RS-13-248, Relief Request 14R-17, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fourth Inservice Inspection Interval
| ML13364A361 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/30/2013 |
| From: | Simpson P Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-13-248 | |
| Download: ML13364A361 (19) | |
Text
RS-13-248 10 CFR 50.55a December 30, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249
Subject:
Relief Request 14R-17, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fourth Inservice Inspection Interval In accordance with 10 CFR 50. 55a, "Codes and standards," paragraph (g)(5)(iii), Exelon Generation Company, LLC (EGC), requests NRC approval of the attached relief request associated with the fourth inservice inspection (ISI) interval for Dresden Nuclear Power Station, Units 2 and 3 (DNPS). Relief is requested due to the impracticality of satisfying the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components,"
due to plant design. The fourth ISI interval for DNPS ended January 19, 2013.
The relief request is based on the limitations that precluded completion of full Code examination requirements of ASME Class 1 and 2 welds during the fourth interval. Code examination of the welds was limited due to the materials of construction and design configurations. The DNPS fourth ten - year ISI program plan met the requirements of ASME Code,Section XI, 1995 Edition with 1996 Addenda.
EGC requests approval of these requests by December 30, 2014.
There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819.
Exelon Generation Company, LLC
Attachment:
Dresden Nuclear Power Station 10 CFR 50. 55a Request No. 14R-17
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number I4R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--inservice Inspection Impracticality-
- 1. ASME Code Component(s) Affected Code Class: 1 and 2
References:
IWB-2500, IWC-2500, Table IWB-2500-1, Table IWC-2500-1, ASME Code Case N-460, ASME Code Case N-578-1, Table 1 Examination Category: B-A, B-D, B-K, B-M-1, C-B, C-C, R-A Item Number: B1.12, B1.40, B3.90, B3.100, B10.10, B10.20, B12.40, C2.21, C3.20, R1.11, R1.20
Description:
Limited examination coverage Component Number: See Tables 1 and 2 below for specific component identification
2. Applicable Code Edition and Addenda
The Inservice Inspection (ISI) Program for the Dresden Nuclear Power Station (DNPS),
Units 2 and 3 fourth ISI interval was based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 1995 Edition with the 1996 Addenda.
- 3. Applicable Code Requirement(s)
Table IWB-2500-1, Table IWC-2500-1, and Table 1 of Code Case N-578-1 Examination Categories/Item Numbers B-A, B1.12, B1.40, B-D, B3.90, B3.100; B-K, B10.10, B10.20; B-M-1, B12.40; C-B, C-C, C2.21, C3.20; and R-A, R1.11, R1.20 require a volumetric and/or surface examination, which includes essentially 100% of the weld. Dresden Nuclear Power Station (DNPS), Units 2 and 3 adopted ASME Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1," which defines "essentially 100%" as greater than 90% coverage of the examination volume or surface area, as applicable.
- 4. Impracticality of Compliance Relief is requested in accordance with 10 CFR 50.55a(g)(5)(iii), on the basis that conformance with these Code requirements is impractical. Conformance would require extensive structural modifications to the component structure.
DNPS, Units 2 and 3, obtained Construction Permits CPPR-18 and CPPR-22 on January 10, 1966, and October 14, 1966, respectively. The piping systems and associated components were designed and fabricated before the examination requirements of ASME Section XI were formalized and published. Since DNPS, Units 2 and 3 were not specifically Page 1 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--lnservice Inspection Impracticality-designed to meet the requirements of ASME Section XI, full compliance is not feasible or practical within the limits of the current plant design.
Physical obstructions imposed by design, geometry, and materials of construction are typical of vessel appurtenances and sacrificial shield, insulation support rings, structural and component support members, adjacent component weldments in close proximity, unique component configurations and dissimilar metal weldments.
Tables 1 and 2 below indicate the refueling outage in which these welds were examined, and the coverage percentages obtained for those welds that have been examined. These tables are cumulative lists of all welds with limited examination coverage during the Fourth Interval.
Based on the above explanation, DNPS requests relief from the requirement to achieve greater than 90% volume and/or area coverage for the components listed in Tables 1 and 2 below, where greater than 90% coverage is impractical.
- 5. Burden Caused by Compliance Compliance with the examination requirements of ASME Section XI would require modification of plant components to remove obstructions, redesigning of plant systems, and replacement of components where geometry is inherent to component design.
