RS-17-083, Inservice Inspection Program Third Interval Relief Requests 13R-12 and 13R-15

Inservice Inspection Program Third Interval Relief Requests 13R-12 and 13R-15

ML17180A367
Person / Time
Site:	Byron
Issue date:	06/29/2017
From:	Gullott D Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RR 13R-12, RR 13R-15, RS-17-083
Download: ML17180A367 (38)

Text

4300 Winfield Road AdINEW Warrenville, IL 60555 1AMENOW A-- Exelon Generation 630 657 2000 Office June 29, 2017 10 CFR 50.55a RS-17-083 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN-50-454 and STN 50-455

Subject:

Inservice Inspection Program Third Interval Relief Requests 13R-12 and 13R-15 In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(5)(iii), Exelon Generation Company, LLC (EGC), is submitting two requests for relief due to 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." As noted in 10 CFR 50.55a(g)(5)(iii), "Requests for relief made in accordance with this section must be submitted to the NRC no later than 12 months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought." The subject relief requests are associated with the third interval for Units 1 and 2, which ended July 15, 2016. Note that Relief Request 13R-12 is applicable to Units 1 and 2 whereas Relief Request 13R-15 is applicable to Unit 2 only.

The relief requests are based on limitations that precluded full code examination requirements of ASME Class 1 and 2 welds during the third interval. Code examination of the welds is limited due to materials of construction and design configurations.

There are no regulatory commitments contained within this letter. Should you have any questions concerning this submittal, please contact Joseph A. Bauer at 630 657-2804.

Respectfully, David M. Gullott Manager Licensing xelon Generation Company, LLC Attachments: 1. 10 CFR 50.55a Relief Request 13R-12

2. '10 CFR 50.55a Relief Request 13R-15

June 29, 2017 U. S. Nuclear Regulatory Commission Page 2 CC' NRC Regional Administrator Region III NRC Senior Resident Inspector Byron Station NRC Project Manager, NRR Byron Station Illinois Emergency Management Agency Division of Nuclear Safety

ATTACHMENT I 10 CFR 50.55a RELIEF REQUEST MR-12 Revision 0 Request for ReHei Regarding Inservuce Inspection Impracticality Due to Limited Examinations on Pressurizer Surge, Spray, Safety, and ReHet Nozzie-t-!Vessel WeIds In Accordance with 10 CFR 50.55a(g)45y(uuo)

1St Program Plan Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST 13R-12 Revision 0 (Page 1 of 6)

Request for Relief Regarding Inservice Inspection Impracticality Due to Limited Examinations on Pressurizer Surge, Spray, Safety, and Relief Nozzle-to-Vessel Welds In Accordance with 10 CFR 50.55a(g)(5)(iii) 1.0 ASME CODE COMPONENTS AFFECTED Code Class: 1

Reference:

IWB-2500, Table IWB-2500-1 Examination Category: B-D Item Number: B3.110

Description:

Limited Examinations on Pressurizer Surge, Spray, Safety, and Relief Nozzle-to-Vessel Welds Component Number: Unit 1 1 RY-01-S/PN-01, 1 RY-01-S/PN-02, 1 RY-01-S/PN-03, 1 RY-01-S/PN-04, 1 RY-01-S/PN-05, and 1 RY-01-S/PN-06 Unit 2 2RY-01-S/PN-01, 2RY-01-S/PN-02, 2RY-01-S/PN-03, 2RY-01-S/PN-04, 2RY-01-S/PN-05, and 2RY-01-S/PN-06 Drawing Number: 1PZR-1-ISI (Unit 1) 2PZR-1-ISI (Unit 2) 2.0 APPLICABLE CODE EDITION AND ADDENDA The Third Interval Inservice Inspection Program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 2001 Edition through the 2003 Addenda. The 2001 Edition through 2003 Addenda requires essentially 100% examination coverage of required surfaces and volumes of Class 1 components.

3.0 APPLICABLE CODE REQUIREMENT ASME Code Section XI, 2001 Edition through the 2003 Addenda requires a volumetric and/or surface examination, which includes essentially 100% of the weld and the applicable base metal, for the affected examination categories.

Table IWB-2500-1, Examination Category B-D, Item B3.110 requires volumetric examination of the Pressurizer Nozzle-to-Vessel welds as detailed in Figure IWB-2500-7(b).

