined that based on the drawings and basis provided by the licensee, the ASME Code requirements are impractical. In order for the licensee to perform the ASME Code required examinations, the subject components would have to be redesigned and would cause a burden on the licensee.

Furthermore, based on the coverages obtained, if significant service-induced degradation were

M. Balduzzi occurring, there is reasonable assurance that evidence of it would be detected by the examinations that were performed and that the examinations performed provide reasonable assurance of structural integrity of the subject welds. Therefore, for RR 4-2, RR 4-3 (Revision 1), RR 4-6, and RR 4-7, relief is granted, pursuant to 10 CFR 50.55a(g)(6)(i), for the fourth 10-year ISI interval. The submittal requested relief pursuant to 10 CFR 50.55a(a)(3)(ii) for RR 4-2, RR 4-6, and RR 4-7, and 10 CFR 50.55a(g)(5)(iii) for RR 4-3 (Revision 1).

However, the NRC staff has determined, based on the licensees submittal, that granting relief pursuant to 10 CFR 50.55a(g)(6)(i) is more applicable for RR 4-2, RR 4-3 (Revision 1), RR 4-6, and RR 4-7 because the relief is necessary due to an impracticality rather then a hardship. The NRC staff has determined that granting relief pursuant to 10 CFR 50.55a(g)(6)(i) for RR 4-2, RR 4-3 (Revision 1), RR 4-6, and RR 4-7 is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

All other requirements of the ASME Code,Section XI for which relief has not been specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

A copy of our related safety evaluation is also enclosed.

Sincerely,

/RA/

L. Raghavan, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255

Enclosure:

Safety Evaluation cc w/encl: See next page

M. Balduzzi occurring, there is reasonable assurance that evidence of it would be detected by the examinations that were performed and that the examinations performed provide reasonable assurance of structural integrity of the subject welds. Therefore, for RR 4-2, RR 4-3 (Revision 1), RR 4-6, and RR 4-7, relief is granted, pursuant to 10 CFR 50.55a(g)(6)(i), for the fourth 10-year ISI interval. The submittal requested relief pursuant to 10 CFR 50.55a(a)(3)(ii) for RR 4-2, RR 4-6, and RR 4-7, and 10 CFR 50.55a(g)(5)(iii) for RR 4-3 (Revision 1).

However, the NRC staff has determined, based on the licensees submittal, that granting relief pursuant to 10 CFR 50.55a(g)(6)(i) is more applicable for RR 4-2, RR 4-3 (Revision 1), RR 4-6, and RR 4-7 because the relief is necessary due to an impracticality rather then a hardship. The NRC staff has determined that granting relief pursuant to 10 CFR 50.55a(g)(6)(i) for RR 4-2, RR 4-3 (Revision 1), RR 4-6, and RR 4-7 is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

All other requirements of the ASME Code,Section XI for which relief has not been specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

A copy of our related safety evaluation is also enclosed.

Sincerely,

/RA/

L. Raghavan, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION:

PUBLIC LPL3-1 Reading RidsNrrDorlLpl3-1 RidsNrrPMMChawla RidsNrrLATHarris MMitchell TMcLellan RidsRgn3MailCenter RidsOgcRp RidsAcrsAcnwMailCenter TBloomer, EDO, Rgn III ADAMS ACCESSION NO. ML071110003

• per Memo dated April 3, 2007 OFFICE LPL3-1 LPL3-1/PM LPL3-1/LA CVIB/BC OGC LPL3-1/BC NAME JPoole MChawla THarris MMitchell* JBiggins (NLO) LRaghavan DATE 5/11/07 5/15/07 5/10/07 04/03/07 5/16/07 5/18/07 OFFICIAL RECORD COPY

Palisades Nuclear Plant cc:

Regional Administrator, Region III Sr. Vice President, U.S. Nuclear Regulatory Commission Engineering and Technical Services Suite 210 Entergy Nuclear Operations, Inc.

2443 Warrenville Road 1340 Echelon Parkway Lisle, IL 60532-4351 Jackson, MS 39213 Supervisor Mr. Bruce C. Williams Covert Township Vice President, Oversight P. O. Box 35 Entergy Nuclear Operations, Inc.

Covert, MI 49043 1340 Echelon Parkway Jackson, MS 39213 Office of the Governor P. O. Box 30013 Mr. Christopher J. Schwarz Lansing, MI 48909 Site Vice President Entergy Nuclear Operations, Inc.

U.S. Nuclear Regulatory Commission Palisades Nuclear Plant Resident Inspector's Office 27780 Blue Star Memorial Highway Palisades Plant Covert, MI 49043 27782 Blue Star Memorial Highway Covert, MI 49043 General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Michigan Department of Environmental Quality Palisades Nuclear Plant Waste and Hazardous Materials Division 27780 Blue Star Memorial Highway Hazardous Waste and Radiological Covert, MI 49043 Protection Section Nuclear Facilities Unit Mr. Oscar Limpias Constitution Hall, Lower-Level North Vice President, Engineering 525 West Allegan Street Entergy Nuclear Operations, Inc.

P.O. Box 30241 440 Hamilton Avenue Lansing, MI 48909-7741 White Plains, NY 10601 Michigan Department of Attorney General Mr. John F. McCann Special Litigation Division Director, Nuclear Safety & Licensing 525 West Ottawa St. Entergy Nuclear Operations, Inc.

Sixth Floor, G. Mennen Williams Building 440 Hamilton Avenue Lansing, MI 48913 White Plains, NY 10601 Mr. Michael R. Kansler Ms. Charlene D. Faison President & CEO/CNO Manager, Licensing Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. John T. Herron Sr. Vice President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 April 20, 2007

Palisades Nuclear Plant cc:

Mr. Ernest J. Harkness Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. William Dennis Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Joseph DeRoy Vice President, Operations Support Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Laurie A. Lahti, Manager, Licensing Regulatory Affairs Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 April 20, 2007

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION REQUESTS FOR RELIEF RR 4-1, RR 4-2, RR 4-3 (REVISION 1)

RR 4-4, RR 4-6, AND RR 4-7 PALISADES NUCLEAR PLANT ENTERGY NUCLEAR OPERATIONS, INC.

