Text

Relief Request RR-04-13 for the Temporary Non-Code Compliant Condition of the Class 3 Service Water System 10 Inch Emergency Diesel Generator Supply Piping Flange
	ML12297A333
Person / Time
Site:	Millstone
Issue date:	10/18/2012
From:	Price J; Dominion, Dominion Nuclear Connecticut
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	12-636, RR-04-13
	Download: ML12297A333 (73)
	v • d • e

Dominion Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 : Dominion Web Address: www.dom.com October 18, 2012 U.S. Nuclear Regulatory Commission Serial No.12-636 Attention: Document Control Desk NLOS/MAE RO Washington, DC 20555 Docket No. 50-336 License No. DPR-65 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2 RELIEF REQUEST RR-04-13 FOR THE TEMPORARY NON-CODE COMPLIANT CONDITION OF THE CLASS 3 SERVICE WATER SYSTEM 10 INCH EMERGENCY DIESEL GENERATOR SUPPLY PIPING FLANGE Pursuant to 10 CFR 50.55a(a)(3)(ii), Dominion Nuclear Connecticut, Inc. (DNC) requests relief from the Section XI requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code for Millstone Power Station Unit 2 (MPS2).

This request is based on the hardship of performing required ASME code repair/replacement activities to a piping flange in the 10-inch service water (SW) supply line to the Facility 2 emergency diesel generator (EDG) heat exchangers. In accordance with 10 CFR 50.55a(g)(1), this safety-related piping must meet the requirements applicable to components which are classified as ASME Code Class 3.

A Code repair requires shut down of MPS2 to replace the piping flange. Given the limited risk associated with the condition of the flange, Code repair is considered a hardship without a compensating increase in the level of quality and safety. An alternative of continued operation with compensatory actions is proposed until the flange is replaced at the next refueling outage. Attachment 1 to this letter describes the temporary compensatory actions taken by DNC and the technical basis for the proposed relief request for this 10-inch moderate energy SW flange. Attachment 2 provides a structural integrity evaluation.

At the time of discovery of this condition (September 19, 2012) MPS2 was operating at 100% power. Subsequently, on October 6, 2012, MPS2 entered refueling outage 21 and is currently shutdown. The submittal of this alternative request was the subject of a discussion between DNC (William Bartron) and the NRC (James Kim) on September 21, 2012, and again: between DNC (William Bartron) and the NRC (Timothy Lupold) on October 9, 2012. These discussions encompassed the analytical approach used in support of continued plant operation with the identified condition until the plant was shut down for the planned refueling outage, as well as the timely submittal of this alternative request, recognizing the request would likely be submitted after the shutdown of the unit for refueling.

A permanent code-compliant replacement for the identified 10-inch SW flange will be completed no later than the end of the refueling outage which started on October 6, 2012.

Serial No.12-636 Docket No. 50-336 Relief Request RR-04-13 Page 2 of 2 If you have any questions regarding this submittal, please contact Wanda Craft at (804) 273-4687.

Sincerely, J. +/-rice Vice President - Nuclear Engineering Attachments:

1. Relief Request RR-04-13 for the Temporary Non-Code Compliant Condition of the Class 3 Service Water System 10 Inch Emergency Diesel Generator Supply Piping Flange

2. ETE-CME-2012-1024, Rev 2, Structural Integrity Evaluation of Degraded Flange in B Service Water Pipe to EDG Spool SK-2963 Commitments made in this letter:

1. Replace the downstream flange on Spool Piece 2963 (Facility 2 SW supply piping to the Facility 2 EDG HXs) no later than the end of the next refueling outage scheduled for October 2012.

2. UT examination of the pipe flange will be done on a daily basis to track the progression of the corrosion damage.

cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 J. S. Kim, Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 0-8 C2A Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No.12-636 Relief Request RR-04-13 Docket No. 50-336 ATTACHMENT 1 RELIEF REQUEST RR-04-13 FOR THE TEMPORARY NON-CODE COMPLIANT CONDITION OF THE CLASS 3 SERVICE WATER SYSTEM 10 INCH EMERGENCY DIESEL GENERATOR SUPPLY PIPING FLANGE DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.12-636 Docket No. 50-336 Relief Request RR-04-13 Attachment 1, Page 1 of 7 RELIEF REQUEST RR-04-13 Relief Request In Accordance with 10 CFR50.55a(a)(3)(ii)

-- Code Repair Hardship/No Compensating Increase in Safety --

1.0 ASME Code Component(s) Affected ASME Code Class: Code Class 3

Reference:

ASME Section Xl, IWA-4000

Description:

Repair/Replacement Activities Component: Service Water (SW) System 10-inch Light Weight Slip-on Flange (10"JGD-4 spool SK-2963)

Material Coated Carbon Steel

2.0 Applicable Code Edition and Addenda

Millstone Power Station Unit 2 (MPS2) is currently in the fourth 10-year inservice inspection (ISI) interval, which began on April 1, 2010. American Society of Mechanical Engineers (ASME) Section Xl, 2004 Edition, No Addenda (Reference 8.1) applies to the ISI program and is used as the primary ASME code edition for Section Xl repair/replacement activities. The SW system piping design code (code of construction) is ANSI B31.1, 1967 Edition through the summer of 1973 Addendum (Reference 8.4) and the fitting design code (code of construction) is ANSI B16.5, 1968.

3.0 Applicable Code Requirement

ASME Code Section Xl, 2004 Edition, No Addenda, Article IWA-4000, Repair/Replacement Activities.

4.0 Reason For The Request On September 19, 2012, Ultrasonic Test (UT) inspections were performed on a slip-on flange located on 10" service water supply line to B Emergency Diesel Generator (10"-JGD-4 spool SK-2963) to identify damage before, leakage occurs. UT examinations of spool SK-2963 determined that material has been lost from several localized areas.

Serial No.12-636 Docket No. 50-336 Relief Request RR-04-13 Attachment 1, Page 2 of 7 to this attachment contains UT inspection results for the observed flaw area of the flange.

A Code repair would require shutting down to replace the piping flange.

Given the limited risk associated with the present condition~of the flange, Code repair is considered a hardship without a compensating increase in the level of quality and safety. Online repair was considered, however, it would require entry into abnormal operating procedures (i.e., OP 2326C, Off-Normal Service Water System Operations) including the following actions and/or conditions to effect a Code repair.

1. Ensure that SW temperature is less than 58 0 F (currently SW temperature is approximately 66 0 F and normally remains above 58°F well into October). One SW train is sufficient to support accident and safe shutdown loads. Online operation requires two SW trains to support the additional loads unless SW temperature is less than 58°F.

2. Align vital switchgear room coolers and chillers to the A train (or establish compensatory cooling).

3. Disable the B EDG.

4. Align the swing reactor building closed cooling water (RBCCW) heat exchanger (HX) to the A train on the SW side and the B train on the RBCCW side and ensure swing RBCCW HX can provide adequate B train cooling with SW flow less than 1500 gpm.

5. Align the swing SW pump mechanically to the A train and electrically to the B train and start the pump.

6. Align two turbine building component cooling water (TBCCW) HXs to the A train on the SW side (this may require a reactor down power to provide sufficient cooling).

Once in this configuration, completion of the work activities for the spool replacement within the remaining time of the limiting condition for operation of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> will not be possible. Therefore a transition to Mode 5 (a hardship) would be required to perform this repair. Therefore, this is not a feasible option. Further, there is no compensating increase in plant safety by performing the repair during the operating cycle.

This temporary degraded condition of the 10-inch light weight slip on flange is not in compliance with ASME Section Xl, 2004 Edition, IWA-4000, nor

Serial No.12-636 Docket No. 50-336 Relief Request RR-04-13 Attachment 1, Page 3 of 7 does it fall within the scope of the accepted analysis methods contained in NRC Generic Letter (GL) 90-05 (Reference 8.2). Additionally, Code Case N-513-3 (Reference 8.3) is not applicable for use in structural evaluations because the degradation is in a component (10-inch light weight slip-on flange) which is specifically excluded from the scope of the code case.

However, the current pipe stress analysis of record has been reviewed and the pipe stress levels adjacent to the flange (for the non-degraded condition) have been determined to be less than 10% of applicable Code allowables.

The current corrosion damage to the flange is characterized through UT evaluations as limited. Because the observed damage is limited, it is considered that adequate margin is available to accommodate the corrosion that is anticipated to occur during the remaining week of operation until the next refueling outage.

5.0 Proposed Alternative and Basis for Use 5.1 Flaw Characterization - Based on the UT results of the current condition and experience from other similar lining failures discovered during normal inspection on carbon steel piping components in SW, the flaw is characterized to be a localized area corrosion rather than a crack-like flaw.

Dominion procedure ER-AA-NDE-UT-701 (included as Enclosure 2 to Attachment 1) contains additional details on the nondestructive examination process used. The inspection process is reviewed by a qualified Level III inspector.

The examination identified symptoms of localized area corrosion which is consistent with prior experience from other lining failures on this system.

The flange in question was not designed to permit a complete volumetric examination once installed. However, the UT examination process used is capable of identifying localized area corrosion in the flange. There is no history of crack-like flaws in this system and it is not considered credible that such a flaw exists in the small area that did not receive a volumetric examination.

The coating on SW spool SK-2963, where the degradation is occurring on the outlet flange, is inspected every other refueling cycle to ensure that the pressure boundary of the SW pipe remains intact and that the tube sheets of safety-related heat exchangers (HXs) do not become clogged by coating material. This every other refueling outage inspection is based upon the inspection of one train of SW every outage. This inspection scheme has been used for over ten years. Numerous defects have been detected by these inspections and repaired before a through-wall leak occurred.

Serial No.12-636 Docket No. 50-336 Relief Request RR-04-13 Attachment 1, Page 4 of 7 Galvanic Corrosion Mechanism The typical corrosion encountered in this carbon steel lined pipe, used for MPS2 SW, comes from a break or perforation (holiday) in the coating or lining.

The flaws in the coating have been observed most often in or around the inner diameter (ID) corners of the flanged joints. Once the coating is damaged, seawater penetrates into the coating and eventually migrates through to the carbon steel. Once the seawater electrolyte makes contact with the carbon steel, galvani6 corrosion begins if the affected flange is joined to another flange of dissimilar metal (as in this case, AL6XN). The carbon steel is anodic to the surrounding coated carbon steel and any uncoated alloy surfaces. This creates an electrical current and metal ions are released into solution creating a cavity. The cavity grows from the initial point outwards in a radial shape in all directions and takes on a concave appearance.

When the fit-up line between the slip-on flange ID and pipe outer diameter (OD) is exposed, this narrow space is flooded and exposed to seawater which then becomes subject to corrosion. However, the geometry of this gap is not favorable for the mass exchange (movement of negatively charged chloride and free oxygen atoms in and positively charged metal ions out) required for rapid corrosion. The free oxygen within the gap is quickly depleted and the rate of corrosion diminishes to a substantially lower amount compared to that in the active cavity. Thus, significant corrosion of the flange hub or attachment weld beyond the active cavity is not expected.

Beginning in 2005, sections of the piping have been replaced with super austenitic stainless steel, AL6XN, designed for seawater service. Dominion has planned a systematic replacement of the safety-related portion of the SW piping. Spool SK-2963 is scheduled for replacement in the following refueling outage (spring 2014).

The coating on the outlet flange was visually inspected by a qualified linings engineer during 2R20 (spring 2011). Lining engineers receive specific training in the inspection of linings to recognize coating defects. The epoxy lining on the flange face and ID of the pipe had minor evidence of damage that was repaired at that time.

Initial evaluation of this degradation assumed a corrosion rate of 0.067"/month. In addition, daily UT measurements were taken to determine a growth rate. The nature of these measurements inherently introduces some data scatter, so several days of data were required to confirm that growth rate. On 9/27/12, it was determined that the growth rate of several

Serial No.12-636 Docket No. 50-336 Relief Request RR-04-13 Attachment 1, Page 5 of 7 areas of degradation were quite small, but that one area was corroding at a rate that could not support continued operability (approximately .005" /day).

The service water header was accordingly declared inoperable that evening.

Since this rate was indicative of galvanic corrosion and testing indicated inadequate insulation of the.affected flange, actions were initiated to properly install insulation kits on that flange by removing one bolt at a time and replacing it along with an insulating sleeve and washers. By the morning of 9/30/12, the flange had been adequately insulated. Analyses showed that with the reduced rate of corrosion that could be expected in this configuration, no leakage from this degraded flange would be expected for the remaining time to the refueling outage plus a 30-day mission time. The margin to structural integrity and to flow diversion are significantly higher than the margin to leakage. Daily UT monitoring continues to verify that the corrosion rate is lower than allowable. It should be noted that the expected corrosion rate is less than 20% of the allowable to maintain operability until the refueling outage plus 30-day mission time.

5.2 Structural Integrity - Per MPS2 Technical Requirements Manual (TRM) 3.4.10, the structural integrity of an ASME component is determined in accordance with either the original construction code or the ASME Section XI Code, approved code cases or regulatory-approved methods of evaluation. No NRC approved methodology could be identified (i.e., GL 90-

05) and Code Case N-513-3 is not applicable for use. Engineering Technical Evaluation ETE-CME-2012-1024, Revision 2 (Reference 8.6) is a structural integrity assessment of the degraded flange. Pipe stress levels for the Code equations for the adjoining pipe are less than 10% of their associated allowables. Since the limiting case assumes that a 50%

maximum wall loss is experienced (to be confirmed periodically by UT) and the adjoining pipe element has over 90% margin in the stress equations, structural integrity of the flange joint will be maintained for the loading conditions (i.e., dead load, thermal and seismic). The flaw is not crack-like and thus will remain stable under the postulated design loading conditions since a large structural capability margin exists in the worst case degraded flange. Full structural integrity will be restored during 2R21 with a code compliant repair.

