RS-13-248, Relief Request 14R-17, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fourth Inservice Inspection Interval
| ML13364A361 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/30/2013 |
| From: | Simpson P Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-13-248 | |
| Download: ML13364A361 (19) | |
Text
RS-13-248 December 30, 2013 10 CFR 50.55a U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249
Subject:
Relief Request 14R-17, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fourth Inservice Inspection Interval In accordance with 10 CFR 50. 55a, "Codes and standards," paragraph (g)(5)(iii), Exelon Generation Company, LLC (EGC), requests NRC approval of the attached relief request associated with the fourth inservice inspection (ISI) interval for Dresden Nuclear Power Station, Units 2 and 3 (DNPS). Relief is requested due to the impracticality of satisfying the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components,"
due to plant design. The fourth ISI interval for DNPS ended January 19, 2013.
The relief request is based on the limitations that precluded completion of full Code examination requirements of ASME Class 1 and 2 welds during the fourth interval. Code examination of the welds was limited due to the materials of construction and design configurations.
The DNPS fourth ten-year ISI program plan met the requirements of ASME Code,Section XI, 1995 Edition with 1996 Addenda.
EGC requests approval of these requests by December 30, 2014.
There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819.
Exelon Generation Company, LLC
Attachment:
Dresden Nuclear Power Station 10 CFR 50. 55a Request No. 14R-17
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number I4R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--inservice Inspection Impracticality-
- 1. ASME Code Component(s) Affected Code Class:
1 and 2
References:
IWB-2500, IWC-2500, Table IWB-2500-1, Table IWC-2500-1, ASME Code Case N-460, ASME Code Case N-578-1, Table 1 Examination Category:
B-A, B-D, B-K, B-M-1, C-B, C-C, R-A Item Number:
B1.12, B1.40, B3.90, B3.100, B10.10, B10.20, B12.40, C2.21, C3.20, R1.11, R1.20
==
Description:==
Limited examination coverage Component Number:
See Tables 1 and 2 below for specific component identification
2. Applicable Code Edition and Addenda
The Inservice Inspection (ISI) Program for the Dresden Nuclear Power Station (DNPS),
Units 2 and 3 fourth ISI interval was based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 1995 Edition with the 1996 Addenda.
- 3. Applicable Code Requirement(s)
Table IWB-2500-1, Table IWC-2500-1, and Table 1 of Code Case N-578-1 Examination Categories/Item Numbers B-A, B1.12, B1.40, B-D, B3.90, B3.100; B-K, B10.10, B10.20; B-M-1, B12.40; C-B, C-C, C2.21, C3.20; and R-A, R1.11, R1.20 require a volumetric and/or surface examination, which includes essentially 100% of the weld. Dresden Nuclear Power Station (DNPS), Units 2 and 3 adopted ASME Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1," which defines "essentially 100%" as greater than 90% coverage of the examination volume or surface area, as applicable.
4. Impracticality of Compliance
Relief is requested in accordance with 10 CFR 50.55a(g)(5)(iii), on the basis that conformance with these Code requirements is impractical. Conformance would require extensive structural modifications to the component structure.
DNPS, Units 2 and 3, obtained Construction Permits CPPR-18 and CPPR-22 on January 10, 1966, and October 14, 1966, respectively. The piping systems and associated components were designed and fabricated before the examination requirements of ASME Section XI were formalized and published. Since DNPS, Units 2 and 3 were not specifically Page 1 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--lnservice Inspection Impracticality-designed to meet the requirements of ASME Section XI, full compliance is not feasible or practical within the limits of the current plant design.
Physical obstructions imposed by design, geometry, and materials of construction are typical of vessel appurtenances and sacrificial shield, insulation support rings, structural and component support members, adjacent component weldments in close proximity, unique component configurations and dissimilar metal weldments.
Tables 1 and 2 below indicate the refueling outage in which these welds were examined, and the coverage percentages obtained for those welds that have been examined. These tables are cumulative lists of all welds with limited examination coverage during the Fourth Interval.
Based on the above explanation, DNPS requests relief from the requirement to achieve greater than 90% volume and/or area coverage for the components listed in Tables 1 and 2 below, where greater than 90% coverage is impractical.
5. Burden Caused by Compliance
Compliance with the examination requirements of ASME Section XI would require modification of plant components to remove obstructions, redesigning of plant systems, and replacement of components where geometry is inherent to component design.
