Text

ASME Section XI Inservice Inspection Program Relief Requests for Limited Coverage Examinations Performed in the Second Period of the Third 10-Year Inspection Interval
	ML20049A088
Person / Time
Site:	Millstone
Issue date:	02/17/2020
From:	Mark D. Sartain; Dominion Energy Nuclear Connecticut
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	19-403
	Download: ML20049A088 (89)
	v • d • e

{{#Wiki_filter:Dominion Energy Nuclear Connecticut, Inc. 5000 Dominion Boulevard, Glen Allen, VA 23060 DominionEnergy.com February 17, 2020 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. MILLSTONE POWER STATION UNIT 3 Dominion Energy Serial No. NRA/SS Docket No. License No. 19-403 RO 50-423 NPF-49 ASME SECTION XI INSERVICE INSPECTION PROGRAM RELIEF REQUESTS FOR LIMITED COVERAGE EXAMINATIONS PERFORMED IN THE SECOND PERIOD OF THE THIRD 10-YEAR INSPECTION INTERVAL The Millstone Power Station Unit 3 (MPS3) third 10-year interval for the inservice inspection program began on April 23, 2009. During the second inspection period of this interval, the components identified in Attachments 1 through 6 received less than the required examination coverage. Accordingly, pursuant to 10 CFR 50.55a(g)(5)(iii), Dominion Energy Nuclear Connecticut, Inc. requests relief on the basis that the required examination coverage was impractical due to physical obstructions and limitations imposed by design, geometry and materials of construction of the subject components. Attachments 1 through 6 contain the specific relief requests and the individual basis for each request. These relief requests have been reviewed and approved by the station's Facility Safety Review Committee. If you have any questions or require additional information, please contact Shayan Sinha at (804) 273-4687. Sincerely, Mark D. Sartain Vice President - Nuclear Engineering & Fleet Support

Attachments: Serial No. 19-403 Docket No. 50-423 Page 2 of 2

1. Relief Request IR-3 Examination Category B-8, Pressure Retaining Welds in Vessels other than Reactor Vessels

2. Relief Request IR-3 Examination Category B-O, Full Penetration Welded Nozzles in Vessels - Inspection Program B

3. Relief Request IR-3-33, Examination Category C-A, Pressure Retaining Welds in Pressure Vessels

4. Relief Request IR-3-34, Examination Category C-F-1, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping

5. Relief Request IR-3-35, Examination Category C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping

6. Relief Request IR-3-36, Examination Category R-A, Risk-Informed Piping Examinations Commitments made in this letter: None cc:

U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 R. V. Guzman Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-C 2 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

ATTACHMENT 1 RELIEF REQUEST IR-3-31 EXAMINATION CATEGORY 8-8 Serial No. 19-403 Docket No. 50-423 PRESSURE RETAINING WELDS IN VESSELS OTHER THAN REACTOR VESSELS DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC) MILLSTONE POWER STATION UNIT 3 (MPS3)

10 CFR 50.55a Request Number: IR-3-31 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii) lnservice Inspection Impracticality

1. ASME Code Components Affected:

ASME Code Class: Code Class 1 Serial No. 19-403 Docket No. 50-423, Page 1 of 6 Examination Category: B-B, Pressure Retaining Welds in Vessels other than Reactor Vessels Item Numbers: B2.40, Steam Generator (Primary Side), Tube Sheet-to Head Weld Component Identification: Listed in Table 1 Material: Channel Head SA 533, GR B - CL. 1 Tube Sheet Plate SA 508 - Class 2

2. Applicable Code Addition and Addenda ASME Section XI, 2004 Edition, No addenda

3. Applicable Code Requirement

ASME Section XI, 2004 Edition, Category B-B requires volumetric examination of 100 percent (%) of the weld volume as defined in Table IWB-2500-1 and shown in Figure IWB-2500-6. The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory Guide 1.147, Revision 18, allow credit for essentially 100% coverage of a weld provided greater than 90% of the required volume has been examined.

4. Impracticality of Compliance

Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from essentially 100% volumetric examination coverage requirement for the subject weld due to the design and permanent obstructions which limit the volumetric coverage that can be obtained.

Serial No. 19-403 Docket No. 50-423, Page 2 of 6 The examination of the subject weld was performed with a manual ultrasonic technique using equipment and procedures written in accordance with ASME Section XI, Appendix 1 and Section V, Article 4. The subject steam generator tube sheet-to-head weld 03-003-SW-Z is limited due to the close proximity of the tube sheet flange that limits scanning on the flange side of the weld and additional limitations due to four lower steam generator support vertical members. Specifically, the 45° and 60° scans are limited for 12 inches in four locations due to the close proximity of the supports. The 45° and 60° axial scans are limited to approximately 51/2 inches from the centerline of the weld on the tube sheet side due to the location of the tube sheet plate. The required examination volume of this weld was interrogated ultrasonically to the maximum extent possible. No alternative techniques or advanced technologies, including phased array, were considered to be capable of obtaining complete examination coverage. Coverage calculation and limitation sketches are provided in Attachment 1. TABLE 1 Limited Examination Category B-B, Pressure Retaining Welds in Vessels other than Reactor Vessels Weld Code Configuration Identification Item# 03-003-SW-Z B2.40 Steam generator tube sheet to head weld

===5. Burden Caused by Compliance=== Examination Angle and Limitations and Wave Mode Results 00 Longitudinal Wave Scan limitations 45° Shear Wave due to 60° Shear Wave obstruction caused by tube sheet flange and steam generator lower support members. No recordable indications were detected. Examination Coverage (%) 85.4% Compliance with the Code requirements for weld 03-003-SW-Z would require removal of the lower steam generator support members which provide stability and support the weight of the steam generator. Additionally, modification or replacement

Serial No. 19-403 Docket No. 50-423, Page 3 of 6 of the steam generator with a design such that weld examination coverage from the position of the tube sheet is possible, would not be practical. DENC considers these options to meet the 100% Code examination requirement to be impractical due to the cost, increased radiation exposure, and impact to plant equipment.

6. Proposed Alternative Examination and Basis for Use The subject weld received a volumetric examination to the maximum extent practical utilizing the best available techniques. Additionally, this component is monitored for through-wall leakage as part of the ASME Section XI System Pressure Test Program and receives a visual (VT-2) examination at the end of each refueling outage during the system leakage test as required by Section XI, Table IWB-2500-1, Category B-P for Class 1 components.

Based upon the examination volume that was obtained with acceptable results, along with the visual (VT-2) examination performed each refueling outage, it is reasonable to conclude that service-induced degradation would be detected. Therefore, this proposed alternative will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject weld.

7. Duration of Proposed Alternative

Relief is requested for the third ten-year inspection interval for MPS3, which began on April 23, 2009 and ended on June 22, 2019 (extended from April 22, 2019 in ML19100A126).

8. Precedent A similar relief request was approved for use at MPS3 during the second 10-year ISi interval (i.e., Relief Request IR-2-52 (ADAMS Accession No. ML110691154)).

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37. 73 sq. inches Weld Volume "'[85.3% (Perpendicular scan)+88.3% (Parallel scan)]/2"'86.8%

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ATTACHMENT 2 RELIEF REQUEST IR-3-32 EXAMINATION CATEGORY 8-D Serial No. 19-403 Docket No. 50-423 FULL PENETRATION WELDED NOZZLES IN VESSELS - INSPECTION PROGRAM B DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC) MILLSTONE POWER STATION UNIT 3 (MPS3)

1 0CFR50.55a Relief Request IR-3-32 Relief Requested Serial No. 19-403 Docket No. 50-423, Page 1 of 11 In Accordance with 10 CFR 50.55a(g)(5)(iii) lnservice Inspection Impracticality

1. ASME Code Components Affected:

ASME Code Class: Code Class 1 Examination Category: 8-D, Full Penetration Welded Nozzles in Vessels - Inspection Program 8 Item Numbers: 83.110, Pressurizer, Nozzle-to-Vessel Welds 83.130, Steam Generator (Primary Side), Nozzle-to Vessel Welds Component Identification: Listed in Table 1 Material: Pressurizer: Head - SA533, GR A, CL2 Nozzle - SA508, CL2 Steam Generator: Head - SA533, GR 8, CL 1 Nozzle - SA508, CL2

2. Applicable Code Addition and Addenda ASME Section XI, 2004 Edition, No Addenda

3. Applicable Code Requirement

ASME Section XI, 2004 Edition, Examination Category 8-D requires volumetric examination of 100 percent (%) of the weld volume as defined in Table IW8-2500-1 and shown in Figures IW8-2500-7 (a) - (d). The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory Guide 1.14 7, Revision 18, allow credit for essentially 100% coverage of a weld provided greater than 90% of the required volume has been examined.

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

Serial No. 19-403 Docket No. 50-423, Page 2 of 11 The steam generator nozzle-to-head welds and the pressurizer relief and safety nozzle-to-head welds were all examined with a manual ultrasonic technique using equipment and procedures written in accordance with ASME Section XI, Appendix 1 and Section V, Article 4. Limitations imposed by the nozzle configuration preclude obtaining 100% coverage. This configuration with the nozzle outside radius within close proximity of the weld prevents complete scanning in these areas due to lift-off of the search unit that occurs causing a loss of contact between the search unit and the component. The required examination volume of these welds was interrogated ultrasonically to the maximum extent possible. No alternative techniques or advanced technologies, including phased array, were considered capable of obtaining complete examination coverage. Isometric drawing(s) and coverage calculations are provided in this attachment.

Weld Code Identification Item# 03-006-SW-U B3.130 03-006-SW-V B3.130 03-007-SW-B B3.110 03-007-SW-C B3.110 03-007-SW-D B3.110 TABLE 1 Serial No. 19-403 Docket No. 50-423, Page 3 of 11 Examination Category B-D Welds with Limited Volumetric Coverage Examination Angle and Examination Configt1ration Limitations and*Results ). WaveMode

- Coverage (%)

Steam Generator Outlet oo Longitudinal Wave Scan limitations due to nozzle 70.9% Nozzle to Head Weld 45° Shear Wave configuration restricting the scans from 60° Shear Wave the nozzle side. No recordable indications were detected. Steam Generator Inlet oo Longitudinal Wave Scan limitations due to nozzle 70.9% Nozzle to Head Weld 45° Shear Wave configuration restricting the scans from 60° Shear Wave the nozzle side. No recordable indications were detected. Pressurizer Safety Nozzle to oo Longitudinal Wave Scan limitations due to nozzle 82.1% Head Weld 45° Shear Wave configuration restricting the scans from 60° Shear Wave the nozzle side. No recordable indications were detected. Pressurizer Safety Nozzle to oo Longitudinal Wave Scan limitations due to nozzle 82.1% Head Weld 45° Shear Wave configuration restricting the scans from 60° Shear Wave the nozzle side. No recordable indications were detected. Pressurizer Relief Nozzle to oo Longitudinal Wave Scan limitations due to nozzle 82.1% Head Weld 45° Shear Wave configuration restricting the scans from 60° Shear Wave the nozzle side. No recordable indications were detected.

