SBK-L-11164, End of Second 10-Year ISI Interval Relief Requests for Examinations with Limited Coverage

End of Second 10-Year ISI Interval Relief Requests for Examinations with Limited Coverage

ML11234A185
Person / Time
Site:	Seabrook
Issue date:	08/17/2011
From:	Freeman P NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-11164
Download: ML11234A185 (44)

Text

NExTeram ENERGYf ,

August 17, 2011 SBK-L- 11164 Docket No. 50-443 U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 Seabrook Station End of Second 10-Year ISI Interval Relief Requests For Examinations With Limited Coverage NextEra Energy Seabrook, LLC (NextEra) concluded its second ten-year inservice inspection program on August 18, 2010. During this interval, components identified in Attachments 1 through 4 received less than the required examination coverage. Therefore, pursuant to 10 CFR 50.55a(g)(5)(iii), NextEra requests relief on the basis that the required examination coverage is impractical due to physical obstructions and limitations imposed by design or geometry.

Attachments 1 through 4 contain relief requests and the basis for these requests. The relief requests are specifically identified as 21R-17, 21R-18, 2IR-19 and 21iR-20.

If you have any questions regarding this submittal, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.

Sincerely, NextEra Energy Seabrook, LLC Al'lFrean Seied Site Vice President NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

U.S. Nuclear Regulatory Commission SBK-L- 11164 / Page 2 Attachments cc: W.M. Dean, NRC Region I Administrator G. E. Miller, NRC Project Manager, Project Directorate 1-2 W. J. Raymond, NRC Resident Inspector

Attachment 1 Relief Request 21R- 17 Examination Category C-A Pressure Retaining Welds in Pressure Vessels (Limited Exams)

NextEra Energy Seabrook, LLC Second Ten-Year Interval 10 CFR 50.55a Request Number 21R-17, Rev. 0 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

Sheet 1 of 7

1. ASME Code Component(s) Affected Code Class: 2 Examination Category: C-A, Pressure Retaining Welds in Pressure Vessels Item Number: C1.10, Shell Circumferential Welds C1.30, Tubesheet-to-Shell Welds Weld Identification: Listed in Table 21R17-01

2. Applicable Code Edition and Addenda

ASME Section XI, 1995 Edition, including Addenda through 1996.

3. Applicable Code Requirement

ASME Section XI, 1995 Edition with 1996 Addenda, Examination Category C-A requires volumetric examination of 100 percent of the weld length as defined in Table IWC-2500-1 and shown in Figure IWC-2500-2. The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory guide 1.147 Rev. 15, allows credit for essentially 100 percent coverage of the welds provided greater than 90 percent of the required volume has been examined.

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the 100 percent volumetric examination coverage requirement of the subject weld due to geometric configuration, which limits the volumetric examination coverage that can be attained.

Residual Heat Removal Heat Exchanger The "B" Residual Heat Removal (RH) heat exchanger shell circumferential weld was examined with a manual ultrasonic technique using most recent technology available to achieve maximum examination coverage practical.

21R-17, Rev. 0 Sheet 2 of 7 Due to original design of the heat exchanger, the lower shell circumferential weld is in close proximity to the flange joining the lower heat exchanger shell to the upper shell, thereby limiting ultrasonic examination coverage from the tubesheet side of the weld.

Containment Building Spray Heat Exchanger The "B" Containment Building Spray (CBS) heat exchanger tubesheet-to-shell weld was examined with a manual ultrasonic technique using most recent technology available to achieve maximum examination coverage practical.

Due to original design of the heat exchanger, the tubesheet-to-shell weld is in close proximity to the flange joining the heat exchanger shell side to the tubesheet side, thereby limiting ultrasonic examination coverage from the tubesheet side of the weld. Further examination limitations exist from support gusset plates welded on each side of the tubesheet shell.

Limitation sketches are provided in Figures 21R-17-01 and 21IR-17-02.

5. Burden Caused by Compliance Residual Heat Removal Heat Exchanger To increase examination coverage on the R1HR heat exchanger lower shell circumferential weld, the heat exchanger would require replacement with a design that would allow for complete examination coverage of the subject weld. This option to meet the 100 percent examination requirement is considered impractical.

Containment Building Spray Heat Exchanger To increase examination coverage on the CBS heat exchanger tubesheet-to-shell weld, removal of the permanently welded support gusset plates that are part of the original heat exchanger design or replacement of the heat exchanger with a design that would allow for complete examination coverage of the subject weld would be required. These options to meet the 100 percent examination coverage requirement are considered impractical.

6. Proposed Alternative And Basis for Use There are no alternative examinations proposed. The subject welds received a volumetric examination to the maximum extent practical utilizing best available techniques on accessible portions of the weld to the extent practical. Additionally, a visual (VT-2) examination is performed each refueling outage during the system leakage test as required by Section XI, Table IWC-2500-1, Category C-H, All Pressure Retaining Components.

21R17. Rev. 0 Sheet 3 of 7 Based on the volumetric examination coverage attained with acceptable results along with the visual (VT-2) examination performed each refueling outage with acceptable results, it is reasonable to conclude that service induced degradation would be detected, which provides an acceptable level of quality and safety for the subject welds.

