View source for LR-N09-0168, Response to Request for Additional Information Regarding Relief Request Associated with the Second Inservice Inspection (ISI) Interval

{{Adams
| number = ML092240586
| issue date = 07/28/2009
| title = Response to Request for Additional Information Regarding Relief Request Associated with the Second Inservice Inspection (ISI) Interval
| author name = Keenan J
| author affiliation = PSEG Nuclear, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000354
| license number = NPF-057
| contact person = 
| case reference number = LR-N09-0168
| document type = Letter type:LR
| page count = 23
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:PSEG Nuclear LLC P.O. Box 236,, Hancocks Bridge, NJ 08038-0236 0 PSEG NuclearL.L. C.
10 CFR 50.55a LR-N09-0168 July 28, 2009 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354

==Subject:==
Response to Request for Additional Information Regarding Relief Request Associated with the Second Inservice Inspection (ISI) Interval

==References:==
: 1) Letter from Jeffrie Keenan (PSEG Nuclear LLC) to USNRC, "Submittal of Relief Request Associated with the Second Inservice Inspection (ISI) Interval," dated December 11, 2008
: 2) Email from R. B. Ennis (USNRC) to J. Keenan (PSEG Nuclear LLC),
                 "Revised Draft RAI - Hope Creek Relief Request HC-12-RR-A25 (TAC ME0230)," dated June 9, 2009 In Reference 1, PSEG Nuclear LLC (PSEG) submitted relief request HC-12-RR-A25 for Hope Creek Generating Station (HCGS), requesting relief from specific 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.
Relief request HC-12-RR-A25 applies to the second 10-year inservice inspection (ISI) interval which ended on December 12, 2007.
In Reference 2, the NRC requested additional information. Attachment 1 to this letter provides PSEG's response.
There are no commitments contained in this letter.
11OV-7
                                                                                               /11M

i LR-N09-0168 July 28, 2009 Page 2 Should you have any questions regarding this submittal, please contact Mr. Paul Duke at 856-339-1466.
Sincerely, ager - Licensing PSEG Nuclear LLC Attachment
: 1. Response to Request for Additional Information cc:    S. Collins, Regional Administrator - NRC Region I R. Ennis, Project Manager - USNRC NRC Senior Resident Inspector - Hope Creek P. Mulligan, Manager IV, NJBNE L. Marabella, Corporate Commitment Tracking Coordinator T. Devik, Hope Creek Commitment Tracking Coordinator LR-N09-0029 Page 1 of 21 DRAFT REQUEST FOR ADDITIONAL INFORMATION RELATED TO RELIEF REQUEST HC-12-RR-A25 FOR SECOND TEN-YEAR INSERVICE INSPECTION INTERVAL HOPE CREEK GENERATING STATION DOCKET NO. 50-354

==1.0     BACKGROUND==

By letter dated December 11, 2008, (Agency wide Documents Access and Management System (ADAMS) Accession No. ML083590292) PSEG Nuclear LLC (the licensee), submitted Relief Request (RR) HC-12-RR-A25 for Hope Creek Generating Station (HCGS). The licensee requested relief from specific 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 for HCGS. RR HC-12-RR-A25 applies to the second 10-year in-service inspection (ISI) interval. The code of record for the start of the HCGS second ten-year ISI Program interval is the ASME Code, 1989 Edition, without Addenda. However, beginning with the third period of the second 10-year ISI interval, PSEG elected to perform a mid-interval update to the 1998 Edition through 2000 Addenda of the ASME Code, Section XI. The use of the later ASME Code Edition was approved in a safety evaluation (SE) issued by the Nuclear Regulatory Commission (NRC) on December 23, 2004 (ADAMS Accession No. ML043580369).
In accordance with Section 50.55a(g)(5)(iii) of Title 10 Code of FederalRegulations (10 CFR) the licensee has submitted RR HC-12-RR-A25 covering several ASME Code Class 1 and Class 2 component weld examinations. The ASME Code requires that 100 percent of the examination volumes described in ASME Code, Section Xl, Tables IWB-2500-1 and IWC-2500-1 be completed. The licensee has claimed that 100 percent of the ASME Code-required volumes are impractical to obtain at HCGS. 10 CFR 50.55a(g)(5)(iii) states that when licensees determine that conformance with ASME Code requirements is impractical at their facility, they shall submit information to support this determination.
The NRC staff, with technical assistance from Pacific Northwest National Laboratory, has reviewed the information the licensee provided that supports the subject RR and would like to discuss the following issues to clarify the submittal.
2.0     REQUEST FOR ADDITIONAL INFORMATION 2.1     HC-12-RR-25 (Part A). ASME Code, Section Xl, Category B-A, Pressure Retaining Welds in Reactor Vessel 2.1.1   Clarify, whether the reactor pressure vessel (RPV) longitudinal welds contained in HC-12-RR-[A]25 had been examined previously in the second 10-year ISI interval or whether RR-B1 submitted by letter dated May 11, 1998, as supplemented by letters dated June 16 and October 25, 1999, was requested prior to examining the subject RPV longitudinal welds in the second 10-year ISI interval.
LR-N09-0029 Page 2 of 21

