ML092240586

Hope Creek - Response to Request for Additional Information Regarding Relief Request Associated with the Second Inservice Inspection (ISI) Interval

ML092240586
Person / Time
Site:	Hope Creek
Issue date:	07/28/2009
From:	Keenan J Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N09-0168
Download: ML092240586 (23)

Text

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

Subject:

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

References:

1) Letter from Jeffrie Keenan (PSEG Nuclear LLC) to USNRC, "Submittal of Relief Request Associated with the Second Inservice Inspection (ISI) Interval," dated December 11, 2008 2) Email from R. B. Ennis (USNRC) to J. Keenan (PSEG Nuclear LLC),"Revised Draft RAI -Hope Creek Relief Request HC-12-RR-A25 (TAC ME0230)," dated June 9, 2009 In Reference 1, PSEG Nuclear LLC (PSEG) submitted relief request HC-12-RR-A25 for Hope Creek Generating Station (HCGS), requesting relief from specific requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components.

Relief request HC-12-RR-A25 applies to the second 10-year inservice inspection (ISI)interval which ended on December 12, 2007.In Reference 2, the NRC requested additional information.

Attachment 1 to this letter provides PSEG's response.There are no commitments contained in this letter.11OV-7/11M i LR-N09-0168 July 28, 2009 Page 2 Should you have any questions regarding this submittal, please contact Mr. Paul Duke at 856-339-1466.

Sincerely, ager -Licensing PSEG Nuclear LLC Attachment

1. Response to Request for Additional Information cc: S. Collins, Regional Administrator

-NRC Region I R. Ennis, Project Manager -USNRC NRC Senior Resident Inspector

-Hope Creek P. Mulligan, Manager IV, NJBNE L. Marabella, Corporate Commitment Tracking Coordinator T. Devik, Hope Creek Commitment Tracking Coordinator Attachment 1 LR-N09-0029 Page 1 of 21 DRAFT REQUEST FOR ADDITIONAL INFORMATION RELATED TO RELIEF REQUEST HC-12-RR-A25 FOR SECOND TEN-YEAR INSERVICE INSPECTION INTERVAL HOPE CREEK GENERATING STATION DOCKET NO. 50-354

1.0 BACKGROUND

By letter dated December 11, 2008, (Agency wide Documents Access and Management System (ADAMS) Accession No. ML083590292)

PSEG Nuclear LLC (the licensee), submitted Relief Request (RR) HC-12-RR-A25 for Hope Creek Generating Station (HCGS). The licensee requested relief from specific requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components for HCGS. RR HC-12-RR-A25 applies to the second 10-year in-service inspection (ISI) interval.

The code of record for the start of the HCGS second ten-year ISI Program interval is the ASME Code, 1989 Edition, without Addenda. However, beginning with the third period of the second 10-year ISI interval, PSEG elected to perform a mid-interval update to the 1998 Edition through 2000 Addenda of the ASME Code,Section XI. The use of the later ASME Code Edition was approved in a safety evaluation (SE) issued by the Nuclear Regulatory Commission (NRC) on December 23, 2004 (ADAMS Accession No. ML043580369).

In accordance with Section 50.55a(g)(5)(iii) of Title 10 Code of Federal Regulations (10 CFR)the licensee has submitted RR HC-12-RR-A25 covering several ASME Code Class 1 and Class 2 component weld examinations.

The ASME Code requires that 100 percent of the examination volumes described in ASME Code, Section Xl, Tables IWB-2500-1 and IWC-2500-1 be completed.

The licensee has claimed that 100 percent of the ASME Code-required volumes are impractical to obtain at HCGS. 10 CFR 50.55a(g)(5)(iii) states that when licensees determine that conformance with ASME Code requirements is impractical at their facility, they shall submit information to support this determination.

The NRC staff, with technical assistance from Pacific Northwest National Laboratory, has reviewed the information the licensee provided that supports the subject RR and would like to discuss the following issues to clarify the submittal.