7. Duration of Proposed Alternative Relief is requested for the second 10-year inspection interval for Seabrook Station, which began on August 19, 2000 and ended on August 18, 2010.

8. Precedents Similar relief requests documenting limited examinations have been granted to the following plants:

NRC to Dominion Nuclear Connecticut, Inc. letter, "Millstone Power Station, Unit No. 3 - Issuance of Relief Requests IR-2-51 Through IR-2-60 Regarding Second 10-Year Interval Inservice Inspection Program Plan (TAC. Nos. ME3809 Through ME3818)", dated April 26, 2011 M NRC to Virginia Electric and Power Company letter, "North Anna Power Station, Unit No. 1, Third 10-Year Inservice Inspection Interval Program, Relief Request N1-13-PRT-004, Part A Through Part G (TAC Nos. ME3333, ME5136, ME5137, ME5138, ME5139, ME5140 and ME5141)", dated January 7, 2011

9. References 0 ADAMS Accession Number: ML110691154 ADAMS Accession Number: ML110060011

Sheet 4 of 7 Table 21R-17-01 Examination Category C-A, Pressure Retaining Welds in Pressure Vessels ISI Weld ID Item Configuration Coverage Angle Mode Comments Number RH E-9B O1B C1.10 "B" RHR Heat 50% 450 Shear Wave Limited examination from the shell side due to Exchanger Shell 600 Longitudinal close proximity of the flange to the weld. No Circumferential Wave service related flaws were detected.

Weld CBS E-16B C1.30 "B" CBS Heat 19% 450 Shear Wave Two limitations exist, the weld is in close 01 Exchanger 600 Longitudinal proximity to the flange, which limits scanning Tubesheet-to- Wave from the shell side of the weld and welded Shell Weld support attachments, which prohibit access to the weld in those locations. No service related flaws were detected.

Sheet 5 of 7 Table 2IR-17-02 Examination Category C-A, Pressure Retaining Welds in Pressure Vessels Base Material and Thickness Heat Exchanger ISI Weld ID Base Material Thickness RH E-9B O1B SA240/TP304 0.875 inches CBS E-16B 01 SA240/TP304 0.625 inches

Figure 21R- 17-01 Residual Heat (RH) Heat Exchanger I-RH-E-9B Circumferential Weld Detail (Exam Limitation)

Sheet 6 of 7 RH E-9B 01B CLASS 3 CLASS 2 FII ,-

C WELD VOLUME NO EXAMINTION COVERAGE DUE TO CONFIGURATION GEOMETRY (LIMITATION)

Figure 21R- 17-02 Containment Building Spray (CBS) Heat Exchanger 1-CBS-E-16B Tubesheet-to-Shell Weld (Exam Limitation)

Sheet 7 of 7 CBS E-16B 01 WELD VOLUME NO EXAMINTION COVERAGE DUE TO CONFIGURATION GEOMETRY (LIMITATION)

SECTION A-A

Attachment 2 Relief Request 21R- 18 Examination Category C-B Pressure Retaining Nozzle Welds in Vessels (Limited Exams)

NextEra Energy Seabrook, LLC Second Ten-Year Interval 10 CFR 50.55a Request Number 21R-18, Rev. 0 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

Sheet 1 of 6

1. ASME Code Component(s) Affected Code Class: 2 Examination Category: C-B, Pressure Retaining Nozzle Welds in Vessels Item Number: C2.21, Nozzles Without Reinforcing Plate in Vessels > 1/2 in. Nominal Thickness, Nozzle-to-Shell (or Head) Weld Weld Identification: Listed in Table 21R-18-01

2. Applicable Code Edition and Addenda

ASME Section XI, 1995 Edition, including Addenda through 1996.

3. Applicable Code Requirement

ASME Section XI, 1995 Edition with 1996 Addenda, Examination Category C-B requires volumetric and surface examination of 100 percent of nozzle welds as defined in Table IWC-2500-1 and shown in Figure IWC-2500-4(a) or (b). The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory guide 1.147 Rev. 15, allows credit for essentially 100 percent coverage of the welds provided greater than 90 percent of the required volume has been examined.

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the 100 percent volumetric examination coverage requirement of the subject welds due to geometric configuration, which limits the volumetric examination coverage that can be attained.

The "B" Containment Building Spray (CBS) heat exchanger inlet and outlet nozzle-to-shell welds were examined with a manual ultrasonic technique using most recent technology available to achieve maximum examination coverage practical. Examination coverage of the inlet and outlet nozzle-to-shell welds is limited because of single sided access due to nozzle-to-shell weld configuration.

21R-18. Rev. 0 Sheet 2 of 6 Limitation sketch provided in Figure 21R-18-01.

Table 21R- 18-02 provides base material and thickness data.

5. Burden Caused by Compliance To increase examination coverage on the CBS heat exchanger nozzle-to-shell welds would require extensive modification or replacement of the heat exchanger with a design that would allow for complete examination coverage of the subject welds. This option to meet the 100 percent examination coverage requirement is considered impractical.

