PNP 2016-052, Relief Request Number RR 4-25 Impracticality - Limited Coverage Examinations During the Fourth 10-year Inservice Inspection Interval

Relief Request Number RR 4-25 Impracticality - Limited Coverage Examinations During the Fourth 10-year Inservice Inspection Interval

ML16335A032
Person / Time
Site:	Palisades
Issue date:	11/30/2016
From:	Hardy J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2016-052
Download: ML16335A032 (35)

Text

• ~ Entergy Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000 Jeffery A. Hardy Regulatory Assurance Manager PNP 2016-052 November 30,2016 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001

SUBJECT:

Relief Request Number RR 4-25 Impracticality - Limited Coverage Examinations During the Fourth 10-year Inservice Inspection Interval Palisades Nuclear Plant Docket 50-255 Renewed Facility Operating License No. DPR-20

Reference:

1. Nuclear Management Company, LLC letter to Nuclear Regulatory Commission, 4th Intervallnservice Inspection Plan, dated June 12, 2006 (ADAMS Accession Number ML061710302)

Dear Sir or Madam:

Pursuant to Title 10 of the Code of Federal Regulations (CFR) 50.55a(g)(6)(i), Entergy Nuclear Operations, Inc. (ENO) hereby requests Nuclear Regulatory Commission (NRC) authorization for the Palisades Nuclear Plant (PNP) of relief request number RR 4-25 for limited coverage examinations during the fourth 10-year inservice inspection (lSI) interval.

Pursuant to 10 CFR 50.55a(g)(5)(iii) the basis for the determination of impracticality is being submitted to the NRC within 12 months after the expiration of the 120-month inspection interval.

The fourth 10-year inservice inspection (lSI) interval ended on December 12, 2015 and complied with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPV),Section XI , 2001 Edition through the 2003 Addenda (Reference 1).

The attached relief request identifies weld locations for which less than the required examination coverage was obtained due to interference or geometry. The information provided in the attachment demonstrates the limitations experienced, at each weld location, when attempting to comply with the code required examination coverage.

Summary of Commitments This letter contains no new commitments and no revised commitments.

~Bf JAH/jpm

PNP 2016-052 Page 2 of 2

Enclosure:

10 CFR 50.55a, Relief Request Number RR 4-25, Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii), Inservice Inspection Impracticality cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

PNP 2016-052 ENCLOSURE 10 CFR 50.55a Relief Request Number RR 4-25 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality 32 pages follow

PNP 2016-052 ENCLOSURE 10 CFR 50.55a Relief Request Number RR 4-25 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. American Society of Mechanical Engineers (ASME) Code Component(s) Affected The welds and components with limited examinations included this relief request, RR 4-25, are identified in Table 1 below.

Table 1 Examination Item Category Number (No.) Component Identification (10) Code Class 8-A 81.11 RPV Circumferential Weld 10-112 1 8-8 82.12 PZR Weld 2-982A 1 8-J 89.11 ESS-12-SIS-1A 1-10 1 8-J 89.11 ESS-12-SIS-181-13 1 8-J 89.11 ESS-12-SIS-181-14 1 8-J 89.11 ESS-6-SIS-1 A 1-13 1 8-J 89.11 ESS-6-SIS-1 81-14 1 8-J 89.31 PCS-30-RCL-1 8-10/12 1 8-J 89.31 PCS-42-RCL-1 H-3/12 1 8-K 810.30 1A-S-A 1 8-K 810.30 1A-S-8 1 8-K 810.30 1A-S-C 1 8-K 810.30 1A-S-D 1 8-L-1 812.10 18-02 1 R-Al R1.11 PCS-4-PRS-1 P2-3 1 R-Al R1.11 PCS-4-PRS-1 P2-4 1 R-Al R1.16 ESS-6-SIS-181-13 1 1 Entergy Nuclear Operations, Inc. (ENO) implemented at Palisades Nuclear Plant (PNP) a risk informed program in accordance with Code Case N-716-1 in the third period of the 4th interval (Reference 5).

Unit/Inspection Interval: Palisades Nuclear Plant (PNP) 1 Fourth 10-Year lSI Interval December 13, 2006 - December 12, 2015

2. Applicable Code Edition and Addenda

The code of record for the fourth 10-year inservice inspection (lSI) interval at the Palisades Nuclear Plant (PNP) is the 2001 Edition through the 2003 Addenda of the ASME 80iler and Pressure Vessel Code (8PV),Section XI, Rules for Inservice Inspection of Nuclear Power Page 1 of 32

PNP 2016-052 ENCLOSURE 10 CFR SO.SSa Relief Request Number RR 4-2S Relief Request in Accordance with 10 CFR SO.SSa(g)(S)(iii)

Inservice Inspection Impracticality Plant Components, as conditioned by 10 CFR SO.SSa. The Appendix VIII, Supplement 11, Qualification Requirements for Full Structural Overlaid Wrought Austenitic Piping Welds, requirements and use of the performance demonstration initiative (POI) requirements at PNP are in accordance with the 2001 Edition of Section XI as conditioned by 10 CFR SO.SSa(b)(2).

