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| issue date = 05/09/2012
| issue date = 05/09/2012
| title = Inservice Inspection Program Fourth Ten-Year Interval Limitation to Examination Relief Request No. RR-G-5, Supplement and Response to Request for Additional Information
| title = Inservice Inspection Program Fourth Ten-Year Interval Limitation to Examination Relief Request No. RR-G-5, Supplement and Response to Request for Additional Information
| author name = Price J A
| author name = Price J
| author affiliation = Dominion, Dominion Energy Kewaunee, Inc
| author affiliation = Dominion, Dominion Energy Kewaunee, Inc
| addressee name =  
| addressee name =  
Line 14: Line 14:
| page count = 44
| page count = 44
| project =  
| project =  
| stage = Response to RAI
| stage = Supplement
}}
}}


=Text=
=Text=
{{#Wiki_filter:Dominion Energy Kewaunee, Inc. 0 5000 Dominion Boulevard, Glen Allen, VA 23060 _.Dominionll May 9, 2012 ATTN: Document Control Desk Serial No. 12-247 U. S. Nuclear Regulatory Commission LIC/JG/RO Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.KEWAUNEE POWER STATION INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL LIMITATION TO EXAMINATION RELIEF REQUEST NO. RR-G-5 SUPPLEMENT AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By application dated September 28, 2011 (Reference 1), Dominion Energy Kewaunee, Inc. (DEK), requested approval, pursuant to the provisions of 10 CFR 50.55a(g)(5)(iii), of relief request RR-G-5 for the Fourth Ten-year Interval of the Inservice Inspection (ISI)Program for Kewaunee Power Station (KPS). That submittal requested relief from inspecting those areas that either could not be examined in accordance with American Society of Mechanical Engineers (ASME) Section Xl Code requirements or could not be examined without significant modifications to the plant.Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the relief request (Reference 2). The RAI questions and associated DEK responses are provided in Attachment 1 to this letter.Independent of the above, DEK has removed certain welds associated with four of the individual relief requests submitted in Reference  
{{#Wiki_filter:Dominion Energy Kewaunee, Inc.                                                   0 5000 Dominion Boulevard, Glen Allen, VA 23060                 _.Dominionll May 9, 2012 ATTN: Document Control Desk                                         Serial No. 12-247 U. S. Nuclear Regulatory Commission                                 LIC/JG/RO Washington, DC 20555-0001                                           Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.
: 1. These welds were removed in conjunction with a modification of the auxiliary feed water system and no longer exist.This weld removal has obviated the need for those four specific relief requests.Therefore, DEK hereby supplements Reference 1 by requesting withdrawal of the following four relief requests submitted therein:* RR-G-5-32:
KEWAUNEE POWER STATION INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL LIMITATION TO EXAMINATION RELIEF REQUEST NO. RR-G-5 SUPPLEMENT AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By application dated September 28, 2011 (Reference 1), Dominion Energy Kewaunee, Inc. (DEK), requested approval, pursuant to the provisions of 10 CFR 50.55a(g)(5)(iii),
3" Auxiliary Feedwater Circumferential Weld AFW-W194* RR-G-5-34:
of relief request RR-G-5 for the Fourth Ten-year Interval of the Inservice Inspection (ISI)
3" Auxiliary Feedwater Circumferential Weld AFW-W1 96* RR-G-5-35:
Program for Kewaunee Power Station (KPS). That submittal requested relief from inspecting those areas that either could not be examined in accordance with American Society of Mechanical Engineers (ASME) Section Xl Code requirements or could not be examined without significant modifications to the plant.
3" Auxiliary Feedwater Circumferential Weld AFW-W1 97* RR-G-5-36:
Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the relief request (Reference 2). The RAI questions and associated DEK responses are provided in Attachment 1 to this letter.
3" Auxiliary Feedwater Circumferential Weld AFW-W198 No further consideration should be afforded to the four specific relief requests listed above.
Independent of the above, DEK has removed certain welds associated with four of the individual relief requests submitted in Reference 1. These welds were removed in conjunction with a modification of the auxiliary feed water system and no longer exist.
Serial No. 12-247 Relief Request RR-G-5 Response to RAI's Page 2 of 2 If you have questions or require additional information, please feel free to contact Mr.Jack Gadzala at 920-388-8604.
This weld removal has obviated the need for those four specific relief requests.
Very truly yours, J. a Price Vceesident  
Therefore, DEK hereby supplements Reference 1 by requesting withdrawal of the following four relief requests submitted therein:
-Nuclear Engineering
* RR-G-5-32: 3" Auxiliary Feedwater Circumferential Weld AFW-W194
* RR-G-5-34: 3" Auxiliary Feedwater Circumferential Weld AFW-W1 96
* RR-G-5-35: 3" Auxiliary Feedwater Circumferential Weld AFW-W1 97
* RR-G-5-36: 3" Auxiliary Feedwater Circumferential Weld AFW-W198 No further consideration should be afforded to the four specific relief requests listed above.
 
Serial No. 12-247 Relief Request RR-G-5 Response to RAI's Page 2 of 2 If you have questions or require additional information, please feel free to contact Mr.
Jack Gadzala at 920-388-8604.
Very truly yours, J. a Price Vceesident - Nuclear Engineering


==Attachment:==
==Attachment:==
Line 32: Line 39:


==References:==
==References:==
: 1. Letter from J. Alan Price (DEK) to Document Control Desk (NRC), "Inservice Inspection Program Fourth Ten-Year Interval Limitation to Examination Relief Request No. RR-G-5", dated September 28, 2011.2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "ME7378 -Kewaunee -Relief Req RR-G-5-1 to -40 Request for Additional Information (RAI)", dated March 27, 2012.Commitments made by this letter: NONE cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. Karl D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station Serial No. 12-247 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. RR-G-5 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM (JUNE 16, 2004- JUNE 16, 2014)1ST PERIOD AND 2ND PERIOD KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
: 1. Letter from J. Alan Price (DEK) to Document Control Desk (NRC), "Inservice Inspection Program Fourth Ten-Year Interval Limitation to Examination Relief Request No. RR-G-5", dated September 28, 2011.
Serial No. 12-247 Attachment 1 Page 1 of 15 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. RR-G-5 On March 27, 2012, the NRC transmitted to Dominion Energy Kewaunee, (DEK) a request for additional information (RAI) (Reference  
: 2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "ME7378 -
: 1) concerning Request for Relief (RR) RR-G-05, from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components," for Kewaunee Power Station (KPS).The RAI questions are provided below, followed by the DEK response.NRC Question ME7378-RAII-EPNB-McL-2.1-2012-04-27 General Information Required on Request for Relief RR-G-05 In Attachment 1 of the licensee's submittal, DEK provided a general summary of the relief request. Under a section entitled ASME Code Requirements and the Basis for Relief, the licensee states the following:
Kewaunee - Relief Req RR-G-5-1 to -40 Request for Additional Information (RAI)",
Volumetric and surface examinations of welds and base material will be examined in accordance with the applicable  
dated March 27, 2012.
[ASME Code, Section Xl,] Examination Category and Item Number and as required by the [KPS7 Risk Informed Program.During the performance of scheduled examinations, there were numerous instances where examiners reported some type of interference.
Commitments made by this letter: NONE cc:     Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. Karl D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station
DEK personnel evaluated every instance where this situation was reported, and when possible, alternative examination areas were selected to avoid having to examine restricted areas.Piping welds that were selected that still necessitated limited examination (i.e. less than or equal to 90% coverage) were those included in the KPS Fourth Ten-Year Inservice Inspection program to ensure examinations were performed on a representative sample of piping welds and piping welds that were not previously examined during the first 30 years of plant operation.
 
There are two risk informed program methodologies that are generally accepted for use by the NRC; they have been developed by the Electrical Power Research Institute (EPRI) and the Westinghouse Owners Group (WOG) and are documented in Topical Report TR-1 12657, Revised Risk-Informed Inservice Inspection Evaluation Procedure, Revision B-A, and Topical Report WCAP-14572, Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report, Revision 1-NP-A, respectively.
Serial No. 12-247 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. RR-G-5 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM (JUNE 16, 2004- JUNE 16, 2014) 1ST PERIOD AND 2ND PERIOD KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
The two programs use either ASME Code Case N-578-1 (Endnote 1)' Risk-Informed Requirements for Class 1, 2 or 3 Piping, Method B Section X1, or Code Case N-577 (Endnote 1), Risk-Informed Requirements for Class 1, 2 or 3 Serial No. 12-247 Attachment 1 Page 2 of 15 Piping, Method A, both of which assign a new Examination Category R-A, listing welds, or other elements, according to expected forms of degradation.
 
The ASME Categories and Item numbers included in the licensee's current request for relief appear to be for a conventional ISI program, not a risk-informed program.However, as shown in the licensee's statements above and in the data sheets provided for the specific welds listed under Category B-F, B-J, C-F-I, and C-F-2, the reviewer is lead to believe that these welds are part of a risk-informed program.Please clarify the type, either conventional ISI program or a RI-ISI program, to which each of the welds submitted for relief are included.
Serial No. 12-247 Attachment 1 Page 1 of 15 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. RR-G-5 On March 27, 2012, the NRC transmitted to Dominion Energy Kewaunee, (DEK) a request for additional information (RAI) (Reference 1) concerning Request for Relief (RR) RR-G-05, from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, "Rules for Inservice Inspection of Nuclear PowerPlant Components," for Kewaunee Power Station (KPS).
If a RI-ISI program is being implemented, provide a reference to the NRC Safety Evaluation (SE) approving this program and to which methodology (WOG or EPRI) was followed.
The RAI questions are provided below, followed by the DEK response.
If a RI-ISI program is not being implemented, state why alternative piping welds that have not been previously examined during the first 30 years of plant operation were selected for examination during the fourth interval.Response: Kewaunee Power Station (KPS) employs a risk-informed ISI program. The Fourth Interval Risk-informed Program for Class 1 and Class 2 piping at the KPS follows the guidance of Electric Power Research Institute (EPRI) Topical Report TR-1 12657 Rev.B-A, "Revised Risk-Informed Inservice Inspection Evaluation Procedure", and is consistent with ASME Boiler and Pressure Vessel Code, Section XI, Code Case N-578,"Risk-Informed Requirements for Class 1, 2, and 3 Piping Method B, Section XI, Division 1." TR-112657, Rev. B-A, is a Risk-Informed application that meets the intent and principles of NRC Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-Informed Decision Making Inservice Inspection of Piping." The KPS risk-informed program was submitted as Relief Request RR-G-1 and approved by the NRC on September 23, 2005, as a risk-informed inservice inspection (RI-ISI) alternative to the ASME Code, Section Xl, requirements (TAC Nos. MC2502, MC2508, and MC2537).DEK chose not to assign specific risk-informed program category numbers for the Class 1 and Class 2 piping welds. ASME categories were used to identify the Class 1 and Class 2 welds and a note was added to each individual weld to identify them as risk-informed welds. The risk-informed program prepared for KPS per TR-1 12657, Rev. B-A, is a separate document that lists the risk ranking for each individual Class 1 and Class 2 weld. The Class 1 and Class 2 welds were divided into the following Categories:
NRC Question ME7378-RAII-EPNB-McL-2.1-2012-04-27 General Information Required on Request for Relief RR-G-05 In Attachment 1 of the licensee's submittal, DEK provided a general summary of the relief request. Under a section entitled ASME Code Requirements and the Basis for Relief, the licensee states the following:
Serial No. 12-247 Attachment 1 Page 3 of 15 1. System 2. Risk Characterization (Segment, Category and Risk)3. Consequence (ID and Rank)4. Failure Potential (Degradation Method and Rank)5. Line in Segment 6. Welds in Segment 7. Weld Count 8. Sketch Number 9. Code Class 10. Consequence Evaluation Conditional Core Melt Potential 11. Degradation Mechanism Assessment Pipe Rupture Potential The Fourth 10-Year ISI Program (2004-2014) for KPS, which was submitted to NRC on December 16, 2003, outlined the classification of Class 1 and Class 2 Piping welds under examination categories from ASME Boiler and Pressure Vessel Code, Section XI, 1998 Edition, 2000 Addenda. A separate section of the Fourth 10-Year ISI Program (2004-2014) for KPS outlined the risk-informed program (weld risk ranking is provided in Enclosure 1 to this Attachment).
Volumetric and surface examinations of welds and base material will be examined in accordance with the applicable[ASME Code, Section Xl,] Examination Category and Item Number and as required by the [KPS7 Risk Informed Program.
During the performance of scheduled examinations, there were numerous instances where examiners reported some type of interference. DEK personnel evaluated every instance where this situation was reported, and when possible, alternative examination areas were selected to avoid having to examine restrictedareas.
Piping welds that were selected that still necessitated limited examination (i.e. less than or equal to 90% coverage) were those included in the KPS Fourth Ten-Year Inservice Inspection program to ensure examinations were performed on a representative sample of piping welds and piping welds that were not previously examined during the first 30 years of plant operation.
There are two risk informed program methodologies that are generally accepted for use by the NRC; they have been developed by the Electrical Power Research Institute (EPRI) and the Westinghouse Owners Group (WOG) and are documented in Topical Report TR-1 12657, Revised Risk-Informed Inservice Inspection Evaluation Procedure, Revision B-A, and Topical Report WCAP-14572, Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report, Revision 1-NP-A, respectively. The two programs use either ASME Code Case N-578-1(Endnote 1)' Risk-Informed Requirements for Class 1, 2 or 3 Piping, Method B Section X1, or Code Case N-577 (Endnote 1), Risk-Informed Requirements for Class 1, 2 or 3
 
Serial No. 12-247 Attachment 1 Page 2 of 15 Piping,Method A, both of which assign a new Examination Category R-A, listing welds, or other elements, according to expected forms of degradation.
The ASME Categories and Item numbers included in the licensee's current request for relief appear to be for a conventional ISI program, not a risk-informed program.
However, as shown in the licensee's statements above and in the data sheets provided for the specific welds listed under Category B-F, B-J, C-F-I, and C-F-2, the reviewer is lead to believe that these welds are part of a risk-informed program.
Please clarify the type, either conventional ISI program or a RI-ISI program, to which each of the welds submitted for relief are included. If a RI-ISI program is being implemented, provide a reference to the NRC Safety Evaluation (SE) approving this program and to which methodology (WOG or EPRI) was followed. If a RI-ISI program is not being implemented, state why alternative piping welds that have not been previously examined during the first 30 years of plant operation were selected for examination during the fourth interval.
 
===Response===
Kewaunee Power Station (KPS) employs a risk-informed ISI program. The Fourth Interval Risk-informed Program for Class 1 and Class 2 piping at the KPS follows the guidance of Electric Power Research Institute (EPRI) Topical Report TR-1 12657 Rev.
B-A, "Revised Risk-Informed Inservice Inspection Evaluation Procedure", and is consistent with ASME Boiler and Pressure Vessel Code, Section XI, Code Case N-578, "Risk-Informed Requirements for Class 1, 2, and 3 Piping Method B, Section XI, Division 1." TR-112657, Rev. B-A, is a Risk-Informed application that meets the intent and principles of NRC Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-Informed Decision Making Inservice Inspection of Piping." The KPS risk-informed program was submitted as Relief Request RR-G-1 and approved by the NRC on September 23, 2005, as a risk-informed inservice inspection (RI-ISI) alternative to the ASME Code, Section Xl, requirements (TAC Nos. MC2502, MC2508, and MC2537).
DEK chose not to assign specific risk-informed program category numbers for the Class 1 and Class 2 piping welds. ASME categories were used to identify the Class 1 and Class 2 welds and a note was added to each individual weld to identify them as risk-informed welds. The risk-informed program prepared for KPS per TR-1 12657, Rev. B-A, is a separate document that lists the risk ranking for each individual Class 1 and Class 2 weld. The Class 1 and Class 2 welds were divided into the following Categories:
 
Serial No. 12-247 Attachment 1 Page 3 of 15
: 1. System
: 2. Risk Characterization (Segment, Category and Risk)
: 3. Consequence (ID and Rank)
: 4. Failure Potential (Degradation Method and Rank)
: 5. Line in Segment
: 6. Welds in Segment
: 7. Weld Count
: 8. Sketch Number
: 9. Code Class
: 10. Consequence Evaluation Conditional Core Melt Potential
: 11. Degradation Mechanism Assessment Pipe Rupture Potential The Fourth 10-Year ISI Program (2004-2014) for KPS, which was submitted to NRC on December 16, 2003, outlined the classification of Class 1 and Class 2 Piping welds under examination categories from ASME Boiler and Pressure Vessel Code, Section XI, 1998 Edition, 2000 Addenda. A separate section of the Fourth 10-Year ISI Program (2004-2014) for KPS outlined the risk-informed program (weld risk ranking is provided in to this Attachment).
NRC Question ME7378-RAII-EPNB-McL-2.1-2012-04-27 (continued)
NRC Question ME7378-RAII-EPNB-McL-2.1-2012-04-27 (continued)
Confirm the correct RI-ISI Examination Category and Item Numbers for each of the welds listed in Table 2.1.1 below. Specifically, if a RI-ISI program is being implemented, please list the RI-ISI R-A Item Numbers in accordance with the appropriate ASME Code Case or if KPS has an unique identifying RI-ISI system based on either RI-ISI ASME Code Case clarify how to identify the welds examined.B-F B5.40 PR-W1DM PZR 6" Nozzle-to-Safe End B-F B5.40 PR-W26DM PZR 6" Nozzle-to-Safe End B-F B5.40 RC-W67DM PZR 14" Nozzle-to-Safe End B-J B9.11 PR-W27 6" PZR Relief Circumferential Weld B-J B9. 11 RC-W60 6" Reactor Coolant Circumferential Weld B-J B9.11 SI-W51 6" Safety Injection Circumferential Weld B-J B9.11 RHR-W9 8" Residual Heat Removal Circumferential Weld B-J B9.11 SI-W74 12" Safety Injection Circumferential Weld B-J B9.31 RC-W3BC 8" Reactor Coolant Pipe Branch Connection B-J 89.31 RC-W22BC 6" Reactor Coolant Pipe Branch Connection Serial No. 12-247 Attachment 1 Page 4 of 15 C-F-1 C5.13 ICS-W18bC 6" Containment Spray Circumterential Weld C-F-1 C5.13 ICS-W181 6" Containment Spray Circumferential Weld C-F-1 C5.13 RHR-W419 6" Residual Heat Removal Circumferential Weld C-F-1 C5.13 ICS-W45 8" Containment Spray Circumferential Weld C-F-1 C5.14 SI-W429 6" Safety Injection Circumferential Weld C-F-1 C5.21 Sl-W249 3" Safety Injection circumferential Weld C-F-1 C5.21 AFW-W148 3" Auxiliary Feedwater Circumferential Weld C-F-1 C5.21 AFW-W151 3" Auxiliary Feedwater Circumferential Weld C-F-1 C5.21 AFW-W152 3" Auxiliary Feedwater Circumferential Weld C-F-1 C5.21 AFW-W155 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W156 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W171 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W172 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W178 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W189 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W19O 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W191 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W192 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W194 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W195 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W196 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W197 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W198 3" Auxiliary Feedwater Circumferential Weld Response: The piping welds listed in Table 2.1.1 were examined per the requirements of EPRI TR-112657, Rev. B-A, and consistent with ASME Boiler and Pressure Vessel Code, Section Xl, Code Case N-578, "Risk-Informed Requirements for Class 1, 2, and 3 Piping Method B Section Xl, Division 1." TR-112657, Rev. B-A, is a Risk-Informed application that meets the intent and principles of NRC Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-Informed Decision Making Inservice Inspection of Piping." Weld risk ranking is provided in Enclosure 1 to this Attachment.
Confirm the correct RI-ISI Examination Category and Item Numbers for each of the welds listed in Table 2.1.1 below. Specifically, if a RI-ISI program is being implemented, please list the RI-ISI R-A Item Numbers in accordance with the appropriate ASME Code Case or if KPS has an unique identifying RI-ISI system based on either RI-ISI ASME Code Case clarify how to identify the welds examined.
B-F       B5.40       PR-W1DM       PZR 6" Nozzle-to-Safe End B-F       B5.40     PR-W26DM       PZR 6" Nozzle-to-Safe End B-F       B5.40     RC-W67DM       PZR 14" Nozzle-to-Safe End B-J       B9.11       PR-W27     6" PZR Relief Circumferential Weld B-J       B9. 11       RC-W60     6" Reactor Coolant Circumferential Weld B-J       B9.11         SI-W51     6" Safety Injection Circumferential Weld B-J       B9.11       RHR-W9     8" Residual Heat Removal Circumferential Weld B-J       B9.11         SI-W74     12" Safety Injection Circumferential Weld B-J       B9.31       RC-W3BC     8" Reactor Coolant Pipe Branch Connection B-J       89.31     RC-W22BC     6" Reactor Coolant Pipe Branch Connection
 
Serial No. 12-247 Attachment 1 Page 4 of 15 C-F-1     C5.13     ICS-W18bC     6" Containment Spray Circumterential Weld C-F-1     C5.13     ICS-W181       6" Containment Spray Circumferential Weld C-F-1     C5.13     RHR-W419       6" Residual Heat Removal Circumferential Weld C-F-1     C5.13       ICS-W45       8" Containment Spray Circumferential Weld C-F-1     C5.14       SI-W429       6" Safety Injection Circumferential Weld C-F-1     C5.21       Sl-W249       3" Safety Injection circumferential Weld C-F-1     C5.21     AFW-W148       3" Auxiliary Feedwater Circumferential Weld C-F-1     C5.21     AFW-W151       3" Auxiliary Feedwater Circumferential Weld C-F-1     C5.21     AFW-W152       3" Auxiliary Feedwater Circumferential Weld C-F-1     C5.21     AFW-W155       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W156       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W171       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W172       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W178       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W189       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W19O       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W191       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W192       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W194       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W195       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W196       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W197       3" Auxiliary Feedwater Circumferential Weld C-F-2     C5.61     AFW-W198       3" Auxiliary Feedwater Circumferential Weld
 
===Response===
The piping welds listed in Table 2.1.1 were examined per the requirements of EPRI TR-112657, Rev. B-A, and consistent with ASME Boiler and Pressure Vessel Code, Section Xl, Code Case N-578, "Risk-Informed Requirements for Class 1, 2, and 3 Piping Method B Section Xl, Division 1." TR-112657, Rev. B-A, is a Risk-Informed application that meets the intent and principles of NRC Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-Informed Decision Making Inservice Inspection of Piping." Weld risk ranking is provided in Enclosure 1 to this Attachment.
 