===Response===
The longitudinal seam welds contained in HC-12-RR-A25 (Reference 1) Table 1 were inspected during refueling outage RF14 (Fall 2007). The welds were not inspected previously in the second 10-year ISI interval.
2.1.2  State whether the examinations that were performed from the inside of the RPV were conducted using procedures that had been successfully qualified through performance demonstration requirements of ASME Code, Section XI, Appendix VIII. Also, state whether any other longitudinal welds were examined to the full requirements of the ASME Code (using performance demonstrated procedures) and whether any indications were detected during any of the examinations.

===Response===
Examinations of the Category B-A pressure-retaining welds listed in Reference 1 Table 1 were performed from the inside of the RPV using procedures that had been successfully qualified through performance demonstration requirements of ASME Code, Section XI, Appendix VIII. The following longitudinal welds were also examined using procedures that had been successfully qualified through performance demonstration requirements of ASME Code, Section XI, Appendix VIII:
Table 2.1.2-1 Sum#       Component ID                 Description               ASME Cat       Exam Outage 100040      RPV1-W11-1      LONGITUDINAL SEAM AT 30 DEG              B-A         RF14 100045      RPV1 -W11-2    LONGITUDINAL SEAM AT 150 DEG              B-A          RF14 100050      RPV1-W11-3     LONGITUDINAL SEAM AT 270 DEG              B-A          RF14 100066      RPV1 -W1 3-1    LONGITUDINAL SEAM AT 35 DEG              B-A          RF13 100067      RPV1-W13-2     LONGITUDINAL SEAM AT 155 DEG              B-A          RF13 100068      RPV1-W13-3     LONGITUDINAL SEAM AT 275 DEG              B-A          RF13 100070      RPV1-W14-1      LONGITUDINAL SEAM AT 90 DEG              B-A          RF13 100075      RPV1-W14-2     LONGITUDINAL SEAM AT 210 DEG              B-A          RF13 100080      RPV1-W14-3     LONGITUDINAL SEAM AT 330 DEG              B-A          RF13 100085      RPV1-W15-1      LONGITUDINAL SEAM AT 18 DEG              B-A          RF13 100090      RPV1-W15-2     LONGITUDINAL SEAM AT 138 DEG              B-A          RF13 100095      RPV1-W15-3     LONGITUDINAL SEAM AT 258 DEG              B-A          RF13 No recordable indications were detected during the examinations.
2.1.3  Relief request HC-12-RR-25 provided Figure 4 as a supporting sketch to demonstrate that the RPV closure head Weld RPV1-W20 cannot be examined to the full extent required by the ASME Code. However, the dimensions on this figure are not legible.
Please re-submit the drawing with legible dimensions.