5.3 Flow Margin - No leakage has been identified from Spool SK2963.

Therefore there are no flow margin concerns.

5.4 Spray Concerns - No leakage has been identified from Spool SK2963.

Therefore there are no spray concerns.

Serial No.12-636 Docket No. 50-336 Relief Request RR-04-13 Attachment 1, Page 6 of 7 5.5 Flooding - No leakage has been identified from Spool SK2963. Therefore there is no flooding concern.

5.6 Extent of Condition - UT examination of a slip-on flange on the 24" service water supply line to the B Reactor Building Closed Cooling Water heat exchanger (24"-JGD-3 spool SK-893) indicated some material loss in the vicinity of bolts 5 & 6 (clockwise from the top of the CS flange). The affected spool is planned to be replaced during refueling outage 2R21.

Extent of condition examinations (UT and visual) of other areas are being conducted. Some areas may be left in service for a short time after being evaluated to ensure acceptable wall thickness for the duration of that in service period. Areas of degradation will be repaired and the cause of the degradation (typically coating defects and/or improper galvanic isolation) corrected prior to returning the unit to service from the fall 2012 refueling outage. An on-going capital project has replaced much of the carbon steel lined/coated carbon steel piping. However, many similar coated carbon steel flange joints (to the current degraded joint) remain in service. No SW system flange leaks are present in the MPS2 SW system. Because the corrosion rate of carbon steel pipe and fittings can be unacceptably high when galvanic corrosion is present, action will be taken during this refueling outage to reduce the probability of further galvanic attack. These actions include:

" Identification of the affected components.

" Identification and selection of strategies including testing, monitoring, and mitigation activities to minimize the probability of galvanic attack.

Additionally, long term corrective actions will be identified.

5.7 Compensatory Monitoring Plan - UT monitoring will be performed daily while the degraded spool remains in service until a code compliant repair is completed. UT examination of the pipe flange, as was done to identify the degraded area, will track the progression of the corrosion damage. If the circumferential extent of corrosion increases to greater than 50% of the circumference at least partially degraded or if the radial extent of the worst area of degradation indicates greater than acceptable rate of corrosion, the service water header will be declared inoperable and appropriate actions in accordance with Technical Specifications will be taken. Additionally, if the pipe flange experiences a through wall leak, appropriate actions in accordance with technical specifications will be taken.

Serial No.12-636 Docket No. 50-336 Relief Request RR-04-13 Attachment 1, Page 7 of 7 5.8 Conclusion - Although the structural integrity of the degraded flange cannot be demonstrated in accordance with a regulatory-approved methodology, it is concluded the integrity and functional requirements of the flange will be maintained. Thus, SW will continue to be capable of providing required cooling water flow to meet the required cooling loads including the EDG HXs. There will be no adverse impact on neighboring equipment due to either spray or flooding. DNC will implement the compensatory monitoring plan above to ensure any growth of the flaw is identified and assessed for its impact on structural integrity.

6.0 Duration of Proposed Alternative The affected spool piece is scheduled to be repaired in October 2012 during 2R21. Therefore, the duration of the proposed alternative is requested until end of the refueling outage which started in October 2012.

7.0 Precedents Millstone Power Station, Unit No.2-Issuance of Relief Request RR-04-12 Regarding the Temporary Non-Code Compliant Condition of the Class 3 Service Water System 10 Inch Emergency Diesel Generator Supply Piping Flange (TAC NO. ME6886), ML113000100.

8.0 References 8.1 ASME Code Section XI, Division 1, 2004 Edition (No Addenda) 8.2 NRC Generic Letter GL 90-05, "Guidelines for Performing Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 Piping," June 15, 1990 8.3 Code Case N-513-3, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping," Section Xl, Division 1, January 26, 2009 8.4 American National Standards Institute (ANSI) B31.1, Power Piping Code, 1967 Edition through the Summer 1973 Addendum (Note: The MPS2 Pipe Stress Analysis Criteria Document allows the use of ASME III, 1974 Edition to demonstrate pipe stress acceptability) 8.5 Condition Report CR 488814, UT of coated carbon steel flange adjacent 6%

Mo SS indicates damage to carbon steel.

8.6 Engineering Technical Evaluation ETE-CME-2012-1024, Revision 2.

Serial No.12-636 Relief Request RR-04-13 Docket No. 50-336 Enclosure 1 of Attachment 1 Enclosure 1 (of Attachment 1)

Ultrasonic Test Results DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.12-636 Relief Request RR-04-13 Docket No. 50-336 Enclosure 1 of Attachment 1 Exam Data Sheet Millstone Power Station ULTRASONIC EXAMINATION STRAIGHT BEAM MEASUREMENTS Plant Millstone Unit 2 Page ILof .22 System & Zone No. "B" Train Service Water/ 3326 Exam Data Sheet No N/A Component ID SK-2963 AWONumber 531025J6395 Component Description Inlet Flaungeon Spool SK-2963 Drawing No. 25203-201941 Sh.2263 Examination Purpose Eneineering Information Line No. 10"-JGD-4 Instrument & Settin Manufacturer Olympus Model No. 38 DL Plus Serial No. 100030807 Range 3.0" Velocity .2326 Delay N/A oZet Value 26570 Cal Tolerance 1 +/-.002" Intermediate N/A N/A N/A N/A N/A Search Unit Data Final 14:15 .2 50" 1.00" .250" 3.00" Manufacturer Panametrics Type No. D791-RM Couplant Data Temperature Data Serial No. 109450 B.ln Utage 11 Cal. Block Temp. N/A

- requency 5.0 MHz Batch No. 11225 G Component Temp. N/A Size 0.2" SAP Batch Mgmt. No. NT/A Thernometer No N/A See Attachment for Detailed Examination Results Examiner (pin & sign) .Level II Date 09/19/2012 Reviewer (sign) t S Level

Date ANVANII If Required (Sign)

N/A Date N/A Level of Use RA -7 Reference ER-AA-NDE-UT-701

Serial No.12-636 Relief Request RR-04-13 Docket No. 50-336 Enclosure 1 of Attachment 1 Millstone Unit 2 Service Water System "B" Train Component ID: SL-2963 (Inlet flange on spoof SK-2963)

WO #: 53102516395 Position UT Point 1 UT Point 2 UT Point 3 UT Point 4 1 0.405 N/A 0.816 2.520 2 0.388 N/A 0.822 2.520 3 0.380 N/A 0.816 2.520 4 0.389 N/A 0.823 2.500 5 0.399 N/A 0.810 2,100 6 0.405 N/A 0.808 2.530 7 0.411 N/A 0.803 2.530 8 0.414 N/A 0.809 2.180 9 0.409 N/A 0.812 1.900 10 0.415 N/A 0.826 1.910 11 0.410 'N/A 0.822 2.530 12 0.387 N/A 0.824 1.900 Comments: n ;ý;

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Notp: UT readine.~ nht~ined on n~intpd ~uirfsce whirh rniild rp~ijIt in rliffir,,Itx, difficul- in in Note: UT readings obtained on Dainted surface which could result in obtaining UT data at some locations. No UT readings at point 2. Rough weld surface does not provide for consistent UT point repeatability.

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Serial No.12-636 Relief Request RR-04-13 Docket No. 50-336 Enclosure 1 of Attachment 1 16.00 (REF) 2.59 K

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Serial No.12-636 Relief Request RR-04-13 Docket No. 50-336 Enclosure 2 of Attachment 1 Enclosure 2 (of Attachment 1)

Dominion Procedure MP-PROC-000-ER-AA-NDE-UT-701, "Nondestructive Examination Procedure"

Nuclear Fleet DNondestructive Examination Procedure

Title:

Ultrasonic Thickness Measurement Procedure Procedure Number Revision Number NPQR Number ER-AA-NDE-UT-701 5 ER-AA-NDE-UT-701 -NPQR, Revision 0 Approval signatures on file with approval documentation for this procedure revision.

R. T. Stack 02/26/2011 Independent Level III Review Date K, J. Hacker 02/2612011 Corporate Level III Approval Date J.W. Niemerg 02/26/2011 ANII Date Level of Use: Reference

DOMINION ER-AA-NDE-UT-701 Revision 5 Page: 2 of 11 Record of Revision Rev. Page# Paragraph # Summary of Revision 0 All All New issue as Dominion Nuclear Fleet Procedure.

1 4 2.3 Added "couplant" 4 5.1.1 Added the option for using other gauges/scopes with Level III approval.

5 5.2.4 Deleted requirements for using dual element transducers for measuring through coatings.

6 6.2.2 Deleted requirements for using the multi-echo technique.

6 7.1 Deleted reference to multi-echo technique.

6 7.2 Deleted limitation of single-echo technique for non-coated surfaces.

6 7.3 Deleted (multi-echo requirements) 6 7.3.1 Deleted (multi-echo requirements) 7 8.5 Deleted (multi-echo requirements) 8 9.8 Added new paragraph for guidance for evaluating thickness results for coated surfaces.

2 4 5.1 Added new paragraph for equipment to comply with ER-AA-NDE-130 requirements.

5 5.6.1 Provide allowance for using the component being examined as the reference standard for calibration.

6 8.4 Clarified the guidance for selecting the calibration points for calibration.

10 10.2 Added new paragraph for data records to be processed in accordance with ER-AA-NDE-1 40 requirements.

3 4 3.1 Updated reference to the 2004 Edition.

4 4 1.1 Updated the type of UT equipment displays to include A-scan and direct thickness readout.

4 2.1 Reduced the minimum thickness range from 0.050" to 0.025".

Allowed the examination of components outside the specified range provided demonstrated through the calibration process and Level III approval.

4 4.1 Clarified the Level 11-L qualifications by adding straight beam qualification.

5 5.2.1 Identified the ultrasonic instrument requirements based on display.

5 5.3.1 Increased the upper range of search unit frequency from 10 MHz to 20 MHz to address thinner limits of the procedure.

5 5.3.4 Included the use of delay lines for high temperature or improved near surface resolution is required.

6 5.7.1 Changed to require the use of temperature measurements only for high temperature components.

8 8.7 Changed to require the use of temperature measurements only for high temperature components.

9 9.7 Included additional guidance for addressing areas of laminations with lower frequency search units.

DOMINION ER-AA-NDE-UT-701 Revision 5 Page: 3 of 11 Rev. I Paae # ParaaraDh # Summarv of Revision 5 6 5.3.2 Modified the search unit size to "should" and added criteria for resolution capabilities when using smaller search units.

DOMINION ER-AA-NDE-UT-701 Revision 5 Page: 4 of 11 Table of Contents 1.0 Purpose ........................................................................................................................... 5 2.0 Scope .............................................................................................................................. 5 3.0 Reference Documents ................................................................................................ 5 4.0 Personnel Qualifications ............................................................................................. 5 5.0 Equipment and Material Requirements .................................. 5 6.0 Examination Requirements ........................................................................................ 7 7.0 Thickness Measurement Technique ............................................................................ 7 8 .0 C a lib ra tio n ....................................................................................................................... 7 9.0 Exam ination ..................................................................................................................... 9 10.0 Data Recording ........................................................................................................... 10

DOMINION ER-AA-NDE-UT-701 Revision 5 Page: 5 of 11 1.0 Purpose 1.1 The purpose of this procedure is to provide a process for the calibration and application of straight beam ultrasonic techniques for performing thickness measurements utilizing equipment with A-scan display or direct thickness readout with A-scan displays.

2.0 Scope 2.1 This procedure is applicable to the manual, pulse echo, straight-beam, longitudinal wave, contact ultrasonic technique for performing thickness measurements of ferritic or austenitic tubing, piping, vessels, and components in the nominal thickness range of 0.025 to 20.00 inches. Thickness measurements may be taken outside of the specified nominal thickness ranges provided the equipment capabilities is demonstrated through the calibration process and Level Ill approval is documented on the examination record.

2.2 Examinations may be conducted from the inside (ID) or outside (OD) surfaces.

2.3 The temperature of the component being examined should not exceed the manufacturer's maximum temperature for the search unit or couplant being used.

3.0 Reference Documents 3.1 ASME Boiler & Pressure Vessel Code,Section V, 1989 Edition through the 2004 Edition, Article 23, SE-797, Standard Practice for Measuring Thickness by Manual Ultrasonic Pulse-echo Contact Method.

4.0 Personnel Qualifications 4.1 The examiner shall be certified to Level II-L (limited to straight beam or thickness measurements), Level II, or Level Ill in the ultrasonic method in accordance with Dominion's written certification practice. The examiner shall be responsible for and shall accept the results of the examination.

4.2 An assistant qualified to at least a Level I in the ultrasonic method in accordance with Dominion's written certification practice may assist the examiner. The Level I shall work under the direct supervision of the examiner and shall not evaluate or accept the examination results.

5.0 Equipment and Material Requirements 5.1 All equipment and materials used to implement this procedure shall comply with the requirements of ER-AA-NDE-130, "Storage and Control of Calibrated NDE Equipment, Calibration Standards, and Consumable NDE Materials".

DOMINION ER-AA-NDE-UT-701 Revision 5 Page: 6 of 11 5.2 Ultrasonic Instruments 5.2.1 Approved pulse echo ultrasonic instruments shall provide either a direct A-scan display or a combination of an A-scan display with direct thickness readout. An acceptable calibration in accordance with this procedure demonstrates acceptable ultrasonic instrument selection for use.