DOCKET NO. 50-255

1.0 INTRODUCTION

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed and evaluated the information provided by Nuclear Management Company, LLC (NMC, the licensee, at the time of submittal) in its letter dated June 12, 2006 (Agencywide Documents Access and Management System (ADAMS), Accession No. ML061710216), which proposed its Fourth 10-Year Interval Inservice Inspection Program Plan Requests for Relief (RRs) RR 4-1, RR 4-2, RR 4-3 (Revision 1), RR 4-4, RR 4-6, and RR 4-7 for Palisades Nuclear Plant (Palisades). The licensee provided additional information in its letter dated February 12, 2007 (ADAMS Accession No. ML070440187) and by email on March 28, 2007 (ADAMS Accession No. ML070870606). In its letter dated February 12, 2007, the licensee withdrew RR 4-4 and revised RR 4-3. RR 4-4 will not be discussed further in this safety evaluation (SE).

2.0 REGULATORY REQUIREMENTS Inservice inspection (ISI) of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, 2, and 3 components is performed in accordance with Section XI of the ASME Code and applicable addenda as required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(g), except where specific relief has been granted by the NRC pursuant to 10 CFR 50.55a(g)(6)(i). The regulation at 10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if: (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and ENCLOSURE

addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ASME Code of record for the Palisades fourth 10-year interval ISI program, which began on December 13, 2006, is the 2001 Edition with the 2003 Addenda of Section XI of the ASME Code.

3.0 EVALUATION RR 4-1 ASME Code Component Identification ASME Code Class 1 ASME Code,Section XI Reference IWB-2500 Table IWB-2500-1 ASME Code Examination Category B-A ASME Code Item Number B1.22 Component Description Reactor Pressure Vessel (RPV) Lower Head Meridional Welds: 1-113A at 0°, 1-113B at 60°,

1-113C at 120°, 1-113D at 180°, 1-113E at 240° and 1-113F at 300° ASME Code Requirement ASME Code,Section XI, Table IWB-2500-1, Category B-A, Item B1.22 requires a volumetric of essentially 100 percent of the accessible weld length of RPV welds 1-113A, 1-113B, 1-113C, 1-113D, 1-113E, and 1-113F.

Licensees Basis for Relief Request (As Stated)

The six (6) lower head meridional welds in the [RPV] are not fully accessible, such that 100 percent of the entire length of the weld volumes can not be achieved during an ultrasonic examination from inside of the [RPV] using remotely operated examination equipment. The limitation on the exam is caused by an internally installed flow ring, a permanent 360E attachment in the upper part of the lower head. The flow ring covers up to the top half of the meridional welds and prevents direct access for scanning.

Following are the coverages which were achieved during the past examination:

1. Meridional Weld 1-113A at 0° - 47%

2. Meridional Weld 1-113B at 60° - 53%

3. Meridional Weld 1-113C at 120° - 53%

4. Meridional Weld 1-113D at 180° - 47%

5. Meridional Weld 1-113E at 240° - 53%

6. Meridional Weld 1-113F at 300° - 53%

Two drawings1 are provided to support this relief request, the first drawing (232-113) is a copy from the vendor file and is the best available drawing to show the reactor vessel bottom head forming and welding.

The second drawing (Sketch NTD-MNA-DSD9515. Sheet 17 of 43) is taken from the Westinghouse final report to Palisades for the June 1995 reactor vessel examination.

This cross sectional drawing details the limitation created by the flow ring and the transducers which were used for the examination of these lower head welds.

Manual ultrasonic examination from the exterior of the vessel would not be feasible due to the large amount of dose required to set-up lighting, prep the examination areas, ultrasonically examine the portions of the weld which were inaccessible from the ID

[inside diameter], and demobilize from the area. The contact dose on the lower head is 2.5R[/HR] and the general dose levels in the room range from 1.5 to 2R[/HR]. The expected dose expended to complete this scope of work could easily exceed 20R[/HR].

The expected benefit of obtaining this data does not outweigh the consequences of exposing personnel to this cumulative dose.

Additionally, there were no indications in the portions of the weld which were examined from the ID using the mechanized tool.

Licensees Proposed Alternative Examination (As Stated)

The accessible weld volumes of each of the 6 identified meridional welds will be ultrasonically examined from the ID using remotely operated mechanized equipment during the performance of the reactor vessel examination.

NRC Staffs Evaluation The ASME Code requires a volumetric examination of essentially 100 percent of the accessible weld length of RPV lower head meridional welds 1-113A, 1-113B, 1-113C, 1-113D, 1-113E and 1-113F. As noted in the licensees proposed alternative, it will examine the accessible weld volumes of each of the 6 identified meridional welds. The ASME Code,Section XI, Table IWB-2500-1, Examination Category B-A, Item B1.22 specifically states a volumetric examination of essentially 100 percent of the accessible weld length of the subject welds will be performed. The ASME Code Committees, when writing the ASME Code, considered that when examining welds under the RPV it would be impractical to volumetrically examine essentially 100 percent of the weld length of the subject welds because depending on the type of reactor, there are support skirts, control rod drives, and instrumentation probes located under the reactor. Therefore, the NRC staff determined that the licensee will meet the ASME Code requirements and relief is not required for RPV lower head meridional welds 1-113A, 1-113B, 1-113C, 1-113D, 1-113E and 1-113F.

1. Drawing 232-113 and Sketch NTD-MNA-DSD9515. Sheet 17 of 43 are not included in this SE and may be found in the licensees submittal dated June 12, 2006.

RR 4-2 ASME Code Component Identification ASME Code Class 1 ASME Code Reference IWB-2500 Table IWB-2500-1 ASME Code Examination Category B-B and B-D Item Numbers B2.11, B2.21, B2.22, and B3.110 Component Description Pressurizer Upper Shell-to-Upper Head Weld 5-988 Pressurizer Lower Shell-to-Lower Head Weld 3-982 Pressurizer Lower Head Circumferential Weld 2-984 Lower Head Meridional Welds 1-984A through D Lower Head Nozzle-to-Shell Welds 1-986, 3-985, 8-986, and 8-986A through C ASME Code Requirement ASME Code,Section XI, Table IWB-2500-1 requires that the pressurizer upper shell-to-upper head weld 5-988, lower shell-to-lower head weld 3-982, lower head circumferential weld 2-984, meridional lower head welds 1-984A through D, and nozzle-to-shell welds 1-986, 3-985, 8-986, and 8-986A through C to be volumetrically examined essentiality 100 percent during each ISI interval.

