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| number = ML12081A119
| number = ML12081A119
| issue date = 03/16/2012
| issue date = 03/16/2012
| title = R.E. Ginna, Additional Information Regarding Fourth Interval Inservice Inspection Program Relief Requests Nos. ISI-02 and ISI-03
| title = Additional Information Regarding Fourth Interval Inservice Inspection Program Relief Requests Nos. ISI-02 and ISI-03
| author name = Mogren T
| author name = Mogren T
| author affiliation = Constellation Energy Nuclear Group, LLC, R. E. Ginna Nuclear Power Plant, LLC
| author affiliation = Constellation Energy Nuclear Group, LLC, R. E. Ginna Nuclear Power Plant, LLC
Line 14: Line 14:
| page count = 80
| page count = 80
| project = TAC:ME5248, TAC:ME5249
| project = TAC:ME5248, TAC:ME5249
| stage = Other
| stage = Request
}}
}}


=Text=
=Text=
{{#Wiki_filter:Thomas G. MogrenManager -Engineering ServicesCENGa joint venture ofConlltBeationEnergy 6%DR.E. Ginna Nuclear Power Plant, LLC1503 Lake RoadOntario, New York 14519-9364585.771.5208585.771.3392 FaxMarch 16,
{{#Wiki_filter:Thomas G. Mogren                                                      R.E. Ginna Nuclear Power Plant, LLC Manager - Engineering Services                                        1503 Lake Road Ontario, New York 14519-9364 585.771.5208 585.771.3392 Fax Thomas.Moqren*,cenqllc.com CENG a joint venture of ConlltBeation Energy          6%D March 16, 2012 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:          Document Control Desk
 
==SUBJECT:==
R.E. Ginna Nuclear Power Plant Docket No. 50-244 Additional Information Re: Fourth Interval Inservice Inspection Program Relief Requests Nos. ISI-02 and ISI-03
 
==References:==
(1) Letter from D. V. Pickett, NRC, to J. T. Carlin, Ginna LLC, dated April 13, 2011,
 
==Subject:==
R.E. Ginna Nuclear Power Plant -Request For Additional Information Re: Fourth Interval Inservice Inspection Program Relief Requests Nos. ISI-02 and ISI-03 (TAC NOS. ME5248 and ME5249).
(Agencywide Documents Access and Management System (ADAMS)
Accession No. ML110880297)
(2) Letter from T. Mogren, Ginna LLC, to NRC Document Control Desk, dated July 29, 2011,
 
==Subject:==
Response to Request for Additional Information Re: Fourth Interval Inservice Inspection Program Relief Requests Nos. ISI-02 and ISI-03 (ADAMS Accession No. ML11215A012)
In Reference 1, The Nuclear Regulatory Commission requested additional information regarding the R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) requested relief from impractical examination coverage requirements. The NRC staff reviewed the response provided in Reference 2 and during subsequent conversations requested additional information to complete the review of Relief Request ISI-02 and ISI-03. The NRC questions and the corresponding Ginna LLC responses are provided in the Enclosure 1. A list of regulatory commitments associated with this response is provided in Enclosure 2.
Should you have questions regarding this matter, please contact Thomas Harding (585) 771-5219, or Thomas. hardinairacengllc.com.
Very truly yours, Thomas Mogrenf
                                                                                                          ý041 WPLN JC- J33cN60 /
 
Document Control Desk March 16, 2012 Page 2
 
==Enclosures:==
 
(1) Additional Information Regarding Relief Request ISI-02 and 03 (2) List of Regulatory Commitments cc:    W. M. Dean, NRC D. V. Pickett, NRC Resident Inspector, NRC (Ginna LLC)
 
ENCLOSURE 1 Additional Information Regarding Relief Request ISI-02 and ISI-03
 
Relief Request ISI-02 and ISI-03 for Ginna Unit 1                                  Page 1 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided by R.E.
Ginna Nuclear Power Plant, LLC for R.E. Ginna Nuclear Power Plant (Ginna), in its letters dated December 16, 2010, and July 29, 2011 and has determined that additional information is necessary to complete the review of Relief Requests ISI-02 and ISI-03.
GINNA RELIEF REQUEST ISI-02 (Class 1 Welds)
Code Categorv B-F, Welds NSE-3R and NSE-4R (Dissimilar Metal Welds)
* The coverage calculations for Welds NSE-3R and NSE-4R are still not clear.
o  The black & white figures included in the request for additionalinformation (RAI) response show more modes/angles than the color figures that were provided to the project manager (PM) as a supplement to the RAI response. Please provide revised figures that correctly show all of the wave modalities and angles used for these exams.
 
===Response===
See the following revised vendor figures that depict all of the wave modalities and angles used for these Dissimilar Metal (DM) weld examinations.
 
Relief Request ISI-02 and ISI-03 for Ginna Unit 1                              Page 2 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Generic Coverage Illustration of NSE-3-R and NSE-4-R Generic Coverage Illustration of NSE-3-R and NSE-4-R 450 Axial Shear Wave Examination
 
Relief Request ISI-02 and ISI-03 for Ginna Unit 1                                  Page 3 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item

Latest revision as of 18:11, 6 February 2020

Additional Information Regarding Fourth Interval Inservice Inspection Program Relief Requests Nos. ISI-02 and ISI-03
ML12081A119
Person / Time
Site: Ginna Constellation icon.png
Issue date: 03/16/2012
From: Mogren T
Constellation Energy Nuclear Group, Ginna
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME5248, TAC ME5249
Download: ML12081A119 (80)


Text

Thomas G. Mogren R.E. Ginna Nuclear Power Plant, LLC Manager - Engineering Services 1503 Lake Road Ontario, New York 14519-9364 585.771.5208 585.771.3392 Fax Thomas.Moqren*,cenqllc.com CENG a joint venture of ConlltBeation Energy 6%D March 16, 2012 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Docket No. 50-244 Additional Information Re: Fourth Interval Inservice Inspection Program Relief Requests Nos. ISI-02 and ISI-03

References:

(1) Letter from D. V. Pickett, NRC, to J. T. Carlin, Ginna LLC, dated April 13, 2011,

Subject:

R.E. Ginna Nuclear Power Plant -Request For Additional Information Re: Fourth Interval Inservice Inspection Program Relief Requests Nos. ISI-02 and ISI-03 (TAC NOS. ME5248 and ME5249).

(Agencywide Documents Access and Management System (ADAMS)

Accession No. ML110880297)

(2) Letter from T. Mogren, Ginna LLC, to NRC Document Control Desk, dated July 29, 2011,

Subject:

Response to Request for Additional Information Re: Fourth Interval Inservice Inspection Program Relief Requests Nos. ISI-02 and ISI-03 (ADAMS Accession No. ML11215A012)

In Reference 1, The Nuclear Regulatory Commission requested additional information regarding the R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) requested relief from impractical examination coverage requirements. The NRC staff reviewed the response provided in Reference 2 and during subsequent conversations requested additional information to complete the review of Relief Request ISI-02 and ISI-03. The NRC questions and the corresponding Ginna LLC responses are provided in the Enclosure 1. A list of regulatory commitments associated with this response is provided in Enclosure 2.

Should you have questions regarding this matter, please contact Thomas Harding (585) 771-5219, or Thomas. hardinairacengllc.com.

Very truly yours, Thomas Mogrenf

ý041 WPLN JC- J33cN60 /

Document Control Desk March 16, 2012 Page 2

Enclosures:

(1) Additional Information Regarding Relief Request ISI-02 and 03 (2) List of Regulatory Commitments cc: W. M. Dean, NRC D. V. Pickett, NRC Resident Inspector, NRC (Ginna LLC)

ENCLOSURE 1 Additional Information Regarding Relief Request ISI-02 and ISI-03

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 1 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided by R.E.

Ginna Nuclear Power Plant, LLC for R.E. Ginna Nuclear Power Plant (Ginna), in its letters dated December 16, 2010, and July 29, 2011 and has determined that additional information is necessary to complete the review of Relief Requests ISI-02 and ISI-03.

