ML14162A094

Request for Relief (RR-20) from ASME Code,Section XI for the Fourth 10-Year Inservice Inspection Program Interval

ML14162A094
Person / Time
Site:	Robinson
Issue date:	06/23/2014
From:	Lisa Regner Plant Licensing Branch II
To:	William Gideon Carolina Power & Light Co
Barillas M DORL/LPL2-2 301-415-2760
References
TAC MF1967
Download: ML14162A094 (23)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. William G. Gideon, Vice President H. B. Robinson Steam Electric Plant Duke Energy Progress, Inc.

3581 West Entrance Road Hartsville, SC 29550 June 23, 2014

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2-REQUEST FOR RELIEF (RR-20) FROM ASME CODE, SECTION XI FOR THE FOURTH 10-YEAR INSERVICE INSPECTION PROGRAM INTERVAL (TAC NO. MF1967)

Dear Mr. Gideon:

By letter dated June 3, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13178A006) as supplemented by letter dated January 21, 2014 (ADAMS Accession No. ML14028A260), Duke Energy Progress, Inc., (the licensee) submitted Relief Request (RR) 20, Sections 2 through 29, for H.B. Robinson Steam Electric Plant, Unit 2 to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. The Relief is associated with the requirements of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code,Section XI, Rules for lnservice Inspection of Nuclear Power Plant Components. The request for relief applies to the fourth 1 0-year inservice inspection (lSI) interval, in which the licensee adopted the 1995 Edition through the 1996 Addenda of ASME Code Section XI as the code of record.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR),

Section 50.55a(g)(5)(iii), relief is requested from the ASME Code volumetric examination requirement for the specified components on the basis that the code requirement is impractical.

The limitation for examination is due to physical design of the plant in which a volumetric limitation is encountered due to the physical configuration of the specified components contained in the application. In order to achieve more volumetric coverage the plant would need to be redesigned and modified in order to achieve a credited examination.

The NRC staff reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(g)(6)(i). Therefore, the NRC staff grants relief for the subject examinations of the components contained in RR 20, Sections 2 through 29 for the fourth 1 0-year lSI at H. B. Robinson Steam Electric Plant, Unit 2, which ended on July 20, 2012.

For ASME Code Section XI, Examination Category B-F, Items B5.40 and B5.70, Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles, the staff recommends to the licensee that although no current ASME Code,Section XI, Appendix VIII performance demonstrated techniques for examining piping welds from the cast stainless steel side have been qualified, ASME Code Case N-824, Ultrasonic Examination of Cast Austenitic Piping Welds from the Outside Surface, is now available to guide licensees who wish to augment ASME Code, Appendix Ill examinations to obtain enhanced volumetric coverage from the cast stainless steel

material. It is recommended that the licensee review and implement ASME Code Case N-824 during future examinations of welds in cast austenitic stainless steel. ASME Code Case N-824 is approved for general use in Regulatory Guide 1.147, Revision 16, lnservice Inspection Code Case Acceptability (ADAMS Accession No. ML101800536). This recommendation by the staff is not a condition for the approval of this relief request.

All other ASME Operation and Maintenance Code requirements for which alternatives or relief was not specifically requested and approved in the subject request remain applicable.

If you have any questions or concerns, please contact the Project Manager, Martha Barillas, at 301-415-2760.

Docket No. 50-261

Enclosure:

Safety Evaluation cc w/encl.: Distribution via Listserv Lisa M. Regner, Acting Branch Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST NO. 20. SECTIONS 2 THROUGH 29 FOR THE FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL DUKE ENERGY PROGRESS. INC.

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 DOCKET NO. 50-261

1.0 INTRODUCTION

By letter dated June 3, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13178A006), Duke Energy Progress, Inc. (the licensee), submitted Relief Request (RR) 20, Sections 2 through 29 from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Rules for lnservice Inspection of Nuclear Power Plant Components for H. B. Robinson Steam Electric Plant, Unit 2 (HBRSEP 2). The request for relief applies to the fourth 1 0-year inservice inspection (lSI) interval, in which the licensee adopted the 1995 Edition through the 1996 Addenda of ASME Code Section XI as the code of record. Additionally, in response to two U. S. Nuclear Regulatory Commission (NRC) requests for additional information, the licensee submitted additional information in its letter dated January 21, 2014 (ADAMS Accession No. ML14028A260).

2.0 REGULATORY REQUIREMENTS Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 1 0-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code, which was incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.

Section 50.55a(g)(5)(iii) of 10 CFR states, in part, that, that licensees may determine that conformance with certain ASME Code requirements is impractical and that the licensee shall notify the Commission and submit information in support of the determination. Determination of Enclosure impracticality in accordance with this section must be based on the demonstrated limitations experience when attempting to comply with the code requirements during the inservice inspection interval for which the request is being submitted. Requests for relief made in accordance with this section must be submitted to the NRC no later than 12 months after the expiration of the initial 120-month inspection interval or subsequent 120-month inspection interval for which relief is sought.

Section 50.55a(g)(6)(i) of 10 CFR states that the Commission will evaluate determinations under paragraph (g)(S) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

The licensee has requested relief from ASME Code requirements pursuant to 10 CFR 50.55a(g)(6)(i). The ASME Code of record for HBRSEP 2, fourth 10-year interval lSI program, which ended on July 20, 2012, is the 1995 Edition, through the 1996 Addenda, of Section XI of the ASME Boiler and Pressure Vessel Code.

Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request and the Commission to grant the relief and authorize the alternatives requested by the licensee.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed Duke Energy Progress, Inc.'s regulatory and technical analysis in support of the relief requests from the inservice inspection requirements of the ASME Code that are described in its application (ADAMS Accession No. ML13178A006).

3.1 Request for Relief RR-20, Part A. Examination ASME Code,Section XI, Category F-A.

Item F1.40, Supports ASME Code Requirement ASME Code,Section XI, Examination Category F-A, Item F1.40, requires 100 percent visual VT-3 examination, as defined by ASME Code, Section, XI, Figure IWF-1300-1 of selected Class 1, 2, 3, and MC supports other than piping supports.