Serial No. 12-247 Attachment 1 Page 5 of 15 NRC Question ME7378-RAII-EPNB-McL-2.1-2012-04-27 (continued)
Serial No. 12-247 Attachment 1 Page 5 of 15 NRC Question ME7378-RAII-EPNB-McL-2.1-2012-04-27 (continued)
In addition, if the welds listed in Table 2.1.1 above were examined under a RI-ISI program: a) Please state the total number of Class 1 and Class 2 piping welds included in the overall risk-informed program so that the 33 limited examinations can be assessed within the scope of all examinations being implemented.
In addition, if the welds listed in Table 2.1.1 above were examined under a RI-ISI program:
b) Please confirm whether the ultrasonic (UT) examination methods for all piping welds listed in Table 2.1.1 were conducted in accordance with the performance demonstration requirements of ASME Code, Section XI, Appendix VIII.c) Further discuss whether additional welds could have been examined to augment the reduced volumetric coverage resulting from the limited examinations of the subject welds.d) Please state whether any alternative examination such as full surface examination was performed on each of the ASME Code Class 1 and Class 2 piping welds. The staff notes that surface examination is not required for most of the damage mechanisms listed in Table 1 of ASME Code Case N-577 or N-578. Also, please state whether any indications were discovered as a result of surface examinations.
a) Please state the total number of Class 1 and Class 2 piping welds included in the overall risk-informed program so that the 33 limited examinations can be assessed within the scope of all examinations being implemented.
Response: a) KPS has 650 Class 1 welds and 1191 Class 2 welds in the total risk-informed population.
b) Please confirm whether the ultrasonic (UT) examination methods for all piping welds listed in Table 2.1.1 were conducted in accordance with the performance demonstration requirements of ASME Code, Section XI, Appendix VIII.
Table 2.1.1 (above) lists 33 Class 1 and Class 2 piping welds with limitations.
c) Further discuss whether additional welds could have been examined to augment the reduced volumetric coverage resulting from the limited examinations of the subject welds.
However, four of these welds are being withdrawn from consideration for relief with this supplement.
d) Please state whether any alternative examination such as full surface examination was performed on each of the ASME Code Class 1 and Class 2 piping welds. The staff notes that surface examination is not required for most of the damage mechanisms listed in Table 1 of ASME Code Case N-577 or N-578. Also, please state whether any indications were discovered as a result of surface examinations.
Therefore, only the remaining 29 welds remain applicable to this question.
 
Thirteen of those 29 welds were checked during preservice examinations and the remaining 16 welds were checked during inservice examinations.
===Response===
An additional 65 Class 1 and Class 2 risk-informed inservice welds (without limitations) were examined during the 1 st and 2 nd Periods of the Fourth Ten Year interval and received the requisite greater than 90% coverage.
a) KPS has 650 Class 1 welds and 1191 Class 2 welds in the total risk-informed population. Table 2.1.1 (above) lists 33 Class 1 and Class 2 piping welds with limitations. However, four of these welds are being withdrawn from consideration for relief with this supplement. Therefore, only the remaining 29 welds remain applicable to this question. Thirteen of those 29 welds were checked during preservice examinations and the remaining 16 welds were checked during inservice examinations. An additional 65 Class 1 and Class 2 risk-informed inservice welds (without limitations) were examined during the 1 st and 2 nd Periods of the Fourth Ten Year interval and received the requisite greater than 90% coverage. Sixteen Class 1 and 27 Class 2 risk-informed welds are scheduled for the 3 rd period.
Sixteen Class 1 and 27 Class 2 risk-informed welds are scheduled for the 3 rd period.b) The welds listed in Table 2.1.1 were examined in accordance with the performance demonstration requirements of ASME Code, Section XI, Appendix VIII (Supplement 2 or Supplement 3, as applicable), except for the following two welds: 1. ASME Category B-J Code Item B9.31, Weld RC-W3BC, 8" Reactor Coolant Pipe Branch Connection Serial No. 12-247 Attachment 1 Page 6 of 15 2. ASME Category B-J Code Item B9.31, Weld RC-W22BC, 6" Reactor Coolant Pipe Branch Connection Weld RC-W3BC and Weld RC-W22BC branch connections were not initially examined to Appendix VIII, Supplement 2 requirements because PDI Supplement 2 qualifications were not considered demonstrated for branch connections using Electric Power Research Institute (EPRI) Performance Demonstration Initiative (PDI)Generic Procedure PDI-UT-2, Revision C, "PDI Generic Procedure for the Ultrasonic Examination of Austenitic Welds." However, subsequent discussions with the PDI Steering Committee (reference PDI Inquiry 2008-02; provided in Enclosure 2 to this Attachment) determined that branch connections, in fact, can be examined using PDI Generic Procedure PDI-UT-2.
b) The welds listed in Table 2.1.1 were examined in accordance with the performance demonstration requirements of ASME Code, Section XI, Appendix VIII (Supplement 2 or Supplement 3, as applicable), except for the following two welds:
Therefore, during the 3 rd Examination period at KPS, two branch connections were examined using the ASME Section XI Appendix VIII Supplement 2 procedure.
: 1. ASME Category B-J Code Item B9.31, Weld RC-W3BC, 8" Reactor Coolant Pipe Branch Connection
Specifically, RC-W3BC was reexamined and RC-W34BC was examined as a substitute for RC-W22BC.
 
These welds were examined using 450 shear, 600 shear, and 600 longitudinal.
Serial No. 12-247 Attachment 1 Page 6 of 15
The coverage for RC-W3BC and RC-W34BC were 25% best effort coverage and ASME Code coverage of 50% due to one-sided examination for the stainless steel pipe to nozzle configuration.
: 2. ASME Category B-J Code Item B9.31, Weld RC-W22BC, 6" Reactor Coolant Pipe Branch Connection Weld RC-W3BC and Weld RC-W22BC branch connections were not initially examined to Appendix VIII, Supplement 2 requirements because PDI Supplement 2 qualifications were not considered demonstrated for branch connections using Electric Power Research Institute (EPRI) Performance Demonstration Initiative (PDI)
PDI-UT-2, Revision C, is not qualified for detection or length sizing of circumferentially oriented flaw indications when only single side access is available and the flaw is located on the far side of the weld. However, examination guidance is provided.
Generic Procedure PDI-UT-2, Revision C, "PDI Generic Procedure for the Ultrasonic Examination of Austenitic Welds." However, subsequent discussions with the PDI Steering Committee (reference PDI Inquiry 2008-02; provided in Enclosure 2 to this Attachment) determined that branch connections, in fact, can be examined using PDI Generic Procedure PDI-UT-2. Therefore, during the 3 rd Examination period at KPS, two branch connections were examined using the ASME Section XI Appendix VIII Supplement 2 procedure. Specifically, RC-W3BC was reexamined and RC-W34BC was examined as a substitute for RC-W22BC. These welds were examined using 450 shear, 600 shear, and 600 longitudinal.
The techniques identified in this procedure have been demonstrated to be representative of the "best effort" technology for single side detection of far side defects parallel to the weld. PDI-UT-2 is not qualified for length sizing of axially oriented flaws regardless of location.Note: RC-W3BC and RC-W34BC -50% Limitation Relief Request is expected to be submitted at the end of the 3 rd Period examinations.
The coverage for RC-W3BC and RC-W34BC were 25% best effort coverage and ASME Code coverage of 50% due to one-sided examination for the stainless steel pipe to nozzle configuration. PDI-UT-2, Revision C, is not qualified for detection or length sizing of circumferentially oriented flaw indications when only single side access is available and the flaw is located on the far side of the weld. However, examination guidance is provided. The techniques identified in this procedure have been demonstrated to be representative of the "best effort" technology for single side detection of far side defects parallel to the weld. PDI-UT-2 is not qualified for length sizing of axially oriented flaws regardless of location.
c) Piping welds that were selected and recieved limited examination (i.e., less than or equal to 90% coverage) were those welds included in the KPS Fourth Ten-Year Inservice Inspection program to ensure examinations were performed on a representative sample of piping welds and piping welds that were not previously examined during the first 30 years of plant operation.
Note: RC-W3BC and RC-W34BC - 50% Limitation Relief Request is expected to be submitted at the end of the 3 rd Period examinations.
Different Class 1 and Class 2 welds could have been selected that would have had coverage greater than 90%;however, those welds would not have been a representative sample and would have been previously examined with acceptable results. Typical welds that would achieve greater than 90% coverage include pipe-to-pipe welds and pipe-to-elbow welds.Typical welds that would not achieve greater than 90% coverage include stainless steel pipe-to-valve welds and stainless steel pipe-to-flange welds. KPS chose not to exclude these types of welds because a representative sample would not have been achieved.
c) Piping welds that were selected and recieved limited examination (i.e., less than or equal to 90% coverage) were those welds included in the KPS Fourth Ten-Year Inservice Inspection program to ensure examinations were performed on a representative sample of piping welds and piping welds that were not previously examined during the first 30 years of plant operation. Different Class 1 and Class 2 welds could have been selected that would have had coverage greater than 90%;
As previously stated, Table 2.1.1 (above) lists 33 Class 1 and Class 2 piping welds with limitations.
however, those welds would not have been a representative sample and would have been previously examined with acceptable results. Typical welds that would achieve greater than 90% coverage include pipe-to-pipe welds and pipe-to-elbow welds.
However, four of these welds are being withdrawn Serial No. 12-247 Attachment 1 Page 7 of 15 from consideration for relief with this supplement.
Typical welds that would not achieve greater than 90% coverage include stainless steel pipe-to-valve welds and stainless steel pipe-to-flange welds. KPS chose not to exclude these types of welds because a representative sample would not have been achieved. As previously stated, Table 2.1.1 (above) lists 33 Class 1 and Class 2 piping welds with limitations. However, four of these welds are being withdrawn
Therefore, only the remaining 29 welds remain applicable to this question.
 
Thirteen of those 29 welds were checked during preservice examinations and the remaining 16 welds were checked during inservice examinations.
Serial No. 12-247 Attachment 1 Page 7 of 15 from consideration for relief with this supplement. Therefore, only the remaining 29 welds remain applicable to this question. Thirteen of those 29 welds were checked during preservice examinations and the remaining 16 welds were checked during inservice examinations. An additional 65 Class 1 and Class 2 risk-informed inservice welds (without limitations) were examined during the 1 st and 2 nd Periods of the Fourth Ten Year interval and received the requisite greater than 90% coverage.
An additional 65 Class 1 and Class 2 risk-informed inservice welds (without limitations) were examined during the 1 st and 2 nd Periods of the Fourth Ten Year interval and received the requisite greater than 90% coverage.d) Full surface examinations were performed on 100% of the welds listed in Table 2.1.1 (above). No indications were recorded on those welds that exceeded ASME Boiler and Pressure Vessel Code, Section Xl, 1998 Edition, 2000 Addenda recording requirements.
d) Full surface examinations were performed on 100% of the welds listed in Table 2.1.1 (above). No indications were recorded on those welds that exceeded ASME Boiler and Pressure Vessel Code, Section Xl, 1998 Edition, 2000 Addenda recording requirements. VT-2 Visual examination for leakage was also performed on each of those welds per ASME Boiler and Pressure Vessel Code, Section Xl, 1998 Edition, 2000 Addenda, Examination Category B-P, Examination Category C-H, and IWA-4540, as applicable, and no indications were recorded.
VT-2 Visual examination for leakage was also performed on each of those welds per ASME Boiler and Pressure Vessel Code, Section Xl, 1998 Edition, 2000 Addenda, Examination Category B-P, Examination Category C-H, and IWA-4540, as applicable, and no indications were recorded.NRC Question ME7378-RAII-EPNB-McL-2.2-2012-04-27 Request for Relief RR-G-05, Part A, ASME Code, Section Xl, Examination Category B-D, Item B3.90, Full Penetration Welded Nozzles in Vessels Confirm that the UT examination methods used have been qualified in accordance with the performance demonstration requirements of ASME Section Xl, Appendix VIII.Response: Ultrasonic examination methods used on reactor vessel nozzle to vessel welds RV-W7 and RV-W1O, Examination Category B-D, Item Number B3.90, were qualified in accordance with the performance demonstration requirements of ASME Section XI, Appendix VIII (performed using WESDYNE International approved ASME Section XI, Appendix VIII, procedure PDI-ISI-254-NZ and PDI-1SI-254).
NRC Question ME7378-RAII-EPNB-McL-2.2-2012-04-27 Request for Relief RR-G-05, Part A, ASME Code, Section Xl, Examination Category B-D, Item B3.90, Full Penetration Welded Nozzles in Vessels Confirm that the UT examination methods used have been qualified in accordance with the performance demonstration requirements of ASME Section Xl, Appendix VIII.
 
===Response===
Ultrasonic examination methods used on reactor vessel nozzle to vessel welds RV-W7 and RV-W1O, Examination Category B-D, Item Number B3.90, were qualified in accordance with the performance demonstration requirements of ASME Section XI, Appendix VIII (performed using WESDYNE International approved ASME Section XI, Appendix VIII, procedure PDI-ISI-254-NZ and PDI-1SI-254).
NRC Question ME7378-RAII-EPNB-McL-2.3-2012-04-27 Request for Relief RR-G-5, Part B, ASME Code, Section Xl, Examination Category B-F, Item B5.40, Pressure Retaininq Dissimilar Metal Welds In Vessel Nozzles The coverage percentages provided in the licensee's submittal appear to be only from the 45- and 60-degree UT scans performed on the welds. Please state whether any additional "best effort" coverage was obtained using the 35-, 42-, and 50-degree L-wave scans, as applicable.
NRC Question ME7378-RAII-EPNB-McL-2.3-2012-04-27 Request for Relief RR-G-5, Part B, ASME Code, Section Xl, Examination Category B-F, Item B5.40, Pressure Retaininq Dissimilar Metal Welds In Vessel Nozzles The coverage percentages provided in the licensee's submittal appear to be only from the 45- and 60-degree UT scans performed on the welds. Please state whether any additional "best effort" coverage was obtained using the 35-, 42-, and 50-degree L-wave scans, as applicable.
Serial No. 12-247 Attachment 1 Page 8 of 15 Response: The following Examination Category B-F, Item No. B5.40, Pressure Retaining Welds were examined using the stated angles to achieve the maximum coverage as shown on the previously provided data sheets.* PR-W1DM: 450 Shear, 350 Longitudinal, 450 Longitudinal, 600 Longitudinal
 
* PR-W26DM:
Serial No. 12-247 Attachment 1 Page 8 of 15
450 Shear, 350 Longitudinal, 450 Longitudinal, 600 Longitudinal
 
* PR-W67DM:
===Response===
450 Shear, 400 Longitudinal, 420 Longitudinal, 500 Longitudinal, 600 Longitudinal NRC Question ME7378-RAII-EPNB-McL-2.4-2012-04-27 Request for Relief RR-G-5, Part C, ASME Code, Section Xl, Examination Category B-J.Items B9.11 and B9.31, Pressure Retaining Welds in Piping The licensee's submittal states that the subject weld areas in ASME Code, Section XI, Category B-J, Item B9.31 were interrogated with a combination of 34-, 45- and 60-degree shear waves. The licensee's submittal further states that examinations were performed as single-sided examinations from the pipe side of the welds.Confirm the insonification angles and wave modalities used to examine each of the subject-welds in ASME Code, Section XI, Category B-J, Item B9.31. If only shear wave techniques were used to examine the subject stainless steel welds, please explain why refracted longitudinal wave techniques were not used as part of a "best effort" examination.
The following Examination Category B-F, Item No. B5.40, Pressure Retaining Welds were examined using the stated angles to achieve the maximum coverage as shown on the previously provided data sheets.
The L-wave method has been shown capable of detecting planar inside diameter (ID) surface-breaking flaws on the far-side of wrought stainless steel welds.Recent studies (Endnotes 2, 3, 4) recommend the use of both shear and L-waves to obtain the best detection results, with minimum false calls, in austenitic welds. If both shear and L-waves were used please state the "best effort" coverage achieved on the near- and far-side of the subject weld volumes.Response: As discussed in the response to NRC Question ME7378-RAII-EPNB-McL-2.1-2012 27 (subpart b), Weld RC-W3BC and Weld RC-W22BC branch connections were not initially examined to Appendix VIII, Supplement 2 requirements because PDI Supplement 2 qualifications were not considered demonstrated for branch connections using Electric Power Research Institute (EPRI) Performance Demonstration Initiative Serial No. 12-247 Attachment 1 Page 9 of 15 (PDI) Generic Procedure PDI-UT-2, Revision C, "PDI Generic Procedure for the Ultrasonic Examination of Austenitic Welds." However, subsequent discussions with the PDI Steering Committee (reference PDI Inquiry 2008-02; provided in Enclosure 2 to this Attachment) determined that branch connections, in fact, can be examined using PDI Generic Procedure PDI-UT-2.
* PR-W1DM: 450 Shear, 350 Longitudinal, 450 Longitudinal, 600 Longitudinal
Therefore, during the 3 rd Examination period at KPS, two branch connections were examined using the ASME Section Xl Appendix VIII Supplement 2 procedure.
* PR-W26DM: 450 Shear, 350 Longitudinal, 450 Longitudinal, 600 Longitudinal
RC-W3BC was reexamined and RC-W34BC was examined as a substitute for RC-W22BC.
* PR-W67DM: 450 Shear, 400 Longitudinal, 420 Longitudinal, 500 Longitudinal, 600 Longitudinal NRC Question ME7378-RAII-EPNB-McL-2.4-2012-04-27 Request for Relief RR-G-5, Part C, ASME Code, Section Xl, Examination Category B-J.
These welds were examined using 450 shear, 600 shear, and 600 longitudinal.
Items B9.11 and B9.31, Pressure Retaining Welds in Piping The licensee's submittal states that the subject weld areas in ASME Code, Section XI, Category B-J, Item B9.31 were interrogated with a combination of 34-, 45- and 60-degree shear waves. The licensee's submittal further states that examinations were performed as single-sided examinations from the pipe side of the welds.
The coverage for RC-W3BC and RC-W34BC were 25% best effort coverage and ASME Code coverage of 50% due to one-sided examination for the stainless steel pipe to nozzle configuration.
Confirm the insonification angles and wave modalities used to examine each of the subject-welds in ASME Code, Section XI, Category B-J, Item B9.31. If only shear wave techniques were used to examine the subject stainless steel welds, please explain why refracted longitudinal wave techniques were not used as part of a "best effort" examination. The L-wave method has been shown capable of detecting planar inside diameter (ID) surface-breaking flaws on the far-side of wrought stainless steel welds.
PDI-UT-2, Revision C, is not qualified for detection or length sizing of circumferentially oriented flaw indications when only single side access is available and the flaw is located on the far side of the weld. However, examination guidance is provided.
Recent studies (Endnotes 2, 3, 4) recommend the use of both shear and L-waves to obtain the best detection results, with minimum false calls, in austenitic welds. If both shear and L-waves were used please state the "best effort" coverage achieved on the near- and far-side of the subject weld volumes.
The techniques identified in this procedure have been demonstrated to be representative of the "best effort" technology for single side detection of far side defects parallel to the weld. PDI-UT-2 is not qualified for length sizing of axially oriented flaws regardless of location.Note: For RC-W3BC and RC-W34BC, a 50% Limitation Relief Request is expected to be submitted at the end of the 3 rd Period examinations.
 
NRC Question ME7378-RAII-EPNB-McL-2.5-2012-04-27 Request for Relief RR-G-5, Part D, ASME Code, Section Xl, Examination Category C-A, Items C1.10, C1.20, and C1.30, Pressure Retaininq Welds in Class 2 Pressure Vessels State the materials of construction and the wall thickness for the pressure vessel welds submitted under ASME Code Category C-A.Response: The following is a list of materials of construction and wall thicknesses for the pressure vessel welds submitted under ASME Code Category C-A." RR-G-5-3:
===Response===
Residual Heat Exchanger AHRS1-1A Shell Circumferential Weld AHRS1-W.1:
As discussed in the response to NRC Question ME7378-RAII-EPNB-McL-2.1-2012 27 (subpart b), Weld RC-W3BC and Weld RC-W22BC branch connections were not initially examined to Appendix VIII, Supplement 2 requirements because PDI Supplement 2 qualifications were not considered demonstrated for branch connections using Electric Power Research Institute (EPRI) Performance Demonstration Initiative
A240 TP304 Stainless Steel: 0.50" thick" RR-G-5-4:
 
Regenerative Heat Exchanger Tubesheet to Shell Circumferential Weld ARG-W1O: Shell A351 CF8 Cast Stainless Steel; Tubesheet A182 F304 Stainless Steel: 0.938" thick (both)
Serial No. 12-247 Attachment 1 Page 9 of 15 (PDI) Generic Procedure PDI-UT-2, Revision C, "PDI Generic Procedure for the Ultrasonic Examination of Austenitic Welds." However, subsequent discussions with the PDI Steering Committee (reference PDI Inquiry 2008-02; provided in Enclosure 2 to this Attachment) determined that branch connections, in fact, can be examined using PDI Generic Procedure PDI-UT-2. Therefore, during the 3 rd Examination period at KPS, two branch connections were examined using the ASME Section Xl Appendix VIII Supplement 2 procedure. RC-W3BC was reexamined and RC-W34BC was examined as a substitute for RC-W22BC. These welds were examined using 450 shear, 600 shear, and 600 longitudinal.
Serial No. 12-247 Attachment 1 Page 10 of 15" RR-G-5-5:
The coverage for RC-W3BC and RC-W34BC were 25% best effort coverage and ASME Code coverage of 50% due to one-sided examination for the stainless steel pipe to nozzle configuration. PDI-UT-2, Revision C, is not qualified for detection or length sizing of circumferentially oriented flaw indications when only single side access is available and the flaw is located on the far side of the weld. However, examination guidance is provided.         The techniques identified in this procedure have been demonstrated to be representative of the "best effort" technology for single side detection of far side defects parallel to the weld. PDI-UT-2 is not qualified for length sizing of axially oriented flaws regardless of location.
Residual Heat Exchanger AHRS1-1A Head Circumferential Weld AHRS1-W2:
Note: For RC-W3BC and RC-W34BC, a 50% Limitation Relief Request is expected to be submitted at the end of the 3 rd Period examinations.
A240 TP304 Stainless Steel: 0.50" thick" RR-G-5-37:
NRC Question ME7378-RAII-EPNB-McL-2.5-2012-04-27 Request for Relief RR-G-5, Part D, ASME Code, Section Xl, Examination Category C-A, Items C1.10, C1.20, and C1.30, Pressure Retaininq Welds in Class 2 Pressure Vessels State the materials of construction and the wall thickness for the pressure vessel welds submitted under ASME Code Category C-A.
Letdown Heat Exchanger AHLD Shell Circumferential Weld AHNR-WI: A240 TP304 Stainless Steel: 0.375" thick* RR-G-5-38:
 