GINNA RELIEF REQUEST ISI-02 (Class 1 Welds)

Code Categorv B-F, Welds NSE-3R and NSE-4R (Dissimilar Metal Welds)

  • The coverage calculations for Welds NSE-3R and NSE-4R are still not clear.

o The black & white figures included in the request for additionalinformation (RAI) response show more modes/angles than the color figures that were provided to the project manager (PM) as a supplement to the RAI response. Please provide revised figures that correctly show all of the wave modalities and angles used for these exams.

Response

See the following revised vendor figures that depict all of the wave modalities and angles used for these Dissimilar Metal (DM) weld examinations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 2 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Generic Coverage Illustration of NSE-3-R and NSE-4-R Generic Coverage Illustration of NSE-3-R and NSE-4-R 450 Axial Shear Wave Examination

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 3 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Generic Coverage Illustration of NSE-3-R and NSE-4-R o The Code coverage claimed in RAI response, Attachment 1, is based on the 45RL, 60RL and the circ scans and is 40.5% for NSE-3R and 42% for NSE-4R. In the discussion on page 14 of 20 of the RAI response, it states that reductions in claimed coverage were taken due to the surface condition of the components and inability to maintain contact during the exam. The percent reductions taken seem to be very arbitrary. How were they determined?

Response

The reductions in coverage related to surface conditions which reduced the transducer's contact efficiency were conservatively estimated based on the qualified examiner's observations during the execution of the examinations. These qualitative estimations were only made during the circumferential examinations while the transducer was on the as-ground weld surface. These coverage limitations were determined by observing the ultrasonic signals present during the examination. Areas producing ultrasonic signals indicative of inadequate contact were considered coverage limitations. The qualified examination procedure (PDI-UT-10, paragraph 5.3.3) requires that areas where inadequate ultrasonic contact is encountered shall be documented as a limitation.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 4 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 o Is the process used to determine the reduction documented in the vendor's ultrasonic test (UT) procedure? If so, please provide or describe.

Response

Yes, the process is in the UT procedure. Section 5 of the qualified procedure (PDI-UT-10) defines the examination volume requirements including surface condition requirements and documenting examination limitations that impact full ultrasonic interrogation of the required inspection volume. Additionally, Figure 5 of the same procedure provides an examination flow chart which includes steps for evaluating the examination area and documenting limitations.

o Performance demonstrationinitiative (PDI) PDI-UT-10 requires the surface condition to be eithermachined or ground smooth to an RMS finish approximately 250 RMS. Why wasn't the surface condition correctedprior to the examination?

Response

This requirement was met. Two qualified DM examiners performed an inspection of the surface using a "surface finish comparator". Some manual surface conditioning was performed. Following the manual surface conditioning, the two qualified examiners determined that the RMS finish was approximately 250 RMS. Therefore, this requirement was met.

During the execution of the examination, the qualified inspector observed areas where ultrasonic contact was determined to be inadequate and these areas were considered as examination volume limitations. This condition only occurred scanning circumferentially on the weld surface.

o Please clarify that the coverage calculationsshown in Attachment I of the RAI response comply with the following:

10 CFR 50.55a limitation on counting coverage... "Where full coverage credit from a single side may be claimed only after completing a successful single-sidedAppendix VIII demonstration using flaws on the opposite side of the weld."

Response

The condition in 10CFR50.55a was met. The techniques applied to the dissimilar metal weld were qualified in accordance with the PDI's implementation of ASME B&PVC Section Xl, Appendix VIII as well as demonstrated on a site-specific mockup representing the subject weld joint configuration using flaws on the opposite side of the weld. No single-sided coverage was claimed on the similar metal welds.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 5 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244

Reference:

"EPRI - Technical Justification for the Acceptance of Ultrasonic Examination Demonstration Results on Ginna Steam Generator Nozzle Dissimilar Metal Weld Configurations with PDI-UT-10, Revision C" Document IR-2009-381 PDI-UT-1O requirement that two angles be used to examine dissimilarmetal (DM) welds as well as the use of both shearand longitudinal wave modes.

Response

The calculated coverage in Attachment 1 of the RAI response is that percentage of the volume covered by two angles and both wave modes.

PDI-UT-1O is applicable to components with tapers and geometries representedin the PDI DM program sample inventory. Field installed components that are not representedby the PDI configurationsrequire additionalqualificationdemonstration activities utilizing a site-specific mockup. Did the PDI DM program sample inventory contain a qualification mockup that adequately representedthe configuration of these welds?

Response

No, The PDI DM weld program sample inventory did not adequately represent the S/G replacement weld configurations at Ginna. The site contacted other plants during this timeframe (2008) and determined of the nine existing S/G DM site-specific mockups (SSM) in the industry, none matched Ginna's particular configuration. Once this was confirmed, the site began the design and fabrication phase of Ginna's SSM.

" If not, were additional activities conducted on the site-specific mockup to qualify the procedure for this particularconfiguration?

Response

Yes. The intent throughout the project and during the preparation of the required DM SSM was that the existing S/G DM welds were to be examined only after the surface conditioning process was completed. In fact, vendors were on-site during the 2009 refueling outage to mock-up and perform the surface conditioning.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 6 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 The site confirmed during the 2009 refueling outage that these existing DM welds had some original fit-up and off-set joint issues along with the design-machined outer diameter contour as shown on the next figure. Also, the thickness of these components was determined to be at or very close to the design wall thickness. There was no safety margin to reduce any weld crown by surface conditioning to comply with the PDI-UT-10 requirements of being flush and smooth. The engineering conclusion was that any weld crown reduction and surface conditioning would be detrimental to nuclear safety because there was a high likelihood that design wall thicknesses would be violated.

The drawing on the following page shows the cross-section of the site's S/G complex dissimilar-metal weld and similar-metal weld configuration including the design-machined contour and existing off-sets and misalignments.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 7 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 11S]l.IN UZZIu ELo tO t1imOv

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, - SECNut 1i RESPIPE T0 IL.B tI1) VIghISLTi IN-' I"mIr*I This figure was excerpted from site's S/G fabrication site drawing.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 8 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 S/G Welds - (NSE-4-R & PL-FW-X-R) and (NSE-3-R & PL-FW-III-R) outer surface contours - Field Profile Conditions. (Although much of the ensuing discussion focuses on the DM weld, all parts related to contouring and the Condition Report also pertain to the similar-metal narrow groove weld.)

The following four pages identify the field profile conditions of the S/G inlet and outlet weld configurations. It was determined that as much as a 1/4" of material (including butter, DM weld, safe-end, and narrow groove weld) would be required to be removed to meet the PDI procedural (flush) requirements. It should be noted that this complex configuration is all contained within approximately 6 inches.

An additional limitation factor that impacted the scanning during these existing weld examinations was the size of the footprint of the demonstrated and qualified contoured transducers. These square transducer housings measure 2-3/8" by 2-3/8".

During the 2009 Refueling Outage (RFO), the site engineering department's conclusions were that there was insufficient margin for any metal reduction on these S/G DM weld configurations. The site generated Condition Report CR-2009-007117 to capture the following four welds: Steam Generator Inlet and Outlet Nozzle DM welds and the adjacent stainless steel narrow groove tie-in welds. This Condition Report was categorized as significance level 2 which required an Apparent Cause Evaluation (ACE).

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 9 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 2008cO C# 4w

  • cgs w9"b itw~s MO~UP Moo FiELO CAMb 00' V S" Vi c~e*
  • LD rwAsffa 135a Iu 'aWi "-Bn* . -

,~" /e~I 0 5/0 0 The above weld profiles capture the existing weld cap that contains NSE-4-R and PL-FW-X-R

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 10 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244

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/w'ýOz The above weld profiles capture the existing weld cap that contains NSE-4-R and PL-FW-X-R

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 11 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 wc-os-*-

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'390 P~"L /o~'2 The above weld profiles capture the existing weld cap that contains NSE-3-R and PL-FW-I11-R

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 12 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 C$$~4 N~z~tC. 4:"

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. ,4MIMt 4/1,610 The above weld profiles capture the existing weld cap that contains NSE-3-R and PL-FW-111-R

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 13 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Additionally, PDI-UT-10 requires certain inner diameter (ID) impingement angles for initial flaw detection. As such, do the angles used in these examinations meet the PDI-UT-10 requirements?

