ML12081A119
| ML12081A119 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| 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. 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, 2012U.S. Nuclear Regulatory CommissionWashington, DC 20555-0001ATTENTION:SUBJECT:Document Control DeskR.E. Ginna Nuclear Power PlantDocket No. 50-244Additional Information Re: Fourth Interval Inservice Inspection ProgramRelief Requests Nos. ISI-02 and ISI-03(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 AdditionalInformation Re: Fourth Interval Inservice Inspection Program ReliefRequests Nos. ISI-02 and ISI-03 (TAC NOS. ME5248 and ME5249).(Agencywide Documents Access and Management System (ADAMS)Accession No. ML1 10880297)References:(2) Letter from T. Mogren, Ginna LLC, to NRC Document Control Desk,dated July 29, 2011, Subject: Response to Request for AdditionalInformation Re: Fourth Interval Inservice Inspection Program ReliefRequests Nos. ISI-02 and ISI-03 (ADAMS Accession No. ML11215A012)In Reference 1, The Nuclear Regulatory Commission requested additional information regardingthe R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) requested relief from impracticalexamination coverage requirements. The NRC staff reviewed the response provided inReference 2 and during subsequent conversations requested additional information to completethe review of Relief Request ISI-02 and ISI-03. The NRC questions and the correspondingGinna LLC responses are provided in the Enclosure 1. A list of regulatory commitmentsassociated 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 Mogrenfý041WPLN JC- J33cN60 /
Document Control DeskMarch 16, 2012Page 2Enclosures:(1) Additional Information Regarding Relief Request ISI-02 and 03(2) List of Regulatory Commitmentscc: W. M. Dean, NRCD. V. Pickett, NRCResident Inspector, NRC (Ginna LLC)
ENCLOSURE 1Additional Information Regarding Relief Request ISI-02 and ISI-03 Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 1 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244The 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 datedDecember 16, 2010, and July 29, 2011 and has determined that additional information is necessaryto 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 additional information (RAI) responseshow 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 correctlyshow 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 anglesused for these Dissimilar Metal (DM) weld examinations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 2 of 75Generic Coverage Illustration of NSE-3-R and NSE-4-RGeneric Coverage Illustration of NSE-3-R and NSE-4-R450 Axial Shear Wave Examination Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 3 of 75Generic Coverage Illustration of NSE-3-R and NSE-4-Ro The Code coverage claimed in RAI response, Attachment 1, is based on the 45RL, 60RLand the circ scans and is 40.5% for NSE-3R and 42% for NSE-4R. In the discussion onpage 14 of 20 of the RAI response, it states that reductions in claimed coverage were takendue to the surface condition of the components and inability to maintain contact during theexam. The percent reductions taken seem to be very arbitrary. How were theydetermined?Response:The reductions in coverage related to surface conditions which reduced the transducer'scontact efficiency were conservatively estimated based on the qualified examiner'sobservations during the execution of the examinations. These qualitative estimations were onlymade during the circumferential examinations while the transducer was on the as-ground weldsurface. These coverage limitations were determined by observing the ultrasonic signalspresent during the examination. Areas producing ultrasonic signals indicative of inadequatecontact were considered coverage limitations. The qualified examination procedure (PDI-UT-10, paragraph 5.3.3) requires that areas where inadequate ultrasonic contact is encounteredshall be documented as a limitation.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 4 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244o 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 anddocumenting examination limitations that impact full ultrasonic interrogation of the requiredinspection volume. Additionally, Figure 5 of the same procedure provides an examination flowchart which includes steps for evaluating the examination area and documenting limitations.o Performance demonstration initiative (PDI) PDI-UT-10 requires the surface condition to beeither machined or ground smooth to an RMS finish approximately 250 RMS. Why wasn'tthe surface condition corrected prior to the examination?Response:This requirement was met. Two qualified DM examiners performed an inspection of thesurface using a "surface finish comparator". Some manual surface conditioning wasperformed. Following the manual surface conditioning, the two qualified examiners determinedthat the RMS finish was approximately 250 RMS. Therefore, this requirement was met.During the execution of the examination, the qualified inspector observed areas whereultrasonic contact was determined to be inadequate and these areas were considered asexamination volume limitations. This condition only occurred scanning circumferentially on theweld surface.o Please clarify that the coverage calculations shown in Attachment I of the RAI responsecomply with the following:10 CFR 50.55a limitation on counting coverage... "Where full coverage credit from asingle side may be claimed only after completing a successful single-sided AppendixVIII demonstration using flaws on the opposite side of the weld."Response:The condition in 10CFR50.55a was met. The techniques applied to the dissimilar metalweld were qualified in accordance with the PDI's implementation of ASME B&PVCSection Xl, Appendix VIII as well as demonstrated on a site-specific mockuprepresenting the subject weld joint configuration using flaws on the opposite side of theweld. 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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Reference:"EPRI -Technical Justification for the Acceptance of Ultrasonic ExaminationDemonstration Results on Ginna Steam Generator Nozzle Dissimilar Metal WeldConfigurations with PDI-UT-10, Revision C" Document IR-2009-381PDI-UT-1O requirement that two angles be used to examine dissimilar metal (DM)welds as well as the use of both shear and longitudinal wave modes.Response:The calculated coverage in Attachment 1 of the RAI response is that percentage of thevolume covered by two angles and both wave modes.PDI-UT-1O is applicable to components with tapers and geometries represented in the PDI DMprogram sample inventory. Field installed components that are not represented by the PDIconfigurations require additional qualification demonstration activities utilizing a site-specificmockup. Did the PDI DM program sample inventory contain a qualification mockup thatadequately represented the configuration of these welds?Response:No, The PDI DM weld program sample inventory did not adequately represent the S/Greplacement 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 thedesign and fabrication phase of Ginna's SSM." If not, were additional activities conducted on the site-specific mockup to qualify the procedure forthis particular configuration?Response:Yes. The intent throughout the project and during the preparation of the required DM SSM wasthat the existing S/G DM welds were to be examined only after the surface conditioning processwas completed. In fact, vendors were on-site during the 2009 refueling outage to mock-up andperform the surface conditioning.