6. Proposed Alternative And Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing best available techniques on accessible portions of the weld to the extent practical. The subject welds received a surface examination meeting requirements specified in Section XI, Table IWC-2500-1, Category C-B. Additionally, a visual (VT-2) examination was performed each refueling outage during the system leakage test as required by Section XI, Table IWC-2500-1, Category C-H.

Based on the volumetric examination coverage attained with acceptable results, 100% surface examination coverage attained with acceptable results and the visual (VT-2) examination performed each refueling outage with acceptable results, it is reasonable to conclude that service induced degradation would be detected. Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Duration of Proposed Alternative Relief is requested for the second 10-year inspection interval for Seabrook Station, which began on August 19, 2000 and ended on August 18, 2010.

21R-18, Rev. 0 Sheet 3 of 6

8. Precedents Similar relief requests have been granted to the following plants:

NRC to Dominion Nuclear Connecticut, Inc. letter, "Millstone Power Station, Unit No. 3 -

Issuance of Relief Requests IR-2-51 Through IR-2-60 Regarding Second 10-Year Interval Inservice Inspection Program Plan (TAC. Nos. ME3809 Through ME3818)", dated April 26, 2011 NRC to Virginia Electric and Power Company letter, "North Anna Power Station, Unit No.

1, Third 10-Year Inservice Inspection Interval Program, Relief Request N 1-13-PRT-004, Part A Through Part G (TAC Nos. ME3333, ME5136, ME5137, ME5138, ME5139, ME5140 and ME5141)", dated January 7, 2011

9. References

• ADAMS Accession Number: ML110691154

• ADAMS Accession Number: MIL 110060011

Sheet 4 of 6 Table 21R-18-01 Examination Category C-B, Pressure Retaining Nozzle Welds in Vessels ISI Weld ID Item Configuration Coverage Angle Mode Comments Number CBS E-16 NI C2.21 "B" CBS Heat 50% 450 Shear Wave Limited examination from the shell side due to Exchanger 600 Longitudinal nozzle-to-shell weld configuration. No Nozzle-to-Shell Wave service related flaws were detected.

Weld CBS E-16B C2.21 "B" CBS Heat 50% 450 Shear Wave Limited examination from the shell side due to N2 Exchanger 600 Longitudinal nozzle-to-shell weld configuration. No Nozzle-to-Shell Wave service related flaws were detected.

Weld

Sheet 5 of 6 Table 21R-18-02 Examination Category C-B, Pressure Retaining Nozzle Welds in Vessels Base Material and Thickness Heat Exchanger ISI Weld ID Base Material Thickness CBS E-16 N1 Shell: SA240/TP304 Nozzle: SA312/TP304 Shell: 0.625 inches Nozzle: 0.438 inches CBS E-16B N2 Shell: SA240/TP304 Nozzle: SA312/TP304 Shell: 0.625 inches Nozzle: 0.438 inches

Figure 21R-18-01 Containment Building Spray (CBS) Heat Exchanger 1-CBS-E-16B Nozzle Welds (Exam Limitations)

Sheet 6 of 6

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INLET/OIUTLET TYPICAL -

CBS E-16B N1 WELD DETAILS I

E WELD VOLUME NO EXAMINTION COVERAGE DUE TO CONFIGURATION GEOMETRY (LIMITATION)

SECTION A-A

Attachment 3 Relief Request 21R- 19 Examination Category C-F-I Class 2 Stainless Steel Piping Limited Exams (Limited Exams)

NextEra Energy Seabrook, LLC Second Ten-Year Interval 10 CFR 50.55a Request Number 21R-19, Rev. 0 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

Sheet 1 of 12

1. ASME Code Component(s) Affected Code Class: 2 Examination Category: C-F-i, Pressure Retaining Welds in Austenitic Stainless Steel High Alloy Piping Item Number: C5.1 1, Piping Welds > 3/8 in. Nominal Wall Thickness for Piping >

NPS 4 in. - Circumferential Welds C5.21, Piping Welds > 1/5 in. Nominal Wall Thickness for Piping > 2 in. and < 4 in. - Circumferential Welds Number of Affected Welds: Listed in Table 21R-19-01

2. Applicable Code Edition and Addenda

ASME Section XI, 1995 Edition, including Addenda through 1996.

Austenitic piping welds with single side access subject to ultrasonic examination with Supplement 2 of Appendix VIII to the 1995 Edition with 1996 Addenda of ASME Section XI.

3. Applicable Code Requirement

ASME Section XI, 1995 Edition with 1996 Addenda, Examination Category C-F-i requires 100 percent volumetric and surface examination coverage for circumferential piping welds as defined in Table IWC-2500-1 and shown in Figure IWC-2500-7.

The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory guide 1.147 Rev. 15, allows credit for essentially 100 percent coverage of the welds provided greater than 90 percent of the required volume has been examined.

10 CFR 50.55a(b)(2)(xv)(A) requires the following examination coverage when applying Supplement 2 to Appendix VIII:

21R-19. Rev. 0 Sheet 2 of 12 (1) Piping must be examined in two axial directions and when examination in the circumferential direction is required, the circumferential examination must be performed in two directions, provided access is available.

