NL-08-1300, Proposed Relief Requests for the Third ISI Interval

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Proposed Relief Requests for the Third ISI Interval
ML082670627
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 09/22/2008
From: Ajuni M
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-08-1300
Download: ML082670627 (57)


Text

Southern Nuclear Operating Company. Inc.

Post Office Box 1295 Birmingham, Alabama 35201-1295 Tel 205.992.5000 SOUIHERN'\\

COMPANY September 22, 2008 Energy to Serve Your World SM Docket Nos.: 50-348 NL-08-1300 50-364 U, S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Unit 1 and Unit 2 Proposed Relief Requests for the Third lSI Interval Ladies and Gentlemen:

Pursuant to 10 CFR 50.55a(g)(5)(iii), Southern Nuclear Operating Company (SNC) hereby requests NRC approval of proposed relief requests from the specified ASME Boiler and Pressure Vessel Code Section XI requirements.

These relief requests document those limited examinations that had not previously been submitted to the NRC, for the third lSI interval for Farley Unit 1 and Unit 2.

Note that risk-informed lSI was in effect for the third lSI interval during which these relief requests were necessary, as approved by NRC letter dated March 9, 2004. Risk-informed lSI is not currently in effect for the fourth lSI interval.

This letter contains no NRC commitments. If you have any questions, please advise.

Sincerely, rvt48~

M. J. Ajluni Manager, Nuclear Licensing MJAI~ILS/phr

U. S. Nuclear Regulatory Commission NL-08-1300 Page 2

Enclosures:

1) Unit 1 Proposed Relief Request RR-62 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)
2) Unit 1 Proposed Relief Request RR-64 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)
3) Unit 1 Proposed Relief Request RR-65 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)
4) Unit 1 Proposed Relief Request RR-66 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)
5) Unit 1 Proposed Relief Request RR-67 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)
6) Unit 1 Proposed Relief Request RR-68 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)
7) Unit 1 Proposed Relief Request RR-69 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)
8) Unit 2 Proposed Relief Request RR-61 Version 1.0,in Accordance with 10 CFR 50.55a(g)(5)(iii)
9) Unit 2 Proposed Relief Request RR-62 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii) cc:

Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Farley Mr. D. H. Jones, Vice President - Engineering RTYPE: CFA04.054; LC# 14820 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. K. D. Feintuch, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley

Joseph M. Farley Nuclear Plant - Units 1 and 2 Proposed Relief Requests for the Third 151 Interval Unit 1 Proposed Relief Request RR-62 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

Plant Site Unit:

Interval*

Interval Dates:

Requested Date for Approval and Basis:

ASMECode Components Affected:

Applicable Code Edition and Addenda:

Applicable Code Requirements:

Impracticality of Compliance:

Unit 1 Proposed Relief Request RR*62 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Farley Nuclear Plant - Unit 1.

Third 151 Interval - December 1, 1997 through November 30, 2007.

Approval is requested by August 31,2009 in order to close-out the third 151 interval activities.

Southern Nuclear (SNC) developed the risk-informed 151 (RI-ISI) program for piping welds during the third 151 interval for Farley. SNC determined a scope from the Class 1 and 2 piping and prepared a technical alternative for NRC review. The NRC approved the technical alternative (see References) and RI-ISI was implemented at Farley during the 1R19 outage in Fall 2004. The selected RI-ISI examinations are assigned ASME Category R-A per the Farley alternative. Farley has revised the original pipe weld numbers by adding an

"-RI" suffix onto the weld numbers to distinguish them from the previous 151 weld number.

The affected component is a Class 2, ASME Section XI Category R-A, austenitic steel piping weld as shown in Table RR-62.

ASME Section XI, 1989 Edition with no Addenda plus NRC-approved technical alternative to implement risk-informed 151 for the examination of piping welds.

The Farley RI-ISI documentation including the technical alternative is used to determine the scope of the volumetric examinations. The examinations were performed after the required implementation of Supplement 2 of Appendix VIII.

The examination volumes typically follow ASME Section XI Figure IWC-2500 7(a) except that the volume was increased to include Y2-inch beyond each side of the base metal thickness transition (or counterbore) to meet RI-ISI requirements.

Physical limitations due to the geometric configuration of the welded areas restricted coverage of the examination volume as required by Figure IWC-2500 7(a). The Class 2 weld with limitations is described in Table RR-62. The examinations were performed to the maximum extent possible. Figure RR-62 shows a typical representation of a single-side access examination with a valve, along with limitations. Appreciably increasing coverage was impractical due to the limitations described in the table.

E1 - 1

Burden Caused by Compliance:

Proposed Alternative and Basis for Use:

Duration of Proposed Relief Request:

Precedents:

References:

Status:

Unit 1 Proposed Relief Request RR*62 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Compliance would require replacement of the existing valve with a new valve fabricated with a special design to allow examination.

The ultrasonic examination was performed after the implementation of Appendix VIII and consisted of primarily a single-sided examination from the pipe side. The root area of the weld was interrogated with both a 45° and a 70° shear wave looking for circumferential cracking. In addition, VT-2 visual examinations are performed each lSI period for the weld listed in Table RR-62.

These examinations and tests provide reasonable assurance of structural integrity of this weld. Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

The proposed relief request is applicable for the Third Interval.

The physical limitations described in this relief request are essentially identical to Farley-1 RR-50 for the third lSI interval which was approved by the NRC on November 7, 2002. Since the UT examinations in this relief request were performed to Supplement 2 of Appendix VIII, the examination coverage is less than the typical pre-Appendix VIII examination coverage listed in RR-50.

The NRC SER TAC No. for RR-50 is MB3776. The NRC approved risk informed lSI at Farley on March 9, 2004 by NRC TAC Nos. MC0178 and MC 0179.

Awaiting NRC approval.

E1 - 2 Unit 1 Proposed Relief Request RR-62 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR-62: Class 2 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results ALA2-4540-32-RI 1R20 (Spring 2006 Outage)

Valve to Pipe Post-PDI examination. Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration. See Figure RR-62 for typical picture and coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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.

Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

50% UT No Recordable Indications E1 - 3 Unit 1 Proposed Relief Request RR-62 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

FIGURE RR-62 Typical Single-Side Access for Volumetric Examinations Limited examination area (i.e., not all four-directional coverage) shown as hatched.

/

/

Pipe/Elbow (2)

(1) Examination volume: Weld + 14" each side of weld toes.

(2) Additional Volume: + W' each side for RI-ISI.