6. Proposed Alternative and Basis for Use
Proposed Alternative In accordance with 10 CFR 50.55a(g)(5)(iii), EGC requests relief from ASME Section XI Code requirements on the basis that the required "essentially 100%" coverage examination is impractical due to physical obstructions and limitations imposed by design, geometry, and materials of construction for the components discussed in Tables 1 and 2 below.
EGC will continue to perform best effort examinations in order to achieve the maximum amount of coverage. Additionally, a VT-2 examination performed on the subject components during system pressure test per examination category B-P each refueling outage and category C-H each inspection period is performed.
Basis for Use Examination techniques have been progressively upgraded during this interval to augment the required Section XI examinations. EGC has used the Electric Power Research Institute (EPRI), the Performance Demonstration Initiative (PDI), Inservice Inspection vendors and other industry sources to encourage the development and provide an awareness of improved examination techniques. The goal of these initiatives is to enhance coverage and flaw detection commensurate with radiation dose reduction.
Page 2 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-EGC examination procedures are revised on a continuing basis to incorporate proven techniques for a higher level of safety and quality as they become available. The examinations and techniques used today exceed the examinations conducted in the past on each component.
All components received as a minimum, the required examination(s) applicable to the extent practical due to the limited or lack of access available. The examinations conducted, confirmed satisfactory results evidencing no unacceptable flaws present, even though "essentially 100%" coverage was not attained. EGC has concluded that if any active degradation mechanisms were to exist in the subject welds, those degradations would have been identified in the examinations performed.
Based on the above, with the vintage of the DNPS, Units 2 and 3 designs, the underlying objectives of the code required volumetric and surface examinations have been met. The examinations were completed to the extent practical and evidenced no unacceptable flaws present. Additionally, a VT-2 examination performed on the subject components during system pressure test per examination category B-P each refueling outage and category C-H each period provides additional assurance that the structural integrity of the subject components is maintained.
7. Duration of Proposed Alternative
Relief is requested for the fourth ten-year inspection interval of the Inservice Inspection Program for DNPS, Units 2 and 3.
===8.
Precedents===
Relief was granted for the DNPS, Units 2 and 3 third ISI intervals in NRC safety evaluations dated January 8, 2003, and October 1, 2004.
Page 3 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Table 1: Dresden Nuclear Power Station, Unit 2 Fourth Inservice Inspection Interval Limited Coverage Co ponents Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed 2/1/RPV LONGITUDINAL IWB-2500-2 examination was limited SHELL/2-SC1A-WELD Volumetric B1.12 D2R22 88.0%
UT to 88.0% coverage due to VERT proximity of the jet pump diffuser.
The completed 2/1/RPV LONGITUDINAL IWB-2500-2 examination was limited SHELL/2-SC1B-WELD Volumetric B1.12 D2R22 40.2%
UT to 40.2% coverage due to VERT proximity of the shroud repair lower contact.
The completed 2/1/RPV LONGITUDINAL IWB-2500-2 examination was limited SHELL/2-SC1C-WELD Volumetric B1.12 D2R22 40.2%
UT to 40.2% coverage due to VERT proximity of shroud repair lower contact.
The completed 2/1/RPV examination was limited SHELL/2-SC1D-LONGITUDINAL IWB-2500-2 B1 12 D2R22 71 4%
UT to 71.4% coverage due to VERT WELD Volumetric proximity of jet pump restrainers and jet pump diffuser.
The completed examination was limited 2/1/RPV LONGITUDINAL IWB-2500-2 to 69.0% coverage due to SHELL/2-SC2A-WELD Volumetric B1.12 D2R22 69.0%
UT proximity of the jet pump VERT riser brace, lower specimen and upper specimen brackets.
Page 4 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed examination was limited 2/1/RPV LONGITUDINAL IWB-2500-2 to 78.2% coverage due to SHELU2-SC2B-WELD Volumetric B1.12 D2R22 78.2%
UT proximity of the jet pump VERT riser brace, lower specimen and upper specimen brackets.
The completed examination was limited 2/1/RPV LONGITUDINAL IWB-2500-2 to 87.0% coverage due to SHELU2-SC2C-WELD Volumetric B1.12 D2R22 87.0%
UT proximity of the jet pump VERT riser brace, lower specimen and upper specimen brackets.