Licensee's ASME Code Relief Request In accordance with 10 CFR 50.55a(g)(S)(iii), the licensee requested relief from the ASME Code-required 100 percent visual examination of reactor pressure vessel (RPV) supports listed in Table 3.1.1 below:

Table 3.1.1* ASME Code,Section XI, Examination Category F*A ASME Coverage Code Weld ro Weld Type Obtained Item Percent F1.40 101/A Reactor Vessel Cold Leg Loop "A" Support 20.0 F1.40 101/8 Reactor Vessel Cold Leg Loop "B" Support 33.3 F1.40 101/C Reactor Vessel Cold Leg Loop "C" Support 33.3 Reason for Relief Request In its submittal, the licensee stated the reactor vessel is supported by three supports located on the underside of each of the inlet nozzles (cold leg). Each support bears on a support shoe, which is fastened to the building support structure. Each support is designed to restrain vertical, lateral and rotational movement of the RPV, but allows for thermal growth by permitting radial sliding on bearing plates. Examination access to the reactor vessel supports is through the air ductwork for HVE-6 with a robot inside the reactor coolant pump bays. Access to examine the supports is from the ductwork facing the vessel supports, thereby creating a limited visual examination. This is the only access to the supports. These VT-3 examinations were performed to the latest technology available at the time of the examination and the examination achieved the maximum amount of coverage possible.

Proposed Alternative The licensee did not propose any alternative examinations for the subject welds.

However, the licensee's examinations were performed to the maximum extent practical.

NRC Staff Evaluation

The ASME Code requires 100 percent visual examination of ASME Code, Class 1 RPV nozzle supports. However, visual examinations of these supports at HBRSEP 2 are limited due to partial inaccessibility caused by their design and the surrounding appurtenances. In order for the licensee to obtain 100 percent of the ASME Code-required examination coverage, the RPV nozzles and surrounding environment need to be redesigned and modified. This would place a burden on the licensee, therefore the ASME Code examinations are considered impractical.

The nozzle supports consist of a shoe, or integral nozzle pad and steel plates that restrain vertical, lateral, and rotational movement, positioned between steel support structures and the RPV cold leg nozzles, which are surrounded by permanent insulation panels. Due to these insulation panels and the nozzle supports' design, the only access to visually examine them was through the heating, ventilation, and air conditioning (HVAC) ductwork that allows partial access for examinations to be completed by maneuvering a camera attached to a robotic device through the ductwork. Visual VT-3 examinations on RPV inlet nozzle supports 101/A, 101/8, and 101/C, have been performed to the extent practical, with the licensee obtaining approximately 20.0 to 33.3 percent of the ASME Code-required coverage as shown in Table 3.1.1 above. On RPV nozzle support 101/A, there was an area of concern that required debris removal; subsequent examination verified that there was no material degradation with only discoloration of the material being observed.

The licensee has shown that it is impractical to meet the ASME Code-required visual VT-3 examination coverage for the subject attachment supports due to their design and appurtenances adjacent to the RPV nozzles. Based on the remote visual coverage obtained via robotics maneuvered through the HVAC ductwork, the NRC staff finds it is reasonable to conclude that, if significant service-induced degradation had occurred in the accessible areas, evidence of it would have been detected by the examinations performed. Furthermore, the staff determined that the examinations performed provide reasonable assurance of structural integrity of the subject welds.

3.2 Request for Relief RR-20. Part B. ASME Code,Section XI, Examination Category B-F.

Items B5.40 and B5. 70. Pressure Retaining Dissimilar Metal Welds (DMW) in Vessel Nozzles ASME Code Requirement ASME Code,Section XI, Examination Category B-F, Items B5.40 and B5.70, require 100 percent volumetric examination, as defined by Figure IWB-2500-8, of Class 1 pressurizer (PZR) and steam generator (SG) nozzle-to-safe end butt welds, NPS

[nominal pipe size] 4 inch diameter, or larger. ASME Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds, as an alternative approved for use by the NRC in Regulatory Guide 1.147, Revision 16, lnservice Inspection Code Case Acceptability (RG 1.147, Revision 16), states that a reduction in examination coverage due to part geometry or interference for any Class 1 and 2 weld is acceptable provided that the reduction is less than 10 percent, i.e., greater than 90 percent examination coverage is obtained.

Licensee's ASME Code Relief Request In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the ASME Code-required volumetric examinations for the PZR and SG nozzle-to-safe end butt welds listed below in Table 3.2.1.

Table 3.2.1~ ASME Code, SectiortXI, Examination Category B-F

ASME,

' vveJd ID Coverage Code

• • Weld;Type Obtained

If'**'

.em;**

Percent 85.40 1168/19DM Piping-to-PZR Spray Nozzle 75.0 85.70 107/04DM Reactor Coolant Loop "A" Hot Leg DMW at SG Nozzle 52.8 85.70 107/05DM Reactor Coolant Loop "A" Cold Leg DMW at SG Nozzle 64.8 85.70 107A/04DM Reactor Coolant Loop "8" Hot Leg DMW at SG Nozzle 49.1 85.70 107A/05DM Reactor Coolant Loop "8" Cold Leg DMW at SG Nozzle 47.5 85.70 1078/04DM Reactor Coolant Loop "C" Hot Leg DMW at SG Nozzle 50.0 Table 3.2:1-ASME Code,Section XI,. Examination Category B-F ASME Coverage Code Weld 10

• weld Type*

Obtained Item Percent 85.70 1078/05DM Reactor Coolant Loop "C" Cold Leg DMW at SG Nozzle 50.0 Reason for Relief Request In its submittal, the licensee stated the following:

Piping-to-PZR Spray Nozzle-The 4" pressurizer spray nozzle (SA 351) is clad on the inside diameter of the carbon nozzle side with stainless steel. The nozzle is then connected to a safe-end (SA 316) which is welded to the 4" process pipe. The volumetric examination was performed to the latest technology available at the time of the examination and the examination achieved the maximum amount of coverage possible. The limitation for examination is due to physical design of the plant which is a carbon steel tapered nozzle, stainless steel buttered and welded to a stainless steel safe end weld. In addition, the adjacent process pipe to safe end weld also creates a limitation in that the sound paths travel is through the process pipe to safe end weld when examining the safe end to nozzle dissimilar metal weld. In order to achieve more volumetric coverage the plant would need to be redesigned and modified in order to achieve a credited examination of the pressurizer spray nozzle to safe end weld.