2.0 REQUEST

FOR ADDITIONAL INFORMATION 2.1 HC-12-RR-25 (Part A). ASME Code, Section Xl, Category B-A, Pressure Retaining Welds in Reactor Vessel 2.1.1 Clarify, whether the reactor pressure vessel (RPV) longitudinal welds contained in HC-12-RR-[A]25 had been examined previously in the second 10-year ISI interval or whether RR-B1 submitted by letter dated May 11, 1998, as supplemented by letters dated June 16 and October 25, 1999, was requested prior to examining the subject RPV longitudinal welds in the second 10-year ISI interval.

Attachment 1 LR-N09-0029 Page 2 of 21 Response: The longitudinal seam welds contained in HC-12-RR-A25 (Reference

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

Response: Examinations of the Category B-A pressure-retaining welds listed in Reference 1 Table 1 were performed from the inside of the RPV using procedures that had been successfully qualified through performance demonstration requirements of ASME Code,Section XI, Appendix VIII. The following longitudinal welds were also examined using procedures that had been successfully qualified through performance demonstration requirements of ASME Code,Section XI, Appendix VIII: Table 2.1.2-1 Sum# Component ID Description ASME Cat Exam Outage 100040 RPV1-W11-1 LONGITUDINAL SEAM AT 30 DEG B-A RF14 100045 RPV1 -W11-2 LONGITUDINAL SEAM AT 150 DEG B-A RF14 100050 RPV1-W11-3 LONGITUDINAL SEAM AT 270 DEG B-A RF14 100066 RPV1 -W1 3-1 LONGITUDINAL SEAM AT 35 DEG B-A RF13 100067 RPV1-W13-2 LONGITUDINAL SEAM AT 155 DEG B-A RF13 100068 RPV1-W13-3 LONGITUDINAL SEAM AT 275 DEG B-A RF13 100070 RPV1-W14-1 LONGITUDINAL SEAM AT 90 DEG B-A RF13 100075 RPV1-W14-2 LONGITUDINAL SEAM AT 210 DEG B-A RF13 100080 RPV1-W14-3 LONGITUDINAL SEAM AT 330 DEG B-A RF13 100085 RPV1-W15-1 LONGITUDINAL SEAM AT 18 DEG B-A RF13 100090 RPV1-W15-2 LONGITUDINAL SEAM AT 138 DEG B-A RF13 100095 RPV1-W15-3 LONGITUDINAL SEAM AT 258 DEG B-A RF13 No recordable indications were detected during the examinations.

2.1.3 Relief

request HC-12-RR-25 provided Figure 4 as a supporting sketch to demonstrate that the RPV closure head Weld RPV1-W20 cannot be examined to the full extent required by the ASME Code. However, the dimensions on this figure are not legible.Please re-submit the drawing with legible dimensions.

Response: An updated sketch for RPV closure head weld RPV1-W20 is provided in Figure 2.1.3-1.2.1.4 The licensee stated in Table 1 of the submittal that the required examination volumes for RPV longitudinal welds was 78%, per the previous NRC-approved relief (cited above).However, a review of the NRC Safety Evaluation dated February 3, 2000, does not indicate that the ASME Code requirement of essentially 100% (as defined in ASME Code Case N-460) for the examination volume of the subject welds has been reduced.

Attachment 1 LR-N09-0029 Page 3 of 21 The licensee should explain why it is believed that the required examination volume is 78%, as opposed to 100%, as stated in ASME Code.Response: The ASME Code requires volumetric examination of essentially 100% (as defined in ASME Code Case N-460) of the length of RPV longitudinal shell welds, as defined by Figure IWB-2500-2.

The Required Examination Volume in Reference 1 Table 1 refers to the estimated coverage in RR-B1.2.2 HC-12-RR-25 (Part B), ASME Code, Section Xl, Examination Category B-D, Item B3.90, Full Penetration Welded Nozzles in Vessels The coverage sketch included in the licensee's submittal for all Examination Category B-D nozzle-to-vessel welds is labeled as "typical".