Seal Water Injection Filter AFSI-IA Head Circumferential Weld AFSI-W2: A240 TP304 Stainless Steel: 1.0" thick NRC Question ME7378-RAII-EPNB-McL-2.6-2012-04-27 Request for Relief RR-G-5, Part E, ASME Code, Section Xl, Examination Category C-F-i, Items C5.13, C5.14, and C5.21, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping On the area where the required ISI examination coverage was not achieved, state whether any indications were discovered as a result of ASME Code-required preservice (ASME Code, Section Xl, Category C-F-i, Item C5.21) volumetric (e.g., radiography) and surface examinations that were performed on the ASME Code Class 2 piping welds.State the wall thickness for the subject ASME Code Class 2 piping welds.Provide volumetric coverage sketches detailing the insonification angles and coverage each angle provides on each weld.The licensee's submittal states that the subject weld areas were interrogated with a combination of 45-, 60-, and/or 70-degree shear waves. The licensee's submittal further states that examinations were performed as single-sided examinations from the pipe side of the welds.Confirm the insonification angles and wave modalities used to examine each of the subject welds. If only shear wave techniques were used to examine the subject stainless steel welds and the pipe thickness were greater than 0.50-inches, please explain why refracted longitudinal wave techniques where not used as part of a "best effort" examination.
===Response===
The L-wave method has been shown capable of detecting planar inside diameter (ID) surface-breaking flaws on the far-side of wrought stainless steel welds. Recent studies (Endnotes 1, 2, 3) recommend the use of both shear and L-waves to obtain the best detection results, with minimum false calls, in austenitic welds.If both shear and L-waves were used please state the "best effort" coverage achieved on the near- and far-side of the subject weld volumes.
The following is a list of materials of construction and wall thicknesses for the pressure vessel welds submitted under ASME Code Category C-A.
Serial No. 12-247 Attachment 1 Page 11 of 15 Response: There were no indications on the following two welds for Examination Category C-F-i, Item Number C5.13 that exceeded ASME Code, Section III, Preservice Radiography criteria, and/or B31.1 Construction Code Preservice Radiography criteria." ICS-W180, 6" Containment Spray Circumferential Weld, and* ICS-W181, 6" Containment Spray Circumferential Weld Furthermore, there were no indications for Examination Category C-F-i, Item Number C5.13 that exceeded ASME Boiler and Pressure Vessel Code, Section XI, 1998 Edition, 2000 Addenda, surface examination criteria on the above two welds.The remaining (below listed) welds did not receive radiography examination as part of a Preservice Examination at the time of examination." Examination Category C-F-i, Item Number C5.13 welds: o RHR-W419, 6" Residual Heat Removal Circumferential Weld o ICS-W45, 8" Containment Spray Circumferential Weld* Examination Category C-F-I, Item Number C5.14 Weld o SI-W429, 6" Safety Injection Circumferential Weld* Examination Category C-F-i, Item Number C5.21 Weld o SI-W249, 3" Safety Injection Circumferential Weld The above four welds were installed at the time of construction (1974) and were examined as inservice welds. Surface examinations were performed on these four welds in conjunction, with the ultrasonic examination performed during either the 1 st or 2 nd Period of the 4 th Interval.
  "   RR-G-5-3: Residual Heat Exchanger AHRS1-1A Shell Circumferential Weld AHRS1-W.1: A240 TP304 Stainless Steel: 0.50" thick
No indications that exceeded ASME Boiler and Pressure Vessel Code, Section XI, 1998 Edition, 2000 Addenda, were recorded.There were no indications for Examination Category C-F-i, Item Number C5.21 that exceeded ASME Section III, Preservice Radiography, and/or B31.1 Construction Code Preservice Radiography requirements on the following four welds:* AFW-W148, 3" Auxiliary Feedwater Circumferential Weld," AFW-W151, 3" Auxiliary Feedwater Circumferential Weld," AFW-W152, 3" Auxiliary Feedwater Circumferential Weld, and" AFW-W155, 3" Auxiliary Feedwater Circumferential Weld.
  "   RR-G-5-4: Regenerative Heat Exchanger Tubesheet to Shell Circumferential Weld ARG-W1O: Shell A351 CF8 Cast Stainless Steel; Tubesheet A182 F304 Stainless Steel: 0.938" thick (both)
Serial No. 12-247 Attachment 1 Page 12 of 15 There were no indications for Examination Category C-F-1 Item Number C5.21 that exceeded ASME Boiler and Pressure Vessel Code Section Xl 1998 Edition 2000 Addenda Surface Examinations criteria on the above four welds.The wall thickness for the subject ASME Code Class 2 piping welds was as follows: RR-G-5-12 6" Safety Injection Circumferential Weld Thickness 0.280" SI-W429 6" Containment Spray Circumferential Weld RR-G-5-13 IC-10Thickness 0.280"______ __ I1S- W180_ _ _ _ _ _ _ _RR-G-5-14 6" Containment Spray Circumferential Weld Thickness 0.280" ICS- W181 6" Residual Heat Removal Circumferential RR-G-5-15 Wl H-49Thickness 0.280" Weld RHR-W419 RR-G-5-18 8" Containment Spray Circumferential Weld Thickness 0.322" ICS-W45 RR-G..5..19 3" Safety Injection Circumferential Weld Thickness 0.438" SI-W249 RR..G..5..20 3" Auxiliary Feedwater Circumferential Weld Thickness 0.300" AFW- W148 RR..G..5..21 3" Auxiliary Feedwater Circumferential Weld Thickness 0.300" AFW- W151 RR..G..5..22 3" Auxiliary Feedwater Circumferential Weld Thickness 0.300" AFW- W1 52 RR-G-5-23 3" Auxiliary Feedwater Circumferential Weld Thickness 0.300" AFW- W1 55 Examinations of the following welds were performed in November 2004, at which time the expectation to perform volumetric coverage sketches detailing the insonification angles and coverage for each angle were not in effect at the Kewaunee Power Station." RR-G-5-12:
 
6" Safety Injection Circumferential Weld SI-W429* RR-G-5-13:
Serial No. 12-247 Attachment 1 Page 10 of 15
6" Containment Spray Circumferential Weld ICS-W1 80" RR-G-5-14:
  " RR-G-5-5:     Residual Heat Exchanger AHRS1-1A Head Circumferential Weld AHRS1-W2: A240 TP304 Stainless Steel: 0.50" thick
6" Containment Spray Circumferential Weld ICS-W181* RR-G-5-15:
  " RR-G-5-37: Letdown Heat Exchanger AHLD Shell Circumferential Weld AHNR-WI: A240 TP304 Stainless Steel: 0.375" thick
6" Residual Heat Removal Circumferential Weld RHR-W419 Therefore these welds only showed the percentage and a picture of the limitations based on the calculations performed by the examiner.
* RR-G-5-38: Seal Water Injection Filter AFSI-IA Head Circumferential Weld AFSI-W2: A240 TP304 Stainless Steel: 1.0" thick NRC Question ME7378-RAII-EPNB-McL-2.6-2012-04-27 Request for Relief RR-G-5, Part E, ASME Code, Section Xl, Examination Category C-F-i, Items C5.13, C5.14, and C5.21, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping On the area where the required ISI examination coverage was not achieved, state whether any indications were discovered as a result of ASME Code-required preservice (ASME Code, Section Xl, Category C-F-i, Item C5.21) volumetric (e.g., radiography) and surface examinations that were performed on the ASME Code Class 2 piping welds.
In all cases, the Limitation was due to a single side examination on a stainless steel pipe to valve configuration and the 50% Limitation is documented based on Electric Power Research Institute:
State the wall thickness for the subject ASME Code Class 2 piping welds.
Performance Demonstration Initiative (PDI) Generic Procedure PDI-UT-2, Revision C,"PDI Generic Procedure for the Ultrasonic Examination of Austenitic Welds." PDI-UT-2 Serial No. 12-247 Attachment 1 Page 13 of 15 is not qualified for detection or length sizing of circumferentially oriented flaw indications when only single side access is available and the flaw is located on the far side of the weld; however, guidance is provided.
Provide volumetric coverage sketches detailing the insonification angles and coverage each angle provides on each weld.
The techniques identified in this procedure have been demonstrated to be representative of the "best effort" technology for single side detection of far side defects parallel to the weld. PDI-UT-2 is not qualified for length sizing of axially oriented flaws regardless of location.Volumetric Coverage Sketches, detailing the insonification angles and coverage each angle provides were previously included in the relief request submittal for each of the following welds.* RR-G-5-18, 8" Containment Spray Circumferential Weld ICS-W45" RR-G-5-19, 3" Safety Injection Circumferential Weld SI-W249* RR-G-5-20, 3" Auxiliary Feedwater Circumferential Weld AFW-W148* RR-G-5-21, 3" Auxiliary Feedwater Circumferential Weld AFW-W1 51* RR-G-5-22, 3" Auxiliary Feedwater Circumferential Weld AFW-W1 52* RR-G-5-23, 3" Auxiliary Feedwater Circumferential Weld AFW-W1 55 As discussed above, the subject ASME Code Class 2 piping welds (RR-G-5-12, RR-G-5-13, RR-G-5-14, RR-G-5-15, RR-G-5-18, RR-G-5-20, RR-G-5-21, RR-G-5-22, and RR-G-5-23) were all less than 0.50". Per the PDI Generic Procedure PDU-UT-2 (implemented in Dominion Procedure ER-AA-NDE-UT-802), longitudinal examinations are not required for piping less than 0.50" thickness for stainless steel piping when a single side examination is performed.
The licensee's submittal states that the subject weld areas were interrogated with a combination of 45-, 60-, and/or 70-degree shear waves. The licensee's submittal further states that examinations were performed as single-sided examinations from the pipe side of the welds.
NRC Question ME7378-RAII-EPNB-McL-2.7-2012-04-27 Request for Relief RR-G-5, Part F, ASME Code, Section Xl, Examination Cate-gory C-F-2, Item C5.61, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping On the area where the required ISI examination coverage was not achieved, state whether any indications were discovered as a result of ASME Code-required preservice volumetric (e.g., radiography) and surface examinations that were performed on the carbon steel piping welds.Response: There were no indications that exceeded ASME Code, Section III, Preservice Radiography, and/or B31.1 Construction Code, Preservice Radiography requirements on welds for Examination Category C-F-2, Item Number C5.61, located in Table 2.1.2.Welds that originally exceeded ASME Code, Section III or B31.1 Preservice Serial No. 12-247 Attachment 1 Page 14 of 15 Radiography recording requirements were repaired and reexamined for acceptability.
Confirm the insonification angles and wave modalities used to examine each of the subject welds. If only shear wave techniques were used to examine the subject stainless steel welds and the pipe thickness were greater than 0.50-inches, please explain why refracted longitudinal wave techniques where not used as part of a "best effort" examination. The L-wave method has been shown capable of detecting planar inside diameter (ID) surface-breaking flaws on the far-side of wrought stainless steel welds. Recent studies (Endnotes 1, 2, 3) recommend the use of both shear and L-waves to obtain the best detection results, with minimum false calls, in austenitic welds.
There were no indications that exceeded ASME Boiler and Pressure Vessel Code, Section Xl, 1998 Edition, 2000 Addenda, Surface Examination requirements for Examination Category C-F-2, Item Number C5.61. Welds that originally exceeded ASME Boiler and Pressure Vessel Code, Section XI, 1998 Edition, 2000 Addenda recording requirements were repaired and reexamined for acceptability.
If both shear and L-waves were used please state the "best effort" coverage achieved on the near- and far-side of the subject weld volumes.
Preservice Radiography and Surface results were reviewed by Dominion Radiography Level II or Level III or Contractor Level III examiners, who were certified in the applicable NDE method. Radiography or surface results that may be useful to the Ultrasonic examiner were made available for review prior to the examinations, as required.
 
Following Ultrasonic examinations, any flaws recorded were compared to the radiography results.The nine Examination Category C-F-2, Item C5.61, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping that were limited in ultrasonic examination received a 100% Code Coverage Preservice Radiography and 100% Code Coverage Surface Examination prior to performance of the baseline ultrasonic examination.
Serial No. 12-247 Attachment 1 Page 11 of 15
Serial No. 12-247 Attachment 1 Page 15 of 15  
 
===Response===
There were no indications on the following two welds for Examination Category C-F-i, Item Number C5.13 that exceeded ASME Code, Section III, Preservice Radiography criteria, and/or B31.1 Construction Code Preservice Radiography criteria.
  " ICS-W180, 6" Containment Spray Circumferential Weld, and
* ICS-W181, 6" Containment Spray Circumferential Weld Furthermore, there were no indications for Examination Category C-F-i, Item Number C5.13 that exceeded ASME Boiler and Pressure Vessel Code, Section XI, 1998 Edition, 2000 Addenda, surface examination criteria on the above two welds.
The remaining (below listed) welds did not receive radiography examination as part of a Preservice Examination at the time of examination.
  " Examination Category C-F-i, Item Number C5.13 welds:
o   RHR-W419, 6" Residual Heat Removal Circumferential Weld o   ICS-W45, 8" Containment Spray Circumferential Weld
* Examination Category C-F-I, Item Number C5.14 Weld o   SI-W429, 6" Safety Injection Circumferential Weld
* Examination Category C-F-i, Item Number C5.21 Weld o   SI-W249, 3" Safety Injection Circumferential Weld The above four welds were installed at the time of construction (1974) and were examined as inservice welds. Surface examinations were performed on these four welds in conjunction, with the ultrasonic examination performed during either the 1 st or 2 nd Period of the 4 th Interval. No indications that exceeded ASME Boiler and Pressure Vessel Code, Section XI, 1998 Edition, 2000 Addenda, were recorded.
There were no indications for Examination Category C-F-i, Item Number C5.21 that exceeded ASME Section III, Preservice Radiography, and/or B31.1 Construction Code Preservice Radiography requirements on the following four welds:
* AFW-W148, 3" Auxiliary Feedwater Circumferential Weld,
  " AFW-W151, 3" Auxiliary Feedwater Circumferential Weld,
  " AFW-W152, 3" Auxiliary Feedwater Circumferential Weld, and
  " AFW-W155, 3" Auxiliary Feedwater Circumferential Weld.
 
Serial No. 12-247 Attachment 1 Page 12 of 15 There were no indications for Examination Category C-F-1 Item Number C5.21 that exceeded ASME Boiler and Pressure Vessel Code Section Xl 1998 Edition 2000 Addenda Surface Examinations criteria on the above four welds.
The wall thickness for the subject ASME Code Class 2 piping welds was as follows:
RR-G-5-12     6" Safety Injection Circumferential Weld           Thickness 0.280" SI-W429 RR-G-5-13     6" Containment Spray Circumferential Weld IC-10Thickness                                               0.280"
______   __ I1S- W180_                                           _ _ _ _ _ _ _
RR-G-5-14     6" Containment Spray Circumferential Weld         Thickness 0.280" ICS- W181 RR-G-5-15     6" Residual Wl           Heat Removal Circumferential H-49Thickness                                         0.280" Weld RHR-W419 RR-G-5-18     8" Containment Spray Circumferential Weld         Thickness 0.322" ICS-W45 RR-G..5..19   3" Safety Injection Circumferential Weld           Thickness 0.438" SI-W249 RR..G..5..20   3" Auxiliary Feedwater Circumferential Weld       Thickness 0.300" AFW- W148 RR..G..5..21   3" Auxiliary Feedwater Circumferential Weld       Thickness 0.300" AFW- W151 RR..G..5..22   3" Auxiliary Feedwater Circumferential Weld       Thickness 0.300" AFW- W1 52 RR-G-5-23     3" Auxiliary Feedwater Circumferential Weld       Thickness 0.300" AFW- W1 55 Examinations of the following welds were performed in November 2004, at which time the expectation to perform volumetric coverage sketches detailing the insonification angles and coverage for each angle were not in effect at the Kewaunee Power Station.
  " RR-G-5-12: 6" Safety Injection Circumferential Weld SI-W429
* RR-G-5-13: 6" Containment Spray Circumferential Weld ICS-W1 80
  " RR-G-5-14: 6" Containment Spray Circumferential Weld ICS-W181
* RR-G-5-15: 6" Residual Heat Removal Circumferential Weld RHR-W419 Therefore these welds only showed the percentage and a picture of the limitations based on the calculations performed by the examiner. In all cases, the Limitation was due to a single side examination on a stainless steel pipe to valve configuration and the 50% Limitation is documented based on Electric Power Research Institute:
Performance Demonstration Initiative (PDI) Generic Procedure PDI-UT-2, Revision C, "PDI Generic Procedure for the Ultrasonic Examination of Austenitic Welds." PDI-UT-2
 
Serial No. 12-247 Attachment 1 Page 13 of 15 is not qualified for detection or length sizing of circumferentially oriented flaw indications when only single side access is available and the flaw is located on the far side of the weld; however, guidance is provided. The techniques identified in this procedure have been demonstrated to be representative of the "best effort" technology for single side detection of far side defects parallel to the weld. PDI-UT-2 is not qualified for length sizing of axially oriented flaws regardless of location.
Volumetric Coverage Sketches, detailing the insonification angles and coverage each angle provides were previously included in the relief request submittal for each of the following welds.
* RR-G-5-18, 8" Containment Spray Circumferential Weld ICS-W45
  "   RR-G-5-19, 3" Safety Injection Circumferential Weld SI-W249
* RR-G-5-20, 3" Auxiliary Feedwater Circumferential Weld AFW-W148
* RR-G-5-21, 3" Auxiliary Feedwater Circumferential Weld AFW-W1 51
* RR-G-5-22, 3" Auxiliary Feedwater Circumferential Weld AFW-W1 52
* RR-G-5-23, 3" Auxiliary Feedwater Circumferential Weld AFW-W1 55 As discussed above, the subject ASME Code Class 2 piping welds (RR-G-5-12, RR-G-5-13, RR-G-5-14, RR-G-5-15, RR-G-5-18, RR-G-5-20, RR-G-5-21, RR-G-5-22, and RR-G-5-23) were all less than 0.50". Per the PDI Generic Procedure PDU-UT-2 (implemented in Dominion Procedure ER-AA-NDE-UT-802), longitudinal examinations are not required for piping less than 0.50" thickness for stainless steel piping when a single side examination is performed.
NRC Question ME7378-RAII-EPNB-McL-2.7-2012-04-27 Request for Relief RR-G-5, Part F, ASME Code, Section Xl, Examination Cate-gory C-F-2, Item C5.61, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping On the area where the required ISI examination coverage was not achieved, state whether any indications were discovered as a result of ASME Code-required preservice volumetric (e.g., radiography) and surface examinations that were performed on the carbon steel piping welds.
 
===Response===
There were no indications that exceeded ASME Code, Section III, Preservice Radiography, and/or B31.1 Construction Code, Preservice Radiography requirements on welds for Examination Category C-F-2, Item Number C5.61, located in Table 2.1.2.
Welds that originally exceeded ASME Code, Section III or B31.1 Preservice
 
Serial No. 12-247 Attachment 1 Page 14 of 15 Radiography recording requirements were repaired and reexamined for acceptability.
There were no indications that exceeded ASME Boiler and Pressure Vessel Code, Section Xl, 1998 Edition, 2000 Addenda, Surface Examination requirements for Examination Category C-F-2, Item Number C5.61. Welds that originally exceeded ASME Boiler and Pressure Vessel Code, Section XI, 1998 Edition, 2000 Addenda recording requirements were repaired and reexamined for acceptability. Preservice Radiography and Surface results were reviewed by Dominion Radiography Level II or Level III or Contractor Level III examiners, who were certified in the applicable NDE method. Radiography or surface results that may be useful to the Ultrasonic examiner were made available for review prior to the examinations, as required. Following Ultrasonic examinations, any flaws recorded were compared to the radiography results.
The nine Examination Category C-F-2, Item C5.61, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping that were limited in ultrasonic examination received a 100% Code Coverage Preservice Radiography and 100% Code Coverage Surface Examination prior to performance of the baseline ultrasonic examination.
 
Serial No. 12-247 Attachment 1 Page 15 of 15


==Reference:==
==Reference:==
: 1. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "ME7378 -Kewaunee -Relief Req RR-G-5-1 to -40 Request for Additional Information (RAI)," dated March 27, 2012.Endnotes: 1. ASME Code Cases N-577-1
: 1. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "ME7378 -
Kewaunee - Relief Req RR-G-5-1 to -40 Request for Additional Information (RAI),"
dated March 27, 2012.
Endnotes:
: 1. ASME Code Cases N-577-1 or N-578-1 are not approved for use in RG-1.147, Revision 16. Licensees base their RI-ISI inspection sample size and examination methodology on Table 1 of ASME Code Case N-577-1 or N-578-1.
: 2. F.V. Ammirato, X. Edelmann, and S.M. Walker, Examination of DissimilarMetal Welds in BWR Nozzle-to-Safe End Joints, 8 th InternationalConference on NDE in the Nuclear Industry, ASM International,1987.
: 3. P. Lemaitre, T.D. Koble, and S.R. Doctor, PISC Ill CapabilityStudy on Wrought-to-Wrought Austenitic Steel Welds: Evaluation at the Level of Procedures and Techniques, Effectiveness of Nondestructive Examination,


==Background:==
==Background:==
Dominion requested clarification on whether PDI generic piping procedures were intended to be acceptable for ultrasonic examination of piping branch connection welds.
Inquiry:
Can PDI generic piping procedures be used to examine branch connection welds?
===Response===
Yes, a branch connection weld can be examined in accordance with the PDI qualified generic piping procedures as long as the configuration and material product form allow examination using the normal techniques described within the qualified procedure. For a wrought austenitic branch connection weld, the examination must be performed with a half-vee path technique, using procedurally qualified search units, and the exam coverage in most cases will be limited to single-side only. For a ferritic branch connection weld, the examination may employ the half-vee or full-vee path techniques, using qualified search units, to obtain examination coverage. However, bouncing a sound beam around a comer, in order to examine a weld on a different geometrical plane from the search unit, is not within the scope of the generic procedures. (Refer to Figure 1 and Figure2 for examples)
Page 1 of 2


Dominion requested clarification on whether PDI generic piping procedures were intended to be acceptable for ultrasonic examination of piping branch connection welds.Inquiry: Can PDI generic piping procedures be used to examine branch connection welds?Response: Yes, a branch connection weld can be examined in accordance with the PDI qualified generic piping procedures as long as the configuration and material product form allow examination using the normal techniques described within the qualified procedure.
PERFORMANCE DEMONSTRATION INITIATIVE PDI INQUIRY - 2008-02                                                   Approved: 3-26-2009 Examination can be performed from this side of the weld using the PDI generic piping procedures. If the material is austenitic, only single side exam
For a wrought austenitic branch connection weld, the examination must be performed with a half-vee path technique, using procedurally qualified search units, and the exam coverage in most cases will be limited to single-side only. For a ferritic branch connection weld, the examination may employ the half-vee or full-vee path techniques, using qualified search units, to obtain examination coverage.
                                  - volume coverage would be achievable.
However, bouncing a sound beam around a comer, in order to examine a weld on a different geometrical plane from the search unit, is not within the scope of the generic procedures. (Refer to Figure 1 and Figure2 for examples)Page 1 of 2 PERFORMANCE DEMONSTRATION INITIATIVE PDI INQUIRY -2008-02 Approved:
3-26-2009 Examination can be performed from this side of the weld using the PDI generic piping procedures.
If the material is austenitic, only single side exam-volume coverage would be achievable.
An examination of the same weld, launched from this plane would not be within the scope of the PDI generic piping procedures.
An examination of the same weld, launched from this plane would not be within the scope of the PDI generic piping procedures.
Figure 1: Similar to IWB-2500-9 and 11 For this example, examinations of the subject weld from this plane would not be within the scope of the PDI generic piping procedures Limited examination coverage may be achievable from this scanning surface./* A mockup may be used to qualify additional examination coverage from this tapered surface Figure 2: Similar to IWB-2500-10 Page 2 of 2}}
Figure 1: Similar to IWB-2500-9 and 11 For this example, examinations of the subject weld from this plane would not be within the scope of the PDI generic piping procedures Limited examination coverage may be achievable from this scanning surface.
                                            /
* A mockup may be used to qualify additional examination coverage from this tapered surface Figure 2: Similar to IWB-2500-10 Page 2 of 2}}

Latest revision as of 16:18, 6 February 2020

Inservice Inspection Program Fourth Ten-Year Interval Limitation to Examination Relief Request No. RR-G-5, Supplement and Response to Request for Additional Information
ML12136A461
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 05/09/2012
From: Price J
Dominion, Dominion Energy Kewaunee
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
12-247
Download: ML12136A461 (44)
v • d • e


Text

Dominion Energy Kewaunee, Inc. 0 5000 Dominion Boulevard, Glen Allen, VA 23060 _.Dominionll May 9, 2012 ATTN: Document Control Desk Serial No.12-247 U. S. Nuclear Regulatory Commission LIC/JG/RO Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL LIMITATION TO EXAMINATION RELIEF REQUEST NO. RR-G-5 SUPPLEMENT AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By application dated September 28, 2011 (Reference 1), Dominion Energy Kewaunee, Inc. (DEK), requested approval, pursuant to the provisions of 10 CFR 50.55a(g)(5)(iii),

of relief request RR-G-5 for the Fourth Ten-year Interval of the Inservice Inspection (ISI)

Program for Kewaunee Power Station (KPS). That submittal requested relief from inspecting those areas that either could not be examined in accordance with American Society of Mechanical Engineers (ASME) Section Xl Code requirements or could not be examined without significant modifications to the plant.