Response

Yes. These angles were demonstrated and were successful in detecting all flaws in the DM site-specific mockup performed at the EPRI NDE Center.

Reference:

"EPRI - Technical Justification for the Acceptance of Ultrasonic Examination Demonstration Results on Ginna Steam Generator Nozzle Dissimilar Metal Weld Configurations with PDI-UT-10), Revision C" Document IR-2009-381

" On page 4 of 20 of the RAI response, it says that "the site compared conventional manual UT to phased arraytechniques during 2008 and 2009. The site elected to go with the qualified conventional UT examinations. This decision was made priorto the fabricationof a site-specific mockup for the requiredtechnicaljustification andperformance demonstration." Once the site-specific mockup was built, was an examination with qualified conventional UT method attempted?

Response

Yes, the examination was with qualified conventional UT.

" If so, it appearsthat it would have been clear that conventional manual UT applied to this configuration would encounter significant limitations due to geometry and materials. As such, why wasn't phased array (PA) UT evaluated?

Response

The EPRI NDE PDA personnel communicated to the site that both ultrasonic techniques were qualified at the time; and could be applied to these welds. Fleet and site experience with UT phased array technology was insufficient to provide confidence in the technique at that time (2008). The site's decision was to proceed with the conventional UT on these DM welds. The site-specific mockup technical justification was based only on conventional UT and not using the Phased Array UT technique. Based on existing DM weld limitations, the phased array transducer(s) would have similar scan limitations.

  • Is there anything else that could have been done to expand Code-coverage?

Response

No. With these existing DM weld configurations, the site's position is that the 4 th Interval ISI Program examinations were performed fully to the extent possible taking into account all noted limitations. The limited examination scanning did cover the wetted ID surface of the dissimilar

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 14 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 metal interface and the limited examinations results was no recordable indications noted. These DM welds are constructed with Alloy 52/152 filler metal that is resistant to Primary Water Stress Corrosion Cracking (PWSCC).

The site considered a re-design of the outside diameter (OD) contours by adding weld build-up to meet PDI-UT-1 0 procedural requirements. The weld crown reduction process was estimated to accrue 8 Rem of cumulative dose (200 man-hours in a 40 mRem/hr field). The weld build-up process was estimated to accrue at least as much cumulative dose as the weld crown reduction process. The weld overlay process also had the potential to invalidate current design basis analysis used at Ginna such as leak before break (LBB) as discussed in NRC Regulatory Issue Summary 2010-07. Based on dose and design analysis considerations, this option was not pursued.

Also, once it was determined that the DM weld could not be ground flush per the PDI-UT-1O requirements, why wasn't an alternate exam proposed or hardship requested via reliefrequest?

[(a)(3)(i) or (a)(3)(ii)]

Response

The ISI DM weld examinations were determined to have limitations as stated above; therefore, the limited examinations were submitted in the original Relief Request. The site did not propose the use of an alternate exam such as radiography (RT), since the RT examination results would provide limited flaw information as compared to PDI-UT examination. Site and corporate engineering did not believe that a hardship relief request was applicable regarding the limitation experienced with the DM weld exam.

" Was the generic issue entered into the corrective action program? What were the corrective actions?

Response

Yes. The site did generate a Condition Report in its corrective action program (CAP). CR-2009-007117 was categorized as a significance level 2 condition requiring an Apparent Cause Evaluation (ACE). The ACE contained the following corrective and preventive actions:

" Provide complex weld ISI inspection schedule (5 th ISI Interval) to the site Level III NDE Specialist;

" Qualify the similar metal weld inspections to optimal code coverage;

" Develop a template for planning for complex welds;

" Submit Relief Request to the NRC.

Relief Request ISI-02 and ISI-03 for Ginna Unit,1 Page 15 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Code Category B-J. Welds PL-FW-III-R and PL-FW-X-R (Similar-Metal Narrow Groove Welds)

Zero percent Code coverage was obtained as a result of the licensee's error/lackof review. As such, please clarify why this exam was not completed at the next outage, especially in light of the statement in response to RAI question No. 3b (page 5 of 20 on RAI response), "Forthe future, the site should modify the existing site-specific mockup to include the narrow groove weld configuration with flaws that will be adjacent to the DM weld as in the field. At this time, it will be possible for a qualified ISI vendor to demonstrate a qualified UT technique such as PAUT on this component for flaw detection and applicablecode coverage." Will the exam be done at the next scheduled outage?

Response

No, this exam will not be examined during the Fifth 10-Year Interval. Zero percent code coverage was due to limitations that were not recognized prior to the exam. If recognized, it would have been apparent that this exam was impractical and only a limited best effort exam was possible.

During the preparation of this response, Ginna contacted AREVA qualified PDI staff and EPRI PDA staff about modifying the Ginna site-specific mockup and developing a qualified UT technique for this similar-metal narrow groove weld configuration. The EPRI PDA staff noted that there is still no qualified procedure for a stainless steel weld configuration that is beyond the qualified generic procedure, based on thickness, the tapered outer scan surface and scanning through an adjacent DM weld material. A new procedure qualification would have to be created.

Due to the highly restrictive geometry, both organizations stated that the chances of successfully interrogating the weld in a way that would meet PDI requirements were negligible, even using Phased Array UT. It has become apparent that due to limitations, sufficient technology is not currently available to provide significant Code Coverage. The response to question 3b in Reference 2 was not intended to imply that such methods currently exist and can be used in an upcoming inspection.

These welds were part of the 1996 Steam Generator replacement project and no flaws were identified in the pre-service RT examinations. With the three follow-up examinations discussed in other portions of this response, Ginna will meet the Code required minimum number (129) of properly performed weld examinations for this sample population of 517 welds. A total of 131 Examination Category B-J welds were originally selected for the Fourth Interval ISI program and with the exception of these two welds, 129 will be complete. While this sample does not address these two terminal ends, improved trending information can be obtained from other terminal ends.

Although part of the high safety significance weld population, these welds were not chosen for future exams in the Risk Informed program.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 16 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 0 What were the results of the PSI exams?

Response

For the pre-service inspections (PSI), the following examinations were performed:

For pre-service inspection, welds identified as PL-FW-X-R and PL-FW-111-R were examined in the 1996 outage. (Replacement Steam Generator project)

Surface Examination (PT) - Acceptable Volumetric Examination (RT) - Acceptable All NDE PSI examinations were performed in accordance with ASME BPV Section XI, 1986 Edition, No Addenda.

  • Was the generic issue entered into the corrective action program? What were the corrective actions?

Response

Yes, the site did generate a Condition Report in its corrective action program (CAP). CR-2009-007117 was categorized as a significance level 2 condition requiring an Apparent Cause Evaluation (ACE). The ACE contained the following corrective and preventive actions:

  • Provide complex weld ISI inspection schedule (5 th ISI Interval) to the site Level III NDE Specialist;
  • Qualify the similar metal weld inspections to optimal code coverage

" Develop a template for planning for complex welds;

" Submit a Relief Request to the NRC Code Category B-J. Welds PL-FW-XIII, PL-FW-VI, PL-FW-XV, PL-FW-VIII, D. A. B. CSW-5. A, C.

H. H and J

  • For all of these welds, the figures should have been re-submitted to address the original RAI.

Response

See the following component weld documents addressing the original RAI.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 17 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1012000 Comp ID: PL-FW-XIII The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a cast stainless-steel elbow to cast stainless-steel pump weld configuration. The site's staff was preparing the subsequent request for additional information when it was discovered that this ISI examination was performed incorrectly. Condition report CR-2012-000188 was initiated which documented this deficiency.