HRBSEP utilized ASME Code,Section XI, Appendix VIII dissimilar metal weld (DMW) qualified personnel for this examination.

Reactor Coolant Loop Hot/Cold Leg DMW at SG Nozzle - There are three steam generators and each contains an inlet nozzle and an outlet nozzle with each having the same dissimilar metal weld configuration. The examination is performed from a single side due to the steam generator nozzle configuration. The steam generator nozzles (SA 351) are clad on the nozzle interface side with stainless steel. The loop elbow is centrifically cast stainless steel (CFBM) with a stainless steel weld connecting the assembly to the stainless steel buttered carbon steel steam generator nozzle. There are no safe-ends associated with the steam generator to loop pipe elbow configurations.

These examinations were performed to the latest technology available at the time of the examination and the examination achieved the maximum amount of coverage possible.

The limitation for examination is due to physical design of the plant which would require the plant be redesigned and modified in order to achieve a credited examination of the steam generator nozzle to loop pipe weld. In addition, there is no approved Appendix VIII qualification for centrifugally cast austenitic steel but HRBSEP used Appendix VIII PDI (Performance Demonstration Initiative) qualified personnel, equipment, and procedures for this examination.

Proposed Alternative The licensee did not propose alternative examinations for the subject welds. However, the licensee's examinations were performed to the maximum extent practical.

NRC Staff Evaluation

The ASME Code requires essentially 100 percent volumetric and surface examinations for selected ASME Code,Section XI, Examination Category B-F pressure retaining dissimilar metal welds in ASME Code Class 1 vessel nozzles. However, complete volumetric examinations are restricted by cast austenitic stainless steel materials, design configurations, and adjacent piping in the subject welded components. These conditions preclude the licensee from obtaining full volumetric examinations from both sides of these welds. To gain access for examination, the welds would require design modifications. Imposition of this requirement would create a burden on the licensee, therefore, the ASME Code-required volumetric examinations are considered impractical.

As shown on the sketches and technical descriptions included in the licensee's submittals, examinations of the PZR and SG dissimilar metal nozzle welds have been completed to the extent practical with volumetric coverage ranging from approximately 47.5 to 75.0 percent (see Table 3.2.1 above) of the ASME Code-required volumes.

The limitations encountered during the performance of the ultrasonic examinations were caused by cast austenitic stainless steel (CASS) materials, and curvature of the nozzle-to-safe end and nozzle-to-elbow tapers. The PZR spray nozzle is carbon steel with stainless steel cladding on the inside diameter connected to a stainless steel safe-end. The SG nozzle is carbon steel with stainless steel cladding on the inside diameter connected to a CASS elbow. There are no Alloy 600 materials associated with these welds.

Volumetric examinations on the PZR spray nozzle weld were conducted with equipment, procedures and personnel that were certified to a performance demonstration process outlined in ASME Code Section XI, Appendix VIII. These techniques have been qualified for flaws located on the near and far-side of the welds using ASME Code, Appendix VIII, Supplement 10. The licensee's ultrasonic scanning techniques included 45-degree shear, and/or 45-and 60-degree refracted longitudinal waves (L-waves) for PZR dissimilar metal nozzle-to-vessel Weld 116B/19DM, performed from the safe-end side of the weld. L-waves have been shown to provide enhanced detection on the far-side of austenitic stainless steel welds, 1

• 2' 3 therefore, while the licensee has only taken credit for obtaining limited volumetric coverage, it is expected that the techniques employed would have provided coverage beyond the near-side of the welds. In addition, F.V.Ammirato, X. Edelmann, and S.M. Walker, Examination of Dissimilar Metal Welds in BWR Nozzle-to-Safe End Joints, 8th International Conference on NDE [Nondestructive Examination] in the Nuclear Industry, ASM International, 1987.

2 P. Lemaitre, T.D. Koble, and S.R. Doctor, PISC Ill Capability Study on Wrought-to-Wrought Austenitic Steel Welds: Evaluation at the Level of Procedures and Techniques, Effectiveness of Nondestructive Examination Systems and Performance Demonstration, PVP-Volume 317, NDE-Volume 14, ASME, 1995.

3 M.T. Anderson, A.A. Diaz, A.D. Cinson, S.L. Crawford, S.E. Cumblidge, S.R Doctor, K.M. Denslow, and S. Ahmed, 2011. An Assessment of Ultrasonic Techniques for Far-Side Examinations of Austenitic Stainless Steel Piping Welds, NUREG/CR-7113, PNNL-19353, U.S. Nuclear Regulatory Commission, Washington, DC.

the licensee completed the ASME Code-required liquid penetrant surface examination to its full extent. No recordable indications were noted during the performance of the surface or volumetric examinations other than an intermittent weld metal interface, which was acceptable as it did not exhibit any flaw characteristics.

Volumetric examinations on SG dissimilar metal nozzle welds were conducted using ASME Code,Section XI, Appendix Ill guidance since ASME Code,Section XI, Appendix VIII, Supplement 9, Qualification Requirements for Cast Austenitic Piping Welds, currently states that requirements are "In course of preparation." The licensee's ultrasonic scanning techniques included a 45-degree refracted L-wave for SG dissimilar metal nozzle-to-vessel welds listed in Table 3.2.1 above, from the CASS elbow side of the weld. In addition, the licensee completed the ASME Code-required liquid penetrant surface examinations to their full extent. No recordable indications were noted during the performance of the surface or volumetric examinations other than an intermittent weld metal interface, which was found acceptable as no flaw characteristics were noted.