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the relief request (Reference 2). The RAI questions and associated DEK responses are provided in Attachment 1 to this letter.

Independent of the above, DEK has removed certain welds associated with four of the individual relief requests submitted in Reference 1. These welds were removed in conjunction with a modification of the auxiliary feed water system and no longer exist.

This weld removal has obviated the need for those four specific relief requests.

Therefore, DEK hereby supplements Reference 1 by requesting withdrawal of the following four relief requests submitted therein:

  • RR-G-5-36: 3" Auxiliary Feedwater Circumferential Weld AFW-W198 No further consideration should be afforded to the four specific relief requests listed above.

Serial No.12-247 Relief Request RR-G-5 Response to RAI's Page 2 of 2 If you have questions or require additional information, please feel free to contact Mr.

Jack Gadzala at 920-388-8604.

Very truly yours, J. a Price Vceesident - Nuclear Engineering

Attachment:

1. Response to Request for Additional Information, Relief Request No. RR-G-5 (with two enclosures)

References:

1. Letter from J. Alan Price (DEK) to Document Control Desk (NRC), "Inservice Inspection Program Fourth Ten-Year Interval Limitation to Examination Relief Request No. RR-G-5", dated September 28, 2011.
2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "ME7378 -

Kewaunee - Relief Req RR-G-5-1 to -40 Request for Additional Information (RAI)",

dated March 27, 2012.

Commitments made by this letter: NONE cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. Karl D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station

Serial No.12-247 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. RR-G-5 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM (JUNE 16, 2004- JUNE 16, 2014) 1ST PERIOD AND 2ND PERIOD KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.12-247 Attachment 1 Page 1 of 15 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. RR-G-5 On March 27, 2012, the NRC transmitted to Dominion Energy Kewaunee, (DEK) a request for additional information (RAI) (Reference 1) concerning Request for Relief (RR) RR-G-05, from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, "Rules for Inservice Inspection of Nuclear PowerPlant Components," for Kewaunee Power Station (KPS).

The RAI questions are provided below, followed by the DEK response.

NRC Question ME7378-RAII-EPNB-McL-2.1-2012-04-27 General Information Required on Request for Relief RR-G-05 In Attachment 1 of the licensee's submittal, DEK provided a general summary of the relief request. Under a section entitled ASME Code Requirements and the Basis for Relief, the licensee states the following:

Volumetric and surface examinations of welds and base material will be examined in accordance with the applicable[ASME Code, Section Xl,] Examination Category and Item Number and as required by the [KPS7 Risk Informed Program.

During the performance of scheduled examinations, there were numerous instances where examiners reported some type of interference. DEK personnel evaluated every instance where this situation was reported, and when possible, alternative examination areas were selected to avoid having to examine restrictedareas.

Piping welds that were selected that still necessitated limited examination (i.e. less than or equal to 90% coverage) were those included in the KPS Fourth Ten-Year Inservice Inspection program to ensure examinations were performed on a representative sample of piping welds and piping welds that were not previously examined during the first 30 years of plant operation.

There are two risk informed program methodologies that are generally accepted for use by the NRC; they have been developed by the Electrical Power Research Institute (EPRI) and the Westinghouse Owners Group (WOG) and are documented in Topical Report TR-1 12657, Revised Risk-Informed Inservice Inspection Evaluation Procedure, Revision B-A, and Topical Report WCAP-14572, Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report, Revision 1-NP-A, respectively. The two programs use either ASME Code Case N-578-1(Endnote 1)' Risk-Informed Requirements for Class 1, 2 or 3 Piping, Method B Section X1, or Code Case N-577 (Endnote 1), Risk-Informed Requirements for Class 1, 2 or 3

Serial No.12-247 Attachment 1 Page 2 of 15 Piping,Method A, both of which assign a new Examination Category R-A, listing welds, or other elements, according to expected forms of degradation.

The ASME Categories and Item numbers included in the licensee's current request for relief appear to be for a conventional ISI program, not a risk-informed program.

However, as shown in the licensee's statements above and in the data sheets provided for the specific welds listed under Category B-F, B-J, C-F-I, and C-F-2, the reviewer is lead to believe that these welds are part of a risk-informed program.

Please clarify the type, either conventional ISI program or a RI-ISI program, to which each of the welds submitted for relief are included. If a RI-ISI program is being implemented, provide a reference to the NRC Safety Evaluation (SE) approving this program and to which methodology (WOG or EPRI) was followed. If a RI-ISI program is not being implemented, state why alternative piping welds that have not been previously examined during the first 30 years of plant operation were selected for examination during the fourth interval.

Response

Kewaunee Power Station (KPS) employs a risk-informed ISI program. The Fourth Interval Risk-informed Program for Class 1 and Class 2 piping at the KPS follows the guidance of Electric Power Research Institute (EPRI) Topical Report TR-1 12657 Rev.

B-A, "Revised Risk-Informed Inservice Inspection Evaluation Procedure", and is consistent with ASME Boiler and Pressure Vessel Code,Section XI, Code Case N-578, "Risk-Informed Requirements for Class 1, 2, and 3 Piping Method B,Section XI, Division 1." TR-112657, Rev. B-A, is a Risk-Informed application that meets the intent and principles of NRC Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-Informed Decision Making Inservice Inspection of Piping." The KPS risk-informed program was submitted as Relief Request RR-G-1 and approved by the NRC on September 23, 2005, as a risk-informed inservice inspection (RI-ISI) alternative to the ASME Code, Section Xl, requirements (TAC Nos. MC2502, MC2508, and MC2537).

DEK chose not to assign specific risk-informed program category numbers for the Class 1 and Class 2 piping welds. ASME categories were used to identify the Class 1 and Class 2 welds and a note was added to each individual weld to identify them as risk-informed welds. The risk-informed program prepared for KPS per TR-1 12657, Rev. B-A, is a separate document that lists the risk ranking for each individual Class 1 and Class 2 weld. The Class 1 and Class 2 welds were divided into the following Categories:

Serial No.12-247 Attachment 1 Page 3 of 15

1. System
2. Risk Characterization (Segment, Category and Risk)
3. Consequence (ID and Rank)
4. Failure Potential (Degradation Method and Rank)
5. Line in Segment
6. Welds in Segment
7. Weld Count
8. Sketch Number
9. Code Class
10. Consequence Evaluation Conditional Core Melt Potential
11. Degradation Mechanism Assessment Pipe Rupture Potential The Fourth 10-Year ISI Program (2004-2014) for KPS, which was submitted to NRC on December 16, 2003, outlined the classification of Class 1 and Class 2 Piping welds under examination categories from ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda. A separate section of the Fourth 10-Year ISI Program (2004-2014) for KPS outlined the risk-informed program (weld risk ranking is provided in to this Attachment).

NRC Question ME7378-RAII-EPNB-McL-2.1-2012-04-27 (continued)

Confirm the correct RI-ISI Examination Category and Item Numbers for each of the welds listed in Table 2.1.1 below. Specifically, if a RI-ISI program is being implemented, please list the RI-ISI R-A Item Numbers in accordance with the appropriate ASME Code Case or if KPS has an unique identifying RI-ISI system based on either RI-ISI ASME Code Case clarify how to identify the welds examined.

B-F B5.40 PR-W1DM PZR 6" Nozzle-to-Safe End B-F B5.40 PR-W26DM PZR 6" Nozzle-to-Safe End B-F B5.40 RC-W67DM PZR 14" Nozzle-to-Safe End B-J B9.11 PR-W27 6" PZR Relief Circumferential Weld B-J B9. 11 RC-W60 6" Reactor Coolant Circumferential Weld B-J B9.11 SI-W51 6" Safety Injection Circumferential Weld B-J B9.11 RHR-W9 8" Residual Heat Removal Circumferential Weld B-J B9.11 SI-W74 12" Safety Injection Circumferential Weld B-J B9.31 RC-W3BC 8" Reactor Coolant Pipe Branch Connection B-J 89.31 RC-W22BC 6" Reactor Coolant Pipe Branch Connection

Serial No.12-247 Attachment 1 Page 4 of 15 C-F-1 C5.13 ICS-W18bC 6" Containment Spray Circumterential Weld C-F-1 C5.13 ICS-W181 6" Containment Spray Circumferential Weld C-F-1 C5.13 RHR-W419 6" Residual Heat Removal Circumferential Weld C-F-1 C5.13 ICS-W45 8" Containment Spray Circumferential Weld C-F-1 C5.14 SI-W429 6" Safety Injection Circumferential Weld C-F-1 C5.21 Sl-W249 3" Safety Injection circumferential Weld C-F-1 C5.21 AFW-W148 3" Auxiliary Feedwater Circumferential Weld C-F-1 C5.21 AFW-W151 3" Auxiliary Feedwater Circumferential Weld C-F-1 C5.21 AFW-W152 3" Auxiliary Feedwater Circumferential Weld C-F-1 C5.21 AFW-W155 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W156 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W171 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W172 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W178 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W189 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W19O 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W191 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W192 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W194 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W195 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W196 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W197 3" Auxiliary Feedwater Circumferential Weld C-F-2 C5.61 AFW-W198 3" Auxiliary Feedwater Circumferential Weld

Response

The piping welds listed in Table 2.1.1 were examined per the requirements of EPRI TR-112657, Rev. B-A, and consistent with ASME Boiler and Pressure Vessel Code, Section Xl, Code Case N-578, "Risk-Informed Requirements for Class 1, 2, and 3 Piping Method B Section Xl, Division 1." TR-112657, Rev. B-A, is a Risk-Informed application that meets the intent and principles of NRC Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-Informed Decision Making Inservice Inspection of Piping." Weld risk ranking is provided in Enclosure 1 to this Attachment.

Serial No.12-247 Attachment 1 Page 5 of 15 NRC Question ME7378-RAII-EPNB-McL-2.1-2012-04-27 (continued)

In addition, if the welds listed in Table 2.1.1 above were examined under a RI-ISI program:

a) Please state the total number of Class 1 and Class 2 piping welds included in the overall risk-informed program so that the 33 limited examinations can be assessed within the scope of all examinations being implemented.

b) Please confirm whether the ultrasonic (UT) examination methods for all piping welds listed in Table 2.1.1 were conducted in accordance with the performance demonstration requirements of ASME Code,Section XI, Appendix VIII.

c) Further discuss whether additional welds could have been examined to augment the reduced volumetric coverage resulting from the limited examinations of the subject welds.

d) Please state whether any alternative examination such as full surface examination was performed on each of the ASME Code Class 1 and Class 2 piping welds. The staff notes that surface examination is not required for most of the damage mechanisms listed in Table 1 of ASME Code Case N-577 or N-578. Also, please state whether any indications were discovered as a result of surface examinations.

Response

a) KPS has 650 Class 1 welds and 1191 Class 2 welds in the total risk-informed population. Table 2.1.1 (above) lists 33 Class 1 and Class 2 piping welds with limitations. However, four of these welds are being withdrawn from consideration for relief with this supplement. Therefore, only the remaining 29 welds remain applicable to this question. Thirteen of those 29 welds were checked during preservice examinations and the remaining 16 welds were checked during inservice examinations. An additional 65 Class 1 and Class 2 risk-informed inservice welds (without limitations) were examined during the 1 st and 2 nd Periods of the Fourth Ten Year interval and received the requisite greater than 90% coverage. Sixteen Class 1 and 27 Class 2 risk-informed welds are scheduled for the 3 rd period.

b) The welds listed in Table 2.1.1 were examined in accordance with the performance demonstration requirements of ASME Code,Section XI, Appendix VIII (Supplement 2 or Supplement 3, as applicable), except for the following two welds:

1. ASME Category B-J Code Item B9.31, Weld RC-W3BC, 8" Reactor Coolant Pipe Branch Connection

Serial No.12-247 Attachment 1 Page 6 of 15

2. ASME Category B-J Code Item B9.31, Weld RC-W22BC, 6" Reactor Coolant Pipe Branch Connection Weld RC-W3BC and Weld RC-W22BC branch connections were not initially examined to Appendix VIII, Supplement 2 requirements because PDI Supplement 2 qualifications were not considered demonstrated for branch connections using Electric Power Research Institute (EPRI) Performance Demonstration Initiative (PDI)

Generic Procedure PDI-UT-2, Revision C, "PDI Generic Procedure for the Ultrasonic Examination of Austenitic Welds." However, subsequent discussions with the PDI Steering Committee (reference PDI Inquiry 2008-02; provided in Enclosure 2 to this Attachment) determined that branch connections, in fact, can be examined using PDI Generic Procedure PDI-UT-2. Therefore, during the 3 rd Examination period at KPS, two branch connections were examined using the ASME Section XI Appendix VIII Supplement 2 procedure. Specifically, RC-W3BC was reexamined and RC-W34BC was examined as a substitute for RC-W22BC. These welds were examined using 450 shear, 600 shear, and 600 longitudinal.

The coverage for RC-W3BC and RC-W34BC were 25% best effort coverage and ASME Code coverage of 50% due to one-sided examination for the stainless steel pipe to nozzle configuration. PDI-UT-2, Revision C, is not qualified for detection or length sizing of circumferentially oriented flaw indications when only single side access is available and the flaw is located on the far side of the weld. However, examination guidance is provided. The techniques identified in this procedure have been demonstrated to be representative of the "best effort" technology for single side detection of far side defects parallel to the weld. PDI-UT-2 is not qualified for length sizing of axially oriented flaws regardless of location.

Note: RC-W3BC and RC-W34BC - 50% Limitation Relief Request is expected to be submitted at the end of the 3 rd Period examinations.

c) Piping welds that were selected and recieved limited examination (i.e., less than or equal to 90% coverage) were those welds included in the KPS Fourth Ten-Year Inservice Inspection program to ensure examinations were performed on a representative sample of piping welds and piping welds that were not previously examined during the first 30 years of plant operation. Different Class 1 and Class 2 welds could have been selected that would have had coverage greater than 90%;

however, those welds would not have been a representative sample and would have been previously examined with acceptable results. Typical welds that would achieve greater than 90% coverage include pipe-to-pipe welds and pipe-to-elbow welds.

Typical welds that would not achieve greater than 90% coverage include stainless steel pipe-to-valve welds and stainless steel pipe-to-flange welds. KPS chose not to exclude these types of welds because a representative sample would not have been achieved. As previously stated, Table 2.1.1 (above) lists 33 Class 1 and Class 2 piping welds with limitations. However, four of these welds are being withdrawn

Serial No.12-247 Attachment 1 Page 7 of 15 from consideration for relief with this supplement. Therefore, only the remaining 29 welds remain applicable to this question. Thirteen of those 29 welds were checked during preservice examinations and the remaining 16 welds were checked during inservice examinations. An additional 65 Class 1 and Class 2 risk-informed inservice welds (without limitations) were examined during the 1 st and 2 nd Periods of the Fourth Ten Year interval and received the requisite greater than 90% coverage.

d) Full surface examinations were performed on 100% of the welds listed in Table 2.1.1 (above). No indications were recorded on those welds that exceeded ASME Boiler and Pressure Vessel Code, Section Xl, 1998 Edition, 2000 Addenda recording requirements. VT-2 Visual examination for leakage was also performed on each of those welds per ASME Boiler and Pressure Vessel Code, Section Xl, 1998 Edition, 2000 Addenda, Examination Category B-P, Examination Category C-H, and IWA-4540, as applicable, and no indications were recorded.

NRC Question ME7378-RAII-EPNB-McL-2.2-2012-04-27 Request for Relief RR-G-05, Part A, ASME Code, Section Xl, Examination Category B-D, Item B3.90, Full Penetration Welded Nozzles in Vessels Confirm that the UT examination methods used have been qualified in accordance with the performance demonstration requirements of ASME Section Xl, Appendix VIII.

Response

Ultrasonic examination methods used on reactor vessel nozzle to vessel welds RV-W7 and RV-W1O, Examination Category B-D, Item Number B3.90, were qualified in accordance with the performance demonstration requirements of ASME Section XI, Appendix VIII (performed using WESDYNE International approved ASME Section XI, Appendix VIII, procedure PDI-ISI-254-NZ and PDI-1SI-254).

NRC Question ME7378-RAII-EPNB-McL-2.3-2012-04-27 Request for Relief RR-G-5, Part B, ASME Code, Section Xl, Examination Category B-F, Item B5.40, Pressure Retaininq Dissimilar Metal Welds In Vessel Nozzles The coverage percentages provided in the licensee's submittal appear to be only from the 45- and 60-degree UT scans performed on the welds. Please state whether any additional "best effort" coverage was obtained using the 35-, 42-, and 50-degree L-wave scans, as applicable.

Serial No.12-247 Attachment 1 Page 8 of 15

Response

The following Examination Category B-F, Item No. B5.40, Pressure Retaining Welds were examined using the stated angles to achieve the maximum coverage as shown on the previously provided data sheets.

  • PR-W1DM: 450 Shear, 350 Longitudinal, 450 Longitudinal, 600 Longitudinal
  • PR-W26DM: 450 Shear, 350 Longitudinal, 450 Longitudinal, 600 Longitudinal
  • PR-W67DM: 450 Shear, 400 Longitudinal, 420 Longitudinal, 500 Longitudinal, 600 Longitudinal NRC Question ME7378-RAII-EPNB-McL-2.4-2012-04-27 Request for Relief RR-G-5, Part C, ASME Code, Section Xl, Examination Category B-J.

Items B9.11 and B9.31, Pressure Retaining Welds in Piping The licensee's submittal states that the subject weld areas in ASME Code,Section XI, Category B-J, Item B9.31 were interrogated with a combination of 34-, 45- and 60-degree shear waves. The licensee's submittal further states that examinations were performed as single-sided examinations from the pipe side of the welds.

Confirm the insonification angles and wave modalities used to examine each of the subject-welds in ASME Code,Section XI, Category B-J, Item B9.31. If only shear wave techniques were used to examine the subject stainless steel welds, please explain why refracted longitudinal wave techniques were not used as part of a "best effort" examination. The L-wave method has been shown capable of detecting planar inside diameter (ID) surface-breaking flaws on the far-side of wrought stainless steel welds.

Recent studies (Endnotes 2, 3, 4) recommend the use of both shear and L-waves to obtain the best detection results, with minimum false calls, in austenitic welds. If both shear and L-waves were used please state the "best effort" coverage achieved on the near- and far-side of the subject weld volumes.

Response

As discussed in the response to NRC Question ME7378-RAII-EPNB-McL-2.1-2012 27 (subpart b), Weld RC-W3BC and Weld RC-W22BC branch connections were not initially examined to Appendix VIII, Supplement 2 requirements because PDI Supplement 2 qualifications were not considered demonstrated for branch connections using Electric Power Research Institute (EPRI) Performance Demonstration Initiative

Serial No.12-247 Attachment 1 Page 9 of 15 (PDI) Generic Procedure PDI-UT-2, Revision C, "PDI Generic Procedure for the Ultrasonic Examination of Austenitic Welds." However, subsequent discussions with the PDI Steering Committee (reference PDI Inquiry 2008-02; provided in Enclosure 2 to this Attachment) determined that branch connections, in fact, can be examined using PDI Generic Procedure PDI-UT-2. Therefore, during the 3 rd Examination period at KPS, two branch connections were examined using the ASME Section Xl Appendix VIII Supplement 2 procedure. RC-W3BC was reexamined and RC-W34BC was examined as a substitute for RC-W22BC. These welds were examined using 450 shear, 600 shear, and 600 longitudinal.

The coverage for RC-W3BC and RC-W34BC were 25% best effort coverage and ASME Code coverage of 50% due to one-sided examination for the stainless steel pipe to nozzle configuration. PDI-UT-2, Revision C, is not qualified for detection or length sizing of circumferentially oriented flaw indications when only single side access is available and the flaw is located on the far side of the weld. However, examination guidance is provided. The techniques identified in this procedure have been demonstrated to be representative of the "best effort" technology for single side detection of far side defects parallel to the weld. PDI-UT-2 is not qualified for length sizing of axially oriented flaws regardless of location.

Note: For RC-W3BC and RC-W34BC, a 50% Limitation Relief Request is expected to be submitted at the end of the 3 rd Period examinations.

NRC Question ME7378-RAII-EPNB-McL-2.5-2012-04-27 Request for Relief RR-G-5, Part D, ASME Code, Section Xl, Examination Category C-A, Items C1.10, C1.20, and C1.30, Pressure Retaininq Welds in Class 2 Pressure Vessels State the materials of construction and the wall thickness for the pressure vessel welds submitted under ASME Code Category C-A.

Response

The following is a list of materials of construction and wall thicknesses for the pressure vessel welds submitted under ASME Code Category C-A.