In accordance with the Ginna Station 4 th Interval ISI Program, Weld PL-FW-XIII is a Elbow-to-Pump (RCP-A) weld on a 31" Reactor Coolant Loop A line that was ultrasonically (UT) examined in 2008 under ISI Summary Number 1012000. The incorrect procedure was used and no code credit can be accepted. This weld is Examination Category B-J, Item Number B9.1 1. The Ultrasonic examination will be re-performed no later than the end of the 2014 RFO.

The 4 th Interval ISI Program was developed to ASME Section Xl Code, 1995 Edition with the 1996 Addenda. The ASME Section Xl Code is a sampling code and trends acceptable or degraded conditions. Weld PL-FW-XlII had previous ASME Section Xl Code UT examinations performed and all examinations were acceptable.

ASME Section Xl Code, 1995 Edition with the 1996 Addenda, Table IWB-2500-1 Examination Category B-J, Pressure Retaining Welds in Piping is the criteria for selection. Footnote (1) under Examination Category B-J further defines the selection. Footnote (1) (b) describes "All terminal ends and joints in each pipe or branch run connected to other components where the stress levels exceed either of the following limits under loads associated with specific seismic events and operational conditions: (1) primary plus secondary stress intensity range of 2.4 Sm for ferritic steel and austenitic steel (2) cumulative usage factor U of 0.4." Ginna was designed and built to B31.1 Code 1955. The criteria under Footnote (1) (b) could not be applied. As allowed by 10CFR50.55a (b)(2)(ii), ASME Section Xl 1974 Edition with addenda through 1975 is permitted for Category B-J weld selection and does not utilize stress level criteria. Thus, Ginna selected all accessible Terminal Ends and joints in each pipe or branch run connected to other components such as pumps, branches, and anchors.

The selection of all pump terminal ends is conservative and provides a greater reasonable assurance for public health and safety.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 18 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 On the 31" Reactor Coolant Loop "A" line, weld PL-FW-XIII configuration is Cast Elbow-to-Cast Pump located on Reactor Coolant Pump "A" suction. An identical weld is located on the 31" Reactor Coolant Loop "B" line. This weld is PL-FW-XV. Weld PL-FW-XV configuration is Cast Elbow-to-Cast Pump located on Reactor Coolant Pump "B" suction. This weld was examined by UT during the 2005 RFO, and the results of the examination were acceptable.

On the 27.5" Reactor Coolant Loop "A" line, weld PL-FW-VI configuration is Cast Pump-to-Wrought Pipe located on the Reactor Coolant Pump "A" discharge. This weld was examined by UT during the 2006 RFO, and the results of the examination were acceptable.

On the 27.5" Reactor Coolant Loop "B" line, weld PL-FW-VIII configuration is Cast Pump-to-Wrought Pipe located on the Reactor Coolant Pump "B" discharge. This weld was examined by UT during the 2008 RFO, and the results of the examination were acceptable.

There is no known degradation mechanism for Weld PL-FW-XIII, Cast Elbow-to-Cast Pump (Reactor Coolant Pump "A" suction), and a review of previous examinations for the weld showed consistently satisfactory results. These two facts, coupled with the acceptable examinations of three out of four pump terminal ends during the 4th Interval ISI Program, make it unlikely that there is a problem on Weld PL-FW-XIII and provide reasonable assurance for public health and safety.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

Previously supplied figure was not re-submitted, site is providing the following information:

Investigation and background information:

Condition report CR-2012-000188 describes a condition that occurred prior to the 2008 outage at Ginna. The site personnel provided the outage ISI examination scope list to the selected ISI/NDE vendor. This list included the requested essential component information such as WO #, Summary #,

Component ID, Description, Line name, Diameter, Thickness, Material, etc. During the process of populating the ISI list with information, the site NDE person provided the vendor information that identified this weld as a stainless-steel (elbow) to cast stainless-steel (pump) configuration instead of Cast SS to Cast SS. This human performance error set up the vendor to fail by performing the required ISI UT examination with the incorrect ultrasonic PDI procedure and applicable Cast SS calibration block (Appendix VIII as compared to Appendix III on Cast Stainless Steel material).

The vendor communicated to the site that they had reviewed the historical ISI examination record which had the correct Cast SS calibration block. However, partly due to the HU error previously described, the vendor did not use the applicable calibration block (SS vs. CSS) or the NDE procedure that is applicable to cast stainless steel. Also, during the post-examination reviews of this weld by the vendor and site personnel, the error was not caught.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 19 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Weld PL-FW-XV The original submittal shows this to be a stainless steel (SS) elbow to cast pump that was examined in accordancewith Appendix VIII (page 6 of 21 in the originalsubmittal) from a single side with 50 percent code coverage achieved. However, the RAI indicates that this is a cast stainless steel (CSS) elbow to a CSS pump casing that was examined in 2008 using a best effort exam with a SLIC20 transducer. Assuming that the RAI response clarifying this as a CSS elbow to CSS pump casing is correct,what is the code requiredexamination for this weld?

Response

The following clarification is provided on what examination actions occurred with each of the following CSS to CSS Weld IDs:

PL-FW-XV - CSS elbow to CSS pump configuration examination was performed in 2005 with SLIC20 transducer and Appendix III procedure with acceptable results.

PL-FW-XIII - CSS elbow to CSS pump configuration examination was performed in 2008 and was incorrectly examined with the Appendix VIII procedure. As previously described Condition Report CR-2012-000188 was generated.

Assuming that the RAI response clarifying this as a CSS elbow to CSS pump casing is correct, what is the code requiredexamination for this weld?

Response

The code required examination for this weld should use a alternate "state of the art" technique; using ASME Section Xl, Appendix III procedure that addressed inherent coarse-grained structures in accordance IWA-2240.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 20 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1012100 Comp ID: PL-FW-VI Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a cast stainless steel pump to wrought stainless steel pipe weld configuration. The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the pump cast stainless steel material and configuration restrictions; therefore no axial scan was performed on the pump-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.
  • Circumferential scans were performed using a 450 shear wave in both the clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 21 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 27.5-RC-2501-A Diameter: 29" Component ID: PL-FW-VI Thickness: 2.500" Summary#: 1012100 Material: CSS / SS Exam Angles: 450 S 1 60°RL

Description:

Pump to Pipe Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken cn (D

0 0

0 33 Mti 2.

0.o 0 0 V" Q- 1,

ýqo 0l C

(DCPL ks c~sG C-tCA ~s

-~

Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 22 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1013500 Comp ID: PL-FW-XV Page 1 of3 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a "cast stainless-steel elbow to cast stainless-steel pump weld configuration". The wave modality used for this weld examination was longitudinal wave.

The component scan limitation was due to the pump configuration restrictions; therefore no axial scan was performed on the pump-side (far-side) of the weld. All axial weld examinations were performed on the elbow-side (near-side) of the weld.

No Appendix VIII examination performed, vendor performed an Appendix III examination using a procedure that addressed coarse-grained materials with "state of the art" technology. The vendor utilized a SLIC 20 transducer that is focused for this component thickness. See attached search unit focus chart provided by vendor.

No alternative examinations are planned for the weld during the current inspection (5 th R-1) interval.

The use of radiography as an alternate volumetric examination for the above listed component is not practical due to component thickness and geometric configurations. Other restrictions making radiography impractical are the physical barriers prohibiting access for placement of source, film, image quality indicator, etc.

The insonification angles used for this weld examination were:

  • 30' angle RL wave for the axial scan on elbow-side (near-side) to detect weld discontinuities; 0 300 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from elbow-side.
  • Circumferential scans were performed using a 30' RL wave in both the clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketches derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 23 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 31-RC-2501-B Diameter: 31" Component ID: PL-FW-XV Thickness: 2.400" Summary #: 1013500 Material: CSS / CSS Exam Angles: 3001200 RL

Description:

Elbow to Pump (SLIC 20) (RCP-B)

Page 2 of 3 Exam Coverage = 50%.