===Response===
An updated sketch for RPV closure head weld RPV1-W20 is provided in Figure 2.1.3-1.
2.1.4  The licensee stated in Table 1 of the submittal that the required examination volumes for RPV longitudinal welds was 78%, per the previous NRC-approved relief (cited above).
However, a review of the NRC Safety Evaluation dated February 3, 2000, does not indicate that the ASME Code requirement of essentially 100% (as defined in ASME Code Case N-460) for the examination volume of the subject welds has been reduced.
LR-N09-0029 Page 3 of 21 The licensee should explain why it is believed that the required examination volume is 78%, as opposed to 100%, as stated in ASME Code.

===Response===
The ASME Code requires volumetric examination of essentially 100% (as defined in ASME Code Case N-460) of the length of RPV longitudinal shell welds, as defined by Figure IWB-2500-2. The Required Examination Volume in Reference 1 Table 1 refers to the estimated coverage in RR-B1.
2.2    HC-12-RR-25 (Part B), ASME Code, Section Xl, Examination Category B-D, Item B3.90, Full Penetration Welded Nozzles in Vessels The coverage sketch included in the licensee's submittal for all Examination Category B-D nozzle-to-vessel welds is labeled as "typical". Please re-submit cross-sectional sketches for each type of nozzle-to-vessel weld listed in Table 1, and/or provide full written descriptions, describing the nozzle geometries, the ASME Code-required volumes, and areas of completed coverage (near surface, inner 15 percent, and full volume) for each of the techniques used on these welds. Summarize the scanning directions and techniques, list the materials for the base metal and weld, and clarify whether the methods used have been qualified in accordance with performance demonstration requirements per ASME Code, Section XI, Appendix VIII.