Additionally, the PNP Code of Record is supplemented by the following ASME Section XI Code Cases as required and modified by 10 CFR SO.SSa(g)(6)(ii)(O), SO.SSa(g)(6)(ii)(E), and SO.SSa(g)(6)(ii)(F):

• Code Case N-729-1 , Alternative Examination Requirements for PWR Reactor Vessel Upper Heads with Nozzles Having Pressure-Retaining Partial Penetration WeldsSection XI, Division 1

• Code Case N-722-1, Additional Examinations for PWR Pressure Retaining Welds in Class 1 Components Fabricated with Alloy 6001821182 MaterialsSection XI, Division 1

• Code Case N-770-1, Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated with UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation ActivitiesSection XI, Division 1

3. Applicable Code Requirement

Throughout this request, as clarified by Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 WeldsSection XI, Division 1, when "essentially 100%" is stated it is understood to mean greater than 90% coverage of the required examination volume, or surface area, as applicable.

Examination Category: B-A, Pressure Retaining Welds in Reactor Vessel Table IWB-2S00-1, Examination Category B-A, Item No. B1.11 requires a volumetric examination depicted in Figure IWB-2S00-1 for essentially 100% of the weld area.

Examination Category B-B. Pressure Retaining Welds in Vessels Other than Reactor Vessels Table IWB-2S00-1, Examination Category B-B, Item No. B2.12 requires a volumetric examination depicted in Figure IWB-2S00-2 for essentially 100% of the weld area.

Examination Category: B-J. Pressure Retaining Welds in Piping Table IWB-2S00-1, Examination Category 8-J, Item No. B9.11 requires a volumetric and surface examination of the volumes and surfaces depicted in Figure IWB-2S00-8 for essentially 100% of the weld area.

Page 2 of 32

PNP 2016-052 ENCLOSURE 10 CFR 50.55a Relief Request Number RR 4-25 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality Table IWB-2500-1, Examination Category B-J, Item No. B9.31 requires a volumetric and surface examination of the volumes and surfaces depicted in Figure IWB-2500-9, -10, and -11 for essentially 100% of the weld area.

Note: Code Case N-663 (Reference 3) has been applied, eliminating the surface examinations required by Table IWB-2500-1, Examination Category B-J, Item Nos. B9.11 and B9.31.

Examination Category: B-K. Welded Attachments for Vessels. Piping. Pumps, and Valves Table IWB-2500-1, Examination Category B-K, Item No. B10.30 requires a surface examination as depicted in Figure IWB-2500-13, -14, and -15 for essentially 100% of the weld area.

Examination Category: B-L-1. Pressure Retaining Welds in Pump Casings Table IWB-2500-1, Examination Category B-L-1, Item No. B12.10 requires a VT-1, Visual examination, of the weld surfaces depicted in Figure IWB-2500-16 for essentially 100% of the weld area.

Note: Examination Category B-L-1 does not require a surface examination for component 10 1B-02.

Examination Category: R-A, from Code Case N-716-1 (Reference 4)

Code Case N-716-1, Table 1, Examination Category R-A, Item Nos. R1.11 and R1.16 require a volumetric examination of the volumes depicted in Figures IWB-2500-8(c) and IWB-2500-9, 10, and 11 with the additional requirements from the table's applicable notes as described below:

Item Nos. R1.11 and R1.16:

Note 1: The area of the examination volume shown in Figure IWB-2500-8(c) shall be increased by enough distance [approximately ~ inch] to include each side of the base metal thickness transition or counter bore transition.

Note 3: In part, requires essentially 100% of the examination location to be examined.

Item No. R1.16:

Note 7: In accordance with the Owner's existing programs, such as primary water stress corrosion cracking (PWSCC), intergranular stress corrosion cracking (IGSCC),

microbiological induced corrosion (MIC), or flow-accelerated corrosion (FAC) inspection programs, for degradation mechanisms as described in Table 2 of the Code Case.

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PNP 2016-052 ENCLOSURE 10 CFR 50.55a Relief Request Number RR 4-25 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality Note: Examination Category R-A, Item Nos. R1.11 and R1.16, Code Case N-716-1 also does not require a surface examination.

4. Impracticality of Compliance 10 CFR 50.55a(g)(5)(iii) states, in part, that licensees may determine that conformance with certain code requirements is impractical and that the licensee shall notify the U.S. Nuclear Regulatory Commission (NRC or Commission) and submit information in support of the determination. Determination 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 120-month inspection interval or subsequent 120-month inspection interval for which relief is sought.

Pursuant to 10 CFR 50.55a(g)(5)(iii) described above, relief is requested because ENO has determined that compliance with the code requirements of achieving essentially 100%

coverage of the welds and items listed in this request is impractical. This determination is based on actual demonstrated limitations experienced when attempting to comply with the code requirements in the performance of the examinations listed in this relief request.

The construction permit for PNP was issued on March 14, 1967, before the effective date of implementation for ASME Section XI, thus the plant was not designed to meet the requirements for lSI. Details for all examination access restrictions and reductions in required examination coverage are provided in Attachment 1.