5. Burden Caused by Compliance

Serial No. 19-403 Docket No. 50-423, Page 4 of 11 To increase examination coverage on the subject welds would require a significant design modification or replacement of components with a different design to eliminate the noted obstructions. DENG considers these options to meet the 100% code examination requirement to be impractical due to cost, increased radiation exposure, and impact to plant equipment.

6. Proposed Alternative and Basis for Use

The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques. Additionally, these components are monitored for through-wall leakage as part of the ASME Section XI System Pressure Test Program and receive a visual (VT-2) examination at the end of each refueling outage during the system leakage test as required by Section XI, Table IWB-2500-1, Category B-P for Class 1 components. Based upon the examination volumes that were obtained with acceptable results, along with the visual (VT-2) examination performed each refueling outage, it is reasonable to conclude that service-induced degradation would be detected. Therefore, this proposed alternative will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Duration of Proposed Alternative

The relief is requested for the third ten-year inspection interval for MPS3, which began on April 23, 2009 and ended on June 22, 2019 (extended from April 22, 2019 in ML19100A126).

8. Precedent A similar relief request was approved for use at MPS3 during the first inspection period of the third 10-year ISi interval (i.e., Relief Request IR-3-20 (ADAMS Accession No. ML16136A001 )).

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45° &60° Component ID:03-006-SW-U Weld Coverage Head Side Weld 0 deg.=100% 45 deg.=100% 60 deg.= 100% Nozzle Side Weld 0 deg.=100% 45 deg. =36.5% 60 deg.=22.9% CW Weld 0 deg.=100% 45 deg.=100% 60 deg.= 100% CCW Weld 0 deg.=100% 45 deg.=100% 60 deg.=100% Total Weld Area 3.9438 square inches Total Area 27.68 sq. inches missed coverage 2.33 sq. inches 0 deg. Weld and Base Material Area Total Area 31.62 sq. inches Examination Coverage Summary I Weld Volume =[22.9% (Perpendicular scan)+100% (Parallel scan)]/2=61.5% 45° 60° Total Weld Coverage in two directions 0.9061 square inches Coverage 22.9% Total Base Material Coverage in one direction 25.35 sq. inches 91.5% Coverage Total Coverage with 0 deg. 21.94 sq. inches 69.3 % Coverage Base Material Volume=[91.5%(Perpendicular scan)+69.3%(Parallel scan)]/2=80.4% Total Coverage = 70.9% Base Material Coverage Head Side Base Material 0 deg.=69.3% 21.94 sq.in' 45 deg.=91.5% 24.98 sq. in 60 deg.=94.5% 25.85 sq. in Nozzle Side Base Material 0 deg.=69.3% 21.94 sq. in 45 deg.= 31.5% 8.63 sq. in 60 deg.= 17.2% 4.71 sq. in CW Base Material 0 deg.=69.3% 21.94 sq. in 45 deg.=69.3% 21.94 sq. in 60 deg.=69.3% 21.94 sq. in CCW Base Material 0 deg.=69.3% 21.94 sq. in 45 deg.=69.3% 21.94 sq. in 60 deg.=69.3% 21.94 sq. in ru 0

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45° & 60° Component ID:03-006-SW-V Weld Coverage Head Side Weld 0 deg.=100% 45 deg.=100% 60 deg. =100% Nozzle Side Weld 0 deg.=100% 45 deg. =36.5% 60 deg.=22.9% CW Weld 0 deg.=100% 45 deg.=100% 60 deg.=100% CCW Weld 0 deg.=100% 45 deg.=100% 60 deg.=100% Total Weld Area 3.9438 square inches Total Area 27.68 sq. inches missed coverage 2.33 sq. inches 0 deg. Weld and Base Material Area Total Area 31.62 sq. inches Examination Coverage Swnmary I Weld Volume =[22.9% (Perpendicular scan)+-100% (Parallel scan)]/2=61.5% 45° Total Weld Coverage in two directions 0.9061 square inches 60° Coverage 22.9% Total Base Material Coverage in one direction 25.35 sq. inches 91.5% Coverage Total Coverage with O deg. 21.94 sq. inches 69.3 % Coverage Base Material Volume=[91.5%(Perpendicular scan)+69.3%(Parallel scan)]/2=80.4% Total Coverage = 70.9% Base Material Coverage Head Side Base Material 0 deg.=69.3% 21.94 sq.in 45 deg.=91.5% 24.98 sq. in 60 deg.=94.5% 25.85 sq. in Nozzle Side Base Material 0 deg;=69.3% 21.94 sq. in 45 deg.= 31.5% 8.63 sq. in 60 deg.= 17.2% 4.71 sq. in CW Base Material 0 deg.=69.3% 21.94 sq. in 45 deg.=69.3% 21.94 sq. in 60 deg.=69.3% 21.94 sq. in CCW Base Material 0 deg.=69.3% 21.94 sq. in 45 deg.=69.3% 21.94 sq. in 60 deg.=69.3% 21.94 sq. in 0 3 O en r+ 0 NO CD :::!. ""OQ!. !l) z z COO 0 CD. 00 01 0? cp - No c..vc..v

Component ID: 03-007-SW-B Weld Coverage Head Side Weld 45° & 60° 0 deg.=100% 45 deg.=100% Total Weld Area 2.07 sq. Inches l 60 deg.= 100% Nozzle Side Weld 0 deg.=100% 45 deg. =58.5% 60 deg.=43.7% CW Weld 0 deg.=100% 45 deg.=100% 60 deg.=100% CCW Weld 0 deg.=100% 45 deg.=100% 60 deg.=100% Total Area 9.58" sq. inches missed coverage .3685 sq. inches Examination Coverage Summary Total Weld Coverage in two directions .9059 sq. inches 43.7% coverage Total Base Material Coverage in one direction 9.21 sq. inches

96. 7% Coverage Total Coverage with O deg.

8.79 sq. inches 88% Coverage Weld Volume =[43.7% (Perpendicular scan)+l00% (Parallel scan)]/2=71.8% Base Material Volume=[96.9%(Perpendicular scan)+88.0%(Parallel scan)]/2=92.4% Total Coverage = 82.1 % Base Material Coverage Head Side Base Material 0 deg.= 100% 45 deg.= 100% 60 deg.= 100% Nozzle Side Base Material 0 deg.=88.0% 8. 79 sq. in 45 deg.= 96.7% 9.21 sq. in 60 deg.= 96.7% 9.21 sq. in CW Base Material 0 deg.=88.0% 8.79 sq.in 45 deg.=88.0% 8.79 sq. in 60 deg.=88.0% 8.79 sq. in CCW Base Material 0 deg.=88.0% 8.79 sq.in 45 deg.=88.0% 8.79 sq. in 60 deg.=88.0% 8.79 sq. in 0

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96. 7% Coverage Total Coverage with O deg.

8.79 sq. inches 88% Coverage Weld Volume =[ 43. 7% (Perpendicular scan)+ I 00% (Parallel scan)]/2=71.8% Base Material Volume=[96.9%(Perpendicular scan)+88.0%(Parallel scan)]/2=92.4% Total Coverage = 82.1% Base Material Coverage Head Side Base Material 0 deg.= 100% 45 deg.= 100% 60 deg.= 100% Nozzle Side Base Material 0 deg.=88.0% 8.79 sq. in 45 deg.= 96.7% 9.21 sq. in 60 deg.= 96.7% 9.21 sq. in CW Base Material 0 deg.=88.0% 8.79 sq.in 45 deg.=88.0% 8. 79 sq. in 60 deg.=88.0% 8.79 sq. in CCW Base Material 0 deg.=88.0% 8.79 sq.in 45 deg.=88.0% 8.79 sq. in 60 deg.=88.0% 8.79 sq. in () 3 (D en J') () (D "U m n-Q) (0 z z <D O 0 O 01 -'- 00 <0 -.h.h ->-NO ->. (.,.) w

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8. 79 sq. inches 88% Coverage Weld Volume =[43.7% (Perpendicular scan)+IO0% (Parallel scan)]/2=71.8%

Base Material Volume=[96.9%(Perpendicular scan)+88.0%(Parallel scan)]/2=92.4% Total Coverage = 82.1 % Base Material Coverage Head Side Base Material 0 deg.= 100% 45 deg.= 100% 60 deg.= 100% Nozzle Side Base Material 0 deg.=88.0% 8.79 sq. in 45 deg.= 96.7% 921 sq. in 60 deg.= 96.7% 9.21 sq. in CW Base Material 0 deg.=88.0% 8.79 sq.in 45 deg.=88.0% 8.79 sq. in 60 deg.=88.0% 8.79 sq. in CCW Base Material 0 deg.=88.0% 8.79 sq.in 45 deg.=88.0% 8.79 sq. in 60 deg.=88.0% 8.79 sq. in nr ()

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ATTACHMENT 3 RELIEF REQUEST IR-3-33 EXAMINATION CATEGORY C-A Serial No. 19-403 Docket No. 50-423 PRESSURE RETAINING WELDS IN PRESSURE VESSELS DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC) MILLSTONE POWER STATION UNIT 3 (MPS3)

10 CFR 50.55a Relief Request IR-3-33 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii) lnservice Inspection Impracticality

1. ASME Code Components Affected:

ASME Code Class: Code Class 2 Serial No. 19-403 Docket No. 50-423, Page 1 of 6 Examination Category: C-A, Pressure Retaining Welds in Pressure Vessels Item Numbers: C1.10, Shell Circumferential Welds Component Identification: Listed in Table 1 Material: SA 240, Type 304

2. Applicable Code Addition and Addenda ASME Section XI, 2004 Edition, No Addenda

3. Applicable Code Requirement

ASME Section XI, 2004 Edition, Category C-A requires volumetric examination of 100 percent (%) of the weld length as defined in Table IWC-2500-1 and shown in Figure IWC 2500-1. The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory Guide 1.147, Revision 18, allow credit for essentially 100% coverage of a weld provided greater than 90% of the required volume has been examined.