/

./

(1)

(2)

E1 - 4

Joseph M. Farley Nuclear Plant - Units 1 and 2 Proposed Relief Requests for the Third lSI Interval Unit 1 Proposed Relief Request RR*64 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Plant Site Unit:

Interval Interval Dates:

Requested Date for Approval and Basis:

ASMECode Components Affected:

Applicable Code Edition and Addenda:

Applicable Code Requirements:

Impracticality of Compliance:

Burden Caused by Compliance:

Unit 1 Proposed Relief Request RR-64 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

Farley Nuclear Plant - Unit 1.

Third lSI Interval-December 31, 1997 through November 30,2007.

Approval is requested by August 31,2009 in order to close-out the third lSI interval activities.

Class 1, ASME Section XI Category B-J, Item Number B9.11, and Class 2, ASME Section XI Category C-F-1, Item Number C5.11, austenitic steel piping welds as shown in Table RR-64.

ASME Section XI, 1989 Edition with no addenda.

Examination Category B-J, Table IWB-2500-1, and Category C-F-1, Table IWC 2500-1, of the 1989 Edition of the ASME Section XI Code requires both a surface and a volumetric examination. The examinations were performed after the required implementation of Supplement 2 of Appendix VIII. The examination volumes are shown in ASME Section XI Figures IWB-2500-8(c) and IWC-2500-7(a) and include essentially 100% of the weld length.

Physical limitations due to geometric configuration of the welded areas restricted coverage of the examination volume as required by Figures IWB 2500-8(c) and IWC-2500-7(a). The twelve welds with limitations are described in Table RR-64-1 and Table RR-64-2 for Class 1 and Class 2 piping welds, respectively. Figure RR-64-1 shows a typical representation of a single-side access examination with a valve, along with limitations. The configurations of the flange and tee are similar with no examination possible from the flange or tee side. In addition, the 6-inch Class 1 weld, ALA1-4202-3, was limited by the welded support structure and the ID tag. Figure RR-64-2 shows the lay-out of the weld with the listed limitations. The examinations were performed to the maximum extent possible. Appreciably increasing coverage was impractical due to the limitations described in the table.

Compliance would require replacement of the existing valves, tees, and flanges with new components fabricated with a special design to allow examination.

E2 - 1

Proposed Alternative and Basis for Use:

Duration of Proposed Relief Request:

Precedents:

References:

Status:

Unit 1 Proposed Relief Request RR-64 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

A surface examination (liquid penetrant technique) was performed on these welds. The ultrasonic examinations were performed after the implementation of Appendix VIII and consisted of primarily a single-sided examination from the pipe side of the weld. The root of the weld was interrogated with both a 45° shear wave and a 60° refracted longitudinal wave looking for circumferential cracking.

In addition, VT-2 visual examinations associated with the Class 1 leakage test are performed each refueling outage for the welds listed in Table RR-64-1 and each lSI period for the welds listed in Table RR-64-2. These examinations and tests provide reasonable assurance of structural integrity of these welds. Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

The proposed relief request is applicable for the Third Interval.

The physical limitations described in this relief request are essentially identical to Farley-1 RR-50 for the third lSI interval which was approved by the NRC on November 7,2002. Since the UT examinations in this relief request were performed to Supplement 2 of Appendix VIII, the examination coverage is less than the typical pre-Appendix VIII examination coverage listed in RR-50.

The NRC SER TAC No. for RR-50 is MB3776.

Awaiting NRC approval.

E2 - 2 Unit 1 Proposed Relief Request RR-64 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

Table RR-64-1: Class 1 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results ALA1-4202-3 6" Elbow to Pipe Post-POI examination. 100 % surface examination.

100% PT No 1R18 (Spring 2003 Outage)

Limited UT examination coverage due to welded support structure and welded 10 plate. See Figure RR-64-2 for typical picture and coverage.

75% UT Recordable Indications ALA1-4202-4 1R18 (Spring 2003 Outage) 6" Valve to Pipe Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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. Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

100% PT 50% UT No Recordable Indications ALA1-4202-5 1R18 (Spring 2003 Outage) 6" Pipe to Valve Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only 100% PT 50% UT No Recordable Indications E2 - 3 Unit 1 Proposed Relief Request RR-64 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

Table RR-64-1: Class 1 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

ALA1-4204-4 1R18 (Spring 2003 Outage) 6" Valve to Pipe Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration and limited by welded 10 pad. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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. Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 48% of the Code coverage can be credited.

100% PT 48% UT No Recordable Indications ALA1-4204-5 1R18 (Spring 2003 Outage) 6" Pipe to Valve Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full 100% PT 50% UT No Recordable PT Indications; 60° UT examination 10 geometry.

E2 - 4 Unit 1 Proposed Relief Request RR*64 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR-64-1: Class 1 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results 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. Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

E2 - 5 Unit 1 Proposed Relief Request RR-64 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR-64-2: Class 2 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results ALA2-4524-9 1R18 (Spring 2003 Outage) 4" Pipe to Valve Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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. Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

100% PT 50% UT No Recordable PT Indications; 60° UT examination 10 geometry.

ALA2-4532-9 1R18 (Spring 2003 Outage) 4" Tee to Reducer Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the reducer side.

No examination coverage from the tee side due to configuration. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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. Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

100% PT 50% UT No Recordable Indications E2 - 6 Unit 1 Proposed Relief Request RR-64 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR-64-2: Class 2 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results ALA2-4605-20 1R18 (Spring 2003 Outage) 14" Pipe to Valve Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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. Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

100% PT 50% UT No Recordable PT Indications; 60° & 70° UT examination 10 geometry.

ALA2-4609-1 1R18 (Spring 2003 Outage) 4" Tee to Pipe Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the pipe side. No examination coverage from the tee side due to configuration. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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. Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the 100% PT 50% UT No Recordable PT Indications; 60° UT examination 10 geometry.

E2 -7 Unit 1 Proposed Relief Request RR-64 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR-64-2: Class 2 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results Code coverage can be credited.

ALA2-4609-8 1R18 (Spring 2003 Outage) 4" Pipe to Flange Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the pipe side. No examination coverage from the flange side due to configuration. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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. Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

100% PT 50% UT No Recordable PT Indications; 60° UT examination 10 geometry.

ALA2-461 0-8 1R18 (Spring 2003 Outage) 3" Valve to Pipe Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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. Since PDI qualifications do not meet requirements 100% PT 50% UT PT Indication was removed with surface conditioning.

60° UT examination 10 geometry.

E2 - 8 Unit 1 Proposed Relief Request RR-64 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR-64-2: Class 2 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

ALA2-461 0-9 1R18 (Spring 2003 Outage) 3" Pipe to Tee Post-POI examination. 100 % surface examination.

