brunswick, unit 2, proposed alternatives for the third 10-year … · 2012-12-03 · jul 2 32010...

jProgress EnergyJUL 2 32010SERIAL: BSEP 10-0043 10 CFR 50.55a(g)(5)(iii)

U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

Subject: Brunswick Steam Electric Plant, Unit No. 2Renewed Facility Operating License No. DPR-62Docket No. 50-324Proposed Alternatives for the Third 1 0-Year Inservice Inspection Program

References: 1. Letter from Keith R. Jury to U.S. Nuclear Regulatory Commission,Inservice Inspection Program for the Third Ten-Year Interval, datedApril 23, 1998.

2. Letter from Phyllis N. Mentel to U.S. Nuclear Regulatory Commission,Proposed Alternative for the Third 10- Year Inservice InspectionProgram, dated April 27, 2009, ADAMS Accession NumberML091260502.

3. Letter from Douglas A. Broaddus (NRC) to Michael J. Annacone(CP&L), Brunswick Steam Electric Plant, Unit I - ReliefRequests RR-42, RR-43, RR-44, and RR-45 for the Third 1 0-YearInterval Inservice Inspection Program Plan (TAC Nos. ME]]43,ME1144, ME]145, and ME]146), dated April 30, 2010, ADAMSAccession Number ML 100960547.

Ladies and Gentlemen:

By letter dated April 23, 1998, Carolina Power & Light Company (CP&L), now doingbusiness as Progress Energy Carolinas, Inc., submitted the third 10-year InserviceInspection Program for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2. Duringthe third inspection interval, the 1989 Edition of the American Society of MechanicalEngineers (ASME) Code, Section XI, with no addenda, was used for Class 1, 2, and 3components, unless otherwise permitted.

During the third 10-year interval, CP&L completed the required inservice examinations forBSEP, Unit 2, in accordance with the plan, except that certain components could not fullymeet the examination requirements specified in the 1989 ASME Code, Section XI,including the clarifications provided in ASME Code Case N-460. CP&L has determinedthat conformance to the Code requirement of essentially 100 percent coverage of weldvolume or area examined was impractical due to various constraints and limitations.

Progress Energy Carolinas. Inc.Brunswick Nuclear PlantP O Bus 10429Southport, NC 28461

Document Control DeskBSEP 10-0043 /

Accordingly, in accordance with 10 CFR 50.55a(a)(g)(5)(iii), CP&L requests NRCapproval of four 10 CFR 50.55a Requests for BSEP, Unit 2, copies of which are providedin Enclosures 1 through 4.

The third 10-year inservice inspection interval began on May 11, 1998. As allowed bysubarticle IWA-2430(d) of the ASME Code, Section XI, the third 10-year inspectioninterval was extended for one year. This extension enabled the examination of Unit 2components to coincide with the March 2009 B219R1 refueling outage. The third 10-yearinspection interval for BSEP, Unit 2 concluded on May 10, 2009. Similar alternativerequests for BSEP Unit 1 were submitted by CP&L's letter dated April 27, 2009, andsubsequently approved by NRC letter dated April 30,'2010.

No regulatory commitments are contained in this letter. Please refer any questionsregarding this submittal to Ms. Annette Pope, Supervisor - Licensing/Regulatory Programs,at (910) 457-2184.

Sincerely,

Phyllis N. MentelManager - Support ServicesBrunswick Steam Electric Plant

WRM/wrm

Enclosures:1. 10 CFR 50.55a Request Number RR-472. 10 CFR 50.55a Request Number RR-483. 10 CFR 50.55a Request Number RR-494. 10 CFR 50.55a Request Number RR-50

Document Control DeskBSEP 10-0043 /

cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region IIATTN: Mr. Luis A. Reyes, Regional Administrator245 Peachtree Center Ave, NE, Suite 1200Atlanta, GA 30303-1257

U. S. Nuclear Regulatory CommissionATTN: Mr. Philip B. O'Bryan, NRC Senior Resident Inspector8470 River RoadSouthport, NC 28461-8869

U. S. Nuclear Regulatory Commission (Electronic Copy Only)ATTN: Mrs. Farideh E. Saba (Mail Stop OWFN 8G9A)11555 Rockville PikeRockville, MD 20852-2738

Chair - North Carolina Utilities CommissionP.O. Box 29510Raleigh, NC 27626-0510

Mr. Jack M. Given, Jr., Bureau ChiefNorth Carolina Department of LaborBoiler Safety Bureau1101 Mail Service CenterRaleigh, NC 27699-1101

BSEP 10-0043Enclosure 1.

Page 1 of 16

10 CFR 50.55a Request Number RR-47

Proposed Alternative In Accordance with 10 CFR 50.55a(g)(5)(iii)

- Inservice Inspection Impracticality -

1. ASME Components Affected

Code Class: 1

References: Subarticle IWB-2500, Table IWB-2500-1

Examination Categories: B-D

Item Numbers: B3.90

Description: Volumetric Examination Coverage

Component Numbers: Listed in Table RR-47-1, attached.

2. Applicable Code Edition and Addenda

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 1989 Edition with no Addenda.

3. Applicable Code Requirement

Subarticle IWB-2500 states, in part: "Components shall be examined and tested as specifiedin Table IWB-2500-1 ." Table IWB-2500-1 requires a volumetric examination or a surfaceand volumetric examination be performed on the component based on Category and ItemNumber.

Carolina Power & Light Company (CP&L), now doing business as Progress EnergyCarolinas, Inc., adopted and applied ASME Code Case N-460, Alternative ExaminationCoverage for Class 1 and Class 2 Welds, Section XI, Division 1, (i.e., Reference 1) at theBrunswick Steam Electric Plant (BSEP) during the third 10-year inservice inspectioninterval. Code Case N-460 is applicable when the entire examination volume or area cannotbe examined due to interference by another component or part geometry. Under suchcircumstances, a reduction in examination coverage on any Class 1 or Class 2 weld may beaccepted provided that the reduction in coverage for that weld is less than 10 percent.

In October 2007, the NRC issued Regulatory Guide (RG) 1.147, Revision 15, InserviceInspection Code Case Acceptability, ASME Section XI, Division 1 (i.e., Reference 2). InRG 1.147, the NRC identifies the ASME Code Cases they have determined to be acceptablealternatives to applicable sections of Section XI, and that those Code Cases may be used bylicensees without requesting NRC authorization provided they are used with any identified

BSEP 10-0043Enclosure 1

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limitations or modifications. Table 1 of RG 1.147 lists the following Code Case asacceptable for use by a licensee with no identified limitations or modifications:

Code Case N-460, Alternative Examination Coverage for Class ] and Class 2 Welds,Section XI, Division ]

Code Case N-460 states, in part:

When the entire examination volume or area cannot be examined due to interference byanother component or part geometry, a reduction in examination coverage on any Class 1or Class 2 weld may be accepted provided the reduction in coverage for that weld is lessthan 10 percent.