5.3 Search Units 5.3.1 Search units with a nominal central frequency in the range of 5.0 to 20.0 MHz should be selected for performing thickness measurements.

For thicknesses 0.050" and less the search unit frequency shall be 10.0 MHz or higher. Other frequencies between 1.0 and 5.0 MHz may be used when their properties (i.e., sensitivity, penetration, resolution, etc.)

provide superior results.

5.3.2 The search unit active element size should be between 0.10" and 1.00" square inches, however smaller search units may be used provided the resolution capabilities of 5.3.5 are maintained.

5.3.3 The search unit elements shall be round.

5.3.4 Either single or dual element search units may be used. Delay lines may be used for high temperature components or when improved near surface resolution is required.

5.3.5 Proper search unit selection (size, shape, configuration, frequency) will be indicated by the systems ability to properly display and resolve the calibration standard's reflections throughout the range of the expected thickness measurements for the component to be examined.

5.4 Cabling 5.4.1 The interconnecting cable between the search unit and the ultrasonic instrument shall be RG-58 or RG-174 type coaxial cable (or equivalent) with lengths not to exceed 20 feet.

5.5 Couplant 5.5.1 A suitable liquid couplant medium shall be applied to the examination surface for the examination. The couplant shall be approved for use at the site prior to use. The same couplant used for calibration shall be used to perform the examination.

DOMINION ER-AA-NDE-UT-701 Revision 5 Page: 7 of 11 5.6 Reference Blocks 5.6.1 Reference blocks used for screen distance calibration and verification shall be of the same material as the component material being examined (e.g. carbon steel or stainless steel). As an alternative, the component being examined may be used for calibration. The reference block or component used for calibration must be of known thickness to allow for accurate calibration.

5.7 Thermometer 5.7.1 When required (high temperature components >- 125' F), a calibrated surface thermometer shall be used to document the surface temperature of the reference block and component prior to the examination.

6.0 Examination Requirements 6.1 Examination Area 6.1.1 The extent of the area to be examined and the criteria, by which the ultrasonic measurements and part acceptability will be evaluated, shall be determined by the parties requesting that the examination be performed.

6.2 Surface Condition Requirements 6.2.1 The examination surface shall be free of irregularities, loose material, or loose coatings which interfere with the ultrasonic wave transmission.

Areas where ultrasonic contact is inadequate shall be documented as limitations.

7.0 Thickness Measurement Technique 7.1 Thickness measurements shall be taken using the single echo measurement technique.

7.2 The single echo technique measures the total thickness of the part using a single backwall reflection. This measurement includes any coating which may be present on the surface, leading to an error in the actual base material thickness.

8.0 Calibration 8.1 Calibration shall include the complete UT system. Any change in search units, couplant, cables, instruments, or any other part of the system shall be cause for calibration verification.

DOMINION ER-AA-NDE-UT-701 Revision 5 Page: 8 of 11 8.2 The calibration shall be performed with a reference block meeting the requirements of section 5.6.

8.3 System setup and calibration (zero, velocity, gain, time base, etc.) shall be performed in accordance with the operating manual for the ultrasonic instrument being used for the examination based upon the selected parameters of the examination (i.e,, measurement technique, material, thickness ranges, search units, etc.).

8.4 The calibration shall utilize two points of known thickness. The calibration points may be single backwall reflections or backwall multiples of known thicknesses.

When available, the calibration points should be equal to or greater than the nominal thickness being examined and a thickness less than the nominal thickness being examined.

8.5 Upon completion of the system setup and calibration, couple the search unit to each of the thickness steps of the reference block used for calibration and verify that the readings are within +/-0.002 inches of the as-built thickness dimension.

8.6 Calibration Verification 8.6.1 System calibration shall be checked using the appropriate reference block. Thickness reading of the calibration points shall be recorded during the initial calibration and shall be verified at the following intervals:.

8.6.1.1 At the start and finish of each examination; 8.6.1.2 With any change in examination personnel; 8.6.1.3 Whenever the instrument has been turned off and then turned on; 8.6.114 When there is a change in search unit, cable, or couplant; 8.6.1.5 At intervals not to exceed four hours; 8.6.1.6 Whenever the validity of the calibration is in doubt.

8.6.2 If any calibration thickness point changes by more than 0.005 inches, the following shall be performed:

8.6.2.1 Void all examinations referring to the calibration in question and performed after the last valid calibration check; 8.6.2.2 Conduct a new calibration;

DOMINION ER-AA-NDE-UT-701 Revision 5 Page: 9 of 11 8.6.2.3 Reexamine all areas for which the examinations have been voided, 8.7 For thickness measurements on high temperature components (2>125° F) the examination surface shall be within 250 F of the reference block used for calibration. The thermometer identification and surface temperatures shall be documented on the data sheets.

9.0 Examination 9.1 The examination shall be performed using a 100 percent scan, partial scan, or spot check scanning technique. The type of scan required for each component shall be defined by the parties requesting that the examination be performed. The types of scans are defined as follows:

9.1.1 100 Percent Scan - This examination will encompass the complete component. )t is a detection, as well as a measuring technique, and should be utilized to detect the thickest and thinnest areas or when encountering inclusions, laminations, or rapidly changing thickness (i.e.,

erosion/corrosion).

9.1.2 Partial Scan - This examination covers only a percentage of the component being examined. The percentage should be based on the requirements of the examination. This technique should not be utilized if finding the thickest or thinnest area of the component is required.

9.1.3 Spot Check - This examination is a point-to-point -technique which measures the thickness of the component at predetermined grid locations. It should not be utilized to detect the thickest or thinnest area of the component being examined.

9.2 Thickness readings should be taken using similar couplant thickness and search unit pressure as used for the calibration.

9.3 For dual element search units ensure that the acoustic barrier between the search unit elements is aligned perpendicular to the axis of the pipe to eliminate the effects of the curvature on the UT measurements.

9.4 Thickness readings shall be recorded as required (manually or data logger/recorder).

9.5 The thickness readings taken during an examination should be reviewed at the conclusion of the examination to ensure that no unusual readings exist and that the examination is complete. If there are any erroneous or missing readings, those areas should be reexamined to ensure accurate examination results,

DOMINION ER-AA-NDE-UT-701 Revision 5 Page: 10 of 11 9.6 Where available, the digital readout should be utilized as the primary source for thickness readings. The A-Scan display should be monitored to ensure that thickness readings taken are "true" readings and not the result of couplant readings, inclusions, laminations, etc.

9.7 If inclusions or laminations are encountered, the area should be scanned and marked to properly bound the region. The depth(s) of the inclusion(s) or lamination(s) should also be recorded and documented, as necessary. When areas of laminations are identified, the area of lamination should be examined with a lower frequency search unit to reduce the limited area examined. Lower frequency search units will often penetrate thin/tight laminations due to the increased penetrating power of the longer wave length.

9.8 For components examined through coatings, the coating thickness will cause a slight increase in the recorded thickness from the actual thickness of the component. Although this increase is small, coating with reported thicknesses near the minimum wall thickness (minimum wall +0.015") should be evaluated to determine if the coating should be removed and the actual thickness verified.

9.9 Upon completion of the examination the excess couplant shall be removed.

Supplies and equipment shall also be removed from the examination area.

10.0 Data Recording 10.1 Calibration and examination data shall be recorded on data sheets and -as a minimum shall include the following:

10.1.1 Calibration sheet identification.

10.1.2 Names and certification levels of examination personnel.

10.1.3 Examination procedure number and revision.

10.1.4 Reference block identification.

10.1.5 Ultrasonic instrument serial number, manufacturer, and model identification.

10.1.6 Ultrasonic instrument settings.

10.1.7 Search unit manufacturer, model, and manufacturer's serial number.

10.1.8 Search unit nominal frequency, size, shape, and number of elements.

10.1.9 Special search units, wedges, shoe type, or saddle's identification, delay line, if used.

10.1.10 Search unit cable type, length, and number of intermediate connectors.

DOMINION ER-AA-NDE-UT-701 Revision 5 Page: 11 of 11 10.1.11 Times and dates of initial calibration and subsequent calibration checks including the thickness measurements of the calibration points.

10.1.12 Signal response amplitudes and sweep positions obtained from the calibration reflectors.

10.1.13 Couplant type and batch number.

10.1.14 Identification and location of the component scanned.

10.1.15 Surface from which the examination is conducted.

10.1.16 When applicable, the temperature of the reference block and component along with the thermometer manufacturer, model, and serial number.

10.1.17 The type of scan completed, i.e. 100 percent scan, partial scan, or spot check. For partial scans, record the approximate percentage of each section examined.

10.1.18 Examination results (thickness readings) including limitations of the area scanned. When using data loggers/recorders the data printout may be attached to document the thickness measurements.

10.1.19 A drawing or photograph of the component should be included with the examination records when possible.

10.2 All data records shall be reviewed and processed in accordance with ER-AA-NDE-140, "Processing of Dominion NDE Data".

Serial No.12-636 Relief Request RR-04-13 Docket No. 50-336 Attachment 2 ATTACHMENT 2 ETE-CME-2012-1024, Revision 2, Structural Integrity Evaluation of Degraded Flange in B Service Water Pipe to EDG Spool SK-2963 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 1 of 46 Engineering Technical Evaluation Cover Sheet XDnominion-CMA-T I10 ATAHMN 2, Pae11 f1

1. Stations Doc Type: Sub Type: 2. Document Number 3. Rev # 4. Decomissioning?

V MP 0 SU [] NA F] KW F] CO ETE 000 ETE-CME-2012-1024 2 FD Yes [ No (Note: If both SU and NA, then check CO) 5.

Title:

Structural Integrity Evaluation of Degraded Flange in "B" Service Water Pipe to EDG Spool SK-2963

6. ETE Level 7. Unit(s) 8. Quality Classification 9. FSRC Approval Req.?

D] Levell ] Levelll [] Unit1 2 Unit2 [] Unit33] ISFS1 IF SRR ] NS D NSQ [ Yes [Z No 110. Preparation,Review, and Approval Signatures(add or delete rows as needed)

StandardAttachments Attachment # of pages Reviewed/No Not Req.

Impact

11. Design Effects and Considerations (DNES-AA-GN-1003) Att#1 1 Eli

12. Document Impact Summary (DRUL) (DNES-AA-GN-1002) Att#2 1 D

13. Considerations and Conditions for Document Updates (check N/A 77 if no document updates are noted on the DRUL)

D] All Document updates noted on the DRUL can be initiated immediately D Document updates noted on the DRUL are delayed until the following documents/actions are completed:

(e.g., WO, CR etc.) (See DRUL Remarks section)

IOCFR50.59 Attachments Attachment # of pages Not Req.

14. 10CFR50.59/72.48 applicability review forms (DNAP-3004 or CM-AA-400) Att#3 E_

15. 10CFR50.59/72.48 screen form (DNAP-3004 or CM-AA-400) __

16. 10CFR50.59/72.48 evaluation form (DNAP-3004 or CM-AA-400) __

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PMPe Page 2 of 46 Engineering Technical Evaluation

~ Dominjionr Cover Sheet 1 - I- - I 0

17. Additional Attachments Attachment # of pages Description - SK-2963 Flange UT 20 Measurementsd - Approximated 1 Degradation of Flanged - Email: Regarding 2 Electrical Isolation of Flanged Joint of SK-2963 - Anticipated Corrosion 2 Add Description Rate Following the Installation of the Insulator Kits on SK-2963 - Email Regarding 2 Add Description Millstone Unit 2 SW Degdation Relief Request 0 - Corrtech Data Sheet 2 Indicating Electrical Isolation of the Flanged Joint of SK-2963 - Diagram of Ligament 1 Calculation

18. Distribution Primary Recipient(s): (Enter the Name / Dept or Location for EACH Primary Recipient in this block.)

Copy To? Other Recipient / Department or Location Copy To? Other Recipient/Department or Location F] Preparer [ Dundon, Edward F W Reviewer [ Fiala, Michael P D] Supervisor Wagnecz, Laura D F,/ Site DCE D] Affected organization D Program Owners 1.0 Table of Contents N/A 2.0 Source Document CR489553 - "Corrosion Rate for spool SK2963 outlet flange exceeds rate assumed in OD000502." dated 09/27/2012 for the Unit 2 service water 10" diameter lightweight flange attached to spool piece SK-2963 in the "B"service water supply.

CR488814 - "UT of Coated Carbon Steel Flange Adjacent 6% Molybdenum Stainless Steel indicates Damage to Carbon Steel," dated 09/20/2012 for the Unit 2 service water 10" lightweight flange attached to spool piece SK-2963 in the "B" service water supply.

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 3 of 46 IEngineering Technical Evaluation Cover Sheet Dominion-CMA-T I0 ATTCH-N 2.ae3 f1 3.0 Record of Revision Revision 0 - Original Revision Revision 1 - Updated in this revision is the most current UT thickness readings and the corrosion rate of the lined carbon steel assuming that new stud insulator kits have been installed and tested to show electrical isolation consistent with industry standards (Assumption 2). Additionally, this revision identifies the maximum allowable corrosion rate based upon the the 30-day mission time and the upcoming Unit 2 Outage (2R21) and the entry into Mode 5.

Revision 2 - Unexpected delay of insulator kit installation resulted in more degradation than considered in Revision 1.