4. Impracticality of Compliance

Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the 100% volumetric examination coverage requirement of the subject weld due to the geometric configuration and permanent obstructions which limit the volumetric coverage that can be obtained. The Residual Heat Removal heat exchanger shell-to-flange weld 03-07 4-004 was examined with a manual ultrasonic technique using the best technology available to achieve the maximum examination coverage practical. The examination was

Serial No. 19-403 Docket No. 50-423, Page 2 of 6 performed using equipment and procedures written in accordance with ASME Section XI, Appendix 1 and Section V, Article 4. No alternative techniques or advanced technologies, including the use of phased array, were considered capable of obtaining complete coverage of the examination volume. The position of the flange is within close proximity of the weld and there is not sufficient distance from the flange to the weld to allow any scanning of that side. Additionally, there are two permanently-welded reinforcing plates located at the outlet and inlet nozzles that further limit the axial and circumferential coverage that can be obtained. Isometric drawing and coverage calculations are provided in this attachment. TABLE 1 Examination Category C-A Weld with Limited Volumetric Coverage i Weld code E.xaminatiori Angle and Limitations and Ex8111ination Identification Item# Configuration 03-074-004 Cl.10 Shell to Flange

5. Burden Caused by Compliance

Wave... Mode 45° Shear Wave 60° Shear Wave 60° Longitudinal Wave Results Coverage (%) Limited examination 35.5% performed due to flange and nozzle reinforcing plates within close proximity to the weld. Eight recordable indications were detected that were evaluated as acceptable geometrical reflectors due to ID weld root geometry and an internal divider plate. To increase examination coverage on the subject weld would require a significant design modification or replacement of the component with a different design to eliminate the noted obstructions. DENC considers these options to meet the 100% Code examination requirement impractical due to cost, increased radiation exposure, and impact to plant equipment.

6. Proposed Alternative and Basis for Use

Serial No. 19-403 Docket No. 50-423, Page 3 of 6 The subject weld received a volumetric ultrasonic examination utilizing the best available techniques on the accessible portions of weld to the maximum extent practical. Additionally, this component is monitored for through-wall leakage as part of the ASME Section XI Pressure Test Program and receives a visual (VT-2) examination during each inspection period as required by Section XI, Table IWC-2500-1, Category C-H, for Class 2 components. Based upon the examination volume that was obtained with acceptable results, along with the visual (VT-2) examination performed each inspection period, it is reasonable to conclude that service-induced degradation would be detected. Therefore, this proposed alternative will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject weld.

7. Duration of Proposed Alternative

The relief is requested for the third ten-year inspection interval for MPS3, which began on April 23, 2009 and ended on June 22, 2019 (extended from April 22, 2019 in ML19100A126).

8. Precedent A similar relief request was approved for use at MPS3 during the first inspection period of the third 10-year ISi interval (i.e., Relief Request IR-3-21 (ADAMS Accession No. ML16136A001 )).

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ATTACHMENT 4 RELIEF REQUEST IR-3-34 EXAMINATION CATEGORY C-F-1 Serial No. 19-403 Docket No. 50-423 PRESSURE RETAINING WELDS IN AUSTENITIC STAINLESS STEEL OR HIGH ALLOY PIPING DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC) MILLSTONE POWER STATION UNIT 3 (MPS3)

10 CFR 50.55a Relief Request IR-3-34 Relief Requested Serial No. 19-403 Docket No. 50-423, Page 1 of 22 In Accordance with 10 CFR 50.55a(g)(5)(iii) lnservice Inspection Impracticality

1. ASME Code Components Affected:

ASME Code Class: Examination Category: Item Number: Code Class 2 C-F-1, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping C5.11, Circumferential welds: Piping Welds >3/8 in. (10 mm) Nominal Wall Thickness for Piping >NPS 4 in. (ON 100) C5.21, Circumferential welds: Piping Welds >1/5 in. (5 mm) Nominal Wall Thickness for Piping >NPS 2 in. (ON

50) andN 4 in. (ON 100)

Component Identification: Listed in Table 1 Material: Type 316 or Type 304 Austenitic Stainless Steel (as listed in Table 1) with Stainless Steel weld filler metal. The subject welds contain no Alloy 600/82/182 material.

2. Applicable Code Addition and Addenda ASME Section XI 2004 Edition, No Addenda

3. Applicable Code Requirement

ASME Section XI, Examination Category C-F-1 requires 100 percent (%) volumetric examination coverage for circumferential piping welds. The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory Guide 1.14 7, Revision 18, allow credit for essentially 100% coverage of a weld provided greater than 90% of the required volume has been examined. 10 CFR 50.55a(b)(2)(xv)(A) requires the following examination coverage criteria when applying Supplement 2 (Qualification Requirements for Wrought Austenitic

Serial No. 19-403 Docket No. 50-423, Page 2 of 22 Piping Welds) to Section XI Mandatory Appendix VIII (Performance Demonstration for Ultrasonic Examination Systems): (1) Piping must be examined in two axial directions and when examination in the circumferential direction is required, the circumferential examination must be performed in two directions, provided access is available. (2) Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. 10 CFR 50.55a(b)(2)(xvi)(B) requires that examinations performed from one side of a ferritic or stainless steel pipe weld must be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single side examinations. To demonstrate equivalency to two-sided examinations, the demonstration must be performed to the requirements of Appendix VIII, as modified by this paragraph and §50.55a(b )(2)(xv)(A).

4. Impracticality of Compliance

Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100% volumetric examination coverage requirement for austenitic piping welds with single side access. The subject welds were examined with a manual ultrasonic technique utilizing personnel, equipment and procedures qualified in accordance with ASME Section XI, Appendix VIII, as implemented by the Performance Demonstration Initiative (POI). There are currently no POI-qualified single side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to U.S. nuclear applications. POI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single side examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single side qualification to demonstrate that the examiners qualification and the subsequent weld examination is based on application of the best available technology. When the examination area is limited to one side of an austenitic weld, examination coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A) and proficiency

Serial No. 19-403 Docket No. 50-423, Page 3 of 22 demonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B) and full coverage credit may not be claimed. The subject welds consist of configurations in which one side of the weld has a tapered surface within close proximity of the weld, which limit the ability to scan from that side. The ASME code-required volume of these welds was interrogated ultrasonically to the maximum extent possible. No alternative methods or advanced technologies, including the use of phased array, were considered capable of obtaining complete coverage of the examination volume. Based on the configuration limited to single-sided access, relief is requested from complying with the essentially 100% required examination coverage for the following piping welds listed in Table 1. Note that the examination coverage listed is that which was obtained during examination with no credit taken for the far side of each weld in which examination from that side could not be performed. Supplemental scanning was performed to provide additional best effort (non-code) coverage, as documented on the enclosed coverage calculation for each weld. Coverage calculations are provided in this attachment.

CHS-507-10-SW-I C5.21 11 CHS-507-FW-19 C5.21 QSS-3-4-SW-K C5.11 Tablet ExaminiiiC>tl Category C..;f-:1.;J,Velds witij limited Volumetric Cgvetage System Configuration Material Chemical and Volume Control 4" Elbow-To-Tee Type 316 Stainless Steel, Schedule 160 Chemical And Volume Control 4" Pipe-To-Valve Type 316 Stainless Steel, Schedule 160 Quench Spray 12" Pipe-To-Flange Type 304 Stainless Steel, Schedule 405 Examjnatio.n*Angle and Wave Mode 45° Shear Wave 60° Shear Wave 70° Shear Wave 60° Longitudinal Wave 45° Shear Wave 70° Shear Wave 60° Longitudinal Wave 45° Shear Wave 60° Shear Wave 70° Shear Wave Limited examination performed on the downstream side due to obstruction from the branch of the tee, and on upstream side due to the curvature of the elbow inside radius which limits contact in this area. No recordable indications were detected. Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable indications were detected. Limited examination performed from the pipe side only due to the taper of the flange within close proximity of the weld. No recordable indications were detected. Serial No. 19-403 Docket No. 50-423, Page 4 of 22 82% 50% 50% Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected. Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected. Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected.

QSS-3-FW-5B R I C5.ll I Quench Spray I 450 Shear Wave 70° Shear Wave 12" Pipe-To-Flange I Type 304 Stainless I Steel, Schedule 40S RHS-6-2-SW-K I C5.11 I Residual Heat 1 450 Shear Wave Removal 70° Shear Wave 14" Pipe-To-Flange I Type 304 Stainless I Steel, Schedule 40 RHS-6-FW-4 I C5.11 I Residual Heat 1 450 Shear Wave Removal 70° Shear Wave 14" Pipe-To-Pump I Type 304 Stainless I Steel, Schedule 40 Tablel I limited examination performed from the pipe side only due to the taper from the flange within close I proximity of the weld. Additionally limited on the pipe side due to a permanently welded support in the examination area. No recordable indications were detected. I Limited examination performed from the pipe side only due to the taper of the flange within close I proximity of the weld. I No recordable indications were detected. I Limited examination performed from the pipe side only due to the taper of the pump inlet nozzle I within close proximity of the weld. I No recordable indications were detected. Serial No. 19-403 Docket No. 50-423, Page 5 of 22 Surface Examinatioti'Results 8overage\\'YoJ 35.5% Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected. 50% Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected. 50% Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected.

RSS-11-2-SW-B C5.11 RSS-15-3-SW-B C5.11 SIH-4-3-SW-B C5.21 Sy_tem Corifiguratio'n Material I Recirculation Spray 16" Elbow-to-Flange Type 304 Stainless Steel, Schedule 40S Recirculation Spray 12" Pipe-To-Valve Type 304 Stainless Steel, Schedule 40 Safety Injection 4" Pipe-To-Flange Type 316 Stainless Steel, Schedule 160 Tablel ExaminationA`gle ahd Wave Mode 45° Shear Wave 60° Shear Wave 70° Shear Wave 45° Shear Wave 60° Shear Wave 70° Shear Wave 70° 45° Shear Wave 60° Shear Wave 70° Shear Wave 60° Longitudinal Wave Limited examination performed from the pipe side only due to the taper of the flange within close proximity of the weld. Indications were detected that were evaluated as acceptable root geometry. Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable indications were detected. Limited examination performed from the pipe side only due to the taper of the flange within close proximity of the weld. No recordable indications were detected Serial No. 19-403 Docket No. 50-423, Page 6 of 22 ultrasonic Examinaticfo Cdvarage:]%) 50% 50% 50% Surface Ex'amlnatio'n Results Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected. Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected. Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected.