NRC Information Notice (IN) 98-42 (i.e., Reference 3) states that the NRC determined that areduction in coverage of less than 10 percent to be "essentially 100 percent." IN 98-42 states,in part:

The NRC has adopted and further refined the definition of 'essentially 100 percent' tomean 'greater than 90 percent' in 10 CFR 50.55a(g)(6)(ii)(A)(2) for required examinationcoverage of reactor pressure vessel welds. This standard has been applied to allexaminations of welds and other areas required by ASME Section XI.

The applicable examination area or volume and method required from Table IWB-2500-1,for the affected components, is shown in Table RR-47-1.

4. Impracticality of Compliance

BSEP, Unit 2 systems and components were designed and fabricated before the examinationrequirements of the ASME Code, Section XI, were formalized and published. Therefore, theBSEP was not specifically designed to meet the requirements of the ASME Code,Section XI, and full compliance is not feasible or practical within the limits of the currentplant design.

10 CFR 50.55a recognizes the limitations to inservice inspection of components inaccordance with Section XI of the ASME Code that are imposed due to early plants' designand construction, as follows:

10 CFR 50.55a(g)(1):

For a boiling or pressurized water-cooled nuclear power facility whose constructionpermit was issued before January 1, 1971, components (including supports) must meetthe requirements of paragraphs (g)(4) and (g)(5) of this section to the extent practical.


Page 3 of 16

10 CFR 50.55a(g)(4):

Throughout the service life of a boiling or pressurized water-cooled nuclear powerfacility, components (including supports) which are classified as ASME Code Class 1,Class 2 and Class 3 must meet the requirements, except design and access provisions andpreservice examination requirements, set forth in Section XI of editions of the ASMEBoiler and Pressure Vessel Code and Addenda that become effective subsequent toeditions specified in paragraphs (g)(2) and (g)(3) of this section and that are incorporatedby reference in paragraph (b) of this section, to the extent practical within the limitationsof design, geometry and materials of construction of the components.

10 CFR 50.55a(g)(5)(iii):

If the licensee has determined that conformance with certain code requirements isimpractical for its facility, the licensee shall notify the Commission and submit, asspecified in § 50.4, information to support the determinations.

In accordance with 10 CFR 50.55a(g)(5)(iii), CP&L has determined that it is impractical tomeet the examination coverage requirements of ASME Code Case N-460. The ASME Code,Section XI, requires volumetric (i.e., UT) examination of nozzle-to-vessel welds from twosides of the weld in order to be 100 percent complete. Due to nozzle configurations of thesecomponents, ultrasonic examinations are limited to scanning on the shell-side of the nozzlewelds.

5. Burden Caused by Compliance

Compliance with the examination coverage requirements of the ASME Code, Section XI,would require modification, redesign, or replacement of components where geometry isinherent to the component design.

6. Proposed Alternative and Basis for Use

Proposed Alternative

In accordance with 10 CFR 50.55a(g)(5)(iii), relief is requested for the components listed inTable RR-47-1 on the basis that the required examination coverage of "essentially100 percent" is impractical due to physical obstructions and the limitations imposed bydesign, geometry and materials of construction. No alternative examination is beingproposed.

CP&L performed qualified examinations that achieved the maximum, practical amount ofcoverage obtainable within the limitations imposed by the design of the components.Additionally, as Class 1 examination Category B-P components, a visual (VT-2) examinationis performed on these Reactor Coolant Pressure Boundary (RCPB) components during


Page 4 of 16

system pressure tests each refueling outage. This was completed during the 2009 refuelingoutage (i.e., the B219R1 outage), and no evidence of leakage was identified for thesecomponents.

Therefore, in accordance with 10 CFR 50.55a(g)(5)(iii), CP&L requests relief from therequirements of the ASME Code, Section XI, Table IWB-2500-1, Category B-D, Item B3.90,and proposes to credit the completed exams as acceptable alternatives that provide reasonableassurance of continued structural integrity.

Basis for Use

Due to the design of these welds it was not feasible to effectively perform a volumetricexamination of "essentially 100 percent" of the required volume. The nozzle-to-vessel weldsare accessible from the vessel plate side of the weld and are examined to the extent practical.

The nozzle design at BSEP does not allow for examination on the nozzle side of the weld.The outside blend radius of the nozzle forgings varies from 2.75 inches to 5 inches on thenozzles in question. The curvature of the surface prevents the transducer from maintainingcontact and proper coupling. Additional coverage for the limited areas was not achievable orpractical, based on the latest qualified ultrasonic technology, -nor by other consideredexaminations methods, such as radiography. Figure RR-47-4 provides a plant nozzleconfiguration drawing which shows the nozzle curvature and weld preparation that is typicalon all nozzles.

The volumetric examinations which were completed were performed with the followinginsonification angles (i.e., nominal) and modes of propagation.

0' Longitudinal450 Shear600 Shear

These examinations identified no indications (i.e., see Table RR-47-1).

CP&L has concluded that if significant degradation existed in the subject welds, it wouldhave been identified by the examinations performed.

The BSEP reactor vessel water chemistry is controlled in accordance with the 2008 revisionto the BWR Water Chemistry Guidelines (i.e., Reference 4). Also, a Hydrogen WaterChemistry System is used to reduce the oxidizing environment in the reactor coolant. Theseadditional measures provide added assurance against the initiation of cracking or corrosionfrom the inside surface of the reactor vessel. An inerted primary containment environmentduring operation provides assurance of corrosion protection on the outside surface of thereactor vessel.

The provisions described above as an alternative to the Code requirement will continue toprovide reasonable assurance of the structural integrity of the subject welds. The


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examinations were completed to the extent practical and no reportable indications werepresent. VT-2 examinations performed on the subject components during system pressuretesting each refueling outage, in accordance with Examination Category B-P, providecontinued assurance that the structural integrity of the subject components is maintained.Additionally, the BSEP Water Chemistry Program and inerted primary containmentenvironment provide added measures of protection for the component materials.

6. Duration of the Proposed Alternative

Use of the proposed alternative is applicable to the third 10-year inservice inspection intervalat BSEP, Unit 2. The third 10-year interval began on May 11, 1998, and ended on May 10,2009.

7. Precedents

1. CP&L submitted a similar relief request in the second 10-year interval (i.e., see CP&L'sletter dated February 19, 1999, Serial: BSEP 99-0009, which submitted Relief RequestRR-12, Revision 1). In a Safety Evaluation Report issued February 1, 2000, TACNo. MA4869 and MA4870, Relief Request RR-23 was approved.

2. CP&L submitted a similar relief request for BSEP, Unit 1 applicable to the third 10-yearinterval (i.e., see CP&L's letter dated April 27, 2009, Serial: BSEP 09-0024, ADAMSAccession Number ML091260502, which submitted Relief Request RR-42).

8. References

1. Code Case N-460, Alternative Examination Coverage for Class ] and Class 2 Welds,Section XI, Division ].

2. NRC Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASMESection XI, Division 1, Revision 15, October 2007.

3. NRC Information Notice 98-42, Implementation of 10 CFR 50.55a(g) Inservice

Inspection Requirements, December 1, 1998.

4. BWRVIP-190: BWR Vessel and Internals Project, BWR Water Chemistry Guidelines -2008 Revision, Electric Power Research Institute Topical Report TR- 10 16579.