Updated in this revision is the most current UT thickness readings after the installation of the stud insulator kits on the carbon steel flange of pipe spool SK-2963. Operating experience from the failure of the flange on pipe spool SK-2952 from the "A" service water train that failed 1 year ago, has been incorporated.

4.0 Purpose This revision of the ETE re-evaluates the structural integrity and the minimum required wall thickness for pressure boundary leak integrity of a degraded slip-on flange located on 10" service water supply line to "B" Emergency Diesel Generator (1 0"JGD-4 spool SK-2963). The purpose of this evaluation is to support OD000502 and demonstrate the continued operability (inclusive of 30-day post accident mission time per reference 12 and 13) of the MP2 B service water supply header. The structural integrity review considers all loading conditions (i.e. deadload, seismic and thermal).

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 4 of 46 Engineering Technical Evaluation Dominion- Cover Sheet CMA-T-0 ATAHMN 2. Pae4 f1 5.0 Design Inputs and Assumptions Design Inputs

1. Ultrasonic Testing per the AWO 53102516395 - Reference 2 (Attached).

2. Sketch of flange degradation from NDE group (calculated ligament length was verified by engineering) - Attachment 5.

Assumptions

1. It is assumed that UT is adequate for supporting the structural integrity assessment. However it is noted the UT is not capable of identifying potential through wall flaws due to attack of the grain boundary, which may result in minor or unanticipated leakage. This assumption is covered in this evaluation as any identified pressure boundary flange leakage will make the flange inoperable and the appropriate TRM or T/S shall be entered. These UT inspections are not considered Code compliant inspections because of the interferences [due to bolting, flange configuration and flange surface characteristics]

involved with taking the measurements. In addition these are not Code required inspections.

As a result of issues related to service water pipe degradation, mockups have been utilized at the station to validate the accuracy of UTs for the determination of wall thickness. In addition, use of UTs to determine flaw characteristics was discussed with the corporate level III inspector and he concurred that the use of UTs is valid for this application.

2. On 9/27/2012 testing of the dissimilar metal flanges on pipe spool SK-2963 identified an electrical short between the AL-6XN and lined carbon steel flange. Based on station operating experience, the methodology and material used to install the insulating kit at this flange may not have been adequate to electrically isolate the dissimilar flanges and may have accelerated the galvanic corrosion identified in UT data from 9/20/2012 to 9/27/2012 at UT point 4, positions 5, 8, 9, 11 and

12. Therefore, the assumed corrosion rate 0.200"/yr is used to determine the ligament length for pressure boundary integrity and the 30-day mission time is based on the installation of the new stud insulator kits which have shown to provide electrical isolation that is consistent with standard industry experience (Attachment 9 & 10).

3. Corrosion on a day-to-day basis is assumed to vary, based on uncertainty. Therefore an absolute value to reach the Unit 2 Outage (2R21) is provided to elminate variance in the daily UT data.

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 5 of 46 Engineering Technical Evaluation Dominion- Cover Sheet a ... I 6.0 Methodology Because no NRC approved methodology is available to evaluate flanges, a methodology is developed here. The objective is to assess the applied piping design loads at the flange (as documented in the stress calculation of record Reference

5) compared to a conservative assessment of the extent of remaining flange material (based on bounding the degradation documented in UT examination report Reference 2). The pressure boundary leak integrity is based on the minimum wall thickness and documented corrosion rates are calculated to demonstrate that the "B" service water system will remain operable during a postulated 30-day mission time post accident (Section 14.8.4.3 of Reference 10 and Reference 13).

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 6 of 46 Engineering Technical Evaluation DOomninjio Cover Sheet II

I. .

7.0 Discussion CR 488814 was generated on 9/20/2012. The CR included the associated UT data (attached to the CR), which documented a slip-on flange exhibiting degradation. The UT that was performed was not a Code required inspection. The subject flange is located on the Millstone Unit 2 "B"service water supply train to the "B" emergency diesel generator (10"-JGD-4). The degraded light weight flange is lined carbon steel and is at the downstream end of spool piece SK-2963 as shown on drawing 25203-20150 Sh. 472 (Ref. 3). The degradation is suspected to be the result of a failed lining and the formation of a galvanic cell.

CR489553 was generated on 9/27/2012. A week following the initial examination period of the carbon steel flange of the dissimilar metal joint on pipe spool SK-2963, this CR determined that based on UT data, the corrosion rate used in revision 0 of this ETE was non-conservative. The corrosion rate used (0.067"/month) was based upon corrosion rates previously identified in the carbon steel side of the dissimilar metal flange joint in pipe spool SK-2952 on the "A"train (Ref. 9) and based upon industry operating experience. Consistent UT data between 9/20/2012 and 9/28/2012 indicated that locally a corrosion rate as high as 0.244"/month was occurring (1.900"-1.835"=0.065", 0.065/8 days = 0.0081", 0.0081"*30 days/month = 0.243". Updated corrosion rates (0.200"/year) utilized in this ETE are based upon assumption 2 in Section 5.0 and attachment 8.

Flange insulator kit installation for the flange on pipe spool SK-2963 began on 9/28/2012 and ended on 9/30/2012. UT readings between the 2-day installation indicate that at UT point 4, position 9, a wastage from 1.835" to 1.826" occurred before the installation of the insulator kits. Further analysis is performed below to show this change in material thickness.

The flange face nominal thickness is 11/16" and the nominal flange hub thickness is 5/8" (Reference 8). The pipe stress calculation uses an operating temperature range of 33F to 80F and the conservative pressure of 150 psig per Reference

5. The system maximum operating pressure is 80 psig per reference 11. The system design pressure is 100 psig at the flaw location per reference 11, but 150 psig was conservatively used for the pipe stress analysis qualification calculation.

Structural Integrity Assessment:

Currently there is no NRC approved methodology for ASME Code acceptance of flaws in moderate energy Class 3 flanges.

ASME Code Case N-513-2 (Reference 4) provides NRC approved flaw acceptance methodology for Class 2 or 3 piping, but specifically excludes application to a flanged joint.

Because no NRC approved methodology is available to evaluate flanges, a methodology is developed here. The objective is to assess. the applied piping design loads at the flange (as documented in the stress calculation of record, reference

5) compared to a conservative assessment of the extent of remaining flange material (based on bounding the degradation documented in UT examination report, reference 2). A minimum allowable thickness is calculated based upon the minimum thickness needed for pressure hoop stress plus an allowance for 30 days of corrosion to demonstrate that the service water flange will remain operable during a postulated accident and for the 30-day post accident mission time (Section 14.8.4.3 of Reference 10 and Reference 13).

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 7 of 46 Engineering Technical Evaluation Dominion Cover Sheet CMA-T-0 ATAHMN 2 Page The current piping stress analysis run of record is documented in Addendum B of Reference 5. In the piping analysis computer model the subject flange is located at node point 980 (shown in model worksketch sheet 3). The ASME Code equation pipe stresses for Equation 8 (deadweight/pressure), Equation 9 (Occasional deadweight/pressure + Seismic Inertia), Equation 9 Faulted (Occasional deadweight/pressure + Seismic Inertia), Equation 10 (thermal + Seismic anchor motion) and Equation 11 (Deadweight + Pressure + Thermal + Seismic anchor motion) were extracted (stress calculation Attachment B pages 16 and 59) and are shown in Table 1. Also included in Table 1 are the corresponding allowable stresses and percent ratios of the allowables. As shown in the table, the maximum stress percentage at the flange location is 8.25 percent of ASME Code allowable in the non-degraded condition. This low stress condition (8.25% of allowable) provides considerable margin for material degradation while maintaining structural integrity. The reduced load carrying capability of the flange is proportional to the reduction in area. Postulating that half of the flange is fully degraded results in an increase of 100 percent of the calculated stresses. This increase in stress will increase the percent ratio of applied to allowable stress from 10 percent (rounded up) to 20 percent leaving 80 percent margin for all postulated design basis events.

Table 1 Node 980 Stress (psi) Allowable (psi) Percent Ratio of Allowable Stress after 100% Percent Ratio of Increase (psi) Allowable Eq 8 Sustained 1238 15000 8.25 2476 16.51 (Deadweight)

Eq 9 Occasional 1436 18000 7.98 2872 15.96 (Normal and Upset)

Eq 9 Occasional 1612 35000 4.61 3224 9.21 (Faulted)

Eq 10 (Expansion 522 22500 2.32 1044 4.64 Stress)

Eq 11 (Deadweight 1760 37500 4.69 3520 9.39

+ Expansion Stress)

The UT examination reports are included in Attachment 4. As shown on pages 2 through 18 of Attachment 4, the UT measurements were performed at 4 points of the flange (See page 20 of Attachment 4). The drawing on page 19 of Attachment 4 identifies the 12 positions on the flange. Positions 5, 9, 11 and 12 under UT Point 4 (in Attachment 4, page 18) show considerably lower thickness values (1.823" to 2.082) than the surrounding locations (-2.500"). UT data indicates that position 8/9 and 11/12 are each likely one area of degradation. This indicates that there are 3 positions on the flange circumference that show degradation. With a total of 12 positions under UT Point 4 measured, the degradation still affects 5/12ths of the circumference of the flange. To allow for potential growth of the flaws, it can be assumed that 6/12ths or half of the flange circumference has been lost to wastage and only half of the flange remains. Based on the extremely low loads (less than 10 percent of the respective allowables) a 50 percent loss of the flange load bearing area and structural load path will not challenge the structural integrity of the remaining 50 percent of the flange, as shown above.

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 8 of 46 Engineering Technical Evaluation Dominion- Cover Sheet CM-AA-ETE-101 ATAHET2 Pg Minimum Wall Calculation for Pressure Boundary Integrity In order to maintain pressure retaining capability and minimize the potential for leakage, the following criteria for determining acceptable pressure retaining capability is used. The minimum wall calculation for pressure boundary integrity is based upon the maximum operating conditions, which is reasonable to maintain operability. However, the pressure boundary integrity for the design pressure is calculated below for reference. Equations for the required pressure boundary integrity (leak tightness) are per ASME Section III, NC-3641.1, 1989 Edition (calculated below):

tm = P x Do / [2 x (S + Py)]

Where P = 80 psi for the maximum operating pressure and 100 psi for the internal design pressure (Reference 11). The thickness value calculated from the equation above uses the maximum operating pressure and is a reasonable value for operability, Do = 12 in, outside diameter of pipe (in this case flange hub) (Reference 8),

S = 15000 psi at a design temperature 100F, allowable stress for ASTM A181, Grade 1 (Reference 7 and 12),

y = 0.4 a coefficient having a value of 0.4 except when Do/tm < 6 (Reference 12),

This criterion is applicable to the face of the flange and to the hub or pipe portion of the flange. Based upon an a maximum operating pressure (80 psig) the minimum wall thickness is 0.032". For reference, the maximum wall thickness when using the design pressure (100 psig), is 0.040". An average wall thickness of less than 0.032 inches as determined from measurements between any two bolts would not meet the minimum required wall thickness required for pressure boundary integrity (leak tightness).

Ultrasonic Testing of flange SK-2963 at Position 9 of UT Point 4 on 9/30/2012 indicated a minimum measurement of 1.823" (See Attachment 4, page 18). Based on nominal flange dimensions, this measurement translates into a remaining ligament length of 0.150". Subtracting 0.032" from the ligament length leaves a potential sacrificial thickness of 0.118".

Maintaining 0.032" of material ensures the minimum wall thickness for pressure boundary integrity (leak tightness). Based upon the achievement of electrical isolation per assumption 2 and the rate of degradation provided by the Millstone Corrosion Analyst (Attachment 8), the annual corrosion rate for the flange is 0.200"/ year (0.017"/month).

Maximum Theoretical Corrosion Rate Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 9 of 46 Engineering Technical Evaluation Cover Sheet Dominion-CM-A-TE10 ATAHET2 Sf1 Pg Therefore utilizing the same minimum calculated ligament of 0.150 (1.823" measurement) identified on 9/30/2012, the maximum rate that can be tolerated until mode 5 of outage 2R21 on 10/7/2012 is 1.164"/year (0.150" - 0.032" = 0.118",

0.118"/(7 days + 30 days (mission time)) = 0.00319"/day or 365 days*0.00319"/day or 0.022" between now and 2R21). This corrosion rate is based upon the remaining time until 2R21 and the 30 day mission time and is not expected to occur. Since the corrosion expands equally in all directions, the UT Point 4 measurement cannot degrade more than 0.022" between now and 2R21 based upon the maximum allowable corrosion rate. The anticipated maximum corrosion rate is 0.200"/year per assumption 2 and Attachment 8. This is described in the section below.

Wall Thickness Margin Calculation Based on UT Readings Based on attachment 8 and assumption 2, the anticipated maximum corrosion rate, after the insulator kits are installed, is assumed to be 0.200"/year. Analyzing the results from 9/30/2012 and incorporating the required 37 days to meet both the mission time and enter the Unit 2 outage 2R21, the wastage over a 37 day period is calculated to be 0.020" using the anticpated maximum corrosion rate of 0.200"/year (0.200"/yr / 365 day/yr = 0.000548"/day, 0.000548"/day *37 Days =

0.020"). The current UT Point 4 measurement extrapolated out to Mode 5 of 2R21 (10/7/2012) plus the 30 day mission time,.

based on the anticipated corrosion rate of 0.200"/year, is 1.803" (1.823" - 0.020" = 1.803").

Because of the conservative requirements of this analysis, the calculated minimum wall thickness required for operability remain less than what was measured at the failed flaw of the "A" train 1 year ago (1.750"). For the current flaw at UT Point 4, position 9, the anticipated measurement should be 1.801" after 37 days of operation.

