L-23-214, Submittal of Relief Request for Impractical American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI Examination Requirements

Submittal of Relief Request for Impractical American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI Examination Requirements

ML24158A004
Person / Time
Site:	Davis Besse
Issue date:	06/05/2024
From:	Tony Brown Vistra Operations Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-23-214
Download: ML24158A004 (1)

Text

Davis-Besse Nuclear Power Station Terry J. Brown Site Vice President 5501 North State Route 2 Oak Harbor, Ohio 43449

L-23-214 June 5, 2024

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Submittal of Relief Request for Impractical American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI Examination Requirements

In accordance with 10 CFR 50.55a(g)(5)(iii), Vistra Operations Company LLC hereby provides the Nuclear Regulatory Commission with the basis for the determination that the inservice examination, as specified by the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, of the welds listed below have been determined to be impractical. These determinations are based on experience obtained during the Davis-Besse Nuclear Power Station, Unit No. 1 fourth 10-year inservice inspection interval, which began September 21, 2012, and ended on June 7, 2023.

The affected welds are :

RC-RPV-WR-34, Lower Shell to Bottom Head Circumferential Weld.

RC-RPV-WR-35, Bottom Head Circumferential (Disc) Weld.

RC-PZR-WP-15, Pressurizer Nozzle-to-Vessel Weld.

RC-PZR-WP-33-W/X, Pressurizer Nozzle-to-Vessel Weld.

RC-PZR-WP-33-Y/Z, Pressurizer Nozzle-to-Vessel Weld.

RC-PZR-WP-34, Pressurizer Nozzle-to-Vessel Weld.

Information to support the basis for the impracticality determinations is provided in Attachments 1 and 2.

There are no regulatory commitments contained in this submittal. If there are any questions, or if additional information is required, please contact Jack Hicks, Sr Manager, Licensing, at (254) 897-6725 or Jack.Hicks@luminant.com.

5555 SI ERRA DRIV;: 1RV I NG fFXAS 75039 "/ISTRACORP.COM Davis-Besse Nuclear Power Station L 214 Page 2

Attachments:

1. American Society of Mechanical EngineersSection XI 10 CFR 50.55a Request for Relief Number RR-A1, Revision 0

2. Davis-Besse Nuclear Power Station Specific Applicability

cc: NRC Region III Administrator NRC Resident Inspector NRR Project Manager Utility Radiological Safety Board

Attachment 1 L 214

American Society of Mechanical EngineersSection XI 10 CFR 50.55a Request for Relief Number RR-A1, Revision 0 Page 1 of 4

In Accordance with 10 CFR 50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

1. ASME Code Components Affected

The Davis-Besse Nuclear Power Station (DB), Unit 1, Class 1 welds with limited examinations that are included in this request for relief are for the Fourth Ten-Year Inservice Inspection Interval. The content of this request includes the insights gained from guidance provided in NRC presentation Coverage Relief Requests (Reference 1), and applies to the following Code Classes, Examination Categories, and Item Numbers.

Code Class: Class 1 Examination Categories: B-A, and B-D Item Numbers: B1.11, B1.21, and B3.110

2. Applicable Code Edition and Addenda

The applicable ASME Boiler and Pressure Vessel Code of Record (ASME Code) edition and addenda was ASME Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 2007 Edition with the 2008 Addenda, Reference 2, and was used for the Fourth 10- Year Inservice Inspection (ISI) Interval at DB as modified by 10 CFR 50.55a. The Appendix VIII and Performance Demonstration Initiative (PDI),

Reference 3, requirements at DB were in accordance with the 2007 Edition with the 2008 Addenda of Section XI, for the limited examinations contained in this request.