===Response===
Cross-sectional sketches for each type of nozzle-to-vessel weld listed in Reference 1 Table 1 are provided in Figures 2.2-1 through 2.2-7. The scanning directions and techniques are listed in Table 2.2-1 below. The base metal for the reactor vessel shell and head is SA-533 Grade B Class 1. Base metal for the nozzles is SA-508 Class 2 Specified weld materials for carbon steel are SA-558, SA-559, or SA-233.
Except where noted, the methods used have been qualified in accordance with performance demonstration requirements per ASME Code, Section Xl, Appendix VIII.
LR-N09-0029 Page 4 of 21 Table 2.2-1 Scan         Scan                         Comments                                   TechniqueQualified Sum#         Comp ID           Description                Direction        Angle                                                                      Coverage Strt. Beam Planar- 100%
Strt. Beam Laminar- 64.7%
100200       RPV1-N2B NOZZLE TO SHELL WELD 12" RECIRC     0 to materal               45*160* exams performed from vessel shell side only    Parallel 45- 50%N 10DINLET AT 60 DEG              CW, CCW,      0/45/60    due to nozzle configuration.                           Parallel 60 - 50%                   No Downstream                                                                        Transverse 45' - 100%
Transverse 60* - 100%
Strt. Beam Planar- 100%
O0 to material                                                                    Strt. Beam Laminar - 64.7%
100205       RPV1-N2C NOZZLE TO SHELL WELD 12" RECIRC     0 to material              45"/60' exams performed from vessel shell side only    Parallel 45" - 50%
INLET AT 90 DEG              Cw,                      due to nozzle configuration.                           Parallel 60" - 50%
DownstreamTransverse                                                                           45 - 100%
Transverse 60" - 100%
Strt. Beam Planar- 100%
Strt. Beam Laminar - 64.7%
NOZZLE TO  SHELL AT WELD 1W1INLET        12" RECIRC 300 DEG           0DwstCWm to material  0/45o/60"  45"/60' due to nozzle    performed from vessel shell side only examsconfiguration.                           Parallel Parallel 45"  -50%
60" 45"
                                                                                                                                                           -50%                  No EDownstream                                                                      Transverse       - 100%
Transverse 60" - 100%
Strt. Beam Planar - 100%
Strt. Beam Laminar - 64.7%
1024OPV-2KLET  NOZZLE TON2S ATEL 330LD12REG W     1     E IR   0CW,  CCW, to material  0"/45&deg;/60" 45"/60" exams performed from vessel shell side only    Parallel 45" -50%                   N due to nozzle configuration.                           Parallel 60" -50%                   No INLET ATV330KIELEDownstream Transverse 45" - 100%
Transverse 60" - 100%
100265       RPV1-N4A    NOZZLE   TO SHELL FEEDWATER         WELD NOZZLE  AT 12" 30       CW, CCW,       50"160"   Examined from shell side only due to blend radii       Axial 60" longitudinal - 75%
DERN     E              Downstream                limiting nozzle side scan.                             Circ 50" shear- 75%                 Yes DEGREES 100270       RPV1-N4B    NOZZLE   TO SHELL FEEDWATER         WELD NOZZLE  AT 12" 90       CW, CCW,       50"160"   Examined from shell side only due to blend radii       Axial 60" longitudinal - 75%
DERN     E              Downstream                limiting nozzle side scan.                             Circ 50" shear- 75%                 Yes DEGREES Examined from shell side only due to blend radii NOZZLE TO SHELL WELD 12"                                    limiting nozzle side scan.
100275       RPV1-N4C    FEEDWATER NOZZLE AT 150            CW, CCW,       50"/60                                                           Axial 60 longitudinal - 71          Yes Weld pad from nozzle N11 C extended from toe of        Circ 50" shear- 71%
DEGREES                 Downstream weld back 25 inches. Exam was limited from 91 to 110 inches circumferentially.
NOZZLE TO SHELL WELD 12"           CW, CCW,       50"160"   Examined from shell side only due to blend radii       Axial 60" longitudinal - 75%
DERN    E               Downstream                limiting nozzle side scan.                             Circ 50" shear- 75%
DEGREES 100285       RPV1-N4E    NOZZLE TO SHELL FEEDWATER    NOZZLEWELD  12" AT 240        CW, CCW,       50"/60"   Examined from shell side only due to blend radii       Axial 60" longitudinal - 75%
DERN    E               Downstream                limiting nozzle side scan.                             Circ 50" shear- 75%                 Yes DEGREES Examined from shell side only due to blend radii NOZZLE TO SHELL WELD 12"                                    limiting nozzle side scan.
100290       RPV1-N4F    FEEDWATER    NOZZLE AT 270         CW, CCW,       50"160'                                                          Axial 60"shear-longitudinal 71% - 71%          Yes DEGREES                 Downstream                Weld pad from nozzle N11D extended from toe of         Circ 50 weld back 25 inches. Exam was limited from 91 to 110 inches circumferentially.