Page 6 of 16

TABLE RR-47-1UltrasonicTechnique

System and S=Shear Wave Required PercentComponent L=Longitudinal Examination Coverage Examination

Component ID Description Wave Volume Obtained Results Remarks

2B11-RPV-N3A Reactor Vessel, Main 0, 45S, 60S, ASME Code, Figure 51.7% No Reportable Examination limited dueSteam Nozzle N3A IWB-2500-7(b) Indications to nozzle configuration.

Examination performedprior to implementation ofAppendix VIII,Supplements 4 and 6.

2B11-RPV-N3B Reactor Vessel, Main 0,45S,60S, ASME Code, Figure 51.7% No Reportable Examination limited dueSteam Nozzle N3B IWB-2500-7(b) Indications to nozzle configuration.


2B11-RPV-N3C Reactor Vessel, Main 0,45S,60S, 70L ASMECode, Figure 51.7% No Reportable Examination limited dueSteam Nozzle N3C IWB-2500-7(b) Indications to nozzle configuration.


2B11-RPV-N3D Reactor Vessel, Main 0,45S,60S, 70L ASME Code, Figure 51.7% No Reportable Examination limited dueSteam Nozzle N3D IWB-2500-7(b) Indications to nozzle configuration.


2B11-RPV-N6A Reactor Vessel, Head 0,45S,60S, 70L ASME Code, Figure 50.1% No Reportable Examination limited dueSpray Nozzle N6A IWB-2500-7(b) Indications to nozzle configuration.



Page 7 of 16




2B11-RPV-N6B Reactor Vessel, Head 0, 45S, 60S, 70L ASME Code, Figure 50.-1% No Reportable Examination limited dueSpray Nozzle N6B IWB-2500-7(b) Indications to nozzle configuration.

Examination performedprior to implementation ofAppendix Vill,Supplements 4 and 6.

2B11-RPV-N7 Reactor Vessel, Head 0,45S, 60S, 70L ASME Code, Figure 50.1% - No Reportable Examination limited dueInstrument Penetration IWB-2500-7(b) Indications to nozzle configuration.Nozzle N7 Examination performed

prior to implementation ofAppendix Vill,Supplements 4 and 6.

2B11-RPV-N10 Reactor Vessel, Core 0,45S,60S, 70L ASME Code, Figure 44.5% No Reportable Examination limited dueDifferential Pressure IWB-2500-7(b) Indications to nozzle configuration.Instrumentation, Examination performedNozzle NO 10prior to implementation of

Appendix VIII,Supplements 4 and 6.

2B 11-RPV-N 12A Reactor Vessel, Level 0,45S,60S, ASME Code, 44.5% No Reportable Examination limited dueInstrumentation, Figure IWB-2500-7(b) Indications to nozzle configuration.Nozzle Nl12A Examination performed

prior to implementation ofAppendix VIII,Supplements 4 and 6.


Page 8 of 16




2B11-RPV-N12B Reactor Vessel, Level 0, 45S, 60S, 70L ASME Code, 44.5% No Reportable Examination limited dueInstrumentation, Figure IWB-2500-7(b) Indications to nozzle configuration.Nozzle N 12B Examination performed

prior to implementation ofAppendix VIII,Supplements 4 and 6.


Page 9 of 16

COVERAGE CALCULATION FOR 2B1 1-RPV-N3A, N3B, N3C, N3Dr iSee Figure RR-47-1 for examination areas and coverage

00 (JNMD)

30.6 in2= 59.5/%

450 Circ. CW (JMID)

WELD = 100%

BM = 22.2 in2 = 51.6%

=> 450 Circ CW coverage = 16.3 + (.516)(83.7) = 59.50/

450 Circ. CCW (JMHD)

WELD = 100%

BM = 22.2 in2 = 51.6%

=> 45' Circ CW coverage = 16.3 + (.516)(83.7) = 59.5/

600 Circ. CW (JMHD)

WELD = 100%

BM 22.2 in2 = 51.6%

=> 450 Circ CW coverage = 16.3 + (.516)(83.7) = 59.5°

600 Circ. CCW (JMHD)

WELD = 100%

BM = 22.2 in2 = 51.6%

=> 450 Circ CW coverage = 16.3 + (.516)(83.7) = 59.59

450 axial in (BbEHD)

WELD = 100%

BM = 33.2 in2 = 77.2%

=> 450 axial in coverage = 16.3 + (.772)(83.7) = 80.9%

450 axial out = 0%

600 axial in (BaEHD)

WELD = 100%

BM = 36.4 in2 = 84.7%

=> 60' axial in coverage = 16.3 + (.847)(83.7) = 87.2%

600 axial out = 0%

WRV (AEHD) =51.4 in2

Weld (BCFG) 8.4 in2 = 16.3% of WRV

Base Metal = (51.4 - 8.4) = 43 in2 = 83.7%of WRV

/o

0

/

'C0

TOTAL COVERAGE = (59.5 +59.5 + 59.5 + 59.5 + 59.5 +80.9 + 87.2 + 0 + 0)/9

* Total Coverage = 51.7%


Page 10 of 16

COVERAGE CALCULATION FOR 2B 11 -RPV-N6A, N6B, N7

See Figure RR-47-2 for examination areas and coverage

00 Coverage (LcKE)

7.8 in2= 54.5%450 Circ. CW (LcKE)

WELD (CHJD) = 100%

BM (DJKE)= 5.9 in2 = 52.7% =450 Circ. CCW (LcKE)

WELD (CHJD) = 100%

BM (DJKE)= 5.9 in2 = 52.7% =

600 Circ. CW (LcKE)

WELD (CHJD) = 100%

BM (DJKE)= 5.9 in2 = 52.7% =

600 Circ. CCW (LcKE)

WELD (CHJD) = 100%

BM (DJKE)= 5.9 in2 = 52.7% =

450 axial in (CbFKE)

WELD (DCcGJ)= 100%

BM (ECfFK) = 8.07 in2 = 71.7%

450 axial out(weld) = 0%

WRV (AEFK) = 14.3 in2

Weld (CDJH) 2.25 in2 =15.7% of WRV

Base Metal = (14.3 - 2.25) = 12.05 in2 =84.3% of WRV

> 15.7 + (.527)(84.3) = 59.6%

> 15.7 + (.527)(84.3) = 59.6

> 15.7 + (.527)(84.3) = 59.6

> 15.7 + (.527)(84.3) = 59.6

=> 16.7 + (.717)(84.3) = 76. 1%

600 axial in (CaFKE)

WELD(DCaGJ) = 100%

BM = 8.81 in2 = 78.3% => 16.7 + (.783)(84.3) 81.7%

600 axial out = 0%

TOTAL COVERAGE = (54.5 + 59.6 + 59.6 59.6 + 59.6 + 76.1 + 81.7+0 + 0)/9

* Total Coverage = 50.1%


Page 11 of 16

COVERAGE CALCULATION FOR 2B1 I-RPV-N 10, N 12A, N12B


00 Coveraje (DBcH) WRV (AEHD) = 52.7 in2

24.6 in2== 46.7% Weld (BCFG) = 8.5 in2 = 16.1% of WRV

Base Metal = (52.7 - 8.5) = 44.2 in2 = 83.9% of WRV450 Circ. CW (BcHD)