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 6 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244The site confirmed during the 2009 refueling outage that these existing DM welds had someoriginal fit-up and off-set joint issues along with the design-machined outer diameter contour asshown on the next figure. Also, the thickness of these components was determined to be at orvery close to the design wall thickness. There was no safety margin to reduce any weld crown bysurface conditioning to comply with the PDI-UT-10 requirements of being flush and smooth. Theengineering conclusion was that any weld crown reduction and surface conditioning would bedetrimental to nuclear safety because there was a high likelihood that design wall thicknesseswould 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 andexisting off-sets and misalignments.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 7 of 7511S]l.IN UZZIu tO ELo t1imOv*t NEV WEE TO ILTV lAIDISEhTT 1*'" ' ' \ ' ' \ "i! ,\ _ N .'. -.+" ..N.7 " < ,Zx ,,.",,m ~ \' ' " j. \W., ' .s i l-/ '- .: '.: ./ " -" /NOZE ,-.A" it.IT-LIE f -CERG.a.,um !rip fO TWATIO 431.... ....L o w.. ..... .. ICL I-L V "--0' I i. VEtO 113 rSITIEN #MwILE, -SEC Nut 1iRES PIPE T0 IL.B tI1) VIghISLTiIN-' I"mIr*IThis 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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244S/G Welds -(NSE-4-R & PL-FW-X-R) and (NSE-3-R & PL-FW-III-R) outer surface contours -FieldProfile Conditions. (Although much of the ensuing discussion focuses on the DM weld, all partsrelated 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 weldconfigurations. 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 approximately6 inches.An additional limitation factor that impacted the scanning during these existing weld examinationswas the size of the footprint of the demonstrated and qualified contoured transducers. These squaretransducer housings measure 2-3/8" by 2-3/8".During the 2009 Refueling Outage (RFO), the site engineering department's conclusions were thatthere was insufficient margin for any metal reduction on these S/G DM weld configurations. The sitegenerated Condition Report CR-2009-007117 to capture the following four welds: Steam GeneratorInlet and Outlet Nozzle DM welds and the adjacent stainless steel narrow groove tie-in welds. ThisCondition Report was categorized as significance level 2 which required an Apparent CauseEvaluation (ACE).
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 9 of 752008cO C#4w*cgs00'w9"b itw~sMO~UP MooFiELO CAMbV S" Vic~e*135a* LD rwAsffaIu 'aWi"-Bn .-0 5/0 0,~" /e~IThe 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 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 10 of 75WteMCS ___F_/&: -W -, 0?i -Ao-kKri~,~jj2704-Jraf50T/w' ýOzThe 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 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 11 of 75wc-os-*-0V!o' ..... 0.--0-,- \1%7"rI 5CAtf,ý A"'390P~"L /o~'2The 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 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 12 of 75C$$~4N~z~tC. 4:"I~oa700.,4MI Mt4/1,610The 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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Additionally, PDI-UT- 10 requires certain inner diameter (ID) impingement angles for initial flawdetection. 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 ExaminationDemonstration Results on Ginna Steam Generator Nozzle Dissimilar Metal Weld Configurationswith 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 tophased array techniques during 2008 and 2009. The site elected to go with the qualifiedconventional UT examinations. This decision was made prior to the fabrication of a site-specificmockup for the required technical justification and performance 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 appears that it would have been clear that conventional manual UT applied to thisconfiguration would encounter significant limitations due to geometry and materials. As such, whywasn't phased array (PA) UT evaluated?Response:The EPRI NDE PDA personnel communicated to the site that both ultrasonic techniques werequalified at the time; and could be applied to these welds. Fleet and site experience with UTphased 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 thePhased Array UT technique. Based on existing DM weld limitations, the phased arraytransducer(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 4th Interval ISIProgram examinations were performed fully to the extent possible taking into account all notedlimitations. 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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244metal interface and the limited examinations results was no recordable indications noted. TheseDM welds are constructed with Alloy 52/152 filler metal that is resistant to Primary Water StressCorrosion Cracking (PWSCC).The site considered a re-design of the outside diameter (OD) contours by adding weld build-up tomeet PDI-UT-1 0 procedural requirements. The weld crown reduction process was estimated toaccrue 8 Rem of cumulative dose (200 man-hours in a 40 mRem/hr field). The weld build-upprocess was estimated to accrue at least as much cumulative dose as the weld crown reductionprocess. The weld overlay process also had the potential to invalidate current design basisanalysis used at Ginna such as leak before break (LBB) as discussed in NRC Regulatory IssueSummary 2010-07. Based on dose and design analysis considerations, this option was notpursued.Also, once it was determined that the DM weld could not be ground flush per the PDI-UT-1Orequirements, why wasn't an alternate exam proposed or hardship requested via relief request?[(a) (3) (i) or (a) (3) (ii)]Response:The ISI DM weld examinations were determined to have limitations as stated above; therefore, thelimited examinations were submitted in the original Relief Request. The site did not propose theuse of an alternate exam such as radiography (RT), since the RT examination results wouldprovide limited flaw information as compared to PDI-UT examination. Site and corporateengineering did not believe that a hardship relief request was applicable regarding the limitationexperienced with the DM weld exam." Was the generic issue entered into the corrective action program? What were the correctiveactions?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 CauseEvaluation (ACE). The ACE contained the following corrective and preventive actions:" Provide complex weld ISI inspection schedule (5th ISI Interval) to the site Level III NDESpecialist;" 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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Code 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/lack of review. Assuch, please clarify why this exam was not completed at the next outage, especially in light of thestatement in response to RAI question No. 3b (page 5 of 20 on RAI response), "For the future, thesite should modify the existing site-specific mockup to include the narrow groove weldconfiguration with flaws that will be adjacent to the DM weld as in the field. At this time, it will bepossible for a qualified ISI vendor to demonstrate a qualified UT technique such as PAUT on thiscomponent for flaw detection and applicable code coverage." Will the exam be done at the nextscheduled outage?Response:No, this exam will not be examined during the Fifth 10-Year Interval. Zero percent code coveragewas due to limitations that were not recognized prior to the exam. If recognized, it would havebeen 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 EPRIPDA staff about modifying the Ginna site-specific mockup and developing a qualified UTtechnique for this similar-metal narrow groove weld configuration. The EPRI PDA staff noted thatthere