Operating Experience Ultrasonic testing was performed on the pipe spool (SK-2952) flange that was removed from the "A" service water supply train approximately 1 year ago. Testing from that flange at UT Point 4 indicated a remaining wall thickness of approximately 1.750" around the flaw. Based on the measurement performed on the "A" train flange, UT Point 4 measurements at which the flange is considered inoperable for pipe spool SK-2963, are more conservative (1.801").

8.0 Conclusions This ETE concludes that the structural integrity and the minimum required wall thickness for pressure boundary leak integrity of a degraded slip-on flange located on 10" service water supply line to "B" Emergency Diesel Generator (1 0"JGD-4 spool SK-2963) is sufficient to support OD000502 and demonstrate the continued operability (inclusive of 30-day accident per reference 12 and 13) of the MP2 B service water supply header. This structural integrity review considers all loading conditions (i.e. deadload, seismic and thermal).

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 10 of 46 k Engineering Technical Evaluation Dominion- Cover Sheet.

1 I ... I .

9.0 Precautions or Limitations The type and frequency of the inspections (including UT) shall be performed lAW the requirements of OD000502.

10.0 Required Actions

1. As of 9/30/2012, UT analysis indicates that degradation exists between 5 of the 12 areas between the bolt holes (positions). The degradation is noted at position 5, 8, 9, 11 and 12. Further identification from these areas of degradation has noted that position 8/9 and 11/12 appear to each be one area of degradation under the adjoining bolt hole. Therefore three total areas of degradation are seen. Of the five positions, on 9/30/2012 position 8 and 9 at UT point 4 indicate a thickness of 1.823" while position 11 and 12 indicate a thickness of 1.914" and 1.932", respectively. Position 5 has minimum thickness of 2.082".

Based on the analysis provided, if more than 6 zones are identified with measurements less than 1.900", then the "B" service water system shall be declared inoperable and the appropriate TRM or T/S shall be entered. (Implemented by OD000502, Rev 1.)

2. If at any time a ligament less than 0.128" corresponding to a UT Point 4 measurement reading of 1.801" or less is identified, the service water flange shall be declared inoperable and the appropriate TRM or T/S shall be entered. The ligament value is based on standard flange dimensions, the use of the Pythagorean Theorem and the UT Point 4 measurements. The value of 1.801" represent the one week limit of corrosion on the flanged joint. This limit assumes that uncertainty in the data will vary from day-to-day and is provided as an absolute value to which the flange is considered operable (Implemented by OD000502, Rev. 1).

3. If any through wall leakage at the service water flange is identified, it shall be declared inoperable and the appropriate TRM or T/S shall be entered. (Implemented by OD000502, Rev. 1).

4. A relief request shall be submitted to the NRC. See Attachment 6 (Implemented by CR488814).

11.0 Recommendations N/A Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 11 of 46 IEngineering Technical Evaluation Cover Sheet Dominion-I ..- I 12.0 References

1. CR488814 - "UT of Coated Carbon Steel Flange Adjacent 6% Molybdenum Stainless Steel indicates Damage to Carbon Steel"

2. AWO 53102516395 UT Examination Report - See Attachment 4. Note that there are two sets of data. Those performed on 9/20/2012 entered in UT Point 1, 3 and 4 while those performed on 9/21/2012 entered in UT Point 2. These two data sets are complimentary.

3. Drawing 25203-20150 SH. 472, Rev 11 "Millstone Nuclear Power Station - Unit 2 "B"Train Service Water Supply to Diesel Engine Coolers".

4. ASME Code Case N-513-2 "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section X1, Division 1.

5. Calculation MP58B-00138EM Revision 4, Addendum B "Service Water Supply to Diesel Engine Coolers - Stress Problem 118".

6. Drawing 25203-20224 SH. 60, Rev 3 "Millstone Nuclear Power Station - Unit 2 "B"Train Service Water Supply to Diesel Engine Coolers".

7. Drawing 25203-22200 SH 327141 Rev 4 "Service Water Supply to Diesel Engine Coolers Mark No 327141".

8. Crane Catalog 61, "Welded Fittings, Forged Flanges."

9. Engineering Technical Evaluation ETE-MP-2011-1143, Rev. 0, " Design Criteria for material selection of stainless steel

and nickel based alloys for seawater service applications at Millstone Station (Revision to ETE-MP-2010-1014 rev. 1)."

10. Unit 2 Final Safety Analysis Report, Revision 29.2.

11. Bechtel Piping Spec 7604-MS-1, Piping Class Summary.

12. American National Standard Institute Code for Pressure Piping, ANSI B31.1, 1967 Edition; All applicable addenda up to and including Summer 1973.

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 12 of 46 Engineering Technical Evaluation Cover Sheet Dominion I n ..- I

13. Design Change M2-05009, Rev. 1, "Replacement of ECCS Sump Strainer per Generic Letter 2004-02, GSI-191."

13.0 Attachments Attachment 1 - Design Effects Table (DET)

Attachment 2 - Documents Required to be Updated List (DRUL)

Attachment 3 - Applicability Review Attachment 4 - SK-2963 Flange UT Measurements Attachment 5 - Approximated Degradation of Flange Attachment 6 - Email Regarding Millstone Unit 2 SW Degradation Relief Request Attachment 7 - Diagram of Ligament Calculation Attachment 8 - Anticipated Corrosion Rate Following the Installation of Stud Insulator Kit on SK-2963 Attachment 9 - Email: Regarding Electrical Isolation of Flanged Joint of SKr2963 Attachment 10 - Corrtech Data Sheet Indicating Electrical Isolation of the Flanged Joint of SK-2963 Sep 30, 2012 7:40 PM

Attachment #1 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PMPe Page 13 of 46

.J0 Fon D1omi Design Effects Table DNSA-N10 age 1. of Instructions:

This table will identify impacted programs. If a question is answered yes, the responsible engineer shall address and document in the discussion section of the Design Change. The responsible engineer shall check "No Impact" or "Impact" as appropriate. If necessary, consult the program owner to assist with the determination. If it is determined that there is an impact, identify program owner, check "Impact" in the applicable section, obtain the consulted individual(s) signature on the engineering product cover sheet and document the discussion in the change package. Ifan impact is determined for any program, then relevant portions of this attachment should be attached to the appropriate document. If it is determined that there is "No Impact" in a section where a question is answered "Yes", document the basis for this determination in the change package. When all questions are answered "No" in a particular section, do not check "Impact" or "No Impact."

Station: Unit: ETE Document Number:

" KPS 10 MPS c CO 0 1 022 ETE-CME-2012-1024

" NAPS 0 SPS 03 0 ISFSI Change Document

Title:

Structural Integrity Evaluation of Degraded Flange in "B" Service Water Pipe to EDG Spool SK-2963 1.1 Fire Protection Equipment or Features El Yes 01 No 1.2 Combustible Loading El Yes 2 No 1.3 Hazards and Ignition Sources E0Yes 0 No 1.4 Fire Safe-Shutdown Analysis El Yes 10 No 2.0 Environmental Qualification (EQ) El Yes 0 No 3.0 ASME Codes / ISI / IST El Yes 10 No 3.1 Inservice Inspection El Yes 0 No 3.2 Inservice Testing El Yes 0 No 4.0 Regulatory Guide 1.97 - Post Accident Monitoring El Yes 02No 5.0 Maintenance Rule El Yes 0 No 6.0 Radiological Protection Program (ALARA) El Yes 0 No 7.0 Environmental Impact (Non-Radiological) El Yes 0 No 8.0 Nuclear Material Control El Yes 10 No 9.0 License Renewal Rule Program and Aging El Yes 01 No Management Activities 10.0 Generic Letter (GL) 89-13 Program 0. Yes 01 No 11.0 Station Blackout (SBO) El Yes 01 No 12.0 Appendix J Program 0 Yes 0 No 13.0 NERC - North American Electric Reliability El Yes 01 No Council 14.0 GSI-191 (Containment Recirculation Sump) El Yes 01 No Considerations

Attachment #2 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 14 of 46 Documents Required To Be Updated List (DRUL)

SDominion ,E-AG1 002 A H 21 Pg 1 STATION UNIT I ETE Document Number C KPS 0 MPS 0 NAPS 0 SPS C CO C 1 02 0 3 CISFS1 ETE-CME-2012-1024 Operations Critical Documents Needed N/A Department I Contact Impacted Document Number and/or Title Closeout Documents Needed N/A Department / Contact Impacted Document Number and/or Title Remarks (Attach additional pages if needed):

Attachment #3 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 15 of 46 50.59 / 72.48 Applicability Review Applicable Station Applicable Unit(s) ISFSI Parent Document/Revision r7 North Anna Power Station r- Unit 1 r- Unit 2 r-. ISFSI ETE-CME-2012-1024 Rev. 2 Ir Surry Power Station r.: Unit 1 FI Unit 2 fr ISFSI F Millstone Power Station I Unit 1 F Unit 2 r- Unit 3 r- ISFSI IT Kewaunee Power Station IT Unit 1 IT ISFSI Part I. Brief Description of Activity Being Reviewed (See Attachment 2, Part I)

Structural integrity determination and flow loss evaluation of degraded service water flange on "B" serivce water supply to EDG service water header (spool SK-2963)

Part II. Activity Previously Reviewed (See Attachment 2, Part II)

Is this activity Fully bounded by one or more of the following?

1. Fullt bounded by a IT YES F NO r- Attached (optional) - If YES, identify bounding source document completed 50.59/72.48 Screen or Evaluation?

2. fuliyt bounded by a station I- YES 7 NO IT- Attached (optional) - If YES, identify bounding source document activity that has already received NRC approval?

PART II. CONCLUSION F Both of the above review questions are answered NO, continue the Applicability Review f7 One of the above review questions is answered YES, a 50.59/72.48 Screen is NOT required; complete Parts V, VI, VII Part III. Controlled by Other Regulatory Change Control Process (See Attachment 2, Part III)

Check if any of the following documents are identified as part of the proposed activity.

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to one of these documents which have a different change control process and are NQT to be included in this 10 CFR 50.59/72.48 review.

1 Technical Specifications or Operating License 2 Emergency Plan rF 3 Security Plan FT Fire Protection Program and is NOT associated with ISFSI 17 4

Quality Assurance Program Description FT 5

F 6 Inservice Test Plan - IST 7 Inservice Inspection Plan - ISI F 8 ECCS Analysis 9 Environmental Protection Plan r 10 Radiation Protection Program 11 Radiological Environmental Monitoring and Offsite Dose Calculations Manual IT 12 Reactor Vessel Surveillance Withdrawal Schedule FI PART III. CONCLUSION F If there are no documents selected, continue the Applicability Review.

r. One or more of the documents listed above are selected, ANM the proposed activity is limited to changing those documents, a 50.59/72.48 Screen is NOT required; complete Parts V, VI, VII.

fT One or more of the documents are selected, however, some portion of the activity involves facility or procedure changes; continue the Applicability Review for that portion.

Part IV.1 General Pre-Screen for Maintenance - Not Applicable to ISFSI (See Attachment 2, Part IVA)

1. Is this a maintenance activity limited to restoring an SSC to the normal as designed condition AND r- YES rv NO does NOT permanently alter the design, performance requirements, operation or control of SSCs?

2. Is the activity limited to installing or testing approved facility changes? F- YES r7 NO Part IV.1 CONCLUSION

[F Both of the above review questions are answered NO, all or some portion of the activity extends beyond maintenance; continue the Applicability Review for non-maintenance activities.

r- One of the above review questions is answered YES, the activity is subject to review per the Maintenance Rule; a 10 CFR 50.59/72.48 Screen is NOT required; complete Parts V, VI, VII.

Attachment #3 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 16 of 46 50.59 / 72.48 Applicability Review 5100 miniendi" CMAA40 Atahet1

- .g~f Part IV.2. General Pre-Screen (See Attachment 2, Part IV.2)

Does this activity accomplish any of the following?

1 Does this activity involve any changes to the ISFSI written evaluations required by 10CFR72.212? F_ YES 17 NO 2 Does this activity involve fire protection activities associated with the ISFSI? - YES F NO 3 Does this activity involve maintenance activities on the ISFSI? r YES 7 NO 4 Does this activity alter (temporarily or permanently) the design of an SSC through a modification or f YES P NO addition to, or removal from the facility as described in the SAR?

5 Does this activity alter (temporarily or permanently) the function, ability to function, or method of r7 YES F NO performing a function of an SSC as described in the SAR?

6 Does this activity modify how SSCs are operated or controlled as described, outlined, or summarized r YES F NO in the SAR?

7 Does this activity change a numeric value of a design or performance requirement of a SAR F YES F NO described SSC to a value that has NOT been previously reviewed in accordance with 10CFR50.59/72.48?

8 Does this activity perform a test or experiment that is NOT described in the SAR? F YES [. NO 9 Does this activity involve a change to a method of evaluation used for evaluating behavior or F YES F NO response of the facility or an SSC described in the SAR?

10 Does this activity involve a temporary modification? r YES F NO PART IV.2 CONCLUSION 1 All Pre-Screen questions are answered NO, a 50.59/72.48 Screen is NOT required; complete Parts V, VI, VII F One or more Pre-Screen questions are answered YES, perform a 50.59/72.48 Screen per Attachment 3 and complete Parts V, VI, VII.