WELD (CBcG)= 5.5 in2 = 64.7%

BM = 19.8 in2 = 44.7%

=> 450 Circ CW coverage = (.647)16.1 + (.447)83.9 = 47.9%

450 Circ. CCW (BcHD)

WELD (CBcG)= 5.5 in2 = 64.7%

BM = 19.8 in2 = 44.7%=> 450 Circ CCW coverage = (.647)16.1 + (.447)83.9 47.9%

600 Circ. CW (BcHD)

WELD (CBcG)= 5.5 in2 = 64.7%

BM = 19.8 in2 = 44.7%

=> 600 Circ CW coverage = (.647)16.1 + (.447)83.9 = 47.9%

600 Circ. CCW (BcHD)

WELD (CBcG)= 5.5 in2 = 64.7%

BM = 19.8 in2 =-44.7%

=> 600 Circ CCW coverage = (.647)16.1 + (.447)83.9 = 47.9%

450 axial in (BbEHD)

WELD (BCGF)= 100%

BM = 32.3 in2 = 73.1%

=> 450 axial in coverage = 16.1 + (.731)(83.9) = 77.4%


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450 axial out = 0%

600 axial in

WELD (BCGF)= 100%

BM = 36.3 in2= 82.1%

=> 600 axial in coverage 16.1 + (.821)(83.9) 85%

600 axial out = 0%

TOTAL COVERAGE = (46.7 +49.7 + 49.7 + 49.7 + 49.7 +77.4 + 85 + 0 + 0)/9

Total Coverage = 44.5%


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E MF G H

N3 NOZZLE COVERAGE

FIGURE RR-47-1 SCALE 1:2


Page 14 of 16

F cHl- I K•

N6 AND N7 NOZZLE COVERAGE

FIGURE RR-47-2


Page 15 of 16

IIII

E C G H

N10 AND N12 NOZZLE COVERAGE

FIGURE RR-47-3


Page 16 of 16

Typical Nozzle Configuration Drawing

Figure RR-47-4


Page 1 of 10

10 CFR 50.55a Request Number RR-48




Code Class: 1


Examination Categories: As listed in Table RR-48-1, attached.

Item Numbers: Listed in Table RR-48-1, attached.

Description: Limited Coverage for Welds in Examination Category B-J andR-A, Pressure Retaining Piping Welds

Component Numbers: As listed in Table RR-48-1, attached.




By letter dated April 20, 2001 (i.e., Reference 1), Carolina Power & Light Company (CP&L),now doing business as Progress Energy Carolinas, Inc., submitted the initial risk-informedinservice inspection (RI-ISI) Program for the Brunswick Steam Electric Plant (BSEP). Theinitial RI-ISI program was developed using the process described in Electric Power ResearchInstitute (EPRI) Topical Report (TR) 112657, Revision B-A, Revised Risk-Informed InserviceInspection Evaluation Procedure, and using ASME Code Case N-578, Risk-InformedRequirements for Class 1, Z and 3 Piping, Method B (i.e., Reference 2). The program wasapproved for use by the NRC in a Safety Evaluation issued by letter dated November 28,2001 (i.e., Reference 3).

This relief request applies to eight (8) ASME Code Class 1 pressure-retaining piping welds.These welds were examined after the implementation of RI-ISI. In the BSEP RI-ISIprogram, these seven welds correspond to Examination Category R-A, Item R1.20 weldsusing the format in ASME Code Case N-578-1. Use of Code Case N-578-1 nomenclature isnot intended to imply that the BSEP RI-ISI program is based on Code Case N-578-1. CodeCase N-578-1 is an unapproved code case, as shown in Regulatory Guide 1.193 (i.e.,Reference 4), and BSEP has not requested nor received approval to implement CodeCase N-578-1. Rather, to maintain consistency with established ASME Code, Section XI


Page 2 of 10

conventions, the weld categorization scheme of Code Case N-578-1 was adopted at BSEP toassist in assigning weld examination requirements. Code Case N-578-1 establishes a "R-A"weld category and weld item numbers Ri. 10 through R1.20, which allows BSEP tocategorize RI-ISI piping welds in a manner similar to the standard ASME Section XI pipeweld program. The applicable ASME Code Examination Category and Item Numbers, andRI-ISI program Examination Category and Item Number, are shown in the attachedTable RR-48-1.

Subarticle IWB-2500 states, in part: "Components shall be examined and tested as specifiedin Table IWB-2500-1 ." Table IWB-2500-1 requires a volumetric examination or a surfaceand volumetric examination be performed on the components based on their category and'item numbers.

Figure IWB-2500-8 requires a volumetric examination of a minimum volume of the innerone-third thickness of the weldment. The weldment consists of the weld and the basematerial on each side of the weld equal to a distance of 1/4-inch on each side of the weldcrown. In addition, the ultrasonic examination must meet the performance demonstrationrequirements in the ASME Code, Section XI, Appendix VIII. Essentially 100 percent of therequired volume of each weld must be inspected. Code Case N-460, AlternativeExamination Coverage for Class 1 and Class 2 Welds (i.e., Reference 5), is applicable whenthe entire examination volume or area cannot be examined due to interference by anothercomponent or part geometry. Under such circumstances, a reduction in examinationcoverage on any Class 1 or Class 2 weld may be accepted provided that the reduction incoverage for that weld is less than 10 percent.

In October 2007, the NRC issued Regulatory Guide 1.147, Revision 15, Inservice InspectionCode Case Acceptability, ASME Section XI, Division I (i.e., Reference 6). In RegulatoryGuide 1.147, the NRC identifies the ASME Code Cases they have determined to beacceptable alternatives to applicable sections of Section XI, and that those Code Cases maybe used by licensees without requesting NRC authorization provided they are used with anyidentified limitations or modifications. Table 1 of Regulatory Guide 1.147 lists the followingCode Case as acceptable for use by a licensee with no identified limitations or modifications:

Code Case N-460, Alternative Examination Coverage for Class ] and Class 2 Welds,Section XI, Division ]

Code Case N-460 (i.e., Reference 5) states, in part:

When the entire examination volume or area cannot be examined due to interference byanother component or part geometry, a reduction in examination coverage on any Class Ior Class 2 weld may be accepted provided the reduction in coverage for that weld is lessthan 10 percent.


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NRC Information Notice 98-42 (i.e., Reference 7) states that the NRC determined that areduction in coverage of less than 10 percent to be "essentially 100 percent." InformationNotice 98-42 states, in part:



The BSEP, Unit 2 systems and components were designed and fabricated before theexamination requirements of the ASME Code, Section XI, were formalized and published.Therefore, the BSEP was not specifically designed to meet the requirements of the ASMECode, Section XI, and full compliance is not feasible or practical within the limits of thecurrent plant design.


10 CFR 50.55a(g)(1):


10 CFR 50.55a(g)(4):


10 CFR 50.55a(g)(5)(iii):



Page 4 of 10

In accordance with 10 CFR 50.55a(g)(5)(iii), CP&L has determined that it is impractical tomeet the examination coverage requirements of Code Case N-460. The ASME Code,Section XI, requires volumetric (i.e., UT) examination of the welds from two sides of theweld in order to be 100 percent complete.