The licensee has shown that it is impractical to meet the ASME Code-required volumetric examination coverage for the subject welds due to the design geometry of the welds and materials of construction. Based on the volumetric and surface coverage obtained, and considering the licensee's performance of ultrasonic techniques employed to maximize this coverage, the NRC staff finds it is reasonable to conclude that, if significant service-induced degradation had occurred in the wrought and welded portions of the ASME-required volumes of the subject welds, evidence of it would have been detected by the examinations performed. Furthermore, the NRC staff determined that the examinations performed provide reasonable assurance of structural integrity of the subject welds.

3.3 Requests for Relief RR-20, Part C. ASME Code,Section XI, Examination Category 8-J, Item 89.31, Pressure Retaining Welds in Piping ASME Code Requirement ASME Code,Section XI, Examination Category B-J, Item 89.31, requires essentially 100 percent volumetric and surface examinations, as defined by Figures IWB-2500-9, -10, and -11, as applicable, for branch pipe connection welds NPS 4 inch in diameter or larger. "Essentially 100 percent", as clarified by ASME Code Case N-460, is greater than 90 percent coverage of the examination volume, or surface area, as applicable. ASME Code Case N-460 has been approved for use by the NRC in RG 1.147, Revision 16.

Licensee's ASME Code Relief Request In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the ASME Code-required volumetric examination of Class 1 branch pipe connection welds shown in Table 3.3.1 below.

Table 3.3.1

• ASME Code, 8ectlon XI, Examination Category fbi (Unit 1)

ASIII.E C9Venlg$

COde WeldiD Weld Type Obtltnecl Item Percent B9.31 108/01 BC Branch connection-to-surge line pipe 50.0 B9.31 112/01 BC Pipe-to-Branch Connection 50.0 Reason for Relief Request In its submittal, the licensee stated the limitation for examination is due to physical design of the set on branch connection to loop pipe in which a volumetric limitation is encountered due to the physical configuration of the branch connection to loop pipe weld. In order to achieve more volumetric coverage the plant would need to be redesigned and modified in order to achieve a credited examination of the branch connection to surge line (or loop pipe) weld.

Proposed Alternative The licensee did not propose any alternative examinations for the subject welds.

However, the licensee's examinations were performed to the maximum extent practical.

NRC Staff Evaluation

The ASME Code requires essentially 100 percent volumetric and surface examinations for selected ASME Code,Section XI, Examination Category 8-J pressure retaining welds in piping. However, complete volumetric examinations are restricted by component design and weld configurations. These conditions preclude the licensee from obtaining full volumetric examinations from both sides of these welds. To gain access for examination, the welds would require design modifications. Imposition of this requirement would create a burden on the licensee, therefore, the ASME Code-required volumetric examinations are considered impractical.

As shown on the sketches and technical descriptions included in the licensee's submittal, examinations of the subject branch connection-to-pipe welds have been completed to the extent practical with volumetric coverage of 50.0 percent (see Table 3.3.1 above) of the ASME Code-required volumes. The limitation encountered during the performance of the ultrasonic examinations was caused by the curvature of the taper transition region from the branch connection-to-pipe weld configuration. These configurations limit the volumetric examinations primarily to the pipe side of these welds.

Volumetric examinations on the subject welds were conducted with equipment, procedures and personnel that were certified to a performance demonstration process outlined in ASME Code,Section XI, Appendix VIII. These techniques have been qualified for flaws located on the near-side of the welds; far-side detection of flaws is currently considered to be a "best effort." The licensee's ultrasonic scanning techniques included combinations of 45-degree shear, and 60-degree refracted L-waves for the ASME Class 1 branch pipe connection welds shown in Table 3.3.1 above, from the accessible side of the welds. L-waves have been shown to provide enhanced detection on the far-side of austenitic stainless steel welds, 1

• 2* 3 therefore, while the licensee has only taken credit for obtaining limited volumetric coverage, it is expected that the techniques employed would have provided coverage beyond the near-side of the welds.

For HBRSEP 2, the licensee completed the ASME Code-required surface examinations (liquid penetrant) on the subject welds with no limitations. No recordable indications were observed during the ultrasonic and surface examinations.

The licensee has shown that it is impractical to meet the ASME Code-required volumetric examination coverage for the subject welds due to the design geometry of the welds. Based on the volumetric and surface coverage obtained, and considering the licensee's performance of ultrasonic techniques employed to maximize this coverage, the NRC staff concludes that, if significant service-induced degradation had occurred in the subject welds, evidence of it would have been detected by the examinations performed. Furthermore, the NRC staff determined that the examinations performed provide reasonable assurance of structural integrity of the subject welds.

3.4 Request for Relief RR-20, Part D. Examination Category C-A. Item C1.20, Pressure Retaining Welds in Class 2 Pressure Vessels ASME Code Requirement ASME Code,Section XI, Examination Category C-A, Item C1.20, requires essentially 100 percent volumetric examination, as defined by Figure IWC-2500-1 of the length of Class 2 circumferential head welds. "Essentially 100 percent," as clarified by ASME Code Case N-460, is greater than 90 percent coverage of the examination volume, or surface area, as applicable. ASME Code Case N-460 has been approved for use by the NRC in RG 1.147, Revision 16.