3. Applicable ASME Code Requirements

Exam Cat. Item No. Class 1 Weld Examination Coverage Requirements

B-A B1.11 To include the examination volume of the Reactor Pressure Vessel Shell Welds as depicted in the applicable figure shown in Figure IWB-2500- 1

B-A B1.21 To include the examination volume of the Reactor Pressure Vessel Head Welds as depicted in the applicable figure shown in Figure IWB-2500- 3

B-D B3.110 To include the examination volume of the Pressurizer Nozzle-to-Vessel Welds as depicted in the applicable figure shown in Figures IWB -2500- 7(a),

(b), (c), or (d)

As defined in IWA-2200(c) essentially 100% of the required surface or volume shall be examined. Essentially 100% coverage is achieved when the applicable examination coverage is greater than 90%; however, in no case shall the examination be terminated when greater than 90% coverage is achieved, if additional coverage of the required examination surface or volume is practical.

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Table 1: Exam Categories and Item Numbers applicable to Relief Request RR-A1

Exam Item No. ISI Examination Requirements Category B-A B1.11 Essentially 100% examination of the Lower Shell to Bottom Circumferential Weld (RC-RPV-WR-34)

B-A B1.21 Essentially 100% examination of the Bottom Head Circumferential (Disc) Weld (RC-RPV-WR-35)

B-D B3.110 Essentially 100% examination of four pressurizer nozzle-to-vessel welds (RC-PZR-WP-15, RC-PZR-WP-33-W/X, RC-PZR-WP Y/Z, RC-PZR-WP-34)

4. Reason for Request

10 CFR 50.55a(g)(5)(iii), states: ISI program update: Notification of impractical ISI Code requirements.

If the licensee has determined that conformance with a Code requirement is impractical for its facility the licensee must notify the NRC and submit, as specified in § 50.4, information to support the determinations. Determinations of impracticality in accordance with this section must be based on the demonstrated limitations experienced when attempting to comply with the Code requirements during the inservice inspection interval for which the request is being submitted. Requests for relief made in accordance with this section must be submitted to the NRC no later than 12 months after the expiration of the initial or subsequent 120- month inspection interval for which relief is sought.

This request is based on actual demonstrated limitations experienced when attempting to comply with the code requirements in the performance of the examinations listed in this request.

5. Impracti cality of Compliance

The construction permit for DB Unit 1 was issued on March 24, 1971 and falls under the provisions of 10 CFR 50.55a(g)(2)(i), which were applied to components that are classified as ASME Code Class 1 and 2 and supports for components that are classified as ASME Code Class 1 and 2. Applicable components and supports must be designed and be provided with the access necessary to perform the required preservice and inservice examinations set forth in the code of record in effect 6 months before the date of issuance of the construction permit. Therefore, although the design of the plants has provided access for examinations to the extent practical, component design configurations with conditions resulting in examination limitations,

such as those from support interference, geometric configurations of welds and materials such as fittings or valve bodies made of cast stainless steel may not allow the full required examination volume or surface area coverage with the latest techniques available, and thus this request for relief addresses those conditions.

Details of examination restrictions and reductions in required examination coverage are provided in Attachment 2.

When examined, the welds listed in Attachment 2 of this request did not receive the required code volume coverage due to their component design configurations or interference by other items. These conditions resulted in limited scanning access that prohibited obtaining essentially 100% examination coverage of the required examination volume. When a limited examination occurred, 100% of the volume that was accessible was covered.

Burden Caused by Compliance To comply with the code required examination volumes or surface areas for obtaining essentially 100%

coverage for the welds listed in this request for relief, the welds and their associated components would have to be physically modified beyond their current design. Overall, components and fittings associated with the welds listed in this request are constructed of standard design items and materials meeting typical national standards that specify required configurations and dimensions. To replace these items with items of alternate configurations or materials to enhance examination coverage would require unique redesign and fabrication.

Because these items are in the Class 1 boundaries and for the Class 1 items that form a part of the reactor coolant pressure boundary, their redesign and fabrication would be an extensive effort based on the limitations that exist.