In accordance with 10 CFR 50.55a(g)(5)(iii), relief is requested for the components listed inTable. 2 on the basis that the required examination coverage of "essentially 100 percent" isimpractical due to physical obstructions and the limitations imposed by design, geometry,and materials of construction. No alternative examination is being proposed.

BSEP was at the end of the first period of the third 10-year inspection interval when RI-ISIwas approved (i.e., ADAMS Accession Number MLO 13320632) and implemented (i.e., seethe discussion in paragraph 3, page 2 of the NRC Safety Evaluation). Prior to the transitionto a risk-informed inspection program, weld examinations required performance of surfaceexaminations in accordance with Section XI of the ASME Code. Until the transition point(i.e., the end of the first period of the third inspection interval), 8 percent of the examinationsrequired by the ASME Code, Section XI had been completed for Examination Category B-Fand B-J piping welds. Beginning in the second period of the third interval, the componentsselected by the RI-ISI process replaced those formerly selected in accordance with theASME Code, Section XI criteria. Since 8 percent of the examinations had been completedduring the first period of the third interval, 92 percent of the RI-ISI examinations wereperformed during the second and third periods. Under the RI-ISI program, 61 Class 1 pipingwelds are required to be examined over a complete 10-year interval. Due to the mid-intervalimplementation of RI-ISI, 56 welds were required to be examined to complete the remainderof the interval. Of those 56 welds examined, BSEP is seeking relief on 8 welds.

Additionally, as Class I examination Category R-A components, a visual (i.e., VT-2)examination is performed on the subject components of the Reactor Coolant PressureBoundary during system pressure tests each refueling outage. This was completed during the2009 refueling outage (i.e., the B219R1 outage) and no evidence of leakage was identifiedfor these components.

The sound beam modes and insonification angles used complied with the requirements ofASME Code, Section XI, Appendix VIII. Table 2 includes information on the sound beam


Page 5 of 10

modes and insonification angles. Coverage volumes are summarized in Table RR-48-1.Because the examinations were completed from one side (i.e., 50 percent maximumcoverage), examination coverage plots were not generated.

The ultrasonic examinations of welds in the R-A Category, that are limited, were foraustenitic components. These components were examined using an ultrasonic examinationprocedure based on the requirements of "PDI Generic Procedure for the UltrasonicExamination of Austenitic Pipe Welds UT-PDI-2." This procedure states, "Where dual sideaccess is not possible, the examination shall be performed from a single side of the weld." Insituations where components were limited to single side access due to configuration (i.e., asdescribed in Table RR-48-1), BSEP has only taken credit for 50 percent of examination.

Therefore, in accordance with 10 CFR 50.5 5a(g)(5)(iii), CP&L requests relief from therequirements of the ASME Code, Section XI, Table IWB-2500-1, Category B-J, Items B9.11and B9.31, and ASME Code Case N-578-1, Category R-A, Item R1.20. CP&L proposes toutilize the completed exams as acceptable alternatives that provide reasonable assurance ofcontinued structural integrity

CP&L has performed qualified examinations that achieved the maximum, practical amountof coverage obtainable within the limitations imposed by the design of the components. Allother ASME Code Class 1 piping examinations in the RI-ISI Program have been completedin accordance with ASME Code volumetric requirements.

Basis for Use

The CP&L Nondestructive Examination (NDE) procedures incorporate inspection techniquesqualified under Appendix VIII of the ASME Code, Section XI, by the PerformanceDemonstration Initiative (PDI) for examination of the subject welds. For welds listed inTable 2, an ultrasonic examination was performed with examination personnel andexamination procedures qualified to ASME Code, Appendix VIII, as administered by theEPRI PDI.

Additionally, as Class I examination category B-P components, VT-2 examinations wereperformed on the subject components in association with the Reactor Coolant PressureBoundary system pressure test performed during the 2009 refueling outage. No evidence ofleakage was identified during this system test.

The provisions described above as an alternative to the Code requirement will continue toprovide reasonable assurance of the structural integrity of the subject welds. Therefore, inaccordance with 10 CFR 50.55a(g)(5)(iii), CP&L requests relief from the ASME Code,Section XI, examination requirements for the subject welds..


Page 6 of 10



7. References

1. Letter from David C. Dicello (CP&L) to the U.S. Nuclear Regulatory CommissionDocument Control Desk, Third 10-Year Inservice Inspection Program - Request forApproval of Risk-Informed Inservice Inspection Program, April 20, 2001, ADAMSAccession Number ML011170157.

2. Electric Power Research Institute (EPRI) Topical Report (TR) 112657, Revision B-A,Revised Risk-Informed Inservice Inspection Evaluation Procedure, and using ASMECode Case N-578, Risk-Informed Requirements for Class 1, 2, and 3 Piping, Method B.

3. Letter from Richard P. Correia (NRC) to J. S. Keenan (CP&L), Safety Evaluation for theRisk-Informed Inservice Inspection (RI-ISI) Program (TAC Nos. MB] 760 and MB] 761),November 28, 2001, ADAMS Accession Number ML013320632.

4. NRC Regulatory Guide 1.193, ASME Code Cases Not Approved for Use, Revision 2,October 2007.

5. Code Case N-460, Alternative Examination Coverage for Class ] and Class 2 Welds,Section XI, Division 1.


7. NRC Information Notice 98-42, Implementation of 10 CFR 50.55a(g) InserviceInspection Requirements, December 1, 1998.

l


Page 7 of 10

TABLE RR-48-1

ASMEASME Code Case Ultrasonic

IWB-2500 N-578-1 Technique

Exam Exam Category S=Shear WaveCategory and and L=Longitudinal

Weld Item No. Item No. Description Coverage Wave Limitation

2B32RECIRC-28-B-8 N/A R-A Elbow - Valve 50% 45S, 60S,60L Access limited to elbow side of weld only

R1.20 due to valve to elbow weld configurationPer PDI, the amount of coverage allowed

for one sided examinations is 50%

2B32RECIRC-28-B-9BC N/A R-A branch connection 50% 35S, 45S, 60L Access limited to pipe side of weld only

R1.20 (weld-o-let) due to Branch Connection weldconfigurationPer PDI, the amount of coverage allowed


2B32RECIRC-28-A-9 N/A R-A Valve - Pipe 50% 45S, 60L Access limited to pipe side of weld onlyR1.20 due to pipe to valve weld configuration

Per PDI, the amount of coverage allowed


2B32RECIRC-28-A-9BC-1 N/A R-A branch connection 50% 35S, 45S, 60L Access limited to pipe side of weld only

R1.20 (weld-o-let) due to Branch Connection weldconfigurationPer PDI, the amount of coverage allowedfor one sided examinations is 50%

2EI1l0-9-10-SWA N/A R-A branch connection 42.25% 45S, 60L Access limited to pipe side of weld only

R1.20 (weld-o-let) due to Branch Connection weldconfiguration and surface contour

2G31AYI-1-FWRIOA N/A R-A branch connection 50% 45S, 70S Access limited to pipe side of weld only

R1.20 (weld-o-let) due to Branch Connection weldconfigurationPer PDI, the amount of coverage allowed



Page 8 of 10

TABLE RR-48-1

ASMEASME Code Case Ultrasonic

IWB-2500 N-578-1 TechniqueExam Exam Category S=Shear Wave

Category and and L=LongitudinalWeld Item No. Item No. Description Coverage Wave Limitation

2B32FF-12-FWRRA1OA N/A R-A branch connection 50% 45S, 60L Access limited to pipeside of weld onlyR1.20 (sweep-o-let) due to Branch Connection weld

configurationPer PDI, the amount of coverage allowedfor one sided examinations is 50%

2B32FF-12-FWRRB13A N/A R-A branch connection 50% 45S,.60S Access limited to pipe side of weld onlyR1.20 (sweep-o-let) due to Branch Connection weld

I _configuration


Page 9 of 10

Weld 2B32RECIRC-28-B-8

This is a stainless steel elbow-to-valve weld. Due to configuration this is a one-sidedexamination. The risk category for this weld is 4(2) and the BWRVIP-75-A, IGSCC Categoryis C. This weld was examined after implementation of risk-informed ISI.

