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March 19,2013

ENEM- POINT BEACh 7

NRC 2013-0018 10 CFR 50.55a

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27

10 CFR 50.55a Request. Relief Reauest RR4L1 lnservice lns~ection Im~racticality Examination Limitations Due to Configuration Fourth Ten-Year lnservice lns~ection Program Interval

In accordance with 10 CFR 50.55a, "Codes and Standards," Paragraph (a)(3)(i), NextEra Energy Point Beach, LLC (NextEra) requests that the Nuclear Regulatory Commission (NRC) grant relief from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (B&PV Code), Section XI, 1998 Edition through 2000 Addenda, for I00 percent coverage of the subject weld(s) due to geometric or design configuration, which limited the examination coverage which could be obtained. Relief is requested on the basis that alternative methods will provide an acceptable level of quality and safety.

NextEra requests approval of this request as described in the enclosure prior to December 31,201 3.

Summarv of Commitments

This submittal contains no new commitments or revisions to existing commitments.

Very truly yours,

NextEra Energy Point Beach, LLC

Enclosure

Regional Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW Mr. Mike Verhagan, Department of Commerce, State of Wisconsin

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

ENCLOSURE

RELIEF REQUEST RR-4L1

NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT UNITS 1 AND 2

10 CFR 50.55a REQUEST, RELIEF REQUEST RR4L1 INSERVICE INSPECTION IMPRACTICALITY

EXAMINATION LIMITATIONS DUE TO CONFIGURATION FOURTH TEN-YEAR INSERVICE INSPECTION PROGRAM INTERVAL

ASME Code Component(s) Affected

Code Class:

Examination Category:

Description:

1 and 2

B-A, B-Dl B-K, C-B

Listed In Table 4L1-1

Applicable ASME Code Edition and Addenda

ASME Section XI, 1998 Edition through 2000 Addenda.

Applicable Code Requirement

ASME Section XI requires examination of 100 percent of the weld length as defined in the applicable Code Tables and shown in the applicable Code Figures. The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory Guide 1.147, Revision 16, allows credit for essentially I00 percent coverage of welds provided greater than 90 percent of the required volume has been examined.

Reason for Request

Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the 100 percent coverage of the subject weld(s) due to geometric or design configuration, which limited the examination coverage which can be obtained.

Proposed Alternative and Basis for Use

Proposed Alternative:

There are no alternative examinations proposed. The subject welds received a volumetric or surface examination to the maximum extent practical utilizing the best available techniques on the accessible portions of the weld. Additionally, a visual (VT-2) examination is performed each refueling outage or once each period during the system

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leakage test as required by Section XI. Based on the volumetric or surface examination coverage attained with acceptable results, along with the VT-2 examination performed with acceptable results, it is reasonable to conclude that service-induced degradation would be detected, which provides an acceptable level of quality and safety for the subject welds.

Duration of Proposed Alternative

Relief is requested for the fourth 10-year inservice inspection interval for Point Beach Nuclear Plant, Units 1 and 2, which began on July 1, 2002 and ended on July 31, 2012.

Precedents

Similar relief requests documenting limited examinations have been granted to the following plants:

NRC Letter to Point Beach Nuclear Plant, Dated January 28, 2000, Point Beach Nuclear Plant, Units 1 and 2 - Safety Evaluation Regarding Relief Requests Associated with the Third 10-Year Inservice Inspection (ISI) Interval (TAC Nos. MA5234 and MA5235), (ML003677847) NRC Letter to Point Beach Nuclear Plant, Dated September 1, 2004, Point Beach Nuclear Plant, Units 1 and 2, Re: Request for Relief from American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section XI, Required Examination Coverage (TAC Nos. MB9932 and MB9933), (ML042380592)

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Table 4Ll- I Limited Examinations of Vessels and Welded Attachments for the Fourth IS1 Interval

Point Beach Unit I Component Identification / 1 Figure 1 Category 1 System or I Exam I Exam I Limitation Description Description RPV-17-683 Lower Shell to Lower Head Ring RPV-02-686-A Outlet Nozzle to Shell at 28.5" RPV-02-686-C Outlet Nozzle to Shell at 208.5" RPV-687-0 1 -A Safety lniection Nozzle to Shell