When examined, the welds and items listed in this relief request did not receive the required code coverage due to their access restrictions and/or design configurations. These conditions resulted in limitations that prohibited obtaining essentially 100% examination coverage of the required examination volume or area, but when this situation occurred, 100%

of the accessible volume of the welds and items were examined.

Examination Category: 8-A. Pressure Retaining Welds in Reactor Vessel Item No. 81.11

• RPV Circumferential Weld 10-112 is a Class 1, pressure retaining reactor vessel lower shell to lower head circumferential weld. Exam is limited due to interference with the reactor vessel core stabilizing lugs, core stop lugs and flow skirt.

Examination Category: 8-8. Pressure Retaining Welds in Vessels Other than Reactor Vessels Item No. 82.12

• PZR Weld 2-982A is a Class 1, primary coolant system (PCS), pressure retaining vessel weld, lower shell long seam located at 300 degrees in the pressurizer. The Page 4 of 32

PNP 2016-052 ENCLOSURE 10 CFR SO.SSa Relief Request Number RR 4-2S Relief Request in Accordance with 10 CFR SO.SSa(g)(S)(iii)

Inservice Inspection Impracticality examination is limited to 8 inches from the shell bevel to the proximity of the permanent insulation.

Examination Category: B-J. Pressure Retaining Welds in Piping Item No. B9.11

• EES-12-SIS-1A1-10, ESS-12-SIS-1B1-13, and ESS-12-SIS-1B1-14 are Class 1, nominal pipe size (NPS) 12 welds in the low pressure safety injection (LPSI) system connecting a stainless steel tee to a stainless steel valve. Due to the configuration of the valve and the product form of the valve, examination is limited to single-sided from the tee side only.

• ESS-6-SIS-1A1-13 is a Class 1, NPS 6 weld in the LPSI system connecting a stainless steel Tee to a stainless steel elbow. Due to the configuration of the tee, examination is limited to single-sided from the elbow side only.

• ESS-6-SIS-1 B1-14 is a Class 1, NPS 6 weld in the LPSI system connecting a stainless steel pipe to a stainless steel Tee. Due to the configuration of the tee, examination is limited to single-sided from the pipe side only.

Examination Category: B-J. Pressure Retaining Welds in Piping Item No. B9.31

• PCS-30-RCL-1 B-1 0/12 is a Class 1, NPS 12 to NPS 30 branch connection weld in the cold leg of the PCS. The examination is limited due to the configuration and the permanent insulation obstructions.

• PCS-42-RCL-1H-3/12 is a Class 1, NPS 12 to NPS 42 branch connection weld in the hot leg of the PCS. The examination is limited due to the configuration and the permanent insulation obstructions.

Examination Category: B-K. Welded Attachments for Vessels. Piping, Pumps, and Valves Item No. B10.30

• 1A-S-A, 1A-S-B, 1A-S-C, and 1A-S-D are welded supports on the P-SOA, primary coolant pump casing. The welded sides of the supports are inaccessible to due permanent insulation obstructions.

Examination Category: B-L-1, Pressure Retaining Welds in Pump Casings Item No. B12.10 Page S of 32

PNP 2016-052 ENCLOSURE 10 CFR 50.55a Relief Request Number RR 4-25 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

• 1B-02 is a Class 1 pump case weld in P-50B, Primary Coolant Pump. The examination surface area is limited due to interference from permanent insulation support structure, grating, adjacent piping, and a radiological hot spot.

Examination Categorv: R-A Item No. R 1.11

• PCS-4-PRS-1 P2-3 and PCS-4-PRS-1 P2-4 are Class 1, NPS 4 welds in the PCS connecting a pipe to a fitting. The welds are identified by the N-716-1 (Reference 4) risk informed program as high safety significant (HSS) with a degradation mechanism of thermal transients (IT). The examination is limited to single-sided due to the configuration of the fitting.

Examination Category: R-A Item No. B1.16

• ESS-6-SIS-1 B1-13 is a Class 1, NPS 6 weld in the LPSI system connecting an elbow to a pipe. The weld is identified by the N-716-1 (Reference 4) risk informed program as HSS with a degradation mechanism of IGSCC. Examination is limited due the configuration of the elbow.

5. Burden Caused by Compliance To obtain the code required examination volume or coverage of the subject welds would require significant modifications to PNP welded components and fittings. The components and fittings associated with the subject welds are standard design items meeting typical national standards that specify required configurations and dimensions. To replace these items with items of alternate configurations to enhance examination coverage would require unique design and fabrication. Because these items are in the Class 1 boundaries and form part of the PCS pressure boundary, their redesign and fabrication would be an extensive effort. In addition to obtaining the non-standard items, their installation into the Class 1 boundaries is also a significant effort requiring disassembly of portions of the PCS boundary.

Radiographic Testing (RT) is not a desired option because RT is limited in the ability to detect service induced flaws. Additionally, the water must be drained from the systems where radiography is performed. This increases operational risk through prolonged system restoration times and increased station exposure due to increased general radiation dose rates over a much broader area than in the area of the weld being examined.