is still no qualified procedure for a stainless steel weld configuration that is beyond thequalified generic procedure, based on thickness, the tapered outer scan surface and scanningthrough 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 successfullyinterrogating the weld in a way that would meet PDI requirements were negligible, even usingPhased Array UT. It has become apparent that due to limitations, sufficient technology is notcurrently available to provide significant Code Coverage. The response to question 3b inReference 2 was not intended to imply that such methods currently exist and can be used in anupcoming inspection.These welds were part of the 1996 Steam Generator replacement project and no flaws wereidentified in the pre-service RT examinations. With the three follow-up examinations discussed inother portions of this response, Ginna will meet the Code required minimum number (129) ofproperly performed weld examinations for this sample population of 517 welds. A total of 131Examination Category B-J welds were originally selected for the Fourth Interval ISI program andwith the exception of these two welds, 129 will be complete. While this sample does not addressthese 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 forfuture exams in the Risk Informed program.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 16 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-2440 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 inthe 1996 outage. (Replacement Steam Generator project)Surface Examination (PT) -AcceptableVolumetric Examination (RT) -AcceptableAll NDE PSI examinations were performed in accordance with ASME BPV Section XI, 1986Edition, No Addenda.* Was the generic issue entered into the corrective action program? What were the correctiveactions?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 CauseEvaluation (ACE). The ACE contained the following corrective and preventive actions:* Provide complex weld ISI inspection schedule (5th ISI Interval) to the site Level III NDESpecialist;* Qualify the similar metal weld inspections to optimal code coverage" Develop a template for planning for complex welds;" Submit a Relief Request to the NRCCode 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 originalRAI.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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1012000 Comp ID: PL-FW-XIIIThe NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.Response:This was a manual UT examination performed on a cast stainless-steel elbow to cast stainless-steelpump weld configuration. The site's staff was preparing the subsequent request for additionalinformation when it was discovered that this ISI examination was performed incorrectly. Conditionreport CR-2012-000188 was initiated which documented this deficiency.In accordance with the Ginna Station 4th 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 2008under ISI Summary Number 1012000. The incorrect procedure was used and no code credit can beaccepted. This weld is Examination Category B-J, Item Number B9.1 1. The Ultrasonic examinationwill be re-performed no later than the end of the 2014 RFO.The 4th Interval ISI Program was developed to ASME Section Xl Code, 1995 Edition with the 1996Addenda. The ASME Section Xl Code is a sampling code and trends acceptable or degradedconditions. Weld PL-FW-XlII had previous ASME Section Xl Code UT examinations performed andall examinations were acceptable.ASME Section Xl Code, 1995 Edition with the 1996 Addenda, Table IWB-2500-1 ExaminationCategory B-J, Pressure Retaining Welds in Piping is the criteria for selection. Footnote (1) underExamination Category B-J further defines the selection. Footnote (1) (b) describes "All terminal endsand joints in each pipe or branch run connected to other components where the stress levels exceedeither of the following limits under loads associated with specific seismic events and operationalconditions: (1) primary plus secondary stress intensity range of 2.4 Sm for ferritic steel and austeniticsteel (2) cumulative usage factor U of 0.4." Ginna was designed and built to B31.1 Code 1955. Thecriteria under Footnote (1) (b) could not be applied. As allowed by 10CFR50.55a (b)(2)(ii), ASMESection Xl 1974 Edition with addenda through 1975 is permitted for Category B-J weld selection anddoes not utilize stress level criteria. Thus, Ginna selected all accessible Terminal Ends and joints ineach 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 assurancefor public health and safety.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 18 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244On the 31" Reactor Coolant Loop "A" line, weld PL-FW-XIII configuration is Cast Elbow-to-Cast Pumplocated on Reactor Coolant Pump "A" suction. An identical weld is located on the 31" ReactorCoolant Loop "B" line. This weld is PL-FW-XV. Weld PL-FW-XV configuration is Cast Elbow-to-CastPump located on Reactor Coolant Pump "B" suction. This weld was examined by UT during the 2005RFO, 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-WroughtPipe located on the Reactor Coolant Pump "A" discharge. This weld was examined by UT during the2006 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-WroughtPipe located on the Reactor Coolant Pump "B" discharge. This weld was examined by UT during the2008 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 (ReactorCoolant Pump "A" suction), and a review of previous examinations for the weld showed consistentlysatisfactory results. These two facts, coupled with the acceptable examinations of three out of fourpump terminal ends during the 4th Interval ISI Program, make it unlikely that there is a problem onWeld PL-FW-XIII and provide reasonable assurance for public health and safety.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles 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 atGinna. The site personnel provided the outage ISI examination scope list to the selected ISI/NDEvendor. This list included the requested essential component information such as WO #, Summary #,Component ID, Description, Line name, Diameter, Thickness, Material, etc. During the process ofpopulating the ISI list with information, the site NDE person provided the vendor information thatidentified this weld as a stainless-steel (elbow) to cast stainless-steel (pump) configuration instead ofCast SS to Cast SS. This human performance error set up the vendor to fail by performing therequired ISI UT examination with the incorrect ultrasonic PDI procedure and applicable Cast SScalibration 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 recordwhich had the correct Cast SS calibration block. However, partly due to the HU error previouslydescribed, the vendor did not use the applicable calibration block (SS vs. CSS) or the NDE procedurethat is applicable to cast stainless steel. Also, during the post-examination reviews of this weld by thevendor and site personnel, the error was not caught.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 19 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Weld PL-FW-XVThe original submittal shows this to be a stainless steel (SS) elbow to cast pump that wasexamined in accordance with Appendix VIII (page 6 of 21 in the original submittal) from asingle side with 50 percent code coverage achieved. However, the RAI indicates that this is acast stainless steel (CSS) elbow to a CSS pump casing that was examined in 2008 using abest effort exam with a SLIC20 transducer. Assuming that the RAI response clarifying this asa CSS elbow to CSS pump casing is correct, what is the code required examination for thisweld?Response:The following clarification is provided on what examination actions occurred with each of thefollowing CSS to CSS Weld IDs:PL-FW-XV -CSS elbow to CSS pump configuration examination was performed in 2005 withSLIC20 transducer and Appendix III procedure with acceptable results.PL-FW-XIII -CSS elbow to CSS pump configuration examination was performed in 2008 andwas incorrectly examined with the Appendix VIII procedure. As previously described ConditionReport 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 required examination 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-grainedstructures in accordance IWA-2240.