The completed 2/1/RPV examination was limited SHELU2-SC3A-LONGITUDINAL IWB-2500-2 B1 12 D2R22 1%
69 UT to 69.1% coverage due to VERT WELD Volumetric proximity of the feedwater sparger and core spray downcomer piping.
The completed examination was limited 2/1/RPV LONGITUDINAL IWB-2500-2 to 72.9% coverage due to SHELU2-SC3B-WELD Volumetric 61.12 D2R22 72.9%
UT proximity of the lower VERT guide rod, feedwater sparger and core spray piping Page 5 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed examination was limited 2/1/RPV to 68.7% coverage due to SHELU2-SC3C-LONGITUDINAL IWB-2500-2 131.12 D2R22 a
68.7%
UT proximity of the shroud VERT WELD Volumetric repair tie rod, feedwater sparger and core spray piping.
The completed examination was limited 2/1/RPV SHELU2-SC3D-LONGITUDINAL IWB-2500-2 12 131 D2R22 o
73.7%
UT to 73.7% coverage due to WELD Volumetric proximity of the core VERT spray piping and feedwater s ar ers.
The completed examination was limited 2/1/RPV to 74.2% coverage due to SHELU2-SC3E-LONGITUDINAL IWB-2500-2 B1.12 D2R22 o
74.2%
UT proximity of the upper VERT WELD Volumetric guide rod, core spray piping and feedwater s ar ers.
The completed 2/1/RPV examination was limited SHELU2-SC4C-LONGITUDINAL IWB-2500-2 81.12 D2R22 85.7%
UT to 85.7% coverage due to VERT WELD Volumetric proximity of the steam dryer support.
The completed examination was limited 2/1/RPV NOZZLE-IWB-2500-7 B3 90 D2R20 7%
47 5
0 S 60° 600 L to 47.7% coverage due to SHELUN19A-2 VESSEL Volumetric nozzle configuration and insulation support interference.
Page 6 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed examination was limited 2/1/RPV NOZZLE-IWB-2500-7 90 B3 D2R18 38 0%
UT to 38.0% coverage due to SHELUN19B-2 VESSEL Volumetric nozzle configuration and an insulation support bracket below the nozzle.
UT-60° S The completed 2/1/RPV VESSEL-IWB-2500-7 B3.90 D2R21 27.2%
60 ° 70-S examination was limited SHELUN1A-2 NOZZLE Volumetric
,L to 27.2% coverage due to nozzle configuration.
The completed 2/1/RPV VESSEL-IWB-2500-7 90 B3 D2R18 26 0%
UT examination was limited SHELUNI B-2 NOZZLE Volumetric to 26.0% coverage due to nozzle configuration.
The completed 2/1/RPV NOZZLE-Section XI B3.90 D2R20 39.2%
UT-60° L examination was limited SHELUN2A-2 VESSEL to 39.2% coverage due to nozzle configuration.
The completed 2/1/RPV NOZZLE-IWB-2500-7 90 B3 D2R20 39 2%
UT-60° L examination was limited SHELUN2B-2 VESSEL Volumetric to 39.2% coverage due to nozzle configuration.
The completed 211/RPV NOZZLE-IWB-2500-7 90 B3 D2R18 42 0%
UT examination was limited SHELUN2C-2 VESSEL Volumetric to 42.0% coverage due to nozzle configuration.
The completed 2/1/RPV NOZZLE-IWB-2500-7 90 B3 D2R18 42 0%
UT examination was limited SHELUN2F-2 VESSEL Volumetric to 42.0% coverage due to nozzle configuration.
Page 7 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed 2/1/RPV NOZZLE-IWB-2500-7 B3 90 D2R18 42 0%
UT examination was limited SHELUN2H-2 VESSEL Volumetric to 42.0% coverage due to nozzle configuration.
The completed 2/1/RPV VESSEL-IWB-2500-7 63 90 D2R22 33 5%
UT examination was limited SHELUN3D-2 NOZZLE Volumetric to 33.5% coverage due to nozzle configuration.
The completed UT-45° S, examination was limited 2/1/RPV NOZZLE-IWB-2500-7 63.90 D2R20 39.3%
60° L, 60° to 39.3% coverage due to SHELUN4A-2 VESSEL Volumetric S
nozzle configuration and insulation interference.