(2) Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single side Appendix VIII demonstration using flaws on the opposite side of the weld.

10 CFR 50.55a (b)(2)(xvi)(B) requires that examinations performed from one side of a stainless steel pipe weld must be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single side examinations. To demonstrate equivalency to two sided examinations, the demonstration must be performed to the requirements of Appendix VIII as modified by this paragraph and paragraph 50.55a(b)(2)(xv)(A).

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the 100 percent volumetric examination coverage requirement for austenitic piping welds with single side access. Surface examinations met ASME Code requirements with no unacceptable indications recorded.

There are currently no Performance Demonstration Initiative (PDI) qualified single side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld.

PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single side examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single side qualification to demonstrate that the examiners qualification and the subsequent weld examination is based on application of the best available technology.

Relief is requested from compliance with the 100 percent required examination coverage for piping welds listed in Table 21R-19-01 based on configurations limited to single side access. Examination coverage listed was obtained during examination with no credit taken for the far side of each weld.

Table 21R- 19-02 provides base and weld materials for welds listed in Table 21R- 19-01.

Limitation sketch provided for specific weld CS 371-03 08 in Figure 21R-19-01.

Generic limitation sketch provided in Figure 21R-19-02.

2IR-19, Rev. 0 Sheet 3 of 12

5. Burden Caused by Compliance Compliance would require extensive modification or replacement of components with a design that allows examination from both sides of the weld. This option to meet the 100 percent examination coverage requirement is considered impractical.

6. Proposed Alternative And Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing best available techniques, as qualified through the Performance Demonstration Initiative (PDI) for Supplement 2 with demonstrated best effort for single side examination, from the accessible side of the weld. The subject welds received a surface examination meeting requirements specified in Section XI, Table IWC-2500-1, Category C-F-1. Additionally, a visual (VT-2) examination performed each refueling outage during the system leakage test as required by Section XI, Table IWC-2500-1, Category C-H.

Based on the volumetric examination coverage attained with acceptable results, 100% surface examination coverage attained with acceptable results and the visual (VT-2) examination performed each refueling outage with acceptable results, it is reasonable to conclude that service induced degradation would be detected. Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Duration of Proposed Alternative Relief is requested for the second 10-year inspection interval for Seabrook Station, which began on August 19, 2000 and ended on August 18, 2010.

8. Precedents Similar relief requests have been granted to the following plants:

NRC to Dominion Nuclear Connecticut, Inc. letter, "Millstone Power Station, Unit No. 3 -

Issuance of Relief Requests IR-2-5 1 Through IR-2-60 Regarding Second 10-Year Interval Inservice Inspection Program Plan (TAC. Nos. ME3809 Through ME3818)", dated April 26, 2011 NRC to Virginia Electric and Power Company letter, "North Anna Power Station, Unit No.

1, Third 10-Year Inservice Inspection Interval Program, Relief Request NI-13-PRT-004, Part A Through Part G (TAC Nos. ME3333, ME5136, ME5137, ME5138, ME5139, ME5140 and ME5141)", dated January 7, 2011

21R-19, Rev. 0 Sheet 4 of 12

9. References

• ADAMS Accession Number: ML110691154

• ADAMS Accession Number: MLI 10060011

Table 21R-19-01 Examination Category C-F-1 Pressure Retaining Welds in Austenitic Stainless Steel High Alloy Piping Coverage Limitations and UT Parameters Sheet 5 of 12 ISI Weld ID Item Configuration Coverage Angle Mode Comments Number CBS 1207-02 C5.11 12" Pipe-to- 50% 450 and Shear Wave Limited examination from the pipe side only 02 Valve 600 due to close proximity of the valve taper to the weld. No service related flaws were detected.

CBS 1208-03 C5.11 10" Reducer-to- 50% 450 and Shear Wave Limited examination from the pipe side only 01 Pipe 700 due to close proximity of the reducer taper to the weld. No service related flaws were detected.

CBS 1209-01 C5.11 12" Pipe-to- 50% 450 and Shear Wave Limited examination from the pipe side only 02 Valve 600 Longitudinal due to close proximity of the valve taper to the 700 Wave weld. No service related flaws were detected.

CBS 1212-16 C5.11 16" Pipe-to- 49% 450 and Shear Wave Limited examination from the pipe side only 10 Valve 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

CBS 1214-02 C5.11 8" Valve-to- 50% 450 600 Shear Wave Limited examination from the penetration side 21 Penetration and only due to close proximity of the valve taper 700 to the weld. No service related flaws were detected.

CBS 1215-01 C5.11 6" Flange-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 01 700 due to close proximity of the flange to the weld. No service related flaws were detected.

CBS 1216-02 C5.11 8" Pipe-to-Valve 50% 450 600 Shear Wave Limited examination from the pipe side only 20 and due to close proximity of the valve taper to the 700 weld. No service related flaws were detected.