- 6. Proposed Alternative and Basis for Use Proposed Alternative In accordance with 10 CFR 50.55a(g)(5)(iii), EGC requests relief from ASME Section XI Code requirements on the basis that the required "essentially 100%" coverage examination is impractical due to physical obstructions and limitations imposed by design, geometry, and materials of construction for the components discussed in Tables 1 and 2 below.
EGC will continue to perform best effort examinations in order to achieve the maximum amount of coverage. Additionally, a VT-2 examination performed on the subject components during system pressure test per examination category B -P each refueling outage and category C- H each inspection period is performed.
Basis for Use Examination techniques have been progressively upgraded during this interval to augment the required Section XI examinations. EGC has used the Electric Power Research Institute (EPRI), the Performance Demonstration Initiative (PDI), Inservice Inspection vendors and other industry sources to encourage the development and provide an awareness of improved examination techniques. The goal of these initiatives is to enhance coverage and flaw detection commensurate with radiation dose reduction.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-EGC examination procedures are revised on a continuing basis to incorporate proven techniques for a higher level of safety and quality as they become available. The examinations and techniques used today exceed the examinations conducted in the past on each component.
All components received as a minimum, the required examination(s) applicable to the extent practical due to the limited or lack of access available. The examinations conducted, confirmed satisfactory results evidencing no unacceptable flaws present, even though "essentially 100%" coverage was not attained. EGC has concluded that if any active degradation mechanisms were to exist in the subject welds, those degradations would have been identified in the examinations performed.
Based on the above, with the vintage of the DNPS, Units 2 and 3 designs, the underlying objectives of the code required volumetric and surface examinations have been met. The examinations were completed to the extent practical and evidenced no unacceptable flaws present. Additionally, a VT-2 examination performed on the subject components during system pressure test per examination category B-P each refueling outage and category C-H each period provides additional assurance that the structural integrity of the subject components is maintained.
- 7. Duration of Proposed Alternative Relief is requested for the fourth ten-year inspection interval of the Inservice Inspection Program for DNPS, Units 2 and 3.
- 8. Precedents Relief was granted for the DNPS, Units 2 and 3 third ISI intervals in NRC safety evaluations dated January 8, 2003, and October 1, 2004.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Table 1: Dresden Nuclear Power Station, Unit 2 Fourth Inservice Inspection Interval Limited Coverage Co ponents Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed 2/1/RPV examination was limited LONGITUDINAL IWB-2500-2 SHELL/2-SC1A- B1.12 D2R22 88.0% UT to 88.0% coverage due to WELD Volumetric VERT proximity of the jet pump diffuser.
The completed 2/1/RPV examination was limited LONGITUDINAL IWB-2500-2 SHELL/2-SC1B- B1.12 D2R22 40.2% UT to 40.2% coverage due to WELD Volumetric VERT proximity of the shroud repair lower contact.
The completed 2/1/RPV examination was limited LONGITUDINAL IWB-2500-2 SHELL/2-SC1C- B1.12 D2R22 40.2% UT to 40.2% coverage due to WELD Volumetric VERT proximity of shroud repair lower contact.
The completed examination was limited 2/1/RPV LONGITUDINAL IWB-2500-2 to 71.4% coverage due to SHELL/2-SC1D- B1 . 12 D2R22 71 . 4% UT WELD Volumetric proximity of jet pump VERT restrainers and jet pump diffuser.
The completed examination was limited 2/1/RPV to 69.0% coverage due to LONGITUDINAL IWB-2500-2 SHELL/2-SC2A- B1.12 D2R22 69.0% UT proximity of the jet pump WELD Volumetric VERT riser brace, lower specimen and upper specimen brackets.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed examination was limited 2/1/RPV to 78.2% coverage due to LONGITUDINAL IWB-2500-2 SHELU2-SC2B- B1.12 D2R22 78.2% UT proximity of the jet pump WELD Volumetric VERT riser brace, lower specimen and upper specimen brackets.
The completed examination was limited 2/1/RPV to 87.0% coverage due to LONGITUDINAL IWB-2500-2 SHELU2-SC2C- B1.12 D2R22 87.0% UT proximity of the jet pump WELD Volumetric VERT riser brace, lower specimen and upper specimen brackets.
The completed examination was limited 2/1/RPV LONGITUDINAL IWB-2500-2 to 69.1% coverage due to SHELU2-SC3A- B1 . 12 D2R22 69 . 1% UT WELD Volumetric proximity of the feedwater VERT sparger and core spray downcomer piping.