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 20 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1012100 Comp ID: PL-FW-VI Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.Response:This was a manual UT examination performed on a cast stainless steel pump to wrought stainlesssteel pipe weld configuration. The wave modality used for this weld examination was shear andlongitudinal. The component scan limitation was due to the pump cast stainless steel material andconfiguration restrictions; therefore no axial scan was performed on the pump-side (far-side) of theweld. 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 frompipe-side as indicated on the attached sketch.* Circumferential scans were performed using a 450 shear wave in both the clockwise andcounter-clockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 21 of 75Line Number: 27.5-RC-2501-A Diameter: 29"Component ID: PL-FW-VI Thickness: 2.500"Summary#: 1012100 Material: CSS / SSExam Angles: 450S 1 60°RL Description: Pump to PipePage 2 of 2Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit takencn(D02.:0.o0033Mti0 0V" Q- 1,ýqo 0l C(DCPL ksc~sGC-t CA ~s-~Image Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 22 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1013500 Comp ID: PL-FW-XV Page 1 of3The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.Response:This was a manual UT examination performed on a "cast stainless-steel elbow to cast stainless-steelpump 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 scanwas performed on the pump-side (far-side) of the weld. All axial weld examinations were performedon the elbow-side (near-side) of the weld.No Appendix VIII examination performed, vendor performed an Appendix III examination using aprocedure that addressed coarse-grained materials with "state of the art" technology. The vendorutilized a SLIC 20 transducer that is focused for this component thickness. See attached search unitfocus chart provided by vendor.No alternative examinations are planned for the weld during the current inspection (5th R-1) interval.The use of radiography as an alternate volumetric examination for the above listed component is notpractical due to component thickness and geometric configurations. Other restrictions makingradiography 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 fromelbow-side.* Circumferential scans were performed using a 30' RL wave in both the clockwise and counter-clockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketches derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 23 of 75Line Number: 31-RC-2501-B Diameter: 31"Component ID: PL-FW-XV Thickness: 2.400"Summary #: 1013500 Material: CSS / CSSExam Angles: 3001200 RL Description: Elbow to Pump(SLIC 20) (RCP-B)Page 2 of 3Exam Coverage = 50%.Best effort exam on far side of weld -No coverage credit taken-111 -L.4 PP..vtPumpwD.!OWco xQamAxckExoýPImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 24 of 75Line Number: 31-RC-2501-B Diameter: 31"Component ID: PL-FW-XV Thickness: 2.400"Summary #: 1013500 Material: CSS / CSSExam Angles: 3001200 RL Description: Elbow to Pump(SLIC 20) (RCP-B)Page 3 of 3SLIC search unit focus beam traces chart provided by vendor.(SLIC 20) is displayed on the left side.SLIC MODULEBEAM TRACESSLIC 15S¶L1C 204510 60L SIImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 25 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1013600 Comp ID: PL-FW-VIII Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.Response:This was a manual UT examination performed on a cast stainless steel pump to wrought stainlesssteel pipe weld configuration. The wave modality used for this weld examination was shear andlongitudinal. The component scan limitation was due to the cast stainless steel material and pumpconfiguration restrictions; therefore no axial scan was performed on the pump-side (far-side) of theweld. 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 fromthe pipe-side as indicated on the attached sketch.0 Circumferential scans were performed using a 450 shear wave in both the clockwise andcounter-clockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 26 of 75Line Number: 27.5-RC-2501-B Diameter: 31"Component ID: PL-FW-VIII Thickness: 2.500"Summary #: 1013600 Material: CSS I SSExam Angles: 450S / 60°RL Description: Pump (RCP-B) toPipePage 2 of 2Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit takenSummary No.: 1013600Sketch or Photo:5PA 4 CAo TEASImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 27 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1014500 Comp ID: RC-FW-D Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.Response:This was a manual UT examination performed on a stainless steel pipe to stainless steel nozzle weldconfiguration. 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 axialscan was performed on the nozzle-side (far-side) of the weld. All axial weld examinations wereperformed 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 frompipe-side.* Circumferential scans were performed using a 600 shear wave in both clockwise and counter-clockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 28 of 75Line Number: 10-RC8-2501 Diameter: 10"Component ID: RC-FW-D Thickness: 1.000"Summary #: 1014500 Material: SSExam Angles: 60°S / 60°RL Description: Pipe to Nozzle(Loop B Hot Leg)Page 2 of 2Code Coverage = 50% as per single-sided access PDI rulesTotal 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.: 1014500Sketch or Photo:-:KC-C,,t PAJ-.,4 Q,-, cri/zs/oiFlow* 11 *NozzleExam imians. No axial exam on DS side due to nozzle taper.Welded ID tag on US side, 1.5" tong, 1.75" from weld, at 180*. Best effort axial exam performed in this area. no coverage credittaken.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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1028900 Comp ID: 1OA-AC7-2501-B Weld "A" Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.Response:This was a manual UT examination performed on a stainless steel valve to stainless steel pipe weldconfiguration. The wave modality used for this weld examination was shear and longitudinal. Thecomponent scan limitation was due to the valve configuration restrictions; therefore no axial scan wasperformed on the valve-side (far-side) of the weld. All axial weld examinations were performed on thepipe-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 frompipe-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-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 30 of 75Line Number: IOA-AC7-2501-B Diameter: 10"Component ID: A Thickness: 1.000"Summary #: 1028900 Material: SSExam Angles: 45°S / 60°RL Description: Valve (720) to PipePage 2 of 2Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit takenc2/fMfA¶ j, i '" 1Fha~ a-.Cro~Image Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 31 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1029400 Comp ID: 1OA-AC7-2501-B, Weld "B" Page 1 of3The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.