The completed UT-45° S, examination was limited 2/1/RPV NOZZLE-IWB-2500-7 B3.90 D2R20 39.3%
60° L, 60° to 39.3% coverage due to SHELUN4B-2 VESSEL Volumetric S
nozzle configuration and insulation interference.
The completed UT-45° S examination was limited 2/1/RPV NOZZLE-IWB-2500-7 B3.90 D2R20 39.3%
60° L, 60° to 39.3% coverage due to SHELUN4C-2 VESSEL Volumetric S
nozzle configuration and insulation interference.
The completed 2/1/RPV NOZZLE-IWB-2500-7 UT-45° S, examination was limited B3.90 D2R20 39.3%
60° L, 60° to 39.3% coverage due to SHELUN4D-2 VESSEL Volumetric S
nozzle configuration and insulation interference.
Page 8 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed examination was limited 2/1/RPV VESSEL-IWB-2500-7 B3 90 D2R22 28 5%
UT to 28.5% coverage due to SHELUN5A-2 NOZZLE Volumetric nozzle configuration and proximity of the insulation support bracket.
The completed examination was limited 2/1/RPV VESSEL-IWB-2500-7 B3 90 D2R18 31 0%
UT to 31.0% coverage due to SHELUN5B-2 NOZZLE Volumetric the nozzle configuration and a stabilizer lug below the nozzle.
The completed 211/RPV NOZZLE-IWB-2500-7 B3 90 D2R18 75 0%
UT examination was limited SHELUN9-2 VESSEL Volumetric to 75.0% coverage due to nozzle configuration.
VESSEL-The completed 2/1/RPV UPP UPPER TOP IWB-2500-5 examination coverage HD/2-THD-FLG HEAD FLANGE Volumetric B1.40 D2R20 41.7%
UT was limited to 41.7% due WELD to being single sided due to flange configuration.
The completed 2/2/1302A-ISO IWC-2500-4 examination coverage 12/12-9 CONDENSER Volumetric C2.21 D2R22 50.0%
UT was limited to 50.0% due NOZZLE WELD to component confi uration.
The completed 2/2/1302B-ISO IWC-2500-4 examination coverage 12/12-8 CONDENSER Volumetric C2.21 D2R22 50.0%
UT was limited to 50.0% due NOZZLE WELD to component configuration.
Page 9 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed ISO examination coverage 2/2/1303A-8/8-9 CONDENSER IWC-2500-4 C2.21 D2R22 50.0%
UT was limited to 50.0% due NOZZLE WELD Volumetric to component configuration.
The completed ISO examination coverage 21211303B-8/8-8 CONDENSER IWC-2500-4 C2.21 D2R22 50.0%
UT was limited to 50.0% due NOZZLE WELD Volumetric to component configuration.
The completed 2/1/RPV UPP NOZZLE-IWB-2500-7 B3 90 D2R22 74 2%
UT examination was limited HD/N18A-2 VESSEL Volumetric to 74.2% coverage due to nozzle configuration.
The completed examination was limited 2/1/RPV NOZZLE INSIDE IWB-2500-7 83.100 D2R18 86.0%
UT to 86.0% coverage due to SHELUN56-1 RADIUS Volumetric a stabilizer lug below the nozzle.
The completed 2/1/RPV INTEGRAL IWB-2500-13 tion was limited examin SHELL/M-WELDED IWB-2500-14 B10.10 D2R20 o
56.0%
MT a
to 56.0% coverage due to 1175D-1(IWA)
ATTACHMENT IWB-2500-15 inaccessibility to the Surface bottom of the lug.
The completed examination was limited INTEGRAL IWB-2500-13 0
to 50.0% coverage due to 2/1/1506-16/M-WELDED IWB-2500-14 B10.20 D2R20 50.0%
PT the inner weld on the 1164D-296(IWA)
ATTACHMENT IWB-2500-15 attachment was not Surface accessible and could not be prepped.
Page 10 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed 2/1/3001 D-IWB-2500-17 examination was limited 6/ERV-2-203-VALVE WELD Volumetric B12.40 D2P22 87.3%
VOL to 87.3% coverage due to 3D(WELD) integrally welded cage on the valve ID.
The completed examination was limited INTEGRAL to 81.6% coverage due to 2/2/2304-14/M-WELDED IWC-2500-5 C3.20 D2P19 81.6%
MT only examining three 1151 D-10(IWA)
ATTACHMENT sides since presence of pipe clamp prevented examining fourth side.