Part V. Safety Analysis Report Interface (See Attachment 2, Part V)

Does this activity require revising the Safety Analysis Report? If YES, initiate a Change Request in accordance with CM-AA-SAR-101 and include the Change Request number If YES, additional review required by 50.59/72.48 Screen Preparer/Reviewer if Applicability Review F YES F NO Preparer and Co-signer (when required) are NOT 59.59/72.48 Screen qualified.

Part VI. Comments (use supplemental pages as needed)

(Examples: Identify any 50.59/72.48 Screen or Evaluation, or NRC approved activity that contributes to this review, identify parts of the activity that are bounded or not bounded by a previously completed review or that are NOT part of another change process, identify the source document supporting a numeric value previously reviewed per 10 CFR 50.59/72.48)

This ETE performs a technical evaluation of a non-code compliant degraded piping component in support of an Operability Determination.

Question 4 of Section IV.2 would be answered yes as the flange is not in its original configuration per ASME B16.1/16.5 due to the effects of corrosion. However, due to program limitations, Question 4 has been selected as no. The 50.59 review process is being exited as a relief request will be submitted to the NRC for review per attachment 6.

Part VII. Signature Preparer Name (Print) Preparer Signature Date Digitally Signed by Zachary A Withrow 09/21/2012 09:46:59 PM Form No. 729534 (Jun 2010)

DRAFT ETE-CME-20 1 2 -1024 Report Generated on 9/30/2012 7:40:57 PM Page 17 of 46 Exam Data Sheet Attachment 4 - Page I of 20 Millstone Power Station ULTRASONIC EXAMINATION STRAIGHT BEAM MEASUREMENTS Plant Millstone Unit 2 Page I of 2 System & Zone No. "B" Train Service Water /3326 Exam Data Sheet No N/A Component ID SK-2963 AWO Number 53102516395 Component Des o ool SK-2963 DrawingNo2.2963 Examination Purpose Engineerin Information Line No. l0"-JGD-4 Instrument & Settings Calibration Block(s) Component Data Manufacturer Olympus Type Serial No. Material Component T.o, N/A Model No, 38 DL Plus Step Wedge 95-5768 C/S Component Dia. 10" .

Serial No. 100030807 Step Wedge 99-6791 C/S Attachments. yes Range 3,0" Velocity .2326 Calibration Checks Block Thickness Instrument Reading Delay N/A Type Time Min. Max. Min. Max.

Zero Value 26570 Initial 13:50 .250" 1.00" .250" 3,00" Cal Tolerance 1.002" 'Intermediate N/A N/A N/A N/A N/A Intermediate N/A N/A N/A N/A N/A Search Unit Data Final 14:15 0 1.00" .250" 3.00" Manufacturer Panametrics Type No. D791-RM Couplant Data Temperature Data Serial No. 109450 Brand Ultraget I1 Cal. Block Temp. N/A Frequeney 5.0 MHz Batch No. 11225 G Component Temp. N/A Size 0.2" SAP Batch Mgmt. No. N/A Thermometer No. N/A See Attachment for Detailed Examination Results Examiner (print & sign) Todd Bohnenkamncr / - Level 1I Date 09/19/20.12 Reviewer (sign)Reuied(Level.) N.Date N/A Date ANI/ANII If Required (Sign) N/A -Date N/A

'el of Use ;$& ~ A ER-AA-NDEI-UT-701

"*ren ]ce

Attachmnent #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 18 of 46 Attachment 4 - Page 2 of 20 Millstone Unit 2 Page 2 of 2 Service Water System "B" Trin Component lDit-2963 0( ilange on spool SK-2963)

WO #: 53102516395 Position UT Point I UT Point 2 UT Point 3 UT Point 4 1 0.405 N/A 0.816 2.520 2 0.388 N/A 0.822 2.520 3 0.380 N/A 0.816 2.520 4 0.389 N/A 0.823 2.500 5 0.399 N/A 0.810 2.100 6 0.405 N/A 0.808 2.530 7 0.411 N/A 0.803 2.530 8 0.414 N/A 0.809 2.180 9 0.409 N/A 0.812 1.900 10 0.415 N/A 0.826 1.910 11 0.410 N/A 0.822 .530 12 0.387 N/A 0.824 1.900 Comments: Position 1 at elbow extradose. All positions run in clockwise direction wit,-,

in diffic' Illegible note Note: UT readings obtained on painted surface which could result indicates that obtaining UT data at sorne locations. No UT readings at point 2. Rough wel Position 10 and 11 surface does not provide for consistent UT p~oin* should be switched.

-7 1< r~)zu O)PEU P)NY2(htCn tb qOY1.7

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 19 of 46 Attachment 4 - Page 3 of 20 Millstone Unit 2 Page 2 of 2 Service Water System Component ID: SK-2963 (Outlet flange on spool SK-2963)

WO #: 53102516395 Position UT Point I UT Point 2 UT Point 3 UT Point 4 1 N/A 0.541 N/A N/A 2 N/A 0.535 N/A N/A 3 N/A 0.574 N/A N/A 4 N/A 0.549 N/A N/A 5 N/A 0.549 N/A N/A 6 N/A 0.555 N/A N/A 7 N/A 0.543 N/A N/A 8 N/A 0.539 N/A N/A 9 N/A 0.513 N/A N/A 10 N/A 0.526 N/A N/A 11 N/A 0.518 N/A N/A 12 N/A 0.487 N/A N/A Comments: Position 1 at elbow extradose. All positions run in clockwise direction with flow. Note: UT readinqs obtained on painted surface which could result in difficulty in obtaining UT data at some locations. Readings at UT point 2 obtained on irreaular or uneven surfaces due to weld configuration and may not provide for consistent repeatability of UT readings.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 20 of 46 Attachment 4 - Page 4 of 20 Millstone Unit 2 Page 3 of 3 Service Water System Component ID: SK-2963 (Outlet flange on spool SK-2963)

WO #: 53102516395 Position UT Point 1 UT Point 2 UT Point 3 UT Point 4 1 N/A N/A N/A N/A 2 N/A N/A N/A N/A 3 N/A N/A N/A N/A 4 N/A N/A N/A N/A 5 0.396 0.549 0.806 2.130 6 NIA N/A N/A NIA 7 N/A N/A N/A N/A 8 0.414 0.539 0.809 2.180 9 0.410 0.512 0.819 1.890 10 0.414 0.526 0.828 :1.950 11 N/A N/A N/A 12 0.382 0.486 0.817 1.970 Comments:

I ons.

-C-Di 9 / a-I/ 1Z,

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 21 of 46 Attachment 4 - Page 5 of 20 Millstone Unit 2 Page 3 of 3 Service Water System Component ID:SK-2963 Outlet flange WO #: 53102516395 Position UT Point 1 UT Point 2 UT Point 3 UT Point 4 1 .395" .536" .815" 2.548" 2 .380" .531" .812" 2.575" 3 .373" .574" .813" 2.565" 4 .388" .546" .819" 2.560" 5 .402" .544" .807" 2.130" 6 .393" .551" .802" 2.574" 7 .411" .538" .804" 2.565" 8 .413" .540" .809" 2.182" 9 .412" .515" .819" 1.865" 10 .416" .524" .830" 2.585" 11 .400" .509" .822" 1.933" 12 .381" .489" .818" 1.975" Comments: UT data taken daily in SUDoort of OD 000502.

M C 9/

3 a.I/k Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 22 of 46 Attachment 4 - Page 6 of 20 Millstone Unit 2 Page 3 of 3 Service Water System Component ID: SK-2963 tkut-fl-bT spool SK-2963)

WO #: 53102516395 /09/24/2012 J Position UT PointK UT Pnfi 2 UT Point 3 UT Point 4 1 0.399 0.538 0.815 2.531 2 0.388 0.531 0.815 2.550 3 0.378 0.574 0.814 2.564 4 0.388 0.545 0.821 2.560 5 0.399 0.545 0.808 2.137 6 0.398 0.552 0.805 2.569

.7 0.412 0.541 0.804 2.559 8 0.413 0.539 0.808 2.181 9 0.410 0.514 0.815 1.869 10 0.415 0.525 0.826 2.580 11 0.405 0.512 0.823 1.938 12 0.384 0.486 0.820 1.972 Comments: Position 1 at elbow extradose. Note: UT readinqs obtained on painted surface which could result in difficulty in obtaining UT data at some locations.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 23 of 46 Attachment 4 - Page 7 of 20 Millstone Unit 2 Page 3 of 3 Service Water System Component ID: SK-2 0 te i n96 nspool SK-2963)

WO#: 5310251639r5 09/25/2012__

Position UT PoiotI _.. oint 2 UT Point 3 UT Point 4 1 0.399 0.541 0.815 2.550 2 0.388 0.531 0.814 2.560 3 0.380 0.570 0.814 2.564 4 0.388 0.545 0.821 2.560 5 0.399 0.545 0.810 2.128 6 0.398 0.550 0.805 2.569 7 0.412 0.541 0.806 2.559 8 0.412 0.541 0.808 2.177 9 0.412 0,514 0.816 1.848 10 0.415 0.525 0.826 2.580 11 0.405 0.510 0.823 1.938 12 0.389 0.486 0.819 1.968 Comments: Position 1 at elbow extradose. Note: UT readings obtained on painted surface which could result in difficulty in obtaininci UT data at some locations.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 24 of 46 Attachment 4 - Page 8 of 20 Millstone Unit 2 Page 3 of 3 Service Water System Component ID:SK-2963 Outlet flange WO 1*: 53102516395 Position UT Point 1 UT Point 2 UT Point 3 UT Point 4 1 .393" .536" .817" 2.555" 2 .378" .531" .814" 2.578" 3 .376" .569" .816" 2.570" 4 .393" .544" .820" 2.574" 5 .402" .543" .805" 2.132" 6 .393" .545" .810" 2.578" 7 .405" .548" .810" 2.568" 8 .415" .540" .811" 2.177" 9 .411" .516" .819" 1.855" 10 .415" .528" .826" 2.580" 11 .402" .513" .822" 1.942" 12 .385" .478". .819" 1.965" Comments: UT data taken daily in support of OD 000502.

Attachment #-4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 25 of 46 Attachment 4 - Page 9 of 20 Millstone Unit 2 Page 3 of 3 Service Water System Component ID: SK-2.9.3TuitTeTf Ifae on spool SK-2963)

WO #: 531025163 ,5 09/27/20 Position UT Po'Itt__. -- UT Point 2 UT Point 3 UT Point 4 1 0.399 0.541 0.815 2.550 2 0.388 0.531 0.814 2.555 3 0.379 0.570 0.814 2.564 4 0.388 0.545 0.821 2.560 5 0.399 0.545 0.810 2.120 6 0.398 0.550 0.805 2.569 7 0.412 0.541 0.806 2.559 8 0.412 0.541 0.808 2.177 9 0.412 0.514 0.816 1.840 10 0.415 0.525 0.826 2.580 11 0.405 0.505 0.823 1.932 12 0.389 0.486 0.819 1.962 Comments: Position I at elbow extradose. Note: UT readings obtained on painted surface which could result in difficulty in obtaininq UT data at some locations.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 26 of 46 Attachment 4 - Page 10 of 20 Millstone Unit 2 Page 3 of 3 Service Water System Component ID: SK-29633 on spool SK-2963)

WO #: 53102516395 "009/28/2012 Position UT Poi t 1 UT2if* 2 UT Point 3 UT Point 4 1 0.399 -- 0.541 0.815 2.550.

2 0.388 0.531 0.814 2.555 3 0.379 0.570 0.814 2.569 4 0.388 0.545 0.821 2.565 5 0.399 0.545 0.810 2.115 6 0.398 0.550 0.805 2.569 7 0.412 0.541 0.806 2.559 8 0.412 0.541 0.808 2.177 9 0.412 0.514 0.816 1.835 10 0.415 0.525 0.826 2.580 11 0.405 0.505 0.823 1.932 12 0.389 0.486 0.819 1.962 Comments: Position I at elbow extradose. Note: UT readings obtained on painted surface which could result in difficulty in obtaining UT data at some locations.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 27 of 46 Attachment 4 - Page 11 of 20 Attachment I Exam Data Sheet Millstone Power Station ULTRASONIC EXAMINALION STRAIGHT BEAM MEASUREMENTS Plant Millstone _______Unit 2 Page 1 of 3 System & Zone No. "B" Train Setvice Water Exam Data Sheet No. N/A Component ID- SK-2963 AWO Number 53102516395 Component Description OutletFlange - Drawing No. 25203-20194 Sh. 2963 Examination Purpose _Dailv Monitorintt Line No. l0"-JGD-4 ------- _-

Instrument & Settings Calibration Block(s) Component Data Manufacturer KB Type Serial No. Material Cmponent Tnom N/A ]

Model No. USN 521. Step Blk. 95-5768 CS Component Dia. 10" i Serial No. OOCLXR N/A N/A N/A Attachments. N/A J Range 1.0"1 Velocity 2347 Calibration Checks Block Thickness InstrumentReading Delay -. 203 Type Time Min. Max. Min. Max..

Zero Value 4.443 Initial 0735 .250" 1.000" .250" 1.000" Cal Tolerance +/- .002 Intermediate N/A N/A N/A N/A N/A Intennediate N/A N/A N/A N/A N/A Search Unit Data Final 0800 .250" 1.000" .250" 1.000" Manufacturer KBA Type No. Gamma Couplant Data Temperature Data Serial No. 01WNDF Brand N/A Cal. B1k. Temp. N/A Frequency 5 MI-tZ Batch No. 11225 G Component Temp/ N/A Size .25" SAP Batch Mgmt. No. N/A Thermometer S/N N/A Sketch/Comments Area - Attach Photo(s) of Relevant Conditions Separately Calibration sheet for SK-2963 outlet flange.