SIL-9-FW-1 C5.11 SIL-9-FW-3 C5.ll SIL-40-FW-1 C5.ll System Configuration Material Safety Injection 6" Pipe-To-Valve Type 316 Stainless Steel, Schedule 160 Safety Injection 6" Pipe-To-Valve Type 316 Stainless Steel, Schedule 160 Safety Injection 6" Pipe-To-Valve Type 316 Stainless Steel, Schedule 160 Table*l 45° Shear Wave 60° Shear Wave 60° Longitudinal Wave 45° Shear Wave 60° Shear Wave 60° Longitudinal Wave 45° Shear Wave 60° Shear Wave 60° Longitudinal Wave Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable indications were detected. Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable indications were detected. Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable indications were detected. Serial No. 19-403 Docket No. 50-423, Page 7 of 22 :itr, .g9 . Examination Cove@ge(%) 50% 50% 50% surface Examination,Results Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected. Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected. Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected.

SIL-11-FW-3 CS.11

System ConfigUration Material,.

Safety Injection I 45° Shear Wave 8" Pipe-To-Valve Type 316 Stainless Steel, Schedule 160 60° Shear Wave Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable indications were detected. Serial No. 19-403 Docket No. 50-423, Page 8 of 22 50% Liquid penetrant examination performed obtaining 100% coverage. No recordable indications detected.

5. Burden Caused by Compliance

Serial No. 19-403 Docket No. 50-423, Page 9 of 22 Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow examination from both sides of the weld. DENC considers these options to meet the 100% Code examination requirement for coverage to be impractical based on the cost, increased radiation exposure and impact to plant equipment.

6. Proposed Alternative and Basis for Use

The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques, as qualified through the POI for Supplement 2, with demonstrated best effort for single-sided examination from the accessible side of the weld. Additionally, a surface examination was performed with 100% coverage obtained. Also, these components are monitored for through-wall leakage as part of the ASME Section XI System Pressure Test Program and receive a visual (VT-2) examination each inspection period during the system leakage tests as required by Section XI, Table IWC-2500-1, Category C-H for Class 2 components. Based on the volumetric coverage that was obtained with acceptable results, a surface examination obtaining 100% coverage, and the visual (VT-2) examination performed each inspection period, it is reasonable to conclude that service-induced degradation would be detected. Therefore, this proposed alternative will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Period for Which Relief is Requested The relief is requested for examinations performed during the third ten-year inspection interval for MPS3, which began on April 23, 2009 and ended on June 22, 2019 (extended from April 22, 2019 in ML19100A126).

8. Precedent A similar relief request was approved for use at MPS3 during the first inspection period of the third 10-year ISi interval (i.e., Relief Request IR-3-22 (ADAMS Accession No. ML16136A001 )).

Serial No. 19-403 Docket No. 50-423, Page 10 of 22 Elb .5811 .5811 Flow---1111..,..,_ .58 11 .6611.78 11.67" .65" .6711 .73 11 w Elbow side best effort coverage with 60°RL x .0665"sq/.1477"slF 45% of elbow side limited area y Tee side best effort covernge wi01 60°RL z.0344"sq/.15 l 4 "sq=23% of tee side limited area Tee Note: Upstream scan limitation due to elbow intradose from 13.75" to 1.25"=2.45" limitation Downstream scan limitation due to tee configuration from 9.75" to 12.75"=3"limitation Examination Volume Dimensions: length 14.95" X Width 1.40" X Height .22" Weld Thickness=.7P/' Weld Length= 14.95" Weld Width= .90" Coverage Summary-Weld # CHS-507-10-SW-11 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Circ. 45/60/70 84% 84% 80% 80% 60RL far side 7.2% Best Effort n/a 4.6% Best Effort n/a Code Coverage Total 82% 84+84+80+80=328/4=82% Best Effort Coverage (Max 25%) Total 3% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Flow .52" .52" Pipe Required Examination Volume-.16 Sq. Inches (1.00*.16 = 0.16 Sq. Inches) Far Side Required Examination Volume - 0.08Sq. lnches (.50*.16 =.08 Sq. Inches) Volume Examined on for side -.04 Sq. Inches (50%) (Best Effort) .54".60" Serial No. 19-403 Docket No. 50-423, Page 11 of 22 Valve (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 14.75" x Width 1.00" X Height .18" Weld Thickness= .6011 Weld Length= 14.75" Weld Width= .SO" Coverage Summary-Weld# CHS-507-FW-19 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Clrc. 45/70 100% 100% 0% 0% 60Rl 50% ( Best Effort) Code Coverage Total 50% 0+0+100+100=200/4=50% Best Effort Coverage (Max 25%) Total 12.5% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2.

Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No. 19-403 Docket No. 50-423, Page 12 of 22 .40".40".40".40" .40" .40" Flow '=" .44" Flange g Required Examination Volume-.17 Sq. Inches (l.28*.128 =0.16 Sq. Inches) h Far Side Required Examination Volume - 0.08Sq. Inches (.64*.128 =.08 Sq. Inches) i Volume Examined on far side -.06 Sq. Inches (75%) (Best Effort) (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 37.7511 x Width 1.28" X Height .128" Weld Thickness= .44" Weld Length= 37.75" Weld Width= .78" Coverage Summary-Weld# QSS-3-4-SW-K Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Circ. 45 100% 100% 0% 0% 70 75% ( Best Effort) Code Coverage Total 50% 100+100+0+0=200/4=50% Best Effort Coverage (Max 25%) Total 18.75 % Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2.

Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Flow '--> .40".44".39".38" .38" Serial No. 19-403 Docket No. 50-423, Page 13 of 22 .38" .38" /; --",e /<-,- 0 -,z-----.J 4 so _______ P_ip_e_ t Required Examination Volume-.16 Sq. Inches (l.28*.128 = 0.16 Sq. Inches) Far Side Required Examination Volume - 0.08Sq. Inches (.64*.128 =.08 Sq. Inches) Volume Examined on far side -.08 Sq. Inches ( l00%) (Best Effort) Examination Limited on Pipe side due to welded supports from 38.1 "-2.9" and 17.2"-23.0". (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 4111 X Width 1.2811 X Height .12811 Weld Thickness= .44" Weld Length= 29.411 Weld Width= .78" Coverage Summary-Weld# QSS-3-FW-5-BR Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Circ. 45 0% 0% 71% 71% 70 100% ( Best Effort) ,,., JIJ./ J/J.J/Jc)O Code Coverage Total 35.5% 0+0+71+71=!)>6/4=.5% Best Effort Coverage (Max 25%) Total 25% Notes: 1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No. 19-403 Docket No. 50-423, Page 14 of 22 .46".46".46".46" .46" .46" Flow ':::::-,, .47".45" 45° Pipe Flange m Required Examination Volume-.20 Sq. Inches (l.28*.15 = 0.19 Sq. Inches) n Far Side Required Examination Volume - 0.09Sq. Inches (.64*.15 =.09 Sq. Inches) ' Volume Examined on far side -.09 Sq. Inches (!00%) (Best Effott) (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 14.0" x Width 1.28" X Height .15" Weld Thickness= .47" Weld Length= 14.0" Weld Width= .78" Coverage Summary-Weld# RHS-6*2-SW-K Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Circ. 45 100% 100% 0% 0% 70 100% ( Best Effort) Code Coverage Total 50% 100+100+0+0=200/4=50% Best Effort Coverage (Max 25%) Total 25% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2.

Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

.48" .48" .48" 45° Pipe Flow .43".51".64". 79" Serial No. 19-403 Docket No. 50-423, Page 15 of 22 Pump s Required Examination Volume-.J 9 Sq. Inches (1.28*.15 = 0.19 Sq. Inches) ' Far Side Required Examination Volume - 0.09Sq. Inches (.64*.15 =.09 Sq. Inches) l§s8888X] Volume Examined on farside-.09 Sq. Inches (100%) (Best Effort) (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 44.0" x Width 1.28" X Height .15" Weld Thickness= .41" Weld Length= 44.0" Weld Width=.78" Coverage Summary-Weld# RHS-6-FW-4 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Clrc. 45 100% 100% 0% 0% 70 100% ( Best Effort) Code Coverage Total 50% 100+100+0+0=200/4=50% Best Effort Coverage (Max 25%) Total 25% Notes: 1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively ex*amined with the qualified examination procedure 2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No. 19-403 Docket No. 50-423, Page 16 of 22 Flow .45" Flange Required Examination Volume-.20 Sq. Inches rs tu (l.60*.129 = 0.20 Sq. Inches) Fat Side Required Examination Volume- 0.10 Sq. Inches f/)777 (,80*.125 =. IO Sq. Inches) Volume Examined on far side -.02 Sq. Inches (20%) ...a:::::22 (Best Effort) .38" .38" 45° (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length SO" x Width 1.33" )( Height Weld Thickness= .45" Weld Length= 50" Weld Width= .83" Coverage Summary-Weld# RSS-11-2-SW-B .38" .38".38" Elbow .125" Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Circ. 45/60/70 0% 0% 100% 100% 70 20% ( Best Effort) Code Coverage Total 50% 0+0+100+100=200/4=50% Best Effort Coverage (Max 25%) Total 4% Notes: 1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No. 19-403 Docket No. 50-423, Page 17 of 22 Flow .39" .40" .4011 .40" .4011 .41 II Valve Required Examination Volume-.138 Sq. [nches KX8XXXXXXXXj (l.07*.129 = 0.138 Sq. Inches) Far Side Required Examination Volume - 0.07 Sq. Inchesl (.55*.129 =.07 Sq. Inches) Volume Examined on far side -.04 Sq. Inches (57%) } (Best Effo11) (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 37.70" x Width 1.07" X Height Weld Thickness= .55" Weld Length= 37.70" Weld Width=.57" Coverage Summary-Weld# RSS-15-3-SW-B Pipe .129" Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Clrc. Downstream Axial Downstream Circ. 45/60/70 0% 0% 100% 100% 70 57% { Best Effort) Code Coverage Total 50% 0+0+100+100=200/4=50% Best Effort Coverage (Max 25%) Total 14.2% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

.71".6211 .6611 .53" .5311 Serial No. 19-403 Docket No. 50-423, Page 18 of 22 .53 11 70° 60°L 45° FLANGE =:i_...._Z , ---PIP_. _E _____ _ FLOW Far side required exam volume -.1231" Volume examined on far side -.0132 .0132/.1231 = 10.7% (best effo11) Limited area scanned with 60° RL for best effo11 coverage. (Area dimensions determined with TurboCAD 18.1) Examination Volume Dimensions: Length 14.87" x Width 1.211 X Height .22" Weld Thickness= .66" Weld Length= 14.87" Weld Width=.70" Coverage Summary-Weld# SIH-4-3-SW-B Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Circ. 45 ° /70 ° 0% 0% 100% 100% 60 °RL 10.7% {best effort) 10.7% Code Coverage Total 50% 0+0+100+100=200/4=50% Best Effort Coverage (Max 25%) Total 2.6% Notes: 1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

.66011 .660" Pipe Flow .652".597" .598" .800" .950" Required Examination Volume-.34 Sq. Inches

. (I.50*.23 = 0.34 Sq. Inches) Far Side Required Examination Volume-0.17 Sq. Inches (.75*.23 =.17 Sq. Inches)

Volume Examined on far side-.02 Sq. Inches (12%)

(Best Effort) Serial No. 19-403 Docket No. 50-423, Page 19 of 22 Valve (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 20.625" x Width 1.50" )( Height .23" Weld Thickness= .80" Weld Length= 20.625" Weld Width= 1.00 Coverage Summary-Weld# SIL-9-FW-1 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Clrc. 45/60 100% 100% 0% 0% 70 12% {Best Effort) Code Coverage Total 50% 100+100+0+0=200/4=50% Best Effort Coverage (Max 25%) Total 3% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2.

Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

.7l011 .700" .700".710" .850111 Pipe Serial No. 19-403 Docket No. 50-423, Page 20 of 22 Valve Required Examination Volume-.34 Sq. Inches (l.50*.. 23 = 0.34 Sq. Inches) Far Side Required Examination Volume - 0.17 Sq. Inches (.75*.23 =.17 Sq. Inches) Volume Examined on far side -.16 Sq. Inches (94%) (Best Effort) (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 20.625" x Width 1.50" X Height Weld Thickness= .85" Weld Length= 20.625" Weld Width= 1.0011 Coverage Summary-Weld# SIL-9-FW-3 .23" Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Circ. 45/60 100% 100% 0% 0% 60Rl 94% ( Best Effort) Code Coverage Total 50% 100+100+0+0=200/4=50% Best Effort Coverage (Max 25%) Total 23.5% Notes: 1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No. 19-403 Docket No. 50-423, Page 21 of 22 1.08".8411.68" FLOW'>, Far side required exam volume - 0.1834"O Volume examined on far side - 0.0894"P 0.0894 / 0.1834 = 48. 7% (best effort) .72" .66" 45° Limited area scanned with 60° RL for best effort coverage. (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 18.7" X Width 1.3" X Height Weld Thickness= .68" Weld Length= 18.7" Weld Width= .80" Coverage Summary-Weld # SIL-40-FW-1 PIPE .23" Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Clrc. Downstream Axial Downstream Circ. 45 °/60 ° 0% 0% 100% 100% 60 ° Rl 48.7% (best effort) Code Coverage Total 50% 0+0+100+10020014=so% I Best Effort Coverage (Max 25%) Total 12.1% Notes: 1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2.

Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Valve Flow ::::::----,._ Serial No. 19-403 Docket No. 50-423, Page 22 of 22 .85".91".83".81".91".89".90".91".91" 45° Pipe Required Examination Volume*.42 Sq. Inches (1.45*.30 = 0.43 Sq. Inches) Far Side Required Examination Volume - 0.22 Sq. Inches (.725*.30 =.21 Sq. Inches) Volume Examined on far side -.19 Sq. Inches (86%) (Best Effort) (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 25.25" x Width 1.451 X Height .30" Weld Thickness=.91" Weld Length= 25.25" Weld Width= ,9511 Coverage Summary-Weld# SIL-11-FW-3 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Cfrc. Downstream Axial Downstream Circ. 45 0% 0% 100% 100% 70 88% ( Best Effort) Code Coverage Total 50% 100+100+0+0=200/4=50% Best Effort Coverage (Max 25%) Total 22% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2.

Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

ATTACHMENT 5 RELIEF REQUEST IR-3-35 EXAMINATION CATEGORY C-F-2 Serial No. 19-403 Docket No. 50-423 PRESSURE RETAINING WELDS IN CARBON OR LOW ALLOY STEEL PIPING DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC) MILLSTONE POWER STATION UNIT 3 (MPS3)

10 CFR 50.55a Relief Request IR-3-35 Relief Requested Serial No. 19-403 Docket No. 50-423, Page 1 of 14 In Accordance with 10 CFR 50.55a(g)(5)(iii) lnservice Inspection Impracticality

1. ASME Code Components Affected:

ASME Code Class: Examination Category: Item Numbers: Code Class 2 C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping. C5.51, Circumferential Welds: Piping Welds .:::, 3/8 in. (10mm) Nominal Wall Thickness for Piping > NPS 4 (ON 100) C5.61, Circumferential Welds: Piping Welds > 1/5 in. (5mm) Nominal Wall Thickness for Piping .:::, NPS 2 (ON 50) andL NPS 4 (ON 100) Component Identification: Listed in Table 1 Material: SA 106 GR B Carbon Steel (as listed in Table 1)

2. Applicable Code Addition and Addenda ASME Section XI, 2004 Edition, No Addenda

3. Applicable Code Requirement

ASME Section XI, 2004 Edition, Examination Category C-F-2 requires 100 percent (%) volumetric examination coverage for circumferential piping welds. The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory Guide 1.147, Revision 18, allow credit for essentially 100% coverage of a weld provided greater than 90% of the required volume has been examined.

4. Impracticality of Compliance

Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100% volumetric examination coverage requirement of the subject welds due to

Serial No. 19-403 Docket No. 50-423, Page 2 of 14 the geometric configuration which limits the volumetric coverage that can be obtained. The subject welds were examined with a manual ultrasonic technique utilizing personnel, equipment and procedures qualified in accordance with ASME Section XI, Appendix VIII, as implemented by the Performance Demonstration Initiative (POI). The ASME Code-required volume of these welds was interrogated ultrasonically to the maximum extent possible. No alternative techniques or advanced technologies, including the use of phased array, were considered capable of obtaining complete coverage of the examination volume. The subject welds include configurations that consist of either pipe-to-valve or pipe-to-weldolet that limit the circumferential scans on the upstream side. Due to the tapered surface of the valve or weldolet within close proximity of the weld, no circumferential scans could be performed from this upstream side of these welds. Additional limitations were encountered on welds FWA-511-FW-6, FWA-511-FW-8, and FWS-16-FW-30 due to the weld crown configuration which limited the axial scan from the pipe side, further reducing the coverage that could be obtained. Coverage calculations are provided in this attachment.

DTM-28-FW-1 C5.51 FWA-511-FW-6 C5.61 Examincition CatPgory C;.F'."2 Weld. with limited Volumetric Examincitic>n, Coverage System ConfiguQR}ion Material Main Steam 6" Weldolet-To-Pipe SA106 GR B, Schedule 80 Auxiliary Feedwater 4" Pipe-To-Valve SA106GR B, Schedule 80 45° Shear Wave 60° Shear Wave 70° Shear Wave 45° Shear Wave 60° Shear Wave 70° Shear Wave Limited examination performed from the pipe side only due to the taper of the weldolet within close proximity of the weld. No recordable indications were detected. Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. Additional limitation was encountered on the axial scan performed from the pipe side due to weld crown configuration. No recordable indications were detected. Serial No. 19-403 Docket No. 50-423, Page 3 of 14 75% 63.5% Magnetic particle examination performed obtaining 100 percent coverage. No recordable indications detected. Magnetic particle examination performed obtaining 100 percent coverage. No recordable indications detected.

FWA-511-FW-8 C5.61 FWS-15-FW-74 C5.51 Table1 Serial No. 19-403 Docket No. 50-423, Page 4 of 14 Examination Category C-f-,2 Weld with LimitecJVolumetric; Examinatipn *coverage Auxiliary Feedwater 4" Pipe-To-Valve SA106 GR B, Schedule 80 Feedwater 18" Pipe-To-Valve SA106 GR B Schedule 100 45° Shear Wave 60° Shear Wave 70° Shear Wave 45° Shear Wave 60° Shear Wave 70° Shear Wave Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. Additional limitation was encountered on the axial scan performed form the pipe side due to weld crown configuration. Indications were detected that were evaluated as acceptable ID root geometry. Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. Indications were detected that were evaluated as acceptable ID root geometry.

*. min:!,!e

HoveragI;':(%) 69% 75% Magnetic particle examination performed obtaining 100 percent coverage. No recordable indications detected. Magnetic particle examination performed obtaining 100 percent coverage. No recordable indications detected.

FWS-16-FW-30 I C5.51 I Feedwater I 45° Shear Wave 60° Shear Wave 6" Valve-To-Pipe I 700 Shear Wave SA106 GR B Schedule I 80 MSS-31-FW-2 I C5.51 I Main Steam I 45° Shear Wave 60° Shear Wave 8" Pipe-To-Valve I 700 Shear Wave SA106 GR B Schedule I 100 Tablel Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. Additional limitation was encountered on the axial scan performed form the pipe side due to weld crown configuration. Indications were detected that were evaluated as acceptable ID root geometry. Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. Indications were detected that were evaluated as acceptable ID root geometry. Serial No. 19-403 Docket No. 50-423, Page 5 of 14 68.25% Magnetic particle examination performed obtaining 100 percent coverage. No recordable indications detected. 75% Magnetic particle examination performed obtaining 100 percent coverage. No recordable indications detected.

MSS-31-FW-3 CS.51 Main Steam 8" Valve-To-Pipe SA106 GR B Schedule 100 45° Shear Wave 60° Shear Wave 70° Shear Wave Tablel Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. Indications were detected that were evaluated as acceptable ID root geometry. Serial No. 19-403 Docket No. 50-423, Page 6 of 14 Exarriinatiol1 C<>vagCJ%) 75% Magnetic particle examination performed obtaining 100 percent coverage. No recordable indications detected.

5. Burden Caused by Compliance

Serial No. 19-403 Docket No. 50-423, Page 7 of 14 Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow examination from both sides of the weld. DENC considers these options to meet the 100% Code examination requirement for coverage to be impractical based on cost, increased radiation exposure, and impact to plant equipment.