An ultrasonic examination was performed with examination personnel and examinationprocedures qualified to ASME Code, Appendix VIII, as administered by the EPRI PerformanceDemonstration Initiative (PDI), achieving limited coverage. Per PDI, the amount of Code-required volume allowed for one sided examinations is 50%.

Weld 2B32RECIRC-28-B-9BC

This is a stainless steel-to-stainless steel branch connection (weld-o-let) weld. Due toconfiguration this is a one-sided examination. The risk category for this weld is 4(2) and theBWRVIP-75-A, IGSCC Category is D. As part of the BWRVIP-75-A, IGSCC Category D, thisweld was examined twice during the third inspection interval.

An ultrasonic examination was performed with examination personnel and examinationprocedures qualified to ASME Code, Appendix VIII, as administered by the EPRI PDI,achieving limited coverage. Per PDI, the amount of Code-required volume allowed for one sidedexaminations is 50%.

Weld 2B32RECIRC-28-A-9

This is a stainless steel valve to pipe weld. Due to configuration this is a one sided examination.The risk category for this weld is 4(2) and the BWRVIP-75-A, IGSCC Category is C.


Weld 2B32RECIRC-28-A-9BC-1

This is a stainless steel-to-stainless steel branch connection (weld-o-let) weld. Due toconfiguration this is a one-sided examination. The risk category for this weld is 4(2) and theBWRVIP-75-A, IGSCC Category is D.



Page 10 of 10

Weld 2E110-9-10-SWA

This is a stainless steel-to-stainless steel branch connection (weld-o-let) weld. Due toconfiguration this is a one-sided examination. The risk category for this weld is 4(2) and theBWRVIP-75-A, IGSCC Category is C.

An ultrasonic examination was performed with examination personnel and examinationprocedures qualified to ASME Code, Appendix VIII, as administered by the EPRI PDI,achieving 42.25% coverage of the Code-required volume.

Weld 2G31AYI-1-FWR1OA

This is a stainless steel-to-stainless steel branch connection (weld-o-let) weld. Due toconfiguration this is a one-sided examination. The risk category for this weld is 4(2) and theBWRVIP-75-A, IGSCC Category is D.


Weld 2B32FF-12-FWRRA1OA

This is a stainless steel-to-stainless steel branch connection (sweep-o-let) weld. Due toconfiguration this is a one-sided examination. The risk category for this weld is 4(2), and theBWRVIP-75-A, IGSCC Category is B.


Weld 2B32FF-12-FWRRB13A

This is a stainless steel-to-stainless steel branch connection (sweep-o-let) weld. Due toconfiguration this is a one-sided examination. The risk category for this weld is 4(2), and theBWRVIP-75-A, IGSCC Category is B.



Page 1 of 14

10 CFR 50.55a Relief Request Number RR-49.

Proposed Alternative In Accordance with 10 CFR 50.55 a(g)(5)(iii)



Code Class: 1


Examination Categories: B-A, "Pressure Retaining Welds in Reactor Vessel"

Item Number: B1 .22, "Head Welds, Meridional"B1.30, "Shell to Flange Welds"

Description: Volumetric examination

Component Numbers: 2B 11 -RPV-J3 1, Bottom Head Meridional Weld2B 11 -RPV-J42, Bottom Head Meridional Weld2B 11 -RPV-F 1/lB 11 -RPV-F2 RPV Shell-to-Flange Weld




Subarticle IWB-2500 states, in part: "Components shall be examined and tested as specifiedin Table IWB-2500-1." Table IWB-2500-1, Examination Category B-A, Item B1.22,requires volumetric examination of meridional reactor vessel head welds as defined byFigure IWB-2500-3. Table IWB-2500-1, Examination Category B-A, Item B1.30, requiresvolumetric examination of reactor vessel flange to shell welds as defined byFigure IWB-2500-4. Note 2 identifies that the examination include essentially 100 percent ofthe weld length.

Carolina Power & Light Company (CP&L), now doing business as Progress EnergyCarolinas, Inc., adopted and applied ASME Code Case N-460, Alternative ExaminationCoverage for Class 1 and Class 2 Welds, (i.e., Reference 1) at the Brunswick Steam ElectricPlant (BSEP) during the third 10-year inservice inspection interval. Code Case N-460 isapplicable when the entire examination volume or area cannot be examined due tointerference by another component or part geometry. Under such circumstances, a reductionin examination coverage on any Class 1 or Class 2 weld may be accepted provided that thereduction in coverage for that weld is less than 10 percent.


Page 2 of 14

In October 2007, the NRC issued Regulatory Guide (RG) 1.147, Revision 15, InserviceInspection Code Case Acceptability, ASME Section XI, Division 1 (i.e., Reference 2). InRG 1.147, the NRC identifies the ASME Code Cases they have determined to be acceptablealternatives to applicable sections of Section XI, and that those Code Cases may be used bylicensees without requesting NRC authorization provided they are used with any identifiedlimitations or modifications. Table 1 of RG 1.147 lists Code Case N-460, AlternativeExamination Coverage for Class I and Class 2 Welds, Section XI, Division 1, as acceptablefor use by a licensee with no identified limitations or modifications. Code Case N-460 states,in part:

When the entire examination volume or area cannot be examined due to interference byanother component or part geometry, a reduction in examination coverage on any Class 1or Class 2 weld may be accepted provided the reduction in coverage for that weld is lessthan 10 percent.

NRC Information Notice (IN) 98-42 (i.e., Reference 3) states that the NRC determined that areduction in coverage of less than 10 percent to be "essentially 100 percent." IN 98-42 states,in part:





10 CFR 50.55a(g)(1):



Page 3 of 14

10 CFR 50.55a(g)(4):


10 CFR 50.55a(g)(5)(iii):


In accordance with 10 CFR 50.55a(g)(5)(iii), CP&L has determined that it is impractical tomeet the examination coverage requirements of Code Case N-460. The ASME Code,Section XI, requires volumetric (i.e., UT) examination of essentially 100 percent of the weldlength. Due to the configurations of these components, ultrasonic examinations are limitedto scanning on the accessible areas outside the reactor vessel.