Exelon Byron Station

I SI Program Plan Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST 13R-12 Revision 0 (Page 2 of 6)

ASME Code Section XI Mandatory Appendix I requires ultrasonic examination of vessel welds greater than 2 inches thick to be conducted in accordance with ASME Section V, Article 4, as supplemented by Table 1-2000-1.

ASME Section V, Article 4 requires:

T-472.1.1 Bearn Angle: The search unit and beam angle selected shall be appropriate for the configuration being examined and shall be capable of detecting the calibration reflectors, over the required angle beam path.

T-472.1.2 Reflectors Parallel to the Weld Seam: The angle beam shall be directed at approximate right angles to the weld axis from both sides of the weld (i.e., from two directions) on the same surface when possible. The search unit shall be manipulated so that the ultrasonic energy passes through the required volume of weld and adjacent base metal material.

T-472.1.3 Reflectors Transverse to the Weld Seam: The angle beam shall be directed essentially parallel to the weld axis. The search unit shall be manipulated so that the ultrasonic energy passes through the required volume of weld and adjacent base material.

The search unit shall be rotated 180 degrees and the examination repeated.

Byron Station has invoked ASME Section XI Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 welds,Section XI Division 1." Code Case N-460 states in part, "...when the entire examination volume or area cannot be examined ... a reduction in examination coverage... may be accepted provided the reduction in coverage for that weld is less than 10%."

4.0 IMPRACTICALITY OF COMPLIANCE Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested on the basis that conformance with these Code requirements is impractical, as conformance would require extensive structural modifications to the pressurizer vessel without providing a corresponding increase in the level of quality and safety.

10 CFR 50.55a(g)(4) states; "Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components (including supports) which are classified as ASME Code Class 1, Class 2 and Class 3 must meet the requirements ... set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code and Addenda ... to the extent practical within the limitations of design, geometry and materials of construction of the components." The geometry and materials of construction of the subject pressurizer nozzles results in limited access to the entire examination volume. The pressurizer nozzle surge, spray, safety, and relief nozzle-to-vessel welds are clad with stainless steel on the inside diameter surface and are approximately 3.0 inches thick. Figures 1, 2, and 3 detail the weld and pressurizer nozzle configurations, diameters, and limitations for examination coverage encountered for the subject pressurizer welds at Byron Station during the Third Inservice Inspection (ISI) Interval. In addition, Attachment A, "Relief Request 13R-12, Supporting Documentation," shows examination coverages attained for each of the subject nozzle welds.

Exelon Byron Station

I SI Program Plan Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST I3R-12 Revision 0 (Page 3 of 6)

During previous outages, the nozzles were examined by the ultrasonic method . The three limiting factors in the scanning of these nozzles are as follows:

a) the minirnum scanning surface available on the nozzle side of the weld (component geometry),

b) the minimum scanning surface available on the vessel side of the weld ( obstruction frorn pressurizer penetrations on lower head); and c) the inability of the ultrasonic beam to reach beyond a 1/2Vee sound path (due to the materials of construction).

Furthermore, based on review of the coverage plots, differences in the total coverage achieved can be attributed to geometric variations between the two units such as the weld crown width used in determining the total volume to be examined, the weld toe locations in relation to the curvature of the nozzle (i.e., the location of the examination volume prior to experiencing the limitation caused by the curvature of the nozzle ) and the scans performed.

In Byron Station, Unit 1, Refueling Outage 14 (i.e.,31R14), B2R13, and B2R15, scanning for the pressurizer surge, spray, safety, and relief nozzles was performed with 0 degree longitudinal scans and with 45 degree and 60 degree scans in the shear mode from the outside surface of the vessel . During B1R20 and B2R18, the pressurizer relief nozzles were scanned with a 45 degree scan (only) in the shear mode from the outside surface of the vessel. Only a 45 degree scan was performed forthe B1R20 and B2R18 examinations because, in accordance with ASME Section XI, 2001 Edition, 2003 Addenda, Mandatory Appendix I, vesseis greater tthan 2 inches in laid ness are examined in accordance with ASME Section V, Article 4 as supplemented by Table 1-2000-1 which did not require the 60 degree scan for outside diameter examinations. in addition, Paragraph T-472.1.1, Beam Angie, states the search unit and bears angle selected shall be appropriate for t;1e configuration being examined and shall be capable of detecting the calibraon reflectors, over the required angle beam path. Mote that Supplement 9 of Mandatory Appendix I, which requires both a 45 degree and 60 degree scan, is interoreted to be ap,Dficabie for examMa,., ons conduc`:ed from the inside d'arneter clad surface o-k vessels only.