Sheet 5a CS 0324-01 C5.21 3" Pipe-to-Valve 50% 450 and Shear Wave Limited examination from the pipe side only 01 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

CS 0324-01 C5.21 3" Valve-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 02 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

Table 21R-19-01 Examination Category C-F-1 Pressure Retaining Welds in Austenitic Stainless Steel High Alloy Piping Coverage Limitations and UT Parameters Sheet 6 of 12 ISI Weld ID Item Configuration Coverage Angle Mode Comments Number CS 0355-01 C5.21 3" Valve-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 01 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

CS 0355-01 C5.21 3" Pipe-to-Valve 50% 450 and Shear Wave Limited examination from the pipe side only 04 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

CS 0355-06 C5.21 3" Pipe-to-Valve 50% 450 60° Shear Wave Limited examination from the pipe side only 01 and due to close proximity of the valve taper to the 700 weld. No service related flaws were detected.

CS 0362-01 C5.21 4" Valve-to-Pipe 50% 450 Shear Wave Limited examination from the pipe side only 02 600 Longitudinal due to close proximity of the valve taper to the Wave weld. No service related flaws were detected.

CS 0364-01 C5.21 4" Flange-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 01 600 Longitudinal due to close proximity of the flange to the 600 Wave weld. No service related flaws were detected.

CS 0364-02 C5.21 3" Pipe-to-Valve 50% 450 and Shear Wave Limited examination from the pipe side only 01 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

CS 0369-03 C5.21 8" Pipe-to-Valve 50% 450 600 Shear Wave Limited examination from the pipe side only 08 and due to close proximity of the valve taper to the 700 weld. No service related flaws were detected.

Sheet 6a CS 0371-03 C5.21 6" Elbow-to-Pipe 65% 450 and Shear Wave Weld crown width limited coverage for 08 700 circumferential scans. No recordable indications were detected.

CS 0374-01 C5.21 4" Flange-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 02 700 Longitudinal due to close proximity of the flange to the 600 Wave weld. No service related flaws were detected.

Table 21R-19-01 Examination Category C-F-1 Pressure Retaining Welds in Austenitic Stainless Steel High Alloy Piping Coverage Limitations and UT Parameters Sheet 7 of 12 ISI Weld ID Item Configuration Coverage Angle Mode Comments Number CS 0375-01 C5.21 3" Valve-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 04 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

RC 0013-04 C5.11 14" Pipe-to-Safe 50% 450 and Shear Wave Limited examination from the pipe side only 10 end 700 due to close proximity of the nozzle taper to the weld. No service related flaws were detected.

RH 0152-01 C5.1 1 8" Valve-to-Pipe 50% 45' and Shear Wave Limited examination from the pipe side only 03 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

RH 0155-02 C5.1 1 8" Pipe-to-Valve 50% 450 Shear Wave Limited examination from the pipe side only 32 600 Longitudinal due to close proximity of the valve taper to the Wave weld. No service related flaws were detected.

RH 0159-01 C5.11 8" Pipe-to-Valve 50% 450 Shear Wave Limited examination from the pipe side only 14 600 Longitudinal due to close proximity of the valve taper to the Wave weld. No service related flaws were detected.

RH 0 162-04 C5.11 6" Pipe-to-Flange 50% 450 and Shear Wave Limited examination from the pipe side only 02 600 Longitudinal due to close proximity of the flange to the 600 Wave weld. No service related flaws were detected.

RH 0163-05 C5.11 6" Flange-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 04 600 Longitudinal due to close proximity of the flange to the 600 Wave weld. No service related flaws were detected.

Sheet 7a RH 0180-01 C5.11 8" Tee-to-Pipe 50% 450 Shear Wave Limited examination from the pipe side only Longitudinal due to close proximity of the tee fitting taper 01 600 to the weld. No service related flaws were Wave detected.

Table 21R-19-01 Examination Category C-F-1 Pressure Retaining Welds in Austenitic Stainless Steel High Alloy Piping Coverage Limitations and UT Parameters Sheet 8 of 12 ISI Weld ID Item Configuration Coverage Angle Mode Comments Number SI 0250-02 07 C5.21 4" Valve-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

SI 0250-03 01 C5.21 4" Valve-to-Pipe 50% 450 Shear Wave Limited examination from the pipe side only 600 Longitudinal due to close proximity of the valve taper to the Wave weld. No service related flaws were detected.

SI 0250-03 04 C5.21 4" Pipe-to-Tee 50% 450 Shear Wave Limited examination from the pipe side only 700 Longitudinal due to close proximity of the tee fitting taper Wave to the weld. No service related flaws were detected.

SI 0251-02 08 C5.21 4" Pipe-to-Flange 50% 450, 600 Shear Wave Limited examination from the pipe side only and due to close proximity of the flange to the 700 weld. No service related flaws were detected.

SI 0251-03 01 C5.21 4" Pipe-to-Valve 50% 450 and Shear Wave Limited examination from the pipe side only 600 Longitudinal due to close proximity of the valve taper to the 600 Wave weld. No service related flaws were detected.

SI 0256-01 02 C5.21 4" Valve-to-Pipe 50% 450, 600 Shear Wave Limited examination from the pipe side only and due to close proximity of the valve taper to the 700 weld. No service related flaws were detected.