IWB-2500-8(c)
The completed 2/1/1001A-IWB-2500-9 UT-E-45° examination was limited 16/16-11 TEE-PIPE IWB-2500-10 R1.11 D2R19
° 36.0%
60° L S
to 36.0% coverage due to IWB-2500-11 weld obstruction and Volumetric component configuration.
IWB-2500-8(c)
The completed 2/1/1001 B-FLANGE-PIPE IWB-2500-9 IWB-2500-10 R1 11 D2R20 85 0%
UT-E-45° examination was limited 16/16-2 IWB-2500-11 S
to 85.0% coverage due to component configuration.
Volumetric IWB-2500-8(c)
The completed 2/1/1005B-IWB-2500-9 UT-E-45° tion was limited examin 14/14-7 VALVE-PIPE IWB-2500-10 R1.11 D2R20 50.0%
S, 60 L a
to 50.0% coverage due to IWB-2500-11 component configuration.
Volumetric IWB-2500-8(c)
The completed 2/1/1403-101W-IWB-2500-9
° UT-E-45 was limited examination 103 IWB-2500-10 R1.20 D2R20 81.0%
L, 45° S, verage due to to 81.0% coverage IWB-2500-11
° L 60 component configuration.
Volumetric Page 11 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number I4R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type IWB-2500-8(c)
° The completed 2/1/1404-10/W-IWB-2500-9 UT-E-45 was examination limited 112 VALVE-PIPE IWB-2500-10 R1.20 D2R20 85.0%
° S, 45 L,
° to 85.0% coverage due to IWB-2500-11 60 L
component configuration.
Volumetric Table 2: Dresden Nuclear Power Station, Unit 3 Fourth Inservice Inspection Interval Limited Coverage Components Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed 3/1/RPV LONGITUDINAL IWB-2500-2 examination coverage SHELL/3-SC1A-81.12 D3R22 85.0%
UT-45 was limited to 85.0% due VERT WELD Volumetric to proximity of the jet pump diffuser.
The completed 3/1/RPV LONGITUDENAL IWB-2500-2 UT-45 examination coverage SHELU3-SC1B-81.12 D3R22 39.8%
S,UT-70 was limited to 39.8% due VERT WELD Volumetric RL to proximity of the shroud repair tie rod.
The completed 3/1/RPV LONGITUDENAL IWB-2500-2 UT-45 S examination coverage SHELU3-SC1C-WELD Volumetric 81.12 D3R22 83.4%
-70 RL UT was limited to 83.4% due VERT to proximity of the jet pump diffuser.
The completed 3/1/RPV LONGITUDENAL IWB-2500-2 UT-45 S examination coverage SHELU3-SC2A-WELD Volumetric 81.12 D3R22 75.8%
UT-70 RL was limited to 75.8% due VERT to the tie-rod stabilizer bracket.
Page 12 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed 3/1/RPV SHELL/3-SC2C-LONGITUDENAL IWB-2500-2 B1 12 D3R22 84.2%
UT-45 S examination coverage was limited to 84.2% due VERT WELD Volumetric
-70 RL UT to proximity of the core spray piping.
The completed examination coverage 3/1/RPV SHELL/3-SC3A-LONGITUDENAL IWB-2500-2 B1 12 D3R22 22.6%
UT-45 S was limited to 22.6% due WELD Volumetric UT-70 RL to proximity of the VERT feedwater sparger and core spray downcomer.
The completed examination was limited to 3/1/RPV NOZZLE-IWB-2500-2 B3 90 D3R20
° 53 0%
UT-60° L, 53.0% coverage due to SHELL/N19A-2 VESSEL Volumetric 60°S nozzle configuration and insulation support interference.
The completed examination coverage 3/1/RPV SHELL/3-SC36-LONGITUDENAL IWB-2500-2 12 B1 D3R22 66 0%
UT-45 S was limited to 66.0% due WELD Volumetric UT-70 RL to proximity of the shroud VERT repair tie rod and core spray iin bracket.
The completed examination coverage 3/1/RPV LONGITUDENAL IWB-2500-2 UT-45 S was limited to 55.7% due SHELL/3SC3C-WELD Volumetric B1.12 D3R22 55.7%
UT-70 RL to proximity of the core VERT spray piping, feedwater sparger and specimen bracket.