Complete ultrasonic examination from the pipe side. No examination coverage from the tee side due to configuration. See Figure RR-64-1 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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. Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

100% PT 50% UT No Recordable PT Indications; 60° UT examination 10 geometry.

E2 - 9 Unit 1 Proposed Relief Request RR*64 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Figure RR-64-1 Typical Single-Side Access for Volumetric Examinations Limited examination area (Le., not all four-directional coverage) shown as hatched.

Pipe/Elbow Component (1 )

(1) Examination volume: Weld + %" each side of weld toes.

Weld E2 - 10 Unit 1 Proposed Relief Request RR-64 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Figure RR-64-2

.25"

.85"

.25" E2 - 11

Joseph M. Farley Nuclear Plant - Units 1 and 2 Proposed Relief Requests for the Third lSI Interval Unit 1 Proposed Relief Request RR*65 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Unit 1 Proposed Relief Request RR-65 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Plant Site-Unit:

Farley Nuclear Plant - Unit 1.

Interval -

Third lSI Interval - December 31, 1997 through November 30, 2007.

Interval Dates:

Re~~~::r~:~~

Approval is requested by August 31,2009 in order to close-out the third lSI and Basis: ' interval activities.

ASMECode Southern Nuclear (SNC) developed the risk-informed lSI (RI-ISI) program for Components piping welds during the third lSI interval for Farley. SNC determined a scope Affected: from the Class 1 and 2 piping and prepared a technical alternative for NRC review. The NRC approved the technical alternative (see References) and RI lSI was implemented at Farley during the 1R19 outage in Fall 2004. The selected RI-ISI examinations are assigned ASME Category R-A per the Farley alternative. Farley has revised the original pipe weld numbers by adding an "

RI" suffix onto the weld numbers to distinguish them from the previous lSI weld number.

Applicable ASME Section XI, 1989 Edition with no Addenda plus NRC-approved technical Code Edition alternative to implement risk-informed lSI for the examination of piping welds.

and Addenda:

Applicable The Farley RI-ISI documentation including the technical alternative is used to Code determine the scope of the volumetric examinations. The examinations were Requirements:

performed after the required implementation of Supplement 10 of Appendix VIII. The examination volumes typically follow ASME Section XI Figure IWB 2500-8(c) except that the volume was increased to include Y:!-inch beyond each side of the base metal thickness transition (or counterbore) to meet RI-ISI requirements.

Impracticality Physical limitations due to the geometric configuration of the welded areas of Compliance:

restricted coverage of the examination volume as required by Figure IWB 2500-8(c). The Class 1 welds with limitations are described in Table RR-65.

The examinations were performed to the maximum extent possible. Figure RR-65 shows a representation of a single-side access examination for these welds, along with limitations. Appreciably increasing coverage was impractical due to the limitations described in the table.

Burden Caused Compliance would require replacement of the existing steam generator by Compliance:

nozzles and safe ends with new components fabricated with a special design to allow examination.

E3 - 1

Proposed Alternative and Basis for Use:

Duration of Proposed Relief Request:

Precedents:

References:

Status:

Unit 1 Proposed Relief Request RR-65 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

The ultrasonic examinations were performed to Appendix VIII and consisted of primarily a single-sided examination from the safe-end side of the weld. The ultrasonic examination was also performed from the nozzle side to the extent possible. In addition, VT-2 visual examinations are performed for each refueling outage for these components. These welds are Alloy 690 material which was added to the plant during steam generator replacement (1 R16 Outage in Spring 2000). Based on the examination coverage obtained for these welds and the visual VT-2 tests, there is reasonable assurance of the structural integrity of these welds. Therefore, relief should be granted per 10CFRSO.SSa(g)(6)(i).

The proposed relief request is applicable for the Third Interval.

These welds are approved for limited examination per Farley-1 RR-46 which was approved by the NRC on December 4, 2001. These welds were subsequently examined during the Fall 2007 outage after POI requirements went into effect.

Since the UT examinations in this relief request were performed per Appendix VIII, the coverage is less than the typical pre-Appendix VIII examinations listed in RR-46; therefore this new relief request is being submitted.

TAC Nos. MB0796 and MB0797. The NRC approved risk-informed lSI at Farley on March 9, 2004 by NRC TAC Nos. MC0178 and MC 0179.

Awaiting NRC approval.

E3 - 2 Unit 1 Proposed Relief Request RR-65 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

TABLE RR-65: Class 1 Piping Welds Identification No.

Description Limitation Coverage Examination Results ALA1-4300-26ROM-RI 1R21 (Fall 2007 Outage)

Safe-End to SG Nozzle Post-POI examination. UT scans looking for axial cracking were 100% on the weld and both sides of the weld. The UT coverage looking for circumferential flaws from the safe-end side was 52% with one beam angle. See Figure RR-65 for typical picture and coverage.

52% UT No Recordable Indications ALA1-4300-27ROM-RI 1R21 (Fall 2007 Outage)

SG Nozzle to Safe End Post-POI examination. UT scans looking for axial cracking were 100% on the weld and both sides of the weld. The UT coverage looking for circumferential flaws from the safe-end side was 52% with one beam angle. See Figure RR-65 for typical picture and coverage.

52% UT No Recordable Indications E3-3 Unit 1 Proposed Relief Request RR-6S Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

FIGURE RR-65 Typical Single-Side Access for Volumetric Examinations

'~._--. 2.0'" _.

',.***1 a"

-.......... / ""..

" --~--- -'- 3 3"

-.~=.~-----.... f' "

I;

-_.~~".

Nozzle

/

Safe-End

\\

E3 - 4

Joseph M. Farley Nuclear Plant - Units 1 and 2 Proposed Relief Requests for the Third lSI Interval Unit 1 Proposed Relief Request RR-66 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Unit 1 Proposed Relief Request RR-66 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Plant Site-Unit:

Farley Nuclear Plant - Unit 1.

Interval-Third lSI Interval-December 31, 1997 through November 30,2007.

Interval Dates:

Requested Approval is requested by August 31,2009 in order to close-out the third lSI Date for interval activities.

Approval and Basis ASME Code Class 1, ASME Section XI Category 8-A, Items 81.11, 81.21, 81.22, and Components 81.30 reactor pressure vessel (RPV) welds, as shown in Table RR-66.

Affected:

Applicable ASME Section XI, 1989 Edition with no addenda.