Licensees Basis for Relief Request (As Stated)

Basis for Relief for Pressurizer Upper Shell-to-Upper Head Weld 5-988 and Lower Shell-to-Lower Head Weld 3-982 Volumetric examination of welds 5-988 and 3-982 as required to satisfy the examination region E-F-G-H (as referenced in [ASME Code, Section XI] Figure IWB-2500-1(b) will be limited due to the transition slope from the shell to the heads. Scanning distances are limited by the insulation support rings located on the shell side 7 inches from the centerline of the welds.

Percentage of the volumetric examination of the region E-F-G-H as referenced in

[ASME Code,Section XI,] Figure IWB-2500-1(B) will be as follows:

1. 0° scanning of region E-F-G-H will examine approximately 62 percent of the required volume.

2. Axial angle beam examinations with the beam direction from the head towards the shell will examine approximately 81 percent of the required volume.

3. Axial angle beam examinations with the beam direction from the shell towards the head will examine approximately 68 percent of the required volume.

4. The transverse scans with two angle beam directions in both the clockwise and the counter clockwise directions will obtain approximately 92 percent of the required examination volume E-F-G-H.

Basis for relief for the Pressurizer Lower Head Circumferential Weld 2-984 Due to the component design configuration with relation to the pressurizer heater penetrations in the lower head, weld 2-984 is totally inaccessible for any type of a volumetric or surface examination. This weld is located inside the lower support skirt and lies between the second and third rows of heater penetrations.

The location of the support skirt which is welded to the head near the edge of weld 2-984 does not allow access from the upper side of the weld. Due to the spacing of the heater penetrations, at approximately 4 inches apart, and the angle of each penetration through the lower head, examination from the bottom of the weld towards the upper side is not possible. Therefore, no examinations are planned for this weld other than VT-2 system leakage tests.

Basis for Relief for Pressurizer Meridional Lower Head Welds 1-984A through D Approximately 75 percent of the lower head meridional welds 1-984A through D are totally inaccessible due to the support skirt, the skirt bracket assembly and the heater penetrations.

Approximately 9 to 10 inches of the lower head meridional welds are accessible from the centerline of the lower shell to the lower head weld (3-982) down to the welded support skirt. This accessible area represents 25 percent of the total weld length for each weld.

Of this accessible 25 percent of total weld length, the total volumetric examination of region E-F-G-H as referenced in [ASME Code,Section XI,] Figure IWB-2500-3 will be 100 percent for all required scans. Therefore, this volume on all four lower meridional welds will be examined in lieu of the code required 100 percent examination of one weld length.

Basis for Relief for Spray Line Nozzle-to-Upper Head Weld 1-986 Weld 1-986 is the 4 inch spray line nozzle to upper head weld. Based on previous examination data and a thorough review of the design drawings, it has been determined that examination of this weld is limited. The limitation is due to nozzle 7-986 in the scanning area from the head side. This limitation will result in a loss of accessible examination length of 8.7 inches or approximately 24 percent of the total length of the weld.

Approximately 84 percent of the total required examination volumes for the regions outlined in [ASME Code,Section XI,] Figure IWB-2500-7(a) can be achieved with angle

beam direction from the head side towards the nozzle. This takes into account the volumes that can be examined within the 8.7 inch limitation area.

Total required examination volumes that can be obtained with the 0° scan will equal approximately 54 percent due to the configuration of the weld and the nozzle.

Transverse scan of the total required exam volumes with two angle beams in both the clockwise and the counter clockwise directions will equal approximately 81 percent of the required volume.

Due to the configuration, no examinations can be performed from the nozzle side towards the head.

Basis for Relief for Spray Line Nozzle-to-Upper Head Weld 3-985 Weld 3-985, is the 12-inch surge line nozzle to lower head weld. Based on previous examination data and a thorough review of the design drawings, it has been determined that examination of this weld is limited. The limitation is due to the design configuration and the inability to scan three locations of the weld due to insulation studs welded at the toe of the weld.

The insulation studs result in a loss of approximately 7 percent of the scanning surface when scanning from the head side towards the nozzle. The 93 percent of the accessible examination area will be volumetrically examined from the head side towards the nozzle and will result in 100 percent examination of regions C-D-E-F and B-C-F-G and 84 percent of region A-B-G-H-I as referenced in [ASME Code,Section XI,] Figure IWB-2500-7(a).

The volumetric examination of region A-B-G-H-I from the nozzle side will examine approximately 34 percent, approximately 5 percent of region B-C-F-G will be examined in this direction and approximately 25 percent of exam volume C-D-E-F will be examined in this direction.

The total required examination volume of regions referenced in [ASME Code,Section XI,]

Figure IWB-2500-7(a) with the transverse scan of weld 3-985 will equal 84 percent with two angle beams in both the clockwise and counterclockwise directions.

Basis for Relief for Nozzle-to-Head Welds 8-986 and 8-986A, B, and C Weld 8-986 is the PORV [power operated relief valve] outlet nozzle-to-upper head weld, and weld[s] 8-986A, B, [and] C are the ASME Code safety nozzle-to-head welds. Volumetric examination of these welds will be limited due the design configuration of the head and other limitations described below. The following discussion is applicable to all four welds.

The 0° scan is limited to 10 percent of the total required examination volume in the attachment weld region (B-C-F-G) and the nozzle cylinder region (A-B-G-H-I). In the adjoining region (C-D-E-F) the required examination volume for the 0° scan will be 81 percent due to the limitations produced by insulation studs welded in the area of interest and by the interference of the adjacent nozzles.

Based on a review of the drawings and past examination data, the angle beam scans from the head side towards the nozzle will allow examination of 81 percent of the examination regions identified on [ASME Code,Section XI,] Figure IWB-2500-7(a). This takes into account the configuration and scanning limitations caused by the insulation studs and the proximity of the other nozzles.

Transverse scans with two angle scanning in both the clockwise and counter clockwise directions will examine 81 percent of the required volume in the regions referenced in

[ASME Code,Section XI,] Figure IWB-2500-7(a).

Volumetric examination from the nozzle side is limited in all cases and results in examination of 10 percent of the required volumes.