Please re-submit cross-sectional sketches for each type of nozzle-to-vessel weld listed in Table 1, and/or provide full written descriptions, describing the nozzle geometries, the ASME Code-required volumes, and areas of completed coverage (near surface, inner 15 percent, and full volume) for each of the techniques used on these welds. Summarize the scanning directions and techniques, list the materials for the base metal and weld, and clarify whether the methods used have been qualified in accordance with performance demonstration requirements per ASME Code,Section XI, Appendix VIII.Response: Cross-sectional sketches for each type of nozzle-to-vessel weld listed in Reference 1 Table 1 are provided in Figures 2.2-1 through 2.2-7. The scanning directions and techniques are listed in Table 2.2-1 below. The base metal for the reactor vessel shell and head is SA-533 Grade B Class 1. Base metal for the nozzles is SA-508 Class 2 Specified weld materials for carbon steel are SA-558, SA-559, or SA-233.Except where noted, the methods used have been qualified in accordance with performance demonstration requirements per ASME Code, Section Xl, Appendix VIII.

Attachment 1 LR-N09-0029 Page 4 of 21 Table 2.2-1 Scan Scan Comments TechniqueQualified Sum# Comp ID Description Direction Angle Coverage Strt. Beam Planar- 100%Strt. Beam Laminar- 64.7%100200 RPV1-N2B NOZZLE TO SHELL WELD 12" RECIRC 0 to materal 45*160* exams performed from vessel shell side only Parallel 45- 50%N 10DINLET AT 60 DEG CW, CCW, 0/45/60 due to nozzle configuration.

Parallel 60 -50% No Downstream Transverse 45' -100%Transverse 60* -100%Strt. Beam Planar- 100%O0 to material Strt. Beam Laminar -64.7%100205 RPV1-N2C NOZZLE TO SHELL WELD 12" RECIRC 0 to material 45"/60' exams performed from vessel shell side only Parallel 45" -50%INLET AT 90 DEG Cw, due to nozzle configuration.

Parallel 60" -50%DownstreamTransverse 45 -100%Transverse 60" -100%Strt. Beam Planar- 100%Strt. Beam Laminar -64.7%NOZZLE TO SHELL WELD 12" RECIRC 0 to material 45"/60' exams performed from vessel shell side only Parallel 45" -50%1W1INLET AT 300 DEG DwstCWm 0/45o/60" due to nozzle configuration.

Parallel 60" -50% No EDownstream Transverse 45" -100%Transverse 60" -100%Strt. Beam Planar -100%Strt. Beam Laminar -64.7%NOZZLE TON2 S W 1 E 0 to material 45"/60" exams performed from vessel shell side only Parallel 45" -50%1024OPV-2KLET ATEL 330LD12REG IR CW, CCW, 0"/45°/60" N INLET ATV330KIELEDownstream due to nozzle configuration.

Parallel 60" -50% No Transverse 45" -100%Transverse 60" -100%NOZZLE TO SHELL WELD 12" 100265 RPV1-N4A FEEDWATER NOZZLE AT 30 CW, CCW, 50"160" Examined from shell side only due to blend radii Axial 60" longitudinal

-75%DERN E Downstream limiting nozzle side scan. Circ 50" shear- 75% Yes DEGREES NOZZLE TO SHELL WELD 12" 100270 RPV1-N4B FEEDWATER NOZZLE AT 90 CW, CCW, 50"160" Examined from shell side only due to blend radii Axial 60" longitudinal

-75%DERN E Downstream limiting nozzle side scan. Circ 50" shear- 75% Yes DEGREES Examined from shell side only due to blend radii NOZZLE TO SHELL WELD 12" limiting nozzle side scan.100275 RPV1-N4C FEEDWATER NOZZLE AT 150 CW, CCW, 50"/60 Axial 60 longitudinal

-71 Yes DEGREES Downstream Weld pad from nozzle N11 C extended from toe of Circ 50" shear- 71%weld back 25 inches. Exam was limited from 91 to 110 inches circumferentially.

NOZZLE TO SHELL WELD 12" CW, CCW, 50"160" Examined from shell side only due to blend radii Axial 60" longitudinal

-75%DERN E Downstream limiting nozzle side scan. Circ 50" shear- 75%DEGREES NOZZLE TO SHELL WELD 12" 100285 RPV1-N4E FEEDWATER NOZZLE AT 240 CW, CCW, 50"/60" Examined from shell side only due to blend radii Axial 60" longitudinal

-75%DERN E Downstream limiting nozzle side scan. Circ 50" shear- 75% Yes DEGREES Examined from shell side only due to blend radii NOZZLE TO SHELL WELD 12" limiting nozzle side scan.100290 RPV1-N4F FEEDWATER NOZZLE AT 270 CW, CCW, 50"160' Axial 60" longitudinal

-71% Yes DEGREES Downstream Weld pad from nozzle N11D extended from toe of Circ 50 shear- 71%weld back 25 inches. Exam was limited from 91 to 110 inches circumferentially.