Code Edition and Addenda:

Applicable ASME Item numbers 81.11 and 81.30 listed above for Table IW8-2500-1, Code Examination Category 8-A, require that 100% of the length of each weld be Requirements:

examined. However, ASME Item numbers 81.21 and 81.22 listed above for Table IW8-2500-1, Examination Category 8-A, requires that the accessible length of each weld be examined. Even though only the accessible length was required for Item 81.21 and 81.22 welds, they were conservatively included. The examinations were performed after the implementation of Supplements 4 and 6 of Appendix VIII. Per Code Case N-460, coverage greater than 90% is acceptable. The examination volume is shown in ASME Section XI, Figure IW8-2500-1 for Item Number 81.11, Figure IW8-2500-4 for Item Number 81.30, and Figure IW8-2500-3 for Item Numbers 81.21 and 81.22.

Impracticality Physical limitations due to the geometric configuration of the welded areas of Compliance:

restricted coverage of the examination volume as required by the figures.

A total of eight RPV welds for Farley-1 are shown in Table RR-66. As noted in the limitations, additional positioning of the ultrasonic transducer was undertaken to maximize the coverage for these eight welds.

Appreciably increasing coverage was impractical due to the interferences described in Table RR-66.

Burden Obtaining more coverage would require replacement of the Farley-1 reactor Caused by pressure vessel.

Compliance:

E4 - 1 Unit 1 Proposed Relief Request RR*66 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Proposed Alternative and Basis for Use:

SNC received approval for Farley-1 relief request RR-17 on January 12, 1999 covering weld ALA1-1100-1 (valve to flange weld). In the first 151 Period of the third 151 interval, SNC examined this weld from the flange surface only.

In preparation of the 1O-year automated RPV examinations, SNC submitted ISI-GEN-ALT-06-01 which applied to Farley-1 and both Vogtle units. The applicable Farley-1 weld was ALA1-1100-1. The NRC granted approval on September 26,2006 to allow the use of Appendix VIII for this weld. The coverage of weld ALA1-1100-1 is based upon an Appendix VIII examination.

The examination of these eight welds was performed using automated ultrasonic techniques qualified through the Appendix VIII process. A large percentage of the weld root was interrogated for these eight welds and no ultrasonic indications exceeded the allowable flaw tables. In addition, VT-2 visual examinations are performed each refueling outage for these components. Based on these examination results plus the cumulative volumetric examination coverage of all RPV shell welds there is reasonable assurance of structural integrity and relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of Proposed Relief Request:

The proposed relief request is applicable for the Third Interval.

Precedents:

A similar third 151 interval relief request (RR-56) documented the limited RPV examinations at Farley-2; however, these examinations were performed prior to the implementation of Supplements 4 and 6 of Appendix VIII. The examinations in this new relief request were performed after the required implementation of Supplements 4 and 6 of Appendix VIII. Based on this change, some differences were observed for examination coverage.

The NRC granted approval for these limited examinations by letter dated May 19, 2005.

References:

TAC No. MC2559.

Status:

Awaiting NRC approval.

E4 - 2 Unit 1 Proposed Relief Request RR-66 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

TABLE RR-66 Weld Number I Examined ASME Item Coverage Basis for Limited Coverage ALA1-1100-1 Flange to Upper Shell 1R21 (Fall 2007 Outage) 81.30 68%

The UT examination of this circumferential weld was limited due to flange configuration, keyways and irradiation specimen slots.

ALA1-1100-8 Lower Shell / 80ttom Head 1R21 (Fall 2007 Outage) 81.11 84%

The UT examination of this circumferential weld was limited by the proximity of 4 RPV core support lugs. Scanning was conducted in both the perpendicular and parallel directions around the obstructing lug with the scan boundaries maximized by visually-assisted positioning of the remote examination head so that the scan starts and stops were as close to the core support lug as possible.

ALA1-1100-10 Lower Head Meridional Seam 1R21 (Fall 2007 Outage) 81.22 51%

The UT examination of this meridional weld was limited by the proximity of the peripherally-located bottom-mounted inspection (8MI) tubes. Scanning was conducted between the obstructing tubes with the scan boundaries maximized by visually-assisted positioning of the remote examination head so that the scan starts and stops were as close to the 8MI tubes as possible.

ALA1-1100-11 Lower Head Meridional Seam 1R21 (Fall 2007 Outage) 81.22 80%

The UT examination of this meridional weld was limited by the proximity of the peripherally-located bottom-mounted inspection (8MI) tubes. Scanning was conducted between the obstructing tubes with the scan boundaries maximized by visually-assisted positioning of the remote examination head so that the scan starts and stops were as close to the 8MI tubes as possible.

ALA1-1100-12 Lower Head Meridional Seam 1R21 (Fall 2007 Outage) 81.22 88%

The UT examination of this meridional weld was limited by the proximity of the peripherally-located bottom-mounted inspection (8MI) tubes. Scanning was conducted between the obstructing tubes with the scan boundaries maximized by visually-assisted positioning of the remote examination head so that the scan starts and stops were as close to the 8MI tubes as possible.

E4-3 Unit 1 Proposed Relief Request RR-66 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

TABLE RR-66 Weld Number I Examined ASME Item Coverage Basis for Limited Coverage ALA1-1100-13 Lower Head Meridional Seam 1R21 (Fall 2007 Outage) 81.22 19%

The UT examination of this meridional weld was limited by the proximity of the peripherally-located bottom-mounted inspection (8MI) tubes. Scanning was conducted between the obstructing tubes with the scan boundaries maximized by visually-assisted positioning of the remote examination head so that the scan starts and stops were as close to the 8MI tubes as possible.

ALA1-1100-14 Lower Head Meridional Seam 1R21 (Fall 2007 Outage) 81.22 39%

The UT examination of this meridional weld was limited by the proximity of the peripherally-located bottom-mounted inspection (8MI) tubes. Scanning was conducted between the obstructing tubes with the scan boundaries maximized by visually-assisted positioning of the remote examination head so that the scan starts and stops were as close to the 8MI tubes as possible.

ALA1-1100-15 Lower Head /

Circumferential 1R21 (Fall 2007 Outage) 81.21 25%

The UT examination of this circumferential weld was limited by the proximity of the peripherally-located bottom-mounted inspection (8MI) tubes. Scanning was conducted between the obstructing tubes with the scan boundaries maximized by visually-assisted positioning of the remote examination head so that the scan starts and stops were as close to the 8MI tubes as possible.