Page 13 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed 3/1/RPV LONGITUDENAL IWB-2500-2 UT-45 S examination coverage SHELU3-SC3D-WELD Volumetric 81.12 D3R22 71.8%
UT-70 RL was limited to 71.8% due VERT to core spray piping and feedwater s ar er.
The completed examination coverage 3/1/RPV was limited to 80.2% due SHELU3-SC46-LONGITUDENAL IWB-2500-2 61 12 D3R22 80 2%
UT-45 S to proximity of the dryer VERT WELD Volumetric UT-70 RL bracket and the mismatch between the RPV and flange for this examination.
The completed 3/1/RPV NOZZLE-IWB-2500-7 UT-45° S examination was limited to SHELUNI9B-2 VESSEL Volumetric B3.90 D3R18 38.0%
600 L 38.0% coverage due to nozzle configuration and an insulation support ring.
UT-60° S The completed 3/1/RPV VESSEL-IWB-2500-7 B3.90 D3R18 25.0%
60° 700S examination was limited to SHELUNIA-2 NOZZLE Volumetric 1
25.0% coverage due to L
nozzle configuration.
The completed 3/1/RPV VESSEL-IWB-2500-7 B3 90 D3R20 31 3%
UT-60° S examination was limited to SHELUN1 B-2 NOZZLE Volumetric 70°S 31.3% coverage due to nozzle configuration.
The completed 3/1/RPV NOZZLE-IWB-2500-7 B3 90 D3R20
° 41 7%
UT°
-60 S examination was limited to SHELUN2B-2 VESSEL Volumetric 41.7% coverage due to nozzle configuration.
Page 14 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed 3/1/RPV NOZZLE-IWB-2500-7 B3 90 D3R18 42 0%
UT-60° S, examination was limited to SHELL/N2D-2 VESSEL Volumetric 60° L 42.0% coverage due to nozzle configuration.
UT-60° S The completed 3/1/RPV NOZZLE-IWB-2500-7 B3.90 D3R18 42.0%
60 ° 700S examination was limited to SHELL/N2E-2 VESSEL Volumetric
,L 42.0% coverage due to nozzle configuration.
The completed 3/1/RPV NOZZLE-IWB-2500-7 B3 90 D3R20
° 41 7%
S UT-600 examination was limited to SHELL/N2G-2 VESSEL Volumetric 41.7% coverage due to nozzle configuration.
The completed 3/1/RPV VESSEL-IWB-2500-7 B3 90 D3R21 31 0%
UT-60° S, examination was limited to SHELL/N3A-2 NOZZLE Volumetric 60° L 31.0% coverage due to nozzle configuration.
The completed 3/1/RPV VESSEL-IWB-2500-7 B3 90 D3R21 31 0%
UT-60° S, examination was limited to SHELL/N3B-2 NOZZLE Volumetric 60° L 31.0% coverage due to nozzle configuration.
The completed 3/1/RPV VESSEL-IWB-2500-7 UT-60° L, examination was limited to SHELL/N3C-2 NOZZLE Volumetric B3.90 D3R18 35.0%
700S,600 35.0% coverage due to S
nozzle configuration and thermocouples.
UT-60° L The completed 3/1/RPV VESSEL-IWB-2500-7 B3.90 D3R19 40.8%
60,° 700S examination was limited to SHELL/N3D-2 NOZZLE Volumetric
,S 40.8% coverage due to nozzle configuration.
UT-45° S The completed 3/1/RPV VESSEL-IWB-2500-7 B3.90 D3R20 36.3%
60° L 60° examination was limited to SHELL/N4A-2 NOZZLE Volumetric 36.3% coverage due to I
S nozzle configuration.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type UT-45° S The completed 3/1/RPV VESSEL-IWB-2500-7 B3.90 D3R20 36.3%
60° L 60° examination was limited to SHELUN4B-2 NOZZLE Volumetric 36.3% coverage due to S
nozzle configuration.
S UT-450 The completed NOZZLE-IWB-2500-7 B3.90 D3R20 36.3%
70° 600S examination was limited to SHELUN4C-2 VESSEL Volumetric LT 36.3% coverage due to nozzle configuration.
UT-45° S The completed 3/1/RPV NOZZLE-IWB-2500-7 B3.90 D3R20 36.3%
60° 600S examination was limited to SHELUN4D-2 VESSEL Volumetric L
36.3% coverage due to nozzle configuration.