Overall, it is not possible to obtain examination coverage of greater than 90% of the required code examination volume or area for the welds and items in this request without extensive design modifications. Examinations have been performed to the maximum extent possible.

The examination techniques used for each weld or item in this relief request were reviewed to determine if additional coverage could be achieved by improving those techniques, and none Page 6 of 32

PNP 2016-052 ENCLOSURE 10 CFR SO.SSa Relief Request Number RR 4-2S Relief Request in Accordance with 10 CFR SO.SSa(g)(S)(iii)

Inservice Inspection Impracticality could be identified, thus reconfirming that the examinations have been performed to the maximum extent possible. Therefore, ENO has determined that obtaining essentially 100%

coverage is not feasible and is impractical without adding the additional burdens consisting of significant redesign work, increased radiation exposure, and/or an increased potential to damage the plant or the component itself.

6. Proposed Alternative and Basis for Use Proposed Alternative In lieu of the ASME BPV Section XI essentially 100 percent volumetric examination, ENO proposes limited examination coverage for the subject welds achieved by ultrasonic testing (UT), surface liquid penetrant testing (PT), or visual testing (VT) as listed in Attachment 1.

Basis for Use ENO performed inservice examinations of selected welds and items in accordance with the requirements of 10 CFR SO.SSa, plant technical specifications, and the ASME BPV Section XI, 2001 edition through the 2003 Addenda, including Appendix VIII requirements in accordance with the 2001 edition of Section XI and applicable POI requirements. When a component was found to have condition(s), which limit the examination volume, ENO is required to submit this information to the enforcement and regulatory authorities having jurisdiction at the plant site. This relief request has been written to address areas where these conditions exist and where the required amount of coverage is reduced below that required by ASME BPV Section XI and the NRC.

10 CFR SO.SSa(g)(4) recognizes that throughout the service life of a nuclear power facility, components which are classified as ASME Code Class 1, Class 2, and Class 3 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 described in Attachment 1.

ENO performed the examinations to the extent possible. There is no plant-specific or known industry operating experience regarding failure of welds in similar service.

The welds subject to this request are located within the reactor containment building. During outages, system engineers perform walk-downs of systems inside containment. This walk-down is performed to look for evidence of boron accumulation as well as system abnormalities that could affect plant performance. Also, an ASME BPV Section XI system pressure test and VT-2 (visual testing), is performed each refueling outage.

PCS leakage is limited by PNP Technical Specifications Section 3.4.13, pes Operational Leakage, to no pressure boundary leakage, 1 gpm of unidentified leakage and 10 gpm of identified leakage.

All inservice examinations were performed by personnel certified in accordance with IWA-2300, Qualifications of Nondestructive Examination Personnel, of the 2001 Edition with Page 7 of 32

PNP 2016-052 ENCLOSURE 10 CFR 50.55a Relief Request Number RR 4-25 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality the 2003 Addenda of the ASME 8PV Section XI Code. Additionally, personnel performing ultrasonic examination are qualified in accordance with ASME 8PV Section XI, Appendix VIII, of the 2001 Edition as conditioned by 10 CFR 50.55a.

The UT techniques for each weld were reviewed to determine if additional coverage could be achieved. PNP's procedures require the examiner to make an attempt to achieve complete coverage by using alternative techniques such as using a smaller transducer wedge thus reducing the distance from the exit point to the front of the wedge, changing angles or reducing the search unit element size. Any alternative equipment is required to be in compliance with the limits specified in the qualified procedure. Alternate techniques were investigated at the time when it was discovered that essentially 100% coverage could not be obtained.

For welds in austenitic materials examined in accordance with Appendix VIII, Supplement 2, Qualification Requirements for Wrought Austenitic Piping Welds, the ASME code required examination coverage is limited when the weld can only be scanned in the axial direction from one side. Therefore, Attachment 1, Table 1 only reports code coverage.

The Performance Demonstration Qualification Summary (PDQS) for the qualified Electric Power Research Institute (EPRI) procedure, PDI-UT-2, POI Generic Procedure for the Ultrasonic Examination of Austenitic Pipe Welds POI-UT-2, in part states, the austenitic single side qualification documented on this summary demonstrates application of best available technology, but do not meet the requirements of 10 CFR 50.55a(b)(2)(xvi)(8). It should be noted that UT was performed through the weld to obtain the maximum possible code examination volume and, as shown in Attachment 1, the theoretical beam path extends into the far side for the examinations performed. While the coverage is not included in the code coverage of Attachment 1, Table 1, the techniques employed for the single side examination are noted as a best effort examination in the examination coverage summary for each individual weld. The coverage obtained was the maximum practical. Therefore, the UT examinations conducted using the Appendix VIII, Supplement 2, qualified procedure, provide reasonable assurance for the detection of flaws on the far side of welds where the ultrasonic beam has been transmitted even though not presently qualified.

For Component 10 18-02, which is P-508, primary coolant pump, pump casing weld in Examination Category 8-L-1, it is noted that this Examination Category was deleted in the 2008 Addenda of ASME Section XI, which is also approved in 10 CFR 50.55a without any stated conditions. Examination of Component ID 18-02 will not be required in the successive interval.