The completed examination was limited 2/1/RPV to 72.9% coverage due to LONGITUDINAL IWB-2500-2 SHELU2-SC3B- 61.12 D2R22 72.9% UT proximity of the lower WELD Volumetric VERT guide rod, feedwater sparger and core spray piping Page 5 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50. 55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed examination was limited 2/1/RPV a to 68.7% coverage due to LONGITUDINAL IWB-2500-2 D2R22 68.7% UT proximity of the shroud SHELU2-SC3C- 131.12 WELD Volumetric repair tie rod, feedwater VERT sparger and core spray piping.
The completed examination was limited 2/1/RPV LONGITUDINAL IWB-2500-2 to 73.7% coverage due to 131 . 12 D2R22 73.7% o UT SHELU2-SC3D- WELD Volumetric proximity of the core VERT s p ra y piping and feedwater s ar ers.
The completed examination was limited 2/1/RPV o to 74.2% coverage due to LONGITUDINAL IWB-2500-2 74.2% UT proximity of the upper SHELU2-SC3E- B1.12 D2R22 WELD Volumetric guide rod, core spray VERT piping and feedwater s ar ers.
The completed 2/1/RPV examination was limited LONGITUDINAL IWB-2500-2 85.7% UT to 85.7% coverage due to SHELU2-SC4C- 81.12 D2R22 WELD Volumetric proximity of the steam VERT dryer support.
The completed examination was limited 0 S to 47.7% coverage due to 2/1/RPV NOZZLE- IWB-2500-7 D2R20 47 . 7% 600 L5, 60° nozzle configuration and B3 . 90 SHELUN19A-2 VESSEL Volumetric insulation support interference.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed examination was limited 2/1/RPV NOZZLE- IWB-2500-7 to 38.0% coverage due to B3 . 90 D2R18 38 . 0% UT SHELUN19B-2 VESSEL Volumetric nozzle configuration and an insulation support bracket below the nozzle.
The completed UT-60° S 2/1/RPV VESSEL- IWB-2500-7 examination was limited B3.90 D2R21 27.2% 70-S , 60 ° SHELUN1A-2 NOZZLE Volumetric L to 27.2% coverage due to nozzle configuration.
The completed 2/1/RPV VESSEL- IWB-2500-7 examination was limited B3 . 90 D2R18 26 . 0% UT SHELUNI B-2 NOZZLE Volumetric to 26.0% coverage due to nozzle configuration.
The completed 2/1/RPV NOZZLE- examination was limited Section XI B3.90 D2R20 39.2% UT-60° L SHELUN2A-2 VESSEL to 39.2% coverage due to nozzle configuration.
The completed 2/1/RPV NOZZLE- IWB-2500-7 examination was limited B3 . 90 D2R20 39 . 2% UT-60° L SHELUN2B-2 VESSEL Volumetric to 39.2% coverage due to nozzle configuration.
The completed 211/RPV NOZZLE- IWB-2500-7 examination was limited B3 . 90 D2R18 42 . 0% UT SHELUN2C-2 VESSEL Volumetric to 42.0% coverage due to nozzle configuration.
The completed 2/1/RPV NOZZLE- IWB-2500-7 examination was limited B3 . 90 D2R18 42 . 0% UT SHELUN2F-2 VESSEL Volumetric to 42.0% coverage due to nozzle configuration.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed 2/1/RPV NOZZLE- IWB-2500-7 examination was limited B3 . 90 D2R18 42 . 0% UT SHELUN2H-2 VESSEL Volumetric to 42.0% coverage due to nozzle configuration.
The completed 2/1/RPV VESSEL- IWB-2500-7 examination was limited 63 . 90 D2R22 33 . 5% UT SHELUN3D-2 NOZZLE Volumetric to 33.5% coverage due to nozzle configuration.
The completed UT-45° S, examination was limited 2/1/RPV NOZZLE- IWB-2500-7 63.90 D2R20 39.3% 60° L, 60° to 39.3% coverage due to SHELUN4A-2 VESSEL Volumetric nozzle configuration and S
insulation interference.
The completed UT-45° S, examination was limited 2/1/RPV NOZZLE- IWB-2500-7 B3.90 D2R20 39.3% 60° L, 60° to 39.3% coverage due to SHELUN4B-2 VESSEL Volumetric S nozzle configuration and insulation interference.