Licensee's ASME Code Relief Request In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the ASME Code-required volumetric examination of the Class 2 circumferential head welds shown in Table 3.4.1 below:

202/01 Boron Injection Tank Shell-to-Lower Head Weld 80.3 C1.20 204/A02 Residual Heat Removal Heat Exchanger "A" Shell-to-Lower Head Weld 68.6 Reason for Relief Request In its submittal, the licensee states the following:

Boron Injection Tank (BIT) Shell-to-Lower Head Weld - The shell to lower head weld on the BIT is austenitic stainless steel welded to an austenitic stainless steel head and is limited by the four support legs and the shell to head configuration. The volumetric examination was performed to the latest technology available at the time of the examination and the examination achieved the maximum amount of coverage possible.

The limitation for examination is due to physical design of the plant in which a volumetric limitation is encountered due to the physical configuration of the shell to lower head weld. In order to achieve more volumetric coverage the plant would need to be redesigned and modified in order to achieve a credited examination of the shell to lower head weld on the BIT.

Residual Heat Removal Heat Exchanger "A" Shell-to-Lower Head Weld-The residual heat removal heat exchanger is a vertical mounted heat exchanger. The limited examination is on the shell to lower head weld which is made of austenitic stainless steel welded to the lower head which is made of austenitic stainless steel. The limitations associated with the impracticality are the inlet and outlet nozzles as well as the two supports on the vertical heat exchanger which interfere with the volumetric scan area.

The volumetric examination was performed to the latest technology available at the time of the examination and the examination achieved the maximum amount of coverage possible. The limitation for examination is due to physical design of the plant in which a volumetric limitation is encountered due to the physical configuration of the weld. In order to achieve more volumetric coverage the plant would need to be redesigned and modified in order to achieve a credited examination of the shell to lower head weld.

Proposed Alternative The licensee did not propose any alternative examinations for the subject welds.

However, the licensee's examinations were performed to the maximum extent practical.

NRC Staff Evaluation

The ASME Code requires essentially 1 00 percent volumetric examination of circumferential head welds on selected Class 2 pressure vessels. However, for the subject welds on the HBRSEP 2 BIT and residual heat removal (RHR) heat exchanger, complete examinations are limited due to the design configuration of these components and adjacent appurtenances. In order to achieve greater volumetric coverage, the BIT, RHR heat exchanger and adjacent components would have to be redesigned and modified. This would place a burden on the licensee, therefore the ASME Code examinations are considered impractical.

As shown on the sketches and technical descriptions included in the licensee's submittals, examinations of the "A" RHR heat exchanger lower head-to-shell Weld 204/A02 and the BIT shell-to-lower head Weld 202/01 have been performed to the extent practical, with the licensee obtaining approximately 68.6 and 80.3 percent, respectively, of the required ASME Code examination volume. The BIT shell-to-lower head Weld 201/01 was limited due to four welded tank support legs and a taper in the shell-to-head configuration. The "A" RHR heat exchanger shell-to-lower head Weld 204/A02 was limited due to the proximity of inlet and outlet nozzles along with two vertical supports on the heat exchanger; both of these conditions caused ultrasonic scanning limitations for the shell-to-lower head weld. The BIT and RHR heat exchanger are constructed of austenitic stainless steel materials. The licensee examined these welds using 0-degree L-wave, and 45-and 60-degree shear waves to achieve partial coverage along the weld lengths. There were no unacceptable indications noted during the volumetric examinations. Based on the RAI 2.2 response (ADAMS Accession No. ML14028A260), the licensee stated that HBRSEP 2 will incorporate L-wave methods into the subject vessel examination procedure and use these as supplemental examinations to be applied in limited areas for one-sided scans on stainless steel welds.

The licensee stated it will apply this supplemental technique in future examinations.

The licensee has shown that it is impractical to meet the ASME Code-required volumetric examination coverage for the subject welds due to the design geometry of the welds and proximity of integral appurtenances. The NRC staff determined that based on the volumetric coverage obtained, and the ultrasonic techniques employed, it is reasonable to conclude that, if significant service-induced degradation had occurred in the subject welds, evidence of it would have been detected by the examinations performed. Furthermore, the NRC staff determined that the examinations performed provide reasonable assurance of structural integrity of the subject welds.

3.5 Request for Relief RR-20, Part E. ASME /Code.Section XI. Examination Category C-B.

Item C2.21. Pressure Retaining Nozzle Welds in Class 2 Vessels ASME Code Requirement ASM Code,Section XI, Examination Category C-B, Item C2.21, requires 100 percent volumetric and surface examination, as defined by Figure IWC-2500-4(a) or (b), as applicable, of nozzle-to-shell (or head) welds in ASME Code Class 2 vessels. ASME Code Case N-460, as an alternative approved for use by the NRC in RG 1.147, Revision 16, states that a reduction in examination coverage due to part geometry or interference for any Class 1 and 2 weld is acceptable provided that the reduction is less than 10 percent, i.e., greater than 90 percent examination coverage is obtained.

Licensee's ASME Code Relief Request In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the ASME Code-required volumetric examination of ASME Code, Class 2 nozzle-to-head welds shown in Table 3.5.1 below:

Tabl* 3.5.1.... ASME Code,Section XI, Exami11ation C

,.C*B ASME QOYen!IJf*

Code WeldlD Weld Type

, Qbt;lined Item Percent C2.21 202/03 Boron Injection Tank Lower Head-to-Nozzle Weld 88.5 C2.21 202/04 Boron Injection Tank Upper Head-to-Nozzle 87.2 C2.21 205/08 Upper Shell to Feed Water Nozzle Weld 80.4 C2.21 205A/07 Upper head-to-Main Steam Nozzle Weld 83.3 Reason for Relief Request In its submittal, the licensee states the following:

Boron Injection Tank Lower/Upper Head-to-Nozzle Welds - The boron injection tank lower head to nozzle weld is limited due to the nozzle to head configuration which essentially produces a single sided examination. The volumetric limitation is encountered with the nozzle, which is a set-in nozzle and limits the downstream/upstream axial scan. The volumetric examination was performed to the latest technology available at the time of the examination and the examination achieved the maximum amount of coverage possible. The limitation for examination is due to physical design of the plant in which a volumetric limitation is encountered due to the physical configuration of the nozzle to head weld. In order to achieve more volumetric coverage the plant would need to be redesigned and modified in order to achieve a credited examination of the nozzle to head weld.