7. Duration of Proposed Alternative This relief request is applicable to the PNP Fourth 10-year lSI Interval which began on December 13, 2006 and ended on December 12,2015.

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PNP 2016-052 ENCLOSURE 10 CFR 50.55a Relief Request Number RR 4-25 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

8. Precedents Industry requests for relief due to impracticality associated with limited examinations are common and are typically filed by licensees. Examples of recent NRC relief request authorizations that are in accordance with the guidance in Reference 1 are:

1. NRC letter to Duke Energy Carolinas, LLC, Oconee Nuclear Station, Units 1, 2, and 3 -

Relief from the Requirements of the ASME Code (Relief Request Nos. 15-0N-002 and 15-0N-003, Fourth 10-Year Inservice Inspection Interval) (CAC Nos. MF6506, MF6507, and MF6511), dated July 22, 2016 (ADAMS Accession Number ML16197A011)

2. NRC letter to Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 2 and 3 - Request 14R-17 Relief from the Requirements of the ASME Code (CAC Nos.

MF3352 AND MF3353), dated October 30, 2015 (ADAMS Accession Number ML15265A164)

3. NRC letter to PSEG Nuclear, LLC, Salem Nuclear Generating Station, Unit No.2 - Relief from the Requirements of the ASME Code (TAC No. MF4591), dated July 28,2015 (Adams Accession Number ML15195A495)

9. References

1. NRC presentation, Coverage Relief Requests NDEIC-January 13-15, 2015, dated January 13, 2015, (Adams Accession Number ML15013A266)

2. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1

3. American SOCiety of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI , Code Case N-663, Alternative Requirements for Classes 1 and 2 Surface Examinations,Section XI, Division 1

4. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, Code Case N-716-1 , Alternative Piping Classification and Examination Requirements,Section XI, Division 1

5. Entergy Nuclear Operations, Inc., letter to the NRC, Palisades - Notification of Intent to Utilize ASME Code Case N-716-1, dated September 9,2015 (ADAMS Accession Number ML15253A003)

10. Attachment Attachment 1: Examination Limitation Details Page 9 of 32

PNP 2016-052 ENCLOSURE 10 CFR 50.55a Relief Request Number RR 4-25 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality ATTACHMENT 1 Examination Limitation Details Page 10 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details

1. Introduction This attachment contains a table (Table 1), and figures (Figures A through Y) that are used to depict the limitations and calculations for obtained coverage, materials and product forms, with ultrasonic examination angles and wave forms used, and the examination results for the welds and items associated with this relief request.

Table 1 Component Information Exam Item No. Component ID Item Material 1 Material 2 Examination Examination Limitations and Results Cat Description and Product and Product Code Coverage Form Form Obtained 8-A 81.11 RPV Reactor SA-302-8 SA-302-8 UT = 77.72% RPV Circumferential Weld 10-112 is a Class 1, Circumferential Pressure Plate Plate pressure retaining reactor vessel lower shell to Weld 10-112 Vessel shell lower head circ weld. Exam is limited due to Circ weld to interference with the core stabilizing lugs, core boHom head stop lugs and flow skirt. The 45L and 45S (Fig, A and 8) degree axial scans recorded 2 indications.

8-8 82.12 PZRWeld Pressurizer A-533 Gr. 8 A-533 Gr. 8 UT=66.6% PZR Weld 2-982A is a Class 1, primary coolant 2-982A Lower Shell CI. 1 CI. 1 system, pressure retaining vessel weld, lower Long Weld at Plate Plate shell long seam, located radially at 300 degrees.

300 Deg Exam is limited to 8 inches from the shell bevel to (Fig. C) the proximity of the permanent insulation. No recordable indications.

8-J 89.11 ESS-12-SIS- Tee to Valve ASTM A- 18-8 SMO UT= 50% ESS-12-SIS-1 A 1-10 is a Class 1, nominal pipe 1A1-10 CK3101 403, WP-316 Valve size (NPS) 12 weld in the low pressure safety (Fig. D) or ASTM A- injection system connecting a stainless steel Tee 182, F-316 to a stainless steel valve. Due to the FiHing configuration of the valve and the product form of the valve, examination is limited to single-sided from the Tee side only. No recordable indications.

Page 11 of 32

PNP 2016-052 ENCLOSURE ATT ACHMENT 1 Examination Limitation Details Table 1 Component Information Exam Item No. Component 10 Item Material 1 Material 2 Examination Examination Limitations and Results Cat Description and Product and Product Code Coverage Form Form Obtained 8-J 89.11 ESS-12-SIS- Valve CK3117 18-8 SMO ASTM A-403, UT = 50% ESS-12-SIS-181-13 is a Class 1, NPS 12 weld in 181-13 to Tee Valve WP-316 or the low pressure safety injection system (Fig. E) ASTM A-182, connecting a stainless steel Tee to a stainless F-316 steel valve. Due to the configuration of the valve Fitting and the product form of the valve, examination is limited to single-sided from the Tee side only. No recordable indications.