In accordance with 10 CFR 50.55a(g)(5)(iii), relief is requested for the affected componentson the basis that the required examination, coverage of "essentially 100 percent" isimpractical due to physical obstructions and the limitations imposed by design, geometry,and materials of construction. No alternative examination is being proposed. The supportskirt for the reactor pressure vessel would have to be redesigned for BSEP to achieve100 percent volumetric coverage.

Basis for Use (Welds 2B 11 -RPV-J31 and 2B 11 -RPV-J42)

Welds 2B 11 -RPV-J31 and 2B 11 -RPV-J42 extend meridionally from one side of thehemispherical bottom head to the other. These welds are approximately 213 inches in


Page 4 of 14

length. The reactor pressure vessel sits on an approximately 194 inch diameter integrallywelded support skirt. This support skirt obstructs approximately 194 inches of each of thebottom head welds. See Figure RR-49-1. Typically, any control rod drive (CRD)maintenance activity is performed through access provided from under the vessel at the CRDflanges. The area inside the reactor support skirt man-way provides access to the upperportions of the CRD housings. This inside area contains 137 CRD housings, 43 in-corepenetrations, and one bottom head drain line. The housings are 6 inches in diameter and thedistance between each of the housings is only 6 inches. The elevation between the reactorvessel and insulation, within the man-ways, ranges from approximately 4 feet at the outerdiameter to approximately 12 inches at the center of the reactor. This does not allowphysical access. The CRD housings also limit the total amount of reactor vessel support skirtweld volume which can be examined. This congestion is illustrated in the attached drawingsand pictures.

During the third 10-year inservice inspection interval, a UT examination was performedusing 600 longitudinal wave from both sides to the accessible portion of the welds.100 percent of the accessible portion of these welds, outside the reactor pressure vesselsupport skirt, was examined. No recordable indications were observed during theseexaminations. Examination personnel and examination procedures were qualified to theASME Code, Appendix VIII, as administered by the EPRI Performance DemonstrationInitiative (PDI), The examinations achieved 8.9 percent Code-required coverage on each ofthe welds. This coverage is the maximum extent practical since access to the inside of thesupport skirt is not possible. In addition, each refueling outage, a visual (VT-2) examinationis also performed in conjunction with system pressure testing. Reactor coolant system leakrate limitations and atmospheric particulate radioactivity monitoring also ensure that anyleakage would be detected prior to gross failure.

Therefore, in accordance with 10 CFR 50.55a(g)(5)(iii), CP&L requests relief from therequirements of the ASME Code, Section XI, Table IWB-2500-1, Category B-A Item B1.22,and proposes to use the volume of coverage obtained for welds 2B 11 -RPV-J3 1 and2B 11 -RPV-J42 during the UT examination and the associated pressure testing performed asacceptable alternatives that provide reasonable assurance of continued structural integrity.

Items attached include the following:

1. Plant Drawing FP-9527 50208, CRD As-Built with J-weldlocations added

2. Plant Drawing FP-9527-5014, Bottom Head Dollar Assembly

3. Plant Drawing FP-5609, Sheet I C, Reactor Assembly

4. Plant Drawing C-02404, Sheet 2-1, ISI Isometric Drawing

5. Photograph - Upper CRD Welds


Page 5 of 14

Basis for Use (Weld 2B1 1-RPV-F1/F2)

2B1 1-RPV-F1 and 2B1 1-RPV-F2 is one weld, which has been assigned unique ID numbersfor tracking purposes. 2B11-RPV-F1/F2 is a circumferential weld that attaches the RPVflange to the upper shell. 2B 11 -RPV-F 1 designates the portion of the weld from 00 to 1800and 2B1 1-RPV-F2 designates the portion of the weld from 1800 to 360'.

The shell-to-flange configuration is a structural discontinuity comprised of a ring segmentwelded to a flange segment. The flange segment is thicker than the ring segment and thiscreates a transition on the outside diameter (OD) surface. This OD transition limits thephysical scanning area of the transducer. Loss of contact between the part and the ultrasonictransducer occurs when trying to scan over the transition. No ultrasound enters the part onceloss of contact occurs (i.e., see Figure RR-49-2).

These examinations were performed. from the outside surface, in calendar year 2000, usingthe industry-accepted technology that was available. At that time, the technology forexamination from the inside surface was still emerging and was not yet considered proventechnology for commercial application. Going forward, these welds will be examined usingASME Section XI, Appendix VIII techniques, which will provide an improved examinationwith a greater amount of weld examination coverage.

These examinations were performed with the following insonification angles (i.e., nominal)and modes of propagation:

00 Longitudinal450 Shear

60' Shear

No recordable indications were observed during these examinations.

Applicable drawings and sketches are provided in the Attachment 49-1

During the third 10-year inservice inspection interval, a UT examination was performed, tothe extent practical, in accordance with ASME Code, Section XI. These weld examinationswere completed prior to the implementation of inspection techniques qualified underAppendix VIII of the ASME Code, Section XI, administered by the EPRI PDI. As shown onFigure RR-49-2, the examination achieved 64 percent Code-required coverage on the weld.In addition, each refueling outage, a VT-2 examination is also performed in conjunction withsystem pressure testing. Reactor coolant system leak rate limitations and atmosphericparticulate radioactivity monitoring also ensure that any leakage would be detected prior togross failure.

The design configuration/restriction makes compliance with the ASME Code-requiredexamination coverage requirements impractical. Reactor pressure vessel modificationswould be needed to meet the ASME Code requirements, which would impose a considerableburden on BSEP, Unit 2.

BSEP 10-0043

Enclosure 3Page 6 of 14

Therefore, in accordance with 10 CFR 50.55a(g)(5)(iii), CP&L requests relief from therequirements of the ASME Code, Section XI, Table IWB-2500-1, Category B-A, Item B 1.30,and proposes to use the volume of coverage obtained for welds 2B 11 -RPV-F 1 and2B 11 -RPV-F2 during the UT examination and the associated pressure testing performedprovides reasonable assurance of the continued structural integrity of the subject welds andprovides an acceptable level of quality and safety.


Use of the proposed alternative is applicable to the third 10-year inservice inspection intervalat BSEP, Unit 2. The third began on May 11, 1998, and ended on May 10, 2009, for BSEP,Unit 2.

7. References

1. Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1.