There were no recordable indications requring furtl.er evaluation noted in any of the volumetric examinations per,ormed. T ve examinations were co nd cted and satdsfactory results were confirmed, even `Bough essentsaly 100% coverage was not attained.

=inures 1, 2. alyd 3 represent "-. Se aggregate examination coverage that was achieved for each pressurizer surge, spray, sagely, and relief nozzle-to-vessel we'd.

As previously stated, 'he propagation for tie ultrasonic beam was In t'-,e shear movie.

Normally this mode would allow the ui`rason c beam to reflect olf the inside s°.jr"ace ar?d create two bean^ axes at right angles to each other. This techrr que is riot possible die to 41ie stainless s- eet c;a(dd nc or, the ?nside of i-.e vessel. The ultrasonic beam would r o be comp'H.'ely re lect ed f,cm tl^e slhel /clad interface. 1Vost of the sound energy would be efra ted ti~roug;I 7^is Payer and would be scattered as it reflected from ",-e as-welded clad

aside surface. A-,y sound energy reflected from the shelk'ad interface would be of such

-w amplitude that it would be useless `cr exam ration purposes.

Exei'on 3;1i-on StG,,.ion

ISI Program Plan Units 1 & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST 13R-12 Revision 0 (Page 4 of 6) 5.0 BURDEN CAUSED BY COMPLIANCE Compliance with the applicable Code requirements can only be accomplished by redesigning and refabricating the subject vessel nozzles. Based on this fact, the Code requirements are deemed impractical and meet the criteria for relief in accordance with 10 CFR 50.55a(g)(5)(iii).

6.0 PROPOSED ALTERNATIVE AND BASIS FOR USE The Code required ultrasonic examinations for the subject pressurizer nozzle-to-vessel welds were performed to the maximum extent possible based on the obstructions and geometric constraints detailed in Section 4.0, "Impracticality of Compliance," of this relief request. There were no additional scanning surfaces, search unit angles, or surface preparation activities that would provide reliable additional examination coverage.

In addition to completing the required volumetric examination to the extent practical, a System Leakage Test and associated VT-2 examination are performed in accordance with Section XI Examination Category B-P. This leak test and VT-2 examination are performed every outage at nominal system operating pressure and temperature to verify leak tight integrity of the system. No evidence of leakage associated with the pressurizer surge, spray, safety, or relief nozzle-to-vessel welds has been noted. The results of the ultrasonic examination and system leakage test provide reasonable assurance that pressure boundary integrity has been, and will remain, maintained for the associated components.

Radiography as an alternative is not feasible because access is not available for film placement. No alternative examinations were planned for the weld during the Third ISI Interval.

7.0 DURATION OF PROPOSED ALTERNATIVE Relief is requested for the Third Ten-Year Inservice Inspection (ISI) Interval for Byron Station, Units 1 and 2. For the examination categories applicable to this relief, the Third Interval for Byron Station, Units 1 and 2 began on January 16, 2006 and concluded on July 15, 2016.

8.0 PRECEDENTS Similar relief requests for limitations resulting in examination coverage less than 90% have been previously approved for Byron Station. The Byron Station Second Inservice Inspection Interval Relief Request, 12R-23, was authorized in an NRC Safety Evaluation dated January 15, 2008 (ML073230312). Additionally, the Byron Station Second Inservice Inspection Interval Relief Request, 12R-03, was authorized in an NRC Safety Evaluation dated December 30, 1998.