" RR-G-5-3: Residual Heat Exchanger AHRS1-1A Shell Circumferential Weld AHRS1-W.1: A240 TP304 Stainless Steel: 0.50" thick

" RR-G-5-4: Regenerative Heat Exchanger Tubesheet to Shell Circumferential Weld ARG-W1O: Shell A351 CF8 Cast Stainless Steel; Tubesheet A182 F304 Stainless Steel: 0.938" thick (both)

Serial No.12-247 Attachment 1 Page 10 of 15

" RR-G-5-5: Residual Heat Exchanger AHRS1-1A Head Circumferential Weld AHRS1-W2: A240 TP304 Stainless Steel: 0.50" thick

" RR-G-5-37: Letdown Heat Exchanger AHLD Shell Circumferential Weld AHNR-WI: A240 TP304 Stainless Steel: 0.375" thick

  • RR-G-5-38: Seal Water Injection Filter AFSI-IA Head Circumferential Weld AFSI-W2: A240 TP304 Stainless Steel: 1.0" thick NRC Question ME7378-RAII-EPNB-McL-2.6-2012-04-27 Request for Relief RR-G-5, Part E, ASME Code, Section Xl, Examination Category C-F-i, Items C5.13, C5.14, and C5.21, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping On the area where the required ISI examination coverage was not achieved, state whether any indications were discovered as a result of ASME Code-required preservice (ASME Code, Section Xl, Category C-F-i, Item C5.21) volumetric (e.g., radiography) and surface examinations that were performed on the ASME Code Class 2 piping welds.

State the wall thickness for the subject ASME Code Class 2 piping welds.

Provide volumetric coverage sketches detailing the insonification angles and coverage each angle provides on each weld.

The licensee's submittal states that the subject weld areas were interrogated with a combination of 45-, 60-, and/or 70-degree shear waves. The licensee's submittal further states that examinations were performed as single-sided examinations from the pipe side of the welds.

Confirm the insonification angles and wave modalities used to examine each of the subject welds. If only shear wave techniques were used to examine the subject stainless steel welds and the pipe thickness were greater than 0.50-inches, please explain why refracted longitudinal wave techniques where not used as part of a "best effort" examination. The L-wave method has been shown capable of detecting planar inside diameter (ID) surface-breaking flaws on the far-side of wrought stainless steel welds. Recent studies (Endnotes 1, 2, 3) recommend the use of both shear and L-waves to obtain the best detection results, with minimum false calls, in austenitic welds.

If both shear and L-waves were used please state the "best effort" coverage achieved on the near- and far-side of the subject weld volumes.

Serial No.12-247 Attachment 1 Page 11 of 15

Response

There were no indications on the following two welds for Examination Category C-F-i, Item Number C5.13 that exceeded ASME Code,Section III, Preservice Radiography criteria, and/or B31.1 Construction Code Preservice Radiography criteria.

" ICS-W180, 6" Containment Spray Circumferential Weld, and

  • ICS-W181, 6" Containment Spray Circumferential Weld Furthermore, there were no indications for Examination Category C-F-i, Item Number C5.13 that exceeded ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, surface examination criteria on the above two welds.

The remaining (below listed) welds did not receive radiography examination as part of a Preservice Examination at the time of examination.

" Examination Category C-F-i, Item Number C5.13 welds:

o RHR-W419, 6" Residual Heat Removal Circumferential Weld o ICS-W45, 8" Containment Spray Circumferential Weld

  • Examination Category C-F-I, Item Number C5.14 Weld o SI-W429, 6" Safety Injection Circumferential Weld
  • Examination Category C-F-i, Item Number C5.21 Weld o SI-W249, 3" Safety Injection Circumferential Weld The above four welds were installed at the time of construction (1974) and were examined as inservice welds. Surface examinations were performed on these four welds in conjunction, with the ultrasonic examination performed during either the 1 st or 2 nd Period of the 4 th Interval. No indications that exceeded ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, were recorded.

There were no indications for Examination Category C-F-i, Item Number C5.21 that exceeded ASME Section III, Preservice Radiography, and/or B31.1 Construction Code Preservice Radiography requirements on the following four welds:

" AFW-W151, 3" Auxiliary Feedwater Circumferential Weld,

" AFW-W152, 3" Auxiliary Feedwater Circumferential Weld, and

" AFW-W155, 3" Auxiliary Feedwater Circumferential Weld.

Serial No.12-247 Attachment 1 Page 12 of 15 There were no indications for Examination Category C-F-1 Item Number C5.21 that exceeded ASME Boiler and Pressure Vessel Code Section Xl 1998 Edition 2000 Addenda Surface Examinations criteria on the above four welds.

The wall thickness for the subject ASME Code Class 2 piping welds was as follows:

RR-G-5-12 6" Safety Injection Circumferential Weld Thickness 0.280" SI-W429 RR-G-5-13 6" Containment Spray Circumferential Weld IC-10Thickness 0.280"

______ __ I1S- W180_ _ _ _ _ _ _ _

RR-G-5-14 6" Containment Spray Circumferential Weld Thickness 0.280" ICS- W181 RR-G-5-15 6" Residual Wl Heat Removal Circumferential H-49Thickness 0.280" Weld RHR-W419 RR-G-5-18 8" Containment Spray Circumferential Weld Thickness 0.322" ICS-W45 RR-G..5..19 3" Safety Injection Circumferential Weld Thickness 0.438" SI-W249 RR..G..5..20 3" Auxiliary Feedwater Circumferential Weld Thickness 0.300" AFW- W148 RR..G..5..21 3" Auxiliary Feedwater Circumferential Weld Thickness 0.300" AFW- W151 RR..G..5..22 3" Auxiliary Feedwater Circumferential Weld Thickness 0.300" AFW- W1 52 RR-G-5-23 3" Auxiliary Feedwater Circumferential Weld Thickness 0.300" AFW- W1 55 Examinations of the following welds were performed in November 2004, at which time the expectation to perform volumetric coverage sketches detailing the insonification angles and coverage for each angle were not in effect at the Kewaunee Power Station.

" RR-G-5-12: 6" Safety Injection Circumferential Weld SI-W429

" RR-G-5-14: 6" Containment Spray Circumferential Weld ICS-W181

  • RR-G-5-15: 6" Residual Heat Removal Circumferential Weld RHR-W419 Therefore these welds only showed the percentage and a picture of the limitations based on the calculations performed by the examiner. In all cases, the Limitation was due to a single side examination on a stainless steel pipe to valve configuration and the 50% Limitation is documented based on Electric Power Research Institute:

Performance Demonstration Initiative (PDI) Generic Procedure PDI-UT-2, Revision C, "PDI Generic Procedure for the Ultrasonic Examination of Austenitic Welds." PDI-UT-2

Serial No.12-247 Attachment 1 Page 13 of 15 is not qualified for detection or length sizing of circumferentially oriented flaw indications when only single side access is available and the flaw is located on the far side of the weld; however, guidance is provided. The techniques identified in this procedure have been demonstrated to be representative of the "best effort" technology for single side detection of far side defects parallel to the weld. PDI-UT-2 is not qualified for length sizing of axially oriented flaws regardless of location.

Volumetric Coverage Sketches, detailing the insonification angles and coverage each angle provides were previously included in the relief request submittal for each of the following welds.

" RR-G-5-19, 3" Safety Injection Circumferential Weld SI-W249

  • RR-G-5-23, 3" Auxiliary Feedwater Circumferential Weld AFW-W1 55 As discussed above, the subject ASME Code Class 2 piping welds (RR-G-5-12, RR-G-5-13, RR-G-5-14, RR-G-5-15, RR-G-5-18, RR-G-5-20, RR-G-5-21, RR-G-5-22, and RR-G-5-23) were all less than 0.50". Per the PDI Generic Procedure PDU-UT-2 (implemented in Dominion Procedure ER-AA-NDE-UT-802), longitudinal examinations are not required for piping less than 0.50" thickness for stainless steel piping when a single side examination is performed.

NRC Question ME7378-RAII-EPNB-McL-2.7-2012-04-27 Request for Relief RR-G-5, Part F, ASME Code, Section Xl, Examination Cate-gory C-F-2, Item C5.61, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping On the area where the required ISI examination coverage was not achieved, state whether any indications were discovered as a result of ASME Code-required preservice volumetric (e.g., radiography) and surface examinations that were performed on the carbon steel piping welds.

Response

There were no indications that exceeded ASME Code,Section III, Preservice Radiography, and/or B31.1 Construction Code, Preservice Radiography requirements on welds for Examination Category C-F-2, Item Number C5.61, located in Table 2.1.2.

Welds that originally exceeded ASME Code,Section III or B31.1 Preservice

Serial No.12-247 Attachment 1 Page 14 of 15 Radiography recording requirements were repaired and reexamined for acceptability.

There were no indications that exceeded ASME Boiler and Pressure Vessel Code, Section Xl, 1998 Edition, 2000 Addenda, Surface Examination requirements for Examination Category C-F-2, Item Number C5.61. Welds that originally exceeded ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda recording requirements were repaired and reexamined for acceptability. Preservice Radiography and Surface results were reviewed by Dominion Radiography Level II or Level III or Contractor Level III examiners, who were certified in the applicable NDE method. Radiography or surface results that may be useful to the Ultrasonic examiner were made available for review prior to the examinations, as required. Following Ultrasonic examinations, any flaws recorded were compared to the radiography results.

The nine Examination Category C-F-2, Item C5.61, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping that were limited in ultrasonic examination received a 100% Code Coverage Preservice Radiography and 100% Code Coverage Surface Examination prior to performance of the baseline ultrasonic examination.

Serial No.12-247 Attachment 1 Page 15 of 15

Reference:

1. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "ME7378 -

Kewaunee - Relief Req RR-G-5-1 to -40 Request for Additional Information (RAI),"

dated March 27, 2012.

Endnotes:

1. ASME Code Cases N-577-1 or N-578-1 are not approved for use in RG-1.147, Revision 16. Licensees base their RI-ISI inspection sample size and examination methodology on Table 1 of ASME Code Case N-577-1 or N-578-1.
2. F.V. Ammirato, X. Edelmann, and S.M. Walker, Examination of DissimilarMetal Welds in BWR Nozzle-to-Safe End Joints, 8 th InternationalConference on NDE in the Nuclear Industry, ASM International,1987.
3. P. Lemaitre, T.D. Koble, and S.R. Doctor, PISC Ill CapabilityStudy on Wrought-to-Wrought Austenitic Steel Welds: Evaluation at the Level of Procedures and Techniques, Effectiveness of Nondestructive Examination, Systems and Performance Demonstration,PVP-Volume 317, NDE-Volume 14, ASME, 1995.
4. M.T. Anderson, A.A. Diaz, A.D. Cinson, S.L. Crawford, S.E. Cumblidge, S.R Doctor, K.M. Denslow, and S. Ahmed, 2011. An Assessment of Ultrasonic Techniques for Far-Side Examinations of Austenitic Stainless Steel Piping Welds, NUREG/CR-7113, PNNL-19353, U. S. Nuclear Regulatory Commission, Washington, DC.

Enclosures (to this Attachment)

1. KPS Risk-Informed Inservice Inspection Program, System Welds, Risk Ranking Report
2. Performance Demonstration Initiative (PDI) Inquiry 2008-02

Serial No.12-247 ENCLOSURE I TO ATTACHMENT I RISK-INFORMED INSERVICE INSPECTION PROGRAM, SYSTEM WELDS, RISK RANKING REPORT (22 pages; numbered pages 5 - 24 followed by summary and matrix)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. RR-G-5 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM (JUNE 16, 2004- JUNE 16, 2014) 1ST PERIOD AND 2ND PERIOD KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Weld System Rank ID R Lines in Segment Welds in Segment Count Segment CategoryI I I Rank DOMs Rank SketchNo(s). CC 01RC RC-027 2 High RCS-C-09 High TASCS, TT Medium 10-RC-ISIM-1704 RC-W033BC 5 ISIM-1704 1 10-RC-ISIM-892 RC-W062, RC-W063, RC-W064, RC-W065 ISIM-892 01RC RC-039 2 High RCS-C-17 High TASCS Medium 3-RC-ISIM-874-1 PS-W053, PS-W054, PS-W055, PS-W056, PS- 7 ISIM-874-1 1 W057, PS-W058, PS-W059 01RC RC-001 2 High CVCS-C-02 High TT Medium 2-RC-ISIM-1704 RC-WO51BC 1 ISIM-1704 1 01RC RC-004 2 High IL-C-05 High TT Medium 6-RC-ISIM-982 RC-W028, RC-W029 3 ISIM-1703 1 6-RC-ISIM-1703 RC-W022BC ISIM-982 01RC RC-005 2 High IL-C-08 High TT Medium 6-RC-ISIM-936 RC-W061, RC-W060 3 ISIM-1704 1 6-RC-ISIM-1704 RC-WO54BC ISIM-936 01RC RC-007 2 High IL-C-16 High TT Medium 12-RC-ISIM-1704 RC-WO50BC 1 ISIM-1704 1 01RC RC-026 2 High RCS-C-09 High TT Medium 10-RC-ISIM-892 RC-W066 2 ISIM-892 1 14-RC-ISIM-892 RC-W067DM 02RHR RHR-022 2 High RHR-C-05A1 High TASCS Medium 8-RHR-ISIM-957-1 RHR-W003, RHR-W004, RHR-W005, RHR- 4 ISIM-957-1-1 1 W006 _ _ "__ .__

02RHR RHR-026 2 High RHR-C-05B1 High TASCS Medium 8-RHR-ISIM-957-1 RHR-W027, RHR-W028, RHR-W029, RHR- 4 ISIM-9571.-1 1 02RHR RHR-046 2 High RHR-C-14A High TASCS Medium 8-RHR-ISIM-962-2 RHR-W165 4 ISIM-962-2-1 2 10-RHR-ISIM-962-2 RHR-W166, RHR-W167, RHR-W168 , -_-

02RHR RHR-048 2 High RHR-C-14A High TASCS Medium 8-RHR-ISIM-961-1 RHR-W228, RHR-W229 2 ISIM-961-1 2 03SI SI-033 2 High IL-C-16 High IT Medium 12-SI-ISIM-938-1 SI-W075, SI-W076 2 ISIM-938-1 1 03SI SI-040 2 High IL-C-19 High PWSCC Medium. 4-SI-ISIM-938-2 SI-W112DM 1 ISIM-938-2-4, 1 03SI SI-047 2 High IL-C-22 High PWSCC Medium 4-SI-ISIM-939 SI-W054DM 1 ISIM-939-1,ý- 1 04CVC CVC-010 2 High CVCS-C-09 High TASCS Medium 2-CVC-ISIM-1369-2 WD-WO04S, WD-WO05S 2 ISIM-1369-2 1 04CVC CVC-003 2 High CVCS-C-02 High TT Medium 2-CVC-ISIM-1473 CVC-W096S, CVC-W095S, CVC-W094S, CVC 33 ISIM-1473 1 W093S, CVC-W092S, CVC-W091S, CVC-W090S, CVC-W089S, CVC-W088S, CVC-W087S, CVC-W086S, CVC-W085S, CVC-W084S, CVC-W083S, CVC-W082S, CVC-W081.S, CVC-W080S, CVC-W079S, CVC-W078S, CVC-W077S, CVC-W076S, CVC-W075S, CVC-W074S, CVC-W073S, CVC-W072S, CVC-W071S, CVC-W070S, CVC-W069S, CVC-W068S, CVC-W067S, CVC-W066S, CVC-W065S, CVC-W064S 01RC RC-002 4 Medium CVCS-C-05 High None Low 2-RC-ISIM-1704 RC-W044BC 1 ISIM-1704 1 01RC RC-003 4 Medium CVCS-C-09 High None Low 2-RC-ISIM-1703 RC-W014BC 1 ISIM-1703 1 01RC RC-006 4 Medium IL-C-14 High None Low 12-RC-ISIM-1703 RC-WO23BC 1 ISIM-1703 1

  • PRA model change in 2008.

.General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 5 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

System Semn Risk Characterization aeor ak I J Consequence Ran Failure Potential Lines in Segment Welds in Segment Weld CutSketch No(s). CC 01RC Segment Category IRank RC-008 4 Medium ID RCS-C-01 Rn High Ds Rak DIVs None JRank RakCount Low 29-RC-ISIM-1703 RC-W001DM, RC-W070, RCrW005, RC- 5 ISIM-1703 1 W080, RC-W076DM 01RC RC-009 4 Medium RCS-C-01A High None Low 2.5-RC-ISIM-1703 RC-W071BC 1 ISIM-1703 1 01RC RC-010 4 Medium RCS-C-01B High None Low 6-RC-ISIM-1703 RC-WO04BC, RC-W027 2 ISIM-1703 T 01RC RC-011 4 Medium RCS-C-02 High None Low 31-RC-ISIM-1703 RC-W077DM, RC-W081, RC-W008, RC- 7 ISIM-1703 1 W009, RC-W012, RC-W015, RC-W018 01RC RC-012 4 Medium RCS-C-03 High None Low 27.5-RC-ISIM-1703 RC-W019, RC-W020, RC-W024, RC-W026DM 4 ISIM-1703 T 01RC RC-013 4 Medium RCS-C-03A High None Low 2.5-RC-ISIM-1703 RC-W072BC 1 ISIM-1703 1 01RC RC-014 4 Medium RCS-C-04 High None Low 2-RC-ISIM-1703 RC-W021BC 57 ISIM-1703 1 2-RC-ISIM-1460 RTD-W032S, RTD-W033S, RTD-W034S, RTD- ISIM-1460 W035S, RTD-W036S, RTD-W037S, RTD-W038S, RTD-W039S, RTD-W040S, RTD-W041S, RTD-W042S, RTD-W043S, RTD-W044S, RTD-W045S, RTD-W046S, RTD-W047S, RTD-W048S, RTD-W049S, RTD-W050S, RTD-WO51S, RTD-W052S, RTD-W053S, RTD-W054S, RTD-W055B RTD-W001S, RTD-WO02S, RTD-WO03S, RTD-W004S, RTD-WO05B, RTD-WO06B, RTD-W007S, RTD-WO08S, RTD-WO09S, RTD-W010S, RTD-WO11S, RTD-WO12S, RTD-W013S, RTD-W014S, RTD-WO15S, RTD-W016S, RTD-WO17S, RTD-W018S, RTD-W019S, RTD-W020S, RTD-W021S, RTD-W022S, RTID-W023S, RTD-W024S, RTD-W025B 3-RC-ISIM-1460 RTD-W026, RTD-W027, RTD-W028, RTD-W029, RTD-W030, RTD-W031 3-RC-ISIM-1703 RC-WO13BC 01RC RC-017 4 Medium RCS-C-05 High None Low 29-RC-ISIM-1704 RC-W030DM, RC-W069, RC-W035, RC- 5 ISIM-1704 1 W082, RC-W078DM 01RC RC-018 4 Medium RCS-C-05A High None Low 2.5-RC-ISIM-1704 RC-W074BC 1 ISIM-1704 1 01RC RC-019 4 Medium RCS-C-05B High None Low 6-RC-ISIM-1704 RC-W032BC, RC-W059 2 ISIM-1704 1 01RC RC-020 4 Medium RCS-C-06 High None Low 31-RC-ISIM-1704 RC-W079DM, RC-W083, RC-W038, RC- 8 ISIM-1704 1 W039, RC-W042, RC-W073, RC-W045, RC-1W048 01RC RC-021 4 Medium RCS-C-07 High None Low 27.5-RC-ISIM-1704 RC-W049, RC-W055, RC-W056, RC-W058DM 4 ISIM-1704 1 01RC RC-022 4 Medium RCS-C-07A High None Low 2.5-RC-ISIM-1704 RC-W075BC 1 ISIM-1704 1

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 6 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

System Risk Characterization Segment Categoryl Rank] Consequence ID Rank Failure Potential DMs Rank Lin Welds in Segment Weld

.Count S

E 01RC RC-023 4 Medium RCS-C-08 High None Low 2-RC-ISIM-1704 RC-W052BC 54 ISIM-1704 1 2-RC-ISIM-1461 RTD-W085S, RTD-W086S, RTD-W087S, RTD- ISIM-1461 W088S, RTD-W089S, RTD-W090S, RTD-W091S, RTD-W092S, RTD-W093S, RTD-W094S, RTD-W095S, RTD-W096S, RTD-W097S, RTD-W098S, RTD-W099S, RTD-W100S, RTD-W101S, RTD-W102S, RTD-W103S, RTD-W104S, RTD-W105S, RTD-W106B RTD-W056S, RTD-W057S, RTD-W058S, RTD-W059S, RTD-W060B, RTD-W061 B, RTD-W062S, RTD-W063S, RTD-W064S, RTD-W065S, RTD-W066S, RTD-W067S, RTD-W068S, RTD-W069S, RTD-W070S, RTD-W071S, RTD-W072S, RTD-W073S, RTD-W074S, RTD-W075S, RTD-W076S, RTD-W077S, RTD-W078B 3-RC-ISIM-1461 RTD-W107, RTD-W079, RTD-W080, RTD-W081, RTD-W082, RTD-W083, RTD-W084 3-RC-ISIM-1704 RC-W043BC 01RC RC-030 4 Medium RCS-C-10 High None Low 6-RC-ISIM-940-1 PR-W001DM, PR-W002 12 ISIM-940-1 T 3-RC-ISIM-940-1 PR-W003, PR-W004, PR-WO05, PR-W006, PR-W037, PR-W007, PR-W008, PR-W038, PR-W012, PR-W040 01RC RC-032 4 Medium RCS-C-11 High None Low 3-RC-ISIM-940-1 PR-W039, PR-WO11 2 ISIM-940-1 1 01RC RC-033 4 Medium RCS-C-12 High None Low 3-RC-ISIM-940-1 PR-W041, PR-W015 2 ISIM-940-1 1 01RC RC-034 4 Medium RCS-C-13 High None Low 6-RC-ISIM-940-2 PR-WV06DM, PR- W017, PR-WO18,; PR-WO1 9, 9 ISIM-940-2 1 PR-W020, PR-W021, PR-W022 PRRW023,

______ __ ____ ____ ________ PR-W025 _ _ _ _ _ _

01RC RC-035 4 Medium RCS-C-14 High None Low 6-RC-ISIM-940-2 PR-W026DM, PR-W027, PRA-W028, PR-W029, 10 ISIM-940-2 T PR-W030, PR-W031, PR-W032, PR-W033,"

PR-WO , PR-W036 .. .__.. .. .