6. Proposed Alternative and Basis for Use

The subject welds received a volumetric examination to the maximum extent practical on the accessible portions of the weld utilizing the best available techniques. Additionally, a surface examination was performed with 100% coverage obtained. Also, these components are monitored for through-wall leakage as part of the ASME Section XI System Pressure Test Program and receive a visual (VT-2) examination each inspection period during the system leakage tests, as required by Section XI, Table IWC-2500-1, Category C-H for Class 2 components. Based upon the volumetric examination coverage that was obtained with acceptable results, the surface examination obtaining 100% coverage with acceptable results, and the visual (VT-2) examination performed each period, it is reasonable to conclude that service-induced degradation would be detected. Therefore, this proposed alternative will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Duration of Proposed Alternative

The relief is requested for the third ten-year inspection interval for MPS3, which began on April 23, 2009 and ended on June 22, 2019 (extended from April 22, 2019 in ML19100A126).

8. Precedent A similar relief request was approved for use at MPS3 during the first inspection period of the third 10-year ISi interval (i.e., Relief Request IR-3-23 (ADAMS Accession No. ML16136A001 )).

Serial No. 19-403 Docket No. 50-423, Page 8 of 14 .645".463".412".423".426tt 45° Weldolet Pipe Required Examination Volume (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 21.75" X Width 1.80" X Height .14" Weld Thickness=.65" Weld Length= 21.75" Weld Width=.8011 Coverage Summary-Weld # DTM... 28-FW-1 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Circ. 45/60/70 100% 0% 100% 100% Code Coverage Total 75% 100+0+10o+100=300/4=75 Best Effort Coverage (Max 25%) Total Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

Serial No. 19-403 Docket No. 50-423, Page 9 of 14 45° 70°

.------7

P ipe-

\\:s;k Flow [>_ ar side required exam volume .0545" Volume axially examined far side 0.0295" 7 0.0295/0.0545 = 54.1 % Far ( downstream) side exam volume limited due to valve. (Area dimensions determined with TurboCad 19) Examination Volume Dimensions: Length 14" X Width 1.2 X Height .108" Weld Thickness= .440" Weld Length= 14" Weld Width= 0.7" Coverage Summary-Weld# FWA-511-FW-6 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream7Axial Upstream-Circ. Downstream Axial Downstream Circ. 45/70 100% 100% 54.1% 0% 'Jw{'/,I fl/ I P?faoJ'i) Code Coverage Total 63.5% 100+100+54.1+0/4-=63.5% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

Pipe Valve Flow b-, Serial No. 19-403 Docket No. 50-423, Page 10 of 14 <Far side required exam volume 0.0556" =>?Volume axially examined far side- 0.0424" @ 0.0424 / 0.0556 = 162% Far (downstream) side exam volume limited due to valve. (Area dimensions determined with TurboCad 19) Examination Volume Dimensions: Length 14" X Width 1.2" X Height .115" Weld Thickness=.4421 Weld Length= 14" Weld Width= 0.111 Coverage Summary-Weld# FWA-511-fw.. s Required Scans.. each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Clrc. Downstream Axial Downstream Circ. 45/70 100% 100% 76.2% 0% Code Coverage Total 69% 100+100+76.2+0=276.2/4*=69% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

Pipe Flow 1.04" 1.04" 1.20H Serial No. 19-403 Docket No. 50-423, Page 11 of 14 NR NR Valve (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 57.5" x Width 2.56" X Height .38" Weld Thickness= 1.20" Weld Length= 57.511 Weld Width= 1.56" Coverage Summary-Weld# FWS-15-FW-74 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Circ. 45/60/70 100% 100% 100% 0% Code Coverage Total 75% 100+100+100t0=300/4=75 Best Effort Coverage (Max 25%} Total Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

Valve

V32

.62".58".5811.4211 Serial No. 19-403 Docket No. 50-423, Page 12 of 14 Pipe Flow I':'> RequiredExmVolue _ 11 0.1999sq./m.(1.65.14-.231) Far Side Required Exam Volum = 0.082511 (offset root.682*.14 =.095")7 Volume Examined Far Side = 0,060211.....- m -..--r--r-. Far (upstream) side exam volume limited due to valve. (Area dimensions determined with TurboCad 19) Examination Volume Dimensions: Length 20.9" x Width 1.65" X Height .14" Weld Thickness= .5811 Weld Length= 20.9" Weld Width= 0.65" (US-73%+0S-100%+CW-50%+CCW-50%)/4=68.25% Coverage Summary-Weld# FWS-16-FW-30 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Clrc. Downstream Axial Downstream Circ. 45/70 73% 0% 100% 100% Code Coverage Total 68.25% 73+0+100+100=273/4-=68.25% Best Effort Coverage (Max 25%) Total N/A Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2.

Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Pipe .620" Flow------.. .620" .619".615" .850" Serial No. 19-403 Docket No. 50-423, Page 13 of 14 Valve (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 27.37511 x Width 1.9011 X Height .198" Weld Thickness:::.850" Weld Length= 27.37S" Weld Width=.90" Coverage Summary-Weld # MSS-31-FW-2 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream Axial Downstream Circ. 45 100% 100% 100% 0% Code Coverage Total 75% 100+100+100+0=300/4=75 Best Effort Coverage (Max 25%} Total Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

Examination Volume Dimensions: Length 27.7' Weld Thickness= .77" Weld Length= 27.7' Flow-----*-- X Width Weld Width= 1.9 Serial No. 19-403 Docket No. 50-423, Page 14 of 14 X Height .23" .90 Coverage Summary-Weld# I\\JISS..31-FW-3 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-arc. Dov.nistream Axial Dov,mstream arc. 45/fJJ/70 100% 0% 100% 100% Code Coverage Total 75% lOOt-O+ lOOf.100=300/4=100% Best Effort Coverage (Max 25%) Total n/a Notes:

1. Code Coverage refers to the maxim.am percentage of the required examination volume that is effectively examined with the qualified examination procedure

ATTACHMENT 6 RELIEF REQUEST IR-3-36 EXAMINATION CATEGORY R-A RISK-INFORMED PIPING EXAMINATIONS Serial No. 19-403 Docket No. 50-423 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC) MILLSTONE POWER STATION UNIT 3 (MPS3)

Serial No. 19-403 Docket No. 50-423, Page 1 of 22 1 O CFR 50.55a Request Number: IR-3-36 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii) In-service Inspection Impracticality

1. ASME Code Components Affected:

ASME Code Class: Code Class 1 Examination Category: R-A, Risk Informed Piping Examinations Item Numbers: R1.11, Elements Subject to Thermal Fatigue R1.20, Elements Not Subject to a Damage Mechanism Component Identification: Listed in Table 1 Material: Type 304 or 316 Austenitic Stainless Steel (as shown in Table 1) with Stainless Steel weld filler metal. The subject welds contain no Alloy 600/82/182 material.

2. Applicable Code Addition and Addenda ASME Section XI, 2004 Edition, No Addenda

3. Applicable Code Requirement

The examination requirements for Class 1 piping welds are governed by the Risk Informed In-service Inspection program that was approved by the NRC in a letter dated March 24, 2011 (Adams Accession Number ML110680080). The program was developed in accordance with WCAP-14572, Revision 1-NP-A (Westinghouse Owners Group Application of Risk-Informed Methods to Piping lnservice Inspection Topical Report). Examination Category R-A, requires that essentially 100 percent (%) of the weld volume be examined. The alternative requirements of ASME Code Case N-460, approved for use in Regulatory Guide 1.14 7, Revision 18, allow credit for essentially 100% coverage provided greater than 90% of the required volume has been examined. 10 CFR 50.55a(b)(2)(xv)(A), requires the following examination coverage criteria when applying Supplement 2 (Qualification Requirements for Wrought Austenitic

Serial No. 19-403 Docket No. 50-423, Page 2 of 22 Piping Welds) to Appendix VIII (Performance Demonstration for Ultrasonic Examination Systems): (1) Piping must be examined in two axial directions and when examination in the circumferential direction is required, the circumferential examination must be performed in two directions, provided access is available. (2) Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. 10 CFR 50.55a(b)(2)(xvi)(B), requires that examinations performed from one side of a ferritic or stainless steel pipe weld must be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single side examinations. To demonstrate equivalency to two-sided examinations, the demonstration must be performed to the requirements of Appendix VIII as modified by this paragraph and §50.55a(b)(2)(xv)(A).

4. Impracticality of Compliance

Pursuant to 1 O CFR 50.55a(g)(5)(iii), relief is requested from the 100% volumetric examination coverage requirement for the subject austenitic welds due to the geometric configuration which limits the volumetric coverage that can be obtained. The subject welds were examined with a manual ultrasonic technique utilizing personnel, equipment and procedures qualified in accordance with ASME Section XI, Appendix VIII as implemented by the Performance Demonstration Initiative (POI). There are currently no POI-qualified single side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to U. S. nuclear applications. POI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single side examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single side qualification to demonstrate that the examiner's qualification and the subsequent weld examination is based on application of the best available technology.

Serial No. 19-403 Docket No. 50-423, Page 3 of 22 When the examination area is limited to one side of an austenitic weld, examination coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A) and proficiency demonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B) and full coverage credit may not be claimed. The ASME code-required volume of these welds was interrogated ultrasonically to the maximum extent possible. No alternative methods or advanced technologies, including the use of phased array, were considered capable of obtaining complete coverage of the examination volume. The subject welds consist of a pipe-to-valve, pipe-to-reducer or pipe-to-flange configuration in which the tapered surface of the valve, reducer or flange, within close proximity of the weld limit the ability to scan from that side of the weld. There are no welds in this request that are within the scope of the Electric Power Research Institute (EPRI) document MRP-146 (Management of Thermal Fatigue in Normally Stagnant Non-lsolable Reactor Coolant System Branch Lines) requirements. Based on the configuration limited to single-sided access, relief is requested from complying with the 100% required examination coverage for the piping welds listed in Table 1. Note that examination coverage listed in Table 1 is that which was obtained during examination with no credit taken for the far side of each weld. Supplemental scanning was performed to provide additional best effort (non code) coverage as documented on the enclosed coverage calculation for each weld. Coverage calculations are provided in this attachment.