Exelon Byron Station

ISI Program Plan Units I & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST 13R-12 Revision 0 (Page 5 of 6)

Pressurizer Nozzle: PN-01 B1 R14 '- Vained Coveumcle: 4ii.i i on R%1-01 ding 19, Figure 1: Pressurizer 84 Series Model D 14"0 Surge Nozzles (Drawing not to scale)

Ref: Westinghouse Drawing EDSK379442 B Pressurizer Nozzle: PN -02 B1R14 Obtained Coverage 76 6.9% on PN-02 B2,R1 E obtained Coverage 62.3% on PN-02 Required Examination Area Cladding

-0.191, Figure 2: Pressurizer 84 Series Model D 4"0 Spray Nozzle (Drawing not to scale)

Ref: Westinghouse Drawing EDSK379445 B Exelon - Byron Station

ISl Program Plan Units I & 2, Third Interval 10 CFR 50.55a RELIEF REQUEST 13R-12 Revision 0 (Page 6 of 6)

Pressurizer Nozzles: PN-03, PN-04, PN-05, PN-06 i31R14 Obtained Coverage: 77.2% on PN-03 and 76.8% on PN-06 I it l F31 R20 Obtained Coverage: 64.9% on PN-04, 64.9% on FIN-05 B2R15 Obtained Coverage: 66.3% on PN-03, 66.3% on PN-06 Examination Area B2R18 Obtained Coverage: 62.5% on PN-04, 62.5% on PN-05 1.

Cladding <

-0.19" Figure 3: Pressurizer 84 Series Model D 6"0 Safety and Relief Nozzles (Drawing not to scale)

Ref: Westinghouse Drawing EDSK379558 B Exelon - Byron Station

/S/ Program Plat) Units I & 2, DO(] Interval 1 CM 50.555 RIEUIEF REOU EST ~3R-12 Rlev~sion 0 ATTACHMENT A ReNef Request 13R-12 Supporting Documentation

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-J `;:eIon Report No.: 81 R20-UT-029 Page: 3 of 3 Summary No.: 1-63.110.0005 Examiner: Tauchen, Ryan J. Level: I1-PDI Reviewer: Richard Futter, Level III Date: ""

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10 CFR 50.55a Relief Request 13R-12 Attachment A O Westinghouse WESTINGHOUSE NUCLEAR SERVICES LIMITATION TO EXAMINATION Data Sleet No: 2004-E Page 5 of W rb7 o~

PLANT BYRON UNIT 2 SKETCH 2PZR-1-ISI it SYST./COME' PZR/2RY-01-S _ PROCEDURE EXE-ISI-210 Rev. 0 _

EXAMINER DATE 3/27/04 RELATED TO. UT X P'r MT VT (DENT NO. ?N--02 PROVIDE GENERAL INFORMATION TO DESCRIBE APPROXIMATE SIZE, LOCATION AND TYPE OF LIMITATION.

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E PRESSURIZER SPRAY NOZZLE Examination limited due to Nozzle-to-Vessel configuration.

Due to inconnel cladding, Examination is limited to 1/2 V-path technique.

A.S.M.E. exam figure: 1WB-2500-7 (b)

Weld crown width: 1.5" Weld 'T': 2.8" (NOMINAL)

Required exam coverage area: 12.65 sq. in.

0` Exam coverage achieved: 8.12 sq. in. (64.2%)

45" Circumferential exam coverage achieved: 8.12 sq.in. (64.2%)

60' Circumferential exam coverage achieved: 8.12 sq.in. (64.2%)

45" Axial (upstream) exam coverage achieved: 3.78 sq.in. (29.8%)

60' Axial (upstream) exam coverage achieved: 3.36 sq.in. (26.5%)

45` Axial (downstream) exam coverage achieved: 11.74 sq.in. (92%)

60` Axial (downstrear) exam coverage achieved: 12.02 sq.in. (95%)

Total exam coverage achieved: 62.3%

Calculations performed by: Jeff L. Devers EXELON L III R gjF_... *~ ANTI REVIEW I DATE

B21115-UT-017 Supplemental Coverage Plot 9

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-4 Scan Vol. Exam Vol. ° Scan Cubc Inches Cubic Inches) ~° 00 629 864 72.8%

450 H 721 864 83.5%

450 N 291 864 33.7%

600 H 832 864 96.3%

600 N 164 864 19.0%

45° CW 629 864 72.8%

45° CCW 629 864 72.8% Examination Volume = 864 cubic inches 60° CW 629 864 72.8% Weld Width = 2.5" 60° CCW 629 864 72.8% Thickness = 3.1" H = Head Side N = Nozzle Side Exam Width = 5.5" (2.5" + 1.5" each side)

Total = 597%19 = 66.3% Weld Length = 50.7"

-~ Exelo ~ Supplemental Depart

~ v Report No.: B2R18-UT-018 Page: 2 of 3 Summary No.: 2-B3.110.0004 A/~rbpSfia~tbl~n Examiner: Serth, Joseph P. Level: Il-PDI Reviewer: ~- ~(Y Date: la _1 6 _

Examiner: N/A Level: N/A Site Review- Mlifta Date:

Other: N/A Level: NIA ANiI Review: 420414- Date: spfe4py Comments: Coverage calculations taken from previous report (2004-087).