Strt. Beam Planar- 100%
Strt. Beam Laminar - 64.7%
NOZZLE TO SHELL WELD 10"CORE        0 to material 100295       RPV1-N5A                                       CW, CCW,      0"/45"/60" 45&deg;/60' exams performed from vessel shell side only    Parallel 45" - 50%
SPRAY INLET AT 120 DEG          Downstream                due to nozzle configuration.                           Parallel 60" - 50%                  No Transverse 45" - 100%
Transverse 60" - 100%
LR-N09-0029 Page 5 of 21 Table 2.2-1 Sum#    Camp ID               Description                  Scan          Scan                         Comments                                 Technique                   Qualified Direction        Angle                                                                   Coverage Strt. Beam Planar- 100%
0NEto material                                                                  Strt. Beam Laminar - 64.7%
100300  RPV1-N5B          SPRAYE TONHELLWETLT240DEG                       0         0 45&deg;/60' exams performed from vessel shell side only Parallel 45' - 50%
Do-P  N A Dw,/
Downatream                 due to nozzle configuration.
dTransverse                                         Parallel 60' 45'
                                                                                                                                                     - 50%                    No
                                                                                                                                                         - 100%
Transverse 600 - 100%
100320  RPV1-N8A       NOZZLE TO SHELLAT4"105 JETDEGREES PUMP     CW,  CCW,        50o/60o  Examined   fromside shellscan.
side only due to blend radii Axial      longitudinal 600 shear-INSTRUMENTATION                     Upstream                  limiting nozzle                                     Circ 50&deg;          75% - 75Ye 100325  RPV1-N8B       NOZZLE TO SHELL INSTRUMENTATION   AT4"285 JETDEGREES PUMP     CW,  CCW, Upstream         50o/60o  Examined   fromside limiting nozzle  shellscan.
side only due to blend radii Axial 60a longitudinal - 75%
Circ 50' shear- 75%                    Yes Strt. Beam Planar - 100%
NOZZLE TO SHELL WELD 4" CRD     0 to material                                                                  Strt. Beam Laminar - 64.7%
45&deg;/60&deg; exams performed from vessel shell side only Parallel 450 - 50%
100330  RPV1-N9A         HYDRAULIC RETURN AT 146        CW, CCW,      00/45&deg;/60&deg;  due to nozzle configuration.                        Parallel 60' - 50%                     No DEGREES                DownstreamTrnve45                                                                                  10 Transverse 45' - 100%
Transverse 60&deg; - 100%
100400  RPV1-N17A     NOZZLE TO SHELL 12" LPCI AT 45    CW, CCW,         50o/60o  Examined from shell side only due to blend radii    Axial 600 longitudinal - 75Yes DEG                 Downstream                 limiting nozzle side scan.                          Circ 50&deg; shear- 75%
100401  RPV1-N17B     NOZZLE TO SHELL 12" LPCI AT 135   CW, CCW,         50o/600  Examined from shell side only due to blend radii    Axial 60' longitudinal - 75Yes DEG                 Downstream                 limiting nozzle side scan.                          Circ 50&deg; shear- 75%
100403  RPV1-N17D     NOZZLE TO SHELL DEG12" LPCI AT 315   CW, CCW, Downstream        500/60o  Examined   from shell side only due to blend radii limiting nozzle side scan.                          Axial 600 longitudinal - 75Yes Circ 50' shear- 75%                    Y 100404  RPV1-N6A      NOZZLE TO HEAD 6" HEAD SPRAY      CW, CCW,         50o/60o  Examined from shell side only due to blend radii    Axial 600 longitudinal - 75Yes NOZZLE                Downstream                 limiting nozzle side scan.                          Circ 50' shear- 75%
100405  RPV1-N6B      NOZZLE TO HEAD 6" SPARE HEAD      CW, CCW,         50o/60o  Examined from shell side only due to blend radii    Axial50'   longitudinal 600 shear-        - 75Yes NOZZLE                Downstream      .          limiting nozzle side scan.                          Circ              75%
100406   RPV1-N7     NOZZLE TO HEAD 4" VENT NOZZLE      CW, CCW,         50o/60o  Examined from shell side only due to blend radii    Axial 600 longitudinal - 75%           Yes I                                    Downstream                 limiting nozzle side scan.                          Circ 50&deg; shear- 75%
LR-N09-0029 Page 6 of 21 2.3    HC-12-RR-25 (Part C). ASME Code, Section Xl, Examination Category B-G-1, Item B6.40, Reactor Vessel Flange Ligament The licensee has included, as Figure 6, a sketch depicting areas of limited scanning.
However, insufficient text is provided in order to make use of the drawing. In order to demonstrate impracticality, submit a full written description of how the cladding prevented manual scanning and describe whether smaller diameter search units could be used to scan the ASME Code required area to increase coverage.