SI 0257-01 02 C5.21 4" Valve-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

Sheet 8a SI 0272-02 10 C5.21 4" Valve-to-Pipe 50% 450 Shear Wave Limited examination from the pipe side only due to close proximity of the valve taper to the 600 Longitudinal weld. No service related flaws were detected.

Wave

Table 21R-19-02 Examination Category C-F-i Pressure Retaining Welds in Austenitic Stainless Steel High Alloy Piping Base and Weld Materials Sheet 9 of 12 ISI Weld lID Base Material Weld Material CBS 1207-02 02 Pipe: SA312/F316 Valve: SA 182/F316 ER308 and E308 CBS 1208-03 01 Pipe: SA312/F316 Reducer: SA403/WP304 Construction supplied piping spool that includes weld CBS 1209-01 02 Pipe: SA312/F316 Valve: SA182/F316 87DCR311 CBS 1212-16 10 Pipe: SA358/TP304C1.1 Valve: SA182/F316 ER308 and E308 CBS 1214-0221 Valve: SA351/Gr CF3M Pipe: SA312/TP304 ER308 and E308 CBS 1215-01 01 Flange: SA182/F304 Pipe: SA312/TP304 Construction supplied piping spool that includes weld CBS 1216-0220 Pipe: SA182/TP304 Valve: SA351/Gr CF3M ER308 and E308 CS 0324-01 01 Pipe: SA376/TP316 Valve: SA182/F316 ER308 and E308 CS 0324-01 02 Valve: SA182/F316 Pipe: SA376/TP316 ER308 and E308 CS 0355-01 01 Valve: SA182/F316 Pipe: SA376/TP316 ER316/E316 CS 0355-01 04 Pipe: SA376/TP316 Valve: SA182/F316 ER316/E316 CS 0355-06 01 Pipe: SA376/TP316 Valve: SA182/F316 ER316/E316 CS 0362-01 02 Valve: SA182/F316 Pipe: SA376/TP316 ER316/E316 CS 0364-01 01 Flange: SA182/F316 Pipe: SA376/TP316 Construction supplied piping spool that includes weld CS 0364-02 01 Pipe: SA376/TP316 Valve: SA 182/F304 ER308 and E308 CS 0369-03 08 Pipe: SA312/TP304 Valve: SA182/F304 ER308 and E308 CS 0371-03 08 Elbow: SA403/WP304 Pipe: SA312/TP304 Construction supplied piping spool that includes weld

Sheet 9a CS 0374-01 02 Flange: SA182/F316 Pipe: SA376/TP316 Construction supplied piping spool that includes weld

Table 2IR-19-02 Examination Category C-F-1 Pressure Retaining Welds in Austenitic Stainless Steel High Alloy Piping Base and Weld Materials Sheet 10 of 12 ISI Weld ID Base Material Weld Material CS 0375-01 04 Valve: SA182/F316 Pipe: SA312/TP304 ER308 and E308 RC 0013-04 10 Pipe: SA358/TP304CI.1 Nozzle: SA182/F304 ER308 and E308 RH 0152-01 03 Valve: SA351/Gr CF3M Pipe: SA312/TP304 Construction supplied piping spool that includes weld RH 0155-02 32 Pipe: SA312/TP304 Valve: SA182/F316 ER308 and E308 RH 0159-01 14 Pipe: SA312/TP304 Valve: SA182/F316 ER308 and E308 RH 0162-04 02 Pipe: SA376/TP316 Flange: SA182/F316 ER316/E316 RH 0163-05 04 Flange: SA182/F316 Pipe: SA376/TP316 ER316/E316 RH 0180-01 01 Tee: SA403/WP304 Pipe: SA376/TP316 ER316/E316 SI 0250-02 07 Valve: SA182/F316 Pipe: SA312/TP304 ER308 and E308 SI 0250-03 01 Valve: SA182/F316 Pipe: SA312/TP304 ER308 and E308 SI 0250-03 04 Pipe: SA376/TP316 Tee: SA403/WP316 Construction supplied piping spool that includes weld SI 0251-02 08 Pipe: SA312/TP304 Flange: SA182/F304 Construction supplied piping spool that includes weld SI 0251-03 01 Pipe: SA312/TP304 Valve: SA312/17316 ER316/E316 SI 0256-01 02 Valve: SA182/F316 Pipe: SA312/TP304 ER308 and E308 SI 0257-01 02 Valve: SA182/F316 Pipe: SA312/TP304 ER308 and E308 SI 0272-02 10 Valve: SA182/F316 Pipe: SA376/TP316 ER316/E316

Figure 2IR-19-0l Examination Coverage Limitation for Weld CS 0371-03 08 Sheet 11 of 12 CS 0371-03 08

>2t PIPE ELBOW

• A 1- 1/3t J NO CIRC SCAN COVERAGE DUE TO WELD GEOMETRY

Figure 21R-19-02 Typical OD Profile Representing Various Components (Exam Limitation)

Sheet 12 of 12 SAFE END /VALVE J

FLANGE I --- /

REDUCER TEE 00-PIPE Ti 1/3 t T

NO COVERAGE DUE TO CONFIGURATION GEOMETRY TYPICAL REPRESENTATION OF OD PROFILE FOR VARIOUS COMPONENTS

Attachment 4 Relief Request 21R-20 Examination Category R-A Class 1 Stainless Steel Piping Limited Exams (Limited Exams)