3-CHS-150-PlB-2 Rl.20 407022-FW-5 Rl.20 408043-FW-6-1 Rl.20 Syst#m? Code.$lass C9rJfiguration Material Tabl.e.1 Chemical and Volume 145° Shear Wave Control/ Class 1 60° Shear Wave 70° Shear Wave 1.5" Pipe-to-Flange Type 316 Stainless Steel, Schedule 160 Safety Injection/ Class 1 I 45° 60° 1.5" Pipe-to-Valve 70° Type 316 Stainless Steel, Schedule 160 Safety Injection/ Class 1 I 45° 60° 1.5" Pipe-To-Valve 70° Type 316 Stainless Steel, Schedule 160 Shear Wave Shear Wave Shear Wave Shear Wave Shear Wave Shear Wave Serial No. 19-403 Docket No. 50-423, Page 4 of 22 Limited examination performed from the pipe side only due to the taper of the flange within close proximity of the weld. No recordable indications were detected. Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable detected. indications were Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable detected. indications were 50% 50% 50%

408044-FW-5 I Rl.20 408045-FW-5 I Rl.20 408046-FW-4 I Rl.20 Table 1 Serial No. 19-403 Docket No. 50-423, Page 5 of 22 Examination Categhry 5;AWel6s with limited Volumetric Coverage' I Safety Injection/ Class 1 45° Shear Wave Limited examination performed from the I 50% 60° Shear Wave pipe side only due to the taper of the 1.5" Pipe-To-Valve 70° Shear Wave valve being within close proximity of the Type 316 Stainless I weld. Steel, Schedule 160 No recordable indications were detected. I Safety Injection/ Class 1 45° Shear Wave Limited examination performed from the I 50% 60° Shear Wave pipe side only due to the taper of the 1.5" Pipe-to-Valve 70° Shear Wave valve being within close proximity of the Type 316 Stainless I weld. Steel, Schedule 160 No recordable indications were detected. I Safety Injection/ Class 1 45° Shear Wave Limited examination performed from the I 50% 60° Shear Wave pipe side only due to the taper of the 1.5" Pipe-to-Valve 70° Shear Wave valve being within close proximity of the Type 316 Stainless I weld. Steel, Schedule 160 No recordable indications were detected.

RCS-10-FW-23 Rl.20 RCS-15-FW-33 Rl.20 RCS-150-FW-2 Rl.11 Tablel S,ybtern/1'¢od.c/(:las.s C:onfiglJratidn Material Exdminatie1n'fggle and Wave Mode Reactor Coolant / Class 145° 1 60° 70° 1.5" Pipe-To-Reducer Type 316 Stainless Steel, Schedule 160 Reactor Coolant / Class 45° 1 60° 70° 1.5" Pipe-To-Reducer Type 316 Stainless Steel, Schedule 160 Reactor Coolant / Class 45° 1 60° 70° 2" Pipe-To-Valve Type 316 Stainless Steel, Schedule 160 Shear Wave Shear Wave Shear Wave Shear Wave Shear Wave Shear Wave Shear Wave Shear Wave Shear Wave Serial No. 19-403 Docket No. 50-423, Page 6 of 22 Limitationiahd.Resulth Limited examination performed from the pipe side only due to the taper of the reducer within close proximity of the weld. No recordable indications were detected. Limited examination performed from the pipe side only due to the taper of the reducer within close proximity of the weld._ No recordable detected. indications were Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable detected. indications were .. fiaminati.on Coverage {%) 50% 50% 50%

Sy$t.n, f C()af Class Configuration Materhd RCS-504C-FW-4 Rl.11 Reactor Coolant / Class 1 8" Pipe-To-Valve Type 304 Stainless Steel, Schedule 160 RCS-513-FW-25 Rl.11 Reactor Coolant / Class 1 3" Pipe-To-Valve Type 316 Stainless Steel, Schedule 160 RCS-513-FW-29 Rl.11 Reactor Coolant / Class 1 3" Pipe-To-Valve Type 316 Stainless Steel, Schedule 160 Table*! E>eaminatiqnAngle and* WaveMode 45° Shear Wave 60° Longitudinal Wave 45° Shear Wave 60° Shear Wave 70° Shear Wave 45° Shear Wave 60° Shear Wave 70° Shear Wave Serial No. 19-403 Docket No. 50-423, Page 7 of 22 Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable indications were detected. Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable indications were detected. Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable indications were detected. Examination Coverage (%) 50% 50% 50%

RCS-LP3-FW-27 Rl.11 tablel Serial No. 19-403 Docket No. 50-423, Page 8 of 22 Ec:1mintion CategoryH-A Vtllds "Y,*thlimited Volumetric'1e>verge ,Sysfe:mv Cod~, Class C<>p,fig?,ration Material Exam i9tiori\\; f\\ngl,Efand WaveMode Reactor Coolant / Class 145° 1 60° Shear Wave Shear Wave 6" Pipe-To-Valve 60° Longitudinal Wave 70° Shear Wave Type 316 Stainless Steel, Schedule 160 Limited examination performed from the pipe side only due to the taper of the valve being within close proximity of the weld. No recordable indications were detected. Examination Ce>yrag :(%} 50%

5. Burden Caused by Compliance

Serial No. 19-403 Docket No. 50-423, Page 9 of 22 Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow full examination from both sides of the weld. DENC considers these options to meet the 100% Code examination requirement for coverage to be impractical based on cost, increased radiation exposure, and impact to plant equipment.

6. Proposed Alternative and Basis for Use

The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques, as qualified through the POI for Supplement 2, with demonstrated best effort for single-sided examination from the accessible side of the weld. Also, these components are monitored for through-wall leakage as part of the ASME Section XI System Pressure Test Program and receive a visual (VT-2) examination at the end of each refueling outage during the system leakage tests, as required by Section XI, Table IWB-2500-1, Category 8-P for Class 1 components. Based on the volumetric coverage that was obtained with acceptable results and the visual (VT-2) examination performed each refueling outage, it is reasonable to conclude that service-induced degradation would be detected. Therefore, this proposed alternative will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Duration of Proposed Alternative

Relief is requested for the third ten-year inspection interval for MPS3, which began on April 23, 2009 and ended on June 22, 2019 (extended from April 22, 2019 in ML19100A126).

8. Precedent A similar relief request was approved for use at MPS3 during the second 10-year ISi interval (i.e., Relief Request IR-2-59 (ADAMS Accession No. ML110691154)).

Serial No. 19-403 Docket No. 50-423, Page 10 of 22 c:::Flow .291 .29".3011 .42" _P_i_p_e _____ -'.;;4s o -, -- 6°;§ 0. -45ange Required Exnminnlion Volume-.14 Sq. Inches rnxRi:6a6N5666666d (l.60.09 = 0.14 Sq. Inches) Par Side Required Exnmino.lioh Volume - 0.07 Sq. Inches &XXXX?QQQv1 (.80*,09 =.07 Sq. lnhes) Volume Exumincd on far side *,06 Sq. Inches (85%) (Best Effo1t) (Area dimensions determined with TurboCAD 19) ExamlnaHon Volume Dimensions: Length 4,711 X Width 1.6011 )( Height .0911 Weld Thickness=,300" Weld Length= 4.7" Weld Width=.60" Coverage Summary-Weld# 3-CHS-150-PlB-2 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial I Upstream-Circ. I Downstream Axial Downstream Clrc. 45/60 100% I 100% I 0% 0% 70 I I 85% (Best Effort) Code Coverage Total SO% 100+1000+0,.200/4:50% I Best Effort Coverage (Max 25%) Total 21.253/4 Notes:

1. Code Coverage refers to the ma Kim um percentl;lge of the required examination volume that Is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerltne that is examined in. the axial beam direction with an Appendix VIII demonstrated procedure for single sided.coverage

.330" .271" .271" Serial No. 19-403 Docket No. 50-423, Page 11 of 22 700 450 450 v,1 .£..-/_; __ _.i,Z:__. _1_P_ip_o ___________ _ /J Flow Examination Volume Dimensions: Length 6,011 >< Width 1,811 ){ Height ,09" Weld Thiclmessc .33011 Weld Length= 6,011 Weld Width= ,8,, (US-l00%+DS-0%+CW-50%+CCW-50%)/4=50% Coverage Summary-Weld# 407022-FW-5 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial I Upstream-Clrc, Downstream Axial Downstream Clrc, 45 100% 100% 0% 0% 70 100% (best effort) Code Coverage Total 50% 100+0+50+50=200/4-=50% Best Effort Coverage (Max 25%) Total 25% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the quallfled examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that ls examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Pipe Flow b-- Serial No. 19-403 Docket No. 50-423, Page 12 of 22 Examination Volume Dimensions: Length 6.011 ll Width 1.S" X Height ,09211 Weld Thickness:::.44511 Weld Length= 6,011 Weld Width= ! (US-100%+0S-0%+CW-S0%+CCW*S0%)/4=50% Coverage Summary-_ Weld# 408043-FW-6-1 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Clrc. Downstream Axial Downstream Clrc. 45 100% 100% 0% 0% 70 100% (best effort) . coc(e Coverage Total 50% 100+100+0+0=20 0/ 4*12503/4 Best Effort Coveri)ge (Max 25%) Total 25% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examined with the quallfled examination procedure

2. Best Effort Coverage refers to the required e>camlnatlon volume past the centerline that Is examined In the axial beam direction with an At)pendix VIII demonstrated procdure for single sided coveragá

Pipe Flow b-. Vulve Serial No. 19-403 Docket No. 50-423, Page 13 of 22 EKamination Volume Dimensions: Length x Width 1.45" X Height .094" Weld Thickness=,330" Weld Length= 11" Weld Width=,45" Coverage Summary-Weld# 408044-FW-5 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axla I Upstream-Clrc, Downstream Axlal Downstream Clrc. 45 ° 100% 100% 0% 0% 70° 100% (Best Effort) Code Coverage Total 50% 100+100+0+0=200/4eSO% Best Effort Coverage (Max 25%) Total 25% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examined with the qualified examination procedure 2.