===Response===
The 1/4-inch drop/step from the lip of the cladding seal surface allows a 3/8-inch land area between the stud hole and the cladding raised seal surface, preventing the transducer from accessing the limited area shown on Reference 1 Figure 6. The examination was performed under a non-PDI procedure and a smaller transducer was not considered at the time of the examination. Smaller transducers will be considered for future examinations to gain more information on the ligament land area between the cladding lip and stud hole. To date, PSEG is unaware of any instance of rejectable indications being found as a result of ASME ligament examinations required by category B-G-1 Item 6.40 2.4    HC-12-RR-25 (Part D), ASME Code, Section Xl, Examination Category B-J, Item B9.11. Pressure Retaining Welds in Piping NPS 4 inches and Larger The coverage sketches included in the licensee's submittal for all ASME Code, Section XI, Examination Category B-J piping welds are not adequate to fully describe impracticality.
a) Provide descriptions of the ultrasonic techniques deployed for each weld examination volume, and the amount of coverage obtained for each of these techniques. Also, provide cross-sectional drawings showing scanning angle coverage obtained. List the materials for the base metal and weld.

===Response===
Descriptions of the ultrasonic techniques deployed for each weld examination volume, the amount of coverage obtained for each of these techniques and the materials for the base metal and weld, where available, are listed in Table 2.4-1 below. Profile sketches are provided in Figures 7 through 13 in Reference 1.
LR-N09-0029 Page 7 of 21 Table 2.4-1 Sum#    Comp ID         Description         Scan     Scan                                Comments                                   Technique         Base metal /
Direction  Angle                                                                           Coverage              Weld CW, CCW,   45&deg;/60&deg;  No examination from downstream side due to reducing tee            Axial US - 50%       A-358 CL.1 304/
105890 1-BB-28VCA   PIPE TO REDUCING TEE Downstream           configuration. Circumferential scans (clockwise & counter-         Axial DS - 50%
013-6-R2                                            clockwise) were limited to upstream side only.                     Circ CW - 50%          A-403 WP304 Circ CCW - 50%
CW, CCW      45'    Examination limited to clockwise and counter-clockwise scanning    Axial US -0%           Carbon steel 108105  1-BC-6DBA-     VALVE TO FLNGE                         due to configuration of valve and flange.                          Axial DS -0%
003-21                                                                                                                Circ CW - 66.67%
Circ CCW - 66.67%
CW, CCW,   45&deg;/60'  Examination limited to the upstream side of the weld by the weld   Axial US -60.4%     SA-358 CL.1 304L /
109170 1-BC-12CCA-  PIPE TO REDUCING TEE  Upstream,           and tee configuration.                                             Axial DS - 60.4%  Root SFA-5.9 ER308L /
116-5                        Downstream                                                                              Circ CW - 100%         A-403 WP304 Circ CCW - 100%
CW, CCW,   45&deg;/70&deg;  No examination on the upstream side due to weldolet                Axial US -50%          A-182 F304 /
110200  1-BG-4CCA-    WELDOLET TO PIPE    Upstream            configuration.                                                     Axial DS -50%     Root SFA-5.9 ER308L /
012-1                                                                                                                Circ CW - 50%         SA-312 TP304L Circ CCW - 50%
CW, CCW,   45&deg;/70'  No examination on the upstream side due to weldolet                Axial US -50.48%       A-182 F304 /
110230  1-BG-4CCA-    WELDOLETTO PIPE     Upstream            configuration.                                                     Axial DS -50.48%  Root SFA-5.9 ER308L /
011-1                                                                                                                Circ CW - 50.48%      SA-312 TP304L Circ CCW - 50.48%
CW, CCW,   45&deg;/70&deg;  45&deg; shear wave examination was limited due to sock-o-let location  Axial US -52.50%     SA-106 Grade B I 110432      -     A PIPE TO FLOW ELEMENT  Upstream,           in both directions. 70' shear wave exam was limited due to weld    Axial DS -52.50%  ERNiCr-3 ENICrFe-3 I 003-7A -                      Downstream           crown configuration.                                               Circ CW - 89.20%   SA-182 Grade F304L Circ CCW - 89.20%
CW, CCW,   45&deg;/70&deg;  70' shear wave exam was limited due to weld crown configuration. Axial US -52.50%   SA-182 Grade F304 /
110433  1-FC-4DBA-  FLOW ELEMENT TO PIPE  Upstream,           45' covered circ scan 100%.                                        Axial DS -52.50%  ERNiCr-3 ENICrFe-3 I 003-7B                        Downstream                                                                              Circ CW - 100%        SA-106 Grade B Circ CCW - 100%
CW, CCW,   45&deg;/70&deg;  No exam downstream due to welded pipe support on pipe side of      Axial US -65.03%       Carbon steel Upstream,           weld joint, upstream edge of limitation was positioned on upstream Axial DS -0%
1-FC-4DBA-                                            weld toe and extended downstream past downstream weld toe          Circ CW - 19.58%
110475     003-16       ELBOW TO PIPE                         preventing any downstream examination.                             Circ CCW - 19.58%
Magnetic particle exam was performed and limited to 51.846%
coverage with no recordable indications.
LR-N09-0029 Page 8 of 21 b) As applicable, describe nondestructive examination (NDE) equipment, show accessibility limitations, and discuss whether alternative methods or advanced technologies such as phased array could be employed to maximize ASME Code coverage.