Summary of Weld Coverage for RR 4-2 Welds Axial Scans Transverse Scans Surface Exams 5-988 68% of the required 92% of the required None required per ASME Code Volume Volume Section XI 3-982 68% of the required 92% of the required None required per ASME Code Volume Volume Section XI 2-984 0% of the required 0% of the required None required per ASME Code Volume Volume Section XI 1-984A 25% of accessible 25% of accessible None required per ASME Code Length Length Section XI 1-984B 25% of accessible 25% of accessible None required per ASME Code Length Length Section XI 1-984C 25% of accessible 25% of accessible None required per ASME Code Length Length Section XI 1-984D 25% of accessible 25% of accessible None required per ASME Code Length Length Section XI 1-986 84% of the required 81% of the required None required per ASME Code Volume Volume Section XI 3-985 5% of the required 84% of the required None required per ASME Code Volume Volume Section XI 8-986 10% of the required 81% of the required None required per ASME Code Volume Volume Section XI 8-986A 10% of the required 81% of the required None required per ASME Code Volume Volume Section XI 8-986B 10% of the required 81% of the required None required per ASME Code Volume Volume Section XI 8-986C 10% of the required 81% of the required None required per ASME Code Volume Volume Section XI Licensees Proposed Alternative Examination (As Stated)

The accessible volumes as identified above will be examined in lieu of the 100 percent volumetric requirements.

NRC Staff Evaluation

The ASME Code,Section XI, Table IWB-2500-1 requires that the pressurizer upper shell-to-upper head weld 5-988, lower shell-to-lower head weld 3-982, lower head circumferential weld 2-984, meridional lower head welds 1-984A through D, surge line nozzle-to-lower head weld 3-985, and nozzle-to-shell welds 1-986, 8-986, and 8-986A through C to be volumetrically examined essentiality 100 percent during each ISI interval.

For pressurizer upper shell-to-upper head weld 5-988 and lower shell-to-lower head weld 3-982, the volumetric examinations are limited by the transition slope of the shell-to-head configuration. The examination is also limited by the insulation support rings located on the shell side 7 inches from the centerline of the welds. From drawings and the description of the basis for the relief provided by the licensee, the NRC staff determined that the ASME Code requirements are impractical. In order for the licensee to perform the ASME Code-required examination, the subject components would be required to be redesigned and that would cause a burden on the licensee.

For pressurizer upper shell-to-upper head weld 5-988, the licensee inspected 68 percent of the required volume with an axial scan and 92 percent of the weld volume with a transverse scan.

For the lower shell-to-lower head weld 3-982, the licensee inspected 68 percent of the required volume with a axial scan and 92 percent of the weld volume with a transverse scan. The NRC staff determined that the proposed coverage will provide reasonable assurance of structural integrity of the pressurizer upper shell-to-upper head weld 5-988 and lower shell-to-lower head weld 3-982.

The licensee noted that because of the design configuration of the pressurizer lower head circumferential weld 2-984 (its close proximity to the pressurizer heater penetrations in the lower head, its being located inside the lower support skirt, and its lying between the second and third rows of heater penetrations weld 2-984) it is inaccessible for examination. The support skirt is welded to the head near the edge of weld 2-984 and does not permit access from the upper side of the weld. The spacing of the heater penetrations, (approximately 4 inches apart), and the angle of each penetration through the lower head makes examination from the bottom of the weld towards the upper side impossible.

The licensee proposed to perform a VT-2 visual examination in lieu of the ASME Code requirements. Based on the drawings and the basis provided by the licensee, the NRC staff determined that in order for the licensee to perform the ASME Code-required examinations the subject components would be required to be redesigned and that would be a burden on the licensee. Therefore, the NRC staff determined that the ASME Code requirements are impractical.

The NRC staff determined that, based on examinations of other pressurizer vessel welds and ASME Code-required leakage tests on shutdown and start up, the licensees proposed alternative to perform a VT-2 visual examination will provide reasonable assurance of leak tightness of pressurizer lower head circumferential weld 2-984.

Pressurizer lower head meridional welds 1-984A through D are inaccessible because the support skirt, the skirt bracket assembly and the heater penetrations prevent the licensee from

performing an examination of approximately 75 percent of the subject welds. Nine to ten inches of the lower head meridional welds are accessible from the centerline of the lower shell to the lower head weld (3-982) down to the welded support skirt. This accessible area represents 25 percent of the total weld length for each weld. Based on the drawings and basis provided by the licensee, the NRC staff determined that the ASME Code requirements are impractical. In order for the licensee to perform the ASME Code required examinations, the subject components would have to be redesigned and would cause a burden on the licensee.

The licensee proposed that all of the accessible weld length of the pressurizer lower head meridional welds 1-984A through D will be examined for all required scans. Therefore, the accessible volume of 25 percent of each of the four pressurizer lower head meridional welds will be examined in lieu of the ASME Code-required 100 percent examination of the total weld length of each weld. Based on the proposed examination, other volumetric examinations of the pressurizer shell welds, and ASME Code VT-2 visual examinations, the NRC staff determined that the licensees inspections will provide reasonable assurance of structural integrity of the subject welds.

For the pressurizer 4-inch spray line nozzle-to-upper head weld 1-986, the ASME Code examination is limited by nozzle 7-986 which is in the scanning area from the head side. The limitation results in a loss of accessible examination length of approximately 24 percent of the total length of the weld. Based on the configuration, the licensee determined that no examinations can be performed from the nozzle side towards the head. Based on the drawings and basis provided by the licensee, the NRC staff determined that the ASME Code requirements are impractical. In order for the licensee to perform the ASME Code-required examinations, the subject components would be required to be redesigned and that it would be a burden on the licensee.

The licensee noted that it would be able to inspect approximately 84 percent of the total required examination volumes with an angle beam direction from the head side towards the nozzle. This takes into account the volumes that can be examined within the 8.7 inch limitation area. The licensee noted that the total required examination volumes that can be obtained with the 0° scan will equal approximately 54 percent, and the transverse scan of the total required exam volumes with two angle beams in both the clockwise and the counter-clockwise directions will equal approximately 81 percent of the required volume. Based on the proposed examination, other volumetric examinations of the pressurizer shell welds, and ASME Code VT-2 visual examinations, the NRC staff determined that the licensees inspections will provide reasonable assurance of structural integrity of the subject welds. Furthermore, based on the coverage the licensee will be able to obtain, if significant service-induced degradation were occurring, there is reasonable assurance that evidence of it would be detected by the examinations.

For the pressurizer 12-inch surge line nozzle-to-lower head weld 3-985, the ASME Code-required examination is limited because the insulation studs welded at the toe of the weld prevents the ability to scan three locations of the subject weld. From drawings and the basis for the relief provided by the licensee, the NRC staff determined that the ASME Code requirements are impractical. In order for the licensee to perform the ASME Code-required, examination, the subject components would be required to be redesigned and would cause a burden on the licensee.