The completed 3/1/RPV VESSEL-IWB-2500-7 UT-60° L examination was limited to SHELUNSA-2 NOZZLE Volumetric B3.90 D3R21 29.0%
600S 29.0% coverage due to the nozzle configuration and stabilizer bracket.
The completed 3/1/RPV VESSEL-IWB-2500-7 B3 90 D3R18 36 0%
UT-60° S, examination was limited to SHELUN5B-2 NOZZLE Volumetric 60° L 36.0% coverage due to nozzle configuration.
The completed 3/1/RPV NOZZLE-IWB-2500-7 UT-45° S examination was limited to SHELUN9-2 VESSEL Volumetric B3.90 D3R18 62.0%
60° L 62.0% coverage due to nozzle configuration and insulation support ring.
VESSEL-UPPER The completed 3/1/RPV UPP TOP HEAD IWB-2500-5 61 40 D3R19 72 0%
UT examination was limited to HD/3-THD-FLG FLANGE WELD Volumetric 72.0% coverage due to flange configuration.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type
-45° S UT The completed 3/1/RPV UPP NOZZLE-IWB-2500-7 B3.90 D3R19 66.6%
60° 600S examination was limited to HD/N18A-2 VESSEL Volumetric L l coverage due to nozzle configuration.
UT-45° S The completed 3/1/RPV UPP VESSEL-IWB-2500-7 B3.90 D3R19 66.6%
60° 600S examination was limited to HD/N18B-2 NOZZLE Volumetric L
66.6% coverage due to nozzle configuration.
The completed 3/1/RPV UPP VESSEL-IWB-2500-7 B3 90 D3R19 74 3%
UT-60° S, examination was limited to HD/N8-2 NOZZLE Volumetric 60° L 74.3% coverage due to nozzle configuration.
ISO The completed 3/2/1302A-CONDENSER IWC-2500-4 C2 21 D3R20 37 8%
UT examination was limited to 12/12-8 NOZZLE WELD Volumetric 37.8% coverage due to nozzle configuration.
ISO The completed 3/2/1302B-CONDENSER IWC-2500-4 C2 21 D3R20 37 8%
UT examination was limited to 12/12-9 NOZZLE WELD Volumetric 37.8% coverage due to component configuration.
ISO The completed 3/2/1303A-8/8-8 CONDENSER IWC-2500-4 C2.21 D3R21 50 0%
UT examination was limited to NOZZLE WELD Volumetric 50.0% coverage due to component configuration, ISO The completed 3/2/1303B-8/8-9 CONDENSER IWC-2500-4 C2.21 D3R21 52 3%
UT examination was limited to NOZZLE WELD Volumetric 52.3% coverage due to component configuration.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Component ID Weld Exam Item Outage Actual Exam Remarks Description Requirements Number Examined Coverage Type The completed 3/1/RPV INTEGRAL IWB-2500-13 examination was limited to SHELUM-WELDED IWB-2500-14 B10.10 D3R19 60 0%
PT 60.0% coverage due to 1211 D-1 (IWA)
ATTACHMENT IWB-2500-15 being only able to Surface examine three sides of the lug.
The completed 3/1/0202A-28/M-INTEGRAL IWB-2500-13 examination was limited to 1193D-WELDED IWB-2500-14 B10 20 D3R18 88 0%
PT 88.0% coverage due to 1002(IWA)
ATTACHMENT IWB-2500-15 presence of sway brace Surface which reduced accessibility.
IWB-2500-8(c)
The completed IWB-2500-9 examination was limited to 3/2/320413-VALVE-TEE IWB-2500-10 R1 11 D3R21 78 9%
UT-E-45° 78.9% coverage due to 18/18-1 IWB-2500-11 S
presence of saddle Volumetric weldment, weld-o-let and valve configuration.
The completed 3/1/3001 B-IWB-2500-17 examination was limited to 6/ERV-3-203-VALVE WELD Volumetric 812.40 D3P22 89.4%
VOL 89.4% coverage due to 3B(WELD) integrally welded cage on valve ID.
IWB-2500-8(c)
IWB-2500-9 The completed 3/1/1302-14/14-FLANGE-PIPE IWB-2500-10 R1 20 D3R21 50 0%
UT-E-60° examination was limited to 9(A)
IWB-2500-11 L, 45° S 50.0% coverage due to Volumetric Hued head configuration.
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