01RC RC-036 4 Medium RCS-C-15 High None Low 3-RC-ISIM-1703 RC-W068BC 6 ISIM-1703 1 3-RC-ISIM-874-2 PS-W001, PS-W002, PS-W003, PS-W004, PS- ISIM-874-2 W005 01RC RC-037 4 Medium RCS-C-16 High None Low 3-RC-ISIM-1704 RC-W053BC 5 ISIM-1704 1 3-RC-ISIM-874-1 PS-W030, PS-W031, PS-W032, PS-W033 ISIM-874-1

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 7 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Welds in Segment Weld S N Segment Category Rank ID - Rank DMs Rank Count 01RC RC-038 4 Medium RCS-C-17 High None Low 3-RC-ISIM-874-1 PS-W034, PS-W035, PS-W036, PS-W037, PS- 19 ISIM-874-1 1 W038, PS-W039, PS-W040, PS-W041, PS-W042, PS-W043, PS-W044, PS-W045, PS-W046, PS-W047, PS-W048, PS-W049, PS-W050, PS-W051, PS-W052 01RC RC-040 4 Medium RCS-C-17 High None Low 4-RC-ISIM-874-1 PS-W060, PS-W061DM 2 ISIM-874-1 1 01RC RC-041 4 Medium RCS-C-17 High None Low 3-RC-ISIM-874-2 PS-WO06, PS-W007, PS-W008, PS-W009, PS- 24 ISIM-874-2 1 W010, PS-WO11, PS-W012, PS-W013, PS-W014, PS-WO15, PS-WO16, PS-W017, PS-W018, PS-W019, PS-W020, PS-W021, PS-W022, PS-W023, PS-W024, PS-W025, PS-W026, PS-W027BC, PS-W028, PS-W029 01RC RC-042 4 Medium RHR-C-05A1 High None Low 8-RC-ISIM-1703 RC-WO03BC 1 ISIM-1703 1 01RC RC-043 4 Medium RHR-C-05B1 High None Low 8-RC-ISIM-1704 RC-W034BC 1 ISIM-1704 1 02RHR RHR-021 4 Medium RHR-C-05A1 High None Low 8-RHR-ISIM-957-1 RHR-WO01, RHR-W002 2 ISIM-957-1-1 I 02RHR RHR-023 4 Medium RHR-C-05A1 High None Low 8-RHR-ISIM-957-1 RHR-W007, RHR-W008, RHR-W009 3 !SIM-957-.1- 1 02RHR RHR-025 4 Medium RHR-C-05B1 High None Low 8-RHR-ISIM-957-1 RHR-W025, RHR-W026 2 ISIM-957-1-1* 1 02RHR RHR-027 4 Medium RHR-C-05B1 High None Low 8-RHR-ISIM-957-1 RHR-W031, RHR-W032 2 ISIM-957-1-1 1 02RHR RHR-003 4 Medium ICS-C-02A High None Low 6-RHR-ISIM-950-1 RHR-W408 1 ISIM-950-1 2 02RHR RHR-004 4 Medium ICS-C-02B High None Low 6-RHR-ISIM-950-2 RHR-W411 1 ISIM-950-2 2 02RHR RHR-005 4 Medium RHR-C-01A High None Low 10-RHR-ISIM-958-1 RHR-W417, RHR-W080, RHR-W081 3 ISIM-958-1-2, 2 02RHR RHR-006 4 Medium RHR-C-01B High None Low 10-RHR-ISIM-959-1 RHR-W329, RHR-W118, RHR-W119 3 ISIM-959-1-1 2 02RHR RHR-007 4 Medium RHR-C-02A High None Low 10-RHR-ISIM-958-1 RHR-W082, RHR-W083, RHR-W084, RHR- 12 ISIM-958-1-1 2 W085 ISIM-958-1-2 8-RHR-ISIM-958-2 RHR-W078, RHR-W079, RHR-W086BC ISIM-958-2 10-RHR-ISIM-958-1 RHR-W091, RHR-W092, RHR-W093, RHR-W094, RHR-W095BC 02RHR RHR-010 4 Medium RHR-C-02AH High None Low 8-RHR-ISIM-958-2 RHR-W075, RHR-W076, RHR-W077 3 ISIM-958-2 2 02RHR RHR-011 4 Medium RHR-C-02AS High None Low 12-RHR-ISIM-958-1 RHR-W087, RHR-W088, RHR-W089 4 ISIM-958-1-1 2 10-RHR-ISIM-958-1 RHR-W090 02RHR RHR-012 4 Medium RHR-C-02B High None Low 10-RHR-ISIM-959-1 RHR-W120, RHR-W121, RHR-W123, RHR- 12 ISIM. 959 1 1i: 2 W124, RHR-W126, RHR-W127 SIM 959-2" 8-RHR-ISIM-959-1 RHR-W109, RHR-W117, RHR-W125BC 02RHR_ RHR-015 4 Medium RHR-C-02H High None_ 1ow 8-RHR-ISIM-959-2 RHR-W116, RHR-W117, RHR-W1222BC 2 02RHR RHR-015 4 Medium RHR-C-O2BH High None Low 8-RHR-ISIM-958-2 RHR-W107, RHR-W108 2 II 02RHR RHR-016 4 Medium RHR-C-02BS High None Low 12-RHR-ISIM-959-2 RHR-W111, RHR-W112, RHR-W113, RHR- 5 ISIM-959-2 2 W114 10-RHR-ISIM-959-2 RHR-W1 15

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 8 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Weld

~tgr I Rank IakI n Iem I Rak D s I RankCon Welds in Segment Count Sketch No(s). CC Segment Category ID Rank DIs R Lines in Segment 02RHR RHR-017 4 Medium RHR-C-03A High None Low 10-RHR-ISIM-958-1 RHR-W096, RHR-W097, RHR-W098, RHR- 7 ','ISIM-958-1-1 2 W099, RHR-W100, RHR-W101, RHR-Wl02 02RHR RHR-018 4 Medium RHR-C-03B High None Low 10-RHR-ISIM-959-1 RHR-W128, RHR-W129, RHR-W130, RHR- 6 "IS1M959-1-1 2 W131, RHR-W132, RHR-W133 _____

02RHR RHR-036 4 Medium RHR-C-11A High None Low 6-RHR-ISIM-958-1 RHR-W134, RHR-W135 3 IlSIM-958-1-1 2 8-RHR-ISIM-958-1 RHR-W136 02RHR RHR-037 4 Medium RHR-C-11B High None Low 6-RHR-ISIM-959-2 RHR-W191, RHR-W192 3 ISIM-959-2 2 8-RHR-ISIM-959-2 RHR-W193 02RHR RHR-038 4 Medium RHR-C-12A1 High None Low 8-RHR-ISIM-958-1 RHR-W137, RHR-W138, RHR-W139 3 ISIM-958-1-1 2 02RHR RHR-039 4 Medium RHR-C-12A2 High None Low 8-RHR-ISIM-958-1 RHR-W140*, RHR-W141* 2 ISIM-958-1-1 2 02RHR RHR-040 4 Medium RHR-C-12B1 High None Low 8-RHR-ISIM-959-2 RHR-W194, RHR-W195, RHR-W196 3 ISIM-959-2 2 02RHR RHR-041 4 Medium RHR-C-12B2 High None Low 8-RHR-ISIM-959-2 RHR-W197*, RHR-W198*, RHR-W199, RHR- 4 ISIM-959-2 2 W200 02RHR RHR-042 4 Medium RHR-C-13A High None Low 8-RHR-ISIM-960-1 RHR-W142, RHR-W143, RHR-W143-1, RHR- 14 ISIM-960-1 2 W143-2, RHR-W144, RHR-W145, RHR-W146, RHR-W147, RHR-W148, RHR-W149, RHR-W150, RHR-W151, RHR-W152, RHR-W230 02RHR RHR-043 4 Medium RHR-C-13B High None Low 8-RHR-ISIM-960-1 RHR-W201, RHR-W202, RHR-W202-1, RHR- 12 ISIM-960-1 2 W202-2, RHR-W203, RHR-W204, RHR-W205, RHR-W206, RHR-W207, RHR-W208, RHR-W209, RHR-W240 02RHR RHR-044 4 Medium RHR-C-14A High None Low 8-RHR-ISIM-960-1 RHR-W153, RHR-W154, RHR-W155, RHR- 6 ISIM-960-1 2 W1 56 ISIM-962-2-1 8-RHR-ISIM-962-2 RHR-W254, RHR-W253 _ _

02RHR RHR-045 4 Medium RHR-C-14A High None Low 8-RHR-ISIM-962-2 RHR-W159, RHR-W158 8 ISIM-962 T 2 8-RHR-ISIM-962-2 RHR-W157, RHR-W160, RHR-W161 ISIM-962-2-2 8-RHR-ISIM-962-2 RHR-W162, RHR-W163, RHR-W164 _. _  : -_

02RHR RHR-047 4 Medium RHR-C-14A High None Low 10-RHR-ISIM-962-2 RHR-W169*, RHR-W170*, RHR-W171, RHR- 9 . ISIM-938-2-1 2 W172, RHR-W173, RHR-W174, RHR-W175, ISIM-962-2-1

  • RHR-W176

______ __________1

________ 0-RHR-ISIM-938-2 RHR-W1 76A______

02RHR RHR-049 4 Medium RHR-C-14B High None Low 8-RHR-ISIM-960-1 RHR-W210, RHR-W211, RHR-W212, RHR- 16 ISIM-960-1 2 W213 ISIM-961-1 8-RHR-ISIM-961-2 RHR-W214, RHR-W215, RHR-W216, RHR- ISIM-961-2 W217, RHR-W218, RHR-W219, RHR-W220, RHR-W221, RHR-W222, RHR-W223, RHR-W224 8-RHR-ISIM-961-1 RHR-W225*

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 9 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Weld System ~~~Lines in Segment Wlsi emn ount Sketch No(s).

CWelds CC ID Rank DMs Rank in Segment Segment Categoryj Rank 02RHR RHR-050 4 Medium RHR-C-14B High None Low 8-RHR-ISIM-961-2 RHR-W284, RHR-W285 2 ISIM-961-2 2 02RHR RHR-051 4 Medium RHR-C-15A High None Low 10-RHR-ISIM-938-2 RHR-W177, RHR-W177A 2 ISIM-938-2-1 2 02RHR RHR-052 4 Medium RHR-C-15A1 High None Low 8-RHR-ISIM-962-2 RHR-W255, RHR-W256, RHR-W257, RHR- 21 ISIM-950-1 2 W258, RHR-W259, RHR-W260, RHR-W261 ISIM-962-2-1 6-RHR-ISIM-950-1 RHR-W262, RHR-W263, RHR-W264, RHR-W265, RHR-W266, RHR-W267, RHR-W268, RHR-W269, RHR-W270, RHR-W271, RHR-W272, RHR-W273, RHR-W274, RHR-W275 02RHR RHR-053 4 Medium RHR-C-15A1 High None Low 6-RHR-ISIM-933 RHR-W276, RHR-W277, RHR-W278, RHR- 8 ISIM-933 2 W279", RHR-W280, RHR-W281, RHR-W282, RHR-W283 02RHR RHR-056 4 Medium RHR-C-15B1 High None Low 8-RHR-ISIM-961-2 RHR-W286, RHR-W287, RHR-W288, RHR- 29 ISIM-950-2 2 W289, RHR-W290, RHR-W291, RHR-W292, ISIM-961-2 RHR-W293, RHR-W294, RHR-W295, RHR-W296, RHR-W297 6-RHR-ISIM-950-2 RHR-W298, RHR-W299, RHR-W300, RHR-W301, RHR-W302, RHR-W303, RHR-W304, RHR-W305, RHR-W306, RHR-W307, RHR-W308, RHR-W309, RHR-W311, RHR-W312, RHR-W313, RHR-W310, RHR-W314 02RHR RHR-057 4 Medium RHR-C-15B1 High None Low 6-RHR-ISIM-933 RHR-W315, RHR-W316*, RHR-W317, RHR- 14 ISIM-933 2 W318, RHR-W319, RHR-W320, RHR-W321, RHR-W322, RHR-W323, RHR-W324, RHR-W325, RHR-W326, RHR-W327, RHR-W328 02RHR RHR-064 4 Medium RWST-C-01 High None Low 6-RHR-ISIM-961-1 RHR-W419, RHR-W420, RHR-W421, RHR- 13 ISIM-961-1 2 W422, RHR-W423, RHR-W424, RHR-W425, RHR-W426, RHR-W427, RHR-W428, RHR-W429, RHR-W430, RHR-W431BC 03SI SI-028 4 Medium IL-C-14 High None Low 12-SI-ISIM-935 SI-W120, SI-W121, SI-W122, SI-W123 4 ISIM-935 1 03SI SI-039 4 Medium IL-C-19 High None Low 6-SI-ISIM-938-2 SI-W108 3 ISIM-938-2-1",, 1 4-SI-ISIM-938-2 SI-W109, SI-W110 _ _ _.

03SI SI-046 4 Medium IL-C-22 High None Low 6-SI-ISIM-939 SI-W048, SI-W049, SI-W050, SI-W051, SI- 5 ISIM-939-1 1 W052 03SI SI-001 4 Medium IL-C-01 High None Low 3-SI-ISIM-934-2 SI-W265, SI-W266, SI-W267, SI-W268 4 ISIM-934-2 2 03;1 SI-001A 4 Medium IL-C-01B High None Low I SI-W603, SI-W604 2 M-1952 2

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 10 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342) 1Risk Characterization Consequence Failure Potential Weld 03SI Segment SI-002 Category 4

Rank Medium ID IL-C-01A High DMs None Rank Low Lines in Segment 3-SI-ISIM-934-2 SI-W269 Welds in Segment C Count 2

t c o ISIM-934-2 EC 2

4-SI-ISIM-934-2 SI-W270 03SI SI-003 4 Medium IL-C-02 High None Low 4-SI-ISIM-936 SI-W271 40 ISIM-936 2 3-SI-ISIM-936 SI-W272, S1-W273, SI-W274, SI-W275, SI- ISIM-982 W276, SI-W277, SI-W278, SI-W279, SI-W280, Sl-W281, SI-W282, SI-W283, SI-W284, SI-W285, SI-W286, SI-W287 2-SI-ISIM-936 SI-W288, SI-W289S, Sl-W557Sý,SI-W291S 2-SI-ISIM-982 SI-W438S, SI-W439S, SI-W440S, SI-W441S, SI-W442S, SI-W443S, SI-W444S, SI-W445S, SI-W446S, SI-W447S, SI-W448S, SI-W449S, SI-W450S, SI-W451S, Sl-W452S, SI-W453S, SI-W542S, SI-W543S, SI-W454S 03SI SI-017 4 Medium IL-C-09 High None Low 3-Sl-ISIM-934-1 SI-W237 1 ISIM-934-1 2 03SI SI-018 4 Medium IL-C-09A High None Low 3-S1-ISIM-934-1 SI-W238, SI-W239 2 ISIM-934-1 2 03SI SI-019 4 Medium IL-C-10 High None Low 4-S1-ISIM-937-2 SI-W304 33 ISIM-937-2-1 2 3-SI-ISIM-937-2 SI-W305, S1-W306, SI-W307, Sl-W308 ISIM-937-2-2:

2-SI-ISIM-937-2 SI-W309S, SI-W310S, Sl-W311S, S1-W312S, ISIM-937-1 SI-W31 3S, Sl-W314S, SI-W31 5S, Sl-W316S, SI-W317S, SI-W318S, SI-W319S, S1-W551S, SI-W552S, SI-W320S 3-S1-ISIM-937-2 SI-W338, SI-W339, SI-W340, SI-W341 3-S1-ISIM-937-1 SI-W342, SI-W343, SI-W344, SI-W345, SI-W346, SI-W347, SI-W348, SI-W349 2-S1-ISIM-937-1 SI-W350S, S1-W546S 03SI SI-048 4 Medium RHR-C-14B High None Low 6-SI-ISIM-961-2 SI-W128, SI-W129, SI-W130, SI-W131, SI- 21 ISIM-961-2 2 W132, SI-W133, SI-W134, SI-W135, SI-W136, SI-W137, SI-W138, SI-W139, SI-W140, SI-W141, SI-W142, SI-W143, SI-W144, SI-W145, Sl-W146, SI-W147, Sl-W148 03SI SI-050 4 Medium RWST-C-01 High None Low 16-SI-ISIM-992-1 S1-W560, SI-W570, S1-W57. , S1-W573, SI- 19 ISIM-959-1-1S 2 W574, SI-W575, SI-W576, Sl-W577, Sl-W578, ISIM-992-1 Sl-W579, SI-W585 12-Sl-ISIM-992-1 Sl-W586, SI-W587, Sl-W588 12-Sl-ISIM-959-1 SI-W561, SI-W562, SI-W563

_10-Sl-ISIM-959-1 SI-W564, SI-W565 03SI SI-051 4 Medium RWST-C-01 High None Low 10-S1-ISIM-958-1 SI-W558BC 2 IStI-M958-1-1 2 1 10-SI-ISIM-958-1 SI-W559 .....I$!M-958-1-2

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 11 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Weld System Segmrent Categoryl Rank Lines in Segment Welds in Segment Sketch No(s). C ID Rank DIVs Rank CountE 03SI SI-052 4 Medium RWST-C-01 High None Low 12-SI-ISIM-992-1 SI-W580, SI-W581, SI-W582, SI-W583 4 ISIM-992-1 2 03SI SI-053 4 Medium RWST-C-01 High None Low 12-SI-ISIM-992-1 SI-W584 1 ISIM-992-1 2 03SI SI-054 4 Medium RWST-C-01 High None Low 6-SI-ISIM-992-1 SI-W572BC 1 ISIM-992-1 2 03SI SI-055 4 Medium SI-C-01 High None Low 8-SI-ISIM-992-1 SI-W466, SI-W467, SI-W468, SI-W469, SI- 67 ISIM-992-1 2 W470, SI-W471, SI-W472, SI-W473, SI-W474, ISIM-933 SI-W475, SI-W476, SI-W477 ISIM-1608 12-SI-ISIM-992-1 SI-W478, SI-W479, SI-W480, SI-W481, SI-W482, SI-W483, SI-W484, SI-W485, SI-W486, SI-W487, SI-W488, SI-W489 12-SI-ISIM-933 SI-W417, SI-W418, SI-W419, SI-W420 6-SI-ISIM-933 SI-W421, SI-W422 12-SI-ISIM-933 SI-W403, SI-W407 6-SI-ISIM-933 SI-W408, SI-W409, SI-W410 2-SI-ISIM-933 SI-W404BC, SI-W405S, SI-W406S 2-SI-ISIM-1608 SI-W360S, SI-W361S, SI-W362S, SI-W363S, SI-W364S, SI-W365S, SI-W366S, SI-W367S 2-SI-ISIM-992-1 SI-W368BC 2-SI-ISIM;1608 SI-W369S, SI-W370S, SI-W371S, SI-W372S, SI-W373S, SI-W374S, SI-W375S, SI-W600S, SI-W601S, SI-W602S, SI-W376S, SI-W377S, SI-W378S, SI-W379S, SI-W380S, SI-W381S, 2-SI-ISIM-992-1 SI-W382S, SI-W383S, SI-W384S SI-W385BC 03S] SI-063 4 Medium SI-C-02A High None Low 6-SI-ISIM-933 SI-W394, SI-W395, SI-W396, SI-W397, SI- 15 ISIM-933 2 W398, SI-W400, SI-W401, SI-W402 SI-W411, Sl-W412, SI-W413, SI-W414, SI--

W415, SI-W416, SI-W399BC 03SI SI-065 4 Medium SI-C-02B High None Low 6-SI-ISIM-933 SI-W429, SI-W430, SI-W431, Sl-W432, SI- 15 ISIM-933 2 W433, SI-W435, SI-W436, Sl-W437 SI-W423, SI-W424, SI-W425, SI-W426, SI-W427, SI-W428, SI-W434BC 03SI SI-067 4 Medium SI-C-03A High None Low 4-SI-lSIM-934-2 SI-W240, SI-W241, SI-W242 8 ISIM-934-2 2-SI-ISIM-934-2 SI-W4911BC ISIM-993 2-SI-ISIM-993 SI-W492S, SI-W493S, SI-W494S, SI-W495S

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 12 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Segment SytmLines Category Rank ID -

Consequence Rank Failure Potential DMs Rank in Segment Welds in SegmentSkthNs)

Weld Count

)

E C 03SI SI-069 4 Medium SI-C-03B High None Low 4-SI-ISIM-934-1 SI-W200, SI-W201, SI-W202 8 ISIM-934-1 2 2-SI-ISIM-934-1 SI-W540BC ISIM-993 2-SI-ISIM-993 SI-W541S, SI-W538S, SI-W537S, SI-W536S 03SI SI-073 4 Medium SI-C-05 High None Low 2-SI-ISIM-993 SI-W498S, SI-W499S, SI-W500S, SI-W501S, 34 ISIM-993 2 SI-W502S, SI-W503S, SI-W504S, SI-W505S, SI-W506S, SI-W507S, SI-W508S, SI-W509S, SI-W510S, SI-W511S, SI-W512S, SI-W513S, SI-W514S, SI-W515S, SI-W516S, SI-W517S SI-W533S, SI-W532S, SI-W531S, SI-W530S, SI-W529S, SI-W528S, SI-W527S, SI-W526S, SI-W525S, SI-W524S, SI-W523S, SI-W522S, SI-W521S, SI-W520S 03SI SI-080 4 Medium SI-C-07A High None Low 4-S1-ISIM-934-2 S1-W243, S1-W244, Sl-W245, S1-W246, SI- 5 ISIM-934-2 2 W247 03SI SI-081 4 Medium SI-C-07B High None Low 4-S1-ISIM-934-1 SI-W203, SI-W204, SI-W205, SI-W206, SI- 5 ISIM-934-1 2 W207 03SI SI-082 4 Medium SI-C-08 High None Low 4-S1-ISIM-934-2 SI-W248, SI-W220 28 ISIM-934-2 2 3-S1-ISIM-934-2 SI-W249, S1-W250, SI-W251, SI-W252, SI- ISIM-934-1 W253, SI-W254, Sl-W255 3-S1-ISIM-934-1 SI-W219, SI-W218, SI-W217, SI-W216, SI-W215, SI-W214, SI-W213, SI-W212, SI-W211, SI-W210 4-S1-ISIM-934-1 SI-W209, SI-W208 3-S1-ISIM-934-1 SI-W221, SI-W222, SI-W223, SI-W224, SI-W225, SI-W226, SI-W227 03SI SI-085 4 Medium SI-C-08A High None Low 3-S1-ISIM-934-2 SI-W256, SI-W257, SI-W258, SI-W259, SI- 9 ISIM-934-2 2 W260, SI-W261, SI-W262, SI-W263, SI-W264 03SI SI-086 4 Medium SI-C-08B High None Low 3-S1-ISIM-934-1 SI-W228, SI-W229 2 ISIM-934-1 2 03SI SI-087 4 Medium SI-C-09B High None Low 3-Sl-ISIM-934-1 SI-W2,0S1-W231* I-w232 S1-W233 ' 4 ISIM-934-1 2 03SI SI-088 4 Medium SI-C-10B High None Low 3-SI-ISIM-934-1 SI-W234, SI-W235, SI-W236 3 ISIM-934-1 2 04CVC CVC-005 4 Medium CVCS-C-05 High None Low 2-CVC-ISIM-1474 LD-W001S, LD-WO02S, LD-W003S, LD- 14 ISIM-1474 1 W004S, LD-WO05S, LD-W006S, LD-W007S, LD-W008S, LD-W009S, LD-WO10S, LD-W011S, LD-W012S WD-WO1 7S, WD-WO1 8S O4CVC CVC-009 4 Medium CVCS-C-09 High None Low 2-CVC-ISIM-1369-2 IWD-WO01S, WD-W002S, WD-W003S 3 ISIM-1369-2 1