The licensee noted it will not be able to inspect approximately 7 percent of the surface when scanning from the head side towards the nozzle. Ninety-three percent of the accessible examination area will be volumetrically examined from the head side towards the nozzle and will result in 100 percent examination of regions C-D-E-F and B-C-F-G and 84 percent of region A-B-G-H-I as referenced in ASME Code,Section XI, Figure IWB-2500-7(a). Based on the proposed examination, other volumetric examinations of the pressurizer shell welds, and ASME Code VT-2 visual examinations, the NRC staff determined that the licensees inspections will provide reasonable assurance of structural integrity of the subject welds. Furthermore, based on the coverage the licensee will be able to obtain, if significant service-induced degradation were occurring, there is reasonable assurance that evidence of it would be detected by the examination.

For weld 8-986 and welds 8-986 A, B, C, volumetric examination will be limited due the design configuration of the head and other limitations described below. The licensee noted that the 0° scan is limited to 10 percent of the total required examination volume in the attachment weld region (B-C-F-G) and the nozzle cylinder region (A-B-G-H-I). In the adjoining region (C-D-E-F),

the required examination volume for the 0° scan will be 81 percent due to the limitations produced by insulation studs welded in the area of interest and by the interference of the adjacent nozzles. Furthermore, based on the review of drawings and past examination data, the licensee found that the angle beam scans from the head side towards the nozzle will allow examination of 81 percent of the examination regions identified on ASME Code,Section XI, Figure IWB-2500-7(a). This also takes into account the configuration and scanning limitations caused by the insulation studs and the proximity of the other nozzles. For the transverse scans with two angle scanning in both the clockwise and counter-clockwise directions, the licensee will be able to examine 81 percent of the required volume in the regions referenced in ASME Code,Section XI, Figure IWB-2500-7(a). The licensee will only be able to obtain 10 percent coverage during the volumetric examination from the nozzle side as it is limited in all cases.

Based on the drawings and basis provided by the licensee, the NRC staff determined that the ASME Code requirements are impractical. In order for the licensee to perform the ASME Code-required examinations, the subject components would be required to be redesigned and would be a burden on the licensee. The NRC staff determined that, based on the proposed examination volume, other volumetric examinations of the pressurizer welds, and ASME Code VT-2 visual examinations, the licensees inspections will provide reasonable assurance of structural integrity of the subject welds. Furthermore, based on the coverage the licensee will be able to obtain if significant service-induced degradation were occurring, there is reasonable assurance that evidence of it would be detected by the examination.

RR 4-3, Revision 1 ASME Code Component Identification Code Class 1 Code Reference IWB-2500 Table IWB-2500-1 Examination Category B-D

Item Number B3.130 Component Description Steam Generator Nozzle-to-Shell Welds, 1-104-251, 1-102-251A, 1-102-251B, 2-104-351, 2-102-351A, 2-102-351B ASME Code Requirements ASME Code,Section XI, Table IWB-2500-1 requires all nozzle-to-vessel welds to be 100 percent volumetrically examined once during each inspection interval in accordance with Figure IWB-2500-7(a).

Licensees Basis for Relief Request (As Stated)

In accordance with 10 CFR 50.55a(g)(5)(iii), [NMC] requests approval to implement examination on the accessible volumes as identified below in lieu of the 100 percent volumetric requirements at Palisades Nuclear Plant. The impracticality of compliance is that in order to obtain the required examination volume, the components would require modification or replacement.

For purposes of discussion, Figure 1WB-2500-7(a) (attached2) will be used to describe the four required weld volumes. With the exception of the nozzle inner radius section, this figure is the closest configuration to our actual nozzles.

Palisades working with EPRI [Electric Power Research Institute] have developed the attached package (See Attachment 22). The attached information is an excerpt from the EPRI report and is intended to identify the exam volumes within the areas of limitations.

The final EPRI report [Palisades Steam Generator Inlet and Outlet Nozzle Coverage Calculations dated September 5, 1996,] will identify exam volumes within the area of limitations (attached information), exam volumes where no limitations exist and the composite exam volumes. The final composite exam volumes will be slightly higher since this will include the areas where no limitations exist. However, the code required exam volume will not be achieved and this relief request is necessary.

There are 2 acronyms used in the EPRI report for identification, they are Consumers Power - Steam Generator Project Inlet Nozzle (CP-SGPIN) and Consumers Power -

Steam Generator Project Outlet Nozzles (CP-SGPON).

The computer-based modeling was performed on one steam generator, and this is intended to address all primary head nozzle welds in both steam generators. The steam generators are identical in design.

The probe skew angle for the axial exams are identified as 0° and 180° within the coverage tables. The probe skew angle for the transverse exams were modeled using a 90° and then offset using a 70° and 110° skew to increase exam volume coverages.

In summary, the examination volumes are limited and the maximum achievable volumes within the areas of limitations are accurately identified. A relief request from the code

2. Figure 1WB-2500-7(a) and the EPRI report in Attachment 2 are not included in this SE and may be found in the licensees submittal dated June 12, 2006.

required examination volumes is necessary. The final EPRI report is on file at Palisades. The alternative of using the EPRI report exam volumes, regarding the subject steam generator nozzle-to-shell weld examination coverage, should detect significant patterns of degradation and provide reasonable assurance of continued structural integrity.

Licensees Proposed Alternative Examination (As Stated)

All accessible weld volumes will be examined once per interval in lieu of the 100 percent volumetric examination requirements.

Summary of Weld Coverage for RR 4-3 Welds Axial Scans Transverse Scans Surface Exams 1-104-251 79% of the required 42% of the required None required per ASME volume* volume Code Section XI 2-104-351 79% of the required 42% of the required None required per ASME volume* volume Code Section XI 1-102-251A 74% of the required 22% of the required None required per ASME volume* volume Code Section XI 1-102-251B 74% of the required 22% of the required None required per ASME volume* volume Code Section XI 2-102-351A 74% of the required 22% of the required None required per ASME volume* volume Code Section XI 2-102-351B 74% of the required 22% of the required None required per ASME volume* volume Code Section XI

• from head side only with no beam angles crossing based on material being carbon steel with stainless steel inside diameter cladding which does not allow a full V examination.