Best effort exam on far side of weld - No coverage credit taken

-L.4 -111 PP..vt Pump wD.!OW co xQam AxckExoýP Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 24 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 31-RC-2501-B Diameter: 31" Component ID: PL-FW-XV Thickness: 2.400" Summary #: 1013500 Material: CSS / CSS Exam Angles: 3001200 RL

Description:

Elbow to Pump (SLIC 20) (RCP-B)

Page 3 of 3 SLIC search unit focus beam traces chart provided by vendor.

(SLIC 20) is displayed on the left side.

SLIC MODULE BEAM TRACES S¶L1C 20 SLIC 15 St*IC 45 10 60 L S I

Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 25 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1013600 Comp ID: PL-FW-VIII Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a cast stainless steel pump to wrought stainless steel pipe weld configuration. The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the cast stainless steel material and pump configuration restrictions; therefore no axial scan was performed on the pump-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from the pipe-side as indicated on the attached sketch.

0 Circumferential scans were performed using a 450 shear wave in both the clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 26 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 27.5-RC-2501-B Diameter: 31" Component ID: PL-FW-VIII Thickness: 2.500" Summary #: 1013600 Material: CSS I SS Exam Angles: 450S / 60°RL

Description:

Pump (RCP-B) to Pipe Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken Summary No.: 1013600 Sketch or Photo:

5PA 4 CAo TEAS Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 27 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1014500 Comp ID: RC-FW-D Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel pipe to stainless steel nozzle weld configuration. The wave modality used for this weld examination was shear and longitudinal wave.

The component scan limitation was due to the nozzle configuration restrictions; therefore no axial scan was performed on the nozzle-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 600 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from pipe-side.
  • Circumferential scans were performed using a 600 shear wave in both clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 28 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 10-RC8-2501 Diameter: 10" Component ID: RC-FW-D Thickness: 1.000" Summary #: 1014500 Material: SS Exam Angles: 60°S / 60°RL

Description:

Pipe to Nozzle (Loop B Hot Leg)

Page 2 of 2 Code Coverage = 50% as per single-sided access PDI rules Total Examination Coverage = 74% w/ Best Effort.

Welded ID tag was in the area of interest. Upstream side axial scan was reduced by this obstruction.

See coverage calculation below. The sketch below doesn't show that the 60' RL was used for far-side of weld. This was documented in the ISI report # 09GU014.

Summary No.: 1014500

-:K Sketch or Photo: C-C,,t PAJ-.,4 Q,-, cri/zs/oi Flow

  • 11
  • Nozzle Exam imians. No axial exam on DS side due to nozzle taper.

this area. no coverage credit Welded ID tag on US side, 1.5" tong, 1.75" from weld, at 180*. Best effort axial exam performed in taken.

Coveraoe Calc:

US axial: 32.5' of 34" = 96%

DS axial: 0%

US circ: 100%

DS circ: 100%

(96% + 0% + 100% + 100%)1 4 = 74%

Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 29 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1028900 Comp ID: 1OA-AC7-2501-B Weld "A" Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel valve to stainless steel pipe weld configuration. The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

0 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities; 0 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.

  • Circumferential scans were performed using a 450 shear wave in both clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 30 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: IOA-AC7-2501-B Diameter: 10" Component ID: A Thickness: 1.000" Summary #: 1028900 Material: SS Exam Angles: 45°S / 60°RL

Description:

Valve (720) to Pipe Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken c2/fMfA¶ j, 1 i '"

Fha~ a-.

Cro~

Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 31 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1029400 Comp ID: 1OA-AC7-2501-B, Weld "B" Page 1 of3 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel pipe to valve weld configuration.

The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities; 0 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.
  • Circumferential scans were performed using a 45' shear wave in both clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketches derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 32 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 10A-AC7-2501-B Diameter: 10" Component ID: B Thickness: 1.000" Summary #: 1029400 Material: SS Exam Angles: 450S 1 60°RL

Description:

Pipe to Valve (721)

Page 2 of 3 Exam Coverage = 49.5% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken Description of Lirnltticm:

1. 8snle sided aeam.
2. Welded IDtag at TDC. ¶" wide, 0.8" from weld toe. Obstructed exisl exams for 1" of 34*.

Sketch of UrnitaWon: ---T_

F L 0 %^/._-,C PI Pe VALVE (72*

J-TPC

-J a- w UmItations removal requlrements: (t Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 33 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 1OA-AC7-2501-B Diameter: 10" Component ID: B Thickness: 1.000" Summary #: 1029400 Material: SS Exam Angles: 45°S 1 60°RL

Description:

Pipe to Valve (721)

Page 3 of 3 Exam Coverage = 49.5% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken Summary No-: 1029400 Sketch or Photo:

THJC)-"5S* +- CoJTOL.M. TAKE" AT L_- (7oC).

FLOL',

Vig Lz.,)

- - - _-.11

t. D6" 1.10. "

Le ., fI(I 4/z~4c

'La J C "*t A_

5IMO"- c A 0o04HEX Lq / 2--, (

Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 34 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1030300 Comp ID: 1OA-RCO-2501-B, Weld # CSW-5 Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel tee to nozzle weld configuration.

The wave modality used for this weld examination was shear and longitudinal wave. The component scan limitation was due to the nozzle configuration restrictions; therefore no axial scan was performed on the nozzle-side (far-side) of the weld. All axial weld examinations were performed on the tee-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 450 angle shear wave for the axial scan on tee-side (near-side) to detect weld discontinuities; 0 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from tee-side.
  • Circumferential scans were performed using a 45' shear wave in both clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 35 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 10A-RCO-2501-B Diameter: 10" Component ID: CSW-5 Thickness: 1.00" Summary #: 1030300 Material: SS Exam Angles: 45°S / 60°RL

Description:

Tee to Nozzle Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken

- - * - * *- .. I

  • . -rL* 2 2 I[ ] 2 -. ..J I ] .* '= IG ]I 7 I "- T [I' - - "

-2 ....

."L*... . - .t rl ir !!

'At 1rnin s.

q rer fl2 a,9N* CSLOJ $

I ~I t~ k ,.K .... L~4~4~4-L -

Sket.o,0! to Best Quality Available Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 36 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1030400 Comp ID: 1OA-RCO-2501-A, Weld "A" Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel nozzle to pipe weld configuration.

The wave modality used for this weld examination was shear and longitudinal wave. The component scan limitation was due to the nozzle configuration restrictions; therefore no axial scan was performed on the nozzle-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 600 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from pipe-side.
  • Circumferential scans were performed using a 45' shear wave in both clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 37 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 1OA-RCO-2501-A Diameter: 10" Component ID: A Thickness: 1.00" Summary #: 1030400 Material: SS Exam Angles: 45°S / 60°Sl60°RL

Description:

Nozzle to Pipe Page 2 of 2 Code Coverage = 50% as per single-sided access PDI rules Total Examination Coverage = 74% / Best Effort The sketch below doesn't show that the 60' RL was used for "Best Effort" on far-side of weld.

This was documented in the applicable ISI report.

Summary No.: 1030400 Sketch or Photo:

Flow Exam Limitations: No axial exam on US side due to nozzle taper.

Welded ID tag on DS side, 1.5" long, 1.75" from weld, at 1800. Best effort axial exam performed in this area, no coverage credit taken.

Coverage Calc:

US axial: 0%

DS axial: 32.5" of 34" = 96%

US circ: 100%

DS circ: 100%

(0% + 96% + 100% + 100%) / 4 = 74%

Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 38 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1030700 Comp ID: 1OA-AC7-2501-A Weld "C" Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel valve to pipe weld configuration.

The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld. An additional limitation was a welded ID tag in the scan area.

The insonification angles used for this weld examination were:

  • 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities; 0 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.
  • Circumferential scans were performed using a 450 shear wave in both clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 39 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 1OA-AC7-2501-A Diameter: 10" Component ID: C Thickness: 1.00" Summary #: 1030700 Material: SS Exam Angles: 450S / 60ORL

Description:

Valve (700) to Pipe Page 2 of 2 Exam Coverage = 49.5% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken Summawry No.: 1030700 Sketch or Photo:

TjMjckJs t COAJTOvl TAkEtJ AT L. (TDDC).