===Response===
The limited examinations were completed using manual techniques. The accessibility limitations are discussed in the table above. As new ultrasonic techniques and tooling are qualified to ASME Section XI, Appendix VIII, PSEG reviews the new tooling and techniques to maximize the inspection coverage.
c) Clarify whether the methods used have been qualified in accordance with performance demonstration requirements per ASME Code, Section XI, Appendix VIII.

===Response===
The methods used were qualified in accordance with performance demonstration requirements per ASME Code, Section XI, Appendix VIII.
2.5    HC-12-RR-25 (Part E), ASME Code, Section Xl, Examination Category C-G, C6.10, Pump Casing Welds 2.5.1  The licensee's current submittal includes a request for limited surface examination coverage of Core Spray Pump Casing Weld CP-206-CSP-W2. This weld was previously submitted for the second interval in RR-C1, Part C, and evaluated in an NRC SE dated February 3, 2000. Based on the licensee's statements, it appears that only 23.4 percent of the required surface coverage was actually completed as opposed to the 73 percent originally stated in RR-C1, Part C. Please confirm that the current request is intended to correct the originally stated surface coverage, the basis for limited coverage remains the same as previously stated, and that any commitments made in RR-C1, Part C remain in place.

===Response===
The current request is intended to correct the originally stated surface coverage. The basis for limited coverage remains the same as previously stated. No commitments were made in connection with RR-C1, Part C.
2.5.2  The drawing of the Core Spray Pump included as Figure 19 in the licensee's submittal, does not adequately demonstrate limited accessibility for surface examination of Weld CP-206-CSP-W2. In this drawing, it appears that access to the weld may be sufficient for performing outside surface examination. Please submit further information to demonstrate the inaccessibility, and show the areas where limited coverage has been obtained.

===Response===
Photographs showing the limited accessibility between the concrete pedestal and core spray pump CP-206 casing are provided in Figures 2.5.2-1 and 2.5.2-2.
LR-N09-0029 Page 9 of 21 2.6    Request for Relief HC-12-RR-25 (Part F). ASME Code, Section XI. Examination Category R-A, Risk Informed Piping Examinations 2.6.1  The licensee has provided three drawings that show the coverage obtained for the subject examinations. However, insufficient text is included to describe the conditions that limit ultrasonic scanning in the circumferential directions. Please submit further written description to demonstrate impracticality. In addition, describe the ultrasonic techniques employed; it is unclear whether the examinations were performed using longitudinal and/or shear wave techniques.

===Response===
The ultrasonic techniques employed are described in Table 2.6-1 below. All angled scans were performed using shear mode.
LR-N09-0029 Page 10 of 21 Table 2.6.1-1 Sum#    Comp ID          Description             Scan         Scan                                         Comment                                          Technique Direction      Angle                                                                                           Coverage Downstream,  45&deg;/60'/70' Downstream access only. No examination performed upstream due to the            Axial US - 0%
CW, CCW                 configuration of the branch connection.                                         Axial DS - 100%
1-BB-4VCA-                                                                                                                                     Circ CW -US 0%
105585   011-1-RI  BRANCH CONNECTION TO PIPE                                                                                                           Circ CW -DS 100%
Circ CCW -US 0%
Circ CCW - DS 100%
Downstream,  45&deg;/60&deg;/70&deg; Downstream access only. No examination performed upstream due to the            Axial US - 0%
CW, CCW                 configuration of the branch connection.                                         Axial DS - 100%
105790  1-BB-4VCA- BRANCH CONNECTION TO PIPE                                                                                                           Circ. CW -US 0%
012-1-Ri                                                                                                                                      Circ. CW -DS 100%
Circ CW -US 0%
Circ CCW - DS 100%
Upstream, CW,     45&deg;     No exam performed from downstream due to configuration of valve and weld crown. Axial from US - 89.22%
1-BG-6DBA-                                CCW                                                                                                  Axial from DS - 0%
109810    001-29         PIPE TO VALVE                                                                                                                 Circ CW- 71.53%
Circ CCW - 71.53%
LR-N09-0029 Page 11 of 21 2.6.2  Also, clarify whether any other welds could have been substituted and examined instead of Welds 1-BB-4VCA-011-1-Ri, 1-BB-4VCA-011(2)-1-R1, and 1-BG-6DBA-001-29. If no other welds could have been examined; please explain why.