NRC Staff Evaluation

The ASME Code requires all nozzle-to-vessel welds to be 100 percent volumetrically examined in accordance with Figure IWB-2500-7(a). The licensee was unable to obtain the ASME Code-required examination volume and has requested relief from the ASME Code requirements. For steam generator nozzle-to-shell welds 1-104-251, 1-102-251A, 1-102-251B, 2-104-351, 2-102-351A, and 2-102-351B, the licensee was unable to obtain the ASME Code-required examination volume because of the configuration of the subject nozzles. The NRC staff determined that in order for the licensee to perform the ASME Code-required examinations the subject nozzles would have to be redesigned and that would cause a burden on the licensee. Therefore, the NRC staff determined that the ASME Code requirements are impractical.

The licensee noted that it worked with EPRI to develop a report to identify the examination volumes within the areas of limitations. The licensee further noted that the final EPRI report will identify examination volumes within the area of limitations, exam volumes where no limitations exist and the composite examination volumes. The final composite examination volumes will be

slightly higher since this will include the areas where no limitations exist. Computer-based modeling was performed on one steam generator to address all primary head nozzle welds in both steam generators. The steam generators are identical in design. In the EPRI report, it was noted that the probe skew angle for the axial examinations are identified as 0° and 180° within the coverage tables. The probe skew angle for the transverse examinations were modeled using a 90° and then offset using a 70° and 110° skew to increase examination volume coverages. In the axial scans, the licensee obtained 79 percent, 79 percent, 74 percent, 74 percent, 74 percent, and 74 percent, and in the transverse scans the licensee obtained 42 percent, 42 percent, 22 percent, 22 percent, 22 percent, and 22 percent for steam generator nozzle-to-shell welds, 1-104-251, 2-104-351, 1-102-251A, 1-102-251B, 2-102-351A, and 2-102-351B, respectively. Based on the proposed examination volume of the welds, and ASME Code VT-2 visual examinations, the NRC staff determined that the licensees inspections will provide reasonable assurance of structural integrity of the steam generator nozzle-to-shell welds 1-104-251, 1-102-251A, 1-102-251B, 2-104-351, 2-102-351A, and 2-102-351B.

Furthermore, based on the coverage there is reasonable assurance that the licensee will be able to obtain any significant service-induced degradation, and it would be detected by the examination.

RR 4-6 ASME Code Component Identification Code Class 2 Code Reference IWC-2500 Table IWC-2500-1 Examination Category C-A Item Number C1.10 Component Description Steam Generator Upper Shell-to-Shell Cone Welds, 1-101-221 and 2-101-221 ASME Code Requirement ASME Code,Section XI, Table IWC-2500-1 requires a volumetric examination of welds at gross structural discontinuities which includes essentially 100 percent of the weld length.

Licensees Basis for Relief Request (As Stated)

In accordance with 10 CFR 50.55a(a)(3)(ii), [NMC] requests approval to implement examination on the accessible volumes as identified below in lieu of the 100 percent volumetric requirements at Palisades Nuclear Plant.

Based on examination data obtained during the preservice ultrasonic examinations which were performed on the new steam generators in 1990, there are approximately 171 inches of documented limitations on the upper shell. These limitations are caused

by welded patches, snubber attachments and the 18-inch feedwater nozzles. The limitations are shown on drawings M1-F-AA Sh. 104 and M1-F-AA Sh. 743.

The axial angle beam scan from shell cone with the beam direction towards the upper shell will allow approximately 77 percent of the required volume E-F-G-H as noted on

[ASME Code,] Figure IWC-2500-1. Also, there is a 2 percent loss of coverage area in the required volume due to the configuration of the shell cone. This configuration causes an abrupt transition to exist in the examination area which results in a loss of contact as the exit point of the transducer travels across this point. This condition exists for the entire circumference of the weld. The 2 percent loss of exam volume of area E-F-G-H exists from either the shell side or the cone side. The total examination volume of area E-F-G-H, when scanning from the shell cone side is approximately 75 percent.

The examination volume with the angle beam direction going from the upper shell towards the shell cone is equal to 98 percent of the required volume E-F-G-H as referenced in [ASME Code,] Figure IWC-2500-1. The transverse scans of the weld are not limited.

The total examination volume of region E-F-G-H, with axial crossing beams is limited to approximately 75 percent.

Licensees Proposed Alternative Examination (As Stated)

The accessible weld volumes as identified above will be examined in lieu of the 100 percent volumetric examination requirements.

Summary of Weld Coverage for RR 4-6 Welds Axial Scans Transverse Scans Surface Exams 1-101-221 75% of the required 100% of the required None required per ASME volume volume Code Section XI 2-101-221 75% of the required 100% of the required None required per ASME volume volume Code Section XI

NRC Staff Evaluation

ASME Code,Section XI, Table IWC-2500-1 requires a volumetric examination of essentially 100 percent of the weld length of the steam generator upper shell-to-shell cone welds. The licensee requested approval to implement examinations on the accessible volumes of the steam generator upper shell-to-shell cone welds 1-101-221 and 2-101-221 in lieu of the ASME Code 100 percent volumetric examinations requirements.

The licensee is unable to perform the ASME Code examinations because of limitations caused by welded patches, snubber attachments and the 18-inch feedwater nozzles. Based on the drawings and description of the difficulties provided by the licensee, the NRC staff determined that the ASME Code requirements are impractical and to require the licensee to perform the ASME Code examinations, would be a burden on the licensee because the subject components would have to be redesigned.

3. Drawings M1-F-AA Sh.104 and M1-F-AA Sh. 74 are not included in this SE and may be found in the licensees submittal dated June 12, 2006.

The licensee noted that the axial angle beam scan from shell cone with the beam direction towards the upper shell will allow approximately 77 percent of the required volume E-F-G-H (as noted on ASME Code,Section XI, Figure IWC-2500-1) to be examined. Also, there is a 2 percent loss of coverage area in the required volume due to the configuration of the shell cone. The configuration of the subject components causes an abrupt transition to exist in the examination area which results in lift off of the transducer as the exit point of the signal travels across this point. This condition exists for the entire circumference of the weld. The 2 percent loss of examination volume of area E-F-G-H exists from either the shell side or the cone side.

The total examination volume of area E-F-G-H, when scanning from the shell cone side is approximately 75 percent.

The licensee obtained an examination volume equal to 98 percent of the required volume E-F-G-H as referenced in ASME Code,Section XI, Figure IWC-2500-1. The licensee obtained the subject coverage in the angle beam direction going from the upper shell towards the shell cone.

