Text

SE for Relief Requests 1A, 14A and 15A Associated with Volumetric Coverage of Weld Examinations
	ML063420372
Person / Time
Site:	Turkey Point
Issue date:	12/21/2006
From:	Pickett D; NRC/NRR/ADRO/DORL/LPLII-2
To:	Stall J; Florida Power & Light Co
	Moroney B, NRR/DORL, 415-3974
References
	TAC MD0205, TAC MD0206
	Download: ML063420372 (21)
	v • d • e

December 21, 2006Mr. J. A. StallSenior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT UNITS 3 AND 4 - SAFETY EVALUATION FOR RELIEFREQUESTS 1A, 14A AND 15A ASSOCIATED WITH VOLUMETRIC COVERAGE OF WELD EXAMINATIONS (TAC NOS. MD0205 AND MD0206)

Dear Mr. Stall:

By letter dated February 20, 2006, as supplemented by letter dated July 14, 2006, FloridaPower and Light Company (the licensee), submitted revised Relief Requests 1A, 14A, and 15A, for the third 10-year inservice inspection (ISI) intervals at Turkey Point, Units 3 and 4, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g)(5)(iii). The requestsfor relief pertained to the amount of coverage obtained during specific examinations compared to the coverage required by the American Society of Mechanical Engineers (ASME) Code.Based on review of the submittals, the U.S. Nuclear Regulatory Commission (NRC) staffconcluded that compliance with the ASME Code coverage requirements is impractical for the configurations identified in the subject relief requests, and that compliance with the specified requirements would result in a significant burden on the licensee. The NRC staff also concluded that the examination coverages obtained by the licensee provide reasonable assurance of the structural integrity of the affected components. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for the third 10-year ISI interval at Turkey Point Unit 3, which began February 22, 1994, and ended February 21, 2005, and for the third 10-year ISI interval at Turkey Point Unit 4, which began April 15, 1994, and ended April 14, 2005. Sincerely, /RA/Douglas V. Pickett, Acting ChiefPlant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-250 and 50-251

Enclosure:

Safety Evaluation cc w/encl: See next page

ML063420372NRR-028OFFICELPL2-2/PMLPL2-2/LA CPNB/BCOGCLPL2-2/BC(A)NAMEBMoroneyBClaytonTChanby memo datedJMartin "NLO w/edits"DPickettDATE 12/19/0612/19/06 11/07/06 12/20/0612/21/06 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONINSERVICE INSPECTION PROGRAMRELIEF REQUEST NOS. 1A, 14A AND 15AFLORIDA POWER AND LIGHT COMPANYTURKEY POINT NUCLEAR PLANT UNITS 3 AND 4DOCKET NOS. 50-250 AND 25

11.0 INTRODUCTION

By letter dated February 20, 2006 (Agencywide Documents Access and Management System(ADAMS) Accession Number ML060520631), as supplemented by letter dated July 14, 2006 (ADAMS Accession Number ML061990015), Florida Power and Light Company (the licensee),

submitted revised Relief Requests 1A, 14A, and 15A, for the third 10-year inservice inspection (ISI) intervals at Turkey Point, Units 3 and 4, pursuant to Title 10 of the Code of FederalRegulations (10 CFR), Section 50.55a(g)(5)(iii). The requests for relief pertained to the amountof coverage obtained during specific examinations conducted during the third 10-year ISI intervals compared to the coverage required by the American Society of Mechanical Engineers (ASME) Code.