Strt. Beam Planar- 100%NOZZLE TO SHELL WELD 10"CORE 0 to material Strt. Beam Laminar -64.7%100295 RPV1-N5A CW, CCW, 0"/45"/60" 45°/60' exams performed from vessel shell side only Parallel 45" -50%SPRAY INLET AT 120 DEG Downstream due to nozzle configuration.

Parallel 60" -50% No Transverse 45" -100%Transverse 60" -100%

Attachment 1 LR-N09-0029 Page 5 of 21 Table 2.2-1 Sum# Camp ID Description Scan Scan Comments Technique Qualified Direction Angle Coverage Strt. Beam Planar- 100%NE 0 to material Strt. Beam Laminar -64.7%100300 RPV1-N5B SPRAYE TONHELLWETLT 240DEG 0 0 45°/60' exams performed from vessel shell side only Parallel 45' -50%Do-P N A Dw,/ due to nozzle configuration.

Parallel 60' -50% No Downatream dTransverse 45' -100%Transverse 600 -100%100320 RPV1-N8A NOZZLE TO SHELL 4" JET PUMP CW, CCW, 50o/60o Examined from shell side only due to blend radii Axial 600 longitudinal

-75Ye INSTRUMENTATION AT 105 DEGREES Upstream limiting nozzle side scan. Circ 50° shear- 75%100325 RPV1-N8B NOZZLE TO SHELL 4" JET PUMP CW, CCW, 50o/60o Examined from shell side only due to blend radii Axial 60a longitudinal

-75% Yes INSTRUMENTATION AT 285 DEGREES Upstream limiting nozzle side scan. Circ 50' shear- 75%Strt. Beam Planar -100%NOZZLE TO SHELL WELD 4" CRD 0 to material Strt. Beam Laminar -64.7%45°/60° exams performed from vessel shell side only Parallel 450 -50%100330 RPV1-N9A HYDRAULIC RETURN AT 146 CW, CCW, 00/45°/60° due to nozzle configuration.

Parallel 60' -50% No DEGREES DownstreamTrnve45 10 Transverse 45' -100%Transverse 60° -100%100400 RPV1-N17A NOZZLE TO SHELL 12" LPCI AT 45 CW, CCW, 50o/60o Examined from shell side only due to blend radii Axial 600 longitudinal

-75Yes DEG Downstream limiting nozzle side scan. Circ 50° shear- 75%100401 RPV1-N17B NOZZLE TO SHELL 12" LPCI AT 135 CW, CCW, 50o/600 Examined from shell side only due to blend radii Axial 60' longitudinal

-75Yes DEG Downstream limiting nozzle side scan. Circ 50° shear- 75%100403 RPV1-N17D NOZZLE TO SHELL 12" LPCI AT 315 CW, CCW, 500/60o Examined from shell side only due to blend radii Axial 600 longitudinal

-75Yes DEG Downstream limiting nozzle side scan. Circ 50' shear- 75% Y 100404 RPV1-N6A NOZZLE TO HEAD 6" HEAD SPRAY CW, CCW, 50o/60o Examined from shell side only due to blend radii Axial 600 longitudinal

-75Yes NOZZLE Downstream limiting nozzle side scan. Circ 50' shear- 75%100405 RPV1-N6B NOZZLE TO HEAD 6" SPARE HEAD CW, CCW, 50o/60o Examined from shell side only due to blend radii Axial 600 longitudinal

-75Yes NOZZLE Downstream

.limiting nozzle side scan. Circ 50' shear- 75%100406 RPV1-N7 NOZZLE TO HEAD 4" VENT NOZZLE CW, CCW, 50o/60o Examined from shell side only due to blend radii Axial 600 longitudinal