The licensee noted that the transverse scans of the weld are not limited and the total examination volume of region E-F-G-H, with axial crossing beams is limited to approximately 75 percent. If significant service-induced degradation were occurring, there is reasonable assurance that evidence of it would be detected by the examination. Furthermore, the ASME Code system leakage tests performed each outage with VT-2 visual examinations, and the plants leakage monitoring system provides additional assurance of leak tightness of the steam generator upper shell-to-shell cone welds 1-101-221 and 2-101-221. Furthermore, based on the coverage there is reasonable assurance that the licensee will be able to obtain any significant service-induced degradation, and it would be detected by the examination.

RR 4-7 ASME Code Component Identification Code Class 2 Code Reference IWC-2500 Table IWC-2500-1 Examination Categories C-A, C-B Item Numbers C1.10, C1.30, and C2.21 Component Description Shutdown Cooling Heat Exchanger E-60B Shell-to-Flange Weld E-60B-01, Tubesheet-to-Shell Weld E-60B-02, Nozzle-to-Shell Welds E-60B-03 & 04 ASME Code Requirements ASME Code,Section XI, Table IWC-2500-1 requires all Category C-A welds to be 100 percent volumetrically examined during each inspection interval and Category C-B, Item Number C2.21 welds to be examined 100 percent by surface and volumetric techniques each inspection interval.

Licensees Basis for Relief Request for Weld E-60B-01 (As Stated)

In accordance with 10 CFR 50.55a(a)(3)(ii), [NMC] requests approval to implement examination on the accessible volumes as identified below in lieu of the 100 percent volumetric requirements at Palisades Nuclear Plant.

Weld E-60B-01 is a flange to primary shell weld and is a [ASME Code] Category C-A, Item Number C1.10 [weld]. Volumetric examination of exam volume A-B-C-D as referenced in Figure IWC-2500-1 (a) is limited due to configuration and scanning limitations created by the flange bolting being in the area of interest and by the flange to weld distance.

Upon review of the referenced drawings and previous examination data, the following examination volumes can be achieved:

1. The 45° angle beam examination from the vessel side towards the flange will allow examination of approximately 91 percent of the required volume A-B-C-D.

The 45° angle beam examination from the flange side towards the vessel will allow examination of approximately 60 percent of the required volume.

2. The 60° angle beam from the vessel side towards the flange will allow examination of approximately 95 percent of the required volume A-B-C-D. The 60° angle beam scanning from the flange side towards the vessel will examine approximately 43 percent of the required volume.

3. The transverse scans with two angle beam directions in both the clockwise and the counter-clockwise directions will obtain 94 percent of the required examination volume A-B-C-D.

4. The 0° scan of the required examination volume will obtain 96 percent of the required examination volume A-B-C-D.

Basis for Relief for Weld E-60B-02 (As Stated)

Weld E-60B-02 is the primary shell-to-tubesheet weld and is a [ASME Code] Category C-A, Item Number C1.30 [weld]. Volumetric examination of exam volume E-F-G-H as referenced in [ASME Code] Figure IWC-2500-2 is limited due to the design configuration.

Upon review of the referenced drawings and previous examination data, the following examination volumes can be achieved:

1. The 60° angle beam examination from the shell side towards the tubesheet will allow examination of approximately 96 percent of the required volume E-F-G-H.

The 60° angle beam examination from the tubesheet towards the shell will allow examination of approximately 61 percent of the required volume.

2. The 45E angle beam from the shell side towards the tubesheet will allow examination of approximately 92 percent of the required volume E-F-G-H. The 45E angle beam scanning from the tubesheet side towards the shell will examine approximately 32 percent of the required volume.

3. The transverse scans with two angle beam directions in both the clockwise and the counter-clockwise directions will obtain 92 percent of the required examination volume E-F-G-H.

4. The 0E scan of the required examination volume will obtain 96 percent of the required examination volume E-F-G-H.

Basis for Relief for Weld E-60B-03 and E-60B-04 (As Stated)

Welds E-60B-03 and E-60B-04 are the primary shell inlet and outlet nozzle-to-shell welds and are [ASME Code,] Category C-B, Item Number C2.21 [welds]. Volumetric examination of exam volume C-D-E-F as referenced in [ASME Code,] Figure IWC-2500-4(b), is limited due to the design configuration. Upon review of the referenced drawings and previous examination data, the following examination volumes can be achieved:

1. The 45° angle beam examination from the shell side towards the nozzle will allow examination of approximately 98 percent of the required volume C-D-E-F. The 45° angle beam examination from the nozzle towards the shell cannot be performed due to the design configuration.

2. The 60° angle beam from the shell side towards the nozzle will allow examination of 100 percent of the required volume C-D-E-F. The 60° angle beam examination from the nozzle towards the shell can not be performed due to the design configuration.

3. The transverse scans with two angle beam directions in both the clockwise and the counter clockwise directions will obtain 60 percent of the required examination volume C-D-E-F.

4. The 0° scan of the required examination volume will obtain 33 percent of the required examination volume C-D-E-F.

Licensees Proposed Alternative Examination (As Stated)

The accessible volumes as identified above will be examined in lieu of the 100 percent volumetric requirements.

Summary of Weld Coverage for RR 4-7 Welds Axial Scans Transverse Scans Surface Exams E-60B-01 43% of the required 94% of the required None required per ASME volume* volume Code Section XI E-60B-02 32% of the required 92% of the required None required per ASME volume* volume Code Section XI E-60B-03 98% of the required 60% of the required 100% of the required volume* volume surface with no indications E-60B-04 98% of the required 60% of the required 100% of the required volume* volume surface and one 1/8-inch rounded indication

• from head side only with no beam angles crossing based on material being carbon steel with stainless steel inside diameter cladding which does not allow a full V examination.

NRC Staff Evaluation

The ASME Code requires that essentially 100 percent of the weld length of all Category C-A welds be volumetrically examined each inspection interval and essentially 100 percent of the weld length of all Category C-B welds, Item Number C2.21 welds be examined by surface and volumetric techniques during each inspection interval. The licensee requested approval to implement examinations on the accessible volumes of the shutdown cooling heat exchanger E-60B shell-to-flange weld E-60B-01, tube sheet-to-shell weld E-60B-02, and nozzle-to-shell welds E-60B-03 & 04.