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For the Class 1, Examination Category B-A, Item No. B1.11, Lower Shell to Bottom Head Circumferential Weld, RC-RPV-WR-34, the limitation was caused by the core support lugs. For Item No. B1.21 Bottom Head Circumferential (Disc) Weld, RC-RPV-WR-35, the limitation was caused by the proximity of the Incore Instrument Nozzles.

For the Class 1, Examination Category B-D, Pressurizer Nozzle -to-Vessel Welds, Item No. B3.110, (RC-PZR-WP-15, RC-PZR-WP-33-W/X, RC-PZR-WP-33-Y/Z, and RC-PZR-WP-34), the limitations were caused by the configuration of the nozzles. The examinations were performed from the vessel outside diameter. To obtain the required coverage for each of these welds would require a design modification.

Overall, it is not possible to obtain Ultrasonic (UT) interrogation of greater than 90% of the required code examination volume for the welds in this request without extensive weld or component design modifications.

Examinations have been performed to the maximum extent possible and radiography is impractical due to the amount of work being performed in the areas on a 24-hour basis when the welds are available for examination. Using radiography would result in numerous work-related stoppages and increased exposure due to the shutdown and startup of other work in the areas. The water may need to be drained from systems or components where radiography is performed, which increases the radiation dose rates over a much broader area than the weld being examined. There is significant impracticality associated with the performance of weld or area modifications or the use of radiography to increase the examination coverage.

6. Proposed Alternative and Basis for Use

Proposed Alternative

1) Conduct required UT examinations to the maximum extent possible as required by ASME Section XI.

2) Periodic system pressure tests and VT-2 visual examinations will continue to be performed in accordance with ASME Section Xl, Examination Category B-P, for Class 1 pressure retaining welds and items each refueling outage.

Basis for Use 10 CFR 50.55a(g)(4) recognizes that throughout the service life of a nuclear power facility, components (including supports) that are classified as ASME Code Class 1 must meet the requirements set forth in the ASME Code to the extent practical within the limitations of design, geometry, and materials of construction of the welds and items. When a component is found to have conditions that limit the required examination volume or surface area, a licensee is required to submit this information to the enforcement and regulatory authorities having jurisdiction at the plant site. This request for relief has been written to address areas where these types of conditions exist and where the required amount of coverage was reduced below the minimum acceptable. Vistra Operations Company LLC (formerly Energy Harbor Nuclear Corp.) has performed the weld examinations listed in this request to the maximum extent possible for each of the welds identified with limitations as described in Attachment 2.

The Class 1 Examination Category B-A, Pressure Retaining Welds in Reactor Vessel, Examination Category B-D, Pressurizer Nozzle -to-Vessel Welds within the scope of this request are all located inside the containment building. Even though their examination did not meet the essentially 100% code required volume coverage requirement, there is instrumentation in place to assure that early detection of any reactor coolant system (RCS) pressure boundary leakage is identified. This is accomplished by the leakage detection instrumentation inside the containment building where the RCS leakage detection instrumentation is required to be operable. The instrumentation consists of monitoring of containment floor drain sump level to determine flow rate, containment air cooler condensate flow rate increases, and airborne gaseous radioactivity increases. These instruments are used to quantify any unidentified leakage from the RCS and to meet DB Technical Specification 3.4.13 Limiting Condition for Operation, which states that RCS Operational Leakage shall be limited to:

a. No pressure boundary LEAKAGE;

b. 1 gpm unidentified LEAKAGE;

c. 10 gpm identified LEAKAGE; and

d. 150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

Based upon the extent of the ultrasonic examination volume achieved for each of the welds within this relief request, coupled with applicable leakage monitoring and required system pressure tests with VT-2 visual examinations, generic degradation, if occurring, would be detected.

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7. Duration of Proposed Alternative

This request for relief is for the DB Unit 1, Fourth 10- Year ISI Interval, which began on September 21, 2012, and ended on June 7, 2023.