The completed UT-45° S, examination was limited 2/1/RPV NOZZLE- IWB-2500-7 B3.90 D2R20 39.3% 60° L, 60° to 39.3% coverage due to SHELUN4C-2 VESSEL Volumetric S nozzle configuration and insulation interference.
The completed UT-45° S, examination was limited 2/1/RPV NOZZLE- IWB-2500-7 B3.90 D2R20 39.3% 60° L, 60° to 39.3% coverage due to SHELUN4D-2 VESSEL Volumetric S nozzle configuration and insulation interference.
Page 8 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed examination was limited 2/1/RPV VESSEL- IWB-2500-7 to 28.5% coverage due to B3 . 90 D2R22 28 . 5% UT SHELUN5A-2 NOZZLE Volumetric nozzle configuration and proximity of the insulation support bracket.
The completed examination was limited 2/1/RPV VESSEL- IWB-2500-7 to 31.0% coverage due to B3 . 90 D2R18 31 . 0% UT SHELUN5B-2 NOZZLE Volumetric the nozzle configuration and a stabilizer lug below the nozzle.
The completed 211/RPV NOZZLE- IWB-2500-7 examination was limited B3 . 90 D2R18 75 . 0% UT SHELUN9-2 VESSEL Volumetric to 75.0% coverage due to nozzle configuration.
The completed VESSEL-examination coverage 2/1/RPV UPP UPPER TOP IWB-2500-5 B1.40 D2R20 41.7% UT was limited to 41.7% due HD/2-THD-FLG HEAD FLANGE Volumetric WELD to being single sided due to flange configuration.
The completed ISO examination coverage 2/2/1302A- IWC-2500-4 CONDENSER C2.21 D2R22 50.0% UT was limited to 50.0% due 12/12-9 Volumetric NOZZLE WELD to component confi uration.
The completed ISO examination coverage 2/2/1302B- IWC-2500-4 CONDENSER C2.21 D2R22 50.0% UT was limited to 50.0% due 12/12-8 Volumetric NOZZLE WELD to component configuration.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed ISO examination coverage IWC-2500-4 D2R22 50.0% UT was limited to 50.0% due 2/2/1303A-8/8-9 CONDENSER C2.21 Volumetric to component NOZZLE WELD configuration.
The completed ISO examination coverage IWC-2500-4 D2R22 50.0% UT was limited to 50.0% due 21211303B-8/8-8 CONDENSER C2.21 Volumetric to component NOZZLE WELD config uration.
The completed 2/1/RPV UPP NOZZLE- IWB-2500-7 examination was limited B3 . 90 D2R22 74 . 2% UT HD/N18A-2 VESSEL Volumetric to 74.2% coverage due to nozzle config uration.
The completed examination was limited 2/1/RPV NOZZLE INSIDE IWB-2500-7 86.0% UT to 86 .0% coverage due to 83.100 D2R18 SHELUN56-1 RADIUS Volumetric a stabilizer lug below the nozzle.
The completed IWB-2500-13 examination was limited 2/1/RPV INTEGRAL IWB-2500-14 o MT to 56. 0% coverage due to SHELL/M- WELDED B10.10 D2R20 56.0%
IWB-2500-15 inaccessibility to the 1175D-1(IWA) ATTACHMENT Surface bottom of the lug.
The completed examination was limited IWB-2500-13 to 50.0 0% coverage due to INTEGRAL 2/1/1506-16/M- IWB-2500-14 50.0% PT the inner weld on the WELDED B10.20 D2R20 1164D-296(IWA) IWB-2500-15 attachment was not ATTACHMENT Surface accessible and could not be prepped.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed 2/1/3001 D- examination was limited IWB-2500-17 VOL to 87.3% coverage due to 6/ERV-2-203- VALVE WELD B12.40 D2P22 87.3%
Volumetric integrally welded cage on 3D(WELD) the valve ID.
The completed examination was limited INTEGRAL to 81.6% coverage due to 2/2/2304-14/M- D2P19 81.6% MT only examining three WELDED IWC-2500-5 C3.20 1151 D-10(IWA) sides since presence of ATTACHMENT pipe clamp prevented examining fourth side.