Page 7 of 14

2B11-RPV-J42

Accessible portion ofJ31 and J42 welds 9.5"each side

RPV SKIRT WELD

C~'s

22B1 I-RPV-J31CRD nozzles block access towelds inside skirt

FIGURE RR-49-1

ACCESS LIMITATIONS.OF 1B11-RPV-J31 & J42 WELDS


Page 8 of 14

COVERAGE CALCULATION FOR 2B 11 -RPV-F 1, F2


00 Coverage (AEba)52.4 n 2 ~ 6.6%WRV (AEHD) = 60.5 in2

52.4 in 2= 86.6%Weld (BCGF) = 9.5 in2

= 15.7% of WRV

450 Cire. CW (AEba) Base Metal = (60.5 - 9.5) = 45 in 2 = 84.3% of WRV

WELD = 100%

BM = 36.9 in2 = 82%

=> 450 Circ CW coverage = 15.7 + (.82)(84.3) = 84.8%

450 Circ. CCW (AEba)

WELD = 100%

BM = 36.9 in2 = 82%

=> 450 Circ CCW coverage = 15.7 + (.82)(84.3) = 84.8%

600 Circ. CW (AEba)

WELD = 100%

BM = 36.9 in-2 = 82%

=> 450 Circ CW coverage = 15.7 + (.82)(84.3) = 84.8%

600 Circ. CCW (AEba)

WELD = 100%

BM = 36.9 in2 = 82%

=> 450 Circ CCW coverage = 15.7 + (.82)(84.3) = 84.8%

450 axial in (BcHEA)

WELD = 6.4 in2 =67.1%

BM = 35.8 in2 = 70.2%

=> 450 axial in coverage = (.671)(15.7) + (.702)(84.3) = 69.7%

450 axial out = 0%


Page 9 of 14

600 axial in (BdHEA)

WELD = 7.5 in2= 78.9%

BM=41.1 in2=80.5%

=> 600 axial in coverage = (.789)(15.7) + (.805)(84.3) = 80.2%

600 axial out = 0%

TOTAL COVERAGE = (86.6 + 84.8 + 84.8 +84.8 +84.8 +69.7 +80.2 + 0 + 0)/9

Total Coverage = 64%


Page 10 of 14

FLANGE

A

VESSEL

E G

FIGURE RR-49-22B 11-RPV-F 1, F2


Page 11 of 14

Attachment 49-1

Items attached include the following:1. Plant Drawing FP 9527-5012, Elevations Miscellaneous

Attachments

2. Excerpt from Plant Drawing FP 9527-5013 showing Seam F detail.

3. Excerpt from Plant Drawing showing Flange Seam F weldpreparation


Page 12 of 14

11


Page 13 of 14

6j/4

I.p

-a% - A *, - &

IsmWL V"Ah"I i - fOta fta fti .

ilt~ SCAM

e ~*. t~4b ~ TO ~A~C .z~tTAI.. S.. Z ~

I 0


Page 14 of 14

L2 4ON

j.

S7.

F

FlneSeam F

BSEP 10-0043Enclosure 3Page 1 of 8

10 CFR 50.55a Relief Request Number RR-50




Code Class: 2

Examination Category:

Item Number:

Description:

Component Number:

C-B, "Pressure Retaining Welds in Vessels"

C2.21,"Nozzle to Shell Welds"

Limited coverage for Welds in Examination Category C-B,Pressure Retaining Welds in Vessels

2El 1HX-2A-SWN4




The Inservice Inspection Program for Class 2, Pressure Retaining Welds in Vessels,Category C-B, is based on the requirements of the 1989 Edition of ASME, Section XI. Thisrelief request applies to one (1) ASME Code Class 2 pressure retaining weld in vessels.

ASME Code, Section XI, Table IWC-2500-1, Examination Category C-B, Item No. C2.21requires surface and volumetric examination of selected welds, as defined by FiguresIWC-2500-4(a) or IWC-2500-4(b).

NRC Information Notice (IN) 98-42 (i.e., Reference 1) states that the NRC determined that areduction in coverage of less than 10 percent to be "essentially 100 percent."

IN 98-42 states, in part:






10 CFR 50.55a(g)(1):


10 CFR 50.55a(g)(4):


10 CFR 50.55a(g)(5)(iii):


In accordance with 10 CFR 50.55a(g)(5)(iii), BSEP has determined that it is impractical tomeet the examination requirements of essentially 100 percent coverage. The ASME Code,Section XI, requires volumetric (i.e., UT) examination of nozzle-to-shell welds from twosides of the weld in order to be 100 percent complete. Due to nozzle configuriation of theResidual Heat Removal (RHR) heat exchanger, the ultrasonic examination is limited toscanning on the shell side of the nozzle weld.






In accordance with 10 CFR 50.55a(g)(5)(iii), relief is requested for the 2E 1HX-2A-SWN4weld examination on the basis that the required examination coverage of "essentially100 percent" is impractical due to the limitations imposed by design and geometry.

2E l1HX-2A-SWN4 is a Class 2 nozzle-to-shell weld of the RHR heat exchanger with noaccess to the nozzle side of the weld. An ultrasonic examination was performed to themaximum extent practical in accordance with the requirements of the ASME Boiler andPressure Vessel Code, Section XI, 1989 Edition with no Addenda, achieving 47.9 percentCode-required coverage. This examination was performed in accordance to proceduresqualified to ASME Code Section XI, as follows.

BSEP performed qualified examinations that achieved the maximum, practical amount ofcoverage obtainable within the limitations imposed by the design of the components. Thenozzle design at BSEP does not allow for examination on the nozzle side of the weld. Thecurvature of the nozzle forging surface prevents the transducer from maintaining contact andproper coupling as required by the procedure. Attachment RR-50-2 provides a typical scanlimitation coverage plot.

A magnetic particle examination was also performed from the outside diameter, achieving100 percent Code-required coverage

Additionally, as Class 2 component, a visual (VT-2) examination is performed on the RHRheat exchanger of the pressure boundary during system pressure tests each refueling outage.No evidence of leakage has been identified.

Basis for Use

The design configuration/restriction makes compliance with the ASME Code-requiredexamination coverage requirements impractical. Extensive modifications would be neededto meet the ASME Code requirements, which would impose a considerable burden on BSEP,Unit 2. The volume of coverage obtained for weld 2E 11HX-2A-SWN4 during the ultrasonicand magnetic particle examination and the associated pressure testing performed providesreasonable assurance of the continued structural integrity of the subject welds and providesan acceptable level of quality and safety.




7. References



TABLE RR-50-1

UltrasonicTechnique

S=Shear Wave Required PercentSystem and Component L=Longitudinal Examination Coverage

Component ID Description Wave Volume Obtained Examination Results Remarks

2El IHX-2A-SWN4 RHR Heat Exchanger 45S, 60S, ASME Code, 47.9% No service induced Examination limited due to

Nozzle to Shell Weld Figure IWC-2500-4 indications, nozzle configuration.


Attachments

Attachment RR-50-1 ASME Figure IWC-2500-4(b) Nozzle to Vessel Welds

Attachment RR-50-2 2EllHX-2A-SWN4 Coverage Plot


Attachment RR-50-1

ASME Figure IWC-2500-4(b)Nozzle to Vessel Welds

Ex~am. -su~i'dta~eA- B

-11,2 if in, 03 M' n~)

Exam. vol.C - b 4 E- F

GENIC"RL NO;:ýNozzle sizes aver NPS 4,j(DN 100); vessel thickness~ orA12In.43m)

FIG. IWC-250D-4 ROZZ~LE-TO-VES&EL WELDSfV n 6ti, '?2,lfl. 1-3 ýmmn)


Attachment RR-50-2

2E11HX-2A-SWN4 Coverage Plot

~j~e~aI~o~ PAGE __os 1CA NDE-CS-1.Rev.2II

NDE'DRAWING ATTACIIMENT

PROJECT '24J... JOB NO. UNIT 10 .2X

brunswick, unit 2, proposed alternatives for the third 10-year … · 2012-12-03 · jul 2 32010...

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