8. References

1. NRC presentation Coverage Relief Requests, Industry/NRC NDE Technical Information Exchange Public Meeting January 13-15, 2015, [ADAMS Accession No.: ML15013A266].

2. ASME Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 2007 Edition with the 2008 Addenda.

3. ASME Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, A ppendix VIII, Performance Demonstration for Ultrasonic Examination Systems, 2007 Edition with the 2008 Addenda.

Attachment 2 L 214

American Society of Mechanical EngineersSection XI 10 CFR 50.55a Request for Relief Number RR-A1, Revision 0

Davis-Besse Nuclear Power Station Specific Applicability Page 1 of 34 Introduction

This attachment contains figures and tables, as applicable, that are used to depict the limitations, examination coverage calculations, material and product forms, ultrasonic examination angles and wave modes used, any limited surface examinations, and the examination results for the welds associated with this notification of impracticality, including any applicable previous examination history used. The following Table 1 for DB identifies the welds within the scope of this request and summarizes the extent of examination coverage achieved for each weld.

Many of the welds listed were examined with different approved procedures and techniques during the span of the Fourth 10- Year ISI Interval and therefore not all the coverage calculations used are identical, but they are based on the actual NDE data reports that were provided for the examinations completed.

TABLE 1 - DB UNIT 1 WELDS WITH LIMITED EXAMINATIONS Unit/ Class/ Weld Material 1 Material 2 Examination Examination Applicable Seq. Number Category/ Description and and Code Limitations Tables

/ Weld Item No. Product Product Coverage and Results and Identification Form Form Obtained2 Figures Number 1 1 Lower Shell-to-A508 CL2 A508 CL2 50% Due to Core Figures 1.1/RC-RPV-B-A Bottom Lugs 1.1-1 thru WR-341 B1.11 Circumferential 1.1-6 Weld 1 1 Bottom Head SA533 A508 CL2 84% Due to Figures 1.2/RC-RPV-B-A Circumferential GR. B Incore 1.2-1 thru WR-351 B1.21 (Disc) Weld Nozzle 1.2-8 &

Table 1.2-1 1 1 10 Surge A508 CL1 SA516 GR. 72.3% Due to Figures 1.3/RC-PZR-B-D Nozzle-to-70 Nozzle 1.3-1 thru WP-151 B3.110 Lower Head Configuration 1.3-2 Weld 1 1 3 W/X Axis A508 CL1 SA516 GR. 52.48% Due to Figures 1.4/RC-PZR-B-D Relief Nozzle-70 Nozzle 1.4-1 thru WP-33-W/X1 B3.110 to-Upper Head Configuration 1.4-5 Weld 1 1 3 Y/Z Axis A508 CL1 SA516 GR. 74.1% Due to Figures 1.5/RC-PZR-B-D Relief Nozzle-70 Nozzle 1.5-1 thru WP-33-Y/Z1 B3.110 to-Upper Head Configuration 1.5-7 Weld and proximity of Lifting Lug and Manway 1 1 4 Spray A508 CL1 SA516 GR. 67.60% Due to Figures 1.6/RC-PZR-B-D Nozzle-to-70 Nozzle 1.6-1 thru WP-341 B3.110 Upper Head Configuration 1.6-4 Weld NOTES: 1. Containment RCS Leakage Detection Applies

2. Ultrasonic (UT) Examination, Phased Array UT Examination (PAUT) and Surface Examination by Liquid Penetrant (PT) or Magnetic Particle (MT).

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1.1 Weld RC-RPV-WR-34 - Lower Shell-to-Bottom Circumferential Weld

Figure 1.1-1 Weld RC-RPV-WR-34

This weld was UT examined in Inspection Period 3, during the 1R22 refueling outage in the Spring of 2022. The NDE data came from UT Report No.: 180- 9346485- 000. The UT Code Required Volume (CRV) was determined based on Section XI, Figure IWB-2500- 1). The corresponding CRV as shown on that Figure is E-F-G-H. The UT examination was limited by the location of the core lugs resulting in total UT coverage of 50.2% as described in Figure 1.1-6. No recordable indications were detected during this scan.