Calibration for UT points 1, 2 & 3.

See attached for UT examination results.

Examiner (print & sign) Michael Brehlr/ -_Level II Date 09/29/12 Reviewer (sign) L) Level - Date 9/3o/l2 ANIJANII If Required (Sign) N/A Date N/A Level of Use T .

Mas 4ZQ;F at pw-V A ER-AA-NDE-UT-701-NPQR A.,

Rev. 6 Reference J4 4~ ~ 11

Attachment #.4. DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 28 of 46 Attachment 4 - Page 10 of 20 Attachment I Exam Data Sheet Millstone Power Station ULTRASONIC EXAMINATION STRAIGHT BEAM MEASUREMENTS Plant Millstone Unit 2 Page 2 _.__ of 3 System & Zone No. "B" Train Service Water Exam Data Sheet No. N/A Component ID SK-2963 AWO Number ... 53 102516395 Component Description Outlet Flangqe. .. DrawingNo. 25203-20194 Sh. 2963 Examination Purpose Da4ilyMonitoring Line No. l0"-JGD-4 Instrument & Settings Calibration Block(s) Component Data Manufacturer KB Type Serial No. Material Component T... N/A Model No. USN 52L Step Blk. 99-6791 CS ComponentDia. '10',.

Serial No. 0OCLXR N/A N/A N/A Attachments. N/A Range 5.0" Velocity 2329 Calibration Checks Block Thickness Instrument Reading Delay -. 375 Type Time Min. Max. Min. Max.

Zero Value 9.873 Initial 0805 1.000" 4.000" 1.000" 4.000" Cal Tolerance +/- .002 Intermediate N/A N/A N/A N/A N/A Intermediate N/A N/A N/A N/A N/A Search Unit Data Final 0820 1.000" 4.000" 1.000" 4.000" Manufacturer KBA Type No. MSEB5 Conplant Data Temperature Data Serial No. 57464-1411 Brand N/A Cal. Blk. Temp. N/A Frequency 5 MHZ Batch No. 11225 G Component Temp N/A Size .315" SAP Batch Mgmt. No. N/A Thermometer S/N N/A Sketch/Comments Area - Attach Photo(s) of Relevant Conditions Separately Calibration sheet for SK-2963 outlet flange.

Calibration for UT point 4 See attached for UT examination results.

Examiner (print & sign) Michael Brehler/ _ - Level I1 Date 09/29/12 Reviewer (sign) . "-" _ __ __ __Levcl _ Date D1_ _____

ANI/ANII If Required (Sign) N/A Date N/A Level of Use a a ER-AA-NDE-UT-701 -NPQR Rev. 6 Reference

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 29 of 46 Attachment 4 - Page 13 of 20 Millstone Unit 2 Page 3 of 3 Service Water System Component ID:SK-2963 Outlet flange WO #: 53102516395 09/29/12 Position UT Point 1 UT Point 2 UT Point 3 UT Point 4 1 .393" .526" .818" 2.550" 2 .376" .533" .811" 2.565" 3 .370" .559" .811" 2.567" 4 .387" .544" .818" 2.565" 5 .399" .543" .805" 2.105" 6 .397" .549" .807" 2.570" 7 .411" .540" .805" 2.563" 8 .411" .540" .809" 2.175" 9 .412" .513" .817" 1.835" 10 .412" .524" .826" 2.580" 11 .402" .500" .822" 1.928" 12 .389" .488" .819" 1.962" Comments: UT data taken daily in support of 0D 000502.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 30 of 46 Attachment 4 - Page 14 of 20

-Order based on Attachment 1 Exam Data Sheet calibration time for readings from 9/29 Millstone Power Station ULTRASONIC EXAMINATION to 9/30 in the STRAIGHT BEA1' MEASTIRE W NENTS fol11wing `ages I Plant Millstone Unit 2 Page .of j_ /

System & Zone No. "B" Train Service Water Exam Data Sheet No. N/A Component 1D SK-2963_ AWO Number 531025163957/__

Component Description Outlet Flange Drawing No. 25203-20194 S . 2963 ------

Examination Purpose DailyMnitoring Line No. 10"-JGD-4 _

Instrument & Settings Calibration Block(s) / Component Data Manufacturer KB Type Serial No. V Material Component Tnom N/A USN 52L Step Blk. 99-6791 CS Component Dia. 10",

Model No.

Serial No. OOCLXR N/A N/A N/A Attachments. N/A Range 5.0" Velocity 2329 Calibration Checks Block Thickness Instrument Reading Delay -. 375 Type ie Min. Max. Min. Max.

Zero Value 9.873 Initial 0930 1.000" 4.000" 1.000" 4.000" Cal Tolerance +/- .002 Istermediate N/A N/A N/A N/A N/A Intermediate N/A N/A N/A N/A N/A Search Unit Data Final 1000 1.000" 4.000" 1.000" 4.000" Manufacturer KBA Type No. MSEB5 CouplantData Temperature*Data Serial No. 57464-1411 Brand N/A Cal. BIk. Temp. N/A Frequency 5 MHZ Batch No. 11225 G Component Temp N/A Size .315" SAP Batch Mgmt. No. N/A Thermometer S/N N/A Sketch/Comments Area -Attach Photo(s) of Relevant Conditions Separately Calibration sheet for SK-2963 outlet flange. UT point 4 only, at position #5, #9, #11 and #12. These locations had paint removed.

The following data recorded UT point 4:

Location 5 = 2.083" Location 9 =1.835" Location 11=1.915" Location 12=1.933" Examiner (print & sign) Michael Brehlor/ Level II Date 09/29/12 Reviewer (sign)RqrLevel SgDate N/Aate N/

IANI/ANII If Required (Sign) N/A Date N/A Level of Use IQ ER-AA-NDE-UT-701-NPQR Rev. 6 Reference

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 31 of 46 Attachment 4 - Page 15 of 20 Attachment I Exam Data Sheet Millstone Power Station ULTRASONIC EXAMINATION STRAIGHT BEAM MEASUREMENTS Plant Millstone Unit 2 Page 1 of _ 1 System & Zone No. "B" Train Service Water Exam Data Sheet No. N/A Component ID SK-2963 __ AWO Number 53102516395 Component Description Outlet Flange Drawing No. 25203-20194 Sh, 2963 Examination Purpose Daily Monitoring Line No. l0"-JGD-4 -------

Instrument & Settings Calibration Block(s) Component Data Manufacturer KB Type Serial No. Material Component T,,, N/A Model No. USN 52L Step Blk. 99-6791 CS Component Dia. 10"1 Serial No. OOCLXR N/A N/A N/A Attachments. N/A Range 5.0" Velocity 2329 Calibration Cheeks Block Thickness Instrument Reading Delay -. 375 Type Time Min. Max. Min. Max.

Zero Value 9.873 Initial 1845 1.000" 4.000" 1.000" 4.000" Cal Tolerance +/- .002 Intermediate N/A N/A N/A N/A N/A Intermediate N/A N/A N/A N/A N/A Search Unit Data Final 1915 1.000" 4.000" 1.000" 4.000" Manufacturer KBA Type No. MSEB5 Couplant Data Temperature Data Serial No. 57464-1411 Brand N/A Cal. Blk. Temp.I N/A Frequency 5 MHZ Batch No. 11225 G Component Temp N/A Size .315" SAP Batch Mgmt. No. N/A Thermometer S/N N/A Sketch/Comments Area -Attach Photo(s) of Relevant Conditions Separately, Calibration sheet for SK-2963 outlet flange. UT point 4 only, at position #5, #9, #11 and #12. These locations had paint removed.

The following data recorded UT point 4:

Location 5 = 2.084" Location 9 =1.826" Location 11=1.913" Location 12=1.934" Examiner (print & sign) Michael Brehler/ 2'C4/ * -Level II Date 09/29/12 Reviewer (sign) Level Date ANI/ANII If Required (Sign) N/A Date N/A Level of Use WI. _, A A 6 ET Reference ' "fi*PP'Rev. 6

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 32 of 46 Attachment 4 - Page 16 of 20 Exam Data Sheet Millstone Power Station ULTRASONIC EXAMINATION STRAIGHT BEAM MEASUREMENTS Plant Millstone Unit 2 Page .Lof J_

System & Zone No. "B" Train Service Water / 3326 Exam Data Sheet No N/A Component ID SK-2963 AWO Number 53102516395 Component Description Sp.q SK-2963 Outlet Flange Drawing No. 25203.20150 S- 471 Examination Purpose Engineering Information Line No. 10"-JGD-4 Instrument & Settings Calibration Block(s) Component Data Manufacturer Krautkramer Type Serial No. j Material Component T.,.. N/A Model No. USN 52L Step Wedge 95-5768 C/S Component Dia. 10" Serial No. 00CLY5 Step Wedge 99-6791 C/S Attachments. yes Range 5.0" Velocity .2331 Calibration Checks Block Thickness Instrument Reading.

Delay .250 Type Time Min. Max. Min. Max.

Zero Value 3.910 Initial 00:10 .250" 4.00" .250" 4.00" Cal Tolerance 1.002" Intermediate N/A N/A N/A N/A N/A Intermediate N/A N/A N/A N/A N/A Search Unit Data Final 00:30 .2 50" 4.00" .250" 4.00" Manufacturer KBA Type No. MSEB5 Couplant Data Temperature Data Serial No. 57464-1408 Brand Ultragel II Cal. Block 'emp. N/A Frequency 5.0 MHz Batch No. 11225 G Component Temp. N/A Size 8/2 mm SAP Batch Mgmt. No. N/A Thermometer No. N/A Examination perfoirned at UT Point 4 only at positions 5, 9, 11, & 12.

Data recorded as follows:

Location 5 - 2.084" Location 9 - 1.823" Location 11 - 1.914" Location 12 - 1.934" Examiner (print & sign) Todd "ohnenkamer Level II Date 09/30/2012 Reviewer (sign) -Level 2 t] Date .

ANIANII If Required (Sign) N/A Date N/A Level of Use W. ~ ~?~

E-R-AA-NDE-UT-70 1 Reference o-ý FK4

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 33 of 46 Attachment 4 - Page 17 of 20 I Attachment I Exam Data Sheet Millstone Power Station ULTRASONIC EXAMINATION STRAIGHT BEAM MEASUREMENTS Plant Millstone Unit 2 Page of System & Zone No. "B" Train Service Water Exam Data Sheet No. N/A Component ID SK-2963 AWO Number 53102516.32_5 Component Description Outlet Flange DrawingNo. 25203-20194 Sh. 2963 Examination Purpose Daily Monit'g. Line No. l0"-JGD-4 -_ __ ___

Instrument & Settings Calibration Block(s) Component Data Manufacturer KB Type Serial No. Material Component Tnom N/A Model No. USN 52L Step B11k. 99-6791 CS Component Dia. 10" Serial No. 00CLX]R N/A N/A N/A Attachments. N/A Range 5.0"1 Velocity 2329 Calibration Checks Block Thickness Instrument Reading Delay -.375 Type Trime Min. Max. Min. Max.

Zero Value 9.873 Initial 0730 1.000" 4.000" 1.000" 4.000" Cal Tolerance +/-.002 Intermediate N/A N/A N/A N/A N/A Intermediate N/A N/A N/A N/A N/A Search Unit Data Final 0745 1.000" 4.000" 1.000" 4.000" Manufacturer KBA Type No. MSEB5 CouplantData Temperature Data Serial No. 57464-1411 Brand N/A Cal. B1k. Temp. N/A Frequency 5 MHZ Batch No. 11225 G Component Temp N/A Size .315" SAP Batch Mgmt. No. N/A. Thermometer S/N N/A Sketch/Comments Area -Attach Photo(s) of Relevant Conditions Separately Calibration sheet for SK-2963 outlet flange. UT point 4 only, at position #5, #9, #11 and #12. These locations had paint removed.

The following data recorded UT point 4:

Location 5 = 2.084" Location 9 =1.823" Location 11=1.915" Location 12=1.933" Examiner (print & sign) Michael Brehler/ Lvl_ 11~*i~I Date 09/30/12 Reviewer (sign) -- Level Date ANI/ANII If Required (Sign) N/A Date N/A Level of Use k ER-AA-NDE-UT-701-NPQR ps~\ ~ow Rev. 6 Reference

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 34 of 46 Attachment 4 - Page 18 of 20 I Attachment 1 Exam Data Sheet Millstone Power Station ULTRASONIC EXAMINATION STRAIGHT BEAM MEASUREMENTS Plant Millstone Unit . ... Page 1 of 1 System & Zone No. "B" Train Service Water Exam Data Sheet No. N/A Component ID SK-2963 AWO Number 53102516395 Component Description Outlet Flange Drawing No. 25203-20194 Sh. 2963 Examination Purpose Daily Monitoring Line No. 10"-JGD-4 Instrument &_Settings Calibration Block(s) Component Data Manufacturer KB Type Serial No. Material Component T... N/A Model No. USN 52L Step Blk. 99-6791 CS Component Dia. 10" Serial No. OOCLXR N/A N/A N/A Attachments. N/A Range 5.0" Velocity 2329 Calibration Checks Block Thickness Instrument Reading Delay -. 375 Type Time Min. Max. Min. Max.