2.0REGULATORY EVALUATION

The ISI of the ASME Code Class 1, 2, and 3 components is to be performed in accordance withthe ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power PlantComponents," and applicable edition and addenda as required by the10 CFR 50.55a(g), exceptwhen specific relief has been granted by the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.55a(g)(6)(i). As stated in 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the applicant demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (includingsupports) will meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ISI Code of record for Turkey Point Units 3 and 4 for the third 10-year ISI interval is the ASME Code,Section XI,1989 Edition, No Addenda. Pursuant to 10 CFR 50.55a(g)(5)(iii), if the licensee has determined that conformance withcertain code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in Section 50.4, information to support the determination. Pursuant to 10 CFR 50.55a(g)(5)(iv) where an examination requirement by the code oraddenda is determined to be impractical by the licensee and is not included in the revised ISI program as permitted by 10 CFR 50.55a(g)(4), the basis for this determination must be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. The third 10-year ISI interval at Turkey Point Unit 3 began February 22, 1994, and ended February 21, 2005. The third 10-year ISI interval at Turkey Point Unit 4 began April 15, 1994, and ended April 14, 2005. For both units, the third 10-year interval was extended by one year as allowed by Paragraph IWA-2430 of the ASME Code,Section XI, 1989 Edition, No Addenda.Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission will evaluate determinations under10 CFR 50.55a(g)(5) that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

3.0TECHNICAL EVALUATION

3.1System/Component(s) for Which Relief is RequestedRelief Request 1A: Class 1 pressure retaining welds in the reactor pressure vessel.

Relief Request 14A: Class 1 inner radius in vessels; Class 1 and 2 pressure retaining welds invessel and piping.Relief Request 15A: Class 1 inner radius in vessels; Class 1 and 2 pressure retaining welds invessel and piping.3.2.Applicable Code Requirements The ASME Boiler and Pressure Vessel Code, Rules for ISI of Nuclear Power PlantComponents,Section XI, 1989 Edition, No Addenda.3.3 Licensee's RequestPursuant to 10 CFR 50.55a(g)(5)(iii), the licensee has determined that conformance with certaincode requirements is impractical for its facility. Specifically, the licensee has submitted threerequests for relief addressing the inability to achieve required code volume coverage during examinations due to the components configuration and/or the presence of permanent

attachments. Relief Request 1A requests relief from the requirements listed below:ExaminationCategoryItem No.ComponentExamination RequirementB-AB1.213-WR-9; 4-WR-9Essentially 100% volumetric examination of allcircumferential head welds.B-AB1.303-WR-18; 4-WR-18Essentially 100% volumetric examination of the shell toflange weld.B-G-1B6.403-Lig-1 thru 58; 4-Lig-1 thru 58Essentially 100% volumetric examination of the 1 inchannular volume of flange surrounding each stud holeRelief Request 14A requests relief from the requirements listed below:Examination CategoryItem No.ComponentExamination RequirementB-DB3.120 B3.140Spray Nozzle-SP-03-1-IR3-SRGN-01-IR

3-SGA-I-IRS

3-SGA-O-IRS

3-SGB-I-IRS

3-SGB-O-IRS 3-SGC-I-IRS 3-SGC-O-IRSEssentially 100% volumetric examination of thenozzle inner radius sectionB-FB5.7029"-RCS-1305-429"-RCS-1308-4 31"-RCS-1302-5 31"-RCS-1303-5Essentially 100% volumetric and surfaceexamination of nozzle to safe end butt welds NPS

4 or largerB-JB9.114"-RC-1304-184"-RC-1304-20 4"-RC-1305-1

8"RHR-1301-3

8"-RHR-1304-8

8"-RHR-1305-2A

8"-RHR-1305-3

10"-SI-1302-1

10"-SI-1302-4

10"-SI-1303-11

10"-SI-1303-15 12"-RCS-1301-1

14"-RHR-1301-6 27.5"-RCS-1306-11 27.5"-RCS-1309-11 29"-RCS-1305-3 31"-RCS-1302-10 31"-RCS-1303-10 31"-RCS-1303-7Essentially 100% volumetric and surfaceexamination of circumferential welds NPS 4 or

largerB-JB9.3127.5"-RCS-1306-4 27.5"-RCS-1307-2 27.5-RCS-1309-3 29"-RCS-1305-BC3 29"-RCS-1308-BC-1Essentially 100% volumetric and surfaceexamination of branch pipe connection welds NPS 4 or larger ExaminationCategoryItem No.ComponentExamination RequirementC-AC1.10C1.203-RHE-A23-RHE-A1Essentially 100% volumetric examination of theshell circumferential weldsC-F-1C5.118"-SI-2303-1 10"-SI-2304-3