8-J 89.11 ESS-12-SIS- Tee to Valve ASTM A- 18-8 SMO UT= 50% ESS-12-SIS-181-14 is a Class 1, NPS 12 weld in 181-14 CK3116 403, WP-316 Valve the low pressure safety injection system (Fig. F) or ASTM A- connecting a stainless steel Tee to a stainless 182, F-316 steel valve. Due to the configuration of the valve Fitting and the product form of the valve, examination is limited to single-sided from the Tee side only. No recordable indications.

8-J 89.11 ESS-6-SIS- Elbow to Tee ASTM A- ASTM A-403, UT= 50% ESS-6-SIS-1 A1-13 is a Class 1, NPS 6 weld in 1A1-13 (Fig. G) 403, WP-316 WP-316 or the low pressure safety injection system or ASTM A- ASTM A-182, connecting a stainless steel Tee to a stainless 182, F-316 F-316 steel elbow. Due to the configuration of the Tee, Fitting Fitting examination is limited to single-sided from the elbow side only. No recordable indications.

8-J 89.11 ESS-6-SIS- Pipe to Tee A-376. Type A-403, WP- UT= 50% ESS-6-SIS-181-14 is a Class 1, NPS 6 weld in 181-14 (Fig. H) 316 316 or A-182, the low pressure safety injection system Pipe F-316 connecting a stainless steel pipe to a stainless Fitting steel Tee. Due to the configuration of the Tee, examination is limited to single-sided from the pipe side only. No recordable indications.

8-J 89.31 PCS-30-RCL- 8ranch SA-264 clad SA-508-64, UT = 68% PCS-30-RCL-18-10/12 is a Class 1, NPS 12 to 18-10/12 Connection with CL 1. NPS-30 branch connection weld in the cold leg of (Fig. I) stainless Forging the primary coolant system. The examination is steel limited due to the configuration and permanent Pipe insulation obstructions. No recordable indications.

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PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Table 1 Component Information Exam Item No. Component 10 Item Material 1 Material 2 Examination Examination Limitations and Results Cat Description and Product and Product Code Coverage Form Form Obtained 8-J 89.31 PCS-42-RCL- 8ranch SA-264 clad SA-508-64, UT= 85% PCS-42-RCL-1 H-3/12 is a Class 1, NPS 12 to 1H-3/12 Connection with CL 1. NPS 42 branch connection weld in the hot leg of (Fig. J) stainless Forging the primary coolant system. The examination is steel limited due to the configuration and permanent Pipe insulation obstructions. No recordable indications.

8-K 810.30 1A-S-A Welded Pump ASTM A-351 Not Specified PT=83% 1A-S-A is a welded support on the P-50A primary Support Gr. CFM8 coolant pump casing. The welded sides of (Fig. K) Ann. support are inaccessible to due permanent Pump Case insulation obstructions. No recordable indications.

8-K 810.30 1A-S-8 Welded Pump ASTM A-351 Not Specified PT=58% 1A-S-8 is a welded support on the P-50A primary Support Gr. CFM 8 coolant pump casing. The welded sides of (Fig. L) Ann. support are inaccessible to due permanent Pump Case insulation obstructions. No recordable indications.

8-K 810.30 1A-S-C Welded Pump ASTM A-351 Not Specified PT=83% 1A-S-C is a welded support on the P-50A primary Support Gr. CFM 8 coolant pump casing. The welded sides of (Fig. M) Ann. support are inaccessible to due permanent Pump Case insulation obstructions. No recordable indications.

8-K 810.30 1A-S-D Welded Pump ASTM A-351 Not Specified PT=58% 1A-S-D is a welded support on the P-50A primary Support Gr. CFM8 coolant pump casing. The welded sides of (Fig. N) Ann. support are inaccessible to due permanent Pump Case insulation obstructions. No recordable indications.

8-L-1 812.10 18-02 Pump Casing ASTM A-351 ASTM A-351 VT-1 = 14% 18-02 is a Class 1 pump case weld in primary Welds Gr. CFM 8 Gr. CFM 8 coolant pump P-508. The examination surface (Fig. 0) Ann. Ann. area is limited due to interference from Pump Case Pump Case permanent insulation support structure, grating, adjacent piping, and a radiological hot spot. No recordable indications.

Page 13 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Table 1 Component Information Exam Item No. Component 10 Item Material 1 Material 2 Examination Examination Limitations and Results Cat Description and Product and Product Code Coverage Form Form Obtained R-A R1 .11 PCS-4-PRS- Pipe to Fitting ASME ASME UT= 50% PCS-4-PRS-1 P2-3 is a Class 1, NPS 4 weld in 1P2-3 (Fig. P) SA-376, SA-182, the primary coolant system connecting a pipe to Type 316 F-316 a fitting. The welds are identified by ASME code Pipe Flange case N-716-1 risk informed program as High Safety Significant (HSS) with a degradation mechanism of thermal transients (TT). The examination is limited to single-sided due to the configuration of the fitting. No recordable indications.