E4 - 4

Joseph M. Farley Nuclear Plant - Units 1 and 2 Proposed Relief Requests for the Third lSI Interval Unit 1 Proposed Relief Request RR*67 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(ii1)

Plant Site Unit:

Interval Interval Dates:

Requested Date for Approval and Basis:

ASMECode Components Affected:

Applicable Code Edition and Addenda:

Applicable Code Requirements:

Impracticality of Compliance:

Burden Caused by Compliance:

Proposed Alternative and Basis for Use:

Enclosure S Unit 1 Proposed Relief Request RR-67 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

Farley Nuclear Plant - Unit 1.

Third lSI Interval-December 31,1997 through November 30,2007.

Approval is requested by August 31, 2009 in order to close-out the third lSI interval activities.

Class 1, ASME Section XI Category B-J, Item B9.11, austenitic steel piping weld as shown in Table RR-67.

ASME Section XI, 1989 Edition with no addenda. This was a pre-Appendix VIII examination.

Examination Category B-J, Table IWB-2500-1, of the 1989 Edition of the ASME Section XI Code requires surface and volumetric examination of pressure retaining welds in Class 1 piping. Applicable examination volumes are shown in ASME Section XI, Figure IWB-2500-8(c) and include essentially 100% of the weld length. To obtain 100% coverage, the ultrasonic beam must pass through the entire examination volume in four directions, axial (up &down) and circumferential (clockwise &counter-clockwise). Supplement 4 of Appendix III adds an additionaI1/2-inch of base material for reflectors transverse to the weld (see Figure RR-67 for a pictorial representation).

Physical limitations due to the geometric configuration of the welded areas restricted coverage of the examination volume as required by Figure IWB-2500 8(c) and ASME Section XI Appendix III, Supplement 4. One piping weld with limitations is described in Table RR-67. Figure RR-67 shows coverage. The examinations were performed to the maximum extent possible. Appreciably increasing coverage was impractical due to the limitations described in the table.

Compliance would require replacement of the existing valve with a new valve fabricated with a special design to allow examination.

A surface examination (liquid penetrant technique) was performed on this weld.

The ultrasonic examinations were performed to Appendix III and consisted of primarily a single-sided examination from the pipe side of the weld. Based on the level of examination coverage obtained for the subject weld, if significant E5 - 1 Unit 1 Proposed Relief Request RR-67 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii) service-induced degradation were occurring, there is reasonable assurance that evidence of it would have been detected. In addition, VT-2 visual examinations associated with the Class 1 leakage test were performed each refueling outage.

These examinations and tests provide reasonable assurance of the structural integrity of this weld. Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of Proposed Relief Request:

The proposed relief request is applicable for the Third Interval.

Precedents:

The physical limitations described in this relief request are essentially identical to Farley-1 RR-50 for the third lSI interval which was approved by the NRC on November 7,2002.

References:

The NRC SER TAC No. for RR-50 is MB3776.

Status:

Awaiting NRC approval.

E5 - 2 Unit 1 Proposed Relief Request RR*67 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

TABLE RR-67 Identification No. I Exam.

History Description Limitation Coverage Examination Results ALA1-4103-4 1R15 (Fall 1998 Outage)

Valve to Pipe 100 % surface examination. Complete ultrasonic examination from the pipe side. Limited coverage for axial flaws from the valve side due to configuration. (100% coverage for circ flaws).

See Figure RR-67 for typical picture and coverage.

100% PT 90% UT No Recordable Indications E5 - 3 Unit 1 Proposed Relief Request RR-67 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

FIGURE RR-67 Access for Volumetric Examinations (1) Examination volume: Weld + Y<I" each side of weld toes.

(2) Examination volume: Weld + W' each side of weld toes for austenitic transverse scans.

E5 - 4

Joseph M. Farley Nuclear Plant - Units 1 and 2 Proposed Relief Requests for the Third lSI Interval Unit 1 Proposed Relief Request RR-68 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Unit 1 Proposed Relief Request RR-68 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Plant Site-Unit:

Farley Nuclear Plant - Unit 1.

Interval-Third lSI Interval - December 31,1997 through November 30,2007.

Interval Dates:

Requested Approval is requested by August 31,2009 in order to close-out the third lSI Date for interval activities.

Approval and Basis ASMECode Class 1, ASME Section XI Category B-A, Item B1.22 reactor pressure Components vessel (RPV) closure head welds, as shown in Table RR-68.

Affected:

Applicable ASME Section XI, 1989 Edition with no addenda.

Code Edition and Addenda:

Applicable ASME Item number B1.22 listed above for Table IWB-2500-1, Examination Code Category B-A, requires that the accessible length of each weld be Requirements:

examined for RPV closure head meridional welds. Even though only the accessible length was required for Item 81.22 welds, Code relief is being conservatively submitted by this relief request. Per Code Case N-460, coverage greater than 90% is acceptable. The examination volume is shown in ASME Section XI, Figure IWB-2500-3 for Item Number B1.22.

Impracticality Physical limitations due to the geometric configuration of the welded areas of Compliance:

restricted coverage of the examination volume as required by the figures.

Four RPV welds for Farley-1 are shown in Table RR-68. Appreciably increasing coverage was impractical due to the interferences described in Table RR-68.

Burden Obtaining more coverage would require replacement of the Farley-1 reactor Caused by pressure vessel head. This head was replaced during the 1R19 outage in Compliance:

Fall 2004.

Proposed The examination of these four welds was performed prior to the Alternative and implementation of the Appendix VIII process. A large percentage of the Basis for Use:

weld root was interrogated for these four welds and no ultrasonic indications exceeded the allowable flaw tables. In addition, VT-2 visual examinations were performed each refueling outage for these components.

It should also be noted that the Farley-1 RPV head was replaced during the 1R19 outage (Fall 2004) with a new design which removed all meridional welds. Based on these examination results plus the cumulative volumetric examination coverage of all RPV shell welds there is reasonable assurance E6 -1 Unit 1 Proposed Relief Request RR*68 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii) of structural integrity and relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of Proposed Relief Request:

The proposed relief request is applicable for the Third Interval.

Precedents:

Examinations prior to the required implementation of Supplements 4 and 6 were performed on the Farley-2 RPV shell and bottom head welds during the third lSI interval. The limitations were documented in Farley-2 relief request RR-56. The NRC granted approval by NRC SER letter dated May 19,2005.

References:

TAC No. MC2559 Status:

Awaiting NRC approval.

E6-2 Unit 1 Proposed Relief Request RR-68 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

TABLE RR-68 Weld Number I Examined ASME Item Coverage Basis for Limited Coverage ALA1-1300-1 Merid. Plate Weld (Top Head) 1R15 (Fall 1998 Outage) 81.22 59%

The UT examination of this meridional weld was limited by the proximity of RPV Shroud.