14"-RHR-2301-1Essentially 100% volumetric and surfaceexamination of circumferential piping welds 3/8"nominal wall thickness for piping > NPS 4C-F-1C5.213"-SI-2301-1 3"-SI-2301-4Essentially 100% volumetric and surfaceexamination of circumferential piping welds >1/5" nominal wall thickness for piping NPS 2 and NPS 4C-F-2C5.516"-BDC-2303-66"-BDA-2301-8Essentially 100% volumetric and surfaceexamination of circumferential piping welds 3/8"nominal wall thickness for piping > NPS 4Relief Request 15A requests relief from the requirements listed below:Examination CategoryItem No.ComponentExamination RequirementB-DB3.140 B3.120 4-SGA-I-IRS 4-SGA-O-IRS

4-SGB-I-IRS

4-SGB-O-IRS 4-SGC-I-IRS 4-SGC-O-IRS

SP-04-1-IR 4-SRGN-01-1REssentially 100% volumetric examination of thenozzle inner radius sectionB-FB5.7012"-RC-1401-929"-RCS-1404-4 29"-RCS-1405-4 31"-RCS-1401-5 31"-RCS-1402-5Essentially 100% volumetric and surfaceexamination of nozzle to safe end butt welds NPS

4 or largerB-JB9.118"-RHR-1401-6 8"-RHR-1402-4

8"-RHR-1402-7

10"-SI-1401-14

10"-SI-1401-18

10"-SI-1402-1

10"-SI-1402-13

10"-SI-1402-17

10"-SI-1402-4 12"-RC-1401-1

14"-RHR-1401-1

14"-RHR-1401-5

14"-RHR-1401-6

14"-RHR-1401-9 27.5"-RCS-1406-11 27.5"-RCS-1407-11 31"-RCS-1401-10 31"-RCS-1401-8Essentially 100% volumetric and surfaceexamination of circumferential welds NPS 4 or

larger ExaminationCategoryItem No.ComponentExamination RequirementB-JB9.3127.5"-RCS-1406-1827.5"-RCS-1407-20 27.5"-RCS-1409-16 27.5"-RCS-1409-17 29"-RCS-1404-18 29"-RCS-1405-21Essentially 100% volumetric and surfaceexamination of branch pipe connection welds NPS

4 or largerC-AC1.10C1.204-RHE-A24-RHE-A1Essentially 100% volumetric examination of theshell circumferential weldsC-BC2.214-RHE-A11Essentially 100% volumetric and surfaceexamination of the nozzle to vessel welds.C-F-1C5.118"-SI-2403-17 8"-SI-2404-2

8"-SI-2407-8

10"-SI-2407-4

10"-SI-2407-5

12"-RHR-2402-15

14"-RHR-2403-1

14"-RHR-2403-2

14"-RHR-2403-4Essentially 100% volumetric and surfaceexamination of circumferential piping welds 3/8"nominal wall thickness for piping > NPS 4C-F-1C5.213"-SI-2401-1Essentially 100% volumetric and surfaceexamination of circumferential piping welds >1/5" nominal wall thickness for piping NPS 2 and NPS 43.4Code Requirements for Which Relief is Requested3.4.1Relief Request 1AThe 1989 Edition of ASME Code,Section XI, Code Categories B-A and B-G-1,Figures IWB-2500-3, -4, -12 require a volumetric examination which includes 100 percent of the weld length, once during the 10-year interval. Code Category B-G-1, Figure IWB-2500-12, requires a volumetric examination of the threaded region in the reactor vessel flange, once during the 10-year interval.3.4.2Relief Request 14AThe 1989 Edition of ASME Code,Section XI, Code Categories B-D, B-F, B-J, C-A, C-F-1, and C-F-2, Figures IWB- 2500-7, -8, -10, and Figures IWC-2500-1, -7 require a volumetric examination which includes 100 percent of the weld length, once during the 10-year interval. 3.4.3Relief Request 15AThe 1989 Edition of ASME Code,Section XI, Code Categories B-D, B-F, B-J, C-A, C-B,and C-F-1 Figures IWB- 2500-7, -8, -10, and Figures IWC-2500-1, -4, -7 require a volumetric examination which includes 100 percent of the weld length, once during the10-year interval. 3.5 Licensee's Proposed Alternative to Code3.5.1Relief Request 1AThe licensee proposed the following alternatives:

1) Periodic system pressure tests in accordance with ASME Section XI Category B-P,Table IWB-2500-1.2) Conduct ultrasonic examinations to the maximum extent possible3.5.2Relief Request 14AThe licensee proposed the following alternatives:

1) Surface examination per category B-F, B-J, C-F-1, and C-F-2.

2) Conduct ultrasonic examinations to the maximum extent possible.

3) Periodic system pressure tests in accordance with ASME Section XI Category B-P,Table IWB-2500-1 and Category C-H, Table IWC-2500-1.3.5.3Relief Request 15AThe licensee proposed the following alternatives:

1) Surface examination per category B-F, B-J, C-B, and C-F-1.

2) Conduct ultrasonic examinations to the maximum extent possible.

3) Periodic system pressure tests in accordance with ASME Section XI Category B-P,Table IWB-2500-1 and Category C-H, Table IWC-2500-1.3.6 Licensee's Basis for Relief3.6.1Relief Request 1AThe licensee stated that due to the configuration of the reactor vessel, it is impractical tomeet the examination coverage requirements. The welds or surfaces did not receive the required code volume coverage due to their configuration and/or the presence of permanent attachments. Examination of welds 3-WR-9 and 4-WR-9 were limited due to the close proximity of the instrument tubes. Examination of welds 3-WR-18 and 4-WR-18 were limited due to the keyways and irradiation slots. Examination of the reactor pressure vessel threads in the flange were limited due to the o-ring groove machined into the flange surface, limiting the area for transducer placement for the examination. For the welds and surfaces listed, it was not possible to remove the obstruction/interference without significant work, increased radiation exposure, and/ordamage to the plant.3.6.2Relief Request 14AThe licensee stated that due to the configuration and/or the presence of permanentattachments, essentially 100 percent ultrasonic examination coverage of the required examination volume could not be obtained. Pursuant to the requirements of 10 CFR 50.55a(g)(5)(iii), the licensee seeks relief from performing the 100-percent volumetric examination requirements of the ASME Code. For the welds identified, it was not possible to remove the obstruction without significant work, increased radiation exposure, and/or damage to the plant. Additional weld preparation by welding or metal removal is a modification of the examination area requiring significant engineering and construction personnel support. Increased radiation exposure and cost would be incurred in order to perform these modifications. For Category B-F, the Class 1 dissimilar metal piping welds have carbon steel nozzlesbuttered with stainless steel and field welded to forged stainless steel or cast stainlesssteel components with stainless steel weld material.Radiography was considered impractical due to the amount of work being performed inthe areas on a 24-hour basis. This would result in numerous work-related stoppages and increased exposure due to the shutdown and startup of other work in the areas.