-75% Yes I Downstream limiting nozzle side scan. Circ 50° shear- 75%

Attachment 1 LR-N09-0029 Page 6 of 21 2.3 HC-12-RR-25 (Part C). ASME Code, Section Xl, Examination Category B-G-1, Item B6.40, Reactor Vessel Flange Ligament The licensee has included, as Figure 6, a sketch depicting areas of limited scanning.However, insufficient text is provided in order to make use of the drawing. In order to demonstrate impracticality, submit a full written description of how the cladding prevented manual scanning and describe whether smaller diameter search units could be used to scan the ASME Code required area to increase coverage.Response: The 1/4-inch drop/step from the lip of the cladding seal surface allows a 3/8-inch land area between the stud hole and the cladding raised seal surface, preventing the transducer from accessing the limited area shown on Reference 1 Figure 6. The examination was performed under a non-PDI procedure and a smaller transducer was not considered at the time of the examination.

Smaller transducers will be considered for future examinations to gain more information on the ligament land area between the cladding lip and stud hole. To date, PSEG is unaware of any instance of rejectable indications being found as a result of ASME ligament examinations required by category B-G-1 Item 6.40 2.4 HC-12-RR-25 (Part D), ASME Code, Section Xl, Examination Category B-J, Item B9.11. Pressure Retaining Welds in Piping NPS 4 inches and Larger The coverage sketches included in the licensee's submittal for all ASME Code,Section XI, Examination Category B-J piping welds are not adequate to fully describe impracticality.

a) Provide descriptions of the ultrasonic techniques deployed for each weld examination volume, and the amount of coverage obtained for each of these techniques.

Also, provide cross-sectional drawings showing scanning angle coverage obtained.

List the materials for the base metal and weld.Response: Descriptions of the ultrasonic techniques deployed for each weld examination volume, the amount of coverage obtained for each of these techniques and the materials for the base metal and weld, where available, are listed in Table 2.4-1 below. Profile sketches are provided in Figures 7 through 13 in Reference

1.

Attachment 1 LR-N09-0029 Page 7 of 21 Table 2.4-1 Sum# Comp ID Description Scan Scan Comments Technique Base metal /Direction Angle Coverage Weld CW, CCW, 45°/60° No examination from downstream side due to reducing tee Axial US -50% A-358 CL.1 304/105890 1-BB-28VCA PIPE TO REDUCING TEE Downstream configuration.

Circumferential scans (clockwise

& counter- Axial DS -50%013-6-R2 clockwise) were limited to upstream side only. Circ CW -50% A-403 WP304 Circ CCW -50%CW, CCW 45' Examination limited to clockwise and counter-clockwise scanning Axial US -0% Carbon steel 108105 1-BC-6DBA-VALVE TO FLNGE due to configuration of valve and flange. Axial DS -0%003-21 Circ CW -66.67%Circ CCW -66.67%CW, CCW, 45°/60' Examination limited to the upstream side of the weld by the weld Axial US -60.4% SA-358 CL.1 304L /109170 1-BC-12CCA-PIPE TO REDUCING TEE Upstream, and tee configuration.

Axial DS -60.4% Root SFA-5.9 ER308L /116-5 Downstream Circ CW -100% A-403 WP304 Circ CCW -100%CW, CCW, 45°/70° No examination on the upstream side due to weldolet Axial US -50% A-182 F304 /110200 1-BG-4CCA-WELDOLET TO PIPE Upstream configuration.

Axial DS -50% Root SFA-5.9 ER308L /012-1 Circ CW -50% SA-312 TP304L Circ CCW -50%CW, CCW, 45°/70' No examination on the upstream side due to weldolet Axial US -50.48% A-182 F304 /110230 1-BG-4CCA-WELDOLETTO PIPE Upstream configuration.

Axial DS -50.48% Root SFA-5.9 ER308L /011-1 Circ CW -50.48% SA-312 TP304L Circ CCW -50.48%CW, CCW, 45°/70° 45° shear wave examination was limited due to sock-o-let location Axial US -52.50% SA-106 Grade B I 110432 -A PIPE TO FLOW ELEMENT Upstream, in both directions.

70' shear wave exam was limited due to weld Axial DS -52.50% ERNiCr-3 ENICrFe-3 I 003-7A -Downstream crown configuration.

Circ CW -89.20% SA-182 Grade F304L Circ CCW -89.20%CW, CCW, 45°/70° 70' shear wave exam was limited due to weld crown configuration.