ALA1-1300-2 Merid. Plate Weld (Top Head) 1R15 (Fall 1998 Outage) 81.22 59%

The UT examination of this meridional weld was limited by the proximity of RPV Shroud.

ALA1-1300-3 Merid. Plate Weld (Top Head) 1R15 (Fall 1998 Outage) 81.22 59%

The UT examination of this meridional weld was limited by the proximity of RPV Shroud.

ALA1-1300-4 Merid. Plate Weld (Top Head) 1R15 (Fall 1998 Outage) 81.22 59%

The UT examination of this meridional weld was limited by the proximity of RPV Shroud.

E6 - 3

Joseph M. Farley Nuclear Plant - Units 1 and 2 Proposed Relief Requests for the Third lSI Interval Unit 1 Proposed Relief Request RR-69 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Plant Site Unit:

Interval Interval Dates:

Requested Date for Approval and Basis:

ASME Code Components Affected:

Applicable Code Edition and Addenda:

Applicable Code Requirements:

Impracticality of Compliance:

Burden Caused by Compliance:

Proposed Alternative and Basis for Use:

Unit 1 Proposed Relief Request RR-69 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

Farley Nuclear Plant - Unit 1.

Third lSI Interval - December 31, 1997 through November 30, 2007.

Approval is requested by August 31,2009 in order to close-out the third lSI interval activities.

Class 2, ASME Section XI Category C-F-2, Item C5.81, ferritic steel piping weld as shown in Table RR-69.

ASME Section XI, 1989 Edition with no addenda.

Examination Category C-F-2, Table IWC-2500-1, of the 1989 Edition of the ASME Section XI Code requires surface examination of branch connection pressure-retaining welds in Class 2 ferritic piping. Applicable examination surfaces are shown in ASME Section XI, Figure IWC-2500-9 and include essentially 100% of the weld length (see Figure RR-69 for a pictorial representation).

Physical limitations due to the close proximity of a welded support prevented full examination coverage of the weld as required by Figure IWC-2500-9. One carbon steel piping weld with limitations is described in Table RR-69. The examination was performed to the maximum extent possible. Appreciably increasing coverage was impractical due to the limitations described in the table.

Compliance would require replacement of the existing Main Steam piping with new components fabricated with a special design to allow examination.

A surface examination (magnetic particle technique) was performed on this weld. In addition, VT-2 visual examinations associated with the Class 2 leakage test are performed once every lSI period. These examinations and tests provide reasonable assurance of the structural integrity of this weld.

Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

E7 -1 Unit 1 Proposed Relief Request RR-69 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Duration of The proposed relief request is applicable for the Third Interval.

Proposed Relief Request:

Precedents:

The physical limitations described in this relief request are similar to Farley-1 RR 45 for the third lSI interval which was approved by the NRC on December 4, 2001. The Item No. (C5.81) in this relief request was not requested in RR-45; however, the process is similar.

References:

NRC SER TAC Nos. MB0796 and MB0797.

Status:

Awaiting NRC approval.

E7 - 2 Unit 1 Proposed Relief Request RR*69 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

TABLE RR-69 Identification No. I Exam.

History Description Limitation Coverage Examination Results AlA2-4101-12BC 1R16 (Spring 2000 Outage)

Branch Connection A limited surface examination (magnetic particle technique) was performed on this weld because of the close proximity of a welded support. See Figure RR-69 for a pictorial representation.

70%MT No Recordable Indications E7 - 3 Unit 1 Proposed Relief Request RR-69 Version 1.0, in Accordance with 10 CFR 50.55a{g)(5)(iii)

FIGURE RR-69 E7 - 4

Joseph M. Farley Nuclear Plant - Units 1 and 2 Proposed Relief Requests for the Third lSI Interval Unit 2 Proposed Relief Request RR-61 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Unit 2 Proposed Relief Request RR-61 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Plant Site-Unit:

Farley Nuclear Plant - Unit 2.

Interval Interval Dates:

Third 151 Interval - July 31, 2001 through July 30, 2011.

It should be noted that SNC submitted FNP-ISI-ALT-01, Version 1.0 to the NRC on October 8,2007 by letter NL-07-1612. This alternative would change the Farley-2 151 interval to coincide with Farley-1 which would result in the third 151 interval for Farley-2 starting on July 31, 2001 and ending on November 30, 2007 and the fourth 151 interval for Farley-2 starting on December 1, 2007 and ending on November 30, 2017. This relief request submittal is being made prior to the NRC approving Farley alternative FNP-ISI-ALT-01.

Requested Date for Approval and Basis:

Approval is requested by August 31, 2009 in order to close-out the third 151 interval as described above.

ASMECode Components Affected:

Southern Nuclear (SNC) developed the risk-informed 151 (RI-ISI) program for piping welds during the third 151 interval for Farley. SNC determined a scope from the Class 1 and 2 piping and prepared a technical alternative for NRC review. The NRC approved the technical alternative (see References) and RI 151 was implemented at Farley during the 2R16 outage in Spring 2004. The selected RI-ISI examinations are assigned ASME Category R-A per the Farley alternative. Farley has revised the original pipe weld numbers by adding an "

RI" suffix onto the weld numbers to distinguish them from the previous 151 weld number.

The affected components are Class 2, ASME Section XI Category R-A, ferritic steel piping welds as shown in Table RR-61.

Because of RI-ISI requirements, all welds on each associated piping segment were examined (100% sample size). Therefore, even if there are extreme limitations for a particular weld, a substitution cannot be made.

Applicable Code Edition and Addenda:

ASME Section XI, 1989 Edition with no Addenda plus NRC-approved technical alternative to implement risk-informed 151 for the examination of piping welds.

Applicable Code Requirements:

The Farley RI-ISI documentation including the technical alternative is used to determine the scope of the volumetric examinations. The examinations were performed after the required implementation of Supplement 3 of Appendix VIII.

The examination volumes typically follow ASME Section XI Figure IWC-2500 7(a) except that the volume was increased to include Yl!-inch beyond each side of the base metal thickness transition (or counterbore) to meet RI-ISI requirements.

E8 - 1

Impracticality of Compliance:

Burden Caused by Compliance:

Proposed Alternative and Basis for Use:

Duration of Proposed Relief Request:

Precedents:

References:

Status:

Unit 2 Proposed Relief Request RR-61 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Physical limitations due to the geometric configuration of the welded areas restricted coverage of the examination volume as required by Figure IWC-2500 7(a). The thirteen welds with limitations are described in Table RR-61 for Class 2 piping. The examinations were performed to the maximum extent possible.