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 scanlimitation was due to the valve configuration restrictions; therefore no axial scan was performed onthe 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 frompipe-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-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketches derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 32 of 75Line Number: 10A-AC7-2501-B Diameter: 10"Component ID: B Thickness: 1.000"Summary #: 1029400 Material: SSExam Angles: 450S 1 60°RL Description: Pipe to Valve (721)Page 2 of 3Exam Coverage = 49.5% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit takenDescription of Lirnltticm:1. 8snle sided aeam.2. Welded ID tag at TDC. ¶" wide, 0.8" from weld toe. Obstructed exisl exams for 1" of 34*.Sketch of UrnitaWon:--- T_F L 0 %^/. _-,CPI PeJ-VALVE TPC-Ja-UmItations removal requlrements:w(tImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 33 of 75Line Number: 1OA-AC7-2501-B Diameter: 10"Component ID: B Thickness: 1.000"Summary #: 1029400 Material: SSExam Angles: 45°S 1 60°RL Description: Pipe to Valve (721)Page 3 of 3Exam Coverage = 49.5% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit takenSummary No-: 1029400Sketch or Photo:-+CoJTOL.M. TAKE" AT L_- (7oC).FLOL',Vig Lz.,)---_-.11t. D6" 1. 10. "'L a J C t A_5IMO"- c A 0 o04HE XLe ., f I(I4/z~4cLq / 2--, (Image Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 34 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1030300 Comp ID: 1OA-RCO-2501-B, Weld # CSW-5 Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.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 componentscan limitation was due to the nozzle configuration restrictions; therefore no axial scan was performedon 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 fromtee-side.* Circumferential scans were performed using a 45' shear wave in both clockwise and counter-clockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 35 of 75Line Number: 10A-RCO-2501-B Diameter: 10"Component ID: CSW-5 Thickness: 1.00"Summary #: 1030300 Material: SSExam Angles: 45°S / 60°RL Description: Tee to NozzlePage 2 of 2Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit taken." -2 .... t .-.rl ir !! .2 2 I[ ] 2 -. ..J I ] '= IG ]I 7 I "- T [I' --" - --.. I'At 1 rnin s.q re r fl2 CSLOJ $Sket.o, 0! toI t~ k~I,.K ....L~4~4~4-L -Best Quality AvailableImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 36 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1030400 Comp ID: 1OA-RCO-2501-A, Weld "A" Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.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 componentscan limitation was due to the nozzle configuration restrictions; therefore no axial scan was performedon 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 frompipe-side.* Circumferential scans were performed using a 45' shear wave in both clockwise and counter-clockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 37 of 75Line Number: 1OA-RCO-2501-A Diameter: 10"Component ID: A Thickness: 1.00"Summary #: 1030400 Material: SSExam Angles: 45°S / 60°Sl60°RL Description: Nozzle to PipePage 2 of 2Code Coverage = 50% as per single-sided access PDI rulesTotal Examination Coverage = 74% / Best EffortThe 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.: 1030400Sketch or Photo:FlowExam 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 credittaken.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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1030700 Comp ID: 1OA-AC7-2501-A Weld "C" Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.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 scanlimitation was due to the valve configuration restrictions; therefore no axial scan was performed onthe 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 frompipe-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-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 39 of 75Line Number: 1OA-AC7-2501-A Diameter: 10"Component ID: C Thickness: 1.00"Summary #: 1030700 Material: SSExam Angles: 450S / 60ORL Description: Valve (700) to PipePage 2 of 2Exam Coverage = 49.5% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit takenSummawry No.: 1030700Sketch or Photo:TjMjckJs t COAJTOvl TAkEtJ AT L. (TDDC).VALVE (70o) srL4..% PIPE.r o* "1. 1.0OCLea. III4/7- */ Zoog90 9 /o(>EBest Quality AvailableImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 40 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1034300 Comp ID: 1OA-SI2-2501-B Weld "H" Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for relief request ISI-03 submittedon 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 ultrasonicexaminations.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 scanlimitation was due to the valve configuration restrictions; therefore no axial scan was performed onthe 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 frompipe-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-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 41 of 75Line Number: 1OA-SI2-2501-B Diameter: 10"Component ID: H Thickness: 1.00"Summary #: 1034300 Material: SSExam Angles: 45°S / 60°RL Description: Pipe to Valve(867A)Page 2 of 2Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit takenC eSa : '('kat cL-hs or, Phot_:l -- .-) 1---I--4A qLY6-1. Ce I ýOs 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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1035900 Comp ID: IOA-SI2-2501-A, Weld H Page 1 of 3The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.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 scanlimitation was due to the valve configuration restrictions; therefore no axial scan was performed onthe 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 theapproved 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 catchthe 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 isExamination Category B-J, Item Number B9.1 1. During the 2002 Refueling Outage, a surface andvolumetric examination was performed on Weld H, Pipe to Valve (867B) under ISI Summary Number1035900. The surface examination that was performed was a Liquid Penetrant Test (PT). This PTexamination was acceptable with no recordable indications and no limitations. A Volumetric(Ultrasonic) examination was also performed. The Ultrasonic examination was acceptable with norecordable 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 sideof 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 soundfor 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 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 43 of 75Summary No.: 1035900 Comp ID: 1OA-SI2-2501-A, Weld HPage 2 of 3examination no later than the end of the 2014 RFO. Also, there is no known degradation mechanismfor Weld H, Pipe to Valve (867B).Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 44 of 75Line Number: IOA-SI2-2501-A Diameter: 10"Component ID: H Thickness: 1.00"Summary #: 1035900 Material: SSExam Angles: 600S Description: Pipe to Valve(867B)Page 3 of 3Exam Coverage = 50% as per single-sided access PDI rules.No best effort exam on far side of weld.Sketch or Photo:LUVdeaAttachmentsW2GU 11 .bmpM0S"10(A stS 0 .3 0 .Sr-ALE LI -IIVALVEBest Quality AvailableImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 45 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Weld H (1035900)The RAI response stated that the "site qualified examiner and the site level Ill misinterpretedthe qualified generic procedure which states, "The primary angle shall be the lowest anglethat provides coverage of the required examination volume from each side of the weld," thusthe required 45-degree shear wave exam was not completed. Additionally, the RAI statesthat "during the review process, the site UT Level Ill reviewer missed that the qualified PDIUT examiner did not perform a best effort examination of the far side of the weld using a RLtransducer."o When were these two omissions discovered?Response:These two omissions were discovered in between the original submittal of the ReliefRequest on 12/16/2010 and during the preparation of the 1st RAI submitted on 07/29/2011,the site discovered the procedural non-adherence and human performance error involvingthis ISI component examination.o What plans are in place to meet the requirements of the PDI procedure?Response:The site scope-add process is currently being used to add this examination into the nextrefueling outage. Ginna commits to perform this 4th interval ultrasonic ISI examination nolater than the end of the 2014 RFO.The site is currently in the 5th Interval ISI Program. Weld # H is part of the site's 5th IntervalRisk-Informed Program. The RI weld is classified as high safety significance (HSS) inaccordance with the Risk-Informed Program. Welds other than this one were selected tomeet the risk-informed required examination population.