Best Effort Coverage refers to the required examination volume past the centerline that is examined In the axlal beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Pipe .276".276".278" 45° 45° 70° 1"'(.---1 -1/4..,,......,... I Flow b,, Valve Serial No. 19-403 Docket No. 50-423, Page 14 of 22 Examination Volume Dimensions: Length 6,011 x Width 1.411 X Height ,09211 Weld Thickness::: ,27811 Weld Length= 6,011 Weld Width= .4" (US-100%+DS*0%+CW-50%+CCW-50%)/4=50% Coverage Summary-Weld# 408045-FW-5 Required Scans-each has a weighing factor of 100% for complete coverage Angle U pstream-Axlal Upstream-Clrc. Downstream Axial Downstream Clrc. 45 100% 100% 0% 0% 70 100% Code Coverage Total 50% 100+100+0+0=200/4-::50% Best Effort Coverage (Max 25%) Total 2S% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that Is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

.406".248" .255" Serial No. 19-403 Docket No. 50-423, Page 15 of 22 I r=a \\_,.....,,...'l'f-:*-.4,,_S :_()_-_-_-_-*z-4-J-r ___________ _ /1 Flow Exam[riatlon Volume Dimensions: Length 6,011 x Width 1,Bn X Height .08411 Weld Thickness=.40611 Weld Length= 6.011 Weld Width= £ (US-100%+DS*0%+CW-50%+CCW-S0%)/4=50% Coverage Summary-Weld# 408046--FW-4 Required Scans-each has a weighlng factor of 100% for complete coverage Angle Upstream-Axial Upstream-Circ. Downstream A><lal Downstream Clrc. 45 100% 100% 0% 0% 70 100% (best effort) Code Coverage Total 50% 100+0+50+50=200/4*=50% Best Effort Coverage (Max 25%) Total 25% Notes: 1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2. Best Effort Coverage refers to the required examination volume past the centerline that is examined In the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

.,.,,,,,,- Flow Serial No. 19-403 Docket No. 50-423, Page 16 of 22 ....__......._,_ .34".32" Reducer . r. .29".28"

c.6 '0° 115°: =s-<?=-*

,...,..,..._,...=--'--7.,__ ___ Pipe PQQQQQQQQQQQQQ999l Required Exllminution Volume-.14 Sq. Inches (1.60*.09 = 0.14 Sq. Inches) Fnr Side Required Examinulion Volume* 0.07 Sq. Inches (.Bov.09 =.o7 Sq. Inches) Volume Examined on far side -.05 Sq. Inches (71 %) (Best Effort) (Area dimensions determined with TurboCAD 19) Exami.natlon Volume Dimensions: Length 4.70" K Width

L.60" l{ Height

.0911 Weld Thlclmess= .32" Weld Length= 4.70" Weld Width=.60" Coverage Summary-Weld# RCS-10-FW-2.3 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial I Upstream Circ. I Downstream Axial Downstream Clrc. 45/60 100% I 100% I 0% 0% 70 I I 71% (Best Effort) Cocle coverage Total 50% 100+100+0+0=200/4=50% I Best Effort Coverage (Max 25%) Total 17.75% Notes:

1. Code Coverage refers to the ma){imum percentage of the required examination volume that Is effectively examined with the qualified examination procedure 2.

Best Effo1t Coverage refers to the required examination volume past the centerline that Is e)(amlned In the mdal beam direction with an AppendlH VIII demonstrated procedure for single sided coverage

.Flow,,_ .2W' .29".32".34" Serial No. 19-403 Docket No. 50-423, Page 17 of 22 Required Examination Volume-, I <I Sq. [nches (1.60*.09=0.H Sq. Inches) Pnr Side Required Exnminntion VohnnCl - 0.07 Sq. Inches (,80*.09 =.07 Sq. Inches) Volumll Exmnincd on fo,* side *,05 Sq. lnchc3 (71%) (llest Ef fort) (Area dimensions determined with TurboCAD 19) Eicaminatlon Volume Dimensions: Length 4.70" x Width 1.6011 X Height .09" Weld l'hlclmess= .32" Weld Length= 4.70" Weld Width= .60" Coverage Summary Weld# RCSu15MFW-33 ReqLilrecl Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial I Upstream-Clrc. I Downstream Axial Downstream Circ, 45/60 100% I 100% I 0% 0% 70 I I 71% (Best Effort} Code Coverage Total 50% 1001*100+0+0=2_00/4=50% I Best Effort Coverage (Mm< 25%) Total 17.75% Notes:

1. Code Coverage refers to the mmdrnum percentage of the required examination volume that is effectively examined with the qualified examination procedure 2, Best Effort Coverage refers to the required e><amlnatlon volume past the centerline that Is examined in the metal beam direction with an Appe-ndi>< VIII demonstrated procedure for single sided coverage

Flow VaJve .376" .376" Serial No. 19-403 Docket No. 50-423, Page 18 of 22 .376" Pipe Required Exrunluatlon Volume-.17 Sq. Inches (1.60*.II =0.17Sq, Inches) Fur Side Required Examination Volume* 0.08 Sq, Inches (,80*.1 I-=.08 Sq. Inches) Volume Exnmined on far side -,06 Sq. Inches (75%) (Best Effort) (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length 7.511 x Width 1,60" )( Height .1111 Weld Thickness= ,376" Weld Length= 7,5" Weld Width= .60" Coverage Summary 0 Weld# RCS-lSOFW-2 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial I Upstream* Clrc, I Downstream Axlal Downstream Clrc. 45/60 0% I 0% I 100% 100% 70 75% (Best Effort) I I Code Coverage Total 50% 0+0+100+100=200/4=50% I Best Effort Coverage (Max 2S%) Total 18,75% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examlned with the qualified examination procedure

2. Best Effort Cove1*age refers to the required examination volume past the centerline that is e1camlned in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Flow '>, Serial No. 19-403 Docket No. 50-423, Page 19 of 22 .92".8211 1.0" 1.01" Required Exnmlnal!on Volume*.96 Sq. Inches (3.20*,30= 0,96 Sq. Inches) For Side Required Exnminallon Volume* 0.33 Sq. Inches ³ (I.! *.30 =,33 Sq. Inches) Volume 8xomlncd on far side *,33 Sq. Inches (100%) µ (Best !1ffo11) (Area dimensions determined with TurboCAD 19) Examination Volume Dimensions: Length x Width 3.20" )( Height .30" Weld Thickness= 1.0011 Weld Length= Weld Width= 1.20" Coverage Summary-Weld# RCSN504C-FW-4 Required Scans-each has a weighing factor of 100% for complete coverage Valve Angle Upstream-Axial I Upstream-Clrc. I Downstream Axial Downstream Circ. 45 100% I 100% I 0% 0% 60Rl. I I 100% (Best Effort} Code Coverage Total 50% 100+100+0t0a200/4"S0% I Best Effort Coverage (Mall 25%) Total 25% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerllne that Is examined ht the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No. 19-403 Docket No. 50-423, Page 20 of 22 Flow .438" 438" 438".50011 = _P_i_p_e--- o __ ; I_V Required Examination Volume*.25 Sq. Inches {l.80*.14=0.25 Sq, Inches) Far Slde Required Exnmlnntlon Volume - 0.12 Sq. Inches (.90*,14 "",12 Sq. Inches) Volume Examined on far side -.09 Sq, Inches (75%) Best Effort (Area dimensions determined with Tul'boCAD 19) Examination Volume Dimensions: Length !1£ H Width 1.80 )( Height ,14" Weld Thickness=,50011 Weld Length= 11.0" Weld Width= .8011 Coverage Summary.. Weld# RCS-513-FW-25 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Clrc. Downstream Axial Downstream Clrc. 45/60 0% 0% 100% 100% 70 75% { Best Effort) Code Coverage Total 50% 0+0+100+100=200/11.,S0% Best Effort Coverage (Max 25%) Total 18.75% Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerllne that Is e>eamlned In the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No. 19-403 Docket No. 50-423, Page 21 of 22 Flow .43 Totnl far side volume = O. 122 sq In 3 Best effort fur sid.e volume examined = 0.073 sq in Examlnatlon Volume Dimensions: Length 1111 x Width 1.6611 )( Height ,14611 Weld Thickness=,5311 Weld Length=.!!: Weld Width=.6611 Coverage Summary-Weld ff RCs.. 513.. fW-29 Required Scans-each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream-Clrc, Downstream Axtal Downstream Clrc. 45/60/70 0% 0% 100% 100% 70 far side 603/4 Best effort 0% 0% 0% Code Coverage Total 50% Ot0t100t100*200/4,,,SO% Best Effort Coverage (Max 25%} Total 15% Notes:

1. Code Coverage refers to the max{murn percentage of the required examination volume that Is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination votume past the centerline that Is examined In the axial beam direction with an Appendix vm demonstrated procedure for single sided coverage

Valve Flow---11....,_ .725" Upstream exam volume = 0.306 sq. In. Serial No. 19-403 Docket No. 50-423, Page 22 of 22 Upstl'eatn Best effort exnrn coverage.,. 0.058 sq. in. 0,058/0,306 = 19% Best effotl coverage Note: Exam coverage calcttlnted using TurboCAD 21. Best effort coverage coverage ls estlrnated as complete thickness and contour dntn was not nble to be obtnh1ed 011 upstream side of weld (valve body) due to configuration. Examination Volume Dimensions: Length 21,12511 x Width 2,65" x Height Weld Thlcl<ness= ,92811 Weld Length= 21.12511 Weld Width= 0,9'1 Angle 45/60/70 60RL Notes: Coverage Summary-Weld# RCS-LP3-FW-27 Required Scans-each has a weighing factor of 100% for complete coverage Upstream-Axial I Upstream* Clrc. I Downstream Axial 0% I o3/4 I 100% I l Code Coverage Total 0t0+100+100.. 200/4*503/4 I Best Effort Coverage {Max 25%) Total Downstream Clrc. 100% SO% 4.75%

1. Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that ls examined In the axial beam direction with an Appendbc VIII demonstrated procedure for single sided coverage}}

v t e Letter Sequence Request
EPID:L-2020-LLR-0028, ASME Section XI Inservice Inspection Program Relief Requests for Limited Coverage Examinations Performed in the Second Period of the Third 10-Year Inspection Interval (Approved, Closed) EPID:L-2020-LLR-0027, ASME Section XI Inservice Inspection Program Relief Requests for Limited Coverage Examinations Performed in the Second Period of the Third 10-Year Inspection Interval (Approved, Closed)
Initiation Request, Request, Request Acceptance Administration Questions Answers 27 July 2020 Results Approval Other:
MONTHYEAR2020-07-02 [Table View]

ML20049A088

Text

3. Applicable Code Requirement

4. Impracticality of Compliance

7. Duration of Proposed Alternative

3. Applicable Code Requirement

5. Burden Caused by Compliance

6. Proposed Alternative and Basis for Use

7. Duration of Proposed Alternative

3. Applicable Code Requirement

4. Impracticality of Compliance

5. Burden Caused by Compliance

6. Proposed Alternative and Basis for Use

7. Duration of Proposed Alternative

3. Applicable Code Requirement

4. Impracticality of Compliance

5. Burden Caused by Compliance

6. Proposed Alternative and Basis for Use

3. Applicable Code Requirement

4. Impracticality of Compliance

5. Burden Caused by Compliance

6. Proposed Alternative and Basis for Use

7. Duration of Proposed Alternative

3. Applicable Code Requirement

4. Impracticality of Compliance

5. Burden Caused by Compliance

6. Proposed Alternative and Basis for Use

7. Duration of Proposed Alternative

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