VALVE (70o) srL4..% PIPE.

r "o*

1. 05* 1.0O Lea. III 4/7- */ Zoog 5*poi Cd*o'rl-tHE C 90 9 /o(>E Best Quality Available Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 40 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1034300 Comp ID: 1OA-SI2-2501-B Weld "H" Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for relief request ISI-03 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel pipe to valve weld configuration.

The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.
  • Circumferential scans were performed using a 450 shear wave in both clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 41 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 1OA-SI2-2501-B Diameter: 10" Component ID: H Thickness: 1.00" Summary #: 1034300 Material: SS Exam Angles: 45°S / 60°RL

Description:

Pipe to Valve (867A)

Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken eSa C or, Phot_:l: '('kat cL-hs * -- ) .- 1

--- I--

4AqLY6-

1. Ce IýOs 1,6ý"

VPLV&

A-Best Quality Available - Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 42 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1035900 Comp ID: IOA-SI2-2501-A, Weld H Page 1 of 3 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel pipe weld to valve configuration.

The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 600 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • Circumferential scans were performed using a 600 shear wave in both clockwise and counter-clockwise directions.

Condition Report CR-2012-000188 was generated to document the examination deviation from the approved procedure. The examiner did not use the required longitudinal search unit for "best effort" examination scan on the far side of the weld to detect discontinuities. The data reviewer did not catch the missed scan during the examination document review process in 2002.

In accordance with ASME Section Xl Code, 1995 Edition with the 1996 Addenda, this weld is Examination Category B-J, Item Number B9.1 1. During the 2002 Refueling Outage, a surface and volumetric examination was performed on Weld H, Pipe to Valve (867B) under ISI Summary Number 1035900. The surface examination that was performed was a Liquid Penetrant Test (PT). This PT examination was acceptable with no recordable indications and no limitations. A Volumetric (Ultrasonic) examination was also performed. The Ultrasonic examination was acceptable with no recordable indications. The examination coverage obtained was 50% code coverage as per single-sided access in accordance with PDI rules. No best effort examination was performed on the far side of the weld.

With the performance of a Liquid Penetrant (PT) examination and the Volumetric (Ultrasonic) 50%

code coverage examination, the examinations provide reasonable assurance that the weld is sound for public health and safety and there is little risk in performing the best effort part of the ultrasonic

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 43 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1035900 Comp ID: 1OA-SI2-2501-A, Weld H Page 2 of 3 examination no later than the end of the 2014 RFO. Also, there is no known degradation mechanism for Weld H, Pipe to Valve (867B).

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 44 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: IOA-SI2-2501-A Diameter: 10" Component ID: H Thickness: 1.00" Summary #: 1035900 Material: SS Exam Angles: 600S

Description:

Pipe to Valve (867B)

Page 3 of 3 Exam Coverage = 50% as per single-sided access PDI rules.

No best effort exam on far side of weld.

Sketch or Photo: LUVdeaAttachmentsW2GU 11.bmp (A st Sr-ALE LI-M0 S ee.O*

"1 0 S 0 .3 0 .

I I

VALVE Best Quality Available Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 45 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Weld H (1035900)

The RAI response stated that the "sitequalified examiner and the site level Ill misinterpreted the qualified generic procedure which states, "The primary angle shall be the lowest angle that provides coverage of the required examination volume from each side of the weld," thus the required 45-degree shear wave exam was not completed. Additionally, the RAI states that "duringthe review process, the site UT Level Ill reviewer missed that the qualified PDI UT examiner did not perform a best effort examination of the far side of the weld using a RL transducer."

o When were these two omissions discovered?

Response

These two omissions were discovered in between the original submittal of the Relief Request on 12/16/2010 and during the preparation of the 1 st RAI submitted on 07/29/2011, the site discovered the procedural non-adherence and human performance error involving this ISI component examination.

o What plans are in place to meet the requirementsof the PDI procedure?

Response

The site scope-add process is currently being used to add this examination into the next refueling outage. Ginna commits to perform this 4 th interval ultrasonic ISI examination no later than the end of the 2014 RFO.

The site is currently in the 5 th Interval ISI Program. Weld # H is part of the site's 5th Interval Risk-Informed Program. The RI weld is classified as high safety significance (HSS) in accordance with the Risk-Informed Program. Welds other than this one were selected to meet the risk-informed required examination population.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 46 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 o Was the generic issue entered into the corrective action program? What were the corrective actions?

Response

Yes, the generic issue was entered into the site's corrective action program (CR-2012-000188). The corrective actions are as following:

1. Scope additions for the weld examinations.
2. Independent check of the initial ISI scope UT implementation list for upcoming refueling outages.
3. Enhance existing UT weld examination scan plans for future scheduled ISI welds (Note: The scan plan template document did not exist back in the 2002 timeframe);
4. Revise existing UT reviewer checklist to enhance the final examination record reviews.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 47 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1036200 Comp ID: 6A-RCO-2501-B-J Page 1 of 4 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel valve to pipe weld configuration.

The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 600 angle shear wave was used for best effort axial scan of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.

0 Circumferential scans were performed using a 450 shear wave in both clockwise and counter-clockwise directions.

Weld J (1036200) o The RAI response states that "duringthe review process after the 2002 refueling outage, the site UT Level I/ reviewer missed that the qualified PDI UT examiner did not perform a best effort examination on the far side of the weld using a RL transducer."

o When was this omission discovered?

Response

This omission were discovered in between the original submittal of the Relief Request on 12/16/2010 and during the preparation of the 1 st RAI submitted on 07/29/2011, the site discovered the procedural non-adherence and human performance error involving this ISI component examination.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 48 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1036200 Comp ID: 6A-RCO-2501-B-J Page 2 of 4 o What plans are in place to meet the requirements of the PD!procedure?

Response

The site scope-add process is currently being used to add this examination into the next refueling outage. Ginna commits to perform this 4 th interval ISI examination no later than the end of the 2014 RFO.

o Was the generic issue entered into the corrective action program? What were the corrective actions?

Response

Yes, Condition Report CR-2012-000188 was generated to document the examination deviation from the approved procedure. The examiner did not use the required longitudinal search unit for "best effort" examination scan on the far side of weld to detect discontinuities. The data reviewer did not catch the missed scan during the examination document review process in 2002.

o What were the corrective actions?

Response

The corrective actions are as following:

1. Scope additions for the weld examinations;
2. Independent check of the initial ISI scope for upcoming refueling outages;.
3. Enhance existing weld examination scan plan for future scheduled ISI weld, Note:

The scan plan template document did not exist back in the 2002 timeframe;

4. Revise existing reviewer checklist for enhancing the final examination record reviews.

The site is currently in the 5 th Interval ISI Program. Weld # J is part of the site's 5t Interval Risk-Informed Program. This RI weld is classified as high safety significance (HSS) in accordance with the risk informed Program. Welds other than this one were selected to meet the risk-informed required examination population.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 49 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1036200 Comp ID: 6A-RCO-2501-B-J Page 3 of 4 In accordance with ASME Section Xl Code, 1995 Edition with the 1996 Addenda, this weld is Examination Category B-J, Item Number B9.11. During the 2002 Refueling Outage, a surface and volumetric examination was performed on Weld J, Stainless Steel Valve (852B) to Pipe under ISI Summary Number 1036200. The surface examination that was performed was a Liquid Penetrant Test (PT). This PT examination was acceptable with no recordable indications and no limitations. A Volumetric (Ultrasonic) examination was also performed. The Ultrasonic examination was acceptable with no recordable indications. The examination coverage obtained was 50% code coverage as per single-sided access in accordance with PDI rules. No best effort examination was performed on the far side of the weld.