Axial US -52.50% SA-182 Grade F304 /110433 1-FC-4DBA-FLOW ELEMENT TO PIPE Upstream, 45' covered circ scan 100%. Axial DS -52.50% ERNiCr-3 ENICrFe-3 I 003-7B Downstream Circ CW -100% SA-106 Grade B Circ CCW -100%CW, CCW, 45°/70° No exam downstream due to welded pipe support on pipe side of Axial US -65.03% Carbon steel Upstream, weld joint, upstream edge of limitation was positioned on upstream Axial DS -0%1-FC-4DBA-weld toe and extended downstream past downstream weld toe Circ CW -19.58%110475 003-16 ELBOW TO PIPE preventing any downstream examination.

Circ CCW -19.58%Magnetic particle exam was performed and limited to 51.846%coverage with no recordable indications.

Attachment 1 LR-N09-0029 Page 8 of 21 b) As applicable, describe nondestructive examination (NDE) equipment, show accessibility limitations, and discuss whether alternative methods or advanced technologies such as phased array could be employed to maximize ASME Code coverage.Response: The limited examinations were completed using manual techniques.

The accessibility limitations are discussed in the table above. As new ultrasonic techniques and tooling are qualified to ASME Section XI, Appendix VIII, PSEG reviews the new tooling and techniques to maximize the inspection coverage.c) Clarify whether the methods used have been qualified in accordance with performance demonstration requirements per ASME Code,Section XI, Appendix VIII.Response: The methods used were qualified in accordance with performance demonstration requirements per ASME Code,Section XI, Appendix VIII.2.5 HC-12-RR-25 (Part E), ASME Code, Section Xl, Examination Category C-G, C6.10, Pump Casing Welds 2.5.1 The licensee's current submittal includes a request for limited surface examination coverage of Core Spray Pump Casing Weld CP-206-CSP-W2.

This weld was previously submitted for the second interval in RR-C1, Part C, and evaluated in an NRC SE dated February 3, 2000. Based on the licensee's statements, it appears that only 23.4 percent of the required surface coverage was actually completed as opposed to the 73 percent originally stated in RR-C1, Part C. Please confirm that the current request is intended to correct the originally stated surface coverage, the basis for limited coverage remains the same as previously stated, and that any commitments made in RR-C1, Part C remain in place.Response: The current request is intended to correct the originally stated surface coverage.

The basis for limited coverage remains the same as previously stated. No commitments were made in connection with RR-C1, Part C.2.5.2 The drawing of the Core Spray Pump included as Figure 19 in the licensee's submittal, does not adequately demonstrate limited accessibility for surface examination of Weld CP-206-CSP-W2.

In this drawing, it appears that access to the weld may be sufficient for performing outside surface examination.

Please submit further information to demonstrate the inaccessibility, and show the areas where limited coverage has been obtained.Response: Photographs showing the limited accessibility between the concrete pedestal and core spray pump CP-206 casing are provided in Figures 2.5.2-1 and 2.5.2-2.

Attachment 1 LR-N09-0029 Page 9 of 21 2.6 Request for Relief HC-12-RR-25 (Part F). ASME Code,Section XI. Examination Category R-A, Risk Informed Piping Examinations 2.6.1 The licensee has provided three drawings that show the coverage obtained for the subject examinations.

However, insufficient text is included to describe the conditions that limit ultrasonic scanning in the circumferential directions.

Please submit further written description to demonstrate impracticality.

In addition, describe the ultrasonic techniques employed; it is unclear whether the examinations were performed using longitudinal and/or shear wave techniques.

Response: The ultrasonic techniques employed are described in Table 2.6-1 below. All angled scans were performed using shear mode.

Attachment 1 LR-N09-0029 Page 10 of 21 Table 2.6.1-1 Sum# Comp ID Description Scan Scan Comment Technique Direction Angle Coverage Downstream, 45°/60'/70' Downstream access only. No examination performed upstream due to the Axial US -0%CW, CCW configuration of the branch connection.

Axial DS -100%1 -BB-4VCA-Circ CW -US 0%105585 011-1-RI BRANCH CONNECTION TO PIPE Circ CW -DS 100%Circ CCW -US 0%Circ CCW -DS 100%Downstream, 45°/60°/70° Downstream access only. No examination performed upstream due to the Axial US -0%CW, CCW configuration of the branch connection.