NextEra Energy Seabrook, LLC Second Ten-Year Interval 10 CFR 50.55a Request Number 21R-20, Rev. 0 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

-.-Inservice Inspection Impracticality--

Sheet 1 of 7

1. ASME Code Component(s) Affected Code Class: 1 Examination Category: R-A, Risk Informed Piping Examinations Item Number: RI. 11, Elements Subject to Thermal Fatigue R1.16, Elements Subject to Intergranular Stress Corrosion Cracking R1.20, Elements Not Subject to a Damage Mechanism Number of Affected Welds: Listed in Table 21R-20-01

2. Applicable Code Edition and Addenda

ASME Section XI, 1995 Edition, including Addenda through 1996 (Reference 1).

Austenitic piping welds with single side access subject to ultrasonic examination with Supplement 2 of Appendix VIII to the 1995 Edition with 1996 Addenda of ASME Section XI.

3. Applicable Code Requirement

The examination requirements for Class 1 piping welds are governed by the Risk-Informed Inservice Inspection (RI-ISI) program the was approved by the NRC in a Safety Evaluation dated February 7, 2002 per TAC No. MB 1799. The RI-ISI program was developed in accordance with EPRI Topical Report TR-1 12657 Rev. B-A, Revised Risk-Informed Inservice Inspection Evaluation Procedure.

The RI-ISI program was also implemented in a manner consistent with ASME Code Case N-578, Risk-Informed Requirements for Class 1, 2 and 3 Piping, Method B. ASME Code Case N-578 requires that 100% of the weld be examined.

The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory guide 1.147 Rev. 15, allows credit for essentially 100 percent coverage of the welds provided greater than 90 percent of the required volume has been examined.

10 CFR 50.55a(b)(2)(xv)(A) requires the following examination coverage when applying Supplement 2 to Appendix VIII:

2IR-20, Rev. 0 Sheet 2 of 7 (1) Piping must be examined in two axial directions and when examination in the circumferential direction is required, the circumferential examination must be performed in two directions, provided access is available.

(2) Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single side Appendix VIII demonstration using flaws on the opposite side of the weld.

10 CFR 50.55a (b)(2)(xvi)(B) requires that examinations performed from one side of a stainless steel pipe weld must be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single side examinations. To demonstrate equivalency to two sided examinations, the demonstration must be performed to the requirements of Appendix VIII as modified by this paragraph and paragraph 50.55a(b)(2)(xv)(A).

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the 100 percent volumetric examination coverage requirement for austenitic piping welds with single side access.

There are currently no Performance Demonstration Initiative (PDI) qualified single side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld.

PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single side examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single side qualification to demonstrate that the examiners qualification and the subsequent weld examination is based on application of the best available technology.

Relief is requested from compliance with the 100 percent required examination coverage for piping welds listed in Table 21R-20-01 based on configurations limited to single side access. Examination coverage listed was obtained during examination with no credit taken for the far side of each weld.

Table 21R-20-02 provides base and weld materials for welds listed in Table 21R-20-0 1.

Generic limitation sketch provided in Figure 21R-20-0 1.

5. Burden Caused by Compliance Compliance would require extensive modification or replacement of components with a design that allows examination from both sides of the weld. This option to meet the 100 percent examination coverage requirement is considered impractical.

2IR-20, Rev. 0 Sheet 3 of 7

6. Proposed Alternative And Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing best available techniques, as qualified through the Performance Demonstration Initiative (PDI) for Supplement 2 with demonstrated best effort for single side examination, from the accessible side of the weld. Additionally, a visual (VT-2) examination performed each refueling outage during the system leakage test as required by Section XI, Table IWB-2500-1, Category B-P, All Pressure Retaining Components.

Based on the volumetric examination coverage attained with acceptable results, and the visual (VT-

2) examination performed each refueling outage with acceptable results, it is reasonable to conclude that service induced degradation would be detected. Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Duration of Proposed Alternative Relief is requested for the second 10-year inspection interval for Seabrook Station, which began on August 19, 2000 and ended on August 18, 2010.

8. Precedents Similar relief requests have been granted to the following plants:

NRC to Dominion Nuclear Connecticut, Inc. letter, "Millstone Power Station, Unit No. 3 -

Issuance of Relief Requests IR-2-5 1 Through IR-2-60 Regarding Second 10-Year Interval Inservice Inspection Program Plan (TAC. Nos. ME3 809 Through ME3818)", dated April 26, 2011 NRC to Virginia Electric and Power Company letter, "North Anna Power Station, Unit No.