===Response===
As noted in Reference 1 Table 1, the examinations for 1-BB-4VCA-011 R1 and 1-BB-4VCA-012-1-Ri were both pre-service examinations. Therefore, no other welds could have been examined.
1-BG-6DBA-001-29 is in a risk segment with two other welds. All welds in the segment have been selected; therefore, no other welds are available for selection.
2.6.3  In addition to the bases for impracticality, state whether any outside diameter surface feature, such as weld crown, diametrical weld shrinkage, or surface roughness conditions caused limited volumetric coverage during the subject piping weld examinations. Discuss the efforts that were used to correct these conditions.

===Response===
The weld crown on 1-BG-6DBA-001-29 caused some limitation in volumetric coverage.
However, flat topping the pipe to valve weld crown would not provide significantly better coverage, as the valve body taper will still lift the shoe in the limited area.
2.6.4  Clarify whether the methods used to examine the subject piping weld have been qualified in accordance with performance demonstration requirements per ASME Code, Section XI, Appendix VIII.

===Response===
The methods used to examine the subject piping weld have been qualified in accordance with performance demonstration requirements per ASME Code, Section Xl, Appendix VIII.
References
: 1. Letter from Jeffrie Keenan (PSEG Nuclear LLC) to USNRC, "Submittal of Relief Request Associated with the Second Inservice Inspection (ISI) Interval," dated December 11, 2008

LR-N09-0029 Page 12 of 21 Figure 2.1.3-1 Limitation Due to Reactor Vessel Closure Head to Flange Configuration 12.5 3,2"            6Q"TIP 601p              WAJ LR-N09-0029 Page 13 of 21 Figure 2.2-1 D
E RECIRCULATION INLET NOZZLE N2 SCANTRANSVERSE IN ONEOECTION  ONLY LR-N09-0029 Page 14of21 Figure 2.2-2 D
FEEDWATER NOZZLE ASSEMBLY N4 LIMiATION IDUETO NOZZLE GEOkEW SCk~NN    TRANVERSE IN ONE DIRCTION ONLY LR-N09-0029 Page 15 of 21 Figure 2.2-3 HI CORE SPRAY NOZZLE N5 OLE
       - LIMITED    TO NMZIEGEOMETR(
TPANSVERSE IN SCAPOOJE ONEDWECTION  ON-Y LR-N09-0029 Page 16 of 21 Figure 2.2-4 D
HEAD SPRAY NOZZLE ASSEMBLY N6A LR-N09-0029 Page 17 of 21 Figure 2.2-5 E F GH VENT NOZZLE ASSEMBLY N7 LR-N09-0029 Page 18 of 21 Figure 2.2-6 I)
                                           .2 r~'' =
CONTROL ROD DRIVE AND SYSTEM RETURN NOZZLE N9 JET PUMP INSTRUMENTATION   NOZZLE N8 LR-N09-0029 Page 19 of 21 Figure 2.2-7 N
I/!
ASSEMBLY DETAIL LPCI NOZZLE N17 LR-N09-0029 Page 20 of 21 Figure 2.5.2-1 CP206 LR-N09-0029 Page 21 of 21 Figure 2.5.2-2 P.::9lnr}}