Section XI, Appendix VIII, 2007 Edition with the 2008 Addenda as modified by the Performance Demonstration Initiative (PDI) program and conditions by Federal Register, Part II Nuclear Regulatory Commission, 10 CFR Part 50, Industry Codes and Standards; amended requirements were used for this UT examination.

Note: No la minations exist on the r eactor vessel that could interfere with the angle beam examinations performed on this weld.

L 214 Page 3 of 34

Figure 1.1-2 RC-RPV-WR-34 Area of Interest

Figure 1.1-3 RC-RPV-WR-34 Area of Coverage - "Theta" Scan (Cross Section)

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Figure 1.1-4 RC-RPV-WR-34 Area of Coverage - Axial Scan (Cross Section)

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Figure 1.1-5 RC-RPV-WR-34 Location of Core Lugs L 214 Page 6 of 34

Figure 1.1-6 RC-RPV-WR-34 Examination Coverage Calculations Attachment 2 L 214 Page 7 of 34

1.2 Weld RC-RPV-WR-35 - Bottom Head Circumferential (Disc) Weld

Figure 1.2-1 Weld RC-RPV-WR-35

This weld was UT examined in Inspection Period 3, during the 1R22 refueling outage in the Spring of 2022. The NDE data came from UT Report No.: 180- 9346485- 000. The UT Code Required Volume (CRV) was determined based on Section XI, Figure IWB-2500- 3. The corresponding CRV as shown on that Figure is A-B-C-D. The UT examination was limited by the location of the Incore Nozzle resulting in total UT coverage of 84% as described in Figure 1.2-8. Two recordable indications were detected during this scan and were found acceptable. Both indications were classified as subsurface flaws and are characteristic of slag inclusions from the welding process.

This weld will be examined again during the next reactor vessel examination.

TWS Weld Acceptance Indication Measured Allowable No. Component ID Description Standard Number a/t (%) a/t (%)

W05 RC-RPV-WR-35 Bottom Head Circumferential (Disc) IWB-3510-1 1 1.4 2.2 2 1.3 2.0 Weld MK 181 to MK6 Table 1.2-1 Recordable Indications

Section XI, Appendix VIII, 2007 Edition with the 2008 Addenda as modified by the Performance Demonstration Initiative (PDI) program and conditions by Federal Register, Part II Nuclear Regulatory Commission, 10 CFR Part 50, Industry Codes and S tandards; amended requirements were used for this UT examination.

Note: No laminations exist on the r eactor vessel that could interfere with the angle beam examinations performed on this weld.

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Figure 1.2-2 RC-RPV-WR-35 Area of Interest (Cross Section)

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Figure 1.2-3 RC-RPV-WR-35 Area of Coverage - Theta Scan (Cross Section)

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Figure 1.2-4 RC-RPV-WR-35 Area of Coverage - Axial Scan (Cross Section)

Figure 1.2-5a RC-RPV-WR-35 Area of Coverage - Axial Scan Missed Coverage (Cross Section)

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Figure 1.2-5b RC-RPV-WR-35 Area of Coverage -

Axial Scan Missed Coverage (Cross Section)

Figure 1.2-5c RC-RPV-WR-35 Area of Coverage - Axial Scan Missed Coverage (Cross Section)

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Figure 1.2-5d RC-RPV-WR-35 Area of Coverage - Axial Scan Missed Coverage (Cross Section)

Figure 1.2-5e RC-RPV-WR-35 Area of Coverage - Axial Scan Missed Coverage (Cross Section)

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Figure 1.2-6a RC-RPV-WR-35 Area of Coverage -

Theta Scan Missed Coverage (Cross Section)