1, Third 10-Year Inservice Inspection Interval Program, Relief Request NI-13-PRT-004, Part A Through Part G (TAC Nos. ME3333, ME5136, ME5137, ME5138, ME5139, ME5140 and ME5141)", dated January 7, 2011

9. References 0 ADAMS Accession Number: ML110691154 0 ADAMS Accession Number: ML110060011

Table 21R-20-01 Examination Category R-A Risk Informed Piping Examinations Sheet 4 of 7 ISI Weld ID Item Configuration Coverage Angle Mode Comments Number CS 0329-04 R1.20 2" Valve-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 04 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

CS 0366-02 RI.11 3" Valve-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 04 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

CS 0368-02 RI.11 3" Valve-to-Pipe 50% 45' and Shear Wave Limited examination from the pipe side only 04 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

RC 0013-01 R1.11 12" Pipe-to-Tee 50% 450 Shear Wave Limited examination from the pipe side only 08 600 Longitudinal due to close proximity of the tee fitting taper to the weld. No service related flaws were detected.

RC 0013-01 Ri.11 12" Tee-to-Pipe 50% 450 Shear Wave Limited examination from the pipe side only 09 600 Longitudinal due to close proximity of the tee fitting taper to the weld. No service related flaws were detected.

RC 0048-03 R1.11 4" Reducer-to- 50% 450 Shear Wave Limited examination from the pipe side only 01 Pipe 700 Longitudinal due to close proximity of the reducer taper to the weld. No service related flaws were detected.

39

Sheet 4a RC 0048-03 RI.11 4" Pipe-to-Safe 50% 450 and Shear Wave Limited examination from the pipe side only 06 end 700 due to close proximity of the nozzle taper to the weld. No service related flaws were detected.

RC 0080-02 RI.11 3" Pipe-to-Valve 50% 450 and Shear Wave Limited examination from the pipe side only 10 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

40

Table 2IR-20-01 Examination Category R-A Risk Informed Piping Examinations Sheet 5 of 7 ISI Weld ID Item Configuration Coverage Angle Mode Comments Number RC 0080-06 Ri.11 3" Pipe-to-Valve 50% 450 and Shear Wave Limited examination from the pipe side only 10 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

RC 0097-01 R1.20 3" Valve-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 08 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

RC 0097-01 R1.20 3" Pipe-to-Valve 50% 450 and Shear Wave Limited examination from the pipe side only 11 700 due to close proximity of the valve taper to the weld. No service related flaws were detected.

RH 0180-05 R1.11 12" Pipe-to-Tee 50% 450 and Shear Wave Limited examination from the pipe side only 02 600 due to close proximity of the tee fitting taper to the weld. No service related flaws were detected.

SI 0202-02 17 R1.11 10" Valve-to- 50% 450 Shear Wave Limited examination from the pipe side only Pipe 600 Longitudinal due to close proximity of the valve taper to the Wave weld. No service related flaws were detected.

SI 0251-07 04 R1.16 6" Pipe-to-Valve 50% 450 and Shear Wave Limited examination from the pipe side only 600 due to close proximity of the valve taper to the weld. No service related flaws were detected.

SI 0251-07 05 R1.20 6" Valve-to-Pipe 50% 450 and Shear Wave Limited examination from the pipe side only 600 due to close proximity of the valve taper to the weld. No service related flaws were detected.

41

Table 21R-20-02 Examination Category R-A Risk Informed Piping Examinations Base and Weld Materials Sheet 6 of 7 ISI Weld ID Base Material Weld Material CS 0329-04 04 Valve: SA182/F316 Pipe: SA376/TP316 ER316/E316 CS 0366-02 04 Valve: SA182/F316 Pipe: SA376/TP316 ER316/E316 CS 0368-02 04 Valve: SA 182/F316 Pipe: SA376/TP316 ER316/E316 RC 0013-01 08 Pipe: SA376/TP316 Tee: SA403/WP316 Construction supplied piping spool that includes weld RC 0013-01 09 Tee: SA403/WP316 Pipe: SA376/TP316 Construction supplied piping spool that includes weld RC 0048-03 01 Reducer: SA403/WP316 Pipe: SA376/TP316 ER316/E316 RC 0048-03 06 Pipe: SA376/TP316 Nozzle: SA182/F316 ER316/E316 RC 0080-02 10 Pipe: SA376/TP316 Valve: SA182/F316 ER316/E316 RC 0080-06 10 Pipe: SA376/TP316 Valve: SA182/F316 ER316/E316 RC 0097-01 08 Valve: SA182/F304 Pipe: SA376/TP316 ER316/E316 RC 0097-01 11 Pipe: SA376/TP316 Valve: SA182/F316 ER316/E316 RH 0180-05 02 Pipe: SA376/TP316 Tee: SA403/WP316 Construction supplied piping spool that includes weld SI 0202-02 17 Valve: SA182/F304 Pipe: SA376/TP316 ER308/E308 SI 0251-07 04 Pipe: SA376/TP316 Valve: SA182/F316 ER316/E316 SI 0251-07 05 Valve: SA182/F316 Pipe: SA376/TP316 ER308/E308 42

Figure 21R-20-01 Typical OD Profile Representing Various Components (Exam Limitation)

Sheet 7 of 7 SAFE END /VALVE FLANGE

/

REDUCER TEE PIPE 1/3 t NO COVERAGE DUE TO CONFIGURATION GEOMETRY TYPICAL REPRESENTATION OF OD PROFILE FOR VARIOUS COMPONENTS 43