Zero Value 9.873 Initial 0955 1.000" 4.000" 1.000" 4.000" Cal Tolerance +/- .002 Intermediate N/A N/A N/A N/A N/A Intermediate N/A N/A N/A N/A N/A Search Unit Data Final 1010 1.0010" 4.000" 1.000" 4.000" Manufacturer KBA Type No. MSEB5 Couplant Data Temperature Data Serial No. 57464-1411 Brand N/A. Cal. Blk. Temp. N/A Frequency 5 MHZ Batch No. 11225 G Component Temp N/A Size .315" SAP Batch Mgmt. No. N/A Thermometer SIN N/A Sketch/Comments Area - Attach Photo(s) of Relevant Conditions Separately Calibration sheet for SK-2963 outlet flange. UT point 4 only, at position #5, #9, #11 and #12. These locations had paint removed.

The following data recorded UT point 4:

Location 5 = 2.082" Location 9 =1.823" Location 11=1.914" Location 12=1.932" Examiner (print & sign) Michael Brehler/ . _ Level 11 Date 09/30/12 Reviewer (sign) - Level Date ANIIANII If Required (Sign) N/A Date N/A Level of Use VSK ER-AA-NDE-UT-701-NPQR Rev. 6 Reference

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 35 of 46 Attachment 4 Page 19 of 20 UT Positions / Locations 0((-

0

3 I?-

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 36 of 46 Attachment 4 - Page 20 of 20 UT Point Number Location Figure UT Point 4 Flange Bolt Hole UT Point 3 --- I UT Point 2 UT Point 1 --

,-Area of Material Loss Pipe v

I I Um

\

Note: Arrows show UT scan direction.

16.00 (REF) 10.88 (RFF)

I 1.25 0.150 12.00 (REF)

Attachment #6 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 38 of 46 From: Deborah H MacDonald (Generation - 4)

To: Jane L Marean (Generation - 4); Raymond E Deconto (Generation - 6);

Zachary A Withrow (Generation - 6);

Subject:

FW: Millstone 2 SW Flange Degradation RR Date: Saturday, September 22, 2012 10:48:19 AM FYI Debbie MacDonald Manager Nuclear Design Engineering Millstone X2293 Pager 504-286-2813 From: William D Bartron (Generation - 4)

Sent: Friday, September 21, 2012 5:46 PM To: Kim, James Cc: Stephen E Scace (Generation - 6); Jeff D Semancik (Generation - 4); Matt Adams (Generation - 4); David Sommers (Generation - 6); Scott M Smith (Generation - 4); Bob Sturgill (Generation - 6); Kerry Basehore (Generation - 6);

Josephine Ambrosini (Josephine.Ambrosini@nrc.gov); J Eric Laine (Generation - 4);

Richard MacManus (Generation - 4); Chris Funderburk (Generation - 6); Deborah H MacDonald (Generation - 4); Norm P Sacco (Generation - 4); Wanda D Craft (Generation - 6); Michael F Marino (Generation - 6); George E. Marshall (Generation - 4); Anthony C Conant (Generation - 4); Sonny Stanley (Generation -

4); Bill Standley (Generation - 4); Frederick Kral (Generation - 4); Gary J Closius (Generation - 4); Jeffrey P Blonar (Generation - 4); Larry E Salyards (Generation -

4); MaryLou L Calderone (Generation - 4); Mohamed A Elmaghrabi (Generation -

4); Thomas G Cleary (Generation - 4); William E Brown (Generation - 4)

Subject:

FW: Millstone 2 SW Flange Degradation RR Jim, Thank you for getting back to me so quickly.

We will be proceeding with the development of an operability determination which will rely, in part, on a structural integrity assessment similar to what was used for the previous relief request we discussed earlier today.

We will follow-up in a timely manner with a relief request for the current condition.

Bill From: Kim, James [1]

Sent: Friday, September 21, 2012 4:08 PM To: William D Bartron (Generation - 4)

Subject:

RE: Millstone 2 SW Flange Degradation RR

Attachment #6 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 39 of 46 Bill, I was able to get a hold of Tim Lupold (Branch Chief at Piping and NDE Branch) and discussed the Millstone 2 condition. He said that if an operability determination utilized a non-code compliant analyses to show that the plant is safe for continued operation, then you can follow up with a relief request in a timely manner (he defines "timely manner" as 2-3 weeks) for the non-code compliant method.

Thanks, Jim From: Kim, James Sent: Friday, September 21, 2012 1:37 PM To: 'William D Bartron'

Subject:

Millstone 2 SW Flange Degradation RR Bill, Please copy the following people on the email distribution.

TimothyLupoldcnrc.gov John.Tsao@nrc.gov Georqe.Wilson~cnrc.gov Thanks, Jim

Attachment #7 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 40 of 46 Calculation of the ligament between the defect and the outer wall of the flange hub.

2.56" (calculated) 1 0.737 Cale. Ii 1.823" (measu lnterdose of Pioe

I...

S/ 0.737" is the radius of the defect based on UT Data Point 4 measurement. Therefore using the Pythagoras theorem:

[4 56"Calc from Cati)]Ligament*/ (0.562 + 0.68752) - 0.737" = 0.150"

Attachment #8 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 41 of 46 From: Robert Y Schonenberg (Generation - 4)

To: Zachary A Withrow (Generation - 6);

cc: Jane L Marean (Generation - 4); Harvey E Beeman (Generation - 4);

Deborah H MacDonald (Generation - 4); Scott M Smith (Generation - 4);

Subject:

Document1 [Compatibility Mode]

Date: Friday, September 28, 2012 9:15:40 AM Attachments: Docl.docx Attached is my input into your ETE. I have attempted to clarify what has been observed for corrosion rates with service water piping over that past several years. I don't have a reference for why distance from the bi-metal couple makes a difference but the observed behavior speaks for itself.

Achieving proper electrical isolation should change the rate dramatically. If the testing shows that there is a back current then it will be necessary to isolate the downstream flange on the AI-6XN elbow (SK2964?). Or accept the fact that the rate will not fall that much.

Attachment #8 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 42 of 46 Millstone has had two events where the observed galvanic corrosion rate is relevant to the current condition of service water spool SK2963.

The first of these is the damage and hole that was found on service water spool SK2952 in September 2011. The damage to the outlet flange of SK2952 like that hypothesized on SK2963 was through the slip on flange. The observed rate was about .800"/yr. The following sketch illustrates the geometry. It appears the corrosion starts from a point on the flange and progresses radially with the double ended arrow representing the shortest distance that lead to the leak. This .800"/yr. rate assumes the corrosion started when the flange pair was reassembled during 2R19.

The second event occurred in December 2011, where a hole was found in a coated carbon steel pipe about 2 feet from an improperly isolated carbon steel to AL-6XN flange. This pipe was connected directly to the discharge canal and therefore under a slight vacuum and didn't leak. Data from the damaged area taken over a month gave a corrosion rate of .5 -.6"/yr. This slightly slower corrosion rate demonstrates that the rate is a function of distance from the galvanic couple interface.

Coating damage and subsequent corrosion damage at the flanges of coated carbon steel pipe (i.e., no galvanic couple) has been observed by the Sea Water Team during virtually every recent outage. The corrosion damage has varied in depth from barely noticeable to 1/2" in depth on several larger flanges. The 11/2" of corrosion translates to a corrosion rate of .200"/yr.

The literature corrosion rate of carbon steel in sea water is only about .010"/yr. Higher corrosion rates at holidays or breaks in coatings is a common phenomena not completely understood.

If it is possible electrically isolate the AL-6XN flange from the carbon steel flange, the corrosion rate of the damaged areas on spool SK2963 should change. With the large electrical potential from the AL-6XN eliminated, the corrosion rate should fall to .200"/yr. (.017"/month) range that has been observed for carbon steel with a damaged coating.

Attachment #9 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 43 of 46 From: Richard C Bonner (Generation - 4)

To: Michael F Marino (Generation - 6); Raymond E Deconto (Generation - 6);

Zachary A Withrow (Generation - 6);

Subject:

FW: Testing Millstone 2 Flanges Date: Sunday, September 30, 2012 3:31:39 PM

Original Message -----

From: Scott Paul [2]

Sent: Sunday, September 30, 2012 2:44 PM To: Richard C Bonner (Generation - 4); 'spaul@corrtech-inc.com' Cc: John E Plourde (Generation - 4); Donald S Cleary (Generation - 4); Douglas R Tilton (Generation - 4); Russell A Sturgis (Generation - 4); Scott M Smith (Generation - 4); Thomas E Davis (Generation - 4); Eric P Smith (Generation -

4); Michael P Fiala (Generation - 4); Joseph A Rigatti (Generation - 4)

Subject:

Re: Testing Millstone 2 Flanges Test results obtained today indicate that both insulating flange assemblies are providing adequate electrical separation of the SK-2963 AL6XN elbow. All bolts of both flanges measured greater thank 1,000,000 ohms to the adjacent pipe flange. voltage across the flanges is 0.532 volts dc and 0.58 M ohms. The 40 millamps measure between the carbon steel and AL6XN elbow represenfts approximately .8 pounds of metal loss per year.

Richard C Bonner <richard.c.bonner@dom.com> wrote:

> Scott,

> As we discussed, can you provide a summary email of your examination /

testing of degraded flange SK-2963 today and resulting affect on corrosion rates.

It would be beneficial to us if you could provide any bases specifics for conclusion which could include personal experience.

> Thank you

> Rick Bonner

> Supervisor Nuclear Engineering

> Electrical/I+C Systems

> Millstone Station

> CONFIDENTIALITY NOTICE: This electronic message contains information

> which may be legally confidential and/or privileged and does not in

> any case represent a firm ENERGY COMMODITY bid or offer relating

> thereto which binds the sender without an additional express written

Attachment #9 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 44 of 46

> confirmation to that effect. The information is intended solely for

> the individual or entity named above and access by anyone else is

> unauthorized. If you are not the intended recipient, any disclosure,

> copying, distribution, or use of the contents of this information is

> prohibited and may be unlawful. If you have received this electronic

> transmission in error, please reply immediately to the sender that you

> have received the message in error, and delete it. Thank you.

Attachment #10 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 45 of 46 Millstone Power Facility Dielectric Insulator Evaluation and Documentation Work Order Number: W 6) -C 3 / -* 0 1-~2 Component Number: (3-)aj Date: _ __ page / of . Personnel: c"a_-- /--/

To/

Description of Work: ELJL-- va-L-'s / 6' M 6t "

4 *'*.'-

Test Data _ j' ( -,

Instrument P ., ;o1 .- > f ,

601 Insulation Tester Good indication, needle stays to Defective indication, needle moves Instrument # /?F

._. right of scale to the left "zero" Resistance Scale, Multimeter (Ohms) Oý0Oh Instrument # ______

DC Voltage Scale, Multimeter (VDC) 03qi ) ", Volts Instrument # _____

Evaluation Criteria Condition 1 Condition 2 Condition 3 601 Insulation Good indication, needle stays Good indication, needle stays to right Defective indication, needle moves Tester to right of scale of scale to the left Multimeter Ohms Measured value greater than Measured value less than 1.0 -Ohm Measured value less than 1.0 -Ohm 200-Ohm Mfultimeter DC Measured value greater than Measured value less than 0.05-volt Measured value less than 0.05-volt Volts 0.20-volt Acknowledgement YES NO Condition I Z' 1:

Condition 2 E_

Condition 3 L[I Insulating Flange GOOD, No backside Grounding Insulating Flange GOOD, With backside grounding Insulating Flange DEFECTIVE Sketch V) 1>- -

-*1

Attachment #10 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 46 of 46 Millstone Power Facility Dielectric Insulator Evaluation and Documentation Work Order Number: 4 -11_7 -) / )*- ,5 6 Z&6 Component Number: p-- [ r"4 e(DI Date: W3/i-- Page Of o- 2- Personnel: <, -- eT Description of Work: '. 6 * : J*-,p , ,

Test Data 4 Instrument Initials 601 Insulation Tester 4 Good indication, needle stays to ,/ 4 Defective indication, needle moves Instrument # 0v ' right of scale X k'Ito the left "zero" 1k, Resistance Scale, Multimeter (Ohms) o_______S___?________ Ohms Instrument # m_!(* fT DC Voltage Scale, j3qf7d Multimeter (VDC) ,_ -- _ _--_' ___ Volts Instrument# Al *4V.*ý'L I_

Evaluation Criteria Condition I Condition 2 Condition 3 601 Insulation Good indication, needle stays Good indication, needle stays to right Defective indication, needle moves Tester to right of scale of scale to the left Multimeter Ohms Measured value greater than Measured value less than 1.0 -Ohm Measured value less than 1.0 -Ohm 200-Ohm Multimeter DC Measured value greater than Measured value less than 0.05-volt Measured value less than 0.05-volt Volts 0.20-volt Acknowledgement YES NO Condition 1 ' -. t.-,-2 /1//". tI/

Dv, Condition 2 Condition 3 D _ -__

Insulating Flange GOOD, No backside Grounding Insulating Flange GOOD, With backside grounding Insulating Flange DEFECTIVE Sketch

~.. . .i.: .. ,

I i '" , :

. . . .-...- -! . . /.. . . . . ' ". . . . . . : .. . . .- . ; 7 . .. ". . ... .. . .. . .. .. . . .. . ... . . .i. . .. . . .'

v t e Letter Sequence Request
TAC:ME9820, (Open)
Initiation Request Acceptance... Administration Questions Answers Results Approval... Other: ML13122A450
MONTHYEAR2012-10-18 [Table View]

ML12297A333

Text

Reference:

Description:

2.0 Applicable Code Edition and Addenda

3.0 Applicable Code Requirement

Title:

Title:

Title:

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