Figure 1.2-6b RC-RPV-WR-35 Area of Coverage -

Theta Scan Missed Coverage (Cross Section)

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Figure 1.2-6c RC-RPV-WR-35 Area of Coverage - Theta Scan Missed Coverage (Cross Section)

Figure 1.2-6d RC-RPV-WR-35 Area of Coverage - Theta Scan Missed Coverage (Cross Section)

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Figure 1.2-6e RC-RPV-WR-35 Area of Coverage -

Theta Scan Missed Coverage (Cross Section)

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Figure 1.2-7 RC-RPV-WR-35 Total Scan Coverage of W eld W05 is Limited due to Interference with Instrumentation Nozzles and Core Lugs L 214 Page 17 of 34

Figure 1.2-8 RC-RPV-WR-35 Examination Coverage Calculations L 214 Page 18 of 34

1.3 Weld RC-PZR-WP-15 - 10 Surge Nozzle-to-Lower Head Weld

Figure 1.3-1 Weld RC-PZR-WP-15

This weld was UT examined in Inspection Period 3, during the 1R22 refueling outage in the Spring of 2022. The NDE data came from UT Report No.: 22-UT-029. The UT Code Required Volume (CRV) was determined based on Section XI, Figure IWB-2500- 7a. The corresponding CRV as shown on that Figure is A-B-C-D-E-F-G-H-I.

EPRI modelling report number IR-2014-572 was used to develop a scan plan and determine transducer/wedge selection to maximize examination coverage. The UT examination was limited by the nozzle configuration resulting in total UT coverage of 72.3% as described in Figure 1.3-2. No recordable indications were detected during this scan.

Section XI, Appendix VIII, 2007 Edition with the 2008 Addenda as modified by the Performance Demonstration Initiative (PDI) program and conditions by Federal Register, Part II Nuclear Regulatory Commission, 10 CFR Part 50, Industry Codes and Standards; amended requirements were used for this UT examination.

Note: No laminations exist on the pressurizer lower head that could interfere with the angle beam examinations performed on this weld.

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Beam Angle at Flaw Plot; Examination Techniques 65/10vs, 45/(33 to 74)vs, and 35/120bd

Figure 1.3-2 RC-PZR-WP-15 Examination Coverage Calculation L 214 Page 20 of 34

1.4 Weld RC-PZR-WP W/X - 3 W/X Axis Relief Nozzle-to-Upper Head Weld

Figure 1.4-1 Weld RC-PZR-WP W/X

This weld was UT examined in Inspection Period 1, during the 1R18 refueling outage in the Spring of 2014. The NDE data came from UT Report No.: 18-UT-037. The UT Code Required Volume (CRV) was determined based on Section XI, Figure IWB-2500- 7a. The corresponding CRV as shown on that Figure is A-B-C-D-E-F-G-H-I.

EPRI modelling report number IR-2014-572 was used to develop a scan plan and determine transducer/wedge selection to maximize examination coverage. The UT examination was limited by the nozzle configuration resulting in total UT coverage of 52.48% as described in Figure 1.4-5. No recordable indications were detected during this scan.

Section XI, Appendix VIII, 2007 Edition with the 2008 Addenda as modified by the Performance Demonstration Initiative (PDI) program and conditions by Federal Register, Part II Nuclear Regulatory Commission, 10 CFR Part 50, Industry Codes and Standards; amended requirements were used for this UT examination.

Note: No laminations exist on the pressurizer upper head that could interfere with the angle beam examinations performed on this weld.