The water must be drained from systems where radiography is performed, which increases the radiation dose rates over a much broader area than the weld being examined. The licensee listed the approximate coverages that were obtained for the welds. No reportable indications were noted by the licensee.3.6.3Relief Request 15AThe licensee stated that due to the configuration and/or the presence of permanentattachments, essentially 100 percent ultrasonic examination coverage of the required examination volume could not be obtained. Pursuant to the requirements of 10 CFR 50.55a(g)(5)(iii), the licensee seeks relief from performing the 100-percent volumetric examination requirements of the ASME Code. For the welds identified, it was not possible to remove the obstruction without significant work, increased radiation exposure, and/or damage to the plant. Additional weld preparation by welding or metal removal is a modification of the examination area requiring significant engineering and construction personnel support. Increased radiation exposure and cost would be incurred in order to perform these modifications. For Category B-F, the Class 1 dissimilar metal piping welds have carbon steel nozzlesbuttered with stainless steel and field welded to forged stainless steel or cast stainlesssteel components with stainless steel weld material.Radiography was considered impractical due to the amount of work being performed in the areas on a 24-hour basis. This would result in numerous work-related stoppages and increased exposure due to the shutdown and startup of other work in the areas.

The water must be drained from systems where radiography is performed, which increases the radiation dose rates over a much broader area than the weld beingexamined. The licensee listed the approximate coverages that were obtained for the welds. No reportable indications were noted by the licensee.3.7EvaluationThe ISI Code of record for Turkey Point Units 3 and 4 is the1989 Edition of the ASMEBoiler and Pressure Vessel Code,Section XI. Table IWB-2500-1, Code Categories B-A, B-D, B-F, B-J, and Table IWC-2500-1, Code Categories C-A, C-B, C-F-1, and C-F-2 require a volumetric examination which includes 100 percent of the weld length, once during the 10-year interval. The examination volume is defined in Figures IWB-2500-3, 4, 7(d), 8, 10, 12, IWC-2500-1, 4(a), 7(a). ASME Section XI, Table IWB-2500-1, Code Category B-G-1 requires 100 percentvolumetric examination of the 1 inch annular volume of flange surrounding each reactor vessel stud, once during the 10-year interval. The examination volume is defined in Figure IWB-2500-12. ASME Section XI, Table IWB-2500-1, Code Categories B-F, B-J, and Table IWC-2500-1Code Categories C-B, C-F-1, and C-F-2 also require surface examination of the welds, in addition to the volumetric examination. The examination surface is defined in Figures IWB-2500-8, and 10, and Figures IWC-2500-4(a), and 7(a). All surface examinations were completed with no limitations. No recordable or reportable flaws were detected. The staff's review of the data submitted for the subject welds regarding the inspectionvolumes found that obstructions to limit complete coverages were present by the design of the components. Specifically, either (1) the proximity of another component(s) limited access to the welds requiring examination or (2) the configuration of the component or weld crown limited movement and/or coupling of the ultrasonic transducer to the scanning surface. The coverage limitations and inspection results for each component are listed in the tables below. Relief Request 1A limitations and results:Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications (Yes/No)3-WR-9B-A/B1.21IWB-2500-3 83% coverageLimited due to proximity of the instrumentation tubes No4-WR-9B-A/B1.21IWB-2500-3 83% coverageLimited due to proximity of the instrumentation tubes No3-WR-18B-A/B1.30IWB-2500-4 71% coverageLimited due to the key ways and irradiation slots No Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications (Yes/No)4-WR-18B-A/B1.30IWB-2500-4 71% coverageLimited due to the key ways and irradiation slots No3-Lig-1 thru 58B-G-1/B6.40IWB-2500-12 84.67% coverageReactor vessel o-ring sealingsurface - Inadequate width for

transducer.

No4-Lig-1 thru 58B-G-1/B6.40IWB-2500-12 84.67% coverageReactor vessel o-ring sealingsurface - Inadequate width for

transducer.

NoRelief Request 14A limitations and results:Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications (Yes/No)Spray Nozzle-SP-03-1-IR B-D/B3.120IWB-2500-7(d) 70% CoverageConfiguration and raised letterswelded in examination zone No3-SRGN-01-IRB-D/B3.120IWB-2500-7(d) 55% CoveragePressurizer heaters penetrationsNo3-SGA-I-IRSB-D/B3.140IWB-2500-7(d) 70% CoverageWelded pads, supports,insulation pins, and Inner Radius

configuration No3-SGA-O-IRSB-D/B3.140IWB-2500-7(d) 70% CoverageWelded pads, supports,insulation pins, and Inner Radius