Figure RR-61-1 shows a typical representation of a single-side access examination with a valve, along with limitations. The configuration of the branch connections is similar. Appreciably increasing coverage was impractical due to the limitations described in the table.

Compliance would require replacement of the existing valves and branch connections with new components fabricated with a special design to allow examination.

The ultrasonic examinations were performed after the implementation of Appendix VIII and consisted primarily of a single-sided examination from the carbon steel piping side due to the configuration. In general, the root area of each weld was interrogated with a shear wave looking for circumferential cracking. Because of RI-ISI requirements, 100% of the weld population of each segment was examined; therefore, a large amount of weld and base material was examined, with no recordable indications. In addition, VT-2 visual examinations are performed each lSI period for welds listed in Table RR-61.

With these examinations and tests there is reasonable assurance that the structural integrity is being maintained. Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

The proposed relief request is applicable for the Third Interval.

The physical limitations described in this relief request are essentially identical to Farley-2 RR-45 for the third lSI interval which was approved by the NRC on December 4, 2001. Since the UT examinations in this relief request were performed to Supplement 2 of Appendix VIII, the examination coverage is less than the typical pre-Appendix VIII examination coverage listed in RR-45.

NRC SER TAC Nos. MB0796 and MB0797. The NRC approved risk-informed lSI at Farley on March 9, 2004 by NRC TAC Nos. MC0178 and MC 0179.

Awaiting NRC approval.

E8 - 2 Unit 2 Proposed Relief Request RR-61 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR-61: Class 2 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results APR2-4103-2-RI 2R16 (Spring 2004 Outage) 3" Branch Connection to Pipe Post-POI examination. No examination coverage from the branch connection side due to the configuration. Coverage from the pipe side looking for circumferential cracking was limited to 65% due to the configuration. See Figure RR-61-1.

65% UT No Recordable Indications APR2-4103-5-RI 2R16 (Spring 2004 Outage) 3" Elbow to Valve Post-PDI examination. No examination coverage from the valve side due to the configuration. Coverage from the elbow side looking for circumferential cracking was limited to 65%

due to the configuration. See Figure RR-61-1.

65% UT No Recordable Indications APR2-4202-4-RI 2R16 (Spring 2004 Outage) 3" Elbow to Elbow Post-POI examination. A permanent box restraint limited all scans. The weld was examined for 100% coverage for 83%

of the length. See Figure RR-61-1.

83% UT No Recordable Indications APR2-4202-6-RI 2R16 (Spring 2004 Outage) 3" Pipe to Valve Post-POI examination. No examination coverage from the valve side due to the configuration. Additionally, a welded pipe clamp, 1" back from the toe of the weld on the pipe side limited scanning from the pipe side. See Figure RR-61-1.

50% UT No Recordable Indications APR2-4302-2-RI 2R17 (Fall 2005 Outage) 3" Branch Connection to Pipe Post-PDI examination. No examination coverage from the branch connection side due to the configuration. Coverage from the pipe side looking for circumferential cracking was limited to 83% due to the configuration. Coverage from the pipe side looking for axial cracking was limited to 50% due to the configuration. See Figure RR-61-1.

66.5% UT No Recordable Indications APR2-4302-6-RI 2R17 (Fall 2005 Outage) 3" Pipe to Valve Post-POI examination. No examination coverage from the valve side due to the configuration. Coverage from the pipe side looking for circumferential cracking was limited to 73%

due to the configuration. Coverage from the pipe side looking for axial cracking was limited to 50% due to the configuration.

See Figure RR-61-1.

61.5% UT No Recordable Indications APR2-4302-7-RI 3" Valve to Pipe Post-POI examination. No examination coverage from the valve side due to the configuration. Coverage from the pipe 70.5% UT No Recordable E8 - 3 Unit 2 Proposed Relief Request RR*61 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR*61: Class 2 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results 2R17 (Fall 2005 Outage) side looking for circumferential cracking was limited to 91 %

due to the configuration. Coverage from the pipe side looking for axial cracking was limited to 50% due to the configuration.

See Figure RR-61-1.

Indications APR2-4302-10-RI 2R17 (Fall 2005 Outage) 3" Pipe to Valve Post-POI examination. No examination coverage from the valve side due to the configuration. Coverage from the pipe side looking for circumferential cracking was limited to 87%

due to the configuration. Coverage from the pipe side looking for axial cracking was limited to 50% due to the configuration.

See Figure RR-61-1.

68.5% UT No Recordable Indications APR2-4101-31-RI 2R16 (Spring 2004 Outage) 6" Pipe to Valve Post-POI examination. This weld is located inside of a permanent box restraint. Scanning was limited to piping side at the corners of the box restraint. No examination coverage from the valve side due to the configuration. See Figure RR 61-1.

24% UT No Recordable Indications APR2-4101-32-RI 2R16 (Spring 2004 Outage) 6" Valve to Pipe Post-POI examination. No examination coverage from the valve side due to the configuration. Coverage from the pipe side looking for circumferential cracking was limited to 90%

due to the configuration. See Figure RR-61-1.

90% UT No Recordable Indications APR2-4101-33-RI 2R16 (Spring 2004 Outage) 6" Pipe to Valve Post-POI examination. No examination coverage from the valve side due to the configuration. Coverage from the pipe side looking for circumferential cracking was limited to 90%

due to the configuration. See Figure RR-61-1.

90% UT No Recordable Indications APR2-4201-23BC-RI 2R18 (Spring 2007 Outage) 6" Branch Connection Post-POI examination. Complete ultrasonic examination from the set-on branch connection side only due to configuration.

See Figure RR-61-2.

66.5% UT No Recordable Indications; two fabrications flaws recorded.

E8 - 4 Unit 2 Proposed Relief Request RR-61 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR-61: Class 2 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results APR2-4201-30-RI 2R18 (Spring 2007 Outage) 6" Pipe to Valve Post-PDI examination. No examination coverage from the valve side due to the configuration. Due to a restraint, coverage from the pipe side looking for circumferential cracking was limited to approximately 50% due to the configuration. Coverage looking for axial cracking was limited to approximately 74% due to the configuration. See Figure RR-61-1.

61% UT No Recordable Indications E8 - 5 Unit 2 Proposed Relief Request RR-61 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

FIGURE RR-61-1 Typical Single-Side Access for Volumetric Examinations Limited examination area (i.e., not all four-directional coverage) shown as hatched.