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 13 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Weld System Segment Category Rank ID Lines in Segment Welds in Segment Coun Sketch No(s). CC Iemn Caegr I IakRank DIVs RankCon 04CVC CVC-011 4 Medium CVCS-C-09 High None Low 2-CVC-ISIM-1369-2 WD-W006S, WD-WO07S, WD-WO08S, WD- 6 ISIM-1369-2 1 W009S, WD-W01OS, WD-WO11S 04CVC CVC-019 4 Medium CVCS-C-13 High None Low 2-CVC-ISIM-1471 CVC-W039S, CVC-W040S, CVC-W041S, CVC- 20 ISIM-1471 1 W042S, CVC-W043S, CVC-W044S, CVC-W045S, CVC-W046S, CVC-W047S, CVC-W048S, CVC-W049S, CVC-W050S, CVC-W051S, CVC-W052S, CVC-W053S, CVC-W054S, CVC-W055S 1.5-CVC-ISIM-1471 CVC-W056S, CVC-W057S, CVC-W180B 04CVC CVC-023 4 Medium CVCS-C-15 High None Low 2-CVC-ISIM-1476 CVC-W133S, CVC-W134S, CVC-W135S, CVC- 20 ISIM-1476 1 W136S, CVC-W137S, CVC-W138S, CVC-W139S, 'CVC-W140S, CVC-W141S, CVC-W142S, CVC-W143S, CVC-W144S, CVC-W145S, CVC-W146S, CVC-W147S, CVC-W148S, CVC-W149S 1.5-CVC-ISIM-1476 CVC-W150S, CVC-W151S, CVC-W152S 04CVC CVC-024 4 Medium RCS-C-17 High None Low 2-CVC-ISIM-874-3 CVC-W155S, CVC-W156S, CVC-W157S, CVC- 25 ISIM-874-3 1 W158S, CVC-W159S, CVC-W160S, CVC-W161S, CVC-W162S, CVC-W163S, CVC-W164S, CVC-W165S, CVC-W166S, CVC-W167S, CVC-W168S, CVC-W169S, CVC-W1 70S, CVC-W1 71S, CVC-W1 72S, CVC-W173S, CVC-W174S, CVC-W175S, CVC-W176S, CVC-W177S, CVC-W178S, CVC-W1 79S 071CS ICS-001 4 Medium ICS-C-02A High None Low 8-ICS-ISIM-950-1 ICS-W045 5 ISIM-950-1 2 6-ICS-ISIM-950-1 ICS-WO46BC 8-ICS-ISIM-950-1 ICS-W047 6-ICS-ISIM-950-1 ICS-W048, ICS-W049 071CS ICS-003 4 Medium ICS-C-02B High None Low 8-ICS-ISIM-950-2 ICS-WO50 5 ISIM-950-2 2 6-ICS-ISIM-950-2 ICS-WO51BC 8-ICS-ISIM-950-2 ICS-W052 6-ICS-ISIM-950-2 ICS-W053, ICS-W054 -

071CS ICS-005 4 Medium ICS-C-03A High None Low 6-ICS-ISIM-951 ICS-W001i ICS'W002, ICS-W003, ICS-W004, 7 ISIM-951 2 ICS-WO10, IC-19 071CS ICS-007 4 Medium ICS-C-03B High None Low 6-ICS-ISIM-953 ICS-W100 lCSý!W01, ICS-W102, ICS-W103, 7 ISIM-953 2 ICS-W183,

_____ ____ ___ ___ _ ____ ____ _____ ___ CS-W1 09, ',CS7,W1 86. _ _ __ _ _ _

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 14 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential "Weld 071CS' Segment ICS-009 Category 4

Rank Medium ID ICS-C-04A Rank High DMs None

[ S Rank Low Lines in Segment 6-ICS-ISIM-951 Welds in Segment ICS-W90, ICS-W007BC,.ICS-W191, ICS-Count 31 Sketch No(s).

ISIM-951 E 2 W193, CS-W1I94, ICS-WO11, ICS-W012, ICS-W013, ICS-W014, ICS-WO15, ICS-WO16, ICS-W017, ICS-W018, ICS-W019, ICS-W020, ICS-W02>i1 ICS-W022, ICS-WO23, ICS"W024, ICS-W025, ICS-Wo26, ICsW027, ICS-Wo28, CS-W029, ICS-W030, ICS-W031, ICS-W032, ICS>

)033" ICS-W034*, ICS-W035, ICS-W036 071CS ICS-011 4 Medium ICS-C-04B High None Low 6-ICS-ISIM-953 ICS-W185, ICS+W106BC1--, ICS-W184, ICS- 17',: ISIM-953 2 Wi187,*lcs7w. 88, ICS-W1 10, ICS-W 111 CS-W1 12, ICS-W113, ICS-W114, ICS-Wl 15, ICS, W1 16, 1CS-W1 17, :ICS-W1 18, :ICS&W 1%; ICS- i.

07CS IS-2 4 Medium R 0Nw - 6W120, ICS-W7121 071CS ICS-021 4 Medium RWST-C-01 High None Low 6-ICS-ISIM-1646 ICS-W173, ICS-W174, ICS-W175, ICS-W176 4 ISIM-1646 2 071CS ICS-022 4 Medium RWST-C-02 High None Low 12-ICS-ISIM-950-1 ICS-W179, ICS-W163, ICS-W164, ICS-W165, 10 ISIM-950-1 2 ICS-W166, ICS-W167, ICS-W168 ISIM-950-2 8-ICS-ISIM-950-1 ICS-W169 8-ICS-ISIM-950-2 ICS-W170, ICS-W171 071CS ICS-023 4 Medium RWST-C-02 High None Low 12-ICS-ISIM-950-1 ICS-W158 4 ISIM-950-1 2 I I 8-ICS-ISIM-950-1 ICS-W159, ICS-W160, ICS-W161 071CS ICS-024 4 Medium RWST-C-03 High None Low 8-ICS-ISIM-950-1 ICS-W1 62 1 ISIM-950-1 2 071CS ICS-025 4 Medium RWST-C-04 High None Low 8-ICS-ISIM-950-2 ICS-W1 72 1 ISIM-950-2 2 08AF AF-001 4 Medium AFW-C-01A High None Low 3-AF-ISIM-891-2 AF:WW. 1 56, AFW-W*57* AF WW58, AFW- 24 ISIM-891-2 2 W 159, AFW-W1 60, AFW-W161 I-AFW-W21-2, AFW-W162*, AFW-Wl63*, AEW-Wi 64, AFW-W165, AFW-W21 6,AFW-W2133AFW-W2i 9, AFW-W218, AFW-W217, AFW-W215,;AFW-W214, AFW-W171- AFW-W221 *AFW-W222, AFW-W223,; AFW-W224, AFW-W225 .

08AF AF-003 4 Medium AFW-C-01A1 High None Low 3-AF-ISIM-877-1 AFW-W014, AFW-W015, AFW-W016, AFW- 4 ISIM-877-1 2 W017

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 15 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Weld S Lines in Segment Segment Category I Rank ID Rank DMs J Rank Welds in Segment Count Sketch No(s) C 08AF AF-004 4 Medium AFW-C-01A2 High None Low 3-AF-ISIM-877-1 AFW-W018, AFW-W019, AFW-W020, AFW- 25 ISIM-877-1 2 W021, AFW-W022, AFW-W023, AFW-W024, AFW-W025, AFW-W148, AFW-W149, AFW-W1 50, AFW-W1 51, AFW-WI 89, AFW-W1 90, AFW-W028, AFW-W029, AFW-W030, AFW-W031, AFW-W032, AFW-W033, AFW-W034, AFW-W035, AFW-W036, AFW-W037, AFW-W038 08AF AF-005 4 Medium AFW-C-01A3 High None Low 3-AF-ISIM-877-1 AFW-W039, AFW-W040 16 ISIM-877-1 2 3-AF-ISIM-877-2 AFW-W041, AFW-W042, AFW-W043, AFW- ISIM-877-2 W044, AFW-W045, AFW-W046, AFW-W047, AFW-W048, AFW-W049, AFW-W050, AFW-W051, AFW-W052, AFW-W053, AFW-W054 08AF AF-007 4 Medium AFW-C-01B High None Low 3-AF-ISIM-891-2 AFW-W172, AFW-W173, AFW-W174, AFW- 50', ISIM-891-2i 2 W208, AFW-W209, AFW-'W210, AFW-W1 76, ISIM-891-1 AFW-W177, AW FVV-17I ..... ISIM-89i-3, W202, AFW-W203, AFW-W204,-AFW-W205" AFW-W206, AFW-W207, AFW-W211, AFW-W184, AFW-W185, AFW-W186, AFW-W187',

AFWV-W188*, AFW-W195 3-AF-ISIM-891-1 AFW-W094,AFW-W095, AFW-W096, AFW-W097,AFW-W098, AFW-W152 AFW-W153, AFW W191 3-AF-ISIM-891-3 AFW-W2269AFW2W227 AFW-W228, 1 AFW:

W229 :AFWW230, AFW W231, AFW W232, AFW-W233, AFW-W234, AFW-W235*, AEW-W236, AFW-W237, AFW-W238, AFW-W239*,

AFW-W240* AFW-W241, AFW-W242, AEW-W243, AFW-W245 O K> , .

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 16 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

System Risk Characterization rTI Consequence Failure Potential i Lines in Segment Welds in Segment Weld Sec os.C Segment Category I Rank ID Rank DMs j Rank CountI 08AF AF-009 4 Medium AFW-C-01B1 High None Low 3-AF-ISIM-891-1 AFW-W154, AFW-W155, AFW-W192, AFW- 23 ISIM-891-1 2 W193, AFW-Wl01, AFW-Wl02, AFW-W103, AFW-W104, AFW-Wl05, AFW-W106, AFW-W107, AFW-W108, AFW-W109, AFW-W110, AFW-W1 11, AFW-W1 12, AFW-W1 13, AFW-W1 14, AFW-Wl 15, AFW-W1 16, AFW-W1 17, AFW-W1 18, AFW-W1 19 08AF AF-010 4 Medium AFW-C-01B2 High None Low 3-AF-ISIM-891-1 AFW-W120, AFW-W121 2 ISIM-891-1 2 03SI SI-012 5a Medium IL-C-04 Medium TT, IGSCC Medium 2-SI-ISIM-982 SI-WO11B 2 ISIM-982 1 6-SI-ISIM-982 SI-W012 03SI SI-016 5a Medium IL-C-07 Medium TT, IGSCC Medium 2-SI-ISIM-936 SI-W087B 2 ISIM-936 1 6-SI-ISIM-936 SI-W088 03SI SI-032 5a Medium IL-C-15 Medium TT, IGSCC Medium 12-SI-ISIM-938-1 SI-W074 1 ISIM-938-1 1 03SI SI-027 5a Medium IL-C-13 Medium IGSCC Medium 12-SI-ISIM-935 SI-W119 1 ISIM-935 1 03SI SI-031 5a Medium IL-C-15 Medium IGSCC Medium 12-SI-ISIM-938-1 SI-W072, SI-W073 2 ISIM-938-1 1 03SI SI-038 5a Medium IL-C-18 Medium IGSCC Medium 6-SI-ISIM-938-2 Sl-W107 1 ISIM-938i2-11 1 03SI SI-044 5a Medium IL-C-21 Medium IGSCC Medium 6-SI-ISIM-939 SI-W047 1 ISIM-939-1 1 04CVC CVC-001 5a Medium CVCS-C-01 Medium TT Medium 2-CVC-ISIM-1473 CVC-W063S, CVC-W062S, CVC-W061S, CVC- 5 ISIM-1473 1 1_ W060S, CVC-W059S 06FW FW-001 5a Medium AFW-C-04A -Medium TASCS Medium 8-FW-ISIM-970 FW-W026, FW-W066 2 ISIM-970 2 06FW FW-002 5a Medium AFW-C-04B Medium TASCS Medium 8-FW-ISIM-866 FW-W054 1 ISIM-866 2 06FW FW-011 5a Medium FW-C-04A Medium TASCS Medium 16-FW-ISIM-970 FW-W024, FW-W025, FW-W060, FW-W063, 7 ISIM-970 2 FW-W058, FW-W064 8-FW-ISIM-970 FW-W027BC 06FW FW-013 5a Medium FW-C-04B Medium TASCS Medium 16-FW-ISIM-971 FW-W052, FW-W061, FW-W062, FW-W059, 6 ISIM-971 2 FW-W065 8-FW-ISIM-971 FW-W055BC 08AF AF-015 5a Medium AFW-C-04A Medium TASCS, TT Medium 3-AF-ISIM-865 AFW-W079, AFW-W147 2 ISIM-865 2 08AF AF-016 5a Medium AFW-C-04B Medium TASCS, TT Medium 3-AF-ISIM-866 AFW-W142, AFW-W143, AFW-W144, AFW- 4 ISIM-866 2 1 1_ W145 02RHR RHR-024 6a Low RHR-C-05A2 Medium None Low 8-RHR-ISIM-957-1 RHR-W010, RHR-W011, RHR-W012, RHR- 17 ISIM2957* i1 1 W013, RHR-W014, RHR-WO15, RHR-W016, RHR-W017, RHR-W018, RHR-W019, RHR-W020, RHR-W021, RHR-W022, RHR-W023, RHR-W024, RHR-W432BC, RHR-W433S

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 17 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential L Weld 02RHR Segment RHR-028 CategoryI 6a Rank Low ID RHR-C-05B2 j Rank Medium DMs None Rank Low 8-RHR-ISIM-957-1 RSletch7 RHR-W033, RHR-W034, RHR-W035, RHR-Count 12 ISIM-957-1-1 Es)'2 C

1 W036, RHR-W037, RHR-W038, RHR-W039, ISIM-957-1-2 RHR-W040, RHR-W041, RHR-W042, RHR- A -

W043 8-RHR-ISIM-957-1 RHR-W044 02RHR RHR-001 6a Low ICS-C-01A Medium None Low 6-RHR-ISIM-950-1 RHR-W406, RHR-W407 2 ISIM-950-1 2 02RHR RHR-002 6a Low ICS-C-01B Medium None Low 6-RHR-ISIM-950-2 RHR-W409, RHR-W410 2 ISIM-950-2 2 02RHR RHR-019 6a Low RHR-C-04A1 Medium None Low 12-RHR-.ISIM-958-1 RHR-W413, RHR-W414 2 ,_IlSIM-958-1-1 2 02RHR RHR-020 6a Low RHR-C-04B1 Medium None Low 12-RHR-ISIM-959-2 RHR-W401, RHR-W400 2 ISIM-959-2 2 02RHR RHR-029 6a Low RHR-C-06 Medium None Low 8-RHR-ISIM-957-1 RHR-W046 4 ISIM-957-1 2 10-RHR-ISIM-957-1 RHR-W047, RHR-W048 .ISIM-957-*--2 8-RHR-ISIM-957-1 RHR-W045 _____

02RHR RHR-030 6a Low RHR-C-06 Medium None Low 10-RHR-ISIM-957-2 RHR-W049, RHR-W050, RHR-W051, RHR- 13 ISIM-957-2 2 W053, RHR-W054, RHR-W055, RHR-W056, RHR-W057, RHR-W058, RHR-W059, RHR-W060, RHR-W061, RHR-W062 02RHR RHR-031 6a Low RHR-C-07 Medium None Low 10-RHR-ISIM-957-2 RHR-W412, RHR-W063C, RHR-W063B 7 ISIM-957-2 2 10-RHR-ISIM-958-2 RHR-W063A, RHR-W063, RHR-W064, RHR- ISIM-958-2 W065 02RHR RHR-032 6a Low RHR-C-08 Medium None Low 10-RHR-ISIM-958-2 RHR-W066A, RHR-W067, RHR-W066, RHR- 8 ISIM-958-2 2 W068, RHR-W069 10-RHR-ISIM-958-2 RHR-W071 8-RHR-ISIM-958-2 RHR-W072, RHR-W073 02RHR RHR-033 6a Low RHR-C-08 Medium None Low 8-RHR-ISIM-958-2 RHR-W070BC 4 ISIM-958-2 2 8-RHR-ISIM-958-2 RHR-Wl03, RHR-W104, RHR-W105 02RHR RHR-034 6a Low RHR-C-09A Medium None Low 8-RHR-ISIM-958-2 RHR-W074 1 ISIM-958-2 2 02RHR RHR-035 6a Low RHR-C-09B Medium None Low 8-RHR-ISIM-958-2 RHR-W106 1 ISIM-958-2 2 02RHR RHR-054 6a Low RHR-C-15A2 Medium None Low 10-RHR-ISIM-938-2 RHR-W178, RHR-W179, RHR-W180, RHR- 11 .jI1SIMW938-1 2 W181, RHR-W182, RHR-W183, RHR-W184, ISiM*938.-2-1 RHR-W185 ..

10-RHR-ISIM-938-2 RHR-W188, RHR-W189 10-RHR-ISIM-938-1 RHR-W190 02RHR RHR-055 6a Low RHR-C-15A2 Medium None Low 6-RHR-ISIM-938-2 RHR-W186, RHR-W187 2 ISIM-938-2-1 2 03SI SI-010 6a Low IL-C-04 Medium None Low 2-SI-ISIM-982 SI-W001S 1 ISIM-982 1 03SI SI-011 6a Low IL-C-04 Medium None Low 2-SI-ISIM-982 SI-W002S, SI-W003S, SI-W004S, SI-WO05S, 9 ISIM-982 1 SI-WO06S, Sl-W007S, SI-W008S, SI-W009S, SI-WoloS 03SI SI-014 6a Low IL-C-07 Medium None Low 2-SI-ISIM-936 SI-W077S 1 ISIM-936 1

  • PRA model change in 2008.

General Notes; Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 18 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

System Risk Characterization Consequence IT Failure Potential ILines in Segment Welds Wlsi in Segment emn Weld Sketch No(s). CC Segment. CategorYJ Rank ID Rank DMs J Rank Count S 03SI SI-015 6a Low IL-C-07 Medium None Low 2-SI-ISIM-936 SI-W078S, Sl-W079S, SI-W080S, SI-W081S, 9 ISIM-936 1 Sl-W082S, SI-W083S, SI-W084S, SI-W085S, SI-W086S 03SI SI-026 6a Low IL-C-13 Medium None Low 12-SI-ISIM-935 SI-W113, SI-W1 14, SI-W15, Sl-W116, SI- 6 ISIM-935 1 W117, SI-W118 03SI SI-029 6a Low IL-C-15 Medium None Low 10-SI-ISIM-938-1 Sl-W055, SI-W056, SI-W057, Sl-W058, SI- 9 ISIM-938-1 1 W059, SI-W060, Sl-W061, SI-W062, SI-W063 03SI SI-030 6a Low IL-C-15 Medium None Low 12-SI-ISIM-938-1 SI-W064, Sl-W065, SI-W066, SI-W067, SI- 8 ISIM-938-1 1 W068, Sl-W069, SI-W070, SI-W071 03SI SI-035 6a Low IL-C-18 Medium None Low 2-SI-ISIM-937-2 SI-W091S, SI-W092S, SI-W093S, SI-W094S, 5 ISIM-937-2-1, 1 SI-W095S __ _________-

03SI SI-036 6a Low IL-C-18 Medium None Low 2-S1-ISIM-937-2 Sl-W096S, Sl-W097S, SI-W098S, Sl-W099S, 9 ISIM-937-2' ' 1 SI-Wi OOS, SI-Wi0lS, SI-Wi 02S, SI-Wi 03S ISIM-938-2-11 2-SI-ISIM-938-2 Sl-W104BC1 03SI SI-037 6a Low IL-C-18 Medium None Low 6-SI-ISIM-938-2 Si-W089, SI-W090, SI-W105, Sl-W106 4 ISIM-938S2-1 1 03SI SI-042 6a Low IL-C-21 Medium None Low 2-S1-ISIM-937-1 SI-WO31S 1 ISIM-937-1 1 03SI SI-043 6a Low IL-C-21 Medium None Low 2-S1-ISIM-937-1 SI-W029S, Sl-W030S, Sl-W032S, SI-W033S, 17 ISIM-937-1 1 SI-Wo34s, Sl-W035S, Sl-W036s, SI-W037s, ISIM-939-1 S1-W038S, S1-W039S, Sl-W040S, Sl-WO41S 2-SI-ISIM-939 SI-WO42BC 6-SI-ISIM-939 S1-W043, S1-W044, Sl-W045, S1-W046 03Sl SI-045 6a Low IL-C-21 Medium None Low 6-SI-ISIM-939 Sl-WO13 16 ISIM 939 -1 1 6-S1-ISIM-939 Sl-W014, S1-W015, S1-W016, S1-W017, SI- ISIM-939-21 W018, Sl-W019, Sl-W020, Sl-W021, Sl-W022, Sl-W023, Sl-W024, S1-W025, Sl-W026,.Sl-W027, SI-W028 03SI SI-006 6a Low IL-C-02A Medium None Low 2-SI-ISIM-982 Sl-W455S, SI-W456S 2 ISIM-982 2 03SI SI-007 6a Low IL-C-02A Medium None Low 2-SI-ISIM-982 Sl-W457S, Sl-W458S, Sl-W459S, Sl-W460S, 9 ISIM-982 2 Sl-W461S, SI-W462S, SI-W544S, SI-W545S, SI-W463S 03SI SI-008 6a Low IL-C-02B Medium None Low 2-SI-ISIM-936 SI-W292S, Sl-W293S, Sl-W294S, Sl-W295S, 10 ISIM-936 2 Sl-W296S, SI-W297S, Sl-W298S, SI-W556S, SI-W300S, Sl-W301S 03SI SI-009 6a Low IL-C-03 Medium None Low 2-SI-ISIM-982 SI-W464S, SI-W465S. 2 ISIM-982 2 03SI SI-013 6a Low IL-C-06 Medium None Low 2-SI-ISIM-936 SI-W302S, Sl-W303S 2 ISIM-936 2

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 19 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Weld System Segment Caegor Rank ID Rank DMs j Rank LinesninnSemetWedsntSgmn Count Sketch No(s). CC 03SI SI-021 6a Low IL-C-10A Medium None Low 2-SI-ISIM-937-2 SI-W321S, SI-W553S, SI-W554S, SI-W322S, 16 ISIM-937-2-1, 2 SI-W323S, SI-W324S, SI-W325S, SI-W326S, SI-W327S, SI-W555S, SI-W329S, SI-W331S, SI-W332S, SI-W333S, SI-W334S, SI-W335S .