R-A RU1 PCS-4-PRS- Fitting to Pipe ASME ASME UT= 50% PCS-4-PRS-1 P2-4 is a Class 1, NPS 4 weld in 1P2-4 (Fig. Q) SA-182, SA-376, the primary coolant system connecting a pipe to F-316 Type 316 a fitting. The welds are identified by the ASME Flange Pipe code case N-716-1 risk informed program as HSS with a degradation mechanism of TT. The examination is limited to single-sided due to the configuration of the fitting. No recordable indications.

R-A RU6 ESS-6-SIS- Elbow to Pipe ASTMA- ASTM A-376 UT=80% ESS-6-SIS-1B1-13 is a Class 1, NPS 6 weld in 1B1-13 (Fig. R) 403, WP-316 Type 316 the low pressure safety injection system or ASTM Pipe connecting an elbow to pipe. The weld is A-182, F-316 identified by ASME code case N-716-1 risk Fitting informed program as HSS with a degradation mechanism of IGSCC. Examination is limited due the configuration of the elbow. Axial scans located radially at 60 and 70 degrees recorded indications of root geometry.

Page 14 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure A Examination Category: B-A Item No. B1.11 Component 10: RPV Circumferential Weld 10-112 (#4 below)

LIJIlI> I L[JDP 2 1.0!J' 2B I.CD' IA

[JuTL£T lit OUTL£l M2 INLE1.3 INLE1 ~~

o* v'"

~======~===t=:~========u=~~N:OY=*='==4===~=y~**~..~PL====~Tr~IL,~-,~~~

180' 240' 300' PI

1. 1 2'.66 7~. SO

-I-Hl--+-tJ-tf-+iE-+-lr-f-I-Htl--f-- --L.

133.72

1. 2  !

~'J 30' 231.03 .

I 13$.011

1. 3 III 270' l2Ul

1. 4 PALISADES - (CPAL 1) 201~ £XAM1NATI~ PROGRAM P,-AN VESSEl ROLLOUT I 101[5D YI'~r I =--=--.:.11 OF 2PI Page 15 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure B Examination Category: B-A Item No. B1.11 Component 10: RPV Circumferential Weld 10-112 SC.~N WillS " fl(MjD W(;S P ** peor.dO<;ul.r Scon$ ~ /- 7' from Blob-til;ng Lug Ii.

..-- CORr; STABI!lZIH(; ~UG PerpMCflCuiar !ican. T /- J 5' (,om 6UPPOr, Lug ~

" 0' , !>!f, t2~' Poroll. 5"",. +1- &' from .taltillzlng LU9 ~

1W, U!)' 305' (oorolle' SCcns + /- 5' from .... ppor1 LUQ It Nat.: Perform scons beh"~O I.u¢ fir.'

then expend ,:~an. Dbovc ond ~C.

Lug£. to tnQ).lmizB tQvC'roge 32< ., (71 1.5') BOnD'" FtRPE"L'>C\JI.4~ .. 90'-£ SI.PPORT LUes

~~~§~:~; (7fUlO') rop PARIII. EI. BElO\'( STASI ,111'lC LUCS

"==::-1r

~ 55 (76. i A ') BonO~t Pl<AAlI.l:.L ABOVE Su~l>ORl LU~

~9 (7!> 'S) TOO Ptllp[r~OICUL.J,k B[~W STABILIZINC LUGS

"1'O.S5 (72 40') BOTTOM PARA!,t.i;L 9'7 (7342') Dono,", PlRPENOICUUoR

~~~Ullo~'------------------------

AddllOtlal Pot OA(;l Per'p "a.aod for co,"""ogo ob",,. and be"", then'h\.'Cr"

$~a"; .*tn .lTe A'o\.CJoon" WI tore Support Lv ....

I be Th~ *** cons sno"1d Dc pr.lormea In ~ tn. lh~ *SI.,,6ard Rotol1On" $Con!

Por COR_ISO Ralation} 5eO" m"';m.", ", IS' teom rul)P"\ ~u9 ¢.

Pe-rp. r'Rever:;e. Ra4...e-tion1 ,con m'nimum of 8 4 from support Lwg ~

, ")()IIIZt: SCA/'lS SY V1S\JAL CONFIRMI.T~

01' SU:O LOCATION N\:lCr TO CORt WCS V/,p, .305 4':>8

!Q'BW,! ~C\N NCREt!<lf!

PALISADES - (CPAL 1)

£AP ANO PAil. SCA'<S r C) ~- SURFACE IIlDEX 201 4 EXAMINATION PROGRAM ?lMI

" "'lAGON SCAN \C RfOW jI ERr ~"'o Pit'! Y""""S BElO'II LUG~

• Q.J2!1' LOWER SHELL TO LOVIER I'E'AD (USING HEAD RADIUS or !II .06") eiRe WELD

[RP S('.ANS O£l\"£tU LU<lS Q.:i3J' (USING \IE~(L RADIUS Of !'s.O")

WELD ID: iO-112 (V/4)

.oR SCAr<S EE1I'£~" USGS

• o.s- i WESDYNE 1 :;"-=:-:'1 18 Of 20 J Page 16 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure C Examination Category: B-B Item No. 82.12 Component 10: PZR Weld 2-982A Seam at 300 deg.