configuration No3-SGB-I-IRSB-D/B3.140IWB-2500-7(d) 70% CoverageWelded pads, supports,insulation pins, and Inner Radius

configuration No3-SGB-O-IRSB-D/B3.140IWB-2500-7(d) 70% CoverageWelded pads, supports,insulation pins, and Inner Radius

configuration No3-SGC-I-IRSB-D/B3.140IWB-2500-7(d) 70% CoverageWelded pads, supports,insulation pins, and Inner Radius

configuration No3-SGC-O-IRSB-D/B3.140IWB-2500-7(d) 70% CoverageWelded pads, supports,insulation pins, and Inner Radius

configuration No29"-RCS-1305-4B-F/B5.70IWB-2500-8 43% from elbow side 2% from nozzle sideLimited from elbow side due toweld crown. Limited from nozzle side due to taper on nozzle No Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications (Yes/No)29"-RCS-1308-4B-F/B5.70IWB-2500-8 47% from elbow side 0% from nozzle sideLimited from elbow side due toweld crown. Limited from nozzle side due to taper on nozzle No31"-RCS-1302-5B-F/B5.70IWB-2500-8 75% from elbow side 0% from nozzle sideLimited from elbow side due toweld crown. Limited from nozzle side due to taper on nozzle No31"-RCS-1303-5B-F/B5.70IWB-2500-8 62% from elbow side 0% from nozzle sideLimited from elbow side due toweld crown. Limited from nozzle side due to taper on nozzle No4"-RC-1304-18B-J/B9.11IWB-2500-8 82% coverage Limited due to radius on elbow and tee.

No4"-RC-1304-20B-J/B9.11IWB-2500-8 82% coverage Limited on both sides due to tee radius.No4"-RC-1305-1B-J/B9.11IWB-2500-8

87% from Branch

81% from Elbow Limited due to branch connectionand weld crown.

No8"RHR-1301-3B-J/B9.11IWB-2500-8

100% from Elbow 39% from valveLimited on valve side due to taper.No8"-RHR-1304-8B-J/B9.11IWB-2500-8

67% from pipe 55% from Tee Limited from pipe side due toweld crown and tee side due to

radius.No8"-RHR-1305-2AB-J/B9.11IWB-2500-8

70% each sideLimited due to weld crown.No8"-RHR-1305-3B-J/B9.11IWB-2500-8

67% from Pipe 99% from Tee Limited from pipe side due toweld crown and tee side due to

radius.No10"-SI-1302-1B-J/B9.11IWB-2500-8

100% from Elbow

85% from Branch Limited from branch side due to taper.No10"-SI-1302-4B-J/B9.11IWB-2500-8

85% from Elbow 25% from ValveLimited from elbow side due toweld crown and valve side due to

taper.No Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications (Yes/No)10"-SI-1303-11B-J/B9.11IWB-2500-8

100% from Elbow 4% from ValveLimited from valve side due to taper.No10"-SI-1303-15B-J/B9.11IWB-2500-8

100% from Pipe

66% from Branch Limited from branch connection side due to taper.

No12"-RCS-1301-1B-J/B9.11IWB-2500-8

100% from Pipe

67% from Branch Limited from branch connection side due to taper.

No14"-RHR-1301-6B-J/B9.11IWB-2500-8

86% from Pipe 8% from Valve Limited from pipe side due toweld crown and valve side due to

taper. No27.5"-RCS-1306-11B-J/B9.11IWB-2500-8

0% from Pump

100% from Pipe Limited on pump side due to taper.No27.5"-RCS-1309-11B-J/B9.11IWB-2500-8

0% from Pump

87% from Pipe Limited on pump side due totaper and pipe side due to weld crown.No29"-RCS-1305-3B-J/B9.11IWB-2500-8

93% from Pipe

69% from ElbowLimited from elbow side due to taper. Limited on pipe side due

to 18" branch connection.