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 46 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244o Was the generic issue entered into the corrective action program? What were thecorrective 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 upcomingrefueling 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 recordreviews.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 47 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1036200 Comp ID: 6A-RCO-2501-B-J Page 1 of 4The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.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 scanlimitation was due to the valve configuration restrictions; therefore no axial scan was performed onthe 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 frompipe-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 "during the review process after the 2002 refueling outage, the siteUT Level I/ reviewer missed that the qualified PDI UT examiner did not perform a best effortexamination 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 on12/16/2010 and during the preparation of the 1st RAI submitted on 07/29/2011, the sitediscovered the procedural non-adherence and human performance error involving this ISIcomponent examination.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 48 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1036200 Comp ID: 6A-RCO-2501-B-J Page 2 of 4o 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 nextrefueling outage. Ginna commits to perform this 4th interval ISI examination no later than theend of the 2014 RFO.o Was the generic issue entered into the corrective action program? What were thecorrective actions?Response:Yes, Condition Report CR-2012-000188 was generated to document the examination deviationfrom the approved procedure. The examiner did not use the required longitudinal search unitfor "best effort" examination scan on the far side of weld to detect discontinuities. The datareviewer did not catch the missed scan during the examination document review process in2002.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 recordreviews.The site is currently in the 5th Interval ISI Program. Weld # J is part of the site's 5 t IntervalRisk-Informed Program. This RI weld is classified as high safety significance (HSS) inaccordance with the risk informed Program. Welds other than this one were selected to meetthe risk-informed required examination population.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 49 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1036200 Comp ID: 6A-RCO-2501-B-J Page 3 of 4In accordance with ASME Section Xl Code, 1995 Edition with the 1996 Addenda, this weld isExamination Category B-J, Item Number B9.11. During the 2002 Refueling Outage, a surface andvolumetric examination was performed on Weld J, Stainless Steel Valve (852B) to Pipe under ISISummary Number 1036200. The surface examination that was performed was a Liquid PenetrantTest (PT). This PT examination was acceptable with no recordable indications and no limitations. AVolumetric (Ultrasonic) examination was also performed. The Ultrasonic examination was acceptablewith no recordable indications. The examination coverage obtained was 50% code coverage as persingle-sided access in accordance with PDI rules. No best effort examination was performed on thefar 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 soundfor public health and safety and there is little risk in performing the best effort part of the ultrasonicexamination no later than the end of the 2014 RFO. Also, there is no known degradation mechanismfor Weld J, Valve (852B) to Pipe.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 50 of 75Line Number: 6A-RCO-2501-B Diameter: 6"Component ID: J Thickness: 0.719"Summary #: 1036200 Material: SSExam Angles: 45°S / 60°S Description: Valve (852B) toPipePage 4 of 4Exam Coverage = 50% as per single-sided access PDI rules.*No best effort exam on far side of weld.IIowImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 51 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1011000 Comp ID: PL-FW-II Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.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 scanlimitation was due to the weld configuration restrictions; therefore no axial scan was performed on theRCS 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 frombranch 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-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 52 of 75Line Number: 1OA-RCO-2501-A Diameter: 10"Component ID: PL-FW-11 Thickness: 2.50"Summary#: 1011000 Material: SSExam Angles: 45°SI60°S / 60*RL Description: Branch WeldPage 2 of 2Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit takenComments:W6Lf PL-FW-I_1/1OA..RCO-2501-ATOTAL 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 AvailableImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 53 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1059200 Comp ID: V-720-1 Page I of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.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 scanlimitation was due to the valve configuration restrictions; therefore no axial scan was performed onthe 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 frompipe-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-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 54 of 75Line Number: 1OA-AC7-2501-B Diameter: 10"Component ID: V-720-1 Thickness: 1.36"Summary #: 1059200 Material: SSExam Angles: 450S / 60°RL Description: Velan MotorOperated GateValve(Body Weld)Page 2 of 2Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit takenComment'Sy3 7"Cf- ITO~~ELO~LSketch or Photo:VAL VE\30V4 IVE,,d v..jt442#IP&W0Z&17#Best Quality AvailableImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 55 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1059205 Comp ID: V-720-2 Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for Relief Request ISI-02submitted on December 16, 2010. The questions for the request for additional information are asfollows:1 c) Fully clarify the wave mode(s) and insonification angles used and limitations for all ultrasonicexaminations.Response:This was a manual UT examination performed on a stainless steel valve to valve body weldconfiguration. The wave modality used for this weld examination was shear and longitudinal. Thecomponent scan limitation was due to the valve configuration restrictions; therefore no axial scan wasperformed on the valve-side (far-side) of the weld. All axial weld examinations were performed on thepipe-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 frompipe-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-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 56 of 75Line Number: 1OA-AC7-2501-B Diameter: 10"Component ID: V-720-2 Thickness: 1.36"Summary #: 1059205 Material: SSExam Angles: 45"S/ 60°RL Description: Velan MotorOperated GateValve(Body Weld)Page 2 of 2Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam on far side of weld -No coverage credit takenA DL)Comments:C , M n p oe=, e n 'C " ý 'D %/ .