Upper Shell-to-Feed Water Nozzle Weld - The upper shell to feedwater nozzle weld is limited due to the nozzle to shell configuration which produces a single sided examination. The volumetric limitation is encountered with the nozzle, which is a set-in nozzle and limits the downstream axial scan. The materials associated with this limited weld are carbon steel materials. The volumetric examination was performed to the latest technology available at the time of the examination and the examination achieved the maximum amount of coverage possible. The limitation for examination is due to physical design of the plant in which a volumetric limitation is encountered due to the physical configuration of the nozzle to shell weld. In order to achieve more volumetric coverage the plant would need to be redesigned and modified in order to achieve a credited examination of the nozzle to shell weld.

Upper Head-to-Main Steam Nozzle Weld - The steam generator upper head to main steam nozzle weld is limited due to the nozzle to shell configuration which produces a single sided examination. The volumetric limitation is encountered with the nozzle, which is a set-in nozzle and limits the upstream axial scan of the downstream side of the weld. The materials associated with this limited weld are carbon steel materials. The volumetric examination was performed to the latest technology available at the time of the examination and the examination achieved the maximum amount of coverage possible. The limitation for examination is due to physical design of the plant in which a volumetric limitation is encountered due to the physical configuration of the nozzle to shell weld. In order to achieve more volumetric coverage the plant would need to be redesigned and modified in order to achieve a credited examination of the nozzle to shell weld.

Proposed Alternative The licensee did not propose any alternative examinations for the subject welds.

However, the licensee's examinations were performed to the maximum extent practical.

NRC Staff Evaluation

The ASME Code requires 100 percent volumetric and surface examinations of ASME Code, Class 2 nozzle-to-shell (or head) welds. However, for the subject BIT and SG nozzle-to-head (or shell) welds, complete examinations are limited due to the nozzles' configurations and a permanent insulation support ring. In order to achieve greater volumetric coverage, the nozzles and vessels would have to be redesigned and modified. This would place a burden on the licensee, therefore the ASME Code volumetric examination is considered impractical.

The subject SG main steam and feed water nozzle-to-vessel welds shown in Table 3.5.1 above are constructed of carbon steel materials. The BIT nozzle-to-vessel welds are constructed of austenitic stainless steel materials. These full penetration butt welds extend the full thickness of the vessel head or shell, and the nozzle configurations are of the "set in" design, which essentially makes the welds concentric rings aligned parallel with the nozzle axes. This nozzle design geometry restricts ultrasonic scanning mainly to the vessel side of the welds. In addition, on the SG upper shell-to-feed water nozzle Weld 205/08, there is a permanent insulation ring that limits the downstream scan by approximately 12 percent.

As shown on the sketches and technical descriptions included in the licensee's submittals, examinations of the SG and BIT nozzle-to-vessel welds have been completed to the extent practical with volumetric coverage ranging from approximately 80.4 to 88.5 percent (see Table 3.5.1) of the ASME Code-required volumes. The examination volumes included the weld and base materials near the inside surface of the weld joints, which are high regions of stress, and where one would expect degradation sources to be manifested should they occur. The SG and BIT nozzle-to-vessel weld examinations were performed with 0-degree longitudinal, and 45-and 50-degree shear waves. The licensee completed the ASME Code-required surface examinations on the subject weld with no limitations. No recordable indications were identified during the volumetric and surface examinations.

The licensee has shown that it is impractical to meet the ASME Code-required 100 percent volumetric examination coverage for the subject nozzle-to-shell welds due to the nozzle design configuration and permanent insulation ring. However, based on the volumetric and full surface coverage obtained, the NRC staff finds it is reasonable to conclude that, if significant service-induced degradation had occurred, evidence of it would be have been detected by the examinations performed. Furthermore, the staff determined that the examinations performed provide reasonable assurance of structural integrity of the subject welds.

3.6 Request for Relief RR-20, Part F. ASME Code Section XI, Examination Category C-C, Item C3.1 0, Integral Attachments for Class 2 Vessels, Piping, Pumps, and Valves ASME Code Requirement ASME Code,Section XI, Examination Category C-C, Item C3.1 0, requires 100 percent surface examination, as defined by Figure IWC-2500-5, of integrally welded attachments to Class 2 pressure vessels. ASME Code Case N-460, as an alternative approved for use by the NRC in RG 1.147, Revision 16, states that a reduction in examination coverage due to part geometry or interference for any Class 1 and 2 weld is acceptable provided that the reduction is less than 10 percent, i.e., greater than 90 percent examination coverage is obtained.

Licensee's ASME Code Relief Request In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the ASME Code-required surface examinations for boron injection tank support leg welded attachment 202/WS-2-ATT.

Reason for Relief Request In its submittal, the licensee states the following:

In its submittal, the licensee stated the welded attachment is on the boron injection tank support leg. The tank is stainless steel and the support leg plate is stainless steel welded to the shell creating a limitation on the backside of the support leg. The surface examination was performed satisfactorily on the available portions of this weld. The surface examination was limited due to the physical configuration of the support leg to the boron injection tank support leg and the examination achieved the maximum amount of coverage possible.

Proposed Alternative The licensee did not propose any alternative examinations for the subject welds.

However, the licensee's examinations were performed to the maximum extent practical.

NRC Staff Evaluation

The ASME Code requires 1 00 percent surface examination of the subject ASME Code, Class 2 integral attachment vessel welds. However, surface examinations are limited due to design configuration of the support leg to the vessel. In order for the licensee to obtain 1 00 percent of the ASME Code-required examination coverage, the integral attachment welds would have to be redesigned and modified. This would place a burden on the licensee; therefore, the ASME Code examination requirements are considered impractical.