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Figure 1.4-2 RC-PZR-WP W/X Radial Coverage Work Sheet L 214 Page 22 of 34

Figure 1.4-3 RC-PZR-WP W/X Radial Coverage Work Sheet L 214 Page 23 of 34

Figure 1.4-4 RC-PZR-WP W/X Circumferential Coverage Work Sheet L 214 Page 24 of 34

Figure 1.4-5 RC-PZR WP-W/X Coverage Calculation L 214 Page 25 of 34

1.5 Weld RC-PZR-WP Y/Z - 3 Y/Z Axis Relief Nozzle-to-Upper Head Weld

Figure 1.5-1 Weld RC-PZR-WP Y/Z

This weld was UT examined in Inspection Period 3, during the 1R22 refueling outage in the Spring of 2022. The NDE data came from UT Report No.: 22-UT-013. The UT Code Required Volume (CRV) was determined based on Section XI, Figure IWB-2500-7a. The corresponding CRV as shown on that Figure is A-B-C-D-E-F-G-H-I. EPRI modelling report number IR-2014-572 was used to develop a scan plan and determine transducer/wedge selection to maximize examination coverage. The UT examination was limited by the nozzle configuration and the proximity of lifting lug and manway resulting in total UT coverage of 74.1% as described in Figure 1.5-1. Two indications were detected during this scan. They were the same acceptable indications reported during 1R12, and there have been no changes to these acceptable indications as reported in 1R17 and 1R22.

Section XI, Appendix VIII, 2007 Edition with the 2008 Addenda as modified by the Performance Demonstration Initiative (PDI) program and conditions by Federal Register, Part II Nuclear Regulatory Commission, 10 CFR Part 50, Industry Codes and Standards; amended requirements were used for this UT examination.

Note: No laminations exist on the pressurizer upper head that could interfere with the angle beam examinations performed on this weld.

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Figure 1.5-2 RC-PZR WP-Y/Z Coverage Calculation L 214 Page 27 of 34

Figure 1.5-3 RC-PZR WP-Y/Z Circumferential Scan Coverage L 214 Page 28 of 34

Figure 1.5-4 RC-PZR WP-Y/Z Axial Scan Coverage L 214 Page 29 of 34

Figure 1.5-5 RC-PZR WP-Y/Z Limited Exam due to proximity of Lifting Lug and Manway L 214 Page 30 of 34

Figure 1.5-6 RC-PZR WP-Y/Z Coverage Map:

Vessel Shell Techniques, 65/(-2)vs, 60/(-4 to 14)vs, 45/(0 to 78)vs

Figure 1.5-7 RC-PZR WP-Y/Z Beam Angle at the Flaw Map: Vessel Shell Techniques, 65/(-2)vs, 60/(-4 to 14)vs, 45/(0 to 78)vs L 214 Page 31 of 34

1.6 Weld RC-PZR-WP-34 - 4 Spray Nozzle-to-Upper Head Weld

Figure 1.6-1 Weld RC-PZR-WP-34

This weld was UT examined in Inspection Period 1, during the 1R18 refueling outage in the Spring of 2014. The NDE data came from UT Report No.: 18-UT-036. The UT Code Required Volume (CRV) was determined based on Section XI, Figure IWB-2500- 7a. The corresponding CRV as shown on that Figure is A-B-C-D-E-F-G-H-I.

EPRI modelling report number IR-2014-572 was used to develop a scan plan and determine transducer/wedge selection to maximize examination coverage. The UT examination was limited by the nozzle configuration resulting in total UT coverage of 67.60% as described in Figure 1.6-4. No recordable indications were detected during this scan.

Section XI, Appendix VIII, 2007 Edition with the 2008 Addenda as modified by the Performance Demonstration Initiative (PDI) program and conditions by Federal Register, Part II Nuclear Regulatory Commission, 10 CFR Part 50, Industry Codes and Standards; amended requirements were used for this UT examination.

Note: No laminations exist on the pressurizer upper head that could interfere with the angle beam examinations performed on this weld.

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Figure 1.6-2 RC-PZR-WP-34 Radial Scan Coverage L 214 Page 33 of 34

Figure 1.6.3 RC-PZR-WP-34 Circumferential Scan Coverage L 214 Page 34 of 34

Figure 1.6-4 RC-PZR-WP-34 Coverage Calculation