03SI SI-022 6a Low IL-C-10A Medium None Low 2-SI-ISIM-937-2 SI-W330S 1 ISIM-937-2-2 2 03SI SI-023 6a Low IL-C-10B Medium None Low 2-SI-ISIM-937-1 SI-W352S, SI-W353S, SI-W354S, SI-W547S, 10 ISIM-937-1 2 SI-W548S, SI-W355S, SI-W356S, SI-W549S, SI-W550S, SI-W357S 03SI SI-024 6a Low IL-C-11 Medium None Low 2-SI-ISIM-937-2 SI-W336S, SI-W337S 2 ISIM-937-2-1 2 03SI SI-025 6a Low IL-C-12 Medium None Low 2-SI-ISIM-937-1 SI-W358S, SI-W359S 2 ISIM-937-1 2 03SI SI-034 6a Low IL-C-17 Medium None Low 6-S1-ISIM-938-2 SI-W124, SI-W125, SI-W126, SI-W127 4 ISIM-938-2-1 2 03SI SI-041 6a Low IL-C-20 Medium None Low 6-Sl-ISIM-939 SI-W168, SI-W169 2 :KISIM-939-2, 2 03SI SI-049 6a Low RHR-C-15B2 Medium None Low 6-SI-ISIM-939 SI-W149, SI-W150, SI-W151, SI-W152, SI- 21 ISIM-939-1iý-' 2 W153, Sl-W154, S,-W155, SI-W156, S,-W157, ISIM-939-2, SI-W158, SI-W159, Sl-W160, Sl-W161, Sl-W162, SI-W163, Sl-W164, Sl-W165, SI-W166, SI-W167, S1-W598B3C, Sl-W599S 03SI SI-071 6a Low SI-C-04A Medium None Low 2-SI-ISIM-993 SI-W496S, SI-W497S 2 ISIM-993 2 03SI SI-072 6a Low S-C-04B Medium None Low 2-SI-ISIM-993 Sl-W535S, Sl-W540S 2 ISIM-993 2 03SI SI-079 6a Low SI-C-06 Medium None Low 2-SI-ISIM-993 SI-W518S, S1-W519S 2 ISIM-993 2 04CVC CVC-015 6a Low CVCS-C-11 Medium None Low 2-CVC-ISIM-874-3 CVC-W153S, CVC-W154S 2 ISIM-874-3 1 04CVC CVC-016 6a Low CVCS-C-12 Medium None Low 2-CVC-ISIM-1471 CVC-W0O1S, CVC-W002S 2 ISIM-1471 1 04CVC CVC-017 6a Low CVCS-C-12 Medium None Low 2-CVC-ISIM-1471 CVC-W003S, CVC-W004S, CVC-W005S, CVC- 30 ISIM-1471 1 W006S, CVC-W007S, CVC-WO08S, CVC-W009S, CVC-W010S, CVC-W0 11s, CVC-W0112S, CVC-WO13S, CVC-WO14S, CVC-W015S, CVC-WO16S, CVC-WO17S, CVC-W018S, CVC-WO19S, CVC-W020S, CVC-W021S, CVC-W022S, CVC-W023S, CVC-W024S, CVC-W025S, CVC-W026S, CVC-W027S, CVC-W028S, CVC-W029S, CVC-W030S, CVC-W031S, CVC-W032S 04CVC CVC-018 6a Low CVCS-C-12 Medium None Low 2-CVC-ISIM-1471 CVC-W033S, CVC-W034S, CVC-W035S, CVC- 6 ISIM-1471 1 W036S, CVC-W037S, CVC-W038S 04CVC CVC-020 6a Low CVCS-C-14 Medium None Low 2-CVC-ISIM-1476 CVC-W097S, CVC-W098S, CVC-W099S 3 ISIM-1476 1

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 20 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Weld Segment Category Rank ID [ Rank DMs J S Rank Lines in Segment Welds in Segment Count Sketch No(s). CC 04CVC CVC-021 6a Low CVCS-C-14 Medium None Low 2-CVC-ISIM-1476 CVC-W100S, CVC-W101S, CVC-W102S, CVC. 21 ISlM-1476 1 W103S, CVC-W104S, CVC-W105S, CVC-W106S, CVC-W107S, CVC-W108S, CVC-W1 09S, CVC-W110S, CVC-W111S, CVC-W112S, CVC-W113S, CVC-W1l4S, CVC-W1 15S, CVC-W1 16S, CVC-W117S, CVC-W1 18S, CVC-W119S, CVC-W120S 04CVC CVC-022 6a Low CVCS-C-14 Medium None Low 2-CVC-ISIM-1476 CVC-W121S, CVC-W122S, CVC-W123S, CVC. 12 ISIM-1476 W124S, CVC-W125S, CVC-W126S, CVC-W127S, CVC-W128S, CVC-W129S, CVC-W130S, CVC-W131S, CVC-W132S 05MS MS-001 6a Low MS-C-01A Medium None Low 30-MS-ISIM-871 MS-W118, MS-W002, MS-W003, MS-W004, 12 ISIM-871 2 MS-W120, MS-W005, MS-WO0S, MS-W100, ,sISM-984-2-*

MS-W007, MS-W008 31-MS-ISIM-984-2 MS-W009, MS-W010 05MS MS-002 6a Low MS-C-01B Medium None Low 30-MS-ISIM-872 MS-W119, MS-W050, MS-W051, MS-WO52, 13 !SIM-872 2 MS-W121, MS-W053, MS-W054, MS-W054A, TISIM-`985-l1-MS-W055, MS-W056 31-MS-ISIM-985-1 MS-W057, MS-W058, MS-W059 05MS MS-003 6a Low MS-C-02A Medium None Low 31-MS-ISIM-984-2 MS-Wi0A, MS-W047P 2 .tSIM-984-2-1 2 05MS MS-004 6a Low MS-C-02B Medium None Low 31-MS-ISIM-985-1 MS-W059A, MS-W094P 2 ASIM7985-1-1' 2 05MS MS-005 6a Low MS-C-03A Medium None Low 31-MS-ISIM-984-2 MS-WO11, MS-W012 4 -ISIM-'984-2-1 2 30-MS-ISIM-984-2 MS-WO14, MS-W016 05MS MS-006 6a Low MS-C-O3A Medium None Low 24-MS-ISIM-984-2 MS-W097, MS-W096 5 ISIM-9842-1 2 24-MS-ISIM-984-2 MS-W015, MS-W013, MS-W018 05MS MS-007 6a Low MS-C-03B Medium None Low 31-MS-ISIM-985-1 MS-W060, MS-W061 2 ISIM-985-1-1 2 05MS MS-008 6a Low MS-C-03B Medium None Low 24-MS-ISIM-985-1 MS-W067, MS-W062, MS-W063, MS-W064, 5- ISIM-985-1-1 2 MS-W065 05MS MS-009 6a Low MS-C-04A Medium None Low 6-MS-ISIM-984-2 MS-W031BC 5 :S MH9 2 8-MS-ISIM-969 MS-W020, MS-W021, MS-W022 ISIM-984-2-3 6-MS-ISIM-969 MS-W023 05MS MS-010 6a Low MS-C-04B Medium None Low 6-MS-ISIM-985-1 MS-W078BC 6 ISIM968 2 8-MS-ISIM-968 MS-W079, MS-W080, MS-W081, MS-W082 IS1M-985-l-3):

6-MS-ISIM-968 MS-WO83 05MS MS-011 6a Low MS-C-05A1 Medium None Low 6-MS-ISIM-984-2 MS-W029BC 2 ISIM-984-2-1 2 6-MS-ISIM-984-2 MS-W024 05MS MS-012 6a Low MS-C-05A2 Medium None Low 6-MS-ISIM-984-2 MS-W027BC 2 ISIM-984-2-1 2 6-MS-ISIM-984-2 MS-W026 IIM-984-2-3 O5MS MS-013 6a Low MS-C-05A3 Medium None Low 6-MS-ISIM-984-2 MS-W025BC 2 I:SIM-984-2-1 2

________ I I I

_6-MS-ISIM-984-2 U MS-W028 .ISIM-984-2-3

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 21 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Weld System Lines in Segment Welds in Segment Sketch No(s). CC Segment Category Rank ID J Rank DMs Rank Count 05MS MS-014 6a Low MS-C-05A4 Medium None Low 6-MS-ISIM-984-2 MS-WO23BC 2 ISIM-984-2-l' 2 6-MS-ISIM-984-2 MS-W030 ISIM-984-2-3 05MS MS-015 6a Low MS-C-05A5 Medium None Low 6-MS-ISIM-984-2 MS-WO19BC 2 ISIM-984-2-1 2 6-MS-ISIM-984-2 MS-W032 ISIM-984-2-3 05MS MS-016 6a Low MS-C-05B1 Medium None Low 6-MS-ISIM-985-1 MS-W076BC 2 ISIM-985-1-1 2 6-MS-ISIM-985-1 MS-W077 ___ .ISIM-985-1-3 05MS MS-017 6a Low MS-C-05B2 Medium None Low 6-MS-ISIM-985-1 MS-W074BC 2 ISIM-985-1-1 2 6-MS-ISIM-985-1 MS-W075 _ _ lISM-985-1-3, 05MS MS-018 6a Low MS-C-05B3 Medium None Low 6-MS-ISIM-985-1 MS-W072BC 2 ISIM-985-1-1 2 6-MS-ISIM-985-1 MS-W073 ISIM-985-1-3 05MS MS-019 6a Low MS-C-05B4 Medium None Low 6-MS-ISIM-985-1 MS-W070BC 2 ISlM-985-1-1 2 6-MS-ISIM-985-1 MS-W071 ISlIM-985-1-3:

05MS MS-020 6a Low MS-C-05B5 Medium None Low 6-MS-ISIM-985-1 MS-W068BC 2 ISIM-985-1-1 2 6-MS-ISIM-985-1 MS-W069 ISiM-985-1-3 06FW FW-008 6a (3) Low FW-C-03A Medium None (FAC) Low 16-FW-ISIM-991-1 FW-WO11 2 ISIM-970 2 (High) (High) 16-FW-ISIM-970 FW-W012 _ _ ISIM-991-1-1 06FW FW-003 6a Low FW-C-01A Medium None Low 16-FW-ISIM-991-1 FW-W006 1 lISIM-991-1-1. 2 06FW FW-004 6a Low FW-C-01B Medium None Low 16-FW-ISIM-972-1 FW-W032, FW-W033, FW-W034, FW-W035 4 'ISIM-972-1-1 2 06FW FW-005 6a Low FW-C-02A Medium None Low 16-FW-ISIM-991-1 FW-WO07P, FW-WO08P 2 ISIM-991-1-1 2 06FW FW-006 6a Low FW-C-02B Medium None Low 16-FW-ISIM-972-1 FW-W036, FW-W039P 2 7ISIM-972-1-1, 2 06FW FW-007 6a Low FW-C-03A Medium None Low 16-FW-ISIM-991-1 FW-WO10 1 lIS.IMi991-1-1 2 06FW FW-009 6a Low FW-C-03A Medium None Low 16-FW-ISIM-970 FW-W013, FW-W014, FW-W015, FW-W016, 11 ISIM-970 2 FW-WO17, FW-WO18, FW-WO19, FW-W020, FW-W021, FW-W022, FW-W023 06FW FW-010 6a Low FW-C-03B Medium None Low 16-FW-ISIM-972-1 FW-W040, FW-W041 12 1SIM-97.1 2 16-FW-ISIM-971 FW-W042, FW-W043, FW-W044, FW-W045, *J ISIM-972-1-1 FW-W046, FW-W047, FW-W048, FW-W049, 01 IC03 a

__CS-C-05A1___Medium_ L None____ Low _6-_CS-llM-951 _ICFW-W050, FW-W518 071CS ICS-013 6a Low ICS-C-05A1 Medium None Low 6-ICS-ISIM-951 ICS-W037, ICS-W180 2 ISIM-951 2 071CS ICS-014 6a Low ICS-C-05A2 Medium None Low 6-ICS-ISIM-951 ICS-W040, ICS-W041, ICS-W042, 5 ISIM-951 2 ICS-W181, ICS-W182 071CS ICS-015 6a Low ICS-C-05B1 Medium None Low 6-ICS-ISIM-953 ICS-W122, ICS-W123 2 ISIM-953 2 071CS ICS-016 6a Low ICS-C-05B2 Medium None Low 6-ICS-ISIM-953 ICS-W124, ICS-W125, ICS-W126, ICS-W127 4 ISIM-953 2 071CS ICS-O7 6a Low ICS-C-06A Medium None Low 6-1CS-lSlM-951 ICS-W043, ICS-W044 2 ISlM-951 2 071CS ICS-018 6a Low ICS-C-06B Medium None Low 6-ICS-ISIM-953 ICS-W128, ICS-W129 2 ISIM-953 2 08AF AF-006 6a Low AFW-C-01A4 Medium None Low 3-AF-ISIM-877-2 AFW-WO55, AFW-W056 2 ISIM-877-2 2

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 22 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

Risk Characterization Consequence Failure Potential Weld System n i Segment Wedsin Segment Segment Category Rank ID Rank DMs Rank Count Sketch No(s). CC C

08AF AF-011 6a Low AFW-C-02A Medium None Low 3-AF-ISIM-877-2 AFW-W057 2 ISIM-877-2 2 4-AF-ISIM-877-2 AFW-W058 08AF AF-012 6a Low AFW-C-02B Medium None Low 3-AF-ISIM-891-1 AFW-W122 2 ISIM-891-1 2 4-AF-ISIM-891-1 AFW-W123 08AF AF-013 6a Low AFW-C-03A Medium None Low 4-AF-ISIM-865 AFW-W059 21 ISIM-865 2 3-AF-ISIM-865 AFW-W060, AFW-W061, AFW-W062, AFW-W063, AFW-W064, AFW-W065, AFW-W066, AFW-W067, AFW-W068, AFW-W069, AFW-W070, AFW-W071, AFW-W072, AFW-W073, AFW-W074, AFW-W075, AFW-W076, AFW-W077, AFW-W146, AFW-W078 08AF AF-014 6a Low AFW-C-03B Medium None Low 4-AF-ISIM-866 AFW-W124 18 ISIM-866 2 3-AF-ISIM-866 AFW-W125, AFW-W126, AFW-W127, AFW-W1 28, AFW-W1 29, AFW-W1 30, AFW-Wi 31, AFW-W132, AFW-W133, AFW-W134, AFW-W1 35, AFW-W1 36, AFW-W1 37, AFW-Wi 38, AFW-W139, AFW-W140, AFW-W141 02RHR RHR-063 6b Low RHR-C-18 Low TASCS Medium 8-RHR-ISIM-961-1 RHR-W226, RHR-W227 2 ISIM-961-1 2 02RHR RHR-058 7a Low RHR-C-16 Low None Low 8-RHR-ISIM-960-1 RHR-W231, RHR-W232, RHR-W233, RHR- 8 ISIM-960-1 2 W234, RHR-W235, RHR-W236, RHR-W237 8-RHR-ISIM-960-1 RHR-W239 02RHR RHR-059 7a Low RHR-C-16 Low None Low 6-RHR-ISIM-960-1 RHR-W238BC 1 ISIM-960-1 2 02RHR RHR-060 7a Low RHR-C-17 Low None Low 6-RHR-ISIM-961-1 RHR-W241, RHR-W242, RHR-W243, RHR- 6 ISIM-961-1 2 W244, RHR-W245, RHR-W246 02RHR RHR-061 7a Low RHR-C-18 Low None Low 6-RHR-ISIM-961-1 RHR-W247, RHR-W248, RHR-W249 3 ISIM-961-1 2 02RHR RHR-062 7a Low RHR-C-18 Low None Low 6-RHR-ISIM-961-1 RHR-W250, RHR-W251, RHR-W252 3 ISIM-961-1 2 04CVC CVC-007 7a Low CVCS-C-06 Low None Low 2-CVC-ISIM-1474 LD-W013S, LD-WO14S 2 ISIM-1474 1 04CVC CVC-008 7a Low CVCS-C-07 Low None Low 2-CVC-ISIM-1474 WD-WO19S, WD-W20S 2 ISIM-1474 1 04CVC CVC-013 7a Low CVCS-C-10 Low None Low 2-CVC-ISIM-1369-2 WD-W012S, WD-WO03S, WD-WO14S 3 ISIM-1369-2 1 04CVC CVC-014 7a Low CVCS-C-10 Low None Low 2-CVC-ISIM-1369-2 WD-W015S, WD-WO16S 2 ISIM-1369-2 1 071CS ICS-019 7a Low ICS-C-07A Low None Low 6-ICS-ISIM-952 ICS-W141, ICS-W142, ICS-W143, ICS-W144, 7 ISIM-952 2 I _ICS-W145, ICS-W146, ICS-W147 ICS-020 I71CS 7a Low ICS-C-07B Low None Low 6-ICS-ISIM-954 ICS-W148, ICS-W149, ICS-W150, ICS-W151, 10 ISIM-954 2 ICS-Wi52, ICS-W153, ICS-W154, ICS-W155, I___ __ICS-W156, ICS-W157 I I

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 23 Exam not req'd until 5th Interval.

(Original Risk Ranking in Kewaunee Risk Ranking Report KNPP-03-403, Rev. 0 SI File No. NMC-01-342)

  • PRA model change in 2008.

General Notes: Plant mods 2009, 2011.

1. Dissimilar metal weld numbers contain "DM." Weld added mid- or near end of 4th Interval.
2. Welds selected for examination underlined. 24 Exam not req'd until 5th Interval.

Kewaunee Risk Ranking Summary Risk Failure Potential Weld No. of R Co CC Elements CSystem R Consequence Rank Ca 2 Hig Hihk DIs TTnMediut Selected*

01RC 2 High High TASCSTT Medium 5 1 01RC 2 High High TASCS Medium 7 1 01 RC 2 High High TT Medium 10 1 02RHR 2 High High TASCS Medium 14 1 4 03SI 2 High High TT Medium 2 1 03SI 2 HihHgMd3 03SI 2 High High PWSCC Medium 2 1 04CVC 2 High High TASCS Medium 2 1 04CVC 2 High High TT Medium 33 1 01RC 4 Medium High None Low 248 1 25 02RHR 4 Medium High None Low 9 1 02RHR 4 Medium High None Low 231 2 03SI 4 Medium High None Low 12 1 03SI 4 Medium High None Low 335 2 04CVC 4 Medium High None Low 88 1 9 071CS 4 Medium High None Low 92 2 8 08AF 4 Medium High None Low 144 2 7 03SI 5a Medium Medium TT, IGSCC Medium 5 1 Medium Medium IGSCC Medium 5 1 03SI 5a 04CVC 5a Medium Medium TT Medium 5 1 1 06FW 5a Medium Medium TASCS Medium 16 2 2 08AF 5a Medium Medium TASCS, TT Medium 6 2 1 02RHR 6a Low Medium None Low 29 1 6a Low Medium None Low 59 2 02RHR 03SI 6a Low Medium None Low 95 1 Low Medium None Low 89 2 03SI 6a O4CVC 6a Low Medium None Low 76 1 0 05MS 6a Low Medium None Low 76 2 0 06FW 6a (3) Low (High) Medium None (FAC) Low (High) 2 2 0 06FW 6a Low Medium None Low 33 2 0 071CS 6a Low Medium None Low 17 2 0 08AF 6a Low Medium None Low 45 2 0 02RHR 6b Low Low TASCS Medium 2 2 0 02RHR 7a Low Low None Low 21 2 0 04CVC 7a Low Low None Low 9 1 0 071CS 7a Low Low None Low 17 2 0

  • Does not include elements added during the 4th Interval where examination is not required until the 5th Interval TOTAL: 1841 KNPP-03-403, Rev. 0

4LE

- Low ME~ N IS K O1RC - 0 01RC - 0 02RHR -0 02RHR -0

.03SI -0 03SI -0 04CVC- 0 04CVC - 0 05MS..- 0 05MS - 0 06FW - 0 06FW -0 071CS - 0 071CS - 0a 08AF - 0 O8AF - 0 Total - 0 Elements Total - 0 Elements

%IILCUUIy uu - mUw nQIMP. Category 2 - High Risk -

01RC -0 01RC -22 02RHR - 2 02RHR -14 03SI - 0 03SI -4 04CVC - 0 04CVC - 35 05MS - 0 05MS - 0 06FW - 0 06FW- 0 071CS - 0 071CS - 0 08AF - 0 08AF -0 Total - 2 Elements Total '

4 Category 7a - Low Risk L.ufLgury *d - LUW nleiI 01RC -0 O1RC - 0 02RHR - 21 02RHR - 88 03SI - 0 03SI - 184 04CVC - 9 04CVC - 76 05MS - 0 05MS - 76 06FW - 0 06FW - 35 071CS - 17 071CS - 17 08AF - 0 08AF - 45 Total - 47 Elements Total - 521 Elements KNPP-03-403, Rev. 0

Serial No.12-247 ENCLOSURE 2 TO ATTACHMENT 1 PERFORMANCE DEMONSTRATION INITIATIVE (PDI) INQUIRY 2008-02 (2 pages)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. RR-G-5 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM (JUNE 16, 2004- JUNE 16, 2014) 1ST PERIOD AND 2ND PERIOD KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

PERFORMANCE DEMONSTRATION INITIATIVE PDI INQUIRY - 2008-02 Approved: 3-26-2009 Inquiry No.: 2008-02 Name / Company: Phil Bukes / Dominion Procedure & Section: Supplement 2 and 3 piping generic procedures, scope section.

Background:

Dominion requested clarification on whether PDI generic piping procedures were intended to be acceptable for ultrasonic examination of piping branch connection welds.

Inquiry:

Can PDI generic piping procedures be used to examine branch connection welds?

Response

Yes, a branch connection weld can be examined in accordance with the PDI qualified generic piping procedures as long as the configuration and material product form allow examination using the normal techniques described within the qualified procedure. For a wrought austenitic branch connection weld, the examination must be performed with a half-vee path technique, using procedurally qualified search units, and the exam coverage in most cases will be limited to single-side only. For a ferritic branch connection weld, the examination may employ the half-vee or full-vee path techniques, using qualified search units, to obtain examination coverage. However, bouncing a sound beam around a comer, in order to examine a weld on a different geometrical plane from the search unit, is not within the scope of the generic procedures. (Refer to Figure 1 and Figure2 for examples)

Page 1 of 2

PERFORMANCE DEMONSTRATION INITIATIVE PDI INQUIRY - 2008-02 Approved: 3-26-2009 Examination can be performed from this side of the weld using the PDI generic piping procedures. If the material is austenitic, only single side exam

- volume coverage would be achievable.

An examination of the same weld, launched from this plane would not be within the scope of the PDI generic piping procedures.

Figure 1: Similar to IWB-2500-9 and 11 For this example, examinations of the subject weld from this plane would not be within the scope of the PDI generic piping procedures Limited examination coverage may be achievable from this scanning surface.

/

  • A mockup may be used to qualify additional examination coverage from this tapered surface Figure 2: Similar to IWB-2500-10 Page 2 of 2
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