With the performance of a Liquid Penetrant (PT) examination and the Volumetric (Ultrasonic) 50%

code coverage examination, the examinations provide reasonable assurance that the weld is sound for public health and safety and there is little risk in performing the best effort part of the ultrasonic examination no later than the end of the 2014 RFO. Also, there is no known degradation mechanism for Weld J, Valve (852B) to Pipe.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 50 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 6A-RCO-2501-B Diameter: 6" Component ID: J Thickness: 0.719" Summary #: 1036200 Material: SS Exam Angles: 45°S / 60°S

Description:

Valve (852B) to Pipe Page 4 of 4 Exam Coverage = 50% as per single-sided access PDI rules.

  • No best effort exam on far side of weld.

IIow Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 51 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1011000 Comp ID: PL-FW-II Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel pipe to branch weld configuration.

The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the weld configuration restrictions; therefore no axial scan was performed on the RCS pipe-side (far-side) of the weld. All axial weld examinations were performed on the branch-side (near-side) of the weld.

The insonification angles used for this weld examination were:

e 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;

  • 600 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from branch pipe-side as indicated on the attached sketch.

0 Circumferential scans were performed using a 450 shear wave in both clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 52 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 1OA-RCO-2501-A Diameter: 10" Component ID: PL-FW-11 Thickness: 2.50" Summary#: 1011000 Material: SS Exam Angles: 45°SI60°S / 60*RL

Description:

Branch Weld Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken Comments:

W6Lf PL-FW-I_1/1OA..RCO-2501-A TOTAL WELD LENGATH =-43-2."

Sketch or Photo:

(PIZFILE TAAENh AT EbC OF 1OT Le&,)

ob=32-7 ,

Additional - Supplemental Reports <edit from Setup>

Best Quality Available Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 53 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1059200 Comp ID: V-720-1 Page I of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel valve to body weld configuration.

The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.
  • Circumferential scans were performed using a 450 shear wave in both clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 54 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 1OA-AC7-2501-B Diameter: 10" Component ID: V-720-1 Thickness: 1.36" Summary #: 1059200 Material: SS Exam Angles: 450S / 60°RL

Description:

Velan Motor Operated Gate Valve (Body Weld)

Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken Comment'

~~ELO~L Sy3 7"Cf- ITO

\30 Sketch or Photo:

VAL VE V4 IVE

,,d v..jt4 42

  1. IP&W0Z&17#

Best Quality Available Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 55 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1059205 Comp ID: V-720-2 Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for Relief Request ISI-02 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed on a stainless steel valve to valve body weld configuration. The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

9 450 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;

  • 600 angle RL wave was used for best effort axial scan of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.

0 Circumferential scans were performed using a 450 shear wave in both clockwise and counter-clockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 56 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 1OA-AC7-2501-B Diameter: 10" Component ID: V-720-2 Thickness: 1.36" Summary #: 1059205 Material: SS Exam Angles: 45"S/ 60°RL

Description:

Velan Motor Operated Gate Valve (Body Weld)

Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken Comments:

A DL)

C , Mn p oe=,e n 'C" ý 'D %/=. 0* .2, CB30D?? We t (oeg..

Sketch or Photo:

rxTew-Tnot4 A FA Best Quality Available Image Altered for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 57 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 RELIEF REQUEST ISI-03 ASME Code Category C-F-I, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping, Item No. C5.21 Circumferential Pipe Welds.

The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide detailed and specific information to support the bases for limited examination in all requests for relief submitted on December 16, 2010 and July 29, 2011, and therefore, demonstrate impracticality. The questions for each relief request are as follows:

2.1.1 c) Fully clarify the wave mode(s) and insonification angles used for all ultrasonicexaminations.

2.1.1 d) Provide cross-sectionalcoverage plots to describe ASME Code volumes and transducer angles used during the examination.

ADDITIONAL INFORMATION - GINNA RELIEF REQUEST ISI-03 (Class 2 Welds) o Please resubmit all figures such that each clearly depicts the wave modalities and insonification angles used, as well as limitations encounteredand coverage obtained. Though the RAI response attempts to clarify the coverage obtained as well as insonificationangles and modalities, there are still discrepanciesbetween the text and figures.

Response: See the attached documents for all figures.

o Were these exams performed in accordance with the 1995 Edition/1996 Addenda of Appendix VIII?

Response

Yes - During the site's 4 th ISI Interval program, the ISI ultrasonic examinations were performed in accordance with the 1995 Edition/1996 Addenda, Appendix VIII - as modified by 10CFR 50.55a.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 58 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1163070 Comp ID: 3C-SI-1501-6 Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for relief request ISI-03 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonificationangles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination on a stainless steel pipe to valve weld configuration. The wave modality used for this weld examination was shear-wave. The component scan limitation was due to the valve configuration restrictions; therefore no axial or circumferential scan examination was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

0 00 angle for weld profile;

  • 450 angle for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 700 angle was used for best effort examination of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.

0 Circumferential scans were performed using a 450 shear wave in both clockwise and counterclockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See attached sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 59 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Component ID: 3C-SI-1501-6 Diameter: 3" Summary #: 1163070 Thickness: 0.300" Exam Angles: 001 450 S / 670S Material: SS

Description:

Pipe to Valve (870A)

Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam (700) on far side of weld - No coverage credit taken.

SCAN PLAN ROW Sketch or PNOW:

L4E4 ULOW LA) L u*OO0 Image Enlarged for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 60 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1163570 Comp ID: 3E-SI-1501-8 Page 1 of2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for relief request ISI-03 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination on a stainless steel valve to pipe weld configuration. The wave modality used for this weld examination was shear-wave. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 0' angle for weld profile; o 450 angle for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 600 angle for the axial scan on pipe-side (near-side) to detect weld discontinuities; 0 70' angle was used for best effort examination of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.
  • Circumferential scans were performed using a 45' shear wave in both clockwise and counterclockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See attached sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 61 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Component ID: 3E-SI-1501-8 Diameter: 3" Summary #: 1163570 Thickness: 0.300" Exam Angles: 00! 45°S / 60°S / Material: SS 70 0 S

Description:

Valve (888B) to Pipe Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam (700) on far side of weld - No coverage credit taken.

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vC-i J I I II I I I I I I I I I 4 6-,00 700 jOQ (ero 7D Image Enlarged for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 62 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1163220 Comp ID: 3D-SI-1501-14 Page 1 of3 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for relief request ISI-03 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed in 2002 on a stainless steel valve to pipe weld configuration. The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

Vendor procedure # ISwT-PDI-UT1 was used to examine this weld, refer to PDQS # 371, IHI Southwest Technologies, Inc. Within this procedure, the 520 shear wave transducer is qualified.

The insonification angles used for this weld examination were:

  • 00 angle was used for weld profiling;
  • 520 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 700 angle shear wave was used for best effort examination of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.
  • Circumferential scans were performed using a 450 longitudinal and 520 shear wave in both clockwise and counterclockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketches derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 63 of 75 Code Category B-F, Item No. B5.70 Class I Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Component ID: 3D-SI-1501-14 Diameter: 3" Summary #: 1163220 Thickness: 0.310" Exam Angles: 00/45°RL / 52 0 S/70 0S Material: SS

Description:

Valve (871B) to Pipe Page 2 of 3 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam (700) on far side of weld - No coverage credit taken.

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Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 64 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Component ID: 3D-SI-1501-14 Diameter: 3" Summary #: 1163220 Thickness: 0.310" Exam Angles: 0°/45°RL I 52 0S I Material: SS 700S

Description:

Valve (871B) to Pipe Page 3 of 3 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam (70') on far side of weld - No coverage credit taken I

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Relief Request ISI-02 and ISI-03 for Ginna Unit I Page 65 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1163230 Comp ID: 3D-SI-1501-15 Page 1 of3 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for relief request ISI-03 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed in 2002 on a stainless steel valve to pipe weld configuration. The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 00 angle used for weld profiling;
  • 520 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities; 0 70° angle shear wave was used for best effort examination of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.

0 Circumferential scans were performed using a 450 longitudinal and 520 shear wave in both clockwise and counterclockwise directions.