IWB-2500-8(c) The completed IWB-2500-9 ° examination was limited 2/1/1001A- UT-E-45° TEE-PIPE IWB-2500-10 R1.11 D2R19 36.0% to 36.0% coverage due to 16/16-11 S , 60° L IWB-2500-11 weld obstruction and Volumetric component configuration.
IWB-2500-8(c) The completed IWB-2500-9 UT-E-45° examination was limited 2/1/1001 B- D2R20 85 . 0%
FLANGE-PIPE IWB-2500-10 R1 . 11 to 85.0% coverage due to 16/16-2 S IWB-2500-11 component configuration.
Volumetric IWB-2500-8(c) The completed IWB-2500-9 UT-E-45° examination was limited 2/1/1005B- D2R20 50.0%
VALVE-PIPE IWB-2500-10 R1.11 S, 60 L to 50.0% coverage due to 14/14-7 IWB-2500-11 component configuration.
Volumetric IWB-2500-8(c)
The completed IWB-2500-9 UT-E-45 ° 2/1/1403-101W- examination was limited IWB-2500-10 R1.20 D2R20 81.0% L, 45° S, 103 verage due to to 81.0% coverage IWB-2500-11 60 ° L component configuration.
Volumetric Page 11 of 18
ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number I4R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type IWB-2500-8(c) The completed IWB-2500-9 UT-E-45 ° 2/1/1404-10/W- examination was limited VALVE-PIPE IWB-2500-10 R1.20 D2R20 85.0% S, 45 ° L, 112 to 85.0% coverage due to IWB-2500-11 60 ° L component configuration.
Volumetric Table 2: Dresden Nuclear Power Station, Unit 3 Fourth Inservice Inspection Interval Limited Coverage Components Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed 3/1/RPV examination coverage LONGITUDINAL IWB-2500-2 %
SHELL/3-SC1A- 81.12 D3R22 85.0% UT-45 was limited to 85.0% due WELD Volumetric to proximity of the jet VERT pump diffuser.
The completed 3/1/RPV UT-45 examination coverage LONGITUDENAL IWB-2500-2 SHELU3-SC1B- 81.12 D3R22 39.8% S,UT-70 was limited to 39.8% due WELD Volumetric VERT RL to proximity of the shroud repair tie rod.
The completed 3/1/RPV examination coverage LONGITUDENAL IWB-2500-2 UT-45 S SHELU3-SC1C- 81.12 D3R22 83.4% was limited to 83.4% due WELD Volumetric UT-70 RL VERT to proximity of the jet pum p diffuser.
The completed 3/1/RPV examination coverage LONGITUDENAL IWB-2500-2 75.8% UT-45 S SHELU3-SC2A- 81.12 D3R22 was limited to 75.8% due WELD Volumetric UT-70 RL VERT to the tie-rod stabilizer bracket.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed 3/1/RPV examination coverage LONGITUDENAL IWB-2500-2 UT-45 S SHELL/3-SC2C- B1 . 12 D3R22 84.2% was limited to 84.2% due WELD Volumetric UT-70 RL VERT to proximity of the core spray piping .
The completed examination coverage 3/1/RPV UT-45 S was limited to 22.6% due LONGITUDENAL IWB-2500-2 22.6%
SHELL/3-SC3A- B1 . 12 D3R22 WELD Volumetric UT-70 RL to proximity of the VERT feedwater sparger and core spray downcomer.
The completed examination was limited to 3/1/RPV NOZZLE- IWB-2500-2 ° UT-60° L, 53.0% coverage due to B3 . 90 D3R20 53 . 0%
SHELL/N19A-2 VESSEL Volumetric 60°S nozzle configuration and insulation support interference.
The completed examination coverage 3/1/RPV LONGITUDENAL IWB-2500-2 UT-45 S was limited to 66.0% due SHELL/3-SC36- B1 . 12 D3R22 66 . 0%
WELD Volumetric UT-70 RL to proximity of the shroud VERT repair tie rod and core spray iin bracket.
The completed examination coverage 3/1/RPV was limited to 55.7% due LONGITUDENAL IWB-2500-2 UT-45 S SHELL/3SC3C- B1.12 D3R22 55.7% to proximity of the core WELD Volumetric UT-70 RL VERT spray piping, feedwater sparger and specimen bracket.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed 3/1/RPV examination coverage LONGITUDENAL IWB-2500 -2 UT-45 S SHELU3-SC3D- 81.12 D3R22 71.8% was limited to 71.8% due WELD Volumetric UT-70 RL VERT to core spray piping and feedwater s ar er.