= .2, CB3 0D?? W e t(oeg..Sketch or Photo:rxTew-Tnot4FA ABest Quality AvailableImage Altered for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 57 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244RELIEF REQUEST ISI-03ASME Code Category C-F-I, Pressure Retaining Welds in Austenitic Stainless Steel or High AlloyPiping, Item No. C5.21 Circumferential Pipe Welds.The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide detailed and specificinformation to support the bases for limited examination in all requests for relief submitted onDecember 16, 2010 and July 29, 2011, and therefore, demonstrate impracticality. The questions foreach relief request are as follows:2.1.1 c) Fully clarify the wave mode(s) and insonification angles used for all ultrasonic examinations.2.1.1 d) Provide cross-sectional coverage plots to describe ASME Code volumes and transducerangles 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 insonificationangles used, as well as limitations encountered and coverage obtained. Though the RAIresponse attempts to clarify the coverage obtained as well as insonification angles and modalities,there are still discrepancies between 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 AppendixVIII?Response:Yes -During the site's 4th ISI Interval program, the ISI ultrasonic examinations were performed inaccordance 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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1163070 Comp ID: 3C-SI-1501-6 Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for relief request ISI-03 submittedon 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 ultrasonicexaminations.Response:This was a manual UT examination on a stainless steel pipe to valve weld configuration. The wavemodality used for this weld examination was shear-wave. The component scan limitation was due tothe valve configuration restrictions; therefore no axial or circumferential scan examination wasperformed on the valve-side (far-side) of the weld. All axial weld examinations were performed onpipe-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-sideas indicated on the attached sketch.0 Circumferential scans were performed using a 450 shear wave in both clockwise andcounterclockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See attached sketch derived from the examination data on file at Ginna for cross-sectional coverageplots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 59 of 75Component ID: 3C-SI-1501-6 Diameter: 3"Summary #: 1163070 Thickness: 0.300"Exam Angles: 001 450S / 670S Material: SSDescription: Pipe to Valve(870A)Page 2 of 2Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam (700) on far side of weld -No coverage credit taken.SCAN PLANROWSketch or PNOW:L4 E4ULOW LA) LImage Enlarged for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 60 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1163570 Comp ID: 3E-SI-1501-8 Page 1 of2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for relief request ISI-03 submittedon 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 ultrasonicexaminations.Response:This was a manual UT examination on a stainless steel valve to pipe weld configuration. The wavemodality used for this weld examination was shear-wave. The component scan limitation was due tothe 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-sideas indicated on the attached sketch.* Circumferential scans were performed using a 45' shear wave in both clockwise andcounterclockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See attached sketch derived from the examination data on file at Ginna for cross-sectional coverageplots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 61 of 75Component ID: 3E-SI-1501-8 Diameter: 3"Summary #: 1163570 Thickness: 0.300"Exam Angles: 00! 45°S / 60°S / Material: SS700S Description: Valve (888B) toPipePage 2 of 2Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam (700) on far side of weld -No coverage credit taken..4t41ivC-5-1%~IJ I I I II I I II I I I4 6-,00700jOQ (er o 7DImage Enlarged for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 62 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1163220 Comp ID: 3D-SI-1501-14 Page 1 of3The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for relief request ISI-03 submittedon 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 ultrasonicexaminations.Response:This was a manual UT examination performed in 2002 on a stainless steel valve to pipe weldconfiguration. The wave modality used for this weld examination was shear and longitudinal. Thecomponent scan limitation was due to the valve configuration restrictions; therefore no axial scan wasperformed on the valve-side (far-side) of the weld. All axial weld examinations were performed on thepipe-side (near-side) of the weld.Vendor procedure # ISwT-PDI-UT1 was used to examine this weld, refer to PDQS # 371, IHISouthwest 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, scannedfrom pipe-side as indicated on the attached sketch.* Circumferential scans were performed using a 450 longitudinal and 520 shear wave in bothclockwise and counterclockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketches derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class I ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 63 of 75Component ID: 3D-SI-1501-14 Diameter: 3"Summary #: 1163220 Thickness: 0.310"Exam Angles: 00/45°RL / 520S/700S Material: SSDescription: Valve (871B) toPipePage 2 of 3Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam (700) on far side of weld -No coverage credit taken.I--IVIALVE.sic=o- ---44IeIII{Image Enlarged for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 64 of 75Component ID: 3D-SI-1501-14 Diameter: 3"Summary #: 1163220 Thickness: 0.310"Exam Angles: 0°/45°RL I 520S I Material: SS700S Description: Valve (871B) toPipePage 3 of 3Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam (70') on far side of weld -No coverage credit takenIFLO .6III4IImage Enlarged for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit I Page 65 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1163230 Comp ID: 3D-SI-1501-15 Page 1 of3The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for relief request ISI-03 submittedon 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 ultrasonicexaminations.Response:This was a manual UT examination performed in 2002 on a stainless steel valve to pipe weldconfiguration. The wave modality used for this weld examination was shear and longitudinal. Thecomponent scan limitation was due to the valve configuration restrictions; therefore no axial scan wasperformed on the valve-side (far-side) of the weld. All axial weld examinations were performed on thepipe-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, scannedfrom pipe-side as indicated on the attached sketch.0 Circumferential scans were performed using a 450 longitudinal and 520 shear wave in bothclockwise and counterclockwise directions.Vendor procedure # ISwT-PDI-UT1 was used to examine this weld, refer to PDQS # 371, IHISouthwest Technologies, Inc. Within this procedure, the 520 shear wave transducer is qualified.