(1 )

Component PTpelElbow (1) Examination vOlume: Weld + W' each side of weld toes.

E8 - 6 Unit 2 Proposed Relief Request RR*61 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

FIGURE RR*61*2 FLOW

~

0.43 in PIPE BRANCH E8 -7

Joseph M. Farley Nuclear Plant - Units 1 and 2 Proposed Relief Requests for the Third lSI Interval Unit 2 Proposed Relief Request RR-62 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Unit 2 Proposed Relief Request RR*62 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Plant Site-Farley Nuclear Plant - Unit 2.

Unit:

Interval*

Third lSI Interval - July 31, 2001 through July 30, 2011.

Interval Dates:

It should be noted that SNC submitted FNP-ISI-ALT-01, Version 1.0 to the NRC on October 8,2007 by letter NL-07-1612. This alternative would change the Farley-2 lSI interval to coincide with Farley-1 which would result in the third lSI interval for Farley-2 starting on July 31,2001 and ending on November 30, 2007 and the fourth lSI interval for Farley-2 starting on December 1, 2007 and ending on November 30, 2017. This relief request submittal is being made prior to the NRC approving Farley alternative FNP-ISI-ALT-01.

Requested Approval is requested by August 31, 2009 in order to close-out the third lSI Date for interval as described above.

Approval and Basis:

ASMECode Southern Nuclear (SNC) developed the risk-informed lSI (RI-ISI) program for Components piping welds during the third lSI interval for Farley. SNC determined a scope Affected:

from the Class 1 and 2 piping and prepared a technical alternative for NRC review. The NRC approved the technical alternative (see References) and RI lSI was implemented at Farley during the 2R16 outage in Spring 2004. The selected RI-ISI examinations are assigned ASME Category R-A per the Farley alternative. Farley has revised the original pipe weld numbers by adding an ".

RI" suffix onto the weld numbers to distinguish them from the previous lSI weld number.

The affected components are Class 2, ASME Section XI Category R-A, austenitic steel piping welds as shown in Table RR-62.

Applicable ASME Section XI, 1989 Edition with no Addenda plus NRC-approved technical Code Edition alternative to implement risk-informed lSI for the examination of piping welds.

and Addenda:

Applicable The Farley RI-ISI documentation including the technical alternative is used to Code determine the scope of the volumetric examinations. The examinations were Requirements:

performed after the required implementation of Supplement 2 of Appendix VIII.

The examination volumes typically follow ASME Section XI Figure IWC-2500 7(a) except that the volume was increased to include ~-inch beyond each side of the base metal thickness transition (or counterbore) to meet RI-ISI requirements.

Impracticality Physical limitations due to the geometric configuration of the welded areas of restricted coverage of the examination volume as required by Figure IWC-2500 Compliance:

7(a). The five welds with limitations are described in Table RR-62 for Class 2 E9 - 1

Burden Caused by Compliance:

Proposed Alternative and Basis for Use:

Duration of Proposed Relief Request:

Precedents:

References:

Status:

Unit 2 Proposed Relief Request RR*62 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii) piping. The examinations were performed to the maximum extent possible.

Figure RR-62 shows a typical representation of a single-side access examination with a valve, along with limitations. The configuration of the branch connections is similar. Appreciably increasing coverage was impractical due to the limitations described in the table.

Compliance would require replacement of the existing valves and branch connections with new components fabricated with a special design to allow examination.

The ultrasonic examinations were performed after the implementation of Appendix VIII and consist of primarily a single-sided examination from the piping. The root area of the weld was interrogated with a 45° shear wave looking for circumferential cracking. In addition, VT-2 visual examinations are performed each lSI period for the weld listed in Table RR-62. These examinations and tests provide reasonable assurance of structural integrity of this weld. Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

The proposed relief request is applicable for the Third Interval.

The physical limitations described in this relief request are essentially identical to Farley-2 RR-45 for the third lSI interval which was approved by the NRC on December 4, 2001. Since the UT examinations in this relief request were performed to Supplement 2 of Appendix VIII, the examination coverage is less than the typical pre-Appendix VIII examination coverage listed in RR-45.

The NRC SER TAC Nos. are MB0797 and MB0797 for RR-45. The NRC approved risk-informed lSI at Farley on March 9, 2004 by NRC TAC Nos.

MC0178 and MC 0179.

Awaiting NRC approval.

E9-2 Unit 2 Proposed Relief Request RR-62 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR-62: Class 2 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results APR2-4503-23-RI 2R16 (Spring 2004 Outage)

Flange to Pipe Post-POI examination. Complete ultrasonic examination from the pipe side. No examination coverage from the flange side due to configuration. See Figure RR-62 for typical picture and coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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.

Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

50% UT No Recordable Indications APR2-4503-34-RI 2R16 (Spring 2004 Outage)

Pipe to Flange Post-POI examination. Complete ultrasonic examination from the pipe side. No examination coverage from the flange side due to configuration. See Figure RR-62 for typical picture and coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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.

Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

50% UT No Recordable Indications APR2-4509A-33-RI 2R16 (Spring 2004 Outage)

Valve to Pipe Post-POI examination. Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration. See Figure RR-62 for typical picture and coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic 50% UT 60° UT examination

- geometric indications.

E9-3 Unit 2 Proposed Relief Request RR-62 Version 1.0, in Accordance with 10 CFR 50.55a(g)(5)(iii)

Table RR-62: Class 2 Piping Welds Identification No. I Exam. History Description Limitation Coverage Examination Results 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.

Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

APR2-4509A-36-RI 2R18 (Spring 2007 Outage)

Pipe to Valve Post-POI examination. Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration. See Figure RR-62 for typical picture and coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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.

Since POI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

50% UT No Recordable Indications APR2-4511-2-RI 2R18 (Spring 2007 Outage)

Pipe to Valve Post-POI examination. Complete ultrasonic examination from the pipe side. No examination coverage from the valve side due to configuration. See Figure RR-62 for typical picture and coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when 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.

Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

50% UT 60 0 UT examination

- geometric indications.

E9 -4 Unit 2 Proposed Relief Request RR-62 Version 1.0, in Accordance with 10 CFR SO.SSa(g)(S)(iii)

FIGURE RR-62 Typical Single-Side Access for Volumetric Examinations Limited examination area (i.e., not all four-directional coverage) shown as hatched.

Pipe/Elbow I

(2)

(1)

(2)

~- --

(1) Examination volume: Weld + 14" each side of weld toes.

(2) Additional volume: + W' each side for RI-ISI.

Component I

E9 - 5