No31"-RCS-1302-10B-J/B9.11IWB-2500-8

75% from Elbow

0% from PumpLimited from elbow due to weldcrown and pump side due to

taper.No31"-RCS-1303-10B-J/B9.11IWB-2500-8

56% from Elbow

0% from PumpLimited from elbow due to weldcrown and pump side due to

taper.No31"-RCS-1303-7B-J/B9.11IWB-2500-8

79% from Pipe

52% from ElbowLimited from pipe and elbow sidedue to weld crown.

No27.5"-RCS-1306-4 B-J/B9.31IWB-2500-10

100% from Branch

0% from Piping Limited from main loop piping side due to taper.

No Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications (Yes/No)27,5"-RCS-1307-2B-J/B9.31IWB-2500-10

100% from Branch

0% from Piping Limited from main loop piping side due to taper.

No27.5-RCS-1309-3B-J/B9.31IWB-2500-10

100% from Branch

0% from Piping Limited from main loop piping side due to taper.

No29"-RCS-1305-BC3B-J/B9.31IWB-2500-10

100% from Branch

0% from Piping Limited from main loop piping side due to taper.

No29"-RCS-1308-BC-1B-J/B9.31IWB-2500-10

100% from Branch

0% from Piping Limited from main loop piping side due to taper.

No3-RHE-A2C-A/C1.10IWC-2500-1

71% from Shell

100% from Flange Limited from the shell and flange side due to support integral attachment, welded attachments and nozzle reinforcement plate.

No3-RHE-A1C-A/C1.20IWC-2500-1 95% from Head

57% from Shell Limited from the head and shell side due to support integral attachment, welded attachments and nozzle reinforcement plate.

No8"-SI-2303-1C-F-1/C5.11IWC-2500-7(a)

62% from Pipe 50% from Reducer Limited from pipe side due toweld crown and reducer side due

to taper No10"-SI-2304-3C-F-1/C5.11IWC-2500-7(a)

91% from Pipe 8% from Valve Limited from pipe side due toweld crown and valve side due to

taper No14"-RHR-2301-1C-F-1/C5.11IWC-2500-7(a) 84% from Valve

94% from ElbowLimited from valve side due totaper and elbow side due to weld crown.No3"-SI-2301-1C-F-1/C5.21IWC-2500-7(a)

100% from Elbow

0% from Flange Limited from flange side due to taper.No3"-SI-2301-4C-F-1/C5.21IWC-2500-7(a)

100% from Pipe 0% from ValveLimited from valve side due to taper.No Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications (Yes/No)6"-BDC-2303-6C-F-2/C5.51IWC-2500-7(a) 0% from Valve

100% from PipeLimited from valve side due to taper.No6"-BDA-2301-8C-F-2/C5.51IWC-2500-7(a)

100% from Pipe 50% from WyeLimited from wye side due to taper.NoRelief Request 15A limitations and results:Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications4-SGA-I-IRSB-D/B3.140IWB-2500-7(d) 75% overageLimited by welded pads, supports, insulation pins, and

inner radius configuration No4-SGA-O-IRSB-D/B3.140IWB-2500-7(d) 75% coverageLimited by welded pads, supports, insulation pins, and

inner radius configuration No4-SGB-I-IRSB-D/B3.140IWB-2500-7(d) 75% coverageLimited by welded pads, supports, insulation pins, and

inner radius configuration No4-SGB-O-IRSB-D/B3.140IWB-2500-7(d) 75% coverageLimited by welded pads, supports, insulation pins, and

inner radius configuration No4-SGC-I-IRSB-D/B3.140IWB-2500-7(d) 75% coverageLimited by welded pads, supports, insulation pins, and

inner radius configuration No4-SGC-O-IRSB-D/B3.140IWB-2500-7(d) 75% coverageLimited by welded pads, supports, insulation pins, and

inner radius configuration NoSP-04-1-IRB-D/B3.120IWB-2500-7(d) 70% coverageLimited by configuration andraised letters welded in the examination zone.