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketches derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 66 of 75Component ID: 3D-SI-1501-15 Diameter: 3"Summary#: 1163230 Thickness: 0.310"Exam Angles: 0°I45°RL / 52°S I Material: SS700S Description: Pipe to Valve(870B)Page 2 of 3Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam (70') on far side of weld -No coverage credit taken.WEta* ISVALVE I'I.31IýImage Enlarged for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 67 of 75Component ID: 3D-SI-1501-15 Diameter: 3"Summary #: 1163230 Thickness: 0.310"Exam Angles: 00/450RL / 520S I Material: SS700S Description: Pipe to Valve(870B)Page 3 of 3Exam Coverage = 50% as per single-sided access PDI rules.Best effort exam (700) on far side of weld -No coverage credit takenIIamSS-mdV-ALV 1!toC V -4 , , 5 -qlI,IIIImage Enlarged for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 68 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1162770 Comp ID: 3B-SI-1501-18 Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for relief request ISI-03 submittedon 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 ultrasonic examinations.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 transducercontact when scanning on and within the Tee's crotch radius regions (two regions) adjacent to theweld. Based on the following existing weld crown conditions, as welded and having a fairly widecrown, combined with the component thin wall thickness, the qualified examiner scanned the weldwith 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 pipeand tee side of the weld.0 600 shear-wave used for the circumferential scans in both CW/CCW directions, as indicatedon the attached sketch.2.1.1 d) Provide cross-sectional coverage plots to describe ASME Code volumes and transducerangles used during the examination.Response:See attached sketch derived from the examination data on file at Ginna for cross-sectional coverageplots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 69 of 75Component ID: 3B-SI-1501-18 Diameter: 3.8"Summary #: 1162770 Thickness: 0.300"Exam Angles: 60°S, 700S Material: SSDescription: Pipe to TeePage 2 of 2Weld Examination Coverage = 82.5%.q9",Icr.'rVIMI I~- * -t@~I p ~ -~I~'0 *vdaA~~ ~ w I t --~ ~ = 'II-~LCr~ L~a~q~I b.~ -~Image Enlarged for Clarity -Not to Scale600 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 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1164300 Comp ID: 4E-SI-1501-56 Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for relief request ISI-03 submittedon 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 ultrasonicexaminations.Response:This was a manual UT examination performed in 2000 on a stainless steel flange to pipe weldconfiguration. The wave modality used for this weld examination was shear and longitudinal. Thecomponent scan limitation was due to the valve configuration restrictions; therefore no axial scan wasperformed on the valve-side (far-side) of the weld. All axial weld examinations were performed on thepipe-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, scannedfrom pipe-side as indicated on the attached sketch.o Circumferential scans were performed using a 450 longitudinal and 520 shear wave in bothclockwise and counterclockwise directions.Vendor procedure # ISwT-PDI-UT1 was used to examine this weld, refer to PDQS # 371, IHISouthwest Technologies, Inc. Within this procedure, the 520 shear wave transducer is qualified.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See the following sketch derived from the examination data on file at Ginna for cross-sectionalcoverage plots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 71 of 75Component ID: 4E-SI-1501-56Summary #: 1164300Exam Angles: 00/45°RL / 520S /700SDiameter: 4"Thickness: 0.337"Material: SSDescription: Flange (FE-125) toPipePage 2 of 2Exam 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 ISIreport 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. .11FvAqImage Enlarged for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 72 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1090400 Comp ID: L2-BC-2A Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for relief request ISI-03 submittedon 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 ultrasonicexaminations.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 limitationwas 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 attachedsketch.* Circumferential scans were performed using a 450 shear wave in both clockwise andcounterclockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See attached sketch derived from the examination data on file at Ginna for cross-sectional coverageplots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 73 of 75Line Number: 6B-MS-600-1B Diameter: 6"Component ID: L2-BC-2A Thickness: 0.432"Summary #: 1090400 Material: CSExam Angles: 0°/45°S / 60°S Description: Pipe to Valve(3506)Page 2 of 2Total Exam Coverage = 86%Weld length = 21.5", scan limitation (3" sweep-o-let) @ 2700; based on total circumferential and axialscans, the weld code coverage equals 86%. Scanned area was a total of 18.5" of the 21.5" weldlength.q~v -IraqOLot1'; 9Cf_ " 55Image Enlarged for Clarity -Not to Scale Relief Request ISI-02 and ISI-03 for Ginna Unit 1 Page 74 of 75Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Summary No.: 1083900 Comp ID: G2-BC-2A Page 1 of 2The NRC requested R. E. Ginna Nuclear Power Plant, LLC (Ginna) to provide additional details andspecific information to support the bases for the limited examination for relief request ISI-03 submittedon 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 ultrasonicexaminations.Response:This was a manual UT examination on a carbon steel pipe to carbon steel valve configuration. Thewave modality used for this weld examination was shear-wave. The component scan limitation wasdue 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 theweld. Within the scan region, there was a 3/4" weld-o-let that interfered with the scanning; thisprevented 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 theattached sketch.* Circumferential scans were performed using a 450 shear wave in both clockwise andcounterclockwise directions.Provide cross-sectional coverage plots (figures) to describe ASME Code volumes and transducerangles used during the examination and coverage calculations.Response:See attached sketch derived from the examination data on file at Ginna for cross-sectional coverageplots and calculations.
Relief Request ISI-02 and ISI-03 for Ginna Unit 1Code Category B-F, Item No. B5.70 Class 1 ComponentsCode Category CF-1, Item No. C5.21 Class 2 ComponentsAdditional InformationDocket Number 50-244Page 75 of 75Line Number: 6B-MS-600-1A Diameter: 6"Component ID: G2-BC-2A Thickness: 0.432"Summary #: 1083900 Material: CSExam Angles: 0°/45°SI70°S Description: Pipe to Valve(3507)Page 2 of 2Total Exam Coverage = 84.65%Weld length = 21", scan limitation (3/4" weld-o-let) from 15.25" to 17.5", welded id tag (fromconstruction) @ 10" to 11"; based on circ and axial scans, the weld code coverage equals 84.65%keth oi Ph tA) L by5hAL ff 1-VALVE W~7I PIP-LrN Xk ) (t %.J Q LImage Enlarged for Clarity -Not to Scale ENCLOSURE 2List of Regulatory Commitments LIST OF REGULATORY COMMITMENTSThe following table identifies those actions committed to in this document by R.E. Ginna NuclearPower Plant (Ginna). Any other statements in this submittal are provided for informationpurposes and are not considered to be regulatory commitments. Direct questions regardingthese commitments to Mr. Thomas Harding at (585) 771-5219 or via e-mail atThomas. HardinqJr(,cenqllc.comREGULATORY COMMITMENT DUE DATEPerform ultrasonic ISI examination of No later than June 1, 2014Weld #H (End of 2014 RFO)Perform ultrasonic ISI examination of No later than June 1, 20146A-RCO-2501-B-J (End of 2014 RFO)Perform ultrasonic ISI examination of No later than June 1, 2014PL-FW-XIII (End of 2014 RFO)Page 1 of 1