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Examiner: NIA Level: NIA Site Review:.1~ Etiker Date: /0 -1 c -151 Other: NIA Level. N/A ANI( Review: 7' a~~yu aftf 4tt Date: / aGTt Comments: Coverage calculations taken from previous report (2004-087).

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Scan (C~libc Inches) (Cubic Inches) '° 0J 629 864 72.80/0 45c N --- 721 - 864 v_ ~ 83.5%

45 i ! 291 _ 864 _ 33.7%

60° H 832 864 - 96.3%

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1 45: CV! 629 864 72.8%

45- CC 029 864 !i 72.8% Examination Volume = 864 cubic inches

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864 72.8 Weld Wid h = 2.5" 6J'- CC~A/ 629 864 72.8 °~~I Thickness = 3.1"

_c_ N = Nozzle side Exam Vv'idth - 5.5" (2.5"+ 1.5" each sid e)

Vie_ - 597% / 9 = 66.3% Weld I-cri.gth = 50.7"

ATTACHMENT 2 10 CF R. 50.55a RELIEF REQUEST MR-15 Revision Request for Rebuff Regarding Inservicc Inspection Impracticality Dare to Limited Volur etric ENamination f Reactor Vessel Circumferential Shell Welds In Accordance with 10 CFR 50.55a(g)(5)(uuo)

ISI Program Plan Unit 2, Third Interval 10 CFR 50.55a RELIEF REQUEST 13R-15 Revision 0 (Page 1 of 4)

Request for Relief Regarding Inservice Inspection Impracticality Due to Limited Volumetric Examination of Reactor Vessel Circumferential Shell Welds In Accordance with 10 CFR 50.55a(g)(5)(iii) 1.0 ASME CODE COMPONENTS AFFECTED Code Class: 1

Reference:

IWB-2500, Table IWB-2500-1 Examination Category: B-A Item Number: B1.11

Description:

Limited Volumetric Examination of Reactor Vessel Circumferential Shell Welds Component Number: 2RC-01-R/WR-29 (Unit 2)

Drawing Number: 2RPV-1-ISI (Unit 2) 2.0 APPLICABLE CODE EDITION AND ADDENDA The Third Interval Inservice Inspection Program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 2001 Edition through the 2003 Addenda. The 2001 Edition through 2003 Addenda requires essentially 100% examination coverage of required surfaces and volumes of Class 1 components.

3.0 APPLICABLE CODE REQUIREMENT ASME Code Section XI, 2001 Edition through the 2003 Addenda requires a volumetric and/or surface examination, which includes essentially 100% of the weld and the applicable base metal, for the affected examination categories.

Table IWB-2500-1, Examination Category B-A, Item B1.11 requires volumetric examination of the Reactor Vessel Circumferential Shell welds as detailed in Figure IWB-2500-1.

Byron Station has invoked ASME Section XI Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 welds,Section XI Division 1." Code Case N-460 states in part, "...when the entire examination volume or area cannot be examined ... a reduction in examination coverage... may be accepted provided the reduction in coverage for that weld is less than 10%."

/"-,s required by 10 CFR 50.55x, the 2001 Edition through 2003 Addenda of the ASME Code,Section XI, Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems," was used for examination procedures, equipment, and personnel.

Exelon Byron Station

ISI Prograin Plan Unit 2, Third Inferval 10 CFR 50.55a RELIEF 'R.-GUEST I3R-15 Revision 0 (Page 2 of 4)

J-.0 1MP'RACT1lCAUTY OF CChtfdPUANCIF Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested on the basis that conformance with the specified Code requirement has been determined to be impractical. Due to the original design and geometry associated with the reactor vessel weld , it is not feasible to effectively perform examinations of 100% of the volume of the weld. Therefore, relief is requested on the basis that the Code requirements to examine essentially 100% of the weld volume is impractical due to physical obstructions and geometry of the reactor vessel and concrete support structure. Attaining the necessary geometry to achieve the Code required examination coverage would involve major modifications to the existing component and support structure without providing a corresponding increase in the level of quality and safety.