Vendor procedure # ISwT-PDI-UT1 was used to examine this weld, refer to PDQS # 371, IHI Southwest Technologies, Inc. Within this procedure, the 520 shear wave transducer is qualified.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketches derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 66 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Component ID: 3D-SI-1501-15 Diameter: 3" Summary#: 1163230 Thickness: 0.310" Exam Angles: 0°I45°RL / 52°S I Material: SS 70 0 S

Description:

Pipe to Valve (870B)

Page 2 of 3 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam (70') on far side of weld - No coverage credit taken.

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Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 67 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Component ID: 3D-SI-1501-15 Diameter: 3" Summary #: 1163230 Thickness: 0.310" Exam Angles: 00/450 RL / 52 0 S I Material: SS 700S

Description:

Pipe to Valve (870B)

Page 3 of 3 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam (700) on far side of weld - No coverage credit taken I

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Image Enlarged for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 68 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1162770 Comp ID: 3B-SI-1501-18 Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for relief request ISI-03 submitted on December 16, 2010. The questions for the request for additional information are as follows:

2.1.1 c) Fully clarify the wave mode(s) and insonification angles used for all ultrasonicexaminations.

Response

This was a manual UT examination on a stainless steel Pipe to stainless steel Tee weld configuration.

The wave modality used for this weld examination was shear-wave. This examination was a dual-sided examination. This component weld had a scanning limitation; this was due to losing transducer contact when scanning on and within the Tee's crotch radius regions (two regions) adjacent to the weld. Based on the following existing weld crown conditions, as welded and having a fairly wide crown, combined with the component thin wall thickness, the qualified examiner scanned the weld with higher angles as specified in PDI generic procedure.

The insonification angles used for this ISI Ultrasonic weld examination:

  • 70' shear-wave for the axial scans in the upstream and downstream directions for both pipe and tee side of the weld.

0 600 shear-wave used for the circumferential scans in both CW/CCW directions, as indicated on the attached sketch.

2.1.1 d) Provide cross-sectionalcoverage plots to describe ASME Code volumes and transducer angles used during the examination.

Response

See attached sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 69 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Component ID: 3B-SI-1501-18 Diameter: 3.8" Summary #: 1162770 Thickness: 0.300" Exam Angles: 60°S, 70 0 S Material: SS

Description:

Pipe to Tee Page 2 of 2 Weld Examination Coverage = 82.5%.

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Image Enlarged for Clarity - Not to Scale 600 CW 100%

600 CCW 100%

700 Pipe U/S 100%

700 Tee side w/ limitations 30%

Code Coverage. Total % 330 / 4 = Coverage = 82.5%

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 70 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1164300 Comp ID: 4E-SI-1501-56 Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for relief request ISI-03 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination performed in 2000 on a stainless steel flange to pipe weld configuration. The wave modality used for this weld examination was shear and longitudinal. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld.

The insonification angles used for this weld examination were:

  • 0' angle was used for weld profiling;
  • 520 angle shear wave for the axial scan on pipe-side (near-side) to detect weld discontinuities;
  • 700 angle shear wave was used for best effort examination of the far-side of weld, scanned from pipe-side as indicated on the attached sketch.

o Circumferential scans were performed using a 450 longitudinal and 520 shear wave in both clockwise and counterclockwise directions.

Vendor procedure # ISwT-PDI-UT1 was used to examine this weld, refer to PDQS # 371, IHI Southwest Technologies, Inc. Within this procedure, the 520 shear wave transducer is qualified.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See the following sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 71 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Component ID: 4E-SI-1501-56 Diameter: 4" Summary #: 1164300 Thickness: 0.337" Exam Angles: 00/45°RL / 520S / Material: SS 700S

Description:

Flange (FE-125) to Pipe Page 2 of 2 Exam Coverage = 50% as per single-sided access PDI rules.

Best effort exam on far side of weld - No coverage credit taken.

The 450 RL transducer was used for performing the Circumferential scans as documented on the ISI report but is not displayed on the weld sketch.

Comments: Required coverage obtained. Can scan across the weld.

Sketch or Photo:

4--- 34 31 Jý ýý. .11 FvAq Image Enlarged for Clarity - Not to Scale

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 72 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1090400 Comp ID: L2-BC-2A Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for relief request ISI-03 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination on a carbon steel pipe to carbon steel valve weld configuration.

The wave modality used for this weld examination was shear-wave. The component scan limitation was due to a 3" sweep-o-let component adjacent to the weld region that interfered with the scans.

This prevented the weld examination from obtaining 100% code coverage.

The insonification angles used for this weld examination were:

  • 0' angle for UT Base Metal Lamination and thickness examination; 9 450 angle for the axial scan upstream and downstream to detect weld discontinuities;
  • 600 angle was used for the pipe-side, scanned from pipe-side as indicated on the attached sketch.
  • Circumferential scans were performed using a 450 shear wave in both clockwise and counterclockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See attached sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 73 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 6B-MS-600-1B Diameter: 6" Component ID: L2-BC-2A Thickness: 0.432" Summary #: 1090400 Material: CS Exam Angles: 0°/45°S / 60°S

Description:

Pipe to Valve (3506)

Page 2 of 2 Total Exam Coverage = 86%

Weld length = 21.5", scan limitation (3" sweep-o-let) @ 2700; based on total circumferential and axial scans, the weld code coverage equals 86%. Scanned area was a total of 18.5" of the 21.5" weld length.

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Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 74 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Summary No.: 1083900 Comp ID: G2-BC-2A Page 1 of 2 The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details and specific information to support the bases for the limited examination for relief request ISI-03 submitted on December 16, 2010. The questions for the request for additional information are as follows:

1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonic examinations.

Response

This was a manual UT examination on a carbon steel pipe to carbon steel valve configuration. The wave modality used for this weld examination was shear-wave. The component scan limitation was due to the valve configuration restrictions; therefore no axial scan was performed on the valve-side (far-side) of the weld. All axial weld examinations were performed on the pipe-side (near-side) of the weld. Within the scan region, there was a 3/4" weld-o-let that interfered with the scanning; this prevented obtaining 100% coverage of this weld.

The insonification angles used for this weld examination were:

  • 00 angle for UT Base Metal Lamination and thickness examination; o 450 angle for the axial scan on pipe-side (near-side) to detect weld discontinuities; 0 70' angle was used for the far-side of weld, scanned from pipe-side as indicated on the attached sketch.
  • Circumferential scans were performed using a 450 shear wave in both clockwise and counterclockwise directions.

Provide cross-sectionalcoverage plots (figures) to describe ASME Code volumes and transducer angles used during the examination and coverage calculations.

Response

See attached sketch derived from the examination data on file at Ginna for cross-sectional coverage plots and calculations.

Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 75 of 75 Code Category B-F, Item No. B5.70 Class 1 Components Code Category CF-1, Item No. C5.21 Class 2 Components Additional Information Docket Number 50-244 Line Number: 6B-MS-600-1A Diameter: 6" Component ID: G2-BC-2A Thickness: 0.432" Summary #: 1083900 Material: CS Exam Angles: 0°/45°SI70°S

Description:

Pipe to Valve (3507)

Page 2 of 2 Total Exam Coverage = 84.65%

Weld length = 21", scan limitation (3/4" weld-o-let) from 15.25" to 17.5", welded id tag (from construction) @ 10" to 11"; based on circ and axial scans, the weld code coverage equals 84.65%

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ENCLOSURE 2 List of Regulatory Commitments

LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to in this document by R.E. Ginna Nuclear Power Plant (Ginna). Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Direct questions regarding these commitments to Mr. Thomas Harding at (585) 771-5219 or via e-mail at Thomas. HardinqJr(,cenqllc.com REGULATORY COMMITMENT DUE DATE Perform ultrasonic ISI examination of No later than June 1, 2014 Weld #H (End of 2014 RFO)

Perform ultrasonic ISI examination of No later than June 1, 2014 6A-RCO-2501-B-J (End of 2014 RFO)

Perform ultrasonic ISI examination of No later than June 1, 2014 PL-FW-XIII (End of 2014 RFO)

Page 1 of 1