The completed examination coverage 3/1/RPV was limited to 80.2% due LONGITUDENAL IWB-2500-2 UT-45 S to proximity of the dryer SHELU3-SC46- 61 . 12 D3R22 80 . 2%
WELD Volumetric UT-70 RL bracket and the mismatch VERT between the RPV and flange for this examination.
The completed 3/1/RPV NOZZLE- IWB-2500-7 examination was limited to UT-45° S, B3.90 D3R18 38.0% 38.0% coverage due to SHELUNI9B-2 VESSEL Volumetric 600 L nozzle configuration and an insulation support ring.
The completed 3/1/RPV VESSEL- IWB-2500-7 UT-60° S, examination was limited to SHELUNIA-2 B3.90 D3R18 25.0% 700S , 60° NOZZLE Volumetric 25.0% coverage due to L1 nozzle configuration.
The completed 3/1/RPV VESSEL- IWB-2500-7 UT-60° S examination was limited to SHELUN1 B-2 B3 . 90 D3R20 31 . 3%
NOZZLE Volumetric 70°S 31.3% coverage due to nozzle configuration.
The completed 3/1/RPV NOZZLE- IWB-2500-7 ° examination was limited to SHELUN2B-2 VESSEL B3 . 90 D3R20 41 . 7% UT°-60 S Volumetric 41.7% coverage due to nozzle configuration.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed 3/1/RPV NOZZLE- IWB-2500-7 UT-60° S, examination was limited to B3 . 90 D3R18 42 . 0%
SHELL/N2D-2 VESSEL Volumetric 60° L 42.0% coverage due to nozzle configuration.
The completed UT-60° S, 3/1/RPV NOZZLE- IWB-2500-7 examination was limited to B3.90 D3R18 42.0% 700S , 60 ° SHELL/N2E-2 VESSEL Volumetric L 42.0% coverage due to nozzle configuration.
The completed 3/1/RPV NOZZLE- IWB-2500-7 ° examination was limited to B3 . 90 D3R20 41 . 7% UT-600 S SHELL/N2G-2 VESSEL Volumetric 41.7% coverage due to nozzle configuration.
The completed 3/1/RPV VESSEL- IWB-2500-7 UT-60° S, examination was limited to B3 . 90 D3R21 31 . 0%
SHELL/N3A-2 NOZZLE Volumetric 60° L 31.0% coverage due to nozzle configuration.
The completed 3/1/RPV VESSEL- IWB-2500-7 UT-60° S, examination was limited to SHELL/N3B-2 B3 . 90 D3R21 31 . 0%
NOZZLE Volumetric 60° L 31.0% coverage due to nozzle configuration.
The completed 3/1/RPV UT-60° L, examination was limited to VESSEL- IWB-2500-7 B3.90 D3R18 35.0% 700S,600 35.0% coverage due to SHELL/N3C-2 NOZZLE Volumetric S nozzle configuration and thermocouples.
The completed 3/1/RPV VESSEL- UT-60° L IWB-2500-7 examination was limited to SHELL/N3D-2 B3.90 D3R19 40.8% 700SS, 60 ,° NOZZLE Volumetric 40.8% coverage due to nozzle configuration.
The completed 3/1/RPV VESSEL- IWB-2500-7 UT-45° S, examination was limited to SHELL/N4A-2 NOZZLE B3.90 D3R20 36.3% 60° L, 60° Volumetric S 36.3% coverage due to I nozzle configuration.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed UT-45° S, 3/1/RPV VESSEL- IWB-2500-7 examination was limited to B3.90 D3R20 36.3% 60° L, 60° SHELUN4B-2 NOZZLE Volumetric S 36.3% coverage due to nozzle configuration.
The completed NOZZLE- UT-450 S ,
IWB-2500-7 examination was limited to B3.90 D3R20 36.3% 600S , 70° SHELUN4C-2 VESSEL Volumetric 36.3% coverage due to LT nozzle configuration.
The completed 3/1/RPV NOZZLE- UT-45° S, IWB-2500-7 examination was limited to B3.90 D3R20 36.3% 600S , 60° SHELUN4D-2 VESSEL Volumetric 36.3% coverage due to L
nozzle configuration.