The reactor vessel lower head circumferential weld is clad with stainless steel on the inside diameter (I.D.) surface and is restricted by six core barrel lugs welded to the inner surface of the vessel approximately four inches above :he weld. These lugs obstruct the automated ultrasonic inspection tool from completely examining the code required volume of the weld.

Where access is available, the weld metal can be examined from below and between the core barrel lugs on the I.D. of the vessel. Access to allow examination from the outside diameter (O.D.) (shell side) of the weld is restricted due to the structural concrete surrounding the vessel.

he examination scan plan consisted of using a 45 degree nominal angle with a single longitudinal beam, a dual longitudinal beam , and a shear "seam . The aggregate examination coverage achieved for the circumferential weld was 79.25% and the examination identified zero recordable indications durir?~g the Byron Station ~:njt 2 Refueling Outage 13 (i.e.

B2R13). This documented coverage is ¢core than what was achieved during the previous lnservice lnspect'on (iSl) interval when using a different contractor, ultrasonic testing (OJT) system tooling , and scan plan (i.e., 57% coverage was attained during IB2R07).

7-'cure 1 derails the we'd and verse" configuration, thickness, diameter, and limitations for exa3n,nat7,o n coverage encoun.ered for tl-ie reactor vessel lower dead circum`:ere:~` ial weld at-Byron Station during tl-~e Third ISI lnterval. In addition, AJachment A, "Relief Request i3R-?5, Support ng 'Documentation ," shows the examination coverage attained for ',he subject we'd.

_N CAUSE ." 1! CC .`k'a Compliance with the apoli; cable Code m-equrements can only lie accompiisl^ ed by redesigning and ref-e briOating the reactor vessel a7dlor --'-e structu.-e sE-irro ur,,ding the vessel. Based on this fact, . r.,e Code requiremer `.s are deemed i,rDractjcal and meet the criteria for reiie-, in accol,dar.ce with 10 CFR 50.55a(g)(5)(1 ,-0.

X :~ on 3 /rot Station

1 SI Program Pan Unit 2, TI Ozl Interval

'10 CFR 60.66a RELUEF REQUEST MR-15 Revision 0 (Page 3 of 4) 6.0 PROPOSED ALTERNATWE AND BASIS ME,' USE The Code required volumetric examination for the subject reactor vessel lower head circumferential weld has been performed to the maximurn extent possible based on the obstructions and geometric constraints detailed in Section 4.0, "Impracticality of Compliance," of this relief request.

In addition to completing the required volumetric examination to the extent practical, a System Leakage Test and associated VT-2 examination are performed in accordance with Section XI Examination Category B-P. This leak test and VT-2 examination are performed every outage at nominal system operating pressure and temperature to verify leak tight integrity of the system. No evidence of leakage associated with the reactor vessel lower head circumferential weld has been noted. The results of the ultrasonic examination and systern leakage test provide reasonable assurance that pressure boundary integrity has been, and will remain, maintained for this component.

Radiography as an alternative is not feasible because access is not available for film placement. No alternative examinations were planned for the weld during the Third ISI nterval.

7.0 19ATO'i OF PROPOSE AL: ERNATQ!!E Relief is requested for the Third Ten-Year Inservice Inspection (ISI) interval for Byron Station, Urits 1 and 2. For the examination categories applicable to this relief, the Third interval for Byron Station Units 1 and 2 began on January 16, 2006 and concluded on July 6, 2016.

S ,n:lar relief requests for limitations .Yesultirg in exam7rnatior coverage ess "::tan 10% have

peen previously approved for Byron Station. The Byron S.- ation Secord Irservice Inspection nrerval Relief Request, 12R-01, was condltlonally granted in an NRC Safety valuation aaZed December 30, 1908.

helory S iror SLELion

ISI Program Plari Unit 2, Third Interval 10 CFV 50.55a PEUEF F'EQUES T i3P,1 5 Revisimi 0 (Page 4 of 4)

Figure 1

-2C4' Cavitv Diame!er i +

w191" Reactor Diarneter r

BMT(1)=8.525 CONCRETE :z BUILDING STRUCTURE D BMT(1 )t2 i 2.14" i

B MT( 7.~1z WR29

=8.0" Between RPV and Building BMT(2)=5.62 Unobstructed Scan Area Trarsducer Package ~