Shutdown Cooling Heat Exchanger E-60B Shell-To-Flange Weld E-60B-01 The licensee is unable to perform the ASME Code examinations for shell-to-flange weld E-60B-01 because of limitations caused by the configuration of the subject component, scanning limitations created by the flange bolting being in the examination area and by the flange to weld distance. Based on the drawings and description of the difficulties provided by the licensee, the NRC staff determined that the ASME Code requirements are impractical and to require the licensee to perform the ASME Code examinations would be a burden on the licensee because the subject components would have to be redesigned.

The licensee noted that with a 45° angle beam examination from the vessel side towards the flange they can examine approximately 91 percent of the required volume. The 45° angle beam examination from the flange side towards the vessel will allow examination of approximately 60 percent of the required volume. In addition, the 60° angle beam from the vessel side towards the flange will allow them to examine approximately 95 percent of the required weld volume. The licensee also noted that the 60° angle beam scan from the flange side towards the vessel will allow them to examine approximately 43 percent of the required volume. With the transverse scans with two angle beam directions in both the clockwise and the counter-clockwise directions, the licensee will be able to obtain 94 percent of the required examination volume.

Based on the examinations that will be performed by the licensee of the subject welds, if significant service-induced degradation were occurring, there is reasonable assurance that evidence of it would be detected by the examination. Furthermore, the ASME Code system leakage tests performed each outage with VT-2 visual examinations and the plants leakage monitoring system provide additional assurance of leak tightness of the shell-to-flange weld E-60B-01.

Shutdown Cooling Heat Exchanger E-60B Shell-To-Tubesheet Weld E-60B-02 The licensee is unable to perform the ASME Code volumetric examination for primary shutdown cooling heat exchanger E-60B shell-to-tubesheet weld E-60B-02. The ASME Code-required volumetric examination is limited because of the configuration of the subject component.

Based on the drawings and description of the difficulties provided by the licensee, the NRC staff determined that the ASME Code requirements are impractical and to require the licensee to perform the ASME Code examinations would be a burden on the licensee because the subject components would be have to be redesigned.

The licensee determined that a 60° angle beam examination from the shell side towards the tubesheet can examine approximately 96 percent of the ASME Code-required volume. The licensee also noted that with the 60° angle beam examination from the tubesheet towards the shell will allow examination of approximately 61 percent of the required volume. With a 45E angle beam from the shell side towards the tubesheet, the licensee will be able to obtain an examination of approximately 92 percent of the required volume. In addition, with the 45E angle beam scanning from the tubesheet side towards the shell, the licensee will be able to examine approximately 32 percent of the required volume. For the transverse scans with two angle beam directions in both the clockwise and counter-clockwise directions, the licensee will be able to inspect 92 percent of the required examination volume.

Based on the examinations that will be performed by the licensee of the subject welds, if significant service-induced degradation were occurring, there is reasonable assurance that evidence of it would be detected by the examinations. Furthermore, the ASME Code system leakage tests performed each outage with VT-2 visual examinations and the plants leakage monitoring system provides additional assurance of leak tightness of the primary shutdown cooling heat exchanger E-60B shell-to-tubesheet weld E-60B-02.

Shutdown Cooling Heat Exchanger Inlet and Outlet Nozzle-To-Shell Welds E-60B-03 and E-60B-04 The licensee is unable to perform the ASME Code-required volumetric examination of the primary shell inlet and outlet nozzle-to-shell welds E-60B-03 and E-60B-04. The ASME Code-required volumetric examinations are limited because of the configuration of the subject components. Based on the drawings and description of the difficulties provided by the licensee, the NRC staff determined that the ASME Code requirements are impractical and to require the licensee to perform the ASME Code examinations would be a burden on the licensee because the subject components would have to be redesigned.

The licensee noted that a 45° angle beam examination from the shell side towards the nozzle will allow an examination of approximately 98 percent of the required volume. It was further noted by the licensee that the 45° angle beam examination from the nozzle towards the shell,

cannot be performed due to the design configuration. For the 60° angle beam from the shell side towards the nozzle, the licensee will be able to obtain an examination of 100 percent of the required ASME Code volume. However, with the 60° angle beam examination from the nozzle towards the shell, the licensee cannot perform the ASME Code examination because of the design configuration of the subject components. In the transverse scans with two angle beam directions in both the clockwise and counter-clockwise directions the licensee will be able to inspect 60 percent of the ASME Code required examination volume.

Based on the examinations that will be performed by the licensee of the subject welds, if significant service-induced degradation were occurring, there is reasonable assurance that evidence of it would be detected by the examinations. Furthermore, the ASME Code system leakage tests performed each outage with VT-2 visual examination and the plants leakage monitoring system provide additional assurance of leak tightness of the primary shell inlet and outlet nozzle-to-shell welds E-60B-03 and E-60B-04.

NRC Staff Conclusions The NRC staff has reviewed the licensee's submittal and concludes that ASME Code examination coverage requirements are impractical for the subject welds listed in Request for Relief Nos. RR 4-2, RR 4-3 (Revision 1), RR 4-6, and RR 4-7 for Palisades. Furthermore, based on the coverages obtained, if significant service-induced degradation were occurring, there is reasonable assurance that evidence of it would be detected by the examinations that were performed and that the examinations performed provide reasonable assurance of structural integrity of the subject welds. Therefore, for Request for Relief Nos. RR 4-2, RR 4-3, Revision 1, RR 4-6, and RR 4-7, relief is granted, pursuant to 10 CFR 50.55a(g)(6)(i), for the Palisades fourth 10-year ISI interval. While the submittal requested relief pursuant to 10 CFR 50.55a(a)(3)(ii) for RR 4-2, RR 4-6, and RR 4-7, and 10 CFR 50.55a(g)(5)(iii) for RR 4-3 (Revision 1), the NRC staff has determined, based on the licensees submittal, that granting relief pursuant to 10 CFR 50.55a(g)(6)(i) is more applicable for RR 4-2, RR 4-3 (Revision 1),

RR 4-6, and RR 4-7 because the relief is necessary due to an impracticality rather then a hardship.

For Request for Relief No. RR 4-1, the NRC staff concluded that the licensee will meet the ASME Code requirements and relief is not required.

The NRC staff has determined that granting relief pursuant to 10 CFR 50.55a(g)(6)(i) for Request for Relief Nos. RR 4-2, RR 4-3, Revision 1, RR 4-6, and RR 4-7 is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable, including third-party review by the authorized Nuclear Inservice Inspector.

Principal Contributor: T. McLellan Date: May 18, 2007