The completed 3/1/RPV VESSEL- examination was limited to IWB-2500-7 UT-60° L, SHELUNSA-2 B3.90 D3R21 29.0% 29.0% coverage due to NOZZLE Volumetric 600S the nozzle configuration and stabilizer bracket.
The completed 3/1/RPV VESSEL- IWB-2500-7 UT-60° S, examination was limited to SHELUN5B-2 NOZZLE B3 . 90 D3R18 36 . 0%
Volumetric 60° L 36.0% coverage due to nozzle configuration.
The completed 3/1/RPV NOZZLE- IWB-2500-7 examination was limited to UT-45° S SHELUN9-2 VESSEL B3.90 D3R18 62.0% 62.0% coverage due to Volumetric 60° L nozzle configuration and insulation support ring.
VESSEL-UPPER The completed 3/1/RPV UPP IWB-2500-5 examination was limited to TOP HEAD 61 . 40 D3R19 72 . 0% UT HD/3-THD-FLG Volumetric 72.0% coverage due to FLANGE WELD flange configuration.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed 3/1/RPV UPP NOZZLE- IWB-2500-7 UT-45° S, examination was limited to HD/N18A-2 VESSEL B3.90 D3R19 66.6% 600S , 60° Volumetric coverage due to Ll nozzle configuration.
The completed 3/1/RPV UPP VESSEL- IWB-2500-7 UT-45° S, examination was limited to HD/N18B-2 NOZZLE B3.90 D3R19 66.6% 600S , 60° Volumetric 66.6% coverage due to L
nozzle configuration.
The completed 3/1/RPV UPP VESSEL- IWB-2500-7 UT-60° S, examination was limited to HD/N8-2 B3 . 90 D3R19 74 . 3%
NOZZLE Volumetric 60° L 74.3% coverage due to nozzle configuration.
ISO The completed 3/2/1302A- IWC-2500-4 examination was limited to CONDENSER C2 . 21 D3R20 37 . 8% UT 12/12-8 Volumetric 37.8% coverage due to NOZZLE WELD nozzle configuration.
ISO The completed 3/2/1302B- IWC-2500-4 examination was limited to 12/12-9 CONDENSER C2 . 21 D3R20 37 . 8% UT Volumetric 37.8% coverage due to NOZZLE WELD component configuration.
ISO The completed 3/2/1303A-8/8-8 IWC-2500-4 examination was limited to CONDENSER C2.21 D3R21 50 . 0%
Volumetric UT 50.0% coverage due to NOZZLE WELD component configuration, ISO The completed IWC-2500-4 examination was limited to 3/2/1303B-8/8-9 CONDENSER C2.21 D3R21 52 . 3% UT Volumetric 52.3% coverage due to NOZZLE WELD component configuration.
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ATTACHMENT Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a Request Number 14R-17 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality-Weld Exam Item Outage Actual Exam Component ID Remarks Description Requirements Number Examined Coverage Type The completed IWB-2500-13 examination was limited to 3/1/RPV INTEGRAL IWB-2500-14 60.0% coverage due to SHELUM- WELDED B10.10 D3R19 60 . 0%
IWB-2500-15 PT being only able to 1211 D-1 (IWA) ATTACHMENT Surface examine three sides of the lu g .
The completed IWB-2500-13 examination was limited to 3/1/0202A-28/M- INTEGRAL IWB-2500-14 PT 88.0% coverage due to 1193D- WELDED B10 . 20 D3R18 88 . 0%
IWB-2500-15 presence of sway brace 1002(IWA) ATTACHMENT Surface which reduced accessibility.
IWB-2500-8(c) The completed examination was limited to IWB-2500-9 3/2/320413- 78 . 9% UT-E-45° 78.9% coverage due to VALVE-TEE IWB-2500-10 R1 . 11 D3R21 18/18-1 S presence of saddle IWB-2500-11 weldment, weld-o-let and Volumetric valve configuration.
The completed 3/1/3001 B- examination was limited to IWB-2500-17 6/ERV-3-203- VALVE WELD 812.40 D3P22 89.4% VOL 89.4% coverage due to Volumetric 3B(WELD) integrally welded cage on valve ID.
IWB-2500-8(c)
The completed IWB-2500-9 3/1/1302-14/14- UT-E-60° examination was limited to 9(A) FLANGE-PIPE IWB-2500-10 R1 . 20 D3R21 50 . 0%
L, 45° S 50.0% coverage due to IWB-2500-11 Volumetric Hued head configuration.
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