As shown on the sketches and technical descriptions included in the licensee's submittals, liquid penetrant examination of the BIT support leg welded attachment has been performed to the extent practical, with the licensee obtaining surface examination coverage of approximately 88.0 percent of the ASME Code requirements. There is a permanent stainless steel plate between the backside of the support leg and the BIT shell along with interference from the insulation ring that limits the ASME Code surface examinations. There were no reportable indications detected during the surface examinations.

The licensee has shown that it is impractical to meet the ASME Code-required surface examination coverage for the subject Class 2 integral attachment vessel welds. However, based on the significant surface coverage obtained, if significant service-induced degradation had occurred, evidence of it would be have been detected by the examinations that were performed. Furthermore, the NRC staff determined that the examinations performed provide reasonable assurance of structural integrity of the subject welds.

3.7 Request for Relief RR-20, Part G. ASME Code,Section XI, Examination Category C-F-1, Item C5.11, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy

.EiQlng ASME Code Requirement ASME Code,Section XI, Examination Category C-F-1, Item C5.11, requires 100 percent surface and volumetric examination, as defined by Figure IWC-2500-7, of selected Class 2 austenitic stainless steel or high alloy circumferential piping welds. ASME Code Case N-460, as an alternative approved for use by the NRC in RG 1.147, Revision 16, states that a reduction in examination coverage due to part geometry or interference for any Class 1 and 2 weld is acceptable provided that the reduction is less than 1 0 percent, i.e., greater than 90 percent examination coverage is obtained.

Licensee's ASME Code Relief Request In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the ASME Code-required volumetric examination of the Class 2 austenitic stainless steel welds shown in Table 3.7.1 Below:

Tabl. 3~.1.1 - A$ME. Code, Section. XI, ~JniQa1JOJ\\~(egoryC*f,.1

.. A$ME

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~<Perc,nt C5.11 218/01 Valve RHR-751 to-Pipe 14.0-0.375 66.5 C5.11 219/186A Pipe-to-Tee 10- 1.0 87.5 C5.11 220/42 Elbow to Residual Heat 14-0.375 50.0 Removal Pump "A" Table 3.7.1 - ASME Code, S.Otion XJ,.Examination Ca.. -~

7 C*F*1 ASME Pipe~tze-eovera*e

.. 9 Code WeldiD Weld Type Thlcltnel$

Obtained item lncftis Percent C5.11 220A/62 Valve RHR-7528 to 14-0.375 50.0 Elbow C5.11 220A/72 Elbow-to-RHR Pump "B" 14-0.375 50.0 C5.11 221/171A Tee-to-Flange 12-0.375 75.0 C5.11 239/02 Pipe-to-Valve SI-878A 4-0.337 50.0 Weld Reason for Relief Request In its submittal, the licensee states the following:

Valve RHR-751 to-Pipe-The examination has single side access and is limited by the pipe to valve configuration which limits the circumferential and upstream scan.

Pipe-to-Tee-The pipe to tee weld is austenitic stainless steel welded to a stainless steel tee thereby creating a limited examination in the tee intrados area. The examination is limited from the outside diameter blend radius of the tee branch.

Elbow to Residual Heat Removal Pump "A"- The examination is limited due to elbow to pump taper. The upstream scan was not performed due to the pump taper which would not provide any credited coverage.

Valve RHR-7528 to Elbow-The examination has single side access and is limited by the pipe to valve configuration which limits the circumferential and downstream scan.

There was no downstream scan performed on the upstream side of the weld due to the pipe to valve configuration.

Elbow-to-RHR Pump "8" - The elbow to pump nozzle weld is austenitic stainless steel welded to a stainless steel pump nozzle weld creating a single sided examination. The examination is limited due to elbow to pump taper.

Tee-to-Flange - The examination is limited from the tapered flange to tee configuration creating a single sided examination. There was no upstream scan performed due to the tapered flange and the downstream scan of the upstream side of the weld achieved 100.00% of the volume.

Pipe-to-Valve SI-878A Weld-The examination has single side access and is limited by the pipe to valve configuration which limits the circumferential and upstream scan of the downstream side of the weld. There was no scan performed upstream due to the pipe to valve configuration and the upstream scan of the downstream side of the weld achieved 100.00% of the volume.

Proposed Alternative The licensee did not propose any alternative examinations for the subject welds.

However, the licensee's examinations were performed to the maximum extent practical.

NRC Staff Evaluation

The ASME Code requires 100 percent volumetric and surface examination for selected Class 2 pressure-retaining welds in austenitic stainless steel or high alloy circumferential piping. However, volumetric examinations are limited by design geometries, material of the welds, and associated piping configurations. To gain access for examination, the welds and piping would require design modifications. Imposition of this requirement would create a burden on the licensee, therefore, the ASME Code-required 1 00 percent volumetric examinations of the welds are considered impractical.

As shown on the sketches and technical descriptions included in the licensee's submittal, examinations of the subject welds have been performed to the extent practical with the licensee obtaining volumetric coverage ranging from approximately 50 to 87.5 percent. Access for examination of the subject piping welds is limited to primarily one side of the weld due to the tee-to-flange, valve-to-pipe, elbow-to-pump, valve-to-elbow, or pipe-to-tee weld taper configurations (see Table 3.7.1 above). Volumetric examinations on the subject welds were conducted with equipment, procedures and personnel that were certified to a performance demonstration process outlined in ASME Code Section XI, Appendix VIII.

The licensee's ultrasonic techniques included 45-, 60-, and/or 70-degree shear waves, and in some cases, 60-degree refracted L-waves, as applicable. L-waves have been shown to provide enhanced detection on the far-side of austenitic stainless steel welds. 1* 2* 3 While the licensee has only taken credit for limited volumetric coverage obtained from primarily one side, it is expected that the techniques employed would have provided coverage beyond the near-side of the welds. No recordable indications were noted during the performance of the volumetric examinations other than weld root geometry. In addition, the licensee completed the ASME Code-required liquid penetrant surface examinations to their full extent. There were five indications, one linear and four rounded, identified and found acceptable per ASME Code.