I 12" Exam Area I

~

~

"j

~ I Insulation Ring I

~ V I 4" Obstructed Area II["0.

j

/

CRV coverage = 100% for the 8" from the beveled edge to the permanent insulation ring Page 17 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure D Examination Category: 8-J Item No. 89.11 Component ID: ESS-12-SIS-1A1-10 FLOW I. )

W S/RL Thickness A=1l.199 Transducers B=1..1176

(=1..255

2) 60* Shear D=I.106

3) 60"RL Page 18 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure E Examination Category: 8-J Item No. 89.11 Component 10: ESS-12-SIS-1 81-13 FLOW B=1.240 TransdUJ:eni D=1.Oo2]'

Page 19 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure F Examination Category: B-J Item No. 89.11 Component 10: ESS-12-SIS-1 B1-14 now A=1.25a S=l.:u:aa C=Ul9O D<=l .023 Page 20 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure G Examination Category: 8-J Item No. 89.11 Component 10: ESS-6-SIS-1A1-13 Thickness A--6.7OO" C=O.653" 0=0.725"

)

WCW=1.0" Page 21 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure H Examination Category: 8-J Item No. 89.11 Component 10: ESS-6-SIS-181-14 Tl1InSlb:ers C - .fQ D- .<tI53 Page 22 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure I Examination Category: B-J Item No. B9.31 Component 10: PCS-30-RCL-1 B-1 0/12 I~

0"-75" eiRe.

• tt

~

Obstructed @4S"-69"

,u.

Flow in From 12" to 30" l W

A L

L

\

\

\

\

\

\

Page 23 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure J Examination Category: 8-J Item No. 89.31 Component 10: PCS-42-RCL-1H-3/12

• I

/ /

E--+~- 42" Diam.---~) *

• /

/

0/75" eire Obstructed @ 45"*56" Flow in From 12"* 30" Flow

)

Page 24 of 32

PN P 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure K Examination Category: 8-K Item No. 810.30 Component 10: 1A-S-A SUPPORTS CASE WELD I 4.0" -,--

l! 4.0" INACCESSIBLE INACCESSIBLE ....J......

SUPPORTS S-A & SoC 47" TOTAL WELD 8" WELD INACCESSIBLE = 17%

Page 25 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure L Examination Category: B-K Item No. B10.30 Component 10: 1A-S-B SUPPORTS CASE WELD I 9.0" -.

9.0" INACCESSIBLE INACCESSIBLE -I-SUPPORTS SoB & SoD 43" TOTAL WELD 18" WELD INACCESSIBLE = 42%

Page 26 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure M Examination Category: B-K Item No. B10.30 Component 10: 1A-S-C SUPPORTS CASE WELD I 4 .0" -,-

4.0" INACCESSIBLE INACCESSIBLE -L SUPPORTS S-A & SoC 47" TOTAL WELD 8" WELD INACCESSIBLE =17%

Page 27 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure N Examination Category: B-K Item No. B10.30 Component 10: 1A-S-O SUPPORTS CASE WELD 9.0" -,-

9.0" INACCESSIBLE INACCESSIBLE -1...

SUPPORTS SoB & SoD 43" TOTAL WELD 18" WELD INACCESSIBLE = 42%

Page 28 of 32

PN P 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure 0 Examination Category: 8-L-1 Item No. 812.10 Component 10: 18-02

~=--'J-" IL

--~:; ; '. *:.-!. --~- >. .~~

1. Nozzle-Case, 36.25 Dia. = 114 inches

2. Straight Case, 34 inches ea. = 68 inches

3. Scroll, 84 inches Dia. - 295 degrees, 216 inches ea. = 432 inches

4. Scroll, Top to Bottom = 38 inches Pump Case Total Weld: 114 in. + 68 in. + 432 in. + 38 in. = 652 inches Page 29 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure P Examination Category: R-A Item No. R1.11 Component 10: PCS-4-PRS-1P2-3 FLOW

)

45*

CIRCU M FRENCE=14.25" r---~--~~

PIPE VOLUME=14.2S"xl.3"x.062"'=1.1Sin3 SCAN 1 =100%

SCAN1= ~

WCW=Q.7S" SCAN3=1~

WCH=.062" SCAN4=0%

COVERAGE OBTAINED = 50%

Page 30 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure Q Examination Category: R-A Item No. R1.11 Component 10: PCS-4-PRS-1 P2-4 Circumference =14.25" Page 31 of 32

PNP 2016-052 ENCLOSURE ATTACHMENT 1 Examination Limitation Details Figure R Examination Category: R-A Item No. R1.16 Component 10: ESS-6-SIS-181-13 DOWNSTREAM UPSliREAMI AREA EXAM INED =0. 390 ~ n2 AREA NOT IEXAM I N ED-O. 149~ n2 PERCENT OF LOWER )ol EXAMINIEI[) = 6 1..0 % (2 DIRECTIONS)

PERCENT OF LOWER ~ EXAM INED, = 38.0% (1 DIRECTIONS) = 19:%

PERCENTof TOTAl 3-i EXAM IINED VOllJJ M E = 80~

Page 32 of 32