No. N/A

N/A

N/A

at 288.5" RPV-687-01 -B Safety lniection Nozzle to Shell

N/A

at 108.5" PZR-SPRAYNOZ-IRS Inside Radius Section

lnside Radius Section PZR-SAFNOZ-2-IRS

/Item No. B-A / Bl.11 B-A / B3.90 B-A I

NIA

PZR-SAFNOZ-1 -IRS

lnside Radius Section RHE-IWA-1

B3.90 B-A / B3.90

4L1-1

Welded Attachment #I

Component Reactor Vessel Reactor Vessel Reactor

B-A / B3.90

4L1-2

SG-B-7 Shell to Main Steam Nozzle

Vessel Reactor Vessel

B-D / 83.1 10

Coverage 72.7%

76.6%

76.2%

Reactor Vessel

B-D /

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67.9%

Pressurizer

4L1-3

4L1-4

4L1-5

Technique AUT

AUT

AUT

65%

Pressurizer

Limited due to proximity of core barrel anti- rotation lugs. Limited due to proximity of nozzle integral extension. Limited due to proximity of nozzle integral

AUT

73.3%

B3110 B-D / B3.110 B-K / 810.10

C-B/ C2.21

extension. Limited due to proximity of nozzle integral extension.

AUT

81.6%

Limited due to proximity of nozzle integral extension.

UT

Pressurizer

Regenerative Heat Exchanger

Steam Generator

Examination limited due to permanent insulation straps (14.7%) and raised lettering (cast-in) on

UT head (12%). Examination limited due to permanent insulation

81.6%

75%

77.45%

UT

PT

UT

straps. Examination limited due to permanent insulation straps. Examination limited 1/2 inch on either end of the top attachment due to excessive bleed-out from non-welded portions (attachment is welded on front and back only). 100% coverage obtained in 1 axial direction. 54.9% coverage obtained in CW / CCW direction. Limitation due to configuration.

Table 4Ll-1 Limited Examinations of Vessels and Welded Attachments for the Fourth IS1 Interval

Point Beach Unit 2 Component Identification I Description RPV-I 7-683 Lower Shell to Lower Head Ring RPV-02-686-A Outlet Nozzle to Shell at 28.5" RPV-02-686-C

Figure No. N/A

N/A

Outlet Nozzle to Shell at 208.5" RPV-687-0 1 -A

N/A

Safety Injection Nozzle to Shell at 288.5" RPV-687-01 -B Safety Injection Nozzle to Shell

lnside Radius Section I IB3.110 I I

Category /Item No. B-A / B1. l l B-A /

N/A

at 108.5" PZR-SPRAYNOZ-I RS

I I I I

PZR-SAFNOZ-1 -I RS I 4L1-2 I B-D / I Pressurizer 1 81.6%

B3.90 B-A /

NIA

System or Component Reactor Vessel Reactor

B3.90 B-A /

4L1-1

Vessel Reactor

B3.90

B-A I B3.90

Inside Radius Section PZR-SAFNOZ-2-1 RS

Welded Attachment # I

Exam Coverage 72.1 %

80.2%

80.8% Vessel Reactor

B-D /

Inside Radius Section RHE-IWA-1

Limitation Description Exam Technique AUT

AUT

63% Vessel

Reactor Vessel

4L1-3

Limited due to proximity of core barrel anti- rotation lugs. Limited due to proximity of nozzle integral

63%

Pressurizer

4L1-4

88%

B3.110 B-D /

AUT

B3.110 B-K I

extension. Limited due to proximity of nozzle integral

AUT

Pressurizer

extension. Limited due to proximity of nozzle integral extension.

AUT

81.6%

Reaenerative

Limited due to proximity of nozzle integral extension.

UT

75%

Examination limited due to permanent insulation

UT

straps (14.7%) and raised lettering (cast-in) on - . head (12%). Examination limited due to permanent insulation

UT

PT

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straps. Examination limited due to permanent insulation straps. Examination limited % inch on either end of the top attachment due to excessive bleed-out from non-welded portions (attachment is welded on " I front and back only). .

Figure 4L1-1

Manway

Pressurizer Spray Nozzle Limitations (Typical)

Area of no scan due to insulation ring - Area of no scan due to raised lettering (Cast in Head)

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Figure 4Ll-2

Manway

Pressurizer Limitations Safety Nozzle 1 Inside Radius Examination

PZR-SAFNOZ- 1 -1RS (Typical)

Area of no scan due to insulation strap.

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Figure 4L1-3

Manway

Pressurizer Limitations Safety Nozzle 2 Inside Radius Examination

PZR-SAFNOZ-2-IRS (Typical)

Area of no scan due to insulation strap.

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Figure 4L1-4

Regenerative Heat Exchanger Welded Attachments

Attachment 1 welded on two sides (back and fiont) only. Welds are 3 inches long. Only the middle 2 inches can be examined due to

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Figure 4L1-5

PBNP Unit I Steam Generator Main Steam Outlet Nozzle Examination Coverage Plot

G

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