The licensee has shown that it is impractical to meet the ASME Code-required 1 00 percent volumetric examination coverage for the subject piping welds due to their configurations and materials. Although the ASME Code-required coverage could not be obtained, the ultrasonic techniques employed would have provided full volumetric coverage for the near-side of the welds and limited volumetric coverage for the weld fusion zone and base materials on the opposite side of the welds. Based on the aggregate coverage obtained for the subject welds, and considering the licensee's performance of full surface examinations, the NRC staff finds it is reasonable to conclude that if significant service-induced degradation had occurred, evidence of it would have been detected. Furthermore, the staff determined that the examinations performed provide reasonable assurance of structural integrity of the subject welds.

3.8 Request for Relief RR-20, Part H. ASME Code,Section XI, Examination Category C-F-2, Item C5.51, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping ASME Code Requirement ASME Code,Section XI, Examination Category C-F-2, Item C5.51, requires 100 percent surface and volumetric examination, as defined by Figure IWC-2500-7, of selected Class 2 carbon steel or low alloy steel circumferential piping welds. ASME Code Case N-460, as an alternative approved for use by the NRC in RG 1.147, Revision 16, states that a reduction in examination coverage due to part geometry or interference for any Class 1 and 2 weld is acceptable provided that the reduction is less than 10 percent, i.e.,

greater than 90 percent examination coverage is obtained.

Licensee's ASME Code Relief Request In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from the ASME Code-required volumetric examination of the Class 2 carbon steel welds shown in Table 3.8.1 below:

T*ble3.8.1 ASME Code SectiQn XI, El(arninati()f\\ Category c-f-2 ASME Pipijs~ taV.ritae Code WeldiO Weld Type T'&~~* q~~"'~

Item Percent C5.51 212/21 Pipe-to-Valve MS-V1-3A Weld 26-1.042 75.0 C5.51 214/19 Pipe-to-Valve MS-V1-3C Weld 26-1.042 75.0 Reason for Relief Request In its submittal, the licensee states the following:

In its submittal, the licensee stated the pipe to valve weld is carbon steel welded to a carbon steel valve body creating a single sided exam. The examination has single side access and is limited by the pipe to valve configuration which limits the upstream scan.

Proposed Alternative The licensee did not propose any alternative examinations for the subject welds.

However, the licensee's examinations were performed to the maximum extent practical.

NRC Staff Evaluation

The ASME Code requires 1 00 percent volumetric and surface examination for selected Class 2 pressure-retaining welds in carbon steel or low alloy steel circumferential piping.

However, volumetric examinations are limited by the subject piping configurations. To gain access for examination, the welds and piping would require design modifications.

Imposition of this requirement would create a burden on the licensee, therefore, the ASME Code-required 100 percent volumetric examinations of the welds are considered impractical.

As shown on the sketches and technical descriptions included in the licensee's submittal, access for examination of the subject welds is limited to primarily one side of these welds due to the taper configurations on the valves. Pipe-to-valve Welds 212/21 and 214/19 have been completed to the extent practical with volumetric coverage of 75.0 percent, using 45-and 60-degree shear waves. Volumetric examinations on the subject welds were conducted with equipment, procedures and personnel that were certified to a performance demonstration process outlined in ASME Code Section XI, Appendix VIII.

In addition, the licensee completed the ASME Code-required magnetic particle surface examinations to their full extent. No recordable indications were noted during the performance of the surface or volumetric examinations other than weld root geometry.

Although ultrasonic scans were primarily limited to the pipe side, studies have found that inspections conducted through carbon steel are equally effective whether the ultrasonic waves have only to propagate through the base metal, or have to also propagate through the carbon steel weldment.4 Therefore, it is expected that the ultrasonic techniques employed by the licensee on the carbon steel circumferential piping welds would detect structurally significant flaws that might occur on either side of the subject welds due to the fine-grained carbon steel microstructures present in these materials.

The licensee has shown that it is impractical to meet the ASME Code-required 100 percent volumetric examination coverage for the subject piping welds due to the pipe-to-valve configurations. Based on the limited examinations performed, and considering the enhanced detection capabilities of performance demonstrated techniques on ferritic welds along with the full surface coverage obtained, it is reasonable to conclude that, if significant service-induced degradation had occurred in the subject weld, evidence of it would have been detected by the examination that was performed.

4.0 CONCLUSION

S As set forth above, the NRC staff determines that granting relief pursuant to 10 CFR 50.55a(g)(6){i) is authorized by law and will not endanger life or property, or the common defense and security, and is otherwise in the public interest given due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Furthermore, the staff concludes that the examinations performed to the extent practical provide reasonable assurance of structural integrity of the subject components. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 1 0 CFR 50.55a(g)(6)(i) and is in compliance with the ASME Code 4

Heasler, P. G. and S. R. Doctor, 1996. Piping Inspection Round Robin, NUREG/CR-5068, PNNL-10475, U. S. Nuclear Regulatory Commission, Washington, DC.

requirements. Therefore, the NRC staff grants relief for the subject examinations of the components contained in RR 20, Sections 2 through 29 for the fourth lSI interval at HBRSEP, which ended on July 20, 2012.

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

Principal Contributor: Thomas McLellan Date: June 23, 2014

ML101800536). This recommendation by the staff is not a condition for the approval of this relief request.

All other ASME Operation and Maintenance Code requirements for which alternatives or relief was not specifically requested and approved in the subject request remain applicable.

If you have any questions or concerns, please contact the Project Manager, Martha Barillas, at 301-415-2760.

Docket No. 50-261

Enclosure:

Safety Evaluation cc w/encl.: Distribution via Listserv DISTRIBUTION:

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Lisa M. Regner, Acting Branch Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

• via memo DE/EPNB*

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