C%Ire Support Lug ` ---- Reactor Vessei

..i .,Y. . Shell r

Obstructed

-xelon Byron Station

ISI Program Plan Unit 2. Third Inteival 10 CFR 50.55a RELIEF REQUEST 13R-15 Revision 0 ATTACHMENT A Relief Request 13R-15 Supporting Documentation Exelon Byron Station

10 CFR 50.55a Relief Request 13R-15 Attachment A 2BVSR 4.F-2.2 Attachment 4.3 2R13 COMPONENT INFORMATION Line/Vessel # 2RC-01 -R Weld/Area Number WR-29 B2R13 Observation Number WIEW61 Description Lower Shell to Bottom Head Torus ASME Code Category ASME Code Item Number WesDyne Report # / Data # FITE11 I EXAMINATION RESULTS/COMMENTS I No Recordable Indications.

Scan obstructed by core support lugs.

% of Code Required Volume Achieved: 79.25%

Applicable Relief Request: 1319-15 Number of Pages Cover Page 1 Recordable Indication Report -

Examination Report 40 TOTAL 41 Volumetric Examination Cover Sheet

10 CFR 50.55a Relief Request 13R-15 Attachment A WesDyne International Reactor Vessel Weld Results Summary

,- A~

F BYRON UNIT 2 Lower Shell to Bottom Head WELD NO. RPVC-WR29 DESCRIPTION Torus LIMITATIONS NO FX] YES F] 6 Core Support Lugs Coverage = 79.25%

RESULTS NI RI NO. OF INDICATIONS O STATUS N/A EXAM DOCUMENTATION INDICATION DOCUMENTATION FRI ANALYSIS LOG ASSESSMENT SHEET FX] ACQUISITION LOG PARAGON HARD COPY X! SCAN PRINTOUT OTHER ( specify )

I a COVERAGE BREAKDOWN

~~~1 WESDYNE ANALYST

r~ 6 BYRON UNIT 2 DIRECTION / ORIENTATION RPV COVERAGE ESTIMATE BREAKDOWNS PARALLEL SCANS CCW/CW PERP. SCANS UP/DN WELD LOWER SHELL TO BOTTOM HEAD WELD NO. RPVCWR29 DESCRIPTION TORUS BEAM ANGLES 0

BEAl1A 460 L Dual 450 L Single 450 Shear DIRECTION cn

> v CCw 81.18 81.18 81.18.

~(D

~ ~,

cw 81.18 81.18 81.18 D CD c

cn 64.18 69.80 98.0 cn UP C.0 DOWN 64.18 69.80 '` 98.0 cn TOTAL Combined Average w 79.25% ' Combfnafion of Single & Dual Sided Coverage niw.vsr ~ `~

SCANS BETWEEN LUGS SCAMS BELOW LUGS R=86.5 to Clad

-T'-1 I 1 I Exam Li. pit I 1 1 336.03 -

I l r 1 1 332.0 Top Perp 333.3 Top Parallel 0 s 1 I I I 1 340.0 C7 n

3.1.56 Cn (76.0°) O 78.5' Top Parallel Below Lugs

~ 345.5 Bottom Perp .75.3' Top Per p and D can Bottom Paratlel Below Lugs v ~

347.3 Bottom Parallel cD 345.56 (75.0°)

Exam Umit 1.1'Bottom Perp Below Lugs 5.63 D (D Cn TYPICAL CLAD

.19 e R=88.16 to Clad INDEX SIZE_

Perp Scans m 0.33' MY)

Parallei Scans - 0.5' RPVCWR29 (Westinghouse Weld 4)

Wor- ki,-.9 Pwilo t SGLN LIMITS AMA LUGS 324.56 Perp Scans +/- 7.0" rom Lug CL Parallel Scans +/- 11.0' Fran Lug ~

B YRQN UNIT 2 CBE WesDyne International Note, Perfom scans loetween Lugs first then eupand scans below Lugs Iffm LOWER SHELL TO LOWER HEAD to nanhhue coverage. EXAMINATION PROGRAM PL AN AU DWDIM°NS 11 Dwerm ma.~ '~ SHEET 15 OF 17 N