No4-SRGN-01-1RB-D/B3.120IWB-2500-7(d) 55% coverageLimited by pressurizer heater penetrations No12"-RC-1401-9B-F/B5.70IWB-2500-8

100% from Safe End 74% from NozzleLimited from nozzle side due to taper.No Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications29"-RCS-1404-4B-F/B5.70IWB-2500-8

74% from Elbow 0% from NozzleLimited from elbow side due toweld crown and nozzle side due

to taper.No29"-RCS-1405-4B-F/B5.70IWB-2500-8

53% from Elbow 10% from NozzleLimited from elbow side due to weld crown and nozzle

side due to taper.

No31"-RCS-1401-5B-F/B5.70IWB-2500-8 0% from Nozzle

62% from ElbowLimited from elbow side due toweld crown and nozzle side due

to taper.No31"-RCS-1402-5B-F/B5.70IWB-2500-8 8% from Nozzle

42% from ElbowLimited from elbow side due toweld crown and nozzle side due

to taper.No8"-RHR-1401-6B-J/B9.11IWB-2500-8 20% from Valve

100% from ElbowLimited from valve side due to taper.No8"-RHR-1402-4B-J/B9.11IWB-2500-8

100% from Pipe 30% from Tee Limited from tee side due to taper.No8"-RHR-1402-7 B-J/B9.11IWB-2500-8 60% from upstream Tee 20% from downstream Tee Limited from both sides of tee due to radius.

No10"-SI-1401-14B-J/B9.11IWB-2500-8 26% from Valve

100% from PipeLimited from valve side due to taper.No10"-SI-1401-18B-J/B9.11IWB-2500-8

100% from Elbow

18% from Branch Limited from branch connection side due to taper.

No10"-SI-1402-1B-J/B9.11IWB-2500-8

100% from Elbow 26% from ValveLimited from valve side due to taper.No10"-SI-1402-13B-J/B9.11IWB-2500-8

100% from Pipe 23% from ValveLimited from valve side due to taper.No Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications10"-SI-1402-17B-J/B9.11IWB-2500-8

100% from Elbow

23% from Branch Limited from branch connection side due to taper.

No10"-SI-1402-4B-J/B9.11IWB-2500-8

100% from Elbow 11% from Tee Limited from tee side due to radius.No12"-RC-1401-1B-J/B9.11IWB-2500-8

36% from Branch

86% from Pipe Limited from branch connection and [Pipe] side due to taper.

No14"-RHR-1401-1B-J/B9.11IWB-2500-8

70% from Branch

35% from Elbow Limited from branch connectionand elbow side due to taper.

No14"-RHR-1401-5B-J/B9.11IWB-2500-8

100% from Pipe 0% from ValveLimited from valve side due to taper.No14"-RHR-1401-6B-J/B9.11IWB-2500-8 0% from Valve

100% from PipeLimited from valve side due to taper.No14"-RHR-1401-9B-J/B9.11IWB-2500-8

54% from Elbow

53% from Pipe Limited from pipe side and elbowside due to weld crown.

No27.5"-RCS-1406-11B-J/B9.11IWB-2500-8

0% from Pump

100% from Pipe Limited from pump side due to taper.No27.5"-RCS-1407-11B-J/B9.11IWB-2500-8

18% from Pump

41% from Pipe Limited from pump side due to taper and pipe side due to

instrumentation line.

No31"-RCS-1401-10B-J/B9.11IWB-2500-8

57% from Elbow

0% from PumpLimited from elbow side due toweld crown and taper and pump

side due to taper.

No31"-RCS-1401-8B-J/B9.11IWB-2500-8

64% from Elbow

88% from PipeLimited from elbow side due totaper and pipe side due to weld crown. No Component IDExam Category/Item No.Figure No.

Coverage ObtainedCoverage LimitationRecordable Indications27.5"-RCS-1406-18B-J/B9.31IWB-2500-10

100% from Branch