Axial DS -100%105790 1-BB-4VCA-BRANCH CONNECTION TO PIPE Circ. CW -US 0%012-1-Ri Circ. CW -DS 100%Circ CW -US 0%Circ CCW -DS 100%Upstream, CW, 45° No exam performed from downstream due to configuration of valve and weld crown. Axial from US -89.22%1-BG-6DBA-CCW Axial from DS -0%109810 001-29 PIPE TO VALVE Circ CW- 71.53%Circ CCW -71.53%

Attachment 1 LR-N09-0029 Page 11 of 21 2.6.2 Also, clarify whether any other welds could have been substituted and examined instead of Welds 1-BB-4VCA-011-1-Ri, 1-BB-4VCA-011(2)-1-R1, and 1-BG-6DBA-001-29.

If no other welds could have been examined; please explain why.Response: As noted in Reference 1 Table 1, the examinations for 1 -BB-4VCA-011 R1 and 1 -BB-4VCA-012-1-Ri were both pre-service examinations.

Therefore, no other welds could have been examined.1-BG-6DBA-001-29 is in a risk segment with two other welds. All welds in the segment have been selected; therefore, no other welds are available for selection.

2.6.3 In addition to the bases for impracticality, state whether any outside diameter surface feature, such as weld crown, diametrical weld shrinkage, or surface roughness conditions caused limited volumetric coverage during the subject piping weld examinations.

Discuss the efforts that were used to correct these conditions.

Response: The weld crown on 1-BG-6DBA-001-29 caused some limitation in volumetric coverage.However, flat topping the pipe to valve weld crown would not provide significantly better coverage, as the valve body taper will still lift the shoe in the limited area.2.6.4 Clarify whether the methods used to examine the subject piping weld have been qualified in accordance with performance demonstration requirements per ASME Code,Section XI, Appendix VIII.Response: The methods used to examine the subject piping weld have been qualified in accordance with performance demonstration requirements per ASME Code, Section Xl, Appendix VIII.References 1 .Letter from Jeffrie Keenan (PSEG Nuclear LLC) to USNRC, "Submittal of Relief Request Associated with the Second Inservice Inspection (ISI) Interval," dated December 11, 2008 Attachment 1 LR-N09-0029 Page 12 of 21 Figure 2.1.3-1 Limitation Due to Reactor Vessel Closure Head to Flange Configuration 12.5 3,2" 601p 6Q"TIP WAJ Attachment 1 LR-N09-0029 Page 13 of 21 Figure 2.2-1 D E RECIRCULATION INLET NOZZLE N2 SCAN TRANSVERSE IN ONE OECTION ONLY Attachment 1 LR-N09-0029 Page 14of21 Figure 2.2-2 D FEEDWATER NOZZLE ASSEMBLY N4 LIMiATION IDUE TO NOZZLE GEOkEW SCk~NN TRANVERSE IN ONE DIRCTION ONLY Attachment 1 LR-N09-0029 Page 15 of 21 Figure 2.2-3 HI CORE SPRAY NOZZLE N5-LIMITED OLE TO NMZI EGEOMETR(SCAPOOJE TPANSVERSE IN ONE DWECTION ON-Y Attachment 1 LR-N09-0029 Page 16 of 21 Figure 2.2-4 D HEAD SPRAY NOZZLE ASSEMBLY N6A Attachment 1 LR-N09-0029 Page 17 of 21 Figure 2.2-5 E F GH VENT NOZZLE ASSEMBLY N7 Attachment 1 LR-N09-0029 Page 18 of 21 Figure 2.2-6 I).2 r~ =CONTROL ROD DRIVE AND SYSTEM RETURN NOZZLE N9 JET PUMP INSTRUMENTATION NOZZLE N8 Attachment 1 LR-N09-0029 Page 19 of 21 Figure 2.2-7 N I/!ASSEMBLY DETAIL LPCI NOZZLE N17 Attachment 1 LR-N09-0029 Page 20 of 21 Figure 2.5.2-1 CP206 Attachment 1 LR-N09-0029 Page 21 of 21 Figure 2.5.2-2 P.::9lnr